United States
Environmental Protection
Agency
Office of
Emergency and
Remedial Response
EPA/ROD/R01 -88/030
September 1988
SEPA
Superfund
Record of Decision
Groveland Wells, MA
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50273-101 .
REPORT DOCUMENTATION li. REPORT NO.
PAGE
EPA/ROD/R01-88/030
2.
3. Recipient's Accession No.
4. Title end Subtitle
SUPERFUND RECORD OF DECISION
Groveland Wells, MA.
^•irsfc Remedial Action
•Author
5. Report Oete
09/30/88
aril)
8. Performing Organization R«pt. No.
9. Performing Organization Neme end Address
10. Preject/Task/Work Unit No.
11. Contraet(C) or Grant(G) No.
(C)
(G)
12. Sponsoring Organization Name and Address
U.S. Environmental Protection Agency
401 M Street, s.W.
Washington, D.C. 20460
13. Type of Report & Period Covered
800/000
14.
15. Supplementary Notes
850-acre Groveland Wells site is located in the Town of Groveland, Essex County,
Massachusetts within the lower Johnson CreeK drainage basin. The site includes the
watershed, and aquifer which recharge two municipal supply wells, Station Nos. 1 and 2,
and three known sources of soil, surface water, and ground water contamination: the
Valley site, the A.W. Chesterson site, and the Havenhill Municipal Landfill site. This
remedial action addresses source control at the Valley site. The remaining operable
of the Groveland Wells site will be addressed in subsequent remedial actions. The
site operable unit is located in the far northwestern section of the Town of
, and is bordered to the north and south by residences within 100 feet of the
site. The Town of Groveland 's municipal water supply well, Station No. 1, is located
approximately 3,500 feet northeast and downgradient of the Valley site, and is currently
being treated to remove VOCs as part of an initial remedial measure by EPA. The Valley
Manufactured Products Company (Valley) began operating a metals and plastic parts
manufacturing business in 1963 on a 1.5-acre parcel of property owned by Groveland
Resources Corporation (GRC). The Valley site area consists of the land within and
immediately adjacent to the GRC property boundaries and contains three subsurface
disposal systems, and an oil storage and recovery system consisting of six underground
(See Attached Sheet)
Groveland Wells, MA
First Remedial Action
Contaminated Media: gw, sediments, soil, sw
Key Contaminants: metals (arsenic, lead), VOCs (PCE, TCE, toluene)
b. Identifiers/Open-ended Terms
c. COSATI Reid/Group
ivailability Statement
19. Security Class (This Report)
None
20. Security Class (This Page)
None
21. No. of Pages
210
22. Price
(See ANSI-Z39.18)
See /nstructions on Reverse
OPTIONAL FORM 272 (4-77)
(Formerly NTIS-35)
Department of Commerce
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EPA/ROD/R01-88/030
oveland Wells, MA
Remedial Action
16. ABSTRACT (continued)
tanks and a 55-gallon drum storage area both of which were used to store cutting oils
and solvents such as TCE and methylene chloride. These subsurface disposal systems
dispersed liquid effluent into the ground by filtration through a sand and gravel leach
field. According to Valley/GRC, more than 20 gallons of waste cutting oil containing
TCE and other hazardous substances were released each month on the ground at the south
end of the building between 1964 and 1972. Also, at least four 55-gallon drums of the
same material was used as a defoliant on the eastern side of the building. Between 1979
and 1984, effluent from an acid bath finishing process was discharged to an underground
leach field, and TCE-contaminated oil was released on the soil under a loading dock and
into a floor drain. In 1973, 500 gallons of raw TCE was released from an underground
storage tank into the soil, and additional waste oils and solvents were dumped on the
ground. A site investigation in 1983 revealed high levels of TCE, arsenic, lead, and
copper in the underground disposal systems. Additional sample analysis has detected
soil contaminated with VOCs from the surface to a depth of 15 feet in various locations
onsite. Analysis of surface water and sediments from Mill Pond, downstream of the
Valley site, as well as ground water from monitoring wells in the site area, also
detected VOC contamination. Based on the concentration of VOCs detected in the
subsurface soil and ground water, and historical site use information, both media are
believed to be contributing to ground water and surface water contamination in the
Valley site area and the Mill Pond/ Johnson Creek watershed and aquifer. The primary
contaminants of concern affecting soil, sediments, ground water, and surface water are
Bt)Cs including TCE, PCE, and toluene, and metals including arsenic and lead.
The selected remedial action for the Valley site operable unit includes: in situ
vacuum extraction of approximately 20,000 yd^ of unsaturated soil followed by
activated carbon treatment of the extracted VOCs; onsite ground water pump and treatment
by carbon adsorption and aeration, with recharge to the aquifer of a portion of the
treated ground water upgradient of the site to accelerate removal of saturated zone soil
contamination, and discharge of the remainder of the treated ground water to the aquifer
downgradient of the site, and treatment of air emissions from the aeration process by
carbon adsorption; ground water monitoring; and sealing or disconnecting all drains and
lines to the acid bath finishing process disposal system. Incidental treatment of
inorganic compounds and other contaminants will be provided as necessary in order to
efficiently operate the VOC contaminant treatment system and to meet applicable
discharge permit requirements. The estimated present worth cost of this remedial action
is $4,165,000, with a 10-year present worth O&M cost of $2,677,000.
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Record of Decision
Remedial Alternative Selection
Site Name and Location
Groveland Wells Nos. 1 & 2 Site
Valley Site Source-Control Organic Operable Unit
Groveland, Massachusetts
Statement of Purpose
This Decision Document presents the selected remedial action for
an operable unit for the Valley Site portion of this NPL site
organic contamination developed in accordance with the
Comprehensive Environmental Response, Compensation, and Liability
Act of 1980 (CERCLA), as amended by the Superfund Amendments and
Reauthorization Act of 1986 (SARA), and to the extent
practicable, the National Contingency Plan (NCP); 40 CFR Part 300
et sea.. 47 Federal Register 31180 (July 16, 1982), as amended.
The Regional Administrator for Region I has been delegated the
authority to approve this Record of Decision.
In accordance with CERCLA Section 121(f)(!)(Ł) and (G), EPA has:
provided the Commonwealth of Massachusetts with the opportunity to
review and comment on the Remedial Investigation, the Feasibility
Study, and the Proposed Plan for Remedial Action. The Commonwealth
has concurred in the selected remedy for this operable unit and has
determined, through a detailed evaluation, that the selected remedy
is consistent with its laws and regulations.
Statement of Basis
This decision is based on the administrative record which was
developed in accordance with Section 113(k) of CERCLA and which is
available for public review at the information repositories (index
attached). The attached index identifies the items which comprise
the administrative record upon which the selection of a remedial
action is based.
Description of the Selected Remedy
The selected remedy for the Valley Site is a source control action
which will entail remediation of organic contamination in both
soils and groundwater within the Valley Site boundaries. As such,
the action addresses an operable unit of the larger Groveland Wells
Site.
The soil remediation entails the following:
* In-situ vacuum extraction of approximately 20,000 cubic
yards_of unsaturated soils covering an area of
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approximately 25,000 square feet followed by activated
carbon treatment of the extracted volatile organic
contaminants.
Vacuum extraction followed by carbon adsorption
treatment is a proven, innovative technology which is
effective in permanently removing volatile organic
contamination, thereby treating unsaturated soils
without the need for excavation. This technology was
piloted at the site as part of the Superfund Innovative
Technology Evaluation (SITE) Program.
It is anticipated that the bulk of soil contamination
will be removed and treated within one to two years,
although five to ten years of operation may be required
to attain the soil cleanup goals.
The groundwater treatment component entails the following:
Active restoration of the overburden/bedrbck aquifer
contaminated primarily with volatile organic compounds
(VOCs). The groundwater extraction/reinjection system
will involve the installation of approximately four to
six downgradient recovery wells and four to six
upgradient recharge wells on site. To the extent that
inorganics will need to be removed during treatment,
this remedy will provide some remediation of inorganics
contamination.
Treatment of contaminated groundwater from the site for
removal of volatile organic compounds (VOCs) by aeration
and carbon adsorption. VOC emissions from the air
stripper will be removed by carbon adsorption. A
portion of the treated groundwater will be recharged to
the aquifer upgradient of the site to accelerate
contaminant removal from the saturated zone soils, while
the remainder will be discharged downgradient of the
site.
It is anticipated that the bulk of the groundwater
contamination will be removed in less than five years,
although five to ten years of operation may be required
to attain the VOC groundwater cleanup goals, which are
set at drinking water standards or other appropriate
health based goals.
The final design of the groundwater
recovery/recirculation and treatment system will be
based on ongoing treatability studies performed by
Valley under the terms of a Consent Order.
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The estimated present worth cost for the source control soil and
groundwater remediation is $4.1 million, which includes capital
costs and present worth costs of operation and maintenance for the
projected ten years of soil and groundwater treatment.
Declaration
The selected remedy is protective of human health and the
environment, attains Federal and State requirements that are
applicable or relevant and appropriate, and is cost-effective.
This remedy satisfies the statutory preference for treatment that
permanently and significantly reduces the volume, toxicity or
mobility of the hazardous substances, pollutants and contaminants
as a principal element to the maximum extent practicable. It is
determined that this remedy utilizes permanent solutions and
alternative treatment technologies or resource recovery
technologies to the maximum extent practicable.
Date Michael R. Deland
Regional Administrator, EPA
Region I
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ROD DECISION SUMMARY
GROVELAND WELLS NOS. 1 & 2 SITE
VALLEY SITE ORGANICS SOURCE-CONTROL OPERABLE UNIT
GROVELAND, MASSACHUSETTS
September 30, 1988
U.S. Environmental Protection Agency
Region I
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GROVELAND WELLS NOS. 1 & 2 SITE
VALLEY SITE ORGAN I CS SOURCE-CONTROL OPERABLE UNIT
Record of Decision Summary
TABLE OF CONTENTS
Contents Page
I. SITE NAME, LOCATION AND DESCRIPTION ........ 1
II. SITE HISTORY .................... 2
A. Site Use History ................. ' 2
B. Response History . ................ 5
C. Enforcement History ............... 7
III. COMMUNITY RELATIONS .......... ..... 8
IV. SCOPE AND ROLE OF OPERABLE UNIT OR RESPONSE ACTION 9
V. SITE CHARACTERISTICS ................ 13
A. Morphology ..................... 13
B. Hydrogeologic Setting ............... 13
1. Surface Water Hydrology . . • ....... : 13
2 . Geology ................. * 13
3. Hydrogeology ............... 14
C. Environmental Contamination ............ 14
1. Air ................... 15
2. Soil ................... 15
3. Surface Water .............. 16
4 . Groundwater ............... 16
D. Groundwater Classification and Use ......... 17
VI. SUMMARY OF SITE RISKS ............... 18
A. Contaminants of Concern .............. 18
B. Human Health Risk Assessment ............ 19
C. Environmental Exposure ..... . ......... 21
D. Cleanup Goals/Area of Attainment -
Point-of-Compliance ................ 21
VII. DOCUMENTATION OF SIGNIFICANT CHANGES ........ 22
VIII. DEVELOPMENT AND SCREENING OF ALTERNATIVES ..... 26
A. Statutory Requirements/Response Objectives ..... 26
B. Technology and Alternative Development and
Screening ..................... 27
C. Cleanup Goals ............... .... 29
IX. DESCRIPTION/SUMMARY OF THE DETAILED AND COMPARATIVE
ANALYSIS OF SOURCE-CONTROL ALTERNATIVES ...... 29
A. SC-1 Minimal No-Action .............. 30
B. SC-2 Vacuum Extraction/High-Rate Groundwater
Treatment ................. 30
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C. SC-3 Vacuum Extraction/Low-Rate Groundwater
Treatment • • 33
D. SC-4 Low-Temperature Thermal Stripping/High-Rate
Groundwater Treatment # 33
E. SC-5 Low-Temperature Thermal Stripping/Low-Rate
Groundwater Treatment • 34
F. SC-6 Off-Site Disposal/High-Rate Groundwater Treatment* 34
X. THE SELECTED SOURCE-CONTROL REMEDY .35
A. Description of the Selected Remedy 35
B. Rationale for Selection/Area of Attainment 37
XI. STATUTORY DETERMINATIONS 41
A. The Selected Remedy is Protective of Human Health
and the Environment 41
B. The Selected Remedy Attains ARARs 42
C. The Selected Remedial Action is Cost Effective . . . .43
D. The Selected Remedy Utilizes Permanent Solutions •
and Alternative Treatment Technologies or Resource
Recovery Technologies to the Maximum Extent
Practicable 43
E. The Selected Remedy Satisfies the Preference for
Treatment as a Principal Element 44
XII. STATE ROLE .44
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APPENDICES
Responsiveness Summary Appendix A
Administrative Record Index Appendix B
State Concurrence Letter Appendix C
Figures Appendix D
Tables Appendix Ł
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ROD DECISION SUMMARY
I. SITE NAME, LOCATION AND DESCRIPTION
SITE NAME: Groveland Wells Nos. 1 & 2 Site
SITE LOCATION: Town of Groveland, Essex County,
Massachusetts
OPERABLE UNIT: Source-Control For Organic Contamination
at the Valley Manufactured Products
Company, Inc./ Groveland Resources
Corporation Site [The Valley Site]
SITE DESCRIPTION:
The Valley Site is located at 64 Washington Street in a
residential area, within the Groveland Wells Nos. 1 & 2 Site
[the Groveland Site], in the northwestern-most portion of the Town
of Groveland. See Figure 1. The Valley Manufactured Products
Company, Incorporated (Valley) operates a metals and plastic parts
manufacturing business which is housed in a 30,000 square foot
building [the Valley Facility] on the approximately 1.5 acre
property [the Property] owned by the Groveland Resources
Corporation (GRC). See Figure 2. Valley/GRC has operated this
manufacturing business on the Property since November, 1963.
•
Groveland Resources Corporation is the current owner of the
Property. Valley Manufactured Products Co., Inc. is the current
operator of the Property and Valley Facility. As such, GRC and
Valley have been notified as responsible parties at the Groveland
Site.
For the purpose of the feasibility study (FS) and this Record of
Decision and implementation of this source-control remedy, the
Valley Site is defined as the building and land within and
immediately adjacent to the Property boundaries. For purposes of
implementation of this remedy with respect to CERCLA §121(e)(l),
"onsite" will refer to the entire Groveland Wells NPL Site. For
the purpose of the remedial investigation (Rl).and endangerment
assessments (EA), the Study Area was defined as the Property and
the area which abuts the Property on the east down to and
including the Mill Pond. See Figure 3.
The Valley Facility has had interim status under the Resource
Conservation and Recovery Act (RCRA) for the storage of hazardous
waste since November 15, 1980. Waste is stored in the material
storage area in the southern end of the building. See Figure 4.
The building and paved parking area occupy the majority of the
Property, each covering 30,000 square feet or a total of
approximately 90% of the Property. A narrow strip of land
averaging approximately ten (10) feet wide runs along the southern
and eastern portions of the building. The Valley Site is bounded
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generally to the west by Washington Street, to the north and south
by residential hones within 100 feet and to the
east by wooded property, currently owned by the Roman Catholic
Archdiocese of Boston, which extends from the upland Property
easterly to the Mill Pond wetland area. See Figure 5.
The general area of the Valley Site is presently served by
municipal water supply and private sanitary septic systems.
The Valley Site contains three subsurface disposal systems: the
sanitary septic system; the truck loading well/storm water system
(the truck veil disposal system); and, the "Brite-Dip" metal parts
cleaning rinse water disposal system (the Brite-Dip disposal
system). The sanitary septic system consists of a septic tank,
associated drains and piping, and a leachfield located under the
existing parking lot. The Brite-Dip disposal system consists of a
concrete distribution box, associated drains and piping, and a
leachfield located outside the building's southeast corner. A
floor drain in the former Brite-Dip acid dip room and one in the
material storage area are connected to the Brite-Dip disposal
system. The truck well disposal system consists of a drainage 1
trough outside the front of the building, a presently sealed former
floor drain in the truck loading dock area and associated drains
and piping, connected to a storm water oil/gas separator, and a
leachfield located along the eastern wall on the existing building.
See figure 4.
In addition, an oil storage and recovery system exists at the
Valley Facility. This system consists of five underground cutting
oil storage tanks ranging in capacity from two thousand (2000) to
three thousand (3,000) gallons. A sixth tank (700 gallons), which
is presently empty, was used to store raw halogenated hydrocarbon
solvent (hereinafter, referred to as solvents) (trichloroethylene
from 1972 to 1979 and methylene chloride from 1979 to 1983).
Lubricating or cutting oils are circulated to the milling machines
inside the facility. These oils are circulated to the recovery
system after use for cleaning and metals removal, before being
recirculated for reuse. Waste oils are finally collected in 55-
gallon drums for off-site disposal. The six storage tanks are
located under the material storage area.
A more complete description of the Valley Site and the Study Area
is contained in the Supplemental Remedial Investigation Report
prepared by M. Anthony Lally Associates, July, 1988 (the SRI).
II. SITE HISTORY AND ENFORCEMENT ACTIVITIES
A. Site Use History
In May 1963, Groveland Resources Corporation (d.b.a. Valley Screw
Products Co., Inc.) leased the Property and began
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operations. In November 1966, Groveland Resources Corporation
(d.b.a. Valley Screw Products Co., Inc.) purchased the Property
and continued to operate the manufacturing business on it. On
August 1, 1979, Valley Manufactured Products Co., Inc. (a
corporation organized and incorporated on May 31, 1979) acquired
the manufacturing business operations of Groveland Resources
Corporation at the Property. Groveland Resources Corporation is
the current owner of the Property. Valley Manufactured Products
Co., Inc. is the current operator of the Property.
Since operations began at the Property in May 1963, the three
subsurface disposal systems described above in Section I have been
installed and used. Each of these disposal systems disperses
liquid effluent into the environment by filtration through a sand
and gravel leachfield. The response history with respect to these
disposal systems is discussed below in Section II.B.
Currently, two storm water disposal systems and one sanitary
wastewater disposal system are in operation at the Valley
Facility. The sanitary wastewater system is the same as that -
discussed above. The storm water disposal systems consist of the
one associated with the oil/gas separator manhole, as discussed in
the previous paragraph, and a new combination storm water/
compressor cooling water collection system. The latter collects
storm water from the building roof, cooling water from an air
compressor, and condensate water from the air conditioner. These
flows are routed to eventually discharge to a twelve inch
reinforced concrete drain pipe. This pipe extends from the Town
of Groveland drainage system along Washington Street easterly
across the northernmost portion of the Valley parking lot and then
discharges to a drainage swale located on the abutting Archdiocese
of Boston property, which swale extends easterly to Mill Pond.
The metal products manufacturing process conducted at the Property
involves the lathing, degreasing, and finishing of metal parts.
Cutting oils are used in the lathing operation. After use they are
recycled and reused as described above in Section I. At the
lathes, machined parts are hand-dipped in a solvent to degrease
them for inspection. Until 1983, the finished oily machined parts
were then placed in a solvent vapor degreaser. The Valley Facility
now uses a detergent type degreaser. The final process step, an
acid bath process known as "Brite-Dip," was used until sometime in
1984 to restore lustre to non-ferrous metal parts.
Hazardous wastes result from the lathing/degreasing operations
(spent halogenated solvents and waste cutting oils) and formerly
from acid bath operations (neutralized rinse water).
Trichloroethylene (TCE) was used in the vapor degreasing operation
from May 1963 to February 1979. Methylene chloride was used in the
vapor degreasing operation from June 1979 to 1983. "Solvolsol", or
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equivalent solvent, has been used in the hand dipping of products
for inspection from May 1963 to the present.
Since purchasing the Property in 1966, Valley/GRC has constructed
several additions to the original building, known as the "Old Mill
Building.* From May 1963 to October 1972, Groveland Resources
Corporation operated the manufacturing business in the
approximately 7500 square foot Old Mill Building. The Old Mill
Building had an attached 700 square foot wooden shed which was
used to store: raw TCE, Solvolsol, and cutting oils; waste
cutting oils containing TCE or other hazardous substances or
Solvolsol; and, spent halogenated solvents containing TCE or other
hazardous substances, or Solvolsol froa degreasing operations.
In 1972 and 1973, Groveland Resources Corporation constructed an
addition onto the Old Mill Building for manufacturing operations,
installed six underground storage tanks for raw cutting oils,
solvents and mineral spirits, and constructed a concrete slab over
these tanks. From 1972 to 1979, fifty-five gallon drums of waste
cutting oils and raw and spent solvents were stored on this :
concrete slab. In September 1979 a roof was constructed over the
material storage area, which had been constructed in 1972. Fifty-
five gallon drums of raw and spent solvents and waste cutting oils
had continued to be stored on the slab. See Figure 3.
The following discussion relates to the historical disposal at the
Valley Site of hazardous wastes: waste cutting oils and spent
halogenated solvents. The information contained in this
discussion is taken from the December 23, 1985 Valley/GRC response
to an EPA request for information issued in September 1985. EPA
does not purport to have validated the volume of waste discharged
on the Valley Site. The actual volume may be greater.
Between 1964 and 1972 and possibly as late as 1974, at least
twenty gallons of waste cutting oil containing trichloroethylene
(TCE) or other hazardous substances were released each month onto
the ground in the southern end of the existing building where the
truck well loading dock and the material storage area concrete
slab are presently located. Between 1964 and 1966 and possibly as
late as 1972, at least three to four fifty-five gallon drums of
waste cutting oil containing TCE or other hazardous substances
were released as a defoliant on the eastern side of the building
and in the area where the parking lot is presently located.
Between 1979 and 1984, effluent from the Brite-Dip acid bath
process containing "Low Heat Cleaner II" or "Dispoz-Aid 2", or
their equivalent, were discharged to the Brite-Dip disposal system
leachfield which is adjacent to the southeast corner of the
building. Between 1979 and 1984, the Brite-Dip acid bath process
was located inside the building in the southeast corner. In
November 1980, the Brite-Dip disposal system was installed at its
present location outside the southeast corner of the building.
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Between 1978 and 1979, the Brite-Dip process was located on an
earthen floor in the basement near the compressor room, and
wastewater from this process was discharged into the parking area.
In 1979, oil containing trichloroethylene, or other hazardous
substances, was released from a chip spinner into the truck well
floor drain and into the soil under the truck loading dock or to
the east side of the building where the leachfield for the truck
well disposal system, which was not constructed until 1980, is
presently located. Between 1972 and 1980, the truck well floor
drain was used without benefit of an oil/gas separator and
leachfield. In April 1980, the existing truck well disposal
system and leachfield were constructed. See Figure 3.
In 1973, at least 500 gallons of raw TCE was released from an
underground storage tank into the soil beneath the concrete slab
located in the south side of the building. Between 1966 and 1972,
pails of waste cutting oil from lathes were emptied onto the ground
in the areas where the truck loading dock and concrete slab are .now
located. The waste cutting oil contained Solvolsol or equivalent
solvent.
•
B. Response History
Each of the three subsurface disposal systems was initially
sampled during a joint EPA/State RCRA inspection in January and
March 1983. Analysis of samples collected from the truck well
oil/gas separator detected concentrations of trichloroethylene as
high as 44,000 micrograms per liter (ug/1 or parts per billion,
ppb) and the inorganic compounds arsenic, lead, and copper as high
as 460 ppb, 61,800 ppb and 1,380 ppb, respectively. The truck well.
disposal system was installed after the purported one-time release
from the chip-spinner discussed above in Section II.A. In
addition, analysis of samples from the Brite-Dip distribution box
detected concentrations of the inorganic compounds lead and copper
as high as 2,380 ppb and 4890 ppb, respectively.
As a result of the sampling programs and site inspections
conducted by Valley and the Massachusetts Department of
Environmental Quality Engineering (DEQE), a Consent Agreement and
Order under Massachusetts General Laws (MGL) Chapter 21C was
entered into between Valley and the DEQE Division of Water
Pollution Control (DWPC). The Consent Agreement, dated August 24,
1983, was intended to bring the plant discharges into compliance
with State and Federal Regulations and entailed submission of plans
as well as a sampling program for each disposal system. As a
result of this Consent Agreement, it was determined that the
existing Brite-Dip metal parts cleaning system would be eliminated.
This system, which included rinse water tanks, cleaner holding
tanks, and a wastewater treatment system, was disassembled and
removed in May of 1984. Incoming water supply lines to the system
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were cut and the existing floor drain plugged with a PVC cap. The
subsurface disposal system, consisting of distribution box and
leaching field, remains in place. Also, a drain in the material
storage area slab is connected to the Brite-Dip disposal system.
To eliminate the need for future sampling of the truck well
disposal system, it was agreed between Valley and the DWPC that
the existing truck loading well floor drain would be relocated to
outside the building, where storm water would be collected by a
drainage trough and conveyed to the existing oil/gas separator
manhole for final disposal into the existing leachfields, which
are located at the rear of the facility.
Tightness testing of the underground storage tanks and smoke tests
of the floor drain line from the truck loading well to the oil/gas
separator was also performed for Valley/GRC in 1983.
It was reported that no smoke was detected within the building.
[Letter dated November 23, 1983 from Lally Associates to DEQE-
DWPC]. With respect to the tank testing, it was reported that .
they were in good condition and free from any leakage of their :
contents. The only leakage reported was determined to be from the
2" couplings at the tank vents [Letter Report Re: Underground Tank
Air Testing, Water 4 Waste Pipe Testing].
The DEQE entered into a Second Consent Agreement and Order with
Valley on March 8, 1984 for performance of a remedial
investigation and feasibility study and implementation of remedial
action. On March 30, 1984 EPA issued an Administrative Order to
Valley under the authority of RCRA §3013 to conduct a remedial
investigation. The Valley RI/FS, performed in 1984 and 1985 under
those orders, was determined to be grossly inadequate and.as a
result did not provide the basis for selection of a source-control
or a management of migration remedy. An analysis of this first
RI/FS is contained in the report entitled Groveland Wells Technical
Review of Documents, February 1986, CCA Corporation Technology
Division (now known as, Alliance Technologies). At that time, GCA
also developed an endangerment assessment, which is entitled,
Valley Manufactured Products Company, Endangerment Assessment,
Final Report, Alliance Technologies Corporation, September 1987
(the EA). The EA was based on existing data on contamination of
environmental media contained in the report entitled Data
Management Task Report, Alliance Technologies, July 1987 (the Data
Management Report). Alliance also developed scopes of work for
leachability and geophysical studies. These scopes of work were
used in developing the workplan for the Supplemental RI performed
by Valley/GRC, which is discussed below.
A CERCLA §106 Administrative Order on Consent, Docket No. 1-87-
1091 (the Consent Order), was entered into with Valley/GRC on
September 4, 1987 for performance of a Supplemental RI after
substantial development and negotiation of a detailed workplan.
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The results of the first and this supplemental RI are presented in
the report entitled, Final Phase I Supplemental Remedial
Investigation Report, Docket No. 1-87-1091, Valley Manufactured
Products Co., Inc., Groveland Resources Corporation, Groveland,
Massachusetts, M. Anthony Lally Associates (the SRI). EPA
contractor Camp, Dresser & McKee provided oversight of this
activity and prepared an endangerment assessment amendment, which
is entitled, Amendment To The Valley Manufactured Products Company
Endangerment Assessment, August 1, 1988, Camp Dresser &
McKee (the EA Amendment). EPA contractor Roy F. Weston
developed a source-control feasibility study, which is entitled,
Feasibility Study For The Cleanup Of Volatile Organic Compounds,
Groveland Valley Site, Groveland, Massachusetts, September 1988,
Roy F. Weston (the FS).
In December 1986, the Valley Site was nominated for a
demonstration of the Terra-Vac, Inc. soil vapor vacuum extraction
system (VES) under the EPA Superfund Innovative Technology
Evaluation (SITE) program. The Valley Site was chosen by the SITE
Program for demonstration, and a continuous demonstration of the
VES was conducted from February through April, 1988. During this
fifty-six day demonstration, approximately 1300 pounds of VOCs were
recovered by carbon adsorption from four extraction wells outside
the material storage area.
On August 2, 1988, EPA and Valley/GRC entered into Modification
No. 1 to the Consent Order (Consent Order Modification) for the
performance of groundwater and soil vapor vacuum extraction
treatability studies, which studies are ongoing. For performance
of the soil treatability studies, Valley/GRC has contracted with
Terra-Vac, Inc. to install three vacuum extraction and one soil
gas monitoring well inside the building. Figure 6-1 depicts the
locations of these wells and the extraction and monitoring wells
installed during the SITE demonstration project and the Consent
Order Modification.
A more detailed description of the Valley Site history can be
found in the Supplemental Remedial Investigation Report at pages
1-2 to 1-14.
See Section IV below for a discussion of additional response
actions that have been executed or are planned for the Groveland
Wells NPL Site.
C. Enforcement History
On November 13, 1983, EPA notified three parties who either owned
or operated the Valley facility, generated wastes at the facility
or arranged for the disposal of wastes at the facility of their
potential liability with respect to the Groveland Wells Site.
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To date, these negotiations have resulted in the performance of
remedial investigation work and provision for reimbursement of EPA
oversight costs.
Requests for information on site use were issued to Valley/GRC in
November 1983. After conducting an investigation of site use
which included personal interviews in 1984 and 1985, EPA issued
additional information requests in September and November 1985.
The responses to these requests confirmed that disposal on the
Valley Site had occurred throughout the period of operation of the
Facility. In November 1987 and May 1988, EPA issued requests for
financial information to Valley/GRC.
The PRPs have been active in the RI/FS and remedy selection
process for this Site. Technical comments presented by PRPs
during the public comment period have been reviewed and evaluated
in developing this record of decision. A summary of their
comments and detailed responses to them is contained in the
Responsiveness Summary in Appendix A, while their complete
comments are included in Attachment C of the Responsiveness •
Summary. [Comments of Valley Manufactured Products Company, Inc.
and Groveland Resources Corporation on EPA Valley Site Proposed
Plan, September 7, 1988].
III. COMMUNITY RELATIONS
Throughout the Groveland Wells Site's history, community concern
and involvement has been substantial. EPA has kept the community
and other interested parties apprised of the Site activities
through informational public meetings, fact sheets, press releases
and public hearings.
In September 1983, EPA released the first site community relations
plan which outlined a program to address community concerns and
keep citizens informed about and involved in activities during
remedial activities. This original plan has been updated as
necessary for all subsequent remedial activities.
The Agency published a notice and brief analysis of the Proposed
Plan (the Proposed Plan) in the Haverhill Gazette on August 4,
1988 and made the Plan available to the public at the Langely-
Adams Public Library and Town Clerk's Office in Groveland at that
time.
On July 26, 1988, EPA held an informational meeting to discuss the
results of the remedial investigation and the cleanup alternatives
presented in the FS and to present the Agency's
Proposed Plan. Also during this meeting, the Agency answered
questions from the public. From August 4, 1988 to August 26,
1988, the Agency held a three week public comment period to accept
public comment on the alternatives presented in the FS and the
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Proposed Plan and on any other documents previously released to the
public and in the Administrative Record. On August 9, 1988, the
Agency held an informal public hearing to accept any oral comments.
No comments were read into the record at this
hearing. A transcript of this hearing and the Agency's response
to comments received during the public comment period are included
in Appendix A of the Responsiveness Summary.
On August 17, 1988, EPA sent Proposed Plan Clarifications to
interested parties. These clarifications are discussed in detail
below in Section VII. In consideration of the substance of these
clarifications, no extension to the public comment period was
given. However, in consideration of the ongoing Consent Order
Modification work by Valley/GRC, they were afforded the
opportunity to submit comments on the Proposed Plan up to
September 7, 1988, which comments are presented and responded to
in the Responsiveness Summary.
IV. SCOPE AND ROLE OF OPERABLE UNIT OR RESPONSE ACTION :
The Groveland Wells Site, which was included on the National
Priorities List (NPL) in December 1982, is classified as a Federal
Fund-Lead site. The Groveland Wells Site (Figure 1) consists of
approximately 850 acres within the lower Johnson Creek drainage
basin and includes the watershed and aquifer which recharge two
gravel-packed municipal supply wells, Station Nos. 1 and 2, and
three known sources of soil, surface water and groundwater
contamination: the Valley Site, the A. W. Chesterton Site and the
Haverhill Municipal Landfill Site. Station Nos. 1 and 2 were
ordered closed by the MA DEQE in June and October 1979,
respectively, due to contamination by trichloroethylene.
A multi-source groundwater response plan has been developed to
address the Groveland Wells Site contamination and includes the
following principal components, planned or executed. The Valley
Site source-control operable unit is discussed below at (6).
A potential link between contamination at the Valley and Haverhill
Landfill Sites and the contamination at Stations No. 1 and No. 2
was demonstrated through use of a numerical groundwater flow model
in EPA's 1984/1985 aquifer-wide RI/FS discussed below in (3).
Aquifer response data being collected during operation of Station
No. 1, discussed below at (1) should contribute to a better
understanding of the Groveland Wells Site contamination.
(1) Provision of alternative water supply by restoration of
municipal well station No. 1 with well-head treatment.
By Action Memorandum dated July 25, 1985 EPA approved an initial
remedial measure to provide an alternative water supply by
rehabilitating Station No. 1 with granular activated carbon
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treatment for volatile organics, based on an EPA evaluation of
water supply/demand and an aquifer-vide RI/FS. Station No. 1 was
brought into service in August 1987 and again in Nay 1988.
Station No. 1 with the granular activated carbon treatment system
now provides a safe supply of water and will be operated with
treatment until such tine as source and management of migration
actions effectively eliminate the need for that treatment. A*
Superfund State Contract currently assures State operation and
maintenance of the system until February 1991. Aquifer response
data being collected during operation of Station No. 1 should
contribute to a better understanding of the historic
contamination of it.
(2) Development of an Aquifer Protection Plan for the lower
Johnson Creek aquifer.
In 1985, the Town completed development of an aquifer protection
plan for the lower Johnson Creek aquifer. This aquifer protection
plan established aquifer recharge zones, zoning by-laws, and
recommendations -/or aquifer protection and restoration for long--
term use of Station No. 1.
(3) Operable unit for management of contaminant migration within
the Johnson Creek watershed and aquifer.
EPA performed aquifer-wide management of migration (MOM) RI/FS
work in 1984 and 1985 and will perform supplemental MOM RI/FS work
starting in 1989, in preparation of a fiscal year 1990 MOM ROD.
This supplemental MOM RI/TS will characterize the existing surface
water and groundwater contamination in the Mill Pond/Johnson Creek
watershed and aquifer and evaluate MOM remedial alternatives. It
will consider the selected source-control remedial action for the
Valley Site and the remediation of Station No. 1, and the Mill Pond
groundwater recovery and treatment system. This operable unit will
therefore provide remediation of residual contamination in the
Study Area and Mill Pond/Johnson Creek watershed and aquifer.
Based on EPA's aquifer-wide RI/FS and focused RI/FS work in the
Mill Pond area performed under the State's Water Supply
Contamination Correction Program (MGL Chapter 286), the DEQE
entered into a Consent Agreement (MGL Chapter 2IE) with Valley/
GRC to construct a groundwater recovery and treatment system at
the Mill Pond. This system was put in service on April 1, 1988.
(4) Source-control remediation at the A. W. Chesterton site.
An RI was performed by Chesterton in 1984 and 1985
pursuant to a RCRA §.3013 Administrative Order on Consent entered
into with EPA on March 30, 1984. This RI determined that the
source of contamination was a subsurface disposal system on the
Chesterton property and that soil, groundwater, and surface water
contamination was limited to the Chesterton property and appeared
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not currently connected to contamination in the Valley/Mill Pond
area or the Stations No. 1 or No. 2 area. Chesterton is a RCRA
interim status treatment, storage, and disposal facility. A
corrective action/closure plan has been submitted to EPA and DEQE.
Future plans are to execute corrective action and closure at the
Chesterton facility using RCRA authority.
(5) Source-control remediation at the Haverhill Municipal
Landfill Superfund Site.
The Haverhill Landfill was originally named as a potential source
of contamination which forced closure of Stations No. 1 and No. 2.
EPA's aquifer-vide RI/FS investigated contamination at the
landfill. The Haverhill Site, which is situated less than one
hundred feet from the Merrimack River and the Johnson Creek, was
included on the NPL in October 1984. To date, a title search has
been completed and a responsible party (RP) Search is ongoing to
establish operations history and identify generators and
transporters. Future source-control and MOM remedial action is .
planned for this site. •
(6) Operable unit for source-control organic remediation at the
Valley Site.
Source-control remediation at the Valley Site is the subject
of this ROD. Further discussion of the Valley Site history is
provided above in Section II.
This remedial action addresses organic compounds in the two
principal contaminated media of subsurface soil and groundwater.
Based on the concentrations of volatile organic compounds detected
in these media, and information related to historical site use,
both media are contributing to groundwater and surface water
contamination in the Study Area and Mill Pond/Johnson Creek
watershed and aquifer.
By implementing soil and groundwater organics remediation at the
Valley Site, contamination of groundwater will be reduced and
minimized. Migration of contaminated groundwater which eventually
discharges to Mill Pond and Johnson Creek, thereby contaminating
those water bodies, will likewise be reduced and minimized.
The subsequent management of migration (MOM) remedial action
described above in (3) will address residual/existing
contamination in the Mill Pond/Johnson Creek watershed and
aquifer. This MOM remedial action will be governed by existing
drinking water standards for groundwater and ambient water quality
criteria for surface water, which are applicable or relevant and
appropriate requirements at the Groveland Site.
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This source-control remedial action primarily addresses volatile
organic soil and groundwater contamination. Incidental treatment
of inorganic compounds and other parameter*, as necessary, is
provided as part of the groundvater treatment for volatile organic
compounds. This is necessary in order to efficiently operate the
selected air stripping/carbon adsorption treatment system and to
meet the applicable requirements of the Massachusetts Ground Water
Discharge Permit Program (314 CKR §5.00). As discussed below in
Section V.D, the aquifer underlying and downgradient of the Valley
Site is a Class I under the State classification system (314 CMR
§6.03). Discharges to a Class I aquifer are required to meet
primary and secondary effluent limitations established in 314'CMR
§5.10.
CERCIA remedial actions, at a minimum, must attain applicable or
relevant and appropriate requirements of federal and state
environmental statutes (ARARs) and be protective of human health
and the environment. It can be anticipated that remediation at
the Valley Site under CERCIA will require cleanup of groundwater
for all organic and inorganic contaminants to attain chemical- ;
specific ARARs including: the Maximum Contaminant Levels (MCLs)
established under the Safe Drinking Hater Act (SDWA); the
Massachusetts Ground Water Quality Standards established in 314
CMR §6.00; and, the RCRA Ground Water Protection Standards
established in 40 CFR Part 264.92 to the extent that they are more
stringent.
Table VI-4 lists the applicable or relevant and appropriate ground
water quality and discharge standards for groundwater treatment for
the inorganic contaminants of concern and secondary effluent
parameters.
At the time of the CERCLA five year statutory review or at such
time as the remedy has achieved the cleanup goals for the volatile
organic contamination, or at some earlier time, EPA will evaluate
whether the inorganic standards established under 314 CMR §6.00,
the SDWA and RCRA, which are presented in Table VI-4, and general
standards of protectiveness have been attained or are attainable.
A determination as to whether such standards are attainable will
consider the background or ambient concentration and residual soil
contamination of these compounds at the Valley Site. If these
standards are attainable, but have not been attained at that time,
a determination as to whether continued groundwater treatment or
soil remediation for inorganic contamination is necessary will be
made in a supplemental decision document to this ROD. Such
selection of continued groundwater treatment and soil remediation
will be based on statutory criteria and consideration of the nature
and extent of residual saturated and unsaturated soil
contamination, and the nature and extent of residual contamination
in the subsurface disposal systems and underground storage tank
area.
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V. SITE CHARACTERISTICS
The significant findings of the remedial investigations are
summarized below. A complete detailed discussion of site
characteristics is contained in the RI and SRI Reports.
A. Morphology
Topographically, the Valley-Mill Pond area (the Study Area) is
characterized by irregular terrain of small hills and -narrow
ridges separated by low lying areas. Elevation in the Valley-
Mill Pond area ranges from a high of elevation 150 west of
Washington Street, to a low of elevation 33 in the Mill Pond area.
The topography of the area is a reflection of the underlying land
forms which are glacial in origin. All drainage within the Study
Area ultimately reaches the Johnson Creek, the Mill Pond, and the
Merrimack River via Johnson Creek.
B. Hydroqeolocfic Setting :
1. Surface Water Hydrology
The Valley Site is located within the Johnson Creek drainage
basin. Johnson Creek is a tributary to the Merrimack River. The
Johnson Creek drainage basin, above Mill Pond, covers an area of
approximately 6.4 square miles. The major surface water bodies
within the drainage basin are Hovey's Pond and Johnson's Pond
located to the south of the Study Area. Johnson Creek, the
predominant stream in the area, originates south of the Groveland
Wells Site and flows in a northerly direction to Mill Pond,
located approximately 450 feet east of the Valley Site. Based on
the runoff rate to Johnson's Pond obtained from the United States
Department of Agriculture Inventory of Potential and Existing
Reservoir Sites. Merrimack Study Area, March 1970, it was
calculated that peak runoff to Mill Pond in a 100 year storm would
equal approximately 1,700 cubic feet per second.
A control structure at the northernmost end of Mill Pond regulates
the level of the pond and downstream flows. Excess waters from
Mill Pond are released over the control structure and flow in a
northerly direction approximately 3,700 feet to the Merrimack
River. Downstream of Mill Pond two tributaries to Johnson Creek,
Haverhill Brook and Agrilla Brook, discharge to Johnson Creek,
increasing the Creek's discharge rate to the Merrimack River.
2. Geology
The Study Area is underlain by glacial materials deposited during
the passage of ice sheets of the Pleistocene Epoch. A till
drumlin lies just to the west of the Valley Site, and to the east
is the Johnson Creek stream valley. Overburden materials indicate
that a transition from glaciofluvial (ice contact
and outwash) deposits to till underlie the site. The thickness of
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unconsolidated deposits under the site is on the order of thirty-
two to fifty feet.
