PB96-963118
EPA/AMD/R01-96/125
December 1996
EPA Superfund
Record of Decision Amendment:
Norwood PCB Superfund Site,
Norwood, MA
5/17/1996
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RECORD OF DECISION AMENDMENT
NORWOOD PCB SUPERFUNP SITE
DECLARATION
SITE NAME AND LOCATION
Norwood PCB Superfund Site
Norwood, Massachusetts
STATEMENT OF PURPOSE
This decision document presents an amendment to the United States Environmental
Protection Agency's ("EPA") selected remedial action chosen in a Record of Decision signed
on September 29, 1989 ("the 1989 ROD") for the Norwood PCB Superfund Site, in
Norwood, Massachusetts. This amended selected remedy was chosen in accordance with the
Comprehensive Environmental Response, Compensation, and Liability Act of 1980
("CERCLA"), as amended, 42 U.S.C. § 9601, et seq.. and is consistent, to the extent
practicable, with the National Oil and Hazardous Substances Pollution Contingency Plan
("NCP"), 40 CFR Part 300. This amendment is made in accordance with Section 117 of
CERCLA, 42 U.S.C. § 9617, and 40 CFR § 300.435(c)(2)(ii). The Regional Administrator
has been delegated the authority to approve this amendment to the Record of Decision. The
Regional Administrator has further delegated this authority to the Director of the Office of
Site Remediation and Restoration.
The Commonwealth of Massachusetts has concurred on this amended selected remedy and
determined, through a detailed evaluation, that the amended selected remedy is consistent
with Massachusetts laws and regulations.
STATEMENT OF BASIS
*
This decision is based on the Administrative Record compiled for this Site which was
developed in accordance with Section 113(k) and Section 117 of CERCLA and 40 CFR
300.435(c)(2). The Administrative Record is available for public review at the Morrill
Memorial Library in Norwood, Massachusetts and at the EPA Region I Office of Site
Remediation and Restoration Records Center in Boston, Massachusetts. The attached index
(Attachment A) identifies the items which comprise the Administrative Record upon which
the selection of the remedial action is based.
DESCRIPTION OF THE ORIGINAL REMEDY
The remedial action selected in the 1989 ROD consisted of:
1) Groundwater extraction and treatment;
2) Excavation, treatment via Solvent Extraction, and subsequent re-disposal of
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contaminated soils and sediments; and,
3) Remediation of the Grant Gear building.
DESCRIPTION OF THE AMENDED SELECTED REMEDY
The amended remedy will consist of:
1) Demolition of the Grant Gear building;
2) Consolidation of contaminated soil, and soil and sediment from Meadow
Brook, onto a portion of the Grant Gear property;
3) Removal of "hot spot" of contamination below the water table;
4) Covering of the most heavily contaminated areas of the Grant Gear property
with an asphalt cap and covering of other areas with clean fill material;
5) Periodic monitoring to assess performance and protectiveness of the remedy;
6) Inspections and maintenance of the cap & cover; and,
7) Continued on-Site groundwater extraction and treatment.
DECLARATION
The amended selected remedy is protective of human health and the environment, attains
applicable and relevant and appropriate requirements ("ARARs") and is cost effective. The
amended selected remedy includes statutory waivers under the Toxic Substances Control Act
("TSCA") pertaining to four components for TSCA chemical waste landfills. The amended
selected remedy utilizes alternate treatment technologies or resource recovery technologies to
the maximum extent practicable. However, the amended selected remedy does not satisfy the
preference for treatment which permanently and significantly reduces the toxiciry, mobility,
or volume of the hazardous substances as a principal element.
This amended selected remedy does not change the groundwater portion of the 1989 ROD,
except that removal of die "hot spot" of contamination will likely remove a source of
downgradient groundwater contamination. This amended selected remedy does not re-
analyze the remedy selection criteria, such as overall protection of human health and the
environment and attainment of ARARs, pertaining to the groundwater portion of the remedy,
Because the amended selected remedy will still result in hazardous substances remaining on-
Site, a review will be conducted periodically (at a minimum every five years) to ensure that
the remedy continues to provide adequate protection of human health and the environment.
l\Qa n '4*
Linda M. Murphy, Director /
Office of Site Remediation and Restoration
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RECORD OF DECISION AMENDMENT
NORWOOD PCB SUPERFUND SITE
TABLE OF CONTENTS
Page Number
I. INTRODUCTION 1
II. SITE DESCRIPTION 1
III. PURPOSE OF AMENDED RECORD OF DECISION 2
IV. SITE HISTORY AND ENFORCEMENT ACTIVITIES 3
V. COMMUNITY RELATIONS HISTORY 6
VI. SUMMARY OF SITE CHARACTERISTICS AND 7
REASONS FOR THE ROD AMENDMENT
VH. DESCRIPTION OF ALTERNATIVES 8
VIH. COMPARATIVE ANALYSIS OF ALTERNATIVES 17
IX. THE AMENDED SELECTED REMEDY 24
X. DOCUMENTATION OF CHANGES FROM THE 24
PROPOSED AMENDED CLEANUP PLAN
XI. STATUTORY DETERMINATIONS 25
XH. EXPLANATION OF SIGNIFICANT DIFFERENCES 30
FROM 1989 RECORD OF DECISION
Xm. DOCUMENTATION OF NON-SIGNIFICANT CHANGES 31
TO 1989 RECORD OF DECISION
XIV. STATE ROLE 31
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LIST OF TABLES AND FIGURES
Figure Number/Title
1. Site Location Map
2. Sice Vicinity Map
3. 100-Year Flood Plain
4. Site Plan Showing 1983 Removal Action and Interim Measure Cap
5. Conceptual Outline of Soil Cleanup Levels and Extent of Cap
Table Number/Title
1. Soil Cleanup Levels
2. ARARs affected by ROD Amendment
Attachments
A. Norwood PCS Superfuhd Site Administrative Record Index
B. Norwood PCS Superfund Site Responsiveness Summary
C. Commonwealth of Massachusetts Declaration of Concurrence Letter
D. Norwood PCS Superfund Official Public Hearing Transcript, March 6, 1996
E. Regional Administrator's Findings and Waivers under Regulations of the Toxic
Substances Control Act
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RECORD OF DECISION AMENDMENT
NORWOOD PCB SUPERFUND SITE
DECISION SUMMARY '
I. INTRODUCTION
Site Name: Norwood PCB Superfund Site
Site Location: Norwood, Norfolk County, Massachusetts
Authority: CERCLA Section 117 and 40 CFR 300.435(c)(2)(ii)
Date of Original Record of Decision: September 29, 1989
Administrative Record: This Amended Record of Decision as well as documents
supporting this decision document will become pan of the
Administrative Record for the Site.
The Administrative Record is available for public review at the
following information repositories:
Morrill Memorial Library
Walpole Street, Norwood, MA 02062
(617) 769-0020
Hours: Monday-Thursday 9:00 am - 9:00 pm,
Friday 10:00 am - 5:00 pm,
Saturday 9:00 am - 5:00 pm,
and Sunday 1:00 pm - 5:00 pm
• and,
EPA Records Center
90 Canal Street, Boston, MA 02114
(617) 573-5729
Hours: Monday-Friday 10:00 am - 1:00 pm,
2:00 pm - 5:00 pm.
U. SITE DESCRIPTION
The Norwood PCB Site is located approximately 14 miles southwest of the City of Boston.
The Site consists of several parcels of land including industrial/commercial properties and
associated parking areas. To the north, the Site is bordered by and includes Meadow Brook
and its banks, 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 Pellana Road. Figures 1
1
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and 2 illustrate the Site location and vicinity.
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, beyond
Meadow Brook and a wooded area. Assuming an average of 3.8 residents per home, there
are approximately 3040 residents living within a ]/i mile radius of the Site.
To the east of the Site is the heavily traveled 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, a
Direct Tire dealership and a Mobil gasoline station are located to the southeast of the Site,
near 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 wooded 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 the 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 Brook
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.
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. An
undetermined number of residences in the area reportedly 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,
1989).
in. PURPOSE OF THE AMENDED RECORD OF DECISION
The purpose of the Amended Record of Decision is to formally specify changes to the
previously issued Record of Decision. The Amended Record of Decision describes the
changes adopted and presents an evaluation of the changes in relation to the technologies
which were selected in the original Record of Decision. In addition, it presents the rationale
for changing the Record of Decision, the Commonwealth of Massachusetts and public
perspectives on the change, and a Responsiveness Summary which is EPA's response to
public comment on the change.
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IV. SITE HISTORY AND ENFORCEMENT ACTIVITIES
A. Site History
Contamination at the Norwood PCB Site originated from disposal practices of the parties who
owned property at the Site 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 activities. In October 1947, the land was purchased by
Tobe Deutschman Corporation, which manufactured electrical equipment at the She,
including capacitors and transformers. The property was purchased in October 1956 by
Comell-Dubilier Electronics, Inc. ("CDE"), which also manufactured electrical equipment at
the facility. In January 1960, the property was briefly owned by Mary vale Corporation, and
was then purchased by Jack, Harold, and Leonard Friedland (collectively the "Friedland
Brothers"). The Friedland Brothers leased the property to Federal Pacific Electric Company
("FPE"1), which held the lease on the property until October 1979. During the period from
1960 to 1979, FPE operated a business at the Site, and sublet portions of the facility to CDE
and to Arrow Hart Corporation, a predecessor to Cooper Industries, Inc. ("Cooper") 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 a
vacant lot and the then-Norwood Hyundai automobile dealership, now a Direct Tire
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.'
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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. One lot at the corner of Dean Street and Kerry
Place remains vacant.
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 Place between Pellana Road and the
Grant Gear property. As a result of this call, an initial field investigation by DEP was
conducted. On April 6, 1983, DEP sampled surficial soils and Meadow Brook sediments.
The initial DEP investigations confirmed Polychlorinated Biphenyl ("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
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support using Superfund money. EPA dispatched its 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 was appropriate to address all soils outside the Grant Gear
property with PCB concentrations greater than 50 parts per million (ppm). 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 its 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 of 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. This immediate 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 ("NFL") of sites eligible for cleanup under the Superfund program.
EPA proposed to add the Site to the NPL on October 15, 1984 (49 FR 40320), and the Site
was 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 CDE, 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 temporary cap over a 1.5 acre portion of the
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.
In 1992 EPA began its remedial design phase for the cleanup, beginning with a series of
"Pre Design Studies". Studies were completed in late 1992 and are summarized in a report
prepared in January 1993 by Metcalf & Eddy, Inc. Final plans and specifications for the
groundwater and soil/sediment portions of the cleanup as set forth in the 1989 ROD were
completed in 1994.
Remedial action at the Site began in late 1994 Ebasco Constructors, Inc. (later known as
Enserch Environmental and now as Foster-Wheeler Environmental) was issued a delivery
order under the US Army Corps of Engineers' Total Environmental Restoration Contract
("TERC") for construction and initial operation of the groundwater treatment facility.
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Construction of this facility was completed in late 1995 and the plant is currently in
operation. In addition, a decontamination effort for equipment and machinery inside the
Grant Gear building was conducted in 1995, as was the excavation of contaminated soils
from four "outlier" areas located outside of the Grant Gear property. Planning and
contracting activities for the soil/sediment solvent extraction remedy outlined in the 1989
ROD gave rise to the issues outlined in this ROD Amendment.
A more detailed description of the Site history can be found in the RI Report (Ebasco, 1989).
B. Enforcement History
The 1989 Record of Decision contains a comprehensive history of enforcement activities
through 1989. Since that time, there have been several enforcement developments.
Pursuant to Section 122(e) of CERCLA, in March, 1990, EPA sent special notice letters to
CDE, FPE, Cooper, the Friedland Brothers, and the Town of Norwood. Subsequent
negotiations seeking performance of the remedy selected in the 1989 ROD by those parties
were unsuccessful, and in August, 1990, EPA issued an administrative order under Section
106 of CERCLA to CDE. FPE, Cooper, and the Friedland Brothers compelling those parties
to perform the remedy. To date, the parties have not complied with that order.
In 1991, the United States entered into a settlement with Grant Gear Works, Inc. and John
and Robert Hurley, whereby the Hurleys agreed to pay certain money to the government and
provide access and institutional controls on property they control.
In 1992, the United States and the Commonwealth of Massachusetts initiated a lawsuit
against CDE, FPE, Cooper, and the Friedland Brothers hi federal court. In that lawsuit, the
governments seek reimbursement of response costs, a declaratory judgment as to the
defendants' liability for future response costs, and civil penalties and/or punitive damages for
defendants' failure to comply with the 1990 Administrative Order.
In 1994, the United States and .the Commonwealth entered into a settlement with the
Friedland Brothers. That settlement required the Friedlands to pay certain money to the
United States, and also required the Friedlands to assign to the United States and the
Commonwealth certain proceeds of indemnification claims that they have against CDE,
FPE, and Cooper.
Settlement negotiations with CDE, FPE, and Cooper have continued sporadically since the
initiation of the governments' lawsuit in 1992. Negotiations related to the Site are also
ongoing with John and Paul Reardon and the Town of Norwood.
Technical comments presented by several 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 B of this ROD
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Amendment. In addition, these documents are included in the Administrative Record for the
Site.
V. COMMUNITY RELATIONS HISTORY
Through the Sice's history, community concern and involvement has been average. 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 responsiveness
summary attached to the 1989 Record of Decision.
On May 24, 1994, EPA held a public meeting to announce the completion of the remedial
design phase for the groundwater remediation and to address questions regarding the
implementation of the remedy.
On August 7 and August 10, 1995, EPA held public meetings to outline new developments in
the remedial action at the Site and to invite public comment on the approach to the soil
cleanup portion of the Site remedy. The public was invited to comment on a potential
change in the cleanup plan through August 18, 1995.
On February 22, 1996, EPA began a 30 day public comment period to accept public
comment on the Proposed Amended Cleanup Plan and on the other documents which were, a
part of the Administrative Record for the Site. At that time, EPA made a supplement to the
Administrative Record available for public review at EPA's offices in Boston and at the
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Mornll Memorial Library in Norwood, Massachusetts. EPA published a notice and brief
description of the Proposed Amended Cleanup Plan in the Norwood Bulletin on February 21,
1996 and in the Patriot Ledger on February 22, 1996 and made the plan available to the
public at the Merrill Memorial Library. On March 6, 1996, the Agency held a public
hearing to accept oral comments. A transcript of this meeting is included as Attachment D
to this ROD Amendment and the comments and the Agency's responses are included in the
Responsiveness Summary, which is included as Attachment B to this ROD Amendment.
VI. SUMMARY OF SITE CHARACTERISTICS AND REASONS FOR THE ROD
AMENDMENT
A complete description of the Site characteristics can be found in the 1989 ROD.
The remedial action at the Site has been ongoing since late 1994. Since that time, EPA. has
partially completed cleanup activities. The Site support area has been fenced and
constructed, the groundwater treatment plant has been constructed and is now operational, 57
pieces of machinery and equipment from inside the Grant Gear building have been
decontaminated, and four "outlier" areas, small areas of soil contamination outside of the
Grant Gear property, have been excavated. EPA also issued a request for proposal regarding
the soil/sediment solvent extraction portion of the remedy as outlined in the 1989 ROD.
Early in 1995, EPA received a proposal from its contractor for the implementation of this
work. That proposal's cost greatly exceeded prior cost estimates as well as available funding
for the project1. Also based upon that proposal, EPA believes that there would be
difficulties in properly siting the appropriate solvent extraction facilities on the Site due to
space constraints and safety issues. Based upon these revise'd cost estimates and siting
constraints, EPA determined that it was necessary to amend the remedy for the Site.
Considering the need to amend the remedy for the Site and the amount of time elapsed since
the original risk analysis to support the 1989 ROD, EPA also determined that the risk-based
Site cleanup levels should be re-examined. Prior to release of the Proposed Amended
Cleanup Plan, EPA performed a re-analysis of Site risks to assess the appropriateness of
cleanup goals and to determine what revised human health risk calculations would be
produced by current EPA methodologies and approaches to risk assessments (developed since
the 1989 Endangemient Assessment for the Site was completed). In addition, the anticipated
future land use at the Site has been further clarified since the 1989 ROD, which resulted in
changes to several exposure scenarios used in the risk calculations. The impact of these
changes was also considered in EPA's re-analysis. Ecological risks at the Site also were re-
examined to determine if any adjustments to cleanup levels driven by ecological risks were
appropriate (mainly the Meadow Brook sediment/soil cleanup level). Based on the
'The 1989 ROD estimated the then present value of the soil/sediment solvent
extraction remedy at $13.3 million (1989 dollars). The 1995 proposal estimated cost at
S54.8 million.
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clarification of future land use and changes in nsk assessment methodologies, new cleanup
goals were developed and proposed in the Proposed Amended Cleanup Plan, and now are
adopted as part of this ROD Amendment. These new cleanup goals and their associated
incremental carcinogenic risks after cleanup are discussed in Section VII.B.3. for each area
of the Site and are summarized in Table 1
VII. DESCRIPTION OF ALTERNATIVES
Section VILA, outlines the alternatives evaluated in the 1989 ROD, and Section VILB.
describes the new elements of the amended selected remedy as adopted by this ROD
Amendment.
A. Alternatives Evaluated in the 1989 ROD
The 1989 ROD evaluated five alternatives to address soil and sediment contamination at the
Site. Four alternatives to address contamination of the Grant Gear drainage system were also
evaluated. Finally, the 1989 ROD also evaluated four alternatives to address management of
migration of contaminants through the groundwater.
The five alternatives to address soil and sediment contamination were as follows:
SC-1: Minimal action alternative
This alternative included fencing, institutional controls, public education programs,
long-term monitoring, and five-year reviews.
SC-2: Containment Alternative
This alternative consisted of consolidating outlying contaminated soils and sediments
under an impermeable cap constructed on-Site, long-term monitoring, and five-year
reviews.
SC-3: Treatment Alternative: On-Site Solvent Extraction
This alternative was chosen in the 1989 ROD as the remedy for source control. This
alternative consisted of the excavation of contaminated soils and sediments, treatment
on-Site using the innovative technology solvent extraction to extract contamination
from the soil, and disposal of treated materials on-Site.
SC-4: Treatment Alternative: On-Site Dechlorination
This alternative consisted of the excavation of contaminated soils and sediments,
treatment on-Site using a dechlorination technology to detoxify the PCB
contamination, and disposal of treated materials on-Site.
SC-5: Treatment Alternative: On-Site Incineration
This alternative was chosen in the 1989 ROD as a contingent remedy to be employed
if solvent extraction was determined not to be implementable or would not be
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effective in achieving cleanup levels. This alternate e consisted of the excavation of
contaminated soils and sediments, treatment on-Siie using incineration, and disposal of
treatment residuals on-Site.
The four alternatives to address contamination of the Gram Gear drainage system were as
follows:
SC-A: No Action Alternative
This alternative assumed that the building use would continue without modification
and without change of occupancy and included only long-term monitoring of
contamination.
SC-B: Flushing/CIeaning of the Drainage System
This alternative involved the flushing and cleaning of the Grant Gear building's
drainage system. This alternative was selected as a component of the overall building
source control remedy in the 1989 ROD. The 1989 ROD stated that if flushing and
cleaning was not able to meet cleanup goals, the drainage system would be contained
and replaced, as discussed in alternative SC-C below.
SC-C: Containment of the Drainage Svstem
This alternative involved flushing and cleaning of the drainage system, the subsequent
filling of the pipes and manholes with concrete or slurry, and the installation of a new
replacement drainage system. This alternative also included long-term monitoring, '
institutional controls, and five-year reviews.
SC-D: Removal of the Drainage Svstem
This alternative involved the flushing and subsequent removal of all contaminated
piping and manholes and disposal of these materials off-Site, A new replacement
drainage system would then be installed.
The remedy selected in the 1989 ROD for the Grant Gear building also called for the
cleaning and sealing of roof surfaces and the decontamination of surfaces of machinery and
equipment inside the building and building floor surfaces.
Management of migration (i.e. groundwater) alternatives from the 1989 ROD are not restated
here because that-component of the remedy remains essentially unchanged from the remedy
selected in the 1989 ROD.
A full description of all the alternatives previously evaluated and selected for the Site can be
found in the 1989 ROD, the Feasibility Study for the Norwood PCB Site (Ebasco, 1989),
and the Grant Gear Building Feasibility Study (Camp, Dresser, & McKee, 1989).
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B. New Proposed Alternative/Amended Selected Remedy
In addition to the alternatives set forth in the 1989 ROD, EPA developed a new proposed
alternative for the Site, which was set forth in the February, 1996 Proposed .Amended
Cleanup Plan. EPA believes that the new proposed alternative is a more suitable response to
the revised cost estimates and siting constraints of solvent extraction, and the re-analysis of
Site risks, as described in Section VI., than any of the alternatives from the 1989 ROD.
Following is a description of the new proposed alternative, as set forth in the February, 1996
Proposed Amended Cleanup Plan, and as further modified by EPA based on its own further
analysis and on comments received from the Commonwealth, the Potentially Responsible
Panics ("PRPs"), and the public. This ROD Amendment selects this new proposed
alternative as the cleanup approach for the Site.
According to EPA guidance, there are three categories of Post-ROD remedy changes:
"fundamental changes" to the ROD require a ROD Amendment; "significant changes" to a
component of the remedy require an Explanation of Significant Differences, and "non-
significant changes" require documentation to the EPA Site file. (See Interim Final Guidance
on Preparing Superfund Decision Documents. OSWER Directive 9355.3-02. June, 1989).
Analyzed individually, not all of the five components of the proposed alternative discussed
below constitute fundamental changes to the 1989 ROD. However, EPA believes that
together these five components constitute the most important aspects of the proposed remedy
change. Therefore, the February, 1996 Proposed Amended Cleanup Plan and this document
subject all of these five components to the requirements for "fundamental changes" as set
form in EPA guidance documents. Other modifications to the remedy which are not
fundamental changes to the remedy in the 1989 ROD but which do represent significant or
non-significant changes are discussed in Sections XII and XIII of this document.
1. Demolish Grant Gear Building
The industrial building at the Site, known as the Grant Gear building will be demolished.
Prior to demolition, appropriate asbestos abatement and disposal will be conducted. Once
the demolition is completed, the debris material may be handled in several ways. First,
PCB-contaminated building contents and debris may be consolidated on-Site in the subsurface
boiler room area of the Grant Gear Building. Any such materials will be consolidated into
this subsurface area in a manner which minimizes void space and will resist settling over
time. Any PCB contaminated materials that cannot be placed in the boiler room due to space
constraints, will be disposed of at an appropriate off-Site facility. Second, certain materials,
such as structural steel, may also be subject to federal Resource Conservation and Recovery
Act ("RCRA") requirements. These materials will not be placed in the boiler room or
elsewhere on the Site, but will be disposed of at an appropriate off-Site facility complying
with RCRA and TSCA requirements as necessary. Third, debris which may be
uncontaminated, may be reused or recycled, as appropriate. For instance, certain block and
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brick from the building may be usable as part of the sub-base for the cap described in
Section VII.B.4. Also, if deemed cost-effective, certain contaminated debris may be reused
or recycled if properly decontaminated. Finally, any other material which may be
inappropriate for on-Site disposal, or otherwise precluded from on-Site disposal by law or
regulation, will be disposed of at an appropriate off-Site facility.
Sediment and sludge material from the property's drainage system manholes, including
sediment from drainage system manholes stockpiled from previous excavation activities, will
be removed from the Site and disposed of properly at an appropriate off-Site facility. The
below grade portions of the drainage system will be filled with concrete or slurry and left in
place under the cap described in Section VII.B.4. Existing building foundations will be left
intact and covered by the cap. The underground fuel storage tank which serves the
building's boiler will be decommissioned in accordance with applicable regulations.
This portion of the proposed alternative achieves the same remedial goals as described in the
1989 ROD; namely, to reduce risks from direct contact with contaminated surfaces in and on
the Grant Gear building. The 1989 ROD selected decontamination of the interior surfaces of
the building and decontamination or encapsulation of roof surfaces of the building and
flushing and cleaning or containment and replacement of the building's drainage system so
that use of the building could continue. Since that time, Grant Gear has ceased its operations
on the property, and it is unlikely that the existing building will be used again. Considering
this change hi use and the limited effectiveness of decontamination, the proposed alternative
includes demolition of the building.
2. Excavate Area of High Concentrations of Chlorinated Organic Compounds to
Eliminate a Continuing Source of Groundwater Contamination
In order to further limit continued contamination of groundwater underlying the Site, a small
"hot spot" of contaminated soil at or below the water table located on the west side of the
Grant Gear building will be excavated. Contaminated soils exceeding 97 ppm of 1,2,4
trichlorobenzene (the soil cleanup level established hi the 1989 ROD for this constituent in
unsaturated soils) will be disposed of on-Site under the cap described in Section Vn.B.4. or
at an appropriate off-Site facility. As with all soils below the seasonal low water table,
excavation of these soils was not addressed in the 1989 ROD. This additional item of work
will remove contaminated soils located in the vicinity of highest groundwater contamination.
Excavation of these soils will likely remove a source of downgradient groundwater
contamination and should serve to lower overall contaminant levels hi the groundwater
underlying the Site, thus possibly resulting in a shorter and less costly groundwater cleanup.
It is not certain whether the contaminants in these soils would exceed regulatory limits set
forth by RCRA regulations. If they do exceed these limits, the hot spot soils would be
designated as hazardous wastes under RCRA. Disposal of RCRA hazardous wastes under
the cap would require compliance with RCRA requirements, such as RCRA Subtitle C
hazardous waste landfill requirements. These RCRA requirements would add significant
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expense to the proposed alternative and are otherwise not necessary for the proposed
alternative to be protective. Therefore, the proposed alternative includes removal of these
soils to an appropriate off-Site facility if these soils are determined co be hazardous under
RCRA.
t
3. Excavate and consolidate contaminated soils from portions of Grant Gear property
and from other surrounding properties, including contaminated soils and sediments
from Meadow Brook, and restore the Brook consistent with the Town's flood control
project
The 1989 ROD set a PCB cleanup level of 10 parts per million (ppm) for surficial and
subsurface soils located on commercial/industrial parcels. This ROD Amendment, based on
a recalculation of the risk assessment (described in more detail below), sets PCB cleanup
levels for soils outside of the area to be capped with the asphalt cap at 40 ppm at the surface
(top one foot) and 70 ppm in the subsurface (soils one foot to six feet deep). Likewise, this
ROD Amendment changes the PCB cleanup level for the wooded area north of the Grant
Gear property from 1 ppm in surface and subsurface soils to 10 ppm at the surface and 50
ppm in the subsurface. The cleanup plan relative to Meadow Brook remains essentially
unchanged (i.e., cleanup level of 1 ppm PCBs), except contamination above 1 ppm PCBs
may be left in place provided that it is adequately encapsulated by the materials to be placed
on the bottom and sidesiopes of the Brook as part of its restoration. Figure 5 shows the
general Site locations where these different cleanup levels apply.
Following is an outline of the consolidation activities to be conducted. These items are
organized according to area:
Soils on Commercial or Industrial Properties
Surficial soils (top 1 foot) exceeding 40 parts per million (ppm) and subsurface soils (1 foot
to 6 foot deprn) exceeding 70 ppm PCBs located on portions of the Grant Gear property as
well as on commercial properties adjacent to the Grant Gear property will be excavated and
placed in the area to be capped, or left in place and capped, as described in Section VII.B.4.
Soils from prior excavation activities already stockpiled on the Site will be placed in the area
to be capped or covered, depending on contaminant concentrations, as described in Section
Vn.B.4. Soils located on commercial properties adjacent to the Grant Gear property which
are currently covered with pavement or other permanent ground cover will be considered
subsurface soils; i.e. since contaminant concentrations in these soils are below the
commercial/industrial property subsurface soil cleanup level (70 ppm PCBs), no excavation is
required in these areas.
Reducing Ihe concentrations of residual contaminants to these 40 ppm and 70 ppm levels will
result in an incremental carcinogenic lifetime risk level of 1.3 x lfrs for surficial soils and
1.2 x 10~5 for subsurface soils. These risk levels are based upon future commercial/ industrial
land use exposure assumptions associated with an on-Site worker (e.g., landscaper) for the
surficial soils and a construction worker for the subsurface soils. In addition, EPA believes
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that the placement of the cover described in Section VII.B.4. over areas excavated to these
cleanup levels will further reduce potential risks associated with direct contact with, and
incidental ingestion of, contaminated soils. Risks associated with direct contact with, and
incidental ingestion of, soils exceeding these 40ppm and 70 ppm levels will be eliminated by
construction of the cap.
Soil in Wooded Areas North of Grant Gear Property
Surficial soils exceeding 10 ppm PCBs and subsurface soils exceeding 50 ppm PCBs in the
wooded areas directly adjacent to Meadow Brook will be excavated. These contaminated
soils and sediments will be consolidated onto a portion of the Grant Gear property, and
placed in the area to be capped or covered, as described in Section vn.B.4.
Reducing the concentrations of residual contaminants to these 10 ppm and 50 ppm levels will
result in an incremental carcinogenic lifetime risk level of 5 x 10^ for surfickl soils and 8.3
x 10"6 for subsurface soils. These risk levels are based upon exposure assumptions associated
with an older child ('age 6-16) playing in this area for the surficial soils and a construction
worker for the subsurface soils. In addition, the surficial soil cleanup level in this area will
protect aquatic life in Meadow Brook from potential erosion of contaminants.
Soils and Sediment in Meadow Brook and its Banks
Soils and sediments exceeding 1 ppm PCBs located in Meadow Brook and its banks
(including the Dean Street Culvert, as necessary) will be excavated. To achieve this cleanup
level, the Brook and its banks will be excavated to depths consistent with the Town's
Meadow Brook Flood Control Project ("MBFCP") from the portion of the Brook adjacent to
the Grant Gear property to the entrance to the Dean Street culvert. Although it is not
expected that extensive quantities of contaminated sediment exist in the Dean Street culvert,
additional sampling will be conducted to ensure that no sediments exceeding the 1 ppm
cleanup level remain in this culvert. If sampling results indicate that there are sediments
exceeding 1 ppm PCBs in this culvert, this material will be excavated. All contaminated
soils and sediments from the Brook will be consolidated onto a portion of the Grant Gear
property, and placed in the area to be capped or covered, depending on contaminant
concentration, as described in Section VH.B.4.
