United States
Environmental Protection
Agency
Office of
Emergency and
Remedial Response
EPA/ROD/R01 -88/031
March 1988
SEPA
Superfund
Record of Decision
Cannon Engineering, MA
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30272-101
REPORT DOCUMENTATION r.- REPORT NO.
PAGE
EPA/ROD/R01-88/031
3. Recipient's Accession No.
4. Title and Subtitle
SUPERFUND RECORD OF DECISION
Cannon Engineering, MA
First Remedial Action - Final
I
Author(s)
8. Performing Organization Rept. No.
9. Performing Organization Name and Address
10. Project/Task/Work Unit No.
11. Contract(C) or Grant(G) No.
(C)
12. Sponsoring Organization Namo 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
16. Abstract (Limit: 200 words)
The Cannon Engineering Corporation (CEC) facility is located in a small industrial
park in the western part of the Town of Bridgewater, Plymouth County, Massachusetts.
The four-acre site is bordered by industrial developments to the north and east and'a
wooded lowland to the south .and west. A wetland area lies south and west of the site.
CEC, which has owned the property since 1974, handled, stored, and incinerated chemical
I waste onsite from 1974 to 1980. EPA conducted site investigations between 1980 and
1982, and in October 1982, Massachusetts contracted for the removal of sludge and liquid
j^aste from onsite tanks and drums. In January 1988, EPA provided for the removal and
^Bisposal of numerous hazardous materials abandoned at the site. This remedial action
[addresses three discrete areas of soil and sediment contamination located in the
northwestern and southern portions of the site, and the buildings, tanks, and other
contaminated structures onsite. The volume of contaminated soil is estimated to be
325 yd^. The primary contaminants of concern affecting the ground water, soil, and
debris are VOCs including benzene, TCE, and vinyl chloride, and other organics including
PCBs and PAHs.
(See Attached Sheet)
17. Document Analysis a. Descriptors
Record of Decision
Cannon Engineering, MA
First Remedial Action - Final
Contaminated Media: gw, soil, debris
Key Contaminants: organics (PAH, PCBs), VOCs (benzene, TCE, vinyl chloride)
b. Identifiers/Open-Ended Terms
c. COSATI Field/Group
13. Availability Statement
19. Security Class (This Report)
None
20. Security Class (This Page)
None
21. No. of Pages
227
22. Price
(See ANSI-Z39.18)
See Instructions on Reverse
OPTIONAL FORM 272 (4-77>
(Formerly NTIS-35)
Department of Commerce
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EPA/ROD/R01-88/031
Cannon Engineering, MA
First Remedial Action
16. ABSTRACT (continued)
The selected remedial action for this site includes: access restrictions; excavation"
and onsite treatment of VOC-contaminated soil by thermal aeration, and excavation and
offsite treatment of PCB-contaminated soil by incineration; decontamination, removal,
and disposal of contaminated buildings, tanks, and structures; additional soil sampling
to assess effectiveness; ground water monitoring and implementation of a water quality
monitoring program to assess natural attenuation of contaminants; and institutional
controls to restrict onsite ground water use. The estimated present worth cost for this
remedial action is between $3,400,000, and $4,505,000 with present worth O&M of $700,000,
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UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
i REGION!
J.F. KENNEDY FEDERAL BUILDING, BOSTON, MASSACHUSETTS 02203-2211
iv
RECORD OF DECISION
Cannons Engineering Corporation (CEC) Site
Bridgewater, Massachusetts
March 31, 1988
STATEMENT OF PURPOSE
This Decision Document represents the selected remedial action
for the Cannons Engineering Corporation (CEC) Site 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 Region I Administrator has been
delegated the authority to approve this Record of Decision.
The Commonwealth of Massachusetts has concurred on the selected
remedy and determined, through a detailed evaluation, that the
selected remedy is consistent with Massachusetts 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 Bridgewater Public Library
and the EPA Library. The attached index identifies the items
which comprise the administrative record upon which the selection
of the remedial action is based.
DESCRIPTION OF THE SELECTED REMEDY
The selected remedy for the Cannons Engineering Corporation
(CEC) Site includes both a source control and management of
migration component to obtain a comprehensive approach for site
remediation. In summary, the remedy provides fencing the area to
restrict access to soils, treating certain contaminated soils on
site by thermal aeration and treating PCS contaminated soils off
site by incineration, and installing a groundwater monitoring
system. In addition, buildings and tanks on site will be
removed and soils under those structures, along with other soil
locations, will be sampled. Any contaminated soils requiring
treatment based on a threat to human health and the environment
will be treated by one of the selected soil treatment technologies,
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RECORD OF DECISION page 2
Cannons Engineering Corporation Site
Source Control
The source control remedial measures include:
Fencing:
A chain link fence will be constructed around the perimeter of
the site to restrict access. Warning signs will be posted at 100
foot intervals along the fence and at the entrance gate. The
current locks on the building will be inspected to insure their
integrity and any locks in deteriorating condition will be
replaced.
Soil Treatment:
The VOC contaminated soil will be excavated and treated on site
in a thermal soil aeration facility. PCB-contaminated soils will
be excavated and treated at an off-site incineration facility.
VOC contaminated soil will be excavated from the wet area, a
discrete area of contamination located in the southern portion of
the site. This area is surrounded by a berm to the south and the
upland area to the north with the water table near the surface of
the soil. The majority of the wet area is proposed for
remediation based on sampling data, site topography, and
contaminant transport considerations. The excavated soils will
be treated on site by thermal aeration to reduce levels of
contamination to levels that are protective.
PCB contaminated soil will be excavated from a discrete portion
of the wet area and a discrete portion of the upland area. These
soils will be treated off site by incineration.
Implementation of these measures will result in the disturbance
and temporary loss of areas classified as wetlands. The
unavoidable impacts to these resource areas will be mitigated to
the maximum extent possible and following such activities, a
wetland restoration program will be implemented.
Additionally, any soil that is identified during implementation
of the remedy by the soil sampling program and determined to need
remediation, based on potential risks posed to human health or
the environment, will be treated by one of the above mentioned
soil treatment technologies.
Decontamination and Removal of Buildings and Associated Structures:
Several buildings, tanks and structures will be decontaminated
and removed from the site.
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RECORD OF DECISION • page 3
Cannons Engineering Corporation Site
Sampling:
Following or concurrent with the building and structure removal,
a sampling program will be implemented to fully characterize the
nature and distribution of the contamination present in the soil
and in the vicinity of site structures.
Management of Migration
The management of migration portion of the remedy involves
restricting the use of groundwater at the site, installing
additional groundwater monitoring wells, and implementing a water
quality monitoring program to observe the presence, distribution
and migration of contaminants, if any. Removal and treatment of
contaminated soils will eliminate sources of further groundwater
contamination. Remediation of the low levels of contamination
found in the groundwater to meet drinking water standards will
occur naturally over time.
Cost
The total present worth cost of the preferred alternative is
estimated to be approximately 3.4 million dollars. This estimate
includes the capital cost of the fencing, sampling, and the soil
treatment of approximately 2.7 million dollars and the present
worth cost of the water quality monitoring system of
approximately 0.7 million dollars.
DECLARATION
The selected remedy is protective of human health or 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, toxicityand
mobility of the hazardous substances, pollutants and
contaminants, as a principal element. Finally, it is determined
that this remedy utilizes permanent solutions and alternative
treatment technologies to the maximum extent practicable.
Date Regional Administrator
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ROD SUMMARY
CANNONS ENGINEERING CORPORATION (CEC) SITE
BRIDGEWATER, MASSACHUSETTS
MARCH 31, 1988
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Cannons Engineering Corporation Site
Record of Decision Sumsary
TABLE OF CONTENTS
Contents Pace
I. SITE NAME, LOCATION, AND DESCRIPTION . . ........ 1
II. SITE HISTORY ............. . ........ 4
A. Remedial History . . ....... . ........ 4
B. Enforcement History ....... . ........ 5
III. SITE CHARACTERISTICS ........... ...... 6
A. Overview of the Remedial Investigation .' ...... 6
1. Soil ..................... 6
2 . Groundwater .................. 7
B. Overview of the Endangerment Assessment ...... 7
1. Direct Contact to Surface Soil ........ 10
2. Ingestion of Groundwater ...... ..... 10
IV. COMMUNITY RELATIONS .................. 11
V. DEVELOPMENT AND EVALUATION OF ALTERNATIVES ....... 12
A. Introduction ................... 12
B. Response Objectives ................ 12
C. Development and Screening of Remedial Action
Alternatives ................... 14
1. Technology Jtevelopment and Screening ..... 15
2. Alternative Development and Screening ..... 16
E. Detailed Analysis of Alternatives ......... 17
2. Alternatives Analyzed ... ......... 19
a. Source Control (SC) Alternatives Analyzed 19
b. Management of Migration (MM) Alternatives
Analyzed ................ 23
VI. SELECTED REMEDY ......... ........... 28
A. Description of the Selected Remedy ...... . . ^ 28
1. Scope of the Selected Remedy ......... 28
B. Documentation of the Selected Remedy ........ 30
1. Source Control . ............... 30
2. Management of Migration ..... ....... 33
C. Statutory Determination .............. 37
1. Protectiveness ................ 37
2. Consistency with Other Laws .......... 38
3. Cost-effectiveness and Utilization of Permanent
Solutions and Alternative Treatment
Technologies or Resource Recovery
Technologies to the Maximum Extent
Practicable .... ............ 44
D. Conclusion ........ . ............ 49
VII. STATE ROLE ......... . ............ 49
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Cannons Engineering Corporation Site
Record of Decision Summary
LIST OF FIGURES
Ficrure N"~mber Page
LIST OF TABLES
Table Number Paq»
I
1-1 Site Location Map 2
1-2 Site Plan 3
III-l Locations of Sampling Stations and Monitoring Wells . 8
III-l Contaminants of Concern Evaluated in the Endangerment
Assessment ...................... 9
V-l Summary of Screening of Remedial Alternatives .... 18
V-2 Alternative Evaluation Tables ............ 27
VI-1 Chemical Specific ARARs ............... 39
VI-2 Location Specific ARARs ...............
VI-3 ARARs for Source Control ............... 42
VI-4 ARARs for Management of Migration .......... 43
VI-5 Source Control Costs ................. 47
•
VI-6 Management of Migration Costs ...... ...... 48
APPENDICES
Responsiveness Summary .............. Appendix A
Administrative Record Index ............ Appendix B
State Concurrence Letter .............. Appendix C
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ROD DECISION SUMMARY . ' page 1
Cannons Engineering Corporation Site
I. SITE NAME, LOCATION, AND DESCRIPTION
The Cannons Engineering Corporation (CEC) facility is located in
a small industrial park in the western part of the Town of
Bridgewater, Plymouth County, Massachusetts. Prior to 1969, the
industrial park consisted of a wooded lowland bordered to the
north, south, and east by rural agricultural land. Current land
use around the site consists of industrial development in the
immediate vicinity to the north and east, a wooded lowland to the
south and west, and agricultural and residential development in
the outlying areas.
The site is located in the southeastern portion of the Town
River watershed, which has an estimated area of 56 square miles
(see Figure 1-1 Site Location Map). The Hockomock Swamp occupies
a large portion of the watershed. Lake Nippenicket is the
largest surface water body located within 1 mile of the site.
The towns of Bridgewater, West Bridgewater, and Raynham obtain
their water supplies from wells within the Town River watershed.
The nearest well, operated by the Town of Raynham, is located 1.3
miles west of the site on the southwestern shore of Lake
Nippenicket (Figure 1-1).
The site occupies approximately 4 acres of land on the western
edge of a low, north-south trending ridge. The land surface at
the site slopes generally to the southwest and west, with slopes
varying from zero to 3 percent. Land south and west of the site
is undeveloped and comprises the southern edge of Hockomock
Swamp.
Facilities on-site were built on fill soils (see Figure 1-2 Site
Plan). A wetland area lies south and west of these facilities.
An area encompassing approximately 1 acre immediately south of
the tank farm building is surrounded by manmade berms and the
upland fill area. Throughout the text and figures of this *
document and the Feasibility Study (FS) report, this area will be
referred to as the "wet area" because it contains a discrete zone
of different soil characteristics and vegetation from the natural
wetland surrounding the site. A berm separates the wet area from
the wooded swamp and an east-west trending drainage canal. Most
surface runoff is channeled through a ditch in the southwestern
sector of the berm to the drainage canal (see Figure 1-2). The
canal directs runoff from the CEC site and other built-up areas
toward Hockomock Swamp, which drains to the north, downstream of
Lake Nippenicket. Surficial deposits at the site consist of
unconsolidated sand, gravel, and silt from 11 to 17 feet thick.
The surficial deposits are classified as outwash or ice-contact
strata, and overlie sandstone and conglomerate bedrock of the
Rhode Island Formation.
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L
CANNONS ENGINEERING
CORP. 3IT3
-
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ROD DECISION SUMMARY page 4
Cannons Engineering Corporation Site
Fill and disturbed soils occur at the surface across the site.
The fill contains 20 to 30 percent silt, and ranges in thickness I
from 4 to 6 feet, except in the wet area south of the tank farm
building, where it is absent. The outwash stratum consists of
stratified sand, silty sand, and silt, and ranges in thickness
from 2 feet in the northwestern portion of the site to 12 feet in
the southern portion. In the western areas, the outwash soil
consists of 75 percent silt, whereas the silt content in the
northern half of the site ranges from 45 to 50 percent.
The Remedial Investigation (RI) determined that groundwater in
both the soils and bedrock beneath the site flows to the south
and southwest. Groundwater flow rates estimated in the RI range
from 2 to 10 feet per year. The RI reported similar flow rates
in the bedrock and overlying glacial deposits. Groundwater moves
horizontally in the northern section of the site; however, a
slight upward vertical gradient was measured in multilevel wells
located in the southern and southwestern portions of the site.
Therefore, both shallow and deep groundwater is inferred to
discharge into the drainage canal or Hockomock Swamp located
south and west of the site. In addition, local topography
suggests that deeper groundwater under the site (i.e., in the
lower ice contact and upper bedrock) ultimately discharges into
the Hockomock Swamp south and west of the site.
II. SITE HISTORY
CEC purchased a parcel of land on First Street in Bridgewater,
Massachusetts, in November 1974. The property was developed by
the owner to handle, store, and incinerate chemical wastes.
Incineration of hazardous wastes at the site occurred frequently
between 1974 and 1980. Activities continued at the site until
November 1980, when operations were closed. The Massachusetts
Department of Environmental Quality Engineering (DEQE) revoked
CEC's Hazardous Waste License in June 1980.
A. Remedial History
Between 1980 and 1982, the U.S. Environmental Protection Agency
(EPA) conducted site inspections, performed sampling and
analyses, and determined the presence of chemical contamination
at the site. EPA subsequently used this information to rank the
site and propose its inclusion on the National Priorities List
(NPL) in December 1982.
In October 1982, DEQE contracted with Jet-Line Services (a
hazardous waste clean-up contractor) to remove sludge and liquid
wastes from on-site tanks and drums to prevent the potential
release of contaminants into the environment. Prior to removal
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ROD DECISION SUMMARY page 5
Cannons Engineering Corporation Site
operations, the site contained 711 drums of various wastes and
approximately 155,000 gallons of bulk waste. A acre detailed
description of the site history and response actions are
presented in the Remedial Action Master Plan (RAMP) prepared by
Camp, Dresser, and McKee (CDM, 1983) and the RI Report (Jordan,
May 1987).
B. Enforcement History
CEC's operations at the Bridgewater facility were closed in 1980
when the MA DEQE revoked the hazardous waste license after con-
cluding that the owners were not operating in accordance with the
law. The Commonwealth of Massachusetts and the State of New
Hampshire successfully prosecuted criminal actions against the
officers of CEC and other individuals who were involved in the
illegal disposal of wastes that were to be disposed of at the
Bridgewater facility. The investigations leading to the convic-
tions and subsequent investigations found that CEC, operating in
concert with a number of individuals and businesses, arranged for
wastes that were sent to the Bridgewater facility to be illegally
transported to several other disposal sites in New England which
later became Superfund sites. Specifically, investigations found
that wastes first sent to Bridgewater were commingled with other
wastes and, at various times, were shipped to a storage facility
in Plymouth, Massachusetts and to illegal disposal sites at
Gilson Road in Nashua, NH and Tinkhams's Garage in Londonderry,
NH.
On March 28, 1986, the Agency notified approximately 600 parties
who either operated the facility, generated wastes that were
shipped to the facility, arranged for the disposal of wastes at
the facility, or transported wastes to the facility of their
potential liability with respect to the Site. Negotiations com-
menced with these potentially responsible parties (PRPs) on
May 1, 1986 regarding the settlement of the PRPs' liability at
the CEC-Bridgewater facility, as well as the associated CERCLA
liability stemming from the disposal of wastes that were shipped
from the Bridgewater site to other disposal sites in New England.
The PRPs formed a steering committee and substantial negotiations
have taken place. To date, these negotiations have resulted in
the development of two settlement agreements concerning the Site
and agreements concerning response actions at the Tinkham's
Garage Site in Londonderry, NH, and at the Cannons/Cordage Park
site in Plymouth,
First, the Region has proposed a de minimis settlement under
Section 122(g)(l)(a) of CERCLA to resolve the liability of 331
generator and transporter parties who contributed small amounts
of waste to the Bridgewater facility. This settlement was
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ROD DECISION SUMMARY page 6
Cannons Engineering Corporation Site -
proposed in the Federal Register on February 11, 1988 (53 FR
4070), and approximately 276 PRPs have signed binding letters of
intent to participate in the settlement.
A second agreement at the Bridgewater facility was reached with
22 PRPs to conduct an emergency removal action at the Site. On
January 21, 1988, the Agency signed an Administrative Order by
Consent that provides for the removal and proper off-site
disposal of numerous hazardous materials abandoned at the Site.
The PRPs have also been active in the remedy selection process
for this Site. Technical comments presented by PRPs during the
public comment period at a meeting were summarized in writing,
and the summary and written comments were included in the Admini-
strative Record. .
Special notice has not been issued in this case due to the sig-
nificant negotiations that have already taken place with the
PRPs.
III. SITE CHARACTERISTICS
A. Overview of the Remedial Investigation
The field investigations were designed to assess and
characterize contamination present in the air, soils, sediments,
surface water, and groundwater at the site. Sampling rationale
and methods are presented in detail in the Remedial
Investigation (RI) report. Locations of sampling stations and
monitoring wells are shown in Figure III-l. Chapter 1 of the
Feasibility Study contains an overview of the Remedial
Investigation. The significant findings are summarized in the
following sections.
•
1. Soil
The Remedial Investigation report identified three areas at the
site of surface soil contamination and sediment contamination as
Areas 1, 2, and 3. Area 1 is located in the northeastern portion
of the site. Area 2 is located in the western portion of the
site, and Area 3 is the wet area located in the southern portion
of the site.
Organic contamination was confined mostly to the surface soils at
a depth of one to two feet and PCBs were detected at low levels
in several surface soil areas. Subsurface soil samples generally
contained low total concentrations of organics. No PCBs were
detected in subsurface soils.
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ROD DECISION SUMMARY . -page 7
Cannons Engineering Corporation Site
2. Groundwater
The Rl'and subsequent sampling found low level contamination of
groundwater at several monitoring wells that were installed at
the site. Groundwater samples were collected from all 15 on-site
monitoring wells (see Figure III-l). A total of three rounds of
sampling was performed in the 1984 and 1985 field investigations.
The draft RI was finalized in May 1987 based on this information.
The concentrations of total VOCs were less than 50 ppb, except
in wells MW-2, MW-5, and MW-8. The sources of the contamination
in wells MW-2 and MW-8 are the underground tanks located
upgradient. MW-2 is located about 15 feet south of the sump
connected to the equipment building; MW-5 is about 100 feet south
of the loading dock area; and MW-8 is less than 100 feet south
of the septic tank and west of the underground tank (see Figure
III-l). Following the completion of the May 1987 draft RI, the
Agency collected additional groundwater samples at seven wells
in November 1987. These samples confirmed the previously
identified limited groundwater contamination. Only wells MW-8
and MW-2 showed contamination, while the other five wells
including MW-5 did not.
B. Overview of the Endangerment Assessment
An Endangerment Assessment (EA) of the CEC site was performed to
estimate the probability, and magnitude of potential adverse human
health and environmental effects from exposure to contaminants
associated with the site.
Seventeen contaminants of concern, listed in Table III-l, were
selected for evaluation in the EA. These contaminants
constitute a representative subset of the more than 70
contaminants identified on-site in the RI. The 17 contaminants
were selected to represent potential on-site hazards based *on
toxicity, level of contamination, and mobility and persistence
in the environment.
Potential human health effects associated with the contaminants
of concern in surface soils and groundwater were estimated
quantitatively 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 for the various exposure scenarios.
Exposure scenarios were developed to reflect the potential for
exposure to hazardous substances based on the characteristic uses
and location of the site. Factors of special note that are
reflected in the Endangerment Assessment are that the site is
part of an industrial park and is unlikely that residences will
be built at the site.
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TABLE III-l
CONTAMINANTS OF CONCERN EVALUATED IN THE
ENDANGJ.RMENT ASSESSMENT FOR THE CEC SITE
BRIDGEWATtR, MASSACHUSETTS
Distribution/Extent of Contai
Compound
Benzene
Chlofobeozene
Toluene
Xylenes
4-Methyl-2-Pentanone
1 , 1 , 1-Trlchloroethane
Trana-1 ,2,-Dichloroethylene
Tetrachloroethylene
Trichloroethylene
Methylene Chloride
Vinyl Chloride
PCBs
Phenol
N-Nitrosodiphenylaalne
Bis(2-ethylhexyl)phthalate
Total PAHs
Chroaiua
C = Potential Carcinogen
T * Systeaic Toxicant
( ) * EPA Weight of Evidence
NA * Not Analyzed
« Not Detected
A = EPA Classification of
B2 = EPA Classification of
2B * I ARC classification of
Class
Aromatic
Volatile
Volatile
Volatile
Ketone
Volatile
Chlorinated
Aliphatic
Volatile
Volatile
Volatile
PCB
Phenolic
Nitrosaaine
Phthalate
ester
PAH
Hetal
human carcinogen
probable huaun carcinogen
adequate animal evidence
Hazard
C (A)
T
T
• T
T
T
T
C (B2)
C (B2)
C (B2)
C (A)
C (B2)
T
C (28)
C (B2)
C (A)
C (A)
Tanks/Soils
fc Sediments
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
Surface Ground-
Water water
X
X
X
X
X
X
X
X
X X
X
--
• • •—
X
X X
..
X
lination
Air
X
--
X
--
--
—
--
--
--
X
--
NA
NA
NA
NA
NA
NA
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ROD DECISION SUMMARY page 10
Cannons Engineering Corporation Site
Additionally, there is a municipal water supply in the vicinity
of the site.
Direct contact with surface soil was judged as the most likely
exposure route to result in potential health hazards under
present site conditions. Although on-site groundwater is not
currently used for drinking water, the risks associated with its
consumption were evaluated because it is classified as a
potential source of drinking water. Inhalation of on-site
airborne contaminants was evaluated qualitatively. Other
potential exposures associated with direct contact to
contaminated buildings and surfaces on-site were also discussed
in the EA.
1. Direct Contact to Surface Soil
Human health risks were calculated for an adult assuming
occasional site visits and inadvertent contact with contaminated
soil. Similar calculations were made for an older child (i.e.,
8 to 17 years old) who may play or loiter occasionally on the
site. The risks were assessed assuming both mean contaminant
concentrations and maximum concentrations. As stated in the EA,
a range of probable absorption rates by chemical class (i.e.,
VOCs, SVOCs, inorganics, and PCBs) was used to estimate body
dose. The incremental lifetime cancer risks for an older child
coming in contact with surface soil on-site ranged from 6 x 10~6
under site-wide average contaminant concentration conditions to
7 x 10~* under site-wide maximum concentration conditions. PCBs
and total PAHs contributed the majority of the total risk. For
an adult coming in contact with soil on-site, incremental
lifetime cancer risks ranged from 7 x 10~7 to 1 x 10~5. (The
calculated pollutant dose per unit of body weight and the
exposure time was less for an adult than for an older child.)
PCBs contributed the major portion (i.e., 88 percent) to the
total risk using site-wide average concentration conditions^
while total PAHs and PCBs were the major contributors to total
risk using site-wide maximum concentration conditions.
2. Ingestion of Groundwater
Groundwater on-site is not currently used for drinking water,
but it does represent a potential future source. Should wells be
installed, the yield is likely to be low. According to criteria
established by the DEQE and EPA Groundwater Protection Strategy
guidelines, the aquifer underlying the site is classified as a
Class 2 and Class IIB aquifer, respectively (i.e., a potential
source for future use). Therefore, the incremental lifetime
cancer risk and the noncarcinogenic health risks associated with
the ingestion of on-site groundwater were assessed. The total
incremental cancer risk if a person were to drink the groundwater
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ROD DECISION SUMMARY page 11
Cannons Engineering Corporation Site ; _^_
found under the site for a lifetime containing contaminants of
concern at the mean concentrations of on-site wells was estimated
at 1.4 x 10"5. Benzene, tetrachloroethylene, and
trichloroethylene contributed 94 percent of the risk. The
preceding risk calculations for groundwater do not reflect the
November 1987 groundwater data. Notably, Vinyl Chloride which
was not detected in any of the Remedial Investigation sampling
events, was detected in one well at low levels during this
sampling event. However, due to the limited occurrence of Vinyl
Chloride, it did not warrant inclusion in the risk calculations.
IV. COMMUNITY RELATIONS
Through the site's history, community concern and involvement has
been low to moderate. However, since the listing of the site on
the NPL, one citizen's group, Bridgewater Aware, has remained
actively interested in activities occurring at the site. EPA has
kept this group and other interested parties informed through
informational meetings, fact sheets, press releases, and public
meetings.
In 1982, EPA released a community relations plan which outlined a
program to address community concerns and keep citizens informed
about and involved in activities during remedial activities. On
November 15, 1983, EPA held an informational meeting in the town
to describe the plans for the Remedial Investigation and
Feasibility Study. In July 1984, EPA issued an informational
sheet updating the community on the progress of the RI. On May
27, 1987, EPA held an informational meeting to present the
results of the draft Remedial Investigation and to answer
questions from the public.
On February 11, 1988, EPA held an informational meeting to
discuss the cleanup alternatives presented in the Feasibility
Study and to present the Agency's Proposed Plan. Also during
this meeting, the Agency answered questions from the public.
From February 11 to March 4, 1988, the Agency held a three week
public comment period to accept public comment on the
alternatives presented in the Feasibility Study and the Proposed
Plan and on any other documents previously released to the
public. On February 25, 1988, the Agency held a public meeting
to accept any oral comments. A transcript of this meeting and
the comments and the Agency's response to comments are included
in the attached responsiveness summary.
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ROD DECISION SUMMARY page 12
Cannons Engineering Corporation Site
V. DEVELOPMENT AND EVALUATION OP ALTERNATIVES
A. Introduction
On October 17, 1986, the President signed into lav the Superfund
Amendments and Reauthorization Act of 1986 (SARA) amending the
Comprehensive Environmental Response, Compensation and Liability
Act of 1980 (CERCLA). Prior to October 17, 1986, actions taken
in response to releases of hazardous substances were conducted in
accordance with the revised National Oil and Hazardous Sub-
stances Pollution Contingency Plan (NCP), 40 CFR Part 300, dated
November 20, 1985. Generally, the purpose of the NCP is to
effectuate the response powers and responsibilities created by
CERCLA. In accordance with Section 105 of CERCLA as amended by
SARA, the current NCP is being revised to reflect the additional
provisions of SARA. In the interim, prior to the revision of the
NCP, the procedures and standards for responding to releases of
hazardous substances, pollutants and contaminants shall be in
accordance with Section 121 of SARA and to the maximum extent
practicable, the current NCP.
SARA retains the original CERCLA mandate for protective and cost-
effective remedial actions. According to Section 300.68(a)(l) of
the NCP, remedial actions are those responses to releases that
are consistent with a permanent remedy to prevent or minimize the
release of hazardous substances or pollutants or contaminants so
that they do not migrate to cause substantial present or future
danger to public health or welfare or the environment. SARA adds
a new statutory emphasis on risk reduction through destruction or
treatment of hazardous waste rather than protection achieved
through prevention of exposure. Section 121 of SARA also
establishes a statutory preference for remedies that permanently
and significantly reduce the volume, toxicity or mobility of
hazardous wastes over remedies that do not achieve such results
through treatment. Furthermore, SARA requires that EPA select a
remedy, that is protective of human health and environment, that
is cost-effective and that utilizes permanent solutions and
alternative treatment technologies, to the maximum extent
practicable.
B. Response Objectives
Response actions were developed consistent with the NCP and
CERCLA. Additionally, guidelines in the Superfund Public Health
Evaluation Manual (EPA, 1986) regarding development of design
goals and risk analyses for remedial alternatives were used to
develop response actions.
A number of potential exposure pathways were analyzed for risk
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ROD DECISION SUMMARY . page 13
Cannons Engineering Corporation Site
and threats to public health and the environment in the
Endangennent Assessment and the Wetlands Assessment. As a
result of these assessments, remedial response objectives were
developed to mitigate existing and future threats to public
health and the environment.
The response objectives identified to mitigate threats to public
health are as follows:
o prevent direct contact with contaminated soils
throughout the site
o prevent ingestion of contaminated soils, standing
water in the wet area
o prevent ingestion of contaminated groundwater
o prevent exposure to contaminants in the buildings,
aboveground and underground tanks, and associated
structures
The response objectives identified to mitigate threats to the
environment are as follows:
o prevent the exposure of wildlife to contaminated soil,
sediments, and standing water in the wet area
o prevent future wetlands contamination from surface
water runoff and discharge of contaminated groundwater
into the wetlands
According to CERCLA and the National Contingency Plan (NCP), all
applicable or relevant and appropriate federal public health and
environmental requirements must be identified and "...EPA
believes that those requirements must be met in order to achieve
an effective CERCLA remedy." (Federal Register Vol. 50, No 224,
November 20, 1985), 40 CFR Part 300. Therefore, response
objectives also consider the attainment of chemical-specific and
location-specific ARARs for existing site conditions.
Additionally, CERCLA requires that in certain cases responses
attain more stringent state ARARs. The process in which the ARARs
were identified and considered is discussed in Chapter 2 of the
Feasibility Study. A table of the Chemical-specific and
Location-specific ARARs is located in Section VI.C.3 of this
document entitled Selected Remedy, Statutory Determination,
Consistency with Other Laws. In summary, the response
objectives, to attain the chemical specific and location specific
ARARs, must consider the following:
o attainment of federal Maximum Contaminant Levels
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ROD DECISION SUMMARY ' page 14
Cannons Enaineerina Corporation Site
(MCLs), Massachusetts Groundwater Quality Standards,
and Massachusetts Drinking Water Standards for
groundwater quality objectives;
o Floodplains Executive Order (EO 11888) for restoration
of degraded wetlands; and
o Massachusetts Board of Fire Prevention regulations for
abandoned underground storage tanks.
Currently there are no federal requirements which contain
standards or target levels which apply to soils. Therefore, when
considering treatment or removal of waste and soil source areas,
a combination of risk analysis and an engineering-based cost
effectiveness will be used to develop target levels which will be
protective of the 'public health, welfare and the environment.
•
C. Development and Screening of Remedial Action Alternatives
Section 300.68(f)(l) of the NCP requires that, to the extent that
is both possible and appropriate, at least one remedial
alternative shall be developed as part of the Feasibility Study
in each of the following categories:
• Alternatives for treatment or disposal at an off-site
facility as appropriate.
• Alternatives that attain applicable or relevant and
appropriate federal public health and environmental
requirements.
• As appropriate, alternatives that exceed applicable or
relevant and appropriate federal public health and
environmental requirements.
• As appropriate, alternatives that do not attain applicable or
relevant and appropriate federal public health and
environmental requirements but will reduce the likelihood
of present or future threats from hazardous substances and
that provide significant protection to public health and
welfare and the environment. This must include an alter-
native that closely approaches the level of protection
provided by alternatives that attain applicable or rele-
vant and appropriate requirements.
• No action alternative.
The EPA "Guidance on Feasibility Studies Under CERCLA" dated June
1985 and the National Oil and Hazardous Substances Pollution
Contingency Plan (NCP) set forth the process by which remedial
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ROD DECISION SUMMARY • page 15
Cannons Engineering Corporation Site
actions are evaluated and selected. Based on site information
presented in the RI report, feasible response actions were
identified. Response actions were developed following interim
guidance issued by EPA in OSWER Directive No. 9355-0-19
(December 24, 1986), which provides guidance for the
consideration of amendments to CERCLA that deal with clean-up
standards. Response actions fall into the following general
categories, all of which may be applied to conditions at the CEC
site:
o minimal no-action
o containment on-site
- immobilization of soil contaminants
-'immobilization of waste residues in buildings
- groundwater migration control
o treatment on-site or off-site
- soils treatment
— decontamination and treatment of waste residues
in buildings and tanks
- groundwater treatment
o disposal off-site
In accordance with SARA and the NCP, 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.
1. Technology Development and Screening
The purpose of the technology development and screening sections
in the Feasibility Study is to produce an inventory of suitable
technologies (regarding site conditions) that can be assembled
into remedial alternatives capable of mitigating contamination at
the site to target levels and reducing the potential threat to
public health and the environment. Chapter 4 of the Feasibility
Study identifies technologies applicable to the above response
actions. Additionally, Chapter 4 assesses and screens the
technologies based on engineering feasibility, implementability,
effectiveness, and technical reliability. Table 4-2 in chapter 4
of the Feasibility Study summarizes the screening of technologies
bases on the these considerations. And, Table 4-3, also in
Chapter 4 of the Feasibility Study presents the technologies
which emerged from the screening process. These technologies
were combined into source control (SC) and management of
migration (MM) alternatives.
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ROD DECISION SUMMARY . page 16
Cannons Engineering Corporation Site
2. Alternative Development and Screening
Chapter 5 in the Feasibility Study presents the remedial
alternatives, developed by combining the technologies identified
in the previous screening process, in the categories required by
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). Source control alternatives
designed to prevent or minimize migration of hazardous substances
from source material are formulated. Management of migration
remedial alternatives are assembled to address contaminants that
have migrated from the original source of contamination.
Alternatives developed and considered for initial screening at
the site are listed in Table 5-1 and Table 5-2 of the Feasibility
Study.
The screening of alternatives must comply with SARA. Section
121(d) of SARA basically codifies EPA's CERCLA Compliance
Policy. First published as an appendix to the preamble of the
NCP, this policy requires that Superfund remedial actions attain
applicable or relevant and appropriate requirements (ARARs) of
other federal statutes. While Section 300.68(f) of the NCP
specifically refers to ARARs in regard to the Development
Alternatives, SARA incorporates this requirement into the
statute, while adding the provision that remedial actions also
attain State requirements more stringent than federal
requirements if they are also applicable or relevant and i
appropriate and identified to EPA in a timely manner. The new
statutory requirements and preference for treatment that reduces
the mobility, toxicity, or volume of hazardous waste further
modifies the process by which remedial alternatives are
developed.
The purpose of the initial screening is to narrow the number of
potential remedial actions for further detailed analysis while
preserving a range of options. Screening criteria conform with
remedy selection requirements set forth in CERCLA as amended,
Section 121, and in the NCP. Criteria listed in section
300.68(g) of the NCP were used. These criteria are (1) Costs;
(2) Acceptable Engineering Practice; and (3) Effectiveness. The
effectiveness evaluation, among other things, considers whether
each alternative is protective and whether it will attain or
exceed ARARs that are identified for the site. (In the discussion
in Chapter 6 of the Feasibility Study, the term
"Implementability" has been substituted for the term "Acceptable
Engineering Practice".) Additionally, consistent with Section
121(b)(2) of SARA, innovative technologies were carried through
the screening process if they offered the potential for better
treatment performance or implementability or less adverse
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ROD DECISION SUMMARY page 17
Cannons Engineering Corporation Site •
environmental impacts than other available technologies or lower
costs than demonstrated technologies. Each alternative is
evaluated and screened in Chapter 6 of the Feasibility Study for
effectiveness, implementability, and cost. In summary, of the 14
source control and management of migration remedial alternatives
screened in Chapter 6, 11 are retained for detailed analysis.
Table V-l identifies the 11 alternatives which were retained
through the screening process, as well as those that were
eliminated from further consideration.
E. Detailed Analysis of Alternatives
Each of the alternatives were evaluated using a number of
evaluation factors. The regulatory basis for these factors comes
from the National Contingency Plan and Section 121 of CERCLA
(Cleanup Standards). Section 121(b)(l) states that, "Remedial
action in which treatment which permanently and significantly
reduces the volume, toxicity or mobility of the hazardous
substances, pollutants, and contaminants is a principal element,
are to be preferred over remedial actions not involving such
treatment. The offsite transport and disposal of hazardous
substances or contaminated materials without such treatment
should be the least favored alternative remedial action where
practicable treatment technologies are available." Section
121(b)(1) also states that the following factors shall be
addressed during the remedy selection process:
1. The long-term uncertainties associated with land disposal.
2. The goals, objectives and requirements of the Solid Waste
Disposal Act.
3. The persistence, toxicity, mobility and propensity to
bioaccumulate of such hazardous substances and their
constituents. •
4. Short and long-term potential for adverse health effects from
human exposure.
5. Long-term maintenance costs.
6. The potential for future remedial action costs if the alter-
native remedial action in question were to fail.
7. The potential threat to human health and the environment
associated with excavation, transportation and redisposal
or containment.
Section 121 of CERCLA also requires that the selected remedy be
protective of human health and the environment, be cost
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TABLE V-l
SUMMARY OF INITIAL SCREENING OF REMEDIAL ALTERNATIVES
FOR THE CEC SITE, BRIDCEVATER, HASSACHUSETTS
Retain for Eliminate froa
ALTERNATIVE Detailed Analysis Further Consideration
t
Source Coatrol Alternatives
SC-1 Minimal Mo-Action Z
SC-2 Oa-site Cover Systav I
SCO Solidification and On-site IdA
Landfill/Off-site Incineration
of PGB Waste* Greater tkaa SO ppa Z
SC-4 Solidification aad Off-cite
RCRA Undfill/Off-tite
laciaeratioa of KB Wastes
Greater than SO ppai Z
SC-5 OB-SI te Theraal Aeration of
VOC Vastes/Of f-site InciAeratioa
of PCS and PAH Wastes Z
SC-6 On-site Incineration Z
SC-7 Off-site Incineration Z
Maoageaent of Migration Alternatives
m-1 Hiniawl Mo Action Z
lfll-2 h«p and Treat by
UV-Pnotolysia/Oconatioa Z
and Treat by Air-Stripping Z
HH-4 Puatp and Treat by Carbon Adsorption Z
NH-S PtMp and Treat by Reverse Osnesis
MM-6 Pup and Treat by Air-Stripping and
Activated Carbon
MH-7 Pu«p and Treat Off-site
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ROD DECISION SUMMARY ' page 19
Cannons Engineering Corporation Site
effective, and use permanent solutions and alternative treatment
technologies or resource recovery technologies to the maximum
extent practical.