A dense basal or lodgement till, composed of dense, unsorted
and unstratified silty sands and some gravel, ranges from two to
five feet thick over the bedrock at the site. A compacted outwash
•and and gravel strata of eight to ten foot thickness overlies this
basal till. An ablation till, which is coarser grained than the
lodgement till, ranges from four to eight feet thick above the
outwash. This till is overlain by a layer of medium to fine sands
and gravel located at or near the surface north and east of the
site.
A thin irregular clay layer two to ten feet thick lying at a depth
of six to twelve feet below the ground surface was found primarily
under the southern end of the Valley Site overlying the outwash
sand.
Bedrock beneath the Valley Site has been described as the
Merrimack Quartzite Formation. The bedrock has a schistose
texture and is composed of mostly fine grained phyllites and mica
shist. The depth of bedrock ranges from thirty-two to fifty feet
within the Study Area. The upper five to ten feet is composed of
soft phyllite. The phyllite is gneissic with the foliation
dipping between 30* and 50*. Joints for the most part are
parallel to the foliation but occasional vertical and horizontal
joints were also observed. The bedrock becomes quartzitic with
depth but maintains similar structural attitudes. The bedrock
surface dips to the south toward Center Street and to the east
toward Johnson Creek valley.
3.Hvdroqeoloav
The aquifer in the Study Area is a relatively thin phreatic
aquifer which occurs in the overburden soils and shallow weathered
bedrock. The depth to the water table is twenty-five to thirty
feet below the ground surface. The aquifer materials are granular
soils of glacial origin which fill a relatively narrow north/south
winding valley. The valley is bounded on the east and west by
glacial till/bedrock controlled uplands which are less pervious
than the granular valley deposits. The unconsolidated materials
overlie bedrock at thicknesses of up to fifty feet at the
Valley Site.
C. Environmental Contamination
All data presented and discussed below appear in the Supplemental
RI Report, unless otherwise noted.
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1. Air
It was concluded in the SRI that "air contaminant concentrations
detected in this area are generally low with no known health
impacts at this level and are probably due to oils and greases
being used within the machining equipment and not chemical
contamination existing on the site." The SRI indicates the total
level of organic vapors detected on site with an HNu was 3 parts
per million (ppm) outside the machining area of the building.
2. Soil
Based on laboratory analysis of subsurface soil samples the
most significant soil contamination, ranging in concentration from
10 ug/g (micrograms per gram, parts per million or ppm) to 2552
ug/g total volatile organic compounds (VOCs), has been found in the
southernmost portion of the Valley Site, beneath and outside of the
material storage area of the existing building. See Figure 7. The
highest concentration of contaminants, 2552 ug/g total VOCs, was
detected in subsurface soils within ten feet of the solvent
storage tank. Concentrations of soil contamination generally
decreased away from this area. ;
In addition, analysis of subsurface soil gas samples collected
from an area under the building detected soil gas concentrations
of VOCs as high as 1300 ppm, indicating that additional subsurface
soil contamination may exist under this area of the building,, which
was constructed in 1974. See Figure 7.
The primary contaminants detected in these soils were
trichloroethylene (TCE) and methylene chloride (M/C). Both
compounds were historically used as degreasing agents within the
Valley Facility. TCE, the major contaminant at the Valley Site,
was used in the facility up to 1979. At that time, the use of TCE
was discontinued and M/C was substituted as the degreasing agent.
The use of M/C was discontinued in July 1983, and a detergent type
degreaser is currently being used in the degreasing operation.
In addition to TCE and M/C, lesser concentrations of 1,2-trans-
dichloroethylene (DCE) ranging from below detection limits or non-
detectable (ND) to 12 ug/g, 1,1,1-trichloroethane (TCA) ranging
from ND to 1.4 ug/g, and tetrachloroethylene (PCE) ranging from ND
to 40 ug/g were detected in subsurface soil samples. These
compounds were not known to be used at the Valley Facility in the
past and their presence in soil may be a result of biodegradation
of TCE and M/C or these compounds may have been present as
contaminants in the TCE and M/C used at the Valley Facility.
Based on information submitted by Valley/GRC in response to
an EPA request for information in September 1985, it is
believed that no less than 3000 gallons of waste oil and
solvent were historically released on the Valley Site. Five to
seven hundred gallons of TCE came from a storage tank leak and the
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balance from indiscriminate disposal. EPA had previously issued
two information requests, responses to which did not contain this
information.
Volatile organic soil contamination is generally contained within
soils above the clay lense. These soils generally consist of
coarse sands and gravel. The contamination begins just beloti land
surface and extends down to the top of the clay lense, which
occurs at an average depth of ten to fifteen feet. Below the clay
lense contamination levels are generally less than 100 ppm. It
appears that contamination is largely trapped above the clay layer
or is being attenuated within the clay layer. However,
installation of monitoring wells through this clay lense generally
compromises its' integrity.
Although soils in the Brite-Dip and truck well disposal system
leachfields have not been sampled and analyzed to date, these
leachfields are expected to be sources of residual organic and
inorganic contamination based on the historic release of hazardous
wastes to them and the detection of contaminants in the oil/gas•
separator and distribution box in 1983. This data is discussed
above in Section II.B.
3. Surface water/sediment
Analysis of surface water samples near the southern shore of the
Mill Pond, downstream of the Valley Site, detected concentrations
as high as 760 micrograms per liter (ug/1, parts per billion, or
ppb) DCE, 3400 ppb TCA, and 3200 ppb TCE. Chromium was also
detected in surface water at this location at concentrations as
high as 11 ppb (Data Management Report, Alliance, July 1987).
Analysis of sediment samples near the southern shore of Mill Pond,
downgradient of the Valley Site, detected concentrations as high
as 4390 milligrams per kilogram (mg/kg, parts per million, or ppm)
aluminum, 7 ppm arsenic, 12 ppm barium, 10 ppm chromium, and lead
65 ppm (Data Management Report, Alliance, July 1987).
4. Groundwater
Monitoring wells have been installed at twenty-six locations
in the Study Area. Three of these locations, which are on the
Archdiocese of Boston property to the east, consist of nested
bedrock and overburden wells. Six groundwater monitoring wells
are located within the Valley building. See Figure 6. Recently,
VOC concentrations as high as 150,000 ug/1 TCE and 7900 ug/1 DCE
have been detected within the Study Area and adjacent to the
Property and concentrations of 150,000 ug/1 TCE, 23,000 ug/1 DCE,
1100 ug/1 TCA and 520 ug/1 TCA have been detected under the
material storage slab.
Based on data collected on the Valley Site to date, the main
source of the groundwater contamination is the presence of
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residual organic compounds in the unsaturated soil beneath and
outside of the material storage area. This contamination is*
likely due to the past storage and release of raw materials and
hazardous waste in this area and the leak from the underground
solvent storage tank. Prior to construction of the material
storage area in 1980, spent cutting oils and solvents used at the
facility were stored in fifty-five gallon drums on the ground and'
later on an open concrete slab. Since 1972, unused cutting oils
and solvents have been stored in underground tanks in the same
area. If these storage tanks leak, leachate would percolate
downward through the soil matrix to the water table.
Construction of the existing material storage area enclosure in
1980 largely sealed the area from infiltration of precipitation.
Prior to this, precipitation would runoff the material storage
area and percolate downward through the soil matrix to the water
table.
Inorganic compounds at levels above maximum contaminant levels
(MCLs) were detected under the storage slab in July 1986:
arsenic, 230 ug/1; chromium, 70 ug/1; copper, 1100 ug/1; and,
lead, 130 ug/1. Samples collected adjacent to the Property on the
east exhibited lower levels of these compounds. In samples
collected in July 1988, inorganic compounds levels for the same
wells had maximum detected concentrations of: arsenic, 10 ug/1;
chromium, <20 ug/1; and, lead, 80 ug/1 [Letter Report dated
August 23, 1988, Lally Associates]. Although cadmium and copper
were not detected in this analysis, the reported analytical
detection limits for these compounds was greater than the MCL.
The presence of elevated concentrations of inorganics may be
attributed to cutting oils in soil and groundwater. In 1986 and
early 1988, groundwater samples collected from under the material
storage area exhibited a phase separation of oil, which was not
observed in the July 1988 sampling. This oil phase was analyzed
and determined to be primarily composed of kerosene or light
petroleum fraction and a weathered #2 fuel oil or middle petroleum
distillate [Laboratory Data Report, Lawrence Experiment Station
(LES), analysis date 3/22/88 and Laboratory Memorandum, LES, dated
July 31, 1985].
D. Groundwater Classification and Use
The surficial aquifer beneath and downgradient of the Valley Site
is classified as a Class I by the Commonwealth of Massachusetts
(314 CMR §6.03), which is groundwater designated as a source of
potable water supply.
Under the EPA Groundwater Classification System [EPA Groundwater
Protection Strategy (GWPS), Office of Groundwater Protection,
August 1984], this aquifer is classified as a Class II. The
policy under the GWPS establishes groundwater protection goals
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based on the "highest beneficial uses to which groundwater having
significant water resources value can presently or potentially be
put." Guidelines for protection of aquifers are based on
characteristics of vulnerability, use, and value. The aquifer
beneath and downgradient of the Valley Site is considered to be a
current drinking water source since groundwater is used for
drinking within a two-Bile radius of the site (the classification
review area).
Although there are presently no private/public users of this
aquifer within 1/2 Bile of the Valley Site, Groveland's municipal
water supply well. Station No. 1, is developed in the highly
productive surficial aquifer within the lower Johnson Creek
drainage basin, approximately 3500 feet northeast and downgradient
of the Valley Site. As discussed above in Section IV(l), Station
No. 1 is currently being used as a public water supply. This
supply is being treated with a granular activated carbon treatment
system constructed by EPA as an initial remedial measure, to remove
vocs.
See Sections VI.D and X.B below for a discussion of target
groundwater cleanup levels and the rationale for their selection.
VI. SUMMARY OF SITE RISKS
Endangerment assessments were performed for the Study Area to
estimate the probability and magnitude of potential adverse human
health and environmental effects from exposure to contaminants
associated with the Valley Site. The significant findings of the
endangerment assessments are summarized below. A complete
discussion of the selection of contaminants of concern and human
health risks can be found in the EA (Alliance, 1987) and the EA
Amendment (CON, 1988). A complete discussion of environmental
exposure can be found in the EA (Alliance, 1987).
A. Contaminants of Concern
The EA was developed by Alliance Technologies based on
environmental sampling and analysis performed for the Valley RI
between 1984 and 1986. Alliance selected eight volatile organic
compounds as contaminants of concern. The EA Amendment was
performed by Camp Dresser & McKee (COM) based on the results of
additional sampling and analysis performed by Valley in 1986 and
as part of the Supplemental RI performed by Valley in 1988. Based
on this additional contaminant characterization, COM selected six
inorganic compounds to add to the list of contaminants of concern.
The organic and-inorganic contaminants of concern and their
distribution in environmental media in the Study Area are listed
in Table VI-1. These contaminants constitute a representative
subset of the more than fifty volatile and semi-volatile organic,
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and inorganic contaminants identified during the remedial
investigations. The fourteen contaminants of concern were
selected to represent potential onsite hazards based on toxicity,
concentration, mobility, and persistence in the environment.
Of the fourteen contaminants of concern, six are either known or
suspected carcinogens.
VOCs constituted the majority of contaminants detected at the
Valley Site, with TCE being the most abundant. TCE was detected
at the greatest concentration of all contaminants: in soils at a
concentration of 2,500 ppm and in groundwater at a concentration
of 150 ppm. A summary of sample analysis data is contained in the
Data Management Report, Alliance Technologies, July, 1987 and in
the Supplemental Remedial Investigation Report, M. A. Lally
Associates, July, 1988.
B. Human Health Risk Assessment
Potential human health risks associated with the contaminants
of concern in soils, groundwater, surface water, and air were -
estimated through the development of several hypothetical exposure
scenarios. Incremental lifetime cancer risks and a measure of the
potential for noncarcinogenic adverse health effects were
estimated. Exposure scenarios were developed to reflect the
potential for exposure to hazardous substances based on
characteristic uses and the location of the Valley Site. Two
major potential receptor populations were identified. These
include employees at the Valley Facility and the residential
population in close proximity to the Valley Site. For each of
these populations, risks posed by relevant exposure pathways were
evaluated.
The following list represents potential human exposure pathways
within the Study Area:
* direct contact with soils;
• ingestion of soils;
* ingestion of groundwater;
* ingestion of surface water; and
direct contact with surface water.
A dose-response assessment was performed for each contaminant of
concern to determine the nature and severity of actual or
potential adverse health effects associated with the above
exposure pathways. The toxic effects associated with the
contaminants identified at the Valley Site range from headaches
and minor skin irritation to liver, kidney, respiratory, and
central nervous system damage, and cancer.
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The greatest potential rick identified for the Valley Site ip
attributed to the ingestion of contaminated groundwater. At
present, groundvater in the general area of the Valley Site is not
known to be consulted, owing to the availability of the public
water supply. Thus the risks estimated for the ingestion of
groundwater correspond to possible future risks if groundvater was
consumed. Groundwater is currently being withdrawn for Municipal
supply approximately 3500 feet northeast of the site from
Groveland's Station Mo. 1.
The upper bound of the carcinogenic risk estimates posed by
ingestion of the six carcinogenic contaminants of concern in
groundwater ranged from 8xlO-3 to 6xlO-2 for average and maximum
concentrations, respectively. Trichloroethylene and arsenic were
the two contaminants that contributed most significantly to these
risk levels. Mean concentrations of three of the six carcinogens
also exceeded the current maximum contaminant levels (MCLs)
'promulgated under the Safe Drinking Water Act.
The noncarcinogenic health risks posed by contaminants at the
Valley Site were also evaluated. Groundwater concentrations were
evaluated against available reference doses (RfD) or other
suitable health based criteria. The hazard index is used to
describe the ratio between the chronic daily intake (CD!) and the
RfD and is a measure of the potential for noncarcinogenic health
effects. The hazard index exceeded unity for trans-1,2
dichloroethylene and lead under the average and reasonable worst
case exposures scenario. Hazard indices for methylene chloride
and toluene exceeded unity only for the reasonable worst case
exposure scenario. EPA considers a hazard index less than unity
acceptable for noncarcinogenic compounds. As a result of the
carcinogenic and noncarcinogenic risk evaluation, groundwater at
the site is deemed unsuitable for human consumption. That is, the
incremental lifetime cancer risk exceeds the target risk range of
10~4 to 10~7 and noncarcinogenic health effects are of concern.
For the assessment of possible risks posed by dermal contact and
ingestion of contaminated soils, subsurface soil contamination
data was used, as surface soils were relatively clean. The
resulting risk estimate may thus overestimate current risks but
was selected to characterize future risks resulting from possible
future site use. Two populations, workers and small children,
vere identified as having the greatest potential for exposure
based on likely behavior patterns. Possible risks under the
reasonable worst-case exposure scenario for each of these
populations, was found to be within the acceptable CERCIA target
risk range of 10~4 to 10*7. Since the contamination in soils
resided at a depth of 4 to 25 feet below the surface, and since
the risks fell within EPA's target risk range, the soil exposure
pathways were not considered a significant health risk.
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Similarly, risks to children resulting from the direct contact
with or the ingestion of surface water from Mill Pond were not
associated with a significant public health risk.
Table VI-2 presents a summary of potential risks by exposure
pathway.
C. Environmental Exposure
Subsurface soils at the Valley Site are contaminated with volatile
organic and inorganic compounds which result in groundwater
contamination on-site. This groundwater migrates from the Valley
Site, continually contaminating the Johnson Creek aquifer and the
Mill Pond/ Johnson Creek surface waters, sediments and biota
through groundwater discharge.
D. Cleanup Goals/Area of Attainment
Based upon a review of the applicable or relevant and appro-
priate criteria, standards and requirements of state and federal
environmental laws and the associated risk levels, EPA has
established groundwater and corresponding soil cleanup goals for
the respective volatile organic contaminants of concern. This
section presents the cleanup goals and the residual site risks
associated with these target levels. A detailed discussion of the
basis for selection of the cleanup goals is presented below
in Section X.B. These contaminant-specific cleanup goals are
presented in Table VI-3.
For the carcinogenic contaminants of concern the groundwater
cleanup goals are based on maximum contaminant levels (MCLs) or,
in their absence, on an excess cancer risk level of 10~6. MCLs
are considered relevant and appropriate in the cleanup of this
aquifer as they are drinking water standards.
The cumulative cancer risk level posed by these contaminants in
groundwater at their target cleanup levels is 2.6xlO~4< Most of
this risk can be attributed to vinyl chloride and 1,1
dichloroethylene. Since both of these compounds have relatively
high vapor pressures and Henry's Law constants, they are expected
to be very conducive to removal from soil by vacuum extraction and
from groundwater by aeration. In achieving the target levels for
the other VOCs, these compounds are anticipated to be removed to
below detection levels, thus resulting in a residual risk less
than 2.6xl(T4.
For the noncarcinogenic contaminants of concern the cleanup goals
for groundwater were also based on drinking water standards
(MCLs/MCLGs). Each of these contaminants at their target cleanup
level does not exceed a hazard index of 1 nor do the hazard
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indices of compounds with similar target endpoints add up to a
value greater than 1.
Groundvater cleanup goals shall be achieved everywhere on the
Valley Site at every point in the aquifer. This is based on the
aquifer classification as a current or potential drinking water
supply.
Soil cleanup goals are to be achieved everywhere on the Valley
Site unless it is determined that a contaminant level in soil has
been achieved that is not contributing to groundwater
contamination above cleanup goals.
Soil cleanup goals have been set for volatile organic compounds in
order to prevent the leaching of contamination from the soil into
groundwater. Target level concentrations in soil were based on the
application of the soil/water equilibrium calculation presented in
Section 2.0 of the Feasibility Study.
As discussed above in Section IV(6), the selected remedial action
will also attain, with respect to inorganic contamination, the
applicable or relevant and appropriate requirements of the:
Massachusetts Ground Water Quality Standards (314 CKR §6.00) and
Ground Water Discharge Permit Program (314 CKR §5,00), Safe
Drinking Water Act, and RCRA groundwater protection standards (40
CFR Part 264.92). A determination as to whether these
requirements and other general standards of protectiveness have
been met will be made at the five-year statutory review, at
completion of the selected remedy or at some earlier time. These
applicable or relevant and appropriate standards, criteria and
limitations are presented in Table VI-4.
VTI. DOCUMENTATION OF SIGNIFICANT CHANGES
EPA published a Proposed Plan (soil vapor vacuum extraction/high-
rate groundwater treatment) for remediation of the Valley Site on
July 20, 1988. The Proposed Plan also summarized the
contamination detected in the RI and established the general
remedial action objectives and cleanup goals for the Valley Site
contamination. The preferred alternative presented in the
Proposed Plan included soil vapor vacuum extraction (VES) and a
high-rate of groundwater extraction and treatment with aeration
and carbon adsorption for volatile organics remediation.
Pretreatment of groundwater for inorganics was also presented in
the preferred alternative. The FS, which was released to the
public on August 4, 1988, thus starting the formal 21-day public
comment period, presented contaminant-specific target groundwater
cleanup levels and corresponding residual target soil cleanup
levels, and evaluated remedial alternatives for volatile organics
contamination in soil and groundwater.
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In an August 17, 1988 letter to the PRPs, the Town of Groveland
and other interested parties, EPA clarified certain aspects of the
Proposed Plan. This letter:
• corrected certain tables in the FS relating to organic
contamination in soil and groundvater;
• proposed certain cleanup levels for inorganics in
groundwater; and,
• clarified that EPA's preferred alternative included
removal or decontamination of septic disposal systems;
further evaluation of the release of hazardous
substances from the storage tanks; a determination of the
extent of inorganic contamination and an evaluation of
in-situ treatment alternatives regarding inorganic
contamination.
The remedy selected in this ROD contains all elements of the
alternative presented in the July 20, 1988 Proposed Plan. -It
does not formally select the inorganic remedy; rather it
adopts the inorganic cleanup goals proposed in the August 17,
1988 clarification as a benchmark to determine whether the
inorganic treatment originally presented in the Proposed Plan
as an integral part of the organic groundwater remedy will
incidentally attain a level of inorganic cleanup that attains
ARARs and is protective of human health and the environment.
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TABLE VI-3
VALLEY SITE SOURCE-CONTROL
CONTAMINANT-SPECIFIC CLEANUP GOALS
COMPOUND
CONCENTRATION
CROUNDWATER fifiIL(5)
(ug/1) (ug/kg)
(parts per billion)
BASIS.
Carcinogens—
trichloroethylene
vinyl chloride
methylene chloride
tetrachloroethylene
1,1 dichloroethylene
JOTAL
5
2
5
5
7
6.3
1.14
0.44
18.2
4.6
MCL(l)
MCL(l)
10~6(2)
(3)
MCL(l)
CARCINOGENIC
RISK LEVELf6}
1.6X10"6
1.3X10'4
1.0X10'6
'.3X10"6
2.6X10
-4
Noncarcinogens--
trans 1,2 dichloroethylene 70 41.3 MCLG(4)
toluene 2000 6000.0 MCLG(4)
1/1,1 trichloroethane 200 302.0 MCL(l)
NONCARCINOGENIC
HAZARD INDEX(61
0.2
0.2
0.07
Notes:
MCL - Maximum Contaminant Level, Safe Drinking Water
Act Amendments, 1986.
In the absence of any promulgated drinking water
standard, the target level is based on 10~6 excess
cancer risk level.
Based on the similarities in structure, potency and
toxicity between PCE and TCE, the MCL for TCE was the
basis for the level for PCE.
MCLG - Maximum Contaminant Level Goal (Proposed in the
Federal Register, November 13, 1985).
Maximum soil concentration when in equilibrium with
the groundwater target level. See Section X.B.
Incremental carcinogenic risk level and
noncarcinogenic hazard index for groundwater.
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TABLE VI-4
VALLEY SITE SOURCE-CONTROL REMEDIATION
GROUND WATER QUALITY STANDARDS
AND DISCHARGE STANDARDS
COMPOUND CONCENTRATION BASIS
(ng/1)
arsenic 0.05 (1), (2)
chromium 0.05 (1), (2)
cadmium 0.01 (1), (2)
lead 0.05 (1), (2)
copper 1.0 (1), (3)
zinc 5.0 (1), (3)
mercury 0.002 (1), (2)
oil and grease 15.0 (1), (3)
iron 0.3 (1), (3)
Notes: 1. Ground Water Quality Standards, 314 CMR §6.06
(12/31/86) are applicable to Class I aquifers.
2. Primary effluent limitations for Class I and Class
II ground waters,.314 CMR §5.10(3)(a) (12/31/86)
are applicable to ground water discharges.
3. Secondary effluent limitations for Class I and
Class II ground waters, 314 CMR §5.10(3)(b)
(12/31/86) are applicable to ground water
discharges.
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Th« remedy selected in this ROD does not address removal or
decontamination of the septic disposal systems or the immediate
evaluation of in-situ inorganic treatment alternatives. The
inorganic remedy for the site, if any, will be formally selected in
a subsequent decision document.
The remedy selected does not contain any significant changes from
the Proposed Plan. All interested parties have been given adequate
opportunity to comment on EPA's proposed remedy.
VIII. DEVELOPMENT AND SCREENING OF ALTERNATIVES
A. Statutory Requirements/Response Objectives
Prior to the passage of the Superfund Amendments and
Reauthorization 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
hazardous substances, pollutants and contaminants shall 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
Superfund sites is to undertake remedial actions that are
protective of human health and the environment. In addition,
Section 121 of CERCLA establishes several other statutory
requirements and preferences, 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
warranted and justified in a ROD; 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 permanently and sig-
nificantly reduce the volume, toxicity or mobility of hazardous
wastes over remedies that do not achieve such results through
treatment. Response alternatives were developed to be consistent
with these Congressional mandates.
A number of potential exposure pathways were analyzed for risk and
threats to human 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,
remedial response objectives were developed to mitigate existing
and future threats to human health and the environment. These
response objectives for organic and inorganic contaminants are to:
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(1) Prevent ingestion of groundwater contaminated in excess of
relevant and appropriate drinking water standards (MCLs/MCLGs)
or, in their absence, an excess cancer risk level of 10~6,
for each carcinogenic compound. Also, to prevent ingestion of
groundwater contaminated in excess of a total excess cancer
risk level for all carcinogenic compounds of 10~4 to 10""';
(2) Prevent ingestion of groundwater contaminated in excess of
relevant and appropriate drinking water standards for each
noncarcinogenic compound and a total Hazard Index greater than
unity (1) for all noncarcinogenic compounds;
(3) Prevent migration of contaminants in soils and groundwater
that would result in groundwater contamination in excess of
relevant and appropriate drinking water standards and surface
water contamination in excess of relevant and appropriate
ambient water quality criteria for the protection of aquatic
life; and,
(4) Remediate inorganic contamination to the extent that such •
remediation is incidental to organics remediation, and to
evaluate attainment of the applicable or relevant and
appropriate requirements of Federal and State environmental
regulations.
The groundwater and soil cleanup goals to achieve objectives (1),
(2) and (3) are presented above in Section VI and below in Section
VIII.C. The applicable or relevant and appropriate standards,
criteria and limitations to achieve objective (4) are presented
above in Section VI and below in Section XI.B.
B. Technology and Alternative Development and Screening
CERCLA, the NCP, and EPA guidance documents including, "Guidance
on Feasibility Studies Under CERCLA" dated June 1985, 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) set forth the process by which
remedial actions are evaluated and selected. In accordance with
these requirements and guidance documents, treatment alternatives
were developed for the site ranging from an alternative that, to
the degree possible, would eliminate the need for long-term
management (including monitoring) at the site to alternatives
involving treatment that would reduce the mobility, toxicity, or
volume of the hazardous substances as their principal element. In
addition to the range of treatment alternatives, a containment
option involving little or no treatment and a no-action
alternative were developed in accordance with Section 121 of
CERCLA.
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Section 121(b)(l) of CERCIA 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 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. Cost.
7. Overall Protection of Human Health and the Environment.
8. Community Acceptance.
9. State Acceptance.
In the Feasibility Study, Section 2, general response actions were
identified (Table VIII-1) to achieve the remedial action
objectives presented above in Section VIZI.A. See Appendix E for
Tables VIII-1 through VIII-14. Subsequently, in the FS Section 2,
remedial action technology types and process options for potential
volatile organic treatment technologies and their associated
containment or disposal requirements were identified and screened
for suitability as part of source-control remedial alternatives for
soil (Table VIII-3) and groundvater (Table VIII-2). These
technology types and process options were then combined in the FS
Section 3 to develop media-specific alternatives involving
treatment, containment and no-action (Tables VIII-4 and VIII-5).
In the FS, Section 3, the four groundwater alternatives and eight
soil alternatives presented in Tables VIII-4 and VIII-5 were
developed and screened against effectiveness, implementability and
cost. The purpose of the initial screening was to narrow the
number of alternatives for further analysis while preserving a
range of options (Tables VIII-6 and VII1-7).
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After this initial screening, the groundvater and soil alternatives
were combined into comprehensive source-control remedial
alternatives addressing both soil and groundwater. The treatment
alternatives developed ranged from alternatives that would
eliminate the need for long-term management to alternatives
involving treatment that would permanently reduce toxicity,
mobility or volume as their principal element.
In summary, from the four groundwater and eight soil alternatives
presented in the FS, Section 3.3, six comprehensive source-
control alternatives were developed and retained for detailed
analysis in Section 4.
These six comprehensive source-control alternatives for volatile
organics remediation are presented in Table VIII-B. The evaluation
of these six alternatives with respect to the first seven factors
listed above is presented in Tables VIII-9 through VIII-14.
C. Cleanup Goals
Cleanup goals for soil and groundwater at the Valley Site have
been established for volatile organic compounds based upon the
baseline risk assessment, (Section VI), the groundwater
classification (Section V.D) and an analysis of applicable or
relevant and appropriate requirements of Federal and State
environmental regulations. These cleanup goals are presented above
in Table VI-3. A discussion of the rationale for selection of the
groundwater and soil cleanup goals and the point of compliance for
remedial action is presented below at Section X.B.
Each alternative presented in the detailed analyses of the FS was
evaluated for its capability in achieving the contaminant-specific
cleanup levels.
IX. DESCRIPTION/SUMMARY OF THE DETAILED AND COMPARATIVE
ANALYSIS OF SOURCE-CONTROL ALTERNATIVES
This section presents a narrative summary and brief evaluation of
each alternative according to the evaluation criteria described
above. A detailed tabular assessment of each alternative can be
found in Table 4-7 of the Feasibility Study and Table IX-1 below.
The source-control alternatives analyzed for the Valley Site
include a minimal no action alternative (SC-1); in-situ soil
treatment alternatives (SC-2, SC-3); onsite above ground soil
treatment alternatives (SC-4, SC-5); and, an offsite soil
treatment/disposal alternative (SC-6). Alternatives SC-2, SC-4
and SC-6 also include a high-rate (10 years) groundwater treatment
system, while alternatives SC-3 and SC-5 include a low-rate (>30
years) groundwater treatment system. These alternatives are
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described briefly below with approximate capital and present worth
of operation and maintenance cost*.
8C-1
HO Action
The no action alternative for the Valley Site would not involve
any treatment or disposal of contaminated soil or groundwater.
Instead, additional fencing would be erected and warning signs
would be posted around the Valley property to prevent direct
contact with contaminated soil. Deed restrictions also would be
placed on the Property to restrict future property development and
groundwater use. Additional groundwater monitoring wells would be
installed to permit sampling of groundwater in the overburden and
bedrock, both upgradient and downgradient of the Valley Site.
Groundwater samples would be collected from selected wells on- and
off-site every three months until it was demonstrated that the site
no longer presented a threat to human health and the environment.
Because this alternative would not involve disturbing the
contaminated soil, other than to construct the fence, it provides
short-term effectiveness in protecting public health during
implementation. However, this alternative would require ongoing
surveillance and maintenance to ensure long-term effectiveness.
Institutional controls such as fencing and deed restrictions are
not considered reliable or effective at reducing/eliminating risks
from groundwater ingestion and dermal contact with or ingestion of
soils in the long-term. This alternative would not reduce the
toxicity, mobility, or volume of the contaminants, nor would it
comply with ARARs.
Estimated Time for construction and Operation: > 30 years
Estimated Capital Cost: $76,000
Estimated Operation and Maintenance Cost: $630,000
SC-2
Vacuum Extraction/High Rate Groundwater Treatment
This alternative is the selected remedial alternative for volatile
organic* remediation and is described below as presented in the FS.
This remedy is further described in Section X.A, Selected Remedy.
Extraction
The soil vapor vacuum extraction system (VES) is an alternative
in-situ soil treatment technology utilizing vadose (unsaturated)
zone extraction wells, vacuum pumps, associated piping and vapor
treatment. With the VES process, a subsurface vacuum is developed
in order to indtSce air and contaminant flow through the soil matrix
to the extraction wells, where contaminated vapor is withdrawn.
Volatile organic contaminants are essentially air-stripped from the
soils due to the mass transfer of contaminants to the soil vapor.
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This facilitates soil treatment in-situ,or without excavation.
Moisture is removed from the contaminated soil vapor in a condenser
or separator. Vapors are then drawn through activated carbon beds
where volatile organic contaminants are adsorbed before discharging
the clean air to the atmosphere. The separated water will be
treated on-site via carbon adsorption and then discharged to the
ground downgradient of the site. To measure the effectiveness of
the vacuum extraction system, monitoring of wellhead and process
gases and emissions would be conducted throughout the period of
operation. See Figure 9 and 10.
This remedy is expected to require relatively little time to
implement as fourteen extraction wells at seven locations, each
consisting of one shallow well screened above the clay strata and
one deep well screened below the clay strata, have already been
installed and developed at the site under the SITE Program
demonstration project and the Consent Order Modification. Soil
gas monitoring wells have also been installed at the site. The
extraction and monitoring wells, which are depicted in Figure 6-.1,
are piped/connected to a VES similar to that installed for the '.
Consent Order Modification treatability study. Capital costs
include costs for additional extraction wells, vapor collection
header piping, blowers and associated valves, electrical fixtures,
condensers and carbon canisters. Operation and maintenance costs
include replacement/regeneration of spent carbon, lubrication and
belts, manpower costs and other annual costs such as insurance,
security and administration. Additional soil and wellhead and
process gas sampling are included in this estimate to further
define existing soil contamination and to provide documentation for
system performance. Table XI-1 presents these capital and
operating and maintenance costs and the total present worth cost
for this alternative. The groundwater component of this selected
remedy consists of air stripping, filtration, carbon adsorption and
discharge back to ground water.
This technology would protect human health and the environment in
both the long- and short-term and provide permanent treatment of
the soil and reduction of contaminant volume. The vacuum
extraction system would also provide compliance with Federal and
State applicable or relevant and appropriate requirements (ARARs).
Because the vacuum extraction system is an in-situ process and does
not require excavation or removal of contaminated soil, it would be
less difficult to implement and would pose no risk of exposure to
contaminants during treatment, unlike the other soil treatment
alternatives evaluated in the FS.
The results of the SITE Program vacuum extraction pilot study
conducted at the site and the soil treatability study performed by
Valley/GRC in 1988 under the Consent Order Modification would be
used to aid in the design of a full-scale system for the site.
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The vacuum extraction system will be operated until the coil
cleanup goals are attained everywhere on the Valley Site, as'
determined by subsurface soil and soil gas sampling and analysis.
The system's performance will be evaluated in the five-year
statutory remedy review or at some earlier time as the soil cleanup
goals are attained or determined to be unattainable.
The area of attainment for the soil cleanup goals is to be
achieved everywhere on the Valley Site unless it is determined
that a contaminant level in soil has been achieved that is not
contributing to groundwater contamination above cleanup goals.
Estimated Time for Construction and Operation: <10 years
Estimated Capital Cost: $702,000
Estimated Total Operation and Maintenance Cost: $1,147,000
High Rate Groundwater Recovery and Treatment
Air stripping combined with carbon treatment would be used to
•address groundwater contamination at the Valley Site. This
approach would require installation of a well system to pump
contaminated groundwater at the Site. Groundwater would be
extracted at a high rate (approximately 30 gallons per minute
(gpm)is anticipated). Optimum recovery rates will be developed
through on-site pump tests and other studies conducted during
remedial design. The extracted groundwater would be pretreated to
remove inorganic compounds and then passed through an air
stripping chamber to remove VOCs. In the chamber, air would be
forced over the water, causing contaminants to volatilize from the
water into the air. The air would then be treated in activated
carbon columns to remove contaminants before being discharged to
the atmosphere. A portion of the groundwater that passes through
the air stripper (approximately 1.5 gpm of the total 30 gpm) would
be filtered through activated carbon columns to remove residual
contaminants and then discharged to a point downgradient of the
site. The remainder of the treated groundwater would be circulated
back through the extraction zone and recaptured for further
treatment. This alternative would continually pump and treat
groundwater until cleanup goals are attained. (Figure 8
illustrates the preferred groundwater treatment process). Incoming
groundwater and emissions from the system would be monitored
throughout operation.
Air stripping and carbon adsorption are proven technologies for
the removal of VOCs of the type that have been found at the site.
The combined system would bring rapid improvement in the
groundwater quality. This technology, like vacuum extraction,
would protect human health and the environment in both the long-
and short-term, comply with ARARs, and permanently reduce the
volume of site contamination.
The area of attainment for the groundwater cleanup goals shall be
achieved everywhere on the Valley Site at every point in the
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aquifer. This is based on the aquifer classification as a current
or potential drinking water supply.
Estimated Tine for Construction and Operation: <10 years
Estimated Capital Cost: $786,000
Estimated Total Operation and Maintenance Cost: $1,530,000
SC-3
*^action/I
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ensure that cleanup level goals have bean achieved. Adequately
treated soils would then be backfilled to the excavated areas, or
treated again, as appropriate.
This alternative would provide long-term protection of human
health and the environment, compliance with ARARs, and permanent
reduction of the volume of site contaminants. However, the
alternative is not an in-situ remedy and requires excavation,
stockpiling, and handling of contaminated soils, thereby
increasing the potential exposure to workers, employees, and local
residents. Actions would be required to control and minimize any
short-term threats to human health and the environment from
releases of VOCs into the ambient air during excavation. In
addition, pilot studies to finalize the system design and operating
procedures would be required prior to implementation of remedial
actions. Based on the cost, time to implement and short-term
adverse impacts associated with this remedy as well as community
and state opposition, this remedy was not selected.
Estimated Tiae for Construction and Operation: 2-3 years (soil):;
10 years (groundwater)
Estimated Capital Cost: $7,170,000
Estimated Total Operation and Maintenance Cost: $1,600,000
SC-5
Low—Temperature Thermal Stripping/Low—Rate Groundwater Treatment
This alternative combines the soil treatment component described
above under alternative 14, and the groundwater treatment
component described under alternative 13. Overall, this
alternative would provide a high level of protection of public
health and the environment, compliance with ARARs, and permanent
reduction of the volume of site contaminants. This remedy was not
selected for similar reasons as SC-4 plus the time to achieve the
cleanup goals for groundwater.
Estimated Time for Construction and Operation: 2-3 years (soil);
10 years (groundwater)
Estimated Capital Cost: $7,016,000
Estimated Total Operation and Maintenance Cost: $2,600,000
SC-6
Off—aite Disposal/Hioh—Rate Groundwater Trea^ff^fp*;
This alternative would entail the use of the same groundwater
treatment system as the preferred alternative. For the soil
component of this alternative, approximately 19,000 cubic yards of
contaminated soil at the site would be excavated and transported
off-site for treatment and disposal at a permitted hazardous waste
facility. Excavation and transportation of contaminated soil would
be controlled to minimize any short-term threat to human health
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and the environment from contaminant emissions during the remedial
action. To implement this alternative, approximately fifteen
percent of the Valley building would have to be demolished in order
to remove contaminated soil.
This alternative provides a long-term protection of human health
and the environment, compliance with ARARs, and permanent
reduction of the toxicity, mobility, and volume of site
contaminants but requires disposal off-site. This is not
considered to be consistent with the intent of CERCIA to reduce
toxicity, mobility or volume. Implementation of this alternative
may be difficult, however, because extensive measures would need to
be taken to ensure protection of public health during excavation
and transport of contaminated soil, and because there are currently
no permitted hazardous waste treatment facilities near the site.
Estimated Time for Construction and Operation: 1 year (soil); 10
years (groundwater)
Estimated Capital Cost: $18,000,000 :
Estimated Total Operation and Maintenance Cost: $1,500,000
X. THE SELECTED SOURCE-CONTROL REMEDY
The source-control remedial action selected for implementation at
the Valley Site is consistent 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 Oil and
Hazardous Material Contingency Plan (NCP) 40 CFR Part 300 et seq.,
47 Federal Register 31180 (July 16, 1982) as amended. The selected
remedial action is a comprehensive source-control operable unit of
the Valley Site section of the Groveland Wells Nos. 1 & 2 Superfund
Site for organic contamination which addresses both soil and
groundwater contamination to achieve the response objectives and
cleanup goals established for the Valley Site remediation and
governing legal requirements.
A. Description of the Selected Remedy
(1) Design, install, operate and maintain a soil vapor vacuum
extraction system (VES) in the vadose zone which will
intercept laterally and vertically all areas of subsurface
soil contamination so as to attain the soil cleanup goals
presented in Table VI-3 in an efficient and expeditious
manner.
The area of attainment for the soil cleanup goals
everywhere on the Valley Site unless it is determined that a
contaminant level in soil has been achieved that is not
contributing to groundwater contamination above cleanup goals.
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The VES will utilize the extraction and monitoring welly
installed during the SITE program demonstration and the
Consent Order Modification. Additional extraction and
monitoring wells will be installed as necessary. It is
anticipated that four to six additional extraction/
monitoring wells will be installed. Design of the VES to be
implemented will be based on evaluation of the results of the
SITE Program demonstration and the Consent Order Modification
treatability study.
The VES will utilize carbon adsorption for vapor treatment.
Carbon adsorption or equivalent treatment will also be
utilized for the treatment of separator water before being
discharged downgradient of the site. This contaminated
water may be treated in the groundwater treatment system
described above in alternative SC-2 and below in (3).
An adequate and effective sampling and analysis program will
be designed and implemented to monitor the performance of :
the VES recovery and treatment and process gas discharges. •
It is currently estimated that the soil cleanup goals can be
achieved within 10 years.
(2) Design, install, operate and maintain a groundwater
recovery/recirculation system in overburden and bedrock. This
system will intercept contaminated groundwater on the site in
all downgradient directions (east and south) and recirculate
portion of treated effluent upgradient of the site to
accelerate removal of saturated zone soil contamination.
Recovery/recirculation shall be at high rates that will
attain the groundvater cleanup goals established in Section
VIII.c and presented in Table VI-3 in an efficient and
expeditious manner. As part of design, groundwater recovery
and recharge pilot studies will be performed.
It is currently estimated that the groundwater cleanup goals
can be achieved within 10 years.
The area of attainment for the groundwater cleanup goals
shall be achieved everywhere on the Valley Site at every
point in the aquifer. This is based on the aquifer
classification as a current or potential drinking water
supply.
(3) Design, install, operate and maintain a groundwater treatment
system utilizing aeration and carbon adsorption to treat the
contaminated groundwater from the recovery system implemented
in accordance with (2).
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37
It is anticipated that the portion of the effluent to be
recirculated upgradient of the site within the zone of
influence of recovery will be treated by aeration alone. The
portion of the effluent to be discharged downgradient and
outside of the zone of influence of recovery will be treated
by aeration and carbon adsorption to meet the discharge
standards established in the Massachusetts Ground Water
Discharge Permit Program (314 CMR §5.00).
Carbon adsorption will be utilized for treatment of emissions
from the aeration treatment to comply with the Massachusetts
Air Pollution Control requirement to utilize Best Demonstrated
Available Technology for point source emissions (310 CMR
§7.00).
Incidental treatment for inorganic compounds and secondary
effluent parameters will be utilized as necessary to
efficiently operate the treatment system for removal of VOCs
and to meet the discharge standards of 314 CMR §5.00, which
are presented in Table VI-4. :
An adequate and effective sampling and analysis program
will be designed and implemented to monitor the performance
of the groundwater recovery/recirculation and treatment
system and discharge effluent.
