United States
                  Environmental Protection
                                              Solid Waste and
                                              Emergency Response
    Winter 1993
V>EPA        Superfund  At Work
                  Hazardous Waste Cleanup
                             Success In Brief

                             Cleanup Begins at Wells G&H,

                             One Year After Landmark

                             New England Settlement

                               In July 1991, The U.S. Environmental Protection Agency (EPA)
                             negotiated a record-breaking Superfund settlement for cleanup of
                             municipal wells "G" & "H" in Woburn, Massachusetts. One year
                             later, comprehensive cleanup activities have begun at four of the site's
                             five property areas. Contamination of the wells was discovered in
                             1979 when local residents suspected that an unusually high incidence
                             of childhood leukemia was linked to drinking water.  EPA's
                             Superfund enforcement efforts yielded a resolution in which:
                              Settling parties agreed to a cleanup worth approximately $70
                               million, the largest Superfund settlement in New England. The
                               agreement directs cleanup of four properties simultaneously;
                              EPA achieved this record settlement in only four months of nego-
                               tiations; and
                              Initially recalcitrant polluters realized they were better off cooperat-
                               ing with the Superfund process, and are working with both EPA
                               and the community as partners.
       Wells G&H
       Site Profile
Site Description: Two municipal
drinking water wells located in
Woburn, Massachusetts.

Site Size: 330 acres

Primary Contaminants:
Volatile organic compounds
(benzene, PCE, TCE), organics, lead,
pesticides, PCBs, PAHs

Potential Range of Health Risks
Without EPA Cleanup:
Skin irritation, increased risk of
cancer resulting from contact with
and ingestion of contaminated soil,
sediments, or ground water

Nearby Population Affected:
36,000 residents in Woburn

Ecological Concerns: Effects of
contaminated river sediments on
wildlife and invertebrates

Year Listed on the NPL: 1982

EPA Region: I

State: Massachusetts

Congressional District: 4
                     The Wells G&H Site
 City police discovered abandoned drums at the site, which is located in east
 Woburn, Massachusetts. Two municipal wells were contaminated, leading to
 EPA investigation and cleanup.
                                                         The Site Today

                                                           As of September 30,1992,
                                                         two of the four settling parties
                                                         began pumping and treating
                                                         contaminated ground water.
                                                         Excavation of contaminated soil
                                                         is underway at two other prop-
                                                           Under the settlement, the
                                                         companies agreed to clean up
                                                         the sources of pollution at four
                                                         of the five site properties. Ne-
                                                         gotiations are taking place
                                                         between EPA and parties asso-
                                                         ciated with the fifth property.

                   Superfund At Work
         Wells G&H, Woburn, Massachusetts
                         Winter 1993
  The Wells G&H site includes
two municipal wells (G & H), 330
acres of land surrounding the
wells, and a part of the
Aberjona River. TheAberjona
River flows through the site and
into the Mystic Lakes. Wetland
areas are found on both sides of
the river. The site is located in
east Woburn, Massachusetts, a
small city of 36,000 people
about 12 miles northwest of
  Within the site boundaries,
the area surrounding Wells G &
H is used for several purposes
including light industry, com-
mercial business, industrial
parks, residences, and recre-
ation. The area is surrounded
by industrial and commercial
property to the north, and
residential property to the
    A Site Snapshot
      The property owners primarily
    liable for the contamination of
    Wells G&H are: W.R. Grace,
    UniFirst Corporation, New
    England Plastics, Olympia Nomi-
    nee Trust, and Wildwood Conser-
    vation Corporation. Beatrice
                       Foods is also a liable party; the
                       former Beatrice property has
                       since been purchased by Wild-
                       wood. A combination of illegal
                       dumping and accidental spills
                       on these properties created a
                       variety of pollution problems.
                          The ground water at the site
                       is contaminated with volatile
                       organic compounds (VOCs)
                       like trichloroethylene (TCE).
                       Sediments in the Aberjona
                       River are contaminated with
                       polynuclear aromatic hydrocar-
                       bons (PAHs) and heavy metals
                       such as  chromium, zinc, mer-
                       cury, and arsenic. Soil is con-
                       taminated with PAHs, poly-
                       chlorinated biphenyls (PCBs),
                       VOCs, and lead. Exposure to
                       contaminated soil, river
                       sediment, or ground water
                       may cause an increased risk
                       of cancer.
  Wells G&H
                                      EPA orders Olympia to remove drums

             Full-blown EPA investigation begins of entire 330-acre site

            Three property owners ordered to study
            ground water and soil contamination
            Site is listed on NPL

         Site is proposed for NPL
                   EPA investigates ground water
             Superfund is enacted
  Woburn city police discover
  abandoned drums
  State discovers contamination in
  two municipal wells
  State closes the wells and
  provides alternate water supply
                                           Page 2

