UntodStUM Environmental Agenqr EPA/ROD/R01-88/026 September 1988 A EPA Superfund Record of Decision: Iron Horse, MA ------- REPORT DOCUMENTATION PAGE 1. REPORT NO. EPA/ROD/R01-88/026 Recipient's Accession No, THte and Subtitle JPERFUND RECORD OF DECISION fron Horse Pack, HA Ipicst Remedial Action 7. Authors) 8. Performing Organization Kept. No. 9. Performing Organization Nam* and Address 10. Proiect/Taik/Work Unit No. 11. ContraeMC) or Grant(O) No. (C) (G) 12. Sponsoring Organization Name and Address U.S. Environmental Protection Agency 401 M Street, S.W. Washington, D.C. 20460 IS. Supplementary Notes 13. Type of Report & Period Covered 800/000 14. 1C. Abstract (limit: 200 words) ~~ The Iron Horse Park site is a 552-acre industrial complex and railyard located in North Billerica, Massachusetts. The site includes manufacturing and railyard maintenance facilities, open storage areas, landfills, and wastewater lagoons. A long . history of activities at the site has resulted in contamination of soil, ground water, •kid surface water. In August 1984, EPA, under its removal authority, covered an onsite Mrsbestos landfill located northwest and adjacent to the lagoons area. In September ^.984, the site was placed on the NPL. In 1985, EPA began evaluations of the site and concluded that the size and complexity of the site, as well as the discreet nature of the contamination, necessitated dividing the site into several separate problem areas. This ROD addresses the cleanup of the Boston and Maine Wastewater Lagoons (B&M Lagoons) and surrounding area, which are operated by Boston & Maine (B&M) Corporation. The B&M Lagoons are a series of lagoons located within a ISO-acre parcel of land leased from the Massachusetts Bay Transportation Authority, which uses most of the land to operate a passenger rail service. The lagoons have been receiving untreated industrial and sanitary wastewater from the manufacturing and railyard maintenance facilities since 1915. The lagoon area consists of the North and South lagoons, currently receiving wastewater, an overflow lagoon, one inactive lagoon used until 1954, and an empty lagoon (See Attached Sheet) 17. Document Analysis a. Descriptors Record of Decision Iron Horse Park, MA First Remedial Action Contaminated Media: debris, sludge, soil organics (PAHs), VOCs la^va" COSATI Held/Group Availability Statement 19. Security Class (This Report) None 20. Security Class (This Page) None 21. No. ol Pages 22. Price (See ANSI-Z39.18) See Instructions on Reverse OPTIONAL FORM 272 (4-77) (Formerly NTIS-3S) Department of Commerce. ------- PPA/ROD/R01-88/026 Iron Horse Park, MA First Remedial Action 16. ABSTRACT (continued) that was never used. The lagoons contain approximately 7,800 yd^ of soil and sludge contaminated primarily with VOCs, low levels of PAHs, and metals. In addition, approximately 20,000 yd^ of soil and sludge dredged from the lagoon bottoms and disposed in piles along the lagoon banks are contaminated with low levels of organics and metals. The piles of dredged material and the sludge in the lagoons are considerd to not contribute significantly to ground water contamination. This conclusion is based on the results of the TCLP test which indicates that these materials do not leach contaminants in significant concentrations. Additionally, the contaminants found in these materials are generally not found in the ground water. B&N has been ordered to stop discharging wastewater to the B&M Lagoons by the end of 1988, and plans to tie-in to the town of Billerica's sewer system. Subsequent ROOs will address other portions of the site including a landfill and site-wide ground water. The primary contaminants of concern affecting the soil, sludge, and debris are VOCs, organics including PAHs, and metals including arsenic and lead. The selected remedial action for this site includes: excavation and onsite -biodegradation of contaminated soil and sludge with residual disposal to the lagoon area •ollowed by covering with a clean soil cover and revegetation; and decontamination of ^he lagoon system piping and pumps. The estimated capital cost for this remedial action is $2,273,000 with present worth O&M of $47,000. ------- RECORD OF DECISION Boston & Maine Wastevater Lagoons Iron Horse Park Horta Billerica, Massachusetts STATEMENT OF PURPOSE This decision document represents the selected remedial action for the Boston & Maine Wastevater Lagoons at the Iron Eorse Park Superfund site in North Billerica, Massachusetts. The remedial action was developed in accordance with the Comprehensive Environmental Response, Compensation and Liability Act of 1980 (CERCLA), as amended by the Superfund Amendments and Reauthorization Act of 1986 (SARA), and to the extent practicable, the National Contingency Plan, 40 CFR 300 et seq., 47 Federal Register 31180 (July 16, 1982), as amended. The Region I Administrator has been delegated the authority to approve this Record of Decision. The Commonwealth of Massachusetts has concurred on the selected remedy and has determined that it will attain applicable or relevant and appropriate Massachusetts laws and regulations. STATEMENT OF BASIS This decision is based on the Administrative Record for the site developed in accordance with Section 113(k) of CERCLA. The attached index identifies the items which comprise the Administrative Record. The Administrative Record is available for public review at the Billerica Public Library and the EPA Region I Waste Management Division Records Center at 90 Canal street in Boston. DESCRIPTION OF THE SELECTED REMEDY Scope and Role of Operable Units in the Response Action The response action for the B&M Lagoons is being conducted as an operable unit for the cleanup of the contaminated soil and sludges found in and around the lagoons. It is a source control remedy that is consistent with achieving a permanent remedy for the Site. The remediation of groundwater is not part of this response action; however, the cleanup of the soil and sludges will be consistent with future groundwater remedies and will ensure that releases of hazardous substances from the soil and sludges into groundwater are mitigated. An operable unit is a discrete portion of an entire response, that decreases a release, threat of release, or pathway of exposure. ------- Components of tbe gelected Remedy Tbe selected remedy is a source control response action for tbe BUI Lagoons. It includes* treating tbe contaminated soil .and sludga from tbe lagoons by bioraa«diation; ratuming tha traatad material to tba lagoon area, covering it witb olaan soil and astablisbing a vegetative eorar; and daeoataainating tba lagoon S7staa*s piping and pomps. Tba ramady a*«uaas tbat tba disobarg* to tba lagoons will eaasa. DECLARATION Tba salaotad raaady is protaetiva of buman baaltb and tba anvironaaat, attains fadaral and Btata raquiramants tbat ara applioabla or ralavant and appropriata for tbis raaadial action and is eost-affactiva. Tbis ramady satisfias tba statutory prafaranea for raaadias tbat utiliia traataaat as a principal alamant to raduca tba toxicity, mobility, or voluma of basardous substaneas. In addition, tbis ramady utiliias parmanant solutions and altarnativa traatmant tacbnologias to tba maximum axtant practicable. DataMiebaal & Daland Regional Administrator ------- RECORD OF DECISION SUMMARY BOSTON & MAINE WASTEWATER LAGOONS AT IRON HORSE PARK TABLE OF CONTENTS Contents I.- II. A. B. III. IV. V. VI. VII. VIII. A. B. IX. X. A. B. XI. A. B. C. D. E. XII. Page Nuinher Site Location and Description Site History and Enforcement Activities Response History Enforcement History Community Relations ... Scope and Role of Operable Units in Response Action . B&M Lagoon Characteristics. ... Summary of Site Risks No Significant Changes to the Selected Alternative. Development and Screening of Alternatives Statutory Requirements/Response Objectives .... Technology and Alternative Development and Screening Description and Evaluation of the Remedial Alternatives Description of the Selected Remedy Rationale for Remedy Selection Statutory Determinations The Selected Remedy is Protective of Human Health and the Environment The Selected Remedy Attains ARARs The Selected Remedial Action is Cost-Effective . . The Selected Remedy Utilizes Permanent Solutions and Alternative Treatment Technologies or Resource Recovery Technologies to the Maximum Extent Practicable The Selected Remedy Satisfies the Preference for Treatment as a Principal Element State Role 1 1 1 3 4 5 5 13 15 15 15 17 18 21 21 26 28 28 28 30 31 31 31 ------- RECORD OF DECISION SUMMARY BOSTON & MAINE WASTEWATER LAGOONS AT IRON HORSE PARK LIST OF EXHIBITS Exhibit Nfmher Page 1. Key Site Features Map .................. 2 2. 15 -Acre Lagoon Study Area ................ 6 3. Bioremediation Treatment Process ............ 23 LIST OF TABLES Table Mrnnhfty Page Number 1. Contamination Types and Levels Found in Lagoon Wastewaters ....................... 8 2. Contamination Types and Levels Found in Lagoon Sludge . . 9 3. Contamination Types and Levels Found in Dregded Materials ................ . . . ...... 11 APPENDICES Responsiveness Summary .............. Appendix A Administrative Record Index ....... ..... Appendix B State Concurrence Letter ............. Appendix C ------- RECORD OF DECISION SUMMARY BOSTON & MAINE WASTEWATER LAGOONS AT IRON HORSE PARK I. SITE NAME, LOCATION AND DESCRIPTION This Record of Decision (ROD) is for the cleanup of the Boston and Maine Wastewater Lagoons (the B&M Lagoons) at the Iron Horse Park Superfund site (the Site) in North Billerica, Massachusetts. The B&M Lagoons are a series of lagoons that receive untreated industrial and sanitary wastewater from the manufacturing and railroad maintenance facilities in the Iron Horse Park industrial complex. They were built and put in use around 1915 and have been in operation since then. The B&M Lagoons are operated by the Boston & Maine (B&M) Corporation, a subsidiary of Guilford Transportation Industries, Inc. The B&M Lagoons and the surrounding area are located within a 150-acre parcel of land that B&M Corporation sold to the Massachusetts Bay Transporta- tion Authority (MBTA) in 1976. The MBTA uses most of this land to operate their passenger rail service. B&M Corporation leases some of the property from MBTA to conduct their present operations. Investigations of the B&M Lagoons have identified contamination in sludge located on the lagoon bottoms, as well as contamination in piles of soil and sludge dredged from the lagoons. The primary contaminants of concern for the B&M Lagoons -are poly- aromatic hydrocarbons, volatile organic compounds, metals, and other chemical compounds. The B&M Lagoons comprise just one part of the Iron Horse Park Superfund site. The entire Site consists of approximately 552 acres of land in North Billerica, near the Tewksbury town line (see Exhibit 1). The Site is an active industrial complex and railyard with a long history of activities that have resulted in contamination of soils, groundwater, and surface water. The Site includes open storage areas, landfills, and lagoons. A more complete description of the Site, including the B&M Lagoons, can be found in the Phase IB Remedial Investigation Report at pages 1-1 to 1-14. II. Site HISTORY AND ENFORCEMENT ACTIVITIES A. Response History The Site was placed on the National Priorities List (NPL) in September 1984 following investigations by the Massachusetts Department of Environmental Quality Engineering (DEQE) in the early 1980s and a Site Investigation Report completed by the NUS Corporation for EPA in August 1984. In August 1984, EPA under its removal authority, covered a portion of the Site known as the Johns-Manville Asbestos ------- ROD DECISION SUMMARY B&M LAGOONS AT IRON HORSE PARK Page 2 Exhibit 1: Key Site Features Map: Iron Horse Park Site, Billerica, MA Landfill, with gravel and topsoil to prevent asbestos in the landfill from becoming airborne. In 1985, EPA began evaluations of the Site to determine the nature and extent of contamination. Under the first phase of the evaluation, EPA conducted a broad study of the Site to define the potential problem areas. This study was entitled the Phase 1A Remedial Investigation (RI), and was conducted from September 1985 to July 1987. As a result of the Phase 1A RI, EPA concluded that the size and complexity of the Iron Horse Park Site necessitated using a phased approach to study it, and to determine what cleanup work may be needed. Under this approach, the Site has been separated into a number of different problem areas. Where it is possible, the areas are studied and decisions on how to clean them up are made as operable units. An operable unit is a discrete portion of an entire response action that, by itself, decreases a release, threat of release, or pathway of exposure. ------- ROD DECISION SUMMARY Page 3 B&M LAGOONS AT IRON HORSE PARK The B&M Lagoons and the surrounding area are the first operable unit for the Site. This operable unit addresses the contaminated soil and sludge in the lagoons and dredged from them. In August 1987, EPA began work on a second remedial investigation that focused on the nature and extent of contamination in and around the B&M Lagoons. EPA completed this study, referred to as the Phase IB Remedial Investigation, in May 1988. In addition to the Phase IB RI, the