United States
           Environmental Protection
           Agercy
              Office of
              Emergency and
              Remeaial Resoor.se
EPA/ROD/R01-89/036
September 1989
3EPA
Superfund
Record of Decision
            Wells G&H, MA

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 REPORT DOCUMENTATION
        PAGE
                        1. REPORT MO.
                            EPA/ROD/R01-89/036
                                                                   X f»clpl«nr» «cc«««
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EPA/ROD/R01-89/036   .                .
Wells G&H, MA
First Remedial Action

16.  Abstract  (continued)

contamination, and further evaluating the remaining operable units.  A subsequent ROD
will address the second and  third operable units which include the central area of the
site and the river sediment.  The primary contaminants of concern affecting the soil,
sludge, debris, and ground water are VOCs including PCE and TCE; other organics including
carcinogenic PAHs  (cPAHs), PCBs, and.pesticides; and metals including lead.

 The selected  remedial action for this site includes in situ volatilization, using carbon
adsorption for treatment  of  the extracted vapor, of the 7,400 cubic yards of soil
contaminated with VOCs. only; excavation and onsite incineration of 3,100 cubic yards of
the remaining  contaminated soil and backfilling of the excavated areas; pumping and
treatment of ground water from the five source areas only, using pretreatment for metals
followed by air stripping and vapor phase carbon filtering with either discharge onsite
to the Aberjona.River or  reinjection. into.the aquifer or both; removing and
disposing of 410 cubic yards of sludge and debris; and ground water monitoring.  The
estimated present worth cost for this remedial action is 368,400,000.

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              Declaration of the Record of Decision

Site Name and Location

Wells G & H
Woburn, Massachusetts

Statement of Purpose

This decision document presents the selected remedial action for
the Wells G & H site in Woburn, Massachusetts,  developed in
accordance with the Comprehensive Environmental Response,
Compensation, and Liability Act of 1980 (CERCLA),  as amended by
the Superfund Amendments and Reauthorization- Act of 1986 (SARA) ,
and to the extent practicable,  the National Contingency Plan
(NCP); 40 CFR Part 300 et sea. . 47 Federal Register 31180  (July
16, 1982), as amended.

The  Commonwealth of Massachusetts has concurred with the
selected remedy.

Statement of Basis

This decision is based on the administrative record which  was
developed in accordance with Section 113(k) of CERCLA and  which
as available for public review at the information repositories
located at the Woburn Public Library, Woburn,  Massachusetts, and
at 90 Canal Street, Boston, Massachusetts.  The attached index
identifies the items which comprise the administrative record
upon which the selection of a remedial action is based.

Description of the Selected Remedy

The selected remedial action for the Wells G & H site will be
conducted as the first operable unit and consists of a source
control and management of migration component for the five
properties identified as sources of contamination.  This approach
is appropriate as the source areas of contamination contain the
majority of the; mass of contaminants at the site,  and pose the
principal threat at the site.

The Aberjona River and the central area of the site surrounding
Wells G & H will be addressed as a separate operable unit.

The source control remedial measures include:

     o    Excavation and on-site incineration of approximately
          2100 cubic yards of contaminated soil.  Excavated areas
          will be backfilled.

     o    In situ volatilization of approximately 7400 cubic
          yards of contaminated soil, part of which is located in
          a wetlands area.  In situ treatment will use carbon
          adsorption for vapor treatment.

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The management of migration remedial measures include:

     o    Pumping contaminated groundwater from the overburden
          and/or bedrock aquifers, pretreatment to remove
          suspended solids and metals, and treatment by air
          stripping to remove contaminants.  Carbon adsorption
          will be used to treat emissions from the air stripper.


     o    Groundwater will be treated at separate source area
          treatment plants.

     o    Groundwater will be pumped with the objective of
          achieving Safe Drinking Water Act Maximum Contaminant
          Levels in the aquifer.

Additional measures include:

     o    The removal and disposal of approximately 410 cubic
          yards of sludge and debris.

Declaration

The selected remedy is protective of human health and the
environment, attains Federal and State requirements that are
applicable or relevant and appropriate for this remedial action,
and is cost effective.  This remedy satisfies the statutory
preference for remedies that employ treatment that reduces
toxicity, mobility, or volume as a principal element and utilizes
permanent solutions and alternative treatment technologies to the
maximum extent practicable.

Because this remedy is being conducted as the first operable unit
at the site, it will result in hazardous substances remaining on-
site above health based levels.  A review will be conducted
within five years after commencement of remedial action to ensure
that the remedy continues to provide adequate protection of human
health and the environment.
                      Paul G. Keoiigh  (j
                      Acting Regional Administrator, EPA Region I

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    WELLS G & H




RECORD OF  DECISION

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   WELLS G 6 H




TABLE OF CONTENTS
Cont
I.
II.



III.
IV.

V.



VI.
VII.
VIII



IX.




X.






XI.




ents


A.
B.
C.




A.
B.
C.



A.
B.



A.
B.


A.


B.



A.

B.
C.
Page Nus
SITE NAME, LOCATION AND DESCRIPTION ......
SITE HISTORY 	 ..........
Site Use History . 	 	 	
Response History 	 	
Enforcement History 	 	 	 	
•
COMMUNITY RELATIONS 	
SCOPE AND ROLE OF OPERABLE UNIT OR RESPONSE ACTION

.SITE CHARACTERISTICS 	
Hydrogeologic Setting 	
Groundwater Classification and Use .......
Contamination 	 	 	
SUMMARY OF SITE RISKS 	
DOCUMENTATION OF SIGNIFICANT CHANGES 	
DEVELOPMENT AND SCREENING OF ALTERNATIVES . . '.
Statutory Requirenents/Response Objectives . . .
Technology and Alternative Development and
Screening 	 	 	
DESCRIPTION/SUMMARY OF THE ANALYSIS OF
ALTERNATIVES 	 	
Source Control (SO) Alternatives Analyzed . . .
Management of Migration (MOM) Alternatives
Analyzed ...... 	 	
THE SELECTED REMEDY ... 	
Description of the Selected Remedy ......
1. Remedial Action Objectives/Cleanup Goals. . .
2. . Description of Remedial Components 	
Rationale for Selection 	 .
1. Source Control 	 	
2. Management of Migration . . .... . .
STATUTORY DETERMINATIONS 	 	 	
The Selected Remedy is Protective of Human Health
•and the Environment 	 	
The Selected Remedy Attains ARARs 	
•The Selected Remedial Action is Cost Effective
iber
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1
1
2
5
5

6
7
7
8
1
10
12
15
15

16

18
18

24
29
29
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31
36
36
38
39

39
40
41

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     D.   The Selected Remedy Utilizes Permanent Solutions
          and Alternative  Treatment Technologies or Resource
          Recovery Technologies to the Maximum Extent
          Practicable	    42
     E.   The Selected Remedy Satisfies the Preference for
          Treatment as a Principal Element  	    43

XII.      STATE ROLE	    43

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                      ROD DECISION SUMMARY


I.        SITE NAME/ LOCATION AND DESCRIPTION

     SITE NAME:          Wells G & H

     SITE LOCATION:      Woburn, Massachusetts

     SITE DESCRIPTION:

The Wells G & H Site (Site)  located in east Woburn,  Massachusetts
includes the aquifer and land mass area located within the zone
of contribution of the two municipal drinking water wells known
as Wells G and H.  The Site is bounded by Route 128 to the north,
Route 93 to the east, the Boston and Maine railroad to the west,
and Salen Street to the south.  It is approximately 330 acres
(see Figure 1) ..

Wells G & H are located in the sand and gravel aquifer of
the Aberjona River basin within the Mystic River watershed.  The
area surrounding the wells within the Site boundary is'.
a mixed use area consisting of light industry, commercial
businesses, industrial parks, residences, and recreational
property.  The area surrounding the Site is dominated by
industrial and coror.ercial property to the North, and residential
property to the South.

The Aberjona River, which begins in Reading, Massachusetts, flows
through the Site and eventually reaches the Mystic Lakes in
Winchester.  A substantial wetland area associated with the
Aberjona River flood plain is located on either side of the River
within the Site boundary.  An additional description of the Site
can be found in the Supplemental Remedial Investigation Report at
page 1.


II.       SITE HISTORY AND ENFORCEMENT ACTIVITIES

     A.   Site Use History

Wells G & H were developed by the City of Woburn in 1964 and
1967, respectively.  The wells, screened in the Aberjona River
aquifer and capable of supplying two million gallons of water per
day, were initially intended to supplement previously existing
supplies.  Local officials estimate that 27-28% of the
community's water supply was provided by Wells G & H.  The
remainder of the water supply was provided by seven wells located
near Horn Pond south of Salem Street.  These wells are located in
a different aquifer from Wells G & H and are not affected by
contamination present in the study .area.  Woburn currently uses
the Horn Pond water as its major water supply.

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In 1979, the Massachusetts Department of Environmental Protection
(DEP),  formerly the Massachusetts Department of Environmental
Quality Engineering, prompted by a local disposal problem,  tested
the water supply  from Wells G 4 H.  Several chlorinated volatile
organic compounds, including 1,1,1-trichloroethane (1,1,1-TCA),
trans-1.2-Dichloroethenef tetrachloroethene (PCE), and
trichloroethene (TCE), were detected at concentrations ranging
from  1 to 400 parts per billion (ppb) .  As a result of this
sampling the wells were immediately shut down.  Woburn then
revived an existing agreement with the Metropolitan District
Commission (now the Massachusetts Water Resources Authority or
MWRA) to compensate for the lost water supply.  The MWRA
continues to supplement Woburn's water supply.

As a  result of the contamination at Wells G & H, and disposal
problems discovered at the Industriplex Superfund Site just north
of Wells G & H, the United States Environmental Protection Agency
(EPA, or the Agency) conducted a hydrogeologic investigation and
groundwater quality evaluation of a ten square mile portion of
East  and North Woburn.  This investigation was conducted in 1981.
The purpose of the investigation" was to determine the extent and ?"
degree of contamination in the aquifer, and to identify the
sources of contamination.  Based on the direction of groundwater
flow, the areal extent of groundvater contamination, and property
inspections, EPA  identified the source areas for contamination at
Wells G & H to be within a one square mile area surrounding the
wells on either side of the River within the Site boundary.

The following five facilities have been identified as sources  of
contamination - W. R. Grace & Company, Unifirst Corporation, New
England Plastics, Wildwood Conservation Corporation (also
referred to as the Beatrice property), and Olympia Nominee Trust
(see  Figure 2).  Wells G & H, located in the center of these  '
properties, were  listed as a Superfund Site on the National
Priorities List (NPL) on December 21, 1982.

      B.   Response History

EPA and various property owners have conducted numerous studies
to determine the nature and extent of contamination at the Site.
The following is a brief chronological description and summary of
those studies.  Further explanation can be found in the reports
that  are summarized below.                                  — —_

1983

EPA completed a report entitled Remedial Action Master Plan for
East  Woburn.  Its purpose was to identify the scope of the
sequence of activities necessary to identify and implement
remedial action at the Site.

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 EPA  issued three Administrative Orders pursuant to Section 3013
 of the  Resource Conservation and Recovery Act (RCRA).  These
 Orders  required W. R. Grace & Company, Beatrice Foods Inc., and
 the  Unifirst  Corporation to investigate the nature and extent of
 contamination on their properties.  These investigations have all
 been completed and the results have been forwarded to EPA. 1

'l985~

 The  United States Geological Survey (USGS), under an agreement
 with the  EPA,  conducted a 30-day aquifer test to determine the
 zone of contribution of Wells G & H .  The description of the
 study and the results can be found in the report entitled:  Area
 of Influence  and Zone of Contribution to Superfund Site Wells G &
 H. Woburn.  Massachusetts. 1987.

 EPA  issued an Order to the Wildwood Conservation Corporation
 (Beatrice property) pursuant to Section 106 of CERCLA.  This
 Order required the construction of a fence at the property
 boundaries to limit contact with soil contamination discovered
 during  previous investigations.  In addition, the Order required
 the  presence  of a security guard at the Site.  Soil data results^"
 used to support this action can be found in the Order itself.

 An evaluation of the wetlands area within the Site boundary was
 conducted by  EPA to determine the extent and type of wetlands
 that exist at the Site.  The study also evaluated whether there
 were any  adverse impacts to the wetlands as a result of
 contamination at the Site.  Further detail of the study can be
 found in  the  report entitled:  Wells G & H Wetlands Assessment.
 Final Report.  March 25, 1986, prepared by Alliance Technologies
 Corp.                                 .
          GeoEnvironmental Consultants, Inc., W.R.. Grace & Co..
          Cryovac Division Woburn Plant. Field Investigations  and
          Remedial Measures. Phases I-III, 1983; and W.R. Grace &
          Co.. Cryovac  Division. Woburn Plant Field Investi-
          gations and Remedial Measures. Phase VT-Field Descrip-
          tions, 1985;  Woodward-Clyde Consultants. Geohydrolocrv
          and Groundwater Contamination. J.J. Riley Site, Woburn.
          Massachusetts.1984; and Phase II Groundwater Investi-
          gation. J.J.  Riley Site. Woburn. Massachusetts. 1984;
          Environmental Research & Technology, Inc., Assessment
          of Ground Water Contamination Potential at Interstate  •
          Uniform Services Corp.. Woburn. MA, 1983; Summary of
          Monitoring Program. Unifirst Corporation. Woburn.MA.
          1984; and Evaluation and Recommendations For Alter-
          natives Concerning Additional Investigation of
          Groundwater Contamination. 1984.

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1986

EPA completed a Remedial Investigation which included the
installation of groundwater monitoring wells, the collection of
samples from the groundwater and surface waters of the Aberjona
River, and oversight of work done under the above orders at the
Site.  The report  is entitled:  Wells G & H Site. Remedial
Investigation Report. Part I. Woburn. Massachusetts.  Vol. I-IV,
October 17, 1986,  prepared by NUS Corporation.

EPA completed a report as an addendum to the RI Part I that
focused on the nature and extent of soil contamination at the
Site through a review and validation of data previously
collected.  The report is entitled:  Wells G & H Remedial
Investigation. Part II, November 1986, prepared by Alliance Corp.
EPA issued an Administrative Order to Unifirst Corporation,
pursuant to Section  106 of CERCLA.  This Order required Unifirst
to install monitoring wells on its property to evaluate the      ?"
extent of, and to remove, all pure tetrachloroethene
contamination found  under its property.  The results of this
investigation can be found in the report entitled:  Summary  of
Investigation. Unifirst Site, Woburn.. Massachusetts^ February
1983, prepared by ERT.  Following this study, .Unifirst installed
several multi-port bedrock wells downgradient of their 'property
in order to collect  groundwater samples.  The results of this
sampling effort are  incorporated in the report entitled:  Final
Supplemental Remedial Investigation .for Feasibility Study. Wells
G & H Site. December 1988, prepared by Ebasco Services, Inc.

Under two separate Orders issued by EPA in 1986 and 1987 pursuant
to Section 106 of CERCLA, Olyrnpia Nominee Trust removed drums and
debris from the western half of its property.  The types and
levels of contamination are summarized in the individual orders.

1988

EPA completed an Endangerment Assessment which examined the
current and future potential risks from exposure to
contamination at the Site if no remedial action were to occur.
Further details of this study can be found in a report entitled:
Endanqerment Assessment for the Wells G & H Site. Woburn.
Massachusetts, December 1988, prepared by Clement Associates,
Inc.

EPA completed a supplemental Remedial Investigation which
involved gathering additional soil information at several source
areas, installing additional monitoring wells and collecting
samples, updating groundwater information from existing wells,

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and collecting sediment and surface water samples from the
Aberjona River.  The results of the study can be found in the
report entitled:  Final Supplemental Remedial Investigation for
Feasibility Study. Wells G & H Site. Woburn.  Massachusetts.
December 1938, prepared by Ebasco Services Inc.

-1989_

EPA conducted soil sampling at the W. R. Grace *nd Olympia
Nominee Trust properties in July and August,  1989.  Soil borings
originally sampled and reported in the Final  Supplemental
Remedial Investigation for Feasibility Study. December 1988, were
repeated in order to confirm earlier results.  This sampling was
initiated in response to concerns regarding the laboratory that
analyzed the original sar.ples.  The results of the soil sampling
conducted in July and August confirm the earlier results.
Further details can be found.in the report entitled:  Soil
Sampling at the Wells G & H Superfund Site (W.R. Grace and
Olynpia Nominee Trust). July/August 1989, EPA. .

In addition to the above studies done by or for EPA, the DEP has ?"
been involved in investigating activities at properties that
border the Site.  Property owned by the Whitney Barrel Company,
Olyripia Nominee Trust, and Keyerhauser are currently under
investigation by DEP due to groundwater contamination found at
these sites.

     C.   Enforcement History

On April 20, 1988, EPA notified eight potentially responsible
parties (PRPs) of their potential liability for response actions
at the Site.  On February 3, 1989, EPA notified an additional 14
parties.  In addition, PRPs have received numerous Administrative
Orders related to response activities at the Site.  These  Orders
were summarized in section II B above.  Discussions with PRPs
regarding ROD implementation will not commence until issuance of
this ROD completes the remedy selection process for this operable
unit.

The PRPs have been active in the remedy selection process  for the
Site.  Extensive legal and technical comments were submitted by
the PRPs during the public comment period.  These comments are
included in the Administrative Record.  EPA responses to the
comments are included in the Responsiveness Summary  (Appendix A).


III.      COMMUNITY RELATIONS

There has been a great deal of community concern  and  involvement
associated with this Site.  EPA has kept the community  and other
interested parties apprised of Site activities through

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 informational meetings,  fact sheets,  press releases and public
 meetings.

 In April 1986, EPA released a community  relations plan which
 outlined a program to address community  concerns and keep
 citizens informed and involved in activities during remedial
"activities.  In November 1986, EPA held  a public meeting to
 present the results of the Remedial Investigation, Part I.
 In May 1988,  EPA held an informational ceeting to explain the
 Feasibility Study process and possible alternatives for
 remediation of the Site.

 The Agency published a notice and brief  analysis of the
 Proposed Plan in "The Daily Tines Chronicle" on February 3,
 1989,  and made the plan available to the public at the
 Thompson Public'Library in Woburn and at the headquarters of "For
 A Cleaner Environment,"  also located in  Woburn.

 On February 9, 1989, EPA held an  informational meeting to
 discuss the results of the Supplemental  Remedial Investigation,  .,
 the cleanup alternatives presented in the Feasibility Study, and
 to present the Agency's Proposed  Plan.   During this meeting the
 Agency also answered questions from the  public.

 From February 10, 1989 to March 21, 1989, the Agency held a forty
 day public comr.ent period to accept comments on the alternatives
 presented in the Feasibility Study, the  Proposed Plan, and
 documents  previously released to  the public.  On February 27,
 1989,  the  Agency held a public meeting to accept oral comments.
 A transcript of this meeting, a summary  of the comments received
 during the public comment period,  and the Agency's responses to
 the comments are included in the  Responsiveness Summary (Appendix
 A).


 IV.        SCOPE AND ROLE OF OPERABLE UNIT OR RESPONSE ACTION

 The 330 acre Wells G & H Site consists of the unsaturated soils
 and aquifer associated with the five source areas of
 contamination and the central area surrounding Wells G & H, the
 Aberjona River, and associated wetlands  (Figure 2).  The remedy
 associated with this ROD will be  conducted as the first operable
 unit and addresses remediation of contaminated groundwater, soil,
 and sludge found at the five properties  identified as sources  of
 contamination at the Site.  The remedy also calls for a study  of
 the central aquifer area to determine the most effective way of
 addressing contamination in the central  area.  EPA will address
 the cleanup of the central area of the Site, as well as the
 contamination found in the Aberjona River sediments, as a
 separate operable unit.

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The overall response objective for the Site is  to  restore  the
entire aquifer to drinking water standards,  i.e.,  the  aquifer  in
the vicinity of both the source areas and the central  area.  The
Agency believes, however, that the source areas of contamination
contain the majority of the mass of contaminants at the  site,  and
pose the principal threat at the Site.  It is,  therefore,
appropriate to address the sources of contamination to the
aquifer first, while continuing to evaluate other  problems at  the
Site.  This strategy will reduce the infiltration  of volatile
organics to the aquifer from the soil at the source areas,  and
will prevent further migration of contamination towards  the
central aquifer and off-site from the source areas. Therefore,
cleanup as operable units is appropriate, and the  remedial action
associated with this operable unit is consistent with  the  overall
response objective for the Site.


