United States Office of
Environmental Protection Emergency and
Agency > Remedial Response
EPA/ROD/R01 -91/063
September 1991
SEPA
Superfund
Record of Decision:
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50272.101
REPORT DOCUMENTATION 1" REPORT NO. 1 ~ 3. A8c:IpIent'. A-.lon No.
PAGE EPA/ROD/ROl-91/063
4. 1ItI8 IIId SubIIII8 5. Report Dille
SUPERFUND RECORD OF DECISION 09/27/91
Sullivan's Ledge, MA 6.
First Remedial Action - Final
7. AuIIarC.) a. l'8Iforming 0Ig8nlD1lon A8pI. NO'
8. I'WforINng Org8/nlZ8llon ...... IIId Addrw88 10. PIoj8ctlT88klWorII UnIt No.
11. Contr8ct(C) or Gr8IIt(G) No.
(C)
(G)
1~ Sponaorlng OrglUllz8lon ....... and Add- 13. Typa of Report. PerIod Co","
U.S. Environmental Protection Agency 800/000
401 M Street, S.W.
washington, D.C. 20460 1..
15. ~WY""'"
18. Ab8lr8ct (Umlt: 2IXI wonla)
The Sullivan's Ledge site consists of a 12-acre former quarry site/disposal area and
14.5 acres of downgradient wetlands areas in New Bedford, Bristol County,
Massachusetts. Land use in the area is predominantly municipal. The downgradient
portion of the site, which is the focus of this Record of Decision (ROD), includes
two wetlands areas: a 13-acre wooded wetland called Middle Marsh bordering the
Unnamed Stream and a 1.S-acre wetland area 400 feet upstream from Middle Marsh called
the "adjacent wetlands". In addition, the site includes portions of golf course
fairways, and associated floodplains and watershed areas. The entire site lies
within the 25- and 100-year floodplains of a tributary of the Unnamed Stream to the
south and the Apponagansett Swamp to the north. Prior to 1930, 12 acres of the site
were used as a granite quarry. From the 1930's to 1970's, the City of New Bedford
acquired the property and used the quarry pits and nearby areas were used for
disposal of hazardous materials including electrical transformers and capacitors,
fuel oil, volatile liquids, and other industrial wastes. From 1988 to 1990, several
EPA investigations identified contamination by PCBs and PAHs in surface and
subsurface sediment, soil, and biota; and VOCs and inorganics in ground water.
(See Attached Page)
17. Document An.lyai. L De.criptor.
Record of Decision - Sullivan's Ledge, MA
First Remedial Action - Final
Contaminated Media: soil, sediment, sw
Key Contaminants: VOCs (toluene), other organics (PAHs, PCBs, pesticides, phenols),
b. 1denll1ier8l0pen-Ended Tenn. metals (lead)
c. COSA n ReIdIGroup
18. Av.lI.bllity 8.._t 18. Security 0... (1111. Report) 21. No. of P.ge.
None 294
20. Security 0... (1111. P.ge) 22. PrIce
None
Sea ANSI..z38.18 SH/II8tructlOll8 on ReW,. .,,)
(Formerly NTl8-35)
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EPA/ROD/ROl-91/063
Sullivan's Ledge, MA
First Remedial Action - Final
Abstract (Continued)
Contamination has resulted in part from contaminated sediment migrating from the
disposal area via the Unnamed Stream and deposition in Middle Marsh during stream
flooding. A 1989 ROD for the first Operable Unit (OU1) addressed source control of the
disposal area and the Unnamed Stream. This ROD addresses the Middle Marsh as OU2. The
primary contaminants of concern affecting the soil, sediment, and surface water are
VOCs including toluene: other organics including PAHs, PCBs, pesticides, and phenols:
and metals including lead.
The selected remedial action for this site includes excavating and dewatering
approximately 5,200 cubic yards of contaminated sediment and soil from portions of
Middle Marsh and the adjacent wetlands: solidifying/stabilizing the excavated materials
as needed to comply with RCRA LDR rules: treating water extracted from excavated
materials using carbon adsorption, followed by onsite discharge to the Unnamed Stream:
onsite disposal of the excavated materials beneath the cap that will be constructed
over portions of the disposal area as part of OU1: restoring affected wetlands;
conducting long-term environmental monitoring; and implementing institutional controls
to prevent future residential use of Middle Marsh and the adjacent wetlands. If the
disposal area in OU1 has already been capped when materials from OU2 are excavated and
ready for disposal, a contingency remedy will be implemented. This contingency remedy
includes treating the excavated soil/sediment using solvent extraction, and treating
the extracted oil containing PCBs and other organic chemicals offsite using
incineration; treating residual water using carbon adsorption; disposing of the treated
sediment/soil at Middle Marsh; restoring affected wetlands; conducting long-term
environmental monitoring; and implementing institutional controls to prevent future
residential use of Middle Marsh and the adjacent wetlands. The estimated present worth
cost for this remedial action is $2,800,000, which includes a present worth O&M cost of
$164,000. The estimated present worth cost for the contingent remedy is $7,780,000,
which includes a present worth O&M cost of $164,000.
PERFORMANCE STANDARDS OR GOALS: Soil, sediment, and surface water clean-up goals are
based on an excess lifetime cancer risk of 10 -4 to 10 -6 and an HI=l. The sediment/soil
clean-up level for aquatic areas in Middle Marsh is the interim mean sediment quality
criterion of 20 ug of total PCBs per gram of carbon (ug/Gc). This will result in
interstitial water concentrations equal to or lower than the PCB ambient water quality
criteria of 0.014 ug/l. The sediment/soil clean-up level for non-aquatic areas in
Middle Marsh and for the adjacent wetland is total PCBs 15 mg/kg. This will protect
mammals from chronic. adverse effects from wetland/terrestial exposure to contaminated
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Declaration of Record of Decision
Remedial Alternative Selection
site Name and Location
Sullivan's Ledge Superfund Site
Middle Marsh Operable Unit
New Bedford, Massachusetts
Statement of PurDose
This Decision Document presents the selected remedial action for
the Sullivan's Ledge - Middle Marsh Operable Unit developed in
accordance with the Comprehensive Environmental Response,
Compensation, and Liability Act of 1980 (CERCLA), as amended by
the Superfund Amendments and Reauthorization Act of 1986 (SARA),
and to the extent practicable, the National Contingency Plan
(NCP); 40 CFR Part 300, SS Federal Register 8666 (March 8, 1990).
The Commonwealth of Massachusetts has concurred with the selected
remedy and the contingency remedy.
Statement of Basis
This decision is based on the Administrative Record which was
developed in accordance with Section 113(k) of CERCLA and which
is available for public review at the information repositories
located in the New Bedford Free Public Library, New Bedford,
Massachusetts, and at 90 Canal Street, Boston, Massachusetts.
The attached index identifies the items which comprise the
administrative record upon which the selection of the remedial
action is based.
~ssessment of the Site
Actual or threatened releases of hazardous substances from this
site, if not addressed by implementing the response action
selected in this ROD, may present an imminent and substantial
endangerment to the environment.
Description of the Selected Remedv
The selected remedial action for the Sullivan's Ledge Site -
Middle Marsh Operable Unit consists of the following source
control components:
1.
Site preparation;
2.
Excavation of contaminated sediments and soils from portions
of Middle March and the adjacent wetlands;
3.
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2.
3.
4.
5.
6.
7.
..
4.
Disposal of the materials beneath the cap that will be
constructed ~ver portions of the Disposal Area of the
Sullivan's Ledge site;
5.
Restoration of the affected wetlands;
Institutional controls to prevent future residential use of
Middle Marsh and the Adjacent Wetland; and
6. -
7.
Long-term environmental monitoring.
Because implementation of the selected remedy is dependent upon
the Sullivan's Ledge Disposal Area-being available for disposal
of Middle Marsh sediments and soils, a contingency remedy has
also been selected consisting of the following components:
1.
Site preparation;
Excavation of contaminated sediments and soils from portions
of Middle March and the Adjacent Wetland;
Treat~ent of the excavated sediments by solvent extraction;
and Treatment of the concentrated oil extract by off-site
incineration;
Disposal of treated sediment/soils at Middle Marsh;
Restoration of the affected wetlands;
Institutional controls to prevent future residential use of .
the restrict access ~o Middle Marsh and the Adjacent
Wetland; and
Long-term environmental monitoring.
EPA has determined that if additional design activities necessary
to implement the selected remedy for the Middle Marsh Operable
Unit are not completed in time to integrate the design elements
for the Middle Marsh Operable Unit into the Remedial Design
(which is to be submitted and approved under schedules approved
according to the Consent Decree for the First Operable Unit),
then the contingency yemedy shall be implemented.
Declaration
The selected remedy and contingency remedies are protective of
human health and the environment. The remedies satisfy the
statutory preference for treatment that permanently and
significantly reduces the volume, toxicity and mobility of the
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element. The selected remedy and contingent remedies also
utilize permanent solutions and alternative treatment
technologies to the maximum extent practicable, and are cost-
effective. The selected remedy and contingency remedies attain
federal and state requirements that are applicable or relevant
and appropriate (ARARs).
b.~f Iff I
DAT )
Ju e Belaga
gional Administra
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REGIO.
z
UCORD OF DBCISZOIf StJXDRy
SULLIVAN'S LEDGE SUPERFUND SITE
MIDDLE MARSH OPERABLE UNIT
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Contents
II.
III.
IV.
VI.
VII.
VIII.
IX.
%.
%1.
%11.
~.
v.
SULLIVAN'S LEDGE - MIDDLE MARSH OPERABLE UNIT
~A~LE OF CONTENTS
SI~E NAME, LOCA~ION AND DESCRIPTION.
. . . . . . . .
SITE HISTORY' ENFORCEMENT ACTIVI~IBS .
. . . . . . .
A.
B.
Land Use' Response History. . . . . . . . . . .
Enforcement History. . . . . . . . . . . . . . .
COMMUNITY PARTICIPATION. . .
. . . . . . . . . . . .
SCOPE' ROLE OF OPERABLE UNIT OR RESPONSE ACTION
. .
SU¥~Y OF SITE CHARACTERISTICS
. . . . . . . .
. . .
SUMMARY OF SITE RISKS. .
. . .
. . . . . . . . . . .
DEVELOPMENT AND SCREENING OF ALTERNATIVBS
. . . . . .
A.
B.
Statutory Requirements/Response Objectives. . .
Technology and Alternative Development
and Screening. . . . . . . . . . . . . . . . . .
DESCRIPTION OF ALTERNATIVES. . . . . . .. .
. . . . .
SUY~~Y OF THE COMPARATIVE ANALYSIS OF ALTERNATIVES.
THE SELECTED REMEDY. . . . . . .
A.
B.
. . .
. . . .
. . .
Cleanup Levels. . . . . . . . . . . . . . . . .
Description of the Remedial Components. . . . .
A.
STATUTORY DETERMINATIONS
. . . . .
B.
C.
D.
E.
. . .
. . .
. . .
The Selected Remedy is Protective of Human
Health and the Environment. . . . . . . . . . .
The Sele.cted Remedy Attains ARARs . . . . . . . .
The Selected Remedial Action is Cost Effective
The Selected Remedy Utilizes Permanent Solutions
and Alternative Treatment or Resource Recovery
Technol~~ies to the Maximum Extent Practicable
The Sele~ted Remedy Satisfies the Preference
for Treatment as a Principal Element. . . . . .
DOCUMENTATION OF SIGNIFICANT CHANGES
. . . . . . . .
Paae Number
1
1
1
4
4
6
7
18
30
30
31
32
36
48
49
50
62
62
65
71
73
75 .
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LIST op PIGORES
:Fiaure Number
paoe Number
1 Map of Sullivan's Ledge Site . . . . . . . . . . . '9
2 . Extent of Flooding in MM and the Golf Course . . . 80
3 Wetland Delineation in Middle Marsh and Adjacent
Wetland . . . . . . . . . . . . . . . . . . . . . 81
4 . PCB contours for Middle Marsh . . . . . . . . . . 82
5 PCB contours f~r Adjacent Wetland . . . . . . . . 83
6 Biota Samplinq Stations . . . . . . . . . . . . . 84
7 Aquatic Area * Non-Aquatic Areas . . . . . . . . . 85
8 Food Chain Model . . . . . . . . . . . . . . . . . 86
9 Areas requiring Remediation . . . . . . . . . . . 87
LIST OP TABLES
'Table Number
11
Paoe Number
1
2
Lists of Animal Species. . . . . . . . . . . . .
Tables of Detected Contaminants in Surficial
Sediment/Soils. . . . . . . . . . . . . . . . .
Table of Detected Contaminants in Surface Water
PCB Concentrations in Biota Samples Collected
in Middle Marsh (Charter, 1991) . . . . . . . . .
Summary of Chemicals of Potential Concern. . . .
Total Risks Associated with Current Land-Use. . .
Total Risks Associated with Future Land-Use. . .
Seven Alternatives advanced for detailed
evaluation. . . . . . . . . . . . . . . . . . .
Location Specific ARARS, Criteria, Advisories, and
Guidance for Middle Marsh. . . . . . . . . . . .
Action Specific ARARs for the Selected Remedy Exca-
vation and Disposal at Sullivan's Ledge Disposal
Area. . . . . . . . . . . . . . . . . . . . . .
Action Specific ARARs for the Contingency Remedy
Solvent Extraction. . . . . . . . . . . . . . .
88
92
94
3
4
5
6
7
8
95
96
97
98
9
99
10
100
103
109
APPENDICES
Responsiveness Summary. . . . . . . . . . . . . . . .
Administrative Record Index. . . . . . . . . . . . . .
State Concurrence Letter. . . . . . . . . . . . . . .
Appendix A
Appendix B
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ROD DECISION Su.KKARY
SEPTEMBER 27, 1111
7.
SITE NAME, LOCATION AND DESCRIPTION
The Sullivan's Ledge Site ("the Site") consists of two operable units: the
First Operable Unit which was the subject of a Record of Decision issued on
June 29, 1989 (the "1989 ROD"); and the Middle Marsh Operable Unit, which
is the subject of this ROD. Figure 1 shows the rough boundaries of the
Sullivan's Ledge Site and the Middle Marsh Operable Unit. The First
Operable Unit includes a11 areas within the Sullivan's Ledge Site, except
for those areas in the Middle Marsh Operable Unit.
The Sullivan's Ledge Middle Marsh Operable Unit, the second operable unit
of the Sullivan's Ledge Superfund Site, is located within the New Bedford
Municipal Golf Course north of Hathaway Road in New Bedford, Bristol
County, in southeastern Massachusetts. The Middle Marsh Operable Unit is
bounded on the south by the southern banks of the tributary of an unnamed
stream (the "Unnamed Stream"), on the north by the Apponagansett Swamp and
on the east and west by fairways of the New Bedford Municipal Golf Course
(see Figure 1). This operable unit excludes the Unnamed Stream, which
travels from culverts under Hathaway Road, continues northward across the
golf course in a well-defined channel, bisects Middle Marsh and eventually
drains into the golf course water hazards.
The study area for this operable unit includes a 13-acre wooded wetland
called Middle Marsh, a 1.5 acre wetland area bordering the Unnamed Stream
400 feet upstream of Middle Marsh (the "Adjacent Wetland"), and portions of
the golf course fairways and associated floodplains and watershed areas.
All wetlands in the study area are classified as bordering vegetated
wetlands under the Massachusetts Wetland Protection Regulations, 314 CMR
10.00. "Based on hydrologic sampling and quantitative hydrologic and'
hydraulic studies, the entirety of Middle Marsh and large areas of the golf
course lie within the 25 and 100 year floodplains (see Figure 2).
The primary focus of this ROD is Middle Marsh, because sedimentary
contamination migrates from the Sullivan's Ledge Disposal Area via the
Unnamed Stream and is deposited in Middle Marsh during periods of stream
flooding. Middle Marsh is predominantly a freshwater wetland consisting
of palustrine broad-leaved deciduous forested wetland. Based on the
results of the wetland delineation, additional wetland areas identified in
Middle Marsh include emergent wetlands, scrub-shrub wetlands and forested
upland areas (see Figure 3).
A ~ore complete description of the Site can be found in the "Final Remedial
Investigation Report - Additional Studies of Middle ~arsh" (Metcalf and
Eddy, 1991a) in Chapters 1 and 2 of Volume I.
71.
SITE HISTORY AND ENFORCEMENT ACTIVITIES
A.
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2
The United States Environmental Protection Agency (EPA) conducted an
air monitoring program of the Greater New Bedford Area in 1982 and
installed groundwater monitoring wells around the SUllivan's Ledge
Site in 1983. Based, in part, on the results of these studies, the
Sullivan's Ledge Site was included on the National Priorities List in
September 1984.
The twelve-acre Sullivan's Ledge Disposal Area (located in the area of
the First Operable Unit) is a former granite quarry. Four granite
quarry pits with estimated depths up to 150 feet have been identified
from historical literature and field investigations. After quarrying
operations ceased, the land was acquired by the City of New Bedford.
Between the 1930s and the 1970s, the quarry pits and nearby areas were
used for disposal of hazardous materials including electrical
transformers and capacitors, fuel oil, volatile liquids and other
industrial waste.
The Sullivan's Ledge Superfund Site, including the Disposal Area and
downgradient areas, was the subject of Phase I (Ebasco, 1987) and
Phase II (Ebasco, 1989a) remedial investigations, and a feasibility
study (Ebasco, 1989b) which was completed in January 1989. These
field investigations revealed high concentrations of polychlorinated
biphenyls (PCBs) and polyarornatic hydrocarbons (PAHs) in surface and
subsurface sediment/soils. In addition, the sampling results
indicated the presence of volatile organic compounds (VOCs) and
inorganics in groundwater sampled from the network of wells installed
in the study area. Based on the results of the two RIs, EPA concluded
that the sources of contamination within the Sullivan's Ledge study
area are the wastes disposed of in the former quarry pits,
contaminated soils in the 12-acre Disposal Area, and sediments that
wash off the Disposal Area. In particular, the remedial
investigations revealed that PCBs and other contaminants have ~:gra~e~
from the Disposal Area to the Unnamed Stream and the Middle Marsh.
Operable Unit.
U.S. EPA Region I issued a Proposed Plan for the Site on February 6,
1989. On June 29, 1989, EPA Region I issued a Record of Decision
(ROD) for the First Operable Unit, outlining remedial action for the
. Disposal Area and nearby areas including the Unnamed Stream. The
remedial action selected in the ROD consists of source control and
management of migration components. As described in the June 29, 1989
ROD, the remedy for the First Operable Unit includes the following
components:
1.
2.
Fencing and site preparation;
Excavation and on-site solidification/stabilization of
contaminated soils in the unsaturated zone at the Disposal Area.
Excavation and on-site solidification (if necessary) of
contaminated soils in the unsaturated zone in areas immediately
east and north of the Disposal Area. All excavated and/or
solidified soils shall be disposed on the Disposal Area under the
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7.
8.
9.
3
3.
Excavation/dredging, dewatering, solidification/stabilization (if
necessary) and on-site disposal of contaminated sediments from
the Unnamed Stream up to and including the two golf course water
hazards;
Construction ,of an impermeable cap over approximately 11 acres of
the Disposal Area;
Temporary diversion and lining of a portion of the Unnamed
Strealll;
Construction and operation of passive and active groundwater
collection, extraction, treatment and discharge systems;
Implementation of a wetlands restoration and maintenance program;
Long-term monitoring; and
Institutional controls.
4.
s.
6.
In its 1989 Proposed Plan, EPA presented three possible options for
addressing conta~ination found in Middle Marsh. These options
included a No-Action alternative, which called for no cleanup
activities to occur within Middle Marsh, and two alternatives which
called for excavating sediments that contained PCBs at concentrations
that may cause long-term impacts to aquatic organisms. The two action
alternatives differed in the amount of sediment/soils that would be
excavated, resulting in different residual levels of PCBs in the area.
In the 1989 Proposed Plan, EPA sought comments on the various cleanup
alternatives for Middle Marsh, and initially proposed the No-Action
alternative, stating that removal of the contaminated sediments in all
areas of Middle Marsh which exceeded the interim sediment quality
criteria might cause more harm to the environment than would leaving
the contaminated sediments in place. Because Middle Marsh is located
within a heavily used golf course and because of the high ecological
value of the wetlands, EPA was especially interested in comments on
the three remedial alternatives considered for Middle Marsh.
After further consideration, EPA concluded in June 1989 that
additional studies of Middle Marsh and the Adjacent Wetland would be
necessary to: (1) determine with greater accuracy the nature and
extent of contamination in the area; (2) compare the potential
environmental impacts of conducting cleanup activities to the impacts
of site contamination; and (3) further identify any potential risk to .
human health and the environment posed by the contamination. Thus,
the study and remediation of Middle Marsh and the Adjacent Wetland was
separated into a second operable unit, called the Middle Marsh
Operable Unit. The "Remedial Investigation - Additional Studies of
Middle Marsh" (Metcalf and Eddy, 1991a) was completed in April 1991
and the "Feasibility Study of Middle Marsh" (Metcalf and Eddy, 1991b)
was completed in May 1991. EPA issued a Proposed Plan for the Middle
Marsh Operable Unit on May 29, 1991. A sixty-three day comment period
to accept comments from the public on the proposed remedial
alternatives followed.
A more detailed description of the site history can be found in the
"Phase I Remedial Investigation Report; June 1987" in Chapter 1 of
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4
Middle Marsh" in Chapter 1 of Volume I.
B.
Enforcement Hi.tory
In September 1984, EPA issued the owner of the Site, the City of New
Bedford, an Administrative Order under Section 106 of the
Comprehensive Environmental Response, Compensation and Liability Act
of 1980. (CERCLA) requiring the City to secure the former disposal area
by installing a perimeter fence and posting signs warning against
unauthorized trespassing. .
Between November 1988 and May 1990, EPA notified 23 parties who either
owned or operated the Site, generated wastes that were shipped to the
Site, arranged for the disposal of wastes at the Site, or transported
wastes to the Site that they were potentially liable for response
costs incurred with respect to the Site. On April 6, 1990, EPA began
negotiations with the potentially responsible parties (PRPs) for
performance of the remedial design and remedial action at the First
Operable Unit.
Fourteen PRPs formed a steering committee and substantial negotiations
took place. In September 1990, EPA, the Commonwealth of
Massachusetts, and fourteen PRPs reached a settlement with respect to
the First Operable Unit. This settlement was approved by the United
States District Court in April, 1991. Under the terms of the
settlement, the 14 companies agreed to: (1) construct the remedy
called for in the 1989 ROD; (2) perform operation and maintenance for
thirty years after completion of construction of the remedy for the
First Operable Unit; (3) pay a portion of EPA's and the
Commonwealth's past costs of conducting studies at the Site; and (4)
pay a portion of EPA's and the Commonwealth's costs of overseeing the
design and construction of work to be performed at the First Operable
Unit. Design of the cleanup plan for these portions of the Site, .
including the Disposal Area, is currently underway.
Several PRPs have been active in the remedy selection process for the
Middle Marsh Operable Unit. Technical comments presented by PRPs
during the public comment period were summarized in writing, and the
summary and written responses were included in the Administrative
Record.
~II. CO¥~UNITY PARTICIPATION
The Sullivan's Ledge Site was originally included as part of the New
Bedford Harbor sitel known as the Greater New Bedford Superfund site.
The level of cornrnuni~y concern about the Greater New Bedford site was
quite high during the fall of 1984, when an open house was held by EPA
to explain cleanup options for PCB "hot spots," and a public hearing
was held to obtain comments from citizens and local agencies and
organizations. About that same time, the EPA and the Massachusetts
Department of Public Health announced the start of a three-year health
-------
5
indIviduals to determine the level of PCBs in their bloodstream.
provided funding for the study.
other public meetings were held to discuss findings or information
about the New Bedford sites in January and October of 1985. At the
October 1985 meeting, EPA announced the decision to separate the
Sullivan's Ledge Site from the Greater New Bedford Superfund site and
to include the Sullivan's Ledge Site on the National Priorities List
(NPL). The decision to create a separate site was based on the
following considerations: .
EPA
1.
The severity of the problem and the environmental complexity of
the Sullivan's Ledge Site.
Environmental diversity between harbor areas (aquatic) and the
Sullivan's Ledge Site (primarily wetlands and uplands).
2.
3.
Difference in the range of contaminants found.
4.
Possible differences in potentially responsible parties (PRPs) at
the sites.
5.
Degree to which separate management would facilitate activities
at the sites.
In September 1986, EPA issued a community relations plan which
outlined a program to address community concerns and to keep citizens
informed about activities during remedial activities. On July 20,
1988, EPA held an informational meeting to present the results of the
Phase II Remedial Investigation and to answer questions from the
public.
An administrative record for the First Operable Unit was prepared and
made available to the public on February 6, 1989. On that same date,
EPA held an informational meeting to discuss the cleanup alternatives
presented in the Sullivan's Ledge Feasibility Study (Ebasco, 1989b)
and to present the EPA's Proposed Plan. From February 6 to March 27,
1989, the Agency held a forty-nine day public comment period to accept
public comment on the alternatives presented in the Feasibility Study
and the Proposed Plan for the First Operable Unit and on other
documents available to the public. On February 21, 1989, the Agency
held a public hearing to accept oral comments. A transcript of this
hearing, a summary of written comments, and the comments and EPA's
response to comments ~ere att~ched to the 1989 ROD.
Community concern about and involvement with to the Middle Marsh
Operable Unit has been moderate. EPA has kept the community and other
interested parties apprised of site activities through informational
meetings, fact sheets, press releases and public meetings.
On May 29, 1991, EPA held an informational meeting in New Bedford to
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IV.
6
(Metcalf and Eddy, 1991a), the cleanup alternatives presented in the
Feasibility Study (Metcalf and Eddy, 1991b) and to present the
Agency's Proposed Plan. Also during this meeting, the Agency answered
questions from the public.
On May 30, 1991, EPA made the administrative record available for
public review at EPA's offices in Boston and at the New Bedford Free
Public Library. EPA published a notice and brief analysis of the
Proposed Plan in the New Bedford Standard Times on May 24, 1991 and
made the plan available to the public at the New Bedford Free Public
Library. In the proposed plan, EPA specifically sought comments on
the following: (1) site cleanup plans; (2) the impacts of site cleanup
activities on the wetlands and floodplains found at the Site; and (3)
possible use of a treatability variance to comply with RCRA land
disposal restrictions for each of the alternatives for which a
variance is required.
From May 30, 1991 to July 31, 1991, the Agency held a sixty-three day
public comment period to accept pUblic comment on the alternatives
presented in the Feasibility Study and the Proposed Plan and on any
other documents previously released to the public. On June 2~, 1991,
the Agency held a public hearing to discuss the Proposed Plan and to
accept any oral comments. A transcript of this meeting and the
comments and the Agency's response to comments are included in the
attached responsiveness summary.
SCOPE AND ROLE OF OPERABLE UNIT OR RESPONSE ACTION
In summary, the selected remedy for the Middle Marsh Operable Unit
consists of the following components:
1. Site preparation;
2. Excavation of contaminated sediment/soils from portions of Middle
Marsh and the Adjacent Wetland;
Dewatering of the excavated materials;
Disposal of the materials beneath the cap that will be
constructed over portions of the Disposal Area of the SUllivan's
Ledge Site;
Restoration of the affected wetlands;
Institutional controls to prevent future residential use of and
to restrict access to Middle Marsh and the Adjacent Wetland; and
Long-term environmental monitoring.
3.
4.
5.
6.
7.
Because implementation of the preferred alternative is dependent Upon
the Sullivan's ~dge Disposal Area being available for disposal of
Middle Marsh sediment/soils, a contingency remedy has also been
selected consisting of the following components:
1. Site preparation; .
2. Excavation of contaminated sediment/soils from portions of Middle
Marsh and the Adjacent Wetland;
Treatment of the excavated sediment/soils by solvent extraction;
Disposal of the treated sediment/soils at Middle Marsh;
Restoration of the affected wetlands;
3.
4.
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7
6.
Institutional controls to prevent future residential use of and
restrict access to Middle Marsh and the Adjacent Wetland; and
Long-term environmental monitoring.
7.
The contingency remedy would be implemented if EPA determines, after
consultation with the Massachusetts Department of Environmental
Protection (MADEP), that design activities necessary to implement the
selected remedy for Middle Marsh are not completed in time to
integrate the design elements for the Middle Marsh Operable Unit into
the remedial design for the First Operable Unit, 50 that the Disposal
Area could not be used for the containment of excavated sediment/soils
from Middle Marsh and the Adjacent Wetland without delaying the
implementation of the First Operable Unit.
The remedial action for the Middle Marsh Operable Unit, as described
in this ROD, addresses the principal threats to the environment posed
by exposure of biota to contaminated sediment/soils in Middle Marsh
and the Adjacent Wetland. This remedy, in conjunction with the
selected remedy for the First Operable Unit, addresses all principal
threats to human health and the environment posed by the sources of
contamination at the Sullivan's Ledge Site including contaminated
soils at the Disposal Area, PCB-contaminated sediments that have
migrated to the Unnamed Stream and wetland areas, and wastes disposed
of in the former quarry pits.
v.
SUMMARY OP SITE CHARACTERISTICS
The significant findings of the Remedial Investigation are summarized
below.
A.
General
Field investigations were conducted in the Middle Marsh Operable
Unit's study area in 1988, 1989 and 1990. The results of the
investigations revealed high concentrations of polychlorinated
biphenyls (PCBs) in surface soils, subsurface soils, sediments and
biota. Based on the results of the field investigations, EPA has
determined that erosion of soils from the Disposal Area into the
Unnamed Stream and wetland areas is the most significant pathway for
movement of PCBs. Airborne transport is of little consequence at the
Site.
The primary manner of distribution of PCBs in the environment is
adsorption to soils, so that the distribution of PCBs in the golf
course area mirrors that of sediment deposition along and from the
stream. In areas of frequent flooding and deposition in Middle Marsh,
PCB concentrations ~eYe generally in the range of 10 to 30 mg/kg. PCB
concentrations in the sediment/soil generally diminished to levels of
approximately 2 mg/kg at depths of one foot and deeper. Several heavy
metals including lead and zinc were detected, and the pattern of their
distribution in Middle Marsh is similar to that of the PCBs in the
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8
were generally within the range of background concentrations, but were
higher in Middle Marsh than in the Adjacent Wetland.
Volatiles and semivolatiles were found in the pore and surface water
samples from Middle ,Marsh and the Adjacent Wetland at levels near
detection limits. Similarly, many of the heavy metals were near
detection limits and were below ambient water quality criteria.
However, PCBs (Aroclor 1254) ~ere detected in filtered pore and
surface water samples at levels above 0.014 ~g/l, the PCB ambient
water quality criterion for protection of uses of aquatic life,
specifically the consumption of aquatic life by wildlife.
PCBs were found in the tissues of almost all animals sampled in Middle
Marsh during field studies. In particular, PCBs were detected in
tissue samples of aquatic insects, earthworms, frogs and small
animals, 'including mice and voles.
B.
Wetland and Habitat Delineation
A preliminary wetland delineation included a review of the U.S.
Geological Survey Topographical Map, the U.S. Department of
Agriculture Soi1 Conservation Service Soil Survey of Bristol County,
Massachusetts, and the National Wetland Inventory.
The U.S. Geological Survey map indicates that Middle Marsh is wooded
swamp or marsh. Five unnamed ponds are indicated in the area
surrounding Middle Marsh, and the Unnamed Stream is indicated flowing
through the center of Middle Marsh. Review of Soil Conservation
Service soil surveys indicated the widespread presence of hydric soils
in the vicinity of Middle Marsh and the golf course.
The National Wetlands Inventory indicates Middle Marsh is Palustrine
Forested Broad-Leaved Deciduous Wetland. The Middle Marsh forested
wetland is characterized by woody vegetation that is 6 meters tall'or
taller, with red maple as the dominant tree. In addition, five areas
of Palustrine Open Water are indicated to the north and southwest of
Middle Marsh.
EPA concluded that Middle Marsh was composed mainly of palustrine
forested deciduous wetland, with nearby palustrine open water in three
to five locations. Using the information from the literature review
as a basis, field investigations ~ere conducted in December 1989 and
May 1990 to delineate wetland boundaries, and to characterize further
all wetlands at the Site. Figure 3 depicts the wetland/upland
borders, as ~ell as distinct habitat types identified within and next
to Middle Marsh. As indicated in Figure 3, the following wetland
classes ~ere delineated and characterized within Middle Marsh: (1)
three areas of palustrine emergent persistent wetlands dominated by
the cornmon reed "phragmites australis"; (2) persistent emergent
wetlands with a mix of emergent, non-phragmites plant species, located
in the northern section of Middle Marsh; (3) palustrine scrub-shrub
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9
section of Middle Marsh and characterized by woody vegetation and
erect rooted herbaceous hydrophtes.
In.contrast to the largely forested Middle Marsh, the Adjacent Wetland
consists of palustrine emergent and scrub-shrub wetland, including a
large area of phra~ites wetland directly next to the Unnamed Stream.
c.
Flora and Fauna Investiaations
EPA undertook an investigation of the flora (plants) and fauna
.(animals) at the Middle Marsh Operable Unit. As part of this
investigation, EPA consulted with the Massachusetts Division of
Fisheries and Wildlife, Natural Heritage' Endangered Species Program
to determine the potential occurrence and distribution of any
threatened or endangered species including state listed "Species of
Special Concern." EPA also conducted direct observations and
recording of all wetlands flora and fauna encountered at the Middle
Marsh Operable Unit.
According to the Massachusetts Natural Heritage & Endangered Species
Program, two state-listed "Species of Special Concern", the spotted
turtle (Clemmys guttata) and the mystic valley amphipod (Crangonyx
aberrans), may occur on-site. The occurrence of both species has been
documented in the Apponagansett Swamp, which is contiguous to the
Site.
The spotted turtle is typically found in small, shallow water bodies,
frequently basking along the water's edge. It is omnivorous,
consuming insects, other invertebrates, and aquatic plants underwater.
Breeding occurs from March to May. Spotted turtles hibernate during
the winter on the muddy bottoms of small ponds, and may become dormant
for the late part of the summer. During the May 1990 field
investigation, spotted turtles were observed in Middle Marsh in the
northern part of the scrub-shrub wetland area about 500 feet from the
Unnamed Stream.
The Mystic Valley Arnphipod is primarily a nocturnal species occurring
in lowland aquatic habitats, especially in red maple swamps. They
feed on detritus surrounding the roots of plants, and breed in the
spring or early summer. This species was not observed on-site,
although EPA has determined that Middle Marsh may be suitable habitat
for the Mystic Valley Arnphipod. As described in Section X.B.l.d.,
prior to initiation of remedial activities, further investigations
will be perfor~ed to identify areas of Middle Marsh where the Mystic
Valley Amphipods may inhabit.
Flora and fauna observed at Middle Marsh and the immediate vicinity
are listed in Table 2-2 and Table 2-3 of the RI (Metcalf and Eddy,
1991a), respectively. In particular, animals observed at Middle Marsh
and the immediate vicinity include red-tailed hawk, american robin,
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5.
6.
7.
8.
10
D.
Wetland Functional Analvsis and Habitat Evaluation
An analysis of wetland functions and values was conducted for Middle
Marsh and the Adjacent Wetland using the U.S. Army Corps of Engineers
Wetland Evaluation Technique Volume II (WET II). WET II assesses
functions and values by characterizing a wetland in terms of its
physical, chemical and biological processes and attributes. The
results of the ~ET II evaluation of Middle Marsh are listed below:
1.
. Infiltration from Middle Marsh is not critical to groundwater
supplies in the area. Recharge may be somewhat inhibited in
Middle Marsh because the wetland is underlain by glacial till
which is composed largely of silty sand and may be somewhat
impervious;
2.
Middle Marsh is moderately effective in terms of floodwater
alteration as the area is relatively large, water is not
artificially removed, and the underlying soils do not have an
exceptionally slow infiltration rate;
Vegetated areas of Middle Marsh outside the stream channel are
highly effective for stabilizing sediment since vegetation is
dense in most areas and there is good water/vegetation
interspersion throughout the wetlands;
3.
4.
Middle Marsh is rated low for sediment/toxicant retention because
during average flow conditions in which the Unnamed Stream does
not flood into Middle Marsh, most of the flow and associated
sediments never leave the Unnamed Stream, passing directly into
the golf course ponds/hazards. Chemical data and direct
observations indicate, however, that during wet weather that
causes flooding of the Unnamed Stream, deposition of sediments
and removal of toxicants does OCcur in Middle Marsh;
Middle Marsh generally has a limited effectiveness and a moderate
opportunity to remove and transform nutrients;
Middle Marsh is highly effective in providing breeding, migration
and wintering habitat for wildlife. Table 1 lists animal species
typically associated with wetland cover types identified at
Middle Marsh;
Middle Marsh does not provide an abundance of ideal aquatic
habitat in that permanent open water within Middle Marsh is
limited to its main tributary and nearby permanently flooded
areas. These areas support aquatic life such as aquatic
invertebrates, tadpoles, mollusks, and crayfish;
Middle Marsh is highly significant in terms of
Uniqueness/Heritage because a species of special concern, the
spotted turtle, is known to inhabit Middle Marsh. In addition,
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11
site.
Adiacent Wetland
Due to its general topography and subsurface geology, the Adjacent
Wetland is likely ineffective for ground~ater recharge and discharge.
The Adjacent Wetland does not function effectively for flood
attenuation because of its small size and relatively steep slopes.
With dense vegetation abutting the stream bank, this area could
provide reduction of sediments and toxicants, and removal and
transformation of nutrients, as well as stabilization of sediments
despite rapid overbank stream flow velocities. Due to the area's
relatively small size, homogeneous cover type, and absence of
characteristics such as tree cavities for protective cover and seed or
nut producing tree or plants, the area does not have exceptional
habitat value, but could support various species of birds and
nocturnal mammals.
E.
Surficial Sediment/Soils
Surficial sediment/soils were sampled to define more clearly the
horizontal extent of contamination as well as to investigate the
relationships bet~een contaminant concentrations, elevation, frequency
of flooding, soil description and vegetation cover type. Tables of
detected contaminants in surficial sediment/soils are presented in
Appendix E-l of the "Remedial Investigation - Additional Studies of
Middle Marsh" and are summarized in Table 2 of this ROD. Contaminant
patterns in surficial sediment/soils for PCBs, volatiles,
semivolatiles and metals are summarized below.
1.
Polychlori~ated Biphe~yls
.
PCB Aroclor 1254 was the only Aroclor detected in the study area.
This is consistent with the results of previous studies. Figure
4 shows the individual and contoured PCB concentrations above 5
mg/kg in Middle Marsh, assuming that the stream influences the
distribution of sediment equally on both sides of the stream.
Individual and contoured PCB concentrations at surficial stations
in the Adjacent Wetland and golf course areas are depicted in
Figure 5.
Twenty-seven of the thirty stations sampled in Middle Marsh
during the current investigation had PCB contamination in
surficial sediment/soils. ~s illustrated by Figure 4, the
highest PCB concentrations in Middle Marsh were found near the
Unnamed Stream and in the most upstream areas. In general,
sedirnent/soil concentr~~ions appear to be correlated with
elevation and the frequency of flooding, especially in areas near
the stream that flood at an interval of 3 months or more (see
Figure 2). An additional trend indicates decreasing
concentrations with distance from the stream despite an
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~2
concentrations were found near the Unnamed stream, confirming
that the Unnamed Stream is the source of contamination.
PCB sampling results from the current investigation are
consistent with samples collected in Middle Marsh as part of the
1989 RI and wi~h samples collected by EPA. To the north of the
Unnamed Stream, concentrations at stations ME15 (13 mg/kg), ME29
(5.6 mg/kq), HE1' (24 mg/kg), ME2 (S.8 mg/kg) and ME30 (4.1
mg/kg) decrease with distance from the Unnamed Stream within an
elevation range of less than one foot. Similarly, concentrations
. decrease with distance in forested wetland to the south of the
Unnamed Stream, as seen at stations ME14 (19 mg/kg), ME16 (5.'
mg/kg) and ME23 (0 mg/kg). Stations ME1 (20 mg/kg), ME10 (20
mg/kg), ME14 (19 mg/kg), ME15 (13 mg/kg), and ME1' (24 mg/kg) had
among the most elevated concentrations in the survey and are all
located relatively close to the Unnamed Stream in the upgradient
areas of Middle Marsh.
o
v
However, levels of PCBs at areas previously identified as "hot
spots" were not consistent with previous investigations. In the
Phase II RI (Ebasco, 1989a), station MM-5 marked a "hot spot" of
60 mg/kg PCBs. In the RI (Metcalf and Eddy, 1991a), in the same
area at station ME1, the concentration was 20 mg/kg PCBs.
Conversely, EPA found concentrations of 3.9, 1.8 and 3.0 mg/kg in
the same area (ERTB). Similar variability was found when
comparing other stations located close together. ME11 and MM-20
were located in dense forested wetland in the same area and had
concentrations of 12 and 2B mg/kg PCBs, respectively. ME2' and
MM-25 were both located next to the tributary in the southwest
portion of the wetland, but had concentrations of 2.2 and 10
mg/kg, respectively. EPA believes that this variability is .
likely due to slight differences in topography, hydrology or soil
type. In addition, flooding events of varying intensity between
the sampling rounds may have deposited and redistributed
sediments.
The highest concentrations of PCBs in the Middle Marsh study area
were encountered in the Adjacent Wetland (see Figure 5), upstream
from Middle Marsh. Aroclor 1254 was detected at every station
sampled in the Adjacent Wetland. Stations SL56, ME38, ME35 and
ME34 which were directly next to the Unnamed Stream (from
upstream to downstream) had PCB concentrations of 34, 32, 22 and
16 mg/kq, respectively. Another station next to the stream
(ME31), but further do~nstream, had a concentration of 3.4 mq/kq
PCBs.. Concentrations at other stations decreased with increasing
elevation and distance from the stream.
Surficial soils were sampled at nine locations on the qolf
course. PCBs were detected at eight of the nine stations.
Concentrations ranged from undetected to 10 mg/kg PCBs. In the
vicinity of the ponds/water hazards to the north of Middle Marsh,
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13
course area east of the Unnamed Stream (stations SL63 to SL65),
PCB concentrations ranged from 0.42 to 3.3 mg/kg. Three
additional stations were sampled near a golf course tee area next
to the Adjacent Wetland and the Unnamed Stream. PCB
concentrations in this area were 1.4 mg/kg (SL50), 10.0 mg/kg
(SLS1), and 0.94 mg/kg (SL52). Station SL51 was located closest
to the Unnamed Stream.
2.
Volatile Organics
Thirteen surficial sediment/soil samples were analyzed for
volatile organics. In general, data indicate that volatiles were
found at low levels at ten stations in Middle Marsh. Volatiles
found included acetone (0.019-0.190 mg/kg), 2-butanone (0.004-
0.030 ~g/kg) and methylene chloride (0.009-0.110 mg/kg).
Chloroform, toluene, and xylene were found at levels near
detection limits. These compounds were found at one or more of
the following stations: ME1, ME2, ME4, ME1S, ME1', ME23 and/or
ME29 which are widely distributed in Middle Marsh but are all
within the 3 month floodplain (See Figure 2). No distinct
patterns or relationship to patterns of PCB contamination were
observed in Middle Marsh. Volatiles were virtually undetected in
the Adjacent Wetland/golf course areas.
3.
Semivolatile Organics
Semivolatile organics were found in surficial sediment/soil
samples at all of the 25 stations sampled in Middle Marsh and at
18 of the 23 stations sampled in the Adjacent Wetland and the
golf course. Semivolatile organics detected included:
polyaromatic hydrocarbons (PAH), phenols, furans, phthalates,
1,4-dichlorobenzene, and benzoic acid. Concentrations of
individual compounds ranged from 0.040 to 7.0 mg/kg. Eight PAHs,
including phenanthrene, fluoranthene, pyrene, benzo(a) anthracene,
chrysene, benzo(b)fluoranthene, benzo(k)fluoranthene, and
benzo(a)pyrene were widely distributed. Concentrations of these
eight PAHs ranged from 0.040 to 2.1mg/kg in Middle Marsh, and
from 0.055 to 0.140 mg/kg in the Adjacent Wetland. The levels in
Middle Marsh exceeded site-specific background concentrations,
whereas concentrations in the Adjacent Wetland fell within the
range of site-specific background concentrationsl.
Similar to volatile organics, semivolatiles concentrations did
not exhibit a strong pattern of distribution, but were detected
at greater frequency at several stations near the Unnamed Stream.
1 Concentrations of these PAHs at background stations MEB
and ME20 ranged from ~ndetected to 0.200 mg/kg. In comparison,
concentrations of many of these semivolatile compounds at the
-------
4 .
Metals
Metals analysis was performed on samples from 34 surficial
stations in Middle Marsh and the Adjacent Wetland. The
concentration and frequencies of detection of aluminum, calcium,
sodium, potassium and barium in surficial soils were generally
consistent with site-specific background levels. However,
manganese (22.-3-1870 mg/kg) and iron (2360-167,000 mg/kg) were
widely distributed in Middle Marsh and the Adjacent Wetland, and
exceeded site-specific background levels. Iron appears to be
related to disposal practices at the Site, as evidenced by
comparison to background levels elsewhere on the Middle Marsh
Operable Unit (2490 to 12,100 mg/kg) and by the dark orange color
of the sediments in the Unnamed Stream downstream of the Disposal
Area.
A number of heavy metals were detected in Middle Marsh at levels
above background. Chromium, Copper, lead, vanadium and zinc were
elevated above site-specific background levels in Middle Marsh.
There was no pattern in the distribution of chromium and copper.
In contrast, lead, vanadium, and zinc were present in a pattern.
very similar to that of PCBs, with highest concentrations
occurring at stations ME29, ME17 and ME2 to the north of the
Unnamed Stream and ME16 to the south. These stations are all
located in semi-permanently flooded areas of Middle Marsh in a
palustrine emergent wetland area that drains into the Unnamed
Stream.
Several metals, including lead and zinc, were also found in the
Adjacent Wetland, but concentrations were much lower than those
in Middle Marsh and were generally within site-specific
background levels. Metals were virtually undetected in samples
taken from the golf course. .
Subsurface Sediment/soil~
F.
Core sampling was conducted at 14 stations in Middle Marsh and the
Adjacent Wetland to determine the vertical extent of contamination.
Tables of detected contaminant concentrations in subsurface
sediment/soil are presented in Appendix E-2 of the "Remedial
Investigation - Additional Studies of Middle Marsh". The sections
below describe contamination patterns in subsurface sediment/soils for
PCBs, volatiles, semivolatiles and metals.
1.
Polycblorinated Biphenyls
Core sampling revealed a consistent pattern of decreasing PCB
contamination with depth. At about half the stations,
concentrations diminished to below 2 mg/kg or undetected in the
12-18 and 18-24 inch fractions. At stations ME1, ME14 and ME1S,
PCB levels were more consistent with surface concentrations (8.6,
-------
lS
At station ME38 (SL38), which is located directly next to the
Unnamed Stream in the Adjacent Wetland, a concentration of 97
mg/kg was found in the 6-12 inch core fraction. This was the
highest PCB concentration found downstream of Hathaway Road.
2.
Volatile organics
Most volatiles were found at levels near detection limits in
subsurface samples of various depths. Volatiles were detected at
nine of the ten core sampling stations in Middle Marsh. The
volatiles found at three or more stations included acetone
(undetected-0.480 mg/kg), met~ylene chloride (undetected-0.160
mg/kq,. and 2-butanone (undetected-0.077 mg/kq). Chloroform,
carbon disulfide, xylene, benzene, and toluene were detected less
frequently in core samples at low concentrations near detection
limits.
3.
Semivolatile organics
In general, there was no clear pattern of semivolatile
contamination with depth. PAHs were found at varying depths in
Middle Marsh with individual concentrations ranging from
0.069 mg/kg to 3.8 mg/kq. Concentrations decreased with
increasing depth at some stations, while other stations showed
the opposite pattern. Bis(2-ethylhexyl)phthalate was found at
all ten stations at concentrations ranging from 0.064 mg/kg to
5.9 mg/kg. Other phthalates were detected at few stations and at
concentrations near detection limits. 4-methyl phenol and
benzoic acid were found at station ME17 at concentrations of
1.1 mg/kg and 1.6 rngjkg, respectively.
4.
. Metals
Metals concentrations in subsurface core fractions were generally
in the same range as the surface and there was no clear trend of
changinq concentration with depth. At station MElS, aluminum,
barium, iron, and zinc increased with depth. In contrast, zinc
decreased with depth at ME23. Lead concentrations decreased with
depth as observed at stations ME1S and ME23.
G.
Pore Water
Pore water samples were collected (when present) at the core
sediment/soil sampling stations for co~pariscn with ambient water
quality criteria. Tables of detected contaminants in the pore water
are presented in Appendix £-3 of the "Remedial Investigation -
Additional Studies of Middle Marsh". PCBs, volatiles, semivolatiles
and metals analyses were conducted on pore water samples and the
results are summarized below.
1.
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~6
Aroclor 1254 was found in the pore water in both filtered and
unfiltered samples. In filtered samples, dissolved PCB
concentrations ranged from undetected (at a detection limit of
0.05 ~g/l1 to 4.4 ~g/l in the samples collected in May, 1990 and
from undetected (at a detection limit of 0.02 ~g/l) to 10 ~g/l in
the samples collected in September, 1990. In unfiltered samples,
dissolved and particulate-associated PCB concentrations ranged
from 1.8 ~9/l to 29 ~g/l in the samples collected in September
1990.
.2.
Volatile organic.
Concentrations of volatiles in unfiltered pore water samples were
detected infrequently and were found at levels near detection
limits. Methylene chloride, acetone, carbon tetrachloride,
toluene, and carbon disulfide were found at levels near detection
limits at stations throughout the wetland with no apparent
distribution pattern.
3.
Semivolatile Organic.
Semivolatiles were found at concentrations near detection limits
in unfiltered pore water samples. There were very few detectable
concentrations and no discernable pattern. Bis(2-ethylhexyl)-
phthalate was most common, but was found at low levels
(0.014 ~g/l - 0.230 ~g/l). Benzoic acid was detected at station
ME29 at a concentration of 0.004 ~g/l, and pentachlorophenol was
detected at a concentration of 0.006 ~g/l at station ME14.
4.
Metal8
Unfiltered pore water samples contained barium, lead, aluminUm,
calcium, iron, magnesium, manganese, potassium, and sodium. Lead
concentrations ranged from 21.7 to 1140 ~g/l, with the highest
concentrations found at stations ME3, ME4, and ME14. These three
stations were located along the Unnamed Stream bank and flood
more frequently than the other three pore water sampling stations
(MEll, ME23, and ME29). Arsenic and nickel were found
infrequently and at low concentrations. Chromium was detected at
stations ME4 and ME14 at 76 ~g/l and 65.7 ~g/l, respectively.
Vanadium and zinc were found at five stations with highest
concentrations at ME3, ME4, and ME14 (45 ~g/l, Sl.9 ~g/l, 133
~g/l, and 175 ~g/l, 625 ~g/l, 566 ~g/l, respectively).
Filtered (dissolved) ~etals samples had markedly diminished
concentrations of iron, lead, and zinc as compared to the
unfiltered samples. W~ereas iron and zinc values were
approximately halved, lead values ranged from undetected, at a
detection limit of 2 ~g/l, to 5.2 ~g/l.
B.
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17
Surface water samples were collected when present at the sediment/soil
sampling stations to examine the horizontal extent of contamination.
Tables of detected contaminants in the surface water are presented in
Appendix E-4 of the "Remedial Investigation - Additional Studies of
Middle Marsh" and are summarized in Table 3 of this ROD. PCBs,
volatiles, semivola~iles and metals analyses were conducted on surface
water samples and the results are summarized below.
1.
Polychlorinated Biphenyl.
Aroclor 1254 was detected in the surface water, but at
substantially lower concentrations than in pore water. In
filtered samples, dissolved PCB concentrations ranged from
undetected to 0.19 ~q/l in the samples collected in May, 1990,
and frOD undetected to 0.077 ~g/l in the samples collected in
September, 1990. In unfiltered samples, concentrations ranged
from 0.98 to 2.0 ~g/l in the samples collected in September,
1990.
2.
Volatile organic.
Acetone and carbon tetrachloride were generally undetected in
unfiltered surface water but were found at levels near detection
limits at two stations. No other volatiles were detected in any
of the surface water samples.
3.
Semivolatile organics
Semivolatiles were undetected in nearly every surface water
sample. Benzoic acid and bis(2-ethylhexyl)phthalate were each
found at one station (MEJ and HE23, respectively) near detection
limits.
4.
Metal.
Surface water samples generally had lower metals concentrations
than the pore water. Zinc was 'found in unfiltered samples from
four stations (ME3, MEll, ME23 and ME29) and lead from three
stations (ME3, ME23, and ME24). The highest concentrations of
zinc and lead were found at ME23 and HE3. ME3 is located next to
the stream and is subject to frequent flooding. Similar to the
pore ~ater, lead and zinc values ranged from undetected to values
at the detection limits in filtered surface water samples.
I.
Biota
EPA Environmental Response Team conducted a food chain study in Middle
~arsh which included biological and che~ical sampling conducted in
June and September of 1989.
The study consisted of collection of sediment/soil, surface water, and
-------
detail in Section 2.4 of the RI (Metcalf and Eddy, 1991a). Biota
sampling consisted of benthic invertebrates, small mammals,
amphibians, earthworms, and plants. Figure 6 illustrates biota
sampling stations and the types of samples collected at each station.
All samples in this study were analyzed for pesticides and PCBs.
Aroclor 1254 was the only contaminant found in the tissue data. Table
4 summarizes the animal and plant tissue data collected at ten
stations in Middle Marsh. All animal species exhibited
bioaccumulation of PCBs.
Aroclor 1254, the principal contaminant of Middle Marsh, was found in
samples of small mammals, benthic invertebrates, earthworms, and
frogs. A total of seven green frogs (Rana clamitans melanota) were
sampled in Middle Marsh. PCBs were present in all specimens with
concentrations ranging from 0.19 to 0.73 milligrams per kilogram
(mg/kg). Two short-tail shrews (Blarina brevicauaa) caught at Station
4 had PCB concentrations of 0.38 and 0.98 mg/kq. Concentrations in
meadow vole (Microtus pennsylvanicus) at the east bank station had PCB
concentrations of 0.36, 0.88, and 1.6 mg/kg. Concentrations in deer
mice (peromyscus maniculatus) at the east and west bank stations
ranged from undetected to 1.0 mg/kg PCBs. Concentrations in white-
footed mice (P. leucopus) which were found only at the west bank
station were 0.68, 0.68 and 0.84 mg/kg PCBs.
Concentrations of PCBs in earthworms ranged from undetected at the
reference station (Station 4) to 2.3 and 1.8 mg/kg at the east bank
and west bank, respectively. The concentrations of PCBs detected in
earthworms indicate a likely exposure pathway for predators including
the shrew, frogs, american robin, woodcock and other bird species.
Aroclor 1254 levels were found to be below the method detection limit
(MDL) of 100.0 ~g/kg in all plant tissues sampled and in benthic.
invertebrates from five of the seven sites sampled. PCBs were
detected, however, in benthos at Stations 2 and 3 at concentrations of
0.35 and 0.4 mg/kg, respectively.
These data from tissues of common food species indicate potential
endangerment to lower and upper level consumers. In particular, PCB
tissue values in green frog, shrews, meadow voles, deer mice and white
footed mice, as described above, exceed 0.64 mg/kg PCBs, a level in
diet which was shown to cause death and reproductive failure in mink.
A complete discussion of site characteristics can be found in the
"Remedial Investigation - Additional Studies of Middle Marsh" in
Chapters 2 and 3 of Volume I.
VI.
SU¥~~y OF SI~E RISES
A Human Health Risk Assessment (HHRA) and an Ecological Risk Assessment
~ere performed to estimate the probability and magnitude of potential
adverse human health and environmental effects from exposure to
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The human health risk assessment and the ecological risk assessment
~ollowed a four step process: 1) contaminant identification, which
identified those hazardous substances which, given the specifics of the
Middle Marsh Operable Unit, were of significant concern; 2) exposure
assessment, which identified actual or potential exposure pathways,
characterized the potentially exposed populations, and determined the
extent of possible exposure; 3} toxicity assessment, which considered the
types and magnitude of adverse health effects associated with exposure to
hazardous substances, and 4) risk characterization, which integrated the
three earlier steps to summarize the potential and actual risks posed by
hazardous substances at the Middle Marsh Operable Unit, including
carcinogenic and non-carcinogenic risks. The results of the public health
risk assessment for the Middle Marsh Operable Unit are discussed below
followed by the conclusions of the ecological risk assessment.
A.
Human Health Risk Assessment
Forty-four contaminants of concern, listed in Table 5,
were selected for evaluation in the human health risk assessment.
These contaminants constitute a representative subset of more than
eighty contaminants identified at the site during the Remedial
Investigation. The forty-four contaminants of concern were selected
to represent potentjal 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 of concern can be found in the "Final Remedial
Investigation - Additional Studies of Middle Marsh," in Section 5.3 of
Volume I.
Potential human health effects associated with exposure to the
contaminants of concern were estimated quantitatively through the
development of several hypotheses concerning exposure pathways. These
path~ays were d~veloped to reflect the potential for exposure to
hazardous substances based on the present uses, potential future uses,
and location of the Site. The following is a brief summary of the
exposure pathways evaluated.
Under current and expected future land use conditions, the HHRA .
assumed that the Middle Marsh and golf course areas are frequented by
golfers and maintenance workers, who may contact contaminated
surficial sediment/soils and surface water during activities such as
golfing and landscaping. The study used adult exposure to evaluate a
reasonable ~orst case. since at this operable unit adult exposure over
thirty years will be more significant tnan exposure to older children
over a much shorter period (e.g_, ten years or less).
Under current lano use conditions at the Middle Marsh area, the HHRA
evaluated risks associated with dermal contact and incidental
ingestion of sediment/soils, and dermal contact with surface water for
an adult who may be exposed 28 days per year for 30 years. Under
future land use conditions, EPA took into consideration the
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accordingly evaluated dermal contact and incidental ingestion of
sediment/soils in Middle Marsh for an adult who may be exposed 56 days
per year for 30 years. For the Adjacent Wetland and golf Course areas
under both current and future land use conditions, EPA assumed an
adult exposure of 56 days a year for 30 years for dermal contact and
incidental ingestion of sediment/soils. EPA based its assessment of
future human health exposure parameters on the assumption that Middle
Marsh and the Adjacent Wetland would continue to be used for a golf
course or other recreation, and not for residences (e.g. housing
deve10pments).2 This assumption is based on the stated intention of
the City of New Bedford to change the zoning of the New Bedford
Municipal Golf Course from residential to recreation/conservation, and
the fact that because the Middle Marsh study area is primarily in a
wetland, future development of Middle Marsh and the Adjacent Wetland
is not likely.
A more thorough description of the exposure pathways evaluated can be
found in the "Remedial Investigation - Additional Studies of Middle
Marsh," in Section 5.4 of Volume I.
For each pathway evaluated, an average and a reasonable maximum
exposure estimate was generated, corresponding to exposure to the
average and the maximum concentration of contaminants detected in
medium.
each
..
The HHRA calculated the excess lifetime cancer risks for each exposure
pathway by multiplying the exposure level with a chemical-specific
cancer potency factor. Cancer potency factors have been developed by
EPA from epidemiological or animal studies to reflect a conservative
"upper bound" of the risk posed by potentially carcinogenic compounds.
That is, the true risk is very unlikely to be greater than the risk
predicted. The resulting risk estimates are expressed in scientific
notation as a probability (e.g. 1 X 10-6 for 1/1,000,000) and indicate
(using this example), that an individual is not likely to have greater
than a one in a million chance of developing cancer over 70 years as a
result of site-related exposure as defined by the compound at the
stated concentration. Current EPA practice considers carcinogenic
risks to be additive when assessing exposure to a mixture of hazardous
substances.
The hazard quotient was a1so 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
2 If EPA had assumed that the future use would be
residential, EPA would have calculated the human health risk
based on a higher frequency of exposure, resulting in lower
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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 is kidney damage). The resulting sum is referred
to as the hazard index.
Table 6 depicts the carcinogenic and non-carcinogenic risk summary for
the contaminants of concern in sediment/soils and surface water in
Middle Marsh and the golf course/wetland area evaluated to reflect
present exposure pathways corresponding to the average and the
reasonable maximum exposure scenarios. Table 7 depicts the
carcinogenic and non-carcinogenic risk summary for the contaminants of
concern in sediment/soils in Middle Marsh evaluated to reflect
potential future exposure pathways corres~onding to the average and
the reasonable maximum exposure scenarios.
As indicated in Tables 6 and 7, total excess lifetime carcinogenic
risks associated with present and potential future exposure to the
contaminants of concern in Middle Marsh and the golf course/wetland
areas fall within EPA's acceptable risk range of 10-4 to 10-6, for
both the average and the reasonable maximum. exposure scenarios. In
addition, total non-carcinogenic risks associated with present and
potential future exposure to the contaminants of concern in Middle
Marsh and the golf course/wetland areas are less than one for both the
average and the reasonable maximum exposure scenarios, indicating that
the potential for adverse effects is unlikely. Therefore, EPA has
determined that, based on the exposure assumptions described above,
human exposure to contaminants in Middle Marsh and the golf
course/wetland area through current and future pathways would not
result in significant increases in carcinogenic risk, and that there
are no significant risks to human health posed by exposure to
noncarcinogenic contaminants.
B.
Ecological Risk Assessment
1.
Hazard Assessment
The following contaminants of concern were selected for
3Total risks associated with potential future use of the
golf course/wetland areas are not included in Table 7, because
they are the same as the total risks associated with present use
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evaluation in the ecological risk assessment: chromium, copper,
iron, lead, manganese, vanadium, zinc, PARs and PCBs. These
contaminants constitute a representative subset of the more than
eighty contaminants identified at the Middle Marsh Operable Unit
during the Remedial Investigation. The nine contaminants of
concern were s~lected to represent potential site-related hazards
based on toxicity, concentration, frequency of detection, and
mobility and persistence in the environment. A discussion of the
health effects of each of the contaminants of concern can be
found in the "Final Remedial Investigation - Additional Studies
.of Middle Marsh" in Section 4.1 of Volume I and is summarized
below:
a.
Polychlorinated Biphenyls
As described in Section V. above, PCB sediment/soil
concentrations in Middle Marsh and the Adjacent Wetland are
sUbstantially above background concentrations and exceed site-
specific interim sediment quality criteria. PCB concentrations
in filtered pore water, and unfiltered pore and surface water
exceed the acute toxicity ambient water quality criterion of
2.0 micrograms per liter (ug/l) for the protection of aquatic
organisms. PCB concentrations in filtered and unfiltered pore
and surface water exceed the ambient water quality criterion of
0.014 ug/l for the protection of wildlife.
To support an ecological exposure assessment, a literature
search was conducted to obtain toxicological data such as dose-
response relationships. Table 4-1 of the RI (Metcalf and Eddy,
1991a) lists toxicity data for PCBs (Aroclor 1254) for some
species of birds and ma~~als. Table 4-2 of the RI (Metcalf and
Eddy, 1991a) lists data concerning the lethal and sublethal
effects of PCBs on wildlife species.
As indicated from the literature study, laboratory animals
exposed to dietary PCBs showed increased evidence of cancer;
reproductive impairment; pathological changes such as lesions
on the liver, stomach, and skin; and immunological impairment.
Relatively low levels of PCBs in the diet of a variety of
wildlife species have been shown to cause reproductive.
impairment, behavioral changes and mortality in sensitive
species. Table 4-2 of the RI (Metcalf and Eddy, 1991a)
indicates that reproductive failure in bird species occurs at
dietary levels of PCBs between 5 and 10 ppm (Heinz et a1.,
1984; Peakall et a1., 1972; Tori and Peterle, 1983). Fleming
et al. (1983) reported that 0.64 ppm of PCBs in the diet of
mink caused reproductive failure and 1.0 ppm caused death.
Platonow and Karstad (1973) reported that dietary
concentrations of 3.57 ppm of PCBs caused death for all mink in
105 days and that 0.64 ppm of PCBs caused death, extreme
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Site-specific studies found PCBs in the body tissues of aquatic
invertebrates, earthworms, amphibians, and small mammals in
Middle Marsh. These data from tissues of common food species
indicate potential endangerment to lower and upper level
consumers. 'In particular, PCB tissue values in qreen frog,
shrews, meadow voles, deer mice and white footed mice, as
described in Section V.I., exceed 0.64 mg/kg PCBs, a level in
diet which was shown to cause death and reproductive failure in
mink.