Feasibility Study (FS) of potential remedial alternatives for the cleanup of the B&M Lagoons was issued in June 1988. In addition to the study of the B&M Lagoons, EPA and DEQE are investigating the Shaffer Landfill as an operable unit. Also, other portions of the Site, including site-wide groundwater remediation, will be addressed as part of future site investigations. A more detailed description of the Site history can be found in Section 1.1 of the Phase 1A RI and also in Section 1.2 of the Phase IB RI. B. Enforcement History In July 1984, EPA notified B&M Corporation, Manville Corporation and the MBTA of their potential liability for response actions taken and to be taken at the Site. These parties were given the opportunity to undertake response actions, including completion of the remedial investigations and feasibility study. They declined to do the work at that time. In December 1984, EPA notified five other parties of their potential liability for response actions taken and to be taken at the Site. These parties also declined to undertake response actions. After completion of the Phase IB RI, on June 22, 1988, EPA notified B&M Corporation, BNZ Materials, Inc., and the MBTA of their potential liability with respect to the B&M Lagoon remediation. On July 14, 1988, Manville Corporation was also noticed for the B&M Lagoons. Negotiations with potentially responsible parties will not commence until after the remedy selection process is complete and special notice letters have been issued pursuant to Section 122(e) of CERCLA. In addition to the federal enforcement efforts, Massachusetts has issued numerous violation notices and administrative orders to ------- ROD DECISION SUMMARY Page B&M LAGOONS AT IRON HORSE PARK several parties within the Iron Horse Park industrial complex for a variety of environmental problems. In May 1985, the Massachusetts Department of Environmental Quality Engineering (DEQE) issued an Administrative Order to the B&M Corporation requiring them to stop discharging vastewater to the B&M Lagoons. Such discharges were found to violate Massachusetts' ground water discharge permit requirements. B&M did not meet the schedule stipulated in the 1985 Order that required cessation of the discharge. As a result, a second Administrative Order was issued in February 1988 with a revised project schedule that requires the BSM Corporation to stop the discharges to the lagoons by the end of 1988. The 1988 Order also added penalty provisions for non-compliance. In July 1988, DEQE's Division of Water Pollution Control reviewed and approved the engineering plans submitted by B&M Corporation for the tie-in of the discharge to the Town of Billerica's sewer system. Given this approval, EPA believes that construction will begin shortly and the 1988 Order's compliance schedule will be met. Should the discharge not cease pursuant to this Administrative Order, EPA has independent authority under CERCLA to require the discharge to the B&M Lagoons be stopped. III. COMMUNITY RELATIONS Through the Site's history, community concern and involvement has been high. A local community group, the Superfund Action Committee (SAC), holds regularly scheduled meetings with EPA, the DEQE and local officials to follow response activities at the Site. Additionally, EPA has kept the community and other interested parties apprised of the Site activities through informational meetings, fact sheets, press releases and public meetings. A community relations plan was developed and implemented in August 1985 to address community concerns and to keep citizens involved in activities during response actions. The Agency published a notice and brief analysis of the Proposed Plan for the remediation of the B&M Lagoons in the Billerica Minute-Man on June 2, 1988, and made the plan available to the public at the Billerica Public Library. On June 8, 1988, EPA held an informational meeting to discuss the results of the Phase IB Remedial Investigation and the cleanup alternatives presented in the Feasibility Study and to present the Agency's Proposed Plan. Also during this meeting, the Agency answered questions from the public. From June 9, 1988, to July 15, 1988, the Agency held a five-week comment period to accept public comment on the alternatives presented in the Feasibility ------- ROD DECISION SUMMARY Page 5 B&M LAGOONS AT IRON HORSE PARK Study and the Proposed Plan and on any other documents previously released to the public. On June 23, 1988, the Agency held a public hearing to accept any oral comments. A summary of the comments received by EPA and EPA's responses to those comments are included in the Responsiveness Summary attached as Appendix A. IV. SCOPE AND ROLE OF OPERABLE UNITS IN THE RESPONSE ACTION The response action for the B&M Lagoons is being conducted as an operable unit for the cleanup of the contaminated soil and sludge. It is a source control remedy that addresses a discrete contaminant source. The active remediation of groundwater is not part of this response action; however, the cleanup of the soil and sludges will be consistent with future groundwater remedies and will ensure that releases of hazardous substances from the soil and sludges into groundwater are mitigated. Because of the complexity of the Site and the discrete nature of the problem with .the B&M Lagoons (contamination is found on the lagoon bottoms or in well defined piles around the lagoons), cleanup as an operable unit is appropriate and consistent with the entire response for the Site. The contaminant levels in the wastes from the lagoons will be reduced and exposure will be eliminated to ensure protection of human health and the environment. Additionally, because the ongoing discharge to the lagoons will be stopped and leaching of contamination from the treated wastes will be minimal, the operable unit for the B&M Lagoons is consistent with any future site-wide groundwater remediation. In addition to the* B&M Lagoons, EPA is investigating the Shaffer Landfill as a second operable unit and will address other portions of the Site, including site-wide groundwater, for subsequent remedial actions. V. B&M LAGOONS CHARACTERISTICS Piles of dredged soil and sludge from the lagoons and groundwater in the vicinity of the lagoons are contaminated with hazardous substances. The significant findings of the investigation of the nature and extent of contamination found are summarized below. B&M WASTEWATER LAGOONS Two lagoons, referred to as the North and South lagoons, continue to receive wastewater from the Iron Horse Park industrial ------- ROD DECISION SUMMARY BtM LAGOONS AT TRQM HORSE PARK Pag* 6 complex. In addition, there arc an overflow lagoon, 'one inactive lagoon, and an empty lagoon that was never used (»•• Exhibit 2). Tha lagoon systea was built in 1915, and has baan in operation •inca that tiM. Watar discharging to the lagoons infiltrates directly into area groundvater. Exhibit 2: 15 Acre Lagoon Study Area, Iron Horse Park Site, Billerica, MA ------- ROD DECISION SUMMARY Page 7 BSM LAGOONS AT IRON HORSE J?ARK The North and South lagoons have a layer of wastewater sludges and soils on their bottoms that is contaminated primarily with low levels of polyaromatic hydrocarbons (PAHs), volatile organic , compounds (VOCs), metals and other types of contaminants. The concentrations of contaminants found in the lagoon wastewater and bottom sludge layer are attached in Tables 1 and 2, respectively. The volume of the contaminated sludge found in the lagoon bottoms is approximately 5,200 cubic yards. In addition to the North and South lagoons, there is an overflow lagoon and an area adjacent to the overflow lagoon that periodically receives wastewater. These areas are usually dry. There is also one inactive lagoon which was used until 1954. Approximately 2,600 cubic yards of material from these locations are contaminated with the same chemical compounds as found in the North and South lagoons. Finally, there is one lagoon that was excavated between 1973 and 1976, but has never been used. There is no contamination in this unused lagoon. ------- TABLE 1 CONTAMINANT TYPES AND LEVELS FOUND IN LAGOON WASTEWATERS Contaminants Contaminant Levels <2 <2 <5 3 19 2 <5 6 <5 1 <5 <4 - 9 - 6 - 8 - 16 - 150 - 14 - 9 - 69 - 21 - 26 - 180 VOCs (ppb) Methylene chloride 1,1-Dichloroethene 1,1-Dichloroethane 1,2-Trans-dichloroethene 1,1,1-Trichloroethane Trichloroethylene Benzene Tetrachloroethylene Toluene Chlorobenzene Ethylbenzene Xylenes EXTRACTABLES (ppb) Napthalene <10 - 38 2-Methylnapthalene <10 - 42 Dibenzofuran <10 - 26 Flourene 5 Phenanthrene <3 - 19 Anthracene 41 Flouranthene 14 Pyrene 10 Bis(2-ethylhexyl)phthalate <7 - 23 Alpha-BHYC 0.19 Gamma-BHC (lindane) 0.28 INORGANICS (ppb) Antimony 52 Arsenic 20 Barium 36 - 51 Chromium <4.5 - 139 Copper 39 - 102 Lead 29 - 54 Mercury 0.3 Nickel <3.8 - 8.3 Selenium 6.6 Vanadium <3.9 - 7.6 Zinc 39 - 197 Cyanide <10 - 41 Detection Frequency 5/10 5/10 4/10 7/10 10/10 10/10 6/10 10/10 6/10 1/10 2/10 6/10 3/10 3/10 3/10 1/10 2/10 1/10 1/10 1/10 4/10 1/10 1/10 1/10 1/10 10/10 7/10 10/10 10/10 2/10 8/10 2/10 5/10 2/10 7/10 ------- TABLE 2 Contaminants CONTAMINANT TYPES AND LEVELS FOUND IN LAGOON SLUDGES Contaminant Levels Detection Frequency VOCs Chloromethane 1,1-Dichloroethane 1,2-Trans-dichloroethene Chloroform 1,1,1-Trichloroethane Bromodichloromethane Trichloroethylene Benzene Tetrachloroethy1ene Toluene Chlorobenzene Ethylbenzene Xylenes EXTRACTABLES 2-Methylnapthalene N-Nitrosodiphenylamine Phenanthrene Flouranthene Pyrene Benzo(b)flouranthene Benzo(k)flouranthene Benzo(a)pyrene Bis(2-ethylhexyl)phthalate INORGANICS Antimony Arsenic Barium Beryllium Cadmium Chromium Copper Lead Mercury Nickel Selenium Silver Vanadium Zinc Cyanide (PPb) 480 400 420 180 270 120 130 <42 - 290 220 1300 270 160 350 (PPb) <940 - 140,000 <2,400 - 81,000 <2.400 - 36.000 <2,4QU - 81, <2,400 - 36,000 <2,000 - 39, <1,000 - 39, <760 - 22,000 ^•7«n - •>•> - 22,000 340 <880 - 61,000 (ppm) <8.2 4.8 20 0.2 0.8 18 30 12 <0.13 13 <1.2 <2.4 7.4 20 <0.6 82 102 2300 58 1790 2570 3390 2.4 485 6.5 30 61 2690 2.2 2/8 1/8 1/8 1/8 1/8 1/8 1/8 3/8 1/8 1/8 1/8 1/8 1/8 7/8 2/8 5/8 5/8 6/8 4/8 4/8 1/8 8/8 5/8 8/8 8/8 7/8 8/8 8/8 8/8 8/8 6/8 8/8 2/8 1/8 8/8 8/8 1/8 ------- ROD DECISION SUMMARY Page 10 B&M LAGOONS AT IRON HORSE PARK : PIV5-? QF "^EDGED SOILS AND SLUDGES The B&M Lagoon area is also characterized by piles of contaminated sludges and soils that were dredged from the lagoon bottoms and disposed of along the lagoon banks. The piles range in height from 6 to 10 feet. Low levels of organic compounds and some metals were found in these piles. A summary of the contaminants in the dredged soil and sludge piles is attached in Table 3. The volume of contaminated soil and sludges in the piles is approximately 20,000 cubic yards. SURROUNDING SOILS Soils in the area surrounding the B&M Lagoons were also investigated to determine if dredged soils and sludges from the lagoons were deposited or spread throughout the 15-acre wooded area that surrounds the lagoons. However, EPA found that the dredged materials had not been spread and that the area is free of contamination. GROUNDWATER Groundwater near the B&M Lagoons has less than 50 ppb of volatile organic compounds (VOCs) and less than 15 ppb of total extractable compounds. No detectable levels of PAHs were found. The ongoing discharge of wastewater to .the lagoons is a source of this contamination. Because contaminants other than those found in the discharge were detected in groundwater, there may be other sources of groundwater contamination from other parts of the Site in addition to the discharge. The piles of dredged materials and the sludge in the lagoons do not contribute significantly to groundwater contamination. This conclusion was based on the results of the toxicity characteristic leaching procedure (TCLP) test that indicated these materials did not leach contaminants in significant concentrations. Also, the contaminants found in these materials are generally not found in groundwater. Section 1.3 of the Feasibility Study contains an overview of the Phase IB RI for the B&M Lagoons. A complete discussion of the characteristics of the B&M Lagoons can be found in the Phase IB RI in Sections 4 through a. ------- TABLE 3 CONTAMINANT TYPES AND LEVELS FOUND IN DREDGED MATERIALS Contaminants Contaminant Levels Detection Frequency VOCs (PPb) methylene chloride <5 - 360 13/52 acetone <5 - 680 9/52 2-butanone 2 1/52 chloroform <4 - 7 2/52 1,1,1-trichloroethane 40 1/52 1,1,2-trichloroethane <5 - 10 6/52 trichloroethylene 10 1/52 tetrachloroethylene 110 1/52 toluene <1 - 6 8/52 ethylbenzene <1 - 33 7/52 xylenes <2 - 390 12/52 EXTRACTABLES (ppb) 1,2-Dichilorobenzene 94 1/52 Methylphenol 110 1/52 Benzoic acid <330 - 1,400 7/52 Pentachlorophenol 190 1/52 N-Nitrosodiphenylamine <73 - 160 5/52 Di-N-butylphthalate <330 - 31,000 7/52 Butylbenzylphthalate 400 1/52 Bis(2-ethylhexyl)phthalate <71 - 1,600 6/52 Napthalene <98 - 170 2/52 2-Methylnapthalene <70-220 8/52 Acenapthalene <47 - 800 5/52 Acenapthene <140 - 370 2/52 Dibenzofuran <91 - 440 2/52 Fluorene <110 - 770 3/52 Phenanthrene <51 - 12,000 22/52 Anthracene <46 - 1,000 15/52 Fluoranthene <52 - 4,200 27/52 Pyrene <45 - 7,100 28/52 Chrysene <65 - 1,900 12/52 Benzo(a)anthracene <75 - 1,600 11/52 Benzo(b)fluoranthene <80'- 1,100 11/52 Benzo(k)fluoranthene <80 - 1,100 9/52 Benzo(a)pyrene <180 - 910 7/52 Indeno(l,2,3-cd)pyrene <62 - 610 5/52 Benzo(g,h,i)perylene <81 - 840 5/52 4,4'-DDT <16 - 74 2/52 ------- TABLE 3 (Cont'd) Contaminants INORGANICS Antimony Arsenic Barium Beryllium Cadmium Chromium Copper Lead Mercury Nickel Selenium Silver Vanadium Zinc Cyanide CONTAMINANT TYPES AND LEVELS FOUND IN DREDGED MATERIALS Contaminant Levels (ppm) <0.7 1.3 <5.4 <0.2 <0.8 4 35 3.0 0.05 6.3 0.8 <0.9 <3.5 4 <0.5 - - - - - - - - - - - - - - - 11 19 270 0.59 9 282 1,240 1,260 0.76 46 7.5 8 35 468 1.3 Detection Frequency 5/52 46/52 50/52 9/52 22/52 50/52 51/52 52/52 18/52 44/52 5/52 26/52 46/52 52/52 11/52 ------- ROD DECISION SUMMARY Page 13 B&M LAGOONS AT IRON HORSE PARK VI. SUMMARY OF SITE RISKS The probability and magnitude of potential adverse human health and environmental effects from exposure to contaminants associated with the B&M Lagoons was estimated and summarized in the Endangerment Assessment (EA). Incremental lifetime cancer risks and a measure of the potential for noncarcinogenic adverse health effects were estimated for two exposure scenarios and a number of potential pathways. The contaminants of concern for cancer risks are PAHs, VOCs and arsenic. For noncarcinogenic adverse health affects, lead and other metals are the contaminants of concern because of their elevated concentrations. The two exposure scenarios evaluated - an average and plausible maximum - reflect the potential for exposure to hazardous substances based on the characteristic uses and location of the lagoons were evaluated. The average case scenario represents the most probable risk and assumes that exposure occurs at the average contaminant concentration found in the wastes. The plausible maximum scenario represents a very conservative, worst- case situation. In evaluating the plausible maximum scenario, the number of times a receptor could be exposed was increased over the average case scenario and it is assumed that all exposure events occur at the maximum contaminant concentration found. The current and future risks that the B&M Lagoons may pose based upon various exposure pathways are summarized below. These results assume that no remediation has occurred. CURRENT USE Excess lifetime cancer risks, from the average to a plausible maximum, and noncarcinogenic hazard risks posed by the lagoon area under the current industrial use of the area are due to direct contact with contaminated sludge and soil dredged from the lagoons. Groundwater ingestion is not an exposure pathway, as currently there is no known use of groundwater for residential or industrial facilities near this portion of the Site. The current risks posed are: Cancer Risks Hazard Risks * Direct Contact: Sludge and Soil Piles 3xlO~8 to 2xlO~6 <1 Direct contact with the wastes may pose excess lifetime cancel- risks greater than 1 x 10~6, but only under the plausible maximum scenario. Potential hazard risks associated with noncarcinogens are less than 0.2 under all exposure scenarios. A hazard risk of ------- BOD DECISION SUMMARY Page 14 B&M LAGOONS AT IRON HORSE PARK 0.2 represents exposure to noncarcinogenic contaminants at • concentrations that are one-fifth of the levels that EPA has set as acceptable intake levels. Because of this, the noncarcinogenic risks are not significant. FUTURE USE The excess lifetime cancer risks and hazard risks under average to plausible maximum scenarios to on-site workers and hypothetical on-site residents were evaluated. In the future use scenario, two additional pathways of exposure were included: direct contact with lagoon-bottom sludges when the discharge has ceased and ingestion of groundwater. Although groundwater remediation is not part of this response action, the groundwater ingestion pathway was considered to ensure that the cleanup of the lagoons as an operable unit minimizes the release of contaminants to groundwater and does not result in further degradation of groundwater quality, and is consistent with future groundwater cleanup actions. Potential exposure pathways considered light industrial and residential development. Although residential housing was considered and evaluated, given the industrial setting of the Site and the close proximity of the B&M Lagoons to the Johns- Manville Asbestos Landfill, the development of housing would be unlikely. In evaluating any future scenarios, it was assumed that all discharges to the lagoon system have ceased. The potential future risks for on-site workers are: Cancer Risks Hazard Risks Direct Contact: Sludge and Soil Piles 7xlO"7 to 2xlO"5 <1 Lagoon Sludge 2xlO'6 to 3xlO"4 <1 Ingestion: Groundwater 7xlO"7 to BxlO"6 <1 • For the hypothetical on-site residents, the risks are: Cancer Risks Hazard Risks Direct Contact: Sludge and Soil Piles 7xlO~6 to IxlO"4 <1 Lagoon Sludge 2xlO~5 to 2xlO"3 <1 ------- ROD DECISION SUMMARY Page 15 B&M LAGOONS AT IRON HORSE PARK _____ Ingestion: Groundwater IxlO"5 to 8xlO~5 1 In the future, the contaminants in the B&M Lagoon area could pose potential health risks to on-site workers and residents from possible direct contact with contaminated soils and sludges. Also, the ingestion of groundwater in the area around the B&M Lagoons could present a potential health threat. Although the risk due to inhaling contaminants was estimated at greater than lxlO~6 in the Endangerment Assessment, information collected by EPA and the State in three separate studies, including actual monitoring by the DEQE in August 1985 at the B&M Lagoons, indicated that this pathway of exposure is not a concern. The potential risks to flora and fauna in the area in and around the B&M Lagoons was also evaluated. Birds and mammals inhabiting the area are probably not at risk due to exposure to contaminants that are present. The risks posed by the B&M Lagoons are summarized in Section 2.3 of the Feasibility Study. The complete Endangerment Assessment is found in Appendix E of the Phase IB Remedial Investigation. VII. NO SIGNIFICANT CHANGES TO SELECTED ALTERNATIVE EPA, under Section 117(b) of CERCLA, is required to publish an explanation if there is a significant change between the preferred alternative presented in the Proposed Plan and the final remedy decision. The remedial alternative selected in this Record of Decision is the same as that presented in the Proposed Plan, therefore, no documentation or explanation of changes is required. VTII. DEVELOPMENT AND SCREENING OF ALTERNATIVES A. Statutory Requirements/Response Objectives Prior to the passage of the Superfund Amendments and Reauthor- ization Act of 1986 (SARA), actions taken in response to releases of hazardous substances were conducted in accordance with CERCLA, as enacted in 1980, and the revised National Oil and Hazardous Substances Pollution Contingency Plan (NCP), 40 CFR Part 300, dated November 20, 1985. Until the NCP is revised to reflect SARA, the procedures and standards for responding to releases of ------- ROD DECISION SUMMARY Page 16 B&M LAGOONS AT IRON HORSE PARK hazardous substances, pollutants and contaminants oust be in accordance with Section 121 of CERCLA and, to the maximum extent practicable, the current NCP. Under its legal authorities, EPA's primary responsibility at Super fund Sites is to undertake remedial actions that are protective of human health and the environment. In addition, Section 121 of CERCLA establishes several other statutory requirements and preferences, including: a requirement that EPA's remedial action, when complete, must comply with applicable or relevant and appropriate environmental standards established under federal and state environmental laws unless a statutory waiver is granted; 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 statutory preference for remedies that utilize treatment to permanently and significantly reduce the volume, toxicity or mobility of hazardous substances. Response alternatives were developed to be consistent with these Congressional mandates. A number of potential exposure pathways were analyzed for risk and threats to public health and the environment in the Endangerment Assessment. Guidelines in the Superfund Public Health Evaluation Manual (EPA, 1986) regarding development of design goals and risk analyses for remedial alternatives were used to assist EPA in the development of response actions. As a result of these assessments and a review of applicable or relevent and appropriate requirements (ARARS) , remedial response objectives were developed to mitigate existing and future threats to human health and the environment. These response objectives are: - To protect human health and the environment by stopping the ongoing discharge to the lagoons. protect human health and the environment by reducing current and future risks due to contaminant levels found in soils and sludges from the B&M Lagoon area. • To protect human health and the environment by reducing current and future risks due to releases of contaminants to groundwater, surface water and air. Meet State and federal applicable or relevant and appropriate environmental requirements (ARARs) . ------- ROD DECISION SUMMARY Page 17 B&N LAGOONS AT IRON HORSE PARK B. Technology and Alternative Development and Screening Remedial alternatives were developed and screened using CERCLA, the NCP, and EPA guidance documents, and the "Interim Guidance on Superfund Selection of Remedy" [EPA Office of Solid Waste and Emergency Response (OSWER)], Directive No. 9355.0-19 (December 24, 1986). Treatment alternatives were developed to provide potential remedies ranging from an alternative that, to the degree possible, would eliminate the need for long-term management (including monitoring) to alternatives involving treatment that would reduce the mobility, toxicity, or volume of the hazardous substances as their principal element. In addition to treatment alternatives, containment options involving little or no treatment and a no-action alternative were developed in accordance with Section 121 of CERCLA. Section 121(b)(1) of CERCLA presents several factors that at a minimum EPA is required to consider in its assessment of alternatives. In addition -to these factors and the other statutory directives of Section 121, the evaluation and selection process for the B&M Lagoons was guided by the EPA document "Additional Interim Guidance for FY '87 Records of Decision" dated July 24, 1987. This document provides direction on the consideration of SARA cleanup standards and sets forth nine factors that EPA should consider in its evaluation and selection of remedial actions. The nine factors are: 1. Compliance with Applicable or Relevant and Appropriate Requirements (ARARs). 2. Long-term Effectiveness and Permanence. 3. Reduction of Toxicity, Mobility or Volume. 4. Short-term Effectiveness. 5. Implementability. 6. Community Acceptance. 7. State Acceptance. 8. Cost. 9. Overall Protection of Human Health and the Environment. In the Feasibility Study, a three-part technology and alternative development and screening process was followed. First, technolo- gies were identified, assessed and screened to determine accept- able engineering practices that could provide implementable, feasible and realistic remedies. Second, the technologies were combined into nine remedial alternatives and screened to narrow the number of potential remedial actions for further detailed analysis while preserving a range of options. Seven of the nine alternatives were retained. Finally, following the initial screening, a detailed analysis of the remaining seven alterna- ------- ROD DECISION SUMMARY Page 18 B&M LAGOONS AT IRON HORSE PARK ' tives was conducted utilizing the nine factors discussed above. IX. DESCRIPTION AND EVALUATION OP THE REMEDIAL ALTERNATIVES This section presents a narrative summary and brief evaluation of each alternative retained for the detailed analysis according to the evaluation criteria described above. Alternative fl: No-Action. The no-action alternative would involve leaving the B&M lagoon area just as it is; that is, once the wastewater discharge to the lagoons has ceased, no-action would be taken. The piles of dredged sludges and soils would remain unaltered. The sludges and soils in the North and South lagoons would also remain unaltered, with the exception of eventually becoming dried out, once the lagoons drain. This alternative would not be protective because it does not result in a reduction to the risks posed by the B&M Lagoons and would not meet ARARs. Additionally, this alternative does not utilize treatment as a principle element and, consequentlyt theraf would be no reduction in the mobility, toxicity or volume of the wastes. Estimated Time for Construction: None Estimated Total Cost: None Alternative 12: Closure of Lagoons with a Permeable Cap. This alternative would involve moving the 23,000 cubic yards of contaminated soils and sludges from the piles, the overflow lagoon area and the abandoned lagoon, and placing them on top of the sludges in the North and South lagoons. Then, a cover, referred to as a cap, would be constructed over the sludge deposits. This cap would be permeable (i.e., water would be able to pass through it). The cap would consist of 6 inches of clean sandy soil and 6 inches of topsoil. In addition, the cap would be seeded and fertilized to establish vegetation, which would hinder erosion. The cap