In addition to the factors listed in Section 121 of CERCLA,
alternatives were evaluated using current EPA guidance,
including: "Interim Guidance on Superfund Selection of Remedy"
dated December 24, 1986 and "Additional Interim Guidance for FY
'87 Records of Decision" dated July 24, 1987. In the July 24,
1987 guidance, the following nine evaluation factors are
referenced:
1. Compliance with Applicable or Relevant and Appropriate
Requirements (ARARs).
2. Long-term Effectiveness and Permanence.
3. Reduction of Toxicity, Mobility or Volume.
4. Short-term Effectiveness.
5. Implementability.
6. Community Acceptance.
7. State Acceptance.
8. Cost.
9. Overall Protection of Human Health and the Environment.
2. Alternatives Analyzed
The following section presents a narrative summary and brief
evaluation of each alternative according to the evaluation , •
criteria described above. Following the discussion is a tabular
assessment (Table V-2) of each alternative according to the OSWER
criteria. Note, however, that criterion 7 - Community
Acceptance, and criterion 8 - State acceptance are considered in
the tables under the Implementability heading. Additionally,
criterion 1 - Overall Protection of Human Health and the
Environment, is discussed in the narrative summary.
a. Source Control (SO Alternatives Analyzed
The source control alternatives analyzed for the site include a
minimal no action alternative (SC-1); two containment
alternatives which primarily contain the contamination by
landfilling (SC-3 and SC-4); and three treatment alternatives
which treat the contamination by a thermal aeration treatment
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ROD DECISION SUMMARY • page 20
Cannons Engineering Corporation Site
process or a thermal incineration process (SC-5, SC-6, SC-7) .
SC-1 Approximate Present Worth 'Cost:
Minimal No Action $ 223,000.
This alternative would consist of restricting access to the site,
buildings, and underground structures by fencing and posting
warning signs, sealing buildings, and plugging underground tanks,
catch basins, and pumps. Education programs would inform the
public about potential hazards to the site. Additionally, a long
term monitoring program would be instituted to evaluate changes
in site conditions over time. The monitoring program would
include surface soil sampling, groundwater sampling, and surface
water sampling in the drainage canal.
This alternative may not be protective because it does not
result in reduction of existing risks due to contact with soils
and would not comply with some ARARs. Additionally, this
alternative does not use treatment as a principal element, and
consequently, there would be no reduction in mobility, toxicity
or volume of the wastes present on site. Long term monitoring
and site management would be necessary.
SC-3 Approximate Present Worth Cost:
Solidification and Stabilization $ 2,136,000. to 2,936,000.
On-site RCRA -^"^
This, alternative involves several components in order to achieve
the response objectives. The goal of this alternative is to
reduce the risks associated with direct contact with soils and to
reduce the mobility of the contaminants by placing the
contaminated material in an on-site landfill. This alternative
involves decontamination of all structures, excavation of soils,
treatment of most hazardous soils and debris by solidification,
and disposal in an on-site landfill constructed to RCRA design
standards.
This alternative would achieve a short term reduction in
environmental and public health risks by reducing the direct
contact hazards associated with soil and by containing the source
of groundwater contamination, but this would not be a permanent
remedy. This alternative uses readily, available, technologies and
services and is easy to implement. Although this alternative
uses treatment to reduce the mobility of the contaminants, it
does not use treatment to the maximum extent practicable, and
does not reduce the volume or toxicity of the contaminants by
using such treatment. This alternative would require long term
monitoring and maintenance, and the potential exists for
replacement costs if the landfill were to fail.
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ROD DECISION SUMMARY - page 21
Cannons Engineering Corporation Site
SC-4 Approximate Present Worth Cost:
Solidification and Stabilization $ 2,349,000. to 4,143,000.
Off-site RCRA
This alternative involves several components in order to achieve
the response objectives. The goal of this alternative is to
reduce the risks associated with direct contact with soils and to
reduce the mobility of the contaminants by removing and placing
the contaminated material in an off-site landfill. As with SC-3,
this alternative involves decontamination of all structures,
excavation of soils, treatment of most hazardous soils and debris
by solidification. However, this treated material would be
disposed in an off-site RCRA landfill.
This alternative would reduce the potential for direct human
contact with site contaminants by removing contaminants in soils
and structures from the site. Through excavation and treatment
of contaminated soils, the potential for continued migration of
contaminants to groundwater would be reduced. This remedial
alternative would attain ARARs. This alternative uses readily
available technologies and services and is easy to implement;
however, off site disposal is not a remedial alternative favored
by CERCLA. Solidification and stabilization of soils and
concrete would reduce the mobility of contaminants after disposal
at the off-site RCRA landfill, but would not reduce the toxicity
or volume of contaminants, The alternative would eliminate the
need for long term management and monitoring of soils and
structures at the site. This alternative, however, does not use
treatment to the maximum extent practicable.
SC-5 Approximate Present Worth Cost:
Ori-site Aeration $ 2,711,000. to 3,805,000.
Off-site Incineration
This alternative involves several components in order to achieve
the response objectives. The goal of this alternative is to
reduce the risks associated with direct contact with soils and to
reduce the threat of contamination to groundwater by treating the
contaminated material. This alternative involves
decontamination of structures and excavation of contaminated
soils, and treatment by on-site thermal aeration of volatile
organic compound (VOC) contaminated soils and decontamination
debris. Additionally, small areas of soil contaminated with
PCBs and PAHs, which cannot be adequately treated by thermal
aeration, would be incinerated off-site.
On-site aeration and off-site incineration would reduce the
mobility, toxicity, and volume and achieve permanence of remedy
by treating the majority of contaminants on site and by
destroying some of the contaminants off -site. This would
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ROD DECISION SUMMARY page 22
Cannons Engineering Corporation Site ,
effectively reduce risks associated with the site, and adequately
protect human health and the environment. All ARARs would be
attained under this alternative. Through excavation and
treatment of contaminated soils, the potential for continued
migration of contaminants from soils to groundwater would be
reduced. This alternative could be easily implemented and there
would not be a need for long term monitoring and maintenance, nor
a need for potential future remedial actions.
SC-6 Approximate Present Worth Cost:
On-site Incineration $ 3,389,000. to 5,289,000.
This alternative involves several components in order to achieve
the response objectives. The goal of this alternative is to
reduce the risks associated with direct contact with soils and to
reduce the threat of contamination to groundwater by treating all
the contaminated material by on-site incineration. This
alternative involves the decontamination of all structures,
excavation of contaminated soils, and treatment of all material
on-site by incineration.
On-site incineration would reduce the mobility, toxicity, and
volume of contaminants and would achieve permanence of remedy by
destroying contaminants on site. This would effectively reduce
risks associated with human contact to contaminated soils and
structures. Contaminant specific ARARs would be attained under
this alternative. Through excavation and treatment of
contaminated soils, the potential for continued migration of
contaminants to groundwater would be eliminated. This
alternative could be easily implemented and there would not be a
need for long term monitoring and maintenance, nor a need for
potential future remedial actions. This alternative is not
considered cost effective, in that the cost would exceed the
costs- of SC-5 but achieve the same risk reduction.
SC-7 Approximate Present Worth* Cost:
Off-site Incineration $ 7,261,000. to 15,416,000.
This alternative involves several components in order to achieve
the response objectives. The goal of this alternative is to
reduce the risks associated with direct contact with soils and to
reduce the threat of contamination to groundwater by treating all
the contaminated material off site by incineration. This
alternative involves the decontamination of all structures,
excavation of contaminated soils, transportation of material to a
commercial facility, and treatment by off-site incineration.
This alternative is very similar to SC-6, with the exception that
all the material is incinerated off-site. This alternative,
however, is not considered cost effective because it offers no
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ROD DECISION SUMMARY page 23
Cannons Engineering Corporation Site .
additional reduction of risk to human health or the environment
than on-site incineration (SC-6) and is substantially more
expensive.
b. Management of Migration fMM) Alternatives Analyzed
Management of migration alternatives address contaminants that
have migrated from the original source of contamination. At the
CEC Site, contaminants have migrated form surface soils into the
groundwater. However, this contamination does not impact the
groundwater past the site boundary. The management of migration
alternatives evaluated for the CEC site include a minimal no
action with monitoring alternative (MM-1); and active pumping and
treating of the groundwater alternatives (MM-2, MM-3, MM-4, and
MM-6).
MM-1 Approximate Present Worth Cost:
No Action with Monitoring Alternative $ 700,000.
This alternative would involve restricting the use of groundwater
at the site and instituting a formal water quality monitoring
program. Additional monitoring wells would be installed on site
and to the south of the drainage canal. These monitoring wells
would be sampled on a routine periodic basis to evaluate the
concentration of the contaminants in the groundwater and to
evaluate the dispersion of the contaminants, if any.
This alternative would be protective of public health because the
groundwater is not a current source of drinking water and is not
expected to be a future needed source because there is a
municipal water supply in the vicinity of the site. In addition,
the groundwater discharging to the surface waters is no threat to
human health and the environment. This alternative is also
protective by installing monitoring wells on site and off site
for groundwater and monitoring surface water to detect any .
potential threats from the site. It would attain ARARs for
groundwater in 15 - 20 years as natural attenuation dilutes and
disperses the contaminants. This alternative would provide long
term effectiveness, is very easy to implement, and is the most
cost effective management of migration alternative. Although
this alternative would not reduce mobility, toxicity, or volume
by treatment, such action is not necessary on the basis of low
levels of contamination which do not pose a threat to human
health and the environment.
MM-2, MM-3, MM-4, and MM-6 Approximate Present Worth Cost:
Pump and Treat Alternatives $ 2,400,000.
The pump and treat groundwater remedial alternatives involve
extracting groundwater for on-site treatment.
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ROD DECISION SUMMARY page 24
Cannons Engineering Corporation Site •
Two different pumping scenarios were developed for each of the
management of migration alternatives. Additionally, a range of
extraction efficiencies was considered for the two pumping *
scenarios. Depending on the configuration of the pumping system
and the extraction efficiency, the time to effectively pump and
treat the groundvater will vary.
Pumping Scenario 1 - Multiple Extraction Well System: One pumping
scenario, termed the multiple extraction well system in the FS,
involved installing five pumping wells down gradient of the
contaminated areas, and installing one well near a suspected
source area close to MW-2.
Pumping Scenario 2 - Hot Spot Extraction Well System: The other
pumping scenario, termed the hot spot extraction well system in
the FS, involved installing two pumping wells down gradient from
MW-2 and MW-8. These were the only two wells that showed
significant levels of contamination.
Installation of extraction wells could be easily implemented.
However, hydrogeologic conditions at the site limit the
practicability of drawing water from the aquifer for treatment.
The difficulties of extracting sufficient water volumes in a
reasonable time frame diminishes the effectiveness of the
groundwater pumping system and increases the technical difficulty
.of extracting organic compounds from the groundwater. Moreover,
site investigations show groundwater at only limited locations
beneath the site is contaminated at levels that exceed ARARs.
The treatment technology for each alternative is different.
Alternative Treatment Technology
MM-2 UV-020nation system
MM-3 Air Stripping *
MM-4 Carbon Adsorption
MM-6 Air Stripping and
Activated Carbon
Alternative MM-2 (Pump and Treat by UV Photolysis/Ozonation)
involves groundwater pumping and UV Photolysis/Ozonation (UV/0)
treatment to destroy organic constituents. Contaminant-specific
ARARs in groundwater would be attained over a period of years,
depending on the pumping system and extraction efficiencies.
Treated groundwater would achieve ambient water quality criteria
(AWQC) levels and would be discharged to the wooded swamp.
Long-term pumping operations would be required to extract and
treat contaminants from groundwater; thus, considerable annual
O&M expenditures would be incurred. Present worth for
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ROD DECISION SUMMARY page 25
Cannons Engineering Corporation Site
Alternative MM-2 varies with the pumping system, restoration
time, and extraction efficiency. In terms of present worth.for
equivalent pumping times, Alternative MM-2 would be the most
costly MM alternative involving active restoration.
Alternative MM-3 (Pump and Treat by Air-stripping) involves
groundwater pumping and air-stripping treatment to remove VOCs
from water. Contaminant-specific ARARs in groundwater would be
attained over a period of years, depending on the pumping system
and extraction efficiencies. Treated groundwater would achieve
AWQC levels and would be discharged to the wooded swamp.
Long-term pumping operations would be required to extract and
treat contaminants from groundwater; thus, considerable annual
O&M expenditures would be incurred.
Air-stripping is widely used to treat groundwater at hazardous
waste sites and is considered a reliable technology for VOC
removal, and equipment and services are readily available from
several vendors. Present worth for Alternative MM-3 varies with
the pumping system, restoration time, and extraction
efficiencies.
Alternative MM-4 (Pump and Treat by Activated Carbon) involves
groundwater pumping and activated carbon treatment to remove
organics from water. As with the other three active restoration
alternatives, considerable annual O&M expenditures would be
incurred because of the long-term pumping operations. Treated
groundwater would be discharged to the wooded swamp and would
attain AWQC levels. A period of years would pass before
contaminant-specific ARARs would be attained.
Like air-stripping, activated carbon treatment is widely used at
hazardous waste sites to treat contaminated groundwater.
Several vendors market granular activated carbon (GAC) units and
the technology is considered reliable. Disposable carbon units
would be more appropriate than larger GAC systems at the CEC site
because of the expected low flow from the pumping system and
because of the relatively low concentrations of contaminants in
groundwater. Saturated carbon units would require replacement
and landfilling. Annual replacement would be anticipated based
on observed contaminant concentrations at the site. As with
other treatment alternatives, present worth varies with pumping
system, pumping time, and extraction efficiency.
Alternative MM-6 (Pump and Treat by Air-stripping and Activated
Carbon) involves groundwater pumping and treatment by air-
stripping and activated carbon to remove organics from water.
The considerations discussed for each treatment method
(Alternatives MM-3 and MM-4) apply to the combined treatment
system. Contaminant-specific ARARs in groundwater would be
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ROD DECISION SUMMARY page 26
Cannons Engineering Corporation Site
attained over a period of years, depending on the pumping system
and extraction efficiencies. Both systems are considered
reliable and have been used together to treat groundwater at
other hazardous waste sites.
Alternative MM-6 was considered for detailed analysis because
combined treatment achieves primary removal of organics by air-
stripping, thus reducing carbon utilization and extending the
time to replace the saturated activated carbon unit. Because of
the relatively low concentration of organics in groundwater at
the CEC site, the cost savings achieved through extending carbon
replacement times would not cover the capital costs to install
both units and the O&M costs to operate both units in the
long-term. Both air-stripping and GAG treatment individually
would be expected to attain AWQC levels in the effluent. Thus,
while combined treatment would achieve groundwater contaminant
removal, other treatment alternatives would attain ARARs at less
cost. As with other treatment alternatives present worth varies
with the pumping system, restoration time, and extraction
efficiencies.
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IVALUATIOM CBITUIA TO 1C COMSIOCXCO POt lOCDT
aLECTIOM AT THE CEC SITE, MlOGCWATUt. tUSEACHUSKTO
ALTUUUTIVE SC-1:
NIIINAI WO-tCTlOt
dlTTlIA
• CMLMUMt-MCCifiC ACAJU
Ucatie«-aa*cific
• Act icM-t peel fie AtAJta
Mt
fM>ral aa4
wt*x »
Mt
t# M «CtlM f»r
2.
• Troataoat
t* M
•£ u?ccte4 r*4uctloa i
•Dbilitr. *r voiMe; i* it rcc
•r
ftt* *t
J. U«rt-t«r» Iffectii
riiu
a* of **Uti*«
riaka ta coMuoity, worker*.
viU criteria.
- .
M '
o Tim Mtil protectIM la
rm tffecti
•(
risk
oMl ce«tr*U
o rvtcatlal for future expoann to . fi
••—"-- nod laTlrnnarafil roceptora '
far
Potcatial
S.
Ability t* caMtnict
Skert-t«cm ralimbllitf of
. »r
Mtarml
OB of oxiatlac rlaka.
risk*.
Mt
Will
raliakility.
be accmratoly eotiiHtod; likely to be
eorciMfCAlc riako rovala.
rootiM Lau-ten Mia
«f ea
»f •royerty
fat*
Potectial fabuc eiyoc«rc t»
receptor* rvaaLa* f*r acveral year*.
Mt aMlicakle.
laaily
Reliable for ah*rt-t«iM.
-------
aimu
• Ability ta aaaitar cffactivaaaa* •£
Ability ta aarfan aaaratiaa tut
a Ability ta aaaartaka aaaltiaaal
raaaa'ial •ctlaaa, if
aacaaaary la tta fatara
a availability af aacaaaary
aaacialiata, aatf tcaataaat, •taraaa,
aarf tiaaaaal aarvicaa
U akuU afvcvvtU t
t* c*«r4Uwt« vltfc, cctec
• Of«r«ti«« ••< •a
, if
wrU M«lymi>
feuuv
CMU
>Mlt«r.
M* u*«ct M •kility t*
•ct !.•••.
aaiy ta
fatara
1*0,100
ttft.zso
$10,004
S«raral •illlM
Mil: Tbaaa avalaatiaa critaria ta ka «aa4 la tta cvaaay aalactiaa aracata vara aaaatatf fra* IFA OftCB Oiractiva
•a. IttS.O-ll, "Attitiaaal lataria Gaiaaaca far fl'IT Uearaa af Oaeialaaw (Jaly 24. IM7). Faataata4 critaria
earraaaaa4 ta tta fallaviat atatatary factara U OICU, aa aaaaaa4. lactlaaa Ul(k)(l)(A
4 • tta laac«tacB aacartaiatiaa aaaaciata4 vitt Iaa4 4iaaaaal
I a tta ffaaUi abjactivaa, aa4 raajairaaiaata af tta Sali4 Waata Oitaaaal Act
C a tta paraiataaea, taaicity. aability. aad araaaaaity ta kiaacewaalata af tta aaaaraaaa nAiHarat aa4 ttair
• a abaci- aaj laaftara aataatial Car aavaraa kaaltt affacta fraa kaaaa a^aasn
1 a tta aataaxial Car fvtara raaa4ial actia* caata if tta altaraattv* naa4ial actiaa U taaatia* vara ta fail
6 a tba aatMtial ttraat ta T-ir~r kaaltt aa4 tka aaviraaawat aaaaciata4 vitt aicavatlaa, traaaaartatiaa, aatf
raaiaaaaal, ac
-------
EVALUATION CRITERIA TO BE CONSIDERED FOR REMEDY
SELECTION AT THE CEC SITE, UIDGCWATER. MASSACHUSETTS '
ALTERNATIVE SC-J: SOLIDIFICATION AND ON-SITE ICRA LANDFILL/
OFF-SITE INCINERATION OF KB WASTES GREATER THAN SO PRI
CBITHIA
ASSESSMENT
Coapliaoce »ita IRARa
o
o Ucatiom-tpecific AIAI*
Caatasiaaat-apecific UARa
I
• Actiea-ipeclflc AtAta"
2. ieductioa af T»«ictty. Hobillty. or Voluae
• Treatacat proceoa employed, ead type
aad aaneat ef eatcruie te be
treated
• Degree ef expected reduction U taticity,
aobility, or volMae; ta it penaaaeat
•r eicBlflcaatT*
• Fate •( t«sl4iMla rcMi*i«c After
3. Ihort-tera If feet i*
tty. verkert
ri«k>
Skort-tera
•*4 Uc M
• CoMpliaace trltt criteria, adriaerlea,
e Tiaw uatil pretectie* ia acairred^
, „
laa '
Loat-tet» ttf ectly*e«aa
*'i>C'C
at mioual riak
eni reliability of
aa4 UatitutioMl coaxrala ' ' '
e Long-te ret •aaa|eaieat
e Poteetial for future ecpoaure ta D .
biaMa aad eavlrooawatal receptora '
Potemtlal ajactf for repla
S. Iep
• Ability t* coaiatract tecfaaalegy
• Start-ten reliability af
witt all
Sitiif af Ua4flll ud ucavatioo of wetlaida My be
iacouiateat vitt ref«latioaa eeai|netf ta areuct
«etla«4a; bovrrer, ttia «euU be affaet by beecfita «f
clea«ia4 «elLa*da, ae4 barm ta wetLaada would be
Cee^liaece cea> be it tailed.
Solldlficatlae, vauld reduce avbility af cee,tMia*e>u
af coecera, «a deteraiecd by beacfc-tcale
SifKificaet ra«acti«e, expected ie Mobility Md toxicity
(toaicity rvaactiiM iadicect aa a reault of co«-
Re ti dual a rae»U, altbae«b co«t4Ued; aatural
defradative •rmceaac* la aaaerabic aoil cevir
are likely.
Slpificut redectiee, ef eciatie* riaka.
Ho aipiificaat riaka expected.
Coapliaace MM Id be acblevW.
Pratectioe, aekirnd after laadfill coeplcted;
approti*ately 2 te i eaetaa far *ario«a tar|et levela,
fnej bc(Uai*« of reaiedial actiee,.
le*iew*l carriao|e«tc r|aka below aelected target
level (i.e., <10 l,
-------
anou
Aiscsscurr
Ability to a»eicar effect*
Ability u serfem eeeratiee, aa4
foetttieaa
• Ability U aaferttba a4tfitieMl
NBje4ial aCtiaM, if *eee»4
aeceaaary U tte fotim
• Availability ef aeceeaary
eeecialieto, aarf UMUMC, (terete,
aa4 ilafeeal aervlcee
Ability to ebtaift aa*revela fr
to ceartfiMtt vitb. ttter
ft. Ggft
, it
M M«ily
bay to
All
Mal NM4U1 actiM* CMU4 bt
rfecialiata, ae4 §ervic«* readily
Otlitely to etui*
fra «Uto M4 Ucal
••< liability
it?
It.SU.M* to I2.U2.SOO for
litely.
$40,000 for Ut year; $21.000
(1217,000
•C tor|tt riak
»"?
$10.000 aacb (IIS.SOO ereeeat wrtfc)
$2.136,500 to $2,936,000. for reaea af
Several tee
-------
EVALUATION C1ITERIA TO l£ CONSIDERED FOB
SEUaiON AT THE CZC S1TI, UIDCCWATER, lUSSACXUSETTS
ALTUNATIVE SC-4: SOLIDIFICATION AMD OfT-llTI tOtA LANDFILL/
OFF-IITE IICINUATION OF KB WASTES CREATE* TMAJI SO PRI
OtlTULA
ASSESSMENT
1.
2.
Coapllaaee «ita OAta
• Coetaat*aat-tp*ciflc
• Ucatiae-e»ecific AtAfta
• Actlee-aeaclflc AJUJU"
lea»ctioa af To«lctty. aoeility. ar V«lta»
• Traatawat •reeeaa eaaleyed. aad type
••4 aanaat •( eatarUla le ba
tractae*
• Decree ef azawct*4 reavctloa U l«clcicr.
•0*11117, »t TOllIM; 1* It pCf»«MBt
•r
( rMl
tntuwat
3.
tle* «f
rUU
Stert-tcni rl«k« to
.. „
a* '
• .
witk criteria, ••>i««ri«il
•( re«t4u«l rid
nliaftility •(
* i,r e
a Potaatial far future cxpoeure te -
kuaaa aad eaviroaacat*! nceptara '
.r
S.
• Fataatial
Ia»leaaat»bilitT
far re*lac
• Ability ta caMtract tachaalogy
witM all
•( iMdflll «a4 ucavatiaa «f wtlMd* aaf ••
iaco«ai*tc*C vita r*|iU«tioa« aulpwd ta vrataet
iMtlaaac; hover* r, tki> vowld kc •fftac by kca«fita •(
cl««aia| Mtlaaaa, aad kaca t» <**tl«ad« v»«ld •«
Caatiliaac* cam ba
•alUiflcatlo* na«U radaca aafciUty •( caacamiaaats
•( caaoara. M a«t»cmla«4 by k««c*-«e*l« taatia«.
at nawtlaa txrfct** U aaaillty «ad uciclty
(toKlclty ratfactlaa Udlrvct aa a raault •( caa-
taiowat).
leaiduala reaaU, al
4e|radatlve preceaaea la
are likely.
; aatiiral
aaaerofeic tail •avire
SlialCicaat raaactia* af cxiatlac riaka.
•o •i(mi(icaat rlaka
liaan «ea!4 b* ackla«a4.
Protactlaa acki*««4 after laMflll eaaalated;
apyreBlamtaly 1 ta 2 aaataa ta caa»l«ta fraa
ba(iaaia< af raavaial actlaa.
laaldual rlaU raaaia. aa4 «mtU ba
laaafill (allure acnrrwl.
if
t« ba ra liable, bat eafareaeaa aauiral ar
a Lapacu cottla* coaceivably accmr.
Lee«-ten e»ma|«Meat af laadfill raoiilrad, aad
aoaiteriAf rc^uirea te deuaaiee tffectiveeeaa at
aifratiaa af coateaUaeat*.
an aalikaly.
fHtara
Pateatial replacaaaat aalata aver laa« ten.
taaily caaatracte4 ar aaa already awatlaala coaacrcial
facility.
reliability af teckaalesy
•i«aly reliable aver •aart-tere).
-------
ctrmu
e Ability te aMiter effecti
•f
• Ability te acrfem aeeratiaa aotf
• ability U aatfert«ka
raawtfiel actiaM, if
MCMMCT U tke f*Ure
• Availability •< MOMMCT
aeeciallata, Ml treateMt, a terete ,
ae4 •laf«*al
• Ability te ekCei> •«»r^*la frw.
vtU,
e Ukel
4. Ceet
e CayiUl
• CMU •( fivt-TM*
, if
M4tti*Ml nartUl KtiMt My •• Ufficvlt U
*c • Urt* c«*MrcUl (•ciUcy.
All
•fceUlUU, ul MnriMi rt«4ily
Ukcly C*
Ity
litelf.
tl.l7ff.000 U $3. 314.500 f«r tM«* »f urftt
riak l«««U.
••t
Nrfcra c«vt«f if
IS.34ff.000 U I4.143.SOO (UcUAti
f»r ra«ca •( tarftt riak
Ccvtral aaarfnl rfcaaaiaal tellan far aw]«r rt«>aira,
if Mcoaaarr; a«v«cal silli** tellara 4u« t* liakility
t» raflac*. ac Uflaavut alternative raa«4ial actla*,
if caavarcial facility (aila.
MOTI: 1kaa« cvaluatia* criteria ta k« w*4 U Ue raaary Mlcctia* •r«c««a van a4apt«tf fraai tf* OSWI Directive
•e. tUS.0-21, aa44itiee«l Uteri* C«ti4a«ce far FT'IT Iec*r4a af Baciaiae," (July 24. IM7). Fa«ta«te4 criteria
cerrtepee* t» tte fallavia« atabtury fectan U CUCU, aa aaM4e4. Sectieea 121(»)(1)U
Urm«k 8):
A • tke leaftea vacertaiatiea aaaeciat«4 vitk Iae4 aiaeeeal
I • UM eaala. afrjectivee, ae4 ree>iree««t* af tke Selitf Waate Oiaee«al Act
C • tke aereiatajM*. tecicity. •ability, ae4 erefwMity ta bieeccieMlate af tke kaaartoia anbataacea aetf tkeir
itit
0 • akerf ae4 lee«-tena **be*tial fer a«*ene kealU effecte fra
f • tke eetaiatial fer f»t«re raeeilil actiaei ceaU if tke altenative nawdial actie* U eeeatiea wen l» fail
» tke feteatiel tkreat U
n4iaee««l, ar cvataieawet
bealtk ae4 tke eevlraaaMet aaaaciateal witb> axcavatia*. tra*aa*rtatiaei, ae4
-------
(VALUATION C1ITWIA TO IE COMSIOCXID FOB IENEDY
SELECTION AT THE CEC SITE, WIDCEWATER. IUSSACHUSETTS
AmWtATIVE SC-S:
OM-SITt THEMAI ACIATIOM OF VOC WASTES/OFF-SITE INCINEJUT10* OF KB AMD PAH WASTES
ASSESSMENT
2.
Caoplitoce with AiAKt
o Coateaiotat-tpacific AIA1U
• Ucttioo-tpeclftc AIAJU1
• Actloa-iDeclflc AIAJU
ieducttoa of To«icity. Mobility. or VoU
Trtttacat procai* employed, cad try*
tad oaouat of atteritlt t* be trattau
o Degree of ecpectod reouctia
oobtlily, or *O!MK; it it
3.
Uort-tera IffectlT«ae»t
of reductloa of
• rltkt to coojaui
ctak«
. werlura,
tk*
with crltarU,
MCtl pn>t*cti«« it
4.
of
ri«k'
A.B.C.C
ra rtUablUty o(
•Ad iMtitutloMl ceatcoli ••'
PotcatUl for (utur* «xpo«ur* Co D
«ad *avicooBeac*l receptor* '
far
Ability t* cowtntct
would b« ttt«ia*4.
would bt •tttiaad, t««t-t«f» bemcfit* •(
«( wttltadi for wast« naovtl would affitt
>tt*i*ed.
ld
I«ciMnt« *c
rttk L«t|*C l
t«r|«t tick lrr«l«
toil* wiU PCS* «*d PAJU «t
Mtctc Mill wiU PCte >SO
»«iU CMtMilucod «t
*«r«tla« (»trirola().
t Md pct*«Mflt rvtectlo* !•
would te «tC.U»«4 (if tudfill »oao Mil*.
Q« would »ot be p*r**Mttt for tbo«« Mils).
frooi tr««tMe«c proc*«i would be c«pt»rnl id
c«rbo« filler*. u4 ultiJMtely iettcoyed. tetidualt
Uadfxll would b* eoouiAed; uturtl iegrkdativt
procette* ta vuerobic toil eavtrooaeat 4r« likely-
Sifalficut nductiou of ulstUf rttk*.
•o ritkt upected; bttltk Md ktfety Md
eoatrol «tttur«« would eli«iMtc pouatltl ic ritk
reduced below llaltt e«t«blltbed fraa •ece»Lt*ce
(UidMCW.
•o loufUi* coutrolt required.
•o louc-terw r*quire*efttt for »oilt; irouadvkter
uoeltorio4 required to ittett effectiveaeti tftcr
cooBletiou of •eAtgeaeo.t of oiirttiou reaeditl
•Iteraative*.
Mo pateatieI foe future ecpotur*.
•o potcett*! for rep lac
•t.
Tecbaolofy eetily coattructctf.
-------
page 27 (h)
• wart-can rellMUltr •( uctealacr
• ability U aMitor aCCactlvaaaaa •{
• ahilltr t» aarfaaa aMntlM aa*
(MCtiaM
• ability to M*artoa» *44lttoaal
actiaM, If
Uta» feton
• availability af MCMMCT
clallata, aatf traacamt, auraM,
• ability to abtato apfcwrala Craa).
liMto Vitt,
a UhallbM4 af
C*£t
• OftUl
CMW
. 1C
• . NtMLlcl fMM* CMH4ial tCtttM
CMU
•CttMA M*f t* Mtf*Ct«k*, 1C
, aMcialiato, aa4 traatMttt aaa
MrviMa irf«i n< ta aa availakla; to
•CC-atto tactoaratla* eaa*clty •raarta< ta aa
•Ita availabla at
ta
vtth
ll.TU.MN U I3.0U.MO («r
CMU M4 UrMt riak 1«*«U.
t* *luUM
•( Mil »CMM>IM;
WC MfllCMU.
tl.lM.OOO u 13, MS. 000 (lacl«4M CMtUMMf) for
riak
(allwre
•f •((••iu lM«eill *cc«rra« (1C t*U MS C*»IM (*r
PCI- Md fU-CMtMtMtM" Mil*), IM«ltla« U MtMtUl
liMlllty (M* iC-4).
lMClM erlbni* t* M M*tf to (•• tMi«y ••lactiM »C»CM« wc« •AMtM' frM WA
w. ias>.t-tl. **441tlM«l Utvria «HiM«c« I»e IT'IT tec«rw *C 0*cUU«M (July 24. IM7).
t« CM (•ll«vU« *t«t«(«cT Cactan to CUOA. aa MMM«. SacllMa Ul(kl(l)(4
a):
MOTS:
A a tfc* laafton a*eartototiaa taaaciato* viU Ua4 41apaaal
• • UM Mala, abjactivM, aatf ra^miraaaato aC tka tali* Waato OiaMMl act
C • Ua MraiatMoa, toslcity. •ability, aa4 araawaity to btoaccMalato aC tka
• •
I •
f a
Otncttv*
MU4 crtt«rt«
tfctir
,- aatf laa«rtoa« MtMtial Car acwna baaltk aCCacu It
tW MMktlal fac C»ta« raav«tol acttaa CMta If tka alUraativa na«4ial aetiM to MaatiM war* to Call
tka MCMttol Ucaat to MMB aaaltk aa4 tka MvlrMMMt Maaclacatf wlU aa*avatlaa, triaafirtattaa, Mtf
ca4UMaal. ar
-------
EVALUATION CBITERIA TO IE CONSIDERED FOR ftEMUY
SELECTION AT THE CEC SITE. MIDGEVATIR. HASSACHUSETTS
AUUUUTIVE SC-6: ON-SITE IMCINUATION
ASSUSMEMT
2.
Coapltaece with IKAJta
o feetmminaet-epeciftc AfAfta'
o Lacatiee-tpecific AKABe
• Actioe-tpecific AlAta1
teducUoe. of Toaicity. Hobilttir. er Volu^
o TreatMMt proeeet o«ple>r«dl a*d type
a»d Miiiiot ef Mteriala to be treated
Decree ef txp«ct*4 rt^MCil** U t*KiciCT,
•Dblllty. *r volai*; it it >»c»iiMt
•C •ifBlfiCMtf*
3. Sbort-t«ni If fecti»«aa««
tf rt^uccioa »f
aaet «itk criteria, adriaoriea.
iMCll prauctio* it
4.
Laaf-ter* reliability of eaiiaccxiac
ted iMtitutiooel coatrola ' * '
• Potential for future exposure to 5
nccptar* '
BMd for npUc«HMt
Ability t» CMMtntct
coi nli«»ility of
C of ri»iJt»l
•ctiM, it 4 t» 7 •notbt.
from lr*«taefit
cirboo filt«r« ud
Si|»iftcMt
•o risk*
coatrol M
c«rcio*|e«ie ri*k b«lo«
(i.«., <10*>. <10**, »r <10*T);
rcducod Ulow liaiU ttukli«k«« f
guiduico.
•o lo*|-t«cm caatrol*
riak*
*ccK«t«hl«
for toil*; (roundvcter •oaitorvac required to
•ffecti«e*tti after caa^lctio* of •*a*(eM*t of
•i(ratio* reMcdial alt*r«aiti««.
•o poteatial for futara ecpoouc*.
Ho potential for replaceMst.
Tcebaolour eaaily
reliable.
-------
armu
ACStl;
t.
a Ability ta aaaitar affactivaaaaa af
• Ability ta tarfacaj •aaratiaa
• Ability ta aBaartaa* •44tti«Ml
raMdial fCtiM*. if
aaeaaftacy U taa
• Availability af aacaaaacr ,
aawcialiau, 4*4 traataawt, atacafe,
few, u4
• Ability ta
wit*,
e*«u
( if
MCt* M«lf*U
Ul
£«*cti«M Mty U •*'<•*»•
. if
MCtMCFf.
Ucn««« vita tiat.
ItitUl
••••i
Uf«c
cute
ci«m.
It.TU.OM M 14,231,000 f*r
riak !•**!• .
•<
fet
if
IJ.Ut.OOO t* tS.ZM.OOO
r«««* *f Ur«*t risk
«*«a CMtU«MCT) Ue
M9R: Tk««« «v«liMCiM eriUric (• •• «««4 i« tte rmmtf •»l*cttM
to. f))S.O-tl. *U4itleMl Iat«ri« G«t4«BC« f»c FT 17
t* U* UllMfUf •t*titt*cr f«ct«n ia
0):
w*r* «4«pt«tf fr«* IfA OMU Direct !«•
M* (Jwlf 24.
C • tfc* ••nUuaca. taatcity, ••killtr. ••4 •c*f«*«itf u ktMc
•titumta
Act
•( tfc* >«i»r*»ai wik«t«ac«« «*4 tteir
D • abarf aatf laaftc.ni pataatial far aaVaraa kaalU affaeta frwa
I • laaftccB) aaiataaaaea eaata
f • Ua pataatial far futiure raaa4ial acttaa eaata if tka altaraatlwa c«aa4ial actiaa la
«*n t* fail
6 • ta* aataatial tkraat ta
. ar caata;
•aalU **4 taa *avii
•t •••aei«ta4 with aBcawatiaa,
-------
[VALUATION CRITERIA TO If. CONSIOUtEO FOR UKCDY
SEUCTIO* AT THE CEC SITE. BRIDGEVATER, MSSACHUSETTS
AlTUUUTIVt SC-7: OFF-SITE IMCIXERATIOM
page 27 (k)
OriTWIA
ASSESSHEJfT
1. Caaglisnce vtm ARARa
i. Coataauaaat-specific ARARs
• locstioa-speciflc ARARs*
2.
• Actiaa-speciflc ARARa
Reduction of Toiictty. Mobility. or Volume
• TrettBcat process ••ploy**, sad type
••4 asauat »f eaterlals ta be treated
ef expected reductlaa la tacictty,
ii
•r
of
J. Short-tera
• tUgaltude at reduce loa •( uittia«
risk*
a Ihert-ur* risk* to ceauaity, worker*,
•ad Uc ••vireoMAt durta* LaplaaB
MCc vttk criteria, •dViva
Ttaw uatil pratcctio* is «cai
4. Loixt-t«r»
A.i.c.a
a Haeaitude of residual risk
o Loat-tera reliability of
aad iaatitutioaal cootrois '"'* '
•ad
Poteatial for future exposure
ausua aad eovirooawotal -receptors'
Poteatlsl aeed for repla
0 0
'
a Ability ta eonatruct tec«aolo(r
a Sbart-ten reliability a* technology
Coopliaace would be •ttaiaed.
Coa^liaacc would be stuiaed,
cscivtct«4 of vetlsads for vsste
•aort-tem ia^acts.
CoapliMC* maid be sttaiaed.
laciaarste soils *c tarfet risk levels.
beaefits of
v*l Mould affiet
Sigaificsat aad ••<••
aobtlicy, ud «•!•••.
it ndactio* la tosicity,
tesiduals frost rrsifarnt process would be captured ia
carboa filtars *ad ultimately destroyed.
Sieaiflcsat redactioo of eilatla* risks.
•« risks expected; aealUi aad safety aad aaisstoa
caatrol acssures would tliaiaate poteatisl risks.
Coaplleace would be sttaiaad.
latiatated tia* ta cweplete, fro* ialtistiea of remedial
actioa, is I ta l.S years.
Residual carciao(«alc risk belov selected tarfct level
(i.e., <10**,
-------
Afsusmrr
a.
Ability ta aaoitar affecti
•f
ability u parlan aaarctiaa aa*
• Ability U wUarttka U4UUM1
naval*! actiaaa, i£
U taa fetiira
• Availability af aacaaaary aa»i|
•aacialiata, aaa* tvaatawtt, itaraaa.