As in the 1989 ROD, Meadow Brook will be restored in a manner consistent with the
MBFCP. Therefore, while the target cleanup level for Brook soils and sediments is 1 ppm,
the Brook will be excavated only to the extent necessary to meet the final contours of the
MBFCP. The bottom and slope materials (such as stone or concrete block) to be installed as
pan of the MBFCP will cover any contaminated soils and sediments which may be at depths
greater than the MBFCP contours. Depending on final sideslope grades, some portions of
the Brook's banks may be restored with vegetation. In order to ensure that any residual
contamination in these vegetated areas is also adequately covered in place, excavation will
continue in these areas to a depth of one foot deeper than the final restoration grade.
Restoration will then include replacement of these soils with one foot of clean material,
providing a barrier over soils which may still exceed the Brook cleanup level. All materials
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used in restoration of the Brook will be sufficient to provide the necessary protectiveness for
this portion of the remedy.
EPA believes that it is cost-effective, more permanent and effective in the Ions-term, and
more easily implementable to excavate all soils and sediment necessary to meei the restored
MBFCP contour rather than excavate a limited amount of material, conduct extensive
sampling to determine areas requiring additional excavation, and repeat this process several
times. Achievement of the 1 ppm cleanup level throughout the Brook could prove difficult,
could require multiple excavations in portions of the Brook, and could extend far deeper than
the contour required by the MBFCP. By linking the remedial action and the final MBFCP
contours, EPA is ensuring that all contamination above 1 ppm is either removed or covered
by the restored Brook bottom and slopes and that this is a permanent remedy which will not
have to be re-excavated or otherwise disturbed by the Town or others for implementation of
the MBFCP. Restoration in accordance with the MBFCP also enhances the overall
protectiveness of the proposed alternative by virtually eliminating risk of flood waters
displacing on-Site contaminants.
The remediation of Meadow Brook will reduce risk to mammals, rodents, and aquatic
organisms that inhabit the Meadow Brook area from exposure to contaminants through the
skin, by ingestion, or through the food chain. The target level of 1 ppm PCBs is based upon
toxicological literature which documents the sublethal toxic effects of PCB tissue levels of 1
ppm in aquatic organisms. The degree of protection afforded by this level will be met either
directly through excavation activities, or through the added protectiveness provided by the
cover materials installed consistent with the MBFCP. In addition, remediation of the Brook
consistent with the MBFCP will result in a significant reduction of risk to children exposed
to PCB contaminated sediments in Meadow Brook, resulting in an incremental carcinogenic
lifetime risk level of 5 x 10~7. Remediation of Meadow Brook will also reduce the levels of
carcinogenic Polyaromatic Hydrocarbons ("cPAHs") in the Brook and minimise the risk to
children and environmental receptors exposed to any cPAH-contaminated sediments through
direct contact and ingestion.
Residential Area North of Meadow Brook and Adjacent Wooded Area
The 1989 ROD set a residential PCB cleanup standard of 1 ppm. Adherence to this standard
would require some excavation of surface soils in residential properties directly adjacent to
Meadow Brook. At the request of local residents, EPA agreed to reexamine the need for
cleanup in the residential area north of Meadow Brook. Based upon further sampling and
evaluation of existing data, EPA has concluded that the low levels of contamination found in
this residential area (consisting of eight residential properties) which was originally slated to
be excavated does not require remedial action. 56% of the samples collected contain below
1 ppm PCBs and 99% of the samples collected in this area contain below 10 ppm PCBs.
The highest level of PCBs detected in surficial samples in this residential area was 16 ppm,
representing an incremental carcinogenic lifetime risk level of 1 x 10"*, which is within
EPA's acceptable risk range. The risks associated with these levels of contamination indicate
neither an unacceptable human health nor ecological risk. Therefore, no remedial action is
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planned in this area.
4. Cover/Cap parts of the Site
A multi-layered barrier (cap) will be constructed over the portions of the Grant Gear
property which are contaminated above the 40 ppm and/or 70 ppm PCS cleanup levels
and/or where other soils and sediments exceeding 40 ppm PCBs were consolidated. Since
there will be no RCRA wastes disposed of under the cap or cover, the cap and cover need
not comply with RCRA Subtitle C hazardous waste landfill requirements. However, since
they will contain soil contaminated with greater than 50 ppm PCBs, the cap and cover will
comply with TSCA chemical waste landfill requirements, as discussed in Section XI.2
Moreover, this cap will eliminate exposure pathways by preventing people from coming into
contact with the contaminated soil either by direct exposure (touching) or by incidental
ingestion (accidentally eating) and will limit the amount of rain infiltrating the contaminated
soil on the property. The cap will also cover the slab and foundation of the building to be
demolished according to Section VII.B.l., above. The cap(s) over the contaminated soils
will be a minimum of one foot in thickness overall, will include an asphalt binding course
and an asphalt wearing surface totaling no less than six inches, and wQl include a geotextile
fabric which will also serve as a visible barrier between the contamination below and the cap
itself. The cap design over the building slab may be somewhat different from that covering
the contaminated soils if no contaminated soils are backfilled over the existing slab. If no
contaminated soils are backfilled over the existing slab, the cap over the contaminated Grant
Gear Building slab and foundation will include an asphalt binding course and an asphalt
wearing surface totaling no less than four inches. Otherwise, the cap over the building slab
will conform to the requirements for the cap over the contaminated soils. The cap will be
designed to minimize required maintenance, and will be of sufficient thickness and durability
to ensure its long-term effectiveness, and will include appropriate storm water management
system(s).
As stated in Section VII.B.3., in order to further minimize the overall risk from residual
levels of contamination in these areas, cover(s) consisting of approximately one foot of.clean
fill material will be placed on areas which have been excavated as part of the remedy but
which will not be capped. The cover(s) will consist of approximately one foot of clean fill
material and will be properly graded and will include a surface layer of crushed stone or
other suitable material as part of the 1 foot depth. The cover(s) will also include a geotextile
fabric which will serve as a visible barrier between the contamination below and the
cover(s). This cover material will minimize direct contact with these materials and also will
limit the risk from direct contact with cPAHs which may be present in some of the materials
2In part, Section XI. describes the manner in which the TSCA chemical waste landfill
requirements apply to the Site, including how certain TSCA requirements may be waived so
long as the remedy poses no unreasonable risk to health or the environment.
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excavated from the Brook All contaminated soils and sediments removed from areas outside
of the Grant Gear property and brought for disposal on the Grant Gear property will be
placed in an area to be either capped or covered.
The design and construction of the cap(s) and cover(s) will consider the effects of the
freeze/thaw cycle on long-term performance; consider the effects of settling, subsidence, and
erosion on performance; ensure the durability and long-term reliability of the design and its
components (e.g., the durability and reliability of any synthetic materials and of any joints in
such materials); and, provide adequate plans and procedures to assure quality control during
installation. In addition, cap design and construction activities will be conducted: (i) in
accordance with Applicable or Relevant and Appropriate Requirements ("ARARs"); (ii) to
minimize maintenance requirements; (iii) to promote drainage; (iv) to minimize erosion,
abrasion, the generation of dust or other airborne particulates, or other nuisance conditions,
and (v) with a top slope appropriate to accommodate future use. Existing monitoring wells
or extraction wells which are not to be abandoned will be extended to meet the new grade of
the cap(s) and/or cover(s).
EPA anticipates that the Site may be redeveloped and seeks to facilitate appropriate
redevelopment through this remedy. Therefore, changes may be made to the cap and/or
cover to support the future use of the Site, provided that the remedy remains protective.
Also, the cap design may be modified to provide for "clean corridors" of non-contaminated
soil, in order to facilitate future placement of extraction wells and associated piping, as well
as utility and infrastructure hookups, provided that the protectiveness of the remedy is not
diminished.
If redevelopment occurs at the same time as remedy implementation, new, privately owned
buildings may be constructed in conjunction with, or potentially in lieu of, construction of
portions of the cap and/or cover. New structures which utilize concrete slab construction
may substitute for the cap or cover in certain portions of the Site, so long as they are equally
or more protective than the cap or cover.
If redevelopment occurs after the remedy is implemented, it may entail breaching and/or
reconfiguring of the cap and cover, as well as removal of some or all of the concrete slab of
the Grant Gear building left in place by this remedy. All such future activities will maintain
the overall protectiveness of the remedy, and will be conducted in accordance with all
pertinent laws and regulations.
The potential remedy modifications to facilitate redevelopment that are described in die
paragraphs above are not all-inclusive. Other modifications may be considered as necessary"
for a particular redevelopment project. Any redevelopment will be implemented in a manner
that does not compromise the overall protection of human health and the environment
afforded by the remedy.
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5. Maintain the Integrity of the Cap and Cover and Overall Protectiveness of the
Remedy
Regular inspections will be conducted and all necessary remedy maintenance will be
performed to ensure that the integrity of the remedy is not compromised os er time
Formal activity and use restrictions will be established for the Sue. The goals of these
restrictions will be to restrict activities and uses which are inconsistent with the exposure
assumptions the new proposed alternative is based upon and to restrict any activities or uses
that may compromise the integrity of the remedy while providing for future redevelopment of
the Site property to the maximum extent practicable. Formulation of proper restrictions will
consider whether the existing restrictions implemented in connection with the Grant Gear
consent decree meet these goals, and will also consider requirements pursuant to Chapter 21E
of the Massachusetts General Laws and the Massachusetts Contingency Plan activity and use
limitation provisions. If appropriate, the existing restrictions may be revised.
In addition, periodic groundwater monitoring, surface water monitoring, and inspection of
the restored Brook may be necessary to ensure that the remedy remains protective. As
required by CERCLA Section 121(c), no less than every five years. Site conditions will be
reviewed to assess wherner the cleanup action remains protective.
During these periodic reviews, EPA will also evaluate the effectiveness and the necessity of
continuing the extraction and treatment of the groundwater. Based on information generated
during these reviews, this groundwater extraction and treatment system will either be
continued or shut down.
Vm. COMPARATIVE ANALYSIS OF ALTERNATIVES
A. Evaluation Criteria
Section 121(b)(i) of CERCLA presents several factors that, at a minimum, EPA is required
to consider in its assessment of alternatives. Building upon these specific statutory mandates,
the National Contingency Plan articulates nine evaluation criteria to be used in assessing the
individual remedial alternatives. These criteria and their definitions are as follows:
Threshold Criteria
The two threshold criteria described below must be met in order for the alternatives to be
eligible for selection in accordance with the NCP.
1. Overall protection of human health and the environment addresses whether or not
a remedy provides adequate protection and describes how risks posed through each
pathway are eliminated, reduced or controlled through treatment, engineering controls,
or institutional controls.
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2. Compliance with applicable or relevant and appropriate requirements (ARARs)
addresses whether or not a remedy will meet all of the ARARs of other Federal and
State environmental laws and/or provide grounds for invoking a waiver.
Primary Balancing Criteria
The following five criteria are utilized to compare and evaluate the elements of one
alternative to another that meet the threshold criteria.
3. Long-term effectiveness and permanence addresses the criteria that are utilized to
assess alternatives for the long-term effectiveness and permanence they afford, along
with the degree of certainty that they will prove successful.
4. Reduction of toxicity, mobility, or volume through treatment addresses the degree
to which alternatives employ recycling or treatment that reduces toxicity, mobility, or
volume, including how treatment is used to address the principal threats posed by the
Site.
5. Short-term effectiveness addresses the period of time needed to achieve protection
and any adverse impacts on human health and the environment that may be posed
during the construction and implementation period, until cleanup goals are achieved.
6. Implementability addresses the technical and administrative feasibility of a remedy,
including the availability of materials and services needed to implement a particular
option.
7. Cost includes estimated capital and Operation and Maintenance ("O&M") costs, as
well as present-value costs.
Modifying Criteria
The modifying criteria are used on the final evaluation of remedial alternatives generally
after EPA has received public comment on the Proposed Plan.
8. State Acceptance addresses the State's position and key concerns related to die
preferred alternative and other alternatives, and the State's comments on ARARs or
the proposed use of waivers.
9. Community Acceptance addresses the public's general response to the alternatives
described in the Proposed Plan.
B. Summary of the Comparative Analysis of Alternatives
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The following is a summary of the comparative analysis of three remedial options for source
control: (1) the proposed alternative, consolidation and capping, described in Section VTI.B.
of this document: (2) the selected remedy in the 1989 ROD, solvent extraction: and, (3) the
contingent remedy in the 1989 ROD, on-Site incineration, according to the nine criteria.
Two remedial options for the Grant Gear building are also analyzed: the proposed
alternative's demolition of the Grant Gear building and the 1989 ROD'S decontamination of
the building In accordance with EPA guidance, this ROD Amendment does not reconsider
alternatives that were not selected in the 1989 ROD.
Since the groundwater component of the remedy is essentially unchanged from the 1989
ROD, those aspects of the remedy are not analyzed in this section.
1. Overall Protection of Human Health and the Environment
Source Control
The proposed capping alternative will provide overall protection of human health and the
environment by preventing direct contact, ingestion, and inhalation of Site contaminants. In
addition, both the solvent extraction and incineration remedies outlined in the 1989 ROD, if
properly and successfully implemented, would provide overall protection of human health
and the environment.
Grant Gear Building
The amended selected remedy will provide overall protection of human health and the
environment since demolition of the building will prevent direct contact, ingestion and
inhalation of contaminants on surfaces of the building. Due to limitations in its effectiveness,
the decontamination alternative selected in the 1989 ROD would need to incorporate
encapsulation of contaminants, resulting in residual risk remaining within the building.
2. Compliance with Federal and State Applicable or Relevant and Appropriate Requirements
fARARs)
Source Control
If properly implemented and able to meet performance objectives, the proposed capping and
consolidation alternative, solvent extraction, and incineration would all attain ARARs.
Grant Gear Building
The proposed building demolition alternative will attain ARARs. However, it is not certain
that the decontamination alternative selected in the 1989 ROD would attain ARARs.. Based
on information gathered from investigations conducted after the 1989 ROD and on experience
gained while decontaminating 57 pieces of equipment/machinery inside the Grant Gear
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building, EPA believes that the decontamination alternative may not attain PCB cleanup
criteria outlined in the TSCA SpiLl Cleanup Policy (40 C.F.R. Part 761 Subpart G).
3. Long-term Effectiveness and Permanence
Source Control
If properly implemented, the proposed capping alternative, solvent extraction, and
incineration would all provide long-term effectiveness and permanence. Incineration, by
destroying hazardous contaminants, and solvent extraction, by extracting contaminants for
off-Site disposal, would minimize residual risks at the Site. The capping alternative
minimizes residual risks by creating a barrier that eliminates exposure to Site contaminants
through pathways such as touching or eating. While capping does not destroy contaminants
or remove them from the Site, it achieves acceptable risk reduction by eliminating the
exposure pathways, i.e., dermal contact with or ingestion of contaminated soils.
The 1989 ROD expressed concern mat a capping alternative (Alternative SC-2 in the 1989
ROD) may not be sufficiently permanent and protective in the long-term. Since that time
EPA has gained considerable experience in cap design, construction, and long-term
maintenance, greatly increasing EPA's degree of certainty that the capping alternative will be
successful at the Site. Although not as permanent and effective in the long-term as a
complete removal of contamination or the reduction of all contaminant levels to below risk-
based standards, if properly implemented and maintained, the capping alternative will be an
effective remedy and is appropriate based upon Site-specific factors such as the nature of
contaminants and the expected future land use at the,Site. Furthermore, institutional controls
have proven effective on the Site to date, and will be modified as necessary to ensure that the
remedy remains protective during any change in land use.
Grant Gear Building
The proposed building demolition alternative will eliminate any residual risks from building
contaminants, since the building itself will be eliminated. All contaminated building
materials will either be disposed of off-Site in accordance with pertinent laws and regulations
or disposed of under the cap, thereby eliminating exposure pathways to these contaminants.
In contrast, the building decontamination alternative from the 1989 ROD would not as
effectively reduce residual risks. Even if the building were decontaminated, the ultimate
reuse of the property would most likely require building demolition. Pre-design studies have
shown that not all building surfaces can be cleaned to acceptable contaminant levels during
decontamination. Rather, surfaces such as the steel beams and concrete floor may need to be
encapsulated. This could result in ultimate re-exposure to these contaminants during a future
building demolition.
The 1989 ROD had contemplated that the building's drainage system would be flushed and
cleaned to meet the PCB discharge criteria set forth in the 1989 ROD. The 1989 ROD
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further stipulated that, if flushing and cleaning were ineffective in achieving discharge
criteria, the drainage system would be encapsulated and a new drainage system constructed,
Pre-design studies have shown that flushing and cleaning would likely be ineffective, thus
requiring encapsulation and replacement of the drainage system. The demolition option
therefore achieves the same result, encapsulation of the drainage system, but avoids the task
of replacing the system for a building that likely will never be used again.
4. Reduction of Toxicirv. Mobility and Volume Through Treatment
Source Control
The solvent extraction and incineration processes would both reduce toxicity, mobility, or
volume of contaminants through treatment. Although the proposed alternative does not
involve treatment, the mobility of contaminants will be reduced by placing them under a cap
which will limit water infiltration through the waste. Excavation of the "hot spot" of
contaminated soil will further reduce groundwater contamination. Furthermore, virtually all
contaminated material from Meadow Brook and its banks will be removed which will
eliminate the threat of migration off-Site during flood events.
Grant Gear Building
The proposed building demolition alternative will employ treatment to reduce contamination
on any materials that are deemed salvageable. However, the remaining materials will be
consolidated under the cap. The building decontamination alternative from the 1989 ROD
would have provided for treatment of a greater quantity of building material; however, it has
subsequently been determined that a significant portion of building material could not be
effectively decontaminated.
Neither alternative employs treatment with respect to the building drain system.
5. Short-term Effectiveness
Source Control
The proposed capping alternative will entail excavation of approximately 25 percent of the
total volume of soil that would be excavated under the incineration and solvent extraction
alternatives. Also, the solvent extraction and incineration alternatives would excavate the
highest levels of contaminated soils on the Site. Therefore, the solvent extraction and
incineration alternatives would present a greater potential risk to the community from fugitive
airborne emissions and volitization of contaminants. Site workers would also be at a greater
risk from this highly contaminated material. The solvent extraction process also would
require on-Site temporary storage and use of flammable chemicals, presenting further risks.
While appropriate measures would be taken to mitigate all risks associated with any remedial
action, the above mentioned risks would exist for approximately three years with the
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incineration and solvent extraction alternatives. By contrast, the proposed alternative's
estimated duration is one year (or two construction seasons), and the nature of the work is
simple earth-moving and paving, which presents fewer risks to the community or Site
workers during implementation
While not risks to the community per se, the solvent extraction and incineration alternatives
have the potential for creating nuisances as a result of operating 24 hours a day. Also, the
solvent extraction process (and possibly the incineration process) would likely require a stone
crushing process, which would likely generate significant additional noise.
Grant Gear Building
The demolition of the Grant Gear building may cause some short-term undesirable noise
impact to the surrounding community. However, due to the short duration of demolition
activities (four months), it is expected that these impacts will be minimal. Appropriate steps
will be taken to minimize any risks associated with the disassembling of contaminated
building pans.
The building remedy outlined in the 1989 ROD would also present short-term risks due to
the use of solvents in the decontamination process. Also, it will take significantly longer to
complete (one year) than the demolition alternative.
6. Implementabilitv
Source Control
The proposed capping alternative is fully implementable at the Site. Standard earth moving
techniques and equipment will be used, and die cap design is generally straightforward and
easily constructable.
While at the time of the 1989 ROD EPA believed that solvent extraction was implementable
at the Site, recently acquired information indicates that this may not be so. Space limitations
at the Site would make it difficult to properly locate and construct the necessary facilities.
Although the solvent extraction technology has been proven on a pilot scale and solvent
extraction vendors appear able to successfully "scale-up" their processes to a commercial
scale required for a large site cleanup, it does not appear that the Norwood Site is an
appropriate site for solvent extraction due to space constraints at the Site, the amount of time
necessary to fabricate and deliver the appropriate treatment equipment to the Site, and the
high cost of the proposal received.
The 1989 contingent remedy, incineration, is a proven treatment technology. However, at
the required scale for the Site, incineration would require preparation, treatment, and
stockpile facilities similar to solvent extraction, and, therefore, space limitations could
constrain implementation of that remedy at the Norwood Site.
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Grant Gear Building
Demolition of the Grant Gear building is fully and easily implementable. Prior experience
with the decontamination of certain machinery and equipment from inside the building raises
concerns about the ability to properly decontaminate all building surfaces. Information
gathered during EPA's pre-design studies demonstrates that, due to more widespread
contamination than originally anticipated and the limitations of decontamination, several
surfaces could not be adequately decontaminated and could only be encapsulated.
7. Cost
Source JTontrol
The proposed capping alternative is the least expensive of the alternatives being compared,
with an estimated total cost of $7.4 million.3 The solvent extraction and incineration
alternatives are significantly more expensive, with estimated total costs for EPA
implementation of $54.8 million'and 540.1 million, respectively.
Grant Gear Building
Both the proposed demolition alternative and the building decontamination alternative from
the 1989 ROD can be implemented for a comparable amount of money. The estimated total
costs for EPA to implement demolition versus decontamination (including, in each case, costs
already incurred for decontaminating 57 pieces of machinery and equipment) are $4.0 million
and $3.8 million, respectively. However, the decontamination cost estimate does not include
potential costs for future maintenance of encapsulated surfaces or disposal costs for building
materials when the structure is ultimately demolished.
8. State Acceptance
The Commonwealth of Massachusetts concurs with the proposed capping and building
demolition alternatives as the amended selected remedy in this ROD Amendment. A copy of
the Commonwealth's Declaration of Concurrence is attached as Appendix C.
9. Community Acceptance
EPA held an informational meeting and public bearing in Norwood, Massachusetts on March
6, 1996. At that meeting, four commenters made statements for the record. In addition,
five separate written comment letters were submitted to EPA. The official transcript of the
3This is EPA's best estimate of the cost EPA would incur to implement all activities
described hi Section VQ.B.2. through VI.B.5., above.
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March 6, 1996 hearing is included as Attachment D. See the Responsiveness Summary
"* (Attachment B) for a summary of the comments and EPA's responses.
*
A few area residents, including some Town of Norwood officials, were concerned that the
proposed alternative may not be sufficiently protective, and was being proposed due to a lack
of EPA funding. They also womed that monitoring of the remedy may not occur as
described in [he Proposed Amended Cleanup Plan. The Town of Norwood Board of Health
inquired about who will be responsible for maintenance of the cap. It also asked about the
thickness of the cap. Another resident asked how much taxpayer money has been spent on
the Site to date, and how much will be recouped. Finally, another resident expressed support
for the plan, and hopes that the plan can be approved and implemented quickly.
EPA also held an informal public comment period in August, 1995, in conjunction with
release of its "Invitation for Public Comment on Approach to Soil Cleanup" at the Site. That
document outlined a conceptual consolidation and capping remedy as a modified approach for
the Site. For the most part, public reaction to the modified approach was favorable at that
time, with no outright opposition to the plan. The community expressed frustration about the
length of time spent on the Site, and was also concerned about the government's ability to
ensure long-term maintenance of a cap.
IX. THE AMENDED SELECTED REMEDY
The amended remedy selected in this document is the proposed alternative described in
section VII.B. This amended selected remedy is the result of a re-evaluation of material
contained in the Administrative Record for the 1989 ROD, as well as analysis of new Site
conditions and new information developed since 1989 which has been added to the
Administrative Record. EPA believes that the amended selected remedy represents the best
balance among the evaluation criteria when compared to the alternatives selected in the 1989
ROD.
The amended selected remedy is a fundamental change in the approach for remediating
contaminated soil at the Site (Source Control). The amended selected remedy also presents
changes regarding the remediation of the Grant Gear building, as well as other differences.
EPA is not changing the cleanup approach in the 1989 ROD for addressing contaminated
groundwater at the Site (Management of Migration) except to clarify that periodic reviews of
the groundwater. will be. conducted to determine the need for continued groundwater
extraction and treatment over time.
All other aspects of the 1989 ROD not addressed in this document remain unchanged.
X. DOCUMENTATION OF CHANGES FROM THE PROPOSED AMENDED CLEANUP
PLAN
EPA published a Proposed Amended Cleanup Plan in February, 1996. The remedy selected
'•v
24
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in this ROD Amendment differs from the proposed plan in some respects. First, the
Proposed Amended Cleanup Plan did not identify cleanup levels for the "hot spot". This
ROD Amendment specifies a cleanup level of 97 ppm 1,2,4-trichiorobenzene for these soils.
This cleanup level is based upon a cleanup level for this constituent originally set forth in the
1989 ROD.
The Proposed Amended Cleanup Plan also stated that the sediments and/or sludges excavated
from drainage system manholes would be disposed of "properly". This ROD Amendment
clarifies that this material, as well as RCRA regulated materials'from the Grant Gear
building, will be disposed of off-Site in accordance with all applicable laws and regulations.
Also, this ROD Amendment contains greater discussion regarding the possible redevelopment
of the Site, and specific measures that will be taken to attain certain ARARs.
These changes, while appropriate clarifications, do not represent any significant differences
from the Proposed Amended Cleanup Plan.
XI. STATUTORY DETERMINATIONS
The amended selected remedy for implementation at the Norwood PCB Superfund Site is
consistent with CERCLA and, to the extent practicable, the NCP. The amended selected
remedy is protective of human health and the environment, attains ARARs and is cost
effective. Additionally, the amended selected remedy utilizes alternate treatment technologies
or resource recovery technologies to the maximum extent practicable. However, the amended
selected remedy does not satisfy the statutory preference for treatment which permanently
and significantly reduces the mobility, toxicity or volume of hazardous substances as a
principal element.
The Amended Selected Remedy is Protective of Human Health and the Environment
The amended selected remedy at this Site will reduce the risks posed to human health and the
environment by eliminating, reducing or conn-oiling exposures to human and environmental
receptors through excavation, engineering controls, and institutional controls; more
specifically, the source control component of the amended selected remedy will address all
soils and sediments contaminated at concentrations exceeding protective human health and
environmental levels by either excavation, capping, or covering, and will address
contaminated building surfaces by demolishing the structure and consolidating the material
on-Site or disposing or recycling the material off-Site. At the conclusion of remedial
activities, risks at the Site will be reduced to within EPA's acceptable risk range, as
discussed in Section VH.B. and as indicated in Table 1. The cap will eliminate exposure
pathways by preventing people from coming into contact with contaminated soil either by
direct exposure (touching) or by incidental ingestion (accidentally eating) and will limit the
amount of rain infiltrating the contaminated soil on the property. The cover will be placed
over materials contaminated with less than 40 ppm PCBs at surface, or 70 ppm PCBs at
25
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depth (and thus not posing an unacceptable risk) to further reduce the risk posed by this
material. Remediation of the wooded area will reduce risks to a child or construction worker
to acceptable levels, and the Meadow Brook cleanup will restore that area to levels protective
of children, plants, and animals. A comprehensive maintenance and monitoring program and
controls on future land use will ensure that the remedy remains protective o%er time.
A complete description of the Site risks can be found in the 1989 ROD, the 1989
Endangerment Assessment, other documents in the amended Administrative Record, and in
Table 1.
The Amended Selected Remedy Complies with Applicable or Relevant and Appropriate
Requirements (ARARs)
The amended selected remedy will attain applicable or relevant and appropriate federal and
state requirements that apply to the Site. Environmental laws and regulations which are
ARARs for the source control remedy are listed in Table 2. Since this ROD Amendment
does not alter the management of migration component of the 1989 ROD, ARARs pertaining
to that portion of the remedy are not listed in Table 2. Major ARARs pertinent to this ROD
Amendment are discussed in this section.
PCB disposal requirements promulgated under TSCA
The 1989 ROD deemed PCB disposal requirements promulgated under TSCA as applicable
to the Site because of the presence of soil and sediments contaminated with PCBs in excess
of 50 ppm. Under TSCA regulations, soil contaminated with PCBs may be disposed of by
incineration or in a chemical waste landfill. 40 C.F.R. § 761.60(a)(4). Additionally, PCB
wastes which require incineration may be disposed of by an alternate destruction technology
that achieves an equivalent level of performance to incineration. 40 C.F.R. § 761.60(e).
Like the remedy selected in the 1989 ROD, the amended selected remedy will result in a
chemical waste landfill subject to the TSCA regulations contained at 40 C.F.R. § 761.75.
However, in the 1989 ROD, EPA also determined that waiver of several of the regulatory
requirements pertaining to chemical waste landfills was justified. As explained in the EPA
Guidance on Remedial Actions for Superfund Sites with PCB Contamination (OSWER
Directive No. 9355.4-01, August 1990) (the "PCB Guidance") some requirements specified
under TSCA may not always be appropriate for existing waste disposal sites like those
addressed'by CERCLA. The PCB Guidance states that when this case exists, the waiver of
certain chemical waste landfill requirements may be appropriate. These requirements can be
waived when it can be demonstrated that a waiver will not present an unreasonable risk of .:•
injury to health or the environment. 40 C.F.R. § 76i.75(c)(4). In accordance with the PCB
Guidance, the 1989 ROD waived several chemical waste landfill requirements, including
requirements that (i) chemical waste landfills be constructed only in certain low permeability
clay conditions (40 C.F.R. § 761.75 (b)(l)); (ii) a synthetic membrane liner be used at the
Site (40 C.F.R. § 761.75(b)(2)); and (iii) the bottom of the landfill be 50 feet above the
26
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historic high water table (40 C.F.R. § 761.75(b)(3)). These TSCA statutory waivers are
maintained in this ROD Amendment. Additionally, for the reasons stated below, the
requirements relating to leachate collection (40 C F.R. § 761.75(b)(7)) are also waived in
this ROD Amendment.