would prevent direct human contact with the sludge material underneath, and would prevent evaporation of contaminants in the sludge. A fence would be constructed around the lagoon area to prevent access and possible disturbance to the cap. A restriction in the deed to the property would be required so that the area would never be excavated. Although this alternative would reduce the risks posed by direct contact to the contaminated soil and sludges, it would not attai| ARARs. Specifically, the permeable cap would not meet the ------- ROD DECISION SUMMARY Page 19 B&M LAGOONS AT IRON HORSEPARK relevant and appropriate closure regulations for landfill or surface impoundment covers that require that the cover provide long-term minimization of migration of liquids through the cover. Additionally, this alternative does not utilize treatment as a principal element to reduce the mobility, toxicity or volume of the wastes. Estimated Time for Construction: 9 months Estimated Period of Operation: 30-Year Lifetime of Cover Estimated Total Cost: $546,000 Alternative |3: Closure of Lagoons with an Impermeable Cap. This alternative is similar to alternative #2, in that contaminated materials would be excavated and placed in the North and South lagoons. However, under alternative #3, an impermeable cover that- met closure requirements would be placed directly over the contaminated soil and sludge to prevent precipitation from contacting the waste. An 18-inch layer of sand would be placed above the impermeable cover, with a drainage and filter layer in between, to allow precipitation to drain out of the cap. The cap would be topped with 6 inches of topsoil. This impermeable cap would reduce the amount of precipitation that could filter through the waste and carry contaminants into the groundwater and away from the capped area. Long-term monitoring of the groundwater would be conducted, and a fence would be installed around the capped area. This alternative would be protective of human health and the environment and would attain ARARs. However, this alternative does not utilize treatment as a principle element to reduce the mobility, toxicity or volume of the wastes. Estimated Time for Construction: 9 months Estimated Period of Operation: 30 Years Estimated Total Cost: $1,062,000 Alternative |4: Stabilization and Closure. Under this alternative, contaminated soils and sludges would be excavated and treated on-site by stabilization. A stabilization process involves mixing a hardening agent, called a fixative, with the waste. Cement is an example of a type of fixative that could be used. To implement this alternative, a processing area would be set up near the lagoons and the contaminated soils and sludges would be placed, along with a fixative, in a mixing unit. After stabilization, the treated material would be placed back in the North and South lagoons and covered by a permeable cap. About a fifty percent increase in the volume of the waste would result. ------- ROD DECISION SUMMARY Page 20 RAM TAGOONS AT TROM HORSE PARK This stabilization process would reduce the mobility of hazardous components in the sludge. If, following stabilization, the wastes are still considered hazardous, then the permeable cap would be upgraded to an impermeable cap design to meet the hazardous waste closure requirements, and a groundwater monitoring program would also be implemented to meet post-closure requirements for hazardous waste facilities. This alternative would be protective of human health and the environment and would attain ARARs as the closure would be conducted to meet federal and Massachusetts' requirements. Additionally, this alternative, because it utilizes stabilization, meets CERCLA's preference for remedies that use treatment as a principle element to reduce the mobility of the wastes. Estimated Time For Construction and Operation: 11/2 years Estimated Period of Operation: 30 Years Estimated Total Cost: $5,201,700 Alternative 15: Bioremediation. This alternative is the selected remedy and is discussed in the following section of this decision document. Alternative |6: On-Site Incineration. Under this alternative, excavated sludges and soils would be burned in a mobile thermal destruction facility that would be set up on the Site. The extremely high temperatures in the thermal destruction facility would destroy at least 99.99% of the PAHs, VOCs and all other hydrocarbons in the excavated sludges and soils. The exhaust gases from the facility's combustion chambers would be passed through air pollution control devices before being released to the atmosphere to attain all applicable or relevant and appropriate emission standards. After the incineration process, the treated sludges and soils would be tested to ensure that the residual material is not hazardous. If the treated sludges and soils are not hazardous, they would be used to fill in excavated areas and the North and South lagoons. In the event that these materials are considered hazardous, they would be managed in conformance with applicable or relevant and appropriate requirements. This alternative would be protective and all ARARs would be attained. Incineration would reduce the mobility, toxicity and volume of contaminants and would achieve a permanent remedy. ------- ROD DECISION SUMMARY Page 21 B&M LAGOONS AT IRON HORSE PARK Estimated Time for Construction and Operation: 2 Years Estimated Total Cost: $15,694,500 Alternative |7: Off-Site Disposal in an Approved Hazardous Waste Landfill. This alternative would involve excavating and transporting all sludges and soils from the B&M Lagoon area to an approved off-site hazardous waste landfill. After the contaminated materials are removed, clean soils would be used to fill in the excavated areas. There are currently four approved facilities in the eastern United States to which the wastes could be shipped. These facilities are located in Emelle, Alabama; Model City, New York; Williamsburg, Ohio; and Niagara Falls, New York. Although this alternative would be protective and could attain ARARs, under CERCLA the off-site disposal of contaminated materials without treatment is the least favored remedial action where practicable technologies are available. Additionally, off- site landfilling does not utilize treatment to reduce the mobility, toxicity or volume of the hazardous constituents. Estimated Time for Construction and Operation: 1 Year Estimated Total Cost: $16,900,000 X. THE SELECTED REMEDY The selected remedy for the B&M Lagoons is a source control remedial action for the contaminated soil and sludges from the lagoons. The remedy will protect human health and the environment by reducing the organic contaminant levels found in the soil and sludges and by eliminating potential exposure routes. Additionally, because the ongoing discharge to the lagoons will be stopped and leaching of contamination from the treated wastes will be minimal, the remedy is consistent with any future site-wide groundwater remediation. Also, to ensure that the remedy continues to be protective, it will be reviewed every five years after initiation of the bioremediation in accordance with Section 121(c) of CERCLA. A. Description of the Selected Remedy The selected remedy includes: treating the contaminated soil and sludge from the lagoons by bioremediation; returning the treated material to the lagoon area, covering it with clean soil and establishing a vegetative cover; and decontaminating the lagoon system's piping and pumps. The remedy assumes that the discharge to the lagoons will cease pursuant to State authority. ------- ROD DECISION SUMMARY Page 22 LAGOONS AT TRON HORSE PARK Groundwater remediation is not part of this remedy because there •ay be other sources that have not been addressed that may contribute to contamination of groundvater. Site-vide groundvater remediation will be considered in the future. The bioremediation treatment process is outlined below. The particular bioremediation technology presented serves as the basis for remedial design and subsequent remedial action. The goal of the technology is to achieve the maximum practicable reduction in contaminant concentration. However, another bioremediation technology process can be implemented if approved by EPA and if it is demonstrated to the satisfaction of EPA, through appropriate engineering evaluations, and any necessary lab, bench or pilot-scale testing, that it can achieve at least the same reduction in organic contamination within the five-year time frame as outlined in the process discussed below. Bioremediation The bioremediation treatment process uses naturally occurring microorganisms that exist in soil to degrade, or break down .organic contaminants, such as PAHs and hydrocarbons, into non- toxic, harmless materials such as carbon dioxide, water, biomass,1 and humus. The natural action of the microorganisms is enhanced by adding water, essential nutrients and oxygen to the waste materials. This type of treatment is commonly used to manage contaminated wastes similar to those found at the B6M Lagoons. Prior to start-up of the treatment process, appropriate lab, bench or pilot-scale testing will be done to optimize the bioremediation process. Additionally, within the five-year operating period specified, monitoring of the process and further modifications will be implemented to ensure the maximum practicable reduction in hazardous organic constituents. The 28,000 cubic yards of soil and sludge contaminated by releases of hazardous substances from the B&M Lagoons will be treated by the bioremediation process. A 5-acre area located near the lagoons will be cleared of trees and a fence will be installed. The area will be excavated to a depth of three feet, and an impermeable (i.e., water would not pass through it) liner will be placed over the area. Once the liner is in place, the contaminated soils and sludges will be placed into the lined area. The top layer of waste will then be tilled to introduce oxygen for the microorganisms to grow, and to degrade the contaminants. Water and fertilizers containing essential nutrients, such as nitrogen and phosphorus, will also be added to the contaminated materials. Limestone may be added ------- ROD DECISION SUMMARY B&M LAGOONS AT IRON HORSE PARK Page 23 to adjust the acidity and alkalinity of the wastes. The specific water content, nutrient levels and limestone addition will be determined prior to implementing the remedy through appropriate lab, bench or pilot-scale testing. (Refer to Exhibit 3 for a. schematic representation of the bioremedition process). Exhibit 3: Bioreinediation Treatment Process Tilling to «oa I SOIL BACTERIA * ORGANIC CARBON (WASTES) — ^-u^-1 ^r Biafltgraaation lAeaNumjmsl Dttlil BIOLOGICAL REACTION ZONE 9 INCHES WASTE MATERIALS (SOILS/SLUDGES) 36 INCHES DRAINAGE SYSTEM IMPERMEABLE UNER SOIL AND ROCK BENEATH EARTH'S SURFACE ------- ROD DECISION SUMMARY Page The bioremediation process is effective in breaking down contaminants in the top 6 to 9 inches of soil. Below the level of 9 inches, there is not an adequate supply of oxygen for bioremediation to be effective. Therefore, treatment of the contaminated soil and sludges will be done in layers. Each spring, the upper 6 to 9 inches of waste material, or approximately 6,000 cubic yards, will be bioremediated until the fall, and then returned to the North and South lagoons. The treatment process will be conducted from the spring through the fall, because the bioremediation process is more effective in warmer temperatures. The entire treatment process should take approximately five years to complete. Based on studies of bioremediation (Bossert and Bartha, 1984), it is expected that up to a 70 to 80% reduction can be realized. With this reduction in contaminant concentration in the wastes, the total excess cancer risks posed by direct contact with the residual materials will be less than IxlO'6 for the most probable future receptors - i.e., on-site workers and off-site residents. Although residential development of the B&M Lagoon area is not expected, the risks to hypothetical on-site residents were evaluated. This evaluation showed exposure to the treated materials would pose a risk from carcinogens of less than IxlO'5. In addition to the significant risk reduction achieved by bioremediation, returning the treated material to the lagoon area and covering it with clean soil will eliminate potential exposure routes making both cancer and non-carcinogenic hazard risks essentially zero. Additionally, because bioremediation will reduce contaminant levels in the waste, the potential for contaminants to leach from the treated wastes and migrate into the groundwater will be minimal. Bioremediation is, therefore, consistent with any future site-wide groundwater remediation-. A detailed breakdown of the selected remedy's cost is summarized in Table 4. The cleanup protects human health and the environment by permanently treating the contaminated soils and sludges to the maximum extent practicable. Bioremediation reduces the mobility, toxicity and volume of the hazardous organic constituents in the wastes. The remedy also complies with all applicable or relevant and appropriate requirements (ARARs) set by the Commonwealth of Massachusetts and the federal government, and is cost-effective. Estimated Time for Construction and