United States
Environmental Protection
Agency
Office of
Emergency and
Remedial Response
EPA/ROD/R01-89/043
September 1989
SEPA
Superfund
Record of Decision
Norwood PCBs, MA
-------
50272-101
REPORT DOCUMENTATION
PAGE
1. REPORT NO.
EPA/ROD/R01-89/043
3. Recipient's Accession No.
4. Title and Subtitle
SUPERFUND RECORD OF DECISION
Norwood PCBs, MA
First Remedial Action - Final
5. Report Date
09/29/89
7. AuthOf(»)
8. Performing Organization Rept No.
9. Performing Organization Name «nd Address
ia Pro|sctfTsek/Work Unit No.
11. Contract(C) or Gr«nt(G) No.
(C)
(G)
12. Sponsoring Organization Nemo and Address
U.S. Environmental Protection Agency
401 M Street, S.W.
Washington, D.C. 20460
13. Typs of Report t Period Covered
800/000
14.
15. Supplementiry Nolee
16. Abstract (Umit: 200 words)
The 26-acre Norwood PCBs site consists of several industrial and commercial properties,
parking areas, and vacant lots in Norwood, Norfolk County, Massachusetts. Significant
site features include the Grant Gear property to the north, an office park complex which
extends along the western portion of the site, and residential areas which border the
site to the west and north. Meadow Brook, which discharges to the Neponset River, and an
associated wooded wetlands area make up the north site boundary. Four piles of sediment
sludge, previously dredged from the stream, are located on the.south bank of the brook.
Site contamination originated from disposal practices of previous businesses, primarily
electrical equipment manufacturing, that operated from the building now owned by Grant
Gear Realty Trust. In April 1983 the State responded to a citizen report of previous
industrial waste dumping at the site and took surficial soil and sediment samples which
confirmed PCB contamination. In June 1983 EPA removed 500 tons of PCB- contaminated soil
from the office park complex and Grant Gear properties and disposed of it offsite. The
State implemented an Interim Remedial Measure in 1986 to limit access to areas with high
surface contamination on the Grant Gear property by constructing a 1.5-acre cap. The
primary contaminants of concern affecting soil, sediment, ground water, and building
surfaces are VOCs including TCE and PCE; other organics including PCBs, PAHs, and
phenols; and metals.
(See Attached Sheet)
MA
17. Document Analysis a. Descriptors
Record of Decision - Norwood PCBs,
First Remedial Action - Final
Contaminated Media: soil, sediment, gw
Key Contaminants: VOCs (PCE, TCE), other organics (PAHs, PCBs, phenols), metals
b. Identifiers/Open-Ended Terms
c. COSATI Reid/Group
18. Availability Statement
19. Security Class (This Report)
None
20. Security Class (This Page)
None
21. No. of Pages
271
22. Price
(See ANSI-Z39.18)
See Instructions on Reverse
Ur IIONAL rOHM 272 (4-77)
(Formerly NTIS-35)
Department of Commerce
-------
DO NOT PRINT THESE INSTRUCTIONS AS A PAGE IN A REPORT
INSTRUCTIONS
Optional Form 272, Report Documentation Pag* Is baaed on Guideline* for Format and Production of Scientific and Technical Report*,
ANSI Z39.18-1974 available from American National Standard* Institute, 1430 Broadway, New York, New York 10018. Each separately
bound reportlor example, each volume In a mutUvolum* setshaU have It* unique Report Documentation Pag*.
1. Report Number. Each Individually bound report hall carry a unique alphanumeric designation assigned by the performing orga-
nization or provided by the aponcoring organization In accordance with American National Standard ANSI Z39.23-1974, Technical
Report Number (STRN). For registration of report code, contact NTIS Report Number Clearinghouse, Springfield. VA 22161. Use
upperc*** letter*, Arabic numerals, slashes, and hyphen* only, a* In the following example*: FASEB/NS-75/87 ind FAA/
RD-7S/09.
2. Leave blank.
3. Recipient's Accession Number. Reserved for use by each report recipient
4. Title and Subtitle. Title should Indicate clearly and briefly the subject coverage of the report, subordinate subtitle to the main
title. When a report I* prepared In more than on* volume, repeat the primary title, add volume number and Include subtitle for
the specific volume.
5. Report Date. Each report shall carry a date Indicating at leest month and year. Indicate the basis on which It w. , selected (e.g.,
date of Issue, date of approval, date of preparation, date published).
6. Sponsoring Agency Code. Leave blank.
7. Authors). Give name(s) In conventional order (e.g., John R. Doe, or J. Robert Doe). List author's affiliation If It differs from
the performing organization.
8. Performing organization Report Number. Insert If performing organizaton wishes to aasign this number.
9. Performing Organization Name and Mailing Address. Give name, street, city, state, and ZIP code. List no more than two levels of
an organizational hierachy. Display the name ot the organization exactly aa It should appear In Government indexea such as
Government Report* Announcement* & Index (GRA & I).
10. Project/Taak/Work Unit Number. Use the project, task and work unit numbers under which the report was prepared.
11_. Contract/Grant Number. Insert contract or grant number under which report was prepared.
12. Sponsoring Agency Name and Mailing Addres*. Include ZIP code. Cite main sponsors.
13. Type of Report and Period Covered. State Interim, final, etc., and, If applicable, Inclusive dates.
14. Performing Organization Code. Leave blank.
15. Supplementary Notes. Enter Information not Included elsewhere but useful, such ss: Prepared In cooperation with... Translation
of... Presented at conference of... To be published In ... When a report Is revised, Include s statement whnth«r the new
report supersedes or supplements the older report.
16. Abstract. Include a brief (200 words or less) factual summary of the most significant Information contained In the report. If the
report contains a significant bibliography or literature survey, mention It here.
17. Document Analysis, (a). Descriptors. Select from the Thesaurus of Engineering and Scientific Terms the proper authorized terms
that Identify the major concept of the research and are sufficiently specific and precise to be used aa Index entriea for cataloging.
(b). Identifiers and Open-Ended Terms. Use Identifiers for project names, code names, equipment designators, etc. Use open-
ended terms written In descriptor form for those subjects for which no descriptor exists.
(c). COSATI Field/Group. Field and Group assignments are to be taken form the 1964 COSATI Subject Category List Since the
majority of documents are multldlsciplinary In nature, the primary Field/Group asaignment(s) will be the specific discipline,
srea of human endeavor, or type of physical object. The appllcatlon(s) will be cross-referenced with secondary Field/Group
assignments that will follow the primary posting(s).
18. Distribution Statement Denote public releasablllty, for example "Release unlimited", or limitation for reasons other than
security. Cite sny svailat "Ity to the public, with address, order nun>er end price, If known.
19. & 20. Security Classification. Enter U.S. Security Classification In accordance with U. S. Security Regulations (I.e., UNCLASSIFIED).
21. Number of pages. Insert the total number of pages, Including Introductory pages, but excluding distribution list, If any.
22. Price. Enter price In paper copy (PC) and/or microfiche (MF) If known.
A GPO I983 0 - 381-526(8393) OPTIONAL FORM 272 BACK
(4-77)
-------
EPA/ROD/R01-89/043
Norwood PCBs, MA
First Remedial Action - Final
16. Abstract (Continued)
The selected source control remedial measures include excavation, solvent extraction,
and onsite disposal of approximately 31,000 cubic yards of unsaturated soil and dredge
pile sediment and approximately 3,000 cubic yards of Meadow Brook sediment followed by
installing a soil cover over the treated soil; offsite incineration and disposal of
extracted oils containing PCBs; flushing and cleansing portions of the Grant Gear
drainage system; cleaning and sealing roof surfaces, and decontaminating machinery,
equipment, and floor surfaces in the Grant Gear building which exceed TSCA cleanup
levels; ground water collection in a barrier drain trench with onsite treatment by carbon
adsorption for PCBs, air stripping for VOCs removal, and precipitation/filtration for
.:netals removal; wetlands restoration; long term environmental monitoring of ground water,
soil, sediment and building surfaces; and institutional controls restricting ground water
and land use. The estimated present worth cost for this selected remedy is $16,100,000,
which includes annual O&M costs for up to 10 years.
-------
Declaration of Record of Decision
Remedial Alternative Selection
Site Name and Location
Norwood PCS Superfund Site
Norwood, Massachusetts
Statement of Purpose
This Decision Document presents the selected remedial action
for this 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 Commonwealth of Massachusetts has concurred with the
selected remedy.
Statement of Basis
This decision is based on the administrative record which
was developed in accordance with Section 113(k) of CERCLA
and which is available for public review at the information
repositories located in the Morrill Memorial Library,
Norwood, Massachusetts, and at 90 Canal Street, Boston,
Massachusetts. The attached index identifies the items
which comprise the administrative record upon which the
selection of two remedial action is based."
Assessment of the Site
Actual or threatened releases of hazardous substances from
this site, if not addressed by implementing the response
action selected in this ROD, may present an imminent and
substantial endangerment to public health, welfare, or the
environment.
Description of the Selected Remedy
The selected remedial action for the Norwood PCS site
consists of source control and management of migration
components.
-------
The source control remedial measures include:
Excavation, treatment by solvent extraction and on-site
disposal of approximately 28,500 cubic yards of soils,
dredge pile materials and Meadow Brook sediments
contaminated at levels exceeding specified soil and sediment
cleanup goals. Off-site incineration of the oil extract
from the solvent extraction process. A soil cover will be
placed over the disposal areas for treated soils. On-site
incineration is the contingency remedy for the treatment of
soils and sediments;
Flushing and cleaning of the Grant Gear roof surfaces and
drainage system. To the extent that this activity will not
satisfy specified action levels, the roof will be
encapsulated and the drainage system contained, and
replaced.
Decontamination by solvent washing of equipment, machinery
and floor surfaces within the Grant Gear building.
The management of migration measures include:
Barrier drain trench to collect contaminated on-site
overburden and shallow bedrock groundwater. An extraction
system consisting conceptually of nine shallow extraction
wells is the contingency remedy; and
Groundwater treatment consisting of carbon adsorption for
PCBs removal, air stripping for VOCs removal and
precipitation/filtration for metals removal; Groundwater
treatment will continue until specified groundwater cleanup
levels are achieved.
Additional measures include:
Wetland restoration/enhancement of on-site wetland areas
adversely impacted by remedial action and ancillary
activities;
Long-term environmental monitoring of on-site groundwater,
soils, sediments and surfaces within the Grant Gear
building; and
Institutional controls to prevent the use of groundwater in
the zone of contamination as a drinking water source and
to prevent disturbance of contaminated untreated subsurfa'ce
soils within the Grant Gear property, sediments within the
Grant Gear drainage system and soils under pavement in areas
outside Grant Gear.
The estimated present worth cost for the selected remedy,
including both source control and management of migration is
$16,100,000. The estimate includes capital costs as well as
construction and operation and maintenance costs.
-------
Declaration
The selected remedy and contingency remedies are protective
of human health and the environment. The remedies satisfy
the statutory preference for treatment that permanently and
significantly reduces the volume, toxicity and mobility of*
the hazardous substances, pollutants and contaminants as a
principal element. The selected remedy and the contingent
remedies also utilize permanent solutions and alternative
treatment technologies to the.maximum extent practicable,
and are cost-effective. The selected remedy and contingency
remedies attain federal and state requirements that are
applicable or relevant and appropriate (ARARs).
.
* ' '
DATE ' ' Paul 6. Keough
Acting Regional Administrator
EPA-Region I
-------
ROD DECISION SUMMARY
NORWOOD PCB SUPERFUND SITE
NORWOOD, MASSACHUSETTS
SEPTEMBER 29, 1989
U.S. ENVIRONMENTAL PROTECTION AGENCY
REGION I
-------
Norwood PCB Superfund Site
Table of Contents
Contents Page Number
I. SITE NAME, LOCATION AND DESCRIPTION 1
II. SITE HISTORY 2
" A. Response History 2
B. Enforcement History 4
III. COMMUNITY RELATIONS 6
IV. SCOPE AND ROLE OF OPERABLE UNIT OR RESPONSE
ACTION . I . 7
V. SITE CHARACTERISTICS 7
A. General 8
B. Hydrogeology . . 9
C. Soil 10
D. Sediments 11
E. Wetlands 12
F. Surface Water .12
G. Groundwater 13
H. Grant Gear Building. ..... 14
I. Air 15
VI. SUMMARY OF SITE RISKS 16
VII. DOCUMENTATION OF SIGNIFICANT CHANGES .... 21
VIII. DEVELOPMENT AND SCREENING OF ALTERNATIVES. . 22
A. Statutory Requirements/Response Objectives . 22
B. Technology and Alternative Development and
Screening 24
IX. DESCRIPTION/SUMMARY OF THE DETAILED AND
COMPARATIVE ANALYSIS OF ALTERNATIVES .... 25
A. Source Control (SC) Alternatives Analyzed. . 25
B. Management of Migration (MM) Alternatives
Analyzed 34
X. THE SELECTED REMEDY 38
A. Description of the Selected Remedy 38
B. Rationale for Selection 62
XI. STATUTORY DETERMINATIONS 66
A. The selected Remedy is Protective of Human
Health and the Environment 66
B. The Selected Remedy Attains ARARs 67
C. The Selected Remedial Action is Cost
Effective. 7'3
-------
D. The Selected Remedy Utilizes Permanent
Solutions and Alternative Treatment
Technologies or Resource Recovery
Technologies to the Maximum Extent
Practicable 76
E. The Selected Remedy Satisfies the Preference
for Treatment as a Principal Element .... 77
XII. STATE ROLE 77
LIST OF FIGURES
Flour* Number P_aofl
1 Site Location Map .79
2 Study Area 80
3 Delineation of 100-year Floodplain 81
4 Site Plan 82
5 Wetland Zones 83
6 Location of Monitoring Wells 84
7 Soil Remediation Areas 85
LIST OF TABLES
Tabla Number Pacre Number
1 Surficial Soil Contaminant Concentrations . .86
2 Subsurface Soil Contaminant Concentrations . 88
3 Dredge Pile Contaminant Concentrations ... 90
4 Sediment Contaminant Concentrations .-. : . .91
5 Drainage System Sediment Concentrations . . .93
6 Surface Water Contaminant Concentrations . . 95
7 Water Table Contaminant Concentrations ... 96
8 Bedrock Aquifer Contaminant Concentrations . 98
9 Contaminants of Concern 99
10 Summary of Human Health Risks 100
11 Alternative Screening Results 101
12 Evaluation of SC Alternatives 102
13 Evaluation of MM Alternatives 108
14 Soil Cleanup Levels Assumptions Ill
15 Summary of Soil Component 113
16 Chemical-Specific ARARs 114
17 Location-Specific ARARs 117
18 Action-Specific ARARs 119
19 Groundwater Standards .128
20 Health-Based Groundwater Standards 129
21 Estimated Total Cost of Remedy 131
APPENDICES
Responsiveness Summary. Appendix A
Administrative Record Index Appendix B
.'itnte Concurrence Letter Appendix C
-------
ROD DECISION SUMMARY
I. . SITE NAME, LOCATION AND DESCRIPTION
SITE NAME: Norwood PCB Site.
SITE LOCATION: Norwoodr Norfolk County, Massachusetts
SITE DESCRIPTION:
The Norwood PCB Site is located approximately 14 miles
southwest of .the City of Boston. The 26 acre Site consists
of several parcels of land including industrial/commercial
properties, associated parking areas and adjacent fields.
The Site is bordered to the north by Meadow Brook, to the
east by the heavily commercial U.S. Route 1 and the Dean
Street access road, to the south by Dean Street, and to the
west by the residential Removal Road. Figures 1 and 2
illustrate the study area.
It is estimated that approximately 250 people work within
the site boundaries each day. Employers include Grant Gear
Works, businesses located in office buildings on Kerry
Place, and the Norwood Hyundai automobile dealership. Two
residential areas exist near the Site. To the west,
approximately 26 homes border the Site on Dean Street and
Pellana Road. The other residential area is to the north,
separated from the Site by Meadow Brook and a wooded
wetlands area. Assuming an average of 3.8 -residents per
home, there are approximately 3040 residents living within a
1/2 mile radius of the Site.
To the east of the Site is the heavily travelled U.S. Route
1. Properties along U.S. Route 1 in the vicinity of the
Site are primarily commercial, and include automobile
dealerships, equipment rental businesses, a pet shop,
restaurants, and gasoline stations. A restaurant and a
Mobil gasoline station are located to the southeast of the
site, between the Dean Street access road and Route 1. A
shopping plaza, a car wash and two restaurants are located
across Dean Street to the south of the Site.
The northern portion of the Site is a small deciduous wooded
wetlands area drained by Meadow Brook. Meadow Brook is a
shallow stream approximately 12 feet wide and 6 to 12 inches
deep near the Site. The brook serves as a drainageway for
over 900 acres of densely developed land and discharges into
the Neponset River approximately 1,600 feet downstream of
the Site. Four piles of sediment previously dredged from
the stream (dredge piles) are located on the south bank of
-------
th« brook, between Route 1 and Kerry Place. The town of
Norwood has scheduled the brook for additional dredging and
restoration between Dean Street and Meadow Road (3,000 lin.
ft.) to reduce the frequency of flooding upstream of the
site. Figure 3 shows the extent of the 100-year flood
plain.
Two other known sites of contamination are in the vicinity
of the Norwood PCB Site. The Mobil gasoline station located
between the Dean Street access road and Route 1 was the site
of leaking underground storage tanks. Investigations
performed at the Norwood Press site, approximately 3,000
feet east of the Norwood PCB Site, revealed the presence of
volatile organic compounds (VOCs) in soil, groundwater and
surface water. However, results of the RI showed no
evidence that contaminants from either site have migrated to
the Norwood PCB Site.
All residential and commercial properties within or adjacent
to the Site are supplied with water from the Norwood
municipal system. The town is provided with public water
through a connection to the Massachusetts Water Resource
Authority (MWRA) system. It is reported that an
undetermined number of residences in the area use private
groundwater wells to supply water for gardening and lawn
sprinklers.
A more complete description of the Site can be found in
Chapter 1 of the RI Report (Ebasco, 1989a).
II. SITE HISTORY AND ENFORCEMENT ACTIVITIES
A. Response History
Contamination at the Norwood PCB Site originated from
disposal practices of the parties who owned the property or
operated businesses in the building located on the property
now owned by John and Robert Hurley, Trustees of the Grant
Gear Realty Trust. The building was constructed in 1942 by
Bendix Aviation Corporation, which produced navigational
control systems and conducted other electronic research in
the building for the U.S. Navy. In October 1947, the land
was purchased by Tobe Deutschman Corporation, which
manufactured electrical equipment at the Site, including
capacitors and transformers. The property was purchased in
October 1956 by Cornell-Dubilier Electronics, Inc., which
also manufactured electrical equipment at the facility. In
January 1960, the property was briefly owned by Maryvale
Corporation, and then purchased by the Friedland Brothers.
The Friedland Brothers leased the property to Federal
Pacific Electric Company, which held the lease on the
property until October 1979. During the period from I960 to
-------
1979, Federal Pacific Electric operated a business at the . *
Site, and sublet portions of the facility to Cornell-
Dubilier Electronics, Inc. and to Arrow Hart Corporation
which also manufactured electrical equipment at the
facility. Interpretation of aerial photographs from 1952
through 1978 shows that the site fencing extended to Dean
Street, encompassing that area identified as a vacant lot
and the Norwood Hyundai automobile dealership (Bionetics
Corporation, 1984). Throughout this period, the western
portion of the Site was undeveloped and used for storage of
materials by the owners/operators of the facility.
In 1979, the Site was subdivided. The northeastern portion
of the Site, .-'approximately 9 acres, was purchased by Grant
Gear Realty Trust which leased the facility to Grant Gear
Works, Inc., to produce gears for industry. The southern
and western portions of the Site, approximately 16 acres,
were purchased by Paul Birmingham, Paul Reardon and Jack
Reardon who further subdivided the property into seven lots
and added an access road, Kerry Place. The Reardons still
retain four of the seven original lots. The lots are now
occupied by commercial and light industrial buildings and
the Norwood Hyundai automobile dealership. One lot at the
corner of Dean Street and Kerry Place remains vacant, but
the owners have plans for development.
On April 1, 1983, the Massachusetts Department of
Environmental Protection (DEP), then known as the
Massachusetts Department of Environmental Quality
Engineering, received a telephone call from a citizen living
on Pellana Road reporting past industrial waste dumping and
contamination in the then vacant field of Kerry Pl^ce
between Pellana Road and the Grant Gear property. As a
result of this call, an initial field investigation by DEP
was conducted soon thereafter. On April 6, 1983, DEP
sampled surficial soils and Meadow Brook sediments. The
initial DEP investigations confirmed PCB contamination in
soils. The DEP immediately moved to restrict public access
to the field area and marked areas within the Grant Gear
fence to alert workers of the possible danger. Because
state funds were not available, the Commonwealth of
Massachusetts requested EPA to provide support using
Superfund money. EPA dispatched their Technical Assistance
Team (TAT) Contractor, Roy F. Weston, Inc., of Lexington,
Massachusetts, to aid DEP in collecting confirmatory samples
of the oil-stained areas along the western fence line and in
other areas on both the Grant Gear and Reardon properties.
Based on these findings, it was determined that an immediate
removal action to address all soils outside the Grant Gear
property with PCB concentrations greater than 50 parts per
million (ppm) was appropriate. The Agency planned to follow
the removal action vith a full Remedial Investigation
-------
designed to assess the nature and extent of the remaining
contamination.
Beginning June 23, 1983, EPA (through their subcontractor,
SCA Recycling Industries, Inc., of Braintree, Massachusetts)
began removal of contaminated soils on the Site. A total of
518 tons of contaminated soil was removed and disposed at
the SCA Model City, New York landfill facility. The soils
were removed from locations within the Kerry Place and Grant
Gear properties. Reported excavation depths were up to 30
inches. During the removal action, water samples taken from
the storm drain system behind the Grant Gear building
indicated low levels of PCB contamination. The removal
action was completed on August 5, 1983.
In December 1983, the Site was reviewed by the EPA Field
Investigation Team (FIT) Contractor and evaluated, using the
Hazard Ranking System, for possible listing on the National
Priorities List (NPL) of sites eligible for cleanup under
the Super fund program. EPA proposed to add the Site to the
NPL on October 15, 1984 (49 FR 40320), and the Site was
finally added to the NPL on June 10, 1986 (51 FR 21099).
Based on the preliminary findings of a 1986 Wehran
Engineering study for DEP and a 1986 GZA study performed for
Cornell-Dubilier, the DEP implemented an Interim Remedial
Measure (IRM) at the Site in January 1986. The IRM was
considered necessary to limit access to areas of highest
surface soil contamination within the fenced area of the
Grant Gear property. Specifically, DEP's contractor
installed a cap over a 1.5 acre portion of £he northwest and
southwest corners of the Grant Gear property. The
contaminated surface soils were covered with a filter fabric
liner and 6 inches of crushed stone. The capped areas were
enclosed with a 4 foot high wire mesh fence and the areas
were delineated with yellow hazard tape. The locations of
the capped areas are shown on Figure 4. Following the IRM,
Grant Gear has leased portions of their property, including
the covered areas to local dealerships for the storage of
new automobiles. Maintenance of the cap is presently
monitored and/or performed by DEP.
A more detailed description of the site history can be found
in the RI Report (Ebasco, 1989a).
B. Enforcement History
In June 1983, after EPA committed funds to conduct the
removal action at the Site at the request of Massachusetts,
EPA offered to the property owners the opportunity to
perform the work. The owners of the Kerry Place property
and of Grant Gear declined to assume responsibility for the
-------
work, and EPA initiated the removal action on June 24, 1983.
The removal action ended in August 1983, costing
approximately $200,000. At that time, Massachusetts was the
lead agency for the Site.
Massachusetts engaged in preliminary negotiations with
several former owners and operators to voluntarily perform
the RI/FS for the Site. As a result of these negotiations,
on August 29, 1985, Cornell-Dubilier Electronics, Inc. (CDE)
entered into an agreement with Massachusetts to perform a
study to better define the extent of contamination remaining
on-site as a first step towards undertaking a full-scale
RI/FS. The study report was delivered to Massachusetts in
April 1986. :
EPA issued information requests concerning prior activities
at the Site to the former and current owners and operators
of the Site in January 1985. .On October 17, 1985, EPA
notified 12 parties who were former and current owners or
operators of the facility of their potential liability-with
respect to the Site.
Prior to receiving notice of potential liability from EPA,
Grant Gear initiated a civil action in April 1985 against
parties who had owned or operated the facility since it was
constructed in 1942. John F. Hurley, et al. v. Cornell-
Dubilier Electronics. Inc.. et al.. Civil Action No. 85-
1417-Mc (D.C. Mass.). Grant Gear amended its complaint in
November 1985 to add several other parties. The Court
stayed the litigation initially to allow time for the
parties to decide whether to conduct the RI/FS. The stay
has been continued pending completion of the RI/FS.
In 1986, Massachusetts again attempted to negotiate with the
parties to voluntarily conduct the RI/FS. When an agreement
could not be reached, in March 1987 the Commonwealth
notified EPA that EPA should assume the responsibility of
the lead agency for the Site. Since the RI/FS negotiations
had been unsuccessful, EPA moved forward with conducting the
RI/FS with Superfund monies.
Grant Gear has been seeking a final settlement of its CERCLA
liability as an innocent landowner since 1985. At present,
the governments have declined to enter into such a
settlement. With passage of the Superfund Amendments and
Reauthorization Act of 1986, which expressly authorized EPA
to reach final settlements with landowners who qualify under
the de minimis provisions of Section 122(g)(1)(B) of CERCLA,
Grant Gear, EPA and Massachusetts have continued to engage
in settlement negotiations. No settlement agreement has-
been completed.
-------
However, Grant Gear was the subject of an enforcement action
by EPA under the federal Clean Hater Act for discharging
pollutants without the required permit into Meadow Brook,
which is classified as an antidegradation stream under the
Massachusetts Surface Water Quality Standards. Grant Gear
was first notified in November 1984 that it was discharging
without a permit required under the National Pollutant
Discharge Elimination System (NPDES). Although Grant Gear
submitted an application for the NPDES permit in April 1985,
it failed to apply to Massachusetts for an antidegradation
variance which is required before a discharge to Meadow
Brook will be permitted. As a result of Grant Gear's
failure to complete its permit application, on September 30,
1988, EPA denied Grant Gear's NPDES permit application. On
December 16, 1988, EPA Region I issued an administrative
order citing Grant Gear for violations of Section 301 of the
Clean Water Act, 33 U.S.C. § 1311, EPA Docket No. 1-89-05.
The Order required Grant Gear to conduct a study evaluating
wastewater disposal alternatives. Grant Gear submitted.the
required report on August 24, 1989.
Technical comments presented by the PRPs during the public
comment period were submitted in writing. A summary of the
PRP comments and EPA's responses to those comments are
included in the Responsiveness Summary in Appendix A of this
ROD. In addition, these documents are included in the
Administrative Record for the Site.
Special notice has not been issued in this case to date.
III. COMMUNITY RELATIONS '
Through the Site's history, community concern and
involvement has been moderately high. EPA has kept the
community and other interested parties apprised of the site
activities through informational meetings, fact sheets,
press releases and public meetings.
In June 1988, EPA released a community relations plan which
outlined a program to address community concerns and keep
citizens informed about remedial activities. On
March 16, 1988, EPA held an informational meeting in the
Balch Elementary School to describe the plans for the '
Remedial Investigation and Feasibility Study.
On June 15, 1989, EPA held an informational meeting to
discuss the results of the RI and the schedule that EPA and
DEP planned to follow in selecting the Superfund remedy for
the Site. A third informational meeting to present the
Agency's Proposed Plan and the other cleanup alternatives
presented in the Feasibility Study was held on August 10,
1989. During both meetings, EPA answered questions from the-
-------
public.
On August 11, 1989, EPA began a 30 day public comment period
to accept public comment on the alternatives presented in
the Feasibility Study and the Proposed Plan and on the other
documents which were a part of the administrative record for
the Site. At that time, EPA made the administrative record
available for public review at EPA's offices in Boston and
at the Morrill Memorial Library in Norwood, Massachusetts.
EPA published a notice and brief description of the Proposed
Plan in the Daily Transcript on August 8, 1989 and made the
plan available to the public at the Morrill Memorial
Library. On August 24, 1989, the Agency held a public
hearing 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.
IV. SCOPE AND ROLE OF RESPONSE ACTION
The selected remedy was developed by combining components of
different source control alternatives and a management of
migration alternative to obtain a comprehensive approach for
Site remediation. In summary, the remedy consists of nine
components:
1. Site preparation;
2. Excavation, treatment and on-site disposal of
soils and dredge pile materials;
3. Excavation, treatment and on-site disposal of
MeadoV Brook sediments;
4. Flushing and containment and replacement of
portions of Grant Gear drainage system, cleaning
and sealing of roof surfaces, and decontamination
of machinery and floor surfaces;
5. Collection of groundwater;
6. Treatment of groundwater;
7. Wetlands restoration/enhancement;
8. Long-term environmental monitoring and five-year
reviews; and
9. Institutional controls.
V. SITE CHARACTERISTICS
EPA conducted field investigations at the Site between
September 1987 and May 1989. These investigations were
designed to attain the following objectives: (1) conduct a
comprehensive characterization of the nature and extent of
contamination in the various media at the Site; (2) perform
an evaluation of present and future health risks and
environmental impacts resulting from the contamination at
the Site; and (3) collect sufficient data to be used in
-------
preparing a Feasibility Study (FS) to screen potential
remedial technologies and assemble and evaluate potential
reaedial alternatives Tor the Site.
Chapter 1 of the Draft Final Feasibility Study (Ebasco,
1989c) contains an overview of the results obtained from the
HI, while further details regarding sample locations, sample
methods and sample analyses are provided in the Final
Reaedial Investigation Report (Ebasco, 1989a) and
Endangeraent Assessment Report (Ebasco, 1989b). The
significant findings of the remedial investigation are
summarized below.
A* GENERAL
During the field investigations performed by EPA, ten media
were sampled at the Site: air, surficial soils, subsurface
soils, dredge pile solids, Meadow Brook sediments, surface
water, groundwater, Grant Gear building surfaces and water
and sediments within the Grant Gear drainage system.
Contaminant groups detected that were attributable to the
Site include PCBs, volatile organic compounds (VOCs), semi-
volatiles (extractables), and metals. The primary PCB
detected was Aroclor 1254, but Aroclor 1260 was identified
in some subsurface soil samples and other Aroclors were
detected in the drainage system. The primary site-related
VOCs detected were chlorinated aliphatic hydrocarbons.
Semi-volatiles identified as site-related included
chlorinated benzenes and other aromatic hydrocarbons
including polycyclic aromatic hydrocarbons (PAHs). Site-
related metals included cadmium, chromium, 'copper, nickel,
silver and zinc.
Based on the results of the field investigations, EPA has
concluded that the sources of contamination at the Norwood
PCB Site are surficial and subsurface soils, dredge piles of
sediments taken from Meadow Brook, sediments in Meadow Brook
and sediments in the drainage system of the building
operated by Grant Gear. EPA has further determined that the
overburden and bedrock groundwater beneath the Site is
contaminated with VOCs and PCBs. The Remedial Investigation
documented the highest levels of soil and groundwater
contamination is located in an area directly west of the
Grant Gear building.
In general, the types and concentrations of contaminants
decrease as the distance increases from the highest
contamination directly to the west of the Grant Gear
building. The pattern is typified, with few exceptions, by
the drop in concentration of volatile organics in
groundwater in the direction of groundwater Clow from the
southwestern portion of the Grant Gear property to the
8
-------
northeastern corner of the Site. Surface soil PCB
contamination exhibits a similar pattern with the vast
majority of the contamination confined to the 9-acre Grant
Gear property. The PCB concentrations of Meadow Brook
sediments decreased significantly between the Grant Gear
outfall and the Neponset River. This is apparently a
function of the manner in which PCBs are distributed in the
environment: primarily as adsorbed materials to soils and
sediments, so that their distribution in Meadow Brook
mirrors that of sediment deposition along the brook. On the
other hand, Meadow Brook sediments exhibit a comparatively
undiminished loading of PAHs throughout Meadow Brook, with
the highest values of PAHs detected downstream of Route 1.
This may be due to the urban nature of the environment
downstream of the Grant Gear outfall. Stormwater runoff
from these areas discharge to Meadow Brook and may increase
PAH concentrations in Meadow Brook sediments.
B. HYDROGEOLOGY
Hydrogeological investigations were conducted as part of the
RI to characterize groundwater flow and contaminant
transport. Based on the geological and geophysical evidence
presented in the report, the following conclusions are made:
1. On average, the depth to the water table throughout the
Site is less than 10 feet. The direction of
groundwater flow in the water table aquifer is
northeast in the northern portion of the Site
discharging into Meadow Brook and eastward to
southeastward in the southern portion*of-the Site. The
eastward to southeastward trend in the southern portion
of the Site indicates the effects of the bend in Meadow
Brook towards the Neponset River.
2. The shallow bedrock is highly fractured and the
fracture planes vary both in frequency and orientation.
In general, shallow bedrock exhibits the properties of
a porous medium, with groundwater flowing essentially
in the same direction as the water table aquifer.
Contaminant migration in the shallow bedrock aquifer
would be expected to flow towards Meadow Brook.
3. The direction of groundwater flow in deeper bedrock is
east-southeast in the vicinity of the Grant Gear
property. In the southern portion of the Site, bedrock
flow directions trends are to the south-southeast.
On a local scale, groundwater flow in the overburden and
shallow bedrock is influenced by surface feature? (i.e.,
Meadow Brook). Flow in the deep bedrock is controlled
locally by the distribution and orientation of fractures.
-------
C. SOIL
The geological units directly underlying the ground surface
at the Site include outwash plain deposits and fill
materials. The outvash plain deposits consist of an
extensive layer of gray, fine to coarse sand and gravel,
with moderate amounts of pebbles, some cobbles and minor
amounts of silt. The thickness of the outwash plain
deposits unit varies from 10.6 feet to 51.0 feet.
At the Site, granular fill material was found to vary in
thickness from 0 to 9.5 feet and consists of varying amounts
of silt and fine to coarse sand and gravel. Test pits
installed by GZA in 1986 identified the existence of rubble
fill material consisting of wood, metal scrap, metal cable,
concrete slabs, cinder blocks and pipes.
Tables 1 and 2 present the frequency of detection, average
concentration, and maximum concentration of major
contaminants detected in the RI in surficial soils
(0.0 - 2.0 feet) and subsurface soils. The horizontal
extent of PCB contamination is shown in Figure 4-1 of the
RI. Based on the distribution of PCBs, it appears that
areas of disposal were located in the western and northern
portions of the Grant Gear property, where the highest
concentrations (up to 26,000 ppro at one location and more
than 1,000 ppm over large areas) and the deepest occurrences
(greater than 20 feet) were found. In two locations west of
the Grant Gear building, the PCB contamination extends down
into the bedrock. The estimated total voluine bf
contaminated soils both saturated and unsaturated with
groundwater, with PCB concentrations above 10 ppm is
approximately 31,550 yd3, of which about 29,000 yd3 is
unsaturated.
During the course of the RI, four residential backyards were
sampled. Results of the PCB analysis of these samples
indicate that three of the four samples had PCB levels less
than 1 ppm. The detected PCB concentration in the fourth
sample was relatively low, at 1.7 ppm.
Chlorinated aliphatics, primarily trichloroethene,
tetrachloroethene, 1,2-dichloroethenes (total) and vinyl
chloride, as well as lower levels of chlorinated .ethanes,
were detected in surface and subsurface soils. Chlorinated
benzenes, primarily 1,2,4-trichloroben2ene, were detected in
surficial soils (up to 82 ppb) and subsurface soils (over
110 ppm). PAHs and phenols were also detected in surficial
and subsurface soils. All six site-related metals were
detected in subsurface soils in concentrations exceeding
background criteria. Of these, cadmium, copper, silver and
10 .,
-------
zinc were also found in concentrations exceeding background'
in surficial soil.
D. SEDIMENTS (Meadow Brook, Dredge Piles, Drainage system)
Tables 3, 4, and 5 present the frequency of detection,
average concentration, and maximum concentration of
contaminants detected in the RI in dredge pile sediments,
Meadow Brook sediments, and drainage system sediments,
respectively. Erosion of contaminated soils and continued
discharges from a contaminated drainage system of the Grant
Gear building represent sources of sediment contamination in
Meadow Brook. Additionally, Meadow Brook receives storm
drainage from the large urban watershed that drains into the
brook.
Contamination in the Grant Gear drainage system includes
PCBs (up to 189,000 ppm in sediments in a manhole leading to
the Grant Gear outfall), VOCs (primarily chlorinated
ethenes), semi-volatiles (including chlorinated benzenes and
PAHs) and metals. Contaminants released to the brook from
the Grant Gear drainage system consist primarily of PCBs,
VOCs and metals. The studies indicate that the principal
transport mechanism for PCBs is the movement of sediments to
which the PCBs are attached. A water sample taken at the
outfall of the drainage system into Meadow Brook contained
4.2 ppb PCBs, 48 ppb 1,2-dichloroethenes (total) and 39 ppb
trichloroethene.
PCBs detected in sediments ranged up to 1,100 ppm in the
Meadow Brook sediments and up to 3,850 ppm -in the dredge
piles. Every sample analyzed downstream of the Grant Gear
outfall contained detectable concentrations of Aroclor-1254
with the highest concentrations within 200 feet of the
outfall. Concentrations decreased in the direction of flow
and all samples below Route 1 contained less than 5 ppm of
PCBs. The highest concentrations in the dredge spoil pile
sediments were in the pile closest to the Grant Gear
outfall. The volume of stream sediments, from Meadow Brook
to the Neponset River, containing greater than 1 ppm PCB, is
2,900 yd3. The volume of dredge pile sediments containing
more than 1 ppm is 790 yd3.
The only VOC contaminant detected in the sediment that
appears to have originated at the Site was chloroform.
Site-related semi-volatile organic compounds identified in
the stream sediments include 1,2,4-trichlorobenzene up to
130 ppb and phenol up 76 ppb. Concentrations of the latter
two contaminants were higher in the stream samples taken
closest to the Grant Gear outfall, and all three were found
in the Grant Gear drainage system. Therefore, stream
sediment contamination is considered to be at least
11
-------
partially attributable to the outfall. The total
concentrations of PAHs increase in the downstream direction
and are believed to be at least partially attributable to
the fact, that the brook drains a large urbanized area. PAHs
are formed during combustion of fuels and as a result are
often detected in urban runoff.
Metals identified in stream sediments that may have
originated at the Site include chromium, copper, silver and
zinc, of which the latter two also were found in dredge pile
sediments. As listed in Table 5, thirteen metals were
detected in drainage system sediment samples in
concentrations exceeding twice the background level or
regional concentrations.
K. WETLANDS
The identification of wetlands, as described in the RI, is
based on their proximity to Meadow Brook and/or
identification of wetlands-type flora. Figure 5 shows -the
six zones of identified wetlands. Of the wetland areas
delineated in Figure 5, zone 1 is the most significant both
in terms of its areal extent and functional value. In
particular, zone 1 is a palustrine wetland system with a
surface area of approximately 1.82 acres, extending from
Kerry Place to the Route 1 culvert. In general, its wetland
boundary follows the top of the banks on both sides of the
brook and encompasses a pocket of palustrine wetlands
extending into the residential properties along Audubon
Road. Of the remaining wetlands, zones 4,5 and 6 are
relatively small isolated wetlands within the 'Grant Gear
facility, whereas, zones 2 and 3 are located east of Route 1
in a predominantly urban environment.
F. SURFACE WATER
As described above, Meadow Brook runs along the northern
boundary of the Site. Surface water samples were collected
along the length of Meadow Brook (starting approximately 600
feet upstream of the Grant Gear outfall) to the Neponset
River. Table 6 presents the frequency of detection, average
concentration and maximum concentration of contaminants
detected in surface water samples. As indicated in the
table, VOCs were detected infrequently at low levels.
VOCs detected in Meadow Brook surface waters that may have
been released from the Site included chloroform, 1,1,1-
trichloroethane, trichloroethene and tetrachloroethene with
a maximum total chlorinated aliphatics concentration of 12
ppb at an upstream location. Evan though some of these
compounds were detected in the effluent from the Grant Gear
outfall at higher concentrations, dilution and
12-
-------
volatilization quickly reduce the effect of discharge so ''
that downstream and upstream water contaminant levels are
approximately the same.
6. GROUNDWATER
EPA investigated the nature and extent of groundwater
contamination in two phases: the first one in Hay 1988
(Phase I) and second one in April 1989 (Phase II). The
Phase I investigation included the installation of thirteen
groundwater monitoring wells within the Grant Gear facility
and three background wells, two on Pellana Road and one on
Dean Street. During the Phase II investigation, an
additional/six monitoring wells were installed, including a
well nest in the northeast corner of the Site the point
farthest downgradient on-site. In addition, activities
performed during the Phase II investigation included
sampling and analysis of all previously installed monitoring
wells for a total of twenty-six groundwater monitoring wells
to confirm that groundwater contamination was still confined
to the Site. Figure 6 shows the location of monitoring
wells.
Contaminants detected in collected groundwater samples
included PCBs, VOCs and semi-volatiles. Tables 7 and 8
present the frequency of detection, average concentration
and maximum concentration of contaminants detected in
groundwater samples from the water table and bedrock
aquifers.
The chlorinated aliphatics attributable to the' site include
1,1,1-trichloroethane, 1,2-dichloroethene, vinyl chloride,
and trichloroethene. Chlorinated aliphatic concentrations
were highest in wells west of the Grant Gear building.
Maximum total concentrations of chlorinated aliphatics in
the water table aquifer were 2,179 ppb in MW-lA (Phase I)
and 2,270 ppb in MW-B10 (Phase II). These wells are located
within 125.0 feet of each other just west of the Grant Gear
building. Of the chlorinated aliphatics, trichloroethene
was detected at highest concentrations in water table wells
of both Phase I (1,800 ppb in MW-lA) and Phase II (1,700 ppb
in B-10). Maximum total concentrations of chlorinated
aliphatics in the Bedrock aquifer were found in well MW-1B
(1,307 ppb Phase I and 1,510 ppb Phase II). Monitoring well
MW-IB is also located west of the Grant Gear Building.
Vinyl chloride remained the highest concentration detected
in an on-site bedrock well (MW-2B). Phase I and Phase II
sampling at MVJ-2B detected vinyl chloride concentrations of
65 ppb and no ppb, respectively.
A plume of chlorinated aliphatics is moving in the water
table aquifer from the western portion of the Grant Gear
13
-------
property, where TCE is found at more than 1 ppa, to Meadow'
Brook, where ground water discharges and contaminants
volatilize. These contaminant discharges are quickly
diluted by stream water. Based on a comparison between in-
stream contaminant levels and water quality criteria, these
contaminant discharges are not considered to significantly
impact water quality in Meadow Brook since surface water
sampling did not detect elevated levels within the
groundwater discharge area. The Phase II study found no
bedrock contamination at the most downgradient portion of
the Site indicating that contamination found in well MW-2B
has not migrated off-site.
PCB concentrations detected in groundwater remained
relatively similar for the most part when comparing the
results of the Phase I and Phase II PCB sampling.
Monitoring well B-18 showed a decline in concentration from
180 ppb to 12 ppb. Well B-4 had an increase in
concentration from 46 ppb to 89 ppb, and MW-2A had a
reduction in concentration from 98 ppb to 66 ppb. The
highest concentrations still exist west of the Grant Gear
building and near other areas of high PCB soil
contamination, except for MW-2A. During Phase II sampling,
Aroclor-1248 was detected only in groundwater samples from
monitoring wells B-10 (1.1 ppb) and MW-1A (4.0 ppb).
The semi-volatiles (chlorobenzenes and chlorophenols)
attributable to the Site were detected in the water table
aquifer during Phase I and Phase II sampling. The highest
total concentration of chlorobenzenes, primarily the
chemical chlorobenzene, was detected at 2,125" ppb and 2,413
ppb in monitoring well MW-IA. Chlorophenols
(trichlorophenol and pentachlorophenol) were found in
monitoring wells MW-IA (10 ppb of trichlorophenol) and B-18
(190 ppb pentachlorophenol) during Phase I sampling. Only
pentachlorophenol (210 ppb) was detected during Phase II
sampling, in monitoring well B-18. No semi-volatiles were
measured above detection limits in the bedrock aquifer
during either Phase I or Phase II sampling.
H. GRANT GEAR BUILDING
The Grant Gear building measures approximately 225 feet by
390 feet, with a floor area of approximately 90,000 square
feet. Roof heights vary from 15 feet in office areas to 20
feet in the production area.
In May, 1983, E.G. Jordan performed an investigation for
Grant Gear Works, collecting 30 wipe samples from interior
surfaces of the Grant Gear building, including 10 samples
from floors; 7 from walls reportedly painted prior to
-------
sampling, and support columns; 5 from the ceilings, ledges;
and beams; and 6 from-employee work stations. All samples
were analyzed for PCBs.
The highest concentration of PCBs detected was 690 ug/100
cm2, taken from the surface of a dusty ceiling I-beam near
the center of the building. PCBs were not detected in the
other samples from ceilings, but 110 ug/100 cm PCBs were
detected in a sample from a ledge. PCB concentrations on
vertical surfaces ranged from undetected (<10 ug/100 cm2) in
5 samples to 120 ug/100 cm on a column near the southwest
corner of the building. Concentrations on floors ranged
from <10 to 96 ug/100 cm2 in the northern portion of the
building and''from 78 to 540 ug/100 cm in the Grant Gear
Works portion. Concentrations on surfaces of equipment at
work stations ranged from undetected (<10 ug/100 cm ) to 200
ug/100 cm2. Workstations were reportedly solvent washed
following these analyses.
On May 31, 1988, OSHA collected 14 (PCB Aroclor-1242 arid
Aroclor-1254) wipe samples inside of the Grant Gear
building. Wipe samples were taken after the equipment had
been cleaned by Grant Gear. Although the size of the
surface areas sampled were not noted, OSHA samples detected
no PCB levels.
On May 24, 1989, EPA collected wipe samples of wall, machine
and locker surfaces for possible PCB contamination (Aroclor-
1254) . Analytical results of wall surface samples ranged
from nondetectable (less than 0.5 ug/100 cm ) to 4.0 ug/100
cm2. Machine wipe samples ranged from 2.7 "ug/100 cm2 to 16
ug/100 cm2. The locker wipe sample had a detection of 18
ug/100 cm2.
Results of analyses of a limited number of samples of gravel
that cover the asphalt roof of the Grant Gear building
detected contamination of PCBs in the range of 1.8 to 3.1
ppm.
I. AIR
Outdoor air samples for PCB analysis were taken by EPA in
July 1983, after the removal of contaminated soils.
Measured PCB concentrations ranged from 0.016 micrograms per
cubic meter (ug/m3) along Kerry Place to 3.2 ug/m3 at the
rear of the Grant Gear building.
Indoor air samples collected on May 24, 1989, within the <
Grant Gear building, detected PCB Aroclor-1254 ranging from
1.5 ug/m to 3.7 ug/m3. The detected levels were well below
OSHA's threshold limit value-time weighted average (TLV-TWA)
concentration of 500 ug/mj.
-------
A complete discussion of site characteristics can be found
in the RI Report (Ebasco, 1989a).
VI. 8OMKARY OF 8ZTE RISKS
An Endangement Assessment (EA) was performed to estimate
the probability and magnitude of potential adverse human
health and environmental effects from exposure to
contaminants associated with the Site. Twenty-two
contaminants of concern, listed in Table 9, were selected
for evaluation in the EA. These contaminants constitute a
representative subset of the more than eighty contaminants
identified at.the Site during the Remedial Investigation.
The twenty-two contaminants were selected to represent
potential onsite hazards based on toxicity, level of
contamination, and mobility and persistence in the
environment.
The EA quantitatively estimated potential human health
effects associated with the contaminants of concern in
soils, sediments/ groundwater, surface water, air and on
equipment surfaces 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. For carcinogenic compounds,
risks are estimated by multiplying the estimated exposure
dose by the cancer potency factor of each contaminant. The
product of these two values is an estimate of the
incremental cancer risk. For noncarcinogenic 'compounds, a
Hazard Index (HI) value was estimated. This value is a
ratio between the estimated exposure dose and the reference
dose (Rfd) which represents the amount of toxicant that is
unlikely to cause adverse health effects. Generally, if the
HI is less than one, the predicted exposure dose is not
expected to cause harmful noncarcinogenic human health
effects. Where the HI exceeds one, the potential to cause
adverse noncarcinogenic human health effects increases as
the HI increases.
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 major portions of the Site contain
active businesses with approximately a total of 250 workers,
and the northern portion of the Site is a residential wooded
area that is adjacent to and drained by Meadow Brook.
Additionally, the Endangerment Assessment took into account
the facts that access to major portions of the Site is
unrestricted and the land is zoned for manufacturing UGOS.
16
-------
Direct contact with 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 for drinking water. The EA also
evaluated the risks from inhalation of on-site airborne
contaminants that volatilize from contaminated groundwater
and soils on-site. Other potential human health and
environmental risks associated with direct contact with
contaminated surface water and sediments were also discussed
in the EA.
A. DIRECT CONTACT WITH SURFACE SOILS
1. Worker Contact at Grant Gear and Other Commercial
Properties
One exposure scenario evaluated the potential exposure -and
risk for workers through dermal contact with and incidental
ingestion of chemicals of potential concern in surface soils
at commercial properties within the site boundaries. The
affected workers would be exposed on-site from landscaping
activities or storing materials on the contaminated soils.
The risks were assessed assuming both mean contaminant
concentrations and maximum concentrations. A range of
probable absorption rates for different chemicals (i.e.,
VOCs, SVOCs, PCBs, and inorganics) was used to estimate body
dose.
The incremental carcinogenic risks for a worker in the
vicinity of the Grant Gear facility coming in contact with
surface soil on-site ranged from IxlO'5 using site-wide
average contaminant concentrations to 8xlO"3 using site-wide
maximum contaminant concentrations. For a landscape worker
at Kerry Place, the Hyundai Dealer and other commercial
properties south and east of Grant Gear, the incremental
carcinogenic risks ranged from 2xlO"7 using site-wide
average contaminant concentrations to 2xlO"6 using site-wide
maximum contaminant concentrations. For both scenarios,
PCBs and total carcinogenic PAHs contributed the majority of
the total risk.
Noncarcinogenic risk estimates were also specified for the
worker exposure scenarios. In both cases, hazard indices
(His) calculated for exposure to contaminated surface soil
by on-site workers are all less than one, indicating the
predicted exposure dose is not expected to cause harmful
noncarcinogenic human health effects.
17
-------
2. Residential Contact North of Grant Gear
Two scenarios were presented in the EA to evaluate the
potential exposure and risk through dermal contact and
incidental ingestion of chemicals of potential concern in
dredge piles and/or surface soils in on-site areas north of
the Grant Gear facility. The first scenario assumes an
older child frequents this area and has contact with dredge
piles or soils in this area. The second scenario assumes
local residents are exposed to chemicals of concern in
surface soils in their backyards by outdoor activities such
as playing or gardening.
Calculated incremental carcinogenic risks were determined to
be greater for a child exposed to contaminated dredge piles
or soils in the wooded area north of Grant Gear than for
residents contacting contaminated soils in their backyards.
The incremental lifetime carcinogenic risks for an older
child exposed to contaminated dredge piles and surface soils
in the wooded area north of Grant Gear ranged from 2x10 to
6x10**. In comparison, for residents contacting
contaminated soils in their backyards, incremental lifetime
carcinogenic risks ranged from 2x10 to 3x10 , reflecting
the lower concentrations of chemicals of concern in the
residential backyards. In both scenarios, PCBs and total
carcinogenic PAHs contribute the majority of the total risk
and calculated hazard indices are less than one.
B. Ingestion of Groundwater
Groundwater on-site is not currently used for 'drinking
water, but it does represent a potential future source.
According to EPA Groundwater Protection Strategy guidelines,
the aquifer underlying the Site is classified as Class IIB
aquifer (i.e., a potential source of potable water). Under
the Massachusetts DEP classification system, the aquifer is
considered Class I, based on the same potential use.
Therefore, the incremental lifetime carcinogenic risk and
the noncarcinogenic health risks associated with the
ingestion of contaminated groundwater were assessed.
The EA estimated that the total incremental carcinogenic
risk would be IxlO"3 and 4xlO'2 if a person were to drink for
a lifetime the groundwater found under the Site containing
contaminants of concern at the mean and maximum .
concentrations, respectively (based on the Phase I results).
Vinyl chloride and PCBs contributed over 99 percent of the
total carcinogenic risk. For ingestion of groundwater
containing contaminants of concern at the maximum
concentrations, the total estimated exposure dose exceeds a
HI of one. Therefore, there is also an increased potential
to cause adverse noncarcinogenic human health effects. The
-------
hazard index associated with ingestion for a lifetime of
groundwater containing contaminants of concern at the
maximum concentrations, based on Phase I sampling, was
estimated at 10. In that case, 1,2,4-trichlorobenzene and
trichloroethene contributed over 99 percent of the total
noncarcinogenic risk.
C. Exposure to Sediments
The Endangerment Assessment examined risks associated with
exposure to contaminated sediments in Meadow Brook,
including exposure scenarios involving direct contact with
or incidental ingestion of sediments by a child. The
highest incremental carcinogenic risk was 5xlO~5, based on
direct contact by an older child with the maximum
concentrations of contaminated sediments in Meadow Brook.