TSCA regulations do not contain any requiremenis for closure of chemical waste landfills.
However, as described in this ROD Amendment, contaminated soil will be placed under
either a multi-layered cap or one foot of clean fill, depending on the level of contamination.
These surficial barriers will provide added protectiveness beyond that contemplated by the
TSCA regulations. The cap will eliminate all exposure pathways to the most highly
contaminated soils, thereby eliminating the risks posed by those soils. Soils at 40 ppm PCBs
at the surface, and 70 ppm PCBs at depth, are within EPA's acceptable risk range. (See
Table 1). The one foot cover over these materials will further reduce potential risks
associated with direct contact with, and incidental ingestion of, these materials. Long-term
operation and maintenance of the cap and cover will ensure that there is no future re-
exposure to contaminants. Risks posed by migration of PCBs to the groundwater will be
minimal, due to the chemical nature of PCBs (which tend to bind to the organic matter in
soil) and the excavation of the "hot spot" of soil below the water table contaminated with
semi-volatile organic compounds (which might otherwise act to desorb the PCBs from the
soil into the groundwater). Also, continued operation of the groundwater treatment plant will
ensure the capture of any PCBs or other contaminants that migrate away from the capped
area through the groundwater. Furthermore, available data indicates that the groundwater
plume is not expanding, and drinking water for all area residents is provided by the Norwood
municipal water system, which is unaffected by Site contaminants.
For these reasons, EPA has determined that the amended selected remedy will not present an
unreasonable risk of injury to health or the environment, and that the amended selected
remedy may waive the above-cited TSCA requirements.
The factors discussed above ensure that there will be no unreasonable risk of injury to health
or the environment if certain TSCA requirements are waived. Considering this information,
the Regional Administrator continues to exercise1 the waiver authority contained in the TSCA
regulations at 40 C.F.R. § 761.75(c)(4), and continues to waive the following requirements
of the TSCA chemical waste landfill requirements: (i) that chemical waste landfills be
constructed only in certain low permeability clay conditions (40 C.F.R. § 761.75 (b)(l)); (ii)
that a synthetic membrane liner be used at the Site (40 C.F.R. § 761.75(b)(2)); and (iii) that
the bottom of the landfill be 50 feet above the historic high water table (40 C.F.R. §
761.75(b)(3)). Additionally, the Regional Administrator also exercises the waiver authority
to waive requirements relating to leachate collection (40 C.F.R. § 761.75(b)(7)). The
findings and waivers of the Regional Administrator are contained in Attachment E.
Commonwealth of Massachusetts Hazardous Waste Regulations
Massachusetts hazardous waste regulations, which are similar to regulations under the federal
27
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Resource Conservation and Recovery Act ("RCRA"), are applicable to the Site. Under the
federal regulatory program, PCBs are managed by TSCA, and are not regulated under
RCRA; under die Commonwealth's hazardous waste regulations, PCBs above 50 ppm are a
regulated hazardous waste. Compliance with TSCA, however, satisfies the requirements of
the Commonwealth's hazardous waste regulations with respect to on-site management and on-
sue disposal of PCBs, pursuant to 30 CMR 30.501 (3)(a) and 310 CMR 40.003*1(5).
Accordingly, on-Site management and on-Site disposal of PCBs will be governed by TSCA.
It is anticipated that this approach will avoid potentially duplicative or inconsistent
application of ARARs (as between federal TSCA regulations and the Commonwealth's
hazardous waste regulations).
Other Laws and Regulations
In addition to the environmental provisions listed in Table 2, other laws and regulations will
be complied with during the conduct of the remedy. While not specifically relating to
environmental actions, and therefore not ARARs, compliance with these laws and regulations
is mandatory for any industrial activity. Such requirements may include, but are not limited
to, pertinent regulations pursuant to the Occupational Health and Safety Act and Department
of Transportation regulations.
The Amended Selected Remedy is Cost-Effective
In the Agency's judgment, the amended selected remedy is cost-effective, (i.e., the remedy
affords overall effectiveness proportional to its costs). In selecting this amended remedy,
once EPA identified alternatives that are protective of human health and the environment and
that attain, or, as appropriate, waive ARARs, EPA evaluated the overall effectiveness of
each alternative by assessing the relevant three criteria-long term effectiveness and
permanence; reduction in toxicity, mobility, and volume through treatment; and short term
effectiveness, in combination. In this assessment, EPA determined that the consolidation and
capping portion of the amended selected remedy, solvent extraction, and incineration all
provide overall effectiveness, albeit through different means. However, the costs of these
three options are quite different. The cost estimates for the consolidation and capping
portion of the amended selected remedy, solvent extraction, and incineration, are $7.4
million, $54.8 million, and $40.1 million, respectively. Based upon this disparity, EPA
believes that the consolidation and capping portion of the amended selected remedy is cost
effective while the solvent extraction and incineration alternatives are not. With respect to
the Grant Gear building, the amended selected remedy provides overall effectiveness while
the decontamination alternative does not. The cost estimate for the demolition remedy is
$4.0 million, which EPA believes to be cost-effective for this portion of the amended
selected remedy.
The following estimates of cost and construction duration are inclusive of the work to
complete all aspects of the Source Control and building demolition cleanup at the Norwood
PCS Superfund Site, and are, unless otherwise noted, costs for EPA implementation of
28
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actions to be performed subsequent to this ROD Amendment.
Consolidation, Capping and Covering of Soils and Sediments
(including remediation and restoration of Meadow Brook):
Estimated Time for Design and Construction: 9 - 15 months
Estimated Capital Cost: $ 7,200,000
Estimated Operation and Maintenance Cost: $ 200,000
Estimated Total Cost (Net Present Value): $ 7,400,000
Demolition of Grant Gear Building (including disposal of contents):
Estimated Time for Planning and Demolition: 6 months
Estimated Capital Cost: $ 2,800,000
Estimated Operation and Maintenance Cost: $0 (incorporated into cap maintenance
cost)
Cost of Prior Machinery/Equipment Decontamination Effort: $ 1,200,000
Estimated Total Cost (Net Present Value): $ 4,000,000
The Amended Selected Remedy Utilizes Permanent Solutions and Alternative Treatment or
Resource Recovery Technologies to the Maximum Extent Practicable
Once the Agency identified those alternatives that attain or, as appropriate, waive ARARs
and that are protective of human health and the environment, EPA identified which
alternative utilizes permanent solutions and alternative treatment technologies or resource
recovery technologies to the maximum extent practicable. This determination was made by
deciding which one of the identified alternatives provides the best balance of trade-offs
among alternatives in terms of: 1) long-term effectiveness and permanence; 2) reduction of
toxicity, mobility or volume through treatment; 3) short-term effectiveness; 4)
implementability; and 5) cost. The balancing test emphasized long-term effectiveness and
permanence and the reduction of toxicity, mobility and volume through treatment; and
considered the preference for treatment as a principal element, community and state
acceptance, and the bias against off-Site land disposal of untreated waste. The amended
selected remedy provides the best balance of trade-offs among the alternatives.
Consistent with the NCP, EPA believes that at this Site long-term effectiveness is more
fundamental to the overall protectiveness of the remedy than the degree of treatment
employed. Considering Site circumstances, a reduced level of treatment technologies is- —
preferable, and the amended selected remedy employs such technologies to the maximum
extent practicable while preserving the permanence and protectiveness of the remedy.
The Amended Selected Remedy does not Satisfy the Preference for Treatment which
Permanently and Significantly Reduces the Toxicitv. Mobility or Volume of the Hazardous
Substances as a Principal Element
The principal element of the amended selected remedy is the on-Site capping and containment
29
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of contaminated soils and sediment. Treatment is not employed because it was determined
not to be practicable for this Site, considering the summary of the comparative analysis of
alternatives, as described in Section VIII.B., above. Therefore, the amended selected
remedy does not satisfy the preference for treatment as a principal element. Nonetheless, the
amended selected remedy reduces Site risks to acceptable levels.
XII. EXPLANATION OF SIGNIFICANT DIFFERENCES FROM 1989 RECORD OF
DECISION
In addition to the items discussed in Section VII.B. above, the amended selected remedy
selected in this document contains other differences from the 1989 ROD. These differences
do not represent fundamental changes from the remedy selected in the 1989 ROD, and are
not subject to the requirements for a ROD Amendment. However, the modifications in tins
Section are significant differences from the 1989 ROD. These differences were explained in
EPA's February, 1996 Proposed Amended Cleanup Plan, which was published in accordance
with CERCLA Section 117(d). The following discussion of the these significant differences
in this document is presented in compliance with CERCLA Section 117(c).
A. Decontamination of Only Selected Equipment and Machinery Surfaces;
Disposal/Recycling of Remaining Building Contents
Soon after Grant Gear announced its shutdown, EPA tasked a contractor, through the US
Army Corps of Engineers, to decontaminate certain machines and equipment inside the
building which were to be sold by Grant Gear. This effort included the solvent washing of
accessible exterior surfaces of these machines and sampling of the cleaned surfaces to
demonstrate compliance with the PCB Spill Cleanup Policy (40 CFR Part 761 Subpart G)
cleanup level of 10 micrograms per 100 square centimeters.
Based upon the high cost and labor-intensive nature of this decontamination effort, this work
was suspended after the cleaning of 57 major pieces of equipment and several accessories.
Approximately $1.2 million was spent on this effort. It has been determined that it is not
cost-effective to decontaminate the remaining machines and, since Grant Gear Works has
shut down, disposal or recycling (via a smelter) of any items remaining hi the building will
be equally protective of human health and the environment, at a substantially reduced cost.
Therefore, prior to initiation of the building demolition, any remaining contaminated
machinery/equipment insidejhe building will be recycled at an offrSite smelting facility or
disposed of either on- or off-Sfite. . ' >" "" -
B. Increase of Estimated Cost of Groundwater Remediation
In August 1994, the US Army Corps of Engineers awarded a delivery order under its TERC
contract for approximately 59 million for construction and initial operation (2 years) of the
facilities for extraction and treatment of contaminated groundwater. Cost growth and
changes executed during construction increased this figure to approximately $11 million. The
30
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current overall estimate for die groundwater cleanup; including the approximate present value
of an additional 10 to 20 years of operation of this treatment plant, is approximately S19.2
million.
Xm. DOCUMENTATION OF NON-SIGNIFICANT CHANGES TO 1989 RECORD OF
DECISION
The following remedy modification represents neither a fundamental nor significant change
from the remedy selected in the 1989 ROD. This minor modification is included in this
ROD Amendment so that all changes to the remedy are described in one document.
As set forth in the 1989 ROD, contaminated groundwater underlying the Site will be
collected and treated. To accomplish this task, a number of groundwater extraction wells
have been and will be installed which will extract contaminated groundwater and treat it in
the on-Site groundwater treatment facility which utilizes processes to precipitate and filter
groundwater, as well as air stripping and carbon adsorption operations. Treated water will
be discharged to Meadow Brook. This treatment plant started operating in December 1995.
At the conclusion of all other Site cleanup activities (soil/sediment remedy and building
demolition), the need for continued groundwater extraction and treatment will be evaluated.
If it is determined at that time that groundwater extraction and treatment should continue,
this decision will be revisited once again at each periodic review of the remedy (no less rhan
every five years). If it is determined that groundwater extraction and treatment need not
continue, the groundwater treatment plant will be decommissioned.
This portion of the remedy remains essentially unchanged from the 1989 ROD. As part of
the design and construction of the groundwater treatment plant, which was recently
completed, some changes were made. A series of extraction wells were designed and
constructed in lieu of a trench system as originally contemplated by the 1989 ROD. On-Site
re-charge of treated water was deemed infeasible and, instead, treated water will be
discharged to Meadow Brook. Further information regarding the use of extraction wells and
the change from re-charge to discharge to surface water are summarized in a report prepared
in January 1993 by Metcalf & Eddy, Inc. and other documents in the Administrative Record.
XIV. STATE ROLE
The Commonwealth of Massachusetts has reviewed the various alternatives and has indicated
its support for the amended selected remedy. The Commonwealth believes that the amended
selected remedy is in compliance with applicable or relevant and appropriate Commonwealth
Environmental laws and regulations. The Commonwealth of Massachusetts concurs with the
amended selected remedy for the Norwood PCS Superfund Site. A copy of the declaration
of concurrence from the Commonwealth is included as Attachment C.
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jiVWv <-^ A
NORWOOD PRESS
'• -VfX'
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Figure 2
VICINITY MAP
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HCAOOW tHOOn
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UttMO
4Ff HDIIUttl tOClHOXt 01 I'll •>
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IOWN OF
NORWOOD
SUCISfAllON
AND SIOOP1CO
SOU.S CXCAVAHO IN
ON WANT CTAft
CICAVATt SOLS tlCXCOlNC 40 PPM PCBl
AMD/on 70 PPU PC.BI
AHUS MR* QEAM FU.
[KCAVAtI SOILS AND onOO. flit UAIERULS
etCffOlHG tO PPU PCSi (SUR(IQU) ANO/O)
SO Mtl PCBl (SUBSURrACE).CQNSOLlOAT[ OHIO
CAAHI CTAA
Figure 5:
CONCEPTUAL OUTLINE OF SOIL CLEANUP LEVELS AND EXTENT OF CAP
CKCAVAIf
I PPU PCBl, CONSOliOAU OHIO CHANT CUR
PftQftRlY
CAP ARCAS fKCfCDINC CUANUP UvtLS ATKR
I 1IH M«l« *
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TABLE 1 - SOIL/SEDIMENT CLEANUP LEVELS
Location
(excludes areas to be capped)
Surface Soils (top 1 foot) on
Commercial/Industrial
Properties*
Subsurface Soils (1 foot - 6 foot)
on Commercial/Industrial
Properties*
Surface Soils (top 1 foot) in
wooded area on both sides of
Meadow Brook
Subsurface Soils (1 foot - 6 foot)
in wooded area on both sides of
Brook
Meadow Brook bottom, slopes,
banks, and culverts between
Kerry Place and Neponset River
Organic "hot spot" at or below
water table hi western portion of
Grant Gear property
Cleanup
Standard
40 parts
per million
PCBs
70 parts
per million
PCBs
10 parts
per million
PCBs
50 parts
per million
PCBs
1 part per
million
PCBs
97 parts
per million
1,2.4-
trichloro- .
benzene
Incremental
Carcinogenic Risk
After Cleanup
Standards are
Achieved
1.3 x lO'5
(1.3 in 100,000)
1.2x ID*3
(1.2 in 100,000)
5x10"*
(5 in 1,000,000)
and ecological
risk
8.3 x 10^
(8.3 in
1,000,000)
5x 10-7
(5 in 10,000,000).
and ecological
risk
Based upon risks
hi groundwater
and leaching
model (see 1989
ROD)
Exposed Individual
Used in Risk
Calculation
worker exposure
(e.g., landscaper)
construction worker
exposure
older child (age 6 -
16) exposure; and
aquatic life hi brook
and river
construction worker
exposure
older child exposure;
and aquatic life hi
Brook and River
protection of
groundwater
* Remaining areas which exceed these levels will be capped. Cover(s) will be placed over
remaining soils in other uncapped areas on Grant Gear property.
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TABLE I
ARARs AND CRITERIA, ADVISOKIItS, AND (illllMNri:
NORWOOD I'Cfl SUPEBFUNDSlni. NORWOOD. MASSACIltlShTIS
AMENDED RLCORD OF DECISION
T.II.IL- 2
AUTHORITY
REQUIREMENT
STATUS
REQUIREMENT SYNOI'SIS
ACTION TAKEN 'IO AITAIN
AltAllS
CHEMICAL SPECIFIC ARARs:
federal Criteria,
Advisories, and Guidance
Technical Basis Tor Deriving Sediment
Quality Criteria for Non-tonic Organic
Contaminant* for the Protection of Benttuc
Organisms Using Equilibrium Partitioning
(EPA-822-R-93-01I)
Federal Ambient Water Quality Criteria
EPA Carcinogenic Assessment Group
Potency Factors
EPA Risk Reference Doses (KID*)
To be .
Considered
Relevant i are dnus levcli dcvclnped by lite LPA lor
The criteria csubliihi.il were uitJ lo
evaluate risks ta aijiulic organisms
cuptisedlo ctiiildiiiiii.ilcd wjki uniMined
willnn llie sediiDcni and lo set
cleanup levch
AWQC were used to Lturjcicti/c
In ireiti wdler ji|iultL lite in MLlnLiw
Biook.
ns were
EPA Carcinogenic I'uteiiLy
used 10 conipnic llie indivulttul
incteinental L.niLer risk rcsiilimg Irnni
exposure lo sue
EPA RfDs wi.ie used in Lli.if,n.iLiiK
risks due lo e*|)osnie In Liiiii.iiniiijiiis on
sue
LOCATION SPECIFIC ARARs
Kitcrul
lixeculive Order (LO
Apphcdlile
Under (his icgiiljlmu, I'eileial »ULIH_ICS die
required (o iniiiimuc the dcMiULliDi), IOM. or
degrdddliitn at wetlands, 4iid preserve JiiJ
enhance ndlunl and bent filial values ot
wclUiuls.
ui and iiMiiialum nl Nkinluw
Hrouk will inUiidc all |>i.i«.(K.iliL- means
of iiiimniUJiiy liaini lo wxil.uul-,,
Wetlands protccliun considLidimns will
be incorpordlul nun Ilir pl.iiiinny .nul
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Tahlt 2 -
HoodpUms Uxeculivc Order (I:O I I'JSH)
I'cdural ;i£cin.ics arc required in ririliiLC the risk
i)f iliHHi litsi. lo iimiiuiiie (lie mijuK ol tliHids,
anil lo icMinc anil preserve Ihc n.Hural dud
l ValllCS ()1 Hllllllpl.llllS
flic remedial JLllilll will he I|LM(;IILI| In
kec(>dll JUIKNL1 11(1) ill tllC Itlliulpldlll III
the greatest cxlem |DJL|ILJ|I|(. Also,
substantial mm Sue iLl.nut ikVLlnpnhMit
lids occur re J iti 11 ic Mtaddw linuik
fluodplain 'I lie rLini:dy includes tirook
rcsiorautin in ,ui.indjiiLe witli llic
Meadow lluntk Moiid ('niiinil |'CO|LL|.
greatly increasing the heiu.tiLi.il value of
(he lloodplain
State Regulatory
Matsachuutu Wetlands Protection Act
(M.G.L. c.l Jl Section 40; 310 CMR 10 00)
Applicable
These reguljtums iiullinc (lie requirements
lo work wiilun HMJ foci uf a wetljnd
Wetlands diblurhcd liy extavadon will be
restored consistent willi the approved
Meadow Brotik l-loml Cmittnl I'IDJCL!
ACTION SPECIFIC ARARs
Federal Regulatory
Rcijuiremenls
Resource Conservation and Recovery Act
(RCRA), Subtitle C (40 CFR 260-262)
TSCA Storage Requirements (40 CFR
761.65}
TSCA Chemical Waste Landfill
Requirements (40 CFR 761 75)
Applicable
Applicable
Applicable
RCKA regulate* the generation, transport.
Storage, Itedimeiil, and dispoul ot lijjiardoiii
wane. CLRCI.A iftecilkdHy requires (in
Section 12l(il)(3)) that haurdoui subsuince$
from response ai-luins he diijmied uf at taulitics
in compliance with Subtitle C ol RCKA
Outlines requirements fur temporary TSCA
regulated waste storage including specific design
requirement!*
Esuhlnhes standards tor PCIi land tills including
provisions for the Regional Administrator lo
waive requirements.
Wastes generated as pan
action will he clunulmzed and handled
in accordance with applnahle KCUA
regulattiinv tu lite exlenl dial iin.h
regulations aie mil dtiplicative t>l ihe
authorized Suie program llus intludes
materials from "hut spin"
and diatnage manhole
Proper dtiiyn cunsidLrations will lie
tniplenienied to niiure dial all temporary
storage of TSCA-rcgnlaled wjsie
SJilillos the rc[|
-------
1 - Page 3
TSCA rrn spin Cleanup Policy (4i) rru
76liubpatiO)
Guide on Remedial Actions at Superlund
Sites with PCB Contamination (OSWER
Directive 9355.4-01. August 1990)
National Emissions Standards for
Air Pottutants (NESHAPS) Requirements,
Clean Air Act. Section 112
(40 CFR Part 61)
Clean Water Act (CWA) - Section 404
Dredge and Fill Requirements
(33 USC 1344; 40 CFR Pan 230)
Fish and Wildlife Coordination Act
16 USC 661
'lolic
Considered
To be
Considered
Relevant diiJ
Appropriate
Applicable
Applicable
I'.M.ililhhc's I'liulcliiiLMiii llii. ik'LOiil.iiiiiiiiilnmol
I'CU spills
Sets In Ml) guidelines liir developing rciiiuli.il
auions tor PCBs
IK'J lia/aiilmi!. air pollutants Iioni
specified source activiltes
llnilur ilns iui|inicnii:nl. 1111 activity tlul
advctsely altc-cts t wcdjnd i,lidll he pemnucd if a
practicable alternative thai lias less effei.1 is
available
This act requires that before undertaking any
Federal acunn that Lju^ei ilie modincaliun of any
body of waicr or affect* fish ami wildlife, the
following agencies must be coiivulled. the
appropriate Stale agency exerusint; jurisdiction
over wildlife resources and the US Fish ami
Wildlife Service
In llii: comuMil <
ensure compluncc witli p
NESI1AP regulatuiiis
Iniji.iLii ID WLll.nuli will In.
use ol sill curtjiiu ur ^iliniuiii.
lusms There is no (UdCtiCdhlc
attcnmtive lu excavation of Me
Brook.. The brook will he
(he Town'!,
control project
l hy
lluoughoul their uu'iilvi;t»i.n< uuli this
Sue, Hf'A and MA Ul;l' have miiMiltcil
with llieir wildlife ICMHHLC cuutucipdrt!i
jnd informed them ol Sue JLIIV un_>,
Stalk Kugulalury
Kequirements
Ma»sachusetli Gruundwaler Protection
Regulations
310 CMR 6.04(2) and 6.04(6)
HdevaiU mid
Appropriate
'lltcse rcculaiuinsdeuil the rcquiic-incnii lor
ground water miiniKiring program to be
implemented at the site.
A (JlolirnlwalLr iiimiiioHiig jiiti^i
be tnstiiuttd to aiitii iin|uci!> ol
spot" tixcavatiun and to monitor
oi tin: cj|>|)iit£
-------
Tal>tt 2 - Page 4
Massachusetts Waterways Regulations
(M O I, c.21 Scclioni 26-53. 314 CMR
V INI)
Applicable
Regulates llie water quality certification of
ilicd(;in(( •iiul disniis.il uf iliolged iiMlcn.it
Dredging ol seilnm-nis will IK
lliiplciiiuilctl .HHII,tin); M ii|'iilalHniv
11IL Illlllllg limM.IIII IIUilllliM H\f III
downstream wdieis duini£
implunenlaluin to mntinl mtgr.iiuin of
KIKI.lllllll.IU.ll Mlllllll. lltS
Massachusetts Ambient Air Quality
Standards
310 CMR 6.00
Applicable
'Ihese regulations specify emissions standards lor
All acnviliti will lie LunJui.ii.-d in a
nutl/lcr (0 Illinmn/e Jhc t'cnculniii nf
dun or utlier lujj
Sue Asbignmem Regulation for Solid Wa&ie
Facilities
3IOCMR 16,05(3)(I)
S|)ccilii;jiioiib for oiviin: ilcinuluton fjnlmcs. anJ
disposal rcquireiiiLhl tor dcinuhlion duhns
Demiililiuii ailiviik.i juJ jny inlnciinti
Crushing upcultuiib will lie mndui_lcd
using hcst nuiiiigcmeni JUJLIILCS auJ
will l>e carried DIM m a iti.i»ui.r whit.li
will nut poic a IIIII^JIILI: or (.Jiise
uncoiiliollcdvliivlurge of |iollui.iiitb lo
air, water, or oilier iwlurjl FLUHITLC
Solid Waste Management Facility
Regulations
310 CMR 19.060 C2),(4)&(5) .
Applicable
Requirements (or the Ueltriiiinaljon of l>encni.ial
Ube of sulid wane niaterial
Brick and hlotk dthris (mill t
of the buililtng may be hcnctiUiitly used
on the Site Substantive re'|iiin.incnl ol
these regulations will govern (he
determination as tu whether ihcu
materials may lie
Solid Waste Management Facility
Regulations
310CMKI90610)(a)
AppJicublc
Regulated asheiius niaicnal tcuiii (lie
huilding demolition will be handled in
accordance will) a|>|ihi.jblc n-'yiilainiiu
Solid Waste Management Facility
Regulations
310CMR I9061(6)|iliu,ibli:
Massachusetu Air Pollution Conirul
ReguUnons
310 CMR 7.09
Applicable
lioiu specific to LOIIIIO! of odor and
fugitive dust emissions.
Odors and fugitive dust u ill be
controlled by water sprays, suppressants,
or l*y other en^iicuriiii; 4.
-------
Table 2 • Page 5
Massachusetts Air Pollution Control
Regulations
310CMR7.I5(I){«>
Applicable
Applicable standards for asbestos demolition
Asbestos demolition will lie cundui.it.tl in
accordance wiili d|>pliLat>k
Massachusetts Air Pollution Control
Regulations
3IOCMR7.15UXO
Applicable
Procedures lor asbestos emission cunlrul Cites
procedures to prevent visible or paniculate
emissions to ilie ambient air space.
Asbestos demolition will tic uituluueJ in
accordance with apptiLahlu regulations
Air Pollution Control Regulations 310 CMK
Appllcatile
Cues rct|uituiiienls tor (lie use til air (.leaning
equipment in demolition activities involving
asbestos.
Aslieslus demolition will lit. lomtuued n>
aLumlance wiUi d|i|>ln.,ilili:
Air Pollution Control Regulations 310 CMK
7,15(1 )k
Kcgnlalions giiveriutig Hie gfiicrainin, lieJlnicnt.
, anil disposal nl lia^aldo
regulations will In; lollowLiI in
cmiduLling the (.kjini|i. as J|i|iln.,ihlc
Poiliuns of ilicse ri:£nlalii)ns W|IIL|| ,«c
specific to on-Site reiiuduiuni nl HClls
arc nnt applicaiilc SIIILC I'CU lenimluiio
will be impk'inniiiL-il tluniigli T.SI'A
Hazardous Waste Regulations 310 CMR
30.125(b)
Applicable
Requirements for Toxic CliardUensiit
Procedure (TCLP)
Wastes generated lor oil sue disposal us
pan of remedial action will l>e
characterized and handled m acci)rJaiu.e
with applicable RCKA rtjjuldiiuns Tins
includes materials hum "Imi ipui"
excavation anil dr.inuye inanholc sltidge
Hazardous Waste Regulations 310 CMR
30.302
Applicable
Requirements fur any generator of a waste to
determine if llic waste is hazardous.
Wastes generaicd lor ull-Mic disposal as
pan of feinedi.il ailion will (>e
with applicable KCKA rcgulanons This
includes mateuaK (ruin "hot spot"
excavation ami i!r,im.it;e nunliok simile.
Fire Prevention Regulations: Tanks and
Containers
527 CMR 9.07
Applicable
Requirements lur (he removal or abandonment
ami, if appropriate, die fillmt; in place, ot
underground tanks.
llnilergruund unks will lie j|i|iiupnately
removed or aliuixloikd att-ordin^ n» llic
regulations
(iuidc lu Regulations fur Using ur
Processing Asphalt, Brick and Concrete
Rubble
To be
Considered
Identifies the provisions of the solul waste
rcgulaliuns llial jicitain to reLyilinH/rciismg AUC
nibble.
Tins yiiuijiii.u wilt I'c Lousulti.it lor
Jcinoliuoii at
-------
ATTACHMENT A
RECORD OF DECISION AMENDMENT
NORWOOD PCB SUPERFUND SITE
ADMINISTRATIVE RECORD INDEX
-------
Norwood PCB
NPL Site
Administrative Record
ROD signed: September 29,1989
ROD Amendment Signed: May 17,1996
Index
Prepared By
EPA New England
Office of Site Remediation and Restoration
U.S. Environmental Protection Agency
With Assistance From
ads
2070 Chain Bridge Road
Vienna, VA
-------
Introduction
This document is the Index to the ROD Amendment for the Norwood PCB Administrative
Record signed: May 17, 1996 Although not expressly listed in the Index, all documents
contained in the September 29, 1989 ROD Administrative Record are incorporated by reference
herein, and are expressly made a pan of this ROD Administrative Record. Section I cues site-
specific documents, and Section II cites guidance documents used by EPA staff in selecting a
response action at the site. Site-specific documents in the Administrative Record are in
order by the Document Number included at the end of each citation.
In Section I, documents identified in the Title as [Available in Records Center] are
oversized reports and are separately available for review in the EPA-New England's Canal Street
Records Center, by appointment only.
The Administrative Record is available for public review at EPA New-England's Records
Center at 90 Canal St., Boston, Massachusetts, and at the Morrill Memorial Library, Walpole
Street, Norwood, Massachusetts, 02062. Questions concerning the Administrative Record should
be addressed to the EPA-New England site manager.
An Administrative Record is required by the Comprehensive Environmental Response,
Compensation, and Liability Act (CERCLA), as amended by the Superfund Amendments and
Reauthorization Act (SARA).
-------
Norwood PCS
NPL Site Administrative Record
Table of Contents
Volume I
004453-004464
Volume n
004465-004498
Volume m
004505-004522
-------
Section I
Site-Specific Documents
-------
ADMINISTRATIVE RECORD INDEX
NORWOOD PCBS
All Operable Units
05/21/96
Page i
03.10 REMEDIAL INVESTIGATION - ENDANGERMENT ASSESSMENTS
Title:Re-evaluation of Soil Cleanup Levels for the
Norwood PCS Superfund Site.
