United States '
Environmental Protection
Agency
Office of
Emergency and
Remedial Response
EPA/ROD/R01-89/040
'September 1989
SEPA
Superfund
Record of
W.R. Grace, MA
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50272-101
REPORT DOCUMENTATION
PAGE
1. REPORT NO.
EPA/ROD/R01-89/040
3. Recipient* Accession No.
4. Tide and Subtitle
SUPERFUND RECORD OF DECISION
W.R. Grace, MA
First Remedial Action
5. Report Data
09/29/89
7. Author(s)
& Performing Organization Rept No.
8. Performing Organization Name and Address
10. Proiect/Taak/Work Unit No.
11. Contract(C) or Grant(G) No.
(C)
(G)
12. Sponsoring Organization Nam* and Addraw
U.S. Environmental Protection Agency
401 M Street, S.W.
Washington, D.C. 20460
13. Type of Report & Period Covered
800/000
14.
15. Supplementary Note*
16. Abetract (Umit: 200 worda)
The W.R. Grace (Acton Plant) site is in Acton and Concord, Massachusetts. The American
Cyanamid and Dewey & Almy Chemical companies formerly owned the 200-acre site where they
manufactured explosives, synthetic rubber, container sealant products, latex products,
plasticizers, and resins. In 1954 W.R. Grace & Company purchased the property and began
j^fcpducing container sealing compounds, latex products, and paper and plastic battery
|^^>arators. Effluent wastes from these operations flowed into several unlined lagoons
and were later buried in onsite waste areas, including an industrial landfill. After a
1978 investigation revealed that ground water in the vicinity of the site was
contaminated with VOCs, W.R. Grace & Company agreed to fully restore the aquifer. An
aquifer restoration system was installed in 1985 which recovers and treats ground water
under the site's waste disposal areas. Subsequent samplings, however, have indicated
that the system has only minimally reduced the ground water contamination at the site.
This first operable unit primarily addresses the source contamination and includes
minimal modifications to the aquifer restoration system. Further ground water
remediation will be addressed in a subsequent Record of Decision. The primary
contaminants of concern affecting the soil, sediment, and sludge are VOCs including
benzene and toluene, other organics, and metals included arsenic. (See Attached Sheet)
MA
17. Document Analysis a. Descriptor*
Record of Decision - W.R. Grace,
First Remedial Action
Contaminated Media: soil, sediment, sludge
Key Contaminants: VOCs (benzene), other organics, metals (arsenic)
b. Identifiera/Open-Ended Term*
COSATI Field/Group
vailability Statement
19. Security Cta*a (Thl* Report)
None
20. Security da** (Thl* Page)
None
21. No. of Page*
209
22. Price
(See ANSI-Z39.18)
See Inatructiona on Reran*
OPTIONAL FORM 272 (4-77)
(Formerly NTIS-35)
Department of Commerce
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DO NOT PRINT THESE INSTRUCTIONS AS A PAGE IN A REPORT
INSTRUCTIONS
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1. Report Number. Each Individually bound report shall carry a unique alphanumeric designation assigned by the performing orga-
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an organizational hleraehy. Display the name of the organization exactly as It should appear in Government Indexes such as
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16. Abstract Include a brief (200 words or less) factual summary of the most significant information contained in the report. If the
report contains a significant bibliography or literature survey, mention It here.
17. Document Analysis, (a). Descriptors. Select from the Thesaurus of Engineering and Scientific Terms the proper authorized terms
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A GPO: I983 0 - 381-526(8393) OPTIONAL FORM 272 BACK
. (4-77)
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EPA/ROD/R01-89/040
W.R. Grace, MA
First Remedial Action
Abstract (continued)
The selected remedial action for this site includes excavation and offsite incineration
of highly contaminated soil and sludge; onsite solidification of less contaminated soil,
sludge, and sediment followed by onsite disposal in the landfill and capping of the
landfill; covering and monitoring other waste areas; modification to the aquifer
restoration system to address air stripper emissions controls; and environmental
monitoring. The estimated total cost for this remedial action is $7,058,000, which
includes an estimated O&M cost of $2,468,000.
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DECLARATION OP RECORD OP DECISION
SITE NAME AND LOCATION
W. R. Grace & Co. (Acton Plant)
Acton, Massachusetts
STATEMENT OP PURPOSE
This Decision Document presents the selected remedial action for
the W. R. Grace & Co. (Acton Plant) Site in Acton, Massachusetts
developed in accordance with tbe 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 Oil and
Hazardous Substances Contingency Plan (NCP), 40 CFR Part 300 et
s_eg., as amended. The Region I Administrator has been delegated
the authority to approve this Record of Decision.
STATEMENT OP BASIS
This decision is based on the administrative record which has
been developed in accordance with Section 113(k) of CERCLA and
which is available for public review at the Acton Public Library
in Acton, Massachusetts and at the Region I Waste Management
^Division Records Center in at 90 Canal Street, Boston,
Massachusetts. The attached index identifies the items which
comprise the administrative record upon which the selection of
the remedial action is based.
DESCRIPTION OP THE SELECTED REMEDY
This ROD addresses the first of three planned activities at the
Site. To implement a complete Site cleanup, EPA has organized
the work in three operable units (UOs):
OU One: Disposal areas and surficial contamination areas at the
Site.
OU Two: Residual contamination in disposal areas at the Site
following implementation of OU One.
OU Three: Contaminated groundwater and the establishment of
groundwater target cleanup goals.
The first OU is the remedy selected to remediate sources of
contamination at the Site. The remedial measures described in
this ROD will protect the drinking water aquifer by minimizing
further contamination of the groundwater and surface water, and
will eliminate the threats posed by direct contact with or
ingestion of contaminants in soils and waste sludges at the Site.
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- 2 -
The major components of the selected remedy include:
- -Excavation and transportation off-site for incineration of
highly contaminated material from the Slowdown Pit;
- Excavation and stabilization of the remaining contents of
the Slowdown Pit, as well as the contaminated sludges and
soils of the Primary Lagoon, Secondary Lagoon, North Lagoon,
and Emergency Lagoon;
- Excavation of contaminated soils from the Battery Separator
Lagoons, Boiler Lagoon, and Tank Car area;
Placing both the stabilized and the non-stabilized materials
excavated from the site on the existing Industrial Landfill,
and covering these materials with an impermeable cap;
- Post excavation sampling and analysis;
- Capping the Battery Separator Chip Pile;
- Covering any disposal area which attains the Soil Cleanup
Goals:
Modifying the Aquifer Restoration System (ARS) to address
air stripper emission controls; and
Establishing long term environmental monitoring at each
disposal area designed to monitor the effectiveness of the
proposed remedy.
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 utilize treatment as a principal
element to reduce the toxicity, mobility, or volume of hazardous
substances. In addition, this remedy utilizes permanent
solutions and alternative treatment technologies to the maximum
extent practicable.
Date Paul G. Keough, Acting
Regional Administrator
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W. R. Grace site - Acton, Massachusetts
Record of Decision Summary
TABLE OF CONTENTS
Contents Pace Number
I. SITE NAME, LOCATION AND DESCRIPTION 1
II. SITE HISTORY 1
A. Response History 1
B. Enforcement History 5
III. COMMUNITY RELATIONS 6
IV. SCOPE AND ROLE OF OPERABLE UNIT OR RESPONSE ACTION ... 7
V. SITE CHARACTERISTICS .... 9
A. Source Areas 9
B. Groundwater 12
VI. SUMMARY OF SITE RISKS 13
A. General Methodology 13
B. Direct Contact with Surface Material 15
C. Ingestion of Groundwater 16
VII. DOCUMENTATION OF NO SIGNIFICANT CHANGES 16
VIII. -DEVELOPMENT AND SCREENING OF ALTERNATIVES 17
A. Statutory Requirements/Response Objectives .... 17
B. Technology and Alternative Development and
Screening IS
IX. DESCRIPTION/SUMMARY OF THE DETAILED AND COMPARATIVE
ANALYSIS OF ALTERNATIVES 21
A. Source Control Alternatives Analyzed ....... 21
X. THE SELECTED REMEDY 27
A. Description of the Selected Remedy 27
B. Rationale for Selection 37
XI. STATUTORY DETERMINATIONS 39
A. The Selected Remedy is Protective of Human Health
and the Environment 39
B. The Selected Remedy Attains ARARs 41
C. The Selected Remedial Action is Cost Effective . . 46
D. The Selected Remedy Utilizes Permanent Solutions
and Alternative Treatment Technologies or Resource
Recovery Technologies to the Maximum Extent
Practicable 48
E. The Selected Remedy Satisfies the Preference for
Treatment as a Principal Element 49
XII. STATE ROLE . 49
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W. R. Grace Site - Acton, Massachusetts
Record of Decision Summary
LIST OF FIGURES
Figure vumbeT- Pace Kumber
Figure 1 - Site Map ...... .... ........... 2
LIST OF TABLES
Table Kum'b«»y • Page K umber
Table 1 - List of Indicator Chemicals ............ 14
Table 2 - Alternatives Retained for Detailed Analysis .... 20
\
Table 3 - Soil Cleanup Goals ................ 30
Table 4 - Chemical Specific ARARs . ............. 42
Table 5 - Action Specific ARARs ............... 43
Table 6 - Cost Summary of Each Alternative ..... . . . . . 47
APPENDICES
Model Description ................ Appendix A
Responsiveness Summary ............. Appendix B
Administrative Record Index ........... Appendix C
State Concurrence Letter ............. Appendix D
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ROD DECISION SUMMARY
I. SITE NAME, LOCATION AND DESCRIPTION
SITE NAME: W. R. Grace & Co. (Acton Plant)
SITE LOCATION: Acton, Massachusetts
SITE DESCRIPTION: The W. R. Grace Superfund Site (the
Site) is located in Acton and Concord, Massachusetts, off of
Independence Road, and is composed of approximately 200 acres
bounded to the north in part by Fort Pond Brook and to the east
and south by the Assabet River. Industrial parks border the site
to the south and residential housing borders the site on the
northeast. American Cyanamid Company and the Dewey & Almy
Chemical Company (D&A) were former occupants of the Site.
American Cyanaroide manufactured explosives, and Dewey & Almy
Chemical Coinpany produced synthetic rubber container sealant
products, latex products, plasticizers, and resins.
W. R. Grace & Co. (Grace) acquired the property in 1954.
Historical operations at the W. R. Grace facility included the
production of materials used to make concrete and organic
chemicals, container sealing compounds, latex products, and paper
and plastic battery separators. Effluent wastes from these
operations flowed into several unlined lagoons (the Primary
Lagoon, Secondary Lagoon, North Lagoon and Emergency Lagoon), and
were buried in or placed onto an on-site Industrial Landfill and
several other waste sites. These other waste sites include the
Battery Separator Lagoons, the Battery Separator Chip Pile, the
Boiler Lagoon, and the Tank Car Area. Periodically, sludge fron
the primary lagoon was mucked out, dried along the banks, and
trucked to the landfill for disposal. In addition, the by-
products of some chemical process were disposed of in the
Slowdown Pit. Discharge to all lagoons and the Battery Separator
Area ceased in 1980 (see Figure 1). A more complete description
of the site can be found in the report submitted by Grace under
the Section XI.C. of the Consent Decree entitled the "Phase Four
Site Closure Plan" (the Phase IV Report).
II. SITE HISTORY AND ENFORCEMENT ACTIVITIES
A. Response History
Investigations in 1978 indicated that two municipal wells,
Assabet #1 and 12, vere contaminated with vinylidene chloride
(VDC). Significant levels of vinyl chloride, ethylbenzene and
benzene were also detected at that time. As a result of these
findings, the Town took the precautionary action of closing the
two wells. The United States sued Grace on April 17, 1980 to
require cleanup of the Site in an action entitled U.S. v. W. R.
^Grace & Co. U.S. District Court for the District of
^Massachusetts, Civil Action No. 80-748-C. In October 1980, the
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FIGURE 1
W.R. Grace Superfund Site Features Map
rtn Lapopn
Tank Car Aresj
Eanery Separator
t^res
; slowdown
Secondary
Emerpenry Lacoon
Legend
Contaminated
Areas
0 Assabet Wells
Approximate
Boundary of ARS
Railroad
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EPA and Grace entered into a Consent Decree which outlined a
procedural framework for site cleanup. The Consent Decree
outlined a phased program to plan and undertake cleanup of the
various waste disposal sites and restoration of groundwater in
drinking water aquifers that have been contaminated by the .
facility. The Consent Decree requires Grace to clean up and
restore the quality of the drinking water of the Sinking Pond
Aquifer, the source of water for Assabet Wells #1 and #2 to a
fully usable condition as a public drinking water supply. The
requirements of the Consent Decree are similar to those of an
Administrative Order issued by the Massachusetts Department of
Environmental Protection (DEP)(formerly the Department of
Environmental Quality Engineering) in July 1980. DEP issued an
Amended Order in April 1981 to conform with requirements of the
Consent Decree between EPA and Grace.
Based on the results of investigations started in 1978, on
September 8, 1983 EPA amended the NCP to add the Site to the
National Priorities List (NPL), established pursuant to Section
105 of CERCLA (48 FR 40658).
Under Section XII of the Consent Decree, which relates to cleanup
of the aquifer, Grace initiated development of an engineering
plan for aquifer cleanup and accelerated restoration to a fully
usable condition. The first steps evaluated the Site
hydrogeology and a characterized the extent and nature of
groundvater contamination. Two types of models, one for
simulating groundwater flow and the other for simulating
contaminant transport, were developed and calibrated early in the
study process. The models were used to analyze the transport and
fate of contaminants from the various waste sites and to develop
a conceptual design for the Aquifer Restoration System. Using
the results of these investigations and subsequent groundwater
monitoring results, Grace designed a recovery well network it
expected wouJd contain contaminated groundwater in a "capture
zone," thus preventing further migration off-site. Contaminated
groundwater extracted from the network of wells then would be
either pumped to a central treatment facility or treated at the
well-head.
Following EPA and Massachusetts approval of Grace's aquifer
restoration system design, Grace constructed a groundwater
recovery and treatment system, called the Aquifer Restoration
System (ARS), in March 1985. Since March 1985, W. R. Grace has
been operating the system which recovers and treats the
groundwater under the waste disposal units. In addition, Grace
has been conducting a program for monitoring the contaminated
aquifer and the implementation of restoration measures.
Monitoring indicates that there is contamination outside the area
of containment of the ARS.
The Aquifer Restoration System presently consists of eight
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pumping wells, discharging to a packed tower air stripper which,
in turn, discharges the treated water to Sinking Pond. There are
two bedrock wells, NLBR and SLBR, which serve to collect bedrock
aquifer contamination. There are six sand and gravel aquifer
wells. The NLGP and SLGP wells collect overburden aquifer
contamination. The ELF, WLF and RLF wells collect contamination
originating from the Landfill and the Secondary Lagoon. The NMGP
well was installed later with its principal purpose to establish
groundwater containment under the North Lagoon. All collected
water is discharged directly to Sinking Pond after treatment at
the ARS stripping tower.
The RP-1 bedrock recovery well and packed tower air stripper was
installed in 1984 as part of a pilot treatability study. It has
been operating continuously since that time and continues to
remove volatile organic contamination in the bedrock aquifer in
the northern portion of the Mass. Broken Stone Pit. Most of the
contamination in the Broken Stone Pit lies in the bedrock.
Since the ARS startup, groundwater at the site has been sampled
on a periodic basis. Grace has submitted fifteen progress
reports to date documenting the operation of the ARS including
the results of the sampling. The data show that the Aquifer
Restoration System has established a zone of containment under
the disposal areas. However, there is significant contamination
outside the area of containment. There continues to be
uncertainty with respect to the area of containment to the
northeast and east of the secondary lagoon. Groundwater level
data indicates that this area is almost completely flat, and the
location of the groundwater flow divide is not certain. Until
the NMGP was installed in November 1987, groundwater under the
North Lagoon was not being contained.
The Aquifer Restoration System has produced in some areas a
reduction in contamination in the groundwater both within and
downgradient of the containment zone. The extent of reduction
varies, with some areas being cleaned up very slowly. However,
in some areas there has been no discernable downward trend.
The second response activity, which is governed by Section XI of
the Consent Decree, requires Grace to assess and control sources
of waste on-site. The requirements of the Consent Decree
correspond to those established under the National Contingency
Plan promulgated by EPA at 40 CFR Part 300 for evaluating and
responding to Superfund sites. Specifically, the Consent Decree
established a phased investigation under EPA oversight. In
Phases I and II, Grace was to prepare plans for studying and
determining the nature and extent of contamination "on, in,
beneath, and immediately surrounding the landfill, all lagoons
and all other waste disposal sites," and, after EPA approval,
perform the study. The Phase I and II studies correspond to the
Remedial Investigation requirements for NPL sites set forth in 40
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CFR § 300.68(d) and (e). In Phase III of the source
investigation, Grace was to "identify, analyze, and evaluate
cleanup and remedial measures that will correspond to the nature
and extent of contamination." Following conditional approval of
the Phase III scope of work, Grace performed the evaluations and
submitted the results to EPA and DEP under Phase IV of the
Section XI of the Consent Decree (the "Phase IV Report"). The
development, screening, and detailed evaluation of the remedial
alternatives required under Phases III and IV of the Consent
Decree parallel the requirements of the NCP for a Feasibility
Study under 40 CFR § 300.68(f), (g) and (h). The one feature of
the Consent Decree process that differs from the NCP procedure is
that the Phase IV Report will also include a remedial plan of
action with one or a combination of the cleanup and remedial
measures evaluated in the report. Grace submitted the first
draft Phase IV report on February 17, 1987, and submitted a
second complete draft Phase IV Report containing substantial
revisions to address comments from the EPA and DEP on August 31,
1988. Following a series of meetings in 1989 to discuss
information needs and suggested revisions to the recommended
remedy between Grace, EPA, DEP and representatives of the Town of
Acton, Grace submitted an Addendum to the August 1988 draft Phase
IV Report on June 6, 1989.
Under the Consent Decree, Grace is to implement the remedial
measures of the Phase IV report that are approved by the EPA.
The remedial measures evaluated in the Phase IV Report and the
Addendum provide much of the analysis for the remedy that is
being selected in this Record of Decision. Upon the issuance of
this ROD, EPA will take actions under the Consent Decree to
approve a remedial plan of action consistent with the remedy
selected here.
B. Enforcement History
On April 17, 1980, the U. S. Department of Justice filed an a
civil action against Grace under Section 7003 of Resource
Conservation and Recovery Act (RCRA) seeking a judicial order for
Grace to abate an imminent and substantial endangerment to human
health and the environment at Grace's Acton facility. The action
entitled U.S. v. W. R. Grace & Co. was filed in the U.S. District
Court for the District of Massachusetts, Civil Action No. 80-748.
Shortly thereafter, on July 14, 1980, the Massachusetts DEP
issued an administrative order to Grace specifying procedures and
requirements for evaluating and correcting Site contamination.
EPA and Grace settled the action, agreeing on a Consent Decree
and judicial order that was filed with the Court on October 21,
1980. The provisions of the Consent Decree are similar to the
requirements of the DEP Order, which DEP amended to conform with
the Consent Decree language on April 15, 1981.
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Under the Consent Decree, Grace has been responsible for
conducting the evaluations and analyses necessary for EPA and DEP
approval of remedial measures at the Site. Since 1980, Grace has
implemented an approved groundwater recovery and treatment
program, referred to as the Aquifer Restoration System, and
continues to monitor groundwater as required by the Decree to
evaluate the impact of Site contamination on the aquifer. Grace
has also proceeded to evaluate the sources of contamination at
the facility under government oversight, and presented the
results of the Site evaluation to the public in December 1988.
Following submittal of the draft Phase IV Report in August 1988,
Grace net a number of tiroes with EPA and DEP to discuss the
government parties' comments. Summaries of issues discussed in
those meetings are included in the Administrative Record for this
Site, together with Grace's Phase IV Report, the Addendum to the
Phase IV Report, and comments submitted by Grace on the EPA
Proposed Plan.
Special notice has not been issued in this case because Grace is
operating in compliance with a Consent Decree that governs the
cleanup at the Site.
III. COMMUNITY RELATIONS
Community interest and involvement in EPA activities at the W.R.
Grace site has been exceptionally high throughout most of the
history of EPA involvement at the site. Since 1983, when the
site was added to the National Priorities List, EPA has conducted
activities to keep the community and other interested parties
apprised of Site activities through informational public
meetings, press releases, telephone contact with interested
community members and local officials, and the involvement of
representatives of the Town of Acton in discussions of technical
plans and progress.
In August 1984, EPA and the Massachusetts Department of
Environmental Protection (DEP) held a public meeting to discuss
the Aquifer Restoration System, and plans for future study of the
site. Also in 1984, EPA initiated weekly technical meetings
involving the participation of W.R. Grace, EPA, DEP, consultants
employed by the Town of Acton, and local Acton officials.
Upon completion of a site investigation and evaluation of
alternatives to address the sources of site contamination, EPA
and DEP released the results of the site studies in the Draft
Phase IV Closure Plan prepared by W.R. Grace. Upon release of
the Draft Phase IV Closure Plan, the report was made available at
the Acton Public Library. In December 1988, EPA and DEP held a
public informational meeting in Acton at which W.R. Grace
representatives presented the Closure Plan. The meeting also
included opportunity for public questions and comments.
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In May, 1989, as a result of petition from citizens to the DEP
asking for the site to be designated as a Commonwealth of
Massachusetts Public Involvement Plan site, EPA and DEP met with
interested citizens to discuss community concerns, avenues
through which site information would be supplied to the
community, and opportunities for public involvement in the
process for achieving a Record of Decision at the site.
Following this meeting EPA and DEP maintained telephone contact
and written correspondence to apprise the citizen's group of
plans for public meetings and the projected schedule for public
comment opportunities. EPA is currently working with DEP on a
joint Community Relations Plan to establish mechanisms for public
involvement during the remedial design and remedial action phases
of site activity. The plan will be presented to the community
for comment in autumn, 1989, prior to finalization.
In July of 1989, EPA made the Administrative Record available for
public review at EPA's offices on 90 Canal Street in Boston, and
in Acton at the Acton Public Library. On August 9, 1989, the EPA
published a public notjce and brief analysis of the Proposed Plan
for source control at the site in the Middlesex News. The public
notice also announced the availability of documents for review as
part of the Administrative Record, and provided information on
the dates for a public information meeting, informal public
hearing and comment period. This same information was also .
released in press release form to the media and to the
approximately 500 interested and affected parties on the site
mailing list. To facilitate public involvement further, the
Proposed Plan for the site was also mailed directly to all those
on the site mailing list.
On August 14, 1989 the Proposed Plan for addressing sources of
contamination and other new documents were made available for
public review as part of Administrative Record. Also on August
14, 1989, a public informational meeting was held in Acton to
review the Proposed Plan and provide opportunity for public
discussion. From August 15, 1989 to September 15, 1989, the
Agency held a four week public comment period to accept public
comment on the alternatives presented in the draft Phase Closure
Plan, the Closure Plan Addendum, Proposed Plan and on the other
documents that are a part of the Administrative Record for the
site. On September 12, the Agency held an informal public
hearing to accept any oral comments. A transcript of this
informal hearing and summary of the coirav.ents received and EPA
responses are included in the attached responsiveness summary.
IV. SCOPE AND ROLE OF OPERABLE UNIT OR RESPONSE ACTION
This ROD addresses the first of three planned activities at the
Site. To implement the Site cleanup under the Consent Decree,
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8
EPA has organized the work into three operable units (OUs), which
are:
OU One: Disposal areas and surficial contamination areas at the
Site.
OU Two: Residual contamination in source areas at the Site
following implementation of OU One.
OU Three: Contaminated groundwater in the area of the Acton
facility that is not contained or adequately addressed
by the Aquifer Restoration System.
The first OU is the remedy selected in this ROD to remediate
sources of contamination at the Site. The remedial measures
authorized by this ROD will protect the drinking water aquifer by
minimizing further contamination of the groundwater and surface
water, and will eliminate the threats posed by direct contact to
or ingestior? of contaminants in soils and sludges at the Site.
OU One establishes Soil Cleanup Goals to be attained at each of
the disposal areas and establishes post-excavation sampling and
analysis requirements to determine whether the Soil Cleanup Goals
have been met by the excavation activities described in this OU.
This remedy will be satisfied at a particular disposal area if
the levels of residual contamination are equal to or less than
the established levels. The remedy selected for OU One is
described below in Section X.
It is anticipated that two other operable units may be necessary
to obtain a comprehensive remediation of contamination in soils
and groundwater. OU Two would follow the excavation and post-
excavation analysis activities of this ROD if residual
contamination in soils under a disposal area exceeds the Soil
Cleanup Goals of this ROD. If further remediation is necessary
because the established cleanup goals have not been attained from
excavation of contamination, supplemental remedial measures would
be evaluated and selected to attain the cleanup goals. The
evaluation and selection of a technology to utilize in a second
operable unit would be subject to the same decision criteria and
procedures used by EPA and DEP in the selection of this remedy,
and would result in another ROD.
A third operable unit will evaluate the extent of groundwater
contamination on- and off-site and establish groundwater target
cleanup levels for groundwater that has been contaminated by the
Site. OU Three will determine whether additional remedial
measures are necessary to restore the groundwater affected by the
site to a fully usable condition in the shortest practical time
and to protect public health and the environment. This third
operable unit will include an evaluation of the ARS to determine
if it is adequately containing contaminated groundwater from the
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site,^ is adequately remediating the groundwater affected by the
site, and will establish groundwater target cleanup levels. OU
Three may also require remedial measures if groundwater
monitoring which is part of OU One indicates that groundwater
contamination is not being remediated by the existing ARS or if
contamination at the site is not being adequately contained by
the ARS. If further measures are deemed necessary to remediate
groundwater contaminated by the Site, the selection of such
measures would be subject to the same decision criteria and
procedures used by EPA and DEP in the selection of this remedy,
and would result in another ROD.
V. SITE CHARACTERISTICS
As part of the investigations of contamination sources conducted
under the Consent Decree, Grace conducted field investigations to
assess the nature and extent of soil, groundwater, surface water
and sediment contamination resulting from previous disposal
activities at the W. R. Grace site. Section 4 of the Phase IV
Report contains an overview of the investigations. The
significant findings of the investigations are summarized below.
A. Source Areas
1. Primary, Secondary and Emergency Lagoons
The Primary, Secondary and Emergency Lagoons received process
wastewater from the Organic Chemical plant which formerly
occupied the area north of the three lagoons. The Primary Lagoon
received wastewater directly from the plant and roost of the
solids settled to the bottom. The supernatant was pumped to the
Secondary Lagoon where the finer solids settled. The Emergency
Lagoon received plant wastewater directly when the Primary Lagoon
was closed for dredging.
The Primary Lagoon has a surface area of about 24,000 square
feet. The lagoon has nearly vertical sidewalls and lies within a
depression. Sludge volume in and around the lagoon was estimated
at 5,000 cubic yards in the 1982 Sampling and Analysis Report.
Sludge depth varies from 2 to 6 feet with the deepest deposit at
the northern end. Underlying soils are primarily fine to medium
sands. The groundwater table lies approximately 20 feet below
the bottom of the sludge layer. Discharge of process wastewater
to the Primary Lagoon ceased in 1980. During its operating life,
the Primary Lagoon was dredged approximately every other year.
Sludges were placed next to the lagoon and allowed to dry. Final
disposal of most of the dredged sludge was on site at the
industrial landfill. Some dried sludge piles (approximately 50
to 100 cubic yards) remain near the Primary Lagoon.
Contaminants present in the Primary Lagoon sludges and underlying
soils include but are not limited to VDC, vinyl chloride,, ethyl
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benzene, and .benzene.
The Secondary Lagoon has a surface area of approximately 100,000
square feet. The sludge volume for this lagoon is estimated at
5,000 cubic yards. The groundwater table lies approximately 40
feet below the bottom of the sludge. The soils under this lagoon
are primarily fine sand. Discharge to the Secondary Lagoon
ceased in 1980. Contaminants present in the Secondary Lagoon
sludges and underlying soils include but are not limited to VDC,
vinyl chloride, ethyl benzene, and benzene.
The Emergency Lagoon lies between the Primary and Secondary
Lagoons. Its surface area is approximately 24,000 square feet.
Sludge volume is estimated at 1,800 cubic yards. The underlying
soils are primarily fine sands with thin layers of silt. Depth
to groundwater is about 34 feet. Contaminants present in the
Emergency Lagoon sludges and underlying soils include but are not
limited to VDC, vinyl chloride, ethyl benzene, and benzene.
2. Industrial Landfill
The Industrial Landfill operated from the early 1950's until
1980. During those years, the landfill received waste materials
from Grace's operations, which are detailed in a "Historical
Operational Usage Report" prepared by Grace in April 1983. " The
depth of the fill material varies as does the distance of fill
from the groundwater table. Results of a 1984 investigation of
the landfill reported in the "Sampling and Analysis Report for
Industrial Landfill" by Camp Dresser & McKee, April 1984
(Landfill S&A Report), found that the filled material was up to
19 feet deep. The distance from the bottom of the landfill to
the groundwater table was found to vary between 25 and 35 feet.
The volume of fill was estimated to be approximately 70,000 cubic
yards, of which perhaps 50 percent is backfilled soil, based on
test pit observations. The natural soil which underlies the
landfill is made up of mostly fine-medium sand with some coarse
sand, small amounts of silt, decomposed rock, and fine gravel,
and traces of clay and clay lenses.
The landfill wastes were characterized in the April 1984 Landfill
S & A Report. This section summarizes the descriptions in that
report, which were based on a test pit program and a groundwater
monitoring program. The test pit investigation generally
confirmed a *"istorical Operational Usage Report" issued by Grace
in April 198_ The most abundant material in the landfill test
pits was backfilled sand, which appeared to have been mixed with
the wastes in all areas. The waste materials, in approximate
relative order of abundance, were: coagulum (various types of
latices, synthetic rubbers); lagoon sludge; demolition debris;
miscellaneous trash (battery separators, rags, cardboard, paper);
crushed drums and open containers which originally contained
various rubber, oil, and sealing compounds. No closed containers
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were discovered. The distribution of these waste materials was
observed to be very heterogeneous both vertically and
horizontally.
The landfill also contains "perched" water in several parts of
the landfill in areas where wastes with low permeability such as
lagoon sludges hinder infiltration. Above these types of wastes
are zones of saturated materials. Areas where the fill is mostly
sand and solid refuse are not likely to support perched water.
The perched water tables appear discontinuous and are at varying
elevations. The volume of perched water varies with rain and was
estimated in the Landfill S & A Report to be 700,000 gallons in
March 1984. Volatile organic compounds were detected in all
perched water samples. The aromatics benzene, toluene, and
ethylbenzene are the most prominent compounds throughout the
perched water samples. Samples were taken in the unsaturated
soil beneath the landfill. Many of the contaminants present in
the landfill itself were also detected in the underlying soil.
3. North Lagoon
The North Lagoon is located north of the MBTA railroad tracks.
The lagoon received process washwaters similar to those which
were sent to the Primary Lagoon and it also received washing
waste from the Tank Car Area. The lagoon covers a 26,000 square
foot area and contains about 700 cubic yards of sludge which
varies from 6 inches to 2 feet in thickness. The underlying
soils are primarily fine sands with.silt. Groundwater elevation
fluctuates above and below the lagoon bottom. Volatile Organic
Compound (VOC) contamination was detected along with metals,
cyanide and phthalates in sludges and underlying soils.
Groundwater in the vicinity of the lagoon has shown
contamination.
4. Slowdown Pit
Materials placed in the Slowdown Pit included residues from the
venting of uncontrolled chemical reactions. The sludge, which
has solidified, has been covered with a layer of soil. The
underlying soil is generally fine to medium sand. Depth to
groundwater is about 53 feet. The Slowdown Pit contains the most
highly contaminated material on the site. Groundwater samples
have shown some of the highest VDC concentrations on the site.
5. Boiler Lagoon
The Boiler Lagoon received the annual flushings of phenolic resin
from two storage tanks that were adjacent to the battery
separator building. The Boiler Lagoon no longer receives
discharges from any activities. The underlying soils consist of
sand and silt. Depth to groundwater is about 37 feet. The
principal contaminants found in the Boiler Lagoon are phthalates
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and metals, including arsenic. Materials in and under the
Boiler Lagoon show lower contamination levels than the other
lagoons.
6. Battery Separator Area
The Battery Separator Area consists of three interconnected
lagoons (the Battery Separator Lagoons) and a chip pile (the
Battery Separator Chip Pile) which is bordering piles of cured
paper chips (scraps trimmed from the resin impregnated paper
manufactured at the plant) . The DEP has determined that the
Battery Separator Chip Pile is a solid waste landfill. Until
1977, the Battery Separator Lagoons received drainage from the
Cellulose Building. The underlying soils in this area are
primarily sands and silts with some gravel. Depth to groundwater
is about 37 feet. The principal contaminants found in the
Battery Separator Lagoons were ethylbenzene, formaldehyde, VDC,
benzene, phenol and some metals.
7. Tank Car Area
The Tank Car Area is located immediately north of the former
Organic Chemical Facility, abutting a railroad siding, some of
which is paved. The underlying soils consist of fine to coarse
sand and gravel. Depth to groundwater is about 45 feet. Between
the pavement and the siding lies a concrete drainage trench where
wastewater from tank car washings drained to the North Lagoon.
Materials deposited in the Tank Car Area consist of the residues
from raw materials transported to the plant by train. The
groundwater beneath the Tank Car Area is contaminated. Soils in
the Tank Car Area are contaminated with VDC, phthalates, and
metals.
B. Groundwater
The aquifer over which the Grace property lies consists mainly of
glacial deposits of two general types: (1) stratified sands and
gravels which readily transmit water and (2) an underlying layer
of less pervious glacial till which is a dense and relatively
impervious mixture of sand, gravel, clay, silt, cobbles and
boulders. The glacial deposits are, in turn, underlaid by
bedrock which is weathered and fractured to varying degrees.
This bedrock zone is also transmissive. The primary source of
groundwater in the aquifers underlying the study area is
precipitation. As precipitation enters the ground, it moves
downward through the unsaturated glacial deposits to the .
groundwater table. For the majority of the Grace property, the
groundwater table lies from 20 to 50 feet below the ground
surface. However, in the vicinity of the North Lagoon, the
groundwater table is generally at the ground surface.
There are three general groundwater flow fields under the study
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area. Groundwater north of a divide roughly defined by
Independence Road flows northward toward Fort Pond Brook.
Groundwater south of this divide flows southward in two general
directions. West of a line roughly defined by the property line
between W. R. Grace and the Acton Industrial Park, groundwater
flows southwesterly through the Assabet Well Field and the Mass.
Broken Stone Pit.. East of this line, the groundwater flows
southeasterly to the Assabet River. Under natural conditions,
groundwater generally flows upward into Fort Pond Brook and the
Assabet River.
1. Disposal areas and Groundwater Impacts
Under natural groundwater flow conditions, the Primary Lagoon,
Emergency Lagoon ajid part of the Blowdown Pit lie above the south
westerly groundwater flow field. The volatile organic
contaminants from these waste sites have contaminated the
groundwater including Assabet Wells, WRG-3 and the Massachusetts
Broken Stone Pit. The Blowdown Pit, under natural groundwater
flow conditions, sits above the groundwater divide. Therefore, a
portion of the contamination from the Blowdown Pit also flowed to
the north toward Fort Pond Brook. The Secondary Lagoon has
created a broad contaminant plume ranging from the eastern edge
of the Mass. Broken Stone Pit to the area east of the Landfill.