The EA also evaluated potential impacts to environmental
receptors exposed to contaminated sediments. For the small
mammals, rodents and aquatic organisms that inhabit the
area, the potential exists for exposure to site associated
contaminants through the skin, by ingestion or through the
food chain. Of greatest concern is exposure to PCBs because
they are difficult to eliminate from the body and may affect
the animals and other organisms.
Two approaches were used to evaluate the environmental risk
posed by the contaminated sediments. The first approach was
to determine levels of PCBs and total organic carbon (TOG)
at various sampling locations, and then to compare those
values to the Interim Sediment Quality Criteria (SQC), which
vary depending on the TOC value. The sediment quality
criteria are numbers which predict the relationship between
contaminant levels in sediments and the Ambient Water
Quality Criteria (AWQC) which protects wildlife that consume
aquatic organisms.1 There are three levels of SQCs.2 The
upper level represents a 97.5% probability that PCB levels
in interstitial water (the water between sediment particles)
will exceed AWQCs. The mean level represents a 50%
probability of the same event, and the lower level
represents a 2.5% probability. Generally, the greater the
probability of PCB levels exceeding AWQCs, the greater the
risk to wildlife that consume aquatic organisms.
1 For PCBs, the ambient water quality criterion for the
protection of aquatic life to allow safe consumption of aquatic
organisms by wildlife is 0.014 ug/1.
The derivation of upper, mean and lower value SQCs are
further discussed in Appendix E of the Feasibility Study.
19
-------
At the Norwood PCB Site, PCBs in sediments exceeded both the
mean SQC value of 20 ug PCBs/g TOC and the upper SQC value
of 100 ug PCBs/g TOC in most portions of Meadow Brook from
the vicinity of the Grant Gear outfall to the Neponset
River. In one location near the Grant Gear outfall, the
maximum PCB concentration detected in Meadow Brook sediments
was 200 tines greater than the upper SQC value. Based on
these comparisons between the SQCs for PCBs and measured PCB
levels in sediments, EPA has determined that potential risks
to wildlife exist through consumption of aquatic organisms
exposed to PCB-contaminated sediments within Meadow Brook.
The second approach was used to assess risks to the aquatic
organisms in contact with the PCB-contaminated sediments.
The PCB tissue concentrations of these aquatic organisms are
projected to be equal to or, in some cases, in excess of
those concentrations in the sediment. Assuming a sediment
to tissue Bioconcentration Factor (BCF) of 1, the range of
PCB tissue concentrations in aquatic organisms exposed 'to
contaminated sediments in Meadow Brook are estimated at less
than 1.0 to 200 ppm. PCB tissue concentrations higher than
0.4 ppm in freshwater fish have been associated with
reproductive impairment. Therefore, based on assumed tissue
levels in aquatic organisms, aquatic organisms exposed to
contaminated sediments in Meadow Brook may be at risk of
reproductive impairment or other adverse effects.
D. Exposure to Contaminated Machinery/Equipment Surfaces
Risks to workers within Grant Gear from contact with and
dermal absorption of PCBs on indoor wall and equipment
surfaces were evaluated using results from wipe samples
taken by EPA in May 1989. For worker contact with PCBs on
indoor walls, the incremental carcinogenic risk was 2xlo"6
using mean PCB concentrations and 3xlO*6 using the maximum
PCB concentration. Worker exposure to mean PCB
concentrations detected on equipment surfaces resulted in an
incremental carcinogenic risk of 2x10 ; whereas, exposure
to the maximum PCB concentration resulted in an incremental
carcinogenic risk of 5xlO'5.
In summary, actual or threatened releases of hazardous
substances from this Site, if not addressed by the preferred
alternative or one of the other active measures considered,
may present an imminent and substantial endangerment to
public health, welfare or the environment.
A complete discussion of human health and environmental
risks can be found in the Endangerment Assessment (Ebasco,
1989b) . Table 10 sunmari7.es human health risks associated
with current and future site use.
20
-------
VIZ. DOCUMENTATION OF SIGNIFICANT CHANGES
EPA adopted a proposed plan (preferred alternative) for
remediation of the Site on August 8, 1989. Components of
the preferred alternative included:
1. Site preparation;
2. Excavation, treatment and on-site disposal of soils and
dredge pile materials;
3. Excavation, treatment and on-site disposal of Meadow
Brook:sediments;
4. Flushing and/or containment and replacement of portions
of the Grant Gear drainage system, cleaning and sealing
of roof surfaces, decontamination of
machinery/equipment and floor surfaces;
5. Collection of groundwater from the on-site overburden
and bedrock aquifers;
6. Treatment of groundwater;
7. Wetlands restoration/enhancement;
8. Long-term environmental monitoring and five-year
reviews; and
9. Institutional controls.
The remedy selected in this document differs from the
proposed plan in two respects. The first difference is
regarding the cleanup levels for contaminated machinery or
office equipment surfaces within the Grant Gear building.
The selected remedy establishes a target cleanup level of 5
ug/100cm2 for such equipment. The proposed plan specified a
Grant Gear machinery and office equipment surfaces cleanup
goal of 10 ug/lOOcm for total PCBs. This cleanup level of
10 ug/100cm2 is consistent with the EPA's PCB Spill Policy
for indoor solid surfaces set forth at 40 CFR
761.125(c)(4). However, after the proposed plan was
published, the Endangerment Assessment was finalized which
concluded that the target cleanup level should be 5
ug/100cm2 in order to reduce the residual risk to a maximum
risk of IxlO"5. The selected remedy will use the same
remedial action (decontamination) for reducing the PCB
levels to the revised target cleanup level as was proposed
in the preferred alternative. A memo outlining the change
in cleanup goals was added to the administrative record for
the Site on August 18, 1989, during the public comment
period. In addition, the change was described at the
informal public hearing on August 24, 1989.
The second difference from the Proposed Plan is that floor .
surfaces within the plant areas of the Grant Gear facility
will be decontaminated as a component of the selected
21
-------
remedy. The selected remedy established a perfomance based
target cleanup level of 10 ug/100 cm2 for floor surfaces
within the Grant Gear building. The Proposed Plan outlined
a preferred alternative which addressed contamination of
equipment and machinery surfaces within the plant areas of
the Grant Gear building but not floors. This alternative
specified decontamination of equipment surfaces by solvent
washing. In addition, an equipment cleanup target level of
5 ug/100cm2 was established based on the site-specific risk
exposure assumptions described in the EA. EPA did not
include floor decontamination in the Proposed Plan because
of the assumed infrequent exposure of workers from direct
contact with contaminants on floor surfaces. Comments on
the Proposed-/Plan received during the public comment period
indicated that the selected remedy should include
decontamination of floor surfaces within the Grant Gear
building. Specifically, comments submitted by Grant Gear
recommended that the remedy should address PCB contamination
of the floor as a source of contamination inside the
building. Finally, the Commonwealth of Massachusetts has
expressed a preference for remediation of the contaminated
floors within Grant Gear in order to reduce the total risks
and to reduce the levels of contaminants at the Site to
background levels, co the extent feasible. Moreover, since
issuance of the Proposed Plan, EPA has determined that as a
source control measure, decontamination of the floor
surfaces is necessary to minimize the potential for
migration of PCBs into the air, and subsequent
recontamination of equipment and machinery. Therefore,
decontamination of floor surfaces is necessary to adequately
reduce long-term risks to workers from exposure to
contaminated surfaces. In addition, this measure at a
relatively low cost will further reduce, to the extent that
PCBs on the floor volatilize into the air, the risks to
workers associated with inhalation of PCBs.
EPA finds that these significant changes to the proposed
remedy are logical outgrowths of information available to
the public from the information and analysis presented in
the RI, EA, FS and in the Proposed Plan. For these reasons,
these changes are documented in this ROD; further public
comment is not necessary.
VIII. DEVELOPMENT AND SCREENING OF ALTERNATIVES
A. Statutory Requirements/Response Objectives
Prior to the passage of the Superfund Amendments and
Reauthorization Act of 1986 (SARA), actions taken in
response to releases of hazardous substances were conducted
in accordance with CERCLA as enacted in 1980 and the revised
National Oil and Hazardous Substances Pollution Continqency
7.7.
-------
Plan (NCP), 40 C.F.R. Part 300 (1988), promulgated in the '
Federal Register on November 20, 1985. Although EPA
proposed revisions on December 21, 1988, to the NCP to
reflect SARA, until those proposed revisions are finalized,
the procedures and standards for responding to releases of
hazardous substances, pollutants and contaminants shall be
in accordance with Section 121 of CERCLA and, to the maximum
extent practicable, the current NCP.
Under its legal authorities, EPA's primary responsibility at
Superfund sites is to undertake remedial actions that are
protective of human health and the environment. In
addition, Section 121 of CERCLA establishes several other
statutory requirements and preferences, including: a
requirement that EPA's remedial action, when complete, must
comply with applicable or relevant and appropriate
environmental standards established under federal and state
environmental laws unless a statutory waiver is invoked; a
requirement that EPA select a remedial action that is cost-
effective and that utilizes permanent solutions and
alternative treatment technologies or resource recovery
technologies to the maximum extent practicable; and a
statutory preference for remedies that permanently and
significantly reduce the volume, toxicity or mobility of
hazardous substances over remedies that do not achieve such
results through treatment. Response alternatives were
developed to be consistent with these Congressional
mandates.
A number of potential exposure pathways were analyzed for
risk and threats to human health and the environment in the
Endangerment Assessment. Guidelines in the Superfund Public
Health Evaluation Manual (EPA, 1986) regarding development
of risk analyses for remedial alternatives were used to
assist EPA in the development of response actions. As a
result of these assessments, remedial response objectives
were developed to mitigate existing and future threats to
human health and the environment. These response objectives
are:
1. Prevent, or mitigate the continued release of hazardous
substances from contaminated soils and sediments to
groundwater, air, and surface water;
2. Reduce risks to human health and environmental
receptors associated with direct contact with or
incidental ingestion of site contaminants in surface
and subsurface soils;
3. Reduce risks to human health arid environmental
receptors associated with direct contact with and
incidental ingestion of Meadow Brook sediments;
A. Prevent or mitigate the.release of hazardous substances
to Meadow Brook from the Grant Gear drainage system;
23
-------
5. Reduce risks to workers associated with inhalation of
PCBs and direct contact with PCB-contaminated surfaces
within the Grant Gear building;
6. Reduce risks to human health associated with potential
future consumption of groundwater;
7. Reduce risks to human health and the environment from
current and future migration of contaminants in
groundwater and surface water; and
8. Reduce risks to human health associated with potential
current and future inhalation of airborne organic
compounds released from the Site.
B. Technology and Alternative Development and screening
CERCLA, the NCP and EPA guidance documents, including, the
"Guidance on Feasibility Studies Under CERCLA" dated June
1985, the "Interim Guidance on Superfund Selection of
Remedy" [EPA Office of Solid Waste and Emergency Response
(OSWER)J, Directive No. 9355.0-19 (December 24, 1986), and
the Interim Final "Guidance for Conducting RIs and FSs -under
CERCLA," OSWER Directive No. 9355.3-01, set forth the
process by which remedial actions are evaluated and
selected. In accordance with these requirements and
guidance documents, a range of treatment alternatives, a
containment option involving little or no treatment, and a
no-action alternative were developed for the Site.
Section 121(b)(l) of CERCLA presents several factors that,
at a minimum, EPA is required to consider in its assessment
of alternatives. In addition to these factors and the other
statutory directives of Section 121 of CERCLA,' the
evaluation and selection process was guided by the EPA
document "Additional Interim Guidance for FY '87 Records of
Decision" dated July 24, 1987. This document provides
direction on the consideration of SARA cleanup standards and
sets forth nine ractors that EPA should consider in its
evaluation and selection of remedial actions. The nine
factors are:
1. Compliance with Applicable or Relevant and Appropriate
Requirements (ARARs).
2. Long-term Effectiveness and Permanence.
3. Reduction of Toxicity, Mobility or Volume. .
4. Short-term Effectiveness.
5. Implementability.
6. Community Acceptance.
7.-\ ..
-------
7. State Acceptance.
*
8. Cost.
9. Overall Protection of Human Health and the Environment.
Chapter 4 of the Norwood PCB Site Feasibility Study (Ebasco,
1989c) identified, assessed and screened technologies based
on implementability, effectiveness, and cost. These
technologies were combined into source control (SC) and
management of migration (MM) alternatives. Chapter 5 of
this Feasibility Study presented the remedial alternatives
developed by combining the technologies identified in the
previous screening process in the categories required by
OSWER Directive No. 9355.0-19. The purpose of the initial
screening was to narrow the number of potential remedial
actions for further detailed analysis while preserving a
range of options. Each alternative was then evaluated and
screened in Chapter 5 of the Feasibility Study (Ebasco,
1989c). In summary, of the 12 source control and management
of migration remedial alternatives screened in Chapter 5, 9
were retained for detailed analysis.
Chapter 4 of the Grant Gear Building Feasibility Study (COM,
. 1989) identified and screened alternatives for remediation
of the building's drainage system based on effectiveness,
implementability and cost. Of the 1 alternatives screened,
4 were retained for detailed analysis.
Table 11 identifies the 13 alternatives that were retained
through the screening process, as well as those that were
eliminated from further consideration.
IX. DESCRIPTION/SUMMARY OF THE DETAILED AND COMPARATIVE ANALYSIS
OF ALTERNATIVES
This section presents a narrative summary and brief
evaluation of each alternative according to the evaluation
criteria described above. A detailed tabular assessment of
alternatives SC-1 through SC-5 and MM-1 through MM-4 can be
found in Tables 12 and 13.
A. Source Control (SC) Alternatives Analyzed
The source control alternatives to address soil and sediment
contamination at the Site include a minimal action
alternative (SC-1); a containment alternative (SC-2); and
three treatment alternatives: on-site solvent extraction
(SC-3); on-site dechlorination (SC-4); and on-site
incineration (SC-5). The source control alternatives to
address Grant Gear drainage system contamination include a
no action alternative (SC-A); flushing/cleaning of the
25
-------
drainage system (SC-B); containment of the drainage system *
(SC-C); and removal of the drainage system (SC-D).
A detailed evaluation of the source control alternatives to
address soil and sediment contamination at the Site is
presented in Chapter 6 of the PS Norwood PCB Site (Ebasco,
1989c). A detailed evaluation of the source control
alternatives to address the Grant Gear drainage system
contamination is presented in Chapter 5 of the Grant Gear
Building FS (COM, 1989).
As described in the Grant Gear Building FS (COM, 1989),
three remedial alternatives to address contamination of
surfaces inside the building were screened: sandblasting,
decontamination and removal. Sandblasting was screened out
based primarily on the uncertainty of its effectiveness in
reducing contaminant levels on metal and concrete surfaces
to target cleanup levels. In addition, the implementability
of sandblasting is questionable considering the significant
short-term risks to workers through increased airborne "'
particulates and contaminants during its implementation.
The off-site removal alternative was also screened out
because this alternative would be excessively costly without
any reduction in toxicity, mobility or volume of hazardous
substances. Additional disadvantages include
implementability problems associated with the transportation
and disposal of a significant mass and volume of
contaminated equipment and machinery. Both sandblasting and
off-site disposal would result in significant disruption of
and damage to the Grant Gear operations and building. On
the other hand, decontamination will be readily
implementable, would permanently and significantly reduce
the mobility and volume of contaminants on surfaces, and
will be effective in the long-term in achieving levels
protective of human health and the environment. EPA has
determined that decontamination, UPlike sandblasting and
off-site disposal, will be readily implementable and will
meet all the statutory requirements under CERCLA. Because
only one alternative (decontamination) passed the initial
screening, no detailed analysis of the alternative for
remediation of contaminated surfaces was performed. This
determination also applies to contamination of floor
surfaces.
The source control alternatives for the remaining site
contamination are summarized below:
SC-l
Minimal Action
A strict no action alternative was not evaluated in the
26 .-
-------
detailed analysis of source control alternatives for
remediation of on-.sJ.te. soils* dredge pile materials and
sediments. Instead, a minimal action alternative was
evaluated, as described below. A no action alternative
would be less acceptable than the minimal action alternative
primarily because it would not reduce of the level
unacceptable current or future risks to human health and the
environment posed by exposure to site contaminants.
This minimal action alternative would consist primarily of
restricting access to on-site contaminants. The major items
associated with this alternative are as follows:
Construction of a site perimeter fence
Institutional controls limiting groundwater and land
use (i.e. deed restrictions)
Public educational programs, including public meetings
and presentations, to increase public awareness
Long-term environmental sampling and analysis to .
monitor contaminant concentrations and migration
Site review every five years
This alternative would not be protective because it does not
address human health and environmental risks due to exposure
to soils, sediments and groundwater. In particular, worker
contact with surface soil in the vicinity of Grant Gear
would remain in. excess of a 10"3 risk under the plausible
maximum case. VOCs in the soils would continue to
contaminate groundwater and extend the period needed to
restore the aquifer. VOCs would also continue to be
released into the air and present risks to" workers on-site.
Surface water run-off and erosion from the PCB contaminated
soils would continue to contribute to risks to aquatic
organisms exposed to contaminated sediments in Meadow Brook.
This alternative is not permanent and is ineffective in
reducing what are presently unacceptable risks in the short-
term or long-term. This alternative would not use treatment
as a principal element to address the mass of contamination
at the Site, and consequently, there would be no reduction
in mobility, toxicity or volume of wastes present at the
Site. In addition, this alternative would not attain State
ARARs for groundwater quality and surface water. Finally,
none of the comments received from the community or state
support a no action alternative.
The only advantage- associated with this alternative is that
all components would be readily implemented with no
unforseen difficulties anticipated during construction of
the fence.
Alternative SC-1 Costs:
27 '
-------
ESTIMATED TIME FOR IMPLEMENTATION: < 1 YEAR
ESTIMATED CAPITAL COST; $128,000
ESTIMATED O S M (Present Worth): $954,000
ESTIMATED TOTAL COST (Present Worth)s $1,082,000
SC-2 (SC-2A/SC-2B)
Ce.opi.iiCf of Soils md Sediments
The SC-2 alternative would consist of consolidating outlying
contaminated soils, dredge pile solids, and sediments under
an impermeable cap constructed on-site over the central zone
of contamination. Two capping scenarios (SC-2A and SC-2B)
were evaluated in the FS based on different volumes of
sediments to;be excavated. For Alternative SC-2A, Meadow
Brook sediments with PCB concentrations exceeding 10 ppm,
dredge pile materials, and contaminated soils excavated from
the area located between Meadow Brook and the existing site
fence and from the area extending south beyond the Grant
Gear property line into the vacant lot, would be temporarily
stockpiled at the Site. The difference for Alternative SC~
2B is that Meadow Brook sediments with PCB concentrations
greater than 1 ppm would be excavated and temporarily
stockpiled at the site. All excavated areas would be
returned to their original grade with purchased clean fill
and topsoil.
For both SC-2A and SC-2B, initial site work would include
construction of a fence, installation of erosion control
measures and clearing and regrading. Outlying soils and
sediments would be excavated and consolidated in one area
and stockpiled on-site. Conceptually, all stockpiled solids
would be spread and compacted over a 5.3-acre area on the
Site, covering most of the Grant Gear property south, west,
and north of the building. The contaminated material would
be approximately six feet thick. An impermeable cap would
be constructed over the contaminated materials consisting of
a four-inch thick gravel base, a synthetic liner composed of
high density polyethylene (HOPE) liner, and a two-inch
gravel drainage layer. A three-inch thick asphalt layer
would cover these base layers and drainage materials. The
cap would require annual maintenance and inspections to
ensure the integrity of the cap. Long-term environmental
monitoring, including sediment and surface water sampling,
would also be required. Because untreated contaminated soil
would remain on-site, soil and groundwater samples would be
collected annually from areas adjacent to the cap.
The capping alternatives would be readily implementable, but
could result in short-term adverse environmental impacts
during site preparation activities and .excavation. Although
the site area was considered too small for a landfill
designed to meet minimum technology requirements under RCRA,
23
-------
there would be sufficient space to construct the landfill '
described for these alternatives. These alternatives would
reduce contaminant mobility. Risks from direct contact with
and incidental ingestion of contaminants in on-site soils,
dredge pile materials and sediments would essentially be
reduced to zero in the short-term due to the cap's
elimination of these exposure pathways. Alternative SC-2B
would provide increased reduction of risks to the
environment because sediments with PCB concentrations
greater than 1 ppm would be excavated. These alternatives
would not treat contaminated solids to reduce the total mass
of PCBs and would not result in a reduction in contaminant
toxicity or volume.
Capping would result in overall short-term protectiveness of
human health due to reduction in direct human exposure to
contaminated soils and sediments. However, there is
uncertainty about the long-term effectiveness of the cap and
the potential for significant risks to human health and.the
environment from the untreated wastes, as well as future
costs, if the cap were to fail. As a landfill, this
alternative would not be a permanent solution and would
require long-term operation and maintenance. This
alternative is not supported by the state or the community.
Alternative SC-2A Costs:
ESTIMATED TIME FOR CONSTRUCTION: < 1 YEAR
ESTIMATED TOTAL CAPITAL COSTS: $2,133,000
ESTIMATED OPERATION & MAINTENANCE COSTS: $1,567,000
ESTIMATED TOTAL PRESENT WORTH: $3,700,000
* e
Alternative SC-2B Costs:
ESTIMATED TIME FOR CONSTRUCTION: < 1 YEAR
ESTIMATED TOTAL CAPITAL COSTS: $2,340,000
ESTIMATED OPERATION & MAINTENANCE COSTS: $1,657,000
ESTIMATED TOTAL PRESENT WORTH: $3,997,000
SC-3
On-Site Solvent Extraction
This alternative is a component of the overall source
control remedial alternative selected for the Site. Refer
to Section X, for a discussion of this alternative.
Alternative SC-3 Costs:
ESTIMATED TIME FOR OPERATION: 2 YEARS
ESTIMATED TOTAL CAPITOL COSTS: $10,749,000
ESTIMATED OPERATION & MAINTENANCE COSTS: $2,511,000
ESTIMATED TOTAL PRESENT WORTH: $13,260,000
SC-4
On-Site Dechlorination
20
-------
In this alternative, as in the selected remedy,
approximately 28,500 cy of contaninated soils and sediments
would be excavated, treated and disposed of on-site.
However, this alternative would utilize a dechlorination
technology to detoxify the PCB contamination. Major
components of Alternative SC-4 would be as follows:
Site preparation work;
Construction of a fence;
Construction of stockpiling and treatment areas;
Mobilization of treatment process equipment;
Excavation/treatment of solids;
On-sitedisposal of treated solids;
Placement of soil covering;
Revegetation/repaving of disturbed areas;
Demobilization and decontamination of equipment;
Wetlands restoration;
Institutional controls;
Long-term monitoring; and
5-year reviews.
The dechlorination treatment process, termed the alkali
metal dechlorination process (APEG), removes chlorine atoms
from PCB molecules leaving less toxic, biphenyl molecules as
residuals. Contaminated solids are mixed in a stainless
steel reaction vessel with a combination of chemicals
forming a reagent, APEG (alkali polyethylene glycol). The
mixture is heated to increase the rate of reaction of the
PCBs, and to drive off the volatile organics (VOCs) from the
soil. The slurry mixture is then subjected*to'a series of
washing and dewatering steps. Contaminated reagent would be
continually recycled. Exhausted reagent and any hazardous
treatment byproduct, if generated, would be transported to
an off-site incineration facility for final destruction and
disposal. As outlined above, treated solids would be
replaced on-site and covered with topsoil.
By detoxifying PCBs, the principal chemical of concern at
the Site, this alternative would significantly reduce risks
to human health and the environment posed by direct contact
with and incidental ingestion of PCB-contaminated soils and
sediments. Dechlorination would permanently and
significantly reduce the toxicity, mobility and volume of
contaminants, would utilize an alternative treatment
technology and would comply with ARARs. Short-term risks
posed by dust or VOC emissions during soil excavation
activities would be controlled during implementation.
Dechlorination would not be readily implementable because it
would require the construction of a mobile treatment unit
for which no full-scale, demonstrated unit currently exists.
30 -
-------
The reliability and long-term effectiveness of this .'
innovative treatment technology includes, at present, some
degree of uncertainty since performance tests have shown
significant variability in the concentrations of the APEG-
reagent and PCBs remaining in the treated soil. Finally,
although this treatment would be effective in reducing PCB
levels in on-site soils and sediments to protective levels,
it may not be effective in reducing PAH levels in on-site
soils to protective levels.
ESTIMATED TIME FOR OPERATION: 2.5 YEARS
ESTIMATED CAPITOL COSTS: $10,997,000
ESTIMATED OPERATION 4 MAINTENANCE COSTS: $4,636,000
ESTIMATED TOTAL PRESENT WORTH: $15,633,000
SC-5
On-8ite Incineration
As in the selected remedy, approximately 28,500 cy of
contaminated soils and sediments would be excavated, treated
on-site by incineration,and disposed of on-site. The major
components of SC-5 would be the same as SC-4. This
alternative is selected as the backup treatment for
contaminated soils and sediments if results of predesign
studies indicate that the selected treatment technology
(solvent extraction) would not be implementable or would not
be effective in reducing contaminant levels to soil target
cleanup levels.
Three different types of incinerators were evaluated:
rotary kiln, circulating fluidized bed and infrared
processing. The specific type of process (e.g. rotary kiln)
would be determined in the Remedial Design phase through
engineering design and analysis and the competitive bidding
process. Specific operating practices necessary to meet
performance objectives, including a 99.9999 percent
destruction and removal efficiency (ORE) of stack emissions
as required by EPA regulations in 40 CFR Part 761, would be
determined through a trial burn at the Site. This trial
burn would be conducted on-site to demonstrate the
effectiveness and efficiency of the unit in providing for
the destruction of the contaminants specific to the Norwood
PCB Site, and to verify that residues from the incineration
process are nonhazardous. Exhaust gases would be passed
through air pollution devices before being released into the
atmosphere. - All incinerated residues would be replaced on-
site and would be covered with a layer of topsoil and
revegetated or repaved as necessary. Any contaminated water
residuals associated with dewatering of solids and from
emission control devices would be stored on-site to be
treated in the on-site groundwater treatment system selected
for the management of migration component of the remedy.
31
-------
On-site incineration of contaminated soils and sediments is
readily inplenentable. This alternative would reduce risks
associated with direct contact with and ingestion of
contaminated soils and sediments. Incineration would
permanently destroy PCBs and PAHs, would reduce the volume,
mobility and toxicity of contaminants, and would comply with
ARARs. It would provide overall protection of human health
and the environment because it significantly decreases
contaminant concentrations to protective levels.
Incineration is a proven and highly effective technology.
ESTIMATED TIME FOR OPERATION: 2 YEARS
ESTIMATED TOTAL CAPITAL COSTS: $13,856,000
ESTIMATED OPERATION & MAINTENANCE COSTS: $3,263,000
ESTIMATED TOTAL PRESENT WORTH: $17,119,000
Alternatives to Address Grant Gear Drainage System
Contamination
SC-A
Mo Action
Analysis of the no action alternative is required by the NCP
and is included for comparison with other alternatives.
This alternative assumes that the building will continue
without modification and without change of occupancy or use.
In this alternative, contaminated sediments would remain
untreated within the pipes and manholes of the drainage
system.
As with SC-l, this alternative would not result in the
reduction of toxicity, mobility or volume of contaminants in
the drainage system, which would continue to migrate into
Meadow Brook. The continued unabated discharge would not
attain ARARs (i.e., Clean Water Act) and would not be
protective due to exposure to contaminants in sediments
above protective levels. Since the selected remedy will
remove PCB-contaminated sediments in Meadow Brook at levels
greater than 1 ppm, the continued discharge would
recontaminate the stream, and therefore be ineffective in
the long-term.
Costs associated with this alternative would be generated
only by long-term monitoring requirements.
ESTIMATED TOTAL COST: $57,000
SC-B
Flushing/Cleaning
»
This alternative is a component of the overall source
32
-------
control remedial alternative selected for the Site. Refer '
to Section X, for a discussion of this alternative.
ESTIMATED TOTAL COST: $99,000
SC-C
Containment
»***
This alternative incorporates flushing and cleaning as its
first component to reduce the levels of contaminants in the
drainage system. After the initial flushing and cleaning
step, the pipes and manholes of the existing drainage system
would be filled with concrete or a soil/bentonite/cement
slurry and/abandoned in-place. A new drainage system would
be installed above grade, with drains supported on brackets
welded or bolted to the existing building columns. The
discharge of collected stormwater would be directed to
Meadow Brook via a new outfall pipe.
By reducing contaminant levels discharged to Meadow Brook to
protective levels, this alternative would be protective of
human health and the environment. By use of the flushing
step and subsequent treatment of the purged solids/ this
alternative would reduce the mobility, toxicity and volume
of hazardous compounds within the Grant Gear drainage
system. Upon successful implementation, this alternative
would eliminate the existing release of PCBs to Meadow Brook
while complying with ARARs (i.e., Clean Water Act). The
material and equipment needed to carry out this alternative
are readily available, thus making this alternative' very
implementable.
However, this alternative is a containment option that would
not utilize treatment to permanently reduce the toxicity,
mobility or volume of site contaminants. In addition, this
alternative would require long-term monitoring,
institutional controls and five-year reviews.
ESTIMATED TOTAL COST: $240,000
SC-D
Removal of Drainage System
Under this alternative, all piping and manholes contaminated
with hazardous substances would be removed and transported
to an approved off-site facility for disposal. In order to
remove the drainage system, the alternative would need to
remove portions of the floors and walls. Machines within
the Grant Gear building would have to be moved, protected
and reinstalled. Special precautions would be taken to
protect personnel during excavation. Furthermore, all
surfaces within the building would be decontaminated after
33 '
-------
th« removal to ensure that all contaminated dust generated'
during the demolition was removed. Prior to removing the
drainage pipes, they would first be flushed to remove easily
dislodged contamination to mitigate to the extent feasible
the release of hazardous substances during removal
operations. As described in SC-C, portions of the drainage
system would then be replaced, as necessary, with new above-
grade piping and manholes.
This alternative would permanently stop the discharge of
hazardous compounds to Meadow Brook and thus would be
protective of human health and the environment. However,
implementability of this alternative is limited because it
would result/,in major disruption to the operations of Grant
Gear. Because drain lines are within walls and under the
floors, removal of the piping system would also involve
major excavation of and damage to building structures. By
use of the flushing step and subsequent treatment of the
purged solids, this alternative would significantly but not
permanently reduce the mobility, toxicity and volume of
hazardous compounds within the Grant Gear drainage system.
Although this alternative would significantly and
permanently reduce on-site contamination in the drainage
system, off-site disposal in a landfill would not
permanently treat the contaminants and is the least
preferred under CERCLA. Finally, excavation and demolition
activities, and activities to prepare the materials for
transportation may result in a release of hazardous
substances and thus nay pose short-term risks to workers.
ESTIMATED TOTAL COST: $440,000
B. Management of Migration (MM) Alternatives Analyzed
Management of migration alternatives address contaminants
that have migrated from the original source of
contamination. At the Norwood PCB Site, contaminants have
leached from contaminated soils in the areas of the western
portion of the Grant Gear facility into x.he groundwater
under the Site. The plume of contaminated groundwater is
moving in general, toward Meadow Brook.
Chapter 7 of the Feasibility Study presents the detailed
evaluation of management of migration alternatives including
a minimal no action (MM-1); three groundwater collection and
treatment alternatives; air stripping (MM-2); carbon
adsorption (MM-3); and ultraviolet/oxidation (MM-4).
The groundwater collection system developed for use with
each treatment technology (MM-2, MM-3 and MM-4) is described
in component (e) of the selected remedy (See Section X).
-------
HM-1
Minimal Action
A strict no action alternative was not evaluated in the
detailed analysis of management of migration alternatives.
Instead, a minimal action alternative was evaluated, as
described below. A no action alternative would be less
acceptable than the minimal action alternative primarily
because it would no reduce the unacceptable current or
future risks to human health and the environment posed by
exposure to site contaminants.
In the minimal action alternative, institutional controls in
the form of deed restrictions would prevent groundwater use
in areas of known groundwater contamination. Periodic
public meetings would be implemented to increase public
awareness of the hazards at the Site. No treatment or
removal of groundwater would be included in this
alternative. Because this alternative would not restrict
groundwater flows and would not treat groundwater, migration
of contaminants would continue. Additional on- and off-site
monitoring wells in both the water table and bedrock
aquifers would be included in this alternative to monitor ,
the migration of contaminants. Long-term environmental
monitoring would be conducted for a period of at least
thirty years.
This alternative would be readily implementable and would
not result in adverse short-term impacts because the
groundwater is not currently used for drinking water. The
no action alternative would not reduce the toxicity,
mobility or volume of contaminants in groundwater.
Hazardous substances would continue to migrate in
groundwater to be discharged into Meadow Brook and/or the
Neponset River. Although the Remedial Investigation found
that site-related groundwater contamination had not migrated
downgradient beyond the Site, it is possible that the
contaminated plume will migrate further and contaminate a
larger portion of the aquifer if the contamination is left
unchecked. Contaminant levels in groundwater would not be
reduced to comply with groundwater quality and drinking
water standards, as required under Massachusetts
regulations. Finally, VOCs would continue to be released
into the air and present risks to workers on-site.
This alternative would be the least protective of all the
management of migration alternatives because it would not
reduce current risks to workers from inhalation of airborne
contaminants volatilized from groundwater and future risks
to human health and the environment if contaminants in
groundwater migrated off-site at unacceptable levels.
35
-------
ESTIMATED TIME FOR IMPLEMENTATION: < 1 YEAR
ESTIMATED CAPITAL COSTS: $78,000
ESTIMATED OPERATION t MAINTENANCE COSTS: $889,000
ESTIMATED TOTAL PRESENT WORTH: $967,000
MM-2
Air Stripping
This alternative is a component of the overall management of
migration alternative for the Site. Refer to Section X, for
a discussion of this alternative.
ESTIMATED TIME FOR OPERATION: 10 YEARS
ESTIMATED CAPITAL COSTS: $1,018,000
ESTIMATED OPERATION & MAINTENANCE COSTS: $1,483,000
ESTIMATED TOTAL PRESENT WORTH: $2,501,000
MM-3
Carbon Adsorption
In this alternative, groundvater would be collected and
extracted in the same manner as the selected remedy. The
difference between this and the selected remedy is the
method of treating the contaminated groundwater. For this
alternative, contaminated groundwater would be pumped from
the collection system to a granular activated carbon
adsorption (GAC) unit. As water passes through the GAC, the
contaminants would adsorb, or attach, to the surface of the
carbon granules. A series of carbon filtration beds would
be used to most effectively remove groundwater contaminants.
The first bed would be designed to capture tCB's,
predominantly, while the second bed would capture remaining
VOCs. The PCB-contaminated carbon would be incinerated
off-site at a federally-approved facility or regenerated
off-site. VOC-contaminated carbon beds would be regenerated
off-site for reuse. The treated groundwater would be
disposed of on-site in the groundwater recharge area. As in
the preferred alternative, treatability studies or pilot
studies would be done to determine the need for pre- or
post-treatment units, including acidification and
precipitation/filtration.
Carbon adsorption would permanently and significantly reduce
contaminant levels in groundwater and would attain ARARs.
Carbon treatment would significantly reduce contaminant
mobility and toxicity in extracted groundwater. This
treatment would be readily implementable and effective in
reducing contaminant levels to groundwater target levels.
However, this alternative would require long-term management
of waste residuals, including metal sludges and spent
carbon. A*s with MM-l, MM-2 and MM-4, institutional controls
including deed restrictions would be instituted to restrict
36 ..
-------
the use of on-site groundvater containing particulate-bound
PCBs for drinking water sources. Coupled with institutional
controls, this alternative would provide overall protection
of human health and the environment.
ESTIMATED TIME FOR OPERATION: 10 YEARS
ESTIMATED CAPITAL COSTS: $934,000
ESTIMATED OPERATION £ MAINTENANCE COSTS: $1,392,000
ESTIMATED TOTAL PRESENT WORTH: $2,326,000
MM-4
Ultraviolet (UV1 Oxidation
As with MM-3,-.this alternative is the same as the preferred
alternative, except for the method of treating the
contaminated groundwater. UV/Oxidation is an innovative
technology that would treat organics in contaminated
groundwater. Following pretreatment, groundwater would be
treated with an oxidizing agent, such as ozone or hydrogen
peroxide, while being exposed to UV light. UV light reacts
with the oxidizing agents to form chemical oxidants that
react with the organic contaminants in the water, increasing
the rate at which organic compounds, such as PCBs and VOCs,
are broken down. If these chemical reactions are carried to
completion, the end products of the oxidation process are
carbon dioxide and water. Treated waters would be disposed
of in the on-site recharge field. Because UV/Oxidation is
an innovative technology, pilot testing would be required to
determine its effectiveness at the Norwood PCS Site and the
need for pre- and post-treatment units, such as
acidification and precipitation/filtration.
UV/Oxidation is a relatively new technology that has been
proven effective in treating hazardous wastes containing
VOCs and PCBs. This technology would permanently and
significantly reduce contaminant.levels to groundwater
target levels and would comply with ARARs. It would also
significantly reduce contaminant mobility and toxicity in
extracted groundwater.
This alternative may require long-term management of waste
residuals, including metal hydroxide sludges. Limited
availability of vendors is also a potential implementability
drawback. As with .MM-1, MM-2 and MM-3, institutional
controls would be implemented to restrict the use of on-site
groundwater containing particulate-bound PCBs for'drinking
water sources and provide overall protection of human health
and the environment.
ESTIMATED TIME FOR OPERATION: 10 YEARS
ESTIMATED CAPITAL COSTS: $1,047,000
ESTIMATED OPERATION AND MAINTENANCE COSTS: $1,307,000
37
-------
ESTIMATED TOTAL PRESENT WORTH: $2,854,000
Z. THE SELECTED REMEDY
The selected remedy for the Norwood PCB Site is a
comprehensive approach for overall site remediation which
involves combining source control alternatives (SC-3, SC-B)
and a management of migration alternative (MM-2) . This
comprehensive approach is necessary in order to achieve all
the response objectives established for site remediation and
to meet legal requirements.
A. Description of the Selected, Remedy
Remedial Action ObieetivesCeanup Levels
The selected remedy was developed to satisfy remedial
objectives which will guide the design of the remedy and be
used to measure the success of the remedy. Site-specific
remedial objectives and cleanup levels for each media are
presented below:
a. Soil Cleanup Levels
The objectives of the soil component of the selected remedy
are to reduce risks posed by direct contact with and
incidental ingestion of soils contaminated with PCBs and
PAHs and to minimize migration of VOCs to groundwater.
To achieve these remedial objectives, EPA has used a risk
assessment methodology to establish soil cleanup levels for
several different situations at the Site. . The risk
assessment methodology used in establishing risk-based
target levels was based primarily on Region I ' s
"Supplemental Risk Assessment Guidance for the Superfund
Program.*' EPA recognizes the inherent uncertainties in
establishing such health-based soil cleanup levels.
Uncertainties are associated with the value of each exposure
parameter, the toxicological data base and the overall set
of exposure assumptions. Despite these uncertainties, EPA
believes that the assumptions used to estimate the cleanup
levels in the Endangerment Assessment prepared for this site
are reasonable and that the cleanup goals established in
this remedy will be adequately protective of human health
and the environment.
During the excavation and treatment of soil, air quality
will be monitored to ensure that site-specific ambient
action levels are not exceeded.
1. Soils on Grant Gear and Adjacent Commercial Properties
38
-------
For soils within the Grant Gear property and surrounding
properties, soil target cleanup levels are established at 10
ppm of total PCBs and 6 ppm of total carcinogenic PAHs.
Soils outside the Grant Gear property that are covered with
pavement will be remediated only where the covered soils
contain PCB levels greater than 25 ppm.
Potential exposure and risks were assessed for workers,
through dermal contact with and incidental ingestion of
chemicals of potential concern in surficial soils at
commercial properties within the site boundaries. The
maximum incremental carcinogenic risk for a worker in the
vicinity of the Grant Gear facility, coming in contact
(landscaping,-.storing) with contaminated surficial soils was
8xlO"3. Total PCBs and total carcinogenic PAHs contribute
the majority of the total risk. Based on the results of the
site-specific risk assessment for the protection of workers
of Grant Gear and adjacent commercial properties, soil
cleanup levels of 10 ppm of total PCBs and 6 ppm of total
carcinogenic PAHs have been selected. The assumptions -used
to calculate these soil target levels are presented in Table
14, and reflect the current and future manufacturing land
use of this area.
Reducing the concentrations of residual contaminants to
these levels will result in an incremental carcinogenic
lifetime risk level of IxlO"5 under both current and future
use site conditions. In addition, placement of 10 inches of
a clean soil cover over treated soils will further reduce
potential risks associated with direct contact with and
incidental ingestion of contaminated soils. As specified in
the TSCA PCB Spill Policy, placement of a 10 inch soil cover
would reduce risks associated with contact with contaminated
soils by a factor of 10. Therefore in accordance with this
policy, the combination of treatment of contaminated solids
to the target level described above and placement of a 10
inch soil cover will result in an incremental carcinogenic
lifetime risk level to workers of IxlO"6 under both current
and future manufacturing use of this area.
Soils outside the Grant Gear property that are covered with
pavement will be remediated only where the covered soils
contain PCB levels g-reater than 25 ppm. The existing
pavement already contains the contamination and prevents
risks from exposures from direct contact or ingestion.
Based on results of the RI, PCB levels under paved areas
outside.of the Grant Gear property did not exceed these
levels. Therefore, -no paved areas are expected to heed
remediation. The PCB criteria of 25 ppm for paved areas is
consistent with EPA's TSCA PCB Spill Cleanup Policy.
This soil component of the selected remedy will also reduce
39
-------
VOC levels in the unsaturated soils which at present are '
migrating into the groundwater at levels that contaminate
the groundwater above groundwater quality and drinking water
standards. The site-specific analysis for determining
target soil cleanup levels for vocs used fate and transport
Modeling to determine levels at which residual VOCs in soils
would not leach contaminants to groundwater in levels above
the groundwater target cleanup levels. Reducing VOCs to the
soil target cleanup levels will reduce the time needed for
restoration of the aquifer and aid in the attainment of
groundwater target levels, including MCLs. Of the
contaminants found in the unsaturated soils, the following
have established groundwater target levels, as identified in
Section X.A.l.b.
trichloroethene 5 ppb
tetrachloroethene 5 ppb
vinyl chloride 2 ppb
1,2,4-trichlorobenzene 350 ppb
1,4-dichlorobenzene 5 ppb
For soils within the Grant Gear property, the following soil
cleanup target levels have been established based on above
levels and the leaching model:
trichloroethene 24 ug/kg
tetrachloroethene 60 ug/kg
vinyl chloride 5 ug/kg
1,2,4-trichlorobenzene 97 mg/kg
1,4-dichlorobenzene 260 ug/kg
*
2. Soils and Dredge Piles Between Grant Gear's Northern
Fence and Meadow Brook, and Residential Properties
North of Meadow Brook
Target soil cleanup levels of 1 ppm of total PCBs and 2 ppm
of total carcinogenic PAHs are established for soils and
dredge piles between Grant Gear's northern fence and Meadow
Brook, and for soils in the yards of residences adjacent to
the north bank of Meadow Brook. Since no federal or state
ARARs exist for contaminants in the soil, the soil target
levels for PCBs and PAHs were determined by a site-specific
risk analysis. The EA estimates that a child exposed to
maximum concentrations of contaminants in dredge piles or
soils in the wooded area north of Grant Gear faces an excess
incremental carcinogenic risk of 6xlO"4. In addition, an
assessment of the risk posed to residents by maximum low
level contamination detected in the soils in the backyards
of residences on the north side of Meadow Brook estimated an
excess incremental carcinogenic risk of 3xlO'6. PCBs and
total carcinogenic PAHs contribute the majority of the total
risk.
10
-------
In order to reduce the risks posed by current site
conditions to levels protective of residents exposed to
contaminated soils in the aforementioned areas, soil and
dredge pile cleanup levels of 1 ppm of total PCBs and 2 ppm
of total carcinogenic PAHs have been selected. The
assumptions used to calculate these soil target levels are
presented in Table 14, and reflect the- nonrestricted access
and residential current and future land use of the areas
along and adjacent to Meadow Brook. These clean-up levels
will result in an incremental carcinogenic lifetime risk
level of 7xlO"6 under both current and future use site
conditions.
In addition to setting levels protective of human health,
the soil PCB cleanup level of 1 ppm was selected to be
consistent with the Meadow Brook sediment PCB cleanup level
of 1 ppm. This consistency will ensure that after the
stream remediation, the streambed sediments will not be
recontaminated with PCBs due to contaminants in soil eroding
into the stream from areas adjacent to Meadow Brook.
EPA has determined that for this Site, only contaminated
unsaturated soils will be excavated and treated. This
determination is made primarily on the basis of three
criteria: iroplementability, effectiveness and cost.
Specifically, excavation of saturated soils would require
dewatering in areas to be excavated. As discussed in
Chapter 7 of the FS in the discussion of the active
groundwater extraction system, the design of any active
dewatering operation would require special.measures to
prevent the drawing of Meadow Brook surface waters into the
extraction system. A slurry wall, commonly used in such
cases, would present long-term impacts by continuing to
restrict groundwater flow in and around its location for
periods after implementation of the dewatering operation.
Secondly, areas to be excavated in the saturated zone would
include areas immediately adjacent to the Grant Gear
building. Disadvantages associated with extensive
excavation of soils in and around the building include
possible .structural damage to the building and the exterior
drainage system. Because results of the RI indicated that
the weathered bedrock may also be contaminated, the
effectiveness of this excavation will be limited by the
ability to locate and remove all contaminated weathered
bedrock as well as all saturated soils. It is of
significance that any residual PCB levels in bedrock or
saturated soils not removed during implementation of this
remedial action may contribute to PCB levels in groundwater
above a human health-based risk level.
As stated above, removal and treatment of all saturated
41
-------
soils and bedrock, above the health-based target level, even
if feasible, may not ensure levels in groundvatar protective
of human health. Additionally, najor disadvantages are
associated with the implementability of this alternative.
Therefore, based on the description above, EPA has
determined that it is impracticable to remediate
contaminated saturated soils at this Site. However, all
unsaturated soils with contaminant levels greater than soil
target cleanup levels, as described in this section, will be
remediated.
b. aroundwater Cleanup Levels
The purposes-of the groundwater component of the selected
remedy are to reduce within a reasonable time frame risks to
workers posed by inhalation of airborne contaminants
volatilized from groundwater and to reduce risks to human
health and the environment from current and future migration
of contaminants in groundwater.
The groundwater cleanup levels established for this remedy
are the Maximum Contaminant Levels (MCLs) and the
Massachusetts groundwater quality standards for contaminants.
in groundwater at the Site. The determination of
groundwater cleanup levels focused on the risks posed by
current levels of contamination at the Site, the
classification of the groundwater underlying the Site and
compliance with federal and state ARARs. Groundwater on-
site represents a potential future drinking water source
according to state and federal classifications. The EA
prepared for this Site estimated that the total incremental
carcinogenic risk if a person were to drink the on-site
groundwater containing contaminants of concern at the mean
and maximum concentrations for a lifetime was estimated at
IxlO"3 and 4xlO"2, respectively, vinyl chloride and PCBs
contributed over 99 percent of the total carcinogenic risk.
EPA considered as ARARs several standards in establishing
the groundwater cleanup levels. These include Maximum
Contaminant Levels (MCLs) for several groundwater
contaminants that have been established as federal and state
drinking water standards and Massachusetts groundwater
quality standards. Health effects assessments were also
considered in establishing cleanup levels. The following
contaminants and their respective groundwater cleanup levels
have been established for the Norwood PCB Site:
trichloroethene 5 ppb
tetrachloroethene 5 ppb
vinyl chloride 2 ppb
1,2,4-trichlorobenzene 350 ppb
total 1,2-dichloroethenes 175 ppb
42
-------
1,4-dichlorobenzene 5 ppb
Of the compounds listed above, the cleanup levels set for
1,2,4-trichlorobenzene and total 1,2-dichloroethenes were
based on the site-specific health assessment for the
protection of human health from adverse noncarcinogenic
effects due to ingestion of groundwater contaminated with
those chemicals. Groundwater cleanup levels for
trichloroethene, tetrachloroethene, vinyl chloride and
1,4-dichlorobenzene were set to attain Massachusetts
groundwater quality standards. Of those four chemicals, the
groundwater cleanup levels specified for vinyl chloride and
trichloroethene were also based on HCLs established under
the federal Safe Drinking Water Act (SDWA) and as
Massachusetts drinking water standards and groundwater
standards. Attainment of these levels in groundwater at the
Site will reduce the current and future risks to human
health from inhalation of airborne VOC contaminants to an
estimated lifetime carcinogenic lifetime risk of SxlO*6 and
will significantly reduce future risks to human health from
ingestion of contaminants in groundwater.
Groundwater remedial objectives include attaining the
groundwater target cleanup levels within a reasonable time
frame. Chapter 6 of the FS presents the times estimated for
the most upgradient groundwater contamination to travel and
be extracted in the groundwater collection system, assuming
no further chemical leaching occurs from soils in the
unsaturated zone. Based on this FS analysis, EPA estimated
that the groundwater at the site will attain the cleanup
levels in 10 to 11.5 years, if the groundwater is remediated
as described in components (e) and (f) of the selected
remedy.
Neither MCLs nor Massachusetts groundwater standards have
been established for PCBs that have been detected in the
groundwater at the Site and are assumed to be adsorbed onto
soil particulates in the saturated soils. Currently no
drinking water or groundwater standards for PCBs are in
effect, although EPA has proposed an MCL for PCBs at 0.5
ppb. While the soil and groundwater components of the
selected remedy will reduce PCB levels in soils and collect
PCBs in contaminated groundwater, PCBs in the saturated
soils will not be remediated in a source control action,
(see Section X.A.2.b.i.). The Agency believes that due to
the continued presence of PCBs in the saturated soils it is
technically infeasible to collect enough particulate-bound
PCBs in the saturated zone as part of a groundwater remedy
to significantly reduce PCB levels in groundwater to a
health-based groundwater cleanup level or to the levels of
the proposed MCL. Based on a comparison of PCB levels
detected in unfiltered groundwater samples and in filtered
43 ,
-------
groundwater samples, EPA has concluded that the majority of
PCBs detected in on-site groundwater are not dissolved but
bound to soil particulates. In the case of PCBs present on
particulates, the rate of removal through groundwater
extraction is very limited and substantial amounts of clean
water would be affected as it is pulled into the
contaminated zone. The PS estimates that the time to
remediate PCBs in the groundwater of the site, under the
groundwater collection and treatment systems described in
selected remedy, is over 1,000 years. Therefore, in order
to ensure protection of human health, the selected remedy
will incorporate the implementation of institutional
controls to prohibit the use of on-site PCB-contaminated
groundwater for drinking water sources.
o. Sediment Cleanup Level
The objective of the sediment component of the selected
remedy is to reduce risk to human health and the environment
associated with direct contact with and incidental ingestion
of Meadow Brook sediments.
The cleanup level for sediments in the stream bed of Meadow
Brook is 1 ppm of total PCBs. The Endangerment Assessment
identified excessive risks associated with exposure to
contaminated sediments in Meadow Brook including direct
contact with or incidental ingestion of sediments for a
child. The highest incremental ingestion carcinogenic risk
was 5x10 , based on direct contact by an older child with
the maximum concentrations of contaminants in Meadow Brook.
The EA also evaluated potential impacts to .environmental
receptors exposed to contaminated sediments and concluded
that mammals, rodents and aquatic organisms that inhabit the
Meadow Brook area, are at risk from exposure to site
contaminants through the skin, by ingestion or through the
food chain.
The sediment cleanup level for total PCBs has been specified
at 1 ppm. This value is based on toxicological literature
which documents examples of sublethal toxic effects in
aquatic organisms at PCB tissue levels of 1 ppm. Assuming
that PCB concentrations detected in sediments would result
in the same concentrations in tissues of aquatic organisms,
then PCB concentrations greater than 1 ppm in sediments may
result in adverse effects to aquatic organisms. In
addition, achievement of the sediment cleanup level will
result in a significant reduction of risk to children
exposed to PCB-contaminated sediments in Meadow Brook from a
maximum of 3xlO"5 to l.SxlO"7.
Remediation of Meadow Brook sediments to the PCB sediment
target level will further reduce the levels of carcinogenic
44
-------
PAHs in the sediments and minimize the risk to children and
environmental receptors exposed to PAH-contaminated
sediments through direct contact and ingestion.
d. Grant Gear Drainage system Discharge Cleanup Levels
The cleanup level for PCBs in the effluent discharging to
Meadow Brook is 0.5 ppb. Achievement of this cleanup level
is necessary to minimize the continued release of hazardous
substances to Meadow Brook. This value is based on a
practical detection limit for the analysis of PCBs and was
specified in Grant Gear's draft National Pollutant Discharge
Elimination System (NPDES) permit proposed in 1988. While
other hazardous substances have been detected in the
effluent discharged from the Grant Gear building, this
remedy is establishing cleanup goals in the drainage system
only for PCBs. Effluent limits for all other hazardous
substances in the Grant Gear discharge system will be
consistent with standards established in a final NPDES
permit. EPA anticipates discharge cleanup limits will
incorporate federal ambient water quality criteria and/or
practical detection limits.
e. Grant Gear Machinery/Equipment and Floor Surfaces
Cleanup Level
The objectives of the machinery/equipment and floor surfaces
remediation are to reduce risks to workers associated with
direct contact with PCB-contaminated surfaces and to reduce
risks to workers associated with 'inhalation of airborne PCBs
within the Grant Gear building. .