Since PCB-contaminated species serve as food for upper level
consumers such as American robin and mink, there is a potential
endangerment to wildlife from bioaccumulation of PCBs at this
Site. Based on the toxicity of PCBs to wildlife, potential for
bioaccumulation, and previous site-specific studies, EPA
determined that PCBs, in the Middle Marsh Operable Unit, may
present an imminent and substantial endangerment to the
environment. Accordingly, an ecological exposure assessment
was conducted for PCBs.
b.
Metals
Several heavy metals were detected in sediment/soils in Middle
Marsh and the Adjacent Wetland above background levels,
including copper, chromium, iron, lead, vanadium, manganese and
zinc. However, after comparison to sediment criteria set forth
by Long and Morgan (1990), only lead and zinc were considered
to have levels which could cause toxicity to some species in
the wetland areas. Long and Morgan (1990) found that sediment
lead concentrations of 35-110 mg/kg, and sediment zinc
concentrations of 50-125 mg/kg, resulted in sublethal effects
in aquatic biota. These concentrations are substantially below
the maximum lead and zinc concentrations in Middle Marsh of" 845
and 521 mg/kg, respectively. Iron could also pose a threat to
aquatic biota through creation of a solid floc that adheres to
sediments and smothers sediment benthic organisms.
Because contaminants in sediments partition into pore and
surface water, the potential for exposure to contaminated
sediments resulting in toxicity to biota can be related to the
concentrations of contaminants in water. Therefore, to
evaluate further the potential for biological impacts, surface
water and pore water metals data were compared to ambient water
quality criteria. This co=parison revealed that dissolved
(fjltered' metals concentr~ti~ns vere near or below ambient
water quality criteria for lead, zinc and other metals. This
phenomenon may be due to the binding of metals to sediments as
sulfides, resulting in low bioavailability for uptake by plants
and animals. Due to the low water concentrations, heavy metals
have not been evaluated as a hazard to site biota.
c.
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PAR levels in Middle Marsh exceeded site-specific background
concentrations, whereas concentrations in the Adjacent Wetland
fell within the range of site-specific background
concentrations. In water samples, PARs were found at levels
. near detection limits, indicating that exposures of wildlife to
PAHs in pore water and surface water do not represent pathways
of concern.
Measured sediment/soil levels were compared with interim
sediment quality criteria established by EPA for fluoranthene,
pyrene, benzo(a)pyrene and benzo(a)anthracene and were below
the lowest site-specific sediment quality criteria. Based on
these considerations, PARs are not considered a hazard to
wildlife in the study area.
2.
Exposure Pathways
Detailed physical, chemical and biological information was
collected and evaluated for Middle Marsh to identify aquatic and
wetland/terrestrial exposure pathways critical to the transfer of
PCBs in Middle Marsh and the Adjacent Wetland.
a.
Aquatic Exposure Pathways
In the aquatic environment, sediment-dwelling or benthic
organisms are at the base of the food chain. These organisms
are in intimate contact with the interstitial (pore) water of
the sediments and many emerge in later life stages as aquatic
insects. Further, in all aquatic organisms, contact with water
through respiration is an important route of uptake. Thus,
aquatic species accumulate PCBs through several pathways,
including direct exposure to water and food chain
bioaccumulation.
EPA evaluated areas within Middle Marsh to identify those areas
which support an aquatic food chain and, thus, an aquatic
exposure pathway. Based on field observations, EPA determined
that the area west of the stream in the northwest portion of
Middle Marsh, as delineated in Figure 7, was connected to the
stream over most of the year, and that this area could be a
feeding area for stream animals and could contribute plant and
animal material to the stream on a continuing basis. The area
was further identified as an aquatic area, based on the
invertebrate surveys (which identified aquatic organisms in
this area), the topography, and the fact that the area is
permanently flooded. Therefore, this northwest portion of
Middle Marsh could represent an area that supports a
significant aquatic pathway for the biological transfer of
contaminants.
b.
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Wetland and terrestrial species, such as terrestrial insects,
small mammals and birds, are not in intimate contact with
surface water or pore water. For these species, direct
sediment/soil contact and food chain exposure are predominant.
In soil-dwelling organisms such as earthworms and mice, dermal
contact may'play a significant role. However, in upper level
consumers, PCB uptake is due primarily to food chain (trophic)
bioaccumulation.
Figure 8 depicts a food chain pathway model that was developed
for the Middle Marsh Operable Unit to represent the trophic
relationships between the species present in Middle Marsh.
Site-specific tissue data, and literature information on the
life histories and feeding h~bits of selected species, were
used to select critical food chain pathways and target species
for protection. The model was developed to: 1) evaluate the
effects of contamination on environmental receptors, 2)
determine ecological assessment endpoints for remediation, 3)
evaluate the impacts of remediation on the wetland area, and 4)
identifying appropriate mitigating measures.
Species included in the food chain pathway model for Middle
Marsh were selected because they are integral parts of
important transfer pathways. Selections were based on observed
abundance at the Site, presence of suitable habitat for the
species, and likelihood of exposure. Abundance of the species
was judged by the number of sightings during sediment/soil and
wetland studies and by trapping conducted by EPA. Habitat
suitability was based on the U.S. Fish and Wildlife Service's
Habitat Evaluation Procedure CHEP). Species with frequent or
constant exposure to sediment/soil and water such as
earthworms, insects and small mammals were included in the'
model. Conversely, species were excluded from the model if,
they were assumed to have little or no exposure to site
contaminants or if they have been to shown to have very high
tolerances to the contaminants.
Specifically, raccoon was included because its tracks were
observed and its food species include small mammals, frogs,
worms, and reptiles. Mink were included in the model because
Middle Marsh provides the basic habitat requirements for mink,
because of its known susceptibility to PCBs, and its position
as a top level consumer in an area where site-specific data
showed that many of the mink's food sources are contaminated
with PCBs. Mink may also utilize aquatic food sources such as
fish, crayfish, tadpoles, and mollusks when an aquatic feeding
area is available, as well as small mammals and other
terrestrial animals, such as mice and small birds during a
substantial portion of the year. Minks are expected to use the
Middle Marsh Operable Unit because they have historically
occurred in the region and have been recently sighted in nearby
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neighboring Dartmouth, Massachusetts. Finally, mink tracks and
the tracks of other small animals were recently observed and
photographed in Middle Marsh near the Unnamed stream.
Small Bammals such as mice and shrews were included because
they burrow in the soi1 and are frequent prey of reptiles and
other small ma~als such as raccoons and mink. In addition,
the shrew is a voracious insectivore, feeding on terrestrial
insects which are in intimate contact with the sediment/soil.
Amphibians such as the green frog were included because of
their abundance, site-specific data indicating PCB body
burdens, and because they are frequent prey of reptiles and
mammals.
~
American robin (TUrdus migratorius) and American woodcock
(Philohela minor) were included in the food chain pathway model
because they are carnivorous and their principal food source is
earthworms, which were found to carry body burdens of PCBs up
to 2.3 mg/kg in Middle Marsh. Earthworms also play an
important role in mobilizing PCBs into the food chain due to
their contact with sediment, soil, and water. Insectivorous
birds that feed on terrestrial insects such as beetles, pill
bugs, and centipedes have a1so been included. Although the
snapping turtle is a top level carnivore and was frequently
observed in Middle Marsh, it is not a target species due to its
high level of body fat and associated resistance to PCBs and
other lipophilic contaminants. The spotted turtle is largely
herbivorous and, based on site-specific plant tissue data
indicating undetected PCB concentrations, has not been
included. The Red-tailed hawk (Buteo jamaicensis) was observed
on-site on a number of occasions, but was not included as a
target species because its home range is 0.5-2.2 square miles.
Middle Marsh comprises only about a maximum of 4 percent of the
hawk's range, thus reducing the percent of its diet that would
come from Middle Marsh.
3.
Risk Assessment
A variety of methods were used to assess exposure of Middle Marsh
wildlife species through both aquatic and wetland/terrestrial
exposure pathways. For aquatic exposure pathways, the
equilibrium partitioning method was used as a method of
developing sediment quality criteria for aquatic portions of
Middle Marsn. For wetland/terrestri~l pathways, exposure of
upper level consumers was evaluated by calculating potential
dietary levels an~ comparison of those levels to the toxicity
data. The ecological risk assessment for aquatic and
wetland/terrestrial exposure pathways is discussed below:
a.
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Interim sediment quality criteria (SQC) were used to estimate
the toxicity of the sediments and the biological impact of
in-place contaminated sediments. sQc are intended to be
protective of the presence and ecological functions of benthic
invertebrat~s and other aquatic life. Sediment quality
criteria are based on water quality criteria and are used to
develop limits for contaminant concentrations in the
interstitial (pore) water of sediments. These limits are
established to protect benthic, epibenthic, and other aquatic
invertebrate communities at the base of the aquatic food chain.
EPA has derived contaminant-specific criteria for sediments
from ambient water quality criteria, through use of the
partitioning coefficient. This allows back-calculation of
sediment levels that, within certain probabilities, will not
result in exceedance of water quality criteria in the pore
water. The PCB sediment quality criteria were derived from the
PCB ambient water quality criterion that was developed to
safeguard against bioaccumulation that could result in chronic
reproductive effects in upper level consumers, as represented
by the mink (Mustela vison), a species found to be particularly
sensitive. In 1988, EPA published interim sediment quality
criteria (including mean values and 95\ confidence values) for
13 chemicals. The proposed low, mean, and upper value
freshwater sediment quality criteria for PCBs were 3.87, 19.5,
and 99.9 ~g PCB/g carbon, respectively4.
Comparison of the interim PCB sediment quality criteria with
normalized PCB sediment data (unit of ug PCBs/g carbon) in the
aquatic northwest area of Middle Marsh indicates that
approximately 0.4 acres exceed the mean sediment quality
criteria and 0.1 acres exceed the upper sediment quality
criteria. Data from the biological tissue study for the Middle
Marsh indicated that at the Middle Marsh Operable Unit, PCBs
have accumulated in benthic organisms living in sediments where
PCB-normalized concentrations exceed 200 ug PCBs/g carbon, a
value two times the interim upper sediment quality criterion.
Specifically, PCB concentrations of 0.35 and 0.40 mg/kg were
found in benthic organisms collected from sediment samples with
normalized PCB concentrations of 316 and 253 ug PCBs/g carbon,
respectively.
In addition, PCBs (Aroclor 1254) were detected in filtered and
unfiltered pore and surface water samples at levels above the
ambient water quality criterion for PCBs of 0.014 ~g/l.
Given the site-specific data indicating that bioaccumulation is
occurring on-site, and due to the presence of aquatic
4The low and upper values are based on the variability of
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environments in portions of Middle
concentrations, EPA has determined
in the northwest portion of Middle
unacceptable risk to biota present
Unit.
Marsh with elevated PCB
that contaminated sediments
Marsh present an
at the Middle Marsh Operable
b.
Wetland/Terrestrial Exposure
EPA's Ecological Risk Assessment used bioaccumulation and
toxicity data presented earlier to conduct a wildlife exposure
assessment for species indigenous to Middle Marsh, and to
calculate potential levels of contaminants in sediment/soils
which would be protective of the environment. For
wetland/terrestrial pathways, EPA evaluated exposure of upper
level consumers (such as the raccoon and mink) by calculating
protective sediment levels, using lowest observed effect
dietary levels, and site-specific bioaccumulation factors.
Site-specific tissue data were used to develop bioaccumulation
factors for species such as small mammals, earthworms, and
frogs. The bioaccumulation factors (BAFs) developed for these
species were calculated as the ratio of PCBs in the tissue to .
the level in the sediment/soil, as follows:
Sediment/soil X BAF - Animal Tissue PCB Level
which yields: BAF = Animal Tissue PCB Level
Sediment/Soil PCB Level
This method accounts for all types of exposure including direct
contact, inhalation, soil ingestion, and trophic magnification
or food exposure. This method assumes that the organisms
exposure level is directly proportional to the level in the.
sediment/soil. This information was used to back-calculate
levels for sediment/soil that are protective of wildlife, by
maintaining the food supply of targeted upper level consumers
at or below lowest observed effects levels. BAFs based on
site-specific data and literature values are summarized in
Table 4-4 of the RI (Metcalf and Eddy, 1991a).
In the exposure assessment presented below, sediment/soil
protective levels were back-calculated using the following
relationship:
Crnedia. -
~
BAF
where:
Cmedia = concentration of PCBs in environmental
media (e.g. sediment, soil, water)
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LOEL
c:
dietary lowest observed effect level (mq/kq)
bioaccumulation factor from the media to the
food species consumed (unitless)
BAF
-
carnivorous Birds. Based on the abundance of earthworms in
Middle Marsh and frequent siqhtinqs of the American robin,
a sediment/soil protective level was calculated for
American robin and other carnivorous birds (e.g. woodcock),
based on a protective dietary level of 5 ppm PCBs and a BAF
of 0.29 for earthworms. Assuming that earthworms comprise
75 percent of these species diet, and that Middle Marsh is
90 percent of their feeding range, a protective level of
25.5 mg/kg is indicated by the following equation:
Sediment/Soil
Protective Level
-
5 t)t)m PCBs
(0.29) (0.75) (0.9)
- 25.5 mg/kg
Insectivorous Birds. Insectivorous birds are exposed to
PCBs through the terrestrial food pathway through
consumption of terrestrial insects. A sediment/soil
protective level was calculated for insectivorous birds
using a BAF of 0.19. Assuming that terrestrial insects
comprise 100 percent of the bird's diet, and that Middle
Marsh is 90 percent of the feeding range, a sediment/soil
protective level of 29.2 mg/kg is indicated by the
following equation.
Sediment/Soil =
Protective Level
5 PPTTI PCBs
(0.19) (1.0) (0.9)
= 29.2 mg/kg PCBs
Carnivorous and Omnivorous Mammals. Upper trophic level
carnivorous and omnivorous mammals in Middle Marsh and the
Adjacent Wetland include raccoon and mink. Mink prefer
aquatic food sources to terrestrial food sources when both
options are equally available (Linscombe et al., 1982). In
Middle Marsh, aquatic food sources for mink include small
fish, crustaceans, newts, mollusks, and tadpoles. Mink
will also consume a significant number of frogs when
available. However, during winter when the stream may be
partially frozen and when frogs are hibernating, mink will
feed largely on small mammals (Linscombe et al., 1982).
Since reproductive impairment can occur in mink at low
dietary levels in less than a year, the dietary level of
0.64 ppm PCBs was used as an acute exposure level and
die~ary exposure levels ~ere calculated for the mink's
winter (terrestrial) diet. In winter, mink will feed
largely on small mammals. Accordingly, a sediment/soil
protective level for wetland/terrestrial areas outside the
aquatic areas is based on the site-specific BAF for small
mammals as indicated by 0.64/0.07 = 9.14. Since Middle
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acres, the protective level is adjusted accordingly to 15
mg/kg.
Raccoon, in comparison, are omnivorous, feed
opportunistically and may consume a substantial amount of
frogs and mice when readily available, as is the case in
Middle Marsh. Accordingly, a sediment/soil protective
level has been calculated to protect raccoon. A BAF of
0.22 for frogs, a BAF of 0.07 for mice and a protective
dietary level of 1 ppm were used in the calculations. The
raccoon has a home range of 18-36 acres. It was assumed
that Middle Marsh comprises 50 percent of the raccoons
feeding range and that 30 percent of their diet is composed
of frogs and mice. A sediment/soil protective level of
45.9 mg/kg was calculated for protection of raccoon as
indicated below.
'.
o
1
[(0.'2)(0.5) + (0.07) (0.5)] [0.5][0.3]
- 45.9 mg/kg PCBs
In summary, using the application of site-specific
bioaccumulation factors to the food chain pathway model to
PCB concentrations in Middle Marsh and the Adjacent Wetland
reveals several areas, totalling approximately 1.9 acres
where levels derived to protect mink are exceeded (see
Figure 9). PCB concentrations at sampling locations ME22,
ME38, and SL56 of 28, 32, and 34 mg/kg PCBs, respectively,
exceed the calculated level which are protective of
carnivorous birds. In addition, PCB concentrations at
sampling locations ME38 of 32 mg/kg PCBs, and SL56 of 34
mg/kg PCBs exceed the calculated level which are protective
of insectivorous birds. .
VII.
In summary, EPA has determined that actual or threatened
releases of hazardous substances from contaminated
sediments in Middle Marsh and the Adjacent Wetland, if not
addressed by implementing the response action selected in
this ROD, may present an imminent and substantial
endangerment to biota present in the environment at the
Middle Marsh Operable Unit.
DEVELOPMENT AND SCREENING OF ALTERNATIVES
A. statutory RequirementS/Response Objectiv..
Under its legal authoritjes~ EPA's primary responsibility at
Superfund sites is to undertake remedial actions that are protec-
tive 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
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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 technol-
ogies 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 poten-
tial threats to the environment. These response objectives were:
.
Reduce exposure of aquatic organisms to PCB-
contaminated pore water and sediments either through
direct contact or diet-related bioaccumulation;
Reduce exposure of terrestrial and wetland species to
PCB-contaminated sediment/soils through direct contact
or diet-related bioaccumulation;
Prevent or reduce releases of PCBs to the Unnamed
Stream and the Apponagansett Swamp; and
Mitigate the impacts of remediation on wetlands.
.
.
.
B. Technology and Alternative Development and screening
CERCLA and the NCP set forth the process by which remedial
actions are evaluated and selected. In accordance with these
requirements, a range of alternatives were developed for the
Middle Marsh Operable Unit.
With respect to source control, the RIfFS 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 Middle Marsh Operable
Unit but vary in the degree of treatment employed and the
quantities and character- istics of the treatment residuals and
untreated waste that must be managed; alternative(s) that involve
little or no treatment but provide protection through engineering
or institutional controls; and a no action alternative.
As discussed in Chapter 7 of the Feasibility Study, the RIfFS
identified, assessed and screened technologies based on imple-
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32"
combined into source control (SC) alternatives. Chapter 8 of the
Feasibility study presented the remedial alternatives developed
by combining the technologies identified in the previous
screening process in'the categories identified in Section
300.430(e) (3) of the NCP. The purpose of the initial screening
was to narrow the number of potential remedial actions for
further detailed analysis while preserving a range of options.
Each alternative was then evaluated and screened in Chapter 9 of
the Feasibility Study.
In summary, of the 13 source control remedial alternatives
screened in Chapter 8 of the Feasibility Study, 7 were retained
for detailed analysis. Table 8 identifies the 7 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
evaluated. A detailed tabular assessment
be found in Table 9-19 of the Feasibility
Eddy, 1991b).
Source Control (SC) Alternatives Analyzed
of each alternative
of each alternative can
Study (Metcalf and
The source control alternatives analyzed for the Middle Marsh
Operable Unit include the following:
SC-l - No Action
SC-2b - THE SELECTED REMEDY: Site Preparation; Excavation;
De~atering; Disposal of Excavated Materials at the
Sullivan's Ledge Disposal Area; Wetlands Restoration;
Long-Term Environmental Monitoring; and Institutional
Controls.
SC-S - THE CONTINGENCY ALTERNATIVE: Site Preparation; Excavation;
On-site Solvent Extraction; Disposal of Treated
Sediment/Soils in Middle Marsh; Wetland Restoration; Long-
Term Environmental Monitoring; and Institutional Controls.
SC-6(a) - Site Preparation; Excavation; On-Site Solidificationl
Stabilization; Disposal of Treated Materials at the
Sullivan's Leqge Disposal Area; Wetlands Restoration;
Institutional Controls; and Long-Term Monitoring.
SC-6(b) - Site Preparation; Excavation; On-Site SOlidification/
Stabilization; Disposal of Treated Materials at Landfill
within the Golf Course; Wetlands Restoration; Institutional
Controls; and Long-terc Monitoring-
SC-7(a) - Site Preparation; Excavation; On-Site Incineration;
Disposal of Ash at the Sullivan's Ledge Disposal Area;
Wetlands Restoration; Institutional Controls; and Long-Term
Monitoring.
SC-7(c) - Site Preparation; Excavation; On-Site Incineration;
Off-Site Disposal of Ash; Wetlands Restoration;
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33
Alternatives 2(b), the selected remedy, and Alternative 5, the
contingency remedy, are discussed in Section X of this ROD. All
other alternatives outlined above are described below:
As.
SC-l No-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, no excavation or
treatment of contaminated sediments/soil would occur. No
restrictions on site use or access would be implemented. Because
contaminants would remain in place, the area would be monitored
annually to monitor contaminant concentrations over time and to
trace the extent of possible contaminant migration. After five
years, site conditions would be evaluated to determine whether
cleanup activities would be required. A wetlands restoration
program would not be implemented because, under this alternative,
remedial activities would not be performed in wetland areas.
Estimated Time for Implementation: Not Applicable
Estimated Capital Cost: Not Applicable
Estimated Operation and Maintenance Cost (net present
$50,000
Estimated Total Cost (net present worth): $50,000
worth) :
SC-2Cb): THE SELECTED REMEDY: Site Preparation: Excavation:
De~aterinq: Disposal of Excavated Materials at the
Sullivan's Ledqe Disposal ~rea: Wetlands Restoration: Lona-
Term Enviro~ental Monitoring: and Institutional Controls.
The selected remedy is described in detail in Section X of this
ROD.
L.
~
SC-s - THE CONTINGENCY ~LTERNATIVE: site Preparation:
Excavation: On-site Solvent Extraction: Disposal of Treated
Sedicent/Soils in Middle Marsh: Wetland Restoration: Lonq-
Term Environmental Monitorina: and Institutional Controls.
The contingency remedy is described in detail in Section X of
this ROD.
~
SC-6(a): site Preparation: Excavation: On-site
Solidification/Stabilization: Disposal of Treated Materials
at the Sullivan's Led~e Diseosal Area: ~etlands Restoration:
Insti~utional Controls: Lona-Term Monitorina.
In this alternative, excavated material would be treated by
solidification/stabilization to immobilize, or trap, the
contaminants. To implement this component, a processing area
would be set up at the site prior to excavation of the
contaminated sediment/soils. Four areas would be excavated.
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34
located southeast of Middle Marsh in the Adjacent Wetland (see
Figure 9). The approximate surface areas of Areas 1, 2, 3 and 4
are approximately 0.4, 1.0, 0.1, and 0.4 acres, respectively. Of
the total 1.9 acres to be remediated, 0.75 acres are forested
wetland.
Initially, bulk debris would be screened out of the excavated
materials. The excavated, screened soils would be placed in a
mixing unit for solidification/stabilization.
Solidification/stabilization involves mixing contaminated
sediments/soil with a material such as quick lime, cement,
flyash, or various polymers to chemically bind the contaminants
into a solid material. The solidified material would be tested
to ensure that the PCBs have been effectively trapped. The
solidified materials would then be placed, along with the bulk
debris, in the Sullivan's Ledge Disposal Area and covered with
the cap that will be constructed as part of the site remedy for
the First Operable Unit. If the sediment/soils are
characteristic of RCRA hazardous waste (e.g. because of the
presence of certain metals such as lead, barium and chromium),
solidification/stabilization is expected to remove their
hazardous characteristic, or in the alternative, to comply with. a
treatability variance for land disposal restrictions (LDRs) as
provided in 40 C.F.R. 268.44. The alternative would comply with
ARARs concerning wetlands (e.g. Section 404(b) of the Clean Water
Act, Executive Order 11990, Protection of Wetlands, ~nd
Massachusetts Wetlands Protection Regulations). In particular,
EPA has determined that, there are no practicable alternatives to
excavation of the contaminated sediment/soils which would have a
less adverse short-term impact to the aquatic ecosystem, but
which would not also have significant adverse effects to the
environment which will result if the contaminated sediment/soils.
are left in place.
Wetland restoration would be performed, as described in component
d. of the selected remedy.
Estimated Time for Implementation: 6 Months
Estimated Capital Cost: $4,890,000
Estimated Operation and Maintenance Cost (net present worth):
$164,000
Estimated Total Cost (net present worth): $5,050,000
L
SC-6Cb): Site Pre~aration: Excavation: On-Site
Solidification/Stabilization: DisPos~l of Treate~ Materials
at Lan~fil1 within the Golf Course: ~etlahaS Restoration:
Institutional Controls: Lonq-term Monitorina.
This alternative would include all staging, excavation, treatment
and wetland restoration aspects of Alternative 6(a). However,
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35
disposed of under the cap in the Sullivan's Ledge Disposal Area.
Instead, a 1.6 acre disposal area, or landfill, would be
constructed within the golf course in accordance with
Massachusetts Solid Waste Landfill Regulations. The disposal
area would be const~ucted in an area within the golf course 80
that wastes would be located above the 100 year flood-plain and
be covered by a cap. The conceptual design for the cap 1s 0.5
feet of soil to be placed over the solidified materials, one and
one-half feet of clay, one and one-half feet of soil to protect
the clay, a one-foot drainage layer, and a 2 foot layer of 80il
that would be planted with grass to stabilize the cap.
For this alternative, the long-term environmental monitoring for
the Middle Marsh study area required for all alternatives would
be expanded to include groundwater and soil sampling in areas
next to the golf course disposal area to ensure the long-term
effectiveness of the landfill in preventing migration of PCBs.
If the sediment/soils are characteristic of RCRA hazardous waste
(e.g. because of .the presence of certain metals such as lead),
sOlidification/stabilization is expected to remove their
hazardous characteristic, or in the alternative, to comply with
an LDR treatability variance. For the reasons stated above with
respect to alternative SC-6(a), this alternative complies with
the wetlands ARARs.
Estimated Time for Implementation: 6 Months
Estimated capital Cost: $5,420,000
Estimated operation and Maintenance Cost (net present worth):
$650,000
Estimated Total Cost (net present worth): $6,070,000
ZL
SC-7(a): site Pre~aration: Excavation: On-site
Incineration: Dis~osal of ~sh at the Sullivan's Le~a.
Dis~osal ~rea: Wetlands Restoration: Institutional Controls:
Lonq-Term Monitorina.
This alternative would include all staging, excavation, disposal
and wetland restoration aspects of Alternative 6(a). However,
under this alternative sediments/soil would be treated in a
mobile incinerator that would be assembled in the staging area.
Three different types of incinerators were evaluated in the FS:
rotary kiln, circulating fluidized bed and infrared processing.
The extremely high temperatures of these thermal destruction
facilities may destroy 99.9999 percent of all tbe organic
contaminants. Prior to implementation of a full-scale
incinerator on-site, a test burn would be conducted on-site to
demonstrate the effectiveness and efficiency of the unit in
providing for the destruction of the contaminants specific to the
Middle Marsh Operable Unit. Exhaust gases would be passed
through air pollution devices before being released into the
atmosphere. All incinerated residues would be tested to ensure
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incineration program, the incinerator would be disassembled and
removed from the Site.
TCLP tests would be performed to determine if the residues from
the incinerator process are characteristic of hazardous waste due
to the presence of metals. If such residues are determined to be
hazardous, the residues would be treated by
SOlidification/stabilization, to render the residues non-
hazardous if possible, or in the alternative to comply with an
LDR treatability va~iance. As with alternatives SC-6(a) and SC-
6(b), this alternative complies with the wetlands ARARs. Treated
sedi~ent/soils, referred to as ash, would be disposed of in the
Disposal Area of the SUllivan's Ledge Site and covered by the cap
that will be constructed as part of the site remedy for the First
Operable Unit. Wetland restoration would be performed, a.
described in component d. of the selected remedy.
Estimated Time for Implementation: 6.S Months
Estimated Capital Cost: $9,660,000
Estimated Operation and Maintenance Cost (net present worth):
$164,000
Estimated Total Cost (net present worth): $9,820,000
L.
SC-7 c: Site Pre aration. Excavation. On-8 te
Incineration: Off-Site Dis~osal of Ash: Wetlands
Restoration: Institutional Controls: and Lona-term
Monitorina.
This alternative is similar to Alternative 7(a) except that ash
would be shipped off-site to a federally licensed hazardous waste
landfill for disposal. As described in Alternative 7(a), prior.
to disposal of the ash off-site, TCLP tests would be performed to
determine if the residues from the incinerator process are
hazardous. If such residues are determined to be hazardous, the
residues would be treated by solidification/stabilization, in
order to attain the treatment level range established through an
LDR treatability variance. This alternative complies with
wetland ARARs, for the reasons stated with respect to alternative
SC-6(a).
Estimated Time for Implementation: 6.S Months
Estimated Capital Cost: $9,800,000
Estimated Operation and Maintenance Cost (net present worth):
$164,000
Estimated Total Cost (net present worth): $9,960,000
II.
SU~Y~Y OP THE COMPARATIVE ANALYSIS OF ALTERNATIVES
A.
Evaluation Criteria
Section l2l(b) (1) of CERCLA presents several factors that at a
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37
alternatives. Building upon these specific statutory mandates,
the National Contingency Plan articulates nine evaluation
.criteria to be used in assessing the individual remedial
alternatives. These criteria and their definitions are as
follows:
Threshold criteria
The two threshold criteria described below must be met in
order for the alternatives to be eligible for selection in
accordance with the NCP.
1.
2.
Overall protection of human health and the environment
addresses whether or no~ a remedy provides adequate
protection and describes how risks posed through each
pathway are eliminated, reduced or controlled through
treatment, engineering controls, or institutional
controls.
Compliance with Applicable or relevant and appropriate
requirements (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. .
primarv Balancina criteria
The following five criteria are utilized to compare and
evaluate the elements of one alternative to another that
meet the threshold criteria.
3.
4.
s.
6.
Long-term effectiveness and permanence addresses the
criteria that are utilized to assess alternatives for
the long-term effectiveness and permanence they
afford, along with the degree of certainty that they
will prove successful.
Reduction of toxicity, mobility, or volume throuqh
treatment addresses the degree to which alternatives
employ recycling or treatment that reduces toxicity,
~obility, or volume, including how treatment is used
to address the principal threats posed by the Site.
Short term effectiveness addresses the period of time
needed to achieve protection and any adverse impacts
on human health and the environment that may be posed
during the construction and implementation period,
until cleanup goals are achieved.
Implementability addresses the technical and
administrative feasibility of a remedy, including the
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7.
implement a particular option.
Cost includes estimated capital and Operation
Maintenance (O&M) costs, as well as present-worth
costs.
Modifvina Criteria
The modifying criteria are used on the final evaluation of
remedial alternatives generally after EPA has received
public comment on the RI/FS and Proposed Plan.
8.
state acceptance addresses the State's position and
key concerns related to the preferred alternative and
other alternatives, and the State's comments on ARARs
or the proposed use of waivers.
Community acceptance addresses the publics' general
response to the alternatives described in the Proposed
Plan and RIfFS report.
9.
A detailed assessment of each alternative according to the nine
criteria can be found in Chapter 9 of the "Feasibility Report of
Middle Marsh".
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. This
comparative analysis can be found in Table 9-19 of the
Feasibility Study (Metcalf and Eddy, 1991b).
In order to make a fair comparison of alternatives, EPA has
compared the alternatives in two ways. The first analysis
assumes that implementation of the remedy for the Middle Marsh
Operable Unit can be coordinated with implementation of the First
Operable Unit for the Site; that is that it would be possible to
dispose of contaminated sediment/soils under the Disposal Area
cap. The second analysis compares all alternatives exceDt those
that call for disposal under the Disposal Area cap.
B.
summary of the Comparative Analysis of Alternativ..
(Selected Reme~y)
Assuming that the Middle Marsh Operable Unit can be coordinated
with the First Operable Unit, a detailed analysis Was performed
on all alternatives 11, 2(b), 5, 6(a), 6(b), 7(a), 7(0)], using
the nine evaluation criteria in order to select a site remedy.
The following is a summary of the comparison of each
alternative's strength and ~eakness with respect to the nine
evaluation criteria. This analysis assumes that the Sullivan's
Ledge Disposal Area will be available for use as the Disposal
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~.
Overall Protection of Human Health and the Environment
The No-Action alternative (SC-l) would be protective of
human health based on current and projected site risks.
Although the No-Action alternative would not cause
construction-related iropacts to wetlands because no
excavation or construction activities would occur, this
alternative would not be protective of the environment
because no reduction in, or containment of, contaminant
concentrations would occur. Under this alternative, biota
that inhabit the Middle Marsh study area would continue to
be exposed to PCBs at levels that result in adverse impacts
to animals and aquatic organisms. As more fully discussed
in Section XI.B. of the ROD, EPA has determined that for
this site, disturbance of wetlands and floodplains is the
only practicable alternative that would be protective of the
biota while minimizing adverse impact on the terrestrial and
aquatic ecosystem.
In contrast, all the treatment and/or removal alternatives
[2(b), 5, 6(a), 6(b), 7(a), 7(c)] would be protective of the
environment, as well as human health, by reducing
contaminant levels to meet EPA cleanup goals and protective
standards. Wetlands would be temporarily affected by
excavation procedures, but a comprehensive wetland
restoration program would be implemented for all
alternatives (except the no action alternative). There may
be potential short-term risks to site workers during
excavation and treatment due to the possibility of exposure
to PCBs. These risks, however, would be minimized by use of.
appropriate personal protective equipment.
Upon completion of implementation of alternatives 2(b), 5,
6(a), 6(b), 7(a) and 7(c), low level risks would remain due
to low residual PCB concentrations. Low level risks remain,
under all the containment/treatment alternatives from
exposure to untreated PCB-contaminated sediment/soils that
are below remediation levels (20 ug/gram carbon in aquatic
areas and 15 ppm PCBs in all other areas). However, these
residual levels are protective of human health and the
environment.
Compliance witb ~pplicable or Relevant and Appropriate
Requirements (ARAas)
All alternatives, except for the No-Action alternative, will
comply with ARARs relating to wetlands, including Section
404(b) guidelines under the Clean Water Act, Executive Order
11990, and, the Massachusetts Wetlands Protection
Regulations. As discussed in section XI of the ROD, EPA has
determined that temporary disturbance of wetlands and
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40
floodplains is the only practicable alternative that would
be protective of biota while minimizing adverse impact on
the wetland and aquatic ecosystem. All treatment or removal
alternatives, if properly implemented, would comply with
ARARs. However, compliance with wetland-related ARARs for
these alternatives will depend upon the success of wetland
restoratjon. Fill placed to support the access roads and
the staqing and treatment areas will cause only temporary
.impacts on wetlands and minor impacts on flood storage
capacity and would not threaten homes or other property in
the study area. The No Action alternative may not meet the
requirements of the Wetlands Executive Order 11990 which
requires EPA to minimize the degradation of wetlands and ~o
preserve and enhance the beneficial uses of the wetlands.
In the event that sediment/soils with PCB concentra~ions
greater than 50 ppm are excavated from the Middle Marsh
Operable Unit, alternatives involving incineration [7(a) and
7(c)] will comply with TSCA incineration regulations.
Similarly, alternatives 2(b) and 6(a), which call for
disposal of sediment/soils under the cap at the Disposal
Area will comply with chemical waste landfill requirements,
at 40 CFR 761.75, with the exception of certain requirements
which were waived in the June 29, 1989 ROD. Finally, oil
from the solvent extraction unit (alternative 5) would be
treated in an off-site incinerator and disposed of in
compliance with TSCA.
EPA expects that the majority of the sediment/soils to be
excavated at Middle Marsh do not constitute hazardous
wastes, as defined under state and federal law, because the.
processes generating the contaminants are unknown, the level.
of heavy metals in the sediment/soils are relatively low,
and most of the sediment/soils contain PCBs at
concentrations lower than 50 ppm. However, because the
wastes at the Site are. similar to hazardous wastes, RCRA
regulations are relevant and appropriate. Disposal of
sediment/soils under the cap at the Disposal Area
[alternatives 2(b) and 6(a)] will comply with relevant and
appropriate RCRA requirements. Disposal of non-hazardous
treated sediment/soils within the landfill to be constructed
at the golf course [alternative 6(b)J will comply with
Massachusetts Solid Waste ~egulations. If it is determined
that a portjon of the contaminated sediment/soils are.
considered hazardous waste under federal law, then all
action alternatives will comply with federal land disposal
restrictions (LDRs) by solidifying/immobilizing the
sediments/soils in accordance with a Treatability Variance
under 40 C.F.R. 268.44. Immobilization will attain the
treatment level ranges for treatability variances for lead,
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41
The ash resulting from incineration alternative 7(c) would
be transported and disposed of according to RCRA
regulations.
All alternatives, except for the No Action alternative, will
comply with the chemical-specific ARARs for surface water,
including federal Ambient Water Quality Criteria. For
alternatives 2(b), 5, 6(a), 6(b), 7(a) and 7(c), monitoring
of effluent discharges to the stream or wetlands shall be
performed to ensure that treated water discharges will meet
surface water requlations. Likewise, for all remedial
alternatives involving excavation or disposal [alternatives
2(b), 5, 6(a), 6(b), 7(a) and 7(c)], ambient air monitoring
shall be performed to ensure that particulates do not exceed
air quality emissions during remedial activities.
3.
Long-term Effectiveness and Permanence
The No-Action alternative would not provide long-term
effectiveness or permanence. Alternatives 7(a) and 7(c),
would provide the highest degree of protection and
permanence by incinerating and destroying site contaminants.
Solvent extraction, alternative 5, would also be effective
in the long-term in that PCBs recovered during the treatment
process would be permanently removed from the Site and
destroyed. Solidification/stabilization, alternatives 6(a)
and 6(b), would provide long-term protection through
treatment of the PCBs and containment of the solidified
materials, although solidification/stabilization is less
reliable in the long-term than the other treatment
alternativ~s such as alternatives 5, 7(a) and 7(c)].
SOlidification/stabilization with on-site disposal
[alternatives 6(a) 'and 6(b)] would also require long-term
maintenance of the landfill, whereas the solvent extraction
and incineration equipment would be present at the Site only
for the duration of the treatment program and would then be
removed. Alternative 2(b) does not provide permanence
through treatment; however, given the low levels of PCBs
detected in sediments and soils at the Middle Marsh Operable
Unit, alternative 2(b) would be only slightly less effective
in the long-term than alternatives 6(a) and 6(b). Unless
required by land disposal restrictions, it may not be
necessary to solidify excavated Middle Marsh and Adjacent
Wetland sediment/soils, because the levels of PCBs are
relatively low, less than 50 ppm, and would be properly
contained.
4.
Reduction of Toxicity, Mobility, or Volume Througb
Treatment
The No-Action alternative would have no effect on the
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42
Alternatives 7(a) an~ 7(c), incineration with on-site or
. off-site ash disposal, woul~ provide the greatest reduction
of toxicity, mobility and volume by destroying the
contaminants. Alternative 5, solvent extraction, would also
significantly reduce the toxicity, mobility an~ volume of
site contaminants through treatment, an~ is preferre~ under
CERCLA because it is an innovative technology. Alternatives
6(a) and 6(b)~ woul~ solidify the excavated materials, thus
reducing the mobility of the site contaminants. They would,
. however, increase the volume of site contaminants that would
require disposal. Alternative 2(b), EPA's selected remedy,
does not provide treatment that w~uld reduce the toxicity
and volume of site contaminants, but it would significantly
reduce the mobility of the contaminants by placing the
excavated sediment/soils under the RCRA cap at the Disposal
Area. In comparison to Alternatives 6(a) and 6(b),
Alternative 2(b) would not increase the volume of
contaminated materials found at the Site.
5.
Short-term Effectiven...
The No-Action alternative woul~ pose no risk to human health
or the environment beyond those already posed by site
contaminants. Implementation of all other alternatives may
result in a slight increase in PCB exposure to workers
during remedial activities. Additionally, alternatives 7(a)
and 7(c) may pose a short-term risk to public health,
workers, and the environment due to air emissions.
Alternative 5 may pose a potential risk to workers due to
possible exposure to solvents. These short-term risks
would be mitigated by requiring workers to wear protective
clothing. Although PCEs are not volatile and inhalation of
contaminants is not expected to be a problem, the breathing
zone will be monitored and respirators worn if necessary.
Dust is not expected to be a problem during excavation or
transport of sediment/soils, however, water or other control
measures will be kept available in case roadways'or other
areas become. too dry.
Wildlife in the wetlands would also be exposed to short-term
risks, due to disruption of habitat, during the limited time
that site remediation and restoration would be required.
However, engineering controls would be chosen and
irnple~ented to ~ini~ize dDwnstream i~pacts resulting from
excavation and other impacts on the wetlands, including the
use of sandbags, earthen dikes, silt curtains and
sedime~tation basins. In addition, measures will be
implemented to minimize impacts to wildlife.
All treatment or containment alternatives have
implementation times of approximately six months, exclusive
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43
No Action alternative has no short-term effectiveness
limitations, because it consists of remedial activities
relating only to long-term environmental monitoring.
I.
Implementability
The No-Ac~ion alternative would be easiest to implement as
the remedial activities are limited, consisting mainly of
long-term environmental monitoring. All of the remaining
alternatives [2(b), 5, 6(a), 6(b), (7a), 7(c)] involve
excavation of portions of the wetlands, sediment/soil
processing, placement of processed materials and wetlands
restoration. Of these alternatives, alternatives 5, 6(a),
6(b), 7(a), 7(c), would also require mobilization,
demobilization and implementation of sediment/soil treatment
units. Treatment units are expected to be equally available
for solvent extraction, solidification/stabilization, and
incineration. However, obtaining competitive bids on the
solvent extraction unit may be difficult because there are
fewer vendors and mobilization may require a greater lead
time. Alternative 2(b) does not involve treatment; however,
its implementability is dependent on the suitability of the
dewatered and conditioned material for placement under the
cap at the Disposal Area.
Of the action alternatives, capping without prior
sOlidification/stabilization, solvent extraction or
incineration would not require use of specialized treatment
equipment with limited availability. The placement of
excavated sediment/soils under the cap over the Disposal
Area [Alternative 2(b») would not significantly increase the'
volume of site contaminants to be disposed of under the cap, .
and Alternative 2(b) is therefore more implementable than
Alternatives 6(a) and 6(b), which would increase material
handling requirements due to the increase in volume of
contaminants produced by sOlidification/stabilization.
It is anticipated that the incineration alternative 7(c) and
solidification/stabilization alternative 6(b) with disposal
on the golf course may be difficult to implement based on
public accessibility, land acquisition, siting requirements
and community opposition.
7.
C08t
Alternatives 7(a) and 7(c), incineration, are the most
expensive of all the alternatives, each with an estimated
total cost of approximately $10,000,000. Solvent
Extraction, Alternative 5 would be equally effective as
Alternatives 7(a) and 7(c) in reducing contaminant
concentrations to cleanup levels but at a lower total cost
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44
sOlidification/stabilization alternatives 6(a) and 6(b) are
less eA~ensive than the more permanent treatment
alternatives [Alternatives 5, 7(a), and 7(c)J.
The capping alternative, Alternative 2(b), is the least
costly of the action alternatives. Of the containment
alternatives [Alternatives 2(b), 6(a), 6(b)J, Alternative
2(b) is the least costly to implement, at a total cost of
approximately $2,800,000, compared to total costs in excess
of $5,000,000 for the sOlidification/stabilization
alternatives [Alternatives 6(a) and 6(b)J. The No-Action
alternative would require the least amount of money to
implement.
\'
8.
state Acceptance
Based on its review of the RI/FS and Proposed Plan, the
Commonwealth of Massachusetts concurs with alternative 2(b)
as the selected remedy. A copy of the declaration of
concurrence is attached as Appendix C to this ROD.
t.
Community Acceptance
Comments received from the community indicated a preference
for the No Action alternative. In particular, a petition
from golfers at the New Bedford Municipal Golf Course
requested that the PCBs be left alone since there is no
guarantee that the PCBs will be removed, and because the
cost of remediation is high. The City of New Bedford
opposed the preferred alternative, stating that it was not
protective of the environment because the cleanup would have.
a more damaging impact on species at the Site than would the
long-term effects of PCB contamination, -and would cause
redistribution of contaminants allover the Site. The City
also stated that the selected remedy was not cost-effective
and that a limited action consisting of institutional
controls should be implemented.
Summary of the Comparative Analysis of Alternativ..
(Contingency Remedy)
c.
This section compares and evaluates those alternatives that
would not require use of the Sullivan's Ledge Disposal Area
for placement of excavated materials. This analysis is
based on EPA's assu~ption that the timing of the Disposal
Area cap construction ~ay prevent further use of the
Disposal Area, and that another remedial alternative should
be chosen for implementation if the Disposal Area should
prove to be unusable. Therefore, all alternatives that
would require use of the Sullivan's Ledge Disposal Area,
which were evaluated in the previous section, have been
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45
The alternatives that are retained for evaluation in this
section are:
. Alternative No.1 -- No-Action;
. Alternative No.5 -- THE CONTINGENCY REMEDY - On-site
solvent extraction with off-site PCB treatment (EPA's
contingency alternative);
Alternative No.6 (b) -- On-site
sOlidification/stabilization and on-site disposal;
Alternative No.7(c) -- On-site incineration and off-
site ash disposal.
A detailed analysis was performed on the alternatives using
the nine evaluation criteria in order to select the
contingency remedy. The following is a summary of the
comparison of each with respect 'to the nine evaluation
criteria.
.
.
1.
Overall Protection of Human Health and the Environment
Alternative 1, No Action, would be protective of human
health, but would not be protective of the environment. EPA
has determined that for the Middle Marsh Operable Unit,
disturbance of wetlands and floodplains is the only
practicable alternative that would be protective of the
biota while minimizing adverse impact on the terrestrial and
aquatic ecosystem. '
All the treatment and/or removal alternatives [5, 6(b),
7(c)] would be equally protective of human health and the
environment by reducing contaminant levels to meet EPA
cleanup goals and protective standards. There may be
potential short-term risks to site workers during excavation
and treatment due to the possibility of exposure to PCBs.
These risks, however, would be minimized by use of
appropriate personal protective equipment. Wetlands would
be temporarily affected by excavation procedures, but a
comprehensive wetland restoration program would be
implemented.
Upon completion of implementation of alternatives 5, 6(b),
and 7(c), low level risks would remain due to low residual
PCB concentrations, although these levels would be
protective of human health and the environment. Low level
risks remain, under all the containment/treatment
alternatives listed above, from untreated PCB-contaminated
sediment/soils that are below remediation levels (20 ug/gram
carbon in aquatic areas and 15 ppm PCBs in all other areas).
2.
compliance with Applicable or Relevant and Appropriate
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46
All alternatives, except for the No Action alternative, will
comply with the chemical-specific ARAR for surface water,
federal Ambient Water Quality Criteria. In addition, the No
Action alternative may not meet the requirements of the
Wetlands Executive Order 11990 which requires EPA to
minimize the degradatjon of wetlands and to preserve and
enhance the beneficial uses of the wetlands.
c
Alternatives 5, 6(b) and 7(c) would comply with ARARs, as
described in Section IX.B.2. above.
3.
Long-term Effectiveness and Permanence
The NO-Action alternative (Alternative 1) would not provide
an effective long-term solution to site contamination.
Solvent extraction (Alternative 5) and incineration
[Alternative 7(c)] would be equally effective in providing
permanent solutions to site contamination because site
contaminants would be destroyed.
Solidification/stabilization with on-site disposal,
Alternative 6(b), in a new landfill would provide long-term
protectiveness, but would have a significant, permanent
impact on the golf course where the landfill would be
located. Solidification/stabilization with on-site disposal
would also require long-term maintenance of the landfill,
whereas the solvent extraction and incineration equipment
would be present at the site only for the duration of the
treatment program and would then be removed.
4.
Reduction of Toxicity, MObility, or Volume Through
Treatment
The NO-Action alternative would not affect the toxicity,
mobility or volume of site contaminants. Alternative 6(b),
solidification/stabilization, would significantly reduce the
mobility of the contaminants by immobilization of the
conta~inants in a solid and placement of the solidified
materials under an impermeable cap, but would significantly
increase the volume of the materials that would be placed in
the landfill located at the golf course. Incineration,
alternative 7(c), would permanently reduce the toxicity,
mobility and volume of site contaminants through treatment.
Solvent extraction, alternative S, would be equally
effective. Solvent extraction is preferred under CERCLA,
however, because i~ is an innovative technology. The
development and use of innovative technologies are
encouraged by the federal government to stimulate continuing
improvements in hazardous waste treatment technologies.
5.
Short-term EffectiveneS8
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4/
or the environment beyond those already posed by site
contaminants. Implementation of all other alternatives,
[alternatives 5, 6(b) and 7(c)], may result in a slight
increase in PCB exposure to workers during remedial
activities. Additionally, alternative 7(c) may pose a
short-term risk to public health, workers, and the
environment due to air emissions during incineration.
Alternative 5 may pose a potential risk to workers due to
poss;ble exposure to solvents. These short-term risks would
be mitigated by requiring workers to wear protective
clothing. . Altho~gh PCBs are not volatile and inhalation of
contaminants is not expected to be a problem, the breathing
zone will be monitored and respirators worn if necessary.
Dust is not expected to be a problem during excavation or
transport of sediment/soils, however, water or other control
measures will be kept available in case roadways or other
areas become too dry.
Short-term risks may also be present for wildlife in the
wetlands due to disruption of habitat during the limited
time that site remediation and restoration would be
required. However, engineering controls would be chosen and
implemented to minimize downstream impacts resulting from
excavation and other impacts on the wetlands, including the
use of sandbags, earthen dikes, silt curtains and
sedimentation basins. In addition, measures will be
implemented to minimize impacts to wildlife.
All treatment or containment alternatives [alternatives 5,
6(b) and 7(c)] have implementation times of approximately
six months, exclusive of the time required for design,
bidding and award of contracts. The No Action alternative
has no short-term effectiveness limitations, because it
consists of remedial activities relating only to long-term
environmental monitoring.
I.
Implementability
The No-Action alternative would be easiest to implement as
this alternative consists primarily of remedial activities
relating to long-term environmental monitoring.
Incineration [al~ernative 7(c)] and solvent extraction
[alternative 5] would be implementable, although
incineratjon may be more easily accomplished due to the
larger number of transportable hazardous waste incinerators
available in the country. Solidification/stabilization and
on-site disposal would be implementable technically, but
construction of the landfill would significantly impact
operations of the golf course, which could affect
implementability. In addition, alternative 6(b) would
increase material handling requirements due to the increase
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48
sOlidification/stabilization.
It is anticipated that the incineration alternative 7(c) and
sOlidification/stabilization alternative 6(b) may be
difficult to implement based on the need to construct a
landfill in the golf course and because of issues relating
to public accessibility, land acquisition, siting
requirements and community opposition.
7.
Coat
Alternative 7(c), on-site incineration, would be the most
expensive of all the alternatives, with an estimated total
cost of approximately $10,000,000. Solvent extraction
[alternative 5) would be equally effective as alternative
7(c) in reducing contaminant concentrations to cleanup
levels, but at a lower total cost of approximately
$7,800,000. The sOlidification/stabilization alternative
6(b), at an estimated total cost of $6,070,000, would be
less expensive than the more permanent treatment
alternatives [Alternatives 5 and 7(c»), but would be the
most expensive alternative to operate and maintain over the
long term, with an estimated operation and maintenance total
cost of $650,000. No-Action alternative would require the
least amount of money to implement.
8.
state Acceptance
Based on its review of the RI/FS and Proposed Plan, the
Commonwealth of Massachusetts concurs with alternative 5 as
the contingency remedy. A copy of the declaration of
concurrence is attached as Appendix C to this ROD.
t.
Community Acceptance
Comments received from the community indicated a preference
for the No Action alternative. In particular, a petition
from golfers at the New Bedford Municipal Golf Course
requested that the PCBs be left alone since there is no
guarantee that the PCBs will be removed, and because the
cost of remediation is hiqh. The City of New Bedford
opposed the contingency alternative, statinq that it was not
protective of the environment because the cleanup would have
a more damaging impact on species at the Site than would the
long-term effects ot PCE contamination, and would cause
redistribution of contaminants allover the Site. The City
stated that a limited action consisting of institutional
controls should be implemented.
x.
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The selected and contingency remedies contain source control
components which address the threat to biota posed by exposure to
contaminated sediment/soils in Middle Marsh and the Adjacent
Wetland.
A.
CleanUD Levele
Cleanup levels have been established for total PCBs which
were identified in the baseline risk assessment and were
found to pose an unacceptable risk to the environment.
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. If the remedial
action is not found to be protective, further action shall
be required.
As described in section VI. above, protective levels were
developed to assess exposure of Middle Marsh species through
both aquatic and wetland/terrestrial exposure pathways.
Based on the ecological risk assessment, sediment/soil
cleanup levels were established for the aquatic area
delineated in Middle Marsh and for non-aquatic areas in
Middle Marsh and the Adjacent Wetland as described below:
1.
Sediment/Soil Cleanup Level for Aquatic Areas in
Middle Marsh
The sediment/soil cleanup level for the aquatic area
in Middle Marsh, as designated in Figure 7, is the
interim mean sediment quality criterion (SQC) of 20
micrograms of total PCBs per gram of carbon (ug/Gc).
As described in Section VI.B.3.a., this value has been.
derived by EPA's criteria and Standards Division to be
protective of the presence and ecological functions of
benthic invertebrates. In addition, the PCB SQC was
derived from the corresponding ambient water quality
criterion developed to safeguard against
bioaccumulation that could result in chronic
reproductive effects in upper level consumers as
represented by a species found to be particularly
sensitive, the mink CMustela vison).s
Tbe mean sediment quality criterion (20 ug/Gc) was
established as the cleanup level for aquatic areas in
Middle Marsh because after remedia~ion, the resulting
5 As described in section VI.B.3.a., site-specific tissue
data indicates that accumulation of PCBs occurred in benthic
organisms at sediment/soil concentrations greater than 200
micrograms of PCBs per gram of carbon (ug PCBs/ Gc), a value
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50
PCB concentrations in sediment/soils represent levels
which, with approximately 50t certainty, will result
in interstitial water concentrations equal to or lower
than the PCB ambient water quality criterion of 0.014
ug/l.
2.
Sediment/Soil Cleanup Levels for Non-aquatic Areas in
Middle Marsh and for the Adjacent Wetland
As described in Section VI.B.3.b., the application of
site-specific bioaccumulation factors to the food
chain pathway model in comparison to PCB sediment/soil
concentrations in Middle Marsh and the Adjacent
Wetland reveal several areas, approximately 1.5 acres
in total, that exceed levels derived to protect
carnivorous and omnivorous mammals, as represented by
the mink. In addition, PCB concentrations at several
locations in Middle Marsh and the Adjacent Wetland
exceed levels derived to protect carnivorous birds.
d
For non-aquatic areas in Middle Marsh, as designated
in Figure 7, and for the Adjacent Wetland, the
sediment/soil cleanup level is 15 mg/kg total PCBs.
A sediment/soil cleanup level of 15 mg/kg total PCBs
has been established to protect carnivorous and
omnivorous mammals from chronic adverse effects from
wetland/terrestrial exposure to contaminated
sediment/soils. Remediation of Middle Marsh and the.
Adjacent Wetland sediment/soils to the PCB cleanup
level will also reduce the concentrations of PCBs to
levels protective of carnivorous and insectivorous
birds.
B.
Descri~tion of Reme~ial Com~onents
After evaluating all of the feasible alternatives, EPA is
selecting a seven-component plan to address sediment/soil
contamination at the Middle Marsh Operable Unit. Major
components of the selected remedy and the contingency remedy
are described below.
1.
Selected Remedy
a.
site Preparation
Site preparation activities would be initiated with
the construction of access roads necessary for the
mobilization and use of excavation, treatment and
disposal equipment. Roadway construction would be
performed to minimize wetland impacts, in accordance
with the conceptual design discussed in Sections 8.1.1
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51
Eddy, 1991b). Exact locations of the access roads
shall be determined in Remedial Design. Performance
standards of such road construction shall include, at
a minimum, the following:
(1) To'the extent necessary, a gravel roadway shall
be constructed around the wetland to minimize impacts
to areas not requiring remediation;
(2) To minimize fill placed in wetlands, narrow
access roads would be constructed within areas
requiring excavation;
(3) Slumping of fill shall be minimized by placement
of fill on geotextile or geogrid mats;
(4) Measures such as signs, signals or temporary
widening of Hathaway Road shall be implemented to
mitigate traffic problems to and from Hathaway Road.
The site preparation includes the establishment of
security and controlled access to the site, the
connection of light and power utilities and the
furnishing of sanitary facilities. A chain link fence
will be constructed around the perimeter of the areas
to be remediated and designated off-site areas. To
the maximum extent feasible, the existing fences will
be utilized. warning signs will be posted at 100 foot
intervals along the fences and at the entrance gates.
Site preparation work will also include provisions for
controlling site drainage. In general, diversion
ditches will be used to ensure proper drainage of
stormwater away from contaminated areas. Erosion
control in the form of silt fencing will be used to
prevent uncontrolled movement of contaminated
sediment/soils. Stormwater management and erosion
control measures to be used during
excavation/treatment activities are also considered
part of the site preparation work.
Because these activities may include sediment/soil
movement, an air monitoring program will be .
implemented during the performance of the site
preparation work to determine risks to on-site
workers, golfers and nearby residents. In addition,
subsequent to site preparation work but prior to soil
excavation activities, sediment/soil monitoring will
be performed to further define contaminant levels in
- any area impacted by site preparation work.
This component of the remedy will utilize measures to
limit potential air emissions from excavation
activities, including the following methods: enclosure
of the work a~eas; emission suppression techniques
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sediment/soils.
Following the installation of erosion control
structures, clearing and grubbing will be performed on
the dens~ly vegetated parts of the Middle Marsh
Operable Unit of only those areas necessary for
implementation and construction of. the selected
remedy. Cleared debris such as trees and shrubs will
be disposed of on-site or off-site after initial
processing (e.g. chipping). EPA anticipates that
decontamination of such debris will not be required.
In order to minimize the possibility of residual
contamination of debris, special precautions will be
taken during clearing and grubbing activities such as
temporary covering of contaminated sediment/soils.
stumps and other contaminated materials shall be
shredded and/or disposed of with the contaminated
sediment/soil. Any rubble unearthed from fill
material during site preparation work, or surface
obstructions (e.g. cinder block, metal scrap) shall be
decontaminated prior to off-site disposal in an
approved facility. After areas have been cleared,
grading will be performed to provide a level surface
for the operational areas.
~
A concrete pad for stockpiling and dewatering will be
constructed as the final step to prepare for.
construction of the sediment/soil treatment facility.
b.
Excavation
Four areas within the New Bedford Municipal Golf
Course property shall be excavated. Areas 1, 2, and 3
are located within Middle Marsh, whereas Area 4 is
located southeast of Middle Marsh in the Adjacent
Wetland (see Figure 9). The approximate surface areas
of Areas 1, 2, 3 and 4 are 0.4, 1.0, 0.1, and 0.4
acres, respectively. Of the 1.9 acres to be
remediated, approximately 0.75 acres are forested
wetland.
Areas 1, 2, 3 and 4, as delineated in Figure 9, shall
be excavated by conventional mechanical means to an
initial depth of one and one-half feet to remove
sediment/soils with PCBs in excess of the cleanup
levels outlined in Section X.A. A total of
approximately 5,200 cubic yards of contaminated
sediment/soils shall be excavated. Additional
sediment excavation shall be conducted as necessary to
remove all contaminated sediment/soils with PCB
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A combination of conventional mechanical means shall
be utilized including the following: crawler-mounted
dragline; backhoe; front-end loader; bobcat; hand
shovels; and other small lightweight excavators.
However, due to the limited size of Area 3
(approxi~ately 5,600 square feet), a dragline shall
not be used for this area. Alternatively, although
more labor intensive, a combination of light
excavators such as bobcats and hand shovels. shall be
used to excavate Area 3 while minimizing tree removal
and fill placement. Excavated material from Area 3
shall be removed by wheel barrows or by conveyor
belts.
'To implement this component, a processing area will be
set up at the Middle Marsh Operable Unit prior to soil
excavation. The processing area will be constructed
so as to prevent, to the extent possible, any
migration of the excavated soils.
As described in component a of the selected remedy,
measures will be implemented to limit potential air
emissions from excavation, treatment and ancillary
activities. An air monitoring program shall be
implemented during the performance of the on-site
sediment/soil excavation and treatment components of
the remedy to determine risks to on-site workers,
golfers and nearby residents. Air sampling stations
will be located at representative points throughout
the golf course and at the perimeter of the work zone
for the Middle Marsh Operable Unit. Samples will be
analyzed, at a minimum, for PCBs in vapor phase and
PCB particulates.
EPA anticipates that some amount of on-site wetland
areas will be impacted by sediment/soil excavation.
For those areas, steps will be taken as described in
component d of the selected remedy, to minimize
potential destruction or loss of wetlands or adverse
impacts to organisms.
Upon completion of the initial excavation of on-site
contaminated sediment/soils, samples will be collected
and contaminant levels will be evaluated against the
cleanup levels for sediment/soils (see Section X.A.l).
Sediment samples will be analyzed, at a minimum, for
PCBs and TOC. All samples will be evaluated to ensure
that response objectives and performance standards are
achieved. Based on the sampling results, additional
excavation at one foot depth intervals will be
performed in any area where sediment contaminant
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54
cleanup level.
Appropriate pretreatment and materials handling
(blending), such as feed size preparation and optimum
sediment/soil feed criteria will be evaluated during
remedial design for the excavation phase of the
selected remedy.
Excavation activities shall be scheduled so that
disturbances to Massachusetts species of special
concern are minimized to the maximum extent
practicable. EPA will evaluate the following factors
in determining practicability: public access, weather
conditions, stream flow, scheduling constraints.
This portion of the selected remedy will be
implemented in a manner that mitigates any contaminant
migration downstream. The method of isolating
contaminated sediment/soils will be determined during
design of the selected remedy, considering the need to
mitigate wetland impacts.
Because the areas to be excavated are wetlands,
excavation and associated activities will be performed
to minimize adverse impacts to wetland areas. EPA
has determined that, for this operable unit, there are
no practicable alternatives to the site preparation
and sediment/soil excavation components of the
selected remedy, that would achieve site goals but
would have less adverse impacts on the ecosystem.
Therefore, sedimentation basins and/or silt curtains
will be installed downstream to capture any particles.
that may become suspended during excavation
activities. During excavation and dewatering of PCB-
contaminated sediments, downstream monitoring of
surface water will be conducted to ensure that
transport is not occurring as a result of the
excavation. Excavated areas shall be isolated by
means of erosion (e.g. sandbags, haybales or earthen
dikes) and sedimentation control devices (e.g.
sedimentation basins), and diversion structures.
For wetlands areas affected by sediment/soil
excavation, steps will be taken as described in
component d of the s~lected remedy, to minimize
potential destruction or loss of wetlands or adverse
impacts to organisms.
c.
Dewatering and Disposal
Because the excavated sediment/soils would contain
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55
filter presses) shall be used following excavation.
Dewatering would reduce the moisture content of the
excavated materials and facilitate their handling and
transport. The dewatering system shall consist of
mechanical (e.g. belt filter presses, recessed chamber
filter presses, centrifuges) . and/or chemical processes
(e.g. quicklime addition) and would be designed based
on results of bench-scale and chemical tests. In
particular, Toxicity Characteristic Leaching Procedure
(TCLP), PCBs and paint filter liquid tests would be
performed to determine suitability for landfilling and
to determine if the sediment/soils are characteristic
of Resource Conservation and Recovery Act (RCRA)
hazardous waste due to the presence of heavy metals.
If solidification/stabilization is determined by EPA,
in consultation with MADEP, to be necessary, then,
bench-scale testing of the
sOlidification/stabilization process using
representative sediment/soil samples shall be
performed to evaluate solidifying agents and mixtures,
including the use of quicklime. Testing to determine
appropriate and optimal use of hardening agents will
consist of leachability tests. TCLP tests shall also
be performed to determine whether certain
sediment/soils will be RCRA characteristic waste after
sOlidification/stabilization.
Sediment/soils which are determined to be RCRA
hazardous waste would be subject to the land disposal
restrictions (LDRs). If, upon evaluation of the
results of the TCLP tests, sediment/soils are
determined to be RCRA hazardous waste, then
solidification/stabilization of these sediment/soils
shall be performed, as necessary, to render the
materials non-hazardous, or in the alternative to meet
the treatability variance provided in the hazardous
waste land disposal restrictions. Because existing
and available data do not demonstrate that the full-
scale operation of sOlidification/stabilization
treatment technology can attain the LDR treatment
standards consistently for all soil and debris wastes
to.be addressed by this action, this alternative will
comply with the LDRs through a Treatability Variance
for the wastes that cannot be treated to meet the
standard.
