United States Office of
Environmental Protection Emergency and
Agency Remedial Response
EPA/ROD/R01-93/078
March 1993
&EPA Superfund
Record of Decision:
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50272.101
REPORT DOCUMENTATION 11. REPORT NO. . 2. 3. Reclplenr. Acca.lon No.
PAGE EPA/ROD/ROl-93/078
4. Title end Subtitle 5. Report Date
SUPERFUND RECORD OF DECISION 03/25/93
Salem Acres, MA 6.
First Remedial Action - Final
7. Author(l) 8. Performing Organization Aept. No.
9. Performing Organization Nama and AddrIU 10 ProJact Ta.klWork Unit No.
11. Contract(C) or Grant(G) No.
(C)
(G)
12. Sponsoring Organization Name and Add..... 13. Type of Report & Period COVlrad
U.S. Environmental Protection Agency
401 M Street, S.W. 800/800
Washington, D.C. 20460 14.
15. Supplementery Note.
PB94"'963711
16. Abstract (Limit: 200 worda)
The 234-acre Salem Acres site is a former waste disposal area located approximately one
quarter mile west of Route 107 near Salem and Peabody, Massachusetts. Land use in the
area is primarily residential. Although the site remains relatively undeveloped,
densely populated communities are located nearby, and there are an estimated 2,600
residents within a one-mile radius. Ground water at the site is classified as a
sole-source aquifer; however, ground water in the vicinity of the site remains
relatively unaffected by contamination. The site is surrounded to the north, east, and
west by seven wetland areas, ranging in size from one to three acres. Surface water
drainage patterns are complicated by a surface divide that separates the site into two
drainage basins. On the west side of the site, drainage flows into a series of
wetlands that connect and flow into the Strongwater Brook drainage basin, which in turn
empties into the North River and eventually, into Beverly Harbor on the coast of
Massachusetts. The east side of the site drains into the wetlands that connect with
Thompson's Meadow Basin, which flows into an unnamed brook along Swampscott Road.
There are several debris piles scattered throughout the site; however, hazardous
substances are confined primarily to the southern 13 acres. From the mid 1940s until
(See Attached Page)
17. Document Analysl. a. Descrlptora
Record of Decision - Salem Acres, MA
First Remedial Action - Final
Contaminated Media: soil, debris, sludge, sw
Key Contaminants: VOCs (benzene, xylenes), other organics (dioxin, PAHs, PCBs), metals
(arsenic, chromium, lead)
b. IdentifieralOpen-Ended Terms
c. COSATI Field/Group
18. Availability Statlmlnt 19. Security Cia.. (ThIs Alport) 21. No.otPagas
None 149
20. Security Cia.. (ThIs Pagl) 22. Price
None.
(Sla ANSI.Z39.18)
SH Instruct/ons on Rlverse
OPTIONAL FORM 272 (4-77)
(Formerly NTIS-35)
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EPA/ROD/ROl-93/078
Salem Acres, MA
First Remedial Action - Final
Abstract (Continued)
1969, the South Essex Sewerage District (SESD) disposed of an estimated 28,000 yd3 of
sewage material onsite under an agreement with the previous owner. Reportedly, this
material contained large quantities of tannery wastes, including chromium, fats, and
grease, and was disposed of in a series of unlined lagoons (known as disposal areas DA1
and DA2) located in the southern 13 acres of the site. Lime was added occasionally to the
waste, and gravel was used as a cover. Historical aerial photographs show that there may
have been as many as ten lagoons within the DA1 and DA2 disposal areas at various times,
although to date only eight have been identified. There are also five lagoons (identified
as SL-1 to SL-5) located next to the DA areas that contain varying amounts of hazardous
substances and three onsite debris piles, (SL-6, SL-12, and SL-13). The site also
contains a fly ash pile (SL-4) and an old landfill (SL-5), approximately 0.6 and 0.5
acres, respectively. In 1969, the site was sold to Salem Acres Inc., and the agreement to
allow SESD to dispose of sludge onsite was terminated. The SESD conducted two emergency
removal actions at the site. In 1987, lagoon water was removed and disposed of, the
slurry wall was capped at DA-1 and DA-2, and a fence was installed. In 1990, activities
included drum repacking and storage and repair of ground water monitoring wells and
fencing. This ROD addresses a source control remedy for the contaminated soil, debris,
and sludge at the site. Ground water at the site and adjacent wetlands demonstrate only
minor contamination; therefore, no future RODs are planned. The primary contaminants of
concern affecting the soil, debris, sludge, and surface water are VOCs, including benzene
and xylenes; other organics, including dioxins, PAHs, and PCBs; and metals, including
arsenic, chromium, and lead.
The selected remedial action for this site includes selecting a permitted landfill for
offsite disposal of materials; conducting bench-scale and pilot-scale treatability studies
to determine fixation material and mixing requirements; conducting soil delineation
studies at the hazardous waste areas to determine cleanup boundaries based upon site
cleanup levels; decontaminating debris from the debris piles in preparation for offsite
disposal; removing the existing cap for offsite disposal; pretreating sludge at DA-1 and
DA-2, if required; preparing and mixing fly ash, followed by treating sludge in DA-1 and
DA-2 in-situ using fixation; excavating all treated material in areas DA-1 and DA-2, all
untreated materials in SL-1 through SL-5, and debris piles SL-6, SL-12, and SL-13,
followed by offsite disposal at a permitted landfill; closing any onsite wells; employing
drainage control measures to protect wetlands and waste areas and removing lagoon water
and treating it, if necessary; implementing engineering controls and air monitoring;
monitoring ground water and regrading the site with clean soil; and providing a
contingency remedy for capping, if the selected remedy cannot treat the sludge to render
it non-hazardous under RCRA since the waste cannot be classified as "special waste" under
the State regulations, and treated lagoon sludge and untreated soil cannot be disposed at
a permitted landfill. This contingency remedy will include all components of the selected
remedy, as well as the following: conducting a feasibility study on the use of the
existing cap, followed by removal and disposal of the cap, if required; consolidating soil
to reduce the number of individual RCRA caps needed and to increase remedy effectiveness;
constructing a RCRA cap at DA-1, DA-2, SL-3, SL-4, SL-5, SL-6, SL-12, and SL-13, based on
the results of a design study; constructing concrete retaining walls and barrier walls to
protect wetlands and provide side wall stability; implementing institutional controls to
preclude the use of capped areas; and maintaining the integrity of the RCRA cap. The
estimated present worth cost for this remedial action is $9,123,000, which includes an
annual O&M cost of $21,000. The estimated present worth cost for the contingency remedy
is $4,410,000, which includes an annual O&M cost of $37,000 for 30 years.
PERFORMANCE STANDARDS OR GOALS:
Chemical-specific cleanup goals for soil and sludge are based on excess cancer risk levels
between 10-4 and 10-6 and practical quantitation limits/background values for any
non-detectable concentrations, and include carcinogenic PAHs 1.2, mg/kg; PCBs 1 mg/kg;
dioxins 1 mg/kg; arsenic 40 mg/kg; beryllium 0.42 mg/kg; chromium 900 mg/kg; and lead 500
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E. -. .' - ~.,'"
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DECLARATION FOR THE RECORD OF DECISION
SALEH ACRES SI'rE
SALEH, HASSACBDSETTS
HARCR 25, 1993
STATEMENT OF PURFOSE
This decision document represents the selected remedial action
for the Sale~ Acres Site in Salem, Massachusetts, developed in
accordance with the Comprehensive Environmental Response,
Compensation ar.d Liability Act 'of 1980 (CERCLA), as amended by
the Superfund &~end:ents and Reauthorization Act of 1986, and to
the extent practicable, the National Oil and Hazardous Substances
Contingency Plan (NCP), 40 CFR Part 300 et sea., as amended. The
Regional Administrator has been delegated the authority to
approve this Reccrd of Decision (ROD).
The 'Commonwealth ~f Massachusetts has concurred on the selected
remedy and on the alternative remedy.
STA'rEMENT OF BASIS
This decision is ~ased on the Administrative Record which has
been developed in accordance with Section 113 (k) of CERCLA and
which is availabl~ for public review at the Salem Public Library
at 352 Lafayette Street, Salem, Massachusetts and at the Region I
Waste Management ~ivision Records Center in Boston, MA. The
Administrative Re~ord Index (Appendix F to the ROD) identifies
each of the items comprising the Administrative Record upon which
the selection of ~~e remedial action is based.
ASSESSMENT OF THE SITE
Actual or threate:led releases of hazardous substances from this
Site, if not addressed by implementing the response action
selected in the ROD, may present an imminent and substantial
endangerment to hL~an health or public welfare or to the
environment.
DESCRIPTION OF THE SELECTED REMEDY
This ROD sets for~n the selected remedy for the Salem Acres Site,
which includes so~rce control components to obtain a
comprehensive remedy.
The remedial acti~n for the Salem Acres Site, as described 'in
this ROD, address as the principal threats to the human health and
the environment posed by exposure of humans to contaminated
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,
7.
8.
9.
10.
11.
12.
13.
14.
15.
16.
2
principal threats to human health and the environment posed by
the sources of c=~tamination at the Site resulting from dermal
absorption and ir.cidental ingestion of contaminants in surficial
soils.
The major compone~ts of the selected source control remedy
(SC-7S; Soil-Fixa~ion) ir.clude:
1.
2.
Selection of a permi~ted landfill for off-site disposal;
Treatability studies to detercinefixation material and
mixing requi=ements, including bench scale laboratory tests
and a field cilot test;
Additional soil delineation studies at hazardous waste areas
including, but not limited to, Sludge Disposal Areas (DA-l
and DA-2) and Contaminated Soil Areas (SL Areas) to
determine cleanup boundaries based upon Site Soil Cleanup
Levels;
Site preparation, including road construction, security
measures, well closure, grading and grubbing activities, and
decontamination pad construction;
Drainage control measures to protect wetlands and waste
areas;
Air monitorir.g and engineering controls for dust, odors, and
noise;
Existing cap removal and disposal;
Removal of lagoon water and treatment (if required);
Pretreatment of sludges at DA-1 and DA-2 (if required);
Fly ash preparation and mixing;
In-situ mixing with fly ash at DA-1 and DA-2;
Excavation of treated waste from DA-1 and DA-2;
Excavation of untreated waste from SL-3, SL-4, SL-5,
SL-6, SL-12, and SL-13;
Excavation of other soils and sludges above Soil Cleanup
Levels based on additional soil delineation studies at the
Site;
Off-site disposal by truck of DA and SL wastes and other
soils and/or sludges above Soil Cleanup Levels at the
selected pe~itted landfill;
Other components include groundwater well installation and
monitoring for a minimum of five years, Site restoration
to previous g=ade with clean fill and Site vegetation.
3.
4.
5.
6.
The Selected soil-:ixation Remedy (SC-7B) must satisfy the
following three cenditions in order to be implemented:
. 1.
2.
Treatability testing by bench tests and pilot scale
operation must demonstrate that the fly ash fixation
process rende=s the sludges non-ignitable and non-toxic
under RCRA as defined at 40 CFR 261.21 and 261.24
respectively.
All waste fre: the Site can be classified as a "Special
Waste" under Massachusetts Solid Waste Regulations 310
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7.
8.
9.
10.
11.
12.
13.
14.
15.
3
3.
Treated lagoon sludges from DA-l and DA-2, and untreated
soils from SL-3, SL-4, SL-3, SL-6, SL-12, and. SL-13 can be
disposed at a permitted landfill.
Unless a~l of the above con~~tions are met, a contingent remedy,
Alte~~at~ve SC-2, RCRA Subt~~le C Hazardous Waste Capping will be
the selected remedy for the ~ite. The RCRA Subtitle C Cap will
cove~, at a minimum, the lagcon areas DA-l and DA-2 and
conta~inated soils from the ~L Areas and all other contaminated
soils and/or sludges that ar; above the Soil Cleanup Levels.
Pendi~g design studies, these soil areas may be consolidated
prior to RCRA Capping. Both che preferred remedy and the
contingent remedy will add~ess the primary risk at the Site which.
is direct contact with and i~~estion of soils and/or sludges.
The major components of the c~ntingent remedy are listed below:
1.
Additional soil delineation studies at SL and DA Areas to
determine cleanup bounda:ies based upon Site Cleanup Levels;
All contaminated soils C.1 the Site that exceed Site Cleanup
Levels will be included in the contingent remedy.
Site preparation, incluc:.Lng road construction, security
measures, well closure, qrading, grubbing activities, and
decontamination pad cons -:ruction;
Drainaqe control measure~ to protect wetlands and waste
areas;
Air-monitoring and engin~ering controls for dust, odors, and
noise; .
Feasibility study on the use of the existing cap;
Soils consolidation to reduce the number of individual RCRA
Caps and to inc~ease remedy effectiveness;
Existing HDPE cap removal (if required) ;
Treatment of lagoon water and disposal (if required) ;
Construction of RCRA Subtitle C Cap at DA-l, DA-2, and
SL-3, SL-4, SL-S, SL-6, SL-12, and SL-13 Areas based on
results of design study for SL Area consolidation and soil
sampling.
Construction of concrete retaining walls and barrier walls
to protect wetlands and to provide side wall stability;
Institutional Controls to preclude use of Capped areas;
Fencing and sign posting to preclude access to Capped areas;
Groundwater well installation and sampling;
Operation and maintenance requirements to assure RCRA
Subtitle C Cap integrity;
Evaluation of additional controls if groundwater monitoring
shows levels that exceed a risk of 1. 0 x 10.10 or that exceed
ARARS .
2.
3.
4.
s.
6.
DECLARATrON
The selected remedy and the alternative remedy are protective of
human health and the environment, attain Federal and State
require~ents that are applicable or relevant and appropriate for
this remedial action and are cost-effective. The preferred
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4
preference for remedies that utilize treatment as a principal
element to reduce the toxicity, ~obility, or volume of hazardous
substances. In addition, this remedy utilizes a permanent Site
solution by the requirement for eff-site waste disposal after
treat!nent.
The alternative remedy, SC-2, of a RCRA Subtitle C Cap does not
provide for treatment of the wasta, but the Cap will impede the
mobility of the waste through the groundwater by the elimination
of infiltration and control the primary risk at the Site
associated with Site soils. As this alternative remedy will
result in hazardous substances re~aining on Site above health-
based levels, a review will be co~ducted at least every five
years after commencement of remed~al action to ensure that the
remedy continues to provide adequate protection of human health
and the environment.
~ b-h~-;
DATE:
I' Paul G. Keoug
. Acting Regional A
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REGION
:t
RECORD OF DECISIC"'l SUHHARY
SALEH ACRE;
SALEH, KASSACH"7SETTS
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SALEM ACRES
,
TABLE OP CONTENT ~!
Contents
Paae Number
I.
SITE LOCATION. . . . . . . . . . . . . . . . . . . . . .
A. Surface Water. . . . . . . . . . . . . . . . . . . .
B. Geoloqy /'Hydroloqy . . . . . . . . . . . . . . . . . .
II. SITE 'HISTORY AND ENFORCEMENT ACTIVIT:ES . . . . . . . . .
A. Land Use and Response 'History. . . . . . . ... . . .
B. Enforcement 'History Contacts wit~: Defendants. . . .
III.
COHHt1N%TY PARTICIPATION.
. . . . .
. . . . . .
. . . .
:IV.
SCOPE AND ROLE OP OPERABLE trNIT OR F.ESPONSE ACTION. . .
V.
St1HMARY OP SITE CHARACTERISTICS. . . . . . . . . . . .
A. Soil. . . . . . . . . . . . . . . . . . . . . . . .
B . Ground Water. . . . . . . . . . . . . . . . . . . .
C. Wetlands. . . . . . . . . . . . . . . . . . . . . .
D . Air. . . . . . . . . . . . . . . . . . . . . . . . .
VI.
St1HMARY OP SITE USKS ..... . . . . . . . . . . . .
A. Exposure Pathways. . . . . . . . . . . . . . . . . .
B. summary of Baseline Risk Assessment. . . . . . . . .
C. Remedial Implications. . . . . . . . . . . . . . . .
VII.
DEVELOPHENT AND SCREEHDlG OP ALTE1U:AT%VES . . . . . . .
A. statutory Requirements/Response Objectives. . . . .
B. Technoloqy and Alternative Develcpment screening. .
VIII. DESCRIPTION OP ALTERNAT%VES . . . . . . .
A. Source Control (SC) Alternatives ~alyzed
. . . . . .
. . . . . .
IX.
St1HMARY OP 'l'EE COHPARATrvE ANALYSIS OP ALTERNATIVES. .
A. Evaluation Criteria. . . . . . . . . . . . . . . . .
X.
'l'EE SELECTED REHEDY . . . . . . . . . . . . . . . . . . .
A. Soil Cleanup Levels. . . . . . . . . . . . . . . . .
B. Description of Remedial Components. . . . . . . . .
%3:. STA'l't1'l'ORY DETERMINATIONS. . . . . . . . . . . . . . . .
A. The Selected Remedy is Protective of 'Human 'Health
and the Environment. . . . . . . . . . . . . . . .
The Selected Remedy Attains ARAP~ .........
The Selected Remedial Action is Cost-Effective. . .
The Selected Remedy utilizes Permanent Solutions
and Alternative Treatment or Resource Recovery
Technologies to the Haximum Extent Practicable. .
B.
C.
D.
1
2
2
3
3
4
5
6
9
10
14
15
16
16
18
19
22
23
23
24
25
25
38
38
46
47
48
57
57
59
73
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E.2
~he selected Remedy, SC-7B, satisfies the preference
for ~reatment Which permanentlY and siqnificantlY
reduces the ~oxicity, Xobility or Volume of the
Hazardous Substances as a principal ~lement . . . .
~he continqent Remedy, Alternative 5C-2, Does Not
satisfY the preference for ~reatment as the principal
Element. . . . . . . . . . . . . . . . . . . . .
76
E.l
77
X~I. Documentation of No Siqnificant Chanqes
. . . '. .
. . .
78
XI~I. S~A~E ROLE
..............
. . . . .
. . .
78
APPENDI:CES
J'iqures. . .
. . . . . .
. . .
. . . .
. . . .
. . .
. Appendix A
Appendix B
~a))les .
. . . . . . . . .
. . . . .
. . .
. . .
. . .
ARAR ~a1:Iles. .
commonwealth of. HaS sachUS etts Let~er of con
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SALEM ACRES ROD DECISION SUMMARY
I.
SITE LOCATION
The Salem Acres superfund Site (the Site) comprises an area of
234 acres and is located approximately one quarter mile west of
Route 107 near the Salem and Peabody, Massachus~tts Town line as
shown in Figure 1. The Site is comprised of lc~lands and small
wooded hills with an average slope of seven per:ent. To the
north and west, the Site is bordered by wooded land in Peabody
and to the south and east by residential housir.g in Salem.
Although there are several debris piles scattered throughout the
Site, hazardous substances are confined primarily to the southern
13 acres. This Record of Decision (ROD) covers the entire Site,
but focuses on the southern 13 acres.
The southern 13 acres are located on a hilly arE: with several
bedrock outcrops 200 feet from Barcelona Avenue in Salem,
Massachusetts. This area is surrounded to the r.~rth, east, and
west by seven wetlands. These wetlands, designQted WA-1 to WA-7,
range in size from one to three acres (Figure 2}. Additionally,
high tension power lines traverse the site in t~is southern area
in an east-west direction. The main hazardous substancesl
identified to date on the Site are shown in Fi~e 2 and are -
briefly described below:
1., Disposal Area (DA) DA-1, an area of 2.4 acr~s containing 5
unlined ~ludge lagoons and 8 drums of hazar~oussubstances;
2.
DA-2, an area of 2.3 acres containing 3 unl~ned lagoons;
3.
Soil Areas (SL) SL-1, SL-2, and SL-3, a combined area of 2
acres containing cQntaminated soils from past disposal
activities and/or from run-off from the adjacent waste
lagoons at DA-1 a~d DA-2;
SL-4, a fly ash pile 'of 0.6 acres;
4.
5.
SL-5, an old landfill of 0.5 acres; and
SL-6, SL-12, and SL-13, three debris piles located in the
north of the Site.
6.
The lagoons at DA-1 and DA-2 contain approximately 21,300 cubic
yards (cu/yds) of hazardous substances and the adjacent SL
contain approximately 15,300 cu/yds of hazardous substances.
There are also eleven debris piles located in the northern area
of the Site which contain general refuse. Several of these
1 DA and SL waste areas designations are taken from the
Remedial Investigation Report (RI), done by URS Consultants, May
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ROD DECISION SUMMARY
Salem Acres
Page 2
1;
debris piles also contain hazardous substances. O~~er structures
on the Site include chain link fencing around DA-1 and DA-2 and
three separate security gates. These gates and fer:cing were
erected on the Site in 1987 to preclude access to the waste
areas. Despi te these gates and the fence around tr..e sludge
lagoons at DA-1 and DA-2, there has been a history of vandalism
and trespassing at the Site.
Densely populated communities are located near the Site (although
the Site remains undeveloped). The closest, the B~rcelona Avenue
neighborhood is located about 200 feet south of the old landfill
(SL-5), as shown in Figure 2, and comprises about sixty homes.
Approximately 2,600 people reside within a one-mile radius of the
Site, which encompasses portions of the cities of ~alem, Peabody,
Lynn, and the town of Swampscott.
A more complete description of the Site location c~n be found in
the Remedial Investigation Report (RI) in Chapter I (Salem Acres,
Remedial Investigation Report, URS Consultants, Cleveland, Ohio;
May 29, 1992).
A. Surface Water
In the southern 13 acres, the surface water draina~e pattern is
complicated by a surface divide that separates the Site into two
drainage basins. In general, this divide is found between DA-1
and DA-2. On the west side of the Site (including waste areas
DA-1, SL-1, SL-4, and SL-5) drainage is in a westward direction
toward a series of on-site wetlands designated WA-1 and WA-2.
These wetlands connect and flow northward into the Strongwater
Brook drainage basin. This Brook continues to flow north into
the North River which eventually empties into Beverly Harbor on
the coast of Massachusetts.
The east side of the Site (DA-2, SL-2 and SL-3) , dr~ins in an
easterly direction toward wetlands WA-4, WA-5, and NA-6.
Although there is some flow north from Wetland WA-4, the general
flow from these wetlands is southward into the Thoro~son's Meadow
Basin which flows into an unnamed brook along swampicott Road.
B. Geology IHydrology
As previously mentioned, the southern 13 acres of tbe site where
hazardous wastes is concentrated, are located on a hilly portion
of land with several bedrock outcrops. Bedrock is overlain by
recent marsh deposits and a veneer of glacial till. Overall, the
overburden material is quite thin, varying from zero at the
numerous bedrock outcrops, to more than 17 feet in the lowland
areas adjacent to wetlands. The bedrock underlying these
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ROD DECISION SUMMARY
Salem Acres
Page 3
Groundwater at the Site was monitored at seven locatic~s in both
overburden and bedrock wells. The shallow overburden, which
averages about 9 feet, is discontinuous due to the ~ed~ock
outcrops. Moreover, several of the overburden monitorlng wells
were dry during sampling because of the thin nature of the
overburden material. The occurrence of this discontin'lous
overburden aquifer limits the conclusions which can be drawn
concerning the hydraulic gradients at the southern 13 ;icres of
the Site. However, it appears that groundwater flow 1.1 the
overburden and in the bedrock aquifer follows the sa~e general
pattern as the surface water with an east/west divide :t.nd a
discharge into the surrounding wetlands at WA-1, WA-4, WA-5, and
WA-6.
II. SITE HISTORY AND ENFORCEMENT ACTIVITIES
A. Land Use and Response History
Beginning in the mid 1940's and ending about 1969, the South
Essex Sewerage District (SESD) brought an estimated 38..000 cu/yds
of sewage material on the Site under an agreement with a former
Site owner, John Grasso. According to the RJ:, this ma-:erial
contained large quantities of tannery wastes including chromium,
fats and grease, and was disposed of in a series of un:.ined
lagoons loc~ted in the southern 13 acres of the Site. These
lagoons are designated as DA-1 and DA-2 (Figure 3A & 3~}}. Lime
was sometimes added to the waste after it was deposite.L in the
lagoons and gravel was occasionally used as a cover fo:' these
wastes.
Historical aerial photographs show that there have bee;l as many
as ten lagoons within the DA-1 and DA-2 disposal areas at
different times. There are presently eight identified lagoons at
the.DA areas. Adjacent to the DA areas are SL-1, SL-2, SL-3, SL-
4, and SL-5 which contain varying amounts of hazardous
substances. In 1969 the Site was sold to Salem Acres ::nc. and at
that time the agreement that allowed SESD to dump sluds'e on the
Site was terminated.
In the waste lagoons at DA-l and DA-2, there are appro::imately
21,300 cu/yds of hazardous waste sludge (hazardous sub~tances)
that include high concentrations of chromium, non-carcinogenic
polycyclic aromatic hydrocarbons (ncPAH), and carcinog~nic PAHs
(CPAH). These sludges also contain significant quantities of
oily material and xylenes, ignitable and volatile orga~ic
compounds (VOC). Based upon tests results in the RI, the wastes
at DA-1 and DA-2 are classified as ignitable under the Resource
Conservation and Recovery Act (RCRA ignitability is defined at 40
CFR 261.21). Wastes at SL-1, SL-2, and SL-3 contain r~n-off and
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ROD DECISION SUMMARY
Salem Acres
Page 4
,
CPAH. The Site also contains a fly ash pile (SL-4.) and a~ old
landfill (SL-5), approximately 0.6 and 0.5 acres respectiv~ly.
Both these waste areas contain hazardous compounds which i.lclude
chromium and CPAH.
EPA conducted two Emergency Removal Actions (ERA) at the s~te,
one in 1987 and one in 1990. The 1987 removal action (fun.ted by
EPA) consisted of lagoon water removal and disposal, cappi;lg and.
slUrry wall construction at DA-1 and DA-2, and fence/gate
construction to preclude Site access. The capping which r,~mains
in place consists of a double layer synthetic liner made 0:: High
Density Polyethylene (HDPE). These capped areas are surrc.mded
by a chain link security fence (This chain link fence repl.\ced
the original fence that was constructed by SESD at the
recommendation of the Massachusetts DEP in 1985). In 1990 a
second ERA was conducted by EPA and included drum repackin~( and
storage, posting of new signs, and repair of security gate:; and
monitoring well number 7. SESD carried out most of this w~'rk,
while EPA repaired the broken gates and installed new lock:. on
October 11, 1990.
The Site is zoned for residential housing, but to date, re~\ains
undeveloped. current land use has been restricted by the
security fencing installed during the ERA. However, vanda:.ism of
the signs, fences and gates, and Site trespassing with
recreational vehicles continues to occur.
B.
Enforcement History Contacts with Defendants
Between 1985 and 1992, EPA notified nine Potentially Respo!.sible
Parties (PRPs), who either owned or operated the Site, qen~rated
wastes that were shipped to the Site, arranged for the dis!osal
of wastes at the Site, or transported wastes to the Site 01 their
potential liability with respect to the Site. The earliesT
negotiations with the PRPs commenced on December 29, 1986
regarding performance of the Remedial Investigation/Feasibility
Study (RI/FS) at the Site. As a result of these negotiations, .
SESD entered into parallel federal and state Consent Order~ for
the performance of the RI/FS. The Consent Order with the
Commonwealth of Massachusetts was signed on June 11, 1987 and the
federal Consent Order was signed on June 15, 1987. SESD, to
date, has been the only PRP to work with EPA in conducting site
studies.
On January 28, 1987 the EPA Regional Administrator signed a
Superfund lien on the Site which named the Site owners
responsible for costs and damages associated with the 1987 ERA at
the Site. That lien was filed with the Essex County Recorder of
Deeds on January 30, 1987. On June 19, 1987 the EPA Regional
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ROD DECISION SaMHARY
Salem Acres
Page!
parties. That document was recorded with the Essex County
Registry of Deeds on July 1, 1987.
Concerning case litigation, EPA filed a Cost Recovery Action on
April 9, 1991 against the following three parties in order to
recover costs incurred during the past two ERAs:
1. DiBiase Salem Realty Trust
2. Ugo DiBiase
3. South Essex Sewerage District
III.
CO~TY PARTICIPATION
Throughout the Site's history, community concern and involvement
has been moderate. EPA has kept the community and other
interested parties apprised of the site activities through
informational meetings, fact sheets, press releases and public.
meetings.
In December of 1987, EPA held an informal meeting at the Old Tow~
Hall in Salem, Massachusetts to inform citizens of the ERA that
began in April, 1987. During September 1989, EPA released a
community relations plan which outlined a program to address
community concerns and keep citizens informed about activities
during remegial activities. EPA published a notice and brief
analysis of the Proposed Plan in The Salem News on June 18, 1992.
On June 24, 1992, EPA made the administrative record available
for public review at EPA's offices in Boston and at the Salem
Public Library. Also, on June 24, 1992, EPA held an
informational meeting at the Old Town Hall in Salem to discuss
the results of the RI and the cleanup alternatives presented in
the Feasibility Study (FS) and to present the Agency's Proposed
Plan. During this meeting, the Agency answered numerous
questions from the public concerning Site hazards.
From June 25, 1992 to July 25, 1992, the Agency held a 30-day
public comment period to accept public comment on the
alternatives presented in the FS and the Proposed Plan and on any
other documents previously released to the public. On July 15,
1992, the Agency held a public meeting at the Old Town Hall in
Salem 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 (see attachment A).
Following is a summary list of the Community Relations Activities
at the site:
1.
December 1987 - EPA held an informal meeting at the Salem
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ROD DECISION SUHHARY
Salem Acres
Page 6
2.
September 1989 - EPA completed the development of a Community
Relations Plan for the Site.
3.
May 1990 - EPA issued a fact sheet which provided an overview
of the RI Study.
4.
February 1992 - Massachusetts Department of Environmental
Protection (DEP) and Massachusetts Department of Public
Health held a public meeting to update the community on the
Site Health Assessment. EPA participated in this meeting and
presented a summary of the RI.
June 1992 - EPA announced the preferred remedial alternative
for the cleanup of the Site by issuing a Proposed Plan.
Copies of the Proposed Plan were mailed to all parties
included on the Site mailing list.
5.
6.
June 1992 - On June 24 a public informational meeting was
held to present and discuss the results of the RIfFS and to
present EPA's Proposed Plan.
June 1992 - On June 2S the Proposed Plan public comment
period opened.
7.
8.
July 1992 - Additional copies of the Proposed Plan were
mailed to 169 local residents who live near the Site and who
were not on the original mailing list.
July 1992 - On July 15 a public hearing was held at which EPA
accepted oral cQmments on the Proposed Plan.
9.
10. July 1~92 - On July 25 the public comment period closed.
IV.
SCOPE AND ROLE OF OPERABLE UNIT OR RESPONSE ACTION
The selected remedy was developed by combining components of
different alternatives to obtain a comprehensive approach for
Site remediation. Because groundwater at the Site and adjacent
wetlands demonstrate only minor contamination (within the
acceptable risk established by EPA of 1 x 10 -4 to 1 x 10 -6
based upon average concentrations of contaminants), the selected
remedy was developed for source control only. In summary, the
selected remedy, Alternative SC-7B, involves the in-situ (in-
place) treatment of lagoon sludges at DA-1, DA-2, with fly ash,
followed by the excavation of the treated sludge and soil and
excavation of other untreated contaminated soils from SL-3, SL-4,
SL-S, SL-6, SL-12, and SL-13 for removal to an off-site permitted
landfill. All contaminated Site soils and sludges above the Soil
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ROD DECISION SaKHARY
Salem Acres
Page 7
the remedy.
components:
7.
8.
9.
10.
11.
12.
13.
14.
15.
16.
The selected remedy includes the following
1.
2.
Permitted landfill selection for off-site disposal;
Treatability studies to determine fixation material and
mixing requirements, including bench scale laboratory tests
and a field pilot test;
Additional soil delineation studies at hazardous waste areas
including, but not limited to, DA and SL areas to determine
cleanup boundaries based upon Site Soil Cleanup Levels;
Site preparation, including road construction, security
measures, well closure, grading and grubbing activities, and
decontamination pad construction;
Drainage control measures to protect wetlands and waste
areas;
Air monitoring and engineering controls for dust, odors, and
noise; .
Existing cap removal and disposal;
Removal of lagoon water and treatment (if required);
Pretreatment of sludges at DA-1 and DA-2 (if required);
Fly ash preparation and mixing;
In-situ mixing with fly ash at DA-1 and DA-2;
Excavation of treated waste from DA-1 and DA-2
Excavation of untreated waste from SL-3, SL-4, and SL-5;
SL-6, SL-12, and SL-13;
Excavation of other soils and sludges above Soil Cleanup
Levels based on additional soil delineation studies at the
Site;
Off-site disposal by truck of DA and SL wastes and other
soils and/or sludges above Soil Cleanup Levels at the
selected permitted landfill;
Other. components include groundwater well installation and
monitoring for a minimum of five years, regrading site with
clean fill and revegetation.
3.
4.
5.
6.
The Selected Remedy, Alternative SC-7B, must satisfy three
conditions in order to be implemented:
1.
2.
Treatability testing by bench tests and pilot scale
operation must demonstrate that the fly ash fixation
process renders the sludges non-ignitable and non-toxic
under RCRA as defined at 40 CFR 261.21 and 261.24
respectively.
All waste from the Site can be classified as a "Special
Waste" under Massachusetts Solid Waste Regulations 310
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7.
8.
9.
10.
11.
12.
13.
14.
ROD DECISION SUMMARY
Salem Acres
Page 8
3.
Treated lagoon sludges from DA-1 and DA-2, and untreated
soils from SL-3, SL-4, SL-S, SL-6, SL-12, and SL-132 can be
disposed at a permitted landfill.
Unless all of the above conditions are met, a contingent remedy,
Alternative SC-2, RCRA Subtitle C Hazardous Waste Capping
(hereinafter, any reference to a RCRA Cap or RCRA Capping shall
mean a RCRA Subtitle C Cap) will be the selected remedy for the
Site. The RCRA Subtitle C Cap will cover, at a minimum, the
lagoon areas DA-1 and DA-2 and contaminated soils from SL-3, SL-
4, SL-5, SL-6, SL-12, SL-13 and all other contaminated soils and/
or sludges that are above the Soil Cleanup Levels.. Pending
design studies, these soil areas may be consolidated prior to
RCRA Capping. Both the preferred remedy and the contingent
remedy will address the primary risk at the Site which is direct
contact with and ingestion of soils and/or sludges. The major
components of the contingent remedy are listed below:
1.
Additional soil delineation studies at SL and DA Areas to
determine cleanup boundaries based upon Site Cleanup Levels;
All contaminated soils on the Site that exceed Site Cleanup
Levels will be included in the contingent remedy.
Site preparation, including road construction, security
measures, well closure, grading and grubbing activities,
decontamination pad construction;
Drainage control measures to protect wetlands and waste
areas;
Air monitoring and engineering controls for dust, odors, and
noise; .
Feasibility study on the use of the existing cap;
Soils consolidation to reduce the number of individual RCRA
Caps and to increase remedy effectiveness;
Existing HDPE cap removal (if required);
Treatment of lagoon water and disposal (if required);
Construction of RCRA Subtitle C Cap at DA-1, DA-2, and SL
Areas based on results of design study for SL Area
consolidation and soil sampling at areas SL-1 through SL-5;
Construction of concrete retaining walls and barrier
walls to protect wetlands and to provide side wall'
stability; .
Institutional Controls to preclude use of Capped areas;
Fencing and sign posting to preclude access to Capped areas;
Groundwater well installation and sampling;
Operation and maintenance requirements to assure RCRA
Subtitle C Cap integrity;
2.
3.
4.
5.
6.
2 The SL wastes will have to undergo testing to demonstrate
that they are non-ignitable and non-toxic under RCRA as defined
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ROD DECISION SUMMARY
Salem Acres
Paqe 9
,
15.
Evaluation of additional controls if groundwater monitoring
shows levels that exceed a risk of 1.0 x 10-4 or exceed
ARARS .
This contingent remedy is based upon source control and was
developed after an analysis of Site risks and the fact that off-
site migration of contaminants is within EPA acceptable risk
range of 1 x 10-4 to 1 X 10-6 ; based upon average levels of
contaminants (See Chapter X of this ROD for a comprehensive
description of the selected and contingent remedies).
v.