Furthermore, the Secondary Lagoon may have contaminated the
groundwater to the northeast. The Landfill plume flows
southeastward to the Assabet River. Plumes that might be
emanating from the Battery Separator Area, the Boiler Lagoon, the
Tank Car Area or the Korth Lagoon are being mixed with the plume
from the Blowdown Pit. Groundwater under these four waste units
flows toward Fort Pond Brook.
VI. SUMMARY OF SITE RISKS
A Risk Analysis was performed to estimate the probability and
magnitude of potential adverse human health and environmental
effects from exposure to contaminants associated with the site.
A complete discussion of site risks can be found in the Risk
Analysis prepared by EPA, dated June 30, 1989. From this
analysis, it is apparent that the Grace property in the absence
of remediation is likely to pose significant carcinogenic and
noncarcinogenic risks to huir.an health in the event that the
property is developed and used for residential purposes.
A. General Methodology
Twenty three indicator chemicals (8 for surface material such as
soils and sludges, and 15 for groundwater), listed in Table 1,
were selected for evaluation in the Risk Analysis. These
contaminants constitute a representative subset of the
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Table 1 - List of Indicator Chemicals
GROUNDWATER
SURFACE MATERIAL
Vinyl Chloride
Vinylidene Chloride
Benzene
Toluene
Trichloroethene
Ethylbenzene
Formaldehyde
Arsenic
Beryllium
Cadmium
Chromium
Copper
Lead
Nickel
Zinc
Vinyl chloride
Vinylidene Chloride
Benzene
Toluene
Ethylbenzene
Formaldehyde
Arsenic
Cadmium
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(contaminants identified at the Site during the investigations.
The 23 contaminants were selected to represent potential on site
hazards based on toxicity, level of contamination, and mobility
and persistence in the environment.
Potential human health effects associated with the contaminants
of concern in surface soils and groundwater were estimated
quantitatively through the development of several hypothetical
exposure scenarios. Exposure scenarios were developed to reflect
the potential for exposure to hazardous substances based on the
characteristic uses and location of the site. Two exposure
scenarios were evaluated in the risk analysis. The realistic
worst-case scenario is based on maximum concentrations of
chemicals in each medium, and the most-probable scenario utilizes
average contaminant concentrations. Furthermore, three exposure
pathways were included in the analysis; they are: ingestion of
groundwater, direct contact with surface materials, and
incidental ingestion of surface materials. The Grace site is
considered to be a single source for the evaluation of exposure
to contaminated groundwater; that is, site wide groundwater data
was used. LiXevise, exposure to surface materials was evaluated
collectively across the entire Grace site. Additionally, in
order to evaluate the risk associated with individual source
areas, an evaluation of exposures to surface materials
independently for each source area was conducted. The specific
feource areas evaluated were the lagoons (primary, secondary,
emergency, and north lagoon), the industrial landfill, the
blowdown pit, the battery separator area, the boiler lagoon, and
the tank car area.
Incremental lifetime cancer risks and a measure of the potential
for noncarcinogenic adverse health effects were estimated for the
various exposure scenarios. For carcinogenic compounds, risks
are estimated by multiplying the estimated exposure dose by the
cancer potency factor (CPF) of each contaminant. The product of
these two values is an estimate of the incremental cancer risk.
For noncarcinogenic compounds, a Hazard Index (HI) value was
estimated. This value is a ratio between the estimated exposure
dose and the reference dose (Rfd) which represents the amount of
toxicant that is unlikely to cause adverse health effects.
Generally, if the HI is less than one, the predicted exposure
dose is not expected to cause harmful human health effects. If
the HI exceeds one, the potential to cause noncarcinogenic human
health effects increases to an unacceptable level.
B. Direct Contact with Surface Material
Surface material at Grace varies in composition from one source
to another. In the lagoons, the primary surface material is
^ludge. However, at the landfill and the other disposal areas,
mhe primary surface material is contaminated soils. Therefore,
exposure point concentrations for these sources were developed
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utilizing material which exists at the surface at each source.
The exposures to surface materials were evaluated in two
independent analyses: jite wide exposure and source specific
exposure.
Under residential land use conditions, it was assumed that both
small children and adult/youths will be subject to exposure via
direct contact to surface material and ingestion of surface
material. In general, exposure via ingestion of solid material
by small children is greater than for adults or older children.
In sugary, the risks associated with direct contact with and/or
ingestion of surface material throughout the Grace site were less
than those from ground water ingestion. Under realistic
worst-case conditions, the total lifetime cancer risks were
observed to be 3.35 x 10"4 for direct contact and 3.22 x 10"6 for
ingestion exposures. The greatest risks were from exposure to
VDC, vinyl chloride, and arsenic. The hazard index did not
exceed unity for either scenario under realistic worst-case
conditions. Exposures to surface materials were also evaluated
for the specific source areas at Grace. The cumulative risk from
direct contact and ingestion of surface material was found to
exceed 10"4 for five of the six sources evaluated under realistic
worst-case conditions. The highest risk was seen for cumulative
lifetime exposures at the landfill (4.61 x 10"4). It is
recognized that there is limited source specific concentration
data for some of the specific source areas.
C. Ingestion of Groundvater
The primary risks observed in this analysis were those associated
with ingestion of contaminated ground water by a small child and
an adult/youth. Under realistic worst-case conditions, the
cumulative lifetime risks for ground water ingestion was found to
be 2.78 x 10"1. The greatest risks were associated with VDC,
vinyl chloride, and arsenic. For acute noncarcinogenic effects,
a cumulative hazard index of 3.99 was observed for adults/youths
under realistic worst-case conditions. For small children, the
cumulative acute hazard index was 9.31. Moreover, for chronic
effects, adult/youths showed a cumulative hazard index of 122
under realistic worst-case conditions, while the cumulative
hazard index for small children was 286. The indicator chemicals
.which contributed most, to these indices were vinyl chloride, VDC,
arsenic, lead, and zinc.
VII. DOCUMENTATION OP NO SIGNIFICANT CHANGES
EPA adopted a proposed plan (preferred alternative) for
remediation of sources of contamination at the site in August
1989, including:
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1) excavation and transportation off-site for incineration of
highly contaminated material from the Slowdown Pit;
2) excavation and stabilization of the remaining contents of
the Slowdown Pit, as well as the contaminated sludges and
soils of the Primary Lagoon, Secondary Lagoon, North Lagoon,
and Emergency Lagoon;
3) excavation of contaminated soils from the Battery Separator
Lagoons, Boiler Lagoon, and Tank Car area;
4) placing both the stabilized and the non-stabilized materials
excavated from the site on the existing Industrial Landfill,
and covering these materials with an impermeable cap;
5) closing the Battery Separator Chip Pile Area;
6) establishing Soil Cleanup Goals for all waste disposal
areas;
7) modifying the Aquifer Restoration System (ARS) to address
air stripper emission controls; and
8) establishing compliance monitoring at each disposal area
designed to monitor the effectiveness of the proposed
remedy.
The remedy selected in this ROD is consistent with the August
1989 Proposed Plan and indicates no significant changes from the
preferred alternative.
VIII. DEVELOPMENT AND SCREENING OF ALTERNATIVES
A. Statutory Requirements/Response Objectives
Prior to the passage of the Superfund Amendments and
Reauthorization Act of 1986 (SARA), actions taken in response to
releases of hazardous substances were conducted in accordance
with CERCLA as enacted in 1980 and the revised National Oil and
Hazardous Substances Pollution 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
these 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 CEPCLA establishes several other statutory
requirements and preferences,, including: a requirement that EPA's
remedial action, when complete, must comply with applicable or
relevant and appropriate environmental standards established
under federal and state environmental laws unless a statutory
waiver is invoked; a requirement that EPA select a remedial
action that is cost-effective and that utilizes permanent
solutions and alternative treatment technologies or resource
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recovery technologies to the maximum extent practicable; and a
statutory preference for remedies tha'~t permanently and sig-
nificantly reduce the volume, toxicity or mobility of hazardous
wastes over remedies that do not achieve such results through
treatment. Response alternatives were developed to be consistent
with these Congressional mandates.
The remedial objectives for the site closure program are
established to mitigate existing and future threats to public
health and the environment by considering the nature and extent
of contamination on-site, the potential exposure pathways and the
location and sensitivity of potential receptors. The cleanup
objectives are listed below.
1. Protect exposure points, where humans or wildlife may be
exposed to contaminants, in soil, groundwater, surface water
and sediments, during and after site remediation.
2. Prevent the migration of contaminants in groundwater from
sources on- site to public drinking water supplies.
3. Protect on- and off-site groundwater from contamination by
site contaminants in excess of drinking water quality.
4. Eliminate the potential for contact in the future with waste
materials by the public and the environment.
5. Protect on- and off-site surface water from contamination by
site contaminants.
6. Prevent the migration of contaminated run-off from the waste
sites.
7. Protect against direct contact with site contaminants and
minimize environmental exposure during remedial activities.
8. Reduce to the maximum extent practicable the number of
source areas to eliminate long-term management and permit
unrestricted use.
B. Technology and Alternative Development and Screening
CERCLA, the NCP, and EPA guidance documents including, "Guidance
on Feasibility Studies Under CERCLA11 dated June 1985, the
"Interim Guidance on Superfund Selection of Remedy" [EPA Office
of Solid Waste and Emergency Response (OSWER)], Directive No.
9355.0-15 (December 24, 1986), and the Interim Final "Guidance
for Conducting RIs and FSs under CERCLA," OSWER Directive No.
9355.3-01, set forth the process by which remedial actions are
evaluated and selected. In accordance with these requirements
and guidance documents, and consistent with the Consent Decree, a
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range of treatment alternatives were developed for the Site, a
containment option involving little or no treatment, and a no-
action alternative.
Section 121(b)(l) of CERCLA presents several factors that at a
minimum EPA is required to consider in its assessment of
alternatives. In addition to these factors and the other
statutory directives of Section 121, the evaluation and selection
process vas guided by the EPA document "Additional Interim
Guidance for F* '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-term Effectiveness and Permanence.
3. Reduction of Toxicity, Mobility or Volume.
4. Short-term Effectiveness.
5. Implementability.
6. Community Acceptance.
7. State Acceptance.
8. Cost.
9. Overall Protection of Human Health and the Environment.
Sections six and seven of the Phase IV Report identified,
assessed and screened technologies based on effectiveness,
implementability, and cost. These technologies were combined
into contaminant source control alternatives. Section seven in
the Phase IV Report presented the remedial alternatives developed
by combining the technologies identified in the previous
screening process in the categories required by OSWER Directive
No. 9355.0-19. Each alternative was also evaluated by the nine
evaivjation criteria in Section seven and summarized in Table 7.9-
1 of the Phase IV Report. In summary, six remedial alternatives
were developed and retained for detailed analysis. Table 2
identifies these six alternatives.
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Table 2 - Alternatives Retained for Detailed Analysis
Minimal No Action
Capping in Place Alternative 1
Stabilization and Combined Closure Alternative 2
on the Landfill
Excavation and On-Site Encapsulation Alternative 3
Partial Excavation and either Alternative 4
(a) On-Site Incineration or
(b) Off-Site Incineration
Complete Excavation and Incineration either
(a) On-Site or
(b) Off-Site.
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IX. DESCRIPTION/SUMMARY OP THE DETAILED AND COMPARATIVE ANALYSIS
OP ALTERNATIVES
This section presents a narrative summary and brief evaluation of.
each alternative according to the evaluation criteria described
above.
A. Source Control Alternatives Analyzed
The source control alternatives analyzed for the site include a
minimal no action alternative; Capping in Place; Stabilization
and Combined Closure on the Landfill; Excavation and On-Site
Encapsulation; Partial Excavation and either (a) On-Site
Incineration or (b) Off-site Incineration; Complete Excavation (
and Incineration either (a) On-Site or (b) Off-Site.
Minimal No Action
Analysis of the No Action alternative is required by federal law
and is included for comparison with other alternatives. In this
alternative, site conditions would remain unchanged and the ARS
would continue to remain in operation on the site. The no action
alternative would not achieve any of the remedial objectives.
This alternative would not be protective of public health or the
environment because it would not reduce existing risks from
contact with soils and would permit continued leaching of source
contaminants to groundwater. Additionally., this alternative
would cause no reduction in mobility, toxicity or volume of the
source contaminants present on-site. For these reasons, a no
action alternative would not be effective in the short- or long-
term in providing a permanent remedy. Since no action would
permit continued migration of contaminants at levels above
drinking water standards, this alternative would not comply with
ARARs for drinking water. The ARS would be required to continue
operations into the foreseeable future, and the sources and
groundwater would require long-term monitoring. No action would
not permanently address site contamination and would be
unacceptable to the community.
Estimated Period of Operation: 100 years
Estimated Operation and Maintenance Cost: $200,000
Estimated Total Cost: $2,000,000
Alternative 1
Capping in Place
In this alternative, the Primary, Secondary, and Emergency
Lagoons; Industrial Landfill; and the Slowdown Pit would be
capped in place. With the .exception of the excavation of
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approximately 20 cubic yards of contaminated materials for off-
site incineration, no other excavation would occur and each of
these waste disposal areas would be covered with impermeable .
caps. The construction of these caps would be generally the same
as is described under the selected remedy for the Industrial
Landfill (Section X.A.3.e). Each of the areas to be capped would
first be graded to ensure that clean run-off would drain off of
the caps. The North and Boiler Lagoons, the Battery Separator
Area, and the Battery Separator Chip Pile would be covered with
clean fill and seeded t-o control erosion. The pavement covering
the Tank Car Area would be drilled with a series of holes to
encourage movement of rainfall through the covered soils and
accelerate leaching out site area contaminants that would be
captured and treated by the ARS. The industrial Landfill would
be closed and covered with a cap.
This alternative would use readily available technologies and
services and would be easy to implement. Capping would achieve
a short-term reduction in public health risks by preventing the
potential for direct contact with wastes. However, there would
be no reduction of risks associated with the migration of
contaminants into the aquifer from wastes disposed of in the
other waste areas. Caps would reduce the mobility of the
contaminants migrating into the groundwater from the Primary,
Secondary and Emergency Lagoons, and the Industrial Landfill, but
would not restrict the mobility, toxicity or volume of wastes at
the Other Waste Areas. While groundwater contamination levels.
would recede over time, the protectiveness of this alternative
would be dependent upon the use of the ARS to attain drinking
water quality. Groundwater in the aquifer would not meet
drinking water ARARs and this alternative would not achieve the
remedial objective of restoring the aquifer in the shortest
practical period of time. In addition, this alternative would
not meet certain federal and state requirements for closure of
landfills. Another remedial objective that would not be attained
is that the number of source areas would not be reduced. Thus,
this alternative would require long-term management, monitoring
and maintenance, and the potential exists for replacement costs
if any of the individual caps at the ten source areas were to
fail. Finally, representatives of Massachusetts and the
community have already indicated that this alternative would not
be an acceptable remedial action.
Estimated Time for Construction: 1 year
Estimated Capital Costs: $3,270,000
Estimated Operation & Maintenance Costs:$1,228,000
Estimated Total Costs: $5,048,000
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Alternative 2
Stabilization and Combined Closure on the Landfill
Alternative 2 would excavate and solidify sludges and soils from
the lagoons, stabilize the excavated materials, place the
solidified mass on the industrial landfill, and construct an
impermeable cap on the landfill. Other waste areas would be
covered and monitored. This alternative was recomjnended by Grace
in the August 19S8 Phase IV Report as the cleanup and remedial
measure for addressing site contamination. Subsequent amendments
to Alternative 2, as subciitted by Grace in their June 6, 1989
Addendum., provided for the additional excavation of waste
materials from all of the disposal areas to attain soil cleanup
levels, and included plans for another groundwater extraction
well for contaminants migrating from the landfill.
This alternative, as modified by additional requirements for soil
cleanup levels, compliance monitoring, air emission controls, and
closure of the solid waste chip pile, has been chosen as the
selected remedy for the Site and is described in detail in
Section X.
Alternative 3
Excavation and On-Site Encapsulation
In this alternative, waste materials and two feet of soil would
be excavated from the Primary, Secondary and Emergency Lagoons,
as well as from the Slowdown Pit (twenty cubic yards from the
Slowdown Pit would be excavated for off-site incineration). The
excavated material would be consolidated in an encapsulation
system that would be constructed on top of the Industrial
Landfill. The encapsulation system would consist of a cap to
prevent rainwater from coming in contact with the wastes combined
with a leachate collection system that would prevent any waste
materials from migrating into the groundwater. Any leachate
captured by the collection system would be treated using the air
stripping tower that is part of the ARS. The encapsulation
system would cover approximately 50 percent of the Landfill
surface. The remaining 50 percent of the Landfill would be
covered with an impermeable cap. The Boiler Lagoon, Battery
Separator Area, Battery Separator Chip Pile, and the North Lagoon
would be covered with clean fill and seeded. The pavement
covering the Tank Car Area would be drilled with a series of
holes to encourage movement of rainfall through the covered soils
and to accelerate leaching out site area contaminants that would
be captured and treated by the ARS.
This alternative would be implemented using available
technologies and services and would be effective in containing
contaminants excavated from the disposal areas. Alternative 3
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would reduce the mobility of much of the contaminants on-site;
however, this reduction in mobility would not be achieved for
contaminants in the Boiler Lagoon, Battery Separator Area,
Battery Separator Chip Pile, and the North Lagoon source areas.
This alternative would not reduce the toxicity or volume of
contaminants (with the exception of the materials from the
Slowdown Pit that would be incinerated off-site). Alternative 3
would not protect groundwater from the migration of residual
contamination remaining in the excavated and unexcavated areas.
The protectiveness and long-term effectiveness of this
alternative would be dependent upon the use of the ARS to treat
contaminated groundwater prior to use as drinking water. Thus,
this alternative would not achieve the remedial objective of
restoring the aquifer in the shortest practical period of time.
Also, this alternative would not achieve drinking water ARARs in
groundwater at the Site. In addition, this alternative would not
reduce the number of contaminant source areas, requiring long-
term monitoring and maintenance to watch for and correct any
failure in the encapsulation system.
Estimated Time for Construction: 2.5.years
Estimated Capital Costs: $4,117,000
Estimated Operation & Maintenance Costs: $1,752,000
Estimated Total Costs: $5,869,000
Alternative 4
Partial Excavation and (a) On-Site Incineration
Partial Excavation and (b) Off-Site Incineration
Alternative 4 would excavate sludges and two feet of underlying
soil from tbe Primary, Secondary and Emergency Lagoons and the
Blov^own Pit. The excavated material would be incinerated at
eit. ur a transportable hazardous waste incinerator that would be
asser.bled on-site or it an off-site incinerator. The Boiler
Lagoon, Battery Separator Area, Battery Separator Chip Pile, and
the North Lagoon would be covered with clean fill and seeded.
The surfaces of the excavated lagoons and Slowdown Pit would also
be covered with clean soil. The pavement covering the Tank Car
Area would be drilled with a series of holes to encourage
movement of rainfall through the covered soils to leach out site
area contaminants for capture and treatment by the ARS. The
Industrial Landfill would be closed and covered with a cap.
In Alternative 4(a), in which the incinerator would be operated
on-site, ash resulting from the incineration process would be
placed on the Industrial Landfill. The landfill would be closed
and covered with an impermeable cap. In Alternative 4(b), the
contaminated materials and soil would be transported off-site in
specially designed water-tight trucks to a licensed hazardous
waste incinerator in compliance with all applicable state and
federal requirements and in compliance with the EPA's off-site.
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policy. Air pollution controls would be utilized to prevent any
release of contaminants during the incineration process.
Incineration is a proven technology and would permanently destroy
most of the site contaminants excavated from the Primary,
Secondary and Emergency Lagoons and the Slowdown Pit.
Incineration would not destroy metals that may be present in the
site contaminants, however, and could increase the concentration
of metals in the resulting incinerator ash. The mobility and
toxicity of remaining site contaminants would not be reduced, but
incineration would achieve some reduction in volume. This
alternative would not address residual contamination left in each
source area after excavation and would leave an undetermined
amount of waste in-place in the landfill and Other Waste Areas
with only a soil cover. Therefore, it would permit continued
migration of contaminants from the source areas into the
groundwater at levels exceeding drinking water standards.
Because this alternative would not expedite restoration of the
aquifer, it would not be protective of public health or the
environment and the long-term and overall effectiveness of this
alternative would be dependent upon the use of the ARS to protect
groundwater quality. On-site incineration would be
implementable, although test burns would be necessary to
establish performance parameters and engineering controls would
be necessary to protect worker health and safety during cleanup
activities. Off-site incineration may be difficult to implement
due to the limited nurier of existing commercially operated
incinerators licensed to accept wastes of the type found at the
W. R. Grace site and the problems associated with handling and
transporting large amounts of contaminated soils and sludges.
Limited availability would increase the time necessary to
complete the remedial action, which means this alternative would
net be effective in the short-term in achieving the remedial
objectives. 'Furthermore, transportation and incineration of
large volumes of wastes would be expensive and would pose
controllable short-term risks along the route to the incineration
facility.
Estimated Time for Construction: 5 years
Estimated Capital Costs:
On-Site: $10,862,000
Off-Site: $69,806,000
Estimated Operation 4 Maintenance Costs:
On-Site: $1,752,000
Off-Site: $1,752,000
Estimated Total Costs:
On-Site: $12,614,000
Off-Site: $71,558,000
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Complete Incineration
on-site . off-site
This alternative would involve the excavation and incineration of
contaminated sludges and soils in all of the source areas, except
from the Tank Car Area. The Industrial Landfill and an
additional two feet of soil underlying each area would be
excavated and incinerated from each waste disposal area. Costs
for incineration were evaluated for operation of both an on-site
incinerator and for tracking all vastes to an off-site
incinerator. On-site incinerator ash would be placed in a secure
landfill that would be constructed on-site.
This alternative vould be, protective of public health and
environment over the long-term. The mobility, volume and
toxicity of site contaminants would be permanently reduced. This
alternative would meet all the remedial objectives for the site
and it is anticipated that this alternative, if properly
implemented, would attain ARARs. Incineration of all
contaminated material in the source areas, and especially the
landfill, would pose substantial implementation problems. First,
the excavation of the landfill and materials storage and handling
would present the threat of contaminant release in air emissions
over several years. The potential for releases is increased for
off-site incineration, since the waste materials would have to be
prepared for shipment. Strict process, safety and engineering
controls would be necessary to protect site workers and public
health and the environment during excavation, waste storage and
handling, and incineration activities. Incineration of the
various types of waste materials that have been found in the
landfill Bay. require utilization of more than one incineration
technology and subsequent disposal of various types of waste
residuals. In addition, delays in implementation due to the
limited availability of licensed incinerators, together with the
potential need to utilize more than one technology, indicate that
this alternative would not provide short-term effectiveness.
Finally, the off-site incineration alternative would require
extensive truck or rail traffic, which would have to move through
the Town of Acton and would pose potential risks of accidental
releases and exposures over the duration of the remedial program
at the site.
Estimated Period of Operation: 4-8 years
Estimated Operation and Maintenance Costs:
Off-site: $1,728,000
On-site: $1,728,000
Estimated Total Cost:
On-site: $105,031,000
Off-site: $472,223,000
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X. THE SELECTED REMEDY •
The selected remedy is an operable unit that will address source
areas on site. As described in Section IV, Scope and Role of
Operable Unit or Response Action, this operable unit is a
integral portion of the overall site remedy.
A. Inscription of the Selected Remedy
1. Remedial Action Objectives
The selected remedy 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.
a. Waste Disposal Areas
Eliminate the risks from human contact in the future with waste
materials in the Lagoons (Primary, Secondary, Emergency, and
North); Industrial Landfill; Slowdown Pit; and, Other Waste Areas
(Battery Separator Lagoons, Battery Separator Chip Pile, Boiler
Lagoon, and Tank Car Area) by attaining the Soil Cleanup Goals
established for each indicated area.
Protect site workers from exposure to contaminants during all
phases of the remedial activities.
Reduce the number of waste disposal areas which require long-tern
management by consolidating, containing, and monitoring the waste
material in a protective manner.
Minimize environmental releases to the maximum extent practicable
during excavation of the waste disposal areas, while transporting
the excavated material to the VFL staging area or to the
landfill, while conducting the VFL process, while transporting
stabilized material from the VFL staging area to the landfill,
while placing the waste material on the landfill, or during any
other phases of the remedial action.
Protect on- and off-site surface water from contamination by site
contaminants.
Prevent the migration of contaminated run-off from any of the
waste disposal areas.
b. Groundwater
Protect current exposure points from contaminated groundwater
during and after site remediation.
Protect on- and off-site groundwater from contamination by
disposal areas.
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Expedite restoration of groundwater to drinking water quality in
the shortest practical period of time.
2. Soil Cleanup Goals
To meet these objectives, EPA has established Soil Cleanup Goals
that would be protective of public health and the environment.
The term Soil Cleanup Goals is intended to refer to indicator
compounds or any other compounds that EPA and DEP determine are
not adequately addressed by the currently selected indicator
compounds. Attaining the cleanup levels is expected to reduce
the level of contamination in the source areas so that any
further nigration of contaminants into the groundwater will not
exceed drinking water quality under the source area. Achieving
these Soil Cleanup Goals will expedite restoration of the aquifer
under the site to drinking water quality. Additionally,
attaining these goals will mitigate the threat posed by direct
contact to site contaminants.
Soil Cleanup Goals are established for five indicator compounds
which have been selected to represent the chemical contamination
in the waste disposal areas. They are: VDC, vinyl chloride,
ethylbenzene, benzene, and bis (2-ethylhexyl) phthalate. It is
expected that the attainment of the cleanup levels for these
compounds will reduce residual contamination of other compounds
found in the disposal areas to such low levels as to present no
significant risk from direct contact or from migration of
contaminants to the groundwater. The Soil Cleanup Goals for this
remedy also include other compounds that are identified at any
time in the underlying soils at levels that, through direct
contact of if allowed to leach into groundwater, would exceed
federal or state drinking water quality or exceed state
groundwater quality, or would present a carcinogenic risk of 1 x
10"6.
The Soil Cleanup Goals were generated by EPA using a model
developed by W. R. Grace and their consultants. The model and
the calculations for establishing the Soil Cleanup Goals are
described in Appendix A to this ROD. The EPA and DEP have
reviewed this model and believe that it is a reasonable tool for
developing appropriate Soil Cleanup Goals. The model calculates
the levels of the indicator compounds which, if left in each
disposal area as a residual, would not lead to further
contamination of groundwater at levels that exceed drinking water
standards. To the extent that Maximum Contaminant Levels (MCLs)
have been established under the federal and state drinking water
statutes for Site contaminants, the model has calculated the Soil
Cleanup Goals to ensure that groundwater passing under the
residual contamination is not degraded by those waste residuals
to levels that would exceed the promulgated drinking water or
groundwater quality standards. Specifically, the Soil Cleanup
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Goals for the following substances were established to attain the
following MCLs: VDC of 7 "ppb, vinyl chloride of 2 ppb, benzene of
5 ppb; the following proposed MCL: ethylbenzene of 700 ppb; and
the following risk based level: bis (2-ethylhexyl) phthalate of 2
ppb.
As noted previously, the Soil Cleanup Goals of this remedy are
protective of public health and are intended to facilitate the
restoration of the groundwater at the site. Attaining the Soil
Cleanup Goals of this remedy will not in itself result in the
immediate attainment of MCLs in groundwater at the Site.
Contamination that has already migrated into the groundwater will
still remain. Therefore, groundwater that passes under a
remediated source area may contain contaminants exceeding the
drinking water standards used for the Soil Cleanup Goals.
However, this remedy will reduce any additional contamination
from the migration of residuals so any future leachate from the
sources will not contaminate the groundwater above drinking water
quality. If site monitoring after the implementation of the
selected remedial action indicates that conditions are not as
predicted by the model, additional actions would be conducted to
assure protection of human health and the environment. Table 3
lists the Soil Cleanup Goals for this remedy.
3. Description of Remedial Components
The selected alternative addresses each of the following waste
disposal areas: Lagoons (Primary, Secondary, Emergency, and
North); Industrial Landfill; Slowdown Pit; and, Other Waste Areas
(Battery Separator Lagoons, Battery Separator Chip Pile, Boiler
Lagoon, and Tank Car Area). The individual components of the
selected alternative are described below.
a. Excavation and Stabilization of wastes in the
Lagoons and the Slowdown Pit and Placement of
Treated Wastes on the Industrial Landfill
Waste materials in the Primary, Secondary and Emergency lagoons,
including sludges and contaminated soils, will be excavated using
conventional construction equipment, such as backhoes. The
excavated contents will be treated on-site by stabilization using
the VFL process. Sludges and at least two feet of soil
underlying the sludges in the disposal areas will be excavated
and stabilized, thereby eliminating the majority of the
continuing source of groundvater contamination. Following
stabilization, the treated materials will be placed on top of the
Industrial Landfill, which will then be covered with an
impermeable cap.
All excavation and stabilization activities will be performed
using best engineering practices to minimize release of compounds
to the ambient air or underlying soils.
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able 3 - Soil Cleanup Goals
SOIL CLEANUP GOALS
concentrations in parts per billion (ppb)
RIMARY
AGOON
ECONDARY
AGOON
KERGENCY
AGOON
__>WDOWN
OILER
AGOON
ATTERY
EPARATOR
AGOONS
.-J:K CAR
.REA
VDC VINYL ETHYL
CHLORIDE BENZENE
17 19 1277
65 75 4914
8 9 619
15 17 1122
23 26 1741
15 18 1161
17 19 1277
BENZENE BIS-2
ETHYL
HEXYL
PHTHALAT
2 123
7 491.
1 61
2 112
3 . 174
2 116
2 12S
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Sediments from the North Lagoon will be ismoved, at a minimum, to
a depth equivalent to the low groundwater level so that there
will not exist a zone of residual contamination above the
groundwater table that will re-contaminate groundwater and •
require additional remedial work. Because of the location of the
North Lagoon, excavated materials from this area will be pumped
to the stabilization area as a slurry under the railroad bed with
equipment similar to that used to pump concrete. All of the
sludge and sludge contaminated sand above the low groundwater
level will be removed from the North Lagoon. The excavated
materials will then be transported to the stabilization unit in
equipment that will prevent releases of contamination during
transportation.
Materials in the Slowdown Pit containing greater than 100 parts
per million (ppm) of VDC will be excavated and shipped to an off-
site hazardous waste incinerator for treatment. The remaining
sludge and contaminated materials in the Slowdown Pit disposal
area and at least tvo feet of underlying soil will be excavated
and stabilized in the same manner as the lagoon area
contaminants. The stabilized material will also be placed on the
Industrial Landfill prior to construction of the cap. Prior to
any excavation activities at the Slowdown Pit, this disposal area
will be sampled in order to define the approximate volume and
area likely to be contaminated in excess of 100 ppm of VDC.
A sludge stabilization process developed by the VFL Technology
Corporation has been proposed by Grace and determined by EPA and
DEP to be an effective method at the pilot scale level for
minimizing the migration, or leaching, of site contaminants after
placement of the wastes on the Industrial Landfill. The VFL
process consists of excavating the contaminated soils and sludges
and mixing them with quicklime, flyash, and portland cement.
Pilot-scale tests of the VFL process were conducted at the W. R.
Grace site in the spring and summer of 1984. These tests were
designed to determine the most effective procedures for
stabilizing the type of sludges and contaminants found at the W.
R. Grace site. Mixing of the sludges with flyash and lime
results in the production of a material with the consistency of
soil. The material physically contains site contaminants and
absorbs any liquids that might be present in the contaminated
materials. The addition of portland cement creates a more solid
and stable material, increasing its suitability for placement
upon the Industrial Landfill prior to construction of the cap.
Excavation of the disposal areas and application of the VFL
process will be implemented sequentially lagoon by lagoon so as
to complete the stabilization from one lagoon before moving on to
the next lagoon. The total mixing of all wastes from a
particular lagoon with VFL materials will be done in batches.
The various materials will be metered from live bottom hoppers or
silos onto a moving belt that will convey them to a mixer. The
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mixer will be enclosed and'vented to an emission control system
which uses BACT, probably activated carbon, to prevent emissions
to the ambient air during this process step. The completed mix
will be transported to its final location at the landfill after
it demonstrates that it meets predetermined mixer specifications.
There will be separate mixtures used for the sludge, soil, and
combination of sludge and soil. Mixtures that were successfully
used for the pilot project will be used, and additional mixtures
may be pilot tested during design of the remedy. Periodic
testing for waste constituents at various stages of the
stabilization process will be conducted. It is estimated that
the solidification and placement on the landfill of all the
wastes from the lagoons will take 4-5 months. Approximately 350
truckloads of raw materials to be used in the VFL process will be
transported to the site at a rate of approximately 3 trucks per
day. During implementation of the remedy, measures to minimize
the impact of transporting this volume of material to the site
will be implemented.
b. Other Waste Areas
In order to attain the Soil Cleanup Goals established for the
other vaste areas; to consolidate as much source material from
the site on the landfill as practical; and to provide the fill
needed to construct the appropriate Landfill cap; the contents of
the Battery Separator Lagoons, the Boiler Lagoon, and the Tank
Car Area will be excavated to a depth of at least five feet.
These materials will be placed on the Landfill above the
stabilized materials to create a surface grade suitable for cap
construction. Although Site investigations indicate that the
waste materials from these areas contain low levels of
contaminants that would not require stabilization prior to
placement under the cap, the contaminant levels of all excavated
materials from this area will be analyzed prior to placement on
the Landfill. Should the analytical results show that a portion
of excavated materials is contaminated at unexpected levels that
indicate the unstabilized materials may present implementation
problems or impact on the effectiveness or protectiveness of the
landfill remedy, then those materials would be stabilized prior
to placement on the landfill or would be disposed off-site. If
post-excavation sampling and analysis indicate Soil Cleanup Goals
have not been attained, other actions under OU 3 would be taken
similar to those described for the Secondary Lagoon, Emergency
Lagoon and Slowdown Pit.
c. Post Excavation Analysis
Immediately following completion of the remedial actions to
excavate sludges and soils from each waste disposal area (not
including the Industrial Landfill and the Battery Separator Chip
Pile), comprehensive horizontal and vertical sampling of soils
will be performed to characterize residual contaminants at the
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disposal areas. The soils will be analyzed for all priority
pollutants plus the five highest non-priority peaks and metals.
The analytical results will be evaluated to determine whether
contamination is present at concentrations equal to or less than
the Soil Cleanup Goals. The post excavation sampling and
analysis program for a disposal area will be initiated within 30
days after completing the excavation of sludges, soils or
sediments from that disposal area, and the evaluation of the
results will be completed as soon as possible.
If the evaluation indicates that the areas have residual
contamination equal to or below the Soil Cleanup Goals as
specified in Section X.A.2, the excavated area will be graded,
covered with a minimum of six inches of clean top soil and seeded
or vegetated as necessary to establish and support growth to
control erosion.
If the evaluation indicates that the areas have residual
contamination at levels that exceed the Soil Cleanup Goals, then
the following actions will be taken.