Addressee: FILE
Authors: ROBERT G. CIANCIARULO - EPA NEW ENGLAND/ OSRR
Date: January 31, 1996
Format: LETTER, MEMORANDUM, NOTE No. Pgs: 2
AR No. 03.10.1 Document No. 004453
Title:Review of Remedial Alternative Evaluation.
Addressee: ROBERT G. CIANCIARULO - EPA NEW ENGLAND/ OSRR
Authors: SUSAN C. SVIRSKY - EPA NEW ENGLAND/ OSRR
Date: December 11, 1995
Format: LETTER, MEMORANDUM, NOTE No. Pgs: 6
AR NO. 03.10.2 Document No. 004454
Title:Draft Cleanup Levels for Surface and Subsurface
Soil at Grant Gear Property.
Addressee: ROBERT G. CIANCIARULO - EPA NEW ENGLAND/ OSRR
Authors: ANN-MARIE BURKE - EPA NEW ENGLAND/ OSRR
Date: December 18, 1995
Format: LETTER, MEMORANDUM, NOTE No. Pgs: 3
AR No. 03.10.3 Document No. 004460
Title:Evaluation of Cleanup Levels.
Addressee: ROBERT G. CIANCIARULO - EPA NEW ENGLAND/ OSRR
Authors: ANN-MARIE BURKE - EPA NEW ENGLAND/ OSRR
Date: December 15, 1995
Format: LETTER, MEMORANDUM, NOTE No. Pgs: 7
AR No. 03.10.4 Document NO. 004461
Title:comments Pertaining to the PAH Contamination at
the Norwood Superfund site.
Addressee: ANN-MARIE BURKE - EPA NEW ENGLAND/ OSRR
Authors: KENNETH H. BROWN - EPA NATIONAL EXPOSURE RESEARCH
LAB
Date: February 1, 1996
Format: LETTER, MEMORANDUM, NOTE No. Pgs: 35
AR No. 03.10.5 Document No. 004517
-------
ADMINISTRATIVE RECORD INDEX
NORWOOD PCBS
All Operable Units
05/21/96
Page 2
04.09 FEASIBILITY STUDY - PROPOSED PLANS FOR SELECTED REMEDIAL ACTION
Title:Proposed Amended Cleanup Plan.
Authors: EPA NEW ENGLAND/ OSRR
Date: February 1996
Format: FACT SHEET, PRESS RELEASE No. Pgs: 15
AR No. 04.09.1 Document No. 004484
05.01 RECORD OF DECISION - CORRESPONDENCE
Title:
Addressee :
Authors :
Date:
Format:
AR No.
Department of Environmental Protection,
Concurrence with the ROD Amendment.
LINDA M. MURPHY - EPA NEW ENGLAND/ OSRR
JAMES C. COLMAN - MASSACHUSETTS DEP
May 16, 1996
LETTER, MEMORANDUM, NOTE No. Pgs: 3
05.01.1 Document No.
004520
uS.02 RECORD OF DECISION - ARARS
Title: Applicable, Relevent and Appropriate
Requirements.
Addressee: ROBERT 6. CIANCIARULO - EPA NEW ENGLAND/ OSRR
Authors: JAY NAPARSTEK - MASSACHUSETTS DEP
Date: April 10, 1996
Format: LETTER, MEMORANDUM, NOTE No. Pgs: 3
AR No. 05.02.1 Document No. -004505
05.03 RECORD 07 DECISION - RESPONSIVENESS SUMMARIES
Title:
Addressee:
Authors:
Format:
AR No.
Comments on Soil/Sediment Cleanup Plan.
ROBERT G. CIANCIARULO - EPA NEW ENGLAND/ OSRR
RESIDENTS
LETTER, MEMORANDUM, NOTE No. Pgs: 2
05.03.1 Document No. 004486
-------
ADMINISTRATIVE RECORD INDEX
NORWOOD PCBS
All Operable Units
05/21/96
Page 3
Title: Comments on Soil/Sediment Cleanup Plan.
Addressee: ROBERT G. CIANCIARULO - EPA NEW ENGLAND/ OSRR
Authors: RESIDENTS
Format: LETTER, MEMORANDUM, NOTE No. Pgs: 1
AR No. 05.03.2 Document Ho. 004487
Title:comments on Soil/Sediment Cleanup Plan.~~
Addressee: ROBERT G. CIANCIARULO - EPA NEW ENGLAND/ OSRR
Authors: RESIDENTS
Format: LETTER, MEMORANDUM, NOTE No. Pgs: 1
AR No. 05.03.3 Document No. 004488
Title:Comments on Soil/Sediment Cleanup Plan.
Addressee: ROBERT G. CIANCIARULO - EPA NEW ENGLAND/ OSRR
Authors: RESIDENTS
Format: LETTER, MEMORANDUM, NOTE No, Pgs: 1
AR No. 05.03.4 Document No. 004489
Title:Comments on Soil/Sediment Cleanup Plan.
Addressee: ROBERT G. CIANCIARULO - EPA NEW ENGLAND/ OSRR
Authors: RESIDENTS
Format: LETTER, MEMORANDUM, NOTE No. Pgs: 1
AR No. 05.03.5 Document NO. 004490
Title:Comments on Soil/Sediment Cleanup Plan.
Addressee: ROBERT G. CIANCIARULO - EPA NEW ENGLAND/ OSRR
Authors: RESIDENTS
Format: LETTER, MEMORANDUM, NOTE No. Pgs: I
AR No. OS.03.6 Document No. 004491
Title:Comments on Soil/Sediment Cleanup Flan.
Addressee: ROBERT G. CIANCIARULO - EPA NEW ENGLAND/ OSRR
Authors: RESIDENTS
Date: August 18, 1995
Format: LETTER, MEMORANDUM, NOTE No. Pgs: 3
AR No. 05.03.7 Document No. 004492
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ADMINISTRATIVE RECORD INDEX
NORWOOD PCBS
All Operable Units
05/21/96
Page 4
Title:
Addressee:
Authors:
Date:
Format:
AR Ho.
Transnittal Letter Concerning Board of
Selectmans1 Vote to Refer Residents Letters to
the EPA.
ROBERT G. CIANCIARULO - EPA MEW ENGLAND/ OSRR
JULIA A. LIDDY - TOWN OF KORWOOD
August 17, 1995
LETTER, MEMORANDUM, NOTE No. Pgs: 2
05.03.8 Document NO. 004493
Title: Preliminary Comments on Proposed Revision to Site
Remedy.
Addressee: ROBERT G. CIANCIARULO - EPA NEW ENGLAND/ OSRR
Authors: LAWRENCE FELDMAN - GZA GEOENVIROHMENTAL, INC.
Date: August 18, 1995
Format: LETTER, MEMORANDUM, NOTE No. Pgs: 10
AR No. 05.03.9 Document No. 004494
Title:
Addressee:
Authors:
Date:
Format:
AR No.
Comments on Soil/Sediment Cleanup Plan.
ROBERT G. CIANCIARULO - EPA NEW ENGLAND/ OSRR
RESIDENTS
August 13, 1995
LETTER, MEMORANDUM, NOTE No. Pgs: 1
05.03.10 Document No. 004495
Title:
Addressee:
Authors:
Date:
Format:
AR No.
Comments on Soil/Sediment Cleanup Plan.
ROBERT G. CIANCIARULO - EPA NEW ENGLAND/ OSRR
RESIDENTS
August 8, 1995
LETTER, MEMORANDUM,, NOTE No. Pgs: 1
05.03.11 Document No. 004496
Title:
Addressee:
Authors:
Date:
Format:
AR No.
Comments on Soil/Sediment Cleanup Plan.
ROBERT G. CIANCIARULO - EPA NEW ENGLAND/ OSRR
RESIDENTS
August 8, 1995
LETTER, MEMORANDUM, NOTE No. Pgs: 1
05.03.12 Document No. 004497
-------
ADMINISTRATIVE RECORD INDEX
NORWOOD PCBS
All Operable Units
05/21/96
Page 5
Title: comments on Soil/Sediment Cleanup Plan.
Addressee: ROBERT G. CIANCIARULO - EPA NEW ENGLAND/ OSRR
Authors: RESIDENTS
Date: August 4, 1995
Format: LETTER, MEMORANDUM, NOTE Ho. Pgs: 1
AR No. 05.03.13 Document No. 004493
Title!Comments on Proposed Amended Cleanup Plan.
Addressee: ROBERT G. CIANCIARULO - EPA NEW ENGLAND/ OSRR
Authors: DANIEL P.B SMITH
Date: February 24, 1996
Format: LETTER, MEMORANDUM, NOTE No. Pgs: 1
AR NO. 05.03.14 Document No. 004507
Title:comments on Proposed Amended Cleanup Plan.
Addressee: ROBERT G. CIANCIARULO - EPA NEW ENGLAND/ OSRR
Authors: CAMERON F. KERRY - MINT2, LEVIN, COHEN, & FERRIS
P.C.
Date: March 29, 1996
Format: LETTER, MEMORANDUM, NOTE No. Pgs: 1
AR NO. 05.03.15 Document No. 004506
Title:Comments on Proposed Amended Cleanup Plan.
Addressee: ROBERT G. CIANCIARULO - EPA NEW ENGLAND/ OSRR
Authors: CRAIC H. CAMPBELL - MINTZ, LEVIN, COHEN, & FERRIS
P.C.
Date: March 22, 1996 . '
Format: LETTER, MEMORANDUM, NOTE No. Pgs: 10
AR No. 05.03.16 Document No. 004508
Title:comments on Proposed Amended Cleanup Plan.
Addressee: ROBERT G. CIANCIARULO - EPA NEW ENGLAND/ OSRR
Authors: GZA GEOENVIRONMENTAL, INC.
Date: March 22, 1996
Format: LETTER, MEMORANDUM, NOTE No. Pgs: 44
AR No. 05.03.17 Document No. 004509
-------
Title:
Addressee:
Authors:
Date:
Format:
AR NO.
ADMINISTRATIVE RECORD INDEX
NORWOOD PCBS
All operable Units
05/21/96
Page 6
Comments on Proposed Amended Cleanup Plan.
ROBERT G. CIANCIARULO - EPA NEW ENGLAND/ OSRR
URSULA C. FECHEK
March 21, 1996
LETTER, MEMORANDUM, NOTE No. Pgs: 1
05.03.18 Document No. 004510
Title:
Addressee:
Authors:
Date:
Format:
AR No.
Comments on Proposed Amended Cleanup Plan.
ROBERT G. CIANCIARULO - EPA NEW ENGLAND/ OSRR
PHYLLIS M. BOUCHER - NORWOOD BOARD OF HEALTH
March 13, 1996
LETTER, MEMORANDUM, NOTE No. Pgs: 1
05.03.19 Document No. 004511
Title:
Addressee:
Authors:
Date:
Format:
AR No.
Response to Board of Selectmens' Comments on
Proposed Amended Cleanup Plan.
GARY M. LEE - TOWN OF NORWOOD
ROBERT G. CIANCIARULO - EPA NEW ENGLAND/ OSRR
March 14, 1996
LETTER, MEMORANDUM, NOTE No. Pgs: 2
05.03.20 Document No. 004518
Title:
Addressee:
Authors:
Date:
Format:
AR No.
"Conceptual Utility Plan, Grant Gear Property -
Providence Highway," Supplemental Comments of
Grant Gear.
ROBERT G. CIANCIARULO - EPA NEW ENGLAND/ OSRR
NORWOOD ENGINEERING
May 1, 1996
MAP, BLUEPRINT, PHOTO, NE No. Pgs: 2
05.03.21 Document No. 004522
05.04 RECORD O7 DECISION - RECORD OP DECISION
Title: Declaration of the Record of Decision Amendment,
Norwood PCB Superfund Site.
Authors: LINDA M. MURPHY - EPA NEW ENGLAND/ OSRR
Date: May 17, 1996
Format: TITLED DOCUMENT {REPORT, No. Pgs: 99
AR No. 05.04.1 Document No. 004519
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ADMINISTRATIVE RECORD INDEX
NORWOOD PCBS
All operable Units
05/21/96
Page 7
Title: Regional Admninistrator's Findings and Waivers
Under Regulations of the Toxic Substances Control
Act.
Authors: PATRICIA MEANEY - EPA REGION I
Date: May 17, 1996
Format: LETTER, MEMORANDUM, NOTE No. Pgs: 1
AR No. 05.04.2 Document No. 004521
05.06 RECORD O7 DECISION - COST REPORTS AND INVOICES
Title: Rough Cost Estimate for Building and Soil
Incineration Remedy.
Addressee: FILE
Authors: ROBERT G. CIANCIARULO - EPA NEW ENGLAND/ OSRR
Date: January 31, 1996
Format: LETTER, MEMORANDUM, NOTE No. Pgs: 6
AR No. 05.06.1 Document No. 004455
.02 REMEDIAL DESIGN - SAMPLING AND ANALYSIS DATA
Title: Sampling and Analysis Report for the Demolition
of the Grant Gear Building.
Addressee: U.S. ARMY CORP. OF ENGINEERS
Authors: FOSTER WHEELER ENVIRONMENTAL CORPORATION
Date: September 1995
Format: REPORT No. Pgs: 404
AR No. 06.02.1 Document No. 004456
Title: Sampling Report and Technical Memorandum for
Disposal Stategy of GGB Materials.
Addressee: BRIAN BAKER - U.S. ARMY CORP. OF ENGINEERS
Authors: EVERETT WASHER - FOSTER WHEELER ENVIRONMENTAL
- - ' CORPORATION
Date: September 20, 1995
Format: LETTER, MEMORANDUM, NOTE No. Pgs: 2
AR No. 06.02.2 Document No. 004457
-------
Title:
Addressee:
Date:
Format:
AR No.
ADMINISTRATIVE RECORD INDEX
NORWOOD PCBS
All operable Units
05/21/96
Page s
Technical Memorandum - Grant Gear Building
Disposal Strategy.
EPA NEW ENGLAND/ OSRR
September 19, 1995
MISCELLANEOUS NO. Pgs: 31
06.02.3 Document No. 004458
06.04 REMEDIAL DESIGN - REMEDIAL DESIGN DOCUMENTS
Title:
Addressee:
Authors:
Date:
Format:
AR No.
Title:
Addressee:
Authors:
Date:
Format:
AR No.
Pre-Design Study Final Reports. Vol I - Field
Investigations. [Available at Records Center]
EPA REGION I
METCALF & EDDY
January 1993
REPORT No. Pgs: 297
06.04.1 Document No. 004104
Title: Pre-Design Study Final Reports. Vol. 2 -
Hydrogeologic investigations. [Available at
Records Center]
Addressee:
Authors :
Date:
Format :
AR No.
Title:
Addressee:
Authors :
Date:
Format:
AR No.
EPA REGION I
METCALF & EDDY
January 1993
REPORT
06.04.2
No. Pgs: 483
Document No. 004106
Pre-Design Study Final Reports. Vol. 3 -
Bench-Scale Treatability Study Report. [Available
at Records Center]
EPA REGION I
METCALF & EDDY
January 1993
REPORT No. Pgs: 49
06.04.3 Document No. 004107
Pre-Design Study Final Reports. Vol. 4 - Solvent
Extraction Treatability Study Report. [Available
at Records Center]
EPA REGION I
METCALF & EDDY
January 1993
REPORT No. Pgs: 272
06.04.4 Document No. 004108
-------
Title:
Addressee:
Authors:
Date:
Format:
AR No-.
ADMINISTRATIVE RECORD INDEX
NORWOOD PCBS
All Operable Units
05/21/96
Page 9
Title: Specificarions for Groundwater Remediation -
Volume I, Final Submittal. [Available at Records
Center]
Addressee: EPA REGION I
Authors: METCALF & EDDY
Date: May 1994
Format: REPORT No. Pgs: 529
AR No. 06.04.5 Document No. 004499
Specifications for Groundwater Remediation -
Volume II, Final Submittal,
Records Center]
EPA REGION I
METCALF & EDDY
May 1994
REPORT
06.04.6
[Available at
No. Pgs: 482
Document No.
004500
*Attached to Document No. 004499 In 06.04
Title:
Addressee:
Authors:
Date:
Format:
AR No.
Specifications for Soil Remediation - Volume I,
Final 100% Submittal,
Center]
EPA REGION I
METCALF & EDDY
August 1994
REPORT
06.04.7
[Available at Records
No. Pgs: 388
Document No. 004502
Title: Specifications for Soil Remediation - Volume II,
Final 100% Submittal. [Available at Records
Center]
Addressee: EPA REGION I
Authors: METCALF & EDDY
Date: August 1994
Format: REPORT No. Pgs: 402
AR No. 06.04.8 Document No. 004503
'Attached to Document No. 004502 In 06.04
-------
ADMINISTRATIVE RECORD INDEX
NORWOOD PCBS
All Operable Units
05/21/96
Page 10
06.06 REMEDIAL DESIGN - WORK PLANS AND PROGRESS REPORTS
Title:
Addressee:
Authors:
Date:
Format:
AR No.
Groundwater Remediation - Site Plans. [Available
at Records Center]
EPA REGION I
U.S. ARMY CORP. OF ENGINEERS
May 1994
MAP, BLUEPRINT, PHOTO, NE No. Pgs: 24
06.06.1 Document No. 004501
*Attached to Document No. 004499 In 06.04
Title:
Addressee:
Authors:
Date:
Format:
AR No.
Soil -Remediation - Site Plans. [Available at
Records Center]
EPA REGION I
U.S. ARMY CORP. OF ENGINEERS
August 1994
MAP, BLUEPRINT, PHOTO, NE No. Pgs: 23
06.06.2 Document No. 004504
* Attached to Document No. 004502 In 06.04
07.02 REMEDIAL ACTION - SAMPLING AND ANALYSIS DATA
Title: Area 5 soil Sampling Program - Sampling and
Analysis Report [Draft].
Addressee: U.S. ARMY CORP. OF ENGINEERS
Authors: FOSTER WHEELER ENVIRONMENTAL CORPORATION
Date: January 29, 1996
Format: REPORT No. Pgs: 51
AR No. 07.02.1 Document No. 004459
07.04 REMEDIAL ACTION - ARARS
Title! Letter Regarding the Discharge Point for Effluent
from the Groundwater Treatment Plant into the
Heponset River and Meadow Brook.
Addressee: CHRISTOPHER TUREX - U.S. ARMY CORP. OF ENGINEERS
Authors: ROBERT G. CIANCIARULO - EPA NEW ENGLAND/ OSRR
Date: July 21, 1995
Format: LETTER, MEMORANDUM, NOTE No. Pgs: 3
AR No. 07.04.1 Document No. 004462
-------
ADMINISTRATIVE RECORD INDEX
NORWOOD PCBS
All Operable Units
05/21/96
Page ii
07.06 REMEDIAL ACTION - WORK PLANS AND PROGRESS REPORTS
Title:summary Final Report - Equipment Decontamination.
Addressee: U.S. ARMY CORP. OF ENGINEERS
Authors: FOSTER WHEELER ENVIRONMENTAL CORPORATION
Format: REPORT No. Pgs: 2
AR No. 07.06.1 Document No. 004463
Title:Preliminary Work Approach to Support an Order of
Magnitude Estimate for Off-property Soil
Evaluation and Capping of Contaminated Area on
Grant Gear.
Addressee: U.S. ARMY CORP. OF ENGINEERS
Authors: ENSERCH ENVIRONMENTAL
Format: MISCELLANEOUS No. Pgs: 6
AR No. 07.06.2 Document No. 004464
Title:Draft Work Plan for Soil Remediation.~
Addressee: U.S. ARMY CORP. OF ENGINEERS
Authors: FOSTER WHEELER ENVIRONMENTAL CORPORATION
Date: May 1995
Format: REPORT No. Pgs: 115
AR No. 07.06.3 Document No. 004465
Title:Final Work Plan and cost Estimate - Groundwater
Remediation.
Addressee: MICHELLE KEWER - U.S. ARMY CORP. OF ENGINEERS
Authors: J. GARRY CUSACK - EBASCO
Date: August 3, 1994
Format: LETTER, MEMORANDUM, NOTE No. Pgs: 3
AR NO. 07.06.4 Document No. 004466
07.07 REMEDIAL ACTION - COST REPORTS AND INVOICES
Title: Order of Magnitude Estimate for Meadow Brook
Remediation.
Addressee: BRIAN BAKER - U.S. ARMY CORP. OF ENGINEERS
Authors: EVERETT WASHER - ENSERCH ENVIRONMENTAL
Date: December 19, 1995
Format: LETTER, MEMORANDUM, NOTE No. Pgs: 2
AR No. 07.07.1 Document No. 004467
-------
Title:
Addressee:
Authors:
Date:
Format:
A3 No.
ADMINISTRATIVE RECORD INDEX
NORWOOD PCBS
All Operable Units
05/21/96
Page 12
Public Voucher for Purchases and Services Other
Than Personal.
RAYMOND J. MARCHINI - EBASCQ
GORDON G. SPANEK, CHARLES W. CQE - EPA/
CINCINNATI FINANCIAL MANAGEMENT CTR
December 11, 1995
COST DOCUMENTATION No. Pgs: 2
07.07.2 Document No. 004468
Title:
Addressee:
Authors:
Date:
Format:
AR No.
Public Voucher for Purchases and services Other
Than Personal.
RAYMOND J. MARCHINI - EBASCO
GORDON G. SPANEK, CHARLES W. COE - EPA/
CINCINNATI FINANCIAL MANAGEMENT CTR
December 11, 1995
COST DOCUMENTATION No. Pgs: 2
07.07.3 Document No. 004469
Title: Cost Summary for All Tasks.
Format: COST DOCUMENTATION
AR No. 07.07.4
No. Pgs: 1
Document No.
004470
10.06 ENFORCEMENT - PRP-SPECIPIC NEGOTIATIONS
Title:
Addressee:
Authors:
Date:
Format:
AR No.
Letter Outlining Cornell-Dubilier's Concern for
Cashout Settlement and Increased Cost for Remedy.
- EPA NEW ENGLAND/ OSRR
JAMES R. KAPLAN - CORNELL/DUBILIER ELECTRONICS
April 24, 1995
LETTER, MEMORANDUM, NOTE No. Pgs: 1
10.06.1 Document No. 004471
10.11 ENFORCEMENT - PRP ENFORCEMENT WORK PLANS
Title:
Addressee:
Authors:
Date:
Format:
AR No.
Remedial Alternative Evaluation.
VARIOUS
GZA GEOENVIRONMENTAL, INC.
November 27, 1995
REPORT No. Pgs: 276
10.11.1 Document No. 004472
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ADMINISTRATIVE RECORD INDEX
NORWOOD PCBS
All Operable Units
05/21/96
Page 13
11.09 POTENTIALLY RESPONSIBLE PARTY - PRP - PRP-SPECIFIC CORRESPONDENCE
title:Letter Stating Cornell-Dubilier's Concurrence
with Cooper Industries' Request that EPA
Reconsider Groundwater Remedy.
Addressee: ROBERT G. CIANCIARULO - EPA HEW ENGLAND/ OSRR
Authors: ROBERT S. SANOFF - FOLEY HOAG t ELLIOT
Date: October 30, 1995
Format: LETTER, MEMORANDUM, NOTE No. Pgs: 1
AR No. 11.09.1 Document No. 004473
Title:Letter Stating Federal Pacific Electronics'
Concurrence with Cooper Indutries1 Request that
EPA Reconsider Groundwater Remedy.
Addressee: ROBERT G. CIANCIARULO - EPA NEW ENGLAND/ OSRR
Authors: HOWARD T. WEIR - MORGAN, LEWIS & BOCKIUS
Date: October 17, 1995
Format: LETTER, MEMORANDUM, NOTE No. Pgs: 1
AR No. 11.09.2 Document No. 004474
Title:Letter Concerning EPA's Failure to Consider
Parties' Comments On Proposed Revisions to Site
Remedy.
Addressee: ROBERT G. CIANCIARULO - EPA NEW ENGLAND/ OSRR
Authors: DANIEL RIESEL - SIVE, PAGET & RIESEL, P.C.
Date: October 11, 1995
Format: LETTER, MEMORANDUM, NOTE No. Pgs: 3
AR No. 11.09.3 Document No. 004475
Title:Letter Stating Confirmation of Understanding that
Site Remediation will Include Demolition of Grant
Gear Building.
Addressee: ROBERT G. CIANCIARULO - EPA NEW ENGLAND/ OSRR
Authors: ROBERT J. HURLEY - GRANT GEAR
Date: December 1, 1994
Format: LETTER, MEMORANDUM, NOTE No. Pgs: 1
AR No. 11.09.4 Document No. 004476
-------
Title:
Addressee:
Authors:
Date:
Format:
AR No,
ADMINISTRATIVE RECORD INDEX
NORWOOD PCBS
All Operable Units
05/21/96
Page 14
Letter Confirming Cease of Operation at Grant
Gear Site and Decision to Demolish Building.
ROBERT J. HURLEY - GRANT GEAR
ROBERT G. CIANCIARULO - EPA NEW ENGLAND/ OSRR
November 29, 1994
LETTER, MEMORANDUM, NOTE No. Pgs: 1
11.09.5 Document No. 004477
13.01 COMMUNITY RELATIONS - CORRESPONDENCE
Title:
Addressee:
Authors:
Date:
Format:
AR No.
Letter Regarding Area to be Excavated.
RESIDENTS
ROBERT G. CIANCIARULO - EPA NEW ENGLAND/ OSRR
September 5, 1995
LETTER, MEMORANDUM, NOTE No. Pgs: 4
13.01.1 Document No. 004478
-1.03 COMMUNITY RELATIONS - NEWS CLIPPINGS/PRESS RELEASES
Title:"Neighbors Say Leave Grant Gear Site Alone."
Authors: BILL ARCHAMBEAULT - DAILY TRANSCRIPT
Date: September 1, 1995
Format: NEWSPAPER No. Pgs: 1
AR No. 13.03.1 Document No. 004479
Title:
Addressee:
Authors:
Date:
Format:
AR No.
Title:
Addressee:
Authors:
Date:
Format:
AR No.
EPA Environmental News - EPA Invites Public
Comment on Amended Cleanup Plan for Norwood PCB
Superfund Sites.
FILE
EPA NEW ENGLAND/ OSRR
February 22, 1996
FACT SHEET, PRESS RELEASE No. Pgs: 1
13.03.2 Document Ho. 004513
"The U.S. Environmental Protection Agency Invites
Public Comment on the Proposed Amended Cleanup
Plan for the Norwood PCB Superfund Site".
FILE
EPA NEW ENGLAND/ OSRR
April IS, 1996
NEWSPAPER No. Pgs: 1
13.03.3 Document No. 004515
-------
ADMINISTRATIVE RECORD INDEX 05/21/96
NORWOOD PCBS Page IS
All Operable Units
Title: "The U.S. Environmental Protection Agency Invites
Public Comment on the Proposed Amended Cleanup
Plan for the Norwood PCB Superfund Site."
Addressee: FILE
Authors: EPA NEW ENGLAND/ OSRR
Date: February 21, 1996
Format: NEWSPAPER OR MAGAZINE CLI No. Pgs: 1
AR No. 13.03.4 Document No. 004516
13.04 COMMUNITY RELATIONS - PUBLIC MEETINGS
Title:Public Meeting/Hearing Sign In Sheet.
Addressee: FILE
Authors: EPA NEW ENGLAND/ OSRR
Date: March 6, 1996
Format: MISCELLANEOUS No. Pgs: 2
AR No. 13.04.1 Document NO. 004512
Title:Public Meeting and Hearing - Proposed Amended
Cleanup Plan.
Addressee: FILE
Authors: EPA NEW ENGLAND/ OSRR
Date: March 6, 1996
Format: MISCELLANEOUS No. Pgs: 19
AR No. 13.04.2 Document No. 004514
13.05 COMMUNITY RELATIONS - PACT SHEETS
Title:EPA Invites Public Comment on Approach to Soil
Cleanup.
Addressee: FILE
Authors: EPA NEW ENGLAND/ OSRR
Date: August 1995
Format: FACT SHEET, PRESS RELEASE No. Pgs: 15
AR No. 13.05.1 Document No. 004485
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ADMINISTRATIVE RECORD INDEX
NORWOOD PCES
All Operable Units
05/21/96
Page 16
14.01 CONGRESSIONAL RELATIONS - CORRESPONDENCE
Title: Letter Addressing Concerns of Residents Regarding
Clearing and Excavation of Portions of Wooded
Area.
Addressee: JOHN MOAKLEY - U.S.CONGRESS-HOUSE
Authors: JOHN P. DEVILLARS - EPA REGION I
Date: October 3, 1995
Format: LETTER, MEMORANDUM, NOTE No. Pgs: 2
AR No. 14.01.1 Document No. 004480
Title:
Addressee:
Authors:
Date:
Format:
AR No.
Title:
Addressee:
Authors:
Date:
Format:
AR No.
Letter Regarding Receipt of Residents' Letter.
JOHN MOAKLEY - U.S.CONGRESS-HOUSE
JOHN P. DEVILLARS - EPA REGION I
September 19, 1995
LETTER, MEMORANDUM, NOTE No. Pgs: 1
14.01.2 Document No. 004481
Residents Complaint.
JOHN P. DEVILLARS - EPA REGION I
JOE MOYNIHAN - U.S.CONGRESS-HOUSE
August 25, 1995
LETTER, MEMORANDUM, NOTE No. Pgs: 1
14.01.3 Document No.
004482
17.07 SITE MANAGEMENT RECORDS - REFERENCE DOCUMENTS
Title:New Bedford Harbor - Initial Successful Bid Cost.
Addressee: EPA NEW ENGLAND/ OSRR
Authors: U.S. ARMY CORP. OF ENGINEERS
Format: COST DOCUMENTATION No. Pgs: 1
AR No. 17.07.1 'Document No. 004483
-------
Section H
Guidance Documents
-------
Norwood PCB
1TPL Sit* Adaini«trativ« Record
Guidance Documents
EPA guidance documents may be reviewed at EPA-New England Canal St.