The cleanup levels for machinery and equipment in the plant
areas of the Grant Gear building is 5 ug/100cm2 for total
PCBs. As described in the EA, Grant Gear worker exposure to
mean and maximum PCB concentrations detected on equipment
.surfaces resulted in an incremental carcinogenic risk of
2x10 and 5xlO"5, respectively. Based on the site-specific
risk assessment, the cleanup level for^Grant Gear machinery
and equipment surfaces has been set at 5 ug/100cm2 for total
PCBs. Remediation of all equipment to this cleanup level
will result in a maximum risk of IxlO"5 workers due to
exposure to contaminated machinery and equipment surfaces
inside Grant Gear.
For remediation of floor surfaces, EPA has established a
performance-based PCB target cleanup goal of 10 ug/100cm2.
Remediation of all floor surfaces to this cleanup level will
reduce long-term risks to workers from exposure to
contaminated surfaces and the risks to workers associated
with inhalation of airborne PCBs.
45
-------
2, Description of R*me4la,]L Components
After evaluating all of the feasible alternatives, EPA is
selecting a nine-component plan to address soil, sediment,
equipment and groundwater contamination at the Norwood PCB
Site:
a. Site Preparation
The site preparation work includes the establishment of
security and controlled access to the Site. A chain link
fence will be constructed around the perimeter of the Site
and designated off-site areas. To the maximum extent
feasible, the existing fences will be utilized.
Site preparation work will also include provisions for
controlling site drainage. In general, based on a
conceptual design described in the Feasibility Study,
diversion ditches will be used to ensure proper drainage of
stormwater away from the Site. Erosion control in the -form
of silt fencing will be used to prevent -uncontrolled
movement of contaminated soils. Stormwater management and
erosion control measures to be used during
excavation/treatment activities are also considered part of
the site preparation work.
Because these activities may include soil movement, an air
monitoring program will be implemented during the
performance of the site preparation work to determine risks
to on-site workers and n'earby residents. In addition,
subsequent to site preparation work but prior.to soil
excavation activities, soil monitoring will be performed to
further define soil contaminant levels in any area impacted
by site preparation work.
This component of the remedy will utilize measures to limit
potential air emissions from excavation activities,
including the following methods: enclosure of the work
areas; emission suppression techniques (i.e., foam, water
spray); and containment of excavated soils. In addition,
best management practices and engineering measures, such as
installation of curbing and sweeping of pavement surfaces,
will be taken to prevent further contamination of Grant
Gear's drainage system including roof surfaces.
To the extent legally required, any soils that will be
excavated as a result of any site preparation work will be
adequately stored on-site in accordance with state and
federal regulations (e.g., TSCA, 40 CFR § 761.65) prior to
treatment on-site during implementation of the soil
treatment component of the selected remedy.
46
-------
Following the installation of erosion control structures,
clearing and grubbing will be performed on the densely
vegetated parts of the Site. Cleared debris such as trees
and shrubs will be disposed of off-site after initial
processing (i.e., chipping) or if appropriate, burned
on-site. EPA anticipates that decontamination of such
debris will not be required. In order to minimize the
possibility of residual contamination of debris, special
precautions will be taken during clearing and grubbing
activities such as temporary covering of contaminated soils.
Any rubble for fill material unearthed during site
preparation work or surface obstructions (e.g., cinder
block, metal scrap) will be decontaminated prior to off-site
disposal in an approved facility. After areas have been
cleared, grading will be performed to provide a level
surface for the operational areas.
A concrete pad for stockpiling and dewatering will be
constructed as the final step to prepare for construction of
the soil and sediment treatment facility. Storage
facilities will be designed in accordance with storage
requirements under TSCA of 40 C.F.R. § 761.65.
Specifically, the facilities will meet, at a minimum, the
following criteria:
1) Adequate roof and walls to prevent rain water from
reaching stored materials;
2) Adequate floor with continuous curbing; and
3) No openings that would permit liquids to flow from
curbed area.
b. Excavation, Treatment and On-Site Disposal of Soils and
Dredge Pile Materials
This component is composed of the following: excavation,
grading, solvent extraction, on-site disposal, backfilling,
soil covering, predesign work and implementation monitoring.
i. Excavation.
To implement this component, a processing area will be set
up at the Site prior to soil excavation. The processing
area will be constructed so as to prevent, to the extent
possible, any migration of the excavated soils.
All uhsaturated soils and dredge pile materials contaminated
above the soil cleanup levels, described in Section X.A.I.a,
will be excavated (see .Figure 6-1 FS) , which is
approximately 31,000 cubic yards, including soils within the
100-year floodplain. Areas to be excavated would be
primarily within the Grant Gear property and immediately v
south and north of Meadow Brook.
47
-------
In the areas within the Grant Gear property and adjacent
commercial properties- all unsaturated soils and dredge pile
naterials contaminated with PCBs greater than 10 ppm, or
with carcinogenic PAHs greater than 6 ppm, or with organic
chemicals above the soil target cleanup levels,
approximately 28,500 cy, will be excavated and treated using
a solvent extraction technology. The exact volume of soils
and dredge pile materials to be treated and/or excavated
will be further defined by predesign sampling. Soils and
dredge pile materials from areas immediately south and north
of Meadow Brook including the backyards of residents, with
total carcinogenic PAH concentrations above 2 ppm and total
PCB concentrations above 1 ppm and 10 ppm will be excavated.
These soils with levels less than 10 ppm PCB or less than 6
ppm PAH will not be treated, but will be used as fill in the
areas within the Grant Gear property where contaminated
soils were excavated. A summary outlining soil action and
target levels is given in Table 15.
As described in component (a) of the selected remedy,
measures will be implemented to limit potential air
emissions from excavation, treatment and ancillary
activities. In addition, best management practices and
engineering measures, such as installation of curbing
(berms) and sweeping of pavement surfaces, will be taken
during soil excavation, treatment storage and disposal
activities to prevent further contamination of Grant Gear's
drainage system including roof surfaces.
Appropriate pretreatment and materials handling (blending),
such as feed size preparation and optimum soil feed
criteria, will be evaluated during remedial design for the
soil excavation phase of the selected remedy.
ii. Treatment by the Solvent Extraction Process.
The solvent extraction process involves the use of a solvent
to remove PCBs and other organic chemicals from the soils.
The first step in this process is to mix the contaminated
soils with water and the solvent in order to extract the
PCBs and other organic chemicals from the soils. Once the
extraction is complete, the treated soils are removed from
the mixture. Soils that do not meet EPA's target cleanup
goals after an initial extraction will again be treated in
the solvent extraction process until the target levels are
attained. The liquid solvent/PCB/water mixture is then
heated, separating the solvent/PCB-cpntaminated oils from
the PCB-free water. The solvent is then separated in a
stripping column and recycled for use in the system. The
solvent extraction process will take place in a closed unit
to prevent any contaminant air emissions.
48
-------
Design of facilities and best management practices related
to the storage and use of solvent and other chemical
products and waste will be performed in accordance with
state and federal regulations, including Massachusetts
Hazardous Waste regulations and requirements for above-
ground storage tanks. Extracted PCBs and other organic
chemicals will be collected, stored and disposed of off-site
by incineration in accordance with TSCA regulations at 40
CFR Part 761. Residual water from the process will be
pumped into storage tanks for treatment by a portable carbon
unit located on-site or for storage until the on-site
groundwater treatment system is implemented.
iii. On-site Disposal.
All excavated areas within the Grant Gear property and
surrounding businesses will be backfilled with soils and
sediments treated to the soil cleanup levels and the
untreated soils and sediments from the Meadow Brook area
with contaminant levels below 10 ppm PCBs or 6 ppm PAHs or
clean fill. All areas where treated soils will be disposed
will be covered with 10 inches of topsoil and either
revegetated or repaved and returned to their original
condition, to the extent practicable. Excavated areas
immediately south and north of Meadow Brook will not be
filled with treated soils. These areas will be backfilled
with clean fill brought in from off-site, layered with
topsoil, and revegetated.
iv. Remedial Design. -
Predesign work will include soil sampling, defining the
unsaturated zone and solvent extraction treatability
studies. Areas to be sampled are shown in Figure 7. The
sampling will further define soil contamination above soil
target levels in the unsaturated layer in the above
referenced areas. The unsaturated zone at the Site is
defined as that area from the surface elevation to the
seasonal low groundwater table. The seasonal low
groundwater elevation will be defined by implementing a
monitoring program that will evaluate the fluctuation of the
water table. This program will include the use of
continuous recorders to monitor the water level
fluctuations, with particular focus on periods of seasonal
low water.
Solvent extraction is an innovative treatment. Prior to
implementation of the full-scale process at the Site,
predesign treatability studies, including a pilot study,
will be conducted to determine the implementability of this
technology on site-specific contaminants and on a full-scale
49
-------
level. The pilot study will yield information on optimum
operational settings, percent reduction of organic compounds
in soils and sediments and the volumes and types of
residuals and byproducts produced by the operation of the
treatment system. Results of the treatability and pilot
studies will also be evaluated to determine appropriate
material handling methods that will be implemented during
remedial action. This evaluation will determine the extent
to which soils will be blended prior to treatment, based on
soil characteristics and/or contaminant levels, to ensure
the optimal effectiveness of the solvent extraction process
in reducing site contaminants to respective target levels.
Appropriate materials handling measures is particularly
critical for: .this Site because of the relatively high levels
of contaminants detected in soils in some areas.
If solvent extraction, based on the results of the
treatability studies, is not determined to be implementable
or effective or is determined to be significantly more
costly than incineration, on-site incineration will be'used
as the treatment technology for the removal of site
contaminants in soils, dredge pile materials and sediments.
On-site incineration was discussed and evaluated in the FS
and the Proposed Plan as SC-5. Incineration is a proven
technology at Superfund sites to treat wastes similar to
those found at the Site. Prior to full-scale
implementation, a trial burn will be conducted to
demonstrate that the incineration technology can achieve a
99.9999 percent destruction and removal efficiency for PCBs.
Residuals and side streams will also, be evaluated during the
trial burn. Treated soils will be placed back on-site, *
covered with 10 inches of clean soil and revegetated. All
other components of the source control remedy would remain
the same.
v. Monitoring.
An air monitoring program will be implemented during the
performance of the on-site soil excavation and treatment
component of the remedy to determine risks to on-site
workers and nearby residents. Air sampling stations will be
located at representative points throughout the Site and at
the perimeter of the Site. Samples will be analyzed, at a
minimum, for VOCs, PCB in vapor phase and PCB particulates.
vi. Additional.
EPA anticipates that some amount of on-site wetlands areas
will be impacted by soil excavation. For those areas, steps
will be taken, as described in component (g) of the selected
remedy, to minimize potential destruction or loss of
wetlands or adverse impacts to organisms.
50 ,'
-------
Upon completion of the excavation of on-site contaminated
soils and dredge pile materials, samples will be collected
and contaminant levels will be evaluated against the cleanup
levels for soils (see Section X.A.I.a). Additionally,
sampling and analysis of soils entering and leaving the
full-scale treatment plant will be evaluated. All samples
will be evaluated to ensure that response objectives are
achieved.
A summary of this soil component is given in Table 15.
e. Excavation, Treatment and On-Site Disposal of Sediments
The sediment component is composed of: preparation work,
temporary diversion of surface waters, excavation/dredging,
implementation monitoring, rediversion of surface waters,
dewatering, storage, and on-site disposal.
Initial preparation work, as described in component (a) of
the selected remedy, will include clearing of trees and
shrubs only from those areas necessary for implementation
and construction of this component. Cleared materials will
be disposed of off-site, or if appropriate, burned on-site.
Additional requirements relating to dust suppression
techniques during sediment excavation, transport and
disposal and decontamination procedures for rubble material .
will be implemented as described in site preparation,
component (a) of the selected remedy.
Meadow Brook streambed sediments with contaminants in excess
of the sediment target cleanup level of 1 ppm PCBs will be
excavated. Initially, the stream sediments will be
excavated to a depth of two feet, from locations near the
Grant Gear outfall to the confluence of Meadow Brook and the
Neponset River. The FS estimated that approximately 3,000
cy of sediments are at PCB levels greater than 1 ppm.
Additional sediment excavation will be conducted as
necessary to remove all sediments at levels exceeding 1 ppm
PCBs.
EPA will determine when excavation activities should be
performed by evaluating weather conditions, stream flow,
scheduling constraints and the impacts of construction
activities on the proposed Meadow Brook flood control
project.
This portion of the selected remedy will be implemented in a
manner that mitigates any contaminant migration downstream.
To accomplish the brook excavation, a temporary dam will-be
constructed upstream to expose the stream sediments. The
method of stream diversion will be determined during design
51
-------
of the selected remedy, considering the need to mitigate '
wetland impacts. If feasible, the stream flow will be
diverted and/or pumped through a temporary pipe located
parallel and in close proximity to the existing streambed to
carry brook surface waters around the areas to be excavated.
Because the streambed and adjacent areas are wetlands,
sediment excavation and associated activities will be
performed to minimize adverse impacts to wetland areas.
EPA has determined that, for this Site, there are no
practicable alternatives to the soil excavation, sediment
excavation and stream diversion components of the selected
remedy that would achieve site goals but would have less
adverse impacts on the aquatic ecosystem. Sedimentation
basins and/of silt curtains will be installed downstream to
capture any particles that may become suspended during
excavation activities. During excavation and dewatering of
PCB-contaminated sediments, downstream monitoring of surface
water will be conducted to ensure that transport is not
occurring as a result of the excavation. For wetlands areas
affected by sediment excavation, steps will be taken as
described in component (g) of the selected remedy, to
minimize potential destruction or loss of wetlands or
adverse impacts to organisms.
The exposed sediments will then be excavated and moved to
the stockpile/dewatering pad on-site. Dewatered sediments
with PCB concentrations greater than 10 ppm or carcinogenic
PAH concentrations greater than 6 ppm will be treated by
solvent extraction to the 10 ppm PCBs and 6 ppm PAHs target
levels and disposed of on-site, as described for soils and
dredge pile materials in component (b) of the selected
remedy. Sediments with PCB concentrations less than 10 ppm
or carcinogenic PAH concentrations less than 6 ppm will not
be treated prior to disposal on-site in excavated areas
along with treated soils and sediments.
An air monitoring program will be performed during the
implementation of this component to monitor risks to on-site
workers and nearby residents, as described in component (a)
and (b)(v) of the selected remedy.
After the initial excavation of sediments, sediment sampling
of the excavated areas will be performed to ensure
compliance with the sediment target level. Sediment samples
will be analyzed, at a minimum, for PCBs and TOC. These
samples will be used to evaluate the success of
excavation/dredging. Based on the sampling results,
additional excavation at one foot depth intervals will be
performed in any area where sediment contaminant levels are
equal to or greater than the sediment target level.
52
-------
d. Flushing Cleaning and/or Containment and Replacement of
Portions of Grant Gear Drainage System, Cleaning and
Sealing of Roof surfaces/ Decontamination of
Machinery/Equipment and Floor surfaces
i. Flushing/cleaning and/or Containment: and Replacement: of
Portions of Grant Gear Drainage System, and Cleaning
and Sealing of Roof Surfaces
This component includes flushing and cleaning the drainage
system's piping and manholes to remove as much of the
contaminated sediments as possible and minimize any further
migration of contaminants from the drainage system into
Meadow Brook> The first step of this component will be to
purge the drainage system of all solids, using standard pipe
cleaning methods (i.e., pneumatic ball or "pig" and wire
brushes). All purged sludges and solids, including
sediments from manholes, will be collected for subsequent
treatment as specified in component (b) of the selected
remedy. Sediments with contaminant levels too high to be
effectively treated on-site to less than 10 ppm PCBs and 6
ppm carcinogenic PAHs or all sediments if the storage time
before treatment would be excessive, will be transported
off-site to an incinerator operating in compliance with 40
CFR Part 761. Costs estimated for this component assumed
that the sediments would be treated on-site.
The mechanical purging and collection operations will be
followed by flushing of the drainage system using water to
drive out as much contamination as possible. Flushing
operations will include methods to prevent.the release of
hazardous substances to Meadow Brook, including
sedimentation basins.
The extent to which flushing and cleaning can eliminate
contaminants within the existing drainage system and thereby
permit its continued use in the long-term, will be
determined during remedial design. However, it is
anticipated that major portions of the external drainage
system to the west and north of the Grant Gear building
cannot be effectively flushed. Where the remedial design
studies or remedial action show that flushing will be
ineffective, for those portions, the drainage system will be
abandoned and contained with concrete or a slurry mixture
(e.g., bentonite/soil slurry). Containment of the drainage
system was discussed and evaluated as part of alternative
SC-C. Any portion of the existing drainage system that will
be abandoned and/or contained will be replaced by new piping
or manholes, to the extent necessary to control stormwater
discharge from the facility. Containment will be an
effective method of preventing any further discharge of
contaminants in the drainage system into the environment or
53
-------
Meadow Brook. The determination of whether to use concrete
or a slurry mixture will be made during the remedial design,
considering factors such as cost, inplementability,
permanence, and effectiveness. All other aspects of this
component of the selected remedy would remain the same.
This component of the selected remedy includes additional
sampling of roof materials on the high and low roofs and
stormwater collected in roof drains to further define the
extent of PCB contamination for these building structures.
If additional sampling of roof covering materials and
stormwater on the roof indicates that stormwater discharging
from the roof contains PCB concentrations greater than the
Grant Gear drainage cleanup levels set forth in Section
X.A.l.d., contaminated gravel on the roof will be removed
and disposed of on-site and roof drains will be cleaned. If
cleaning of the roof drains is determined to be ineffective
in reducing contaminant levels in the discharge stream, the
roof drains will be removed or contained and replaced
depending upon the most cost-effective method. Should-the
actions to clean the roof and roof drain prove ineffective
in reducing contaminants discharging to Meadow Brook, the
roof will be sealed with a sealing agent and covered with
additional clean gravel to immobilize and encapsulate any
PCB contamination.
Decontamination of surfaces of machinery, equipment and
floor surfaces within the plant areas of the Grant Gear
building will be performed according to requirements
specified in the EPA TSCA.PCB Spill Cleanup Policy, 40 CFR
Part 761, Subpart G. In particular, machinery/equipment and
floor surfaces will be cleaned by double washing with an
appropriate solvent and rinsing to designated target cleanup
levels, as measured by the standard wipe tests. As stated
in Section X.A.l.e., the risk-based PCB target cleanup level
for the machinery/equipment surfaces has been established at
5 ug/100 cm2. For remediation of the floor surfaces, EPA
has established a performance-based PCB target cleanup goal
of 10 ug/100 cm. Conformance to the PCB risk-based target
level of 5 ug/100 cm2 in the case of machinery/equipment
surfaces and the performance-based target level in the case
of floor surface will be verifed by postcleanup sampling, as
specified under 40 C.F.R. § 761.130.
ii. Decontamination of Machinery/Equipment and Floor
Surfaces
All hazardous or solid wastes generated from decontamination
of surfaces will be properly stored, labeled, and treated in
an off-site incinerator in accordance with the provisions of
40 C.F.R. § 761.60. Liquid wastes generated by the
decontamination of equipment and floors will be analyzed to
54 ,
-------
determine contaminant levels. If the on-site treatment
system proposed for groundwater remediation would be
effective in reducing the contaminant levels in the
wastewater to the effluent limits set for groundwater
discharge levels, then, depending upon timing constraints,
wastewaters not regulated under TSCA may be stored on-site
until implementation of the on-site groundwater treatment
system. If treatment of the liquid wastewater generated
from the decontamination operation is determined to be
ineffective or not implementable in the on-site groundwater
treatment system or if storage would be required for an
excessive period of time, then the liquid wastes would be
disposed of off-site in an approved facility.
e. Collection of Groundwater from the On-Site Overburden
and Bedrock Aquifers
On-site contaminated groundwater in the overburden and
shallow bedrock aquifers will be collected by a barrier
drain (see Figure 7-2 of the FS). The groundwater
collection system will be designed to intercept contaminated
groundwater both in the overburden aquifer that is moving
toward Meadow Brook and in the shallow bedrock aquifer that,
at the point of collection, will be discharging to the
overburden aquifer. The barrier drain will be designed to
collect contaminated on-site groundwater, but not draw in
off-site groundwater and surface water. The major
components of constructing the subsurface barrier extraction
system are:
Mobilization of equipment;
Clearing and grubbing the wooded area along Meadow
Brook where the barrier drain will be located;
Excavating the trench, and sampling and stockpiling the
soil;
Placement of an HOPE liner along the bottom and the
north face of the excavation;
Placement of a geotextile fabric liner in the
excavation;
Placement of perforated PVC pipe and gravel backfill in
the excavation;
" Installation of pump stations and construction of
related piping to transport waters to the treatment
area;
Construction of an impermeable cap along the length of
the barrier extraction system;
Connection of the system to the treatment unit; and
Disposing of the excavated soils.
Conceptually, as described in the FS, the barrier drain will
be approximately 700 feet long and will be installed by
excavating, from the ground surface to shallow bedrock, a 3
-------
utilize treatment to permanently and significantly reduce '
the T,M,V of hazardous substances, would comply with ARARs
and would be effective in reducing contaminant levels to
groundwater target levels. Coupled with institutional
controls to restrict the use of on-site groundwater
containing particulate-bound PCBs for drinking water
sources, all three treatment alternatives would provide
overall protection of human health and the environment. Of
the three treatment technologies (MM-2, MM-3, MM-4), EPA has
determined that air stripping (MM-2) presents the best
balance of the 9 criteria described in Section VIII. B. Air
stripping was selected as the treatment technology for the
remediation of on-site groundwater because it is more
implementable than UV/oxidation and its effectiveness is
proven. Air stripping also will not generate, to the same
extent, the amount of waste residuals (spent carbon) as
carbon adsorption. As described above, MM-1 was not
selected because it would not be protective of human health
and the environment and would not comply with ARARs.
Comments received from the PRPs questioned the justification
for remediation of groundwater given the need for
institutional controls. Other comments from the public
indicated the preference for groundwater remediation to
reduce site contaminants. The state concurs with the
groundwater component of the selected remedy.
XI. STATUTORY DETERMINATIONS
The remedial action selected for implementation at the
Norwood PCS Site is consistent with CERCLA and, to the
extent practicable, the NCP. The selected-remedy is
protective of human health and the environment, attains
ARARs and is cost effective. The selected remedy also
satisfies the statutory preference for treatment which
permanently and significantly reduces the mobility, toxicity
or volume of hazardous substances as a principal element.
Additionally, the selected remedy utilizes alternate
treatment technologies or resource recovery technologies to
the maximum extent practicable.
A. The Selected Remedy is Protective of Human Health and
the Environment
The remedy at this Site will permanently reduce the risks
presently posed to human health and the environment through:
1) solvent extraction of PCBs and other contaminants in
soils, sediments and dredge pile materials and off-site
incineration of PCB-contaminated oil extract; 2) flushing
and containment of PCB-contaminated sediments in the Grant
Gear drainage system to prevent further contamination of
Meadow Brook; 3) decontamination of equipment and floor
surfaces within the Grant Gear building; 4) extraction and
66 .
-------
treatment by air stripping of contaminated groundvater to
contain the contaminant plume and restore groundwater
quality; and 5) institutional controls.
Treatment of contaminated soils and dredge pile materials
will reduce risks associated with exposure to contaminants
from direct contact with and ingestion of soils and dredge
pile materials from a maximum incremental carcinogenic risk
of 8xlO"3 at Grant Gear to less than 1x10 . In addition, 10
inches of clean soil will be placed over areas where treated
soils will be disposed to further reduce the potential risks
associated with direct contact with or ingestion of site
contaminants.
Excavation, treatment (if necessary) and on-site disposal of
contaminated sediments will mitigate risks to environmental
receptors inhabiting the Meadow Brook area and will
significantly reduce risks to children exposed to
contaminated Meadow Brook sediments. The Grant Gear office
and machinery equipment surfaces cleanup level to be
attained by the decontamination of these surfaces, will
reduce risks to Grant Gear workers in direct contact with
such surfaces to a maximum carcinogenic risk of 1x10 .
Reducing the levels of floor contaminants will minimize the
potential for migration of PCBs into the air, and subsequent
recontamination of equipment and machinery. The combination
of flushing and containment of the Grant Gear drainage
system will virtually eliminate the continued release of
hazardous substances to Meadow Brook, especially PCBs, so as
not to recontaminate the stream sediments and reintroduce
the risks from sediments that are being remediated by this
remedy.
Risks from exposure to contaminated groundwater, via
inhalation of groundwater contaminants in the air or
ingestion, will be permanently and significantly reduced as
a result of groundwater collection and treatment. Cleaning
the contaminated groundwater at this Site will promote
restoration of groundwater quality and prevent off-site
migration of contaminated groundwater. EPA has determined
that it is technically infeasible to attain a health-based
groundwater cleanup level for PCBs (see Section X.A.l.b.).
Groundwater within the zone of contamination is not
currently used for drinking water sources. Institutional
controls will be implemented to ensure that in the future,
drinking water wells will not be drilled within the zone of
PCB groundwater contamination.
B. The Selected Remedy Attains ARARs
This remedy will meet or attain all applicable or relevant
and appropriate federal and state requirements that apply to
67 -'
-------
the Site. Environmental laws from which ARARs for the
selected remedial action at the Norwood PCB Site are derived
include:
Toxic Substances Control Act (TSCA)
Resource Conservation and Recovery Act (RCRA)
Clean Water Act (CWA)
Safe Drinking Hater Act
Clean Air Act (CAA)
Occupational Safety and Health Act (OSHA)
The following policies, criteria or guidelines will also be
considered (TBCs) during the implementation of the remedial
action: . .-.-
Executive Order 11988 (Floodplain Management)
Executive Order 11990 (Protection of Wetlands)
TSCA PCB Spill Policy
State environmental regulations which are applicable or
relevant and appropriate to the selected remedial action at
the site are:
Dept. of Environmental Protection (DEP) Regulations
Hazardous Waste Regulations
Wetlands Protection Regulations
Certification for Dredging and Filling in Waters
Air Quality Standards
Air Pollution Control Regulations
Surface Water Quality Standards
Groundwater Quality Standards
Supp. Requirements for Hazardous Waste Management
Facilities
Tables 16, 17, and 18 provide a synopsis of the applicable
or appropriate chemical-, location- and action-specific
requirements for the selected remedy and how this remedy
will attain those requirements. A brief discussion of how
the selected remedy meets those requirements follows:
1. Groundwater
Safe Drinking Water Act MA/PEP Drinking Water
Reoulations/MA DEP Groundwater Quality Standards
The groundwater at the Norwood PCB Site is not currently
used as a drinking water source, but is classified by EPA
and Massachusetts as a potential drinking water source.
Maximum Contaminant Levels (MCLs) promulgated under the Safe
Drinking Water Act and Massachusetts Drinking Water
Standards, which regulate public drinking water supplies,
are not applicable. However, because the groundwater could
68 .-
-------
potentially be used as a drinking water source, MCLs and MA
drinking water standards are relevant and appropriate.
Moreover, Massachusetts has groundwater quality standards
for a number of site contaminants which establish the same
level as the MCL for the respective chemical. Minimum
Groundwater Criteria established under the Massachusetts
Groundwater Quality Standards are applicable.
Meeting the groundwater target levels discussed in Section
X.A.l.b. will attain these ARARs. Tables 19 and 20 show the
MCLs and Groundwater Standards that will be attained.
The groundwater treatment facility will be located outside
of the 100-year floodplain. The location of the facility
attains the siting requirements of MDWPC Supplemental
Requirements for Hazardous Waste Management Facilities.
The proposed location is within the area! extent of
contamination, and is considered to be part of the site for
the purposes of Section 121(e) of CERCLA. Therefore, no
groundwater discharge permit is required. Discharges from
the treatment facility into the groundwater recharge system
will attain ARARs, (SDWA, MA Groundwater Standards).
2. Soils and Sediments
0
The applicable or relevant and appropriate requirements for
the excavation, treatment and disposal of the contaminated
soils, sediments and dredge pile materials are regulations
promulgated pursuant to TSCA, RCRA and DEP Hazardous Waste
Management Regulations. . .
Toxic Substances Control Act
The PCB Disposal Requirements promulgated under TSCA are
applicable to the remedy because the selected remedy
involves storage and disposal of soils and sediments and
liquids contaminated with PCBs in excess of 50 ppm. The
PCB-contaminated extract produced from the solvent
extraction treatment will be treated off-site in an
incinerator meeting the standards of 40 C.F.R. §761.69.
Under the Disposal Requirements, soils and sediments
contaminated with PCBs may be disposed of in an incinerator
meeting the standards of 40 C.F.R. § 761.69 or a landfill
meeting the requirements of 40 C.F.R. § 761.75. Under the
provisions of 40 C.F.R. § 761.75(c)(4), the EPA Regional
Administrator may waive one or more of the specified
landfill requirements upon finding that the requirement is
not necessary to protect against an unreasonable risk of
injury to health or the environment from PCBs. ,,
In this case, placement of soils, sediments and dredge pile .
materials with PCB levels no greater than 10 ppm under a 10
69
-------
inch soil cover or asphalt and construction of a groundwater
collection trench will provide a permanent and protective
remedy that satisfies the requirements of the Part 761
landfill regulations. Long-term monitoring of groundwater
wells will also be instituted, as required by the chemical
waste landfill regulations.
I
The Regional Administrator is exercising the waiver
authority contained within the TSCA regulations at 40 C.F.R.
S 761.75(c)(4), and is waiving certain requirements of the
chemical waste landfill regulations. The provisions to be
waived require construction of chemical waste landfills in
certain low permeable clay conditions [40 C.F.R. f
761.75(b) (1)J, the use of a synthetic membrane liner [S
761.75(b)(2)3, and that the bottom of the landfill be 50
feet above the historic high water table [S 761.75(b)(3)].
The Regional Administrator hereby determines that, for the
following reasons, the requirements of 40 C.F.R. SS
761.75(b)(1), (2) and (3) are not necessary to protect
against an unreasonable risk of injury to health or the
environment from PCBs in this case.
The primary reason that the waived specifications are not
necessary is that contaminated soils and sediments with PCB
concentrations greater than 50 ppm will be treated to the
PCB soil target cleanup level' of 10 ppm prior to on-site
disposal. As described in Section X.A.I.a., reducing the
concentrations of residual contaminants to the PCB soil
target levels will result in an incremental carcinogenic
risk level of 5x10 from exposure to PCB-contaminated soils
under both current and future use site conditions. In
addition, placement of 10 inches of a clean soil cover over
treated soils will further reduce' potential risks associated
with direct contact with and incidental ingestion of
contaminated soils. As specified in the TSCA PCB Spill
Policy, placement of a 10 inch soil cover would reduce risks
associated with contact with contaminated soils by a factor
of 10. The combination of treatment of contaminated solids
to the PCB target level described above and placement of a
10 inch soil cover will result in an incremental
carcinogenic lifetime risk level to workers of 5x10 from
exposure to PCB-contaminated soils under both current and
future manufacturing use of this area. In contrast, the
landfill requirements that are waived are designed to
protect against the risks from disposal of PCBs at levels no
lower than 50 ppm. The specifications regarding liners,
soil conditions and depth to groundwater are designed to
protect against the risks that high levels of PCBs will
migrate into groundwater, or be released, to air or surface
water.
70
-------
Low permeability clay conditions for the underlying
substrate are not necessary at this Site to prevent
migration of PCBs. Treated soils with residual PCB
concentrations less than 10 ppm will be disposed of on-site
in excavated areas within the unsaturated zone at the Site.
Disposal of the treated soils within the unsaturated zone
will minimize the hydraulic connection between the treated
soils and groundwater and subsequent PCB migration of PCBs
in groundwater. In addition, PCBs at these low levels would
not be expected to pose a risk to groundwater from soil
dissolution. Based on the range of total organic carbon
values from on-site soil samples, the FS estimated that
critical PCB soil concentrations of up to 40 ppm PCBs would
attain 1 part.per billion PCB in leachate entering
groundwater. Considering the low PCB concentrations of
treated soils (<10 ppm) and selection of the unsaturated
zone for disposal, the migration of PCBs from treated soils
to groundwater will be minimal.
The factors described above are also pertinent when
evaluating the synthetic membrane liner and 50 feet to the
water table requirements. The requirements are waived
primarily, because of the limited hydraulic connection
between groundwater, and the low PCB levels in soils at less
than 10 ppm that will be disposed on-site. Furthermore,
given the low mobility of PCBs in soils, migration of PCBs
from treated soils to groundwater would be minimal.
This remedy will also comply with the storage requirements
of the PCB Disposal Regulations by the construction of a
storage area meeting the standards of 40 C.F.R. § 761.65.
Hazardous and Solid Waste Amendments to the Resource
Conservation and Recovery Act
The Commonwealth of Massachusetts has been authorized by EPA
to administer and enforce RCRA programs in lieu of the
federal authority. The state requirements are either
equivalent to or more stringent then the federal RCRA
regulations. Compliance with Massachusetts Hazardous Wastes
Regulations (310 CMR 30.00) is discussed below. However,
federal regulations promulgated under the Hazardous and
Solid Waste Amendments to RCRA (HSWA) are potentially
applicable.
The applicability of HSWA regulations as action-specific
requirements for disposal depends on whether the wastes are
hazardous, as defined under RCRA. The agency has determined
that none of the wastes in the soils, sediments, and dredge
pile materials at the Norwood PCB site are listed or
characteristic hazardous wastes under RCRA. Accordingly,
HWSA Land Disposal Restrictions (LDR) will not be applicable
because placement of the treated solids on the land will not
71 ..
-------
constitute disposal of a hazardous waste. The Agency is
undertaking a rulemaking that will specifically apply to
soil and debris. Since that rulenaking is not yet complete,
EPA does not consider LDR to be relevant and appropriate at
this Site to soil and debris that does not contain RCRA
restricted waste. In order to determine the applicability
of HSWA land disposal restrictions' for the metal sludge
generated from the groundwater treatment system, this sludge
will be tested to determine whether it exhibits
characteristics of hazardous waste. If the metal sludge is
determined to be a restricted RCRA hazardous waste, the HSWA
land disposal restrictions would be applicable. In such a
case, the metal sludge will be pretreated consistent with
LDR prior to.-pff-site disposal. Off-site disposal by
incineration will comply with LDR for any PCB-containing
liquids from the solvent extraction process that meet the
definitions of California list wastes in 40 C.F.R. § 268.32.
The minimum technology standards for landfills are federal
requirements promulgated pursuant to HSWA that are not
applicable because disposal will not involve a hazardous
waste. In this case, those requirements landfill may be
relevant but are not appropriate because the PCB disposal
and landfill requirement of 40 CFR Part 761 have been
designed to apply to the specific component of this remedy
that requires disposal of PCB- contaminated soils and
sediments and more fully match the circumstances at the
Site.
Massachusetts PEP Hazardous Waste Regulations 3
Massachusetts DEP Hazardous Waste Regulation establishing
general hazardous waste facility management standards are
relevant and appropriate to the remedial activities that
will implement this remedy, because the CERCLA remedial
Activities are similar to the activities of an operating
hazardous waste facility, to the extent that the actions are
not already governed by PCB regulations at 40 CFR Part 761.
Implementation of the remedy will comply with the following
provisions of the Massachusetts hazardous waste regulations
3 Massachusetts Hazardous Waste Regulations are not
applicable, because the remedial action implementing this Record
of Decision will be initiated or ordered by DEP as well as EPA.
In such circumstances, no license pursuant to the Massachusetts
hazardous waste statute and DEP hazardous waste regulations is
required. 310 CMR 30.801(11). Accordingly, DEP does not require
strict compliance with all hazardous waste regulations for such
remedial actions, but only requires compliance with the relevant
and appropriate substantive sections of those regulations.
72 ..-
-------
TABLE
FEDERAL AND STATE STANDARDS AND CRITERIA FOR
SUMMARY OF CHEMICALS OF POTENTIAL CONCERN IN GROUND WATER
NORWOOD PCB SITE
(All concentrations in ug/liter)
MAXIMUM MASSACHUSETTS MASSACHUSETTS
CONTAMINANT GROUNDWATER DRINKING WATER
LEVELS STANDARDS STANDARDS
(relevant and (applicable) (relevant and
CHEMICAL appropriate) appropriate)
Chlorinated Alinhatics
Vinyl Choride " 2 2 2
1,1-Dichloroethene 7 7 7
1,1-Dichlorethane --
trans-1,2 Dichlorethene > '
1,1,1-Trichloroethane 200 200 200
Trichloroethene 5 5 5
Tetrachloroethene 5
Chloroform
Monocvclic Aromatics
Benzene 5 5 5
Toluene 2,000
ChorobenzeTie
1,2-Dichlorobenzene 20 600
Ethylbenzene 700
Xylenes 1,000
1,4-Dichlorobenzene 75 5
Other Volatiles
Acetone 700
Seroi-Volatiles
Diethyl Phthalate
Bis(2-ethylhexyl)
phthalate 10 ' 10
Naphthalene
Di-n-butylphthalade
Carcinogenic PAHs
PCBs .
Inorganics
Copper 1,000
Nickel
Qualitative Assessment Only
Noncarcinogenic PAHs
Cobalt -- --
72(a)
-------
at 310 CMR 30.00: General management standards for all
facilities (310 CMR 30.510-516); Contingency plan, emergency
procedures, preparedness, and prevention (310 CMR 30.520-
524); Manifest system (310 CMR 30.530-534); Closure and
post-closure (310 CMR 30.580-595); Groundwater protection
(310 CMR 30.660-675); Use and management of containers (310
CMR 30.680-689). The placement of contaminated soils,
sediments, and dredge pile materials under a soil cover will
occur outside the 100-year floodplain, in accordance with
location standards in the Massachusetts Hazardous Haste
Regulations.
The groundwater monitoring program will comply with the
groundwater protection regulations under the DEP
regulations. It is possible that the frequency of
groundwater monitoring will differ from semi-annual
monitoring requirements under this portion of the
regulations, which are not appropriate for this remedy.
While this remedy requires quarterly monitoring during
construction and implementation, the primary purpose of
groundwater monitoring for the remedy is to assess the
effectiveness of the groundwater collection and treatment
program.
3. Surface Water
Clean Water Act
Some regulations under the Clean Water Act are applicable to
the discharge of stormwater/wastewater to the surface waters
of Meadow Brook, or any other designated surface water body.
Under Section 121(e) of CERCLA, no permit is required under
the NPDES program for the remedial action performed under
CERCLA, because the effluent from the Grant Gear drainage
system will be discharged directly into a surface water of
the U.S. at a point considered part of the CERCLA site.
However, Grant Gear must obtain a NPDES permit to authorize
and regulate in the short- and long-term their continuing
discharge of pollutants into Meadow Brook from on-going
manufacturing operations and use of the Grant Gear building
which is not part of the remedial action.
Massachusetts Surface Water Quality Standards
Massachusetts water quality standards for discharges to
surface waters are applicable to discharges to Meadow Brook,
or any other designated surface water body. Meadow Brook is
classified as Class B, for the uses and protection of
propagation of fish, aquatic life and wildlife, and for
primary and secondary contact recreation. In addition,
Meadow Brook is classified as an anti-degradation stream for
the protection of low flow waters, where new or increased
discharges of hazardous substances are not allowed unless no
73
-------
other feasible discharge alternative exists. Discharge
limits, as established in a NPDES permit, for all hazardous
substances in the effluent from the Grant Gear discharge
system will be consistent with state water quality
standards. EPA anticipates discharge effluent limits, as
specified in the Grant Gear NPDES permit, will incorporate
federal ambient water quality criteria and/or practical
detection limits.
The proposed cleanup level for PCBs in the effluent
discharging to Meadow Brook from the drainage system has
been set at 0.5 ppb. This value is based on a practical
detection limit for the analysis of PCBs and was specified
in Grant Gear's draft NPDES permit proposed in 1988.
Floodplains and Wetlands ARARs
Regulations under Section 404 of the Clean Water Act are
applicable, because restoration of the Meadow Brook area
will involve a discharge of dredged or fill material. The
Agency has determined that in this case there is no other
practicable alternative which would address PCB
contamination in soils and sediments but which would also
have a less adverse impact on the aquatic ecosystem. The
selected remedy will comply with the substantive
requirements of Section 404 to minimize adverse impacts to
the aquatic ecosystem, by creating sedimentation basins or
using silt curtains during dredging operations, and by
restoring the stream and wetlands, to the extent feasible.
In addition, the policies expressed in Executive Orders
regarding wetlands and floodplains were taken.into account
in the selected remedy. The remedy will include steps to
minimize the destruction, loss, or degradation of wetlands
in accordance with Executive Order 11990, and will include
steps to reduce the risk of floodplain loss in accordance
with Executive Order 11988.
DEP Wetlands Protection Regulations concerning dredging,
filling or altering inland wetlands are applicable to the
dredging of Meadow Brook. The remedial action will comply
with the performance standards of the regulations regarding
banks, bordering vegetated wetlands, lands under water
bodies and waterways and land subject to flooding.
Because the Meadow Brook area is within the areal extent of
contamination, it is considered part of the site, and no
permits will be necessary.
Air
Standards for particulate matter under the Clean Air Act and
DEP Air Quality and Air Pollution regulations are applicable
and will be attained during construction phases and during
74
-------
operation of the groundwater treatment system (air
stripper).
QSHA
OSHA standards for general industries and health and safety
standards are applicable and will be attained.
Department of Transportation Regulations
Any hazardous wastes transported for off-site disposal,
including any solids extracted during the groundwater
treatment program, will be transported in accordance with
Department of Transportation regulations.
C. The Selected Remedial Action is Cost-Effeetive
EPA is required under the NCP to evaluate closely the costs
required to implement and maintain a remedy and to select
cost-effective remedies. Of the remedial alternatives that
are protective and attain all ARARs, EPA's selected remedy
is cost-effective.
Of the source control alternatives for soils, sediments and
dredge pile materials remediation, EPA has determined that
solvent extraction (selected treatment) followed by off-site
incineration of the PCB-contaminated oil extract, and on-
site incineration (backup treatment) would be the most
effective in permanently and significantly reducing the
toxicity, mobility and volume of hazardous substances and in
reducing contaminant levels in soils, sediments and dredge
pile materials to cleanup levels. A comparison of present
worth costs for solvent extraction and on-site. incineration
indicates that the present worth costs for solvent
extraction is lower than on-site incineration, $13.3 million
versus $17,2 million, respectively.
While the limited action and containment alternatives are
cheaper than the selected source control alternative
(solvent extraction) or the backup alternative (on-site
incineration), they do not provide the same degree of short-
and long-term effectiveness and permanence. As stated
above, the selected source control alternative (solvent
extraction/off-site incineration) is less expensive than the
only other equally effective .treatment alternative*(on-site
incineration). Thus, the selection of solvent extraction as
the source control alternative for soils, sediments and
dredge pile remediation is cost-effective because its costs
are proportionate to its effectiveness in reducing
contaminants to protective levels.
Of the four alternatives for the remediation of the Grant
Gear drainage system, EPA selected flushing followed by
limited containment. This selection was based primarily on
75
-------
the reduction of toxicity, mobility and volume (T,M,V) of "
hazardous substances achieved by flushing/containment when
followed by treatment of purged solids. None of the other
alternatives, individually or in combination, would achieve
the same degree of reduction. In particular, there is
significant uncertainty that flushing alone would be
effective in achieving the target cleanup levels as
described in Section X.A.l.d. Containment alone or off-site
disposal of the drainage system would not achieve any
reduction of T,M,V of hazardous substances. Off-site
disposal is also the least preferred alternative under
CERCLA. In view of the high levels of contaminants in the
drainage system and the greater degree of reduction of T,M,V
of hazardous., substances achieved by flushing/containment,
EPA has determined that flushing/containment of the Grant
Gear drainage system is cost-effective alternative because
its costs are proportionate to its overall effectiveness.
EPA has determined that decontamination is the only
effective and implementable alternative for remediation of
machinery/equipment and floor surfaces. Because
decontamination is the only effective alternative in
reducing the toxicity, mobility and volume of contaminants
on such surfaces, it is therefore cost-effective.
Three treatment technologies for remediation of .VOCs in
groundwater were evaluated in detail- in the FS (Ebasco,
1989c). EPA has determined that all three treatment
alternatives (air stripping, carbon adsorption,
ultraviolet/oxidation) would be effective in achieving the
management of migration response objectives, outlined in
Section VIII A. In addition, a comparison of present worth
costs associated with these three alternatives indicates
that the costs of each are relatively equal. Therefore, all
of the three alternatives are equally cost-effective.
Table 21 presents the estimated total cost of the remedy by .
elements, capitol costs, operation and maintenance costs and
present worth.
D. The Selected Remedy Utilizes Permanent Solutions and
Alternative Treatment Technologies or Resource Recovery
Technologies to the Maximum Extent Practicable
EPA has determined that the selected remedy utilizes
permanent solutions to the maximum extent practicable. In
particular, solvent extraction of soils, sediments and
dredge pile materials followed by off-site incineration of
the oil extract, or on-site incineration of soils as the
backup treatment, will permanently reduce, contaminants in
on-site solids to protective levels. In addition, removal
of the soil contaminants will reduce the source of
76
-------
groundwater contaminants, increasing the long-tern
effectiveness of that component of the remedy.
Decontamination of Grant Gear equipment/machinery and floor
surfaces will permanently reduce the PCB levels on such
.surfaces. Flushing of the Grant Gear drainage system
followed by on- or off-site treatment of purged solids will
permanently reduce the levels of hazardous substances in the
Grant Gear drainage system. The management of migration
portion of the remedy also utilizes a treatment method which
will result in the permanent removal of targeted
contaminants.
Solvent extraction, which is the selected soil remedy is an
alternative treatment technology. This alternative will be
used, if technically practicable.
E. The Selected Remedy Satisfies the Preference for
Treatment as a Principal Element
The principal elements of the selected remedy are the source
control alternatives and the management of migration
alternatives. These elements address the primary threat at
the Site, contamination of soils, sediments, dredge pile
materials, office equipment surfaces, drainage system and
groundwater. The selected remedy satisfies the statutory
preference for treatment as a principal element by
incorporating the following components:
1. Solvent extraction (on-site incineration-backup
treatment) of soils, sediments, Dredge pile
materials;
2. Off-site incineration of PCB-contaminated oil
extract;
3. Off-site incineration of waste residuals from
decontamination of equipment;
4. On-site solvent extraction (off-site incineration-
backup treatment) for purged solids from flushing
of the drainage system; and
5. Air stripping, and additional treatments as
needed, of collected on-site groundwater.
XII. STATE ROLE
The Massachusetts Department of Environmental Protection (MA
DEP) has reviewed the various alternatives and has indicated
its support for the selected remedy. The State has also
reviewed the Remedial Investigation and the Feasibility
Studies to determine if the selected remedy is in compliance.
with applicable or relevant and appropriate State
environmental laws and regulations. MA DEP concurs with the
selected remedy for the Norwood PCB Site. A copy of the
77 .-
-------
declaration of concurrence is attached as Appendix C.
In accordance with Section 104 of CERCLA, the Commonwealth
of Massachusetts is responsible for at least 10 percent of
the costs of the remedial action, and all future operation
and maintenance of the remedial action.
78
-------
NEPONSET RIVERA
** ILC*
2)00
SCALE IN FEET
APPROXIMATE
4200
REFERENCE
OSOS 75' X 15' METRIC
TOPOGRAPHIC MAP, NORWOOD
QUADRANGLE,1985
SCALE I:25000
FIGURE 1
SITE LOCATION
79
-------
Norwood PCB Site
KEY
Site Boundary
/WWW Fence
Drawing not to scale.
/\
N,
-------
ICtCXO
MCtOOW tllOOK
' *
UMitt Of IOC N »«> OM
U M'AMIMfNI Of HOuSlMO AMI
»tooo
COHH(*CI*L CONlfdUCTlON At
HI HI! T M.AC1
MrtMNO:
ASt fUK MOVWCD « 01C. WC.. »A«0
CM ACMM. fHoioCHMMtmr M« MOUNO
fUO«t B«n »» HAHtH I). I«M.
fOO
JCAlt IM »Ctt
«uo
J
FIOUMC 3
MCAOOW MOOK
oo-TCAD rtooo PLAIN
NOOgOOO PC* Sift !
-------
OJ
Cvj
lUtNO
X
0* tl«l
tMOvIO Ouiint l»» MMOvAt
*CllON. IJUNI. Itltl
iiootio* or in'l« «» *si>
I cnutxco t*o*c ;* .is'nii:
>N INN It 0(01. '»»
tlfl »OuKO»»»
N0t(
I ILtVAtlONS *»l M ril t. HI . Alivl III Ul AN
1C* LCVCl CONIOU* IHIfN/H I I...I
t OtVClOPUCNT »t «C«»T Fv*C( OCtUNDIO
AMI* MtMOvtl. M1ION
MtriNCNCC.
I l»«t PLAN MOVIOID *T OfC. INC 1*1(0 ON
MNIAL fNOtOgMMMlIKY «HO 0*OUNO
fLICHt OAIC "»» MAKCN ll.lttl
FIGURE 4
SITC PLAN
-------
il'V.tff^f^
I (MM*
10*1 1
MCO««ltAI»S»N«
I. tftANO MUMMHirS OfUNtAKO VI*
IIMI or sicNt moM
ff*IU*l* AH* AfUlAl
I »«( fO IHC t| it.MCtlON i t.
« MtCHlMKM Ol tACH fONI .
KTUCNCt:
AM M.AM MOMOCO IT OK. MC.. «ASCO
OM ACIMl fNOIOCttAMMtniT AMD CMOUNO
1MVCV. rUMI OAlt WAJ UUICM II. KM
MO
fCAlf. IK ftlT
FIGURE 5
WETLAND
KOMWOQO e
ZONES
» IITI III
-------
.
- K-(
.,, // -
//- ' / -,. / ;'
'A.'::/ : <4."^.//<
X-
. .
' « i
ItCCHO:
. MWU MONItOKIMO Wtll IMflMirO >/!/»
<> IIMOUCH «//« OUNINC PM»St 0 HI
MONITOMIMO WCll INSt*lt.(0 li/a» tllHOUCH
l/«t 8T WCHRAN CNOIHttRINa
HONITOKINO CIL NfST IMJttlKO J/»i
TMNOUCH «/ OUMINO KI
NOttV
«. IOCADCNS V «CUS 1-4 IHKOUO4 ->! tAlfN f«OM
CIA (IIM). name 4. nt^nooucto M v>nn»i *.
t IOC AT MINI or Otllt MW-IA tH»OUCH M»-»B
OCTCMIUNCO « GHOUND SUNVtf
WrCRCNCC:
ASC r«.AN MOVIOCO IT OtC. MC.. 8AMO
ON ACMAl PH010CMAUMC1DT AND CNOUNO
SUftVCY. ruCHt OATC WAS MARCH IJ. 1988
40O
1OO
SCALC IN Hll' '
FIGURE 6
REMEDIAL INVESTIGATION'
GROUND WATER SAMPLING STATIONS
noaooou KB sue
-------
_: Target Cleanup Levels for Norwood PCB Site Soils
KEY
Site Boundary
SECTION A Target cleanup level is 1 ppm PCBs
SECTION B Target cleanup level Is 10 ppm PCBs
Drawing not to seal*
-------
TABLE 1
SURFICIAL SOIL CONTAMINANT CONCENTRATIONS
NORWOOD PCB SITE
Compound
Frequency Of
Detection
Concentration (ug/kg)
Average Maximum
Detection Detection
PCBs
Aroclor-1254 278/312
Chlorinated Aliohatics
Methylene chloride 5/34
Chloroform 3/34
1,1-Dichloroethane 5/34
1,2-Dichloroethane 5/34
1,1,1-Trichloroethane 4/34
1,1,2-Trichloroethane 4/34
Trichloroethene 1/34
Tetrachloroethene 4/34
Pheno|s
Phenol 1/34
Chlorobenzenes
1,2,4-Trichlorobenzene 1/34
PAHs
Naphthalene 1/34
2-Methynaphthalene 2/34
Acenaphthalene 4/34
Acenaphthene 3/34
Dibenzofuran 2/34
Fluorene 5/34
Phenanthrene 15/34
Anthracene 7/34
Fluoranthene 24/34
Pyrene 25/34
Benzo(a)anthracene 14/34
Chrysene 17/34
8enzo(b)fluoranthene 14/34
Benro(k)flouranthene 6/34
Bsnzo(a)oyrene 14/24
IndenoC1,2,3-cd)oyrene 12/34
Dibenzo(a,h)anthracene 4/34
Ber.zoi g.h, i )oery lene 9/24
886,000
31
24
'20
123
24
26
6
33
2,300
82
150
78
200
123
120
61
530
302
651
568
580
552
,270
130
670
424
321
466
26,000,000
41
.46
42
330
54
42
6
67
2,300
82
2
2
3
2
2
5
5
2
i
1
150
88
270
180
200
100
,800
880
,800
,500
,000
, 100
,300
,300
,700
,900
800
,700
86
-------
Other Sami-Volatilea
Benzoic Acid 7/34 483 1,200
Metala
Cadmium 22/34 2.9 7.0
Copper 34/34 35 297
Silver ... 6/34 5.6 20
Zinc 34/34 56 160
NOTES;
1, Frequency of detection is the number of samples taken at
different locations in which compound was detected divided
by the number of samples for which the compound was analyzed
(including blanks and duplicates). CLP PCS data not
included in frequency of detection, average concentration,
or maximum concentration when mobile laboratory data exists
for duplicate samples.