V.        .SITE CHARACTERISTICS

A complete discussion of Site characteristics can  be found in  the
Remedial Investigations, Parts I,'II, and the Supplemental RI     •
Report.  Chapter 1 of the Feasibility Study also contains  an
overview of the Remedial Investigations.  The significant
findings are summarized below.

     A.  Hydrogeologic setting

Groundwater in the study area occurs in two principal  formations,
the bedrock underlying the entire area, and the stratified drift
which overlies bedrock in most of the study area.   The two
formations are separated in a few areas by a thin  deposit  of
glacial till.  The glacial till is exposed at land surface in  the
northeastern and southwestern parts of the study area.  A  peat
deposit of variable thickness and extent overlies  the  stratified
drift throughout most of the wetlands area.

The stratified drift is composed primarily of sand and
gravel and yields the largest quantities of water  in the area.
Wells G & H are located in the stratified drift.  Stratified
drift deposits of up to 140 feet thick are found directly
overlying the till and bedrock.

Recharge to stratified drift, till, and bedrock is from
precipitation and periodically from the Aberjona River.   The
general direction of groundwater flow is from upland areas east,
west, and north of the Aberjona River valley southward.   The
Aberjona River and its wetlands are a seasonal  discharge area.
Groundwater from the aquifer flows upward discharging into these
surface water bodies.

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                                 8


 The Aberjona River,  which has  its headwaters in Reading and
 empties into the Mystic Lakes  in Winchester, flows north to south
 through the site.   Relatively  small amounts of grouhdwater enter
 the Aberjona River Valley from upgradient areas north of
 Interstate 95,  and exit the  narrow southern end of the valley
 south 'of Salem  Street.   A 38 acre wetland area exists on both
_sides  of the Aberjona River  in the center of the Site (see Figure
 3).  These wetlands are located  within the 100-year floodplain of
 the Aberjona Rivex.

 River  sediments are composed of  silt and sand ranging in
 thickness from  0.5 to 2 feet and are underlain by peat averaging
 up  to  7 feet in. thickness.   The  peat, a relatively loose nearly
 saturated material,  permits  groundwater discharge to the river.

 Water  within the bedrock occurs  in fractures.and joints.  Where
 fractures and joints .are nur.erous, open, and well-connected,
 significant quantities  of water  may be obtained.  The depth to
 bedrock from land surface ranges from zero, where bedrock is
 located on the  surface  at several locations along the eastern and
 western sides of the valley, to  approximately 140 feet in the    '
 south  central area of the valley.  The primary axis of the
 bedrock valley  is north-northwest/south-southeast, parallel to
 the orientation of the  Aberjona  River.

 The pulping of  Wells G  & H and the Riley Tannery production well
 (Piley well)  have influenced the movement of groundwater for much
 of  the sites history. 2   Each generated a cone of influence which
 intercepted groundwater.  When all wells were pumping, a
 groundwater divide was  created between Wells G & H and the Riley
 well.   This divide separated the groundwater flowing towards
 Wells  G & H and. the  groundwater  flowing towards the Riley well.
 This divide was located in the southwestern part of the Site.
 Further information  is  presented in the USGS aquifer test.


     B.    Groundwater Classification and Us*

 The  Aberjona River aquifer,  beneath and downgradient of the Site,
 is  classified as Class  I by  the  Commonwealth of Massachusetts
 (314 CKR §6.03).   Class I aquifers are those groundwaters that
 are  designated  as a  source of  potable water supply.

Under  the EPA Groundwater Classification System  [EPA Groundwater
 Protection Strategy  (GWPS),  Office of Groundwater Protection,
August 1984], this aquifer is  classified as Class II B.  Class II
 aquifers are aquifers that are currently used or potentially
 available for drinking  water or  other beneficial uses.  Class II
          The  tannery ceased operations in January 1989.

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  A aquifers are those that  are  currently used, and Class II B
  aquifers are potential  drinking water sources.  The GWPS
  establishes groundwater protection goals based on the "highest
  beneficial uses to which groundwater having significant water
  resources value can presently  or potentially be put."  Guidelines
  for protection of aquifers are based on characteristics of
-vulnerability, use, and value.

  The Aberjona River aquifer,  in the vicinity of Wells G & H, can
  yield up to 2 million gallons  of water a day.  Although it was
  used in the 1960's and  70's as a supplemental water supply for
  Woburn, it is unusable  for drinking water purposes in its present
  condition.

       C.   Contamination

            1.   Groundwater

  Volatile organic compounds (VOCs) are the primary contaminants in
  the groundwater at the  Site.   Groundwater contamination has been
  found in the overburden and bedrock aquifers at the W.R. Grace & ,
'  Company property,  the Unifirst Corporation property, the Wildwood-
  Conservation Corporation property, the New England Plastics
  Company property and the central area of the Site.  In addition,
  groundwater contamination  has  been found in the overburden
  aquifer at the Olynpia  Nominee Trust property,

  Plumes of VOCs in the overburden and bedrock .groundwater extend
  from the W.R. Grace and Unifirst Corporation properties to Wells
  G & H.   The W.R.  Grace  plume consists primarily of chlorinated
  solvents and is characterized  by a high percentage of TCE and
  1,2-Dichloroethene (DCE).   Other contaminants include PCE and
  vinyl chloride.  The Unifirst  Corporation plume is characterized
  by a predominance of PCE.   Secondary constituents are 1,1,1-TCA,
  and smaller amounts of  TCE and DCE.

  In addition, groundwater contamination was discovered beneath the
  Wildwood Conservation Corporation, the Olympia Nominee Trust and
  New England Plastics Corporation properties.  The contamination
  at the Wildwood Corporation property consists primarily of TCE
  detected at a number of wells, with 1,1,1-TCA, DCE, and PCE
  detected at a few locations.   At the Olympia property TCE and
  xylene were detected in the overburden.  Concentrations of PCE,
  TCE,  1,1,1-TCA and DCE  were found in both bedrock and overburden
  wells at the New England Plastics property.

            2.   Soil

  Soil investigations were performed on several properties
  throughout the Site. VOCs are the primary contaminants in the
  soil at the Site and were  found at various levels on the Wildwood

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                                10


Corporation, Olyr.pia Nominee Trust, W.R. Grace & Co.,  New England.
Plastics and Unifirst  Corporation properties.  Some soil
contamination was  found  in a wetlands area on the Wildwood
property.

Other contaminants found in soil  include PCBs, chlordane (a
pesticide), phthalates,  and PAHs.  These contaminants were found
dispersed throughout the Wildwood property. PAHs were found in
one location on the Olympia property.  PCE and phthalates were
found in a small area  on the New  England Plastics property.
In addition, small quantities of  sludge, contaminated with lead,
VOCs, PAHs, pesticides,  and assorted debris, was also found on
the Wildwood property.

          3.   Sediment/River

Sediment sar.ples tak:en from the Aberjona River, and along the
banks of the Aberjona  River in the wetlands, revealed
contamination including  PAHS and  metals such as arsenic, mercury,
and chromium.  Surface water samples revealed low levels of VOCs.f-

          4.   Air.

Air monitoring, conducted during  all site investigations, did not
reveal any readings above background at the breathing zone.


VI.       SUMMARY  OP SITE RISKS

An Endangerment Assessment  (EA) was performed to estimate the
probability and magnitude of potential adverse human health and
environmental effects  from exposure to contaminants at the Site.
Thirty-five contaminants of concern, listed in Table 1, were
selected for evaluation  in the EA.  These contaminants constitute
a representative subset  of the total number of contaminants
identified at the  Site during the Remedial Investigation.  The
thirty-five contaminants were selected to represent potential on-
site hazards based on  their toxicity, concentration, frequency of
detection, and mobility  and persistence in the environment.

Potential human health effects associated with the contaminants
of concern in groundwater, surface and subsurface soils, surface
water, sediments,  sludge, and air were estimated quantitatively
through the development  of several hypothetical exposure
scenarios.  The incremental lifetime cancer risks and the
potential for noncarcinogenic adverse health effects were
estimated for various  exposure scenarios.  Exposure scenarios
were developed to  reflect the potential for exposure to hazardous
substances based on the  characteristic uses and location of the
Site.  Factors of  special note that are reflected in the EA are
that the Site is a mixed use area which includes residences,
commercial businesses  and light industry, the aquifer was used at

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                                11


one time as a municipal drinking water supply,  the aquifer is
currently used to a limited degree for industrial process water,
and that the Wildwood property is currently fenced and guarded.

For risk assessment purposes, individual contaminants are
separated into categories of chemical toxicity depending on
whether or not they exhibit carcinogenic effects.  Carcinogenic
risks are derived by multiplying the potency factor for a
specific carcinogen, developed by EPA's Carcinogen Assessment
Group, by its chronic daily intake (GDI).  GDIs are the amount of
a substance taken into the body per unit body weight per unit
time.  The product results in a number such as IxlO"4'  This
number represents the probability that one out of ten thousand
people will contract cancer as a result of exposure to a
potential carcinogen.  This nunber is then used by EPA to
evaluate the risk associated with exposure to a contaminant under
a particular exposure scenario.

Noncarcinogenic health risks posed by contaminants at a Superfund
site are expressed via a hazard index.  The hazard index is a
term used to describe the- ratio between the GDI and a relevant   p
contaminant specific noncarcinogenic guideline such as the
reference dose (RfD).  This ratio (CDIrRfD) provides a measure of
the potential for noncarcinogenic health effects to occur.  When
the hazard index is less than one, then adverse health effects
from exposures attributed to the chemical(s) at the site are not
anticipated.

A separate evaluation of risk was performed on each of the five
source areas at the Site and the central area including the
Aberjona River.  This evaluation included selecting chemicals of
potential concern on an area by area basis based on the presence
of the chemical in background samples, the extent and magnitude
of chemical contamination, chemical and physical properties
affecting fate and transport of the chemical in the environment,
and chemical toxicity.  In addition, possible exposures to human
and environmental populations were also examined.  Table 2
summarizes the risks, by media, at the five source areas and the
central area.

The greatest potential risks identified at the Site are
attributed to future ingestion of contaminated groundwater, the
inhalation of volatiles while showering, and exposure to surface
soils through dermal contact and incidental ingestion.  Other
potential exposures include the inhalation of dust generated by
site activities, the inhalation of volatiles released from the
groundwater during industrial processes, and exposure to surface
water and sediments from the Aberjona River through ingestion or
dermal contact.

A comparison was made of all pathways of exposure for each of the
contaminants of concern at each property at the Site to determine

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                                12


 which chemicals presented the greatest risks.  It was found that
 the saroe group of chemicals posed a risk at most, if not all, of
 the properties.  The chemicals contributing the greatest
 carcinogenic risk under the ground-water exposure scenarios are
 vinyl chloride, 1,1-Di.chloroethene, TCE,  PCE,  1,1-Dichloroethane,
 chloroform,  and 1,2-Dichloroethane.  The chemicals contributing
 the greatest carcinogenic risk under the surface soil exposure
•scenarios are chlordane, chloroform,  4,4'-DDT, carcinogenic PAHs,
 PCBs,  TCE,  and PCE.  The hazard index for noncarcinogenic risks
 exceeded one in surface soils for trans.-!, 2-Dichloroethene,
 1,1,1-TCA and lead.  The hazard index exceeded one in groundwater
 for trans^l.2-Dichloroethener PCE and 1,1,1-TCA.

 The results  of the EA were used to assist EPA  in developing
 response objectives for the Site and in setting cleanup goals for
 these chemicals which posed, the greatest threat to human health
 and the environment.  The response objectives, as well as the
 cleanup goals selected for the soil and groundwater contaminants
 listed above, are further discussed under Section X.  A detailed
 discussion of Site risks can be found in the EA.
 VII.       DOCUMENTATION OF SIGNIFICANT CHANGES

 EPA published a Proposed Plan for remediation of  the  Site on
 February 9,  1989.  The two-part cleanup plan consisted of a
 source control remedy and a management of migration remedy.  The
 source control portion of the plan included alternatives for the
 treatment of contaminated soils.  The preferred source control
 alternative  consisted of the treatment of soils contaminated with
 volatiles using in-situ volatilization, and the incineration of
 soils contaminated with PCBs, PAHs,  and pesticides.   The
 management of migration portion of the plan covered alternatives
 for the treatment of contaminated groundwater.  The preferred
 management of migration alternative included the  extraction of
 groundwater  from the five source areas of contamination and the
 center of the Site.  The groundwater would be pumped  to a central
 treatment facility where it would be pretreated for metals, and
 then sent through an'air stripper and vapor phase carbon filter
 for removal  of volatile organic contamination.

 The remedy selected in this POD adopts the same source control
 component that was presented in the Proposed Plan.  For the
 management of migration component, however, this  ROD  contains the
 following changes:

      o    Extraction of groundwater will still  occur  on all five
           source areas of contamination as stated in  the
           preferred alternative section of the  Proposed Plan, but
           the groundwater will be treated at individual treatment
           plants as opposed to one central treatment  plant.

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                                13


     o    Groundwater will not be extracted from the  central  area
          aquifer at this tine.  Father,  a study of the  central
          area will be conducted to select the best remedial
          alternative for addressing contaminated groundwater in
          that area.  The objectives of the study are delineated
          in Section X of this ROD.  The study will be developed
          and implemented during the predesign phase  of  the
          remedy selected under this ROD.  As discussed  in
          Section IV of this ROD, the central area will  be
          addressed as a separate operable unit and the  remedy
          will be selected in a separate decision document.

     o    It is no longer necessary for the Riley Tannery
          production well to be pumped in an effort to maintain
          the southern boundary of the Site as was stated in  the
          Proposed Plan.

     o    Treatment technologies other than air stripping may be
          considered for inpleroentation of the groundwater remedy
          if they can be demonstrated to be equally or more
          effective.

Each of the changes listed above will be discussed in turn in the
remainder of this section.

EPA received strong opposition from both the public and  the PRPs
to a central treatment facility.  Many of the comments received
concern the fact that construction of a single central treatment
facility would require that pipes be placed in a wetlands area,
and that contaminated water be moved across uncontaminated areas
of the Site.  In addition, some commenters felt that  a single
treatment plant would rule out the possibility of using  different
treatment options to address unique chemical combinations and
concentrations found at individual source areas.  These  comments
are further described in the attached Responsiveness  Summary
(Appendix A).

The Agency believes that the comments regarding these issues
raise valid concerns, and that the overall protectiveness and
effectiveness of the remedy will not be compromised by using
individual treatment plants at the source areas of contamination.
Therefore, in response to the public's comments, the  Agency has
decided to deviate from the originally preferred alternative in
favor of a remedy which employs individual source area treatment
plants.

In addition, many individuals raised issues during the public
comment period which challenged the effectiveness and
protectiveness of extracting groundwater from the central area.
While it is the Agency's intent to address the contamination in
the central area aquifer, EPA does see merit in further
evaluating options for remediating this area while implementing

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                                14


 the source area cleanup.  Therefore,  the Agency has decided to
 refrain from making a decision on the remedy  for the central area
 until the concerns raised during  the  comment  period can be more
 fully evaluated.

 As mentioned above, the Agency has decided to address the central
 area as a separate operable unit.  EPA believes that this
-approach is environmentally sound and logical for several
 reasons: the majority of contamination at the site is associated
 with the source areas; cleanup of these areas will prevent
 further migration of contaminants into the central area, and
 further migration of contaminants off-site from the source areas;
 and further evaluation of the central area will ensure that the
 eventual central area cleanup will be protective and effective.

 Since completion of the Feasibility Study for this Site the Riley
 Tannery production well has ceased operation.  The Proposed Plan
 called for pumping of the Riley well  in conjunction with the
 central aquifer extraction system. This measure was intended to
 create a groundwater barrier that would prevent water from
 outside of the southern hydraulic boundary of the Site from being
 drawn into the central area.  As  the  cleanup  of the central area f-
 will be addressed as a separate operable unit, the maintenance of
 the Southern hydraulic boundary is no longer  critical.
 Accordingly, the selected remedy  provides simply that pump rates
 and well locations be determined  that will capture the
 contamination associated with each individual property, and
 reduce the capture of contamination from other properties.  The
 exact pumping rates and well locations to best accomplish this
 objective will be determined during remedial  design.

 During the public comment period, the Agency  considered comments
 regarding the engineering advantages  of employing individualized
 treatment processes at the source areas.  EPA concurs that
 technologies in addition to air stripping may be appropriate for
 use at certain areas.  Therefore, during remedial design EPA will
 consider proposals for the use of alternative treatment
 technologies which were evaluated in  the Feasibility Study for
 groundwater remediation.  It must be  demonstrated that the
 proposed technology is equally or more effective than air
 stripping.  In addition, treatment technologies other than those
 evaluated in the Feasibility Study may be considered by EPA
 subject to public comment.

 As a result of the changes outlined above the Agency now supports
 a  different management of migration (MOM) alternative than was
 presented in the Proposed Plan.  The  preferred MOM alternative
 has changed from MOM-4  (Pump and  Treat Source Areas and the
 Central Area) to MOM-2.  (Pump and  Treat Source Areas).  The MOM-2
 alternative will be supplemented  by a study  of the central area
 to determine the most appropriate method of  addressing
 groundwater contamination in that area, as well as an

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                                15


investigation of contamination in the Aberjona River.   The  reader
is referred to Section IX for an analysis of the alternatives
that were presented in the Feasibility Study,  and to Section X
for the rationale for selection of the selected alternative.

The Agency does not believe that it is necessary to reissue the
Proposed Plan for. further comment and provides the following
rationale: because the Feasibility Study (FS)  and the Proposed
Plan discussed the alternatives of using separate treatment
facilities at the source areas, and of proceeding with source
area treatment only, the public already had an opportunity  to
comment on these alternatives; the suggested changes,  including
the potential use of an alternative groundwater treatment
technology which was evaluated in the FS, do not alter the
overall remedial objectives for the Site (presented in Section
VIII) ; and the eventual proposal for reraediation of the central
area, as well as any proposal for use of a groundwater treatment
technology that was not evaluated in the FS, will be subject to
public comment.


VIII.     DEVELOPMENT AND SCREENING OF ALTERNATIVES

     A.   Statutory Retirements/Response Objectives

Prior to the passage of the Superfund Amendments and
Reauthorization Act of 1986 (SARA), actions taken in response  to
releases of hazardous substances were conducted in accordance
with CERCLA .as enacted in 1980 and the revised National Oil and
Hazardous Substances Pollution Contingency Plan (NCP), 40 CFR
Part 300, dated November 20, 1985.  Although EPA proposed
revisions on December 21, 1988 to the NCP to reflect SARA,  until
those proposed revisions are finalized, the procedures and
standards for responding to releases of hazardous substances,
pollutants and contaminants shall be in accordance with Section
121 of CERCLA, and to the maximum extent practicable,  the current
NCP.

Under its legal authorities, EPA's primary responsibility at
Superfund sites is to undertake remedial actions that are
protective of human health and the environment.  In addition,
Section 121 of CERCLA establishes several other statutory
requirements and preferences, including: a requirement that EPA's
remedial action, when complete, must comply with applicable or
relevant and appropriate requirements  (ARARs)  established under
federal and state environmental laws unless a statutory waiver is
warranted and justified in the ROD; a requirement that EPA select
a remedial action that is cost effective and that uses permanent
solutions and alternative treatment technologies or resource
recovery technologies to the maximum extent practicable; and a
statutory preference for remedies that permanently and
significantly reduce the volume, toxicity or mobility of

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                                16


hazardous substances over remedies that do not achieve such
results  through treatment.   Response alternatives were developed
to be  consistent with these Congressional mandates.