Superfund At Work
Wells G&H, Woburn, Massachusetts
Winter 1993
Superfund Responds to Tragic Contamination
State Moves to Protect Citizens
Opened by the City of Woburn
in the mid-1960s, Wells G & H
were tapped to supplement the
existing municipal water supply.
Although there are no reliable
records indicating how often the
wells operated, local officials
estimate that the wells provided
30% of the municipal water
supply until 1979.
At that time, citizens com-
plained of the bad taste and odor
of their drinking water. Investiga-
tions by city police turned up
nearly two hundred 55-gallon
drums of industrial waste that
were abandoned on a vacant lot
near the wells. Subsequent testing
by the Massachusetts Department
of Environmental Protection
revealed high levels of TCE and
other industrial solvents contami-
nating the ground water. The
wells were shut down in 1979,
and the City of Woburn re-
enacted an agreement with the
Massachusetts Water Resource
Authority to permanently supply
residents with safe drinking water.
Superfund Sets
Cleanup in Motion
In April 1980 --eight months
before Superfund was enacted -
a public meeting was organized
by a local citizens group. This
meeting brought together EP A
and the Massachusetts Depart-
ment of Environmental Quality
Engineering (MEQE), to discuss
with citizens the pollution of
Wells G & H. At the meeting,
EP A announced its intent to
study the extent of contamination
at the site.
About this time, the commu-
nity also became aware of what
. EPA orders UniFirst to install monitoring wells and remove contaminant
. EPA finishes soil and ground water studies
. EPA determines long-term cleanup approach
appeared to be a cluster of child-
hood leukemia cases near the site.
During a public meeting, cases of
childhood leukemia were identi-
fied, several within a small neigh-
borhood near the wells. Citizens
also were concerned by the
elevated rate of birth defects and
cancer in the local population,
and suspected that their exposure
to contaminated drinking water
had caused these illnesses. Com-
munity concerns regarding
environmental hazards sparked
the formation of the citizens
group, For A Cleaner Environ-
ment (FACE) in October 1979.
FACE subsequently became a
voice for the citizens ofWoburn
on the environmental and public
health impacts of the site.
In 1982, eight families who had
lost children to leukemia filed a
highly publicized civil suit against
. Companies jointly agree to conduct cleanup
. Landmark $70 million agreement lodged with
federal court
. Companies begin design of long-term cleanup
Page 3
. Two of five companies begin
long-term ground water cleanup
. Two others begin soil

Superfund At Work'
Wells G&H, Woburn, Massachusetts
. Winter 1993
some of the alleged polluters of the
site. National and local media
followed the ease, keeping the focus
on issues of liability. EP A faced a
challenging situation at the site
because of this coverage. Site
investigations were initiated in an
emotionally charged atmosphere,
coupled with friction among the
EPA used its enforcement
authority under Superfund
and RCRA to pursue
the polluters
polluten; as some denied responsi-
bility for the ground water con-
In December 1982, the site was
proposed for the National Priori-
ties List (NPL), EP A's roster of
hazardous waste sites eligible for
comprehensive cleanup under the
Superfund program. In Septem-
ber 1983, EPA used its enforce-
ment authority under Superfund
and the Resource Conservation
and Recovery Act (RCRA) to
order the following cleanup
. In 1983, EPA ordered three
property owners (W.R. Grace,
Beatrice Foods, and UniFirst) to
fully study the nature and
extent of contamination on
their properties.
. In 1985, EPA ordered Wild-
wood Conservation Corpora-
tion to put up a fence and hire a
24-hour security guard to
prevent entry by the public to
the contaminated soil.
. In 1986 and 1987, EP A issued
two orders to Olympia Nomi-
nee Trust to remove all drums
and debris from the western
portion of its property to an off-
site, licensed facility.
. Also in 1987, EP A ordered
UniFirst to install monitoring
wells and remove pure
tetrachloroethene found in a
well on the property.
In September 1988, EP A con-
cluded its own detailed investiga-
tions, which demonstrated that
ground water contamination
specifically came from five proper-
ties located around the municipal
wells. The following September,
after modifying proposals based on
public comments, EP A selected its
long-term approach for the site.
An Innovative Oeanup
The plan calls for cleanup of soil
and ground water using three
different methods:
. Some of the contaminated soil
will be cleaned in place through a
process called vacuum extraction.
This innovative technology uses
vacuum pumps to draw air out
of the soil. The VOCs trapped in
the dirt are suctioned out through
wells installed around the site.
The air passes through a chamber
where contaminants are filtered
out, and the treated air is re-
leased. This technology mini-
mizes damage to environmen-
tally sensitive areas, and reduces
the potential for exposure to site
contaminants during treatment.
. The areas of the site that are
contaminated with PCBs, P AHs,
and pesticides cannot be treated
effectively with vacuum extrac-
tion. These areas will be exca-
vated and treated in an off-site
licensed hazardous waste incin-
. The ground water will be
pumped and treated by various
methods. Contaminants will be
removed in separate treatment
plants designed to address the
Page 4
particular mix of contamination
present at each site. Ultra-
violet oxidation, an innovative
treatment, is one method that
will be used to remove volatile
organics from ground water.
UV radiation is combined with
ozone, hydrogen peroxide, or
both; its main advantage is that
only carbon dioxide and water
are released during the treat-
ment phase.
As of September 30,1992, just
over one year after signing the
agreement, W.R. Grace and
UniFirst have begun long-term
ground water cleanup at their
respective site areas, and Wild-
wood and New England Plastics
have begun soil excavation.
II ...We achieved agreement on
a record-setting settlement
that lets us begin the
comprehensive cleanup owed
to the people of Woburnll
-- Julie Belaga, EPA Official
EP A Reaches Record-Breaking
A cooperative effort that now
exists between EPA and the
polluters would not have oc-
curred without EP A's initial use
of Superfund enforcement tools to
set the cleanup process in motion.
Even with the civil litigation
and resulting friction between the
companies, EP A negotiated in
only four months the largest
Superfund settlement in the
history of New England. U.S.
Attorney General Scott
Harshbarger noted the signifi-
cance of the settlement: "As a
result of the cooperative effort, the
cost of undoing the environmen-
tal damage will be shouldered by