For disposal areas where the Soil Cleanup Goals are not attained,
interim measures will be taken at each disposal area as soon as
possible to minimize the infiltration of surface water and
migration of contaminants into the residual soils for the period
immediately following excavation of each disposal area until a
remedy is selected under OU Two, as described below.
If residual contamination found in the Primary Lagoon exceeds the
cleanup goals set for the Primary Lagoon, an additional remedial
step, flushing, will be considered. This additional remedial
step is potentially feasible because of the close proximity of
the Primary Lagoon to the ARS extraction wells currently being
operated by Grace on the site. The decision to use this
additional remedial step will be based on the type and
concentration of contaminants identified. This additional step
will consist of flushing clean water through the excavated
Primary Lagoon and capturing this water (now containing the
residual contamination) using two existing extraction wells, SLGP
and SLBR, of the ARS. The effectiveness of the soil flushing
will be monitored and evaluated for two months. If flushing does
not prove to be effective in this period, actions will be taken
similar to those taken at the other disposal areas as described
below, and will include determining the nature and extent of
contamination and evaluating remedial options.
If the Soil Cleanup Goals set for any of the disposal areas,
including the Secondary Lagoon, Emergency Lagoon, Slowdown Pit,
Boiler Lagoon, Battery Separator Lagoons or Tank Car Area, have
not been attained following excavation of sludges and underlying
ksoils, OU Two will be implemented. Using the results of the post
"excavation sampling, an evaluation of remedial alternatives will
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be conducted for each disposal area to determine the most
appropriate remedial technology to apply to attain the Soil
Cleanup Goals. The nature and extent of contamination as well as
the criteria used in selecting the remedy in this ROD will be
considered in selecting remedial measures that will attain the
Soil Cleanup Goals. Alternatives that will be considered
include, but will not be limited to, additional soil removal
(possibly requiring solidification), and vacuum extraction. As
mentioned previously, the selection of any additional remedial
measures will be subject to the same remedial decision procedures
as the selection of this alternative and will be selected in a
supplemental ROD.
d. Battery Separator Chip Pile
The Battery Separator Chip Pile will be closed as a solid waste
landfill in accordance with Massachusetts Regulations in 310 CKR
19.00. These regulations require, among other things, capping
the disposal area with an impervious material. The final cap
over the Battery Separator Chip Pile vill consist of a minimum of
twelve inches of impervious final cover material with a
coefficient of permeability of less than or equal to 1 x 10"7
centimeters per second, or a synthetic equivalent, overlain by at
least a six inch minimum thickness of drainage blanket layer of
sand, and a top layer of at least six inches of loam that will
support vegetation. The final cap will be graded so that surface
water will not accumulate and will be at a slope greater than
three percent.
e. Industrial Landfill
The Landfill will be covered with the stabilized materials fron
the lagoons and Blowdown Pit and then graded using excavated
materials from the other waste disposal areas. The Landfill will
then be sealed, or closed, with an impermeable cap designed and
constructed in accordance with Massachusetts Hazardous Waste
Regulations for landfills specified at 310 CMR 30.580-595 and
30.620-633, as well as any other ARARs (see Section XI.B).
The impermeable cap will include a synthetic cover to prevent
infiltration of surface water (e.g., rain or snow melt waters)
into the waste materials beneath the cap. By preventing water
from coming into contact with contaminated materials, the cap
will prevent contamination from migrating into groundwater. In
addition, construction of the cap will prevent direct human and
environmental exposure to the excavated site contaminants and the
contents of the Landfill.
During design of the landfill closure, an evaluation of the
feasibility of monitoring the unsaturated soils below the bottom
of the landfill will be conducted. The intent of this monitoring
is to determine as soon as possible if a failure of any sort in
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the cap has permitted the generation of landfill leachate. To
the extent that this monitoring is found to be feasible,
implementable, and effective, it will be conducted.
Field survey control will be established at various points on the
landfill before any disposal activities on the landfill for use
in designing placement of materials and establishing the
boundaries of the landfill.
Additionally, during the design of the landfill closure, an
engineering analyses will be conducted to determine the potential
for differential settlement of the landfill. If the results of
the engineering analyses indicate the likelihood of differential
settlement that may affect the long term integrity of the cap,
deep dynamic densification or consolidation of the landfill will
be evaluated as a pre-construction activity to mitigate the
adverse impacts" of unpredictable settlement on the integrity of
the cap.
After survey data show that primary consolidation has occurred,
it is estimated that this may take 6 months to a year to occur,
the subgrade will be adjusted with additional common fill, if
necessary, and the final cap will be constructed. Liquids
released to groundwater during consolidation will be captured and
treated by the Industrial Landfill Groundwater Recovery System.
After the final cap is installed, survey control points will be
reestablished.
Interim measures will be taken as soon as possible at the
landfill during the consolidation period to minimize the
infiltration of surface water into, and surface water run off
from, the exposed landfill.
The landfill cap will be operated and maintained in accordance
with the requirements of 310 CMR 30.620-633. Groundwater and
survey monitoring will continue after closure for as long as
necessary to provide the protective remedy designed by this ROD.
The cap will be repaired as necessary, including total or partial
replacement if necessary. This remedy will include the
preparation of a landfill operation and maintenance plan that
will specify measures for ensuring the integrity of the cap and
for taking actions to investigate the need for repairs. A
degradation of groundwater quality downgradient of the landfill
or subsidence of the landfill cap or other indicators will be
used to evaluate the integrity of the cap. Zones of subsidence,
as defined by the survey control points, may indicate where
repairs are necessary. Cap repairs will be conducted as soon as
possible.
A groundwater monitoring and recovery system will be designed and
installed at the Industrial Landfill to supplement the existing
ARS recovery wells. The Industrial Landfill Groundwater Recovery
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System will be constructed as close as possible to the landfill
boundary to contain and collect any contamination migrating from
the Landfill. The existing eastern landfill recovery well (ELF)
may also be used as a component of this system. This system will
be installed and in operation prior to any remedial activities at
the Landfill. Sufficient monitoring wells will be installed, to
the extent that they do not already exist, to accurately identify
the conditions on all sides of the landfill and to monitor
groundwater on all sides of the landfill.
The cap will be constructed with vents through the Landfill cap
to allow gases from the existing landfilled material or newly
placed material to vent to the surface outside the Landfill.
These vents will be distributed over the entire area of the
landfill. Vents placed in the existing Landfill material will go
directly to the surface and will not be vented under the High
Density Polyethene (HOPE) membrane. A soil gas analysis will be
conducted over the landfill during design to determine
appropriate venting locations. To attain Massachusetts ARARs
found in Massachusetts Regulations 310 CMR 19.00 (Solid Waste
Regulations) and in 310 CMR 7.00 (Air Quality Control
Regulations), emissions from the Industrial Landfill vents will
be controlled utilizing best available control technology (BACT).
It is anticipated that BACT will eliminate any discharge of
contaminants to the ambient air. The gas control system will be
designed such that all vents can be combined into a common single
discharge point. Testing of the emissions discharged through the
venting system after complete installation of the cap will
determine the type of technology needed for control of the
emissions. The vents will also be used to monitor and evaluate
the integrity of the cap over time.
f. Upgrading the ARS Air Stripper Tower
In accordance with Massachusetts Air Quality Control Regulations
in 310 CMR 7.00, the ARS air stripping tower will be upgraded by
installing Best Available Control Technology (BACT). It is
anticipated that BACT will be carbon adsorption to control
contaminant levels in air emissions from the groundwater
treatment facility. This requirement is being imposed on new air
strippers and any existing units that are modified or found to
cause an odor. If additional controls or changes in operations
are needed to address odors, they will be required.
g. Groundwater Monitoring
A comprehensive groundwater monitoring plan will be implemented
to evaluate the effectiveness of the selected remedy. This
groundwater monitoring plan will be developed during the design
of the remedial action. Performance monitoring will be
implemented consistent with 310 CKR 30.660-675, including 310 CKR
30.672(4). Groundwater monitoring compliance wells will be
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installed at all disposal -areas prior to any remediation
activities at the site. They will be located in order to monitor
groundwater in each disposal area in a manner that ensures a
comprehensive horizontal and vertical delineation of groundwater
quality upgradient and downgradient of each disposal area. .
Comprehensive sampling and analysis of these wells would be
performed prior to initiation of any remedial action.
Additionally, these wells would be sampled during the remedial
action and at appropriate frequencies after the completion of the
remedial action to ensure source control measures have been
effective.
h. Review of the Remedy
In addition to the reviews planned as part of the remedy to
review the effectiveness of OU One in attaining the remedial
objectives, EPA plans to conduct other reviews of the Site.
Since hazardous substances, pollutants or contaminants will
remain at the Site following completion of this operable unit,
EPA will review the Site at least once every five years after the
initiation of remedial action at the site to assure that the
remedial action continues to protect human health and the
environment, in accordance with Section 121(c) of CERCLA. EPA
will also evaluate risk posed by the Site at the completion of
the remedial action (i.e. before the Site is proposed for
deletion from the NPL).
B. Rationale for Selection
The rationale for choosing the selected alternative is based on
the assessment of each criteria listed in the evaluation of
alternatives section of this document. 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 met these statutory requirements, EPA focused on the other
evaluation criteria, including, short term effectiveness, long
term effectiveness, iroplementability, 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, taking into account the
statutory preferences of CERCLA, EPA selected the remedial
approach for the Site.
The selected remedy provides the best combination of measures tc
address the contaminated areas. The selected alternative will
provide overall protectiveness of human health and the
environment. Potential contact with site contaminants by the
public would be eliminated. The selected alternative will reduce
the number of disposal areas that are the sources of continuing
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38
groundwater contamination to promote a more timely cleanup of
groundwater. The waste sludges and contaminated soils will be
created and then consolidated at the landfill where the
contaminants can be, monitored, managed and controlled more
effectively. The selected alternative will utilize treatment to
reduce the mobility, toxicity and volume of contaminants from the
Slowdown Pit by incineration and will significantly reduce the
mobility of other contaminants as a result of solidification and
containment. Engineering controls will be required for short-
term protection of site workers during excavation and waste
handling operations. The selected alternative will be readily
implementable and will attain ARARs. Finally, the selected
remedy attains all the response objectives.
Other alternatives evaluated in detail were considered less
acceptable. The minimal no action alternative was not selected
because it would not be protective of public health or the
environment, would not comply with ARARs, and would not achieve
the remedial objectives. Furthermore, the no action alternative
would not be effective in the short- or long-term in providing a
permanent remedy and would not be acceptable to the community.
All of the other action alternatives, -except for complete on-site
and off-site incineration, are not protective because they would
not adequately address the contamination in the Other Waste Areas
and would not address residual contamination left behind after
the remedial actions are taken. Those alternatives did not
include soil cleanup levels, and planned only to remove sludges
and two feet of underlying soils they may leave higher levels of
contaminants in each of the disposal areas, and would not address
contamination in the Other Waste Areas. Therefore, those
alternatives would not be as protective of groundwater that would
be affected by the migration of residual contamination.
Furthermore, the capping in place alternative, the encapsulation
alternative, and the partial incineration alternatives would only
install a permeable cover over the Boiler Lagoon, Battery
Separator Lagoons, Battery Separator Chip Pile, and the North
Lagoon source areas, which would permit flushing of residual
contaminant into the groundwater for the foreseeable future.
Thus, these alternatives would rely solely on the ARS to capture
the released contaminants and therefore extend the time period
for restoration of the aquifer to drinking water quality.
Consistent with this analysis, the only protective alternatives
that vere evaluated were the selected remedy and the complete
incineration alternatives. Both the on-site and off-site
complete incineration alternatives would address all the disposal
areas except for the Tank Car Area and thus provide a level of
protectiveness similar to the selected alternative. However, the
cost of the complete incineration alternatives are not
proportionate to the protectiveness provided.
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39
Although the capping in place alternative and the encapsulation
alternative reduce the mobility of some of the site contaminants,
they do not use treatment as a principal element to attain such
reduction. The incineration alternatives would use treatment to
reduce the mobility, toxicity and volume of the wastes and .
provide a permanent reduction of contaminants. However, the
incineration alternatives are not cost-effective because their
costs are disproportionate to their effectiveness in providing a
protective remedy.
Considering the implementability of the alternatives, all the
alternatives except the complete incineration alternative are
readily implementable. The complete incineration alternative,
either on-site or off-site, would take significantly longer to
complete than will the selected remedy, and would pose difficult
implementation problems. First, the excavation of the landfill
would present the threat of contaminant release to groundwater
and in air emissions throughout the duration of the project.
Strict process engineering and safety controls would be necessary
to protect site workers, public health and the environment during
excavation, waste handling and storage and incineration
activities. Incineration of the various types of waste materials
that have been found in the landfill also could require
utilization of more than one incineration technology and
subsequent disposal of various types of waste residuals. In
addition, the off-site incineration alternative would require
extensive, truck traffic in and through the residential
communities surrounding the site.
XI. STATUTORY DETERMINATIONS
The remedial action selected for implementation at the W. R.
Grace Site is consistent with CERCLA and, to the extent
practicable, the NCP. The selected remedy is protective of hur.an
health and the environment, attains ARARs and is cost effective.
The selected remedy also satisfies the statutory preference for a
permanent solution to the maximum extent practicable and for
treatment which reduces the mobility, toxicity or volume as a
principal element. Additionally, the selected remedy utilizes
alternate treatment technologies to the maximum extent
practicable.
A. The Selected Remedy is Protective of Human Health and
the Environment
The selected remedy at this site will attain the remedial
objectives and will permanently reduce the risks posed to human
health and the environment by exposure to contaminated source
areas. The Soil Cleanup Goals have been selected to achieve
drinking water standards in groundwater under each disposal area
and protect against the potential risks from continued leaching
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40
of source area contamination into the groundwater.
Specifically, attaining the Soil Cleanup Goals will reduce the
level of contamination in the source areas so that any further
migration of contaminants into the groundwater will not cause the
groundwater on site to exceed drinking water standards (including
MCLs). Achieving these Soil Cleanup Goals will reduce the time
necessary for restoration of the aquifer under the site to
drinking water quality.
The soil cleanup levels to be attained by this remedy will reduce
the risks from direct contact to and incidental ingestion of
contaminated soils to a level protective of human health. The
cumulative risk, under residential assumptions, associated with
direct contact plus ingestion for the four indicator compounds
that are carcinogens at the established Soil Cleanup Goals is
8.34 x 10"7.
The solidification of excavated waste and soil materials and
placement on the Industrial Landfill and construction of an
impermeable cap over the materials in the landfill will provide a
barrier to protect against exposure wastes- and contaminated soils
by both human and environmental receptors. The combination of
solidification, placing on the landfill and capping will
significantly reduce the mobility of contaminants in the
landfill. Consolidation of the waste materials on the existing
landfill and under the landfill cap will reduce the number of
potential sources of contamination and allow for more effective
monitoring, management, and maintenance of contaminants.
There are two areas on-site where waste will be left in place
under a cap which will require long term management. Periodic
site inspections and maintenance will be performed to ensure the
integrity of the caps, and their effectiveness in preventing
exposure to the waste materials which they cover. Safe and
protective long term management will be accomplished by proper
inspection, monitoring and maintenance of the cap systems.
In addition, EPA plans to conduct periodic reviews of the
remedy's effectiveness in attaining the protectiveness
established as remedial objectives and in order to ensure that
the remedy remains protective. Institutional controls will be
implemented to regulate land use of the Industrial Landfill and
Battery Separator Battery Separator Chip Pile including
activities which may compromise the integrity of the caps. These
controls will supplement requirements of the existing Consent
Decree, which required Grace to file a notice with the Registry
of Deeds and to obtain the consent of the United States before
transferring any property at the Site.
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41
B. The Selected Remedy Attains ARARs
This remedy will meet or attain all applicable or relevant and
appropriate federal and stricter state requirements that relate
to the site. Federal Environmental laws which are applicable or
relevant and appropriate to the selected remedial action for this
operable unit at the W. R. Grace - Acton Site are:
Clean Water Act (CWA)
Safe Drinking Water Act (SDWA)
Resource Conservation and Recovery Act (RCRA)
Clean Air Act (CAA)
Occupational Safety and Health Administration (OSHA)
State environmental regulations which are applicable or relevant
and appropriate to the selected remedial action at the Site are:
Massachusetts Dept. of Environmental Protection (DEP) Regulations
Hazardous Waste Regulations
Drinking Water Regulations
Air Quality Standards ~
Air Pollution Control Regulations
Groundwater Quality Standards
Solid Waste Regulations
Water Pollution Control Regulations
Table 4 lists the chemical specific ARARs and outlines the action
which will be taken to attain the ARARs. Table 5 indicates the
action specific ARARs, presents a brief synopsis of the
requirements, and outlines the action which will be taken to
attain the ARARs. No location-specific ARARs have been
identified. A brief narrative summary of the ARARs follows.
1. Chemical Specific
The groundwater at the Site, both on-site and immediately off-
site, is a source of drinking water. Maximum Contaminant Levels
(MCLs) promulgated under the Safe Drinking Water Act and
Massachusetts Drinking Water Standards, which regulate public
drinking water supplies, are applicable to drinking water at the
tap and are not applicable to groundwater. However, because the
groundwater is used as drinking water source, MCLs are relevant
and appropriate. The Massachusetts drinking water standards
applicable to this Site are the same as the MCLs. Groundwater at
the Site is classified as Class I by Massachusetts, making the
Massachusetts Groundwater Quality Standards (MGWQS) listed under
314 CMR 6.07 applicable to the groundwater aquifer. The MGWQSs
applicable to this Site are the same as the MCLs. This operable
unit will attain these ARARs by meeting the Soil Cleanup Goals
for the compounds with promulgated MCLs and MGWQS. By reducing
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TABLE 4
CHEMICAL SPECIFIC
APPLICABLE OR RELEVANT AND APPROPRIATE REQUIREMENTS FOR
THE SELECTED REMEDY AT THE
W R GRACE - ACTON SUPERFUND SITE, ACTON, MASSACHUSETTS
ARARs
FEDERAL SOWA - Maximum
Contaminant Levels
(MCLs)(40 CFR 141.11-
141.16)
Contaminant
Benzene
Vinyl chloride
VDC
MCL
5 ppb
2 ppb
7 ppb
MASSACHUSETTS - Drinking
Water Regulations (310 CMR
22.00)
REQUIREMENT SYNOPSIS
MCLs have been promulgated
or proposed for a number
of common organic and
inorganic contaminants.
These levels regulate the
concentration of
contaminants in public
drinking water supplies,
and may be relevant and
appropriate for
groundwater aquifers used
or potentially used for
drinking water.
Establishes maximum
contaminant levels for
drinking water supplies,
as the federal MCLs.
ACTION TO BE TAKEN TO
ATTAIN ARARs
MCLs for indicator
compounds are the target
cleanup levels for
groundwater under each
waste area; attaining the
Soil Cleanup Goals will
ensure that any future
migration of residual
contaminants in the soil
will not exceed MCLs in
groundwater under each
waste area.
State drinking water
standards are the same as
federal MCLs that will be
attained.
MASSACHUSETTS -
Groundwater Quality
Standards (314 CMR 6.00)
Establishes minimum
groundwater quality
criteria.
State groundwater criteria
will be attained by
reducing residual soil
contaminants to the Soil
Cleanup Goals.
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TABLE 5
ACTION SPECIFIC
APPLICABLE OR RELEVANT AND APPROPRIATE REQUIREMENTS FOR
THE SELECTED REMEDY AT THE
W R GRACE - ACTON SUPERFUND SITE, ACTON, MASSACHUSETTS
ARARs
MASSACHUSETTS- Standards
for Owners and Operators
of Permitted Hazardous
Waste Facilities (310 CMR
30.510-516)2
REQUIREMENT SYNOPSIS
General facility
requirements for waste
analysis, security
measures, inspections, and
training requirements.
ACTION TO BE TAKEN TO
ATTAIN ARARs
Facility would be
constructed and operated
in accordance with this
requirement. All workers
would be properly trained,
MASSACHUSETTS -
Contingency Plan,
Emergency procedures,
Preparedness and
Prevention (310 CMR
30.520-524)
MASSACHUSETTS -
Manifesting,
Recordkeeping, and
Reporting (310 CMK 30.530
545)*
Safety equipment and spill
and leak control.
Emergency procedures to be
used following explosions,
fires, etc.
Requires manifesting
hjzardoud waste shipped
off-sito for disposal.
Safety and communications
equipment will be
installed at the site, and
local authorities will be
familiarized with the
operation. Plans would be
developed and implemented
during remedial design.
Copies of the plans would
be kept on-site.
Waste materials shipped
off-site for incineration
will be manifested.
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MASSACHUSETTS - Closure
and Post-closure (310 CMR
30.580-595)2
MASSACHUSETTS - Landfills
(310 CMR 30.620-633)
Closure and post-closure
of hazardous waste
facilities. Comprehensive
program for closure and
post-closure of hazardous
waste facilities are
generally relevant and
appropriate. The
requirements for double
liners are not appropriate
for this site because the
solidified material will
be placed on top off an
existing landfill. A
leachate collection system
is not appropriate because
the ARS extraction wells
will collect any
contaminants migrating
from the landfill.
Establishes requirements
for construction,
operation, monitoring and
maintenance of hazardous
waste landfill.
The remedy will meet
closure requirements
because there would be a
substantial removal of
waste from the disposal
areas; residual
contamination would have
low mobility and toxicity;
pathways of potential
exposure would be limited;
and long-terra monitoring
would be provided.
Hazardous materials
excavated from the
disposal areas will be
stabilized and solidified,
and contained by placing
an impermeable cap over
the landfill that meets
the RCRA cap standards. A
30-year post-closure
program will include
monitoring and maintaining
the cap, and monitoring
groundwater.
The landfill cap will be
constructed, operated and
maintained in accordance
with these requirements.
The double liner and the
leachate collection system
are not appropriate for
this Site.
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MASSACHUSETTS -
Groundwater Protection
(310 CMR 30.660-675)2
Performance requirements
for a groundwater
monitoring network, and
standards for a monitoring
program and sample
analysis.
Groundwater at each
disposal area will be
monitored to determine the
effectiveness of the
remedial measures; a
groundwater monitoring
program is already being
implemented as part of the
aquifer restoration
system.
FEDERAL CAA - National
Ambient Air Quality
Standards (40 CFR § 50.6)'
FEDERAL OSHA - Worker
Safety Regulations (29 CFR
1926)T
Maximum primary and
secondary 24-hour
concentrations for
particulate matter.
Specifies the type of
safety equipment, training
and procedures to be
followed during
construction of the
remedy.
Standards for particulate
matter will be met during
excavation and
stabilization activities,
and construction of the
landfill cap and Chip Pile
cap.
This regulation will be
applicable during
construction of the
selected remedy.
FEDERAL Protection of
Archaeological Resources
(32 CFR § 229.4)1
Procedures for the
protection of
archaeological resources.
If archaeological
resources are encountered
during soil excavation,
work would stop until the
area has been reviewed by
federal and state
archaeologists. Research
already completed suggests
that none would be found
at this site.
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FEDERAL DOT - Rules for
the Transportation of
Hazardous Materials (49
CFR 107, 171.1 - 171.500)1
Specific requirements for
markings, vehicle
registration, manifests,
and transportation of
hazardous wastes and
chemical substances.
MASSACHUSETTS - Ambient
Air Quality Standards, 310
CMR 6.00, and Air Quality
Control Regulations, 310
CMR 7.00)1
Establishes primary and
secondary standards for
emissions of dust, odor
and noise from
construction and remedial
activities.
Prior to transportation
for off-site incineration,
waste from the Slowdown
Pit will be properly
classified, packaged,
manifested, marked, and
labelled, and must have
registration numbers
including the letters DOT.
Transportation of
materials on-site for the
VFL process will meet
these requirements.
Particulate and noise
emissions during
excavation and
solidification activities
will be meet the
requirements. Odor
emissions from the
groundwater treatment air
stripper will be
controlled with Best
Available Control
Technology ("BACT"). A
gas control system
utilizing bACT will be
installed during
construction of the
landfill cap to control
emissions.
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MASSACHUSETTS - Sanitary
Requirements for closure
Landfill Regulations (310 of solid waste landfills.
CMR 19.00)'
The Battery Separator Area
chip piles will be closed
as a solid waste landfill
with, among other things,
an intermediate cover
consisting of impervious
material or flexible
membrane which prevents
the percolation of surface
or rain water.
1. Applicable.
2. Relevant and Appropriate. i
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44
levels of residual contamination in the disposal areas to these
Goals, any leachate migrating from these disposal areas will not
contaminate the groundwater at levels exceeding the ARARs.
2. Action specific
a. Federal Hazardous and Solid Waste Amendments
to the Resource Conservation and Recovery Act
The Commonwealth of Massachusetts has been authorized by EPA to
administer and enforce RCRA programs in lieu of the federal
authority. The authorized state hazardous waste regulations are
equivalent to or more stringent than the federal RCRA
regulations. Compliance with Massachusetts RCRA regulations is
discussed below.
The applicability of HSWA regulations, specifically the Land
Disposal Restrictions (LDR) promulgated under Section 3004 of
RCRA, depends on whether the wastes are RCRA hazardous wastes, as
defined under RCRA and in EPA regulations at 40 C.F.R Part 261.
In this case, EPA has determined that the soils and sludges to be
excavated aj?d disposed of on the landfill -are not RCRA hazardous
wastes. The EPA has also determined that the sludges to be
excavated are not sufficiently similar to warrant applying these
regulations as relevant or appropriate.
b. Massachusetts PEP Hazardous Waste Regulations
Some Massachusetts' DEP Hazardous Waste Regulations are relevant
and appropriate to the implementation of this remedy. Although
this site does not have hazardous wastes, as discussed above,
many of the state hazardous waste regulations for operating a
hazardous waste facility and managing hazardous wastes are
appropriate requirements for the kind of activities that will be
taken at the Site and, therefore, are relevant and appropriate to
the implementation of the remedy. Specifically, implementation
of the remedy will comply with the following provisions of the
Massachusetts hazardous waste regulations at 310 CMR 30.00:
General management standards for all facilities (310 CMR 30.510-
516) ; Contingency plan, emergency procedures, preparedness, and
prevention (310 CMR 30.520-524); Manifest system (310 CMR 30.530-
534); Closure and post-closure (310 CMR 30.580-595); Landfills
(310 CMR 30.620-633); Groundvatei protection (310 CMR 30.660-
675); Use and management of containers (310 CMR 30.680-689).
The placement of contaminated soils and sediments under a cap
will occur outside the 100-year floodplain, in accordance with
location standards in the Massachusetts Hazardous Waste
Regulations. Massachusetts closure and post-closure requirements
requiring, among other things, that a cap attain a certain low
permeability standard and act to minimize migration of liquids
through the landfill in the long term, will be attained. In
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45
addition, the substantive elements of the contingency:plan,
emergency procedures, preparedness and safety requirements will
be satisfied.
The portion of the landfill regulations requiring a double liner
and a leachate collection and removal system are not appropriate
to the site and will not be attained. Large volumes of wastes
will be left in the landfill underlying the solidified material.
Thus, placement of a double liner over the wastes in the landfill
would be ineffective in containing the wastes. Any leachate
that migrates from the landfill will be intercepted and collected
by the Industrial Landfill Groundwater Recovery System.
c. Massachusetts Solid Waste Regulations
Closure of the Battery Separator Chip Pile will be conducted in
accordance with the Massachusetts requirements for closure of a
solid waste landfill. The chip pile, composed of waste trimmings
discarded frczi the battery separator manufacturing operation, is
considered a solid waste. The selected remedy for the chip pile
will comply with 310 CMR 19.00, by installing an impermeable
cover that will prevent the percolation of- surface or rainwater,
constructing the cap with proper slopes/finished grades, and
groundwater monitoring.
d. Federal Clean Air Act and Massachusetts Air
Quality and Air Quality Control .regulations
The National Ambient Air Quality Standards promulgated under the
Clean Air Act are applicable to the control of particulate matter
and will be attained during excavation, treatment, and .
construction phases.
The Massachusetts Ambient Air Quality Standards are also
applicable to the control of particulate emissions and noise
during excavation and construction activities. The Air Quality
Control regulations at 310 CMR 7.00, which authorizes the control
of existing air strippers using Best Available Control Technology
(BACT) for odor emissions, will be attained by installing a
treatment system for air emissions from the ARS groundwater
treatment facility. In addition, collection and treatment 'by
BACT of gases generated by the landfill before release to the
ambient atmosphere will comply with this ARAR.
e. Federal Occupational Safety and Health Act
regulations and Massachusetts Right to Know
law
OSHA standards for general industries and health and safety
standards will be attained.
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46
f. U.S. Department of Transportation Regulations
Any wastes excavated from the Slowdown Pit for off-site
incineration will be transported in accordance with Department of
Transportation regulations.
C. The Selected Remedial Action is Cost Effective
Of those remedial alternatives that are protective and attain
ARARs, EPA's selected remedy is cost-effective in providing a
protective remedy in a reasonable period of time. The cost
effective remedy is a protective remedy whose costs are
proportionate to its overall effectiveness.
Table 6 is a summary of the cost information for each alternative
as provided in the Phase IV Report:
While the No Action Alternative is the least expensive
alternative, it is not protective of human health or the
environment and therefore is not a cost effective remedy
Complete On-Site Incineration and Complete-Off-Site Incineration
are the most expensive of the alternatives. While complete
incineration would be effective in permanently reducing
contaminant levels at the site, the costs of these alternatives
are so great as to be disproportionate to their effectiveness.
Furthermore, these alternatives will be difficult to implement
and are not effective in the short term. These two alternatives
will not be more protective than the selected remedy, will take
much longer to complete, and are 15 and 67 times more expensive
respectively than the selected remedy. For all of these reasons,
EPA concludes that these alternatives are not cost effective
because the additional costs do not provide a proportionately
greater degree of effectiveness.
The Excavation and On-Site Encapsulation alternative and the
Partial On Site Incineration alternative have reasonably similar
costs when compared to the selected remedial action. However,
similar to the three incineration alternatives just discussed,
these two alternatives do not. include soil cleanup levels, and
plan only to remove sludges and two feet of underlying soils.
Thus, they do not address residual contamination left behind
after the remedial action is taken.
Furthermore, these two alternatives do not adequately address the
Other Waste Sites. The Excavation and On-Site Encapsulation
alternative does not use treatment as a principle element to
reduce the mobility, toxicity or volume of the wastes. This
alternative will not provide greater protectiveness than the
selected remedy and therefore, is not cost effective. The
partial on site incineration is much more difficult to implement,
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Table 6 - Cost Summary of Each Alternative
ALTERNATIVE
NO ACTION
CAPPING IN
PLACE
SOLIDIFICATION
AND CLOSURE OF
LANDFILL
ENCAPSULATION
LANDFILL
ON SITE
INCINERATION
OFF SITE
INCINERATION
COMPLETE
ON SITE
INCINERATION
COMPLETE
OFF SITE
INCINERATION
TOTAL COST
$2,000,000
$5,048,000
$7,058,000
$5,869,000
$12,614,000
$71,558,000
$105,031,000
$470,223,000
CAPITAL
COSTS
$0
$3,270,000
$4,590,000
$4,117,000
$10,862,000
$69,806,000
$103,303,000
$470,495,000
O & M COSTS
$200,000
$1,778,000
$2,468,000
$1,752,000
$1,752,000
$1,752,000
$1,728,000
$1,728,000
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48
is not as effective in the short term, would not be as
protective, and is almost twice the cost of the selected
alternative. Therefore, partial on site incineration is not
considered cost effective.
The Capping in Place alternative has reasonably similar costs
when compared to the selected remedial action. However,
considering the evaluation criteria, capping in place does not
use treatment as a principle element to reduce the mobility,
toxicity or volume of the wastes, it is .not as effective in the
long term as the selected alternative, and does not attain the
response objectives for site cleanup. Therefore, capping in
place is not considered cost effective.
D. The Selected Remedy Utilizes Permanent Solutions and
Alternative Treatment Technologies or Resource Recovery
Technologies to the Maximum Extent Practicable
The EPA has determined that the excavation, solidification and
placement on the landfill and the capping components of the
operable unit utilize permanent solutions and treatment
technologies to the maximum extent practicable.
Remediation of the Primary Lagoon, Secondary Lagoon, Emergency
Lagoon, Blowdown Pit, Battery Separator Lagoons, Boiler Lagoon
and Tank Care Area to attain the Soil Cleanup Goals will provide
a permanent solution.
Capping and properly closing and monitoring the Industrial
Landfill is fully protective of human health and the environment.
However, wastes materials in the landfill will be left in place.
In this case, it is technically impractical from an engineering
perspective to excavate and thermally destroy all the wastes
contained in the Industrial Landfill, and therefore technically
impracticable to permanently eliminate all waste materials at the
Site. This is based primarily on the nature of the wastes
present in the landfill. The evidence indicates that the
landfill contains a wide variety of materials in a five acre area
that is filled up to 19 feet deep. Excavation, waste handling
and thermal destruction would take up to eight years to complete,
and would present a significant potential for releases to
groundwater, surface water and air during implementation.
Both incineration of the Blowdown Pit materials and
solidification of sludges and soils from the disposal areas are
alternative treatment technologies. Thus, the selected remedy
satisfies the requirement to select a remedy that utilizes
alternate treatment technologies.
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49
B. Tbe Selected Remedy Satisfies the Preference for
Treatment as a Principal Element
The selected alternative uses solidification treatment as a
principal element of the remedy to reduce risks associated with
the site. Tbis element addresses the primary threats at the site
which are associated with the source areas. Approximately 39,000
cubic yards of source material will be treated by the VFL
solidification process.
Stabilization and placement of wastes on the landfill will reduce
the mobility of contaminants. The stabilization process converts
the contaminated sludges and soils into a permanent, impermeable
compacted mass exhibiting properties similar to that of soil
cement. Leaching tests conducted as part of the pilot study
showed that contaminant mobility from the stabilized material is
significantly reduced.
Additionally, incineration of the most highly contaminated
material from the Slowdown Pit will permanently reduce the
mobility, toxicity and volume of this portion of wastes present
at the site.
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 State has
also determined 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 for the W. R. Grace Acton Site. A copy of
the declaration of concurrence is attached as Appendix D.
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APPENDIX A - MODEL DESCRIPTION
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The Record of Decision (ROD) contains a tabulation of Soil Cleanup
Goals for "five indicator compounds in seven waste areas at the
site. As the ROD indicates, these levels are protective of public
health and are intended to facilitate restoration of the
groundwater at the site. It is expected that attaining these soil
cleanup levels in disposal areas will allow groundwater beneath
these areas to be restored to drinking water standards. These
cleanup levels have been calculated using a model developed by Camp
Dresser & McKee for VJ. R. Grace, and is based on published research
and experimental data evaluated by EPA.
There are two aspects to this model: a conceptual or descriptive
model of how contamination is released from the source areas and
migrates into the aquifer beneath the site, and a mathematical
approach for calculating and quantifying the distribution and
transfer of contaminants through the soil and into the aquifer.
In the conceptual model, water from precipitation and snow melt
percolates through the pores in the soil of the disposal areas.