A number of potential exposure  pathways were analyzed for risk
and threats to public health and  the environment in the
Endangerment Assessment and the Wetlands Assessment.  Guidelines
were used to assist EPA in the  development of response actions
including the Superfund Public  Health Evaluation Manual (EPA,
1986)  and the Draft Guidance on Remedial Actions for Contaminated
Groundwater at Superfund Sites, October 1986 and April 1988.
As a result of these assessments, EPA-identified several
objectives for the cleanup of the Wells G & H Superfund Site.
These  objectives were developed to mitigate existing and future
threats  to public health and the  environment.  The response
objectives listed here are the  overall objectives for the entire
Site including the central area,  the five source areas of
contamination,  the Aberjona River and its associated wetlands
within the Site boundary.   The  specific response objectives for
the operable unit associated with this ROD - the five source
areas  of contamination - are listed in Section X, part A.  The   f-
response objectives for the entire Site cleanup, at the
completion of all operable units, are as., follows:

     1.    Restore the aquifer that supplied water to Wells G & H
           to drinking water standards.

     2.    Stop the introduction of contaminated groundwater from
           the source areas to the rest of the aquifer.

     3.    Stop the leaching of  soil contaminants to the
           groundwater.

     4.    Prevent public contact  with contaminated groundwater
           and soil above the cleanup levels.

     5.    Protect the natural resources in the area, such as the
           river and wetlands, from becoming further degraded.

     6.    Reduce further migration of contaminated groundwater
           off-site.                       .

     B.    Technology and Alternative Development and Screening

CERCLA,  the NCP,  and EPA guidance documents including, "Guidance
on Feasibility Studies Under CERCLA" dated June 1985, and the
"Interim Guidance on Superfund  Selection of Remedy" [EPA Office
of Solid Waste and Emergency Response  (OSWER)], Directive No.
9355.0-19 (December 24, 1986) set forth the process by which
remedial actions are evaluated  and selected.  In accordance with
these  requirements and guidance documents, a range of treatment
alternatives were developed for the Site ranging from an

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                                17


alternative that, to the extent possible, would eliminate the
need  for long terra management at the Site (including monitoring),
to alternatives  involving treatment that would reduce the
mobility, toxicity, or volume of the hazardous substances as
their principal  element.  In addition to the range of treatment
alternatives, a  containment option involving little or no
treatment and a  no action alternative were developed in
accordance with  Section 121 of CERCLA.

Section 121(b)(1) of CERCLA presents several factors that at a
minimum EPA is required to consider in its assessment of
alternatives.  In addition to these factors and the other
statutory directives of Section 121 of CERCLA, the evaluation and
.selection process was guided by the EPA document "Additional
Interim Guidance for FY 87 Records of Decision" dated July 24,
1987.  This document provides direction on the consideration of
SARA cleanup standards and sets forth nine factors that EPA
should consider  in its evaluation and selection of remedial
actions.  The nine factors are:

1.   Compliance  with Applicable or Relevant and Appropriate
     Requirements  (ARARs).
2.   Long tern Effectiveness and Permanence.
3.   Reduction of Tcxicity, Mobility or Volume.
4.   Short term  Effectiveness.
5.   Implementability.
6.   Cost.
7.   Overall Protection of Human Health and the Environment. .
8.   Community Acceptance.
9.   State Acceptance.

Section 2 of the Feasibility Study identified, assessed and
screened technologies for both soil and groundwater remediation
based on technical feasibility, implementability, effectiveness,
and cost.  The purpose of the initial screening process was to
narrow the number of potential remedial actions for further
detailed analysis while preserving a range of options.  These
technologies were separated into source control (SC) and
management of migration  (MOM) alternatives.  Each alternative was
then evaluated and screened in Section 3 of the Feasibility
Study.  Section  3 of the Feasibility Study presented the remedial
alternatives developed by combining the technologies that passed
the previous screening process into the categories required by
OSWER Directive  No. 9355.0-19.  A total of eleven SC alternatives
and five MOM alternatives were evaluated and screened in Section
3.  Of these, nine SC alternatives and four MOM alternatives were
retained for detailed analysis in Section 4.  Table 3 identifies
the thirteen alternatives that were retained throughout the
screening process.

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                                18

IX.        DESCRIPTION/SUMMARY OP  THE ANALYSIS OF ALTERNATIVES

This  section  presents  a  narrative stannary and brief evaluation of
each  alternative  according  to the evaluation criteria described
above.  A  detailed  tabular  assessment of each alternative can be
found in the  Feasibility Study, Section 4, Tables 4-36 and 4-39.

_]'   "A".    Source  Control (SC) Alternatives Analyzed

The source control  alternatives analyzed for the Site include a
limited action  alternative, SC-1; on-site and off-site
incineration  alternatives,  SC-3 and SC-4; on-site high
temperature enhanced volatilization, SC-5; on-site supercritical
fluid extraction, SG-7;  on-site enhanced
volatilization/incineration, SC-8; on-site enhanced
volatilization/off-site  incineration, SC-9; in-situ
volatilization/on-site incineration, SC-10; and in-situ
volatilization/off-site  incineration, SC-11.  These alternatives
are described briefly  below with  approximate capital and present
worth operation and maintenance costs.

SC-1
Limited'Action

The limited action  alternative entails leaving contaminants
untreated  on  site,  and monitoring contaminant concentrations
every year for  30 years.  EPA would conduct a more extensive
review of  the Site  every five years to determine whether further
remedial action is  necessary to protect'human health and the
environment.  The limited action  alternative also involves
limiting access to  the Site, limiting Site use, and conducting
public education  programs to increase public awareness of the
Site.  Although it  is  expected that contamination will remain on
site  beyond 30  years,  EPA's cost  analysis is based upon a 30 year
timeframe.  SC-1  was referred to  as a no-action alternative in
the Feasibility Study  and Proposed Plan.

Because this  alternative would not involve disturbing the
contaminated  soil,  other than to  construct a fence, it provides
short term effectiveness in protecting public health during
implementation.   In addition, little difficulty would be involved
in the implementation  of the tasks associated with this
alternative and the work could be completed within a relatively
short period  of time.  However, this alternative would require
ongoing surveillance and maintenance to ensure long term
effectiveness.  This alternative  would not involve removal or
other on-site containment and treatment to reduce the toxicity,
mobility,  or  volume of the  contaminants.  It would not,
therefore, provide  adequate protection of human health and the
environment.  This  alternative does not comply with APvARs.

The no-action alternative  (i.e.,  the baseline scenario presented
and evaluated in  the risk assessment) does not include activities

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                                19


to reduce the potential for exposure such as restrictions on site
use and access.  Since the limited action alternative,  which
includes institutional controls to limit site access and use,  is
not protective and does not attain ARARs, the no-action
alternative, which is less protective than the limited  use
alternative, would also not be protective nor attain ARARs.

Total Capital and Operation and Maintenance Costs:  $800,800


SC-3
Excavation/On-Site Incineration/Backfill On-Site

This alternative would involve excavating approximately 9,500
cubic yards  (cy) of contaminated soil at the Site and treating
the soil on-site in a mobile incinerator.  The contaminated soil
would be burned at very high terperatures.  Because incineration
will destroy virtually all of the organic contaminants  in the
soil, the treated soil can be backfilled.

This alternative would use treatment to reduce the toxicity,
mobility and volume of contaminants and would achieve permanence  ^
by destroying the contaminants of concern.  This would
effectively reduce risks associated with the Site and adequately
protect human health and the environment.  While there  is a
potential for short term public health threats to workers and
area residents during excavation, soil handling and incineration,
risks would be minimized by the use of adequate preventive
measures.  All components of this alternative are well  developed
and commercially available.  No long term management of treated
soil would be required, nor would there be a need for future
remedial actions.  This alternative would, however, require
excavation and placement of fill in a wetlands, and if  it is
determined that a practicable alternative exists, it would not
meet the Federal Wetlands. Protection ARARs.

Estimated Time for Completion Including Design/ Bidding,
     Construction and Operation:  4 years
Estimated Time for On-Site Construction and Operation Only:  15
     months
Total Costs:  $7,500,000


SC-4
Excavation/Off-Site Incineration/Backfill with Clean Off-Site
Soil

This alternative is similar to SC-3 except that contaminated soil
would be transported to an off-site incineration facility for
treatment, and the excavated area would be backfilled with clean
off-site soil.

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                                20


This  alternative would  meet the criteria in the sane way as  SC-3
with  the following exceptions.  While the components of this
alternative are well  developed and commercially available, the
available capacity of off-site incineration facilities could be a
potential problem since there are only a few currently in
operation in the country.  In addition, this alternative is  more
costly  than SC-3.

Estimated Time for Completion Including Design/ Bidding/ and
:      Construction and Operation:  3.5 years
Estimated Time for Construction and Operation Only:   15 months
Total Costa:   $22,100,000


SC-5
Excavatlon/On-Site High Terperature Enhanced
Volatilization/Backfill Or-Site

This  alternative involves excavating approximately 9,500 cy  of
contaminated soils and  treating the soils.in a mobile treatment
unit  by high temperature enhanced volatilization.  High
temperature enhanced  volatilization is a type of thermal
treatment process that  involves mixing the contaminated soil with
heated  air.   This causes the release and transfer of VOCs,  PAHs,
PCBs  and chlordane from the soil to the air in the unit.  The
contaminants in the air are then destroyed afterwards in a
burner.   The treated  soil would then be backfilled into the
excavated areas.

While there is a potential for short term public health threats
to workers and area residents during excavation, soil handling,
and high temperature  volatilization, risks would be minimized by
the use of adequate preventive measures.  All components of  this
alternative are well  developed and commercially available.
However,  data is lacking with respect to the effectiveness of
this  technology to achieve target levels for chlordane and PAHs.
While the technology  would use treatment to reduce the toxicity,
mobility and volume of  contaminants at the Site, it is uncertain
as to whether the technology can reduce the concentrations of all
contaminants to their target levels.  Therefore, institutional
controls may need to  be implemented to ensure the long term
effectiveness of this alternative.  Treatability studies would
have  to be done to confirm whether this process would meet target
levels  for all contaminants.  As with SC-3 and SC-4, this
alternative would require excavation and placement of fill in a
wetlands area, and if it is determined that a practicable
alternative exists, it  would not meet the Federal Wetlands
Protection ARARs.

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                                21
Estimated Time for Completion Including Design,  Bidding,
     Construction and Operation:  3 years
Estimated Time for On-Site Construction and Operation Only:
     months  .             .
Total Costs:  $6,600,000
Excavation/On-Site Supercritical Fluid Extraction/Backfill On-
Site

This alternative would use an innovative technology to treat
approximately 9500 cy of contaminated soil.  Contaminated soil
from the Site would be excavated and mixed with water to create a
slurry that can be p.u-ped into a mobile on-site extractor unit.
Liquified carbon dioxide introduced into the unit would work as a
solvent, dissolving- contar.ir.ants as .it- passes over the slurry in
the extraction unit under elevated pressure.  Treated soil would
be backfilled to the excavated areas.  The snail quantity of
extractant containing the contaminants stripped from the soils
would be collected and shipped off-site to a commercial
incineration facility.

This alternative would use treatment to reduce toxicity, mobility
and volume of contaminants at the Site.  Although currently in
use to treat PCB laden oily wastewater and sludges from refinery
industries, this technology has not been used. on a large scale
for removal of the kind of soil contamination present at the
Site.  Therefore, its ability to reduce contamination to target
levels is uncertain,  and institutional controls may need to be
implemented to ensure the long; term effectiveness of this
alternative.  Treatability studies would be necessary before
supercritical fluids extraction could be implemented at the Site.
In addition, because this is an innovative technology, we are
uncertain of the availability of materials and services to
implement this alternative.  As with all other alternatives
involving excavation and placement of fill in a wetlands, this
alternative would not meet the Federal Wetlands Protection ARARs
if it is determined that a practicable alternative exists.

Estimated Tine for Completion Including Design, Bidding,
     Construction and Operation:  3.5 years
Estimated Time for Construction and Operation Only:  1 year
Total Costs:  $7,500,000

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                                22
SC-8
Excavatlon/On-Slte  Enhanced Volatilization/On-Site
Incineration/Backfill On-Site

This alternative would use enhanced volatilization as described
under SC-5, except  at lower temperatures, to treat approximately
7,600 cy of soil contaminated with VOCs only, and on-site
incineration in a mobile unit as described under SC-3 to treat
approximately  1,900 cy of soil contaminated with a mixture of
PAHs, PCBs, VOCs, and pesticides.  Treated soil from both the
enhanced volatilization and incinerator units would be backfilled
on-site.

While there is a potential for short term public health threats
to workers and area residents during excavation, enhanced
volatilization,"and incineration activities, risks would be
minimized' by the use of adequate preventive reasures.
All components of this alternative are well developed and
conr.ercially available.  This combination would use treatment to
reduce toxicity, mobility and volume of contaminants at the Site.
Soil contaminants would be reduced to target levels by
incineration in this alternative.  However, the ability of
enhanced volatilization to achieve target levels is uncertain,
and institutional controls may need to be implemented to ensure
the long term  effectiveness of this alternative.  Treatability
studies would  be required .to confirm the long term effectiveness
of enhanced volatilization with respect to achieving target
levels.  This  alternative requires excavation and placement of
fill in a wetlands.  If it is determined that a practicable
alternative exists, it would not meet the Federal Wetlands
Protection ARARs.

Estimated Time for  Completion Including Design/ Bidding/
     Construction and Operation:  4 years
Estimated Tine for  Construction and Operation Only:  16 months
Total Costs:   $6,200,000


SC-9
Excavation/On-Site  Enhanced Volatilization/Off-Site
Incineration/Backfill with Treated and Clean Off-Site Soil

This alternative differs from SC-8 only in that soils
contaminated with a mixture of organic contaminants would be
excavated, packaged and shipped off-site for incineration.  Since
only the soil  treated by enhanced volatilization would remain
on-site for use as  a backfill, clean fill would have to be
brought in to  supplement the treated soils.  This alternative
would meet the criteria in the same way as SC-8 except that this
alternative is more costly.

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                               23


Estimated Time for Completion Including Design,  Bidding,
     Construction and Operation:   3.5 years
Estimated Tine for Construction and Operation Only:   10 months
Total Costs:  $9,000,000


SC-10
In Situ Volatllization/Excavation/On-Site Incineration/Backfill
On-Site

This alternative uses both in-situ volatilization and
incineration to treat the contaminated soil on-site.   In-situ
volatilization would be used to treat 7600 cy of soil
contaminated only with VOCs.  This technology involves installing
extraction wells into the contaminated soils above the
groundwater table.  .Piping is attached to each well  and also to a
vacuum pump.  The vacuum pur.p draws air frc- thr> surrounding
soils into the wells without disturbing the soils.  As the air
passes over the contaninated soils, VOC contaminants are
transferred from the soil to the air.  The air is sent through
columns of activated carbon that filter out the contaminants, andf-
the treated air is discharged to the atmosphere.  The carbon is
then regenerated to remove contaminants.  Incineration would be
used to treat the remaining 1900 cy of soil at the Site
contaminated with a mix of PCBs,  PAHs, pesticides and VOCs.

While there is a potential for short term public health threats
to workers and area residents during excavation, incineration,
and in-situ volatilization, risks would be minimized by the use
of adequate preventive measures.   All components of this
alternative are well developed.  In-situ volatilization has been
successfully used at a number of Superfund sites for VOC removal,
and incineration technologies are demonstrated to be reliable.
Pilot scale testing would be required for in-situ volatilization
for fullrscale design and optimization.

This alternative would effectively reduce the toxicity, mobility
and volume of contaminants in the soil.  This alternative would
reduce contaminants to target levels.  In addition,  a portion of
the soil to be treated by in-situ volatilization is located in a
wetland area where the technology could be implemented without
damaging the wetland.  SC-10 would meet all Federal and State
ARARs.

SC-10 is the chosen source control alternative for implementation
at the Site.  It is discussed in greater detail in Section X.

Estimated Time for Completion Including Design, Bidding,
     Construction and Operation:   4 years
Estimated Time for Construction and Operation Only:   16 months
Total Costs:  $3,200,000

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                                 24

 SC-11
 In-Situ Volatilization/Excavation/Off-Site Incineration/Backfill
 With Clean Off-Site Soil

 This alternative is similar to SC-10 except that the  soil with
 nixed contaminants would be packaged and shipped off-site for
 incineration.

-This alternative would meet the criteria in the same  way as SC-10
 except that this alternative is more costly.

 Estimated Time for Completion Including pesign, Bidding,
      Construction and Operation:  3.5 years
 Estimated Time for Construction and Operation Only:   10 months
 Total Costs:  $6,200,000


      B.   Management of Migration (MOM) Alternatives  Analyzed

 The management of migration alternatives address contamination of
 the groundwater at the source areas and at the center of the
 Site.  Contamination which exists in the overburden and bedrock  ^
 aquifers of the source areas has migrated to the center of the
 Site.  In addition, some groundwater contamination exists beyond
 the southern boundary of the Site.   The MOM alternatives
 evaluated include a limited action alternative, MOM-1; pumping
 and treating the source areas, MOM-2; pumping and treating the
 central area, MOM-3; and pumping and treating both the source
 areas and the central area, MOM-4.

 Section 4 of the Feasibility Study examines 11 variations of the
 three "pump and treat" MOM alternatives (see Table 3), all of
 which include three basic procedures: 1) the installation of
 wells to extract contaminated groundwater from the Site; 2)
 pretreatment of the extracted groundwater to remove suspended
 solids and metals that could potentially foul the principal
 treatment unit; and 3) a treatment scheme to remove VOCs from the
 groundwater.  These 11 variations differ according to the
 location of the extraction well, the type of treatment scheme
 employed, and the location and number of treatment facilities.

 The three different treatment schemes that were evaluated for the
 removal of VOCs include physical treatment by air stripping,
 chemical treatment by ultraviolet (UV)/chemical oxidation, and
 physical treatment by carbon adsorption.  Below is a  brief
 description of each technology.

      Air Stripping:  Extracted groundwater is first pretreated
      and then passed through an air stripping chamber which  is
      encased in a cylindrical structure.  In the chamber, air  is
      forced up through the water.  As a result, contaminants are
      carried into the air stream.  The air stream is  then treated

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                               25

     in activated carbon columns to remove contaminants before
     being released to the atmosphere.   Treated groundwater would
     then be discharged.

     Ultraviolet (UV)/Chemical Oxidation:   This technology uses  a
     chemical reaction to destroy organic  contaminants in the
     groundwater.  Hydrogen peroxide would be introduced into the
     contaminated groundwater in the presence of ultraviolet
     light to create new compounds called  hydrogen radicals.
     These radicals react to chemically alter organic
     contaminants to non-hazardous carbon  dioxide and water.

     Carbon Adsorption:  This technology can be used as a
     principal or secondary treatment;  either to remove organic
     contaminants from groundwater or to remove organics from the
     airstream.  Activated carbon is carbon that has been treated
     to enhance properties that cause contaminants to adhere to
     the carbon surface areas.  Groundwater is continuously
     pumped through the activated carbon units until cleanup
     goals are met.  The carbon filter is  regenerated from time
     to time to maintain its efficiency.
                                                                '
As stated earlier in this ROD, the Riley Tannery production well
is no longer in use.  The cleanup timeframes and approximate pump
rates for the MOM alternatives were estimated based on the
conditions that existed when the Riley well was pumping. The
absence of the Riley well does not change  the recommended pump
rates as discussed in the Feasibility Study as these rates were
developed excluding the effects of the Riley well.  The absence
of the Riley well, however, does impact the movement of
contaminants into the central area and the timeframe associated
with the cleanup of the central area.  The Agency does not
believe that these changes are significant since the central area
is not being addressed under this ROD,  and the objectives of
remediating the five source areas are not modified by the fact
that the Riley well is no longer pumping.

The following is a brief description of each of the MOM
alternatives evaluated for the treatment of contaminated
groundwater.


MOM-1
Limited Action

A limited action alternative for groundwater would consist of a
long term monitoring program and review every five years to
determine whether further remedial action is necessary to treat
contaminated groundwater.  The limited action alternative also
involves limiting the withdrawal of groundwater and conducting
educational programs to increase public awareness.  Groundwater
contamination, however, would remain and continue to migrate to
other areas within the Site and downgradient from the Site.  The

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                                26

actual time it would take for remediation to be accomplished,
through natural attenuation, is greater than 100 years.   Thirty
years, however, is the estimate being used for costing purposes
only.  MOM-1 was referred to as a no-action alternative in the
Feasibility Study and Proposed Plan.