The design of the groundwater recovery/recirculation and
treatment system will consider the groundwater treatability
study performed under the Consent Order Modification.
(4) Effectively seal or disconnect all drains-and lines to the
Brite-dip subsurface disposal system.
The area of attainment for the groundwater cleanup goals is
everywhere on the property in the saturated zone, and for the soil
cleanup goals, everywhere in the vadose zone.
While not a part of the selected remedy, it is anticipated that
EPA will review closure of the underground storage tanks under the
UST program and closure of the septic systems under RCRA.
B. Rationale for Selection/Cleanup Goals
The rationale for choosing the selected alternative is based on
the assessment of each criteria 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 have been found to 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,
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including, short term effectiveness, long term effectiveness,
implementability, use of treatment to permanently reduce the'
mobility, toxicity and volume, and cost, EPA also considered
nontechnical factors that affect the implementability of a remedy,
such as state and comnunity acceptance. Based upon this
assessment, talcing into account the statutory preferences of
CERCLA, EPA selected the reaedial approach for the Site.
This source control remedial action is designed primarily to
address the organic contamination in unsaturated and saturated
subsurface soils and groundwater. The target groundwater and
corresponding soil cleanup levels are presented in Table VI-3 and
discussed below.
EPA has determined that while in the long-term, alternatives
involving excavation of contaminated unsaturated soils and on-
site above-ground treatment via low temperature thermal stripping
(LTTS) (SC-4 and SC-5) and those involving in-situ removal of
contaminants from unsaturated soils by a vacuum extraction system
(VES) and treatment of extracted vapor via carbon adsorption (SC-
2 and SC-3), provide a similar degree of protection, those
involving excavation and above-ground treatment have significant
potential short-term adverse effects associated with their
implementation: threat of volatile contaminant emissions during
excavation and treatment processing; threat of exposure to
contaminants during handling; disruption to site and surrounding
community; long lead time from selection to implementation due to
need for pilot studies/design and site preparation.
In addition, the limited area on the Valley site poses potential
institutional/implementability issues related to staging of
excavation and treatment equipment and the stockpiling treated
soils before backfilling to the excavation area.
The selected in-situ vacuum extraction: provides the same degree
of contaminant removal and permanency, few or no adverse short-
term impacts, no site or community disruption, no excavation or
handling of contaminated soils. Further, in-situ vacuum
extraction has been demonstrated to be effective on this site and
will require relatively little time to implement with substantial
contaminant reduction realized immediately.
Groundwater
The target groundwater cleanup levels are primarily based upon the
classification of the groundwater at the Valley Site as a current
or potential source of drinking water to which Maximum Contaminant
Levels promulgated under the Safe Drinking Water Act are relevant
and appropriate. The groundwater protection standards under RCRA
Subpart F are also relevant and appropriate requirements. The
target groundwater levels have been set at NCLs or, in their
absence, an excess cancer risk level of 10~6 (as is the case with
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39
methylene chloride). As the legally enforceable standards under
the Safe Drinking Water Act, MCLs determine the level of water
quality that is acceptable for public supplies.
With respect to groundvater remediation, EPA evaluated two rates
of groundwater restoration: low-rate involving removal and
treatment of contaminated groundwater at the rate of natural flow
through the site; and, high-rate which accelerates contaminant
removal from the saturated zone by artificially recharging
treated groundwater upgradient. Both options utilize
aeration/carbon adsorption for treatment.
While both rates of groundwater restoration provide the same
degree of long-term protection and will attain ARARs, the low-
rate would require substantially longer than 30 years to achieve
the cleanup goals while a high-rate system would require an
estimated 10 years to achieve those goals, at a lower total cost
for capital and present worth of operation and maintenance, due to
the shorter period of operation. Capital costs for both low- and
high-rate groundwater recovery/treatment system are nearly equal at
$1.3 and $1.5 million, respectively.
The Agency's decision to restore the groundwater at the Site to
drinking water standards was based on several factors. In
addition to the requirement to attain Federal and State ARARs, the
Agency considered its Groundwater Protection Strategy (GWPS)
(Office of Groundwater Protection, August, 1984) which provides
guidance concerning how different groundwaters throughout the
country should be classified and to what extent cleaning up a
particular class of groundwater is appropriate. EPA also
considered the Agency's draft Guidance on Remedial Actions for
Contaminated Groundwater at Superfund Sites (October, 1986). This
guidance directs the Agency to consider a 10~4 to 10~7 range of
risk levels in selecting the appropriate risk level for the
groundwater at the Site.
The policy under the GWPS establishes groundwater protection goals
based on "the highest beneficial uses to which groundwater having
significant water resources value can presently or potentially be
put." Guidelines for protection of aquifers are differentially
based, relative to characteristics of vulnerability, use and value.
Under the classification scheme, the groundwater at the Valley
Site is Class II groundwater. This groundwater is considered to
be a current drinking water source since groundwater is used for
drinking water within a two-mile radius of the Site (the
classification review area).
EPA believes that active restoration of the groundwater is
appropriate for the Site. Presently, the Town obtains
groundwater from the overburden aquifer system. Contamination
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40
in the overburden and bedrock aquifers has been detected at
substantial levels beyond the Valley Site boundaries.
Finally, it is reasonable to assune that development could occur
on or near the Site following remediation. As mentioned
previously, source soils will be remediated to levels that are
protective of human health and the environment.
Consistent with the draft Guidance on Remedial Actions for
Contaminated Groundwater at Superfund Sites and EPA's Superfund
Public Health Evaluation Manual. EPA evaluated a risk range of 10~4
to 10"v individual lifetime cancer risks for carcinogens in
•electing a risk level for groundwater. In selecting the
appropriate risk level for the Site and the rate of restoration,
EPA considered the following major factors:
1. Site and groundwater characteristics;
2. Cost, reliability, speed, and technical feasibility of
groundwater response actions;
3. Anticipated future need for the groundwater;
4. Potential for spreading of the contaminant plume; and,
5. Effectiveness and reliability of institutional controls.
MCLs were selected as target cleanup levels for vinyl chloride,
trichloroethylene, and 1,1-dichloroethylene, as established under
the Safe Drinking Water Act. A standard for tetrachloroethylene
has not yet been developed. It is, however, similar in chemical,
physical, and toxicological properties to trichloroethylene and
therefore the same cleanup level of 5 ppb has been adopted. A
value of 5 ppb for methylene chloride, corresponding to a IxlO"6
excess cancer risk level, was also adopted.
An incremental lifetime cancer risk of 2.6 x 10 ~4 associated with
the ingestion of the five volatile organic contaminants of concern
at their respective target cleanup levels is considered by EPA to
be adequately protective of public health under the specific
conditions related to this Site. EPA anticipates continued growth
within the Town of Groveland, thus increasing the demand placed on
the Johnson Creek aquifer and Municipal Well Station No. 1. EPA
rejected target risk levels significantly lower than 2.6xlO~4 due
to the technical and economic feasibility of remediating
groundwater.
soil
The target soil cleanup levels presented in Table VI-3 are based
on achieving the target groundwater levels. This approach
utilizes a soil/water sorption coefficient which describes the
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41
distribution of an indicator chemical between soil and groundwater
at equilibrium. The amount of naturally occurring organic carbon
present in soils has a large impact on the amount of contamination
that will be attenuated in those soils and therefore unable to
migrate and contribute to further groundwater contamination.
Typically, glacial soils contain small amounts of organic carbon,
roughly one-half to five percent. Clay content and iron oxide
content of soils have been shown to significantly increase the
adsorptive capacity of soils. Some soils at the Valley Site have
large amounts of clay material but others are relatively porous
sands and gravels. Although there have been no tests performed to
determine the fraction of organic carbon in the soils at the
Valley Site a value of 1% was assumed based on the soil types
present. The equation used to calculate the soil cleanup target
levels is provided in the FS in Section 2.
XI. STATUTORY DETERMINATIONS
The remedial action selected for implementation at the Valley 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 a permanent
solution and for treatment which reduces the mobility, toxicity or
volume as a principal element to the maximum extent practicable.
Additionally, the selected remedy utilizes alternate treatment
technologies to the maximum extent practicable.
A. The Selected Remedy is Protective of Human Health and
the Environment
The source-control remedy for the Valley Site will significantly
reduce the current and potential risks to human health and the
environment posed by contaminated groundwater and subsurface
soils. This source control remedy will reduce and minimize the
migration of groundwater contamination from the Valley Site. The
Valley Site contributes to significant contamination off site in
the Mill Pond/Johnson Creek watershed and aquifer. Upon
successful implementation of this remedy, the relevant and
appropriate drinking water standards established under the Safe
Drinking Water Act and other health based groundwater cleanup
goals for the selected volatile organic contaminants of concern
will be achieved everywhere on the Valley Site.
The incremental lifetime cancer risk level posed by the ingestion
of residual volatile organic contaminants of concern in .
groundwater is not expected to exceed 2.6 x 10~4. The
noncarcinogenic health effects posed by ingestion of the volatile
organic contaminants of concern in groundwater is not expected to
exceed a hazard index of unity.
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B. The Selected Remedy Attains ARARs
This remedy will meet or attain all applicable or relevant and
appropriate federal and state environmental raquiraaants that
apply to tha sita. Fadaral anvironnantal lavs and regulations
which ara applicable or relevant and appropriate to the selected
remedial action at the Valley Site are certain provisions of the:
Resource Conservation and Recovery Act (RCRA)
Safe Drinking Water Act (SDNA)
Clean Air Act (CAA)
Occupational Safety and Health Administration (OSHA) Regulations
Table C-l, taken from Appendix C of the Feasibility Study, lists
the chemical-specific Federal and State ARARs, and outlines the
actions which will be taken to attain these ARARs. No location-
specific ARARs have been identified for the Valley Site. Table C-2
lists the action-specific Federal and State ARARs, presents a
brief synopsis of the requirements, and outlines the action which
will be taken to attain these ARARs. These tables also indicate
whether an ARAR is determined to be applicable, relevant and
appropriate or whether it is in the category of to-to-considered.
A brief narrative summary of the ARARs follows.
The principal chemical-specific ARARs are the Maxima Contaminant
Levels (HCLs) established in the Safe Drinking Water Act (40 CFR
141.1 - 141.16) and the Massachusetts Groundwater Quality Standards'!
(MGQSs) (314 CMR 6.00), which have been determined to be relevant
and appropriate to remediation of the site. Hence, the NCLs were
used primarily to establish the groundwater cleanup goals for
volatile organic contaminants. In addition, the Maximum
Contaminant Level Goals (MCLGs) established in the 5DWA and the EPA
risk Reference Doses (RfDs), both of which have been determined to
be in the category of To Be Considered, were used in the absence of
MCLs in establishing site cleanup goals. The HCQSs are set at MCLs
with the exception of iron and manganese.
With respect to action-specific ARARs, in accordance with The
Massachusetts Air Pollution Control (310 CMR 7.00) regulations
which are considered to be applicable to all point-source
discharges of volatile organic compounds, Best Available Control
Technology (BACT) will be utilized in the treatment of discharges
from the groundwater aeration system and vacuum extraction system.
Discharges of treated water to groundwater, both upgradient of the
site for recirculation and downgradient will meet the standards set
forth in the Massachusetts Ground Water Discharge Permit Program
(314 CMR 5.00) Vhich are established to meet the MGQSs. these
regulations, which are applicable to all ground water discharges,
require treatment to MCLs for inorganics or organics identified as
primary parameters. Discharge limitations are also established for
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43
secondary parameters such as oil and grease, iron, manganese and
zinc. These standards are required to be met for all discharges.
The temporary storage and transportation of spent activated carbon
will also comply with provisions of RCRA.
All Occupational Safety and Health Administration requirements for
health and safety during hazardous waste operations (29 CFR Part
1926) and general industry standards (29 CFR Part 1910) will be
complied with during implementation of this remedy.
With respect to long-term groundwater monitoring, the RCRA
Groundwater Protection requirements (40 CFR §264, Subpart F) have
been determined to be relevant and appropriate for this site. A
groundwater monitoring system will be implemented consistent with
40 CFR §264.100(d) to determine the effectiveness of the
groundwater remediation system.
C. The Selected Remedial Action is Cost Effective
In evaluating the cost-effectiveness of source-control
alternatives, EPA considered the total short- and long-term costs
of all proposed alternatives, which include the capital costs and
present worth costs of operation and maintenance for the entire
period during which such activities will be required. The FS
identified and evaluated in detail remedial alternatives for no-
action, in-situ treatment, on-site above-ground treatment and off-
site treatment. All the alternatives evaluated in the detailed
analysis of the FS, with the exception of the no-action
alternative, are protective of human health and the environment
and upon completion will attain ARARs.
The only alternative that has a lower cost than the remedy
selected was the no action alternative. Thus, the selected remedy
is cost effective.
D. The Selected Remedy Utilizes Permanent Solutions and
Alternative Treatment Technologies or Resource Recovery
Technologies to the Maximum Extent Practicable
Vacuum extraction is an alternative treatment technology which
provides removal of the mass of volatile organic contamination in
soil, thereby permanently and significantly reducing the toxicity,
mobility and volume of contamination. The VOCs that are removed in
the extracted soil vapor are adsorbed onto granular activated
carbon, which when saturated is transported for off-site
regeneration at a resource recovery facility. Contaminant
reduction efficiencies of 99.999% have been achieved at other sites
utilizing vacuum extraction.
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44
The groundwater recovery/treatment portion of the selected remedy
also provides permanent removal and reduction of the Bass of
volatile organic contaminant* in groundwater through groundwatar
recovery and treatment via air stripping and carbon adsorption.
As with tha VES, tha spant activatad carbon from tha air strippar
aaissions control and froa tha liquid phasa aftar aaration will ba
transportad off-site for raganaration at a rasourca racovary
facility.
B. Tha Salactad Remedy Satisfias tha Prafaranca for
Traataant as a Principal Elaaant
Tha principal alaaants of tha salactad source-control raaady ara
soil vapor vacuum axtraction and traatmant with carbon adsorption
for unsaturatad soil traatmant and racovary/racirculation and
traatmant by aaration and carbon adsorption for groundwatar and
saturated soil traatmant. Thasa alamants addrass all human health
and environmental threats at tha site resulting from organic
contamination of subsurface soils and groundwatar by removing tha
mass of contaminants via in-situ recovery.
XII. STATE ROLE
Tha Commonwealth of Massachusetts Department of Environmental
Quality Engineering has reviewed the various alternatives and has
indicated its support for the selected remedy. Tha State has also
reviewed the Remedial Investigation, Endangerment Assessments and
Feasibility Study to determine if the selected remedy is in
compliance with applicable or relevant and appropriate State
environmental lavs and regulations. The Commonwealth of
Massachusetts concurs with tha selected remedy for the Valley Site.
A copy of the declaration of concurrence is attached as Appendix C.
In accordance with Section 104 of CERCLA, tha Commonwealth of
Massachusetts is responsible for 10 percent of the cost of the
remedial action. In tha case of tha salactad remedy, tha
Commonwealth's share is estimated at approximately $400,000.
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APPENDIX A
RESPONSIVENESS SUMMARY
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C D M CAMP DRESSER i McKEE INC.
t /ntntprmm eemunna toman. MuMchuMV (BK»
•17 M2-51S1
September 26, 1988
Mr. Dennis P. Gagne
Regional Project Officer
U.S. Environmental Protection Agency. Region I
J.F.K. Federal Bunding
Bostcn, Massachusetts 02203
Ms. Kathleen Janes
Regional Superfund Ctmunity Relations Cbordinator
U.S. Environmental Protection Agency, Region I
J.F.K. Federal Bunding
Boston, Massachusetts 02203
Subject: Final Responsiveness Summary for the Public Consent Period on
the Feasibility Study and Proposed Plan for the Valley Source
Area at the Grcveland Hells Superfund site in Groveland,
Massachusetts.
Work Assignment No: 415-1132.0
EPA Contract No: 68-01-6939
Document No: 270-OR2-EP-GM3W-1
Mr. Gagne and Ms. James:
Csnp Dresser & McKee, Inc. is pleased to deliver this final responsiveness
summary for the public cement period on the Feasibility Study and Proposed
Plan of the Valley Source area at the Groveland Wells Superfund site in
Grcveland, Massachusetts. This responsiveness summary summarizes coanents
received during the public cement period and provides EPA's responses to
If you have any questions or comments, please contact me or Richard Quatanan,
REM II Oammity Relations Specialist.
Very truly yours,
CAMP ERESSER & McKEE INC.
wniiam R. Swanson, P.E.
REM n Regional Manager
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FERFCRWNCB CP REMfcuiAL RESPCMaB
ACTIVITIES AT IKJLKIHJUB) EAAROCD5
HASTE STIES (REM H)
IB EPA Contract Ho. 68-01-6939
FINAL.
FCR IBB
VAILEĄ SOURg: AREA XT TOE
GOTHLAND tdlS SDFEKPQND SHE
GK7/ELAND, MSSMCBEEIIS
DOOMEMT GCKERQL ».: 270-CR2-EP-OGX-1
Prepared By:
Approved By:
Approved By:
Approved By:
Richard K. Quateman
REX II Cuinunity Relations Specialist
Date;
Date:
REM H Site
Elizabeth S. Maroobte
REM SI Oonrunity Relations Manager
Date;
William R. Svansfcn, p
REM n Regional Manager
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TABLE OF CONTENTS
HCLtACE.
I. OVERVIEW OF REMEDIAL ALTERNATIVES CONSIDERED IN THE FEASIBILITY
STUDY INCLUDING THE HttltXHEU ALTERNATIVE 3
n. BACK3SUND OF CtmiNITY INVOLVEMENT AND CONGERS 5
in. sutara OF CEMENTS RECEIVED DURING THE PUBLIC ccwENr PERIOD
AND EPA RESPCNSES 6
Part I. Sutmary of Citizen and Other Interested Party Ccnnents. .6
A. Garments Regarding EPA's Definition of the Site
Off Site Inpacts 6
B. Cements Regarding EPA's Preferred Alternative 7
Part II. Suntnary of Potentially Responsible Party (PRP)
Cements ...11
IV. REMAINING CONCERNS 17
ATTACHMENT A - CdWUNrTY RELATIONS ACTTVnTES CONDUCTED AT THE VALLEY
SOURCE AREA AT THE GROVELAND WELLS SITE
ATTACHMENT B - TRANSCRIPT OF THE AUGUST 9, 1988 XNPCSMAL PUBLIC HEARING
ATTACHMENT C - DETAILED OME37IS OF THE POTENTIALLY RESPONSIBLE'PARTIES
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Preface
The Uhited States Environmental Protection Agency (EPA) held a public
ccianent period from July 27, 1988 to August 26, 1988 to provide an opportunity
for interested parties to cement on the August 1988 Feasibility Study (FS)
and July 20, 1988 Proposed Plan for the Valley Manufactured Products company,
Inc. (Valley)/ Grcveland Resources Corporation (GRC) site (the Valley site) at
the Grcveland Wells Superfund Site in Grcveland, Massachusetts. In addition,
EPA allowed the potentially responsible parties (PRPs) the opportunity to
submit additional technical information relevant to the Proposed Plan until
September 7, 1988. The FS examines and evaluates various source control
cleanup options, called remedial alternatives, for addressing contamination of
soils and groundwater by volatile organic compounds (VOCS) at the Valley Site.
The Proposed Plan presented EPA's preferred alternative for source control
remedial action for VOCs at the Valley Site. ;
•
One purpose of this responsiveness summary -is to identify comments raised
during the public cement period and provide EPA responses to the commits.
EPA considered all of the Garments summarized in this document before
selecting a final source-control remedial alternative for the contamination at
the Valley site in Grcveland, Massachusetts.
This responsiveness summary is divided into the following sections:
I. Overview of Ren**^*^ ^^Tnativ*** Consider**^ in the
Study and Proposed Plan - This section briefly outlines the remedial
alternatives evaluated in the FS and presented in the Proposed Plan,
including EPA's preferred alternative: soil vapor vacuum extraction
for removal/treatnent of contaminants from soil, and high-rate
groundwater recovery and treatment utilizing air-stripping followed
by carbon adsorption for groundwater treatment.
H. Background on Cmmiunity Involvminjit and Om'totans — This section
provides a brief history of community interests and concerns
regarding the Grcveland Wells and Valley site.
HI. Suntr^Tv of Pumienfrs Ponp^yt*^ unH EPft p**gponses ~ This section
summarizes comments received by EPA during the public comment period
and provides EPA's responses. A summary of the comments received
from the Potentially Responsible Parties (PRPs) and EPA's responses
to them are included in this section. The PRP's detailed cements
are included as Attachment C to this responsiveness summary*
IV. Remaining Concerns - This section describes issues that nay continue
to be of concern to the community during the design and
implementation of EPA's selected remedy for the Valley Site. EPA
will address these concerns during the Remedial Design and Remedial
Action (RD/RA) phase of the cleanup process.
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attadwant i* a list of the ccmamity rmlatior*
•ctivitiM that EFA has oonductad to data at tha V4ll«y sit*.
Attaetment B - Trai»cript of tha August 9, 1988 mfoxnal Public Haaring
hald in Growland,
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I. OVmVlkW OP REMEDIAL AI2B9AHVES GCNSHH&D IN IRE FEASIHUJTY STUDY AND
RAN
Using the information gathered during the Remedial Investigation (RI) and
Supplemental RI performed by valley/GRC under a Consent Order with EPA, and
the Endangennent Assessment (EA) developed by EPA, EPA identified several
objectives for the cleanup of the Valley Site. The response objectives are
to:
1) prevent ingestion of contaminated grcundwater;
2) prevent direct contact and ingesticn of contaminated soil;
3) prevent inhalation of contaminants in the air; and,
4) prevent migration of contaminants from the site that would cause
grcundwater contamination in excess of state and Federal drinking
water standards.
To achieve these objectives, EPA identified cleanup goals for remedial
action and identified, developed, and evaluated potential cleanup
alternatives. Ihe evaluation, or FS report, specifically describes the
alternatives considered for addressing volatile organic contamination in
grcundwater and soil, as well as the criteria EPA used to narrow the list to
six potential remedial alternatives. Each of these alternatives is described
briefly below.
1. No Action. The no action alternative would entail implementing a
grcundwater sampling program, installing additional fencing and warning signs,
and restricting further use of the site. No groundwater or soil treatment
would be conducted.
2. Vacuum Extract ion/Hi qh~Rat.g> Groundwyt'^^* Treatment fEPA's Prefgrrpfj
Alternative). This alternative will use vacuum extraction to remove
contaminants from soils on the site. A series of wells will be installed
above the groundwater table and connected to a pumping system to create a
vacuum that extracts vapor from the soil. Volatile organic compounds (VOGs)
present in the soil are drawn into the vapor. The extracted contaminated
vapor is treated using carbon filters to remove VOCs prior to discharging the
cleaned air to the atmosphere.
To address contaminated grcundwater, this alternative involves pumping
grcundwater from the site for treatment and then reinjecting a portion of the
treated water upgradient of the site to speed the flushing of contaminants
from the aquifer. The contaminated groundwater will be treated by air-
stripping before being reinjected on the site. The remaining portion will be
treated further by carbon adsorption to achieve drinking water quality before
being discharged on the downgradient side of the site.
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i the air-stripper, groundwater is punped to the top of an air stripping
Air is forced up through a tower as the extracted groundwater flows
down. VOCs in the groundwater are transferred to the air stream which is next
paseed through an activated carbon filter to remove VOCs prior to discharge of
the clean air to the atmosphere.
utilize the sane vacuum extraction technology used in alternative |2. low
rate groundwater treatment would utilize the sane punping and air-stripping
tower/carton adsorption system as alternative 2, but no groundwatar would be
reinjected to flush contaminants. Instead, all the extracted groundwater
would be discharged downgradient on the sits.
this alternative, contaminated soils would be excavated and treated in a
mobile unit by heating the eoil and forcing air through it to remove VOCs.
The air would then be passed through a series of pollution control devices
prior to release to the atmosphere. This alternative would require :
demolishing a portion of the existing building for excavation of contaminated
soils underneath it. Treated soils would be stcdqpiled on-site before being
replaced in the excavated area. This alternative would utilize the sane
groundwater treatment as the preferred alternative in |2 above.
5.
This
alternative would carabine soil treatment in alternative |4 and the groundwater
treatment used in alternative 13.
use the preferred alternative groundwater treatment technology in 12 abov*.
Contaminated soils would be excavated and transported off site for treatinent
and ^i^p^M at a federally approved hazardous waste facility.
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n. aocaocND GN cattHm INVOLVEMENT AND GCNCEEMS
Community involvement at the Groveland Wells Superfund Site, of which the
Valley Site is a component, has focused primarily on the contamination of the
Gtoveland Municipal wells, which were ordered closed by the State in 1979 due
to contamination by VDCs. Historically, EPA has held and attended frequent
public meetings to dlsraisB the Agency's plans for site investigations, studies
and cleanup plans. In particular, between 1985 and 1987, EPA held frequent
meetings with residents and local officials to «^ernee the design and
implementation of the remedial alternative selected for treatment of the
contaminated Grcveland Well Station No. 1. Community concern decreased once
the veil treatment began in 1987. Interest in the site again increased in
1987 when EPA conducted a pilot study of vacuum extraction at the Valley Site
under the Superfund Innovative Technology Evaluation Program (SITE).
Residents were generally supportive of the project, though there were concerns
about potential delays in implementing the cleanup at the Valley Site due to
the SITE demonstration. Since the SITE demonstration, community interest In
the site has again leveled off and residents remain supportive of EPA's
actions at the Valley Site.
Principal community concerns at the present time are summarized below.
Municipal Well Omf^ruination
This concern focuses on the contamination and closing of Groveland's
municipal wells. The shutdown, in 1979, resulted in water use restrictions,
increasing resident interest in the site. Citizen concern seemed to peak
during this period and during final design of a treatment system that would
eventually allow one well to again be utilized. This well, Station No. 1 is
now in full operation.
Scope of the Proposed Plan
Citizens expressed concern that the Proposed Plan addresses only the
limited area of the Valley site and not the contaminant plume (s) leaving the
site and impacting the Mill Pond area and the Johnson Creek and aquifer.
Citizens are concerned that treating each area separately reduces the overall
effectiveness of the cleanup.
Availability of Site Information
Citizens have recently expressed concern that information from the SITE
Program demonstration has not been made available.
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m. scMMcr or GDMMS FBZIVED max THE FOKIC coMeir FBOOD MD
This responsiveness summary addresisi the tuunsiits received by
concerning tht draft fS and PimxjseJ Plan for the Valley site at the Grovaland
Halls Superfund sit* in Groveland, Massachusetts. Three aata of rrmiaiilB wara
received daring the public ouuuaut period: tMD from tha general public and one
from the PRPa. Copies of tha tranecript of tha July 26, 1968 informal public
hearing arc available at the Langlay Adas* Library* IBS Main Street,
Groveland, HMaarFuiaatta 01834; the Grovaland Town dark's Office, Grovaland
Town Hall, 183 N»in Street, Grovaland, Naaaachusetts 01834; and, at the EPA
Records Canter at 90 Canal Street, Boston, Massachusetts 02114.
Bart I - Counts froa the General Public and Other Interested Parties
The ocranents frcm citizens, along with EPA responaes, are sunnarixed and
organized into the following categoriss:
A. Definition of the Site/Off Site
B. Vacuum ZMraction/Grounduater TraatBsnt
of t>M Sit*/Off
One town representative stzvsaed that the Valley site is but
one section of the larger Groveland Walls Superfund site, and that ERfc
should look at tha whole site because treating tha Valley site separately
Btes a fragmented approach to the cleanup.
Cement 2. One town representative stated that EPA should give greater
ettention to the impacts of remedial activities et the Valley aite on
other areas of the Groveland Wells site, noting specifically that cleanup
of the Valley soils should have an tafact upon the Mill Fond area, a
contaminant plvne originating at the Valley site, and the Johnson Creek
Aquifer.
Comment 3. A town representative stated that EPA should consider
Groveland's aquifer protection plan and by-laws in deteraining cleanup
plans for tha Valley sits;.
EPA recognizes that tha Valley Site is one primary uii|Ai*»l of a larger,
•ore complex contamination problem at the Groveland Walls Site. In order
to most efficiently address all areas of source and migratory
contamination at tha Groveland Site, EPA has developed a multi-source
groundwater response plan which splits the Groveland Site into operable
units for source-control and management of migration remedial actions.
To date, this plan has entailed (1) the provision of an alternative water
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supply by restoring Station No.l by treating for volatile organic
contaminants, and (2) the selection of a source-control remedy for the
Valley Site, which is the subject of this ROD.
This source-control remedy will reduce the volume of contaminants in soil
and groundwater at the Valley Site, which includes the Valley property
and immediately adjacent areas of soil contamination. This remedy will
therefore reduce and minimize further migration of contamination in
groundwater from the Valley Site.
The Valley site FS appropriately focuses on the aouiueuuntrol soil and
groundwater remediation at the Valley Site. The HDD for the Valley Site
discusses in detail the relationship between the source-control action
and the other planned or executed actions at the Groveland Wells site,
which includes consideration of the Town's aquifer protection by-lav.
The endangerment assessment performed for the Valley Site recognizes and
evaluates environmental exposure in areas off of the Valley Site
including the Mill Pond/Johnson Creek. :
. Subsequent to this source-control action at the valley site, a management
of migration (KH) remedial action will be taken for the Mill
Pond/Johnson Creek watershed and aquifer. A remedial investigation will
be performed to characterize the nature and extent of surface water,
sediment, and groundwater contamination in these areas, which includes
the area between Valley and the Mill Band. An endangerment assessment
will be performed to characterize the human health and environmental
exposures associated with this contamination. A feasibility study will
be performed to develop and evaluate JCM remedial alternatives to
address this contamination. Alternatives will be developed in
consideration of the existing contamination, human health and
environmental exposures, and the performance of Station No. 1 and the
Mill Pond groundwater intercept/treatment system constructed and operated
by Valley under agreement with the Massachusetts Department of
Environmental Quality Engineering (DEQE).
This XK remedial action will meet the CERCXA statutory requirements to
utilize treatanent as a principal element to permanently reduce the
toxicity, mobility or volume of contaminants to the »»v*"«™ extent
practicable, and to attain the applicable or relevant and appropriate
requirements (ARARs) of other Federal and State environmental statutes.
Such ARARs would include, but not be limited to, requirements of the Safe
Drinking Water Act and Clean Water Act. State ARARs would include the
Ground Water Quality Standards established in 314 CMR §6.00. The Town's
aquifer protection plan is consistent with these and other ARARs.
B. Ty&'s Pref^red Alternative! Vacuum Bftraction/Hioh—Rat"° ftroundwafrjar
Treatment
Comment J. A number of citizens asked about the long-term effectiveness
of vacuum extraction for soil treatment. One town representative noted
that the report on the SITE demonstration had not yet been published and
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interest in my information en long-ten operation and
saintanance costs of the systen as Mil as total
With respect to the lonj-teia effectiveness of the aoil
remedy, vacuum attraction provides permanent reduction of tha volume of
volatile organic umvjuids (VOQi), to tha asxtaai axtant pnctieabla -by
aubatantially rawing than from tha unsaturatad aoil.
Although tha evaluation raport fxon the SITE Program demonstration of tha
Terra-Vac vaouua axtraction system (VES) has not baan published, carbon
\\ntjt rataa auggaat that aignificant VOC removal rataa wara realised.
Baaad on uaaga (aatunttion) of 13,000 pound* of activated carbon with an
estimated adsorption efficiency of 10%, appradaataly 1300 pounds of VDCfc
ware renewed during tha
The design of the VES to be implemented in accordance with this BCD win
be based on the results of the SITE Program demonstration and a VES soil
treatability study currently being performed at tha Valley Site under :a
The effectiveness of VES has also baan evaluated for the purpose of this
remedy selection based on its performance at several other sites at which
it has baan applied. Tvm-Vac has published technical papers describing
the results of these applications. Most notable is its application at a
carbon tetrachlorida spill site in Puerto Rico where contaminant
reduction to 7 parts per billion in aoil was achieved.
Qament S. A town representative asked if the Town will be responsible
for any of tha operating costs for tha vacuum extraction or groundwatar
__ EPA intends to negotiate with Valley for the design and
implementation of the selected soil and groundwatar treatanent remedies.
If Valley implements the remedy, which entails effectively operating and
maintaining the treatanent systems until the groundwatar and soil cleanup
goals established in the RX are achieved, compliance and technical
oversight will be provided by EPA. valley would be required to scnitor
groundwater for some period after achieving the cleanup goals to ensure
that the remedy is complete. If negotiations ware not successful, then
EPA would implement the eelected remedy using CERCXA funds, to that
case, EPA and the State would share the costs at a level of §0% Federal-
funds and 10% State-funds and the State would assure operation and
seintenance after the remedy is complete, to any event, the Town would
bear no cost in the implementation of the remedial action.
poitnent 6. one coramentar asked what the source of the vacuum extraction
cooling water would be.
The final design of the vacuua axtraction system to be iapl
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Valley nay not include a heat exchanger. The fle»n'«^ih»i design of a
vacuum extraction system presented in the Valley Site PS did entail use
of a heat exchanger for process gases. The cooling water was to come
front the Valley facility supply, with flcwrates dependent on the design.
However, it is anticipated that the final design for the VES and
groundwater treataent systems would be integrated to the m»v extent
practicable. It is possible that vapor and liquid phase treatment from
both systems could share mi^mils and that cooling water, if used,
could cone from the groundwater treatment system.
eminent 7. One town representative asked if there was adequate space on
the site to construct all the required soils and groundwater treatment
equipment.
EPA Response; EPA believes there is adequate space on the Valley site to
construct both the VES and groundwater treatjnent system. The VES
installed for the SITE Program and the system currently on site is ;
contained entirely within the material storage area, where it could be
located for final implementation. If additional space were required, it
is conceivable that access to the adjacent wooded property could be
secured for this purpose.
Oumient 18. One ccmenter asked if the use of additional air strippers
had been considered.
EPA Response; The Valley Site FS presented a cnni.Tei.thinl design for the
groundwater treatanent system which entailed the use of one air stripper.
The treatjnent system to be implemented in accordance with this ROD will
be designed to be most effective and efficient at achieving the cleanup
goals established in the ROD and may entail the use of multiple air
strippers.
Oament 9. The Valley Site FS indicates that the VES is confined to the
Valley property only. What will be done with the contaminated soil
beyond the property line?
EPA Response; Although it is true that, based on soil gas analysis
performed during the remedial investigation, soil contamination exists
off of the Valley property, relatively little contamination has been
detected in subsurface soil samples collected in this area. Nonetheless,
the VES selected in this ROD requires monitoring of the unsaturated zone
to the south and east to determine if these areas are contaminated. If
determined to be necessary, recovery could take place at these wells in
the future. This way not be necessary as radii of influence from the
existing extraction wells has been determined to be on the order of 50 to
75 feet and recovery of contamination from this area would likely occur
with extraction within the property boundaries.
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Qanmnt io. The Valley Sit* IS cost estimate does not include electrical
or labor for routine •aintenanoe.
The Draft Valley FS included the electrical coats for the
vacuum extraction systsn in the cost tables (see Appendix B of the IS).
This oast, which is an operation and •aintenanoe cost has a pxeeaiit worth
of approodastely $60,000. The labor cost for routine •aintenanoe is
included in the operators oast far stapling. In fact, the vacuua
extraction system requires very little operator involvement eaeoept for
saqple collection as all controls and the eaeiojency shutdown is
Butcnstic.
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Fart U - cements from the Potentially nrqpnraihle Parties
The PRPs stated that, in general, they support EPA's selected volatile
organic source-control remedial alternative at the Valley site. This
alternative involves soil vapor vacuum extraction and carbon adsorption
treatment for soils and recovery/recirculation and air-stripping/carbon
adsorption for groundwater treatment. The PRPs, however, raised the following
cements or suggestions regarding the draft F5 and Proposed Plan relative to
the design of and expected costs for the selected alternative. The PRPs state
that their intent is to demonstrate the availability of alternative remedial
designs which employ the treatanent technologies in EPA's selected remedy and
which achieve an equal degree of protection of human health and the
environment but at less cost than that presented in the Feasibility Study
prepared by EPA contractor Roy F. Westcn.
More specifically, the responsible parties submit information critical
of, and relative to the: :
o Volume (mass) of volatile organic ccqpounds (VOCs) in the
unsaturated soil zone;
o Design of the vacuum extraction system [radii of influence of the
vents (extraction wells) ];
o Volume of VOCs in the saturated zone; and
o Technical practicability of the proposed 30 gallon per minute
(groundwater recovery rate) treatment system
With respect to other aspects of EPA's Proposed Plan as amended, the
responsible parties take issue with the:
o Selected soil cleanup goals;
o Use of (vapor phase) carbon treatment of air stripper vapor
emissions;
o Proposal to remove the subsurface disposal system leaching fields
and underground storage tanks; and
o Proposal to address inorganic contamination present at the valley
Site.
These comments are addressed separately below. In general, with regard
to the first four comments above, related to the design and cost for remedial
alternative, EPA supports the basis for, and the development and detailed
analysis of the source-control remedial alternatives in the feasibility study
performed for the Valley Site. The FS achieved its intended purpose of
developing and analyzing a range of source control remedial alternatives which
are protective of human health, attain ARARs, utilize permanent treatment and
alternative technologies or resource recovery technologies to the mnvimim
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extent practicable and satisfies tha statutory preference for treatnant as a
principal eli
EPA believes on this basis that tha Administrative Record and FS provide
the analysis naoasaary to aalact a cest-«ffective remedial action. One
cuiiuaiits submitted on bahalf of tha FRPs do not affect tills salaction, but
rathar sore appropriately adlieaa issuas related to the design and
implementation of tha salactad ramsdial action. In fact, thaaa data furthar
support EPVs salaction as cost-effective as oonparad to tha othar
alternate
Qjuumnt 1. ERA has over estimated the volume of VOCs in the saturated
and unsaturated zones. The PRPs state that the fS calculations presume
that no VXs have migrated from the immediate Valley area, and note that
if that ware the case there would be no off-site groundueter
contamination.
EPA Response: The volume (and hence tha mass) of vocs used by Waston in
the FS is based on admissions by Valley/CSV in responae to an
information request and, to date, is tha only factual basis for
estimating tha amount of waste (Tiipnearl of historically.
waste *<~r*~»'i pxacticaa do suggast that this amount ssy ba higher.
ttoila EPA racngnJ7iis that disposal of this voluna or tha actual
undatar&inad voluna ououiTad ovar tha pariod of at least 17 yaars and
that migration and attenuation has obviously uuuuued, it believes this
estimate to ba adequate for tha evaluation of alternatives in tha IS.
While attempts can ba nada to estimate tha present sess of contaminants
on the site, they are gross estimates at best since they assu
entrations over a substantial volume of soil and that the
concentration onsite has been detected. EPA believes that it is best to
determine the actual mass of contaminants in soil based on the operation
date collected during tha treatability studies and implementation. In
any event, the relative comparison of tha alternatives is tha same. EPA
believes that tha estimate provided by Vallcy/QC's consultant is low
based on the fact that 1300 pounds of VXS were recovered during the SHE
demonstration [13,000 pounds of carbon having bean exhausted (with in
estimated efficiency of 10%)]. Valley/CMC's calculations would only
leave 450 pounds remaining onsite, which would require very little time
to recover with vacuum extraction and union probably would have
recovered in their performance of tha ongoing treatability study.
The SITE and treatability study results indicate that ERA'S
cleanup goals could be achieved using fewer vacuum extraction walls than
are proposed by ERA.
Ihe purpose of the feasibility study was to develop a
lign with enough detail to evaluate each alternative's
reliability, and engineering feasibility, and perform a comparative
analysis with respect to tha seven statutory criteria. The VES yiaeented
by Weston in the feasibility study is based on Weston's analysis of this
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technology. Weston did not have information from the SITE prajiam
demonstration. Further, this technology as presented is a design that
Weston inplements, and nay not be similar to the design of Terra-Vac or
any other vendor. EPA anticipates that the results of the SITE
demonstration, and the treatability study being performed by Valley/GRC
under the Consent Order Mortification, will fora the basis for the final
design. In any event, the BOO defines this remedy in terns of
performance standards and cleanup periods.
Qjnimrit 3. Removal of noils in the vicinity of the underground storage
tanks is not necessary; cleanup of the soils is achievable using vacuum
extraction. EPA also does not have authority to order removal of the
soils as the regulations cited by EPA are either not yet in force or not
applicable.
EPA Response; This ROD does not require removal of soils, subsurface
systems or the underground storage tanks. EPA anticipates that
these items may be addressed, if necessary, under the environmental
programs such as RCRA Part 265 or the Underground Storage Tanks program.
Oament 4. EPA has set target cleanup levels for soil based upon
calculations intended to achieve certain contaminant concentrations in
groundwater. EPA should define soil cleanup target levels in response to
actual cleanup results in order to accurately determine impacts upon
groundwater.
EPA Response; Indeed, this ROD establishes soil cleanup goals for the
protection of groundwater, and to achieve the cleanup goals established
for groundwater. Based on the relevance and appropriateness of the
Maximum Contaminant Levels (Mds) prcnulgated under the Safe Drinking
Water Act, the groundwater cleanup goals are based on these contaminant
specific MCLs. The area of attainment for these objectives is everywhere
on the Property. Consequently, the soil cleanup goals have been
established based upon soil/water equilibrium using the most conservative
assunptions. This would reflect a worst case scenario at the site of
static equilibrium and partitioning between the soil and water phase.
The equation for this calculation is presented in the FS in Section 2.
Statements relative to the soil cleanup goals being based on ARARs have
been clarified to reflect that no chemical-specific ARARS exist and that
the soil cleanup goals are based on achieving the groundwater ARARs under
the worst cas* site conditions described above.
The area of attainment for the soil cleanup goals is everywhere on the
Property corresponding to the groundwater area of attainment. These
levels are to be achieved unless it is determined that they are not
necessary to achieve the groundwater cleanup goals.