The source area soil consists of three phases or "compartments":
soil particles, air in the pore spaces between the soil particles,
and moisture (water) in the pore spaces. The moisture migrates
through the soil and leaches out some of the residual
contamination. The moisture content is continuously replenished by
precipitation from above, so that the net volume percent of
moisture in the bulk soil is constant. The water (i.e. leachate).
migrates downward beneath the source area and enters the ground
water. When it reaches the water table, the leachate mixes with
the ground water beneath the source area and is diluted through the
entire thickness of the aquifer above the bedrock. Because the
groundwater beneath the site is flowing, the leachate entering the
aquifer from the source above is continuously diluted by "fresh"
groundwater arriving from upgradient. Leachate will be most
diluted beneath sites where the aquifer is thickest and where
ground water flow is most rapid.
Using the mathematical model, EPA calculated what the allowable
bulk concentration of each contaminant in the soil could be, and
still ensure that the concentration of indicator compounds in
groundwater beneath the site be less than federal drinking water
standards (maximum contaminant levels, MCL). The mathematical
model consists of two parts. The first part of the calculation is
commonly referred to as the Mackay method Level I, and it is a
means of calculating the concentration and the quantity of each
contaminant in each phase or compartment in the source area (i.e.,
soil particles, air in pores, and moisture). The second part of
the mathematical model calculates how the leachate emerging fron
the source areas will be diluted when it reaches the ground water.
-------
The Level I Mackay method (Mackay, 1979, 1981) is based on a
fundamental principle of chemical thermodynamics which states that
the fugacity of a chemical substance (e.g. vinyl chloride) must be
equal in every phase (compartment) in the system at equilibrium.
Fugacity is a thermodynamic property which may be thought of as the
"escaping tendency" of a chemical substance from a phase.
Fugacity, f, has units of pressure, and it may be directly related
to concentration (C) through a factor Z:
C = f Z (1)
Z depends on temperature, pressure, the nature of the chemical
substance, and the medium or phase in which it is present. At a
given fugacity, if Z is low, C is low, and only a small amount of
substance is necessary to exert the escaping tendency. Toxic
substances thus tend to accumulate in phases where Z is high. Z
permits one to calculate how a substance will partition among
several phases in equilibrium.
For a gas (i.e. the pore air compartment), the fugacity is
approximately equal to the partial pressure of the chemical
substance, and Z can be shown to be equal to 1/RT, where R is the
gas constant (8.2 x 10~5 atm-m3/n>ol-deg) and T is temperature on the
absolute (Kelvin) scale.
For a substance dissolved in a liquid (i.e. contaminants in the
soil moisture or leachate), fugacity is related to concentration
through the Henry's Law constant, H, and Z is equal to 1/H.
For substances adsorbed onto solids (i.e. contaminants adsorbed on
the soil particles), the fugacity is related to the sorption
partition coefficient, Kd, and the concentration of the substance in
the water. Kd has been shown to be dependent on the fraction of
organic matter in the soil, f^, and the organic carbon-water
partition coefficient, K^. Thus, Z is equal to f^ K^ D/H, where D
is the bulk density of "the soil.
The mass of a substance in a compartment is related to
concentration
M » C V
and therefore for each substance in each phase:
M = f Z V
For a cubic meter of bulk soil, the mass fraction of a substance
may be expressed as follows:
Ma = V/RT
Mt [T] for air; (2)
-------
Mt [T] for water; and (3)
[T] for soil particles; (4)
where T = vyRT + vyH + (Vg f^ K^ D)/H
Va, Vw, and Vs are the volumes of air, water, and soil,
respectively, and M8, MM, Ms, and Mt are the masses of air, water,
soil, and total mass, respectively. Note that in the above
equations, f has been cancelled out of the right side because it is
identical in every phase or compartment.
Each contaminant is distributed among the three phases according to
the partitioning ratios dictated by the Z value for each phase and
compound. That is, each compound exists partially adsorbed onto
the solid soil particles, partially as a vapor in the pores, and
partially dissolved in the pore moisture. The expressions above
allow one to calculate the mass fraction of a contaminant in each
of the three compartments in the soil system. In order to solve
equations (2), (3), and (4), it is necessary to select values for
Va, Vw, and Vs, expressed as fractions of a cubic meter. EPA
determined that realistic values are 0.2, 0.1, and 0.7,
respectively. The value for D, the soil bulk density, was based on
actual measurements of soil sampled beneath the lagoon. The bulk
density used in the model is 127 lb/ft3 (approximately 2.0 gm/cm3 =
2000 kg/m3) . The value for f^. was chosen to be 0.001 (0.1%), which
is considered to be reasonable for the types of soils encountered
and is also the lowest value for which the relationship between Kd
and K^ is generally preserved.
The mass fraction of a contaminant in each phase or compartment
(e.g. vinyl chloride vapor in the air-filled soil pores) may be
converted to total mass or concentration of contaminant in each
compartment in a cubic meter of soil if the total mass of the
contaminant in the bulk soil is known. For example, the mass
fractions for vinyl chloride, for the volume fractions given above,
have been calculated to be:
Ma = 0.981
Mw = 0.017
Mt
Mj = 0.002
«t
-------
(Note that these values indicate that over 98% of the vinyl
chloride in the bulk soil will partition into the air in the pore
spaces.) If the total concentration of vinyl chloride in the bulk
soil is 40 ppb, and if the bulk density of the soil is 2000 kg/m5,
the total mass of vinyl chloride in one cubic meter of the bulk
soil (Mt) is 8.0 x 10"5 kg. Of this total mass, 0.017 x 8.0 x 10"5
kg = 1.36 x 10"6 kg of the vinyl chloride is dissolved in the soil
moisture compartment. In one cubic meter of bulk soil, the volume
of moisture is 0.1 cubic meters or 100 liters of water. The mass
of water is 100 kg because the density of water is approximately 1
kg/liter. Therefore, the concentration of vinyl chloride in the
moisture or leachate is 1.36 x 10"6 kg/100 kg = 1.36 x 10'8 kg/kg or
13.6 ppb.
The second part of the mathematical model is a simple mixing
calculation. Leachate is assumed to be generated from the source
area at the same rate that rainfall percolates into the soil, and
this value is chosen to be 20 inches per year. This is
approximately half of the regional annual rainfall, and 50%
infiltration is a typical value. (The remainder of the
precipitation is evaporated, taken up by vegetation, or runs off.)
The amount of leachate generated per day (20 in./365 day) is
multiplied by the area of the source (i.e. the lagoon) to obtain
the daily volume of leachate that is generated from each source.
The leachate entering the water table is then diluted by ground
water entering the aquifer along the upgradient edge of the source
area. This aquifer recharge rate is calculated by the rate of
ground water flow beneath the site multiplied by the
cross-sectional area of underflow (i.e. the thickness of the
aquifer multiplied by the width of the site measured in the
direction perpendicular to the direction of ground water flow.) A
dilution factor, F, is then obtained:
F = aouifer recharge rate + leachate generation rate
leachate generation rate
The concentration of the contaminant in the ground water is
calculated by dividing the leachate concentration by F.
EPA applied this mathematical model to calculate what the bulk
concentration of the residual contamination of the soil could be
and still ensure that the concentration of the aquifer beneath the
site was below MCL. The approach used by EPA is the identical
calculation described above performed "in reverse". If the
concentration of a contaminant in the aquifer beneath the site is
the MCL value, the concentration of leachate entering the ground
water is obtained by multiplying MCL x F. This leachate
concentration can be used to calculate the corresponding
concentrations and masses in each of the other compartments, and
also in the bulk soil. The concentration of the contaminant in the
bulk soil, corresponding to the "drinkable diluted leachate", is
-------
5
the soil cleanup goal determined by EPA.
The attached memorandum dated August 7, 1989, documents the
assumptions made in the model and provides the computer
spreadsheets from the model.
References
Mackay, D., 1979. Finding fugacity feasible. Environmental Science
& Technology,
V.13 No. 10, pp. 1218-1223.
Mackay, D. and S. Paterson, 1981. Calculating fugacity.
Environmental
Science & Technology, v. 15, No. 9, pp. 1006-1014.
-------
UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
REGION I
J.F. KENNEDY BUILDING, BOSTON, MA 02203
MEMORANDUM
DATE: August 7, 1989
SUBJ: Proposed Plan - Modelling Assumptions
W. R. Grace Site - Acton, MA
FROM: Wayne M. Robinson.'-d-kvi.//'"'. ' * ^.
Remedial Project Manager
TO: W. R. Grace Site File
The attached information documents the assumptions used in the
model developed by COM, Inc. for establishing the Soil Cleanup
Goals as indicated in the August 1989 Proposed Plan.
Additionally, the attached information corrects some of the
technical information submitted to EPA by W. R. Grace and COM,
Inc. The calculations follow the same modeling methodology as in
the June 6, 1989 Addendum to the Phase IV Site Closure Plan,
which can be found in Attachment A, Soil Cleanup Values. The
following information is provided on the attachments to this
memo:
Page 1 through 2 provides the calculations for determining
the volume ratios used in the model. This information
include the bulk density of the soil, the volume of solids
in the soil, the volume of water in the soil, and the volume
of air in the soil.
Page 3 provides the calculations for the rate of recharge
through the waste area into the groundwater. Information
presented is for the Boiler Lagoon, Tank Car Area and the
Battery Separator Lagoons.
Page 4 calculates the groundwater flow ratio under the
lagoons. This factor is also called the dilution factor.
It is calculated for all waste areas.
Pages 5 through 7 are the spreadsheets from the model
calculations. They follow the same methodology as the June
6, 1989 Addendum.
-------
MODEL: WRG - RESIDUAL SOIL CLEAN-UP
Input Parameters
Bulk Density:
1982 GZA Report: Disposal Area Characterization
Bulk density of soils = 125 to 130 lb/ft3, say 127 lb/ft3
127 lb/ft3 = 2.04 g/cm3 say 2.0 g/cm3
Volume Ratios;
Vs = volume of solids
Vw = volume of water
Va = volume of air
The groundvater flow calculations are based on a
porosity (n) = 30%.
if n = 0.3, then Vs must = 0.70
then calculate V8 and Vw: Void ratio = "e"
First calculate dry density = spec, arav. mat. (G) * unit wt
1 + e of wat.
e = n = 0.3 = .38
1-n 0.7
dry density = 2.65 * 62.4 lb/ft3 = 119.8 say 120 lb/ft3
1 + .38
In 1 ft3 of material: bulk density - dry density = weight
of water
127 Ib - 120 Ib = 7 Ib. of water
There is 7 Ibs. of water in 1 ft3 of soil
-------
If there is 7 Ibs of water in 1 ft3 then the volume of water
is:
unit wt. of water =62.4 lb/ft3, if have 7 lb/ft3
volume of water = 7 lb/62.4 lb/ft3 =0.11 ft3
say: volume of water = 0.10 or 10%
if Vg = 0.7 and Vy = 0.1 then V. = 0.2
Input to model: Vs=0.7, VM=0.1, V8=0.2 fol = 0.001
(given by COM)
-------
RECHARGE THROUGH OTHER WASTE AREAS
Boiler Lagoon
20,000 ft2 * 20 in * i ft * 1 vr = 91 ft3/day
yr 12 in 365 days
Tank Car Area
29,000 ft2 * 20 in * l ft * l vr = 132 ft?/day
yr 12 in 365 days
Estimate of 29,000 ft2 based on 8/7/89 conversation with
Charlie Jutras, CDM
Battery Separator Lagoons
It is reasonable to assume the 3 Battery Separator Lagoon as
one lagoon with a total area equal to the sum of 3.
(discussed with Jutras 8/7/89)
78,450 ft2 * 20 in * 1 ft * 1 vr = 359 ft3/day
yr 12 in 365 days
-------
GROUNDWATER FLOW RATIO CALCULATION
The June 6, 1989 Addendum:
The average groundwater flow under each site was erroneously
calculated for the Secondary Lagoon and Slowdown Pit. The
correct values are:
Secondary Lagoon = 5346 ft3/clay
Slowdown Pit = 105.3 ft3/day
also note: The 8/4/89 facsimile transmitted from C.
Jutras to Wayne Robinson had errors which
have been corrected on the attached copy.
Groundwater ratio = flow under the waste area + recharge
recharge
Primary Lagoon = 252 + 109 =3.3
109
Secondary Lagoon = 5346 + 456 =12.7
456
Emergency Lagoon = 63 + 109 =1.6
109
Slowdown Pit » 105.3 + 55 =2.9
55
Battery Sep. Lagoons = 713 + 359 =3.0
359
Boiler Lagoon = 203 + 91 =3.2
91
Tank Car Area = 303 + 132 =3.3
132
-------
3PHEPA.WM
Va
0.2
Tot Ma
8.324315
Tot Mw
VDC
VC
EB
B
Tot Ms
VDC
VC
EB
^
Vw
0. 1
Vw
0. 1
0.1
0.1
0.1
vs
0.7
0.7
0.7
0.7
Vs
G.-
Henry' s
0.154
0.695
0.00644
0.00543
Foe
0.001
0.001
0.001
0.001
density
2
T Vw
0'.649350
0.143884
15.52795
18.41620
KOC
65
8.2
680
65
FOC
0.001
Cs
2
2
2
2
I
• -4
Tot Ma
8.324315
Tot Mw Tot Ms
0.649350 0.590909
Cs
2
2
2
2
M
H
0.154
0.695
0.00644
0.00543
Fractions
Fa
T Ms
0.590909
0.016517
147.6260
16.75874
Fw
Fs
9.564575 0.870327 0.067891 0.061781
Tot M
VDC
VC 8.324315 0.143864 0.016517 6.484718 0.981095 0.016958 0.001946
EB 6.324315 15.52795 147.8260 171.6783 0.048487 0.090447 0.861064
B 6.324315 18.41620 16.75874 43.49926 0.191366 0.423366 0.385265
fcven 1 cu. m of soil and the assumed volume ratios
bulk
mass kg
2000
kg or 1
of water
100
oercent oercent water dry soil
water water mass kg mass kg
EY VOL BY WT
0.1 0.05 100 - 1900
VDC
VC
EB
B
for MCL
ug/1
7
2
700
5
mass of
contam
water ug
700
200
70000
500
mass of
contam
soil ug
637
23
666400
455
mass of
contam
air ug
6974
11571
37526
226
mass of
contam
total ug
10311
11794
773926
1181
cone.
CLEAN UP
5.2
5.9
387.0
0.6
-I
v--
-------
LAGjC'N
./fcarv_EvEi.S~{esc}3DnEPA.wk 1
/f car.ASSUME~ {esc} Spneca.wk 1
Vol Air
0.2
Vol water
0.1
/F£~R/FR{ESC}TABLE.WK1~
PRIMARY
VDC
VC
EB .
E
ti'.s Z-
SECOND.
VDC •
VC
EB
E
EMERG
VDC
VC
EB
E
BDP
VDC
VC
EB
B
DILUTION
FACTOR
3.3
3. 3
3.3
3.3
3 3
12.7
12.7
12.7
12.7
'2. '
1.6
1 .6
1 . t
1.6
C
2.9
2.9
2.9
2.9
ALT L
LEACHATE
5.2
5.9
387.0
0.6
3*.f
5.2
5.9
337.0
0.6
i*>
5.2
5.9
357.0
o.e
38.1
5.2
5.9
387.0
0.6
vol
Soil
0.7
SOIL
CLEANUP
17.0
19.5
1277.0
1.9
65.5
74.9
4914.4
7.5
6.2
9.4
619. 1
0.9
15
17
1122
1
,0
,1
.2
,7
p.p
ALT L
ALT S
ALT A
Blk Den
2
ALT S
Org Carb
0.001
1/2. (
-------
LAGCON
{esc}3pnErA.
/FS~R/FR{ESC)
BOILER
vDC
VC
EB
B
BAT SEP
VDC
VC
EB
B
tr- -L
TANK CAR
VDC
V \»
£5
B
"- i 2-
vol Air
0.2
TABLE. WK1~
DILUTION
FACTOR
3.2
3.2
3. 2
3.2
3
3
3
3
i
3. 3
3 . 3
3 . 3
3 . 3
-> ^
Vol water
0. 1
ALT L
LEACHATE
5.2
5.9
337.0
0.6
. 5.2
5.9
367 . 0
. 0.6
2g. -
5 . 2
5.9
oo7 . 0
• • ' 0.6
'IB 7
Vol Soil
0.7
SOIL
CLEANUP
16.5
16.9
1236.3
1.9.
15.5
17.7
1160.9
1.6
lit,, I
17.0
19.5
1277.0
1.9
ALT L
ALT S
AtT A
Blk Den
2
ALT S
Org Carb
0.001
-------
CDM
CAMP DRESSER & McKEE INC.
TO:
FACSMU TRANSMISSION
OFFICE:
JOB CHARGE: 7 9g ' 7/"$5 GROUP KUW3ER: /
FAX OPERATOR:
OF PAGE5 INCL. COVER
COI5.1NTS:
. J->
-------
CM8C
-------
*
. i.'
-------
APPENDIX B - RESPONSIVENESS SUMMARY
-------
FINAL RESPONSIVENESS SUMMARY
W.R. GRACE SUPERFUND SITE
ACTON, MASSACHUSETTS
SEPTEMBER 1989
U.S. ENVIRONMENTAL PROTECTION AGENCY
REGION I
-------
W.R. GRACE SUPERFUND SITE
RESPONSIVENESS SUMMARY
TABLE OP CONTENTS
PREFACE,
I. OVERVIEW OF REMEDIAL ALTERNATIVES, INCLUDING
THE PREFERRED ALTERNATIVE 3
Exhibit 1 - Site Features Map
II. BACKGROUND ON COMMUNITY INVOLVEMENT AND CONCERNS 5
III. SUMMARY OF COMMENTS RECEIVED DURING THE PUBLIC
COMMENT PERIOD AND EPA RESPONSES 8
A. Comments Regarding the Preferred Alternative
1. Excavation and Stabilization
2. Industrial Landfill and Capping
3. The Aquifer Restoration System (ARS)
4. Suggested Alternatives
5. Miscellaneous
B. Comments Regarding Contamination at the Site
1. Ground and Surface Water Contamination
2. Soil Contamination and Sludges
3. Miscellaneous
C. Comments Regarding Bioremediation
D. Comments Regarding Public Involvement
E. General Comments
IV. REMAINING CONCERNS 42
ATTACHMENT A - COMMUNITY RELATIONS ACTIVITIES CONDUCTED AT
THE W.R. GRACE SUPERFUND SITE
ATTACHMENT B - TRANSCRIPT OF THE SEPTEMBER 12, 1989 INFORMAL
PUBLIC HEARING
-------
Preface
The U.S. Environmental Protection Agency (EPA) held a 30-day
public comment period from August 15, 1989 to September 15, 1989
to provide an opportunity for interested parties to comment on
the Phase IV Closure Plan (Phase IV Report) and the August 1989
Proposed Plan prepared for the W.R. Grace Superfund site (W.R.
Grace site) in Acton, Massachusetts.
The Phase IV Closure Plan Report, prepared for the Site by
the W.R. Grace Company with the oversight of EPA and the
Massachusetts Department of Environmental Protection (DEP),
examines and evaluates various options, called remedial
alternatives, for addressing specific sources of contamination at
the W.R. Grace site. EPA identified its preferred alternative
for the cleanup of the Site in the Proposed Plan issued on August
10, 1989, before the start of the public comment period.
The purpose of this Responsiveness Summary is to summarize
comments raised during the public comment period regarding the
Phase IV Report, the Proposed Plan, and EPA's preferred
alternative, and provide EPA responses. Citizen involvement and
interest at the W.R. Grace site is high. There is an active
citizens' group, Acton Citizens for Environmental Safety (ACES),
which continues to monitor activities at the Site. The town of
Acton has also been very involved as a participant in technical
discussions and review of technical documents that have been
prepared for the Site. At present, residents and local officials
are primarily concerned with ensuring that EPA selects an
effective and permanent cleanup remedy for the Site; establishing
a short- and long-term monitoring program at the Site; and the
possible effects that Site contamination could have on public
health.
EPA has given careful consideration to all of these
questions and comments before signing the Record of Decision
selecting the final remedy to address sources of contamination at
the W.R. Grace site.
This Responsiveness Summary is divided into the following
sections:
I. Overview of Remedial Alternatives. Including the Preferred
Alternative - This section briefly outlines the remedial
alternatives evaluated in the Phase IV Report and the
Proposed Plan, including EPA's preferred alternative.
II. Background on Community Involvement and Concerns - This
section provides a brief history of community interest and
concerns regarding the W.R. Grace site.
III. Summary of Comments Received Durinq the Public Comment
-------
Period and EPA Responses - This section summarizes and
provides EPA responses to the oral and written comments
received from the public during the comment period.
IV. Remaining Concerns - This section describes issues that may
continue to be of concern to the community during the design
and implementation of EPA's selected remedy for the W.R.
Grace site. EPA will address these concerns during the
Remedial Design and Remedial Action (RD/RA) phase of the
cleanup process.
In addition, two attachments are included in this
Responsiveness Summary. Attachment A provides a list of the
community relations activities that EPA has conducted to date at
the W.R. Grace site. Attachment B contains a copy of the
transcript from the informal public hearing held on September 12,
1989.
-------
I. OVERVIEW OF REMEDIAL ALTERNATIVES, INCLUDING
THE PREFERRED ALTERNATIVE
On August 10 1989, EPA released a proposed Plan for the
Site, identifying a preferred alternative for addressing source
areas of Site contamination. For a detailed description of the
preferred alternative, and other remedial alternatives evaluated,
refer to the August Proposed Plan document and the Phase IV
Closure Plan. An outline of the major components of the
preferred alternative, and a list of the other remedial
alternatives evaluated for the Site in the Phase IV report, are
provided below.
Components of the Preferred Alternative upon which public
comment was taken include:
1. Excavation and transportation off-site for incineration
of highly contaminated material from the Slowdown Pit
(see Exhibit 1);
2. Excavation and stabilization of the remaining contents
of the Blowdown Pit, as well as the contaminated
sludges and soils of the Primary Lagoon, Secondary
Lagoon, North Lagoon, and Emergency Lagoon;
3. Excavation of contaminated soils from the Battery
Separator Lagoons, Boiler Lagoon, and Tank Car area;
4. Placing both the stabilized and the non-stabilized
materials excavated from the Site on the existing
Industrial Landfill, and covering these materials with
an impermeable cap;
5. Closure of the Chip Pile Area;
6. Establishing Soil Cleanup Goals for all waste disposal
areas;
7. Modifying the Aquifer Restoration System (ARS) to
address air stripper emissions controls; and
8. Establishing compliance monitoring at each disposal
area designed to monitor the effectiveness of the
proposed remedy.
The additional six cleanup remedies considered for the are:
o No-Action Alternative
3
-------
W.R. Grace Superfund Site Features Map
:Boiler Laaoon'
'Tank Car Ares
Eatery Sepa:a:o;
Area
Blowccv.-n Pit ;
Secondary
zmernencv Lasoon
industrial
Landfill i--
/ Sinking
Legend
Contaminated
Areas
Asssbet Wells
Approximate
Boundary of ARS
Railroad
-------
o Alternative 1: Capping in Place
o Alternative 2: Stabilization and Combined Closure on
the Landfill
o Alternative 3: Excavation and On-Site Encapsulation
o Alternative 4: Excavation and a) On-Site Incineration;
b) Off-Site Incineration
o Complete Incineration Alternative
-------
II. BACKGROUND ON COMMUNITY INVOLVEMENT AND CONCERNS
Interest from citizens local officials and the media has
been high since contamination of municipal wells in Acton was
first discovered in 1978, during Town review of W.R. Grace plans
for expansion of its battery separator plant. The discovery of
suspected carcinogenic agents in the water caused immediate
concern and alarm in residents and local officials. In response
to the findings, Acton closed the Acton Water Supply District's
Assabet Wells #1 and #2. The wells supplied approximately 40
percent of the Town's water supply and community interest in the
problem grew, even after well closure.
In December 1978, when the wells were closed, two community
meetings were held with state and local officials and W.R. Grace
Company representatives attending. These meetings were well
attended and those present expressed great concern about possible
health effects from past exposure to contaminants, and operations
at W.R. Grace.
By 1979, the Town had developed new drinking water wells to
replace the supply lost as a result of the Assabet well closures..
At that time, the Town and DEP began additional investigations of
waste disposal practices at the W.R. Grace site to.determine the
cause of water supply contamination and the potential
relationship between the Site activities and chemicals detected
in the water supply wells. During that time, a group of about a
dozen Acton residents formed a group called Acton Citizens for
Environmental Safety (ACES). Since 1979, ACES has gathered
information about problems at the W.R. Grace site, conducted
research on technical and legal issues, reported to the media,
testified at meetings and initiated the formation of a Health
Effects Subcommittee of the Acton Board of Health. ACES has
maintained regular communication with EPA and DEP, in addition to
the Massachusetts Attorney General's Office and other branches of
state government responsible for enforcing public safety and
public health laws. Before 1980, ACES threatened to file suit
against W.R. Grace Company in an effort to force the firm to
address waste discharge and air emissions problems at the Site.
On October 21, 1980, EPA and the W.R. Grace Company signed a
Consent Decree that set the terms under which W.R. Grace has
proceeded with Site investigations and other Site activities. As
work has proceeded at the Site the town of Acton has been
apprised of Site study activities conducted under the oversight
of EPA and DEP (formerly the Massachsuetts Department of
Environmental Quality Engineering).
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Since 1983, when the Site was added to the National
Priorities List, EPA has conducted activities to keep the
community and other interested parties apprised of Site
activities through informational public meetings, press releases,
and contact with interested community members and local
officials.
In August 1984, EPA and DEP held a public meeting to discuss
the Aquifer Restoration System proposed by W.R. Grace and plans
for future study of the Site. Also in 1984, EPA initiated weekly
technical meetings involving the participation of W.R. Grace,
EPA, DEP, consultants employed by the Town of Acton, and local
Acton officials. Based on public comment, EPA and DEP
recommendations, the W.R. Grace Company installed and activated
an Aquifer Restoration System (ARS) to begin the groundwater
cleanup process.
Between 1984 and 1988, community interests in the Site were
represented through Town of Acton participation in technical
discussions. The high level of ACES involvement lessened during
this period of Site study, however, citizens from Concord and
Acton have voiced concern about odors from the Aquifer
Restoration System since it went on line.
Upon completion of a Site investigation and evaluation of
alternatives to address the sources of Site contamination, EPA
and DEP released the results of the Site studies in the Draft
Phase IV Closure Plan prepared by W.R. Grace. Upon release of
the Draft Phase IV Closure Plan, the report was made available at
the Acton Public Library. In December 1988, EPA and DEP held a
public informational meeting in Acton at which W.R. Grace
representatives presented the Closure Plan. The meeting was well
attended by ACES members who have remained visible and active in
expressing their concerns about the Site since that time.
In May, 1989, as a result of petition from citizens to the
DEP asking for the Site to be designated as a Commonwealth of
Massachusetts Public Involvement Plan site, EPA and DEP met with
interested citizens to discuss community concerns, avenues
through which Site information would be supplied to the
community, and opportunities for public involvement in the
process for achieving a Record of Decision at the Site.
Following this meeting EPA and DEP maintained telephone contact
and written correspondence to apprise the citizen's group of
plans for public meetings and the projected schedule for public
comment opportunities. EPA is currently working with DEP on a
joint Community Relations Plan to establish mechanisms for public
involvement during the remedial design and remedial action phases
of Site activity. The plan will be presented to the community
for comment in autumn, 1989, prior to finalization.
In July of 1989 EPA made the Administrative Record available
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for public review at EPA's offices on 90 Canal Street in Boston,
and in Acton at the Acton Public Library. On August 9, 1989 EPA
published a public notice and brief analysis of the Proposed Plan
for source control at the Site in the Middlesex News. The public
notice also announced the availability of documents for review as
part of the Administrative Record, and provided information on
the dates for a public informational meeting, informal hearing
and comment period. This same information was released in a
press release to the media and to the approximately 500
interested and affected parties on the Site mailing list. To
facilitate public involvement further, the Proposed Plan for the
Site was also mailed directly to all those on the Site mailing
list.
In August 1989, ACES was awarded a Technical Assistance
Grant (TAG) from EPA, to provide funds for a technical consultant
to assist the group in its efforts to participate in review of
future Site activities.
On August 14, 1989 the Proposed Plan for addressing sources
of contamination and other new documents were made available for
public review as part of Administrative Record. Also on August
14, 1989, a public informational meeting was held in Acton and
attended by approximately 60 people, to review the Proposed Plan
and provide opportunity for public discussion.
From August 15, 1989 - September 15, 1989, the Agency held a
four-week public comment period to accept public comment on the
alternatives presented in the draft Phase IV Closure Plan, the
Closure Plan Addendum, Proposed Plan and on other documents that
are part of the Site Administrative Record. A set of Site
technical reports was also provided to ACES to enhance their
ability to review and comment.
On September 12, the Agency held an informal public hearing
attended by approximately 140 participants, including ACES
members, area residents, local officials, representatives of
environmental advocacy groups from Massachusetts and New
Hampshire (where W.R. Grace has another facility), and
representatives from W.R. Grace.
The comments received are summarized and responded to in the
following sections of this document.
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III. SUMMARY OP COMMENTS RECEIVED DURING THE PUBLIC
COMMENT PERIOD AND EPA RESPONSES
This Responsiveness Summary addresses the comments received
during the public comment period by EPA concerning the Phase IV
Closure Plan (Phase IV Report) and Proposed Plan for the W.R.
Grace site in Acton, Massachusetts. Eighteen sets of written
comments were received from a Town of Acton official, area
residents, Acton Citizens for Environmental Safety (ACES)
representatives, a Sierra Club representative, and the W.R. Grace
Company (WRG) during the public comment period (August 15 to
September 15, 1989).
Thirty-six oral comments were presented at the September 12,
1989 informal public hearing. Individuals commenting at the
hearing included a W.R. Grace Company representative, local
citizens, one representative of the Acton Board of Selectmen,
several representatives of ACES, one Sierra Club representative,
several citizen and environmental advocacy group representatives,
and a few individuals from New Hampshire active in community
activities involving the W.R. Grace Company Nashua RCRA facility.
A copy of the Informal Public Hearing transcript is included as
ATTACHMENT B.
Public comments, both oral and written, along with EPA
responses, are summarized and organized into the following
categories:
A. Comments Regarding the Preferred Alternative
1. Excavation and Stabilization
2. Industrial Landfill and Capping
3. The Aquifer Restoration System (ARS)
4. Miscellaneous
B. Comments Regarding Contamination at the Site
1. Ground and Surface Water Contamination
2. Soil Contamination and Sludges
3. Miscellaneous
C. Comments Regarding Bioremediation;
D. Comments Regarding Public Involvement; and
E. General Comments.
Certain responses refer to actions taken or approvals issued
by Government Parties (GPs) under the Consent Decree. GPs
include both DEP and EPA, rather than EPA alone.
A. comments Regarding the Preferred Alternative
1. Excavation and Stabilization
Comment: One resident asked for clarification on whether
EPA's proposed cleanup plans will completely remediate
contamination at the Site.
EPA's Response:
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The ROD indicates that the remediation of the W.R. Grace
site will be achieved in three Operable Units (OUs) or three
distinct steps: the first step is the control of sources of
contaminants that are releasing contaminants to the
environment by addressing the source areas on-site, the
second step is to ensure the achievement of Soil Cleanup
Goals in the source areas at the Site, and the third step '..s
evaluation of groundwater contamination on- and off-site and
determination of the need for more remediation than is
currently provided by the on-site aquifer restoration
system. The ROD addresses Operable Unit One, control of
sources of contaminants. The plan does not describe in
detail steps two and three because the GPs intend to address
these issues subsequent to the source control remedies
presented this ROD. Operable Units Two and Three will be
subject to full community relations activities when the GPs
develop proposed plans, in a process identical to that used
on this ROD.
Comment; One citizen remarked that all pits and lagoons at
the Site should be degassed before any other action is
taken.
EPA's Response;
The transfer of volatile organic contaminants to the
atmosphere is a concern of the GPs; the actual details of
the excavation technique to be used at the Site will be
determined during design. However, the GPs have stressed on
numerous occasions to WRG the requirement to minimize
releases of contaminants from source materials to any
environmental media. The ROD focuses on this important
issue requiring that all excavation activities will be
performed using best engineering practices to minimize
release of compounds to the ambient air or underlying soils.
Comment: An ACES representative remarked that they had been
given no analytic data to help them to understand if the VFL
process will actually stabilize the waste sludge and
contaminated soils.
EPA's Response;
VFL treatability data is included in the Administrative
Record and can be found in Appendix E VFL Pilot Program of
the Phase IV Report. The Administrative Record is a source
of extensive additional data and information on the Site
available at the Acton Public Library and EPA.
ffaiimianfc' Two ACES representatives stated that the only
pozzolonic VFL prototype they are aware of at the W.R. Grace
site exploded and failed, and requested more information on
the explosion. One of the representatives stated that the
VFL process is uncertain, unproven and difficult to use,
that she has seen VFL pozzolonic material crumble easily,
and asked for information regarding where the process has
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worked for 50 years. .
EPA's Response:
The GPs are not aware of explosion hazards from the VFL
process; the one incident that was of concern to the GPs was
the addition of pozzolonic materials to sludges at a rate
which caused the heat released from the exothermic reaction
to boil water off the mixture. The rate of addition of
material during the VFL process will be done in a controlled
manner to control the amount of heat released to levels that
would not elevate the mixture temperature significantly so
this situation will not occur.
gQtnm«»Ttfc; An ACES representative referred EPA to EPA
research that indicates that organics can leach through the
VFL material.
EPA's Response; The VFL pilot test and leaching studies
indicated that the solidified material can be made to leach
ethylbenzene at low levels under laboratory conditions.
However, the GPs believe that containing the solidified
materials beneath the impermeable cap will further minimize
the potential for leaching. In addition, the selected
remedy provides for groundwater monitoring at the landfill
to detect any leachate. Furthermore, the remedy provides
for the Industrial Landfill Groundwater Recovery System,
which would collect and treat any leachate that is released
from the landfill.
comment; one citizen asked why only two feet of underlying
soil will be excavated from the Primary, Secondary and
Emergency lagoons.
EPA's Response:
The selection of two feet of soil beneath the lagoons was
based on the analytical data that indicated the majority of
contaminants are largely concentrated in the sludges and
approximately the top foot of soil. Excavation of the top
two feet of soil below all the sludges will remove the
majority of contamination. The data are not complete enough
to determine if excavation of two feet of soil will achieve
the Soil Cleanup Goals. Post excavation analysis will be
conducted following excavation. Additional investigations
will be required for soils below 2 feet if the Soil Cleanup
Goals are not met, as described in the ROD.
romment• one citizen asked why EPA plans to excavate the
Battery Separator, Boiler and Tank Car areas to a depth of
five feet, rather than to the bottom of these areas plus an
additional five feet.
EPA's Response:
The Battery Separator lagoons, the Boiler lagoon, and the
Tank Car area have no discernable waste layers; therefore,
excavation did not include reference to the bottom of the
waste material.
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lent: Several commenters expressed concern that the
material dug out of the lagoons will leave holes and emit
gases and asked if EPA will survey the materials left
behind, with a preference for multi-level soil sampling from
the bottom of the lagoon excavation to the water table and
what activities would be involved in such surveys. They
indicated that an analysis of each excavated Site should
begin immediately upon its excavation.