2. Arithmetic average concentration is calculated only for the
samples where the compound was detected.
3. Compounds not listed were not detected or not considered
site-related.
-------
Compound
TABLE 2
SUBSURFACE SOIL CONTAMINANT CONCENTRATIONS
NORWOOD PCB SITE
Concentration (ug/kg)
Frequency Of Average Maximum
Detection Detection Detection
PCBs
Aroclor-1254
Arocloi1260
Chlorinated Aliohatics
194/392
7/54
Chloroform 5/54
1,2-Dichloroethane 1/54
1,2-Dichloroethene (total) 3/54
1,1,2-Trichloroethane 2/54
1,1,2,2-Tetrachloroethane 1/54
Vinyl chloride 2/54
Trichloroethene 4/54
Tetrachloroethene 3/54
BTEX
Benzene 1/54
Xylenes (total) 2/54
Phenols
Phenol 3/54
4-Methylphenol 1/54
Chlorobenzenes
Chlorobenzene 2/54
1,3-Dichlorobenze 2/54
1,4-Dichlorobenze 3/54
1,2-Dichlorobenze 1/54
1,2,4-Trichlorobenze 8/54
PAHs
2-Methylnaphthalene 1/54
Acenaphthene 1/54
Phenanthrene 6/54
Flouranthere 7/54
Pyrene 7/54
Benzo(a )antnracne 5/54
Chrysene 3/54
283,000
48,000
2
24
58
8
420
9
2,610
188
1
45
1 ,440
410
16
124
420
220
62,000
1 00
75
190
310
340
390
540
13,400,000
230,000
7*
24
140*
8*
420
12
10,000
420
1
70
3,300
410
22
160
950
220
360,000
380
850
740
400
700
-------
Benzo(b)fluoranthene 6/54
B«nzo(k)fluoranthane 1/54
Benzo(a)pyrene 4/54
Indenod,2,3-cd)pyrene 4/54
Dibenzo(a,h)anthracene 1/54
Benzo(g,h,i)perylene 4/54
Other Sami-Volatilea
Benzole add 1/54
3,3-Dichlorobenzidene 1/54
Metals
Cadmium 19/54
Chromium 27/54
Copper 26/54
Nickel 24/54
Silver 4/54
Zinc 27/54
870
350
1,100
740
570
600
330
1,500
4.
16
23
12
4
64
3,500
350
3,600
2,400
570
1,800
300
1,500
9.1
75
265
29
9
599
* - Maximum concentration detected in background sample.
NOTES: See Table 1.
-------
TABLE 3
DREDGE PILE CONTAMINANT CONCENTRATIONS
NORWOOD PCS SITE
Compound
Frequency Of
Detection
Concentration (ug/kg)
Average Maximum
Detection Detection
RGBs
Aroclor-1254 25/31
Chlorinated Aliohatics
Chloroform 2/7
PAHs
Naphthalene 1/7
Acenaphthalene 3/7
Dibenzofuran 1/7
Fluorene 1/7
Phenanthrene 6/7
Anthracene 3/7
Fluoranthene 7/7
Pyrene 7/7
Benzo(a)anthracne 6/7
Chrysene 7/7
Benzo(b)fluoranthene 6/7
Benzo(k)fluoranthene 6/7
Benzo(a)pyrene 7/7
Indeno(1,2,3-cd)pyrene 7/7
Dibenzo(a,h)anthracene 3/7
Benzo(g,h,i)perylene 7/7
Metals
Silver 5/7
Zinc 7/7
206
3,850,000
53
129
42
65
472
98
860
840
520
560
920
830
540
330
150
330
2.7
78
230
42
65
1 , 100
180
2,200
2,300
1 ,200
1 ,500
1 ,600
1 ,600
1
,300
800
270
840
6.3
132
NOTES: See Table 1
-------
TABLE 4
SEDIMENT CONTAMINANT CONCENTRATIONS
NORWOOD PCB SITE
Compound
Frequency Of
Detection
Concentration (ug/kg)
Average Maximum
Detection Detection
PCBa
Aroclor-1254
Chlorinated Aliohaties
Chloroform
Phenols
Phenol
2-Methy1 phenol
4-Methylphenol
2,4-D i methy1phenol
Chlorobenzenes
1,2,4-Trichlorobenzene
PAHs
Naphthalene
2-Methylnaphthalene
Acenaphthalene
Acenaphthene
Dibenzofuran
Fioorene
Phenanthrene
Anthracene
Fluoranthene
Pyrene
Benzo(a)Anthracene
Chrysene
Benzo(b)fluoranthene
Benzo(k)f1uoranthene
Benzo(a )pyrene
Indeno(1,2,3-cd)pyrene
Di benzo(a,h)anthracene
Benzo(g,h,i )perylene
55/79
4/17
2/17
1/17
4/17
1/17
3/17
9/17
8/17
7/17
11/17
11/17
12/17
17/17
14/17
17/17
17/17
17/17
17/17
16/17
16/17
16/17
13/17
11/17
14/17
14,200
1,100,000
64
48
226
81
115
362
174
134
771
554
725
5,688
3,020
5,891
6,182
067
738
953
953
S26
916
471
338
76
48
370
81
130
1 ,400
670
190
3,800
2,600
4,800
34,000
34,000
27,000
32,000
15,000
1 ,300
25,000
25,000
8,700
3,600
1 ,200
3,600
-------
Other Semi-Volatiles
4-Chloroaniline 6/17 112 300
Metals
Chromium 17/17 21 119
Copper 17/17 52 202
Silver 15/17 6.1 21
Zinc 17/17 1.10 298
NOTES: See Table 1.
-------
TABLE 5
DRAINAGE SYSTEM SEDIMENT CONTAMINANT CONCENTRATIONS
NORWOOD PCB SITE
Compound
Concentration (ug/kg)
Frequency Of Average Maximum
Detection Detection Detection
PCBa
Aroclor-1016
Aroclor-1242
Aroclor-1248
Aroclor-1254
Chlorinated Aliohatlcs
1 , 2-Di chl oroethene
Trlchl oroethene
Tetrach 1 oroethene
BTEX
Xylenes (total)
Phenols ^
Phenol
4-Methylphenol
2, 4-Di methyl phenol
Chlorobenzenes
1 ,2-Dichlorobenzene
1 ,3-Dichlorobenzene
1 ,4-Dichlorobenzene
1 , 2,4-Trichlorobenzene
PAHs
Dibenzofuran
Naphthalene
2 -Me thy! naphthalene
2-Chloronaphthalene
Acenaphthene
Flourene
Phenanthrene
Anthracene
Fluroranthene
Pyrene
Benro( a )anthracene
2/38
1/38
1/38
36/38
2/10
3/10
2/10
1/9
1/22
5/22
1/22
1/22
2/22
7/22
9/22
4/22
7/22
7/22
2/22
5/22
7/22
16/22
11/22
15/22
14/22
14/2 2
8,600,000
500
500
16,700,000
175,000
5,400,000
26,000
100,000
400
10,390
600
830
5,400
5,750
106,420
9,330
6,230
2,700
1 ,450
10,760
9,340
33,760
1 0 , 350
27,770
29,160
23,020
9,000,000
500
500
180,000,000
200,000
2,200,000
52,000
100,000
400
47,000
600
830
9,500
13,000
350,000
17,000
19,000
9,000
1 ,600
16,000
25,000
165,000
33,000
190,000
1 50,000
&2 , 000
-------
Chrysene 15/22 21,730 84,000
Benzo(b)flouranthene 14/22 22,630 74,000
Benzo(k)flouranthene 9/22 15,170 48,000
Benzo(a)pyrene 13/22 21,080 65,000
Indeno(1,2,3-cd)pyrene 8/22 22,780 55,000
Dibenzo(a,h)anthracene 4/22 9,350 15,000
Benzo(g,h,ijperylene 8/22 22,150 54,000
Other Semi-VoTatlies
Benzyl Alcohol . 1/22 690 690
'Metals
Arsenic 6/10 30 135
Barium 10/10 308 1,390
Cadmium 9/10 14 37
Chromium 10/10 140 419
Cobalt 3/10 18 30
Copper 10/10 1,120 3,120
Lead 10/10 490 963
Mercury 9/10 1.4 3.
Nickel 9/10 45 184
Silver 7/10 80 172
Vanadium 8/10 90 198
Zinc 10/10 1,460 9,700
NOTES: See Table 1.
-------
TABLE 6
SURFACE WATER CONTAMINANT CONCENTRATIONS
MEADOW BROOK
NORWOOD PCB SITE
. . Concentration (ug/1)
Compound Frequency Of Average Maximum
Detection Detection Detection
Chlorinated Aliohatics
Chloroform 1/9 6 6
1,1-Dichloroethane 1/9 33
1,1,1-Trlchloreothane 3/9 2 3
1,1,2,2-Tetrachloroethane 3/9 6 10
1,2-Oichloroethene (total) 2/9 2 3
Trichloroethene 2/9 3
Tetrachloroethene 4/9 2 *
Total Chlorinated
Allohatics 7/9 7.4 12
* - Maximum concentration detected in upstream sample.
NOTES:
1. Frequency of detection is the number of samples taken from
different locations in which the compound was detected
divided by the number of samples for which the compound was
analyzed (including blanks and duplicates).
2. Arithmetic average concentration is calculated only for the
samples where the compound was detected.
3. All surface water samples were unfiltered.
4. Compounds not listed were not detected or not considered
site-related.
-------
TABLE 7
WATER TABLE AQUIFER
GROUNDWATER CONTAMINANT CONCENTRATIONS
NORWOOD PCB SITE
Compound
Frequency Of
Detection
Concentration
Average
Detection
(ug/1)
Maximum
Detection
PHASE I RESULTS
PCBs
Aroclor-1254
Chlorinated Aliphatics
11/16
BTEX
Xylenes (total)
Total VOCs
Phenols
2,3,5-Trichlorophenol
Pentachlorophenol
Chlorobenzenes
Chlorobenzenes
1,3-Dichlorobenzene
1,4-Dichlorobenzene
1,2-Dichlorobenzene
1,2,4-Trichlorobenzene
Total SVQCs
PHASE II RESULTS
PCBs
Aroclor-1246
Aroclor-1254
1/19
13/19
1/16
1/16
4/19
1/13
7/12
34
1,1, 1-Trichloroethane
1., 1 ,2-Trichloroethane
1 , 1 ,2,2-Tetracholoroethane
Vinyl chloride
1 ,2-Dichloroethene (total)
Trichloroethene
Tetrachloroethene
1/19
1/19
1/19
1/19
5/19
9/19
3/19
3
18
53
14
77
230
7
6
203
10
190
579
1 . 1
180
3
18
53
14
300
1 ,800
12
-6
2,149
10
190
1/19
2/16
2/16
2/16
3/16
. 5
4
14
5
700
5
4
14
7
2, 100
2,125
1 . 1
39
'J6
-------
*Aroc1or-1248 1/13 4 4
*Aroclor-1254 4/13 3.1 4.6
**Aroc1or-1254 0/3 0 0
Chlorinated Aliphatics
1,1,2-Trichloro«thene 1/13 2 2
1,1,2,2-T«trachloroethen« 1/13 110 110
Vinyl Chloride 2/13 73 120
1,2-Dichloro«th«ne (total) 5/13 199 560
Trichloro«th«ne . . 8/13 328 1,700
Tetrachloroethene 3/13 41 87
Total VQCa 7/13 568 1,172
Phenola
P«ntach1oropnenol 1/13 210 210
Chlorobenzenes
Chlorobenzenes 3/13 25 38
1,4-Dichlorobenzene 3/13 48 67
1,2-Dichlorobenzene 3/13 10 11
1,2,4-Trichlorobenzene 3/13 1,420 2,200
NOTES:
1. Frequency of detection is the number of samples taken from
different locations in which the compound was detected
divided by the number of samples for which the compound was
analyzed (including blanks and duplicates).
2. Arithmetic average concentration is calculated only for the
samples where the compound was detected.
3. Compounds not listed were not detected or not considered
site-related.
4. All samples unfiltered unless noted.
* Glass Filtration
** Paper Filtration
-------
TABLE 8
BEDROCK AQUIFER
GROUNOWATER CONTAMINANT CONCENTRATIONS
NORWOOD PCS SITE
Compound
Frequency Of
Detection
Concentration (ug/1)
Average Maximum
Detection Detection
PHASE I RESULTS . .
PCBs
Aroclor-1254
Chlorinated Aliohatics
Vinyl chloride
1,2-Dichloroethene (total
Trichloroethene
Total VOCs
PHASE II RESULTS
PCBs
Aroclor-1254
*Aroclor-1254
Chlorinated Aliphatlcs
Vinyl Chloride
1,2-Dichloroethene(tota1 )
Trichloroethene
Total VOCs
Chiorobenzenes
Chlorobenzene
NOTES: See Table 7.
2/14
3/14
) 3/14
2/14
9/14
2/12
0/12
1/12
3/12
1/12
4/12
1/12
6.4
23
44
1 ,250
308
2.4
0
110
43
1 ,400
410
8
65
68
1 ,300
1 ,356
2.7
0
1 10
1 10
1 ,400
1 ,510
-------
Table 9
SUMMARY Of TMf EK0ANGERMENT ASSESSMENT
CHEMICALS Of WENTIAL CONCERN
NORWOOD KS SITE
REMEDIAL INVESTIGATION REPORT
Owvical
emeic Acid
*ff*l «Mwaft»^A*^«kA
QtlvTvOTtWfv
Qiior«fom
ff2*OfcM«*(Mtt«M
03*OlCn(9C4QHWW
y 4*0 1 CfltOTGMnMfM
tf 1*0lCnl6Tt9MMfMI
,2*0ictiloroet*ane
,2-DicMoroettMnea (total)
ntenal
PCI*
CareiMfanie *ANt
Noncarcinotanie »ANs
1. 1.2.2*T«tradiloroatham
TatraefttarottlMM
1>2.i,*Triehlorobannna
1.1.1
-------
TABUS 10-
OF POTENTIAL aisics AiicciATcO vn* THE HCRWOOO PC: ;:'
Tcta; Jppe'OOund lifetime
Ixcess Cancer Risk
>oncarc-iogemc
(aura Incex
Plausible Plausib'.e
Average Maximum Average Maximum
and-use
contact with surface soil in the vicinity
of the Grant tear Facility
Worker contact with equipment surfaces and indoor
ails of the Grant area of the Grant Gear facility
Inhalation of indoor air by workers at the
Grant Gear facility
Landscape worker contact with surface soil at
Kerry Place, the Hyundai Oeale* lid other
commercial properties south ano east of Grant Gear
Children contacting soil and dredge piles in the
wooded area north of the Grant Gear facility
Residents contacting soil in yards north of
Meaoow Brook
Children contacting surface water ana seoiment
- in Meadow Brook
IE-OS
2E-OS
2E-05
Zt-07
2E-06
2E-07
3E-06
8E-03
SC-OS
NA
2£-06
6E-04
3E-06
5E-OS
KC
NC
NA
future land-use
Ses:dent>al contact with soil at the Grant Gear
ari'ity of the wooded area north and east of
Grant
Residential contact with soil in the vacant lot
by residents at tr.e Grant Gear Facility
s'-c me -oooed area north ano east of Grant Gear
;>* ":a*. -or: Sv res-.cents at trie vacant lot
>?es:ior. of grourowater
St-05
9E-07
9E-OS
Sf-07
IE -03
3E-02
2E-04
NA
NA
4E-02
NA
NA
« « NS: isc-' 'tas'ie: or-'y average air concentrations -ere used ir. the evaluation.
^1 ' NO: :a:cuiateo: only carc-.nogemc r:$
-------
TAILE
SUMMIT or Aircnurivc SCMENINC
Homooo pa SITE
Pro* Screening
Alternative
SC-1
SC-2
Description
Ho* Action
Capping
omits of Screening
Retained
Retained 2 optiono
MOM
Alternative No.
SC-1
sc-z
SCO
SC-4
SC-5
SC-6
SC-7
SC-8
MN-7
m-t>
Lin* Str«M
Solvent Extraction: TEA
Oochlorination: KPEG
Onsitt Incineration
Offsit* Incineration
Offsite landfill ing
No Action
Air Stripping
Carbon Adsorption
UV/Oxidation
A: Cap sitt soils > 10 ppa,
sediments > 10 pp», and
northern sito soils > 1 pp».
g. Cap sito soils > 10 pp»
ediments > 1 ppm, and
northern sito soils > 1 pp».
Eliminated as on individual
alternative. Will be kept as
option with all SC alternative*
except SC-1.
Retained
Retained
Retained
Eliminated
Eliminated a* individual
alternative. Maintained as
option for sediments with SC-2.
Retained
Retained
Retained
Retained
SC-J
SC-4
SC-5
NM-1
m-2
HM-3
MM-4
lol
-------
TABLE 12 I.....
SUMMARY OF DEtAILEO ANALYSIS SOURCE CONTROL (SC) REMEDIAL ALTERNATIVES
NORWOOD PCB SITE FEASIBILITY STUDY
Assessment Alternative SC-1
factors Minimal No-Action
Major Construction of
Components site perimeter
fence.
Implement
Institutional
restrictions.
Perform
long-term
environmental
monitoring.
,
Alternative SC-2
Capping
Construct a neu
perimeter fence.
Impose
Institutional
restrictions.
Conduct public
education
programs.
- Regrade dredge
piles.
- Excavate and
place outlying
materials.
- Backfill and
restore outlying
areas.
- Restore wetlands
areas.
- Construct
asphalt cap and
restore existing
pavement .
- Perform
long-term site
environmental
monitoring.
- Optional lining
of stream
channel.
Alternative SC-3
Solvent
Extract ton: TEA
Construct ilte
fence.
Clear and grub
Ite.
Excavate and
stockpile solids
and sediment.
- Treatment via
BEST process.
Offslte
Incineration
of extracted
PCB oils.
- Replace treated
solids onslte.
- Backfill and
restore outlying
areas.
Restore wetlands
areas.
- Reyegetate and
repave.
' Optional lining
of stream
channel .
Alternative SC-4
Dechlor (nation:
KPEG
Construct site
fence.
Clear and grub
alte.
Excavate and
stockpile solids
and sediment.
- Treatment via
KPEG process.
Replace treated
solids onslte.
- Backfill and
restore outlying
areas.
- Restore wetlands
areas.
Revegetate. and
repave.
Optional lining
of stream
channel .
Alternative SC-5
Onslte
Incineration
Construct site
fence.
Clesr and grub
site.
Excavate and
stockpile solids
and sediment.
* Incinerate
solids.
Replace
Incinerated
solids onslte.
Backfill and
restore outlying
areas.
- Restore wetlands
areas.
Revegetate and
repave.
Optional lining
of stream
channel.
Short Icrm t Hect i vcncss
Protect ion
of Ccmnjni'ty
No net Increase
in risk to
community during
Implementation.
the poblic would be at
Increased risk compared
to SC-1 during soil and
sediment excavation.
Risks of direct contact
with soils and sediments
during excavation and
onslte storage of PCB
oils from the treatment
prior to offslte
disposal.
Risks of direct contact
with soils and sediments
during excavation.
Risks associated with
treatment are believed
minimal.
Risks of direct cont
with soils and sedla
during excavation.
Additional Increase
airborne contaminant
fro* thermal treatm
unit emissions. Imj
largely mitigated b>
emissions treatment.
102
-------
table «/ (Continued)
Pag* 2
Assessment
factors
Alternative SC-I
Minimal Mo-Act Ion
Alternative JC-2
Capping
Alternative SC-3
Solvent
Extraction: TEA
Alternative SC-4
Oechlorfootlorn
KPM
Alternative *C-J
Ons It*
Incineration
Protection
of Workers
Protection required
during installation of
(Itt tenet.
Environmental Impacts
Minor impact* due to
tree cutting during
fence Implementation
Iime to Achieve
Protection
eduction in the current
risks of direct contact
could be achieved within
t year; risks from
future ground water
Ingest Ion and direct
contact would remain.
Worker* Mould be
required to use "Level
C" personal protective
equipment and
respiratory protection
equipment.
May result In a short
ten* adverse
environmental Impact
caused by clearing and
grubbing In the central
tone and during the
excavation and
consolidation of
outlying soil areas and
sediment under the cap.
Wetlands areas would be
disturbed during
excavation.
deduction in risks
addressed could be
achieved within 2-1/2
years of the start of
the remedial design.
Workers would b*
required to use "ttval
C* personal prettcttvt
equipment and
respiratory protection
equipment; treatment
system operated by
vendor* trained
personnel.
Potential mobilization
of soil* and sediment*
during excavation; TEA
has a strong amjaonla-
like odor.
Wetlands areas would be
disturbed during
excavation.
eduction In risks
addressed could be
achieved within 4 year*
of the start of the
remedial design.
M Alternative
$C-4.
Potential mobilisation
of solla and sediments
during excavation.
Wetlands areas would b*
disturbed during
excavation.
eduction In risks
addressed could be
achieved within 4ft years
of the start of the
remedial design.
Same M Alternative
C-4.
Potential mobllliatlo
of soil* and edlment
during excavation plu
additional Impact* du
to low level emission
from Incineration.
Wetlands area* would
disturbed during
excavation.
eduction In risks
addressed could be
achieved within 4 yei
of the start of the
remedial design.
1U3
-------
table U- «:
Page S ^
Assessment
factors
Mjcd)
Alternative SC-1
Minimal No-Action
Alternative SC-2
Capping
Alternative SC-J
Solvent
Extraction: TEA
Alternative SC-4
Dechlorlnatlont
KPEQ
Alternative^^;
Ons Ite
Incineration
M.igni tude
ol Residual Risks
Adequacy
ol Controls
Significant residual
risks remain, since
containment or treatment
technologies are not
employed. Risks remain
as identified In the EA.
Potential exists (or
exposure to contaminated
solids and leaching of
contained material to
ground water if cap
falli.
Mo direct engineering
controls to prevent
exposure to contaminated
«olIds; fence Is
susceptible to
vanda11sm; Inspec 11ons
and reviews required.
Monitoring will track
but not remediate
contamination.
Hon-RCRA cap will reduce
potential for direct
contact with soils and
sediments; leaching to
ground water reduced.
Capping requires regular
inspection and
maintenance. Monitoring
Mill track but not
remediate contamination.
Residual risk of
untreated volume
dependent on selected
cleanup level. Less
than 10 ppm PCB In
residual; Long-tern
management required for
saturated soils.
Solvent extraction is an
Innovative technology;
treatablllty study Is
required; compatible
with flood control
requirements In Meadow
Brook. Monitoring
needed to verify
treatment effectiveness.
Residual risk of
untreated votuM
dependent on selected
cleanup level. Let*
than 10 ppn PCB In
residual; Long-ten*
management required for
saturated soils.
Oechlorlnatlon Is an
Innovative technology;
treatablllty study U
required; compatible
with flood control
requirements In Meadow
Brook. Monitoring
needed to verify
treatment effectiveness.
Residual risk of
untreated volume
dependent on selected
cleanup level.
Treatment residual Is
assumed to pats leaching
requirements.
Additional treatment
would be required for
Inorganics If leaching
Halts were exceeded.
Long-tens management
required for saturated
soils.
Thermal treatment Ia a
proven technology to
destroy organlcs; long-
term management of
residuals may be
required. Compatible
with flood control
requirements tn Needou
Brook. Monitoring
needed to verify
treatment effectiveness.
104
-------
table I*- Continued)
Page 4
Assessment
factors
Alternative SC-1
Minimal No-Action
Alternative SC-2
Capping
Alternative SC-3
Solvent
Extractions TEA
Alternative SC-4
Oechlorlnatloni
KfCft
Alternative $C-$
On* It*
Incineration
leliability
»eduction o( tonicity.
Mobil ity and Voli/nc
Sol* reliance on fence
and institutional
control* to prevent
exposure; high level of
residual rltk. Further
degradation of ground
water likely.
long-term monitoring
required.
No reduction In
mobility, toxiclty, or
volume of wastes.
Likelihood of failure !
low aa long at 0 A N I*
performed; risks fro*
direct contact and
Inhalation of
VOCa la reduced; further
degradation of ground
Mater la possible.
Long-term monitoring
required.
eduction in contaminant
mobility due to
reduction of
Infiltration. No
reduction in toxiclty or
volime.
Remedy Hill be highly
reliable due to removal
of organic* from aolla
and sediment*.
Monitoring needed to
verify treatment
performance.
No long-term maintenance
required.
Long-term monitoring of
saturated soils
required.
Significant reduction In
contaminant volume and
in toxiclty by
destruction of treatment
oil concentrate. Nay
Increase mobility of
PCts In residuals.
emedy Mill be highly
reliable due to removal
of organic* from soil*
and sedlMnts.
Monitoring nssdsd to
verify treatment
performance. Treatment
realduala are not toxic.
No long-term maintenance
required.
long*term monitoring of
saturated toll*
required'.
Significant reduction In
contaminant volume and
toxiclty by destruction
of * and chlorinated
organic*. May Increase
mobility of Kts In
residual*.
omsdy Mill be highly
reliable due to
destruction of organic*
from aolla. and
sedlamnte. Monitoring
nssdsd to verify
treatment performance.
No long-term, Maintenance
required.
Long-ten* monitoring of
eaturated *oil*
required.
Significant reduction In
contaminant volume and
toxiclty by destruction
of PCi* and organic*.
Nay Increase mobility of
Inorganics In residuals.
luplenyntabil i ty
lechmciil feasibility
All components easily
implemented.
Wetlands restoration any
be difficult.
Solvent extraction I* an
Innovative technology
requiring special
equipment and operators.
Naa been demonstrated on
other site* to achieve
sufficient reduction In
initiel concentration to
achieve target level.
Wetland* restoration may
be difficult.
Dechlorlnetlon la an
innovative technology
requiring special
equipment and operatore.
Naa been damoratroted on
other sites to achieve
sufficient reduction In
Initial concentration to
achieve target level.
Wetland* re*toretIon may
be difficult.
Incineration requires
speclel equipment and
operator*. Nee been
demonstrated on other
sites to achieve
99.99991 destruction of
Cts.
Wetland* restoration may
be difficult.
105
-------
table I J. (
Pnyr 5
nucd)
jssmcnt Alternative SC-1
:tors Minimal No-Action
Alternative SC
Capping
2
Alternative SC-3
Solvent
Extraction: TEA
Alternative SC-4
Dechlorlnatlon:
KPEG
Alternative SC-5
Ons Ite
Incineration
Artninistrat ivc
FcnsibiIity
Long-term coordination
between EPA and State
required for monitoring.
Long-tern coordination
between EPA and State-
required for excavation,
wetlands restoration and
monitoring.
Av»ilubiIity of Services
Services and materials
locally available.
Services and materials
regionally available.
Cost
Refer to
Table 6-17 for Cost
S urinary.
Refer to
Table 6-17 for Cost
S urinary.
Same as Alternative SC-2
for excavation and
wetlands restoration,
requires offslte
transport and
Incineration of
treatment oil
concentrate, does not
require long-term
coordination.
Solvent extraction
equipment ( available
from a few national
sources. Incineration
services are available
In eastern region
for treatment of oil
residues. Remainder of
component* same as
Alternative SC-2.
Refer to
Table 6-17 for Cost
S turnery.
Same at Alternative SC-2
for excavation and
wetlands restoration,
doe* not require long-
tern coordination.
Same as Alternative SC-2
for excavation and
wetlands restoration,
does not require long-
tern coordination.
Dechlorlnatlon equipment
Is available from one
commercial source.
Remainder of component*
same as Alternative
SC-2.
Refer to
Table A-17 for Cost
Summary.
Mobile Incinerators and
operator* are available
from a nuifcer of sources
nationally. Remainder of
componenta same a*
Alternative SC-2.
liefer to
Table 4-17 for Cost
Surma ry.
106
-------
12 (Continued)
f ic tors
Alternative SC-t
Minimal No-Action
Alternative SC-2
Capping
Alternative SC-3
Solvent
Extract Ion: TEA
Alternative SC-4
DecMorlmtlom
K*ca
Alternative SC-5
Oml to
Incineration
Compliance ulth «R<»
RC»A closure/
post-closure
requirements Mill not be
net. ARARs for ground
water will not be
attained.
Overall Protection
Risk of direct contact
and inhalation
controlled by fence;
cont.nued degradation of
ground water quality
will occur.
Excavation performed In
wetland. Waste Material
Mill be removed fro*
flood plain. RCRA
closure/post-closure
requirements met. ARAKS
for ground Mater May not
be attained dependent
upon selected MM
alternative.
Risk of direct contact
with soils and sedlnents
controlled by non-HCRA
cap; risk of VOC
Inhalation controlled by
reducing volet Hi tat Ion;
provides protection to
aquatic life coopered to
SC-1; potential remains
for continued ground
water and surface Mater
degradation.
Same as Alternative
SC-2.
Sam* M Alternative
SC-2.
Same M Alternative
SC-2.
Risk of direct contact
with soils and sediment*
controlled; risk of VOC
Inhalation controlled by
reducing volatllliation;
provide* equal
protection to aquatic
life cowpered to SC-2;
Potential reawln* for
continued ground water
degradation, due to
contMlnants below
groundwater table.
Risk of direct contact
M!tli soils end aedlawnt*
controlled; risk of VOC
Inhalation controlled by
reducing volatilization;
provide* equal
protection to aquatic
III* compared to SC-3;
Potential rea*lne for
continued ground Meter
degradation, due to
conta«lnanta beloM
groundiMter table.
Risk of direct contact
Mlth Mile and sedlatent*
controlled; risk of VOC
Inhalation controlled by
reducing volarilItatI on;
provide* equal
protection of aquatic
life M SC-J; Potential
roMln* for continued
round water
degradation, due to
contaminants beloM
groundMater table.
State tccfptaoct
Acceptance
To be addressed following public comment period.
To be addressed following public comment period.
107
-------
Assessment
(actors
TABLF *,
SUMMARY OF OEIAIIEO ANALYSIS MAMACEMEMt OFmCRATIOI (MH) REMEDIAL ALTERNATIVES
NORUOOO PCS SITE FEASIBILITY STUDY
Alt emotive MM-1
Minimal No-Action
Alternative MM-2
Air Stripping
Alternative KH-J
Carbon Adsorption
Alternative MM-4
UV/OxIdatlon
Major
Conponerits
Short-lerm
[Meet ivcncss
Protect ion
o( Conmjnity
Protect ion
ol workers
Obtain (and use/deed
restrictions
Implement institutional
restrictions on future
water usage
Conduct public education
programs. Including public
meetings and presentations,
to increase public awareness
Perform grounduater, surface
water, sediment, and air
monitoring to monitor
contaminant concentrations
and migration
Perform site review every
five years
No significant increase in risks
during implementation
Protection of workers required
during monitoring well
installation.
Minor impacts associated with
installation of monitoring system.
Shallow/bedrock collection
and extraction system
Activated carbon bed
Air stripping with vapor
phase controls
Precipitation/filtration.
Groundwater recharge system.
Perform site review every
five years.
Slight increase In risk associated
with the installation of
extraction and recharge system,
treatment system has potential to
release VOCs if failure occurs.
Protection required during
Installation of extraction/recha-
rge system and monitoring system.
Shallow/bedrock collection
and extraction system
- Activated carbon bed
Granular Activated Carbon
Precipitation/filtration.
- Groundwater recharge system.
Perform site review every
five year*.
Slight Increase In risk associated
with the Installation of
extraction and recharge system,
and offslte regeneration or
disposal of spent carbon.
Protection required during
Installation of extraction/recha-
rge system and monitoring system.
Shallow/bedrock collection
and extraction system
UV/OxIdatlon unit
Precipitation/filtration.
Groundwater recharge system.
- Perform site review, every
five years.
Slight Increase In risk associated
with the Installation of
extraction and recharge aysten,
treatment system may produce
sludge lor offslte transport and
disposal.
Protection required during
Installation of
extraction/recharge system
and monitoring system.
Environmental
Impacts
1 imc to Achieve
Protect ion
If institutional controls
effective within one year of start
of remedial design, reduction In
potential for groundwater
ingest ion.
Significont future residual risks
remain, since containment or
treatment is not performed. Risks
renviin as presented in the EA.
Minor impacts associated with
installation of extraction/recha-
rge system and monitoring system.
Construction and implementation
could be achieved within two years
start of remedial design. Risks
associated with VOCs removed from
aquifers within 8 to 24 years.
Residu.il risks from PCBs in
aquifers will remain for many
yc.irs.
108
Minor Impacts associated with
Installation of extraction/recha-
rge system and monitoring system.
Construction and Implementation
could be 'achieved In less than two
years of start of remedial design.
Risks associated with VOCs removed
from aquifers within 8 to 24
years. Residual risks from PCBs
In aquifers will remain for many
years.
Minor Impacts associated
with Installation of
extractIon/recharge system
and monitoring system.
Construction and Implementation
could be achieved less than two
years-of stsrt remedial design.
Risks associated with VOCs removed
from aquifers within 8 fo 24
years. Residual risks from PCBs
in aquifers will remain for many
years.
-------
I *ble /
Page 2
Assessment
factors
Alternative MH-1
Minim*! No-Action
Alternative HH-2
Air Stripping
Alternative HH-5
Carbon Adsorption
Alternative M
(Itf/Oxldatlon
Adequacy No direct engineering controls to
of Controls prevent exposure; dependent on
land use and deed rtstrlet Ions.
Long-term Monitoring required.
Pliability Sole reliance on Institutions!
controls to reduce exposure. High
level of residual risk. Near-term
reliability good, long-ten*
unknown.
Monitoring and Maintenance of
collectlon/treat«*nt/recharge
eysteai required to maintain
effectiveness.
likelihood of fsi lore low If
proper 01M perfor*ed. Pilot
testing used to design system,
anitoring performed to evaluate
effectiveness.
Monitoring and Maintenance of
collectlon/treatMent/recharge
syste* required to Mlntoln
effectiveness.
likelihood of failure low If
proper OM perforated. Pilot
testing used to design system,
Monitoring perforated to evaluate
effectiveness.
Monitoring and maintenance of
col lactlon/treatMent/racharge
systaai raqulrod to Mlntoln
effectiveness.
likelihood of failure tow If
proper (MM perforated. Pilot
tasting wad to design system,
Monitoring performed to evaluate
effectiveness.
deduction No reduction In nobility,
ol Ionicity. toxicity, or volume. PCS* Move
Hobility and very slowly in aquifers; VOCs Move
volume more rapidly.
Implement
ability
technical
Irosibility
Adninistrat i
fcasibil ity
ity
ol Service*
All components easily implemented.
Uould require 1009-term
coordination between State and EPA
for adequate monitoring and
evaluation of need to expand
institutional controls.
Services and materials available
locally.
Significant reduction in
contaminant toxicity of extracted
groundwater and reduction of
contaminant volune in groundwater.
Relatively uncomplicated to
implement.
Same as NN-1 with addition of
meeting State drinking water
standards and criteria for
recharge to groundwater.
Services and materials available
in New England.
Significant reduction In
contaminant toxicity of extracted
groundwater and reduction of
contaminant volume In groundwater.
Relatively uncomplicated to
implement.
Same as NN-1 with addition of
meeting State drinking water
standards and criteria for
recharge to groundwater.
Services and materials available
In New Cnglend.
Significant reduction In
contaMlrtant toxicity of extracted
groundwater and reduction of
contaminant voluae In groundwater.
UV/oxIdatlon Is an Innovative
technology. Mill require pilot
testing to verify design and
performance characterletlea.
a NN-1 with addition of
meeting State drinking weter
standards and criteria for
recharge to groundwater.
Most services and Materials
available In New England, limited
number of vendors of UV/oxIdatlon
treatment units In nation.
Co-it
10-rear
r- w (SX)
JO year
170,000
1967.000"
11,018,000
12,501.000
loy
1 934,000
12.526.000
S1,(K7,000
12.854,000
-------
Pogc J
I net ors
Mternat ive HM-1
Minimal No-Action
Alternative HM-2
Air Stripping
Alternative MN-3
Carbon Adtorption
Alternative KM-*
UV/0*idafion
Vill.rtot me?! Groindwater
Protect ion Criteria; contaminant-
spec i lie ARARs lor groundwater not
t tained.
Act ion-spec i lie ARARs attained.
Contaminant-spec I fie ARAR»
attained lor VOCS within 10 yecrt.
Act(on-specific ARARs attained.
Cont«*in«nt-»pecilic ARAR»
attained for VOCt «!thm 10 yeart.
Act ion-specific A»AR»
ContMinant-tperif it ARA»»
attained for VOC* vitltm 10 yn
Protrt t ion
Minimal level of protection by
limiting future u*e and
oV.velofinrnt ol the groundMater.
Future risk* Mitigated by the
collection and treatment of
contaminants from the groundwater
aquifers, lime to achieve these
goalt is about 10 years and Is
United by the chemical properties
of contaminant* and aquifer
properties which prevent effective
extraction.
future risk* mitigated by the
collection and treatment of
contaminants from the groundwater
aquifers, line to achieve these
goals is about 10 years-and is
limited by the chenlcat properties
of contaminants and aquifer
properties which prevent effective
extraction.
future risks miligate«1 t/y the
collection and treatment ul
contaminants from the gi i»»»J»»
aquifers, lime to achieve i*r
goals is about 10 year* ai«t i>
limited by the chemical propei
of contaminants and aquifer
properties which prevent el lee
extraction.
S' ? IC. .*£ ccpliinr c
Acecptnncc
lo be addressed following public comment period.
lo be addressed following public camcnt period.
110
-------
TABLE 14
Assumptions Used In Calculating Soil Target Clean Levels
A. Soils at Grant Gear and Surrounding Connercial Properties
Parameter
Frequency of Exposure
Years of Exposure
Average Body Weight Over
Exposure Period
Soil Contact Rate
Dermal Absorption Factors:
inorganics
noncarcinogenic PAHs
carcinogenic PAHs
PCBs
benzole acid
Quantity of Soil Ingested
Oral Absorption Factors:
inorganics
PCBs & PAHs
other organics
Exposure Conditions
100 events/years
20 years
70 kg
500 mg/event
Negligible
0.05
0.05
0.05
0.5
100 rag/exposure
event
l.O
0.3
1.0
111
-------
Table 14 Continued
B. Soils and Dredge Piles Between Grant Gear's Northern Fence
and Meadow Brook/ and Residential Properties North of Meadow
Brook
Parameter
Exposure Conditions
Frequency of Exposure
Years of Exposure
Average Weight Over Exposure
Period
Average Soil Contact Rate
Over Exposure Period
Dermal Absorption Factors:
PCBs
noncarcinogenic
carcinogenic PAHs
benzoic acid
chloroform
volatile organics
Average Quantity of Soil Ingested
Over Exposure Period
Oral Absorption Factors:
inorganics
PCBs & PAHs
other organics
100 events/year
70 years
70 kg
500 mg/event
0.05
0.05
0.05
0.5
0.5
0.5
100 mg/event
1.0
0.3
1.0
112 .-
-------
Table 15
Syponarv of Soil Component
Section A Section B
Area north
of Grant
Gear
northern
fence and
adjacent to
Meadow Brook
including
residential
properties
Areas within
Grant Gear
property and
surrounding
commercial
properties
Meadow Brook
Sediments
Excavation
Action
Levels
Solvent
Extraction
Treatment
Action
Levels
Backfilling
Reguirements
1 ppm PCBs
2 ppm total
carcinogenic
PAHs
10 ppm PCBs
6 ppm
carcinogenic
PAHs
Clean Fill
Topsoil
Revegatation
10 ppm PCBs
6 ppm
carcinogenic
PAHs
(25 ppm PCBs
for
commercial
properties
outside
Grant Gear)
10 ppm PCBs
6 ppm
carcinogenic
PAHS
All treated
soils
Untreated
soils with
<10 ppm PCBs
and <6 ppm
PAHs
10 inch soil
cover clean
fill
revegatation
/repavement
1 ppm PCBs
10 ppm PCBs
6 ppm
carcinogenic
PAHs
Wetlands
Restoration
113
-------
TABLE 16
CHEHICAl-SPECIFIC ARARS AND CRITERIA, ADVISORIES, AND GUIDANCE
NORWOOD PCB SITE
NORWOOD. MASSACHUSETTS
MEDIUM/AUTHOR I IT
REQUIREMENT
STATUS
REQUIREMENT SYNOPSIS
ACTION TAKEN TO ATTAIN ARAKS
Ground Water
federal Regulatory
Sccnts
SDUA-Maximum Contaminant
Levels (HCLs)
(60 CFR U1.11-141.16)
State Regulatory
Retirements
Star;ards
RCRA Subpart f Releases from
Solid Waste Management Units
(40 CFR 264.90 264.101)
DEP - Massachusetts
Groundwater Quality Standards
(314 CMR 6.00)
Croundwater Discharge Permit
Program (314 CMR 5.00)
DEP - Drinking Water Standards
(310 CMR 22.00)
Relevant and MCLs have been promulgated for number
Appropriate of common organic and inorganic
contaminants. These levels regulat* the
concentration of contaminants In public
drinking water supplies, but may also-be
considered relevant and appropriate for
ground water aquifers potentially used
for drinking water.
Relevant and RCRA MCLs provide groundwater protection
Appropriate standards for 14 cornnon contaminants.
All are equal to the SOUA HCLs for those
contaminants.
Applicable Massachusetts Groundwater Quality
Standards have been promulgated for
number of contaminants. When the state
levels are more stringent than federal
levels, the state levels will be used.
Relevant and The standards applying to site
Appropriate contaminants are generally equivalent to
Massachusetts Drinking Water Standards.
Relevant and The Massachusetts Drinking Water
Appropriate Guidelines and Standards Include
Massachusetts Maximum Contaminant Levels
(MMCLs) which are the MCL values
established by EPA and adopted by the
state and HCLs which have been
established for any of the contaminants
of concern In groundwater; therefore,
the MCLs were used to establish target
levels.
Treatment will be conducted to achieve
SOWA HCLs In groundwater.
Treatment wilt be conducted to achieve
RCRA HCLs In groundwater.
OEOE groundwater standards were
considered when determining clean-up
(vela and discharge Unite for treated
groundwater.
DEQE groundwater standards were
considered when determining clean-up
levels and discharge limits for treated
groundwater.
Since some DEP drinking water standards
are the same as HCLs, promulgated HCLs
were used to set clean-up levels for
contaminant* of concern Including vinyl
chloride and trlchloroethene.
Groundwater target cleanup levels for
tetrachloroethene and 1,4-
dlchlorobenzene were based on the State
drinking water standards.
0'. II
-------
table 18
Page Two
MARs
Requirement Synoosls
Action to ha Taken to Attain MM*
DIP ' Closure and
Post-Closure .
(310 CMR 30.580 595r
DEP Hazardous Waste
Regulations, Phase I .
and II (310 CM* 30.00)'
Proposed Standards for
Control of Emissions
of Volatile Organic*
52 fR 3748 (February 5,
19B7)J
Fish and Wildlife
Coordination Act 16 USC661
DtP Wetlands Protection
(110 CMR 10.00)
this regulation details specific requirements for closure
and post-closure of haiardous Matte facilities.
this regulation provides a comprehensive program for the
handling, storage and recordkeeplng at haiardous waste
facilities. This regulation operates supplements RCRA
regulations.
Prescribes proposed standards for VOC emissions from units
such as air strippers.
this act requires that before undertaking any Federal action
that causes the modification of any body of Mater or affects
fish and Mildlife. the following agencies must be consulted:
the appropriate State agency exercising jurisdiction over
Wildlife Resources and the U. S. fish and Wildlife Service.
this regulation outlines the requirements necessary to work
within 100 feet of a coastal or inland wetland.
llnce froundwater will bt cleaned to drinking utter
standards, post-closure standards Mill be met. full
compliance will depend en ttfilch source control option Is
ut11 lied.
All handling, storage, and recordkeeplng executed at the
site Mill bo performed In manner consistent with
regulations.
Air treatment equipment will be designed, constructed, and
operated In tandem Mlth air-stripping units.
If It Is determined that the alternative Mill cause a
modification of a body of Mater, the U. S. Fish and Wildlife
Service Mill be notified.
All' Mork done within the regulated wetlands areas Mill be
performed so as to minimi le the adverse effects on Met I ends,
If possible.
CWA Disposal of
Dredged or rill Material
(40 CFR 230)'
Regulates the discharge of dredged material to control the
impacts on wetlands.
Work Mill be performed In a
adverse effects on MetIends.
that minimises the
Standards Applicable
to transporters of
Hazardous Waste
RCRA Section 3003.
10 CM 262 and 263.
40 crR 170 to 1791
Establishes the responsibility of offslte transporters of
haiardous waste In the handling, transportation, and
aienagement of the waste. Requires a manifest, record
keeping, end lanedlate action In the event of a discharge of
hazardous waste.
this regulation Mill be applicable to any company contracted
to transport hazardous material from the site (vapor phase
carbon; PCS-contamlnated liquids; metal sludge).
NOR
4
120
-------
tnblc
Page three
ARARs
18
Synopsis
Action to be taken to Attain ARARs
tSCA Disposal
Requirements
(40 CFR 761.60)
1
MDWPC Supplemental
Requirements for Hazardous
Waste Management ,
faculties (5U CHR fl.OO)Z
OEOE Underground
Water Source Protection
(110 CMR 27.00)'
CAA - NAOS lor total
Suspended Particulates (40
CFR 129.105, 750)'
Establishes treatment and disposal standards for PCB Items
and PCBs In soil* end liquids tor all alternatives which
Include the disturbance of PCB-contanlnated soil and
generate PCB-contamlnated liquids.
Outlines additional requirements for water treatment unit,
surface Impoundment and POtU which treats hatardous waste.
Regulates effluent contaminant concentrations to the ground.
This regulation specifies maximum primary and secondary
24-hr, concentrations for partlculate matter. Fugitive dust
emissions fronts Ite excavation activities must be maintained
below 260 ug/m (primary standard).
If soil* removed during Implementation of the collection and
recharge system arc contaminated tilth PCBs regulated by TSCA
those soils Mill be treated or disposed In carpilane* with
TSCA. Sacrificial carbon bed materials and PCB-contatnlnated
oil extracts Mill be managed according to TSCA.
Requirements Mill be considered during design and
Implementation of the Mater treatment system.
Effluent contaminant concentration requirements must be
considered prior to discharge of the treated grounduater via
the aquifer recharge system.
Fugitive dust emissions Mill be controlled during
construction to maintain concentrations below these levels.
OEOE Antoicnt Air
Ount:ty Standards
lor the Commonwealth
of Mnssdchusetts
O10 CMR 6.00)
OEOE Air Pollution
Controls
-------
TAILI 18
ACTION-SPECIFIC MAM FOR ALTERNATIVE
SOLVENT EXTRACTION
NORWOOD PCI SITE
SC-3
Regulrement Synopsis
Action to bt taken to Attain ARARi
OSHA-General Industry
Standards (29 CFR 1910)'
OSHA-Safety and Health
Standards .
(29 CfR 1926)'
Resource Conservation and
Recovery Act (RCRA), «CRA
Subtitle C,
40 CfK 260
OSMA-Recordkceping,
Reporting and Related
Regulations (29 CFR 1904)'
DEP -Standards for Owners
and Operators of Permitted
Matardous Waste facilities
(310 CMR 30.510 516)'
OEP Contingency Plan,
Emergency Procedures,
Preparedness and
Prevention .
(310 CMR 30.S20 52*)z
DEP Closure and
Post-Closure .
(310 CMR 30.580 59-5 r
Tliet* regulations specify the 8-hr, time-weighted average
concentration for various organic compounds. Training
requirements for workers at heiardous waste operations art
specified In 29 CFR 9910.120
This regulation specifies the type of safety equipment and
procedures to be followed during site remediation.
RCRA regulates the generation, transport, storage,
treatment, and disposal of hatardous waste. CCRCLA
specifically requires (In Section 121(0)(3» that hazardous
substances from, response actions be disposed of at
facilities In compliance tilth Subtitle C of RCRA.
This regulation outlines the recordkeeplng and reporting
requirements for an employer under OSHA.
General facility requirements outline general waste
analysis, security measures. Inspections, and training
requirements.
This regulation outlines requirements for safety equipment
and spill control.
This regulation details specific requirements for closure
and post-closure of haiardous waste facilities.
Proper respiratory equipment wilt be taarn If It U not
possible to maintain the work atmoaphere below those
concentrations. Fugitive dust emissions will bo controlled
during construction to maintain concentrations below these
levels.
All appropriate safety equipment will be worn on site during
construction and procedure* will bo followed during
environmental Monitoring.
All excavation, storag, treatment, and disposal activities
will bo designed and implemented In accordance with
applicable RCRA regulations.
This regulation will bo applicable to the construction-
coaponyia) contracted to perform the specified construction
activities and monitor soils and sediments prior to
'disposal.
During alt slto work, a written waste analysis plan oust be
developed and maintained on alto. Entry to the alto oust bo
prevented by o 24 hr. surveillance system and appropriate
signs posted. A written Inspection program must bo
developed, and all personnel oust complete an on-the-Job
training program, to ensure facility compliance.
Safety .and conaunlcatlon equipment will be Installed at the
alto; local authorities will be familiar I ted with alto
operations and construction activities will be conducted to
prevent any typo of spillage or contaminated runoff from
leaving the alto.
Treated sol Ida wilt bt monitored to Insure they can bt
disposed of onalto without further treatment. The treatment
units and associated pada will be decontaminated,
dismantled, and removed from the site.
122
NOB
-------
18
table
Page Two
ARARs
Requirement Synopsis
Action to be Taken to Attain ARARs
Interim RCRA/CERClA
Guidance on Non-Contiguous
Sites and Onsite
Management of Waste
nnd treated Residue
(USEPA Policy Statement
March 27. 1986)3
Fish and Wildlife
Coordination Act USC661
CAA-NAOS for total
Suspended Participates (40
CFR 1Z9.1Q5. nor
If treatment of storage unit Is to be constructed for
onslte remedial action, there should be a clear Intent to
dismantle, remove, or close the unit after the CERCLA action
Is completed. Should there be plans to accept commercial
waste at the facility after the CERCIA waste has been
processed. It Is EPA policy that a RCRA permit be obtained
before the unit Is constructed.
this act requires that before undertaking any Federal action
.that causes the modification of any body of water or affects
fish and wildlife, the following agencies must be consulted:
the appropriate State agency exercising jurisdiction over
Wildlife Resources and the U.S. fish and Wildlife Service.
,-Ihls regulation specifies maximum primary and secondary 24-
'hr. concentrations for participate matter. Fugitive dust
emissions from_slte excavation activities must be maintained
below 260 ug/m (primary standard).
Afttr completion of the treatment process, tht I.E.S.T.
equipment will be decontaminated and removed from the site.
Any Materials that cannot be decontaminated will be disposed
of In an offslte landfill.
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 Service.
Fugitive dust emissions will be controlled during
construction to maintain concentrations below these levels.
I Si A Disposal
Requirements (40 CFR
761.60}'
Establishes treatment and disposal concentrations of PCBs In
soils for all alternatives which include the disturbance of
PC8-contaminated soil.
Treatment or disposal of excavated soils and sediments will
be performed In accordance with these regulations.
1SCA Storage
Requirements
(40 CFR 761.65)
ISCA Chemical Waste
landfill Requirements
(40 CFR 761.75)
Outlines requirements for temporary TSCA-regulated waste
storage Including specific design requirements.
Establishes standard for PCB landfills Including provisions
for the Regional Administrator to waive requirements.
Proper dealgn considerations Mill be Implemented to Insure
that alt storage of TSCA-regulated waste satisfies the
requirements of the regulations.
Disposal of treated soils and sediments will comply with
this regulation, but will Include waivers for clay soils,
synthetic liner and SO feet to water table.
DfP Hotardous waste
Regulations, Phase I
nnd I I (310 CMR 30.00)
DtP uctlnnds Protection
(110 CMR 10.00)'
Cw« Disposal of Dredged
or Fill M.vtrrial
(<-0 cm ?50)
this regulation provides a comprehensive program for the
handling, storage and rccordkeeping at hatardous waste
facilities. This regulation supplements RCRA regulations.
this regulation outlines the requirements necessary to work
within 100 feet of a coostal or inland wetland.
Regulates the discharge of dredged material to control the
impacts on wetlands.
All handling, storage, and record keeping executed at the
site will be performed In a manner consistent with
regulations.
Wetlands disturbed by excavation will be returned to their
natural state following treatment of soils.
Wetlands disturbed by excavation will be returned to their
natural state following treatment of soils.
r\i.
123
-------
Table 18
Page Three
ARAR*
Requirement Synopsis
Action to be taken to Attain ARARs
DEOE Aiiblent Air
Quality Standards
for the Connurvweal th
of Massachusetts
(310 C«R 6.00)
DEOE Air Pollution
Controls' (310 CM* 7.00)
waterways Regulations (314
CHR 9.00)'
USfPA Office of Solid
,u«ste and Emergency
Response, Directive
935S.O-28; Air Stripper
Con!rot Guidance
This regulation specifies dust, odor, and noise emissions
fro* construction activities.
the act prohibits discharges to the atmosphere that create
an odor nuisance or air pollution beyond the property line.