Operation: 5 years Estimated Total Cost: $2,320,000 ------- TABLE 4 BIOREMEDIATION REMEDY COSTS DIRECT CAPITAL COSTS Amount 1. Site Preparation $762,500 2. Placement of Waste in Treatment Area 210,000 3. Final Cover 23,000 4. Restoration of Treatment Area 12,500 $1,008,000 INDIRECT CAPITAL COSTS 5. Construction Contractor 150,000 6. Design Development 100,000 7. superfund Allowance 200,000 $450,000 ENGINEERING AND CONTINGENCIES 8. Engineering (315%) 217,500 9. Contingency (315%) 217,500 10. Administration (35%) 72,500 $507,500 TREATMENT COSTS (Present Worth - 5 Years) 11. Treatment Process ' 64,400 12. Returning Treated Waste to Lagoon Area 91,700 13. Process Monitoring 151,600 $307,700 Total Capital Costs $2,273,000 LONG-TERM COVER MAINTENANCE (Present Worth - 30 Years) 14. Cover Maintenance $47,000 TOTAL REMEDY COSTS $2,320,000 ------- ROD DECISION SUMMARY Page 26 B&M LAGOONS AT IRON HORSE PARK^ ____^__ B. Rationale for Remedy Selection The remedy was selected based on the assessment of each criterion listed in the evaluation of alternatives section of this document. In accordance with Section 121 of CERCLA, to be considered as a candidate for selection in the ROD, the alternative must be protective of human health and the environment and able to attain ARARs unless a waiver is granted. In assessing the alternatives that met these statutory requirements, EPA focused on the other evaluation criteria, including: short-term effectiveness, long-term effectiveness, implementability, use of treatment to permanently reduce the mobility, toxicity and volume, and cost. EPA also considered the implementability of a remedy and the Commonwealth's and community's acceptance of it. The assessment is summarized in Section 4.0 of the Feasibility Study and discussed below. The selected remedy provides long-term effectiveness, protective- ness and reduces the mobility, toxicity and volume of the waste sludges and soil by permanently degrading the PAHs and other types of hydrocarbons present through the action of micro- organisms. Because there will be no discharges of water from.the bioremediation process and necessary measures will be taken to ensure air quality is not impacted and that safety requirements are met, no adverse short-term impacts will occur during implementation of the remedy. Bioremediation is an easily implemented remedy: materials and equipment are readily available and the process has been demonstrated in other similar situations. The remedy will meet federal and State ARARs and is cost-effective in comparison to the other remedial alternatives. The Commonwealth of Massachusetts was consulted during the development of the Remedial Investigation and Feasibility Study, Proposed Plan and this decision document and has provided their concurrence for the selected remedy. Also, as documented in the Responsiveness summary, attached as Appendix A, the community supports the selected remedy. Based upon this assessment, taking into account the statutory preferences of CERCLA, EPA selected the remedial approach that utilizes bioremediation for the Site. In all alternatives considered, the ongoing discharge to the lagoons is assumed to have stopped. The present discharge of untreated wastewater to the B&M Lagoons is illegal. The discharge is not permitted as required by the Massachusetts Groundwater Discharge Permit Program (310 CMR 5.00). Moreover, the discharge to the lagoons contains chemical compounds at ------- ROD DECISION SUMMARY Page 27 B&M LAGOONS AT JCRON HORSE PARK concentrations that exceed applicable effluent limitations .set by Massachusetts regulations to ensure that groundwater quality is maintained. Alternatives 1 and 2, No Action and closure of the Site with a permeable cover, would not meet ARARs or provide a protective remedy. Because of this, they were eliminated from further consideration. The other remedial alternatives that are both protective and attain ARARs were not selected for the reasons noted below. Alternative # 3, closure of lagoons with impermeable cap, would be protective of human health and the environment and would be constructed to attain ARARs. However, this alternative was not selected because it does not utilize a permanent solution and an alternative treatment technology to the maximum extent practicable to reduce the mobility, toxicity, and volume of the waste material. Alternative # 4, stabilization and closure, would be protective of human health and the environment and attains ARARs. Although this alternative uses treatment to reduce the mobility of contaminants, it was not chosen because stabilization would result in a substantial increase in the volume of waste material. This would make implementation difficult and, unlike the selected remedy, it would not reduce the concentration of the organic contaminants in the waste or their toxicity. In addition, the cost of this remedy is greater than the selected remedy. Alternative # 6, on-site incineration, would be protective of human health and the environment. In addition,, this alternative utilizes a permanent solution and an alternative treatment technology to the maximum extent practicable and would attain ARARs. Moreover, almost a 100% reduction in the hazardous organic constituents would be achieved by incineration. Incineration was not selected because it is significantly more expensive than the selected remedy yet the degree of additional protection afforded by the complete destruction of the organic constituents in the waste, as opposed to the selected remedy, is minimal in terms of risk to human health and the environment. Also, incineration is a relatively complex technology that would be more difficult to implement than the bioremediation process. Alternative # 7, off-site disposal, would be protective of human health and the environment and attain ARARs. This alternative was not selected because the off-site disposal of contaminated materials without treatment is the least favored alternative ------- ROD DECISION SUMMARY Pag* 28 B&M IAQOQNS AT IRON HORSE PARK under CERCLA where practicable technologies are available. In addition, this alternative does not utilize a permanent solution and alternative treatment technologies to the maximum extent practicable. Finally, this alternative is significantly more expensive than the selected remedy. XI. STATUTORY DETERMINATIONS The remedial action selected for at the B&M Lagoons at the Iron Horse Park Site is consistent with CERCLA and, to the extent practicable, the NCP. The selected remedy is protective of human health and the environment, attains ARARs and is cost-effective. The selected remedy also satisfies the statutory preference for treatment which reduces the mobility, toxicity or volume as a principal element. Additionally, the selected remedy utilizes a permanent solution and alternate treatment technologies to the maximum extent practicable. A. The Selected Remedy is Protective of Human Health and the Environment The remedy for the B&M Lagoons will reduce the risks posed to M human health and the environment. Stopping the ongoing discharge^ to the lagoons will mitigate contaminant release to groundwater. Bioremediation will reduce the organic contamination in the soil and sludges to levels that ensure protectiveness: the treated material will pose less than a lxlO~6 excess cancer risk under the present and future industrial use of the area. Clean soil will cover the treated wastes to eliminate future exposure and risks associated with non-carcinogens. During the design of the remedy, measures to ensure that air emissions and odors are controlled will be identified and implemented during the remedial action phase of the cleanup. Any short-term risks associated with the remedial action are minimal and are greatly outweighed by the long-term effectiveness and permanence the remedy will provide. B. The Selected Remedy Attain ARARs • This remedy will meet or attain all applicable or relevant and appropriate federal and State environmental laws and regulations. Environmental laws and regulations which are applicable or relevant and appropriate to the selected remedial action for the B&M Lagoons at Iron Horse Park are: Massachusetts Regulations for the Land Application of Sludge and Septage (310 CMR 32) ------- ROD DECISION SUMMARY Page 29 B&M LAGOONS AT IRON HORSE PARK Massachusetts Groundwater Discharge Permit Program (314 CMR 5.00) Clean Water Act (CWA) Clean Air Act (CAA) Massachusetts Air Quality Regulations (310 CMR 6.00-8.00) Executive Order 11990 (Protection of Wetlands) Massachusetts Wetlands Protection Regulations (310 CMR 10.00) Occupational Safety and Health Administration (OSHA) These ARARs are discussed below. Bioremediation of the Contaminated Soil and Sludges With the exception of a Massachusetts requirement for pathogen reduction in sludge that is relevant and appropriate (310 CMR 32) , there are no State or federal requirements that specify how the bioremediation process should be operated or what cleanup levels should be achieved. The pathogen reduction requirement will be met by the bioremediation process. Groundwater Stopping the discharge to the lagoons will meet applicable Massachusetts Groundwater Discharge Permit requirements. There are no federal primary or secondary air quality standards for chemical contaminants that may be released from the lagoons during the bioremediation process or after it is completed. However, federal National Ambient Air Quality Standards have been established for particulates that could be emitted during imple- mentation of the remedy will be met (40 CFR 50.6 and 50.7). These requirements will be met during implementation of the remedy. In addition, Massachusetts air quality regulations establish allowable ambient levels (AALs) for many of the chemi- cal contaminants found in the lagoon area (310 CMR 6.00-8.00) . The air monitoring conducted by the DEQE on two separate occasions in 1986 indicated that the Massachusetts AALs are not presently being exceeded. Because the level of volatile organic compounds is very low in the contaminated soil and sludges, it is expected that these AALs will not be exceeded during the bioremediation process. During the design of the remedy, a more complete assessment of potential air emissions and odors will be conducted. Any necessary measures needed to ensure that the AALs are met and odors are controlled will be implemented. ------- ROD DECISION SUMMARY Page 30 R£M LAGOONS AT TRON HORSE PARK Surface Water Since the bioremediation process includes no discharges to surface waters, there are no federal or State requirements that have to be net. Wetlands and Floodplains Although no construction will be conducted in a wetland or floodplain, Section 404 of the CWA, Executive Order 11990 (Protection of Wetlands) and the Massachusetts wetlands protection requirements (310 CMR 10.00) will be met by assessing any impacts to wetlands and minimizing these impacts. Land Use Restrictions In order for the selected remedy to adequately protect public health, safety and welfare and the environment, a land use restriction will be recorded with the Middlesex County Registry of Deeds that indicates that the bioremediation process has been conducted and that the treated waste was placed into the lagoon area and covered. The restriction will further state that the lagoon area shall not be disturbed, in any manner, until and unless the State and federal authorities review plans for work in the lagoon area and determine whether or not the cover over the treated waste can be disturbed without creating an unacceptable risk. QSHA All applicable safety and health requirements established under the Occupational Safety and Health Act will be met for the on- site workers during the bioremediation process. C. The Selected Remedial Action is Cost-Effective The selected remedial action, which utilizes bioremediation, is cost-effective. It provides the best remedy in consideration, of attainment of ARARs, short-term, long-term and overall protectiveness, implementability> reduction in toxicity, mobility and volume of the wastes, acceptance by the community and State and cost. Specifically, bioremediation would be more effective than all of the containment options considered and would result in the permanent reduction of organic contaminant levels. In addition, bioremediation would be easier to implement and less costly than the other treatment-based remedies that attained applicable or relevant and appropriate requirements. Although incineration would destroy all of the organic components in the ------- ROD DECISION SUMMARY Page 31 B&M LAGOONS AT IRON HORSE PARK waste, it would be more difficult to implement and would cost more than five times as much as bioremediation yet not provide a significant increase in protectiveness. D. The Selected Remedy Utilizes Permanent Solutions and Alternative Treatment Technologies or Resource Recovery Technologies to the Maximum Extent Practicable Stopping the ongoing discharge to the lagoons, reducing the levels of contaminants in the soil and sludges by bioremediation and decontaminating the lagoon system's pipes and pumps utilizes a permanent solution for the lagoon remediation. Additionally, bioremediation is an alternative treatment technology that is used to the maximum extent practicable. E. The Selected Remedy Satisfies the Preference