EPA's Response:
The ROD indicates that post excavation sampling and analysis
program will be conducted within 30 days of excavation. The
survey will include extensive and comprehensive horizontal
and vertical soil sampling and analysis to determine if Soil
Cleanup Goals have been attained. The post excavation
sampling work plan will be required and approved by the GPs
prior to the commencement of excavation of the lagoons.
goniTn«»Tifci one citizen requested that EPA require WRG to
provide an explanation of the effects of the freeze-thaw
cycle on solidified sludge.
EPA's Response:
The selected remedy has intentionally been designed to have
at least four feet of fill material placed over the
solidified waste to protect the stabilized mass from
stresses associated with freeze-thaw cycles.
Comment: One Town of Acton representative stated that
Goldberg, Zoino Associates (GZA), the Town of Acton's
technical consultant, recommends that consideration be given
to solidifying more of the contaminated soils and sediments
from waste areas on-site, rather than simply placing them
beneath the cap as additional fill.
EPA's Response:
The GPs do not believe the excavated material from the Other
Waste Areas require solidification. However, should the
analytical results show that a portion of excavated
materials is contaminated at unexpected levels that indicate
the unstabilized materials may present implementation
problems or impact the effectiveness or protectiveness of
the landfill remedy, then those materials would be
stabilized prior to placement on the landfill or would be
disposed off-site.
fjettnTnftTifci one resident asked what procedures would be used
to measure Volatile Organic Constituents (VOC) levels during
excavation and what would happen if previous estimates of 20
cubic yards to be excavated were 10 times too low. This
resident also asked if this highly contaminated material
will be excavated from the Slowdown Pit before or after the
less contaminated material around it, and if it would be
removed from the Site.
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EPA's Response:
The remedy specifies that the wastes in the Slowdown Pit
containing greater than 100 ppm of VDC will be excavated and
shipped to an off-site hazardous waste incinerator for
treatment. The volume of soils to be shipped off-site will-
be based on the volume of soils with concentrations of VDC
greater than 100 ppm. If the volume is found to be so great
that off-site disposal is not feasible, EPA would amend the
ROD to reconsider this approach.
gQHiment; one resident asked how long it takes for VFL
stabilized contaminants to decompose, and asked if the
contaminants decompose gradually or precipitously after an
indefinite period of time.
EPA's Response:
The first issue raised has not been resolved, since the VFL
technology has not been in use for an infinite period of
time. Studies performed under contract to WRG have looked
at performance times of less than a year. However, the GPs
expect that the lifetime of the material will be extended by
the protection of the cap design.
Comment; An ACES representative asked why concrete
containerization could not be used for immobilization of
wastes.
EPA's Response;
The concept of creating a storage structure that would
eliminate contaminant exposure pathways has been considered
in Section 5.2.2, although concrete specifically has not
been considered. However, a single barrier constructed of
concrete would be limited in effectiveness largely due to
its susceptibility to cracking with time. The EPA guidance
for final cover design suggests the use of a design similar
to that proposed for the landfill.
2. Industrial Landfill and Capping
r>mnm*-n+• There were numerous comments about the integrity;
service life; construction of; and monitoring of the
Industrial Landfill Cap. Many of these comments referred to
cap rupture and leaking cap membranes caused by differential
settlement of the Landfill. There were also many
suggestions and recommendations for dealing with cap
replacement and monitoring.
EPA's Response; Much of the existing information on the
integrity of synthetic liner materials has been established
by agencies such as the Bureau of Reclamation and the
Nuclear Regulatory Commission, who use synthetic materials
to contain liquid impoundments such as salt-brine ponds.
These agencies report good results with 30 mil PVC liners
with up to 30 years of service. The permeability of
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synthetic liners is approximately 10 cm/sec, whereas clay
barriers exhibit permeability in the 10 to 10 "7 cm/sec
ranges. Therefore, it is safe to say that synthetic
materials are quite impermeable. Manufacturers, in general,
warrantee synthetic materials (HDPE 40 mils in thickness)
for 20 years for chemical breakdown and ultra violet ray
resistance.
Since the installation of the high density polyethylene
(HDPE) material at the Grace facility is as a cap rather
than a liner, it will not be subject to the extreme
hydraulic heads that an impoundment liner would be subject
to. With proper design and careful installation, it is not
unreasonable to predict that the cap will provide an
effective impermeable barrier for at least 30 years.
EPA will use the technical resource document "Covers for
Uncontrolled Hazardous Waste Sites" (EPA/540/2-85/002) and
"Final Covers on Hazardous Waste Landfills and Surface
Impoundments" (EPA/530-SW-89-047) to judge the design of the
Industrial Landfill cover system. Although we may not
require that the final cover be designed in strict
conformance with the guidance, we will require that any
alternative cover system be designed to be at least.as
effective as the guidance cover system. Key to this design
will be the following: top slopes which after settling and
subsidence are between 3 and 5 percent; a surface drainage
system capable of conducting run-off across the cap with no
retention or ponding; a middle drainage layer designed to
prevent clogging, overlain with a graded granular or
synthetic fabric filter that allows discharge to flow freely
and prevents liquid from backing up on the synthetic
material cap; a detailed installation quality assurance
program for placement and installation of the synthetic cap;
a compacted soil layer overlying the solidified wastes and
contaminated soils that will provide a firm foundation for
the synthetic cap, as well as protecting the cap from direct
contact with the solidified wastes and soils; and a detailed
quality assurance program for placement of the solidified
waste and soils on the existing landfill.
Settlement within the existing industrial waste landfill is
expected to occur over the fill as the surcharge from the
solidified waste material is applied. However, to minimize
cover system damage from settlement and subsidence, EPA will
require that the final cover be designed and constructed to
allow for the total estimated settlement.
In making the estimate for settlement of the landfill, the
following will be considered:
consolidation of all waste layers in the existing
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landfill
consolidation of soils and foundation materials
underlying the landfill
• „ release of perched and pore water from the landfill as
the surcharge is applied.
consolidation of the solidified waste and contaminated
soils after placement on the landfill; and
• consolidation of all final cover components.
Finally, EPA will require a written construction quality
assurance program for inspecting the quality of construction
materials and the construction practices employed in their
placement. The quality assurance plan will address
activities such as inspecting, monitoring, and sampling of
the individual components of the cover system.
mmma-n+i An ACES representative questioned the long term
effectiveness, impermeability, and durability of the 60-mil
HOPE membrane.
EPA's Response; The GPs believe the 60-mil H.DPE material
incorporated in a properly designed and maintained cap
system is protective. The selection of HOPE and the
evaluation of other cover designs is included in the Phase
IV Report as part of the Administrative Record for this
Site, which is available for public review.
Comment; One commenter asked about the occurrence of "hot
spots" and the potential for chemical reactions to occur
when chemicals from the on-site lagoons are added to the
Industrial Landfill.
EPA's Response; The VFL solidification will reduce the
mobility of the contaminants moved to the landfill from the
lagoons. Since the surface materials on the existing
Industrial Landfill are similar in chemical composition to
those in the on-site lagoons the potential for chemical
reactions that would cause problems is very slight. The cap
design will effectively eliminate transport of contaminants
from the solidified material and other wastes down through
the landfill wastes.
A representative of the New England Chapter of the
Sierra Club and another citizen urged EPA to reconsider its
Preferred Alternative and to choose a remediation plan that
not only involves excavation of wastes, but also renders
them non-toxic. The Sierra Club representative stated that,
because EPA has said that a cap is not necessarily a
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permanent solution and its effectiveness cannot be
guaranteed, EPA's proposed plan appears to follow a short-
term, cost-benefit approach to decision making. He also
stated that if the costs of monitoring and maintaining the
cap were .factored in, the proposed plan may not be the
lowest cost choice.
EPA's Response;
The EPA followed a procedure for remedy selection described
in the Proposed Plan that is consistent with 40 CFR 300 the
National Contingency Plan, CERCLA, and SARA. The
alternatives retained for evaluation were evaluated using
the nine generated from statutory requirements, the National
Contingency Plan (NCP) and EPA policy. Costs were one of
nine criteria presented on pages 10 and 11 of the Proposed
Plan that EPA used to assess alternatives. The costs
analyses presented in the proposed plan include monitoring
and maintenance, and are present worth costs.
Comment; One citizen remarked that the enormous weight of
the VFL-treated waste and the weight of the cap may cause
materials to shift in the Industrial Landfill, causing the
cap to rupture. The citizen asked how EPA plans to monitor
the Industrial Landfill and asked whether EPA would take
precautions to prevent a rupture from occurring.
EPA's Response;
The barrier layer actually resides above the solidified
sludge and the bulk of the landfill cap materials. The
vegetative layers, filter layer, and sand that lie above the
barrier layer will not exert loads in excess of the barrier
layer strength, and function to protect the barrier layer
from disturbances from above. The GPs are confident that
the cap will not fail solely due to the design of the cap.
However, the remedy requires proper operation and
maintenance meeting state ARARs that will ensure the long
term integrity of the cap or identify needed repairs. In
addition, the groundwater monitoring and subsidence
monitoring programs will ensure that the cover system
remains effective over time. If the monitoring data
indicate a potential release of pore water from the
landfill, the GPs will initiate an investigation and
resolution of the cause of the failure.
ratnnienti one Town of Acton representative expressed concern
about the integrity of the proposed Industrial Landfill cap
in light of potential differential landfill settlement under
the cap. He recommended using one, or a combination of, the
following measures to address cap integrity;
1) deep dynamic densification of the landfill prior to
sludge/cap placement to remove the non-consolidated
mediated settlement;
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2) use of a very heavy grade woven geotextile between
the soil fill layer and the sand bedding layer
immediately below the synthetic membrane; and
3) use of a synthetic membrane on top of a 2-foot clay
layer.
He also asked EPA to require the placement of a geotextile
material of sufficient thickness between the drainage layer
and the subsoil layer such that it can be identified with
the soil gas probes. He requested the implementation of a
monitoring program for the cap shortly after its
construction to identify breaches in the liner, and
suggested that monitoring include the use of a closely
spaced soil gas sampling grid after infusion of a tracer gas
into the gas collection system, or the placement of 30-foot
wide linear strips of geosynthetic net under the synthetic
membrane that would each start at the apex of the landfill,
run parallel to the slope, and terminate at the slotted
collection pipe. He explained that this monitoring option
would detect and identify the location of non-settlement
induced cap failures and would provide redundancy for the
cap itself.
EPA's Response;
EPA agrees that in dealing with large areas such as the
Industrial Landfill, engineering analyses (i.e., one-
dimensional consolidation etc.) would prove valuable in
determining the potential for differential settlement of the
cap. Consideration will be given to obtaining data of this
type during the remedy design phase to support the final cap
design.
Bullet 1; The ROD indicates that during the design of the
landfill closure, an engineering analyses will be conducted
to determine the potential for differential settlement of
the landfill. If the results of the engineering analyses
indicate the likelihood of differential settlement that may
affect the long term integrity of the cap, deep dynamic
densification or consolidation of the landfill will be
evaluated as a pre-construction activity to mitigate the
adverse impacts of unpredictable settlement on the integrity
of the cap.
Bullet 2; As illustrated in Exhibit 4 of the Proposed
Remedy, EPA intends to utilize a woven textile between the
soil fill and the sand bedding layer beneath the synthetic
membrane. The select grade for the geotextile will be based
on load-bearing requirements determined during the remedy
design.
Bullet 3; EPA will use the Technical Guidance Document:
Final Covers on Hazardous Waste Landfills and Surface
Impoundments, July 1989, to evaluate the design of the
Industrial Landfill cover system. A key component of the
design will be a compacted soil layer overlying the
solidified waste that will provide a firm foundation for t'r.c-
synthetic cap.
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one resident stated that EPA should require
complete replacement of the cap after every three or four
repairs.
EPA's Response:
Replacement of the entire five acre cap to address minor
repairs would be impracticable, since anticipated cap
problems would be localized. Since waste will be left in
place, EPA and MA DEP will be reviewing the effectiveness of
the cap on a periodic basis as required by CERCLA. If data
indicate the need for full cap replacement at any time
following remediation, the GPs will require such actions be
taken.
gftitmtonfci one Town of Acton representative requested
verification of the adequacy of the 6-inch thick drainage
layer proposed as part of the cap, and specifically asked
for information regarding the layer's capacity to transmit
peak cumulative flows, particularly at the bottom of slopes.
EPA's Response;
The adequacy of the 6" drainage layer will be verified
during the remedy design phase. The drainage layer of the
cap will be designed to transmit peak cumulative flows and
minimize any backup.of liquids above the synthetic layer.
eotnm«»nfci one citizen suggested EPA use the vent design
proposed by WRG instead of the design proposed by the EPA in
which internal vents from the landfill are not allowed to
vent below the cap.
EPA's Response:
The primary concern of the GPs with regard to the vent
design in the Phase IV Report is that uncontaminated soils
beneath the cap added to protect the barrier layer above
will be contaminated from below if waste vents are offset
from surface vents as in the Phase IV Report.
Comment; One resident asked how much differential
settlement is allowable before visual inspection of the cap
is initiated.
EPA's Response:
It is anticipated that visual inspection of the cap will be
triggered by several indicators; for example, actual field
measurements indicating subsidence will be compared to an
allowable settlement tolerance based on an estimated
subsidence of the fill and cover system and the liner's
engineering characteristics. The tolerances will be
established during the design phase of the response action
and will support an action value that will trigger liner
inspection.
Comment; A representative of the New England chapter of the
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Sierra Club requested that EPA investigate reports that
acidic soil from another of W.R. Grace Company's facilities
in Cambridge, Massachusetts was dumped at the Acton site.
He pointed out that if acidic soils are present it is
possible that metals are also leaching from the Site because
metals are more susceptible to ac'ids than are VOCs.
EPA's Response :
EPA plans to sample and analyze for metal and soil acidity
during the excavation of the waste lagoons. Data generated
from past sampling in the Phase III report (see indicator
chemicals page 14 of the ROD) indicate that metals do not
pose a significant risk at the Site.
f»ftmm«»nfc» One citizen asked for the elevation and dimensions
of the capped area, and asked if this area would be an
eyesore for abutting residences.
EPA ' s Response ;
The final design elevations for the landfill cap have not
yet been established, and will be established during the
design phase of the response action. The preliminary design
work has suggested an elevation apex of 208 ft. +MSL,
approximately 10-15 feet above existing surrounding grades.
Based on the surrounding mature vegetation, it is unlikely
the cap will be visible from off -site.
3. The Aquifer Restoration System (ARS)
Comment; There were numerous comments concerning the ARS and
the ARS computer model developed by Camp Dresser & McKee,
Inc. for W.R. Grace. The commenters were concerned with the
models validity in predicting contaminant transport
conditions in the northeast sector of the Site in the
general direction of Lawsbrook Road and the effectiveness of
the ARS in capturing contaminants before they leave the
EPA's Response: The remedy under consideration will
effectively remove contaminant sources from contributing
further contamination to the groundwater under the Site.
The approach described in the ROD acknowledges the need for
further investigation of the migration of contaminants in
groundwater (OU Three) and the placement of the proposed
Industrial Landfill groundwater recovery system and assure
collection of any contamination migrating from the Landfill
in the northeasterly and easterly direction. The ARS
computer model was developed by CDM for WRG to simulate the
direction and flows of groundwater passing through the Site
and also to predict the physical behavior of the
contaminants that are released from the waste areas to the
groundwater under the Site. Review of the quarterly
monitoring data from the ARS by EPA and the MA DEP since its
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commencement of operations in March 1985 indicate that it is
effective in capturing the majority of contaminants and
removing the VOCs from the contaminated groundwater plume.
However there is uncertainty with respect; to the actual area
of-containment and this will be investigated during OU
Three. The Consent Decree stipulates the continued
operation of the ARS until the aquifer is restored to a
fully useable condition.
Comment; The W.R. Grace Company stated that it beliaves
that the ARS will achieve the cleanup standard of restoring
the aquifer to "a fully usable condition." It also stated
that the Proposed Plan for cleanup of specific source areas
of contamination will ensure compliance with the Consent
Decree.
EPA's Response;
The remediation of groundwater is enhanced by the actions in
the selected remedy; however, WRG is responsible for
compliance with the Consent Decree, and the EPA intends to
focus on existing uncertainties in the performance of the
ARS in evaluations conducted under OU Three.
The selected remedy is a source control remedy. The
operable unit approach described in the ROD identifies the
need for additional steps to fully remediate the WRG site.
Therefore, the selected remedy is a partial remedy to the
WRG site problems, and items raised in these comments will
be addressed in the ongoing evaluation of migrated
contaminants as discussed in the ROD for soil contamination
and for groundwater contamination management. Each
subsequent step will include opportunities for public
comment identical to those provided for with this ROD.
Comment: One resident referred to the ARS and the trap for
keeping the orange slime in a drainage ditch above the
Sinking Pond. He asked if the trap is operating, if it has
ever been cleaned, and if there is a schedule for periodic
cleaning. He cautioned that an inefficient or inoperable
trap would allow materials into the pond that would probably
never leave.
EPA's Response;
The orange slime referred to in the above comment is the
ferric hydroxide floe formed from the naturally occurring
iron in groundwater treated in the ARS. As ferrous iron is
exposed to oxygen, ferric iron is formed; ferric iron is
insoluble and forms the rusty colored deposits. Control of
these deposits is largely an aesthetic concern, and will
continue to be handled by the MA DEP enforcement of
provisions of the discharge permit issued to WRG for the
ARS.
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lent; One resident'asked what the plans are for
stabilizing the exposed shores of.Sinking Pond to prevent
erosion of sediment once the ARS system is shut off and the
Pond subsides.
EPA's Response;
The Consent Decree and Administrative Order prescribe a
phased program of groundwater remediation that led to the
design and implementation of the ARS. Concerns such as
those expressed in this comment will be addressed under the
continuing aquifer restoration and under OU Three.
Comment! Commenters requested that EPA require WRG to
utilize the best available control technology to eliminate
offensive odors from the Stripping Tower and inquired what
the air quality levels are expected to be.
EPA's Response;
Emissions from the stripper at the time of remedy
implementation is a concern that the GPs have taken into
consideration during formulation of the selected remedy.
The ROD indicates that in accordance with Massachusetts Air
Quality Control Regulations in 310 CMR 7.00, the ARS air
stripping tower will be upgraded by installing best
available control technology (BACT). It is anticipated that
BACT would be carbon adsorption to control contaminant
levels in air emissions from the groundwater treatment
facility. This requirement is being imposed on new air
strippers and any existing units that are modified or found
to cause an odor. If additional controls or changes in
operations are needed to address odors, they will be
required. The requirement for Best Available Control
Technology (BACT) at the air stripper will reduce to the
extent practicable the gas phase contaminants at the point
of emission. The specific technology and the levels of
reduction that will be achieved, and a performance
demonstration requirement in terms of removal efficiencies
and target stack and ambient concentrations will be
established in the design phase of the remedy.
Commentt One resident urged that the ARS system remain in
operation at least until groundwater monitoring reveals
concentrations at or less than the most updated MCL levels
at the time of monitoring. The commenter asked EPA to
consider using an alternative groundwater target cleanup
level.
EPA's Response:
EPA will require the continued operation of the ARS until
the aquifer is restored to a fully useable condition;
decisions regarding standards to be used to determine the
fully useable condition have yet to be established.
Promulgated standards and site-specific risk based levels
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will be fully considered in the decision-making process.
4. Suggested Alternatives
Comment; Many commenters suggested remedial alternatives to
the proposed cleanup of solidifying Site contaminants and
capping the landfill. These alternate suggestions included:
excavating and lining the landfill or creating a new
landfill; air stripping the contaminated sludge and soils
instead of moving them to the Industrial Landfill;
transporting the waste to an off-site facility; or use other
remedial technologies such as in-situ bioremediation or on--
site incineration or some other in-situ technology. Some
commenters expressed dismay that EPA had not developed its
own engineering plan, but instead relied almost entirely on
the alternative proposed by COM, WRG consultant.
EPA Response: The Phase IV Report, like all feasibility
studies, evaluated a number of distinct alternatives
representing a range of remedies. Although some of the
commenters suggested alternatives or technologies that were
not specifically evaluated in the Phase IV Report, the Phase
IV Report evaluated a range of alternate approaches like
those suggested in the comment.
The process of developing the Phase IV Report followed the
phased approach outlined in the 1980 Consent Decree and
Administrative Order, and closely paralleled the EPA
established procedures for developing a Feasibility Study
under the NCP.
EPA followed a procedure for remedy selection described in
the ROD that is consistent with 40 CFR 300 the National
Contingency Plan, CERCLA, and SARA. The first phase of
remedy selection included completion of remedial
investigations and the identification and screening of
alternatives. The screening process was completed and
conditionally approved by the GPs prior to issuance of the
first Draft Phase IV Report.
The Phase IV Report reflects a two and one half year
interactive effort between WRG, EPA, Massachusetts DEP, and
consultants to WRG and the Town of Acton. The first Draft
Phase IV Report was issued in December 1986; additional
Phase IV Report revisions/addendums were issued in response
to EPA comments in February 1987, March 1988, May 1988,
August 1988, and June 1989. During the course of these
various revisions, numerous meetings and consultations were
held between the GPs and WRG representatives, during which
the GPs directed WRG to correct, modify, revise, and expand
analyses as necessary to reach an acceptable feasibility
study useful in providing a foundation for the selection cf
a remedial action by the GPs. The Phase IV Report was
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extensively reviewed at each revision by GPs engineers and
scientists, and their consultants. The efforts of the past
few years have considered a range of feasible alternatives
for cleanup of the source areas at the Site. EPA and MA DEP
have independently reviewed and analyzed the alternatives
that are appropriate for the Site and believe the Phase IV
Report is of sufficient technical quality to proceed with
the selection of a source control remedy.
5. Miscellaneous
pettnm»T
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in a Record of Decision to assure a remedy will be
implemented at Superfund site. Such administrative
requirements are not considered to be ARARs under Section
121 of CERCLA.
fv*nimon+-. wRG stated that, as set forth in the Phase IV
Report, it believes that the Proposed Plan will achieve the
statutory standards listed on page 10 of the Proposed Plan.
EPA's Response:
EPA has determined that the Proposed Plan, as developed by
EPA, will achieve the statutory standards listed on page 10
of the Proposed Plan.
rnmmoTifc' One citizen asked how the public can be sure that
only five indicator compounds need to be treated and that no
other toxic materials are accumulating somewhere else in the
Site environment. The citizen asked why other chemicals
present at the Site will not be monitored, and asked EPA to
provide the rationale for selecting only five chemicals as
indicator compounds.
EPA's Response;
The establishment of clean-up goals for a select group of
indicator compounds is consistent with the EPA approach for
Superfund site remediation. The purpose of this approach is
to focus the remedial effort on those contaminants of
greatest concern, while assuming that any treatment system
designed to eliminate these compounds will also reduce the
levels of other Site contaminants. The ROD indicates that
to the extent other compounds are identified at any time in
the underlying soils that would not be adequately addressed
by the selected indicator compounds, additional remediation
would be required to attain the cleanup objectives.
Confirmation sampling will include analysis for other
compounds, including heavy metals known present at the Site.
Confirmation sampling will seek to confirm the remediation
plan to use indicator compound soils cleanup goals to assure
all contaminant levels are reduced to acceptable levels
protective of human health and the environment. The
selected remedy includes a commitment to perform additional
remediation to attain cleanup objectives if compounds other
than the indicator compounds are identified in the soils; in
order to achieve this, confirmation sampling will include
all contaminants known present at the Site.
Comment; One citizen asked if EPA establishes cleanup
objectives for a site based on reducing rather than
eliminating risks to public health, and if so, what level of
risk EPA is attempting to achieve. The citizen referred EPA
to page 9, paragraph 1 of the Proposed Plan.
EPA's Response;
Section 121 of the Superfund statute requires that the
remedy at a minimum, must assure protection of human health
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and the environment. EPA uses risk management tools to
determine protectiveness. Using these tools, EPA has
selected protective Soil Cleanup Goals in conformance with
the requirements of the statute. The risk is within an
acceptable range of 10"* to 10" .
r»«mm »*+•;• An ACES representative referred to page 9 of EPA's
Proposed Plan, where it is stated that the soil cleanup
goals were generated using a model developed by the WRG and
asked if EPA could provide detail on that model.
EPA's Response:
Appendix A of the ROD has a full description of the model
used to determine Soil Cleanup Goals.
gammon*-* Commenters asked when excavation activities would
begin and how remedial cleanup actions can begin early in
1990 when EPA has not yet entered the Design Phase.
EPA's Response;
The implementation of remedial activities will depend on the
finalization of and approval by the GPs, all prerequisite
design and planning activities. Implementation will occur
as soon as possible in order to mitigate any continuing
releases addressed in this source control remedy.
Comment: A New Hampshire resident asked if all waste
materials from the Site would be incinerated in Acton or if
they would be transported to Nashua for incineration in the
facility there.
EPA's Response: Slowdown Pit materials contaminated with 100
ppm or greater levels of VDC will be transported off-site
for incineration at a RCRA incineration facility licensed to
incinerate the type of waste from the WRG Site in compliance
with all applicable state and federal requirements and in
compliance with the EPA's off-site policy. The actual
facility has not yet been identified. However, the
incinerator at the WRG Nashua facility is a process waste
incinerator and is not licensed to accept hazardous waste
for treatment.
Comment; Commenters asked how much consideration cost
factors were given in EPA's evaluation of cleanup
alternatives.
EPA's Response;
In selecting the remedy for the Site, EPA evaluated each
alternative against nine established evaluation criteria, as
required by the statute. The purpose of this analysis is to
objectively assess the alternatives against each criteria to
determine the relative performance of the alternatives and
identify major trade-offs between them. One of the criteria
is costs.. EPA used all of the information, including costs,
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to select the remedy for the Site.
r?ftitnn«nfci one resident asked whether or not an artificial
removal/recharge scenario has been simulated with CDM's
computer model to determine if it will adversely affect
quantity/quality of groundwater available to Assabet Wells.
EPA's Response;
Such a study has not been performed since the studies
performed in association with the ARS program in the early
1980s. Since the ARS has been in operation for a number of
years without a significant adverse hydrologic impact on the
Assabet Wells, and the hydrology of the aquifers do not
suggest that the selected remedy will impact Assabet Wells,
none is planned at this time. However, under OU Three,
these scenarios may be considered.
pomniATit'; one citizen referred to the Environmental
Reporter, Volume 18, number 40, page 2079, January 29, 1988
which discusses two landfills which have sludge contaminants
comparable to the ones at the W.R. Grace site in Acton. The
citizen referred EPA to case number EPA V38816DC, and asked
that EPA read that article and the remedies described there
and explain how it applies to the Acton site.
EPA's Response:
The report referenced above cites an enforcement action
taken in EPA Region III at the Coker's Landfill. The
article contained no descriptions of remedies;- it referred
to a January 5, 1988 Administrative Consent Order that
outline a program of study leading to the development of
remedial alternatives, similar to the program used to date
at the WRG site.
one resident asked where the Chip Pile Area is
located and asked if the Chip Pile Area will be remediated.
EPA's Response;
The Battery Separator Chip Pile is located within the
Battery Separator Area. The Battery Separator Chip Pile will
be closed as a solid waste landfill in accordance with
Massachusetts Regulations in 310 CMR 19.00. These
regulations require, among other things, capping the
disposal area with an impervious material. The 310 CMR
19.00 regulations prescribe a thorough closure program that
the GPs believe is protective. The final cap over the Chip
Pile will consist of a minimum of twelve inches of
impervious final cover material with a coefficient of
permeability of less than or equal to 1 x 10"7 centimeters
per second, or a synthetic equivalent, overlain by at least
a six inch minimum thickness of drainage blanket layer of
sand, and a top layer of at least six inches of loam that
will support vegetation. The final cap will be graded so
that surface water will not accumulate and will be at a
25
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slope greater than three percent.
r»r>mTnent« One Town of Acton representative recommended
evaluating the feasibility of including excavated Chip Pile
materials under the cap proposed for the Battery Separator
lagoons to consolidate the waste piles and to decrease the
size of the pile that would require capping. The commenter
suggested that this option could result in lower capping
costs and enhanced cap integrity and stability.
EPA's Response;
EPA will consider during the design phase, the technical
feasibility of excavating the Chip Pile and placing these
materials into the Battery Separator Lagoon prior to
capping.
commonfc» A representative of the New England chapter of the
Sierra Club stated that the presence of metals in
incinerator ash is not a valid reason for EPA to have
rejected the choice of on-site incineration because metals
are already present in the material EPA proposes to leave
on-site. He also stated that the composition of ash could
be determined by trial burns prior to full-scale
incineration.
EPA's Response;
On-site incineration was not rejected solely based on the
metals in ash concerns. The implementability and short-term
effectiveness of excavating the landfill was considered.
The excavation of the landfill and materials storage and
handling would present the threat of contaminant release in
air emissions over several years. The potential for
releases is increased for off-site incineration, due to
shipment preparation. Also, due to the heterogeneous nature
of wastes present in the landfill, more than one
incineration technology may be required.
r?QinniftTit--« One resident requested that the ROD explicitly
state that EPA and DEP retain the right to require further
action at the Site in the future.
EPA's Response;
The ROD requires further action at the Site under OU Three.
The decision contained in this ROD, OU One, provides for
surface remediation. Future EPA decisions will address the
need for residual soil contamination and groundwater
contamination.
B. Comments Regarding Contamination at the Site
1. Ground and Surface Water Contamination
Comment; One ACES representative requested maps of
contaminant plumes showing where the plumes are going, and
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what they will do in the Assabet River. The representative
also asked that plume maps be prepared not only by year, but
by contaminant, as well.
EPA's Response:
These comments address migrated contaminants associated with
groundwater contamination. This ROD addresses only the
source control Operable Unit and acknowledges the need for
further investigation of the groundwater. Items raised in
these comments will be addressed in the future during
Operable Unit Three.
r?ftmm«Tifc« An ACES representative reported that, based on two
documents prepared for the Acton Water District and noted
below, there is evidence that "the Secondary Lagoon (on W.R.
Grace property) and vicinity is the primary potential source
area for the VDC plume" detected in the Lawsbrook Aquifer.
The representative cited two relevant documents:
o "Lawsbrook Aquifer Contamination Study", File No. A-
2949, by Goldberg-Zoino & Associates (GZA), March 1985.
o "Reconnaissance Contaminant Hydrology, Southern
Lawsbrook Aquifer", by Pine and Swallow Associates
(PSA), May 1986.
The representative stated three conclusions that it reached
following a review of these two documents. These are listed
below:
1. It is apparent that the original contaminants from
the W.R. Grace site have taken, and will continue
to take, a long time to finally migrate off-site
to other locations.
2. The above studies reveal that theoretical models
are of value in pointing to and estimating
potential contamination problems and their
sources. However, the modelling must be based on
sound input from extensive and reliable data
sources, and must be redone every 4 or 5 years.
3. All modelling must be verified by field
measurements from observation wells at varied
locations and at varied depths and times.
EPA's Response;
This comment address contamination associated with the
groundwater migration and suggests that modelling be
recalculated and verified by field measurements. This ROD
is a source control OU and requires future groundwater
investigations. These comments will be considered during
the future groundwater study and decision.
Comment: An ACES representative, referring to the
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contamination issues discussed in the previous comment,
asked what consideration has been given to other possibly
polluted areas, such as the private wells serving the Parker
Street apartments and condominiums. The representative
expressed concern;that, while this water is not used for
drinking, it is used regularly in lawn care sprinkler
systems, and if contaminated, could contribute to air
pollution. The representative asked if homes using private
wells would receive warning that there could be contaminants
in their water.
EPA's Response:
This comment is not specific to the selected remedy.
However, Massachusetts and the local Board of Health should
be consulted for advice concerning the use of individual
water supplies.
ronntiAni-• one resident asked what the present source of
drinking water is for citizens living in areas where wells
have been contaminated. In addition, the resident asked how
often the present water supplies are tested for
contamination, whether the results of such testing are made
available to the public, and what level of contamination is
allowed in drinking water.
EPA's Response;
This comment is not specific to the selected remedy.
However, Massachusetts and the local Board of Health should
be consulted for advice concerning the use of individual
water supplies.
Comment; The W.R. Grace Company expressed concern regarding
the soil cleanup levels EPA has set for bis (2-ethyl hexyl)
phthalate at the Site, because analyzing for phthalates
(BEHP) in soil is more prone to inaccuracies than analyzing
for them in water, and because there is also a high
probability of BEHP laboratory contamination. For this
reason, they proposed relying primarily on groundwater
analyses to ensure that BEHP contaminants will not exceed
MCLs in groundwater.
EPA's Response:
These comments address contaminants associated with soil, as
compared to groundwater contamination. The selected remedy
addresses soils contaminants in the source control operable
unit remedy in order to safeguard against exposures
including continuing releases to groundwater, and
acknowledges the need for migrated contaminant management.
Groundwater issues raised in these comments will be
addressed in Operable Unit Three. While groundwater
monitoring is required under the ROD, requirements for soils
cleanup is an important component of the remedy, despite the
fact that analysis of soils is subject to greater
variability than analysis of groundwater.
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The detection limit range of 20 ppb to 2000 ppm listec _n
the comment reflects the fact that the soils matrix
influences the achievable detection limit, not the BEHP
analyte. This is common to all soils analyses, not only
BEHP. The sample preparation steps taken to release soils
contaminants for analysis"is an additional step not needed
in water analysis that reduces the accuracy of soils
analysis. In addition, the range also depends on the number
of other analytes present and the need to dilute samples to
complete an analysis for multiple analytes in survey mode,
which is a costs factor rather than a purely technical
issue. The CLP limits of detection for BEHP in soils is 330
ppb; the 1600 ppb value given in these comments refers to
phenols. The CLP methods may not be appropriate for WRG in
determining if soils cleanup goals have been met. EPA
method SW 846 Method 8060 (Modified) includes GC/MS analysis
with precautions for cleanup of glassware and reagents that
can achieve lower detection limits than other methods.
Comment; Several commenters requested more stringent
groundwater cleanup goals than drinking water MCLs and
indicated that such goals should be below drinking water
MCLs,
EPA's Response:
EPA's Superfund program operates within the framework of
EPA's Groundwater Protection Strategy in determining the
appropriate remediation for groundwater. The goal of this
approach is to return useable groundwater to their
beneficial use within a timeframe that is reasonable, given
the particular circumstances at the Site. Given the fact
that the groundwater at the Site is class II, an existing or
potential source for drinking water, EPA generally uses the
standards established under the Safe Drinking Water Act of
more stringent state standards to establish the remediation
goals.
pammAnt-' one citizen asked what would happen if water
seeped into the lagoons, whether it would be contaminated,
and what would be done with the water.
EPA's Response;
Water entering the lagoons currently either evaporates or
percolates down into the subsurface. The goal of the
operating ARS is to capture such water and treat it. The
ROD indicates that interim measures will be taken as soon as
possible to minimize the infiltration of surface water and
migration of contaminants into the residual soils.
Comment! One citizen stated that groundwater flow
information is inaccurate and explained that contamination
from the landfill could be drawn into Assabet Wells No. 1,
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2, and 3 if the landfill were left uncovered or if there was
a failure of the landfill cap.
EPA'S Response:
The remedy selected in the ROD calls for capping the
landfill and capturing and treating all groundwater flow in
the landfill vicinity. The GPs are confident that the
hydrogeologic regime in the vicinity of the landfill is
understood so as to .properly design and install the
Industrial Landfill Groundwater Recovery System, and
continue to monitor the groundwater.