SUMMARY OF SI~E CRARAC~ERIS~ICS
A summary of Site contamination is provided below; however, a
more detailed analysis of the nature and extent of contamination
on the Site is found in Chapter IV of the RI. The RI included
numerous samples in the soils, sludges, and groundwater at the
Site as well as sampling and analyses in the adjacent wetlands
for surface water, sediment, and biological organisms. Air
sampling was conducted at six locations both on and off the Site
to determine the health risk to the public.
Results of the nature and extent of hazardous substances indicate
that contamination is primarily concentrated in the southern 13
acres of th~ Site. Hazardous substances at this area are found
in the sludge lagoons at DA-1 and DA-2, contiguous soil area SL-
3, a fly ash pile at SL-4, and at an old landfill designated SL-5
(Figure 2). Two additional areas, SL-1 and SL-2, are located
adjacent to the DA disposal areas and contain superficial
contamination from DA area runoff. Additionally, there are
eleven debris piles (SL-6 through SL-16) that are located
throughout the northern part of the site (Figure 2).
Contaminant analyses of site groundwater, wetland sediments,
surface waters, biota, and air indicate that, on an average,
contamination does not mi~ate in concentrations that represent a
risk qreater than 1 x 10 -4. Contamination at the Site is found
primarily at the DA lagoon and SL areas. Figure 3 provides a
location map of the soils, surface water, sediments, and qround-
water sampled on and off-site, excluding the DA lagoon areas
which are shown in Figure 4. Siqnificant hazardous compounds
identified at the site include the following:
1.
Heavy Metals, including lead (Pb), arsenic (As), chromium
(Cr);
Volatile Organics (VOC), including xylenes and ethylbenzene;
carcinogenic Polynuclear Aromatic Hydrocarbons (CPAH);
Non-Carcinogenic Polynuclear Aromatic Hydrocarbons (ncpah);
POly-chlorinated Biphenols (PCBs);
Dioxins/Furans.
2.
3.
4.
5.
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ROD DECISION SUMHARY
Salem Acres
Page 10
,
The significant findings of the RI are summarized below:
A.
Soil
1.
DA-1 Con~amina~ion
This is a 2.3 acre disposal area with an estimated 11,700 cu/yds
of hazardous soil and sludge in at least five identifiable
lagoons (figure 4~. Sludge in these lagoons has an average depth
of 7.5 feet and l~es on the bedrock. The number and boundaries
of lagoons within DA-1 has changed during the active life of Site
disposal. Table 1 provides a summary of the data at the DA-1
lagoons. The sludge contaminants occurring within DA-1 lagoons
appear to be randomly distributed - there are no apparent lateral
or vertical trends within any of the lagoons, nor is there any
indication of contaminant stratification or segregation by
compound or class. Sludge materials throughout the five lagoons
in DA-1 vary considerably in terms of observable physical
properties (e.g., color, texture), and chemical constituents. A
double layer HOPE liner presently caps these lagoons and a fence
surrounds each DA area as a result of the ERA action taken by EPA
in 1987.
The results of analyses obtained during the RI indicate that the
sludge from the DA-1 lagoons contains petroleum hydrocarbons,
semi-volatile, volatile substances, PCBs, and metals. Among the
approximately twenty DA-1 sludge samples obtained, the
concentration of total VOCs averaged 654 ppm (mg/kg), with a
maximum value of 1,170 ppm. This is largely due to the presence
of xylenes, highly ignitable compounds. The wastes in the five
lagoons are classified as RCRA ignitable under 40 CFR 261.21.
Semi-volatile organic compounds (SVOCs) detected in DA-1 consist
almost entirely of non-carcinogenic polynuclear aromatic
hydrocarbons (ncPAH). The average and maximum concentrations of
ncPAHs in DA-1 were 1,320 ppm and 3,600 ppm, respectively. The
specific ncPAH compounds which were detected most frequently were
naphthalene and 2-methylnaphthalene. CPAHs were not found in DA-
1 lagoons and this is possibly due to the high detection limits.
However, the presence of CPAH in DA-1 at concentrations lower
than the detection limits cannot be ruled out.
PCBs (Aroclor 1254) were detected in 2 of 19 sludge samples from
DA-1, in the low ppm range; the highest concentration of these
samples (from Lagoon 1B) was 6.4 ppm. Dioxins were found in all
five lagoons. The average concentration of dioxin was 4 ppb
while the maximum was 8.4 ppb. The dioxin.found in the lagoons
has been treated as the toxic form of 2,3,7,8-TCDD to be as
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ROD DECISION SttMHARy
Salem Acres
paqe 11
Chromium is found in all five lagoons .at concentrations within
the range of 329 ppm to 1,780 ppm. Of 20 samples in DA-1, there
are a total of 5 values above 900 ppm. The presence of this
metal is indicative of the tannery wastes that were included in
the sludges brought to the Site by SESD. No other metals are
detected above Soil Cleanup Levels although arsenic and lead
appear to be elevated (above non-contaminated areas sampled on
the Site) and are detected at maximum values of 30 ppm and 236
ppm respectively.
2.
DA-2 Contamination
This 2.3 acre disposal area is located 20 feet east of DA-1 and
has three identifiable lagoons that were used for the disposal of
liquid and semi-solid sludges. The lagoons, which contain an
estimated 9,600 cubic yards of sludge, have an average depth of
6.5 feet. Table 2 provides a summary of the data at DA-2. As in
DA-1, the lagoons in DA-2 are unlined and the sludge lies on top
of bedrock. In general, the waste characteristics of DA-2 are
similar to those of DA-1. There appears to be no clear spatial
or vertical trends to the contamination within individual
lagoons, nor is there any clearly definable differences among the
three lagoons.
Similarities between DA-1 and DA-2 include samples with
occasional high total VOC concentrations (maximum of 1,090 ppm) ,
widespread occurrence and high concentration of ncPAHs,
occasional PCBs below 6.0 ppm and dioxin at values above 1.0 ppb.
There is also widespread occurrence and high concentration of
total chromium, and a high organic content and associated
ignitability of the waste. The three lagoons at DA-2 were capped
individually with a double HDPE liner and fenced during the 1987
ERA. The chemical nature of the DA-2 waste is summarized below:
VOCs in the DA-2 lagoons have .occasional high concentrations up
to 1,090 ppm and the majority of the VOC is due to the highly
ignitable compound xylene. The presence of xylene and additional
presence of other iqnitable organic compounds (oil. and greases),
as in DA-1, result in a waste that is classified as RCRA
ignitable (40 CFR 261.21). The majority of semi-VOcs in DA-2
lagoons are made up mostly ncPAH compounds which are similar in
nature to DA-1 compounds. In DA-2, however, CPAH were detected
in two samples with a maximum concentration of 110 ppm. These
compounds were not detected in DA-1, but because of the high
detection levels in samples at DA-1 and because of the other
similarities in chemical compounds between DA-1 and DA-2, the
presence of CPAH at DA-1 is suspected at concentrations in the 10
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ROD DECISION SUHKARY
Salem Acres
paqe 12
PCB's are found in the majority of samples with a maximum
concentration of 5.5 ppb. Dioxins are also present throughout
the DA-2 lagoons. The maximum concentration of dioxins is 2.1
ppb. As in DA-l, the dioxin is treated as the most toxic species
to be as conservative as possible in the analysis of Site risk.
Chromium (Cr) is
concentration of
not found in any
maximum value of
found throughout the DA-2 lagoons with a maximum
3,440 ppm. Arsenic (As) and beryllium (Be) were
of the samples, while lead (Pb) was found at a
269 ppm.
, 3.
soil Areas
Five separate areas at the Site, located adjacent to or near the
sludge disposal areas DA-l and DA-2, have been identified as
locations where past on-site waste disposal activities have
resulted in soil contamination. The main cac in the SL soil
areas are the CPAHs and elevated levels of metals. The table
below summarizes the data and qives maximum values on the soil
areas (see also Tables 3 through 7).
DATA ON SOILS FROM AREAS SL-l THROUGH SL-S
AREA CPU PCB CR PI:) Be
~TS ARE MG/Xa-Max~um Concentrations
SL-1 5.17* nd 18 152 0.6*
SL-2 6.7* nd 20 327 0.8*
SL-3 10* .3 1,870* 160 1.3*
SL-4 41* nd 5,210* 3,220* 4.7*
SL-5 3,800* nd 1,850* 3,240* 1.3*
nd - nODe det:ermined
* exceeds Soil Cleanup Levels (see Sect:ioD x.A.1
The areas desiqnated SL-1 through SL-16 are discussed below:
(a) SL-1 and SL-2
Historical aerial photoqraphyindicates that waste disposal pits
were not built at these locations and suggests that contamination
is the result of past soil/sludge migration from DA-1 and DA-2
via surface drainage. Carcinogenic PAHs were detected in these
areas with an average of 2.2 ppm and a maximum of 6.7 ppm. The
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ROD DECISION SUKKARY
Salem Acres
Page 13
,
at concentrations ranging from 0.18 ppm to 0.80 ppm. Lead is
found at a maximum concentration of 327 ppm and although below
the Cleanup Levels, is a concern. This level is considered
"elevated" above the backqround and may mean that lead levels
above the Cleanup Level could be present. Tables 3 and 4
summarize the data on SL-1 and SL-2.
(~)
SL-3
Relative to SL-1 and SL-2, high levels of contamination were
encountered at the SL-3 area. These samples exhibited the
physical characteristics and many of the chemical properties
the sludge within DA-1 and DA-2. These similarities include
presence of carcinogenic and non-carcinogenic PAHs, PCBs and
levels of chromium (Tables 3 through 7). Historical aerial
photoqraphs suggest that the DA-2 lagoon once extended into the
SL-3 area and that the material of SL-3 is actually lagoon
sludge. CPAH are found at levels up to 10.0 ppm and chromium is
found at a maximum of 1,870 ppm. Further sampling in areas SL-1,
SL-2, and SL-3 will be required during the design phase in order
to delineate the extent of contamination. Table 5 summarizes the
data on SL-3. .
of
the
high
(c)
SL-4 - Ply Ash Pile
This area is commonly referred to as the fly ash pile, an
apparent reference to the former disposal of fly ash at this
location. The fly ash pile is next to the old landfill and is
located about 300 feet north of the Barcelona Avenue
neighborhood. The total quantity of wastes in this 0.6 acre fly
ash pile is estimated to be 9,600 cubic yards. Although the
dominant chemical contaminants within this area are metals,
(including arsenic, 124 ppm maximum; and chromium, 5,210 ppm
maximum) there are other contaminants including CPAHs which occur
at a maximum value of 41 ppm. Table 6 summarizes the data on
SL-4.
(4)
SL-S - Old Landfill
This area is commonly referred to as the "old landfill" and it
contains metal, wood, glass, brick, and miscellaneous debris in
addition to contaminated soil. There is an estimated 3,600 cubic
yards of general refuse disposed of in an area of 0.5 acres in
SL-5. Although the primary physical form of contamination is
qeneral refuse, this area contains the hiqhest levels of CPAH
contamination found on the Site. CPAHs are found at
concentrations that average 540 ppm with a maximum value of 3,800
ppm. The metals chromium, beryllium and lead are also elevated.
The averaqe concentration of chromium is 538 ppm and the maximum
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ROD DECISION SUKKARY
Salem Acres
Page 14
1.0 ppm with a maximum value of 1.3 ppm. Lead is found at an
average of 1,140 ppm with a maximum value of 3,240,ppm. Table 7
summarizes the data on SL-5.
(e) Debris Piles SL-6 to SL-16
There are a series of 11 debris piles (SL-6 to SL-16) scattered
north of DA-1 and DA-2 that contain a variety of trash and
household waste in addition to demolition debris containing
gravel, wood and masonry. The nearest of these piles is 200 feet
from the DA areas while other piles SL-12 and 13 are 1/4 mile
away. These piles were sampled for hazardous waste constituents
including metals, PARs and semi-volatile analytes, volatile
compounds and PCBs. The metals, arsenic, chromium, and lead are
detected at concentrations well below the Soil Cleanup Levels.
Arsenic is present at average and maximum concentrations of 3.3
and 5.4 ppm, respectively. Chromium is present at average and
maximum concentrations of 25 and 108 ppm respectively, while lead
is found at average and maximum concentrations of 42 and 97 ppm
respectively. Some low level PCB contamination (below 8.0 ppm,
but above Soil Cleanup Levels), is detected at SL-6, SL-12 and
SL-13. The debris piles do not appear to be related to the
sludge disposal areas and soil areas and may constitute a
separate disposal scenario. However, the debris piles at SL-6,
SL-12 ang SL-13 contain soil contamination above the Soil Cleanup
Levels and are included in the Site remedy.
B.
Ground Water
Twelve monitoring wells were installed at the Site in both
bedrock and the overburden during the RI. Quarterly sampling and
analyses were performed at these locations. Samples were
analyzed for metals, PCB's, volatile and semi-volatile organics
,and pesticides. Analyses of samples collected from these wells
indicate that the groundwater on site contains only trace levels
of VOCs, SVOCs, and some metals. The most significant
Contaminants of Concern (COC) found in the groundwater include
the metals arsenic, antimony and manganese and the VOC benzene
and 1,'4 dichlorobenzene. All groundwater levels for these
compounds, except antimony, are below the Maximum contaminant
Levels (MCLs) , which are the EPA standards established for
maintaining safe drinking water quality. For antimony, three
samples out of a total of twenty-seven samples, exceeded the MCL.
Table 9 summarizes the data on groundwater.
.
Three off-site residential wells were sampled for both organics
and metals. With the exception of a trace concentration of
chloroform in one drinking water well (not attributable to site
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ROD DECISION SUHMARY
Salem. Acres
Page 15
during the RI did not contain any levels of organic or metal
contamination above trace levels.
c. Wetlands
1. Surface Water
There are 7 distinct wetland areas on the site that range in size
from 1 to 3 acres (WA-1 through WA-7). Surface water was
collected at 16 locations on two separate sampling events at all
wetl~nd areas and analyzed for VOC, SVOC, pesticides, PCBs, and
metals. Of a total of 32 samples collected from the 16
locations, only one sample contained organic contaminants at
dete~table levels. In this sample xylene is found at a
conc~ntration of 3.3 ppb, and 1,2-dichloroethane is recorded at a
conc~ntration of 1.7 ppb. Table 10 summarizes the data on
surf .~ce water.
2. Sediments
Sedi~ent samples were collected at 42 locations in Wetlands WA-1
to WA-7. Samples were analyzed for pesticides, SVOC, PCB,. and
metals. Analyses of these samples revealed generally trace
levels of several metals and semi-volatile organic compounds. No
pesticides or PCBs were detected in any of these sediment
samples. Among the semi-volatile compounds, most of those
detected were polynuclear aromatic hydrocarbons (PAHs) with an
average total concentration of 6.1 ppm. Maximum CPAH in the
sedi~ents are recorded. at 4.2 ppm. Table 11 summarizes the data
on sediments.
3. Wetlands Biota
The WA-1 to WA-7 wetlands at the Site (Figure 2) were evaluated
to determine the impact of site contaminants upon wetland
ecology. As par-t of this evaluation, the wetlands were
classified and mapped using a combination of stereo aerial
photograph analysis and field validation. Vegetation types were
identified and evaluated and a bird survey was performed. Fish
were captured and investigated (both visually and by laboratory
tissue analysis) and benthic macro invertebrates were sampled and
evaluated. Acute bioassay tests were performed on several test
organisms using sediment and surface water taken from the
adjacent Site wetlands WA-1 and WA-4. The results of this
wetlands ecological assessment may be briefly summarized as
follows:
.
There were no signs of chemically induced stress on
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ROD DECISION SUKMARY
Salem Acres
Page 16
:II
.
There was no evidence of contaminant-related impacts to
the bird population.
.
There was no evidence of lesions or tumors in captured
fish.
.
Benthic macro invertebrate samples and resulting
indices were indicative of poor water quality.
poor water quality is attributed to the shallow
senescent aspect of the wetlands.
species
The
and
'.
All bioassay samples were non-toxic to daphnids and
fathead minnows, with 100 percent survival after 48
hours of exposure. All Microtox test results were
negative.
Based upon the above and the fact that wetland sampling of
sediments and surface water through out WA-1 to WA-7 show only
trace level contamination, contamination at the site has not
migrated into contiguous wetlands at concentrations that affect
the wetlands ecology or that have a human health significance.
J). Air
Air samplinq was conducted at six locations on and off the Site
to determine the health risk to the public. Sampling occurred
twice, during the spring and late summer of 1989, in order to
assess contamination at times when dust is least and most likely
to be generated. The samples were analyzed for PCBs and metals.
PCBs were not detected during either sampling event and only a
few samples contained. trace levels of metals. Additionally, air
sampling by EPA for volatile organics using portable equipment at
various locations throughout the Site during June 1990 failed to
demonstrate the presence of volatile organic air contamination.
v:t.
SUHHARY OF SITE RISKS
URS Consultants (consultants to SESD) together with input and
oversight from EPA conducted a Risk Assessment (RA) to estimate
the probability and magnitude of potential adverse human health
and environmental effects from exposure to contaminants
associated with the Site. The public health risk assessment
followed a four step process: 1) contaminant identification,
which identified those hazardous substances which, given the
specifics of the Site were of significant concern; 2) exposure
assessment, which identified actual or potential 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
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ROD DECISION SUMMARY
Salem Acres
Page 17
and 4) risk characterization, which integrated the three earlier
steps to summarize the potential and actual risks posed by
hazardous substances at the Site, including carcinogenic and non-
carcinogenic risks. The results of the RA for the Site are
discussed below.
Three semi-volatile organic compounds: PAHs, PCBs and
dioxins/furans; and four metals: lead, chromium, arsenic and
beryllium are identified in the RA as COC in soils/sludge,
surface water, sediment and fish and were selected for evaluation
in the RA. In addition, two pesticides (DDD and DDE) were
evaluated in the fish ingestion pathway and two volatile
compounds (1,4 dichlorobenzene and benzene) and two metals
(antimony and manganese) were evaluated for the groundwater
ingestion pathway. These cae represent potential Site-related
hazards based on toxicity, concentration, frequency of detection,
and mobility and persistence in the environment. A summary of
the health effects of each of the COC can be found in Volume I of
the RA, General Toxicity Profiles.
Potential human health effects associated with exposure to the
COC in the RA are estimated quantitatively through the
development of several hypothetical exposure pathways. These
pathways ref~ect the potential for exposure to hazardous
substances based on the present uses, potential future uses, and
location of the Site. Present risk is based upon occasional site
use by trespassers. Future potential risk at the Site is based
upon a residential use scenario. The site is zoned for
residential housing and the owners have proposed to develop the
Site for single family dwellings. The following is a brief
summary of the exposure pathways evaluated. A more thorough
description can be found in Volume I, section IV of the RA. It
is significant to note that the risk associated with the current
use by trespassers is much less than the future potential risk
associated with residential development and is due to the
frequency of exposure.
Potential human health effects associated with exposure to the
cae in the RA are estimated quantitatively through the
development of the following hypothetical exposure pathways:
- Ingestion of groundwater
- Ingestion of soils/sludge
- Dermal contact with soils/sludge
- Ingestion of fish
- Ingestion of surface water
- Dermal contact with surface water
- Ingestion of sediment
- Dermal contact with sediment
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A. Exposure Pathways
1. GroW'ldwater
currently groundwater is not being used. Therefore, the RA
includes only future use of the groundwater as a drinking water
supply and as a potential exposure pathway. A daily frequency
and 70-year duration (lifetime) of consuming 2 liters of water
were assumed to assess risks from exposure to carcinogenic and
non-carcinogenic compounds. Exposure to children (age 2) is also
assessed in the RA for non-carcinogens based on a daily frequency
and one-year duration.
2. soils/Sludge
The RA includes both present and future use exposures evaluations
for soils and sludge. The present use exposure scenario was
based on the assumption that nearby residents may use the Site
for recreational activities and may be exposed as a result of
direct contact with soil/sludge and subsequent incidental
ingestion and dermal absorption. Exposure may also occur via
inhalation of airborne particulates from the contaminated surface
soils. The RA is based on the assumptions that recreational use
may occur at a frequency of 2 days per week for 40 weeks per year
over a 70 year lifetime for carcinogenic and non-carcinogenic
compounds. Exposure to children aged 6 to 16 was evaluated for
non-carcinogenic compounds based on the same frequency and a one-
year exposure duration.
The future exposure scenario was based on residential use of the
Site. A frequency of 100 days per year over a lifetime was
assumed for assessing all compounds. A frequency of 150 days per
year and duration of one year was assumed to assess childhood
(age 2) exposure to non-carcinogenic compounds. Exposure via
ingestion, dermal contact and inhalation were evaluated.
3. Pish Ingestion
Both present and future potential fish ingestion exposures were
evaluated. Lifetime exposure was evaluated for carcinogenic and
non-carcinogenic compounds assuming that 10% of an average daily
fish consumption is from fish caught in the Site wetlands. A
childhood exposure for children aged 6 to 16 was evaluated for
non-carcinogenic compounds. The future exposure was based on the
same assumptions with the exception of increasing the percent of
the average daily fish consumption from the Site from 10% to 20%.
This exposure scenarios considered to be very conservative
because the fish in wetlands WA-l and WA-4 are small, under 5
inches in length, and thus are unlikely to be used as a constant
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ROD DECISION S~~Y
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4. Surface Water
Both present and future potential exposures via incidental
ingestion of surface water while swimming were evaluated. The
present Site use was assumed to be recreational. Risks from
exposure to carcinogenic and non-carcinogenic compounds for the
present use exposure scenario were based on a swimming frequency
of 40 days per year and a duration of 70 years (lifetime). Risks
from exposure to non-carcinogenic compounds were also evaluated
for children (aged 6 to 16) based on the same frequency and a
duration of one year. The future site use was assumed to be
residential. The exposure assumptions were the same as the
present use scenario with the exception of increasing the
frequency from 40 days to 50 days per year.
s. Sediment
Both present and future potential exposures via ingestion of and
dermal contact with sediment were evaluated. The frequency and
duration of exposure to sediment is the same as for the surface
water scenario. For each pathway evaluated, an average and a
reasonable maximum exposure estimate was generated corresponding
to exposure to the average and the maximum concentration detected
in that particular medium.
B. Summary of Baseline Risk Assessment
The excess lifetime cancer risks are determined for each exposure
pathway by multiplying-the exposure level with the chemical
specific cancer potency factor. EPA developed cancer potency
factors 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 unlikelv
to be areater than the risk Dredicted. 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 qreater than a
one in a million chance of developing cancer over 70 years as a
result of Site-related exposure to the compound at the stated
concentration. current EPA practice considers carcinogenic risks
to be additive when assessing exposure to a mixture of hazardous
substances.
EPA also calculated the hazard index for each pathway as a
measure of the potential for non-carcinogenic health effects.
The hazard index is calculated by dividing the exposure level by
the reference dose (RfD) or other suitable benchmark for non-
carcinogenic health effects. Reference doses have been developed
by EPA to protect sensitive individuals over the course of a
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ROD DECISION SUMMARY
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Page 20
to be without an appreciable risk of an adverse health effect.
RfDs are derived from epidemiological or animal studies and
incorporate uncertainty factors to help ensure that adverse
health effects will not occur. The hazard index is often
expressed as a single value (e.g. 0.3) indicating the ratio of
the stated exposure as defined to the reference dose value (in
this example, the exposure as characterized is approximately one
third of an acceptable exposure level for the given compound).
~he hazard index is only considered additive for compounds that
have the same or similar toxic endpoints (for example: the hazard
index for a compound known to produce liver damage should not be
added to a second whose toxic endpoint is kidney damage)".
Table 8 depicts the present and future carcinogenic and non-
carcinogenic risk summary for the cae in soils and sludge. The
Summary for groundwater, surface water, sediment, and fish
consumption data can be found in the Health Risk Assessment
Report dated May 29, 1992. Each medium is evaluated to reflect
present and potential future risks corresponding to the average
and the reasonable maximum exposure scenarios.
1. Groundwater
The average and reasonable worst case risks associated with the
future potential ingestion of drinking-water are 8.5 x 10-5 and
2.6 x 10-4, respectively. Arsenic, antimony and manganese
comprise the majority of the risk. The average and maximum
Hazard Indices associated with antimony are 4.6 and 12, with
manganese are 0.5 and 1.1 and with arsenic are 0.5 and 1.6
respectively. Antimony and manganese may cause damage to blood
and the central nervous system, respectively.
2. Soils/Sludge
Exposure to soi1s and sludge in Lagoons DA-1, DA-2, and areas
SL-3, "SL-4, and SL-5 under the future residential use scenario
are associated with the greatest significant risk to human health
at this site. Risks associated with future use'are summarized
below.
a. Lagoons at DA-1
The average and reasonable worst case risks are 8.7 x 10-4
and 1.7 x 10-3. Arsenic and dioxin/furans comprised the
majority of the risk. The average and maximum Hazard
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ROD DECISION SnMKARY
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paqe 21
~. Laqoonsat DA-2
The average and reasonable worst case risks are 2.2 x 10-3
and 4.9 x 10-3. carcinogenic PAHs and dioxin/furans
comprised the majority of the risk. The average and maximum
Hazard Quotients associated with chromium are 1.7 and 5.6.
c. SL-1
The average and reasonable worst case risks are 1.55 x 10-6
and 1.72 x 10-6. carcinogenic PAHs comprise the majority of
the risk. The Hazard Quotient is below one.
d. SL-2
The average and reasonable worst case risks are 1.5 X10-5
and 3.2 x 10-5. Carcinogenic PAHs comprise the majority of
the risk. The Hazard Quotient is below one.
e. SL-3
The average and reasonable worst case risks are 4.7 x 10-4
and 7.~ x 10-5. (The average risk is higher than the
reasonable worst case risk because an artificial value of
one half the detection level for samples with "non-detects"
was used in calculating the average concentration, and in
some cases, the detection limits were very hiqh.) CPAHs
comprise the majority of the risk. The averaqe and maximum
Hazard Quotients are 0.96 and 3.1 for chromium.
f. SL';'4
The average and reasonable worst case risks are 6.6 x 10-5
and 3.3 x 10-4. CPAHs and arsenic comprise the majority of
the risk. The average and maximum Hazard Quotients are 2.2
and 8.5 for chromium.
q. SL-S
The averaqe and
and 2.1 x 10-3.
The average and
for chromium.
reasonable worst case risks are 3.0 x 10-3
CPAHs comprise the majority of the risk.
maximum Hazard Quotients are 0.88 and 3.0
h. DeJ:»ris Piles
Most of the debris piles contained levels of contaminants
which do not exceed the Soil Cleanup Levels. However, three
areas, SL-6, SL-12 , and SL-13 contain PCBs that are above
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ROD DECISION SUMHARY
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Page 22
3. ~ish Ingestion
The average and worst case risks associated with potential
exposure via fish ingestion are 1.5 x 10-5 and 2.3 x 10-5.
4. Surface Water
Based upon the available data, car~inogenic compounds are not
detected in surface water and the Hazard Quotient for exposure to
surface water is insignificant and less than 1.
s. Sediment
The avera~e and reasonable worst case risks are 4.6 x 10-6 and
1.2 x 10-. CPAHs comprise the majority of the risk.
c.
Remedial ~plications
The baseline health risks calculated in this assessment have
several important implications concerning the need for, and
extent of, remedial action at the site. These may be briefly
summarized as follows:
Remediation of the wetlands sediments, surface waters, and
groundwater at the Site is not warranted since risk associated
with these areas (with one exception) is within the acceptable
range of 1.0 x 10 -4 to 1.0 x 10 -6. The exception is arsenic in
groundwater for the 'maximum values only; the calculated maximum
risk for arsenic is 2.6 x 10-4. The maximum Site groundwater
concentration for arsenic was recorded at 4.9 ppb which is well
below the drinking water MCL of 50.0 ppb. Moreover, the future
remediation of the Site, should reduce risk from arsenic to
within the accepted risk range of 1.0 x 10-4. Thus the major
risks posed by the COC are from contact/ingestion with Site soils
and sludges from the following waste areas on the Site:
1. SL-5 (old landfill)
2. SL-4 (ash pile)
3. DA-2 (sludge lagoons)
4. DA-1 (sludge lagoons)
5. SL-3 (suspected sludge
6. SL-6, SL-12, and SL-13
.r
lagoon)
(debris piles)
At a minimum, remediation of these soil and sludge waste areas
will be required because they are outside the accepted risk
range. The soil areas at SL-1 and SL-2 have a slightly elevated
risk. These areas will have to be further delineated in a Soil
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ROD DECISION SUHKARY
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Any part of the Site confi~ed to contain contaminants above the
Soil Cleanup Levels, shall be included in the remedy.
In addition, there are two areas in wetland WA-l, which is west
and adjacent to DA-l, that show slightly elevated levels of
contaminants when compared to acceptable levels for "Aquatic
Water Quality Criteria". These areas will be further evaluated
in the design phase to confirm the area of contamination. It is
not anticipated that these areas will require remediation.
However, the presence of contaminants in sediments that result in
a health risk greater than 1.0 x 10-4 or excessive ecological
threat, to be determined by EPA in consultation with other
Federal and State Agencies, will trigger these sediments for
inclusion in the Remedy.
In summary, EPA has determined that actual or threatened releases
of hazardous substances from this Site, if not addressed by
implementing the response action selected in this ROD, may
present an imminent and substantial endangerment to public
health, welfare, or the environment. The RA identified the waste
areas DA-l, DA-2, SL-3, SL-4, SL-5, SL-6, SL-12, and SL-13 as
posing health risks exceeding EPA risK management criteria.
Therefore, ~ese waste areas have been targeted as the focus of
the remedial actions in this ROD. The areal extent of
remediation at these areas will be based upon further waste
delineation done during the design study. All areas of the site
that are found to contain contaminants above the Soil CleanuD
Levels shall be included in the remedy.
VII.
DEVELOPMEN'l' AND SCREENING OF ALTERNATIVES
A.
statutory Requirements/Response Objectives
Under its legal authorities, EPA's primary responsibility at
Superfund Sites is to undertake remedial actions that are
protective of human health and the environment. In addition,
Section 121 of CERCLA establishes several other/statutory
requirements and preferences, includ~ng: a requirement that
EPA's remedial action, when complete, must comply with all
federal and more stringent state environmental standards,
requirements, criteria or limitations, unless a waiver is
invoked; a requirement that EPA select a remedial action that is
cost-effective and that utilizes permanent solutions and
alternative treatment technologies or resource recovery
technologies to the maximum extent practicable; and a preference.
for remedies in which treatment which permanently and
significantly reduces the volume, toxicity or mobility of the
hazardous substances is a principal element over remedies not
involving such treatment. Response alternatives were developed
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ROD DECZSZON SUHHARY
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Page 24
Based on preliminary information relating to types of
contaminants, environmental media of concern, and potential
exposure pathways, remedial ac~ion objectives were developed to
aid in the development and scr~ening of alternatives. These
remedial action objectives were! developed to mitigate existing
and future potential threats to public health and the
environment. These response o:,jectives were:
1. To prevent the ingestion of and direct contact with soils and
sludges having a cancer ris~ greater than 1 x 10 -4 and/or
precluding contact with non-carcinogenic compounds with a
toxic risk above a reference dose of 1;
2. To prevent ingestion of water with a cancer risk greater than
1 x 10-4 or ingestion of water with a reference dose greater
than 1;
3. To prevent the migration of contaminants from the Site that
would result in contaminaticn of adjacent soils and wetland
sediments with concentratio~s above Soil Cleanup Levels listed
in Section X.A; and
4. To preclude the inhalation cf carcinogenic and toxic compounds
from contaminated dusts on the Site.
B. _Technology and Altern~tive Development and screening
CERCLA and the NCP set forth tr.e process by which remedial
actions are evaluated and selected. In accordance with these
requirements, a range of alternatives were developed for the
Site.
with respect to source control, the Feasibility Study (FS)
developed a range of alternatives in which treatment that reduces
the toxicity, volume and mobility of the hazardous substances is
a principal element. This range included an alternative for off-
site disposal that removes the hazardous substances to the .
maximum extent feasible, eliminating or minimizing to the degree
possible the need for long term management. This range also
included alternatives that treat the principal threats posed by
the Site but vary in the degree of treatment employed and the
quantities and characteristics of the treatment residuals and
untreated waste that must be managed; alternative(s) that involve
little or no treatment but provide protection through engineering
or Institutional Controls; and a No-Action Alternative.
This alternative screening is based on the fact that contaminated
soils and sludges are the only threats to public health and the
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ROD DECISION SUMHARY
Salem Acres
Page 25
included in the screening since contamination in these areas is
not a threat to public health or the environment.
As described in Chapter 2 of the Feasibility Study (FS), th~ FS
identified, assessed and screened technologies for source control
based on implementability, effectiveness, and cost. Chapter 3 of
the FS presented the remedial alternatives developed by combining
~~e 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 4 of the FS.
In summary, of the 15 source control remedial alternatives
sc~eened in Chapter 3 of the FS, nine alternatives were retained
for detailed analysis. The nine alternatives that were retained
th~ough the screening process, as well as those that were
eliminated from further consideration are listed below in Section
VIZI.A.
VI!I.
DESCRIP~ION OP ALTERN1TIVES
This Section provides a narrativ~ summary of each alternative
ev~luated. A detailed narrative assessment of each alternative
ca~ be found in Chapter IV table 4-12 of the Feasibility study.
A.
Source Control (SC) Alternatives Analyzed
The below list of source control alternatives includes those that
were eliminated from fUrther consideration (SC-S TO SC-13) as
well as those that were analyzed for detailed evaluation (SC-l
through SC-7B):
SC-l.
SC-2.
SC-3.
SC-4.
SC-S.
SC-6.
SC-7.
SC-7A.
SC-7B.
SC-S.
SC-9.
SC-10.
SC-ll.
SC-12.
SC-13.
No Action
RCRA Subtitle C Capping
Incineration with Stabilization
Thermal Desorption/Dechlorination/Stabilization
Solvent Extraction/Stabilization
In-Situ Vitrification
Immobilization
Immobilization with Off-Site Disposal
Sludge Fixation with Off-Site Disposal
Subsurface Isolation
In-Situ Steam/Hot Air Stripping
Soil Washing/Soil Flushing
In-Situ Vacuum Extraction
Biological Treatment
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ROD DECISION SUMMARY
salel. Acres
Page 26
1.
Alternative SC-l:
No Action
,
Al~ernative SC-l was evaluated in detail in the FS to serve as a
base~ine for comparison with the other remedial alternatives
under consideration. Under this Alternative, no action would be
taker except for long-term monitoring of groundwater. No
treatment or containment of contaminated media would be conducted
and ro effort, other than current fencing, would be made to
restrict Site access. Although DA-l and DA-2 are capped and
fenced, exposure to contaminated soil around these sludge lagoons
and at areas SL-3, SL-4, SL-S, SL-6, SL-12, and SL-13 would
continue to cause potential health risk to recreational Site
use~~ under existing land use conditions, and to on-Site
resicents under possible future land use conditions. In
addition, although the present impact of the untreated and
uncor.tained soil contaminants does not warrant remediation of the
grour.dwater and wetland environment, the potential for release of
contaminants would remain.
Beca~se contaminants would remain in place, the area would be
monitored periodically, to determine contaminant concentrations
over cime and to trace the extent of possible contaminant
migracion. After five years, Site conditions would be evaluated
to decermine whether cleanup activities would be required.
Quartarly Site inspections and monitoring would be conducted for
the firs~ two years and semi-annually for 28 years or until
compliance is achieved with all ARARs. Monitoring data would be
evalu~ted every year. .
ESTIM\TED TIME FOR DESIGN AND CONSTRUCTION: N/A
ESTIM\TED TIME FOR OPERATION: 30 YEARS
ESTIM\TED CAPITAL COST: NONE
ESTIM\TED 0 & M (Present Worth): $330,000
ESTI~\TED TOTAL COST (Present Worth): $330,000
2.
Alternative SC-2: RCRA, Subtitle C, Capping
This Alternative involves the placement of a RCRA Subtitle C Cap
(RCRA Cap/Capping) over the lagoons at DA-l and DA-2, at soil
areas SL-3, SL-4, SL-S, SL-6, SL-12, and SL-13 and those areas
throu'Jhout the site that are determined to exceed the Soil
Clean'.lp Levels. All soils/sludges that exceed the Soil Cleanup
Levels established in Section X, shall be included in the remedy.