This alternative poses no short term threat to the community as
groundwater use would continue to be restricted.  While workers
at the site for sample collection and site inspection would be
exposed to contaminated groundwater, risks would be minimized by
the use of personal protective equipment.   However,  as this
alternative contains no active remediation, it would not result
in any immediate reduction in toxicity, mobility, or volume of
contaminants, and would not result in the attainment of target
cleanup levels in a rapid time frame.  Also, the volume of
contaminated groundwater would probably increase with time due to
the migration of contaminants into other areas of the Site as
well as into the deeper fractures in the bedrock.  Therefore,
this alternative will not provide long terra effectiveness and
permanence, and it. is not protective of human health and the
environment.  Finally, this alternative does not comply with
ARARs.
                                                                ^
The no-action alternative (i.e., the baseline scenario presented
and evaluated in the risk assessment) does not include activities
to reduce the potential for exposure such as limiting groundwater
withdrawal.  Since the limited action alternative, which includes
institutional controls to limit the withdrawal of -groundwater for
potable use, is not protective and does not attain ARARs, the
no-action alternative, which is less protective than the limited
jse alternative, would also not be protective nor attain ARARs.

Total Costs:  $440,200
10M-2
Pump and Treat Source Areas

This alternative would  involve pumping groundwater from each of
;he five source areas,  pretreatment to remove suspended solids
md metals, and treatment by either air stripping or ultraviolet
(UV) /chemical oxidation to remove VOCs.  Treatment by carbon
idsorption alone was not evaluated for this alternative because
Df the superiority of air stripping and UV/chemical oxidation for
removing higher levels  of VOCs.  Contaminated groundwater in the
jverburden aquifer would be pumped and treated at all of the
properties.  Contaminated groundwater in the bedrock would be
jumped and treated at all properties except Olympia Nominee
Trust.  Contaminated groundwater would be treated at either
Separate source area treatment plants or one centrally located
;reatment plant.  Source areas would be pumped with the objective
)f achieving MCLs.

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                                27
  nder this alternative,  potential public health threats would
 exist for area residents and workers during construction, but
 would be minimized by the use  of adequate preventive measures.
 Eventually,  contamination .in the groundwater would be reduced to
 target levels throughout the Site.  Although MOM-2 does not
 directly address the  central area of the Site, it was
 anticipated,  at the time the Feasibility Study was conducted,
 that-pumping at the Riley well and natural attenuation would
 remediate the central area to  MCLs over a period of 22 years.  A
 small portion of contaminated  groundwater may migrate off -site.

 The extraction at source areas would control the migration of
 contaminated groundwater to the central area and beyond, thereby
 preventing further contamination of the aquifer.  Also, treatment
 would "directly reduce the toxicity, mobility and volume of
 contaminants in the groundwater.  The effectiveness of extraction
 of contaminated groundwater from the fractured bedrock is
 uncertain,  however, and  some residual contamination could remain
 in the bedrock.   Finally,  this alternative would comply with
 ARARs.             .

. MOM-2 is the chosen management of migration alternative for
 implementation at the Site and is discussed in greater detail in
 Section X.
           Tine for Completion  Including Design/ Bidding/
      Construction, and  Operation:   22 years  for central area; 20-
      50  years  for source  areas.
 Total Costs: The  cost for implementing this  alternative will
      depend on the number and  type  of treatment plants selected
      for the remedy.  See Table  4 for a breakdown of costs for
      each variation.
MOM-3
Pump and  Treat  Central  Area

This alternative  involves  pumping  contaminated groundwater from
.the central  area  of  the site  followed by pretreatment and either
air stripping,  UV/cheroical oxidation, or carbon adsorption.
This alternative  would  significantly reduce migration of
.contaminants off-site to the  south due to the large capture zone
for Wells G  & H.   However, contaminated groundwater in source
areas  could  migrate  off-site.

Potential public  health threats  to area residents  and workers
during construction  would  exist  from direct contact with
contaminated groundwater,  soils  and inhalation of  fugitive dust
and organic  vapors.  These risks,  however, could be minimized by
       preventive  measures  and personal protective  equipment.

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                                28


This alternative would capture contaminated groundwater  from the
central area, and would also intercept a limited amount  of
contaminated groundwater that flows from the source  areas to the
central area.  Since no direct bedrock pumping at the sources
would occur, some contaminated groundwater may remain in the
bedrock at the source areas and continue to recontaminate the
overburden in the future.  As the achievement of MCLs throughout
the site is anticipated to require in excess of 60 years, this
alternative would result in protection of human health and  the
environment only after a lengthy remediation period.   This
alternative will meet ARAEs throughout the Site, although there
is more uncertainty that ARARs can be met in the bedrock.

Estimated Time for Completion Including Design, Bidding,
     Construction and Operation:  Exceeds 60 years
Total Coats:  See Table 4
MOM-4
Purp and Treat Source Areas and the Central Area

This alternative combines KOM-2 and MOM-3 to provide pumping  and
treatment of contaminated groundwater from the source areas and
the center of the Site.  Treatment of groundwater would occur at
either six separate treatment plants or at one centrally located
treatment plant.  Groundwater would first be pretreated and then
principally treated by either an air stripper or by UV/chemical
oxidation.  Treatment by carbon adsorption alone was not
evaluated for this alternative because of the superiority of  the
other two treatment processes for removing higher levels of VOCs.

The extraction of contaminated groundwater at the source areas
and central area followed by pretreatment and air stripping would
significantly reduce the migration of contaminants from source
areas as well as the central area.  The source areas and central
area would be pumped with the objective of achieving MCLs
throughout the Site.  The effectiveness of extraction of
contaminated groundwater from the fractured bedrock is uncertain,
however, and some residual contamination could remain in the
bedrock in the source areas.

Potential public health threats to area residents and workers
during construction would exist from direct contact with
contaminated groundwater, soils and inhalation of fugitive dust
and organic vapors.  These risks, however, could be minimized by
using preventive measures and personal protective equipment.
This alternative would result in overall protection of human
health and the environment upon completion of remediation. MOM-4
would comply with ARARs.

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                               29


Estimated Time for Completion Including Design,  Bidding,
     Construction and Operation:   10 years for the central  area,
     20-50 years for the source areas.
Total Costs:  See Table 4
Z.        THE SELECTED REKZDY

The remedial action selected for implementation at the Wells
G & H Site consists of the source control alternative SC-10, and
the management of migration alternative MOM-2.   The operable unit
addressed by this ROD includes the five identified source areas
of contamination.  In addition, the remedial action also includes
a study of the central area to determine the most effective
remedial alternative for restoring the central  area aquifer to
drinking water quality, as well as an investigation to identify
the extent of contamination in the Aberjona River.

     A.   Description of the Selected Remedy

          1.   Remedial Action Objectives/Cleanup Goals

The selected reredy was developed to satisfy the following
remedial objectives which will guide the design of the remedy and
be used to measure the success of the remedy. .  The objectives
listed below are specific to the operable unit  described in this
ROD.
          a.    Soil

The remedial objectives for contaminated soil at the five source
areas of contamination at the Wells G & H site  are as follows:

     o    Prevent public contact with contaminated soil above the
          Cleanup levels;

     o    Stop the leaching of soil contaminants to the ground
          water; and

     o    Protect the natural resources at the  site from
          further degradation.

EPA has identified site-wide cleanup goals for  each of the
chemicals of concern in soil.  These goals satisfy the above
objectives.  The soil cleanup goals represent the concentrations
that can remain in the soil and still be considered protective of
public health.  Three approaches were used to determine these
levels.  For volatile organic compounds detected in the soil and
the groundwater, and which pose a substantial risk from exposure
via groundwater, a leaching model was used to calculate a level
in the soil that is protective of groundwater.   These chemicals
and their respective target soil concentrations are presented in
Table 5.

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                                30

 The second approach involved developing soil cleanup goals for
 PCBs,  PAHs, and the pesticides chlordane and DDT.  Consistent
 with the Superfund Public Health  Evaluation Manual. 1986, EPA
 evaluated a risk range of 10.-* to 10-  individual  lifetime excess
 cancer risks associated with direct contact with  the contaminants
 in the soil.  The soil cleanup levels  corresponding with a 10-6
 increase in potential excess cancer risk were  chosen for these
 contaminants.  These chemicals and  their respective target soil
"concentrations are presented in Table  6.

 The third approach develops a cleanup  goal for lead based on
 acceptable blood lead levels.  The  chosen cleanup goal  for lead
 in soil, based on a target blood  lead  level of 10 ug/dl, is 640
 ing/kg.  The methodologies used to derive the cleanup goals for
 each of the three approaches presented above are  discussed in
 detail in the Feasibility Study,  Section 1.

           b.   Grcundwater

 The remedial objectives for contaminated groundwater at the five
 source areas.of contamination at  the Wells G & H  Site are as
 follows:                                                         F

      o    Prevent the further introduction of  contaminated ground
           water from the source areas  to the central area;

      o    Limit the further migration  of contaminated ground
           water off-site from the source areas;

      o .   Restore the bedrock and overburden aquifers  (aquifers)
           in the vicinity of the  source areas  to  drinking water
           quality; and

      o    Prevent public contact  with  contaminated
           groundwater above the cleanup levels.


 The target groundwater cleanup levels  are based upon the
 classification of the groundwater at the Site  as  a potential
 source of drinking water. .Therefore,  EPA has  identified Maximum
 Contaminant Levels (MCLs) promulgated  under the Safe Drinking
 Water Act as the cleanup goals to be applied to the Site
 groundwater within the aquifer.   These goals satisfy the above
 objectives and are protective of  human health  and the
 environment.  Table 7 presents the  cleanup goals  for the
 chemicals of concern in groundwater.

 Cleanup goals for treated groundwater  effluent will depend on  the
 point of discharge.  Presently, EPA believes that treated
 groundwater will be discharged to the  Aberjona River.   In this
 case,  the Massachusetts Ambient Water  Quality  Standards (AWQSs)
 will be used to set effluent targets.   If the  effluent  is
 discharged to the aquifer, MCLs will be the appropriate

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                                31

standards.  Specific effluent discharge requirements will be
refined during design.

          2.   Description of Remedial Components

The following components define the selected remedy.  This remedy
addresses groundwater, soil, sludge and debris at the Site.

          a.   Contaminated Soil Treatment

This component of the remedy is composed of the following: in-
situ volatilization, excavation, on-site incineration,
backfilling, predesign work, implementation monitoring,  and
completion requirements.

Incineration will be used to treat approximately 2100 cy of soil
at the Site contaminated with a mix of PCBs, PAHs,  pesticides and
VOCs.  These soils will be excavated from the Wildwood,  Unifirst
Corporation, New England Plastics Company and Olympia Nominee
Trust properties and then destroyed in a mobile temporary on-site
incinerator.  The incinerator will employ Best Available Control
Technology, such as air scrubbers, and will be monitored to
control air emissions.  Test burns will be required to determine
actual performance of incineration on the mixed contaminant soil
and to generate treated samples for EP toxicity and TCLP tests to
confirm that the treated soil would be acceptable for backfill at
the site.  If EPA determines that the incinerator ash is subject
to the Land Disposal Restrictions of the Resource Conservation
and Recovery Act (RCRA), the ash will be managed in accordance
with such restrictions.  After the soil has been treated and
tested, and it is determined to meet cleanup goals, it will be
used as backfill for excavated areas.

In-situ volatilization will be used to treat approximately 7400
cubic yards of VOC contaminated soil on the Wildwood property.  A
portion of the soil to be treated by in-situ volatilization is
located in a wetland area on the Wildwood property.  The in-situ
volatilization system will be installed in such a way that it
minimizes damage to the wetland.  In-situ treatment will use
carbon adsorption for vapor treatment.  Pilot scale testing will
be required to ensure full scale design and optimization.

The areas of contaminated soils at the Site are identified in
Figure 4.  There was no soil found at the W.R. Grace property in
concentrations above the target cleanup levels.  Consequently,
there is no soil removal prescribed for the W.R. Grace property.
Following are approximate volumes of contaminated soils per
property.  The methodology used to estimate these volumes is
presented in Appendix D and Section 3.1 of the Feasibility Study.

     Wildwood - 7400 cubic yards of VOC contaminated soil and
     1900 cubic yards of mixed contaminant soil.

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                                32

     Olympia -  5 cubic yards of PAH contaminated soil.

     New England Plastics - 40 cubic yards of VOC contaminated
     soil.

     Unifirst - 150 cubic yards of VOC contaminated soil.

Requirements of predesign will include soil sampling to refine
estimates of contaminated soil volumes and to generate  property
specific values for the  fraction of organic carbon in the  soil.
This information will be used to modify soil volumes and soil
cleanup goals as necessary.  VOCs are the primary soil
contaminant at  the Site.  The volume of VOC contaminated soil
requiring remediation is largely determined by the target  cleanup
levels for VOCs.  These  levels are based on the leaching model
discussed in Section X.A.I.a above and presented in Section 1.0
of the Feasibility Study.  As the soil fraction of organic carbon
is a component  of that model, a variation in this number may
necessitate refinement of the cleanup goals for VOCs in soil.  A
value of 1% for the fraction of organic carbon in soil  was used
to generate the approximate volumes of contaminated soil per
property listed above.   That value was assumed based on the soil
types present.  Any refinement of the cleanup goals based  on the ?"•
fraction of organic carbon value will be made in accordance with
the leaching model.

Air monitoring  will be performed during the implementation of the
remedy to ensure that fugitive and point source emissions  do not
result in unacceptable ambient air quality.  Consideration will
be given to the sequencing of the soil and groundwater  components
of the remedy to avoid recontamination of treated soil  by
volatilization  of contaminated groundwater.  This is of special
interest at the Unifirst property due to the presence of dense
non-aqueous phase liquids which have the potential to volatilize
and recontaminate the soils.  In addition, wetlands monitoring
will occur to avoid degradation of the wetlands.

A soil sampling and analysis program will be implemented to
monitor the performance  of in-situ volatilization.  At  a minimum,
it will include soil and soil gas sampling at the beginning,
during, and end of implementation.  Soil samples will also be
taken during excavation  for the incineration component of  this
remedy in order to refine the extent of soil for removal.   Upon
completion of the excavation and in-situ volatilization programs,
soil samples will be taken and evaluated against cleanup goals.
This data will  be used to evaluate the success of the remedy, and
ultimately for  site delisting.  A specific soil sampling and
analysis program will be developed during design.

        b.      Sludge and Debris Disposal

A specific program for the removal and disposal of sludge and
debris from the Wildwood property will be defined during design.

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                                   33

   This material does not lend itself to on-site incineration due to
   its metal content.  If EPA determines that this material  is
   subject to the Land Disposal Restrictions of RCRA,  it will be
   managed in accordance with such restrictions.  If the material is
   not subject to the Land Disposal Restrictions of RCRA,  it will be
   removed by a licensed waste hauler for appropriate disposal.
   Upon completion of removal, soil samples will be taken and
   evaluated against ROD soil cleanup goals to determine the need
'•r_-Jfor^additional excavation or treatment.

             c.   Ground Water Extraction and Treatment

   This component of the remedy consists of the following:
   construction of groundwater treatment plants, predesign pump
   tests and bench tests, development of extraction and monitoring
   wellsy groundwater treatment, groundvater monitoring, and
   effluent monitoring.

   Ground water extraction and treatment systems are to be
   implemented at each source area.  As the location and type of
   contamination may vary among the source areas, each system will
   be designed to address the bedrock and/or overburden
   contamination associated with a particular area.  Following are  t
   approximate pumping rates used in the Feasibility Study for
   comparison purposes.  The methodology used to estimate the pump
   rates is presented in Section 3.2 and Appendix C of the
   Feasibility Study.  The exact number, location, depth,  and
   pumping rate of extraction wells at each source area will be
   developed during remedial design.

        W.R. Grace - 45 gallons per minute (gpm) in the overburden,
        20 gpm in the bedrock.

        Unifirst - 60 gpm in the overburden, 20 gpm in the bedrock.

        Olympia - 50 gpm in the overburden.

        Wildwood - 240 gpm in the overburden, 60 gpm in the bedrock.

        New England Plastics - 15 gpm in the overburden, 6 gpm in
        the bedrock.

   The proposed groundwater treatment system consists of
   pretreatment by precipitation, coagulation, flocculation, and
   clarification to remove suspended solids and metals followed by
   air stripping to remove VOCs.  Pretreatment sludge will be
   disposed of at a licensed facility.  The sludge will be tested to
   determine if it is subject to the RCRA Land Disposal
   Restrictions.  If EPA determines that the sludge is subject to
   such restrictions, it will be managed accordingly.

   Carbon adsorption will be used to treat emissions from the air
   stripper in order to comply with the Massachusetts Air Pollution

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                                34

Control  requirements  to  use Best  Demonstrated Available
Technology for point  source emissions (310 CMR § 7.00).  Treated
grouridwater will  be discharged to the Aberjona River,  reinjected
into  the aquifer,  or  both, depending on design.  Given that each
source area is unique in regard to its contaminants, EPA will
consider alternative  treatment approaches that can be
demonstrated to be equally or more effective in contaminant
removal  as the presented system.

The approximate area  of  groundvater contamination associated with
each  source area  is defined in Figure 5.  This figure delineates
approximate boundaries for groundwater extraction that will be
refined  during design.

Predesign work will consist of pump tests, groundvater sampling,
and bench and pilot testing of the presented and/or proposed
treatment technologies.   Pump tests will be performed to
determine well yields.   This information will be used to help
determine pumping  rates  and the location and number of extraction
wells.   Groundwater sampling will occur at each source area to
refine and confirm the nature and extent of contamination in both^
the bedrock and overburden.  Bench scale treatability studies    •
will  be  performed  for the presented and/or proposed treatment
technology employed at each source area.

Groundwater monitoring of the overburden and bedrock aquifers
will  occur during  implementation  of the remedy in order to
determine compliance  with the. cleanup goals.  A specific
monitoring program will  be developed during design and will
include,  at a minimum, overburden and bedrock monitoring wells at
each  source area  including those  wells that have been installed
as part  of the remedial  investigation.  Monitoring wells will be
sampled  at least  quarterly.  In addition, pumping rates at each
extraction well will  be  monitored.  Treatment system influent and
effluent concentrations  will be monitored at a minimum of once
per day.   The objectives of monitoring are to define the mass of
contaminants extracted over the life of the remedy, to evaluate
the efficiency of  the remedy, and to ensure compliance with
appropriate Federal and  State requirements.

In addition to the monitoring program, a summary report will be
generated yearly during  the implementation of the remedy.  The
report will summarize the status  of groundwater remediation and,
at a  minimum,  will include the following: summary tables of
contaminant concentrations; a summary of the mass of contaminants
removed,  i.e.,  groundwater pump rates and the influent and
effluent concentrations;  contour  maps of the distribution of
contaminants;  and  an  interpretation of the trends in contaminant
concentration and  distribution.

Once  cleanup goals have  been satisfied, the extraction wells will
be shut  down and  a monitoring program will be implemented.  This
program  will consist  of  a minimum of three years of quarterly

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                               35

monitoring of ground water quality.  If the monitoring data
during this period shows an increase in contaminant levels over
time, such that cleanup goals are not maintained,  active
groundwater remediation will be resumed.  The results of this
monitoring program will be reviewed by EPA in order to evaluate
the success of the remedy, the maintenance of cleanup goals,  the
need for any additional site work including the resumption of the
remedy or the implementation of institutional controls, and to
provide information for site delisting.             - .

          d.   Institutional Controls

EPA recommends that the State and the City of Woburn implement
controls, such as regulations, ordinances, deed and land
restrictions, or other effective forr.s of land use control to
prevent the use of the aquifer in the vicinity of the Site.
Groundwater use should be restricted until it is determined
conclusively that cleanup goals have been met.

          e.   Central Aquifer/Aberjona River Study

EPA's objective is to restore the central area aquifers to
drinking water quality.  This study is being.pursued in part in
response to the .number of coi^menters who have questioned whether
or not this objective is feasible.   The objectives of the study
were developed in order to investigate more fully the concerns
that were raised during the public coirjnent period.  They include,
but are not liir.ited to, the following:

     o    Defir. 2 the nature and extent of contamination in the
          Aberjona River.

     o    Define the upgradient introduction of contaminants to
          the Aberjona River.

     o    Refine the present understanding of the interaction of
          the Aberjona River and the aquifer systems on the Site.

     o    Evaluate the effectiveness of pump and treat as a
          remedial alternative for the cleanup of contaminated
          groundwater in the central area.

     o    Evaluate the impact of pumping the central aquifer
          on the Aberjona River and associated wetlands.

     o    Identify and evaluate innovative remedial technologies
          for aquifer restoration,  e.g., in-situ bioremediation.

     o    Evaluate the mobility of contaminants including semi-
          volatile organics and metals under ambient and pumping
          conditions.