for Treatment as a Principal Element The principal element of the selected remedy is the bioremediation of the contaminated soil and sludges. This element addresses the primary threat posed by organic contaminants at the B&M Lagoons and satisfies the statutory preference for treatment as a principal element. XII. STATE ROLE The Massachusetts Department of Environmental Quality Engineering (DEQE) has reviewed the various alternatives and has indicated its support, for the selected remedy. The State has also reviewed the Remedial Investigation, Endangerment Assessment and Feasibility Study to determine if the selected remedy is in compliance with applicable or relevant and appropriate State environmental laws and regulations. The Massachusetts DEQE concurs with the selected remedy for the B&M Lagoons at the Iron Horse Park Site. A copy of the declaration of concurrence is attached as Appendix C. ------- RECORD OF DECISION BOSTON & MAINE WASTEWATER LAGOONS AT IRON HORSE PARK APPENDIX A RESPONSIVENESS SUMMARY ------- FINAL EE5PCN5XVH1ESS SDMARY Boston & Maine Wasteuater lagocn Area Iron Horse Bark S^jerlliiil Site EPA Walk Assigraent No.: 33-1157 BBC U Docunent Qantrol No.: 132-OO-GP-G3IJ-1 FOR TBDE U.S. ENVHOMENIAL FR7EBCTKN AGENOf RBGXCN I BOSICN, MASSAOCSETES 1988 Prepared by the HEM U Project Team under EPA Contract No. 68-01-6939 ------- TABLE OF CONTENTS Page PREFACE 1 I. OVERVIEW OF REMEDIAL ALTERNATIVES CONSIDERED IN THE FEASIBILITY STUDY INCLUDING THE PREFERRED ALTERNATIVE 3 H. BACKGROUND ON COMMUNITY INVOLVEMENT AND CONCERNS 5 HI. SUMMARY OF COMMENTS RECEIVED DURING THE PUBLIC COMMENT PERIOD AND EPA RESPONSES TO THESE COMMENTS .7 A. Questions Regarding the Remedial Alternatives 7 B. Questions Regarding Enforcement Issues 11 IV. REMAINING CONCERNS 13 ATTACHMENT A - COMMUNITY RELATIONS ACTIVITIES CONDUCTED AT THE IRON HORSE PARK SITE 15 ------- Preface Hie U.S. Environmental Protection Agency (EPA) held a public comment period from June 9, 1988 to July 15, 1988 to provide an opportunity for interested parties to cement on the Kay 1988 Feasibility Study (FS) and Proposed Plan for the Boston & Maine (B & M) wastewater lagoon area at the Iron Horse Park Super fund site in Billerica, Massachusetts. The FS examines and evaluates various options, called remedial alternatives, for addressing contamination in the lagoon area. EPA identified its preferred alternative for the cleanup in the Proposed Plan issued before the start of the public comment period. This Responsiveness Summary documents EPA responses to the comments and questions raised during the public comment period. EPA will consider all of the ocranents summarized in this document -before selecting a final remedial alternative for the lagoon area at the Iron Horse Park Superfund site. This responsiveness summary is divided into the following sections: I. Overview of Reny^jai Alternative!? Considered in the Study and Proposed Plan - This section briefly outlines the remedial alternatives evaluated in the Feasibility Study and Proposed Plan, including the preferred alternative, bioremediation. n. Background on Community Involvement and Concerns — This section provides a brief history of community interests and con regarding the Iron Horse Park site, focusing on the lagoon area at the site. ------- 2 XXX • SUHJMIV pf O iiii|flTTts pjpnfti.v**3 Burincr thff Public - This section sunnarizes and. EPA responses to the written and oral ccnmants received from the public during the public oonuent period. These ccranants are organized by subject area. XV. Remaining Qonoerns - This section i:1escri]:ies issues that nay continue to be of concern to the cconunity during the design and implementation of EPA's selected remedy for the lagoon area. EPA will continue to address these concerns during the Rsmertial Design and Remedial Action (KD/RA) phase of the cleanup process. A • This attachment is a list of the coranunity relations activities that EPA has conducted to date at the Iron Horse Park site. ------- I. GVUfl/lfcH OF REMEDIAL AUTERNATTVES CONSIDERED IN THE FEASXHILnY STUDY AND PROPOSED FUN Using the information gathered during the Remedial Investigation and the results of the Endangerment Assessment for the lagoon area at the Iron Horse Park site, EPA identified several cleanup objectives for the lagoon area. (See Exhibit l for a nap of the lagoon area.) The objectives are: (l) to protect human health and the environment by stopping the ongoing wastewater discharge to the lagoons; (2) to protect human health and the environment by reducing the risks associated with potential exposure to contamination in lagoon area sludges and soils; and (3) to reduce risks due to releases of contaminants into the groundwater, surface water, and the air. After identifying the cleanup objectives, EPA developed and evaluated potential cleanup alternatives. The Feasibility Study report describes the alternatives considered for addressing contamination in the lagoon area, as well as the criteria EPA used to narrow the list to seven potential remedial alternatives. Each of these alternatives is described briefly below: Alternative # 1; No Action: The no-action alternative would involve leaving the B & M lagoon area just as it is; that is, once the wastewater discharge to the lagoons has opnsprl, no action would be taken. #2: Closure of Taefnp|ng with a Prf'^hle cap: This alternative would involve excavating 23,000 cubic yards of contaminated materials, including all of the piles of dredged materials and contaminated soils from the overflow lagoon and the abandoned lagoon, and placing them on top of the existing sludges in the North and South lagoons. Then, a cover, referred to as a cap, would be constructed over the sludge deposits. This cap would be permeable (i.e. , water would be able to pass through it) . ------- Exhibit 1 15-ACRE LAGOON STUDY AREA IRON HORSE PARK SITE, BILLERICA, MASSACHUSETTS UNUSED LAGOON '///A PRIMARY OVERFLOW LAGOON INACTIVE X LAGOON PIEOFDREDGED SON. AND SLUOQE ------- with am ImpeniE^tile Cap. This alternative is similar to alternative #2, in that contaminated matwj^ig would be excavated and placed in the North and South lagoons. However, under alternative #3, an impermeable rather than a permeable cap would be used. Hie bottom layer of the cap would be constructed of an impermeable synthetic liner that would be placed directly over the sludge to prevent precipitation (i.e., rain and snow melt) from contacting the waste. Alternative # 4; Stabilization and Closure. Under this alternative, contaminated soils and sludges would be excavated and treated on-site by stabilization. A stabilization process generally involves mixing a hardening agent, such as cement, with the waste. To implement this alternative, contaminated soils and sludges would be mixed with a hardening agent in a mixing unit that would be set up at the site. After stabilization, the treated material would be placed back in the North and South lagoons and covered by a permeable cap. Alternative #5: Bioremediation and Closure. EPA chose this alternative as its preferred alternative when it released its Proposed Plan. After considering public comments on the preferred alternative, EPA officially chooses this alternative as the cleanup remedy for the lagoon area. A bioremediation treatment process uses naturally occuring microorganisms that exist in soil to degrade, or break down, organic contaminants such as polyaromatic hydrocarbons (PAHs) and other hydrocarbons., into non-toxic, harmless materials such as carbon dioxide, water, biomass, and humus. At the Iron Horse Park site, a five-acre area located near the lagoons will be cleared of trees and excavated to a depth of three feet, and an impermeable synthetic liner will be placed over the area. Once the liner is in place, the contaminated soils and sludges from the lagoon area will be placed into the lined area. The top layer of contaminated soils and sludges will then be tilled to introduce oxygen necessary for the microorganisms to grow, and to degrade the contaminants. (Refer to Exhibit 2 for a schematic representation of the bioremediation process). Alternative #6t On-site Incineration. Under this alternative, excavated sludges and soils would be burned in a mobile incinerator that would be set up on the site. The extremely high temperatures in the thermal destruction facility would destroy an estimated 99.99% of the PAHS and volatile organic compounds (VDCs) in the excavated sludges and soils. The exhaust gases from the facility's combustion chambers would be passed through air pollution itrol devices before being released to the atmosphere. Alternative f 7: Off-site Disposal in an Approved Hazardoyg w*gte landfill. This alternative would involve excavating and transporting all sludges and soils from the site to an approved off-site hazardous waste landfill. After the contaminated materials are removed, clean soils would be used to fill in the excavated areas. ------- Exhibit 2 BloremedJatlon Treatment Process SOIL BACTERIA ORGANIC CARBON (WASTES) C*6onOlo»dt Wattr Below Dotail BIOLOGICAL REACTION ZONE 9 INCHES WASTE MATERIALS (SOILS/SLUOGES} 36 INCHES DRAINAGE SYSTEM IMPERMEABLE LINER SOIL AND ROCK BENEATH EARTH'S SURFACE ------- H. BACH3DDND CN COMMITY INvCUJEMEtfr AND OCNCEFN5 Hie Iron Horse Park site, which consists of approximately 552 acres of land, is located in Billerica, Massachusetts, near the Tewksbury town line. The site is an active industrial complex with a long history of waste management activities that have resulted in open storage areas, landfills, and lagoons. (See Exhibit 3 for a key site features nap.) The site is surrounded by a densely populated residential area. There is an estimated population of 8,300 residents within a one-mile radius of the site boundary. When the site was added to the National Priorities List (NFL) in September of 1984, several citizen's groups that had originally been organized to address separate Issue^ «t •the site, merged into the Superfund Action Committee Coalition (now called the Superfund Action Committee, or SAC). Members of the SAC are generally supportive of EPA's Proposed Plan for the lagoon area at the Iron Horse Park Site. At the public meeting held on June 8, 1988 to present the Proposed Plan, citizens questioned why EPA did not choose the incineration option presented in the Feasibility Study, but appeared to be satisfied with EPA's response that bioremediation represents the best balance among the criteria that were used to analyze the alternatives. Citizens were interested to know to what extent the lagoons are contributing to groundwater contamination at the rest of the site. Citizens remain very interested in the extent and nature of groundwater contamination ------- Exhibit 3 KEY SITE MATURES MAP IRON HORSE PARK SITE, BILLERICA. MASSACHUSETTS JOHNS-MANVN.LE GeOWGe MCOUESTEN ^ ^ ASBESTOS LANDFILL WOOOFABmCATORS BAM ^SEWAGE LAGOONS ------- 6 at the entire site, including the direction of groundwater flow. Oversight Citizens have expressed their concern that EPA should strictly oversee all aspects of the cleanup of the lagoon area, especially if the Boston & Maine Corporation conducts the cleanup. One citizen expressed concern that, because the bioremediation process will take many years, it is especially important that effective oversight be conducted. Site Security In addition, citizens are very concerned about site security. They indicated that there is easy access to the site, and that a fence should be constructed around the lagoon area, as well as around the entire site. Citizens stated that local residents continue to enter the site and ride vehicles on top of the former asbestos landfill, and are worried that people would drive around in the lagoon area. For this reason, citizens stated that security personnel should be posted at the site. Future-Use Citizens also expressed concern that once remediation is complete, and the lagoons are backfilled, EPA needs to ensure the lagoon area will never be used for development. At the public informational meeting, EPA explained that the goal of bioremediation is to clean up the lagoon area to a level that would ensure that if the land were to be developed, the risks to human health and the environment would be ------- 7 HI. SUMMARY OF CCMMEffES RECEIVED DURING THE HJHLIC CCMMENT PERIOD AND EPA QCMMEOTS This responsiveness sunnazy addresses the ocmnents received by EPA concerning the Feasibility Study and Proposed Plan for the lagoon area at the Iron Horse Park Superfund site in Billerica, Massachusetts. One written iit was received from the Oonnonwealth of Massachusetts. There were four oral cements presented at the June 23, 1988 public hearing. Copies of the hearing transcript are available at the information repositories located at the Billerica Public Library, Billerica Town Hall, and the EPA Records Center at 90 Canal Street, First Floor, in Boston, Massachusetts. The oral and written ocmnents are sunmarized and organized into the following categories: A. Questions Regarding the Remedial Alternatives B. Questions Regarding Enforcement Issues EPA responses are provided for each cement, or set of like comments. A. Questions Regarding the Remedial Alternatives 1. The Oonncnwealth of Massachusetts indicated its acceptance of the cxi'iLtipt of bioremediation for the sediments, sludges and soils from the lagoons. The Qonmanwealth expressed concern about how bioremediation would affect the site's air and groundwater quality. EPA P-PSLxuise; EPA believes that air quality problems will not result. In 1986, DEQE conducted monitoring that found no elevated levels of contamination in air. Additionally, EPA believes that because there ------- 8 are only low levels of volatile organic compounds fVOCs) in the lagoon wastes, the bioremadiation process will not result in ' oontaminant levels that eacceed Massachusetts' allowable ambient levels (A&l*). Although detectable levels of asbestos were found in four soil staples, the levels were just above the detection limit and well below EPA's action levels or levels that could results in any adverse health affects. Besides the results of EEQE's and EPA's studies that indicate that air quality will not be adversely affected, the Record of Decision (POD) contains a provision that calls for the design of the remedy to include a complete fiUFintTmnnt of potential impacts associated with air emissions and odors. Based on this miBenmmiint. any to ensure air quality will be implemented. Regarding groundwater quality, the bioremedation process will be conducted as a closed system; there will be no discharges to groundwater during implementation. Additionally, results of the tcodcity characteristic leaching procedure (TOP) test ocrrtiinfed during the Remedial Investigation indicated that the wastes will not leach contaminants into groundwater. 