The f.)llowing components of the Cap are listed below from the top
of t~.! Cap to the bottom:
-
-. .
A top soil layer of at least 24 inches thick planted with
grass or other suitable vegetation that will not
interfere with the underlying Cap. This layer shall
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ROD DECISION SUMMARY
Salem Acres
Paqe 27
~
soil. A flexible geomembrane will be placed between this
layer and the next drainage layer.
2. A drainage layer of 12 inches to provide for drainage
away from the underlying impermeable layers. The
permeability (K) for this layer shall be 10-2 or greater.
A geotextile of suitable drainage characteristics may
replace this layer.
3. An impermeable flexible liner will lie directly beneath
the drainage layer.
4. A 24 to 36 inch layer of compacted clay with a K value of
10-6 will underlie the flexible liner.
5. A layer of soil between the clay layer and the area of
soil or sludge to be capped to provide a smooth layer
for the clay cover as well as a layer for gas collection.
The thickness and K value of this layer will be
determined during design studies.
6. A gas venting system will be provided to the atmosphere.
This RCRA Subtitle C Cap would be designed and constructed in .
accordance with the Federal Resource Conservation and Recovery
Act Subtitle "C" guidelines in effect at the time of design. Any
future development in the areas of the RCRA Caps would be
prohibited through Institutional Controls that would include deed
restrictions. Drainage controls would be implemented to preclude
run-on and potential erosion impacts of rain and snow melt on the
RCRA Cap. Finally, a ~oundwater monitoring program would be
developed to allow periodic evaluation of the RCRA Cap's
effectiveness in preventing the migration of soil contaminants to
groundwater. The combination of a RCRA Cap, security fence and
Institutional Controls would control all risks associated with
human exposure to contaminated soil,. including those derived from
ingestion, dermal contact and inhalation of airborne
particulates. However, the contaminants would remain on-site and
untreated under the RCRA Cap. As a result, thete would be a
potential residual risk if the RCRA Subtitle C Cap were to fail
or, as a result of fence breaching or Institutional Control
failure, be disturbed by future on-site activities. This remedy
would call for operation and maintenance requirements and
Institutional Controls to assure integrity of the RCRA Cap,
fence, and monitoring well system.
In addition, if groundwater monitoring shows a risk greater than
1 x 10 -4, a Site Assessment will be initiated by the EPA. This
Assessment will entail a review of all available groundwater and
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ROD DECISION SUMMARY
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Page 28
treatment and/or controls are necessary. These additional
require~ents may include, but are not limited to, source related
controls, migration of contamination controls, Institutional
Controls, and continued or additional monitoring requirements.
The decision to institute additional Site actions shall be made
by the EPA Regional Administrator.
Although Alternative SC-2 is effective in controlling Site risk,
it is not a form of treatment and does not directly reduce the
toxicity, mobility or volume of the waste and thus, does not
provide for permanence. This Alternative calls for a continual
proqram of monitoring and inspection and is not as preferable as
a remedy that includes treatment to provide permanence. However,
this Alternative would be easily implementable and involves a
known technclogy that has been effectively employed at other
hazardous waste sites in New England.
Management Regulations (40 CFR 260 through 268), MADEP Air
Pollution Centrol regulations (3~0 CMR 6.00 and 7.00), OSHA
Safety and Health Standards (29 CFR ~9~0 and ~926) and the MADEP
Waste Regulations (3~0 CMR 30.00), RCRA (40 CFR 264 Subpart
D,F,G,K, and N) would apply. The federal and state air quality
regulations would additionally serve as applicable action-
specific ~~s for excavation activities when fugitive dust or
particulate matter is generated.
Both federal and state wetlands laws and regulations (Clean Water
Act (CWA) 33 use 40~ et seq. and ~344, 33 CFR 330, and MADEP 3~0
CMR ~O.OO) and the Wetlands Executive Order ~~990 would be
potentially applicable location-specific ARARs should
construction activities disturb any of the nearby wetlands. RCRA
standards for treatment and Land Ban requirements would not apply
since the material consolidation under this option would not be
considered r~oval from the original location during treatment.
Design considerations under RCRA (40 CFR 265.~~0-265.~20;
265.220-265.230; and 265.250-265.260; and 265.300-265.3~6) for
closure of lagoons, waste piles and landfills would be
applicable.
ESTIMATED
ESTIMATED
. ESTIMATED
ESTIMATED
ESTIMATED
TIME FOR DESIGN AND CONSTRUCTION: 20 months
TIME FOR OPERATION: 30 years
CAPITAL COST: $3,84~,000
o & M COST: $569,000
TOTAL COST (Present Worth): $4,4~0,000
3. Alternative SC-3: %ncineration/Stabilization
This Alternative would involve excavation and pretreatment of
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ROD DECISION SaMHARY
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Page 29
infrared, or fluidized bed}, and on-site burial of all
soils/sludges above the Soil Cleanup Levels. Pretreatment in
this overall process is necessary to remove large objects and to
screen, shred, and mix the remaining wastes to create a more
uniform-sized soil/waste mixture which could be more efficiently
incinerated and/or stabilized. Following pretreatment at a
. . . ,
m~n~um, 21,300 cu/yds of so~l from areas DA-1 and DA-2, and at a
minimum 3,000 cu/yds of soil from SL-3, SL-4, SL-5, SL-6, SL-12,
and SL-13 will be incinerated. An anticipated destruction
efficiency of 99.99 percent for organic compounds may be achieved
with incineration which would result in a permanent solution for
organics.
Because incineration does not treat metals, this Alternative
would be followed by immobilization (stabilization/
solidification) of a minimum of 24,300 cu/yds of incinerated
soils, together with an additional minimum of 12,300 cu/yds of
soil, contaminated primarily with metals from SL-3, SL-4, and
SL-5. The immobilization would utilize a cement based
stabilization process which would involve excavation of soils and
mixing in tanks followed by reburial of the solidified material
under a permeable cap. The immobilization process would add an
additional 20% to 40% to the volume of the stabilized material.
This process will effectively bind up the heavy metals in a
matrix that woul1 preclude leaching into groundwater.
Institutional Controls including deed restrictions on the use of
the capped area, fencing, and long term groundwater monitoring
would be requirej under this Alternative. .
Although inciner~tion involves widely-used and readily available
treatment technologies; there are some potential technical and
administrative p=oblems associated with its implementation. Some
of these proble~s deal with community opposition to incineration
and the possibility for volatilization of heavy metals and their
potential for release into the atmosphere. One particular
problem is the potential for conversion of chromium from
trivalent into a very toxic form of hexavalent chromium at
temperatures above 700°F. These potential technical issues could
be resolved through design/pilot study to contr~l for the
potential release of metals to the atmosphere.
Management Regulations (40 CFR 260 through 268), MADEP Air
Pollution Control regulations (310 CMR 6.00 and 7.00), OSHA
Safety and Health Standards (29 CFR 1910 and 1926) and the MADEP
Waste Regulations (310 CMR 30.00), RCRA (40 CFR 264 Subpart O)
would apply. Land Disposal Requirements under RCRA would also
apply. The federal and state air quality regulations would
additionally serve as applicable action-specific ARARs for
excavation activities when fugitive dust or particulate matter is
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ROD DECISION SUHHARY
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Page 30
Both federal and state wetlands laws and regulations (Clean Water
Act (CWA) 33 USC 401 et seq. and 1344, 33 CFR 330, and MADEP 310
CMR 10.00) and the Wetlands Executive Order 11990 would be
potentially applicable location specific ARARs should
construction and/or excavation activities disturb any of ~~e
nearby wetlands. RCRA standards for treatment would apply under
the Land Disposal Requirements since the material under this
option would be removed from the original location during
treatment.
ESTIMATED TIME FOR DESIGN AND CONSTRUCTION: 20 MONTHS
ESTIMATED TIME FOR OPERATION: 24 MONTHS
ESTIMATED CAPITAL COST: $30,502,000
ESTIMATED 0 & M Cost (Pre5ent Worth): $323,000
ESTIMATED TOTAL COST (Pre5ent"Worth): $30,825,000
~.
Al~erna~ive SC-4:
stabiliza~ioD:
'rherma1 Desorp~ioD/DechloriDa~ioD wi~h
This Alternative would in~olve pretreatment, thermal desorption,
dechlorination and on-sit~ burial of all soils/sludges above the
Soil Cleanup Levels. Pretreatment in this overall process is
necessary to remove large objects and to screen, shred, and mix
the remaining wastes to create a more uniform-sized soil/waste
mixture which could be more efficiently desorpted and/or
s~abiliz~d. FOllowing pretreatment, at a minimum, 21,300 cu/yds
of soil from areas DA-1 and DA-2, and, at a minimum, 3,000 cu/yds
of soil from SL-3, SL-4, SL-5, SL-6, SL-12, and SL-13 will be
thermally desorpted. In this process distillation of the various
contaminants would occur within a heated anaerobic environment of
between 7000 and 1,L50 of. Combustion is controlled and the
decomposition of halogenated hydrocarbons does not occur.
The distilled organics would contain PAH primarily and would be
concentrated and condensed to form a liquid stream of about 9,500
gallons. This liquid waste would be further treated on-site. A
variety of aqueous waste treatment processes are available for
this purpose; the final treatment selection would be based upon
required process treatability studies. This process also results
in the production of about 30 gallons of PCB and dioxin
containing waste that would be treated by dechlorination, which
is a chemical substitution process that renders the PCB/Dioxin
waste non-toxic. Treated effluent, depending upon its quality,
could be discharged either on-site or to the sanitary sewer
system. Concentrated organic, sludge would be disposed of off-
site, by incineration. An anticipated destruction efficiency of
99.99 percent for organic compounds may be achieved with this
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ROD DECISION SUMMARY
Salem Acres
paqe 31
Because thermal desorption does not treat metals, this
Alternative would be followed by immobilization (stabilization/
sOlidification) of a minimum of 24,300 cu/yds of previously
treated soils, together with an additional minimum of 12,300
cu/yds of soil, contaminated primarily with metals from SL-3, SL-
4, and SL-S. The immobilization would utilize a cement based
stabilization process which would involve excavation of soils and
mixing in tanks followed by reburial of the solidified material
under a permeable cap. The immobilization process would add an
additional 20% to 40% to the volume of the stabilized material.
This process will effectively bind up the heavy metals in a
matrix that would preclude leaching into groundwater.
Institutional Controls including deed restrictions on the use of
the capped area, fencing, and long-term ground water monitoring
would be required under this Alternative.
One potential problem with this Alternative is that some of the
more volatile metals may change state and become volatile at
temperatures above 700 of. These issues would require evaluation
in a design/pilot study, as in Alternative SC-3, to contre.l for
the potential release of metals to the atmosphere.
The regulations set forth by RCRA Subtitle C, and in 310 CMR
30.00, considered applicable action-specific ARARs, would be met,
including: incineration, secondary containment of residual
storage, tank inspections, temporary waste piles, contingency
planning and proper adherence to transportation requirements once
the concentrated organic waste is transported off-site for
incineration. Discharge effluent limitations established by
Massachusetts surface water discharge permit rules (314 CMR 3.00
et seg.) under the NPDES program (40 CFR 122 and 125) will be met
through engineering controls. Other applicable regulations which
will be met include state technical standards addressing the
operation of wastewater treatment facilities at hazardous waste
facilities (310 CMR 30.605). Any discharges to a POTW would
conform to state standards for discharge to POTWs (314 CMR 12.00)
under the CWA.
ESTIMATED TIME FOR DESIGN AND CONSTRUCTION: 20 MONTHS
ESTIMATED TIME FOR OPERATION: 24 MONTHS I
ESTIMATED CAPITAL COST: $26,442,000
ESTIMATED 0 & M COST (Present Worth): $323,000
ESTIMATED TOTAL COST (Present Worth): $26,765,000
s.
Alternative Sc-s:
Solvent Extraction/Immobilization
This Alternative would involve excavation and pretreatment of
contaminated soil, on-site solvent extraction, and on-site burial
of all soils/sludges above the Soil Cleanup Levels. Pretreatment
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ROD DECZSZON SUMMARY
Salem Acres
paqe 32
to screen, shred, and mix the re~aining wastes to create a more
uniform-sized soil/waste mixture which could be more efficiently
treated by the solvent extractic~ process and stabilized.
Following pretreatment, at a minimum, 21,300 cu/yds of soil fr~m
areas DA-1, DA-2, SL-6, SL-12, a.1d SL-13 and at a minimum 3,00')
cu/yds of soil from SL-3, SL-4, SL-5, will be placed into an
enclosed mixinq tank, and combin.!d with a chemical solvent. T:le
solvent extracts the organic con':aminants from the soil and
sludge. The sol vent is then rem',ved from the soil through a
process of distillation.
Because solvent extraction may n..,t be effective in removing
metals, the 24,300 cu/yds of tre.lted soil would be combined wi~:h
a minimum of 12,300 cu/yds of additional soil from SL-3, SL-4,
and SL-5 and underqo a stabiliza:ion /solidification process
similar to that described in Alt~rnative SC-3. The
immobilization stage would utili~e a cement based stabilization
process that includes excavation of soils and mixing in tanks
followed by reburial of the solidified material under a permea;)le
cap. The immobilization process would add an additional 20% t~)
40% to the volume of the stabili:~ed material. This. process wi:.l
effectively bind up the heavy me.:als in a matrix that would
preclude leaching into qroundwat~r. Institutional controls
including deed restrictions on ~le use of the capped area,
fencing, and long-term qroundwatar monitoring would ~lso be
required under this Alternative. .
Laboratory performance data using the solvent process has shoWTt
consistent removal efficiencies =or PCBs greater than 99.99%.
However, actual field results wi.~ solvent extraction have not
produced the high removal effici~!ncies of the laboratory tests in
all cases. This is apparently d:le to complications presented
from certain non-homoqenous wastE!S that contain a variety of
solvents, oils and clays.
. .
Management Regulations (40 CFR 2.jO through 268), MADEP Air
Pollution Control regulations (3:0 CMR 6.00 and 7.00), OSHA
Safety and Health Standards (29 CFR 1910 and 1926) and the MAD!P
Waste Regulations (310 om 30.00), RCRA (40 CFR 264) would app2.y.
Land Disposal Requirements under RCRA would also apply. The
. federal and state air quality regulations would additionally
serve as applicable action-specific ARARs for excavation
activities when fugitive dust or particulate matter is generatad.
Both federal and state wetlands laws and regulations (Clean Water
Act (CWA) 33 USC 401 et seq. and 1344, 33 CFR 330, and MADEP 310
CMR 10.00) and the Wetlands Executive Order 11990 would be
potentially applicable location specific ARARs should
construction and/or excavation activities disturb any of the
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ROD DECISION SUKHARY
Salem Acres
Page 33
the Land Disposal since the material under this option would be
removed from the original location during treatment.
ESTIMATED TIME FOR DESIGN AND CONSTRUCTION: 20 MONTHS
ESTIMATED TIME FOR OPERATION: 24 MONTHS
ESTIMATED CAPITAL COST: $18,914,000
ESTIMATED 0 & M COST (Present Worth): $323,000
ESTIMATED TOTAL COST (Present Worth): $19,237,000
6.
Alternative SC-6:
In-Situ vitrification
Under this Alternative, organic contaminants would be destroyed
and inorganics immobilized through the process of vitrification.
Vitrification would be achieved by the placement of electrodes
into the soil at a desired depth and creating an electric current
between the electrodes, resulting in the heating of adjacent
soils to temperatures in the range of 1,6000 to 2,0000
centigrade. At this temperature the soils become a molten mass
and form a glass matrix once cooled. The vitrified material
. would be stable for several thousand years. The soils/sediments
volume would be reduced by 20 to 40 percent. After
vitrification, a permeable cap would be placed over the vitrified
soils, and the surface would be regraded and planted.
Alternative SC-6 would require an off-gas treatment system to
treat the highly volatile constituents that may be emitted during
vitrification. In addition, dewatering and treatment of ground
water beneath the contaminated soils/sediments would be
necessary. Alternative SC-6 would include the consolidation of
DA lagoon and SL areas and all other areas above Soil Cleanup
Levels prior to vitrification. This alternative would also
include long-term monitoring of contaminated media, access
restrictions (e.g., fencing), regrading, vegetation and
Institutional Controls.
This Alternative, although carried through in the FS, was
eliminated from consideration by EPA due to the hiqh potential
for fire hazard. This potential fire hazard results from the
combination of ignitable waste in the lagoons with the extremely
high temperatures required for the vitrification process.
ESTIMATED TIME FOR DESIGN AND CONSTRUCTION: 10 MONTHS
ESTIMATED TIME FOR OPERATION: 22 MONTHS
ESTIMATED CAPITAL COST: $44,600,000
ESTIMATED 0 & M Cost (Present Worth): $323,000
Estimated Total Cost (Present Worth): $44,923,000
7.
Alternative SC-7:
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ROD DECISION SUHKARY
Salem Acres
paqe 35
apply. Land ban requirements under RCRA would also apply. The
federal and state air quality regulations wculd additionally
serve as applicable action-specific ARARs fc~ excavation
activities when fugitive dust or particulate matter is generated.
Both federal and state wetlands laws and regllations (Clean Water
Act (CWA) 33 USC 401 et seq. and 1344, 33 Cr_~ 330, and MADEP 310
CMR 10.00) and the Wetlands Executive Order ~1990 would be
potentially applicable location-specific ~~~ should
construction activities disturb any of the r.!arby wetlands. RCRA
standards for treatment would apply under th! Land Disposal
Requirements since the material under this c:,tion would be
removed from the original location during tr!atment.
ESTIMATED TIME FOR DESIGN AND CONSTRUCTION: .0 MONTHS
ESTIMATED TIME FOR OPERATION: 22 MONTHS
ESTIMATED CAPITAL COST: $14,873,000
ESTIMATED 0 & M COST (Present Worth): $569,0'10
ESTIMATED TOTAL COST (Present Worth): $15,44.:,000
8.
A1~era~ive SC-7A:
Immobiliza~ioD/off' .Si~e Disposal
J
Alternative SC-7A is similar to Alternative ~;C-7 and
immobilization is the sole means of treatmen": for contaminated
soils at DA-1, DA-2,.SL-3, SL-4, SL-5, SL-6, SL-12, and SL-1J.
However, instead of the treated material bei'lg left on-site, it
would be disposed of off-site in a permitted landfill. The
chemical immobilization component of Alterna :ive SC-7A and the
amount of contaminateq sludges and soil treaced would be
identical to ,the immobilization process desc~ibed for Alternative
SC-7.
Because all of the contaminated soil above 50il Cleanup Levels
would be excavated and removed from the Site, it would be
necessary to backfill all of the' excavated areas with clean fill.
The Site would then be restored with topsoil, regraded, and
vegetated. Pretreatment to remove large obj ects, would be
required. under this Alternative. Additionally, I long-term
monitoring, fencing and access control, and Institutional
Controls would be required under this Alternative.
The regulations set forth by RCRA Subtitle C and in 310 CMR
30.00, considered applicable action-specific ARARs, would be met,
including: secondary containment of residual storage, tank
inspections, temporary waste piles, and contingency planning. In
addition, because this Alternative will remove waste from the
lagoons, the Land Disposal Requirements under RCRA would apply.
The federal and state air quality regulations would serve as .
applicable action-specific ARARs for excavation activities when
~uqitive dust or particulate matter is generated. Control
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ROD DECISION SttMKARy
Salem Acres
Page 35
apply. Land ban requirements under RCRA wo~ld also apply. The
federal and state air quality regulations wculd additionally
serve as applicable action-specific ARARs fc~ excavation
activities when fugitive dust or particulats matter is generated.
Both federal and state wetlands laws and regtlations (Clean Water
Act (CWA) 33 USC 401 et seg. and 1344, 33 Cr_{ 330, and MADEP 310
CMR 10.00) and the Wetlands Executive Order ~1990 would be
potentially applicable location-specific ~~{s should
construction activities disturb any of the n!arby wetlands. RCRA
standards for treatment would apply under th! Land Disposal
Requirements since the material under this c:,tion would be
removed from the original location during tr!atment.
ESTIMATED TIME FOR DESIGN AND CONSTRUCTION :.0 MONTHS
ESTIMATED TIME FOR OPERATION: 22 MONTHS
ESTIMATED CAPITAL COST: $14,873,000
ESTIMATED 0 & M COST (Present Worth): $569, 0')0
ESTIMATED TOTAL COST (Present Worth): $15,44:,000
8.
Alterative SC-7A:
Immobilization/Off' .site Disposal
i
Alternative SC-7A is similar to Alternative :%C-7 and
immobiliza~ion is the sole means of treatmeno; for contaminated
soils at DA-1, DA-2, .SL-3, SL-4, SL-5, SL-6, SL-12, and SL-13.
However, instead of the treated material bei'lg left on-site, it
would be disposed of off-site in a permitted landfill. The
chemical immobilization component of Alterna :ive SC-7A and the
amount of contaminateq sludges and soil treaced would be
identical to .the immobilization process desc~ibed for Alternative
SC-7.
Because all of the contaminated soil above Soil Cleanup Levels
would be excavated and removed from the Sits, it would be
necessary to backfill all of the' excavated areas with clean fill.
The Site would then be restored with topsoil, regraded, and
vegetated. Pretreatment to remove large objects, would be
required under this Alternative. Additionally, 'long-term
monitoring, fencing and access control, and Institutional
Controls would be required under this Alternative.
The regulations set forth by RCRA Subtitle C and in 310 CMR
30.00, considered applicable action-specific ARARs, would be met,
including: secondary containment of residual storage, tank
inspections, temporary waste piles, and contingency planning. In
addition, because this Alternative will remove waste from the
lagoons, the Land Disposal Requirements under RCRA would apply.
The federal and state air quality regulations would serve as .
applicable action-specific ARARs for excavation activities when
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ROD DECISION SUMMARY
Salem Acres
Page 36
,
equipment is available for fugitive dust control during
remediation. Air quality standards for organics can be met with
vapor phase treatment as an integral component of the remediation'
technology.
Both federal and state wetlands laws and regulations (Clean Water
Act (CWA) 33 USC sec. 401 et seq., 33 CFR 330, and MADEP 310 CMR
10.00) and the Wetlands Executive Order 11990 would b~ complied
with since the construction activities during remediation will
not disturb any of the nearby wetlands. Other ARABS include
Management Regulations under 40 CFR 260 through 268 and MA
Management rules provided in 310 CMR 30.00.
ESTIMATED TIME FOR DESIGN AND CONSTRUCTION: 10 ,MONTHS
ESTIMATED TIME FOR OPERATION: 22 MONTHS
ESTIMATED CAPITAL COST: $17,457,000
ESTIMATED 0 & M Cost (Present Worth): $569,000
ESTIMATED TOTAL COST (Present Worth): $18,026,000
9.
Al~erna~ive SC-7S:
soil/Sludge Fixa~ion/Off-Si~e Disposal
This Alternative would involve excavation and pretreatment of
contaminated soils/sludges, on-site soil-fixation of all
soils/sludges above the Soil Cleanup Levels and removal of the
treated material to an off-site permitted landfill. Pretreatment
in this overall process may be necessary to remove large objects
and to screen, shred, and mix the remaining wastes to create a
more uniform-sized soil/waste mixture which could be more
efficiently treated .by the soil-fixation process. FOllowing
pretreatment, a minimum of 21,300 cu/yds of lagoon sludges at
DA-1 and DA-2 will undergo an in-situ process of soil-fixation
with fly ash and possibly with other compounds such as silica and
cement. Following soil-fixation, the treated soil-fixed sludge
together with at least, and possibly more than, 15,300 cu/yds of
untreated soils from SL-3, SL-4, SL-5, SL-6, SL-12, and SL-13
will be excavated, loaded on trucks, and taken to an off-site
permitted landfill for disposal.
I
As for the other Alternatives, all contaminated soils and sludges
above Soil Cleanup Levels will be included in this Alternative.
This Alternative is technically easy to implement and would
provide for a permanent Site solution. Alternative SC-7B, must
satisfy the following three conditions in order to be
implemented:
1.
Treatability Studies utilizing bench tests and pilot
scale field operational study must demonstrate that the
soil-fixation process renders the sludges non-ignitable
and non-toxic as defined under RCRA at 40 CFR 261.21
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ROD DECISION SUHKARY
Salem Acres
Page 37
,
2.
All waste from the Site can be classified as a "Special
Waste" under Massachusetts Solid Waste Regulations 310
CMR 19.00.
3.
Treated laqoon sludqes from DA-1 and DA-2 and treated
soils from and untreated soils from the SL-3, SL-4,
SL-5, SL-6, SL-12, and SL-13 areas and other areas
above Soil Cleanup Levels can be disposed at a
permitted landfill.
The major components of this Alternative are listed below:
Permitted landfill selection for off-site disposal;
Treatability studies to determine fixation material and
mixinq requirements, includinq bench scale laboratory tests
and a field pilot test;
Additional soil delineation studies at hazardous waste areas
includinq, but not limited to, DA and SL areas to determine
cleanup boundaries based upon Site Soil Cleanup Levels;
site preparation, includinq road construction, security
measures, well closure, qradinq and qrubbinq activities, and
decontamination pad construction;
Drain~qe control measures to protect wetlands and waste
areas;
Air monitorinq and enqineerinq controls for dust, odors, and
noise;
Existinq cap removal and disposal;
Removal of laqoon water and treatment (if required);
Pretreatment of sludqes at DA-1 and DA-2 (if required);
Fly ash preparation and mixinq;
In-situ mixinq with fly ash at DA-1 and DA-2;
Excavation of treated waste from DA-1 and DA-2
Excavation of untreated waste from SL-3, SL-4, and SL-5;
SL-6, SL-12, and SL-13;
Excavation of other soils and sludqes above Soil Cleanup
Levels based on additional soil delineation studies at the
Site;
Off-site disposal by truck of DA and SL wastes and other
soils and/or sludqes above Soil Cleanup Levels at the
selected permitted landfill;
Other components include Site restoration to previous qrade
with clean fill, Site veqetation, and qroundwater well
installation and monitorinq for a minimum of five years.
Hazardous Waste Manaqement Regulations (40 CFR 260 throuqh 268),
MADEP Air Pollution Control regulations (310 CMR 6.00 and 7.00),
OSHA Safety and Health Standards (29 CFR 1910 and 1926) and the
MADEP Waste Regulations (310 CMR 30.00), RCRA (40 CFR 264) would
apply. Land ban requirements under RCRA would also apply. The
federal and state air quality regulations would additionally
7.
8.
9.
10.
11.
12.
13.
14. .
15.
16.
1.
2.
3.
4.
5.
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ROD DECISION SUMMARY
Salem Acres
Page 38
serve as applicable action-specific ARARs for excavation
activities when fugitive dust or particulate matter is generated.
Both federal and state wetlands laws and regulations (Clean Water
Act (CWA) 33 use 401 et seq. and 1344, 33 CFR 330, and MADEP 310
CMR 10.00) and the Wetlands Executive Order 11990 would be
potentially applicable location-specific ARARs should
construction activities disturb any of the nearby wetlands. RCRA
standards for treatment would apply under the Land Disposal since
the material under this option would be removed from the original
location during off-site disposal. .
ESTIMATED TIME FOR DESIGN AND CONSTRUCTION: 8 MONTHS
ESTIMATED TIME FOR OPERATION: 13 MONTHS
ESTIMATED CAPITAL COST: $9,032,000
ESTIMATED 0 & M COST: $91,000
ESTIMATED TOTAL COST (Present Worth): $9,123,000
IX.
SUHHARY OF TRE COMPARATIVE ANALYSIS OF ALTERHAT:IVE:S
A.
Evaluation criteria
section l2l(b) (1) of CERCLA presents several factors that at
a minimum EPA is required to consider in its assessment of
alternatives. Building upon these specific statutory
mandates, the National Contingency Plan (NCP) articulates
nine evaluation criteria to be used in assessing the
individual remedial alternatives.
A detailed analysis was performed on the Alternatives using
the nine evaluation criteria in order to select a Site
remedy. The following is a summary of the comparison of
each Alternative's strength and weakness with respect to the
nine evaluation criteria. These criteria are summarized as
follows:
Threshold criteria
The two threshold criteria described below must be met in order
for the alternatives to be eligible for selection in accordance
with the NCP.
1.
OVerall protection of human health and the
environment addresses whether or not a remedy
provides adequate protection and describes how
risks posed through each pathway are eliminated,
reduced or controlled through treatment,
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ROD DECISION SUMMARY
Salem Acres
paqe 39
2.
Compliance with applicable or relevant 1nd
appropriate requirements (ARARS) addres3es
or not a remedy will meet all of the ~\Rs
other Federal and state environmental l~ws
provide grounds for invoking a waiver.
primary Balancing criteria
whether
of
and/or
The following five criteria are utilized to compare ar.1 evaluate
the elements of one alternative to another that meet t~e
threshold criteria.
4.
5.
6.
7.
3.
Long-term effectiveness and permanence addresses
the criteria that are utilized to asseS5
alternatives for the long-term effectiveness and
permanence they afford, along with the degree of
certainty that they will prove successf~l.
Reduction of toxicity, mo~ility, or volame through
treatment addresses the degree to whict
alternatives employ recycling or treat~ent that
reduces toxicity, mobility, or volume, including
how treatment is used to address the principal
threats posed by the Site.
Short term effectiveness addresses the period of
time needed to achieve protection and any adverse
impacts on human health and the enviror.ment that
may be. posed during the construction ar.d
implementation period, until Soil Clearup Levels
are achieved.
Implementability addresses the techniccl and
administrative feasibility of a remedy, including
the availability of materials and services needed
to implement a particular option.
Cost includes estimated capital ~nd operation
Maintenance (O&M) costs, as well as present-worth
costs.
Hodifyinq 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
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ROD DECISION SUMMARY
Salem Acres
Page ~O
State's comments on ARARs or the proposed use of
waivers.
Community acceptance addresses the pUblic's
general response to the alternatives describ!d in
. the Proposed Plan and RI/FS report.
A detailed assessment of each alternative according to the .1ine
criteria can be found in Section 4.0.of the Feasibility Stuiy
(URS Consultants, Inc., June 4, 1992).
9.
FOllowing the detailed analysis of each alternative, a
comparative analysis, focusing on the relative performance)f
each alternative against the nine criteria, was conducted. This
comparative analysis can be found in Table ES-2, Volume I c: the
FS.
1.
OVerall protect;on of Human Health and the Environment
The preferred Alternative, SC-7B, and Alternative SC-7A eaC1
provide a very high degree of overall protection by removinJ all
Site waste above the Soil Cleanup Levels to an off-site per~itted
landfill. These two Alternatives would provide for complet!
protection from contact with contaminated soils and sludge ind
remove all risk associated with the Site.
Alternative SC-2, RCRA Subtitle C Capping, would also protect
human health and the environment by preventing exposures tc the
Site contaminants. .Although the RCRA Capping Alternative is not
a treatment of waste, the RCRA Subtitle C Cap results in tr.e
control of. the primary risk associated with the Site which is
from contact with and ingestion of contaminated soil and s:udge.
'The RCRA Subtitle C capping Alternative will require ground water
monitoring, periodic Site inspections, and Institutional Controls
to assure the long-term protectiveness of the remedy.
Alternative SC-3 (Incineration/stabilization), Alternative SC-4
(Desorption/Dechlorination/Stabilization), Altetnative 5 (Solvent
Extraction/Stabilization), and Alternative SC-7 (Immobilization),
would all offer a high degree of overall protection by either
destroying or removing organic contamination and contain metal
contamination by further treatment through immobilization. The
No-Action Alternative SC-l would not protect human health and the
environment over the long-term because the existing synthetic cap
over the lagoons was only planned for use as an interim solution
and would be expected to eventually fail. Additionally, the No-
Action Alternative would not treat or control material in the
contaminated soils areas at SL-l, SL-2, SL-3, SL-4, SL-5, SL-6,
SL-12, and SL-13. These untreated areas would continue to pose a
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ROD DECISION SUMMARY
Salem Acres
Paqe 41
,
Alternative SC-6, In-situ Vitrification was evaluated in the FS
but is not considered applicable due to the potential for fire'
hazard resultant from the high temperatures required for
treat~ent and the ignitable nature of the sludges.
Compliance with Applicable or Relevant and Appropriate
Requirements (ARARs)
All of the Alternatives, except for the No-Action SC-l and In-
situ Vitrification, SC-6, would meet federal and state ARARs
including state landfill regulations, air quality regulations,
hazardous waste storage and transportation regulations, process
discharge water regulations, wetlands regulations, and health and
safety regulations. Alternatives SC-7A, and SC-7B, because of
the off-site disposal of waste, would have the least impact on
site environmental media, but would have to meet ARARS for
potential air emissions and RCRA standards for treatment of
hazardous waste. Alternative SC-2, the RCRA Cap, would require
long-term monitoring to assure compliance with groundwater ARARS.
2.
3.
Long-Term Effectiveness and Permanence
Alternatives SC-7B and SC-7A would achieve long-term
effectiveness by removing all organic and metal contamination
from the Site, and thus restore the Site to a state that could be
used without restriction. These are the only two Alternatives
that entail off-site removal of waste and that would provide for
permanence through on-site treatment followed by the off-site
waste removal requirement.
Alternatives SC-3, SC-4, SC-S, and SC-7 would also achieve long-
term effectiveness and permanence by destroying or removing at
least 99.99% of the organic contamination and by stabilizing
metal contamination with immobilization. However, Alternatives
SC-3, SC-4, SC-S, and SC-7 would leave immobilized hazardous
waste on-site and would require Institutional Controls, fencing
and long-term monitoring to assure long-term effectiveness.
,
Alternative SC-2 would also provide an effective solution by
controlling exposures to soil and sludge; long-term
effectiveness, however, would have to be assured throuqh a
program of groundwater monitoring and Institutional Controls. A
series of operation and maintenance requirements to maintain the
RCRA Subtitle C Cap and the monitoring well system integrity
would also be required for this Alternative. Although an
effective remedy, the RCRA Subtitle C Cap does not provide the
same degree of permanence as does the off-site Alternative, SC-
7B. The -No-Action Alternative SC-l would not provide long-term
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ROD DECISION SUKMARY
Salem Acres
Page 42
~
with human exposures to contaminated soil and sludge would
continue under SC-l.
4.
Reduction of Toxicity, Mobility, or Volume through Trea:ment
All the Alternatives, except Alternative SC-l, would eliminate or
control the mObility of the contaminants. Overall, all the
Alter~atives except Alternatives SC-l and SC-2, would add an
overall 20 to 40% volume to the treated material as a result of
the solidification process. All the Alternatives, except SC-l
and SC-2, would satisfy the statutory preference for treatment to
reduce toxicity, mobility or volume under CERCLA. Alternatives
SC-7B and SC-7A are the only Alternatives that would provide for
th~ removal of the wastes off-site and thus achieve permanence
without the requirements for Institutional and other controls
except for short-term monitoring.
Alternatives SC-3, SC-4, and SC-5 would destroy at least 99.99%
of the organic contamination, but would still require the
immobilization of metals through stabilization. Stabilization
would reduce mobility of the metals and provide permanence, but
would increase the volume of treated soils by about 20% to 40%.
This increased volume may present some logistical problems for
disposal-of the waste on-site. For example, the increase in
volume may require special design considerations to prevent
encroachment of the solidified material into the surrounding
wetlands.
Alternative SC-2, RCRA Capping, although not a direct treatment
of the waste, would control infiltration and, thus, reduce the
probability of waste migration via groundwater. Alternative SC-2
would also indirectly result in a reduction of toxicity by
providing a RCRA Subtitle C Cap that would prevent contact-with
the contaminated soils and sludges on Site.
s.
Short-Term Effectiveness
The No-Action, Alternative SC-l, would not pose 'a risk to human
health or the environment beyond existing risks for the short -
term. Although air monitoring would be implemented on the Site
to prevent unacceptable exposures, the potential exists for
exposure of workers and adjacent residents to fugitive dusts
generated during construction and excavation activities
associated with Alternatives SC-2, SC-3, SC-4, SC-5, SC-7, SC-7A,
and SC-7B. In order to preclude dust generation and exposure to
air-born contaminants during construction activities, engineering
controls, dust suppressant agents, and safety equipment would be
employed. Additionally, measures to control noise during
construction activities would also be required due to the
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ROD DECISION SUHKARY
Salem Acres
Page 43
,
The potential for short-term impact to adjacent wetlands exists
under Alternatives SC-2, SC-3, SC-4, SC-S, SC-7, SC-7A and SC-7B
due to contaminated sediment runoff from disturbed areas.