Garment 5. The rate of groundwater reinjection proposed by EPA for high-
rate groundwater treatment will result in flooding of the unsaturated
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cent and interfere with tha operations of tht vacuum extraction system.
Target cleanup goals can also ba ast using fewer extraction and injection
ERA supports its contractor's determination of tha rate of
groundwatar recovery/recirculation for tha selected groundwatar treatment
remedy. Although a groundwatar recharge test was perfumed at tha site
by valley/<3C, this only supports determination of a feasible injection
rate in tha absence of pumping, which is a part of tha
ERA'S objective in selecting a "high-rate11 groundwatar
which differs frcn the alternatives involving "low rate11 by
upgradient reinjecticn to accelerate contaminant removal frca tha
saturated zone, is to achieve tha groundwatar cleanup goals as
aoQjaditicusly as is technically feasible with a high-rate of aquifer
restoration.
ERA believes that the actual design rate for recovery/recirculation can
only be appropriately determined after performance of aquifar pumping as
wall as recharge tests, which will be performed as part of tha remedial
design worK.
Qjiiheul 6. ERA lacks the authority to require use of carbon treatment on
air emissions frcn the groundwatar air strippers since no Federal air
emissions limitations and no promulgated State air emissions limitation
are applicable to the air stripper.
ERA does not have to justify all aspects of a selected
action on the basis of ARARs. In addition to attaining ARARs,
remedial actions must, by statute, be protective of human health and the
environment and meet other requirements.
ERA believes that vapor phase carbon adsorption on the air stripper is
required to be protective of the environaant and satisfy the CEROA
statutory preference for treatment that permanently reduces toxicity,
mobility or volume of hazardous substances and constituents. It is
unacceptable to remove contaminants frca ens madia and transfer all or a
portion of them to another media. This does not reduce mobility, but
Imansas it. ERA further believes that such control aay ba naoassary
for protection of human health, as there are people residing within 100
feet of the site and that point of discharge. Further consideration is
given to tha fact that tha Canaonwealth is a "nan attainment11 area for
under the dean Air Act. VDCs are precursors to ozone pollution
With respect to ARARs, tha Massachusetts Air Quality Program, 310 OW
7.00, requires si Emission of a Plans Application for all new or uputadad
sources of VDC emissions. These plans aust include description of
piopmad pollution control equipment. Although there are no regulations
governing an allowable emission rate, Massachusetts has consistently
applied a policy of requiring tha use of the Bast Available Control
Technology (BACT) f or aU new or upgraded MX emissions
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EPA has determined that such a requirement is in the ARAR category of To
Be Considered material and therefore requires use of vapor phase carbon
adsorption to be functionally equivalent with this policy.
The foregoing discussion also applies to the use of carbon adsorption for
the vacuum extraction system.
7. ERA's initial calculations determined that the levels of
inorganic contamination were below levels of concern. A later amendment
to the Remedial Investigation essentially confirms this determination.
Given that levels of arsenic and chromium are below background levels,
and that maximum contaminant levels for copper, lead and cadmium are only
proposed, there is no technical or legal basis to require cleanup of
inorganics.
EPA Response; EPA believes it was necessary to perform an additional
endangerment assessment for several reasons. First, since the *iff» of:
the EA performed by Alliance in 1986 and 1987, EPA modified its approach
to the remedial action cleanup goal attainment boundary at the "property
boundary" to an area of attainment as "everywhere on the property." This
is based on the classification of this aquifer under the EPA Groundwater
Protection Strategy and a determination that the requirements of the Safe
Drinking Mater Act are relevant and appropriate to remedial actions at
Valley. The Alliance EA also required modification based on new
toxioological data for the indicator chemicals, and increased
concentration of trichloroethylene from a previous high of 120 ppm to 150
ppm.
Of greatest inportance was the necessity to include the inorganic metals:
arsenic, cadmium, chromium, copper, lead and mercury. All of these were
detected in groundwater samples from wells within the building material
storage area above MCLs. Based on these concentrations and the intrinsic
toxioological properties of these compounds, they were appropriately
selected as contaminants of concern.
ERA believes these inorganic compounds are present in the material
storage area well above the background levels in the area as exhibited by
samples collected at the Valley Site in August 1988 from TW-22,
upgradient of the building and in the Mill Pond area in October 1987 from
EBQE 1-4, in which all these compounds were not detected.
Die presence of inorganic contamination at the Valley Site is
attributable to historic manufacturing operations and ^spncai Of waste
cutting oils containing these and other hazardous substances in the truck
veil subsurface *tigr"c*l system, Brite-Dip
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adequate opportoiity to wtait
DLJtaBBDM* 1W» MO doaa not aalact a ravady for inorganic
oontaainaticn. Father, EEA ha* dataxminad that incidental inorganioa
traataant is naoaaaazy to ocnply with Haaaachuaatts grcmdwatar discharga
•tandazda. Grcunduatar tiaatiaiit for inorganics say'also ba
for tha affidant Iraifaanf of organic ccntssination.
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IV. RBAINDC CCNCB96
At the JUly 26, 1988 public informational meeting and at the informal
public hearing held in Groveland en August 9, 1988, EPA representatives and
local residents and officials disruwri issues of community concerns as the
cite neves into the design and implementation of EPA's selected remedies for
the Valley Source area at the Groveland Nells site. These issues and con
are described briefly along with EPA ccranents on how the Agency intends to
address these concerns.
(A) Citizens remain concerned about off site contamination resulting from the
contamination at the Valley Area. Resident concern is focused on the
possibility of additional veil and groundwater contamination and the long term
uses of town wells.
EPA Response; The Agency will address the contamination in the Mill Pond/
Johnson Creek watershed and aquifer, and the management of migration, in the
next phase of the Groveland Nells Superfund site cleanup.
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KEXATICK5 ACTIVITIES
XT IBB
a'THE aoreuioNexis SDPBVGND sxs
IM CTCVELAND,
Camnunity relations activities conducted at the Valley Source area of the
Groveland Wells Supertund site have included:
o JUly 28, 1987 - EPA Issued a public notice announcing the upcoming
public meeting on EPA's proposed demonstration of vacuum extraction
at the site under the auspices of the Super fund Innovative
Technology Evaluation (SITE) Program.
o July 1987 - EPA released a fact sheet on the vacuum extraction •
demonstration project.
o July 29, 1987 - EPA held a public meeting to allow interested
parties to cement on EPA's proposed dencnstration of vacuum
extraction.
o June 1988 - EPA released a fact sheet announcing the completion of
the vacuum extraction pilot study.
o July 1988 - EPA issued a public notice to announce the tiny and
place of the Feasibility Study (FS) and Proposed Plan public
informational meeting for the site and to invite public uiuuuiil on
the FS and Proposed Plan.
o July 1988 - EPA mailed the Proposed Plan announcing EPA's preferred
alternative for addressing contamination at the site and the results
of the Supplemental Remedial Investigation and the Endangerment
Assessment to all those on the site mailing list.
o July 27, 1988 - EPA held a public informational meeting to discuss
the results of the FS and the Proposed Plan.
o July 27 - August 16, 1988 - EPA held a public comment period on the
Proposed Plan.
August 9, 1988 - EPA held an informal public hearing to
nts on the remedial alternatives evaluated in the FS and
Proposed Plan.
o August 11, 1988 - EPA announced an extension of the public cxuiuent
period through August 26, 1988.
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ATTACHMENT B
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UNITED STATES OF AMERICA
ENVIRONMENTAL "PROTECTION AGENCY
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§!
6 I Hearing in the Matter of:
7 ]' GROVELAND SUPERFUND SITE
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10. jj Tuesday
!i August 9, 1988
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|j Groveland Town Halll
12 i; 185 Main Street
Groveland, Massachusetts
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The above-entitled matter came on for Public
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16 I, Meeting, pursuant to Notice at 7:15 p.m.
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19 f BEFORE: LINDA MURPHY
l! Chief
20 !; Environmental Protection Agency
; Massachusetts Waste Management Branch
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JAMES CIRIELLO
23 Regional Project Manager
Environmental Protection Agency.
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APEX Reporting
Rtgistrrtd P'offsiional Reporters
(617) 426-3077
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.INDEX
DPRSKRTD PAGE
Linda Murphy ' 3
James Ciriello 4
APEX Reporting
Registtred Profrstiunal Reporters
(617)426-3077
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PROCEEDINGS
2 (7:15 p.m.)
MS. MURPHY: My name is Linda Murphy, I'm the
Chief, Massachusetts Waste Management Branch at EPA, and I
implement Superfund for Massachusetts sites. And with me
tonight is Jim Ciriello, who's the Regional Project Manager
for the Groveland Superfund site.
8 The purpose of tonight's hearing is to accept
9 comments on four aspects of EPA's plan to clean up the Grovelan
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site. Those aspects being the proposed plan itself, the remedial
investigation of the contamination problem, the endangermefit
assessment of the contaminants, and the feasibility study j
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of the cleanup alternatives. . j
The public consent period officially runs frcn j
Juty 27th to Aught 26th. We're accepting connents crally en !
the record tonight. We will accept comments in writing if j
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they're postmarked to our Agency by August 26th. Tonight j
we would like to limit comments on the record to actual comments
19 | as opposed to questions
20 j> The proposed plan was mailed to people on our
21 j; mailing list on July 22nd, and if you're not already on our
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mailing list, just by signing up tonight, you'll be included.
And if you know of any neighbors or other people that should
be on the mailing list, you can add them to the list tonight.
On July 26th we had a public meeting which
APEX Reporting
Registered Professional Reporters
(617)426-3077 **
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Jim attended, I didn't attend it myself, but Jim attended
that public meeting. It was an informal meeting, to explain
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the proposed plan to the public and to answer questions about
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the plan.
The reports that I mentioned before, which
6 we're accepting comments tonight on, those being the remedial
7 investigation, the feasibility study and the endangerment
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8 ! assessment, were released into the record on August 5th, and
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they're available at two locations. What's the location in
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Town, Jim?
MR. CIRIELLO: The repositories are the library
and the Town Clerk's office.
KS. KURPHY: .They're also available at our
office at EPA in Boston on Canal Street.
The format for the hearing tonight it that |
we're going to have a formal transcription made of any commentsj
that are entered into the record, and that transcript will |
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be available at the formal repositories and at our office. !
We'll open the hearing with a short summary
of the proposed plan, even though this isn't a public meeting
per se, for those of you who missed the public meeting, Jim's
going to give a very quick summary of the proposed plan for
your information, then we're going to accept public.comments
on the record. If anybody does make comments, we may ask
them clarifying questions.
APEX Reporting
RegittrrtJ Pr^psional Reporters
(617)426-3077
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Following that, we'll close the hearing and
the transcript will end, and we'll kind of have an informal
public meeting again to answer any questions that you might
have.
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All comments submitted, whether they're oral
submissions tonight or written submissions during the public
comment period, will be categorized, they'll be summarized
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8 ;! and responded to, and those responses will be mailed to the
9 I; people on our mailing list. So if you make a written comment
10 | or an oral comment, you may not get an individual letter :
!; responding to your individual comment, but you will get a • i
i; response that's included in the responsiveness summary. . ~ i
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So I think I will turn the meeting over to
Jia Ciriello, who's going to describe EPA's, very quickly,
EPA's proposed plan for cleanup of the Grcvel&r.d site.
MR. CIRIELLO: Thank you, Linda. One point,
I think, that Linda pointed out was that the comment period has
extended to August 26th, which is 21 days from the time that
i
19 J! the reports were put in the record August 5th. That's en
ii
20 i; extension from what was the rational proposed plan.
|i
21 [I I just want to briefly review the proposed
22
23
24
25
plan. The proposed plan is EPA's, is a plan which sets out
EPA's preferred alternative for the cleanup of the Valley
site on Washington Street.
This proposed plan and preferred alternative
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1
2
3
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6
deals solely with the Valley Manufactured Products Company
facility, which is on Washington Street, located above Mill
Pond. It's an action known as a source-control action.
Over the last couple of years, EPA has performed
some various studies, feasibility studies of the Valley property,
along with the Valley Company, and most recently, Valley
completed a remedial investigation of contamination of the
8 j! property and EPA completed an endangerment assessment and
Ij
9 ' a feasibility study, based on the remedial investigation work
1C- i that Valley had conducted.
11 ;; The recedial investigation located at the Valley
12 I site, showing it in relation to Center Street, Washington
•13 Street, Valley sits in a residential area, those square blocks
u ; are houses, and St. Patrick's Church is down on Center Street.
15 ! The reaedial investigation WES conducted to
1;
16 J! define the nature and extent of contamination, the source
i
u i- of contamination on the property, and to identify soil and
I!
IB i' groundvater contamination. The endangerment assessment is
19 |T an evaluation based on the results of the remedial investigation
20
21
22
23
24
25
combined with the risk that the site poses to the environment
and to public health.
Basically, we have found through the remedial
investigations that there is groundwater contamination, soil
contamination on the site, primarily in one area, on the
southern side of the building known as the material storage
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1 '] I
jj area. The contamination principally consists of volatile organic
I compounds in soil and in groundwater.
3 i| *' • "
Based on the endangerment assessment and the
I assessment of the risk that the site posed, we've established
5 four broad cleanup objectives. Those are to prevent ingestion
ii . *
6 jj of contaminated groundwater on the property or downgradient
7 i' of the property and prevent direct contact, ingestion of
i>
•i
8 || contaminated soil on the property, prevent inhalation of volati
9 ' organic compounds that might occur upon excavation of the
j '
i
1 V >:
10 j: property, and prevent migration of groundwater contamination
11 ;; into groundwater from the property, contaminating downgradient
j-
'2 : water supplies.
!
'3 Based on those general objectives, we've esteb- j
' .." ' i
'* lished actions, or identified actions which reed to take piece !
15 on the property as part of remedial action to prevent exposure
16 • by those four routes shown on the previous slide, and those |
i
17 ; three actions, generally, are to treat and remove the source I
18 of soil contamination, treat and remove any source of soil :
I \
19 j! contamination, it would be something like the septic system I
i i
20 i: or a spot of soil that had a high concentration of contaminants
21 ji treat or remove the soil, and to treat the groundwater to
22
23 The Feasibility Study is the document prepared
24 by EPA which evaluates various cleanup technologies, treatment
I;
achieve standards which we've adopted as our target levels.
25
technologies for groundwater and soil, and the Feasibility
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Study performs • detailed evaluation of various alternatives
which addrets both soil and groundwater contamination.
3 In the Feasibility Study as outlined in' the
4 proposed plan, we evaluated in detail six alternatives for
•
5 achieving our objectives of cleaning up the Valley site, and
6
the six alternatives are shown here on this slide.
7 As part of the Feasibility Study, EPA has
e "
8 |! established target cleanup levels, which appear in the FS
ii
9 : Report. These target cleanup levels are largely based on
i1
1°' j: existing standards, existing drinking water standards in
r
l<
11 ", groundwater, and that is maximum contaminant levels or proposec
12 :: maximum contaminant levels, those come out of, they're i
12 established in the Safe Drinking Water Act, and EPA has '
'i I
'* established those as our target clesr.up levels for groundwaterJj
15 ;• The target cleanup level for soil is based j
i; |
16 :; on achieving those target cleanup levels in groundwater. i
I*
17 ~ That is, the remedial action level for soil is the soil i
18
19
20
21
22
23
24
25
concentration that would not exceed the concentration in !
i
i
groundwater. j
In order to achieve those target levels, we've j
, developed six, or five alternatives, principally. The first
alternative is no action, which is a base-line alternative.
The other five alternatives will achieve those target levels,
but at different, within different time frames.
And there are two principal treatment systems
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proposed The first treatment system is an in situ treatment
2
system, it treats the soil in place, it's known as vacuum
3 !'
j| extraction. Vacuum extraction is something we've discussed
ij in the past, in that we did a demonstration under the Superfund
Innovative Technology Evaluation Program of the vacuum extraction
!!
5
system last winter.
We have two alternatives involving vacuum-extrac•
6
7
8 5
0 •• tion which will treat the soil in the same order of time, that
9 !; I
: is 10 years, to the target levels, and with each of those vacuum
|i
10 ji extraction systems we have two different rates of groundwater
11 "• treatment. 1 1
12 j,: The high-rate groundwater treatment system is a j
12 treatment system which would, it's projected, would treat the •
i
groundwater on the site withir 10 years, the lew-rate groundwat'er
IS
treatment system would require substantially longer than 33 years
i
The low-rate treatment system is a passive system, which simply
17 - collects the groundwater migrating from the site, treats it, aijd
IB i discharges it downgradient. The high-rate system involves some
'•: I
19 I recirculation of groundwater to accelerate the flushing process..
ii
20 i; The other treatment system that was considered
21
22
23
24
25
is an above-ground treatment system for soil, known as low-
temperature thermal stripping. That involves excavation of
the soils that are contaminated on the property, processing
the excavated soils through a low temperature, on the order
of a couple of hundred degrees Fahrenheit, treatment system
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to volatilize, to drive off the volatile contaminants with
heat, and then soils, after being treated, would be replaced
in the excavation.
We have two alternatives involving above-ground,
low-temperature thermal stripping. Each of those involve
the same, the hight-rate and the low-rate groundwater treatment
!' system, it's the same configuration as it is with the vacuum
•i extraction system.
;i
;l
;' And the last alternative, or the fifth treatment
i
1C •; alternative is an alternative involving excavation of on-site
;i - : I
11 • soils and off-site treatment and disposal of those soils,* j
12 . backfilling the property with clean borrow. j
13 Those are the six alternatives we've conducted j
'lŁ •• a detailed analysis on. j
15 : The preferred alternative, EPA's preferred i
*'
16 ;• alternative as presented in the proposed plan, is the second j
17 |. alternative, involving vacuum extraction in place and high- i
,: - I
18 !' rate groundwater treatment system. With this alternative, !
19 |; we expect, or project remediation to take place within 10 j
20 I years.
21 |' In evaluating these six -- in evaluating the
22
23
24
25
I seven alternatives, EPA considers a number of factors to do
a comparative analysis of the six alternatives, and the factors!
that are involved are overall protection of human health and
environment, compliance with other environmental laws, the
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1 I
long-term effectiveness of the alternatives and the permanence
2 I
of the alternatives. The amendments to the Superfund Statute
require, essentially, or contain cleanup goals and require
ji that we attain all of the standards, requirements, criteria
of all of their environmental laws. Hence, we've established
target levels as being at what's equivalent to drinking water
7
!; standard for groundwater. And the other thing that the
S '•
|: Superfund .amendments require is that we have a preference
9 '•'•
for permanent remedies, permanently reducing the toxicity,
i; mobility and volume of the contamination, to get us away from !
11 •; relying on land-disposal options and so forth. So we evaluated'
12 ;; alternatives which will permanently reduce or eliminate the
* * * * !
.'" ; contamination on the property, both in soil and grouncwater. j
: I
:A : Another factor that's used in the comparative :
•• i
15 ' analysis is the short-term effectiveness, which is the effectivje-
i; ' !
16 j ness of, during construction, during the actual remedial action,
._ • i
17 i are there any adverse impacts on human health environment !
18 j! from actually implementing it. With something like excavation,;
19 i; there might be some short-term effects that would be considered
20 J; in comparing it to something in situ which doesn't involve
i-
21 ji excavation.
22
23
24
25
Implementability is also another factor used
to evaluate these. Is it administratively implementable and
is it also technically implementable? Is the equipment
available, can you meet the necessary equivalence of permits
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that wtre required? And a final factor would be the coat,
capital and O&M coat, operation and maintenance coata.
3
These factors are in the propoaed plan,*known
aa the Nine Critetia. I juat described aeven of them. The
laat two criteria are atate acceptance and community acceptance
We evaluate, in our decision for aelecting an action and an
altrnatlve, we evaluate community acceptance and atate acceptance
8 i1
i; Your comments tonight and your comments in writing go into
9 >'
i. this factor known aa community acceptance in our aelecting
1tr | a remedy for the property.
n •, Just briefly, the preferred alternative that
i:
12 :' EPA's presented, again, involves vacuum extraction for aoil,
.12 this is a very simple schematic of a aoil vapor vacuum ,
'•• I
ii '
*•* : extraction system, which involves the installation of extraction
15 wells above the water table in the uns'eturated soil zone, I
: ' I
:
16 | monitoring wells, again above the water table. There'a a j
i* ;
17 ! vacuum pump which ia shown as No. 5 here. The vacuum pump j
16 ! creates a vacuum, essentially, on the extraction wells, drawing
i.
!' I aoil vapor out of the wella and from the ground into the wells
I!
20 J! That vapor ia drawn through carbon, in this caae, for absorption
21 I of the contaminanta out of the vapor, and then the clear vapor
22
23
24
25
or treated air ia discharged to the atmosphere. This ia similar
to the configuration that waa in place at Valley during our
demonatration thia winter.
The groundwater system simply involves groundwate
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M I
recovery wells .in the water table, the groundwater is pumped '
! from the ground, and in this configuration and in our
3
alternatives, groundwater is passed through an air-stripping
A \
chamber where the volatiles are stripped from the water, air
is discharged after going through activated carbon. The
groundwater is then, depending on whether it gets recharged
•• above — whether it gets recharged into the ground for further
si'
ji collection or if it gets discharged out of the site area,
!i
9 ;
if it gets discharged out of the site area, the water would
10
n
12
12
M,
go through activated carbon for further treatment and then
: j
discharged. It would be discharged at a drinking water standard
essentially. Water that's passed through the site again,
doesn't have to achieve those levels, and would then go through,
i
i
the sir stripper alone and then beck through the systea to j
i: I
15 i be recovered once again. !
16 j! That's it for the slides. j
17 j . That's a very quick version of the two treatment)
18 I systems, or the preferred alternative which involves treatment :
19 ij for soil or treatment for groundwater.
\
20 MS. MURPHY: Okay, thank you, Jim.
Again, we're going to accept public comments
for the record at this point in time, and following the public
comments, we're going to close the transcript officially and
we'll have an informal meeting, so if you have questions about
21
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Jim's presentation and you don't want to make a formal comment,
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we're available to answer those questions.
We didn't have anybody who signed the index
card, is there anybody who would like to make a public comment
for the record at this time?
5
(No response.)
MS. MURPHY: I think we'll close the record
for the moment.
I
;• (Whereupon, at 7:32 p.m., the hearing was
9 I
concluded.)
10
II •
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12 !:
12 =;
i!
15
16
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20 }
F
21 ii
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CERTIFICATE OF REPORTER AND TRANSCRIBER
This is to certify that the attached proceedings
before; LINDA MURPHY
in the Matter of:
GROVELAND SUPERFUND SITE
Place: Groveland, Massachusetts
Date: August 9, 1983
were held as herein appeirs, and that this is the true,
accurate and ccrr.plete transcript prepared from the notes
and/or reccrdines taken of the above titled proceeding.
V Paemuscon fl/12/RR
Reporter Date
J. Rasnmssen B/12/8B
Transcriber . Date
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ATTACHMENT C
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NUTTER.McCLENNEN & FISH
ONE INTERNATIONAL PLACE
BOSTON, MASSACHUSETTS 02110-2699
«t? 439-2000
TUEX M-WO nuCOMIR »rTTJ-r>4l
September 1, 1988
2843-92
FOR INCLUSION IN THE EPA VALLEY SITE ADMINISTRATIVE RECORD
VIA HAND DELIVERY
Mr. William Walsh-Rogalski
Assistant Regional Counsel
U.S. Environmental Protection Agency
JFK Federal Building - RRC-2003
Boston, Massachusetts 02203-2211
Re: Comments of Valley Manufactured Products Company,
Inc. and Groveland Resources Corporation on EPA Valley
Site Pro-posed Plan
Dear Bill:
Please find enclosed the complete and final comments of
Valley Manufactured Products CoTtipBiry, Inc. and Groveland
Resources Corporation on ZI'A's Valley Site Proposed Plan. The
comments now contain a section discussing inorganics, as well
as a new Appendix G. Formal changes were made to the cover
page and table of contents.
As stated in my letter to you September 1, I stand ready,
as do my clients' consultants, to meet with representatives of
EPA to discuss the contents of the comments and any other
issues pertaining to remedial action at the Valley Site. It is
my hope, and that of my clients, that careful and serious
consideration by EPA of these comments (together with the
balance of the Valley Site Administrative Record) will yield a
selected remedy of a scope responsive to the conditions
actually observed at the Valley Site, as described in the Lally
RI and SRI reports.
HYANNH • AMSTERDAM HOVTHOFT WTTO McCLCKNEN
COUNSEL: LONDON • TOKYO
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NUTTEB, McCLZNKEN * FISH
Mr. William Walsh-Rogalski
September 7, 1988
Page Two
If you have any questions or comments, please feel free, as
always to contact me.
Very truly yours,
JZ1
in C. Pentz
MCPrccd
2166C
Enclosure
cc: XJames S. Ciriello, Remedial Project Manager
(with enclosure)
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COMMENTS OH THE
VALLEY SITE PROPOSED PLAH
Submitted by
Valley Manufactured Products
Company, Inc.
Groveland Resources Corporation
September 7, 1988
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TABLE OF CONTENTS
I. INTRODUCTION 1
II. CLEANUP OF VOLATILE ORGANIC COMPOUNDS 3
A. Soil Cleanup - Vacuum Extraction 5
1. Volume of VOCs in the Unsaturated
Zone 5
2. Design of Vacuum Extraction System:
Radii of Influence of Vents 12
3. Leaching Fields, Underground Storage
Tanks 15
B. Soil Cleanup - Selected Target Levels 18
C. Groundwater Cleanup - "High Rate" Groundwater
Treatment 22
1. Volume of VOCs in the Saturated Zone 23:
2. Technical Practicability of 30 GPM
Treatment System 27
3. Carbon Treatment of Air Stripper Vapor
Emissions 28
III. INORGANIC CHEMICALS 31
A. The Alliance EA and EPA's Response 33
B. The CDM Amendment 35
C. Selected Target Levels 37
D. Cleanup of Inorganics 38
APPENDIX A - Estimation of Volume of VOCs in the
Valley Site Unsaturated Zone
APPENDIX B - August 23, 1988 Letter from Mary K.
Stinson, Project Manager, EPA Risk
Reduction Engineering Laboratory to
Counsel for Valley and GRC
(i)
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TABLE OF CONTESTS
APPENDIX C - On the Prospect that • •Pool* of TCE
Exists in the Unsaturated Zone Beneath
the Valley Building
APPENDIX D - August 31, 1988 Letter from James J.
Malot, P.E., President, Terra Vac, Inc. to
Counsel for Valley and GRC
APPENDIX E - Estimate of Volume of TCE in the Saturated
Zone
APPENDIX F - August 29, 1988 Letter from John L.
Falcone, Jr., M. Anthony Lally Associates,
to Counsel for Valley and GRC
APPENDIX G - Results of Groundwater Sampling and
Analysis - August 4, 1988 Sampling Round
(ii)
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I. INTRODUCTION
EPA has released a "Proposed Plan* announcing its selection of a
preferred alternative to address the presence of volatile organic
compounds ("VOCs") in soil and groundwater at the Valley
Manufactured Products Company, Inc. ("Valley") facility located at
64 Washington Street, Groveland, Massachusetts (the "Valley Site").
The Valley Site lies within the boundaries of the Groveland Wells
Superfund Site, which was defined and listed by EPA as a "National
Priorities List" site in 1982, under the Comprehensive Environmental
Response, Compensation and Liability Act of 1980 ("CERCLA"). Pub.
L. No. 96-510, 94 Stat. 2767 (1980).1X fififi National Contingency
Plan ("NCP"), Appendix B, 40 CFR Part 300, App. B. EPA apparently
has determined to treat the Valley Site as a discrete "operable
unit" within the meaning of §300.68(c) of the NCP, 300 CFR
§300.68(c), and has announced in its Proposed Plan an intention to
address other portions of the Groveland Wells Superfund Site "in a
separate investigation and cleanup action."
The Valley Site Proposed Plan was furnished to counsel for
Valley and Groveland Resources Corporation ("GRC*" the owner of the
Valley Site) and, by letter dated August 17, 1988, EPA advised
I/ Since the listing of the Groveland Wells Superfund Site on
the National Priorities List, CERCLA has been amended or
affected by a number of enactments, most recently and most
significantly by the Superfund Amendments and Reauthorization
Act of 1986 ("SARA-), Public Law 99-499, 100 Stat. 1613. All
references in these comments to CERCLA are to Public Law 96-510
as amended through SARA.
-------
counsel for Valley and GRC of certain additional determinations
intended to form a part of the Proposed Plan, as well as certain
corrections to and clarifications of natters discussed in the
Proposed Plan as originally released. The comments set forth-herein
were prepared after careful review by counsel and Valley and GRC's
technical consultants of the Proposed Plan (as amended) and all
underlying documents, including the remedial investigation ("RI")
and Phase X supplemental remedial investigation ("SRI") reports
prepared by Valley and GRC's consultant, N. Anthony Lally Associates
(•Lally-), the Valley Site endangerment assessment (Alliance, 1987)
and draft amendment thereto (Camp, Dresser fc McXee, 1988) and the
draft feasibility study prepared by Roy F. Weston, Inc. for EPA (the
•weston PS"). •
The comments in this document are quite detailed and are
intended to be constructive. Valley and GRC are principally
concerned that certain fundamental flaws in the Weston FS have
yielded grave miscalculations of the necessary design of and
expected costs for EPA's preferred technical approaches to both soil
and groundwater remediation. The purpose of these comments is to
point out the significant errors and deficiencies in the Weston FS
and to demonstrate the availability of alternative remedial designs
which employ the technology preferred by EPA and achieve a degree of
protection of human health and the environment equal to that of the
preferred alternative, but at vastly reduced cost.
- 2 -
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II. CLEANUP OF VOLATILE ORGANIC COMPOUNDS
The Valley Site Proposed Plan, as originally issued by EPA, sets
forth EPA's proposal of a cleanup plan consisting of two principal
components: soil vapor vacuum extraction to remove VOCs from the
soil strata in the unsaturated zone, and groundwater extraction,
treatment and reinjection to remove VOCs from the groundwater at the
Valley Site. According to the Proposed Plan, this two-pronged
approach "is designed to address VOC contamination in site soil and
groundwater, since VOCs are the major contamination problem detected
at the site." Proposed Plan at 7. While reference is made in the
Proposed Plan document to the detection of inorganic chemicals at
the Valley Site, and to the potential for pretreatment of extracted
groundwater to remove inorganic chemicals, the focus of the Proposed
Plan document clearly is upon VOC remediation.* Accordingly,
these comments are structured first to discuss cleanup of VOCs by
vacuum extraction and groundwater treatment, with discussion of the
evidence regarding the presence of inorganic chemicals at the Valley
Site reserved to a separate section, below.
In describing EPA's preferred alternative, the Proposed Plan
states that EPA preliminarily has recommended that "Alternative 2,
Vacuum Extraction/High-Rate Groundwater Treatment" as described in
2/ Indeed, the Weston FS, from which the preferred alternative
was selected, did not purport to address any cleanup of
inorganic chemicals, but "only technologies to remedy existing
VOC contamination at the Valley Site." Weston FS at 1-2.
- 3 -
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the Western FS "be used to 'address contamination at the Valley
Site.* Proposed Plan at 7. Further, EPA relies upon the detailed
cost estimates contained in the Weston FS in announcing the expected
costs of the selected remedy. Compare Proposed Plan at 7-8 with
Weston FS, Appendix B. Accordingly, any meaningful comments with
respect to the design and expected costs of the remedy recommended
in the Proposed Plan must be directed to the design description and
cost estimates contained in the Weston FS.
The discussion in the following subsections of these comments
will demonstrate that the Weston FS is fatally flawed in that iŁ
fails, in designing and estimating the cost of remedial
alternatives, to make adequate use of the extensive data base :
*^^VHM*"MBI'BH^^^^^"^nBH^^^^* M^^^B"MH^^^^^M^H^^^^^^^H^^^MnM*'MIVH^^^^MM^^MM^^^B^BW^^*iV^M^^M^Mi[^MW^**H>MMi^^HMI^^^^^M^i^^^^B •
developed in the course of the Lally RI and ^pj. in particular, it
will be shown that the failure of the Weston FS even to attempt an
estimate of the volume of VOCs presently in the soil and groundwater
at the Valley Site (based on ample data presented in the Lally RI
and SRI reports) has resulted in the preparation of unduly elaborate
and costly designs for the soil and groundwater treatment systems as
well as grossly exaggerated cost estimates for operation and
maintenance of those systems. Finally, a number of other errors,
omissions and unfounded assumptions of the Weston FS also will be
highlighted for their cumulative contribution of the excessive
design and expected cost elements of the preferred alternative.
- 4 -
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A. Soil Cleanup - Vacuum Extraction
As previously stated in correspondence to EPA, Valley and GRC
support the use of in-situ soil vapor vacuum extraction technology
to remove VOCs from unsaturated zone soils at the Valley Site.^
The discussion in this section therefore is not directed to the.
appropriateness of the recommended technology. Rather, Valley and
GRC, will endeavor herein to lay the groundwork upon which the
party(ies) undertaking the remedy (whether EPA or Valley and GRC)
can base (1) a cost-effective design of a vacuum extraction system
for the Valley Site, and (2) a reasonable estimate of the expected
costs of this component of the remedy.
1. Volume of VOCs in the Unsaturated Zone
In determining the appropriate design and expected operating
costs of a vacuum extraction system, one critical consideration is
I/ Valley and GRC view vacuum extraction as conceptually
similar to in-situ soil flushing/ with the exception of the
difference in the medium employed to strip VOCs from soil
particles (air versus water). Indeed, had EPA indicated a
preference for in-situ soil flushing, in accordance with the
recommendation contained in Lally's 1985 feasibility study
report (the "Lally FS") Valley and GRC would have supported
EPA's choice.
Hothing in these comments, therefore, should be construed
as a concession by Valley or GRC of the appropriateness of
EPA's refusal to rely upon the Lally FS in selecting a remedy
for the Valley Site. Furthermore, nothing in these comments
should be construed as an expression of agreement with the
conclusions stated at pages 3-17 to 3-18 of the Weston FS with
respect to the long-term protectiveness and technical
implementability of in-situ soil flushing at the Valley Site.
- 5 -
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the volvune of VOCs which the system will be required to remove. The
Weston FS expressly states that "[tjhe annual O&M costs for the
vacuum extraction system would be largely for carbon replacement,
based upon recovering 3,000 gallons of solvent." Weston FS at'
4-14.^ In basing an expected cost analysis on the premise that
"3,000 gallons of solvent" (presumably VOCs) are to be removed, the
Weston FS commits a fundamental and grave error, and proceeds in a
fashion inconsistent with the NCP and EPA's 1988 Draft Guidance for
Conducting Remedial Investigations and Feasibility Studies Under
CERCLA (the "1988 Guidance"), the result is an enormously inflated
and misleading cost estimate for vacuum extraction.
It is by now axiomatic that the two major components of the ;
RI/FS process, the remedial investigation and the feasibility study,
are interactive, that is, "data collected in the RI influence the
development of remedial alternatives in the FS, which in turn
affects the data needs and scope of treatability studies and
additional field investigations." 1988 Guidance $1*3 at 1-7. See
jBlSfi 1988 Guidance §4.1.1 at 4-2. See generally 40 CFR
S§300.68(d)-(h). Data generated through additional site
characterization and treatability studies are then used to further
define remedial alternatives, 1988 Guidance §7.2.1 at 7-5 to 7-6,
and "to refine cost estimates for remedial action alternatives."
1988 Guidance §7.2.3.5 at 7-24.
One significant category of data generated through an RI which
is to be used in defining and estimating the cost of remedial
I/ Insofar as the Weston FS considers volume for design
purposes, presumably the same assumed volume is used.
- 6 -
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alternatives is "the extent or volume of contaminated material."
1988 Guidance §5.2.1.2 at 5-6. Sfig also 1988 Guidance §7.2.1 at 7-4
to 7-5. Further, the 1988 Guidance, in illustrating typical data
requirements for remediation technologies, specifically lists '
"tcjoncentration of volatile compounds" as an example of data
required to evaluate in-situ vapor extraction of soils. 1988
Guidance, Table 6-1 at 6-5.
Clearly, then, one function of the Lally SRI properly should
have been to collect data defining the extent or volume of VOCs in
the unsaturated zone. This in fact was one stated purpose of the
SRI, see Administrative Order by Consent, U.S. EPA Docket No.
1-87-1091 (Region I) (the "SRI Order") §6 at 4, and the Lally Phase
I SRI report (together with the original Lally RI report) in fact
•
presents the necessary data upon which an estimate of the volume of
VOCs in soil can be made. Furthermore, the SRI Order contemplated
the performance of a soil treatability study, SRI Order, Appendix A
(workplan) at 14, and a soil vapor vacuum extraction treatability
study presently is underway at the Valley Site, in accordance with
Modification No. 1 to the SRI Order.* The data generated through
this study will permit any necessary refinement of VOC volume
estimates made based on presently available data.
Ł/ The SRI Order originally contemplated a soil flushing
treatability (or "leachability") study.
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Against this background, the capriciousness of the approach of
the Weston FS to estimating VOC volumes in the unsaturated xone
becomes manifest. While the Weston FS avoids reference to the basis
for its assumption that "3,000 gallons of solvent" will be recovered
by the vacuum extraction system, Weston FS at 4-14, one can only
conclude that it is based upon the statement made earlier in the
report that "[a] total of 3,000 gallons is estimated to have been
discharged to the environment . . .," Weston FS at 1-10 to 1-11.
That estimate, in turn, apparently is ultimately based upon anecdotal
accounts of past disposal practices given by persons employed at the
Valley Site at various times, accounts which reach back as many as
25 years. fififi Weston FS at 1-10 (referring to "information" in the
SRI Order).
•
Whatever the value of these historical accounts to an estimate
of the total volume of VOCs discharged at the Valley Site since the
screw machine operation was started, such a calculation sheds
precious little light upon the issue of concern in the context of
designing and estimating the cost of a vacuum extraction system,
viz.: what is the volume of VOCs presently existing in unsaturated
zone soils at the Valley Site? The answer to this question is
entirely absent from the Weston FS.
Furthermore, the substitution of the 3,000 gallon estimate for a
calculation of volume based on available data is simply insupportable
as a technical matter. To make such a leap, one must assume that
each and every gallon of VOCs discharged at the Valley Site, perhaps
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as many as 25 years ago, presently resides in unsaturated zone soils
within the Valley Site property boundaries. Such an assumption
flies in the face of the well-understood fate and transport behavior
of VOCs (particularly TCE) after release into the environment.'
For example, the approach of the Weston FS fails to account for
the expected loss of TCE to the atmosphere through volatilization,
from the ground surface after a spill or through soil strata after
liquid phase TCE penetrates the ground surface. Similarly, in
relying upon the 3,000 gallon estimate, the Weston FS fails to
account for migration of VOCs into the saturated zone, a phenomenon
•clearly recognized elsewhere in the Weston FS. In light of the
operation of these fate and transport mechanisms, a reasonably
reliable estimate of the presently existing volume of VOCs in the
Valley Site unsaturated zone can be obtained only by means of
calculations employing the soil and soil gas analytical data
presented in the Lally RI and SRI reports.
An estimation of the volume of VOCs in the Valley Site
unsaturated zone based upon presently available data is presented in
Appendix A to these comments. In the southeast region of the
building, where detected VOC concentrations have been highest, soil
analytical data from samples taken during boring activities are
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used.* For the area beneath the Valley building where soil gas
has been detected, but analytical data from soil borings are
unavailable, soil gas data are used, together with a data-based and
experimentally verified ratio of soil gas VOC concentration to* soil
VOC concentration, permitting estimates of VOC volume in this area
as well.2''
The result of the calculations contained in Appendix A is an
estimate that approximately 140 gallons of VOCs presently exist in
liquid or vapor phase in unsaturated zone soils at the Valley
Ł/ In order more fully to characterize the extent of
VOC-containing soils, the calculation of VOC volume in the
unsaturated zone in the southeast region of the building relies
in part upon certain djjLtt data obtained by Valley during the
course of EPA's Superfund Innovative Technology Evaluation
("SITE") project at Valley, in the course of which some eight
borings were driven in the area adjacent to the south wall of
the Valley building. Valley and GRC are informed that
validated data from these borings will be available as of
September 20, 1988. (See letter dated August 23, 1988 from
Mary X. Stinson, Project Manager, to counsel for Valley and
GRC, attached as Appendix B.) In the event that quality
assurance/quality control procedures have resulted in rejection
of any draft data relied upon in Appendix A, appropriate
refinements to the calculations may be made when the final
draft technical report from the SITE project is released.
Valley and GRC request that the SITE project technical report
be included in the Valley Site administrative record.
I/ The degree of accuracy of this calculation is, of course,
limited by the inherent limitations of soil gas analysis.
Valley and GRC request only that EPA consider this calculation
as an indicator of the order of magnitude of VOC volume in the
area for which this calculation is employed.
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Site. As noted, still further soil VOC concentration data
presently is being prepared from samples collected during boring
activities conducted under Modification No. 1 to the SRI Order.
When available, these data may be used to further refine the volume
estimate.
Calculation of the presently existing volume of VOCs in the
Valley Site unsaturated zone thus reveals that the 3,000 gallon
figure employed in the Weston FS for estimation of carbon costs for
the vacuum extraction system is wide of the mark by. mare. Ihjui ŁH
order oj[ magnitude. If the data-based calculation of VOC volume is
used to estimate carbon costs, as the NCP and the 1988 Guidance
require, then the present worth of such costs (assuming a 10-year;
operation period) should be estimated to fall below $100,000, even
if the 140 gallon figure is doubled.
The expected cost analysis on the basis of which a preferred
alternative is chosen can have a significant impact upon EPA
decision-making at a number of points in the RI/FS process and
beyond. For example, in exercising its discretion to enter into an
agreement with a private party to perform response actions, the
ability of the private party to meet the financial obligations
&/ It should be noted that the calculations in Appendix A do
nfit purport to account for any reduction in the volume of VOCs
in unsaturated zone soils at the Valley Site resulting from the
operation of the SITE program pilot vacuum extraction system.
All data .used were derived from samples taken prior to
operation of that system.
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associated with conduct of the remedy frequently is determined by
reference to the expected costs thereof, as estimated in the FS.