MCVtCM
• Ability u
U C
, if
CMitc*
Ul
CMU
taaily
Opcraciaa M4 ••
r««4ilr «T«iUbl« wit*
i availability
, if
MCVtGM
Mtf
U i*ct««M «iU ti
aa vtU ttata
IS.J7«,OM t* tU.333.MO f*r
«« 1C *pf Ucablt.
ritk
••C
W.7U.OOO t« tlS.4U,000 (i
raa«« •< fcac(«t fiat Irwla.
lal e*ac«
CMtiM«*cy) far
Wtnt: TWaa traltutia* criteria ta »• na«4 i* the rarity Mla«tia« pr»caaa war* *4apt*4 fra* IP* OHM Oiractivc
IU. IUS.0-21. *M41tiaMl latcrl* teitfaac* far FT«7 kcartfa af Oaciaia*" (July 14, l»«7). ra«u*t«4 criteria
ta U* fallavla« statittarr factara U O«CU, aa !•••<• I. tectiaM Ul(»)(t)(A
0):
t**ir
aaaaciata*
I • ta* taala, •bjactivea. aa4 r«*«iraa*ata af t*a Sall4 Waata Diaaaaal Act
C » ta* »«raiata«ca. tacicity, a*bility, aa4 araaaaaity U biaacciaavlata af tb*
caaatitavaM
0 • aa*ct* aa4 laag-tata) aataatial far atfwaraa baalU affacta tram
r • tA* aatMtial far fataca raa*4ial actiaa caata if taa altaraativa
ial actia* U atttatia* wara u fail
6 • tkc a«ta«tial tltcaat t*
ra4iaa««al, ac caata
tealtk aa* ta* awrirmut aaaaciaU4 «iU eicavatla*, traMa*rtatia«. aa4
-------
page 27(m)
EVALUATION CRITERIA TO BE CONSIDER!!) FOft RMEDT
SELECTION AT THE CSC SITE, IRIDCEVATER, MASSACHUSETTS
ALTERNATIVE W-l: HINIKAL NO-ACTION
ClITEtIA
ASSESSMENT
1. Coapliaace with ARARs
o Coatasiiaaat-speclflc ARARs
a Locstloi-SBCclfic AtARa*
o Actioa-tpeeific sJURs*
Achieves coatt*ia«at-sp«cific AlAls over • period of
yesrt through utursl ttuoiutioa.
Coflplias.ee vlth locstlovspeciflc AtAl*
di*char|e af coeXaaiMau ta wetlaads would aot esceed
AUQC.
bcept for corrective actio* re^uircawsta, covpliaace
would be ttLaLsed.
2. Reductioa of To«lclty. Mobility. »r Volus*
a TrestaMt process •glared, sad type
••4 lanuat af aaterlala to be treated
• Degree of expected reductloa ia teilclty,
•ooillty, «r *°iv—-i l* it
or aigAiflcaatT
a Fit* e( rttldiMl*
Uetiaeat
after
so tr«a
af
t to reduce aofclllty, taticity, or volMM
Natural atteauMtloe, •roce«aea r*4uce eo*ce*tratioaa af
coetaaiaaata la t,ro*iA4vat*r «rer a pariod «f year*.
Cootaaioasta ia (rouadwater dlacharte to draiaate
caoal where volatile cooatitueata volatilise Item
surface water. Only liait*d Ij^acta la aquatic
or|aaiaa« expected because of the law levels of
coaLastiaaats la
3. Shoct-ttt»
o IU(aitu4c of re4uctloo af eciitiof risk*
• Short-teem rlik« to cnaaninUy, worker*,
•ad the
4ucia|
• Coaplltice vltk criteria, •dviaarlea,
aad
Tim uatll protectio« la acti<
Tariet risk levels sad BCLa achieved through aatarsl
atteauatioa ia the loot-ten. The alteraative would
ea?loy lastitutloaal coatrols to preveat |rouad«ater use
ia the short-tar*. Grouodwatar aot preseatly used for
domestic purposes.
Noaitariot well iastallttioa aad saem>lis« poa« •iaLaal *
risks to worker*, caavjuaity, aad eavirooacat.
NCLs aad tartet risk levels are preseatly exceeded
la (rouadwater at the CSC site.
Oa-site receptors expected to achieve ItCU aad 10**
rlak level ia 22.S years (aee tectloa 7.4 aad Table
7-21).
4. Loni-terai EffectiTeaeaa
o lb(mltude of residual rlak'
A.I.C.C
o Loa|-term reliability of
and ioatitutloMl coatrola ' ' '
Loaf-ten •aoa(ea]ent aad eaailtorl«c
require^ata*'*'1*
Foteotial for future CKpotur* to ^ g
humtm «nd eavtrooaeatal receptors '
fcesidual risks decrease with tla* through aatucsl
atteauatioa.
Loeg-tersi aooitoriag expected to reliably evaluate
coataaiaaat distributioa aad changes ia site coaditio
with tia«. Loog-teoa reliability of lastitutioaal
coatrols uacertaia.
Loag-ter» (I.e.. M-yesrs) grouodwater aooitoriag
prograa required.
Potential for future developacat of grouadvater for
doaestlc purposes considered reawta. LiaUted future
impacts to eaviroavjeatal receptors ia wet area aad
draiaage caaal because of the low coaceatratioas of
coataaMaaats ia grouadvater.
-------
CtlTOlA
(CMtUtttd)
ASSES
• NtMtUl M*4 (ac rtaUcMMt
a Ability ta MMtmct tacaa»U«y
a Sbart-tam reliability •( taebaalagf
a Ability ta aaaitar t(fcctivMM« •(
• Aaility u aar(am •Mntiai
• Ability ta Mtertftka «441tiaaal
Ul «ctiaaa, U
U taa (Man
A*t11ability •( atc«««ary ta.*iM»at,
•••culitts, «a4 trtataaat. atarii*.
••4 ii«»M«l Mnrica*
Aaility t« *bt«ia •aar«v*U tnm, u
i* cMNtMU wtU, *Uar
UMU
•C
•ity
C«fiUl
CMC* •( (t
, if
Ptrio4ic nylacMMt •(
. If futurt
Will
tMily
ftb MalyvU raliably
Utll Mtwvrk tfftetlvily iMlUn siU CMiiti
MtHCftl «ttMUMtlM
OCH
•Mil
Q*ly
trt«t
If
MCMMCy
ru4lly
• ItM.
«« t((«rt ky •**i
MM4 by l*c«l rMl4aat>
«Mt«c f*r 4
»C IS4.400
M •( MM MtiUrUs mils.
Varicc ««ch year
lto«t OM
ravUv nmicM. BitiMfcM n«t:
$10.000 *«ai. IOM U«al nvtm mck «!M
wrtfc (30 y«an, 101 41aewMt rate):
1421,000. PrttMC wrU ulculatiM M>MM
•yvtia lifcCiaa a*4 tyctM rtf lacoBiat •(tat
IS y*an. LtMt CMtly MMgMMt •(
•lunativi.
NtaatUl (Mara raai4ial acti** «•*!• ia«*l««
«X»«M«« t* iMUll Mi •y*r*t« • "f»M> M4 tract*
•yttM. PotMtUl cayital c**U MM 1700,000 M4
MWM! Ottl CMts. el*M ta 1200.000. 4afM4taf M
, tnataamt amit. M
WRI:
lMttM ecitart* ta •• MM4 U taa raa»4y Ml*cti«a »rM«s« twra Miytai (CM tP4 OfUD Oiractivi
Ha. •3SS.O-21, 'AaaittMal latcria C*14MM (ac Ft'11 Iccaraa •( OactiiM* (Jaly 24, l»07). raataMai critari*
carraayaatf ta taa (allawtat ttatMacr (actan ia CUCL4. M MM4a4. laetiaM 121(a)(l)U
0).
-------
(coatiaued)
ASSESSMENT
« the loo(-t«r*) uocertAiotiet •**oci«ted with l*ad
» the io*U, objective*, aod requireaeat* of the Solid U**t« Di*po*«l Act
C « the per*i*t«ace, toiicity, Mbility, *od prop«Mity to bio*ccu*»il*te of the h*K*rdou* tubiUace* Md their
coo*titueat*
D » •hare- t*d loa«-t«c« pote«ti«l (or tdvors* health effect* fro« huMO e*po«ure
I • loo|-c«c« ••ikLauMce coot*
F * the poteotial for future reaedUl action co*t* if the *lura*tive reotedi*! tctioa U qu«*tlo« were to f*il
6 « the ooteatUl thrMt to huMO, hoolth «nd the eaviroaoMt •••ocUud with tj(C*«*tioe>. traojporutioo, *«d
r*di*po**l, or
-------
EVALUATION CtlTEXIA TO K CONSIDERED FOt UMBY
SEUCTION AT THE ttC SITE, UIOCCUATU, (USSAOWSms
ALTERNATIVE m-2: PUMP AND TUAT It UV MOTOLTSIS/OtONATION
J.
• Ucatiat-tatcific AlAIa1
• Actlat-tatciflc AlAla
• Trtataatt arac*aa aaplayai, aai tyaa
af aatarlala u to traaba4
_.._ af ••pact** ra4uctia* ia taiicit*.
atfcility, ar valuat; la it acraaaMt
ar aiiaifleaatT
Fat* af raaiatala
tr— --
after
•( rateetiM •(
riato
• ltort.-t.cra riakc u
, B .
l«* •
vitfc ecit*ri«,
4.
• Tiat iistil •r«t*cti*« !•
Iff«ct<
Ackit««t CMU«
»f yean
MUr ackUvti 4MQC ItvtU.
lya
T.4 M4
7-21).
vttli faeilitr sttUc Mrf
iaw Mwl4 •• •tutart; M ••••awnc •< tte
Mn4»«t*r MtcMtlM M ta* wttU«4 «Mtl4
•• teat a»cimf caaHial aNiat; «Mt-teMtaMC 4Ueaarf«
«MiU MC aim Mill
•tiam cai at atutawl.
UcataMt
bility. W»/0,
u aiatray arcamic caMtltanta
atacnctiai »f »r|«aic c**cjata«ata •>
with UV/0| tnatatat. Cronaavatac puapi>4 c*«tr*la
•< eaktamiaaiU.
tcairv* 4UQC Itvcla «a*
MI 4iacaar|«4 U taa m*ai4 maaj wat •€ taa
Tariat riak Ivrala aai atta atUiaH WMC a a>rta4 «f
ycara t^roitflk gnuaajataf p«avla«- fctauctiam U
uiatiag riak* aiffvn vtU yaaiM »e«a*ri», wu «a»14
a«t •« *tuia«4 far M««ral yaara (M« Ccctiai 7.4 aai
Takia 7*21). Trwbal griuaantar M«I4 acfciro AMQC
walla aai traataavt aiit a*a« «iaiaal rlaka
caaauAity, varkcra, aai aaviraaBMt 4«tria4 iaitallati
aai aairactai.
HCU aa4 tarsvt rtak lev* la «M*14 at atuiaai awae a
per 1*4 •( yaara (••« kctlM 7.4 aai Tab la 7-11)
AWQC Irwla.
Cravaiwatcr iiairtti t* acklcv* HCia aai 10*' rtak !•*•!
ia ].7 ta M ycara, atawoaliac aa. fiavta4 tca^Ari* aai
MtractiM afdclattcy (aa« laccia* 7.4 aai TatU
7-21). Traatai «ra«iaawabar «a«14 laartlaUly acklcv*
AMQC lavela.
RaalaSial rlaka aKraaa* wit* tiat tkrawtk |r*ia*dwatar
aai Crate
PMapia« aai UV/0, traataatt am*act«4 u to raliakla.
-------
(coatlaued)
OtlTOU
Loaf-tent M|«|epMt sod aoaitoriac
r*o.uire»eata '*'
o Potaatial (or future tipoaim te - ,
biaMa sad eavlroaecatal receptor* '
o Poteatlal aaed for rep lac
S. laplaaeatabiltty
o Ability t» ceaatntct tacbaeleay
o Short-ten reliability ef tocfcaaleffv
• Ability ta aoeitor effectlveeaea o(
rea»dy
Ability to perfons eperatioa tod
aaiataaoace fuactleaa
Ability to eadertaka additional
medial actioaa, If deemed
eeceaaary la tbe future
o Availability of aaccaaary
•f«ci*litta. tad trt*cacot, itoc«(«,
••d dii»o«ol
ta obtaia approveIs fro*.
aaed ta coerdlaata vita, etaar
a likellbaad af favorable
reapoaae
Coot
o Capital coata
* Operatloa aad Miataaaace caata
Cooto of flvo-yoor review*, if
o Pnoo*t vortk caolyoio
USESSHEKT ___«
era puovt>« oporotloao required to octroct
•ad treat cootuloooto fro» irouodwoter.
Noaitoriac veil ioo9li*c ««d periodic treotaeat
unit ttop1104 required to evoluoto cffectiveaeto
of reoKdial act loo.
Fucun txpoiure to tmtod wotor by kuaoa receptor*
ualikely. Llaiud f»ture i^oct* to aa«lroo«ekUl
receptors tUco diockorge would cttiU AWJC limit*.
Periodic replocaeieat of rquiiaeat io, puepikf tyctoei,
UV/0, ty«to>, cad •oe.iteriaf well oetwork required. If
fystoB Uiled, puepiM tyttc* would be redeoifBod or
rcpUcod, or UV/0, uait would be reploced *ll* oir*
•tripyi«t or activotod corfea* tr
(yetoet **d W/0, treauteat tyotom relatively
oooy to co«otntct oa
Md DV/O treottvat reliable la tke ttert-ter*.
Wtll eatwort affectively eaaitor* iito cooditiou tmd
ptaplai tf foctiveae**. Periodic t«BpLia| of UV/0( uait
eaaiton trootaeat •ffectivcaeoa.
loaic routiae QCfl aaticipatod for
UV/0, tre«Ukiat aait.
iy*tan «ad
Additioaal reacdlal actioaa (additioaol pta^iat veils)
would be uadortokea if eoaitoria* **t* iadicsta a
aced to eatract eare coataelaotcd grouadviter.
Nodificatioaa to UV/0, «ait (aiaia«) taea would
poteatially be oocdcd.
Piatpiai syatcei oe^iipecat readily available aad
routioaly p«rfore»d at otaer haaardoua watte aitea.
UV/0) e^uipaeat available, but aot ia videipread MOO to
treat grouadvetar.
Approval fne> state afmcie* expected.
»ity reai
Favorable
tatiaated at $700.400 to $750.500. depeodla« oa
acaaario. Capital coat iacludcs start-up aoaitoria«.
Vanoa iepcadiag ea saepliaf prograai sad ptaapia«
sceaario. Batiaated at spproaiaately $200,000 (ace
AppeadU D.
Review "ill be coocurreat wtta aoaitoria* proireei. or
at a aiaioMsi of every five years if applicable.
Preaeat wo rib variea depeadlaf oa p«aepiac systoei,
puapiat tiaei. aad eatrsctioa efficioacy (•«• Table
7-J5). For preliatiaary aatlaote, p re seat wortb to
scbieve 10** risk >oio| Nultiple btrsctioa Well Syeta*
wit* SO percoat catroctioo officioacy ia sppreaiaataly
I2.UO.OOO. Ia terao of pre*«et vorU for equi»sleet
piomj(nt tiaae. M-2 ia taa aost coatly aaastcacet af
•ieratioa altarvative iavolviag (rouadwatar treotaMt.
-------
CtlTWA
AMUSMMT
ACttM
CMC!
Patamtiai f«t*ra
•Kfajuaa la
UV/0, Halt vtU
lal actiaa> caata tavalva
aa4 treat" tyataa at rif I«e«
•*
DOR:
4 a Ua ia«e*t«cB ««e«etjUtiaa aaa*ciata4 viU Ua4
I a tltt laala, afcjactlwa, aa4 raajulcaamu a< Ua 1*114 Waat* Diavaaal Act
C • tte aaniataaca. tacicity. •aktlltr. aatf araawaaltf U ataacnaviiau a( U*
cv«l«MttM erlttrt* u kc «M4 ia Uw r«at pacastlal tar («CM«
6 • Ua pataatial tkcaat ta
ac
•ctla* c*«c« if tte •lurutiv*
*ctt*« !• <«M«ti«« «wn t* fail
-------
EVALUATION CUTIRU TO l£ CONSIDERED FOB UHEOT
SELECTION AT THE CEC Sin. UtIDCCWATU, IUSSACUUSETTS
ALTUUUTIVE ttt-1: PUHP AM) TttAT IT AIR-STUPPIHG
dlTtllA
ASSESSMUT
Caagliaace with OAIU
• CaertAauaaafapeclfic ABABa
• Lacatiea-apeciflc AIAAa
• Actioe-apeciflc AIAU
2. iaductioa of To«tclty. Mobility, ac Yoliaat
• Traetiaeat proceee ••ploy**. aad type
aad aaouat of aabariala to be treated
e Octree of expected reductioa ia toiicity,
•obi lily , or vo^uav; la it penaaaeat
•r algaificeai?
Achieve* ceataaio«at»tp«ci(ic AlAftt iM |roua^w«t«r over
• period af ytart depeo4U| *v4Ul desica; poet-treataeat diacacrge
aa>i
Fate •<
«ft«r
8hort-ter» tff«cti»«g«»«
o( r*ductioa o( c>l*ti>t tit km
CoeetlLaace CM be atLataed.
T*te* ceatrala c««taeU.aaat eobility. Air*
atrippia« trocna atripa VOCa (ram vatec aatf traaafert
w««t*« to ta« abaoapacr*, a better a«dii«i (or rapid
dllutiM, ocidatio*. a«d raoto4«trad«cio« of
cootaouamata.
Oeatrvctioa of coat^axaaau ia the ataoipber« would
be rapid aad pecaaaeat. Crouadw*t«r puoptaf coairola
eobility of coafaattaaaca.
Treated irauaevatar would achieve AMQC levela aad
would be diacaarced ta the wooded awaap weat of the
equipawat
Target riak levela aad HCLa attaiaed rvor a period of
ycara through grouatfwator puafilag. ftaductia* Ul
eciatiac riaka diffcra with pua^iM acaaario, but would
aot be attaiaed far aeveral yaara (ae« Scctioe, 7.4 aad
Table 1-11}. Treated grouadvater would achieve AWQC
levela.
• Short-tcr* rtaha M covauaity, uorhera, .
aad the aaviroau«at duriag laplawatatioa '
a C
NCU aad target riak levela would be attaiaed over a
period of yeara (aee Scctloa 7.4 aad Table 7-11)
through pwafiag. Treated grouadwater would achieve
AWQC levela.
Crouadwater expected ta achieve NCLa aad 10 * riak level
ia 3.1 W 66 yeara, depeadiag oa puopiag aceaario aad
eatractloa afficleacy (aee S«ctioa 7.4 aad Table
7-21). Treated grouadvater would iaaaedlately acalcve
AWQC levela.
Beaidual riaka decreaae with tiaa through grouodwatcr
puaetiag aad tceatawat.
aad air-atrippiag treatavat aa^e«ted ta be
reliable.
-------
aaaiterUt;
• NuctUl for future aipoaure u . fl
•MM aetf eavireeBMetal receeten •
• NteMial eee4 for reelac
receeten
a ability te ceeat
i«cr
-teei reliability *f
• Ability te aeaiter effectiveeeea •(
a Ability ta eerfen •aeretiaa
• Akility U Mtertate
*. II
tte f»t«c«
a Ability ta
eeev. te caareiaate vita, etaer
ty
*. Ceet
e Caaital
e Oaeratiaa aae* ea
a Ceata ef
. if i»f»ir««
u utrtcc
••4 treat CMUaUMta Inm inMtrtin
NMitarlat will •MBlU« M< p*ri*4ic tnatavt
MBit tM^liM r*^«ira4 t« t««lMU tff*eti«
u trmt«4 Mt«r ky hM
Uaiutf fMtura ifl>«cta u wv
lUcc 4Ucterf« «Mil4 atUU AWQC liaiU.
Nrietfie real
If *y«UM
*r rafUmtf,
r«Bia««4 wit* activated
u etactrvct
U tft*
tfell Mt«*rk affectively eeeiUn aite ceetfitiee* ae4
aff*cti*ee«a*. Periodic taaB>U«f •( «»r-
aut eeaUten tnataae,t aftectiveeeaa.
taaic raatiae OCfl aatieiaate4 fer avaaiM ayatea aae*
A44itiae«l cwHUl acti
va«14 be M»4ert«kee, if
te tstraet eare c««L*auMta4
H»4ificatiae« te air-atriffia*
be
« «ella)
aata l»4icate a
tkee «enU
ayaue) ee/iipeeet rea4ily available aae*
revtiaely aerfece*4 at ataer bauraaae Maatea aitea.
Air*atriaeia« eajaiyajeat rea4ily available, aa4 ia nae
at aUer at tea vttk ceataauaatae' graiia e»itar.
Affrevel tctm atate ae4 lacal a<
aaeeeitiea
Faverable ceaaMaity reaa«aae eaaectetf.
ta air aaiaaiaaa aaticiaate4.
KatiMte« at »«U,MO te |»7»,000, eeaea4ia| ••
aceaarie. Cayital ceat iaclaeea atarttay aeaitarta«.
Variee
aceaaria. KatiMtetf at aaarakiaataly f Ma. 000 (
AaeesAU f).
•eview vill be cvecvrreat vitk aaeitariat rrefraai, er
•c a aiiaiaiai a( every five yean if aeelicabla.
-------
TA1LE 7-49 (continued)
C1ITWIA
ASSESSHEXT
Present worth analysis
Present worth varies depending M pushing systee),
puapiat ti«e, and attraction efficiency (tee Table
7-37). For preliminary estimate, present worth to
achieve 10** risk using Multiple Eatrsctioe Veil Syeteai
with SO percent extraction efficiency is approciautely
$2.2(0,000. !• UCM of »r*se«t worth for tquivslent
puvpioi ILHBS, ltl-1 has close U the soaa srcseat worth
M ltl-4.
Potcoxisl future
costs
isl sctioa
Potc«tlal four* raMooisl sctlo* costs Urrolve
eipeases to e>p«a4 "pwsp sa4 trcot" syvto* or replscc
sir-stripplag wait with Activated carbo* systaa.
Tvose evsluatioa criteria to be used ia the tuaedy aelectioa process were adapted (roes EPA OSWER Directive
•o. IJ55.0-21, "AdditioMl lotecl* Ouidaace for FT1 17 tec or da »f Oecisioa" (July 24. 1M7). Footnoted criteria
corresp«e4 te the feilewia« ststiitory factors ia CUCU. as aecoaed, Sectio«s 121(b)(U(a
NOTl:
A • the lo««-tacsi wacertaUtiea associated with laad disposal
| s the coals, objectives. a*4 reqaireeceta o( the Solid Ussta Disposal Act
C « the persistence, toiicity, Mobility, sad propeosity to bioaccweulate of the kaurdoita substaaces sad their
coostibieats
0 • short- aad loaf-ten poteatial for adverse heslth effects I torn hieiaa ccposon
I • loaf-ten Miateaaace coats
F • the poteatial (or futMre res»dial action costs if the sltenative raecdial sctioa in fuestioa were to fail
6 * the poteatial threat to his»aa tea 1th aad the cavirooewat associsted with excavation, transportation, sad
redispossl, or coataiae*at
-------
EVALUATION CtlTCIlA TO U CONSUMED FOft UHEDT
ULCCTIOM AT THE CEC SITE, UIOCCWATU, MASSACHUSETTS
AL1UNATIVE ltl-4: PUMP AMD HEAT IT ACTIVATED CAUOM
CtlTPtlA
1. Caajliaace vita AJtAla
• tecatiaa-eaeciflc AlABa
• actlaa-eaeciCic AlAla"
2. ieaactiaa •( Ta«icitT. aaailttT. ar Ta
• Traataaat areceaa eaaleye*, aa* type
af eater ia la t* a*
• Degree e( ecpecte* rveuctiea ia tMicity,
aekility , er veltaHi it It eemaacat
•r •igai(icaatT
Fat* ef
tcM
1. tt»rt'-Ucm
«(ttr
•( n4«ctl*a •( t«i«tl«( risk*
Sk«rt-t«c« rUU t*
, «wrkcr«,
. .
«« *
with criteria, aavtaariaa.
a .TUat aatii eretactlea ia
4. Uar-tai* Iffacti»aa»aa
( raalteal
Ackievea ceataaiaaat-taecific AlAla ia gravaaxatac aver
• eerie* af yaara etoeaaiag aa »uaaiig tyttaa aa*
iBtractiea t((ieieacy (tea Sectiaa 7.4 aa* Table 7-11).
Treat** vatar acaievea IMQC.
Ceaaliaace vita facility titiag aa* vatlaa*a aratactiaa
regitlatiaaa va«l* aa attaiae*: aa aaaaaaaaat a( tke
(afact af graaa*yat*r aitractlaa aa tka vatlaa* va«l*
ae aaae avriag raae*ial aaaiga; aaaftraal
v*«l* eat iaaact vetlaaaa.
Caayliaaea
aa actaiaatf.
syatM eaatrala caaraaiaaat aaaility.
Activatatf caraaa acacaaa traaafara argaaic caaatitaaata
fraa tMtar t* tka tarfaea af the activate* cactoa. Tka
eueaaaale earkaa aaita «a«U aa Ua4(lUatf •((•tit*
»ater «a«ld acaiwa AMQC levala a*4
aa 4iacaaraa4 la taa vaad*4 *M*» veat a( ta*
aat aaiUiac- Ditaaaaala earaaa aaita r«aUca4
•am aatarat*4 a*4 Iaa4(illa4 a((-aita.
Target riak lavela aa4 NCla •ttaiaee' aver a aaria4 af
yeara tkrauck |ra«a«watar ataapiag. teauctiaa ia
eaiatiai ritka 4i((*ra witk aMpia« acaaaria, ant «a«l|
aat aa attaia*4 (ar teveral yean (aee lectiaa 7.4 »a4
T«ala 7*11). Treat** trana4wat*r vaiiU ackieve AUQC
levaia.
valla aa4 ta* traatjaaat aait aaae aiaiaal riaka
ta cMBuaity. «*arkara, aa4 aaviraaajMt aitriac
iaatallatiaa aa4 aaaratiaa,.
NCU aa4 target rtak levcla «e«U aa attaia*4 avar a
eerie* a( yaara (aee lectiea, 7.4 aa4 Takla 7-11)
Urangk aMayiac. Traatea* graaaMNetar vavU achieve
AUQC levela.
Craa**xater eafcct^ ta achieve aCU aa* 10*» riak level
ia 1.7 ta aa yaara, aafeatflag ea ana* lag aceaaria aa4'
estractiaa a((iclaacy (aee Sectiaa 7.4 aa* Takla
a((iclaacy
7-Zl). Treat** gcwaa*wat*r va«l*
AUQC levela.
.ately ackleva
•aaiaaal riaka aacreaae vita tiaa tkravga graiiaavater
g aa* treat
nliaktlltv aC
aa* activate* eerbaa traataaat acaccta* ta a*
reliaal*.
-------
(coatlaued)
OtlTUIA
ASSESSIOVT
s.
0.
o Loaftera aiaatraant aad aealtoriag
requiraaaata ' '.
• Poteatial far future eapoeure to
aad eavtt
o Pe teat la I aeed far repla<
ital reccptar*
_.F
0,6
Ability t» eoaatraet bocaaolacy
Saorftaca reliability ef tacaaolegy
Ability to aoaiter effectlveaeea of
re
Ability to perfora oaeretloa aad
aaiateaaace fuactleaa
Ability ta aadertaa* addltieaal
reaedlal actvoa*. if
a tae future
Av*iltbillty of MC«>««ry
o Ability to ofetcl*. »pfroT«lt fro*,
to eoardiaot* wit*, otter
Uk*llBoo4 of favorable
• Capital CMta
• Oporatio* «a4 •a
coeta
Coata of flva-yoar ravicM, If
Uoj-tem pu*B)ia« oecratlooa roquirH to aitract
•o4 treat coaLaaiaaata fro« irouatoatar.
Noaitorl04 well 10091104 *e4 periodic treatment
uait (aapllaf required to tvaliute tffactivoMta
of raejedial «ctio*.
future ciaoeure to treaud wat«r *y kuaaa receatora
uellkoly. Halted future Uayacu to oavirooovetal
receptor* alAce aiacoat|« «o«14 attala AWQC llaiu.
Periodic rejplacawe*t of equiaent la puapiac syetea.
activated tarboo, ayateei, tad eaaitoriaf veil oetvork
required. If tyiuei failed, fie»jliu lyatea vould be
rcdealaaed or replaced, or actlvotod carboa wait would
be replaced vita alr-etrlpplac treataeat.
it syatea
t reliable la taa
ayatea aad activated corboa traa
aaay to coaotmct aad iealoaeat.
aad activated corboa trea
aaorftaca.
vail actvork affectively aoalton alt* coadltiaaa aad
•iMpiat a((octlv*ocaa. Parlo4lc 10091104 of activated
carboa «ait aoaitora treatacat effactivoaeaa.
kaic rovtlaa OCM aaticlpoted for
activated carboa treatacat eait.
ia« ayatea aad
Additioaal reaedial actloaa (addltioaal pueaiac vella)
would be uadortakca If aoaitorlaf data iadlcate a aeed
to tatract aore cootaaiaated irouadvater.
Hodificatioaa to activated carboa uait (aisiaf) tbea
would poteatially be
Pue01a| ayatea equipaeat readily available aad
routiaely perforard at otaer kaurdoua uaatea tltoa.
Activated carboa •qulpacat readily available, aad ia uae
at other altea vita coaLaalaated |rou*dvatar.
Approval frea atato aad local aeaaclea araerTad.
Favorable
»lty reapoaae
eatiaat«d at f6U,UO to IWJ.rOO, dcpcadiac aa puaplo*
acaaorla. Capital coat iacludea atart-up aoaltoriaft.
Varlea depcadlac aa aaapllac proiraa aad paeo)ia(
aceaorlo. tatiaated at approaiaately $200,000 (aae
tevlev vill be coacvrreat vltb aoaltoriat prograa. or
at a alaiaua of every five yoara If applicable.
-------
(c»ttiMM4)
atimu
PrmtM v*rt* «M
ftttnc* r*M*4i«l MtiM
CMtt
UStSStOT
c tiM, Md titeactiM •fficlMcy (MM T«*l«
7-M). For •cvliaiMry ••tuMtc, praMM «*rtk u
achieve 10 * rick iuU« IWlti^U btraetiM Wtll Sy«lM
•itk SO pcrcMic utr«cc»«a •fficiaacy U
$4,270,000. IB t«n» •( pr«*««C Mctfc («
p««ViM tiflM, W*4 k«t elMt t« tta «••• ^riM«t wart*
M W-J.
•cti««u4 e«(ta« «alt vita •tr*ttcif*i«« •?•(«•.
WTI: TteM «v«liMtiM crlMri* t« fc
I*. IMS.0-21. "AMitiMAl Isuria OHI««*C« Uc FT'IT tecorfe «f teeUiM* (Jwly 24. IHT). r«*CMU« crtMcU
«):
I • Uc (Ml«, ••iccclwa, *^ nviicwMU •! UM to 114 VMM Oi«vM«l Act
•
C • t*a p«r*l*t**c«. t**icity, ••klllty, M^ pr*p«Mtcy t»
f*r
0 • M»rt» M
I • !••«•(•«§ Mi«t«uac«
r • (te p*CMti«l C*r
6 • tk* M»u*tiAl t»t««t t*
if tk* aluCM
M U «tt«tiM wc« U Uil
-------
EVALUATION CXITERU TO IE CONSIDERED FOR UHEDY
SELECTION AT THE CEC SITE. MIDGE WATER, HASSACHUSETTS
AITUNATIVE ltt-6: PUtf AND THAT BY AlR-STRIPPtNC AMD ACTIVATED CARBON
C1ITWIA
1. Coajliaoce with ARARa
a Caataaiaaat-apeeific ARAfts
• Ucatioe-apeciflc ARAJts*
a Actloa-tpeciflc ARARa
2. Reductioa af Toeicitg. Mobility, or Volieae
a Treatawat process aaplofwd, aad type
at af aatarlala to be treated
a Deftee of acpected reductioa ia tocicity,
•obility, or voluaw; is it penaaaeat
or sisalficaatT*
a Fate of residuals reawiaiaf after
Achieve! ce«t«*ia«at-«eeciflc ARAt* ia (rovadwater over
• period of yean depeodiai M pua^iac iy«i«« *od
e>tr«ctio« efficieacy (tee lectio* 7.4 tad Table 7-21).
Truud irouadwatar acalrvei AUQC.
Coapliaac* vita facility iitia« aad wetlaada protectioa
re(ulatiaoa w««ild be. attaiaed; aa ataeaaaeet o( the
iapact of (rouadveter eitractioa oa tae vetlaad would
he ioae duriaf reaedtal desiga; foat-treatavat dlacaart*
«o«ld aet taatect vetlaaaa.
CeaylUaca caa Ve atLaiaad.
ivvteai coatrola coataaiiaaat aoaility.
Air-atripo 104 proceat itrtpa VOC« froa>
vater to4 txa*»(«ra vaatea to Lae ataoapaere, a bettar
aediua for rapid diUtioa. ociaatioc,, aad
paotod«|ralatioa. activated carboa proceaa traaafer*
or|aaic coaatitueata I tarn voter to tae aurface of ta«
activated carboa. Tbe diapoaablc carboa uait vould be •
laadfilled off-aita vkca aaturatad.
Oeatmctioa of coaLaaiaaata ia tae «ta«apaer« would be
capid aad peraaaeat. Rcductioa ia coataauaaat anbility
aad voluac achieved tarougfe carboa treatacat.
Crauadwatar piaapiac coatrola aoaillty of coataaUaaata.
Treated (rouadwatar wwld ac&ievc iWQC level a aad
would be diacharfed ta taa vooded «VMK> weat of the
cquipacat buildia^. Diapoaable carboa uaita replaced
vbea ta titrated aad laadfill off-aita.
J.
of
e Short-terai ritkt to coaswaity. workers, - (.
aad the cavirooateat duriag taaleaeatatioa '
a Coea>liaace with criteria, advisories,
aad
until protcetioa io achieved
4.
of rvsidiul rUk*'itCt°
Target riak levels aad BCLa attaiaed over a period of
years larow|h |ro«advater piaapiat- Redactioa ia
e>iatia« rtaka differs vita piaapio^ aceaario, but would
aot be attaiaed far aeveral year* (aee Sectioa 7.4 aad
Table 7-Z1). Treated s,ro«a4uater would achieve AWQC
1evela.
Piavpiac wells aad tae treatavat aait poae aiaiaal riaka
to coaauaity, workers, aad eaviroaacat duriac
iastallatioa aad oaeratioa.
NCLs aad tareeC risk levels Mould be attaiaed over a
period of years (aee Sectioa 7.4 aad Table 7-21)
through piawDiat. Treated (rouadvater would achieve
AWQC levels.
Crouadvster acpected to achieve NCLs aad to * riah level
ia J.7 to 64 years depeediat oa puaniae, aceaario aad
Mtractloa efficieacy (aee Scctioa 7.4 aad Table
7-21). Treated (rouadwater would ieatedlately achieve
AWQC levala.
Residual risks decreaaa with tla* throu|h (rouadwatac
aad treatawat.
-------
aiTUIA
Uat-tom rtlUkillty •(
M« uwcititti*Ml caatralt ' ' *
a NtaatUl far fatacv Maaaum u
a* aavlraaaaatol racaatara'
• HtoatUl
<*c ra*
• Ability to caaatcact
• Sa*rt-tora reliability •(
UfT
• Ability to aaaitor •fftctivaaraa •(
u BarCaca •aaratlaa a*«
Ability to Mteruk* *441ti«Ml
l MtiMM. if
• AkIUty to
U
•a*
*T
• Cayiul CMU
• OpwaUwt Mtf ••.
if
crutanc
U ntr*et
••4 tr««t
veil
f«rl*4ic tc««
•fftcti
(roa
**
t« t
P«t«n t^Miin to trtato4 Mtor ky
••likely. Uait*4 f«tor« iayccu to
nuyton «Uoa 4UclMrt« w«14 «cuu AMQC limu.
raetf tort
Nrl*4ic
Mil
*r
»e
M»y to
c«li«bU
Wall
la UM
•ff«ctl««ly M»iuc* tlto e**41tl
«^IlM «f C
•ff«cti«
•••ic
if
to ••tr*cc mum
U
(M4UUM1
itorU« 4«u
4 imwtfMto
tCMUMMt
-------
page 27(aa)
(coatiaued)
atrrexiA
ASSESSMENT
Preaeot worth aaelyaia
• Poteafial future remedial «etie
catU
•reseat worth varies depeadiae, oa piaapiac syateM,
puapiag tiae, aed eitractiea efficieacy (aee T»bl«
7-J9). For preliauaary •atueate, pceaeat worth to
achieve 10** risk uaiae, Hultiple Utractioa Well Syatoai
with SO perceet utrictio« efflcieacy i« •pproki««tely
$2,140,000. U tern* of pr««c«t worth foe •quivcleat
pu^io4 tiait, IW-6 h«i • ki|het prtciat worth Uua
(ft-1 tod Mt-4. Siacc both Itt-I ud lflt-4 would
efflucat AUQC 1U1U, ltt-4 would Mt »t • wrc
coif«£fectiv« trtaUMt
Potcotiol futon reMidltl «ctloa cost* iivolv*
ccpeatei to eipoad "puap «od trttt" tyitea or replace
or redesign coo^lacd trctUKat oait.
TV««e evaltutloo. criteria to be u»ed U the reewdy Mlectioe, proceso were adapted fro* UA 08VZI Directive
Ho. «1S&.0-21. •Uditiooal loteriai Cuidaece for FT'17 Iccorda af Deciaioe," (July 2t, 1M7). rootaated
«d*d, Sectioaa UUb)(l)(A ^Hf^"t^ G):
•OTI:
criteria correapoatd te- the follow 104 ttat«tory (actora 10 CUCIA, aa
A - t*<« la£c-'«r» ae>c«rcaietiee aaaociated with laad diapeeel
• * the (oala, abjective*, aed rrquirea^ati af the Solid Waata Oitpoaal Act
C • the periiateace, toxicity, eobility, aatf propeaaity to bioaccuaulate of the hacardoua auhataoceo aad their
coeatitueeta
0 * •hart- aad loaftera poteatial for adverae health effecta freai buetaa eipoauce
C • leaf-ten aaiaLeaaace coat a
f * the poteatial for future reawdial actioa coots if the alternative rcawdial actioa U questioa were to fail
C * the poteatial threat te
rediapoaal, or coataiaaieat
health aad the eaTiroejaeat aaaociated with eicavatiaa, traasportatioa, aad
-------
ROD DECISION SUMMARY . page 28
Cannons Engineering Corporation Site
VI. SELECTED REMEDY
A. Description of the Selected Remedy
The remedial action selected for implementation at the Cannons
Engineering Corporation 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 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 approach for site
remediation which includes a source control and a management of
migration component. A comprehensive approach is necessary in
order to achieve the response objectives established for site
remediation and the governing legal requirements.
1. Scope of the Selected Remedy
The selected remedy was developed by combining components of
different source control alternatives (SOI, SC-3, SC-5) and a
management of migration alternative (MM-1) to obtain a
comprehensive approach for site remediation. In summary, the
remedy provides fencing the area to restrict access to soils,
treating certain contaminated soils on site by thermal aeration
and treating PCB contaminated soils off site by incineration, and
installing a groundwater monitoring system. In addition,
buildings and tanks on site would be removed and soils under
those structures, along with other soil locations, would be
sampled. Any contaminated soils requiring treatment based on a
threat to human health and the environment will be treated by one
of the selected soil treatment technologies.