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                                36

 This study will be developed  and  implemented during the predesign
 portion of the remedy.   The central aquifer and the Aberjona
 River will be addressed as a  separate operable unit and the
 remedy for the central.area and the Aberjona River will be
 selected in a separate  decision document.

      B.    Rationale for Selection

The  rationale for choosing the selected alternative is based on
 the  assessment of each  criteria listed in Section VIII, Part B.
 In accordance with Section 121 of CERCLA, to be considered as a
 candidate for selection in the ROD, the alternative must have
 been found to be protective of human health and the environment
 and  able to attain ARARs unless a waiver is granted.  In
 assessing the alternatives that net these statutory requirements,
 EPA  focused on the other evaluation criteria, including, short
 term effectiveness, long tern effectiveness, implementability,
 use  of treatment to permanently reduce the mobility, toxicity and
 volume,  and cost.   EPA  also considered nontechnical factors that
 affect the implementability of a  remedy such as state and
 community acceptance.   Based  upon this assessment, and taking
 into account the statutory preferences under CERCLA, and public
 comment  on the Proposed Plan, EPA selected the remedial approach •
 for  the  first operable  unit at the Site.

           1.    Source Control,

 The  selected source control remedy, SC-10, as well as SC-3, 4,
 and  11,  reduces risks to human- health and the environment by
 reducing VOCs, PCBs, PAHs, pesticides, and lead in soil and
 sludge to cleanup goals. The limited action soil alternative,
 SC-1,  is not protective of human  health and the environment.
 Because  soil alternatives SC-5, 7, 8, and 9 may require the use
 of institutional controls to  provide protection of human health
 and  the  environment, there is greater uncertainty as to their
 long term effectiveness and permanence.

 SC-3,  4,  10 and 11 reduce risks to human health and the
 environment through complete  destruction of the contamination,
 and  result in a permanent, protective cleanup that requires no
 long term management after cleanup goals are reached.  The long
 term effectiveness of soil alternatives SC-5, 7, 8, and 9 is less
 certain  as they may require the use of institutional controls,
 such as  access restrictions,  to achieve protection if cleanup
 goals cannot be met. SC-1 does not provide reliable protection,
 does not meet cleanup goals,  and  is not a permanent remedy.

 SC-10 and 11 use treatment to permanently reduce the level of
 toxicity of the contaminants  at the Site, to prevent the
 potential for contaminants .to move away from the source, and to
 reduce the volume, or amount, of  contamination at the Site.  SC-1
 would not treat or destroy any of the contaminated soil exceeding
 target levels and therefore would not achieve any reduction in

-------
                                37

toxicity, mobility or volume.  For all other source control
alternatives, except for SC-3 and 4, there is greater uncertainty
as to their ability to achieve the target levels for all
contaminants.                                           .         .

All alternatives except SC-1 pose short term impacts due to
excavation activities which require dust control to protect
workers and the community.  The alternatives that include in-situ
volatilization, SC-10 and 11, have fewer adverse effects since
they only require excavation of the mixed contaminant areas.

SC-1 is easily implemented since it does not involve any soil
excavation or treatment.  All other alternatives are feasible and
readily available technologies with the exception of SC-7 which
is an innovative technology and is not readily available.  The
most proven and corrjnonly used alternative is incineration (SC-3
and 4).  The enhanced volatilization (SC-8 and 9) and. high
temperature enhanced volatilization (SC-5) technologies have been
used to a lesser extent.  The in-situ volatilization process (SC-
10 and 11) has been used successfully at a number of sites to
treat volatile organics in soil to concentrations in the range of.
the proposed soil target levels.  There is less certainty that
alternatives SC-5, 7, 8, and 9 can achieve the target levels in
soil.

All of the technologies except for SC-7 are available in mobile
transportable units which can be transported to the Site.  There
is some uncertainty associated with the availability of capacity
of off-site permitted commercial incineration facilities (SC-4,
9, and 11) and therefore the implementability of these
alternatives is less certain.

Other than SC-1, SC-10 and 11 are likely to result in the least
adverse impacts on wetlands since excavation is minimized.  All
other alternatives (SC-3, 4, 5, 7, 8, and 9) require excavation
and filling of wetlands.  Because there is a practicable
alternative to construction in the wetlands area, and this
alternative satisfies the other evaluation criteria^ SC-3, 4, 5,
7, 8, and 9 would not meet the Wetlands Executive Order. In
addition, under the Massachusetts Wetlands Protection Act all
alternatives except for SC-10 and 11 require replication of the
wetlands that are lost due to excavation.  This is expected to be
difficult to do.

Alternative SC-4, off-site incineration, is the most expensive
remedial alternative at approximately $22 million  (see Table 12).
In general, none of the alternatives involving off-site
incineration (SC-4, 9, and 11) would be considered cost effective
as they are substantially more expensive than their on-site
counterparts and offer no additional reduction of risk to human
health and the environment.  SC-10, the chosen source control
alternative, is the least expensive alternative that will achieve
cleanup goals.

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                                38

           2.   Management of Migration

The management of migration portion of the remedial action is
designed primarily to  reduce the volatile organic contamination
in the overburden and/or bedrock aquifers of the five source
areas of contamination at the Site to drinking water standards as
quickly as possible.   It is also designed to prevent off-site
migration  of contaminants from the source areas.

Section VII, Documentation of Significant Changes, presents the
Agency's rationale for deciding to approach the cleanup of the
Site through-the implementation of operable units.  This ROD
addresses  the first operable unit of the Site, the five source
areas of contamination.  The central area and the Aberjona River
will be addressed as a separate operable unit.  Accordingly,
evaluation of the alternatives addressing the central area, i.e.,
MOM-3 (Pump and Treat  Central Area), and MOM-4 (Pump and Treat
Source Areas and Central Area), is not appropriate for this first
operable unit.  Alternatives for the central area aquifer cleanup
will be evaluated and  addressed in a separate decision document
following  the completion of further investigation of this area.
Therefore, the following discussion simply compares the MOM-1     '
alternative  (Limited Action) to the various treatment options
evaluated  for the MOM-2 alternative (Pump and Treat Source
Areas).

The selected management of migration remedy MOM-2, including
pretreatment and air stripping at separate treatment plants, will
reduce risks to human  health and the environment by reducing VOC
contamination in the bedrock and overburden groundwater.  While
the source areas will  be pumped with the objective of.achieving
MCLs there is some uncertainty in how- effective the bedrock
remediation will be.   Therefore, some residual bedrock
contamination may remain after the remediation period (see
discussion of groundwater cleanup goals Section X.A.l.b).  MOM-1
provides minimal protection of human health and the environment
by monitoring the contaminant migration downgradient of the Site.

For alternative MOM-1, although use of the aquifer would continue
to be restricted, the  future risk of exposure to groundwater
contamination remains.  MOM-2 would permanently reduce
contamination at the source areas.

MOM-2 will significantly reduce the toxicity, mobility, and
volume of  contaminants in the groundwater at the source areas.
MOM-1 does not provide extraction and treatment of contaminated
groundwater and therefore does not provide any reduction in the
toxicity, mobility, or volume of contaminants other than through
natural attenuation.

MOM-1 does not include any active remediation and therefore does
not present a risk to  the community or to workers at the site.

-------
                                39

 MOM-2 requires construction  of pumping systems and treatment  .
 plants.   Therefore,  protection and  controls will need to be
 provided to protect  the community and on-site workers using
 measures such as dust control, personal protection equipment, and
 air monitoring during construction  activities.

 MOM-2 will comply with all State  and Federal ARARs.  Treatment
 plants will be located outside of wetlands and floodplains to the
^extejit possible. -The limited action alternative MOM-1 would not
 attain ARARs.

 MOM-1 is easily implemented  since it does not involve any
 construction.  However,  while it  would be easy to implement, it
 does not use treatment to reduce  the toxicity, mobility, or
 volume of contaminants at the source areas, is not protective of
 public health and the environment,  and does not comply with
 ARARs.   For MOM-2, treatment plants can be easily constructed at
 the individual source areas.  All of the treatment technologies
 are well proven, reliable and available with the exception of
 UV/Cheraical oxidation:   UV/chemical oxidation is feasible and
 available, but is an innovative technology and may not be
 reliable for conditions at the Site.  While carbon adsorption is
 feasible and available,  it may not  be. reliable for the levels of .
 VOC contamination found in groundwater at all of the source
 areas.

 The preferred alternative MOM-2 is  the least expensive
 alternative for addressing the remedial action objective of
 achieving cleanup goals in the bedrock and overburden aquifers
 (see further discussion of cost in  Section XI.C.).


 XI.        STATUTORY  DETERMINATIONS

 The remedial action  selected for  implementation at the Wells G &
 H Site is consistent with CERCLA  and, to the extent practicable,
 the NCP.   The selected remedy is  protective of human health and
 the environment, attains ARARs and  is cost effective.  The
 selected remedy also satisfies the  statutory preference for
 treatment which permanently  and significantly reduces the
 mobility,  toxicity or volume of hazardous substances as a
 principal element.   Additionally, the selected remedy uses
 alternate treatment  technologies  or resource recovery
 technologies to the  maximum  extent  practicable.

      A.    The Selected Remedy is  Protective of Human Health and
           the Environment

 The remedy at this Site will significantly and permanently reduce
 the current and potential risks presently posed to human health
 and the  environment  by:

-------
                                40

     reducing PCBs, PAHs, VOCs, and pesticides in the soil  at  the
     source areas of contamination to cleanup levels, thus
     preventing exposure to contamination that may present  a risk
     to human health and wildlife;

     eliminating the leaching of soil contamination to the
     groundwater at levels in excess of groundwater cleanup
     goals;

     reducing the contamination in the bedrock and overburden
     aquifers in the vicinity of the source areas to cleanup
     levels;               .   .

     preventing off-site migration of contaminated groundwater
     from the source areas; and

     preventing further degradation of surface water in the
     Aberjona River by contaminated groundwater. from the source
     areas.

     B.   The Selected Remedy Attains ARARs

This remedy will r.eet or attain all applicable or relevant  and
appropriate federal and state requirements that apply to the
Site.  Environmental requirements which are applicable or
relevant and appropriate to the selected remedial action at the
Wells G & H  Site are:

Resource Conservation and Recovery Act (RCRA)

Toxic Substances Control Act  (TSCA)

Clean Water Act (CWA)

Safe DrinXing Water Act including the Underground Injection
Control Provisions at 42 U.S.C. Section 300(H)

Executive Order 11988 (Floodplain Management)

Executive Order 11990 (Protection of Wetlands)

Clean Air Act (CAA)

Protection of Archeological Resources

Occupational Safety and Health Administration  (OSHA)

Transportation of Hazardous Waste Regulations  (DOT)

310 CKR 30.00 - Hazardous Waste Management Requirements

-------
                               41

310 CMR 6.00 - Ambient Air Quality Standards for the Commonwealth
               of Massachusetts

310 CMR 7.00 - Air Pollution Controls

310 CMR 33.00 - Employee and Community Right to Know Requirements

310 CMR 10.00 - Massachusetts Wetlands Protection Requirements

314 CMR 3.00 - Surface Water Discharge Permit Program
               Requirements

314 CMR 4.00 - Surface Water Quality Standards

314 CMR 5.00 - Groundwater Discharge Permit Program

314 CMR 6.00 - Groundwater Quality Standards

310 CMR 9.00 - Massachusetts Water Ways Licenses

314 CMR 9.00 - Massachusetts Certification for Dredging and
               Filling

302 CMR 6.00 - Inland Wetlands Orders

314 CMR 12.00 - Operation and Maintenance and Pretreatment
               Standards for Wastewater Treatment Works and
               Indirect Discharges

Tables 8 and 9, taken from Section 1 of the Feasibility Study,
list the chemical specific ARARs and guidances to be considered
during the implementation of the remedy, present a brief synopsis
of the requirements, and outline the action which will be taken
to attain the ARARs.  Tables 10 and 11, taken from Section 4 of
the Feasibility.Study, identify the action specific and location
specific ARARs and guidances to be considered during the
implementation of the source control and management of migration
alternatives, present a brief synopsis of the requirements, and
outline the action which will be taken to attain the ARARs.

     C.   The Selected Remedial Action is Cost Effective

Once EPA has identified alternatives that are protective of human
health and the environment, and attain ARARs, EPA analyzes those
alternatives to determine a cost-effective means of achieving the
cleanup.  Each of the alternatives underwent a detailed cost
analysis to develop costs to the accuracy of -30 to +50 percent.
In that analysis, capital and operation and maintenance costs
have been estimated and then used to develop present worth costs.
In the present worth analysis, annual costs were calculated for
thirty years (estimated life of an alternative) using a five
percent interest rate factor and were based on 1988 costs.

-------
                                42

 For source control,  the combination  of  on-site incineration and
 in-situ volatilization is the least  costly method for soil
 remediation except for the limited action alternative (Table 12).
 However, the limited action alternative will not meet ARARs, and
 is not protective of public health and  the environment.  Thus,
 the selected source control component is a cost effective method
 of achieving protection of human  health and the environment.

~For the management of migration alternative, the treatment of
 groundwater at one central treatment plant, by both the air
 stripping and UV/cheraical oxidation  treatment technologies, is
 less expensive than treatment at  separate plants  (see Table 4).
 EPA believes, however, that the public  has raised valid concerns
 regarding the construction of a single  central treatment
 facility.  These concerns, discussed in Section VII and further
 documented in the Responsiveness  Summary, include the fact that
 construction of a single central  treatment facility would require
 that pipes be placed in a wetlands area, and that contaminated
.water be moved across uncontaminated areas of the Site.
 Therefore, EPA believes that construction of separate plants is
 the most cost effective option for groundwater treatment which
 does not potentially degrade the  wetlands area or spread
 contamination across uncontaminated  areas of the Site.
 Furthermore, treatment by air stripping at separate treatment
 plants is less costly than treatment by UV/chemical oxidation at
 separate treatment plants, and is therefore the most cost
 effective technology for achieving cleanup goals at the Site.

      D.   The Selected Remedy Utilizes  Permanent Solutions and
           Alternative Treatment Technologies or Resource Recovery
           Technologies to the Maximum Extent Practicable

 In-situ volatilization is an alternative treatment technology
 which provides permanent removal  of  the mass of volatile organic
 contamination in soil, thereby permanently and significantly
 reducing the toxicity, mobility and  volume of contamination.
 Contaminant reduction efficiencies of 99.999% have been achieved
 at other sites using in-situ volatilization.

 The incineration portion of the selected remedy also provides  for
 permanent destruction of the PAHs, PCBs, VOCs, and pesticide
 components in the soil.  Because  incineration uses high
 temperatures to destroy virtually all of the organic contaminants
 in the soil, the treated soil can be used to fill in excavated
 areas on Site.  Treated soil samples will be tested to confirm
 that the soil is acceptable as backfill.

 The groundwater extraction/treatment portion of the selected
 remedy also provides permanent removal  and reduction of the mass
 of volatile organic contaminants  in  groundwater through
 groundwater recovery and treatment via  air stripping and carbon
 adsorption.  Carbon columns will  remove contaminants from  the

-------
                                43

 airstream before being released to the atmosphere.  Treated
 groundwater will be discharged to the Aberjona River, reinjected
 to  the  aquifer, or both.

     E.   The Selected Remedy Satisfies the Preference for
          Treatment as a Principal Element

 The principal elements of the selected source control remedy for
 contaminated soil are in-situ volatilization and incineration.
 The principal elements of the selected management of migration
 remedy  for contaminated groundwater are air stripping and carbon
 adsorption.  These elements are all technologies that use
 treatment to address all human health and environmental threats
 at  the  Site resulting from contamination of soil and groundwater.


 XII.      STATE ROLE

 The Commonwealth of Massachusetts' Department of Environmental
 Protection has reviewed the various alternatives and has
 indicated its support for the selected remedy.  The Commonwealth
 of  Massachusetts has also reviewed the Remedial Investigations,   f-
 Endangerment Assessment and Feasibility Study to determine if the
 selected remedy is in compliance with applicable or relevant and
 appropriate State environmental laws and regulations.  The
 Commonwealth of Massachusetts concurs with the selected remedy
 •or the Wells G & H Site.  A copy of the declaration of
-concurrence is attached as Appendix C.

-------
                           WELLS G & H

                    Record of  Decision  Summary
Figure 1.
Figure 2.
Figure 3.
Figure 4.
Figure 5.
          LIST OF FIGURES

Site Location Map of Wells G & H in Woburn,  MA
Property Specific Source Areas at Wells G &  H
Wetlands Area at Wells G & H
Areas of Contaminated Soil at Wells G & H
Source and Central Area Pluses at Wells
G & H Site
Table  1.

Table  2.

Table  3.
Table  4.

Table  5.

Table  6.
Table  7.
Table  8.
Table  9.
Table 10.

Table 11.

Table 12.
           LIST OF TABLES

Chemicals of Potential Concern at the Source and
Central Areas at Wells G & H
Estimated Risks Associated With Exposure at Wells
G & H
List of Remedial Alternatives Analyzed
Costs Associated With Groundwater Treatment
Alternatives
Action Levels For Soil Based on the Leaching of
Contaminants From Soil into Groundwater
Action Levels For Soil Based on Direct Contact
ARAJ* Based Action Levels For Groundwater .
Chemical Specific ARAEs and TBCs
Chemical Specific"Potential ARARs and TBCs
Action Specific and Location Specific ARAJ?s and
TBCs for the Chosen Source Control Alternative
Action Specific and Location Specific ARARs and
TBCs for the Management of Migration Alternatives
Costs Associated With Soil Treatment Alternatives
                            APPENDICES
Responsiveness Summary
Administrative Record Index
State Concurrence Letter
                                        Appendix A
                                        Appendix B
                                        Appendix C

-------
WELLS G i H






  FIGURES

-------
f
           Figure [Site Location Map of Wells G and H in Woburn, MA
WILMINGTON
                                                              K
                                                              STONEHAM
               LEGEND

               S!!t Boundary
                                            T North

                                             Not To Scalt

-------
                        FIGURE  2
      SOURCE AREA MAP  FOR THE WELLS G & H SITE
                       V/OBURN, MA
                                       °//\\ PLASTICS
RILEY
TANNERY
PRODUCTION
WELL
                                              PROPERTY BOUNDARY
                                                (APPROXIMATE)

-------
                       FIGURE 3
WETLANDS AREA
                                               U.S. ENVIRONMENTAL
                                               PROTECTION AGENCY
                                                  WELLS G & H
                                                  FIGURE 1-5
                                          APPROXIMATE BOUNDARY OF THE
                                                 WETLANDS AREA
                                        EBASCO SERVICES INCORPORATED

-------
                               FIGURE  4
                AREAS OF CONTAMINATED SOILS
                            AT  WELLS G&H
                                              CONTAMINATED
                                                  SOIL
                                              IUC-7. UC-S. UC-17)
                                  NORTH
CONTAMINATED
                        WELLM  „
                                                       NEW
                                                       ENGLAND
                                                       PLASTICS
   COSTAMINATEO
      SOIL
   (REF. FIG. 3-JI
WILDWOOD
                                            CONTAMINATED
                                               SOIL
                                           (NE-SSVSS2.SS4.SS3
                                                   PROPERTY BOUNDARY
                                                   (APPROXIMATE)

                                                   LOCATIONS OF CONTAMINATED
                                                   SOILS AT VARIOUS PROPERTIES

-------
                                  FIGURE 5*
                       LOCATION OF SOURCE PLUMES AND
                   THE CENTRAL AREA AT THE WELLS G&H SITE
                     I
                              X
                                 WELL H

                                   CENTRAL AREA
                                            NEW ENGLAND PLASTICS
* This figure represents the approximate area of  groundwater contamination
  (Source: Feasibility Study, Appendix C, Figure  C-1)

-------
WELLS  G & H
   TABLES

-------
                        Table  1
Chemicals  of Potential  Concern  at  the  Wells  G&H  Site
ATILC OPCANICS
tone
jroform
-Dichlorobenzene
-DJchloroethone
-"Die hi oroe thane
-Dichloroethene
i~1 ,2-Dichloroethene
i/iene chloric*
lochloropheriol
-.ol
3Chloro«>hen«
en*
1 — Trichloroelhone
•iloroelnent
ij*Lpr,a-. -
*
-VOLATILE QSGANICS
n
2-eihylhe»yl)3ntho!ole
rdane
-DDT
aromolic hydrocarbons
chlorinated biphenylj
ne
'CAN1CS
nic
jm .
•nium
imiiim
>"

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LOCATION

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Ingest ion of Grcuiflwater
Inr.a'iaticn of Volatiles Released
•hi le Showering
New England Plastics Corporation
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Future Exposure to Surface Soil'
Wilovcc-3 Coiservatio" Cc-poration
Dermal Contact an; Incidental
Ingest ten of Sei 1
- Surface Set '•
- Northern Slucges
- Southern Slucges
Inhalation of Oust Generates
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-------
                           TASlE   2 CC
EJS::'J-E AT THE WELLS G
LO:ATI:N ' R<
. AVENGE
Wi lo«sod Conservation Corporation Continued
future Eiposure to Surface Soil
- Surface Soil 7E-07
- fcsrthern S'luCges EE-C5
- Scu'.we-n S.lucges • ' 2L-06
Fut.-'e !••••« lat ion of volatile* •
't 'eases f ror. So' 1
- S-.-fece So'l 3E-C7
- sc-t-e-n Si_::es 1E-07
- Sc.'.'e" S ''trees IE-OS
Future i"esticr, if G'Ou's-ate*1 EE-Gi
fut.re ;'-!•«•.•.:-. o* vclat i'.es 2E-C4
*e 'eases «.-. i'.« jic»e".-;
fcs^ssur-e A-ea e' We'>'ii G&H
!-^a'atlC- of Volatile* »eleaser 2E-OE
C.'i"; I'.r.st'ia'' P^-jesses
*•. I**" st^'a'1 ^c'^e^s
• ^e--a''ci'tait a-r'lr.: •. re-ta'i 2E-OS
!*:e st 'o" cf Sc • 1

S.*'a:e «ate'
• • A r u 1 1 s 4 E • 1 i
- C" i isre". • 2E-C9
Zc~<~.»': C:^:a;; ars jr.; oertal
'-'A;! Its " 2E-07
- C-^c-en 6E-C7
Futu*e ir'~estion e' G":-j"2»ater 4E-OS
f uti.'e .i';est icr. cf Gr:.-.r-a:er
Cc-ta-ri-j ?aric"u: 1 ices
- G-:IS A •;-£ Pa", it les
- G'oss Beta Particles
- Strcrt -.uff-50
- 7 r 1 1 IJB
- " a r i J~
• L - a • i (jf
F^t.'e >.-.a'at ic" c' volatiles 4E-06
rt '*4ie. .e . .-• • -g
i"""s:TE"
SK
Ptt'JSIBiE


2E-03 «1 (
IE-C3 <1 (
4E-04  1




•1
3E-CS «1


HAZA;: IKCEX
AGE MAX l MUM


0.01) >1 (3) -
:.3) »i (14)
0.2) ».l (20)


: c::9) 1 (116)'
C.CS) >1 (Se)


0.1) «1 (C 3!
.