Water extracted from the excavated materials shall be
adequately stored and treated by carbon adsorption and
additional treatment units, as necessary, to remove
residual contaminants to protective levels. Treated
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S6
Following dewatering and sOlidification/stabilization,
if necessary, the excavated materials would be
transpor~ed to the Sullivan's Ledge Disposal Area,
disposed of above the existing ground surface and
outside the 100-year floodplain, and covered by the
cap that will be constructed as part of the site
cleanup for the First Operable Unit.
Activities relating to the treatment, disposal and
transportation of these sediment/soils shall be
performed while minimizing potential destruction or
loss of wetlands or adverse impacts to organisms.
~
Q
d.
Wetlands Restoration
EPA has determined that, for this Site, there are no
practicable alternatives to the selected remedy that
would achieve site goals but would have less adverse
impacts on the ecosystem. Unless sediment/soils with
contaminants greater than the target levels are
excavated, the contaminants in the sediment/soils
would continue to pose unacceptable environmental
risks.
Excavation, treatment and disposal of contaminated
sediment/soils, and any ancillary activities will
result in unavoidable impacts and disturbance to
wetland resource areas. Such impacts may include the
destruction of vegetation and the loss of certain
plants and aquatic organisms. Impacts to the fauna
and flora will be mitigated in accordance with Section
9.2.1.4. of the Feasibility Study (Metcalf and Eddy, .
1991b) and the requirements discussed below.
During implementation of the remedy, steps will be
taken to minimize the destruction, loss and
degradation of wetlands, including the use of
sedimentation basins or silt curtains to prevent
downstream transport of contaminated sediment/soils.
A wetland restoration program will be implemented upon
completion of the remedial activities in wetland areas
adversely impacted by remedial action and ancillary
activities. In particular, the restoration program
for the excavated portions of Middle Marsh and the
Adjacent Wetland will be designed to mitigate any
future impacts of such activities to those areas.
Measures to be used will include adequate sloping of
stream banks to prevent excessive sediment/soil
erosion into the Unnamed Stream. All excavated areas
would be backfilled, graded, stabilized and planted.
The area would be restored to detail appropriate
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57
planted. organic fill material would be distributed
throughout the excavated areas to create grading,
elevation and drainage approaching original patterns
and to serve as substrate for replacement of
vegetati,on.
A variety of mitigating measures shall be implemented
during and after remedial action including protection
of sensitive species, erosion control and turbidity
control. Excavation, backfilling and other remedial
activities shall be conducted such that the
disturbance of the Spotted Turtle, a Massachusetts
species of special concern known to occupy Middle
Marsh is minimized. In addition, during remedial
design, further investigations will be performed to
identify areas where the Mystic Valley Amphipods may
be inhabiting. Based on the results of such an
investigation, measures shall be planned and
implemented to minimize adverse impacts of remedial
activities, including wetlands restoration, on the
Mystic Valley Amphipods.
Upon completion of remedial action, any wetland areas
impacted by dredging, excavation, treatment, disposal
and/or associated activities performed in accordance
with components a, band c of the selected remedy,
will be restored or enhanced, to the maximum extent
feasible, to similar hydrological and botanical
conditions existing prior to these activities.
The restoration program will be developed during
design of the selected remedy to replace wetland '
functions and habitat areas. The Wetlands Restoration
Plan will evaluate utilizing the spotted turtle and
the mystic valley amphipod as biological indicators to
measure the success of the restoration. In addition,
this program will identify the factors which are key
to a successful restoration of the altered wetlands.
Factors will include, but not necessarily be limited
to, replacing and regrading hydric soils, provisions
for hydraulic control and provisions for vegetative
reestablishment, including transplanting, seeding or
some combination thereof. Quality assurance measures
shall include; (1) detailed topographic and vegetative
surveys to ensure replication of proper surface
elevations and vegetation; (2) engagement of a wetland
replication specialist; (3) establishment of work area
limits for equipment to prevent inadvertent placement
of fill; (4) production of a reproducible base map and
a detailed planting scheme; (5) photographic
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58
EPA, in consultation with MADEP, shall determine when
restoration shall be performed. Consideration shall
be given to breeding seasons of sensitive species,
climatic.conditions, and the time frame between
excavation activities and possible
stabilization/restoration activities.
The restoration program will include monitoring
requirements to determine the success of the
restoration. Periodic maintenance (i.e. planting) may
a150 be necessary to ensure final restoration of the
designated wetland areas.
e.
Long-Term Environmental Monitoring
Long-term environmental monitoring, including
sediment/soil monitoring shall be performed to
determine the degree to which sediment/soils are
mobilizing on- or off-site. Sediment/soils in the
Unnamed Stream, the stream's tributary and nearby
aquatic areas in the northwest portion of Middle Marsh
shall be periodically sampled to determine if
contaminants are migrating into these critical aquatic
areas. Samples shall be analyzed, at a minimum, for
TOC and PCBs.
Long-term monitoring of the wetlands shall be
conducted to ensure the long-term effectiveness of the
wetland restoration program.
All monitoring data and environmental conditions shall
be formally reviewed and evaluated during the
operation of the remedy to ensure that appropriate
response objectives are achieved. Monitoring
frequency and chemical parameters may be added or
deleted based on review of monitoring data, and upon
approval by EPA, in consultation with MADEP.
As required by law, EPA will review the Middle Marsh
Operable Unit at least once every five years after the
initiation of remedial action at the Middle Marsh
Operable Unit if any hazardous substances, pollutants
or contaminants remain at Middle Marsh or the Adjacent
Wetland to assure that the remedial action continues
to protect human health and the environment. EPA will
a150 evaluate risk posed by the Middle Marsh Operable
Unit at the completion of the remedial action (i.e.,
before the Site is proposed for deletion from the
NPL). Future remedial action will be considered if
the environmental monitoring program determines that
unacceptable risks to human health and/or the
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59
contaminants.
f.
Institutional Controls
EPA's choice of the selected remedy is based in part
on the assumption that the future land use of Middle
Marsh and the Adjacent Wetland will be recreation and
conservation. PCB cleanup levels for sediment/soils,
as described in Section X.A. above, have been derived
based on such future land uses. Therefore,
institutional controls, such as zoning ordinances
and/or deed restrictions, shall be implemented to
ensure that future uses of Middle Marsh and the
Adjacent Wetland are limited to its existing
recreation and conservation purposes. Residential and
non-recreational commercial uses of these areas will
be prohibited.
The effectiveness of institutional controls shall be
re-evaluated during the five year reviews described
above. If, at the five year review, or at any time
during or after completion of remedial action, EPA
determines that additional or alternative
institutional controls are necessary to protect human
health, then such additional or alternative
institutional controls will be implemented for a
portion or all of the properties in the Middle Marsh
Operable Unit, including the New Bedford Municipal
Golf Course.
2 .
Contingency Remedy
EPA'S selected remedy - excavation, dewatering, and disposal
beneath the cap that will be constructed over portions of
the Sullivan's Ledge Disposal Area - is dependent upon
Middle Marsh excavations being conducted prior to capping of
the Disposal Area. If the cap is constructed before the
Middle Marsh excavations are conducted, the selected remedy
could not be implemented.
Design of the Disposal Area cap is currently underway. In
accordance with a legal agreement between EPA, the
Commonwealth of Massachusetts and fourteen parties that have
been determined to be potentially responsible for
contamination at the Sullivan's Ledge First Operable Unit,
this work is being conducted by the 14 Potentially
Responsible Parties, under supervision of EPA, in
consultation with MADEP.
Because it is not certain that the excavation of targeted
sediment/soils in Middle Marsh and the Adjacent Wetland
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installation of the cap at the Sullivan's Ledge Disposal
Area, EPA has selected a second alternative, a contingency
alternative, to be implemented, if EPA, in consultation with
MADEP, determines that the Disposal Area would not be
available for placement of the excavated sediment/soils from
Middle Marsh and the Adjacent Wetland. The contingency
alternative is described below.
While a number of factors may affect the schedule for
. remedial construction at the First Operable Unit, CERCLA
places a high value on the speedy cleanup of sites,
especially principal threats, as found at the Disposal Area.
Accordingly, it would be inconsistent with CERCLA to delay
significantly the construction of the First Operable Unit in
order to allow coordination of construction for the Middle
Marsh Operable Unit.
Pre-design activities for the First Operable Unit are
currently being conducted. EPA anticipates that based on
preliminary time schedules, the remedial design for the
First Operable Unit will be completed by March of 1994.
EPA has determined that if additional design activities
necessary to implement the selected remedy for the Middle
Marsh Operable Unit are not completed in time to integrate
the design elements for the Middle Marsh Operable Unit into
the Remedial Design (which is to be submitted and approved
under schedules approved according to the Consent Decree for
the First Operable Unit), then the contingency remedy shall
be implemented.
The contingency remedy would include all site preparation,
excavation, wetlands restoration, long-term monitoring and
institutional control activities of the selected remedy, as
described in components a,b,d,e and f above. However, under
the contingency remedy, excavated sediment/soils from Areas
1, 2, 3 and 4, as delineated in Figure 9, would be treated
using a solvent extraction process.
The solvent extraction process generally involves the use of
a solvent to remove PCBs and other organic chemicals from
the sediment/soils. The first step in this process is to
mix the contaminated sediment/soils with water and the
solvent in order to extract the PCBs and other organic
chemicals from the sediment/soils. Once the extraction is
complete, the treated sediment/soils are removed from the
mixture. Sediment/soils that do not meet EPA's target
cleanup goals after an initial extraction will again be
treated in the solvent extraction process until the target
levels are attained. The liquid solvent/PCB/water mixture
is then heated, separating the solvent/PCB-contaminated oils
from the PCB-free water. The solvent is then separated in a
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solvent extraction process will take place in a closed unit
to prevent any. contaminant air emissions.
The facilities will be designed and best management
practices related to the storage and use of solvent, other
chemical products and waste will be used, in accordance with
state and federal regulations, including RCRA requirements
and requirements for above-ground storage tanks. Extracted
PCBs and other organic chemicals will be collected, stored
and disposed of off-site by incineration in accordance with
TSCA regulations at 40 CFR Part 761. Residual water from
the process will be pumped into storage tanks for treatment
by a portable carbon unit, and other treatment units
necessary to achieve regulated discharge limits, located on-
site.
Solvent extraction is an innovative treatment. Prior to
implementation of the full-scale process at the site,
predesign treatability studies, including a bench-scale
study will be conducted to determine the implementability of
this technology on site-specific contaminants and on a full-
scale level. The treatability study will yield information
on optimum operational settings, percent reduction of
organic compounds in sediment/soils and the volumes and
types of residuals and byproducts produced by the operation
of the treatment system. Results of the treatability
studies will also be evaluated to determine appropriate
material handling methods that will be implemented during
remedial action. This evaluation will determine the extent
to which sediment/soils will be blended prior to treatment,
based on sediment/soil characteristics and/or contaminant
levels, to ensure the optimal effectiveness of the solvent
extraction process in reducing site contaminants to
respective target levels.
Prior to full-scale implementation of the solvent extraction
process on the Site, treatability tests, including TCLP
tests, would be conducted to establish the optimum treatment
design, and to verify that sediment/soil residues from the
process are nonhazardous. If, after treatment, the
sediment/soils are determined to be characteristic of RCRA
hazardous waste, then these sediment/soils would be
solidified to render the materials non-hazardous or in the
alternative to meet the land disposal restriction
treatability variance requirements.
Treated sediment/soils from the solvent extraction process
would be mixed with fresh organic material and returned to
the excavated area within Middle Marsh and the Adjacent
Wetland. The addition of organic material to the treated
sediment/soils would be necessary because the solvent would
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untreated sediment/soils and necessary for suitable wetland
fill.
XI.
STATUTORY DETERMINATIONS
The selected remedy and contingency remedy selected for
implementation at the Middle Marsh Operable Unit are consistent
with CERCLA and, to the extent practicable, the NCP. The
selected and contingency remedies are protective of human health
and the environment, attain ARARs, and are cost-effective. The
selected remedy does not, however, satisfy the statutory
preference for treatment which permanently and significantly
reduces the mobility, toxicity or volume of hazardous substances
as a principal element, based on the reasons discussed in Section
XI.E below. The contingency remedy satisfies the statutory
preference for treatment which permanently and significantly
reduces the mobility, toxicity or volume of hazardous substances
as a principal element. Additionally, the selected remedy and
the contingency remedy utilize alternate treatment technologies
or resource recovery technologies to the maximum extent
practicable.
A.
The Selected and contingency Remedies are Protective of
Human Health and the Environment
The selected and contingency remedies for the Middle Marsh
Operable Unit will permanently reduce the risks posed to the
environment by eliminating, reducing or controlling
exposures to environmental receptors through containment
(the selected remedy) or treatment (the contingency remedy),
engineering controls, and institutional controls.
Excavation of sediment/soils with PCBs exceeding cleanup
levels, as required by the selected and contingency
remedies, will permanently and significantly reduce the
risks to biota associated with exposure to contaminated
sediment/soils in Middle Marsh and the Adjacent Wetland, and
will reduce subsequent bioaccumulation.
As discussed above in Section VI.B (Ecological Risk
Assessment), the site-specific bioaccumulation data and
toxicity data show that PCBs in the Middle Marsh Operable
Unit present a substantial risk to wildlife in the
environment. The data show that, unless the soi1s and
sediments at the Middle Marsh Operable Unit are remediated
in accordance with the selected cleanup levels, adverse
effects on wildlife can be expected. EPA's evaluation of
the protectiveness of the selected and contingency remedies
also considered the effects of the temporary disruption of
wetlands habitat that will occur as part of the remedy
(primarily during the site preparation and excavation
phases), and the fact that wetlands will be restored to the
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the selected and contingency remedies will be protective of
the environment in the long-term. EPA'S evaluation of
impacts to the wetlands is further discussed in section
XI.B. .
As indicated in Tables 6 and 7, total excess lifetime
carcinogenic risks evaluated to reflect present and
potential future exposure for the contaminants of concern in
Middle Marsh and the golf course/Adjacent Wetland areas
corresponding to the average and the reasonable maximum
exposure scenarios fall within EPA's acceptable risk range
of 10-4 to 10-6. In addition, total non-carcinogenic risks
evaluated to reflect present and potential future exposure
for the contaminants of concern in Middle Marsh and the golf
course/Adjacent Wetland areas corresponding to the average
and the reasonable maximum exposure scenarios are less than
one, indicating that the potential for adverse health
effects are unlikely. Therefore, EPA has determined that,
based on the exposure assumptions described above, human
exposure to site contaminants in Middle Marsh and the golf
course/Adjacent Wetland through the current and future
pathways outlined in Section VI.A. would not result in
significant increases in carcinogenic risk if contaminant
levels were not remediated according to the selected and
contingency remedies. EPA has further determined that there
are no significant risks to human health posed by exposure
to noncarcinogenic contaminants in Middle Marsh and the golf
course/Adjacent Wetland. Excavation of sediment/soils with
PCBs exceeding the cleanup levels, in accordance with the
selected and contingency remedies will further reduce risks
associated with potential future exposure to contaminants
from direct contact with and ingestion of such
sediment/soils.
Under the selected remedy, disposal of excavated materials
under the impermeable cap to be constructed at the
Sullivan's Ledge Disposal Area will provide a barrier
against exposure to contaminated sediment/soils to both
human and environmental receptors. Periodic site visits and
maintenance will be performed to ensure the integrity of the
cap, and its effectiveness in preventing exposure to
contaminated sediment/soils. Similarly, institutional
controls will be implemented to regulate land use of the
site, including activities which may compromise the
integrity of the cap (part of the remedy selected for the
First Operable Unit) and restrictions on residential
development.
Under the contingency remedy, solvent extraction of PCBs
from excavated sediment/soils, off-site incineration of the
PCB-contaminated oil extract, disposal of treated
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wetland restoration will mitigate risks to environmental
receptors.
Finally, implementation of the selected and contingency
remedies will not pose unacceptable short-term risks or
cross-media impacts. Implementation of these remedies may
result in a slight increase in PCB exposure to workers
during remedial activities. In addition, implementation of
the contingency remedy may pose a potential risk to workers
due to possible exposure to solvents. However, any short-
term risks will be mitigated by requiring workers to wear
protective clothing. Although PCBs are not volatile and
inhalation of contaminants is not expected to be a problem,
the breathing zone will be monitored and respirators worn if
necessary. Dust is not expected to be a problem during
excavation or transport of sediment/soils, however, control
measures such as water will be kept available in case
roadways or other areas become too dry. For all remedial
activities that may include sediment/soil movement, an air
monitoring program will be implemented during the
performance of the activities to determine risks to on-site
workers, golfers and nearby residents. Measures will be
utilized to limit potential air emissions from site
preparation, excavation, treatment and disposal activities,
including the following methods: enclosure of the work
areas; emission suppression techniques (e.g. foam, water
spray); and containment of excavated sediment/soils.
Short-term risks would also be present for wildlife in the
wetlands during the limited time that site remediation and
restoration would be required. However, engineering
controls would be chosen and implemented to minimize
downstream impacts resulting from excavation and other
impacts on the wetlands, including the use of sandbags,
earthen dikes, silt curtains and sedimentation basins.
Containment of the sediment/soils, as required by the
selected remedy, would not result in cross-media impacts
because disposal under an impermeable cap would minimize the
transport of contaminants from sediment/soils to air and
surface waters. In accordance with the contingency remedy,
solvent extraction of sediment/soils and off-site
incineration of the oil extract would be performed to
mitigate cross-media impacts to the air by the use of air
pollution devices on the incinerator and engineering
controls (e.g. closed system) for the solvent extraction
unit. Finally, as described in component d of the selected
remedy, remedial activities associated with the selected and
contingency remedies would be performed to mitigate impacts
to the fauna and flora including the use of sedimentation
basins or silt curtains to prevent the transport of
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B.
The Selected Remedy and continqency Remedy Attain ARARs
The selected and continqency remedies will attain all
applicable or relevant and appropriate federal and state
requirements that apply to the Middle Marsh Operable Unit.
Environmental laws from which ARARs for the selected and
contingency remedial actions are derived, and the specific
ARARs include:
Resource Conservation and Recovery Act (RCRA)
Toxic substances Control-Act (TSCA)
Clean Water Act (CWA)
Executive Order 11988 (Floodplain Manaqement)
Executive Order 11990 (protection of Wetlands)
Clean Air Act (CAA)
state environmental regulations which are applicable or
relevant and appropriate to the selected remedial action at
the site include:
Hazardous Waste Regulations
Wetlands Protection Regulations
certification for Dredging and Filling in Waters
Air Quality Standards
Air Pollution Control Regulations
Surface Water Quality standards
supplemental Requirements for Hazardous Waste
Management Facilities
Tables 9, 10 and 11 provide a synopsis of the applicable or
appropriate requirements and to be considered (TBCs)
requirements for the selected remedy and for the contingency
remedy, respectively. A brief narrative summary of the
major ARARs and TBCs follows:
Sediment/soils
Hazardous and Solid Waste Amendments to the Resource
Conservation and Recoverv Act
The Commonwealth of Massachusetts has been authorized by EPA
to administer and enforce RCRA programs in lieu of the
federal authority. compliance with Massachusetts RCRA
regulations is discussed below. However, land disposal
restrictions (LDRs) promulgated under the Hazardous and
Solid Waste Amendments to RCRA (HSWA) and codified at 40 CFR
section 268, may be applicable under certain conditions.
The applicability of HSWA regulations as action-specific
requirements for disposal depends on whether the wastes are
hazardous, as defined under RCRA. In this case, the
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of inorganics, including lead, such that these
soils/sediments would be considered characteristic of
hazardous waste.6. During predesign, TCLP tests shall be
performed to determine if the sediment/soils are
characteristic, of RCRA waste. If, upon evaluation of the
results of the TCLP tests, sediment/soils are determined to
be RCRA hazardous waste, then sOlidification/stabilization
of these sediment/soils shall be performed, to render the
materials non-hazardous,or in the alternative to meet the
treatability variance provided in the hazardous waste land
disposal restrictions. EPA expects, however, that LDRs will
not be applicable to those sediment/soils, because the
Agency expects that after the sediment/soils are solidified,
they will no longer exhibit any characteristics of hazardous
wastes. If LDRs are applicable, the selected remedy and
contingency remedy will comply with LDRs through the use of
a treatability variance.
~
~
Massachusetts DEP Hazardous Waste Reaulations
The applicability of Massachusetts Hazardous Waste
Regulations depends on whether wastes at Middle Marsh
Operable Unit are classified as hazardous waste under state
law. If PCB concentrations in any soils/sediments to be
excavated and disposed of are equal to or greater than 50
ppm, or if such soils/sediments exhibit the characteristics
of hazardous waste due to the presence of metals, the
Massachusetts Hazardous Waste Regulations will be applicable
to those soils and sediments.
In the case of the sediments and soils to be excavated from
the Middle Marsh Operable Unit during the selected remedy
and the contingency remedy, EPA expects that the
concentrations of PCBs will not, in most instances, exceed
50 ppm.7 In addition, both the selected remedy and the
contingency remedy call for sOlidification/stabilization of
soils and sediments which are characteristic of hazardous
waste due to the presence of metals. EPA expects that
6The Agency has determined that none of the wastes in the
sediment/soils at the Middle Marsh Operable Unit are listed
hazardous wastes under RCRA because the specific processes
creating the wastes are unknown.
7 Even if PCB concentrations in these media do exceed 50
ppm, 310 CMR 30.501 provides that the Massachusetts hazardous
waste regulations do not apply if the materials are handled and
disposed of in accordance with the federal standards contained in
the TSCA regulations, at 40 C.F.R. 761. As discussed below, the
selected remedy and the contingency remedy comply with these
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following solidification/stabilization, such soils and
sediments will no longer be characteristic of hazardous
waste. For these reasons, EPA expects that the
Massachusetts ,Hazardous Waste Regulations are not applicable
to the disposal of soils and sediments at the Middle Marsh
Operable Unit. However, since the soils. and sediments may
be similar to hazardous wastes, portions of these
regulations are relevant and appropriate.
Implementation of the selected remedy and the contingency
remedy will comply with the following provisions of the
Massachusetts hazardous waste regulations at 310 CMR 30.00:
General management standards for all facilities (310 CMR
30.510); contingency plan, emergency procedures,
preparedness, and prevention (310 CMR 30.520); Manifest
system (310 CMR 30.530); and Use and management of
containers (310 CMR 30.680).
Under the selected remedy, the soils and sediments to be
excavated from Middle Marsh and the Adjacent Wetland will be
disposed of under the cap at the Disposal Area. These
activities at the Disposal Area will comply with relevant
and appropriate portions of the following Massachusetts
hazardous waste regulations: Closure and post-closure (310
CMR 30.580, 310 CMR 30.590); Landfills (310 CMR 30.620);
Groundwater protection (310 CMR 30.660). As discussed in
the 1989 ROD, the portion of the DEP landfill regulations
requiring a double liner is not appropriate to the Disposal
Area and will not be attained. Because of the
impracticability of excavating the quarry pits, large
volumes of wastes will be left in the quarry pits underneath
the PCB-contaminated soils and sediments, and placement of a.
double liner over the wastes in the quarry pits would be
ineffective in containing the wastes. Closure and post-
closure requirements requiring, among other things, that the
cap attain a certain low permeability standard and act to
minimize migration of liquids through the landfill in the
long term will be attained. As discussed in the 1989 ROD,
relevant and appropriate requirements for leachate
collection and groundwater monitoring will be achieved at
the Disposal Area as part of the selected remedy for the
First Operable Unit.
For the selected remedy, the placement of contaminated
sediment/soils under a cap will occur outside the 100-year
floodplain, in accordance with location standards in the
Massachusetts Hazardous Waste Regulations. In addition, the
substantive elements of the contingency plan, emergency
procedures, preparedness and safety requirements will be
satisfied.
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To the extent that the soils and sediments to be excavated
from t~e Middle Marsh Operable Unit contain PCB
concentrations of greater than 50 ppm, the PCB Disposal
Requirements promulgated under TSCA are applicable. As
discussed in the 1989 ROD, disposal of PCB-contaminated
soils and sediments under the cap at the Disposal Area will
comply with the chemical waste landfill requirements of 40
C.F.R. S 761.75, with the exception of certain
requirementsB which were waived pursuant to 40 C.F.R. S
.761.75(c) (4). Accordingly, the selected remedy will comply
with PCB Disposal Requirements.
The PCB Disposal Requirements are also applicable to the
contingency remedy because it involves disposal of liquids
(oil extract) contaminated with PCBs in excess of 50 ppm.
The PCB-contaminated extract produced from the solvent
extraction treatment will be treated off-site in an
incinerator meeting the standards of 40 C.F.R. S 761.69.
o
~
Both the selected remedy (for sediment/soils with PCBs
greater than 50 ppm) and the contingency remedy require the
construction of a storage area meeting the PCB storage
requirements of 40 C.F.R. Section 761.65.
FloodDlains and Wetlands ARARs
The regulations under Section 404 of the Clean Water Act
(CWA) are applicable to the selected remedy, because
construction of roads in the wetlands will involve a
discharge of dredged or fill material. In addition, wetlands
restoration will involve backfilling to the extent necessary
to create grading, elevation and drainage approaching
original patterns and to serve as substrate for replacement
of vegetation. The Section 404 regulations are applicable
to the contingency remedy for the same reasons, and also
because the contingency remedy calls for the placement of
treated soils and sediments (from which the PCBs have been
extracted) back into Middle Marsh and the Adjacent Wetland.
Regulations promulgated under the Clean Water Act require
that, before a project which involves a discharge of fill
material into a wetland is undertaken, there must be an
analysis of the impact of such a project on the aquatic
environment, and a comparison to other practicable
alternatives. 40 C.F.R. S23G.10(a). In this case, EPA
compared the selected remedy and contingency remedy to other
8 The requirements relating to low permeability clay
conditions, use of a synthetic membrane liner, and distance
the high water table, 40 C.F.R. S 761.75(b) (1), (2) and (3),
waived in the 1989 ROD.
from
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alternatives which did not involve a discharge of fill
material to Middle Marsh and the Adjacent Wetland. EPA
compared excavation (as called for in the selected and
contingency re~edies) to: (1) a "no action" remedy; (2)
capping contaminated soils and sediments in Middle Marsh and
the Adjacent Wetland; and (3) in-situ bioremediation.
EPA determined that none of the alternatives to excavation
would be able to achieve the overall purpose of the project,
which is to reduce risk to environmental receptors at the
Site, without causing other significant adverse impacts to
the environment. Specifically, a "no action" remedy would
leave PCBs in place, and bioaccumulation which is known to
occur at the Middle Marsh operable unit would continue,
causing adverse effects on higher trophic level species.
Thus, although the habitat would remain intact, adverse
environmental effects due to the presence of PCBs would
continue. In-situ bioremediation would cause less temporary
disturbance to the wetlands than excavation, but the
technology has several major limitations: it is not proven
for PCBs, it is not certain that the technology can attain
cleanup goals, it may not be effective in dense organic
soils, the organisms may metabolize sediment organics
instead of PCBs, and there are few contractors available to
perform the technology. In addition, bioremediation may not
be less disruptive of the wetlands because of the need to
rototill the soil during the aerobic phase of
bioremediation. Finally, capping contaminants within the
wetland would result in permanent loss of wetland habitat
and loss of flood storage capacity. Accordingly, EPA has
concluded that the only practicable alternative that will
attain the'project purpose of reducing risk to environmental'
receptors but does not also permanently destroy wetlands
habitat is an alternative that provides for excavation of
soils and sediments contaminated with PCBs above the cleanup
level. Accordingly, EPA has determined that there are no
other practicable alternatives which would have a less
adverse impact on the aquatic ecosystem than the impacts of
the selected remedy and the contingency remedy.
The selected and contingency remedies also satisfy the
substantive requirements of 40 C.F.R. 230.10(b). Mitigation
techniques such as silt curtains will be used so that the
action will not cause or contribute to the violation of a
state water quality standard; the action will not violate
toxic effluent standards under the Clean Water Act; and the
action will not jeopardize the continued existence or
critical habitat of species listed in the Endangered Species
Act. In addition, consistent with 40 C.F.R. S 230.10(c),
the selected and contingency remedies will not cause or
contribute to significant degradation of the waters of the
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environment caused by PCBs, and the discharge which is
necessarily involved as part of the remedial action will not
have a significant, long-term adverse effect on aquatic life
and other wildlife, or on ecosystem diversity, productivity
and stability.
The selected and contingency remedies will comply with the
substantive requirements of 40 C.F.R. S 230.70 to minimize
adverse impacts to the aquatic ecosystem, by creating
sedimentation basins and by restoring the stream and
wetlands, to the extent feasible.
In addition, the policies expressed in Executive Orders
regarding wetlands and floodplains were taken into account
in the selected and the contingency remedies. The remedies
will include steps to minimize the destruction, loss, or
degradation of wetlands in accordance with Executive Order
11990, and will include steps to reduce the risk of
floodplain loss in accordance with Executive Order 11988.
DEP Wetlands Protection Regulations concerning dredging,
filling, altering or polluting inland wetlands are
applicable to the dredging of Middle Marsh and the adjacent
wetland. The remedial actions will comply with the
performance standards of the regulations regarding banks,
vegetated wetlands, and lands under water, and a one-for-one
replication of any hydraulic capacity which is lost as the
result of this part of the remedial actions.
The selected and contingency remedies satisfy the
substantive requirements for a variance from the.
Massachusetts wetlands regulation stating that a project
which alters the habitat of a state-listed species of
special concern cannot have any short or long term adverse
effects on the habitat of the local population of that
species. 310 CMR 10.58, 10.59. As a condition of the
variance, it may be appropriate to use the Spotted Turtle
and Mystic Valley Amphipod as biological indicators of
habitat restoration. The wetland restoration program will
evaluate methods for using these two state-listed species of
special concern as biological indicators of habitat
restoration.
Because Middle Marsh and the adjacent wetland are within the
areal extent of contamination, they are considered part of
the Site, and no permits will be necessary. .
Surface Water
Clean Water Act
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to the discharge of treated waters to the surface waters of
the Unnamed stream, or any other designated surface water
body. Under Section 121(e) of CERCLA, no permit is required
under the NPDES program for these discharges, because the
effluent from xhe treatment facilities (e.g. dewatering,
solvent extraction) will be discharged directly into a
surface water of the United states at a point considered
part of the CERCLA site.
Massachusetts Surface Water Oualitv Standards
Massachusetts water quality standards for discharge to
surface waters are applicable-to discharges to the Unnamed
stream. The Unnamed Stream is classified as Class B, for
the uses and protection of propagation of fish, aquatic life
and wildlife, and for primary and secondary contact
recreation. Massachusetts standards state that water shall
be free from pollutants that exceed the recommended limits,
that are in concentrations injurious or toxic to humans, or
that exceed site-specific safe exposure levels determined by
bioassay using sensitive species. At Sullivan's Ledge, these
standards will be attained by using either ambient water
quality standards or whole effluent toxicity limits.
Bioassay tests may also be performed to determine site-
specific safe exposure levels. Because the effluent from
the treatment facilities and dewatering activities will be
discharged directly into the Unnamed stream at a point
considered part of the Site, no permit is required.
Air
Standards for particulate matter under the Clean Air Act and
DEP Air Pollution regulations are applicable and will be
attained during construction phases.
other Laws
The selected remedy and the contingency remedy will comply
with certain other laws and regulations, although strictly
speaking, they are not ARARs because they are not
environmental laws or relate only to off-site activities.
These laws include, but are not limited to: the
occupational Health and Safety Act, 29 U.S.C. 651 et ~.;
Department of Transportation Hazardous Material
Transportation Act regulations, 49 C.F.R. 171-179, 387;
Massachusetts Requirements for Transporters of Hazardous
waste, 30 CMR 30.400; and Massachusetts Right to Know
Requirements, 105 CMR 670.00, 310 CMR 33.00, and 454 CMR
21. 00.
C.
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In the Agency's judgment, the selected and contingency
remedies are cost effective, i.e., the remedies afford
overall effectiveness proportional to their costs. In
selecting these remedies, once EPA identified alternatives
that are protective of human health and. the environment and
that attain, or, as appropriate, waive ARARs, EPA evaluated
. the overall effectiveness of each alternative by assessing
the relevant three criteria--long term effectiveness and
permanence; reduction in toxicity, mobility, and volume
through treatment; and short term effectiveness, in
combination. The relationship of the overall effectiveness
of the selected and contingency remedial alternatives was
determined to be proportional to their costs.
c
~
1.
Selected Remedy
The costs associated with the selected remedy are:
Estimated Capital Costs: $2,640,000
Estimated Operation and Maintenance Cost (net present
worth): $164,000
Estimated Total Cost (net present worth): $2,800,000
Of the source control alternatives discussed in Section
VIII., EPA has determined that the selected remedy
(excavation, dewatering, disposal under an impermeable cap)
may be only slightly less effective in the long-term as
alternative 6(a) (solidification/stabilization, disposal at
the Disposal Area) and alternative 6(b)
(solidification/stabilization, disposal at golf course
landfill) because under the selected remedy, the
contaminants would be placed in a RCRA landfill that would
include groundwater treatment and monitoring to ensure the
effectiveness of the landfill. Although this selected
remedy does not provide permanence through treatment, unless
required by the land disposal restrictions, it may not be
necessary to solidify or otherwise treat excavated Middle
Marsh and Adjacent Wetland sediment/soils because the levels
of PCBs are relatively low, less than 50 ppm, and would be
properly contained under a RCRA engineered cap to be
constructed as part of the First Operable Unit. While the
selected remedy does not provide the same degree of
permanence as alternatives requiring solvent extraction
and/or incineration, for the Middle Marsh Operable Unit
uncertainty associated with the long-term effectiveness of
the selected remedy in containing relatively low levels of
PCBs shall be minimized by engineering and institutional
controls.
In comparison to all other containment/treatment
alternatives, the selected remedy is the least costly, with
a present worth cost of $2,800,000. In contrast, present
-------
73
include: solidification/disposal from $5.0 to $6.0 million;
solvent extraction at $7.8 million; and on-site incineration
from $9.8 to $10.0 million.
2.
contingency Remedy
The costs associated with the contingency remedy are:
Estimated capital Costs: $7,620,000
Estimated Operation and Maintenance Cost (net present
worth): $164,000
Estimated Total Cost (net present worth): $7,780,000
If the Disposal Area is unavailable for disposal of
excavated materials, EPA has determined that solvent
extraction, followed by off-site incineration of the PCB-
contaminated oil extract (the contingency remedy), would be
the most effective of the remaining source control
alternatives in permanently and significantly reducing the
toxicity, mobility and volume of hazardous substances and in
reducing contaminant levels in sediment/soils to cleanup
levels. A comparison of present worth costs for solvent
extraction and on-site incineration indicates that the
present worth costs for solvent extraction are lower than
on-site incineration, $7.8 million versus $10.0 million,
respectively.
D.
While the solidification/containment alternative is cheaper
than the contingency source control alternative (solvent
extraction), the contingency alternative is significantly
more effective in the long and short term, and is permanent.
EPA has determined that there are some uncertainties
associated with the long-term effectiveness of
sOlidification/stabilization and on-site disposal in a
landfill constructed in the golf course. In addition, this
alternative would require construction of a new landfill in
a golf course and would significantly restrict public access
to golf facilities. As stated above, the selected source
control alternative (solvent extraction/off-site
incineration) is less expensive than the only other
treatment alternative (on-site incineration) which provides
an equivalent measure of long-term effectiveness. Thus,
assuming the selected remedy would not be implementable, the
selection of solvent extraction as the contingency source
control alternative for sediment/soils is cost-effective;
the costs are proportional to the overall effectiveness.
The Selected Remedy and contingency Remedy utilize Permanent
Solutions and Alternative Treatment or Resource Recovery
Technologies to the Maximum Extent Practicable
The No Action alternative was eliminated from consideration
-------
74
would not attain ARARs, as described in sections IX.B.l. and
IX.B.2., respectively. Once the Agency identified those
alternatives that attain or, as appropriate, waive ARARs and
that are protective of human health and the environment, EPA
identified which alternatives utilize permanent solutions
and alternative treatment technologies or resource recovery
technologies to the maximum extent practicable. This
determination was made by identifying alternatives that
provide the best balance of trade-offs 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.
o
1.
Selected Remedy
The selected remedy provides the best balance of trade-offs
among the alternatives. The selected remedy would be
protective of human health and the environment by reducing
contaminant levels to meet cleanup levels. Given the low
levels of PCBs detected in sediment/soils (less than 50 ppm)
and the fact that the Sullivan's Ledge Disposal Area would
be capped as part of the remedy for the First Operable Unit,
EPA has determined that, for the Middle Marsh Operable Unit,
treatment is impracticable. Excavation, dewatering and
disposal of sediment/soils in the RCRA engineered landfill
to be constructed at the Disposal Area provides the best
balance of all alternatives considering short- and long-term
effectiveness and cost. Of all the action alternatives,
excavation and capping would be the most easily
implementable as it would not require use of specialized
units with sometimes limited availability. The placement of
excavated sediment/soils under the cap to be constructed
over the Disposal Area would not significantly increase the
volume of contaminated materials as would
solidification/stabilization alternatives but would
significantly reduce the mobility of hazardous substances
through enqineerinq and institutional controls.
2.
Contingency Remedy
Assuming the Sullivan's Ledge Disposal Area would not be
available for disposal of excavated sediment/soils from
Middle Marsh and the Adjacent Wetland, EPA has determined
that the contingency remedy, excavation and solvent
extraction, utilizes permanent solutions to the maximum
-------
75
(contingency technology) meets the statutory preference for
utilizing treatment technologies that significantly and
permanently r~duce the toxicity, volume or mobility of all
hazardous substances. In addition, removal of the
sediment/soil contaminants will reduce the source of
sediment/soil contaminants, mitigating the possibility of
PCBs migrating off-site.
Although solvent extraction is an innovative treatment, the
results of treatability studies performed on various soils
and sediments at other Superfund sites indicates that this
technology will be effective in meeting cleanup levels for
sediment/soils. This determination will be confirmed by
site-specific treatability studies on solvent extraction.
Solvent extraction has been selected over on-site
incineration because it is an alternate treatment, as
preferred by CERCLA, and is equally effective as
incineration in attaining the protective cleanup levels of
this remedy but at a lower estimated present worth cost
($7.8 million for solvent extraction; $10.0 million for
incineration). Disadvantages associated with
sOlidification/containment SC-6(b) include the uncertainty
of the long-term effectiveness of the containment system
located on the golf course for untreated wastes and the
potential for future remedial costs and risks to the
environment if the cap were to fail.
E.
The Selected Remedy for the Middle Marsh Operable Unit is
Primarily a Containment Remedy, and Does Not Use Treatment
as a principal Element to Permanently and significantly
Reduce the Toxicity, Mobility or Volume of the Hazardous
Substances; The contingency Remedy Does satisfy the
Preference for Treatment Which Permanently and significantly
Reduces the Toxicity, Mobility or Volume of the Hazardous
substances as a principal Element.
The principal threats identified at the Sullivan's Ledge
Site will be addressed through treatment by implementation
of the remedial activities selected in the 1989 ROD. As
described above, the remedial investigations at the
Sullivan's Ledge Superfund Site, including the First
Operable Unit and the Middle Marsh Operable Unit, revealed
that high concentrations of PCBs and polyaromatic
hydrocarbons (PARs) were present in surface and subsurface
sediment/soils. Based on the results of these remedial
investigations, EPA concluded that the sources of
contamination within the Sullivan's Ledge study area are:
wastes disposed of in the former quarry pits, contaminated
soils in the 12-acre Disposal Area, and sediments that wash
off the Disposal Area.
-------
76
Disposal Area and nearby areas, including the Unnamed
stream. The selected remedial action, as established in the
ROD, includes. source control components to address the'
principal threats at the Sullivan's Ledge Site. The
components of the First Operable Unit remedy are:
Fencing and site preparation;
Excavation and on-site sOlidification/stabilization of
contaminated soils in the unsaturated zone at the
Disposal Area; -
Excavation and on-site sOlidification/stabilization
(if necessary) of contaminated soils in the
unsaturated zone in areas immediately east and north
of the Disposal Area. All excavated and/or solidified
soils shall be disposed on the Disposal Area under the
cap;
Excavation/dredging, dewatering,
sOlidification/stabilization (if necessary) and on-
site disposal of contaminated sediments from the
Unnamed Stream up to and including the two golf course
water hazards;
Construction of an impermeable cap over approximately
11 acres of the Disposal Area;
Implementation of a wetlands restoration and
maintenance program;
Long-term monitoring; and
Institutional controls.
Thus, the principal threats at the Sullivan's Ledge Site are
addressed through implementation of the remedy for the First
Operable Unit. However, implementation of the Middle Marsh.
Operable Unit will be necessary to address remaining threats
at the Site and to ensure a site-wide remedy that is
protective of human health and the environment.
1.
Selected Remedy
The selected remedy for the Middle Marsh Operable Unit is
primarily a containment remedy, and does not satisfy the
preference for treatment as a principal element. Given the
low levels of PCBs detected in sediment/soils (less than 50
ppm) and the fact that the Sullivan's Ledge Disposal Area
would be capped as part of the remedy for the First Operable
Unit, EPA has determined that for the contaminated
sediment/soils in Middle Marsh and the Adjacent Wetland,
treatment is impracticable. This approach is consistent
with the 1989 ROD, which specified that only unsaturated
soils with PCB concentrations equal to or greater than 50
ppm will be treated (solidified) prior to disposal within
the Disposal Area. Unsaturated soils in the First Operable
Unit in areas outside the 12-acre Disposal Area with PCB
-------
7.7
excavated, transported to and disposed of within the site's
Disposal Area. In summary, the overall response at the
Sullivan's Ledge site is consistent with the NCP
expectations to treat principal threats and contain low
threat material.
2.
Contingency Remedy
The contingency remedy satisfies that statutory preference
for treatment as a principal element by specifying
excavation and solvent extraction of contaminated
sediment/soils equal to or above environmental risk-based
target levels. In addition, the PCB-contaminated oil
extract shall be treated off-site by incineration.
XII. DOCUMENTATION OF NO SIGNIFICANT CHANGES
EPA presented a proposed plan for remediation of the Middle Marsh
Operable Unit on May 24, 1991.
In summary, the preferred alternative, ~s described in the
proposed plan, consisted of the following components:
1. site preparation;
2. Excavation of contaminated sediment/soils from portions of
Middle Marsh and the Adjacent Wetland;
Dewatering of the excavated materials;
Disposal of the materials beneath the cap that will be
constructed over portions of the Disposal Area of the
Sullivan's Ledge site;
Restoration of the affected wetlands;
Institutional controls to prevent future residential use of
and restrict access to Middle Marsh and the Adjacent
Wetland; and
Long-term environmental monitoring.
3.
4.
5.
6.
7.
Because implementation of the preferred alternative is dependent
upon the Sullivan's Ledge Disposal Area being available for
disposal of Middle Marsh sediments and soils, a contingency
remedy was also described in the proposed plan consisting of the
following components:
1. site preparation;
2. Excavation of contaminated sediments and soils from portions
of Middle Marsh and the Adjacent Wetland;
Treatment of the excavated sediments by solvent extraction;
Disposal of the treated sediments at Middle Marsh;
Restoration of the affected wetlands;
Institutional controls to prevent future residential use of
and restrict access to Middle Marsh and the Adjacent
Wetland; and
Long-term environmental monitoring.
3.
4.
5.
6.
7.
-------
78
be implemented if, based upon EPA's determination in consultation
with MADEP, the timing of the Disposal Area cap construction to
be implemented in accordance with the Consent Decree for the
First Operable Unit would prevent further use of the Disposal
Area for the containment of excavated sediments and soils from
Middle Marsh and the Adjacent Wetland, as described in Section
X.B.2.
~
Neither the selected remedy nor the contingency remedy contain
significant changes from those proposed.
XIII. STATE ROLE
The Commonwealth of Massachusetts/Department of Environmental
Protection has reviewed the various alternatives and has
indicated its support for the selected and the contingency
remedies. The Commonwealth has also reviewed the Remedial
Investigation, Risk Assessment and Feasibility Study to determine
if the selected remedy and the contingency remedy is in
compliance with applicable or relevant and appropriate State
Environmental laws and regulations. The Commonwealth of
Massachusetts concurs with the selected remedy and the
contingency remedy for the Middle Marsh Operable Unit at the
Sullivan's Ledge Superfund Site. A copy of the declaration of
-------
79
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-------
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DECOMPOSERS; DEmITUS; DECAYING
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Figure 8
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SAlAMANDER
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-------
ti8
Table 1 ANIMAL SPECIES' TYPICALLY ASSOCIATED WITH WETLANDS
COVER TYPES IDENTIFIED AT HIDDLE HARSH
Cover TV'Des
Scientific CQ1Dmon Name Forested Scrub- Emergent
Name Wetland Shrubl Wetland
. Emergent "
AMPHIBIA
Ambystoma Spotted 8 8 8
maculatum salamander
Sufo Eastern 8 8 8
americanus American
~oad
Hyla crucifer Northern 8 8 8
Sprinq
Peeper
Rana Bullfroq 8 8
catesbeiana
Rana clamitans Green Frog 8 . .
Rana sylvatica Wood Froq . . .
Rana pi pi ens Northern . .
Leopard
Froq
REPTILIA
chelydra Common . .
serpentina Snapping
Turtle
CleIUmys Spotted . .
gutatta Turtle
chrysemys Painted . .
pi eta Turtle
Nerodia Northern . . .
sipedon Water Snake
Thar.:nophis Eastern . . .
sauritus Ribbon
-------
';"J
'Table 1
ANIMAL SPECIES TYPICALLY ASSOCIATED WITH WET~~S
COVER TYPES IDENTIFIED AT KIDDLE KARSH (CONT'D)
scientific
Name
Common Name
Forested
Wetland
Cover Types
Scrub- Emergent
Shrub! wetland
Emergent
AVES
Ardea herodins
Great Blue
Heron
.
.
Butorides
striatus
Green-
backed
Heron
.
.
.
Nycticorax
nycticorax
Black-
crowned
Night Heron
.
Aix sponsa
Wood Duck
.
.
.
Anas rubripes
American
Black Duck
.
.
.
AlJas
platyrhyncos
Buteo lineatus
Mallard
.
.
.
Red-
shouldered
Hawk
.
Falco
sparverius
Alnerican
Kestrel
.
.
.
Rallus
ellegans
Rallus
limicola
King Rail
.
.
virginia
Rail
.
.
.
Porzana
carolina
Sora
Gallinago
gallinago
common
Snipe
.
.
.
S-""'0""::I'7' ........~I""'\'"
---'- ~-- ~........--
American
Woodcock
.
.
.
Tachycineta
bicolor
Tree
Swallow
-------
T4.ble 1
ANIMAL SPECIES T~ICALLY ASSOCIATED ~ITH WET~~S
COVER TYPES IDE~7I7IED AT HIDDL! HARSH (CONT'D)
Scientific
Name
Common Name
Forested
Wetland
Cover TVDes
Scrub- Emergent
Shrubl Wetland
Emergent
cistothorus
platensis
Cistothorus
palustris
Sedge Wren
.
.
Marsh Wren
. ..
.
Vireo griscus
White-eyed
vireo
.
Dendroica
petec:hia
Yellow
Warbler
.
.
seiurus
noveborac:e!'Jsis
Northern
Water
Thrush
.
Geothlypis
tric:hes
CO%M'lon
Yellow-
throat
.
.
Melospiza
melodia
Song
Sparrow
.
.
Helospiza
georgiana
S",'arnp
Sparrow
.
.
Agelaius
pheoi.ic:eus
Red-winged
Blackbird
.
.
Quisc:alus
qui sc:ula
Casduelis
tristis
Common
Crackle
.
.
American
Goldfinch
.
.
.
pic:oides
pubesc:ens --
Downy
Woodpecker
.
~.AMY..ALIA
Castor
c:anadensis
Bea":e= -
.
.
Mic:rotus
pennsylvanic:us
Meadow Vole
.
.
-------
Table 1
ANI~~ SPECIES TYPICALLY ASSOCIATED WITB WET~~S
COVER TYPES IDE~7IFIED AT KIDDLE ~~SB (CONT'D)
Scientific
Name
. Common Name
Forested
Wetland
Cover TVt>es
Scrub- Emergent
Shrubl Wetland
Emergent
Ondatra Muskrat
zibethicus
Zapus Meadow
hudsonius Jumping
Mouse
Mustela vison Mink
Mephitis S'triped
mephitis Skunk
Sciurus Gray
carolinensis Squirrel
. .
. . .
. . .
.
-------
92
Table 2
~RT STATISTICS '01 MIOOLE MARSH SUR'ACE SEOIMENT/SOIL
(Or,anlca: ~/tg, lnorganlCI: 8I/tg>
Corcentration CJ
.-...............................
...." "Inl- MaallUll
'~Of S~le Oetected Arlt_tlc Oetected
Ch8111 i cal DttlC'ion'l> Siu Cb> Vilue "..n Vllue
<,
Or,lnlCI:
........
Acenaptl thene Z I Z' 2 62 69 75
Aceneptlthylene 1 I 2' , ... "
Acetone 6 I 10 10 19 68 190
Anthrlc."e 6 I 2' 7 69 150 2'0
'enZOCI)lnthrlcene 17 I Z' 19 130 400 ISO
IenZOCI)pyrene 17 I 2' " UO "0 . 880
'enzOCb)flwor&~t~~ 20/24 ~ ZO 660 2,100
'enzoCg,h,l)perY~ene 7 , 24 12 7' 300 500
'enZOCk)flworlnthene 16 I 2' 20 20 400 1,100
lenzoic Icid , I 2' 11 73 490 1,050
2..l.Iul"IOnt 2 I 12 11 , 15 30
'I.ItylbenZYI~thlllte 7 I 2' 11 100 230 310
ChlorofOMli 2 I 12 11 11 U
Chrysene 17 I 2' " 170 490 1,100
',".OOD 1 I 26 26 ... 110 590
-',".00£ 2 / 26 23 53.1 7' 210
4,".001 3 I 26 2' 120 '2 205
Oi.n.butylptlthllate 5 I 2' 13 65 300 '80
Oi.n.octylpnthilite 2 I 2' 2 130 140 "0
DibtnZOCI,h)lnthracene 4 I 24 , 84 110 150
Oibtn:ofuran 1 I 2' 1 ... 71
1,"Dic~lorobenzene 2 I 2' 2 " 120 150
bisC2.£thylheayl)phthlllte 21 I 22 22 120 1,300 3,500
, I worlnthene " I 2' 23 190 680 1,'00
'Iuorene 2 I 2' 2 79 86 92
IndenoC1,2,3.c,d)pyrene 8 / 2' 13 100 280 410
"et~ylene C~loride 7/7 7 9 '5 110
2-"tthylphenct 2 / 2' 7 200 280 340
'-"tt~ylp/'lenol 8 / 2' 2' 180 730 2,300
".n;trOSod;p/'Ie~ylamine 1 / 2' 1 ... 66
PCBs CAroclor.125') 50 I 57 57 380 8,700 60,000
Pe~tachlorop/'l.nol 1 / 2' 2 1,100 1,200
P~enanthrene 16 / 2' 19 130 400 830
Phenol 3 I 2' 8 180 270 350
Pyrene 19 / 2' 23 220 700 1,500
Tolwne 1 / 11 10 7.5 15
lnorganiCI:
.-.-......
All.fllinun 2' / 2' 2' 2,255 10,000 22,500
Arsenic 16 / 2' 21, 2 5.' 10.9
IIri "" 2' I 2' 2' 23 120 252
leryll i I.fII 2 / 21, 22 0.5 0.5 0.8
CaC2llil.fll 2 / 21, 2' 0.5 0.5 1.9
Calcil.fll 21, / 21, 24 702 5,100 15,100
Cllrcrnil.fll 7 I 2' 2' 15 19 51.2
tObllt 1 I 24 2' 3.5 S.,
Copper 'a I 2' 2' 24.8 47 '"
Iron 24 I 2' 2' 2,425 37,000 167,000
Lead 2' I 21, 21, 43.7 340 &1.5
Mlvnes i I.fII 22 I 2' 2' 1,520 3,300 7,'00
M'~va!'llU 2' / 2' 24 13.5 460 1,870
Mercury 1 I 2' 15 0.1 0.2
..ickel , I 21, 13 5.1 7.7
POUII i I.fII ,,, , 2' 21, 512 880 3,210
Se lln i I.fII 1 / 2' 1 ... 0.2
Sodil.fll 3 / 2' 2' 210 140 566
Thai I il.fll 1 / 2' 2' 0.' 1.3
Vanadl I.fII 21 I 2' 2' 31.7 61 110
Zinc 20 I 2' 2' 25.7 190 521
Ca) The number of sa~les in ~ich the contaminant WIS aetected di¥;dec Cy the totll rurDer of
SI~les analyzed.
Cb) The number of sa~les in cllel.lllt;nv the ~.n. This ~r may diffrr from t~e denomi"ltor
of the frequrncy of drtrction, br~a~'1 nO~'detect I~!es ;n which one-half thr dection limit
I.crrds the ma.i~ ¥llur in I group of sa~les were not included in cal~ulat;"9 thl ..an.
... . Not I~llcabll due to th, ...11 lampl, lilt or linee only one ~as~r8b11 concentration ~IS
-------
Table 2 (Cont'c'\)
~RT STATISTICS FOR THE GOLF CCURSEIWETLANO AREA StOl"ENT/~IL
(Or,anics: Ul/k" lnor,anics: -elk;)
tonc."trat' an
-----..--.........................
-un "'n'- ...1-
'r~y of S~II Oltl'Cted ArltllllRtlc Dltected
CII",'cal DltlCtian (a) Sin (b) Value ',"n Value
Or,lnicI:
........
ACltCl"l , I " 130
Anthracene , / 13 " 465 '90 890
lenzo(l)anthracene 5 / 13 " 60 I.OQ 180
If!''\Zo(l)pyrlne 5 I " " 55 380 180
..nzo(b)fluorantllene 5 / 13 '0 '40 640 180
Ilnzo(k)fluoranthene , / " " 280 '70 180
2.1 utll'lOnt , / " 30
lutylbenzylphtllalatl '/13 ' "
Chr'yllne 5 / " " 70 430 180
4 4"000 , / 28 ' ... ,
o!.n.butyiphtllilati 2 I 13 12 480 460 180
bis(2.Ethylh.~yl)phtb6l.te 7 I 13 '2 140 600 , ,500
FluorlntllP'le 7 / 13 " '00 4Z0 180
Ind.no(',Z,3.c,d)pyrene 1/ U " 335 640 180
Methylene Chloride , I , , ... 35
. Z.Metllylphlnol . 2 / '3 , 270 280 340
,."ethyl phenol , I 13 " ... 450 550
P:I, (Aroclor"ZS') 27 I 29 29 380 5,800 32,500
Pentlchlor~enol , / " " ... 2, '00 3,7'50
PheMnthrene 5 I 13 " 58 '20 180
Ptleno I , / '3 ' 140
Pyrene 7 I '3 " "0 420 180
Toluene , I " 15
lnorglnic.:
..........
AIUIIII'UII " I " " 5,760 1,'00 '0,140
Arunic 9 I " " 1.9 2.6 '.3
IIrlUII " I " " 23.7 37 67.6
Btryll lUll 9 I 11 " 0.6 0.7 '.2
CIC2IIIUII 9 I " " 0.9 1.2 2.'
ClleiUII " I " " 9" ',600 3, '05
ChremlUII '0 I " " 15.9 2Z 42
Cobilt 2 I " " 6 3.1 6.5
COpellr " I " " 8.7 20 31.8
Iran " I " " 8,190 " ,000 25,200
Llld l' I " " 9.' "0 352.5
M.gnes iUII " I " " , ,4030 2,300 4895
Mln;ln... " I " " 98.' '90 365
Mercury , I " " 0.' 0.3
Nickll , I " " 5.7 8 14.'
poullha '0 I " " 387 640 , ,97'5
SII."iUII 1 I '0 , 0.2 0.' 0.6
SodlUII 9 I " " '02 270 '7'
VIMdl"" '0 I " " '7.' 23 43.7
Zinc , I " " 13.7 52 111
(I) The numcer of s~lls in ~Ich tll. eantlminl"t M8$ Gttl'Cted divided by thl totll numDer of
18~le5 In.lyzed.
(b) Tile ~. 0' 'Imples In cllcullt;~g the ~8n. Th;, nuMber may diffe- 'rem the denomiMtor
of tile frequency oi detl'Cti~; btc.U5e ~~.Ottt:t ..~1.. in ~.ich ~'hllf tht dctecti~
I ;m;t ucH'dl the ....i- vllue in I IJr~ of ,~\~ ""re net ircluOed in e81eulatine the
mean.
.., . Mot 1~llc.bl. due to the sm811 ,~I. sizl or line. only ant ~alur.bl. cancentrat;on
-------
~4
Table 3
~RT STATISTICS 'OR "IDDL! MARS" SURFACE WATER
Coneentrltlon,. ug/L
<'
.-.-[[[
U~r 95 '.rcent
""n "inllUll Conf I aerie' L 1.1 t "I.IIUII
'r~ of 5~le Du.ceed ArithIMt Ic on the ArithIMtlc D.t.cted
Cl'lfIIIlc.1 CI) Duectlon Ca) Siae Vilue ""n ""n Vllue
Acttone 2 I 6 6 6 5.5 6.2 7
lenzoic Icid 1 I 6 1 ... ... 2
Clrbon t.trlchlorlde Z I 6 2 1 1.S 2
bis(2.!t"'ylh..yl)~thlllt. 1 I 6 1 ... ... 4.5
PCls (Aroclor 1254) (b) 2 I 5 5 0.01 0.02 0.06 0.077
{)
(I) S.y.rll IMtlls w.re IMllured In lurflce wlt.r. '~am I humen h.llth perspectly., chemiclls In lurflC. wlter
will be eYllu.~e= fo~ ~.~.1 Ibso~tion. Sine. the de~1 Ibsorption of metlls is insi8nificant, metal
cOl'\(t:'\trltiCll"llo I'" nor '&IIr'..,.iud ,..~..
(b) Repr.l.ntl resultl for filtered 18mp1.1 only.
-------
Table 4
PCB CONCENTRATIONS IN BIOTA SAMPLES COLLECTED
IN MIDDLE MARSH (CHARTERS. 1991)
LOC~ TJON SAMPL.E PCB (AROCLOR 1254)
(mQfkO)
ERT1 Benthos 0.1 U
Grltn Fro;, R,n, cl,mlt,rIS m.l,not, 0.25
Rose Hi"S, Flou multiflor, 0.1 U
Grass Seed Heaos, Ph,/oris If'lJndinlCII 0.1 U
ERT2 Benthos 0.35
GrHn Frog, ~n' cl,mit,rIS m./lnotl 0.27
Rose Hips, lIou multlflorl 0.1 U
Grass Seed Heads. Phlloris If'lJndlnlCN ' 0.1 U
ERT3 B.nthos O.~
Green Frog. FUn' cl,mit,ns m.l,flOfl 0.68
Green Frog, lI,n, cl,mit,ns m./lnotl 0.2.
Rosl Hips, Rou multlflorl 0.1 U
Grass Seed HeadS. Ph,/oriS If'lJndin'CII 0.1 U
EAT. BenthOS 0.1 U
~rthworm 0.1 U
M8I::JOw Vole. MlcrOlus p,nnsylVlnicus 0.1 U
Short-tail8<1 SMr.w, BI,ri'" br.viClI.ICl' 0.38
Short-tailed Shrew, BI,rin, br,viClud, 0.98
Rose Hips. Ros, mlJltiflor, 0.1 U
ERTS BenthoS 0.1 U
Grass Sled HeaOs. Ph,loris ,rlJndin,cea 0.1 U
EF1T 6 Green Frog. R,n, cl,mit,ns me/anot, 0.19
Rose HIPS, ROil mlJltiflor, 0.1 U
Grass Seed Heaos. Ph,loris ,rlJndinlCea 0.' U
ERT7 BenthOS 0.1 U
Green Frog, R,n, cl.mit,ns m.l.not, 0.73
EAST BANK ~rthworm 2.3
Green Frog, Ran, clamita!,s m",not, 0.39
Meadow Vole, Microtus p,nnsylv,nicus 0.36
Meaoow Vole, MicrotlJS pe''''sylv,niCus 0.38
Meadow Vole, MicrotlJs p,nnsylvlnicus 1.6
Ceer Mouse, PeromysclJS maniculatus O.s.
Ceer Mouse, P.rom~us m'f'licul'tus C.1 U
Cee! Mouse. P.romyscus m,nicut.nn 0.44
WEST BANK Earthworm 1.8
Ceer Mouse. Pe!omYSCIJS maniCIJII/US 0.27
Ceer Mouse, Peromys.cu$ manicul,tus 1
Ceer Mouse, PeromYSCIJS maniculatus 0.28
Wrute-footed Mouse. P,romyscL/S I'L/COPUS 0.84
While-footed Mouse. Pe'o,~YSCU$ 1'lJco;JuS 0.68
Wl'Iite-footed Mouse, Peromyscus 1'L/COpL/S 0.68
CRT 8 Green Fro:. Rana clamitans m"a."Iota 1.02
-------
Table 5
~RT OF CHEMICALS OF POTENTIAL CONCERN
"IDDLE ~RSM SURFACE SEDIMENT/SOIL
GOLF COURSE/WETLAND AREA
SURFACE SEDIMENT/SOIL
"fDDLE MARSH SURFACE WATER
0~81'1;CI:
Or,."lcI:
ACltOl'le
"l'Itllr8C-
Aroclor-1ZS'
l'I'IZO(8)8I'1tllr8CII'I8
IeI'lZ0CI)pyr81'\8
"l'IZoCb)fl~"al'ltll.1'Ie
1'l'Izo(k)f\uor8nth81'\8
2-,,,tll'IOn8
l"tylber'lZylphth818tl
Cllryul'l8
'." °000
Oi-l'l-butylp"thaI8t.
biICZ-fthylhIKyl)phth818te
FllIOrll'lthll'l'
11'Id'l'IoC1.2.3-c,d)pyrel'l8
M.thyl81'\8 Chloriae
'-Methylphel'lOl
PIl'lt8chiorophll'lOi
PII'P'IIl'Ithr81'\8
PIIII'IOI
Pyr81'\8
TollI8I'I8
.........
AC8"I8pMhene
AI: 8"18 ph t lIy 11M
Ace t OM
Anthr8cene
"roclor-1ZS4
I,"ZOCI)8I'1thr8C8n8
Iel'lzoCI)pyr81'\8
Ilr'lZoCb)fluor'l'Ith8l'\e
1'''~OCI,h,I)~~l-
1'l'IZoCk)fluor8I'1thel'l8
Z-I"t81'101'18
'''tyl~zylphth8l.te
Chi orof 0...
Chry'lel'l8
'."-DOO
'." °00£
'."-ODT
Di°l'l-octylp"th818t.
Oibel'lZoCI.h)'l'Ithr.c81'\8
Dibe~zof"rln
1.'-Dichlo"~81'18
b;ICZ-Ethylhlayl)phthlllt.
FlllOr8ntl'lll'l8
F 1110 r81'\8
11'Id'I'IOC~.Z,3oc,d)pyrll'le
~rthyt- Chloride
'-Methyl p"el'lOl
N-n;trOSodiphel'lyllmil'll
Pe~tl=hlorophll'lOl
Ph,"ll'Ithrel'll
Ph el'lo I
Pyrel'le
Tol-
Il'IOr,ll'Iil:l:
-.........
C.ci!'I;\III
Copper
Lead
Il'IOr'I~;CS:
............
Clem; \III
Co~r
I rOl'\
Lud
M.n;.I'IeSt
Zinc
Or..nICI:
A'ltOM
',"zoic 8cid
Clrbon tetr8chloride
bil(Z-Ethylh.ayl)phthllltl
-------
Table 6
TOTAL II$[S ASSOCIATED WITH CURRENT LAND.USE
C8nc." 1 lilt Cenc." 1 I lit
Dye to ALL ChemicIl1 Dye to PCII
....................... .......................