Fencing:
The first part of the selected remedy would be to restrict
access to the site. A chain link fence will be constructed
around the perimeter of the site. Warning signs will be posted
at 100 foot intervals along the fence and at the entrance gate.
The current locks on the building will be inspected to insure
their integrity and any locks in deteriorating condition will be
replaced. Plywood will be used to board up any windows that are
currently broken or open.
Decontamination and Removal of Buildings and Associated
Structuresi
Several buildings, tanks and structures will be decontaminated
and removed from the site. The Tank Farm Building and Ready
Building will be removed to allow access for sampling the soils
-------
ROD DECISION SUMMARY page 29
Cannons Engineering Corporation Site
beneath the buildings to assure the absence of contaminated soils
beneath them which might act as a source of groundwater
contamination. Additionally, the incinerator, above ground tanks
and underground tanks will be decontaminated and removed to
comply with ARARs.
Sampling;
Following or concurrent with the building and structure removal,
a sampling program will be implemented to further characterize
the nature and distribution of the contamination present in the
soil. This sampling program will be conducted during the
Remedial Design stage to determine the presence of contamination
in discrete locations of the site that were not fully
characterized during the Remedial Investigation, to investigate
the presence of contamination under site structures, and to
further delineate the extent and distribution of PCS
contamination.
Soil Treatment:
This source control component comprises the majority of the
selected remedy. It consists of excavating the VOC contaminated
soil and treatment on-site in a thermal soil aeration facility,
and excavation of PCB contaminated soils and treatment at an off-
site incineration facility.
VOC contaminated soil will be excavated from the wet area and
treated on site by thermal aeration. The wet area is a discrete
area of contamination located in the southern portion of the •
site. This area is surrounded by a berm to the south and the
upland area to the north with the water table near the surface of
the soil. The majority of the wet area is proposed for
remediation based on sampling data, site topography, and
contaminant transport considerations.
PCB contaminated soil will be excavated from a discrete portion
of the wet area and a discrete portion of the upland area. These
soils will be treated off site by incineration.
Additionally, any soil that is identified during the previously
mentioned sampling program and determined to need remediation,
based on potential risks posed to public health or the
environment, will be treated by one of the above mentioned soil
treatment technologies.
Management of Migration;
The management of migration portion of the selected remedy
involves restricting the use of groundwater at the site,
-------
ROD DECISION SUMMARY r_je 30
Cannons Engineering Corporation Site
installing new monitoring veils, and implementing a formal water
quality monitoring program to observe the presence, distribution
and migration of contaminants. Removal and treatment of
contaminated soils will eliminate sources of further groundwater
contamination. Remediation of the low levels of contamination
found in the groundwater will occur naturally over time.
B. Documentation of the Selected Remedy
1. Source Control
The source control portion of the remedial action is designed
primarily to address the soil contamination and to look for and
further characterize soil in which contamination remains at or
near the areas where it was originally deposited and is not
adequately contained to prevent migration into the environment.
The purpose of the source control remedy is to prevent potential
direct human contact with contaminated soil at the site and to
prevent or minimize movement of contamination from the soil to
the groundwater. Contaminated buildings and structures are also
considered under the source control alternative.
a. Contaminated Media
The contaminated media to be addressed under the source control
portion of remedial action are the contaminated soils in the wet
area, contaminated soils in the upland portion of the site, and
the buildings, tanks and other associated structures on site.
b. Soil Target Cleanup Levels
The approach to remediating contaminated soils in the wet area is
based on direct contact risks and risks associated with
contaminants leaching to the groundwater. The volume of
contaminated soil to be treated is dependent upon cleanup levels
set for particular indicator compounds that were developed
considering such risks in conjunction with the sampling results.
For site soils, two approaches were taken to assure protection of
human health and the environment:
Direct Contact - The first approach used to develop soil
target levels considered direct contact with site soils and
calculated target levels based on this exposure.
Leaching to Groundwater - The second approach used to
develop soil target levels evaluated the leaching of
contaminants from site soils into groundwater. This
involved calculations of concentrations in site soils
required to achieve groundwater target levels.
-------
ROD DECISION SUMMARY page 31
Cannons Engineering Corporation Site
As described above, the cleanup level for VOCs is based on the
risks associated with the direct contact with the soil and
leaching of contaminants from the soils to the groundwater. The
approach to developing a list of groundwater contaminant levels
from which to derive soil cleanup levels was to utilize
regulatory criteria for individual contaminants. The agency has
determined that Maximum Contaminant Levels (MCLs) are the
relevant and appropriate regulatory criterion to use for this
site. The following six compounds with MCLs were detected in the
on site soils samples: chloroform, benzene, trichloroethylene,
1,1,1-trichloroethane, vinyl chloride, and 1,2-dichloroethane.
However, chloroform, 1,1,1-trichloroethane, and 1,2-
dichloroethane have not to date been found in the groundwater and
therefore are not expected to warrant cleanup in the soil.
To determine cleanup levels based on preventing further
groundwater deterioration at the site due to contaminant leaching
from soil to groundwater, the Organic Leaching Model (OLM) was
used. This model is an empirically determined expression
relating concentrations of contaminants in leachate to their
respective concentrations in a soil matrix. A full description
of the modeling approach taken to estimate movement of pollutants
is presented in Appendix B of the Feasibility Study, and a
discussion describing the selection of contaminants and cleanup
levels is in the Technical Memorandum entitled Development of
Soil Cleanup Levels for Cannons Engineering Corporation (CEC)
Site in Bridgewater, Massachusetts (March 1988). Based on the
results of the application of the OLM, the following cleanup
levels for contaminants in soils in the wet area were determined.
A sampling program will be implemented to determine the extent of
soil excavation to attain the following cleanup levels.
Contaminant Wet Area Soil Cleanup Level
BENZENE 55 ppb
TRICHLOROETHYLENE 71 ppb
VINYL CHLORIDE 11 ppb
Alternatively, the sample data from the wet area is sufficient to
determine the need for cleanup. It is expected that the
distribution of VOCs is widespread throughout the wet area as a
result of their mobility and solubility in soil and water
systems. The data indicates that the contamination in the wet
area is restricted to the west of the pond at a depth of
approximately two feet. Surface topography indicates that the
surface water runoff should flow westward from points
approximately twenty feet from the pond. Consequently, based on
sampling data, site topography, and contaminant transport
consideration, along with the difficulties associated with
excavating discrete locations of the wet area, the entire wet
-------
ROD DECISION SUMMARY page 32
Cannons Engineering Corporation Site
area from approximately twenty feet west of the pond will be
excavated to a depth of two feet. Following excavation, sampling
will be done to insure protection of human health and the
environment.
The cleanup level for PCBs (polychlorinated biphenyls) is based
on a direct contact threat and not a threat of leaching to
groundwater. Due to the chemical nature of the PCB compound,
they are very immobile in soil and do not migrate in groundwater.
Therefore, it was concluded that the PCBs do not pose a threat to
groundwater. This conclusion is supported by site data which
showed no PCB contamination in the groundwater. Therefore, based
on the risks associated with direct contact to soil, PCB
contaminated soil at a level of 9 parts per million (ppm) or
greater anywhere on the site will be excavated. Because the
volume of PCB contaminated soil is expected to be small, it will
be treated off site by incineration. Excavation of soil to this
level and treatment by incineration will significantly reduce the
risks associated with the site to a level which is protective to
human health and the environment. Off-site treatment of the PCB-
contaminated soils by incineration will provide a permanent
remedy favored under Section 121(b) of CERCLA. Because PAH
compounds are found coextensively with PCBs in the soils,
excavation and off-site incineration of the PCB contaminated
soils will also reduce the threat posed by the compounds at the
site. Prior to excavation of PCB contaminated soil, a sampling
program may be implemented to further delineate the exact extent
of PCB contamination in the vicinity of soil sample locations F-6
and B-2.
c. Additional Soil Sampling
There are several locations on site in which there is not enough
data concerning the level and distribution of contamination.
Therefore, samples will be collected in the vicinity of the
following locations.
Stained soils and surface soil sample data indicate that spills
may have occurred in the western portion of the site.
Additionally, a zone of subsurface contamination may lie in the
western part of the site. Potential sources of subsurface
contamination are the surface spills, septic system, and
underground tank north of the ready building.
It is possible that waste samples and laboratory reagents may
have been routinely disposed in the laboratory sink, and
ultimately in the septic tank located to the west of the
Equipment Building. Groundwater in MW-8, located about 75 feet
southwest of the septic tank and about 50 feet west of the
underground storage tank, showed levels of contamination in all
-------
ROD DECISION SUMMARY ' page 33
Cannons Engineering Corporation Site
sampling events. Based on the inferred groundwater flow
directions, it is most likely that either the septic system or
the underground tank is the source of contaminants observed in
MW-8.
During the Remedial Investigation, an area of stained soil in
the wooded swamp west of the ready building was documented
(SS-5). Fate and Transport calculations conducted in Section 3
of the Feasibility Study indicate that locations SS-5 and SS-ll
in the western portion of the site pose a potential threat to
groundwater.
Other locations other than the western portion of the site may
require remediation due to contamination. These area are: the
northeastern corner of the site where tanks were discarded and
surface soil sample SS-8 showed contamination; east of the
equipment building where drum handling activities reportedly
occurred and debris is located; and the loading deck and drum
storage areas where waste transfer activities occurred.
An underground vault vith manhole cover is situated east of the
equipment building. Groundwater in the monitoring well
immediately downgradient of the vault (MW-2) contained a number
of VOCs during the last round of sampling. It is assumed that
the vault is the source of this contamination.
Also, to specifically address concerns raised by the National
Oceanic and Atmospheric Administration (NOAA), PCB samples will
be collected from the drainage canal southwest of the site.
These samples will be collected from depositional sites along the
drainage canal including the terminus of the canal adjacent to
the Hockomock Swamp.
During remedial design, a sampling program will be implemented
to better ascertain the distribution of surface and subsurface
soil contamination in all the above referenced areas.
Furthermore, additional soil samples will be collected in the
vicinity of any excavated tanks. Any soil that is identified
during the previously mentioned sampling program and determined
to need remediation, based on potential risks posed to human
health and the environment, will be treated by either on site
thermal aeration or off site incineration.
2. Management of Migration
As described previously, the groundwater contamination at the
site does not pose a significant risk to human health or the
environment because the analysis of the groundwater conditions
indicates that no contaminants migrate past the site boundaries
at levels above drinking water standards or any other criteria
-------
ROD DECISION SUMMARY page 34
Cannons Engineering Corporation Site
which are protective of human health or the environment.
Additionally, there is no current use of the groundvater within a
one aile radius of the site. Residences and commercial
facilities in the vicinity of the site are served by a municipal
water supply system.
The management of migration portion of the selected remedial
action involves restricting the use of groundwater at the site
and implementing a formal water quality monitoring program to
observe the distribution, migration and lessening of contaminants
as the cleanup levels are attained over time. The effects of
natural attentuation are expected to reduce contaminants in the
groundwater to cleanup target levels in fifteen to twenty years.
The following actions will be implemented under the selected
alternative for management of migration, in addition to
performing the selected source control action:
a. Groundwater Monitoring Network
The groundwater monitoring network to be implemented will be
designed during the remedial design phase of the remedial action.
The monitoring program will be designed to meet the intent of
RCRA groundwater monitoring requirements, and will be tailored to
site specific hydrogeologic conditions. Wells will be sampled on
a routine periodic basis to evaluate dispersion of the
contaminant plume and monitor contaminant concentrations in
groundwater.
Before design, the condition and usefulness of existing wells
will be checked and compared with future data needs. This
comprehensive monitoring well network will be designed to provide
sufficient information to evaluate dispersion of the contaminant
plume, and the distribution, if any, of contaminant migration
off-site.
The frequency of monitoring will be finalized during design;
however, it is expected that during the first two years of
monitoring the wells will be sampled and analyzed on a quarterly
basis to improve the existing data base and establish initial
contaminant concentrations. It is also expected that well
samples in years 3 through 10 will be collected once per year.
After year 10., well sampling will be conducted every other year.
Whenever monitoring well samples are collected, samples will also
be taken from the drainage canal upstream of the site, downstream
of the site, and near the site. These surface water and
sediment samples will assist in evaluating the contaminant
migration from on-site groundwater to the drainage canal and
quantifying the effect of site-related contaminants in off-site
surface water and sediments.
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ROD DECISION SUMMARY . page 35
Cannons Engineering Corporation Site
Initially, all samples will be analyzed for VOCs, SVOCs, PCBs,
and metals. Specific parameters may be added or deleted
depending on sampling results and observed trends. The duration
of monitoring activities will also be assessed after several
years of groundwater data collection. The modeling is
conservative and does not consider chemical degradation,
hydrolysis, biological degradation, and other attenuation
phenomena have not been considered in modeling; therefore the
potential exists for selected contaminants to be below predicted
concentrations or below detection limits in less time than
predicted by modeling.
b. Groundwater Target Cleanup Levels
The evaluation of groundwater target cleanup levels focused on
the current level of groundwater contamination at the site, the
groundwater use, and the time required to achieved remediation
goals. The Superfund Public Health Evaluation Manual and EPA's
Groundwater Protection Strategy aided in the development of
groundwater remediation target levels. The groundwater's current
and potential use influences groundwater cleanup levels and the
time of restoration. The use and application of the Superfund
Public Health Evaluation Manual to site clean up is discussed in
detail in the Endangerment Assessment, and a detailed evaluation
of EPA's groundwater protection strategy as it applies to this
site is given in Section 7.3 of the Feasibility Study.
Based on contaminants found in groundwater during Site studies,
and as discussed further in the discussion of ARARs, the
following contaminants and their respective MCLs were identified
as appropriate groundwater cleanup targets to achieve:
Contaminant MCL
BENZENE 5 ppb
TRICHLOROETHYLENE 5 ppb
VINYL CHLORIDE 2 ppb
The preceding compounds were selected because they were the only
compounds which were ever documented to exceed their respective
MCL. The analysis indicates that lifetime risk from ingesting
drinking water at these target cleanup levels for Benzene and
Trichloroethylene is approximately 6 x 10~6. The estimated
lifetime residual risk posed by ingestion of Vinyl Chloride in
groundwater at the MCL is approximately 1.3 x 10~4. However,
this contaminant does not appear to pose a significant risk at
the Site because it has been detected in only one sampling round
in one well. However, it is considered protective to monitor for
this compound. The target cleanup levels for the site will be
achieved in groundwater throughout site. The monitoring network
-------
ROD DECISION SUMMARY . page 36
Cannons Engineering Corporation Site
to be implemented under this remedy will observe levels of these
contaminants over time to ensure levels of contamination decrease
through natural attentuation to target levels.
In summary, the groundvater contamination at the site does not
pose a significant risk to human health or the environment
because analysis of the groundwater conditions indicates that no
contaminants migrate past the site boundaries at levels above
drinking water standards (MCL's) or any other criteria which are
designed to be protective of human health or the environment.
Moreover, the low levels of contamination presently found in
groundwater at the Site are expected to decrease over time to
meet the cleanup targets so that the groundwater will meet
drinking water standards.
In determining the appropriate rate of restoration for achieving
groundwater cleanup target levels, a number of factors were
considered. The first consideration was whether the groundwater
remediation is presently necessary in order to protect human
health or welfare or the environment. Site studies indicate that
there is no current use of the groundwater within a one mile
radius of the site. Residences and commercial facilities in the
vicinity of the site are served by a municipal water supply
system. In addition, the Site is presently used for industrial
purposes and the groundwater at the Site is not expected to be
used for drinking water in the foreseeable future. Finally, as
already mentioned, groundwater at the site is not impacting the
quality of surface water as the groundwater discharges to the
surface. A second consideration was the length of time required
for natural attentuation to reduce contaminant levels in
groundwater to reach the target cleanup levels. Studies indicate
that based on the observed contaminant distribution and fate and
transport considerations, that the maximum timeframe expected to
achieve the above MCLs as the result of natural attenuation is
about 15 to 20 years. The necessity, if any, for future actions
will also be assessed during this time.
Therefore, the Agency has concluded that the groundwater remedy
will be attained and that MCLs will be acheived over time as the
result of natural attentuation. Given the present uses and
availability of public water supplies, and the expectation that
the aquifer can be restored by natural attentuation to drinking
water quality, a restoration period of 15-20 years is
acceptable. A faster rate of restoration to reach groundwater
cleanup target levels based on ingestion of on-site groundwater
is not warranted.
Institutional controls (e.g., deed and land restrictions) will
be required legal instruments as part of the remedial action to
prevent the use of on-site groundwater for all water use purposes
-------
ROD DECISION SUMMARY • page 37
Cannons Engineering Corporation Site
and to protect human health. Institutional controls will also
alert future property owners to potential site-related risks.
Education programs including public meetings and presentations
will be undertaken to increase public awareness.
C. Statutory Determination
Section 121(a) of the Comprehensive Environmental Response,
Compensation and Liability Act (CERCLA), as amended by the
Superfund Amendments and Reauthorization Act (SARA), requires EPA
to select appropriate remedial actions determined to be
necessary to be carried out under Section 104 or secured under
Section 106 which are in accordance with Section 121 and, to the
extent practicable, the National Contingency Plan (NCP), and
which provide for cost-effective response. The selected remedy
presented herein is consistent with the requirements of CERCLA
and to the extent practicable the 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. Section 121(b)
of CERCLA requires that remedial actions in which treatment which
permanently and significantly reduces the volume, toxicity or
mobility of the hazardous substances, pollutants and
contaminants is a principal element, are to be preferred over
remedial actions not involving such treatment. The statute also
requires EPA to select a remedial action that is protective of
human health and the environment, that is cost-effective and
that utilizes permanent solutions and alternative treatment
technologies or resource recovery technologies to the maximum
extent practicable. The Agency may select an alternative
remedial action meeting the objectives whether or not such
action has been achieved in practice at any other facility or
site that has similar characteristics.
Further, Section 121(d) of CERCLA provides that EPA's remedial
action, when complete, must comply with applicable or relevant
and appropriate environmental standards established under federal
and state environmental laws.
1. Protectiveness
The remedy at this site will permanently reduce the risks
presently posed to human health and the environment by
contaminated soils and will ensure that any increase in risk
posed by contaminated groundwater and surface water is detected
for further remedial considerations.
The soil cleanup levels to be attained by this remedy will reduce
the risks associated with the soils to a level protective of
-------
ROD DECISION SUMMARY page 38
Cannons Engineering Corporation Site
human health and the environment. The target cleanup levels
address the risks from direct contact to contaminated soils. In
addition, the cleanup levels for vocs in soils were developed to
prevent the leaching of contaminants from soils into the
groundwater at concentrations in excess of MCLs under the site.
The Feasibility Study and Endangerment Assessment discussed
three compounds identified as contaminants of concern for direct
contact: PCBs, PAHs, and Benzene. The proposed cleanup
(excavation and treatment of the majority of the soils in the vet
area and excavation of soils with PCBs exceeding 9 ppm) will
reduce the risks associated with all three compounds to a level
protective of human health and the environment.
The groundwater target cleanup levels established for the site
are the MCLs for Benzene, Trichloroethylene, and Vinyl Chloride.
The Agency has determined for this site that the attainment of
MCLs at the site in groundwater is protective of human health
and the environment. The remedy for this site utilizes the
action of natural attenuation over time to reach the groundwater
target levels. This remedial approach is protective because the
groundwater is not currently used and is not expected to be used
in the future for drinking purposes and is not threatening to
increase contamination of surface waters. Therefore, the length
of time necessary to restore the groundwater is not a crucial
factor in protecting human health and the environment.
2. Consistency with Other Laws
This remedy will meet or attain all applicable or relevant and
appropriate federal and state requirements that apply to the
site. Environmental laws which are applicable or relevant and
appropriate to the selected remedial action at the Cannons
Engineering corporation Site are:
Resource Conservation and Recovery Act (RCRA)
Toxic Substances Control Act (TSCA)
Clean Water Act (CWA)
Safe Drinking Water Act
Executive Order 11988 (Floodplain Management)
Executive Order 11990 (Protection of Wetlands)
Clean Air Act (CAA)
Occupational Safety and Health Administration (OSHA)
State Superfund Law M.G.L. c 21E, as amended in 1986
Table VI-1 and Table VI-2, taken from Chapter 2 of the
Feasibility Study, list the chemical specific and location
specific ARARs, respectively, and outline the action which will
-------
TABLE VI -1
MB ctitniA, MVIMBIU, AD our
oc tin.
•Muntptar tnonn
u/ri
Cr
tar
Tadaral ftatulatary
• lanlnaiata
Stata Bagnlatary
toqulrwMala
•taa4ar4a
Fa«aral Critaria
Atfvlaariaa, a***
0«l4aa*a
Laval* (BOa) (40 Cfl
141.11 • 141. U)
DCQK • MaMaefcnaatt*
Cratia4watar Quality
•taadarto (314 Ott ft.00)
KQt • DtiakiM »*•*«»
Si«m4ar4« O10 CM U.M)
IfA Bisk
Wattt
Quality Crttarla
(AUQC) • A4J«at«4 far
Water
t4«r«4 r*l*va*t aa4 ap* r«f riat* far
r a«jMifar« p«t«*t tally Ha«4
far ArlajklMf «at«r.
lu*« »•«• proawl»ata4 far a Ma^ar at
ce«taml«««ta . «ba« tka atat* la«ala arc
man itrla*ut UkM fadaral lavala, Lka
•tat« l*v«la will •• a*a4.
HaaaadMaatu a4a»ta4 Kta aa ita 4rlakU«
watar ata»oar4a. Lika HCLa, tkaaa Irwala
raaj»lat« ta« c«*c«atratia« af caataaitaaat
la p«kllc
•fD» an
IT* far
af gra«aAMt«r war* aaaaaaaara4 ta tkalr HCLa. MCta wata
ta a«t claaai-ia> lavala far tfcaaa caa>taaiaaat*.
IBQI CtMtaAMtar Ilia«n4a far Ira* aa4
•ara «a«4 «*•• 4at«tmiala« claaa->* lavala. aUca
ataa4ar4a far tWa« caataala«ata ara a*ra
fa4aral ataa4ar4a.
•laca BtVQi 4riakia« vatar ataa4ar4a ar« tka s
aa BCta, BMa«la>it*4 Kta wara aa«4 ta aat cla
lavala far caait aailaaata af c«a«ar*
carciawgaaic affacta.
WA RfBa vara «a«4 ta ckaractartaa riaka 4a« ta
akyoa«ra ta caa>taa)i»a«ta la (ravMiMtar, aa wall
aa atfcar a«41a. Tfcry wara ca«al4ara4 far
•ataylaaai cklarl«e aa4 tatrackiaraatkylaM.
Fa4aral AMQC ara k«alt»-a*»a4 crttarla
ha«* k«a« a>*«laa«4 far M car-
ra na«4 ta cfe«ractarisa
haaltfc riaka 4wa t» ca*taMi«aM ca«-
raatratiaaM is 4rlakla« watar. TWy
wara caa«i«ara4 far klad-aUylkavyl)
*4 avtkylawa cklari4a.
-------
J9.••« t*t«l C*llt*ra vlll
it. »t••<•!•< «• *M ralat IM
te flT
U *•>!•«• «*l«i
cciutto
IM n kMlU
t«
** «f
tic
•ill k* •••< l»t
«•
-------
page 39(c)
TABLE VI-1 (
MM ** cumu.
ac srn.
•ignitf HUTT
u m
eu-National Ambient Air
Quality Standards (NAAQS)
40 CFR 50
OUR • Air CjMlity. Air
NlUtUa (310 CHI ft.OO -
•.00).
CrlMrU,
MrtM, M4 (UVi)
Ltett ?•
f*c
•«••»
c«U f*c M
TVN
f«r *•
C Mil
•§•«•>!•••.
-------
page 40(a)
TABLE VI-2
utt.
US Army Corps of Engineers
Nationwide Permit Program
33 CFR 330
AM |M ••••«
(*• CM M4.il)
()!• OB t*.M)
I.M)
%• to |M IMM)
. M MtiHtf
f UfwM • mini *M>II to
MttMt tl • fCMtiMM* •!
hM UM BltM* ft*
t BKV^K*^,
•f flMU BB
it viUj UM
VtUIif* tonl«M. Thta
•*
Md
If MB •!
* tte •.•. Vtak M« Ml«-
i^ • KM fMftlttf ••
•*«•««• M
It »
If
M »*tl«tU« BMAM •«
W t*U4 MUt UM •«. If
•!•• tefiMa ttl«4.
•I UM Mt
•f • «• fMiUty M
*
•f
•1
•U
UM yt
-------
page 40 (b)
TABLE VI-2 (c~tt»~4)
LOCATlCB-tflClflC MAU MB CUtniA. MXHtOUU.
oc
•in
DOT tnonit
amimuavm m m n/n
Or««r 0» 1UU)
ttet
ftcUl
*a «f ••
•f
•t«f«f* taalM will
fin >i»»««ttm
•Mt W
-------
ROD DECISION SUMMARY . page 41
Cannons Engineering Corporation Site
be taken to attain the ARAR. Table VI-3 and VI-4 indicates the
action specific ARARs, presents a brief synopsis of the
requirement, and outlines the action which will be taken to
attain the ARAR. A brief narrative summary of the ARARs follows.
The remedial action will involve the construction of a facility
to excavate contaminated soils, drum the PCB contaminated soils
for transport and disposal, and prepare the site for low
temperature thermal stripping. The facility will be
constructed, operated, and maintained according to RCRA facility
standards and OSHA requirements. ARARs for low-temperature
thermal stripping of the VOC contaminated soils include
controlling the air emissions from the thermal stripping unit to
comply with CAA and OSHA requirements. The drummed PCB
contaminated soils will be transported to an off-site incinerator
which is in compliance with the EPA's off site policy. The drums
and transportation vehicles will be properly labeled in
accordance with TSCA and will be done in a manner in compliance
with DOT rules for transportation of hazardous materials.
RCRA requirements will be met by implementing this alternative
because the tanks, storage areas, and incinerator will be
decontaminated. The Massachusetts Hazardous Waste Regulations
are consistent with RCRA so that compliance with RCRA will result
in compliance with Massachusetts regulations. The Massachusetts
Fire Prevention Regulations will apply to the handling and
removal of the underground storage tank.
Because these activities are taking place in a wetland, the CWA
Section 404 and the Massachusetts Wetlands Protection Act are
ARARs. The Wetlands and Floodplains Executive Orders must also
be considered. The CWA and wetland protection regulations and
policies are an ARAR because the remedy will result in the
disturbance and temporary loss of areas classified as wetlands.
The unavoidable impacts to these resource areas will be mitigated
to the maximum extent possible and following such activities, a
wetland restoration program will be implemented.
Incineration of the contaminated soil will be conducted
consistent with EPA's off site policy.
Massachusetts' air pollution control regulations are ARARs in
regulating particulate air emissions from construction and
excavation activities. Additionally, the Massachusetts draft
Allowable Ambient Levels (AALs) will be considered.
RCRA requirements that are applicable or relevant and appropriate
to the decontamination and dismantling of existing tank storage
and incinerator facilities will be met by this alternative.
-------
ACTION-SPECIFIC ARARS FOR ALTF.RMATIVE SC-S:
ON-SITE THERMAL AF.RAT1ON OF VOC UASTES/OFT-StTE INCINERATION OF PCS AMD PAH WASTES
CEC SITE. BRIOCEWATF.R, MASSACHUSETTS
ARARS
:CRA - Standards for Owner* and OprrJtort e
.( Permitted Hazardous Waste Facilities
:40 CFR 264.10-264.IS)*
RCRA - Preparedness and Prevention
(40 CFR 264.30-264.3I)1
RCRA - Contingency Plan and Emergency
Procedure* (40 CFR 264.SO-264.S6)1
RCRA - Manifesting, Recordker.ping, and
Reporting (40 CFR 264.70-264.;;)*
RCRA - Croundwater Protection (40 CFR
264.90-264.
RCRA - Location Standards (40 CFR
164.11)*
RCRA - Closure and Post-closure (40
CFR 264.110-264.120)'
RCRA - 40 CFR 268 EPA Regulations
Land Disposal Restrictions'
RCRA-Interim Statu*
Standards - Closure of
Tank* and Incinerator
(40 26S.I97 and 26S.3SI)1
REQUIRRMENT SYNOPSIS
ACTION TO BE TAKF.N TO ATTAIN ARARS
General f.itility requirements outline
general waste analysis, security measures,
inspection*, And training requirements.
This regulation outlines requirement* for
safety equipment and spilt control.
This regulation outlines the requirements
far emergency procedures to be used following
explosions, fires, etc.
Thi* regulation specifies the recordkeeping
and reporting requirements for RCRA
facilities.
This regulation details the requirement*
for a grounduater monitoring program to
be installed at the site.
Thi* regulation outlines the requirement*
for constructing a RCRA facility on •
100-year floodplain.
This regulation details the specific
requirements for closure and post-
of hazardous waste facilities.
o This regulation outlines land disposal
requirements and restrictions for hazardous
wastes.
These regulations detail requirement* for
closure of the CEC site a* an interim status
facility, sperifically, for the tank* and
the incinerator.
During all cite work, a watte analysis plan must he written
and maintained mi-site. Entry to site must be prevented by a
24-hour surveillance system and appropriate signs posted. A .
written inspection program must be developed, and jtl worker*
properly trained.
Safety and communication equipment will be Installed at the site;
local authorities will be familiarised with the site, and drums
will he stacked and stored to maintain required aisle space.
.Plans will he developed and implemented during remedial design.
Copies of the plan* will be kept on-site.
Records of facility activities will be naiatained during
remedial action.
A groundwater monitoring program will be designed, installed, and
operated to assess groundwater contaminant migration.
A fa.c|tity located on • 100-year Haodplain must be designed,
constructed, operated, and maintained to prevent washout of any
hazardous waste by • 100-year flood( unless waste may be removed
safely before floodwater can reach the facility or no advene
effects on human health and the environment would result if
washout occurred.
Since there will be substantial remfval of waste; residual
contamination will have low mobility and toxiclty; pathway*
of potential exposure will he limited; and long-term monitoring
will he provided, this alternative will meet proposed alternate
closure. A notation on the deed to the property must be
recorded that will notify any potential purchaser that the (and
has bren used tn manage hazardous waste.
Contaminated soils will he treated J.o the lest Demonstrated
Avail.iMe Technology level* before being placed or replaced
on thf Ian I. Hazardous watte cannot be atored except for
an imulat ion for recovery, treatment, or disposal. Thermal
arration and incineration will meet treatment standard*.
All hazardous waste and hazardous waste rceidue* must be removed
from the tanks, discharge control equipment, and discharge con-
finement structures. All hazardous waite and hazardous waste
residues must he removed from the incinerator. These regulations
are applicable to the closure of the CCC site a* an interim status
facility. '
-------
TAttLt. VI-
ACTION-SPECIFIC ARAM ron
ON-SITE THERMAL AERATION Of VOC HASTES/OFF-SITE
CEC SITE. RRIDGEMATER.
ALTERfl^fe
t iNCnHFr
HASSACNOser
page
*t-S:
ION or
;m
Kl AM PAN WASTES
_RCQUIRFJCNT SYNOPSIS
ACTION TDK TAREN TO An A IN AHARS
. • Narking of rtii and PCS Item*
CP* 1*1.40-101.19)'
- storage •««
(40 cm
A - Record* and Revert* (40 CFR
.ll-rtl.ISS)1
o SO pom PCI atoraeje area*. *t«rage Items,
and transport equipment muat he marked
with the N, mark.
o Thi* requirement specific* the require-
ment* for aterage an<
of PCt item* in e*cess of SO ppm.
o Thi* regulation outlines the require-
ment* for recordkeeping for storage *i
•M
PCt it«M.
All *tor4(i* «rrjn
jpprofri*te •j
ilriiM, and transport e«j«if«enl will carry the
4i*play« lkeeping
and reporting refutations for an employer
under OSNA.
These regulations develop procedures for
the protection of archaeological resource*.
This regulation specifies that a he*I
management program (RHP) he develnped
to minimite pollutant release from the
facility.
Fugitive dust emission* will be controlled t* maintain PCI
concentration* below these level*.
All appropriate safety eoutpment will be on-site and appropriate
procedures will be followed during r*m*di*tion.
o This regulation will.be applicable t* the construction
company(s) contracted t* perform the decontamination
process on-sile.
o If archaeological retourco* are, encountered Airing soil
eicavatian. work will atom until the area ha* been reviewed by
feiteral and state archaeologist*.
n A RHP will he developed and will include •edimentalinn control
arnund the work *r«a. fugitive duct control, etc.
-------
ACTION-SPECIFIC ARAKS FOR ALTERNATIVE SC-5:
ON-SITE THERMAL AERATION OF VOC WASTES/OFF-SITE INCINERATION OF PC* AKD FAX WASTES
CEC SITE. RRIOCEWATER, MASSACHUSETTS
AJtARS
US Army Corps of Engineers
Nationwide Permit Program
33 CFR 330
Fish and Wildlife
Coordination Act (16 U.S.C
661)'
Floodplains Executive Order (MOSS)'
Wetlands Executive Order (11990)'
DEQE - Wetlands Protection (310 CHU
10.00)
DEQE - Air Quality Air Pollution
(310 CM* C.OO-t.OO)
REQUIREMENT SYNOPSIS
ACTION TO BE TAKEN TO ATTAIN ARARS
Thil regulation stales th»l no alternative
that impact! a wrtlainl shall be permitted
i( there is a practicable alternative
that has lest impact on the wetland.
l( there is no prarlitable alternative.
impacts mutt be mitigated.
Thil regulation requires that any federal
agency proposing to modify a body of
water mist consult with the U.S. Fish and
Wildlife Services. This requirement is
addressed under CWA Section 40*
requirements.
This rtt.ul.ition states that federal
agencies shall reduce the risk of flood
loss, mininite the impacts of floods oo
human safety, health, and welfare, and
restore ami preserve the natural and
beneficial values served by floodplaios.
This rrRul.ition states that federal agencies
shall minimize the destruction, loss, or
degradation of wetlands, and preserve and
enhance the natural and beneficial values, of
wetlands.
This requirement regulate! work within
100 feet of a wetland. This regulation
defines the wet area j* 4 wetland based
on vegetation types. Impacts to wetlands
must he mitigated.
This regulation specifies dust, odor,
•ad noise emissions fro* construction
activities.
Following excavation of contaminated soils, a wetl.ind will be
created in the wet srea ky placement of clean soil* (if
necessary). and graded to s 60-foot elevation followed by
revrgetation. The excavated portion of the wooded swamp
will be backfilled to original grade and revegetated.
Potential imparts associated with erosion, sedimentation, and
resuspenslon of sediments will be mitigated by closing the
ditth draining the wet are* by using hay bales, silt curtains,
or other erosion, resuspension, and sedimentation control
measures.
During the identification, screening, and evaluation of
alternatives, the effects on wetlands are evaluated. If an
alternative modifies a body of water, EPA must consult the
U.S. Fish and Wildlife Services.
Excavation of contaminated soils In the wooded swamp, and
possibly the wet area, may occur in the 100-year floodplain.
Wetland replacement of these areas will restore the floodplain
to its original sis*. Grading of the wet area to an elevation
of 60 feet following excavation and backfilling (if necessary)
will actually increase the site of the floodplain.
Following excavation of contaminated soils and completion of
remedial activities, • wetland will be created in the wet
area by placement of clean soil* (if necessary) and grading te
• 60-foot elevation followed by revegetation. The excavated
portion •( the wooded swamp will be backfilled to original
grade and rrvegetated. Potential impact* associated with
rrosion, sedimentation, and resuspension of sediments will be
mitigated by closing the ditch draining the wet area by using
hay bales, sili curtains, or other erosion, resuxprnsion,
and sedimentation control measures.
Any person who proposes to do work that will remove, fill,
dredge, or alter a wetland must flit s Notice of Intent. A
public hearing will bt Held anil the conservation commission
will make a decision and stay issue sn order of conditions.
A Notiie of Intent vvst demonstrate that the proposed work
will contribute to protection of the wetland.
Fugitive duct will ** controlled by water sprays or dust
suppressants. All equipment will bt maintained so as not to
produce excessive aolsc.
-------
ACTION-SPECIFIC ARARS FOR ^••NATIVE SC-S:
OM-SITE THERMAL AERATION OF VOC WASTES/OFF-SI t^PtlNERAT ION OF PCR AND PAN WASTES
CEC SITE. SRIDGEVATER. MASSACHUSETTS
ARARS
DEQC - Hazardous Waste.
(JIO CNR 10.00)
Phases I and II
Hazardous Wa«t* Facility Sit* Safety
Council (990 (Ml 1.00-U.OO)
DOT*Rules (*r tit* Transportation
• f Hazardous Materials (4* CFR
107. Ifl.l-IM.SOO)1
Massachusetts Fire
Prevention Regulations
CHR 9.00-Tankt)
RKQUIRtlglfT SYHOfSIS
Tfc««* r*(ul«tion( provide a ce«f rehentive
pr*a,raoi for handling, nlortfie. and
at h.»«»rrtou» waate titca.
Tnia r*|«lali*n outline* tn* procedwrra
for •atakliahina. a njtacdou* waatc facility
In Haaaach«a«tta.
H««t« rcgulationt specify the
vehicle reflctration. Manifest, and
tranapovtat ion reiuirenenta for hazardous
wast* cheoiicals.
This regulation applies to the .leii|n.
construction, installation. t*»tin«. and
staintcnance of tanks and containers, and is
intended to protect the public safety and
welfare.
ACTion TO 1C TAKEN TO ATTAIN ARARS
farina, remedial dealt*. the«e rc|ulations will he compared to the
corresponlini fcder*! RCRA rrfulatlons, anH the amr* strin«eitt
re*|uirea«nts will k* applicable.
A Notice of Intent Mist be filed with DCQC out«nin« the
propoaed location and My he used to Infor* the public of th*
facility.
Waste aNist he properly clasaified. packaged, oiaiilfested, awrk*4,
and labelled, and *M«t hawe refistratio*. niaaber* including the
Inters DOT.
This regulation applies is) reswdiaj action operations involving
tank <^ptyin«. cleaning, removal, dlsoiautling, and disposal
procedures.
Massachusetts Superfund Law
(HGL Chapter 2 IE)
1. Applicable
2. Relevant and Appropriate
3. Tto be Considered
-------
puye
ARABS
ACTION-SPECIFIC ARAKS FOR ALTERATIVE m-l:
niNIHAL MO-ACTION
CtC SITE. BRIDCKWATER. MASSACHUSETTS
REQUIREMENT SYNOPSIS
ACTION TO BE TAKE* TO ATTAIK ARABS
o RCRA - Standards for Owner* and
Operator* o( Permitted Haiardous Vaate
Facilities (40 CFR 26*. 10-264. !•)»
o RCRA - Preparedness and Prevent-
ion («0 CrR 264.30 - 264.17)*
o RCRA - Contingency Plan and
Emergency Procedure* (40 CFR
264.50 - 244.56)*
o RCRA • Manifesting. Recordkeeping, and
Reporting (40 CFR 264.10-264.71)'
o RCRA - Groundwaier Protection (40 CFR
264.90-264.10*)*
o General facility requirements outline general w.iste jn.tlysis.
••curity measures, inspection*, and training requirements.
o Thi» regulation outline* requirement* for *afety
equipment and npill control.
o This regulation outlinea the requirement* for
emergency procedure* to be used following
CMplosions, fires, etc.