Regulate* MM sources of air pollution to prevent air
quality degradation. Requires the use of "Beit Available
Control Technology* (IACT) on all new sources.
Regulates the water quality certification of dredging and.
disposal of dredged Material.
Establishes guidance on the control of air Missions from
air strippers used at Superfund sites for groundwater
treatment.
Fugitive dust Mill bt controlled by water pray* or
suppressant*. All equipment Mill be Maintained so at not to
produce eicoMlve mite.
Design of the I.I.S.T. solvent extract Ion technology
consider* the proper handling and use of TEA.
ACT will be used en all new sources.
Dredging of sediments will be Implemented according to
regulation*. Including constant monitoring of downstream
water* during Implementation to control migration of
contaminated sediments.
VOCs will be controlled In air stripper emissions with lest
Available Control Technology under Massachusetts'
requirement*.
HSVA-land Ban
(40 CfR 268, Sub 0)1
Restricts Ir/id disposal of specified hatardous wastes.
Waste residual* produced by solvent extraction will be
properly disposed or treated a* required by the regulations.
Applicable
Relevant and Applicable
To be Considered
124
-------
TABLE IB
AC1IOH-SSPECIHC ARARS FOR ALTERNATIVE SC-5
ONSITE INCINERATION
NORWOOD PCS SITE
ARARs
Requirement Synopsis
Action to be Taken to Attain ARARs
OSHA-Ccneral Industry
Stnndards (29 CFR 1910)
OSHA-Safety and Health
Standards (29 CFR 1926)
1
Resource Conservation nnd
Recovery Act (RCRA), RCftA
Subtitle C 42 U.S.C. 4
692 et scq.'
OSHA-Recordkeeping,
Reporting and Related
Rcgulotions (29«CFR 1904)
OEP Standards for Owners
and Operators of Permitted
Hazardous Waste Facilities
(310 CHR 30.510 516)Z
DEP Contingency Plan,
Emergency Procedures,
Preparedness and
Prevention
(310 CMR 30.520 524)Z
OEP Closure and
Post-Closure
(310 CMR 30.580 595)Z
Off Maiardous Waste
Pcqulotions, Phase I
and II <3)0 CHR 30.00)
These regulations specify the 8-hr, time-weighted average
concentration for various organic compounds. Training
requirements for workers at hazardous waste operations are
specified In 29 CFR 9910.120
This regulation specifies the type of safety equipment and
procedures to be followed during site remediation.
RCRA regulates the generation, transport, storage,
treatment, and disposal of hazardous waste. CERCLA
specifically requires (In Section 121(d)(3)> that hazardous
substances from response actions be disposed of at
facilities in compliance with Subtitle C of RCRA.
This regulation outlines the recordkeeplng and reporting
requirements for an employer under OSHA.
General facility requirements outline general waste
analysis, security measures. Inspections, end training
requirements.
This regulation outlines requirements for safety equipment
end spill control.
This regulation details specific requirements for closure
and post-closure of hazardous waste facilities.
this regulation provides a comprehensive program for the
hand!Ing, storage and recordkecping at hazardous waste
facilities. This regulations operate in lieu of federal
Proper respiratory equipment nil I be worn If It l« not
possible to maintain the work atmosphere below these
concentrations. Fugitive dust emissions will be controlled
during construction to maintain concentrations below these
levels.
All appropriate safety equipment Mill be worn on site during
construct Ion'and procedures will be followed during
environmental monitoring.
Any facility used for off-site disposal will operate In
compliance with applicable ftCRA regulations.
This regulation will be applicable to the construction
company(a) contracted to perform the specified construction
activities and monitor the soils and sediments prior to
disposal.
During all tlte work, a written waste analysis plan must be
developed and maintained on site. Entry to the site must be
prevented by a 24 hr. surveillance system and appropriate
signs posted. A written Inspection program must be
developed, and all personnel must complete an on-the-Job
training program to ensure facility compliance.
Safety and comunlcatlon equipment will be Installed at the
site; local authorities will be familiarized with site
operations and construction activities will be conducted to
prevent any type of spillage or contaminated runoff from
leaving the site.
Treated solids will be monitored to Insure they can be
disposed of onslte without further treatment. The treatment
units and associated pads will be decontaminated,
dismantled, and removed from the site.
All handling, storage, and recordkeeplng executed at the
site will be performed in a manner consistent with
regulations.
>J(K IK II
125
-------
'We 18
Page two
ARARs
Synoos I s
Action te be Taken to Attain MAfts
Clean Air Act (CAA)
Nation*! Air Duality
Standards (NAOS) .
(440 Cfll 1 to 99)*
Inter in RCRA/CERCIA
Guidance on Mon-Contiguous
Sites nod Omite
Management offeaste
ond treated Residue
(USEPA Policy Statement
March 27, 1986)J
fish and wildlife
Coordination Act
USCi'^1 et. seq.
CAA-NAOS for Total
Suspended Particulates
(40 Cr« 129.105. 750)*
Applies to Mjor stationary sources such at treatment unltt
that have the potential to emit significant aoountt of
pollutants such a* NO^' SO,' co» **** mercury and
partIcutates (wore than 250 tons/year). Regulations under
CAA do not specifically regulate emissions fro* hatardous
watte Incinerators, but It it likely that Prevention of
Significant Deterioration (PSD) provisions would apply to an
onslte treatment facility.
If a treatment of storage unit Is to be constructed for
onslte remedial action, there should be a clear Intent to
dismantle, remove, or close the unit after the CCRCIA action
It completed. Should there be plant to accept commercial
watte at the facility after the CERCIA watte hat been
processed, It It EPA policy that a RCRA permit be obtained
before the unit it constructed.
This act requires that before undertaking any Federal action
that causes the and!fleet ion of any body of water or affects
fish and wildlife, the following agencies must be consulted:
the appropriate State agency exercising jurisdiction over
Wildlife Resources and the U.S. fish and Wildlife Service.
This regulation specifies awxlaua primary and secondary 24-
hr, concentrations for partlculate matter. Fugitive dust
emissions from_slte excavation activities must be maintained
below 260 ug/m3 (primary standard).
If necessary, tha Inclntrstor will be constructed and
operated ta achieve emissions af these contaminants at
levels equal ta ar lass than those required far stationary
treatment unltt.
After completion af tha Incineration process, tha
Incinerator will be decontaminated and removed from the
site. Any materials that cannot be decontaminated Mill be
disposed of In an affalta landfill.
During the Identification, screening, and evaluation af
alternatives, tha effects on wetlands ara evaluated. If an
alternative modifies a body af water, EPA suet consult the
U. .S. Fish and Wildlife Service.
fugitive dust emissions Mill be controlled during
construction ta maintain concentrations below' these levels.
126
-------
Tnble 10
Page three
ARARs
Requirement Synopsis
Action to be Taken to Attain ARARs
TSCA Disposal
Requirements
(40 CFR 761.60)
tSCA Storage
Requirements
(40 CfR 761.65)
1SCA (40 CFR 761.70)
OEOE Wetlands Protection
(310 CM« 10.00)
CUA Disposal x>f
Dredged or Fid Material
(40 CFR 230)'
DE'fE - Ambient Air
Quality Standards
(or the Commonwealth
ol Massachusetts
(310 CMR 6.00)
DEOE Air Pollution
Controls (310 CMR 7.00)
Waterways Regulations
(JU CMR 9.00)'
USEPA office of Solid
u.iste and Emergency
Response, Directive
93SS.O-2B; Air Stripper
Control Guidance
Establishes treatment and disposal concentrations of PCBs In
soils for all alternatives which Include the disturbance of
PCs-contaminated soil.
Outlines requirements for temporary TSCA-regulated waste
storage facilities Including specific design requirements.
Lists special performance standards for Incineration of
PCBs.
This regulation outlines the requirements necessary to work
within 100 feet of a constal or Inland wetland.
Regulates the discharge of dredged material to control the
impacts on wetlands.
This regulation specifies dust, odor, and noise emissions
from construction activities.
The act prohibits discharges to the atmosphere that create
an odor nuisance or air pollution beyond the property line.
Regulates new sources of air pollution to prevent air
quality degradation. Requires the use of "Best Available
Control Technology" (BACT) on all new sources.
Regulates the water quality certification of dredging and
disposal of dredged material.
Establishes guidance on the control of air emissions from
air strippers used at Super fund sites for groundwater
treatment.
the incinerator Mill be constructed and operated to attain a
99.9999X destruction and removal efficiency.
Proper design considerations will be Implemented to Insure
that all storage of TSCA-regulated waste satisfies the
requirements of the regulations.
The Incinerator Mill be constructed and operated to attain a
99.99991 destruction and removal effeelency of organlc.s and
PCBs In all wastes to be treated.
Wetlands disturbed by excavation will be returned to their
natural state following treatment of soils. The Incinerator
will be sited outside of the wetlands.
Wetlands disturbed by excavation will be returned to their
natural state following treatment of soils.
Fugitive dust Mill be controlled by water sprays or
suppressants. All equipment Mill be maintained so as not to
produce excessive noise.
Design of the B.E.S.T. solvent extraction technology
considers the proper handling and use of TEA:
BACT will be used on all new sources.
Dredging of sediments will be Implemented according to
regulations, Including constant monitoring of downstream
waters during Implementation to control migration of
contaminated sediments.
VOCs Mill be controlled In air stripper emissions with Best
Available Control Technology under Massachusetts'
requirements.
127
NOR 0'. H
-------
TABLE 19
FEDERAL AND STATE STANDARDS AND CRITERIA FOR
SUMMARY OF CHEMICALS OF POTENTIAL CONCERN IN GROUND WATER
NORWOOD PCB SITE
(All concentrations in ug/liter)
MAXIMUM MASSACHUSETTS MASSACHUSETTS
CONTAMINANT GROUNDWATER DRINKING WATER
LEVELS STANDARDS STANDARDS
(relevant and (applicable) (relevant and
CHEMICAL appropriate! appronriate)
Chlorinated Aliphatics
Vinyl Choridc 222
1,1-Dichloroethene 7 7 7
1,1-Dichlorethane
trans-1,2 Dichlorethene
1,1,1-Trichloroethane 200 200 200
Trichloroethene 55 5
Tetrachloroethene 5
Chloroform
Monocvclic Aromatics
Benzene 555
Toluene 2,000
Chorobenzene
1,2-Dichlorobenzene 20 600
Ethylbenzene 700
Xylenes 1,000
1,4-Dichlorobenzene 75 5
Other Vclatiles
Acetone 700
Semi-Volatiles
Diethyl Phthalate
Bis(2-ethylhexyl)
phthalate 10 10
Naphthalene
Di-n-butylphthalade
Carcinogenic PAHs
PCBs
Inorganics
Copper 1,000
Nickel
Qualitative Assessment Only
Noncarcinogenic PAHs
Cobalt
128
-------
GROUNDUATER ClEAmJP°CRITERIA
NORWOOD PCS SITE AND SURROUMDINO AREA
NORWOOD PC8 SITE fEASIBILIIT StUOT
HaxlMLM Naatachutetu llfetliw NaKltua
Health-Bated Contaminant Groundnater Health Contaminant Contract Required
Target Rlak level Clear**) Criterion level Crlterlaa Advliorlea level Coals Ouantltatlon Unite
Chemical/Scenario (10-4 to 10-7) (ug/l) (ug/l) (ug/l) (ug/t) (ug/l) (ufl/O
Ingest ion of Croundwater by
Average Case:
PCBs
1 , 4-DicMorobcmono
1,1.2,2- tetra<;hl or oe thane
Ictrnchlorocthcne
1, 1.2-trichloroethane
Irichlorocthcne
future »etldent«;
"2
10"7
10^
IS-7
10'5
10"7
10'5
IS-7
10"5
10'7
"1
10i
10-5
107
HI * 1
HI = 0.2
0.45 -- 0(P)a . 0(P) 0.5 1.0
0.045
0.0045
0.00045
UO 75 5 75 75 10
14
1.4
0.14
18 - - - 5
1.8
0.18
0.018 . '
60 5(P) 5 10 3(T) 5
6.6
0.68
0.068
62 - 5
6.2
0.62
0.062
320 5 0(P)a . 0 5
32
3.2
0.32
260
52
129
-------
table 20
age TMO
Chemical/Scenario
vinyl Chloride
1 , Z , 4 I r 1 chl orobentene
Target Risk level
(10-4 to 10-7)
"1
WS
10-!
10'7
Nl 1
HI » 0.2
Nealth-Baaed
Cleanup Criterion
(Ui/l)
1.5
0.15
0.015
0.0015
700
UO
NMlMI
Contaalnant
level
(UO/D
2
*
NoMadNMttta
OroundMottr
Criteria*
Cuo/l)
2
*.
llfotlM NMlauB
I tit ContMlnont Contract Raqulr*
AaVfaorlo* Itvot Co*l« Ouantftatlon ll«|-
(og/O Cut/I) (ui/l)
0 s
9(1) 10
n Shall not exceed health edvttorlei which have been adopted by the Massachusetts Division of Water Pollution Control and/or the CM.
(P) Proposed
(I) Tentative
(HI) Hazard Index
130
-------
TABLE 21
Summary of Total Cost of Remedy
BREAKDOWN OF SELECTED REMEDY COST
Source Control (Soils, Sediments) Component
Estimated Time for Design, Construction and Operational Startup:
2 years
Estimated Total Capital Costs: $10,749,000
Estimated Operation and Maintenance Cost: $2,511,000
Estimated Total Present Worth: $13,260,000
Source Control (Drainage System and Building) component
Estimated Time for Design, Construction and Operational Startup:
8 months
Estimated Total Present Worth: Approximately $300,000
Management of Migration (Groundwater) Component
Estimated Time for Design, Construction and Operational Startup:
1.5 years
Estimated Total Capital Costs: $1,018,000
Estimated Operation and Maintenance Cost: $1,483,000
Estimated Total Present Worth: $2,501,000
The estimated total present worth cost of the selected
remedy including all SC and MM components is $16,100,000.
131
-------
APPENDIX A
RESPONSIVENESS SUMMARY
NORWOOD PCS SUPERFUND SITE
-------
FINAL RESPONSIVENESS SUMMARY
NORWOOD PCB SUPERFUND SITE
NORWOOD, MASSACHUSETTS
SEPTEMBER 1989
U.S. ENVIRONMENTAL PROTECTION AGENCY
REGION I
-------
NORWOOD PCB SUPERFUND SITE
RESPONSIVENESS SUMMARY
TABLE OF CONTENTS
PREFACE 1
I. OVERVIEW OF THE PREFERRED ALTERNATIVE AND OTHER REMEDIAL
ALTERNATIVES CONSIDERED IN THE FEASIBILITY STUDY
. . . .2
II. BACKGROUND ON COMMUNITY INVOLVEMENT AND CONCERNS 4
III. SUMMARY OF COMMENTS RECEIVED DURING THE PUBLIC COMMENT
PERIOD AND EPA RESPONSES . 6
Part I - Citizen Comments 6
A. Comments on EPA'S Preferred Alternative 6
B. Comments on Meadow Brook 12
C. Comments on Groundwater Contamination 15
D. Comments on Public Health 16
E. General Comments 18
Part II - Potentially Responsible Party Comments 23
EXHIBIT A - COMMUNITY RELATIONS ACTIVITIES CONDUCTED AT THE
NORWOOD PCB SUPERFUND SITE
EXHIBIT B - TRANSCRIPT OF THE AUGUST 24, 1989 INFORMAL PUBLIC
HEARING
-------
PREFACE
The U.S. Environmental Protection Agency (EPA) held a 30-day
public comment period from August 11, 1989 to September 9, 1989
to provide an opportunity for interested parties to comment on
the Feasibility Study (FS) and the August 1989 Proposed Plan
prepared for the Norwood PCB Superfund site in Norwood,
Massachusetts. The FS examines and evaluates various options,
called remedial alternatives, for addressing contamination of
groundwater, surface water, soil and sediment at the site. EPA
identified its preferred alternative for the cleanup of the site
in the Proposed Plan issued on August 10, 1989, before the start
of the public comment period.
The purpose of this Responsiveness Summary is to identify major
comments raised during the public comment period and to provide
EPA response to the comments. EPA has considered all of the
comments summarized in this document before selecting a final
remedial alternative for the contamination at the Norwood PCB
site in Norwood, Massachusetts.
This Responsiveness Summary is divided into the following
sections:
I. Overview of the Preferred Alternative and Other Remedial
Alternatives Considered in the Feasibility Study - This
section briefly outlines the remedial alternatives,
including EPA's preferred alternative, that are described
and evaluated in detail in the FS and the Proposed Plan.
II. Background on Community Involvement and Concerns - This
section provides a brief history of the site and of
community interests and concerns regarding the Norwood PCB
site.
III. Summary of Comments Received During the Public Comment
Period and EPA Responses - This section summarizes and
provides EPA responses to the oral and written comments
received from the public during the public comment period.
In Part I, the comments received from citizens are organized
by subject. Part II lists the comments received from the
PRPs and EPA's responses. A brief summary of PRP comments
precedes EPA's detailed response.
Exhibit A - This exhibit is a list of the community relations
activities that EPA has conducted to-date at the Norwood PCB
site.
Exhibit B - This exhibit contains a copy of the transcript from
the informal public hearing held on August 24, 1989.
-------
Z. OVERVIEW OT THE PREFERRED ALTERNATIVE AMD OTHER REMEDIAL
ALTERNATIVES CONSIDERED IN THE FEASIBILITY STUDY
EPA** Preferred Alternative for the Norwood PCB Site
EPA has developed a comprehensive three-part cleanup plan to
address contamination at the Norwood PCB site. The preferred
alternative is a combination of two source control (SC)
alternatives: SOI and SC-A. Both SC alternatives are designed
to address sources of contamination at the site. The first SC
alternative addresses soil and sediment contamination, and the
second SC alternative addresses contamination within the Grant
Gear drainage system. In addition, the preferred alternative
includes a management of migration (MM) alternative designed to
address the migration of groundwater contamination at the site.
EPA's preferred alternative involves the excavation and treatment
by on-site solvent extraction of soils contaminated with PCBs and
other organic chemical-contaminated soils, dredge pile materials,
and sediments to meet required target cleanup levels. The second
SC alternative includes flushing, containing and replacing
portions of the Grant Gear drainage system. In addition, the
overall site remedial alternative involves collection and
treatment of contaminated groundwater by air stripping, carbon
adsorption and precipitation/filtration.
Other Alternatives Evaluated in the Feasibility Study
The FS prepared for EPA by Ebasco Services, Inc. for the Norwood
PCB site identifies and evaluates five SC alternatives to address
soil and sediment contamination and four MM alternatives to
address groundwater contamination to achieve EPA's cleanup
objectives for the site. In addition, EPA evaluated four SC
alternatives for remediation of the Grant Gear drainage system in
the 1989 Grant Gear Building FS prepared by Camp, Dresser and
McKee (COM) for EPA. The Proposed Plan, which identifies the
alternatives EPA recommended for the site, also contains brief
descriptions of each of the alternatives considered in detail in
the Norwood PCB site FS and the Grant Gear Building FS. These SC
and MM alternatives, including the preferred alternatives
identified in the Proposed Plan, are listed below. A detailed
description of remedial alternatives can be found in the Norwood
PCB site FS, the Grant Gear Building FS, and EPA's Record of
Decision. These documents are available as part of the
Administrative Record for the site at the Morrill Memorial
Library on Walpole Street in Norwood, Massachusetts and the EPA
Records Center at 90 Canal Street, Boston, Massachusetts.
-------
1. SOURCE CONTROL ALTERNATIVES (Soils, Sediments) :
The purpose of implementing SC-1 alternatives at the Norwood PCB
site is to address contaminated soils and sediments. The FS for
the Norwood PCB site evaluated the five SC-1 alternatives listed
below.
fl. Limited No Action
§2. Capping of Soils and Sediments
#3. On-Site Solvent Extraction (EPA's Preferred SC-1
Alternative)
14. On-Site Dechlorination
15. On-Site Incineration
2. SOURCE CONTROL ALTERNATIVES (Grant Gear Drainage System):
The Grant Gear Building FS evaluated three SC-A alternatives to
address contamination within the Grant Gear drainage system which
is also considered to be a source of groundwater contamination.
These alternatives are listed below.
fl. No Action
12. Flushing/Cleaning of Drainage System (EPA's Preferred
SC-A Alternative)
|3. Containment of Drainage System
#4. Removal of Drainage System
3. MANAGEMENT OF MIGRATION ALTERNATIVES
The FS also evaluated four MM alternatives to manage the
migration of contaminants by collecting and treating contaminated
groundwater to prevent the spread of contamination. These
alternatives are listed below.
#1. Limited .No Action
#2. Air Stripping (EPA's Preferred MM Alternative)
#3. Carbon Adsorption
#4. Ultraviolet/Oxidation
-------
ZZ. BACKGROUND ON COMMUNITY INVOLVEMENT AND CONCERN*
The Norwood PCB site is located on 26 acres of mostly commercial
and industrial properties in Norwood, Massachusetts. The site
consists of several parcels of land, including the Grant Gear
facility where gears are produced for industry; Kerry Place, an
office park; an automobile dealership; a restaurant; and
associated parking areas and adjacent fields.
Beginning in the 1940's, previous owners and operators of the
Grant Gear building used polychlorinated biphenyls (PCBs) in the
production of electrical transformers and other electrical
components. In 1983, the Massachusetts Department of
Environmental Protection (DEP), formerly the Massachusetts
Department of Environmental Quality Engineering, in response to a
complaint from an area resident, investigated the site and found
high levels of PCBs in soils and on interior surfaces of the
Grant Gear building. Community residents were very concerned
about health risks associated with exposure to site soils and
contaminated equipment within the Grant Gear facility, and media
coverage of site contamination during this time period was
extensive.
In the summer of 1983, at the request of DEP, EPA conducted an
emergency removal of over 500 tons of highly contaminated soil
from the present Kerry Place and Grant Gear properties. In 1983,
the Massachusetts Department of Public Health, responding to
Norwood residents' health concerns, conducted a blood testing
program of those residents who had experienced the most direct
contact with the site. The test results showed PCB-blood levels
were not elevated. Community concern about the site diminished
following the emergency soil removal and publication of blood
test results.
In October 1986, the Norwood PCB site was added to EPA's National
Priorities List making it eligible to receive federal funds for
investigation and cleanup under the Superfund program. In 1986,
DEP implemented an Interim Remedial Measure (IRM) at the site to
limit access to the areas of highest surface sell contamination.
The IRM included the installation of a 4-foot high wire mesh
fence around a 1.5-acre portion of the northwest and southwest
corners of the Grant Gear property and covering contaminated
soils within the fenced areas. The cover consists of a filter-
fabric liner and six inches of crushed stone.
In July 1987, the Norwood General Manager initiated quarterly
meetings with EPA to discuss local complaints about site cleanup
delays and to keep informed about site activities. In 1987, EPA
began a Remedial Investigation (RI) and Feasibility Study (FS) at
the site which included sampling and analysis of soil,
groundwater, surface water, stream sediments and four dredge
piles located along the south bank of Meadow Brook. After the RI
-------
was initiated, community interest regarding the Norwood site
increased considerably. At a January 1988 meeting with Norwood
town officials, EPA announced that preliminary sampling results
detected high levels of PCBs in and along Meadow Brook.
Community concern focused on potential adverse health effects
from exposure to the Brook area. The Town of Norwood
subsequently constructed a fence restricting access to the Brook.
In addition, because of contamination in Meadow Brook sediments,
implementation of a 1988 flood control project that would have
required dredging of the Brook, was delayed. Brook flooding
during heavy rains caused storm sewer overflows in residences
abutting the Brook. Neighbors became concerned that the flood
waters were also spreading contaminants into their yards and
basements. Elevated community concern about Meadow Brook
flooding prompted several meetings of federal and state
legislators and EPA representatives between 1987 and 1989 to
discuss expediting cleanup of the Meadow Brook portion of the
Norwood PCB site.
Public interest has continued at a low to moderate level
throughout the RI/FS process. In June 1989, EPA completed the RI
and presented RI results at a public informational meeting.
Those at the meeting expressed frustration with site cleanup
delays and the postponement of the Meadow Brook flood control
project. EPA held a public informational meeting and a public
hearing in August 1989 to present the Proposed Plan and FS. The
Proposed Plan meeting received extensive media coverage. The
principal community concerns expressed at the hearing are
summarized below.
Solvent Extraction. Residents expressed concern about the
reliability and safety of the solvent extraction process. Some
residents expressed a preference for on-site incineration to
treat contaminated soils and sediments.
Meadow Brook Flood Control. Residents and officials requested a
meeting with EPA to discuss remedial design plans for Meadow
Brook sediment excavation. They asked EPA to make Meadow Brook
cleanup a priority and expressed concern about the potential
spreading of contaminants during floods.
Groundwater Quality. Residents expressed frustration with
groundwater target cleanup goals. Residents requested additional
information about potential health problems resulting from
exposure to contaminated groundwater.
-------
ZZZ. SUMMARY OF COMMENTS RECEIVED DURING THE PUBLIC COMMENT
PERIOD AND EPA RESPONSES
This Responsiveness Summary addresses the comments received by
EPA concerning the FS and Proposed Plan for the Norwood PCB
Superfund site in Norwood, Massachusetts. Five sets of written
comments were received during the public comment period (August
11, 1989 - September 9, 1989). Eight commenters orally presented
their concerns at the August 24, 1989 informal public hearing. A
copy of the transcript is included as Attachment B. Copies are
also available at the Morrill Memorial Library on Halpole Street
in Norwood, Massachusetts, the information repository that EPA
has established for the site; and at the EPA Records Center at 90
Canal Street, Boston, Massachusetts as a part EPA 'a
Administrative ' Record.
The comments from citizens, along with EPA responses, are
summarized and organized into the following categories:
A. Comments Regarding EPA's Preferred Alternative
B. Comments Regarding Meadow Brook
C. Comments Regarding Groundwater Contamination
D. Comments Regarding Public Health
E. General Comments
Part I - Citizen Comments
A. Comments Regarding EPA's Preferred Alternative
1. One commenter wanted an explanation of the operation and
maintenance costs included as part of the groundwater and
soil treatment alternative, and asked if there is going to
be some ongoing operation and maintenance at the site for a
period of time after cleanup.
EPA Response: The cost estimates prepared for the Norwood
Site included both capital costs, and annual operation and
maintenance costs. The capital costs are the expected costs
that would be incurred within the first year of operation.
Annual operation and maintenance costs are costs that extend
beyond the first year of operation. All costs incurred
after the first year of operation were converted into
current dollars through a present worth analysis.
Operation costs associated with the solvent extraction
alternative include the cost of utilities (i.e., water for
the decontamination pad activities) , the solvent extraction
process and mobile lab use, (these will be utilized longer
than one year, thus they have an operations cost associated
with them) and the wetlands restoration project (which will
require periodic visits to monitor growth and may extend for
6
-------
as long as five years).
Maintenance costs associated with the solvent extraction
process include upkeep of the perimeter fence, keeping all
equipment in efficient working order, and general
maintenance associated with any construction site.
Operation costs associated with the air stripping
alternative include utilities (electricity to run pumps),
carbon replacement costs, treatment plant operation
(operators, chemical costs, sludge handling), and long-term
monitoring and site review. The long-term review is
necessary as the alternative is anticipated to be in
operation for approximately 10 years.
Maintenance costs associated with the selected management of
migration alternative include general equipment overhaul,
pump replacement, fencing repairs, and other typically
required water treatment plant maintenance.
2. One commenter wanted to know the length of time of the
cleanup, and asked what the difference in cleanup time is
between incineration and solvent extraction.
EPA Response: The estimated time of cleanup of the site
solids is 4 years; 2 years for design, bid preparation,
contract negotiation, bench scale studies, and other pre-
implementation activities, and approximately 2 years of
field operations. The estimated time of cleanup of the
volatile organic chemicals present in the site groundwater
is 10 years.
The estimated cleanup times for solvent extraction and
on-site incineration are very similar. Both processes have
units that operate at approximately 100 tons/day, thus, the
actual time spent on-site would be very similar. Both
processes are complex and will require extensive design and
careful scheduling to ensure an efficient operation at the
site. The solvent extraction system would require bench-
scale pilot testing. The on-site incinerator would be
required to perform a test burn. Time of cleanup of the
site soils by the solvent extraction process may be slowed
by materials handling problems. Time of cleanup by the
on-site incinerator may be slowed by material handling
problems and excessive solids water content. Thus, it is
estimated that the time required for either alternative is
approximately the same.
3. Several commenters expressed their preference for
incineration of contaminated soils and sediments over
solvent extraction treatment. The commenters stated that
they are opposed to the use of solvent extraction because
-------
they do not want any additional chemicals brought to the
site. On* commenter stated that he thought solvent
extraction was selected by EPA because it is less costly
than incineration, although incineration is a proven
technology.
EPA Response; The solvent extraction system proposed for
removal of PCBs from the soils is a closed system. The
chemical extractant is added to a volume of soil within a
closed reactor vessel, allowed to react and the washed soil
is removed from the vessel to use as fill. The liquid
solvent/PCB/water mixture is then heated, separating the
solvent/PCB-contaminated soils from the PCB-free water and
collected for disposal. The solvent is separated in a
stripping column and recycled for use in the system. Soils
are checked as they are removed from the vessel to ensure
that the soils meet the target cleanup goal. Low level
residual chemicals on the soils quickly volatilize as the
soils are removed from the vessel. All pipe connections and
storage tanks are protected against spills with spill
prevention catch basins. Although many of the soil wash
technologies have not been tested on superfund soils, these
technologies have been commercially applied to the
extraction of organic contaminants from various sources.
Additionally, the implementability and effectiveness of the
technology will be assessed with treatability studies,
during the final design prior to full scale adaptation to .
the site soils.
The rationale for choosing the selected alternative is based
on an assessment of each criteria listed in the evaluation
of alternatives section of this document. In accordance
with Section 121 of CERCLA, to be considered as a candidate
for selection in the ROD, the alternative must have been
found to be protective of human health and the environment
and able to attain ARARs unless a waiver is invoked. In
assessing the alternatives that meet these statutory
requirements, EPA focused on the other evaluation criteria,
including, short-term effectiveness, long-term
effectiveness, implementability, use of treatment to
permanently reduce the mobility, toxicity and volume of
hazardous substances, and cost. EPA also considered
nontechnical factors that affect the implementability of a
remedy, such as state and community acceptance. Based upon
this assessment, taking into account the statutory
preferences of CERCLA, EPA selected the remedial approach
for the Site.
As described in the FS and Section XI of the ROD, based on
the performance potential of solvent extraction, this
innovative technology provides the best balance of tradeoffs
from among the options considered, despite its
-------
uncertainties. Specifically, both solvent extraction
(selected technology) and on-site incineration (selected as
the backup technology) and on-site incineration (selected as
the backup technology) meet the statutory preference for
utilizing treatment technologies that significantly and
permanently reduce the toxicity, volume or mobility of all
hazardous substances. Although solvent extraction is an
innovative treatment, the results of treatability studies
performed on various soils and sediments at other Superfund
sites indicates that this technology will be effective in
meeting cleanup levels for soils, sediments and dredge pile
materials. This determination will be confirmed by
, site-specific treatability studies on solvent extraction.
If results of these studies indicate that solvent extraction
would not be implementable or effective or is determined to
be significantly more costly than incineration, then EPA
will select on-site incineration as the treatment technology
for the remediation of soils, sediments and dredge pile
materials. Incineration is a proven technology for meeting
the soil cleanup levels. Solvent extraction has been
selected over on-site incineration because it is an
alternate treatment, as preferred by CERCLA, and is equally
effective as incineration in attaining the protective
cleanup levels of this remedy but at a lower estimated
present worth cost ($13.3 million for solvent extraction;
$17.2 million for incineration). Both solvent extraction
and on-site incineration will comply with ARARs. Finally,
comments received during the public comment period indicate
that while a limited number of the public prefers on-site
incineration, the state prefers solvent extraction.
Several commenters asked why EPA is not removing all
contamination from the site including contaminated pavement,
the drainage pipe within the Grant Gear buildings, oil
beneath the Grant Gear building, and soil on the Hyundai and
Kerry Place properties. One commenter specifically
requested that the Grant Gear drainage system be removed.
Several commenters asked EPA to buy out the Grant Gear
company and demolish the building, and stated that the
contamination on and in the building continues to pose a
risk to the workers at the Grant Gear.
EPA Response; EPA has determined that for this Site, only
contaminated unsaturated soils will be excavated and
treated. This determination is made primarily on the basis
of three criteria: implementability, effectiveness and cost.
Specifically, excavation of saturated soils would require
dewatering in areas to be excavated. As discussed in
Chapter 7 of the FS in the discussion of the active
groundwater extraction system, the design of any active
dewatering operation would require special measures to
prevent the drawing of Meadow Brook surface waters into the
-------
attraction system. A slurry wall, commonly used in such
cases, would present long-term impacts by restricting
groundwater flow in and around its location for periods
after implementation of the dewatering operation. Areas to
be excavated in the saturated zone would include areas
immediately adjacent to the Grant Gear building.
Disadvantages associated with extensive excavation of soils
in and around the building include possible structural
damage to the building and the exterior drainage system.
Because results of the RI indicated that the weathered
bedrock may also be contaminated the effectiveness of this
excavation will be limited to the ability to locate and
remove all contaminated weathered bedrock as well as all
saturated soils.
It is also of significance that any residual PCB levels in
bedrock or saturated soils not removed during implementation
of this remedial action may contribute to PCB levels in
groundwater above any human health-based risk level.
Finally, additional costs relating to health and safety
measures (groundwater within saturated soils is
contaminated), dewatering operation (e.g. extraction system)
before and after excavation and treatment of collected waste
residuals.
As stated above, removal and treatment of all saturated
soils, even if possible, will not ensure levels in
groundwater protective of human health. Additionally, major
disadvantages are associated with the implementability of
this alternative. EPA believes that the costs required to
implement this alternative is not proportionate to its
overall effectiveness. Therefore, based on the description
above, EPA has determined that it is impracticable to
remediate contaminated saturated soils at this Site.
However, all unsaturated soils with contaminant levels
greater than soil target cleanup levels, as described in
X.A.I.a., will be performed.
PCB levels in soils under paved area outside Grant Gear are
less then 25 ppm, the soil cleanup level for soil in
restricted access areas, as specified in the TSCA PCB Spill
Policy Cleanup. Soils that are not accessible to the public
do not pose a risk because exposure to contaminants is
prevented by in this case pavement. EPA therfore believes
that based on levels of PCBs in soils under pavement outside
Grant Gear, remediation of such soils is not warranted.
Removal (SOD) and off-site disposal of the drainage system
is the least preferable alternative as defined by CERCLA.
While removal from the Site would permanently reduce on-site
contaminant levels, this alternative would simply move those
contaminants to another site without treatment, and would
10
-------
not permanently reduce the mobility, toxicity or volume of'
the wastes. Further, removal is the most costly alternative
while achieving no permanent T,M,V reduction. This
alternative would also result in significant disruption to
Grant Gear's operations and damage to building structures
and its short-term effectiveness and risks would depend upon
the ability to contain any releases of hazardous substances
during the removal operations.
Demolition of the Grant Gear building would be no more
effective then Removal or Containment but at much greater
cost and disruption to Grant Gear operations. While this
alternative could be effective, it would present significant
technical difficulties in demolishing and disposal of
building structures. Accordingly, this alternative was
screened out of further consideration based on concerns with
short-term risks, implementability, and a significant
increase in cost with uncertain effectiveness over other
alternatives.
Remediation of the Grant Gear building can obtain an
acceptable limit of residual risk by washing/remediating
contact surfaces within the building without the added
destruction and exposure created by excavation of soils
beneath the pavement and Grant Gear building.
5. One commenter asked if EPA would be excavating soils
containing PCB concentrations greater than one part per
million (ppro) in residential areas abutting the site.
EPA Response; As is discussed in Section 6.2 and shown on
Figure 6-1 of the FS, the specified PCB cleanup level along
Meadow Brook is 1 ppm, both south of the brook between the
Grant Gear fence and the stream, and north of the brook in
the adjacent residential areas. ' Thus, all material in these
areas, including residential properties, with PCB
concentrations exceeding 1 ppm will be excavated and
removed.
One commenter asked if PCBs pass through concrete and
questioned the effectiveness of using concrete to seal the
Grant Gear drainage system.
EPA Response; PCBs will pass through concrete when
dissolved in an organic oil or solvent carrier liquid if
pressure is exerted on the liquid to force the PCB-solvent
mixture through the pores in the concrete. Water samples
obtained during the RI indicate that PCBs are attached to
sediment within the Grant Gear drainage system and would not
be in a form anticipated to pass through the concrete pipes.
PCB-containing sediment is moved through the drainage system
11
-------
by the flow of water contained in the discharge. As part of
the drainage system cleanup, sediment in the drainage system
will be removed prior to sealing with concrete. The purpose
of sealing the drainage system with concrete is to
physically retain any residual sediment not removed prior to
sealing within the drainage system pipes.
7. One commenter asked if the site cleanup includes the
removal, treatment and disposal of the dredge piles located
on the banks of Meadow Brook.
EPA Reaponae; As is discussed in Section 6.2 and shown on
Figure 6-1 of the FS, the dredge piles are included in the
soil component of the selected remedy. As is specifically
stated in Section 6.2.1 of the FS, paragraph 1, "In
determining the location and volume of the soils to be
excavated, the dredge piles were treated as soils and
likewise grouped with the soil volumes." The material from
the dredge piles that contain PCB concentrations greater
than 10 ppm and PAH concentrations greater then 6 ppm would
be treated by solvent extraction and disposed of on-site.
Those dredge pile materials with PCB concentrations between
1 ppm and 10 ppm and PAH concentrations between 2ppm and 6
ppm would be excavated and disposed of on-site within the
Grant Gear property boundary.
B. Comments Regarding Meadow Brook
8. The Norwood General Manager, and several conunenters, asked
if the Town could get some agreement that the work they are
going to do is not going to have to be redone by the Town or
some other entity at a future tine, and requested a
cooperative effort between EPA and the Town of Norwood so
that EPA's cleanup goals for Meadow Brook and the Town's
flood control needs can both be met. The General Manager
specifically asked EPA for a commitment to work together to
achieve a mutually beneficial goal, which is not only the
cleanup of the PCbs, but also the dredging and the
increasing of the capacity of Meadow Brook. He asked that
EPA adhere to the proposed cross-section specifications in
the flood control project while conducting the cleanup, even
if EPA excavates a greater volume of sediment than the
volume proposed for the flood control project.
EPA Response; EPA will work with the Town of Norwood in
achieving the mutually beneficial goals of cleanup and flood
control in implementing the work to be performed on Meadow
Brook. The acknowledgement of these goals is reflected in
the alternative evaluations presented in the Feasibility
Study through the identification of interactions between the
flood control project requirements and the requirements of
cleanup alternatives involving excavation. The conceptual
12
-------
cleanup plans evaluated in the FS that included excavation
considered the estimated amount of clean fill required to
bring Meadow Brook to*the grade and cross-section required
by the flood control project.
The wetlands restoration component of the selected remedy
describes measures to be taken during remedial action of the
Meadow Brook area which will incorporate plans for the flood
control project. Therefore, upon completion of the soil and
sediment excavation of the Meadow Brook from approximately
the Grant Gear outfall to the Neponsent River, the brook
streambed and adjacent banks from these areas will be
restored, to the maximum extent feasible, in a manner
consistent with the Meadow Brook flood control project plans
and specifications. Upon completion of the flood control
project, and bordering wetland areas impacted by dredging,
excavation and/or associated activities performed in
accordance with component (c) of the selected remedy, will
be restored or enhanced, to the maximum extent feasible, to
similar hydrological and botanical conditions existing prior
to these activities. The restoration program will be
developed during design of the selected remedy. This
program will identify the factors which are key to a
successful restoration of the altered wetlands. Factors may
include, but not necessarily be limited to, replacing and
regrading hydric soils, provisions for hydraulic control and
provisions .for vegetative reestablishment, including
transplanting, seeding or some combination thereof. As
described above, the restoration program will incorporate
plans and specifications of the Meadow Brook flood control
project for the Meadow Brook streambed and adjacent banks.
A more detailed examination of the interaction between
cleanup and flood control will be performed in coordination
with the Town of Norwood during the design of the remedial
action.
9. Several commenters were concerned about the length of time
it will take to clean up the Meadow Brook area, and felt
that EPA inaction over the years has prevented the Town from
carrying out the Meadow Brook flood control project. The
commenters were particularly concerned about the possibility
of PCBs flooding in the streets during a rainstorm when the
water backs up from the brook and the danger of kids playing
in the streets during this time. The commenters urged EPA
to make Meadow Brook cleanup activities a priority so that
the Town can begin the Meadow Brook dredging project.
EPA Response: EPA concurs with the concern relative to the
flood control project. This concern is intended to be
addressed, to the degree possible, by prioritizing the
streambed and dredge pile remediation component of the site
remediation during the remedial design. Upon completion of
13
-------
the noil and sediment excavation of the Meadow Brook area, '
the brook streanbed and adjacent banks will be restored, to
the maximum extent feasible, in a manner consistent with the
Meadow Brook flood control project plans and specifications.
10. One commenter was concerned about a flood plain disruption
during site cleanup and asked EPA to take precautionary
measures or come up with a plan to prevent flooding of
residences during site cleanup.
EPA Raaponaat During the development of alternatives,
potential flooding of the local areas during construction
was given consideration. A conceptual design was developed
whereby the Meadow Brook waters would be routed into a pipe
laid parallel to the brook to bypass the site. During the
design stage, this conceptual design will be fully developed
to ensure that the bypass piping is adequately sized to
handle the anticipated flows from typical local storm
events. Careful design and scheduling of sediment and soil
removal will be utilized to protect the local area to the
greatest extent possible.
11. One commenter stated that the Savagran Company, along with
the Northrup Company and a neighboring foundry, use the same
chemicals that are found in Meadow Brook and are
consequently polluting the brook. The commenter asked if
anything can be done to prevent further polluting of the
brook after it is cleaned up.
EPA Response: To evaluate the potential for other
contributors of contamination to Meadow Brook from upstream
sources EPA collected samples from the brook upgradient of
the Grant Gear facility in the vicinity of Kerry Place.
These data were compared to the results of samples taken
from downstream of the Grant Gear facility and to samples
collected from the Grant Gear outfall to calculate the
relative contribution from the site.
Only the Norwood PCB Site is on the National Priorities list
and therefore qualifies for federal funding. Any
investigations and remedial actions taken under Superfund
must therefore be related to site contamination. EPA has
relayed citizens' concern about these potential
contributions to the State.
12. One commenter asked if EPA would be testing drinking water
in the site area to determine if flooding is causing
drinking water contamination.
EPA Response: As indicated in Table 6 of the ROD, VOCs were
detected infrequently at low levels. Even though some of
these compounds were detected in the effluent from the Grant
14
-------
Gear outfall at higher concentrations, dilution and
volatilization quickly reduce the effect of discharge so
that downstream and upstream water contaminant levels are
approximately the same.
Drinking water in the vicinity of the site is supplied by
the MWRA. The source of this water is routinely analyzed
prior to distribution. Existing groundwater monitoring
wells upgradient of the site along Pellana Road and north of
Meadow Brook have not been found to be contaminated.
Results of the Phase II sampling of monitoring wells
performed during the RI, confirmed that contaminated
groundwater is confined to the Grant Gear property.
Therefore, exposure to contaminated on-site groundwater
would only occur within the Grant Gear property. In
addition, water supplied by the MWRA is distributed in pipes
under pressure and the potential for outside contaminants to
leach into any distribution system is negligible.
Components (e) and (f) of the selected remedy addresses
groundwater contamination within the Grant Gear boundaries.
Remediation of the groundwater will result in attainment of
groundwater and drinking water standards and with
implementation of institutional controls, such as deed
restrictions, will be protective of human health and the
environment.
C. Comments Regarding Groundwater Contamination
13. One commenter asked if the high water table at the site
would increase the likelihood of contaminants spreading into
the abutting residential areas when flushing out the PCBs.
EPA Response: The high water table at the site is not
anticipated to increase the likelihood of spreading
contaminants into the abutting residential areas when
flushing out the PCBs. The groundwater extraction system
proposed will collect contaminated groundwater flowing from
the site towards Meadow Brook and remove the water for
treatment. Following treatment to remove contaminants, the
treated water will be reintroduced into a groundwater
recharge system located on-site to aid in the movement of
contaminated water toward the extraction and treatment
system. The extraction and recharge systems will be
designed to use this recirculating effect to reduce the
likelihood of spreading contaminants into the abutting
residential areas through the groundwater system.
14. One commenter asked EPA to provide the results of sampling
conducted at test wells located at the corner of Hillside
and Pellana.
15
-------
EPA Response? Monitoring well test number 5 is located at*
the corner of Hillside Drive and Pellana Road. Mo
detectable concentrations of organic contaminants were found
in either the deep or shallow well. Inorganic compounds in
the well are within expected levels for non-contaminated
wells. These wells are used as the upgradient wells to
measure against in an effort to identify site related
contaminants in downgradient wells. Monitoring well number
6, in the Kerry Place office complex, was also found to be
clean.
15. One commenter was concerned that there may be contamination
in the groundwater off of Grant Gear and asked if EPA has
sampled resident's wells in the area that might have
groundwater wells. The commenter also asked if EPA had
identified the source of groundwater contamination and if it
is industrial in nature.
EPA Response! All monitoring wells sampled beyond the Grant
Gear property boundaries were found to be clean. No
contamination was found in wells upgradient of the site and
therefore, there would be no reason to believe that an
upgradient source of groundwater contamination exists which
is contributing to the problems at the site. The source of
on-site groundwater contamination is assumed to be
contaminated soils in former areas of disposal to the west
of the Grant Gear Building. Some of the chemicals detected
in site media are constituents of solvents used in various
manufacturing operations.
16. One commenter asked whether groundwater wells will ever be
allowed to be drilled in areas abutting the site.
EPA Response: Groundwater contamination has been detected
only in onsite wells downgradient of the source areas.
Future risks from groundwater consumption references only
that case where a drinking water well was installed onsite
in areas of contamination. There is no current data which
would prohibit the consumption of offsite water from a
drinking water well. Further, groundwater collection and
treatment from the site will reduce current groundwater
contaminant levels and the possibility of off-site
migration. Institutional controls on groundwater
consumption will be adopted only in the zone of
contamination and are proposed to prevent installation of
wells within the on-site zone of groundwater contamination.
Although no evidence indicates that groundwater in off-site
areas are contaminated from chemical migration from the
site, it will be important to determine the zone of
influence for any pumping well installed in close proximity
to Grant Gear. Under pumping conditions, an off-site well
16
-------
may impact the groundwater flow and hence the location of
the contaminated plume currently detected within the Grant
Gear boundaries.
17. One commenter asked EPA to thoroughly clean up contaminated
groundwater and surface water at the site.
EPA Response; EPA believes that it is technically
infeasible to remove all particulate-bound PCBs from the
soils at the site. However, removal of the non-saturated
portion of the contaminants will significantly reduce the
source of groundwater contamination and when combined with
groundwater extraction and institutional controls provides a
site remediation which will be protective of human health
and the environment. The remediation will also be combined
with an environmental monitoring program. Five-year reviews
of the remediation will be conducted to ensure that human
health and the environment are being protected by the action
being taken. Future remedial action will be considered if
the long-term environmental monitoring program determines
that unacceptable risks to human health and/or the
environment are posed by exposure to site contaminants.
D. Comments Regarding Public Health
18. One commenter requested information about the extent of soil
and water contamination at residences near the site. The
commenter asked whether it is safe for children to walk
'barefoot in backyards containing contaminated soils and
whether it is safe to eat vegetables grown in neighborhood
gardens near the site.
EPA Response; The locations of surface soil samples
obtained near residences are shown on Remedial Investigation
Figure 2-3. Of the approximately 16 samples obtained, seven
contained PCB values above the 1 ppm cleanup target
concentration in these areas. These seven samples are
identified as sample numbers SO-015, SO-075, SO-017, SO-019,
SO-020, SO-021, ans SO-013 on Figure 2-3 of the FS.
Residentail (adult and child) exposure to surface soils in
yards located north of Meadow Brook were evaluated in
Section 5.2.1.6 (page 5-25) of the Endangerment Assessment.
This evaluation considered both dermal contact and
incidental ingestion of hazardous chemicals as a result of
outdoor activities such as playing and gardening. The
plausible maximum exposure through direct contact and
incidental ingestion in these areas was estimated to result
in a 3xlO"6 lifetime excess cancer risk. EPA determined
that remediation of contaminated soils along Meadow Brook
would be performed to reduce the risks even further.
Residential yard areas having PCB concentrations above 1 ppm
17
-------
will undergo cleanup under the proposed plan.
The additional potential exposure pathway through ingestion
of vegetables grown in yards north of Meadow Brook was
qualitatively evaluated. This potential exposure pathway
was not quantitatively evulated due to uncertainties
involving quantifying chemical uptake, quatities grown, and
ingestion rates. If residents do consume vegetables grown
in their yards, potential exposure can be reduced through
simple precautions such as washing and peeling vegetables.
Additionally, cooking vegetables may also reduce
concentrations of some chemicals in vegatables.
Groundwatar contamination has been detected only in on-site
wells downgradient of the source areas. There is no current
data which suggests that contamination has migrated beyond
site boundaries.
19. One commenter asked if the results of the blood tests
performed on area residents in June 1989 had been received,
and, if so, what the results were.
EPA Response; Individual blood test results will be mailed
to those individuals by the Massachusetts Department of
Public Health in the near future. After notifying
individual residents, a report summarizing the results of
the blood testing program will be-made available to the
public by the Massachusetts Department of Public Health.
E. General Comments
20. One commenter stated that EPA activities at the site have
resulted in the spread of contaminants and stated that EPA
is therefore liable to the Town of Norwood for site
contamination.
EPA Response: All site activities performed by EPA to
collect environmental data were performed using the
contaminant reduction zone process. Each sampling tool was
decontaminated between samples using a standardized
decontamination program to prevent the cross-contamination
or spread of contamination from one location to another.
All drilling equipment was decontaminated on a
decontamination pad as it enters the site, between drill
locations and following completion of all field activities.
The excess fluids and wash water from the decontamination
process were collected and stored in 55-gallon drums for
offsite shipment and disposal. All personal protection
clothing and disposable sampling equipment was stored in-
drums for disposal. The contaminant reduction zone process
minimizes the potential for the spread of contamination as a
18
-------
result of site activities.
21. Several commenters expressed frustration with cleanup delays
and want the most expedient method of cleanup used.
EPA Response; EPA evaluates the times for operation for and
implementation of the alternatives when selecting the final
remedy. As described in EPA's response to comment A.I., a
comparison of the two treatments determined to be effective
for on-site soils indicates that the estimated cleanup times
for these treatments (solvent extraction, on-site solids by
solvent extraction the selected alternative is 4 years; 2
years for design, bid preparation, contract negotiation,
bench scale studies, and other pre-implementation
activities, and approximately 2 years of field operations.
One of the remedial response objectives for groundwater
component is to reduce risks to human health and the
environment from current and future migration of
contaminants in groundwater within a reasonable time frame.
The estimated time of cleanup of the VOCs present at the
site in groundwater is estimated at 10 years.
22. One commenter asked how EPA informs residents in the area
about the contamination, especially new residents buying
homes who know nothing about the site, and wondered why it
was not until 1989 that a map of the site area was finally
published in the newspaper.
EPA Response; The community relations activities began at
the Norwood PCB site in 1983, when the removal action took
place. The Region I EPA Office of Public Affairs maintains
a mailing list for the site to help keep the community,
local officials, and media informed of site activities.
This site mailing list is used when mailing out press
releases and fact sheets, and is continually updated. For
example, when a person moves from an address in Norwood, EPA
continues to mail, information to the address by changing it
to read "Current Resident". In this way EPA hopes to inform
new residents of site activities. A sign-in sheet is also
available at the entrance to every public meeting that EPA
holds, so that people can sign in and let EPA know if they
are currently on the mailing list; EPA then adds any names
that are not already on the mailing list. In addition, the
fact sheets that EPA mails out to the community have a
coupon on the back so that names and addresses can be added
at any time.
EPA also informs the community of site activities through
the information repositories that are set up at the Morrill
Memorial Library and the Norwood Town Hall, where fact
19
-------
sheets and site reports are housed for public review. These
information repositories are listed in the fact sheets that
EPA sends out to everyone on the nailing list to inform them
of where to go for site information.
Exhibit A to this Responsiveness Summary lists the community
relations activities that have been conducted at the Norwood
site over the years.
<
23. One commenter asked whether cars would still be allowed to
be parked on the area of contamination where the cap is
coming apart in spots?
EPA Responses Upon completion of the remediation process at
the site the surface soils will be remediated to meet the
EPA action level and no institutional controls will be
imposed on the use of the land surface. Presently, the MA
DEP is responsible for the maintenance of the capped areas
and will maintain them for their current use until the final
remediation is implemented.
24. One commenter asked why EPA has not been in communication
with the Norwood Conservation Commission and asked that the
EPA clarify whether cleanup activities will comply with the
Wetlands Protection Act.