Records Center, Region I, Boston, Massachusetts.
1. U.S. Environmental Protection Agency. Office of Emergency and
Remedial Response. Guidance on Remedial Actions for Superfund
Sites with PCB Contamination (OSWER Directive No. 9355.4-01),
Auguust 1990. [2014]
2. U.S. Envrionmental Protection Agency. Office of Solid Waste
and Emergency Response. A Guide on Remedial Actions at
Superfund Sites With PCS Contamination (OSWER Directive No.
9355.4-01 FS), August 1990. [C254]
-------
Norwood PCB
NPL Site Administrative Record
Index
Compiled: August 11, 1989
ROD Signed: September 29, 1989
Prepared for
Region I
Waste Management Division
U.S. Environmental Protection Agency
With Assistance from
EBASCO SERVICES, INC
ZIl Congms Slrnl, Boston, Massachusetts 02110
-------
Introduction
This document is the Index to the Administrative Record for the Norwood PCS
National Priorities List (NPL) Site. Section I of the Index cites site-specific documents,
and Section II cites guicance documents used by EPA staff in selecting a response
action at the site.
The Administrative Record is available for public review at EPA Region I's office in
Boston, Massachusetts, and at the Mornll Memorial Library, Walpoie Street, Norwood,
Massachusetts, 02062. Questions concerning the Administrative Recora should fie
addressed to the EPA Region I site manager.
The Administrative Record is required by the Comprehensive Environmental Response
Compensation and Liability Act (CERCLA), as amended by the Superfund
Amendments and Reauthorizatton Act (SARA).
-------
SECTION I
SITE-SPECIFIC DOCUMENTS
-------
ADMINISTRATIVE RECORD INDEX
for the
Norwood PCB NPL Site
1 0 PRE-REMEDIAL
1 14 FIT Contrsct
1 "Massachusetts FIT Contract - Work and Cost Plan Proposal -
Grant Gear Company - Problem Evaluation Study - Site
Response Assessment - Site Management Plan," Wehran
Engineering (June 6, 1985).
1.18 FiT Technical Direction Documents (TDDs) and Associated Reccrcs
1. "Geophysical Survey," Westcn Geophysical Corporation for NUS
Corporation (July 1S34). NOTE: Oversize Maps and figures
are avaiiaole for review at EPA, Region I, Boston,
Massachusetts
2. "Field Investigation of the Norwood Site, Norwood,
Massachusetts," NUS Corporation (September 10, 1984).
2.0 REMOVAL RESPONSE
21 Correspondence
1. Letter from Anthony D. Cortese, Massachusetts Department of
Environmental Quality Engineering to Paul Keough, EPA Region
t (June 16, 1983). Concerning immediate removal action at the
Norwood PCB site.
2. Memorandum from David Mclntyre, EPA Region I to Richard T.
Leignton, EPA Region I (August 5, 1983). Concerning
immediate removal action at the Dean Street site.
3. Memorandum from Frank W. Ultey, EPA Region I to Dave
Mclntyre, EPA Region I (September 15, 1983). Concerning
Norwood II Airborne PCB investigation.
4. Letter from Richard Chatpin, Massachusetts Department of
Environmental Quality Engineering to William E. Baird, WEB
Engineering Associates, Incorporated (February 14, 1984).
Concerning review of four reports entitled "Kerry Place,
Norwood, Lots #1, #2, #3, and #4; Report of On Site
Investigation of Possible Chemical Contamination," dated
February 1, 1984.
-------
2 1 Correspondence (cont'rj)
5 Letter from Carr.erc" Kerry. Miniz. L='..n. Conn Ferns. G.c.s-,.
& Pcceo (Ar.crney fcr Grant Gear Works, Incorporate) to
SL.SSO Berr.ard, Massscrujser.s Cff.cs of the Attorney Genera:
(January 28. 1S=5) Concerning recent s.te activities relating :z
on-site car storage ar,c soil sampling.
2.4 Pollution Reports (POLREPs)
1. POLREP 1, (June 23, 1983)
2. POLREP 2, (July 1. 1983).
3. POLREP 3, (July 11, 1983).
4 POLREP 4, (July 12, 1983).
5. POLRE? 5, (July 23, 1983).
6 POLREP 6, (August 3, 1933).
2 5 On-Scene Coordinator Repcrt
1. "On-Scene Coordinator's Report," (June - August, 19S3).
Including Attachments 1-21. (Confidential business information
redacted.)
3.0 REMEDIAL INVESTIGATION (Rl)
3.1 Correspondence
1. Notice from Bartley King, Norwood Board of Health and John
Carrol), Norwood Board of Selectmen to the residents of
Meadowbrook area (June 28, 1983). Concerning analysis of
soil samples.
2. Notice from Bartley King, Norwood Board of Health, and John
Carroll, Norwood Board of Selectment to residents of
Meadowbrook area (June 29, 1983). Concerning analysis of
soil samples.
3. Memorandum from John Rgler, EPA Region I to Merrill S.
Hohman, EPA Region I (August 2, 1983). Concerning Norwood
PCS Blood Results.
4. Notice from Patricia Talbot, Norwood Board .of Health and.
Bernard Cooper, Norwood Board of Selectmen to residents of
Meadowbrook area (August 12, 1983). Concerning PCS test
results.
5. Letter from Robert Hurley, Grant Gear Works, Incorporated to
Leonard Pagnotto, Massachusetts Department of Labor and
Industries (December 7, 1983). Concerning letter of November
29, 1983
-------
3 1 Correspondence (ccnt'd)
6 Lerter from David Constant. Ec'.va-i £a'-er, sno E'zace:-
N'cricik County Hcs~ital to Revert H_'=y, Grart G~: v;-r-s
Incorporated (September 2-i, 1S34) Ccncsrnir.g group res^irs
of PCS anaiys.s of Grant Gear Works Incorporated employees
7 Letter from James C Colrr.an, Massacnusetts Department of
Environmental Quality Engineering to Jonn J, Carroll, Norwood
Town Manager (October a, 1S85) Concerning the presence cf
Polychlonnsted Biphenyl (PCS) contaminated -material on and
around property owned by Grant Gesr Realty Trust.
8 Letter from James Colman, Massachusetts Department of
Environmental Quality Engineering to John Hannon,
Massachusetts Department of Environmental Management
(January 15, 1986). Concerning analytical results on water and
sediment samples/Meadow Brook.
S. Letter from Susan M. Bernard, Department of the Attorney
General to Janine M. Sweeney, Morgan, Lewis & Bockius
(Attorney for Federal Pacific Electric)" Cameron F. Kerry, Mintz,
Levin, Conn, Ferns, Glovsky & Pcpeo (Attorney for Grant Gear
Works, Incorporated); Robert F. Sar.off, Foley, Hoag & Eliot
(Attorney for Cornell-Dubiher Electronics, Incorporated); Anton T.
Moehrke, Wright & Moehrke (February 11, 1986). Concerning
clients' agreement to prepares scope of work for a Remedial
Investigation/Feasibility Study at the Grant Gear Works
Superfund site.
10. Letter from Cameron F. Kerry. Mintz, Levin, Cohn, Ferris,
Glovsky & Popeo (Attorney for Grant Gear Works, Incorporated)
to Philip R. Boxett, EPA Region I (July 11, 1986). Concerning
EPA's decision not to include any remedial investtgation of PCS
contamination inside the industrial plant located at the site.
11. Letter from=Susan-M. Bernard, Department of the Attorney
General to Janine M. Sweeny, Morgan, Lewis & Bockius
(Attorney for Federal Pacific Electnc); Cameron F. Kerry, Mintz,
Levin, Cohn, Ferris, Glovsky & Popeo (Attorney for Grant Gear
•Works, Incorporated); Robert F. Sanoff, Fotey, Hoag & Eliot
{Attorney for Cornell-Dubilier Electronics, Incorporated); Anton T.
2- Moehrke, Wright & Moehrke (July 15, 1986). Concerning DEQE
and EPA review of RI/FS Scope of Work at the Norwood
Superfund Site.
12. Letter from Susan M. Bernard, Department of the Attorney
General to Janine M. Sweeny, Morgan, Lewis & Bockius
(Attorney for Federal Pacific Electric); Cameron F. Kerry, Mintz,
Levin, Cohn, Ferris, GJovsky & Popeo (Attorney for Grant Gear
Works, Incorporated); Robert F. Sanoff, Foley, Hoag & Eliot
(Attorney for Comell-Dubilier Electronics, Incorporated); Anton T.
Moehrke, Wright "& Moehrke (August 14, 1985). Concerning
DEQE and EPA review of RI/FS Scope of Work at the Norwood
Superfund Site.
-------
3 1 Correspondence (ccr.t'd)
13 Ler.-r frc~ Tncrras Mcf.tsncn, Mamcr.usens Cecarrr.s-;: cf
Env!ron.T~-r£l Q^'S ry E-.~ neenng iz Jcnn Ha~r.on,
Mas5ac"rLse~5 De-artrr.e-t of Envircrrr.entai Management
(Septernrer 25 i£=5). Concerning application for Water Qua.::y
Certification.
14. Letter from Cameron F. Kerry, Mints, Levin. Conn. Ferns,
Glovsky & Popeo (Attorney for Grant Gear Works, Incorporated)
to Honorable Joyce London Alexander, United States Magistrate
(November 25, 1SS6). Concerning Hurley et al., v. CorneH-
Dubilier Electronics, Incorporated et ai., Civil Action No, 85-
1417-MC.
15. Letter from Susan M Bernard, Department of the Attorney
General to Honcrasle Joyce London Alexander, United States
Magistrate (November 25, 1SS6). Concerning response to
Cameron F. Kerry's letter of November 25, 1986.
16. Letter from Cameron F. Kerry, Mirtz, Levin, Cohn, Ferns,
Giovsky & Pcpeo (Attorney for Grant Gear Works, Incorporated)
to Honcracle Joyce London Alexander, United States Magistrate
(Decemcer 3, 1SSS). Concerning response to letters dated
November 25 and 28, 1S8S.
17, Letter from Cameron F. Kerry, Mintz, Levin, Cohn, Ferns,
Glovsky & Popeo (Attorney for Grsnt Gear Works, Incorporated)
to Philip R. Boxell, EPA Region I (December 3, 1986).
Concerning Grant Gear Works' involvement in expediting a
prompt remedy at the Norwood PCS site.
18. Letter from Laurie Butt, Foley, Hoag & Eliot (Attorney for
Cornell-Dubilier Electronics, incorporated) to Lee Breckenndge,
EPA Region I (Decembers, 1986). Concerning handling of the
Comell-Dubtlier Electronics, Incorporated proposal to perform
the Remedial investigation and Feasibility Study at the Grant
Gear Works Site,
19. Letter from William F. Cass, Massachusetts Department of
Environmental Quality Engineering to Merrill Hohman, EPA
Region I (March 16, 1987). Concerning the Department of
'"-" Environmental Quality Engineering's decision to refer the lead
for the Norwood PCS site to EPA.
20. Letter from James C. Colman, Massachusetts Department of
Environmental Quality Engineering to Robert F. Sanoff, Foley,
Hoag & Eliot (Attorney for Comell-Dubilier Electronics,
Incorporated) (March 18, 1987). Concerning the conditional
offer by Cornell-Dubilier Electronics, Incorporated to perform the
Remedial Investigation and Feasibility Study at the Norwood
Superfund site.
21. Letter from Marvin Rosenstein, EPA Region I to John J.
Hannon, Massachusetts Department of Environmental
Management (August 11. 1987). Concerning flood and erosion
control project.
-------
3 2 Sar-oimg and Analysis Data
* Ssmp;,ng and a-a'ysis ca:a :or t,u5 Fe^e-a i.-ves' rst.c-1 ,-=,
be reviewed, by appointment only, at E^A Reg'cn I, Ezs-.-r,
f/assacnusetts
x
3 4 Inter.m Deliverables
1. "Interim Report en Drajnage System Contamination," Camp
Dresser & McKse Incorporated (January 19, 1988).
2. Memorandum from Susan Henderson, Camp, Dresser & McKee
to A. Quagiien, Camp, Dresser & McKee (February 17, 1988)
Concerning soil boring under floor slao in Grant Gear Works
building
3 B Remedial Investigation (Rl) Reports
1 "Draft Report - Summary of Reid Work - Norwood PCS Site,"
COM, Incorporated (September 25. 1935). (Conficential
business information redacted.)
2 "Final Remedial Investigation Report," ICF Incorporated for
Ebasco Services Incorporated, Volumes I and II (June 1989).
3. "Grant Gear Indoor Survey Results.Norwood PCB Site,
Norwood, Massachusetts" EPA Region I (June 1989).
3.7 Wcrk Plans and Progress Reports
1. "Technical Oversight for EPA TES III - Work Plan," COM Federal
Programs Corporation (December 18, 1987).
2. "Work Plan - Remedial Investigation and Feasibility Study," ICF
Incorporated for Ebasco Services Incorporated (December
1987).
3. "Plan for Soil Sampling Below Slab on Grade at Grant Gear,
Incorporated, Norwood, Massachusetts," Camp, Dresser &
McKee, Incorporated {January 1988). (Confidential business
information redacted.)
- 4. "Plan for Video Examination of Drains at Grant Gear
Incorporated - Norwood Massachusetts," Camp Dresser &
McKee Incorporated (January 1988). (Confidential business
information redacted.)
5. 'Grant Gear Indoor Survey Work Plan," EPA Region t (April
1989).
-------
3 9 Heattn Assessments
1. Crcss-re^erencs: Notice from Pstric a Talbc: N'or.vcc- Boa-^ cf
Health, and Bernard Coocsr. Ncr.vccd Bce-c cr Se er.rr.e-. -c
res.cents of Meadcworook area {August 12. *S23) Ccrcerr."?
PCB test results (Filed anc! cited as entry rurr.ce' 4 m 2 i
Correspondence.)
2. Letter from David Chnstiani and Nancy Fox, Norfolk County
Hospital to Robert Hurley, Grant Gear Works, Incorporated
(August 29, 1983). Concerning transmittal cf attached "Report
of PCB Blood Levels among Grant Gear Employees," Norfolk
County Hospital.
3 Letter from Leonard Pagnotto, Massachusetts Department of
Labor and Industries to Jack Lawler, Grant Gear Works,
Incorporated (November 29, 1983). Concerning transmitts! of
attached letter report on health hazards to Grant Gear Works,
Incorporated employees,
4 Cross-reference. Letter from Robert Hurley, Grant Gear Works,
Incorporated to Leonard Pagnotto, Massacnusetts Department
of Labor and Industries (December 7, 1983). Concerning letter
of November 29, 1983. (Filed and cited as entry number 5 in
3.1 Correspondence.)
5. "PCB Exposure Assessment in Norwood," Martha Steele,
Division of Environmental Health Assessment, Massachusetts
Department of Public Health (February 22, 1984).
6. Letter from David Christian), Edward Baker, and Elizabeth Averill,
Norfolk County Hospital to Robert Hurley, Grant Gear Works,
Incorporated (August 29, 1984). Concerning transmittal of
attached "Report of Follow-up PCB Study at Grant Gear,"
Norfolk County Hospital (August 29, 1984).
7. Cross-reference: Notice from Bartley King, Norwood Board of
Health, and John Carroll, Norwood Board of Selectment to
residents of Meadowbrook area (June 29, 1983). Concerning
analysis of soil samples. (Fled and cited as entry number 2 in
3.1 Correspondence.)
3.1& Endangerment Assessments
1. "Final Endangerment Assessment Report," ICF Incorporated for
Ebasco Services Incorporated (August 1989).
-------
FEASiSiLITY STUDY (FS)
Letter from Cameron Kerry, Mir.tz, L=v,n. Ccr.r, Ferns, G.cvsXy
& Pcpeo (Attorney for Grant Gear Works, lnccroora:ed) to
David Fierra, EPA Region I, and William Gaucnan,
Massachusetts Department of EnvironmentaJ Protection (August
24, 1989). Concerning transmittal of "Evaluation of Discharge
Options for the Grant Gear Site, Norwood, Massachusetts"
ENSR Consulting and Engineering (August 1829). [("Evaluation
of Discharge Options for the Grant Gear Site ," (August 1989)
is file and cited as entry number 4 in 4 S Feas.oility Study (FS)
Reports.)]
4 4 ir.tenm Dehverables
i. "Oversight at Grant Gear - Norwood Massachusetts - During
Pipeline Video Taping," CDM Federal Programs Corporation
(March 15. 1S88).
2 "Trip Report - Grant Gear Building, Norwood, Massachusetts,
Dye Testing of Sewer Connection," CDM Federal Programs
Corporation (April 12, 1988).
4.6 Feasibility Study (FS) Reports
1. Letter Report from Charles Martin and Jeffrey Lawson, ERT to
Cameron Kerry, Mintz, Levin, Conn, Ferns, Giovsky & Popeo
(Attorney for Grant Gear Works, Incorporated) (June 10, 1988).
Concerning summary evaluation of drainage line remedial
actions.
2. "Feasibility Study Report," ICF Incorporated for Ebasco Services
Incorporated (August 1989).
3. 'Draft Feasibility Study for the Grant Gear Building, Norwood
PCS Site, Norwood, Massachusetts," Camp, Dresser & McKee
{August 17, 1989).
4. "Evaluation of Discharge Options for the Grant Gear Site •
Norwood, MA,' ENSR Consulting Engineering (August 1989).
(Confidential business information redacted.)
Comments received by EPA Region I during the forma} public comment
period on the Feasibility Study and Proposed Plan are filed and cited in
5.3 Responsiveness Summaries.
-------
j. 7 Work F ans ana P-cgresa Reports
1 Cross-p.s-e.-sr.es 'Wcrk Plan - Re.~ei:al lrv.es: ~s:.cr. =--
reas.c.1 r/ Sfjcy," ICF IncarpcrarecJ 'sr Eoasco Services
.'.-iccrpc.'cr-d (Decemcer 1937) (Fiiec and ate: ss en:ry nurr.rr'
2 in 3.7 v.'ork Plans and Progress Reports )
49 Proposed Plans for Se'ected Remedial Actions
1. "EPA Prccoses Clean-up Plan for the Norwccd PCS S.:e," EPA
Region I (August 1989).
2. Memorandum from Jane Downing, EPA Region I to File {August
14, 1S83) Concerning Grant Gear Works' macninery and cftcs
equipment clean-up goal.
Comrr.snts received by EPA Region I during the forma/ public cc
period on the Feasibility Study and Proposed Plan are filed and cited tn
5.3 Responsiveness Summaries.
5.0 RECORD OF DECISION
5.1 Correspondence
1. Letter from Janine Sweeney, Morgan, Lewis & Bockius (Attorney
for Federal Pacific Electric Company) to Paul Keough, EPA
Region I (August 31, 1989). Concerning extension of comment
period.
2. Letter from Robert Sanoff, Foley, Hoag & Eiiot (Attorney for
Cornell-Dubilier Electronics, Incorporated) to Jane Downing, EPA
Region I (September 6, 1989). Concerning extension of
comment period.
3. Letter from Merrill Hohman, EPA Region I to Janine Sweeney,
Morgan, Lewis & Bockius (Attorney for Federal Pacific Electric
Company) (September 12, 1989). Concerning EPA's response
To SweertSy^fc&quest'for extension of the comment period.
4. Letter from Richard McAister, EPA-Region t to Robert Sanoff,
Foley, Hoag & EHot (Attorney for Cornell-Dubilier Electronics,
Incorporated) (September 13, 1989). Concerning EPA's
response to Sanoff's request to extend the comment period.
5.2 Applicable or Relevant and Appropriate Requirements (ARARs)
1. Cross-Reference: Letter from Massachusetts Department of
Environmental Protection to EPA Region I concerning state
concurrence with selected remedy and attainment of state
ARARs is Appendix C of the Record of Decision [filed and cited
as entry number 1 in 5.4 Record of Decision (ROD)]
-------
5 3 r=5ocrs.veress S<-~—ary
C.rcs3-F,5;='er;ce Responsiveness Summary is AccsiC'>
re Recc"- of Dec:s,on [filed and cited as entry n^r-.cer • r. 5 -
Rsccrc cf Dec:SiOn (ROD)].
r.-e following citations indicate documents received by EPA Region I
cjnng :he forma! public comment period.
2 Ccmme-:s Dated August 5, 1989 from Faye Siegfriedt, Ncrwocc
resident, on the August 1989 Norwood PCB Proposed Plan -
'EPA Proposes Clean-up Plan for tne Norwood PCB Site." EPA
Region I.
3 Comments Dated August 29, 1989 from John Carroll, Norwood
Town Manager, on the August 1989 Proposed Plan - "EPA
Proposes Clean-up Plan for the Norwood PCB Site," EPA
Region I." NOTE: "Specifications for the Meadow Brook Flood
Control Project," may be reviewed, by appointment only, at EPA
Region I. Boston, Massachusetts.
- Letter from Cameron Kerry, Mmtz, Levin, Conn, Ferris, Giovsky
& Pcpeo (Attorney for Grant Gear Works, Incorporated) to Jane
Downing, EPA Region l (September 8r 1989) with attached
index. Concerning inclusion of additional documents in the
Norwocc PCB Site Administrative Record.
5. Comments Dated September 11, 1989 from Robert Sancff,
Foley, Hoag & Eliot (Attorney for Comell-Dubilier Electronics,
Incorporated) on the August 1989 Norwood PCB "Final
Feasibility Study Report," ICF Incorporated for Ebasco Services
incorporated.
5. Comments Dated September 11, 1989 from Leslie Ritts, Morgan,
Lewis & Bockius (Attorney for Federal Pacific Electric) on the
June 1989 Norwood PCB "Final Remedial Investigation Report,*
ICF Incorporated for Ebasco Services Incorporated, on the
August 1989 Norwood PCB "Final Feasibility Study Report," ICF
Incorporated for Ebasco Services Incorporated, and on the
August 1989 NorwpQdj PCB "Final Endangerment Assessment
Report," ICF Incorporated for Ebasco Services Incorporated.
7. Comments Dated September 12, 1989 from Cameron Kerry,
Mintz, Levin, Cohn, Fern's, Giovsky and Popeo (Attorney for
Grant Gear Works, Incorporated) on the August 1989 Proposed
Plan - "EPA Proposes Clean-up Plan for the Norwood PCB
Site," EPA Region I.
8. Letter from Dale Young, Massachusetts Department of.
Environmental Protection to Jane Downing, EPA Region I
(September 27, 1989). Concerning Massachusetts Department
of Environmental Protection's comments on the Norwood PCB
site Proposed Plan.
-------
Reccra of Oe^s.cn (SCO)
1- 'Record cf Decs.cn • Feme-.a! A:=--ative S==c: ~- EPA
Pegicn I (Sec-e~cer 25 1SS9)
9 0 STATE COORDINATION
91 Correscondence
1. Letter from Ricnard Chafpm, Massachusetts Department of
Environmental Quality Engineering to John J. Carroll, Norvvccd
Town Manager (March 6, 1985). Concerning a brief history arc
update on the status of the Norwood PCB hazardous waste
site.
10.0 ENFORCEMENT
TO.' Correspondence
1. Letter from Charles W. Stenholm, United States House of
Representatives, Committee on Small Business to Michael
Delano, EPA Region I (July 23, 1985). Concerning the
testimony of Robert J. Hurley, President of Grant Gear Works.
Incorporated, before the House Small Business Committee,
2. Letter from Samuel L Silverman, United States Department of
Justice, United States Attorney, District of Massachusetts to
Cameron F. Kerry, and Michael S. Gardener, Mintz, Levin.
Conn, Ferris, Giovsky & Popeo (Attorney for Grant Gear Works,
incorporated) (October 11, 1985). Concerning John F. Hurley,
et al.t v. Cornetl-Dubiiier Electronics, Incorporated et a!., Civil
Action No. 85-1417-MC.
3. Letter from Thomas C. McMahon, Massachusetts Department of
Environmental Quality Engineering to Joseph Dorsett, Jr.,
Certified Engineering and Testing Co., Incorporated (March 16,
1987}. Concerning response to Joseph Oorsett, Jr.'s fetter of
February 23, 1987.
10.3 State and Local Enforcement Records
1. Memorandum from A. Charles Lincoln, EPA Region I to Robert
DiBiccaro, EPA Region I (March 14, 1984). Concerning
transmitta) of Proposed Civil Complaint against Cooper
Industries, Arrow Hart Division, Hartford, Connecticut.
2. Complaint, Director of the Division of Water Pollution, Control v
Kelek Division of Arrow-Hart. Incorporated. Suffolk County
Superior Court.
10
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10-1 interviews Deocs.tions. ana Affidavits
1 A-cavit cf Arthur F Hurley (Feorus". 3. 1925)
2 A-cavit cf Joseph Lewis (Jure 6, 1955)
'.25 FnP-Specfic Negotiations
1 Letter from Michael Gardener, Mintz. Levin, Cohn, Ferns,
Gicvsky & Popeo (Attorney for Grant Gear Works, Incorporated)
to Samuel Silverman, United States Office of the Attorney
General, and Stephen Leonard, Massachusetts Office of the
Attorney General (June 27, 1S85). Concerning Huriey, et ai, v
Corned-Dubilier Electronics, Incorporated.
2. Letter from Cameron F. Kerry, Mintz, Levin, Cohn, Ferris,
Giovsky & Popeo (Attorney for Grant Gear Works, Incorporated)
to Micnael R. Deland, EPA Region I (March 31, 1937}
Concerning Norwood PCS Site.
3. Letter frcm Larry S. Snowhite, Mintz, Levin, Cohn, Ferns,
Gicvsky & Popeo (Attorney for Gran: Gear Works, Incorporated)
to Gene A. Lucero, EPA Washington (April 6, 1937).
Concerning final settlement cf Grant Gear Works' potential ctvil
(facility to federal government arising from the release of PCBs
at the Grant Gear Works site.
4, Letter from Cameron F. Kerry, Mintz, Levin, Cohn, Ferns,
Glovsky & Popeo (Attorney for Grant Gear Works, Incorporated)
to Gene Lucero, EPA Washington (July 21, 1987). Concerning
Norwood PCS site Innocent Landowner Settlement.
5 Letter from Gene Lucero, USEPA to Cameron Kerry, Mintz,
Levin, Cohn, Ferns, Glovsky & Popeo (Attorney for Grant Gear
Works, Incorporated) (August 11, 1987). Concerning innocent
landowner settlement issues.
6 Letter from Cameron Kerry, Mintz, Levin, Cohn, Ferns, Glovsky
& Popeo {Attorney for Grant Gear Works, Incorporated) to
Richard McAllister, EPA Region I (April 28, 1988). Concerning
Grant Gear Works, Incorporated settlement issues.
7. LettefJtenrCarrtercn Kerry, Mintz, Levin, Cohn, Ferris, Gtovsky
& Popeo (Attorney for Grant Gear Works", Incorporated) to
Michael Deland, EPA Region I, John DeVillars, Massachusetts
Executive Office of Environmental Affairs, and Daniel
Greenbaum, Massachusetts Department of Environmental Quality
Engineering (April 24, 1989). Concerning innocent landowner
settlement.
10.7 Administrative Orders
1. Administrative Order, In the Matter of Grant Gear Works.
Incorporated and Grant Gear Reaitv Trust. Norwood.
Massachusetts. Docket No. 89-05 (December 16, 1988).
11
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108 Consent Dec'ees
1 Conser: AcrseT.ent and Orcer, In :~e Ma"- r Cc'~ -^^- =~
E'eczr.-'_cs" ircc'zc'a's^ Ccmmcnweaitn c: Mas=5c~-5="s
Depairr.ent cr E^vircnrnenral Quality Eng.reer.ng (Ajrj=: 29,
1985).
11 0 POTENTIALLY RESPONSIBLE PARTY (PRP) '
11 12 PRP-Related Dccumerts
1. Letter from Jcsech Nassif, Monsanto Company to Cameron
Kerry, Mintz, Levin, Conn, Ferris, Glovsky & Popeo (Attorney for
Grant Gear Weeks, Incorporated) (July 3, 1S84), Concerning
PCS sales by Monsanto to previous owners of Grant Gear s.ts
2. Cross-reference: Affidavit of Arthur F, Hurley (February 8,
1985). (Filed and cited as entry number 1 in 10.4 Interviews,
Depcsit:ons, and Affidavits.)
3 Letter from Stcxiey Towles, Brown Brothers Harnmen &
Company to Robert Hurley, Grant Gear Works, Incorporated
(March 4, 19B5). Concerning financing.
4. Cross-reference: Affidavit of Joseph Lev/is (June 6, 1985).
(Filed and cited as entry number 2 in 10.4 Interviews,
Depositions, and Affidavits).
5. Statement of Robert J. Hurley, Grant Gear Works, Incorporated,
before the Committee on Judiciary, United States Senate (June
10, 1985). Concerning effect of Superfund law on Grant Gear's
business.
6. Lette^fes^Alga^aridyga, Old Stone Bank to Robert Hurley,
Grant Geaf Works, Incorporated (June~14,~1985). Concerning
financing.
7. Letter from Nicholas Mavroules, Member of Congress,
Subcommittee on General Oversight and the Economy, and
Charles Stenhoim, Member of Congress, Subcommittee on
~^~~ Energy, Environment and Safety, United States House of
Representatives to Robert J. Hurley, Grant Gear, Incorporated
(July 1, 1985). Concerning the hearing to be held on July 15,
1985 to review the impact of the current Superfund law on small
businesses.
8. Statement of Robert J. Hurley, Grant Gear Works, Incorporated,
before the Committee on Small Business, Subcommittees on
General Oversight and the Economy, and Energy, Environment
and Safety, United States House of Representatives (July 15,
1985). Concerning the effect of Superfund law on Grant Gear's
business
12
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12 PHP-Related Documents (cont'd)
9 letter from Micr.ae' Garce-.er, M.ntz Levin, Ccr.n, Fs^s,
Glcvsky & Pcpeo (Attorney for Gra~.: Gear Works, Incorporate:,
to Stephen Leonard, Massachusetts Office cf the Attorney
General (July 17, 1SS5). Concerning Grant Gear's financial
situation.