• Thia regulation specifies the recordkeeping and reporting
requirement* for RCRA facilities.
o Thi« regulation detaila the requirement* for a grounilwater
monitoring program to be Installed at the cite.
o RCRA - Closure and Post-closure (40 CfR « Thi* regulation detaila the specific requirement* for closure
264.110-264.120)* end po«l-clo»ure of hazardous waste facilities.
o OSHA - Geoersl Industry Standards (29 e Thi* regulation specifies the (1-hour, time-weighted average
CFR 1910) concentration for various organic compouods «nd two PCB
compound*.
o OSHA - Safety and Health Standards (29 o Thi* regulation specilirs the type of safety equipment iml
CFR 1926) procedures to be followed during site remediation.
o OSHA - Recordkeeping, Reporting, and
Related Regulation* (29 CFR 1904)'
o DEQE - lUiardou* Waste, Phases I and
II (110 Cm 10.00)
Massachusetts Superfund
Law (M3L Chapter 2 IE)
• Thi* regulation outlines the recordkeeping and reporting
requirements for an employer under OSHA.
o These regulation* provide' a comprehensive program for
monitoring, storing, and recordkeeping at hatai.lou*
site*.
o Facility will he conitructed, fentr<1, pn*ted,
.ind operated in accordance with tint requirement.
All worker* will be property trainr-l.
o S.ifety and communication c|uiremrntt
will ho ap|t|l< ihle.
1. Applicable
2. Relevant and Appropriate
-------
ROD DECISION SUMMARY page 44
Cannons Engineering Corporation Site
3. Cost-effectiveness and Utilization of Permanent Solutions and
Alternative Treatment Technologies or Resource Recovery
Technologies to the Maximum Extent Practicable
The selected remedy offers the best combination of effectiveness,
implementability, and cost in comparison with the other
alternatives that provide the same level of protection. The
selected remedy is consistent with section 121 of CERCLA and
satisfies the statutory preference for a permanent solution and
for treatment which reduces the mobility, toxicity or volume as a
principal element. Additionally, the selected remedy utilizes
permanent solutions and alternate treatment technologies to the
maximum extent practicable.
This remedy satisfies the statutory preference for treatment as a
principal element. The principal element of the selected remedy
is the source control portion of the remedy. The principal
threat at the site is due to the contamination in the soils. The
selected remedy will treat the contamination by two treatment
technologies: Thermal Aeration and Incineration. Thermal
aeration is proven treatment technology that will provide a
permanent solution to the VOC contamination at the site by
reducing the concentrations of VOCs in the soils to target
cleanup levels which are protective of human health and the
environment. This technology, however, is not effective at
treating PCBs. Soil incineration is a proven treatment
technology that will provide a permanent solution to the PCB
contamination at the site by reducing the concentrations of PCBs
in the soils to target cleanup levels which are protective of
human health and the environment.
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. 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. Therefore, in choosing among
alternatives, the difference in the remaining criteria, namely
short term effectiveness, long term effectiveness,
implementability, use of treatment to permanently reduce the
mobility, toxicity and volume, and the cost were the focus of
the evaluation, while the nontechnical factors that affect the
implementability of a remedy, such as state and community
acceptance, also were considered. Because the evaluated
alternatives are not equal in all aspects of the evaluation
criteria, the cost effective remedy is identified as the remedy
that represents the best balance among the evaluation criteria.
The following alternatives were carried through the detailed
-------
ROD DECISION SUMMARY page 45
Cannons Engineering Corporation Site
analysis but were not selected for the reasons noted.
The first source control alternative, Alternative SC-1, minimal
no action, would not protect human health and the environment
from the risks presented by contaminated soils and does not
attain ARARs. Moreover, some form of source control is necessary
to reduce further contamination of groundwater at the site.
Alternative SC-3, solidification and on site landfilling, is
protective of human health and the environment and could be
constructed to attain ARARs, however; this alternative does not
utilize a permanent solution and an alternative treatment
technology to the maximum extent practicable. The major negative
factor associated with landfilling is the fate of residuals
remaining. This alternative reduces the mobility as the wastes
remain in place but there is no reduction in toxicity or volume.
Essentially, this alternative would create a permanent land
disposal area. In addition, the long term effectiveness of
landfilling is dependent in part on monitoring to determine
whether the landfill is effective in preventing migration of
contamination and on the long term integrity, and if necessary,
taking future maintenance and corrective measures. Finally, the
potential for failure in the future and need for replacement
exists over a long period of time.
Alternative SC-4, solidification and off site landfilling, pose
similar concerns as SC-3. Additionally, Section 121 of CERCLA
states that off-site disposal is the least favored alternative.
The Agency's policy to select on site response actions over off
site land disposal actions.
Alternative SC-6, on site incineration, would protect human
health and the environment by treating the soils as effectively
as the selected source control. It utilizes permanent solutions
and alternative treatment technologies to the maximum extent
practicable and would attain ARARs. However, this alternative
does not offer greater protection to human health or the
environment than the selected remedy, and it is significantly
more expensive. Therefore, incineration on site is not
considered to be the most cost effective source control.
Alternative SC-7, off-site incineration, would protect human
health or the environment and will attain ARARs. However, it is
far more expensive than the selected remedy and does not offer
additional protection of human health and the environment.
Therefore, this alternative is not considered to be cost
effective.
The selected management of migration portion of the preferred
alternative is MM-1, no action with monitoring. This alternative
-------
ROD DECISION SUMMARY ' page 46
Cannons Engineering Corporation Site
will involve restricting the use of groundwater at the site and
instituting a water quality monitoring program. Additional
monitoring wells will be installed on site and to the south of
the drainage canal. Selected monitoring wells will be sampled on
a routine periodic basis to evaluate the concentration of the
contaminants in the groundwater and to evaluate the dispersion of
the contaminants, if any.
This alternative will be protective of public health because the
groundwater is not a current source of drinking water. It will
attain ARARs for groundwater over a period of time as natural
attenuation dilutes and disperses the contaminants. This
alternative is effective and very easy to implement. It is the
most cost effective because it is as protective as all the other
management of migration alternatives and is the least expensive.
The pump and treat groundwater remedial alternatives (MM-2, MM-3,
MM-4, and MM-6) involve extracting groundwater for on-site
treatment.
Two different pumping scenarios were developed for each of the
management of migration alternatives. A range of extraction
efficiencies was considered for the two pumping scenarios.
Depending on the configuration of the pumping system and the
extraction efficiency, the time to effectively pump and treat the
groundwater will vary. Additionally, each alternative uses a
different treatment technology. Each treatment technology,
however, is equally as effective in treating the groundwater.
Installation of the wells could be easily implemented. However,
certain hydrogeologic conditions, the contaminant properties, and
the level of contamination limit the feasibility of drawing water
from the aquifer for treatment. The difficulties of extracting
sufficient water volumes diminishes the effectiveness of the
groundwater pumping system and increases the technical difficulty
of extracting organic compounds from the groundwater.
Additionally, the site studies show only limited portions of the
shallow groundwater are contaminated at levels that slightly
exceed ARARs. Considering these factors, the timeframe necessary
to achieve the groundwater goal would be similar to that of
natural attenuation. Therefore, this alternative does not offer
more protection to human health or the environment when compared
to the management of migration portion of the selected remedy,
and it is significantly more expensive. Thus, pumping and
treating the groundwater is not considered to be cost effective.
Table VT-5 presents the capital and O&M costs for the source
control portion of the selected alternative. Table VI-6
presents capital costs, operation and maintenance costs, and
present worth costs over a period of time for the management of
-------
page 47(a)
TABLE VI -5 M
COST ESTIMATE FOR
ALTERNATIVE SC-5: ON-SITE THERMAL AERATION OF VOC WASTES/
OFF-SITE INCINERATION OF PCB AND PAH WASTES
CEC SITE, BRIDCEVATER, MASSACHUSETTS
ITEM
I. CAPITAL COSTS
A. Mobile Lab
B. CLP Verification (20X
of staples)
C. Decontaminate Concrete,
Non-Concrete Surfaces
0. Deconcaainate and Raze Tanks
E. Raze Tank Farm Bldg.,
Ready Bldg., Incinerator
Bldg., Drainage Vault,
and Resurface Equipment
Bldg. Concrete Slab
F. Excavate Soils (Level C)
C. Collect and Treat Ponded
COST
10"5 Target
$ 105,000
46,000
57,000
250,000
126,000
12,000
8,000
COST
10"6 Target
$ 162,000
56,000
57,000
250,000
126,000
18,000
12,000
COST
10"7 Target
$ 242,000
76,000
57,000
250,000
126,000
26,000
18,000
Water from. Wet Area
H. Thermal Aeration of VOCs
o Low End Estimate 650,000 899,000 1,102,000
($180 cu yd)*
o High End Estimate 787,000 1,089,000 1,414,000
($250 cu yd)*
I. PCB, PAH Treatment (Constant volume' of 325 cu. yd. for all
VOC target levels)**
o Low End Estimate*** 424,000 424,000 424,000
o High End Estimate**** 733,000 733,000 733,000
J. Restore Disturbed Areas $ 45.000 $ 69.000 $ 102.000
Total Capital Costs (Low End) $1,723.000 $2,073,000 $2,423,000
Total Capital Costs (High End) $2,169,000 $2,572,000 $3,044,000
-------
COST ESTIMATE. FOR
ALTERKATIVE SC-5: ON-SITE THERMAL AERATION OF VOC WASTES
OFF-SITE TREATMENT OF PCB AND PAH WASTES
CEC SITE, BRIDCEWATER, MASSACHUSETTS
ITEM
COST
COST
COST
10"* Target 10** Tartet IP*7 Tartet
II. CONTINGENCY (2SX)
o Low Ead Estimate
e High Ead Estiaate
III. TOTAL PRESENT WORTH
e Low Ead Estimate
o High Ead Estimate
$ 431,000 $ 518,000 $ 606,000
542.000 643.000 761.000
52.154.OOP $2.591.000 $3.029.000
$2.711.000 S3.215.OOP $3.805.000
* Processing costs based oa cost* to treat soils at McJCia site (Haiae).
** Volume of soils with PCBs and PAHs held coastaat for differeat VOC
tariet levels; 325 cu. yd. represents PCB aad PAH coaceatratioas of
9 aad 3 ppa, respectively (see discussioa ia text Sectioa 7.2.5.2).
Entails incinerating soils with PCBs >50 pp« aad solidifying/landfilling
soils with PCBs <50 pp«, >9 pp« aad PAHs >3 ppa.
Eatails incinerating soils with PCBs >9 ppa aad PAHs >3 pp«.
NOTE: The 10~ Target Column was used to estimate the cost of the
Source Control portion of the Selected Remedy.
-------
TABLE VI-6
COST ESTIMATE FOR
ALTERNATIVE MM-1: MINIMAL NO ACTION
CEC SITE, BRIDGEWATER, MASSACHUSETTS
I. CAPITAL COSTS
A. Design and Project Planning $ 18,500
B. Monitoring Veil Installation - 7 new wells 15,000
C. Institutional Controls - Legal Restrictions 10,000
0. Contingency (251) 10,900
TOTAL CAPITAL COSTS: $ 54,600
II. ANNUAL OPERATING COSTS
A. Monitoring (Tears 1 and 2 -
quarterly Monitoring program)
Saopling (including labor, travel, equipment) $ 22,700
AaaLy»es 124,800
Monitoring (Years 3 through 10 and
every other year thereafter - annual
•onitoring prograa)
Sampling 4,475
Analyses ' 25,200
B. Monitoring Manageaeat/Over&ight/Reporting
Tears I and 2 ' 16,000
Years 3 through 10 and every other
year thereafter 8,000
C. Equipment Repair (per year) 1,000
D. Miscellaneous Legal Work (per year
for Years 1 through 10) ' 2,000
E. Public Education Costs (per year
for Years 1 through 10) 2,500
III. PERIODIC EXPENDITURES
A. Five-year Site Review (cost per review) $10,000
-------
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ROD DECISION SUMMARY • page 49
Cannons Engineering Corporation Site .
migration alternative. Supportive data for the cost estimates
are presented in Appendix F of the Feasibility Study.
D. Conclusion
Based on information available in the Administrative Record and
the evaluation of the alternatives against the statutory re-
quirements of CERCLA, the NCP, and the criteria contained in
OSWER Directive 9355.0-21, EPA has concluded that the selected
remedy is protective of human health and the environment,
attains all applicable or relevant and appropriate requirements
and is cost-effective. This remedy also satisfies CERCLA's
preference for remedies which employ treatment as their principal
element to reduce the volume, toxicity or mobility of hazardous
substances at the Site.
Although this remedy will require measures to control possible
risks related to its construction and operation, the Agency's
analysis indicates that all of these risks can be satisfactorily
controlled. Additionally, any short-term risks appear heavily
outweighed by the long-term effectiveness and permanence this
remedy will provide. The Agency believes this remedy will result
in a permanent solution to protect the public health and
environment resulting from the contamination of the Site and
utilizes alternative treatment technologies to the maximum extent
practicable.
VTI. STATE ROLE
The Commonwealth of Massachusetts Department of Environmental
Quality Engineering (DEQE) has reviewed the various alternatives
and has indicated its support for the selected remedy. The DEQE
has reviewed the Remedial Investigation, Endangerment Assessment,
and Feasibility Study to determine if the selected remedy is in
compliance with M.6.L. c 2IE and is in compliance with other
applicable or relevant and appropriate State environmental laws
and regulations. The Commonwealth of Massachusetts concurs with
the selected remedy for the Cannons Engineering Corporation (CEC)
Bridgewater site. A copy of the declaration of concurrence is
attached as Appendix C. In accordance with Section 104 of
CERCLA, the Commonwealth of Massachusetts is responsible for 10
percent of the cost of the remedial action. In the case of the
selected remedy, the Commonwealth's share is estimated at
approximately $ 340,000.
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APPENDIX A
RESPONSIVENESS SUMMARY
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FINM* RESPCKSIVQIESS SOtABY
Cairms Engineering Corporation Sqperfund Site
EPA Vfaric Assignment No. 103-IL47
FOR
U.S. BNVIRltff2fIAL HCTBGHOf AGENCY
FBUCN I
BOETTON, MASSAQC5EITS
MARCS 1988
Bd by the REM m Project Tteam under EEA. Contract No. 68-01-7250
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TABIE OF
Page
DEFACE 1
I. BACKGROUND ON CCMMUNTTY INVOLVEMENT AND CONCERNS 3
II. SUMMARY OF COMMENTS RECEIVED DURING THE HJBLIC COMMENT PERIOD
AND EPA RESPONSES TO THESE COMMENTS. 5
A. Determination of Soil Cleanup Levels
1. Bias in the Sampling Program 6
2. The Exclusion of Non-detectable (ND Values and
Inclusion of Duplicates Resulted in Overstated
Mean Contaminants Levels 7
3. Failure to Factor Limited Spatial Distribution of
Contamination in the Endangerment Assessment 7
B. Incineration Requirement for Soils. 9
1. Contaminant Levels Requiring Incineration 9
2. Cost-Effectiveness of Incineration 10
3. Alternative Approaches for Disposal of PCB-Contaminated
Soil. 11
C. Treatment of VOC-Contaminated Soil 12
1. Cost Estimates for Treatment 12
2. Alternative Approach: Biological Treatment 15
3. Alternative Approach: Asphalt Batching 18
D. Remediation of Building and Structures 20
E. Ground Water 22
III. REMAINING CONCERNS ' " 24
ATTACHMENT A - COMMUNITY RE1ATIONS ACTIVITIES CONDUCTED AT
THE CANNONS ENGINEERING CORPORATION SITE 26
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Pr
The U.S. Environmental Protection Agency (EPA) held a public uumimiL
period from February 11, 1988 to March 4, 1988 to provide an opportunity for
interested parties to ooanent on the January 1988 draft Feasibility Study (FS)
and Proposed Remedial Action Plan prepared for the cannons Engineering
Corporation (CEC/Bridgewater) Super fund site in Bridgewater, Massachusetts.
The FS examines and evaluates various options, called remedial alternatives,
for addressing contamination at the site. EPA identified its preferred
alternative for the cleanup of the site in the Proposed Remedial Action Plan
issued at the start of the public comment period.
The purpose of this responsiveness summary is to document EPA responses
to the comments and questions raised during the public comment period. EPA
will consider all of the comments summarized in this document before selecting
a final remedial alternative for the Cannons Engineering Corporation Superfund
site in Bridgewater, Massachusetts (CBC/3ridgewater site) .
This responsiveness summary is divided into the following sections:
I. Background on O^fflnunitv Involvement and Concerns • This section
provides a brief history of community interests and concerns
regarding the CEC/Bridgewater site.
XX. gunnmry nt ftnm*»iih« Ppoeivgd PffllTT the P*iff?li7 QjmiKtnt P^^iod and
EPA Btffponses to These CciiBiitiMts - This section summarizes both
written and oral comments received from the public during the public
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2
conment period and provides EPA responses to them. These Garments
are organized by subject area.
III. Remaining Concerns - This section describes issues that may continue
to be of concern to the conmunity during the design and
implementation of EPA's selected remedy for the CEC/Bridgewater
site. EPA needs to address these concerns during the Remedial
Design and Remedial Action (RD/RA) phase of the cleanup process.
Attachment A - This attachment includes a list of the ojummnity relations
activities that EPA conducted at the CEC/Bridgewater site during the
remedial activities at the site.
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I. EACH3CUND ON OOtfJNTlY 3NWDVBffiNT AMD ODORS
Through the site's history, community concern and involvesnent has been
low to moderate. However, since the site's listing on the NFL, one citizen's
group, Bridgewater Aware, has remained actively interested in activities
occurring at the site. EPA has kept this group and other interested parties
informed through informational meetings, fact sheets, news releases, and
public meetings.
In 1982, EPA released a community relations plan which outlined a program
to address community concerns and keep citizens informed about and involved in
activities during remedial activities. On November 15, 1983, EPA held an
informational meeting in Bridgewater to describe the plans for the RI/FS. In
July 1984, EPA issued an information sheet updating the community oh the
progress of the HI. On May 27, 1987, EPA held an informational meeting to
present the results of the draft RI and to answer questions from the public.
On February 11, 1988, EPA held an informational meeting to rtismss 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 February 11 to March 4, 1988, the Agency held a three-week
public uuuueiiL period to accept public comment on the alternatives presented
in the FS and Proposed Plan and on any other documents previously released to
the public. On February 25, 1988, the Agency held a public hearing to accept
any oral comments. A transcript of this meeting and agency responses to
comments are included in this document.
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At these public meetings, citizen inquiries about EPA activities at the
site generally focussed on the cleanup costs and schedule, and EPA enforcement
actions. Citizens also were interested in discussing the extent and results
of EPA sampling and testing activities. Citizens expressed specific concern
about potential health risks posed by exposure to site contaminants, whether
EPA has plans to fence the site, and about the on-site storage of chemicals in
the site equipment building.
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U. SUMMARY OF CCMMENTS RECEIVED DURING THE KJBLIC CCMMENT FERZGD AND EPA
This responsiveness summary addresses the written comments raoeived by
EPA concerning the draft IS and Proposed Plan for the Cannons Engineering
Corporation Super fund site (CEC/Bridgewater site) in Bridgewater,
Massachusetts. There were no formal oral contents presented at the February
25 public hearing, but the question-and-answer period that followed is
recorded in a transcript of the hearing. Copies of the hearing transcript are
available at the information repositories located at the Bridgewater Public
Library, and the EPA Region I office in Boston, Massachusetts.
EPA received one set of written oonnents from a PRP on the FS and
Proposed Plan. The written comments are summarized and organized into the
following categories:
A. Determination of Soil Cleanup Levels
B. Incineration Requirement for Soils
C. Treatment of VOC-Contaminated Soil
D. Remediation of Building and Structures
E. Ground Water
EPA responses are provided for each eminent, or set of like comments.
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A. DL'i'mgNAnON OF SOIL
1. Blag in 'the Sampling Program
Comment; The commenter stated that the design of the soil sampling
program, as described in the PI, was biased toward high positive results.
The reasons given by the ocntnenter for the bias were: (1) from each
grid, samples were taken where there was visible contamination or, if no
contamination was visible, the grid center was sampled, and (2) only
those sanples which screened positive in the field were sent for
laboratory analysis. The commenter felt that it was not appropriate to
use these data to represent average site conditions.
Response; The field sampling program for the CEC/Bridgewater site is
typical of most Superfund sites. A grid sampling design is used to
determine the extent of contamination on a site because contamination may
be present, but not visible, in soil. The objective of field sampling is
to characterize the extent and limits of contamination. Sampling at
regular intervals is performed to characterize a site as fully as
possible within reasonable cost. To implement a cost-effective sampling
program, grid samples that show visible contamination and/or screen
positive in the field are targeted for chemical analyses. EPA and its
contractors recognize that field sampling data may be biased toward the
positive. This is necessary to avoid overlooking contamination at a site
and to provide for cost-effective field programs.
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2. The Exclusion of
ary sion
The commenter disagreed with some aspects of the methods used
to compile the laboratory data for use in the Endangennent Assessment.
In particular, the commenter felt that failure to incorporate ND values
into the mean resulted in artificially high values of average contaminant
trations and that the use of duplicates in calculating means was
unacceptable. The commenter stated that duplicate samples are collected
solely for assessing the reproducibility of results and should not be
used in the calculation of means. The commenter concluded that these
procedures overestimate mean contaminant concentrations.
Response! The use of ND values would not change the remedy selected for
the site. RI sampling data are compiled in various ways for use in
Superfund risk assessments. There is no single "right way11 to summarize
such data. The inclusion of ND values into the calculation of means does
not significantly alter mean contaminant concentrations for the site.
Furthermore, the inclusion of duplicates in the calculation of average
contaminant concentrations would not significantly change the value of
the means.
3.
Failure to
of OonfcarBiration in
Comment: The commenter stated that the Endangennent Assessment failed to
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consider the heterogeneous spatial distribution of contaminants on site
and that this further contributes to the overestimation of risk at the
site. The exclusion of the ND values in the calculation of mean
contaminant levels and the lack of consideration of the probability of
contact of human receptors with contaminated soil are cited as reasons
for overestimation of risk.
j
Response; The impact of exluding ND values in the calculation of mean
contaminant levels has already been discussed. The use of statistical
methods to assess the probability of direct contact in assessing risks at
Super-fund sites is not routine. The approach taken in the
CEC/Bridgewater Endangerment Assessment is consistent with EPA Region I
standard procedures for assessing direct contact hazards. The use of
statistical methods that assume random behavior to assess the probability
of direct contact may be inappropriate given the non-random nature 'of
human behavior.
While the Endangerment Assessment developed upper and lower bounds on
risk, it did not specifically address the variability in distribution of
surface soil contaminants. However, the spatial distribution of soil
contaminants at the CEC/Bridgewater site was considered in the evaluation
of remedial alternatives and the selection of the remedy.
Finally, as the commenter indicates, different exposure assumptions will
result in different outcomes of incremental risk. However, EPA adopted
exposure assumptions to realistically reflect exposure scenarios which
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have a reasonable likelihood of occurring.
B. INC1JNKHATION REQUIREMENT FDR SOUS
1.
Cuiiiifcint; The FS is incorrect in stating that soils containing PCBs in
excess of 50 ppm must be disposed of by incineration. TSCA (40 CFR
761.60 - 761.79). TSCA (40 CFR 761.60, a. (4) states that, "Any non-
liquid PCBs at concentrations of 50 ppro or greater in the form of
contaminated soil, rags or other debris shall be disposed of:
(i) In an incinerator which complies with 761.70; or
(ii) In a chemical waste landfill which corplies with 761.75.
Response; The FS did not state that the only way to remediate soils
containing PCBs in excess of 50 ppm was by incineration. The FS
indicates in the screening of alternatives that wastes with PCBs greater
than 50 ppm may be treated by incineration or landfilled at a TSCA-
approved facility. It further indicates that "TSCA regulation would be
net by using incineration to treat soils with PCBs greater than 50 ppm.
Alternatively, these soils could be landfilled without treatment at a
permitted facility." See p. 6-5, Feasibility Study.
Additionally, in the detailed analysis section of the FS where actions to
be taken to attain ARARs are discussed, the FS indicates PCB-
ccntaminated soil in excess of 50 ppm . . . "would have to be disposed of
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or treated in a facility permitted for PCBs, in compliance with TSCA
regulations." See p. 7-73, Feasibility Study.
2* Qpst— Effg^'tivenpsi? nf Incjr>OT'9*^"i
Incineration of PCB-contaminated soils is not a cost-effective
remedy. Inasmuch as PCBs are highly iimobile when mixed with fine
grained soils, the level of contamination is low, the regulations do not
require incineration, and the cost of incineration is extremely high, it
does not appear that incineration is appropriate to this situation. The
commenter suggests two alternative approaches to off-site incineration of
the PCB-contaminated soils. First, the PCB-contaminated soils could be
disposed of in a TSCA-pennitted land disposal facility, which should be
adopted as the preferred alternative in the ROD. Second, the soils could
be dechlorinated by potassium/polyethylene glycol similar to the Resolve,
Inc. site, which should be considered as an alternative to landf illing in
the ROD.
Response: The Agency selected off -site incineration of PCB-contaminated
soils as the alternative that best meets the cleanup standards of CEBCLA.
The target cleanup levels of PCB-contaminated soils are designed to
provide a protective remedy. Incineration of the contaminated soils will
provide a permanent solution and utilize an alternative treatment
technology to reduce the mobility, toodcity, and volume of the wastes.
CERCLA Sec. 121 (b) states that the off-site transport and disposal of
contaminated materials without treatment is the least favored '
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alternative.
Additionally, incineration is cost-effective because it represents the
best balance among the remedy evaluation criteria: protection of human
health and the environment, overall compliance with ARARs, reduction of
mobility, toxicity, and volume, short-term effectiveness, long-term
effectiveness, implementability, community acceptance, state acceptance,
and cost.
3. Alternative Approaches for Disposal of PCB-Contaminated Soil
Comment; The Agency should consider dechlorination of PC&- contaminated
soils as a cost-effective treatment alternative.
Response; Dechlorination was not considered a cost-effective treatment
alternative at the site because of the estimated small volume of PCs-
contaminated soils to be treated. The costs per cubic yard cited by the
commenter were developed for the Resolve, Inc. site based on a volume of
25,000 yards. It is inappropriate to assume a similar unit cost for
treating the estimated 325 cubic yards at the CEC/Bridgewater site since
the capital costs for Resolve were spread over 25,000 cubic yards.
Furthermore, the Agency notes that the commenter asserts dechlorination
would meet a clean-up target level of 25 ppm, which would not meet the
soil remediation target level of 9 ppm for this site. Incineration will
meet the remedial response objectives for the site.
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C. U.S. EPA'S APPRQACT TO TREATMENT OF
1. Oust, Estijna^^s for
Qonrnentt The estimated costs of treating soils by thermal aeration are
inaccurate. The FS estimates the capital costs to be $300,000 and the
operation and maintenance costs to be between $180 and $250 per cubic
yard. Based upon an estimated 1,875 cubic yards of soil and 61 cubic
yards of demolition debris, for a total of 1,936 cubic yards to be
processed by this technique, the total unit cost would range from $334 to
$404 per cubic yard or from $650,000 to $787,000.
The coramenter noted that the process may be hampered by a high water
content and the high percentage of fines in the soil. Reduction of the
water content by mixing the soils with a drying agent or by dewatering
prior to treatment will increase the unit costs for this process.
Alternatively, a reduction in the through-put rate to achieve drying in
the reactor could be considered but will increase energy costs.
Considering these factors, the commenter claims that the unit cost for
thermal aeration will liJcely be closer to $400 per cubic yard than to the
lower estimate.
The FS indicates that testing work will be required before using the
thermal aeration technique. However, the success of this technique
elsewhere indicates that additional testing work is not necessary.
Excspt for start-up testing prior to full-scale operation, no feasibility
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testing of this technique should be required.
The proposed thermal aeration process is estimated to require
approximately 1/3 acre. According to the FS, this will require that the
Tank Farm Building be demolished and removed from the site at an
estimated cost of $92,000. Based upon a site inspection, the commenter
believes that sufficient area exists on the site without demolishing the
building.
The commenter stated that the quantities of contaminated soils targeted
for cleanup do not include an allowance for soils under the tanks and
buildings. Since it is possible that these soils are contaminated, the
estimated quantities of soil requiring treatment will increase
significantly. Inasmuch as this may effect the methodology used to treat
the soils on the site, the sampling of these soils should be undertaken
before a final decision is made on the remedial technology to be used.
Response; The FRP Group's comments regarding alternative approaches to
remediation of soils and buildings are premised upon inaccurate
representations of the conclusions in the FS. The particular points of
contention that the FRP Group raises with the FS are in the following
three areas:
(1) volumes of soil to be remediated;
(2) low temperature thermal aeration processing costs; and
(3) siting requirements for low temperature thermal aeration.
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These three issues are addressed in the following paragraphs.
Hie volume of soils and debris that should be used for cost estimating
purposes is approximately 3,000 cubic yards, and not 1,936 (1,935 + 61)
cubic yards, as stated in the Garments. This is because the FS estimated
that, in addition to surficial soils, approximately 1,000 cubic yards
from subsurface excavation zones (around tanks and under buildings) would
also have to be treated for VDCs. Based on this volume and the FS's
estimated range of thermal aeration processing costs ($180 to $250/cubic
yard) and capital costs ($300,000), the total unit costs would range from
$280 to $350 per cubic yard, not $334 to $404, as stated in the comments.
The FS estimates of $180 to $250 per cubic yard for processing costs were
based on actual costs incurred during the cleanup of VOC- and PAH-
contaminated soils at the McKin site. Because that site represented the
first full-scale application of the technology, costs were higher than
future costs projected for application of this technology. Certain
vendors contacted during the development of the F5 stated that low
temperature thermal aeration unit costs of $75 to $150 per cubic yard are
achievable with suitable site conditions (contaminants with low boiling
points; soils with low moisture and silt contents). The soils at the
CEQ/Bridgewater site have high moisture and silt contents; therefore, it
is more appropriate to utilize the McKin site costs for estimating
purposes because of the problems that had to be overcome during that job.
The thermal aeration process siting requirement of 1/3-acre stated in the
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PS is the area needed only for the processing unit. The F5 stated that
additional area is required for support functions (staging, storage,
decontamination, etc.), and that the entire area required to implement
this alternative would likely require the removal of the tank farm
building or use of land to the north of the CEC/Bridgewater site
boundary.
The FS did account for potential subsurface excavation zones underneath
the tank farm building and around the septic system and underground vault
(or sump). (See pages 3-18,3-19, and 3-23 in the FS); This volume was
estimated at 1,000 cubic yards and was then added to surficial soil
volumes for use in cost analyses (see Table 3-4 in the FS).
2. Biological Treatment
Comment; The FS should have conducted detailed analyses of biological
treatment of contaminated soils. The FS eliminated biological treatment
as an alternative because it has not been demonstrated as an effective
technique. Yet on soils containing VOCs at the Tinkham Garage site in
Londonderry, New Hampshire, biological treatment has been demonstrated as
effective at a cost of $160 per cubic yard. Biological treatment should
be retained as a feasible technology. Also, if carried out in the
existing Equipment Building, biological treatment could be even less
costly.
In 1987, ECOVA Corporation conducted bench scale tests to assess the
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potential for biodegraticn of vocs in soils from the Londonderry site.
These tests indicate that VDC's can be reduced to the 1 ppn level by
biological treatment and air stripping in a controlled environment. In
preliminary discussions relative to the Bridgewater site soils, EOOVA
personnel indicated their belief that the biological treatment process
could meet the remediation goals of reducing benzene to the 4 ppm level
and PAHs to the 3 ppm level at a cost considerably less than the
estimated $400 per cubic yard for thermal aeration.
Response; The use of biological treatment to treat soils at the
GBC/Bridgewater site is not an appropriate approach for several reasons.
Biological treatment of contaminated soils is still in the developmental
stage. Biological treatment has been used to treat industrial waste
streams and oily sludges, but this does not require the same type of
process controls as treating hazardous wastes. The treatment of soils at
the CEC/Bridgewater site would require a preliminary analysis of the
technology's effectiveness, as well as a demonstrated ability to monitor
and control all emissions and process streams.
It is expected that biological treatment would be effective against
monoaromatic contaminants at the CEC/Bridgewater site. Bench-scale
testing, however, would be required to assess its effectivenss against
polyaromatic compounds in the CEC/Bridgewater site soils. The BCOVA
studies with contaminated soils demonstrated that aromatic hydrocarbons,
but not chlorinated hydrocarbons, were biodegraded under the conditions
of the study. The studies were designed to compare the rate of
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disappearance of contaminants from nonsterile versus sterile soils. The
difference between the disappearance of methylene chloride and
trichloroethylene (TCE) from nonsterile versus sterile soils was only 16%
after six days. For tetrachloroethylene, there was a greater loss from
sterile soils than fron nonsterile soils. These results indicate that
the disappearance of these cotpounds from soil is attributable primarily
to volatilization. Differences observed between sterile and nonsterile
soils could be attributable to biodegradation and/or heterogeneity of
contaminant distribution in site soil samples. The summary section of
ECOVA's report states that "biodegradation of TCE was not achieved by the
native microorganisms" and "to achieve cleanup levels most rapidly, both
biodegradation of petroleum hydrocarbons and volatilization of
chlorinated hydrocarbons must be used effectively.
Remediation of ground water contaminated with chlorinated aliphatics is
in the developmental stage by several vendors and institutions, and
involves complex microbial consortiums and process requirements that are
incompatible with biodegradation of aromatics. Therefore, sequential
batch reactors would probably be required to degrade the different
classes of compounds in soils at the site.
.Process parameter requirements for biological treatment would require
mixing as well as aeration for the aromatics. This would cause
volatilization of the VDCS, for which an emissions control unit would
have to be designed. At present, no fixed or mobile treatment unit with
these necessary design features is available. Extensive bench- and
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pilot-scale testing would be required to design an effective system for
the CEC/Bridgewater site.
In contrast to biological treatment, the effectiveness of low-
temperature thermal aeration has been proven in the field. Furthermore,
additional research and development considerations would not be necessary
for emissions management and process parameter requirements.
In summary, the selection of low-temperature thermal aeration to
remediate soils at the CEC/Bridgewater site ensures that cleanup can be
initiated in a manner that is timely and consistent with statutory
preferences for treatment, and at reduced costs relative to other proven
technologies.
3. Asphalt Batching
Comment; The FS should consider asphalt batching as an approach for
disposal of VOC-oontaminated soil. At least two asphalt batching
companies, Black Mountain Corporation of Holliston, Massachusetts and
Brocks Jetline of Dover, Massachusetts, have performed asphalt batching
of contaminated soils as a means of remeditating sites where spills of
petroleum oils have occurred. The asphalt/soil mix is then used for
highway construction. This method of remediation has been implemented at
several sites in Massachusetts under the direction of the CBQE.
To date, Black Moutain Corp. has handled only soils contaminated with
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"light-end" hydrocarbons, such as gasoline, kerosene, diesel fuel, and
No. 2 fuel oil. The contaminants found at the Bridgewater site are
similar to those found in soils contaminated by gasoline and oil spills.
The cold batching process utilized by Black Mountain is reported to cost
from 60 to 80 percent of that for disposing of soil in an approval
landfill and should be considered in the POD.
Brocks Jetline performs hot-mix asphalt batching of soils contaminated
with hydrocarbons including gasoline, kerosene, diesel fuel, and Nos. 2,
4 and 6 fuel oils. Hot mixing reportedly costs from $100 to $150 per ton
or $150 to $225 per cubic yard.
The asphalt batching process may be considered as a potential alternative
to thermal aeration or biological treatment. The reported cost of $150
to $225 per cubic yard are considerably less than the $334 to $404 per
cubic yard estimated by USEPA for thermal aeration.
Response; Asphalt batching is similar to the use of a solidification
technology as described in the FS for Alternative SC-3. The asphalt
batching approach would involve mixing the contaminated soils with
asphalt emulsions, and using the resultant material for pavement.
Alternative SC-3 involved solidification of contaminated soils and
debris, and subsequent disposal in an on-site RCRA landfill rather than
use as a pavement. The solidification/landfill alternative was not
selected because it is not a permanent solution, it does not use
treatment to the maximum extent practicable, it does not reduce the
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volume of toxicity of the wastes, and it would require long-term
monitoring to assess the effectiveness of the remedy. Asphalt batching
would not be the preferred alternative for the same reasons. Asphalt
batching does not confer any advantages with regard to effectiveness and
implementability over those previously described for solidification in
Alternative SC-3.
D. PPIEDIftnON OF BUirpDJG AND
The FS and Proposed Plan would demolish all above ground
storage tanks and all buildings, except the equipment building, after
decontamination. The FS implies that the buildings and tanks must be
demolished after decontamination to permit the sampling of soils under
the foundations. This plan appears to be highly excessive in terms of
necessary remediation of the site. The purpose of the demolition of all
of the storage tanks after decontamination is not clearly described nor
is the estimated cost of $250,000 justified in the FS.
While demolition of the buildings would facilitate sampling for poten-
tially contaminated soils beneath the flooring, it is an extreme measure
to acccnplish this task. Because of the uncertainties in the level of
effort required to decontaminate the structures, the requirement for
building and above grade tank demolition seems premature with the
possible exception of the incinerator building.
The incinerator and incinerator building may require removal for
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effective remediation. However, further sampling of wall and floor
surfaces in the other buildings is required to assess the extent of
contamination. A sampling program for building walls and floors should
be carried out as a first step in deciding the ultimate fate of the
structures. They should be demolished only if the sampling proves that
the floors and walls are permeated with contaminants to the extent that
they cannot be decontaminated.
In the more likely event that the building walls and floors contain only
minor surface contamination, the next step should be to core drill
through the floor slabs and sample the soil immediately under the floors.
If the soil is found to be contaminated, the buildings may have to be
demolished to permit removal and treatment. If not, the buildings could
be decontaminated, as described in the FS, the walls and floors
resurfaced or sealed with paint, resin, or gunnite, and the buildings
left in place.
If required, the above-ground outside steel tanks can be decontaminated
using conventional cleaning methods. However, it is reported that these
tanks were never used, and it is very possible that they are not
contaminated. Therefore, they should be tested for contamination prior
to deciding upon the need for decontamination or removal.
It should be noted that the equipment building, tank farm building and
ready building appear to be in good structural condition. After cleaning
and removal of piping and tanks, if required, these buildings could
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retain en the site and be sold to another user. The FS does not
the future use of this valuable site, and it should be considered in the
POD.
Response: The Agency has determined that decontamination and removal of
the buildings and structures is necessary to protect human health and the
environment from the release and threat of release of contamination, and
to fully characterize the nature and extent of contamination at the site.
Sampling of soils under the buildings and structures can be most
effectively conducted after the buildings and tanks are removed.
Decontamination of the tanks and building is required to properly close
the incinerator and tank facilities. Additional costs for the removal of
the structure after decontamination are estimated to be $150,000. Given
the small additional cost and the potential risks of failing to detect
contaminants if sampling is hampered by the exising structure, the Agency
determined that maintaining the integrity of the tank farm and buildings
would not be the most protective, effective, or inplementable approach.