EPA Response: EPA has determined that, for this site, there
are no practicable alternatives to the soil excavation,
sediment excavation and stream diversion components of the
selected remedy, that would achieve site goals but would
have less adverse impacts on the aquatic ecosystem. The
contaminants in the soils and sediments would continue to
pose unacceptable human health and/or environmental risks if
excavation of the soils and sediments greater than target
levels were not performed. In light of this, during
implementation of the remedy, steps will be taken to
minimize the destruction, loss and degradation of wetlands,
including the use of sedimentation basins or silt curtains
to prevent the downstream transport of contaminated
sediments. A wetlands restoration program will be
implemented upon completion of the remedial activities in
wetland areas adversely impacted by remedial action and
ancillary activities. Performance of this cleanup remedy
will meet or attain all applicable or relevant and
appropriate federal and state requirements that apply to the
site including Section 404 of the Clean Water Act,
Floodplain and Protection of Wetlands Executive Orders 11988
and 11990, respectively and DEP Wetlands Protection
Regulations.
As part of the extensive community relations plan, EPA has
20
-------
met with local officials, sent out fact sheets and held
public meetings-on numerous occasions within the last year.
A representative of the Norwood Conservation Commission has
attended most of these meetings and participated in
discussions concerning site activities. EPA will continue
to meet periodically with interested parties during the
remedial design to discuss new information and design plans.
In addition, an informational public meeting will be held
when the design is near completion..
25. Several commenters expressed confusion about conflicting
information they have received from EPA over the years. The
commenters stated that they have been told that the
emergency removal action in 1983 included the removal of all
PCBs at the site.
EPA Response; The history of the removal action is
described below:
On April 1, 1983, the Massachusetts Department of
Environmental Department of Environmental Protection (MA
DEP), received a telephone call from a citizen living on
Pellana Road reporting past industrial waste dumping and
contamination in the then vacant field of Kerry Place
between Pellana Road and the Grant Gear property. As a
result of this call, an initial field investigation by DEP
was conducted soon thereafter. On April 6, 1983, DEP
sampled surficial soils and Meadow Brook sediments. The
initial DEP investigations confirmed PCB contamination in
soils. The DEP immediately moved to restrict public access
to the field area and marked areas within the Grant Gear
fence to alert workers of the possible danger. Because
state funds were not available, the Commonwealth of
Massachusetts requested EPA to provide support using
Superfund money. EPA dispatched their Technical Assistance
Team (TAT) Contractor, Roy F. Weston, Inc., of Lexington,
Massachusetts, to aid DEP in collecting confirmatory samples
of the oil-stained areas along the western fence line and in
other areas on both the Grant Gear and Reardon properties.
Based on these findings, it was determined that an immediate
removal action to address all soils outside the Grant Gear
property with PCB concentrations greater than 50 parts per
million (ppro) was appropriate. The Agency planned to follow
the removal action with a full Remedial Investigation
designed to assess the nature and extent of the remaining
contamination.
Beginning June 23, 1983, EPA (through their subcontractor,
SCA Recycling Industries, Inc., of Braintree, Massachusetts)
began removal of contaminated soils on the Site. A total of
518 tons of contaminated soil was removed and disposed at
21
-------
the SCA Model City, Hew York landfill facility. The soils'
were renoved from locations within the Kerry Place and Grant
Gear properties. Reported excavation depths were up to 30
inches. During the removal action, water samples taken from
the storm drain system behind the Grant Gear building
indicated low levels of PCB contamination. The removal
action was completed on August 5, 1983.
22
-------
Part IX. Summary of Potentially Responsible Party Comments
EPA received and responded to extensive comments from the
PRPs. In brief, the main comments are: 1) the EA and FS do
not support the need for an active management of migration
alternative with respect to groundwater; 2) the recommended
cleanup levels of contaminants in soils are inconsistent
with levels set by EPA in comparable circumstances and
inappropriate in light of the risks associated with those
contaminants; 3) the solvent extraction alternative is not
cost-effective and EPA did not consider containment
alternatives; 4) the target cleanup levels and target risks
from which they are derived are based on flawed analysis and
are inconsistent with Region I Records of Decision at other
PCS sites and EPA guidance documents; 5) the Remedial
Investigation and Feasibility Studies contain two critical
omissions of data and remedial alternatives concerning the
Grant Gear facility; 6) the proposed drainage remedy, while
appropriate in its thrust, fails to take into account .
alternatives while prematurely proposing additional
measures; 7) the proposed wipedown of interior plant
surfaces is excessive in light of the data in the record; 8)
analytical measurements at the site are not realiable; 9) an
environmental risk assessment was not conducted; and 10) EPA
has mishandled the RI/FS process.
EPA's responses to the PRP's comments are provided in the
following section.
23
-------
Part ZZ. Potentially Responsible Party Comments
A* Comments from Folev. Hoao". and Eliot on Behalf of Cornell
r Electronics. Inc.
1. There is no justification to state that the federal
groundvater protection strategy and drinking water standards
are "relevant and appropriate.1*
EPA Responses In response to the need to organize and
coordinate the various programs that protect groundvater,
EPA issued its "Groundvater Protection Strategy" in 1984.
Although the Strategy is not a promulgated requirement and
therefore vould not be a potential ARAR for a Superfund
site, it does list several policy statements to be
considered vhen developing a protective remedy. The
Strategy outlines a number of specific activities, including
issuing guidelines on classifying groundvater for EPA
decisions affecting groundvater protection and corrective
action. Using the Groundvater Protection Strategy and the
EPA Guidelines for Groundvater Classification as, EPA
determined that the contaminated groundvater at the Norwood
PCB Site falls within Class IIB, (i.e. groundvater that
might be used as a drinking vater source in the future) . In
addition to the EPA policy for groundvater classification
and protection as outlined in the "Groundwater Protection
Strategy", the State of Massachusetts has adopted a
groundwater classification system. Under the state
classification system, on-site contaminated groundwater has
been classified as Class I, potential drinking water source.
The goal of the Superfund program's approach is to return
groundwaters to their beneficial uses. Therefore, for the
Norwood PCB Site, one of the goals of the groundwater
remediation is to restore the contaminated on-site
groundwater to drinking water quality within a reasonable
time frame. Based on the on-site groundwater classification
and the site-specific groundwater remediation goal, EPA has
determined that for this site maximum contaminant levels
(MCLs) are relevant and appropriate federal ARARs and
Massachusetts drinking water standards are relevant and
appropriate state ARARs.
2. A recommendation for the imposition of an active management
of migration alternative with respect to groundwater is
unwarranted.
EPA Response; Management of migration response objectives
were identified for the Site including the following:
1. reduce risks to human health associated with potential
24
-------
future consumption of groundwater;
2. reduce risks to human health and the environment from
current and future migration of contaminants in
groundwater; and
3. reduce risks to human health associated with potential
current and future inhalation of organics released from
the site.
The first objective was established in response to EPA's
Groundwater Protection Strategy and state and federal
groundwater classification schemes, as described in detail
in EPA's response to Comment A.I. Based on the on-site
groundwater classification and in order to achieve this
objective, EPA has determined that MCLs and Massachusetts
drinking water standards are relevant and appropriate ARARs.
Waivers, including technical infeasibility from an
engineering perspective, from complying with these ARARs are
not justified for this site.
Results of the RI indicate that a plume of chlorinated
organics is moving in the water table aquifer from the
western portion of the Grant Gear property, where
trichloroethene is found at more than 1 ppm, to Meadow
Brook. Chlorinated organics were also detected in bedrock
monitoring wells with maximum total chlorinated organics
detected at 1.5 ppm. In particular, vinyl chloride was
detected in a downgradient well at concentrations of 65 ppb
and 110 ppb. The second objective, as listed above, was
established to mitigate future migration of contaminants
within the site and possibly off-site. Future migration of
on-site groundwater, if unremediated, may result in
unacceptable risk to the environment and/or human health
from exposure to contaminants in Meadow Brook or in
groundwater migrated off-site.
The EA evaluated risks to workers at Grant Gear from
inhalation of airborne contaminants volatilized from the
Site. This evaluation indicates that the risk to workers
due to inhalation of vinyl chloride volatilized from
groundwater was estimated at 1.9x10 . The third
objective, as listed above, was, in part, established to
reduce risks to workers from inhalation of airborne
contaminants volatilized from groundwater. Achievement of
MCLs, including 2 ppb of vinyl chloride, within the aquifer
will significantly and permanently reduce risks to less than
1x10 to Grant Gear workers through inhalation of organics
volatilized from the Site.
In summary, an active management of migration alternative,
as described in Section X.B.2., has been selected in order
to achieve management of migration remedial response
objectives within a reasonable time frame. The FS has
25
-------
estimated, a restoration time frame, as defined as
achievement of MCLs within the aquifers, of less then 10
years.
3. The imposition of institutional controls obviates the need
for evaluation of a groundwater ingestion scenario in the
Endangerment Assessment.
EPA Response! The Endangerment Assessment evaluated a
groundwater ingestion scenario as a potential exposure
pathway for a future hypothetical resident. This baseline
evaluation was conducted in the absence of institutional
controls. The purpose of a baseline endangerment assessment
is to evaluate potential risks under the no-action
alternative (i.e., in the absence of remedial actions
including institutional controls).
As described in EPA's response to comments A.I and A.2., the
groundwater at the site is classified under both state and
federal classification systems as a possible future drinking
water source. In view of this classification, evaluation of
a future groundwater ingestion scenario is appropriate. It
should also be noted that institutional controls are never
selected when a more protective and effective alternative is
available.
4. The proposed groundwater extraction system as designed will
not be capable of excluding flow from Meadow Brook and of
extracting a significant amount of bedrock groundwater.
EPA Response: The alternative groundwater extraction
systems evaluated in the FS considered the need to protect
Meadow Brook against flow reduction. The barrier drain
extraction system included in the proposed plan was selected
based on its estimated technical feasibility,
implementability, and cost-effectiveness in providing this
protection. Additional evaluation is planned prior to the
final design of the barrier drain system to evaluate the
ability of the HDPE liner in preventing Meadow Brook surface
waters from entering the groundwater collection system.
However, the barrier drain extraction system must be
considered as part of the overall groundwater treatment plan
which returns treated groundwater to the.aquifer system.
The combination of the barrier drain extraction system and
the reintroduction of treated water into the groundwater
system was conceived to aid in balancing the flow
relationships of Meadow Brook to prevent flow reduction.
Prior to installing the barrier drain extraction system,
predesign studies will be performed to evaluate
implementation issues.
26
-------
Tests, including permeability tests, will be conducted to
evaluate the effectiveness of the HOPE liner in preventing
Meadow Brook surface waters from entering the groundwater
collection system. Consideration of impacts of surrounding
wetlands (i.e. dewatering, groundwater mounding) will be
incorporated into the pumping and HOPE liner test designs.
If the evaluation of predesign studies determines that the
barrier drain collection system would not be implementable
or effective, an active pumping extraction system will be
used to collect overburden and shallow bedrock groundwater
using a series of groundwater extraction wells. The
extraction well system was discussed and evaluated in
Section 7.2 of the FS, which described a series of nine
shallow extraction wells in a line parallel to Meadow Brook.
This analysis indicated that the extraction well system
would be supplemented with a cutoff wall, such as a slurry
wall, in order to control the capture of water flowing in
Meadow Brook.
5. The technical feasibility of the proposed recharge system is
not demonstrated.
EPA Responsei The recharge field conceptually designed for
use in the discharge of treated water is based on
conventional technology used in septic system leach fields.
This technology has been in use for many years across the
United States to effectively manage the discharge of
wastewaters to the subsurface. While this is a different
use of the technology than domestic wastewater management,
the sizing and capacity requirements of the recharge field
can be easily modified at low cost, if required, to meet
higher or lower flow requirements.
6. Airstripping does not appear to be the most economical
alternative because both liquid and vapor-phase activated
carbon adsorption will be required.
EPA Response; As is presented in Tables 7-5 (Air Stripping
Costs) and 7-6 (Activated Carbon Costs), the cost of air
stripping is approximately $175,000 more than the cost of
carbon adsorption (present worth, 5% discount rate).
,However, the type of conceptual design costing included in a
feasibility study is intended to be within a -30/+50 %
range. The costs of the air stripping and carbon adsorption
alternatives are within 10% of each other, thus, in terms of
the accuracy of the cost estimate, these costs can be
considered to be identical.
Estimated present worth costs associated with
ultraviolet/oxidation are greater than the costs for air
stripping. Any post- or pre-treatment requirements need for
air stripping will be equally needed for carbon adsorption
27
-------
and UV/oxidation.
7. A nor* cost-effective mtinr of removal of PCBs from
groundwater could include m filtration system with gradually
decreasing mesh sized to remove solids from the groundwater.
This technology was not evaluated in the FS.
EPA Response: All treatment units described in the
conceptual design of the ground water treatment process will
require some amount of bench scale and/or pilot scale'
treatability testing to determine that best unit processes
to use, sizing and flow requirements, and their most
efficient configuration. The filtration system described in
the comment (gradually decreasing mesh sizes) can be modeled
by a multi-media granular filtration system. This
technology was screened in Section 4 of the FS,
Identification and Screening of Remedial Alternatives, and
maintained as a support technology. This type of filtration
would probably be utilized at the end of the treatment train
to remove the remaining suspended solids following
precipitation. There are several reasons why it was not
utilized to remove PCB contaminated solids in the conceptual
design of the ground water treatment system. Filtration
systems must be periodically back-washed to remove trapped
solids. The back-washing requires large amounts of water.
This water would be contaminated and would require disposal.
As the unit would be the first step of the treatment train,
recycle would be impossible and the back wash would require
disposal off-site or additional on-site treatment
capabilities. The granular media would become contaminated
with PCBs and would therefore be very expensive to dispose
since it would be required to be placed in a TSCA landfill.
If a filtration system of "decreasing mesh sizes" were used,
those mesh materials would require frequent replacement or
cleaning and would also require expensive disposal. The
"sacrificial" carbon units were selected for their ease in
maintenance and relatively low cost. They are called
sacrificial beds because their sole purpose is to remove
PCBs. PCB compounds are extremely susceptible to absorption
on solids particles. Very little carbon would be required
to remove the majority of the PCB from the water. All other
chemicals present would eventually pass through the carbon
bed and be treated via the air stripper and
precipitation/filtration treatment units.
8. The type of precipitation/filtration process that is
considered in the FS is not identified. This process is
included at the end of the treatment train, raising question
concerning both its technical and effectiveness and its
intended purposes.
EPA Response: All treatment units described in the
28
-------
conceptual design of the ground water treatment process will
require some amount of bench scale and/or pilot scale
treatability testing to determine that best unit processes
to use, sizing and flow requirements, and their most
efficient configuration. Typically, precipitation processes
result in sludges requiring further treatment, volume or
water content reduction, and, ultimately, disposal. The
intent of placing the precipitation/filtration process at
the end of the treatment train was to reduce the quantity of
hazardous chemicals in the water prior to generation of the
sludge, resulting in a reduction of the additional sludge
treatment required and in the cost of final sludge disposal.
9. The selection of the 1 ppm PCB cleanup target would result
in excessive remediation costs not supported by the risk
evaluation.
EPA Response; Two scenarios were presented in the EA to
evaluate the potential exposure and risk through dermal.
contact and incidental ingestion of chemicals of potential
concern in dredge piles and/or surface soils in on-site
areas north of the Grant Gear facility. The first scenario
assumes an older child frequents this area and has contact
with dredge piles or soils in this area. The second
scenario assumes local residents are exposed to chemicals of
concern in surface soils in their backyards by outdoor
activities such as playing or gardening.
Calculated incremental carcinogenic risks were determined to
be greater for a child exposed to contaminated dredge piles
or soils in the wooded area north of Grant Gear than for
residents contacting contaminated soils in their backyards.
The incremental lifetime carcinogenic risks for an older
child exposed to contaminated dredge piles and surface soils
in the wooded area north of Grant Gear ranged from 2x1O"6 to
6xlO"4. In comparison, for residents contacting
contaminated soils in their backyards, incremental lifetime
carcinogenic risks ranged from 2xlO"7 to 3xlO~6,
reflecting the lower concentrations of chemicals of concern
in the residential backyards. In both scenarios, PCBs and
total carcinogenic PAHs contribute the majority of the total
risk and calculated hazard indices are less than one.
Since no federal or state ARARs exist for soil, the soil
target levels for PCBs and PAHs were determined by a site-
specific risk analysis. Based on the results of the risk
assessment for the protection of residents exposed to
contaminated soils in the aforementioned areas, soil and
dredge pile cleanup levels of 1 ppm of total PCBs and 2 ppm
of total carcinogenic PAHs have been selected. The
assumptions used to calculate these soil target levels are
presented in Table 14 of the ROD, and reflect the
29
-------
nonrestricted access and residential current and future land
use of the areas along and adjacent to Meadow Brook.
As stated above, the Meadow Brook area soil and dredge pile
remediation component of the selected remedial action
involves excavation of solids, within the unsaturated zone,
contaminated with total PCBs at concentrations of 1 ppm or
greater, and total carcinogenic PAHs at concentrations of 2
ppm or greater. These clean-up levels will result in a
incremental carcinogenic lifetime risk level of 7x10"* under
both current and future use Site conditions. This risk
level is between the 10 and 10*7 risks levels recommended
by EPA guidance and less than the maximum total site risk
level of 10 specified in the Massachusetts Contingency
Plan.
In addition to setting levels protective of human health, it
is of particular note that the soil PCB cleanup level of 1
ppm was selected to be consistent with the Meadow Brook
sediment PCB cleanup level of 1 ppm. This consistency
will ensure that after the stream remediation, the streamed
sediments will not be recontaminated with PCBs due to
contaminants in soil eroding into the stream from areas
adjacent to Meadow Brook.
10. Insufficient information and calculations are provided to
evaluate the validity of the cleanup goals for VOCs in soil.
EPA Response: Soil cleanup goals for volatile organic
chemicals (VOCs) were identified to minimize migration of
VOCs to groundwater. The site-specific analysis for
determining target soil cleanup levels for VOCs used fate
and transport modeling to determine levels at which residual
VOCs in soils would not leach contaminants to groundwater
above groundwater target cleanup levels. Reducing VOCs to
the soil target cleanup levels will reduce the time needed
for restoration of the aquifer and aid in the attainment of
groundwater target levels, including MCLs. Cleanup target
concentrations were set to limit potential effects of
leaching of chemicals from site soils to the ground water
system. Complete information and calculations used as a
basis for estimating soil concentrations that would prevent
leaching of water from the soils to the ground water system
in excess of groundwater target levels including Maximum
Contaminant Levels (MCLs) were presented in the Feasibility
Study.
11. The proposed cleanup level for PAHs is below "background"
levels. This could result in no limit to the areal scope of
the remediation.
EPA Response: Total carcinogenic PAH soil target cleanup
30
-------
EPA Response: Total carcinogenic PAH soil target cleanup.
levels for soils and dredge piles between Grant Gear's
northern fence and Meadow Brook and areas north of Meadow
Brook have been set at 2 ppxn. For all other on-site soils,
a soil target cleanup level of 6 ppm of total carcinogenic
PAHs has been established.
As described in the "Supplemental Risk Assessment Guidance
for the Superfund Program,11 EPA, Region I (June, 1989),
preferably upgradient samples collected in the field should
be used to characterize background levels of contamination.
Consistent with this policy, background samples (SO1-100,
SO1-044, SD-000, and SS1-005) were collected from
various areas in the vicinity of the Site. The background
samples collected furthest from the Site are SO1-100 and SD-
000 which were collected from Shattuck Park which is located
approximately 1.2 miles northwest of the Site. Based on
results of analysis of these samples, background
concentrations of contaminants in soils in the region of the
Site were established and are presented in Table 2-1 of the
EA (Ebasco, August, 1989). This table lists a range of Not
Detected (<430) - 1,020 ug/kg (1.02 ppm) as the "background"
range for total carcinogenic PAHs. Therefore, the PAH soil
target cleanup levels specified in the ROD are not below the
"background" levels for this site, as determined by analysis
of upgradient samples collected in the field.
12. The need for a chemical waste landfill for several source
control alternatives including solvent exaction may
significantly affect the cost and feasibility of these
alternatives.
EPA Response: As described in Section XI.B. of the ROD, EPA
has determined that for this Site, placement of soils,
sediments and dredge pile materials with PCB levels no
greater than 10 ppm under a 10 inch soil cover or asphalt
and construction of a groundwater collection trench will
provide a permanent and protective remedy that satisfies the
requirements of TSCA Disposal regulations (Part 761 landfill
regulations). Long-term monitoring of groundwater wells, as
described in components (e)(f) and (h) of the selected
remedy, will also satisfy requirements of the TSCA landfill
regulations.
This determination is based on the Regional Administrator's
exercise of the waiver authority contained within the TSCA
regulations at 40 C.F.R. § 761.75(c)(4). Specifically, the
Regional Administrator determined that, for the Norwood PCB
Site, the following provisions of the regulations will be
waived and are not necessary to protect against an
unreasonable risk of injury to human health or the
31
-------
environment:
1) 40 C.F.R. § 761.75(b)(l) - low permeable clay
conditions
2) 40 C.F.R. § 761.75(b)(2) - synthetic membrane liner
3) 40 C.F.R. § 761.75(b)(3) - bottom of liner 50 feet
above water table
The soil cover, collection trench and groundwater monitoring
are all integral parts of the source control and management
of migration components of the selected remedy. Because
these components also satisfy the requirements under TSCA §
761.75, no additional costs are warranted based solely on
compliance with the TSCA ARAR. As described above, EPA has
concluded that based on an assessment of Site conditions and
an evaluation of the selected remedy in comparison to
requirements specified in 40 C.F.R. 761.75, the construction
of a chemical waste landfill is not needed at this Site.
13. The FS did not evaluate any containment alternatives that
may provide a high degree of environmental and public health
protection at a significantly lower cost than the proposed
alternative.
EPA Response; The FS did evaluate in detail a containment
option (SO2 Capping) as a source control alternative. The
SC-2 alternative would consist of consolidating outlying
contaminated areas, and dredge piles, and sediments under an
impermeable cap constructed on-site over the central zone of
contamination.
The cap would be designed to serve two purposes:
1. to prevent direct human exposure to contaminated soils
and sediments; and
2. to reduce the amount of infiltration through the
contaminated soil, thus reducing the potential for
contaminants leaching to groundwater.
Although the present worth cost estimated for the
containment option (SC-2) is lower than the solvent
extraction (SC-3), the containment option was not selected
as the source control alternative for remediation of soils,
sediments and dredge pile materials. Significant
disadvantages associated with containment (SC-2) include the
uncertainty of its long-term effectiveness and the potential
for future remedial costs and risks to human health and the
environment if the cap were to fail. In addition,
containment would not address the principal threats posed by
such contaminants and would not permanently and
significantly reduce the toxicity, mobility or volume of
hazardous substances. Finally, volatile organic
32 .
-------
contaminants in soils would continue.to leach into
groundwater, thus contributing to groundwater contamination.
14. Several components of the cost estimates appear to
underestimate the actual cost. When an appropriate estimate
of the actual costs for implementing the solvent extraction
alternative is developed, that alternative may not be cost-
effective or justifiable.
EPA Response; Cost estimates developed and presented in the
feasibility study are a direct result of vendor quotes or
have been taken from reliable sources (i.e., Means Site
Work) and have been modified to reflect the additional costs
associated with handling hazardous material. All
alternative costs were developed in the same manner and to
the same degree of accuracy. Therefore, a cost increase
associated with one alternative will most likely result in
an increase in the other alternatives also. The final
result of this exercise would be a higher cost for each of
the alternatives, yet no change in the cost ranking of each
alternative.
15. An overall rejection of all acetone, toluene, methylene
chloride and phthalates based on these compounds being
common lab contaminants does not seem appropriate.
EPA Response; As stated on page 2-2 of the Endangerment
Assessment, a screening analysis was performed to determine
the chemical-specific concentrations which would correspond
to a lifetime excess cancer risk of 10 . These screening
concentrations were then compared to concentrations in the
site samples, and site-specific concentrations that were
lower than the screening concentrations were eliminated from
further evaluation because of their negligible impact.
16. The assumption of a zero background concentration for
organics may skew cleanup targets beyond background levels.
EPA Response: In preparing the Endangerment Assessment for
the Norwood site, site data were compared to available
background concentrations. Based on this comparison,
numerous organic chemicals were eliminated from the
evaluation. Table 2-1 lists the background concentrations
used in the endangerment assessment for organic chemicals.
This data was collected at the site in areas that EPA
believes is representative of background levels. A zero
background concentration was not assumed for any of the
organic chemicals. In some cases the background
concentrations were below the analytical detection limit,
but EPA did not assume that non-detected concentrations were
zero.
33
-------
collected.
EPA Response; The scope of the remedial investigation, to
include the number of samples collected and the analysis
performed was developed through an extensive well defined
scoping process. The process began with an assessment of
remedial objectives and development of potential remedial
alternatives for the site to focus the investigation and
increase the efficiencies of the study. The identification
of data needs were identified through a thorough
investigation of potential site contaminants and potential
remedial action related ARARs, preparation of a baseline
risk assessment and identification of risk based data needs,
and an assessment of site characterization data needs.
Based on the data needs identified, the samples
were collected to be representative of the site and the
analysis performed on the samples was honed through the use
of Data Quality Objectives (DQOs). DQOs are qualitative and
quantitative goals, in terms of precision, accuracy,
representativeness, comparability and completeness which are
specified for each data set proposed for collection. Data
quality is the degree of uncertainty which can be acceptable
in the decisions or conclusions which are derived from
interpretation of the data set. The use of this process
prevents the investigator from the collection of inefficient
samples and the costs associated with the analysis. Based
on the use of this process EPA feels that a sufficient
number of samples were collected to meet the project
requirements for this site.
18. Not selecting a contaminant because it was not elevated in
any other areas or media sampled is not appropriate.
EPA Response; As stated on page 2-2 of the Endangerment
Assessment, a chemical was eliminated from further
consideration if it was detected infrequently in one sample
set and either not detected at all or infrequently in other
areas and/or media sampled. This criterion is considered
appropriate and necessary so that the evaluation would be
based on site-related chemicals only. The infrequent
detection of a given chemical in a particular sample set
coupled with its infrequent or non-detection in other sample
sets and/or sampled media indicated that the presence of the
chemical at the site would not be considered site-related.
19. It is not appropriate to consider the TSCA PCB Spill Policy
as an ARAR.
EPA Response: TSCA's Spill Cleanup Policy is in 40 C.F.R.
Part 761 Subpart G. In § 761.120(a) (ii), the policy states
that "...old spills which are discovered after the effective
date of this policy will require site-by-site evaluation
34
-------
because of the likelihood that the site involves more
pervasive contamination than fresh spills and because old
spills are generally more difficult to cleanup then fresh
spills." Therefore the cleanup policy doesn't supply a
standard for "old spills" which occurred before the
effective date of the policy, May 4, 1987.
The TSCA PCB Spill Cleanup Policy is designated as "to be
considered" (TBC) for the Norwood PCB Site because PCB
contamination at the Site occurred before the effective date
of the policy. However, in accordance with EPA ARARs
guidance, TBCs will be considered along with ARARs as part
of the site risk assessment and may be used in determining
the necessary level of cleanup for protection of health or
the environment. For this site, EPA considered the TSCA PCB
Spill Cleanup Policy in determining appropriate target
levels and remedial action for PCB contaminated soils and
equipment and floor surfaces. EPA's risk assessment
indicates that for the cleanup of contaminated equipment
surfaces within the Grant Gear building a risk-based target
level (5 ug/100 cm2! lower than the Spill Policy cleanup
level (10 ug/100 cm ) is warranted to adequately protect
Grant Gear workers in direct contact with contaminated
equipment surfaces. However, based on the infrequency of
exposure to PCB-contaminated floor surfaces within Grant
Gear and soils under paved roads outside the Grant Gear
property, EPA established a target cleanup level of 25 ppm
for contaminated soils under paved roads and a remedial
action of decontamination based on the TSCA PCB Spill
Policy. Both these measures will be adequately protective
of human health and the environment. %
20. The Town of Norwood should be partially responsible for
dredging costs because of the planned flood control work.
EPA Response; CERCLA § 121 requires selection of a remedial
action that is protective of human health and the
environment. The Endangerment Assessment examined risks
associated with exposure to contaminated sediments in Meadow
Brook including direct contact with or incidental injestion
of sediments for a child. The highest incremental
carcinogenic risk was 5xlO"5, based on direct contact by an
older child with the maximum concentrations of contaminants
in Meadow Brook sediments. The EA also evaluated potential
impacts to environmental receptors exposed to contaminated
sediments and concluded that small mammals, rodents and
aquatic organisms that inhabit the area, are at risk from
exposure to Site contaminants through the skin, by ingestion
or through the food chain. Based on results of the EA, EPA
has determined that remediation of Meadow Brook sediments is
necessary to adequately protect human health and the
environment.
35
-------
The sediment cleanup level for total PCBs has been specified
at 1 ppm. This value'is based on toxicological literature
which documents examples of sublethal toxic effects in
aquatic organisms at PCB tissue levels and hence sediment
PCB concentrations of greater than 1 ppm. A value of 1 ppm
of total PCBs for the protection of environmental receptors
is also consistent with other Records of Decision signed
within this region. In addition, achievement of the
sediment cleanup level will result in significant reduction
of risks to children exposed to contaminated sediments in
Meadow Brook.
As described in Section X.A.2.C. of the ROD, approximately
3,000 cy of Meadow Brook streambed sediments with
contaminants in excess of the sediment cleanup levels will
be excavated, from locations near the Grant Gear outfall to
the confluence of Meadow Brook and Neponset River. This
volume of sediments that will be excavated exceeds the
volume necessary to be removed for construction of the
Meadow Brook flood control project. Therefore, costs
associated with dredging of sediments in accordance with
component will justifiably be the responsibility of whomever
performs the remedial action selected in this ROD. The town
of Norwood, based solely on their flood control project,
will not be partially responsible for dredging cost incurred
by remedial action described in Section X.A.2.C. of the ROD.
21. The entire issue of water and sediment quality upstream
versus downstream of the site and its outfall is not
addressed and sources other.than the site may exist.
EPA Response: The Remedial Investigation (RI) considered
the results of upstream and downstream water and sediment
samples as well as the results of water and sediment samples
to identify site-related chemicals. Some chemicals in
sediments that were found above detection upstream of the
Grant Gear discharge pipe but were found downstream and in
. the discharge pipe at higher concentrations were identified
as being partially attributable to the Grant Gear discharge.
This was the case with the semi-volatile chemicals 1,2,4-
trichlorobenzene and phenol.
22. Semi-volatile contamination in the sediments is only
partially attributable to the site. Therefore, remedial
costs associated with these compounds should not be
completely attributable to the site.
EPA Response: Semi-volatile contamination (PAHs) in
sediments was estimated in the RI to potentially be
partially attributable to site activities in some urban
areas of Medow Brook. The RI further indicated that the
36
-------
sediments in Medow Brook were contaminated with PCBs from .
areas approximately near the Grant Gear outfall to the
Neponset River. As described in Section X.A.l.c. of the
ROD, a sediment target cleanup level for PCBs was
established. There is no question that PCBs is a chemical
of concern at the Norwood PCB Site. No sediment target
cleanup level for PAHs was established. While it is true
that excavation of the sediments will result in reduction of
the PAH levels in sediments, remedial costs relating to
remediation of the sediments will be driven by activities
relating to the PCB cleanup not the PAH cleanup.
23. The FS does not present evidence that the route of air
exposure due to VOCs is complete.
EPA Response; The Endangerment Assessment does discuss the
air exposure pathway for VOC release from soils and
groundwater and considers the pathways to be complete (see
Section 4 of the EA).
24. No rationale is advanced in support of lower cleanup levels
for soils and dredge piles between the northern fence and
Meadow Brook than for all other soils.
EPA Response; Exposure assumptions used in establishing
target levels for soils and dredge piles between the
northern fence and Meadow Brook are different than the
assumptions used for all other soils. Specifically, soil
and dredge pile cleanup levels of 1 ppm of total PCBs and
2 ppm of total carcinogenic PAHs were selected to protect
* residents exposed to contaminants in soils and dredge piles
in areas between the northern fence of Grant Gear and Meadow
Brook and north of Meadow Brook. Exposure assumptions used
to calculate these target levels are presented in Table 14
of the ROD, and reflect the nonrestricted access and
residential current and future land use of the areas along
and adjacent to Meadow Brook. These cleanup levels for
soils and dredge piles will result in an incremental
carcinogenic lifetime risk of 7xlO"6 under both current and
future residential use of these areas.
In addition to setting levels protective of human health, it
is of particular note that the soil PCB cleanup level of 1
ppm was selected to be consistent with the Meadow Brook
sediment PCB cleanup level of 1 ppm. This consistency
will ensure that after the stream remediation, the streambed
sediments will not be recontaminated with PCBs due to
contaminants in soil eroding into the stream from areas
adjacent to Meadow Brook.
For all other soils, including soils within the Grant Gear
property, soil cleanup levels of 10 ppm of total PCBs and 6
37
-------
ppm of total carcinogenic PAHa were selected to protect
workers exposed to contaminants in soils in areas within
Grant Gear and other commercial properties. Exposure
assumptions used to calculate these target levels are
presented in Table 14 of the ROD, and reflect the
nonrestricted access and commercial current and future land
use of these areas. These levels will result in an
incremental carcinogenic lifetime risk level of IxlO"5 under
both current future use Site conditions.
25. The basis for the 175 ppb cleanup goal for total 1,2-
dichloroethenes is not presented.
EPA Response* As stated in the Proposed Plan for the
Norwood PCB Site, "groundwater cleanup goals for the site
were based on the federally - established MCLs, health
effects assessments and the State of Massachusetts
groundwater standards". In particular, the cleanup levels
established for total cleanup levels established for total
1,2-dichloroethenes and 1,2,4-trichlorobenzene were based on
the site-specific health assessment for the protection of
human health from adverse noncarcinogenic effects due to
ingestion of groundwater contaminated with those chemicals.
Each target level reflects a hazard index (HI) of 0.5, for a
combined HI of 1.0.
26. The non-RCRA cap should be eliminated because of
unreliability and the RCRA cap retained.
EPA Response: Based on the evaluation of screening
criteria, the RCRA cap was eliminated and the non-RCRA cap
was retained. As was presented in Section 4 of the FS, and
discussed in detail in Appendix A of the FS, implementation
of the RCRA cap would have a detrimental effect on the
future uses of the property and the Grant Gear building.
The building is surrounded on three sides by PCB
contaminated material. A multi-layered RCRA approved cap is
typically at least 4 feet thick and may be as much as 7 feet
thick depending upon the final approved design. The
placement of a RCRA cap on the site would not allow the
continued use of the building as many exits including the
loading docks in the rear of the building, would be precluded
from use. Additionally, the contamination is directly
adjacent to the building, which would require the cap to be
placed directly against the building walls. It is doubtful
if the walls could withstand the added pressure placed upon
them by the multi-layered cap. The non-RCRA cap, while
admittedly requiring a greater amount of maintenance, would
not effect the future use of the site or the building. The
non-RCRA cap would result in an elevation change of
approximately one foot which would not greatly affect the
building functions. The asphalt cap would be designed to
38
-------
building functions. The asphalt cap would be designed to '
support a typical parking lot which would increase the uses
of the site property, much of which is currently being used
for parking. The asphalt cap is easily repaired through
standard construction maintenance, and the HOPE liner
incorporated into the cap design would mitigate the volume
of precipitation reaching the contaminated soil in between
the periodic cap repair.
27. Costs estimated for the lining of Meadow Brook appear low
including handling costs, analysis costs, costs associated
with clearing and cost for dam construction, pipeline and
sediment curtains.
EPA Response: Cost estimates developed and presented in the
feasibility study are a direct result of vendor quotes or
have been taken from reliable sources (i.e., Means Site
Work) and have been modified to reflect the additional costs
associated with handling hazardous material. The costs
presented in Tables 6-3, and 6-4 are the estimated costs of
lining Meadow Brook from just above the Grant Gear outfall
pipe to the confluence with the Neponsett River, after the
sediment containing PCB concentrations exceeding the
indicated level have already been removed. For example,
Table 6-3 presents the estimated cost to line Meadow Brook
given the 10 ppm excavation scenario. Therefore, all
sediment material containing PCB concentrations greater than
or equal to 10 ppm have already been removed. The costs
presented include the additional clearing and grubbing, and
the access road needed to reach the lower portions of the
stream in order to remove the additional material necessary
to allow construction of the liner. These costs are not
included in Table 6-4, the 1 ppm excavation scenario,
because it is assumed that the material containing 1 ppm
concentrations of PCB or greater have already been removed,
thus the access road construction and additional clearing
required have already been performed. Since both scenarios
assume that contaminated material has already been
excavated, there is no need to include the costs of bypass
pipes, sediment curtains, and analyses, as these will
already have been done.
In addition to the above discussion, the comment appears to
be concerned with the unit costs used for several of the
site activities. Item 1.5 of Table 6-3 is the cost of
spreading and compacting material on the site. The cost of
loading the trucks and hauling the material to the site is
included in the excavation and stockpiling cost. The costs
of disposing the material containing PCB concentrations less
than 1 ppm assumes that this material may be disposed as
clean fill, thus the majority of the cost reflects the
anticipated cost of transporting the material to a site
39
-------
accepting clean fill.
28. The cost estimate for excavation and stockpiling appears to
be very low.
EPA Response; The cost estimate for soil excavation and
stockpiling is based on costs taken from Means Site Work,
and modified to include a health and safety factor. It
should be noted that excavation will only be to the water
table (8 feet), and the majority of the excavation is within
the top 5 feet of soil. Actually, much of the contaminated
area is only 1 to 2 feet deep, thus, the excavation will be
simple and fairly routine. Although proper respiratory
equipment will most likely be required, it is not
anticipated to slow down equipment operators a significant
amount. Depending on the site layout that will be developed
in the design phase, and the phasing of the
excavation,stockpiling, and treatment, excavation costs may
be higher than estimated if excessive double handling of
material is required. If the cost estimate for the
excavation and stockpiling is higher than estimated, the
contingencies applied to the capital cost are more than
sufficient to cover any additional costs.
29. Costs estimated for the groundwater extraction system appear
low, including excavation costs and unanticipated variations
in bedrock elevations.
EPA Response; Cost estimates developed and presented in the
feasibility study are a direct result of vendor quotes or
have been taken from reliable sources (i.e., Means Site '
Work) and have been modified to reflect the additional costs
associated with handling hazardous material. Variations in
the depth of bedrock were utilized in determining the volume
of material required to be excavated. The type of
conceptual design costing included in a feasibility study is
intended to be within a -30/+50 % range. Assuming the
trench excavation cost presented is low, doubling the
excavation cost adds less than 10 % to the total cost of
implementing the barrier drain trench, and it is st:ll much
more cost-effective than the well extraction system and
slurry wall option.
30. The costs of vapor phase carbon appear overestimated
whereas, costs for the sacrificial carbon bed appear
underestimated.
EPA Response; The costs presented for the vapor phase
carbon and the sacrificial carbon bed are the result of
direct conversations with carbon vendors. It was difficult
to develop the costs for the vapor phase carbon since the
air stripper has not been fully designed, and the chemical
40
-------
concentrations of the air phase effluent of the air stripper
have not been determined. However, vapor phase carbon
systems are commonly much more expensive than aqueous phase
carbon systems, and the volatile chemicals expected to exist
in the air phase effluent will have relatively fast carbon
saturation rates resulting in high carbon usage. On the
other hand, the sacrificial carbon bed will have a very low
carbon usage rate as it is designed solely for removal of
PCB, which is readily adsorbed onto the activated carbon.
All other chemicals present would be allowed to saturate and
pass through the sacrificial bed to be treated via the air
stripper. The low PCB concentrations present in the water,
and the relatively low flow rate will not require the
utilization of a large carbon unit.
31. The placement of metals removal at the end of the treatment
train, while offering the potential for production of a less
hazardous sludge can cause operation problems.
EPA Response: All treatment units described in the
conceptual design of the ground water treatment process will
require some amount of bench scale and/or pilot scale
treatability testing to determine that best unit processes
to use, sizing and flow requirements, and their roost
efficient configuration. The precipitation/filtration
process was placed at the end of the water treatment train
because it would result in a less hazardous sludge which may
require less treatment and be less expensive to dispose.
The. ground water would require acidification prior to
treatment via the activated carbon unit and the air stripper
to mitigate the potential of precipitation clogging either
treatment unit. After air stripping, the treated water
would be neutralized and returned to its natural pH prior to
recharge of the treatment effluent to the ground water.
This neutralization may cause some precipitation of metals
forming sludge. Additionally, there may be biological
growth in the air stripper that will slough off into the
effluent. This will also require filtration. Thus, some
. type of filtration unit may be required at the end of the
treatment train, regardless of the treatment configuration.
As stated above, results of treatability studies or pilot
studies will be evaluated to determine the best overall
design for the air stripper and other treatment components
and the need for pre- and post-treatment units, including
acidification and carbon polishing unit, thay may be
necessary to meet all required discharge regulations. These
results will also yield information on the percent reduction
of organic and inorganic compounds in groundwater and the
volume and types of residuals and byproducts produced by the
operation of the groundwater treatment system.
41
-------
B. ffffBMPts from Morgan. Lewis and Backing on behalf of Federal
Pacific Electric Company
1. Region I*s usa of a "maximum plausible risk assessment
methodology" is not a scientifically validated technique and
its use is inconsistent with EPA Headquarters Guidance for
conducting public health evaluation.
EPA Response i The Endangerment Assessment used a single set
of exposure parameters with both mean and maximum
concentrations for the chemicals of potential concern where
appropriate. The exposure parameters used in the evaluation
ranged from average to plausible maximum values. Thus, this
evaluation did not use maximum plausible values exclusively.
The use of plausible maximum values in the Endangerment
Assessment is consistent with EPA Headquarters guidance and
operational practice.
2. The Aroclor mixture at the site was reported to be largely
Aroclor 1254. Therefore, it is unreasonable to use the same
cancer potency factor for these mixtures as one would use
for Aroclor 1260.
EPA Response: EPA guidance does not provide Aroclor-
specific cancer potency factors for PCBs. Instead a general
cancer potency factor is provided for PCBs that is based on
studies of Aroclor 1260. This number is intended to
represent all PCBs when quantifying the potential health
risks from any PCB mixture or Aroclor.
Use of the potency factor for Aroclor 1260 is consistent
with the "Supplemental Risk Assessment Guidance for the
Superfund Program" (EPA Region I, June 1989).
3. The risk assessment treats all carcinogenic PAHs at the site
as having the old cancer potency factor of benzo(a)pyrene.
As a result, the Agency has been able to grossly inflate the
risk estimates for human contact.
EPA Response: The use of the benzo(a)pyrene cancer potency
factor as a surrogate for all known and suspected
carcinogenic PAHs is consistent with current EPA guidance
and operational procedures. It is done in the absence of
EPA validated health criteria for other PAHs besides
benzo(a)pyrene (B[a]P).
As stated in EPA Region I guidance. Use of the carcinogenic
potency factor of B[a]P for carcinogenic PAHs may result in
overestimation of risk because B[a]P is considered to be one
of the most potent of the carcinogenic PAHs, and B[a]P is
likely to constitute only a fraction of the mixture of
carcinogenic PAHs present at a site. On the other hand,
42
-------
many other PAHs that are not routinely analyzed for at
Superfund sites nay have carcinogenic potential. Thus, this
approach nay not account for sone carcinogenic PAH
costituents because they haven't been identified or
classified by EPA as having carcinogenic potential.
4. Analyzing PCBs individually and sunning for reporting
purposes is a questionable nethodology resulting in skewing
of information on the naterial present at a particular site.
EPA Response: This nethodology was used for evaluating the
potential health effects associated with PCBs at the site.
As stated in the response to comment B.2, the EPA has
established only one health criteria number for PCBs.
Therefore, it is a common risk assessnent practice to sun
all PCB aroclors in a particular sanple in order to assess
the potential health inpacts for the entire mixture of PCBs
detected at the site. This is currently the only way to
quantitatively evaluate all PCBs detected at the site.
5. Use of the linear multistage model for risk assessments is
inappropriate for assessing risk form chemicals like PCBs
based on biological considerations.
EPA Response; The use of the linear multistage model for
quantifying potential health risks associated with exposures
to PCBs is consistent with current EPA guidance and
operational practices.
6. Human experience demonstrates that the PCB cancer prediction
model is overconservative.
EPA Response; While the conservative nature of the PCB
cancer prediction model is open to scientific debate, its
use in the Endangerroent Assessment is consistent with EPA
guidance and operational practices.
7. Potential exposures within the Grant Gear facility are
within OSHA allowable limits. Thus, it is difficult to
understand why EPA proposed such extensive cleanup of this
area when the exposures fall within legally established
limits.
EPA Response; Indoor air samples collected on May 28, 1989
within the Grant Gear building, detected PCB Aroclor-1254
ranging from 1.5 ug/m3 to 3.7 ug/m3. These detected levels
were well below OSHA's threshold limit value-time weighted
average (TLV-TWA) concentrations of 500 ug/m3.
The degree to which sources of PCBs within and outside the
Grant Gear building contribute to airborne PCB levels cannot
be exactly quantified. However, based on the results of the
43
-------
RI, the following media nay be contributing sources:
1) contaminated soils in the exterior of the building,
2) contaminated sediments and water within the drainage
system, and
3) contaminated surfaces within the Grant Gear building.
An evaluation of potential risks to workers from inhalation
of volatilized PCBs from soils (assuming no indoor source)
resulted in an incremental carcinogenic risk of 3x10"*.
Therefore, EPA believes it is reasonable to remediate
possible indoor sources so that predicted risk levels are
not significantly increased.
The selected remedy includes remediation of surfaces of
equipment, machinery and floors within the plant areas of
the Grant Gear building. EPA believes that remediation of
such surfaces is necessary to protect workers both in the
short- and long-term. The rationale behind this selection
is presented below:
1) As described in the EA, Grant Gear worker exposure
through direct contact with mean and maximum PCB
concentrations detected on equipment surfaces resulted
in an incremental carcinogenic risk of 2x10 and 5x10*
, respectively. Based on the site-specific risk
assessment, the cleanup level for Grant Gear machinery
and equipment surfaces has been set at 5 ug/100 cm for
total PCBs. Remediation of all equipment to this
cleanup level will result in a maximum risk of IxlO"5
workers due to exposure to contaminated machinery and
equipment surfaces inside Grant Gear.
2) EPA has determined that as a source control measure,
decontamination of the floor surfaces is necessary to
minimize the potential for migration of PCBs into the
air, and subsequent recontam- ination of equipment and
machinery. Therefore, decontamination of floor
surfaces is necessary to adequately reduce long-term
risks to workers for exposure to contaminated surfaces.
In addition, this measure at a relatively low cost will
further reduce, to the extent that PCBs on the floor
volatilize into the air, the risks to workers
associated with inhalation of PCBs.
Comments on the Proposed Plan received during the public
comment period, indicated that the selected remedy should
include decontamination of floor surfaces within the Grant
Gear building. Specifically, comments submitted on behalf
of Grant Gear, indicates the need to address PCB contam-
ination of the floor as a source of contamination inside the
building. Additional comments from the public have
44
-------
expressed the need to "prevent risk to humans by eliminating
all organic contaminants from the site." Finally, the state
of Massachusetts has expressed a preference for remediation
of the contaminated floors within Grant Gear in order to
restore conditions at the Site, to the extent feasible.
Therefore, inclusion of decontamination of floor surfaces
into the selected remedy as a source control measure is
consistent with EPA's guidance on the selection of a remedy
in that it addresses submitted state and community concerns
as part of the state and community acceptance criteria.
8. The Agency's failure to ensure the integrity of the sampling
data casts serious doubt on EPA's analytical finding and
conclusions.'
EPA Response: All EPA activities are performed under an
exhaustive Quality Assurance/Quality Control program from
sample collection and shipment through analysis and data
validation. Samples are collected with duplicates and
method blanks and matrix spike duplicates are prepared for
analysis. Sample shipments to the laboratory include travel
blanks, equipment blanks and matrix blanks. The validation
procedure evaluates holding time, instrument calibration,
laboratory blank results, ICP interference checks, spike
recovery results, laboratory duplicates, field duplicates,
laboratory control samples, detection limits, serial
dilutions, instrument time, surrogate spike recovery,
instrument performance and compound identification. It is
because of this program that EPA is able to ensure the
integrity of the data collected. The mobile laboratory used
at the Norwood PCB Site was subject to much the same QA/QC
as a standard CLP laboratory, and was subject to an
independent QA/QC audit. Approximately 24 percent of all
samples (104 samples) analyzed by the mobile laboratory were
analyzed by the CLP for confirmational analysis. A
regression analysis performed on the data found a high
correlation coefficient (0.945) and found significant
correlation at a confidence level greater than 99.5 percent.
Where minor problems were identified through the validation
procedure was in the CLP generated data. These problems
were a result of low level contamination by the laboratory
of the samples with extractant solvents resulting in very
few of the samples being either rejected or qualified as
estimated, where appropriate. Estimated values also include
concentrations of contaminants which were detected at
concentrations above the instrument detection limit but
below the CRQL. Notes on the tables in the data evaluation
portion of the RI relative to the use of data collected
prior to the remedial investigation were inserted to provide
a baseline of data to scope the project around. If data
collected by a previous investigation did not meet the
requirements and data needs identified in the scoping
45
-------
process, it was noted to b« unacceptable and no decisions
were Bade based on the data.
9. Unreasonable assumption were used to evaluate risks to
workers at the site including: a) implausibility that
workers would not wash or wear protective clothing; b)
unlikely soil exposure through landscaping or material
storage; and c) inappropriate soil adsorption factor.
EPA Responses EPA considers the exposure factors used in
the Endangerment Assessment to be reasonable. It is true
that in some cases these factors may represent a
conservative approach to the exposure level. The resulting
Endangerment Assessment represents at worst a maximum
plausible exposure assessment of the potential health risks.
With regard to the soil absorption factors, EPA used a
factor of 0.05 for PCBs and PAHs, and a value of 0.5 for all
other organic chemicals evaluated.
10. Unreasonable assumptions were used to evaluate risks to
children playing in the brook including: a) unreasonable
soil ingestion rate; b) failure to take credit for
vegetative cover.
EPA Response; The soil ingestion rate used in the
Endangeraent Assessment (50 rog/day) is within the values
published in the EPA's Exposure Factor Handbook (1988) for
children from 5-18 years of age with an intermediate to high
tendency to ingest soil. This data is based on considerable
experimental data. With regard to vegetative cover, EPA
does not believe that the cover is of a nature to prevent
soil contact. Therefore, the vegetative cover was not
considered in the evaluation of potential health risks
associated with this pathway.
11. EPA's groundwater exposure assessment is based on a model
which assumes that PCBs are dissolved in groundwater and
volatilization can be determined by application of Henry's
constant. However, the model does hot account for the
. ability of PCBs to bind to particulates and not dissolve in
groundwater. The model also overestimates the indoor air
concentration of PCBs inside the facility.
EPA Response; The model used to estimate volatilization
from groundwater assumed that the PCBs were dissolved in the
groundwater. However, the evaluation of this pathway looked
at volatilization from both groundwater and soil. In the
soil volatilization analysis the equilibrium partitioning
did account for the propensity for PCbs to bind to soil
particles. The chronic daily intake (CDI) associated with
soil volatilization was approximately 50 times greater than
the COI associated with the groundwater volatilization.
46
-------
Therefore, the risks associated with PCBs for this pathway
are driven by soil volatilization, and the effect of
assuming all PCBs are dissolved in the groundwater has no
impact on the risk number.
With regard to the overestimation of the indoor air
concentration of PCBs inside the facility, the Endangerment
Assessment presents a discussion of a comparison of
predicted to measured air concentrations of PCBs inside the
Grant Gear facility which showed that the predicted
concentration was -4 times higher than the average measured
value. An agreement within a factor of 4 between measured
and modeled air concentrations based on short-term (8-hour)
average air concentrations is generally considered a
reasonable agreement, due to the fluctuating nature of air
concentrations in the short term. Therefore, EPA believes
that the long-term air concentration estimates provided by
the modeling are representative of the air concentrations
inside the Grant Gear facility.
12. It is not credible to assume that the aquifer would replace
the municipal water supply or that if it. did, that water
would be untreated.
EPA Response: As described in detail in EPA's response to
comment A.I, the groundwater cleanup approach for the Site
is based upon EPA's Groundwater Protection Strategy and
federal and state groundwater classification schemes. This
approach which incorporates classification of on-site
groundwater as a potential future drinking water source is
consistent with EPA's guidance on remediation of
groundwater. Under EPA's guidance documents and policies,
it is credible to assume that the aquifer would replace the
municipal water supply, for potable and non-potable uses and
that if it did, that water would be untreated. Of
particular note is the continuing increased demand for water
supplies, thus negating the approach to "write off" aquifers
that are currently on municipal water supply systems,
through implementation of no action alternatives.
13. EPA's analysis is flawed with respect to changes in the land
use of the industrial park at the site to residential
housing.