: cj) 1 (3S)

C.6) >1 (4)
3E-04) 
-------
                            TABLE 3

           LIST OF ALTERNATIVES FOR DETAILED ANALYSIS


Source Control Alternatives (SC)

SC-1   • No Action (Source Control)

SC-3    Excavation?On-Site  Incineration/Backfill On-Site

SC-4    Excavation/Off-Site   Incineration/Backfill   with   Clean
        Off-Site Soil

SC-5    Excavation/On-Site  High Temperature Enhanced Volatiliza-
        tion/Backfill On-Site

SC-7    Excavation/On-Site  Supercritical Fluid Extraction/
        Backfi 11 On-Site

SC-8    Ercavation/On-Site  Enhanced Volati1ization/On-Site
        Incineration/Backfill On-Site

SC-9    Excavatibn/On-Site  Enhanced Volati1ization/Off-Site
        Incineration/Backfill With Treated and Clean
        Off-Site Soil

SC-10   In Situ Volati1ization/Excavation/On-Site Incineration/
        Backfill On-Site

SC-11   In Situ Volati1ization/Excavation/Off-Site Incineration/
        Backfill with Clean Off-Site Soil

Management of  Migration Alternatives (MOM)

MOM-1       No Action (Management of Migration)

MOM-2       Pump and Treat  Source Areas

   -2A(i)   Pretreatment  and  Air  Stripping at Separate Treatment
            Plants

   -2A(ii)  Pretreatment    and  Air   Stripping   at   a   Central
            Treatment Plant

   -2B(i)   Pretreatment  and  UV/Chemical  oxidation  at  Separate
            Treatment Plants

   -2B(ii)  Pretreatment  andUV/Chemical oxidation at a Central
            Treatment Plant

MOM--3       Pump and Treat  Central Area

   _3A      Pretreatment  and  Air Stripping  at Central Treatment
            Plant

-------
                       TABLE  3   (Confd)

            LIST  OF ALTERNATIVES  FOR DETAILED ANALYSIS
   -3B       Pretreatment  and UV/Chemical Oxidation  at  a Central.
             Treatment  Plant

   -3C       Pretrea~tment   and   Carbon  Adsorption  at  a  Central
             Treatment  Plant

MOM-4        Pump  and Treat Source Areas  and Central Area

   -4A(i)    Pretreatment  and Air Stripping at Separate Treatment
             Plants.

   -4A(ii)   Pretreatment  and Air Stripping at a Central Treatment
             Plant

   -4B(i)    Pretreatment  and UV/Chemical Oxidation at Separate
             Treatment  Plants

   -4B(ii)   Pretreatment  and UV/Chemical Oxidation at a Central
             Treatment  Plant

-------
      Table 4  Costs Associated with  Groundwater Treatment Alternatives
                                     (Total Present Worth Cost)
.
Alternative No. 1
No Action '
Alternative No. 2
Pump and Treat
Source Areas
Alternative No. 3
Pump and Treat
Central Area
Alternative No. 4
Pump and Treat
Source Areas and
Central Area
Air Stripping
Treatment at
Separate Plants
Treatment at One
"Central Plant
N/A
N/A "
$65.200.000 2
$27.400.000
N/A
$24,200,000
$79.100.000
$37.100,000
Ultraviolet (UV)/Chemical Oxidation
Treatment at
Separate Plants
Kitment at One
tral Plant
N/A
N/A
$89.100.000
$44.200.000
N/A
$28.200.000
$104.800.000'"
$60,200.000
Carbon Adsorption
Treatment at
Separate Plants
Treatment at One
Central Plant
N/A
N/A
N/A
N/A
N/A
$26.900.000
N/A
N/A
1. Total present worth cost of no-action: $440,000.
2. This is the preferred alternative for groundwater treatment.

Other Notes
Alternatives 2.3 & 4 have been costed to.30 years only- however,
  some alternatives may take longer than 30 years to complete cleanup.
Alternative No. 1 predicted to exceed 100 years to remediate.
Alternative No. 2 predicted to take 22 years for central area:
  20-50 years for source areas to remediate.
Alternative No. 3 predicted to exceed 50 years to remediate.
Alternative No. 4 predicted to take 10 years for central area. 20-50 years
 •>r source areas to remediate.

[See Appendix C in FS for detailed discussion of timetrames.)

-------
                                                      Table    5
                               AC'!?- LEVELS ros SC:L  AT  TH[ WELLS G & M SITE
                     BASED 0* THE LEACHING Of C3A.TW.MSTS  FKG« SOIL INTO GRO'J»GVATER

                                          A.  PCTENT1AL CASC I NO-JENS
                                                           CSISV.X-i WATER            TA5C-ET  SOIL
                                              is             STA.SCA;:               CCCSCESTSATI:
                                             V«;)            (rxj, 1)                   (u;/ig)
                                                                                          62. S
                                                                                          36.7
                                                                                          12  7
                                  KCC         Ki.          ::)N<;no WATER          •  TAPPET SOIL
                                 C'/»s)      (I/*;)           S:AS;A;;               CONCENTRATION
O'D'JNO                               '                       l^.'l)                  lug/kg)
trans-!.2-C-.c'-.lcroe:'.e'e        S SCE-C1.     5.S:E-01       7.COE.-02 ^CLG  (c)               83 2
l.l.l-T-icr.'.o'oef.«"e           1.S2E-02     1.S2E-0:       2.0CE-01 «CL.                    613
Aci'.on  le»«''i tases  or  t*«  atiamaeni :f-a  t^rge: ri»» !«««! in sails •men cs**es;5*ss to tne attainment of ASABs
(a) >*C!.  i*  for  tcta1  tr vr.alo^etr^nes,  r*fe"$  to tie Su* of cn'oroform.  bro«'r  tc* icc'io;.ical  encpo'nti.

(c) Proposed.

NOTE.   Scientific  notation (such as  2E-06)  n a shorthand nay of  indicating  Decimal  places,  (i.e.. trie ma;nitude
of the  nuT.EeO .  A  negative e»poner.t  mdica'.ej that tne deciir.*! snobld b« moved the  specified hunae- of places
to the  le't  (i.e..  2 4E-G3 • 0.002*   =  2.
 (Source:  Feasibility  Studyx Section  1.0,  Table  1-5)

-------
                                                Table  6
                                    A:T:CS IEVEI.S F:; S::L AT T*£  VEILS G i H SITE
                                       rc:j«E  USE CC.S::T:GNS FOS  DIRECT CON:ACT

                                                POTENTIAL CARCINOGENS
COMPOUND                                                   TARGET  SOU CONCENTRATION  (mg/kg)
                          PCTfKC*  FACTOR                           TASGET RISK LEVEL
                                                     10-4         10-5          1C-6*         10-7
Chlordane                   1.3CE.OO                6.14E.C2     614E-C!       6.UE-00       6.14E-CJ

4.4--05T                 -   3 4-:E-Ci              '  I  25J.03     I 35E-C2       Z.3SE-C1       2.2SE-OC
CPA.-.S                       :.is.r-c;                t  9<{-c:     6 ?«c-c:       e..94E-oi       6 94[-c?
P:BS                        7 ?:£.•:•:                i.c«E-c7     i.04E»ci       i.04E»oo       i.04E-oi
Action le»el»  based on t*e «tt«inm«nt  of  i target rn» level  for tne pstentul  c»reiioqer» and *  COI.RfO
of one for  tie noneireinojeni for e»pcjure to eor^oufC* in  tr>e  ioil via direct  contact (benrval contact «ith ana
• nd tncioental ingestion of soil);  e«?c»jre auj^Ttionj are presentee! in tr\« ensangerment assessment  and be'c"«.
GENERAL ASSUMPTIONS:  Body «tignt • 70 kg. Average lifetime  •  70 yrj; Eiposare period • 70 yrt;
Frequency of  eiposure • 100 d/yr; Incidental  ingestion rate  •  S4 mg/d; Dermal contact rate • 790 ng/d.

ASSUMPTIONS FW  PESTICIDES. PAHS. AND PCBS:   Injestion absorption factor • 0.3;  Dental absorption factor • 0.02.

ASSUMPTIONS FOR -VOLATILE OS&ANICS:  Ingestion absorption factor • 1.0; Dentul absorption factor  • 0.3.

ASSUMPTIONS FOR  INOBGANICS:  Ingestion absorption factor --1.0; Dermal absorption  (i negligible.

NOTE:   Scientific  notation (sucn as 2E-06)  is a shorthand «ay  of  indicating decimal places. (I.e.. the
magnitude of  the njrser).  A negative eisone'nt indicate- tMf.trie flecimal should t* moved the specified
njmoer of places to the left (i.e.. 2.4E-03 • O.OC24 =  2..4x10"')
 *  Cleanup  levels  for  the  Wells  G  S H Site are  based  on a  10    risk  level.

 (Source:   Feasibility  Study,  Section  1.0,  Table 1-6)

-------
                                             Table  7


                              ARM-BASED ACTION LEVELS FCS  GROUND-WATER

                                     A.   POTENTIAL CARCINOGENS
COMPOUND


Chl.sref CHB
1 . l-Dicnloroetf.a"e
1 .2-Cicrilci-cethane
l.l-C'chiorcethe^e
Tetrachlcroethene
Tr ic«lc'r-The-« '
V inyT Cnlor ioe
- OS iNSJNG WATER
STAN:AO M CRITERIA
(ug/1)
1C: M;L (a)
5 is)
s MCL

S (c)
5 MCL
2 M;L
INTAKE

(-SAs/d.y)
2 8SE-C3
1 43E-C4
1 4JE-C4
2 O:E-O<
1.43E-C*
1 43E-04
S.7:E-05
PCTENCT FACT£»

(^/kB/a.,)-l
6.10E-03
9 10E-C2
9. ICE -02
. S.S:E-CI
S.10E-02
1.10E-02
Z.3CE-00
RISK


1.7E-OS
1.3E-CS
1.3E-OS
1.2E-C4-
7.3E-05
1.6E-06
1.3E-04
                                         hCsCAs;IMOGENS
COf?0'JN3
«;NG WATER
ti;: os CRITERIA
("9/D
R-EFESENCE  D:SE  RATIO OF
   (Rf:i       INTAKE TO
           )      RfO
trar.s-1.2-Dichloroet
1.1.1-Trichloroethane
                                   70 MCI 6 (d)
                                 200 MCL
                  2 OOE-03
                  5.71E-03
   1.02E-02
   9.00E-02
2.COE-01
6.35E-02
^il  MCI i* for totil tr ihj lonetf-jnes. rtferj to tr>«  JI/T of chloroform.
brcxrod iCMloromethan*. diBromocrilorometrune. »no bromofonn.

\C)  MCL is for l.^-Oicriloroet^an*.   This value MAS used based on the chemical
similarities between the two compounds and their toncological endpoints.

(c)  MCL is for trichloroethene.   This value was used based on the chemical
similarities cet-een the two compounds and their lexicological endpoints.
Trr.s value is a'sc the CLP detection  limit.
(d) Proposed.

NOTE:  Scientific notation (such as 2E-06)  is a shorthand «ay of  indicating decimal
places, (i.e.. the "viarirud* o* »he numter).  A negative eiponent  indicates that  tne
deciir^l should be moved the specified numoer of places to the  left
(i.e.. 2.4E-03 - 0.0024 =  2.4x10"3)
(Source:   Feasibility  Study,  Section1.0,  Table  1-4)

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                                                                         TABLE  8

                                                           CHEMICAL - SPECIFIC ARARS AND TBCS FOR
                                                           WELLS OW  SITE. WOOURN. MASSACHUSETTS
            JtQUlRLHLNL
                  REQUIREMENT SWOPSLS_
                                                                                                    ACTION TO BE TAKEN TO ATTAIN REQUIREMENT
I)  ARAPS

    0   OWA - Maximum Contaminant
       Level* (MCLs) (40 CFR
       141.11 -I41.16)2
    0  RCRA - Haul MUM Concentrator!
       Limit (MCLS) (40 CfR 264.94)2
IE!- Mass*
>Jt M>.:_
    0  DCQEl- Massachusetts Drinking
       Water^Manimum Contaminant Levels
       (MCL) (310 CMR 22.00|2

    0  DEQE - Massachusetts Groundwater
       Quality Standards (314 CMR 6.00)2
    0  CWA - Ambient Water Quality
       Criteria (AWQC) - Protection of
       Freshwater Aquatic Life,  Human
       Health - Fish Consumption
2)  TBCS
    o  fPA Risk Reference Ooset
       (RfOs)
    o  EPA Carcinogen Assessment
       Group Potency Factors
    o  Massachusetts  Drinking Water
       Malth Adviseries
MCLS have been promulgated for a number of common
organic and Inorganic contaminants.  These levels
regulate the concentration of contaminants in
public drinking water supplies, but nay also
be considered relevant and appropriate for
groundwater aquifers potentially used for drinking
water.

RCRA MCLS provide groundwater protection
Standards for 14 comron contaminants.  All .
are equal to the SOWA MCLs for those contaminants.

Massachusetts MCLs establish levels of
contaminants allowable in public water supplies.
They are essentially equivalent to SOWA MCLs.

These standards consist of. groundwater
classifications which designate and assign the
uses of Connonwealth groundwaters. and water
quality criteria necessary.to substain these
uses.  There is a presumption that all
groundwaters are Class I.

AWQC are developed under the Clean Water Act (CWA)
as guidelines from which states develop water
quality standards.  A xnre striqent AWQC for
aquatic life tyiy be found relevant and appropriate
rather than an MCL, when protection of aquatic
organisms is being considered at a site.
o  RfOs are dose levels developed by the EPA for
   noncarcinogenic effects.


0  Potency Factors are developed by the EPA
   from Health Assessments or evaluation by the
   Carcinogen Efforts Assessment Group.

o  DFQC Health Advisories are guidance criteria
   for drinking water.
                                                        o  Treatment will bt conducted to achieve SOWA MCLs in
                                                           groundwater.
                                                        o  Treatment Mill bt conducted to achieve RCRA MCLs in
                                                           groundwater.
                                                        o  Since DEQE MCLS art the same as SDWA MCLs, they
                                                           were used to set clean-op levels for contaminants
                                                           of concern.

                                                        o  OEQC groundwater standards were considered when
                                                           determining clean-up levels.
                                                        o  AWQC were used to characterlie risks to fresh water
                                                           aquatic life resulting from discharge of treated
                                                           groundwater to the Aberjona River.
                                                                                           o  EPA RfDs  were used to characterise risks due to
                                                                                              exposure  to contaminants In groundwater, as well
                                                                                              as other  media.

                                                                                           o  EPA Carcinogenic  Potency Factors were used to
                                                                                              compute the individual incremental cancer risk
                                                                                              resulting from exposure to site contamination.

                                                                                           o  DEQE Health Advisories were considered when
                                                                                              developing clean-up levels for groundwater.

-------
                                                                         TABLE 9
                    CHEMICAL-SPECIFIC POTENTIALLY APPLICABLE OR RELEVANT AND APPROPRIATE REQUIREMENTS AND "TO BE  CONSIDERED"  REQUIREMENTS
1,1-Oichloroethene
1,I,1-Trichloroethane
trans-1,2-0«chloroethtne
Tetrachloroethene
Trichlorr-'lhene
'hlorofoi
trich)ore luoroethane
 lethylent- chloriJ«
Zarbon teirachloride
 •ara-Oichlorobeniene
 'ichlorobentenes
:,l-Dichloroethane
 ,2-0ichloroethane
 ,2,4-Trichlorobeniene
 'inyl Chloride
 ..ZrDichlorobeniene
 •enxene
 oluene
 cetone
 iethyl ethyl ketone (MCK)
 thylben/ene
 ylene
 iyrtne
Saft Drinking Water Act
Maxinum Contaminant
Levels
0(C)
               I.100/760(c'

             118.000/20,000(c)
 1.120/76 »(c)
 5.300/-<<>
I7.500/-'c'
                                                   32.000/-'c>
                                       6.94
                                                                                     2,600
                                                                                     2.600
    243

    525
  2,600
     40
424,000
                                   3,250
                    Massachusetts Drinking
                    Water Maxima Contami-
                    nant Levels (e)
                    (310 CMR 22.OQ)
7
200
70"
0"
0
1
ll.600/-
-
_
5.280/840'c*
45. 000/21, 900'C>
28. 900/1. 24fl'c'
1.85
1.030.000
_
8.85
80.7
15.7
7
200
-
«.
5
100(a)
                             5
                            75
5

2

5
 11  values  in  ug/1  unless otherwise noted

-------
                                                                     TABLf   9 (Cont'd)
                                                                   •i..              '                                     •   .    •   .
                    CHEMICAL-SPECIFIC POTENTIALLY APPLICABLE  OR  RELEVANT  AND APPROPRIATE  REQUIREMENTS  AND  "TO  BE  CONSIDERED"  REQUIREMENTS
                                Safe Drinking Water Act
                                Maxtnuii Contaminant
                                Levels
                                LfjC.Hl 40 CFR Ml
                   Saft Drinking Water Act
                   Maxinun Contaminant
                   Level Goals (MCLGs)
                   40 CFR 141 t 5Q TR 16936
 Carbon Disulfide
 Phenol
 Naphthalene
 2-Htthylnaphthalene
 dibutyl  phlhalaU
 diethyt  phthalate
 bis(2-ethylhe»yl)phtha1ate
'Acenaphthylene
 Acenaphthene
 Phenanthrene
 Fluoranlhene
 Chrysene
 2-Methyl phenol
 4-Mcthyl phenol
 2.4-0imethyl phenol
 2-Hexane
 4-L'thyl-2-pentanone
 Trichloroisocyanuric acid
 Chlordane
 Polychlorinated Biphenyls
 Arsenic
 ChroniuM
SO
  0
  0"
 50'
120'
                 Clean Water Act
                 Water Quality
                 Cri teria for Fresh-
                 Water Aquatic Life
                 Acute/Chronic	
                                            10.200/2.560

                                             3.980/-'£)



                                             2.120/-'c>
                                                 2.4/0.0043
                                                 2.0/0.014
Clean Water Act
Water Quality
Criteria for Huaan
Health - Fish
Consumption	
Massachusetts Drinking
Water Maxinun Contami-
nant Levels (e)
    (310 CHR 2Z.OQ1
                                                                              154.000
                                                                            1.800.000
                                                                               50.000(h'
                                                      54
                                             1.700/2IO(d>(9)
           .00048
          0.000079
           .0175
  3.433.000*9)
       50
       50
All values  in ug/1  unless otherwise noted

-------
                                                                     TABLE   9  (Cont'd)
                                                                    «JL.
                    CHEMICAL-SPECIFIC POTENTIALLY APPLICABLE OR RELEVANT AND APPROPRIATE REQUIREMENTS AND "TO BE CONSIDERED"  REQUIREMENTS
Bariua
Hercury
Lead
CaJmiu*
Manganese
Zinc
Iron
Cadmium
Copper
ticket
Saf« Drinking Water Act
HaKimu« Contaninant
levels
(HCLs) 40 CFR HI

     1000
        2
       50(5")
       10
       10
    1.300-
Saft Drinking Water Act
Maximuo Contaminant
Level Goals (MCLGs)
40 CFR HI t 5Q f"J&9J6.