Ar'I/Peth"'IY Ave"I,' ....1- AV'''I,' .... I lUll
"idel' "Irlh:
IngutiOtl of Sedillll'!'lt/50il 2.'E.06 , .OE-05 9.1,£.07 6.5E-06
O.MIIIL Absorption F"am
Sed i lllerlt/So I I , .ZE-06 6.3£-06 7.9(.07 5.41-06
a.MIIIL Absorption
F"am S~"flc' Wit." 1.U.09 2.1,£.09 '.0E-10 '.51-09
......... ......... ........- ........-
Totll Clnc." Iialt 4£.06 ZE-05 ZE-06 11.05
Golt tourl./.'tll~ 'r.l:
In,'Ition of Sediment/Soil '.0£-06 '-3£-05 '.3E-06 7.1£-06
O'MIII L Absorpt Ion
Fram S.ciment/Soll 1.n-06 7.3E-06 '.OE-06 5.91-06
......... ......... ......... .-.......
Toul Clnc.r lillt 61-06 2E-05 ZE-06 11-05
Nonclrcino"nlc IIIIt Nonclrclnoeenie 1111t
Dye to At L ChemicaLI Dye to PCII
....................... .......................
Ar.I/PathwIY 'v.rl;' "1J.llIUII Av.rl;' "U i nun
Middl, "Irll'l:
In;,st i 0tI of Sediment/Soi I 3.n-03 2_3E-02 2.9£-03 2.0E.02
D,rll\lll Absorption 'ram
Seod;""~t/Soi 1 2.'£-03 1. 6£ -02 2.1.E'03 , .6£-02
a'Mllal Abso~tio,",
'rom S~rflC' Wlt,r 1.6E-05 2.'E.05 , .2E .06 '.6E.06
......... ......... ......-.. .........
TouL HlZlrd I ~u c , c , c , c ,
CoL f Co~rs,/w'tllnd Ar.l:
In;utio,", of Sediment/Soi I 4.2E-03 2.2£-02 3.8E.03 2.1£-02
O,rll'.l Absorption
From Sediment/Soil 3.2£-03 , .8£.02 3.2E-03 ' .8E.02
......... ......... ......... .........
-------
98
Table 7
tOtAL IISeS ASSOCIATED WITH FUTU.E LAND.USE
C.rc.r II,k Carc.r 11,11:
Dw to 1.\1 Ch_icals Dill to PCls
..-.---.-.............. .......................
Arll/Pethw.y Anr';1 Mea i alii Ay.r';1 MeailUll
Middl. M.rSh:
J "I" t i on of SI'd hllent '.9£-06 2.DE-05 , .9£.06 '.3£-05
C'l"IIIIl Absorption
Frail SI'd;ment 2.3£-06 1_3E-05 , .61.06 , .11-05
......... ........- ......... .........
Total Carclr li,1I: 71-06 31.05 3E-06 2E-05
N~lrci"Otenlc li,1I: Nonc.rcl"O;lnlc lilll:
D~toAlt Chlfllic.ls Cue to Pels
....................... .......................
Ar../pethw.y Averl;1 Mea i lUll AYlr.;1 Mea i alii
"'idell. "'lrr1'l~
In8~ti~ of Sl'diment 7.'E-03 '.5E.02 S.n.03 3.9E-02
CIl"llllt Absorption
Frail SI'd;ment '.8E-03 3.3£-02 '.BE.03 3.3£-02
-........ ......... ......... .........
-------
99
The Seven Alternatives A~vance~ for Detaile~ Evaluation
o
Alternative #1. No action (retained as a baseline,
pursuant to the NCP).
Alternative 12b. Excavation of all remediation areas
with disposal of untreated sediments at Sullivan's
Ledge Disposal Area and ~etland restoration.
o
o
Alternative #5. Excavation of all remediation areas
with treatment of excavated materials by solvent
extraction, disposal of treated sediments in Middle
Marsh, and wetlands restoration with the treated
sediments, enhanced by organic, nutrient-rich clean
soil.
o
Alternative #6a. Excavation of all remediation areas
with treatment of excavated materials by
sOlidification/stabilization, disposal of the
solidified material at the Sullivan's Ledge Disposal
Area landfill, and wetlands restoration with clean,
organic soil.
o
Alternative 16b. Excavation of all remediation areas
with treatment of excavated materials by
solidification/stabilization, disposal of the.
solidified material at the golf course in a new solid
waste landfill, and wetlands restoration with clean,
organic soil.
o
Alternative #7a. Excavation of all remediation areas
with treatment of excavated materials by an on-site
incinerator, disposal of the ash material at the
Sullivan's Ledge Disposal Area landfill, and wetlands
restoration with clean, organic soil.
o
Alternative #7c. Excavation of all remediation areas
with treatment of excavated materials by an on-site
incinerator, disposal of the ash materials at an off-
site RCRA disposal facility, and wetlands restoration
with clean, organic soil.
-------
TABLE 9.
100
LOCATUII-SI'ECIFIC ARARS, CRITERIA, ADV ISOHIES, AIID CUIDAIICE FOR MIDDU MARSII
~dlum/Authorlty
Action to be Taken to Attain ARAR
Hequlrellent
fede.'al Regulatory
Ifequ "'ellM:n ts
Clean Water Act (CWA)
Guidelines for Disposal
of Dredged or Fill
Haterlal (]) U.S.C.
11]1111) (110 cn Part 2)0)
Slatement of Procedures
on floodplain HanaSe8ent
and Wetlands Protection
(110 efR 6, App. A)
fish and Wildlife
Coonllnat Ion Act
(Ib U.S.c. 1661 ~t seq.)
Status
Applicable
Applicable
Applicable
Requirement SynopsiS
No discharge of dredsed or fill material
'shall be pe"II1ltcd If there I:t a practicable
alternative to the discharge which would
have a less adverse Impact on the aquatic
ecosystem, so long as the alternative does
not have other significant adverse environ-
mental con:tequences. Appropriate and
practicable steps 8Ust be taken whIch will
minimize the pOlentlal adverse Impacts of
the discharge of the dredged material on the
aquatic ecosystcm.
federal aglmcles shall avoid, wherever
possible, lhe long and short term 18pacts
a:tsoclated with the destruction of wetlands
and the occupancy and modifications of
flOOdplains and wetlands development
wherel/e.' there I:t a practicable aJt':J'lIat he
In accordallce with EKecutlve Order:t 11990
alld 11988. The agency shall prolDOte the
preserl/Oltlon and restoratIon of floodplains
so lhat their natural and beneficial values
can be realhed. Any plans for actions In
wetlands or 1'100dplaills IIUSt be submitted
for publ ic rel/lew.
Under i('62, imy modlfloatlon of a body
of water requires consultation with the
U.S, fl:;h and WildUfe Se"l/lco:s, to develop
measurcs to prel/Cllt, ml ligate, or
compclI.:iate for losses to fish alld wlldUfe.
ThbJ rC'Iulre8Jcnt:; 1:1 addres:ted under CWA
Section 11011 ,'equlrellCnt:t.
Any actlvltle:t that Inl/oll/e the
d I:tcharge of drl:dge or fll1 Ilitle.'lal:t
In wetlands shal1 be conducted In a
manner ut Ulz Ing the alternat Ive
which would have the least adverse
Impact on the aquatic ecosystem and
the enl/I rOR8lent, pursuant to 110 CrR
12)0.10(a).
A 11 pract Icab I e lUeans w III be used to
81nl81ze harm to wetland:t and flooa-
plains. Wetland:t and floodplaln:t
disturbed by eNcal/atlon will be
restored to their original condl-
ttons. l'ellpO.'a.'y fill placcd In the
gol f Cour:te and wetland for acce:ts
roads iUld stagIng area wlil not hal/e
. :l18nl fleant llUpacl on lhe eKtellt of
(loJodlng. Cull/e.'t:t wil 1 be placed
U'kJer the acce:t:t .'oad:t to al10w for
UI~lverted piI:t:tagc of flood water:t.
O..rlnK the IdenlJflcatlon, :Jcrecnlng,
alld evaluation of alterlli,tlves, the
effects 011 wetlands al'C el/a luated.
If an altcrnatll/c mudll'lc:I a body of
"i.ter, I::I'A 8U:tt con:JuH the U.S. Fish
a..d Wildlife SCI'I/Ice. Whencl/er
1I..lIsl bl e, the remed la I alternative
d.::lc.'lbc:i IIcasu"C:i to p.'el/Cllt,
.,tlgate, or compcnsate for losses
-------
TAIILE 9 (Contlrwed).
101
LOCATIOI-SI'EClfIC AHAItS, CHIn:HIA, AUVISOHIES, AIID CUIDAIICE FOH "IDDU: "AHSII
Medium/Authority
Federal Relulatory
RequI re.-ents
(Continued)
Slatl' IIclSulatory
lie:4ui",,_nt:t
RCllu I re-nt
RCRA location Standards
(110 CFR 2611. 18)
ttazardous Waste Facility
Sit In8 Re8ulatlons
(990 eNR 1. 00 )
Hassachusetts Wetlands
1','ot..cUon Act,
(H. C.". 131, 1110)
(] 10 eNR 10.00)
Status
Relevant and
Appropriate
Relevant
and
Appropr late
Applicable
Hequ I relDellt Synops I s
this reBulatlon outlines the requlre.ents
for constructlns a RCRA facility on a
100-year floodplain.
These regulations outline the criteria for
the construction, operation, and aalntenance
of a new facUlty or Increase In an e.bUnS
facUlty for the storage, treat.-ent, or
disposal 01' hazardous waste.
These regulations are promulsated under
Wetlands I'rotectlon l.aws, which regulate
dredging, I'll illig, alterln8, or poUutln8
01' Inland wetlallds. Work within 100 feet of
a wetlalld Is ,'egulated under this require-
ment, The requirement 81so defines wetlands
bascLi 011 vegetaL Ion type and requl res that
effects on wctland:s be IIltlgatcd. Each
remcdial alte"'Iatlve will be evaluated for
Its abilIty to attain regulatory performance
staudards, IlicluLilng ..It 18at Ion of Impacted
wc II ,Ulds ,
Action to be Taken to Attain AHAR
A RCRA facility that Is located on a
lOO-year floodplains BUst be
desl8ned, con:structed, operated, alld
aalntalned to prevent washout of any
hazardous wa:ste by a 100-year flood,
unle:ss waste may be removed safely
bel'ore floodwater can reach the
facility or 110, adver:..: effeots on
hUlllan health and the environment
would re:sult If was~ut occurred.
No portion of the facility may be
loc.ted'wlthln a wt:tland or borderln8
a IIegctatud wetlalld, or within a 100-
)'ear flOOdplain, unles:s approved by
the :state:
If allerll3'tlvc:s Ilivoillc removln8,
fl1l1l1g, d,'cdgillg, or altering a 01::1'-
defillcd wet land, 0" COllductln8 work
within 100 I"e:et of a wetland, It must
be dellOlIst,..,ted that the modi floa-
tlons a,'e not slglllficalit to the
wetland 0" Lhat the: p,'opo:te:d NO,'k
will cOlltrlbute to the protection
01' the wethlld, Whencver pos:slble,
rt:medlal act lUllS wi 11 bt! conducted so
tta..t Impact:! to wdland.. will b~
-------
TAUI-E 9 (Continued).
102
LOCATION-SPECIFIC AUAI/S, CRITEUIA, ADVISORIES, AIIO CUIDAIICE fOR "1001.£ HAUSlJ
Medlu../Authorlty
Hequ I rc..ellt
State Nonresulatory
Requlre.ents to be
Conslde'ed
Endangered Wildlife
and Wild Plants Resula-
tions (321 CHR 8.00)
Massachusetts Wetlands
~rotectlon Prosraa
Pol Icy 90-2; Standards
and Procedures for
Deter.lnlna Adverse
I~pacts to Rare Species
Status
Requlremcnt Synopsis
Action to bc Takell to AU..ln 111111
If alternatlvcs Involvc Impacts to
the habitat of any Ilstcd species,
appropr late act Ions must be taken
durtnS re..edlatlon to mlt Isate or
.Inl.be I.pacts to the species and
Its critical hiabitat. Ildbitats of
any listed species will be Identified
prior to remediation.
IIabltats of rare species, as.
determined by the Massachusetts
Natural Hcrltage P,'ogra., will
be considered In the mitigation
plans.
APPlicable
1'hese rcgulatlons establ tshed Massachusetts'
list of threatened and endansered species and
specIes of special concern, The habitat of
any specie:; listed under this requlrcment
Is protected by the reSulatlons pr08Ulsated
under the HI Wet lands P,.otection Act.
To be
Considered
ThIs polley clarifies the rules resardln. rare
-------
TABLE 10.
103
ACTJOII-:JI'£CIPIC AIIAlia t'OR TIlE SELECTED RDCl::DY (EIICAVATIOII &liD DISPOSAL
SULLI VAllI'S L£IJG£ DISI'OOAL AREA)
AT
AHAR
Action to be Taken to Attain ARAR
Statu:l
Requirement Synop~I:I
National Pollution
Discharse EII.lnatlon
Syste. (NPOES)
(~O CfR 122.125)
Tollc POllutant Effluent
Standards (~O CFR 129)
Ha:llsachusetts Surface
w..tt!r Quail ty Standards
31" CMR ".00
Appllcable
Applicable
Applicable
Resulates the dl~charge of water Into
publtc surface waters. AmonS other thlnss,
IlaJor requirements are:
Use of best available tectulology (BAT)
ecoOOllI~lly achievable 1:1 required to
control tOile and non-conventional pollu-
tants. Use of best conventional pollutant
control technology (BCT) 1:1 required to
control conventional pollutants. Tech-
nology-based limitations may be deter.lned
on a case-by-ca~c basis.
Appl1cable federdUy appl"ovcd State water
quality stalll.lard:l ..u~t are complied with.
These standards may be In addition to or
IIIOre stringent thafl other Federal standards
under the CWA.
Rcsulates the dlscharse of the follow InS
pollutants: aldrin/dieldrin, PDT, endrln,
to.aphene, benzidine, and PClls.
These standards designate the IIOst sensitive
use:l for which the var.lous waters of the
COIUbOnwealth shall be enhanced, llalntalned
and protected. Hlnlmum water quality
criteria requlrt!d Lu :lustal.. the deslsnated
use:!! are estllbll:Jhcd. Fcdt!l"al AWQC art! to be
con:llldt!red In dctcl'Dllnlng cfflut!nt dhcharse
11.1 h. Where rt!con'lIt!m.lcd 1IIIIt:l are lIot
available, slte-~Jleclflc limits shall be
developed. Any on-~ Ite water treatllent and
dl~charge Is :lubJect to tht!~e requlremcnts.
Discharsed waters will be lIonltored for the
required pollutants and standard~ will be
.et.
All discharS8 wattlr:l will be IIOnltored for
the resulated pollutants and wIll meet
standard:l.
Water fro. the dewatering proce:ll~ will be
discharged dlr.cl1y to the UllllalUed :IItream.
If this water doc:!! not meet state standards,
It will be tr.at~d prior to discharge.
Effluent 11.llat Ions for water discharges
will be established so that such dlschargt!s
~hall flat result III a violation of state
-------
TABU: 10 (ContInued).
104
ACTICII-SPt:CIFIC ARAR. fOR 'TII£ SEI.£CTED RDfEDr (EICAVATI08I "'D DISPOSAL AT
Stl.LlVAIl'S I.£DCE DISI'OOAL AII£A)
~NAII
Clean Water Act I 40~
('10 en 230)
Procedure~ on floodplain
Hanagelllent and Wetlands
Protection (40 efR 6, App. A)
""':i:iilchu:ictl:i Wctlanda
I'rotectton Act
I". G .l, 1]1 I 40)
(JIO CHN 10.00)
Status
Applicable
Applicable
Appll~ble
RequIrement Synop~ls
No discharge of dredged or fill material
ahall be permitted Ir there Is a practicable
alternative to the discharge which would
have a less adverae lapact to the aquatic
ecosy~te., so long as the alternative does
not have other Slgnlrlcant adverse envlron-
.ental consequencea. Appropriate and
practicable steps aust be taken which will
.lnlml2e the potential adverse l8pacts or
the dbcharge of the dredsed 8aterlal on
the aquatic ecosystem.
federal agencies ahall avoid, wherever
PO~slble, the long and short ter. Impacts
aaaoclated with the destruction of wetlanda
and the OCcuj)ilncy and IIOdl fl catlona of
floodpla Ina and wetlands developalCnt
wherever there h a practicable alternative
In accordance with £xecutlve Orders 11990
and 11988. The agency llhaJi pr080te the
pre~ervatlon anll rC:itoration of fJoodplalns
so that their natural and bcneflclal values
can be realhed. Any plan~ for actlona In
wetlanda or fJoollplalna lIust be aubmltted
for PUblIc review.
The dredgIng, fillIng, allcrlng, or
polluting of Inlanll wetlanlla and work
wllhln 100 fed of a well a nil h rcgulated.
Each remcdlal alternative will be evaluated
'or Ita abilIty to attain regulatory perfor-
lllance atandarlla, Including mitigation of
I"j)ilcted wetlanda.
Action to be Taken to attaIn ARAN
Any activIties that Involve the dbcharge of
dredge or fj 11 ...ter lab In wetlanda ahall be
COnducted In a 8anner utll121ng the
alternative which would have the least
adverse lapact on the aquatic eco~yate. and
the envlroll8ent, pursuant to ~O efN
1230.10(a), and any excavated area~ to be
filled shall be filled with clean materials
fro. off-site, In aocordance wIth '10 efN
1230.
Thl. alternative will take Into con:> Idc,'at Ion
this state8ent. All pracllcab Ie Dleana 101 111
be "sed to .lnl.l:u. tJa,". to wo:tlallds allll
floollplalns. Wetlah.Ja and floOliplalna
disturbed by e.cavallon will be '"e:ilol't~1I to
their' original condla.lona. TCIOl'o"al')' fill
plac8Id In the golf course and wellaruJ for
access roads and IItaglng area wlllllUl h..vlt
a sIgnificant blJulCl on the cltCllt of flood-
Ing. Culverts will be placed unllc,' a.he
access road~1 to hI low for unlllvc,'lcd pa~a-
age of flool1 watur~.
Wetlanda dl:lturbc.. by excavallon will bc
restQI'ed to orlgh'itl condltlon:i. All JlI'dctl-
cable .ean~ will III: u:icd to mlnlmi:tc wetlalld
dlsturballce. kcmcdlal actlvltlc:I wIll be
selectell based all lhe ability to Dlll1l.bl:ld
-------
TiDLE 10 (Continued).
105
ACTlmi-SPECIFIC ARANs FOR TIlE SELECTED RDtEDY (£ICAVATIOII 1110 OISl'OSAL AT
SULLIVAII'S LEDe£ DISI'OSAL AIII::I)
IIIAII
Ictlon to be Taken to Atta In AIIAII
Status
Requirement Synop~ls
Ha~~achu~~tts Enddnsered
WlltHlfe and WUd 1'1ant:l
Resulallons
(J21 CMR 8.00)
Massachusctts Certification
for Ored81n8, Ored8ed
Hat~rlal OI~po~l, al~
Flllln8 In Waters
(JIll CMH 9.00)
FI:>h all(J Wildlife
Coordination Act
(16 U.S.C. 166 et seq.)
TSCA, Subpart D, Stora8e
and DhJ>o:ial
(110 CPR 161.60, 761.65,
761. 79)
Applicable
App1Jcable
Applicable
These re8ulatlons established Hassachusetts'
l1st of threatened and endalliered speclu and
species of special concern. The habitat of
of any species 11~ted under this requlreaent
Is protected by the re8ulatlons pr08ul8ated
under the Hassachusetts Wetlands Protection
Act.
The substantive portions of these resulatlons
establish criteria and standards for the
dredllnl, handBnl and dlsJ>U~al of fill
aaterlal and dredled material.
Any 8Odlflcatlon of a body of water
requires prior consultation with the
U.S. FWS to develop -asures to prevent,
.ltl8ate, or c08pensate for losses to
fish' wlldl1fe.
Applicable If All dred8.d materials that contain I'CBs at
PCB concen- concentrat Ions of 50 ppa or sreater shall
tratlons are be dl:tposud of In an Incinerator or In a
>50 Pplli chelllical waste landf I 11 or, upon appUcatlon,
Rdevant and u~ln8 a I1hposal Dldhod to be approved by the
al'l'roprlate If EI'A He&IO/l In whIch the I'CUs are located.
I'ClI concen- Oo-sl to :storage fac 11 it I es for !'CUS shall
tratlolls are .eet, at III .InllllU18, the foUowlng cl'lter la:
(50 J>pIII
Adequate roof alld wal Is to prevent rain
Adequatu floor with continuous curbing
No opel,lng~ thal would per.1 t liquids
to flow from curbed area
If the alternative Involve~ I"pact~ to the
habitat of any ll:lted species, apprup.'14Le
actions IllUst be taken during rellledialion to
IIIltlgate or IIIInlllllz8 IlIIpacts to the ~pecles
and Us critical habUat. Habitats uf any
listed species will be Identified prior to
rellledlation.
£.cavation, fill lng, and cflsposal operations
will lIIeet substantive criteria and standards
In these r"ell"laltons. The I"t:med la I altel'lla-
tlve will tit: des lined to ensure the
aalntellance or allalnment of the HA WatlH'
Quality Standards In the affected waters and
to .Inlmlze the Impllct on the envll'onment.
Prior to Clcavattoll, EPA will cOllsult with
U.S. FWS. This ehernatlve Includlls measures
to prevent, .1 tli. ,e, or cOlllpensate for los:.es
to fish and wildlife.
Disposal of solla/sedlaents under the cap at
the DIspo~al Area .wlll comply with chemical
W8:.te landfl1l re'lul rellent:. e.cept requl re-
_nts waived In U... 1100 for the Hrst Opllrable
Unit. T"~se relulatlons will be cun~hlered by
U,S. EI'A lIegion I In the :lClecUpn of this
alternative and h. the design 01' storage
faclllUe~. Sol 111 dcbrl:J, excluding Lree:l
and bushU:I, ahall be decontamll~tlld prior to
off-sllu transJ>UI't or off-:ille dlsJ>U~al In
accordance with ~O CfH 161.19i sLorage
facUltle:. shall b.: designed con:lt:lLent wlt.h
-------
T&il1.[ 10 (Continued).
106
ACTIOI-SI'£CIFIC AIlAifs FOil 111t: SEI.£CTED Ifacmy (EICAVATIOII AMD DISI'OOAL AT
SUlLJVAIl'S U::DCE DISl'USAL AIfEA)
~AH
Status
TSCA, Subpart 0, Storage
alld Dl3posal
(/f0 cn 161.60, 161.65,.
161.19) (Continued)
Action to be Taken to AU.. III AHAH
Has:Jachusetts Supplemental
Requlreaents for Hazardous
Waste Hanageqent facilities
nil! CHH 0.00)
Hassachus~tts Hazardous
Waste Regulations
n 10 CHIf 30.000)
Relevant &
Appropriate
Applicable
1 f sedlaents/
:soils are
defined a:t
hazardous
waste under
Hass. law;
rei OIwant and
appropr late
If secU.ents/
soils are
s 1.lIar to
hazarduus
wastes
Rdqulreaent Synop:tl:t
Not located at a :Jlte that Is below the
IOO-year flood water elevation
Water treatment units which are exe.pted
fr08 H.C.L.c.2IC and which treat, store, or
dispose of hazardous wastes generated at
the :ia88 SHd are resulated to ensure that
such activities are conducted In a manner
Which protects public health and safety and
the em v I rUCllllen t .
Resulate the seneratlon, storage, COlleotlon,
transport, treatment, disposal, use, reuse,
and recycling of hazardous waste In
Ha:t:tachusetts. Th.e c'egulations pruv Ide
procedural standards for the following:
senerators (310 CHH 30.300), seneral
lfl.lnagclllent standac'ds for a II fuc III ties
(301 CHH 30.510), cunttllsency plan, emergency
procedures, prepiu'ednt!ss, and pc'event 1011
(310 CHH 30.520), IIIdnlfc.:It syste8 010 CHH
30.530), closure alld Post-closure (310 CHH
]0.580), landfill rcqulc'cllltmts (]Ol CHH
30.620), protection (]IO CHH ]0.660), use
and IIIdllas"..ent of COllt.. I ners (] 10 CHH 30.680),
and facUlLy locat lUll 9t""d,,rds and land
disposal re:Jtrlctions (J 10 CH" 30.100).
If treatment of sedlment/sotl dewaterlns
water Is necessary, all proce:ts will coaply
with Hassachusetts requirements resardlns
location, technical standards, closure ac~
POst-closure, and manageaent stahdards.
Based on known h,formation, E/'A expects that
the sedlaent/soll are not hazardous waste
under Hassachu.etts law. lIowever, I I' the
:Jedlaellt/soU Is des Ignated h":lac'dous "".:Ite
under Hassachusetts law, all processes
Invo!v InS the contaminated sedlment/soll w1l1
be conducted In IIccordunce with state hazard-
-------
TABL£ 10 (Continued).
107
ACTIOI-SI'£CIPIC AHaNs FOH TIlE St:1£CI'm IIEJt£Dy (ElcavaTIOII AltO OISi'OOAL AT
StU.1 vail'S U::JJGE OISl'OSAL AH£a)
AHAIt
Action to be Taken to AUa In AHAH
Status
H.:qulrement Synopsl~
RCRA I land Dlspo:;al
Regulations !
(~O CfR 268, Subpart C)
Clean All' Act (CAA)
~O CI'H 50,6
Hassachusetts ambient
All' Quality Standards
and Hassachusetts All'
Pollution Control Regula-
tions (]O! CHH 1.00)
Federal Noise Control Act
(~O CFR 204, 205, 211)
TOlic Substance Control
Act (TSCA), Sub~art G,
PCB Spill Clean-up ~ollcy
(~O Cflt I 16.. 1~0-1)5)
Applicable If
the sedlmentsl
soils are
character-
istic of
hazardous
waste under
federal law
Applicable
Applicable
Relevant'
Appropriate
"0 Be
Considered
Prohibits the disposal of HCRA hazardous
waste In the land unless treatment standards
are met or a treatability variance Is
oblalned.
The mallmu8 primary and secondary 2~-hr,
concentration for particulate emissions
fro. site excavation actl~ltles must be
maintained below 150 )g/m I 24-hour
average for part Iculates hav Ilig a mean
diameter of 10 micrometers or less. The
annual standard Is 50 )g/m), annual
arlllUlletlc mean.
The applicable portions of these regulations
prohibit burning or e18bsloliS of dust which
causes or contributes to a condition ot
all' pollution.
Regulates construction and transportation
equlp.ent noise, ~rocess equipment' noise
levels, and noise levels at the property
boulldar I.:s of the ~1'OJ.:ct.
Sets cleanup levels for PC" spills of
50 PIJIII or sreater at 10 ~IJIII for non-
restricted access areas, and 25 Pp8 for
re:ttl'lcted access areas.
Baaed on known Information, EPA elpt!cts that
the sedl.ent/soll Is not hazardous waste.
I~wever, If the sediment/soil Is hazardous
waste due to the pr.:sence ot .etals, It will
be solidified to render It non-hazardous or,
alternatively, to meet the t,'eatability
variance requlr.:ments In the' land db~o:sal
requirements.
The ambient all' will be continuously
8Onltored to ensure compliance with feneral
regulations.
Control measures w III be Inlplemcnt.:d to ellSUl'e
C08pl1ance wlt.h st.ilte regulal1olls.
Site noise level, will be In accordance
with federal rt:qulre8ents.
Cleanup levels e~tabllshed In Chapter 511
-------
TABU: 10 (Continued).
108
ACTION-SPECIFIC AllARa FOR TIlE SELECTED RatED! (EICAVATIOII AND DISI'OSAL AT
SII.LI VAil'S LEIJCE DISi'OSAL AHEA)
AI/All
Status
Interl. Sedl.ent
Quality Criteria
To Be
Considered
Action to be Taken to AUa In AllAH
Massachusetts Allowable
Aablent air LI.lts - annual
(AaLs) and 2'-hour (TEla)
To Be
Considered
Culdance on Remedial
Actions for Superfund Site.
wi th PCB Conta.inatton
To Be
Considered
ErA Interllll Poltcy for
Plllllnlni and Il8jJlelltmtlnl
CEIICLA Response Actions.
Proposed Hule, 50 fR -5933
(November 5, 1985)
To Be
Considered
Requirement Synopsis
These criteria were developed by U.S. EPA
for certain hYdrophobic orKanlc C08pounds,
Includlnl PCBs, to protect benthic orlanlaas.
The criteria for PCDs Is 19.5 )1 rCD/1 carbon.
These Iuldances are to be considered In
evaluatlna whether a condition of air
pollution ~.Ists. The TEL for PCB Is
0.003 )1/. 'and the AAL Is 0.005 )1,.3.
Describes various scenarios and consider-
ations pertinent to deter_lnlnl the
appropriate level of PCUs that can be left
In each conta.lnuted 8edla to achieve
protection of human health and the
environlllent.
Discusses the need to cons Ider treatllent.
recycltnl, and reuse before off:! I te land
disposal Is used. Prohibits use of a IICHA
facility for offslte llanalellent of Superfund
hazardous substances If I t has s linin cant
IICHA violations.
The cleanup levels developed In Chapter 6 of
the fS are consistent with Inter I. criteria.
Massachusetts air 11.lts and exposure levels
will be considered In the evaluation of
e.lsslons ~nltorlna results.
ThI:J luldance 11111 be considered In dl'tcrmln-
Inl the appropriate level of I'CUs that wll1
be left In the sediment/soil. HaliaKellent of
I'CB-conta.lnated residuals will be des lIned
In accordance with the luld
-------
T&8L£ 11.
109
«
ACTlmi-SPECIPIC AHAHII FOB 111£ C08r1'UIGElICr 1IDtE0r (SOLVENT ElTHACTlmI)
AHAII
Action to be Taken to Allilln AIIAII
Status
Requirement Synop~ls
~lIonal f'ollutlon
01 ~cha"ge EII.lllat Jon
System ("POES)
C~O efR 122. 125)
TOKlc Pollutant Effluent
Standards (_0 crR 129)
Hassachusetts Surface
Water Quality Standards
31- CHR ",00
Applicable
AppUoable
AppUoable
Hegulates the dl:icharge of water Into
public surface waters. AIIIOlIg other things,
aaJor requirements are:
Use of best available technology (BAT)
econoalcally achJevable Js requJred to
control tOKlc and non-conventional pollu-
tant. Use of best conventional pollutant
control technology (OLf) Is required to
control convent 10lla I pollutants. Tech-
nology-based limitations aay be deter.lned
on a case-by-case basis.
Applicable t'edt!I'aUy appl'oved State water
quality standards must be compiled with.
These standards may be In addition to or
IIOre stringent than othe.' federal standards
under the CWA.
Resulates the dl:icharge of the followlnS
pollutants: aldrJn/dJeldrln, 001. endrln,
toKaphene. ben~Jdlne. and PCBs.
These standards designate the IIIOSt sensitive
uses for which the various waters of the
C08IIIOnweal th sha II be enhanced. aa Inta Ined
and protected. HIIIIIP:.JIII water quality
c.'llel'lea n:qu 11't!d tu :ou:>taln Un: de:llgllated
uses are dstlllJIIshcd. federal AWQC are to be
considered In dett!I'aolnlng el'fluent dlscharse
11111 ts. Where recoulaellth:d limits are not
available, slte-~flcclflc Ilmils shall be
developed. Anyon-site water treatment and
d1:lcharge 13 subject to these requirements.
Discharged waters will be monltol'ed 1'01' the
requ Jred pollutants and :itandoil'd:l will lJe
I18t.
AU dlscharse wcaters wJlI be monitored for
the regulated pollutants Pnd will meet
standards.
Water from the treatment process which will
be dbcharged directly to the unnamed stren
Includes water froa :IOJI dewatering. If
this water does not aeet state standards,
II wUI IMI treat"d III'Jor to dl:ieh...-se.
Effl uent 11111 tat lOlls for water .U scharges
will be estabHshed :>0 that :luch dlscharles
shall not rcssulL In a violation of state
-------
TABU II (Continued).
110
ACTIOI-SP£CIPIC AIIARa fOR 111£ awrUICDlCV IID£DV (SOI.'£IIT EITltACTIOI)
AllAH
Status
Clean W~ter Act 1 1t01t
(ltO cn 2]0)
Applicable
Action to be Taken to AttaIn AHAH
Procedures on floodplain
Hianagullcnt II,KJ Wet landa
Prot ec tI on
(ltO CfN 6, App. A)
AppUcable
Ha~~actw~utt~ WuLland:!i
Protection Aut
(e.L.C. 131 t 110)
(]IO CHN 10.(0)
Applicable
Requlreaent Synopala
No dl3charge of dredged or fIll materIal
shall be per.ltted If there la a practicable
alternative to the dl3charge which would
have a less adverae I.pact to the aquatlo
eooayate., ao long aa the alternative doea
not have other ~Ignlflcant adverse envlron-
8ental conaequence~. Appropriate and
practicable ~tep~ mu~t be taken which will
.Inl.lze the potential adverse I.paota of
the discharge of the dredged 8aterlal on
the aquatic eco~ystc..
Federal agencle:!i 3ha11 avoid, wherever
posalble, the lon8 and short term I.pacts
8330clated with the destruction of wetlanda
and the OCcupancy and 8OdlflcaUons of
floodplains and wutlands develoJ18ent
wherever there 19 a practicable alternative
In accordance wi th E"ucut I ve Orders 11990
and 11968. The agency ~haJI promote the
pre~e,'vatlon and "e~toratlon of floodpJaJns
30 that their naturaJ and beneficial values
can be realized. Any plan3 for actions In
wetlalld~ or floodpla In3 8IU~t be subillUed
for PUblic review.
nle dr~lIlng, fllli/lg, altednll, or
polluting of Inland wetland~ and work
within 100 feet 01' a wetland Is regulated.
Each remedla I alte,."atlve will be evaluated
for Ita ability to attain. regulatory perfor-
8ance ~tandards. Including .lllgaLton of
lapacted wetlands.
Any actJvltles that Involve the discharge of
dredge or fJ 11 llater lab In wetlands shall be
COnducted In II Manner utlll~lng the
alternative which would have the least
adverse I.pact on the aquatic eQo~yste. and
the envlronaent, pur3uant to /to CFR
12]0.10(a), and any excavated areas to be
filled shall be filled with adequately
treated and appropriately reCOnditioned
8aterla1s.
1bb alternative wUI take Into con~lderat1on
this stateaunt. All practicable mean3 will
be uaed to .Inl.lze harm to wetlands and
floodplaln3. Wet1all"~ alld "'000pl..1113
disturbed by e.cavatlon will be restored to
their original conditions. Tellpo,'ary flU
placed In the go I f CO",,'se and wutta/ld for
access road~ and staging area wlH not have
a algnlflcant I.pact on the e..tent of flOOd-
Ing. Culverts will be placed under the
acceaa roads to allow for undlverted pa3s-
age of flooo wate,'s.
Wutland3 dbturbed by e..cavatlon will be
restored to original conditions. All practi-
cable 8eans will be u~ud to .Inllllh:e wetland
disturbance. RClllUdlal actlvlll;:~ will be
aelected based on the Mbility to 81nllll12e
-------
TABU: 11 (Continued).
III
ACTlmI-St'ECIFIC aRAlia fOil mE OOII1'IIICEIICY IlEt£OY (SOLVDIT UTaACTlmI)
AHAR
Action to be Taken to Attain AHAH
Status
Requirement Synop:sls
H.a:l::laehu:leU:s Elldangered
Wildlife and Wild Plants
Regulations
(]21 CHH 8.00)
Mas::lachuseU:I Certification
for Oredllnl, Dredled
Material Disposal, and
Filling in Waters
01" CHII 9.00)
Fbh and Wildlife
Cool'dlnatlon Act
(16 U.S.C. 166 et seq.)
TSCA, Subpal.t 0, Sto,'alle
and Disposal
(110 efR 161.60, 161.65,
16 I. 19)
Applicable
Applicable
Applicable
Applicable If
PCB concen-
trations are
>50 ppll;
relevant and
appropriate
I f PCB con-
centrations
The:le regulatlon:l e:stabll:1hed Has»achu:letts'
11 st of threatened and endangered spec les and
species of special ooncern. The habitat of
any species II:lted under this requlre.ent Is
protected by the regulations pr08UIgated
under the Massachusetts Wetlands Protection
Act.
The :sub:ltantlve portions of the:le regulations
establish criteria and standards for dredging,
handling, and dl:sposal of dl fferent classes
of fill material ar~ dredged aaterlal.
Any BIOdl flcat ion of a body of water
requires prior consultation with the
U.S. fWS to develop measures to prevent,
.1 LIgate, or compen:sate for los:le:l to
fish & wildlife.
All dredsed materlal:l that contain PCBa at
concentrations of 50 ppm or greater shall
be disposed of in an Inchlel"ator or In a
chemical waste landfill 01', upon application,
using a disposal method to be approved by the
EI'A Heglon In wh ieh the I'CU:I ar-e located.
on-site storage facilities for PCOs shall
meet, at a miniPlum, the following cl'lterla:
Adequate roof and walls to prevent rain
e. Adequate floor with conLinuous curbing
If the alternative Involves Impacts to the
habitat of any listed species, appropriate
actions 8USt be taken durlns remediation to
.Itlgate or .Inlml~e Impacts to the species
and Its critical habitat. Habitats of any
listed species will be Identified prior to
to remediation.
Excavation, fll11l1g, and dlspo:lal operations
will lIeet substantive criteria, and standards
In these regulations. The remedial aHerna-
tlve will be de:llgned to en:lure the
malntenanoe or attainment of the HA W3ter
Quality Stalldard:l In the affected Wiaters and
to mlnh.la... the II.pao:t on the environment.
Prior to exoilvatlon, EI'A will cc.n:lult with
U.S. FWS. Thl8 alternative Includes .easures
to prevent, III tlgoite, or cOl1lpensate for lo:sses
to fbh alld wlldllflL
These rellulatlona will be considered by U.S.
EPA Region I In the design of storage
facilities. Solid debris, excluding trees and
bushes, shall be decuntalllinoited prlur to off-
site transport or off-site disposal In
accordancQ with 110 e,," 161. '/9 j :rtorage
facilltics shall be dC:llgllcd con:ll:rtellt with
110 CFII 161.65(b)(I)(1), (il) an~ (ili).
I'C8-conc~lItratclt wa:rtc 011::1 fl'um Lhe :solvcnt
eltractlon ~roce8a will be dl:rposcd of In
-------
TABLE 11 (Continued).
112
ACTIOU-SI'ECIFIC AHAHa roo nlE COIITlliGEllCr HDe:DY (SOLVDlT EIT"ACTIOU)
AHA"
Status
Hequlr~ment SynoPSI~
TSCA, Subpart 0, Storase
and Dlspo:sal
(40 CFR 161.60, 161.65,
(161.19) (Continued)
Action to be Taken to Attd In AHA"
Has~achusett~ Supple8ental
Requlrc8ents for Hazardous
Waste Hanase.ent Facilities
nl4 CHH 8.00)
Massachusetts llazardous
Wa,te Hegulatlons
(JIO CHIt 30.000)
Relevant'
Appropriate
Applicable to
PCB-cOlicen-
trated waste
011 j applic-
able If sed-
8ent/solh
ara defln~ .
.s hazard-
ou~ wa~t~3j
rtllevant and
.'Ipropr la te
I f sediments/
soil=- are
IU-H..r to
ha:tardou3
wa3tea
110 upenlngs that would permit liquids
to flow fr08 curbed area
lIot located at a site that Is below the
100-year flood water elevation
Water treatment uhlts which are exempted
tr08 H.G.L.c.2IC and which treat, store, or
dispose of hazardous wastes senerated at
the sallie s Jt.a are reKu la ted to en:.ure that
3uch actlvltle3 are COI~ucted In a aanner
Which protects public health and safety and
lhe env I ronmunt.
Regulate the Keneratlon, storase, cOlleotlon,
transport, treatment, dhpo:lal, use, reuse,
and recycling of hazardous waste In
Ha~sachu:lelt3. The reKulatlon3 provide
procedural standard~ for the fOllowlns:
generator~ (]IO CHII 30.300), general
mallaGeOlcnl ~tiUldard~ for all facHllle:.
(]IO CHH 30.5\0), cOlltlllKellcy plan,
emerK~ncy proc~dures, prepal'edn~s:., and
prevcntlon (]IO CHo 30.530), closure and
post-closure (JIO CHo JO,580), landfill
rcqu Ircmenls (] 10 CHo 30.(20), gl'oundwater
protection (JIO CHo ]0.6(0), u:le al~
aanagcment o/' contalner~ OW CHo ]0.680),
and facility location :ilillldards and land
dlspo~al re:ltrlctlons (]IO CHo 30,100).
It treatment of sedl-ent/soll dewalerll~
water Is necessary, all process will comply
with Hllsachusett. requlre.ents regard InS
locatloo, lechnloil standard:., clo:lura and
post-olosure, and ..naKc~nt standard:J.
Based 011 known II,foraatton, [PA expect:J that
the sedlillent/lioll Iu'e not ha:tardou:s waste
under Ha3sachusu,ts law. llowever, If the
sedl....t/:.oH h deslKnated hazardous wa~te
under ~8~achubetts law, all processes
Invoh Inl the c...nt...natcd sed IOlent/:>o II
will be c.....ductUd In accordance with state
hazardou8 wa:.te r""ulatlolls. All proce:J3es
Involv 1011 the I'CU-culicellll'ated wa:ite 011 wll J
be conlJuCled III aouurdallct! with th~~e regula-
-------
TlBL£ II (Continued).
113
ICTIOII-SI'£CIPIC AIIans FON 111£ COiII'UIG£IICr IID£Dr (SOLVDlT £XTnaCTU:W)
AIfAH
Acllon to be Takcli to Alta In AIfAH
Status
Requirement Synopsis
RCIIA, lalld 0 I:iPO:la I
Hcgulallon:.
(~O efR 268, Subpart C)
Clean AII' Act (CAA)
qO CfR 50.6
Hu~~achu~etl:. ambIent
AII' Quality Standards
and Hds:.achu~etts All'
Pollution COlltrol Resula-
lIolis (301 CHII 6.00-1.(0)
fc~cral NQI~e Control Act
(qO CFn 20q, 205, 211)
10x..: Subst..flce Control
Act ('I"SCAI. ~bpart G,
PCB 51'111 Clcan-up Policy
(qO efn , 161,120-135)
Applicable If
sed l.ents/
50il:. are
character-
Istic
of hazard-
ous waste
Applicable
Applicable
Ho:levallt ,
Appl'opl'late
10 lie
Cuu:.ldered
Prohibit:. the dl:.po:.al of HeHA ha~ardous
wast!! In the land unles:. treatment stalldards
are IDCt or a treatability variance Is
obta Ined.
The ...11110111 pl'lOI4ry and secondary 2Q-hr.
concentration fur pal" i, wlate ellb:.lons
fr08 site excavation actl~ltles 8Ust be
aalntalned below 150 )s/m , 2Q-hour
average for particulate:. havlns a mean
dla.eter of 10 IIIlcrometers]or less. The
annual stalldard 15 50 )g/8 , annual
ar I thmetl c lDeall.
All construction and treatlllClit activities
will utlll~e 8e:.t Available Control
Technology III order to prevellt cantailinant
trall~fer between other media and all'.
Hassaohusetts AAls and TEls are used In
detenunlllg coolllilance with these I'esula-
tlons. Burn Ing or eml sslolls of dust
which causes or contrlbutcs to a condition
of all' pollutloll al'c pl'ohlblted.
negulates COIl:itl'Uct 1011 alld tl'ansportation
cLjull'lIlImt lIulse, procc~s equlpllent , noise
level:!!, alld noise levels at the property
tK,,,ndarlcs of the project.
St:ts cleallup level:J for PCU spills of
50 p..... or greater at 10 PfJII for noll-
re~trlotod access areas, and 25 p~ for
re~trloted access areas.
Ba:!!ed an known Infol'matlon, EI'A expects that
the sediment/soil Is not ha~ardous waste.
llawever, If the sedlmellt/soll Is ha~arduus
waste due to the presence of metals, It will
be solid Ifled to render It nOIl-hazardou~ or,
alternatively, to meet the treatability
variance requirements In the lalld dhpo:.al
requlremcllt:..
The ambient all' will be continuously
monitored to ensure compliance with federal
resulatlons.
The aablent all' will be eontilluously
IIOnlto.'od alld control 8Iea:.ures shall be
IlIpleJlclltad to ell:.ure C08lpll,,"cII with
state regulations.
Site 111)1.. level:. will be In accordance
with ".darlal requll'cmt!IIL:t.
Cleanup levills establl:thed III Chapter Six
-------
TABL2 II (Continued).
114
Requirement Synop~ls
ACTIOII-SPECI'IC &RARe POR 111£ COIITU.CEIICY IEN!:Df (SOLUQIT EITRACTIOII)
AllAR
Status
Interim Sediment
Quality Criteria
To be
Considered
Actton to be. Talu:II. to Attain AIIAII
Hassachusetts Allowable To Be
Aablent Air LI.lts - annual Conaldered
(AALa) and 2Q-hour (TEla)
Guidance on Heaedlal To Be
Actions for Superfund Sitea Conaldered
wIth PCD Contamination
EPA Interl. Polley for
Planning and Imple.entlna
CENCLA Res~nse Acttona.
Proposed Rule, 50 FR -593]
(November 5, 1985)
To Be
Considered
These criteria were developed by U.S. EPA
for certain hydrophobic organic C08pounds,
InCluding PCDs, to protect benthic oraanl....
The criterIa for PCBs Is 19.5 )8 PCD/8 carbon.
These guidances are to be considered In
evaluating whether a condition of air
pollution ~Xlsts. The TEL for PCD IS]
0.003 )g/m and the AAL Is 0.005 )g/. .
Describes various scenarios and con~lder-
atlons pertinent to determining the
appropriate level of PCDs that can be left
In each contaminated .edla to achieve
protection of human health a/ld the
environment.
Discusses the need to consider treataent,
recycling, and reuse before offslte tand
disposal Is u~cd. Prohlblt~ use of a HCRA
faclll ty for oftsl te .a/lage.ent of Superfund
ha~ardous sub~tances If It ha~ significant
HCRA v lolatloll:l.
The cleanup level~ developed In Chapter 6 of
the FS are consistent with Inter 1. criteria.
Massachusetta air U8ttS and e.pO~ure levels
will be considered In the evaluation of
..Isslons 8Onltorlna results.
this ,~Idance will be considered In determln-
In8 th~ appropriate level of PCDs that will
be left In the sedIment/soIl. Hanaaement of
PCB-contaminated residuals will be designed
In accurdance with the guidance.
this polIcy will be considered In the
treat.ent of thll PCD-contamlnated waste
-------
APPENDIX A
RESPONSIVENESS SUMMARY
SULLIVAN'S LEDGE SITE
-------
United States
Environmental Protection Agency
Region I
s
U PER FUN D
\')
Responsiveness summary
Sullivan'. Ledge Sit.
Middle Marsh Operable Unit
New Bedford, Massachusett.
-------
Table of Content.
Preface. .
. . . . . . . . . . .
. . . . . . . . .
. . . .
I.
Overview of Reme4ial Al~erna~i.e. CoD.i4ere4 iD ~be
Feasibility Stu4y, iDclu4iDg ~be Preferre4 Alternati.e
aD4 Contingency Alternati.e . . . . . . . . . . . . . . . .
II.
Site History and Background on Communi~y In.ol.emen~
and CoDC.rD. ............... . . . . .
III. Summary of Comment. Recei.e4 During ~be Public
Commen~ Peri04 an4 EPA Response. ~o ~bo.e Commen~.
. . . .
Part A - Community Comment.
. . . . . . . . . . . . .
Part B - State Comments
. . . . . . . . . . . . . . .
Part C - Potentially Responsible Party Comments
IV.
Remaining Concern.
. . . . . . . . . . . . . . . . .
A~tacb.men~ A
Formal Community Relations Activities Conducted To Date at
the Middle Marsh Operable Unit - Sullivan'. Ledge Superfund
Site
Attachmen~ .
Transcript of the July 26, 1991 Informal Public Hearing
1
3
6
9
10
38
40
-------
Preface
The U. S. Environmental Protection Agency (ZPA) held a 62-day
pUblic Comment period from Kay 30, 1991 to July 31, 1990 to provide
an opportunity ~or intere.ted partie. to comment on the Remedial
Inve.tigation (RI), draft Fea.ibility Study (FS), and the Hay 1991
Kiddle Kar.h Operable Unit, Hew Bedford, Ka.sachu.etta.
Propo.ed Plan prepared for the Sullivan's Ledge Superfund Site,
FS examines and evaluates variou. option., called remedial
alternative., to addre.. .oil and .ediment contamination in the
The draft
Kiddle Kar.h Study Area.
The Kiddle Kar.h Study Area i. defined by
EPA to include the Kiddle Kar.h -- a 13-acre wetland located within
the Hew Bedford Kunicipal Colf Cour.e -- and an adjacent wetland
located between Hathaway Road and Kiddle Kar.h.
Contamination in
the Kiddle Har.h Study Area occurred a. a re.ult of the movement of
Contaminant. from the quarry, or Di.po.al Area of the Sullivan'.
Ledge Site.
EPA identified it. preferred alternative and
contingency alternative for addre..ing sediment and .oil
Contamination for the Kiddle Kar8h Study Area in the Propo8ed Plan
iS8ued in Kay 1991, before the start of the public comment period.
To facilitate an efficient cleanup of the aite, EPA has divided it.
investigation of the Sullivan'. Ledge Site into two segments, known
as operable unit..
A Remedial Investigation (RI) and Fea8ibility
conducted between 1984 and 1989.
Study for the Fir.t Operable Unit (Di.po8al Area contamination) wa.
comment period on the FS and the Agency'. preferred alternative for
addressing contamination in the Fir8t Operable Unit and, in
EPA held a 49-day formal public
EPA'. plan8 for 8ite cleanup.
September 1989, .igned a Record of Deci8ion (ROD) that e.tabli.hed
Area includes:
1) excavation, solidification (if neCea8ary), and
The cleanup plan for the Di8posal
on-aite di8po8al of contaminated soi18 from the Disposal Are. and
sediments from the Unnamed Stream; 2) con8truction of an
Sullivan's Led;e Superfund Site. Middle Marsh Operable Unit
-------
-...,...,..-me...o.l.e cap over eleven acre. of the Di.po.al Area; 3)
diver. ion and lining of a .ection of the Unnamed Stream near the
Di.po.al Area14) collection and treatment of contaminated
groundwater1 5) wetland and .tream restoration1 6) long-term
environmental monitoring1 and 7) institutional control. to limit
future .ite u.e,. The .econd Operable Unit, which 1. the .ubject of
this Respon.ivene.. Summary, focu.e. on contamination in the Kiddle
Karsh Study Area.
The purpo.e of this Re.pon.ivene.. Summary i. to document ZPA
re.pon.es to the que.tion. and comment. rai.ed during the public
comment period on the Middle Kar.h Operable Unit.
ZPA will
consider all of the.e question. and comment. before .electing .
final remedial alternative to addre.. contamination in the Middle
Mar.h Study Area at the Sullivan'. Ledge Superfund Site.
Thi. Responsivene.. Summary i. divided into the following .ect1on.:
I.
OverYiew 01 Remedial Alternative. CoD.idered iD the Draft
Fea.ibilitr Study, IDcludiag the Preferred aDd CoatiDgeacr
Alternative. - Thi. .ection briefly outline. the remedial
alternative. evaluated in the rs and the Propo.ed Plan,
including EPA'. preferred alternative and contingency
alternative.
II.
Site B~.torr aad Backgrouad 00 Commuaitr Iavolvemeat aAd
Coacern. - Thi. .ection provide. a brief .ite hi.tory and.
general overview 01 community intere.t. and concern.
regarding the Sullivan'. Ledge Site.
III.
SWlllllarr of Commeat. Received Duriag Ue Pw»lic Co_eat Period
&04 ~A Re.poD.e. to tho.e Commeat. -
Thi8 .ection
.ummarize. the oral and written comment. received from the
public and from the Potentially Re.pon.ible Partie. (PRP.)
2
-------
during the public comment period, and provide. EPA re.pon.e.
to the.e comment..
IV.
R...iDiD~ CoDc.re. - Thi. .ection de.cribe. i..ue. that may
"
continue to be of concern to the community during the de.ign
and implementation of EPA'. .elected remedy for addre..ing
Are. at the Sullivan-. Ledge Site.
.011 and .ediment contamination in the Middle Mar.h StUdy
concern. during the Remedial De.ign and Remedial Action
(RD/RA) pha.e of the cleanup proce...
EPA will addrea. the.e
Summary .
In addition, two attachment. are included in thi. Re.pon.ivene..
Att.chment A provide. a li.t of the community relation.
Operable Unit - Sullivan'. Ledge Site.
activitie. that EPA has conducted to date at the Middle Mar.h
copy of the tran.cript from the informal public hearing held on
July 26, 1991.
Attachment. contain. a
I.
Overview of Reme4ial Alternatives Consi4ere4 in the
Draft Peasibility StU4y, inclUding the Preferred
Alternative and Contingency Alternative
Based upon Sullivan'. Ledge Site .tudie., EPA identified specific
objective. for the Middle Har.h Operable Unit portion of the
Sullivan'. Ledge Site.
The objective. are.
(1)
Reduce expo.ure of aquatic org.niama to PCB-
contaminated pore water and .ediment. either through
~iz.et contact or diet-related bio.cc~latioQJ
(2)
Reduce expoaure of terreatrial and wetland .pecie. to
PCB-contaminated aediment/aoil. through direct contact
or" diet-related bioaccumulation;
$ullfv8n'l ledge Superfund Site. Middl. Mlrsh Operlble unit
-------
(3)
Prevent or reduce releases of pcs. to the Unnamed
Stream and the Apponagan.ett Swamp, and
(4)
Mitigate the impact. of remediation on wetland..
EPA 8creened and evaluated potential cleanup alternative. for the
Middle Marsh Study Area at the Sullivan'. Ledge Site in the Middle
Marsh Feasibility Study (FS).
The FS describe. the remedial
alternatives considered for addressing contamination of sediments
and 80i1., a. well a. the .creening criteria u.ed to narrow the
li.t to .even potential remedial alternative. to be analyzed in
greater detail.
From theee seven alternatives EPA .elected the
Agency'. preferred alternative.
EPA's preferred alternative for
the Middle Mar8h Operable Unit include..
1) .ite preparation, 2)
excavation of contaminated sediment/.oil. from portion. of Hiddle
Mar.h and the adjacent wetland, 3) dewatering of the excavated
material.; 4) di.po.al of the material. beneath the cap that will
be constructed a8 part of the First Operable Unit for the site, 5)
restoration of the affected wetlands; 6) application of
institutional control. to prevent future residential u.e of Middle
Mar.h and the Adjacent Wetland; and 7) establishment of a long-t8rm
environmental monitoring program.
Secause implementation of the preferred alternative i. dependent
upon the availability of the Disposal Area for disposal of Middle
Mar.h sediment/soil., EPA a180 proposed a Rcontingency alternativeR
for u.e in the event that the Disposal Area become. unavailable.
The contingency alternative includes the same site preparation,
excavation, wetlands restoration, institutional controls, and long-
term monito~ing a. the preferred alternative.
However, under the
contingency alternative, the excavated sediment/sOils would be
treated on-site by solvent extraction, and the clean, treated
sediment/soils would be returned to Middle Marsh as part of the
wetland restoration. The contaminants extracted by the treatment
4
-------
~O~.Q oe 8n~pped tor destruction to an incinerator located off-
.ite.
Re.edial Alternati... a.aluated in the Middle Mar.h Fea.ibilit~
8tud~
EPA are described briefly below.
The .even remedial alternative. retained for detailed analy.i. by
the Feasibility Study .hould be con.ulted for a detailed
explanation of the.e remedial alternative., including EPA'.
The May 1991 Propo.ed Plan and
preferred and contingency alternative..
Copies of each document
are located in the Rew Bedford City Sall/Hew Bedford Public Library
and the EPA Recorda Center at 90 Canal Street in Bo.ton,
Ma..achu.ett..
.
Alternati.e 1:
No Action
.
Alternati.e 2(b)a
Site Preparation; Excavation; Dewatering;
Di.posal of Excavated Materials at the Sullivan'. Ledge
Disposal Area; Restoration of Wetland.; Long-Term
Environmental Monitorin;; and In.titutional Control..
In the Propo.ed Plan is.ued prior to the public Comment
period, EPA recommended this alternative a. it. preferred
remedy for addre.8ing Middle Marsh Operable Unit
contamination.
.
Alternati.. 5,
Site Preparation; Excavation; On-Site Solvent
Extraction; Di.po.al of Treated Sediment/Soil. in Middle
Karsh; Wetland Restoration; Long-Term Monitoring; and
Institutional Control..
In the Proposed Plan issued prior to the public comment
period, EPA recommended this alternative a. it. contingency
Sullivan's Ledge Superfund Site. Middle Marsh Operable Unit
-------
remedy for addressing Middle Marsh Operable Unit
contamination.
.
Alt.rnati.. 6(a)1
Sit. Preparation, Excavation, On-Site
Solidification/Stabilization; Disposal of Treated Materials
at the Sullivan's Ledge Disposal Area, Wetlands Restoration;
Institutional Controls; Long-Term Monitoring.
.
Alt.rnati...
6(b)1
Site Preparation; Excavation; On-Site
Solidification/Stabilization; On-Site Disposal in a Landfill
constructed at the Colf Course; Wetlands Restoration,
Institutional Controls, Long-Term Monitoring.
.
Alt.rnati.. 7(b)1
Site Preparation; Excavation, On-Site
Incineration; Disposal of Ash at the Sullivan's Ledge
Disposal Area; Wetlands Restoration; Institutional Control.;
Long-Term Monitoring.
.
Alternati.. 7(c)1
Site Preparation; Excavation; On-Site
Incineration; Off-Site Disposal of Ash; Wetland. Restoration;
Institutional Controls; Long-Term Monitoring.
II.
site History and Backqround on Community
Involvement and Concerns
The Sullivan's Ledge Superfund Sit. in New Bedford, Mas.achusetts
includes a 12-acre former quarry area, called the Sullivan's Ledge
Disposal Area, and sections of the New Bedf~rd Municipal Country
Club, including a 13-acr. wetland named Middle Marsh and an
Adjacent Wetland.
The Sullivan's Ledge Disposal Area was us.d by
local industries from the mid-1930s to the 1970s for disposal of
industrial wastes.
Wastes disposed of at the Sullivan's Ledge
Disposal Area included electrical capacitors containing
polychlorinated biphenyls (PCBs), waste oils, volatile liquids,
,
-------
metala,acrap rubber, and other materiala.
In 1984, the aite waa
added to the National Prioritiea Liat (NPL), allowing Federal
Superfund money to be used for aite inveatigation.
EPA conducted a~te investigationa, including a Remedial
Investigation/peasibility Study (RI/FS) between 1984 and 1989.
Theae inveatigation. evaluated the nature and extent of
contamination present at the aite, and dete~ined that the .ite
1989, EPA released the Proposed Plan to addresa aite contaminanta.
contam+nanta poae a riak to public health and the environment.
In
Following consideration of public Comment a on the Propoaed Plan and
the FS, EPA iaaued a Record of Deciaion (ROD) for the Firat
Operable Unit on June 29, 1989, eatabliahing a cleanup plan for
aelected portiona of the .ite.
In September 1990, EPA, the Commonwealth Of Maaaachusett. and
fourteen companies that have been determined to be POtentially
reaponaible for contamination in the Firat Operable Unit, reached a
settlement. Under this settlement, the 14 companies agreed to do
the following: (1) construct the remedy called for in the 1989 ROD;
(2) perform Operation and maintenance for thirty years after
completion of construction of the remedy; and (3) pay a POrtion of
EPA'a and the State' a paat coat a of conducting atudiea at the aite
performed in the Firat Operable Unit.
and of overseeing the design and construction of work to be
the portiona of the aite addreased in the Firat Operable Unit,
including the Di8posal Area, i. currently underwAY.
Deaign of the cleanup plan
optiona for addres.ing Contamination found in Middle Marah.
In the 1989 Proposed Plan, EPA presented three posaible cleanup
options included a NO-Action alternative, which called for no
cleanup activities to occur within Middle Marsh; and two
These
alternatives that called for excavating sediments that Contained
PCSs at concentrations that may cause long-term impacta to aquatic
Sullivln'. Ledge Superfund Site - Middle Mlrsh Operlble Unit
-------
organism..
The two alternative. differed in the amount of
.ediment/.oil that would be excavated, and thus in. the re.idual
level. of Pcs. that would remain in the area.
In the 1989 Propo.ed
Plan, ZPA .ought comment. on the various cleanup alternative. for
Middle Mar.h and initially recommended a No-Action alternative.
EPA .tated that removal of the contaminated .ediment. in all area.
of Middle Mar.h exceeding the interim Sediment Quality Criteria
could cause more harm to the environment than leaving the
contaminated sediment. in place.
Secau.e Middle Mar.h is located within a heavily used golf COur.e
and because of the high ecological value of wetland., ZPA was
especially interested in receiving public comment on the three
remedial alternative. con.idered for Middle Mar.h.
After further
consideration, EPA concluded in June 1989 that additional .tudie.
of Middle Marsh and the Adjacent Wetland would be nece.sary tOI
(1) determine with greater accuracy the nature and extent of
contamination in the area; (2) compare the potential environmental
impact. of conducting cleanup activities to the impacts of .ite
contamination; and (3) further identify any potential risk to human
health and the environment posed by the contamination.
This
decision separated the study and remediation of Middle Marsh and
the Adjacent Wetland into a .econd operable unit, called the Kiddle
Marsh Operable Unit.
The nece.sary additional information was
developed by conducting an RI and FS for the Kiddle Marsh Study
Area.
Community concern surrounding contamination at the Sullivan'. Ledge
Site ha. been moderate throughout EPA's involvement at the site.
Comments received during the 1989 public comment period on the
First Operable Unit focused on the following is.ue.:
.
Extent and nature of site contamination;
.
Public health impacts resulting from site
contamination;
B
-------
.
Future u.e. of the .ite including monitoring and
maintenance, and
.
EPA'. community relation. program.
On Kay 28, 1991 ,EPA held a public informational meeting to pre.ent
the Proposed Plan for the Kiddle Mar.h Operable Unit.
Approximately 2S per.ons attended the meeting.
Public comment. at
that meeting covered topics including the Disposal Area cap,
financing of the Middle Kar.h cleanup, future u.e of the golf
cour.e property, the ability of EPA'. remedies for the .ite to
control the contamination of groundwater, and ,incident. of human
contact with the contaminated sediment/aoil..
A complete li.t of community relation. activities conducted at the
Sullivan'. Ledge Site i. included in Attachment A at the end of
this document.
III. Summary of Comments Received During the Public
Comment Period and EPA Responses
Thi. Respon8ivenes8 Summary addre8ses the comment. received by EPA
concerning the draft FS and Proposed Plan for the Kiddle Kar.h
Operable Unit for the Sullivan'. Ledge Superfund Site in New
Bedford, Massachusett..
Six .et. of written comment. were received
during the public comment period (May 30 - July 31, 1991).
Five
Kunicipal Golf Course and potentially responsible partie..
Environmental Protection, the City of New Bedford, member. of the
included representative. of the Massachusetts Department of
hearin9 and on. peraon provided comment a by telephone.
persona provided oral comment. at the July 26, 1991 informal public
Comment or.
B.
of the transcript of the public hearing i. included as Attachment
A copy
Sullivan'l Ledge Superfund Site. Middle Marlh Operable Unit
J
POOR QUALITY
-------
A.
Co-UDitr Co_eat.
1.
The co..eat. fro. citi.ea. gi.ea at ~be public beariDg aad/or
ia vri~iag are .umaari.ed ~elow aloag vi~b EPA re.poa.e..
COIUUllf'Z' J:
A resident commented that too much time and money may
have ~een .pent on the aite.
RESPONSE -
The remedial inve.tigation and feasibility atudy
(RIllS) .tudy proce.., as outlined in the -Guidance for Conducting
Remedial Investigation. and Feasibility Studies under CERCLA8
represent. the methodology that the Superfund program ha.
established for characterizing the nature and extent of risks posed
by uncontrolled hazardous waste sites and for evaluating potential
remedial option..
The objective of the RIIFS proce.. i. to gather
information .ufficient to .upport an informed ri.k management
decision regarding which remedy appears to be mo.t appropriate for
a given aite.