E. GROUND WATER
Considering the hydrologic conditions and the low levels of
organic contaminants at the site, the FS plan to install seven additional
monitoring wells (of which 3 of the proposed wells are duplication of
existing wells) and to perform extensive sampling over a thirty-year
period are unwarranted and costly. The commenter further suggests a
reevaluation of the target compound list, and an alternative approach to
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monitoring well locations and frequency of monitoring.
Response; The proposed target compound list has been reevaluated in the
"PCD and has been slightly modified. A full explanation of the selection
of groundwater clean-up target levels is in the POD. The FS outlines a
proposed monitoring program. Ihe groundwater monitoring network to be
implemented will be designed during the remedial design phase of the
remedial action. Ihe monitoring program will be designed to meet the
intent of PCKA groundwater monitoring requirements and will be tailored
to site specific hydrogeologic conditions. Ihe carmenter's suggested
alternative approach to monitoring well locations and frequency of
monitoring will be considered during the design.
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IV. KEMADtDG
During the public comment period, at the public informational meeting en
the FS held by EPA in Bridgewater on February 11, 1988, and at the informal
public hearing held en February 25, 1988, local residents rtismssfri issues
that may continue to be of concern during the design and implementation of
EPA's selected remedy for the CEC/Bridgewater site. These issues and concerns
are described below:
(A) Site Security
Citizens expressed concern that, although there is now a guard stationed
at the site, often the gate is left open and the guard is not visible.
Citizens requested that the guard lock the gate if he is planning to sit
inside the trailer where he cannot be seen. Furthermore, citizens requested
that EPA quickly construct a fence to prevent access to the site following the
removal actions and dismissal of the guard.
Several citizens were very concerned about whether EPA had conducted any
off-site sampling, and whether EPA expects that there is any off-site
contamination of the surrounding property. EPA explained that no off-site
sampling of soil or ground water has been conducted to date. EPA has found
that ground water is flowing in a north to south direction, and that the
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25
contaminants in the ground water naturally attenuate before reaching the
drainage canal. EPA will be conducting further on-site sampling during the
remedial design phase, and will continue to provide citizens with this
sampling data. In addition, EPA will begin to monitor the ground water off
site to study the movement of contaminants and to ensure that they are not
migrating off site.
(C) Availability of On-site Contact Person
Citizens asked EPA if there would be an on-site official who could asnwer
any questions they may have regarding the design and construction of the
remedial action. The person assigned by ZPA to be the on-scene coordinator
should be prepared to respond to citizens questions.
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26
xracararr A
CXMCNTH HELATICK; ACTIVITIES
ATTBE
CANNGK5 BdMEERINS OCRPCRWTGN
DJ ERIDGZHATER, HASSAQIJ5ETIS
Community relations activities conducted at the CEC/Bridgewater Suqperfund site
to date have included:
o 1982 - EPA released a community relations plan describing citizen
concerns about the site and outlining a program to address these
ms and to keep citizens informed about and involved in site
activities during site remedial activities.
o November 15, 1983 - EPA held a public meeting to explain plans for
the Remedial Investigation (RI), to define the extent nf
contamination, and the Feasibility Study (FS), to evaluate
alternatives for remedial action at the site.
o July 1984 - EPA issued an information sheet updating the community
on the progress of the RI.
o May 1987 - EPA issued a public notice announcing the availability of
the RI, and the upcoming public meeting to explain the results of
the RI.
o May 27, 1987 - EPA held a public meeting to present ttoe results of
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27
the draft Remedial Investigation and answer questions fron the
public.
o February 4, 1988 - EPA issued a public notice to announce the time
and place of the upcoming PS informational meeting and to invite
comment on the FS and the Proposed Plan, which outlines EPA's
preferred alternative for addressing contamination at the
CEC/Bridgewater site.
a February 11, 1988 - EPA held an informational meeting to discuss the
cleanup alternatives presented in the FS, and EPA's Proposed Plan
for addressing the contamination at the CEC/Bridegewater site. EPA
also answered questions fran the public.
D February 11, 1988 to March 4, 1988 - EPA held a three week public
comment period to accept public comment on the alternatives
presented in the FS and EPA's Proposed Plan.
o February 25, 1988 - EPA held an informal pubic hearing to accept
oral comments on the remedial alternatives evaluated in the FS, and
EPA's Proposed Plan.
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1
2
3
4
In the Matter of:
PROPOSED PLAN FOR CLEANUP OF
CANNONS ENGINEERING CORPORATION
8
SUPERFUND SITE
10
11
12
13
14
15
16
17
18
19
24
25
UNITED STATES OF AMERICA
ENVIRONMENTAL PROTECTION AGENCY
REGION ONE
Thursday
February 25, 1988
Bri::ewater Acaderr.y Building
Second Floor Meeting Room
Bridgewater, Massachusetts
The above-entitled matter came on for hearing,
pursuant to Notice; at 7:30 p.m.
BEFORE:
20 MERRILL HOHMAN, Director
Waste Management Division
21
WAYNE ROBINSON
Environmental Engineer
RICHARD MCALLISTER
Assistant Regional Counsel
PRESENT: HARISH PANCHAL
D.E.Q.E.
MARGARET BARRETT
ICF
Rcgistrrtd Professional R
(617) 426-3077
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2
3
2
MR. HOHMAN: Good evening and welcome.
My name is Merrill Hohman. I'm the
Director of the Waste Management Division of Region I
of the United States Environmental Protection Agency,
and let me welcome you to this session this evening.
Could I suggest that maybe people would
like to just fill in down here. There's plenty of seats
down front, as they say, and we will try to make this
as informal as we can.
There are some formalities we have to
go through this evening and I will explain why as we go.
ii
i;
12 !| First, this is a public meeting and an
j:
12 j] informal public hearing to present and to receive comer.ts
i!
1.1 !j on EPA's proposed plan for cleanup 'of the Cannons/
i1
/:
15 ji Bridgewater Superfund site, as required by Section 117
I:
15 i of the Amended Superfund law. And as you will see, we
i-
j
17 . are having a stenographer record the entire meeting this
i,
15 !i evening and a transcript will bn prepared and will be
6
7
8
9
19
n
ii
21
22
23
24
25
made part of the record and it will be available for
20 !; public review in our office in Boston, in the John F.
Kennedy Federal Building, and also, a copy will be made
available for review here in the Bridgewater Public
Library.
If, for any reason, anyone wishes their
*
own copy.of the transcript, I would suggest that you
APEX Reporting
Registered Professional Kfportrrs
(617)426-3077
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6
7
8
16
"-•i
20
21
22
23
24
25
contact the stenographer directly after the hearing closes
and see if you can make your own individual arrangements.
That might be the quickest way for that to be done.
Let me begin by doing some introductions
of some EPA and State staff that are here with me this
evening.
On my left is Wayne Robinson, the EPA
project manager for the Bridgewater Superfund site. On
9 ii my immediate right is Richard McAllister, who is the
;i
1C i: attorney for the site in EPA's office of Regional Cou-.sel.
!i
11 :, Down^ at the door we have Margaret Barrett,
Ii
0
12 l| from a firm by the name of ICF, which is our community
13 •-. relations consultants to EPA for this particular site.
i1
r t
14 i We also have with us, in the front rev
I
15 :• right here, Harish Panchal, who is with the State of
16 ; Massachusetts, Department of Environmental Quality
17 '• Engineering, and has been working with us on this site.
Now, as I say, I hope you will bear with
me because of the fact that we have to prepare a
transcript and so forth, we would like to break the evening
up into basically three parts. Now let me review how
we would proceed.
First, I'm going to ask Wayn« Robinson,
our project manager, to make a brief statement reviewing
*
our proposed plan for the cleanup. I think we can nake
APEX Reporting
Registered ProffStioni:! Rrporteri
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1
2
6
7
8
19
21
22
23
24
25
that brief because there was a meeting down here to discuss
! the plan in considerable detail on February llth.
3 ij After we finish that presentation, there
will be a chance for those of you who want to make a
formal statement to do so. I have, now, two individuals
who have indicated they would like to make a statement,
and if you would like to make a statement, please contact
Ms. Barrett and she'll sign you up.
9 i' We will go through those formal statements,
1C •; which are more of the usual hearing-type of statement,
11 '; and then after we take those, wo will open the session
'1
•I
12 I; up to a very informal period of time to take questions,
13 ,: answers and any comments that you might wish to make to uc.
14 ij . Are there any questions on how we are
ji
15 '•• going to proceed?
i
16 !• (No verbal response.)
17 l! MR. HOHMAN: Okay. Why don't we get
18 i' started and I'll start by calling on our site manager,
Wayne Robinson, who will make a little presnntation to
20 .ll all of us on the proposed plan for cleanup.
MR. ROBINSON: Thank you, Merrill.
I have two overheads that I would like
to show you as I described our preferred alternative.
The first is — I would like to acquaint
you with the site itself, because I will be making some
APEX Reporting
Rrgistftfd Proffnional Reporters
i
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39(b)
TABLE VI-1
UL-WtClMC MUM MB CUTOU.
OC Mil.
0011
rooriU
tuuaatm u rm
KM CarciaafaB
Craap rataac* Vactan
Vactan ara
lik Ufacta
ky U* IM
•M
Haaaackaaatta Haaaackaaatta Driaktof *»*
Critaria. Mviaariaa, Baaltk Mviaariaa
•*•!«» MvtMttM «wra c«*«
f*c
MQI
UfeMt Quality
()!• CM 4.M)
lateral Aakiaat Mitar
Crtlarla (AUQC)
tarfaca «atar ^aallty ltaa«aNa
•r« ftivaa far 4taaal«*4 aaygaa,
(••awraMra tacraaaa. pM, aa4 tatal
Ulifan.
aata fa* 4iaaalva4 aay*aa, taayaratara
. pi. aa4 tatal Calltara) vill ka attaiaa4(
r«a
-------
page 39(c)
TABLE VI-1 (c«n !•••«)
MUM *trt CUTOU. MVIMUU.
oc nn.
MQUHIBMT
a m M/f»
eu-. National Ambient Air
Quality Standards (NAAQS)
40 CFR 50
••*« 9vUwtllf
(•c y*ctlcmlat« MtMr will b«
*« •*!! tr*«(•••(•.
- Air
1.00).
010
, Alt
ft.oo
fwtaril Criteria,
l»«rlOT, «•* (TLV»)
Lteit ?•
TUP*
!•« Mil
-------
page 40la)
TABLE VI->
US Army Corps of Engineers
Nationwide Permit Program
33 CFR 330
FUk w4 MtUHfe
C»M4lMUM AM CM •-••
Ml)
(«• CM M4.1B)
(>!• CM U.M)
twill*
I.M)
to to (M tint)
, W Mtivttf
f •! fMU • MtUM* MBit to
M*tM4 tf •
aftott
•f *ltoM»U«M, tto «ICMU M
IM ttot
tto. fcMMtttMliM. MMM&M. M«
It M •!
««. Tki»
i CM
It Ito •.».
nt*
!•* i
tortUtf
MM* to •
« facility
to«lt* ••« kto ••v
toyii««ktltty
«l» fiU* • *MiC« •< !•>«•!
U i«Ml>««i M>it tkM
•tot •tfl«M« ••
tea tto «*U«rU
•to C^uiAty mn to
•« • MW tMiUtf W
to»tltcy tor tto
•ll
•U
M to
ttot toMlwi
• •*
»••««<«*••
I «It«
-------
page 40(b)
TABLE VI-2
*»*» MB cunmiA. «on*ouu. AM avuMKS m m
oc im,
•in fiATug •igumaui wmntatan martin can unarm v va M/M
Orfer CBO 1UM) UM ri*k •< fl»M U*«. (• •! •!•!•• «r»«l««l*4 t« ••••r« ttot U
Ail •*ter(c«M4 «t«i«fa Udk« will to
-------
ROD DECISION SUMMARY page 41
Cannons Engineering Corporation Site
be taken to attain the ARAR. Table VI-3 and VI-4 indicates the
action specific ARARs, presents a brief synopsis of the
requirement, and outlines the action which will be taken to
attain the ARAR. A brief narrative summary of the ARARs follows.
The remedial action will involve the construction of a facility
to excavate contaminated soils, drum the PCB contaminated soils
for transport and disposal, and prepare the site for low
temperature thermal stripping. The facility will be
constructed, operated, and maintained according to RCRA facility
standards and OSHA requirements. ARARs for low-temperature
thermal stripping of the. VOC contaminated soils include
controlling the air emissions from the thermal stripping unit .to
comply with CAA and OSHA requirements. The drummed PCB
contaminated soils will be transported to an off-site incinerator
which is in compliance with the EPA's off site policy. The drums
and transportation vehicles will be properly labeled in
accordance with TSCA and will be done in a manner in compliance
with DOT rules for transportation of hazardous materials.
RCRA requirements will be met by implementing this alternative
because the tanks, storage areas, and incinerator will be
decontaminated. The Massachusetts Hazardous Waste Regulations
are consistent with RCRA so that compliance with RCRA will result
in compliance with Massachusetts regulations. The Massachusetts
Fire Prevention Regulations will apply to the handling and
removal of the underground storage tank.
Because these activities are taking place in a wetland, the CWA
Section 404 and the Massachusetts Wetlands Protection Act are
ARARs. The Wetlands and Floodplains Executive Orders must also
be considered. The CWA and wetland protection regulations and
policies are an ARAR because the remedy will result in the
disturbance and temporary loss of areas classified as wetlands.
The unavoidable impacts to these resource areas will be mitigated
to the maximum extent possible and following such activities, a
wetland restoration program will be implemented.
Incineration of the contaminated soil will be conducted
consistent with EPA's off site policy.
Massachusetts' air pollution control regulations are ARARs in
regulating particulate air emissions from construction and
excavation activities. Additionally, the Massachusetts draft
Allowable Ambient Levels (AALs) will be considered.
RCRA requirements that are applicable or relevant and appropriate
to the decontamination and dismantling of existing tank storage
and incinerator facilities will be met by this alternative.
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ACTION-SPF.CIFIC ARARS FOB ALTERNATIVE SC-5:
ON-SITE THERMAL AF.RATIOM OF VOC WASTES/OFF-Sin INCINERATION OF PCS AND PAH WASTES
CEC SITE. RRIOCEVATKR, MASSACHUSETTS
ARAKS
REQJJIRF.MENT SYHOPSIS_
CRA - Standard* (or Owners and Operators o
I Permitted Hazardous Waste Facilities
tO CFR 266.10-266. 18)*
"CRA - Preparedness and Prevention
40 CFR 266.10-266.3I)>
:CRA - Contingency Plan and Emergency
•rocedures (60 CFR 264 50-266.56)'
:CRA - Manifesting, Recordkerping, and
^porting (60 CFR 266.70-266.77)'
:CRA - Groundwater Protection (60 CFR
'66.90-266.109)'
:CRA - Location Standards (60 CFR
266.18)'
KCRA - Closure and Post-closure (60
;tR 266.110-266.120)'
General f.uility requirements outline
general w.iste analysis, security measures.
inspect ion» , and training requi regents .
This regulation outlines requirements for
safety equipment and spill control.
This regulation outlines the requirrments
for emergency procedures to be usrd following
explosions, firrs, rtc.
This regulation specifies the recordkeeping
and reporting requirements for RCRA
facilities.
This regulation details the requirements
for a grounnvitcr monitoring progr.im to
be installed at the site.
This regulation outline* the requirements
for constructing a RCRA facility on a
100-year floodplain.
This regulation details the specific
requirements for rlnsiirr and post -c l;>s,ure
of hazardous waste fjcilities.
RCPA - 60 CFR 268 EPA Regulations
Land Disposal Restrictions'
RCRA-Interim Status
Standards - Closure of
Tanks and Incinerator
(60 265.197 and 265.151)'
o This regulation oillinrs l.ind disposal
rrqutremenls and restrictions for hazardous
wastes.
These regulations detail requirement! for
closure of the CEC site as an interim status
facility, specifically, for the tanks and
the incinerator.
ACTION TO BE TAKF.N TO ATTAIN ARARS
During all sitr work, a waste analysis: plan must he written
jnd maintained nit-site. Entry to site must he prevented by a
26-hour surveillance system and appropriate signs posted. A
written inspection program must be developed, and jll workers
properly trained.
Safety and communication equipment will be installed at the site;
local authorities will be familiarized wits) the lite, and drums
will he stacked and stored to maintain required aisle space.
flan* will he developed and implemented during remedial design.
Copies of the plans will be kept on-lite.
Records of facility activities will be
remedial action.
isiatained -luring
A groundwater monitoring program will be designed, installed, and
open ted to assess groundwater contaminant migration.
A facility located on • 100-year fl»odpl*in suit be designed,
constructed, operated, and maintained to prevent washout of any
h-iz.ir'lous waste by • 100-year floodf unices waste may be removed
safely before floodwater can reach |he facility or no adverse
effect* on human health and the environment would result if
washout occurred.
Since there will be substantial removal of waste; residual
cont.ifin.it ion will have low mobility and toxiclty; pathways
of potential exposure will he limited; and long-term monitoring
will he provided, this alternative will meet proposed alternate
closure. A notation on the deed to the property must be
recorded that will notify any potential purchaser that the {and
has bren used to manage hazardous watte.
Cnnl.mnn.it"! soils will he treated £o the Best Demonstrated
Avail.iMe Technology levels before being placed or replaced
on the I .in I. Hazardous watte cannot be stored except for
.ir« iin|iljl ion for recovery, treatment, or disposal. Thermal
jeration and incineration will meet treatment st.ind.irds.
Alt hazardous waste and hazardous waste residues must be removed
from the tanks, discharge control equipment, and discharge con-
finement structures. All hazardous waste and hazardous waste
residues must he removed from the incinerator. These regulations
are -«p|il ir*hle to the closure of the CEC site a* an interim status
f4t it ity . '
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Vl-J
AcnoN-speciric MAM rot ALTCI^MC ST.-S:
Mi-Sin THERMAL AERATION Of VOC tMSTtS/OfT-Sin INCrlPuUION Of PCI AND PAN WASTES
CCC SITC. MIDCEUATCR. MASSACHUSETTS
page 42 (b)
ARAM
REQUIRfJCNT SYNOPSIS
ACTION TO U TAKEN TO ATTAIN ARAKS
^ - Narking of PCI* and PCS I tens
CPR 74l.40-HI.J9)'
A - Storage and Disposal (40 Ct"R
A - Record* and Report* (40 CFR
.11-161.IIS)1
SO ppoi PCI storage area*, storage items,
and transport equipment must he marked
with ike N, mark.
Thi* requirement specific* tke require*
•rut* for «tora|e and disposal/destruction
•f PCI item* in eicess of SO pp«.
TKii regulation outline* thr re^uire-
•«nt* for recordkrrpint for *tor-t|e and
and di*poaal of >%0 pp» PCt iteaia.
All *tor«(<* «r>>a». dr««M, and tra«*port e*j«iB«rNi will carry tn»
appropriate o^rking* di*playc-l in an eacily ceadaklr poaltion.
Storage area* for druaw containing PCI *oll» in eiice** of SO pp«
will ke conitrncted to coojply wltk this req«»|re«ent. Tke«e PCI-
contaoiinated *»il* would have to ke dltpoaed of or treated In a
facility peraitted for PCIa, in covpltance wltk TSCA regulation*.
Treato>pnt *Mi*t ke performed oaing incloeratloo. or »oo« otker
•ethod with equivalent destruction efficiencies. Verification
of incinerator compliance wilt ke made prior to 4rMo> (Hipaent.
Record* will ke ••intained during reewdlal action, in c
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ACTION-SPECIFIC ARABS FOR ALTERNATIVE SC-5:
ON-SITC THERMAL AERATION OF VOC WASTES/OFF-SITE INCINtRATIOH OF PCI AND PAN WASTES
CEC SITE. RRIDCF.WATER, MASSACHUSETTS
r—:f— •- »~»
ARARS
T Army Corps of Engineers
ationwide Permit Program
3 CFR 330
ish and Wildlife
nordination Act (16 U.S.C
61)'
loodplaini Executive Order (11188)'
'etlinds Executive Order (11990)'
•EQE - Wetland* Protection (310 CHM
0.00)
IEQC - Air Quality Air Pollution
(310 CMR •.00-1.00)
REQUIREMENT SYNOPSIS
Thil regulation states that no alternative
that impacts a wetland shall be permitted
i( there is a practicable alternative
that has lets impact on the wetland.
If there it no practicable alternative.
impact* oust be mitigated.
Thi* regulation require* that any federal
agency proposing to modify a body of
water must consult with the U.S. Fish and
Wildlife Service*. This requirement is
addressed under CWA Section t04
requirements.
This res.ul.ition states that federal
agencies shall reduce the risk of flood
loss, minimise the impacts of floods on
human safety, health, and welfare, and
restore ami preserve the natural and
beneficial value* .served by floodplaio*.
This regulation states that federal agencies
•hall minimize the destruction, loss, or
degradation of wetlands, and preserve and
enhance the natural and beneficial value* ef
wetland*.
n This requirement regulate* work within
100 feet of a wetland. This regulation
define* the wet area j« « wetland baaed
on vegetation types. Impart* to wetland*
must he mitigated.
Tki* regulation specifies dust, odor.
•ad noise emissions fro* construction
•cttvltle*.
ACTION TO BF. TAKF.N TO An A IN ARAKS
Following excavation of contaminated soils, • wetl.ind will be
rrrjted in the wet area hy placement of clem soil* (if
necesssry), and graded to a 60-foot elevation followed by
revegetslion. The excavated portion of the wooded swamp
will be backfilled to original grade and rcvegetated.
Potential impacts associated with erosion, sedimentation, and
resuspension of sediment* will be mitigated by closing the
ditch draining the wet area by using hay bales, silt curtains,
or other erosion, resuspension, and sedimentation control
measures.
During the identification, screening, and evaluation of
alternative*, the effect* on wetland* are evaluated. If an
alternative modifies a body of water, EPA must consult the
U.S. Fish and wildlife Service*.
Excavation of contaminated soils in the wooded swamp, and
possibly the wet area, may occur In the 100-year flnodplain.
Wetland replacement of these areaa will restore the floodplain
to its original site. Grading of the wet area tn an elevation
of 60 feet following excavation and backfilling (if necesssry)
will actually increase the sue of the floodplain.
Following excavation of contaminated foil* and completion of
remedial activities, • wetland will be created in the wet
area hy placement of clean soil* (if necc***ry) and grading to
a 60-foot elevation followed hy revegetatlon. The excavated
portion of tbe wooded awamp will be backfilled to original
grade and rrvegelated. Potential impact* associated with
erosion, sedimentation, and re*uspen*ion of sediments will be
mitigated by closing the dtti.h draining the wet are* by using
hay bales, siK rurtalna, or other erosion, resuspension,
and sedimentation1 control measure*.
Any person who proposes to do work that will removr, fill,
dredge, or alter a wetland must flic a Notice of Intent. A
public hearing will bt held anil the conservation commission
will make a decision and may issue an order of conditions.
A Notice of tnlenl trust demonstrate that the proposed work
will contribute to protection nf thi wetland.
Fugitive dust will °* controlled by water ipray* or dust
suppressants. All equipment will he maintained so as not to
produce excessive aolse.
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ON-SITt TKRNAI
ACTION-SPECIFIC AJWRS FOR
AERATION OF VAC WASTIS/OFF-SI
CEC Sin. MIKEWATER,
STMOTSIS
page
iTIVI SC-S:
INERATION Or PCR AM PAN MASTCI
MQC - Naiardow* Vaite. Phase* I and II
(110 CNR 30.00)
Naiardou* Watt* Facility Sit* Safety
Council (990 CMI I.OO-lft.OO)
DOT Rule* foe the Transportation
of Ratardou* Material* (49 CFR
101. IM I-III.JOO)1
a Ha**arhu*ett* Fire
Prevention Regulation*
CNR 9.00-Tank*)
Tt»«*e regulation* provide a comprehend ve
pr«|ra« for handling, •torjge. and
«t h.*c*r>lou* wa*te *ite*.
Thl* refMlalion outline* the procedure*
fee eatakl titling a hjsardou* wa*te facility
in Ha***chu*etta.
The*e regulation* specify the Barking*,
vehicle reglatralton. •jnifett, and
transportation re>|uire«ient* for hazarilou*
watte chenical*.
Thl* regulation jpplie* to the
construction, installation, toting, and
awintenance of tank* and container*, and i*
intended to protect the public safety and
welfare.
ACT KM TO 1C TACT.B TO
During reowalial dealgn. theae rcgul*tio«* will be co*p*red to the
corre*po*ling federal ICRA regnlatl*4lt). and the amre itrtngent
reiulreawnt* will W applicable.
A Notice of Intent *u*t he filed with MQC mitlining the
proposed location and o>ay he u«e*1 to Inform the public of the
facility.
Waste *Ni*t he properly cla**ifie4, packaged, awnlfeited, atarkeit,
and labelled, and (Mat have regi*tratio« number* including the
tetter* DOT.
Thi* regulation applie* to re«e4i«l actioa operation* Involving
tank evptying, cleaning, removal, dlwnantling. and ditpoial
procedure*.
Massachusetts Superfund Law
(MGL Chapter 21E)
1. Applicable
2. Relevant and Appropriate
3. Tb be Considered
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ACTION-SPECIFIC ARABS FO* ALTERATIVE MM-I:
HINIHAL NO-ACTION
CtC Sin. iRIDGF.WATER. MASSACHUSETTS
ARABS
REQUIREMENT SYNOPSIS
ACTION TO BE TAKEN TO An A III ARABS
RCRA - Standards for Owner* and
Operator* of Permitted Haxardou* Waste
Facilities (40 CIH 26*.10-264.li)1
RCRA - Preparedness and Prevent-
ion (40 CFR 264.30 - 264.37)1
« RCRA - Contingency flan and
Emergency Procedure* (40 CFR
264.50 - 2J4.56)1
o RCRA - Manifesting. Recordkeeping, and
Reporting (40 CFR 26*.70-264.77)'
o RCRA - Croundwater Protection (40 CFR
264.90-264.109)*
o General facility requirements outline general w*»te Jn.ilyji*.
security measures, inipections, and training requirement*.
o Thi* regulation outlinri requirement* for safety
and opitl control.
o Thi* regulation outlines the requirement* for
emergency procedures to be used following
explosions, fires, etc.
o Thi* regulation specifies the recordkeeping and reporting
requirements for RCRA facilities.
o Thi* regulation detail* the requirement* for a grounjwater
monitoring program to be Installed at the site.
o RCRA - Closure and Post-closure (40 CFR o Thi* regulation detail* the specific requirement* for closure
264.110-264.120)' and post-closure of hazardous waste facilities.
9 OSHA - General Industry Standard* (29
CFH 1910)*
o Thi* regulation specifies the H-hour, time-weighted average
concentration for vsnous organic coapeuade «nd two PCB
compounds.
o OSHA - Safety and Health Standards (29 o Thi* regulation spectlin the type of safety equipment mil
CFR 1926) procedures to be followed during site i emedlit. ion.
o OSHA - Recordkeeping, Reporting, and
Related Regulations (29 CFR 1904) •
o DEQC - Hazardous Waste. Phases I and
II (310 CNR 30.00)
Massachusetts Superfund
Law (MGL Chapter 2IE)
Thi* regulation outline* the rccordkeeping and reporting
requirement* for an employer under OSHA.
These regulation* provide a comprehensive program, for
monitoring, storing, and recordkeeping at hazaiiloxs w.isto
sites.
n Facility will he constructed, fenir-1. pnsted.
.in|uirrmenli
will bu ap|illi ihle.
1. Applicable
2. Relevant and Appropriate
-------
ROD DECISION SUMMARY page 44
Cannons Engineering Corporation Site
3. Cost-effectiveness and Utilization of Permanent Solutions and
Alternative Treatment Technologies or Resource Recovery
Technologies to the Maximum Extent Practicable
The selected remedy offers the best combination of effectiveness,
implementability, and cost in comparison with the other
alternatives that provide the same level of protection. The
selected remedy is consistent with section 121 of CERCLA and
satisfies the statutory preference for a permanent solution and
for treatment which reduces the mobility, toxicity or volume as a
principal element. Additionally, the selected remedy utilizes
permanent solutions and alternate treatment technologies to the
maximum extent practicable.
This remedy satisfies the statutory preference for treatment as a
principal element. The principal element of the selected remedy
is the source control portion of the remedy. The principal
threat at the site is due to the contamination in the soils. The
selected remedy will treat the contamination by two treatment
technologies: Thermal Aeration and Incineration. Thermal
aeration is proven treatment technology that will provide a
permanent solution to the VOC contamination at the site by
reducing the concentrations of VOCs in the soils to target
cleanup levels which are protective of human health and the
environment., This technology, however, is not effective at
treating PCBs. Soil incineration is a proven treatment
technology that will provide a permanent solution to the PCB
contamination at the site by reducing the concentrations of PCBs
in the soils to target cleanup levels which are protective of
human health and the environment.
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. 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. Therefore, in choosing among
alternatives, the difference in the remaining criteria, namely
short tern effectiveness, long term effectiveness,
implementability, use of treatment to permanently reduce the
mobility, toxicity and volume, and the cost were the focus of
the evaluation, while the nontechnical factors that affect the
implementability of a remedy, such as state and community
acceptance, also were considered. Because the evaluated
alternatives are not equal in all aspects of the evaluation
criteria, the cost effective remedy is identified as the remedy
that represents the best balance among the evaluation criteria.
The following alternatives were carried through the detailed
-------
ROD DECISION SUMMARY page 45
Cannons Engineering Corporation Site '
analysis but were not selected for the reasons noted.
The first source control alternative, Alternative SC-1, minimal
no action, would not protect human health and the environment
from the risks presented by contaminated soils and does not
attain ARARs. Moreover, some form of source control is necessary
to reduce further contamination of groundwater at the site.
Alternative SC-3, solidification and on site landfilling, is
protective of human health and the environment and could be
constructed to attain ARARs, however; this alternative does not
utilize a permanent solution and an alternative treatment
technology to the maximum extent practicable. The major negative
factor associated with landfilling is the fate of residuals
remaining. This alternative reduces the mobility as the wastes
remain in place but there is no reduction in toxicity or volume.
Essentially, this alternative would create a permanent land
disposal area. In addition, the long term effectiveness of
landfilling is dependent in part on monitoring to determine
whether the landfill is effective in preventing migration of-
contamination and on the long term integrity, and if necessary,
taking future maintenance and corrective measures. Finally, the
potential for failure in the future and need for replacement
exists over a long period of time.
Alternative SC-4, solidification and off site landfilling, pose
similar concerns as SC-3. Additionally, Section 121 of CERCLA
states that off-site disposal is the least favored alternative.
The Agency's policy to select on site response actions over off
site land disposal actions.
Alternative SC-6, on site incineration, would protect human
health and the environment by treating the soils as effectively
as the selected source control. It utilizes permanent solutions
and alternative treatment technologies to the maximum extent
practicable and would attain ARARs. However, this alternative
does not offer greater protection to human health or the
environment than the selected remedy, and it is significantly
more expensive. Therefore, incineration on site is not
considered to be the most cost effective source control.
Alternative SC-7, off-site incineration, would protect human
health or the environment and will attain ARARs. However, it is
far more expensive than the selected remedy and does not offer
additional protection of human health and the environment.
Therefore, this alternative is not considered to be cost
effective.
The selected management of migration portion of the preferred
alternative is MM-1, no action with monitoring. This alternative
-------
ROD DECISION SUMMARY page 46
Cannons Engineering Corporation Site
will involve restricting the use of groundwater at the site and
instituting a water quality monitoring program. Additional
monitoring wells will be installed on site and to the south of
the drainage canal. Selected monitoring wells will be sampled on
a routine periodic basis to evaluate the concentration of the
contaminants in the groundwater and to evaluate the dispersion of
the contaminants, if any.
This alternative will be protective of public health because the
groundwater is not a current source of drinking water. It will
attain ARARs for groundwater over a period of time as natural
attenuation dilutes and disperses the contaminants. This
alternative is effective and very easy to implement. It is the
most cost effective because it is as protective as all the other
management of migration alternatives and is the least expensive.
The pump and treat groundwater remedial alternatives (MM-2, MM-3,
MM-4, and MM-6) involve extracting groundwater for on-site
treatment.
Two different pumping scenarios were developed for each of the
management of migration alternatives. A range of extraction
efficiencies was considered for the two pumping scenarios.
Depending on the configuration of the pumping system and the
extraction efficiency, the time to effectively pump and treat the
groundwater will vary. Additionally, each alternative uses a
different treatment technology. Each treatment- technology,
however, is equally as effective in treating the groundwater.
Installation of the wells could be easily implemented. However,
certain hydrogeologic conditions, the contaminant properties, and
the level of contamination limit the feasibility of drawing water
from the aquifer for treatment. The difficulties of extracting
sufficient water volumes diminishes the effectiveness of the
groundwater pumping system and increases the technical difficulty
of extracting organic compounds from the groundwater.
Additionally, the site studies show only limited portions of the
shallow groundwater are contaminated at levels that slightly
exceed ARARs. Considering these factors, the timeframe necessary
to achieve the groundwater goal would be similar to that of
natural attenuation. Therefore, this alternative does not offer
more protection to human health or the environment when compared
to the management of migration portion of the selected remedy,
and it is significantly more expensive. Thus, pumping and
treating the groundwater is not considered to be cost effective.
Table VI-5 presents the capital and O&M costs for the source
control portion of the selected alternative. Table VI-6
presents capital costs, operation and maintenance costs, and
present worth costs over a period of time for the management of
-------
page t/va>
COST ESTIMATE FOR
ALTERNATIVE SC-5: ON-SITE THERMAL AERATION OF VOC WASTES/
OFF-SITE INCINERATION OF PCB AND PAH WASTES
CEC SITE, BRIDGEWATER, MASSACHUSETTS
COST COST COST
ITEM
I. CAPITAL COSTS
A. Mobile Lab
B. CLP Verification (201
of samples)
C. Decontaminate Concrete,
lion-Concrete Surface!
0. Decontaminate and Rate Tanks
E. Raze Tank Farm Bldg.,
Ready Bldg. , Incinerator
Bldg., Drainage Vault,
and Resurface Equipment
Bldg. Concrete Slab
F. Excavate Soils (Level C)
G. Collect and Treat Ponded
Water from Wet Area
H. Thermal Aeration of VOCa
o Low End Estimate
($180 cu yd)* .
o High End Estimate
($250 cu yd)*
I. PCB, PAH Treatment
o Low End Estimate***
o High Ead Estimate****
J. Restore Disturbed Areas
10*s Target
$ 105,000
46,000
57,000
250,000
126,000
12,000
8,000
650,000
787,000
10*» Target
$ 162,000
56,000
57,000
250,000
126,000
18,000
12,000
899,000
1,089,000
(Constant volume of 325 cu.
VOC target levels)**
424,000
733,000
$ 45,000
424,000
733,000
$ 69,000
10"7 Target
$ 242,000
76,000
57,000
250,000
126,000
26,000
18,000
1,102,000
1,414,000
yd. for all
424,000
733,000
$ 102.000
Total Capital Costs (Low End) $1,723,000 $2,073,000 $2,423,000
Total Capital Costs (High Ead) $2,169,000 $2,572,000 $3,044,000
-------
TABLE VI-5 (continued)
COST ESTIMATE FOR
ALTERNATIVE SC-S: ON-SITE THERMAL AERATION OF VOC WASTES
OFF-SITE TREATMENT OF PCB AND PAH WASTES
CEC SITE, BRIDGEWATER, MASSACHUSETTS
ITEM
COST
COST
COST
10** Tartet 10** Tartet IP*7 Tartet
ZZ. CONTINGENCY (25%)
o Low Ead Eatisate
o High Ead Estimate
ZZZ. TOTAL PRESENT WORTI
• Low Ead Eatisute
o High Ead Eatiaute
$ 431,000 $ SIS,000 $ 606,000
542.000 643.000 761.000
$2.154.000 $2.591.000 $3.029.000
$2.711.000 $3.215.000 $3.805.000
* Processing costs based oa cose* to treat soils at McKia sitt (Maiae).
Volusw of *oil» with PCBs aad PAHa held coastaat for different VOC
target levels; 325 cu. yd. represents PCB aad PAH conceatratioaa of
9 aad 3 ppa, respectively (see discussioa ia text Sectioa 7.2.5.2).
Eatails iaciaeratiag soils with PCBs >50 ppa aad solidifyiag/laadfilliag
soils with PCBs <50 pp«, >9 ppa aad PAHs >3 ppa.
***+ Eataila iaciaeratiag soils with PCBs >9 ppai aad PAHa >3 ppa.
NOTE: The 10~5 Target Oolxim was used to estimate the cost of the
Source Control portion of the Selected tetedy.
-------
TABLE VI-6
COST ESTIMATE FOR
ALTERNATIVE MM-1: MINIMAL NO ACTION
CEC SITE, BRIDGEVATER, MASSACHUSETTS
I. CAPITAL COSTS
A. Design and Project Planning $ 18,500
B. Monitoring Well Installation - 7 new wells 15,000
C. Institutional Controls - Legal Restrictions 10,000
D. Contingency (251) 10,900
TOTAL CAPITAL COSTS: $ 54,400
II. ANNUAL OPERATING COSTS
A. Monitoring (Years 1 and 2 -
quarterly Monitoring program)
Sampling (including labor, travel, equipment) $ 22,700
Analyses 124,800
Monitoring (Years 3 through 10 and
every other year thereafter - annual
monitoring program)
Sampling 4,475
Analyses 25,200
B. Monitoring Management/Oversight/Reporting
Year* 1 and 2 16,000
Years 3 through 10 and every other
year thereafter 8,000
C. Equipment Repair (per year) 1,000
D. ttiscellaneouc Legal Work (per year
foe Yean 1 through 10) 2,000
E. Public Education Costs (per year
for Years 1 through 10) 2,500
III. PERIODIC EXPENDITURES
A. Five-year Site Review (cost per review) $10,000
-------
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-------
ROD DECISION SUMMARY page 49
Cannons Encrineerliter Cornoration
migration alternative. Supportive data for the cost estimates
are presented in Appendix F of the Feasibility Study.
D. Conclusion
Based on information available in the Administrative Record and
the evaluation of the alternatives against the statutory re-
quirements of CERCLA, the NCP, and the criteria contained in
OSWER Directive 9355.0-21, EPA has concluded that the selected
remedy is protective of human health and the environment,
attains all applicable or relevant and appropriate requirements
and is cost-effective. This remedy also satisfies CERCLA's
preference for remedies which employ treatment as their principal
element to reduce the volume, toxicity or mobility of hazardous
substances at the Site.
Although this remedy will require measures to control possible
risks related to its construction and operation, the Agency's
analysis indicates that all of these risks can be satisfactorily
controlled. Additionally, any short-term risks appear heavily
outweighed by the long-term effectiveness and permanence this
remedy will provide. The Agency believes this remedy will result
in a permanent solution to protect the public health and
environment resulting from the contamination of the Site and
utilizes alternative treatment technologies to the maximum extent
practicable.
VII. STATE ROLE
The Commonwealth of Massachusetts Department of Environmental
Quality Engineering (DEQE) has reviewed the various alternatives
and has indicated its support for the selected remedy. The DEQE
has reviewed the Remedial Investigation, Endangerment Assessment,
and Feasibility Study to determine if the selected remedy is in
compliance with M.6.L. c 2IE and is in compliance with other
applicable or relevant and appropriate State environmental laws
and regulations. The Commonwealth of Massachusetts concurs with
the selected remedy for the Cannons Engineering Corporation (CEC)
Bridgewater site. A copy of the declaration of concurrence is
attached as Appendix C. In accordance with Section 104 of
CERCLA, the Commonwealth of Massachusetts is responsible for 10
percent of the cost of the remedial action. In the case of the
selected remedy, the Commonwealth's share is estimated at
approximately $ 340,000.