ŁŁ. 42 U.S.C. §122(f)(4) (in assessing the appropriateness of
settlement, EPA is to consider '[w]nether the remedial action will
be carried out ... by the responsible parties themselves.")
Valley and GRC submit that EPA reliance upon the expected costs for
vacuum extraction set out in the Weston FS would constitute a grave
error, in part because that analysis grossly overestimates carbon
replacement costs based upon a legally and technically insupportable
overestimate of the volume of VOCs to be recovered by the system.*7
2. Design of Vacuum Extraction System: Radii of
Influence of Venta
The Weston FS states, with respect to the preferred alternative,
that '[approximately 30 extraction wells would be located
throughout the area of significant soil contamination at the
southern end of the building." Weston FS at 4-9 . It is stated
that "[i]t was assumed that a vacuum could be induced within the
soil in a 15-25 foot radius surrounding each vent, and a 25-foot by
25-foot grid system was used to estimate that 30 vents would be
required." Weston FS at 4-9 to 4-10. As demonstrated below, a
design of a vacuum extraction system for the Valley Site based on
Ł/ The suggestion has been made that an undetected "pool" of
free TCE may exist in the Valley Site unsaturated cone. The
likelihood of the existence of such a "pool" is discussed in
Appendix C. It is concluded that the probability that such a
•pool" exists, and is of substantial sise, is extremely low,
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the assumptions stated in the Weston FS would contravene the NCP and
the 1988 Guidance, and would result in substantial undue expense and
interference with the operation of the Valley plant.
As discussed in the preceding section, the interactive RI/FS
process calls for input from RI to FS in the form of site
characterization and treatability studies. The preceding section
dealt with the failure of the Weston FS to make use of site
characterization data from the Valley Site RI and SRI in estimating
unsaturated zone VOC volume. This section deals with the failure of
the Weston FS to make use of treatability study data from the SITE
project and the treatability work presently.underway at the Valley
Site. I
As stated in the 1988 Guidance, "[t]he primary objectives of
treatability studies are: [(1) to] [plrovide sufficient data to
allow treatment alternatives to be fully developed and evaluated
during the detailed analysis and support remedial design of a
selected alternative [and (2) to] [r]educe cost and performance
uncertainties for treatment alternatives to acceptable levels so
that a remedy can be selected." 1988 Guidance §6.1.1 at 6-1.
Detailed evaluation such as that undertaken in Section 4 of the
Weston FS is premature and inappropriate where existing data, absent
a treatability study, is insufficient to achieve the two quoted
objectives. 1988 Guidance, Figure 6-1.
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At the Valley Site, • wealth of treatability data have been and
will be developed. The SITE program project has been completed and,
es noted* the data generated thereby is expected to be available by
September 20, 1988. In addition, a soil vapor vacuum extraction
treatability study presently is underway at the Valley Site. The
combined data output of these two studies should form a more than
ample basis for the design of the vacuum extraction system.
By contrast, a review of the Heston FS gives no clue with
respect to the basis for the design assumed therein. Whatever the
basis for the radius of influence figure quoted in the Weston FS
(15-25*), it is extremely unlikely that the radius of influence of
ADZ of the extraction wells will in fact be less than 35 feet at the
Valley Site and indeed there is reason to believe that many will
exceed that figure.
Appendix D to these comments contains a discussion, prepared by
Terra Vac, Inc., summarizing its experience at other sites where
vacuum extraction has been applied and venturing a preliminary
estimate of the radii of influence expected to be encountered at the
Valley Site. Given the relatively high permeability of the soil
strata at the Valley Site (excepting only the clay layer) and given
the fact that much of the area to be evacuated is "sealed" beneath
the concrete building slab, the Valley Site presents quite favorable
conditions for a relatively wide radius of influence of the
extraction wells.
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Valley and GRC believe that the results of the SITE study and
treatability study will demonstrate a need for few, if any,
extraction wells beyond those already installed to conduct the
remedy. These studies may yield data indicating other areas i-n
which the design discussed in the Weston FS may be scaled-back,
without sacrificing protectiveness, to yield a far more reasonable
capital cost. EPA is obliged to consider these data and to approve
a cost-effective design for the vacuum extraction system. See NCP
§300.68(i)(2) (40 C.F.R. §300.68(i)(2)) (in selecting the
appropriate "extent of remedy" the lead agency is to consider, among
other things, "cost").
3. Leaching Fields. Underground Storage Tanks :
The Weston FS asserts that "the proposed corrective action
regulations [RCRA §3008(u)] would apply to and require removal of
the underground storage tanks and waste disposal systems, including
all contaminated soils associated with the tanks and subsurface
disposal systems." Weston FS at 2-6. (Bracketed material in
original.) This statement is incorrect as a matter of law.
First, there is no RCRA section 3008(u). Section 3008(h)
authorizes the issuance of corrective action orders with respect to
interim status facilities, and section 3004(u) establishes
corrective action requirements for permitted facilities. Second,
the RCRA Subtitle C standards have no application to Valley's
underground storage tanks (USTs). Valley's USTs have at all times
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been used for storage of virgin products, not wastes, and therefore
are not subject to EPA jurisdiction under RCRA. Third, to the
extent that the quoted language purports to refer to EPA's proposed
UST regulations under sections 9001-9009 of RCRA (see 52 Fed. Reg.
12662 (April 17, 1987)), the language grossly misstates the
pertinent provisions. Those proposed regulations require closure ai
repair of a UST, and only if it is found to be leaking. (See
proposed 40 C.F.R. §S 280.61, 280.71(a)(2)). There is no
requirement that contaminated soils be removed; rather, the proposed
regulations merely require that a plan for "cleanup" be approved.
(See proposed 40 C.F.R. S 280.73.) Also, Valley and GRC question
whether proposed regulations are properly considered as relevant and
appropriate under Sl21(d) of CERCLA (42 U.S.C. S9"l(d)) when they
have neither been finalized nor adopted or followed as policy by EPA.
The Massachusetts Board of Fire Prevention Regulations, 527 CMR
9.00, also do not require the removal of any of Valley's underground
storage tanks; nor do they require the removal of any contaminated
soils. One of Valley's USTs is no longer in service. 'Since it is
located beneath a building it will be abandoned in place in
accordance with 527 CMR 9.21(1). Valley's other USTs, which are
still in use, will be tested and managed in accordance with 527 CMR
9.16-9.18.
The language from the Weston FS quoted above refers to
•subsurface disposal systems,* and thereby appears to state that all
soils associated with the former Brite-Dip and MDC oil/gas separator
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leaching fields must be removed and disposed of. However, we find
nothing in EPA's RCRA regulations to support such a conclusion.
Neither the corrective action requirements at 40 C.F.R. §§
264.100-264.101, nor the closure requirements at 40 C.F.R. § 264.280
contain any such standard. Cleanup of any VOCs in soils associated
with the leaching fields by means of vacuum extraction is entirely
consistent with EPA's RCRA regulations.^/
Since there is no basis, in law or otherwise, for the conclusion
of the Weston FS that the Valley USTs must be removed, this item
must not form a part of the preferred alternative or of any expected
cost analysis. Likewise, since there is at present no basis for
concluding that VOCs cannot be removed from leaching field areas by
means of vacuum extraction,.it is premature to assume that
excavation and off-site disposal of those materials will be
necessary to achieve cleanup goals or to comply with RCRA
regulations.
While the FS is silent on the issue, it has been suggested
that excavation and off-site disposal of leaching field soils
may be necessary on the ground that the vacuum extraction
system would not adequately treat these areas. No basis for
such a conclusion can be found in the documents underlying
EPA's Proposed Plan. As a practical matter, such questions are
best addressed in the context of monitoring the process of VOC
removal in the course of operation of the remedy.
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B. Soil Cleanup - Selected Target Levels
The Weston FS, as clarified and corrected by EPA's August 17
correspondence, recommends soil cleanup "objectives" by means of a
calculation which purportedly yields the soil concentration levels
for VOC "contaminants of concern" necessary to maintain the target
concentrations selected for the same chemicals in groundwater.
Since the figures generated by this calculation, while useful, do
not in fact reflect the real-world dynamic equilibrium between soils
and groundwater at the Valley Site, Valley and GRC submit that they
must not be employed as hard and fast standards by which the success
or failure of the cleanup is to be judged. Rather, Valley and GRC
suggest herein that EPA's soil cleanup objectives for the Valley :
Site be dictated by the conditions that develop as the cleanup nears
completion and monitoring reveals the actual equilibrium established.
The discussion of soil cleanup objectives in the Weiton FS
begins with a recognition that "[flederal regulations and guidance
do not provide specific cleanup objectives that are applicable or
relevant and appropriate for contaminated soils." Heston FS at
2-12. Likewise, no applicable or relevant and appropriate
Massachusetts cleanup standards are cited. The Valley Site soil
cleanup levels therefore are not based upon "applicable or relevant
and appropriate" federal or state standards ("ARARs"). Łtft $121(d)
or CERCLA (42 U.S.C. $9621(d)).
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The Western FS next notes/ based upon the Endangerment Assessment
(Alliance, 1987), that "soil exposure routes were not used in
establishing soil cleanup objectives, since no unacceptable risk is
posed by current Site conditions or operation." Weston FS at 2-13.
Accordingly, the cleanup objectives for soil are "'based on
evaluation of the potential impact(s) on groundwater quality'".
Weston FS at 4-4.
In order to determine the level of soil cleanup necessary to
assure no adverse impact on groundwater quality (i.e., to permit
maintenance of selected groundwater cleanup levels), Weston employs
a formula utilizing the partitioning coefficients (KQC) of the
various VOC "contaminants of concern," an assumed fraction of •
organic carbon in the soil and the selected groundwater cleanup
levels (the "Weston formula"). See Weston FS at 2-14. This
calculation yields the expected concentration of the various VOCs in
soils in contact with standing water, i.e., it yields soil
concentrations for a static equilibrium. Such figures would
describe accurately the equilibrium expected to exist between soil
particles and associated moisture in the unsaturated zone. They do
nflt accurately describe the dynamic equilibrium between soil VOC
concentrations in the unsaturated zone and groundwater VOC
concentrations in the saturated zone. The formula employed,
therefore, is ill-suited to EPA's purpose.
The Weston formula fails to take account of at least two
critical factors affecting the dynamic equilibrium between VOC
concentrations in unsaturated zone soils and VOC concentrations in
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saturated zone groundwater. First, and most importantly, water that
percolates through Valley Site soils contributes only a very small
fraction of the groundwater present in the aquifer underlying the
Site at any given point in tine. The great majority of that water,
of course, will have originated upgradient, off-site. By failing to
account for groundwater movement, the Heston formula ignores a very
significant dilution factor.
Furthermore, the Weston formula fails to account for the time
required for equilibrium to be established between soil and water in
the unsaturated cone. There is no basis for concluding that
percolation of water through the unsaturated cone occurs at a
sufficiently slow rate to permit the calculated equilibrium to be:
reached.
The expected cumulative effect of these two factors is that VOC
concentrations in groundwater will be maintained at the desired
levels notwithstanding substantially higher unsaturated zone soil
VOC concentrations than those generated by means of the Weston
formula. A simple examination of pertinent data confirms this
expectation.
According to the Heston formula, the ratio of TCE soil
concentration to TCE groundwater concentration should be 1.3:1.
Heston FS Table 2-1A (as corrected) . A comparison of average TCE
concentration values in the "source" region suggests that a higher
ratio is appropriate. These ratios are shown in Table I.
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TABLE I
TEMPORARILY AVERAGED
VERTICALLY AVERAGED GROUNDWATER
WELL SOIL CONCENTRATION fppm) CONCENTRATION fpoml RATIO
TW-9 703 80.92 '8.68
TW-16 30 3.44 8.72
TW-18 892H/ 66.9012' 13.30
Average: 10.24
The above analysis indicates that a ratio of about 10:1 for TCE
more accurately reflect the equilibrium reached under the dynamic
conditions actually prevailing at the Valley Site.
In view of the failure of the figures generated by means of the
Weston formula to reflect accurately the dynamic equilibrium
actually observed at the Site, a decision by EPA to treat those
figures as immutable standards by which the success of vacuum*
extraction is to be judged would be wholly arbitrary and
insupportable. A far more reasonable approach, sensitive to actual
Site conditions, would be to treat the figures produced by the
Weston formula as aspirational goals, with the proviso that, if
•
those goals are not reached by the vacuum extraction system,
groundwater monitoring will be conducted for a reasonable period of
time to determine whether groundwater VOC concentrations are indeed
increasing toward an equilibrium in excess of the selected
From estimate of volume of VOCs in unsaturated zone,
Appendix A hereto.
12/ From estimate of volume of VOCs in saturated zone,
Appendix E hereto.
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groundwater cleanup standards. Only if such changes were in fact
observed would there be any justification ~ under EPA's own
analysis — for the performance of additional soil remediation.
C. Groundwatfcr Claanuo — "High Bate* Croundwatar Traataaant
The preferred alternative includes a groundwater cleanup
component referred to as 'High Rate Groundwater Treatment." In
outline, the envisioned treatment system would pump groundwater from
a line of 14 recovery wells along the eastern boundary of the Valley
Site at a combined rate of 30 gpm to be fed into an air stripping
tower. Following air stripping treatment, 28.s gpm of groundwater
would be returned to the aquifer, upgradient of the extraction :
wells, through a set of reinjection wells, while 1.5 gpm would be
•
reinjected — after liquid phase carbon treatment ~ downgradient of
the Site. A total of 10 reinjection wells are.contemplated; and air
emissions from the air stripper are to be treated with vapor phase
carbon. Western FS at 3-7 to 3-8; Appendix B, Table B-5.
With certain significant exceptions discussed below, Valley and
GRC do not contest EPA's determination that a groundwater pumping,
treatment and recirculation system is an appropriate method for
removing VOCs from the groundwater beneath the Valley Site. With
respect to the design for this system described in the Weston FS,
however — particularly the 30 gpm pumping rate and the numbers of
extraction and reinjection wells ~ Valley and GRC take strong
exception, both on grounds of need (in terms of the volume of VOCs.
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to be removed) and technical implementability (in terns of the
capacity of the aquifer to accept reinjected water without affecting
the water table). Specifically, Valley and GRC will demonstrate
(1) that the target cleanup levels for groundwater can be reached
within 10 years (assuming technical feasibility) by means of a
treatment system with a pumping rate of 1 gpm, if a reasonable -
estimate of VOC volume is employed, and (2) that a 30 gpm pumping
rate cannot be used in any event since any pumping rate in excess of
7 gpm will cause flooding of the unsaturated zone and interfere with
the vacuum extraction system.
1. Volume of VOCs in the Saturated Zone; Necessary Pumping
Eats
As noted above, a critical factor in determining the appropriate
design and expected operating costs of remedial facilities is the
volume of "contaminant" the system will be required to remove. This
is no less true for groundwater remediation than it is for soil
remediation. While the Weston FS is strangely silent with respect
to any estimate of the volume of VOCs in the saturated zone, its
determination of a necessity of treatment for 10 years at a rate of
30 gpm reveals that, contrary to the NCP and 1988 Guidance, the data
generated through the RI and SRI once again have been ignored. The
result of this error is an unnecessarily elaborate groundwater
treatment design, an excessive pumping rate and exaggerated
operation and maintenance costs.
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The authorities discussed in Section II.A.1., above establish
that one purpose of the Lally RI and SRI properly should have been
to define the extent or volume of VOCs in the saturated cone. The
SRZ Order confirms that, indeed, this was one purpose of the SRI,
SRI Order, S* *t 4, and, indeed, sufficient data is available from
which an estimate can be made.
The Weston FS, however, makes no reference to any such
calculation. Perhaps this should not be surprising, in view of the
fact that Weston assumes that all 3,000 gallons it estimates to have
been discharged at the Site exist today within the unsaturated zone
soils. Of course, Weston does not seriously contend that that is
the case, since if it did, it could find no need for groundwater ;
remediation. Moreover, since Weston has seen fit not to disclose
the substance of the groundwater modelling it indicates it has
performed, Weston FS at 3-7 to 3-8, this avenue is of no help in
determining the saturated zone VOC volume assumed.^
12/ A rudimentary method of discerning the assumed volume is
to apply a per-gallon carbon cost derived from the vacuum
extraction cost estimate to the total carbon costs assumed for
groundwater treatment. The vacuum extraction carbon cost
estimate (initial and replacement) totals $708,370. Weston FS,
Appendix B, Table B-2. As noted, this cost is based on
recovering 3,000 gallons of VOCs. Thus, the per gallon carbon
cost is $236.12. The groundwater treatment carbon cost
estimate (initial and replacement) totals $208,000. Weston FS,
Appendix B, Table B-5. At a per gallon cost of $236.12, this
calculation yields an assumed saturated zone VOC volume of
if this or a figure of similar magnitude was used,
then the expected costs announced in EPA's Proposed Plan are
based upon the remarkable premise that 3,881 gallons of VOCs
are expected to be recovered where only 3,000 gallons are -
estimated to have been released!
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An estimation of the volume of VOCs in the Valley Site saturated
zone based upon presently available data is presented in Appendix E
to these comments." According to that estimate, only about li.s
gallons of VOCs (TCE and 1,2 trans-dichloroethylene) exist in the
saturated zone within the property boundaries of the Valley Site.
(A total of 99 gallons is estimated to be present in the entire
plume.)
Appendix F presents (in the form of a letter to counsel) the
results of computer modelling developed to determine the removal
rate of VOCs under various assumed groundwater pumping rates (30,
15, 5 and 3 gpm). In each case, it is assumed that 1.5 gpm will be
reinjected downgradient (accordingly, recycle rates are 28.5, 13.5^
3.5 and 1.5 gpm). In each case, a starting average VOC
•
concentration of 100 mg/1 (ppm) is assumed and the pore volume
quoted in the Weston FS (1.3x10. gallons) is employed. (Thus, the
model assumes a total Valley Site saturated zone VOC volume of
gallons, a figure far higher than the calculated volume.)
Appendix E also presents an estimate of the total volume
of VOCs in the "Valley Plume" as depicted in the 1985 ERT
Groveland Wells Site Remedial Investigation Report, should
off-site VOC volume be deemed relevant.
IS/ To convert 1.3xl06 gallons of water at 100 mg/1 VOC to a
volume of VOC, the concentration must be converted to a
volumetric basis by dividing the product of volume of water
times the volumetric concentration (1.3xl06 gallons • 100
mg/1) by the specific gravity of the VOC (taken in this case to
be the specific gravity of TCE, 1.46 mg/ml). Thus the volume
(Footnote Continued on Next Page)
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The model predicts that • 3.0 gpm pumping rate (1.5 gpm recycle
rate) will reduce total VOCs in the groundwater to 1 ppb (assuming
technical feasibility) within tha 10-vaar period prafarrad bj: EE&.
By contrast, a 30 gpm pumping rate is predicted to achieve VOC
cleanup goals within ojia zft&Ł* For purposes of comparison only, a
preliminary cost estimate for the 3 gpm system also is presented.
Appendix F, Table 5. The expected total cost for the 3 gpm system,
including operation and maintenance, is about AHA fifth of the cost
estimated for the 30 gpm system in the Heston FS.^/
The foregoing analysis, together with the referenced appendices,
demonstrates that the Weston FS has grossly overestimated the rate
of extraction of groundwater necessary to achieve the selected :
groundwater cleanup target levels within ten years. Furthermore, it
has been shown that a scaled-down 3 gpm treatment system can achieve
EPA's goals, within EPA's time frame, at about one-fifth the cost of
the 30 gpm system described in the Weston FS. In such
IS/ (Footnote Continued from Previous Page)
of VOC will be:
V » 1.3 x 106 gallons * 100 mg/1
1.46 W/ul * 10* »*/! ~
V • 89 gallons
!&/ The groundwater treatment system design described in
Appendix F assumes, for argument purposes only* that carbon
treatment of air stripper vapor emissions may properly be
required. As noted in Section III.C.3., below, Valley and GRC
question the authority of EPA to impose such a requirement.
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circumstances, a decision to select the 30 gpm system would be
wholly arbitrary and inconsistent with the NCP. ŁŁŁ 40 C.F.R.
§300.68(1).
2 • Technical Practicability of 30 GPM Treatment
Even if the installation and operation of a 30 gpm groundwater
treatment system could be justified as a matter of cleanup goals
(which it cannot) the employment of such a system nevertheless would
have to be rejected as technically impracticable, since any
recycling rate in excess of 7 gpm will cause the groundwater table
to rise substantially and interfere with the operation of the vapor
vacuum extraction system in the unsaturated zone.
In August 1985, Lally conducted a pump test at the Valley Site
during which test wells TW-19, TW-20, TW-21 and TW-22 were employed
as injection wells and groundwater elevations were recorded in a
number of other wells at the Site, including the wells located in
the storage area. The results of the pump test are set forth in
Table VI-1A of the Final Lally SRI Report.
During the test, groundwater levels rose sharply at injection
rates exceeding 7 gpm. For example, in the storage shed area,
groundwater levels rose over 5* (TW-9, TW-18). At TW-15,
groundwater rose over 12'. Moreover, groundwater levels had not
completely stabilized when the injection rate was reduced, so
equilibrium levels may be somewhat higher. An injection rate of
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30 gpm (more thin four times, the magnitude of the rite of the 1985
pump test) could result in groundwater levels ibfixfi the clay lena
where the highest TCE concentrations have been detected.
Since a 30 gpm pumping rate will cause a dramatic rise in the
water table, -flooding the unsaturated cone at the Site, and
interfering with the operation of the vacuum extraction system, the
•high rate" groundwater treatment system described in the Heston FS
must be rejected as technically infeasible.
3. Carbon Treatment of Air Stripper Vapor Emissions
The groundwater treatment system design presented in the Westbn
FS includes the use of carbon columns to treat vapor emissions from
the air stripper. It is presumed that this requirement has been
imposed based on the purported applicability of a "performance
standard" limiting ambient air concentrations of VOCs. Valley and
GRC submit that EPA lacks authority to impose this requirement since
no federal air emission limitation, and no promulgated Massachusetts
air emission limitation is applicable to the air stripper proposed
to be installed at the Valley Site.
While referring generally to the federal Clean Air Act and to
Massachusetts air emissions regulations (310 CMR §§6.00-7.00), the
Heston FS fails to cite to any air emission limitation specifically
applicable to VOC emissions from the operation of an air stripping
tower. Neston FS at 2-7 to 2-8; 2-11. Valley and GRC are unaware
- 28 -
-------
of any such standard under the Clean Air Act and can find no
limitation in 310 CMR §§6.00-7.00 which appears to be applicable to
an air stripping unit.
In light of the foregoing, Valley and GRC can only conclude that
the vapor phase carbon adsorption step in the preferred groundwater
treatment design is based on the purported applicability (or
"appropriateness") of an unpublished set of air emission
"limitations" known as "Allowable Ambient Levels* ("AAL"), which
apparently are maintained by the Massachusetts Department of
Environmental Quality Engineering. Since those AALs have not been
published in the Massachusetts Register or the Code of Massachusetts
Regulations, it is submitted that they do not have the force of law
and cannot be imposed upon Valley and GRC as "legally applicable"
standards. See CERCLA §121(d)(2)(A) (42 U.S.C. §9621(d)(2)(A)).
Furthermore, it is submitted that EPA is without authority to
impose a requirement of compliance with AALs on the basis that they
are "relevant and appropriate." Under §121(d)(2)(A)(ii) of CERCLA,
a state "standard, requirement or limitation" may be imposed as
•relevant and appropriate" only if it has been "promulgated." Ss&
42 U.S.C. §9621(d)(2)(A)(ii). Since the AALs have not been
promulgated, CERCLA does not furnish EPA with authority to require
- 29 -
-------
carbon treatment of air stripper vapor emissions in order to conform
to AALs for VOCs.12'
1Z/ A second concern of Valley and GRC with respect to the
design of the groundwater treatment system is its failure to
exploit the potential of the air stripper already operating at
Mill Pond to further contribute to groundwater cleanup. Valley
and GRC request that EPA give further consideration to this
option.
- 30 -
-------
III. INORGAHIC CHEMICALS
As noted at the outset of these comments, the Western FS did not
address the sporadic detection at the Valley Site of minute
concentrations of the inorganic chemicals arsenic, cadmium,
chromium, copper and lead (collectively, "the inorganics"). This
was a consequence of the fact that the original Endangernent
Assessment ("EA") (Alliance, 1987) declined to designate the
inorganics as "contaminants of concern" due to "their low
concentrations and low frequency of detection." Western FS at 1-22.
Apparently dissatisfied with the conclusion of the Alliance EA,
EPA first determined that the five inorganics would in fact be
designated as "contaminants of concern" And Ulfin commissioned Camp,
Dresser & McKee, Inc. ("CDM") to prepare an "amendment" to the EA
("Draft Amendment to the Valley Manufactured Products Company
Endangerment Assessment," CDM, 1988) purportedly re-evaluating
Valley Site public health risks, taking into account the
- 31 -
-------
inorganics. Finally, EPA, in its August 17, 1988 letter to counsel,
selected groundwater target cleanup levels for the inorganics. As
of the drafting of these comments, no soil cleanup target levels had
been selected for the inorganics and no particular approach to any
cleanup of the inorganics in soils had been discussed or
selected.1^
The discussion below will demonstrate that the conclusion of the
Alliance EA was correct: there is no sound basis for designating
the inorganics as "contaminants of concern." It will be shown that
the COM amendment to the Alliance EA in fact supports the conclusion
drawn by Alliance, and not that of EPA. Finally, it will be
demonstrated that EPA lacks authority to impose upon Valley and GRC
the chosen cleanup targets for the inorganics, both because observed
concentrations do not in fact exceed background levels and because
CERCLA does not authorize EPA to treat proposed regulations as ARARs.
IB./ As to the remedial approach for the inorganics in
groundwater, the August 17 letter states that "EPA's preferred
alternative involves removing and treating groundwater for VOCs
which would, by design, involve any necessary oil phase
separation and inorganics treatment." As discussed below,
however, results of recent sampling indicate that oil phase
separation will not be required, since no oil or grease
separation was detected in the sampled wells. Sfifi Appendix G.
- 32 -
-------
A. The Alliance EA and EPA's Response
The Alliance EA declined to list the inorganics as "contaminants
of concern* because (1) the concentrations detected did not exceed
expected background levels described in current literature, and
(2) inadequate analysis of inorganics had been performed in prior
investigations. Alliance EA at 2-7. Despite these conclusions, and
*
before the results of anv additional inorganics analysis of Valley
Site samples were available. EPA decided to designate the inorganics
as "contaminants of concern." EPA's purported reasons
for rejecting its own contractor's conclusion were (1) that the
Alliance EA did not calculate so-called "indicator scores" for the
inorganics, and (2) that Alliance incorrectly focused on two
monitoring wells, GZ-2 and GZ-3, which EPA found not truly
"representative" of Site conditions. CDM Amendment at 1. The
conclusions of the Alliance EA were correct; EPA's objections are
wholly without merit.
The conclusion of the Alliance EA has been borne out by
inorganics analysis conducted on samples taken on August 4, 1988
from monitoring wells selected by EPA for the purpose of
characterizing more completely the distribution of inorganics at the
Site, See SRI Order, Modification No. 1, Task 1. Appendix G
presents the results of this sampling round. Four of the five
selected inorganics (arsenic, cadmium, chromium and copper) either
were not detected at all or were detected only at concentrations
- 33 -
-------
below the selected target levels.< As to lead, which was
detected in only two of the seven sampled wells and exceeded the
current MCL at those two wells by only .01 and .03 ppm. Alliance's
conclusion that background has not been exceeded remains intact.^/
EPA's objections to the Alliance conclusions, by contrast, are
extremely weak. First, there is no requirement that "indicator
scores" be developed for all HSL chemicals detected at a site.
EPA's Superfund Public Health Evaluation Manual (1986) (the
"Manual") expressly states that "EPA recognizes that other
approaches [i.e., other than that discussed in the manual] may be
equally valid." Manual at 4. As stated in the CDM Amendment, :
Alliance's selection of "contaminants of concern" was based on
•consideration of the relative importance of a contaminants'
inherent toxicity, measured concentrations at the site, and physical
and chemical parameters related to environmental mobility and
persistence of each chemical." COM Amendment at 1. Surely EPA
does not contend that such an approach is inappropriate.
12/ Based on these results, and in view of the historic
pattern of infrequent detection of minute concentrations of
these four inorganics, arsenic, cadmium, chromium and copper
should be removed from the list of "contaminants of concern,"
even if EPA's endangerment analysis for the inorganics is in
all other respects valid (which it is not).
2Q/ Even if the reported lead concentrations in TW-8 and
TW-17 exceed "global" groundwater background levels, it should
be noted that both of these wells are in the area of the MDC
oil/gas separator and leaching field, which collects and
distributes run-off from Washington Street. The lead
concentrations detected in TW-8 and TW-17 are within typical
urban runoff parameters.
- 34 -
-------
Amendment serves only to underscore the correctness of the Alliance
conclusion.**
In discussing the hazard from possible ingestion of
"carcinogens" in groundwater, the CDM Amendment is careful to note
that "arsenic levels found in soils of the Valley Site are within
the background range for New England soils." CDM Amendment at 25.
Similarly, in discussing hazards resulting from ingestion of the
"non-carcinogens" in groundwater, the CDM Amendment states that
exceedence of a hazard index of 1 was "mostly attributable to
trans-l,2-dichloroethene." CDM Amendment at 9. The message is
clear that reduction of concentrations of trans-l,2-dichloroethene
alone to the selected VOC target level will reduce the hazard index
to an acceptable level.
Furthermore, the CDM Amendment takes a giant step backward in
failing to consider (1) the absence of any evidence of migration of
the inorganics, and (2) the real-world probability that a drinking
water well will be installed in the area where lead haS been
detected, a matter of a few feet from the manufacturing plant,
22/ It is difficult to discern the purpose served by the CDM
Amendment. Its purpose apparently was not to determine whether
the inorganics should be designated "contaminants of concern,"
since this was a fait accompli before its preparation. CDM
Amendment at 1. Nor did it generate target cleanup levels for
the inorganics. The selected levels are stated in the August
17 letter to be based solely upon MCLs, proposed MCLs and
proposed MCL Goals. One is compelled to conclude that the CDM
Amendment is little more than a post-hoc justification of a
decision already made.
- 36 -
-------
adjacent to the MDC manhole and oil/gas separator. On the first
point, there simply is no evidence of migration of the inorganics
on-site, let alone off-site. Given this fact, based on the analysis
results presented in Appendix 6, the only risk to be evaluated is
that of a person installing a drinking water well adjacent to TW-8
or TW-17 at the Valley Site, the probability of which is next to
zero.
The COM Amendment, if it serves any purpose at all, merely
confirms that the inorganics should not have been selected as
"contaminants of concern."
C. Selected Target Levels
EPA's August 17 letter establishes groundwater cleanup target
levels for the selected inorganics based upon MCLs for arsenic and
chromium (which are not being exceeded at the Site (fififi Appendix G))
and upon proposed MCLs for copper and lead and a proposed MCL Goal
for cadmium. Since the target levels for copper, lead and cadmium
are based neither upon a site-specific hazard assessment nor upon
ARARs, EPA has no authority to enforce them.
Section 121(d) of CERCLA authorizes EPA to establish cleanup
target levels based on "any standard, requirement, criteria or
limitation under any Federal environmental law, including . . . the
Safe Drinking Water Act . . .,"42 U.S.C. $9621(d)(2)(A)(i>, if the
- 37 -
-------
Second, EPA's position that monitoring wells GZ-2 and G2-3 are
not "representative* is irrelevant to the soundness of Alliance's
conclusion. Alliance simply did not rely solely upon GZ-2 and GZ-3
in concluding that the inorganics ought not to be designated
•contaminants of concern." Alliance EA at 2-7.
The sampling round recently conducted for the express purpose of
generating an improved database for inorganics in groundwater at the
Site demonstrates that the conclusion of the Alliance EA was
correct; the selected inorganics should not be designated as
"contaminants of concern."^*
B. The CDM Amendment
After erroneously concluding that the Alliance EA was flawed by
its decision not to select the inorganics as "contaminants of
concern," EPA commissioned CDM to amend the EA accordingly. The CDM
2I/ As to soil, the inorganics analysis performed on samples
taken from TW-26 as part of the SRI show soil concentrations of
the five selected inorganics at or below current MCLs. Lally
SRI, Appendix C, Soil Analytical Data. These results are
hardly supportive of EPA's decision to designate the five
selected inorganics as "contaminants of concern." Results of
additional soil sampling, which Valley and GRC have agreed to
perform as part of the vacuum extraction treatability study,
are not yet available.
- 35 -
-------
standard or limitation is either applicable or relevant and
appropriate. 42 U.S.C. §9621(d)(2)(A). SDWA authorizes EPA to
promulgate regulations, by means of appropriate administrative*
procedures, fixing MCLs and MCL Goals for drinking water. Until the
administrative procedure is complete, however, a proposed MCL or
MCL Goal cannot be a "standard ... or limitation . . . under
CSDHA].* To hold otherwise is to deny the role of the review and
comment process in establishing regulations. CERCLA cannot be
interpreted in a manner so fundamentally inconsistent with the
Administrative Procedures Act.
Since the cleanup levels for copper, lead and cadmium were
selected-by EPA based on standards which are merely "proposed," and
which have not been adopted or followed, EPA lacks authority to
impose such levels and must not make them a part of its Valley Site
Record of Decision.
D. Cleanup of Inorganics
Since the Proposed Plan does not select remedial alternatives
for cleanup of the inorganics at the Valley Site, Valley and GRC
obviously can make no comment on any such potential remedies. At
such time as EPA does propose a remedy or remedies, if any,
addressing the inorganics, Valley and GRC expect and demand that
they will be accorded an opportunity to submit comments, pursuant to
Sections 113(k)(2)(B)(ii) and 117(a)(2) of CERCLA. 42 U.S.C.
- 38 -
-------
§§9613(k)(2)(B)(ii), 9617(a)(2). For present purposes it will
suffice to state that, based on presently available data, EPA's
course of action with respect to inorganics at the Site should be
•no action." S&& NCP §300.68(f)(1)(v) (40 CFR §300.68(f>(l)(v)).
- 39 -
-------
TERRA VAC~?ARTIAL PROJECTS LIST
VACUUM EXTRACTION
SCIE
TOMS
SPILL
MOO*
ajimiND
scum
CMGUHt
HIOUON
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SUBCUO KW8* MOV 8t TOP 750 11*
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TCE
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OKSPIUM. JIM 84 MC 8S 90UKNIS 7,000 I7(
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taatB
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M) 300 llaulk
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Ri * Radius of Influence
-------
4697-J UU€5T UJflTgflS
ROPCfl 23434 • T6. (613; 885-5374
AUQUSt 31. 1983
Mr. Martin Cents
Attorney
Valley Manufactured Products
Urovaiand. MASS.
RE: U.adius ot Influence
Vailov Manufactured Products
Terra vac Project assj-4O5
Mi
ncqardino your rcouc-at. far inl ormAti.on on the? radius of
influence of vacuum extraction wells at valley we can bo con-
fident that tha radius of influence rxnonds at least i5 feet at
the ooen Field area outside the builoina and extends substan-
tially further in tho area beneath tnc building. This is based
on our extensive experience at applyinq this technology at more
than 3O rotes across the counr.rv t sec enclosed partial list) and
our cvocricncc with tha sit.a saccific subsurface conditions at
vnllcv and successful implementation of cho vacuum extraction
svs r.^m a t Val 1 c ;.
If you l-.avo any questions, please contact our firm at
your c&nvcriirr.i ice.
Very truly yours.
Jamos J. Malot. P.E.
President
cr: Joe
-------
APPENDIX A
ESTIMATION OF VOLUME
OP VOCS IH THE VALLEY SITE
UNSATURATED ZONE
-------
Section I; Introduction
The Lally Remedial Investigation (RI) and Supplementary Remedial
Investigation (SRI) reports contain compilations of soil sampling
data and soil gas sampling data which permit calculation of an
estimated volume of TCE in the Valley Site unsaturated zone,
including TCE that is sorbed to soil particles as veil as TCE
which exists in vapor phase in the interstitial spaces. Since
TCE is the major volatile organic compound (VOC) detected at the
Valley Site, a calculation of the volume of TCE in the
unsaturated zone yields a fair approximation of the total volume
of VOCs at the Valley site to be recovered through soil vapor
vacuum extraction.
The analysis set forth belov separately considers the volume of
TCE presently existing in (1) the area beneath and adjacent to
the southeast corner of the Valley building where soil borings
have been advanced and soil analytical data therefore are
available, and (2) the area beneath the Valley building for which
no soil borings have been advanced. (Other areas of the Valley
Site have been excluded based on soil gas sampling failing to
detect significant concentrations of TCE.) In those areas where
soil borings have not been advanced and soil analytical data
therefore are absent (Area 2), soil TCE concentrations are
calculated by reference to soil gas data and soil gas to soil
distribution coefficients. Where soil sampling data are
available (Area 1), soil concentrations are based on such data.
2310.137
-------
Section 2s tatination of Valum* of TCE in the Valley Site
Pn«aturated Zone in the Southeast Region of the
Vellev Building
Calculations were performed to determine the quantity of TCE in
tha unsaturated sone in tha araa of the Vallay Sita for which
•oil analytical data ara availabla. Tha calculation daacribad
balow estimates tha quantity of TCE in tha ragion naar tha
southeast aid* of tha building, vhara soil borings hava baan
advancad and soil aamples analyiad. To accomplish thia task,
chaaical analyaaa of aoil from boringa aada at tha aita vara uaad
to davalop a profila of TCE concentrations. Thasa data vara
collactad froa tha following sourcaa:
o Tha 1985 Lally RI Raport.
o Draft report of GC/MS purga and trap data
collactad in tha course of EPA 'a SITE vacuua
extraction project. March 19S8. (These data ara
expected to be available in final, validated fora
about Septeaber 20, 1988.)
Tha saaplaa froa tha various borings ware obtained over a period
of several yeara. To perfora this calculation, an assumption was
•ade that the aoil concentrations did not vary significantly
during thia tiae.
Tha total mass ofT«-±n^he unsaturatad tone beneath this ragion
ia estimated to bV^«84JcgJ»s shown in Table 2-1. ). Thia
converts to^lSOS^pcfuhdi , "which in turn converts to 124 gallons.
Thus, 1ŁT gafŁoas-
-------
account for the observed concentrations.
METHODx
The region covered by this calculation is depicted in Figure 2-1.
This region was broken into triangular sub-regions or "elements".
The corners (or "nodes") of these triangles were chosen to
coincide with the locations of the soil borings completed in this
area. The quantity of TCE in the soil within each element was .
estimated by multiplying the volume of soil beneath the triangle
by an average concentration of TCE in that volume. Soil volumes
were determined by multiplying the triangle area by an average
depth to the water table. These volumes are listed in Table 2-1.
The average depth was determined by averaging the reported values
for each of the soil borings. This depth is 38.3 feet. •
An average TCE concentration for each element was determined by
first calculating an average soil concentration for the boring at
each node, and then averaging these three nodal concentrations.
The nodal average concentration was determined by a simple
arithmetic mean of the measured concentrations at various depths.
For depth intervals where measured soil concentrations are not
available, soil concentrations were assigned. Assigned
concentrations were estimated by choosing the highest
concentration of the two adjacent depth intervals. For example,
if the measured concentration in the depth interval 0-2 feet in
boring B-8 was 610 ppm, and the concentration in interval 5-8
feet was 1600 ppm, then the interval 2-5 feet was assigned a
concentration of 1600 ppm. This estimate most likely biases the
overall calculation to show a greater quantity of TCE than is
actually present. Table 2-2 presents the average concentrations
for each of the/nodes.
2310.137
-------
The average TCE concentration for each triangular element was
then determined by calculating the o«on«trie Bean of that
element's nodal concentrations. This Bean is defined as:
c, * c,)
1/S
These values are presented in coluan 4 of Table 2-1.
The last coluan of Table 2-1 lists the mass of TCE in each
eleaent. These values were calculated by multiplying an
eleaent's voluae (a3) by its average concentration (ag TCE/kg
soil) and the bulk density of the soil (2000 kg/as).
2310.137
-------
FIGURE 2-1 MAP OF TRIANGULAR ELEMENT DISCRETIZATION OF
THE SOUTHEAST REGION OF THE BUILDING
TW-8
B-4
TW-3
B-2
VALLEY MANUFACTU'R
•PROPWCTS CO. INO.
EXT*1
EW1
EXT*2
^. VAC
V V0KIN6 LOCATIONS
A M9NIT01TINO WEU.
PVC WELL
5CALF : 1" « 20
TW-22
-------
Tabla 2-1
calculation of th« Quantity of TCI in Each llaaa&t
Zlaaant
Noda
Voluaa (•')
TCE
Geometric
Mean Cone.
Total
(kg TCE)
3
4
5
6
7
8
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25
26
27
28
29
1
2
30
31
32
7, 16, 14 1000
7, 3, 14 700
3, 14, 9 534
14, 13, 9 83
13, 9, 28 92
28, 9, 12 59
12, 9, 27 74
9, 27, 35 26
26, 27, 26 36
27, 35, 29 141
12, 27, 29 92
12, 30, 29 94
12, 28, 30 30
13, 28, 30 41
29, 30, 31 50
29, 31, 34 51.