10. Letter from Debbie Freeclman, Massachusetts Industrial Services
Program to Robert Hurley, Grant Gear Works, Incorporated
(September 5, 1985). Concerning financing.
11 Letter from Edward McSweeney, EPA Region 1 to Robert Hurley,
Grant Gear Works, Incorporated (November 18, 1986).
Concerning Grant Gear NPDES permit application.
12. Letter from Thomas McMahon, Massachusetts Department of
Environmental Quality Engineering to Joseph Dorsett, Certified
Engineering and Testing Company, Incorporated (March 16,
1S87). Concerning Grant Gear NPDES permit
13. Letter from Thomas McManon, Massachusetts Department of
Environmental Quality Engineering to Robert Hurley, Grant Gear
Works, Incorporated (January 26, 1SSS), Concerning Grant
Gear NPDES permit.
14. "Authorization to Discharge Under the National Pollutant
Drscharge Elimination System," State Permit No. MA 0029262.
EPA Region I and Massachusetts Department of Environmental
Quality Engineering (January 29, 1S88).
15. Letter from Margaret Sheehan, Massachusetts Office of the
Attorney General to Cameron Kerry, Mintz, Levin, Cohn, Ferns,
Glovsky & Popeo (Attorney for Grant Gear Works, Incorporated)
(April 5, 1988). Concerning Grant Gear's application for a
waiver from anti-degredation provisions of the Massachusetts
Clean Waters Act, regulations.
16. Letter from Cameron Kerry, Mintz, Levin, Cohn, Ferris, Glovsky
& Popeo (Attorney for Grant Gear Works, Incorporated) to
Thomas McMahon, Massachusetts Department of Environmental
Quality Engineering (April 15, 1988). Concerning application for
• anti-degradation vanance.
17. Letter from Paul Dekker, Certified Engineering & Testing
Company Incorporated to Joanne Robbins, Mintz, Levin, Cohn,
Ferris, Glovsky & Popeo (Attorney for Grant Gear Works,
Incorporated) (April 15, 1988). Concerning lab results for water
samples collected at Grant Gear Works, Incorporated.
18. Letter from Thomas McMahon, Massachusetts Department of
Environmental Quality Engineering to Robert Hurley, Grant Gear
Works, Incorporated (May 24, 1988). Concerning application for
variance to authorize discharges to Meadow Brook.
13
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12 PRP-Related Documents (cont'd)
".9. Cross-reference' Letter Repcrt from Charles r.:=-.n a-d J="5y
Lawson, ERT to Cameron Kerry, M,r:i Levin, Conn, Ferns
Gicvsky & Popeo (Attorney for Gran: Gear WC'KS. incorpcratecj
(June 10, 1988). Concerning summary evaluation of arasnage
line remedial actions. (Filed and cited as entry number 1 in 4 5
Feasibility Study (FS) Reports.)
20. Letter from Cameron Kerry, Mintz, Levin, Cohn, Ferns, Glovsky
& Popeo (Attorney for Grant Gear Works, Incorporated) to
Thomas McMahcn, Massachusetts Department of Environmental
Quality Engineering (June 28, 1988). Concerning application for
antidegredation variance.
21. Letter from Thomas McMahon, Massachusetts Department of
Environmental Quality Engineering to Cameron Kerry, Mintz,
Levin, Conn, Ferns, Glovsky & Popeo (Attorney for Grant Gear
Works, Incorporated) (July 18, 1988). Concerning Grant Gear
Works' request for extension to provide arguments for variance.
22. Letter from Marian Rambelle and Jeffrey Lawson, ERT to
Cameron Kerry, Mintz, Levin, Cohn, Ferris, Giovsky & Pcceo
(Attorney for Grant Gear Works, Incorporated) (August 12,
1988). Concerning PCS sampling plan at Grant Gear Works
property.
23. Letter from Cameron Kerry, Mintz, Levin, Cohn, Ferris, Giovsky
& Popeo (Attorney for Grant Gear Works, Incorporated) to
Thomas McMahon, Massachusetts Department of Environmental
Quality Engineering (August 12, 1988). Concerning Grant
Gear's application for anti-degredation variance.
24. Letter from Thomas McMahon, Massachusetts Department of
Environmental Quality Engineering to Cameron Kerry, Mintz,
Levin, Cohn, Ferris, Glovsky & Popeo (Attorney for Grant Gear
Works, Incorporated) (August 26, 1368). Concerning Grant
Gear Works' request for variance.
25. Letter from Jane Downing, EPA Region I to Cameron Kerry,
Mintz, Levin, Cohn, Ferris, Glovsky & Popeo (Attorney for Grant
Gear Works, Incorporated) {August 30, 1988). Concerning
review of PCB Sampling Plan at Grant Gear Works
Incorporated.
14
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n -.2 PRP-Related Documents (cont'd)
25 Memorandum frcm Carr.e'C* Kerry .*.',.ntz, Le.T., Ccr.r,, Fe.-s
Giovsky & Popso (Attorney 'cr Gr=~: Gear V.cxs, ircc.'-cra:=^i
to Thomas McNtancn, Juc.tr, Perry Da(e Yc-.~g, Massair-user.e
Department of Environmerta! Qua.ry Engines'.r'g, Jans
Downing, Richard McAllister, Joan Jcuzaws, E?A Region I;
Margaret Sheehan, Office of the Ancrney General;
Massachusetts Water Authority; Executive Office of
Transportation; Commissioner of Public Works; Town of
Norwood Board of Selectmen; Metropolitan Area Planning
Council; Robert Hurley; John Hurley Joanne Bobbins (August
31, 1988). Concerning Grant Gear Works, Incorporated
NPDES permit application.
27 Letter from Cameron Kerry, Mintz. Levin, Ccnn, Ferns, Glovsky
& Popeo (Attorney for Grant Gear works, Incorporated) to
Thomas McMahon, Massachusetts Department of Environmental
Quality Engineering (August 31, 1SB3). Concerning Grant Gear
Works request for variance.
23. Letter from Cameron Kerry. Mintz. Levin, Ccnn, Ferns, Glovsky
& Popeo (Attorney for Grant Gear Works, incorporated) to Jane
Downing, EPA Region I (September 1, 1988). Concerning
review of PCS sampling at Grant Gear Incorporated.
29. Letter from Cameron Kerry, Mintz, Levin, Ccnn, Ferris, Glovsky
& Popeo (Attorney for Grant Gear Works, incorporated) to
Thomas McMahon, Massachusetts Department of Environmental
Quality Engineering (September 7, 1988). Concerning
application for NPDES permit and antidegredation variance.
30. Letter from Elisabeth Goodman, Massachusetts Department of
Public Works to Cameron Kerry, Mintz, Levin, Conn, Ferris,
Glovsky & Popeo (Attorney for Grant Gear Works, Incorporated)
(September 13, 1988), Concerning Grant Gear Works' possible
permit application to discharge storm drainage into state
highway drainage system.
31. Letter from David Fierra, EPA Region t to Robert Hurley, Grant
Gear Works, Incorporated (September 30, 1988). Concerning
denial of NPDES permit No. MA 0029262.
32. Letter from Cameron Kerry, Mintz, Levin, Conn, Ferris, Glovsky
& Popeo (Attorney for Grant Gear Works, Incorporated) to
David Fierra, EPA Region I (October 11, 1S88). Concerning
NPDES permit No. MA 0029262 denial.
33. Letter from David Fierra, EPA Region I to Robert Hurley, Grant
Gear Works, Incorporated (Novemoer 7, 1S88). Concerning
Grant Gear, Incorporated, Norwood, Massachusetts NPDES
permit application No. MA 0029262 denial.
15
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12 PRP-Re!ated Documents (cont'd)
3- Lerte: from Cameron Kerry, Mintz. Levin Ccr.n, Fevs. G':.-=-/
& Pcpeo (Arcrney for Grant Gear Works. lr,ccrc;-=:sc!) :z
David Fierra, EPA Region I and Wiiiiam Gaugnar.
Massachusetts Depanment of Environmental Qua r/ Engineering
(December 30, 1988). Concerning Grant Gear V.'crks,
Incorporated and Grant Gear Realty Trust. Docket No 89-05.
35. Letter from Cameron Kerry, Mintz, Levin, Conn, Ferns, Glovsky
& Popeo (Attorney for Grant Gear Works, Incorporated) to
David Fierra, EPA Region I, and William Gaughan,
Massachusetts Department of Environmental Qua.ity Engineering
(January 6, 1S89). Concerning transmittal of attached "Revised
Sampling Plan,* ENSR Consulting and Engineering (January 3,
1989).
35. Letter from Robert Chrusciel, Norwood Engineer.r.g Company,
Incorporated to Robert Hurley, Grant Gear Works, Incorporated
(January 18, 1989). Concerning roof drainage study.
37. Letter from Cameron Kerry, Mintz, Levin, Conn, Ferns, Gicvsky
& Pcpep (Attorney for Grant Gear Works, Incorporated) to
David Fierra, EPA Region I, and William Gaughan,
Massachusetts Department of Environmental Quality Engineering
(January 20, 1989) Concerning Grant Gear Works,
Incorporated and Grant Gear Realty Trust, Docket No. 89-05.
38. Letter from Cameron Kerry, Mintz, Levin, Conn, Ferris, Glovsky
& Popeo (Attorney for Grant Gear Works, Incorporated) to John
Heaiey, EPA Region I (February 1. 1989). Concerning approval
of sampling plan.
39. Letter from Cameron Kerry, Mintz, Levin, Conn, Ferris, Glovsky
& Popeo (Attorney for Grant Gear Works, Incorporated) to
David Fierra, EPA Region t (February 14, 1989). Concerning
sampling plan.
40. Letter from Cameron Kerry, Mintz, Levin, Cohn, Ferris', Glovsky
& Popeo (Attorney for Grant Gear Works, Incorporated) to
David Fierra, EPA Region I, and William Gaughan,
Massachusetts Department of Environmental Quality Engineering
(March 21, 1989). Concerning stormwater sampling.
41. Letter from Cameron Kerry, Mintz, Levin, Cohn, Ferris, Gtovsky
& Popeo (Attorney for Grant Gear Works, Incorporated) to
David Rerra, EPA Region I and William Gaughan,
Massachusetts Department of Environmental Quality Engineering
(Apnl 4, 1989). Concerning progress on sediment and
stormwater sampling.
42. Letter from Dianne Chabot, Mintz, Levin, Cohn, Ferris, GSovsky
& Popeo (Attorney for Grant Gear Works, Incorporated) to
David Fierra, EPA Region I, and William Gaughan,
Massachusetts Department of Environmental Quality Engineering
(May 19, 1989), Concerning progress report. -
16
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•i 12 PrP-Related Doc-jr.ents (ccnt'd)
42 Letter frcrr. D.anne Chaoct, M;r:z, Le.-, Cor- Fr"3 G ;.£-,.
& Pcceo (Attorney for Grant Gear V/c'-o, Incc'cc'rec) —
Dsvid Fier'= EPA Reg.on I arc Wili.sn Gaugrs-,
Massachusetts Department of Envircr.—ental Qua..:/ Er.g-r5r,r;
(June 15, 1539). Concerning Administrative Orcer Docne: No
89-05.
44 Letter from Cameron Kerry, Mir.tz, Levin, Cohn, Ferris, G cvsky
& Popeo (Attorney for Grant Gear Works, Incorporated) to
David Fierra, EPA Region ! and William Gaughen,
Massachusetts Department of Environmental Quality EncTeenng
(June 29, 1£39). Concerning availability of Gra.it Gear's craft
report required by Administrative Order.
45 Letter from Mark Stein, EPA Region I to Cameron Kerry, Mmtz.
Levin, Cohn, Ferns, Glovsky & Poceo (Attorney for Gran: Gear
Works, Incorporated) (July 5, 1989). Concerning Grant Gear
Works, Incorporated Clean Water Act Administrative Order No.
89-05.
^5 Letter from Dianne Chabot, Mintz, Levin, Conn, Ferns, Glcvsky
& Popeo (Attorney for Grant Gear Works, Inccrpcrated) to
David Fierra, EPA Region 1 and William Gaughan,
Massachusetts Department of Environmental Quality Engineering
(July 19, 15S9) Concerning Administrative Order No. 89-05.
47 Cross-reference: Letter from Cameron Kerry, Mmtz, Levin,
Cohn, Ferns, Glovsky & Popeo (Attorney for Grant Gear Works,
Incorporated) to David Fierra, EPA Region I, and William
Gaugnan, Massachusetts Department of Environmental Quality
Engineering (August 24, 1989). Concerning transmtttal of
"Evaluation of Discharge Options for the Grant Gear Site," ENSR
Consulting and Engineering (August 1989). (Filed and oted as
entry number 1 in 4.1 Correspondence.)
130 COMMUNITY RELATIONS
13.2 Community Relations Plans
1. "Interim Final Draft Community Relations Plan, Norwood PCB
Site,' ICF Incorporated for Ebasco Services Incorporated (June
1988).
2. "Ftnaf Community Relations Plan for the Norwood PCB Site," ICF
Incorporated for Ebasco Services Incorporated (September
1989).
17
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-2 3 N=.v C.ppmgs. Press Re'eases
1 "Senator Kenr.ecy Announces Directcr c' Gear's :c- Di^^e
Control to Vis.t Norwood, Massacr.us-tts,1 Orf-ce r Ser.a'ir
Eiwari M Kennedy of Massachusetts (Jur.e 23. *>9=3)
2 Bellctti and DEQE Negotiate for Private St'jcy c: PCS Site '
EPA Region I (August 29, 1985).
3 'DEQE Announces Interim Measure at Norwood PCS Site ' E?A
Region I (December 9, 1985).
4 "The Environmental Protection Agency Will Hold a Puolic
Meeting to Discuss Current Work in Progress at the Norwood
Superfund Site in Norwood, Massachusetts," Environments!
News - EPA Region I (March 3, 1987).
5 "EPA Announces Public Meeting to Explain Results of the
Remedial Investigation and Endangerment Assessment for the
Norwood PCS Superfund Site," Environmental News - EPA
Region I (June 8, 1989).
6 "Public Meeting to Explain Proposed Cleanup Plan for the
Norwood PCS Superfund Site," Environmental News - EPA
Region I (August 3, 1989).
7 "United States Environmental Protection Agency Invites Puclic
Comments on the Feasibility Study and Proposed Plan for the
Norwood PCS srte in Norwood, Massachusetts and Announces
the Availability of the Site Administrative Record," The Patriot
Ledger - Qumcy, Massachusetts (August 4, 1989).
8 "United States Environmental Protection Agency Invites Public
Comments on the Feasibility Study and Proposed Plan for the
Norwood PC8 site in Norwood, Massachusetts and Announces
the Availability of the Site Administrative Record," The Daily
Transcript - Dedham, Massachusetts (August 9, 1989).
9. Media Advisory, Environmental News - EPA Region I (August
18, 1989). Concerning announcement of public hearing to
accept oral comments on the cleanup alternatives for Norwood
PCB site.
13.4 Public-Meetings
1. Meeting Notes, October 23, 1984 Norwood Board of
Selectmen's meeting on the Norwood PCB site.
2. "Hazard Assessment, Norwood PCB Site, Norwood,
Massachusetts," Public meeting for the Norwood PCB site, EPA
Region I (March 1988).
3. EPA Region I Meeting Notes, Norwood Community Workgroup
meeting for the Norwood PCB site {April 24, 1989). Concerning
purpose of the community work group and discussions on
information EPA could provide to citizens.
18
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13 5 Fez: Shee:s
Crcss-refe's^cs Nct;ce from 5anl=y Kirc Ncr.vccz Ec='~ ;:
H5=:-i, and Jcr.n Carrc!l, Ncr.vccd Sea" of Se!e::~=n tc
r== z=-,ts cf tre Meacow Brcck area (Jur.e 23, 19=3) (F e:
arc cted as er.rry number 1 in 3 1 Correspondence)
Cress-reference: Notice from Bartley King, Norwood Scare c:
Hea.:^i, and Jorn Carroll, Norwood Board of Selectmen 10
res dents of ;ne Meadow Brook area (June 29, 1583}
Concerning analysis of soil samples. (Filed and cited as entry
numcer 2 in 3 1 Correspondence.)
"EPA Sampling Activities Begin at Norwood PCB Site,"
S'jserfund Program Fact Sheet, EPA Region I (Ncvemcer *S~7)
"EPA Completes Field Investigation at the Norwood PCB Site,"
Supe-r'und Program Information Update, EPA Region I
(Ncvemoer 1535).
"EPA Announces the Results of the Remedial Investigation and
Erzangerment Assesssment," Superfund Program Fact Sheet,
Ncr.vood PCB Site, EPA Region I (June 1989).
140 CONGRESSIONAL RELATIONS
14 1 Ccrrespcncence
1. Letter from Michael R. Deland, EPA Region I to Honorable John
J. Moakley, United States House of Representatives (July 13,
1SS3). Concerning response to letter dated June 22, 1983
regarding the discovery of PCB contamination in Norwood,
Massachusetts.
2. Cross-reference: Statement of Robert J. Hurley, Grant Gear
Works, Incorporated, before the Committee on Judiciary, United
States Senate (June 10, 1985). (Filed and cited as entry
number 5 in 11.12 PRP-Related Documents.)
3. Cross-reference: Letter from Nicholas Mavroules, Member of
Congress, Subcommittee on General Oversight and the
Economy, and Charles Stenholm, Member fo Congress,
Subcommittee on Energy, Environment and Safety, United
States House of Representatives to Robert J. Hurley, Grant
Gear Works, Incorporated (July 1, 1985). (Filed and cited-as
entry number 7 in 11.12 PRP-Related Documents.)
4 Cross-reference: Statement of Robert J. Hurley, Grant Gear
Works, Incorporated, before the Committee on Small Business,
Subcommittees on General Oversight and the Economy, and
Energy, Environment and Safety, United States House of
Representatives (July 15, 1985). (Red and cited as entry
number 8 in 11.12 PRP-Related Documents)
19
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5 Meetng Nc'es Jane Downing, =PA Region I arc =cv/a'~ '.'.
Kc-.-edy. r.'e-cer cf tre Unites States Ser.ete, M.c~ael Cea~c
EPA Regie" I, Jcnn Carol!, Norwood Town Manager, D£" =i
Grsenbaurn Massachusetts Department of Environmental Qua •/
Eng.neenng, anc Massachusetts Department of Public He= :h
Staff (Apnf5, 1539) Concerning Town Of Norwood's ccr.cer-is
about clean-up and flood control project.
6. Letter from Edward M. Kennedy, Member of the United Srstes
Senate to Michael Defand, EPA Region I (May 3, 1989).
Concerning discussions at meeting with Town cf Norwocc
official abci-T cleanup.
160 NATURAL RESOURCE TRUSTEE
15.1 Correspondence
1. Ls-er from Gcrc'on E. Beckett, United States Department of the
Interior Rsn and Wildlife Service to John C. Keane, EPA Region
I (September 14, 1987). Concerning receipt of Trust Notification
Perm for the Norwood PCS site
2 Letter from Kenneth Finkelstem, National Oceanic and
Atmospheric Administration to Jane Downing, EPA Regicn I
(September 20, 1989). Concerning PCS sediment criterion
154 Trustee Notification Form and Selection Guide
1. Letter from Merrill S. Hohman, EPA Region I to William
Patterson, Department of the Interior (August 19, 1987).
Concerning EPA documentation of release or threatened release
of hazardous substances, pollutants or contaminants at
Norwood PCB site.
16.5 Technical Issue Papers
1. "A Discussion of PCB Target Levels in Aquatic Sediments,"
National Oceanic and Atmospheric Administration and EVS
Consultants, Incorporated (January 8, 1988).
20
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SITE MANAGEMENT PECORCS
17-1 Site Pr.ctcgrsc-s/Msps
Tr.e rezcrd c,:stf in er,:ry number 1 may £e reviewed, £/ azzcmmer,:
only, at EPA Ksgion I, Boston, Massachusetts.
1 "Site Analysis - Norwood PCB Site," EPIC (Apnl 1934}
17.7 Reference Dcc-jments
1. "Site Investigation, Grant Gear Incorporated, Norwood,
Massachusetts," E,C. Jordan Company (June 1S33).
2. "Kerry P!ace Norwood, Lot #1 Report of On Site Investigation c'
Poss.cie Chemical Contamination," WEB Engineering ASSOCIATES
Incorporated (January 20, 1984).
3. "Kerry Place Norwood, Lot #2 Report of On Site Investigation of
Poss.oJe Chemical Contamination." WEB Engineering Associates,
Jrtccrscrated (January 20, 1984),
4 "Kerry Place Norwood, Lot #3 Report of On Site Investigation of
Possible Chemical Contamination," WEB Engtneenng Associates,
Incorporated (January 20, 1984).
5. "Kerry Place Norwood, Lot #4 Report of On Site Investigation of
Possicte Chemical Contamination," WEB Engineering Associates
Incorporated (January 20, 1984).
6. "Kerry Place Norwood, Lot #5a Report of On Site Investigation
of Possible Chemical Contamination," WEB Engineering
Associates, Incorporated (January 20, 1984).
17.8 State and Local Technical Records
1. Letter from James C. Colman, Massachusetts Department of
Environmental Quality Engineering to John J. Carroll, Norwood
Town Manager (October 31, 1985). Concerning understanding
between Division of Solid and Hazardous Waste and the
Division of Waterways tn the meeting held in the Division's
Boston office.
2. Letter from James C. Colman, Massachusetts Department of
Environmental Quality Engineering to John Hannon, Division of
Waterways (January 15, 1986). Concerning response action to
levels of contaminants found in the water and sediments of
Meadow Brook.
3. Certificate of the Secretary of Environmental Affairs on the
Environmental Notification Form, Massachusetts Office of
Environmental Affairs (May 9, 1986).
4. Property Location Plan, Meadow Brook Improvement Project,
Norwood, Massachusetts (July 1986).
5. Public Notice, Department of the Army, New England Division,
Corps of Engineers (January 22, 1987).
21
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INITIAL REMEDIAL MEASURE (IRUJ RECORDS
'3 1 Ccrresooncer.ce
Letts' from CaT.e-cn Kerry, r.'.r.tz. Levin, Cchn, Ferr.s, G.:•.;-,'
& Pcseo (Attc.-r.ey for Gram Gear WOCKS, Incorpcrated) to
Susan Bernard. Massachusetts Office of the Attorney Genera1
(August 19, 1555) Concerning GZA study.
2. Letter from Cameron Kerry, Mintz, Levin, Conn, Ferns, Glcvsvy
& Pcpeo (Attorney for Grant Gear Works, Incorporated) to
Susan Berna-d, Massachusetts Office of the Attorney General
(August 23, 1985). Concerning GZA study.
3. Letter from Rcoert Hurley, Grant Gear Works, incorporated to
James Caiman, Massachusetts Department of Environmental
Quality Engineering (September 10, 1985). Concerning GZA
stucy.
4 Letter from Wiiiiam F. Cass, Massachusetts Department of
Environmental Quality Engineering to Merrill S. Hohman, EPA
Region I (Cccoer 11, 1S8S). Concerning request for transfer of
responsibility for managing remedial activities at Norwood to
Massachusetts Department of Environmental Quality
Engineering.
5 Letter from James C. Colman, Massachusetts Department of
Environmental Quality Engineering to Heather Ford, EPA Region
I (December 11, 1985). Concerning DEQE belief that an Initial
Remedial Measure (IRM) should be implemented at Norwood
site.
6. Letter from James C Colman, Massachusetts Department of
Environmental Quality Engineering to Robert S. Sanoff, Foley,
Haag & Eliot (Attorney for Cornetl-Dubilier Electronics,
Incorporated) (January 15, 1986). Concerning Initial Remedial
Measure (IRM).
22
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SECTION II
GUIDANCE DOCUMENTS
-------
NORWOOD PCS
NPL SITE ADMINISTRATIVE RECORD
GUIDANCE DOCUMENTS
EPA guicance Cc-'jmer.ts rr.ay ce renewed at EPA Reg en I, Bcstcn, Massachusetts
General EPA Guidance Documents
1 "Appendix D - Protect.cn of Wetlands: Executive Order 119SQ," 42
Feceral. Reo-ster 25S51 (1977).
2 Memorandum from Jcr.n W, Lyon toxic Substance Division, USEPA to
Sanford W Harvey, Jr., Enforcement Division, EPA Region IV (August
3. 1979). Concerning aoplicability of PCS regulations to spiils whicn
occurred prior to the effective date of the 1978 regulation. , -
3. US Environmental Protection Agency. Office of Emergency and
Remedial Response. Community Relations in Saeerfund: A Handbook
(Interim Version) (EPA/540/G-88/002), June 1988.
4 U.S. Environmental Protection Agency. Office of Emergency and
Remedial Response Guidance for Conducting Remedial Investigators
and Feasibility Studies Under CERCLA (EPA/540/G-89/004) (OSWER
Directive 9355.3-01), October 1988.
5. "National Oil and Hazardous Substances Pollution Contingency Plan,"
Code of Federal Regulations (Title 40, Part 300), 1985.
6 U.S. Environmental Protection Agency. Office of Emergency and
Remedial Response. Suoerfund Remedial Design and Remedial Action
Guidance (OSWER Directive 9355.0-4A), June 1S86.
7. U.S. Environmental Protection Agency. Office of Research and
Development. Hazardous Waste Engineering Research Laboratory.
Handbook for Stabilization/Solidification of Hazardous Wastes
(EPA/540/2-86/001), June 1986.
8. Comprehensive Environmental Response. Compensation, and Liability
Act of 1980. amended October 17, 1986.
9. U.S. Environmental Protection Agency. Office of Emergency and
Remedial Response. Suoerfund Public Health Evaluation Manual
(OSWER Directive 9285.4-1), October 1S86.
24
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General EPA Guidance Documents fcont'd)
-: US Environmental Prc;ec:;"n Agency Cr',-= c: Sc..c '/.are arc
E~='cency Response lnrer.n Guica^cs en Susanna Se ?ctir.r -'
Rf-eciv (OSWER Directive S2350-19), Decerncer 24, 193S
'i US Environmental Protection Agency. Office of Solid Waste and
Emergency Response Data Quality Objectives for Remedial Respn
Acrvities1 Development Process (EPA/540/G-87/003), March 1S87
'2. "Part 761 - Polychlorinated Biphenyfs (PCSs) Manufacturing,
Processing, Distribution in Commerce, and Use Prohibitions," Coge of
Fgceral Regulations (40 CFR Part 761), 1S87.
13. Memorandum from J. Winston Porter to Addressees ("Regional
Acmmistrators, Regions )-X; Regional Counsel, Regions I-X; Director,
Waste Management Division, Regions 1, IV, V, Vll, and VIII; Director,
Emergency and Remedial Response Division, Region II; Director,
Hazardous Waste Management Division, Regions III and VI; Director
Toxics and Waste Management Division, Region IX; Director,
Hazardous Waste Division, Region X; Environmental Services Division
Directors, Region I, VI, and VN"), (July 9, 1987). Concerning intenm
guidance on compliance with applicable or relevant and appropriate
requirements.
14. u.S Environmental Protection Agency. Office of Health and
Environmental Assessment. A Compendium of Technologies Used in
the Treatment of Hazardous Waste (EPA/625/8-87/014), September
1S87.
15. Memorandum from Denise M. Keehner, Chemical Regulation Branch,
USEPA to Bill Hanson, Site Policy and Guidance Branch, USEPA
(October 14, 1987). Concerning comments on the PCS Contamination-
Regulatory and Policy Background Memorandum.
16. 'Guidelines for PCS Levels in the Environment," The Hazardous Waste
Consultant, pp. 26-32 (January/February 1988). c * * -
17. Memorandum from Christopher Zarba, USEPA to Jane Downing, EPA
Region I (April 11, 1988). Concerning the application of interim
sediment criteria values at Sullivan's Ledge Superfund Site.
18. U.S. Environmental Protection Agency. Office of Emergency and
Remedial Response. Draft Guidance on Remedial Actions lor
Contaminated Groundwater at Suoerfund Sites (OSWER Directive
9283.1-2), April 1988.
25
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General EPA Guidance Documents fcont'dl
19 "Sucpiemental R.sk Assessment G-dance 'zr :r.s S-^s^ur.d Prcgrarr.
EPA Region I (June 1959)
2C 'Summary of tne Requirements. Land D.sccsal Restrictions Rcre," E?A
Region I
Norwood PCS NPL Site-Specific Guidance Documents
1. US. Environmental Protection Agency. Office of Health and
Environmental Assessment. Development of Advisory Leve's of
Pah/chlorinated Biohenyis (PCBsl Cleanup (OHEA-E-187), May 1S8S. ~~
2. "Project Summary: PCS Sediment Decontamination -
Technical/Economic Assessment of Selected Alternative Treatments."
Ben H. Carpenter, EPA Region V (March 1987).
3. "PCS Spill Cleanup Policy," {40 CFR Part 751), Feceral Register (April
2, 1987). _ ; .-
4. "Sediment Quality Values Refinement: 1938 Update and Evaluation of
Puget Sound AET," PTI Environmental Services for Tetra Tech,
Incorporated (September 1988).
5. Letter from Lanny D. Weimer, Resources Conservation Company to
Angelo L Massullo, ICF Technology, Incorporated (December 16,
1988). Concerning technical paper entitled "Basic Extractive Sludge
Treatment (B.E.S.T.)* - Demonstrated Available Technology."
6. "PCS Sediment Decontamination Processes Selection for Test and
Evaluation," Ben H. Carpenter, Engineering Research Applications, and
Donald L Wilson, EPA Region V (1988).
7. "Evaluation of the B.E.S.T.* Solvent Extraction Sludge Treatment
Technology Twenty-Four Hour Test," Gerard W. Sudell, Enviresponse,
Incorporated.