Therefore, measures to control sediment run-off and wastewater
discharge during construction and waste treatment would be
required. Such measures include sediment traps and drainage
collection controls; the exact nature of the control measures to
be employed will be determined during the design stages of the
remedy.
6.
Implementability
Alternative SC-l would be the easiest to implement since it would
only require monitoring. Alternatives SC-2 and SC-7B would
involve the use of commonly available construction methods,
equipment, and materials and would be easily implemented. Both
of these Alternatives involve well established technologies -
Capping and immobilization are techniques that have been utilized
successfully at other Superfund Sites. However, Alternative SC-2
would require the construction of concrete barrier walls at DA-l
and DA-2 as well as at SL-4 and SL-S to provide for side-slope
stability and to preclude encroachment of the RCRA Subtitle C Cap
into the surrounding wetlands. These barrier walls may extend
the time to-implement the remedy due to design considerations.
Alternative 7B would likely be the shortest to implement and
would only take a total of 20 months. Alternatives SC-7 and SC-
7A involve technoloqies that are feasible to implement, but would
take 32 months to design and construct; while Alternatives SC-3,
SC-4, and SC-S would take 44 months for desiqn and construction.
Alternative SC-2 will likely take an additional year to implement
due to the .design and construction of the barrier/stabilization
walls.
Some technical difficulties may be encountered implementing
Alternative SC-3 (incineration/stabilization) and Alternative SC-
.4 (desorption/dechlorination/stabilization) due to the non-
uniform content of soils and sludqes on the Site. This non-
uniform nature may likely cause some delays in developinq a
uniform material for incineration and thermal desorption.
Additionally the incineration Alternatives SC-3 and SC-4 would
require trial burn tests to design controls for the potential
release of metals that can be expected at temperatures above
700°F. Although these technical issues can be resolved by
adequate study, they may extend the design phase and cause a
delay in implementation. There may also be some difficulties
implementing Alternative SC-S as the solvent extraction process
may not be highly effective in providing removal of contaminants
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~
,~
ROD D!CZSZON SUHKARY
Salem Acres
Page 44
7.
CQst
The most expensive of the options is Alternative SC-6, In Situ
Vitrification at $44,923,000 (not considered feasible because of
the potential for fire hazard) while the least expensive is the
No-Action Alternative, SC-1, which costs $330,000. Although
Alternative SC-1 is the lowest cost, it does not reduce Site
risks or provide a permanent solution. Alternatives SC-3, and
SC-4 and SC-5 involve treatment of the organics followed by
stabilization for metals and cost $30,825,000, $26,765,000 and
$19,237,000 respectively. Alternatives SC-3, SC-4, and SC-5 are
not considered cost effective in lieu of the other available
lower cost remedies (SC-2, SC-7', SC-7A, and SC-7B) that are as
protective in removing the Site risk which is due to soil contact
and/or ingestion.
Alternatives SC-7 and SC-7A are each a form of immobilization and
cost between $15,000,000 and $18,000,000. The basic difference
between Alternative SC-7 and SC-7A, is that in SC-7A the
stabilized waste is taken off-site; in SC-7 the waste is
stabilized and covered on-site with a permeable cap. In
Alternative SC-7B, waste is treated with a fly ash, soil-fixation
process and taken off-site for disposal. Alternative SC-7B is
estimated to cost $9,123,000'. Because Alternative SC-7B includes
off-site waste removal for all contaminated soils above the Soil
Cleanup Levels, this Alternative provides a permanent solution
and precludes the need for Site controls such as long-term
monitoring, Institutional Controls, and Operation and
Maintenance. Implementation of Alternative SC-7B offers a
permanent solution at a cost effective price and would result in
unlimited future site use. Alternative SC-7A also includes
provision for off-site disposal of wastes after on-site
immobilization and thus achieves permanence. However,
Alternative 7A would cost almost twice that of Alternative SC-7B,
and offers no siqn.ificant environmental advantages over the lower
cost Alternative SC-7B.
The contingent alternative to the preferred SC-1B remedy, is
Alternative SC-2, a RCRA Subtitle C Cap which is estimated to
cost $4,410,000. This Alternative would provide protectiveness
that would be similar to the other on-site Alternatives. This is
a result of the low migration potential of the contaminants of
concern on the Site and the nature of the RCRA Subtitle C Cap
that addresses the primary Site risk of contact/ingestion with
Site soils and sludges~ However, implementation of Alternative
SC-2 would leave waste on-site, and therefore it is not as
protective as the preferred remedy, SC-7B or the other
Alternatives that include treatment of the wastes. Alternative
SC-2, although a low cost and protective Alternative, would
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ROD DECISION SUMMARY
Salem Acres
Page 45
development and use of the RCRA Capped areas, long-term
monitoring, and a maintenance plan to maintain the RCRA Subtitle
C Cap integrity.
Following is a summary of costs for each of the Alternatives
listed by capital Cost, Operation and Maintenance, and Present
Worth. It should be noted that these costs are estimates and are
expected to provide an accuracy from - 30% to + 50% :
ALTERNATIVE Direct capital $ 0 , H $/yr. Present
Worth$
SC-l NO ACTION ° 21,500 330,000
SC-2 RCRA CAPPING 2,561,000 37,000 4,410,000
SC-3 INCINERATIONj
STABILIZATION 18,857,000 21,000 30,825,000
SC-4 THERMAL DESORPTION/
DECHLORINATION WITH
STABILIZATION 15,844,000 21,000 26,765,000
SC-5 SOLVENT EXTRACTION/
STABILIZATION 11,160,000 21,000 19,237,000
SC-6 VITRIFICATION 44,923,000 21,000 44,923,000
SC-7 IMMOBILIZATION 8,602,000 37,000 15,442,000
SC-7A IMMOBILIZATIONj
OFF-SITE DISPOSAL 10,122,000 37,000 18,026,000
SC-7B SLUDGE FIXATIONj "
OFF-SITE DISPOSAL 6,056,000 21,000 9,123,000
8. state Acceptance
Massachusetts DEP supports Alternative SC-7B, soil-Fixation with
fly ash (in-situ) with off-site disposal in a permitted landfill
and the Contingent Remedy, SC-2 of a RCRA Subtitle C Cap. A copy
of the Declaration of Concurrence is attached as Appendix D to
this ROD.
9.
community Acceptance
Several comments have been made by the community at the public
"hearing held in Salem, Massachusetts on the site on July 15,
1992. Comments mainly address community risks during
implementation of the proposed plan. These comments are
addressed in the Attachment A - The Responsiveness Summary.
Generally, the people that attended the public meetings
concerning the Site supported the proposed remedy SC-7B including
the contingent remedy, SC-2, of a RCRA Cap. Several people
declared their preference for the RCRA Subtitle C Cap over other
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ROD DECISION SUHHARY
Salem Acres
Page 46
x.
THE SELECTED REMEDY
The selected remedy for the Site is source control Alternative
SC-7B, soil-fixation with fly-ash (in-situ) and off-site disposal
at a permitted landfill. This remedy includes remediation of all
contaminated soils and sludges that are above the Soil Cleanup
Levels. This remedy has to satisfy the following three
conditions in order to be implemented: .
1.
Treatability testing by bench tests and pilot scale
operation must demonstrate that the fly ash fixation
process implemented at DA-1 and DA-2 renders the sludges
non-ignitable and non-toxic under RCRA (40 CFR 261.21 and
261.24).
2.
All waste from the Site can be classified as a "Special
Waste" under Massachusetts Solid Waste Regulations 310 CMR
19.00.
3.
Treated lagoon sludges (from DA-1 and DA-2 and untreated
soils from SL-3, SL-4, and SL-5, SL-6, SL-12 , and SL-13 and
possibly other areas above Soil Cleanup Levels can be
disposed of at a permitted landfill.
Unless all of the above conditions are met, a contingent remedy,
Alternative SC-2, RCRA Subtitle C Capping will be the selected
remediation for the Site. The RCRA cap, at a minimum, will cover
the lagoon areas DA-1 and DA-2 and contaminated soils from SL-3,
SL-4, SL-S, SL-6, SL~12, and SL-13. Pending design studies,
these soil areas may be consolidated prior to Capping and
additional'soils from.SL-1 and SL-2 and other areas may be
included in the remedy. As described in Section V and VI of this
ROD, contamination of groundwater, surface water, and sediments
is within the limi~s. established for cleanup and does not pose a
health risk greater than 1 x 10-4 except for arsenic in
groundwater which is just outside this range at 2.6 x 10 -4.
Because of the minor off-site migration of contamination at the
Site, the preferred and contingent remedies in the FS and in this
ROD do not include Management of Migration Alternatives.
A.
soil Cleanup Levels
Soil Cleanup Levels for known and suspect carcinogens (Classes A,
B, and C compounds) have been set at 1 x 10-4 to 1 X 10-6 excess
cancer risk level considering exposures via dermal contact and
incidental ingestion. Soil Cleanup Levels for compounds having
non-carcinogenic effects (Classes D and E compounds) were derived
for the same exposure pathway(s) and correspond to a level that
represents an acceptable exposure level to which the human
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ROD DECISION SUKKARY
Salem Acres
Page '"
adverse affect during a lifetime or part of a lifetime,
incorporating an-adequate margin of safety (hazard quotient = 1).
Exposure parameters for ingestion, inhalation, and skin contact
have been described in the BRA in Chapter 4. If a 50il Cleanup
Level described above is not capable of being detected with good
precision and accuracy or is below background values, then either
the practical quantification limit or a background value was used
as appropriate for the 50il Cleanup Level. Table 12 summarizes
the 50il Cleanup Levels for carcinogenic and non-carcinogenic
contaminants of concern.
~ABLE 12: SOIL CLEANUP LEVELS
BASED ON INGES~ION AND DDHAL CO~AC~
Carcinogenic
Contaminants
of Concern (Class) .
Soil Cleanup
Levels
Basis
Risk Level
CPAKs (B2 )
PCBs (B2)
Dioxins
Arsenic
Beryllium
1.20
1.00
1.00
40.00
0.42
ppm
ppm
pp!)
ppm
ppm
risk
risk
risk
risk
risk
6.7E-06
1.7E-06
2.0E-0"
'.6E-05
2.0E-06
Non-carcinogenic
Hazard Contaminants
~arget Endpoint
Quotient
Chromium (D)
900 ppm
500 ppm
HQ
HQ
Not Defined
Lead
liver/kidney
B2 - Pro!)a!)le Human carcinogen Based on Animal studies
D - Not Classified
HQ - Hazard QUotient
,
These Soil Cleanup Levels must be met throuqhou~ the Site at the
completion of the remedial action for all 5ite soils and sludges.
The 50il Cleanup Levels attain EPA's risk management goal for
remedial actions and have been determined by EPA to be
protective.. The areas to be remediated to 50il Cleanup Levels
include, but are not limited to: all of the soils and sludges at
DA-1 and DA-2, the two large lagoon areas, and the soils at 5L-3,
SL-4, SL-5, SL-6, SL-12, and 5L-13. The cleanup at the two
lagoon areas will be required from the ground surface to the
bedrock surface. Additional delineation outside these DA and 5L-
4 and SL-5 areas include, but are not limited to, areas: 5L-l,
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<;'0>
ROD DECISION SnHHARy
Salem Acres
. Page 48
Based upon the information in the RI, it is expected that, at a
minimum, 21,300 cu/yds of sludge and soil will have to be
treated, excavated, and removed off-site to a permitted landfill
from DA-1 and DA-2. Additionally, it is anticipated that, at a
minimum, 15,300 cu/yds of soil contaminated primarily with metals
will have to be excavated and removed off-site to a permitted
landfill from the SL-3, SL-4, SL-5, Sl-6, SL-12, and SL-13.
Depending upon further delineation testing at the Site during the
design phase, additional amounts of material (soils and sludges
above Soil Cleanup Levels) could be included in the remedy.
B. Description of Remedial Components
The preferred remedy, Alternative SC-7B, includes the in-situ (in
place) soil-fixation treatment of a minimum of 21,300 cu/yds of
'lagoon sludges at DA-l and DA-2 with fly ash and possibly with
other compounds such as silica and cement. Following soil-
fixation, the fixated sludge from DA-1 and DA-2 together with, at
a minimum, an additional 15,300 cu/yds of untreated soils from
SL-3, SL-4, SL-5, SL-6, SL-12 , and SL-13 will be excavated,
loaded on trucks, and taken to an off-site permitted landfill.
All contaminated Site soils/sludges above 50il Cleanup Levels
will be included in the remedy and will be completely defined as
a result of design delineation studies. The preferred remedy,
Alternative SC-7S, must satisfy the three conditions described
above (Section X) in order to be implemented. If all of the
conditions are not met, then a contingent remedy, Alternative SC-
2, RCRA Subtitle C Capping, will be the remedy for the Site.
The RCRA Subtitle C Cap will cover at least, but not limited to,
the lagoon 'areas DA-1 and DA-2 and contaminated soils from SL-3,
SL-4, SL-5, SL-6, SL-12 , and SL-13. Pending design studies,
these soil areas may be consolidated prior to Capping. As in the
case of the preferred remedy, all contaminated Site soils/sludges
above the Soil Cleanup Levels will be included in the remedy and
will be completely defined as a result of design delineation
studies. Both the preferred remedy and the contingent remedy
will address the primary risk at the Site which 'is direct contact
with and/or ingestion of Site soils and/or sludges. The
components of the selected remedy, SC-7B and the contingent
remedy SC-2 are described below:
1. Selected Remedy Components - SC-7B
At a minimum, the following components of Alternative SC-'B shall
be performed by the party or parties responsible for the
implementation of the remedial action:
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ROD DECISION SUKHARY
Salem Acres
Page 49
As the initial step in the design, a commitment letter shall
be obtained from the permitted landfill and sent to EPA.
The letter from the landfill authority shall describe the
costs for disposal, ~~e amount of waste to be accepted,
specific requirements for testing and any other requirements
that the landfill authority may have. This letter shall be
accompanied with an estimate for the cost for transportation
and disposal of waste at the permitted landfill.
b. Treatability Studies
(1) Bench scale tests treatability studies: A treatability
study will be performed during the design stage to determine
the appropriate mix of fly ash with the various waste in the
lagoons DA-1 and DA-2 on Site. Samples for this study w~ll
be collected from the lagoons at DA-1 and DA-2. Additional
compounds such as portland cement or other compounds may be
added to the fly ash to provide for additional "fixation" of
the organic wastes, if required, to produce a treated
material that meets the RCRA standards for toxicity and
iqnitability (40 CFR 261,21 and 261.24). Other tests or
standards may be required by the Massachusetts DEP for total
hydrocarbon content or by the landfill accepting the waste.
(2) After successful completion of the Bench scale tests, a
pilot scale on-site test on not less than 300 cu/yds of
material from DA-2 (in an area away from the wetlands and
approved by EPA) shall be performed as part of the design
study to demonstrate the feasibility of the remedy and to
refine mixing requirements and requirements for odor, dust,
noise "and wetlands controls.
c. Site Preparation
Site preparation activities will be initiated with the
construction of access roads necessary for the mobilization
and use of excavation, treatment and disposal eqUipment.
Roadway construction and decontamination pads would be
constructed to minimize the impacts to wetlands in
accordance to the design assumptions made on Appendix B of
the FS. Design of the decontamination pad shall be at least
4 inch thick concrete with minimum dimensions of 12 feet
wide and 25 feet long. The pad shall contain an adjacent
sump pump and holding tank.
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ROD DECISION SUMMARY
Salem Acres
paqe 50
site preparation work shall also include provisions for.
controlling Site drainage and provisions to assure that
silt, soils and sludges do not drain into adjacent wetlands.
This will be accomplished by the development and
implementation of a "Site Wetlands and Drainage Control
Implementation P~an".
Drainage control will be implemented to divert run-off from
the disposal areas, in particular disposal areas DA-l and
DA-2, and to control sediment deposition in the wetlands.
This plan shall include diversion ditches, sedimentation
traps and other measures to control the potential adverse
affects of water run-off from the waste Site areas into the
adjacent wetlands.
e. Clean Area Delineation study
Additional soil delineation testing in the areas between and
outside the ~agoons at DA-l and DA-2 and at SL-3, SL-4, and
SL-5 shall be done to determine the exact area and quantity
of naterial that will be addressed by this remedy. This
soi2 testing shall include tests for Soil Cleanup Levels
established by EPA in Section X. In addition, soil testing
sha~l also take place at SL-l, SL-2 (and possibly other
areas) to further delineate the site and determine if these
and/or other areas should be included in this remedy.
Sediment testing at WA-l adjacent to the DA-l disposal area
.shall also be included as part of this study. All Site
soils/sludges shall be remediated up to Soil Cleanup Levels
established in .Section X.A. of this ROD.
,"
f. Air Monitoring
An air monitoring program shall be implemented to determine
if site activities pose a threat to human health or the
environment. The stations employed for monitoring shall be,
at a minimum, similar to the stations utilized during the
Remedial Investigation. Sampling shall include testing for
compounds identified in Section X.A.
q. Existinq Cap Removal and Disposal
The existing cap at DA-l and DA-2 shall be removed
immediately prior to the actual mixing with fly ash and
other materials that have been identified during the
treatability studies to control odor and run-off problems.
If required, standing water in the lagoons will be pumped
into temporary holding areas on site and tested. The water
shall be treated, if required, and disposed of at a local
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ROD DECISION SaMHARY
Salem Acres
Page 51.
h. Pretreatment of Sludges and Soils
Pretreatment requirements will be determined by EPA during
the pil~t stage testing. If required, removal of large
objects from the sludges and soils will precede mixing with
fly ash. These objects will be decontaminated, tested, and
disposed of in the off-site landfill.
i. Kixi:!1g
Fly ash and possibly other compounds such as silica and
cement would be mixed in the lagoons (in-situ mixing) with,
at a minimum, 21,300 cu/yds of lagoon sludge at DA-l and DA-
2. Approximately 26,000 tons of fly ash and possibly other
additives determined during treatability studies will be
required to immobilize the contaminants in the sludge.
Approxi~ately 7,000 tons of fly ash from SL-4 would be
excavated and combined with about 19,000 tons of additional
fly ash that would be purchased and transported to the site.
Some pretreatment of the sludges may be required to remove
large objects that would interfere with the soil fixation.
Additionally dust suppression and odor controls will likely
be required during and/or after the mixing stages with fly
ash. _These controls, as well as the method for mixing, will
be determined during the pilot scale test. All .
soils/sludges above the Soil Cleanup Levels established in
section X.A of this ROD will be included in the remedy (The
drums of hazardous waste at DA-l will be mixed with fly ash
and removed off-s~te with the other "fixed" waste).
j. Testing
The materials scheduled for shipment off-site would be
subject to testing for RCRA Toxicity and Iqnitability (40
CFR section 261.21 and 261.24), MA DEP requirements for
disposal of solid waste, and those requirements of the
permitted landfill.
k. Excavation
Following treatment with fly ash, the immobilized sludge
would be excavated from the lagoons at DA-l and DA-2, and
combined with untreated soils from SL-3, SL-4, and SL-S, SL-
6, SL-12, and SL-13 and other soils above Soil Cleanup
Levels and loaded on trucks for off-site disposal in the
permitted landfill.
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ROD DECISION SUHHARY
Salem Acres
Paqe S2
Excavated areas would be backfilled, covered with clean
soil, graded to pre-excavation levels, and seeded and
maintained for a period of two years or until vegetation in
the filled areas becomes reestablished.
m. GroUDdwa~er Koni~orinq
A groundwater monitorinq system would be required for a
minimum of at least five years to confirm the effectiveness
of the remedial action at the site. This qroundwater
monitoring system will be installed as one of the initial
steps of the remedy. The monitoring system shall include
wells in the overburden and bedrock in a minimum of least 12
locations on-site. Effectiveness of the remedy shall be
based upon meeting ARARs and upon qroundwater monitoring
levels in a risk range of between 1 x 10-4 and 1 x 10-6
shall be considered proof of the effectiveness of the
remedy.
n. Cos~ and xmp1emen~a~ion Time for A1~erna~ive SC-'B
ESTIMATED TIME FOR DESIGN AND CONSTRUCTION: 8 MONTHS
ESTIMATED TIME FOR OPERATION: 13 MONTHS
EST~TED CAPITAL COST: $9,032,000
ESTIMATED 0 & M COST: $91,000
ESTIMATED TOTAL COST (Present Worth): $9,123,000
2. con~inqen~ Remedy Componen~s, A1~erna~ive SC-2
.
In the event that soil-fixation, Alternative SC-7B, cannot be
implemented due to the conditions described in the introduction
of Section X of this ROD, a RCRA Subtitle C Cap will be placed
over the lagoons at DA-1 and DA-2, ~nd at soil areas SL-3, SL-4,
SL-5, SL-6, SL-12, and SL-13 and other areas that exceed the Soil
Cleanup Levels for the site. Additional areas for RCRA Capping
may be required and will be determined by soil delineation
studies during the design stages. At a minimum, the following
provisions of Alternative SC-2 shall be performed by the Party
responsible for carrying out the remedial actions:
a. similar provisions wi~h A1~erna~ive Sc-,s
1. Si~e Preparation
Site preparation activities will be initiated with the
construction of access roads necessary for the
mobilization and use of excavation, treatment and
disposal equipment. Roadway construction and
decontamination pads would be constructed to minimize
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ROD DECISION SUHKARY
Salem Acres
Page S3
assumptions made on Appendix B of the FS. Design of
the decontamination pad shall be at least 4 inch thick
concrete with minimum dimensions of 12 feet wide and 2S
feet long. The pad shall contain an adjacent sump pump
and holding tank.
2. Drainage Control Plan
Site preparation work shall also include provisions for
controlling Site drainage and provisions to assure that
silt, soils and sludges do not drain into adjacent
wetlands. This will be accomplished by the development
and implementation of a "Site Wetlands and Drainage
Control Implementation Plan".
In general, drainage control will be implemented to
divert run-off from the disposal areas, in particular
disposal areas DA-l and DA-2 and to control sediment
deposition in the wetlands. This plan shall include
diversion ditches, sedimentation traps and other
measures to control the adverse affects of water runoff
at the waste site areas into wetlands.
3.-Clean Area Delinea~ion study
Additional soil delineation testing in the areas
between and outside the lagoons at DA-l and DA-2 and at
SL-3, SL-4, and SL-S shall be done to determine the
exact area and quantity of material that will be
addressed by this remedy. This soil testing shall
include tests for Soil Cleanup Levels established by
EPA in Section X.A.. In addition, soil testing shall
also take place at SL-l, SL-2 (and possibly other
areas) to further delineate the Site and determine if
these and/or other areas should be included in this
remedy. Sediment testing at WA-l adjacent to the DA-l
disposal area shall also be included as part of this
study. All Site soils/sludges shall ~e remediated up
to Soil Cleanup Levels established in Section X.A. of
this ROD.
4. Air Honi~oring
An air monitoring program shall be implemented to
determine if Site activities pose a threat to human
health or the environment. The stations employed for
monitoring shall be, at a minimum, similar to the
stations utilized during the Remedial Investigation.
Sampling shall include testing for compounds identified
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ROD DECISION SUHKARY
Salem Acres
Page S4
4.
5.
b. Feasibility Study for Soils/Sludge Consolidation
A Study to determine the feasibility of soil/sludge
consolidation or soil consolidation alone shall be
determined as an initial step in the design for the RCRA
Caps. This study will determine which areas, if any, could
be combined with other areas to reduce cost and increase the
efficiency of the Remedy.
c.
Existing cap
A synthetic non-RCRA cap is presently in place and covers
the lagoon areas of DA-~ and DA-2. The SL waste areas are
not covered at present. This non-RCRA cap was installed as
a result of the EPA Emergency Removal (ERA) in April, ~987
to control lagoon overflows into the adjacent wetlands. The
design of the new RCRA Subtitle C Cap system will evaluate
the feasibility of utilizing the present cap and slurry
walls in the remedy (rather than removal) as a measure of
additional protectiveness, but not as a substitute for the
RCRA Subtitle C Cap.
d. RCRA Subtitle C Cap Components
The RCRA Subtitle C Cap shall include the following
components from top to bottom:
~.
A top soil layer of at least 24 inches thick to promote
vegetative "growth. This layer shall contain a minimum
layer of six inches of compacted top soil. A flexible
geotextile will separate this top layer from the
drainage layer which is described next.
A drainage layer of 12 inches to provide for drainage
away from the underlying impermeable layers. The
permeability (K) for this layer shall be ~0-2 or
greater. A geotextile drainage layer may be added in
instead of a soil drainage layer. I
2.
3.
An impermeable flexible liner will lie directly beneath
the drainage layer.
A 24 to 36 inch layer of compacted clay with a K value
of 10-6 will underlie the flexible liner.
A layer of soil between the clay layer and the area of
soil or sludge to be capped to provide a smooth layer
for the clay cover. The thickness of this layer will
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ROD DECISION SUMMARY
Salem Acres
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,
A layer of soil or geotextile shall be added to provide
for gas collection. This gas shall be vented to the
atmosphere.
This Cap would be designed and constructed in accordance
with the current Federal Resource Conservation and Recovery
Act (RCRA subtitle C) guidelines in effect at the completion
of the Cap Design. Grading and/or other measures will be
provided to promote rapid drainage away from the Cap. (The
drums of sludge samples at DA-l will be emptied and added to
the sludge at DA-l prior to Capping.)
6.
8. Concrete Barrier and Retaininq Walls
In addition to the RCRA Cap, a concrete barrier wall would
be constructed between area DA-l and the adjacent wetlands
at WA-l and between area DA-2 and Wetlands WA-4, and
concrete retaining walls would be constructed around the
west side of areas SL-4 and SL-5. The walls would provide
side slope stability in addition to preventing the migration
of contaminants to the wetlands. Other areas may require
barrier and or retaining wall construction and will be
determined during the design of the RCRA Cap. If future
groun~water monitoring should indicate the RCRA Subtitle C
Cap was not effective, additional controls may be applied.
These controls include additional monitoring as well as
additional treatment. The exact nature of the controls that
may be implemented would depend upon the nature of the
contamination and. the specific problems associated with the
contamination. This adds to the overall protectiveness of
this remedy.
f. Fencing and Signs
Because this Alternative does not include any treatment,
contaminated soil would remain on-site beneath the RCRA
Subtitle C Cap. In order to protect this RCRA Subtitle C
Cap and thereby provide continued, long-term"reduction in
human exposure to soil contaminants, access to the Capped
areas would be restricted by fencing. Hazardous waste
warning signs, with wording similar to the existing Site
signs"wi11 be required to be posted both inside the fence as
well as on the fence. These signs shall be made of weather
resistant plastic and signs inside the fence shall be placed
on fiberglass poles secured in a cement base. Posting
inside the fence is required to reduce the opportunity for
vandalism. The design of these warning siqns shall be
determined during design studies.
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ROD DECISION SUMMARY
Salem Acres
Page 56
Any future development in the southern portion of the Site
would be prohibited through Institutional Controls.
Drainage controls would also be implemented in order to
preclude run-on and potential erosion impacts of rain and
snow melt on the RCRA Cap. Finally, a groundwater
monitoring program would be developed to allow periodic
evaluation of the RCRA Cap's effectiveness in preventing the
migration of soil contaminants into groundwater.
The Site is zoned for residential land use, and residential
development of the Site has been proposed in the past. With
an Alternative such as containment by RCRA Capping, it would
not be appropriate to construct residential dwellings or
other structures within, or in the immediate vicinity of the
untreated contaminated soil areas on-site. Therefore,
Institutional Controls, specifically the prohibition of any
form of development in the southern 13 acres of the Site,
would be a requirement with this Alternative.
h. Groundwater Monitoring
The purpose of qroundwater monitoring would allow an
indirect method for evaluating the effectiveness and
permanence of the RCRA Cap. At least 12 new locations, with
wells located in the overburden and in the bedrock would
have to be installed in order to provide for comprehensive
monitoring. Groundwater monitoring for the Contaminants of
Concern, identified in Section X.A, and other hazardous
. compounds to be identified during the design phase shall be
done on a quarterly basis for the first five years at a
minimum, and there~fter twice a year.
i. Additional Site Remedial Measures
The combination of a RCRA Cap, security fence and
Institutional Controls would eliminate, all risks associated
with human exposure to contaminated soil, ~ncluding those
derived from ingestion, dermal contact and inhalation of
airborne particulates. However, the contaminants would
remain on-site in an untreated form under the RCRA Cap. As
a result, there would be a potential residual risk if the
RCRA Subtitle C Cap were" to fail in the future or, as a
result of fence breaching or Institutional Controls
failures, be disturbed by future on-site activities and/or
vandalism. This remedy would call for operation and
maintenance requirements to assure RCRA Cap, fence, and
monitoring well integrity, and Institutional Controls.
In addition, if groundwater monitoring shows a risk greater
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ROD DECISION SnHHARY
Salem Acres
Page 57
be initiated by the EPA. This Assessment will review all
available groundwater and other Site information available
to determine if additional treatment and lor controls are
necessary. These additional requirements may include one or
more of the following: source related controls, migration of
contamination controls, Institutional Controls, and
continued or additional monitoring requirements and other
controls considered applicable. The decision to institute
additional Site actions shall be made by the EPA Regional
Administrator.
ESTIMATED TIME FOR DESIGN AND CONSTRUCTION: 20 months
ESTIMATED TIME FOR OPERATION: 30 years
ESTIMATED CAPITAL COST: $3,841,000
ESTIMATED 0 & M COST: $569,000
ESTIMATED TOTAL COST (Present Worth): $4,410,000
XI. S~A~tJTORY DE~ERHINA!rIONS
A.
The Selected Remedy is Protective of Human Health and the
Environment
1. ~ternative SC-7B Soil Pixation with ~ly ash and Off-site
Disposal
The remedy at this Site, Alternative SC-7B, will permanently
reduce the risks posed to human health and the environment
by eliminating, reducing or controlling exposures to human
and environmental receptors through treatment, engineering
controls and off-site disposal of treated wastes; more
specifically in-situ treatment with fly ash of contaminated
sludges and soils at DA-1 and DA-2; excavation of these
treated materials into trucks, and disposal of these wastes,
together with untreated soils from SL-3, SL-4, SL-5, SL-6,
SL-l2, and SL-13 and all other soils and lor sludges above
Soil Cleanup Levels, to a permitted landfill. This remedy
includes all site contaminated soils/sludq~s that are above
the Soil Cleanup Levels and may include areas in addition to
those mentioned above. These additional areas will be
delineated during Site design studies as required in Section
X.B.1(e) above. Thus this Alternative will eliminate the
risk at the Site which is due to contact with andlor
ingestion of contaminated soils and sludges.
The selected remedy is protective of human health and the
environment and will include a monitoring program that will
ensure the protective aspects of the remedy. Moreover, the
selected remedy will attain potential human health risk
levels that maintain the 1 x 10-4 to lx 10-6 incremental
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ROD DECISION SUMHARY
Salem Acres
Page 58
J
endpoints. The remedy will also comply with ARARs and "To
Be Considered" crite~ia. The solution of off-site disposal
of Site waste offers a permanent remedy that will allow for
the future unrestricted use of the Site.
Implementation of this remedy will not pose unacceptable
short-term risks or cross-media impacts since the
technologies are proven and will be field tested with a
pilot proqram to reduce operational risks. Engineering
controls will be used to minimize potential for noise, dust,
and air releases of contaminants during construction
activities.
2. The Contingent Remedy, Alternative SC-2 - RCRA Subtitle C
Capping
As a contingency to Alternative SC-7B (in the event that one
of the conditions in Section X.A. above cannot be met),
Alternative SC-2 will be employed to remediate the Site. At
a minimum, an on-site RCRA Subtitle C Cap will be placed
over the disposal areas at DA-1 and DA-2, as well as at SL-
3, SL-4, SL-5, SL-6, SL-12 , Sl-13 and over other soils or
sludges that are above the Soil Cleanup Levels. While the
application of a RCRA Subt~tle C Cap will not affect the
volume or provide treatment of the waste, RCRA capping will
impede the mobility of the waste through the qroundwater and
will also control all the primary Site risks associated with
exposure to the Site soils and sludges.
Moreover, the data from the Remedial Investigation and other
information available in the Administrative Record
demonstrate that health based risk associated with average
values for Site qroundwater, surface water, or sediments in
the wetlands are within an average risk of 1 x 10-4 to 1 x
10 -6 (Arsenic risk in qroundwater for the maximum value is
2.6 x 10 -4). These findings are consistent with the type
of wastes found on the Site; that is, the Contaminants of
Concern are PAH's and metals, which, with some exceptions,
miqrate slowly in qroundwater. Thus, the risk at the Site
is controlled by RCRA Capping. The RCRA Capping Alternative
would require engineering controls to assure the RCRA
Subtitle C Cap inteqrity and to assure long-term
protectiveness and include:
1.
2.
3.
4.
5.
Institutional controls
Long-term Monitoring of Groundwater
Periodic Site Inspections
Fencing and Posting with Keep Out Signs
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R~D DECISION SUKKARY
Sa-lem Acres
Paqe 59
6.
Periodic upkeep of the RCRA Cap, Including
Repairs and Usual Operation and Maintenance
However, the RCRA Subtitle C Cap does not constitute
treatment, and, thus, untreated waste remains on-site under
implementation of this Alternative. In the event of
alteration of the RCRA Cap, the possibility for off-site
movement of contaminants in the qroundwater exists. As an
additional requirement of this Alternative, if t~e
groundwater monitoring demonstrates that health related risk
above 1.0 X 10-4 exists or if ARARs are exceeded, a "Site
Assessment" will be initiated. This Assessment and a
decision for additional Site controls and/or treatment will
be made by the Regional Administrator of the EPA.
Additional treatment/controls at the Site, if required, may
consist of one or more of the followinq: source control,
miqration control, Institutional Controls, continued or
additional monitorinq, and or other measures andior controls
that are determined to be responsive to the particular
issues at the Site. This additional requirement for a Site
Assessment adds to the overall protectiveness of the RCRA
Subtitle C Cap Alternative and for the above reasons EPA has
determined that Alternative SC-2 will provide adequate risk
reduc1:ion.
B.
The Selected Remedy Attains ARARs
The Selected Remedy and the Contingent Remedy each will
attain all applicable or relevant and appropriate federal
and state requirements that apply to the Site. The ARARs
for the selected. remedial action are derived from
substantive portions of environmental laws, and the specific
ARARs include, amonq others, those listed below.
1. Alternative se-7B Soil-Fixation and Off Site Disposal
(a) Chemical Specific ARABS
(1) Chemical Specific ARARS List
Massachusetts Ground Water guality Standards - Applicable
Standards include Ground Water Classificationj Water
Quality Criteria to Sustain the Desiqnated Usesj and
Regulations to Achieve Uses and Maintain Ground Water
Quality - 314 CMR 6.00.
Massachusetts Operation and Maintenance and Pretrea~ent
S~dards for WasteWater, Treatment Works, and Indirect
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ROD DECISION SUMMARY
Salem Acres
Page 60
Pe~eral Safe Drinking Water Act (SDW1) - Applicable
National Primary Drinking Water Regulations (NPDWR) 40
cn 014l.
Maximum Contaminant Levels (MCLs) and Maximum
Contaminant Level Goals (MCLG).
Ha~sachusetts Drinking Water Regulations - Applicable
Massachusetts Maximum Contaminant Levels (MMCLs).
MMCLs for compounds detected at the Salem Acres Site
include Federal MCLs Adopted by DEP - 310 CMR 22.00.
~a;csachusetts Surface Water Discharge Permit Requirements -
Relevant and Appropriate
Regulates discharges to surface waters and any
treatment works associated with discharges. Applicable
if any lagoon water requires treatment - 314 CMR 4.04.
ClE:&n Water Act (CWA) - Applicable
- National Pollution Discharge Elimination System (NPDES)
A NPDES permit is required if the lagoon water is
discharged off-site, as defined in the NCP, to the
surface waters of the United States - 40 CFR Parts 122
and 125.
Ha~sachusetts Surface Water Quality standards - Applicable
Regulations recommend the use of Federal Ambient Water
Quality criteria (FAWQCs) to establish water quality
for toxic pollutants. Applicable if the lagoon is
discharged to surface waters of the United States - 314
CMR 4.00.
Cleln Air Act (CAA) - Applicable
National Ambient Air Quality Standards (NAAQS) - 40 CFR
Part 50.