         1500"
            3"
       20"(0*)
            5"
        1.300-
                                                                                   Clean Water Act
                                                                                   Water Quality
                                                                                   Criteria for Fresh-
                                                                                   Water Aquatic Life
                              Clean Wattr Act
                              Water Quality
                              Criteria for Hui
                              Health - Fish
2.4/0.012
82/3. 2(d)
0.146
                                                                                   100
                                                   I20/I10(d'
                                                   1.000.
Massachusetts Drinking
Water Maximum Contami-
nant Levels (e)
    1310 CMR 22.001

        1,000
            2
           50
           10
                                                                                         10
18/12 ^
1.400/160
                                                                                  100
    values in ug/1 unless otherwise  noted.
•  -  Proposed MCL or MUG (1988)  (53  FR  31516)
•• -  Proposed MCLGs SO FR 46936  (November  13.  1985)
(a)   MCL for total trihalonelhane  concentration
(b) '  Chrowiun «6              ,
(c)   Lowest Observed Effect  Level
(d)   Hardness dependent criteria  (100 *g/1 used)
(e)   As of  8/31/1988
(f)   Value  shown is for (pent)arsenlc.   (trl)arsenic  Is 360/190 ug/L.
(g)   (tritchromium
(h)   Value  shown is for di-2-ethylhexylphthalate.

-------
                                                                     TABLE 10
                                                          u~.
                                     ACTION-SPECIFIC AND LOCATION-SPECIFIC  ARABS AND TBCS FOR ALTERNATIVE SC-IO:
                                       IN-SITU VOLATILIZATION/EXCAVAUON/ON-SITE INCINERATION/BACKFILL ON-SITE
                                                       WELLS G&H SITE. WOUURN, MASSACHUSETTS
        REQUIREMENT
                                 REQUIREMENT SYNOPSIS
                                                                                                             ACTION TQ BE TAKEN TO ATTAIN REQUIREMENT
I)   Action-Specific  ARARs

    o  RCRA - General  Facility
       (40  CFR 264.10-264.18)2
                           Requirements  o
o  RCRA Incineration Requirements
   (4(J CfR 264 Subpart 0)z
o  TSi'A - PCB Incineration
   Requirements
   (10 CFR 76l.70(a)(2).(b)>

o  RCRA - Generator and Transporter
   Responsibililies
   (40 CFR 262 and 263)Z

o  RCRA - Land Disposal Restrictions
   (40 CfR 268)*
General facility requirements outline general
waste security measures, inspections, and training
requi rements.

Principal  Organic Hazardous Constituents
(POHC) are to be destroyed to 99.99 percent
destruction and removal efficiency, stringent
particulate and HCL limits are imposed.

Contaminated soil in excess of SO pp« PCB
concentration must be incinerated to a 99.9999
percent destruction efficiency.

Provides standards for packing and accumulating
hazardous  waste prior to off-site disposal.
                  Provide treatment standards and schedules
                  governing land disposal of RCRA wastes and of
                  materials contaminated with or derived fro*
                  RCRA wastes.
                                                                       o  Facilities Mill be constructed,  fenced, posted,  ant
                                                                          .operated in accordance with  this  requirement.  All
                                                                          workers will be properly trained.

                                                                       o  On-site incineration activities will be designed
                                                                          and operated in compliance with Subpart 0.
                                                                                                    o  Appropriate technology will be employed to achieve
                                                                                                       the 99.9999 percent TSCA destruction requirement.


                                                                                                    o  Decontamination and scrubber water and carbon
                                                                                                       adsorption waste management and off-site disposal
                                                                                                       will proceed in accordance with RCRA requirements.

                                                                                                    o  On-site incinerators will be designed in accordant
                                                                                                       with standards to allow site-specific RCRA delistit
                                                                                                       of material.
0  RCRA - Container Require!
(40 LFR 264 Subpart I)2
   cnts
o  DOT - Transportation of  Hazardous
Waste Requirements
(49 CFR I71-I79)2
I
                                               Thl* regulation sets forth RCRA requirements for
                                               use and management of containers at RCRA
                                               facilities.

                                               Those regulations set forth DOT requirements for
                                               transportation of hazardous waste.  These are
                                               generally identical  to (USA requirements at
                                               40 CfK i-'()3.
                                                     0  Packing and accumulation of excavated soil treatmei
                                                        sludges and other materials will adhere to these
                                                        standards.

                                                     o  All  on- and off-site transport of excavated soil
                                                        treatment sludges, and other materials will follow
                                                        these standards.

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                                                                   ^  TABLE  10   (Confd)

                                            ACTION-SPECIFIC  AND  LOCATION-SPECIFIC  ARABS AND TBCS  FOR ALTERNATIVE  SC-10:
                                              IN-SITU  VOLATILIZATION/EXCAVATION/ON-SITE INCINERATION/BACKFILL ON-SITE
                                                              WELLS  GtH  SHE. WOOURN. MASSACHUSETTS
               JtQUJBUItUI.
                                                           REOUIREHLNT SYNOPSIS
                                                                 ACTION TO BE TAKEN TO ATTAIN REQUIREMENT
CD
o
       0  RCRA - Tank Requirements
          (40 CFR 264 Subpart J)
0  RCRA - Preparedness and Prevertion
   (40 CFR 264.30 - 264.31)2

0  RCRA - Contingency Plan and
   Emergency Procedures (40 CFR
   264.50 - 26-1.56 )Z

o  RCRA - Manifesting, Recordkeeping.
   and Reporting (40 CFR 264.70 -
   264.?7)z

o  RCRA - Closure and Post-Closure
   (•10 CIR 264 Subpart G)z


0  OSMA - General Industry Standards
   (29 CFR I9IO)1
       o  OSIIA - Safety and Health Standards
          (29 CFR 1926)'
       o  OSMA - Recordkeeping,  Reporting ant
          Related Regulations  (29 CFR  1904)'
o  Provides design and operating requirements
   for RCRA wast* treatment facilities utilizing
   tanks.

o  This regulation outlines requirements for safety
   equipment and spill control.

o  This regulation outlines the. requirements for
   emergency procedures to be used following
   explosions, fires, etc.

0  This regulation specifies the recordkeeping and
   reporting requirements for HCRA facilities.
o  This regulation details the specific requirements
   for closure and post-closure care of hazardous
   waste fdciIi t ies.

o  This regulation specifies the 8-hour, time-
   wriijhted average concentration for various organic
   compound* and 2 PCB compounds; site control pro-
   cedures; training; and protective clothing re-
   quirements for worker protection at site reme-
   diations.

0  This regulation specifies the type oF safety
   equipment and procedures to be followed during
   construction and excavation activities.

0  The regulation outlines the recordkeeping and
   reporting requirements for an employer under OSHA.
                                                                                                 o  Design and operation of the In-situ volatilization
                                                                                                    facility will follow these requirements.
                                                                                                           On-stte facilities and activities will be designed
                                                                                                           and operated in accordance with RCRA requirements.

                                                                                                           Emergency procedures will  be developed and imple-
                                                                                                           mented in accordance with  RCRA requirements.
                                                                                                           Records will  be Maintained during sit* remediation
                                                                                                           in compliance with this requirement.
Hazardous waste facilities will be closed in a
•anner that meets the requirements of the closure
regulations.

Proper respiratory equipment will be worn IF it is
not possible to maintain the work atmosphere below
these concentrations.
                                                                                                    All  appropriate safety equipment will  be on-sitt and
                                                                                                    procedures  will be followed  during groundwater
                                                                                                    monitoring  and  excavation.
                                                                                                                                                   i
                                                                                                    These  regulations  are applicable to the company
                                                                                                    contracted  to execute site  remediation.

-------
                                                               TABLE   10  (Cont'd)
                                                               «L.
                                    ACTION-SPECIFIC AND LOCATION-SPECIFIC ARABS  AND TBCS  FOR  ALTERNATIVE  sc-io:
                                      IN-SITU VOLATILIZATION/EXCAVATION/ON-SHE  INCINERATION/BACKFILL ON-SITE
                                                       WILLS GIH  SITE,  WOHURN. MASSACHUSETTS
       JLQUJJCJ1EHL
                                                                ACTION TO BE TAKEN TO ATTAIN REQUIREMENT
   DEQE - Hazardous Waste Manage-
   ment Requirements
   I VI0 CMR 30.00)Z
   DEQE - Hazardous Waste Incinerator
   Air Emisson Requirements
   310 CMR 7.0B(4)Z
   These regulations provide comprehensive
   monitoring, storing,  recordkeeping,  etc.  programs
   at hazardous waste sites.
   Provides air emission requirements  for  hazardous
   waste incinerators.   Principal  Organic  Hazardous
   Constituents (POHCS)  destroyed  to 99.99 percent,
   PCBs to 99.9999 percent.   Paniculate.  HCL  and
   CO emissions also controlled.
                                                                                                   During remedial  design,  these regulations  will  be
                                                                                                   compared to the  corresponding federal  RCRA regula-
                                                                                                   tions, and the rare, stringent requirements will  be
                                                                                                   uti.lized.   Note  that Massachusetts considers soil
                                                                                                   contaminated in  excess  of  50 ppm PCBs  to be a
                                                                                                   hazardous  waste  (310 CMR 30.131.  waste m)02).

                                                                                                   On-site incineration activities  to be  designed  and.
                                                                                                   operated in compliance  with requirements.
   TSCA - Marking of PCBs  aqd  PCB  Items
   (40 CFR 761.40 - 761.79)'
6  50 ppm PCB storage areas,  storage  items,  and
o  TSCA - Storage aqd Disposal  MO  CFR   o
   761.60 - 761.79)'
0  TSCA - Records and Reports  (40 CFR
   761.18-761.185)'
0  CAA - National Air Quality  Standards  o
   for Total Suspended Particulates
   (40 CfR 129.105.  750)1

o  DEQE - Ambient  Air  Quality       o
          Standards  for the Common-
                          >achusetts1
0  OEQE - Air Pollution Control S   ..
                    (310 CMR 7.00)  '
transport equipment must be marked with  the  M|_
mark.

This requirement specifies the requirements  for
storage and disposal/destruction of  PCBs  in  excess
of SO ppm.  These PCB-contaminated soils  would have
to be disposed of or treated in a facility permitted
for PCBs, in compliance with TSCA regulations.
Treatment must be performed using incineration or
som«» other method with equivalent destruction
efficiencies.

This regulation outlines the requirements for
recordkeeping for storage and disposal of >50 ppm
PCBs.

This regulation specifies maximum primary and
secondary 24-hour concentrations for particulate
matter.

This regulation specifies dust, odor,  and noise
emissions fron construction activities.
                                           Regulates new sources of air pollution to prevent
                                           air quality degradation.  Requires the use of "Best
                                           Available Control Technology" (HACT) on all  new
                                           sources.
                                                                                                   All  storage areas,  drums,  and  transport equipment
                                                                                                   will  carry the appropriate Markings displayed in an
                                                                                                   easily readable position.

                                                                                                   Storage areas  for drums  containing PCB soils  in
                                                                                                   excess of  50 ppm will  be constructed to comply with
                                                                                                   this  requirement.   Verification  of incinerator
                                                                                                   compliance will  be  made  prior  to drum shipment.
                                                          Records will be maintained during remedial action in
                                                          compliance with this regulation for all PCB drums
                                                          which contain soils in excess of SO ppm.
                                                          Fugitive dust emissions from site activities
                                                          maintained below  ISO ug/tr* (secondary standard)
                                                          water sprays and  other dust suppressants.
                                                                                                                                                 ill  be
                                                                                                                                                 )  by
                                                       o   Fugitive dust will be controlled by water sprays or
                                                           suppressants.  All equipment will be maintained so
                                                           as not  to produce excessive noise.

                                                       o   BACT will be used on all new sources.

-------
                                                                    TABLE  10    (Cont'd)
                                                                  u~.

                                        ACTION-SPECIFIC AND LOCATION-SPECIFIC ARABS AND TBCS FOR ALTERNATIVE SC-10:
                                          IN-SITU VOLATILIZATION/EXCAVATION/ON-SITE INCINERATION/BACKFILL ON-SITE
                                                           WELLS G&H SITE. WOBURN. MASSACHUSETTS
           _8tQUlBfJltBL
                 REQUIREMENT SYNOPSIS
                                                                                                             ACTION TO BE TAKEN TO ATTAIN REQUIREMENT
       Employee and Community Rlgbl-to-Know
       Q»n.,ir».u.ntc Mid fMO IT*'1'
       Requirements (310 CMR 33)
   Establishes rules for the dissemination of'
   information related to toxic and hazardous
   substances to the public.
o  Information dissemination procedures
   in these regulations Mill be used.
2)  Action-Specific TBCs

    0  RCRA - Proposed Air Emission
       Standards for Treatment Facilities
       (52 (R 3748. February 5. 1987)
3)
    o  RCRA - location Standards
       (40 CFR 264.18)'
    o  CWA - Section 404 Dredge  and  Fill
       Requirements
       (Guidelines at 40 CFR  230)'
    o  Massachusetts Wetlands  Protection
       Requirements
       (310 CMR 10.00)'
   This proposal would set performance standards for
   RCRA treatment facility air emissions.
o  This regulation outlines the requirements for con-   o
   structing a RCRA facility on a 100-year floodplain.

   A facility located on a 100-year floodplain must bt
   designed, constructed,  operated,  and maintained to
   prevent washout of any hazardous waste by a 100-year
   flood, unless waste may be removed safely before
   floodwater can reach the facility, or no adverse
   effects on human health and the environment would
   result if washout occurred.

O  The placement for fill  following excavation of       o
   contaminated soil pursuant to remediation activities
   in the Aherjona River wetlands triggers Section
   404 jurisdiction.  The governing regulations favor
   practicable alternatives that have less impact
   on wetlands.  If no mitigated practicable
   alternative exists, impacts must be Mitigated.

o  'These requirements control regulated activities      o
   in freshwater wetlands, 100-year floodplains,
   and 100-foot buffer tones beyond these areas.
   Regulated activities include virtually any
   construction or excavation activity.  Perfor-
   mance standards are provided for evaluation of
   the acceptability of various activities.
   Volatilization facilities and other non-Incinerators
   that have air emissions (e.g., air strippers) will
   be designed to meet the proposed federal regulations.
   It Is assumed that remediation facilities will bt
   located outside floodplains.  Temporary staging
   areas or remediation facilities that art located in
   a floodplain will  be a designed to allow quick mobi-
   lization out of the area and to prevent damage caused
   by initial  floodwattrs.
   Under this alternative no excavation will occur In
   Section 404 wetlands.  Soil contamination In such
   areas will bt remediated using in-situ volatilization
   which dots not require, excavation and subsequent
   filling.
   Under this alternative, no excavation will occur In
   the regulated wftlands:  Excavation of contaminated
   soil may occur In the wetlands buffer zone.  In this
   case, the alternative will meet performance standards
   for activities in tht buffer lone.

-------
                                                                       TABLE  10   (Cont'd)
                                                                   UL..
                                           ACTION-SPECIFIC AND LOCATION-SPECIFIC ARARS AND TBCS FOR ALTERNATIVE SC-IO:
                                              IN-SITU VOLATILIZAUON/EXCAVATION/ON-SITE INCINERATION/BACKFILL ON-SITE
                                                              WULS G&H SITE. WOOURN. MASSACHUSETTS
                                                                JEQUlRErlENT SYNOPSIS
                                                                ACTION TO BE TAKEN  TO ATTAIN  REQUIREMENT
       o  Wetlands Executive Order
          - rrqulalions develop procedures for the
   protection of archaeological  resources.
o  No excavation will occur in Section 404 wetlands.
   This is the best practicable alternative for
   treating contaminated wetlands.
   Excavation and filling are temporary disruptions, and
   filling will Match preconstruction topography,  thus,
   there is no permanent disruption of floodplatn
   values and the ARAR will be net.
   If archaeological resources are encountered during
   excavation, work will stop until the area has been
   reviewed by federal and state archaeologists.
CO
   'Applicable.

   ^Relevant and Appropriate

-------
                                                                       TABLE  11

                                        ACTION-SPECIFIC  AM) LOCATIOH-SPECIFIC ARARS AM) TBCS  FOR MOH ALTERNATIVES:

                                          HOH-2        Pump and Treat Source Areas
                                                      -  2B(i)   Prelreatnfnl and UV/Chemlcal  Ovidatlon at Separate Treatment Plants
                                                      -  2B(ii)  Pretreatnrnt ind UV/Chemical  Oiidation at a Central Treatment Plant

                                          MOH-3        Pump and Treat Central Area
                                                      -  3B      Pretreattwnt and UV/Che«ical  Oiidation at a Central Treatment Plant

                                          MOM—4        Pump and Treat Source Areas and Central  Area
                                                      -  4fl(i)   Pretre«t«rnt and UV/Chmical  0«idation at Separate Treatment Plants
                                                      -  iB(ii)  Pretreattvnt and UV/Chr«ical  Oxidation at a Central Treatment Plant

                                                          WTllS  GIH SITE.  WOflUBN. MASSACHUSETTS
«)
           -BLQUIRLMLML
                                                                                               ACTION TO BE IAKEH TQ ATTAIN RCQUlfiEMCNT .
       RCHA
       (40  CfH
- General  Facility Requirements  o  Central  facility  requirenrnti outline, qeneral
FR 264.10-264.10)'                  watte security aeatures, inspections; and training
                                   requirenents.
                                                    o  Facilities Mill  be  constructed, fenced, posted, and
                                                       operated In accordance with this requirement.  All
                                                       workers will  be  properly trained. ,
    o  PCRA  - Generator and Transporter
          onsibilities (40 CFR 262 and
    o  RCBA  - Preparedness and Prevention
       (40 CFR 264.30 - 264.3I)2

    o  RCRA  - Contingency Plan and
       Emergency Procedures (40 CFH
       264. SO - 264.56I2

    o  RCRA  - Manifesting. Recordkeeplng,
       and Reporting (40 CFB 264.70 -
             2
       264.
       (40 CFR 264 Subpa
           ••quirt
           rt I).2
                               tnts
                                •  Provides  standards for packing and accumulating
                                   haiardous vaste prior to off-site disposal.
                                   This  regulation outlines requiri
                                   equipwnt  and  spill control.
                                 rnts for safety
                                   This  regulation outlines the requirements  for
                                   energrncy  procedures to be used to)loving
                                   enplosions,  fires, etc.