2. Soil Contamination and Sludges
gomtn«»Ti«-» one resident requested that EPA establish soil
cleanup goals for compounds in addition to the indicator
compounds. The resident requested that EPA conduct a risk
assessment to evaluate risks posed by compounds that would
not be specifically addressed by soil cleanup goals.
EPA's Response;
Appendix D to the Phase IV Report (in particular
chapter 2) includes an extensive discussion of contaminants
detected at the WRG site and the selection of indicator
chemicals. The GPs carefully reviewed the risk assessment
provided by WRG and found a number of problems with the
approach, which the GPs corrected through completion of
supplemental studies by EPA, DEP, and their consultants.
The term Soil Cleanup Goals is intended to refer to
indicator compounds .or any other compounds that EPA and DEP
determine are not adequately addressed by the currently
selected indicator compounds.
Comment: WRG reported concern about the potency factor of
1.4 x 10"2 used for calculating the soil cleanup levels for
BEHP because reliable reports reference a potency factor of
8.36 x 10'3.
EPA's Response:
The carcinogenic potency factor of 1.4 x 10-2 (mg/kg/day)'1
is found in the 1989 U. S. EPA Health Effects Assessment
Summary Tables - FY89, Office of Research and Development,
U.S. EPA, January 1989.
roTmnanfci one Town of Acton representative requested that
EPA use laboratory column leaching tests to verify the
leachate contaminant concentrations following soil
excavation and cleanup.
EPA's Response;
The Soil Cleanup Goals were generated by EPA using a model
developed by W. R. Grace and their consultants. The model
and the calculations for establishing the Soil Cleanup Goals
are described in Appendix A to this ROD. The EPA and DEP
have reviewed this model and believe that it is a reasonable
30
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tool for developing appropriate Soil cleanup Goals. The EPA
does not believe it is necessary to conduct laboratory
column leaching tests to verify the leachate contaminant
concentrations.
rr>mwi«»nti An ACES representative stated that xylene is found
in the Primary and Secondary Lagoons and asked where this
chemical comes from and what effect it can have on people
and the environment.
EPA's Response;
A review of interrogatories provided in 1980 by WRG
indicates a number of industrial chemical manufacturing
operations discharged to the primary and secondary lagoons
over time. It is likely xylene, a common solvent, was used
in the manufacture of certain products by solvent
polymerization; another possible source was the container
sealing compound manufacturing. Xylene has been shown to be
fetotoxic in rats and mice. In humans, exposure to high
concentrations of xylenes adversely affects the central
nervous system and aggravates mucous membranes.
Comment; One resident was concerned about chloride
emissions from the landfill.
EPA's Response;
The ROD indicates that to attain Massachusetts ARARs found
in Massachusetts Regulations 310 CMR 19.00 (Solid Waste
Regulations) and in 310 CMR 7.00 (Air Quality Control
Regulations), emissions from the Industrial Landfill vents
will be controlled utilizing best available control
technology (BACT). It is anticipated that BACT will
eliminate any discharge of contaminants to the ambient air.
rrmimoTit-; one citizen asked if metals and phthalates are
permanently located in the unsaturated soils just below
their source lagoons, and what assurances there are that
these compounds will not migrate to groundwater, and if
future monitoring is scheduled for these contaminants.
EPA's Response:
Metals and phthalates are located in both wastes and soils
at the Site; confirmation sampling will include analysis for
other compounds including heavy metals known present at the
Site. Confirmation sampling will seek to confirm the
remediation plan to use indicator compound soils cleanup
goals to assure all contaminant levels are reduced to
acceptable levels protective of human health and the
environment. The ROD includes a commitment to perform
additional remediation to attain cleanup objectives if
compounds other than the indicator compounds are identified
in the soils. In order to achieve this, confirmation
sampling will likely include all contaminants known present
at the Site.
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3. Miscellaneous
nnmmnnt! An ACES representative, referring to Appendix A,
on page A7, 1.3.1.1 of the Phase IV Report, asked what the
contaminants of concern are and how they were determined.
EPA's Response:
The contaminants of concern or indicator compounds for
groundwater are listed in Table 1 of the ROD. The number of
contaminants detected at many Superfund sites is often too
large to quantify all possible health risks. Thus, a subset
of these compounds known as contaminants of concern or
indicator compounds, is selected to serve as the focus for
further risk calculation efforts. They are selected based
on those that are likely to contribute most to the overall
risk. Selection of contaminants of concern is based on
concentration, toxicity, frequency of detection, sample
location, and the chemical and physical properties of the
compound which determines its environmental fate and
transport.
r?gtn»TnATi-h• An ACES representative cited Figure 4.2.5 of the
Phase IV Report and requested a similar figure for each
contaminant.
EPA's Response:
Figure 4.2-5 illustrates groundwater contamination in the
vicinity of the Industrial Landfill. Groundwater
contamination is an issue the GPs will evaluate under OU
Three. It is not addressed in the source control proposed
plan.
roiHTHgnt• one citizen stated that CDM's analysis of
chemicals at the W.R. Grace site contains distortions and
errors and fails to mention the styrene in the ground, and
the oil and hexane which is currently leaking on-site. The
citizen also stated that, to date, WRG has collected more
oil and hexane than they have ever admitted is present on-
site.
EPA's Response;
The absence of discussion of the Styrene release and Styrene
tanks closure at the WRG Acton site in the Phase IV Report
is considered appropriate by the GPs in view of the fact
that the Styrene problems have been addressed previously in
separate actions conducted by the GPs. Three Styrene tanks
were operated by WRG between 1950 and 1981. In 1986, WRG
prepared a plan to close these tanks by dismantling the
aboveground tank and filling the two subgrade tanks
containing hardened polystyrene with sand and concrete. The
GPs studied the styrene issues carefully and concluded the
nature and form of the polystyrene present, and the
containment of the polystyrene during a rapid polymerization
event within the tanks was supportive of the plan to handle
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this environmental issue as proposed. The oil and hexane
releases were terminated in the early 1980s and recovery and
monitoring was instituted to address these releases that are
physically separate and distinct from the problems addressed
in the proposed plan. The GPs are confident the oil and
hexane releases are being addressed via remedies already in
place.
Comment; A Nashua, New Hampshire resident and a New
Hampshire journalist asked whether or not there are any
waste products from the W.R. Grace facility in Nashua, New
Hampshire which were placed in the landfill at the W.R.
Grace facility in Acton, Massachusetts and if so, requested
a list of which specific contaminants Nashua might have
contributed.
EPA's Response;
For a period during late 1977 and early 1978, a few
truckloads of manufacturing by-product waste containing
ammonia produced at Grace's facility in Nashua, New
Hampshire were disposed of in the Secondary Lagoon.
Comment: An ACES representative referred to Chapter IV of
the Phase IV Report, which states that only two chemicals
will be addressed, the representative asked why these two
chemicals were singled out and requested a list of the
chemicals, ranked according to level of risk, which have
been used since 1970 (and earlier, if available).
EPA's Response:
Appendix D to the Phase IV Report (in particular chapter 2)
includes an extensive discussion of contaminants detected at
the WRG site and the selection of indicator chemicals. The
GPs carefully reviewed the risk assessment provided by WRG
and found a number of problems with the approach, which the
GPs corrected through completion of supplemental studies by
EPA, DEP, and their consultants (June 1989 Risk Analysis of
the W.R. Grace Site). EPA has indicator compounds for this
source control operable unit. EPA does not believe it is
necessary to evaluate all the chemicals found at the Site.
The number of contaminants detected at the Site is often too
large to quantify all possible health risks. Thus, a subset
of these compounds known as contaminants of concern or
indicator compounds, is selected to serve as the focus for
further risk calculation efforts. They are selected based
on those that are likely to contribute most to the overall
risk. Selection of contaminants of concern is based on
concentration, toxicity, frequency of detection, sample
location, and the chemical and physical properties of the
compound which determines its environmental fate and
transport.
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C. ruminants Regarding Bioremediation
Several citizens and ACES representatives
suggested that EPA give careful consideration to
bioremediation to treat contamination at the W.R. Grace
site. They referenced several studies supporting
bioremediation of certain compounds. They also referenced
Appendix G of CDM/Grace Phase IV Report and felt that this
information supported the use of bioremediation as a
remedial approach. They recognized that the appendix
discusses only aerobic biodegredation and asked about
anaerobic biodegredation. They also asked if biodegradation
could be utilized in the other waste areas with the
consideration of adding nutrients or "farming" the wastes.
EPA 'a Response; The GPs have carefully considered the role
of biodegradation at the WRG site. Biodegradation will
likely occur for some contaminants at the W.R. Grace site;
however, some of the predominant contaminants which the GPs
are most concerned about (vinyl chloride and VDC) , as well
as other Site contaminants, are unlikely to be biodegraded.
Conditions for biodegradation are limited and time rates for
contaminant reduction to Soil Cleanup Goals are unknown.
The EPA recognizes that numerous studies and applications
have demonstrated the biodegradability of nonhalogenated
compounds such as benzene and toluene; however, the
chlorinated compounds such as VDC and vinyl chloride are
only marginally biodegradable. Vinylidene chloride is one
of the most predominant contaminants at the Site.
Therefore, predictions of degradation of these compounds is
not useful for mitigation of the bulk of Site soils
contamination .
Biodegradation of the soil contaminants in the plume of
migrated contamination at the Site has been the subject of a
limited study performed by CAA under contract to WRG
(Appendix G) . The EPA reviewed the results of the studies
when the data became available in May and October 1988.
Concerns focused first on the limited number and class of
contaminants for which biodegradation was investigated.
Notably, VDC and vinyl chloride were not investigated.
Secondly, the Grace study only assessed aerobic degradation.
Aerobic metabolism of organics is much faster than anaerobic
degradation due to the biochemistry of the process. The
study also confirms that the rate of aerobic degradation is
widely variable and dependent on the concentration of
oxygen. The study indicates groundwater oxygen levels below
the landfill are within the range of significantly reduced
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biodegradation (P.13 of Appendix G). The EPA believes that
for the majority of the contaminated soils at the WRG site,
anaerobic conditions will be probable, and oxygen levels
will limit the rate of biodegradation. Amendment of soils
with oxygen in unsaturated zones will likely enhance
partitioning of volatiles to soil gas (volatilize them to
the air), rather than enhance biodegradation.
Thirdly, the rate of biodegradation curves presented in the
report indicate that as substrate (i.e. biodegradable
contaminant) concentration decreases, so does the rate at
which it is decreased. Extrapolations to the zero ppb level
are from the hundred ppb level, and are hypothetical. EPA
is concerned about biodegradation being able to achieve
Soils Cleanup Goals in a measurable time frame.
Considering landfarming, the elevated concentrations of
contaminants within the contaminated sludges present at the
majority of waste sites presents a more severe environment
unfavorable for microbes than in the soils. Landfarming of
contaminated soils will also promote volatilization of
contaminants in addition to biodegradation. Such intermedia
transfer is undesirable.
In summary, a bioremediation remedy is subject to
feasibility limitations of the bioremediation technologies
due to the concerns presented above primarily due to the
presence of chlorinated organics resistant to
biodegradation. Concentrations of contaminants in wastes
may be toxic to microbes. Active landfarming biodegradation
techniques will promote intermedia transfer of soils
contaminants to the atmosphere. Reviews performed by the
EPA and their contractors have not supported the further
investigation of this approach.
D. Comments Regarding Public Involvement
Comment; A resident commented that thirty days was an
insufficient amount of time for public comment prior to a
Record of Decision, and quoted a Special Report of the
Office of Technology Assessment on Superfund Implementaton
entitled "10 Case Studies", which contends that pressure to
complete RODs by the end of the fiscal year can lead to poor
cleanup decisions.
EPA's Response;
EPA is required to conduct a 21-day comment period prior to
reaching a Record of Decision to address Site contamination.
EPA recognizes that the 21-day period is relatively brief
and therefore extended the comment period for the W.R. Grace
site to 32 days. EPA has also addressed the issue of time
limitations by making technical documents available for
public review through the Acton Town Hall and Public Library
as they have been completed. EPA also held a public meeting
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on the draft Phase IV Closure Plan in December 1988 to
familiarize the public with the draft plan and allow
opportunity for pubic comment. The draft plan was therefore
available for more.than six months prior to the beginning of
the formal comment period.
Additional efforts were made to supply the Proposed Plan
summarizing the Site history, results of technical studies,
optior.3 for remedial action and the preferred alternative,
to over 500 people on the Site mailing list. Other actions
to inform and involve the public are listed in Attachemnt A
of this document. Based on the fact that these actions have
provided enhanced opportunity for review and comment on
documents, EPA determined that the comment period was
adequate and meets all statutory obligations for allowing
opportunity for review and comment.
EPA also notes that the Office of Technology Assessment
report presents general conclusions that are not based on
consideration of the history of community and Town of Acton
involvement over a period of years in EPA decisions
concerning the W.R. Grace site. EPA has based its cleanup
decision on years of study and considered evaluation with
input from the Town of Acton, and does not consider its
decision rushed or flawed.
lent: One resident stated that because EPA does not
evaluate community acceptance as part of the development of
a preferred alternative, it is not given equal weight with
other evaluation criteria, such as cost effectiveness,
identified in the Proposed Plan.
EPA's Response;
EPA evaluates community acceptance principally based on
comments received during the public comment period. Public
comments are carefully considered prior to any final
decision on Site cleanup. EPA presents its preferred
alternative at the start of the public comment period to
help the community understand and focus comments on that
preferred alternative. The public, however, has been
encouraged to comment on all alternatives given detailed
screening in the Phase IV Closure Plan, since none of the
alternatives evaluated in detail are definitively rejected
until public and State comments have been considered.
The nine criteria, including public acceptance, are not
assigned individual weighting factors during evaluation of
remedial alternatives. EPA balances the criteria to develo:
a remedy that provides overall protection of human health
and the environment.
Comment; One resident asked that copies of the ROD and
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Responsiveness Summary be sent to newspapers in Acton.
EPA'S Response:
An announcement and brief summary of the ROD will be
published as a paid public notice in the Middlesex News.
Copies of the complete ROD and Responsiveness Summary will
be available at the Acton Public Library and at EPA
headquarters in Boston. Copies will be supplied through the
EPA Public Affairs Office in Boston upon request.
ffemmenti one resident asked if the ROD can be changed after
it is signed.
EPA's Response;
The ROD can be changed after it is signed. The process for
making changes can be found in an EPA guidance document
entitled "Interim Final Guidance on Preparing Superfund
Decision Documents" (OSWER Directive 9355.3-02).
E. General Comments
Comment; One ACES representative asked what specific health
and safety standards EPA could guarantee Acton citizens over
the next several decades. The representative asked EPA to
be as specific as possible regarding the standards that
would be maintained.
EPA's Response:
EPA will ensure that the remedy is fully protective of human
health and the environment. EPA will review the Site at
least once every five years after the initiation of remedial
action at the Site to assure that the remedial action
continues to protect human health and the environment, in
accordance with Section 121(c) of CERCLA. EPA will also
evaluate risk posed by the Site at the completion of the
remedial action (i.e. before the Site is proposed for
deletion from the NPL).
Comment: An ACES representative asked what the ambient air
will be like if CDM's option is used.
EPA's Response;
Ambient air at the time of remedy implementation is a
concern that the GPs have taken into consideration during
formulation of the proposed remedy. The potential for
release of volatile contaminants to the atmosphere
represents the greatest risk of air pollution during the
remediation. This has been addressed in the proposed plan
under the VFL stabilization process description, which
includes a discussion of controls to be used on the mixing
equipment to capture and treat off gases. In addition,
existing releases from the ARS air stripper would be
controlled by installing a control device to treat these
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emissions as described on page 15 of the proposed plan.
Finally, the releases -of gases from the vents in the
landfill will be carefully evaluated and best available
control technology applied to control releases, as described
on page 15 of the Proposed Plan.
Comment; One Town of Acton representative indicated that
EPA's risk analysis did not include an evaluation of
potential risks to the environment, and questioned whether
these potential impacts have been adequately addressed. The
commenter also asked that the potential exposure pathways
and associated risks that were evaluated in CDM's Phase IV
Baseline Risk Assessment be presented. The commenter
requested the definition and identification of all exposure
points, and specifically asked that air be added as an
exposure media.
EPA's Response;
The Town of Acton is correct in indicating that the EPA Risk
Analysis (Prepared, June 1989) does not evaluate the
potential risks posed to the environment by the release of
contaminants from the W.R. Grace site. However, EPA notes
that the selected remedy has been developed with both human
and environments protection in mind. See the remedial
action objectives section of the ROD. Actions taken to
limit and protect human exposure will also serve to limit
and protect environmental exposure. Although an extensive
analysis of baseline risks to the environment has not been
conducted, the proposed remedy will provide protection to
public health and the environment.
Air has been considered as an exposure media at the W.R.
Grace site. In fact, EPA has conducted a risk assessment
which evaluated the risks associated with exposure to
contaminants released from the air stripping tower
(considered to be the primary source of airborne
contaminants). The results of the assessment did not
indicate that a risk to human health was posed by these
emissions. Further, during the source control remedial
actions, air emissions will be controlled in compliance with
air ARARs as well as to protect workers on-site. These
controls will effectively limit exposure pathways to both
human and environmental receptors. The source control
remedial measures will also minimize contribution from the
overlying soil to the groundwater. Therefore, the amount of
groundwater contaminants requiring treatment via the ARS
treatment system will continue to decline, which in turn
will lead to a continued reduction in VOCs at the tower.
Further, the remedy will serve to eliminate the potential
for release of contaminants through: immobilizing volatile
contaminants (stabilization and capping); covering any area
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are
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IV. REMAINING CONCERNS
Issues raised during the public comment period that will
continue to be of concern as activities at the Site move into the
RD/RA phase are summarized below, along with EPA responses.
r»rtmm«»Ti*-» one resident asked what opportunities there would
be for public review of remedial plans during the Design
Phase and if residents would be given an opportunity to see
if the design data responds to their questions and concerns.
EPA's Response;
The GPs are committed to involving the public during the
design phase of the remedial action. Documents developed
during the design phase will be reviewed by EPA and DEP and
discussed with the public for their comment and input.
pommgTij-* Commenters asked how ACES' TAG advisor will be
involved in future remedial design meetings and other
meetings associated with the cleanup at the Site and how EPA
plans to incorporate the findings of ACES' TAG research
during the design phase.
EPA's Response; The role of the technical advisor chosen by
ACES under the TAG program will be determined by ACES, since
this advisor will report directly to ACES during the
remedial design and construction phase. EPA will continue
to conduct public meetings or other forums in which
representatives of the public may discuss concerns with the
GPs. In addition, individuals and groups, as well as their
advisors, with concerns about the Site or the Superfund
program in general, are encouraged to call or write the EPA
Remedial Project Manager, Wayne Robinson, or the EPA
Community Relations Coordinator, Diane Ready.
r?f>mm«»Ti4- ? one citizen remarked that bringing 350 truckloads
of sand, soil and other materials to the Site will take six
months and create noise and traffic problems for residents
in the area. The citizen asked EPA to consider reactivating
the train system to handle this traffic.
EPA's Response;
The GPs have considered the truck traffic issue and have
concluded additional truck traffic (approximately 3 trucks
per day) can be accommodated without significant impact.
Train transport of materials has not been ruled out, but it
is unlikely to prove economically competitive for transport
over the short period of remedial measures implementation.
Commentt One resident asked how often the Site will be
tested once cleanup has been initiated. The resident also
asked whether test results would be available to the public
and where they would be located.
EPA's Response;
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Progress reports will be required from WRG by EPA and DEP as
the construction of the remedy progresses. Copies of these
reports will be forwarded to the Town Manager.
r?g>mm«nfc« one citizen urved that EPA require adherence to
strict air monitoring standards during VFL mixing and
emission control operations.
EPA's Response:
The GPs have focused on the volatilization of contaminants
from the sludges and soils solidified via the VFL process.
The concern has been expressed to W.R. Grace that releases
from these wastes must be controlled, that is, they must be
captured and treated. The ROD indicates that the mixer will
be enclosed and vented to an emission control system,
probably activated carbon, that would prevent emissions to
the ambient air during the process step.
Comment: Commenters requested that on-site and perimeter
air-monitoring be required during sludge excavation and
solidified sludge placement operations and asked that
contingency plans regarding air emissions be in-place prior
to commencement of excavation. The commenter also stated
that a backhoe, rather than a dragline, should be used for
sludge excavation to minimize repeated sludge handling,
particularly for the primary lagoon where "wet" sludges
still remain. The commenter added that using a dragline may
not minimize liberation of pore fluid and mixing of
excavated materials with the remaining sub-base materials.
EPA's Response;
These issues will be developed in detail during the design
phase of the remedial response. EPA intends to implement an
air monitoring program (on-site and perimeter monitoring)
during Site remediation activities, especially during
excavation operations. Additionally, contingency plans will
be developed. EPA will consider a backhoe for excavation
during the design phase to minimize the liberation of pore
fluid into the subbase during excavation activities. EPA
agrees that strict monitoring standards should be
established and adhered to during the VFL mixing operation.
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• one resident asked what measures are planned in
the event that monitoring shows actual results are poorer
than predicted.
EPA's Response:
In the event monitoring indicates the remedy is not
performing as planned, the GPs will evaluate the results and
determine an appropriate corrective measure for the
diagnosed shortcoming.
(-rtmmftnt; one resident asked what plans EPA has for
restoring the lagoons and pits that will be excavated.
EPA's Response;
If the confirmation sampling data indicate these areas have
residual contamination below the soils cleanup goals and are
at levels ensuring protection of the public health and the
environment, the excavated areas will be graded, covered
with a minimum of six inches of clean top soil and seeded or
vegetated to establish and support growth to control
erosion.
gg>mm«»mfci An ACES representative asked that all materials
brought to the W.R. Grace site for remediation be monitored
for content and place of origin.
EPA's Response;
The ROD requires clean fill be used for construction of cap
layers above the barrier layer; specifications for clean
fill determinations will be developed during the design
phase of the remedy.
comment? one resident asked when flushing of the Primary
Lagoon would begin. The commenter asked who is responsible
for developing the cleanup schedule and specifically
requested the timeframe for soil sampling, analysis,
excavation and flushing activities.
EPA's Response:
The flushing of the Primary Lagoon will only occur if
residual contamination exceed Soil Cleanup Goals set for the
Primary Lagoons; therefore, a specific time cannot now be
established for this activity. The GPs are responsible for
assuring W.R. Grace complete all remedial measures necessary
at the W.R. Grace site. The timetable for remedial
activities will be determined during design phase of the
remedy.
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ATTACHMENT A
Community Relations Activities Conducted at the
W.R. Grace Superfund Site
August 30, 1984 - EPA issued a press release to announce a
Public Meeting regarding the Aquifer Restoration System
(ARS).
September 12, 1984 - EPA and DEP held a Public Meeting
regarding the ARS.
October 22, 1984 - EPA issued a press release regarding the
ARS approval.
December 1988 - EPA conducted a public meeting to present
the draft Phase IV Report to Acton residents.
February 24, 1989 - EPA placed a public notice in the
Middlesex News describing the Technical Assistance Grant
(TAG) program and announcing receipt of a notice of interest
to apply for a TAG from the citizen group Acton Citizens for
Environmental Safety.
May 1989 - EPA and the MA DEP met with residents of Acton to
discuss opportunities for public involvement at the site.
July 19, 1989 - EPA delivered Administrative Record to site
for public review.
August 9, 1989 - EPA issues a press release and paid public
notice in the Middlesex News announcing 1) availability of
the Phase IV closure plan and EPA's Proposed Plan for
addressing sources of site contimination; 2) availability of
the Administrative Record for public review; 3) EPA's
schedule for a public informational meeting and informal
public hearing on the Proposed Plan; and 4) schedule for
public comment period.
August 10, 1989 •?• EPA released the Proposed Plan to address
sources of site contamination to the public through the site
mialing list of approximately 500 interested and affected
parties and through the Administrative Record.
August 14, 1989 - EPA delivered Addendum to Administrative
Record.
August 14, 1989 - EPA conducted a Public Informational
Meeting to present the Phase IV Report and the Proposed Plan
and answer questions.
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August 15 - September 15, 1989 - EPA held a Public Comment
Period to solicit citizens' comments regarding EPA's
preferred alternative for addressing contamination at the
W.R. Grace site.
August 23, 1989 - EPA issued a press release announcing the
awarding of a Technical Assistance Grant (TAG) to the Acton
Citizens for Environmental Safety.
September 12, 1989 - EPA held a Public Hearing to accept
oral comments on the Phase IV Report and Proposed Plan to
address sources of site contamination.
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ATTACHMENT B
September 12 / 1989 Informal Public Hearing Transcript
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1 UNITED STATES OF AMERICA
2 ENVIRONMENTAL PROTECTION AGENCY
3 BOSTON REGION
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5 In the Matter of:
PUBLIC HEARING
7 W. R. GRACE SUPERFUND SITE
PROPOSAL PLAN
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Town Hall
Acton, Massachusetts
Tuesday
13 September 12, 1989
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The above entitled mat-ter came on for hearing,
1C pursuant to Notice at 7:35 o'clock p.m.
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1g BEFORE: MERRILL HOHMAN, Director
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Waste Management Division
Environmental Protectior
J.F.K. Federal Building
1Q Environmental Protection Agency
2Q Boston, Massachusetts 02203
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INTRODUCTION:
Merrill Hohman, Director
Waste Management Division
New England Region EPA Office
5 PREFERRED ALTERNATIVE:
Wayne Robinson, EPA Project Manager
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Richard McAllister, EPA Office of Regional Counsel
Ed Benoit, Central Regional Engineer for Waste
Site Cleanup, Mass. Dept. of Environmental Protection
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Richard Boynton, EPA Project Supervisor
Diane Ready, EPA Community Relations Specialist
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2 ; 7: 35 p. m.
3 . MR. HDhilAN: Good evening. Can everyone hear? 1 =
the microphone on ol/av? Again, good evening and welcome.
5 My name is Merrill Hohman. I'm the Director of the Waste
6 Management Division for the New England Region of the United
States Environmental Protection Agency with the office in
Boston, Massachusetts.
My staff and I are responsible for implementing
the Federal Superfund Program here in New England, and I
will serve as the presiding officer for tonight.'s hearing.
12 Let me introduce to you the people that are up
13 here with me on the hearing panel. On my immediate right is
14 Wayne Robinson, who is the EPA Project Manager for this
15 site. To his right, Richard McAllister, an attorney with
15 EPA's Office of Regional Counsel. On my immediate left, Ed
17 Benoit. Central Regional Engineer for Waste Site Cleanup
18 with the Massachusetts Department of Environmental
19 Protection. Next to him is Richard Boynton. EPA's Project
20 Supervisor for this particular site. And at the door, we
have Diane Ready, who is EPA's Community Relations
22 Specialist that i£j assigned -to this site.
23 The purpose of this hearing tonight is to formal 1
24 accept comments on EPA's proposed plan for addressing t.*>e
25 sources of contamination at the W.R. Grace Superfund Site
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here in Acton. EPA held A public information meeting to
talk about our various alternatives here on August 14, 1989.
At that meeting we described the decision provess and th^
contents of EPA's proposed plan, and then had an opportunity
for general questions and answers and discussion with the
audience.
A more formal public comment period began August
15 and will end on September 15, 1989.
Before I actually begin the hearing, I want to
talk a little bit about the format that we will follow.
Essentially, the evening agenda will begin with a brief
presentation by Wayne Robinson Just to review for everyone
what EPA's plans are, or the proposed plans for this site,,
Following that presentation, I am then going to
provide an opportunity to W.R. Grace Company to provide
comments. Following that, we will proceed to accept any
oral comments 42£-3077
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be addressed in EPA's record of decision. asnd part of that
document includes something called a responsiveness summary,
which is a bureaucratic way of saying here are the comments
that we got from people, and here is EPA's response to those
comments. So that will become part of the record.
Once all of the formal comments have been entered
into the record tonight, then we will close the public
hearing. I think at that point, at least some of EPA's
staff will stay. If you have questions or things you want
to ask or clarify, feel free to contact them and discuss it
with them. And then, hopefully, that will enable you to
provide written comments to us with your opinions on the
proposed plan. And again, those written comments must be
sent to us by September 15th."
Now. for those of you who wish to testify tonight
or wish to comment, you should have indicated your desire to
do so when you came in the door by filling out the
registration form available from our representative. If yo<.
have not registered to sign up to speal-, then you will not
be called, at least during the early part of the evenina.
I will call on those of you who have signed up to
make a statement in the order in which you signed up. I
would also acknowledge or re-cognize that some of you may
have personal commitments or problems. And if you do have,
speal- to Diane Ready at the door, and we'll try to squeeze
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you in out of order if there is some pressing need for you
to be somewhere else as well this evening.
When we call upon you, I would ask,. since we ar^F
having a transcript of this hearing, I would ask that you
come up to the mi.crophone up here, identify yourself, your
name, where you come from, and comment speaking into the
microphone so that we can have a good record of all your
comment s.
We do have a number of speakers that have signed
up already. So I do ask that you limit your comments to not
more than ten minutes. If you have a formal presentation
that you want to make that is going to take more than ten
minutes, I would respectfully ask that you summarize it in
ten minutes or less and submit to our reporter over here the
complete- document. And tht? complete document then will
p u t i n t o t h e r e c o r d .
Again, I would encourage you also to submit
written comments if you hove any, or at the conclusion of
tonight's hearing. And again, I want to remind you those
comments must be postmarked no later than September 15, T5S9
and mailed to our office in Boston. The appropriate address
can be found in the proposed plan that was circulated. And
I believe there are additional copies of that proposed plan
at the registration desk if any of you need them.
Are there any questions on how we are going to run
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the hearinq? I should add that we won't have any formal
2 "question and answer discussion. But the members of the
3 panel up here may as^ you after you complete your statement -
-they may have some questions simply to clarify our
5 understanding of what you are saying, what your position is.
5 So I hope you will bear with us and not mind answering our
7 questions, although during the formal period we will not
3 answer yours
Any questions on the format? Okay. Then what I
would like to do is to begin by calling on Wayne Robinson,
the project manager, to give a very brief, not more than
12 ten-minute I hope, Wayne, overview of the proposed plan for
13 the W.R. Superfund Site in Acton. Wayne?
14 MR. ROBINSON: Thank you, Merrill. My description
15 of the preferred alternative will be pretty brief. And
16 again, it's the preferred alternative to clean up the
17 sources of contamination at the site.
i8 The first part of the remedy will be to excavate
19 the mats:'ia 1 from the primarily lagoon, secondary lagoon,
2o and emergency lagoons. All the sludge will be excavated,
21 and an Additional two feet of soil underneath the sludges
22 will be excavated. This material will then be solidified
23 and stabilized by the VFL process and then placed on the
24 existing industrial landfill.
25 Additionally, material from the north lagoon will
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be removed. This material will be removed to a depth of at
2 least the low groundwater table, and this material will a
3 be solidified and placed on the industrial landfill.
Also, material from the blowdown pit will be
5 removed. The first part of this process will be to e.'.cavate
6 all the material with contamination above 100 parts per
7 million of venyldine chloride, or VDC. This material will
8 be excavated and taken to an off-site incineration facility
9 for treatment.
10 After that's done, all the remaining sludges and
an additional two feet of soil underneath the sludge will be
12 removed, solidified &nd placed on the industrial landfill.
13 The other waste areas on the site will also be
14 excavated. These include all three Battery Separator
15 Lagoons, the Tsnt Car Area, and the Boiler Lagoon. These
16 areas will be excavated to a depth of five feet and placed
17 unsolidified on the landfill.
13 After all this excavation is complete, there will
19 be a comprehensive sampling of the excavated areas. The
20 pur post of this s^iT.pling will be to determine if we have
21 attained the established soil clean-up goals for those
22 spots. These soil clean-up goals were developed for
23 indicator compounds which if left in each disposal are^. a= a
24 residual, will not leaci to contamination of ground wate
25 It-vels that ex teed drinking water standards.
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If our sampling indicates that we have indeed
2 attained the soil clean-up goals for the waste areas, then
3 those areas will be properly graded and seeded. However, if
O'j.r sampling indicates that the clean-up goals, soil clean-
5 up goals have not been attained, then we will take the
6 following actions.
7 The first step will be to look at the sampling an
e analysis that was done and determine what is the best
g available technology to attain these soil clean-up goals.
• 10 We will make this decision based on the nature and percent
of contamination that we just found from that sampling,
12 along with the nine-point EPA evaluation criteria.
13 This decision process on deciding on the next
14 technology or remedial action to attain the soil clean-up
15 goals will be the same decision process as we're discussing
today for the future rod. That is, it will be a very
similar rod process.
16 To address . the industrial landfill, no
19 cor tamir.cmts . from the industrial landfill will be excavated.
20 The landfill will be closed with an impermeable cap designed
21 and constructed in accordance with Massachusetts hazardous
22 wante- regulations for hazardous landfills. This impermeable
23 cap will include a synthetic cover to prevent the
24 j infiltration of waters into the landfill. This cap — I'm
25 sofr/. The landfill will also have vents in it. These
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i vents will take contaminants from inside the landfill to the
2 surface, where they will be collected and treated.
3 Additionally, a ground water recovery and
4 monitoring system will be- installed around the landfill.
5 This system will be used to supplement the existing aquifer
6 restoration system in that area. And that system will be
7 installed before any remedial activities are conducted at
8 the landfil 1.
9 The Battery Separator Chip Pile will be closed as
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10 a solid waste landfill with an impervious cap in accordance
11 with the Massachusetts solid waste regulations. The aquifer
12 restoration system, airstrip and tower, will be upgraded by
13 installing additional treatment. It is anticipated that
14 this treatment will be carbon absorption.
15 Additionally, there will be a comprehensive ss^^B-
16 wide, ground wrter monitoring plan implemented to evaluate
17 the effectiveness of the selective remedy. This groundwater
18 monitoring p'ljj.n '-'ill be developed during the design of the
19 remedial action. Under this plan, groundwater monitoring
20 compliance wells will be installed, both upgradient and
21 downgradient of the disposal areas—again, to evaluate the
22 effectiveness of the source control actions that we have
23 taken.
24 So in summary, the future remedial steps that we
25 will be conducting are to address the source areas that
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exist on the site. That will be by the process I have .just
describe in implementing the rod.
The next step of the process will be, if the soil
c. lean-up goals have not been attained and we determine what
the best technology is to attain those, soil clean-up goals
and have a similar decision-making process to deci.de on that
remedy, that process would include input from the community.
And then the last step of the process will be to
determine if all the groundwater is being adequately
addressed by the existing aquifer restoration system. And
if not, additional groundwater actions will be taken.
Again, the decision on this last portion of the remedy will
have you all available for input and comment.
So in • cone 1usion, I would like to just stress that
again, this is a remedy to clean up the sources at the site.
And it's .->.:< t the groundwa'ter remedy. And also, we recognize
that there are many design issues to be determined during
the process. And the E°A is committed to understanding and
evaluating and taking into consideration your input during
t h c'. t design process. T h a n k r o u.
MR. HQHMAN: Thant you, Wayne. I'd like now to
call on W.R. Grace. They have a representative here who
wishes to make a statement for the record.