National Emission Standards for Hazardous Air
Pollutants (e.g., benzene and vinyl chloride) - 40 CFR
Part 61.
.,
Massachusetts Air Pollution Control Regulations - Standards
for emissions of hazardous and non-hazardous air
pollutants 310 CMR 6.0 through 8.0
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ROD DECIS;ON SUHHARY
Salem Acres
Paqe 61
The groundwater aquifer at the compliance boundary is
classified as a Class I source of potable water under the
Feder~l Groundwater Protection Strategy and as Class I by
the C~mmonwealth of Massachusetts. While Maximum
Contaninant Levels (MCLs) and Maximum Contaminant Level
Goals (MCLGs) promulgated under the Federal Safe Drinking
Water Act are not applicable to groundwater, they are
relev mt and appropriate to groundwater maintenance for the
selec~:ed remedy. Site groundwater presently attains the
MCL's (See 40 CFR 300.430(a) (iii) (F». The Selected Remedy
will c\ttain MCLs by the removal of waste off-site which will
eliminate discharges into the groundwater. Massachusetts
grouncwater quality standards for Class I groundwater issued
in 31~ CMR 6.00 are applicable requirements for the Site.
The S~ate drinking water standards that are relevant and
appro~riate for groundwater as a potential drinking water
suppl1 are the Massachusetts Maximum Contaminant Levels
(MMCL;) issued under 310 CMR 22.00, which are the same as
Feder~l MMCLs and MCLGs.
In ad~ition to the Federal and State regulatory standards
and g~idelines for drinking water and groundwater, risk- .
based :riteria are to be considered. These criteria include
conce~:rations derived from EPA Reference Doses (RiDs) and
risk-s.Jecific doses based on Carcinogenic Potency Factors
(CPFs) and standard exposure assumptions for the ingestion
of dri lking water.
Altern"Ltive SC-7B, is not anticipated to have an adverse
effect on the Site groundwater, and thus will maintain these
ARARs c\S well as those regulations which have been
identiiied as TBCs above. Moreover, the Site remedy will
offer a permanent solution so that groundwater will be a
source of future drinking water.
Federal Primary and Secondary National Ambient Air Quality
Standards (NAAQS) under the Clean Air Act (CAA) exist for
emissi~ns of sulfur oxides, carbon monoxide, ozone, nitrogen
oxides. lead and particulate matter (PM10). Generation of
fuqiti're dusts and air emissions from sediment excavation or
capping operations and soil/sediment consolidation and
treatmEmt facilities (air and stabilization treatment
systems) are subject to NAAQS. Best available control
technoloqies will be utilized to promote and maintain public
health and welfare.
Massachusetts air regulations include Ambient Air Quality
Standards (310 CMR 6.00), Air Pollution Control Regulations
(310 CMR 7.00) and requirements for the Abatement of
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~$~
~~
.~~.
ROD DECISION SttHHARy
Salem Acres
Page 62
8.00). Certain provisions of 310 CMR 7.00 which require the
best available emissions controls and specify ambient air
quality standards are applicable and will be met by
engineered controls. The remaining State standards for
fugitive emissions from excavation and consolidation, and
emissions from treatment equipment associated with this
remedy are relevant and appropriate and will be met through
the use of engineering controls. These controls will be
completely identified during the design phases of the
project.
These Federal and state air standards will guide mitigation
measures designed to control the release of fugitive dust,
particulate matter and VOCs during excavations at the site.
Odor and dust controls will be established during the pilot
.scale operation in order to meet all air requirements.
These controls may include foams and/or other similar
chemicals used to spray on areas to reduce odor and dust and
or containment structures that capture dusts and odors and
include treatment methods such as filtration, carbon
columns, and thermal oxidation. There are a variety of
controls that may be utilized and the final selection of
dust, odor, and VOC controls shall be determined during the
design phase of the pilot scale treatment test.
Massachusetts standards for the treatment of surface water
discharges 314 CMR 3.00 and 4.00 and federal requirements
under NPDES are relevant and appropriate in the event that
lagoon water is. collected, treated and discharged to surface
waters of the United States via a permitted treatment
facility (MTF). . Prior to discharge into a MTF, treatment
may be required for dissolved and suspended hazardous
compounds. Treatment methods utilizing carbon and forms of
precipitation for metals removal may be employed. The exact
treatment methods to be employed will depend upon the nature
of the lagoon water waste constituents.
(~)
Loca~ion specific ARARS
(1) Location specific ARARS List
Hassachuset~s Wetlands Protection Act (WPA) Requlations -
Applicable - 100 foot buffer zone of wetlands is regulated
under WPA - 310 CMR 10.00.
Federal Execu~ive Order 11990, Protection of Wetlands -
Applicable - These regulations require minimization of
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ROD DECISION SaKKARY
Salem Acres
Page 63
Pederal - Clean Water Act (eRA) - Relevant and Appropriate
Requirements under these codes prohibit discharge of dredged
or fill material into wetlands - CWA Section 404 (b) (1); 40
CFR part 230, 33 CFR parts 320-330.
Pederal - US Pish and Wildlife Coordination Act - 16 USC 661
et. seq.- Applicable - Requirements to mitigate adverse
impacts to natural resources including wetlands.
(2) Location Specific ARARS Description
Areas immediately adjacent to the east, north, and west of
the Site are wetlands and protected under the Massachusetts
Wetlands Protection Act (WPA) Regulations (310 CMR 10.00),
the Federal Clean Water Act 404 (b) (1) Dredge and Fill
Regulations, the Federal Executive Order 11990 requiring
wetland protection, and the Federal Fish and Wildlife
Coordination Act (16 USC 661). The Site lies within the
100-foot buffer zone under jurisdiction of the WPA for the
wetlands. Activities associated with selected Source
Control remedy within the 100-foot buffer zone are subject
to the applicable requirements of the above regulations and
will be met through the use of engineering controls. Durinq
excavation of DA-l and DA-2 near the wetland areas, sediment
traps and erosion control measures will be included as
wetland control protection measures. These measures will be
completely identified during the design phases of the
project. Coordination with the US Fish and Wildlife will
also be done to assure that the wetland natural resources
are protected.
(c) Action Specific ARARS
(1)
Action Specific ARARS List
Massachusetts Air Pollution Control Requlations - Applicable
310 CMR 6.00, 7.00, and 8.00 '
Kassachusetts Hazardous Waste Regulations, 310 CMR 30.00
These regulations are consistent with RCRA and provide for
the identification, handling, transport, and record keeping
of hazardous waste including:
310 CMR 30.500, 30.561, 30.590, 30.610 - 30.633,
30.640, 30.660 are relevant and appropriate
requirements
310 CMR 30.680 and 30.690 are applicable to material
transferred to containers and tanks
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.~.~
ROD DECISION SUHHARY
Salem Acres
Page 64
,
National Ambient Air Quality Standards (NAAQS) - 40 CFR
Part 50
NAAQS for Hazardous Air Pollutants - 40 CFR Part 61
utilize Best Available Control Technologies for
emissions.
Resource Conservation and Recovery Act (RCRA) - Applicable
RCRA Subtitle C, 40 CFR 260 - Regulates the Generation,
Transport, Excavation, Storage, Treatment and Disposal
of Hazardous Waste.
RCRA Part 264 requirements that are applicable "to this
remedial action involving on-site treatment, storage and
disposal of hazardous waste include standards for
preparedness and prevention (Subpart C)i contingency
plan and emergency procedures (Subpart D)i groundwater
protection (Subpart F)i and Closure and Post
Closure (Subpart G).
Hassachusetts Clean Water Act - Relevant and Appropriate
Surface Water Discharge Permit Requirements - Regulates
discharges to surface waters and any treatment works
associated with discharges. Applicable if lagoon water
~equires treatment and is discharged via a permitted
treatment facility to surface waters. - 314 CMR 3.00 and
4.00.
Pederal National Pollutant Discharge Elimination System/~
40 CFR Part ~22 and 125 Regulates discharges into surface
waters and requires permit.
(2) Action Specific ARARS
Federal Primary and Secondary National Ambient Air Quality
Standards (NAAQS) under the Clean Air Act (CAA) and
Massachusetts Air Pollution Regulations (310 CMR 6.00-8.00)
are action specific ARARs. The discussion of these
requirements is found above under section B. lea), Chemical
Specific ARARs. The in-place blending of the sludge with
fly ash, and the subsequent excavation of wastefrom the Site
will have siqnificant potential for dust and VOC generation.
Also grading of the soils and sludges will probably result
in dust and VOC generation. The Federal and State air
quality regulations would then serve as applicable action-
specific ARARs for excavation activities when fugitive dust
or particulate matter is generated. Massachusetts Ambient
Air Quality Standards (310 CMR 6.00) define a fugitive dust
" emission standard of 260 ug/m3. Control equipment are
available for fugitive dust control during remediation. Air
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ROD DECISION SUMMARY
Salem Acres
Page 65
,
treatment methods as an integral component of the
remediation technology if required. The need for and
dust, odor and VOC controls will be determined during
design phase of the pilot scale treatment test.
Under the Clean Water Act (CWA) 40 CFR ~22 and ~25 and
Massachusetts Surface Water Discharge Permit Requirements
(3~4 CMR 3.00) and Massachusetts Surface Water Quality
Standards (3~4 CMR 4.04, 3~~ CMR 4.06(2», substantive
permit requirements for discharges are relevant and
appropriate if any lagoon w~ter is treated and discharged to
surface waters via a permitted treatment facility. These
requirements include compli~nce with technology-based
standards, water quality criteria, and discharge monitoring
systems. Federal water quality standards will be met
through appropriate treatme~t systems such as carbon columns
and metals removal if required. As discussed above under
Chemical Specific ARARs, the'se regulations are ARARs and
will be met through treatmert and engineering controls.
use of
the
RCRA regulations for waste characteristics under 26~.2~ are
applicable to the Soil-Fixation process since the
wastesludges in the DA areas have been defined to be a RCRA
ignitable waste. Fly ash (and possibly other compounds to
be determined during bench scale and pilot tests) will be
mixed with the ignitable waste to result in a treated
soil/sludge that is non-ignitable under RCRA. The resultant
treated waste will require testing under RCRA 26~.2~ to
assure that the treatment has been effective in removing the
ignitable hazard. Other portions of RCRA that are
applicable to on-site treatrent, storage or disposal,
include RCRA Part 264 Standards for Operators of Hazardous
Waste Treatment Facilities. These standards will be
attained through the application of engineering controls and
will be identified during the design stages.
Massachusetts Hazardous Waste Regulations that pertain to
above ground storage containers and tanks used to treat or
store hazardous waste(3~0 Cl!R 30.680 and 30.690) are
applicable and will be met through engineering controls
including leak-proof enclosed storage containers if
required. Additional Massachusetts Hazardous Waste
Regulations that pertain to handling, storage, treatment and
disposal of hazardous waste on-site are relevant and
appropriate requirements and will be met through proper
design controls that will be identified during the design
stages.
The off-site disposal of wastes generated from the soil and
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ROD DECISION SnHKARY
Salem Acres
Page 66
meet all substantive Federal end State requirements
(administrative requirements ere not ARARs). The soil-
fixation process will result in waste that is no longer
hazardous waste; specifically, the treatment with fly ash
will render the waste non-toxi: and non-ignitable (to be
confirmed by specific tests u~jer RCRA at 40 CFR Section 261
Appendix II for toxicity and at 261.21 for iqnitability).
The off-site disposal will cc~ply with all RCRA Land
Disposal Requirements for hazardous waste listed because of
characteristics under 40 CFR 5:ction 261 Subpart C.
(d) To Be Considered (TBC)
The following policies, criteria, and quidance (among
others) are also to ~e considered (TBCs) during the
implementation of the remedial action:
American Conference of Governw9ntal Industrial Hygienists
(ACGIH)- Threshold Limit ?alue (TLV), Time Weighted
Average (TWA) and Short-Term Exposure Limit (STELs).
Clean Water Act (cw.1) - Federal Ambient Water Quality
Cri~eria (FAWQCs).
BPA Reference Doses (RfD) - Fc~ Non-carcinogens.
BPA Lifetime Health Advisories - For Certain Toxic
Chemicals.
EPA Risk Speci~ic Doses - For :arcinogens.
EPA Directive for Lead - OSWE~ Directive 9355.4-02.
Hassachusetts Allowable Ambier-t Limits (AALs) and Threshold
Effects Exposure Limits (TELs) Cited in Chemical Health
Effects Assessment Kethodology to Derive Ambient levels.
Massachusetts DEP, 1989
Hassachusetts Office of Research and Standards Drinking
Water Guidelines (ORSGLs).
Federal SDWA NPDWR 40 CPR 141 Proposed KOLs
Federal occupational Health and safety Act (OSHA; 29 CPR
section 1910.1000) for air contaminants
(TBC is included in ARARS description above)
Contingent Remedy - Alternative SC-2, RCRA capping
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ROD DECISION SUKMARY
Salem Acres
Page 6'
(a) Chemical specific ARARS
(1) Chemical Specific ARABS List
Kassachusetts Groundwater Quality standards - Applicable 314
CMR 6.00.
Kassachusetts Air Pollution control Regulations - Applicable
310 CMR 7.00
Federal Safe Drinking Water Act (SDWA) - Relevant and
Appropriate
National Primary Drinking Water Requlations (NPDWR) 40
CFR 141.
Maximum contaminant Levels (MCLs) and Maximum Contaminant
Level Goals (MCLG)
Kassachusetts Drinking Water Regulations - Relevant and
Appropriate. These regulations include Maximum contaminant
Levels (MMCLs). MMCLs for compounds detected at the Site
include Federal MCLs Adopted by DEP - 310 CMR 22.00
Clean Air Act (CAA) - Applicable
National Ambient Air Quality standards (NAAQS)- 40 CPR
Part 50.
NAAQS for Hazardous Air Pollutants - 40 CFR part 60
(2) Chemical specific ARABS
The groundwater aquifer at the Site is classified as a Class
I source of potable water under the Federal Groundwater
Protection Strategy and as Class I by the Commonwealth of
Massachusetts. While Maximum contaminant Levels (MCLs) and
Maximum contaminant Level Goals (MCLGs) promulgated under
the Federal Safe Drinking Water Act are not applicable to
groundwater, they are relevant and appropriate to
groundwater maintenance. Site groundwater presently attains
theMCL's. See 40 CFR 300.430(a) (iii) (F). ,
Massachusetts groundwater quality standards for Class I
groundwater issued in 314 CMR 6.00 are applicable
requirements for the site. The state drinking water
standards that are relevant and appropriate for groundwater
as a potential drinkinq water supply are the Massachusetts
Maximum contaminant Levels (MMCLs) issued under 310 CMR
22.00, which are the same as Federal MMCLs and MCLGs.
In addition to
and quidelines
based criteria
concentrations
the Federal and State requlatory standards
for drinking water and groundwater, risk-
are to be considered. These criteria include
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ROD DECISION SUHMARY
Salem Acres
Page 68
risk-specific doses based on carcinogenic Potency Factors
(CPFs) and standard exposure assumptions for the ingestion
of" drinking water. The contingent remedy Alternative 2,
RCRA Capping will maintain these ARARs by the application of
a RCRA subtitle C Cap that will be protective by preventing
migration of contaminants in groundwater.
Federal Primary and Secondary National Ambient Air Quality
Standards (NAAQS) under the Clean Air Act (CAA) exist for
emissions of sulfur oxides, carbon monoxide, ozone, nitrogen
oxides, lead and particulate matter (PM10). Generation of
fugitive dusts and air emissions from sediment excavation or
capping operations and soil/sediment consolidation and
treatment facilities (air and stabilization treatment
systems) are subject to NAAQS. Best available control
technologies will be utilized to promote and maintain public
health and welfare. Massachusetts air requlations include
Ambient Air Quality Standards (310 CMR 6.00), Air Pollution
Control Requlations (310 CMR 7.00) and requirements for the
Abatement of Episodic and Incidental Air Pollution
Emerge~cies (310 CMR 8.00). Certain provisions of 310 CMR
7.00 which require the best available emissions controls and
specify ambient air quality standards are applicable and
wiIl be met~ The remaining State standards for fugitive
emissions from excavation and consolidation, and the
substantive requirements will be met by the applicat~on of
foams and or other chemicals. The need for such controls
with the RCRA Subtitle C Cap option will be dependent upon
the amount of ~aterials that are moved for consolidation
prior to capping. These Federal and State air standards
will quide mitigation measures desiqned to control the
release of fugitive dust, particulate matter and VOCs during
excavations at the site under the contingent remedy.
(~)
Location specific ARABS
(1) Location Specific ARARS List
Massachusetts Wetlands Protection Act (WPA) Requlations -
Applicable - 100 foot buffer zone of wetlands is requlated
under WPA - 310 CMR 10.00.
Federal Executive Order 11990, Protection of Wetlands -
Applicable - These requlations require minimization of
wetland destruction.
Federal - Clean Water Act (~) - Applicable - Requirements
under these codes prohibit discharge of dredged or fill
material into wetlands - CWA Section 404 (b) (1); 40 CFR part
-------
ROD DECISION SUHKARY
Salem Acres
Page 69
,
(2) Location Specific ARABS
Both federal and state wetland laws and regulations (Clean
Water Act (CWA) 33 USC Section 404 (b) (1)., 33 CFR 320 to
330, and MADEP 310 CMR 10.00) and the Wetlands Executive
Order 11990 would be complied with under this option. Areas
immediately adjacent to the east ,north, and west of the
Site are wetlands under the Massachusetts Wetlands
Protection Act (WPA) Regulations (310 CMR 10.00). The Site
lies within the 100-foot buffer zone under jurisdiction of
the WPA for the wetlands. Activities associated with
selected source control remedy within the 100-foot buffer
zone are subject to the applicable requirements of the WPA
and will be met through the use of engineering controls.
During RCRA Capping at DA-1 and DA-2 near the wetland areas,
sediment traps, erosion control and other measures may be
required to protect wetlands. These measures will be
completely identified during the design phases of the
project. In order to prevent the RCRA Subtitle C Cap
encroachment into wetlands, concrete retaining walls at the
west and north side of DA-I and at the east side of DA-II .
will be required to protect wetlands and to provide side
slope stability for the RCRA Cap. Concrete retaining walls
will a~so be required in disposal areas SL-4 and SL-5 as
well as other areas to be determined during design phase to
provide for wetlands protection. Coordination with the US
Fish and Wildlife Agency will also be done to assure that
the remedy does not pose a threat to natural resources.
(c)
Action Specific ARABS
(1) Action Specific ARARS
Massachusetts Air Pollution Control Regulations - Applicable
310 CMR 7.01, 7.02 (2) (a), 7.06, 7.09, 7.10, and 7.18
Kassachusetts Hazardous Waste Requlations, Applicable
310 CMR 30.00 - These regulations are consistent with
RCRA and provide for the identification, handling,
transport, and record keeping of hazardous waste.
310 CMR 30.500, 30.561, 30.590, 30.610 - 30.633, 30.640,
30.660 are relevant and appropriate requirements'
310 CMR 30.680 and 30.690 are applicable to material
transferred into containers and tanks.
Clean Air Act (CAA) - Relevant and Appropriate
National Ambient Air Quality Standards (NAAQS) - 40 CFR
Part 50.
-------
or:; -- -
;:..~
ROD DECISION S~y
Salem Acres
Paqe 70
,
Resource Conservation and Recovery Act - Applicable
RCRA Subti~le C, 40 CFR 260 - Regulates the Generation
Transport, Excavation, Storaqe, Treatment and Disposal'of
Hazardous ft'aste.
RCRA Part 264 requirements that are applicable
appropriate to this remedial action involving on-site
trea~ent, storage and disposal of hazardous waste
include standards for preparedness and prevention
(Subpart C; i contingency plan and emergency procedures
(Subpart D)i groundwater protection (Subpart F)i closure
and post-c:osure requirements (Subpart G)i and landfills
(Subpart N} . -
Massachusetts Clean Water Act - Surface Water Discharge
Permit Requir~ents - Applicable - Regulates discharges to
surface waters and any treatment works associated with
discharges. ~pplicable if lagoon water requires treatment
and is discha=ged via a permitted treatment facility to
surface waters. - 314 CMR 3.00 and 4.00.
Federal Natio:al Pollutant Discharge Elimination System/~
40 CFR Part 124 and 125 Regulates discharges into surface
waters and re~ires permit.
(2) Action Specific ARABS
Federal Prima--y and Secondary National Ambient Air Quality
Standards (N~_~QS) under the Clean Air Act (CAA) and
Massachusetts air pollution regulations (310 CMR 6.00-8.00)
are action specific ARABs. The discussion of these
requirements ~s found above under Chemical Specific ARARs.
Alternative S~-2 may involve some waste consolidation prior
to actual RCFl~ Capping. The excavation of wastefrom one
area to anothe: will have significant potential for dust and
VOC generatio~. Also, grading of the soils and sludges will
probably resu!t in dust and VOC generation. The federal and
state air qua~ity regulations would then serve as applicable
action-specif~c ARARs for excavation activities when
fugitive dust or particulate matter is generated.
Massachusetts Ambient Air Quality Standards (310 CMR 6.00)
define a fugitive dust emission standard of 260 ug/m3.
Control equip~ent are available for fugitive dust control
during remedia~ion. Air quality standards for organics can
be met with vapor phase treatment as an integral component
of the remedia-:ion technology if required.
Under the Cle~ Water Act (CWA) and Massachusetts Surface
Water Dischar~e Permit Requirements (314 CMR 3.00) and
Massachusetts Surface Water Quality Standards (314 CMR 4.04,
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ROD DECISION SUHMARY
Salem Acres
Page 71
:II
source discharges are relevant and appropriate if any lagoon
water is present and requires treatment. Treatment may be
required to remove metals and organics prior to discharge.
If required, treatment methods may employ the use of carbon
columns, flocculation, filtration and other methods to be
determined during the design stage. These requirements
include compliance with technology-based standards, water
quality criteria, and discharge monitoring systems. Federal
water quality standards will be met through treatment and
testing. Treated lagoon water will be disposed of in a
local permitted treatment system.
RCRA regulations are relevant and appropriate since the
wastesludges have been defined to be a RCRA ignitable waste.
The portions of RCRA Subtitle Cthat are relevant and
appropriate to RCRA Capping include releases from solid
waste management units (Subpart F), closure and post-closure
requirements (Subpart G)j and landfills (Subpart N). The
contingent remedy provides a RCRA Subtitle C Cap which
covers the contaminated soils, and therefore meets the
closure requirements of 40 CFR 264.310(a) and 310 CMR 30.620
et seq. A post-closure monitoring plan that can be used to
monito~ the effectiveness of the RCRA Subtitle C Cap for the
protection of human health and the environment will also be
implemented including periodic monitoring as required by
SARA regulations (40 CFR 264.90-264, 109, and 319 CMR
30.660).
The Land Disposal .Restrictions (LDR) of the Hazardous and
Solid Waste Amendments of RCRA will not apply to the remedy.
EPA has determined that the movement of contaminated
materials for consolidation at the Site does not constitute
placement under the LDR. The contaminants of the soil areas
(SL-l, SL-2 SL-3) are contiguous to the DA areas and have
been caused by activities at the DA areas. Movement of
these soil areas to the DA areas therefore constitutes
"consolidation within the unit". Likewise,the soil areas at
SL-4 and SL-5 are contiguous with no clear separation
between SL-4 and SL-5 and movement of soils from SL-4 to SL-
5 constitutes "consolidation within the unit".
Both federal and state wetlands laws and regulations (Clean
Water Act (CWA) 33 U.S.C. 401(b) (1), 33 CFR 320 to 330, and
MADEP 310 CMR 10.00) and the Wetlands Executive Order 11990
are potentially applicable location-specific ARARs should
construction activities disturb any of the nearby wetlands.
These regulations control development activities within and
around designated wetland areas and require the minimization
of destruction, loss or degradation of wetlands. Compliance
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ROD DECISION SaMHARY
Salem Acres
Page 72
21
mitigation of any wetland impacts, although permits and
notification requirements do not apply. All Site
activities" would be carried out pursuant to OSHA standards
(29 CFR 1910 and 1926), which specify both safe working
procedures and the types of safety equipment to be used
during all remedial activities. Chemical specific ARARs for
groundwater and surface water will be met by RCRA Capping as
long as the RCRA Subtitle C Cap remains intact. RCRA
Subtitle C Cap integrity will be assured through a process
of Operational and Maintenance requirements. .
(d) To Be Considered
The following policies, criteria, and guidance (among.
others) will also be considered (TBCs) during the
implementation of the remedial action:
EPA Reference Doses CRfD) - For non-carcinogens.
EPA Lifetime Health Advisories - For certain toxic chemicals
EPA_Risk specific Doses - For carcinogens.
EPA Directive for Lead - OSWER Directive 9355.4-02.
Agency for Toxic Wastes and Disease Registry CATSDR).,
- For dioxins.
Massachusetts Allowable Ambient Limits CAALs) and Threshold
Effects Exposure.Limits (TELs).
Massachusetts Office of Research and Standards Drinking
Water Guidelines (ORSGLs).
c.
The Selected Remedial Action is Cost-Effeciive
1. Selected Remedy - SC-7B
In the Agency's judgment, the selected remedy is cost effective,
i.e., the remedy affords overall effectiveness proportional to
its costs. In selecting this remedy, once EPA identified
alternatives that are protective of human health and the
environment and that attain, or, as appropriate, waive ARARs, EPA
evaluated the overall effectiveness of each alternative by
assessing the relevant three criteria-long-term effectiveness and
permanence; reduction in toxicity, mobility, and volume through
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ROD DECISION SUMMARY
Salem Acres
paqe 73
relationship of the overall effectiveness of this re~edial
alternative was determined to be proportional to its costs.
costs of this remedial alternative are: .
The
COST COMPARISON OF SOaRCE CONTROL ALTERN1TIVES
ALTERN1TIVE Direct Capital $ 0 , H $ yr. $ Present
Worth
SC-l NO ACTION 0 21,500 330,000
SC-2 RCRA CAPPING 2,561,000 37,000 4,410,000
SC-3 INC INERAT I ON/
STABILIZATION 18,857,000 21,000 30,825,000
SC-4 THERMAL DESORPTION/
DECHLORINATION WITH
STABILIZATION 15,844,000 21,000 26,765,000
SC-5 SOLVENT EXTRACTION/
STABILIZATION 11,160,000 21,000 19,237,000
SC-6 VITRIFICATION 44,923,000 21,000 44,923,000
SC-7 IMMOBILIZATION 8,602,000 37,000 15,442,000
SC-7A IMMOBILIZATION/
OFF-SITE DISPOSAL 10,122,000 37,000 18,026,000
SC-7B SLUDGE FIXATION/
OFF-SITE DISPOSAL 6,056,000 21,000 9,123,000
The most expensive of the options is Alternative SC-6, In-Situ
Vitrification at $44,923,000 (not considered feasible because of
the potential for fire hazard) while the least expensive is the
No-Action Alternative SC-l which involves costs, of $330,000 for
qroundwater monitoring. Alternatives SC-3, andSC-4 involve
thermal decomposition of the organics followed by stabilization
for metals and cost $30,825,000 and $26,765,000 respectively.
Alternatives SC-3 and SC-4, are not considered cost effective in
lieu of the other available lower cost Alternatives SC-2, SC-S,
SC-7, SC-7A, and SC-7B that are as protective in removing the
site risk which is due to soil contact and/or ingestion.
Alternative Sc-s involves solvent extraction combined with
immobilization and costs $19,237,000. Due to potential problems
with implementation, Alternative SC-S is not as protective as the
remaining Alternatives, SC-7, SC-7A, SC-7B and SC-2, and also
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ROD DECISION SUMMARY
Salem Acres
Page 74
form of immobilization and cost between $15,000,000 and
$18,000,000.. Alternative SC-7B, soil fixation with fly ash is
also a form of immobilization and is estimated to cost about
$9,123,000. Alternative SC-7B provides for Site protection that
is similar or equal to Alternatives SC-7 and SC-7A, but costs
significantly less. Alternative SC-7B provides for removal of
wastes from the Site, offers a permanent Site solution at
$9,123,000 and would result in unlimited future Site use.
Additionally, under alternative. SC-7B the waste would undergo
further controls that are required by law at an off-site
permitted landfill. No other remedy provides the same level of
Site protectiveness and permanence at such a cost effective
price.
2. The Contingent Remedy - SC-2
The contingent remedy to SC-7B is Alternative SC-2, a RCRA
Subtitle C Cap at a cost of $4,410,000. Next to the No-Action
Alternative SC-1, the RCRA Subtitle C Cap is the lowest cost of
all the Alternatives, but it does not provide a permanent
solution or reduce Site related risks. Because implementation of
Alternative SC-2 would result in untreated waste remaining On-
site, SC-2 is not as permanent or as protective as the off-site
remedy under SC-7B. However, Alternative SC-2 does provide for
protectiveness because the Cap prevents contact with the .
underlying wastes and because the wastes on-site do not miqrate
in the qroundwater at levels that pose a risk above 1.0 x 10 -4
based upon average levels3. This has significance when
evaluating cost effectiveness, as the amount of risk reduction
attained by the RCRA Subtitle C Cap is similar to those options
that include treatment - Alternatives SC-3, SC-4, SC-5, SC-6 and
SC-7 and leave waste on-site. However, because there is no
treatment of waste with Alternative SC-2, the RCRA Subtitle C Cap
will require long-term monitoring and operation and maintenance
requirements, and Institutional Controls to assure its inteqrity.
Thus, the selected remedy of Alternative SC-7B, 'soil-fixation
with fly ash, with a contingent remedy for a RCRA Subtitle C Cap,
Alternative SC-2, is the most cost effective solution for the
Site.
D.
The Selected Remedy Utilizes Permanent Solutions and
Alternative Treatment or Resource Recovery Technologies to
the xaximum Extent Practicable.
3 For maximum values, three of 25 values for Antimony showed
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ROD DECISION SUMMARY
Salem Acres
Page 7S
Once the Agency identified those alternatives that attain or as
. . ,
appropr~ate, wa~ve ARARs and that are protective of human health
and the environment, EPA identified which alternative utilizes
permanent solutions and alternative treatment technologies or
resource recovery technologies to the maximum extent practicable.
This determination was made by deciding which one of the
identified alternatives provides the best balance of trade-offs
among alternatives in terms of: 1) long-term effectiveness and
permanence; 2) reduction of toxicity, mobility or volume through
treatment; 3) short-term effectiveness; 4) implementability; and
5) cost. The balancing test em~hasized long-term effectiveness
and permanence and the reduction of toxicity, mobility and volume
through treatment, and community and state acceptance. The
selec~ed remedy provides the best balance of trade-offs among the
alternatives.
1. Selected Remedy - SC-7B
The selected remedy of Soil-Fixation and off-site disposal
provides a solution that is cost effective, technically easy to
implement, and provides for a permanent solution to the Site by
removing all waste that presents a risk, and meets all ARARs.
This remedy results in a permanent on-site solution and attains
off-site permanence" through the Institutional Controls and
treatment (leachate controls and cappinq) required by regulations
to be provided by an off-site permitted landfill. No other
remedy provides the same level of Site protectiveness and
permanence at such a low cost. The remedy cost, except for SC-1,
no action, and SC-2, RCRA Cap, is the least expensive, yet most
Site protective of the Alternatives. The only other Alternative
that is provides comparable protectiveness by completely removing
waste(and associated Site risk) is Alternative SC-7A,
Immobilization with off-site disposal. However, Alternative SC-
7A is twice the cost of the selected remedy and would not provide
for any greater Site protectiveness.
The selected remedy is also one of the technically easiest to
implement and, except for SC-1, the NO-Action Alternative, can be
completed 12 months faster than Alternatives SC-7A or SC-7 and 24
months faster than Alternatives SC-3, SC-4, or SC-5.
(2) The Contingent Remedy - SC-2
The contingent remedy, the RCRA Subtitle C Capping option, also
provides for a cost effective solution in addressing the primary
Site risk of contact/ingestion of Site soils and sludges. The
RCRA Subtitle C Cap is cost effective and except for SC-1 is the
least expensive alternative to implement. The RCRA Subtitle C
Cap is based upon proven technology, one of the fastest
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ROD DECXSION SUHKARY
Salem Acres
Page 76
short-term requirements. However, Alternative SC-2 does not
directly reduce toxicity, volume, or mobility of the contaminants
or provide for treatment of the wastes.
Even though the RCRA Subtitle C Cap does not provide for direct
treatment, when compared to most alternatives, (except for SC-7A
and SC-7B which are the most protective because of the associated
off-site waste removal) Alternative SC-2 does provide for similar
ris~ reduction by precluding contact with on-site contaminated
soils and wastes in the lagoons and in the contaminated soil
areas. As evidence of this risk reduction, the High Density
Polyethylene Cap which presently covers the lagoon areas at DA-1
and at DA-2 has been effective in mitigating groundwater
'contamination (see RI/FS results and Administrative Record) since
it was installed as a temporary solution under an EPA Emergency
Removal Action in 1987. Also, the contingent remedy requires a
series of Institutional Controls and monitoring requirements that
provide for RCRA Subtitle C Cap maintenance and long-term
protectiveness.
Additionally, in the event that groundwater monitoring shows an
elevated risk (above 1 x 10 -4 based on average contaminant
concentrations for COC) a "Site Assessment" to determine
additional controls will be initiated by EPA. These additional
controls may be one or more of the following: Institutional
Controls, additional monitoring requirements, source treatment,
migration control treatment such as a pump and treat options,
and/or other additional controls that are determined to be
appropriate by the EPA Regional Administrator. Although this
requirement adds to the long-term permanence of the contingent
remedy, Alternative SC-2 does not provide for a permanent Site
solution as does Alternative SC-7B and will always require long-
term monitoring, inspections, and operational and maintenance to
maintain the protectiveness of the RCRA Cap.
The Selected Remedy, Se-7S, Satisfies the Preference for
Treatment Which permanently and Significantly reduces the
Toxicity, Mobility or Volume of the Hazardous Wastes as a
Principal Element
The principal element of the selected remedy SC-7B is the
treatment of on-site sludges and soils above Soil Cleanup Levels
which includes at a minimum, the removal of the DA treated
materials, along with the non-RCRA wastes from the SL areas, to
an off-site permitted landfill. This remedy addresses the health
risk at the Site which results from potential contact and
ingestion of contaminated soils and sludges. The Selected Remedy
satisfies the statutory preference for treatment of the RCRA
hazardous wastes in the lagoons as a principal element by soil-
fixation and off-site disposal in a permitted landfill.
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ROD DECISION SUMMARY
Salem Acres
Page 77
The contingent Remedy, Alternative SC-2, Does Not Satisfy
the Preference for Treatment as the principal Element
In the event that the selected remedy SC-7B, Soil Fixation with
off-site disposal is not implementable, at a minimum, a RCRA
Subtitle C Cap will be applied over the waste areas at DA-1 and
DA-2 and at SL-3, SL-4, SL-S, SL-6, SL-12 , and SL-13 and at all
other areas of soil/sludges that are found above Soil Cleanup
Levels during soil delineation desiqn studies. The RCRA Subtitle
C Cap does not satisfy the preference for treatment of the wastes
as the principal element. Because Alternative SC-2 does not
satisfY the statutorv ~reference for treatment. EPA will not
institute this Alternative unless the selected remedy SC-7B
cannot be imDlemented.
E.2
However,the RCRA Subtitle C Cap does control the risk at the site
which results from contact with, and ingestion of contaminated
soils and lagoon sludges. Moreover, despite the fact that the
waste has been on-site since the mid 1940's and exposed to the
potential for migration, the RI data demonstrated that there is
not an off-site migration of contaminants that pose an elevated
risk and additionally that on-site groundwater is not highly
contaminated. The average risk associated with drinking
groundwater, eating fish from the nearby wetlands and swimming is
within EPA acceptable limits of between 1 x 10-4 and 1 x 10-6.
This is due to the fact that the primary waste contaminants on
Site, metals and CPAH, are not highly soluble in water. This has
siqnificance in evaluating the appropriate solution to the Site.
The RCRA Capping Alternative with effective Institutional
Controls and monitoring provides for an effective Site remedy
even though it is not considered treatment.
Additionally, through a system of Institutional Controls, the
long-term integrity of the RCRA Subtitle C Cap can be maintained.