As stated in the National Oil and Hazardous
Substances Pollution Contingency Plan (NCP), developing and
conducting an RIllS generally includes the following activities:
project .coping, data collection, ri.k assessment, treatability
.tudie., and analy.i. of alternative..
The Sullivan'. Ledge Superfund Site, including the Middle Mar.h
Operable Unit, has been the subject of Phase I (Ebaaco, 1987) and
Phaae II (Eba.co, 1989a) remedial investigations and a feasibility
study (Eba.co, 1989b) which was completed in January 1989.
The
remedial investigation. reveal that PCBs and other contaminant.
have migrated from the Disposal Area to the Unnamed Stream and the
wetland. just north of the Disposal Area, including Middle Mar.h
and the Adjacent Wetland.
EPA concluded in June 1989 that
additional studies of Middle Marsh and the Adjacent Wetland areas,
including biological 8tudies, would be necessary to: (1) determine
with greater accuracy the nature and extent of contamination in the
10
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area; (2) compare the potential environmental impact. of conducting
cleanup activities to the impact. of .ite contamination, and (3)
environment po.ed by the contamination.
further identify any potential ri.k to human h.alth and the.
Thu. the .tudy and
remediation of Hiddle Har.h and the Adjacent Wetland area. wa.
.eparat.d into a .econd Operable unit, called the Hiddle Har.h
Operable Unit.
The -Remedial Inve8tigation - Additional Studies of
Hiddle Mar.h- wa. completed in April 1991 and the -Fea.ibility
Study of Middle Mar.h- wae completed in May 1991.
EPA believe. that the time and co.t. a..ociated with the conduct
and completion of the .tudie. de.cribed above wa. not exce..ive but
wa. con8istent with CERCLA, the NCP and the -Cuidance fOr
CERCLA-.
Conducting Remedial Investigation. and Fea.ibility Studies under
locat.d within a heavily uS.d golf cour.. and becau.e of the high
ecological value of the wetland., the.e studies, including the
In particular given the fact. that Middle Harsh is
ecoloqical assessment were neces.ary to gather information
sufficient to support an informed risk management deci.ion
regarding which remedy is most appropriate for the Middle Mar.h
Operable Unit
COMMENT 2:
A resident Commented that the proposed cleanup wa. very
expen.ive.
RESPONSE -
In the Agency'. judgment, the lelected and contingency
remedies are co.t effective, i.e., the remedies afford overall
effectivene.. proportional to it. co.t..
In selecting the..
remedies, once EPA identified alternatives that are protective of
human health and the environment and that attain, or, a.
appropriate, waive ARAR., EPA evaluated the overall effectivene..
of each alternative by a..es.ing the relevant three criteria--long
term effectiveness and permanence, reduction in toxicity, mobility,
and volume through treatment; and short term effectiveness, in
Sullivan's Ledge Superfund Site. Middle Marsh Operable unit
-------
co~ination.
The No Action alternative was elLminated from
conaideration becauae it would not attain ARARa and would not be
protective of the environment.
The relationahip of the overall effectiveneaa of the aelected and
contingency remedial alternatives waa determined to be proportional
to their coata.
1.
Selected Remedy
The coata aaaociated with the 8elected remedy are I
Estimated Capital eost., $2,640,000
E8timated Operation and Maintenance Coat (net pre8ent worth)1
$164,000
E8timated Total Cost (net pre8ent worth)1 $2,800,000
Of ~e source control alternatives discu88ed in Section
VIII., EPA haa determined that the selected remedy
(excavation, dewatering, disposal under an impermeable cap)
may be only 8lightly les8 effective in the long-term .s
alternative 6(.) (solidification/stabilization, disposal at
the Disposal Area) and alternative 6(b)
(solidification/stabilization, dispo8al at golf cour.e
landfill) because under the .elected remedy, the contaminants
would be placed in a RCRA landfill that would include
groundwater treatment and monitoring to ensure the
effectiveness of the landfill.
Although this selected remedy
doe. not provide pernanence through treatment, unle..
required by the land di8po8al re8triction., it may not be
~eceasary to 80lidify or otherwi8e treat excavated Middle
Mar8h and Adjacent Wetland sediment/soils because the leve18
of PCBs are relatively low, le88 than 50 ppm, and would be
properly contained under a RCRA engineered cap to be
constructed as part of the Firat Operable Unit.
While the
selected remedy does not provide the same degree of
J2
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and/or incineration, for the Kiddle Karsh Operable Unit
uncertainty associated with the long-term effectiveness of
the selected remedy in containing relatively low levels of
pcas shall be minimized by engineering and institutional
controle.
In comparison to all other containment/treatment
alternatives, the selected remedy is the lea.t costly with a
present worth cost of $2,800,000.
Contrastly, present worth
cost. of other alternatives requiring treatment include:
80lidification/di8posal from $5.0 to $6.0 million1 80lvent
extraction at $7.8 million1 and on-site incineration from
$9.8 to $10.0 million.
2.
Contingency Remedy
The coats associated with the contingency remedy are:
Estimated Capital Costs: $7,620,000
Estimated Operation and Maintenance Cost (net present worth):
$164,000
Estimated Total Cost (net present worth): $7,780,000
Assuming the Disposal Area would not be available for
disposal of excavated material8, of the remaining source
control alternatives for sediment/soil remediation, EPA has
determined that solvent extraction (contingency remedy)
followed by off-.ita incineration of the PCB-contaminated oil
extract would be the most effective in permanently &D4
significantly reducing the toxicity, mobility and volume of
hazardous substances and in reducing contaminant levels in
sediment/soils to cleanup levels.
A comparison of present
worth costs for solvent extraction and on-site incineration
indicates that the present worth costs for solvent extraction
Sullivan't Ledge Superfund Site - Middle Marth Operable Unit
-------
i. lower than on-.ite incineration, $7.8 million verau. $10.0
million, reapectively.
While the .olidification/containment alternative i. cheaper
than the c~ntingency .ource control alternative (.olvent
extraction), it doe. not provide the .ame degree of .hort-and
long-term effectivene.. and permanence.
EPA haa determined
that .ignificant uncertaintie. are a.aociated with the long-
term effectivene88 of alternative 6(b),
.01idification/8tabilization with on-.ite di.po.al in a
landfill conatructed in the golf cour.e.
In particular, thi.
alternative would require con.truction of a new landfill in a
golf cour.e where public acce..ibility would be aignificant.
A. .tated above, the 8elected .ource control alternative
(.olvent extraction/off-8ite incineration) i. le.. expen.ive
than the only other equally effective treatment alternative
(on-.ite incineration).
Thu., a8auming the .elected remedy
would not be implementable, the .election of 80lvent
extraction al the contingency source control alternative for
8ediment/8oil. 18 cost-effective.
co~ 3.
A re.ident commented that no fi.h live on the aite, and
that the only aquatic organisma present on-.ite are micro.copic.
RESPONSE -
Table 2-3 of the RI, li.ta fauna observed at Middle
Mar8h and the immediate vicinity.
Among thoae li8ted are the
following aquatic organism8: bull frog, green frog, northern
leopard frog and crayfi.h.
A qualitative benthic invertebrate survey was conducted on
September 20, 1990 in aubmerged area. on each aide of the unnamed
8tream in Middle Mar8h at the sixteen locations (81 to 816)
indicated in Figure 4-1 of the RI.
At each location, sample8 were
collected with a dip net by agitating the water just above the
l4
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sediment~
Invertebrate species were identified to the low.st
practical taxa.
The results of .ampling at each .tation, i. listed
in Table 4-3 of the RI.
Obligate aquatic organisms identified
includedz
amphipods, freshwater clams (Sphaeriidae), isopods,
Alderfly larvae (Sjalu8 ap.), Cranefly larvae (rjpula ap.), midge
larvae (Chironomid.), tadpole. and leeche. (Hirudinea).
Finally, during field inveatigation., Metcalf and Eddy peraonnel
observed fi.h in the unnamed ~ream within POrtion. of Middle
Mar.h.
Because of the connection between the .tream, and it.
tributary and surrounding area. within the northwest POrtion of
Middle Mar.h, EPA hae determined that fi.h may al.o inhabit the
aquatic area within Middle Mar.h, as designated in Figure 4-2 of
the RI.
All of the organisms identified above are of .uitable size and
.hould not be deacribed aa microacopic.
COlUUlNr 4:
A reaident commented that golfers would not ventur.e
into the marsh to retrieve golf balls, but that children have done
so in the past.
RESPONS~ -
Under current and future land uae condition., the
Middle Marsh and golf Course areas would be expected to be
frequented by golfers and maintenance worker. who may contact
activities such a. golfing and landscaping.
contaminated surficial 8ediment/soil. and .urface water during
as a reasonable worst caee aince exposure to this age group over.
An adult was evaluated
thirty year period will be more significant than exposure to older
children over a much shorter period (e.g., ten years or le..).
As indicated in Tables 5-31 and 5-35 of the RI, total exc.as
lifetime carcinogenic ri8ks evaluated to reflect preaent and
potential future exposure for the contaminant8 of concern in Middle
Sullivan's Led;e Superfund Site - Middle Marsh Operable Unit
-------
Marsh and the golf course/Adjacent Wetland area. corresponding to
the average and the rea.onable maximum expo.ure .cenario. fall
within EPA'. acceptable ri.k range of 10.' to 10.'. In addition,
total non-carcinogenic risk. evaluated to reflect pre.ent and
potential future expo.ure for the contaminant. of concern in Middle
Mar.h and the golf cour.e/Adjacent Wetland area. corre.ponding to
the average and the reasonable maximum expo.ure .cenario. are le..
than EPA'. benchmark for a hazard index of one.
Therefore, EPA has
. determined that, ba.ed on the expo.ure assumption. described above,
human expo.ure to .ite contaminant. in Middle Mar.h and the
Adjacent Wetland through the current and future pathway. outlined
above would not re.ult in .ignificant increase. 1n carcinogenic
ri.k.
EPA ha. further determined that there are no .ignificant
ri.k. to human health posed by expo.ure to noncarcinogenic
contaminants in Middle Marsh and the golf cour.e/adjacent wetland
area..
Based on the above calculation., it can be further
determined that there would be no .ignificant increa.e. in
carcinogenic ri.k to an older child through infrequent expo.ure.
However, exposure of children to contamination at any level. .hould
be min~ized to the extent possible.
A. part of .ecurity mea.ure. to be implemented in the golf cour.e,
.ign. will be po.ted to di.courage contact with contaminated
sediment/soil., a. a warning to older children a. well a. golfers.
Finally, institutional control. shall be implemented to en.ure the
continuing u.e of the Middle Marsh Operable Unit a. .
recreation/conservation area and to prevent residential development
of the area which may result in more frequent exposure than the
assumptions u.ed to calculate human health risk. a. identified in
the ROD.
COIUCEII%' 5:
A resident commented that homes would never be built on
the golf course due to the value of the course as a community
recreational facility.
J6
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RESPONSE -
EPA baaed ita aaaeaament of future human health
expoaure parameter a on the aaaumption that Middle Marah and the
Adjacent Wetland would continue to be uaed for a golf courae or
other recreation; and not for reaidencea (e.g. houaing
developmenta).
Thia asaumption ia baaed on the 8tated intention of
the City of New Bedford to change the &oning of the aite from
. reaidential to recreation/conaervation of Middle Mar8h and the fact
that because the Middle ~r8h 8tudy area i. primarily in a wetland,
future development of Middle Marah and the adjacent wetland i.
highly unlikely.
EPA acknowledge. your concurrence with the assumption made by EPA
with respect to the recreation/conaervation future land u.e of
Middle Marsh and the Adjacent Wetland.
A. a component of the ROD,
inatitutional control. shall be implemented to en.ure the
continuing u.e of the Middle Mar.h Operable Unit a. .
recreation/conservation area and to prevent residential development
of the area.
COlDfENr 6:
A resident commented that he does not want the sediment
and soil. from the Middle Mar.h cleanup .to be placed under the
Sullivan' a Ledge Diapoaal Area cap.
RESPONSE -
EPA haa determined that the aelected remedy provide.
the best balance of trade-offs among the alternative..
The
selected remedy would be protective of human health and the
environment by reducing contaminant levels to meet cleanup levels.
Given the low level. of PCB. detected in sediment/soil. (less than
50 ppm) and the fact that the Sullivan'. Ledge Di.posal Area would
be capped as part of the remedy for the First Operable Unit, EPA
has determined that, for the Middle Harsh Operable Unit, treatment
i. impractiCable.
Excavation, dewatering and disposal of
sediment/.oils in the RCRA engineered landfill to be constructed at
the Disposal Area provides the best balance of all alternatives
Sullivan'. Ledge Superfund Site. Middle Mlrsh Operable unit
1.7
-------
cons.idering .hort- and long-term effectiven..s and co.t.
Of all
the action alternatives,. excavation and capping would be the most
easily 1mplementable as it would not require use of .peciali&ed
units with .ometimes limited availability.
The placement of
excavated .edim~nt/.oil. under the cap to be constructed over the
Disposal Area would not significantly increase the volume of
contaminated material. a. would .olidification alternative. but
would significantly reduce the mobility of hazardous substances
through engineering and institutional control..
The No Action alternative was eliminated from consideration as a
recommended alternative becau.e it would not. be protective of the
environment and would not attain ARAR..
COK1UlN7' 7,
A resident .tated that the proposed cleanup of Hiddle
Harsh would not be effective in the long-term becau.e the
contaminated groundwater flowing from the Disposal Area would
continue to contaminate the Middle Marsh area.
RESPONSE -
The selected and contingency remedies address
contaminated sediment/.oil. in Middle Har.h and the adjacent
wetland by requiring excavation of sediment/soil. with PCSs in
'.
excess of sediment/soil cleanup levels.
These remedies contain
source control components and do not include any remedial
components which address the groundwater contamination at the Site.
U.S. EPA Region I i.sued a Record of Decision (ROD) for the First
Operable Unit on June 29, 1989 which outlined remedial action for
the D~.po.al Area and included management of migration component.
to addres8 the qroundwater contamination at the Disposal Area.
described in the June 29,1989 ROD, the selected remedy included
A8
construction and operation of groundwater pa88ive and active
collection, extraction, treatment and discharge 8y.tems to
J'
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intercept and minimi&e further migration of contaminated
groundwater to the golf cour.e.
There i. no dat~ which indicate. that the groundwater
contamination, which originate. at the Di.po.al Area, ha. migrated
to the Middle Mar.h area.
Furthermore, a. di.cu..ed above,
implementation of remedial activities a. .pecified for the Fir.t
Operable Unit .hould mitigate the potential for contaminated
groundwater to migrate from the Di.po.al Area to downgradient area.
including Middle Mar.h.
C01Ul.ENr ,:
A re8ident .tated that the public hearing and the
propo.ed plan .hould have been adverti.ed more aggre8.ively.
RESPONSE -
EPA conducted community relation. activities at the
.ite in accordance with Section 300.430(f)(3) of the NCP.
In
particular, on May 29, 1991, EPA held an informational meeting at
the Day'8 Inn, New Bedford to de8cribe the re8ult. of the Middle
Mar.h Remedial Inve.tigation, the cleanup alternative8 presented in
the Fea8ibility Study and to pre8ent the Agency'. Propo.ed Plan.
On May 30, 1991, EPA made the admini8trative record available for
public review at EPA'. office. in Bo.ton and at the New Bedford
Free Public Library.
EPA publi8hed a notice and brief analy.i. of
the Proposed Plan in the New Bedford Standard Time. on May 24, 1991
and made the plan available to the public at the New Bedford Fr.e
Public Library.
From Hay 30, 1991 to July 31, 1991, the Agency
held a .ixty-three day public comment period to accept public
comment On the alternative8 pre8ented in tbe Fea8ibility Study and
the Propo.ed Plan and On any other documents previou.ly relea.ed to
the public.
On June 26, 1991, the Agency held a public hearing to
di8cu.. the Propo8ed Plan and to accept any oral comment..
A
tran8cript of this meeting and the comment8 and the Agency'.
respon8e to comment8 are included herein.
Sullivan'S Ledge Superfund Site - Middle Marsh Operable Unit
-------
A complete list of community activities conducted at the Sullivan'.
Ledge Site i. included in Section III. of the ROD and in Attachment
A to this re.pon.ivene.. .ummary.
COIOlEN'r 'a
A repre.entative of the golfer. who use the cour.e
surrounding Middle Marsh stated that a majority of the golfers
believe that a no action alternative is the most appropriate remedy
for the site becau.e of the po.sibility that contaminated
groundwater may continue to contaminate the .ite for an indefinite
r.
period of time, and thus thwart the goals of the cleanup proposed
by EPA.
by EPA.
A petition to this effect with 76 signature. wa. received
RESPONSE -
The rationale on why the selected and contingency
remedies were cho.en over the No Action alternative i. discussed in
EPA respon.e to comment 1 in Section A.3. below.
Refer to EPA response to Comment 7 above for explanation of the
interaction of the groundwater remediation component, a8 specified
in the 1989 ROD for the First Operable Unit, with the selected
remedy for the Middle Marsh Operable Unit.
--
COKKBWr 10, A resident 88ked why the State's standard for the
protection of human health for the .ite is different from that u.ed
~:
=-S .
by EPA.
RESPONSE -
The Mas8achusetts Contingency Plan establi.hes
requirements and procedures to be followed by the Commonwealth to
888e8s releases and threats of releases of hazardous materials. 310
CKR 40.S4S(3)(g)(J)(b) of the Massachusetts Contingency Plan
specifies that if hazardous materials are likely to be transported
to exposure point. through more than one medium, the ri.k of harm
to health shall be characterized by comparing current and
20
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reasonably foreseeable exposure point concentrations and the
estimated frequency and duration of exposure to each hazardous
material to estimate ~o~al si~e cancer risks.
Under ~hese
procedures, ~otal si~e cancer risks is compared to a total site
cancer risk limit of one in one hundred thousand.
Under the NCP, acceptable exposure levels calcula~ed by ZPA are
generally concentration levels that represent an excess upper bound
lifetime cancer risk to an individual of between one in one ten
thousand and one in one million using information between dose and
response.
This approach ditfers from the Commonwealth's in ~ha~
generally, riaks are evaluated separately tor each medium and not
added up as a total site risk.
Based on the differences in ~he.e
approaches, cleanup levels calculated in accordance with ~he HCP,
and with NCP mayor may not be more stringent, depending upon site-
specitic factors including exposure points.
CO~r 11: A resident asked whether fencing the contaminated areas
would be the 8implest remedy for the Hiddle Harsh Study Area, and
if 80, why could fencing not be the cleanup remedy chosen tor the
Middle Marsh Operable Unit.
This resident argued that the
uncertaintie8 regarding the transport of contaminant8 to the marsh
and the effectiveness of EPA's propo8ed remedy indicate that a
8impler and les8 expen8ive remedy is most appropriate for the site.
RESPONSE -
Limited No Action which would include fsncing
contaminated area. in the Middle Marsh study area was not ch08en as
the 8elected or contingency remedy for ~he reasons outlined in EPA
response to Comment 1 in Section A.3. below.
EPA did consider the factors of long-term effectivenes8 and cost in
the selection process and concluded that both the selected and
contingency remedies represent the best balance of those criteria,
Sulllv8n'l Ledge Superfund Site - Middle M8rlh Oper8ble Unit
-------
as described in Section 11.C. of the ROD, and described in response
to Comment 2 above.
CO~T 12: A resident noted that one of the quarry pits at the
Disposal Area was approximately 300 feet deep. 'He stated his
belief that there is no existing technology that can extract the
contaminated water from the pits in the Disposal Area, and that the
most EPA can do is prevent the contamination from becoming worse.
RESPONSE -
As described in EPA response to Comment 7 above, U.5.
EPA Region 1 i..ued a Record of Decision (ROD) for the First
Operable Unit on June 29, 1989 which outlined remedial action for
the Disposal Area and included management of migration components
to address the groundwater contamination at the Disposal Area.
described in the June 29,1989 ROD, the selected remedy included
As
construction and operation of groundwater passive and active
collection, extraction, treatment and discharge systems to'
intercept and minimize further migration of contaminated
groundwater to the golf course.
The selected and contingency remedy for the Middle Mar8h Operable
Unit does not address 8uch groundwater contamination at the
DiBpo8al Area becau8e it will be addresBed as part of remedial
action taken at the FirBt Operable Unit.
EPA agrees with your statement that no exiBting technology can
extract the contaminated water from the pits in the Disposal Area.
For this reason, aB part of the 1989 ROD for the First Operable
Unit, EPA determined that compliance with the requirements of
certain groundwater ARARs i8 technically impracticable and waived
compliance with such ARARs,including maximum contaminant levels
promulgated under the Safe Drinking Water Act.
22
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co~r 13, A re.ident commented that .ample. he has taken from the
Apponagan.ett Swamp .how very high level. of PCB., and therefore he
believe. that the PCBs in the Middle Mar8h Study Area did not
originate in the'Di8poaal Area.
~
RESPONSE -
EPA has determined that elevated PCB concentration. in
Middle Mar.h and the Adjacent Wetland have been detected a. .
result of the transport of contaminated .oil. from the Di8posal
Area, a. de.cribed in EPA respon.e to Comment 8 in Section C.l.
below.
2.
~be comment. froa Dr. Pbilip Gidley gi..n in writing are
.ummari..d b.low along with EPA r..pon....
COMMENT 1:
Thi. hazard i8 greatly exaggerated, not nearly a.
hazardous a8 the continuing use of golf course pesticide..
ftesconse - A8 de8cribed in Section VI. of the RI, EPA has
determined that actual or threatened relea8e8 of hazardous
8ub.tance. from contaminated 8ediments in Middle Mar.h and the
adjacent wetland, if not addressed by implementing the respon.e
action selected in this ROD, may present an imminent and
substantial endangerment to biota through aquatic and
wetland/terrestrial pathway..
In 8ummary, the application of 8ite-specific ti88ue data and
bioaccumulation factors to the food chain pathway model, reveals
several areas in Middle Marsh and the adjacent wetland
approximately 1.9 total acres that exceed level. derived to protect
mink (.ee Figure 9 of the ROD).
PCB concentrations at sampling
locations HE22, HE38 and SLS6 of 28, 32 and 34 mg/kg PCB,
re8pectively'exceed calculated protective levels for carnivorous
birds.
-------
of 32 mg/kg PCB, and SL56 of 34 mg/kg PCB exceed calculated
protective levels for insectivorous birds.
EPA has further ~etermined that there are no significant risks to
human health posed by exposure to carcinogenic and noncarcinogenic
contaminants in Middle Mar8h and the adjacent wetland.
It is .important to note that pe8ticides were detected in only four
surface 8amples from thirty (30) 8tations in Middle Marsh.
The
pe8ticides detected were 4,4'-DDE, 4,4'-DDT, and 4,4'-DDD and were
found at leve18 only slightly above detection limits with
concentration8 ranging from 0.13 mg/kg to 0.590 mg/kg.
In the
Adjacent Wetland, 4,4-DDD was found at Station SL54 at 0.009 mg/kg.
No other pesticides were found at levels above detection limits in
the Adjacent Wetland.
Pe8ticides were not found on the golf
course.
Since 4,4'-DDD and 4,4'-DDT were found in only two samples
collected under the Phase I RI, these detection8 of pe8ticides a~e
not likely related to the Disposal Area.
Furthermore, pesticides
were not detected in water samples and in plant samples taken from
Middle Marsh.
For the reasons stated above, pesticides were not 8elected a8
contaminant8 of concern at the Middle Mar8h Operable Unit, and were
not considered to pose a 8ignificant risk to human health.
, .
COMMENT 21
A sediment trap should have been installed a8 early as
1981 to trap PCBs. Had thi8 trap been installed early, there would
have been substantially no contamination in the so-called Middle
Marsh.
ReSDonse -
EPA conducted an air monitoring program of the Greater
New Bedford Area in 1982 and installed groundwater monitoring wel18
around the Sullivan's Ledge 8ite in 1983.
Ba8ed, in part, on the
24
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re.ults of these atudie., the Sullivan'a Ledge .ite was included on
the National Priorities liat in September 1984, making it eligible
for auperfund monies.
In September 1984, EPA ia.ued the owner of
the aite, the City of New Bedford, an Adminiatrative Order under
Section 106 of the Comprehensive Environmental Reapon.e,
Compensation and Liability Act of 1980 (CERCLA).
In compliance
with this Order, the City of New Bedford in 1984 aecured the
Disposal Area by installing a perimeter fence and poated .igns
warning against unauthorized trespassing of the aite.
The perimeter fence deacribed above was con.tructed to prevent
expoaure to the principal threat a posed by the aite. Although it ia
true that early intervention by inatallation of aedimentation trapa
may have somewhat mitigated transport of PCB a to downstream areaa,
EPA determined that aince access to the principal threat in the
ahort-term had been minimized through construction of the fence"
the thre.t of releaae and risk aa.ociated with auch rele..ea would
be addressed by the RIfFS to be conducted at the aite.
Finally, aignificant deposition of sediment over the banks of the
unnamed stream was observed by Metcalf and Eddy staff in Middle
Marah during a storm event, especially in the most upgradient areas
of Middle Marah.
Therefore, the use of sedimentation baa ins aa
early a. 1981 may have lessened but would not have completely
prevented the contamination of Middle Marah.
COMMENT 31
The EPA Fact Sheet of April 1991 greatly exaggerat..
the ecological exposure risk by its highly theoretical premise of
bioaccumulation in the food chain and fails to put this theoretical
riak in its actual perspective.
Response -
The food chain model is a conceptual model used to
represent the trophic levels between the apecies expected to be
present in Middle Marah.
However, only site-specific tissue data
Sullivan'. Ledge Superfund Site - Middle Marsh Operable unit
-------
was u.ed to develop bioaccumulation factor. for .mall mammal.,
earthworm. and frogs, indicator species u.ed in the model. These
.ite-.pecific factor. were used in the model to evaluate the
effect. of contamination on environmental receptor..
A. .tated in the -Guidance for Conducting Remedial Investigation.
and Feasibility Studie8 under CERCLA-, the objective of the RI/PS
process i. not the unobtainable goal of removing all uncertainty,
but rather to gather information sufficient to support an informed
ri.k management deci8ion regarding which remedy appear. to be moet
appropriate for. given .ite.
EPA believe. that the information
provided by the RIfFS, including the re.ult. of the .ite-.pecific
biological study and the u.e of the food chain model, i. not highly
theoretical but i. .ufficient to baee the remedy .election for the
Kiddle Kar.h Operable Unit.
See EPA response. to comment. 10 and 14 in Section C.l. below for
description8 of how EPA calculated cleanup levela.
COMMEHT 4:
Vegetation absorbs very small amounts of PCB.
Rest)()nse -
EPA agrees with your comment that, for this 8ite, the
vegetation absorbed very small amount of PCB.. In particular, plant
sample. were collected at seven sampling location. in Kiddle Karsh.
The results of the analysis of the grass seed heads (Phaloris
arundinacea), and the multiflora rose hips (Rosa multiflora)
indicate. that no pesticides or PCBs were detected.
COIOa:HT 5:
Kalathlon spraying for mosquitoes in Southeastern
Kassachusetts presents a much greater hazard to insects, frogs and
bird..
Rest)()nse -
See response to comment 1 in Section A.2. above.
26
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COMMENT 6,
None of the aquatic organieme or animals cited in the
Middle Marsh are in the human food chain.
Res~nee -
Consumption of aquatic or terre.trial organiem. by
humane was not considered a complete exposure pathway and therefore
wa. not evaluated in the human health ri.k a.se..ment for the
Middle Marsh Operable Unit.
The food chain model wae developed to
represent the trophic relationships between the species expected to
be pre.ent in Middle Mar.h and to evaluate the effect. of
contamination on environmental receptors.
Whether or not a .pecie. i. in the human food chain i. not a
criterion for eelecting it a. an indicator epeciee for evaluation
in the ecological ri.k a..e.sment.
For the Middle Mareh Operable
Unit, epecie. .elected for the food chain model were ba.ed on
observed abundance at the eite, presence of .uitable habitat for
the species, and likelihood of exposure.
Specifically, the u.e of
mink as an indicator species, a specie. known to be .eneitive to.
PCBs, is consistent with EPA quidance. As .tated in the quidance,
ecologiste will often use professional judgement to select a
particular organism as an indicator species, that is, a species
thought to be representative of the well-being and reproductive
succe.. of other species in a particular habitat. Indicator speciee
may al.o be chosen becau.e it ie known to be particularly seneitive
to pollutant. or other environmental change..
COMMENT 7,
The animal. are much more endangered by golf course
pesticides and run-off.
Resoonse -
Pesticides were not selected as contaminants of
concern, as described in response to comment I in'Section A.2.
above.
Sullivan's Ledge Superfund Site. Middle Mersh Cpereble unit
-------
EPA found no sources of .ignificant urban runoff other than the
unnamed .tream and doe. not believe that the heavy metal. found in
the interior area. of Middle Marsh have their .ource in area. other
than Sullivan'. Ledge and the urbanized drainage area.
Due to the
low water concentration., heavy metals have not been evaluated a. a
hazard to aite biota.
EPA believes that the exposure to PCB-contaminated .ediment. in
Middle Marsh and the adjacent wetland present an unacceptable ri.k
to biota expo.ed to .uch contaminant..
EPA has determined that the
.ource of elevated PCB concentration. in Middle Mar.h and the
adjacent wetland, i. the Sullivan'. Ledge Disposal Are. (.ee
Comment 8, Section C.l. below).
COIOIENT 8:
Given the low solubility of PCB. in water, the brevity
of contact and small amount of solute involved, it i. practically
inconceivable that skin absorption could result from retrieving a
wet golf ball.
ReSDOnse -
Assumptions regarding contact with surface water were
conservatively made in order to protect maintenance workers or
other individuals who spend a day retrieving golf balls from the
marsh and are consi.tent with Region 1 risk assessment guideline..
Given the assumptions for surface water exposure used in the ri8k
assessment and the contaminant concentrations in surface water, EPA
has determined that there are no significant risks to human health
posed by expo8ure to contaminants iu surface water in Middle Marsh
and the golf course/Adjacent Wetland.
COHHEHT 9:
The risk to golfers from golf course pesticides is far
greater.
Response - See response to comment 1 in Section A.2. above.
28
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COMMENT 10: The accidental inge.tion of contaminated .oil and
.ediment by golfer. cited by EPA i. an extraordinarily remote
po88ibility.
RestlOnee -
EPA believe. that the exposure as.umption. u.ed in the
human health ri.k as.essment are rea.onable given the pre.ent and
future land u.e of the Middle Marsh Operable Unit and are
consi.tent with Region 1 ri.k aeses.ment quidance.
In particular,
under current land-use condition., the Middle Mar.h and golf cour.e
areas would be expected to be frequented by golfer., maintenance
worker. and older children who reside in the vicinity of the .ite.
These receptor. can contact contaminated .urface .ediment/.oil
during activities during activities such as golfing, working and
playing.
The mo.t 8ignificant expo.ure pathway for the area. of concern
involve direct contact with surface sediment/soil.
This i. because
.urface sediment/soil will most likely be contacted during
recreational or work activitie., and the majority of the chemicals
of concern were measured at the highest concentrations in surface
.ediment/soil.
3.
rb. commeat. froa the Citr of Hew Bedford giyea at tbe pUblic
beariag aad ia writiag are .ummarized below aloag with EPA
re.poa.es.
C01f1Unlr l,
The City of New Bedford stated that a no action or
limited action remedy should be implemented instead of EPA's
Preferred Alternative.
The limited action should include: (1)
institutional controls including zoning restrictions, deed
restrictions, and access restrictions; (2) fencing and or
vegetative barriers to human access at Middle Marsh; (3) wincreased
remediationw of the southern portion of the unnamed stream located
Sullivan'l Led;e Superfund Sfte . Middle Marlh Operable Unft
-------
.outh of Hathaway Road during implementation of the First Operable
Unit at the .ite.
RESPONSE -
The Comprehen.ive Environmental Response, Compen.ation
and Liability Act (CERCLA), as amended by the Superfund Amendment.
and Reauthorization Act of 1986 (SARA), require. EPA to ensure the
protection of the environment in (1) selection of remedial
alternatives and (2) assessment of the degree of cleanup necessary.
Several section. of CERCLA make reference to protection of health
and the eavironment a. part. of a whole.
Section 105(a)(2) call.
for methods to evaluate and remedy -any releases or threat. of
releases ... which po.e .ubstantial danger to the public health or
the environment.-
Section 121(b)(1) requires selection of remedial
action. that are -protective of human health aad the env!roaaent.-
Section 121(c) call. for -assurance that human health and the
enviroD88Dt continue to be protected.-
Finally, Section 121(d)
directs EPA to attain a degree of cleanup -which assures protection
of human health and the environmeat.-
Like CERCLA, the NCP refers throughout to health and environment a8
aspects of the evaluation and remediation processes.
For example,
in discussing the baseline risk assessment in a Remedial
Investigation, the purpo.e i. defined as determining -whether the
.ite pose. a current or potential risk to human health and the
environment in the absence of any remedial action.-
The exposure
assessment in the RI -i. conducted to identify the magnitude of
actual or potential human or environmental exposure....w
The
toxicity assessment -consider. ... the types of adverse health or
potential environmental effects associated with chemical
exposure..W
In addition, the NCP states that -Superfund remedies
will.... be protective of environmental organisms and ecosystems.w
The NCP further states that if, after the remedial action i.
completed, any hazardous substances remain on a site -above levels
that allow for unlimited use and unrestricted exposure for human
and environmental receptors-, the lead Agency shall review the
30
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remedial action every five years to ensure that the environment
continues to be protected.
Finally, the decision to select a cleanup goal based on the
protection of environmental receptors exposed to site contaminants
is consistent with recommendations listed by the Science Advisory
o
Board in September 1990.
In particular, the September 1990
document titled Reducina Risk: Settina Priorities and Strateaies
for Environmental ProtectioQ provided a recommendation that EPA
.hould attach as much importance to reducing ecological risk a. it
does to reducing human health riak.
The document further de.cribes
that productive natural ecosystems are essential to human health
and to sustainable, long-term economic growth, and are
intrinsically valuable in their own right.
The No Action alternative was not chosen a. the selected or
contingency remedy because it would not be protective of the
environment and would not attain ARARs.
Specifically, EPA has
determined that actual or threatened releases of hazardous
substances from contaminated sediments in Middle Marsh and the
adjacent wetland, if not addressed by implementing the response
actions selected in this ROD, would present an imminent and
substantial endangerment to biota through aquatic and
wetland/terrestrial pathways.
Under the No Action alternative,
biota that inhabit the Middle Marsh study area would continue to be
expo8ed to PCBs at levels that would result in adverse impacts to
animals and aquatic organi8ms.
For the Middle Marsh Operable Unit,
EPA ha. determined that excavation of sediment/soils with PCB
concentrations exceedln9 cleanup level. specified in the ROD is the
only practicable alternative that would be protective of the biota
while minimizing adverse impact on the terrestrial and aquatic
eC08ystem.
Finally, the No Action alternative would not comply with the
chemical-specific ARAR8 for surface water, federal Ambient Water
Sullivan'l Ledge Superfund Site - Middle Marlh Operable unit
-------
Quality Criteria.
In addition, the No Action alternative may not
meet the requirement. of Executive Order 11990 which require. EPA
to minimize the degradation of wetland. and to preserve and enhance
the beneficial U8e8 of the wetland8.
A limited action alternative which would include fencing and
monitoring was not cho.en as the 8elected or contingency remedy for
the 8ame reasons discu88ed above for the No Action alternative.
colUUDlr 2,
It i. the view of the City of New Bedford that the
cleanup effort would have a more damaging impact on the .pecie. of
concern and other .pecies inhabiting the Site than would the long-
term affects of any PCB contamination.
The repopulation of Hiddle
Mar8h by these species would take year. and may not ever occur,
Resconse - A variety of mitigating mea8ures shall be implemented
during and after remedial action including protection of 8ensitive
species, erosion control and turbidity control.
Excavation,
backfilling and other remedial activities shall be conducted such
that the disturbance of the Spotted Turtle, a Massachusetts species
of special concern known to occupy Hiddle Marsh i. minimized.
addition, prior to initiation of remedial activities, further
. .
In
investigations will be performed to identify areas where the MY8tic
Valley Amphipods may be inhabiting.
Based on the results of such
an investigation, measures shall be planned and implemented to
minimize adverse impacts of remedial activitie., including wetland8
restoration, on the Mystic Valley Amphipod..
EPA will determine when excavation activities should be performed
by evaluating public access, weather conditions, stream flow,
scheduling con8traints and the impacts of construction activities
on the state species of concern.
32
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EPA doe. not believe that the remedial action. .elected in the ROD
will devastate Middle Marsh or its associated wildlife, including
the Massachusetts species of concern, as described in EPA responses
to comment. 2S and 26 of Section C.I. below.
COMMENT 3:
The proposed cleanup would increase the ri.k of
resu8pen8ion and redistribution of the contamination to other parts
of the site, the golf cour8e, Hathaway Road, and the Apponagansett
cl
Swamp.
ResDOnee -
Excavation and ancillary activities to be performed as
part of the selected remedy will be implemented in a manner that
mitigate. any contaminant migration downstream.
The method of
isolating contaminated sediment/soils will be determined during
design of the selected remedy, considering the need to mitigate
wetland impacts.
Because the areas to be excavated are wetlands, excavation and
associated activities will be performed to minimize adverse impacts
to wetland areas.
EPA has determined that, for this operable
unit, there are no practicable alternatives to the site preparation
and sediment/soil excavation components of the selected remedy,
that would achieve site goals but would have les. adverse impacts
on the aquatic ecosystem.
Therefore, sedimentation basins and/or
silt curtains will be installed downstream to capture any particles
that may become suspended during excavation activities.
During
excavation and dewatering of PCB-contaminated sediments, downstream
monitoring of surface water will be conducted to ensure that
transport is not occurring a. a result of the excavation.
Excavated areas shall be isolated by means of erosion (e.g.
sandbags, haybales or earthen dikes) and sedimentation control
devices (i.e. sedimentation basins), and diversion structures.
Sullivln's Ledge Superfund Site - Middle Mlrlh Operlble Unit
-------
COIOCEN'l' 4:
Due to the mature vegetation in Middle Marsh,
restoration of the marsh to state and federal standards may not be
pouible.
Resoonse -
The restoration proqram will be developed durinq design
of the .elected remedy to replace wetland function. and habitat
areas.
Thi. program will identify the factors which are key to a
successful restoration of the altered wetlands.
The Wetlands
Restoration Plan will evaluate utilizing the spotted turtle and the
mystic valley amphipod as biological indicators to measure the
success of restoration.
ractors may include, but not necessarily
be limited to, replacing and regrading hydric soils, provisions for
hydraulic control and provision. for vegetative reestablishment,
including transplanting, .eeding or .ome combination thereof.
Quality assurance measures shall include; (1) detailed topographic
and vegetative surveys to ensure replication of proper surface
elevations and vegetation; (2) engagement of a wetland replication
specialist; (3) establishment of work area limits for equipment to
prevent inadvertent placement of fill; (4) production of a
reproducible base map and a detailed planting 8cheme; (5)
photographic documentation.
EPA has determined that, for this Site, there are no practicable
alternatives ~o the selected remedy that would achieve site goals
but would have less adverse impacts on the aquatic ecosystem.
Unle8s sediment/soils with contaminants greater than the target
levels are excavated, the contaminants in the sediment/eoils would
continue to pose unacceptable environmental ri.ks.
EPA believes that the remedial activities to be implemented at the
site which will include 8teps to minimize the destruction, 10S8, or
degradation of wetlands and to restore impacted wetlands, as
described above, will comply with federal and 8tate ARARs relating
to wetlands, including the Executive Order 11990.
J,
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EPA believe. that the Wetland Re8toration Plan will meet all .tate
and federal .tandard., as further de.cribed in EPA'. re.pon.e to
Comment 27 in Section C.l. below and re.pon.e to Comment 4 in
Section C.3. below.
COMMENT 51
The City ob.erved that the cleanup levels .elected for
the Middle Mar.h Operable Unit are generally lower than the cleanup
objectives propo.ed at the New Bedford Harbor Superfund Site.
RESPONSE -
The cleanup level. e.tablished in the ROD are ba.ed on
.ite-.pecific factor. including total organic content, organic mat
coverage, depths of overlying water and other sediment/.oil
characteri.tic..
Total organic content i. a particularly important
parameter because it indicates the extent to which contaminant. may
be available for uptake by the biota.
Detailed phy.ical, chemical and biological information was
collected and evaluated for Middle Mar8h to identify aquatic and
wetland/terre8trial expo8ure pathwaY8 critical to the tran8fer of
PCBs in Middle Mar.h and the adjacent wetland.
In particular, PCB
ti8.ue data of indigenous biota from the .tudy area was evaluated
to determine the extent to which accumulation of PCBs wa. occurring
at the 8ite.
Conclusions drawn from evaluation of the information
di8cussed above are pertinent only to the Middle Marsh Operable
Unit.
Cleanup. level. derived to be protective at other .ites may
be significantly different from the levels established at this site
because any Dumber of factor. may be different than tho.e at the
Middle Marsh Operable Unit.
Thi. ROD doee not attempt to e8tablish ecological-risk based
cleanup levels for PCBs to be achieved at all superfund site..
Both human health and ecological risk assessment must be performed
at each site to determine endangerment to human health and the
Sullivan'. Ledge Superfund Site - Middle M8rsh Operable Unit
-------
environment baaed on aite-specific factors including receptors,
exposure pathways and site characteristic..
The New Bedford Harbor Superfund Site i. significantly different
from Sullivan'. Ledge becau.e it i. a .altwater environment with
uniquely different sediment substrate, overlying water and
environmental receptor..
Therefore, it ia expected that PCB
cleanup levels estahli.hed for the ~wo .ites would be different not
the .ame.
COMMENT 61
The City argued that, .ince the potential for
additional contaminant. reaching the marah cannot now be determined
with reaaonable certainty, EPA .hould wait and re-evaluate the .ite
at a later date before spending the large sums of money proposed
for the Middle Marsh cleanup.
RESPONSE -
The remedial investigation and feasibility Itudy
(RIfFS) study process, as outlined in the -Guidance for Conducting
Remedial Investigations and Feasibility Studies under CERCLA-
represents the methodology that the Superfund program has
establi.hed for characterizing the nature and extent of risks posed
by uncontrolled hazardou. waste site. and for evaluating potential
remedial optiona,
The objective of the RIfFS process is to gather
information .ufficient to .upport an informed risk management
deci.ion regarding which remedy appears to be most appropriate for
a given .it..
The Sullivan's Ledge Superfund Site, including the Middle Marsh
Operable Unit, ha. been the .ubject of Phase I (Ebasco, 1987) and
Phase II (Ebasco, 1989a) remedial investigation. and a feasibility
.tudy (Ebasco, 1989b) which was completed in January 1989.
The
remedial investigationa reveal that PCBs and other contaminants
have migrated from the Disposal Area to the unnamed stream and the
wetlands just north of the Diapoaal Area, including Middle Marsh
J6
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and the adjacent wetland.
EPA concluded in June 1989 that
additional studies of Kiddle Karsh and the adjacent wetland areas,
including biological studies, would be necessary to I (1) determine
with greater accuracy the nature and extent of contamination in the
area, (2) compare the potential environmental impacts of conducting
cleanup activities to the impact. of .ite contamination, and (3)
further identify any potential risk to humaD health and the
environment posed by the contamination.
o
Thu. the .tudy and
remediation of Kiddle Kar.h and the adjacent wetland area. wa.
separated into a .econd operable unit, called the Kiddle Kar.h
Operable Unit.
The -Remedial Investigation - Additional Studies of
Kiddle Karsh- was completed in April 1991 and the -Feasibility
Study of Kiddle Kar.hw was completed in Kay 1991.
EPA believes that result. derived from the completion of the
.tudies described above are conclu.ive and consistent with CERCLA,
the NCP and the wGuidance for Conducting Remedial Investigation.
and Feasibility Studies under CERCLAw.
In particular, the site-
8pecific data derived from the ecological asseS8ment indicate. that
biota that inhabit Kiddle Karsh and the Adjacent Wetland are at
risk from exposure to PCB-contaminated sediment/soils.
based on available information on the presence of .ite
Therefore,
contaminants, implementation of the selected remedy is warranted.
In addition, all monitoring data and environmental condition. .hall
be formally reviewed and evaluated during the operation of the
remedy to en.ure that appropriate response objective. are achieved.
As required by law, EPA will also review the KiddIe Karsh Operable
Unit at leaat once every five years after the initiation of
remedial action at the Kiddle Karsh Operable Unit if any hazardous
8ubstances, pollutants or contaminants remain at Kiddle Kar.h or
the Adjacent Wetland to .ssure that the remedial action continue.
to protect human health and the environment.
EPA will al.o
evaluate risk posed "by the Kiddle Karsh Operable Unit at the
completion of the remedial action (i.e., before the Site is
Sullivan'. Ledge Superfund Site. Middle Mlrsh Operable unit
-------
proposed for deletion from the NPL).
Future remedial action will
be considered if the environmental monitoring program determines
that unacceptable risks to human health and/or the environment are
posed by exposure to site contaminants.
Refer to EPA response to Comment 7, Section A.I above, for
explanation of the interaction of the groundwater remediation
component, as specified in the 1989 ROD for the First Operable
Unit, with the selected remedy for the Middle Marsh Operable Unit.
COIUlEN7' 7,
The City stated that the Middle Marsh area does not
contain suitable habitat for the spotted turtle, but that the
spotted turtle lives in the Apponagansett Swamp.
RESPONSE -
As described in Chapter 2 of the RI, the spotted turtle
is found in small, shallow water bodies, frequently basking along
the water's edge.
It is omnivorous, consuming insects, other
invertebrates, and aquatic plants underwater. During the Band 9
May 1990 field investigation, spotted turtles were observed in
Middle Marsh in the northern part of the scrub-shrub wetland area
about 500 feet from the Unnamed Stream.
B.
State CollUlleDts
The Massachusetts Department of Environmental Protection provided
oral comments at the public hearing through Helen Waldorf.
The
State did not submit any written comments during the public comment
period.
The State's oral comments are summarized below.
COIUfEN7' l:
A representative from the Mas8achusett8 Department of
Environmental
Protection stated that a no action remedy .s
recommended by other commentors would not meet the State standards
for protection of human health, and therefore the State would not
concur with such. remedy.
The State representative noted that the
3'
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State's standards for protection of human health are more stringent
than those used by EPA.
The State repre8entative explained that,
although EPA wa. requiring the cleanup of Middle Marsh for the
protection of the, environment, the State's standards would require
the cleanup for the protection of human health.
Q
. RESPONSE -
EPA acknowledges the Commonwealth's concurrence with
the selected and contingency remedies for the Middle Marsh Operable
Unit and its decision not to support the No Action alternative.
The Commonwealth of Ma8sachusetts/Department of Environmental
Protection based its decision on review of the
Remedial
Investigation, Risk As.essment and Feasibility Study in order to
determine if the selected remedy and the contingency remedy would
be in compliance with applicable or relevant and appropriate State
Environmental laws and regulations.
A copy of the declaration of
concurrence 1s attached as Appendix C to the ROD.
C.
Comment. fro. Potentiallf Re.ponsible Partie.
Written comments from PRPs, except for the City of New Bedford, are
summarized below.
Responses to comments received from the City of
New Bedford are listed in Section A.3. above.
Sullivan'l Ledge Superfund Site. Middle M8rlh Operable unit
-------
C.
POTENTIALLY RESPONSIBLE PARTY COMMENTS
1.
Comments fro~ GEI Consultants, Inc. on Behalf of Acushnet
Company, .t ale
COMMENT 1: Use of maximum exposure estimates in calculating
the human health risk are inappropriate and are inconsistent
with Superfund guidance. 'GE1 advocated use of average
exposure estimates.
ResDonse - The Human Health Risk Assessment conducted for the
Middle Marsh Operable Unit used a single set of exposure
parameters with both mean and maximum concentrations for the
chemicals of concern. It is Region 1's opinion that a
characterization of an average and a reasonable maximum
exposure, as performed at Sullivan's Ledge, is advisable and
is consistent with the NCP and EPA risk assessment guidance.
As defined in the preamble to the NCP, EPA defines "reasonable
maximum" so that potential exposures that are likely to occur
will be included in the assessment of exposures.
While the NCP and the Risk Assessment Guidance for Superfund:
Volume I Human Health Evaluation Manual (RAGS 1989) calls for
an evaluation of a "reasonable maximum exposure", the Region
I Succlemental Risk Assessment Guidance for the Sucerfund
Proqram calls for a dual analysis, part of which includes the
equivalent of the "reasonable maximum exposure" referred by
Region I in the guidance manual as a "reasonable worst-case"
exposure. While the maximum detected concentrations are
called for by the Region as part of the "reasonable worst-
case" expo'sure, other parameters that fit into the exposure.
equation (e.g. frequency of exposure) are not necessarily at-
the maximum possible values and thus the Region believes the
approach taken at this site to estimate risk is consistent
with the intent of the NCP and the EPA RAGS Guidance: .
"For Superfund exposure assessments, intake variable
values for a given pathway should be selected so that the
estimate is the reasonable maximum exposure for that
pathway. As defined previously, the reasonable maximum
exposure (RME) is the maximum exposure that is reasonably
expected to occur at a site. Under this approach, some
intake variables may not be at their individual maximum
values but when in combination with other variables will
result in estimates of the RME." (RAGS 1989 pg.6-l9).
Consequently, reliance on a maximum concentration as input
into the exposure estimates as was done at Sullivan's Ledge in
the R1 (Metcalf and Eddy, 1991a) results in an exposure
estimate that is consistent with the most recent Risk
Assessment Guidance for Superfund (RAGS).
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COHHENT 2: The human health risk assessment inappropriately
relies on PCB data from both the 1989 and 1991 Remedial
Investigations for Middle Marsh and therefore overestimates
the maximum risks.
Rest)onse - EPA's incorporation of the data from the 1989
Remedial Investigation (RI) (Ebasco 1989) and the 1991 RI was
appropriate. The hot spot concentration of 60 mg/kg
identified during the 1989 study was located near frequently
used golf course areas; it is likely that further intensive
sampling in this area would yield both higher and lower
concentrations. The 1989 data were of sufficient quality for
risk assessment. EPA does not believe that PCB concentrations
have been reduced between the 1988 and 1990 sampling periods
as PCBs continue to erode off the soils in the Disposal Area
and continue to be disposed in the wetlands. For these
reasons, EPA believes that risks are not overstated. A
discussion of trends in PCB concentrations in Middle Marsh is
presented in response to Comment NO.7.
COHHENT 3: Use of arithmetic averages of sampling data for
several substances are unreliable; these averages likely do
not reflect actual conditions.
Resnonse In calculating the arithmetic average, EPA
excluded e1evate~ detection limits in order to avoid biasing
the mean, (i.e. overestimating or underestimating the average
concentration). For example, a value measured at an elevated
detection of <3 ppm may have a true value anywhere from 0 to
2.9 ppm. If the true value was on the high end (close to 2.9
ppm) then, use of this data point at one-half the detection
limit would be an underestimation of the true value. .
Alternatively, if the true value was on the low side (close to'
o ppm) then, use of the data point at one-half the detection
limit would be an overestimation of the true value. This
possibility of over- and under-estimation of the true values
is increased when evaluating use of data with high detection
limits. In this case, the detection limits were relatively
high, elevated above detection limits used for EPA's Contract
Lab Program. For this reason, EPA believes that the decision
to exclude data points at elevated detection limits was
reasonable.
It is important to note that this approach was only used when
the detection limits were at values greater than the contract
lab required detection limits.
GEI assumes that "low concentrations" were necessarily omitted
in the calculation of the arithmetic mean. However, as stated
above, in those cases where there are elevated detection
limits, it cannot be assumed that the chemical in question is
necessarily present at a very low concentration; the chemical
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may be present at a concentration just below the elevated
detection limit. .
The data used in the risk assessment went through the contract
laboratory program (CLP) data validation, and no rejected data
were used in quantifying risk, including data generated from
the analyses for PAHs. As stated in the Chapter 5 of the RI,
some uncertainty exists regarding the identification of
benzo(b)fluoranthene and benzo(k)fluoranthene. On occasion,
the analytical method could not distinguish between these two
isomers and the reported results represented the total
concentration of these two compounds. When this occurred, the
total concentration was divided in half and assigned to each
isomer. Some questions regarding Aroclor identity also arose".
The 26 PCB sediment/soil samples from Middle Marsh obtained
from the Phase II Remedial Investigation (EBASCO 1989)
underwent REM III laboratory analysis for Aroclor 1254 and 4
samples underwent CLP confirmatory analysis results for total
PCBs. The data from both analyses were used, and the CLP
resul ts were assumed to represent Aroclor 1254. However,
despite these data uncertainties, because of the way in which
risk to these chemicals is estimated (total PAHs and PCBs)
these data uncertainties and simplifying assumptions have no
outcome on the risk assessment results.
COMMENT.. : Exposure frequencies for contaminants in the
Middle Marsh are overestimated, and future land-use
assumptions are inconsistent with the ecological risk
assessment.
ResDonse - EPA does not agree that the exposure frequencies
used in the risk assessment were overestimates and that future"
land-use assumptions were inconsistent with the ecological'
risk assessment.
As stated in the preamble to the NCP:
"In general, the baseline risk assessment will look at a
future land use that is both reasonable, from land use
development patterns, and may be associated with the
highest risk, in order to be protective. These
considerations will lead to the assumption of residential
use as the future land use in many cases. The analysis
for potential exposures under the future land use
conditions is used to provide decision makers with an
understanding of exposures that may potentially occur in
the future."
EPA believes that the exposure frequencies for contaminants in
Middle Marsh are not overestimated. Specifically, the
exposure frequencies are not based on a future residential use
(which would have resulted in much lower cleanup levels) but
are based on the continuing use of the Middle Marsh area for
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recreation/conservation. Furthermore, an estimate of 56 days
per year (a little more than once per week; or 2 days per week
during the months of April to October) as a future exposure
frequency is an estimate of exposure frequency that may
potentially Occur to golfers and maintenance workers in Middle
Marsh. As stated in the RI, golfers and maintenance workers
in Middle Marsh and the Adjacent Wetland may be in fairly
constant contact with the PCB-contaminated sediments for the
purposes of retrieving golf balls and maintaining the golf
course. The human health risk assessment is not based on
exposure to hikers and nature lovers.
It is certainly possible that portions of the marsh will be
drier at some point in the future due to natural processes.
EPA has reasonably assumed that such a condition could result
in increased human contact with soil and sediment in the
Middle Marsh area. EPA does not believe that a drier Middle
Marsh would preclude the existence of the aquatic and
wetland/terrestrial exposure pathways presented in the RI.
The Unnamed Stream would still exist and could support mink
and other species included in the ecological food chain model,
such as small mammals. Therefore, EPA does not agree that its
assumptions were inconsistent.
COMMENT 5: Assumed levels of exposure to contaminated soils
and surface waters overestimate realistic human exposures.
ResDonse - The soil ingestion rate of 100 mg/day for an adult
human is standard EPA policy (OSWER Directive 9850.4). Based
on a review of the available literature, EPA Headquarters
determined that this value (100 mg/day) for an older child or
adult corresponds to upper bound values on the amount of soil..
and indoor dust ingested by these age groups.
Assumptions regarding contact with surface water were
conservatively made in order to protect maintenance workers or
other individuals who could spend a day retrieving golf balls
from the marsh. In actuality, this pathway was insignificant
with respect to risk to human health.
COMMENT., The human health risk assessment for PARs in the
SUpplemental Remedial Investigation (SRI) is based on
unrealistic and inaccurate factors.
ResDonse - The use of the benzo(aJpyrene cancer potency
factor as a surrogate for all known and suspected carcinogenic
Polycyclicaromatic hydrocarbons (cPAHs) is consistent with
current EPA guidance and operational procedures. It is done
in the absence of EPA validated health criteria for other PAHs
besides benzo(a)pyrene (B[aJp). The Carcinogen Assessment
Group of EPA has not yet made a recommendation with respect to
a Toxic Equivalency Factor (TEF) approach for PAHs which would
-------
apportion risk on a chemical by chemical basis relative to the
potency of B(a]P and may not apply the B(a]P potency factor to
all CPAHS. However, until such recommendations and/or
guidance are finalized, it is not the policy of EPA Region I,
at this time, to use the TEF approach for PAHs, including the
application of the potencies listed by GEI in Table 1.
As stated in EPA Region I guidance, use of the carcinogenic
potency factor of B(a]p for carcinogenic PAHs may result in
overestimation of risk because B(a]P is considered to be one
of the most potent of the carcinogenic PAHs, and B(a]p is
likely to constitute only a fraction of the mixture of
carcinogenic PAHs present at a site. On the other hand, other
PAHs that are not routinely analyzed for at Superfund sites
may be carcinogenic. Thus, this approach may not account for
some carcinogenic PAH constituents because they haven't been
identified or classified by EPA as having carcinogenic
potential. Based on the above, EPA believes that, at this
point in time, the carcinogenic potency factor derived
specifically for B(a]p and used for numerous PAHs in the
Middle Marsh Risk assessment is a reasonable approach in
determining risks posed by exposure to total carcinogenic PAHs
and is consistent with both regional and headquarters
guidance.
COMMENT 7: The concentrations of PCBs measured in Middle
Marsh are not high and have significantly decreased since the
measurements reported in the 1989 Remedial Investigation
report for Sullivan's Ledge site.
ResDonse - EPA has concluded that PCB concentrations in.
Middle Marsh are high when compared to background levels and.
calculated cleanup levels for the protection of the
environment. EPA has determined that actual or threatened
releases of hazardous substances from contaminated sediments
in Middle Marsh and the Adjacent Wetland, if not addressed by
implementing the response action selected in this ROD, may
present an imminent and substantial endangerment to biota
through aquatic and wetland/terrestrial pathways.
EPA does not agree that dramatic reductions in PCB
concentrations have occurred in Middle Marsh. PCBs in the
environment are generally resistant to physical and biological
degradation and have a high affinity for organic material such
as the sediment/soil in Middle Marsh. Sampling data from the
RI (Metcalf & Eddy, 1991a) indicate that PCBs are present
throughout the surface sediment/soil in most of Middle Marsh
and the Adjacent Wetland and are present at concentrations
near 10 mg/kg at depths of up to two feet, as shown at
stations ME1, ME14, ME1S, and SL38. In addition, at SL38, a
PCB concentration of 97.0 mg/kg was found at a depth of o. S to
1.0 foot near the Unnamed Stream in the Adjacent Wetland, the
44
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highest PCB concentration detected in all studies associated
with the Middle Marsh operable unit.
EPA has determined that the PCB concentrations downstream of
Hathaway Road are due to long-term releases of contaminated
soils from the SUllivan's Ledge Disposal Area. As shown by
Ebasco (1987), soil PCB levels at the surface of the Disposal
Area are 1000 ppm in areas near the Unnamed Stream. On
numerous occasions such as during hydrologic monitoring
performed for the Remedial Investigation, EPA's consultants
observed flooding of Middle Marsh with extremely turbid water
from the Unnamed Stream, ponding of floodwaters in Middle
Marsh, and deposition of sediments in areas found to have the
highest PCB concentrations. As long as these sediments and
soils are uncontrolled, they will continue to act as a source
of PCBs to downstream areas including Hiddle Marsh.
PCB concentrations have not decreased significantly since the
1989 Remedial Investigation. The S4 percent annual rate of
reduction between 1988 and 1990 cited by GEI would have
reduced PCBs in Middle Marsh to near zero over several years.
The data show that this has not occurred. Additional
statistical examination of surface PCB concentrations from the
two data sets reveals that no statistical reduction in PCB
concentrations has oCcurred. The 1988 samples averaged
9.26 mg/kg (n = 26) and the 1990 samples averaged 7.72 mg/kg
(n = 30). A simple t-test reveals that there is a 9S percent
chance that any difference in the means is due to chance
alone. In" addition, the Wilcoxon rank-sum test, which makes
the effect of outliers less apparent, showed a high degree of
similarity in the two data sets. The lQw degree of change
with time in the results is demonstrated by simply removing'.
the "hot spot" data of 20 mg/kg (ME1) and 60 mg/kg (MM-S) from
the data sets. The new averages are practically identical;
7.24 and 7.29 for the 1990 and 1988 data, respectively.
The extent to which certain sets of sampling stations were
paired is overstated by GEI. In the 1989 Remedial
Investigation report (Ebasco, 1989), the approximate station
locations were marked on Fiqure 5-3. EPA' s consultant sampled
the ME stations at locations near the previous MM stations
based on this information and the recollections of EPA staff
who assisted the consultant in selecting sampling stations.
For other stations such as ME6 and ME1S, it was noted in the
comments column in Table 2-9 of the RI (Metcalf & Eddy, 1991a)
that these were "close to" or "near" certain MM stations;
however, it was not intended to duplicate the results of the
previous sampling effort. Even if it were EPA's intention, it
is practically impossible to sample the exact same location
twice. Even if a sample location were duplicated, the sample
results would likely vary widely. Potential reasons for such
differences are discussed below.
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The RI (Metcalf & Eddy, 1991a), on Page 3-16, discusses
potential reasons for the variability in sampling results in
Middle Marsh. Such factors would account for differences
between years and even differences between samples collected
near each other and include "slight differences in topography,
hydrology or soil type" and the effects of storms which
deposit and redistribute sediments. It is entirely possible
that a large storm could cause substantial changes in the
location of hot spots. This high variability would make it
difficul t to document any trends in maximum PCB concentrations
in the wetland and to determine the persistence and extent of
previously identified hot spots.
EPA does not believe that dissolution, volatilization, or
biodegradation have caused significant reductions in PCB
concentrations in the study area. The Aroclor found in Middle
Marsh is Aroclor 1254, a highly chlorinated mixture of PCBs
with little solubility in water (Mackay and Wolfkoff, 1973).
In backup information presented by GEI, Yoakum & Associates
(1989) stated that, "The transport and fate of PCBs in aquatic
systems and their partitioning into different compartments of
the environment depend to a large degree on sorption reaction.
Generally, sorption increases with increase in chlorine
content of the chlorobiphenyl, and with surface area and
organic carbon content of the sorbent." TOC and grain size
analysis have shown that the sediment in Middle Marsh has a
very fine grain size and thus high surface area, and a very
high organic content. Griffin and Chian (1980) indicate that
the total solubility in water is approximately 70 ~g/l. EPA's
consultant generally found less than 1 ~g/l dissolved PCB in
the pore water and surface water in Middle Marsh indicating
that the PCB at this site is partitioned into the solid.'
sediment matrix. While it is true that the lower chlorinated
Aroc10rs have some solubility in water, the more toxic and
readily bioaccumulated hexa- and' hepta-chlorobiphenyls are
common in Aroclor 1254 and do not dissolve readily in water.
Similarly, it is only the mono, di, tri, and a few tetra
substituted isomers in Aroclor 1254 that have vOlatility.
However, Aroclor 1254, the Aroclor found in Middle Marsh, has
predominantly tetra, penta, hexa and other higher isomers that
are much less volatile. Binding of PCBs to solids reduces the
amount of PCB that volatilizes (Griffin et al., 1978). Reuter
and Have1icek (1978) found that the amount of volatility from
water depends on the humic acid condition and the Ph. Meng,
et a1. (undated) found 3.5 percent volatilization of PCB from
water, 2.6 percent volatilization from water with humic acid,
and 0.74 percent when in suspension with soil. Yoakum &
Associates (1989) stated that "In environmental samples where
PCBs are sorbed on soil or sediment surfaces, the rate of
volatilization is greatly reduced and depends upon the
sorption surface". Because the PCBs in Middle Marsh were
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deposited with sediment, the PCBs were already adsorbed to
silty organic wetland soils which are high in humic acid,
greatly reducing the volatility and solubility of the PCBs.
Further, EPA does not believe that significant biodegradation
has occurred in Middle Marsh, as described in response to
Comment 31. This is confirmed by examinations of several
chromatograms from Middle Marsh which did not exhibit
dechlorination.
Research performed in the New Bedford Harbor which indicates
that volatilization is the most significant process occurring
at that site (as described by GEI), cannot be directly applied
to the Middle Operable Unit. As stated above, the degree to
which PCBs volatilize is dependent upon the sorbent reaction
and sediment characteristics such as surface area and organic
carbon content. These variables may be significantly
different from site to site, even within the same site. For
e"xample, TOC variability within the Middle Marsh area has
indicated over a ten fold difference in the range of values.