                                   This  regulation specifies the recordkeeping and
                                   reporting  requir»*ents for RCRA facilities.
This regulation tetf  forth RCRA requirements for
use and management  of  containers at HCRA
facilities.
                                                    o  Pretreatment.  sludge management and off-site disposal
                                                       will  proceed  In  accordance with RCRA requirements.
0  On-sltt facilities and  activities will be designed
   and operated in accordance  with RCRA requirements.

o  Emergency procedures  will be  developed and Imple-
   mented in accordanct  with RCRA requirements.
                                                    o  Records  will be maintained during site remediation
                                                       In compliance with this requirement.
o  Packing and accumulation of  treatment sludges and
   other materials will  adhere  to these standards.
      RCRA  -  Land Disposal  Restrictions     o
      140 ffB ?«,(!>£
      (40  CfR
                                   Provide treatment  standards  and schedules
                                   governing land disposal  of RCRA wastes and of
                                   •ulenals contaminated with  or  derived fro«
                                   RCRA wastes.
                                                         On-site treatment will be conducted
                                                         in  accordance  with standards to allow
                                                         site-specific  RCRA delisting of material.

-------
                                                                TABLE  11  (Cont'd)
                                     ACTION-SPECIFIC  AND  LOCATWN-SPECMC ARABS AND TBCS FOR MOM ALTERNATIVES:
                                        MOM-2
                                        MOM-3
                                        MOM-4
        Putip and Treat Source Areas
        -  2B(i)   Pretreatment and UV/Chemical  Oxidation at  Separate Treatment  Plants
        -  2B(ii)  Pretreatnent and UV/Che«ical  Oxidation at  a Central  Treatment Plant

        Pump and Treat Central Area
        -  3B      Pretreatnent and UV/Che«ica1  Oxidation at  a Central  Treatment Plant

        Pump and Treat Source Areas and Central  Area
        -  4fl(i)   Pretretment and UV/Chenical  Oxidation at Separatt Treatment Plants
        -  48(ii)  Pretreatnent and UV/Che«ical  Oxidation at  a Central  Treatment Plant
       _BIflU_lRiMINJ_
            WELLS  GtH  SITE,  W06URN, MASSACHUSETTS

               REQUIREMENT  SYNOPSIS	
o  Massachusetts Wetlands Protection
   Requirements
   (310 CMR 10.00)
o  Massachusetts Waterways  licenses
   (310 CMR 9.00)'
0  Massachusetts Certification  for
   Dredging and Filling
   (314 CMR 9.00)'
These requirements control regulated activities
in freshwater wetlands. 100-year Moodplains,
and 100-foot buffer tones beyond these areas.
Regulated activities include virtually any
construction or excavation activity.  Perfor-
rvmce standards are provided for evaluation of
the acceptability of various activities.
Controls dredging, filling,  and other work
in water of the Commonwealth.
Establishes water quality-based standards  for
filling activities (CWA Section 401).
         ACTION  TQ  BE  TAKEN  TO ATTAIN  REQUIREMENT
                                                                                                   botto* contours.  These actions meet the ttrws of
                                                                                                   tht U.S. Amy Corps of Engineers Nationwide Permit
                                                                                                   No. 12 (33 CFR 330.5(a)(12)).  This permit providts
                                                                                                   authorization under Section 404 for discharge of
                                                                                                   material for backfill or bedding for "utility lines",
                                                                                                   provided there is no change in preconstruction
                                                                                                   bolto" contours.  A "utility line" is defined as A
                                                                                                   pipe for the transportation of any liquid for any
                                                                                                   purpose.
o  Extraction pipes will be laid underground
   through regulated wetlands, floodplains, and buffer
   tones.  This will not cause loss of flood storage
   capacity, and will only temporarily disturb wetlands.
   The performance standards of the regulations will
   therefore be achieved.  All treatment facilities will
   be constructed above the 100-year floodplain       .  .
   elevation (e.g., 48 feet above sea level.

o  Alternatives Involving source area pumping and cen-
   tral area treatment require placement of pipes under
   and across the Aberjona River.  Pertinent require-
   ments will be followed regarding dredging methods
   and management of dredged spoil.

o  Alternatives involving source area pumping and cen-
   tral area treatment require placement of pipes under
   and across the Aberjona River.  Proper measures will
   be taken to avoid contravention of water quality
   standards (i.e., turbidity) during installation of
   pipes.

-------
NJ
00
                                                                            TABLE   11  (Cont'd)

                                                 ACTION-SPECIFIC AND LOCATION-SPECIFIC ARABS AMD TBCS FOR MOM ALTERNATIVES:
                                                   MOM-Z
                                                   HOH-3
                                                   MOM-4
                                                 Pu«p and Treat  Source  Areas
                                                 -  2B(I)   Prelreativnt  and UV/Chemical Otldatlon at Separatt Treatment Plants
                                                 -  2B(tl)  Pretre«t»*nt  and UV/Che«ica1 Oiidalion at • Ctntral Treatment Plant

                                                 Pu«p and Treat  Central Area
                                                 -  38      Pretrralnrnt  and UV/Chemical 0«ldation at a Ctntral Treatment Plant

                                                 Pu«p and Treat  Sourer  Arras and Central Area
                                                 -  *8(i)   Pretreatwnt  and UV/CHp«ical 0«idatlon at Separate Trtatment Plantt
                                                 -  4B(ii)  Prelre*t«vnt  and UV/Chemical Onidalion at a Ctntral Treatment Plant
                   JIWIRIMCML
                                                    WELLS MM SITE. V08UP.N.  MASSACHUSETTS

                                                   	REQUIREMENT  SYNOPSIS	
                                                              ACTION TO. PC, TAKEN TO ATTAIN
               DOT - Transportation of  Hatardout
               Wattt Brquirr«»nli
               (49 CfH UI-H9)Z
               CAA - National  Air Quality Standards
               for Total Sutptndtd Partlculatt*
               (40 CIB 129. IDS.  7SO|'
                                         Thott rt9ulationt  itl  forth DOT rtqulrMvnts for
                                         trantportallon  of  haiarrtout waitr.  Thtsr art
                                         grnrrjllj identical  to RCRA requireaenls at
                                         40 CfR 263.

                                         This regulation tpeclfiet aaiiMja prlaary and
                                         ttcondary 24-hour  tonttntrjticni for particulatt
                                         •tatttr.
DEQC .Ambient  Air Quality  1     o  This regulation  specifies dust. odor, and noise
 Standards  for  the  Commonwealth  emissions  from construction activities.
of "asoachusetts (310  CMR  6.00)
           o  OEQE  -  Air  Pollution  Control S
                                (310 CM«  7.00)
                                          Regulates new tourctt of air pollution to prevent
                                          air  quality degradation.  Requires the ust  of  "Best
                                          AvaiIjblt Control Technology" (BACT) on all  new
                                          sources.
                                                        All  on- and off-sltt  transport of treatment sludges
                                                        and  other Materials will adhere to these standards.
                                                        fugitive dust  emissions fro* site activities will b«
                                                        •uintained  below  ISO ug/»^ (secondary standard) by
                                                        water sprays and  other dust suppressants.

                                                        Fugitive dust  will be controlled b« water sprays or
                                                        suppressants.  All equip*ent will be maintained so
                                                        as  not  to product tictssivt noise.

                                                        o   BACT will  bt used on all ntw  sourcts.
            o  OSMA  - General Industry Standards
               (29 Cf«      '      f
            o   OSMA - Safety,aitd Health Standards
               (29 CfU  1926)'
           o  OSMA - Recordkttplng, Reporting aqd
              Related Regulations ('29 CfR 1904)'
            o  CWA - National Pollutant Discharge
              (Ii«in«tion SyStl
              (40 CfR  122-125)'
Elimination  Syste* (NPDES)
          2-I25I1    !
This regulation specifies  the  S-hour,  tl«t-
weighted f««rage concentration for  various organic
co«pound| and 2 PCS co«f>oundi; site control pro-
cedures; training;  and protective clothing
requirements for worker protection  at  site re**—
diations.

This regulation specifies  the  type  of  safety
equipornt and procedures to be followed during
construction and excavation activities.

The regulation outlines the recordkeeplng and
reporting requirements 'or an  employer under OSHA.

Provides permitting process for surface water
body point source discharges.
                                                                                                Proper  rtsplratory tqulpaent.will bt worn If It is
                                                                                                not  possiblt to maintain tht work atmosphert btlow
                                                                                                thtst concentrations.                          i
All appropriate saftty equipment will  bt  on  sitt and
procedures will bt followed during groundwattr
monitoring.

Thest regulations art applicable to tht company
contracted to execute sitt remediation.

Water discharges to tht Abtrjona Rlvtr will  bt
treated to ensurt that violations of  the  Clean Water
Aft do not occur.

-------
                                                             TABLE  11  (CoMt'd)
                                  ACTION-SPECIFIC AND LOCATION-SPEC If 1C ARAMS AND TBCS FOR MOM ALTERNATIVES:

                                     MOM-2       Punp and Treat Source Area*
                                                 -  2B(i)   Pretreatment and  UV/Chemical  Oxidation  at  Separate Treatment Plants
                                                 -  2B«i)  Pretreatment and  UV/Chemical  Oxidation  at  * Central  Treatment Plant

                                     MOM-3       Pump and Treat Central  Area
                                                 -  38      Pretreatment and  UV/Che«ical  Oxidation  at  a Central  Treatment Plant

                                     MOM-4       Pump and Treat Source Areas  and  Central  Area
                                                 -  4B(i)   Pretreatment and  UV/Chemical  Oxidation  at  Separate Treatnent Plants
                                                 -  48(ii)  Pretreatnent and  UV/Chemical  Oxidation  at  a Central  Treatment Plant

                                                    WELLS Glfl SITE. WGOURN. MASSACHUSETTS
    -RtflUlfitMIHL
     Surface.
OEQE -/(Water Discharge Permit
Program Requirements
(314 CMR 3.00)'

DEQE - Surface Water Quality
Standards (314 CMR 4.00)'
OEQE - Groundwater Quality Standards
(314 CMR 6.00)' and Groundwator
Discharge  I'crmit Program
(314 CMH 5.00)1

DEQE - Air Emission Limitations
(or Unspecified Sources of
Volatile Organic Compounds
(310 CMH 7.I8(17))Z

DCQE - Haiardous Wast* Manage-
ment Requi renx;nts       .
(310 CMH 30.00)2
DCQE - Air Pollution  Control  New
Source Approvals (310 CMR  7.00)'
                                                       REQUIREMENT SYNOPSIS
         ACTION  TO BE  TAKEN  TO ATTAIN  REQUIREMENT
                                         Provides permitting process  for  surface  water
                                         body point discharges.   This  requirement is
                                         generally identical  to  CWA NPOES.

                                         This regulation consists  of  surface water classi-
                                         fications which designate and  assign uses, and
                                         water quality criteria  necessary to sustain the
                                         designated uses.

                                         This regulation consists  of groundwater  classi-
                                         fications which designate and  assign uses, and
                                         water quality criteria  necessary to sustain the
                                         designated uses.

                                         Unspecified source  with the potential to emit
                                         100 tons/year of  VOCs oust install "Reasonably
                                         Available Control Technology"  (RACT).
                                         These  regulations provide comprehensive moni-
                                         toring,  storing, recordkeeping. etc. programs at
                                         hazardous  waste  sites.
                                         Regulates  new  sources of air pollution to prevent
                                         air  quality  degradation.  Requires the use of "Best
                                         Available  Control  Technology"  (BACT) on all new
                                         sources.
Employee and Community  Right-tO-Know  0   Establishes  rules  for the dissemination of
R..ni.ir».u.ntt Min fMO in T                information  related to to«ic and haiardous
Requirements (310 CMR  33)'
                                         Substances  to  the public.
   Water discharges to the Aberjona River will be
   treated to ensure that violations of the DEQE water
   discharge permit program do not occur.

   Water discharges to the Aberjona River will be
   treated to ensure that violations of the OEQE water
   quality standards for that water body do not occur.
o  Class I qroundwater quality criteria will be achieved
   at end of the remediation process.
   Treatment of VOC air emissions from pretreatment
   units to 99.99 percent combustion efficiency In vapor
   phase carbon adsorption.
o  During remedial design, these regulations will be
   compared to the corresponding federal RCRA regula-
   tions, and the more stringent requirements will be
   utilized.  Note that Massachusetts .considers liquids
   contaminated with PCBs greater than 50 ppm to be
   haiardous wastes (M002).

o  BACT will be used on all new sources.
   Information dissemination procedures in these
   regulations will be used.

-------
                                                                     TABLE      (Cont'd)
                                           ACTION-SPEC IF 1C AND LOCATION-SPECIFIC ARABS AND TBCS FOR MOM ALTERNATIVES:
                                             MOM-2



                                             MOM-3


                                             MOM-4
         Pump and Treat Source Areas
         -  2B(i)   Pretreatnent  and  UV/Che«lca1 Oxidation at Separate  Treatment Plants
         -  2B(ii)  Pretreatnent  and  UV/Chenical Oxidation at a Central  Treatment Plant

         Punp and Treat Central Area
         -  3B      Pretreatnent  and  UV/Cheaical Oxidation at a Central  Treatment Plant
         Pump and Treat Source Areas  and Central Area
         -  48(i)   Pretreatnent  and  UV/Che«ical Oxidation at Separate  Treatw
         -. 48(ii)  Pretreatnent  and  UV/Chenical Oxidation at a Central  Treati

             WELLS CIH  SITE, W06URN. MASSACHUSETTS
                                                                                                                            nt Plants
                                                                                                                            «nt Plant
             JLQU1BIJ1LN_L
   2)  Action-Specific IBCi

       0  RCRA -  Proposed Air Emission
          Standards  for Treatment Facilities
          (12  FR  3748. February 5, 1987)
  The proposal would set performance  standards
  for RCRA treatment facility air emissions.
                                                             ACTION TO BE TAKEN TO ATTAIN REQUIREMENT
Vapor phase carbon  adsorption Facilities and othtr
non-incinerators  that have air emissions will be
designed to meet  the proposed Federal regulations.
     o  USfcPA Office of Solid waste  and
        Emergency  Response,  Directive
        UJ5f).0-20;  Air  Stripper  Control
        Guidance
o  Establishes guidance on  the  control of
   air emissions  from  air strippers  used
   at Supertund sites  for yroundwater
   treatment.
   3)   Location-Specific A.RAJH,

       o  RCRA  - Location Standards
          (•JO CFR 264.I8J2
u»
o
       o  CWA  - Section 404 Dredge and  Fill
          Requirements
          (Guidelines at 40 CFR 230)'
  This regulation outlines the requirenents  for
  constructing a RCRA facility on  a  100-year
  floodplain.

 'A  facility located on a 100-year floodplain must be
  designed, constructed, operated,  and  maintained to
  prevent washout of any ha/ardous  waste  by  a 100-year
  flood, unless waste nay be removed  safely  before
  flootlwater can reach the facility,  or no adverse  .
  effects on human health and the  environment would
  result if washout occurred.

  The placement for fill pursuant  to  remediation  .
  activities in Aberjona River wetlands triggers
  Section 404 jurisdiction.   The governing regula-
  tions favor practicable alternatives  that  have
  less impact on wetlands,  (f no  practicable
  alternative exists, impacts must be
  (litigated.
There Is adequate  space  to  site treatment plants out-
side a floodplain.   Pipes extending fro* pumping
areas and treatment  plants  through floodplains do not
present any risk of  washout due to flooding and'will
not displace Floodplains.
There is adequate space to  site  treatment plants out-
side Section 404 wetlands.
                                                                                                        Excavation and  subsurface placement of extraction
                                                                                                        wells and  piping  to  and  fro* source areas and treat-
                                                                                                        ment  olinU  will  h»  d»« !«••••< •- -••-'

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                                                                    TABLE 11   (Confd)
                                         ACTION-SPECIFIC  AND LOCATIflfc-SPECIFIC  ARABS  AND  TBCS FOR MOM  ALTERNATIVES:
                                            HOH-2
                                            MOM-3
                                            MOM-4
        Pump and Treat Source Areas
        -  2B(i)   Pretreatment and UV/Chenical  Oxidation at Separate Treatment Plants
        -  2B(H)  Pretreatment and UV/Chenical  Oxidation at a Central  Treatment Plant

        Pump and Treat Central Area
        -  38      Pretreatment and UV/Cheerical  Oxidation at a Central  Treatment Plant

        Pump and Treat Source Areas and Central  Area
        -  4B(i)   Pretretxent and UV/Chenical  Oxidation at Separate Treatnent Plants
        -  4B(ii)  Pretreatmenl and UV/Chenical  Oxidation at a Central  Treatment Plant
                                                           WtLLS GWi SITE. W06URN. MASSACHUSETTS

                                                          	BtQUJEQltMJLilliQESJ 5	
                                                             ACTION TO BE TAKEN TO ATTAIN REQUIREMENT
    0  Inland Wetland Orders
       (302 CHR 6.00)2
       Operation and Maintenance and Pre-
       treatment Standards for Waste Water
       Treatment Works and Indirect
       Discharges (314 CMR 12.O)2

       Wetlands Executive Order
       (EO 11990)'
       Floodplains Executive Order
       (I 1 11888)1
Location-Spec!Me IBCs

o  EPA Groundwater Protection  Strategy   0
Defines wetland areas, establishes encroachment
lines along watervayf or ftoodplain areas,  and
regulates activities in these areas.
Insures the proper operation and maintenance of
waite water treatment facilities including
operation and maintenance, sampling, and
discharges.

Undflr this Executive Order, federal  agencies are
required to mininiie the destruction, loss or
degradation of wetlands, and preserve and enhance
natural jnd beneficial values of wetlands.  If no
pract i< able alternative exists impacts mst be
Federal agencies, are required to reduce the risk
of flood loss, to •initiize impact of  floods,  and to
rciiore dnd preserve the natural and  beneficial
value of floodplains.
                                                EPA  classifies  groundwcter  into  three  categories
                                                depending  on  current,  past  or potential ui*.
                                                This serves as  a  guid* .for  protection  of  the
                                                resource.
                                                                                                o  Son* pipes connecting central treatment plants will
                                                                                                   be laid across the river.  In these cases,  con-
                                                                                                   sultation with OCQE regarding proper construction
                                                                                                   will occur.

                                                                                                o  Guidelines appropriate For a wastewater treatment
                                                                                                   facility will be followed.
                                                                                                o  The placement of pipes in wetlands,  Is necessary  to
                                                                                                 • connect the central treatment plants.  Therefore,  it
                                                                                                   i's consistent with the requirements  oF the  Executive
                                                                                                   Order.
                                                                                                   The placement of pipes  in wetlands,  below  grade,
                                                                                                   poses no additional  flood hazard and meets the  re-
                                                                                                   quirements of the Executive Order.
                                                        Wells GUI aquifer is a Class II B aauifer-potentlally
                                                        usable aquifer.  At the end of remediation, all MOM
                                                        alternatives will attain standards for Class IIB
                                                        aqui fers.
 Applicable
rt
^Relevant and Appropriate

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                                                                      TABLE   12

                                                           SUMMAffV OF PRFSF.NT WORTH COSTS  FOR
                                                              SOURCE CONfHUL  ALTERNATIVES
                                                                                     Total Present Worth M9BB1 Dollars
SC-I:
SC-3:
SC-4:
SC-5:
SC-7:
SC-8:
SC-9:
SC-IO:
SC-11
No Action*
Excavation On-Sitt Incineration/Backf ill On-Site
Excavation/Off-Site Incineration/Backfill
With Clean Off-Site Soil
Excavation/On-Si te High Temperature Enhanced
Volatilization/Backfill On-Sitt
Excavation/On-Site Supercritical Fluids
Extraction/Backfill On-site
Excavat ion/On-Si te Enhanced Volatil ization/On-Si l«
Incineration/Backfill On-Site
Cxcavat ion/On-Site Enhanced Volatil i zat ion/Of f-Si te
Incineration/Backfill with Treated and Clean Off-Site
Soil
In Situ Volatil ization/Excavation/On-Site Incineration/
Backfill On-Site
In Situ Volatil ization/Excavation/Of f-Si te Incineration/
\Q~A Target
Level
799.500
7,301,800
21.517.100
6.424.800
7.372.700
5.733.100
6.306.800
2.285.800
3.111.000
1
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      WELLS G & H

      APPENDIX A
RESPONSIVENESS SUMMARY

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