MR. WILKIE: My name is Russ Wilkie, and am a Vice
President with the Polyfibron Division of W.R. Grace ?•• Co.
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12
yCM.I for coming out this evening to comment on the
2 plans for the Acton site.
3 Slightly over ten years age-, Grace's Acton sit^
4 was founc? to be a major contributor to the contamination of
5 Assabet Aquifer, which forced the closing of the town wells.
6 Discovery of a contaminated water supply was a
7 difficult time for you, your neighbors, for the entire
8 community. It was also a difficult time for those of us at
9 W.R. Grace, many of who live or work in Acton. We would
'10 like to. take this opportunity to express our regret for the
11 hardship we have caused you and the community. The fact is,
12 we at Grace have made a. number of mistakes in dealing with
13 the town aquifer, and we realize that we cannot simply erase
14 those mistakes.. We must prove our commitment to protection
15 of the Town •;•' Acton.
16 We have taken full responsibility for the clean-up
17 of the Acton site and the pollution of the aquifer. We> have
18 put substantial resources into this clean-up effort,
19 utilizing the best technology available—even developing
20 some TIG"., technologies. The results show that the s^stetr is
21 worl' ing. The aquifer is being cleaned up. We will continue
22 to work at the cleanup in a responsible and professional
23 manner.
24 Grace believes that the site closure plan that ha.s
25 beer-; presented represents a. positive step forward. Vou. the
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town officials and private citizens, have contributed to
this plan. And while it may have not been easy for anyone,
we believe it i^ a good plan.
We hope that the implementation of this plan will
be a significant step toward improving the relationship
between Grace and the Town of Acton. Grace sincerely wants
to be more than Just physically located in Acton. We want
to be an asset, to the community. We hope to move forward to
a future characterised by an honest and open relationship .
between.the people of Grace and the people of Acton.
I would like to close by thanking the EPA, the
DEP, and the Town of Acton for their professional approach
and their cooperation. Thank you.
. MR. HDHMAN: Thank you. I do want to break the
order, ar-.d we will make an exception to any elected public
C1'.'T i c ic. 1 that shows, up during the evening. The first one
that has- come in is Nancy Tave^nier, who -is Chairman of the
Board of Selectmen of the Town of Acton. So I will c :< I 1 :-.-,
her- CM: a" elected of fi-cia I.-
MS. TAVERNIER: Than* you very much for that
courtesy. The Town of Acton had been ably represented over
the pa.it ten or 11 years., or as long as the history of tr.e
U'.R. Grace clean-up by special counsel Stephen Anderson, and
by our consultants, GZA. In fact, these two entities
represented the only continuity of experience in our -<-•.;. re-
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1 town and in fact, in terms of the EPA and the DEP, town
2 official;: and the Grace officials, all other key player^
3 have changed ir that time period. But we're -fortunate tSBFl
4 GIA ;---.d S-teve Anderson have been with MS throughout this
5 process.
6 They have been submitting comments to the EPA ever
7 since t he --f ore c losure plan was released. And they are
8 prepared tc submit final written comments by September 15th.
9 I Just want to defer tonight to our counsel,
10 Stephen Anderson, for any further comments that the town
11 wi 1 1 be mak ing.
12 MP. HDHMAN: Thank you. And now we will begin, ir,
13 all of our list, are there any public officials that I don't
14 know about "'
15 'Mo response)
16 MP. HOHMAN: Okay, Prudy Piechota.
17 MS. PIECHOTA: Gee, I'm kind of sorry I am the
18 first person to do this. ' E-'ut I happen to be from the city
19 of Nashua in New Hampshire. We have a W.P. Grace facility
20 m our front yard, as you have one in your back. yard. Our
21 facility is ongoing. I am a member of the LAPC in the City
22 of Nashua. I am here to 1isten--pardon?.
23 FROM THE FLOOR: What's the LAPC?
24 MS. PIECHOTA: LAPC is the--committee for
25 emergency preparedness in the community. I have been very
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., active in the environmental issues in the City of Nashua for j
2 over te-n years. I worked on Gillson Road. I worked on
evacuation plans for Gillson Road. Also, I am now in the
process of looking at W.R. Grace Nashuau for a cyanide
5 cont. £"•
22 ma, be want to te up front and ongoing, I have received m£-r,-; -
23 -from this facility in Nashua. I cannot speak for after.
And unfortunately, I would like to hear a lot rnors
25. comments from you folks because you have lived with thj.s f :
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i 11 years. I have lived with Grace Nashua for seven years
2 and have been- very active there. 5o please, do not be
3 afraid to contact me. My name is Prudy Piechota. My
4 address is '!'£ Musket Drive. Nashua, New Hampshi-r e. And my
5 ZIP Code 1= 01033. My telephone number is area code 603,
6 SSO-78£S. I am not a politician. I am not paid by industr,"
7 or anyone else. I am an environmentalist. I have started
8 the Greater Nashua Campaign Against Toxics. I am a founding
9 member. I <~.TI also a member of the Greater New Hampshire
"10 Campaign Against Toxics, and I also belong to the Nashua
11 Campaign Against Toxics, which represents this country and
12 eleven other co.untries .
13 5o your environment here is also our environment
14 in New Hampshire. We are very, very much concerned.
15 Please, feel free to cor.tact me and talk about it. And
16 here to observe, and ! would like those questions answered
17 in a written form, if t ou would l^e. I will submit- to you
13 a form. T h a n !• > -;- u v e •• >
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them to be defective? •
2 ' How much differential settlement is allowable for
3 visual inspection of the cap or a soil gas--is initiated"'
4 Wi 1 1 tf.ir>-e be ~ 2 e?.d--inspect ion scheduled annually? And
5 will there be a written report submitted to the Board of
6 Selectmen"1 Thank you.
7 . MR. HDHMAIM: Thank you. Charlotte Sa.goff.
8 MS. SAGOFF; I had hoped to speak a little bit
later than--after more questions were asked because I have a
rather lengthy statement to read. Mainly in response to the
answers from W.R. Grace to the August 14th meeting, as well
12 as some comments with regard to the preferred alternative.
13 I am going to try to summar ire, and I am going to make it
14 shorten than it really is in order to keep it in the time
15 limit.
16 !•";-.-•> of the responses by Grace to questions raised
17 in the- A'.! g <: -.: t 14th public information meeting and in their
'18 June? l'?S'? addendum to their 19ETE- Fht.se- 4 report indicate
19 that natural fciodegr adat ion occurs uith or --'ith-iut s
2o synthetic cover. We urge that you consider' soil remediation
on a larger scale, and with a changed, speedier schedule • :«r
22 the 1 agoons-- 1 andf i 1 1 . I nnoc •-.•. 1 at ion of the varieties of
23 organisms, bacteria, fungi and yei-st, pluu end addition •: f
24 nutrients li!e ox>'g&n and nitrates, would speed up the
25 natural processes.
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i The EPA should place- more stress on bioremediation
2 which car, be used or. L-O many different volatile organics,
3 lile- contaminant n at the:- Grace site. Also, rt' s cheaper _ r
4 W.R. Grace, sir. :t that's r; r:ia».;or concern.
5 We- are -.:oncerned that the—process is uncertain,
6 unproven and difficult to use with assurance on many
7 varieties of materials. I have seen VFL toxilonic material
8 which crumbles easily. That's that cement, lye, ash, lime--
9 anc! the contaminents which will all be mixed together in
10 order to make a solid, stable top to lay down on top of
11 what's in the landfill now before the--. And I have seen it
12 break down. It is possible that slabs of the so-called
13 stabilired material may work for a while in the small
14 set ting.
15 Ev.t in an area as la'ge and as irregular as an
16 over f our -;- c r ••:- land-fill, the result is likely to be breakup.
17 And t h. •. = , de £'.-'.'c t ion of the Mill £j s/Titfist 11 membrane
18 -'hie!-. G-'-.-:e propo-i-es '•:•-• use. I have thought a. ch un^ along
19 of the membrane, a t£v-mil merr.br a ne, which ij. very t h i c !• t c-
20 g--1 ovt-r an aim..:-st five-ac'e landfill, e~d wl ich will on
21 contact with broken edge^ of the VFL material, the--
22 material, n.ay very well be she-a red and torn and pun c t v. re-d
23 and ruptured.
24 EPA research indicates that organics can !e£cfc.
25 through the- VFL ' mater-r i a 1 . I have reari the EPA aquaduet
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1 ' annual research do cumer. t, the- 14th annual rehear ch
2 do c.ur.er:t =. I merit ioned thai- at the? hearing on August 14th.
Grace would be investing large amounts of money in an
uncerti-.i- p"oc&=s. After e very th ing is covered over, if the
5 method doesn't function as they hope it will,' more expense
6 wi 1 1 . b.e . ir,cur red to dig it all up and to do it all 'over
7 again. Cr more likely, it will be forgotten by Grace and
8 just leech the materials into the groundwater, into the
g aquifer underneath.
There is a journal called the Environmental
Report, which I am sure you all know of. Volume IB, number
12 40, pages 2079. of January 23, 1939 has a useful article or,
13 an EPA site in Chesawa, Delaware, called Poker's Landfill.
14 There are two landfills -there which have sludge c.ontaminents
15 comparable to the ones at the Grace Actor, site. I ref = - >•<:•.:.
T6 to case r-,,.i enter EPA V35S1£DC. Would you please read that
17 article and the remedies used there and advise us in you
18 r tL-;•!-,£ t ----- that w= c insider it with our consultants,
I.ope we will soon be able to hire.
20 1~- a= Grace says thtir drums ir the landfill are
21 now empty and the material in the tank truck is solidified,
22 that r.-ifc-(r r.s- tvi£-t those coritents have already leeched into e
23 ground, where they are si owl/ travelling through the soil
24 ^r.c/or .other substances are there in perched layers.
25 . U'i- a = l that ,•!•.• tap the flune« and extract, the
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VOC's before- they reach the aquifer and the groundwater.
These lagoon sludges and contaminated fluids, when cover.^.
up, uould otherwise be forgotten. Research and practiceTn
the biotechnology •: f soil organisms indicates that VOC's
•: :•'. I t be digested in the same way that bacteria in septic
tanfs digests and degrade septage. Even many of our
medicines, like perimycin, come fro>m soil organisms.
Grace, i.n it's September 1, 1SS9- letter of
response to the comments on August 14th, stated that
batter 15 -n average soil works to degrade and cleanse. They
should add to what is already there naturally. VFL methods
soliciif/ pollutants, possibly only temporarily. And this
would prevent soil organisms fro-m working.' The empty
lagoons will ha/s; pollutants in the sandy soil underneath.
Dc'r._-.t cover the.-. Add bioremediating bacteria, oxygen,
nit.-rts nutrients, f.nd let the vatose layer cleanse itself.
They should use supplemental treatment instead •: f
just ::-.-i-inz the lagoons in -itn end for get ti ng' about the.T,
u11h gras^v covers. ' Fits and lagoons should be degassed
firs1: be T.;.-•=• any other action is taken.
Areas I^ke the lagoons, where sand will be
excavated, will be d ras 11 cr-.l 1 y disturbed, requiring
restorative pli.M-r.ing. What are those? restorinc: plans thr-.t
>ou f.ave for those lagoons and pits that will be evacuated
and e:.Ct-vatecJ'"' Grace refers only to a vegetated cover of
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2 Now, the c-nly toxilanic VFL prototype that we know
3 of at the: Grace site exploded and failed. They got
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-.. r-cvl t .-- - t •£ , then continued to advise such stabilisation. j
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5 Ua have :- o evidence 'chat it's workable. We would like in.
6 your response that you give us information where it works or
7 has worked f.or 50 years. j
8 . There are so many contaminated pits and lagoons as
9 well as the nearly five-acre landfill, that it should be
•10 possible to do some control prototype tests of proper soil
remediation end soil stabilization for critiquing. Maybe a
12 ccmbi nal i-i n c f methods should be used, not just the one
13 des.cribed as the preferred alternative. You're putting: all
14 your cc .-it i-rrii r.ar.ts in •: ne ba.u1 Et. You're going to get so'ir.e
15 monste.-' r- out of that.
16 The ZPA should demand on-si te--cspabi 1 i ty for. all
17 -ths lagoons and pits as material is shifted. Then when we
13 writ wL.cn tr.e !£..:::> inn i-.r & e- a c.=-. vated - -wh i 1 e '/ou a^e waitinc
19 for thoiit. lagoons all t :• be excavated, eight o-* them or r-.ir-.e
20 c f thfc-'. with the tli'wdowr-. pit, t^.c? gr c ur.dwat er will shift,
21 will mov_ -fj..=£ver, and it will be disturbed.
22 An analysis i'f each excavated site should begin
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24 •.indEr-r.c:- th t^.ere now or at that point. Dor.' t wait ur.til all
25 the sites are e.-.cavated for VFLing the polluted material,
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1 which is the.-, to be placed on the landfill.
2 Grace speaks of disconnecting zones of perc
3 water during the six-month wait for the fill 'and the VFL
sl'.'de t :• L.'.L-side, wh/ not--into the area & combination of
5 tr.e--, ye as:-T., fungi, whatever biological forms are available
6 to adjurt the VQC's;. Feed them with oxygen and nitrate to
7 speed the digestive process.
8 • On page 20 of the June 8th addendum, when they di;
9 out five feet of contaminated soil from under the back of
10 the sepa -£-.t or, the boiler lagoon and the tank car area, and
n they load it on top of the VFL sludge and label this clean
12 fill--see attachment 2-2 in the Grace letter--this is
13 typical of the double talk we have gotten for years. That
14 stuff is not clean. They call it clean, saving that it's
15 j!-' = t go inc to be on top clean.
16 Similarly, page 20 of' the June .addendum, Graie IE
17 p= --.i t ti-i J: o une the NCL m ; ... i m .1 m contamination levels and .
18 =-.;.'! l3-vt_'l fecifivl UJ-r.l!,e' = tande •' -- . It's » very cocr_'
19 c-. crjnyrr,. Put the> arc- not =trinGfe.-.t enough for Acton. We
20 prefe-'- our one-part per billion standard for a single
21 volatile- organic chemical with no more than five partn per
22 billior, -fii f r-ny mcT'.e t.har. o"ie contaminent in our water.
23 We have paid e-.tra monev yearly for ten years to
24 pay for J:ht loss of our wells and the cleansing of our
25 wat =••;•. '3r-:ice:- should-atide by t.he- e.-; eel lent standards
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c : nsidere-d appropriate/ by Acton's citirenr,. Paje 1'j'of the
June addendum, let us I-now which on-site or off-site
iTior, i t or i nc wells are at or above NCL values. •
In atta cl.ed--l of the Grace response to the
diagram showing the covered landfill, the stabilised sludge
is drawn as a neat, solid block. It will not be a neat,
solid block. Two uneven masses will be dumped, one onto the
east landfill and one onto the west landfill. And then
there is going; to be another solidified mass to be dumped
onto the ground between the ground that used to be for
trucking.'
All three will subside unevenly and will shatter
eventually and break unevenly in different places because of
the weight of the overburden--a 11 the sand and soil and
iTietal gra_", etcetera. And tubing and venting.
We ha/£- b= = n given no analytic data w'-ich wculd
help -.• = tc '. nderstand how the VFL stabilizer; sludcs w_ll
wort. Wr cannot r-cr^pt C? r a c =• * c wcrd without su-pr-'t d •:• t a.
At least 20,000 cubic >a^di :-f sard will be used ^ : t:-'..ilr
t !• e dome ovE?r the SO-.T.il liner. We want tc- know where each
substance comes from that Grace will bring: in.
I-i the past, Grace has dumped in c i-nt a.T.ir.ent : f r •: -
Nashua. Wob urn and Cambridge, and possibl", otht-r places. -'11
n:ateri£-.l- brought tc the Acton site for r er.ediat ion we - c -1
monitored for content c-.nd place of that origin. ~r
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many type, of f 1 ,- ash from the incinerators, froir. cement
kilns, c:-:-1 bur-ne-rs, etietera. You do not want any Grace-
p.'odvced •* 1 . c-.i.-'-, used in the cover-up. We are tcld that^fll
the tr.a te- lal s being brought to the Grace proper t-, --the sand,
the fly ^c1-.. the lime and cer.er.t will be in trucks. We
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sist that Grace begin scheduling their train transport
aain
cf these materials instead of increasing the burden or
our roads and neighborhoods. Thank you very much,
MR. HOHMAN: Thank you.
C Applause''
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1 MR. HOHMAN: Did you want to identify the
2 organisation you represent?
3 MS. SAGOFF: Oh, yes. This is -- that --
4 you said, that the selected -- DEQE then -- I know -- I
5 now know it's the DEP thing, and EPA were the longest
6 groups in this situation.
7 ACES, Active Citizens for Environmental
8 Safety^ were, also, in on this from the very beginning
9 or since 19 -- about October, 1978. We've been
10 listening to, and analyzing, and questioning, and
11 critiquing stuff that we've been hearing.
12 So our organization is ACES. Thank you.
13 MR. HOHMAN: Bob Eisengrein?
14 MR. EISENGREIN: My name is Bob Eisengrein,
15 I'm a citizen of Acton and, also, a member of ACES.
16 I have reviewed the CDM/Grace phase 4
17 reports, plus the addendum, in detail; the
18 recommendations do meet one of the Federal law's
19 criteria for a solution "to immobilize toxic waste".
20 However, if EPA and Grace will hearken to
21 the citizens researched comments at the August 14, 1989
22 hearing, there still exists a real concern, and
23 .skepticism, that the recommended approach represents
24 permanent immobilization. The toxic are still left in
25 the earth, and are as potent as ever!
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1 Federal law does state, with reference to
2 toxic wastes "a permanent solution is preferred". From
3 my review of all the reports submitted to EPA,, there is
4 virtually no reference to the use of an alternative
5 solution, which "permanently reduces waste toxicity."
6 Why?
7 Are there such choices? Certainly. ACES
8 has published several reports and summaries of
9 applicable bioremediation techniques, and cases where
10 bioremediation has worked on Superfund sites like
11 Grace's Acton site.
12 Bioremediation is a straight-forward
13 process. It uses microbes already in the earth, which
14 regularly degrade toxic into harmless byproducts.
15 Biodegradation can be accelerated by the
16 addition of nutrients injected into toxic soil;
17 CDM/Grace admits this .in their reports, Appendix G!
18 Yet no such alternative solution was presented!
19 Bioremediation gets to the root cause of
20 citizens concerns; the impermanence of soil
21 stabilization. Carefully selected bioremediation
22 techniques can degrade the toxic into harmless
23 byproducts -- toxic are not left in the ground. ACES
24 has offered our resource material to EPA and CDM/Grace.
25 The material includes not only references to
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bioremediation work going back 10 to 10 years, BUT
correspondence with two leading companies whose only
business is bioremediation solutions to toxic problems!
The companies are:
Biotrol Co., Chaska, Minnesota, and
DuPont Biosystems, in Aston, Pennsylvania.
My recommendations, and plea, to EPA and
G r a c e i s:
1. Delay the Record of Decision for & to 9 to
12 months, until the alternate solution of
bioremediation is reviewed and applied to this
Superfund site.
We have waited 10 years to get where we are
now; another year could provided the "truly permanent
solution".
2. If this recommendation is "politically
impractical", write a Record of Decision which insists
•on bioremediation techniques being reviewed in parallel
with the final detail design process.
Remember, either approach, stabilization or
bioremediation, requires the excavation of the sludge;
this work consumes about 50% of the preferred solution
costs.
Study of bioremediation alternatives could
well involve two economic gains; the short term one of
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1 costing less than soil stabilization, and a long term
2 gain during the operation and maintenance phase since
3 toxicity would decrease over time and require less
4 maintenance monitoring.
5 Grace could proceed with the excavation
6 design plans. The fundamental difference thereafter
7 wc-'.ild be:
8 -bic-remediation would take the excavated
9 sludge, treat it, and produce harmless byproducts
10 -stabilizing the toxic would only
11 "immobilize" them, leave them in the ground with the
12 constant citizens concerns already expressed!
13 The above recommendations are not an
14 emotional response to issues at stake, but a carefully
15 researched effort. If neither of the above
16 recommendations is accepted, one truly wonders if
17 citizen input to the EPA process is meaningful.
18 Thank you.
19 MR. HOHMAN: Thank you.
20 Andrea Miller?
21 MS. MILLER: I'm Andrea Miller, an Acton
22 resident, and I have a question and a comment.
23 I would like to know how many breaks and
24 repairs at the Landfill Synthetic Cap would be
25 permitted before the entire Gap would require
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1 replacement?
2 <: Pause. >
3 • MS. MILLER: I think that EPA should
4 establish a performance criteria that assumes that for
5 every break discovered there are at least two that are
6 not detected.
7 EPA should require complete replacement of
8 the cover, after every three or four repairs.
9 Thank you.
'10 MR. HOHMAN: Mi cky Wi 1 1 iams?
11 MS. WILLIAMS: I'm Micky Williams. I'm an
12 Acton resident.
13 I have two comments. The first one is --
14 is fairly specific. I would like the EPA to require —
15 rates, to utilize the best available patrol technology
16 to eliminate offense odors from the Stripping Tower.
17 There have been decades of odor complaints -- mine
18 included -- that have never been adequately addressed
19 or the sources eliminated by WR Grace.
20 My second comment has to do with my concern
21 about the safe competent nature of the clean-up
22 solution. It's short term and unproven. There are no
23 contingency plans for failure of the CAP, no plans for
24 money to pay for replacement thirty or forty years down
25 the road, if it fails -- maybe I should say when it
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1 fails.
2 We have dealt with this problem for more
3 than ten years, and I would like to have a solution
4 that is permanently eliminating the problem, even if it
5 is more costly and longer in time.
6 Thank you.
7 MR. HOHMAN: Thank you.
8 Jonathan Hudson?
9 MR. HUTSON: In my capacity as a
iO Journalist, in Nashua, New Hampshire, I've chronicled
11 the on-going problems brought out in my community by
12 the numerous chemical releases from .the WR Grace
13 facility there.
14 In the past two years, the Grace facility,
15 in Nashua, has had more than several releases,
16 according to Paul Kehoe, Acting Administrator, EPA
17 Region One. This is prompted EPA Region One to perform
18 in April of 1989, a multi-agency safety audit of the
19 Grace facility, in Nashua.
20 This is remarkable for the fact that this
21 is only the second safety audit ever performed in the
22 entire history of EPA Region One. The first safety
23 audit having been performed at the International Paper
24 Company Mill, in Maine.
25 In other words, the WR Grace facility, in
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1 Nashua, has compiled such an outstanding record as a
2 chronic pol.luter that even the United States
3 Environmental Protection Agency could no longer ignore
4 it.
5 As you know, the citizens of New Hampshire,
6 are presently concerned about the recent discovery of a
7 cyanide contamination site along the western bank of
8 the Merrimack River, directly below the Nashua facility
9 of WR Grace. Grace officials had acknowledged that
10 their Nashua facility is the probably cause of the
11 cyanide contamination.
12 What the citizens of Acton need to know is
13 that when Grace officials first reported this
14 contamination site to EPA Region One, they described
15 the blue cyanide stain as being "about twenty-five feet
16 in length".
17 My newspaper, J.he^Br^oad.caster, informed the
18 EDA, that the blue cyanide stain, in fact, extends for
19 more than a quarter of a mile in length.
20 My experience has convinced me that the
21 presence of citizens of oversee the work of WR Grace
22 and the EPA is imperative. Further, we have set up a
23 precedent Sending Citizens Committee, to oversee the
24 work of the EPA at WR Grace. This is setting a
25 precedent across the nation, as this is -- such a
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1 committee has never before been set up for a --
2 Resource Conservation and Recovery Act investigation.
3 Further, New Hampshire Congressman, Chuck
4 Douglas, will be holding an oversight hearing this
5 fall, looking into how the EPA Region One has conducted
6 its investigation of the WR Grace facility, in Nashua.
7 On behalf of the people of Nashua, I would
8 now like to reiterate two questions raised by
9 Mrs. Pichota previously.
10 1- Has the WR Grace facility, in Nashua, New
11 Hampshire, contributed to the contamination of the
12 landfill, in Acton, Massachusetts, and if so, the
13 citizens would request a list of which specific
14 contaminants Nashua might have contributed.
15 '2. Does WR Grace have a contingen-cy plan to
16 transport any hazardous materials to Nashua for
17 incineration at its Nashua facility?
18 I say this in view of the fact that I don't
19. believe that the Acton facility of WR Grace presently
20 has an incinerator on its site, whereas I know that the
21 Nashua, New Hampshire facility of Grace does have an
22 incinerator on its site.
23 If it be the case that WR Grace intends to
24 burn any of its hazardous materials from Acton in
25 Nashua, New Hampshire, then the people of Nashua do
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strongly object.
MR. HOHMAN: Wanda Mandile? ;
MS. MANDILE: My name is Wanda Mandile.
I'm a member of ACES and a eighteen year resident of
Acton.
After -- following all these people who
really know what they are talking about technically,
basically, I think Charlotte Sagoff did -- her comments
did address concerns recovering the new landfill
proposed, recovering well, and some new monitoring
well, at the end of the lagoons.
I.'m just going to leave you with some
questions regarding that specific subject.
We're interested in the scheduling relative
to the initiation of excavation activities, the
sampling period required to avoid well installation
effects, the number of samples required to establish a .
wide base line, and finally, will wells near sources
'""•'}
with metal contaminatio. ^and phthalate problems be
analyzed for these contaminates?
Thank you.
MR. HOHMAN: Thank you. '
Edgar Geithner?
MR. GEITHNER: I'm Edgar Geithner. I'm an
Acton resident, and my comments concerns money.
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1 We have A dump here that's going to be
2 tc-xic for years to come, and -from the last time you
3 presented to us, I got the impression that nobody
4 really knew how long.
5 The sources of money, to make sure that the
6 solution works -- whether it is preferred alternative
7 or something else -- are unsure. I guess it is based
8 on taxes on penalties assessed to WR Grace.
9 I don't know whether the preferred
10 alternative will work, and I got the impression that
11 nobody else really does either. We may find out after
12 thirty, or forty years, or more that it didn't .work.
13 So no matter what technology you decide you
14 to use, I'd like to recommend that a Trust Fund be set
15 up, funded entirely by WR Grace, the amounts to be
16 equal to the cost of the clean-up or something close to
17 it.
18 I propose that this be an interest
19 generated account, with the Town of Acton, as Trustee,
20 and it would be used only for remedial maintenance of
21 the site, as well frequent safety audits.
22 When it is determined that the site is no
23 longer toxic and there is no further danger to the
24 town's people, then I think the funds would be returned
25 to WR Grace.
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1 Thank you.
2 MR. HOHMAN: Stephen Anderson?
3 MR. ANDERSON: My name is Stephen Anderson.
4 I' m an attorney from the firm of.Anderson and Criger,
5 formerly of Palmer and Dodge, the town council.
6 For a number of years, I and Bill Berzarno
7 Nave represented the town, as legal and technical
8 consultants, in this matter.
9 I wanted to comment briefly. We will be
]0 submitting detailed, technical written comments by the
11 due date, but I wanted to suggest a number of concerns
12 this evening that maybe reinforced by some of the
13 public, comments or, in turn, that it may reenforce
14 things that people have already said.
15 We have met with the Board of .Selectmen.
16 We have explained to them our review of the plan and
17 our recommendations, and we are here, at the behest of
18 the Board, not to advocate for the EPA Plan or the
19 Grace Plan, and at the same time not to recommend the
20 design of a different plan.
21 Rather, as we have done in the past, we are
22 here to respond to the proposal, as it is made, and to
23 suggest areas of concern and areas of improvement,
24 because even though the EPA Plan does incorporate some
25 comments that the Town has already made and even though
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1 it does improve upon Grace's original Phase 4 Proposal,
2 there are still significant areas of concern and areas
3 for improvement. I would like to suggest several of
4 those this evening.
5 One has to do with air monitoring -- on
6 site and perimeter air monitoring. GCA recommends that
7 both on site and perimeter air monitoring be required,
8 both during the sludge excavation process and during
9 solidification of the sludge and placement of the
ip sludge.
11 If performance criteria during this
12 monitoring are exceeded, then steps would have to be
13 taken to correct the situation, but the citizens of
14 Acton should not be exposed to unnecessary air
15 emissions during the course of this proced.ure.
16 As far as sludge excavation goes, GCA
17 recommends that procedures be implemented to minimize
18 the liberation for fluid.
19 ' Currently, the proposal is to use a drag
20 line to excavate from the lagoons. That is probably
21 the least favorite alternative way of excavating from
22 those lagoons.
23 Instead, GCA recommends that it backhoe --
24 similar to the types that are used for excavation of
25 slurry walls -- be used in connection with excavating
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1 these sludge from the lagoons.
2 GCA recommends that consideration be given
3 to solidifying more of the contaminated soils and
4 sediments from the other waste sites, rather than
5 simply placing them beneath the cap, as additional
6 fill.
7 To verify the predictions that are made by
8 various models -- including the K model -- GCA suggests
•9 using such tools as laboratory column bleaching tests,
10 to verify particular contaminates concentration.
11 GCA, also, suggests consideration to the
12 feasibility of placing the Battery Separator Chips in
13 the Battery Separator Lagoons. This would consolidate
14 those waste piles and increase the efficiency for the
15 CAP for those particular wastes.
16 As far as the land fill is concerned, GCA
17 has concerns about the cap integrity and the potential
18 differential supplement. They suggest that one or a
19 combination of the following be used to address these
20 concerns.
21 Deep dynamic intensification of the
22 landfill prior to the sludge cap placement. Use of a
23 very heavy grade woven geo-textile between the soil
24 fill and the sand bedding layer, and/or employment of a
25 composite designed synthetic membrane to increase the
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1 tolerance of the cap differential settlement.
2 There are several other technical concerns
3 that GCA has raised about cap design, but I would leave
4 those for comments that we will submit in writing.
5 As far as cap monitoring goes, GCA
6 recommends that some form of cap monitoring, other than
7 -- platforms, be implemented shortly after
8 construction, in order to pick up non-sediment induced
9 breaches in the lining -- such as poor workmanship or
.10 inadequate precautions taken, during construction.
11 An example of a technique would be -- based
12 soil gas sampling for linear strips of geo synthetic
13 drainage.
14 the Aquifer Restoration System is still
15 i operational, and it is one component of this, but there
16 are concerns that we have, both now while it is
17 operating and in the future, if it is allowed to be
18 turned off.
19 One of those concerns is whether the
20 captured area of the system includes all of the
21 contaminated areas at the site.
22 The Town has submitted detail comments on
23 the most recent Aquifer Restoration System Report.
24 Those comments suggest that there are a number of areas
25 of contaminates that are beyond the influence of the
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1 Aquifer Restoration System and that are being allowed
2 to migrate in various directions from the site. Those
3 directions include towards the -- wells, and, -also,
4 toward the Assebet wells. These areas should be
5 addressed and those contaminates should not simply be
6 allowed to migrate.
7 On possible way of addressing this is to
8 install an additional Aquifer Restoration System well,
9 in areas of concern. Such as, north and east.
10 There have been concerns in the past about
11 the ability of the Aquifer Restoration Tower to operate
12 successfully and operate consistently.
13 Along the lines of the Verify theory, we
14 would like to have the ability to make unannounced
15 i nspec tion's of the Grace site -- both the EPA, DEP, and
15 Town -- at least twice a quarter to inspect the various
17 operating facilities out there -- the Aquifer
18 Restoration Tower, plus the various wells, and so on --
19 to confirm that they are, in fact, operational.
20 As far as clean-up criteria go, the plan
21 that you have proposed seems to have implicitly adopt
22 maximum contaminate levels, as the clean-up goal, and
23 these would presumably somehow be implemented as.
24 criteria ceasing the Aquifer Restoration Systems
25 operation.
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Selectmen do not agree that these criteria
should be the ones to trigger ceasing the use of the
aquifer restoration system. Rather, they believe that
the strictest available criteria should be applied.
Those would include consideration -- for
example — of maximum contaminate level goals where
those are relevant and appropriate, and other risk
based target levels where there are no such goals.
In addition, these criteria need to be
consistently applied over the entire area that has been
influenced by the contamination, such that if you poked
a hole anywhere in the aquifer, you would meet and
exceed the standards.
As far as monitoring goes, GCA recommends
that a more complete curtain of monitoring wells be
implemented around the landfill. That is where a lot
of these wastes are going to be left for an extended
period of time or indefinite period of time.
These wells should be multi-level wells,
and they should include areas such as between LM-2 and
L-4, to close the 250 foot distance between these
monitoring wells, northwest of LM-2, to monitor the
western end of the landfill, and southeast of LM-B to
monitor the eastern end of the landfill.
GCA recommends that the monitoring of these
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wells not be limited to a 20 year time frame, as is
suggested, but rather that no time limit on this
monitoring should be involved. They should be
monitored indefinitely into the future, and they should
be monitored not only for the kinds of perimeters that
have been monitored in the past, but also for
additional perimeters. Such as, drinking water,
metals, acid based, neutrals, semi-volatile.
There are several institutional concerns
that the Town has. Some of which have already been
mentioned by the public this evening, but I wanted to
reenforce those comments.
One of those has to do with a trust or
ground water monitoring, and operation, and maintenance
of this facility over time..
There are a number of different
alternatives that can assure the finances are
available, in the event of failure or problems with the
system in the future. I would like to suggest some of
those.
One would be Trust Fund. Another would be
an agreement with Grace that in the event the property
is sold, in the future, that a percentage of the sale
proceeds be placed in escrow, in order to insure that
this system will be operational and insure that the --
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1 the cap and related facilities can be maintained and
2 replaced, if necessary in the -future.
3 The second concern, also along the lines of
4 potential future sale of the property -- for instance,
5 subdivision and building of homes or other buildings on
6 the property in the future -- is that people be aware
7 of the history of this property and have an easy way to
8 get at the history of this property.
9 The Town suggests that one of the best ways
\Q to do that is to place a Notice in the Registry of
11 Deeds, along with a plan that shows, in surveyed
12 detail, where the waste locations exist today, and
13 where the waste locations exi-st after the
14 implementation of this remedy. That plan can then be
15 easily consulted in the future, in the event of a Title
16 Search or someone is purchasing a lot, and they will
17 then I,now whether or not they are buying a lot that at
18 one time had these primary lagoons on the property.
19 If possible -- if legally allowable, the
20 Town would like to see land use restriction placed on
21 portions of the property that include the landfill, in
22 particular where waste will remain in the future, and
23 potentially other areas of the site if residual
24 contaminates remain there over time.
25 I won't take anymore time this evening, but
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1 we do have additional comments that we will be
2 submitting on this.
3 MR. HOHMAN: Steve Grones.
4 MR. HRCNE£: That's Hrones. Steve Hrones,
5 from Concord.
6 Everyone talks as though this is just an
7 Acton problem, but it is very much a Concord problem,
8 as a result of the Aquifer Restoration System clean-up
9 efforts by Grace up to the present time.
»
10 As most of you know now — hopefully from
11 my other talks on other occasions -- the systems great
12 for Acton.. I don't think anyone is drinking toxic
13 water, because what has happened is the wells take the
14 water and pipe it to this air stripping tower that
15 Peter is referring to.
16 The toxic -- the contaminates are stripped
17 out of the water, and into the air. Well, there has
18 been a technology for a long time. Carbon absorbs the
19 system which is in most systems, and which grabs the
20 contaminates, as they come out of the tower.