-------
APPENDIX A
RESPONSIVENESS SUMMARY
-------
EEA Hack AasigrnEnt No. 103-1147
WO9SED FOR IBB
U.S. ENVHCtMQfEKL HfJUBUTlOf
KOaluf I
BOGIGN,
Stl
trad by th» KEM m Ptcrjact
under EE& QjiUact No. 68-01-7250
-------
TABLE OP
Page
PREFACE 1
I. BACKGROUND ON COMMUNITY INVOLVEMENT AND CONCERNS 3
II. SUMMARY OF COMMENTS RECEIVED DURING THE PUBLIC COMMENT PERIOD
AND EPA RESPONSES TO THESE COMMENTS 5
A. Determination of Soil Cleanup Levels
1. Bias in the Sampling Program 6
2. The Exclusion of Non-detectable (ND Values and
Inclusion of Duplicates Resulted in Overstated
Mean Contaminants levels 7
3. Failure to Factor Limited Spatial Distribution of
Contamination in the Endangerment Assessment 7
B. Incineration Requirement for Soils 9
1. Contaminant Levels Requiring Incineration 9
2. Cost-Effectiveness of Incineration 10
3. Alternative Approaches for Disposal of PCB-Contaminated
Soil 11
C. Treatment of VOC-Contaminated Soil 12
1. Cost Estimates for Treatment 12
2. Alternative Approach: Biological Treatanent 15
3. Alternative Approach: Asphalt Batching. 18
D. Remediation of Building and Structures. ........... 20
E. Ground Water 22
in. REMAINING CONCERNS 24
ATTACHMENT A - COMMUNITY RELATIONS ACTIVITIES CONDUCTED AT
THE CANNONS ENGINEERING CORPORATION SITE 26
-------
Htm U.S. Environmental Protection Agency (EPA) held a public
period frcD February 11, 1988 to Match 4, 1988 to provide an opportunity for
interacted parties to umuieuL on the January 1988 draft Feasibility Study (FS)
and Pinjueed Remedial Action Flan prepared for the Cannons Engineering
Corporation (CEC/Bridgewater) Superfund sit* in Bridgewatar, Massachusetts.
The FS examines and evaluate* various options, called remedial alternatives,
for addressing contamination at the site. EPA identified its preferred
alternative for the cleanup of the site in the Proposed Remedial Action Plan
issued at the start of the public cement period.
The purposa of this responsiveness summary is to document EPA
to the comments and questions raised during the public comment period. EPA
will consider all of the comments summarized in this document before selecting
a final remedial alternative for the Cannons Engineering Corporation Superfund
sit* in Bridgewatsr, Massachusetts (CEC/Bridgewatsr site).
This responsi
summary is divided into the following sections:
I* Pflldmr^urc^ cti QoBiHunitv Involvement and OnQQerns • This section
provides a brief history of community interests and concerns
• This section summarizes both
written and oral comments received from the public during the public
-------
2
conment period and provides EEA responses to than. These comments
are organized by subject area.
Remain ^ TXT Concerns — This section describes !».«?» M>g that nay continue
to be of concern to the connunity during the design and
implementation of EPA's selected remedy for the CEC/Bridgewater
site. EPA needs to address these concerns during the Remedial
Design and Remedial Action (RD/RA) phase of the cleanup process.
Attachment A - This attachment includes a list of the community relations
activities that EPA conducted at the CEC/Bridgewater site during the
remedial activities at the site.
-------
I. BACR3OQND CN OCMfMTDf XNVQDVEMQfT AND CQNCEflNS
Through the site's history, ocnnunity concern and involvement has bean
low to moderate. However, sinoa tha site's listing on tha NFL, ana citizen's
group, Bridgewater Aware, has remained actively intarastad in activitiaa
occurring at tha sita. EPA has kapt this group and other interastad partias
informed through informational meetings, fact sheets, news releases, and
public meetings.
in 1982, EPA released a community relations plan which outlined a program
to address community concerns and keep citizens informed about and involved in
activities during remedial activities. On November 15, 1983, EPA held an
*
informational meeting in Bridgawatar to describe the plans for the RI/FS. In
July 1984, EPA issued an information sheet updating the community on the
progress of the RX. On May 27, 1987, EPA held an informational meeting to
present the results of the draft RZ and to answer questions from the public.
On February 11, 1988, EPA held an informational meeting to discuss the
cleanup alternatives presented in the IS and to present the Agency's Proposed
Plan. Also during this meeting, the Agency answered questions from the
public. Iron February U to March 4, 1988, the Agency held a three weak
period to yj'-'ti.1*. public connent on the alternatives presented
in the FS and Proposed Plan and on any other documents previously released to
the public. On February 25, 1988, the Agency held a public hearing to accept
any oral comments* A transcript of this meeting and agency responses to
nts are included in this document.
-------
4
At these public meetings, citizen inquiries about EPA activities at the
site generally focussed on the cleanup costs and schedule, and EPA enforcement
actions. Citizens also were interested in discussing the extent and results
of EPA sampling and testing activities. Citizens expressed specific con
about potential health risks posed by exposure to site contaminants, whether
EPA has plans to fence the site, and about the on-site storage of chemicals in
the site equipment building.
-------
H. SQMBRY OF OCMME2HS RECEIVED DURING THE PUBLIC CCM4ENT HdUXJU MID EPA
CDMEtXCS
This responsiveness summary add my leu the written comments received by
EPA concerning the draft ES and rixyjoneJ Plan for the Cannons Engineering
Corporation Superfund site (CEC/Bridgewater site) in Bridgewatex,
Massachusetts. There were no formal oral comments presented at the February
25 public hearing, but the question-and-answer period that followed is
recorded in a transcript of the hearing. Copies of the hearing transcript are
available at the information repositories located at the Bridgewater Public
Library, and the EPA Region I office in Boston, Massachusetts.
EPA received one set of written comments from a PRP on the FS and
Proposed Plan. The written comments are summarized and organized into the
following categories:
• A. Determination of Soil Cleanup Levels
B. Incineration Requirement for Soils
C. Treatment of VDC-Oontaminatad soil
0. Remediation of Building and Structures
E. Ground Water
EPA responses are provided for each eminent, or set of like comments.
-------
6
A. DLTJhiKMDPVnON OF SOIL PTr&NTTP
1. Biag in the Sampling Rroq
nt: The commenter stated that the design of the soil sampling
program, as described in the PI, was biased toward high positive results.
The reasons given by the commenter for the bias were: (1) fron each
grid, samples were taken where there was visible contamination or, if no
contamination was visible, the grid center was sampled, and (2) only
those sanples which screened positive in the field were sent for
laboratory analysis. The cuiimenter felt that it was not appropriate to
vise these data to represent average site conditions.
Response: The field sampling program for the CEC/Bridgewater site is
typical of most Superfund sites. A grid sampling design is used to
determine the extent of contamination on a site because contamination may
be present, but not visible, in soil. The objective of field sampling is
to characterize the extent and limits of contamination. Sampling at
regular intervals is performed to characterize a site as fully as
possible within reasonable cost. To implement a cost-effective sampling
program, grid samples that show visible contamination and/or screen
positive in the field are targeted for chemical analyses. EPA and its
contractors recognize that field sampling data may be biased toward the
positive. This is necessary to avoid overlooking contamination at a site
and to provide for cost-effective field progrc
-------
2.
The
with
aspects of the methods UMd
to compile the laboratory data for us* in the Bidangexment A»nismsnt..
In particular, the cannenter fait that failure to incorporate ND valuta
into the mean resnltert in artificially high values of average contaminant
concentrations and that the use of duplicates in calculating means was
unacceptable. The conmenter stated that duplicate samples are collected
•
solely for assessing the reproducibility of results and should not be
used in the calculation of means. The conmenter concluded that these
procedures overestimate mean contaminant concentrations.
Response; The use of ND values would not change the remedy selected for
the site. RI sampling data are compiled in various ways for use in
Super-fund risk assessments. There is no single "right way" to summarize
such data. The inclusion of ND values into the calculation of means does
not significantly alter mean contaminant concentrations for the site.
Furthermore, the inclusion of diiplimten in the calculation of average
contaminant
the
ntrations would not significantly change the value of
3.
Vfeilu
to Vfeetor T4m
Snatial
in
eminent.! The
nter stated that the Brtangerment ft iimniiaiil failed to
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consider the heterogeneous spatial distribution of contaminants on site
and that this further contributes to the overestination of risk at the
site. The exclusion of the ND values in the calculation of mean
contaminant levels and the lack of consideration of the probability of
contact of human receptors with contaminated soil are cited as reasons
for overestimation of risk.
Response; The impact of exluding ND values in the calculation of mean
contaminant levels has already been discussed. The use of statistical
methods to assess the probability of direct contact in assessing risks at
Superfund sites is not routine. The approach taken in the
CEC/Bridgewater Endangeiment Assessment is consistent with EPA Region I
standard procedures for assessing direct contact hazards. The use of
statistical methods that assume random behavior to assess the probability
of direct contact may be inappropriate given the non-random nature of
human behavior.
While the Endangerment Assessment developed upper and lower bounds on
risk, it did not specifically address the variability in distribution of
surface soil contaminants. However, the spatial distribution of soil
contaminants at the CEC/Bridgewater site was considered in the evaluation
of remedial alternatives and the selection of the remedy.
Finally, as the commenter indicates, different exposure assumptions will
result in different outcomes of incremental risk. However, EPA adopted
exposure assumptions to realistically reflect exposure scenarios which
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hav» a reasonable likelihood of occurring.
B. mgrNEBATICH RBgnREMBfT FOR SOUS
1.
i The TS is incorrect in stating that soils containing FCBs in
excess of 50 pen most be «ti TT""f ^ of by incineration. TSCA (40 CER
761.60 - 761.79). TSCA (40 OR 761.60, a. (4) states that, "Any ncn-
liquid FOBS at oonosntrations of 50 ppm or graatar in the form of
oontaminatsd soil, rags or othar dabris shall ba dlqp-mer! of:
(i) In an incinarator which cenplias with 761.70; or
(11) In a chemical wast* landfill which oonplias with 761.75.
Tha FS did not stata that tha only way to raosdiata soils
containing PCBa in axoass of 50 ppn was by incinaraticn. Tha FS
indicates in tha screening of alternatives that wastes with PCBs greater
than 50 ppn nay be treated by incineration or landf illad at a TSCA-
approved facility. It further indicates that TSCA regulation would be
net by using incineration to treat soils with PCBs greater than 50 ppm.
Alternatively, theae soils could be landf illad without treatment at a
permitted facility." See p. 6-5, Feasibility Study.
Additionally, in the detailed analysis section of tha FS where actions to
ba taken to attain ARARs are discussed, the FS indicates PCB-
contaminated soil in excess of 50 ppa . . . "would have to be rtl airff** of
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or treated in a facility permitted for FGBs, in compliance with TSCA
regulations." See p. 7-73, Feasibility Study.
2. Post-Effectiveness of Incineration
OuuiineiiL; Incineration of PCB-contaminated soils is not a cost-effective
remedy. Inasmuch as PCBs are highly immobile when mixed with fine
grained soils, the level of contamination is low, the regulations do not
require incineration, and the cost of incineration is extremely high, it
does not appear that incineration is appropriate to this situation. The
commenter suggests two alternative approaches to off-site incineration of
the PCB-contaminated soils. First, the PCB-contaminated soils could be
disposed of in a TSCA-permitted land disposal facility, which should be
adopted as the preferred alternative in the BOD. Second, the soils could
be dechlorinated by potassium/polyethylene glycol similar to the Resolve,
Inc. site, which should be considered as an alternative to landfilling in
the ROD.
Response; The Agency selected off-site incineration of PCB-contaminated
soils as the alternative that best meets the cleanup standards of CERCXA.
The target cleanup levels of PCB-contaminated soils are designed to
provide a protective remedy. Incineration of the contaminated soils will
provide a permanent solution and utilize an alternative treatment
technology to reduce the mobility, toxicity, and volume of the wastes.
CERCXA Sec. 121 (b) states that the off-site transport and disposal of
contaminated materials without treatment is the least favored
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alternative.
Additionally, incineration is cost-effective because it represents the
best balance among the remedy evaluation criteria: protection of human
health and the environment, overall compliance with ARARs, reduction of
nobility, toxicity, and volume, short-term effectiveness, long-tern
effectiveness, inplementability, community acceptance, state acceptance,
and cost*
3.
Qatmentt The Agency should consider dechlorination of PCS- contaminated
soils as a cost-effective treatment alternative.
Response; Dechlorination was not considered a cost-effective treataent
alternative at the site because of the estimated small volume of PCB-
contaminated soils to be treated. Ihe costs per cubic yard cited by the
commenter were developed for the Resolve, Inc. site based on a volume of
25,000 yards. It is inappropriate to assume a similar unit cost for
treating the estimated 325 cubic yards at the GEC/Bridgeuater site since
the capital costs for Resolve were spread over 25,000 cubic yards.
Furthermore, the Agency notes that the commenter asserts dechlorination
would meet a clean-up target level of 25 ppm, which would not meet the
soil remediation target level of 9 ppm for this site. Incineration will
meet the remedial response objectives for the site.
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C. U.S. EPA/S APPROACH TO TREATMENT OF VDC-OONIftMINATED SOIL
1. Post y-stinafr^s for
Qjiunent; The estimated costs of treating soils by thermal aeration are
inaccurate. The FS estimates the capital costs to be $300,000 and the
operation and maintenance costs to be between $180 and $250 per cubic
yard. Based upon an estimated 1,875 cubic yards of soil and 61 cubic
yards of demolition debris, for a total of 1,936 cubic yards to be
processed by this technique, the total unit cost would range from $334 to
$404 per cubic yard or from $650,000 to $787,000.
The commenter noted that the process may be hampered by a high water
content and the high percentage of fines in the soil. Reduction of the
water content by mixing the soils with a drying agent or by dewatering
prior to treatment will increase the unit costs for this process.
Alternatively, a reduction in the through-put rate to achieve drying in
the reactor could be considered but will increase energy costs.
Considering these factors, the commenter claims that the unit cost for
thermal aeration will likely be closer to $400 per cubic yard than to the
lower estimate.
The FS indicates that testing work will be required before using the
thermal aeration technique. However, the success of this technique
elsewhere indicates that additional testing work is not necessary.
Except for start-up testing prior to full-scale operation, no feasibility
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tasting of this technique should be required.
The proposed thermal aeration proosss is estimated to require
approximately 1/3 acre. According to the FS, this will require that the
Tank Farm Building be demolished and moved from the situ at an
estimated cost of $92,000. Based upon a sits inspection, the oomnentsr
believes that sufficient area exists on the sits without demolishing the
building.
The ocnsnenter stated that the quantities of contaminated soils targeted
for cleanup do not include an allowance for soils under the tanks and
buildings. Sines it is possible that these soils are contaminated, the
estimated quantities of soil requiring treatment will increass
significantly. Inasmuch as this may effect the methodology used to treat
the soils on the site, the sampling of these soils should be undertaken
before a final decision is made on the remedial technology to be used.
The »P Group's comments regarding alternative: approaches to
remediation of soils and buildings are premised upon inaccurats
representations of the conclusions in the FS. The particular points of
contention that the BRP Group raises with the FS are in the following
i:
(1) volumes of soil to be remediated;
(2) low temperature thermal aeration processing costs; and
(3) siting requirements for low temperature thermal aeration.
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These three issues are arMrgssPd in the following paragraphs.
The volume of soils and debris that should be used for cost estimating
purposes is approximately 3,000 cubic yards, and not 1,936 (1,935 + 61)
cubic yards, as stated in the contents. This is because the FS estimated
that, in addition to surficial soils, approximately 1,000 cubic yards
from subsurface excavation zones (around tanks and under buildings) would
also have to be treated for VDCs. Based on this volume and the FS's
estimated range of thermal aeration processing costs ($180 to $250/cubic
yard) and capital costs ($300,000), the total unit costs would range from
$280 to $350 per cubic yard, not $334 to $404, as stated in the comments.
The FS estimates of $180 to $250 per cubic yard for processing costs were
based on actual costs incurred during the cleanup of VOC- and PAH-
contaminated soils at the McKin site. Because that site represented the
first full-scale application of the technology, costs were higher than
future costs projected for application of this technology. Certain
vendors contacted during the development of the FS stated that low
temperature thermal aeration unit costs of $75 to $150 per cubic yard are
achievable with suitable site conditions (contaminants with low boiling
points; soils with low moisture and silt, contents). The soils at the
CEC/Bridgewater site have high moisture and silt contents; therefore, it
is more appropriate to utilize the McKin site costs for estimating
purposes because of the problems that had to be overcome during that job.
The thermal aeration process siting requirement of 1/3-acre stated in the
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FS is the area needed only for the processing unit. Tim FS stated that
additional area is raquirad for su^juit functions (staging, storage,
decontamination, ate. ) , and that tha entire area raquirad to implement
this altaxnativa would likely require tha removal of tha tank fan
building or use of land to tha north of tha CEC/Bridgewatar site
boundary.
Ihe FS did account for potential subsurface excavation zones underneath
the tank farm building and around the septic system and underground vault
(or sump) . (See pages 3-18,3-19, and 3-23 in tha FS) . This volume was
estimated at 1,000 cubic yards and was then added to surficial soil
volumes for use in cost analyses (sea Table 3-4 in the FS) .
2*
FS should have CTrc^y'tyl detailed analyses of biological
treatment of contaminated soils. The FS eliminated biological treatment
as an alternative because it has not been demonstrated as an effective
technique. Yet on soils containing VOCs at the Tinkham Garage site in
Londonderry, New Hampshire, biological treatanent has been demonstrated as
effective at a cost of $160 par cubic yard. Biological treatment should
be retained as a feasible technology. Also, if carried out in the
existing Equipment Building, biological treatment could be even less
costly.
In 1987, EOOVA Corporation conducted bench scale tests to mniess the
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potential for biodegxation of TOCs in soils froa the Londonderry site.
These tests indicate that VDC's can be reduced to the 1 ppm level by
biological treatment and air stripping in a controlled environment. In
preliminary discussions relative to the Bridgewater site soils, EOOVA
personnel indicated their belief that the biological treatment process
could meet the remediation goals of reducing benzene to the 4 ppm level
and PAHs to the 3 ppm level at a cost considerably less than the
estimated $400 per cubic yard for thermal aeration.
Response; The use of biological treatment to treat soils at the
CEC/Bridgewater site is not an appropriate approach for several reasons.
Biological treatment of contaminated soils is still in the developmental
stage. Biological treatment has been used to treat industrial waste
streams and oily sludges, but this does not require the same type of
process controls as treating hazardous wastes. The treatment of soils at
the CEC/Bridgewater site would require a preliminary analysis of the
technology's effectiveness, as well as a demonstrated ability to monitor
and control all emissions and process streams.
It is expected that biological treatment would be effective against
monoaromatic contaminants at the CEC/Bridgewater site. Bench-scale
testing, however, would be required to asspss its effectivenss against
polyaromatic compounds in the CEC/Bridgewater site soils. The EOOVA
studies with contaminated soils demonstrated that aromatic hydrocarbons,
but not chlorinated hydrocarbons, were biodegraded under the conditions
of the study. The studies were designed to compare the rate of
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disappearance of contaminants from nonsterile versus sterile soils. ' The
difference between the disappearance of methylene chloride and
trichloroethylene (TCE) from nonsterile versus sterile soils was only 16%
after six days. For tatrachloroethylene, there vas a greater loss from
sterile soils than from nonsterile soils. These results indicate that
the disappearance of these compounds from soil is attributable primarily
to volatilization. Differences observed between sterile and nonsterile
soils could be attributable to biodegradaticn and/or heterogeneity of
contaminant distribution in site soil samples. The sunnary section of
ECOVA's report states that "biodegradation of TCE was not achieved by the
native microorganisms'1 and "to achieve cleanup levels most rapidly, both
biodegradation of petroleum hydrocarbons and volatilization of
chlorinated hydrocarbons must be used effectively.
liation of ground water contaminated with chlorinated aliphatics is
in the developmental stage by several vendors and institutions, and
involves complex ffliTn*">'i>*1 oonsortjtiffp and prrvifin y^r ^ r*|in'N'i*T that are
incompatible with biodegradation of aromatic*. Therefore, sequential
batch reactors would probably be required to degrade the different
of compounds in soils at the site.
Piuuess parameter requirements for biological treatment would require
mixing as well as aeration for the aromatic*. This would cause
volatilization of the VOCS, for which an emissions control unit would
have to be designed. At present, no fixed or mobile treatment unit with
these necessary design features is available. Extensive bench- and
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pilot-scale testing would be required to design an effective system for
the CEC/Bridgewater site.
In contrast to biological treatment, the effectiveness of low-
temperature thermal aeration has been proven in the field. Furthermore,
additional research and development considerations would not be necessary
for emissions management and process parameter requirements.
In summary, the selection of low-temperature thermal aeration to
remediate soils at the CEC/Bridgewater site ensures that cleanup can be
initiated in a manner that is timely and consistent with statutory
preferences for treatment, and at reduced costs relative to other proven
technologies.
3. Asphalt Batching
Comment! The FS should consider asphalt batching as an approach for
disposal of VCC-contaminated soil. At least two asphalt batching
companies, Black Mountain Corporation of Kolliston, Massachusetts and
Brocks Jetline of Dover, Massachusetts, have performed asphalt batching
of contaminated soils as a means of remeditating sites where spills of
petroleum oils have occurred. The asphalt/soil mix is then vised for
highway construction. This method of remediation has been implemented at
several sites in Massachusetts under the direction of the DBQE.
To date, Black Moutain Corp. has handled only soils contaminated with
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"light-end" hydrocarbons, such as gasoline, kerosene, diesel fuel, and
No. 2 fuel oil. The contaminants found at the Bridgewater site are
similar to those found in soils contaminated by gasoline and oil spills.
The cold batching process utilized by Blade Mountain is reported to cost
from 60 to 80 percent of that for disposing of soil in an approval
landfill and should be considered in the BOD.
Brocks Jetline performs hot-mix asphalt batching of soils contaminated
with hydrocarbons inciting gasoline, kerosene, diesel fuel, and Nos. 2,
4 and 6 fuel oils. Hot mixing reportedly costs from $100 to $150 per ton
or $150 to $225 per cubic yard.
The asphalt batching process may be considered as a potential alternative
to thermal aeration or biological treatment. The reported cost of $150
to $225 per cubic yard are considerably less than the $334 to $404 per
cubic yard estimated by USEPA for thermal aeration.
\: Asphalt batching is similar to the use of a solidification
technology as described in the IS for Alternative SC-3. The asphalt
batching approach would involve mixing the contaminated soils with
asphalt emulsions, and using the resultant material for pavement.
Alternative SC-3 involved solidification of contaminated soils and
debris, and subsequent dl^msnl in an on-site RCRA landfill rather than
use as a pavement. The solidification/landfill alternative was not
selected because it is not a permanent solution, it does not use
treatment to the mnvlTum extent practicable, it does not reduce the
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volume of toxicity of the wastes, and it would require long-term
monitoring to assess the effectiveness of the remedy. Asphalt batching
would not be the preferred alternative for the same reasons. Asphalt
batching does not confer any advantages with regard to effectiveness and
implementability over those previously described for solidification in
Alternative SC-3.
D. RS^niATION OF BUIIDING AND
Comment; The FS and Proposed Plan would demolish all above-ground
storage tanks and all buildings, except the equipment building, after
decontamination. The FS implies that the bull dings and tanks must be
demolished after decontamination to permit the sampling of soils under
the foundations. This plan appears to be highly excessive in terms of
necessary remediation of the site. The purpose of the demolition of all
of the storage tanks after decontamination is not clearly described nor
is the estimated cost of $250,000 justified in the FS.
While demolition of the buildings would facilitate sampling for poten-
tially contaminated soils beneath the flooring, it is an extreme measure
to accoqplish *i*5« task. F^caus** of the uncertainties in the level of
effort required to decontaminate the structures, the requirement for
building and above grade tank demolition seems premature with the
possible exception of the incinerator building.
The incinerator and incinerator building may require removal for
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effective remediation. However, further sampling of wall and floor
surfaces in the other buildings is required to ussens the extent of
contamination. A sampling piujiaiu for building walls and floors should
be carried out as a first step in deciding the ultimate fate of the
structures. They should be demolished only if the sampling proves that
the floors and walls are permeated with contaminants to the extent that
they cannot be decontaminated.
In the more likely event that the building walls and floors contain only
minor surface contamination, the next step should be to core drill
through the floor slabs and sample the soil immediately under the floors.
If the soil is found to be contaminated, the buildings may have to be
demolished to permit removal and treatment. If not, the buildings could
be decontaminated, as described in the IS, the walls and floors
resurfaced or sealed with paint, resin, or gunnite, and the buildings
left in place.
If required, the above-ground outside steel tanks can be decontaminated
using conventional cleaning methods. However, it is reported that these
tanks were never used, and it is very possible that they are not
contaminated. Therefore, they should be tested for contamination prior
to deciding upon the need for decontamination or removal.
It should be noted that the equipment bunding, tank farm bunding and
ready building appear to be in good structural condition. After cleaning
and removal of piping and tanks, if required, these bindings could
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remain on the site and be sold to another user. The FS does not
the future use of this valuable site, and it should be considered in the
ROD.
Response; The Agency has determined that decontamination and removal of
the buildings and structures is necessary to protect human health and the
environment from the release and threat of release of contamination, and
to fully characterize the nature and extent of contamination at the site.
Sampling of soils under the buildings and structures can be most
effectively conducted after the buildings and tanks are removed.
Decontamination of the tanks and building is required to properly close
the incinerator and tank facilities. Additional costs for the removal of
the structure after decontamination are estimated to be $150,000. Given
the small additional cost and the potential risks of failing to detect
contaminants if sampling is hampered by the exising structure, the Agency
determined that maintaining the integrity of the tank farm and buildings
would not be the most protective, effective, or implementable approach.
E. GROUND WATER
Comment! Considering the hydrologic conditions and the low levels of
organic contaminants at the site, the FS plan to install seven additional
monitoring wells (of which 3 of the proposed wells are duplication of
existing wells) and to perform extensive sampling over a thirty-year
period are unwarranted and costly. The commenter further suggests a
reevaluation of the target compound list, and an alternative approach to
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monitoring well locations and frequency of monitoring.
Response; The proposed target oin»miil list has been reevaluated in the
ROD and has been slightly modified. A full explanation of the selection
of groundwater clean-up target levels is in the BOD. The PS outlines a
proposed monitoring piuyiauu The groundwater monitoring network to be
implemented will be designed during the remedial design phase of the
remedial action. The monitoring piujiarn will be designed to meet the
intent of RORA groundwater monitoring requirements and will be tailored
to site specific hydrogeologic conditions. The ocnraenter's suggested
alternative approach to monitoring well locations and frequency of
monitoring will be considered during the design.
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IV. REMAINING GCNCEXSE
During the public comment period, at the public informational meeting on
the FS held by EPA in Bridgewater on February 11, 1988, and at the informal
public hearing held on February 25, 1988, local residents rh'smsspd issues
that may continue to be of concern during the design and implementation of
EPA's selected remedy for the CEC/Bridgawater site. These issues and concerns
are described below:
(A) Site Security
Citizens expressed concern that, although there is now a guard stationed
at the site, often the gate is left open and the guard is not visible.
Citizens requested that the guard lode the gate if he is planning to sit
inside the trailer where he cannot be seen. Furthermore, citizens requested
that EPA quickly .construct a fence to prevent access to the site following the
removal actions and dismissal of the guard.
(-B) Sampling Data
Several citizens were very concerned about whether EPA had conducted any
off-site sampling, and whether EPA expects that there is any off-site
contamination of the surrounding property. EPA explained that no off-site
sampling of soil or ground water has been conducted to date. EPA has found
that ground water is flowing in a north to south direction, and that the
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contaminants in the ground water naturally attenuate before reaching the
drainage canal. EPA will be conducting further en-site sampling during the
remedial design phase, and will continue to provide citizens with this
sampling data. In addition, EPA will begin to monitor the ground water off
site to study the movement of contaminants and to ensure that they are not
migrating off site.
(C) Availability of On-site Contact Person
Citizens asked ERA if there would be an en-site official who could asnwer
any questions they may have regarding the design and construction of the
remedial action. The person assigned by ERA to be the en-scene coordinator
should be prepared to respond to citizens questions.
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A
GdMGNTK KEEAXXGK5 ACTIVITIES
CANNCKS ENGINEERING CCRPQRATICN srns
IN ERDGOOffiER,
Community relations activities conducted at the CEC/Bridgewater Staperfund site
to date have included:
o 1982 - EPA released a community relations plan describing citizen
concerns about the site and outlining a program to address these
concerns and to keep citizens informed about and involved in site
activities during site remedial activities.
o November 15, 1983 - EPA held a public meeting to explaitn plans for
the Remedial Investigation (RI), to define the extent saf
contamination, and the Feasibility Study (FS), to evaluate
alternatives for remedial action at the site.
o July 1984 - EPA issued an information sheet updating the community
on the progress of the RI.
o Hay 1987 - EPA issued a public notice announcing the availability of
the RI, and the upcoming public meeting to explain the results of
the RI.
o May 27, 1987 - EPA held a public meeting to present tine results of
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the draft Remedial Investigation and answer questions fron the
public*
o February 4, 1988 - EPA issued a public notice to announce the tine
and place of the upcoming FS informational meeting and to invite
comment on the FS and the Proposed Plan, which outlines EPA's
preferred alternative for addressing contamination at the
CEC/Bridgewater site.
3 February 11, 1988 - EPA held an informational mooting to discuss the
cleanup alternatives presented in the FS, and EPA's Proposed Plan
for addressing the contamination at the CEC/Bridegewater site. EPA
also answered questions from the public.
D February 11, 1988 to March 4, 1988 - EPA held a three week public
uuuimaut. period to accept public uauuttuL on the alternatives
presented in the FS and EPA's Proposed Plan.
o February 25, 1988 - EPA held an informal pubic hearing to accept
oral comments on the remedial alternatives evaluated in the FS, and
EPA's Piupjeed Plan.
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In the Matter of:
PROPOSED PLAN FOR CLEANUP OP
CANNONS ENGINEERING CORPORATION
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SUPERFUND SITE
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UNITED STATES OF .AMERICA
ENVIRONMENTAL PROTECTION AGENCY
REGION ONE
Thursday
February 25, 1988
Bridgewater Academy Building
Second Floor Meeting Room
Bridgewater, Massachusetts
The above-entitled matter came on for hearing,
pursuant to Notice, at 7:30 p.m.
BEFORE:
MERRILL HOHMAN, Director
Waste Management Division
21
WAYNE ROBINSON
Environmental Engineer
RICHARD MCALLISTER
Assistant Regional Counsel
PRESENT: HARISH PANCHAL
D.E.Q.E.
MARGARET BARRETT
ICF
Rtgistrrrd Professional Rrfiortm
(617)426-3077
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MR. HOHMAN: Good evening and we1cone.
My name is Merrill Hohman. I'm the
Director of the Waste Management Division of Region I
of the United States Environmental Protection Agency,
and let me welcome you to this session this evening.
Could I suggest that maybe people would
like to just fill in down here. There's plenty of seats
down front, as they say, and we will try to make this
as informal as we can.
There are some formalities we have to
go through this evening and I will explain whv as we go.
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12 jj First, this is a public meeting and an
13 jj informal public hearing to present and to receive conner.ts
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15 ji Bridgewater Superfund site, as required by Section 117
of the Amended Superfund law. And as you will see, we
17 ; are having a stenographer record the entire meeting this
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79 li made part of the record and it will be available for
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Kennedy Federal Building, and also, a copy will be made
available for review here in the Bridgewater Public
Library.
If, for any reason, anyone wishes their
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own copy of the transcript, I would suggest that you
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(617)426-3077
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contact the stenographer directly after the.hearing closes
and see if you can make your own individual arrangements.
That might be the quickest way for that to be done.
Let me begin by doing some introductions
of some EPA and State staff that are here with me this
evening.
On my left is Wayne Robinson, the EPA
project manager for the Bridgewater Superfund site. On
my immediate right is Richard McAllister, who is the
10 attorney for the site in EPA's office of Regional Counsel
11 1 Down at the door we have Margaret Barrett,
from a firm by the name of ICF, which is our community
13 jj relations consultants to EPA for this particular site.
We also have with us, in the front rov;
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we would proceed.
First, I'm going to ask Wayne Robinson,
our project manager, to nake a brief statement reviewing
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that brief because there was a meeting down here to discuss
the plan in considerable detail on February llth.
After we finish that presentation, there
will be a chance for those of you who want to make a
formal statement to do so. I have, now, two individuals
who have indicated they would like to make a statement,
and if you would like to make a statement, please contact
Ms. Barrett and she'll sign you up.
We will go through those formal statements,
10 ;; which are more of the usual hearing-type of statement,
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12 !> up to a very informal period of time to take questions,
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13 ;! answers and any comments that you might wish to make to_us
14 jj Are there any questions on how we are
15 j. going to proceed?
16 I. (No verbal response.)
i
17 j! MR. HOHMAN: Okay. Why don't we get
18 !' started and I'll start by calling on our site manager,
19 j Wayne Robinson, who will make a little presentation to
'20 'i all of us on the proposed plan for cleanup.
I'
MR. ROBINSON: Thank you, Merrill.
I have two overheads that I would like
to show you as I described our preferred alternative. j
i
The first is — I would like to acquaint
you with the site itself, because I will be making some
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reference to some of these — some of the facilities on
the site as I describe the proposed plan.
This is the Cannons site off of First
Street in the Bridgewater Industrial Park. There's some
notable features on the site that we will be discussing.
. One, the Tank Farm Building, which housed several tanks
6
_ where Cannons stored the waste that they are handling;
the equipment building on site, which they used, obviously,
o
to store some of that equipment. They also had a small
laboratory in it.
Two other buildings, the Incinerator
Building, which housed the incinerator control facilities
'i and the Ready Building, which stored the waste before
13 I;
I,
it was put into the incinerator.
Other notable features is this area here,
15
which we have called the "wet area." To the far west
16 i:
|: of the site is Route 24. And, as I sa'id, First Street
r
is to the east.
As a quick overview of the site, I would I
i
!
now like to discuss the preferred alternative that we
are proposing for the site. The first portion of it would
be fencing the perimeter of the site. After that we will
remove and decontaminate the buildings, tanks and other
structures on the site.
*
We will be removing the Tank Farm Building
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and the Incinerator Building and the Ready Building that
I described, most notably to get underneath the buildings
to evaluate whether there is any soil contamination under
there that may have leaked from the structure, inside
the building.
We will also be removing and decontaminate
the incinerator itself and we will also be removing any
underground tanks that are there at the site.
Following the removal of those structures,
we will do some additional sampling of the site's soil
11 •' for a couple of reasons. One being, as I explained,
i
12 !j that we are going to sample underneath the buildings that
13 !j we couldn't get at while the buildings were still up.
14 i! • So, once they're down, we will do some additional sampling;
J! .
15 j! and we will also do some additional soil sampling to
1
further delineate the exact extent of the soil
17 !' contamination, so we can implement our soil remedy.
i!
18 i Following the sampling, we will then get
j:
19 into one of the major portions of our cleanup, and that
is soil treatment. We are proposing two different sorts
of soil treatment at the site. One being soil aeration
and the other being soil incineration.
The soil aeration, we will use to treat
the soils — any contaminated soils from underneath the
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buildings and also the contaminated soils from the wet
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area.
The contamination that we will be treating
through soil aeration will be the volatile organic
contamination.
The other type of soil treatment we will
use will be incineration. Let me back up a bit and say
that that soil aeration process will be conducted on the
site and it's a process in which we pass the contaminated
soil through a machine, through a heated .air which passes
through it and strips off the contamination from the
contaminated soil inside the machine. That contamination
12 jj goes into the air inside the machine and then the air
it
13 i1 is passed through a pollution control device so clean
i:
14 i air is released to the atmosphere. That will be on-site
15 I for the followup on the contaminants.
16 !; The other portion of soil treatment is
17 |! incineration. There are some contaminants at the site
18 i that are not amenable to aeration, and that contamination
I . i
19 j! is the soil contaminated with polychlorinated biphenyls.
We call those PCBs, polychlorinated biphenyls.
That contamination will be excavated from
the site and transported to an off-site incineration
facility to be incinerated for burning.
Following that soil treatment process
4
we will then implement a groundwater monitoring program,
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in which we will install additional additional wells in
the vicinity of the site and take samples on a periodic
basis to monitor thn groundwater.
And that's our preferred alternative.
MR. HOHMAN: Now I would like to go to
the second part, which is to call upon anyone who wishes
to make a formal statement for the record.
I'll go through the aign-ups here that
I have, in the order I received them. If you are going
10 ij to make a formal statement, I would ask that you identify
li
i
11 •! yourself for the record, and if you have a lengthy
12 i statement, over ten minutes, I would suggest you summarize
13 jj it, and submit the full statement for .the record.
14 !| The first is Paul, I think it — Chourard.
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MR. CHOURARD: Yes. I am here as a
concerned resident of Bridgewater. The reason I'm here
17 I is I think too much time has gone on. The place has been
closed for eight years, or seven years and they're studying
it to death. I would just like to know what's sitting
down there right now.
The cost — we're all business people
in this room, we all have our own budgets we manage. Could
you break up these five options and what it's going to
cost to render this site harmless; list exactly how many
«
gallons — there is gallonage still above the ground down
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there. Read through this and you can tell that the soil
is contaminated. But it doesn't list what's sitting down
there, you know.
Hundreds of thousands of dollars are being
spent to guard this place. I'm concerned what's sitting
down there. Is it a time problem? Is it going to take
eight more years? Tell us what's going to happen? If
8 I we go with Option One, will it take 12 months? If we
'i
go with Option Three, it's going to be 36 months? If
we go with Option Five, it's going to five years? Tell
us a little bit more than just, you've got contaminated
ji
12 Jj soil. Let us know what's happening. That's all I ask.
13 !; MR. HOHMAN: Okay. Before we start
I
14
answering questions, is there anyone who wants to make
a formal statement or just add comments, or is it all
going to be questions and answers?
If it is, we will just go right into
18 ' questions and answers and not worry about any formal
statements.
(No verbal response.)
MR. HOHMAN: Okay, why don't we turn it
around, then. We've got a question of what the contaminants
are and how long it's going to take to clean it up, the
cost and so forth.
Wayne, why don't you see if you can answer
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some of those.
MR. ROBINSON: Okay. To get — in order
to — You asked me a lot of different questions, and I'm
trying to jot them down. Very quickly, the preferred
alternative I discussed, which is some fencing, additional
sampling, removing of buildings and the soil treatment,
we anticipate that to take, once we implement that remedy,
to take approximately six months to do all that and to
take care of the soil.
However, though, we plan to monitor the
11 '! groundwater for a period of time, longer than that, to
12 ij evaluate the groundwater further.