EPA Response: As stated in the "Supplemental Risk
Assessment Guidance for the Superfund Program", EPA Region I
(June 1989), Region 1 has maintained the position that
future land use at most Superfund sites could be
residential. Based on this guidance, the EA evaluated
exposure scenarios for Grant Gear and adjacent commercial
properties under a future residential use. However, EPA, in
consultation with the state, have determined that for this
47
-------
site it is highly unlikely that areas within Grant Gear and
adjacent commercial properties will ever be rezoned for
residential use. Therefore target ceanups levels for soils
located at Grant Gear and surrounding commercial properties
were based upon protection of workers from exposure to
contaminated soils, reflecting the current and future
commercial use of this area.
14. The Agency failed to conduct an environmental risk
assessment of the site.
EPA Response; Chapter 6 of the Endangerment Assessment
provides a detailed environmental assessment of the site.
15. The lack of a baseline on the flora or fauna will make it
difficult, if not impossible, for EPA to attain the stated
goals of wetlands mitigation/restoration/enhancement.
EPA Response! Environmental characteristics of the wetland
in Meadow Brook was investigated and the results presented
in Section 3.6 of the Remedial Investigation. As part of
this assessment, the nature of the wetland in Meadow Brook
was described through identification of flora and fauna and
evaluation of the hydrologic characteristics of the wetland
habitats. An environmental risk assessment was performed
and presented in the Endangerment Assessment using site-
specific information on wetland flora and fauna identified
during the on-site evaluations.
16. EPA has improperly determined that an environmental risk
existed at the site based on a sediment quality criteria
number.
EPA Response; In response to growing concerns on the
effects contaminated sediments have on the Nation's waters,
EPA has been actively pursuing the development of numerical
sediment quality criteria (SQC). The regulatory authority
to develop SQC has been given to EPA by the Clean Water Act
of 1977, its reauthorization in 1987 and other legislation.
This effort has been conducted in cooperation with numerous
Agency Offices, contractors and university scientists.
A variety of approaches have been proposed to develop SQCs,
three of which are being considered for numerical SQC on a
national level: a water quality criteria approach, an
approach involving equilibrium partitioning (EP), and an
approach involving body burden effect relationships
(bioassays). The EP approach currently has had a
substantial amount of scientific and economic support.
Preliminary SQC have been derived for several contaminants
including PCBs using this method.
48
-------
The EP methodology was reviewed by the Sediment Criteria
Subcommittee of the Science Advisory Board in February,
1989. Supporting documents provided to the Board indicate
that sensitivities of benthic species are sufficiently
similar to those of water column species to tentatively
permit the use of water quality criteria for the derivation
of sediment quality criteria for non-polar organics by the
equilibrium partioning approach. Thus, while it is EPA's
opinion that any one method that assesses sediment
contamination would not be sufficient to address all
contaminated sediment problems, the EP approach in
establishing SQC presently has enough scientific validity to
justify its use in environmental risk assessments to assess
endangermentto aquatic organisms exposed to contaminated
sediments.
Site-specific SQCs for PCBs, based on the EP approach, were
compared to contaminant sedimentary levels to determine
environmental risks at the Norwood PCB Site. In this case,
the use of the SQCs as a to-be-considered (TBC) is
appropriate because no federal or state ARARs exist for
assessing risk or establishing target cleanup levels for
contaminated sediments. As stated in the ARARs guidance
document "CERCLA Compliance with other Law", in many
circumstances TBCs will be considered along with ARARs as
part of the site risk assessment. The guidance further
specifies that cleanup goals' for some substances may have to
be based on nonpromulgated criteria and advisories rather
than on ARARs when ARARs do not exist for those substances.
17. EPA's selection of cleanup goals rests on a highly
questionable interpretation of EPA's PCB Spill Policy.
EPA Response: The selection of cleanup levels for the Site
was consistent with EPA's guidance documents including
"CERCLA Compliance with Other Laws Manual" and "Guidelines
in the Superfund Public Health Evaluation Manual." EPA's
response to comments A.19. describes the rationale on the
use of TSCA PCB Spill Policy in the selection of cleanup
levels for floor surfaces and soils under paved surfaces.
EPA believes that consid- eration of the TSCA PCB Spill
Policy in establishing such cleanup levels was appropriate.
18. EPA's commitment to spend $2 million on control of pollutant
migration is arbitrary and capricious. CERCLA's preference
for treatment is not so overriding that it can be used to
overcome a situation of technical infeasibility,
particularly in a situation where there is a municipal water
supply.
EPA Response: Control of further mirgration of contaminants
in groundwater is only one of three remedial response
49
-------
objectives set for the management of migration alternatives.
A detailed explanation of all management of migration
remedial response objectives and the rationale behind EPA's
selected groundwater collection and treatment components of
the selected remedy is presented in EPA's responses to
comments A.I and A.2.
19. EPA has violated the 404 guidelines by failing to prepare an
analysis of the viability of other practicable remediation
alternatives to excavation of the brook which would not
destroy the habitat.
EPA Responset The Feasibility Study (FS) addressed a range
of potential remedial actions including containment of
sediments, excavation of sediments and minimal no-action
which would not involve excavation of sediments. Each of
these potential remedial actions was evaluated according to
the criteria identified in the FS. In addition, evaluation
of the alternatives considered the existing plans of the
Town of Norwood to perform modifications to Meadow Brook for
the purposes of flood control. Based on this evaluation and
analysis, EPA has determined that, for this site there is no
practicable alternative to excavation that would achieve
site goals but would have less impact on the aquatic
ecosystem. Unless soils and sediments greater than the
target levels are excavated, the contaminants in the soils
and sediments would continue to pose unacceptable human
health and environmental risks.
20. The selection of solvent extraction technology for this site
contravenes CERCLA and the NCP. Solvent extraction cannot
be said to be more readily implementable and cost-effective
than other technologies considered since its
implementability is currently unknown, and the technology
has not been tested.
EPA Response: The analysis of solvent extraction
technologies was based on the selection of solvent
extraction using triethylamine (TEA) as a representative
process option. Solvent extraction using TEA has been
applied to the on-site treatment of petroleum re-refining
sludges containing PCBs at the General Refining Co. site in
Savanna, Georgia during 1986-1987. An EPA report of that
full-scale application indicated that bench-scale
treatability studies showed good correlation with full-scale
results. The vendor of the TEA solvent extraction process
has completed over 80 bench-scale treatability tests on
waste materials. As indicated in the FS, bench-scale
treatability studyresults performed on a variety of soils
by the vendor of the TEA solvent extraction technology were
used in the evaluation of technical feasibility. This
information was deemed adequate for EPA to decide that the
50
-------
solvent extraction technology could perform adequately over
a range of soil conditions and concentrations and that order
of magnitude cost estimates (i.e. +50/-30 percent) required
for the FS could be made. Since site-specific media samples
were not used in the vendor's treatability studies, a site-
specific pilot-scale treatability study was included as a
pre-design task of the selected remedy to verify attainment
of extraction efficiencies and performance necessary to meet
cleanup objectives.
21. To perform pilot studies of remedial technologies that are
candidates for site cleanup after a ROD is signed is
inconsistent with NCP and CERCLA and an arbitrary and
capricious action on the part of the Agency.
EPA Response; The Superfund Remedial Design and Remedial
Action Guidance Manual (OSWER Directive No. 9355.0-4A)
indicates in Section 2.3.2. that remedial actions involving
on-site treatment or disposal of contaminated wastes may
require additional studies to supplement the technical data
available from the RI/FS so that the optimum treatment or
disposal methods may be determined. Additional studies
could include bench and pilot scale studies. Since
treatability studies were not conducted during the RI/FS,
these additional studies on solvent extraction will be
conducted as part of remedial design/remedial action (RD/RA)
for the source control portion of the remedy.
The Guidance for Conducting Remedial Investigations and
Feasibility Studies Under CERCLA (OSWER Directive No.
9355.3-01) indicates in Chapter 5 that the decision to
conduct treatability must be made by weighing the cost and
time required to complete the investigation against the
potential value of the information in resolving
uncertainties associated with selection of a remedial
action. In some situations, treatability investigations may
be postponed until the remedial design phase. The decision
process for treatability investigations includes 1)
determining data needs, 2) reviewing existing data on the
site and available literature on technologies to determine
if existing data are sufficient to evaluate alternatives.
The Guidance further states that pilot-scales studies should
be limited to situations in which bench-scale testing or
field sampling of physical or chemical parameters provide
insufficient information from which to evaluate an
alternative. Because of the time required to design,
fabricate, and install pilot-scale equipment and to perform
tests from a reasonable number of operating conditions,
conducting a pilot study can add significant time and cost
to the RI/FS.
For the Norwood PCB Site, EPA believes that the existing
51
-------
particular, described in Chapter 6 of the FS (Ebasco, 1989)',
available test data on the effectiveness of the solvent
extraction process from trectability studies performed on
PCB-contaminated wastes were presented in the detail
evaluation of solvent extraction. EPA believes that for
this Site, an evaluation of test data from treatability
studies on solvent extraction performed on wastes similar to
solids found at the Site and existing site characterization
'data provides sufficient information from which to evaluate
alternatives without the need to perform a pilot study
during the RI/FS. Therefore, conducting a pilot study on
solvent extraction during the RI/FS would have added an
unreasonable time delay. A pilot study will be performed as
part of the source control component of the remedy. In
general, data necessary for remedy selection is distinct
from that required for remedial design. Performing
treatability studies at every Superfund site during the
RI/FS for a significant number of remedial alternatives
would be extremely time-consuming and expensive.
22. The FS fails to analyze other remedial technologies in the
detail that is required for screening including
bioremediation.
EPA Response; The Feasibility Study presented the results
of technology screening at the site based on effectiveness,
implementability, and relative cost. The screening was
performed according to Section 300.68 of the National
Contingency Plan (NCP), in conjunction with the EPA guidance
document entitled "Guidance for Conducting Remedial
Investigations and Feasibility Studies under CERCLA" (OSWER
Directive 9355.3-01, Interim Final, October 1988). The
summary results of technology screening are presented in
Chapter 4 of the FS. Detailed screening of the remedial
technologies identified in Chapter 4 of the FS are presented
in FS Appendix A. EPA believes that the FS for the Norwood
PCB site adequately screened alternatives. In particular,
bioremediation technologies were screened out because the
uncertainties associated with these "emerging" technologies
were greater than solvent extraction and other innovative
technologies. The problems associated with bioremediation
are:
1. Maintenance of the proper environment for the micro-
organism populations;
2. High energy requirement to break down large complex
molecules such as PCBs. This translates into longer
retention tines to complete the reaction;
3. Without agitation provided by a reactor, mass transfer
is greater reduced, thus reducing the speed and
52
-------
effectiveness of the reaction;
4. Variable soil conditions of the site may result in
inconsistent flushing, thereby limiting direct contact
between micro-organisms and contaminants (PCBs), and;
5. If bioremediation was implemented using landfarming
technique, large areas of land would be needed to set
up and maintain these plots. As stated in the FS and
the ROD, the land surrounding the Norwood site is
predominantly wetland resource areas and commercial
properties thus, limiting the implementability of
certain technologies requiring large areas of land,
including bioremediation.
23. There appears to be a number of inconsistent estimates of
the quantity of soils that are contaminated at the site,
which cast doubts on the cost estimates for the cleanup.
EPA Response; The initial calculations of the soil volume
at the site were developed for various PCB concentrations
including 10 ppm, 25 ppm, 50 ppm, 100 ppm, and 500 ppm, and
for various depths including surface soils only, excavation
to the ground water table, and complete excavation of all
contaminated material. Thus, a matrix of volumes and
associated costs had to be developed for each proposed site
activity dependent upon the selected cleanup concentration-
and depth of excavation. In narrowing these various volume
calculations down to the selected cleanup level, EPA made
several decisions regarding cleanup concentrations, depth of
excavation, and associated assumptions that differed from
the assumptions used to originally calculate the soil and
sediment volumes presented in the RI report. These
assumptions included:
o The PCB target level within the Grant Gear property was set
at 10 ppm, and the target level north of the Grant Gear
fence, along Meadow Brook, was set at 1 ppm.
o The uncontained portions of zones B, C, and D will be
excavated.
o Only soils and sediments contaminated with PCBs above 10 ppm
will be treated. Those soils and sediments with PCB
concentrations between 1 ppm and 10 ppm will be placed on
the Grant Gear property as fill.
o The maximum depth of excavation will be to the ground water
table which is estimated to be approximately 8 foot below
grade across the site.
When a decision was reached as to the selected PCB cleanup
53
-------
When a decision was reached as to the selected PCB cleanup
criteria, and the depth of excavation at the site, the
volumes were recalculated and recheclced. Thus, the volumes
and costs presented in the Final FS are correct. These
volumes are as follows, noting that the soil volume includes
the dredge pile material:
Total soil and sediment volume to be treated (PCB > 10 ppm)
28,455 cy
Total soil and sediment volume to be placed on site without
treatment (PCB >l, < 10 ppm)
- 5,090 cy
Total soil and sediment volume requiring excavation
- 33,545 cy
The proposed plan and the ROD may present a rounded figure
of these volume estimates.
24. Unit rates used in the cost estimates for all soil/sediment
remediation alternatives appear to be at the low end of
estimated ranges, thus assuming best case operating
conditions and results.
EPA Response; Cost estimates developed and presented in the
feasibility study are a direct result of vendor quotes or
have been taken from reliable sources (i.e., Means Site
Work) and have been modified to reflect the additional costs
associated with handling hazardous material. All
alternative costs were developed in the same manner and to
the same degree of accuracy. The costs associated with the
standard construction activities (i.e., excavation,
materials handling, etc) were all increased by a safety
factor to account for increased health and safety conditions
necessary for work with hazardous material. When vendor
quotes were used, as in the case of the solvent extraction,
incineration, and dechlorination costs, a cost slightly
higher than the middle of the quoted range was utilized. In
addition, the type of conceptual design costing included in
a feasibility study is intended to be within a -30/+50 %
range and should not be considered final as there may be
many things overlooked at the conceptual stage that will
become apparent during design of the alternative. The costs
presented at the FS stage are merely used as a comparison
between potential remedial alternatives. Since all the
alternatives have been developed to the same degree of
accuracy, an increase in the costs of all the alternatives
would not change their cost-effectiveness in relationship to
each other.
25. The groundwater remediation technology is based on only one
54
-------
set of groundwater elevations.
EPA Response: Groundwater elevations in the water table and
bedrock aquifer systems were measured on May 11, 1988,
August 11, 1988, March 15, 1989 and April 4, 1989. The
results of the measurements obtained at these times were
presented on Table 2-3 of the RI. Results from the series
of ground water elevation measurements performed were
plotted and showed similar trends in flow direction and
gradient. Seasonal variation in ground water elevations
were considered in the formulation and evaluation of the
ground water remediation technologies during the FS.
26. Given the levels of PCBs in the stream and the cost estimate
for constructing the liner, it seems, wholly unreasonable to
pursue this particular remedy.
EPA Response; EPA concurs with the determination that major
disadvantages are associated with construction of a liner in
Meadow Brook as a source control alternative. Specifically,
containment of Meadow Brook by construction of a liner would
not comply with the statutory preference for treatment that
permanently and significantly reduces the toxicity, mobility
and volume of wastes. There is also an uncertainty in the
long-term effectiveness of a containment option and the
possibility of future risks and costs if the liner were to
fail. Based in part on the reasons described above, EPA did
not select construction of a liner in Meadow Brook as the
source control alternative for remediation of contaminated
sediments.
27. The fact that EPA contemplates a pilot study, with a default
position causing incineration to be substituted at some
later date if solvent extraction proves to be infeasible for
the site, is an arbitrary and capricious mishandling of the
RI/FS process.
EPA Response; As explained in EPA's response to Comment
B.21., EPA believes that performing a pilot study on solvent
extraction as part of remedial design/remedial action is
consistent with guidance documents including "Guidance for
Conducting Remedial Investigations and Feasibility studies
Under CERCLA" (OSWER Directive No. 9355.3-01).
Furthermore, the "Interim Final Guidance on Preparing
Superfund Decision Documents" (OSWER Directive No. 9355.3-
02) states that where an innovative technology is selected
and its performance potential is to be verified through
additional testing conducted during RD/RA, a proven -
treatment technology may be included in the Proposed Plan
and ROD as a contingency remedy. In the event that test
results indicate that the innovative technology will not
55
-------
fulfill it» performance expectations at that site or
operable unit, the contingency remedy could be implemented.
As described in the FS and Section XI of the ROD, based on
the performance potential of solvent extraction, this
innovative technology provides the best balance of tradeoffs
from among the options considered, despite its
uncertainties. Congress provided support for selecting
innovative technologies in such instances in CERCIA section
12l(b)(2), which states:
The President may select an alternative remedial action
meeting the objectives of this subsection whether or hot
such action has been achieved in practice at any other
facility or site that has similar characteristics.
28. Few, if any, tests have been conducted with the RCC B.E.S.T.
process to assess its contacting and extraction efficiency.
Several scale up issues cannot be addressed in small scale
test.
EPA Response; The BEST solvent extraction process has been
utilized in a full scale cleanup at a Superfund site in
Savannah, Georgia. In addition, RCC has completed over 80
bench-scale treatability tests with a variety of waste
material and contaminants. Reported PCB removal
efficiencies are typically greater than 99%. RCC is also
currently operating a pilot-scale unit at their facility in
Bellevue, Washington. Comparison of data between the bench-
scale and full-scale operations at the Savannah site
indicated a good correlation between the two, thus, scale up
from bench-scale to full-scale is not anticipated to be a
problem. While existing bench scale test results on a
variety of soils and PCB concentrations have indicated
adequate removal efficiencies for site concentrations,
treatability tests will be performed on the material
existing at the site prior to the final design of the
remedial alternative.
29. An incremental 20% allowance (in addition to the base
contingency of 20%) should be included for solvent
extraction given the limited commercial experience it has
compared to incinerators.
EPA Response; The solvent extraction process does have
limited commercial experience. Treatability tests would be
required to ensure that the process will treat the site soil
and sediment to the specified concentration levels. If the
process is proven to be effective in treating the site
materials, the actual treatment of the material is not
expected ^p pose exceptional problems. The site activity
anticipated to be the most troublesome will be the materials
56
-------
handling and preparation required prior to the utilization'
of any of the solids treatment options. Both the solvent
extraction and incineration process require solids to be
screened and over-sized solids to be either crushed or
disposed via an alternate method such as landfilling. This
.solids preparation process is often difficult and may be
costly, however, the process would be very similar for both
the solvent extraction and incineration treatment
operations, thus, both options have identical scope
contingency factors.
30. Fugitive dust emission can be a problem with the dry solids
produced in the RCC process.
EPA Response; Water from the solids is separated and
collected during the operation of the RCC process. This
water is passed through a carbon adsorption unit to remove
contaminants. Prior to discharging the treated solids, a
portion of this treated water is mixed into the solids to
bring the water content to approximately 10%. This
mitigates the potential fugitive dust emissions problem, and
creates a material that is much easier to handle.
31. The observation that on-site incineration is readily
implementable overstates the current state of knowledge and
is an abdication of EPA's responsibility in overseeing the
RI/FS process.
EPA Response; Based mostly on the limited availability of
vendors for the solvent extraction and dechlorination
treatments, on-site incineration is described as readily
implementable when compared to the other treatments (solvent
extraction, dechlorination) evaluated in detail in the FS.
Both pilot and full-scale mobile PCB incinerators are
available and have been used successfully at other hazardous
waste sites. Experience with this technology is more
extensive than that of the innovative technologies.
EPA owns a mobile rotary kiln incinerator which consists of
specialized equipment mounted on 4 trailers. System
performance is monitored through instruments and automatic
safety shutdown controls. This mobile unit has demonstrated
a greater than 99.9999% destruction and removal efficiency
at a trial burn on liquids and solids contaminated with
dioxins. It has been operated over the past 2 years for
cleanup of dioxin-contaminated liquids and soils from
numerous dioxin sites in Missouri. To date, over 2 million
pounds of solids and 18,000 gallons of liquids have been.
processed.
Ogden Environmental Services, Inc. owns and operates a
57 ,
-------
mobile circulating bed combustor incinerator for th«
treatment of hazardous wastes. Test results from the
company's pilot plant indicate that the TSCA requirement for
99.9999% destruction and removal efficiency was achieved for
soil contaminated with 10,000 ppm of PCBs.
Under EPA's Superfund Innovative Technology Evaluation
(SITE) program, a full-scale and a pilot-scale infrared
system have been demonstrated. The full-scale system
demonstration was conducted at the Peake Oil Superfund site
in Florida. A total of 7,000 cubic yards of waste material
contaminated with PCBs and lead was processed. During the
trial burn that was conducted, extensive sampling was
included for the solid waste feed, stack gas, ash, scrubber
liquid and water influent, scrubber effluent solids, and
ambient air. The final technical report on the
demonstration will document the entire mechanical operating
history of the system and the problems that were encountered
in operating this type of full-scale system. The pilot-
scale system demonstration was conducted at the Rose
Township - Demond Road Superfund site in Michigan.
Approximately 10 cubic yards of contaminated soils were
treated utilizing a blend of the most highly PCB- and lead-
contaminated soils at the site. The final technical report
will document information similar to the full-scale
demonstration.
32. Additional analysis of the types of incinerators and
problems with each needs to be conducted before incineration
could be selected as a treatment technology at this site.
EPA Response; As stated in EPA's response to comment B.21,
EPA believes that the existing database is adequate to
support EPA's remedy selection of on-site incineration as
the backup treatment for the remediation of soils, sediments
and dredge pile materials. Identified concerns regarding
the types of incinerators and problems with each needs are
concerns that may be addressed during the remedial design
process, and are not essential to the remedy selection of
on-site incineration (back-up treatment).
Incineration is a proven technology which will meet ARARs
and will be protective of human health and the environment.
Although design work is needed, there is no basis for any
expectation that new information will change EPA's
conclusion.
EPA agrees that incineration is not appropriate at every
site. EPA considered a variety of factors in determining
that incineration could achieve the desired clean-up goals
at the Norwood PCB Site. These factors included:
58
-------
1. Variability of waste feed composition: Variability in
particulate size will be addressed by design of
appropriate pretreatment and materials handling
processes. Variability in feed contaminant
concentrations will be addressed by soil blending,
particularly in cases where extremely high PCB
concentrations are found.
2. Nature of contamination: There is not historical
evidence of disposal of metal-bearing wastes.
Contaminants identified at the Norwood PCB Site are
predominantly organic and are suited to destruction by
thermal treatment. EPA does not believe there are high
levels of metals at the site. Appropriate design of
air emissions controls and ash disposal practices can
be imposed to address metals levels.
3. Depth of contamination: Soil excavation below the
water table becomes complex and expensive and generally
complicates material handling procedures. Soil
moisture content affects the fuel consumption rate of
the incinerator. EPA believes that limiting excavation
to the water table for the majority of the site
addresses a number of technical implementation
concerns.
4. Climate: A mobile incinerator may be more susceptible
to climate considerations than stationary incinerators
located in close proximity to the site. However,
appropriate weather-proofing (e.g., temporary structures
to protect the incinerator, area of excavation, and/or
materials handling and preparation area) would mitigate
climatic impacts. EPA does not consider the weather to
be an insurmountable obstacle to the implementation of
on-site incineration.
Other factors which will need to be considered during
remedial design of the incinerator include, but are not
limited to, the following: non-combustible fraction of
solids, fraction of ash as particulate; combustible solids
heating value; incinerator and afterburner operating
temperatures; and residence time. Treatability testing will
be required to determine appropriate operating parameters
for the incinerator as well as ash/decontaminated soil
handling procedures.
C. Comments from Mintz. Levin. Cohen. Ferris. Glovskv and
Popeo. P.C.. on behalf of Grant Gear
1. The target cleanup levels recommended in the Ebasco FS are
based on unsupported risk targets.
59
-------
PCS-contaminated soil on the Grant Gear property are based
on a target excess lifetime cancer risk of 10'. The
exposure assumptions used in the Endangerment Assessment for
direct contact under future land use conditions were
combined with the PCB cancer potency factor of 7.7 (mg/kg-
day) to determine the target cleanup level for PCBs in
soil. The use of the 7.7 (mg/kg/day) cancer potency
factor is consistent with current EPA guidance and
operational procedures. The EPA Carcinogen Assessment Group
(EPA 1989. Integrated Risk Information System [IRIS].
Environmental Criteria and Assessment Office, Cincinnati,
Ohio) calculated the oral potency factor of 7.7 (mg/kg-day)"
for PCBs used in the Endangerment Assessment and cleanup
level calculations. This number was intended to represent
all PCBs when quantifying the potential health risks from
any PCB mixture. Therefore, the calculated target cleanup
level for PCBs, which is based on the use of a 7.7 (mg/kg-
day) cancer potency factor for PCBs, is supported by
current EPA guidelines.
2. The soil cleanup target level of 10 ppm appears to have been
chosen with the objective of maximizing the amount of
cleanup rather than with any associated risk in mind.
EPA Response: The PCB cleanup level of 10 ppm is a risk-
based level based on the site-specific risk assessment.
Potential exposures and risks were assessed for workers,
through dermal contact with and incidental ingestion of
chemicals of potential concern in surficial soils at
commercial properties within the site boundaries. The
maximum incremental carcinogenic risk for a worker in the
vicinity of the Grant Gear facility, coining in contact
(landscaping, storing) with contaminated surficial soils was
8 x 10 . Total PCBs and total carcinogenic PAHs contribute
the majority of the total risk. - Based on the results of the
site-specific risk assessment for the protection of workers
of Grant Gear and adjacent commercial properties, soil
cleanup levels of 10 ppm of total PCBs and 6 ppm of total
carcinogenic PAHs have been selected. The assumptions used
to calculate these soil target levels are presented in Table
14 of the ROD, and reflect the manufacturing current and
future land use of this area.
Reducing the concentration of residual contaminants to these
levels will result in an incremental carcinogenic lifetime
risk level of 1 x 10 under both current and future use
site conditions.
3. The RI/FS and EA address surface and air contamination
within the Grant Gear building but the RI/FS and proposed
remedies completely disregard the source of this
contamination.
60
-------
contamination.
EPA Response; As described in EPA's response to Comment
B.7., the degree to which sources of PCBs within and outside
the Grant Gear building contribute to PCB level detected in
the air and on equipment surfaces within the Grant Gear
building cannot be exactly quantified. However, based on
the results of the RI, the following may be contributing
sources: 1) exposed contaminated soils in the exterior of
the building; 2) contaminated sediments and water within the
drainage system; and 3) contaminated surfaces with the Grant
Gear building.
The selected remedy addresses all suspected sources, as
described above, of surfaces and air PCB contamination
within the Grant Gear building. These source control
components are described below: 1) component (b) of the
selected remedy - excavation, treatment, on-site disposal,
of contaminated soil within the Grant Gear property and soil
covering and revegetation or repaving of excavated areas;
and 2) component (d) of the selected remedy - flushing
and/or containment and replacement of portions of the Grant
Gear drainage system and decontamination of contaminated
machinery, equipment and floor surfaces within the Grant
Gear building.
4. By failing to address the source of PCB contamination, EPA
has in effect chosen a No Action alternative with respect to
this source which seems to assume the building will operate
as a cap.
EPA Response; As described in EPA's response to Comment
C.3., EPA believes that the selected remedy addresses all
identified sources of PCB contamination of equipment
surfaces and of airborne PCB levels within the Grant Gear
building.
With respect to soils beneath the building, site
investigations have indicated on average relatively low
levels of PCBs, when compared to all other soils within the
Grant Gear property. A maximum value of 99 ppm of PCBs was
detected in soils beneath the building. This value is
greater than soil target levels of 10 ppm PCBs and 25 ppm
PCBs established for soils on Grant Gear and adjacent
commercial properties and for soils outside the Grant Gear
property under paved areas, respectively. EPA has
determined that because of extreme disruption to and damage
of the Grant Gear building, it is impracticable to remove
Grant Gear's floor in order to remediate the underlying
soils. Instead, EPA's selected remedy incorporates
institutional controls which will be designed to ensure
disturbance of untreated subsurface soils beneath the Grant
61
-------
EPA believes this approach la protective or human health ana
the environment because no risk is associated with these
contaminated soils based on incomplete exposure pathways.
5. The proposed wipedown remedy requires continuing operations
and maintenance that are difficult to control over time.
EPA Response; Comments submitted on behalf of Grant Gear,
indicate that a wipedown and vet-sweeping floors measures
performed within the plant have been effective in reducing
PCB levels within the plant. EPA believes that component
(d) of the selected remedy which includes solvent washing of
floor and equipment surfaces will be equally effective in
reducing indoor PCB levels.
As an additional ensurance of the long-term effectiveness of
the decontamination of floor and equipment surfaces, 5 year
reviews performed at the site will include wipe sampling of
equipment and floor surfaces within the plant areas of Grant
Gear. Future remedial action, including source control
measures, will be considered if the long-term monitoring
program determines that unacceptable risks to human health
and/or the environment are posed by exposure to site
contaminants.
6. The FS omits the possibility that, at some point, the Grant
Gear building will either partially or totally be demolished
which would present significant technical difficulties in
demolishing and disposing of building structures.
EPA Response; As described in Section VII of the ROD, the
preferred alternative, as described in the Proposed Plan has
been amended to include decontamination of floor surfaces.
Therefore, the selected remedy specifies a number of
components relating to remediation of the Grant Gear
building including decontamination of equipment and floor
surfaces and flushing/cleaning and containment of the
drainage system. Any disposal of building structures in the
future would have to be performed in accordance with state
and federal regulations. EPA anticipates that any residual
PCB levels on building structures would not be greater than
50 ppm and not subject to TSCA PCB Disposal regulations.
7. To the extent that any contamination of the floor slab is
greater than or equal to 50 ppm, the remedy selection does
not meet EPA TSCA regulation or its PCB Spill Cleanup
Policy, respectively.
EPA Response; As described in component (d) of the selected
remedy, decontamination of floor surfaces within the plant
areas of the Grant Gear building will be performed according
to requirements specified in the EPA TSCA PCB Spill Cleanup
»
62
-------
to requirements specified in the EPA TSCA PCB Spill Cleanup
Policy, 40 C.F.R. 761, Subpart G. In particular, floor
surfaces will be cleaned by double washing with an
appropriate solvent and rinsed to an appropriate performance
standard, as measured by the standard wipe tests.
The PCB Disposal Requirements promulgated under TSCA do not
require the removal of PCBs and PCB Items from service and
disposal for disposal occurring prior to the effective date
of the regulations. However, these regulations are
applicable to PCB-contaminated solid and liquid wastes
generated as a result of decontamination of contaminated
surfaces. All solid wastes generated from decontamination
of surfaces will be treated in an off-site incinerator
meeting the standards of 40 C.F.R. § 761.69.
8. RCRA requirements for closure and post-closure should be
adhered to with respect to the concrete plant floor.
EPA Response; RCRA Regulations for floor surfaces are not
applicable nor relevant and appropriate because levels on
floor surfaces are not sufficiently similar to hazardous
wastes under Massachusetts Hazardous Waste regulations.
Rather, the cleanup levels specified in the TSCA PCB Spill
Cleanup Policy have been designed to apply to contamination
of floor surfaces and matches the circumstances of the site.
9. The potentially devastating impact on Grant Gear raises a
question whether the remedies involving soil excavation are
implementable.
EPA Response; It is recognized that the space available for
use on the Grant Gear property is limited. The
availability of work space was considered in the Feasibility
Study when evaluating alternatives involving soil
excavation. As a result of these evaluations, staging of
soil excavation and treatment activities will be carefully
planned during remedial design to reduce the short-term and
long-term impact on Grant Gear operations. During the
remediation process, some temporary modification of existing
land use within the Grant Gear property can be anticipated.
However, the temporary modifications in existing land use.
required during soil excavation were not deemed severe
enough or of a sufficiently long duration to preclude
implementation or business relocation.
10. The FS is deficient in failing to consider relocation of
Grant Gear as part of response action by EPA or the Federal
Emergency Management Agency.
EPA Response: . The Grant Gear Building FS (COM, August 1989)
identified and screened seven response alternatives. Of
63
-------
these alternatives, Alternative B-6 consisted of Demolition
of the Grant Gear building. Although not explicitly stated,
relocation of Grant Gear would be a component of this
alternative. Given the total destruction of the building,
relocation of the Grant Gear business would be required on a
long-tern or permanent basis depending upon the feasibility
and cost of reconstructing a.building on-site upon
successful implementation, of the remedial action.
The other six alternatives identified in Chapter 4 of the FS
would not incorporate relocation of Grant Gear as a
component because these alternatives would not result in
damage to the building to the extent that the building would
be uninhabitable.
11. The remedy should include the permanent relocation of Grant
Gear.
EPA Responsei The terms "remedy" or "remedial action" is
defined under CERCLA § 101(24) to include costs of permanent
relocation of residents and businesses where the President
determines that, alone or in combination with other
measures, such relocation is more cost-effective than and
environmentally preferable to the transportation, storage,
treatment, destruction, or secure disposition off-site of
hazardous substances, or may otherwise be necessary to
protect the public health or welfare.
This alternative would not be more cost-effective than other
alternatives evaluated because relocation alone would not
result in any reduction of current on-site risks but would
be excessively costly. There is no advantage to be gained
by such relocation, based on its effectiveness, because
contaminant levels within the building would not be reduced
to acceptable target cleanup levels. If demolition of the
building was combined with relocation of Grant Gear,
excessive costs would be associated with demolition of all
building structures and disposal or decontaminated of roofs,
walls, drainage piping, floors and other building structures
and combined with the costs of relocation would be orders of
magnitude greater than other alternatives evaluated in the
FS. Additional disadvantages associated with demolition are
as follows:
1) off-site disposal of building least preferred under
CERCLA
2) implementability constraints relating to the logistics
of demolishing a large building contaminated with
residual levels of PCBs
3) transportation and disposal constraints associated with
handling of significant volume and mass of building
structures.
64
-------
Comments submitted on behalf of Grant Gear, state that a
decision to provide permanent relocation may be based on
findings that exposure, to hazardous substances from the
site after remedial actions, has a significant likelihood of
causing or contributing to adverse health effects or
exacerbating existing conditions.
EPA has determined that the selected remedy, as described in
Section X. of the ROD, will be protective of human health.
The remedy at this Site will permanently reduce the risks
presently posed to human health and the environment through:
1) solvent extraction of PCBs and other contaminants in
soils, sediments and dredge pile materials and off-site
incineration of PCB-contaminated oil extract;
2) flushing and containment of PCB-contaminated sediments
in the Grant Gear drainage system to prevent further
contamination of Meadow Brook;
3) decontamination of equipment and floor surfaces within
the Grant Gear building;
4) extraction and treatment by air stripping of
contaminated groundwater to contain the contaminant
plume and restore groundwater quality; and
5) institutional controls.
Treatment of contaminated soils and dredge pile materials
will reduce risks associated with exposure to contaminants
from direct contact with and ingestion of soils and dredge
pile materials from a maximum incremental carcinogenic risk
of 8xlO"3 at Grant Gear to less than IxlO"5. In addition, 10
inches or clean soil will be placed over areas where treated
soils will be disposed to further reduce the potential risks
associated with direct contact with or ingestion of site
contaminants.
The Grant Gear office and machinery equipment surfaces
cleanup level to be attained by the decontamination of these
surfaces, will reduce risks to Grant Gear workers in direct
contact with such surfaces to a maximum carcinogenic risk of
IxlO"5. Reducing the levels of floor contaminants will
minimize the potential for migration of PCBs into the air,
and subsequent recontamination of equipment and machinery.
The combination of flushing and containment of the Grant
Gear drainage system will virtually eliminate the continued
release of hazardous substances to Meadow Brook, especially
PCBs, so as not to recontaminate the stream sediments and
reintroduce the risks from sediments that are being
remediated by this remedy.
Risks from exposure to contaminated groundwater, via
65
-------
ingestion, will be permanently and significantly reduced as
a result of groundwater collection and treatment. Cleaning
the contaminated groundwater at this Site will promote
restoration of groundwater quality and prevent off-site
migration of contaminated groundwater. EPA has determined
that it is technically infeasible to attain a health-based
groundwater cleanup level for PCBs. Groundwater within the
zone of contamination is not currently used for drinking
water sources. Institutional controls will be implemented
to ensure that in the future, drinking water wells will not
be drilled within the zone of PCB groundwater contamination.
EPA believes that there is not significant likelihood of
causing or contributing to adverse health effects or
exacerbating existing conditions once remedial action is
complete. Therefore, based on this determination and all
other reasons stated above, relocation of Grant Gear is not
justified.
12. The ROD should allow enough designing flexibility to
accommodate differences between the ENSR proposal (Grant
Gear's contractor) and the COM proposal (EPA's contractor).
EPA Response: As stated in the comments submitted by Grant
Gear, ENSR's conclusions and recommendations are
conceptually in accord with those of the principal remedy
for the drainage system (flushing/cleaning). As part of the
soil component of the remedy, .EPA has also specified that
best management practices and engineering measures, such as
installation of curbing and sweeping of pavement surfaces
will be taken to prevent further contamination of Grant
Gear's drainage system including roof surfaces. Specific
measures and implementation requirements will be finalized
during remedial design.
13. The ROD should allow for incorporation of a requirement
greater than the limits of detection for PCBs if that should
be adopted instead.
EPA Response; EPA, in consultation with MA DEP, established
a cleanup level of 0.5 ppb of total PCBs in the effluent
from the Grant Gear drainage system. This value is based on
a practical detection limit for the analysis of PCBs and was
specified in Grant Gear's draft National Pollutant Discharge
Elimination System (NPDES) permit proposed in 1988.
As stated above, the PCB cleanup Isvel of 0.5 ppb was based
on the achievable detection limit for the analysis of PCBs
in surface and its value is approximately 35 times the PCB
ambient water quality criterion of 0.014 ppb. Given this
comparison, EPA believes it is unlikely that a requirement
greater than 0.5 ppb would be acceptable. However, if EPA
66
-------
in consultation with the Massachusetts Division of Water
Pollution Control (MDWPC) determines that, after ROD
signature, a greater target cleanup level for the drainage
system would be acceptable, then, the ROD may be changed as
a minor change or a significant change.
The decision process relating to such changes to the ROD
changes to the ROD is described below: Minor changes, such
as the decision to move the location of a well or minor cost
or time changes, are those technical or engineering changes
that do not significantly affect the overall scope,
performance, or cost of the alternative and fall within the
normal scope of changes occurring during the remedial
design/remedial action engineering process. Such changes
should simply be documented in the post-decision document
file and, optionally, can be mentioned in a remedial design
fact sheet, which is often issued as part of the community
relations effort.
Significant changes to the remedy in terms of scope,
performance, or cost are explained in an Explanation of
Significant Differences provided for under CERCLA Section
117(c). This document describes the differences and what
prompted them and is announced in a newspaper notice. This
is placed in the administrative record for the site, along
with the information that prompted the change. Significant
changes involve a component of the remedy, such as a change
in the volume of contaminated ground water that must be
addressed, or a switch from air stripping to carbon
adsorption in a ground-water pump and treat remedy, but do
nbt fundamentally alter the hazardous waste management
strategy represented by the selected remedy.
14. The effectiveness of flushing and the implementability of
additional contingent measures depend on completion of soil
and groundwater treatment.
EPA Response: As described in component (b) of the selected
remedy, measures will be taken during implementation of the
soil component to limit potential air emissions from
excavation, treatment and ancillary activities. In
addition, best management practices and engineering
measures, such as installation of curbing (berms) and
sweeping of pavement surfaces, will be taken to prevent
further contamination of Grant Gear's drainage system
including roof surfaces. Specific measures and
implementation requirements including optimal sequencing of
the soil, groundwater and drainage system will be finalized
during remedial design.
15. The ROD should adopt a more flexible, staged approach to the
remediation of the drainage system, including retesting and
67 .
-------
additional source measures applied.
EPA Responses The ROD establishes what measures will be
taken to remediate the site to protective levels. EPA
acknowledges there are numerous factors to be considered
before implementing the extensive site remedy, as specified
in Section X of the ROD. The appropriate sequence of
implementation of the various components of the selected
'remedy will be finalized during remedial design.
16. There is not reason to believe that the roof is a
significant source of contamination within the drainage
system or that roof drains have accumulated a significant
volume of contaminated sediments. Therefore, the existing
roof drains can be connected directly to a new above-grade
exterior drain.
EPA Responses Investigations performed by EPA indicated
that gravel that cover the asphalt roof of the Grant Gear
building was contaminated with PCBs in the range of 1.8 to
3.1 ppm. In addition, sampling and analyses of roof water
performed by ENSR, Grant Gear's consultant, indicated PCB
levels ranging from 0.27 to 2.7 ppb. Because the
established Grant Gear drainage system cleanup level is 0.5
ppb, the results, as described above, are of significance.
EPA has determined that additional sampling is necessary to
further determine PCB levels on the roof and in roof drains.
Based on these results, appropriate remedial actions will be
performed, including if necessary replacement of roof drains
and sealing of the roof.
17. The objectives of the containment remedy can be achieved
more effectively by sealing points on inflow and outflow,
without the additional labor and material cost of filling
and sealing the entire system.
EPA Response; As described in component (d) of the selected
remedy, containment will implemented were flushing and
cleaning are ineffective in reducing contaminant levels to
target levels. For those portions that will be contained,
the entire portion will be filled with concrete of a slurry
mixture (e.g. bentonite slurry). EPA did not select
containing only the inflow and outflow because of the
uncertainty of the long-term effectiveness of uncontained
portions of the drainage system in preventing future release
and migration of contaminants.
18. It is unnecessary to clean the drainage system and then also
fill it with concrete.
EPA Response; The cleanup standard under §121(b)(l)
68
-------
mandates that remedial actions in which treatments which
permanently and significantly reduce the volume, toxicity or
mobility of the hazardous substances, pollutants, and
contaminants as a principal element, are to be preferred
over remedial actions not involving such treatment.
In the case of remedial alternatives for remediation of the
Grant Gear drainage system, EPA selected flushing and
cleaning followed by treatment of the purged solids over
containment because flushing and cleaning will permanently
and significantly reduce the volume, toxicity and mobility
of the hazardous substances. Containment would not utilize
treatment and would only reduce the mobility of hazardous
substances.
Containment of the drainage system will be the backup
alternative if flushing and cleaning is ineffective in
reducing contaminant levels to target levels. To what
extent containment would be necessary will be determined
during remedial design and remedial action.
19. Careful attention needs to be given in remedial design to
insure protection of drainage area during soil excavation.
EPA Response; As described in components (b) of the
selected remedy, measures will be implemented to limit
potential air emissions from excavation, treatment and
ancillary activities. In addition, best management
practices and engineering measures, such as installation of
curbing (berros) and sweeping of pavement surfaces, will be
taken during soil excavation, treatment, storage and
disposal activities to prevent further contamination of
Grant Gear's drainage system including roof surfaces.
20. The ROD should provide for resampling of roof and any other
exterior drainage source and measures consistent with the
drainage remedy in the event that any areas have been
recontaminated during remedial action.
EPA Response: The selected remedy specifies methods to be
implemented to minimize further contamination of the Grant
Gear drainage system. EPA believes these measures will be
effective in minimizing further migration of contaminants
into the drainage system. As with any component, sampling
will be performed to determine how effective these measures
were in meeting the response objective.
21. EPA's study fails to support decontamination of equipment
surfaces in both the office and plant. The record reveals
that no decontamination is required in the office portion of
the building.
69.
-------
EPA Regponaai EPA concurs that the record does not support *
decontamination of equipment surfaces in both the office and
plant areas of the Grant Gear building. Component (d) of
the selected remedy specifies that only machinery/equipment
and floor surfaces within the plant areas of the Grant Gear
building will be remediated.
22. The decontamination of surfaces component of the remedy will
result in cleaning up too many surfaces too low a level and
is therefore neither cost-effective nor considered with
ARARS.
EPA Response; The PCB target cleanup level for equipment
and machinery surfaces is a risk-based level of 5 ug/100
cm2. This level was based on the site-specific human health
risk assessment and was established to be protective of
Grant Gear workers in direct contact with contaminated
surfaces. Remediation of all equipment to this cleanup
level will result in a maximum risk of 1x10 workers due to
exposure to contaminated surfaces. Assumptions used to
determine this target level is presented in the EA and is
consistent with the "Supplemental Risk Assessment Guidance
for the Superfund Program" EPA Region I (June 1989).
With respect to ARARs, no federal or state ARARs exist for
establishing target cleanup levels for contaminated
surfaces. As described in EPA's response to comment A.19,
the TSCA PCB Spill Policy is not an ARAR but a TBC. EPA did
consider the surface cleanup level of 10 ug/100 cm
specified in the TSCA PCB Spill Policy but determined that
the site-specific risk-based level of 5 ug/100 cm was
necessary to adequately protect workers exposed to
contaminated surfaces.
70
-------
EXHIBIT A
COMMUNITY RELATIONS ACTIVITIES CONDUCTED AT THE NORWOOD PCB SITE
71
-------
COMMUNITY RELATIONS ACTIVITIES CONDUCTED AT THE NORWOOD PCB SITE
EPA has conducted the following community relations activities at
the Norwood PCB site:
o June 22f 1983 - EPA attended an emergency meeting held by
the Town to discuss the status of soil removal activities at
the site.
o July 1983 - EPA issued a press release announcing that
contaminated soil would be removed from the site.
o July 1987 - EPA met with local officials to describe field
investigation activities and the status of negotiations with
PRPs.
o March 1988 - EPA sent letters to residents living in the
Meadow Brook area regarding the initial results of sediment
and surface water sampling activities.
o March 3, 1988 - EPA issued a press release announcing that a
March 16 public meeting would be held to discuss the 2-phase
RI/FS being conducted for the site.
o March 16, 1988 - EPA held a meeting to discuss the RI/FS.
o November 1988 - EPA distributed a fact sheet summarizing
field investigations conducted to-date and explaining
opportunities for public involvement during the site
investigation and cleanup process.
o March 8, 1989 - EPA met with the Norwood Board of Selectmen
to present a status report on groundwater investigations
being conducted as part of the RI. This was one of many
quarterly meetings sponsored by the Town that EPA attended
and provided information about the site related issues.
o June 8, 1989 - EPA issued a press release announcing that a
public meeting would be held to explain the results of the
RI and EA.
o June 15, 1989 - EPA held a public informational meeting to
present the results of the RI and EA.
o August 3, 1989 - EPA issued a press release announcing an
August 10 public meeting and an August 24 public hearing to
present the FS and Proposed Plan. The notice also stated
that a 30-day public comment period would be held, and that
the Administrative Record would be available at site
information repositories so that the documents could be
reviewed.
o August 1989 - EPA distributed copies of the Proposed Plan to
those on the site mailing list prior to the August 10
72
-------
meeting* '
August 10, 1989 - EPA held a public informational meeting to
present the FS and Proposed Plan.
August 24, 1989 - EPA held an informal public hearing to
accept comments on the FS and Proposed Plan.
August 11, 1989 through September 9, 1989 - EPA held public
comment period on the FS and Proposed Plan.
73
-------
EXHIBIT B
TRANSCRIPT OF THE AUGUST 24, 1989 INFORMAL PUBLIC HEARING
74
-------
1-53
3
4
5
6
7
8
9
10
11 I!
UNITED STATES OF AMERICA
ENVIRONMENTAL PROTECTION AGENCY
REGION ONE
In the Matter of:
PROPOSED CLEANUP PLAN FOR THE
NORWOOD PCS SUPERFUND SITE
Thursday
August 24, 1989
Memorial Hall
Norwood Town Hall
Washington Street
Norwood, Massachusetts
13 8
The above-entitled matter came on for hearing,
14 jj pursuant to Notice, at 7:37 o'clock p.m.
15
16 ;| BEFORE:
j;
17
18 ;
19 1!
M
it
20 1:
21 ii
22
23
24
25
RICHARD CAVAGNERO, Chairman
Chief
Massachusetts Superfund Section
U.S. EPA
90 Canal Street
Boston, Massachusetts 02114
RICHARD G. MCALLISTER, Esq.
U.S. EPA, Assistant Regional Counsel
JANE DOWNING '
U.S. EPA, Project Manager
DALE C. YOUNG
Massachusetts Dep.t. of Environmental Protection
Site Manager
APEX Reporting
Registered Professional Reporters
(617) 426-3077
-------
1
2
3
4
S
6
7
8
9
10
11
12
13
M
IS
16
i!
13 ;
19
20
21
22
23
24
25
' 8
Soil Cleanup Goals, number 2, where it cays All Other
Soils, at the very bottom of the page we have a
chemical which is called 1,4-dichlorobenzene with a
number next to it of 260ppm. Unfortunately,"" that m
should be a b. So the soil target level for that
particular chemical should be 260 parts per billion,
with a b there.
And the next one is at the very next page,
page 8, under the Grant Gear Machinery and Office
Equipment Surfaces Cleanup Goal. The proposed cleanup
goal is now 3 and not 10. We did write a memo which is
in the administrative record which explains why that
was changed. So, again, we are going with a proposed
cleanup goal for the office equipment of 5 micrograims
per 100 square centimeters. It's on page 8. Does
anyone have £.ny questions about that?
17 i CNo responsej
MS. DOWNING: I would like to begin with
just a very quick summary of the results of the
remedial investigation, simply because we are concerned
with what- chemicals showed up at the site and at what
concentration. This is in summary form because we we>-t
into quite detailed two weeks ago and also in June.
For this particular site, it is called the-
N:-i-wood PC'E site, so oij.'iouily PCSc were the IT. a.j or
APEX PEPQF:TIUG
Pegi at ».i'«d F'«'O f es'ii oiic-1 F'«*portc-r
-------
1
2 the soils within the 26 acre site and most of the Grant
3
5
6
7
8
9
10
11
9
14
15
16
17
18
19
ii
21
22
23
24
25
contaminant and it did show up in the site soils. For
Gear Facility. The major contaminants were PCBs. We
also had contaminants which we call PAHs. PAH stands
for poly aromatic hydrocarbons. The third contaminant
class of chemicals that we found are the VOC. The VOC
stands for the volatile organic compounds.
So essentially for the soils, there are
three different classes.of chemicals that showed up:
the PCBs, the PAHs and the VOCs. You will see, when
you read the proposed plan, because they are
12 j| contaminants of concern, we do .target- these chemicals
|i
13 so that the cleanup will remediate these-chemicals down
to an acceptable- level.
For the sediments, what we believe happened
is that the seals erroded from the site and ended up in
the brook. Therefore, the PCBs were in the soils arid
the PCBs also showed up in the sediments of Meadow
Brook.
i
20 i The groundwater underneath the site, we
also found contaminants. These contaminants were
mostly the volatile organic compounds. The PCBs rea]l/
did not show up to any great extent in the groundwater.
And one of the reasons for that is PCBs tend to absorb
to =01 1 T. The> don' t very esai 1 > di ssol -.-*.: .
APEX REPOE'TI.NG
PC?y1 G t s f eri Pc C' f e: zi o;-. z 1 P-o;:: o. t c i
T£. 17)-411 £-3077
-------
1
2
3
4
5
6
' 7
8
9
10
11
12
13
14
'10
19
20
21
22
23
24
25
So those chemicals really we found
basically in the soils and the sediments, not so much
in the groundwater. Unfortunately, the volatile
organic compounds do easily dissolve and we did find
them in the groundwater. We will be targeting them in
groundwater.
Grant Gear has a drainage system, because
of past disposal practices, there are sediments in the
drainage system that are very highly contaminated.
They are contaminated with, again, the PCBs, the PAH&,
there are some metals that showed up in the sediments.
So, the drainage system of Grant Gear is also
contami nated.
We have, as far as potential health risks,
is jj we do have some? risks associated with exposure to these
chemicals. Some of the ways that you can bfc- exposed to
the chemicals is simply direct contact with
"e i! contaminated soils, direct contact with contaminated
sediments. So, we do have a public health risk. The>
are not too significant other than some of the maximum
concentrations. But it is a potential public health
risk.
There's also an environmental risk that we
also look at because a remedy must be protective of
public 1'ic.j. I'll and the envi ronnic-nt. r.r.d basic Ml/ we-
'APEX PEPOF7IMG
-------
' 11
1 were concerned with the environment when we took a look
2
3
4
5
6
7
8
9
10
11 '
12
13
14
21
22
23
24
25
at the sediments. So, we had to set a level in the
sediments that was also protective of the environment.
Very quickly just showing this map, because
again, for the PCBs it's really the soils that we are
mostly concerned about. And the one thing to remember
here and this, I think, pretty well illustrates is that
most of the soils that we found that were contaminated
with the PCBs did show up within the Grant Gear
property. The Grant Gear property is approximately
nine acres of the twenty six acres.
You can see from the colors that the more
highly contaminated, soils and, actually, the greatest
volume of soils showed up within the property. We did
15 ! have- some high levels that we found in the south bank
15 j of Me-a.dow Brook. On the north bank, the levels, were
17 | fairly low. So, essentially, our PCB conta.mii'.ited
"5 jj soil was confined to the Grant Gear property with some
,. l|
19 jj outlying areas and also the south bank.
20 : Now what I would like to do is just to
recap the preferred alternative. Two'weeks ago we gave
you the? preferred alternative explained and then we
took a loot, at some of the other options. Those other
options are explained in the proposed plan. The> are-
also e:-..pl a i n-_'J in the feasibility ctuciy a.-id if yo-
APrlX REPORT ING,
'"'
-------
1
2
3
4
s
6
7
8
9
10
11
12
13
15
ie
19
20
21
22
23
24
'12
would like, we can discuss it after the formal public
hearing.