26
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ATTACHMENT B
RECORD OF DECISION AMENDMENT
NORWOOD PCB SUPERFUND SITE
RESPONSIVENESS SUMMARY
This Responsiveness Summary documents public comments regarding the proposed
amendment to the 1989 Record of Decision (ROD) expressed during the public comment
period. The summary also documents EPA's responses to the comments that were received.
The public comment period for the amendment to die 1989 ROD for the Norwood PCB
Superfund Site began on February 22 and ended on March 22, 1996. EPA held an official
Public Hearing on March 6, 1996 at 7:30 p.m. at Memorial Hall in the Norwood Town Hall
to accept oral comments on rnis proposed amendment to die 1989 ROD. Four oral
comments were received at the public hearing. Written comments were also accepted. EPA
received five written comment letters. The comments and responses are summarized below:
Pan I - Comments bv Local Officials
1. One Town of Norwood Selectman and the Town's Board of Health asked about whose
responsibility it would be for future maintenance and repair of the asphalt cap. These
officials were concerned mat, if EPA would not retain responsibility for maintenance
and repair of the cap, there would not be enforcement power to ensure the future
integrity of the cap. The Selectman was also concerned diat the Town would be
expected to maintain and repair the cap.
EPA Response: There are several means by which long-term operation and maintenance
may be performed. First, if the remedy is performed by private panics, those panics would
be required to assume die obligation as pan of an enforceable consent decree. Second, a
future redeveloper may undertake the obligation as pan of acquisition and redevelopment of
the property. Finally, at sites where no private party is available to perform long-term
operation and maintenance the National Contingency Plan provides that states perform this
obligation. •
2. The Town Selectman expressed confusion and frustration at the change in cleanup
levels and asked whether EPA has now changed its opinion regarding the dangers
posed by the Site based solely on cost considerations.
EPA Response: Human health risk assessment is a relatively "young" science. As such,
substantial progress has been made over the past several years and risk assessment methods,
assumptions, and techniques have been refined during that time. When EPA decided to take
a fresh look at the remedy at the Site, it decided that the cleanup levels should also be re-
examined based upon advances in risk assessment. The revised cleanup levels being adopted
are a result of this re-examination. Also, more current assumptions regarding future use of
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the Site were incorporated into the re-examination. By using exposure assumptions which
better reflect the expected future use of the Site, more appropriate cleanup levels are derived.
Furthermore, EPA's regulations governing the cleanup of Superfund Sites, the National
Contingency Plan (NCP), specifies an "acceptable risk range" which is used to determine the
need for action and, if action is required, to determine the exient to which cleanup should be
conducted. This acceptable risk range represents the probability of cancer occurring in
individuals exposed at a hazardous waste site and spans a 10"* to 10"6 risk. The revised
cleanup levels for the Norwood Site are roughly at the midpoint of this risk range. The
newly proposed cleanup levels are also generally consistent with cleanup levels that would be
derived under the Commonwealth's "Massachusetts Contingency Plan", Chapter 21E
program, were this a state site rather than a federal site. EPA still believes mat the
contamination at the Site poses a serious health threat if left unaddressed. EPA also believes
that the amended remedy will adequately address this threat and result in a remedy that
protects human health and the environment. Regarding cost issues, see response to Comment
No. 40.
3. The Town's Board of Health expressed concern about the depth of the cap. The
Board also stated that this concern is even more relevant if high levels of
contamination are capped on Site.
EPA Response: The primary threats posed by PCBs at the Site are from direct exposure
(touching) or by incidental ingestion (accidental eating). EPA believes that the asphalt cap
proposed is of sufficient thickness to serve as an adequate barrier from these threats.
Furthermore, the cap will be designed to resist cracking and to minimize maintenance. Also,
at a minimum, the entire cap and cover will be inspected annually for wear, cracks, or other
damage, and all necessary repairs will be conducted' in a timely manner. The cap and cover
will also include a geotextile fabric which, in addition to providing additional stability to the
cap and cover, will serve as an additional barrier between the cap and the underlying soils.
Part J7 - Citizen Comments
4. One citizen expressed concern about EPA's ability to assure future monitoring and
inspections of the cap. This citizen also stated that this cleanup should include •
removal of dirt and that the proposed remedy was not adequate.
EPA Response: See response to Comments No. 1 and No. 2 in Pan I above.
5. . Two citizens expressed frustration with the slow pace of the cleanup.
EPA Response: The national average for Superfund cleanups from the date a site is first
listed on the National Priorities List (NPL) to the date when construction activities are
completed is 12 to 14 years. The Norwood PCB Superfund Site was listed on the NPL in
1986; hence, 10 years has elapsed. Elapsed time notwithstanding, EPA believes that the
amended selected remedy can be completed quickly and with limited difficulty. It is
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expected that all construction activities associated with this amended selected remedy will be
completed by 1997.
6. One citizen asked for the total amount spent by the government at this Sue to date and
how much of that wdl be recouped.
EPA Response: As of March 1996, the date of EPA's most recent cost summary, EPA has
incurred approximately $18.7 million relative to the investigation, study, planning
enforcement, and cleanup of the Norwood PCB Superfund Site. Approximately $2 million
has been collected from current and prior owners of the property. EPA has filed a lawsuit in
federal court against other former owners and operators of the property to recoup additional
response costs (see Site History and Enforcement Activities section in the ROD Amendment).
7. One citizen expressed support of the plan to demolish the building and cap the Site.
EPA Response: No response required.
8. One citizen expressed concern about Meadow Brook and future flooding of the Brook
and expressed a desire to see the Brook remediated.
EPA Response: The amended selected remedy remains consistent with the 1989 ROD
which addresses cleanup of contaminated sediment hi Meadow Brook. Furthermore, as
stated in the 1989 ROD, after excavation of the Brook, it will be restored in a manner
consistent with the Town's Meadow Brook Flood Control Project.
9. One citizen expressed concern that the Town was running out of developable land and
that the remedy should allow future redevelopment of this Site.
EPA Response: The cap will be constructed in a manner which will allow its use and will
allow flexibility for the placement of new structures on the property, even hi areas slated for
capping. The cap design may also include the placement of "clean utility corridors" to
further enhance redevelopment potential as well as protectiveness of the capping remedy.-
See also, responses to Comment Nos. 35 through 37 and No. 44, below.
10. One citizen discussed the dangers of PCBs and their accumulation in fat cells of
mammals. This commenter stated disagreement with any opinions stating that PCBs
do not pose a health risk.
EPA Response: EPA has never contended that PCBs do not pose a health threat. PCBs are
a group of manmade chemicals that contain 209 different compounds with varying harmful
effects. EPA considers PCBs probable human carcinogens, based on sufficient evidence of
carcinogenicity hi animals. In addition, noncarcinogenic adverse effects have been noted in
humans or animals exposed to varying PCB mixtures in the following biological systems;
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* . skin
* gastrointestinal * liver * neurological
* blood * endocrine * reproductive
* muscular * imrmmological * developmental
Potential adverse health effects from PCBs have been evaluated in the human health risk
assessment for this Site.
11. One citizen stated that a "cosmetic cap" cannot assure that natural forces will not
leach pollutants into the community's water supplies and stated a preference for a
more thorough cleanup.
EPA Response: The cap is not merely "cosmetic." See Section VTI.B.4. of the ROD
Amendment for a discussion of the components of the cap and cover. Also see section XI of
the ROD Amendment for a discussion of how the amended selected remedy is protective of
human health and environment.
The Site does not present any threat to local water supplies. Groundwater underlying the
Site discharges to the adjacent Meadow Brook. The groundwater treatment plant which
recently began operation at the Site serves to intercept contaminated groundwater flowing in
the direction of Meadow Brook, extracts it from the aquifer and treats the contamination
prior to discharge. Use restrictions on the Site prohibit the extraction of groundwater
underlying the Site for drinking water use. Therefore, EPA believes that this remedy will
protect against direct contact with contamination as well as the spread of contamination in the
future.
Part 777 - PotentialtyJResponsible Party Comments
Comments fay GZA GeoEnvironmental. Inc. on behalf of Cooper Industries. Inc..
Cornell Dubilier Electronics. Inc.. and Federal Pacific Electric
12. These PRPs supported the general thrust of EPA's proposed amended cleanup plan
based upon its cost-effectiveness, implememability, and protectiveness.
EPA Response: No response required.
13. These PRPs do not believe that poly nuclear aromatic hydrocarbons (PAHs) should be
considered Site-related chemicals of concern.
EPA Response: EPA reviewed the statistical evaluation provided by GZA and Cambridge
Environmental, Inc. (CEI) and determined that the available information did not support the
conclusion that the PAH contamination at the Site was due to highway traffic. See February
1, 1996 memorandum from Kenneth W. Brown Director of EPA's Technology Support
Center, included in the Administrative Record for this ROD Amendment. While EPA still
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considers PAHs potential contaminants of concern at the Site, no specific cleanup levels have
been set for these compounds. Since the highest concentrations of PAHs are expected to be
removed during excavation of sediments in and adjacent to Meadow Brook as part of the
amended ROD, the risks associated with these compounds should be reduced to protective
levels.
14. These PRPs pointed out that the figure provided as part of the Proposed Amended
Cleanup Plan, the "Conceptual Outline of Soil Clean-up Levels and Extent of Cap" is
intended to delineate areas where cleanup levels apply rather than areas proposed for
excavation.
EPA Response: This comment is correct. The figure provided in the Proposed Amended
Cleanup Plan and included as a figure in the ROD Amendment delineates general areas
where specific cleanup levels will apply and is expected to be broader than the actual area or
areas requiring excavation.
15. These PRPs contend that there is no clear basis for the 1 ppm cleanup criterion of
Meadow Brook. These PRPs contend that a PCB cleanup level of 10 ppm would be
protective for Meadow Brook.
EPA Response: The 1 ppm clean-up level established in the 1989 ROD and the ROD
Amendment is based upon the calculation of a sediment concentration using Site-specific total
organic carbon (TOC) data that would be protective of aquatic life using the sediment quality
criteria approach. This method is outlined in "Technical Basis for Deriving Sediment
Quality Criteria for Non-ionic Organic Contaminants for the Protection of Benthic Organisms
Using Equilibrium Partitioning, EPA-822-R-93-011" . This methodology is appropriate for
Meadow Brook, classified by the Commonwealth of Massachusetts as a Class B water which
shall be capable of supporting aquatic life.
16. These PRPs state that if the Brook sediments are excavated to accommodate the Brook
cross-section as set forth in the Town's Meadow Brook Flood Control Project
(MBFCP), a 1 ppm sediment cleanup level would not be warranted since the flood
control project provides for restored bottom and slope materials.
EPA Response: EPA believes that it is acceptable to leave some contaminated materials in
the Brook so long as these materials are adequately covered by restored bottom and slope
materials planned for as part of the MBFCP. Were the MBFCP not planned, EPA would
require excavation of all soils and sediments exceeding the 1 ppm criterion hi the Brook.
EPA believes that it is more cost-effective and more easily implementable to excavate all
soils and sediment necessary to meet the restored MBFCP contour rather than excavate a
limited amount of material, conduct extensive sampling to determine areas requiring
additional excavation, and repeat this process several tunes. Achievement of the 1 ppm
cleanup level throughout the Brook could prove difficult and could require multiple
excavations in portions of the Brook, and could extend far deeper than the contour being
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proposed by the MBFCP. See also response to Comment No. 17, below.
17. In reference to the restoration of Meadow Brook, these PRPs stated that the purpose
and the scope of the remedy should be to satisfy CERCLA criteria, noc promote
public works projects.
EPA Response: Excavation of the Brook, and restoration consistent with the MBFCP, is
consistent with the remedial objectives of CERCLA. It ensures the protectiveness of the
remedy to ecological receptors in a more cost-effective and easily implementable manner than
complete excavation to 1 ppm PCBs. The MBFCP also ensures the proper drainage of
surface waters through the Site, which is essential considering that, at the completion of
remedial activities, wastes will remain in place on-Site. See also response to Comment No.
16, above, and Section VII.B.3 of the ROD Amendment, Sods and Sediment in Meadow
Brook and its Banks.
18. These PRPs contend that EPA provided no basis for its 10 ppm PCB cleanup criteria
of the wooded areas adjacent to Meadow Brook. They state that their contractor CEI
derived a cleanup level of 50 ppm for surficial soils in this area. The PRPs agreed
that the proposed 50 ppm cleanup level of subsurface soils in this area should be
adequate, alrnough they do not anticipate contact with subsurface soils. The PRPs
state that the 10 ppm surficial cleanup level is too conservative and unnecessary and
will destroy more of the buffer of trees located along the northern edge of die Brook.
EPA Response: The 10 ppm PCB cleanup level for this area was based upon EPA's
recalculation of the risk assessment considering the current land use and a reasonable future
use for this area. The exposed individual was assumed to be an older child (age 6-16) who
might frequent diis area 3 days per week for 6 mondis per year. The 10 ppm cleanup level
for PCBs represents a 5 x 10"* cancer risk level for diis receptor. In addition, diis cleanup
level is set at 10 ppm in order to be protective of aquatic life hi the Brook should soils from
this area erode into die Brook. Notwithstanding, restoration of this area and of Meadow
Brook should be done in such a way as to minimize any erosion from diis area since soils
exceeding the Brook cleanup level of 1 ppm PCBs may still remain in place in this wooded
area. EPA does not believe that die overall extent of excavation will be increased
dramatically by selecting a 10 ppm cleanup level for surficial soils rather than 50 ppm.
Conversely, by increasing this cleanup level to 10 ppm from 1 ppm as set forth in the 1989
ROD, die volume of contaminated soils, and the areal extent of the wooded area which must
be disturbed are greatly reduced, retaining much of die wooded buffer north of die Brook.
Regarding the cleanup level for subsurface soils in this wooded area, EPA believes that a
cleanup level for these soils is proper. The SO ppm cleanup level set for this area is based
upon a construction exposure scenario since sewer lines run adjacent to the Brook in diis area
which could require repair or replacement in the future.
19. These PRPs state their belief that a reduction in the size of die cap would further
enhance die property's redevelopment potential.
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EPA Response: While EPA does anticipate that the actual capped area on the Grant Gear
property will be minimized to encourage development of the parcel, EPA does not believe
chat the area! extent of the cap is the only consideration for development potential. The finaJ
cap design must ensure that slopes of the capped area do not make this area unusable for
parking or for construction of new structures in this area. Furthermore, adequate drainage
must be installed to ensure that the capped area drains stormwater properly and does not
merely divert this water to other portions of the property which are now unpaved (since these
areas will likely be included in any future development plans). However, EPA notes thai cap
design issues, such as proper drainage and slope, are essential to ensure the long-term
effectiveness and permanence and overall protectiveness of the cap, future Site development
notwithstanding.
20. These PRPs state that the cap design should account for differences between areas of
contaminated soils and the contaminated building slab.
EPA Response: EPA agrees with this comment. Although not specifically discussed in the
Proposed Amended Cleanup Plan, EPA contemplates that the cap design over the areas of the
most heavily contaminated soils will be more substantial than the cap to be placed over the
building slab, provided that no contaminated soils are consolidated onto the slab.
21. These PRPs recommend that the cap be graded with a gentle slope and designed such
that runoff from the property will sheet flow to adjacent vegetated areas or to the
street.
EPA Response: These issues are largely design issues which will be addressed when the
plans and specifications for the cap are prepared. As discussed in response to Comment No.
19 above, the cap should be designed with a gentle slope to ensure its long-term effectiveness
and permanence and suitability for future development of the property; also, adequate
drainage should be included as part of the cap design and construction. However, EPA
believes that it may not be appropriate to design the cap to merely shed stormwater to
adjacent areas or to the street. Drainage from the capped area(s) should be designed
consistent with state and local codes, standard practices, and applicable or relevant and
appropriate requirements ("ARARs").
22. These PRPs recommended that the feasibility and cost-effectiveness of
decontamination approaches to some demolition debris be examined. These PRPs
contend mat selective decontamination and salvaging of specific building media, such
as structural steel beams, may be feasible and cost-effective.
EPA Response: EPA will not preclude the analysis of the feasibility and cost-effectiveness
of selective decontamination of certain building demolition debris. Debris from the
demolition will be handled in the most protective, implementable, and cost-effective manner.
Specifically addressing the issue of the structural steel beams, it appears that due to
contamination by PCBs and high levels of lead due to the presence of lead-based paint on
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the surface of these beams, disposal, rather ihan decontamination and salvaging of this steel,
is the most cost-effective solution. However, EPA will not preclude re-examinaiion of this
*** issue should other parties assume responsibility for conducting the cleanup, and demonstrate
its cost-effectiveness.
23. These PRPs requested clarification of issues relating to EPA's proposal to dispose of
building debris under the cap: whether the cap can accommodate the debris, whether
the subgrade boiler room is available for disposal of these materials, and what wastes
are involved.
EPA Response: EPA plans to use the "basement" portion of the Grant Gear building for
consolidation of TSCA regulated demolition debris. Materials which may cause settling or
other difficulties for on-Site disposal in this area may be excluded from disposal in this
basement area. Materials which would be considered hazardous wastes under the federal
RCRA regulations would be precluded from on-Site disposal. Asbestos containing materials
may only be disposed of in this on-Site area if allowed by federal and state regulations.
Certain building materials are not expected to contain regulated levels of contamination.
These materials, namely certain concrete block and brick debris, may be usable as a portion
of the sub-base of the cap to be constructed as part of the remedy. Once the basement area
of the building is filled with contaminated debris, voids should be filled to avoid settling and
the entire area should be sealed with concrete (matching the surface of this area with the
existing building slab). This area will then be placed under the cap which will cover the
building slab.
24. These PRPs conceptually support the plan to demolish the building. However, these
PRPs contend that the cost difference between demolition of the structure and
decontamination and continued use of the structure should not be considered a
CERCLA cost but a cost to improve the property for redevelopment purposes.
EPA Response: EPA believes that demolition of the building is the appropriate CERCLA
response. Demolition of the Grant Gear building is a more permanent and more readily
implementable remedy. Based upon cost estimates set forth hi the Proposed Amended
Cleanup Plan and the ROD Amendment, the capital costs for demolition and decontamination
are essentially equal (approximately $200,000 difference). These costs do not take into
account future expenses which would be required for maintenance or repair of areas which
would need to be encapsulated under the decontamination alternative or future monitoring to
ensure success of the decontamination effort. The decontamination cost estimate also does
not include any costs associated with future remedial costs (i.e., ultimate demolition of the
building) which may need to be incurred if the building is allowed to remain standing under
this remedial action. Overall, EPA believes that the demolition of the Grant Gear building
represents a better overall balance of the nine CERCLA criteria for remedy selection than the
decontamination alternative. Therefore, EPA considers all costs to be incurred relative to the
demolition of the building to be CERCLA costs.
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25. These PRPs recommend placing contaminated equipment from inside the Grant Gear
building in the subgrade boiler room area of the building.
EPA Response: EPA concurs with this recommendation. It appears that these
machines/equipment cannot be recycled in compliance with TSCA due to the levels of PCBs
on their surfaces and, therefore, would require disposal. These machines/equipment may be
disposed of in the "basement" area of the Grant Gear building along with other debris from
the demolition of the building. Prior to disposal of these items, it may be necessary to drain
any liquids from reservoirs inside certain machines and ensure that these machines/equipment
are not otherwise unsuitable for disposal on-Site.
26. These PRPs asked whether more than one "hot spot" exists.
EPA Response: EPA does not believe that a second "hot spot" like the one discussed in
the Proposed Amended Cleanup Plan exists. The "hot spot" discussed in that Plan is
believed to be in the general vicinity of soil boring SS-012.
27. These PRPs requested additional information regarding the "hot spot" excavation of
chlorinated organic compounds, including information about contaminants, volume
estimates and disposal options.
EPA Response: EPA anticipates that this "hot spot" excavation will entail the excavation
of saturated soils from an area west of the Grant Gear building (located near soil boring SS-
012) to a cleanup level of 97 ppm 1,2,4-trichlorobenzene. This material should be
characterized to determine if it would be considered hazardous waste under RCRA and
disposed of at an appropriate off-Site facility if it is a hazardous waste. If it can be
demonstrated that on-Site disposal of this material will not pose a threat due to volatile and
semi-volatile contaminants and that it would not be considered hazardous under RCRA, these
"hot spot" soils may be disposed of on-Site. EPA has not generated a volume estimate for
this material but does not expect that this area will require extensive excavation.
28. These PRPs state that the planned "hot spot" excavation could be performed hi place
of, rather than in addition to, the current groundwater treatment system.
EPA Response: While EPA agrees that the proposed "hot spot" excavation may, in fact,
benefit the cleanup of the groundwater at the Site, EPA cannot assume that this "hot spot"
excavation will make continued groundwater extraction and treatment unnecessary. In order
to evaluate the potential beneficial impacts on groundwater due to the "hot spot" excavation,
the remedy calls for the evaluation of the need for continued groundwater extraction and
treatment and/or expansion of the network of extraction wells at the conclusion of other
remedial action work and periodically thereafter.
29. These PRPs expressed disappointment that EPA did not choose to reevaluate and
revise the groundwater remedy for the Site. These PRPs contend that the "hot spot"
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excavation and future monitoring of groundwater can provide equivalent protection
with less disruption and at substantially lower cost.
EPA Response: Construction of the groundwater treatment facility has been completed; the
plant now operates as an automated or one-man operation and is not believed to be causing
any noise or other nuisance which may be considered a disruption to the community.
Regarding the cost of the groundwater remedy, the bulk of monies for the groundwater
remedy have already been expended in constructing the plant and EPA believes strongly that
continued operation of the now-completed plant is justified unless and until a periodic review
demonstrates that die plant may be shut down. The first periodic review should take place in
1997.
30. These PRPs contend that groundwater treatment at this Site is not necessary based
upon Massachusetts Contingency Plan guidelines, water quality standards, EPA's
Groundwater Protection Strategy, and risk.
EPA Response: Under the current regulatory framework, EPA continues to use the federal
classification for this aquifer which states that this is a potential future source of drinking
water. The Massachusetts Contingency Plan comprises the State's cleanup regulations, which
are not the determining guidelines for this decision. EPA believes that, if the aquifer is to be
considered a future drinking water source then, contrary to the contention by these PRPs, a
significant risk does exist since groundwater contaminant concentrations exceed drinking
water standards. As noted above, federal groundwater classification would still consider this
aquifer a potential future source of drinking water. One cannot conclude from the fact that
surface water samples did not contain contaminants exceeding water quality criteria that
groundwater does not require remediation. The surface water data were not collected to
determine the influence of groundwater discharge to Meadow Brook, and are insufficient to
do so. A more appropriate screening approach would be to compare groundwater
concentration data to water quality criteria to determine if there could be an impact from
groundwater discharge to the Brook.
31. These PRPs contend that the precipitation/filtration and catalytic oxidizer systems in
the current groundwater treatment plant are not necessary.
EPA Response: EPA has just recently begun operation of the groundwater treatment facility
and believes that it is premature to fully assess the efficacy of certain unit operations in the
treatment plant. EPA will, throughout the life of the groundwater treatment plant, endeavor
to optimize performance and implement cost-savings measures so long as overall
performance and protectrveness of the treatment plant is not compromised. The full network
of extraction wells planned as part of the design have yet to be installed; therefore, because
the characteristics of the influent to the plant may change upon completion of these wells, it
is premature to make major process changes in the plant. Furthermore, since use of the
plant may be necessary to treat water with varying influent characteristics generated during
other remedial activities, EPA furdier believes that it would be inappropriate to make major
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process changes at this time.
32. These PRPs requested additional explanation of the S19.2 million cost figure
presented for the groundwater remedy at the Site.
EPA Response: In the fall of 1994, the US Army Corps of Engineers, on behalf of EPA,
awarded, a "delivery order' to its TERC contractor for approximately $8,9 million for the
construction of the groundwater treatment facility and two years of operation. During
construction, that figure increased due to typical cost growth for this type of project and due
to changes made during construction. It is now estimated that the capital costs of the
treatment plant, all extraction wells, and the initial two years of operation will total
approximately $11 million. An additional $8.2 million figure represents an estimate of the
present value of an additional ten to twenty years of operation of this treatment plant at a
cost similar to that being spent for its current operation. This is the basis for the $19.2
million figure stated in the Proposed Amended Cleanup Plan.
33. These PRPs state that the current underground piping serving the groundwater
treatment facility may have to be reconfigured to accommodate the capping activities.
EPA Response: EPA does not see the connection between existing underground piping and
the capping remedy. Existing underground piping constructed as pan of the groundwater
treatment remedy does not extend into any area expected to require excavation as part of the
ROD Amendment. Should existing well vaults lie in areas along the edges of the area to be
capped, the covers of these vaults can be raised to meet the new grade. This work will be
done as part of the capping remedy.
34. These PRPs propose that the groundwater remedy be re-evaluated at least semi-
annually and that the system be shut down if "its substantial costs do not provide
added protection. "
EPA Response: In the ROD Amendment, EPA states that the groundwater remedy will be
re-evaluated at the completion of remedial action (expected in 1997) and again at each
periodic review (EPA must conduct such periodic reviews at least once every five years but
may, in its discretion, conduct reviews more frequently). EPA believes that semi-annual
evaluations will be too frequent since several rounds of quarterly groundwater monitoring
results will likely need to be reviewed in order to make any determination regarding
suspension of groundwater treatment.
Comments by Mintz. Levin. Cohn. Ferris. Glovskv and Popeof P.C. on behalf of
(ear. Inc.
35. This PRP stated its general support for EPA's inclusion of beneficial re-use of the
Site as a component of the amended remedy, but does not believe that the proposed
ROD Amendment will in fact permit re-use.
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EPA Response: EPA desires to assist in the beneficial reuse of contaminated properties.
However, beneficial reuse, while a desideratum, is not one the nine evaluation criteria for
remedy selection set forth in the National Contingency Plan (40 CFR Part 300.430(e)(9)(iii)).
Currently, there are no specific redevelopment plans for the property, so it is difficult to
assess the extent to which any proposed redevelopment might be coordinated with the
CERCLA remedy at the Site. Once EPA receives a specific redevelopment proposal, it will
work with the proponent in an effort to address the proponent's concerns whtle maintaining
the remedy's consistency with the NCP.
36. This PRP is concerned that the slope of the landfill may make it impossible for
anyone to build a structure on it.
EPA Response: The slope of the cap and cover to be installed as pan of the remedy will be
appropriate to ensure that the remedy is protective, and that the cap and cover meet the
standards and specifications set forth in the ROD Amendment. However, EPA believes that
the resulting slopes will also be compatible with a variety of reuse options.
37. This PRP believes that the revised remedy's landfill design should incorporate a
subsurface utility grid. This grid would accommodate the water, sewer, electrical and
telephone needs of a future developer.
EPA Response: The subsurface utility grid contemplated by Grant Gear would add
significant expense to the remedy for die sole benefit of Grant Gear, and would diminish the
cost-effectiveness of the remedy. The costs of such extensive modifications to the Site
should be borne by either the Site owners or a prospective redeveloper. However, EPA
anticipates that the Site may be ultimately redeveloped, and that redevelopment may include
utility installation. Therefore, the Amended ROD provides that "clean corridors" may be
installed through the cap. These corridors would minimize the disturbance of contaminated
material during any future utility installation, thereby enhancing the overall protectiveness
and long-term effectiveness of the remedy.
38. This PRP notes that the remedy set forth hi the Proposed Amended Cleanup Plan does
not meet the CERCLA statutory preference for treatment as a component of the
remedy.
EPA Response: Section 121(b)(l) of CERCLA states: "Remedial actions in which treatment
which permanently and significantly reduces the volume, toxicity or mobility of the
hazardous substances, pollutants and contaminants is a principal element, are to be preferred
over remedial actions not involving such treatment." This statutory preference is
incorporated into one of the nine evaluation criteria for remedy selection set forth in the NCP
at 40 CFR Part 300.430(e)(9)(iii). 40 CFR Part 300.430(e)(9)(iii)(D) requires evaluation of
remedial alternatives in terms of "reduction of toxicity, mobility or volume through
treatment." In this ROD Amendment, EPA evaluated die amended selected remedy and
other alternatives according to all nine criteria. The amended selected remedy represents the
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best balance of factors among the evaluation criteria among the alternatives evaluated.
39. This PRP believes that EPA should "take" the Grant Gear property and pay the
property owners just compensation. This PRP notes that this was suggested to EPA
in comments on the 1989 ROD.
EPA Response: The remedial activities to be performed at the Site constitute a remediation
of the Grant Gear property, not a taking. A potentially responsible party is not entitled to
"just compensation" for property that is being returned to it hi an^improved condition.
Grant Gear decided, of its own accord, to stop operating its business in the building.
Considering this cessation of use, and the unanticipated expenses and limitations associated
with decontaminating the building and its contents, the presence of the building became an
obstacle to successful remediation at the Site. The present state of the building also is an
obstacle to redevelopment at the Site; demolition will actually enhance the prospects of
beneficial reuse of the property.
Grant Gear has expressly waived any claim that its property has been taken, or that it is
entitled to "just compensation." In a consent decree entered into between Grant Gear and the
United States, United States v. The Grant Gear Works. Inc.. et al. Grant Gear "agree[s]
neither to interfere with ... response actions nor to take actions ... inconsistent with any
response action selected by EPA and carried out by any person. [Grant Gear] recognizefs]
that the implementation of response actions ... may interfere with Settling Defendants' use of
the Trust Property and ... may interrupt normal operations.... [Grant Gear] agree[s],
pursuant to Paragraph 17 herein, not to assert claims against the United States or the
Hazardous Substances Superfund with respect to matters arising out of or relating to expenses
incurred or work performed pursuant to this Consent Decree, and not to seek any other
costs, or damages, including claims for business losses, property damages, takings or
condemnation of real property, or attorneys' fees from the United States arising out of
response activities at the Site." Consent decree at page 8, par. 5 (emphasis added). Also, at
page 19, par. 7, the consent decree provides: "In consideration of the United States'
covenants not to sue ... [Grant Gear] agree[s] not to assert any causes of action, claims, or
demands against the United States, or its contractors or employees, or the Hazardous
Substance Superfund with respect to matters arising out of or relating to expenses incurred or
payments made pursuant to this Consent Decree, or to seek any other costs, damages,
including Claims for business losses or property damage, or attorneys' fees from the United
States or its contractors or employees, arising out of response activities at the Site."