31, 33, 34 93
30, 31, 33 92
30, 32, 33 78
13, 30, 32 88
13, 14, 32 63
21, 14, 32 263
36, 21, 32 287
36, 32, 33 51
33, 34, 36 94
14, 16, 21 832
16, 21, 20 936
20, 16, 37 1100
37, 16, 7 1350
3, 38, 9 900
38, 9, 26 250
35, 38, 26 325 — >
-
33.5
36.4
62.2
266.0
50.2
20.2
26.8
11.9
3.8
7.8
28.0
69.1
38.8
96.2
19.3
3.2
1.0
6.0
27.3
242.4
392.0
191.5
28.7
6.6
1.4
80.0
15.9
3.7
3.5
3.3
4.9
1.4
... . Total
67 « fc
51
66.4
44.2
9.2
2.4
4.0
0.6
0.3
2.2
5.2 :
13 •
2.3
8.0
1.9
0.3
0.2
1.1
4.3
42.7
49.4
101
16.5
0.7
0.3
133
30
8.1
9.5
5.9
2.5
0.9
• 684.1
•s. c.i to
-------
Table 2-2
Average Concentration* at Element Vodea
Node
3
7
9
12
13
14
16
20
21
26
27
28
29
30
31
32
33
34
35
36
37
38
Boring
Name
B-ll
TW-15
TW-16
B-l
B-9
TW-18
TW-17
B-8
B-3
EW 2
KW 2
EW 3
EW 1
KW 3
KW 1
EW 4
KW 4
EX 1
EX 2
B2
B4
TW-22
Average Soil
Concentration (ppa)
9
6
30
46
703
892
7
7
82
4
14
6
34
211
1
96
1
1
1
3
1
1
-------
Section III; Estimation of Voluaa of TCE in the Vallev Sita
Dnsaturated gene in Areas Beneath the Vallay
Building Mhare Mo Sell Berinua Have B«en
In the area under the Valley building where no soil borings have
been advanced, the amount of TCE present in unsaturated sone
•oils can be estimated by reference to the soil gas
concentrations beneath the building slab and the equilibrium
relationship between soil gas concentrations and soil
concentrations. This calculation was perfoned as described
below utilizing the soil gas data contained in the Lally SRI
report and soil analytical data from the Lally RI report.
ftZSULTS
The total mass of VOCs estimated to be present in the soil gas
beneath the Valley building (in areas where no soil borings have
been advanced) is 155 grams, about equal to 5 ounces.
Based on equilibrium considerations, the total volume of TCE
estimated to be sorbed to soil particles in the unsaturated cone
beneath Valley building fin areas where no soil borings have been
advanced) is 13.8 gallons.
An equilibrium condition exists between TCE adsorbed to the soils
and TCE in the soil gas beneath a relatively impermeable surface
such as the concrete slab of the Valley building. Determination
of this partitioning coefficient (i.e. the ratio between soil gas
concentration and soil concentration) allows one to use soil gas
2310.137 8
-------
data to estimate the Bass of TCE under the building where no soil
boring data exists.
This ratio was determined by comparing soil gas measurements and
the chemical analyses of soil samples from borings TW-15 and B-ll
which are the closest to the area being estimated by this method.
This comparison is presented below.
Boring Identification TW-15 B-ll
Mean soil TCE
in ppm. (from Table 2-2) 6 9
pp
Mean soil DCF concentration
in ppm (calculated as for TCE) 0 1
Total Soil concentration 6 10
TCE, DCE in ppm
Mean of soil gas concentration
TCE, DCE in ppm at points 28, 29,
30 (area of TW-15) 293 ---
Mean soil gas concentration
TCE, DCE in ppm at points
IS^JISR, 29, C2 (area of B-ll) --- 296
Ratio of soil gas concentration
(ppm) to soil concentration (ppm) 49:1 30:1
The average of these ratios yields an equilibrium partition
coefficient of 39.5.
This partition coefficient can be used to estimate the likely
concentration of TCE in unsaturated zone soil at the Valley Site
for each point at which soil gas was collected and analyzed. It
is assummed that, because the soil has been covered by the
concrete building slab for about 15 years in most areas, the soil
and soil gas are in equilibrium.
2310.137 9
-------
Figure 3-1, a plan of the Valley building, depicts and identifies
by assigned number all soil gas sampling points in the vicinity
of the Valley building. -Tigure 3-2 indicates for each sampling
point shown in Figure 3-1 the total concentrations of TCE and
dichloroethylene (DCE) detected during sampling in August and
October, 1987. Finally,figure 3-3 depicts the discretisation of
the area for vhich soil concentrations vere estimated based on
•oil gas analysis results. As shown in Figure 3-3, the soil gas
saapling points within the building were used as nodes to plot
triangular areas for which geometric mean concentrations were
calculated for both soil gas and soils.
MOTE: Soil gas concentrations utilized were averages of two
values where the soil gas sampling point was sampled twice. The
concentrations of TCE and DCE (dichloroethylene - the anaerobic
biodegradation product of TCE) in the soil gas were expressed as
TCE. This sum was then used to calculate the amount of TCE and
DCE in the soil.
Table 3-1 sets forth the nodes of each triangular area, the
volume of soil beneath each area to a depth of 29 feet (the
average water table depth in July 1988 in nearby wells 115, 11,
16, and 23) and the corresponding soil weight and soil gas volume
at 25% porosity. Column 7 lists the geometric mean soil gas
concentration calculated for each triangular area, followed by
the total volume of VOCs calculated to be in each area. The
total volume of VOCs in the entire area is 0.37 cubic meters of
TCE vapor which is equal to 155 grams of TCE liquid or about 5
ounces.
Similarly, Table 3-2 sets forth the same triangular areas and
•oil volumes and the estimated soil concentrations which vere
2310.137 10
-------
calculated by application of the soil gas/soil partition
coefficient of 39 as the following example indicates:
For triangular element 18, mean soil gas cone. - 194 ppm TCE, DCE
Soil Gas ppm « 39 • 194
Soil Cone, ppa l Soil Cone.
therefore, Soil Cone. » 194 « 5 ppa
39
These estimated soil concentrations were multiplied by the mass
of soil in each triangular area (to the unsaturated depth of 29
feet) to obtain the mass of TCE + DCE (VOCs) in each.area, the
results of which are shown in the last column of Table 3-2.
Finally, all amounts were totaled, the result being 76 kg of
TCE/DCE - 13.8 gallons.
Laboratory Experiment
To validate the soil gas to soil partition coefficient of 39, a
laboratory experiment was designed and performed. The data and
calculations shown in Table 3-3 are the result of this experiment
designed to measure soil gas and soil concentrations under
controlled laboratory conditions similar to that under the Valley
building.
Procedure - Clean soil from the Valley Site was placed in vials.
Known amounts of TCE were then deposited onto the soils and the
vials were capped immediately. After waiting 2 days for the TCE
to reach equilibrium, the headspace of each vial was analyzed for
TCE. Following this analysis, TCE in the entire contents (soil
and soil gas) was extracted with methanol and analyzed for TCE.
This information allows one the calculate the soil concentrations
and the corresponding soil gas/soil concentrations ratios as
2310.137 11
-------
shown in Table 3-3. Tha ratios obtained by this axpariaant ware
91:1, 282:1, and 73:1.
Tha antira ranga of soil gas/soil partitioning coafficiants
•aasurad by various aaans is: 30, 49, 73, 91 and 282. Tharafora,
tha valua of 39 froa borings B-ll and TW-15 appaars to ba a
raasonabla but consarvativa choica for usa in calculating
astiaatad soil concantrations froa aaasurad soil gas
concantrations.
2310.137 12
-------
55 52
A A52
v49
56 A5I A50
37
n
••I i
V
A
104
c
••
* Ai 1
^— ^ 0 15 30 49l' 60 feet'
^/ %A ^V ' • I . i • 1
^^^ J locations not surveyed
-
45 46 47
A 41 4IR A A
•A
40 14 39 87 42
36 «38 • • • A •
92
A
•
22
^93
•v _ .
A9I w 2 1
• hipping
•Blfl*M>
• •
24 25
A94 .23 .26
26R
A95
20R 18 17
i Mn *
"20
1 1
1 1
•
FICUR™-'
Soil Gas Samp) ing
Point Numbers
A 10/87 sanpling point
• 8/87 sanpling point?
12 13 89 10 ^90
*A* *
101
9 7
6
•
A 100
88 43 89 44
A •
A
97
A
•
m
w
• 27 «BB «30 32
16 15 .29
• ^LV • f ft F
m I5R
T Original will b»IUInt «aN
!
1 A '
Oflle**
I
1 j ^
Valley Manufactured Products j
Groveland.MA j
96
^ »^
/
^xVV '
__ •
A31
3IR
I?
s|
—
44
.
33
•C2
\
\
-
5 "
98
19 ^9,
1
A
10]
2 •
3 .
4«
•••• » y«
•%
.
-------
fiO
r •? 3o •» «* f~*
•0
DCE and TCE
in PPM
October Sampling*
August Sampling
valley Manufactured Products
Washington Street
» - resuft fro* gas baR
analysis
-------
FIGURE 3-3 MAP OF TRIANGULAR ELEMENT DISCRETIZATION OF
UNSATURATED ZONE BENEATH THE BUILDING
VALLEY MANMFACTHKEP
PR0PMCT5. GKOVELAHV, MA
WASHINGTON
to rr
Y////A AREA EVTIMATEP vr SOIL UOKINCW
X^X AKEA5 ESTIMATE!? »V Soil. CA0 KE5ULT5 * 9OIL/SOtL CAS
• »/57 SAMPLING TVINT5
A 10/»7 «AMfLINQ
-------
TABLE a-i
CAT-OTLATTON OF VOC« TM SOTL CXS FOR EACH ELEMENT AND TOTAL
Triangular
Element
1
2
3
4 '
5
6
1
8
9
10
11
12
13
14
15
16
7
18
19
20
21
22
23
24
25
26
27
28
29
30
31
36
36
22
22
24
23
23
25
25
27
88
15
15
15
27
27
27
18
18
94
94
21
21
20
16
16
16
29
35
3
21
Hod**
93
22
93
24
94
24
25
26
27
28
28
28
29
28
16
16
17
17
23
18
20
20
91
17
17
35
35
15
29
35
20
91
93
94
94
18
25
26
27
88
88
28/30*
28/30*
28/30*
27
15
17
26
26
26
20
93
93
93
96
96
96
15
35
3
96
96
Soil voluaa soil gas
(cubic voluna
•etars)
1086
687
397
722
745
483
490
406
566
390
232
186
269
327
302
339
371
608
469
434
452
408
357
1076
432
302
209
195
993
689
457
TOTAL TCE
TOTAL TCE
Geometric
•tan moil
(cu. asters) gas-ppa
&X*'9
271
172
99
180
186
121
122
102
142
97
58
46
67
82
75
85
93
152
117
108
113
102
89
269
108
75
52
49
248
172
114
VAPOR VOLUME
1.9
3.4
38.4
41.3
116.5
87.7
194.4
194.4
13.0
21.3
229.2
358.7
259.4
253.1
173.9
132.8
234.9
261.9
249.7
152.9
69.2
40.7
9.0
114.8
109.5
56.0
93.2
98.1
20.3
16.4
46.5
(CU.B) -
(VOC») IN GRAMS -
Cubic
••tars of
TCE vapor
0.0005
0.0006
0.0038
0.0074
0.0217
0.0106
0.0238
0.0197
0.0018
0.0021
0.0133
0.0166
0.0175
0.0207
0.0131
0.0112
0.0218
0.0398
0.0292
0.0166
0.0078
0.0042
0.0008
0.0309
0.0118
0.0042
0.0049
0.0048
0.0050
0.0028
0.0053
0.37
155
Nota: * indicatas that tha avaraga soil ga* concentration of 128
and 130 was uaad to describe this location vhara tharf
vara no soil gas valuas.
2310.137
16
-------
TABLE 3-2
CALCULATION OF VOCs IN SOIL IN EACH TRIANGUIAP ELEMENT AND TOTAL
Triangular
Eleaent
1
2
3
4
5
6
7
8
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25
26
27
28
29
30
31
36
36
22
22
24
23
23
25
25
27
88
15
15
15
27
27
27
18
18
94
94
21
21
20
16
16
16
29
35
3
21
Modes
93
22
93
24
94
24
25
26
27
28
28
28
29
28
16
16
17
17
23
18
20
20
91
17
17
35
35
15
29
35
20
91
93
94
94
18
25
26
27
88
88
28/30*
28/30*
28/30*
27
15
17
26
26
26
20
93
93
93
96
96
96
15
35
3
96
96
Soil Vol.
in cubic
aeters
1086
687
397
722
745
483
490
406
566;
390
232
186
269
327
30Z
339
37*
608
469
434
452
408
357
1076
432
302
209
195
993
689
457
TOTAL VOCs
TOTAL VOCs
Soil Vt.
in 1000
Kg, /^
2172'
1373
793
1443
1489
965
979
812
1132
780
464
371
538
654
603
! 677
I 742
1216
937
868
905
817
715
2153
863
603
418
390
1986
1378
914
(Kg) -
(gallons
Mean soil Total
TCE cone. TCE
(ag/kg)
t
0.050
0.087
0.984
1.058
2.987
2.248
4.985
4.985
0.334
0.545
5.878
9.196
6.652
6.489
4.458
3.404
6.024
6.714
6.401
3.921
1.774
1.045
0.231
2.942
2.808
1.435
2.389
2.515
0.521
0.420
1.193
) -
Kg
0.11
0.12
0.78
1.53
4.45
2.17
4.88
4.05
0.38
0.43
2.73
3.41
3.58
4.25
2.69
2.31
4.47
8.16
6.00
3.40
1.61
0.85
0.17
6.33
2.42
0.87
1.00
0.98
1.04
0.58
1.09
76.8
13.8
Note: * indicates that the average soil gas concentration of 128
and 130 vas used to .describe this location where there
were no soil gas values
2310.137
17
-------
Table 3-3
Experimental Soil/Vapor Partitioning Data and Calculation*
Experiaental Conditions 5 ul TCE as ul TCE 100 ul TCE
in 40 al vial 20 g soil 20 g soil 20 g soil
Readspace Concentrations 11.5 no: TCE
aeasured by GC
Readspace concentration
in ag/a*
Readspace concentration
in ppm at 20°C
Mass of TCE in soil and
headspace at equilibrium
(extracted in Methanol and
analyzed by GC/Hall)
Mass of TCE aeasured by
CC in 32.5 al headspace
ul air
Mass of TCE in soil by
subtraction
2100 ppm
833 ug
374 ug
459 ug
33.5 no TCE
ul air
33,500BS
aj
6140 ppa
1525 ug
1089 ug
436 ug
Soil Concentration
ug TCE/20 g soil
23.0 uq » ppm
9
Headspaee Cone. Ratio
Soil Cone.
91:1
21.8 ug - ppm
9
282:1
51.3 no TCE
ul air .
51.300 BO
9500 ppm
4274 ug
1667 ug
2607 ug
130 ug - ppm
9
73:1
*20 grams soil per vial - 2.651 grams/ml soil density - 7.5 ml
soil volume. Therefore air volume in headspace • 32.5 ml.
1Buc)onan and Brady, "The Nature and Properties of Soils",
Macnillan, 1969, p. 52.
2310.137
18
-------
APPENDIX B
AUGUST 23, 1988 LETTER FROM
MARY K. STINSON, PROJECT MANAGER,
EPA RISK REDUCTION ENGINEERING LABORATORY
TO COUNSEL FOR VALLEY AND GRC
-------
RECEIVED
*i UNITED STATES ENVIRONMENTAL PROTECTION AGENcAUG 2 9 1988
' RISK REDUCTION ENGINEERING LABORATORY
REPLY TO:
Releases Control Branch
U.S. EPA (MS-104)
Woodbrldge Avenue
Edison, New Jersey 08837
August 23, 1988
Mr. Martin C. Pentz
Nutter, McClennen & F1sh
One International Place
Boston, MA 02110-2699
RE: Freedom of Information Act Request No. 5277-88
Dear Mr. Pentz:
I This 1s 1n reference to your letter of July 1, 1988 to
John S. Farlow 1n which you requested documents on the SITE Terra Vac
project under the Freedom of Information Act. Your letter has been .
assigned the EPA Freedom of Information Act request number of
5277-88.
As Steve James and I discussed with you 1n the respective phone
conversations of mid July, we will be glad to provide you with the
documents you requested. However, not all of these documents have
been prepared to date. Thus, I presently enclose the documents we
have, and I will send you the remaining documents by September 20,
1988.
The enclosed documents are:
1. A demonstration plan entitled, "Demonstration Test Plan In-s1tu
Vacuum Extraction Technology Terra Vac, Inc. SITE Program
Groveland Wells Superfund SITE, Groveland, MA" dated October 5,
1987.
2. A paper presented at the 14th Annual Research Symposium on Land
Disposal, Remedial Action, Incineration and Treatment of
Hazardous Waste, May 9-11, 1988, Cincinnati, Ohio entitled "Terra
Vac In-s1tu Vacuum Extraction Process SITE Demonstration."
-------
The documents to be delivered to you by September 20, 1988 are:
1. A draft technical final report from the demonstration of the
Terra Vac process under the SITE program. (This document will
contain both the presentation and discussion of all pertinent
data generated 1n the course of the Terra Vac project).
2. A paper to be presented on September 21, 1988 at the Haztech
International Conference 1n Cleveland that will discuss the
results from the SITE demonstration of the Terra Vac process.
As the EPA Project Manager for the Terra Vac SITE demonstration
project, I appreciate your Interest 1n this technology. Thus, 1f I
can be of any further assistance to you please feel free to contact
me anytime. My direct phone number 1s (201) 321-6683.
Sincerely yours,
*, K !K<
Mary K. Stlnson
Physical Scientist
Technology Evaluation Section
Enclosure
cc: John S. Farlow
Steven C. James
Robert N. Carr, FOI Coordinator
Jeralene B. Green, A 101
Cynthia A. Holley, RD 674
James 5. CiMello, Region I
Peter A. Michaels, El
-------
APPENDIX C .
OH THE PROSPECT THAT A "POOL1
OF TCE EXISTS IN THE
UNSATURATED ZONE BENEATH
THE VALLEY BUILDING
-------
It has been suggested that there may be a "pool" of free TCE in
the unsaturated zone at the Valley Site. The implication is that
one must take account of this possibility in calculating the volume
of VOCs to be recovered through the vacuum extraction system.
For a "pool" to exist the degree of soil saturation with TCE
would be about 90 to 100% (accounting for some retained water in the
zone of the pool). The highest TCE concentration detected, however,
(2,500 ug/g (ppm) in B-9) represents a degree of saturation of only
about 1%, well below that which would be expected if a "pool"
existed.
If a "pool" of TCE exists at the Valley Site in the unsaturated
zone, it clearly has not been encountered in any exploration to
date. The issue, therefore, is whether it is likely that a pool of
significant size exists and has, by chance, been missed. It is not.
First, there is reason to believe that the highest concentrations
of TCE in the unsaturated zone at the Valley Site have, been
detected. Boring B-9, in which a TCE concentration of 2,500 ppm was
detected at a depth of 10-12', is in the storage shed area of the
building downstream of the tank which was reported to have released
approximately 500 gallons of TCE. Further, the 10-12* depth
corresponds with the top of the clay layer, which is believed to
have impeded downward movement of TCE and diverted it easterly
-------
•cross the clay. Yet the degree of TCE saturation of the soil at
this point is only about 1%. Since the TCE retention capacity of
the soil is 2.5 to 4.0%. TCE at the highest observed concentration
is immobile — an observation inconsistent with the existence of a
freely moving "pool.*
Furthermore, the existence of the postulated "pool" is
contradicted not only by direct observations (as from borings) but
by indirect observations as well. Neither the extensive soil gas
sampling survey nor the SITE project vacuum extraction work have
suggested the presence of a "pool."
Based on the above, it is felt that the probability of the
presence of an undetected TCE "pool* of substantial size in the
unsaturated zone is infinitessimally small. Any "pool* in the
unsaturated zone would likely be quite small and would not
contribute greatly to the total volume of TCE.
1894C
- 2 -
-------
APPENDIX D
AUGUST 31, 1988 LETTER
FROM JAMES J. MALOT, P.E.,
PRESIDENT, TERRA VAC, INC. TO
COUNSEL FOR VALLEY AND GRC
-------
APPENDIX E
ESTIMATE OF VOLUME OP TCE
IN THE SATURATED ZONE
-------
The volume of TCE in the groundwater (both in solution and
adsorbed) was estimated by integration of average observed
concentrations at wells in the Valley plume as depicted in the
ERT RI, figures 5-25 through 5-27 (Volume I). The procedure
was as follows:
(a) The sum of TCE and 12TOCE concentrations was averaged
for all readings at a particular well. Anomalously
low readings were discarded. The resultant averages
are shown in Table 1.
(b) Where the edge of the plume was not well defined,
assumed points were added based on the overall
configuration shown in the above noted figures and on
behavior expected by the flowfield. This occurred on
the southeast side of the Valley site and immediately
east of Mill Pond.
(c) The plume was discretized into triangular elements and
the area of each element was calculated. The
discretization is shown in Figures la through le.
Assumed points are A-l, A-2, A-3 on the Valley Site
and M-3 east of Mill Pond. All assumed points were
given as concentration of 100 ppb.
-------
(d) The volume of TCE and 12TDCE within each element was
calculated on the basis of a log linear variation
using the following parameters:
Saturated thickness: 15* west of Mill Pond,
30' in remainder of aquifer (See line on
figure 1: where elements spanned this line,
an average was used based on the number of
nodes in each cone)
Specific gravity of TCE: 1.46
Porosity: 0.25
Retardation factor: 2.0 (Mason 1984)A/
(e) The resultant relationship between observed
concentrations of nodes (wells) and the mass of TCE
and 12TDCE in the elements (including unit conversion)
is:
M (gallons) - Cavg (ug/L)«Area(ft2)«H(ft)«
2.56xlO-9(_L)«(_akl )
(ug) (ft*)
The calculations for each element are shown in Table 2.
The plume is plotted in Figure 2.
I/ Mason, Benjamin J., "Evaluation of Data from the Kingston*,
NH Site,* Engineering Report Submitted to Brown & Nizson
Attorneys, April 1984.
-2-
-------
The total volume of VOCs (TCE plus 12TDCE) in the
groundwater and adsorbed to the soil in the saturated zone was
calculated to be 99 gallons.
The mass of VOCs on-site can be calculated in the same
manner, by limiting the summation to those elements lying
within the area of the Site. This was taken as the area west
of B-7, GZ-3, B-14, GZ-2, TW-8A and A-l. The total VOC
calculated in this area is 11.5 gallons.
1913c
-------
TABLE I
Averaae Well Concentrations of TCE. 12TDCB
WELL I.Dr
B-7
TW-22
TW-11A
GZ-3
TW-12
B-14
TW-15
TW-23
TW-16
TW-19
A-3
TW-1
TW-9
TW-18
A-2
TW-17
TW-26A
TW-26
G2-2
TW-8A
TW-3
A-l
TW-25
TW-24A
ERT-22/7
ERT-23
DEQE-3
ERT-16
ERT-9/11/13
DEQE-4
DEQE-1
DEQE-8
M-3
No. 4
ERT-5/NO. 5
MEASURED
CQNC (PPBi
57
20
142
232
5395
6537
11400
69850
3443
12550
100
13192
80917
66900
100
39225
50000
2987
42968
79764
3030
100
53300
2395
20
48
2479
3
553
890
14706
20700
100
20176
36310
X
COORD
Y
COORD
106
-12
30
155
255
164
61
50
35
40
37
52
60
60
117
105
120
117
147
154
114
181
244
277
-268
99
6
611
154
226
264
273
638
299
287
371
16
44
284
322
186
55
29
6
-5
-27
-6
6
12
-22
31
73
85
101
54
-1
5
210
130
1240
1683
1338
1471
1256
1133
1056
583
710
1071
475
THICKNESS OF
SATURATED ZONE
CONTAINING TCE. 12TDCE
15
15
15
15
15
15
15
15
15
15
15
15
15
15
15
15
15
15
15
15
15
15
15
15
30
30
30
30
30
30
30
15
15
30
15
1898C
-------
TABLE II
me. COM»J7.7IOh 0s COK7««!hENT rtSS ••••
tVC.CONC. tvt.SlV.
1
2
.3
*
s
6
7
8
9
10
11
12
13
1*
IS
16
17
. IS
19
20
21
22
23
it,
15
26
27
it
29
3"3
31
101
102
103
10*
10!
106
107
10C1
1002
1003
100*
1005
1036
1C07
loot
1CC9
101C
1C11
1*12
1013
i:i*
1C1S
iC16
1C1?
me
ic:s
1020
5281.
11218.
>803.
(68.
23*.
SC71.
$637.
4033.
3*3.
3*3.
2*3.
75.
138.
76.
43*8.
3196.
1139.
20*.
381.
2123.
110*.
70*.
478.
135.
833.
352.
o!7*.
2661.
733.
857.
886.
»C*0.
1723.
713.
«S9.
(03.
13*.
60*.
*27Q8.
1J7379.
1106*3.
*375.
6150.
40*50.
ItSii.
2799.
2»3*3.
1!3*82.
57*60.
2258.
1633.
iS.S.
12*116.
i:3i»t.
*f2C.
!9?73.
.755.
2281.
.15.
123.
55.
21..
8e .
721.
4636.
32*..
252*5.
2651*.
15174.
23750.
123*1.
2*6*6.
9*32.
If 583.
lit*:.
6060.
28172.
31*93.
56805.
55659.
21266.
1*78? .
2167*.
567*1.
S!5*..
5368:.
ill*..
2o7j.
2891.
3li.
1587.
SOi.
25*4.
293.
13..
1*1.
127e.
Jl89.
106*.
2589.
1153.
15»*6.
*S«.
* 3.
322.
21*i.
6*16.
1E313.
182.
*i«*.
2*751.
2656.
777«.
5cM.
15.
li.
' 1 >.
li.
li .
li.
li.
li.
15.
IS.
15.
15.
15.
15.
15.
15.
15.
15.
15.
15.
li.
li.
li.
li.
15.
15.
15.
la.
15.
15.
li.
li.
15.
li.
1!.
li.
15.
IS.
30.
2i .
23.
3t>.
3C.
20.
Is.
11.
30.
3i .
3;.
3C.
3d.
25.
2i .
2C.
2 C .
li..
li.
15.
0.5941
0.0536
0.0121
0.0071
w.OOoS
C.392*
C.55»7
(.01*0
0.06!t
0.0*27
0.2351
I). 076*
0.08(1
0.0693
i.fc&Ot
3.02*7
O.*125
b.l*5(
0.17*7
O.*9*l
1.19*3
C.851*
1.0*15
C.3092
C.67* 6
&.1999
5. 1336
5.797*
1.56i*
1.77:2
1.7112
O.*l*7
0.1912
C.OC85
C.0*01
C.0157
0.0131
0.006E
t.*J79
1.2*31
S.C3»2
1.1207
0.50*7
i .3il 6
1.4152
1.712?
C.909P
C.3*19
1 .*2 J 1
C.37i7
O.S04*
4.7805
:.»*76
22.1065
e.lOe*
*.&!:*
l.*let
6.7759
IS
?».l*5f 7
-------
PIGURflOP-A
Discretization Osed to
Calculate Mass of TCE-12TOCB
in Valley Pluae
1700
MOO
IMO
UOO
I -I «
000
100
•001
I
MOj
«ooj
MO I
100 j
o.
I
-704 HMO -MM -400 -MO -200 -MO 0 WO 100
I - I I — J J 1 —.1 — 11
-------
FIGURE 1-B
Enlargement of Southern
End of Grid Showing Nodes
(red) and Element (blue)
Nuabers
400
ISO
,100 I
2SOJ
200
100!
iO1
/!*
-(19
.18"
..CO
e
a ' '-.-':. .!*•• .-.
"• ' -45
,mt,;
TT7"T^-
.84
-M;
-SO
MO ISO 200 2SO MO WO 400 I
. _ . ..'. I
-------
FIGUMT i-c
BnlargeMent of Southern
End of Plime Showing
Correspondinq
Me11 Designations
400
"
- 'i;
2M
700J
i
I
ISOJ
100
0 •-
/•;
/' i
o •-•«
•I--/ i\
/ o'l"
O »•-!••
• 0 '»-»,• 0 '•-•
o »-••-
0 r
IW-24A
0 «-J
-M!
-so o"
too
"BO 200 ~ 2M MO M*
-------
. FIGURE 1-D
Enlargement of Northern
End of Grid Showing Nodes
(red) and Element (blue)
Numbers
,. ..... --j
MOO
M 001
uoo!
1200
woo!
».X).
100'
/•*"\
iooj \
IIJ.-4.
"
-------
Northern
End of Grid Showing
Correspondinq Well
... Designations
•00, • : "I i i i ' I • T- t 1 II
7«°i o "»-"
i M
•«• / ;
. ' .
1 ',
-i / \ ^>
M°°I / i ^"' /
i » .r i
\ 0 K«H>
uoo| '• ^
0 «T-«/7 • 0 Wf-t/M/ !
nooi
', 0 K«C-«
• ^Mkl
; \ o°«*^
«ooj ' '1
' 1
»•», ;
i
-•I . il
1 1
1 1
7001 ; , i.,
• , ii
•°°i ! / 0{ otoc-o, .
•' ''f
1001 ' :Q «'-»/«...
Wf-»
-
i
-i
.
I
1
|
1
0 *"3
t
1
1
l 'i
- • • -'- — 'L. -.i.--^— ^s— 4.— ,U--«
-MO -MO -K» 0
. .
200 MO 400
-------
FIGURE 2
Plot of the Valley Plane
Based on Data
in Table I
HIM;
i
i.oooo- 10.0
10.0- 100.0
100.0- 1000.0
j looo.o- ioooo.o
toooo.o-«*«**««
1*1)0
1)00 j
1400
uoo!
uoo;
i
uoo!
wool
«o;
«OOI
7ou;
uoo!
son.
40U:
JOO
200;
I00|
0'
-•00 -40O -400 -1OO -100 -MO 0
I
I
too 200 loo 400" soo~*oo~~i4b~ io«~90o~t6oo""ii6«
•I i
-------
APPENDIX F
AUGUST 29, 1988 LETTER FROM
JOHN L. FALCONE, JR., M. ANTHONY
LALLY ASSOCIATES, TO COUNSEL
FOR VALLEY AND GRC
-------
M. Anthony Lally Associates
Consulting Enuironmenfo/ Engineers M. Anthony Laiiv. RE.
100 Belmont Street North Andover, Massachusetts 01845 Tel. (508) 688-1763
August 29, 1988 RECEIVED
AUG5 01388
Attorney Martin c. Pentz u *» a
Nutter, McClennen & Fish M.C.P*
One International Place
Boston, MA 02110-2699
Re: Groundwater Treatment Process
Valley Manufactured Products Co., Inc.
Groveland Valley Site
Groveland, MA
Dear Attorney Pentz:
We have reviewed the Draft Feasibility Study (FS) for the Cleanup :
of Volatile Organic Compounds, Groveland Valley Site, Groveland, •
MA and have the following comments regarding the High Rate
Groundwater Treatment/Reinjection Alternative (GW-3).
A computer simulated model (Figure 1) was developed to determine
. the removal rate of the volatile organic compounds in the Valley
Site groundwater according to the High Rate Groundwater
Treatment/Reinjection Alternative which was proposed in the U.S.
EPA FS.
The rate of change of groundwater contamination was calculated
based on a pore volume of 1.3 x 106 gallons having an average
starting concentration of 100 mg/1 total volatile organic
compound's. The pore volume concentration (VC)(T+i) was
calculated as:
VC(T+i) « [V * VC(T)1 - IF * FCl + [R * RC]
where: V « pore volume » 1.3 x 106 gallons
VC(T) • VOC concentration in pore volume at T » 0 Hrs.
VC(T+1) * voc concentration in pore volume at T-T+1 Hr.
F • Groundwater feed rate to air stripper tower
- 30 GPM
FC * VOC concentration in groundwater feed to air
stripper tower - VC(T)
R - Treated groundwater recycle « F-1.5 GPM » 28.5 GPM
RC • VOC concentration of treated groundwater recycle
- (FC x .05)
Water • Wastewater • Solid Waste • Site Development
-------
Attorney Martin C. Pentz
August 29, 1988
Page TWO
Table 1., Groundwater Airstrip System, Recirculation Rate » 28.5
GPM, shows the results of the concentration of VOC's in the
groundwater and the volumes of VOC which have been removed with
vapor phase and liquid phase granulated activated carbon. Figure
2 is a schematic of the groundwater treatment process.
Changing the groundwater feed rate to the air stripper tower from
30 GPM to 15, 5 and 3 GPM in the simulated model produced
additional corresponding data found in Tables 2, 3 and 4
respectively. A plot of the data (Figure 3) shows the number of
years of operation of the groundwater treatment process required
in order to reduce the concentration of VOC's in the groundwater
to 1 ppb for the various rates of treated recycle water to be
reinjected upgradient in the contamination zone. :
The High Rate Groundwater, Treatment/Reinjection Process (GW-3)
would reduce the total VOC's in the groundwater to approximately 1
ppb in one year. With treated water recycle rates of 3.5 and 1.5
GPM, the length of time to reach 1 ppb would be 6 and 10 years
respectively.
It should be noted that previous soil flushing studies have
indicated that the limiting rate of reinjection cannot exceed
approximately 7 GPM. Reinjection in excess of7GTHmaycause
flooding in the unsaturated zone which would interfere with the
soil gas evacuation process.
The estimated costs associated with the 3.0 GPM groundwater
treatment process are shown in Table 5 and are compared with the
FS estimate for the 30 GPM (GW-3) alternative for groundwater
treatment. In comparison, the capital and 0 & M costs for the 3.0
GPM groundwater treatment process are approximately 20 percent of
the proposed FS 30 GPM groundwater treatment process.
A plot of carbon treatment costs vs elapsed time, Figure 4, is
attached to this correspondence. Although the total cost of
carbon may not vary with the rate of treatment, the rate of carbon
adsorption and associated costs are dependent on the rate of
treatment.
-------
Attorney Martin C. Pentz
August 29, 1988
Page Three
If groundwater treatment using air stripping in conjunction with
groundwater recycle through rcinjection is the chosen technology
for remedial action at the Valley Site, the reduced rate of
treatment at 3.0 GPH is preferred because it has been demonstrated
to be:
. Technically feasioie
. Within maximum limits for recharge
. will not interfere with vacuum extraction process
. Lower capital and 0 t M costs
If you have any questions or require additional information
regarding this matter, please do not hesitate to contact this
office.
Very truly yours
M. ANTHONY LALLY ASSOCIATES
John L. Falcone, Jr.
JLF/jk
Enclosures
-------
FIGURE 1
5 PRtt 1
10 PRINT "GROUNDWATER AIRSTRIP S
YSTEM"
20 PRINT "RECIRCULATION RATE = 1
.5 GPM"
25 PRINT
30 PRINT " . PPM VOC IN
VDC V.PH. VOC L.
PH"
40 PRINT " GROUNDWATER
REMOVED REMOVE
D"
45 PRINT
50 T = 0:V » 1300000: VC = 100: P =
180: R = 90: PC = VC
60 H = O:D = 0:W = 0:Y = 0:RC = .
05 * FC
10O T=T+ 1:S=S* 1
101 H «= T:D = H / 24:W = D / 7:Y =
W / 52
110 VC - < (V * VC) •»• (R * RC) - (
F * PC) ) / V
115 FC = VC:RC = .05 * FC
120 VPHVOC * VPVOC •«• F * FC * .95
/ 1 000000
130 LPHVOC = LPVOC * (F * .05 * F
C * .05 / 1000000)
140 IF S = 168 THEN PRINT "WEEK
,";W:" ":VC:" ":VP
HVOC;" "; LPHVOC
144 IF S = 169 THEN B = B + 1
145 IF S = 168 THEN S = 0
146 IF Y = 10 THEN END
148 IF B = 50 THEN 160
150 GOTO 100
160 FOR I = 1 TO 16: PRINT : NEXT
I
165 B « 0: GOTO 100
-------
1
LJ
LTZIII:
•
.
-
I <
' ! •• ; ' •
i I i i i I • i i i i
gJrr! M ; i { I I :
J_1J_ I i U
-------
FIGURE 3
VALLEY MANUFACTURED
PRODUCTS COMPANY, INC.
VOC CONC. IN SITE .
GROUNDWATSR VS TREATMENT
PERIOD § VARIOUS
RECIRCULATION RATES OF
TREATED WATER
• IMI-LOCAIIITMMIC » C»Clt» «
-------
FIGURE 4
VALLEY MANUFACTURED
PRODUCTS COMPANY, INC.
CARBON COSTS VS TREATMENT
PERIOD « VARIOUS .
RECIRCULATION RATES OF
TREATED WATER
I I I I I I I I I I I I I I I I I I I I I I I I I I i i
3 Ocfe* t It M Ihr tack
-------
TABL«2 1
GROUNDWATER AIRSTRIP SYSTEM
RECIRCULATION RATE -28.5 GPM
1
2
3
4
5
6
7
13
14
15
WEEK
WEEK
WEEK
WEEK-
WEEK
WEEK
WEEK
•WEEK B
WEEK 9
WEEK 10
WEEK 11
WEEK 12
WEEK
WEEK
WEEK
WEEK 16
WEEK 17
WEEK IB
WEEK 19
*EEK 20
WEEK 21
WEEK 22
WEEK 2Z
WEEK 24
WEEK 25
WEEK 26
WEEK 27
WEEK 2B
WEEK 29
WEEK 30
WEEK 31
WEEK 32
WEEK 33
WEEK 34
WEEK 35
WEEK 36
WEEK 37
WEEK 38
WEEK 39
WEEK 40
WEEK 41
WEEK 42
WEEK 43
WEEK 44
WEEK 45
WEEK 46
WEEK 47
WEEK 48
WEEK 49
WEEK 50
PPM VOC IN
GROUNDWATER
80.1145754
64.1834515
51.4202993
41.1951543
33.0033227
26.4404717
21.1826715
16.9704073
13.5957696
10.8921931
8.7262342
6.99098542
5.60079826
4.49705573
3.59478562
2.87994723
2.30725749
1.84844953
1.48087748
1.18639869
. 95047827
.761471626
.610049758
.488738771
.391550989
.313689411
.251310939
.201336691
.161300034
.129224837
. 103527929
.0829409603
.066447798
. 0532343709
.0426484899
.0341676563
. 0273732726
.021929981
.0175691111
.0140754186
.0112764618
9. 0340B943E-03
7.23762236E-03
5.79B39039E-03
4.645355B3E-03
3.72160709E-03
2.9B15497E-03
2.38B655B7E-03
1.91366151E-03
1.5331217BE-03
VOC V.PH.
REMOVED
25.7491979
46.3780586
62.9047825
76.145097
66.7525186
95.2506095
102.058819
107.513187
111.882931
115.383732
118. 188384
120.43532
122.235442
123.677603
124.832983
125.758612
126.500175
127.094275
127.570236
127.95155
128.257038
128.501779
128.697852
128.854935
128.980781
129.0B1603
129.162375
129.227086
129.278928
129.320461
129.353736
129.380394
129.40175
129.41BB6
129.432567
129.443548
129.452346
129.459395
129.465041
129.469565
129.47319
129.476094
129.47842
129.4B02B3
129.481776
129.482972
129.483931
129.4B469B
129.485313
129.485806
VOC L.PH
REMOVED
.0677610472
.122047522
.165538901
.200381834
.228296102
.250659499
.26857584
.282929441
.294428766
.303641402
.311022067
.316935054
.321672219
. 325467379
.328507855
.330943719
.332895201
.334458622
.335711151
.336714608
.337518525
.338162578
.33867856
.339091935
.33942311
.339688429
.339900989
.340071279
.340207708
.340317007
.340404571
.340474722
.340530924
. 34057595
.340612022
. 34064092
.340664073
.340682621
.340697482
. 3407093B6
.340718924
. 340726565
.340732687
.340737591
.34074152
. 340744668
.340747189
.34074921
.340750828
.340752125
-------
WEEK 51
WEEK 52
WEEK S3
WEEK 54
WEEK 55
WEEK 56
WEEK 57
WEEK 58
WEEK 59
WEEK 60
WEEK 61
WEEK 62
WEEK 63
WEEK 64
WEEK 65
WEEK 66
WEEK 67
WEEK 6B
WEEK 69
*EEK 70
.WEEK 71
WEEK 72
WEEK 73
WEEK 74
WEEK 75
WEEK 76
WEEK 77
WEEK 78
WEEK 79
WEEK 80
WEEK 81
WEEK 82
WEEK 83
WEEK 84
WEEK 85
WEEK 86
WEEK 87
WEEK 88
WEEK 89
WEEK 90
WEEK 91
WEEK 92
WEEK 93
WEEK 94
WEEK 95
WEEK 96
WEEK 97
WEEK 98
WEEK 99
WEEK 100
1.228254E-03
9.84010467E-04
7.8833S806E-04
6.3157186E-04
S.OS9B112BE~04
4.05364631E-04
3.247361S1E-04
2.6017701E-04
2.08439705E-04
1.66990583E-04
1.337B3796E-04
1.071B032E-04
8.5B67057BE-05
6.B79202B3E-05
5.5112441E-05
4.4153097BE-05
3.S3730666E-OS
2.83369818E-05
2.27036549E-05
1.81BB9367E-05
1.45719893E-05
1.16742873E-05
9.352BOS6BE-06
7.49296057E-06
6.0029335E-06
4.8092407E-06
3.B3290274E-06
3.OB673666E-06
2.47292596E-06
1.96117413E-06
1.56720923E-06
1.271S8593E-06
1.01B72366E-06
B.16147734E-07
6.53B53291E-07
5.23831785E-07
4.19665609E-07
3.3621331BE-07
2.69335B7E-07
2.15793311E-07
1.72B81B93E-07
1.3B303595E-07
1.10961566E-07
B.BB963B76E-OB
7.121B9632E-OB
5.70567687E-OB
4.57107B7BE-08
3.6621003SE-OB
2.93387613E-08
2.35046239E-OB
129.466201
129.486517
129.48677
129.486973
129.487136
129.487266
129.487371
129.467454
129.467521
129.487575
129.467618
129.487652
129.467681
129.487701
129.487721
129.487733
129.487743
129.467753
129.467763
129.487773
129.467775
129.487775
129.487775
129.487775
129.467775
129.487775
129.467775
129.487775
129.487775
129.467775
129.467775
129.467775
129.487775
129.487775
129.467775
129.467775
129.487775
129.487775
129.487775
129.487775
129.487775
129.487775
129.487775
129.487775
129.487775
129.467775
129.487775
129.487775
129.487775
129.487775
.340753164
.340753996
.340754663
.340755197
.340755625
.340755967
.340756242
.340756462
.340756638
.34075678
.340756892
.340756983
.340757056
.340757113
.340757159
.340757199
.340737229
.340757249
.340757268
.340757268
.340757308
.340757318
.340757318
.340757318
.340757318
.340757318
.340757318
.340757318
.340737318
.340757318
.340757318
.340757318
.340757318
.340737318
.340757318
.340757318
.340757318
.340757318
.340757318
.340757318
.340757318
.340757318
.340757318
.340757318
.340757318
.340757318
.340757318
.340757318
.340737318
.340757318
-------
WEEK 101
WEEK 102
WEEK 103
WEEK 104
WEEK 105
WEEK 106
WEEK 107
WEEK 108
WEEK 109
WEEK 110
WEEK 111
WEEK 112
WEEK 113
WEEK 114
WEEK -11 5
WEEK 116
WEEK 117
WEEK 118
WEEK 119
MEEK 120
WEEK 121
WEEK 122
WEEK 123
WEEK 124
WEEK 125
WEEK 126
WEEK 127
WEEK 128
WEEK 129
WEEK 130
WEEK 131
WEEK 132
WEEK 133
WEEK 134
WEEK 135
WEEK 136
WEEK 137
WEEK 138
WEEK 139
WEEK 140
WEEK 141
WEEK 142
WEEK 143
WEEK 144
WEEK 145
WEEK 146
WEEK 147
WEEK 148
WEEK 149
WEEK 150
1.