21 The problem is right down to the last five
22 years, since March of '85, they have been coming out
23 without any protective system, and coming across the
24 Assabet, to my house in Concord.
25 What I'm asking the Board or the EPA is t:
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1 not approve any plan that doesn't deal with the odor
2 byproduct, as well as the contaminates. I think that's
3 reasonable, apart from any regulation.
4 It makes simple sense that you don't take
5 Acton problems and send it over to Concord, or you
6 don't take the water problem and make it an air
7 pollution problem.
8 So I believe you certainly have the
9 authority to make absolutely clear that no plan will be
10 approved unless Grace deals with the odor problem.
11 One must distinguish between your
12 suggestion in the plan here -- the proposed plan that
13 they put in a carbon absorption system and the odor
14 problem. They are not necessarily the same thing.
15 The absorption system will tak'e care of the
16 five major contaminates, and that's very good. It
17 should have been in a long time ago, because there are
18 health concerns that are involved, apart from the odor
19 problem, which is also a nuisance situation to the
20 people in Acton, I understand, as well as Concord.
21 So as I understand it, you are requiring
22 definitely a carbon absorption system, and that's good,
23 and I ask that you put a time frame on that, because
24 unlike the rest of the plan, there is no reason why
25 that shouldn't go on immediately.
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1 I understand that the other part of the
2 project will take some further- time and must be
3 coordinated, but this carbon system should go on
4 immediately.
5 The plan should also make clear that they
6 also must deal with the odor problem, apart from the
7 carbon absorption system, if that doesn't deal with the
8 problem itself.
9 Once again, you do have the regulation --
10 the Massachusetts Air Duality Regulation that defines
11 air pollution as creating a nuisance. So you have that
12 regulation to force Grace to deal with the odor.
13 Once again, even apart from the regulation,
14 it seems to me that no plan should be approved that has
15 a byproduct an odor that creates additional new
16 problems for neighbors, such as Concord and other
17 citizens of Acton, in the form of air pollution.
ig <.'Appl ause . .')
19 MR. HOHMAN: Florence Geithner? I'm sorry.
20 Is it Bonnie Florence--
21 MS. GEITHNER: Yes. Florence is my legal
22 name, but I just don't answer to it.
23 (Laughter. >
24 MS. GEITHNER: My -- my question or
25 statement is four parts, and it concerns the holes that
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1 are going to be left around after everything is calmer
2 into one part of that plastic sheet. It's going to
3 break.
4 WR Grace's proposals for characteriring
5 soils left in the excavated empty holes are grossly
6 inadequate with respect to the three dimensional
7 analysis of remaining contamination, in comparison with
8 proposed soil clean-up values.
9 Multi-level sampling -- including actual
10 soils samples -- is mandatory from the bottom of the
11 lagoon excavation down to the water table.
12 Further, with increasing acid rainfall,
13 what insurance is there that the metals and phthlates
14 will not begin to migrate down into the ground water?
15 WR Grace appears to assume that these
16 compounds are stuck permanently in that unsaturated
17 soil Just below their source lagoons. Are they?
18 Is future monitoring 'scheduled for those
19 conte.fTii nates, in those empty lagoons, that Grace plans
20 to fill with -- with soil and grass over? I am
21 concerned about tall those residues and -- and the type
22 of testing that is going to be done in those areas.
23 Thank: you.
24 (Pause. )
25 MR. HOHMAN: Jack Ormsbee?
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MR. ORMSBEE: My name is Jack Ormsbee. I'm
a resident of Acton. I'm a member of ACES and a former
Acton Selectman.
During my term on the Board of Selectman,
in the Town, I had a number of negotiations and
problems with WR Grace.
There was an emergency alarm that the Town
required to be installed that couldn't be heard from
five feet away.
There was as leak that started out as being
less than a hundred gallons, and months later it had
exceeded more than thousands of gallons.
There was an entire tank car, which was
discovered buried in an area that was suppose to
contain building materials.
During that term, my faith in the
credibility of WR Grace sank so low that I was quoted
in the press as saying that I wouldn't trust them as
far as I could throw one of their batteries. I still
say that, and rr.y distance on battery tossing is getting
less and less.
( L a u g h t e r . )
MR. ORMSBEE: However, I accepted Mr.
Wilkes assurances that WR Grace is ready to -- like
most of the citizens of Acton, I st.and ready to be
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1 shown, but with deeds not with words. Also, I have a
2 few specific comments on the plan.
3 EPA's nine evaluation criteria on page ten,
4 and included costs, No. 7, and community acceptance,
5 No. '? -- it does not appear to me that these factors
6 can be effectively weighed against each other, when
7 community acceptability is not evaluated in their
8 selection of a preferred alternative, whereas costs are
9 considered from the upset in evaluating which
10 alternative is preferred.
11 In conjunction with that comment, it is
12 also not clear to me -- I don't believe to ACES either
13 -- what weight is given to benefits versus costs? What
14 are the benefits considered?
15 Secondly, -- that even after the clean-up
16 plan is carried out, tests will be required to
17 determine whether the contaminates are present.
18 Some of these things infer to the
19 possibility of finding contaminates not previously
20 identified.
21 Shouldn't one of the objectives of the
22 Clean-Up Plan shown on page one -- perhaps the first
23 one -- be determining the nature and extent of
24 contamination, and shouldn't this step be taken before
25 the entire Clean-Up, in order to be sure that it
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1 accurately addresses the nature and extent of all the
2 contaminates, including those that have not yet been
3 identified'"
4 In this respect, I support whole-heartedly
5 the idea presented by Bob Eisengrein, of ACES, that
6 back-up opinion to determine whether there cannot be
7 another method that can really define the pr -. blem
8 before the Clean-Up Plan is in tact.
9 Thank you.
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1 MR. HOHMAN: Ed Richter.
2 MR. RICHTER: My name as Edward Richter.
I ' m a thirty some odd resident of Acton, member of the
School Committee and Board of Health at various times,
not now.
6 • I'm also an engineer and an editing of The
7 Engineer_ing_Journaj., and one of the things that I asked
8 at the last meeting in August was what kind of
9 technology was to be used as sensors and in particular
at that time I was inquiring about the emissions from
11 the instrument tower.
12 I was told that none -- no particular
techniques had been looked at, and I was a little bit
14 aghast at that, and I .would suggest that there are a
lot of times when you're going to have to monitor the
air emissions and water emissions for contaminants to
the water.
I would suggest that you early in the
program look into what kind of sensors are available
for what kind of contaminants you have, identify them,
21 identify their sensitivities and arrange for some sort
22 of unified communication of all their outputs to one
23 central computer where you can -- where you can record
24 your data continuously.
25 i have a paper in my -- my bag here that
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was contributed to our journal from India where they
monitored all kinds of emissions in the Hooghly River.
Originally, the wanted to call it Hooghly
water monitoring or something like that, and I told
them take out the Hooghly, and I think the third world
countries are very intimate.
They have massive populations, and they
have massive -- massive pollution problems, and they're
looking into this, and they get together with the
universities.
This, I think, was the University of
Calcutta, and they -- they selected techniques that can
be used, and they used radio sensors from -- in the
river back to the central place where they recorded all
this data, and they -- they really had on-line
monitoring at all times.
I think this is the kind of thing we should
do. I think -- when I was on the Board of Health, I
was appalled that most of the time we were monitoring
things, we took a sample and waited four or five days
until it grew into something.
You don't have to do that with chemical
pollutants. Maybe with biological pollutants you do,
but evc?n there I think: there are better -- better
approaches that we should investigate.
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1 Now, I think Grace's is a strong technical
2 company. They know about computers. They know about
3 monitors and sensors, I think, and they should be able
4 to provide a lot of input on that.
5 EPA also should provide a lot of input on
6 that, and if you want any -- or anything like that, I'd
7 be glad to help you.
8 Thank you.
9 (Appl ause. !>
10 MR. HOHMAN: George Emmons.
11 MR. EMMONS: My name is George Emmons, and
12 I've been a resident of Acton for .11 years and am
currently on the Board of Health. I'm not speaking for
14 them tonight though.
I have a couple of questions and a couple
of comments, suggestions to reinforce those that have
17 already been made.
18 One question is why shouldn't the chip pile
19 be blended with the fill from the other areas and put
20 ,;,n the landfill and spread there as a fill layer, and
21 the result would be that this waste pile would be under
22 much better control and in an area that's not
23 hydrologica 1 ly connected to the -- wells.
24 Another question is what's the effective
25 life time before significant decomposition of the BFL
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1 stabilized contaminants occurs.
2 How do the decompose? Do.they decompose
3 gradually or precipitously after an indefinite time?
4 My comments. I do think that an escrow
account should be established to be used as needed to
fund remediation if and when decomposition of the BFL
stabilized contaminants occurs.
This should be done regardless of the
present land's stated life time because life time
1 estimates are hard to make, especially if they are
11 long.
12 So a long term solution may turn out to be
needed more quickly than is now predicted because of
14 the difficulty making the prediction, and it may be
needed some time much -- in the future, and1 some money
16 wj. 1 1 be there.
Also, read the rate of decomposition. As I
said, it may not be uniform. It may occur
precipitously after a long indefinite period and then
20 repollute the groundwater in the Assabet River unless
21 further remediation is undertaken at that time, and the
22 funds will then be available for that remediation.
23 Finally, let me make a comment that's based
24 on my experiences with the Board of Health. I know
25 firsthand that in some cases of repairs or additions to
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1 house here an Acton, that we require the owner of that
2 house to file a letter with the Register of Deeds
3 stating what has been done because itfs significantly
4 different from a house that a person might be buying
with respect to --
Now, I suggest that the comment made that
7 Grace be recorded -- refers to -- and planning and the
8 details where all the pollutants are on that site so
9 that it's known long in the future to any buyer is a
TO very good suggestion.
11 It's one consistent with what we on the
12 Board of Health require of the citizens of Acton, and I
don't think that that's an unfair thing to ask of the
14 Grace Corporation who are also citizens here in Acton.
Thank you.
< Appl a use. '>
17 MR. HOHMAN: Paula Bushkoff.
:'- '• MS. BUSHKOFF: My name is Paula Bushkoff.
I'm a citizen in Acton. I've a series of — questions.
20 if flushing of the primary -- is needed
21 because soil tests show contamination above SCD levels,
22 will the flushing begin during the 1990 construction
23 season, or will it be postponed?
24 who decides this? What are the criteria?
25 What happens if two lagoons need flushing? Describe
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1 how. samples from -- ways and meadows will be
2 obtained -- excavation. What is the time frame for
analysis?
Will W. R. Grace seek on-site GT analysis
for PLA's during soil sampling? If not, why not?
6 MR. HOHMAN: Thank you. Margaret Korde.
7 MS. KORDE: My name is Margaret Korde, and
I have some comments really just to reinforce and
reiterate what I've heard tonight.
10. I think it's clear that what you're
11 proposing, what Grace is proposing, doesn't seem to .be
12 an acceptable -- it's definitely not a permanent
13 solution.
14 It looks to me like we are going to need
funds available to be sure that we can monitor the site
forever and that there are funds available to be able
17 : to continually see such -- other types of remedial
a c t i o n.
19 j i would just reiterate that I think 'that
20 Grace has said that they want to prove that they intend
21 to act in good faith.
22 They want to be an asset to the community.
23 I think it's time for Grace to come forward and offer
24 an amount of money be set aside --
25 Thank you.
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1 CApplause?. :>
2 MR. HOHMAN: Valerie Nelson.
3 MS. NELSON: My name is Valerie Nelson.
4 I'm a citizen of Action for 23 years and a member of
5 ACES.
6 I'd like- to make a few brief comments and
7 give those present some food for thought on some of the
8 computer simulations that the EPA has in.its
possession.
These are computer simulations of possible
11 flow tracks from the landfill. They are used by W. R.
12 Grace, according to a letter of August 31st from Mr. J.
13 Armor to the EPA, to show that, "The contaminants
14 cannot impart the drinking water of the present Assabet
Wells Nos. 1 and 2 or the future Assabet 3 which is at
16 the location of the W. R. Grace No. 3 well.
17 "This would be the case even if the
landfill was left without a final cover or cap as shown
on the attached computer simulation, Figure 1."
20 w. R. Grace states that, "With Assabet No.
21 1 and No. 2 wells and the future Assabet No. 3
22 operating at normal capacity, no contamination from the
23 landfill will be drawn into the wells even if the
24 landfill were left uncovered or there was a failure of
25 the cover. -
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1 Several technically competent people who've
2 reviewed these computer simulations claim that Figure 1
3 shows no such thing and that, in -fact, it does.not
4 represent reasonably expected future contours or flow
5 directions.
It's their contention that a reasonable
worst case simulation would instead do any or all of
the following: Would pump W. R. Grace No. 3 water to
the Acton Water District System and not to the sinking
!° pond as shown on 301; would shut off the reach-outs --
11 ponds since W. R. Grace has never assumed
12 responsibility for maintaining this hydraulic barrier;
13 would shut off the aquifer for the restoration system;
14 would impose 180 day drought conditions; and would als
assume no cover on the landfill.
Food for thought.
17 < Appl ause. .''
MR. HOHMAN: Joseph Conuby.
19 MR. CONUBY: My name is Joe Conuby, and I'm
a resident of Acton for 20 years. My concern is with,
21 first of all, the intent to stabilize the waste rather
22 than to properly treat it and, secondly, with the
23 stabilization process.
24 A comparable process exists, and there's
considerable data on it. Statelex (.'phonetic)
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Corporation has operated a hazardous waste facility --
for a number of years.
They use a lime and cement to stabilize the
waste. They will not accept any type of waste
containing organic contaminants.
The process is effective, approved by the
EPA for inorganic materials. Further, after they treat
the material and it is classified by the EPA, in other
words not --, they dispose of the material in a plain
pit which is subsequently covered with a barrier.
This is in an area where the surrounding
community is served by a municipal water system. I
think that you should look very carefully at the
effectiveness and, indeed, the intent to stabilize the
waste leaving a problem in the future.
''Applause. .')
MR. HOHMAN: Tony Mandile.
MR. MANDILE: My name is Tony Mandile.
I've been a resident of Acton for 18 years and a member
of ACES since 1378.
Sand and gravel was one of our earliest
loams. Sand and gravel was one of the earliest
concerns in that area, Grace area, in question.
We will -- Grace has -- to supply common
fill be located, how big it will be, will it create --
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eyesore from any offset point and what are -- the
gravel pit, but a -- view. Last, are there any --
MR. HOHMAN: Christine MacDonald. •
MS. MacDONALD: My name is Christine
MacDonald, and I've been a resident of South Acton for
two and a half months.
FROM THE FLOOR: I can't hear you.
MS. MacDONALD: My name is Christine
MacDonald, and I've been a resident of South Acton for
two and a half months.
Since I've lived in South Acton, my family
has noticed two or three times a week a strong chemical
.
odor coming into our house.
It took us six weeks to understand what
that odor was, and we believe that it comes from the
stripping -- at the Grace plant.
My comments should be addressed primarily
to my concerns about emission. In a proposed plan, it
states that new towers will be -- will be equipped with
a carbon absorption technology to maintain the air
emissions, but not all the old towers will have that
technology added.
I believe that all of the towers should
have the carbon absorption because we certainly are
noticing the odors now, and as I understand, other
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1 peopsle in the area have noticed it for many years.
2 My other concerns to do with air emissions
3 come from reading the proposed plan. I believe that
4 when the lagoons are excavated and when they're mixed
5 to -- process, when all of that material is stirred up,
6 I believe that the -- compounds, but we can't literally
7 --the air.
I don't know if there's any way to contain
those materials during that process. I hope that there
is, and I'd like to see the air tested during that
11 process
12 My third concern about air emissions has to
13 do with the covering over the landfill. I'm concerned
14 on reading the proposal, as I understand it, the way
you're treating the air emissions, they'll not be
determined until after the landfill is covered and the
17 air is tested.
I think that's too late. When I read that,
I get the impression that nobody knows what emissions
20 will be coming out of the landfill and that's why
21 nobody knows what the best available technology is. I
22 find that unacceptable.
23 I have one other concern that's not related
24 to air emissions, and that has to do with the landfill
25 -- the contaminated material that is present in the
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1 landfill that will not be --
2 It -seems to me that- when other materials
3 added to that landfill to fill it up to the surface of
4 the ground and then heavier materials are added to the
5 top, that there will be much displacement of the
6 materials and the landfill.
7 Granted, there's a little more contaminants
8 coming out of that landfill towards the Assabet River
and that -- today will not contaminate the water
supply.
11 However, the materials are added on top of
12 it. I don't understand why we can be so certain that
13 there won't be shifting of materials and that the
14 nature of that fill might change and the water supply
would be contaminated.
16 I don't know of any way that if that were
^
17 to happen it would be possible to go t-^_^,k into the
18 landfill and remove those materials.
19 Thank you.
20 (Applause. .''
21 MR. HOHMAN: Pamela Kelly.
22 MS. KELLY: In the interest of time, I'm
23 going to -- little card because.you're not going to
24 answer tonight anyway.
25 I'm going to just say a word to reiterate
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1 what other people have said. I want to admit to you
2 here tonight that I'm a terrible housekeeper, but if I
3 to.'k a rug five acres large and swept the dirt'under it
4 and -- it to stay there for 30 years, I wouldn't just
be c=. terrible housekeeper, especially if something is
carcinogenic -- to find out just how carcinogenic it
has been and all of a sudden air contamination somehow
may yet bear fruit in the sense of possible suits of
companies that don't deal responsibly -- that don't
deal responsibly with contaminants that they know or —
11 that they know --
12 Now, I think -- going to deal with this
13 because citizens of Acton who may die of cancer because
14 of lack of action.
There's no apology that's acceptable for
that.
17 C Appl aiise. !>
MR. HOHMAN: You would like to have this
q ij e s t i o n put i n t o t h e record'"'
20 MS. KELLY: Yes.
21 Question: Grace proposes that material
22 with more than 100 ppm VOA be incinerated and estimates
23 that about 20 cubic yards are likely to exceed this
24 limit.
25 What instruments and procedures are used to
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1 reassure this during excavation? Would there be any
2 problem if the estimates turned out to be ten times too
3 low? When will this hot stuff actually be, (A>,
excavated .from blowdown pit, before or after the cooler
stu'ff around it, and, <'EO, removed from site?
6 MR. HOHMAN: Lorraine Carter.
7 MS. CARTER: My name's Lorraine Carter, and
8 I'm an Acton, resident and also a member of .ACES. I
.just have a few specific questions regarding the
>0 landfill.
11 • What are the allowable levels of --
12 chloride emission in the landfill? Is the Grace
13 landfill likely to exceed these limits? What will be
14 t h e c o n t r o 1 s u r v i v a 1 ?'
Thank you.
16 MR. HOHMAN: Ken Appel.
17 MR. APPEL: My name is Ken Appel, an Acton
resident for 14 years. I just have a couple of
questions that are directed at the water entrance
sinking pond.
21 Since its start-up in 1384, the aquifer
22 recovery system has been dumping treated waste water
into the sinking pond.
24 This waste water is very rich in iron, and
it creates an orange slim iron mask that accumulates in
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1 a cascade ditch leading to the pond.
2 In its original plans, W. R. Grace proposed
3 to trap this slim in a ditch above the pond. More
4 questions, basically, relating to that.
5 Is the trap/operating? Second, has the
6 trap ever been cleaned? Is there a schedule to clean
7 it periodically? If not, an inefficient or inoperable
trap allows particulars to enter the pond that will
probably never leave.
The last question, once the Aquifer
11 Restoration System is shut off and the level of the
sinking pond subsides, what plans does W. R. Grace have
13 to stabilize exposed shores to prevent erosion of
14 sediment?
Thank you.
MR. HOHMAN: Richard Kedugan.
17 MR. KEDUGAN: Mr. Hohman, my name is
Richard Kedugan.
MR. HOHMAN: I'm not having much luck with
20 names tonight.
21 (.Laughter.)
22 MR.' KEDUGAN: That's understandable. I've
23 been associated with the actual Grace site since early
24 1978, and I think: I'm probably the most senior
25 technical people still --
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FROM THE FLOOR: Louder.
MR. KEDUGAN: I have a simple question
concerning -- that draws a parallel between underground
tank testing that when practiced -- for all underground
storage tanks for hazardous materials and the proposed
area.
I think that it would be a reasonable
request for Grace to have to perform an integrity test
on the cap every two or three or four years such as we
require of anyone who stores hazardous materials
underground.
The problem I see with that right at this
moment is that the plans proposed by W. R. Grace in
their Phase IV Addendum for venting and a testing
procedure that involves use of the banks are apparently
contradicted by Page 15 of the EPA proposed plan such
that internal vents from the landfill materials that
exist at the cite now are not allowed to vent below the
cap.
They are -- must be designed, according to
Page 15 of the EPA proposed plan, to go right up
through the cap to the surface.
Simply, I'd ask how the heel: are we going
to test the integrity of the cap using a vent system
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1 which I thought was -- had some attractive features
2 and, lastly, why don't we institute a plan that uses
the vents to pump in a tracer -- perhaps with just
helium which is used to test tanks and find any leaks
on a regular bi-annual or three year schedule?
6 In other words, treat this as an
7 underground storage tank in some respects.
Thank you very much.
9 • (Applause.)
1° MR. HDHMAN: Nancy Cadwgan.
11 MS. CADWGAN: In the interest of time, I
12 will not ask my questions that have been aptly phrased
by many members of ACES.
14 I would just like to say that ACES has
monitored the problems with Grace and has been a watch
dog since 1975, and we were the first group to identify
17 the problem
It hint- the-- questions that they have
raised here deserve some very close scrutiny by the EPA
with preferred alternative solution —
21 (Applause. !i
22 MR. HOHMAN: Carol Mackey.
(No response.)
24 MR. HOHMAN: Carol Mackey.
(No response..''
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1 MR. HOHMAN: Of Acton.
2 ('o response.
3 MR. HOHMAN: Nancy Fox.
4 fNo response.)
5 MR. HOHMAN: Nort Salz.
6 MR. SALZ: I'm Nort Salz, a resident of
Acton. I don't know that I can add. anything new. I
really just want to underscore what a number of people
have raised so far.
10 In particular, I would like some kind of
11 assurance that, in fact, the many technical points and
other concerns that people have raised are, in fact,
going to be addressed.
14 It seems to me pretty clear that the
'5 proposed alternative is not going to work and that some
other approach, probably something that includes some
kind of a biodegradable approach, is something that
will have to be looked at.
I really hope that Grace will, in fact,
20 collaborate with ACES and some of the people who've
21 done a lot of careful research on some of these
22 difficult questions.
23 MR. HOHMAN: Thank you. Pom Resor.
24 M£. RESOR: Parr, Resor, former Acton
25 selectman from '81 until '97, so I've been involved in
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1 this --
2 FROM THE FLOOR: Louder.
3 MS. RESOR: And I'm also a member of ACES.
4 Throughout the past ten years and continuing, --
specific performance standard, well supply procedures,
monitoring specific points to be assessed for two
years, -- to the site -- maintenance plans.
We demand that this most important clean-up
phase is a solution and not just a cover up. I
honestly knew exactly what standards and criteria were
11 used to -- design the standards.
It provides a solution. During an earlier
13 meeting, the response to many of our questions was that
14 question will be answered when we get to the -- design
15 phase.
The greater concern is that EPA is=
selecting a preferred alternative with HO many
unanswered questions.
If it's in a design phase, first the
20 questions cannot be answered or raises more questions.
21 Can you alter your financing --
22 What public review will be provided during
23 the design phase? Will we be given an opportunity to
24 see that -- the design data to answer our questions?
25 (Applause.)
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1 MR. HOHMAN: Gil. Woo ley.
2 MR. WOOLEY: My name is Gil Woo ley. I'm
testifying on behalf of the New England Chapter of the
-- Club.
We were — actually, one of our groups
which is no longer active, I guess, was actually the
7 first to go into the site and take photographs of
8 the dump and to see that lovely pink froth of the
lagoons.
1P Since then the ACES have done a wonderful
11 Job. I have to pay tribute to them. It's the best --
most popular, civic group I have ever experienced.
I don't have to go over what other people
14 have said, but I've been finally getting the things in
from CVA fcr ten years now.
It seems as though there was a great amount
17 of studying being done and something good should come
out of it.
When your final election dote -- that old
20 saying came to me, the mountain has been in labor, was
21 brought forth announced.
22 Ten years ago, I understand something like
23 $2 million and you've come to the right recommendation
which the first year -- engineering student came up
25 with it as a cost project fee --
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1 I don't want the -- I associate most of the
2 remarks made by previous speal ers except those
3 regarding the cap.
4 I -- we are not interested in the cap.
This -- you've got a cultivation there. If the cap is
successful in containing the material; then it will be
there forever.
If it isn't successful, it will -- you
can't have it both ways, so the only solution -- if
this site could be cleaned up, then you will get all
11 the materials in one place, you'll go in there expedite
12 and it's not the -- it's hot the question of -- it's
not some difficult site in the middle of the city.
There's lots of room on the side. In ten
years you could have cleaned it up with not much more
than you've spent, I'm sure.
17 This is really-- collected by the --
another environmental or gani - i\ i ion -- and this is
typical of what the EPA's recommending, cover-up, not
20 clean-up.
21 Sometimes there's a justification for it,
22 but in this case they could have cleaned it up --
23 there's no such thing as a permanent cap. No one will
24 ever believe that.
25 You'll have to stop trees growing on it
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1 forever, and if -- it will be there forever. You can't
2 say you're containing it and yet -- because nothing --
3 as far as I know, there is no biological -- of material
4 when it consolidates.
It in some way -- eventually it will be
great. What you're doing is just making the sort of .
time bomb for the future.
One .thing that hasn't been mentioned, if
it's term and people can be -- there that Grace has
10 moved this highly acid soil from the -- site onto the
11 site, this changes the whole chemistry of it.
12 The solids that have been there already are
13 not -- to method, but the material on the old -- site
14 is so acid they have to move it or they could pour
concrete wit hi the red —
It would have leaked the calcium carbon and
17 __ cement. That's our -- if that starts to seep down
into the metal, then you've got the whole hill of
problems that haven't even been addressed.
20 The only solution to this thing is to clean
21 up the site. Now, how are we going to address this'1 I
22 think all of you will have to think o.f the political --
23 and state -- it's not clear that the state doesn't
24 still maintain ^ome jurisdiction over the -- over the
25 site.
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The ERA'S -- supposed to be in conformity
with ?tate rules. It's not clear. I've talked to
attorneys about this, and "it never was quite clear, but
if u-e can get enough politicians to state an interest'
in it, I think we can force Grace to do this.
They can well afford to do it. They've
caused enough environmental problems in New England to
at least effect some restitution to the city for the
things they've done, and they can well afford to do it.
They're one of the top 50 corporatio-ns in
the world, I believe, so it's not like somebody who the
Board Of Selectmen suddenly .find they've got a toxic
waste site which is unfortunate sometimes.
Grace created the problem, and Grace can
afford to f i .•••. it, and Grace must be made to fix it.
(.'Applause. ')
MF. HOHMAN: Susan Fingerman.
MS. FJNGERMAN: My name is Susan Fingerman,
and I've been a resident of Acton for 19 years. I
don't have a technical comment or question, but I do
want to say in 1971 we were a neighbor of Grace's on
PaH er St reet.
I was one of the several people calling the
Board of Health at lea=t once a week complaining about
the odor that was --
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1 At that time we were told eventually that
2 it was -- which is not at all t'o be of any concern and
that Grace was willing to go through several mapping
procedures arid do some bending at night, and we moved
away.
We're still in Acton, b'.it we moved away
7 from that area about three years after that still
8 having the odor problems, and I'm hoping that this is
not another mask and that 18 years from now we are not
going to be? here again trying to find some solution --
11 (. Appl ause. ')
12 MR. HOHMAN: Could we have just a
13 clarification, if you wouldn't mind?
14 MR. BDVNTDN: You mentioned you lived on
Parter Street and'you mcved to somewhere else'7'
16 MS. FINGERMAN: Right.
17 MR. BOYNTON: And where is that?
18 MS. FINGERMAN: West Acton.
19 MR. BOYNTON: And you still have odor
2w" problem there'"'
21 MS. FINGERMAN: No, no, but I understand
22 someone that's been there two and a half months has an
23 odor problem.
24 MR. BOYNTON: All right. I misunderstood
25 what you said. Thanl you.
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1 MS. FINGERMAN: I'm sorry.
2 MR. HOHMAN: Thank you. Again, Carol
3 Mocley.
4 (No response.)
5 MR. HOHMAN: Nancy Fox.
<:NO response. .')
7 MR. HOHMAN: 1= there anyone who hasn't
8 been called on who wishes to make a statement'? Yes?
9 MS. KELLY: Can I make a request?
1° MR. HOHMAN: Yes. Why don't you come up to
11 the microphone, please, so we can put it on the record
12 and identify yourself, please?.
13 . MS. KELLY: I'd like to see that this
14 material is sent to the -- so that it can be published
in the paper and not have any more sent undercover to a
few people who -- that -- my name is Pam Kelly. I'm
17 from South Actor,.
MR. HOHMAN: Which material are you talking
19 a &*..: t?
20 MS. KELLY: The answers to these question
21 and some of'this data.
22 MR. HOHMAN: Okay. Let me thank all of
23
24 MS. FOUNTAIN: I have a question.
25 MR. HOHMAN: Do you have another question
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MS. FOUNTAIN: My name is Marian Fountain,
and I'm an Acton resident for two years. I also live
on Parker Street, and one thing that nobody mentioned
was the truck traffic.
We have lots of huge trucks going by all
the time, and my question is what is in these trucks?
What happens if somebody gets in a car accident and
crashes into one of these trucks in front of our house?
There are -- all over the place. What if
that -- what are the health hazards of that? I want to
thank ACES for the wonderful job they've done.
Unfortunately, I'm not -- basis, but I wish
I was. I'd like to also remind everybody that what
we're really talking about is the future of the
children in this town.
I'm a parent, and I'm also the school
psychologist at the junior high school, and I have a
.
very deejj concern atout the children and what effects
t h i u all m i g h t h a ve o n them.
(. Appl ause. !>
MR. HOHMAN: Thank you. I'll bet i. cup of
coffee you're a member of ACES before you get out of
t h e b u i 1 d i n g t o n i g h t.
(.' L a M g h t e r . )
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1 MR. HOHMAN: Anyone else'"1 Down in back.
2 MS.-BAILEY: Yeah. -I'm Martha Bailey,
3 President of the National -- Campaign, and I was
4 wondering if you people have heard of landfill mines
•phonetic ) .
I'm hearing a lot about landfills here'
tonight, and as far as I can find out and as far as I
see or hear, it's barrels that are empty, landfill that
9 are buried, and --
1P Why don't we take them out, and why don't
11 we take what soil is in that landfill before we start
12 putting something else in?
13 So -- out of here.
MR. HOHMAN: Thank you. Anyone else?
15 MS. MORGAN:. My name is Andrea Morgan, and
I'm a resident -- former resident of Acton for IS
years.
18 I have a few questions -- first of all, the
lagoons. What happens if water s'eeps into the lagoons
and, if so, would it be contaminated, and, if so, what
would be dont- to the water?
22 Second of all, is there anything wrong with
t',e lar-.dfill, and, if not, why not, and what would
24 happen if our -- toxic: sneaked through the landfill
underneath —
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1 MR. HOHMAN: Other comments?
2 MR. WILSON: My name is Matthew Wilson, and
3 I am the- Director of the Me. = sa chuset ts Campaign to
4 Clean Up Hazardous Waste.
5 We're a statewide group that works with
6 about 50 community groups across the state dealing with
7 tov.ic waste setting in our communities.
I wasn't going to say anything tonight, but
I just want to make a comment that I think the comments
by the citizens here and the show up of how concerned
11 citizens here are is very important.
12 -- allowed the other groups across the
13 state, and our experience with other groups is that by
14 ' taking in comments and taking into account the comments
that peopl'e have said here tonight, I think, will make.
the clean up much more effective and happen a lot
quicker.
We've seen that in other site;: across the
19 state where the EPA and DEP has really taken into
account these comments.
21 That's when clean-up has happened quicker
22 and more effectively so I Just hope that in --
23 important comments that people said here tonight are
24 all incorporated in because you can see from the crowd
25 here if it's not done right the first time, we're going
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1 after the comment period closes, we will be evaluating
2 all of the? comments and the questions that -we have
3 heard tonight and also that we receive in writing.
4 W-i- will be mar..ing s decision on the clean-
5 up remedy for this particular -site. As part of that
6 process, we- will be preparing what we call a responsive
7 summary which will be EPA's answers to all of the
8 comments that we have received during the comment
9 period and will at that point attempt to answer any of
10 the questions, also, that have been raised here and
11 have not yet been answered.
12 : Are there any other, comments before I close
13 the hearing-
14 MS. 5AGOFF: Excuse me. Can you explain
15 about the ROD"' I thin.', many . peop 1 e --
16 MR. HOHMAN: I'm sorr>. I have 3 tendency
17 -- I'm a bureaucrat. RDD stands for record of
18 d e c i £ i •:• n.
19 It's the clean-up remedy. Probably EFA
20 could simply say it's the c \ e»;- •- v p remedy, but we Save
21 . to call it a ROD or record of decision.
22 • That will r-pc-11 out what the remedy that w*
23 arc- going to imp] E/merit at this site will be.
24 CM.ay. Again, thank you all for coming. I
25 will be leaving, but I thinf: a few of the EPA staff
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will stay around for a little while.
If you Nave any more/ questions or comments,
you want to speal, to them and get a little more
information to help you prepare your comments within
th~ comment period.
We thank you very much. The hearing is
adjourned.
(Whereupon, at 9:30 p.m., September 12,
198'?, the above matter was concluded.)
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CERTIFICATE OF REPORTER AND TRANSCRIBER
This is to certify that the attached proceeding'
3 before: UNITED STATES ENVIRONMENTAL PROTECTION 'AGENCY
4
in the Matter of:
•5
W.R. GRACE SUPERFUND SITE
PROPOSED PLAN
' 7
8
9
Place: Acton, Massachusetts
11 Date: September 12, 1S89
12
were held as herein appears, and that this is the true,
accurate and complete transcript prepared from the notes
14
and/or recordings taken of the above entitled proceeding.
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S. French 9-12-89
Reporter Date
E. Scannell, D. Brideau, S. Hayes 9-14-89
Transcribers Date
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APPENDIX C - ADMINISTRATIVE RECORD INDEX
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APPENDIX D - STATE CONCURRENCE LETTER
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Office of $iwi#c
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Mr. Keough
Sept. 29, 1989
Page 2
The Department has reviewed the ARAR's identified for the
Commonwealth and believes the proposed remedy will meet these.
This will continue to be evaluated as remedial design progresses
and during implementation and operation. In addition, we will
continue to identify ARAR's during remedial alternative
evaluation of subsequent operable units at the W.R. Grace site.
The Department looks forward to working with EPA in
designing and implementing the preferred alternative for source
control and in developing additional remedial measures for
groundwater remediation. If you have any questions or require
additional information please contact Jay Naparstek at 292-5697
or Michael LeBlanc at 792-7653.
Very truly you
Daniel sT Greenbaum
Commissioner
Department of Environmental
Protection
cc: Edmond Benoit, CRO
Anne Bingham, OGC
Steve Richmond, OGC
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