(emphasis added). These waivers of claims and covenants by Grant Gear were for good
consideration, namely Grant Gear resolving its CERCLA liability to the United States.
Furthermore, these waivers and covenants broadly relate to "response activities," as opposed
to only that remedy specifically selected in the 1989 ROD. In light of this language, Grant
Gear cannot seriously contend that the amended selected remedy in this ROD Amendment
somehow modifies or diminishes the effectiveness of its consent decree obligations.
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40. This PRP states that EPA has not provided any valid reasons for changing the
remedy. Instead, the PRP states that the remedy change seems born of EPA's desire
to save money. EPA has been unsympathetic when private parties have suggested this
type of argument as a reason to modify a remedy. Now, when it suits EPA's
purposes, EPA uses this argument to its own advantage.
EPA Response: Both the Proposed Amended Cleanup Plan and this ROD Amendment
describe the considerable uncertainty regarding the efficacy and practicability of solvent
extraction for this Site. Furthermore, cost considerations are a valid component of the
remedy selection process. See NCP at 40 CFR Part 300.430(e)(9)(iii)(G), and 40 CFR Part
300.430(f)(l)(ii)(D). In some circumstances, PRPs seek to perform less expensive remedial
alternatives that would also provide less protectiveness or otherwise not attain remedial
objectives. In this instance, the less expensive amended selected remedy is also the
alternative that presents the best balance among the nine evaluation criteria, as explained in
the ROD Amendment.
41. This PRP questions the proposed remedy's excavation of the "hot spot" of VOC-
contaminated soils. This PRP believes that placement of these soils on the Grant
Gear property would require compliance with RCRA Subtitle C, which it does not
believe EPA intends to do.
EPA Response: During the excavation of this "hot spot" material, it will be analyzed to
determine if it constitutes a RCRA waste. If it does, it will be disposed of off-Site. If it
does not, it may be relocated in a portion of die Site under the cap, yet above the water
table. In either scenario, there will be no disposal of RCRA waste on-Site, so a RCRA
Subtide C hazardous waste landfill Is not required.
42. This PRP believes that the disposal of highly contaminated soils beneath the cap will
require far greater reliance on institutional controls than was contemplated in the 1989
ROD. This will increase the costs and uncertainty to any party that otherwise may be
interested in redeveloping the Site. Conversely, the property would have been much
more valuable to the Site owners and any r.edeveloper if the cleanup had progressed
according to the 1989 ROD.
EPA Response: Institutional controls were and remain an integral pan of the remedy, as
originally selected in the 1989 ROD and as part of this ROD Amendment. The existing
institutional controls, recorded by Grant Gear pursuant to its settlement, are extremely strict,
since even the 1989 ROD would not have eliminated all existing subsurface PCB
contamination. See the Notice of Institutional Controls, attached to the consent decree
entered into between Grant Gear and the United States in 1991, United States v. The Grant
Gear Works. Inc.. et al. at page 4, par. l.c (no disturbance of contaminated untreated soils
without EPA approval); at page 4, par. l.d (soils covering "disposal areas" not to be
disturbed absent EPA approval). These and other restrictions hi the Notice of Institutional
Controls would apply to any activity at the Site even absent the ROD Amendment.
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The Grant Gear building, in the 1989 ROD, was essentially a substitute for a cap of the soils
beneath it. Therefore, existing institutional controls bar, without EPA approval, digging,
drilling or excavation of the building floor (Notice of Institutional Controls, page 5, par,
l.e), and require prior approval of any excavation of the floor beyond a depth of six inches
or a volume of 12 cubic inches Qd. page 6, par. 2.a). Thus, if the Grant Gear building
would have been demolished as part of a redevelopment scheme prior to this ROD
Amendment, the existing institutional controls would have been at least as onerous for Site
activities as any institutional controls under the ROD Amendment, and perhaps more so,
since under the 1989 ROD no cap would have covered the soils beneath the building
footprint.
EPA does not owe any property owner a duty to maximize the post-cleanup value of the
property to the owner. To the contrary, settlements with property owners typically attempt
to recapture, as cost recovery, the value added by the cleanup so that a property owner does
not obtain a "windfall" from a government-funded remediation. Moreover, there is no
evidence that the property would have been more valuable under the 1989 ROD. By
removing the outmoded Grant Gear building and placing the cap and cover over
contaminated portions of the property, the amended selected remedy arguably makes the
property more valuable to a developer.
43. This PRP believes that the ROD Amendment fundamentally changes the conditions
upon which Grant Gear entered into settlement with the United States in 1991.
Specifically, the PRP states that the ROD Amendment now deprives Grant Gear of
the value of machinery and equipment that was to have been decontaminated under
the 1989 ROD, and the ROD Amendment, by capping contamination rather than
treating it, further reduces the value of the Grant Gear property.
EPA Response: The consent decree entered into between the United States and Grant Gear
did not contemplate, nor does it depend on, a particular remedy being selected. Although
the recitals in the consent decree refer to the 1989 ROD-(consent decree at page 2.), the
decree clearly envisioned the possibility of additional or amended RODs. See, for example,
consent decree at page 7, par. 4.a, (access granted for "the response action selected by EPA
in the ROD or anv subsequent remedy selected by EPA for the Site oiLany_additinna| wnrlc
deemed necessary by EPA to meet the objectives of say. ROD"); page 7, par. 4.c (for "any
removal action"); page 7, par.4.g (assessing need for "additional response actions"); page 8,
par.5 ("Nothing in this Consent Decree shall in any manner restrict or limit the nature or
scope of response actions which may be taken by EPA in fulfilling its responsibilities under
federal and state law.") Considering the explicit language of the consent decree to which it
willingly assented, Grant Gear now cannot claim to have acted in detrimental reliance upon
the 1989 ROD.
As stated in the response to Comment No. 42 above, EPA does not owe any property owner
a duty to maximize the post-cleanup value of the property to the owner. Modifications made
to the building remedy pursuant to this ROD Amendment are consistent with the NCP,
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irrespective of whatever financial impact they may or may not have on Grant Gear, a
potentially responsible pany at the Site. However, the commenter seems to ignore the value
of faster completion of the remedy to Grant Gear's redevelopment possibilities.
Finally, to any extent that the ROD Amendment may dimmish Grant Gear's property value,
it has explicitly waived any claim for such "loss of value." See also the response to
Comment No. 39, above.
Pan IV - Comments b\ Other Interested Parties
44. A consultant involved in the redevelopment of contaminated sites expressed support
for the Proposed Amended Cleanup Plan as one that makes the Site more amenable to
development. However, this commenter raised several technical issues relative to the
remedy and its impact on redevelopment: (1) the Grant Gear building slab to be left
in place and capped over may present some difficulties for future development as
some intrusions into this area or removal of portions of this slab may be necessary in
the future; (2) the "phase B" groundwater extraction wells planned under the
groundwater remediation may need to be relocated so that they are not within the
footprint of a new structure; and, (3) it would be most beneficial to all panics if
construction efforts relative to redevelopment were coordinated with cleanup efforts.
EPA Response: First, the amended plan will not prohibit future excavation into the capped
area covering the slab (or other capped areas) nor will it preclude future removal of portions
of the slab. This work, however, is not considered within the scope of the cleanup. Second,
as discussed in the ROD amendment, at the conclusion of other remedial construction
activities, the need to install the "phase B" wells will be re-evaluated. In the event that it is
decided to proceed with installation of these extraction wells, efforts will be made to locate
these wells so as not to interfere with new or planned structures. Third, EPA supports the
concept of coordinated efforts between cleanup and development and will support efforts to
achieve this goal, so long as the remedy remains protective.
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ATTACHMENT C
RECORD OF DECISION AMENDMENT
NORWOOD PCB SUPERFUND SITE
COMMONWEALTH OF MASSACHUSETTS
DECLARATION OF CONCURRENCE LETTER
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COMMONWEALTH OF MASSACHUSETTS
EXECUTIVE OFFICE OF ENVIRONMENTAL AFFAIRS
DEPARTMENT OF ENVIRONMENTAL PROTECTION
ONE WINTER STREET, BOSTON MA 02108 |617) 292-o500
WILLIAM F WELD TRUDY CQXZ
Governor Secretary
ARGEO PAUL CELLUCCI DAVID B STRUHS
Lt Governor Commissioner
May 16, 1996
Ms. Linda Murphy, Director
Office of Site Remediation and Restoration
U.S. Environmental Protection Agency
J.F.K. Building
Boston, MA 02203
Re: Concurrence with the ROD
Amendment for the Norwood PCB
Superfund site.
Dear Ms. Murphy:
The Department of Environmental Protection (Department) has reviewed the amended selected
remedy recommended by the U.S. EPA for the Norwood PCB Superfund site located in
Norwood, Massachusetts. Based on this review, the Department concurs with the amended
selected remedy. The Department deems the amended remedy to be adequately regulated for
purposes of compliance with 310 CMR 40.0000. the Massachusetts Contingency Plan.
Although the major portion of the amended selected remedy, consolidation and capping, will not
reduce the contaminant levels, it will achieve acceptable risk reduction by eliminating the
exposure pathway. The exposure assumptions underlying the amended selected remedy will be
maintained by the development of activity and use limitations. Because contamination is not
being reduced in this remedy, where practicable. EPA's five year review process should include
consideration of a more permanent remedy which may become available in the future.
The remedy as amended for the Norwood PCB Superfund site includes the following components:
Demolition of the Grant Gear building;
Removal and off-site disposal of sediments and sludge from drainage system manholes,
encapsulation of the drainage system;
Consolidation of contaminated soil, and soil and sediment from Meadow Brook, onto a
portion of the Grant Gear property;
• Prrni« o*^
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ROD Amendment
Concurrence
Restoration of Meadow Brook consistent with the Town's flood control project;
Removal of a "hot spot" of contamination below the water table;
Covering of the most heavily contaminated areas of the Grant Gear property with an
asphalt cap and covering of the other property area with clean fill material;
Establishment of activity and use restrictions to maintain the exposure assumptions
underlying the remedy, and to protect the integrity of the remedy;
Periodic ground water monitoring to assess performance and protect! veness of the remedy;
Inspections and maintenance of the cap & cover; and
Continued on-site ground water extraction and treatment.
The remedial action selected in the 1989 Record of Decision consisted of treatment of
contaminated soils via Solvent Extraction, ground water extraction and treatment, dredging and
restoration of the Meadow Brook, implementation of institutional controls, and decontamination
of the Grant Gear Building. This amended selected remedy does not change the groundwater
portion of the original remedy, except that removal of the "hot spot" of contamination will likely
remove a source of downgradient groundwater contamination.
The Department looks forward to working with the Environmental Protection Agency in
implementing the amended selected remedy. If you have any questions or require additional
information, please contact Martin J. Home, Project Manager, at (617) 292-5716,
Very truly yours.
James C. Colman
Assistant Commissioner
Bureau of Waste Site Cleanup
cc: Richard Chalpin, DEP NERO
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ATTACHMENT D
RECORD OF DECISION7 AMENDMENT
NORWOOD PCB SUPERFUND SITE
OFFICIAL PUBLIC HEARING TRANSCRIPT
MARCH 6, 1996
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UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
John F.
Boston,
Region I
Kennedy Federal Building
Massachusetts 02203-0001
NORWOOD PCB SUPERFUND SITE
Proposed Amended Cleanup Plan
PUBLIC MEETING AND HEARING
Norwood Tall Hall
Norwood, Massachusetts
Wednesday,
Public Meeting: 6
Public Hearing: 7
March 6, 1996
:30 p.m. - 7:30 p.m.
;30 p.m. - 8:00 p.m.
Dan Coughlin, Chief, EPA Massachusetts
Superfund Section
Bob Cianciarulo, EPA Remedial Project Manager
Martin Home, Massachusetts Department of
Environmental Protection Project Manager
Major Brian Baker, US Army Corps Engineers
Project Manager
Brian Rohan, EPA Case Attorney
Corrinne Van Alstine, EPA Community Involvement
Coordinator
EATON COURT REPORTING SERVICES
Nancy L Eaton, RPR, RMR, RDR
Guarding the Record Since 1966
Two Oliver Street, Eleventh Floor
Boston, MA 02109
617-338-7333
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1 PROCEEDINGS
2 MR. COUGHLIN: I first have a short
3 statement to make to get into the record, and
4 then we will kick off this evening's public
5 hearing.
6 My name is Dan Coughlin,. I-am Chief of
7 the Massachusetts Superfund Section at the EPA
r*~
8 in Boston. I welcome you to the public hearing
9 on the amended proposed plan for %the Norwood
10 PCB Superfund Cleanup.
11 With me tonight is Bob Cianciarulo, the
12 Remedial Project Manager for the EPA. He's
13 right down front. He's making a presentation
14 tonight. Also we have with us tonight Martin
15 Home from the Mass. DEP and several other
16 folks all representing the agencies as well as
17 the Department of Justice.
18 Now the purpose of tonight's hearing is
19 to give the public an opportunity to comment on
20 the EPA's proposed ammended cleanup strategy.
21 We will be recording your comments, as you can
22 see, this evening, and we will produce a
23 printed transcript which will be part of the
24 administrative records and used by the EPA to
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1 make a final rememdy decision,
2 If you wish to buy a copy of the
3 transcript, you may make arrangements directly
4 with the transcription service, and we have
5 sheets up back available for you to get that
6 address. ,f —
7 As I previously stated, if you wish to
/» *-•• ' -.=—..-
8 make a comment tonight, would you please pick
m
9 up an index card, fill it out, and return it to
10 Corrine back there so that we can make sure
11 that your name and affiliation, et cetera, is
12 entered into the record correctly, and I will
13 call on everyone in the order in which you have
14 submitted the cards.
15 We typically reserve the right to limit
16 peoples' comments to ten minutes. We usually
17 have a'large crowd when we do that, so I'm
18 probably not going to do that but I ask you to
19 be brief. If you think it's going to be a long
20 comment, please try to summarize it, and give
21 it to us in writing, the entire text, and you
22 should submit it to us within the comment
23 period.
24 Hopefully over tne pest hour, you had an
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opportunity to talk to all of us, to look at
our posters and have an appreciation of what we
are proposing to do, and hopefully we addressed
most of your questions.
I should make it clear to people that we
will not be answering questions du-aring the
public hearing portion of this meeting
f tstm • ••- -'•
tonight. We will be, rather, answering those
questions in the responsiveness summary which
will be issued with the proposed amended
cleanup plan or the ammended record decision at
a later date, but all questions and comments
will be addressed in that order.
In addition to tonight's hearing, you
may also submit written comments to the
agency. You should do so by the end of the
comment period, which ends on March 22, 1996.
The address for submitting those comments is in
the proposed plans which I think copies are
available up back. I think perhaps you all
have copies, but if you don't, you can get them
up back, and I think there's also an E-mail
address up there, too.
Finally let me remind you that there are
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1 copies of the administrative record at the
2 Morrill Memorial Library in Norwood and also
3 at the EPA's Record Center in Boston and all
4 are welcome to review the materials at either
5 of those spots at your convenience during the
6 normal business hours. -,
7 I guess we did leave one thing out.
f**~
8 Before we get into the comments, Bob will give
9 you a very quick overview of the ^minutes of the
10 proposed plans, and then I will start taking
11 comments. Any questions on how we are going to
12 proceed?
13 If not, Bob, why don't you do your
14 talk. Let me say thank you for coming. It's
15 not a great night to be out, and I appreciate
16 having you here tonight.
17 MR. CIANCIARULO: Thank you, Dan. I
18 want to give you a quick overview of the
19 proposed amendment. Hopefully you all had
20 a chance to look at the plan that was mailed
21 to everybody on the mailing list for this
22 site.
23 For those of you not familiar with the
24 cleanup, the project is basically divided into
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three major phases: One, the cleanup of ground
water underlying the site; the cleanup of the
Grant Gear Building, and the major part of the
cleanup/ the cleanup of the soil and the
sediments at the site. .
If you recall back in August of 1995,
EPA published a facts sheet, and we had two
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public meetings to basically get the public's
feedback on an idea of the amended cleanup plan
which involved capping of the soils as a major
component versus the treatment of the soils,
which was originally selected as a remedy in
1989 .
This current proposed amended cleanup
plan basically embodies that same approach we
presented to you in August. In general, this
plan calls for the demolition of the Grant Gear
Building; the consolidation of contaminated
soil from the Grant Gear and adjacent
properties and soil sentiments from Meadow
Brook onto a portion of the Grant Gear
property, the removal of a hot spot of organic
contamination located below the water table in
the Western portion of the Grant Gear property,
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1 then covering of the most heavily contaminated
2 areas of the Grant Gear property with an
3 asphalt cap, and covering other less
4 contaminated areas with clean fill.
5 The plan would also call for regular
6 • inspections, monitoring and repair-ing, if
7 necessary, the cap in the regular ground water
f- **>* • -*- --
8 monitoring and also calls for continued ground
9 water extraction and treatment.
10 The ground water treatment plant at the
11 site was completed in early 1996 -- late 1995,
12 early 1996. It is currently in operation
13 extracting and treating gro-und water under the
14 site.
15 The amended plan also does change some
16 cleanup levels at the site. These changes were
17 made based on risk assessment methods and other
18 information which basically has been improved
19 and refined since those activities were done in
20 1989 when the original risk assessment was done.
21 However, the cleanup level for
22 sentiments in Meadow Brook has not changed,
23 and, consequently, the general cleanup level
24 relative to Meadow Brook itself remains
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consistent with the -- remains unchanged from
the 1989 plan.
One of the outcomes of the August 1995
meeting was a strong message from local
residents, a small area north of Meadow Brook,
is that they wanted to take a,^second look at
soil contamination in that area which we had
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slated for excavation.
Based on this feedback, we went and took
an additional round of samples, and also again
as we looked at cleanup levels for the site in
general, we looked at the appropriateness of
the cleanup levels in that area.
Basically based on this new data and the
existing data that was already collected from
that area, it's been determined that the levels
of contamination in this area do not pose an
unacceptable risk to human health and
environment, and, therefore, in this current
proposal, no action will be taken in that
residential area.
EPA is recommending this amended cleanup
plan today. The major component of this which
is consolidation and capping of the contaminated
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1 soils because we believe the plan is protective
2 of human health and environment, technically
3 reliable, easily implementible, can be completed
4 in a relatively short time frame and in a
5 cost-effective manner.
6 EPA no longer believes, ^that-the
7 treatment alternatives selected in 1989,
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8 solvents extraction or the contingency remedy
9 selected in 1989 and the on-site incineration,
10 are implimentable or cost-effective for this
11 site.
12 Furthermore, based upon the fact that
13 that site is to be reused for commercial and/or
14 for industrial purposes in the future -- just
15 as a no-te there is also a note attached to the
16 deed for this property that prohibits the
17 development of this land for residential use,
18 -so that is clearly ruled out. The proposed
19 amended cleanup plan appears to be the choice
20 best suited to the expected future use of this
21 property.
22 Again, I encourage you to refer back
23 to the February 1996 Proposed Amended Cleanup
24 Plan for more information. I'm just trying to
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give you a quick overview here. We look forward
to receiving your input here both tonight and
again in writing prior to the end of the
comment period on March the 22nd. Thank you.
MR. COUGHLIN: okay. I'm going to ask
for comments. We ask that you, come up to the
microphone and speak very clearly into the
,**- — -
microphone, if you would, and state your name
clearly'so once again we are correct in the
record.
And the first comment is from Gary Lee,
selectman from the town of Norwood.
COMMENT ONE: Thank you, Mr. Coughlin,
Mr. Cianciarulo. Xy name is Gary Lee,
selectman from the town of Norwood. Seeing
that this is still a public comment period, 1
have two questions I would liXe addressed in
writing and have you get back to us through
the board, so we can get back to our neighbors
and constituants.
By way of background, first of all, I
think we all remember too well that Senator
Kennedy gave his comments 13 years ago about
the threat of PCBs in the environment.
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1 As far back as '89, we sat down in
2 Boston with the EPA and Senator Kennedy and
3 others at which time they still continued to
4 tell us what a threat the PCBs were in the town
5 of Norwood.
6 One of the problems tha^t people continue
7 to have and the board's having in getting back
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8 to the people is that as far as three, four
9 years ago when I was involved in this board,
10 we were still told of the serious threat PCBs
11 were to the environment, and they were so
12 concerned about it that the only way to treat
13 it was to excavate the soil, treat it and get
14 it off the site.
15 Now there's a change of feeling because
16 of the lack of funds in the EPA Superfund
17 account. You're now telling us, and we are
18 being lead to believe, it's all right just to
19 dig it up, pave it over, cap it, and that's it.
20 I think some people, including myself, are
21 having a tough time understanding that. The
22 message has been that it was such a threat over
23 the years, so why is it okay now to dig it up
24 and to cap it? I think I need that addressed
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1 for my education so that we can get back to the
2 people.
3 The second part of the question I would
4 like to see addressed is, I think as the people
5 take a look at these maps, we are concerned
6 about when you say cap it over,, are we going to
7 be inheriting a large section of concrete cap
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8 or asphalt cap, such as three or four years
9 from now are we going to have an overgrowth
10 cap? Who is going to maintain it? Who is
11 going to keep it? Is that a site that is going
12 to be able to be sold on the subsequent market
13 or is the town of Norwood going to inherit such
14 an eyesore? Again, any written response given
15 about that will help us, and I appreciate your
16 time. Thank you.
17 MR. COUGHLIN: Rose Foley, please.
18 COMMENT TWO: As Mr. Lee has stated, -
19 this has been going on for 13 years, and I do
20 own a piece of property that abuts the Grant
21 Gear works. I'm there every day. I worked
22 there every day.
23 For years off and on, there has been a
24 lot going on but not on a constant basis. For
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1 13 years I would like to know, do you have a
2 figure of how much was spent to date at this
3 time? I, as a taxpayer, would be interested ,in
4 that, and how much is going to be recooped from
5 whatever damage there is from this land? Thank
6 you. .f —
7 MR. COUGHLIN: Thank you. David Wright.
f 0V» ' -*-" -"
8 COMMENT THREE: Thank you, Mr. Coughlin.
9 For the record, my name is David B. Wright.
10 I'm the Director of Project-Development for the
11 firm of Caswell, Eichler & Hill, and my role
12 within the firm is to account for the
13 development of property that is contaminated on
14 behalf of the clients.
15 In the interest of doing that, I would
16 like to sta-te for the record that I support the
17 amended plan as is presented. I think it is
18 still a difficult site to develop. It is a
19 costly site to develop, but this amendment
20 needs to allow some possibility of being
21 developed as long as we can keep it within the
22 market costs that would derive those decisions.
23 We are trying to assess that now in this
24 process, and we came here tonight to hear and
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1 talk about some details of the site. I will
2 have a couple technical comments I would like
3 to make into the record generally now and maybe
4 follow-up with a more detailed letter in a
5 letter form once we have finalized a rough plan
6 for the site. -, -
7 First of all, the slab, as is being
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8 maintained, poses some difficulties for
9 redevelopment because you may not have a
10 building exactly on that site in the same exact
11 location, and that will require some, perhaps,
12 frostwalls or other types of new foundation to
13 be added that have to be put in, perhaps in the
14 middle of that slab in some fashion, or perhaps
15 part of that slab might be removed for things }
16 like utility poles that are very shallow or
17 vaults that are used for plumbing, heating and
18 whatsoever so that it is easy to relocate a
19 piece of equipment where things are stored and
20 also you don't have to dig underground, you
21 know, something of that sort that we don't want
22 to do once the cap is put in place.
23 The Phase IB wells are the new wells,
24 the recovery we-lls, that are being proposed in
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1 the market may also have to be relocated if
2 this project is to go forward, slightly north
3 or slightly south in relation to where -we won't
4 be contaminating the wells in the next
5 building, and we can pump it out for
4 m
6 maintenance and other things and joist as we
7 had for everything involved. That is something
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8 that we would like to enter into the record.
9 We are not quite sure where they should be,
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10 but it would not be too much off from where
11 they are working right now.
12 And finally the excavation of the
13 foundation, if they are going to be done, time
14 is everything in a commercial development. You
15 are .going to have crews working on the site. It
16 would prolxably be best to have the same contractor
17 if possible, excavate that trench for frostwalls,
18 perhaps in building, and we would probably pay
19 that cost or share it or whatever.
20 But basically I think that ought to be
21 done and considered into the scheduling of the
22 development so that we can expeditiously get
23 into the property afterwards, and you can have
24 OSHA-trained people on site, so we can have all
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the contractors monitored unless this seems to
be a logistical problem. And you can do that
as a separate contract with the same contractor,
so we can avoid some of the federal procurement
problems.
It might be an option or we_pay for a
change order that you had issued as paying the
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difference. That is a suggestion we would like
to pose in the record. Whether that can be
done ... But again generally we support this
concept.
It's a pleasure to have a chance to come
up and say good things about an EPA proposal.
In my whole career, I seem to be on the other
side, and it's been very difficult for the EPA
and for us because of the law. I think it is a
fresh, good wind blowing in the right direction.
And perhaps the town will come out with a site
that is developed that will make sense for them,
and the EPA will have a success story here for
their headquarters. And that's the conclusion
of my comment.
MR. COUGHLIN: Thank you. Stan Wasil.
COMMENT FOUR: Stan Wasil. I represent
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1 that district. District 7, and I, like a lot of
2 people here, want to see this thing come to an
3 end, and it's not going to come to an end it we
4 Just keep changing plans all the time. We've
5 done it now for 20 years, and I think now that
6 you've done some cleaning up, I believe -- I
7 feel very positive of this.
8 I think we should now start to knock
9 that building down and hardtop it.
10 Furthermore, I would like to see that brook
11 cleaned up. That's very important because if
12 there is a big flood and it backs up, it backs
13 up into the storm drains and in some cases into
14 the houses, and we don't want PCBs traveling
15 around town. So that's my comment there.
16 I have another comment. I am very much
17 concerned that the town is hurting for new
18 development. That's one. It should be moved
19 along. Also the Stop & Shop right in back
20 there. That is sitting there, too, and it
21 should not be, and I hope it is not going to be
22 sitting around long.
23 So many people want to see that
24 developed. It's a prime piece of property.
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And that's my comment. I want to see this
whole thing start to come to an end. I think
we have overdone it. Thank you.
MR. COUGHLIN: Thank you. Well, those
are all the cards I have. Is there anybody
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else who would like to make a statement for the
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record? We certainly urge you to do so.
& ^^HW * *-**• -~~ '
If not, we would also encourage you to
submit written comments to us. The written
address is on the proposed plan. As I said,
the comment period ends on the 22nd of March,
and if you have any comments, please feel free
to send them in. We will issue our final
decision.
Again, I want to thank you all for
coming out tonight, and 1 appreciate you coming
here in the bad weather. And with that, I think
we will close the public hearing for this site.
As you know, during the first hour, we
invited you up to look at the posters, and we
discussed questions with you. We welcome*you
to stay around and talk with us, if you like.
(The hearing was concluded at 8:00 p.m.)
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1 CERT me ATE
2
3 COMMONWEALTH OF MASSCHUSETTS
4 PLYMOUTH, SS.
5
6 I, Michelle J. Madden, Certified
7 Shorthand Reporter, do hereby certify that the
8 foregoing record. Pages 2 through" 18, is a
9 complete, accurate and true transcription of my
10 stenographic notes taken in the aforementioned
11 matter to the best of my skills and ability.
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. -M J A A
14 "IIUAjttJLULiL ft
15 Michelle TJ. Madden, CSR
16 Certified Shorthand Reporter
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ATTACHMENT E
RECORD OF DECISION AMENDMENT
NORWOOD PCB SUPERFUND SITE
REGIONAL ADMINISTRATOR'S FINDINGS AND WAIVERS
UNDER REGULATIONS OF THE TOXIC SUBSTANCES CONTROL ACT
On or about this 17th day of May, 1996, the Director of the Office of Site Remediation and
Restoration is approving a ROD Amendment for the Norwood PCB Site in Norwood, MA.
Like the remedy selected in the original Record of Decision for the Site, signed September
29, 1989, the amended remedy selected in the ROD Amendment will result in a chemical
waste landfill subject to regulations promulgated under the Toxic Substances Control Act.
However, as set forth in 40 CFR 761.75(c)(4), certain regulatory requirements for chemical
waste landfills may be waived in the discretion of the Regional Administrator if the Regional
Administrator finds that such requirements are not necessary to protect against an
unreasonable risk of injury to health and the environment. This waiver may be exercised
only by the Regional Administrator.
The ROD Amendment waives the following four requirements for chemical waste landfills;
(i) that chemical waste landfills be constructed only in certain low permeability clay
conditions (40 C.F.R. § 761.75 (b)(l)); (ii) that a synthetic membrane liner be used at the
Site (40 C.F.R. § 761.75(b)(2)); (iii) that the bottom of the landfill be 50 feet above the
historic high water table (40 C.F.R. § 761.75(b)(3)), and (iv) that specific leachate
monitoring/collection systems be employed. The reasons for waiving these requirements are
set forth in Section XI of the ROD Amendment, Statutory Determinations.
The factors discussed in Section XI of the ROD Amendment ensure that there will be no
unreasonable risk of injury to health or the environment if the four TSCA chemical waste
landfill requirements specified above are waived. Considering this information, I hereby
exercise the waiver authority contained in the TSCA regulations at 40 C.F.R. § 761.75(c)(4),
with respect to these four requirements.
jst. Patricia Meaney Date
Acting Regional Administrator
U.S. Environmental Protection
Agency - Region I
JFK Federal Building
Boston, MA 02203-2211
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