UntodStUM
Environmental
Agenqr
EPA/ROD/R01-88/026
September 1988
A EPA
Superfund
Record of Decision:
Iron Horse, MA
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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.
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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.
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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.
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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
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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
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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
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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
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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.
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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
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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
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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
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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
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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.
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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
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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
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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.
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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
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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
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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
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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
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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) .
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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-
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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
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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.
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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.
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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.
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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
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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
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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
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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
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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)
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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.
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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
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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.
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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
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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
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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.
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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.
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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) .
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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
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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.
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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
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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
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Exhibit 3
KEY SITE MATURES MAP
IRON HORSE PARK SITE, BILLERICA. MASSACHUSETTS
JOHNS-MANVN.LE
GeOWGe MCOUESTEN
^
^ ASBESTOS LANDFILL
WOOOFABmCATORS
BAM
^SEWAGE
LAGOONS
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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
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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
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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
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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.
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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
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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
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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*
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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
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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.
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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.
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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.
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RECORD OF DECISION
BOSTON i MAINE WASTEWATER LAGOONS AT IRON HORSE PARK
APPENDIX B
ADMINISTRATIVE RECORD INDEX
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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
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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
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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
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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).
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Section I
Site-Specific Documents
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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).
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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).
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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).
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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).
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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).
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Section II
Guidance Documents
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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.
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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.
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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
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