Furthermore, as stated by GEI, a substantial amount of PCB
that entered the water column in the harbor subsequently
volatilized to the atmosphere. However, as described above,
less than 1 ~g/l dissolved PCB was measured in the pore water
and surface water in Middle Marsh indicating that the PCB at
this site is primarily partitioned into the solid sediment
matrix.
COMMENT 8: Not all elevated concentrations of contaminants
appear to be originating from the Sullivan's Ledge Site.
ResDonse EPA has determined that the elevated PCB."
concentrations in Middle Marsh and the Adjacent Wetland, which
are the subject of this ROD, have migrated from the Disposal
Area. This was determined, in part, by comparison to
background PCB concentrations from samples collected at
stations ME8 and ME20 during the SRI and samples SL-SO-401 and
SL-SO-402 (Ebasco, 1987) in which PCB concentrations ranged
from 0.71 to 1.4 mg/kg. PCB concentrations at these levels
could be the result of historical waste disposal activities at
SUllivan's Ledge and perhaps trace amounts from airborne
contaminants from Sullivan's Ledge or other sources including
the New Bedford municipal landfill. The PCB concentrations in
Middle Marsh and the Adjacent Wetland are significantly above
these background levels and are, on average, an order of
magnitude higher. Further, contamination patterns in these
areas matched what would be expected if the source of
contamination was from upstream areas (i.e., the Sullivan's
Ledge Disposal Area) (Metcalf & Eddy, 1991a, Boucher et al,
1990).
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GEI has mis~akenly identified station SL-Sl as a background
station. Station SL-Sl was not a background station and is
not elevated on a golf tee but rather was located just a few
feet from the Unnamed stream, well within the 100-year flood
area. Delineation of areas of various flooding frequencies
was truncated in Figure 2-6 of the RI at the edge of the map
in order to stay within the mapped area and the page border.
Field observations from a site visit on August 8, 1990
confirmed that this area is subject to flooding during storms
below the 100-year frequency and, therefore, PCB values
detected at this station can be attributed to the transport of
PCBs from the Sullivan's Ledge Disposal Area via the Unnamed
Stream.
EPA found no sources of significant urban runoff other than
the Unnamed Stream and does not believe that the heavy metals
found in interior areas of Middle Marsh have their source in
areas other than Sullivan's Ledge and the urbanized drainage
area. In addition, it is very unlikely that elevated PCB
concentrations are due solely to urban runoff sources and are
not associated with a source of PCBs such as the Sullivan's
Ledge Disposal Area. EPA believes based on field observations
and the results of hydraulic modeling. presented on Figure 2-6
of the RI (Metcalf & Eddy, 1991a), that these pockets of
elevated lead concentrations have formed in depositional areas
and that concentrations are slightly less in areas near the
stream due to higher water velocities. A similar pattern was
observed for PCBs as shown in Figures 3-1 and 3-4 in the RI
(Metcalf' Eddy, 1991a).
COMMENT' : EPA' s withdrawal of the original "no action"
remedy appears to have been based on an erroneous comment, the'
contents of which were not even addressed in the SRI. '.
.
The Carr memo incorrectly infers that statistical
probabilities relating to the Sediment Quality Criterion
(SQC) correspond to probabilities of harm to benthic
orqanisms
.
The SQC for PCBs is designed to protect mink, not benthic
organisms
ResDonse - GEI has mischaracterized the history of EPA' s
consideration of remedial approaches for the Middle Marsh
Operable Unit. EPA had never made a final de~ermination on a
"no actionH remedy. In February, 1989, as part of a site-wide
remedy, EPA DrODosed a no action alternative for Middle Marsh.
In the 1989 Proposed Plan, EPA noted that two other action
alternatives were still under consideration. EPA specifically
sought public comments on how to achieve a protective remedy
for the Middle Marsh area, particularly in balancing the need
to remove contaminants from the Marsh and the need to protect
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a functioning, valuable wetland from temporary disruption. At
the end of the public comment period, based in part on
comments received over the previous year and in part on
further consideration within EPA of the issues, in its 1989
decision, EPA decided that further data was needed,
particularly site-specific data on bioaccumulation and a more
complete understanding of the aquatic and terrestrial
organisms in the Marsh ecosystems. EPA now has this data.
Based on these more comprehensive studies, EPA has enough
information to make a reasoned careful decision that is
consistent with CERCLA, the NCP and EPA's guidance.
EPA decided to re-assess its decision to select the no action
alternative as the preferred alternative in part because of
concerns raised by federal and state agencies over potential
long-term impacts to trustee species and other resources. The
U.S. Department of Interior (DOI) and the Massachusetts
Department of Environmental Protection raised concerns that if
the PCB-contaminated sediments in Middle Marsh are not
excavated, they may continue to pose a long-term threat to a
variety of aquatic and terrestrial organisms that inhabit the
Middle Marsh area. The additional studies conducted during
the RI (Metcalf & Eddy, 1991a) showed that PCBs in Middle
Marsh pose an unacceptable risk to site biota and EPA has
determined that in order to be protective of the environment,
contaminated sediment/soils must be excavated.
J
Sediment quality criteria (sQC) are designed to ensure that
benthic organisms are not exposed to bioavailable
concentrations of chemicals greater than what is currently
allowed by existing water quality criteria. In the case of
PCBs, EPA has determined that, for Middle Marsh, the.'
appropriate water quality criterion with which to derive
protective SQC Marsh is 0.014 ug/l PCBs. The approach used by
EPA to derive protective cleanup levels for the aquatic area
in Middle Marsh is described in response to comment 14. .
COMMENT 10: The SRI and FS studies for Middle Marsh assume
that the PCB concentrations pose an unacceptable risk to
female mink in the Marsh. However, there is no evidence that
any mink, female or male, inhabit the Marsh.
Rescons. - Comments 10 through 14 relate to the use of mink
as an indicator species in the ecological exposure assessment
for Middle Marsh. The following paragraphs describe EPA's
overall approach and rationale for the ecological exposure
assessment which was conducted by EPA's consultant according
to EPA guidance.
The objectives of the ecological exposure assessment of Middle
Marsh (Metcalf & Eddy, 1991a) were to 1) define the ecological
conditions of the stUdy area, 2) identify appropriate
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remediation goals, 3) determine how remediation would affect
the study area, and 4) provide information for mitigation. To
help meet these objectives, EPA's consultants conducted
ecological site investigations consisting of wetland
delineation, wildlife observations, and a-habitat assessment.
From this information it was determined that Middle Marsh was
dominated by palustrine forested wetlands, palustrine scrub-
shrub wetlands, and emergent wetlands. These areas are
suitable habitat for a variety of wildlife species including
small insectivorous birds, small mammals, amphibians, - and
reptiles.
To assist in the identification of potential exposure
pathways, an ecological food chain pathway model was developed
(Figure 2-11 of the RI). Species included in this model were
species that were either observed on site or were expected to
occur on site based upon historic occurrence, habitat
requirements, food availability, home range requirements, and
the likelihood of exposure. Mink were included in the
ecological food chain pathway model because: Middle Marsh
provides the basic habitat requirements for mink: minks are
known to be susceptible to PCBs (Platonow and Karstad, 1973:
Eisler, 1986): and the mink is a top level consumer in an area
where site-specific data (Charters, 1991) showed that many of
its food sources are contaminated with PCBs.
Mink are expected to use the site because they have
historically occurred in the region (DeGraaf and Rudis, 1983).
While the Middle Marsh system is not considered by EPA to be
"optimum" mink habitat as defined by Allen (1986) and as
modelled in the RI (Metcalf & Eddy, 1991a), it is nevertheless
suitable for mink inhabitation as defined by the presence of.
life requisites. Allen (1986) stated that "the species is
tolerant of human activities -and will inhabit suboptimum .
habitats as long as an adequate food source is available".
Mink food preferences are varied, and can be classified into
1) aquatic (e.g. fish, frogs and crayfish): 2) semi aquatic
(e.g. waterbirds and water associated mammals): and 3)
terrestrial (e.g. rabbits and rodents) (Allen, 1986). The
importance of each group depends upon availability and season
(Linscombe et a1. 1982). EPA' s observations and site-specific
studies (Charters, 1991) indicate that Middle Marsh and the
adjacent wetlands have relatively high populations of these
prey t-ypes, particularly high numbers of frogs and small
rodents.
Minks have recently been sighted in nearby areas, including
the Apponagansett Swamp, and as road kills in the neighboring
town of Dartmouth, Massachusetts. In addition, following the
receipt of comments by GEI and others on the occurrence of
mink in Middle Marsh, EPA's consultants conducted a site visit
on August 26, 1991. During this investigation, mink tracks
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were observed and photographed in Middle Marsh near the
Unnamed Stream. The mink tracks were identified by a
certified wildlife biologist (petron, 1991). In addition, a
number of potentially suitable mink den sites were observed
and photographed. Tracks of other small mammals were also
observed. 'This information has been added to the
administrative record.
Secondly, mink was used in the pathway model because it is
representative of other sensitive species. Mink are
. particularly sensitive to PCBs. Platonow and Karstad (1973)
found in a study of dietary effects, that mink feeding at a
level of 0.64 ppm Aroclor 1254 for 160 days either died, were
extremely weak, or produced young all of which died during the
first day after birth. Therefore, consistent with EPA
guidelines (EPA, 1989), EPA included the mink in the
ecological exposure assessment and based protection of the
ecosystem and development of remediation criteria (cleanup
levels) on this key sensitive indicator species. As a top
level predator in the marsh, protection of mink would ensure
achievement of the goal of ecosystem integrity and balance.
Furthermore, the known susceptibility of mink would provide a
margin of error for protection of a variety of environmental
receptors for which toxicological data is not known. The use
of mink, a species known to be sensitive to PCB, is consistent
with EPA guidance. As stated on Page 3-20 of EPA's "Risk
Assessment Guidance for Superfund -- Environmental Evaluation
Manual (EPA/540/1-89/001) , "Ecologists will often use
professional judgement to select a particular organism as an
'indicator species', that is, a species thought to be
representative of the well-being and reproductive success of
other species in a particular habitat. The indicator species.
may also be chosen because it is known to be particularly
sensitive to pollutants or other environmental changes." In .
the absence of complete toxicological data of the effects of
all pollutants and contaminants on the myriad species found in
Middle Marsh, it is reasonable to extrapolate information
known about a particularly sensitive species.
The exposure assessment for mink involved the development of
appropriate exposure parameters. EPA determined that because
of the mink's high trophic level, dietary exposure would be
the primary exposure pathway. Analysis of the habitat, prey,
and home range requirements suggests that mink using the site
may either live, breed, and feed on-site, or live off-site and
feed on-site. Densely vegetated wetlands are the preferred
habitat of mink (Allen, 1986); Middle Marsh contains such
habi tat. There is an abundance of preferred mink prey
available, in the form of small mammals, frogs, and small
birds (Linscombe et al., 1982; Allen, 1986). Although on the
lower end of home range sizes, the Middle Marsh and
surrounding habitat is of sufficient size to support mink
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because of its dense habitat and abundant prey. Gerell (1970)
and Allen (1986) report that most minimum home ranges
documented in the literature can be attributed to situations
of dense cover and/or high prey abundance. Mink often
concentrate their feeding in core areas wi thin their home
range. These core areas usually are characterized by high
prey densities and are in relatively close proximity to
streams (Allen, 1986). Given the existence of the stream
which could represent a core feeding area for mink and the
apparent susceptibility of female mink to the lethal and
chronic reproductive effects of dietary PCB exposure, EPA
determined that the use of the female mink's home range of 20
acres was appropriate. Further, given the short time period
(160 days) for the adverse effects of PCBs to occur, EPA
decided not to calculate the mink's dietary exposure as an
annual average but to address seasonal changes in the mink's
diet which could influence its exposure. Accordingly, EPA
determined that in Middle Marsh, the mink's winter diet would
consist mainly of small mammals. .
Based on site-specific data for sediment/soils and biota
(Charters, 1991), a sediment/soil cleanup level of 15 mg/kg
was calculated for wetland/terrestrial areas of Middle Marsh.
The cleanup level of 15 ppm was designed to protect mink and
other potentially sensitive species from chronic health
effects from PCB exposure and to restore the area as viable
habitat where mink and other species sensitive to PCBs may
exist and breed. Use of mink as an indicator species may
ensure protection of other sensitive species for which
toxicological data does not exist. This cleanup level is also
protective of carnivorous and insectivorous birds whose
calculated cleanup levels were 25.5 and 29.2 mg/kg,
respectively. A cleanup level of 15 mg/kg would also result.
in removal of sediments above cleanup levels developed for
birds such as those at stations ME22 (28 mg/kg), ME38 .
(32 mg/kg), and SL56 (34 mg/kg). A detailed discussion of
development of cleanup levels for aquatic areas of Middle
Marsh is provided in response to comment 14.
EPA applied the cleanup level on a point-by-point (never to be
exceeded) basis, rather than reducing the average site
contaminant concentration to the cleanup level. This method
ensures that the mink's dietary level will not exceed
0.64 ppm, which was found to cause reproductive failure and
even death, and which is the basis for the ambient water
quality criterion and sediment quality criterion for PCBs.
EPA believes this ~ethod is especially appropriate for Middle
Marsh, and is appropriate for mink and other species with
feeding habits similar to mink which concentrate their feeding
in a core area.
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COMMENT ~~: Ranges and territorial habits of the mink would
indicate that, at most, only one mink would feed in the Marsh.
ResDonse - EPA agrees that Middle Marsh would be Used by 8
small number of mink at a time based on home range
requirements.' However, EPA disagrees with GEI's assertion on
the use of a larger home range for mink, and that the mink's
solitary and "shy" nature would preclude its presence in
Middle Marsh. As discussed in detail in response to comment
10, EPA has determined that Middle Marsh will support mink and
that the Use of a minimum home range is appropriate. Further,
EPA believes based on field observations and recent literature
that the use of a 6S percent residence time is appropriate.
The mink is primarily nocturnal (Gerell, 1969; Linscombe et
81, 1982) and tolerant of human activity (Godin, 1977; Allen,
1986). The daytime Use of the surrounding golf course would
not deter mink from travelling to and from Middle Marsh. The
Unnamed Stream traverses the fairways on both sides of Middle
Marsh, and with its associated vegetation and cover would
provide a secure travel corridor between Middle Marsh and the
Adjacent Wetland and/or the Apponagansett Swamp (Petron,
1991). Finally, EPA disagrees with GEI's assertion that
because mink have highly developed day vision they are more
active by day and thus would be disturbed by golf course
activity. It is well established that mink are primarily
active at night (Allen, 1986; LinscOmbe, 1982; Gerell, 1969).
Many primarily nocturnal carnivores have well developed day
vision. .
It must be noted that the rationale for the cleanup is not to
protect one female mink but to restore the area as viable
habitat where mink and many other species sensitive to PCB may.
exist and breed. Under CERCLA, EPA must ensure that its
actions provide overall protection of the environment. EPA's
objective is to restore Middle Marsh such that it will support
all life functions for a balanced indigenous population
including top level predators such as the mink, other
mustelids, and other sensitive species for which there
toxicological data does not exist. EPA acknowledges that the
overall effects may not be immediate and dramatic, but they
are nonetheless important. For example, the removal of top
predators could result in increased numbers of small mammals
such as mice, which are known to be present in Middle Marsh.
As mice feed predominantly on seeds, this could result in
reduced diversity of plant species and, as a direct resUlt, a
reduced diversity of animals such as birds that require
certain plants as habitat.
EPA has determined that excavation of a portion of Middle
Marsh is necessary to ensure that mink and other sensitive
species can exist and breed. This approach is consistent with
the recommendations of EPA's Science Advisory Board, as
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articulated in the report entitled Reduci'ng Risk: Setting
Priorities and Strategies for Environmental Protection,
September 1990 (SAB-EC-90-021). That reports states:
"Ecological systems like the atmosphere, oceans and
wetlands have a limited capacity for absorbing the
environmental degradation caused by human activities.
After that capacity is exceeded, it is only a matter of
time before those ecosystems begin to deteriorate and
human health and welfare begin to suffer.
In short, beyond their importance for protecting plant
and animal life and preserving biodiversity, heal thy
ecosystems are a prerequisi te to heal thy humans and
prosperous economies. Although ecological damage may not
become apparent for years, society should not be blind to
the fact that damage is occurring and the losses will be
felt, sooner or later, by humans. Moreover, when species
and habitat are depleted, ecological health may recover
only with great difficulty, if recovery is possible at
all. While the loss of species may not be noticed
immediately, over time the decline in genetic diversity
has implications for the future health of the human
race."
COKHEN'l' 12: The habitat ranges for mink and other animals
which EPA considers to be potentially present are applied
inappropriately and inconsistently across the Marsh in the
computation of the ecological risk. Therefore, the exposure
predictions are excessive and biased.
Response - EPA conducted the ecological exposure assessment.
for Middle Marsh by making assumptions for home ranges, food
source, and other parameters based on the most recent,
available scientific information. Based on the most recent
literature, EPA believes that home ranges for mink and other
species addressed in the ecological exposure assessment were
applied appropriately. GEI asserts that mink feed in equal
proportions over their entire home range. However, as
described in response to comment 10, mink have a core area
wi thin their home range in which they do most of their
feeding. The core area (and the home range) is smaller in
areas of high prey density. This core area is also usually
associated with a stream (Allen, 1986). According to Whitaker
(1980), when mink inhabit areas along rivers, creeks, lakes,
ponds, and marshes (such as Middle Marsh), their exposure
would be weighted toward streambank areas. At this site, the
streambank areas are not evenly distributed throughout Middle
Marsh and the surrounding area. Two intensive sampling
programs have demonstrated that the areas of highest
contamination are close to the Unnamed Stream in both Middle
Marsh and the Adjacent Wetland. Thus, adjusting the cleanup
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level based on the size of Middle Marsh compared to the mink's
home range (13/20 = 0.65) was reasonable and not overly
conservative.
EPA disagrees with GEI's suggested use of an averaged
bioaccumulation factor for earthworms. In the conduct of the
ecological exposure assessment, EPA decided to Use available
site-specific data to develop bioaccumulation factors (BAFs).
For small mammals, the BAF of 0.07 was based on an average of
tissue levels from eleven animals captured at two different
stations. However, for earthworms, there were only two data
points and EPA was concerned that BAFs for earthworms could
significantly exceed 0.29, the higher of tile two values.
Comparative literature values showed high variability which
contributed to uncertainty in the analysis. In this case, EPA
decided to select the higher value because of the low
confidence in averaging only two values.
COMMENT 13: The mink's average dietary concentration of PCBs,
if obtained solely from food sources in Middle Marsh, will be
lower than the dietary concentration used in the derivation of
the sediment quality criterion.
Resnonse - The selected cleanup levels of 20 ~g PCB/gram
carbon for aquatic areas and 15 mg/kg for all other wetland
areas were not designed to reduce the average contaminant
concentration to the cleanup level. Under EPA policy, the
developed cleanup levels were applied on a point-by-point
(never to be exceeded) basis rather than a site average to
ensure that future exposure will fall below accepted limits,
regardless of where the animal spends its time or obtains its
food.
EPA does not agree with the food chain exposure assumptions.
presented by GEI in that a nUmber of assumptions used in the
calculations are inappropriate for Middle Marsh. EPA and its
consul tants conducted a variety of biological studies in
Middle Marsh in order to determine appropriate parameters for
calculation of food chain exposure. Several technical
arguments are presented below:
.
The habitat evaluation conducted by EPA's consultant
determined that Middle Marsh is poorly suited to muskrat.
Thus, EPA does not believe it appropriate to attribute
47 percent of the mink's diet to voles and muskrat.
Based on site-specific data, EPA does not agree with the
selected bioaccumulation factor (0.02) for voles and
muskrat. Tissue data from meadow voles collected near
the Unnamed Stream by EPA (Charters, 1991) indicate
bioaccumulation factors ranging from 0.05 to 0.21.
.
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.
EPA does not agree with the use of area averaged PCB
concentrations.. Cleanup levels were applied on a point-
by point (never to be exceeded) basis. EPA believes this
method is especially appropriate for Middle Marsh, and
for mink and other species with feeding habits similar to
mink which concentrate their feeding in a core area.
In addition, ~he method presented by GEI: (1) uses an annual
average diet approach which EPA believes is inappropriate; and
(2) fails to consider exposure to the PCB Aroclor that is
actually present at the site. Exposure to the lower
chlorinated Aroclors such as Aroclor 1016 does not produce
toxic effects (as described in the material provided by GEI),
as the congeners present in Aroclor 1016 are readily
metabolized and are not bioaccumulated. Toxicological studies
of mink and other species feeding on the more highly
chlorinated Aroclors, such as Aroclor 1254 (the contaminant at
Middle Marsh) have shown that sublethal and even lethal
effects from relatively low dose.s. of PCB can occur in
significantly less than a year. Platonow and Karstad (1973)
found in a study of dietary effects, that all adult mink died
wi thin 105 days of dietary exposure to 3.57 ppm of PCB Aroclor
1254, the same Aroclor present in Middle Marsh. In the same
study, mink feeding at a level of 0.64 ppm for 160 days either
died, were extremely weak, or produced young all of which died
during the first day after birth. In addition, the short time
period for manifestation of health effects could be a
significant threat to mink young who remain together from late
April/mid-May until fall (Linscombe et al., 1982). It is for
this reason that EPA examined the winter diet of mink
separately. Given the relative unavailability of frogs and
other aquatic species during New England winters, the Dink's.
winter diet could consist almost exclusively of small mammals.
This pathway was used to derive the cleanup level presented in
the. RI (Metcalf & Eddy, 1991a).
Further, EPA recognized uncertainty by using the "lowest
observed effect level" (LOEL) of 0.64 ppm as a protective
dietary level rather than a "no effects level". As described
above, the LOEL of 0.64 ppm in diet was shown to cause death
and reproductive failure in mink. EPA is concerned that a
dietary level below 0.64 ppm could still cause serious
sublethal and even lethal effects in mink and other sensitive
species. Therefore, the approach used by EPA was not overly
conservative, because EPA did not use a safety factor of 10 to
adjust the LOEL of 0.64 ppm to a "no effects level".
However, applied as a never-to-be-exceeded basis, remediation
of PCBs to the cleanup level of 15 ppm would ensure that the
minks' and other sensitive species' dietary levels will not
exceed 0.64 ppm. Thus, assuming 0.64 ppm is a protective
dietary level and without applying a safety factor, mink and
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other sensitive species would be protected regardless of where
they spend their time or obtain their food.
A complete discussion of the use of mink as an indicator
species in th~ ecological risk assessment for Middle Marsh is
provided in the response to Comment No. 10.
COMMENT 14: The food chain presented in the SRI risk
assessment is based upon the erroneous presumption that mink
. eat contaminated trout in the Marsh. The SRI does not provide
any evidence of trout (and any other fish) being present in
Middle Marsh.
Restlonse - EPA has determined that it is appropriate to
derive a cleanup level in the aquatic area of Middle Marsh to
account for uptake of PCBs through an aquatic food chain
pathway. In particular, site-specific studies indicate that
benthic organisms have accumulated PCBs and that upper trophic
level consumers are at risk. As stated in the EPA document
Water Oualitv Standards for Wetlands:
" Applying water quality standards to wetlands is part of
an overall effort to protect and enhance the Nation's
wetland resources. At a minimum, all wetlands must have
uses designated that meet the goals of Section 101(a) (2)
of the CWA by providing for the protection and
propagation of fish....and wildlife."
As described above in response to comment 10 the remediation
criteria were established to ensure the restoration of a
healthy ecosystem, as indicated by conditions suitable for an
unaffected, reproducing mink population. In order to achieve
this objective, all potential food sources for mink must be.
free from PCB contamination that would inhibit reproduction or
other critical life stages or ecological functions. It is not.
appropriate to protect only a portion of the mink's diet,
based on presumed relative use of available acceptable food
sources. All carnivores in the wild utilize food based on
availability, and restoration of the population must provide
for a variety of dietary mixes. Data presented by Linscombe
et ale (1982) demonstrates, for example, the variability in
mink diet between seasons and from location to location.
The RI (Metcalf & Eddy, 1991a) demonstrates that Middle Marsh
supports an aquatic food chain which could be a significant
portion of the diet of a mink or other mammalian or avian
carnivore. Frogs, tadpoles, and crayfish are abundant in
Middle Marsh and fish have been observed in the Unnamed Stream
that travels through Middle Marsh. The actual extent of fish
is unknown but, based on physical conditions and presence of
suitable food, there is no reason why the stream and its
tributaries could not support an abundant fish assemblage once
contaminants are removed from sediments and the water column.
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Therefore, a remediation criterion that ensures safe
concentrations in aquatic food sources has been established.
To achieve a safe aquatic food web, the RI/FS evaluated and
used sediment remediation criteria. The indicator used in
evaluating sediment criteria was acceptable concentrations of
PCBs in the aquatic or aquatic dependent portion of the mink
diet. There was no indication of contamination effects on the
benthic community and thus protection of the structure of the
benthos was not an objective in establishing sediment
criteria. ARARs, risk type evaluations, and review of on-site
data were used in establishing sediment remediation criteria.
The interim sediment quality criterion for PCBs represents a
standard which is "to-be-considered" (TBC) in the RI/FS
process. The interim criterion for PCB was derived based on
residue effects and not protection of the benthos from toxic
effects of PCB. The sediment quality criterion was designed
to ensure that benthic organisms are not exposed to
bioavailable concentrations of chemicals greater than what is
currently allowed by existing water quality criteria.
However, as described above, the objective of sediment
remediation criteria for Middle Marsh was control of residue
in mink diet, so the interim criteria approach and methods for
PCBs was appropriate for Middle Marsh.
The approach for sediment quality criteria does include
assumptions, and in some cases the database is limited;
therefore, additional considerations were used in evaluation
of remediation criteria. The benthos can bioaccumulate PCB
from the sediments via the pore water. Potential mink food
sources such as fish, frogs, or crayfish, feed on these.
benthic animals and can further concentrate the PCB in their
tissues. Using the same assumptions established for.
bioavailability, bioaccumulation, and partitioning in the
relevant ARARs for water and sediment quality criteria, a PCB
concentration of 0.014 ~g/lin the pore water would result in
an aquatic food web with PCB concentrations protective of mink
reproduction, and thus the indicator was used for a healthy
Middle Marsh ecosystem. Based on specific Middle Marsh site
conditions of sediment organic carbon concentrations and mink
diet, a pore water concentration of 0.014 ~g/l would give a
sediment remediation criteria of 19.5 ~g PCB/Gct which was
used in the RI/FS. This approach was evaluated considering
on-site data and was found to be substantiated. Sediment in
the Unnamed stream in excess of two times the upper PCB
interim sediment quality criterion (EPA 1988) resulted in
benthic tissue concentrations of approximately 0.4 ppm
(Charters, 1991). The upper SQC is exceeded in much of the
aquatic area (Area 1 in the FS) that was targeted for
remediation. These benthic tissue concentrations are close to
the levels in mink diet which have been shown to produce
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reproduction inhibition (0.64 ppm) (Platonow and Xarstad,
1973). A diet of benthos (or the adult insects resulting from
the benthic larvae) at the measured levels of PCB by fish,
crayfish, or frogs could result in tissue concentrations above
the levels shown to be harmful to mink.
Bioaccumulation of PCBs in the Middle Marsh area is further
substantiated by benthic and fish sampling conducted by
Environmental Science and Engineering (1978) in the Unnamed
Stream in downstream areas as it flows through the
Apponagansett Swamp. This area is also near the New Bedford
Municipal Landfill which is also reportedly contaminated with
PCBs. Benthic concentrations in the stream were 1.13 ppm
Aroclor 1254 in a composite sample from six stations. PCBs
were also found in fish at one station. The report concluded
that "Bioaccumulation of PCBs is demonstrated by the
relatively high levels detected in benthic organisms within
the swamp. Transport of this contamination up the food chain
to the more mobile biological organisms (i.e. fish) is
occurring". This indicated that mink food sources in other
areas surrounding Middle Marsh could be contaminated, and that
the use of 65 percent residence time (which assumes all other
food sources not related to the site are not contaminated with
PCBs) was not overly conservative. If, in the calculation of
the cleanup level, food sources not found in Middle Marsh had
assumed to be contam~nated with PCBs, then, a lower cleanup
level may have been derived.
One of the uncertainties, as pointed out by GEI, in the
development of the SQC for PCBs, and in the ecological
exposure assessment for Middle Marsh is the use of the
bioaccumulation factor of 45,000 derived from trout studies.
for uptake of PCBs by aquatic species. However,
bioaccumulation factors for Aroclor 1254 are presented in the.
ambient water quality criterion document for PCBs (EPA, 1980);
they range up to 238,000 for the fathead minnow, a species
which could inhabit Middle Marsh. In addition, EPA states
that "available information strongly indicates that field
bioaccumulation factors for PCB are probably a factor of 10
higher than the available laboratory BAF values" (EPA, 1980).
Laboratory values such as those BAFs listed above, are based
on direct arid respiratory exposure only. The higher field
values would result from dietary exposure which would occur
for aquatic species in Middle Marsh.
The SQC model was applied to areas of Middle Marsh that
support permanent standing water, even during the dry months
of the year. EPA agrees that SQC do not apply to wetland
soils or semi-permanently flooded wetland areas. During the
RI field studies (Metcalf & Eddy, 1991a), much of Middle Marsh
was inundated and aquatic invertebrates were found in these
areas. Yet SQC were not applied to these areas because the
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inundation was judged to be seasonal. To determine the
presence of aquatic habitat, EPA conducted qualitative
biological sampling in August of 1990 to determine the
presence of obligate aquatic invertebrates. Aquatic habitat
was limited to a large tributary of the Unnamed Stream and
nearby areas that were characterized by permanent flooding up
to about three feet in depth and obligate aquatic organisms,
including amphipods, freshwater clams (Sphaeriidae), isopods,
Alderfly larvae (Sialus SD.), Crane fly larvae (TiDula SD.),
midge large (Chironomids), tadpoles and. leeches (Hirudinea).
These areas are inundated even during mid-summer. They
maintain a self-sustaining aquatic community, serve as feeding
areas for stream biota, contribute plant and animal material
to the stream on a continuing basis, and could support an
aquatic pathway for bioaccumulation.
It is important to note that EPA used the SQC as an indicator
of potential wildlife impacts and then field verified the
resul ts. The use of SQC as part of an overall ecological risk
assessment is consistent with EPA guidance. The EPA
publication Guidance for Conductinq Remedial Investiqations
and Feasibilitv Studies Under CERCLA (EPA/540/G-89/004)
includes the following statement on Page 1-3 concerning
determination of risk:
The objective of the RI/FS process is not the
unobtainable goal of removing all uncertainty, but rather
to gather information sufficient to support an informed
risk management decision regarding which remedy appears
to be most appropriate for a given site. .. . These
choices [as to the appropriate course], like the remedy
selection itself, involve the balancing of a wide variety
of factors and the exercise of best professional.
judgement.
In the case of Middle Marsh, the pore water PCB concentrations
that exceeded the ambient water quality criterion of 0.014
~g/l, the sediment levels that exceeded the sediment quality
criterion, and the elevated PCB concentrations in site biota
including benthic organisms were a part of the "weight-of-
evidence" judgement that there was potential endangerment to
wildlife in Middle Marsh. In particular, biological tissue
data verified that exposure to PCB sediment concentrations
exceeding the upper sediment quality criterion resulted in
accumulation of PCBs in benthic organisms, the lowest level of
the aquatic food chain. EPA believes that this could result
in food chain bioaccumulation, bioconcentration and ultimately
exposure of mink and other sensitive species to detrimental
dietary concentrations of PCBs.
COMMENT 15: The SQC methodology is applicable only if
contaminated sediments are submerged for sufficient periods of
time. to establish an equilibrium between the sediments and the
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overlying water column. This condition is not true for most
of Middle Marsh where there is NO truly aquatic environment.
ResDonse - In this ROD, EPA applied the SQC only to a small,
permanently 'flooded, aquatic area within Middle Marsh.
Aquatic areas were identified by the combination of hydraulic
modeling, field observations, and benthic reconnaissance as
described in the response to Comment 14. GEl has suggested
that according to definitions presented by Cowardin et ale
(1979) that open water areas shallower than 6.6 feet deep are
not aquatic. EPA does not agree with the use of the Cowardin
definitions which were selected only as the basis for
development of a wetland nomenclature system and would, in
this context, indicate that millions of acres of streams and
shallow areas of rivers, lakes and ponds are not aquatic. EPA
has determined, based on site-specific studies, that the
aquatic areas in Middle Marsh were flooded even during dry
months of the year and could support an aquatic pathway for
bioaccumulation.
COMMENT 16: The sediment quality criteria methodology, a
highly controversial and complex method for evaluating risk,
produces extremely unpredictable and inaccurate results. The
Equilibrium Partitioning Method used to derive the SQC
produces results that differ significantly from measured data
from pore water samples taken at Middle Marsh.
ResDonse - EPA's rationale for collecting and measuring PCB
concentrations in the pore water and sediment was not to
validate the SQC model. Interrelating pore water and sediment
levels is inherently difficult due to sampling methodologies.
Rather, these media were sampled to obtain a range of values.
for use in the ecological exposure assessment. EPA is
proceeding with the equilibrium partitioning method for
development of sediment quality criteria. EPA has determined
that the application of this method to Middle Marsh is
appropriate for prediction of the range of pore water
concentrations, on average, in aquatic areas of this wetland.
COMMENT 17: The SQC methodology improperly assumes that
aquatic organisms such as trout will be exposed to pore water
concentrations of contaminants.
ResDons~ - Site-specific data has shown that the benthos in
Middle Marsh bioaccumulate PCB from sediments via the pore
water. Potential mink food sources such as fish, frogs, and
crayfish feed on these benthic animals. EPA believes that a
PCB concentration of 0.014 ~g/l in the pore water would result
in an aquatic food web with PCB concentrations protective of
mink and other sensitive species' reproduction. The cleanup
criterion for aquatic areas is designed to achieve this level
of protection. A complete discussion of the use of SQCs in
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the ecological risk assessment for Middle Marsh is provided in
the response to Comment 14.
COKHENT 18: The SRI correctly concludes that volatile and
semivolatile .organics, heavy metals, and pesticides in the
Middle Marsh sediments, pore waters, and surface waters pose
no threat to the environment.
Response - As indicated in the hazard assessment in the RI
(pp. 4-1 - 4-3) the following conclusions were reached with
respect to volatiles, semivolatiles, heavy metals, and
pesticides:
Volatile organic compounds were detected infrequently and
at levels below detection limits in all media in Middle
Marsh. Accordingly, volatile organics are not considered
a threat to wildlife in the study area. Semivolatile
organic compounds (SVOCs), especially polycyclic aromatic
hydrocarbons (PAH), may cause a variety of health effects
in wildlife. However, as described earlier in Chapter 3,
Nature and Extent of Contamination, and as further
documented in Chapter 5, Human Health Risk Assessment
(Tables 5-1,5-8 and 5-9), semivolatiles in both wetland
areas appear to be within the range of background
concentrations from the literature that are typically
found in soils near highways. Semivolatiles were found
at levels near or below detection limits in water samples
indicating that exposures of wildlife to SVOCs in pore
water and surface water do not represent pathways of
concern. Further, measured sediment/soil levels were
compared with interim sediment quality criteria (EPA,
1988b) established for fluoranthene, pyrene, .
benzo(a)pyrene and benzo(a) anthracene and were below the
lowest site-specific sediment quality criteria. Based on .
these considerations, semivolatiles are not considered a
hazard to wildlife in the study area.
Several heavy metals detected in sediment/soil in Middle
Marsh and the Adjacent Wetland are above background
levels including copper, chromium, iron, lead, vanadium,
manganese and zinc. However, after comparison to
sediment criteria set forth by Long and Morgan (1990),
lead and zinc were identified as metals for which the
levels in the range of those present in the wetland areas
could cause toxicity to some species. Long and Morgan
(1990) found that sediment lead concentrations of 35-
110 mg/kg, and sediment zinc concentrations of 50-
125 mg/kg resulted in sublethal effects in aquatic biota.
These values are substantially below the maximum lead and
zinc concentrations in Middle Marsh of 845 and 521 mg/kg,
respectively. In addition, iron may pose a threat to
aquatic biota through creation of a solid floc that
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adheres to sediments and smothers sediment benthic
organisms. To further evaluate potential for biological
impacts,surface water and pore water metals data were
compared to ambient water quality criteria (EPA, 1986d).
This comparison revealed that dissolved (filtered) metals
concentrations were near or below ambient water quality
criteria' for lead, zinc and other metals. This
phenomenon may be due to the binding of metals to
sediments as sulfides, resulting in low bioavailability
for uptake by plants and animals. In addition to lead
and zinc, this phenomenon was also evident for calcium
and silver in Middle Marsh water samples and has been
observed at other sites (Mac et al., 1985). Due to the
low water concentrations, heavy metals have not been
evaluated as a hazard to site biota.
COMMENT l' : The remedial schedule proposed in the FS is
unrealistic. Remediation of the Marsh will be seriously
jeopardized by the remediation of the Unnamed Stream (during
the remedial action for the First Operable Unit) if the
actions are not performed simultaneously.
ResDonse - The remediation schedule for the selected remedy
is optimistic but not unrealistic. It is fast-tracked (as
with all alternatives evaluated in the FS) to minimize
wetland, habitat, and wildlife impacts. The schedule for the
selected remedy (Figure 9-2 in the FS) includes separate tasks
for site preparation and excavation and does not account for
pre-design, design and contracting activities. Site
preparation includes construction of access roads, removal of
trees, and mobilization of equipment. One month was allotted
for site preparation. This is followed by excavation or.
actual removal of sediments. One and a half months has been
allotted for excavation. EPA believes that this time frame is .
realistic for the reasons discussed below.
The replacement of wetland soils will not be constrained by
treatment, thus wetland protection and restoration activities
may begin as soon as possible after excavation. The wetland
restoration schedule does not include post-restoration
maintenance and monitoring. These activities would continue
for a number of years after excavation. EPA agrees that for
the Middle Marsh operable unit, even with prior site
preparation, one excavator may not always produce 64 cubic
yards of dredged material per hour. This rate, quoted in the
FS, is based on average outputs of excavators with 1/2 and
3/4 cubic yard buckets working in wet, stiCky, clay (Peurifoy,
1979). However, EPA believes that this rate could be achieved
if excavation was performed in several of the remediation
areas at the same time. The excavation rate would also be
enhanced by the use of a dragline in Area 2. The dragline is
a relatively large and powerful excavator. Also, EPA expects
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that excavation in Area 4, a relatively dry and accessible
area, could alone produce the 64 cubic yards per hour
estimated in the FS. The overall operation would not be
constrained by the size of the working areas or any small
roots that remain in place after site preparation.
The schedules developed in the FS are estimated and are based
on assumed use of effective equipment, skilled workers, and
absence,of severe weather disturbances that could halt work
for several days. The schedule is based on a conceDtua].
design and would be refined during design. At the conceptual
level, there is uncertainty as to what excavation method would
be used and the amount and type of dewatering needed.
No permits are required for remedial actions undertaken on the
Site under CERCLA.
EPA agrees that the remedial activities for the two operable
uni ts would best be performed simultaneously; however, if
simui taneous operations are not possible, and if the time
period between the First Operable Unit and the Middle Marsh-
Operable Unit would be significant, EPA does not want to
significantly delay remediation of the Sullivan's Ledge
Disposal Area which acts as a continuing source of PCB to
Middle Marsh. EPA may consider delaying final restoration of
the stream depending on the degree of impact if not restored
and the possible time frame for construction of the Middle
Marsh operable unit. In the interim, although not fully
restored, Middle Marsh would need to be stabilized in
accordance with wetland guidelines.
COMMENT 20: There is no reasonable justification for EPA's.
proposed contingency alternative.
ResDonse - EPA' s selected remedy for the Middle Marsh
Operable Unit is dependent on Middle Marsh excavations being
conducted prior to capping the Disposal Area. If the cap is
constructed before the Middle Marsh excavations are conducted,
the selected remedy could not be implemented. For the First
Operable Unit, EPA has determined that both solidification and
disposal under a cap is necessary to ensure that in the long-
term, contaminated soils will not erode into the Unnamed
Stream and other downstream areas. It must be noted, however,
that only soils contaminated at levels over 50 ppm will be
solidified.
GEI has suggested that a significant time period could be left
in bet~een the operable units by leaving a portion of the
disposal area cap incomplete. EPA is concerned, however,
about the long-term potential for release of contaminated
soils and further contamination of the Unnamed Stream and
downstream areas including Middle Marsh and the Apponagansett
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Swamp. As stated in the 1989 ROD, the cleanup level for
sediment in the Unnamed Stream is 20 ~g PCBs/Gc. Thus for
this site, it is critical to ensure that on-site soils will
not erode into the Unnamed Stream. Unsolidified and uncapped
PCB-contaminated soils even at PCB levels below 50 ppm in an
uncompleted cell and/or temporarily .stockpiled excavated
material could present a significant threat of release and
recontamination of remediated areas. In addition,
infiltration in the uncapped area could contribute to
migration of contaminated groundwater including seepage of
contaminants to the Unnamed Stream.
The NCP and its preamble encourage using operable units as
early actions to eliminate, reduce or control the hazards
posed by a site or to expedite site cleanup. 55 Fed. Reg.
8704. At this site, EPA decided in 1989 to split the Site
into two operable units so that protective measures at the
Disposal Area and Unnamed Stream could be implemented promptly
at those locations, while EPA conducted further studies to
characterize risks at Middle Marsh and analyze remedial
approaches for Middle Marsh in greater detail. It does not
make sense to decide now to wait until negotiations with
potentially responsible parties (and perhaps litigation)
regarding the Middle Marsh Operable Unit are Over, an
agreement is reached or an administrative order is issued
under Section 106 of CERCLA, and design activities for the
Middle Marsh Operable Unit are completed, before addressing
the principal threat at the First Operable Unit. EPA is
commi tted to selection of remedies that provide permanent
protection. The Agency is concerned that leaving a partially
completed cap to be completed at a later date could compromise
the integrity of the remedy, lead to long-term maintenance.
problems and increase costs. The measures suggested by GEI
could only be implemented with significant additional.
planning, design, operations, and maintenance to ensure that
the open cell and/or stockpiled material would not present
significant adverse impacts, as described above.
There are two reasons why EPA bel ieves that it would be
inappropriate to put a hold on implementation of the First
Operable Unit until the implementation of the Second Operable
Unit can be coordinated. First, the contamination at the
First Operable Unit presents the most urgent and serious
threat to human hea.lth and the environment at the Site.
Significant delay in implementing protective measures to
address the contaminated groundwater, soils and sediments at
the First Operable Unit (the principal threats at the Site)
would be inappropriate.
Second, in signing the Consent Decree relating to the First
Operable Unit, EPA, the Commonwealth of Massachusetts and 14
PRPs have agreed to a schedule of activities for the First
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Operable Unit. This agreement was approved by the United
States District Court in April 1991 and is legally binding on
EPA. If EPA acted unilaterally in extending the schedule
dates without the consent of the other parties to the Consent
Decree, the 14 signatory PRPs could be adversely affected --
for example, the PRPs' contracts with design contractors and
subcontractors would have to be extended out for longer
periods of time, causing the PRPs' costs to increase. Based
on the preliminary timetables established under the Consent
Decree, it is expected that remedial design for the First
Operable Unit will be completed by March, 1994. If additional
design activities necessary to implement the selected remedy
for the Middle Marsh Operable Unit are not completed in time
to be integrated into the design of the First Operable Unit,
then the contingency remedy will be implemented in place of
the selected remedy.
If, however, all parties to the Consent Decree for the First
Operable Unit can reach agreement, EPA would consider a short
extension of time (consistent with the need to address
principal threats quickly) that would permit coordination of
the selected remedy for Middle Marsh with the remedy for the
First Operable Unit, through an Explanation of Significant
Differences ("ESD") if appropriate.
COMMENT 21: Backfilling the disturbed wetlands, as required in
the preferred remedy, is not absolutely necessary and requires
destruction of wetlands elsewhere in order to obtain the most
suitable materials.
Response - EPA bel ieves that replacement of sediments is
required under federal and state law. Under Section 404 (b) (1) .
of the Clean Water Act, the remedy cannot have significant
adverse environmental consequences, or cannot cause or
contribute to significant degradation of waters of the U.S.
In addition, all appropriate and practicable steps must be
taken to minimize impacts to the aquatic ecosystem. 40 CFR
Section 230 specifies that a project involving fill material
should be designed and maintained to emulate a natural
ecosystem. The restoration should be based on characteristics
of a natural ecosystem in the vicinity of the proposed
activity to ensure that the restored area will be maintained
physically, chemically, and biologically by natural processes.
Executive Order 11988, Floodplain Management, and Executive
Order 11990, further require that actions in floodplains or
wetlands restore and preserve the natural and beneficial
values of the wetland and floodplain areas. E.O. 11990
requires that actions in wetlands "consider the maintenance of
natural systems including conservation .and long-term
productivity of existing flora and fauna, species and habitat
diversity and stability, and hydrologic utility." Finally, MA
DEP Wetlands Protection Regulations concerning dredging,
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filling, altering or polluting inland wetlands are applicable
to the dredging of Middle Marsh and the Adjacent Wetland and
require compliance with performance standards of the
regulations regarding banks, vegetated wetlands and lands
under water, ,and a one-for-one replication of any hYdraulic
capaci ty which is lost as the result of this part of the
remedial actions.
The wetland areas in question, especially Areas 2 and 4, are
subject to substantial rapid changes in water surface
elevation due to stormwater runoff from the upstream urbanized
watershed. During hydrologic monitoring, Metcalf & Eddy
observed high stream velocities exceeding two feet per second
in these areas and significant scouring of the stream bottom
and bank sediments. If these areas were excavated and not
restored, EPA believes that there would be severe erosion
problems, water quality degradation, and failure of any
attempt to revegetate these areas due to the increased
insurgence of stormwater, erosion, and sedimentation.
EPA agrees that excavation of another wetland in order to
restore Middle Marsh would not be protective of the
environment and such a measure would not be taken. However,
it is not possible to identify the source of replacement
sediment to be used at the site, at this time. The FS states
that the replacement "soil would be conditioned with organic
amendments" such as "organic dredged material from a lake or
pond, sphagnum or organic silt, or other organic soils" and
"chipped, uncontaminated or decontaminated trees and brush".
Sediments from a dredging project not conducted to provide
backfill for Middle Marsh could provide suitable material if
such a project could be identified. The details of the.
wetland restoration will be finalized during remedial design.
Details of the plan will reflect regulatory requirements, .
inCluding replacement of the functional values of the impacted
areas.
COMMENT 22: There is no justifiable reason to manage the
cleared vegetation as a hazardous waste.
Rescons~ - EPA agrees that plants in Middle Marsh do not
accumulate PCBs at significant levels. EPA also agrees that
not all cleared vegetation would need to be managed as a
hazardous waste and that properly handled material could be
managed as a solid waste. In fact, the FS (Metcalf & Eddy,
1991b) states on Page 7-20 that non-contaminated material may
be disposed of on-site or in a municipal landfill in
accordance with applicable regulations. However, on Page 9-12
of the FS, in the detailed evaluation of alternatives, the FS
clarifies further that only contaminated materials such as
stumps and vegetation that does come in contact with
contaminated mud would need to be managed as a hazardous
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waste. EPA does not believe that all areas to be remediated
could be cleared without generating contaminated vegetation.
COMMENT 23: Production rates and treatment technologies stated
in the FS are unrealistic and likely unattainable.
y,
ResDonse - ,The production rate of 100 tons per day is
reasonable, and is based upon direct consultations with
vendors of two solvent extraction processes, Resources
Conservation Company (the B.E.S.T. process) and CF Systems
Corporation (liquified propane extraction). This treatment
rate is expected to be consistent with excavation rates.
Resources Conservation Company (RCC) has successfully operated
a 100 ton per day unit at the General Refining Superfund site
(Sudell, 1988). The B.E.S.T. process unit that would probably
be mobilized for a site the size of Middle Marsh would consist
of two modular batch units, each capable of operating at 75
tons per day, for a total capacity of 150 tons per day.
According to conversations with RCC engineers, the units taken
together would occupy no more than 1/2 acre of land area.
While it is possible that extreme materials-handling or
treatment problems could reduce the production rate of such a
system to less than 100 tons per day, such problems should be
uncovered during treatability testing and may be corrected for
by measures such as feed pretreatment or increasing the number
of modular units employed for treatment. Materials handling
is not expected to be difficult at Middle Marsh because the
soils and sediments will not contain a great deal of large-
sized material which must be removed before treatment. Thus
the treatment process could be expected to proceed on schedule-
and without significant impact to the mating of the spotted
turtle. As described on pages 9-35 and 9-36 of the FS .
(Metcalf and Eddy, 1991b), the remediation will be conducted
with sensitivity to impacts. on this species through the use of
extensive mitigating measures. As further described in detail
-in the response to Comment 26, the spotted turtle was observed
in inundated areas in the northeast area of Middle Marsh. The
remediation of the targeted areas near the Unnamed Stream is
not expected to have an overall adverse impact on this
species. A representative of the Massachusetts Natural
Heritage and Endangered Species Program (Copeland, 1991) has
been consulted and agrees with this assessment.
Table 1 (see attached) summarizes the results of treatability
studies performed by RCC and ART International (the LEEP
process) in which cleanup levels less than or equal to 2 mg/kg
total PCB were attained (Steiner, 1991). Although the solvent
extraction technology vendors state that attainable cleanup
levels are matrix-specific, their previous experience in
treating PCB-contaminated soils and sediments indicates that
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the cleanup levels for Middle Marsh are attainable. This
assumption shall be confirmed by performing sol vent extraction
treatability studies on Middle Marsh sediment/soils during
predesign.
The end products of the B.E.S.T. process are dry, treated
soils and sediments: a concentrated oil stream containing the
extracted PCBs: and a product water stream. The concentrated
oil stream will be incinerated in an off-site TSCA
incinerator, and the product water stream will be treated to
applicable standards before being discharged to surface waters
or mixed back into the treated_soils. Therefore, there will
ul timately be no residual toxicity associated with these
streams. With regard to the treated soils and sediments,
potential sources of residual toxicity are any PCBs or
residual triethylamine which remain. Since the PCB
concentrations will be below cleanup levels the risk
associated with them is minimal. Residual triethylamine is
not expected to pose a problem because it is readily
biodegradable in water and soil. According to RCC's
literature, triethYlamine at an initial concentration of 200
ppm in water is completely biodegraded in 11 hours by
Aerobacter, which are common soil bacteria.
The effectiveness of the B.E.S.T. process is not necessarily
limited by the oil content of the soil, as is demonstrated by
the data in Table 1. Soils with oil contents as low as 0.07
percent were effectively treated to a total PCB concentration
less than 2 mg/kg. Therefore, the low oil content of Middle
Marsh soils and sediments does not preclude use of the
B.E.S.T. process.
Dechlorination techniques were screened from consideration in
the previous FS performed by Ebasco because these techniques.
may not be effective on materials with initial concentrations
less than 25 mg/kg PCBs. The results of this screening were
maintained in the current FS (Metcalf & Eddy, 1991b).
Performance of treatability studies of the KPEG process
simultaneously with studies of solvent extraction would
certainly be of interest, but given the information currently
available, there is no compelling reason to assume that
solvent extraction will be ineffective and therefore, less
preferable than KPEG.
COMMEN7' 24: The proposed plan would require excavation of more
wetland acreage than necessary, even accepting the SQC in the
SRI.
ResDonse - As described in the response to Comments 10 and
14, cleanup areas are not based on reducing. the average
sediment/soil PCB level to the cleanup level. Rather it is
intended to eliminate materials with concentrations above the
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,
cleanup level. Removal of these sediments will eliminate
areas where mink and other sensitive species could contact
sediments that could cause reproductive failure or other
health effects, regardless of where in Middle Marsh the animal
spends most of its time or obtains most of its food.
The delineation of Area 1 was based on reliable PCB and Toe
data. The borders of the area wer~ delineated using a
geographic information system and represents an approximation
of the area that exceeds the sediment quality criterion for
PCBs. GEI has asserted that the area was based on an "extreme
value", namely the TOC concentration of 22,000 mg/kg at
station MES. However, an examination of the data (Table 3-1
of the RI) reveals that this value is not extreme and that
there are numerous TOC values in the range of 10,000 to 30,000
mg/kg TOe, revealing that the value of 22,000 mg/kg is not an
anomaly. It should be noted that additional sampling will be
conducted during predesign to further refine the boundaries of
Area 1 to be remediated.
COMMENT 25: The proposed plan will disturb and/or destroy the
wildlife it is supposed to protect.
ResDonse - EPA is very concerned about the impact of
excavation and remediation on wildlife and habitats in Middle
Marsh, and was very careful throughout the RIfFS process to
assess the natural resources present at the site, to evaluate
potential short- and long-term impacts, and to evaluate ways
to mitigate those impacts. Al though the remediation will
result in some direct short-term impacts to Middle Marsh, EPA
has determined that disturbance of wetlands and floodplains is
the only practicable alternative that would address PCB.
contamination in the Middle Marsh study area while minimizing
adverse impact on the terrestrial and aquatic ecosystem. The.
contaminants in the sediment/soil would continue to pose
unacceptable environmental risks if the excavation were not
performed and could be the cause of any absence of a viable
and diverse ecosystem in the wetlands.
EPA has developed an extensive conceptual mitigation plan as
presented in the FS. Following site cleanup activities,
impacted wetlands would be backfilled with clean soil and
organic material such as peat moss, organic silt, and shredded
trees and vegetation. The areas would be graded, stabilized,
and then planted with vegetation appropriate to the type of
wetland affected. During implementation of the remedy, steps
will be taken to minimize the destruction, loss and
degradation of wetlands, including the use of sedimentation
basins or silt curtains to prevent the downstream transport of
contaminated sediments. As illustrated in Figure 9-1 in the
FS, most of the required access roads in wetland areas will be
placed within areas to be remediated, minimizing damage to
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nearby areas. In addition, excavation of Area 3 will be
conducted using hand-held shovels and wheelbarrows to
transport excavated sediment/soils, thus eliminating the need
for access roads to this area.
Performance of this cleanup remedy will meet or attain all
applicable or relevant and appropriate federal and state
requirements that apply to the site including Section 404 of
the Clean Water Act; Floodplain Management and Protection of
Wetlands; Executive Orders 11988 and 11990, respectively; and
DEP Wetlands Protection Regulations. EPA will. ensure that the
cleanup is conducted properly through the development of
detailed specifications for performance of the work, proper
equipment, experience of the contractor, mitigation, and
employment of an appropriate specialist for wetland
restoration.
EPA does not believe that this remedial action will devastate
Middle Marsh or its associated wildlife. The project will
directly affect approximately two acres of wetland, a
relatively small amount compared to the total 14.5 acres of
Middle Marsh and the Adjacent Wetland. FOllowing remediation,
the terrestrial and aquatic organisms that inhabit the surface
soils and sediments would quickly repopulate the disturbed
areas. Stream diversion and stream dewatering are not planned
as part of the Middle Marsh excavation because most of the
areas to be remediated do not have significant volumes of
overlying waters and the sediments can be effectively removed
through the use of readily available excavators. Stream
diversion of a portion of the Unnamed Stream near the Disposal
Area was chosen as part of the selected remedy for the First
Operable Unit because of the need to line this stream portion.
to prevent the waters of the Unnamed Stream from being pulled
into the extraction wells to be installed at the Site.
Remedial activities to be performed at the Middle Marsh
Operable Unit would temporarily disturb aquatic areas but
would not "dry up and destroy all aquatic life. II FOllowing
remediation, EPA believes that indigenous wildlife, if
displaced during construction or if adversely affected as a
resul t of exposure to contaminants, will return to Middle
Marsh. This includes the eventual return of mink, which, as
stated above, are tolerant of human activity (Allen 1986).
EPA agrees that it will take several years to reestablish
dense vegetation in the remediation areas, which comprise
approximately 14 percent of Middle Marsh and the Adjacent
Wetland. EPA further acknowledges that this action will
invol ve removal of trees from several areas of forested
wetland habitat. However, EPA is confident that the
ecological forces and conditions that created forested wetland
in this area will still exist following remediation and that
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planted trees and natural succession will reestablish forested
wetland in these areas and that without PCBs, Middle Marsh
will offer suitable habitat for a wide diversity of species.
EPA acknowledges that remedial activities will impact several
acres of ,land outside of Middle Marsh; however, these
activities will have little impact on wetland areas. For
example, the staging area is located outside the 100 year
floo4plain at a considerable distance from Middle Marsh. As
described on pages 9-6 to 9-12 of the FS (Metcalf and Eddy,
1991b), EPA has outlined mitigating measures to control
erosion from the staging area and from access roads located
within and outside the wetland. Following remediation, all
access roads and other facilities would be removed from the
Si te and the disturbed areas returned to their original
condition.
EPA conducted a full ecological assessment including wetland
and habitat delineation, a wetland functional assessment, an
ecological risk assessment, a detailed review of pertinent
wetland and other environmental regulations, and a feasibility
study including identification and evaluation of technologies
that minimize damage to wetlands, and development of
mitigating measures. These studies were intended to ensure
that only appropriate areas were targeted for cleanup and that
any impacts would be mitigated. It is anticipated that once
the preferred plan is implemented, Middle Marsh will be
restored as sui table habitat for mink and other species
sensitive to the chronic and lethal effects of PCB
contamination.
COMMENT 26: The proposed plan poses a substantial and-
unreasonable danger of destroying the habitat of the spotted
turtle, a species of special concern in Massachusetts. .
Resnonse - EPA does not believe that the excavation conducted
under the Middle Marsh Operable Unit will destroy the habitat
of the spotted turtle. Al though this species has been seen in
Middle Marsh during the RI, it was seen in wet, swampy areas
far to the north of the Unnamed Stream, whereas the
remediation areas are directly adjacent to the Unnamed Stream
in relatively dry, grassy, vegetated wetland areas. As stated
on page 9-35 of the FS (Metcalf & Eddy, 1991b):
.During wetland field investigation, a Massachusetts
Species of Special Concern, the spotted turtle, was
observed in Middle Marsh. Remediation of Middle Marsh
shall be conducted with sensitivity to this species. The
spotted turtle courts in the period betwee'n March and May
and nests in dry areas in June. Their young, or
hatchlings, emerge in late August-September or over-
winter in the nest until spring. Mitigating measures to
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reduce impacts to the spotted turtle populations may
include a detailed survey of the remediation areas to
catch and translocate any adults to uncontaminated areas
of the wetland, restriction of heavy equipment to defined
work areas, and control of turbidity and erosion.
Short-term impacts could include displacement, . noise
disturbance, and short-term habitat loss; however,
although the entire area of Middle Marsh has been
identified by the Massachusetts Natural Heritage Program
as spotted turtle habitat, spotted turtle were primarily
observed in inundated areas in northeast regions of
Middle Marsh, and remediation of the targeted areas near
the Unnamed Stream is not expected to have an overall
adverse impact on this species.
Copeland (1991) of the Massachusetts Natural Heritage &
Endangered Species Program stated that "In general, we believe
that the spotted turtle can adapt to short-term changes in its
habitat, with proper planning, executions, and design of the
proposed work." EPA believes that the implementation of the
remedial activities will mitigate potential impacts to the
spotted turtle while ensuring suitable habitat for mink and
other sensitive species.
COMMENT 27: The proposed wetlands restoration plan is
inadequate and not consistent with existing wetland species.
Res~onse - EPA believes that the Wetlands Restoration Work
Plan to be implemented for the Middle Marsh Operable Unit will
be tailored to address existing wetland species. All wetland
and upland areas would be restored, to the maximum extent
feasible, to similar hydrologic and botanical conditions'
eXisting prior to excavation. As described in detail in
response to Comment 25, construction of all access roads, both.
within and outside of the wetland areas, will be conducted
with mitigating measures such as sand bags, haybales, swales,
and culverts to maintain existing runoff patterns and to
prevent excess erosion and sedimentation in and wetland area.
Following remediation, all access roads and facilities would
be removed from the Site and disturbed areas returned to their
original condition.
The details of the restoration plan will be developed during
remedial design at which time the least disruptive and
environmentally correct restoration program will be developed.
The restoration plan will evaluate using the spotted turtle
and the Mystic Valley Amphipod as biological indicators to
measure the SUccess of the restoration. In addition, this
program will identify the factors important to Successful
restoration of wetland areas including, but not limited to,
replacement of hydric soils, hydraulic control, and vegetation
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re-establishment through
combination thereof.
transplanting,
seeding,
or
a
The wetland restoration plan presented in the FS is not
intended as 'a final design and the plant species listed are
examples of emergent wetland vegetation that are economically
available and could thrive in Middle Marsh. However, EPA
agrees that red maple may be more appropriate for restoration
than red oak. Both species were found in the area. As stated
on page 9-21 of the FS, quality assurance measures for the
restoration of wetlands would include before and after
vegetation surveys to ensure replication of proper vegetation
and engagement of a wetland specialist.
COKKENT 28: The data which is relied upon in the FS regarding
PCB concentrations in surface water and pore water samples
contain several discrepancies.
Resnonse - EPA's consultant sampled the pore water for PCBs
at low detection limits in Middle Marsh during May and
September of 1990. In transcription of the data from both
data sets, several errors were made in developing the
appendices that accompanied the 1991 RI. However, the data
used in the text of the RI were largely correct. Table 2 of
this Responsiveness Summary presents the filtered and
unfiltered pore water and surface water PCB data and clarifies
the transcription errors. Discrepancies in the data are
discussed below.
Resampling was conducted in September 1990 to provide
assurance for the May 1990 data with which there were several
problems.. Due to the calibration method used for the May 1990.
data, the laboratory inadvertently identified Aroclors 1242
and 1260: however, during validation it was determined that.
the PCBs were all Aroclor 1254. This was not reflected in
Appendices E3 and E4 where both aroclors (1242 and 1260) were
reported. In addition, the unfiltered (total PCB) samples
from the May 1990 sampling were not mixed before analysis and
only the supernatants were analyzed. Thus, for this data set
many of the detections of PCBs in filtered and unfiltered
water were very close in concentration. This could account
for some of the anomalous results between filtered and
unfiltered samples in the May 1990 data set. The September
1990 sampling yielded high quality data that contained none of
the inconsistencies found in the Hay 1990 data set. These
data were used to confirm the useability of the filtered PCB
water data from May 1990.
The laboratory errors associated with the May 1990 data were
corrected during validation and the transcription errors for
the September and May 1990 data did not affect the conclusions
of the ecological exposure assessment. In fact, several of
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the highest detected values in pore water had been
inadvertently omitted from the 1991 RI, indicating exposure of
aquatic organisms to pore water concentrations may be higher
than originally discussed in the RI.
EPA does not agree with GEI that uncertainties in the data
were not elaborated in the RI, and that the qualifier "J" was
used to indicate that a compound was "tentatively" identified.
The analytical problems outlined above for the May 1990 data
were described on page 2-77 of the RI (Metcalf and Eddy,
1991a). -
After resampling in September 1990, it was determined that all
of the dissolved (filtered) PCB water data from both sampling
rounds were suitable for use in the Risk Assessment. In
addition, it should be noted that the data qualified with "JII
from the May and September sampling were definitely identified
as Aroclor 1254, a highly chlorinated mixture of PCB
congeners. The "JII for the May 1990 data was assigned under
EPA validation protocol due to problems with calibration,
sample cleanup and "weathering" of some peaks normally
associated with this Aroclor. The "J" qualifiers for the
September 1990 data were only used to indicate that surrogate
recoveries were outside of prescribed limits, as required by
EPA validation protocol. After data validations of both the
May and September 1990 data sets, EPA used these data in the
ecological risk assessment with confidence.
COMMENT 29: The TOC Analytical Method produces inconsistent,
unreliable results which are not reproducible to even an order
of magnitude in the laboratory.
ResDonse - The TOC analysis was performed through a special
analytical services (SAS) request. The initial request was.
performed using a Metcalf & Eddy generated SAS that was
approved by EPA/ESD Lexington. This SAS calls for the use of
the Lloyd Kahn method (June 13, 1989) along with the analysis
of every sample in duplicate. The TOC data was not produced
using the SAS protocol of Region V appended by GEI. Although
the laboratory did not perform every sample in duplicate it
did perform four samples in quadruplicate and seven in
duplicate. This data is summarized in Table 3 along with this
response. The four quadruplicate analyses had relative
standard deviations of less than 20%. The duplicate analyses
had relative percent dif£erences (rpd) ranging from 4% to 52%
(average 24.9%). The sa~ples with high rpd are still within
the same order of magnitude and could be aVeraged to yield
valid information. The duplicate data show little variation
within a given sample.