1.
i.
9.
7.
6.
4.
3.
3.
2.
2.
1.
1.
1.
8.
6.
5.
4.
3.
2.
2.
1.
1.
1.
9.
7.
5.
4.
3.
3.
2.
1.
1.
1.
1.
8.
6.
5.
4.
3.
2.
2.
1.
1.
1.'
8.
7.i
5.
4.
3.
1.8B306295E-OB
508607B8E-OB
20861479E-OB
6B276603E-09
757306B5E-09
2147334E-09
97890723E-09
98BB303BE-09
19563449E-09
560169E-09
05106B52E-09
643204B3E-09
31644657E-09
05466557E-09
4494084BE-10
6.76920771E-10
5.423122E-10
4.34471115E-10
4B0746B8E-10
.7BB5B557E-10
2340634BE-10
,7B9B1046E-10
433B9904E-10
14B76212E-10
20325895E-11
37315176E-11
90696921E-11
73234329E-11
79129672E-11
0373B126E-11
4333B509E-11
94949612E-11
56183053E-11
251253B9E-11
00243674E-11
03097937E-12
4339B499E-12
15455972E-12
1293S361E-12
30B37433E-12
6S049003E-12
12342BB2E-12
70M7597E-12
362B899E-12
0918734SE-12
74749774E-13
00B02065E-13
61444595E-13
4.4979B9S2E-13
3.60354519E-13
129.4B7775
129.487775
129.487775
129.487775
129.487775
129.487775
129.487775
129.487775
129.487775
129.487775
129.487775
129.487775
129.487775
129.487775
129.487775
129.487775
129.487775
129.487775
129.487775
129.487775
129.487775
129.487775
129.487775
129.487775
129.487775
129.487775
129.487775
129.487775
129.487775
129.487775
129.487775
129.487775
129.487775
129.487775
129.487775
129.487775
129.487775
129.4B7775
129.487775
129.487775
129.487775
129.487775
129.487775
129.487775
129.487775
129.487775
129.487775
129.487775
129.487775
129.487775
.340757318
.340757318
.340757318
.340757318
.340757318
.340757318
.340757318
.340757318
.340757318
.340757318
.340757318
.340757318
.340757318
.340757318
.340757318
.340757318
.340757318
.340757318
.340757318
.340757318
.340757318
.340757318
.340757318
.340757318
.340757318
.340757318
.340757318
.340757318
.340757318
.340757318
.340757318
.340757318
.340757318
.340757318
.340757318
.340757318
.340757318
.340757318
.340757318
.340757318
.340757318
.340757318
.340757318
i34075731B
.340757318
.340757318
.340757318
.340757318
.340757318
.340757318
-------
WEEK 131
WEEK 152
WEEK 133
WEEK 154
WEEK 135
WEEK 156
WEEK 137
WEEK 158
WEEK 159
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2
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2.312S796BE-13
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1.4B44B6E-13
1.18928965E-13
9.527943SSE-14
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4.42606BB9E-18
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1.8233259IE-IB
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WEEK 251 6.78370263E-23
WEEK 252 5.436336B3E-23
WEEK 253 4.35529815E-23
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1.0403309E-27
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1.59495406E-32
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129.487775
129.487775
129.487775
129.487775
129.487775
129.487775
129.487775
129.487775
129.487775
129.487775
129.487775
129.487775
129.487775
129.487775
129.487775
129.487775
129.487775
129.487775
129.487775
129.487775
129.487775
129.487775
129.487775
129.487775
129.487775
129.487775
129.487775
129.487775
129.487775
129.487775
129.487775
129.487775
129.487775
129.487775
129.487775
129.487775
".340757318
.340757318
.340757318
.340757318
.340757318
.340757318
.340757318
.340757318
.340757318
.340757318
.340757318
.340757318
.340757318
.340757318
.340757318
.340757318
.340757318
.340757318
.340757318
.340757318
.340757318
.340757318
.340757318
.340757318
.340757318
.340757318
.340757318
.340757318
.340757318
.340757318
.340757318
.340757318
.340757318
.340757318
.340757318
.340757318
.340757318
.340757318
.340757318
.340757318
.340757318
.340757318
.340757318
.340757318
.340757318
.340757318
.340757318
.340757318
.340757318
.340757318
-------
WEEK 451
WEEK 452
WEEK 453
WEEK 454
WEEK 455
WEEK 456
WEEK 457
WEEK 458
WEEK 459
WEEK 460
WEEK 461
WEEK 462
WEEK 463
WEEK 464
WEEK 465
WEEK 466
WEEK 467
WEEK 466
WEEK 469
WEEK 470
*EEK 471
WEEK 472
WEEK 473
WEEK 474
WEEK 475
WEEK 476
WEEK 477
WEEK 478
WEEK 479
WEEK 480
WEEK 481
WEEK 482
WEEK 483
WEEK 484
WEEK 483
WEEK 486
WEEK 487
WEEK 488
WEEK 489
WEEK 490
WEEK 491
WEEK 492
WEEK 493
WEEK 494
WEEK 495
WEEK 496
WEEK 497
WEEK 498
WEEK 499
WEEK 500
0 129.487775
0 129.487775
0 129.487775
0 129.487775
0 129.487775
0 129.487775
0 129.487775
0 J29.487775
0 129.487775
0 129.487775
0 129.487775
0 129.487775
0 129.487775
0 129.487775
0 129.487775
0 129.487775
0 129.487775
0 129.487775
0 129.487775
0 129.487773
0 129.487775
0 129.487775
0 129.487775
0 129.487775
0 129.487775
0 129.487775
0 129.487775
0 129.487775
0 129.487773
0 129.487775
0 129.4B7775
0 129.487775
0 129.487775
0 129.487775
0 129.487775
0 129.487775
0 129.487775
0 129.487775
0 129.487775
0 129.487775
0 129.487775
0 129.487775
0 129.487775
0 129.487775
O 129.487775
0 129.487775
0 129.487775
0 129.487775
0 129.487775
0 129.487775
.340757318
.340757318
.340757318
.340757318
.340757318
.340757318
.340757318
.340757318
.340757318
.340757318
.340757318
.340757318
.340757318
.340757318
.340757318
.340757318
.340737318
.340757318
.340757318
.340757318
.340757318
.340737318
.340757318
.340737318
.340757318
.340737318
.340737318
.340757318
.340757318
.340757318
.340757318
-.340757318
.340757318
.340757318
.340737318
.340757318
.340737318
.340737318
.340757318
.340757318
.340757318
.340757318
.340757318
.340757318
.340757318
.340757318
.340757318
.340757318
.340757318
.340757318
-------
WEEK 501
WEEK 502
WEEK 503
WEEK 504
WEEK 505
WEEK 506
WEEK 507
WEEK SOB
WEEK 509
WEEK 510
WEEK 511
WEEK 512
WEEK 513
WEEK 514
WEEK 515
WEEK 516
WEEK 317
WEEK 518
WEEK 319
WEEK 520
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
129.4B7775
129.4B7775
129.487775
129.4B7775
129.487775
129.487775
129.487775
129.487775
129.487775
129.487775
129.487775
129.487775
129.487775
129.487775
129.487775
129.487775
129.487775
129.487775
129.487775
129.487775
.340757318
.340757318
.340757318
.340757318
.340757318
.340757318
.340757318
.340757318
.340757318
.340757318
.340757318
.340757318
.340757318
.340757318
.340757318
.340757318
.340757318
.340757318
.340757318
.340757318
-------
6 ROUNDWATER AIRSTRIP SYSTEM
REC1RCULATION RATE -13.5 GPM
PPM VOC IN
GROUNDWATER
WEEK 1
WEEK 2
WEEK 3
WEEK 4
WEEK 5
WEEK 6
WEEK 7
WEEK 6
WEEK 9
WEEK 10
WEEK 11
WEEK 12
WEEK 13
WEEK 14
WEEK 15
WEEK 16
WEEK 17
WEEK IB
WEEK 19
WEEK 20
WEEK 21
WEEK 22
WECK 23
WEEK 24
WEEK; 25
WEEK 26
WEEK 27
WEEK 28
WEEK 29
WEEK 30
WEEK 31
WEEK 32
WEEK 33
WEEK 34
WEEK 35
WEEK 36
WEEK 37
WEEK 38
WEEK 39
WEEK 40
WEEK 41
WEEK 42
WEEK 43
WEEK 44
WEEK 45
WEEK 46
WEEK 47
WEEK 46
WEEK 49
WEEK 50
69.483979
60.073825
71.6532447
64.1181744
57.3754938
31.3416747
45.9427524
41.1114031
36.7681193
32.9194728
29.4576541
26.3596811
23.5878705
21.1073651
18.8677102
16.9014747
15.1241121
13.3336572
12.110455
10.636917
9.69730456
6. 67753401
7.7650027
6.9484334
6.21773471
5.56387645
4.97877805
4.45520871
3.98669801
3. 56745602
3.19230161
2.8565985
2.556198
2.2873877
2.04684554
1.63159883
. 63898752
.46663125
.3124
. 17438774
. 05088888
.94037719
.841486929
.732995969
.673810774
.602952691
. 539546059
.482807284
.432035169
.386602259
VOC V.PH.
REMOVED
13.3902609
25.7513671
36.6336089
46.371471B
55.0B5299
62. BB277S3
69.B60273
76. 1040127
81.6911397
B6. 69076 11
91.1646035
95.1679756
98.7503522
101.956005
104.624551
107.39144
109.688395
111.743801
113.58306
115.228903
116.701668
118.019557
119.198856
120.254141
121.198451
122.043457
122.799603
123.476232
124.081706
124.623509
125. 108336
125.542178
125.930397
126.277791
126.588653
126.866825
127.115744
127.338486
127.537805
127.716164
127.675766
128.018585
128.146385
128.260745
128.363079
128.454652
128.536595
128.60992
128.675535
128.73425
VOC L.PH
REMOVED
. 0357638445
. 0677667554
. 0964042334
.122030166
.144961313
. 165480995
.183842823
.200273718
.214976736
.226133561
.239906651
.25044204
. 259869348
. 268305277
. 275854082
. 282609054
.28865367
. 294062634
. 29890279
. 303233955
.307109652
.310577781
.313681201
.316458265
.318943292
.321166993
.323156849
. 324937452
. 326530805
. 327956602
. 329232462
.330374152
.33139578
. 332309975
.333128033
. 333860063
.334515113
.335101278
.335625801
.336095166
.336515172
.33689101
.337227325
. 337528274
.337797574
. 338038554
.338254193
.338447155
.338619826
.338774339
-------
WEEK 51
WEEK 52
WEEK 53
WEEK 54
WEEK 55
WEEK 56
WEEK 57
WEEK 58
WEEK 59
WEEK 60
WEEK 61
WEEK 62
WEEK 63
WEEK 64
WEEK 65
WEEK 66
WEEK 67
WEEK 68
WEEK 69
WEEK 70
WEEK 71
WEEK 72
WEEK 73
WEEK 74
WEEK 75
WEEK 76
WEEK 77
WEEK 78
WEEK 79
WEEK 80
WEEK 81
WEEK 82
WEEK 83
WEEK 84
WEEK 85
WEEK 86
WEEK 87
WEEK 88
WEEK 89
WEEK 90
WEEK 91
WEEK 92
WEEK 93
WEEK 94
WEEK 95
WEEK 96
WEEK 97
WEEK 98
WEEK 99
WEEK 100
.345947084
.309567217
.277013064
.247882311
.221814955
.198488848
.17761572
.158937614
.142223701
.127267427
.113883958
.101907897
.0911912417
.0816015516
.0730203152
.0653414837
.0584701596 '
.0523214256
.0468192936
.0418957669
.0374899993
.0335475432
.0300196765
.026862801
.0240379034
.0215100725
.0192480687
.0172239377
.0154126648
.0137918658
.0123415104
.0110436746
9.88231947E-03
B.B4309265E-03
7.91313118E-03
7.08100253E-03
6.33636281E-03
5.67002956E-03
5.07376B08E-03
4.54020957E-03
4.06276019E-03
3.63551947E-03
3.25320749E-03
2.91109951E-03
2.60496768E-03
2.33102B73E-03
2.08589726E-03
1.B66543B7E-03
1.67025773E-03
1.4946130BE-03
128.78679
128.833806
12B.B75B77
128.913524
128.947212
128.977357
129.004332
129.02847
129.05007
129.069399
129.086695
129.102172
129.116021
129.128414
129.139504
129.14942B
129.158308
129.166255
129.173365
129.179728
129.185422
129.190517
129.195076
129.199156
129.202807
129.206073
129.208997
129.211613
129.213953
129.216048
129.217922
129.2196
129.221101
' 129.222444
129.223646
129.224721
129.225683
129.226545
129.227315
129.226005
129.228622
129.229174
129.229668
129.23011
129.230506
129.230B6
129.231176
129.23146
129.231713
129.231941
,338912603
.33903632B
.339147041
.339246112
.339334763
.339414093
33948508
339548602
339605445
.339656309
.339701825
.339742554
.339779
.339811614
.339840798
.339866913
.339890281
.339911193
.339929905
.33994665
.339961633
.339975041
.339987039
.339997775
.340007382
.340015979
.340023671
.340030555
.340036715
.340042227
.34004716
340051573
.340055523
.340059057
.34006222
.34006505
.340067583
.340069849
.340071876
.340073691
.340075315
.340076766
.340078068
.340079232
.340080273
.340081205
.340082039
.340082784
.340083452
.340084049
-------
WEEK 101
WEEK 102
WEEK 103
WEEK 104
WEEK 105
WEEK 106
WEEK 107
WEEK 108
WEEK 109
WEEK 110
WEEK 111
WEEK 112
WEEK 113
WEEK 114
WEEK IIS
WEEK 116
WEEK 117
WEEK 118
WEEK 119
WEEK 120
WEEK 121
WEEK 122
WEEK 123
WEEK 124
WEEK 125
WEEK 126
WEEK 127
WEEK 128
WEEK 129
WEEK 130
WEEK 131
WEEK 132
WEEK 133
WEEK 134
WEEK 135
WEEK 136
WEEK 137
WEEK 138
WEEK 139
WEEK 140
WEEK 141
WEEK 142
WEEK 143
WEEK 144
WEEK 143
WEEK 146
WEEK 147
WEEK 148
WEEK 149
WEEK 150
1
1
1
9
8
7,
6,
6
3,
4,
4,
3,
3,
3.
2,
2.
2.
2.
1.
1.
1.
1,
1.
1.
9.
8.
7.
6.
5.
5.
4.
4.
3.
3.
3.
2.
2.
2.
1.
1.
1.
1.
1.
1.
1.
9.
8.
7.
6.
5.
1.33743926E-03
1.196793B7E-03
1.07093B77E-03
9.5B31B626E-04
8.3754163BE-04
7.673623B4E-04
.86666394E-04
6.14456414E-04
3.49840049E-04
4.9201B756E-04
4.40277961E-04
3.9397B237E-04
3.32347403E-04
3.15473445E-04
2.8229B193E-04
2.32611637E-04
2.26046962E-04
2.02275B17E-04
8100445E-04
619699B4E-04
449371B7E-04
29695562E-04
160567SE-04
03852198E-04
29310793E-05
8.31584276E-05
44134704E-05
65B81345E-05
95837124E-05
33196664E-05
7712559IE-OS
26930966E-05
3.82052712E-05
3.41B75969E-05
3.05924222E-05
73753167E-05
44963226E-OS
19204632E-05
96153027E-05
75525534E-05
5706723IE-OS
40550008E-OS
2576974E-03
1.12543768E-05
1.00708642E-05
9.011B1007E-06
8.06412631E-06
7.21610111E-06
6.45725442E-06
5.77B20B2E-06
129.232144
129.232325
129.2324BB
129.232634
129.232764
129.23288
129.232984
129.233078
129.233161
129.233236
129.233303
129.233363
129.233416
129.233466
129.233506
129.233546
129.23358
129.23361
129.23364
129.233663
129.233683
129.233703
129.233723
129.233743
129.233753
129.233763
129.233773
129.233783
129.233793
129.233803
129.233813
129.233823
129.233833
129.233841
129.233841
129.233841
129.233841
129.233841
129.233841
129.233841
129.233841
129.233841
129.233841
129.233841
129.235841
129.233841
129.233841
129.233841
129.233841
129.233841
.340084584
.340085062
.34008549
.340085874
.340086217
.340086522
.340086797
.340087042
.340087263
.340087461
.340087637
.340087793
.340087933
.340088058
.340088174
.340088272
.340088365
.3400B8443
.340088521
.3400BB5B
.340088638
.3400BB697
.340088737
.3400BB776
.340088815
.340088854
.340088886
.340088905
.340088923
.340088944
.340088964
.340088983
.340089003
.340089023
.340089042
.340089062
.340089072
.340089072
.340089072
.340089072
.340089072
.-340089072
.340089072
.340089072
.340089072
.340OB9072
.340089072
.340089072
.340089072
.3400B9072
-------
WEEK 151
WEEK 152
WEEK 153
WEEK 154
WEEK 155
WEEK 156
WEEK 157
WEEK 158
WEEK 159
WEEK 160
WEEK 161
WEEK 162
WEEK 163
WEEK 164
WEEK 165
WEEK 166
WEEK 167
WEEK 16B
WEEK 169
WEEK 170
WECK 171
WEEK 172
WEEK 173
WEEK 174
WEEK 175
WEEK 176
4EEK 177
WEEK 17B
AlEEK 179
dEEK 180
«JEEK 181
AlEEK 182
•JEEK 183
AlEEK 184
JEEK- 185
AlEEK 166
-------
WEEK 201
WEEK 202
WEEK 203
WEEK 204
WEEK 203
WEEK 206
WEEK 207
WEEK 20B
WEEK 209
WEEK 210
WEEK 211
WEEK 212
WEEK 213
WEEK 214
WEEK 21S
WEEK 216
WEEK 217
WEEK 218
WEEK 219
WEEK 220
WEEK 221
WEEK 222
WEEK 223
WEEK 224
WEEK 223
WEEK 226
WEEK 227
WEEK 228
WEEK 229
WEEK 230
WEEK 231
WEEK 232
WEEK 233
WEEK 234
WEEK 233
WEEK 236
WEEK 237
WEEK 238
WEEK 239
WEEK 240
WEEK 241
WEEK 242
WEEK 243
WEEK 244
WEEK 243
WEEK 246
WEEK 247
WEEK 248
WEEK 249
WEEK 230
1.99B9543E-08
1. 7B8743B3E-OB
1.60063917E-OB
1.43231563E-08
1.28169302E-OB
1.1469099IE-OB
1.02630063E-OB
9.1837463BE-09
B.21798174E-09
7.33377703E-09
6.38045233E-09
5.BBB4505BE-09
S.269219B8E-09
4.71S10762E-09
4.21926591E-09
3.77356702E-09
3.37832759E-09
3.02324093E-09
2.70531629E-09
2.42082466E-09
2.16625023E-09
1.93B4469E-09
1.73439942E-09
1.5S21B85BE-09
1.38896011E-09
1.242B9677E-09
1.11219348E-09
9.9523498E-10
8.90575BS9E-10
7.9692271BE-10
7.13118159E-10
6.3B126506E-10
3.710209B8E-10
3.10972302E-10
4.5723834BE-10
4.091S506BE-10
3.6612B236E-10
3.27626114E-10
2.93172B83E-10
2.62342761E-10
2.34734741E-10
2.10067B84E-10
1.87977102E-10
1.6B20939E-10
1.50320455E-10
1.34691692E-10
1.203274B6E-10
1.07832791E-10
9.65109685E-11
B.6361B54BE-11
129.233841
129.233841
129.233841
129.233841
129.233841
129.233841
129.233841
129.233841
129.233841
129.233841
129.233841
129.233841
129.237841
129.233841
129.233841
129.233841
129.233841
129.233B41
129.233841
129.233841
129.233841
129.233841
129.233841
129.233841
129.233841
129.233841
129.233841
129.233841
129.233841
129.233841
129.233841
129.233841
129.233841
129.233841
129.233B41
129.233841
129.233841
129.233841
129.233841
129.233841
129.233B41
129.233841
129.233841
129.233841
129.233841
129.233841
129.233841
129.233841
129.233841
129.233841
.340089072
.340089072
.340089072
.340089072
.340089072
.340089072
.340089072
.340089072
.340089072
.340089072
.340089072
.340089072
.340089072
.340089072
.340089072
.340089072
.340089072
.340089072
.340089072
.340089072
.340089072
.3400B9072
.340089072
.340089072
.340089072
.340089072
.340089072
.340089072
.340089072
.340089072
.3400B9072
.340089072
.340089072
.340089072
.340089072
.3400B9072
.340089072
.340089072
.340089072
.340089072
.340089072
.340089072
.340089072
.340089072
.340089072
.340089072
.340089072
.340089072
.340089072
.340089072
-------
WEEK 251
WEEK 252
WEEK 253
WEEK 254
WEEK 255
WEEK 256
WEEK 257
WEEK 258
WEEK 259
WEEK 260
WEEK 261
WEEK 262
WEEK 263
WEEK 264
WEEK 265
WEEK 266
WEEK 267
WEEK 268
WEEK 269
WEEK 270
WEEK 271
WEEK 272
WEEK 273
WEEK 274
WEEK 275
WEEK 276
WEEK 277
WEEK 278
WEEK 279
WEEK 280
WEEK 281
WEEK 282
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6. 18810714E-11
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1.1550373BE-15
1.0335734E-15
9.24882612E-16
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7.405BB8B6E-16
6.6270B402E-16
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3.9938181 IE-IB
3.57561705E-18
3.19960441E-1B
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6.67404653E-23
5.97220241E-23
S.34416437E-23
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4.279276BIE-23
3.8292671BE-23
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.340089072
.340089072
.340089072
.340089072
.340089072
.340089072
.340089072
.340089072
.340089072
.340089072
-------
GROUNDWATER AIRSTRIP SYSTEM
RF.CIRCULATION RATE « 3. 5 GF'M
9
10
14
15
WEEK 1
WEEK 2
WEEK 3
WEEK 4
WEEK 5
WEEK 6
WEEK 7
WEEK B
WEEK
WEEK
WEEK 11
WEEK 12
WEEK 13
WEEK
WEEK
WEEK 16
WEEK 17
WEEK 18
WEEK 19
WEEK 20
WEEK 21
KEEK 22
WEEK 23
WEEK 24
WEEK 25
WEEK 26
WEEK 27
WEEK 28
WEEK 29
WEEK 30
WEEK 31
WEEK 32
WEEK 33
WEEK 34
WEEK 35
WEEK 36
WEEK 37
WEEK 38
WEEK 39
WEEK 40
WEEK 41
WEEK 42.
WEEK 43
WEEK 44
WEEK 45
WEEK 46
WEEK 47
WEEK 48
WEEK 49
WEEK 50
PPM VOC IN
GROUNDWATER
96.3274872
92.7898478
89.3821288
86.0995587
82.9375416
79.8916498
76.9576188
74.1313407
71.4088578
68.7863583
66.2601707
63.8267576
61.4827119
59.2247515
57.049715
54.954557
52.936344
50.9922501
49.1195532
47.3156312
45.5779586
43.9041023
42.2917187
40.7385499
39.2424215
37.8012385
36.4129834
35.075712
33.787552
32.5466998
31.3514181
30.2000333
29.0909332
28.0225649
26.9934327
26.0020955
25.0471653
24.127305
23.2412267
22.3876897
21.5654989
20.7735033
20.0105937
19.2757019
18.5677994
17.8858945
17.2290327
16.5962942
15.9867932
15.3996762
VOC V.PH.
REMOVED
4.69900847
9.22544524
13.585648
17.7857218
21.8315474
25.7287895
29.4829049
33.0991499
36.5825879
39.9380961
43.1703729
46.2839439
49.2831686
S2. 1722465
54.9552225
57.6359934
60.2183127
62.705796
65.1019261
67.4100582
69.6334237
71.775136
73.8381935
75.8254849
77.7397928
79.5837974
81.3600809
83.07113
84.7193408
86.3070209
87.836393
89.3095989
90.7287009
92.0956862
93.4124692
94.6808927
95.9027334
97.0797019
98.213446
99.3055532
100.357553
101.370917
102.347066
103.287365
104.193132
105.065635
105.906095
106.715688
107.49555
108.246771
VOC L.PH
REMOVED
.0123658118
.0242774875
.0357517054
.0468045312
.0574514406
. 0677073409
.077586592
.0871030263
. 0962699683
.105100253
.113606245
.121799853
.12969255
. 137295386
.144619008
. 151673668
. 158469245
.165015254
.171320859
.177394891
.183245853
. 1BBBB173B
.194311036
. 19954075
1.204578403
|. 209431047
'.214105477
.218608238
. 222945635
.22712374
.231148404
. 235025262
.238759741
.242357071
.245822289
.249160246
.252375616
. 255472902
.258456439
.261330405
.264098825
.266765574
.269334387
.271808859
.274192455
.276488514
. 278700249
.280830759
.282883026
.284859923
-------
WEEK 31
WEEK 52
WEEK 53
WEEK 54
WEEK 55
WEEK 36
WEEK 57
WEEK 38
WEEK 39
WEEK 60
WEEK 61
WEEK 62
WEEK 63
WEEK 64
WEEK 65
WEEK 66
WEEK 67
WEEK 68
WEEK 69
WEEK 70
WgEK 71
WEEK 72
WEEK 73
WEEK 74
WEEK 75
WEEK 76
WEEK 77
WEEK 78
WEEK 79
WEEK 80
WEEK 81
WEEK 82
WEEK 83
WEEK 84
WEEK 85
WEEK 86
WEEK 87
WEEK 88
WEEK 89
WEEK 90
WEEK 91
WEEK 92
WEEK 93
WEEK 94
WEEK 93
WEEK 96
WEEK 97
WEEK 98
WEEK 99
WEEK 100
14.8341211
14.2893362
13.7645584
13.2590534
12.7721129
. 12.3030555
11.8512242
11.4159865
10.9967329
10.5928765
10.2038518
9.82911406
9.4681386
9.12042004
8.78547145
8.4628239
8.15202559
7.85264142
7.56425217
7.28645404
7.01885809
6.76108965
6.5127878
6.27360484
6.04320592
5.82126842
5.60748159
5.40154611
5.20317363
5.0120864
4.82801689
4.65070734
4.47990952
4.3153843
4.15690126
4.00423B5S
3.85718238
3.71552687
3.37907368
3.44763174
3.32101704
3.19905226
3.08156666
2.96839574
2.85938103
2.7543699
2.65321531
2.55577564
2.46191445
2.37150033
108.970403
109.667459
110.338916
110.985714
111.608758
112.208921
112.787043
113.343933
113.880371
114.397108
114.894868
115.374348
115.836219
116.281128
116.709697
117.122527
117.520196
117.90326
118.272257
118.627702
118.970092
119.299909
119.6176^3
119.923649
120.218447
120.302418
120.775959
121.039455
121.293275
121.537772
121.773291
122.00016
122.218697
122.429208
122.631988
122.827322
123.015481
123.196731
123.371324
123.339503
123.701509
123.857564
124.007888
124.132691
124.292176
124.426538
124.555966
124.680641
124.800737
124.916423
.286764218
.2BB59857B
.290365571
.29206767
.29370726
.295286636
.296808008
.298273508
.299685187
.301043022
.302354917
.303616706
.304832156
.306002968
.307130783
.308217178
.309263676
.31027174
.311242783
.312178164
.313079193
.313947133
.314783197
.3155BB556
.316364338
.317111629
.317831476
.318524885
.31919283
.319836245
.320456032
.321053055
.321628153
.3221B213
.322715762
.323229796
.323724953
.324201924
.324661379
.325103961
.325530288
.325940959
.326336548
.326717609
.327084675
.327438262
.327778862
.328106954
.328422997
.328727433
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WEEK 101
WEEK 102
WEEK 103
WEEK 104
WEEK 105
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WEEK 108
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WEEK 112
WEEK- 113
WEEK 114
WEEK 115
WEEK 116
WEEK 117
WEEK 118
WEEK 119
WEEK 120
WEEK 121
WEEK 122
wŁE"K 123
WEEK 124
WEEK 125
WEEK 126
WEEK 127
WEEK 128
WEEK 129
WEEK 130
WEEK 131
WEEK 132
WEEK 133
WEEK 134
WEEK 135
WEEK 136
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WEEK 138
WEEK 139
WEEK 140
WEEK 141
WEEK 142
4EEK 143
WEEK 144
4EEK 145
WEEK 146
-JEEK 147
WEEK 148
AlEEK 149
WEEK 150
2.28440669
2.20051157
2.11969751
2.04185136
.9668641
. 89463077
. 82505022
. 75802502
.69346132
.63126874
1.57136018
1.51365178
1.45806272
1.40451519
.35293418
. 3032475
.25538557
.20928138
.16487037
.12209036
.08088145
.04118595
1.00294827
.966114867
.930634175
.896456516
. .863534035
.831820634
.801271915
.771845104
.743498993
.716193897
.689891586
.66455523
.640149354
.616639789
.593993616
.572179127
.551165774
.53092414
.511425884
.492643704
.474551301
.457123345
. 440335433
.424164058
.408586577
.393581183
.379126864
.365203381
125.02786
125.135205
125.238607
125.338212
125.434159
125.526582
125.615611
125.70137
125.78398
125.863556
125.940209
126.014047
126.085174
126.153688
126.219687
126.283261
126.344501
126.403491
126.460316
126.515053
126.56778
126.618571
126.667496
126.714625
126.760022
1-26.803753
126.845878
126.886455
126.925S42
126.963194
126.999463
127.0344
127.068054
127.100473
127.1317
127.161781
127.190757
127.218668
127.245555
127.271455
127.296403
127.320435
127.343584
127.365883
127.387363
127.408055
127.427986
127.447186
127.46568
127.483495
.329020688
.329303173
.329575284
.329837402
.330089894
.330333113
.3305674
.330793082
.331010477
.331219886
.331421606
.331615917
.331803092
.331983394
.332157072
.332324373
.33248553
.332640769
.332790306
.332934352
.333073108
.333206767
.333335518
.333459541
.333579009
.33369409
.333804944
.333911727
.334014589
.334113672
.334209117
.334301056
.334389618
.334474929
.334557107
.334636266
.334712519
.334785971
.334856725
.334924882
.334990535
.335053777
.335114697
.335173379
.335229906
.335284357
.335336808
.335387333
.335436003
.335482885
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WEEK 151
WEEK 1S2
WEEK 153
WEEK 154
WEEK 155
WEEK 156
WEEK 157
WEEK 158
WEEK 159
WEEK 160
WEEK 161
WEEK 162
WEEK 163
WEEK 164
WEEK 165
WEEK 166
WEEK 167
WEEK 16B
WEEK 169
WEEK 170
WEEK 171
MEEK 172
WEEK 173
WEEK 174
WEEK 175
WEEK 176
WEEK 177
WEEK 178
WEEK 179
WEEK 180
WEEK 181
WEEK 182
WEEK 183
WEEK 184
WEEK 185
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WEEK 187
WEEK 188
WEEK 189
WEEK 190
WEEK 191
WEEK 192
WEEK 193
WEEK 194
WEEK 195
WEEK 196
WEEK 197
WEEK 198
WEEK 199
WEEK 200
.351791241
.338871662
.326426557
.3144385
.302890708
.291767008
.281051826
.270730162
.260787563
.251210105
.241984382
.233097476
.224536942
.216290795
.208347487
.200695899
.193325316
.18622542
.179386267
.172798284
.166452245
.160339264
.154450784
.148778559
.143314648
.1380514
.132981445
.128097684
.12339328
.118861646
.114496437
.110291541
.10624107
.102339353
.0985809274
.0949605303
.0914730932
.0881137323
.0848777443
.0817605982
.0787579299
.0758655345
.0730793632
.0703955146
.0678102305
.0653198912
.0629210096
.0606102277
.0583843093
.0562401382
127.500656
127.517187
127.533111
127.548449
127.563225
127.577458
127.591168
127.604375
127.617096
127.629351
127.641155
127.652526
127.663479
127.67403
127.684194
127.693984
127.703415
127.712499
127.72125
127.729679
127.737799
127.745621
127.753155
127.760413
127.767404
127.774138
127.780626
127.786875
127.792894
127.798692
127.804277
127.809657
127.81484
127.819832
127.824641
127.829274
127.833736
127.838034
127.842174
127.846163
127.850005
127.853706
127.85727
127.860705
127.864012
127.867199
127.870268
127.873225
127.876073
127.878816
.335528045
.335571546
.335613451
.335653816
.335692699
.335730154
.335766234
.335800988
.335834466
.335866714
.335897778
.335927701
.335956525
.335984291
.336011037
.336036801
.336061619
.336085525
.336108554
.336130736
.336152104
.336172687
.336192514
.336211613
.336230011
.336247733
.336264804
.336281249
.336297089
.336312347
.336327046
.336341204
.336354843
.33636798
.336380636
.336392826
.336404569
.33641588
.336426777
.336437273
.336447383
.336457122
.336466504
.336475541
.336484245
.336492631
. 336500708
.336508489
.336515983
.336523203
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WEEK
MEEK
WEEK
WEEK
WEEK
WEEK
WEEK
WEEK
WEEK
WEEK
WEEK
WEEK
WEEK
WEEK
WEEK
WEEK
WEEK
WEEK
WEEK
WEEK
WEEK
WEEK
BEEK
WEEK-
WEEK
WEEK
WEEK
WEEK
WEEK
WEEK-
WEEK
WEEK
WEEK
WEEK
WEEK
WEEK
WEEK
WEEK
WEEK
WEEK
WEEK
WEEK
WEEK
WEEK-
WEEK
WEEK
WEEK
WEEK
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WEEK
201
202
203
204
205
206
207
208
209
210
211
212
213
214
215
216
217
218
219
220
221
222
223
224,
225
226
227
228
229
230
231
232
233
234
235
236
237
238
239
240
241
242
243
244
245
246
247
248
249
250
.0541747119
.0521851388
.0502686327
.0484225109
.0466441881
.0449311743
.0432810713
.0416915685
.0401604403
.0386855431
.0372648116
.0358962567
.0345779621
.0333080822
.0320848385
.0309065187
.029771473
.0286781119
.0276249046
.0266103765
.025633107
.0246917279
.023784921
.0229114168
.0220699921
.0212594689
.0204787121
.0197266288
.0190021658
.0183043088
.0176320808
.0169845403
.016360781
.0157599293
.0151811439
.0146236145
.0140865604
.0135692296
.013070898
.0125908676
.0121284664
.0116830469
.0112539855
.0108406815
.0104425561
.0100590519
9.68963191E-03
9.33377891E-03
B.99099468E-03
B.66079923E-03
127.881459
127.884005
127.886457
127.888819
127.891095
127.893286
127.895398
127.897431
127.89939
127.901278
127.903095
127.904847
127.906533
127.908158
127.909723
127.911231
127.912683
127.914082
127.91543
127.916728
127.917978
127.919183
127.920343
127.921461
127.922537
127.923574
127.924573
127.925536
127.926463
127.927355
127.928216
127.929044
127.929842
127.930611
127.931351
127.932065
127.932752
127.933414
127.934052
127.934666
127.935257
127.935827
127.936376
127.936905
127.937415
127.937905
127.938378
127.938833
127.939272
127.939694
.336530157
.336536856
.33654331
.336549526
.336555514
.336561282
.336566838
.33657219
.336577346
.336582312
.336587096
.336591704
.336596143
.336600419
.336604537
.336608505
.336612327
.336616008
.336619554
.336622971
.336626261
.336629431
.336632484
.336635426
.336638259
.336640988
.336643617
.336646149
.336648589
.336650938
.336653202
.336655382
.336657482
.336659506
.336661454
.336663331
.33666514
.336666882
.33666856
.336670176
.336671733
.336673233
.336674678
.336676069
.33667741
.336678701
.336679946
.336681143
.336682297
.336683409
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WEEK 251
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>»EEK 271
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B.34273032E-03
B.03634249E-03
7.7412067BE-03
7.4S690996E-03
7.18305397E-03
6.9192S54E-03
6.66514488E-03
6.420366S8E-03
6.1845778E-03
5.95744839E-03
5.73B66034E-03
5.52790732E-03
S.324B942E-0?
5.12933679E-03
4.94096123E-03
4.759503BE-03
4.5B47104E-03
4.41633632E-03
4.25414S81E-03
4.09791177E-03
3.94741546E-03
3.80244613E-03
3.6628008IE-03
3.5282B399E-03
3.3987073E-03
3.2738B935E-03
3.15365536E-03
3.03783695E-03
2.926272E-03
2.B1BB042BE-03
2.7152B333E-03
2.61S5642E-03
2.51950727E-03
2.42697B04E-03
2.33784696E-03
2.2519B924E-03
2.16928466E-03
2.08961739E-03
2.01287592E-03
1.93895279E-03
1.86774451E-03
1.79915136E-03
1.7330773E-03
1.66942981E-03
1.60811979E-03
1.54906139E-03
1.49217191E-03
1.43737171E-03
1.3845B405E-03
1.33373503E-03
127.940101
127.940493
127.940871
127.941235
127.941585
127.941923
127.942246
127.942561
127.942863
127.943153
127.943433
127.943703
127.943963
127.944213
127.944454
127.944686
127.94491
127.945125
127.945333
127.945533
127.945725
127.945911
127.946089
127.946261
127.946428
127.946587
127.946741
127.946889
127.947032
127.947169
127.947301
127.947429
127.947552
127.94767
127.947785
127.947895
127.948
127.948102
127.9482
127.948296
127.948386
127.948474
127.948559
127.94864
127.948719
127.948794
127.948867
127.948937
127.949004
127.949069
.33668448
.336685512
.336686505
.336687462
.336688385
.336689274
.336690128
.336690953
.336691746
.336692512
.336693248
.336693958
.336694642
.336695299
.336695934
.336696546
.336697135
.336697702
.336698248
.336698774
.336699281
.336699769
.336700239
.336700691
.336701126
.336701546
.336701952
.336702344
.336702717
.336703079
.336703431
.336703763
.336704087
.3367044
.336704698
.336704991
.336705265
.336705538
.336705792
.336706046
.33670628
.336706515
.336706734
.336706949
.336707157
.336707353
.336707548
.336707731
.336707907
.336708083
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WEEK 301
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-WEEK 322
WEEK 323
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WEEK 346
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WEEK 349
WEEK 350
1
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9.17427759E-04
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8.20016465E-04
7.B9901261E-04
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7.3294B179E-04
7.06030565E-04
6.80101501E-04
6.551246B5E-04
6.31065147E-04
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5.85564393E-04
5.64059466E-04
5.43344311E-04
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5.0416B361E-04
4.85652715E-04
4.67B17056E-04
4.50636415E-04
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3.87995972E-04
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127.9503
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127.950408
127.950423
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w
Wl
WEEK 351
WEEK 352
WEEK 353
WEEK 354
WEEK 355
WEEK 356
WEEK 357
WEEK 358
WEEK 359
WEEK 360
WEEK 361
WEEK 362
WEEK 363
WEEK 364
WEEK 365
WEEK 366
WEEK 367
WEEK 368
WEEK 369
WEEK 370
iEEK 371
EEK 372
WEEK 373
WEEK 374
WEEK 375
WEEK 376
WEEK 377
WEEK 378
WEEK 379
WEEK 380
WEEK 381
WEEK 382
WEEK 383
WEEK 384
WEEK 385
WEEK 386
WEEK 387
WEEK 388
WEEK 389
WEEK 390
WEEK 391
WEEK 392
WEEK 393
WEEK 394
WEEK 395
WEEK 396
WEEK 397
WEEK 398
WEEK 399
WEEK 400
1.97B47875E-04
1.905B1B87E-04
1.83382743E-04
1.76B4O643E-04
1.70346148E-04
1.64090165E-04
1.58063933E-04
1.5225901SE-04
1.466672B3E-04
1.41280908E-04
1.36092349E-04
1.3109434E-04
1.26279884E-04
1.21642239E-04
1.17174913E-04
1.12871649E-04
1.08726424E-04
1.04733432E-04
1.00887083E-04
9.71B1991BE-05
9.36129707E-05
9.01750226E-05
8.6B633335E-OS
8.36732666E-05
8.06003552E-05
7.7640297IE-OS
7.47B8947E-05
7.20423136E-05
6.9396S503E-05
6.68479S3E-05
6.43929533E-05
6.20281141E-05
5.9750123BE-05
S.7555793E-05
5.54420492E-05
5.3405933E-05
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4.95552B3BE-05
4.77353596E-05
4.S9B22725E-05
4.42935676E-05
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3.95905337E-05
3.81365666E-05
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127.95073
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127.95073
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.33671239
-------
WEEK 401
WEEK 402
WEEK 403
WEEK 404
WEEK 405
WEEK 406
WEEK 407
WEEK 408
WEEK 409
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WEEK 411
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WEEK 414
WEEK 415
WEEK 416
WEEK 417
WEEK 41B
WEEK 419
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WŁEK 422
WEEK 423
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WEEK 426
WEEK 427
WEEK 428
WEEK 429
WEEK 430
WEEK 431
WEEK 432
WEEK 433
WEEK 434
WEEK 435
WEEK 436
WEEK 437
WEEK 438
WEEK 439
WEEK 440
WEEK 441
WEEK 442
WEEK 443
WEEK 444
WEEK 445
WEEK 446
WEEK 447
WEEK 448
WEEK 449
WEEK 450
3.04679326E-05
2.93489939E-05
2.82711484E-05
2.7232B869E-05
2.62327558E-05
2.52693543E-05
2.4341334E-05
2.34473955E-05
2.25B62869E-05
2.17568025E-05
2.09577812E-05
2.0188104IE-OS
1.94466934E-05
1.8732S11IE-OS
1.80445573E-05
1.73818686E-05
1.6743S172E-05
1.61286094E-05
1.55362842E-05
1.49657121E-05
1.44160944E-05
1.38866615E-05
1.33766721E-05
1.28854121E-05
1.24121937E-05
1.19563543E-05
1.15172555E-05
1.10942829E-05
1.06B68439E-05
1.029436B2E-05
9.91630626E-O6
9.55212B61E-06
9.2013255E-06
8.86340564E-06
8.537B9592E-06
B.2243406E-06
7.92230062E-06
7.6313531E-06
7.35109071E-06
7.0811209BE-06
6.B2106591E-06
6.5705614E-06
6.32925667E-06
6.09681392E-06
5.87290766E-06
5.6572243BE-06
5.44946209E-06
5.2493299E-06
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127.95073
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-------
WEEK
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-------
WEEK 501
WEEK 502
WEEK 503
WEEK 504
MEEK 505
WEEK 506
WEEK 507
WEEK 508
WEEK 509
WEEK 510
WEEK 511
WEEK 512
WEEK 513
WEEK 514
WEEK 515
WEEK 516
WEEK 517
WEEK 518
WEEK 519
WEEK 520
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5605502BE-07
35633B35E-07
15962613E-07
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7B760924E-07
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3.6B44300BE-07
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127.95073
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-------
RECIRCULAT1UN KM It • 1.=, toi-n
WEEK 1
WEEK 2
WEEK 3
WEEK 4
WEEK 5
WEEK 6
WEEK 7
WEEK 8
WEEK 9
WEEK 10
WEEK 11
WEEK 12
WEEK 13
WEEK 14
WEEK 15
WEEK 16
WEEK 17
WEEK 18
WEEK 19
WEEK 20
WEEK 21
WEEK 22
WEEK 23
WKK 24
WEEK 25
WEEK 26
WEEK 27
WEEK 28
WEEK 29
WEEK 30
WEEK 31
WEEK 32
WEEK 33
WEEK 34
WEEK 35
WEEK 36
WEEK 37
WEEK 3B
WEEK 39
WEEK 40
WEEK 41
WEEK 42
WEEK 43
WEEK 44
WEEK 45
WEEK 46
WEEK 47
WEEK 48
WEEK 49
WEEK SO
PPM VOC IN
GROUNDWATER
97.7573761
95.5650461
93.4218817
91.3267801
89.2786639
87.2764795
85.3191963
83.4058074
81.5353289
79.7067981
77.9192744
76.1718378
74.4635898
72.7936517
71.161164
69.5652868
68.0051989
66.4800983
64.9891995
63.5317362
62.1069584
60.7141329
59.3525432
58.021489
56.720285
55.4482623
54.2047664
52.9891575
51.8008098
50.6391122
49.5034673
48.3932907
47.3080113
46.2470706
45.2099228
44.1960342
43.2048834
42.2359603
41.2887666
40.3628149
39.4576288
38.5727424
37.7077008
36.8620588
36.0353816
35.2272435
34.4372288
33.6649316
32.9099538
32.1719074
VOC V.PH.