13 i! Your question .on what is contamination that
*
U .1 we find there right now, as I discussed in some other
IS li meetings — and let me point out some documents that give
I
16 ji you some great detail on the extent of the contamination.
i
17 '•• And it could also help you on some of your questions.
I:
18 J! The extent of the contamination is discussed
in the remedial investigation, and that's over at the
library. Additionally, all the alternatives that you
wanted to know about, the cost and time frame on all
the different alternatives, that'll also at the library.
The contamination that we are addressing
right now is mainly contamination in the soils oh the
site. As I said, there's basically two types we are
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concerned with, volatile organic contaminants, or VOCs,
and the PCBs that I explained.
That contamination is on the site soil
right now at levels that we feel need to be cleaned up,
to protect public health, in terns of possible contact.
Also, protecting the environment as the chemicals might
leach out of the soil into the groundwater.
The cost for the alternative that I'm
proposing is approximately $3.4 million, which, the majorit
of that is the actual soil treatment cost of roughly
11 j| 2.7 million; and monitoring the groundwater, .7; 700,00.
12 l| How did — did I hit on all your points?
ii
13 ,' . MR. CHOURARD: Is there gallonage of any
kind, whatsoever, above the surface down there? Does
it sit in tanks or drums.or barrels or boxes? What's
happening? What have we got? Something's being guarded
down there and it's not contaminants that are in the
ground.
MR. ROBINSON: Right. Previous to our
activity at the site, there was waste on the site, and
that was removed, liquid waste on the site, and the drum
waste on the site was removed back in 1980. The liquid
waste was removed from those tanks — from the Tank Farm
Building, approximately 155,000 gallons; and approximately
700 drums were removed from the site.
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So, the majority of the liquid waste on
the site has been removed. The reason for the guarding
of the site right now is to either insure no one gets
on the site due to the abandoned waste inside the
laboratory, and some wastes that were abandoned inside
the box trailers. Those wastes have been inventoried
by the EPA and are awaiting removal in the very near
future by some potentially responsible parties that we've
been negotiating with.
So the guard is there in terms of
controlling access, due to the abandoned laboratory
material and the other material that was abandoned on
13 I! the site, due to a tank line, it's a company that
abandoned some paint waste there, tank line waste.
MR. MCALLISTER: Just to add in something,
this is, right now, about to happen. We have signed an
order with the responsible parties to do this, and they
are in the final stages of working out the work plan,
the exact details of how they are going to do that..
So, to directly answer your question,
whatever liquids that are on the site that are above the
ground are going to be — and there's very little of them
that remain at this point, are about to be removed as
part of this immediate removal action that has been agreed
«
to be performed by the parties who are responsible for
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the problem at the site.
MR. CHOURARD: I'd like to turn the
incinerator on for about ten minutes and throw that guy
in there that created all that mess.
MR. HOHMAN: Let me go in the order in
which you came in, now. We'll make one round and then
we will come back and repeat, and so forth, so everybody
gets a chance here.
Robert Gabriel.
10 MR. GABRIEL: Robert Gabriel, 800 High
11 Street.
12 || I would like to direct my questions to
13 | the property immediately adjacent Cannons, which is a
lot of land to the north of it and south of it/ parallel
to Route 24.
I want to know if there is any effort
made to test the adjacent lots there and if there has
been any contamination from the Cannons site on the
adjacent lots.
I also would like to know if there has
been, what is the results of the tests that have been
done. If the tests have been done and it shows to be
be positive tests, what your plans are to alleviate that
situation.
And, also, will the landowners of the
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adjacent lots be issued 21Es from this department after
the cleanup has been made; will they guarantee that the
site adjacent to that will fall in the realms of
acceptable levels.
MR. HOHMAN: Let's — We'll ask Wayne
to answer the first part of the question.
The question of 21E will be up to the
Department of Environmental Quality Engineering, and I
don't know if their representative wants to try and answer
10 1 that tonight or not* but let's go about the adjoining
property when--
MR. ROBINSON: I think an easy way to
13 ;! do that — I'll throw up our site map and we can talk
about the properties that you are concerned with.
All right, how you said north and south
— this piece of property here and this down here?
17 ! We have done — here's the Cannons'
i
18
property boundary — we have done sampling both of the
soils and of the groundwater on the property. With
respect to groundwater, we have found some contamination,
as I discussed, on the site.
However, the groundwater flow is from
the north— generally from the north to the south. So,
it's not anticipated to have any contamination on the
groundwater north of the site. We don't have any wells
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north of the site, but they are not necessary; the
groundwater is moving to the south.
We have — the other issue is surface soil
contamination. To answer your question, we have not taken
surface soil samples outside of the Cannons property,
with one exception, and that is, we have taken some samples
7 II in this northern portion of the site. And I would have
to check the data to see exactly where the property
boundary is before I can make a determination on — if
there's contamination in the property that's not Cannons.
Well, there's some Cannons' debris in
this northeast corner of the site, and I would like to
recheck the documents to make sure that debris is on —
fully on Cannons' property. If it is on Cannons' property,
then there is no contamination off the property. If the
debris is not on Cannons' property, then we have some
samples up there and, frankly, I would have to check the
results of the sampling before I make a definite, you
know, statement as to level of contamination in that
corner.
MR. GABRIEL: Cannon's debris that you
are talking about is not on Cannons' property. That's
on the adjacent property.
MR. HOHMAN: Let me interrupt to tell
you what we will be doing if — we define the-site as
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the area of contamination, not a property boundary.
Now, when we get in to actually designing
the final cleanup, if it turns out that there is a
contamination, you know, on the northern edge — you said
that debris is not on Cannons' property, it would still
be tied into the Cannons' operation; it would be part
of the Cannons' Superfund site and it would be cleaned
up.
On the other hand, if there was
contamination on that property north-of Cannons' property
11 ij line which had nothing to do with Cannons, then that would
12 j| be beyond the scope of our cleanup.
13 i| MR. GABRIEL: .That's very reasonable.
14 ii What's I'm concerned with is Cannons' contamination on
that adjacent property and if it was going to become a
responsibility of the Superfund cleanup?
MR. HOHMAN: It would be, because the
Cannons' site would include anywhere that Cannons'
contamination has gotten to, so if there is debris on
the other side of the property line—
MR. GABRIEL: The question is, has that
been determined yet—
MR. ROBINSON: Well, we know where that
debris is.
MR. GABRIEL: But, the debris, you say,
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has not been tested—
MR. ROBINSON: No, the debris is physical
3 debris— we have taken soil samples in that area. I would
have to recheck the data to give you information on the
exact results of those — I don't have that number off
the top of my head, the exact results.
MR. GABRIEL: Do you know if that area
8 is contaminated? Is what you are telling me—
9 I MR. ROBINSON: Well, we have the results.
'0 [j I don't have the number off the top of my head. I would
gladly look up the number in our investigation and let
you know what we found there.
MR. GABRIEL: Okay. Is the same — on
the southerly boundary also?
MR. ROBINSON: Okay. The southern portion,
this is — the southern portion of the site is, the site
boundary we consider stopping at this drainage canal, we
consider the southern portion of the site. We have no
sampling information for south of this drainage canal.
We do have sampling information, of course
in the wet area that shows contamination. Our
investigation of the groundwater indicates that there
-- we have in the past found some contamination,
historically, back in earlier years, in '84 and '85, and
the recent data indicates that the contamination, as
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it migrates through the ground is being naturally
attenuated and there is no groundwater contamination
going any further south than this drainage canal.
So we have not taken the actual samples
in that area, but there is no reason to believe that
there's surface soil contamination here related to
Cannons' activities and our hydrogeologic data indicates
that we would not expect any contamination to move any
further south than that drainage canal.
10 MR. GABRIEL: Is it unreasonable to ask
11 this Board for a write-up, a statement, guaranteeing that
12 j! fact?
13 i! MR. HOHMAK: Guaranteeing?
i!
14 MR. GABRIEL: Guaranteeing that there
15 ! is no contaminants on the north or south side?
16 ' MR. HOHMAN: I can't make that statement,
17 ! because, for all I know, the property owner on the south
18 ; may have contaminated the property or it may be
19 . contaminated from a completely different basis.
20 j • MR. MCALLISTER: I think it deserves a
2i j little clarification that that middle line, down through
22 the middle there, defines that just south — below Wayne's
23 hand right there is not the Cannons' property. That is
24 another parcel of property.
Now that's within the boundaries of our
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Superfund site that we are going to be cleaning up, because
that's what our investigation has found VC contamination.
So, we are cleaning south of Cannons' property, per se,
to what we have found the contamination to be.
Does that answer—
MR. GABRIEL: Well, it doesn't satisfy
me, but I understand what you are saying. My point is,
no matter where that contamination has spread to, I would
think — I would hope that the Superfund would be resposibl*
for that.
11 I; MR. HOHMAN: If we have any information
that says «r, -yota iraow, if we had any information that
13 jj suggests to us a basis for the possibility of the Cannons'
contaminants, for example, went across that brook and
further south, then it would be included in our site plan,
16 li but we have nothing to indicate that at this point.
MR. GABRIEL: And you are saying that
you have made those tests to determine that?
MR. HOHMAN: Well, what we are saying
is, that on the basis of the tests we have done, tracing
the contamination down, we have been convinced that the
contamination line there, that it ends at that drainage
canal, that it does not go across.
We did not actually sample on the other
side. We used—
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MR. GABRIEL: As long as you are satisfied
that it does — and you will state that you are satisfied
that it does not.
MR. H01IMAN: And it would be defined
— it is the definition of the site and the site cleanup,
right,
MR. MCALLISTER: You know, we actually
do the design and decide exactly which soil is going to
be removed, and so forth, which is part of the actual
design work, getting ready to construct. Then that would
11 !! be verified.
12 I One of the cornerstone of things that
ji
13 ;! we try to accomplish in the remedial investigation and
14 j feasibility study, is to define the nature and extent
t,
15 I of contamination at the site. And that is, the over-
16 l> riding purpose of what we are doing and Wayne feels very
li
17 j; confident, based on studies that he has found where the
l:
IB |j bounds of that contamination are.
MR. GABRIEL: I think the only question
is, if you have gone beyond the bounds to make these tests
to determine that, that's fine. But, being the Board
is reluctant to issue 21£s without knowing the specific—
MR. HOHMAN: Well, I'm going to call on
Mr. Panchal, if he wants to talk about 21E, because he's
t
from the State DEQE, and that's a State function.
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MR. PANCHAL": On the issue of 2IE. I
assume that's where we see —• at this point in tine.
There is no clear test of the extent
of the law, 21E, to go on anyone's property and to do
any type of testing or do any type of certification
of private property.
Now how that concerns, as far as the
issue of banks or any other financial institutions —
I assume it would be up to the owner of a piece of
property and the buyer to produce a report saying
that the property is clean or clear.
As I said, at this point in time the
13 Ij law does not allow us to do technical work of any kind
on private property.
What would happen is that the owner of
a piece of private property may hire a consultant. The
consultant, in order to do this, will do the assessment
and furnish a report to the owner. This report may be
submitted to the department.
If there is a violation of the law
then the department can act to deal with it.
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MR. GABRIEL: If that is done, and it
is found that is not clean — will the Superfund
be responsible for that also.
MR. PANCHAL: Well just as the man
has stated, that the boundaries of the property is
considered the line as far as containment.
As far as this case is concerned, we
have found no evidence — and this goes together with
that line.
If there is nc record of a problem with
a piece of property, then-it is just not possible for us
12 j! to identify the containment or the boundaries or
13 ; anything else like that.
MR. GABRIEI-. From what I am hearing
15 i it seems that -this will t« removed in degrees, is that
i
correct?
17 j! MR EDHMAN: Yes.
MR. GABRIEL-. Is that right?
MR. ROBIK50N: Yes.
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MR. HOHMAN: I guess the final part of
— if I may make one comment, and that is, if some time
down in the. future, contamination was found on that property
outside of what we had cleaned up on the Cannons site
and there was some information that it came from Cannons,
it would be basically — the Agency would say, I think,
that we missed it. We thought we had cleaned up the
whole site; we were confident we had; and we missed it.
We blew it. And, therefore, we would come back in and
take care of it, because it would be still contaminated
11 !J from the Cannon's operation. It would still be part of
12 ij the Cannon site.
13 jj There would have to be some kind of tie-in,
I;
14 ij you know, to show that it happened.
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MR. MCALLISTER: As a final point to that,
we will be,through this program, maintaining a presence
at the site for years to come; monitoring the site.
There is a requirement, basically, that we will go out
and conduct reviews.
MR. HOHMAN: Every five years we are
supposed to review the property, also, the site to make
sure it's still — that nothing has happened that we
didn't expect to happen.
Okay, Bea Veronesi, President of
Bridgewater Aware.
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MS. VERONESI: Yes. I would like to ask
why there is such a length of tine between the removal
of the hazardous waste and some of the barrels to where
we are now. Why was there such a length of time in
between the — you know, when you did the biggest part
of work to now?
MR. HOHMAN: Well, let me basically respond
to that, if I can, to the extent that I can, anyway.
We did the removal action because one
of the things that we do, we have one part of the program
11 !j which is able to respond, if there is any immediate threat
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12 j to health. That's our removal program. And, just as
13 ! a matter of routine, any site that we discover, we have
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14 ij the removal people look at it. If there is a serious
15 1 problem, we have a separate pot of money specifically
to go in and do quick containment of the problem. Not
i
cleaning the site up, but if there's drums there, perhaps I
removing the drums, if there's a bit of a problem, or ;
i
putting up fences or sealing it in some way, until longer-
term studies can happen.
Now, we began the studies, I'm not sure
exactly what year we began the studies on this, but a
couple of things happened.
First of all, you have to have the budget
*
and we had, at the start of the program, a large' number
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1 of sites came on line all at once and we had to budget
2 the funds that we had available; start some immediately;
3 start others a little bit later.
4 Then, in addition, we had a major slowdown
5 in the program in 1985 to '86, because the Superfund law
6 actually expired, and there was a delay for getting it
7 in and that impacted with the budget. We were running
8 on some leftover money and we had to curtail some of our
9 operation.
10 So, that's the best excuse we can give.
11 1 We can't be everywhere at once, as much as we would like
12 | to. There are. some sites that we have that are on the
ii
13 ! Superfund list, that we are just really getting started
14 I now. Some have been on the list waiting and will not
15 ' start until next fall, for example.
16 i So, it's & case of resources, timing,
17 ! the unfortunate circumstance with the law, which I'm not
18 ! saying anyone was to blame; it was one of those things
19 i that happened, and the budget and so forth. A combination
20 i of things.
2i ! MS. VERONESI: I was concerned, because
22 we didn't have the guards there and there was that building,
23 laboratory building, or whatever, that still had vials
24 - and jars and what-have-you there, and that's what worried
25 me, because we didn't have fences; we didn't have a guard
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there and there was this length of time from when the
biggest — I know the biggest part was done, because I've
been following this through.
But, I wondered, you know, why the length
of tine and it could be because of the money, having
enough money to come back and do— -
MR. HOHMAN: The funds and also a
judgment as to whether or not the problem warranted it.
Sometimes you look at it on the basis of all the other
10 problems you have to deal with at that moment, and you
11 ;! say, no, it doesn't warrant responding, and you might
1
12 jj look a little later on and decide that, you know, maybe
it does at that point and you have the ability to respond,
so, you do.
15 : It's strictly government budget and
16 i everything else all at once, for which we apologize, but,
that's a fact of life in, I think, any program.
Anything else? Okay, Norman Snow.
MR. SNOW: I drove by there twice last
Saturday and this guard who is stationed there — is there
a guard positioned there now?
MR. HOHMAN: Yes.
MR. SNOW: He should be told to close
the gate. I went by there twice last Saturday and the
«
gate was left open at all times. His car was out front
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by the trailer, but I didn't see him anywhere.
3 you,
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MR. HOHMAN: We'll check on that. Thank
MR. SNOW: And is there any measure of
— what can individuals do about future Cannons? For
example, why does the Town allow something like this to
come In and be built?
MR. HOHMAN: That's kind of a — you see,
a lot of these things predated, I think, a recognition
by government — by anyone, that there was a problem.
MR. SNOW: It's hazardous waste—
I!
12 jj MR. HOHMAN: Yes, but it wasn't recognized
I!
in many cases, it wasn't an area of concern, for example,
back, I think, when Cannons started.
A great many of our sites that we have
are Superfund sites. I think the normal thought that people
have when we hear about a Superfund site; it was —
somebody did something wrong and it was illegal, it was,
you know, it was bad, and they should never have done it.
Quite the contrary, a great many of our
sites were sites that were "operated perfectly correctly
for the circumstances and the knowledge that we had when
they were in operation.
I think that starting in the '70s, there
4
began the recognition that, whoopsv some of these
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hazardous wastes are things that we rea*
ought to go uncontrolled. We ought to ha\
on it.
Congress put the federal gove.
know, into the program in 1976 with the passage
Resource Conservation Recovery Act,, which was the
federal program to begin to deal with managing haz&
waste on a national basis and requiring the states tc
participate,
It took us from 1976 until, I think, 198>
11 ji to define what a hazardous waste was. I mean, you'd think
i
it would be obvious to the eye of the beholder what would
be a hazardous waste. In fact, it is not that easy to
do from a regulatory standpoint.
In 1980 we came out with our first standards!
on how these wastes should be managed and now facilities
that handle hazardous waste, that generate it, store it,
transport it, so forth, are all required to comply with
much more strict federal and state standards because we
recognize the problem.
It may well be that there are other
problems out there in the environment that we haven't
even begun to recognize yet. If you read the newspapers,
people are starting to worry about something called the
*
ozone layer warming the — all kinds of things that we
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really don't understand at this point and are just
beginning to recognize might be concerns. I think the
whole question of hazardous waste has been in that category,
that when a lot of these facilities .were operated, it
was, people thought about them when they were located
there, it was acceptable, and the thing to do and it
was certainly — this kind of facility is needed, because
0 we continue to produce hazardous waste.
8
We've got to have facilities to take care
of them and to manage them properly. I think the thing
to do is to be sure, as citizens, that when one is
proposed, not to oppose it just because the name is
hazardous, but to satisfy yourself that the controls that
the state and/or the federal government are going to put
on that facility are going to be such that you won't have
problems in the future.
MR. SNOW: Yeah, I just think they could
put it somewhere else besides near houses. That's all
I'm interested in.
Another question: Are the Cannons, have
they been slapped on the wrist — or, I understand they
have four or five other places in Massachusetts or New
Hampshire. What's the — do you know anything about
that?
MR. HOHMAN: Well, does counsel—
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] MR. MCALLISTER: Yes. They 'were prosecuted
2 criminally by the Commonwealth of Massachusetts. They
3 were also considered individually, the two Cannons,
4 individually, as well as the corporation, which has got
c insurance assets, but they were considered potentially
6 responsible parties, at the top of our list, and we are
7 expecting to get some payment from them to help pay for
8 the cleanup cost that we—
9 MR. SNOW: Do I understand that they were
.. just being prosecuted financially—
MR. MCALLISTER: They were prosecuted
i|
I criminally by the Commonwealth of Massachusetts, and I
j| believe they spent some time in jail.
I I mean, you have to recognize, the kind
of time in jail for environmental crimes is not like for
!' robbing a local drugstore, but they did spend some time
if i;
„ \ in i»il.
"!
| MR. SNOW: Aren't they worth a lot of
' ** ti
i!
money?
MR. MCALLISTER: Well, actually, we are
20
trying to get an update on that right now, where they
are. They are not insignificant.
MR. SNOW: Thank you.
MR. HOHMAN: All right, that concludes
the list of the people that signed up. Now, anyone else
25
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who — yes.
A SPEAKER FROM THE FLOOR: Well, I live
across the street. What about testing our water, you
know, to ray home. I have a lot of grandchildren and family
and it worries me about that.
MR. HOHMAN: Well, it's a public water
supply system down there, right?
A SPEAKER FROM THE FLOOR: Yeah, but you
don't think that it's—
MR. HOHMAN: No. No. The public water
out — number one, we don't believe the material would
12 i move that far anyway, even to get near it. Number two,
I;
i|
13 !!, public water supplies are under pressure, and because
of that, anything that happens, it always, you know, water
goes out, it doesn't suck stuff in.
So, that, because of that pressure, I
17 think you're pretty confident there is no problem. There
are requirements, and I'm not a water supply expert, there
are requirements for public water supply systems to be
checking the quality of the water that goes into the
system and so forth—
A SPEAKER FROM THE FLOOR: Where could
I have that done?
MR. HOHMAN: If you want to have — well,
4
I would suggest the first thing you do is talk to your
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1 own water department right here and see what analyses
2 they have. If you are concerned about it, as an individual.
3 you could contact — actually, I suppose, look in the
4 telephone book and find a laboratory. You night want
S to contact the DEQE Water Supply Office, which is — is
6 it in Boston or down in Lakeville — in Boston, okay,
7 talk to then and see if they could give you some
8 recommendation. Z think they have a list of approved
9 testing labs, don't they, in Massachusetts.
10 A SPEAKER FROM THE FLOOR: —the price
!|
11 ! may cut because Cannon's out there. I don't know if I
I
12 jj want to sell it or not, but I don't want to give it away.
13 |! And I won't get what I should get for it because the first
ji
14 thing they tell me, no way you're getting it if Cannons
i;
15 { is still there. So, we couldn't even think of selling
i
16 :' on our street, but not for what we should get for it.
17 : MR. KOHMAN: I have one philosophy on
\ *
18 |j the Super fund program. I quite often get in trouble when
:i
.19 |i I state it, but that is, that, hopefully, if we are doing
20 ; our job right, when we're done, as far as any uncertainty
2i • about risk to your property, you are much better off than
22 s someone who doesn't live next to a site, because they
23 ! really have no idea what's in their environment.
24 So, at least we know--
25 ' A SPEAKER FROM THE FLOOR: No one wants
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to buy a piece of property near that site either.
MR. HOHMAN: Well, hopefully, when we
get this done, that stigma will be gone.
A SPEAKER FROM THE FLOOR: What"should
we do with our taxes. Should we take this in—
MR. HOHMAN: That's a matter between you
and the local assessors and one in which EPA will not
get involved.
Any other questions from the floor at
this time?
11 j! A SPEAKER FROM THE FLOOR: When the soil
12 | goes into this container, the contaminants — you know,
13 you said — is that going to go into our air at all? Is
i
that an enclosed-type thing or are you going to be —
if a gust of wind comes by and blow this over?
MR. ROBINSON: Essentially, it's a facility
which the contaminant soil would be moved into, all
enclosed1 inside, okay, and then the warm-air would be !
r j
forced through the soil and the contamination will come '
off the soil into the air inside this machine. It's still
not going out anywhere. But it has to go somewhere.
Before that air with the contaminants is released into
the environment, it will go through an additional pollution
control device in which only clean air will be released
4
to the atmosphere and the material that goes — that
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contamination, before it goes into the atmosphere, will
be removed from the site.
A SPEAKER FROM THE FLOOR: The contaminant!
that are sitting in the soil or water, whatever, now
,
is it a type of contaminant that is contaminating that
air right now? X mean, if we walk by and breathe the
air—
MR. ROBINSON: We have — we know the
level of contamination in the soil and one of the natures
of the contaminants is that they volatize out of the soil
11 !• into the air. However, the amount in the soil itself
12 :'; if very low and the amount expected to volatize off will
i;
13 i| not be a threat as you are walking by the site.
i;
I
14 i! -A SPEAKER FROM THE FLOOR: If it does
jl
15 f g«t in the air, is there anybody who can tell us what
l!
16 ! will happen —
17 ;. MR. HOHMAN: Well, one of the things that
i
18 ' will be done when we set up any kind of operation like
this, as part of the actual design of the operation, there
will be an air monitoring program also involved, both
around the outside edge of the property and also monitors
and so forth on the equipment itself, so that we will
know what is happening, what has happened, make sure .there
isn't any release that would be a problem.
A SPEAKER FROM THE FLOOR: Is there going
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to be a person there, if we have any questions or problems,
that we could walk over and talk to while all this is
going on?
be a—
be?
MR.. HOHMAN: Yes.
MR. MCALLISTER: Yes, again, there will
A SPEAKER FROM THE FLOOR: Who will that
MR. HOHMAN: Hard to say at this point.
MR. MCALLISTER: Project coordinator.
MR. HOHMAN: Project coordinator or whatever
There will be an individual there that's responsible for
13 j' the operation that is available to :talk to to people on
ii
a regular basis and so forth, any problems that might
come up.
It isn't a case of just hiring a firm
17 j: to come in and the company that you hire to do the work
i;
comes in and they are the only ones there. There is
someone there from the government overseeing it. It might
be somebody from EPA; it could be somebody from the state.
MR. GABRIEL: Where do you expect the
work to start, with respect to the actual work on the
premises?
MR. ROBINSON: There's two actual work
4
activities that we have discussed. One being the very
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near term removal of the abandoned waste that's up in
the lab. That we anticipate should start very shortly.
I'm talking a couple of weeks, a month, or so, as we get
the people on-site for that.
The other portion of the cleanup that
we have discussed, that is the major soil treatment, our
aeration facility, et cetera, the basic timetable for
that is/ once we formalize our decision on this remedy,
which we will do at the end of March, the decision's
formalized. We will then properly design this alternative.
And that will take a certain period of time before we
can actually implement, you know, get out and start
digging that soil and putting it through the machine.
|j Estimated time frame for that design is
.. „ roughly a year or so, six months to a year.
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A SPEAKER FROM THE FLOOR: So, meanwhile,
in the next year, while this soil is still sitting there,
that guard is going to sit there and it's still going
to be—
MR. ROBINSON: No, the guard will be
leaving the site once we have the near term activity done;
that is, the removal of the abandoned stuff up in the
lab.
MR. HOHMAN: There will be a fence around
it?
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MR. ROBINSON: Right. And, if you recall,
the first — we will be constructing a fence. That will
certainly be done before the design and implementation
of our actual soil treatment.
So, as soon as possible, after March,
we will be going to activities to get the fence up?
MR. GABRIEL: Will the fence run the
cor.plete perimeter?
MR. ROBINSON: The fence will run roughly
the complete perimeter. Let me point that out. It would
11 !| run along First street, along here, the back of the site.
However, the fence — we had actually two proposed
13 i locations for the fence, one being right across this berm,
and the other being on the — right along the property
line.
Right now we are proposing across the
berm, because the only contamination that someone could
actually get to is in the wet area, right here, in the
wet area, so right across the berm. There is no soil
contamination between the berm and the canal.
Now, recall, we said no contamination
moved passed the canal. The only contamination from the
berm down might be groundwater and there is certainly
no way that anyone could, you know, get to the groundwater,
4
So, the intent of our fence is to prevent
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anyone from getting to the — contacting the soils that
are contaminated.
MR. CHOURARD: If all of the contaminants
were removed from the site, in barrels, in drums, or
sealed containers, of that type, what would the timetable
by for that type of a procedure, rather than getting into
this aeration and putting it up on the site and kind of
rendering it harmless down there?
MR. HOKMAN: Well, the problem is that
some of the material — the material that's in the trailer
11 !{ and so forth — that material you are talking about? I'm
12 I; not sure I understood the question.
r
13 || MR. CHOURARD: What I'm hearing is, you
could go over a year or whatever — my question is this:
15 |j If it was contained and removed from the site, rather
than getting into this aeration and blowing the steam
17 j; and trying to render some of it harmless on the site;
18 Ij what would the timetable be?
MR. HOHMAN: It could conceivably take
you longer. If you talk about, for example, picking up
all the contaminated soil and putting it in containers
and taking it away, is that—
MR. CHOURARD: I think that's what one
of your options are.
«
MR. HOHMAN: Yeah, it could — again,
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one of the problems you would have there would be whether
or not you could find an operating — adequate, licensed
disposal facility that could take it. Quite often, you
have to stage it. You can ship a few drums at a time.
That could stretch out over a long period of time. You
still have to go through all of the work that we have
to do — ori most of the work that we have to do for the
design, including making sure you know exactly where the
contaminated soil is and what it is contaminated with
and so forth, before you could ship it off.
11 :; So, it would be probably — might be a
j!
12 ij little bit quicker, but, again, there's an awful lot of
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13 S! uncertainties, so it could conceivably take you a lot
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14
15
longer, by the time you actually managed to get rid of
the material.
MR. CHOURARD: You've generated some
17 prices here to remove this material and render it harmless,
as you said earlier, 3.4 million. How is this generated,
this cost. Was it put out to bid already, and do you,
in fact, have some firm numbers, or is it just kind of
educated guesswork and it could go 7 million or .10 million.
Is there any threat that the funds won't
— there won't be enough funds to do whatever option you
chose to do? You know, do we have to go in there and
4
fight for more money if it goes over? What's the policy?
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MR. HOHMAN: No, those are engineering
estimates basically developed by our consultant, using
a wide variety of sources of what bids are elsewhere in
the country for that kind of activity and so forth. Some
of them you can pick up — for example, fencing you can
get a pretty good idea on by calling a couple of companies,
and so forth, but the other stuff is based on what's going
on elsewhere in the country, unit costs and so forth.
They are not bids.
It is possible that when you actually
go out to bid, you know, your bids will come in a lot
higher, in which case the Agency is committed to get the
13 jj job — the cleanup done, and we would have to take the
money out of the Superfund to do it.
MR. CHOURARO: The answer to the question ia
unlimited sources are available, once you make a commitment
to go in there to finish that up, regardless of -- there's
no constraints upon you.
MR. HOHMAN: Well, I think there is a
budgetary constraint if — let me just draw an extreme
example, and leave out the fact that we do have responsible
parties here and they may well decide they want to do
the cleanup or whatever, instead of the federal government,
but, if the federal government were to be funding a project
t
like this, we have a rough idea early on in the process,
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and we go through a budget process, we will' have money
targeted in our budget for the next fiscal year to cover
about three and a half million dollars worth of work on
a project like this.
There's always a little contingency built
in there and so forth, recoginizing the uncertainties
of the estimate.
Now, if the bids came in and the low bid
was $4 million; probably out of the grand scheme of the
national Superfund for the next fiscal year, that
ii
11 appropriation would be able to slip another project somehow
make up the $600,000 difference and sign the contract
13 r and start the work.
If, however, the bids came in at $10 ir.illio;
and I needed another $7 million, probably you would have
to wait at least another fiscal year to get that extra
money through the budget, because we have a budget, even
though it's Superfund as such, the money is still
appropriated each year by Congress and we have to kind
of budget out how we are going to make it pay; how we
are going to do it.
MS. VERONESI: My other concern is this:
I know the Town of Bridgewater owns that terrible piece
of property. Will the Town be responsible for any of
the cleanup?
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MR. HOHMAN: Do you want to make a
statement on that?
MR. MCALLISTER: Well, the Town, as the
technical owner, is technically a responsible party.
There is also a technical way they may not be considered
to be a potentially-responsible party, under the way that
the Superfund was amended. There is a provision in there
that municipalities or governmental entities that take
property through a tax-delinquency action, if it's an
10 involuntary taking, are not considered owners and operators
11 Actually, I think there are — our approach
j
12 |, in this case is to try to get the people who caused the
13 j: problem to pay for the cleanup, and we wouldn't be trying
~
14 |l to get the Town of Bridgewater to be bearing the cost
i
!
15 jj of the cleanup because we think that we have the potential
— the generators, the owners and operators out there
who will pay for it.
MS. VERONESI: It's nice to hear. Thank
you,
A SPEAKER FROM THE FLOOR: Where's all
this stuff going that you say you are cleaning up and
taking out? Where are you taking it to? Where's it
going?
MR. ROBINSON: The material, again, we
are talking about two portions. The material that we
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1 are going to be doing in the very near term, the removal
2 of the stuff from- the lab, that will be taken off-site
3 and incinerated and properly disposed of.
4 Actually in~
* MR. HOHMAN: Well, we can't tell for sure,
6 because, again, we have to — when you take stuff off
7 to be incinerated, it has to go to a licensed operator
8 — hazardous waste incinerator. There are half a dozen
9 I of then in the country, and what happens is that at the
i
i
10 time we are getting ready, we contact each of them to
11 | see whether or not they have the capacity.
12 | There is also a requirement, we check
13 ! with the State and EPA Region, wherever those facilities
*
14 .are located, to be sure they are in compliance'with
15 I something we call our off-site policy, which basically
16 i says you have to be in compliance with all of the laws
17 ' and requirements before EPA will ship hazardous waste
18 ! .to your site from a Superfund operation.
ij
19 . Once we know that, then there will be
20 i negotiations to decide which facility it might be. It
21 | could conceivably in Ohio; could be in New Jersey; could
22 ! be in Alabama — where else, Michigan — I mean, it could
23 be any one of a number of places, New Jersey, that it
24 would go to. That will be decided when we actually get
25 ! ready to get rid of it.
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A SPEAKER FROM THE FLOOR: My question
kind of goes to —- and this is probably more or less for
the state DEQE. How can you state right now — we
know, for example, off in our industrial park we have
a company that's been burying about 20,000 gallons of
what they have told our Board of Health and Selectmen,
has been termed hazardous waste by the state, yet they
don't have a DEQE site assignment. It's been there for
ten years.
MR. PANCHAL: I don't know if you are
referring to Safety-Kleen or some other facility, I am
12 !; not sure, but if there is any facility in opertaion
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then they do have a yearly inspection on the facility
by our licensing people for permits.
A SPEAKER FROM THE FLOOR: Now, shouldn't
they be fined, you know, when you go out there and inspect
and find out that they didn't have a site assignment and
18 ! didn't possibly follow the procedures that are set out
by the State for burying this stuff?
MR. PANCHAL: Well, in the firt place,
the site assignment is not subject to annual renewal.
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1 A SPEAKER FROM THE FLOOR: Does plants
2 like this that do bury chemicals in the ground, do they
3 have to file with the State and be inspected every so
4 often, how their tanks are set up and so forth?
5 MR. PANCHAL: If the facility is approved
6 then an annual inspection is in order and it is
7 required by the State and also by the fire department.
8 At this time the facility is inspected and compliance
9 and they are supposed to check the tank structures
10 j and things like that, and we do have a inspection
U just to make sure that they are in compliance.
12 I MR. HOHMAN: Thank you.
13 Any other questions or comments?
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14 MR. -CHOURARD: Yes.. Could you briefly
15 explain how much money has been spent to date on this
16 project?
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17 ! MR. ROBINSON: I really would not — I I
IB can't say right off the top of my head. I would certainly •
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19 let you know, if you give Margaret your phone number,
20 Paul. Give Margaret your phone number or give me your
2i phone number, actually, I'll definitely get back to you.
22 MR. HOHMAN: Any other questions or
23 comments?
24 MR. CHOURARD: Has the State seized any
25 I assets of these individuals?
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MR. MCALLISTER: The State has, under
the Mass. General Laws 2IE, they have what is known as •
a Super lien, and I believe they have liens on everything
the Cannons own.
MR. CHOURARD: Can you tell us where all
this is, where their assets are?
MR. MCALLISTER: The State can — as a
matter of fact, I was just looking at this. They have
property in Yarmouth; they have a number of pieces of
property, too. There's a sister Cannons facility in
Yarmouth, West Yarmouth, I guess. There are a number
of piece« around that they have with liens on them, yes.
MR. CHOURARD: How can we get a list
of the areas with liens on them?
15 MR. ROBINSON: Should we have him get
it
16 Ii ahold of Greg Wilson? Is that—
MR. MCALLISTER: Yeah, I think that would
be the best thing to do.
MR. CHOURARD: I mean, it's public
information. When you put a lien on property, it's public
information.
MR. HOHMAN: Yes, through the Registry
of Deeds. It's a question of how do you go about finding
out — and I think the person to talk to is the Assistant
4
Attorney General, who is handling the case for the
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1 Commonwealth of Massachusetts, a fellow named Greg Wilson,
2 and I can give you his phone number if you would like
3 to ask him.
MR. CHOURARD: My suspicion, these
individuals live high off the hog at everyone else's expense
I just want to see what's been attached and what hasn't.
7 I heard that they got six months in jail. I call that
8 totally unreasonable for dumping contaminants in public
9 drinking water.
10 MR. HOHMAN: Okay, any other questions
11 ! or comments?
12 j (No verbal response.)
[!
13 MR. HOHMAN: If not, before I close, let
14 me again thank you for coming out tonight. And let me
15 remind you that the public comment period is still open
16 and that you can give us comments any time until the close
17 j of business on March 4.
18 . You should submit those comments to Wayne
19 Robinson in our office in Boston. His address is on the
~2Q fact sheet.
2i All of the comments that we receive will
22 be addressed in something called' the Responsiveness
23 Summary, which will be attached to our final decision
24 document which will explain any comments that we receive,
*
25 and what our response was in answer to those comments.
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1 So, if there is no further questions and
2 comments tonight, again, thank you all for coming and
3 I declare this meeting adjourned,
(Whereupon, at 8:34 p.m., the meeting
5 I was adjourned.)
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1 |! CERTIFICATE OF REPORTER . 49
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This is to certify that the attached proceeding
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before: MERRILL HOHMAN. Director
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CANNONS ENGINEERING CORPORATION SITE
PROPOSED SUPERFUND CLEANUP PLAN
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Docket No. N/A
Place: Bridgewater, Massachusetts
Date: February 25, 1988
were held as herein appears, and that this is the original
transcript thereof.
,/.
OFF^CIAlfeSP^ftT^HSignature)
^^^
MARTIN T. FARLEY
(Name typed)
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APPENDIX B
ADMINISTRATIVE RECORD INDEX
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ADMINISTRATIVE RECORD INDEX
for the
CANNONS BRID6EWATER Sit*
This Administrat ive Record support* the remedial Actions determined by the
Record of Decision (ROD) dated April, 1988.
1 . 0 Pr •- Rented i a 1
1. EPA Notification of Hazardous Waste Sits, Baudreau,
John, Sippican Corp.
£. Crk.no* led geme^t of Notification of Hazardous Waste
Activity, US EPA.
3. •";-•* '.tfl firi*iy-ris of Cf-.r r..!,r.« E ng i neer i ng Corp. f •:••••
Solvent and Oil Contaminant s Includas Written Total
WS/L of 0S/CI
-,iP:s Cna lysis - 5*^ple WOs. D01876, DC 1
fnsip Acti.it'** c*'t»>- Co''ipl>int of Leaking 55 Gall-:
->S. at Site. 4i?£-55 Gallons Drums in Poor Condition
«• Observed During Inspection of Cleanup. Future
Inspection Planned, White, Ronald, MA DEQE (Ul/lA/Sl ) .
"S-si'-Sing Har*rci-i".is W*stt-Pridgewat»r Cannons
Corporation Notice of Violation 315 CMS
r..:.v*r,, Robert E, KA DECE dZic'/SP/Sl ) .
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PS port of Inspection of Hazardous Waste Storage at
?>*iiJrj*'i*i* t»r Sit* - Also Irfo»*rnwd of Solidified and
Sev.: -Solidified Waste, White, Ronald, MA DEOE
B^idgewate** Hazardous Waste Inspection -
Cannons Engineering. Inspection Made on (53/01/81 -
Five Observations Listed, White, Ronald, MA DEQE
9. Inspection and Sampling of Bridgewater Site of
Locations C-l through C-3 Includes Sketch of Locations,
White, Ronald, MA DEQE (07/08/81).
10. Report on W*ste Transfer from Tanks at Cannons Site
Includes Amounts of Materials, White, Ronald, MA DEQE
(98/05/61).
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