Field observations made by EPA's consultant while sampling
Middle Marsh, as described in Tables 3-1 and 3-2 of the RI
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'--
(Metcalf & Eddy, 1991a), indicate a variation from one
geographical area to another. Some samples contained
biodegraded twigs, leaves, moss, and other plant matter and
others were soil-like with less organic matter. This
variation in the character of the sediments is most likely the
reason for the variation in PCB and TOC concentration. In
summary, the variation in TOC data is predominantly due to
large variations in sediment character and not in the
variation in the TOC analytical method.
COMMENT 30: The basic assumptions of the hydrologic computer
models are not included in the SRI or available for review,
either by EPA or the public. The limited information on the
hydrologic computer modeling which is available indicates that
the models may not have been calibrated correctly.
ResDonse - Hydrologic and Hydraulic modeling of Middle Marsh
was conducted to estimate flood flows and the spatial extent
of flooding in Middle Marsh resulting from various design
storms: the 1 month storm through the lOO-year storm.
Determining the extent of flooding in Middle Marsh was an
important aspect of developing a meaningful and representative
sampling program. The model results were used to identify
areas in Middle Marsh that are likely to be inundated with
flood flows from the Unnamed Stream for various design storms
to select sampling locations, and to develop maps of areas of
varying flood frequency.
TR-20 was used to estimate storm flow rates entering Middle
Marsh by way of the Unnamed Stream at Hathaway Road for
monitored storms and various design storms. The peak storm
flow rates were then routed through Middle Marsh using HEC-2, .
a water surface profile model, to determine flood elevations
throughout Middle Marsh.
The contributing drainage area to the Unnamed Stream at
Hathaway Road is approximately 345 acres and is shown in
Figure 1 (see Attached). Field investigations were conducted
to determine watershed characteristics such as land use, flow
patterns, stream channel and flood plain characteristics, and
presence of flow control structures. Based on information
obtained from field investigations and review of plans, the
drainage area was divided into four subdrainage areas in order
to simulate the routing of flows through upstream reaches of
the Unnamed Stream. The delineation of the subdrainage areas
is indicated on Figure 1. Required input information such as
drainage area size, runoff curve numbers and times of
concentration for subdrainage areas are presented in Table 4
(see Attached). Weighted average runoff curve numbers were
determined from existing land uses for hydrologic soil group C
and assuming average antecedent soil moisture conditions (II).
Times of concentration were determined using the SCS Lag
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Method, taking into account flow paths through enclosed
drainage systems where pertinent.
The headwaters of the Unnamed Stream start at the outlet of a
60-inch diameter storm drain outfall located south of the SE
on and off ramps for routes 195 and 140. From this point the
Unnamed Stream flows through six culverts before discharging
to Middle Marsh. Information on each of these culverts is
presented in Table 5 (see Attached). It was assumed based on
the magnitude and locations of storm flow inputs to the
Unnamed Stream and culvert characteristics that storm flows
would pass relatively unimpeded through the four upstream
Culverts, while the twin 48-inch culverts under Hathaway Road
and 72-inch culvert, located 60 feet upstream under the car
wash driveway, may significantly control the passage of flows
to Middle Marsh. To take into account the overall effect of
these downstream controls, detailed routing of various flows
through these culverts was accomplished using the HEC-2 model.
The results of the model were used to develop a rating curve
of elevation versus discharge and storage which was then used
as input to the TR-20 model as a control structure.
TR-20 was used to model the routing of flows through the
upstream reaches of the Unnamed Stream. Information on the
reach characteristics used in TR-20 are presented in Table 6
(see Attached). A schematic of the TR-20 model used to
predict flows discharging to Middle Marsh is shown in Figure 2
(see Attached).
Water surface profiles in Middle Marsh were calculated for
flows predicted by TR-20 using the HEC-2 model. Required
input information for HEC-2 includes cross-sectional data,'
reach length, and friction or roughness coefficients. The
cross-sectional data were based on actual field surveys'
conducted in Middle Marsh and the golf Course along the
Unnamed Stream between Hathaway Road and the Conrail railroad
embankment. The cross-sections were located at points where
hydraulic control structures, such as culverts and weirs exist
and where stream channel and floodplain characteristics change
appreciably. Roughness coefficients were derived from
literature values (Chow, 1959) based on field observations of
channel and floodplain vegetation characteristics. The
complete HEC-2 input data sets used for Middle Marsh have been
placed !n the Administrative Record.
As indicated on the final RI (Metcalf & Eddy, 1991a), flow
monitoring of the Unnamed Stream was conducted at several of
the sUrveyed cross-sections during the rainstorm of April 3-4,
1991. This rain event was a large storm in which 3.17 inches
fell and resulted in significant overbank flooding in Middle
Marsh. To test the accuracy of the models, observed peak flow
levels at the six monitored stations were compared with the
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water surface elevations predicted by HEC-2. As indicated in
Table 7 (see Attached), it was found that the simulated values
are very close to the observed values, indicating the models
are representative of actual conditions.
The modeling effort was an integral part in understanding the
wetland, hydrologic, and habitat functions of Middle Marsh,
and in understanding the likely distribution of contamination
in Middle Marsh which was not fully addressed in previous
studies. The modeling results were primarily used as an aid
in designing a "smart" sampling plan that would provide more
detail on the most contaminated areas of the wetland rather
than expending unneeded effort and funds on relatively
uncontaminated areas. It should be noted that the remediation
plan for Middle Marsh is based on the PCB sampling data and
the ecological risk assessment, and not the results of the
hydrologic and hydraulic models.
COMMENT 31: The FS for Middle Marsh did not adequately
evaluate potentially appropriate remedial alternatives for
Middle Marsh and failed to address critical aspects of the
preferred and contingency remedies. EPA eliminated
technologies because they are unproven or would require bench
and pilot scale testing.
ResDonse - EPA did not eliminate alternatives based solely on
the need for bench and pilot-scale testing. The need for
extensive testing is a valid consideration when evaluating
alternatives, since it points to questions of effectiveness,
implementability, and cost.
Examination of Table 8-2, of the FS, titled "Summary of"
Alternative Screening for Middle Marsh," shows that the need
for bench and pilot-scale testing was not used to eliminate.
alternatives. The only alternative for which the need for
treatability studies was specifically listed in the table was
in-situ bioremediation, and the statement was given a "0"
rating, meaning that the statement had no effect on selection
or rejection of the alternative. When treatability studies
are needed this fact was discussed in the text of the FS, as
is appropriate, but it was not used as a screening tool.
The fact that a technology is unproven was used as only one of
many criteria in screening alternatives for the Middle Marsh
site, as is appropriate during this phase of the FS process.
The fact that a technology is unproven is an important part of
an evaluation of its effectiveness.. .In "Guidance for
Conducting Remedial Investigations and Feasibility Studies
under-.CERCLA" (U.S. EPA, 1988), contractors are directed to
evaluate effectiveness based on three criteria, one of which
is "how proven and reliable the process is with respect to the
contaminants and conditions at the site." .
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The NCP specifies that innovative technologies be considered
when they offer the "potential for comparable or superior
treatment performance or implementability, fewer or lesser
adverse impacts than other available approaches, or lower
costs for similar levels of performance than demonstrated
technologies.'" As an innovative technology, in-situ
bioremediation was retained beyond the initial screening of
remedial technologies and evaluated as an alternative. It was
at this stage, through evaluations of effectiveness,
implementability, and cost, that in-situ bioremediation was
screened out. The evidence that biodegradation of PCBs takes
place naturally in soils and sediments is not sufficient to
recommend in-situ bioremediation as a treatment technology at
this time, because current evidence does not demonstrate the
potential for comparable treatment performance, fewer impacts,
or lower costs. For example:
.
The research papers cited by GEI discuss the limitation
that aerobic bacteria can only degrade the low
chlorinated PCB congeners. Unterman (1991) states that
"Aroclors 1254 and 1260 are too highly chlorinated to be
reasonably degraded by currently-existing bacterial
strains and will probably require an anaerobic
treatment. II It must be noted that no anaerobic PCB-
degrading bacteria have been identified or isolated and
that no such process currently exists. Current
researchers generally acknowledge that degradation of
Aroclor 1254 would require the development of dual
anaerobic/aerobic processes for its destruction. This
two-stage process is still a concept and has never been
demonstrated.
.
Anaerobic/aerobic in-situ bioremediation processes are at
the level of an emerging technology, as opposed to an .
innovative technology. Pilot-scale studies have yet to
be performed. During preparation of the FS, M&E
engineers had several conversations with engineers and
scientists at the General Electric Research and
Development Center. GE's research group is at the
forefront of PCB biodegradation research. GE scientists
have just begun (in August of 1991) their first pilot
study of a combined anaerobic/aerobic process for
biodegradation of PCBs in Hudson River sediments, after
years of preparation. However, GE has no plans to
develop and market the process as a remediation
technology (Abramowicz, 1990). Even if GE's pilot test
proves successful, the question of implementability then
arises. There are no vendors who have successfully
bioremediated PCBs in-situ. Years of development will be
needed before the technology could be implemented on any
site at full scale.
-------
.
Meanwhile, adverse impacts to the environment would still
be occurring due to PCB contamination. Other processes
(e.g. solvent extraction) could address the entire
problem well before a potentially effective in-situ
bioremediation process could be developed, let alone
implemented.
As discussed in the FS, it is also questionable whether
wetland impacts would be eliminated by use of in-situ
bioremediation. Placement of an oxygen injection system
into the wetlands will undoubtedly cause disturbance of
the sediments, and may require removal of all vegetation
from the area. In addition, the time required to
remediate the sediments in this manner is likely to be
quite long, on the order of years. Hence, the
disturbance would take place for a long time, while the
disturbance due to excavation will be relatively short-
lived.
.
Allowing the PCBs to biodegrade naturally, without
addition of oxygen, organisms, or nutrients, is not an
acceptable option. Certain congeners may never
biodegrade, while those that do will require excessive
lengths of time. For example, the work of Lake et al.
(1989) on New Bedford Harbor sediments, which appeared in
Appendix B, Volume I of the comments on theFS, lists
half-lives for PCBs ranging from 7.5 to 465 years,
depending on the sample and the congener.
There is little evidence that in-situ bioremediation will
effectively remediate Middle Marsh within an acceptable time
frame. The combined aerobic/anaerobic process which would be-
needed is not yet developed sufficiently to be applied to a
fUll-scale remediation. The level of effort needed to develop.
it would far exceed what would be needed to test and implement
other technologies such as solvent extraction, and the
potential advantages in terms of wetlands impacts are
questionable.
.
The cost estimate for the contingency alternative does not
consider residual sediment toxicity because the solvent
extraction process is not expected to yield treated sediments
containing residual toxicity. The sediments will be treated
such that the PCB concentration is below cleanup levels, thus
residual PCB levels will pose minimal risk. Residual solvent
levels will also pose minimal risk. For example, if the
B. E. S. T. process were to be used, the residual sol vent,
triethYlamine, would be readily biodegraded by common soil
bacteria. If liquefied propane extraction were to be used,
residual solvent would not be of concern since the solvent
(propane) would vaporize from the sediments under ambient
conditions. In addition, the remediation timetable is not
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believed to be unrealistic because the solvent extraction
technology vendors market 100 ton-per-day systems which should
be readily implementable at Middle Marsh.
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2.
Comments from Boward T. Weir, Horgan, Lewis' Bockius, and
Laurie Burt, Foley, Boag , Eliot, on behalf of Cornell-
Dubilier Electronics, Inc. and Federal Pacific Blectric
Company
COMMENT 1: EPA proposes to spend $2,800,000 to protect from
the alleqed effects of PCBs a single animal of a single
species -- the mink -- who has never been found at the Study
Area, and who in all likelihood does not live in the Study
Area.
ReSDonse - EPA believes that the selected remedy is cost-
effective. Of the remedies evaluated in the FS, the selected
remedy is the least expensive way to meet cleanup goals
established for the operable unit. Mink were selected by EPA
as an indicator species to represent small carnivorous mammals
that use Middle Marsh. As mammals are suspected to be the
most sensitive species, selection of mink is intended to
reduce the uncertainty in the exposure assessment in its
attempt to protect a variety of environmental receptors.
Analysis of the habitat, prey, and home ra~ge requirements
suggests that mink using the site may either live, breed, and
feed on-site, or live off-site and feed on-site. Mink tracks
were observed and photographed in Middle Marsh near the
unnamed stream during a site visit on August 26, 1991. The.
mink tracks were identified by a certified wildlife biologist
(petron and Boucher, 1991). A detailed discussion of the use.
of the mink as an indicator species, is given in Section C.l.,
in response to Comments 10 through 13. This section includes
a discussion of the mink's range and behavior.
Comment 2 - EPA proposes remedial actions which will destroy
hundreds .of trees and other vegetation, and most likely
numerous types of animals and other natural environmental
features, such as wildlife habitat.
Response: EPA does not believe that this remedial action
will devastate Middle Marsh or its associated wildlife. EPA
Region I's Waste Management Division has consulted closely
with Region I's Wetland Protection Section and the
-------
Massachusetts Department of Environmental Protection in
developing the selected and contingency remedies. Both the
selected remedy and the contingency remedy specifically
include methods to minimize and mitigate damage to vegetation
and habitat. 'EPA is confident that the ecological conditions
in the area will remain following remediation, that planted
trees and natural sUccession will reestablish forested wetland
in these areas, and that without PCBs, Middle Marsh will offer
suitable habitat for a wider diversity of species. EPA has
determined that disturbance of wetlands and floodplains is the
only practicable alternative that would address PCB
contamination in the Middle Marsh study area while minimizing
adverse impact on the terrestrial and aquatic ecosystem.
Further discussion on this issue is provided in Section C.l.,
in response to Comments 25, 26 and 27.
Comment 3 - EPA can schedule remedial activities at the
Disposal Area and Middle Marsh to avoid an additional cost of
almost $5,000,000 that its contingent alternative would
require. A cell can be left open in the cap that could
accommodate the excavated material from the study area.
ResDonse: There are two reasons why EPA believes that it
would be inappropriate to put a hold on implementation of the.
First Operable Unit until the implementation of the Second
Operable Unit can be coordinated. First, the contamination,
at the First Operable Unit presents the most urgent and
serious threat to human health and the environment at the
Site. Significant delay in implementing protective measures
to address the contaminated groundwater, soils and sediments
at the First Operable Unit (the principal threats at the Site)
would be inappropriate. The NCP and its preamble encourage
using operable units as early actions to eliminate, reduce or
control the hazards posed by a site or to expedite site
cleanup. ss Fed. Reg. 8704. At this site, EPA decided in
1989 to _,split the Site into two operable units so that
protective measures at the Disposal Area and Unnamed Stream
could be implemented promptly at those locations, while EPA
conducted further studies to characterize risks at Middle
Marsh and analyze remedial approaches for Middle Marsh in
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greater detail. It does not make sense to decide now to wait
until negotiations with potentially responsible parties (and
perhaps litigation) regarding the Middle Marsh Operable Unit
are over, an agreement is reached or an administrative order
is issued under Section 106 of CERCLA, and design activities
for the Middle Marsh Operable Unit are completed, before
addressing the principal threat at the First Operable Unit.
EPA does not agree that leaving one cell open under the cap at
the Disposal Area is an environmentally sound option, based on
current information. Unsolidified and uncapped soils even at
PCB levels below 50 ppm in an uncompleted cell could present
a significant threat of release and recontamination of
remediated areas. In addition, infiltration in the uncapped
area could contribute to migration of contaminated groundwater
including seepage of contaminants to the Unnamed Stream.
Further discussion is provided in Section C.l., in response to
Comment 20.
Second, in signing the Consent Decree relating to the First
Operable Unit, EPA, the Commonwealth of Massachusetts and 14
PRPs have agreed to a schedule of activities for the First
Operable Unit. This agreement was approved by the United
States District Court in April 1991 and is legally binding on.
EPA. If EPA acted unilaterally in extending the schedule
dates without the consent of the other parties to the Consent.
Decree, the 14 signatory PRPs could be adversely affected --
for example, the PRPs' contracts with design contractors and
subcontractors would have to be extended out for longer
periods of time, causing the PRPs' costs to increase. Based
on the preliminary timetables established under the Consent
Decree, it is expected that remedial design for the First
Operable Unit will be completed by March, 1994. If additional
design activities necessary to implement the selected remedy
for the Middle Marsh Operable Unit are not completed in time
to be integrated into the design of the First Operable Unit,
then the contingency remedy will be implemented in place of
the selected remedy.
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If, however, all parties to the Consent Decree for the First
Operable Unit can reach agreement, EPA would consider a short
extension of time (consistent with the need to address
principal threats quickly) that would permit coordination of
the selected remedy for Middle Marsh with the remedy for the
First Operable Unit, through an Explanation of Significant
Differences ("ESD") if appropriate.
Comment 4 - For sediments, EPA used the equilibrium
partitioning method which relies on certain assumptions which
bear no relation to the actual environment at Middle Marsh.
Employing the method applied to soils would have yielded a
more appropriate cleanup level.
Res~onst: The application of sediment quality criteria for
this site is consistent with EPA guidance. The equilibrium
parti tioning method has only been applied to Qii.. small,
("""";"'.'.'
permanently flooded, aquatic area within Middle Marsh. EPA
determined, based on site-specific studies, that the aquatic
areas in Middle Marsh could support an aquatic pathway for
bioaccumulation. The methods used in the RI to determine
areas suited to the equilibrium partitioning method and
approach taken to derive cleanup levels are described in
detail in Section C.l., in response to Comments 10 through 15. .
Comment 5 EPA arbitrarily applied cleanup levels to
particular portions within the Site in an apparent and ill-
founded attempt to justify a cleanup. If cleanup levels are
applied against site-average PCB concentrations, no risk to
wildlife is presented by the site.
Res~onse: EPA does not agree with the use of area averaged
PCB concentrations to set cleanup levels. Cleanup levels were
applied on a point-by-point (never to .be exceeded) basis. EPA
believes this method is especially appropriate for Middle
Marsh, and for mink and other species with feeding habitats
similar to mink which concentrate their feeding in a core
area. Applied as a never to be exceeded basis, remediation of
PCBs to the cleanup levels would ensure that the mink and
-------
other sensitive species would be protected regardless of where
they spend their time or obtain their food. A discussion of
the development of cleanup levels is provided in Section C.1.,
in response t~ Comments 13 and 14.
CommeDt , - Any risk the Site poses to mink, it probably poses
to only a single mink.
ResDonse: Mink were selected by EPA as an indicator species
to represent small carnivorous mammals that use Middle Marsh.
The use of mink as an indicator species is described in
response to Comment 1 and a detailed discussion is given in
Section C, in response to Comment 10 through 12.
CommeDt 7 - The conditions in the aquatic sediments in the
unnamed stream and Middle Marsh do not match the underlying
assumption for the derivation of water quality criterion
including the bioconcentration factor of 45,000.
ResDonse: Site-specific data has shown that the benthos in
Middle Marsh bioaccumulate PCB from sediments via the pore
water. EPA believes that a PCB concentration of 0.014 IJg/l in
the pore water would result in an aquatic food web with PCB.
concentrations protective of mink reproduction. A detailed
discussion of the use of the SQC is given in Section C.l., in -
response to Comment 14.
CommeDt 8 - EPA improperly calculated the cleanup levels for
terrestrial/wetland exposure. Specifically, if a more
realistic figure of 50 acres for the home range of the mink
should have been used, the cleanup levels would have been set
at higher levels.
ResDonse: EPA believes that its figures for the home range
for mink are appropriate. Although on the lower end of home
range sizes, Middle Marsh and the surrounding habitat are of
sufficient size to support mink because of its dense habitat
and abundant prey. The use of the minimum range is reasonable
-------
considering the expected home range constriction due to
suburban habitat partitioning. Furthermore, all the
documented minimum home ranges were in a situation of dense
cover and/or high prey numbers (Allen, 1986; Gerell, 1979).
Mink often concentrate their feeding in core areas within
their home range which are usually characterized by high prey
densities and are in relatively close proximity to streams
(Allen, 1986). The golf course fairways cannot be excluded
from the home range or be considered an effective barrier to
the travel of mink. The unnamed stream traverses the course
in an approximately perpendicular manner and, with its
attendant emergent vegetation and heavier vegetated side
slopes along the stream and ponds, provides an excellent
travel corridor. In addition, the stream is repeatedly
crossed with cart paths which have culverts. The culverts
provide additional security cover. Therefore, mink can be
expected to readily follow the stream for travel between
Middle Marsh and the adjacent wetland or the Apponagansett
Swamp.
EPA does not believe that daytime golf activities would hinder
this primarily nocturnal activity. The 'golf fairways more
likely act as open fields in influencing the mink behavior
because there are no obtrusive human structures such as
buildings. Although most wild mammals, carnivores in.
particular, are wary of humans, these animals often coexist
easily with humans given their nocturnal nature. Recent.
literature indicates that mink are "curious and bold and may
try to steal fish caught by fishermen" (Godin, 1977) and are
"tolerant of human activity" (Allen, 1986).
Additional description of the rationale behind the use of the
home range n~mber in calculating cleanup levels is described
in response to Comment 12 in Section C.l.
Comment' - EPA's bioaccumulation factor for the frog of 0.22
is incorrect because it is calculated by averaging station-by-
station frog-to-sediment ratios. By first averaging the frog
tissue concentrations, and then the soil/sediment
concentrations, and then dividing the two averaged values, the
more appropriate bioaccumulation factor of 0.08 is obtained.
-------
ResDonse - Field observations made by EPA's consultant while
sampling Middle Marsh, as described in Tables 3-1 and 3-2 of
the RI (Metcalf & Eddy, 1991a), indicate a variation in
sediment/soil ~haracteristics from one area in the wetland to
another. Some samples contained visible twigs, leaves, moss,
and biodegraded plant matter and others were soil-like with
less organic matter. Due to the variation in sediment/soil
characteristics, EPA felt that an average of BAFs calculated
for each frog concentration and the associated sediment/soil
concentration would be more accurate than averaging the
sediment/soil concentrations and the frog concentrations and
calculating one BAF. This methodology was used consistently
to calculate site-specific BAFs in the ecological assessment.
Comment; 10 - EPA failed to consider the effect of natural
restoration processes on the study area. EPA's failure to
address the effects of sedimentation of clean sediments over
sediments containing contaminants in the Study Area is
arbitrary and capricious and contrary to law.
ResDonse: EPA does not believe that natural biodegradation
processes will result in attainment of levels of PCBs which
are protective of biota at the Middle Marsh Operable Unit
within an acceptable time frame. PCBs have been present at.
the .Sullivan's Ledge site for decades, perhaps as long as
fifty years. Although there is no evidence of disposal of .
PCBs at the Site since the early 1970's (almost twenty years
ago), elevated concentrations of PCBs still persist at the
Disposal Area and in the Middle Marsh Operable Unit. EPA does
not believe that dissolution, volatilization, or
biodegradation have caused significant reductions in PCB
concentrations in the Middle Marsh Operable Unit. PCBs in the
environment are generally resistant to physical and biological
degradation and have a high affinity for organic material such
as the sediment/soil in Middle Marsh. Indeed, certain PCB
congeners may never biodegrade; others will only biodegrade in
an excessive amount of time. A detailed discussion of natural
degradation is included in Section C.l., in response to GEI
Comments 7 and 31.
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In addition, once excavation has been performed to remove
soils and sediments contaminated above the cleanup levels,
natural restoration processes would not be appropriate for
Middle Marsh a,nd the surrounding wetlands because the wetlands
are subject to substantial changes in water surface elevation
and high stream velocities. If excavated areas were not
restored, EPA believes that there would be severe erosion
. problems, water quality degradation, and failure of any
attempt to revegetate excavated areas due to the increased
insurgence of stormwater, erosion, and sedimentation.
"
In addition, federal and state ~i require replacement of
X';';';";';':';v;';';';';';,;,;,
sediments and restoration of disturbed wetlands. Executive
Orders (E.O.) 11988 and 11990 require that actions in
floodplains or wetlands restore and preserve the natural and
beneficial values of the wetland and floodplain areas. E.O.
11990 requires that actions in wetlands "consider the
maintenance of natural systems including conservation and
long-term productivity of existing flora and fauna, ... [and)
hydrologic utility."
Comment 11 - EPA has failed to adequately weigh the harm to
the environment which inevitably will result from its proposed
remedy against the benefits that will result if natural.
restoration is allowed to occur.
ResDonse: The ecological remediation criteria for Middle
Marsh and the adjacent wetland were established to protect
species that inhabit, or migrate to, Middle Marsh and
downstream habitats. The remedial action was selected based
on objectives outlined in the FS, including "minimize the
destruction, loss, or degradation of wetlands, and preserve or
enhance the natural and beneficial values of wetlands"
(Metcalf & Eddy, 1991b). EPA has determined that disturbance
of wetlands and floodplains is the only practicable
alternative that would address PCB contamination in the Middle
Marsh study area while minimizing adverse impact on the
terrestrial and aquatic ecosystem. This issue is discussed in
detail in the ROD and in Section C.l., in response to Comments
25 and 26.
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L.
CommeD~8 from Prank c. Hun~ina~oD. Wide~~. Slader , Goldman.
P.C.. on behalf of 12 Po~en~iallv Res~onsible Par~i..
{.
EPA's responses ~o the comments in the "Summary of Technical
Comments" section of Mr. Huntington's letter are contained in
EPA's responses to comments submitted by GEI on behalf of the
same PRPs. Responses to other comments raised by Mr.
Huntington are given below.
"
Commen~ 1 - There is no basis for EPA to depart from the
original "no action" determination.
Res~onse: This comment mischaracterizes the history of EPA' s
consideration of remedial approaches for the Middle Marsh
Operable Unit. EPA had never previously made a final "no-
action" determination. Rather, in the 1989 Proposed Plan, EPA
~ronosed a no-action alternative for Middle Marsh, as part of
a site-wide remedy. At that time, EPA discussed two other
"action" alternatives, and specifically sought public comment
on how to achieve a protective remedy for the Middle Marsh
area, given the need to balance the benefits of removing
contaminants from Middle Marsh.against the need to protect a
functioning, valuable wetland from temporary disruption. At
the end of the public comment period, based in part on.
comments received from state and federal officials over the
previous year and in part on further consideration within EPA .
of the issues, EPA decided that further data was needed,
particularly site-specific data on bioaccumulation and a
better understanding of the aquatic and terrestrial organisms
that inhabit the Middle Marsh ecosystems. This approach of
splitting off an operable unit for further investigation,
while addressing principal threats more expeditiously, is
consistent with the NCP.
The comprehensive studies have now been completed, and EPA now
has sufficient information to make a reasoned, careful
decision that is consistent with CERCLA, the NCP, and EPA
guidance. The Metcalf & Eddy Remedial Investigation (1991),
which included bioaccumulation studies, showed that PCBs in
portions of Middle Marsh pose an unacceptable risk to site
-------
biota and, in order to be protective of the environment,
contaminated sediment/soil must be excavated. Further
discussion of EPA's decision to undertake further studies is
provided in Section C.l., in response to Comment 9.
Comment 2 - EPA's remedy ,selection process for Middle Marsh
did not adequately address the three major criteria
(effectiveness, implementability and cost).
ResDonse: The RI concluded that remedial action was
necessary to reduce exposure of aquatic and terrestrial
organisms through food chain bioaccumulation and direct
contact with PCB-contaminated sediments, pore water, surface
water and soils. Chapter 9 of the FS provides a detailed
analysis of effectiveness, implementability, and cost for each
of the alternatives evaluated. Particular attention was given
to the long-term effectiveness of each action in attaining the
remedial action objectives -- i.e. reducing risk to aquatic
and terrestrial organisms in the environment, and protecting
and enhancing wetland and floodplain values. The FS included
a comprehensive analysis which compared the relative
performance of each alternative in relation to nine criteria
set out in the NCP, including effectiveness, implementability,
and cost.
Comment 3 - The preferred alternative is not cost-effective.
The proposal to spend $3 million, and perhaps as much as $8 .
million or more, with the goal of avoiding one chance in
10,000 that one female mink (which probably does not even
exist) might become sterile is a clear violation of the NCP's
mandate that remedies be cost-effective.
ResDonse: EPA disagrees with this comment. The selected
remedy and the contingency remedy are cost-effective. EPA has
followed the process set out in the NCP for choosing a cost-
effective remedy: EPA evaluated the long-term effectiveness,
the reduction of mobility and toxicity, and short-term
effectiveness of the remedial alternatives, including the "no-
action" alternative, to determine the overall effectiveness of
each remedial alternative; EPA then evaluated the overall
-------
effectiveness of the remedial alternatives to the cost of the
alternatives.
EPA concluded that the excavation of soils and sediments
contaminated .with PCBs above the cleanup levels in Middle
Marsh and the Adjacent Wetland, when combined with measures to
minimize and mitigate damage to the wetland areas, is the most
effective remedy in reducing risks to aquatic and terrestrial
organisms. On the other hand, EPA does not believe that a "no
action" alternative would be protective. EPA does not believe
that natural degradation processes will reduce PCB levels in
the Middle Marsh Operable Unit to levels that are protective
of wildlife with an acceptable time frame, if at all. The
half-lives of PCBs can be as great as 465 years. (See
Response to GEI Comments 7 and 31 and Morgan, Lewis Comment
10). While the NCP recognizes that there may be a range of'
protective remedies, with some more effective than others, it
is EPA's judgment, after reviewing all the data, that the "no
action" remedy does not fall into the range of protective
remedies.
The role of cost in selection of CERCLA remedies is carefully
spelled out in the NCP. The preamble to the NCP is clear that
"cost can only be considered in selecting a remedy from among
protective alternatives." 55 Fed. Reg. 8726. Of the remedial
alternatives which EPA considers protective, the selected.
remedy provides the best proportion between overall
effectiveness and cost. The selected remedy is the least.
expensive of the action alternatives.
In the event that the selected remedy cannot be implemented
within the timeframes discussed in the ROD, the contingency
alternative provides a cost-effective remedy. For the reasons
discussed in EPA's response to Morgan Lewis Comment #3, EPA
believes that indefinitely delaying the implementation of the
remedy for the First Operable Unit could be inconsistent with
the NCP and with the terms of the Consent Decree entered by
the District Court in April 1991. If it is impossible to
implement the selected remedy without significantly delaying
the remedy for the First Operable Unit, then the contingency
-------
remedy provides the balance between overall effectiveness and
cost.
Mink were selected by EPA as an indicator species to represent
small carnivorous mammals that Use Middle Marsh. As mammals
are sUspected to be the most sensitive species, ,selection of
mink is intended to reduce the uncertainty in the exposure
assessment in its attempt to protect a variety of
environmental receptors. A detailed discussion of the Use of
the mink as an indicator species is given in Section C.l., in
response to Comments 10 and 11.
Comment.. - The preferred remedy does not comply with the
Massachusetts Wetlands Regulations that provide that "no
project may be permitted which will have any adverse effect on
specified habitat sites of rare vertebrate or invertebrate
species" and that if a project will alter a resource area
which is part of the habitat of a rare species, the project
"shall not be permitted to have any short or long term adverse
effects on the habitat of the local population of that
species."
Resoonse: EPA believes that the selected and contingency
remedies will comply with the substantive portions of
Massachusetts wetlands regulations. Those regulations at 310.
om' 10.00 establish procedures for a variance from portions of
the regulations, if: (i) there are not reasonable conditions.
or alternatives that would allow the project to proceed in
accordance with the regulations: (ii) mitigating measures are
proposed that allow the project to contribute to the interests
identified in the Wetlands Protection Act; and (iii) the
variance is necessary to accommodate an overriding community,
state or national public interest. The Massachusetts
Department of Environmental Protection has advised EPA that
the proposed remediation appears to meet the variance criteria
of 310 CMR 10.58, with the condition that the Spotted Turtle
and Mystic Valley Amphipod serve as biological indicators of
habitat restoration, if appropriate. The wetland restoration
program will evaluate methods for using these two state-listed
-------
species of special concern as biological indicators of habitat
restoration.
"
Comment 5 - EPA's selection of a contingency alternative is
inconsistent with the NCP because the extra cost of $5 million
would result solely from EPA's refusal to integrate the
schedules for remediation of the Sullivan's Ledge Disposal
Area and Middle Marsh operable units. The NCP states that use
of operable units "should not be inconsistent with or preclude
implementation of the expected final remedy for the whole
site."
Res~onse: EPA disagrees with this comment. EPA's use of
operable units to address contamination at the Sullivan's
Ledge site is consistent with the NCP. First, in choosing the
selected remedy in this ROD, EPA has made every effort to
ensure that the Middle Marsh Operable Unit remedy is in fact
consistent with the First Operable Unit remedy. The selected
remedy was designed to minimize duplication of activities and
to minimize costs. The contingency remedy will only be
triggered if such coordination is not possible.
Second, the NCP makes it clear that it is appropriate to
rernediate sites in phases using operable units to eliminate,
reduce or control site hazards or to expedite the completion.
of total site cleanup. In this case, EPA concluded that
separating Middle Marsh out as an operable unit would allow.
implementation of the remedy at the Disposal Area and Unnamed
Stream to proceed, without waiting for the conclusions of
additional studies for Middle Marsh.
EPA is concerned that, unless a contingency remedy is
available, the delays associated with the Middle Marsh
Operable Unit (e.g. protracted litigation) could potentially
prevent implementation of the remedy for the First Operable
Unit for an indefinite ~eriod of time. Litigation under
CERCLA can be extremely complex, lasting many years. EPA
wishes to avoid a scenario where implementation of the remedy
for the First Operable Unit -- which is designed to contain
and treat the principal threats at the Site -- would be
-------
significantly delayed. If capping the Disposal Area is
delayed, the contaminated soils could continue to migrate to
downstream areas including Middle Marsh via the Unnamed Stream
and would continue to be a threat to public health and the
environment. ' Further discussion of this issue is provided in
response to Morgan Lewis Comment #3 and in Section C.l., in
response to GEI Comment 20.
Commen~ , - The contingency remedy is not cost-effective.
There would be no significant risk to human health or the
environment from briefly delaying the installation of the cap
at the Disposal Area, should that be necessary until the
excavated Marsh sediments are ready to be placed there, or
from briefly stockpiling the excavated sediments from the
Marsh until the cap is ready.
EPA Response - See EPA's response to Morgan Lewis Comment #3
and GEI Comment #20 and Comment 5 above. If capping the
Disposal Area is delayed, PCB-contaminated soils could
continue to migrate to downstream areas, and would continue to
present a threat to the environment, and if contaminant levels
increase, to human health. Leaving unsolidified and uncapped
soils at levels below 50 ppm in an uncompleted cell would
present a significant threat of release and recontamination of
remediated areas.
4.
Comments from MCGregor, Shea and Doliner on behalf of Bri~tany
Dyeing and Printing Corpora~ion
COMMENT 1 - The 1989 NO-Action alternative remains the most
reasonable and supportable option. Under the NO-Action
alternative, institutional controls on site access and use,
and monitoring of contaminant concentrations could be
required.
ResDonse: 'The NO-Action alternative and the Limited Action
alternative were not chosen as the selected or contingency
remedy because they would not be protective of the environment
and would not attain ARARs. Additional descriptions of the
-------
rationale for the selection of the remedies are given in
response to Comment 1 in Section A.3., Comment 9 of Section
C.l. and Comment 10 of Section C.2.
COMMENT 2 - The negligible risks to aquatic organisms and
predators from levels of PCBs below the 50 ppm Toxic
Substances Control Act hazardous threshold do not support
performance of the $2.8 million preferred remedy.
ReSDonse: EPA has determined that actual or threatened
releases of hazardous substances from contaminated sediments
in Middle Marsh and the Adjacent Wetland, if not addressed by
implementing the response action selected in the ROD, may
present an imminent and substantial endangerment to biota
present in the environment at Middle Marsh and the Adjacent
Wetland. A description of the results of the ecological risk
assessment is given in Section VI.B. of the ROD.
EPA has further determined that none of the alternatives to
excavation, including no-action, would be able to achieve the
overall purpose of the project, which is to reduce risk to
environmental receptors at the Site, without causing other
significant adverse impacts to the environment. Given the
need to excavate, the selected remedy is cost-effective, as
summarized in Section XI.C. of the ROD and described in EPA.
response to Comment 2 in Section A.l. and Comment 1 in Section
C.2.
COMMENT 3 - EPA's preferred alternative will result in
inadequately estimated adverse impacts to wetlands.
ReSDonse: EPA does not believe that this remedial action
will devastate Middle Marsh or other wetlands. Performance of
this cleanup remedy will meet all applicable or relevant and
appropriate federal and state requirements. Further
discussion on this issue is provided in Section C.l., in
response to Comments 25, 26 and 27, and in Section C.2., in
response to Comment 2.
-------
REFERENCES
Abramowicz, D.A., 1990. Personal communication with B. Weir of
Metcalf & Eddy, July 23, 1990. General Electric Research and
Development Center.
Allen, A. W., 1986. Habitat sUitability index models:
U.S. Wildlife Service Biological Report 82 (10.127).
Boucher, P.M., J.T. Maughan and J. Downing, 1990. Ecological
Assessment and Modeling of a Contaminated Wetland.
Proceedings of the 11th National Conference, Hazardous
Materials Control Research Institute.
Mink.
/)
Charters, D. W., 1991. Environmental Assessment, Middle Marsh
SUllivan's Ledge Site, New Bedford, Massachusetts, Final
Report. U.S. EPA, Environmental Response Branch (in press).
Chow, 1959. Open-Channel Hydraulics.
MCGraw-Hill Book Company.
Copeland, J. 1991. Letter from J. Copeland, Division of Fisheries
and Wildlife, to C. Reinganum, Massachusetts Department of
Environmental Protection on May 9, 1991.
Coward in , L.M., V. Carter, F.C. GOlet, and E.T. LaRoe, 1979.
Classification of Wetlands and Deepwater Habitats of the
Uni ted States. U. S. Department of the Interior, Fish and
Wildlife Service, FWS/OBS-79/31.
DeGraaf, R.M., and D.D. RUdis, 1983. New England Wildlife:
Habitat, Natural History, and Distribution. U.S. Department
of Agriculture. Northeastern Forest Experiment Station..
General Technical Report NE-108.
Ebasco Services Incorporated, 1987. Phase I Remedial Investigation
Report, SUllivan's Ledge Site, New Bedford, Massachusetts.
EPA Contract No. 68-01-7250.
Ebasco Services Incorporated, 1989. Volume I Draft Final, Remedial
Investigation, Sullivan's Ledge Site, New Bedford,
Massachusetts. EPA Contract No. 68-01-7250.
Eisler, R. 1986. Polychlorinated biphenyl hazards to fish,
wildlife, and invertebrates: a synoptic review. U.S. Fish
and Wildlife Service Biological Report 85 (1.7).
Environmental Science and Engineering, 1978, Environmental
Assessment of Polychlorinated BiphenYls (PCBs) Near New
Bedford, MA Municipal Landfill, EPA156016-781006, Office of
Toxic SUbstances, Washington, DC.
-------
Gerell, R., 1969. Activity patterns of the mink (Mustela viso~)
Schreber in southern Sweden. Oikos 20:451-460.
Gerell, R., 1970. Home ranges and movements of the mink in
southern Sweden. Oikos 21:160-173.
GOdin, A.J., 1977. Wild Mammals of New England.
University Press, Baltimore.
Griffin, R.A., and E.S.K. Chian, 1980. Attenuation of water-
soluble polychlorinated biphenyls by earth materials. U.S.
EPA, Municipal Environmental Research Laboratory, Office of
Research and Development, Ci~cinnati, OB, EPA-600/2-80-027.
The Johns Hopkins
Griffin, R.A., R. Clark, M. Lee, and E.S.K. Chian, 1978. Disposal
and removal of polychlorinated biphenyls in soil, In: D.
Schultz (ed.). Land disposal of hazardous waste. U.S. EPA,
Cincinnati, OH 45268, EPA-600/9-78-016, pp. 169-181.
Lake, J.L., R.J. Pruell, and F.A. Osterman, 1989. Dechlorination
of PCBs in Sediments of New Bedford Harbor, U.S. EPA
Environmental Research Laboratory, Narragansett, RI.
Linscombe, G., N. Kinler, and R.J. Aulerich, 1982. Mink (Mustela
vison). Pages 629 - 643 In: Wild Mammals of North America:
Biology, Management, and Economics, J .A. Chapman and G.A.
Feldhamer, eds. The Johns Hopkins University Press,
Baltimore. 1147 pages.
Mac, M.J., c.c. Edsall, and R.J'. Hesselberg, 1985. Accumulation of
PCBs and Hg by fish and earthworms during field and laboratory
exposures to Green Bay sediments. U.s. Fish and Wildlife
Service -GLFL/AR-85-4.
Mackay, D. and A.W. Wolkoff, 1973. Rate of evaporation of low.
solubility contaminants from water bodies to atmosphere.
Environmental Science and Technology, V.7, pp. 611-614.
Meng, H., E.S.K. Chian, and R.A. Griffin, undated. Effect of humic
acid and soil on volatilization of polychlorinated biphenyls
from water. Cited in: Griffin, R.A., and Chian, E.S.K.
Attenuation of water-soluble polychlorinated biphenyls by
earth materials. U.s. EPA, Cincinnati, OH 45268, EPA-600/2-
80-027, pp. 82-86.
Metcalf & Eddy, 1991a. Final Remedial Investigation: Additional.
Studies of Middle Marsh, Volume I. EPA Contract No. 68-W9-
0036.
Metcalf & Eddy, 1991b. Final Feasibility Study Report of Middle
Marsh, New Bedford, Massachusetts. U.S. EPA Contract No. 68-
W9-0036.
-------
O'Reilly, M., 1991.
Letter to Ms. J. Downing, EPA.
petron, S., 1991. Technical Memorandum from S. petron, Metcalf &
Eddy, Inc. to J. Downing, U.s. EPA.
Peurifoy, R.L., '1979.
Methods. New York:
Construction Plannina.
MCGraw-Hill Book Co.
EauiDment.
a~
Platonow, N.S. and L.H. Xarstad, 1973. Dietary effects of
Polychlorinated biphenYls on mink. Can J. Compo Med. 30:391-
400.
b
Reuter, J.H., and S. Havlicek, 1978. Private communications:
October, Georgia Institute of Technology.
RObbins, L.C., undated. A Permanent Solution to Hazardous Waste:
The B.E.S.T.. Solvent Extraction Process. Resources
Conservation Company, Bellevue, Washington.
Steiner, W., 1991. LEEP: Low Energy Extraction Process.
Presented at the Two-Hour Seminar "Remedial Technologies:
Innovative and Permittable," sponsored by the New Jersey Water
Pollution Control Association Inc., March 6, 1991.
Suddell, G.W., 1988.
Evaluation of the B.E.S.T. Solvent Extraction
Sludge Treatment Technology Twenty-Four Hour Test.
88/055.
EPA/600/S2-
Unterman, R., C.D. Chunn, and M.J .R. Shannon. 1991. Isolation and
Characterization of a PCB-Dredging Bacterial Strain EXhibiting
Novel Aerobic Congener Specificity. Poster Q-49, ASM Meeting, .
Dallas, Texas.
U.S. EPA, 1988. Guidance for Conducting Remedial Investigations.
under CERCLA, Interim Final. EPA/540/G-89/004.
U.S.
EPA, 1989. Risk Assessment Guidance for Superfund
Environmental Evaluation Manual, Interim Final. Office of
Emergency and Remedial Response. EPA/540/1-89/00lA. OSWER
Directive 9285.7-01.
U.S. EPA, 1990. Reducing Risk: Setting Priorities and Strategies
for Environmental Protection. SAB-EC-80-021.
Weimer, L.D., 1989. The B.E.S.T. Solvent Extraction Process:
Applications with Hazardous Sludges, 50ils and Sediments
Presented at the Third International Conference New
Fronti~rs for Hazardous Waste Management, Pittsburgh,
Pennsylvania.
-------
Whitaker, J.O., 1980.
American Mammals.
The Audubon Societv Field Guide to North
Alfred A. Knopf, Inc.
Yoakum & Associates, 1989. PCB BacKground Information Relevant to
the New Bedford Harbor Project.
-------
I.aues rai.ed during the public comment period that will continue
to be of concern a. the aite move. into the RD/RA pha.e are
described briefly below.
EPA will continue to address these i..ues
as more information becomes available during the RD/RA.
1.
Until the contaminated .oil. are removed, questions are
likely to continue to ari8e regarding incident. of
human contact with contaminated 80il. and .ediment..
2.
Because the City of New Bedford i. a PRP, the impact of
the Middle Mar.h cleanup on the City'. finance. could
potentially be a significant public concern.
Public
oppo.ition to the City paying for the cleanup i. likely
to focus onl (1) the fact that no human health risk ha.
been identified and (2) the belief that the cleanup may
not prove effective in the long-term due to the
continued flow of contaminated groundwater into the
area from the Disposal Area.
The public may not .ee
the value of devoting City re80urces to a cleanup
designed to protect animals when the value of the
cleanup i8 weighed again8t other municipal need. .uch
a. police protection and 8chool financing, e8pecially
when the economy i. .low.
3.
Di.ruption of activities at the golf Course and the
quality of the re.toration portion of the cleanup are
likely to be i8.uea that will ari.. when con8truction
of the remedy commence..
101
-------
Table 1 - Solvent Extraction Treatability Study Results for
PCB Contaminated Sediments
Sample Technology Raw Sample Composition Treated Soil Composition Reference
Identification PCBs Oil PCBs Percent Removal
(mg/kg) (percent) (mglkg)
Superfund A Composite B.E.S.T. 68 17 1.1 99.6 Robbins, undated
Superfund B ('13) B.E.S.T. 83 44 1.8 99.6 Robbins, undated
Soils
C B.E.S.T. 4300 1 2 >99.9 Weimer, 1989
E B.E.S.T. 190 0.07 1.6 99.3 Weimer, 1989
F B.E.S.T. 3000 1.5 0.8 >99.9 Weimer, 1989
J B.E.S.T. 19 0.09 0.7 96.9 Weimer, 1989
Natural Gas Pipeline
Compressor Soils
Hot Spot B.E.S.T. 2000 0.38 1.5 99.9 Weimer, 1989
Composite I B.E.S.T. 550 0.66 0.77 99.9 Weimer, 1989
Composite II B.E.S.T. 510 0.14 1.2 99.8 Weimer, 1989
Clay Subsoil lEEP 1500 Nl NU1.5f 99.9 Steiner, 1991
NOTES:
-------
Table 2 - Results of PCB Water Analysis (Aroclor 1254)
Station Surface Water Pore Water
(unfilt.) (filt.) (unfilt.) (filt.)
ME01 O.08J* O.OSJ* 1.5J* O.92J* ..
ME02 O.039J O.022J* O.7SJ O.56J
ME03 O.1J* O.05U O.87J O.64J
ME04 O.05U O.05U 1.7J* 1.1J
ME11 O.05U O.05U 1.6J O.05U
ME14 O.27J O.088J
ME15 O.05U O.19J* O.05U 4.4J
ME17 O.05U O.05U 1.1J* 1.1J*
ME23 O.05U O.05U O.17J* O.04J
ME24 O.061J* O.05U 1.7J* O.05U
ME29 O.083J O.05U O.68J* O.45J*
ME36 O.12J O.069J
SL01 O.9SJ O.01U 3.5J O.02U
SL04 2.00J O.01U 1.8J O.7J
SL14 3.6J O.84J
SL15 1.5J O.01U 7.6J 1.4J
SL17 1.7J O.077J 29J 10J
<>
J - Estimated Value
U - Undetected at Detection Limit
-------
Table 3 - Sullivan's Ledge Soil Analysis
USEPA Sample ID Toe S.D. M&E %RSD M&E %RPD
. 5344A-006 21000 4320.5 17.28 -
31000
23000
.25000
.5344A-022 15000 2581.9 16.14 -
13000
19000
17000
. S344A-031 16000 2217.4 15.03 -
14000
12000
17000
.S344A-067 14000 957.4 7.23 -
14000
13000
12000
..5344A-008 9500 - - 9
-009 8700
.. S344A-014 38000 - - 10
-015 42000
..S344A-019 34000 - - 57
-020 61000
..S344A-022 14000 --- - 15
-023 12000
..S344A-032 19000 - - 30
-033 14000
..S344A-036 500000 - - 4
-037 480000
. .5344A-070 330000 - - 49
-071 200000
. - Indicates Samples Analyzed in Quadruplicate
.. - Indicates Field Duplicates
S.D. - Standard Deviation
RPD - Relative Percent Differences
-------
Table 4 - Catchment and Subcatchment Characteristics
Subdrainage Area Curve 8 Time 01
Area Number Concentration
(acres) (sq. mi.) (CN) tc (hrs)
1 159 0.249 81.4 2.23
2 24 0.037 87.2 1.67
3 67 0.104 81.6 0.83
4 96 0.15 83.3 1.32
(8). Weighted average curve number
Table 5 - Culverts on Unnamed Stream
location Size length Slope
(in.) (ft.) (ft./ft.)
Hathaway Rd. Twin 48 eire. 92 0.0011
Carwash 72 eire. 90 0.0067
Driveway
NW Ramps for 72 eire. 206 0.0053
Rtes. 140 & 195
Rte. 140 north 72 eire. 142 0.0049
of Rte. 195
Rte. 195 east 66 eire. 220 0.005
of Rte. 140
SW ramps for 60 eire. 140 0.0057
Rtes. 140 & 195
Table 6 - TR-20 Reach Information
Reach No. Representative length Slope Mannings
Cross Section- - eft.) (ft./ft.) Roughness coeff.(n)
1 1 990 0.0036 0.1
2 --- 2 290 0.004 0.06
3 3 856 0.0046 0.06
4 4 I 850 0.0058 0.1
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Table 7 - Comparison of Simulated and Observed
Flood Elevations in Middle Marsh
ELEVATION
HEC-2 MONITORED OBSERVED HEC-2 SIMULATED
STATION CROSS-SECTION NO. (Feet) (Feet)
155 13 63.5 63.7
255 '2A 63.6 63.8
645 10 63.8 64.0
1085 9 64.3 64.1
1355 7 65.2 64.5
-------
,-
2000
I.-
o
t
SCALE IN FEET
---........
F1GURE 1. DELINEA nON OF SUBDRAINAGE AREAS
POOR QUALITY
ORI~'~'I.\'-
-------
CHANNEL X.SECTIONS
D--0
3:1~3:1 n-0.1OO
<>--0
3:1 ~ 3:1 n - 0.060
<>--0
3:1 ~ 3:1 n - 0.060
~
2:1 V2:1 E"
,L ,L
LEGEND
-.m STRUCTURE NUMBER 5
o--(D CROSS SECTION NUMBER 1
1-1 0.249 t>- DRAINAGE AREA. SOUARE MILES
81.4 (2.23) RUNOFF CURVE NUMBER
(TIME OF CONCENTRATION -HOURS)
990
[0.39][ 1.33J
REACH LENGTH. FEET
{END AREA COEFF. (x)J {EXPONANT (M)J
nGURE 2. TR.20 SCHEMATIC FOR UNNAMED
STREAM AT HATHAWAY ROAD
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ATTACHMENT A
Formal Community Relations Activities Conducted To Date
-------
ATTACHKEN'l'
A
Formal Community Relations Activities Conducted To Date
at the Sullivan's Ledge Superfund Site
Continuous
BPA maintenance of the sit. mailing list.
BPA Community Relations Plan completed.
9/86
1/88
BPA fact sheet for Remedial Investigation
Phase I.
7/88
BPA fact sheet for Remedial Investigation Phase I
5 II.
7/20/88
BPA public meeting on the preliminary findings of
the RI and Endangerment Assessment.
BPA public notice of the Proposed Plan, comment
period, pubic meeting, and public hearing.
1/23/89
1/27/89
2/6/89
BPA Proposed Plan mailed with press release.
EPA public meeting on the Proposed Plan and
Feasibility Study.
2/7/89-3/27/89
EPA public comment period on Proposed Plan and
Feasibility Study.
2/21/89
EPA public hearing to accept comments on the
Proposed Plan and Feasibility Study.
6/30/89
EPA press release announcing ROD for first
operable unit.
6/30/89
EPA responsiveness summary for the first operable
unit.
7/7/89
EPA public notice announcing the ROD for first
operable unit.
EPA Middle Marsh Remedial Investigation fact
sheet.
4/91
5/21/91
EPA Proposed Plan and press release for the
Middle Marsh operable unit.
EPA public notice of the Proposed Plan, comment
period, public meeting, and public hearing for
Middle Marsh operable unit.
5/24/91
5/28/91
EPA public meeting on the Middle Marsh Proposed
Plan and Feasibility Study.
EPA public comment period on the Middle Marsh
Proposed Plan and Feasibility Study.
5/30/91-7/31/91
6/21/91
EPA press release announcing extension of public
comment period.
EPA public hearing to accept comments on the
Middle Marsh Proposed Plan and Feasibility Study.
6/26/91
9/27/91
EPA responsiveness summary and press release for
-------
ATrAcmu::rr B
-------
~NITED STATES OF AMERICA
ENVIRONMENTAL PROTECTION AGENCY
2
BOSTON REGION
3
4 In the Matter 01:
5 PUBLIC HEARING RE:
6 PROPOSED CLEANUP PLAN FOR
MIDDLE MARSH
7 SULLIVAN'S LEDGE SUPERFUND SITE
8
9
June 26. 1991
Wednesday
10
11
Days Inn
Hathaway Road
New Bedford. Massachusetts
12
13
The above-entitled matter came on for hearing.
14 cursuant to Notice. at 7:30 o'clock c.m.
15
16 BEFORE:
JIM SEBASTIAN. Hear~ng Officer
Community Relations Coordinator
U. S. Environmental Protection Agency
and
JANE DOWNING
Site Manager/Sullivan's Ledge Sucerfund
U. S. Environmental Protection Agency
(HRS-CAN3) JFK Federal Building
Boston. MA 0220~-2211
Site
17
18
19
20
21
JAMIE MAUGHAN
Metcalf and Eddy
22
23
24
25
APEX REPORTING
Registered Profess~~nal Recorters
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17
18
19
20
21
22
23
24
25
..
I N D E X
---------
2
3
4
IQE1~
~Es~t:;sE
E:~!ag
5
6
Opening Comments
Mr. Sebastion 3
Ms. Downing 7
Attendees 13
Attendees 26
7
Description of Proposed Plan
8
Question and Answer Session
9
rormal Cc.mments
10
11
12
13
14
15
16
AF'EX REPORT I NG
.Registered Professional Reporters
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..
J
1.
I
I .
.
~
]
:3
E_e_Q_~_s-g_Q_l_~_~_~
2
COMMENCED [7:30 p.m.]
3
QQgQiQg-~QmmgQ!~
4
MR. SEBASTION:
Good evening.
5
My name is Jim Sebastion.
I'm from the
6
Environmental Protection Agency.
I'm what's called the
7
Community Relations Coordinator for the Sullivan's Ledge Site.
8
Tonight, I will be the Hearing Officer for tonight's meeting.
9
This is a hearing on the Middle Marsh portion of
10
the Sullivan's Ledge Superfund Site.
11
With me tonight is Jane Downing.
Jane is the site
12
manager for the Sullivan's Ledge Site, including Middle Marsh.
13
And also in the back is Jamie Maughan from the consulting firm
14
Metcal f t-c Eddy.
He's been helping out with the technical
1S
aspects of the site.
16
The purpose of tonight's meeting is to accept
17
comments on the feasibility study and proposed plan for the
18
remediation of Middle Marsh.
We were down here, some of you
19
may remember, last month on May 23th to describe the plan
20
prior to the public comment period.
21
The format for tonight will be as follows: first,
22
Jane will briefly describe the proposed plan again.
It wi 11
23
be just five or ten minutes of the highlights to refresh your
24
memory.
25
Second, a1ter Jane's short presentation, we can
APEX REPORTING
Registered Professional Reporters
-------
23
24
25
4
2
try to answer any remaining questions you may have about the
plan before the comment portion to clarify any questions you
3
may have about the proposed plan.
4.
Next, we will accept formal comments for the
5
record.
All the comments will be recorded and transcribed a~d
6
a transcript will be made available eventually in the public
in f.jrmat i on reposi tory which is now at the city hAll,
New Bedford City Hall, it's been moved from the library.
7
8
9
I will be calling on people to make comments who
10
have put their names on three by five cards in the back of the
11
room.
So, if you would like to comment, please put your name
12
on a card and we will be able to call on you during the formal
13
comment portion of the meeting.
And if at some point you
14
decide that you would like to comment a~d you haven't filled
15
out a .:ard,
we'd be happy to help you out and we can assist
16
you with that, just see Jamie in the back.
I wi 11 call c.n
17
people in the order that we receive the cards.
The cards
18
basically ensure that we have your name spelled correctly and
19
that we call you up in the order that you came to the meeting.
20
If necessary, we may need to limit the time for each
21
commentator so that everyone has a chance to comment.
22
Another announcement I would like to make tonight
is that the comment period has been extended.
It was
scheduled to end this rriday, but we received a request for a
comment period extension and the comment periOd has now been
APE X F~EPORT I NG
~egistered Professional Reporters
-------
5
extended another thirty days to July 31st. All written
2 c c.mmen t s must be pc.stmar ked no 1 at er than July 31st for them
3 to be considered in the fi nal decision.
4
We do hope that you will submit comments.
It can
5
be on any of the alternatives, including the preferred
6
alternatives or any oi the work that has been done on Middle
7
Marsh.
All of this information is available, as I mentioned,
8
at the information repository which is at the New Bedford City
9
Hall in the City Clerk's office, it was formerly at the
10
library.
It's also in Boston at the EPA Record Center.
We
11
want to hear everything you have to say about the plan, be it
12
good or bad or any of the different aspects of the plan.
13
We will take all of these comments into
14
consideration when we are making a final decision.
The
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comments will be listed along with responses to comments in a
16
document known as a responsiveness summary, which will also be
17
available at the information repository and it will be
18
released at the time of the record of decision which we expect
19
at the end of the summer.
20
If you have any questions about how to comment or
21
about the plan itself, during the comment period, during the
22
next thirty days, please let us know.
Jane's number and my
23
number are in the back of the proposed plan and we would be
24
happy to help you with any questions you have.
25
Two more important points I want to get across
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before we start.
6
One, when we start the comment portion of
2
the meeting, and I'll let yOU ~now when that is, after the
3
questions ~nd answers, we are only receiving comments.
We
4
will listen to what you have to say, but we will not respond
S
during that period.
That's important to know, we are just
6
acceptjng comments then.
After we have heard your comments,
7
if you do need Some questions answered at that point, we would
8
be happy to stay behind and answer those for you, or try.
9
And the second point I want to make clear before
10
we begin is that we are accepting comments only on the Middle
11
Marsh portion of the cleanup.
The remediation for the
12
disposal area, this area here in yellow surrounded by a green
13
bc.rder,
has already been determined.
We went through a
14
similar process a couple years ago for this cleanup and it
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includes a number of measures including a cap.
We can not and
16
will not accept comments on that portion of the cleanup
17
tonight.
Again, we can answer questions about that cleanup
18
after the comment portion of the meeting, but we're not
19
looking for comments on that portion tonight.
So, just to recap what we're going to be going
over tonight, we're going to be talking -- Jane is 90in9 to
briefly describe the proposed plan once again for you and then
we wi 11 answer any e 1 ar i fyi ng quest i e.ns that y.:.u may abc.ut ':Iur
presentation and then we will accept
formal comments for the
record and I will be calling on you.
And then we will close
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that formal comment portion and we will informally discuss or
2
answer any questions that you have.
3
So now I would like to turn it over to Jane and
4
she will discuss the proposed plan for an alternative.
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~~!£tlel1~Q-~!_et2eg!~g_E!~D
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MS. DOWNING:
Thank you, Jim.
7
As Jim stated, this will be a fairly abbreviated
8
explanation of the preferred alternative.
Most of you were
9
here about a month ago when we went over the specifics.
And I
10
do have an overview of some of the results of the study.
But
"
please, if you have any questions after the presentation, I
12
certainly will answer any questions or concerns that you have.
13
First of all, very quickly, you all probably
14
reali:e where the site is, considering we are almost next door
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to the site.
But this particular portion of the site is
16
really focused on Middle Marsh, and Middle Marsh, as you may
17
know, is located almost in the middle of the golf
course
18
across the street.
It is about a twelve acre area and it is
19
designated as a wetlands.
There's also a small area which is
20
also a wetlands area along the unnamed stream which is part of
21
this study.
22
So, this particular study and this selection of
23
cleanup is just for the portion of the site that is north of
24
Hathaway Road, including Middle Marsh and a second wetland
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area.
This will be what we'll be talking about tonight.
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25
2
We looked at a number of the media within the
e
study area during the remedial investigation.
We took a
3
number of ~amples inCluding samples of sediments, surface
4
water and what we call pore water.
And pore water is just the
5
water that you see in between the sediments.
6
And the results of the remedial investigation
7
basically indicated that the contaminants that we have in
8
those areas are PCBs, PAHs, PAHs are POlyaromatic
9
hYdrocarbons, and also metals.
These are consistent with the
10
results that we found on the first part of the site.
So that
11
if you look at the results of the remedial investigation that
12
was done at the disposal area, you can see that they're the
13
very same type of contaminants.
14
BaSically what has happened is, the contaminated
15
soils have migrated from the disposal area, have migrated into
16
the unnamed stream, and with the stream, the sediments have
17
traveled across Hathaway Road into the golf Course and then
18
basically Spread out into Middle Marsh.
So, the contamination
19
is consistent with the first part, but the major focus is
PCBs.
Now, given the levels of PCBs we found in Middle
Marsh, we determined that the risk to human health was
minimal.
The way that we felt that people would be exposed to
th.:.se PCB contam.i nated 5edi ments are pr i mar i 1 y the gCll fers whc.
may go in there after golf balls and touch the contaminated
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sediments.
So, we looked at that exposure and we concluded
2
that the levels in Middle Marsh do Mot pose a significant risk
3
to golfers and to children who may periodically go in and play
4
in those sediments.
5
The primary risk that is posed by those
6
contaminated sediments is to the animals who live in Middle
7
Marsh.
As part of the study, we looked at all the animals
8
that could potentially or the animals that do inhabit Middle
9
Marsh.
And we determined that all the animals that were
10
sampled had PCBs in them.
11
So, the risk that we have found that is
12
significant is happening through direct contact with the
13
contaminated pore water or the contaminated sediments, and
14
those risks are posed to the animals that inhabit Middle
15
Marsh.
That is the primary conclusion from the study.
16
Now, the fact that we have an unacceptable risk,
17
we set cleanup levels so ~hat by the time we cleaned up the
18
site, the risk would not be unacceptable, that those animals
19
would not have any risk to their health.
20
The numbers that we determined that would be
21
acceptable, which are the cleanup objectives or the cleanup
22
levels that we have established are two different numbers.
23
The first one is 15 parts per million and that is mostly for
24
the area about eleven acres of the twelve acre area.
And the
25
15 is to protect the mammals.
You may have mink, you may have
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frogs, you may have dogs out there, and that 1~ ppm is
10
basically to protect the terrestrial animals.
We set another
3
limit whic~ is in a tributary stream in the northern portion
4
and that number is twenty micrograms, and that's to protect
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any fish or aquatic organisms that may be in that area up
6
there.
So, there are two different cleanup levels that were
7
selected or proposed in the proposed plan.
8
Now,
in terms of cleanup, we have concluded that
9
in order to meet the cleanup objectives, we need to go in and
10
excavate four different areas in the golf Course.
Three of
11
the areas are within Middle Marsh.
You can see that this
12
particular picture shows the three areas, there's a larger
13
area here and there's two small areas, one to the south and
14
one to the north.
There's another area up here that's about a
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half an acre.
All total, the areas that should be cleaned up
16
in order to meet the cleanup levels are about
So,
1.9 acres.
17
we are proposing to go in and excavate almost two acres of the
18
Middle Marsh area.
The preferred alternative has a number of
components.
The first one is site preparation and that is
basically self-exPlanatory.
We would have to go in and remove
the trees.
There are a lot of trees out in Middle Marsh, so
there will have to be some preparatory work that has to be
don e.
We will excavate the sediments and that is a total
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of about 5,~OO cubic yards.
Again, it's about two acres that
2
we're talking about.