These Institutional Controls include long-term monitoring,
fencing, deed restrictions, and periodic site inspections of the
site. In the event that the monitoring of groundwater
demonstrates that contaminants are migrating in concentrations
that present a risk above 1 x 10 -4 or are above theMCLs for
drinking water, further controls and treatment at the Site will
be evaluated. The additional controls that may be implemented
include one or more of the following: additional source controls,
migration controls, additional monitoring requirements and
Institutional Controls. These additional requirements add to the
protectiveness of the and for the above reasons EPA has
determined that the RCRA Subtitle C CAP will provide adequate
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ROD DECISION SUMMARY
Sal.tm Acres
Page 78
XII. DOCUMENTATION OF NO SIGNIFICANT CHANGES
EPA presented a proposed plan (preferred alternative) for
rem~!diation of the Site on JUDe 24, 1992. The preferred remedy
SC-.B and the contingent remedy SC-2 contain no significant
cha:\ges from those recommended in the proposed plan.
XII:'. STATE ROLE
The Massachusetts Department of Environmental Protection has
rev:.ewed the various alternatives and has indicated its support
for the selected remedy. The State has also reviewed the
RemE.dial Investigation, Risk Assessment and Feasibility Study to
detE.rmine if the selected remedy is in compliance with applicable
or !elevant and appropriate State Environmental laws and
regt.lations. The State of Massachusetts concurs with the
selEcted remedy for the Salem Acres Site. A copy of the
dec;aration of concurrence letter is attached as Appendix D.
-------
APPENDICES
Figure.I. . . . . . . . . . . . . . . . . . . . . . . Appendix A
Tables . . . . . . . . . . . . . . . . . . . . . . . . Appendix B
ARAR T:4bles. . . . . . . . . . . . . . . . . . . . Appendix C
Common9.real th or Hassachusetts Letter of Concurrence. . Appendix D
Respon~;i veness S1mn11'8 ry . . . . . . . . . . . . . . . . Appendix B
-------
-------
E ~ ~
APPENDIX - A
LIS'!' OP PIGtmES
No.
'l'itle
1.
Locus Hap
2.
Site ~ ap
3 A.
8i te Eamplinq Hap-Debris, We1:1ands
8i1:e Eamplinq Hap-Surface, Groundwa1:er
3 B.
.c.
"DA" taqooD Samplinq Hap
Loca1:ion
A-1
A-2
A-3
A-.c
-------
/-.::J-'" ~.
BASE MAP IS A PORTION OF THE FOU.OWING USGS 7.5 x 15' SERrES QUACRANGlES:~
l YNN,.MA, 1985; SALEM, MA, 1985
MASS
o 1000 2000 3000 feet ", ': \ \
I ' ! I " .. "",~
....:,."'"..':"," "....." ."""::, ;~ \ ACRA"-' =' --'-'C"
-------
./
.
.
)
~"'--'_.
"»/ ~
.........
............... "e
:Figure 2.
Salem Acres Site Map
'/1, '. l'3 ~
(~A'7 / ~ "
. / G...
"
,
.......
~t4.
",
/
/'
/
WA-,
to
Swa~tt
Braok
Not to Scale
'.....
@ WasI8 Lagoons
<::> CisaosaJ Areas (fenced)
--- Site Boundary
o WA.' W8l1andAt8a No.1
o DeOris Piles
1St..'! SoilAteas InV8Sligat8d
~ Cit8dion ot Flow
O Antas of GntalHt
ContaminatIOn
-------
:J iguTe 3 JI..
Salem Acres Sampling Locations
fA'7 ) (p.,,,
'. ./ SL"20
SAM!'\.: OESIGNAT10NS
o MonitcMg Well
SSoF. SedUnent-ApnVAugust1989
ASMo1 e Air Monltering - ApnVMay.AususI19S;
SW.A 0 Surface Water-ApriVAugust 1989
~~. SedimenllSurface WaUlt-April1989
S\'-1-1!1 Test Pit.Soil- MardlJS~tember 1989
SR-70 Sediment R~Ie-S~l8maer 1990
e F"tShITutlle or W.aandlPlant - June 19a9
SFM-1 A Surface Water Flow Measurement-
May/June t989
S\.fJ)
/
./
/
./
./. SSo7
SW-7
. --e. \.L/ --.;;
-- '»l /"~
WA-3 /'
'.. S~.-
.. \ sw-a
<>
~\
tD
SWampscatt
Brook
SFM-4..
Not to Scale
Nate: Sample Lccatians
are Appraximat9
@ Waste Lagoons
<::> Disposal Areas (fenced)
--- Site Boundary
t":)
--." WA-1 WetiandAntaNo. 1
o Debris Piles
Is\.-,! Soil Areas Investigated
~ Dir8c:tion of Flow
O Areas of Grealest
C=nlaminaDon
-------
.i *'::J -, c:. :)'.0.
Salem Acres Sampling Locations
" SL.~'
"
Nete: Sample Locaticr:s are Apprexl~ate
'"
"
,
WA-4
S;-M SW-B
. SL..2..&
'»f
SL.-2-1 5
"-
"
ASM"" e
C
\
\
,
SAMPLE DESIGNATIONS
o Monitoring Weil
SS-F .
Sedmnent-ApriVAugust1989
AU Monitonng - AprillMaytAugust 1989
Surface Water-~prillAugust 1989
SedimenflSurtaca Water-April 1989
SL-1-1 sa
SR-70
e
Test Pit /Soil- Man:IIISepterntler 1989
Sediment Resample-Septemtler t990
FlSIVTunle or WellandlPlant . June t989
ASM-1 e
SW-A e
55-1.
SW-1
SFM-1 A Surface WaI8r Flow Measurement ~aytJun. t989
Seurce: Adapted from Figure Ne. 6. Salem Acres RIIFS. Maguire Group. Inc.
Not to Scale
@ Wast. Lagoons
<:> Cis!losaJ At8as (htnceG)
--- Site Boundary
9 WA.t Weiland Area NO.1
o Debris Piles
ISL-tl Soil Areas 11MIStigat8d
~ Cintdion ot Flow
O Areas 0' Greates:
Contaminallon
-------
..
!rtq",.,~ 4.
Disposal Area (DA) Sampling Locations.
w
G
"'--0"
W \AI
\it
\)/
D.' c., '
DA.1 .
\J,/ \J,/ .. .
2619 1E
D.S
w . c.S
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\)/
w
"'"
\J,/
ca'UIW.t
MW.t8R
No, '0 Seals
Nole: Sampleloc811ons a,e App,oxlmale
.
8.0
.
A.a
SOIl'CO: AcI:I,IIucI "om fI!Juro Nu. 5, 5:1'uIII A':ro!l 'tllf S
MaUlli,e Group, 'nc. '
"*-*" Ol!lpollnl A/ono Cloneudl
.
Jacobi Sampling LocatlonlNumber
o Manllarlng Well Locations
~~
Wlllland Arens
~ 1 nlloolllllll"III111""I
. ePA Snmpllng l.acollonlNllmbnr
- - ficin" 01 "onll'TIIIII
-------
upmm~ - II - '1'DLBS
-------
. . - ,.,' ,- - .. '.- .- -... ,
2
APPENDIX - B
LIST OJ' TABLES
.0.
Title
Appendix B
1. sludge Levels DA-1 Lagoons B-1
2. Sludge Levels DA-2 Lagoons B-2
3. Soil Levels - SL-1 B-3
4. Soil z.eveJ.s - SL-2 B-4
5. Soil Levels - SL-3 B-S
6. Soil Levels - 81.-4 B-'
7. Soil Levels - 81.-5 B-7
8. site Risk Tables B-8
I.. Ground water S~-~ Da1:& B-9
10. surtace Water S"--?Y Table B-10
-------
.
I FRACTJON I PARAMETC~ I 11 SAMPLES I 11 OETECTS : AVG CONCI MAX CONC
VOCs Metnylene C:~loriae 17 16 7 .SSE ~OO 1.10E-01
[mg/kg] AcetCnB 20 15 1.94E+01 5.10E-i-01
nns-1,2-0ichlorceU'lene 20 4 6.30E+00 1.20E~01
2-e~ane 20 0 NO NO
Trichlorcethene 20 6 4.03E-i-00 1.10e~01
Benzene 12 7 2.24E +00 3.90E ~OO
TetraChloroethene 20 6 5.15E+00 1.3OE~01
Toluene 7 6 3.78E+01 8.70E-i-01
Etnybnzene 7 2 4.95E+01 5.aOE~01
TOtal Xvtenes 7 6 5.22:+02 1.105-03
Semi-VOCs Nopnthalene 'Zl 8 6.05E+02 2.005-i-03
[mg/kg] 2-MeEhytnapmhaiene 'Zl 6 6.3:2:+02 1.60E+03
Fiucnne 'Zl 2 2.30E+01 2.605+01
4-NiUaaniIine 'Zl 1 2.80E+01 2.805-01
N-Nitrosodiphenylamine 'Z/ 1 3.40E-i-01 3.4O=~01
pnenarlhrene 'Zl 3 3.57E+01 3.80E-i-01
F"~ Z1 1 9.50E+OC 9.50E+00
Pvrene 'Zl 1 1.3OE+01 1.3OE+01
bis(2 -ettyltlexyl) phtnalaZS 'Zl 2 4.69E+01 8.70E+01
Oi-n-oetyI.-4ltt<e 'Zl 0 NO Nt)
Senzo (b) F'auoranthene 'Zl 0 NO NO
Benzo lk) Fuoranthene 'Zl 0 NO NO
OioxinsiFurans 2.3.7.8- TCeO 5auivalem rue/kal 5 51 4.135+00 I 8."5+00
Pesticides! 4,4' -ODE I 19 1 I 1.30E-01 I 1.305-01
PCBs ..4.4' -000 19 2. 1.0aE+00 1.505+00
fme/ke1 Aroclor 1254 ~ I 19 2' 3.6aE~00 I 6.405+00
Meats AJurniUn 20 20, 2.3~e : 04 8.~
[mglkgJ Arseni: 20 2 2.55:+01 3.005+01
Barium '20 19 3.15E+02 9.405+02
.
Cadmium 20 0 NO NO
CalciJm 20 20 1 .2SE +04 3ZS5+04
Chrcmium 20 17 7.01E+02 1.78E+03
Copper 20 4 6.BSE+01 1.17:+02
Iron 20 20 1.115+04 5.ooE+04
Lead 20 4 1.52E+02 2.36E+02
Magnesium 20 13 3.27E+03 7.71E+03
Manganese 2D ' 13 3.32E+02 7.85E+02
Mercurv 20 0 NO NO
Sodium 20 13 1.305+04 3.205+04
Tanium 20 19 2.50E+03 9.~E+03
Zonc 20 20 1.705+02 6.105+02
II'\C u:: ,
SLUDGE CONTAMINATION LEVELS. CA-1 LAGOONS
Nola: (1) UD1iI&ed aaa/!MS wen: 10& deUI:UII iDlluciCC samples WID 1111 oC die lICOoaa. (%) NO - No, clCtcacd (i.c.. ~Iow umplC
-------
.. . - ..-- .- .. .
.
FRACTlON I PARAMETC~ I - SAMPLES I # DETECTS I AVG CONCI MAX CONC
VOCs MeU'lylene cnlaride 6 21 4.28E+01. 7.8CE~01
[mg/kg] AcetCne 12 1 5.60E-02 5.60e-02
tranS-1.2-0icnlaroe~ene 12 0 NO NO
2-Bwanane 12 1 2.00E+02 2.00E~02
Trict1loroetnene 12 0 NO NO
Benzene 12 0 NO NO
Tetra:nloroetnene 12 0 NO NO
Toluene 12 1 1.3OE+01 1.3OE+01
Ethyt)enzene 12 9 1.75E+02 2.80E+02
TOtal xvtenes 12 9 4.575+02 8.10E+02
Semi-VOCs NapnnaJene 18 11 2.21E+02 1.20E+03
[mg/kg] 2-ME!U'\ytnaph~alene 18 5 7.295+01 1.60E+02
Fluorene 18 0 NO NO
4-Nitoraniline 18 0 NO I NO
N-NitroSodipt1e~ 18 .2 ~+01 4.4OE+01
Phenantt1rene 18 1 2.3OE+00 2.3OE+00
Fluoramtlene 18 2 2.4OE+00 2.4OE+00
Pvrene 18 0 NO NO
bis(2-enylhexyl)~ 18 6 6.81E+01 2.105+00
Oi-n-octytph1halD 18 1 s.aaE+OC s.acE+OC
Senzc(b) FUcnmnerw 18 2 2.STE+01 5.505+01
Benzolk\F1uora'ltt'lene 18 2 2.S7E+01 5.505+01
Oioxins/Furans 12.3.7.8- TCOD Eouivaent rue/ko11 31 31 8.97E+00 I 2. 105+01
Pesticides! 4,4'-COe 1 :1 ~I NO I NO
PCBs - 4.4'-000 NO NO
I rmoJlcc1 Arodor 1254 31 31 3.91E+00 I 5.90E+00
U8ta1s AIumiWm 12 1.2 1.11£+04 S.1S5+04
[mglkgJ Arseni: 12 0 NO NO
Barium 12 12 3.3OE+02 6.60=+02
Cadmium . 12 1 1.70E+01 1.70E+01
CalciJm 12 12 1.41E+04 1.92:+04
Chromium 12 12 1.03£+03 3.44C+03
Copper 12 3 7.235+01 1.04E+02
Iron 12 12 4.48E+03 2.095+04
Lead 12 6 1.52£+02 2.695+02
Magnesium 12 3 3._+03 4.655+03
Manganese 12 4 2.741:+02 4.79E+02
,
Mercurv 12 2 5.7SE-01 8.50E-01
Sodium 12 3 1.40£+04 2.04E+04
Tanium 12 9 1.57E+03 4.2SE+C3
Zinc 12 . 12 1.9SE+02 4.635+02
SLUDGE CONTAMINAT10N LEVELS' DA-2 LAGOONS
...~- -
Noaa: (1) UlWI&cdaulylcllW8'UO&dcIII:UIS iaaWpalllpla ravaaayoClllc1lpGlll. (%)IIID- NoUI~== (~lIdGwauaptc
-------
.
'FRACTION , PARAM~ I # SAMPt.ES 1 # CETECTS I AVG CONCI MAX CONC
VOQa MeC'1y18n8 ChJona8 1Dj 0 2.T1E-Q21 NO
Im~gJ Ac81cnl 1Q 1 ~54E-02 1.soE-02
1.1.1-"T~.. U) 0 5.A3:-Q3 ND
Be. ... .. 10 0 5.43E-C3 ND
Teuene 10 0 S..c3E-03 NO
~ 10 0 £-43E--.Q3 NO
"Teal Xvten8s 10 0 5.~-03 NO
Seml-voCa Benzyl ai:ChOI 10 0 2.17E-01 NO
~ 2~8If1,1pl-...A . "III ' 2.11E-01 NO
4-MC1ytph8noI 10 0 2.17E-01 NO
BenzoC add 10 0 1._+00 NO
~aJen8 10 2 2.04C-':J1 1.9OE-01
2-M~ 10 1 2.C3E-~1 S.9OE-02
Ckn8U'IyI ptUr\aIaI8 10 0 2.17E-"1 NO
Ac8napmnyIen8 10 2 1.9OE-11 6.8CE-Q2
~ '0 2 ,.sse-~1 '1.'~
C~ 10 2 2.04C-,)1 1.7tE-01
CiInnyt pnrn8:D 10 0 2.17E-!J1 NO
FUnn8 10 2 2.07E-)1 1.7CE-01
N-~ 10 0 2.17E-.J1 NO
~. 10 0 2.17E-:rt NO
'Ph8narlnNM 10 ~ So 1SE-:1 1.9CE+OO
Amnra:en8 10 2 2.Z2E-:1 2.2CE-01
CI-n-tuyt pnrn8:D 10 3 3.C9E-~'1 6.30&-01
A.o._~ 10 ~ S.97E~1 2.OCE+OO
Pyrw18 10 ~ S.3SE-:1 1.7CE+OO
BuM bInzvf 10 0 2.17E-G1 NO
B-=(~. 10 ~ 3.D9E-::" 7 .2JE-01
0Irysen. 10 4 3..2fr"c-':1 7.soe-o,
tXs (2-E!h)t18xyf) phIhaiD . 1Ct. 0 ;'171:-U' NO
B-= (b) FUoaallS".8l8 10 ~ ~.43E-01 1.2DE+OO
Benzo tk} F1JonIr'IIttnt 10 ~ ~.43E-01 1.2Ce+OO
B8nzc:I (a) pyntn8 10 ~ 2.83S-01 6.2CE-01
IndInO(1.2.~pyr8n8 10 ~ 2.3i'E-01 ~.7CE-01
CIb8nzc(aJ1)aruMIc8nI . 10 3 1.75E-o t 1.4CE-Q1
I
Benzc(o.h~1 10 4 2.21E-01 4.0CE-G1
P8Cicici181 Endcsultan I 10 q 5.29E-03 NO
Pea. ~,4'-CC& m D 1.QSE-0.2 NO
{n9'k;J ~4'-cctI 10 0' 1.DSE-C2 NO
~.4' -COT 10 0 1.06E-02 ND
-: Aroctor 1250 t 10 01 1.05C-01 ND
. TABLE J
-------
it
.
FRACTION I P ARAMETE~I:# SAMPU:S I :# OETECTS I AVG CONC: MA;& CONC
MetaJs Ak;mnum 8 8 5.92:+03 9.~ 4E~03
(mglkg) Arseni: 8 8 1.S6E +00 3.. O£~OO
Barium S 8 1.67E+01 4: :eE~01
Berylium S 8 4.09£-01 e: IOE-01
Ca~mium 8 0 6.06E-01 NO
CalciJm 8 8 4.98£+03 I Z. jSE~04
C:vcmium 8 4 6.13£+00 1 . aaE~01
Cobalt 8 8 4.71£+00 1. )QE~01
Copper 8 8 1.12:+01 ,.36£+01
lren 8 8 1.04E+04 1 325 ~04
Lead 8 8 3.08£+01 \ 1 52E~02
Magnesium 8 8 1.81£+03 Z 16E+03
Manganese 8 8 124£+02\ 2 6oe~02
Uercury 8 1 S.s3E-02 1 0DE-C1
Nickel 8 5 1.71£+01 \ ~ Q6C-02
pOtaSSium 8 5 2.63E+02 \ . .6CE +02
SeleniJm e 1 2.46E-01 : .8oe-01
Silver 8 C &,06E-O'\ NO
Sodium 8 0 3.63£+00 NO
ThaJrum 8 0 2.421:-01 NO
Vanadium I 8 :\ 1.73E+01 \ : ..20E+01
Zinc 8 5.9OE+01 .59E+02
Cvanide (fetaO I 81 01 1.51E-01: NO
T AS LE 3
SOIL CONTAMINATtON LEVELS. 'SL-1
Nous: (1} UDlis&cdau!yICS were DOt~ ill aoilsamples frolD'ay oHbc IiVt soil'" (1) NO . Not cIctCCICd (i.c.. bdowsa~, c
cIcSciCIiDD lilllit) ill all samplcl ,",m. soil area. N". Not aaaIyud or aulylC rcjcacd durillc daD validatioD.
.
1
-------
FRACTION
VOCs
(mWk9I
Semi- VOCs
(mWkg]
.
Pesticides!
PCB.
[mglkgJ
pg 1 of 2
. "-- ...... ...
SOIL CONTAMINATION LEVELS: SL-2
I PARAMETER
Me:r.ylene Cnlonde
Acetene
1,1,1- Trichlorcernane
Benzene
TOluene
E:hyt)enzene
TOtal Xvlenes
Benzyt alconoJ
2-MerhyfphenoJ
4-Methylphenol
Benzoic acid
Nactmalene
2-Methylnaptunalene
Dimett¥ pt'nnaIare
Acenapntnyfene
Acer.apntnene
OibenzOfuran
Oie1:'lyl pntnalate
Fluorene
N-Nftrcscdil21enytamine
HexachIorcbenzene
Phenantnrene
AmtIracene
Oi-n-butyf phtnalate
FJuoramnene
Pyrene
ButYl benzvt ~a/ate
Benzc(a)anlMilcene
Chrysene
bis (2-Ett'lylheXyl) phthalate
Benzo (b) Fluorantnene
Benzc (1c) Fklorantt1ene
Banzo (a) pyrene
IndenO(1.2.3-cd)pyrene
o ibenzo(a,h)antt1racene
Benzo(a.h.Ooervene
Endasulfan I
4,4' -ODE
4,4'-DOO
4.4' -t)CT
Aroclor 1260
I # SAMPLES I
3
3
3
3
3
3
3
5
5
5
5
5
5
5
5
5
5
5
5
5
5
5
5
5
5
5
5
S
5
5
5
5
5
5
5
5
5
5
5
5
51
# OETECTS I AVG CONC: MAX CONC
o 2.925-02 NO
o 2.925-02 NO
o 5.83&-03 NO
o 5.83E-03 NO
o 5.83&-03 ~;O I
o 5.83E-03 ~;.') I!
o 5.B3E-03 N ~
o 2.60E-01 N')I
o 2.SOE-01 ~; )
o 2.60E-01 N.)
1 1.71E+00 3.2~ :+00
o 2.60E-01 N: J
o 2.60E-01 N. )
o 2.6OE-01 Nf)
o 2.60E-01 r-.:= I
o 2.60E-01 :-":i I
o 2.60E-01 Nt)
1 2.21E-01 5.=C:~-02
o 2.60E-01 N: t
o 2.6DE-01 Nil
o 2.60E-01 N~ .
4 1.125-01 9 "":-02
.......~
o 2.50E-01 Ni
o 2.60E-01 M
4 1.5SE-01 1.e::'-01
4 1.525-01 1.6':i .-01
o 2.50E-01 NC
3 1.s1S-01 7.1:! -02
4 1.1SE-01 1.0::, -01
2 1.75=-01 6.5r;~ -02
4 1.48E-01 1.10: -01
4 1.48E-01 1.7:, ~
4 1.06E-01 e.sa~ -02
1 2.29E-01 7.90: -02
o 2.60E-01 I\;C;
1 2.2BE-01 7.4C:-02
o 9.20E-03 N~
o 1.84E-02 NO
o 1.&4E-02 NO
a 1.B4E-02 ND
-------
.. - ._- .
. -. ... -.... ..~. ..__..
F"ACTION I PARAMEiCR I # SAMPLSS I # DETECTS I AVG CONC; MAX CONC
Metats Alumnum 4 4 1.1SE+04 1.29E ~O~
[mg/kg] Arsenic 4 4 3.85E+00 4.40E~CO
Barium 4 4 S.44C+01 7.47E+01
BeryflUm 4 4 6.Q3E-01 8.10E-01
Cadmium 4 0 S.63E-01 ND'
Calcum 4 4 2.S6E+03 5.06E+0:3
Chromium 4 4 1.46E+01 2.00E~01
Coed 4 4 9.2SC+OO 1.21E+01
Copper 4 2 1.95E+01 6.55E+01
Iron 4 4 2.S6E+04 4.17E+04
Lead 4 4 1.22:+02 3.27E +02
Magnesium 4 4 1.62:+03 2.51E+03
Manganese 4 4 4.SSE+02 S.41E+02
MeraJry 4 2 . 2.39E-01 7.COE-0'
Nickel 4 4 1.52E+O' 3.46C+O'
POtassium 4 4 3.SSE+C2 6.53E ~02
SeJenum 4 4 5.C8E-01 S.2Ce-01
Silver 4 C S.63E-01 ND
Sodium 4 0 2.0aE+02 NO
'ThaIlum 4 0 2.82:-01 NO
Vanadium I 4 4 3.95E+01 I 4.61E+01
Zinc 4 4 7.60E+01 1.29E-02
Cvanide (TotaO I 41 31 6.6SE-01 I 1.20E~OO
TABLE 4
SOIL CONTAMINATION LEVELS: SL-2
NeIlS: (1) t1~ uaJyla were 1101 deleiCUd iuoilampJa flam any o( USe rrc 1Oilaaaa. (%) ND . Not deIecaS (i.c.. betow sa.
dacaioD Ii=) ill aU samples hm a soil area. JiIIA - Not aaaJyzaS or ualyu: rcjcr:Icd cluriIIl cIata ~
-------
.
FRACTION I PARAMEiCR . I # SAMPLES I # DETECTS I AVG CONC I MAX CONC
voca Mernylene CNonae 1S 01 9.3SE-01 NO
[mg/kg) AcetOne 1S ~I 9.35E-01 2.80E-01
1 t 1 t 1- Trichloraernane 15 1.S8E-01 NO
Benzene 15 1.S8E -01 NO
Toluene 15 8 3.SSE-01 2.80E~00
Ethyl)enzene 15 4 7.15E-01 5.S0E+00
iotal Xvlenes 15 8 S.14E~00 4.10E~01
Semi- VOCS Benzyl aleonol 15 0 1.125+01 NO
[mg/kg) 2-Metr'lylphenol 15 0 1.12:+01 NO
4-Mmnyl~henal 15 1 1.125+01 1.00E-01
Benzoic acid 15 0 5.S2:+01 NO
NactmaJene 15 14 2.56E+01 2.4OE+02
2-Mett'lytnaptunalene 15 10 I 3.41E+01 4.10E+02
Oimetnyl pruhaIat8 15 1 1.12:+01 5.30E-02
Acenapt:tnyJene 1S Q 1.12:+01 Nt)
Ace~tnene 15 1 1.125+01 5.S0E-01
Oibenzofulan 15 1 1.13£+01 6.00E-01
Oietnyl ~ntnaJate 15 2 '.'25~01 9.9OE-02
Fluorene 15 1 1.13E+01 7.4OE-01
N-~ 15 0 1.12E~01 NO
I Hexachlorabenzene 15 0 1.125+01 NO
Phenantrirene 15 11 1.125+01 S.10E+OO
Antnra:ene 15 1 1.13E~01 1.50E+00
Oi-n-butyf pmnalate 15 10 1.06E+01 4.4OE+00
Fluorantnene 15 7 1.13E+01 3.S0E+00
Pyrena 15 7 1.13E+01 " 4.00E+00
BUIVt bInZvf ~ 15 1 '.12:+0' 1.2DE-01
Senza(a)anthra:ene 1S 7 1.11E+01 1.90:+00
Chrysene 15 7 1.11E+01 "1.9OE+00
bis (2-Ett'lylhexYt) ~htnaJate 15 8 1.125+01. 2.30: +00
Senzo (b) Ftuorantnene 15 7 1.125~01 2.4OE~00
Senzo (1<) Fuoramnene 15 7 1.125+01 2.4OE+00
Benzo (a) pyrene 1S 5 1.13E~01 1.4OE+OO
Indeno(1.2.3-cd)pyrene 15 5 1.125+01 6.70E-01
Oibenzo(aJt)amhracene 15 :, 1.125+01 1.9OE-01
Benzo(c.h.i\aervJene 15 1.125+01 2.60E-01
PeSticidaS/ Endcsulfan I 1S I 1 1.09E-02 1.00E -02
PCBs 4,4' -ODe 15 1 2.12:-02 1.10E-02
ImglkgJ 4,4'-000 15 2 2.70E-02 6.50E-02
4.4'-OOT 15 0 2.11E-02 NO
Aroclor 1250 I 151 131 3.99E-01 I 2.60E~OO
, 1'\0 &..C. :I
SOIL CONTAMINATION LEVELS' SL-3
-------
.. .. .....- ....._.- .-.- -- .
FRACTION I PARAMETC::t I # SAMPU:S I # DETECTS I AVG CONC: MAX CONC
Metals Alumnum 13 13 8.56E.,.03 1.99E.,.04
[mg/kg] Arseni: 13 13 2.72:+00 S.OOE +00
Barium 13 13 1.71E+02 7.96E+02
.
BeryUium 13 . 11 5.30E-01 1.30E+OO
Cal:mium 13 10 1.13E+OO 1.80E+OO
Calc:iJm 13 13 7.42E+03 1.S3E+04
Chromium 13 13 5.85=+02 1.87E+03
Ccbal 13 11 4.78E+00 1.00E+01
Co;: per 13 11 2.2SE+01 3.90E+01
Iron 13 13 1.29E+04 3.07E+04
Lead 13 13 7.75:+01 1.60E+02
Magnesium 13 13 2.19E+C3 4.78E+03
Manganese 13 12 1.36C+02 4.01E+02
Mercny '3 " S.57S-01 1.5CE+CC
Nickel 13 9 1.31E+01 7.60E+01
PetaSSium 13 6 3.S4E+02 1.29E+C3
Se!eniJm '3 2 3.SOE-01 6.00E-01
Silver 13 3 9.10E-01 2.00E+OC
Scdum 13 0 4.71E+OO ND
'ThaIfum 13 0 3.1E-01 NO
Vanadium I 131 121 2.63E+01 I 5.40E+01
Zinc 13 12 1.31E+02 4.2SE+02
CYanide (T0taJ) I 13/ , I 2.0BE-011 3.00E-01
TABLE 5
SOIL CONTAMINATION LEVELS: SL-3
Nola: (1tUAlia&cdaulylcsweruoutclCl8!d ill IOiIllmplCS framaay of die fMsoiIlIaL (%)HD. Not ctclCaCd (i.c.. tIeIowsamplc
cIaa:IioIa limit) ill aI1ulllplG fnllII a IOiIIra. NA - Not ualyzaS or uaJytc rejcI=cIS darilll data "8IicIaUoIL.
-------
" -
,
.
FRACT10N I PARAMETER I # SAMPt£S I # OETECTS I AVG CONC I MAX CONC
VOCs Metnylene Chloride 11 5 4.90E-02 1.70£-01
[mg/kgJ AcetOne 11 0 2.88E-02 NO
1,1,1- Ttichloroetnane 11 2 1.12£-02 5.60E-02
Benzene 11 1 5.62:-03 5.60E-03
Toluene 11 1 5.64i-03 5.80E-03
E~ylbenzene 11 0 5.75E-03 NO
TOtal Xvlenes 11 0 5.75=-03 NO
Semi- VOCS Benzyl alConol 11 0 2.91E-01 NO
[mg/kg] 2-Metnylphenol 11 Q 2.91E-01 NO
4-Methylphenol 11 1 2.47E-01 3.10E-01
Benzoic acid 11 Q 1.4SC+00 NO
NaCl'\1tlalene 11 4 3.61E-01 1.90E+00
2-Metnytna;:htnalene 11 1 2.96E-01 8.50E-01
0im8!nyt pnznaaare 11 D 2.91E-.01 NO
~l8Phtnylene 11 0 2.91E-01 NO
Acenaphtnene 11 1 3.82:-01 1.BOE +00
Oibenzofuran 11 1 3.46=-01 1.4CS+OO
Oiett1y1 phthalate 11 0 2.91E-01 NO
Ftuorene 11 1 3.91E-01 1.90E~00
N-Nia'CSOdiphenYlamine 11 a 2.91:-01 NO
Hexachlorobenzene 11 1 2.7E-01 1.BOE-02
Phenanrhrene 11 4 1.SE +00 1.S0E+01
ArnhraCene 11 . 2 5.20E-01 3.S0E .;.00
Oi-n-butyl phthalate 11 2 2.SSE-01 . 5.60E-02
-
Ftuoramnene 11 4 1.64i+00 1.60E+01
Pyrene 11 3 1.29E+00 1.20E.;.01
BUfYt benZYl 11 0 2.91E-Q1 NO
senza(a)amnra::ene 11 3 8.a7C-01 6.80E+00
Chrysene . 11 4 7.61E-01 6.40E.;.OO
bis (2-Ethylhexyl) ptttnalate 11 0 2.91E-01 NO
Benzo (b) Ftuoranthene 11 4 1.03E+00 9.20E~OO
Benzo (1<) Fuoranthene 11 3 1.11E+00 1.00E+01
Sanzo (a) pyrena 11 3 6.625-01 5.2CE.,.OO
Indeno(1,2,3-cd)pyrene 11 3 4.7=-01 3.2CE+00
Oibenzo(a.h)arnI'1rZ8r1e 11 1 2.98E-01 8.70E-01
Ben%o(a.h.noervene 11 3 4.49E-01 2.90E+00
Pesticides! EndOSUIfan I 11 I Q 6.73E-02 NO
PCBs 4,4' -ODE 11 0 1.35E-01 NO
ImglkgJ 4,4'-000 11 0 1.35E-Q1 NO
4.4'-CCT 11 0 1.35E-Q1 NO
Araclor 1260 I 11 I 01 1.35=+00 I NO
TABLE 6
SOil CONTAMINATION lEVELS' Sl-4
!
pg 1 of 2
-------
.. ................ ..~-.- h
. . - - .'.....
.. .--- -
,
.
. FRACilO N I PARAMETER I # SAMPLES I # DETECTS I AVG CONC I MAX CONC
Metals AJumnum 10 10 1.015+04 1.395...04
[mg/kg} Atseni: 10 10 4.63E+01 1.245 ...O~
Bar:wm 10 10 3.SSE+02 1.395+03
Berylium 10 10 1.S4C+00 4.705+00
Cadmium 10 2 8.11E-01 2.50E+00
CalciJm 10 10 3.075+04 1.485+05
Chramium 10 10 1.41E+03 5.215+03
CobaI 10 10 9.725+00 2.015+01
Copper 10 10 1.33E+02 5.sa5+C2
Iron 10 10 2.55:+04 9.46E+04
Lead 10 10 '1.53E+02 3.22:+03
Magnesium 10 10 1.saE+03 3.095+03
Manganese . 10 10 1.52:+02 5.685+02.
Me~ 10 9 '1.1i'E-01 1.805+00
Nickel 10 10 2.4SC+01 5.6CE+01
POtaSSium 10 10 1.03E +03 2.:185+03
SeIenim1 10 8 2.7OC+00 SoSO:+OO
Silver 10 3 1.35E+OO 4.005+00
Sodium 10 4 '1.34£+02 . 3.635+03
'ThaftiJm 10 4 ~ 12:-01 1.~O
Vanadium I 10 I 10 I 5.'105+01 1.105+02
Zinc 10 10. 3.185+02 9.565+02
Cvanide (Tcnan I 10 I 61 1.17E+00 I 3.205+00
SOfL CONTAMINATION LEVELS' SL-4
Noaa: (1) tJAlil&edaulyUswcruout==cd iuoilampla fnuuayor&llc CMsoiI araa. (%)1'10. Notclc=ulS (i.c., bctowsamplc:
cIcrIaiGD Ii!") ill aIIampta flam alOil8'8L NA - I'Iollllll)'mS ar IlllIyu: rcjccd clariltl cilia wIidaIiolL
-------
.
.
F~CTlON I PARAMETER , - SAMPLES I # DETECTS! AVG CONC: MAX CONC
VOCS Metnylene c."'Ilorice 8 0 3.27E -02 NO
[mglkgJ AcetOne 8 0 3.27E-Q2 NO
1,1,1- Tric!"Joroet!'lane 8 0 6.53E-03 NO
Benzene 8 0 6.53E-03 NO
ToJuena 8 ~I 6.53E-03 NO
Elt1yI)enZene 8 6.53E-03 NO
TOtal Xvlenes 8 01 6.53E-03 NO
Semi-VOCS Benzyl alc::no! 8 1 1.0aE~01 1.10E-01
[mg/1cgJ 2-Mettlylphenol 8 1 1.08E+01 5.10E-02
4-Memytpt:enol 8 1 1.09E+01 1.10E-01
Ben:oic ac:d 8 :1 5.46E+01 2.00E+00
Naph~aJene 8 1.05E +01 4.50E+00
2-Memylnaptnnalene 8 ~I 1.05E+01 1.9OE+00
Dime2:1yf pt:'..aIaIe 8 1.091:+01 NO
Acet"I8J)hthyiene 8 S 3.411:+00 2.2OE+01
Ac~tnene a 4 1.09E+01 6.00E+00
. Cibenzofuran 8 4 1.05E+01 4.60E+00
Oietnyt ptttr.alale 8 0 1.09E+01 NO
Fluorene 8 4 1.09E+01 5.60E+00
N-Nibw$Cdiphen~ine 8 1 1. 1CE+01 8.00&-01
HexacnJorcbenZene 8 0 1.09E+01 NO
Phenanthrene 8 6 3.56E+01 1.60E+02
Amnra:ene 8 5 7.72:+00 3.30E+01
Oi-n-tutyf phtnalate. 8 1 1.09E+01 7.00E-01
Ftuoranthene 8 6 9.2OE+01 5.9OE+02
.pyrene 8 6 9.04E+01 5.90E +02
SutVI benzvf ~alate 8 0 1.09E+01 NO
Senzo(a)amnra:ene 8 6 7.79E+01 5.50E+02
Chrysene 8 6 8.97E+01 6.4OE+02
bis (2-EEny1h~ phthalate 8 3 1.06E+01 1.70E+00
Benzo (b) Fluorantnene 8 6 1.29E+02 9.20E+02
Benzo (1<) Fuoranthene 8 6 9.361:+01 6.4OE+02
Senzo(a)pyrene 8 6 9.=+01 7.10E+02
Indeno(1.2.3-cd)pyrene 8 6 3.29E+01 2.4OE+02
Oibenzo(a.h)amtva:ene 8 3 1.52E+01 1.10E+02
Benzo(o.h.i\cervene 8 5 3.2SE+01 2.4OE +02
Pesbcides/ Ettdosulfan I 8 0 6.4OE-02 NO
PCBs 4,4'-CCE 8 ' 2 8.00E-01 5.4OE+00
{mglkgJ 4,4'-000 8 4 2.441:-01 8.50E-01
4.4'-OOT 8 2 2.511:-+00 1.9OE+01
Arcclor 1250 I 81 01 1.28E+00 I NO
:iUIL CONTAMINATION LEVELS' SL-S
1'9 1 of 2
-------
. .. -~~-
. n~ ....... ,
,
.