2. One ccanenter asked how EPA will treat the bottom layer of waste without puncturing the impervious liner. To make sure that the impermeable liner or containment layer is not ------- 9 punctured, the botton layer of waste will be placed on top of a protective bedding layer of soil and not directly on the liner. Bus bedding layer will ensure that handling of the waste and tilling operations do not damage the liner. 3. One concenter asked whether EPA would capture and treat precipitation that filters through the bioremediation treatment area. EPA Response; The bioremediation process will be designed in such a way that no water leaves the system. When it rains, the water will be collected and returned to the treatment area to supply moisture for the organisms that are degrading the wastes. 4. Another oommenter asked whether EPA had examined the impact that the cleanup process would have on the rest of the site. Specifically, the commenter asked whether EPA had analyzed what roadways would be used, and whether other parts of the site would be disturbed. EPA Response; Other than the five-acre area used to treat the waste, no other parts of the Iron Horse Park site will be disturbed by the bioremediation process.' Although the details regarding which roads would be utilized for the bioremediation process will be decided during the design phase of the remedial activities, the present access roads located just south of the lagoons would probably be used. ------- 10 5. One ujuueuLar asked how the design of the cleanup will address the fact that groundwatar levels at the site are artificially elevated. Graundwater levels (that is, the elevation of grcundwater found in the soil and not contamination levels) at the site are elevated because of the large volume of water that continues to be discharged to the lagoons. When the ongoing discharge to the lagoons is. stopped, groundwater levels will return to a lower, natural elevation. Secur arri 6. One oconenter indicated that access to the Iron Horse Park site is easy, and people tend to use the site for recreational purposes such as horseback riding and riding off-road vehicles. The ocanenter expressed concern that if security is not increased (e.g. , by installing fences and hiring on-sita security personnel) , people will continue to enter the site and possibly interfere with the biorsnediation process and cone into contact with the wastes. The coanenter doss not believe that security and maintenance should be the responsibility of the Town, sine* the Town did not create the situation* When the biaremediation process is implemented, security to ensure that the ptuuess is not disturbed and to ensure that people do not into contact with the wastes will be put in place. This nay ------- 11 involve fencing the area and using en-site security personnel if necessary. 7. One ccnraenter stated his belief that contaminants have been found in soil outside of the lagoon study area, and that this contamination has spread from the lagoons. He asked if anything has been done to determine how far these contaminants have spread, and how they will be cleaned up. During the Remedial Investigation for the B & M lagoons, an extensive evaluation of the extent of contamination in the soil of the surrounding area of the lagoons was conducted. Based on this work, EPA believes that contamination from the lagoons is confined to the piles of materials found within the 15 acres that surround the lagoons. EPA does not believe that contamination from the lagoons was dumped outside the fifteen acres, or has spread outside this area. B. Questions Regarding Enforcement Issues for Bonding 1. One commenter was very concerned that if a potentially responsible party (PEP) were to conduct the cleanup, the PRP have full bonding. The commenter noted that at no time during the cleanup procedure should the amount of bonding be reduced by more than 50%. The commenter argued that with such bond assurances, residents could be ------- 12 sure about the project's continued cleanup without funding delays. If a HIP want to conduct the cleanup, EPA would ensure that the FRP has both the technical and financial resources to do the work. Plans and specifications oust be certified by a professional erijineer and a reputable contractor or other qualified party oust conduct the cleanup work* ------- 13 IV. REMAINING GCNCEE96 During the public comment period, at the public informational meeting held in Billerica on June 8, 1988, and at the informal public hearing held on June 23, 1988, local residents ri|lern.ggo^ issues that may continue to be of as the site moves into the design and implementation phase of EPA's selected remedy for the Iron Horse Park site. These issues and concerns are described below along with statements about how EPA intends to address these (A) Odors Citizens exrg*a-c!f>d coiv*>rT^ the bio-rump^ Cation would in bothersome and offensive odors. EPA is aware of this concern and will take measures to decrease the likelihood that bioremediation will cause offensive odors during the design and isplementation of the remedy. (B) Groundwater mouixlwater contamination at the 552—acre site. At the public informational meeting on June 8, 1988, EPA made a conmitment to forward a copy of the survey map to the information repositories. During the Remedial Design/Remedial Action phase, EPA will ------- 14 nincy groundwoter be prepared to release new information oontaaaination when it lieriines available and to answer questions oonoerninj this iiifouBation. (C) EEA will oversee the design and implementation of all major aspects of the bioCTmadiation prooass. Hie connecticn to Billerica's wastewater treatment system is being imiwyrt by the State and Town engineer. ------- 15 GCMCKEIY EELAT1CK5 TEE HQt £CRSE PARK STDB IN HUXERICA, MASSACHUSETTS Community relations activities conducted at the Iron Horse Park Superfund site to date have included; o August 1985 - EPA released a community relations plan describing citizen concerns about, the site and outlining a program to address these concerns and to keep citizens informed about and involved in site activities. o October 1985 - At two separate meetings, EPA officials briefed the Billerica Superintendent of Public Works and members of the Executive Committee of the Superfund Action Committee Coalition (SACC) on the status of the site and answered questions about the detection of PCBs on site. o December 1985 - £PA released a fact sheet to update the public about the initial Rampdial Investigation activities occuring at the site. o 1985, 1986 - EPA representatives continued to attend the public meetings of the SAC to update them on the progress of the initial investigation. ------- 16 o August 1987 - EPA issued a public notice announcing the availability of the Phase 1A RI, and the upcoming public meeting to explain the results of the RI. o August 1987- EPA released a fact nheet summarizing the results of the Phase 1A RI. o August 4, 1987 - EPA held a public meeting to present the results of the Phase 1A RI and to answer questions from the public. o June 1988 - EPA mailed the Proposed Plan announcing EPA's preferred alternative for addressing contamination in the lagoon area to all those on the site mailing list. o June 1, 1988 - EPA issued a public notice to announce the tine and pl%^» of the upcoming FS public informational meeting for the lagoons at the site and to invite public ouuueiit on the FS and Plan. June 8, 1988 - EPA held a public meeting to discuss the results of the lagoon area RT/FS. EPA coordinated the meeting with the local SAC regular committee meeting. June 23, 1988 - EPA held an informal public hearing to accept oral comments on the remedial alternatives evaluated in the lagoon area FS and Proposed Plan. ------- RECORD OF DECISION BOSTON i MAINE WASTEWATER LAGOONS AT IRON HORSE PARK APPENDIX B ADMINISTRATIVE RECORD INDEX ------- Iron Horse Park NPL Site Administrative Record Index As of September 15, 1988 Prepared for Region I Waste Management Division U.S. Environmental Protection Agency With Assistance from AMERICAN MANAGEMENT SYSTEMS, INC. One Kendall Square, Suite 2200 • Cambridge, Massachusetts 02139 • (617) 577-9915 ------- Iron Horse Park NPL Site Administrative Record Table of Contents Volume I 1.0 Pre-Remedial 1.2 Preliminary Assessment 1.3 Site Inspection 2.0 Removal Response 2.9 Action Memoranda 3.0 Remedial Investigation (RI) 3.1 Correspondence 3.5 Applicable or Relevant and Appropriate Requirements (ARARs) 3.6 Remedial Investigation (RI) Reports Volume n 3.6 Remedial Investigation (RI) Reports (cont'd.) Volume m 3.6 Remedial Investigation (RI) Reports (cont'd.) Volume IV 3.7 Work Plans and Progress Reports 3.12 Action Memoranda 4.0 Feasibility Study (FS) 4.1 Correspondence 4.5 Applicable or Relevant and Appropriate Requirements (ARARs) 4.6 Feasibility Study (FS) Reports ------- Iron Horse Park NPL Site Administrative Record Table of Contents fcont'd.) Volume V 4.9 Proposed Plans for Selected Remedial Action 5.0 Record of Decision (ROD) 5.1 Correspondence 5.3 Responsiveness Summaries 5.4 Record of Decision (ROD) 10.0 Enforcement 10.3 State and Local Enforcement Records 13.0 Community Relations 13.2 Community Relations Plans 13.3 News Clippings/Press Releases 13.6 Mailing Lists 16.0 Natural Resource Trustee 16.2 Interagency Agreements/Memoranda of Understanding 16.4 Trustee Notification Form and Selection Guide 17.0 Site Management Records 17.8 State and Local Technical Records Administrative Record Index ------- Introduction This document is the Index to the Administrative Record for the Iron Horse Park National Priorities List (NPL) site. Section I of the Index cites site-specific documents, and Section n cites guidance documents used by EPA staff in selecting a response action at the site. The Administrative Record is available for public review at EPA Region Ts Office in Boston, Massachusetts, and at the Billerica Public Library, 25 Concord Road, Billerica, Massachusetts, 01821. Questions concerning the Administrative Record should be addressed to the EPA Region I site manager. The Administrative Record is required by the Comprehensive Environmental Response, Compensation, and Liability Act (CERCLA), as amended by the Superfund Amendments and Reauthorization Act (SARA). ------- Section I Site-Specific Documents ------- Page 1 ADMINISTRATIVE RECORD INDEX for the Iron Horse Park NPL Site 1.0 Pre-Remedial 1.2 Preliminary Assessment 1. "Preliminary Site Assessment of the Iron Horse Park Facility," NUS Corporation (May 23,1983). 1.3 Site Inspection 1. "Final Report for Iron Horse Park Site Inspection Report," NUS Corporation (September 12,1984). 2.0 Removal Response 2.9 Action Memoranda 1. Memorandum from Robert J. Ankstitus, EPA Region I to Michael R. Deland, EPA Region I (June 26, 1984). 2. Memorandum from Michael R. Deland, EPA Region I to Lee M. Thomas, EPA Headquarters (October 3,1984). 3. Memorandum from William N. Hedeman, Jr., EPA Headquarters to Lee Thomas, EPA Headquarters (October 12,1984). 3.0 Remedial Investigation (R!) 3.1 Correspondence 1. Memorandum from John Gallagher, EPA Region I to Robert Bois, Commonwealth of Massachusetts Department of Environmental Quality Engineering (January 13,1988). 3.2 Sampling and Analysis Data The Sampling and Analysis and Contract Laboratory Program (CLP) Data for the Remedial Investigation (RI) may be reviewed, by appointment only, at EPA Region I, Boston, Massachusetts. 3 J Applicable or Relevant and Appropriate Requirements (ARARs) 1. Letter from Richard Cavagnero, EPA Region I to Madeline Snow, Commonwealth of Massachusetts Department of Environmental Quality Engineering (March 12,1987). 2. List of State Requirements, Dodie Brownlee, Commonwealth of Massachusetts Department of Environmental Quality Engineering (July 28,1987). 