REMOVED
2.84027344
5.61685023
8.33115887
10.9845958
13.578526
16.1142842
18.5931749
21.0164734
23.3854263
25.7012526
27.9651436
30.1782641
32.3417525
34.456722
36.5242608
38.5454324
40.5212767
42.4528103
44.3410269
46.1868979
47.9913729
49.7553804
51.4798278
53.1656023
54.8135712
56.4245825
57.9994647
59.5390283
61.0440654
62.5153499
63.9536391
65.359673
66.7341748
68.0778519
69.3913951
70.6754806
71.9307687
73.1579055
74.3575222
75.530236
76.6766505
77.7973549
78.8929262
79.963928
81.0109113
82.0344148
83.0349648
84.0130763
84.9692523
85.903985
VOC L.PH
REMOVED
7.4744037BE-03
.014781184B
.0219241022
.02B9068308
.0357329633
.0424060112
.0489294076
.05S306508B
.0615405957
. 0676348754
.0735924833
.0794164844
.0851098751
.0906755847
.0961164763
.101435349
.106634939
.111717922
.116686913
.121544468
.126293087
.130935212
.135473231
.1399094B
.14424624
.148485743
.15263017
.156681653
.160642277
.164514079
.168299051
.17199914
.17561625
.179152242
.182608935
.1B598B107
.189291498
.192520805
.195677691
.19876378
.20178066
.204729882
.207612964
.21043139
.21318661
.21588004
.218513066
.221087043
.223603297
.22606312
-------
WEEK 51
WEEK 52
WEEK 53
WEEK 54
WEEK 55
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31.4504125
30.7450981
30.0556012
29.3815673
28.7226492
28.0785083
27.448813
26. 8332393
26.2314706
25.6431972
25.0681168
24.5059331
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23.4191063
22.8939038
22.3804796
21.8785696
21.3879156
20.9082651
20.4393714
19.9809931
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19.0948452
18.6666197
18.2479976
17.8387636
17.4387072
17.0476226
16.6653086
16.2915684
15.9262098
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15.2198897
14.8785648
14.5448946
14.2187073
13.8998352
13.5881141
13.2833838
12.9854875
12.6942719
12.4095872
12.1312868
1 1 . 8592277
11.5932698
1 1 . 3332764
11.0791136
10.8306508
10.5877601
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86.8177553
87.7110328
88.5842778
89.4379392
90.2724561
91.0882581
91.8857645
92.6653859
93.4275231
94.1725685
94.9009053
95.6129082
96.3089437
96.9893697
97.6545363
98.3047857
98.9404526
99.5618638
100.169339
100.763191
101.343725
101.91124
102.466028
103.008373
103.538556
104.05685
104.563519
105.058826
105.543025
106.016366
106.479091
106.931439
107.373642
107.805928
108.22852
108.641635
109.045485
109.440278
109.826218
110.203503
110.572326
110.932878
111.285344
111.629906
111.96674
112.296021
112.617917
112.932594
113.240214
113.540935
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WEEK 101 10.1181978
WEEK 102 9.89128463
WEEK 103 9.66946036
WEEK 104 9.45261073
WEEK 105 9.24062427
WEEK 106 9.03339178
WEEK 107 8.83080681
WEEK 108 8.63276502
WEEK 109 8.43916459
WEEK 110 8.24990587
WEEK 111 8.06489138
WEEK 112 7.88402619
WEEK 113 7.70721714
WEEK 114 7.53437323
WEEK 115 7.3654056
WEEK 116 7.20022725
WEEK 117 7.03875324
WEEK 118 6.8809004B
WEEK 119 6.72658776
WEEK 120 6.57573571
WEEK 121 6.42826672
WEEK 122 6.2841048B
WEEK 123 6.14317603
WEEK 124 6.00540769
WEEK 125 5.87072899
WEEK 126 5.73907062
WEEK 127 5.61036484
WEEK 128 5.48454546
WEEK 129 5.36154773
WEEK 130 5.24130837
WEEK 131 5.12376553
WEEK 132 5.00885875
WEEK 133 4.89652888
WEEK 134 4.78671815
WEEK 135 4.67937006
WEEK 136 . 4.5744294
WEEK 137 4.47184216
WEEK 138 4.37155554
WEEK 139 4.27351799
WEEK 140 4.17767906
WEEK 141 4.08398942
WEEK 142 3.9924009
WEEK 143 3.90286636
WEEK 144 3.81533975
WEEK 145 3.72977603
WEEK 146 3.64613117
WEEK 147 3.56436216
WEEK 148 3.48442693
WEEK 149 3.40628434
WEEK ISO 3.329B942
113.834912
114.122297
114.403236
114.677875
114.946355
115.208814
115.465387
115.716206
115.961401
116.201096
116.435416
116.664481
116.888409
117.107315
117.321312
117.530509
117.735016
117.934936
118.130372
118.321425
118.508194
118.690775
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119.043743
119.214313
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119.703413
119.859189
120.011472
120.160339
120.305868
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120.587208
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120.856071
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121.358554
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121.593208
121.706603
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122.335521
122.432269
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.320280537
.320572253
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.321408731
.321675146
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3.2552172
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3.04108518
2.972BB50B
2.90621445
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2.36959149
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122.619304
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122.88442
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123.051402
123.132096
123.210979
123.288094
123.363479
123.437173
123.509215
123.579641
123.648488
123.715791
123.781585
123.845903
123.908778
123.970244
124.030331
124.089071
124.146493
124.202627
124.257503
124.311148
124.36359
124.4J4856
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124.561858
124.608677
124.654447
124.69919
124.742929
124.785688
124.827488
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125.05932
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.329007473
.329103478
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.329378763
.32946644
.32955215
.329635939
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1.0472655
1.02377927
1.00081975
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125.323209
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125.491968
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125.543307
125.568116
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125.639255
125.661913
125.684062
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125.726882
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125.767802
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126.049921
126.063368
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126.089366
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126.203048
126.213062
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.332086334
.33211329
.332139642
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.336925277
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126.222851
126.232421
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126.250921
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126.277144
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126.301643
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126.317073
126.32453
126.331819
126.338945
126.345911
126.352721
126.359378
126.365886
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126.384547
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126.40198
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126.41296
126.418266
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126.433482
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126.443065
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126.473381
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.332892757
.332901629
.332910301
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.10B3952B9
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*333037018
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.33315615
.33316107
.333163924
.333166714
.333169441
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.0348728335
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126.6054
126.60639
126.607359
126.608305
126.60923
126.610135
126.611019
126.611884
126.612729
126.613555
126.614363
126.615152
126.615924
126.616678
126.617416
126.618137
126.618842
126.619531
126.620204
126.620863
126.621506
126.622136
126.622751
126.623352
126.62394
126.624515
126.625077
126.625626
126.626163
126.626688
126.627201
126.627702
126.628193
126.628672
126.629141
126.629599
126.630046
126.630484
126.630912
126.63133
126.631739
126.632139
126.63253
126.632912
126.633285
126.633651
126.634008
126.634356
126.634698
126.635031
.333172108
.333174714
.333177263
.333179753
.333182188
.333184569
.333186896
.333189171
.333191395
.333193569
.333195695
.333197771
.333199803
.333201788
.333203729
.333205626
.333207481
.333209294
.333211067
.3332128
.333214494
.33321615
.333217768
.333219351
.333220898
.333222411
.333223889
.333225334
.333226748
.333228128
.333229478
.333230798
.333232089
.33323335
.333234583
.333235788
.333236968
.333238119
.333239245
.333240347
.333241423
.333242474
.333243502
.333244508
.333245491
.333246453
.333247393
.33324831
.333249208
-------
WEEK 401
WEEK 402
WEEK 403
WEEK 404
WEEK 40S
WEEK 406
WEEK 407
WEEK 408
WEEK 409
WEEK 410'
WEEK 411
WEEK 412
WEEK 413
WEEK 414
WEEK 415
WEEK 416
WEEK 417
WEEK 418
WEEK 419
WEEK 420
WEEK 421
WEEK 422
WEEK 423
WEEK 424
WEEK 425
WEEK 426
WEEK 427
WEEK 428
WEEK 429
WEEK 430
WEEK 431
WEEK 432
WEEK 433
WEEK 434
WEEK 435
WEEK- 436
WEEK 437
WEEK 438
WEEK 439
WEEK 440
WEEK 441
WEEK 442
MEEK 443
WEEK 444
4EEK 445
4EEK 446
4EEK 447
4EEK 448
WEEK 449
4EEK 450
.0112192557
.0109676499
.0107216868
.0104812397
.0102461849
.0100164016.
9.7917713BE-03
9.37217875E-03
9.33731076E-03
9.14765697E-03
8.94250941E-03
8.74196256E-03
8.S459132E-03
6.35426051E-03
8.1669058BE-03
7.9837S2BBE-03
7.80470732E-03
7.62967709E-03
7.45857213E-03
7.29130441E-03
7.1277B787E-03
6.96793837E-03
6.B1167373E-03
6.6S89135E-03
6.50957912E-03
6.36359373E-03
6.220BB224E-03
6.08137124E-03
5.94498896E-03
S.B1166523E-03
5.6B13314E-03
5.55392053E-03
5.4293669BE-03
5.3076067E-03
3.18B5770SE-03
5.07221679E-03
4.93846605E-03
4.8472663E-03
4.73856033E-03
4.63229224E-03
4.S2840736E-03
4.42685221E-03
4.32757456E-03
4.230S2333E-03
4.13564861E-03
4.0429015BE-03
3.95223449E-03
3.86360075E-03
3.77695472E-03
3.692251B4E-03
126.635357
126.635676
126.635987
126.636292
126.636589
126.636881
126.637165
126.637443
126.637715
126.637981
126.63824
126.638494
126.638743
126.638985
126.639223
126.639455
126.639681
126.639903
126.64012
126.640332
126.640539
126.640741
126.640939
126.641133
126.641322
126.641507
126.641687
126.641864
126.642037
126.642206
126.642371
126.642532
126.64269
126.642845
126.642995
126.643142
126.643287
126.643427
126.643565
126.6437
126.643831
126.64396
126.644085
126.644208
126.644328
126.644446
126.644561
126.644673
126.644783
126.64489
.333250943
.333251782
.333252602
.333253404
.333254186
.333254951
.333255699
.333256431
.333257147
.333257847
.333258532
.333259198
.333259851
.333260491
.333261117
.333261725
.333262322
.333262908
.333263475
.333264033
.333264581
.33326511
.333265633
.333266141
.333266638
.333267127
.3332676
.333268069
.333268519
.333268968
.333269398
.333269827
.333270238
.333270648
.33327104
.333271431
.333271808
.333272179
.333272542
.333272894
.333273246
.333273379
.333273911
.333274236
.333274549
.333274862
.333275162
.333275456
.333275749
.333276029
-------
WEEK 451
WEEK 452
WEEK 453
WEEK 454
WEEK 455
WEEK 456
WEEK 457
WEEK 458
WEEK 459
WEEK 460
WEEK 461
WEEK 462
WEEK 463
WEEK 464
WEEK 465
WEEK 466
WEEK 467
WEEK 468
WEEK 469
WEEK 470
WEEK 471
WJEEK 472
WEEK 473
WEEK 474
WEEK 475
WEEK 476
WEEK 477
WEEK 478
WEEK 479
WEEK 480
WEEK 481
WEEK 482
WEEK 483
WEEK 484
WEEK 485
WEEK 486
WEEK 487
WEEK 488
WEEK 489
WEEK 490
WEEK 491
WEEK 492
WEEK 493
WEEK 494
WEEK 495
WEEK 496
WEEK 497
WEEK 498
WEEK 499
WEEK 500
3.60944B53E-03
3.52850217E-03
3.44937115E-03
3.37201473E-03
3.29639313E-03
3.22246743E-03
3.15019959E-03
3.07955245E-03
3.0104B967E-03
2.94297571E-03
2.87697585E-03
2.B1245609E-03
2.74938329E-03
2.68772496E-03
2.62744941E-03
2.56B52S59E-03
2.51092323E-03
2.45461266E-03
2.39956493E-03
2.34575172E-03
2.29314532E-03
2.2417187E-03
2.19144539E-03
2.14229951E-03
2.09425579E-03
2.047289S1E-03
2.00137652E-03
1.95649317E-03
1.91261639E-03
1.86972359E-03
1.B2779273E-03
1.78680221E-03
1.74673096E-03
1.70755B35E-03
1.66926424E-03
1.63182893E-03
1.59523314E-03
1.55945B07E-03
1.5244B529E-03
1.490296B2E-03
1.45687507E-03
1.42420284E-03
1.39226333E-03
1.3610401E-03
1.33051709E-03
1.30067B6E-03
1.27150927E-03
1.2429941E-03
1.21511841E-03
1.1878678BE-03
126.644995
126.645097
126.645197
126.645296
126.645391
126.645486
126.645576
126.645666
126.645753
126.645838
126.645924
126.646004
126.646084
126.646163
126.646238
126.646313
126.646387
126.646457
126.646527
126.646596
126.646661
126.646726
126.646792
126.646853
126.646913
126.646973
126.647033
126.647088
126.647143
126.647198
126.647253
126.647303
126.647353
126.647403
126.647453
126.6475
126.647545
126.64759
126.647635
126.64768
126.647722
126.647762
126.647802
126.647B42
126.647882
126.647921
126.647956
126.647991
126.648026
126.648061
.333276302
.333276576
.333276839
.333277094
.333277348
.333277599
.333277834
.333278068
.333278303
.333278528
.333278744
.333278959
.333279174
.33327938
.333279575
.333279771
.333279966
.333280161
.333280337
.333280513
.333280689
.333280865
.333281038
.333281194
.333281351
.333281507
.333281664
.33328182
.333281964
.333282101
.333282238
.333282375
.333282512
.333282649
.333282779
.333282897
.333283014
.333283131
.333283249
.333283366
.333283483
.333283601
.333283699
.333283797
.333283B95
.333283993
.333284091
.333284188
.3332B42B6
.333284384
-------
WEEK 501
WEEK 902
WEEK 303
WEEK 504
WEEK 505
WEEK 506
WEEK 507
WEEK SOB
WEEK 30t
WEEK 510
WEEK 511
WEEK 512
WEEK 513
WEEK 514
WEEK 515
WEEK 516
WEEK 517
WEEK 5 IB
WEEK 519
WEEK 520
1.16122847E-03
1.1331864BE-03
1.109728S2E-03
1.0848414BE-03
1.06051257E-03
1.03672926E-03
1.01347932E-03
9.907S0793E-04
9.6B531981E-04
9.4681145E-04
9.25578031E-04
9.04B2079SE-04
8.84S29069E-04
8.6469241E-04
8.45300613E-04
8.263437E-04
8.07B11921E-04
7.B9695743E-04
7.71985839E-04
7.S467309BE-04
126.648096
126.648131
126.648162
126.648192
126.648222
126.648252
126.648282
126.648312
126.648342
126.646369
126.648394
126.648419
126.648444
126.648469
126.648494
126.648519
126.648544
126.648569
126.648591
126.648611
.333284479
.333284558
.333284636
.333284714
.333284792
.333284871
.333284949
.333285027
.333285105
.333285164
.333285262
.333285339
.333285398
.333285457
.333285515
.3332B5574
.333285633
.333285691
.33328575
.333285809
-------
TABLE 5
VALLEY MANUFACTURED PRODUCTS COMPANY, INC.
GROUNDWATER TREATMENT COST COMPARISON
EPA PS VS. PROPOSED TREATMENT PLAN
(EPA GW-3)
30 GPM (PS)
(PROPOSED)
3 GPM
Mobilization
Site Preparation
Concrete Pad
Equipment ('Supplies
Air Stripping Tower
Storage Tanks
Carbon canisters :
' Building
Analytical Equipment
Equipment Installation
Services Cost
Instrumentation
Piping
, Electrical
Groundwater Monitoring
Sampling
Equipment
Shipping
Analysis
Validation
Groundwater Treatment 0 & M
Labor
Chemicals
H.2S04
Carbon
Maintenance
Power
Sample & Analysis
Groundwater Recovery System
Recovery Wells
Reinjeetion Hells
Replace Reinjeetion wells
10,000
5,000
35,000
10,000
8,000
40,000
20,000
18,550
164,438
8,400
1,200
1,067
16,000
7,200
52,000
220
20,000
23,566
1,600
8,256
98,000
70,000
12,668
3,000
7,000
1,000
10,800
17,000
500
5,000
20,000
1,200
10,500
8,300
6,240
4,420
6,240
25,000
10,000
1,600
4,420
20,000
Page 1 of 2
-------
VALLEY MANUFACTURED PRODUCTS COMPANY, INC.
GROUNDWATER TREATMENT COST COMPARISON
EPA PS VS. PROPOSED TREATMENT PLAN
Total Capital
Trtatability Study
Contractor Pee
Legal Pees, Licensing, Permit*
Engineering Administration 15%
Sub Total
Contingency 10%
TOTAL CONSTRUCTION COST
Present Worth of 0 i M Costs
(EPA GH-3)
30 GPM (PS)
478,988
50,000
528,988
52,899
52,899
79,348
. 714,134
71,413
785,547
1,530,323
2,315,870
(PROPOSED)
3 GPM
104,300
50,000
154,300
23.145
177,445
17,744
195,189
293,539
488,728
Page 2 of 2
-------
APPENDIX G
RESULTS OF GROUNDWATER
SAMPLING AND ANALYSIS -
AUGUST 4, 1988 SAMPLING ROUND
-------
M. Anthony Lally Associates AUG 2 * 1988
Consulting Environmental Engineers M.g.P. M. Anthony L*IIV. P.E.
100 Belmont Street North Andover, Massachusetts 01845 Tel. (508) 688-1763
August 23, 1988
Mr. James Ciriello
Remedial Project Manager
U.S. Environmental Protection Agency
Waste Management Division
90 Canal Street 2nd Floor
Boston, MA 02114
Re: Modification No. 1 (August 2, 1988) to the
Administrative Order by Consent
U.S. EPA Docket No. 1-87-1091
Groveland Resources Corporation and
Valley Manufactured Products Company, inc.
Dear Mr. Ciriello:
In accordance with the referenced Modification No. 1 to the :
Administrative Order by Consent, we.are submitting the following'
Letter Report. This Letter Report is being submitted on behalf of
Valley Manufactured Products Company, Inc. As stipulated in the
Administrative Order, we are submitting three (3) copies for' use
and distribution by EPA.
On August 4, 1988 a round of groundwater samples was taken from
the following monitoring wells: TW-8, TW-26, TW-3, TW-22, TW-9,
TW-17 AND TW-23. Groundwater samples taken from these monitoring
wells were submitted to a State Certified Laboratory for analysis
of soluble priority pollutant metals.
The procedures which were followed during the groundwater sampling
round are contained in the Consent Order, Attachment II, Sampling
Procedures.
Water levels, specific conductance, temperature and pH
measurements were taken in all monitoring wells prior to purging
the well for sampling and again, immediately before samples were
collected. This groundwater sampling data is compiled in Table 1
of this correspondence.
Water table elevations were measured in additional monitoring
wells TW-11, TW-15 and TW-16. Monitoring well TW-25 was sampled
and analyzed for volatile organic compounds. Monitoring well TW-9
was sampled and analyzed for hexavalent chromium. The analytical
results for the groundwater samples have been summarized in Table
2 of this correspondence. The data from which Table 2 was
compiled is attached to this correspondence for reference. •
Water • Wastewater • Solid Waste • Site Development
-------
Mr. James ciriello
August 23, 1986
Page TWO
During the groundvater monitoring round, oil, grease and liquid
phase separation were not detected in any of the monitoring wells
which were sampled.
Split samples of monitoring wells TW-9, TW-17, TW-23 and TW-25
were provided to the Department of Environmental Quality
Engineering.
If you have any questions or require additional information
regarding this report, please do not hesitate to contact this
office.
Very truly yours,
M. ANTHONY LALLY ASSOCIATES
John L. Falcone, Jr.
JLF/jk
Enclosures
cc: Attorney Martin C. Pentz,-"
Nutter, Mcclennen & Fish
Mr. Thomas Quinlan, President,
Valley Manufactured Products, Inc.
-------
TABLE NO. 1
Groundwater Sampling Data
Valley Manufactured Products Company,
Administrative Order By Consent
U.S. EPA Docket No. 1-87-1091
Modification No. 1
Inc.
Initial
Final
Location
TW-25
TW-8
TW-26
TW-3
TW-22
TW-9
TW-17
TW-23
*TW-16
*TW-15
•TW-11
Water Level
Feet
45.64
31.81
31.65
33.20
19.84
23.81
35.40
24.84
30.10
Dry
26.40
pH Sp. Cond
nmhos/cm
6.25
6.31
7.02
6.09
7.14
6.50
6.30
5.93
660
440
420
640
500
300
470
520
. Temn .
56°
56°
60°
56°
60°
60°
58°
62°
••
PH
6.30
7.30
6.32
6.32
7.20
6.24
6.20
6.01
•MM^^^^B
Sp. Cond. Temp.
mmhos/cm . F
600
520
400
720
520
320
540
800
54°
55°
60?
60°
60°
60°
58°
62°
• These, wells were not sampled during this sampling round.
-------
TABLE NO. 2
Groundwater Sample Analysis Results*
Valley Manufactured Products Co., Inc.
Administrative Order by Consent
U.S. EPA Docket Mo. 1-87-1091
Modification
Antimony
Arsenic
Beryllium
Cadmium
Chromium
Copper
Lead
Mercury
Nickel
Selenium
Silver
Thallium
Zinc
Hex. Chromium
VOC
TW 3
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
0.01
NT
NT
TW 8
ND
ND
ND
ND
ND
ND
0.06
ND
ND
ND
ND
ND
0.04
NT
NT
TW 9
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
0.12
ND
NT
TW 17
ND
ND
ND
ND
ND
0.07
0.08
ND
ND
ND
ND
ND
0.25
NT
NT
NO. 1
TW 22
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
NT
NT
TW 23
ND
ND
ND
ND
ND
0.03
ND
ND
ND
ND
ND
ND
0.18
NT
NT
TW 25
NT
NT
NT
NT
NT
NT
V
NT
NT
NT
NT
NT
NT
NT
NT
53.7
TW 26
ND
0.010
Of% j\ •
.007
ND
ND
ND
ND
ND
•ND
ND
ND
ND
ND
0.09
0.04
NT
NT
* Concentrations are expressed in milligrams per liter (mg/1 or ppm)
NT - Not Tested
ND « Not Detected
-------
ALHft ANALYTICAL IABORATCRDES
200 Homer Avenue
Ashland Technology Center
Ashland, Massachusetts 01721
(617) 881-3503
CERTIFICA2E OF ANALYSIS
Client: M. A. Lally Associates Job Number: 881555
Address: 100 Belnont Street Invoice Hunter: 5213
Andover, MA 01845 Date In: 08/05/88
Atta: Jay Falcone Date Reported: 08/18/88
Sample Description: Eight water samples
REFERENCES:
1. Test Methods for Evaluating Solid Waste: Physical/Chemical Methods.
EPA SW-846. 1986.
2. Standard Methods for Examination of Water and Waste Water. APHA-AWWA-WPCF.
16th Edition. 1985.
3. Methods for Chemical Analysis of Water and Wastes. EPA 600/4-82-055.
1982.
4. Oil Spill Identification System. CG-D-52-77 U. S. Coast Guard. 1977.
Authorized by:
Scott McLean—Laboratory Director
-------
AUHA ANALYTICAL LABORATORIES
CggiFICAIE OF ANALYSIS
Client: M. A. LaUy Associates Sample Number: 881555.1
Analysis Requested: Volatile Halocarbons (601) Dote Received: 08/05/88
Date Reported: 08/18/88
Client Idant: W-25
Sanple Location:
Sanple Description: Water
Sasple Container: VGA vials f of Containers: 2
Field Prep: Hone
PARAMETER RESULT UNITS MDL* INST RET** METHOD EXTOACT ANALYSIS
Volatile Kalocaztnns
1,2-Dichloroethylene 5,500 ug/L 500 GC l 8010 08/18/88
ttrichloroethylene 48,200 ug/L 500 GC 1 8010 08/18/88
A list of volatile halocarbons analyzed for and their detection limits
accorrpanies this report.
* MDL—Method Detection Limits (sane units as the Results)
** KB*—Reference as cited on the cover (first) page of this report.
-------
ALPHA ANALYTICAL lABORATDRIES
CERTIFICATE OF ANALYSIS
Client: M. A. Lilly Associates
Analysis Requested: Soluble Priority Pollutant
13 Metals
Client Zdent: TW-26
Sa&ple location:
Sample Description: Water
Sample Container: Plastic bottle
Field Prep: None
Saaple Number: 881555.2
Date Deceived: 08/05/88
Date Reported: 08/18/88
i of Containers: 1
PARAMETER
RESULT UNITS MDL* DOT REF** METHOD EXTRACT ANALYSIS
Soluble Priority
Antimony
Arsenic
Beryllium
Cadmium
Chromium
Copper
Lead
Mercury
Nickel
Selenium
Silver
Thallium
Zinc
Pollutant 13
ND
0.010
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
0.09
Metals
mg/L
mg/L
mg/L
ng/L
mg/L
mg/L
mg/L
ng/L
mg/L
mg/L
mg/L
mg/L
mg/L
0.50 ICP
0.005 HGA
0.02 ICP
0.01 ICP
0.02 ICP
0.02 ICP
0.05 ICP
0.0005 CV
0.05 ICP
0.005 HGA
0.003 HGA
0.50 ICP
0.01 ICP
1
1
1
1
1
1
'1
1
1
1
1
1
1
6010 -
7060 —
6010 -
6010 -
6010 -
6010 -
6010 -
7040 —
6010 -
7740 -
7761 -
6010 -
6010 -
08/10/88
08/10/88
08/10/88
08/10/88
08/10/88
08/10/88
08/10/88
08/10/88
08/10/88
08/10/88
08/10/88
08/10/88
08/10/88
* MDL—Method Detection Limits (same units as the Results)
** KEF—Reference as cited on the cover (first) page of this report.
-------
ALPHA ANALYTICAL LABORATORIES
CLKI'll-lCAIE OF ANALYSIS
Client: M. A. Lally Associates
Analysis Requested: Soluble Priority Pollutant
13 Metals
Saopl* Description: Water
Sample container: Plastic bottle
Field Prep: Nans
Saxple Nuaber: 881555.3
Cat* Received: 08/05/88
Date Reported: 08/18/88
f of
PARAMETER
RESULT UNITS HDL* INST RET** METHOD BORACT ANALYSIS
Soluble Priority
Antimony
Arsenic
Beryllium
Cadmium
Q uranium
Copper
Lead
Mercury
Nickel
Selenium
Silver
Thallium
Zinc
Pollutant 13 Metals
ND
ND •
ND
ND
ND
ND
0.06
ND
ND
ND
ND
ND
0.04
ing/L
ng/L
itg/L
ng/L
ng/L
*g/L
ng/L
ng/L
ng/L
ng/L
ng/L
ng/L
ng/L
0.50 ICP
0.005 H3A
0.02 ICP
0.01 ICP
0.02 ICP
0.02 ICP
0.05 ICP
0.0005 CV
0.05 ICP
0.005 ICA
0.003 ICA
0.50 ICP
0.01 ICP
1
1
1
1
1
1
1
1
1
1
1 •
1
1
6010 -
7060 -
6010 -
6010 -
6010 -
6010 -
6010 -
7040 -
6010 -
7740 -
7761 -
6010 -
6010 -
08/10/88
— 08/10/88
08/10/88
08/10/88
08/10/88
08/10/88
08/10/88
08/10/88
08/10/88
08/10/88
08/10/88
08/10/88
08/10/88
*
**
MDL—Mcthod Detection Limits (sane units as the Results)
RET— Reference as cited on the cover (first) page of this report.
-------
Alfffl ANALYTICAL IABORATORIES
OF ANALYSIS
Client: M. A. lally Associates Sample Number: 881555.3S
Analysis Requested: Soluble Priority Pollutant Date Received: 08/05/88
13 Metals, Spike Recovery
Date Reported: 08/18/88
Client Merit: TW-8
Ssnple Location:
Sanple Description: Water
Container: Plastic bottle f of Containers: 1
Field Prep: Hone
FABAMEXER
Antimony 94%
Arsenic 120%
Beryllium 80%
Cadmium 90%
Chromium 92%
Copper 88%
I«>»^ 86%
Mercury 80%
Nickel 92%
Selenium 84%
Silver 115%
Thallium ' 124%
Zinc 91%
* MDL—Method Detection Limts (same units as the Results)
** RET—Reference as cited on the cover (first) page of this report.
-------
ALPHA ANALYTICAL LABORATORIES
CERTinCAIE OF ANALYSIS
Client: M. A, Lally Associates
Analysis Requested: Soluble Priority Pollutant
13 Metals and Hexavalent Chromium
Client Zosnt: TW-9
Saaple Number: 881555.4
Oat* Received: 08/05/88
1: 08/18/88
Saople Description: Water
Sample Container: Plastic bottle
Field Ifcep: Horn
f of Containers: 1
PARAMEHB
Soluble Priority
Antimony
Arsenic
Beryllium
Cadmium
Qu.und.un
Copper
Lead
Mercury
Nickel
Selenium
Silver
Thallium
Zinc
RESULT
PoUutant 13
NO
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
0.12
Hexavalent Chromium ND
UNITS
Mitals
ng/L
ng/L
nj/L
ng/L
mg/L
no/L
ng/L
ng/L
ng/L
ng/L
ng/L
ng/L
ng/L
ng/L
HDL* INST REF**
0.50 ICP
0.005 »A
0.02 ICP
0.01 ICP
0.02 ICP
0.02 ICP
0.05 ICP
0.0005 CV
0.05 ICP
0.005 HA
0.003 HA
0.50 ICP
0.01 ICP
0.01 Spect
1
1
1
1
1
1
1
1
1
1
1
1
1 •
2
MEDOD
6010
7060
6010
6010
6010
6010
6010
7040
6010
7740
7761
6010
6010
312B
DOTACT ANALYSIS
08/10/88
08/10/88
08/10/88
08/10/88 '
08/10/88
08/10/88
08/10/88
08/10/88
— 1 — 08/10/88
— f- 08/10/88
— — 08/10/88
08/10/88
08/10/88
08/05/88
* KDL—Method Detection Limits (sane units as the Results)
** RET—Reference as cited on the cover (first) page of this report.
-------
ALPHA ANALmCAL LABORATORIES
OF ANALYSIS
Client: M. A. LaUy Associates
Analysis Requested: Soluble Priority Pollutant
13 Metals
Client Ident: 1W-17
Sanple Location:
Satsple Description: Water
Sample Container: Plastic bottle
Field Prep: None
Sample Kuaben 881555.5
Date Received: 08/05/88
Date Reported: 08/18/88
f of Containers! 1
PARAMETER
RESULT UNITS KDL* INST REP** KEIHOD DOBACT ANALYSIS
Soluble Priority Pollutant 13
Antimony
Arsenic
Beryllium
Cadmium
Qiromium
Copper
Lead
Mercury
Nickel
Selenium
Silver
Thallium
Zinc
ND
ND
ND
ND
ND
0.07
0.08
ND
ND
ND
ND
ND
0.25
Metals
ng/L
wg/L
ng/L
ng/L
ng/L
ng/L
wg/L
wg/L
ng/L
wg/L
mg/L
wg/L
ng/L
0.50 ICP
0.005 HGA
0.02 ICP
0.01 ICP
0.02 ICP
0.02 ICP
0.05 ICP
0.0005 CV
0.05 ICP
0.005 HGA
0.003 HGA
0.50 ICP
0.01 ICP
1
1
1
1
1
1
1
1
1
1
1
1
1
6010 —
7060 —
6010 -
6010 -
6010 -
6010 -
6010 —
7040 -
6010 -
7740 —
7761 -
6010 -
6010 -
08/10/88
08/10/88
08/10/88
08/10/88
08/10/88
08/10/8.8
08/10/88
08/10/88
08/10/88
08/10/88
08/10/88
08/10/88
08/10/88
* KDL—Method Detection Lmits (same units as the Results)
** REF—Reference as cited on the cover (first) page of this report.
-------
ALPHA ANA
CERTIFICATE OF ANALYSIS
Client: M. A. Lally Associates
Analysis Requested: Soluble Priority Pollutant
13 Metals
Client Xdent: IW-23
location:
Description: water
container: Plastic bottle
Field Prep: None
Saaple Number: 881555.6
Date Received: 08/05/88
Date Reported: 08/18/88
f of Containers: 1
PARAMETER
RESULT UNITS MDL* ZNST KEF1** METHOD EXTRACT ANALYSIS
Soluble Priority
Antimony
Arsenic
Beryllium
Cadniun
ChroniuD
Copper
— «r *
lead
Mercury
Nickel
Selenium
Silver
•JVuilHvlBI
Zinc
Pollutant 13
ND
ND
ND
ND
ND
0.03
ND
ND
ND
ND
ND
ND
0.18
Metals
ng/L
mg/L
ng/L
ng/L
ng/L
ng/L
ng/L
ng/L
ng/L
ng/L
ng/L
ng/L
ng/L
0.50 ICP
0.005 HSA
0.02 ICP
0.01 ICP
0.02 ICP
0.02 ICP
0.05 ICP
0.0005 CV
0.05 ICP
0.005 HSA
0.003 HGA
0.50 ICP
0.01 ICP
1
1
1
1
1
1
1
1
1
1
1
1
1
6010 -
7060 -
6010 -
6010 -
6010 -
6010 -
6010 -
7040 -
6010 -
7740 -
7761 -
6010 -
6010 -
— 08/10/88
08/10/88
08/10/88
08/10/88
08/10/88
08/10/88
08/10/88
08/10/88
08/10/88
08/10/88
08/10/88
08/10/88
08/10/88
* MDL—Method Detection Limits (sane units as the Results) _
** REF—Reference as cited on the cover (first) page of this report.
-------
ALPHA ANALYTICAL lABORATORIES
OF ANALYSIS
Client: M. A. lally Associates
Analysis Requested: Soluble Priority Pollutant
13 Metals
Client Xdentf TW-22
Staple Zccation:
Sanple Description: Water
Sample Container: Plastic bottle
Field Prep: None
Sanple Nuaber: 881555.7
Date Received: 08/05/88
Date Reported: 08/18/88
f of Cental
PARAMETER
PESUU UNITS MDL* INST KEF** HEttOD EXTRACT ANALYSIS
Soluble Priority
Antifflony
Arsenic
Beryllium
Cadmium
Chroniuo
Copper
lead
Mercury
Nickel
Selenium
Silver
Thallium
Zinc
Pollutant 13
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND .
ND
ND
Metals
rog/L
mg/L
rng/L
ng/L
wg/L
wg/L
mg/L
ng/L
ng/If
ng/X|
rg/ll
mg/L
mg/L
0.50 ICP
0.005 Kfi
0.02 ICP
0.01 ICP
0.02 ICP
0.02 ICP
0.05 ICP
0.0005 CV
0.05 ICP
0.005 HGA
0.003 HSA
0.50 ICP
0.01 ICP
1
1
1
'I
1
1
1
1
1
1
1
1
1
6010 -
7060 -
6010 -
6010 -
6010 -
6010 —
6010 -
7040 -
6010 -
7740 -
7761 -
6010 -
6010 -
08/10/88
— s- 08/10/88
08/10/88
08/10/88
08/10/88
08/10/88
08/10/88
- — 08/10/88
08/10/88
08/10/88
08/10/88
08/10/88
08/10/88
*
**
KDL—Method Detection Lunits (same units as the Results)
KEF—Reference as cited on the cover (first) page of this report.
-------
ALPHA ANALYTICAL lABORATOPTES
OF ANALYSIS
Client: M. A, Lally Associates
Analysis Requested: Soluble Priority Pollutant
13 Metals
OisntXdsnt: TW-3
location:
Sanple Description: Water
Saudis Container: Plastic bottle
Field Prep: Nora
Suple Number: 881555.8
Date Received: 08/05/88
Data Reported: 08/18/88
I of Containers: 1
PARAMETER
RESULT UNITS HDL* INST HEF** MEIHOD EXJSACT ANALYSIS
Soluble Priority
Antimony
Arsenic
Beryllium
Cadmium
Chromium
f>*mi*f
^^^Ff^^
Lead
Mercury
Nickel
Selenium
Silver
Thallium
Zinc
Pollutant 13
ND
ND
ND
ND
ND
ND
ND
ND,
NDI
ND
ND
ND
0.01
Metals
ing/L
vg/L
vg/L
ng/L
nq/L
ng/L
mg/L
ng/L
ng/L
ng/L
ng/L
ng/L
ng/L
0.50 ICP
0,005 KA
0.02 ICP
0.01 ICP
0.02 ICP
0.02 ICP
0.05 ICP
0.0005 CV
0.05 ICP
0.005 BG&
0.003 HG&
0.50 ICP
0.01 ICP
1
1
1
1
1
1
1
1
1
1
1
1
1
6010 -
7060
6010 -
6010 -
6010 -
6010 -
6010 -
7040 -
6010 -
7740 -
7761 -
6010 —
6010 -
08/10/88
08/10/88
08/10/88
08/10/88
08/10/88
08/10/88"
08/10/88
08/10/88
08/10/88
08/10/88
08/10/88
08/10/88
08/10/88
* KDL—Method Detection Limits (same units as the Results)
** REF—Reference as cited on the cover (first) page of this report.
-------
Volatile Halocartons by GC
Method 601 and 8010
PARAMETER
BrcBczeth
Cft r.1 « 1 1
Chloroethane
2-Chlonaethylvinyl ether
OilorofcinB
Chlorooethane
ii> i m-it h^no
1 , 2-OichlunjLtg'izaie
1, 3-Dichlorcbenzfine
1, 4-Dichlcrobenrene
1, 1-Dichloroethane
1 , 2-DichlorDethane
1 , 1-DiAloroethene
1,2-Dichloroethme
1 , 2-Oichlarcprcpan
ci.«!-l , 3-Dichl
LL q]TS~l 1 3*^ichlui L|.
Methylene chloride
1,1,2,2-JTetrachlaroethane
1, 1, 1-Trichloroethane
1 , 1 , 2-Trichlaroethane
Trichloroethene
Tric±ilorofluorcnEthane
Vinyl chloride
Method Detection Limit: 500 ug/L
------- |