F~ACT10N I PARAMETE~ I # SAMPLES I # DETECTS i AVG CONCI MAX CONC
Metals AJumnum 5 5 9.7SE+03 1.23E+04
[m~sl Arsenic 5 5 2.77E+01 3.45E+01
Barium 5 5 3.64E+02 7.65E+02
Beryaium 5 5 9.98E-01 1.3CE+00
Cadmium 5 1 9.47E-01 2. 10E+00
CaJciJm 5 5 1.10E+04 1.99E+04
Chramium 5 5 S.38E+02 1.asE+0~
Coba! 5 5 7.64E+OO 1.0SE+01
Copper S 5 S.23E+01 9.OCE+01
lren 5 5 1.49E+04 1.80E+04
Leac 5 5 '.14E+03 3.24E+03
Magnesium 5 5 1.41E+03 1.94E+03
Manganese 5 5 2.05E+02 3.24E+02
MercJry 5 4 &. 13E-01 1.CCE+OO
Nickel 5 5 3.S9E+01 7.91E+01
PctaSSium 5 5 6.00E+02 9.85=+02
SeleniJm S 5 2.C5E+OO 2.6CE+OO
Silver 5 0 6.S0E-01 NO
Sodium 5 0 2.S2:+02 NO
ihaJrum 5 2 4.1=-01 5.7OE-01
Vanadium I 5 :1 2.7SE+02\ 7.4CE+02
Zinc 5 6.27C+02 1.52:+03
Cvanide rrOtaO I 51 51 5.12:+00 I 2.08E+01
SOIL CONTAMINATION LEVELS' SL-S
Noaa: (1) UDlis&cdauJylcs'ICClIOutClCl:lCd ilUOilllmplcs wmaayoflllc a"uoil araa. (:> NO. Not dc&e:1Cd (i.c. bcIowllmplc
dcseciaa 6_=t) ill all 1Imp1a wmuoilara. NA. Nocaaalyzsl orauJycc reja:ted duriDl ULI Yllidatioll.
-------
TAILE a Ccant'd)
SALEM ACRES
SLUDGE LAGDONS . CURRENT LAJIO USE
Potll'ltfll e.I'cinogll'lic and Noncal'einogenic Rfsks fl'OII EJlpo$"I'e
to SUrface Soils vii Inc:idll'ltll Ingestion and Del'lllll CantIC:
Mljol'
Cont_iNnt-
, I'1C;\:II'ICy
of
Conell'lt I'lt i on
(1liii/kg)
~el' Risk
HIZII'd Index
Detec:ion
A"I.
Mia.
A"I.
Mia.
A"I. Mia.
UGDON DA1
CIIl'ali UI 1712D 700 1800 Z Z 7.7E.02 2.0E-01
A......ic 2120 2_6 30 1.41-05 1.61-05 1..7E-02 5.5£-02
Lad 4/20 150 240 z z Z Z
DfafnslFurans- 5/5 0.004 0.008 7.D!-1J' 1.41-03 Z Z
PCb 3/6 2.3 6.' 5.5£-06 9.41-06
Totll Risk (All Ch..icILs) 7.D!-1J' 1.t.r-03
LAGOON DAZ
CIIl'ali &II 12112 1000 3400 Z .z 1.1e-01 3.U-01
cPAH. 2118 58 110 2.6E-1J' 5.2E-Qt. IIA IIA
D f ai ns/'lII'lI'IS- 3/3 0.009 0.021 1.41-03 3.5e-03
PCB. 3/3 5 5.5 5..-06 9.U-06
-------
TAiLE 8
...
SALEM ACRES
SLlJDe! UCiQQNS - FUTURE UNO USE
Potentill Clrcinovenic end Noncarcinogenic Risks f~CIII bposur.
vii InCiden:11 Ingestion IIId DenuL ContlCt
Frequency Concentrltion
M.jo~. of (lIIg/kll) Cancer Risk "Izard Indo
ContlllliNnt Detection "¥S. Mia. Avg. Mia. Avg. Mia.
LAGOON DA 1
Diox1na/FUI"InS 5/5 0.1104 0.008 8.5E-0l0 1.7E-03 Z Z
ChrCllli \III 171ZO 700 1780 Z Z 1.1E.oO 2.9£.00
Arsenic 2/20 2.6 30 1.7£-05 2.0£-05 7.0£-01 8.0£-01
PCls 2/19 3.7 6.4 3.1.E-06 5.9£-06 Z Z
Lnd 41ZO 152 Z36 Z Z Z Z
Totll Risk (ALL CheaiceLS): 8.7£-010 1.7E-03
LAGCON DAZ
ChrCllli \III 12/12 1000 3U.O Z Z 1.7£.00 5.~0
D1oxina/FUI"InS 313 0.1109 0.021 1-8£-03 4.3£-03 Z Z
cPAHs 2/18 58. 110 3.2£-010 6.2E-0l0 Z Z
PCBs 313 4 6 6.0£-06 1.0£-05 Z Z
L.ed 6/12 150 Z70 Z Z Z Z
-------
TAiLE 8 (cant'd)
SALE.'4 ACIES
saIL AREAS (SL.1 AID SL.Z) . FUTURE \.AJIO USE
Potential ~rc;nogenic and lIoncarcinogenic Risks fl'Olll EJ!posure
.,ia Incidental Ingestion ~ De,..l Contac:t
Frequency Caneent,..t; on
Mljor of (Illg/kg) ~er Risk Hazard Index
Cont8inant- Detection Avg. Mu. Avg. Mu. Avg. Mu.
AREA SL.1
cPAIIs 4"0 2.Z 5.14 1.2£.05 Z.9£-05 IIA IIA
Arsenic: 8/8 1.9 3.4 1.3£.06 Z.3E-06 5.1E.02 9.3e.OZ
IeryU IUI 8IS 0.41 0.6 6.9£-07 1.0E-06 6.n-04 9.8E-04
CIII'OIIIiUl 4/8 6.1 15 Z lID 1.0e-OZ Z.4e-OZ
Lad 8/8 31 152 SEE NOTE BELOW Z Z
Total lisk (All Ch8ic:als): 1.5e-05 3.2£-05
AREA SL-Z #'
cPAIIs 41S 10_73 6.75. 5.4E-06 4.7E-06 IIA IIA
Arsenic: 4/4 3.8 4.4 Z.6£-06 3.0E-06 1.1e-01 1.2£-01
'eryU IUI 414 0.6 0.8 1.0£-06 1.4e-06 9.9E-04 1.3e-03
Chl'Olli WI 4/4 14.6 20.0 Z Z Z.4E-OZ 3.3e-02
Lad 4'4 122 327
-------
< ,- . '.<'
TAIL! 1 (cont'd)
SALE.~ ACRES
SClIL AREAS (SL3,SL',SU) . FUTURE L.UID USE
Potential c.rcinosenic and Noncarcinogenic Risks fl'Olll EaposUt'.
via Incidental Ingestion and D.rI8l Contact
FI"equetW:y Concentrat i on
Major of (lIIIIk;) Canc.r Risk Hazard Indea
Cont8llinant- Detection Ayv. Mu. . AVS.-- Mu. Avg. Mu.
AREA SL.3
CPA"s 1/11 Tf 10.9 '.6£.0l. 7.3e.05 IIA NA
Arsenic 13/13 2.7 8 1.9£-06 5.5e-06 7.'e-02 2.2£.01
.erylli~ 11/13 0.53 1.3 8.9£-07 2.2E-Q6 1.1£-0l. 2.1£.03
Chl'Ollli ~ 13/13 590 1870 Z Z 9.6e.01 3.1e-oO
Total Risk (All Cheaicals): '.1£.0l. 7.3£-05
AREA SL.'
cPAMs "1' 5.1 '1.67 2.9£-05 2.4I-C)l. IIA IIA
Al'leni c 10/10 " '20 3.2£.as 1.5E-05 1.3E-DD 3.loHO
BeryL L hll 10/10 1.6 4.7 2.1E-06 7.9£-06 2.71-03 7.5E-03
Cll'Cllliua 10110 1410 5210 Z Z 2.2£4 1.5E-DO
L.ad 10/10 750 3200
TotaL Risk (All ChemicaLs): 6.6£.as 3.3£-010
AREA SL.S
cPA"s 6/8 537 3800 3.ae.03 2.1£-02 IIA
AI'I."i c 5/5 za 35 1.9£.05 2.41-05 7.6£.01 9.'£-01
'eryll fl. . 5/5 1.3 1.7E-06 2.2£-Q6 1.6£-03 2.1£-03
,
Ct,,'_i~ 5/5 538 1850 Z Z 1.1E-01 3.0£4
Lead 5/5 1140 3240
Total lisk (All Chemicals): 3.ae.03 2.1E-02
-------
TABLE 8 (cont'd)
ND a nondetect
cPAH c carcinogenic polycyclic aromatic hydrocarbons
PCB - polychlorinated hydrocarbons
Z D Dose response data is inadequate for a quantitative risk
assessment
* contaminants contributing to the majority of the risk
** Average risk are higher than maximums where ~~ere were
nondetect samples with high detection limits: 1/2 the detection
limit was greater than the maximum detected concentration. .
*** Expressed as 2,3,7,8 TCDD equivalents
-------
. .. - ... . .--."
TAIL! 8 Ccont'd)
SOIL AREAS CSL3,SL',SL5) . CURRE~T LAND USE
Potential Carcinogenic and lIoncarcinogenic lisks fNJIII Exposure
yi. Incidental Intenion and Dermal CQntact
F rlQUeftCy Concentru i on
..ajor of (1liii/kg) Cancer I bit Hazard Indu
Cont8llinant- Detection Avg. Mp. Avg.-..ea. Avg. Mea.
AlEA SL-3
cPANs 8/15 17 10.9 3.5E-~ 4.1E-05 Z Z
Arsenic 13/13 2.7 8 1.5E-06 4.3E-06 5.0E-03 1.5E.02
.eryll i UII 11/13 0.53 1.3 7.1E-07 1.7E.06 5.8E.OS 1.'E-~
Chl"Ollli UII 13/13 . 585 1870 Z Z 6.4E-02 2.1E-01
Tota list (All Chemicals): 3.8E-0l0 5.1SE-05
MEA SL-'
dANs 4/11 5.1 41.67 2.ZE-05 1.ge.0l0 IIA IIA
Arsenic 10/10 46 124 2.5E-06 6.7E-OS 8.5E-02 2.3E-01
.erylltUII 10/10 1.6 "'.7 2.ZE-06 6.3£-06 1.8E-0l0 5.ZE-~
ChrOlliUII 10/10 1'10 5210 Z Z 1.6E-01 5.n-01
Lead 5/5 750 3200
Total .rsk (All Chemicals): 5.3E-05 2.6E-0l0
MEA SL.5
dANs 618 537 3800 '_DOE-07 2.loE-03 1.7E-02 6.9E-07 IIA IIA
A !"18ft i c 5/5 28 35 1.15E.07 1.5E-05 1.9£-05 5.5E-07 5.1E-02 6.3£-02
,
leryll iUII 5/5 1 1.3 1.15E-07 1.3£-06 1.71.06 5.5E-07 1.1E-~ 1.loE-04
Chl"Clli UII 5/5 538 1850 Z Z Z 5.5E-07 5.9£-02 2.GE-01
Lead 5/5 111"Q 32t.O
-------
~
TAlI.E a (cont'd)
SALE!" ACltES
son. AaEAS (51.-1 AID $1.-2) - CUlREIiT LAlla uS!
po:ential Carcinogenic and lIoncarcinogenic RiskS frOlD Exposl.II"e
via lnc:iGental tngestion and O'rI8l COI'Itact
F rlfJlJllfCY concentrl t i 01'1
Major of (1II!I/kg) eanc:er Ii sit Huard I-x
conu.i nant- oetection A'll. MP. A'll. MP. ".,g. MP.
AlEA SI.-1
cPAMS 4/10 2.2 5.14 1.00£-05 1.4(-05 Z Z
Arsenic ala 1.9 3.' 1.0£-06 1.8E-06 3.t.E-03 6.ZE-03
l'ryU h.ll SI8 0." 0_6 5 .5E~07 a.O£-07 '.5£-05 6.6£-05
OIrGli\ll I./a 6.1 15 Z Z 6.7E-Qt. 1.6£-03
1..1Id SI8 31 152 Z Z Z Z
Toul Risk (AU OI.ic:als): 1.ZO!-Q5 2_6CI£-06
AlEA SI.-2
cPAMS 4/5 10.73 6.75 5.1£-06 3_0£-06 IIA IIA
Arsenic 4/4 3.85 4.' 2.1£-06 2.4(-06 7.1£-03 8.1£-03
leryU ;\11 4/4 0.6 0.8 a.0£-07 1_1£-06 6.6£-05 8.ft-05
OIrGli\ll 1./4 15 20 Z 1 1.6E-03 2.ZE-03
...1Id 414 1ZZ 321
Toul Risk (AU O.icals): 8.60£-06 6_50£-06
-------
. . - ~...- . _. ._----
.- _6___~_.____.~_6___~_.
-.--' -~. - -- .
.. .----
ONSITE GROUNDWATER CONTAMINATION LEVE1.S
FAACT10N i PARAMETER I - Samcles: - Cete~.s I Avc Cone I Max Cone
VOCs I Acetone ZI 1 I 1 2iE +01 1 .SOE ~01
[uSIIJ I Carbon Cisulide ZI !I 2.== +00 7.60E+00
I Trict1lorcethene Z/ 2.45= +00 1.10E+00
Benzene 'D, 2.37E +00 3.10E+oo
! Toluene 'D 2! 2.41E+00 1 .3OE +00
! Chlorobenzene 'D 7 1.29: +01 7 .3OE +01
! Etnylbenzene 'D 11 1 .OSE +01 7.ooE+01
! Tetal Xvlenes 'D 7 4.3::1: +00 2.201: +01
Semi-VOCs i 1,3-Cicnlcrobenzene 131 3 5.25=+00 . 3.00E +00
(uSIIJ " 4-Cidil::lrabenzene 13 5 6.13:+00 8.50E +00
. . 131
1'.2-t)ichlcrabenzene 3 6.091: +00 1.10E+01
! Benzoic acid 131 1 I 3.38E +01 6.4OE+01
,
; Naptllnalene 131 ~I 7.51E+00 3.00E~01
12-Mmhvlnziftnalene 13 9.001:+00 1.70E+01
PeStieideS/PCSs Endcsulfan I I 10 I '1 2.SOE-c21 8.ooE-02
I ruc:m !
.
Metats I Aluminum as 3 1.==+01 4.45£+01
[ug/l) . Antimony Z1 3 1.825+01 4.925 +01
IMenC Z1 8 1.53E+00 4.9OE+00
Barium 'Z1 ?:1 4.79E+01 1.37E +02
Calcium Z1 'Z1 7.181:+04 1.51E+05
Chromium ?:1 1 2.11E+OO 4.10E+00
Cobalt Z1 . 10 3.9OE+00 1.125+01
~r 'Z/ 2 3.04E+OO 1.19E+01
- Iron 23 22 3.ooE+04 1 .05E +05
1.Bad Z1 3 1.2E+CIJ 7.7OE+00
Magnesium %1 %1 1.O'7E+04 2.~04
Manc8"les8 'Z1 25 3.075 +C3 7.78E+03
Nickel Z1 2 6.3~ +00 1.p9E+01
.
POtaSSium Z1 'Z1 4.99E+03 1 .05E +04
Selenium ?:1 3 1.13:+00 3.9OE+00
Sodium ~ Zl Zl. 1 .9OE +04 7.73E+04
I ~anadium ~I 1~1 2.5=+00 I 6.70E+00
Zinc 2.52:+01 1.s2E +02
Ncxa: (1) U8Iis&ed uaIyIes. iD::IlIISiq Peaic::iaa aDd PCBs. wa'e !lOt cIeuacd ill Ul'f IIKIIIiIcIriDC wen dllr'iZlllll'f 0{ die sampliDJ r'OIIIIIb.
-------
ONSITE SURFACE WATER CONTAMINATION LEVELS
FAACT10N I I Adiaeent and Oownaradient Wetland Areas
PARAMETER I II Sameles I # Detects I Ava Cone I Max Cone
VOCs I Tam Xylenes I 131 1 I 2.56&+00 I 3.30E-!-oo
Iruont
MetaLs AJumnum 11 10 1.34E+C2 4.01E+02
[ugt1] Barium 11 10 1.77E+01 2.87E-!-01
CaJciJm 11 10 1.87E+04 4.s1E~04
Chrcmium 11 1 2.73E+00 5.QQE~00
Ccecer 11 9 7.965+00 3.12S~01
lien 11 10 1.59E+03 9.74Eojo03
Laad 11 5 1..38E+OO 5.QQE~00
Magnesium 11 10 3.23E+03 6.44C+03
MillgM18se 11 10 1.88E+02 8.2SE~02
PetaSSium " 10 2.06E+03 5.77E~03
Seienilm 11 1 3.D8E+Oa 2.S9E+01
Silver 11 1 2.2OE+00 4.20E...oo
Sodium 11 10 1.S3E+04 3.94E~04
VanCium I 11 1 1.83E+OO I 5.1 DE+OO
Zinc 1 1 3.3SE+01 3.3SE+01
Na-=
(1) u.iiaed VOCalS 8I8iallllJla..-c -..... ill 181..n.z....a.,..
(%) rvca IDd PI8iI::ideIIPCB wre""" - IIDCcIcIa:Ied iD UlfI8fac:e...-1IIIIP1a.
-------
. .. .. ~. ..
. . ----. '...
."w-- , ,
SEDIMENT CONTAMINATION LEVELS
FRACTION I I Adjacent and Downgradiem Wetland Areas
PARAMETER -~. . Samoles I . Detects I Ava Cone I Max Cone
5emi- VOCS 4-Metnylphenol 8 3 3. 17E-01 1.70E-01
[mWk;J 2.4-DiTle!t1yIphenol 8 1 3.63E-01 2.50E-01
Benzoic acid 8 2 1.62£+00 9.10E-01
Napht\alene 8 2 3.15i-01 5.70E-02
2-Metn . alene 8 1 3.4OE-01 6.3OE-02
Acenaphthyiene 8 1 3.44C-01 9.60E-02
F"auorene 8 2 3.23E-01 9.50E-02
Phenanrntene 8 .6 3.50""£-01 8.5oe-01
Amnrzene 8 1 3.48E-01 1.3OE-01
Fiuoramnene 8 6 4.79E-01 1.50E+00
Pyrena 8 6 4.41E-01 1.3OE+00
Benzo(a)GI at II acane 8 5 3.19E-01 5.9OE-01
Chtysene 8 S 3.SCE-01 7.2CE-01
Benzo (b) Flucramhene 8 6 ~.04E-01 1.20E+00
Senzo (k) Fuoranthene 8 6 4.04E-01 1.20E+00
Benza (a) pynme 8 4 3.33E-01 5.4CE-01
Indeno(1.2.3-cd)pyrene 8 2 3.38E-01 2.4OE-01
Dibenm(a.h)antt1rzene 8 1 3.4QE-01 6.50E-02
Benzofa.tl.1 . 8 1 3.56C-01 1.9OE-Q1
Metals Alumnum . 9 9 7.6'iE+03 1.355+04
[mWk91 Arseni: 9 9 3.43E+OO 1.19E+01
Barun 9 9 5.6OE+01 1.50E+02
Berylium 6 3 4.35E-01 7.4OE-01
- CalcUm 9 9 4.01 E+03 9.325+03
Qwmium 8 B 1.63E+01 3.2SE+01
Cccat 9 9 1.10E+01 3.99&+01
C~ 9 9 5.31&+01 3.48E+02
Ircn . 9 9 1.s5i+04 2.69E+04
Lsad 9 8 9.29E+01 3.&+02
Magnesium 8 8 1.96E+03 4.41E+03
y
Manganese 9 9 3.17E+02 1.20E+02
Nickel 9 7 1.15&+01 3.81E+01
Petassium 9 7 4.78E+02 1.15E+03
Seleninn 9 2 7.18E-01 2.5OE+00
Vanadium 9 9 4.921:+01 1.63E+02
Zine 9 9 ' 9.64C+01 3.925+02
MoIlS:
(1) UAIiIIed SVOCaad .... ...". 481ft DOt cIeIa::Ied i118f llldimau alllpla
(%) voe. WII'e"""': JrI8icidaIPCBI W8'e""" -- cIeIeI:I8d.
-------
.
UPJDtI)U - C -
-------
nDLlLDQ=1D
CHEMICAL SPECIFIC ARARB. CRITERIA . ADn@QJtTI@~tflLgUIm\NQE
.:;:'::.:::. :;::::.:.:. :.::.;~\it~:i;::};;.{~\:1!:f;,~::i ....,"..- ..",.,",.
":"':"',":.:.: :. .
H.diu./ '. ,',","'. ",'., Action to be Take.. to
~8tA" .. :. . : .~.:. ;t\1::;:i.ij:~~:.~f. 0; Require.ent
Autbority :..1,:'i: '. : .' ..: " ':.- .~::.: . :..: Attain ARAR
.. .. .
o round rederal 8af. Drinking Water Applioable Haximum Contaminant Levels Remedy of contaminatsd
water Act (SDWA) National Primary (HCLs) are enforceable soUs wUl eliminate any
Drinking Water Regulations stand"rds that are dischal'ge of contaminant.
(NPDWR) - 40 crR 141 applloable to dl'inking to gl'oundwater by the
water supplles. HCLGs al'e removal of waste off-
non-enforceable levels for site. HCLs and non-HCLO.
. suoh .ystems. will be attalned In
groundwater following the
remedy.
Ha.sachusetts Ol'oundwater Applicable Ha..aohusett. gl'oundwater Remedy of contaminated
QuaUty standards - 314 CHR standards have been soUs wUI eliminate
6.00 promulgated for a number of dlscharge of any
oontamlnants. When the contamlnants to
state levels are mOl'e groundwater by the
strlngent than federal removal of waste off-
levels, the state levels site. The 8tate standard.
will be used. will be attalned after
the completion of
remed ia 1 activities.
o round Ha.sachu.ett8 Drinking Applioable Has.achusetts Drinking Remedy of oontaminated
water Water Regulation. - 310 CHR Water Regulations include solls wlll eliminate
(cont'd) 22.00 Ha..achu.etts Haximum dlecharge of contaminants
. Contaminant Level. (HHCLe). to groundwater' by the
If .tate HHCLs are more removal of waste off-
stringent they will site.
supersede federal HCLe.
rederal 8DWA, NPDWR - 40 To Be Con.idsred Proposed MCLs may become Remedy of contaminated
crR 141 potential ARARs, when sol1s wlll eliminate
promulgated, and are dlecharge of contaminants
considel'ed in the absence to gl'oundwater by the
I of HCLs. removal of waste off-
-------
"
I
~gmical-Specific ARARs. Criteria. Advisories. and Guid~nce
'. ; :;.:.'" ;'...,.; :'~iU~~i?;r):,?::i:;} :.'
NecUu.' : .. 0.".. Action to be T..en to
ABAR: : . . 8u...rr of Require.snt
~uthor'1tr Attain ARAR
_. _. '~... -
RPI\ ncfarenco Doses I II fO' 't'.' W,a """'" ,.........,. .~!:~f";!~...!'~:.;:.. '" ~rft hblerence Ooses will
_J_-- w....
ror Mon-oarcinogens I standard exposure be met by the removal of
assumptions for body weight waste off-site.
and daily drinking water
ingestion rate are used to
derive oleanup goals
protective of
nonoaroinoqenio effects.
:
EPA Lifetime Health To "Be Considered These are non-regulatory Lifetime HAs will be met
Advisories CPAs.. Offioe of concentration Umits for by the removal of waete
Drinking Water contaminants in drinking off-site.
water that are considered
proteotj.ve of adverse non-
caroinogenic health effects
over a U feUme.
around
water
(cont'd) Mass.chusetts Offioe of To Be Considered ORSOLs provide guidance for ORSOL standards will be
Research and Standards chemioals other than those met by the removal of
. Drinking Water GuideUnes with HHCLs in drinking waste off-site.
,ORSOLsi water.
Surfaoe Massachusetts Surface Water Relevant and These standards regulate If lagoon water 18
Water Dlecharge Permit Appropriate dlecharges of pollutants to dlecharged to surface
Requirements - 314 CHR 3.00 surface waters, outlets for waters, the water will be
- such discharges and any treated in conformance
treatment works associated with Massachusetts
with these discharges. eurface water discharge
permit requirements.
125054-24
-------
M.dlu.'
Authority
Surface
water
Surface
Hater
cont'd)
725054-24
..
Chemical-Specific ARARs. criteria. Advisories. a~nid~g~
(cont'd)
ARAR ".:.'
..', .:
.<,,:'....
.'....:.:::.:.,
.. ,
Hassachusetts Surface Hater
Quality Standards - Jt4 CHR
4.04
Ha..achusetts Operation and
Haintenance and pre-
treatment Standards for
Ha.tewater, Treatment
Horks, and Indirect
Discharges. 314 CHR 12.00
rederal Clean Hater Act-
National Pollution
Discharge Elimination
System (NPDIS)
.
'ederal Clean Water Act
(CWA) - rederal Ambient
Water Quality Criteria
('AHQQ)
... .
":':::il: ~¥~i~:~:):lii.;:I'~~:~~;}'i;~,.:: ~ :.::~~j~~~~ri of Requlre.ent
Relevant and
Appropriate
"
Relevant and
Appropriate
Relevant and
Appropriate
Relevant and
Appropriate
These requlremento are for
the antidegradation of
sllr.f<'OA w<,tol'n nne' ,,,"nvle'"
for control of .
eutrophication and
eotablish diocharge
criteria.
These regulations enBure
proper operation and
maintenance of wastewater
treatment facilities and
.ewer eystems within the
State.
These standards regulate
the discharge of pollutants
to surface waters of the
United States.
PAHOC are non-regulatory
concentrations for the
protection of aquatic life,
and of human health fTom
water Ingestion and fish
consumption.
Action to be Taken to
Attain ARAR
If lagoon water Is
discharged to surfaco
,.!at.'.!!:tl. lhu ~:~L:...' ..:~l l.,a
treated In conformance
with all water quality
criteria.
Remedial activities will
comply wIth aU
provIsions of this
regulation. Lagoon water
will rscelve pretreatment
to remove hazardous
compounds prior to
dIscharge Into any
municipal treatment
facUlty.
If lagoon water treatment
Is required, the water
will be treated to meet
the applicable standards
prior to discharge.
If lagoon waters are
required to be treated,
water will be treated to
meet PAWQQ.
-------
Chemical-Specifio ARARs. Criteria. Advisories. and Guid~~
(oont'd)
.. . .; .....:,: .:.;; :';~~~ ~~:~.~:r~:~1:~0J.;~:i:.:, ...
M.diu., ' Action to be Taken to
IUR. :..;.:;.~~~.J"r of ~...uir...llt
luthortt:r .. : Attaia ARAR
Air Massachusetts Ambient Air Applioable These regulations epecify Hit:1gat:1ve meaeuree ueing
QuaUty Standarde 310 CHR I primary and eecondary engineering controle,
-
6.00 ambient air quaHty Including '08mo, will bo
atand8rcto 1.0 In"ol.ecl: public taken to control fuqltlvo
t!I'HI,.!.lh ~nd -.:.::If.:..-.,; ,... JI.4DL &:..1 a a.....' ....u. &. "'"
......
certain pollutante. excavation and I
construotion aotivities.
725054-24
-------
Mediu.'
Autbo,"ltr
Air
(cont'd)
725054-24
Chemical-Specifio ARARs. criteria. Advisories. and Guidance
(cont'd)
,'":'::';;":;;
. :::': .:.."R~~:: :;...:;:;;:
. '.
:: .,..:.........,;.-. :..,~;.~..t.,.~.;...:~.:..,.:.:.:.~.:.:.f.:~h::i.:.~:.:.t..j:.i.';.." :::::..;;"~..,!~r ~f Re..uhe.ent
.... ..... .0: :-:-~;.;.:..' ..::'.." .; :'. .'
"."'.
HaBBachuBette Air Pollution
Control Regulatione - 310
CHR 7.00
Applicable
310 CHR 7.06
Applicable
310 CHR 7.09
Applioable
310 CMR 7.10
Applioable
-
TheBe regulations pertain
to the prevention of
emiBsionB in excess of
MaBBachusetts or national
ambient air quality stand-
ards or in excess of
emission limitationo in
those re9~!!!:!~~~.
TheBe regulationB Bpecify
requirements to prevent
vieible emissions, not to
exceed the criteria eet
forth i~ the regulationB.
TheBe regulations Bpecify
requirements to prevent.
dUBt and odors generated
during remedial actions
which contribute to air
pollutlon.
TheBe regulations specify
requirements on
conBtruction equipment to
suppress Bound.
MassachuBetts DEP policy
requireB that the site
perimeter noise levelB not
exceed 10 decibels above
ambient noiBe levels.
Action to be Taken to
Attain ARAR
Mitigative measuree uBing
engineering controls,
including foamB, will be
taken to control
emissions from excavation
and construction activi-
ties.
..........-...
Mitigation measures using
engineering controls,
including foams, will bo
taken to control visible
emissions.
Mitigation measures using
engineering controls,
including foams, will be
taken to control odore
and dusts during
excavation and
construction.
/
Equipment with eound
suppression will be ueed
to reduce noise levels to
below the regulated
level.
-------
".diu.'
Autbodtw
Air
(cont'd)
125054-24
Chemical-Specific ARARs. Criteria. Advisories. and Guidang@
(cont'd)
AU" .
. .
'~., ..
Massachusetts Prevention
and/or Abatement of Air
Pollution Bpisode and Air
Pollution Inoident
Bmergencies
310 CMR 8.00
Clean Air Act (CAA)
HAAQS for Total Suspended
Part leu latee - "0 Ci'"lt bO
HAAQS for Hazardous Air
Pollutants - 40 erR part
61
-
'. :'.,.'..:i':~'~:~~~~~!~{l~~~C::-::'i:::':::': ~ti..arr of Require.eat
Relevant and
Appropr18te
.
Applicable
AppUcable
These regulations specify
requirements to prevent
ambient air contaminant
concentrations of any
location from reaching
levele which would
conetitute significant harm
or imminent and substantial
endangerment to public
health.
This regulation specifies
maximum primary and
....--:":''':''.1 ~-i .:I,",~'"
concentrations. Fugitive
dust emieeions from eite
excavation muet be below a
24-hfur average of 150
pg/m for particles having
a mean di8meter of 10
microne or Ieee.
These regulations specify
amounts of emieeione for
pollutante euch 8e NOll' S02'
00, lead, mercury, ana
particulates for stationary
sources.
Aotioa to b. Takea to
Attaia ARAft
Mitigative measures using
engineering methode,
including foams and water
will be taken to control
fugitive duet releaeed
during excavation and
conetruction activit Lee.
Fugitive duot emiuniono
wlll be conlrolllJd dlll:lllr,
UXVilYIII:10n ano
conetruction actLvitlee
by the uee of foam and or
other engineering
methode.
Action levele for
ha&ardoue air pollutants
will be determined during
design stages and
engineering controls will
be implemented to control
emieeione during remedial
act.ivLt.Lee.
-------
Hedtu.,
"utho~J.t,
Air
(cont'd)
So11
'725054-24
Chemical-Snecific ARARs. Criteria. Advisories. a~Y!dAnQ~
(cont'd)
.'
..
"~It
:.';
'. n. .
. .
Federal - Occupational
Health and Safety Act
(OSHA, 29 CFR Section
1910.1000-Alr Contaminants)
State Massachusetts
Guidance on Allowable
Ambient Levels (AALs) olted
in Chemical Hsalth Effects
Assessment Methodology and
Methodology to Derive
Amb I pnt" '.P.""'.! f\PP 'I1RI1
SPA Directive for Lead
(OSHER Directive 9355.4-02)
-
..
. '.::.;'~;....:;::,;~~'i~~~':i;~ji;:~jj':;'~'~~: ~;~'L'~~~.r, of Re~ulre.ent
".
.--
To Be Considered
To Be Considered
To Be Considered
TLVs are iseued ae criteria
for controlling air quality
for occupational eettinge.
STELs are fifteen minute
time-weighted
concentratione. TWAe are
based on an 8-hour per day,
40-hour work week.
This guidance evaluates
acute and chronic toxicity
and eete draft AALe for
volatile and semi-volatile
chemicals. AAI.s chemicalu
are considered in
W\.l..;....v...~u.. w~...i. in,..;;', &.tI
meet the action epecific
applicable requirement8 at
:no CHR 6.0 through 8.0.
Interim guidance on
e8tabl1ehlng 80il lead
cleanup level8 of Superfund
Sites recommends a
concentration of total lead
of 500 to 1,000 mg/kg.
7
Action to be Taken to
"ttain ARAR
Action levels for
volatile and eemi-
volatile air contaminants
will be establiehed
during the design stage
and engineering controls
will be implemented to
control emissions during
remedial activities.
AALs will be attained
during all on-site
remediation activities if
technically ,feasible.
All soil with lead above
500 ppm will be excavatod
and moved off-site as
part of the remedy.
-------
Had!u_, . .,.
Au~"QJ'1tr::(,:
Wetland8
Waste Siting
Regulatione
725054-24
:.::;::;,.;,~~R
" '..
. . ".
Ha88achu8ette
Wetland
Protection
Act (WPA)
Regulations -
310 CHR 10.00
Ha88achueette
Hazardoue
Waete
FacUlty
Siting
Regulations -
990. CHR 1.00
TABU. BC-7B
Location-Speoifio ARARa. Criteria. Advi8orie8. and Guidanc~
: .:.:;: ~tf ': ",' 't'~:~';}::::=~ff,;f;:;i::d: :\if::''':' ~..~if~':~:I!':i'~"~~~4I.!IIen~>'
Applicable
The8e regulation8 include
8tandard8 on dredging, filling,
altering, or polluting inland
wetland8. Work within 100 feet
of a wetland i8 regulated under
the8e requiremente.
Requirement8 for the expeditiou8
and 8afe 8iting of hazardoU8
wa8te facilitie8 in the Com-
monwealth, which include
controls on the construction,
opsration, and maintenance of
new facllitieo foe otQ~~~q
I~reatment Or di8po8al of
hazardoU8 waste.
,
Applicable
~ctlontQ be S'aken to Attain ARAI
All work, including installation
of groundwater monitoring well.,
to be performed within the 100-
foot buffer zone will be done in
accordance with the8e regulations.'
Any remedial activitie8 to occur
within the 100-foot buffer zone of
Site Wetland. wUl meet these
requ J ,,'uRlenL o.
II
-------
II
(cont'd)
Location-Speoific AAARe. criteria. Advieorie.. and ouidance
Nediu.' AHAR statu. .u..arr 01 Require.ent
Authority Action to be Ta.en to Attain AAA.
Rivere/CWA I'ederal- 16 Applicable . Mitigative aotion. must be Relevant federal agencies will be
use 661 taken to minimize potential contacted to help analyze impacts of
et.seq. 'ish adverse impaot. to natural the implementation of remedial
and WUdllfe souroes euoh as wetlands. alternatives on wildlife in wetland.