continued on page 5

Superfund At Work.
Wells G&H, Woburn, Massachusetts
What is a Technical
Assistance Grant?
When Congress amended
the Superfund law in 1986,
EP A identified the need for
greater involvement by com-
munities affected by hazard-
ous waste sites. The Technical
"The TAG has been a
real boost to our
organization and has
helped us articulate our
- states FACE member
Assistance Grant (TAG) Pro-
gram provides qualified local
groups with up to $50/000 to
help them hire independent
technical advisors. These
advisors interpret the technical
Superfund Responds
continued from page 4

the responsible parties, not the
EP A Regional Administrator
Julie Belaga remarked, "After a
relatively short period of negotia-
tions, we achieved agreement on
a record-setting settlement that
lets us begin the comprehensive
cleanup owed to the people of
Under the terms of the settle-
ment, the companies are:
. Performing the cleanup, val-
ued at $58.4 million;
. Financing EP A's monitoring of
all cleanup activities, valued at
$6.4 million;
TAG'ed.for Success
elements of cleanup so that
residents can make more in-
formed decisions about the
remedy selected for a site.
The community group contrib-
utes 20% of the total costs of the
project and manages the TAG for
an average of three years. Only
one TAG is awarded per Super-
fund site.
Ideally, technical advisors
should be experts in chemistry,
engineering, epidemiology,
hydrology, hydrogeology, or
other advanced sciences, and be
able to translate the contents of
technical documents to plain
English. The consultant may
assist the group or community in:
(1) reviewing site-related docu-
ments, whether produced by EP A
or others; (2) meeting with the
community to explain technical
. Performing a study of the area
immediately surrounding
Wells G & H; and
. Reimbursing EP A for its past
investigation costs, valued at
$2.65 million. In total, the
companies will perform
cleanup work valued at almost
$70 million.
Dialogue Aids Cleanup Process
There has been a great deal of
community concern and involve-
ment associated with the Wells
G & H site. At each stage in the
cleanup, EP A kept the public
informed and addressed concerns
through informational meetings,
fact sheets, and press releases.
Page 5
. Winter 1993
information; (3) communicating
the group's site-related con-
cerns; (4) disseminating inter-
pretations of technical informa-
tion to the community; and (5)
participating in site visits, when
possible. The technical advisor
can help the community gain a
better understanding of
cleanup activities.
to Date
$4.5 million
In 1989, EPA awarded the
community a Technical Assis-
tance Grant (TAG), enabling
residents to hire a technical
advisor to help them participate
more actively in the decision-
making process. Using this grant,
the site workplans and all EP A
documents are being reviewed
and commented on by the citi-
zens' group, FACE.
Despite the emotional issues
surrounding the Wells G & H site,
a steady dialogue between the
responsible parties, EP A, and the
neighboring community is facili-
tating the long-term cleanup.

                   Superfund At Work
                   Wells G&H, Woburn, Massachusetts
Winter 1993
Private Party Cleanup Commitments

  The payment of $70 million to clean up the Wells G&H site is just
one example of an increasing national trend toward responsible party
settlements . Total private party commitments are currently valued at
$7.4 billion, with more than two-thirds of this amount settled in the last
four years. This trend is due largely to two factors. First, after many
years of court battles over pollution liability, the courts now have
much clearer precedents for judging a party's responsibilities at a site.
Second, EPA's "Enforcement First" policy has led to an increased use
of tough legal tools to make polluters pay. Thus, potentially respon-
sible parties are now much more likely to cooperate with EPA than in
the early days of Superfund.
       $2 -
Cumulative Estimated $ Value of
      Responsible Party
     Work Commitments
     Success at

   Wells G&H
    Following the con-
tamination of two munici-
pal wells in Woburn,
Massachusetts, EPA re-
sponded by aggressively
pursuing polluters and
compelling them to take
responsibility for the
entire cleanup.
    By signing a July 1991
agreement, the property
owners consented to the
largest Superfund settle-
ment in New England
history.  Such enforce-
ment underscores the
continued importance of
and need for EPA's
Superfund program.
1980 1986 1992
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