3. Memorandum from John Gallagher, EPA Region I to Margaret Leshen, Gretchen Muench and Ira Leigh ton, EPA Region I (March 31,1988) (CONFIDENTIAL). ------- Page 2 3.6 Remedial Investigation (RI) Reports 1. "Draft Phase 1A Remedial Investigation for the Iron Horse Park Site," Camp Dresser & McKee Inc. (July 1987). 2. Appendices A through C for "Preliminary Draft Phase 1A Remedial Investigation for the Iron Horse Park Site," Camp Dresser & McKee Inc. (July 1987). 3. Appendix D for "Preliminary Draft Phase 1A Remedial Investigation for the Iron Horse Park Site," Camp Dresser & McKee Inc. (July 1987). 4. "Draft Phase IB Remedial Investigation for the Boston and Maine Wastewater Lagoon Area - Iron Horse Park Site," Camp Dresser & McKee Inc. (May 1988). 5. Appendices A through C for "Draft Phase IB Remedial Investigation for the Boston and Maine Wastewater Lagoon Area • Iron Horse Park Site," Camp Dresser & McKee Inc. (May 1988). 6. Appendices D and E for "Draft Phase 1B Remedial Investigation for the Boston and Maine Wastewater Lagoon Area - Iron Horse Park Site," Camp Dresser & McKee Inc. (May 1988). 3.7 Work Plans and Progress Reports 1. "Work Plan Memorandum for Iron Horse Park Remedial Investigation/ Feasibility Study," Camp Dresser & McKee Inc. (October 18,1984). 2. "Project Operations Plan for Iron Horse Park Remedial Investigation," Camp Dresser & McKee Inc. (February 27,1985). 3. "Work Plan for Iron Horse Park Remedial Investigation/Feasibility Study - Volume I: Technical Scope of Work," Camp Dresser AMcKee Inc. (May 10,1985). 4. "Work Assignment Amendment No. 2 - Iron Horse Park Site - Remedial Investigation/Feasibility Study," Camp Dresser & McKee Inc. (May 22,1986). 5. "Work Plan Amendment No. 3 - Iron Horse Park • Remedial Investigation/ Feasibility Study," Camp Dresser & McKee Inc. (March 31,1987). 6. "Work Plan Amendment No. 5 - Iron-Horse Park - Remedial Investigation/ Feasibility Study," Camp Dresser & McKee Inc. (June 5,1987). 3.12 Action Memoranda 1. Memorandum from Merrill S. Hohman, EPA Region I to Michael R. Deland, EPA Region I (September 19,1984). 2. Memorandum from Merrill S. Hohman, EPA Region I to William N. Hedeman, Jr., EPA Headquarters (September 19,1984). 4.0 Feasibility Study (FS) 4.1 Correspondence - . 1. Memorandum from John Gallagher, EPA Region I to Robert Bois, Commonwealth of Massachusetts Department of Environmental Quality Engineering (February 26,1988). 2. Technical Memorandum: "Feasibility Study of a Bioremediation Alternative for the B & M Lagoons, Document #132-FS2-ET-GCEW-1," Richard Christian and Andrea Sewall, Camp Dresser & McKee Inc. (April 26,1988). 3. Letter from John Gallagher, EPA Region I to Dodie Brownie*, Commonwealth of Massachusetts Department of Environmental Quality Engineering (April 28,1988). ------- Pace 3 4.1 Correspondence (cont'd.) 4. Letter from John Gallagher, EPA Region I to Robert Bois, Commonwealth of Massachusetts Department of Environmental Quality Engineering (July 21, 1988). 4.5 Applicable or Relevant and Appropriate Requirements (ARARs) 1. Memorandum from John Gallagher, EPA Region I to File (September 14,1988). 4.6 Feasibility Study (FS) Reports \ Feasibility Study (FS) Reports 1. "Draft Feasibility Study for the Boston & Maine Wastewater Lagoon Area - Iron Horse Park Site," Camp Dresser & McKee Inc. (June 1988). Feasibility Study (FS) Reports Comments 1. Comments Dated July 7,1988 from Robert Bois, Commonwealth of Massachusetts Department of Environmental Quality Engineering on the June 1988 "Draft Feasibility Study for the Boston & Maine Wastewater Lagoon Area - Iron Horse Park Site," Camp Dresser & McKee Inc. 4.7 Work Plans and Progress Reports 1. Cross-Reference: "Work Plan Memorandum for Iron Horse Park Remedial Investigation/Feasibility Study," Camp Dresser & McKee Inc. (October 18,1984) (Filed and cited as entry number 1 in 3.7 Work Plans and Progress Reports], 2. Cross-Reference: "Work Plan for Iron Horse Park Remedial Investigation/ Feasibility Study - Volume I: Technical Scope of Work," Camp Dresser & McKee Inc. (May 10,1985) [Filed and cited as entry number 3 in 3.7 Work Plans and Progress Reports]. 3. Cross-Reference: "Work Assignment Amendment No. 2 - Iron Horse Park Site - Remedial Investigation/Feasibility Study," Camp Dresser & McKee Inc. (May 22,1986) [Filed and cited as entry number 4 in 3.7 Work Plans and Progress Reports]. 4. Cross-Reference: "Work Plan Amendment No. 3 - Iron Horse Park - Remedial Investigation/Feasibility Study," Camp Dresser & McKee Inc. (March 31,1987) [Filed and cited as entry number 5 in 3.7 Work Plans and Progress Reports]. 5. Cross-Reference: "Work Plan Amendment No. 5 - Iron Horse Park - Remedial Investigation/Feasibility Study," Camp Dresser & McKee Inc. (June 5,1987) [Filed and cited as entry number 6 in 3.7 Work Plans'and Progress Reports]. 4.9 Proposed Plans for Selected Remedial Action 1. "EPA Region I Superfund Program Proposed Plan - Iron Horse Park Site - Billerica, Massachusetts," EPA Region I (May 1988). ------- Page 4 5.0 Record of Decision (ROD) 5.1 Correspondence 1. Letter from Margaret Leshen, EPA Region I to Robert Bois, Commonwealth of Massachusetts Department of Environmental Quality Engineering (February 5, 1988). 2. Letter from John Gallagher, EPA Region I to Robert Bois, Commonwealth of Massachusetts Department of Environmental Quality Engineering (August 2,1988). 5.3 Responsiveness Summaries \ 1. Cross-Reference: "Final Responsiveness Summary," EPA Region I (September 1988) [Filed and cited as entry number 1 in 5.4 Record of Decision (ROD) as Appendix A]. 2. Transcript, Feasibility Study and Proposed Plan Public Meeting for the Lagoon Area at the Iron Horse Park Superfund Site, EPA Region I (June 23,1988). 5.4 Record of Decision (ROD) 1. "Record of Decision," EPA Region I (September 15,1988). 10.0 Enforcement 10.3 State and Local Enforcement Records 1. Administrative Order, In the Matter of Boston &. Maine Corporation, Docket No. 581, (May 29,1985). 2. Letter from John W. Morris, Town of Billerica Board of Health to Boston & Maine Corporation (December 28,1987). 3. Administrative Order, In the Matter of Boston & Maine Corporation, Docket No. 723, (February 4,1988). 13.0 Community Relations 13.1 Correspondence 1. Cross-Reference: Letter from John Gallagher, EPA Region I to Dodie Brownlee, Commonwealth of Massachusetts Department of Environmental Quality Engineering (April 28,1988) [Filed and cited as entry number 2 in 4.1 Correspondence]. 13.2 Community Relations Plans 1. "Community Relations Plan - Iron Horse Park - Billerica, Massachusetts," (August 1985). 13.3 News Clippings/Press Releases 1. "Environmental News - Public Meeting to Describe Proposed Cleanup Plan for Lagoons at the Iron Horse Park Superfund Site Announced," EPA Region I (June 1,1988). ------- Page 5 13.4 Public Meetings 1. Gross-Reference: Transcript, Feasibility Study and Proposed Plan Public Meeting for the Lagoon Area at the Iron Horse Park Superfund Site (June 23,1988) [Filed and cited as entry number 2 in 5.3 Responsiveness Summaries]. 13.5 Fact Sheets 1. Cross-Reference: "EPA Region I Superfund Program Proposed Plan - Iron Horse Park Site - Billerica, Massachusetts," EPA Region I (May 1988) [Filed and cited as entry number 1 in 4.9 Proposed Plan for Selected Remedial Action]. \ 13.6 Mailing Lists 1. Mailing List of Media Contacts, Members of the Public, EPA Contacts, and State Officials (May 26, 1988). 16.0 Natural Resource Trustee 16.2 Interagency Agreements/Memoranda of Understanding 1. "Interagency Agreement/Amendment" Form, EPA Region I and U.S. Department of the Interior, Fish & Wildlife Service (September 26,1985). 16.4 Trustee Notification Form and Selection Guide 1. "Trustee Notification Form," EPA Region L 17.0 Site Management Records 17.8 State and Local Technical Records 1. "Sewer System Evaluation Study - Iron Horse Park," Green International Affiliates, Inc. (September 1985). ------- Section II Guidance Documents ------- Page 6 GUIDANCE DOCUMENTS EPA guidance documents and the Commonwealth of Massachusetts laws and regulations relied upon for this decision document may be reviewed at EPA Region I, Boston, Massachusetts. General EPA Guidance Documents 1. Comprehensive Environmental Response. Compensation, and Liability Act of 1980. amended October 17,1986. 2. Memorandum from Francis S. Blake, General Counsel, to J. Winston Porter, Assistant Administrator for Solid Waste and Emergency Response, July 31,1987 (discussing the scope of the CERCLA petroleum exclusion under sections 101(14) and 104(a)(2)). 3. Memorandum from J. Winston Porter to the U.S. Environmental Protection Agency, July 9,1987 (discussing interim guidance on compliance with applicable or relevant and appropriate requirements). 4. "National Oil and Hazardous Substances Pollution Contingency Plan," Code of Federal Regulations (Title 40, Part 300), 1985. 5. U.S. Environmental Protection Agency. Office of Emergency and Remedial Response. Community Relations in Superfund: A Handbook (Interim Version) (EPA/HW-6), September 1983. 6. U.S. Environmental Protection Agency. Office of Emergency and Remedial Response. Draft Guidance on Conducting Remedial Investigations and Feasibility Studies under CERCLA (Comprehensive Environmental Response. Compensation, and Liability Act). March 1988. 7. U.S. Environmental Protection Agency. Office of Emergency and Remedial Response. Draft Guidance on Remedial Actions for Contaminated Ground Water at Superfund Sites (OSWER Directive 9283.1-2), October 1986. 8. U.S. Environmental Protection Agency. Office of Emergency and Remedial Response. Superfund Public Health Evaluation Manual (OSWER Directive 9285.4-1), October 1986. 9. U.S. Environmental Protection Agency. Office of Ground-Water Protection. Ground-Water Protection Strategy. August 1984. 10. U.S. Environmental Protection Agency. Office of Solid Waste and Emergency Response. Additional Interim Guidance for Fiscal Year 1987 Record of Decisions, July 24,1987. 11. U.S. Environmental Protection Agency. Office of Solid Waste and Emergency Response. Data Quality Objectives for Remedial Response Activities: Development Process (EPA/540/G-87/003), March 1987. 12. U.S. Environmental Protection Agency. Office of Solid Waste and Emergency Response. Guidance on Feasibility Studies under CERCLA (Comprehensive Environmental Response. Compensation, and Liability Act) (EPA/540/G-85/003), June 1985. 13. U.S. Environmental Protection Agency. Office of Solid Waste and Emergency Response. Guidance on Remedial Investigations under CERCLA (Comprehensive Environmental Response. Compensation, and Liability Act) (EPA/540/G-85/002), June 1985. ------- Page? 14. U.S. Environmental Protection Agency. Office of Solid Waste and Emergency Response. Interim Guidance on Superfund Selection of Remedy (OSWER Directive 9355.0-19), December 24,1986. ------- RECORD OF DECISION BOSTON & MAINE WASTEWATER LAGOONS At IRON HORSE PARK APPENDIX C STATE CONCURRENCE ------- -(oowwnovuuea/th $a»cttfate af&UCUtfiv Daniel S. Greenbaum One rrvnfov Jfaef, y&o4fcft> 02108 Commissioner September 13, 1988 Michael R. Deland RE: Billerica - Concurrence with Regional Administrator ROD for Iron Horse Park U. S. EPA Superfund Site - Boston 4 Maine JFK Federal Building Lagoons Boston, MA 02203 Dear Mr. Deland: The Department of Environmental Quality Engineering (the Department) has reviewed the preferred remedial action alternative that EPA is recommending for the Boston & Maine lagoons at the Iron Horse Park federal Superfund site. The Department concurs with the selection of the preferred alternative for the lagoons. The Department has evaluated EPA's preferred alternative for consistency with M.G.L. Chapter 21E as amended in November 1986. The Department has deter- mined that the preferred alternative, bioremediation. is consistent with the overall permanency requirements of M.G.L. Chapter 21E. Chapter 21E encourages implementing remedies on portions of a site to address the pressing hazards. A determination, however, that a permanent solution has been achieved can not be made until it has been demonstrated that a selected remedial measure or com- bination of measures will meet the Total Site Risk Limits as defined in 310 CMR 40.00 for the entire site. The Department looks forward to working with you in implementing the per- ferred alternative. If you have any questions or require additional information please contact Dodie Brownlee at 292-5579. Very truly yours. Daniel S. Greenbaum DSG/lgw cc: Richard Chalpin, NERO ------- Daniel S. Greenbaum Conmissioner tcAMAe/fa/ nci4J(Gsiniea^ asv o£ JCcu&cutcfaub ivaAfo . 02108 a ff September 14, 1988 RE: Iron Horse Park Superfund site - B & M Lagoons John Gallagher U. S. EPA JFK Federal Building Boston. MA 02203 Mail Stop: SEC - CAN6 Dear John: The following Massachusetts environmental regulations are applicable or relevant and appropriate to the selected remedial action for the B'& M Lagoons at Iron Horse Park: Massachusetts Regulations for the Land Application of Sludge and Septage (310 CMR 32) Massachusetts Groundwater Discharge Permit Program (314 CMR 5.00) Massachusetts Air Quality Regulations (310 CMR 6.00-8.00) Massachusetts Wetlands Protection Regulations (310 CMR 10.00) The ROD for the B & M lagoons complies with the above regulations. Very truly yours, Robert Bois, MA Federal Superfund Coordinator RBB/lgw cc: Dodie Brownlee Dick Chalpin ------- |