But this essentially is what EPA is
proposing for the cleanup of this particular site.
There are nine components to this preferred
alternative.
The first one is called the site
preparation. That is essentially self explantory. We
need to prepare the site for the future work. That may
consist of grading the site and worrying about
collecting the erosion, some erosions, some runoff
containment.
he soil treatment, there is quite a
14 ' significant volume of soils that must be treated. I
believe we are talking about 29,000 cubic yards of
16 ; contaminated soil. We are proposing to treat the soil.
i:
17 : The other option would be something like containment.
Ws are proposing to excavate the soil,
anything above the target level, and treat it by a
treatment called solvent extraction. That is a
chemical type of treatment where you chemically remove
the contaminants. The other option that we looked at
two weeks ago was incineration. But we are proposing
the solvent extraction. It is an innovative treatment.
U'e v.'j ] 1 !.£<.£. to do some t rest abi .1 i t > -:tudie=.
Arcx PEPor-7ir:c
F t-ui £t£-r t-d Pi of c-sii on,.-.! Pepor *
-------
1 The sediment treatment will be essentially
2
3
4
5
6
7
8
9
10
11
13
15
15
19
ii
21
22
23
24
25
the same as the soil treatment. We are going with the
on-site solvent extraction chemical removal of the
contaminants. There's going to be about 3,000 cubic
yards of sediments that will have to be dredged from
Meadow Brook.
As we talked about two weeks ago, most of
the contamination of the sediments started directly
near the Grant Gear out-fall. So we are in Meadow
Brook at the Grant Gear out-fall and extending all the
way down towards the Neponset River. Although the
12 ij le-.sls between Dean Street an'':>''. or lOO'I. We- don't
APCX F:CPQ~Tir:G
F:&a i st &r tci F( o f e =..-. i -:-i. j- ] Pe fj:: 1..-.- :.
-------
1
2
3
4
5
6
7
8
9
10
11
12
14
15
16
17
13
20
21
22
.'3 ,
. 14
feel that we can, through flushing, totally clean out
the drainage system. We still believe there will be
some manholes or some pipes that will still contain
residual contamination.
For those particular parts of the drainage
system, we are proposing a containment. They will be
filled with concrete. And, to whatever extent is
needed, we will have to replace those portions of the
drainage system.
So, it's going to be a flushing to get out
as much of the contaminants as we possibly can, coupled
with a containment of those portions that can not bfc
13 ! physically cleaned up.
We are also worried about the possibility
that tha- roof of Grant Gear is contaminated. And even
though those levels are fairly low, the values that are-
ello.'Sw to go out to the stream are irv: redi tly low.
So, the roof may have to be remediated. We are floir.c;
19 to do some additional sampling to figure out to what
extent that will be.
If that is true, we are proposing to clean
up the- roof. There are stones out there presently, and
23 jj if need be, seal the roof. The other option for the-
roof could be something like a removal of the roof.
APCX PEPOP-'Tir-.'G
Pf'of essior.iil f\ ;:*:; t-. . ;
(617 >«:£-307?
-------
IS
1 We did take a look at the machinery inside
2 the building because of the past history. There were
3
4
5
6
7
8
S
10
11
12
15
16
I
18
21
22
23
24
25
some low levels of PCBs that were found on the
equipment. They were fairly low. They were very close
to our PCS number that is in a TSCA regulation.
However, we are still proposing to remediate that down
to a certain risk level. We are concerned about the
future, every day exposure to those, low levels.
So, we are proposing a remediation of those
and that would be simply decontamination. We will be
taking a solvent and essentially washing the equipment
to remove the PCBs.
13 I Qroundwater needs to be collected before
you can treat1 it. There will be two parts of o
groundwater collection scheme. One will be « trench
located along the northern border of Grant Gear, close
to the fence between Grant Gear &nd Meadow Brook. ThM
would be to collect some of the top groundwater, some
19 ; of the overburdened groundwater and some of the shallow
I1
20 i- bedrock. That is essentially where most of the
contamination lies, in the overburden and also the
shallow b ed r oc k.
To whatever extent is necessary, we may
have to put in some very deep wells to get some of tlv.
bed roc I- groundwater out.
Fx-gii it er £
-------
1
2
3
4
5
6
7
8
9
10
11
12
13
14
15
"16
So, we are proposing a trench for the
overburden and shallow bedrock and some extraction
wells for the deep bedrock.
The groundwater will have to be treated.
We are going with a fairly readily available treatment,
it's been used at a lot of sites, called air stripping.
It essentially strips out those VOC compounds.
We also may have to remove some metals
simply because you are only allowed small levels of
metal going into the brook. And that will have to be
removed by, again, a fairly common treatment, which is
called precipitation and filtration. You add some
chemicals and it precipitates out the metals.
For the PC3s, again the PCEs tend not to be-
dissolved in the ground water, but they tend to be
! cti-r-rbed to small particles and we are proposing to
ii
il
"" ; reir.o.e tl';.-t by carbor absorption. It's a filtering
i-!
13 !' *>('£ of treatment.
13
20
21
22
23
24
iS
The v-et lands was a special issue thc.t we
talked about two weeks ago. Part of the guidelines,
part of the laws of the land, we need to inform you
that there will be some wetlands impact. The area
between Grant Gear and Meadow Brook has been des: gnat>. J
as a wetlands, although you go out and see a forest
l\->sr&, it i a a wet lends.
Ar'ZX PEP-OFT I Nfc
'egi stc-: t-c! ;*'i o '«£.*! on;-.] Fejjor t tr z
07-
-
-------
1
2
3
4
5
6
7
8
9
10
11
12
13
14
15
16
17
19
21
22
23
24
25
'17
Therefore, if we want to go after the
sediments, we will have to possibly take down some
trees. So there's going to be a lot of impact to those
wetlands areas. We feel that there's really no other
choice. If we are going to clean it up, we are going
to have to impact them.
But, under the law, what we need to do is,
to the extent possible, go back and restore that area.
hat will be somewhat difficult because you have trees
there, but that is the proposal to do a wetlands
restoration program for those areas impacted.
There will bo long term environmental
monitoring. We arc not proposing to go after the soils
" »
underneath the water table. So, thers will be some
soils that will remain on the cite, as well a-z. whatever
contaminants arc remaining in the drainage System. An:!
bc.'Cc ouncj.,'i.t ;_;-, c i ,"(.: j . 1 3 j wilhir, t. ;,;.: C !.:'.
ri:r_.i itr.ru J Pr o f e:-.j i o. .:! Rc-po/t .
-------
1
2
3
4
S
6
7
8
9
10
11
12
13 ;
18
15
19
20
21
22
23
24
25
Gear facility.
Because of the possibility that little PCS
particles could end up-in the groundwater, we don't
feel comfortable saying that you can drink the
groundwater at Grant Gear, even though we are cleaning
up for .the other chemicals. Because of that small
possibility, we are going to have to impose some
institutional controls so that wells are not drilled in
that area.
The other reason why we need them is
because, if the drainage system is going to remain
there, we need tc put some kind of deed restrictions
for any possible future owners, to let them know that
they can not fool around with the drainage system &r
I
15
i
'^ And I just have- two more transparencies,
just a very quick review of what we look at before w
pic!:' a decision. We have a, I believe i * ' z nine
criteria that we use to evaluate all the altern«tives.
The first one is probably the most
important, it's the overall protection of human heal It.
and the environment.
The second one is more the technical nature
of the project, is it going to be effective in the
;!.-.. t * _!
-------
1
2
. 3
4
5
6
7
8
9
10
11
12
13
14
15
16
17
19
19
20
21
22
23
24
25
term.
We then want to look at whether the
alternative will reduce toxicity, mobility and volume
of contaminants. We prefer a treatment as opposed to a
containment because containment will not reduce
toxicity.
We are also looking at whether the
treatment can be fairly implemented. Is it a readily
available treatment? And we feel that the ones that we
have picked are.
Cost, of course, is an important factor and
WE do look at cost. We need to figure out whether our
decision is a cost effective decision and, obviously
we feel thit.is true.
And there are' s lot of laws, including the
wstlands law that we also have to look at.. We have to
make sure thjit we c-.re complying with, basically, = tc..t&
13 I and federal laws.
The state needs to tell us how they feel
j about it. There's a state acceptance that is part of
the .cr i.ter i a.
And 1 sst, but not least, is the community
acceptance. How does the community feel about the
proposed plan? Are there some aspects of it that the.-;,
arc concerned t.fcc-'wi t'"' Are there sc-iTiZ othsi a'l tei'nc-.t :..'. 3
AP-;' P-EPQRTING
c ;..' F :-o f C5 51 on5.1 R-epor t c :".::
-------
1
2
3
4
5
6
7
8
9
10
11
12
13
14
15
17
IS
20
21
22
23
24
25
ii
20
that they would choose. And that is essentially why we
are here tonight.
I would like to close just with a quick
schedule outline. The first two we have actually
finished. We are at the during the public comment
period and you need to know that that will be up
September 9th. And the ROD is proposed to be signed at
the end of September, around September 30.
Thank you.
MR. CAVAGNERO: Thank you, Jcne.
Before we take comments, I just want to
make one further point. Jane indicated we will be
signing something called a ROD in the latter part of
September. This is short for Record of Decision, whii_h
is the Regional Administrator of IPA's decision a.: t :<
what the remedy will be on this site. Again, to di:J. c,
ws have only p.- cposeJ the remedy, we are now in tho
_ s
15 !i process of accepting public comment and we will be
going back, following that comment period, and coming
up with the final remedy.
Once that Record of Decision is signed, it
will also include a section called a responsiveness
suffimary and this essentially will be a summary of all
the comments we received from all parties, either at
t or. i glil * : -hc-c-.i i ny or 3 TI writing, and it will i n c 1'- d :.
7:. -31 c' c-rc?;! Pr .;.f c £.51 ona
-------
.21
1 our responses to all those comments. So, you will,
2 when the Record of Decision, also know how EPA
3 addressed any comments that you did raise during the
4 public comment period.
5 With that, I would like to open it up. In
6 order to get on the record, you will have to approach
7 the mic.
8 The first person is named Robert Clement.
9 MR. CLEMENT: First of all, you said that
10 the 19S3 record, it was very recently that we
11 (unintelligible) we were told that i f documantat ions
12 from DEDE, EPA, that at the end of 1933-S4, this was
13 all cleaned up, WE had no other problem. Six months '
i
u later, you came bach: and you said you left a little bit
15 of c on t«rr;i nation around Grant Gear. It's all
16 docufiiE-ntec!, all in files right there and I have more at
17 ! home..
18 Then Mr. Hourihan and few you will have
19 to excuse me, all yo.u peopls are new to rue, you know,
20 I'm used to looking at the old faces, Mr. Hourihan and
21 Fitzgerald- and a few other people. The- only one I
22 recognise here tonight is John.
23 . Anyhow, we were told that this place wasn't
24 going to be'touched for ten years because it had to go
25 irrt'.-" v certain c 1 z ::ci f i c at i on of lam.' that t:-::::y walcK
APE* REPORTING
-------
1
2
4
5
6
7
8
9
10
11
12
13
22
after all this was done. Ten months later, we get an
industrial park in Kerry Place. And you tell them the
place is so clean, you-guaranteed the water was so
clean that you could build an industrial park there.
Now I see that on the map here that you have 10 to 100
parts per million PCBs still on the spot where you had
been writing as clean.
And in your latest survey that I have over
here, you are telling the people who worked there and
who had done the construction that they may be in
danger of contamination of PCBs.
Now, I understarid from your office about
water snc! groundwater. You seem to go back and forth
- jj wh&re you say we are going to clean this up to a poir.t,
I.
15 j! we are 501.15 to clean that up to a point. There .T.sy be
"'6 j; EC>me of this loft c-v&r here. We are only going to
i;
17 j! bothsr with co ma-:h ...f this in this spot.
ii
15 ' AE far as concrete goes, do PCEs pars
through concrete, does anyone know?
19
20
21
22
23
24
MR. CAVA6NERO: Pass through concrete?
MR. CLEMENT: Yeah.
MR. CAVAGNERO: It c*n penetrate concrete.
MR. CLEMENT: It can penetrate concrete,
then how do you plan to seal a drainage system with
ccoc r et ~."'
'?Cj|i ^1 .:.'Ci-u Pi' O 1 -- - 1 O.'iol r !._;_. '. _ . -
-------
1
2
3
5
6
7
8
9
10
11
n
19
20
21
22
23
24
' 23
MR. CAVAGNERO: Well, we would be happy
to Basically, sealing the drainage system means you
are keeping water I mean, you can make a fairly good
seal to keep water from passing through it.
MR. CLEMENT: Water will go through
concrete. Water leaks through concrete.
MR. CAVAGNERO: Well, I guess we are
looking at what rate.
MR. CLEMENT: I would like to bring up the
fact I raised my family there, we have a lot of
people who are concerned there and you won't see & lot
12 ij of the neighbors here tonight because, frankly, we are
li " " .
13 ii
kind of tired of the EPA and DEDE. No offense, but we
i;
14 j have had an awful lot of it.
- ii
13 ,. Bear in mind, you people- in June are the
on£ii that came up to us and told .u; to throw our shi-c;:
<:.wc.y. Then you said everything's si 1 clean. Ther. we
13 ;j hive an industrial park here and now you are tell in:; uc
it's dirty again. Then you tell us the groundwater is
j never going to be cleaned up completely, that you can't
ever be able to drink the water.
That might not be a big de&l ,
. but prior to that, no ons had clean water there. Now
you have certain parties go out and dirtied it. I'm
LU: e . o-j '- \ Pc-;: oi \ ,. i -
-------
1
2
3
4
S
6
7
8
9
10
11
12
13
14
15
15
IS
19
20
21
22
23
24
How about the people in my neighborhood who
for years have had gardens in their yards. Are these
safe?
Can any of these questions be answered?
Before or after you cleaned the water in the land?
MS. DOWNING: I think at this point, the
best thing to do is to tell us what your comments are
on what we proposed.
MR. CLEMENT: You've got to tell us what
you are going to do. What we You can say you want
to know how the Norwood You just stood here a minute
ago and said, How do people in Norwood feel about thic;
Yight?
MS. DOWNING; Right.
M£. CLEMENT: Car. I grow tomatoes in my
yard"' Thoic s:-e thing; thr.t the people in Norwood want
-i: knou.
j!
When you come up with thic, program, when
you- dici your foundation work, you drew test walls all
over the place. Were you well aware that since the
early r&0s that Norwood has had a severe problem with
the drainage system and the sewage systems and leal:ing
in the- MDC water system in that neighborhood?
I have it all documented here. I have
..rd :::,. fi .MI: >:....;.( office, DEO::, At :..:: n:-v Gci.c-rc.l tc I'.:..
r c-3: itched T- r ; f c- i...
cr
-------
1
2
3
4
5
6
7
8
9
10
11
12
13
14
15
17
20
21
22
23
24
25
all these things fixed. These go back as far as the
'60s. There's never been enough money to fix all this
stuff.
You have groundwater with VOCs in it and
PCBs. It is groundwater; right? It's carrying water
back and forth. It's also wetlands. My own backyard,
I have pictures of the groundwater flooding. So, all
this stuff is getting all mixed up through the sewer
system to the drainage system.
And what I want to know, too, is ever the
potable water in this area ever going to be tested to
see if there's ever been any mixture of that during a
wet season. I'm sure it hasn't during a dry season,
but during a wet season, are we drinking this stuff?
There's been 3 lot of emphasis on Grc-.r.t
Gesr. Grant G«ar , I know, is «n inriocent cor.psriy ;,;_
fs/ ;.L; PCD goes, but as- far as VOCs, that stuff i s. urs
16 ij to clean up machinery. t.'hat your -map doesn't show is
19 j that an inside drainage system that goes directly t :
the brook. It's in your older maps, I have it over
h'ere, I found it. And all this stuff is their mess.
You tallied about the VOCs that are down in the dirt,
who says it isn't their mess?
PCDs was there for 40 years, storting off
with t!'i£ U.S. government was .there, Toby BLiiJnTo-r;,
A r-1 *- \t f, i r> c~k ^. T T k i ,~
MI- u ). F..L.T ur . l,'_i
F: ::- g i s t e r >: d P f .; f c- s s i o n ; 1 I7' c- p o r t G- r =:
-------
1
2
3
4
5
6
7
8
9
12
18
19
20
21
22
23
24
'26
Cornell Dublier, all the rest of them, have it all over
here, gave it to you in 1933. Now, six years later, '
you really haven't come too far.
And you want to know why people in Norwood
are a little bit upset? This is why. We think it's
going to take you another twenty years Just to draw
another map before you do anything.
We also want this cleaned up, as the Town
Manager will tell you. We have been waiting for .yaars
for a new sewer system. We can't get it until you
people clean this up. And this is not something that's
been in the b;;c!. of our minds, this is something thc.l
'3 ji flood: our csllsrs during wet seasons. This is
i
1 something tl.;.t*s very important to us.
!5 S This just addsd to ou/ problems. We sa~
6 j; ti-.i:. t^'cvgb the- e> OL.nd. It nixes. l-'s dcr;'t :.:.<;'.. if
i i'.' . .r, our dr ir.i.irii wj,tcr. We don't i.r.o.- if -: ,;.:,.-,
eat food fro*-. Ciardens. Me don't know if the I ids c^r.
walk barefoot in tlic grass because ths groundwatcr d:-.
come up all over the place. I have pictures of my
backyard flooding. I have pictures of the sewer syatc
being suspended two feet out of the ground by water
pouring out of the sewer systems.
This is all past history as everyone here
knows. Uc- «ifc ret xo i nt orc-zt ed in w!-.crt!-.or yoo ;>;::
ip i it c i' od F-r o f ~z~.. i^i one, ] F'<=(_;; t
-------
1
2
3
4
S
6
7
a
21
22
23
24
2S
27
going to tear Grant Gear or relocate them or plug it
up. We? want to see Anything that's dirty, we want
to see out of there. And we want to know whether or
not the water is any good or not.
I can talk to you after the meeting about
twenty other questions. I don't want to take up the
time because it really doesn't have anything to do with
the regional project.
9 ij This project that you are t&lking about
10 I should include these questions, should be address!na
"
11 ! the&e problems. You stood here and said, you wanted to
know what tits people in Norwood think, how they fec?i ,
whist they £.re worried about. We lived on it. t-.'c- !.;,/e
!idc t.'.st grew up there, ployed i'n it,- physical
contact, rolled around as kids.
And the super hot spots were in \".<2r-.-_,
Place-. They were even hotter than the on&a we- !.£.: ;'.
ji
18 ' G.'c,nt Gear. And this has all bee-n leeched over 3.
li
19 || period of more than forty years, almost fifty now,
because it's come six years to get to this point. So
you are talking just four years shy of fifty yearn of
1 sachi ng.f
We- want to know how dirty the- soil is and
the waiter that we live in.
P~3 i c .1 cf c-ci FT : f u-s s i on;< 1 F'c p: ; t :: i
'I-1""' -1-£-ro~~>
-------
1
2
3
4
s
6
7
a
9
10
11
12
13
15
19
20
21
22
23
24
MR. CAVAGNERO: Thank you.
You raised a lot of questions there. Me
will respond to those, as I said, in the responsive
summary, but I would just like to make a couple
comments.
As part of this Record of Decision, we also
consult with a group from Atlanta called the Agency for
Toxic Substances and Disease Registry, which is an arm
of the U.S. Public Health Service, and also on the
state level with the Department of Public Health. They
will be doing what's called a health assessment.
I'm not sure exactly what st«.tus that's in,
but that will be included in the administrative record,
with the Record of Decision. Toot will be basically
the viewpoint of thecs people who sre essentiall>
PL;;. lie health professior.;,' £ «.:, to, you know, their :--
profc-ssicrial viewpoints &~ to whc-t are thssz- i i-l : j :..
tal !.s»d about.
You have raised & lot of legitimate onrs
and we will respond to that in the Record of Decision.
I think our opinion thus far is that the removal action
that was done. I won't tell you what those people ciic'
to you, I wasn't there. I won't dispute what you said.
I gues» our view is that they tried to do
23 ij thM und£i w;.t-«t J.TC called tiic: En.r.-Cic-iv:., rcni-...j«
«&! s'..t-r ed r, :.ft2;*.:.ri«.] PC (-: t c. ,
-------
1
2
3
4
5
6
7
8
9
10
11
12 :
,3
23
- ! T i , , x
I thank you for your . lo.iiiT.c-.-itE
i
i
1= i
19
20
21
22
23
24
25
authorities we have and I think they felt that they
took care of the bulk of the worst contamination which
was presenting any kind of immediate threat and left
only what they thought was essentially more of a long
term threat that could be addressed after more detailed
study and evaluation.
And we are of the opinion at EPA, and 1
believe the State agrees, that we do not see that the
current situation presents an immediate risk anc,'.that
if it did, we would have done something about it.
Exit, again, all of the questions you rc-.:sod
arc perfectly legitimate and we- will respond to ti'.cic
in the.- responsive summary with the- ROD.
r:r. CAF^OLL : GOOC'
17
ie
M a :; a g e v : i tl o r w o o d.
I would like to ask a coupler of quest ion;
about some items on page 10 and 14 of the report, and
then some comments and questions about the some of
the paragraphs on page 11.
Or. page 10, where you are tcill.ing about the-
disposal of soils, especially the dredge piles, do we-
c.'-:--'iTi-:.- tl'.:-.' wl-..:l ^-o-.i arc- Eaj-ii:.c. ti'ii-rc 12 tl.at tl.«-'
r-'CQj jt u: i.-d r'i"C'f&2- J '- ".''" r'i- i '-' ' -' 1
-------
1
2
3
4
S
6
7
8
9
10
11
12
13
U
15
20
21
22
23
24
'30
dredge pile is essentially going to be removed from the
banks of the brook and then cleaned and disposed of in
some fashion throughout the site? Is that what I
understand is going to happen. The answer is
affirmative there.
On page 14, there was some reference there
to operation maintenance costs having to do with
groundwater and the soil remover. What I don't
understand what that is about. Does that mean that
there's going to be some ongoing maintenance and
operation or. the site for a period of time? Thers's »
isutstantial amount of money there, 2 million dollars, I
tliir.!;, :; ... million and a half dollars for botli of
t her;.
MS. DOWNING: It's basically the CCr of
doi-.:, ti'c so. 1 treatment, bringing the trsatff.ii.-.t t«:
site j.r.-i maintaining the treatment system.
r'F:. CARROLL: Maintaining the?
19 |i MS. DOWNING: Th* treatment, the actual!
doing the work of the treatment.
MF1. CARROLL: But once you leave there,
there will not be continued operation and maintenance,
will there?
MC. DOWNING: Once it's cleaned up, it's.-
Arc;*. F:croF.Tir:£
r'..-.ji -tc. od Fvof Ci«: onil F....-'f. : '. r . :
-------
1
2
3
4
5
6
7
8
9
10
11
12
12
14
15
19
20
I!
.21
22
23
2-S
25
31
and sediment. There will be monitoring done, but that
will be for some of the drainage system soils around
the drainage system and the groundwater.
The proposal is that it's going to take
about two years to do the actual soil and sediment
part. Once we do that work, that should be it for you.
MR. CARROLL: The main questions and
comments I have have to do with the Brook.
I know that both EPA and DECE are aware of
the fact that the Town of Norwood has on the books,
it had advanced to the design stags a project to dradgs
ar;c deep£Tf Masdow Brook from Pleasant Street right down
to thz- Neporisst River. And as part of that, t! ;&.'; thc^ij
ans were done through with the help of DEQET 5
DIM'c with ih-ir funds,.
'..'£ ended up having a pl^n -'hi.;i. w,j-_
scc^-U-.'ilc- to DEM th^t showed a particular crc.~i:
sec t : on , a p ar t : c u 1 a r d ep 1 1 i , a particular p r o f i 1 e . C
we get some agreement that the work they are going tc
do is not going to have to be redone by the Town of
Norwood or some other entity at a future time if you
are excavating 2,000 cubic yards of material? Can we
get -LOine agreement that that material ic going to !:£
excavated to the profile that we had anticipated our
d: c.- J jii-.c. to t- uor.c arid to tiv:: croc= -lection :..- '--:*.'
-------
1
2
3
4
s
6
7
8
9
10
11
12
13
17
19
20
21
22
23
24
25
Is the answer affirmative to that?
MS. DOWNING: I think we have to take that
under advisement.
MR. CARROLL: Well, should we Let me ask
a question. Do you have in your possession a copy of
those plans?
MS. DOWNING: Yes.
MR. CARROLL: You do; okay.
How will we know what you are going to do?
I rrisan, I don't want to receive that last thing, you
call it the ROD, or whatever you call it, that says we
!-.£-.£ listened to Mr. Carroll and we decided that wr a;-e
not going to do it. How do we get torae input in this
tl-.ir.g, becsv.ru- we are tall-ling aboi.-C'U are going to c,o in t'.eri: r.nd ..Is-jr.
,
you ars not goin^ to ol _;.:, it with
,1
15 i tEt-spoonSf you are going to clean it wit!', a
wo'uld guess., which mean;, as, you indicated before, th;.t
trees are going to have to be removed.
If you are going to put a pipe in that's
going to parallel the- brook for some length, I would
assume that that's going to be a pipe of some, ff.sjcr
wire- because that brook carries * lot of water. !
-:::-.'t thin! of !.o.
-------
1
2
3
4
5
6
7
8
9
10
11
12 ji of it, but what I want to do is I just don't wont to
. i'1
13 j, see work dons twice. How do we assure that that can
ta!:c place"' Can we arrange for in meeting with you o--
15 !; something, Jane?
ie jl MS. DOWNING: I think '..£. can have a.meeting
17 ji to clarify what the concerns are, b_'t I believe at this
13 i! point is that I know what you arc saying.
23
21
22
23
2-s
2:
but it's up in the area of 1,000 cubic feet a minute or
something like that.
So that, you are going to do some major
construction work on that brook, and what I'm trying to
get at is that I don't want to see this work done by
you and ths effort essentially be wasted so the Town of
Norwood has to come back and spend a half a million or
$750,000 later on.
If you arc essentially going to do it, I
would like to make sure that we hove a cooperative
Maybe we have to put some money in to be part
19 i I'm not really sure what I can say as for
&z an answer, what we can do under Super fund. There
are some legal constraints to what ^e can and what ws
can't do. And I think we will basically have to take
it under advisement and we will 'talk to you about it.
MR. CARROLL: 0!:
-------
1
2
3
4
5
6
7
8
9
10
11
12
19
20
21
22
23
34
MR. MC ALLISTER: Let me just say
something that, you know, there's a lot of stuff that
you are talking about is going to have to be really
flushed out in design work when you are actually
looking at it.
Just to continue on with what Jane was
saying, what we feel we can be authorised to spend out
of the Super fund and select a remedy is what is
necessary to remediate the risk that's there. I thin!;
that we have made it clear that we expect to excc.vc.te
more sell than would be done in order to mest your
f 1 C'C'i.' C OPit i C'l pi"'.' JE'C t .
"3 i: If that doesn't necessarily follow tlvs
"^ '' -p.ic i f i :at. c-r.s, t!". :-.t's, someti'ii.-g tha-t is.gwing to
^~ ''. I c.. .-.use -;; ;re following the contamination rather l'.;.r.
1~ i. _,- r, .._ . < _ - -1!; ;.-.;-. r . And I tl""n!: tr'.ct th'~ \ i " ~' ~ 'f
"" i; ^.CL-.n.or.i you are talking about are ones that '...II
1S j| t*i'.e £ QC'C-*' a.^i'LTit of working out arrangements if
you wart to try to coordinate. And I just don't know
if that's the kind of thing that you could really
use-'ully resolve at this point.
MR. CAPFrOLL: I know we- can't resolve it -^.
| this po*r.tt but I would like some sort of a commi t.Tient
tc wefI together to try to achieve a mutual!/
* t~ -p- - ^*.^?*«" ^ * » i.-
%m.. i ITF ;jr . . i ; _
-------
1 PCBs, but also'the dredging and the increasing of the
2 capacity of that brook.
3 And also, we are not asking you to spend
4 any more money than you are allowed under Super fund.
5 We are saying that if you are going to excavate more
6 than the soil we are going to take out, we would like
7 you to work to our cross section.
8 Obviously, we would not say you 90 down
9 the brook and dig it out a half s. foot too high and
10 have- the cross section off and have us go back and do
11
it over again, it makes no sense. I maar., it's g:-irig
12 to be an inconvenience to the neighbors to have
13 fiischinery and so forth go back in there sgc.in at s :.;:!?
i
14 | future tiiri-j. Wz wint to be sure that thi- cross section
15 is correct c.r.d t!v.:- depth iz. corre--. t.
!
1£ r:.-w, I thinl. th«t that is net ;..-.
17 jr.iMiiicvsbie go;;l for both of us if ve we..--:, toc.c/!'.:,- on
18 ! -: *.
i . k .
i
19 MR. CAVAGNCFlO: I will only fil£.;.£. one-
j
20 comment on that, Mr. Carroll. The 'us' in terms of who
21 . does the? remedy may not be the EPA or DEP. Our statute
22 that we work under basically is written such thst
23 Congress wants EPA to get the res.poni.ible parties to
actually implement t.-.is and any other ROT1. As <=> matter
2^ f £ . t i;.. i ... .. ....11. .....'J... . i .. . . I_I,_A - -.
r >-' i * v . . , LIU. j .:...,..- _, _ : .. 1 i.1». * * y C, ..i i . *.- '. . _ Z ; t! . ''.. - u
AF;r>: REPORT rrri
-------
1
2
3
4
5
6
7
8
9
10
11
12
13
14
15
I
15
19
20
21
22
23
24
25
. '36
really not supposed to go and tap the Super fund money
until we make an affirmative determination that there
are no responsible and able parties out there who were
able and willing to actually do the remedy.
So what I'm saying is, hopefully after we
get this record of decision, we will actually get a
settlement with responsible parties to do this work,
but we will certainly, in negotiating that settlement
with them or in doing the work ourselves if we can't
reach a settlement, you know, consider what we already
know to be the Town's desire to have their flood
cc-r.i? ol project to 50 forward post haste- or a; -.>:;
I -- what I' i.. tryi.-.g t-.- say is that, for instance, if
'Sji t:,L/c's i. c.-cs: * act: :-,-, of the brook ir. the shape- : f -,
, J!
"' ;i li-t*s ^~..j z. flat U c.r.d ye-.; £/o gsing, to go ir. there ;.. :
excavste only the FOB; out of the bottom of the bro^!
obviously, £- soon as you left there, ws begin h;.. in;
w&shouts in the embankments of those brooks.
So, I would assume that you are going to
leave the brook essentially whole. I mean, you are
going to slope it in such a way that washouts do"«*t
occur from the banks of the brook. That would be
,' ......-.._-.-- A. . .J .. ..!_.. .').!.. ... £ . . ,. T ,
A i _ , |. _ |. * . v . » t . *J ', t_- (.- , u', i J 4 i_ » u ..« ._ i ^; ; tat'_ ^ n,
-------
1
2
3
4
5
6
7
8
9
10
11
12
13
-.8
20
21
22
23
24
25
concerned, for anyone to come in there and excavate the
brook in such a way that the slopes are going to fall
in.
MR. CAVA6NERO: We wouldn't be able to do
that under our law anyway. We have to follow basically
the executive order on wetlands which includes streams,
which requires us, when we do work with wetlands, to
mitigate any impacts we are causing by our excavat i or,.
We would not be able to leave a situation you are
descri bing.
MR. CARROLL: I think our aoals a
compatible because ws ere basically, we only planned to
excavate the brook a foot or so anyway, in depth, c
foot cind a half, and we plan to do something with t'-c
I
15 | slopes to kec-p them frotr, caving in; that's baa: Ci,l 1 j
!
"6 ji what we i.-i t-.-yir,- to do.
17 ! MP. CAVAGWEPDi RiGht.
r*^> .~- A ^. r*. r\% I , r^_ T
.,-.. !_-rir.i-.u_L: ao A
19 j gr££.t deviation between w|-,--it you are trying to do J.nd
what we are trying to do, except for the fact that we
would be redefining or reshaping ths brook front
Pleasant Street down to Grant Gear and you are not
doing that
rp. CAVAGNERO: We arc- not tailing about
o... are
"sr^i stcrc-J r.T
- ^ 4
^ J
-------
2
3
4
5
6
7
8
9
10
11
12
13
19
20
21
22
23
24
MR. CARROLL: Yes, but you are talking
about the major portion of the brook that we are going
to do which is from Grant Gear down to Neponset Street;
that's the longer length. We would certainly like to
work that out.
I will not keep on talking, but I would
certainly like to meet with you, Jane, at some early
time to work out some sort of details and get some sort
of a commitment on this.
Thank you.
MR. CAVAGNERO: Thank you.
Next is Theresa Luna.
.. M£. LUNA: My name is Theresa Luna. I livs
c.t. 3& AudoLon Road, Norwood.
There's just =-. couple questions I I.---.L- i?.
. ijc.rJi, t-i. the preferred sit: oL je: t i . as .
One.- is tJ.ct : would li!-:c- to ;,.-.c-w t!.«_- Icr^t:
: f tics of the cleanup. And, wher. you opt for the
flushing out of the PCEs versus c-fi-site incineration,
what is the time frame in the cleanup? Is it quicker
with incineration versus flushing.
And also another question is, ! feel that
if you flush out the PCBs in that area, the water t«t1e
is incredibly high. What is the chance of
-------
1
2
3
5
6
7
8
9
i:
21
22
23
24
25
'33
Also, in the abutting areas, will wells be
allowed to be drilled in the area, or is that area
forever not to be have any on-site wells drilled at
all?
Also, I would 1 i Ice to know how you inform
residents in the area about the contamination,
especially new residents that enter the area that know
nothing about it who are buying homes in the area?
I'm infuriated at the fact that this was
10 ' found in :93-*. I bought a house in July of 1935 and I
11 !i had no information -about this contamination until
I
12 || October of 1237. I would like to know why th&i-e'c. teen
13 J! ^u:i"; ;-et: corvee i r. giving out this informs-.*: on? Why,
u, .1 il I'jC'., i. fi:ap w;'S finally published i ri the paper- in
II
15 recfj.rds to the area that wcs abut ti fie. the Grant Gee/
1T ! Alao, or, the capped aree--, will c;.;'S still
"s I be allowed to be- parked on the area of contami ne-t . e-n,
^ !; wl'iere the- cap is coming apart in spots?
20 i I guess I'm very angry. I don't agree with
the soil and sediment contaminations that are going to-
be -- the preferred manner of dispensing with it. I
would prefer on-site incineration.
And ! just want the area cleor.td up. !
t!-.;r.: if.-. L.-e-a-n d^tblcd -ill-, cfio-.;:;.'.. T -..c\ ;..:'. it
Reui : t c-rccJ FT c- fc. _e,i :;-.;. 1 Px p :; t e-r r
-------
1
2
a
4
5
6
7
8
9
10
11
12
13
14
15
15
17
ia
19
20
21
22
23
24
40
out of there.
Thank you.
MR. CAVAGNERO: Thank you.
Next we have Stanley Wasil.
MR. WASIL: Some of these things Mr.
Carroll askc'd, but my problem is this I'm a Town
Meeting member, I might as well mention that. I
represent th.it whole area down there and I'm also a
resident that lives right behind thia PCBs and right
next to the Msadow Brook.
C;ie of my problems that I'm really
in tKc newspaper, I haven't seen it in tl'iis, of ss »&-.
/ec.:'S to »::. ;-£':t or to do the work on the MeacJcw r/oo!.
.'
MC. DOLING: Seven ye;.rs to cloc.- up t!.t
g: vundwat Ci' .
M?. WASIL: This is where I conic- to
loggerheads on. I don't like this.
Many of the people in the Meadow Brook ar
have storm drainage backups in their cellars and out
the streets and vhe lads are playing out in the stree
with thi: stL'ff coming out of there. And in mar.> c;.i
it could be- PCEs. Ue.have chemicals in that brook.
23 II .*.- ; t!.._ :, i: ;::-;-.- ^:.i.:r, t'.;z Lr-::'!
»\ [~ \i ^» ^ ^. ^ ^. ^ T » 11
. ta .1 > «... » V'> » * ' J
r. .; fcsi;or,c.l PC-(:-:. '.: .
' C1 "* ' * '-"'" ""*
-------
1
2
3
4
5
6
7
8
9
10
11
12
13
14
15
15
17
18
19
20
21
22
23
24
25
. '41
water comes down from a rainstorm, the water backs up
because it can't go down the brook because the brook is
too narrow.
We have another problem there. In fact, we
have several problems there. Ws have a pipe that goes
across the brook and the water can't go over it if it's
if the brook is brought down. So, Mr. Carroll's
come up with another method of getting the water down
the river. But we do have a problem down there with
Route 1 down there. It's not the The drainage ares
is, too narrow and it just keeps on going.
We'want to get started on this project and
Mr. Car -.'oil has come up with a plan to do this. And,
laeCw-uaiJ cf EPA's, slow action, this has been-going or.
over' two years, I know, trying to get this wo/i-. cor'iC,
t h i £ M e a d o w B r o o I; e x : a v a t i o n p r o j e : t as o " right r. : v is
standstill for another seven years.
I would like to see this done first. I
don't see any reason why this can't be done first, the
brook excavated because all you need is trucks to bring
the stuff away and then we can start digging this
thing up.
You did mention that there war. going to bcr
j.: floc-;j plur.u- wi c:-'_-.p<: i o: which cc-.-lu cau^c c-.JcJi.-d
-e^.-il--.-.-.-d r-,-'.: fi-ih.ic.-.:.l
-------
2
3
4
S
6
7
8
9
10
11
12
13
15
42
problems to the residents. We do have a problem there
it's well documented we have had helicopters come
in from the various newspapers and the radio and TV
stations taking pictures. It's on record and it's also
on record at the Board of Health. They have all kinds
of pictures of the flooding that goes on there.
So, I would advise you to take some kind of
precaution or come up with £ plan that if we start
getting flooded, you know, the PCBs are bad, but being
flooded out of your house is very bad, too and we don't
want this to happen.
£>.', I'm bringing these two areas up for
your consideration.
I have another one and I don't know how t:
address this orsc^ but this is a very serious problem.
t.'c c.re cleaning up, but we have some companies thj.t ;.. -
;~ l! Ctddiris t : our problems right now.
13
19
20
21
22
23
24
Most of us have read about Northrop. T!-.oy
got th&m for dumping. And there's a brook that rurri.
right behind them. Then you have Savagran who works or.
all kinds of chemicals and they also connect up to ti'.iz
Meadow Brook. Then WE got this foundry that's locatsi
right next to Savagran. They also work with the same
chemicals that were found in thc.t brook. And they
couldr. * t bcl :.;.:: i \ ./i.e.. th,;, we-. ; soinj it the nr.
F'c-g.i ;t sr c-d Pr..^s-ior.;»l r«.-p :-. '. c..- L
-------
1
2
3
5
6
7
8
9
10
12
15 -I
15 j
IT
21
22
23
24
25
the level of chemicals when this first came up.
So, I'm asking you, I don't know how we can
fit this in, I know you are working on PCBs, but if we
are resolving the PCBs, we shouldn't be letting other
chemicals come into the brook. And these are three
companies that work with this stuff that's in that
brook. I would like to get it cleaned up.
That's all I have? to say.
MR. CAVAGNERO: Next we have Arthur Rico.
MR. RICO: Yes. I live on Audobon Roac!.
i
11 I I would like to make on comment. I'm
against the chemical treatment as such. We h«-ve enough
chemicals in that ares now and we have enoug!. chemicals
being dumped, if.to the brook. Also it sec-ms that it's a
Ti~t f " * *" i~i * *" '" 't *'- i-''"'-"'!""1 * *' '- * t " -" * i'--- |-l-'i - - a-
bccc.uss of the cost factor, and that the sctuc.l , ir,
your statements, ntatci that the i nc inc,-;,t ion mctJ'.od
"s j! was a more proven method, although i t' z & little more
19 ; costly.
20 ; I think that with the chemicals in that
area and the environment and so forth, I would rather
see incineration used.
Thanl: you.
MR. CAVAGNERC: Now we have Joseph M.
i;-:_:!-.', Super inl one's-1 -.::' U.c- I-opi : t a^nt c f F^L I i :
- r-.^--./ i-.r~^.fT^. f T * i.-
i-ii .... r.Lr Ur. . . i «'j
i; F'._--i sti..-!-:: r ;.::,.-_! :,..: r--_ >...: ; tc-: .
-------
44
Works.
K£. WELCH: My name is Joe Welch and I'm
the Superintendent of the Public Works here in Norwood.
4 I have to go along with a lot of things
* that John Carroll said previously. But, we have been
trying to clean Meadow Brook for quite a few years and
7 take care of the channelisation of the whole brook.
8 Now,, with the problem that we have now down
cit the Grant Gear area, I hope that we can work
10 together and solve & lot of the problems
We have c drainage problem in the csntcr cf
12 touTi that relates to the Lrook.
13 And SO.TIS of these programs that we havs
- bien held bad. a little bit because c f
15 j C.:..T.- c' fit r sg^l at :.:- c-f the EPA and the TZCE. l: =
16 j; wcu:c- :ir-:c- to clc-~r L.; the pro . .
i!
j!
17 j prctliSn.; in t:-.i Cr^rt Qrar area and woi'!, togct!.;/ v:t:-.
18 i you to solve th& problems for the whcle- towr,, riot juit
19 thr one area.
2° So, I hope you can work with uc And do the
21 whole projectand not just the one major problem we
22 hsve. Wo would like to channelise the whclc brook ars
23 and clear up the F'CB problem, too.
24 Th«.nk you.
25
"; 51 itcrcL: rr ; f c. li :-;.: Pipe. '.-...._
-------
1 MR'. CAVAGNERO: Is there anyone else who
2
3
4
5
6
7
8
9
10
11
12
13
15
16
17
18
19
23
21
22
23
24
2£
'45
hasn't made a statement who would like to?
Could we Just get your name and the correct
spelling for the record, please?
MR. EVERS: Yes.
My name is Robert Evers, E-V-E-R-S. I'm a
resident of Hillside Avenue at the corner of Pellana
RC'c,d .
I have been very remiss in not attending
the recent meetings and actually came late tonight, but
I do have some serious concerns as a resident of the
It seem£ to ms- that About c. year and £. hal f
ago there we-re test well: dug at the corner of Hillside
i
one! Pel Ian a. They were dug the crew was out thtjre
at 7:20 Su..-;c!<:-/ miivn incs orie wec!-:C'~c. I called JZ..-.-L
Dowr'ii ng Tit tf'iwt pC'i r.t c.nd coi'ipl c.; ~,^-2 citc-ul. tl';2 nicr.
woriiing en Sunday morning at 7:30. But, no rc-ultc : f
that ever came forth. And I'm just not sure-, what were
the findings outside the Kerry Place area? Can anyone
address that?
I have a number of questions, that's number
one.
MS. DOWNING: We can ce-rtair.ly go into all
I:-.;. t .'d ~ t £. i 1 ev-n after the forme-.! re. ,!.,-., en4, ^^i.-;::. E.'l
-------
1
2
3
4
5
6
7
8
9
10
11
12
13
it
46
I c&n tell you very quickly that those wells turned up
clean.
MR. EVER£: They turned up clean.
It's my understanding that, earlier
tonight, although in "his description in the proposal,
you people maintain that there is no contamination in
the groundwater off of Grant Gear that somehow or other
it came out tonight that it turned out that maybe there
could be?
MS. DOWNING: No.
Should we wait until after the comments are
finished?
r~.:. CAVAGNER1: No, go aher-d.
MZ. DQUr.'ING: The groundwater wells that vz
15 ji sampltd outsici..' ths Grant Gear boundaries all turned up
cliii-r., ar.d t:-.rt includes veils i.cro-c from Mzadow
Drool;. So, -the only contaminated wells tl'.al »'c- ''.'..r.d
15
19
20
21
22
23
24
25
witiiii'i the. Grant Gear boundaries.
riF.:. CVEH:C: Have you sampled resident's
wells in the area that might have groundwate.' wells?
M2. DOWNING: Mo, we haven't. In fact, if
you know of £-,> residential wells in the area, we would
1 i he to I.:now about them.
f-P. EVERS: I h«ve a neighbor U.«.t haz a
C.: --'L ~. J !*.-' '-_... " . L! 2£' C i w OPi . j . O:' Z ,--."«.".'...;. if '. . . _
-------
3
4
5
6
7
8
21
22
23
24
2=
47
lawn, but if this chemical is there, then I think that
his and all wells in that area should be tested.
I don't think my coming up with the names
is important, I think you have to
MS. DOWNING: Well, we can explain exactly
where the contamination started. And we think we have
defined exactly where it is and we do not feel that
it's outside the Grant Gear boundaries.
I will show you the maps and where it's
going so you can see exactly where we think' it is,.
MR. EVZRS: Than!-, you, I would appreciate;
9
10
11
12
i!
13. j| I' ITI curious that the source of the DOCc, and
I, .
14 ji Ihs SAAa a:-i all the othor letters that are cominq ou'i,
jl
15 ij that there':, & siu. cs that's identifiable, you I.:r.o.,
you dor.'t '.>:..£ '.;. .'.ai^c. na^i-, but hive' you fourc1 i.
-our-it for Li'ij.!;'"' Is th;,t also industrial in n;.ture?
MS. DCl'NING: Uc haver,'t specifically
me-nt i oried wl'i;;t company was fj.i r ly. responsible for wi;;-,t
20 ! chemicals. We feel that with industries and industries
normally use all kinds of chemicals, they use
degreasers, and as part of degreasers, you can get sc-iv:r
of t h c.- cl'i e M i c a 1 s t h a t we i oun d.
So, wo don't know specifically wl'.at corr.p i.;.j
:.:; I-L r ;:-;; t.,: v fc-v -!.... t j'^.:' t i : ul af .ilii-.ni . c.: , tut wi
-------
'48
feel that the nature of the businesses that were there
2 in the past, most of them could have contributed to the
3 VOCs that we found.
MR. MC ALLZSTER: Jane, maybe he's asking,
5 though, if we know what the source of the contamination
* of the groundwater site. I mean, I think that we have
7 identified the source of where the contamination is,
8 has been coming from.
9 MS. DOWNING: Right.
10 As far as the area, we feel that the source
cf where the groundwater contamination is coming from
12 is basic ally in the back of Grant Gear. So that area
13 right in the back of Grant Gsar is where most of the
14 ground wit e-r cent ami nation turned up, highly
15 contaminated groundwctsr compounds. From there,
'6 !.-,£ traveled, the way the flew was going t:.c /a! L. . £
1 decrease.
18 So, just by looking at where the chemicals
19 are turning up, we feel that the source arcc is in the
20 back of the building.
21 MR. EVERS: Being a layperson and not aw.;.;-;
22 of the EPA standards that they set for super fund mc-nici
23 &nd so on, it seems to me, just reading this, that it*_
24 somewhat hypocritical in the sense that, Oh, well, ^.c.
25 c.. d- w.'.-ir.:; 1.., (Jo tl.ic.. We are c,*ir.i. t _ ;. :a.c-.*c -''., "I1'. '.'
.1 '-. . . 4 ,..._--.-. 1
wJ f _' I U _ . * -'. I wt «
(GIT- '%2.C 3'! 7"
-------
1
2
3
4
5
6
7
8
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25
49
cubic yards of soil, WE are going to excavate 3,000
cubic yards of sediment from the brook, but we are
going to bury a lot of other things. You are just
going to let it sit there.
We are going to leave the pavement. We are
only going to dig it up if it's really in excess of the
highest of standards. I mean, we are not going to go
into Grant Gear and find out what's.underneath Grant
Gear. We are going to put something over their roof.
Ws are going to sort of entomb a pipe in the ground.
It seems to me that this is « very
hypocr i t i <:al approach to hazardous waste. I know you
hav
-------
1
2
3
4
S
6
7
8
9
10
11
12
13
14
15
'30
19
20
21
22
23
as a buyout of .the Grant Gear and clean that property
up.
MR. CAVAGNERO: Me will address that in the
ROD and we will respond to that comment.
MR. EVERS: Finally, I would like to echo
my sentiment with respect to introducing further
chemicals to the area in the clean up process, better
left undone than to bring more chemicals in there in
the process.
MR. CAVAGNERO: I would just like to
clarify that before anybody leaves tonight. The
process wo arc talking about is basically washing the
soils. In other words, using something akin to a
detergent to get the toxic pollutants out cf the sciIs.
The fc.ct that we. are using chemicals to do it doesn't
15 ;J (iisr.r. that c-r :..& then
17
I """ "
HR. EVCF:5: It seems to be ir,;> e, per i cr.; r
tli«t the Zr.*. c.r.d medicine finds additional care i noser, i
every day of the week. It seems 1 i ke you can't turn ;:.
the TV and siy, Well, you can't eat this and you c«r.'t
do that. S-o, I'm going to reiterate, introducing «.nj
chemicals, «r.> further chemicals to thc.t «rc« is
completely against my wishes.
25
-
rli L. . i .»- -i i . . -
ii z, i 11 c. _ w Pr c> *'. - s i or. ;. 1 . ;,.. -i i .
-------
1
2
3
4
5
6
7
8
o
1
u
15
1o
IT
15
19
20
21
22
23
24
25
MR. CAVAGNERO: Well, if we don't have
anyone? else, we would like to make an oral statement
yes, we do. Okay, one more.
Please state your name for the record.
MR. RABBITT: My name is Joseph Rabbittr
R-A-B-B-I-T-T. I live at 93 Audobon Road.
My wife has been coming to these meetings,
but she couldn't come tonight.
9 On page 7 you say that you propose a soil
10 ;; cleanup level of 1 ppm. You quys came up a little o.'sr
I!
11 ; a year aqo and tested in ir.y backyard, less then 20 feet
i!
12 j! from my house, and found levels nearly twice that. Arc
li
13 j! you going to clean that up for us? Just a simple yss
or no.
MS. DOWNING: We anticipate it.
K-r- r> * '-TV "-r o'- ,.-v rii. -x,
I i . 1 . i <..'*.'* i w i y ui '»''-' w L.1 . wi j *
The other tiding is, wt liad tlood tests c'onc
or. June 3th, which is like two and a half months a 3-:..
Us haven't heard anything. Have you guys heard
anythi ng?
MS. YOUNG: We are still waiting for the
results from the Department of Public Health on ths* .
MR. RAEDITT: Will we- know soon?
M2. YOUNG: Yes, we should know within the
n;.;t ,T,c,-.t!, :; .--.-. '... --.:..-. -.as
F.'cci cl £: i-d Pr :', c-c: _.* -.-ric.; rx ;. . . 1.; . ^
-------
1
2
3
4
5
6
7
8
9
10
11
12
13
14
15
16
report, I will make it available to the public.
MR. RABBITT: That's al 1 I have.
Thank you.
MR. CAVAGNERO: Would anyone else like to
make a comment?
(No response)
MR. CAVAGNERO: With that, I would like to
thank you all for coming and sharing your commsnts and
concerns with us and again, remind you that you still
have until September 9th to submit written comments,
whether or not you have made common tc tonight and that
we will, sgsin, respond to any cc."...T."itz made cith^i' at
tonights hec-ring or in writing wJicn we issue the. Record
of Decision.
TharMc you for your attention sr.c! for your
(The public hearing concluded st S: %5 p.p.)
i ~
I
18
19
20
21
22
23
24
25
AF'ZV F'HrZ'T'T I* I'l
-------
53.
CERTIFICATE OF REPORTER AND TRANSCRIBER
This is to certify that the.attached proceedings
before; RICHARD CAVAGNERO, Chairman
in the Matter of:
PROPOSED CLEANUP PLAN. FOR THE
NORWOOD PCB SUPERFUND SITE
Place: Norwood, Massachusetts
Date: August 24, 1989
were held as herein appears, and that this is the true,
accurate and complete transcript prepared from the notes
and/or recordings taken cf the above titled proceeding.
Martin T. Farley ' 8/31/89
Reporter Date
Laura Madi 8/31/89
Transcriber . Date
-------
APPENDIX B
ADMINISTRATIVE RECORD INDEX
NORWOOD PCB SUPERFUND SITE
-------
APPENDIX C
STATE CONCURRENCE LETTER
NORWOOD PCB SUPERFUND SITE
-------
Z7L
of $n*«'
o£ ^vlaMcuJui6e£&
Q)
-------
Paul Keough.
U.S.. EPA
Pag* Two
As required by the MCP;-a temporary solution must (1) include a plan for
developing a permanent solution, (2) include systems to monitor its effec-
tiveness, and (3) remain effective until a permanent solution is implemented.
The Department, therefore, anticipates that the effectiveness of the institu-
tional controls provisions as well as the feasibility of new technolgies will be
evaluated on a continuing basis.
The proposed remedy appears to meet all ARARs. The Department will con-
tinue to evaluate the. ARARs as remedial design progresses and during implemen-
tation and operation of the remedy.
The Department looks forward to working with you in implementing the pre-
ferred alternative. If you have any questions or require additional infor-
mation, please contact Dale Young, Project Manager, at (617) 292-5785.
Daniel 9-T Greenbaum,
Commissioner
DS/DY/bkt
cc: Anne Bingham, DEP - OGC
Steve Johnson. DEP - NERO
Helen Waldorf. DEP - Boston
Jane Downing. EPA \S
------- |