And once those sediments are excavated,
3
we are pro~osing to take those sediments and bring it to the
4
di spc.sal area.
9asieally, we will excavate the sediments and
5
then transport them across Hathaway Road to the disposal area
6
and di spc.se e.f them in the di sposal
This area will be
area.
7
further capped as part of the first decision.
So, the
8
sediments will come from Middle Marsh, they will not be
9
treated, they will be disposed and then capped with the cap.
10
In addition, we will h.ve to restore the wetland.
11
We will not just excavate and leave the land the way it turns
12
out.
We will have to go in, and to the extent possible, go
13
back and restore the land.
That may mean that we'll have to
14
plant some trees and bushes.
15
We will have to do some long term monitoring 50
16
five,
ten years down the road, we will s~ill be back in and
17
doing some sampling to make sure that we're truly protective
18
of those that we feel are posing unacceptable risks.
19
There will also have to be some institutional
20
.:.:.ntrol s.
And what that means is that basically we can not
21
accept a residential development in that area.
We have
22
proposed that the land use in the future for the golf course
23
will always be similar, as a golf course, recreation area.
We
24
are not proposing that there could be a house built on that
25
I and.
And what we have to do is we have to put in some deed
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23
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restrictions to make sure that that would happen.
12
2
That is basically the preferred alternative.
3
Obviously we're asking for comments tonight on what you all
4
think of that.
We have also selected a contingency
5
alternative.
And the reason we did this was because there may
6
be a possibility that this area here may not be -- may be
7
unavailable to accept the excavated sediments.
If this area
8
had already been capped, we could not move the sediments and
9
dispose of them here.
10
So, we selected a contingency alternative that
11
would take care of that possibility.
And what that would mean
12
is basically the sediments will have to be treated by solvent
13
extraction and then the treated sediments will be disposed
14
back into Middle Marsh.
15
The treatment is called solvent extraction and
16
when you treat with solvent extraction, you have an oil that
17
contains all the PCBs and that oil will be transported off
18
site and burned in an incinerator.
19
We will also have to wetland restoration work
20
similar to the preferred alternative.
We will have to monitor
and we will have the same institutional controls that we
talked about.
And finally, just in terms of anticipated costs,
the preferred alternative, ~e have estimated, will cost 2.8
million.
The contingency alternative, where we have to treat
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the sediments, we have anticipated that it would cost 7.8
2
million dollars.
3
Basically that is the proposal.
We are,
4
obviously, as Jim said, asking for your comments on that
S
today.
And before we go on the record to ask for your oral
6
comments, I woul d just 1 i ke to asl~ if anybody has any
7
questions, do you need further clarification on any point?
8
Q~~!ti2Q_~Qg_~Q!~~t-~~!!i2Q
9
F'P-OM THE F'LOOR:
Yes.
10
I would like to know what metals you found in this
11
site specific analysis that you made reference to earlier?
12
MS. DOWNING:
The metals that we found, I believe
13
they were
::inc,
lead, and there may have been two or three
14
others; but, the primary ones were zinc and lead.
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F'ROM THE F'LOOR:
Zinc and lead?
16
MS. DOWNING:
Yes.
And in fact--
17
F'F.:OM THE F'LOOR:
Do you remember what the portions
18
were, the amounts?
19
MS. DOWNING:
I don't know that.
20
F'ROM THE F'LOOR:
Two parts per million?
21
MS. DOWNING:
I don't know that, but we do have
22
the exact numbers and they are in the reports.
23
F'F~OM THE F'LOOF~:
So I can read the report and find
it in there"?
MS. DOWNING:
Yes; YCILI can.
In fact, there are
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maps that show exactly where the
zinc
levels were found and
2
where the lead levels were found.
3
The one thing that was interesting about the
4
metals with regard to the
and lead, where we found the
zinc
- s
contamination was basically where we found the PCBs.
What was
Q
6
interesting, which is what we Yeally thought had happened, as
7
the sediments went into Middle Marsh, during floods and during
8
rain events, the sediments would come out of the stream and
9
settle into Middle Marsh.
So, we have some areas close to the
10
stream that have the highest pce contamination.
There are
11
also the areas that have th. high metal contamination.
12
So, I think the primary ones were zinc and lead.
13
And if my memory serves me, the highest lead value was
14
800 ppm, the zinc, I would have to check on.
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F"ROM THE F"LOOR:
What's the average PCB level?
16
MS. DOWNING:
The average pce is around 15 parts
17
per million.
18
F"ROM THE F"LOOR:
Throughout the whole Middle Marsh
19
site?
20
MS. DOWNING:
Throughout Middle Marsh;
c:c.rrect.
21
We had--
The highest spot was in this area up
22
here, at a, I think it was greater than six inches below the
23
surface and that highest value was 90 parts per million.
The
24
highest value in Middle Marsh was 60 parts per million.
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F"ROM THE F"LOOR:
And in your average, do you
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include all the areas that came in below the detection limit?
2
MS. DOWNING:
What we typically do is we take half
3 the detection I i mi t and use them as averaging. That's what we
4 do when we do the risk assessment. But in the remedial
5 investigation when we' r e just looking at the average, we only
6
take those that are detected.
So there are two answers to
7
that.
I would say if you Just read through the remedial
8
investigation, only look at the detection, the ones that
were
9
detected.
10
MR. MAUGHAN:
When we looked at some numbers, I
11
think we came up with 9.13.
12
F'F~OM THE F'LOOR:
That's including the detector
13
mc.del s at
:.:: er oj,?
14
MS. DOWNING:
There's a number of ways of looking
15
at it all in numbers.
Typically, the detection limit that you
16
can look at is 1 ppm, although we got lower detection limits.
17
What was our detection limit, Jamie, do you
18
remember?
19
MR. MAUGHAN:
It was, yes; well below
cone.
20
MS. DOWNING:
It was well below one.
21
So, there's a number of ways of playing with the
22
numbers that you can get to get your average.
23
F'ROM THE F'L OOR.:
How did you come up with the
24
detection level of remediation'?
25
MS. DOWNING:
The 15 ppm'?
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F"ROM THE F"LOOR:
16
Right.
I'm asking becaus~ in
2
the, what is coming out in the Lowell Harbor superfund site,
3
it looks like it's 90ing to be about 50 parts p~r million.
4
And in the Middle Marsh where we have an area .that is almost
5
at 15 parts per million, it's five times less.
6
MS. DOWNING:
Well, the way we did it is we looked
7
at how the PCSs were getting into the animals.
So, we have
8
PCBs in sediments.
There's a certain amount of the PCBs in
9
the sediments that will get into the animals.
And that value,
10
that factor is a site specific factor.
So, whatever the
11
factor was for my site may not be the same at any other site.
12
In fact, it would be truly different if it's a marine
13
environment and if you have a lot of water, it will be totally
14
different.
A lot of it depends upon the setting in itself and
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the organic content of that.
16
So what we have to do is we have to go in on. a.
17
site specific basis and just figure out how much of the PCBs.
18
we're getting from the sediments to these animals.
And
19
depending upon that factor, calculate how much of the PCBs
would end up in the animals as you go up the food chain.
And
when we did that, we determined that, as you went up the food
chain, some of these animals are at risk and given that, what
should the level in the sediment be to protect that.
But a5 I said, the reason why I have to say the
number that we came up with may not be the number you get at
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7 animals?
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8
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another site is because it all depends on sediments.
You wi 11
2
have different sediments at any different site.
And certainly
3
in marine -- marine animals would have different animals,
4
would have. different sediments, so you can't really compare
S
the two.'
F'F~OM THE F'LOOR:
That's a habitat for what
MS. DOWNING:
Well, it's a habitat for any number
9
of terrestrial animals.
When we did the biological study, we
10
did a whole different slew of the animals including frogs and
11
earthworms and mice and bulls.
And when we, actually I have a
12
slide, but when we moved it out a level, WR took a look at the
13
mink and the raccoons and the birds.
And that was Just the
14
sampling of some of the selected organisms.
There's obviously
1S many more organisms that we didn't lc'ok at, but we only had t Co
'6 select thc.se certain amc.unt of them.
'7 rROM THE F'LOOR: I spend a lot of time, well, are
'8
there two animals that you were concerned about?
'9
MS. DOWNIN'3:
There were two species that were
20
species of concern in accordance with Massachusetts law.
One
21
was the spotted turtle and the Mystic Valley anthropod.
We
only actually saw the spotted turtle, we didn't see the Mystic
Valley anthropod.
Jamie, do you want to expand on that?
MR. MAUGHAN:
ror both the spotted turtle and the
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anthroPod, the habitat is definitely there, they are
18
potentially there.
As Jane said, we did see the turtle.
We
3
did sample, for the anthropod but w. didn't find it.
4
The detection levels, this 15 parts per million
S
are not based on either of those animals because they proved
6
not to be the most sensitive necessarily.
7
MS. DOWNING:
We also took. look at the birds,
8
fish and Wildlife, are very concerned about the possibility of
9
PCSs getting in through the earthworms and some of the small
10
mammals and getting into the birds.
Birds may be sensitive.
11
And it turned out that the cleanup level for the birds would
12
be about =5, so they were not the most sensitive.
But the
13
most sensitive animal was the mink.
With the spotted turtle,
14
the spotted turtle did not turn out as sensitive.
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rROM THE rLOOR:
How do you know theY're getting
16
across the street from the quarry?
17
'MS. DOWNING:
Well, because we feel that thetr~il
18
of PCBs is fairly indicative to this site.
You can see how it
went from the disposal area to Middle Marsh.
And a11 cd the
information backs that up.
We did all kinds of hydrologic
stUdy to look at where the sediments were gOing.
So we feel
pretty strongly that the contaminants we found in Middle Marsh
came from the disposal area.
rROM THE rLOOR:
So when the disPosal area is,
when remediatic.n of the disp.:.sal area is c':.mplete, migratic.n
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of PCBs and metals will cease if the upper part of the unnamed
2
stream is al.sc. remediated?
3
MS. DOWNING:
That will actually be an objective,
4
cleanup objective.
What we want to do is we want to stop any
5
PC~s from coming here from, moving from this, from the Middle
6
Marsh and getting into the Apponagansett Swamp.
7
Unfortunately, we can't clean up all of the PC~s.
8
There still will be PCBs here even after we finish what
we ' r e
9
prc'pc.sing tCI do.
But what we hope wi 11 nCot happen is, mc.st of
10
the PCBs will be gone in the sensitive area which is the
11
closest area to the stream.
The target, you can see from the
12
diagram that we showed, most of the areas that we're proposing
13
to excavate are very close to the stream.
So if you take out
14
those PCBs, the PCBs that will be left will be at the extremes
15
of Middle Marsh and that would be very difficult to go from
16
the extremes back into the stream and out into the
17
Apponagansett Swamp.
18
So, we are concerned about the possible migration
19
of PC~s and that's one reason why we have to go continually
20
back in to monitor to make sure that that will not happen.
21
F"ROM THE F"LOOR:
What you're saying is that when
22
you finish your remediation, you still will not be able to
23
prevent the water coming from Sullivan's Ledge going across or
24
under Hathaway Road into the Middle Marsh; once you're
25
finished you will not be able to change the water
.:omi ng in
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from the Jedge, going under the road and into the golf Course?
2
MS. DOWNING:
Let me just step back for a minute.
3
What we're talking about tonight is basically the
4
sedi ments.
Once the remediation is complete, both for this
5
portion of the study area and this portion
tjver
here, there
6
should not be any migration of sediments.
This will all be
7
capped, eleven acres of it will be capped so the soils will
8
not be moving into the stream and will not be moving down.
9
Some of these PCBs will be gone so the sediments shouldn't be
10
getting into the stream and moving out.
So, we feel that the
11
migration of sediroents contaminated with PCBs should be
12
stopped once we complete the action.
13
Now, the groundwater is a separate issue.
The
14
groundwater is something that we addressed in the first
15
decision document.
And what we basically said was, the
16
groundwater is severely contaminated at great depths because
17
of the quarry pits and there is really nothing we can do about
18
that.
We can't go in and try to find every single crack in
19
the ground to find all of the contamination.
5,:" we kn,:,w that
20
there is contamination in the grc'undwater.
We also know that
21
nobody is drinking that groundwater.
So, in terms of any risk
to the pUblic, there really isn't any.
The only problem would
be if someone in the
future drilled a well and started
drinking the groundwater.
What we proposed in the first part of this study
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is even though we knew we couldn't clean it up completely so
2
that everybody could be drinking the groundwater everywhere on
3
this site, we still wanted to go in there and get as much of
4
the contamination out of there as we could.
So, we are going
5
tc. pump and treat, we are going to drill wells and we're going
6
as close to the pits as we can, because this is really where
7
all the groundwater is contaminated.
We are going to drill
8
some wells around the pits, pump out as much of that as we can
9
and treat that and discharge it.
We are also going to put a
10
trench of pipe right near the stream to collect any of the
11
contaminated water that gets into the stream because once it
12
gets into the stream it's going to pose a problem to any fish
13
that may live there.
14
50, we're stopping it from getting into the stream
15
and we're going to get as much of the source of that
16
groundwater out as we can.
But we have already acknowledged
17
that we can't get it all and what we're going to do, with the
18
cooperation of the city is put in institutional controls so
19
that nobody will drill a drinking water well and drink any of
20
the contaminated groundwater.
21
So, in summary, we're going to do as much as we
22
can for the groundwater, but we can't clean it all up.
The
23
sediments, we feel, through the combination of the two
24
.:leanups,
should stop the sediment's from going further and
25
clean out and contain that which is contaminated today.
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F"ROM THE F"LOOR:
If you stop the flow from the
2
Ledge to the stream, will the stream dry up?
3
MS. DOWNING:
What we are doing is,
N.:..
we are
4
cutting off only that portion of the groundwater that is
5
seeping into the stream.
A lot of the water from the stream
6
is coming this way, upstream.
So, the stream will still be a
7
stream.
What we're just doing is intercepting any of the
8
groundwater that may get into the stream.
We don't feel we
9
will be drying up the stream.
we were concerned
In fact,
10
about that possibility because when you pump, sometimes you
11
pull in adjacent streams.
12
So, also, as part of this remedy~ we are going to
13
contain this stream.
It will be contained only during the
14
time that we start pumping.
So, that will not happen.
15
F"ROM THE F"LOOR:
Was this water tested with water
16
from Middle MarSh, the groundwater?
17
MS. DOWNING:
were.
They were tested as
Yes; they
18
part of the first study that was done.
We took a look at the
19
water hazards and tested the water itself.
I can not at this
20
pOint remember exactly what levels we found.
We did find that
21
the sediments were contaminated with pcas.
~
The levels were
not that high, 1 believe the highest was maybe 3 parts per
million,
which is a pretty low level.
But these sediments
will have to be excavated.
So these two water hazards are going to be cleaned
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up as part of the first study.
The water that is above the
2
sediments will not be, they didn't really contain
3
contaminants.
4
So, in terms of the water,
it's not really the
5
surface water that we're too concerned about,
it's the
6
groundwater, it's what flows under the ground that people may
7
be drinking.
And it's this water up here where the
8
groundwater catches the surface water, there could be a
9
problem if we don't intercept it.
10
F"ROM THE F"LOOR:
One question, this is on the
11
background of the criteria of PCBs.
I assume that the danger
12
levels are different for all different species, whether they
13
be for humans or for minks,
and now that I know, I'm never
14
going to eat a mink I don't know.
15
I have a question as to what is the danger level
16
for a human and who sets that criteria and how is it set~
just
17
a little background on what is dangerous and what is not.
18
MS. DOWNING:
We have to, by law, look at both the
19
risks to human health and the risks to the environm.nt.
5.:.
20
this is something that EPA takes a look at.
And what we do is
21
we take a look at the concentrations of the PCBs and we
22
determine just how risky that is to human health.
23
As part of the first study, we set cleanup levels
24
for PCBs because we felt that since these levels were so high,
25
there could be someone that could break into this site, this
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is currently fenced, but there could be a trespasser that
could break into the site and contact the soils.
We didn't
3
feel that there was a house or a resident that was continually
4
co~tacting the soils every day.
These soils really are the
5
ones that we're most concerned about.
And the only way that
6
we felt that the pUblic was being exposed was, as I said, a
7
bypasser or a trespasser; someone hopping the fence and
8
touching the soils.
9
We also thought about, well, what would happen in
10
the future?
Is there a possibility that someone would build a
11
home on this site and should we set a cleanup level that would
12
be protective of that, and the answer
we felt that the
was nl;:';
13
site will always be something like a parking lot or just an
14
aband':.ned area.
15
N.:1w,
the way we set cleanup levels is it's based
16
on two things, a cancer risk and a noncancer risk.
F':.r PCBs,
17
PCBs is a Possible human carcinogen, so it could potentially
18
.:ause I:ancer
in humans.
And what we have to do is we have to
19
set levels that we feel are going to be acceptable to the
20
public.
The level that we picked for this area was 50
parts per million of PCBs.
And that basically meant a risk of
,:.ne in 1 ()O, O()O.
80 that if you touch the soils perhaps twenty
seven days a year, a certain of times a year,
there is a
ehance of getting cancer of one in a 100,000, that is the risk
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value.
EPA normally sets cleanup levels within a cancer risk
2
elf cIne in
10,000 and one in a million.
3
And this particular that we set two years ago of
4
50 part per million was based on the one in 100,000 chance of
5
getting cancer through the contact of the PCB soils.
6
Now, what happened when we looked at Middle Marsh'
7
was, we took a look at the numbers and we took a look at the
8
human health risks, the human health risks of contacting these
9
sediments are around one in 100,000 and we feel that that is
10
an insignificant risk, that that is something that is within
11
the acceptable range.
That's why we didn't set a cleanup
12
level because we feel already it's a protected level.
13
I know that was a long answer.
14
MR. SEBASTION:
These are all good questions.
I
15
think we can get to most of them throughout the course 0' the
16
evening,
but several people came tonight to give specific
17
': .jmmen t s
for the record and I would like to move on to that
18
portion of the evening,
and then if there are any further
19
questions that you have now or that come up during the course
20
of the comments,
we can answer
those after that portion of the
21
meeting.
22
The way I would like to do it,
I have three
23
commentators here now, three cards for comments here now.
24
What I would like to do is have the commentators, when I call
25
their names,
stand up and come near a microphone so we can get
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2
E2~m2!_~QmmgQ!a
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MR. SEBASTION:
As I said, we only have three, so
4
you don't have to cut them too short, but we do want to be
S
able to move on and get all the comments and we also want to
6
be able to answer some questions after.
So, keep them as
7
brief as Possible and still let us know what you have to say.
8
The first commentator is Edward Camara.
9
MR. CAMARA:
I would like to tell you that
rirst,
10
I'm very disappointed that when we're talking about three to
11
ten million dollars, we only find these few people here.
It
12
doesn't seem logical
to me.
Maybe I'm goofy, but I've lived a
13
lot of years and I know that if I don't pay all of the ten
14
million, some of my friends are going to and it's very,
very
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expensive when you're talking from three to ten million
16
dollars.
17
And you're talking about a problem that we have in
18
Wide Marsh, there's no question that we have a problem there.
19
That is not the problem.
That's the end of the problem.
The
20
problem is not there.
And I think you have told me, or he
did, befo~e this meeting started that we were not g01ng to
talk about Sullivan's Ledge.
This is the basis of all of this
problem.
It's not Wide Marsh.
You talk about fish, well,
I've lived here many, many years, believe me, there
are no
fish there; if they are, they are microscopic.
You talk about
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muskrats or whatever.
2
I've never heard of a golfer, and I've been here
3
since they'changed this golf course and I have never found a
4
golfer who didn't have anything but a good time there.
I f
5
there's a ball that he's lost, he's lost a ball, he's not
6
going to go into a marshland looking for a golf ball, but kids
7
used to get them.
As a matter of fact, many years ago,
some
8
little kids got little ducks and sold them to my little kids,
9
this is how long I've lived here.
10
I believe that I'm the only next door resident,
11
me, because I live up the street.
I have seen this start.
12
When I say this, I'm talking about Sullivan's Ledge in 1935 is
13
when the WPA built this golf course, it's a fantastic course.
14
You talk about homes being built there, who would
15
have the nerve to go in the middle of the golf course and say
16
I'd like this piece of land
That's idiotic.
for a house.
17
That will never happen.
course
In 1892 they built a golf
18
that's called the New Bedford Country Club,
try to put a house
19
there and see how far you get away with it.
That is so far in
20
the future, it's beyond belief, beyond thinking about that
21
we're going to take our nice golf course, let's cut it up and
22
put condominiums here and get rid of all these golfers; they'd
23
kill you.
Does that make any sense to you?
24
I would hate to see 5,000 yards of garbage, junk,
25
whatever it is, brought over and put on top of the cancer that
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is there, SUllivan's Ledge.
28
2
I don't have any solution for this.
I've lived
3
too many years, but 1 am nc,t what y,:,u ':all really dumb.
The
4
only way that that prOblem will ever end is if the water that
5
is coming out of that ledge, which is hundreds of feet deep,
6
is coming out and you call something about an unnamed stream?
7
I'll tell you what it is, it's a brook.
Before it was a
8
brc,c'k,
there was a pond, Collins Pond, there was an ice house
9
there.
Part of the land that I own, they had the rights to
10
cut ice at that pond, dig down and it picked up, SUllivan's
11
Ledge, six inch pump pumping day and night to take the water
12
out of that ledge so that they could cut stone out of there.
13
It was so deep, unbelievable.
You're going to stop this
14
prOblem by cleaning the mess that it caused over there?
15
I've seen SUllivan's Ledge a place crystal clear.
16
.1 drank out of that creek,
H.:.w dc,. Y':~I..I
that unnamed stream.
17
call it an unnamed stream.
It's a little thing of water
18
that's running down the land, that's all it is.
19
But y.:.u' re w,:orryi ng abc.ut worms, I thi nk Y':'U sai d,
or snakes or something.
If there is a prOblem, there is a
problem in Our river which they worked on for years and years
and years and it will be there for years and years and years.
If y';:'"l.! .:lean that mess,
you've cl~aned it, you haven't stopped
it.
All YOu've'done is just erased it a little bit.
It' s
going to start again.
It will not stop because the water, you
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couldn't count the tires, you couldn't count the horses, you
2
couldn't ~ount the cars that have been thrown in that, because
3
I have lived through it and you haven't.
4
I look at you nice, young people and I think
5
you're from Boston and Medford or wherever you might be from,
6
but you haven't lived here as 10n9 as I have.
I knew the
7
problems before they started.
8
Have you ever gone into a stream and pushed these
9
little animals that fly on top of them, they have like four
10
little pontoons, you might not even know about these.
Dc.es
11
this make any sense to you at all?
12
MS. DOWNING:
Absolutely.
13
MR. CAMAF.:A:
There are some kind of bugs like ants
14
and flies and whatnot, but this little bug had like little
15
f,:.ur little p':.nt':II:ons, we used t,:, brush them ,:,ff and drink
16
that.
I wouldn't do that today.
Now I drink scotch.
17
(Laughter)
18
MR . CAMAF~A:
I just thought I'd like to give you a
19
little bit of my mind.
But I hate to see three to ten million
20
dollars and I look around here and I say,
we've lost something
21
along the way, haven't we.
Perhaps you didn't advertise it
22
well enough as to what you're going to do.
Did I say
23
s,:,methi ng wr':.ng?
I kn':.w it's n,:,t
idea.
y':.ur
S.:.me.:'ne sh':)Ltl d
have maybe publicized it a little more because this is a big
thing.
I don't have ten million dollars, but someone has got
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to bring it out to move that junk and put it on top of the old
2
junk?
F"orget it.
3
I think that's the end of my little speech.
I
4
hope I didn't bore you too much.
5
MS. DOWNING:
Thank you.
6
MR. SEBASTIaN:
Thank you, Mr.
I;amar a.
7
MR. CAMARA:
You're welcome.
8
MR. SEBASTIaN:
The second commentator we have is
9
Armand F"ernandes.
10
MR. F"ERNANDES:
Yes.
11
That's a tough act to follow.
What I will say is,
12
I think, Jim, you have an excellent choice of tie and shirt.
13
I like the combination.
14
F"i rst I:" all, Mr.
Camara's point is well taken.
15
And unfortunately I might not be as artful and as eloquent as
16
he's presented his case.
I think he makes an argument that
17
the City perhaps adopts in its position here tonight and its
18
': ,:,mmen t .
19
F"irst, when we first visited the site, we
20
discussed about no action, we talked about no action in Middle
21
Marsh.
And the City's position is we should follow through
22
with no action with perhaps a modification or maybe we should
23
.: all
it limited action.
Middle Marsh could be fenced in.
It
24
~ould be restricted by deed restrictions, zoning restrictions
25
and access restrictions.
We think fencing and other kind of
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barriers could be constructed around it to prevent at least
2
that huma~ danger we address.
And
And I think that given--
3
we could monitor,
once you clean up Mr. Camara's unnamed
4
brook, we could monitor what's happening on the other site and
s
maybe look at it again at another point in time.
6
But the fact of the matter is, as again,
I cited
7
earlier, we've looked through the SRI and we saw two species,
8
one of which is the spotted turtle.
His habitat really isn't
9
there,
it might be there, but we think it lives in the swamp
10
that you show in your chart on the board.
11
In terms of the levels, we averaged them out and
12
they come out to be 9.13 parts per million, which is, as Mike
13
poi nted c'ut her e, I ess than what, . and I know Y':'u addressed
14
that issue,
or proposed have, or
but less than what we have,
1S
they're much higher, rather,
in the inner harbor, with the
16
exception of one location at
cine c. f
the hc.t spc.ts.
17
We think the restrictions we are willing to
18
pr c.p.:.se,
once you clean up the former quarry pit, that the
19
environment, the habitat will be as protected as we can get
20
it.
Mr. Camara may be right.
The water may be flowing
21
through there.
I don't know and I don't know if anybody
22
knc.ws.
The fact c.f the matter is I think we e,\.\ght t,:. take a
23
second look at it.
Ten million dollars is a lot of money.
24
From the legal standpoint, obviously, you might
25
say the opinion of the City at this point is somewhat tainted.
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We are told we're sued for the ten million dollar cleanup at
~2
the quarry site, we are going to be sued by the PRPs as well
3
as some other small people, allegedly, are going to be sued.
4
We're certainly,
as owner of the site, we're responsible for
5
cleaning it up.
That makes twenty million dollars at the
6
total SUllivan's Ledge site.
We think that the environment
7
and the citizenry of New Bedford are adequately protected by a
8
limited no action,
i f YC1U wi 11 .
9
And we will follow this up in more detail with a
10
written response within the response time.
But I want to
11
thank you for YOur courtesy SO far and you've always been
12
helpful, although we agree to disagree quite often, and this
13
is just another example.
14
Th an k y,:ou.
15
MR. SEBASTION:
Thank you, Mr. Fernandes.
16
The third and final commentator that we have sg
17
far is Al F'almuri.
18
MR. F'ALMUF~I:
I represent a majority of the
19
golfers at the municipal golf COurse up here and we sent a
petition last week to Boston to both of you with the names of
the gOlfers who signed the petition.
And without going into a
long explanation, I think most of it's been Covered by the two
gentlemen before me.
We specifically recommend that
n,:, a,: t i ':,n
be taken regarding this because of the, I would call
ita n,:.
guarantee that the water will stop flowing from Sullivan's
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Ledge onto the golf course.
And as a result of that, we wish
2
to be put on file that no action be taken.
3
Thank you.
MR. SE8ASTION:
Thank you.
Is there anyone else who would like to comment for
the record?
It's not too late and we'd be happy to hear
someone else that hasn't spoken, yet would like to get on the
record.
Helen, would you like to speak?
MS. WALDORF":
Is that all right?
MR. SE8ASTION:
That's fine.
MS. WALDORF":
Thank YClu.
I hadn't planned on saying anything, but in
view
of the fact that there have been three previous commentators
that talked about no action and someone asked the question
about risk and risk to human health, one of the things tha~
has to be looked at, that we look at from the State, and I
represent the Department of Environmental
F'r .:.t e.: t i on,
is
whether or not a cleanup meets the State's risk based
standards.
Unfortunately on this site, where you are not in
the risk range where EPA might take into action for human
health perspective, that's why there's been so much discussion
of the ecology of the site, without taking an action on Middle
Marsh,
it ~ppears as if the human health risk range or the
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human health risk would not meet the state standard if you did
2
nothing.
3
So, the State's position at the moment, as it
4
stands now,
is because it would not meet our risk standard --
5
our risk standard says that you have to take all the media,
6
everything, water, air, water you might drink, direct contact
7
in the future depending on pond future land use, you have to
8
take all those risks and all those risks must be basically,
9
for cancer risk, around, you know,
right at one in 100,000,
10
that's all the risks taken together.
Well, if you took all
11
the risks together with the given remedial action on the site
12
and you did nothing at Middle Marsh, you would still have a
13
human risk that exceeds our risk range of one in a 100,000, I
14
believe it's three or four times that,
somewhere in that
15
range.
16
So, our position is, you're not meeting the "st~te
17
standard which we feel is more stringent in this case than the
18
federal standard.
19
Now, the federal people have to do what they do in
20
making a decision based on their standard.
And we have to,
21
you know, say what we have to say based on the regulations
22
that we have in place.
So, the Massachusetts contingency plan
23
basically says that when we look at the risk assessment that
24
EPA did, our recommendation would be to essentially support a
25
remedy that would remove the materials down so you can get
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close to our risk range.
2
If no action had been or was to be selected by
3
EPA, it appears, although I can't give a definitive answer
4
right now,. I guess it would depend upon how they did that, but
S
it appears as if we might not concur with that remedy.
And
6
the State's role in this right now is we get three choices for
7
the record of decision, and one of the criteria they evaluate
8
the remedy on is, one of the criteria they use to modify is
9
community acceptance and the other one is state acceptance.
10
And the state can either concur with the remedy, have no
11
comment on the remedy or not concur on the remedy.
12
So, and Jane knows this, it's been our position
13
all along, that although they're doing this for environmental
14
reasons, which we support, we also have the position that you
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need to meet the state's health risk based standard in order
16
to have a remedy that would meet a promulgated standard.
17
That's all I have.
18
MR. SEBASTION:
Thanks, Helen.
19
MR. FEF~NANDES :
If we put in these contingency
20
controls that you alluded to briefly, would that satisfy the
21
State standard?
22
MR. SEBASTION:
Sorry, but we're not answering
23
questions right
I would like to,
n.:.w.
but we .:an' t.
24
MS. ST. AUBIN:
I'm Nada St. Aubin and I'm new at
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thi s, but
And in
I'm very interested in the environment.
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1 i steni ng 'to the state and 1 i steni ng t.:. the federal and
::::e.
listening to the City,
I assume, there is an easy answer, but
3
i f y.:.u' re,: he.: king .: ':.mes t.:. cIne in 100,000, wh i chi s
4
practically one in the whole City of New Bedford, how would
S
the state have a different answer to that same question if
6
they used similar testing.
7
And, to make it easier, if you put a fence around
8
the whole thing and.nobody got into it, wouldn't that be the
9
simplest sol~tion?
Because in the environment, nothing can
10
really, it's just like testing when you go to a hosPital
f .:.r a
11
disease, and we're very familiar with that because we're up at
12
Mass. General, over the years very, very frequently, and the
13
cut and find and take biopsies, they find things but don't
14
kn,:,w the answer.
Sometimes there isn't an answer that anybody
1S
can give.
So then you try to solve it by making it
unavailable to anything or anybody and as far as the muskrats
or the mink, I know that other, and the frogs I know of, but
that other thing I've never heard of, and I've lived a 10n9
time, too.
So I think that sometimes we do too much testing,
whether it's federal, state or community and it's just a lot
of wasted money and seven million dollars is a lot of money.
Thank you.
MR. SEBASTION:
Thank ye.u.
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MS. DOWNING:
Thank y.::.u.
2
MR. SEBASTION:
Anyone else for a formal comment
3
on the r e.: or d"7-'
4
(Nc. respc.nse)
S
MR. SEBASTION:
At this point I would like to
6
close the hearing and the~ we can take your questions and
7
answers and have a little more of an informal discussion for a
8
short period and then we can all go home.
9
The formal hearing is adjourned.
10
(The public hearing adjourned at 8:30 p.m.)
11
12
13
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15
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2S
APEX PEPORTING
Registered Professional Reporters
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, CERTIFICATE OF REPORTER AND TRANSCRIBER
38
2
4 in the Matter of:
3 before: JIM SEBASTION. Hearinc Officer
This is to certify that the attached proceedings
r
[
l~
D
m
U
ff
5
6
7
8
Place:
9
ate:
10
PUBLIC HEARING RE:
SULLIVAN'S LEDGE SUPERFUND SITE
New Bedford~ Massachusetts
14
June 26 ~ 13'31
11
ere held as herein appears, and that this is the true,
CCurate and complete transcript prepared from the notes
rec.:.rdings taken
of the above entitled proceeding.
15
':\'..-11'.1'n Sandberq
16 jRep.:.rter
07/01 /'j 1
Date
1r!
Iii
1-
17 Lal.lra Madi
ranscriber
07/01/'31
Date
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~
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~
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22
23
24
25/
I
APEX REPORTING
Registered Professional
(61 TI426 -3077
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APPENDIX B
ADMINISTRATIVE RECORD INDEX
SULLIVAN'S LEDGE SITE
-------
Sullivan's Ledge
(Operable Unit IT)
NPL Site Administrative Record
Index
Compiled: May 29, 1991
ROD Signed: September 27, 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 Administrarive Record for the Record of Decision for the
Sullivan's Ledge National Priorities List (NPL) site (Operable Unit n). Section I of the Index cites
site-specific docwnentS, and Section n cites guidance documents used by EPA stafTin selecting a
response aCtion at the site.
Although nol expressly lish>d in this Index, all documents contoined in the
June 29,1989 Record of Decision Administrative Record (Operable Unit I) Qre
incorporated by reference herein, and are expressly made a part of the Administrative
. Recordfor the September 27,1991 Record of Decision Administrative Record
(Operable Unit II).
The Administrarive Record is available for public review at EPA Region I's Office in Boston,
Massachusetts, and at the New Bedford Free Public Library, 613 Pleasant Street, New Bedford,
Massachusetts 02740. Questions concerning the Administrative Record should be addressed to the
EPA Region I site manager.
The Administrative Record is required by the Comprehensive Environmental Response,
Compensation, and Liability Act (CERCLA), as amended by the Superfund Amendments and
-------
Sulli,'an's Ledge
(Operable Unit D)
, NPL Site Administrative Record
~
V Qlume I
3.0 Remedial Investigation (RI)
Volume n
Volume m
Volume IV
3.2
3.4
3.5
3.6
Sampling and Analysis Data
Interim Deliverables
Applicable or Relevant and Appropriate Requirements (ARARs)
Remedial Investigation (0) Repons
3.6
3.7
Remedial Investigation (RI) Repons (cont'd.)
Work Plans and Progress Repons
3.9
Health Assessments
4.0 Feasibility Study (FS)
4.6
4.9
Feasibility Study (FS) Repons
Proposed Plans for Selected Remedial Action
5.0 Record of Decision (ROD)
5.1
5.3
Volume V
5.3
Volume VI
5.3
Volume vn
5.3
Correspondence
Responsiveness Summaries
Responsiveness Summaries (cont'd.)
Responsiveness Summaries (cont'd.)
-------
~uJUvan's Ledge
(Operable Unit D)
NPL Site Administrative Record
Volume vm
5.4
Record of Decision (ROD)
10.0 Enforcement
]0.8 EPA Consent Decrees
] 1.0 Potentially Responsible Pany (PRP)
11.9 PRP-Specific Correspondence
]3.0 Community Relations
13.3 News CIippingslPress Releases
13.4 Public Meetings
13.5 Fact Sheets .
16.0 Natural Resource Trustee
16.1 Correspondence
17.0 Site Management Records
17.7 Reference DocumentS
-------
This Document Printed on Recycled Paper
-------
(
"
<>..
Section I
-------
ADMINISTRA TIVE RECORD INDEX
for the
Sullh'an's Ledge NPL Site
(Operable Unit II)
ROD Signed: September 27, 1991
3.0
Remedial Investigation (R1)
3.2
Sampling and Analysis Data
1.
'"
"Sampling and Analysis Plan for Additional Studies of Middle Marsh,"
Metcalf & Eddy, Inc. (April 1990).
The remaining Sampling and Analysis Data/or the Remedial Investigation (Rl)
may be reviewed, by appointment only, at EPA Region I, Boston, Massachusetts.
3.4
Interim Delive:rables
3.5
''Final Repon - Middle Marsh Investigation," EPA Environmental Response
Branch, Edison, New Jersey (March 29,1991).
"HydroJogy and Hydraulic Data for Middle Marsh," Metcalf & Eddy, Inc.
(September 1991).
Applicable or Relevant and Appropriate Requirements (ARARs)
1.
2.
1.
Letter from Richard Cavagnero, EPA Region I to Madeline Snow,
Commonwealth of Massachusetts Department of Environmental Protection
(April 10, 1991). Concerning request for state ARARs.
Letter from Madeline Snow, Massachusetts Department of Environmental
Protection to Richard Cavagnero, EPA Region I (May 9, 1991). Concerning
identification of state ARARs with attached "ARARs Identification - Sullivan's
Ledge -' Middle Marsh OU. " . .
Remedial Investigation (R1) Repons
2.
3.6
Repons
''Final Remedial Investigation - Additional Studies of Middle Marsh, Volume 1-
Nan-ative," Metcalf & Eddy, Inc. (April 1991).
''Final Remedial Investigation - Additional Studies of Middle Marsh, Volume n -
Appendices," Metcalf & Eddy, Inc. (April 1991).
Comments
1.
2.
CommelllS on the Rememol Investigation and Proposed Plan received by EP A Region I
during the formal public COmment period are filed and cited in 5.3 Responsiveness
-------
3.9
3.7
Page 2
Work Plans and Progress Repons
1.
2.
"Work Plan for Middle Marsh Investigation," EPA Environmental Response
Branch, Edison, New Jersey (June 23, 1989).
"Work Plan for Middle Marsh Investigation," EPA Environmental Response
Branch, Edison, New Jersey (August 3,1989).
''HealtH and Safery Plan for Middle Marsh," Metcalf & Eddy, Inc.
(November 1989).
''Work Plan for Additional Studies of Middle Marsh," Metcalf & Eddy, Inc.
(April 1990).
Trip Repon on a Visit to Sullivan's Ledge Site, Janet Baldwin, Peter Boucher,
James Maughan, Sandra McCarron and Reyhan Mehran, Metcalf & Eddy, Inc.
(September 21, 1990). Concerning additional sample locations.
Health Assessments
3.
4.
s.
1.
"Addendum to Health Assessment," U.S. Department of Health of Human
Services Agency for Toxic Substances and Disease Registry
(September S, 1989).
Integrated Risk Infonnation System (IRIS) Status Repons, EPA Region I
(March I, ]991) for the folJowing chemicals:
A. Acenaphthene
B. Aceto~
C. Anthracene
D. Benzo[a]pyrene (BaP)
E. Benzo[k]fluoranthene
F. Benzoic acid
G. Bis(2-ethylhexyl)phthalate (BEHP)
H. Butyl benzyl phthalate
1. Cadmium
1. Carbon tetrachloride
K. Chlorofonn
L. Copper
M.. Dibenzofuran
N. Diburyl phthalate
O. Dichlorodiphenyl dichloroethane (DDD)
P. Dichlorcxliphenyldichloroethylene (DDE)
Q. Dich]orodipheny]trich]oroethane (DD1)
R. Dich]oromethane
S. FJuoranthene
T. FJuorene
U. Lead and compounds (inorganic)
V. Manganese
W. Methyl ethyl ketone (MEK)
X. N-Nirrosodiphenylamine
Y. o-Cresol
Z p-Cresol
AA. Pentachlorophenol
BB. Phenol
CC. Polychlorinated biphenyls (PCBs)
DD. Pyrene
EE. Toluene
-------
4.0
4.6
Feasibility Study (FS)
Page 3
4.9
5.0
Feasibility S~udy (FS) Repons
1. ''Final Feasibility Study Repon of Middle Marsh," Metcalf & Eddy, Inc.
(May 1991).
Proposed Plan for SeJected Remedial Action
1.
"EPA Proposes Oeanup Pian for the Middle Marsh Study Area at the Sullivan's
Ledge Site," EPA Region I (May 1991).
Comments
CommentS on the Feasibility Study and Proposed Plan received by EPA Region J during
thl!formal public comment period are filed and cited in 5.3 Responsiveness SU1n11Ulries. .
5.1
Record of Decision (ROD)
5.2
Comspondence
1.
Letter from CharJa Reinganum, CommonweaJth of Massachusetts Department of
EnvironmenraJ Protection to lay CopeJand, Commonwealth of Massachusetts
Division of Fish and Wildlife (April 18, 1991). Concerning how remedial
measures may affect the Spotted tunle and the mystic valley amphipod.
Letter from Richard F. Bohn, City of New Bedford to lane Downing, EPA
Region I (April 23, 1991). Concerning proposed zoning for golf course.
Letter from Jay Copeland, Commonwealth of Massachusens Division of Fish
and Wildlife to Charla Reinganum, Commonwealth of Massachusetts
Department of Environmental Protection (May 9, 1991). Concerning response
to the April 18, 1991 Jetter from Charla Reinganurn.
Letter from Michael O'Rei11y, Town ofDanmouth to lane Downing, EPA
Region I (May 30,1991). Concerning mink sightings in Danmouth.
Letter from Stephen A. Petron, Metcalf & Eddy, Inc. to lane Downing, EPA
Region I (September 19,1991). Concerning the attached photographs of mink
trackings observed at the site.
Letter from Steven E. Mierzykowski, U.S. Department of the Interior Fish and
Wildlife Service to lane Downing, EPA Region I (September 23, 1991).
Concerning seJection of mink for the risk assessment as appropriate.
Memorandum from lames Mahala, Commonwealth of Massachusetts
Department of Environmental Protection to HeJen WaJdon, Commonwealth of
Massachusetts Department of Environmental Protection (September 24, 1991).
Concerning review of remedial alternatives and wetlands restoration.
Letter from lames T. Maughan, MetcaJf & Eddy, Inc. to Jane Downing, EPA
Region 1 (September 27,1991). Concerning analysis compJiance with
substantive regulations under Section 404(b) of the Clean Water Act
Letter from Daniel S. Greenbaum, Commonwealth of Massachusens Depanment
of Environmental Protection to Julie BeJaga, EPA Region I
(September 27, 1991). Concerning concurrence with seJected remedy and
contingency remedy.
Applicable or Relevant and Appropriate Requirements (ARARs)
2.
3.
4.
5.
6.
7.
8.
9.
1.
Ooss-Reference: AppJicable or Relevant and Appropriate Requirements
(ARARs) for the Record of Decision are in Section 11.B of the Record of
-------
Page 4
5.3
Responsiveness Summaries
1.
Cross-Reference: Responsiveness Summary, EPA Region I
(September 27, 1991) [Filed and included as an Appendix to entry number 1 in
5.4 Record of Decision (ROD)].
Cross Reference: Transcript, Public Hearing Summary, EPA Region I
(May 28, 1991) [Filed and included as an Appendix to entry number 1 in
5.4 Record of Decision (ROD)].
The following citations indicate written commenzs received by EP A Region J during
the formal comment period.
2.
3. Letter from Thomas M. Hoban (Attorney for United Dominion Industries) to
Jane Downing, EPA Region I (June 5,1991). Concerning request for an
extension of the public comment period.
4. Letter from Warren A. Fitch, SwidJer & Berlin (Attorney for Emhan Industries)
to Jane Downing, EPA Region I (June 6,1991). Concerning request for an
extension of the public comment period.
5. Lener from Timothy N. Cronin, Commonwealth Electric to Jane Downing, EPA
Region I (June 7. 1991). Concerning request for an extension of the public
comment period.
6. Lener from Timothy N. Cronin, Commonwealth Gas to Jane Downing, EPA
Region I (June 7, 1991). Concerning request for an extension of the public
comment period.
7. Lener from Gary W. Gifford, Goodyear Tire & Rubber Company to Jane
Downing. EPA Region I (June 10, 1991). Concerning request for an extension
of the public comment period.
8. Letter from A. Larry Medeiros, Titleist to Jane Downing, EPA Region I
(June 11, 1991). Concerning request for an extension of the public comment
period.
9. Letter from Kathleen E. McGrath, Palmer & Dodge (Attorney for
Bridgestone/Firestone) to Jane Downing, EPA Region I (June 13, 1991).
Concerning request for an extension of the public comment period.
10. Comments Dated June 17, 1991 from Philip T. Gidley, GidJey Laboratories on
the May 1991 "EPA Proposes Cleanup Plan for the Middle Marsh Study Area at
the Sullivan's Ledge Site," EPA Region 1.
11. Letter from Therese G. Pinter, Seyfarth, Shaw, Fairweather & Geraldson
(Attorney for Chamberlain Manufacturing) to Jane Downing, EPA Region I
(June 18, 1991). Concerning request for an extension of the public comment
period.
12. Telephone Notes Between Jane Downing, EPA Region I and Antoine Correir
(J une 28, 1991). Concerning source of PCBs at the site.
13. Comments Dated July 31,1991 from Michael J. Glinski. City of New Bedford
on 'the May 199] "EPA Proposes Cleanup Plan for the MiddJe Marsh Study Area
at lhe Sullivan's Ledge Site," EPA Region I.
14. Comments Dated July 31,1991 from Howard Weir, Morgan, Lewis & Bockius
(Attorney for Federal Pacific Electric Company) and Laurie Bun, Foley, Hoag &
Eliot (Attorney for CorneIl-DLibilier Electronics, Inc.) on the May 1991"EPA
Proposes Cleanup Plan for the Middle Marsh Study Area at the Sullivan's Ledge
Site," EPA Region 1.
15. Petition, Residents and Users of the MunicipaJ Golf Course, New Bedford.
Concerning removal of PCBs from the site (July 1991).
]6. Comments Dated August 5,199] from John F. Shea, McGregor, Shea &
Doliner (Attorney for Brinany Dyeing & Printing Corporation) on the
May 199] "EP A Proposes Cleanup Plan for the Middle Marsh Study Area
-------
5.4
5.3
Page 5
Responsiveness SUmmaries (cont'd)
17. Lener from Frank C. Huntington, Widen, Slater & Goldman (Attorney for
Acuslu)et Company, el aI) 10 lane Downing, EPA Region 1 (AuguSt 5,1991),
Concerning the anached Comments from Acushnet Company, ct a1:
A. Technical Comments, Appendix A, GEl Consultants, Inc.
(August 5, 1991).
B. Technical Comments, Appendix B, Volumes I" n, GEl Consullants,lnc,
(August 5, 1991).
C. TechnicaJ Comments, Appendix C. Volumes I, n, m & IV,
GEl Consultants, Inc. (August 5, 1991).
Record of Decision (ROD)
1.
Record of Decision for the Middle Marsh Operable Unit, EPA Region I
(September 27, 1991).
10.0 Enforcement
10.8 EPA ConsentD~s
1.
Consent Decree and anached Statement of Work, Unired Srares 01 America and
Commonwealrh 01 Massachuserrs v. Acushner Company, er ai, United States
District Coon for the District of Massachusens (September 28, 1990).
11.0 PotentiaJly Responsible Pany (PRP)
11.9 PRP-Specific Correspondence
1.
Letter from Merrill S. Hohman, EPA Region I to John T. Ludes, Acushnet
Company (April 6, 1990) with anached list ofPRPs. Concerning notice of -
potential liability. - .
Lener from MerriJ1 S. Hohman, EPA Region I to President, Glen Petroleum
Corporation (May 30, 1990): Concerning notice of potential liability.
Lener from Merrill S. Hohman, EP A Region I to President, Pacific Oil
Company (May 30, 1990). Concerning notice of potential liability.
13.0 Community Relations
2.
3.
13.3 News Clippings/Press Releases
1.
2.
"Environmental News - EPA Proposes Cleanup For SuJJivan's Ledge," EPA
Region I (May 21, 1991).
'The Vmted Stales Environmental Prorecrion Agency Invites Public Comment
Qn th~ Proposed Plan and Feasibility Study for the Middle Marsh Study Area at
the SuIIivan's Ledge Superfund Site in NelA' Bedford, Massachusetts," The New
Bedford Standard Times - New Bedford, MA (May 22, 1991).
"Environmental News - EPA Extends Comment Period For SuUivan's Ledge,"
EPA Region I (June 21, 1991). -
3.
13.4 Public Meetings
1.
EPA Region I-Meeting Summary, Public Meeting for the Sullivan's Ledge Site
-------
Page 6
13.5 Fact Sheets
1.
"Superfund Program Fact Sheet - EPA Completes Supplemental Remedial
Investigation of the Middle Marsh Study Area at the Sullivan's Ledge Superfund
Site," EPA Region] (April 1991).
16.0 Natural Resource Trustee
16.1 Conespondence
1.
Lener from Menill S. Hohman, EPA Region I to Roxanne Mayer,
Commonwealth of Massachusetts Depanment of Environmental Protection
(Janwuy 12, 1990). Concerning notification of potential damage to natUral
resources at the site.
17.0 SiteManagementReco~
17.7 Reference Documents
1.
U.S. Environmental Protection Agency. Risk Reduction Engineering
Laboratory. Proiecr SummQ~: EV~J~a~~~oh~h~ ~~.S.T. Solvent Extraction
Slud~e Treatmerlt Technol Twe - u t (EPN600/S2-88/051),
November 1988.
"The B.E.S.T. Solvent Extraction Process Applications with Hazardous
Sludges, Soils and Sediments," Lanny D. Weimer, Resources Conservation
Company (September 1989).
U.S. Environmental Protection Agency. Office of Solid Waste and Emergency
Response. Innovative Technology: B.E.S.T. Solvent Extraction Process
(OSWER Directive 9200.5-253FS), November 1989.
U.S. Environmental Protection Agency. hn J D m n
F VC;feme; anicc; Ex i v T W B ~ H
(EPA/540/S5-90/002), August 1990.
"Wetlands Protection Program Policy 90-2: Standards and Procedures for
Detenruning Adverse Impacts to Rare Species Habitat," Commonwealth of
Massachusetts Depanment of Environmental Protection, August 1990.
Memorandum from Erich W. Bretthauser, EPA Headquaners to Regional
Administrators (March 22, 1991). Concerning the attached "Status Repon on
the Interaction of PCBs and Quicklime," (June 11, 1991).
2.
3.
4.
5.
-------
Section n
-------
Page 7
GUIDANCE DOCUMENTS
EP A guidance documents may be reviewed at EP A Region I, Boston, Massachusetts.
General EPA Guicfancf' Do{"umf'nts
1. "Protection of Wetlands (Executive Order 11990), Appendix D," Federal Revister (VoI.42),
1977.
2. "Polychlorinated Biphenyls; Criteria Modification; Hearings," Federal Re~i~ter (VoL 44,
No. 106), May 31,1979. .
3. U.S. Environmenta1 Protection Agency. Office of Water Regulations and Standards. Ambient
Water Quality Criteria for Polychlorinated Biphenyls (EP A 440 5.80-068), October 1980.
4. Polychlorinated Biphenyls (PCBs); Final Rules and Notice of Request for Additional
Comments on Certain Individual and Class Petitions for Exemption," Federal R~~ist~I
(Vol. 49, No. 133), July 10,1984.
5. "Guidelines Establishing Test Procedures (or the Analysis of Pollutants Under the Clean Water
Act; Final Rule and Interim Final Rule and Proposed Rule," Federal Revister (V01.49,
No. 209), October 26, 1984.
6. Memorandum from William N. Hedeman, Director; U.S. Environmental Protection Agency
Office of Emergency and Remedial Response to Toxic and Waste Management Division
Directors, Regions I-X (OSWER Directive 9280.()..02), August 1, 1985 (discussing policy on
flood plains and wetland assessments for CERCLA Actions).
7. U.S. Depanment of Health and Human Services. National Institute for Occupational Safety
and Health, and Occupational Safety and Health Administration. Occupational SafetY and
Health Guidance Manua] for Hazardous Waste Site Activities, October 1985.
8. U.S. Environmental Protection Agency. Hazardous Waste Engineering Research Laboratory.
Handbook for Stabilization/Solidification of Hazardous Waste (EPAJ540/2-86/001),
June 1986.
11. "PCB SpiIl Cleanup Policy," Federal Re~ister (Vol. 52, No. 63), April 2, 1987.
12. U.S. Environmental Protection Agency. Office of Water Regulations and Standards.
Quality Criteria for Water 1986 (EPAJ44015-86/001), May 1,1987.
13. Letter from Lee M. Thomas, U.S. Environment Protection Agency to James 1. Florio,
Chairman, Subcommittee on Consumer Protection and Competitiveness, Committee on Energy
and Commerce, U.S. Hous~ of Representatives, May 21, 1987 (discussing EPA's
implementation of the Superfund Amendments and Reauthorization Act of 1986).
POOR QUALITY
-------
14. MemO!7lndum from I. Winslon Porter, U.S. Environmental Protection Agency. 0tT1Ce of
Solid Waste and Em"'iency ReSPOnse to Addressees ('Regional Administrators, Regions I-X;
Regional Counsel, Regions I-X; Dino:lon, Wasle Management Division, Regions 1. IV, V,
VD, and \ 'ID; Dino:roT, El11e1}:ency and Remedial Response Division, Region D; Din:clor,
Hazardous Wasle Management Division, Region X; Environmental Services Division
Directon, Regions I, VI, and VIr) (OS\VER Dino:tive 9234.0.()5), Iuly 9,1987 (discuSsing
. interim gUidarice on compliance With applicable or relevant and appropriale tequiremenrs).
IS. Meme>rnndum &om Heruy L. Longest, U.S. Environmental Protecb'on Agency omce of
.Emergency and Remedial Response and Gene Lucero, U.S. Environmental Protection Agency
Office of Wasle Pro8'ams Enforcemenllo Wasle Managemenr Division Din:ctors, Regions I-X
and EnvironmentaJ Services Division Direcron, Regions I, VI, and VII, AuguSt ll, 1987,
(discussing land disposal restrictions).
16. U.S. En vironmental Protecb'on Agency. Center for EnvironmentaJ Resean:h InfOltDation.
. '. w
(EPA/62518-87/Ol4), September 1987.
17. MemO!7lndum hom Denise M. Keehner, Chief, U.S. Environmental Protecb'on Agency
Chemical Regulation B!7Inch to Bill Hanson, U.S. Environmental Protection Agency SilO
POlicy and Guidance B!7Inch, OctobeT 14, 1987 (discUSSing commenrs On the PCB
con lamination -- reguJat"'Y and POlicy background meme>rnndum).
18. U.S. Environmental Protection Agency. Office of.Emergency and Remedial Response.
PUb1ic Tnvo)vel1Jent in tbe ~uperfu'1!U7o"'m (\\'IfJFS-87-004R), Fall 1987. .
19. Memo!7lndum from I. Winston POrler, U.S. EnvironmentaJ Protection Agency Office of Solid
Wasle and Emergency Response to Regional Administraton, Region I-X (OSWER Din:cb've
9834.11), Novem beT 13, 1987 (discussing reviSed PTocedures fOT implementing off-silO
response actions) With attached "Revised Procedures fOT ImpJemenb'ng Off-SilO Response
Actions. "
21. U.S. EnVironmental Protection Agency. omce of Emergency and Remedial Response.
.s:unerfqnd E>nosure A«!:.IWlenr Manl!iJ
-------
Page 9
"
26. Memorandum from Henry L. Longest n, Office of Emergency and Remedial Response and
Bruce M. Diamond, Office of Waste Programs Enforcement to Division Directors, Regions
I-X, December 29, 1988 (discussing environmental evaluation at Superfund sites).
;J
27. Interagency Cooperative Publication. FederaJ ManuaJ for Jdenti1Yin~ and ~Jineati'1:
Jurisdictional WetJand~, January 1989.
28. Memorandum from Bruce M. Diamond, U.S. Environmental Protection Agency Office of
Waste Programs Enforcement et al. to Addressees ("Directors, Waste Management Division,
Regions I, IV, vn, VITI; Director, Emergency and Remedial Response Division, Region n;
Directors, Hazardous Waste Management Division, Regions m, VI; Director, Toxic and Waste
Management Division, Region IX; Director, Hazardous Waste Division, Region X"),
February 9, 1989 (discussing interim final guidance on soil ingestion rates).
\
30. U.S. Environmental Protection Agency. Office of Research and Development EcoJQ~ica1
Asc;c:ssment of Hazardous Waste SiteS (EPA 600/3-89/013), March 1989.
31. 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).
32. 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).
33. Memorandum from Henry L. Longest, U.S. Environmental Protection Agency Office of .
Emergency and Remedial Response to Directors, Waste Management Division, Regions 1. IV,.
V, VII, Vln et al. (OSWER Directive 9347.2-01), June S, 1989 (discussing land disposal .
restrictions as relevant and appropriate).
34. U.S. Environmental Protection Agency. Risk Assessment Work Group, Region L
Supplementa] Risk AS
-------
Page 10
39. U.S. EnvironmentaJ Protection Agency. Office of SoIid Waste and Emergency Response.
The Feasibi)jty Study: Develo.pment and Sc~nin~ of Remedial Action Alternatives (OSWER
Directive 9355.3-01FS3), November 1989.
40. U.S. EnvironmentaJ Protection Agency. Office of Solid Waste and Emergency Response.
The Remedial Tnv~sri~ation: Site Cl1aract~zation and Treatability Studies (OSWERDirective
9355.3-DIFS2), November 1989.
41. U.S. EnvironmentaJ Protection Agency. Office of So1id Waste and Emergency Response.
State and Local Involvement in the Superfund Proeram (9375.5-01/F5), Fall 1989.
42. U.S. EnvironmentaJ Protection Agency. Office of Solid Waste and Emergency Response.
g~Tr;~e~~(g~m ~~;~ '91~.¥:~~j.~~terC~8~~i.nc~ with StJfe
43. "Superfund Exposure Assessment Manual, Technical Appendix: Exposure Analysis of
Ecological Receptors," preFared by Thomas E. Waddell, EnvironmentaJ Research Laboratory.
December 1989
44. U.S. EnyironmentaJ Protection Agency. Office of Emergency and Remedial Response. Risk
~~~~s~~~~~~tZ~Ig;1~8~~~)~D~~~~~ ~:9~~man Health Evaluation Manual {Part A-
45. U.S. EnvironmentaJ Protection Agency. Office of Solid Waste and Emergency Response.
R A 'n' h w n '.
SDW A (OSWER Directive 9234.2-06/FS), February 1990.
46. "National Oil and Hazardous Substances PolIution Contingency Plan; Final Rule," Pan n,
Federal Reeister (40 CFR Pan 300), March 8, 1990.
47. U.S. EnvironmentaJ Protection Agency. Office of Solid Waste and Emergency Response.
The Feasibility Study: Detailed Analysis of RemediaJ Action Alternatives (OSWER Directive
9355.3-01FS4), March 1990.
48. U.S. EnvironmentaJ Protection Agency. Office of Solid Wast~ and Emergency Response.
CERCLA Compliance with Other Laws Manual- Summary of Pan n - CAA, TSCA, and
Other Statutes (OSWER Directive 9234.2-07/FS), April 1990.
49. U.S. EnvironmentaJ Protection Agency. Office of Water ReguJations and Standards.
Water Quality Standards for \VetJands-NarionaJ Guidance (EPA 440/S-90-011), July 1990.
SO. Memorandum from Don R. CJay, U.S. EnvironmentaJ Protection Agency Office of Solid
Waste and Emergency Response to Regional Administrators, Regions I-X, (OSWER Directive
9835.15) August 28, 1990 (discussing guidance on developing risk assessments for sites
remediated under CERCLA). .
--
51. U.S. EnvironmentaJ Protec~on Agency. Office of Emergency and Remedial Response.
ui an m i J ti n f, r u rfun 't w' . .
(EPA 540 G-90 007, OSWER Directive 9355.4-01), August 1990.
52. U.S. EnvironmentaJ Protection Agency. Office of Solid Waste and Emergency Response.
h he - i n R . inn" . .
(OSWER Directive 9355.4-01), August 1990.
53. U.S. Environmental Protection Agency. Science Advisory Board. Reducine Risk: Settin&
Priorities and Strate~ies for Environm~ntaJ Protection (SAB-EC-90-021), September 1990.
POOR QUAliTY
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Page 11
54. U.S. Environmental Protection Agency. Office of Solid Waste and Emergency Response.
~~~~~~Id l~~n~(~~~(b~~~~~Ogj4~~~~~;~)~ ~~;~;~~e~~sO:Teatabi]j(y Variance for
55. U.S. Environmental Protecuon Agency. Office of Emergency RemediaJ Response.
Conducting Remedial rnvesti~ations/Feasibi)jty Studies for CERCLA Municipal Landfil1 SiteS
(EPN540/P-911OO1), February 1991.
56. U.S. Environmental Protection Agency. Summary Rt:port on Issues in Ecolo~cal Risk
Assessment (EPN62513-911018), February 1991-
57. U.S. Environmental Protection Agency. Office of Emergency and RemediaJ Response. RUk
~;;;;:~::~~~en~~T.s,~~~~n~j~a~U<'~~~~~:~~Is~~~~r ~:t. 1991.
58. U.S. Environmental Protection Agency. Office of Emergency Remedial Response. Risk
Assessment in Superfund: A Primer (First Edition) (EPAl5401X-911OO2), Apri11991-
59. Memorandum from Don R. Clay, U.S. Environmental Protection Agency to Directors,
Regions I-X (OSWER Dirccuve 9380.0-17), June 10, 1991 (discussing furthering the use of
innovative treatment technologies in OSWER programs).
POOR QUALITY
ORIGINAL
POOR OG/H;
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i
j
APPENDIX C
STATE CONCURRENCE LETTER
SULLIVAN'S LEDGE SITE
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\
.
j
Commonwealth of Massachusetts
Executive Office of Environmental Affairs
. Department 0'
Environmenfal Protection
D8nl., s. Greenbaum
Com"':"'1O. -
September 27, 1991
Ms. Julie Belaga
Regional Administrator
U.S. EPA Region I
JFK Federal Building
Boston, MA 02103
RE:
Sullivan's Ledge
Federal Superfund Site
Operable Unit Two --
Middle Marsh and
adjacent wetlands
:ROD Concurrence
Dear Ms. Belaga:
The Department of Environmental Protection (the Department)
has reviewed both the preferred remedial action alternative and the
contingency remedial action alternative recommended by EPA for
Operable Unit Two, Middle Marsh and adj acent wetlands, of the
Sullivan's Ledge Federal Superfund Site. The Department concurs
wi th EPA' s selected remedy which includes excavation of
contaminated soils/sediments and their containment under the
Sullivan's Ledge disposal area cap that is being constructed as
part of Operable Unit One. In addition, the Department concurs.
with EPA's contingency remedy which includes excavation of.
contaminated soils/sediments and treatment by solvent extraction.
The Department has evaluated EPA's preferred alternative and
contingency alternative for consistency with M.G.L. Chapter 21E and
the Massachusetts Contingency Plan 310 CMR 40.00 (MCP) and has
determined that both alternatives are consistent with the
requirements of the MCP. However, a permanent solution
determination cannot be made until it has been demonstrated that
the remedial measure or combination of measures will meet the Total
Site Risk Limits as defined in 310 CMR 40.00 for the entire
Sullivan's Ledge Fede~al Superfund Site.
The Department generally identifies the MCP as an applicable
requirement for sites in Massachusetts while reserving the right
to argue that Chapter 21E constitutes an independent enforcement
authority that is not subject to the waiver provisions of CERCLA
section 121 (d) (4). The Department identifies the MCP and Chapter
21E as applicable r~quirements, within the meaning of CERCLA, for
On. Wlnt.r Street
. Bo.ton, M"..chuMttI 02108
.
fAX (817) 556-1048
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Sullivan's Ledge Concurrence
Belaga .
September 27, 1991
Page -2-
Operable Unit Two of the Sullivan's Ledge Federal Superfund Site.
The selected remedy and the contingency remedy appear to meet
all Massachusetts state ARARs. This will continue to be evaluated
as remedial design progresses and during implementation and
operation.
The Department looks forward to working
implementing the Operable Unit Two remedy. If
questions or require additional information, please
Reinganum at 292-5826.
wi th you in
you have any
contact Charla
,
"
Very truly yours,
9i.,.~ ~);u.
Daniel S. Greenbaum, Commissioner
Massachusetts Department of
Environmental Protection
cc:
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