CoordinaUon Restoration of damagsd natural and rivere. If required, restora-
Act features are required. tion of impacted wetlands will Occur
once all excavation and
stabilization activities are
oompleted.
Wetlands/CWA rederal-Clean Applicable Requiremente under these codes Discharge. to wetlands around the
Water Act prohibit the discharge of Site wUl comply with these
(CWA) SecUon dredged or fill material into requirements.
404 C b) ( 1 JI 40 wetlands unless those actions
CFR part 230, comply with the substantive
33 CFR parts requirements which are
320-330 identified under these
regulation..
Wetlands/CWA rederal Applicable Under this regulation, Federal Wetlands protection considerations
Executive agencies are required to will be incorporated into the
Orders 11990- minimize .the destruction, 10.. planning and implementation of this
or degradation of wetland., and .elected remedy.
pre.erve and enhance natural
and beneficial values of
wetlands.
125054-24
-------
..
DDLUQ=ZB
'ACTIOH-SpeCI.IC ARAR8. CRITeRIA. ADVIsoRIes AND GUIDANCe
Hediual AltAR StatuB Suaaary of Require.ent Action to be Taken to
Authority Attain ARAR
Treatment Federal-40 CFR Relevant This subpart applies to all The selected remedy will
Facility Part 264.10- and owners and operators of comply with all substantiv
Operationsl 264.18(Subpart Appropriate hazardous waste facilities. portions of this
RCRA B) General . The subpart identifies requirement during on-site
Facility procedures which must be treatment of contaminated
Standards followed for the operation and materials.
maintenance of a hazardous
waste TSD facility.
TSD Federal-40 CFR Relevant These ARARS identify All waste will be treated
Faoility Part 264.30-37 and requirements which must be met to conform with standards
Prepared- (Subpart C) Appropriate during design, construction, to minimize t~e danger of
ness and Preparedness and operation of TSD fire or unplanned releases
Preventionl and Prevention Faoilities to minimize of hazardous compounds.
RCRA possibility of fires,
explosions or unplanned
releases of waste.
National Federal-40 CFR Applicable These ARARs cover the EPA All discharges of lagoon
Pollutant Parts 122 and administered permit program water to surface water will
Discharge 125 National which allows private parties comply with all NPDES
Elimination Pollutant to discharge pollutants from a substantive requirements.
System/CWA Discharge point source into the "Waters
Elimination of the united states."
System.
-------
TABLE BC-7S (Cont'd)
ACTION-SPECIFIC ARARa. CRITBRIA. ADVISORIES AND OUIDANCB
Medium/ ARAR status Summary of Requirement Aotion to be Taken to
Authority Attain ARAR
Treatment state-JIO CMR Applicable The Hazardous Waste Regulations The selected remedy will
and 30.00 310 eHR 30.00 govern the comply with the substantive
Disposal/ lIazardous generation, listing, handling, requirements under each
RenA Waste storage,. transporting and sUb-part that pertains to
negulations.J disposal of hazardous wastes. on-site or off-site
10 eMR 30.00 activities.
is
cnforcmtlJle
under M.G.L.
CII.21Css.4
and 6.and
H.G.L.Ch.211
s.6.
'I'reatment Federal-"O Applicable '!'hese ARARs regulate the The selected remedy will
and Disposal CFR 260 to treatment of RCRA hazardous comply with the substantive ;
:
nCRA :'.G" lIazardous wastes handling and storage. requirements under each !
Waste sub-part that pertains to
Itegulations on-site or off-site
activities.
Groundwater state-J10 CMR Applicable Groundwater Protection A groundwater monitoring
Protectionl 30. 660Ground- requirements (J 10 CHR., program which meets the
ReRA water 30.660)apply to monitoring requirements of 310 CMR
Protection. requirements and closure of 30.660 and 310 CMR 30.672
This citation surface impoundments. will be implemented
includes the Groundwater protection programs throughout the post-closure
requirements must be conducted after closure period for the site.
of 310 CMR if required by the approved
30.661 thru operating permIt. Groundwater
30.673. monitoring or corrective action
monitoring(310 CMR 30.672)are
required anytime concentrations
of chemicals in the yroundwater
exceed levels establ shed by
the department In accordance
-------
Medluml
Authority
Surface
Water
Protect ion I
CWA
Surface
Water/CWA
Air/cAA
TABLe SC-78 (Cont'd)
ACTIOIf-8PBCIFIC AltARs. CRITBRIA. ADVISORIes AltD OUIDAlfCB
AltAR
State-314 CMR
3.00 (Promul-
gated under
MGL Chapter
21.s.27 and
s.43)
Massachusetts
Operation and
Maintenance
arid Pretreat-
ment
Standards for
Wastewater
Treatment
Works and
Indirect
Discharge 314
CMR 12.00
Federal-CAA-
National
Ambient Air
Quality
Standards
(NAAQA) (40
CFR 50 , 61)
Statu8
Applicable
Applicable
-
Applicable
suaaarJ of Requlre.ent
I
Discharges of any pollutant to
any surface water in the State
of Massachusetts must have a
valid discharge permit from the
Division of Water Pollution
Control(DWPC)-314 CMR 3.04. This
discharge permit (called a
National Pollutant Discharge
Elimination System(NPDES)permit)
is issued jointly by the EPA and
the DEP.
Regulations to ensure proper
operation and maintenance of
wastewater treatment facilities
and sewer systems within the
Commonwealth.
NAAQS define levels of primary
and secondary levels for six
common air contaminants(sulfur
dioxide, particulate matter
"PMIO", carbon monoxide, ozone,
nitrogen dioxide and lead).
Aatlon to be Taten to
Attain ARAR
Any remedial activities
conducted on-site will be
conducted under CERCLA
Sections 104 or 106;
therefore, no federal or
state permits will be
required. However, the
selected remedy will comply
with the standards or
discharge limits and
activities covered by any
permits which would
normally be required.
Remedial activities will
comply with all provisions
of this regulation.
The levels established for
these six air contaminants
will be used as target
levels which may not be
exceeded by air release
-------
KeeHum/
Authority
Air
Discharges/
CM
!'
Noise
Air/
Discharges
TAIL. 8C-78 fCont'4)
ACTION-8PECIFIC ARARs. CRITBRIA. ADVISORIES AND GUIDANCB
ARAR
... .~:. -.. '~:"':..:... .". _......---..._--_.__.~_._~~.&.'L':.L~.:r::.=.::...&...L. ..
Summary of Requirement
Aotion to be Taken to
Attain ARAR
The selected remedy will
comply with the use of Best
Available Control Techno-
logies (BACT) and will not
contribute to a condition
of air pollution.
state-JI0 CMIt
6.0-8.0 Air
Quality
Control
Regulations
state-J10 CMR
7.10 Noise
state-JI0 CMR
7.09 .
Dust,order,co
nstruction,
and
Demolition
Status
Applicable
Applicable
.
Applicable
- --
These regulations govern
emissions to the air from new
sources. Sources must not cause
a ~ondition of air pollution.
In addition there are specific
standards for PICs, cox, oJ, pb
and sox. The state applies
this standard by examining MLs
and other air modeling and
monitoring data and by
requiring standdrd controls
available for some of the more
common remedial technologies.
This regulation requires that
all equipment,machinery and/or
operations which generate noise
(sound),be operated in a manner
which minimizes the generation
of sound or be fitted and
accommodated with noise
reducing equipment and
measures.
On-site construction/
remediation activities will
be conducted during normal
working hours and comply
with the requirements of
this regulation.
.1
Any operation which generates
dust and odors shall be per-
formed in a manner which does
not generate significant
quantities of dust which if
generated would cause or
contribute to a condition of
air pollution
On-site remedial activities
will be performed in a
manner which minimized dust
generation. If significant
quantities of dust are
generated, then mitigative
measures will be employed
to reduce the levels of
-------
.
TA8LB SC-78 .Cont'eS)
ACTION-SPECIFIC ARARs. CRITS.uA. ADVISORIES AND GUIDANCB
Mediuml MAR status SU88ary of aequire.ent Aotion to be Taken to
Authority Attain ARM
Air State-Hasse To. be This guidance evaluates acute The selected remedy will
Dischargel Guidance on considered and chronio toxicity and sets attain AALs during on-site
CM Allowable draft AALs for volatile and remediation activities if
Ambient semi-volatile chemicals. AALs technically feasible.
Levels (AALs) , have been issued by the DEP for
cited in 108 chemicals to date. The MLs
Chemical , to. ,be considered, modeled, and
Itealth monitored for are considered in
Effects conjunction with BACT to meet
Assessment the action specific applicable
Methodoloav requirements at 310 CMR 6.0 thru
and 8.0 in "not causing a condition
Methodoloay of air pollution."
to Deriv",
Allowable
Ambient
Levels, DEP,
1989.
RCRA- TSD Facility Identifies the requirements for The selected remedy will
Closure Closure and Applicable closure of surface impoundments comply with all the closure
Requirements Post Closure and provides for monitoring and monitoring requirements
Federal Subpart G -40 - requirements. for surface impoundments.
CFR 264.110
to .120
-------
..
,
>'-:.:',.. .':..:. . -.'.'.. ..n"
.. .. ..
Mediu_' "" . Action to b. Taken to
I\uthoritr ARAR 8tat~lf.:. .:: .':8u~.rr 01 Require..at '.. Attaia ARAR
.. ..
Ground Federal Safe Drinking Water Applicable Haximum contaminant Levels Remedy of. contaminated
water Act (SDWA) National Primary (MCLB) are enforceable 80ile will eliminate any
Drinking Water Regulations etandarde that are diBcharge of contaminante
(NPDWR) - 40 crR 141 applicable to drinking to groundwater by the
water suppliee. HCLOe are application of a RCRA
non-enforceable levels for Subtitle C Cap.
such eYBteme. Oroundwater preeently
meete the HCL'e for
drinkina water etandarde.
Haeeachueette Groundwater Applicable Haeeachueette groundwater Remedy of contaminated
Quality Standarde - 314 CHR etandarde have been eoile will eliminate
6.00 promulgated for a number of diecharge of any
contaminante. When the contaminante to
State levele are more groundwater by the
etringent than federal application of a RCRA
levele, the State levels Subtitle C Cap. The
..111 be ueed. State etandarde are
preeently being attained.
Oround Haeeachueette Drinking Applioable Ha8eachueette Drinking Remedy of contaminated
water Water Regulatione - 310 CHR Water Regulatione include eoile will eliminate
(cont'd) 22.00 Ha8eachueette Haximum discharge of contaminants
contaminant Levele (HHCLe). to groundwater by the
If HHCLe are more.etringent application of the RCRA
they will euperBede federal Subtitle C Cap.
HCLB.
. Federal SDWA, NPDWR - 40 To 8e ConBidered Propoeed HCLB may become Remedy of contaminated
crR 141 potential ARARB, when eoilB will eliminate
promulgated, and are diecharge of contaminants
coneidered in the abeence to groundwater by the
of HCLe application of a RCRA
Subtitle C Cap.
TJ\DLI: :JC-:;:
-------
"ediu_'
Autbodtr
Ground
water
(cont'd)
Surface
Water
125054-24
Chemical-SDecific ARARs. criteria. Advisories. and Guidance
: ".:"
..
.'.'.:'
MAR
..
.'
BPA Reference Doses (RfD)
for Non-carcinogens
EPA Lifetime Health
Advisories (HAs), Office of
Drinking Water
Massachusetts Office of
Research and Standarde
Drinking Water Guide11nes
tORSGLs.
Massachusetts Surface Water
Discharge Permit
Requirements - 314 CHR 3.00
Massachusetts Surface Water
Quality standards - 314 CHR
4.04
. ". "..';:':;, ~:~~l~;';i~::;:~:!.iJj~~:::~: J~I:~:;.~~~~:#~:I~f.":.~e~~t~~~~..(:
To 8e Considered
To Be Codsidered
To Be Considered
Relevant and
Appropriate
Relevant and
Appropriate
Reference doses and
etandard exposure
assumptions for body weight
and daily drinking water
ingestion rate are used to
derive cleanup goals
protective of non-
carcinoaenic effect..
Non-regulatory
concentration limits for
contaminants in drinking
water that are considered
protective of adverse non-
carcinogenic health effects
over a lifetime.
Guidance for chemicals
other than those with MHCLs
in drinking water.
standards regulate
discharges of pollutants to
surface waters, outlets for
such discharges and any
treatment works associated
with these discharges.
Requirements for the
antidegradation of surface
waters. These provide for
control of eutrophication
and establish discharge
cdtsda.
2
":':AcI:10n to be Taken to
.: . Attaili' ARAR
EPA Reference Doses will
be met by the application
of the RCM Subtitle C
cap.
Lifetime HAe will be met
by the application of a
RCM Subtitle C Cap.
ORSGL standards will be
met by the application of
a RCRA Subtitle C Cap.
If lagoon water is
discharged to surface
waters, the water will be
treated in conformance
with Massachusetts
surface water discharge
oermit requirements.
If lagoon water is
discharged to surface
waters, the water will be
treated in conformance
with all water quality
cdteda.
-------
..
Chemical-SDecific ARARs. criteria. Advisories. and Guidance
(cont'd)
J '
" "',~:' ,':,':':: '; ':":::::"~t,~i~I,-~:::i1:1!'f~;~!i;;~, ,j:~1!~'~:~;'~~~¥.~:::::'~'~": ~8~~i;~~e~~:,;::::r;': :
Medlu8' AUR " Action to be Taken to
Autbodtr : ... . Attain AUR
Surface MaBBachuBetts Operation and Relevant and RegulationB to ensure Remedial activitiell will
water Maintenance and pre- Appropriate proper operation and comply with all
treatment Standards for maintenance of wastewater provisions of th18
Wastewater, Treatment treatment facUiUe. and regulation. Lagoon water
Works, and Indirect eewer lIystems within the wUl receive pretreatmsnt
Dischargss. 314 CMR 12.00 Itate. to remove hazardou8
compounds prior to
d18chargs into any
municipal treatment
facUity.
Surface Federal Clean Water Act- Relevant and Standard. that regulate the If lagoon watsr treatment
Water National Pollution Appropriate discharge of pollutants to 18 required, the water
cont'd) D18charge EUmination surface waters of the w111 be treated to meet
System (NPDBS) United StateB the applicable standards
prior to di8charQe.
Fsderal Clean Water Act Relevant and rANQC are non-regulatory If lagoon water8 are
(CWA) - rederal Ambient Appropriate concentrationB for the required to bB treated,
Nater QuaUty Criteria protection of aquatic 11fe, water will be treated to
(FANQC) and of human health from meet rANge.
water ingestion. and flBh
consumption.
Air MaBBachusetts Ambient Air Appllcable Regulation. specify primary Mitigative measure8 u8ing
QuaUty Standards - 310 CMR and lIecondary ambient air engineering control II,
6.00 quality standards to including foame, will be
protect public health and taken to control fugitive
welfare for certain dust released during
pollutants. excavation and
construction activitie8.
725054-24
-------
"ediu.'.
Authority
Air
(cont'd)
125054-24
. .
chemical-SDecif~c ARARs, criteria. Advisories. and Guidance
(cont'd)
'." ".,.'
AllAR
.. .:.::: ..":::.:~:~;r~?;~~:rr:.i:!{=r -r.;:t::;:~;~~.:~.~:;.:.~~~~i;~.8n~
Massachusetts Air Pollution
Control Regulations - 310
CMR 7.00
310 CMR 7.06
310 CMR 7.09
310 CMR 7.10
Applicable
Applicable
Applicable
Applicable
Regulations pertain to the
'prevention of emissione in
excess of Maseachusette or
national ambient air
quality standards or in
excees of emiseion limita-
tions in those regulations.
Regulatione epecify
requirements to prevent
vieible emiseione, not to
exceed the criteria eet
forth in the regulations.
Regulations specify
requirements to prevent
dust and odore - generated
during remedial actione -
which contribute to air
pollution.
Regulations epecify
requirements on
construction equipment to
supprese eound.
MaBBachuBettB DEP policy
requireB that the Bite
perimeter noiBe levele not
exceed 10 decibelB above
ambient noiBe levele..
4
""
Action to b. Taken to
Attain ARAR
Mitigative meaeuree ueing
engineering controls,
including foame, will be
taken to control
- emieeione from excavation
activities.
Mitigation measuree using
engineering controle,
including foame, will be
taken to control vieible
emiesione.
Mitigation measuree ueing
engineering controls,
including foams, will be
taken to control odors
and dusts.
Equipment with sound
suppreesion will be used
to reducs noise ievels to
below the regulated
level.
-------
Mediua' '
Authority
Air
Ccont'd)
725054-24
Chemical-SDecific ARARs. criteria. Advisories. and Guidance
(cant' d)
"
"
, AMR','
Ma88achu8etts Prevention
and/or Abatement of Air
Pollution Bpi80de and Air
Pollution Incident
Emergencies
310 CMR 8.00
Clean Air Act CCAA)
NAAQS for Total SU8pended
Particulate8 - 40 CFR 50
NAAQS for Hazardou8 Air
Pollutant8 - 40 CFR part
61
Federal - Occupational
lIeelth and Safety Act
caSUAl 29 CFR Sectlon
1910.1000-Air Contaminants)
, ;,; ,:':,';,:;:,; :"~~;;t;~~,:;~1;1:~;~J;;!}:;::~:: ",;t:;lt:~~~~~~:;,:~~': R~~~~re~.~~':>":;",;:"
Relevant and
Appropriate
Applicable
Applicable
To 8e Con8idered
Regulation8 8pecify
requirement8 to prevent
ambient air contaminant
concentration8 of any
location from reaching
levels which would
conetitute 8ignificant harm
or Imminent and substantial
endangerment to public
health.
Regulation 8pecIfie8
maximum primary and
secondary 24-hour
concentrations. Fugitive
dU8~ emiesion8 from site
excavation muet be below a
24-hfur average of 150
~g/m for particle8 having
a mean diameter of 10
micron8 or le88.
Regulation8 8pecify amounte
of emieeione fo~ pollutante
such a8 NO., S02' CO, lead,
mercury, and particulate8
for 8tationary sources.
TLV. are issued as criteria
for controlling air quality
for occupational settings.
STBLs are fifteen minute
time-weighted
concentration8. TWAs are
ba8ed on an 8-hour per day,
40-hour work week.
5
Aotion to be T8ken to
Attdn AKAR
Mitigative mea8ures u8ing
engineering method8
including foam8 and water
will b8 taken to control
fugitive dU8t released
during excavation and
constructIon activities.
Fugitive dU8t emissions
will be controlled during
excavation and
construction activitie8
with engineering methods
including foams and
water.
Engineering controle will
control emi8sions during
remedial activitie8.
Action level8 for
volatile and 8emi-
volatile air contaminants
will be established
during the design 8tage
and met by the
application of
engineering controls.
-------
Chemical-SDecific ARARs. criteria. Advisories. and Guidance
(cont'd)
6
... .. "",;,,\:/,:, "::3:. :'. ;':""':.~;;~~J.[~1:~'::I! $f¥.~H:,/f,::W'\lf?~.1:\/:{:.:::~Y":': ',""s.', . '.' : (.~~j;~>:, ":.:. ..
Medlu8' , ' : aOUOD'. to b' TakeD to
.. 'ARAR ':,~::;rIU"'.r.:fotRl!qubi8.Dt' .
Autbodtr ,. ,;,W:':fo:,:;.:"',,'i:: :.,.)..",,: ..;' .., Attala AltAR
I\ir state Hae8achu8ette To Be Considered ThiB guidance evaiuate8 MLs wUl be attained
(cont'd) Guidance on Allowable acute and chronic toxicity during all on -eite
Ambient Levels (AAL8) cited and 8ets draft AALe for remediation actlYities if
in chemlcal Health Effects volatUe and seml-volatUe technically feaalble.
AS8ee8ment Methodology and chemlcals. AAle che.icale
Methodology to Derive are con8idered in
Ambient Levels, DEP 1989 conjunction with BACT to
. meet the action spec if ic
appUcable requirements at
310 CMR 6.0 . throuqh 8.0
SoU
EPA DirectlYe for Lead To Be Coneldered Interim guidance on "11 so11 with lead above
(OSHER Directive 9355.4-02) estabUshing soll lead 500 ppm w111 be placed
cleanup level8 of Superfund ..nder the RCM Cap.
Sites recommend8 a
concentration of total lead
of 500 to 1,000 mq/kq.
725054-24
-------
7 .
'lULl IC-2
I
Location-Soecific ARARs. CrIterIa. Advisories. and auidance
. . .,..... ."',..:,il.,':" .:'::";::~':i::::;:1;1,~:'~:~'~~:~:~.f.;;:~l.::t,~J1~+,~.~::~~'..',:' ':,.;":-::"'. ..;'.. .. .. .'
MedIu.' AMR Statu. ...'. ...' .,.: Ae;t:1oil to. b. "811... to Attain AMK
Authodtr
Wetlands Massachusetts Appllcable These regulatIons include All woa:k, including installation
Wetland standards on dredging, f1111ng, of groundwater monitoring wells,
Profection al1:ering, or polluting inland to be performed within the 100-
Act (WPA) wetlands. Work withIn 100 feet foot bu ff er zone will be done in
Regulations - of a wetland i8 regulated under accordance wlth these regulations.
310 CMR 10.00 these requirements.
Waste Siting Massachusetts Applicable Requirements for the expeditious Any remedial activities to occur
Regulations Hazardous and safe siUng of hazardous within the 100-foot buffer zone of
Waste waste facUities in the Com- Site Wetlands will meet these
FacUity monwealth, which include requirements. '
SiUng controls on the construction,
Regulations - operation, and maintenance of
990 CMR 1.00 new facIliUe. for storage
treatment or dleposal of
I hazardous waste.
125054-24
-------
(cont'd)
2
1
Mediu./ ARAR statua Su_al"J 01 Requil"e.ent
Authority Action to be Taken to Attain ARAR
Rlven/eNA Federal- 16 Applicable Mitigative actions must be Relevant. federal agencie. will be
USC 661 taken to minimiEe potential contacted to help analYEe impact. of
et..eq. Fi.'" adverse impact. to natural the implementation of remedial
and Nildlife sources .uch a. wetland.. alternatives on wildlife in wetlands
Coordination R~storation of damaged natul"al and rivere. If required, restoration
Act feature. are required. of impacted wetlande will occur once
all excavation and etabiliEation
activitiee are completed.
Netlands/cNA Federal-Clean Applicable Requiremente under these codee Dischargee to wetlands around the
Nater Act prohibit the discharge of eite will comply with these
(CNA) Section dredged or fill material into I"equiremente.
404(b)(I), 40 wetlande unle.. those action.
CFR part 230, comply with the substantive
33 CFR parts requiremente which are
320-330 identified under the.e
regulations.
Netlands/CNA Federal Applicable Under this regulation, Federal Net lands protection consideratione
Executive agencies are required to will be incorporated Into the
Orders 11990 minimiEe the destruction, 108s planning and implementation of this
or degradation of wetlands, and selected remedy.
preserve and enhance natural
and beneficial valuee of
wetlands.
TA8LB 8C-2
Location-SDeclllo ABAR.. el"lterla. AdYI.ol"l... and aUldaac,
. 125054-24
-------
TADL8 SO-2
~ON-SPBCIPIC ARARs. CRIT.~IA. ADVISORIB8 AND GUIDANCB
Mediu., MAR status 8uaaary of Require.ent Aotion to be Taken to
Authority Attain AltAR
Treatment Federal-40 CFR Relevant This subpart applies to all ~he selected remedy will
Facility Part 264.10- and owners and operators of comply with all substantive
operationsl 264. 18 (Subpart Appropriate hazardous waste facilities. portions of this
RCRA B) General The subpart identifies requirement during the
Facility procedures which must be application of the RCRA
Standards followed for the operation and Cap.
maintenance of a hazardous
waste TSD facility.
TSD Federal-40 CFR Relevant Identifies requirements which All waste will be handled
Facility Part 264.30-37 and must be met during design, to conform with standards
Prepared- (Subpart C) Appropriate construction, and operation of to minimize the danger of
ness and Preparedness TSD Facilities to minimize fire or unplanned releases
Prevention I and Prevention possibility of fires, of hazardous compounds.
RCRA explosions or unplanned
releases of waste.
National Federal-40 CFR Applicable EPA administered permit All discharges of lagoon
Pollutant Parts 122 and program which allows private water to surface water will
Discharge 125 National parties to discharge comply with all NPDES
Elimination Pollutant pollutants from a point source substantive requirements.
System/CWA Discharge into the "Waters of the united
Elimination States. II
-------
TADLB SC-2 (Cont'dl
ACTION-SPBCIFIC ARARs. CRITERIA. ADVISORIES AND GUIDANCE
Hediwa! ARM Status SUllllary of Requirement Aotion to be Taken to
Authority Attain ARJ\R
Treatment State-310 CMR Applicable The Hazardous Waste Regulations The selected remedy will
and 30.00 310 CMR 30.00 govern the comply with the substantive
Disposal! Hazardous generation of, listing, handling, requirements under each
nCltA Waste storage, transporting and sub-part that pertains to
Regulations. 3 disposal of hazardous wastes. on-site or off-site
10 CMR 30.00 activities.
is
enforoeable -
I under H.G.L.
CH.21Css.4
and 6.and .
M.G.L.Ch.211
s.6.
Treatment Federal-40 Applicable Regulates the treatment of RCRA The selected remedy will
and Disposal CFR 260 to hazardous wastes handling and comply with the substantive
RCRA 264 Hazardous storage. requirements under each
Waste sub-part that pertains to
Regulations on-site or off-site
activities.
Groundwater State-310 CMR Applicable Groundwater Protection A groundwater monitoring
Protection! 30. 660Ground- requirements (310 CMR program which meets the
RCRA water 30.660)apply to monitoring requirements of 310 CHR
Protection. requirements and closure of ]0.660 and 310 CMR 30.672
This citation surface impoundments. will be implemented
includes the Groundwater protection programs throughout the post-closure
requirements must be conducted after closure period for the site.
of 310 CHit if required by the approved
30.661 thru. operating permit. Groundwater
30.673. monitoring or corrective action
monitoring(]10 CHR ]0.672)are
required anytime concentrations
of chemicals in the groundwater
exceed levels established by
the department in accordance
-------
TABLB SC-Z fCont'4)
ACTION-SPBCIFIC ARARs. CRITBRIA. ADVISORIES AND GUIDANCE
Medium/ ARAR Status Summary of Requirement Aotion to be Taken to
Authority I Attain AltAR
Air state-JIO CMR Applicable These regulations govern The selected remedy will
Discharges/ 6.0-8.0 Air emissions to the air from new comply with the use of Dest
CI\I\ Quality sources. Sources must not cause Available Control '1'echno-
Control a condition of air pollution. logies(BACT)and will not
Regulations In addition there are specific contribute to a condition
standards for PIcs,CO.,OJ,pb of air pollution.
and so.. '1'l1e state applies this
standard by examining AALs and
other air modeling and
monitoring data and by
requiring standard controls
available for some of the more
I common remedial technologies.
I
Noise state-JI0 CMR Applicable This regulation requires that On-site construction/
7.10 Noise all equipment, machinery and/or remediation activities will
operations which generate noise be conducted during normal
(sound),be operated in a manner working hours and comply
which minimizes the generation with the requirements of
of sound or be fitted and this regulation.
accommodated with noise
reducing equipment and
measures.
Air/ State-JI0 CMR Applicable Any operation which generates On-site remedial activities
lJischarges '1.09 dust and odors shall be per- will be performed in a
Dust,order,co formed in a manner which does manner which minimized dust
nstruction, not generate significant generation. If significant
and quantities of dust which if quantities of dust are
Demolition generated would cause or generated, then mitigative
contribute to a condition of measures will be employed
air pollution to reduce the levels of
-------
He4ium/
Authority
Surface
Water
Protectionl
CWA
Surface
Water/CWA
Air/CM
TABLB SC-Z (Cont'4)
ACTIOH-SPRCIFIC ARARs. CRITRRIA. ADVISORIRS AND GUIDANCB
ARM
State-314 CMR
3.00 (Promul-
gated under
MGL Chapter
21.S.27 and
s.43)
Massachusetts
operation and
Maintenance
and Pretreat-
ment
Standards for
Wastewater
Treatment
Works and
Indirect
Discharge 314
CMR 12.00
Federal-CM-
National
Ambient Air
Quality
standards
(NAAQA) (40
CFR 50 , 61)
8tatus
Applicable
Applicable
Applicable
8uaaary of Requirement
Discharges of any pollutant to
any surface water in the State
of Massachusetts must have a
valid discharge permit from the
Division of Water Pollution
Control(DWPC)-314 CMR 3.04. This
discharge permit (called a
National Pollutant Discharge
Elimination system(NPDES)permit)
is issued jointly by the EPA and
the DEP.
Regulations to ensure proper
operation and maintenance of
wastewater treatment facilities
and sewer systems within the
Commonwealth.
\
HMQS define levels of primary
and secondary levels for six
common air contaminants(sulfur
dioxide, particulate matter
"PMIO" carbon
, .
monoxide, ozone, nitrogen dioxide
and lead).
Aation to be Taken to
Attain MAR
Any remedial activities
conducted on-site will be
conducted under CERCLA
Sections 104 or
106;therefore, no federal
ox state permits will be
required. lIowever, the
selected remedy will comply
with the standards or
discharge limits and
activities covered by any
permits which would
normally be required.
Remedial activities will
comply with all provisions
of this regulation.
The levels established for
these six air contaminants
will" be used as target
levels which may not be
exceeded by air release
-------
MediulII'
Authority
Air
Dischargel
CM
RCRA-
Closure
Requirements
Federal
TABLB SC-2 fCont'd)
ACTIOD-SPBCIFIC ARABs. CRITBRIA. ADVISORIBS AND GUIDADCB
J\RJ\R
state-Mass.
Guidance on
Allowable
Ambient
Levels(AALs),
cited in
Chemical
lIealth
Effects
Assessment
MethodoloGY
and
MethodoloGY
to Derive
Allowable
Ambient;
Levels, DEP,
1989.
TSD Facility
Closure and
Post Closure
Subpart G -40
CFR 264.110
to .120
and 264.228
status
To be
considered
Applicable
summary of Requirement
I
This guidance evaluates acute
and chronic toxicity and sets
draft AALs for volatile and
semi-volatile chemicals. MLs
have been issued by the DEP for
108 chemicals to date. The AALs
to be considered,modeled, and
mdnitored for are considered in
conjunction with BACT to meet
the action specific applicable
requirements at 310 CMR 6.0 thru
8.0 in "not causing a condition
of air pollution."
Identifies the requirements for
closure of surface impoundments
and provides for monitoring
requirements.
,
Aotion to be Taken to
Attain ARAR
The selected remedy will
attain AALs during on-site
remediation activities if
technically feasible.
.
The selected remedy will
comply with all the closure
and monitoring requirements
for surface impoundments.
-------
'-".... ~ .-. .~. ~~....
-..
. --"""~ ..- .~. -.-..._... - .~..
-------
Commonwecrth Of McssaChuse;;s
execUtive Office of Environmentcl Affairs .
Department 0'
Environmental Protection
-
-
--=-
D E P
WIllIam F. Wetd
aa....ar
Daniel S. Gt8enuum
COI'fUTh---.
Ma.:ch 24, 1993
Mr. Paul Keough
Accing Kegicnal Adminiscracor
u.s. £nv~ronmental Protection Agenc'l
Region 1 . ..
JFK Fede:al Building
Boscon, ~A 02203
Re:-Salem Acres Federal
Sut)erfund Site
ROD Concurrence
Dear Mr. Keough:
The Department of Envi:onmental Protection (the
"Department") has reviewed the preferred and contingent remedial
alternatives recommended by EPA for final cleanup at the Salem
Acres Federal Superfund Site, the core provisions of which are
summarized below. The Department has worked closely with EPA in
developing t~e preferred alternative and is pleased to concur
with EPA's choice of this as the selected remedial action. In
addition, the Department concurs with the contingent remedial
alternative.
The Department ha~ evaluated the preferred and contingent
alternatives for consistency with M.G.L. c. 21£ ("21E") and the
Massachusetts Contingency Plan (the "MCP"). The alternatives
were also evaluated for consistency with proposed revisions to
the MCP which are currently under consideration. The preferred
alternative addresses the entire site as one operable unit and
includes the following components:
1.
Refined delineation of soil and sludge areas requiring
remedial actions;
2.
Stabilization of sludge by addition of fly ash
rendering the material non-toxic, non-ignitable and
otherwise not hazardous under RCRA;
Excavation of contaminated soils, fly ash, and
stabilized sludge for disposal in a permitted solid
waste landfill; and
3.
4.
Additional monitoring of groundwater, surface water and
wetland sediments.
One WI...., SIr88t
. IoatDn, M88ucIw88tt8 02101
.
fAX (117) 55ao1049
-------
- .....-.-.--'.---' _h._._... -
R~giona: Adm~~is~ra~or
Superfu.~d Si~: ROD Concurrence
?a~l Keough, Ac:~ng
Salem Acres Federal
March 24, 1993
1?age 2 of 3
:I
The preferred a::erna~~ve w~ll be implemen~~d provided all
.,f the following cri:eria are me:: .
1.
2.
3.
Trea~abili~y and Pilot Studies mus~ demonstra~e tha~
the pr=cess used to stabilize the sludge renders the
sludge non-ignitable, non-toxic ~~d o~herwise not
hazardous as defi~ed under RCRA (40 CFR 261.21 and
261.24);
All wastes from the si~e, once stabilized as described
above, can be classified as nspecial waste" under.
Massachuse::s Solid Waste Regulacions (310 CMR 19.00);
A permitted solid waste landfill operator is willing to
issue a le::er of commitment to accept the s~abilized
waste for disposal; and
The' stabilized was~e mee~s the criteria for disposal at
that permitted landfill pursuant to applicable statutes
and regulations (~I 310 CMR 19.00) and the disposal
of such waste is not prohibited under the landfill Site
Assignment.
If anyone of the preceding four criteria cannot be met, the
~ontingent alternative will be implemented, consisting of the
following:
4.
1.
Refined delineation of soil and sludge areas requiring
remedial accions;
Evaluation of the feasibility of consolidating the
various waste disposal areas;
2.
3.
Construction of an on-site .RCRA Subtitle C Cap or Caps
for containment of wastes;
4.
I
Additional monitoring of groundwater, surface water and
wetland sediments;
Implementation of institutional controls;
5.
6.
Long-term operation and maintenance of the remedy; and
cERCLA 5-year reviews of the remedy effectiveness.
-------
:a11 Keough, Acting
Sa~~~ Acres Federal
Ma.:-ch' 24, 1993
. Pa~= 3 of :3
Regier.al A~"~nistrator
Super:und Site ROD Concu-~ence
.
The Department's cor.c~rre:ce with the preferred remedial
a::!~ative is based upon the expectatier. that it will result in
a ?!~anent solution as defined in 21£ and the MCP. The
De~lr~ment's concurrence with the contingent alternative is based
Up~1 the expectation that it will result in a temporary solution
as iefined in 21£ and the'MCP. In addition, under the pro~osed
re~~sions to the MCP (assuming no significant changes prior to
ac.c~'tion), the Department notes that the contingent alternative
may constitu:e a permanent solution.
The Department also notes that, based on the proposed
c:e.mup numbers in the ROD, the preferred and contingent
a:1;~rnatives appear, on their face, to be inconsistent with the
Tct::tl Site Risk requirements for permanent and temporary remedies
cc::'.ained in the MCP. However, the Depa.."'tment bases its
cor:',:\L."'Tence on the expectation that residual levels of
cor:'..amination will, in fact, be significantly lower than the ROD
cle.~u~ numbers. This is because of the discrete nature of the
was~e areas to be remediated which, the Department anticipates,
wo~:d result in the preferred and contingent alternatives
ex~. 'eding the proposed cleanup numbers. '
The Department would like to thank £PA, in particular the
rea.!dial project manager, Joe DeCola, and the section chief,
Pa~~a Fitzsimmons, for their efforts to include the Department in
th~~ process. We look. forward to continuing work with you in
im;:ementing the selected remedial actions. If you have any
que.tions, please contact Jay Naparstek at 292-5697.
Very truly yours,
~~. Commissioner
De~~ment of Environmental
Protection
------- |