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
1
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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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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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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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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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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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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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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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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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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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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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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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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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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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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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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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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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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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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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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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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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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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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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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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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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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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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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
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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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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
>"
1
-A*
™
"
ONUCLIDES
GRACE
GW
•
•
• •
•
•
•
•
/^~ NEW ^N
ENGLAND
S
•
GW
1
•
•
i
• •
• •
• : •
•
•
•
X^OLYWrlA^X
NOMINEE
TRUST '
S G*
•
•
•
•
'•
• • .
•
•
•
•
•
•
S -Soil
SL-Sludge
SD-Sedimenl
SW-Surfoce water
CW-Grounflwoler
^UN,FI*ST-\
S ' GW
•
•
•
J
•
•
•
^WILDWOOO^V
S SL
•
GW
• •
•
• • •
• i
•
:•
• • •
• •
• •
• .0 •
. •
;• •
• •
• ;•
• •
• •
^ i
^ i ™
•
•
•
™
•
f CENTRAL ~^\
AREA
S : SO ' GW Svv
A i
i
•
• •
• f
! : o . •
•
• •
•
•
•
•
•
i ^
•
•
•
"•"•
i ^
•
•
i
•
•
-------
7A£'.E 2
S-jn-lir -•= r -r r-;*:«i:rr ;;tr.s ASSOCIATES'WlT
[i = :i--:- A* Tr: VEILS 5 & * SHE -
LOCATION
V: R. Grace and Company
Ingest ion of Grcuiflwater
Inr.a'iaticn of Volatiles Released
•hi le Showering
New England Plastics Corporation
Ir.r_a lat ior. of Vt 'at lies Ke'eesec
O.rir.; tr.;_jtr-.al rrccesses
fcy Inc.-str -.a 1 «i"*e"S
Oe— .*! Co-tact a-: !^.:-:e-:ai
!"?tf." c' S»*'ace So-. 1
By 1 nc~_s°.* ' a 'i »i*«e"s
Irhalaticr c' Vc'ati'es *t";eaie:
f r T"* ^f s't t v ' - — »*-•*. '• - - R p - t
F * L. *" ^ ? »** ^ % 'c.r; A-J>.S
Innaiatie". of 0--st Ge-erateS
While DirtEi«e Ricmg
. Future Ingest 101 cf Grc.-=»a:er
Future Inna'ation o* Volatiles
Released wrule Srio-e-ing
Unifirst Corporation
Future Ir.geStiO" cf G^oj-3-at er
Future Irr.alet'OP of Vclatiles
Re'ieasec wm le S"o»e'ing
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
While Oirtbike.8 ifling
- Surface Soi 1
- Northern S'uOges
- Southern Sludges
R; s»
PI
2t-03
4E-C4
1E-07
7E-C8
3E-13
IE -08
' 3E-12
8i-es
££-:'.
5E-1C
2E-C3
** t • C S
2£-:s .
SE-C6
; r . r.j
3£ -C-
6E-13
7E-Cc
BE-07
2E-07
1E-07
5E-07
7E-08
.AUS:S-.E
va:>«'jn
2E-01
5E-02
IE-OS
4E-C5
1E-C3
8r-C«
IE-OS
5E-04
3E-05
3E-CE
it -.05
SE-05
6E-C5
1E-C3
4E-C4
4E-C2
1E-12
4E-C3
7E -01
SE-CS
2E-C5
3E-05
' 3E-OS
3E-06
M-t-nw IN.
PI
«i (0.2) >:
«i (0.2) >;
«1 (O.CC7) <
«1 (O.OCS) «
«1 !8E-:S) <
«1 (C 02) >
«I (IE-OS) <
<1 (C C5) <
<; ic c?) <
«; ic 0:2) «
«i (c on <
«1 (2E-OS) <
«! (C CC3 1 «
<1 (0.2)
<1 (C 02) <
1 >
<1 (09)-'
«1 (6E-07) «
«I (0 C2) '
<1 jO.i)
<1 (0.3)
<1 (0 002)
«1 (0 004) .
<1 (0.0005) •
.LX
;tiH5i£
I (241
1 (23)
1 (O.CE)
1 (0.7)
1 (4E-CS)
1 (4)
1 (2E-04)
1 (0.5)
1 (C 4)
I (0.3)
1 .(0.9)
1 (0.001)
1 (0 8)
1 (0.7}
1 (0.06)
1 (471
'1 (41)
1 (4E-OS)
•1 (2)
•'. (12)
•1 (16)
1
•1 (0.5)
=1 (0.3)
NOTE: Scientific notation (such as 2E-06) is a shorthand «ay of in-icating
oecinval places, (i.e.. the magiitu^e of the n-jr.jer) A negative eipsnent
ir.cicates that the oe:ina' sf.s.lc De ".eo tne specified p.unoer of places
to the left h.«.. 2E-03 • Q.QQ2 = 2x10~3)
-------
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)
-------
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.
-------
^ 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.
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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»« !«••••< •- -••-'
-------
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
-------
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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