Superfund Record of Decision Material Technology Laboratory Site US Army Soils and Groundwater OU. Watertown Massachusetts


                                    EPA/ROD/R01-96/124
                                    1996
EPA Superfund
     Record of Decision:
     MATERIALS TECHNOLOGY LABORATORY
     (USARMY)
     EPA ID: MA0213820939
     OU01
     WATERTOWN, MA
     09/26/1996

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                   FINAL RECORD OF DECISION
              SOILS AND GROUNDWATER OPERABLE UNIT
             ARMY MATERIALS TECHNOLOGY LABORATORY
                   WATERTOWN, MASSACHUSETTS

                 Contract No. DAAA15-90-D-0009

                         September 1996

                          Prepared by:

                       Roy F. Weston, Inc.
                          Weston Way
              West Chester, Pennsylvania 19380-1499

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                           TABIiE OF CONTENTS
Section
Title
                                                                                Page
    I     DECLARATION FOR THE RECORD OF DECISION  	  1
   II     SITE NAME, LOCATION, AND DESCRIPTION 	  9
   III    SITE HISTORY AND ENFORCEMENT ACTIVITIES  	 15
          A   Land Use and Response History  	 15
          B   Enforcement History 	 16
   IV     COMMUNITY PARTICIPATION 	 17
    V     SCOPE AND ROLE OF RESPONSE ACTION  	 18
   VI     SUMMARY OF SITE CHARACTERISTICS  	 19
          A   Soil Investigation 	 19
          B   Groundwater Investigation 	 19
          C   Storm Sewer Investigation 	 20
          D   Sanitary Sewer Investigation 	 20
   VII    SUMMARY OF SITE RISKS 	 24
          A   Human Health Risks from Site Soils  	 25
          B   Ecological Risks from Site Soils 	 27
   VIII   DEVELOPMENT AND SCREENING OF ALTERNATIVES  	 40
          A   Statutory Reguirements/Remedial Action Objectives  	 40
          B   Technology and Alternative Development and Screening  	 40
    IX    DESCRIPTION OF ALTERNATIVES 	 43
     X    SUMMARY OF THE COMPARATIVE ANALYSIS OF
          ALTERNATIVES 	 46
          A   Summary of Evaluation Criteria 	 46
          B   Discussion of Alternatives 	 47
    XI   THE SELECTED REMEDY 	 56
          A   Soil Cleanup Levels 	 56
          B   Description of Components of Selected Remedy  	 58
    XII   STATUTORY DETERMINATIONS 	 59
          A   The Selected Remedy Is Protective of Human Health
              and the Environment 	 59
          B   The Selected Remedy Attains ARARs 	 59
          C   The Selected Remedy Is Cost Effective  	 60
          D   The Selected Remedy Utilizes Permanent Solutions and Alternative
              Treatment or Resource Recovery Technologies to the Maximum Extent
              Practicable 	 60
          E   The Selected Remedy Does Not Satisfy the Preference for Treatment
              That Permanently and Significantly Reduces the Toxicity, Mobility,
              or Volume of the Hazardous Substances as a Principal Element  	 61
   XIII   DOCUMENTATION OF SIGNIFICANT CHANGES 	 62
    XIV   STATE ROLE 	 64

APPENDIX A-ADMINISTRATIVE RECORD INDEX

APPENDIX B-MASSACHUSETTS DEPARTMENT OF ENVIRONMENTAL
            PROTECTION DECLARATION OF CONCURRENCE

APPENDIX C-PUBLIC COMMENTS AND RESPONSIVENESS SUMMARY
         C.l-Comment Responsiveness Summary
         C.2-Written Public Comment Letters  (May 13,
                    1996)
         C.3-Transcript of Proposed Plan Formal Hearing  (May 13, 1996)
         C.4-Supplemental Documentation On Change In Selected Remedy
APPENDIX D—SUMMARY OF ARARS FOR SELECTED REMEDY

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                                  LIST OF FIGURES

Figure No.                              Title                            Page

    1      Location of MTL                                                10
    2      Site Plan with Proposed Reuse Zones                            11
    3      Groundwater Contours,  Water Table Wells                        13
    4      Commercial and Residential Reuse Estimation of Areas  To        21
           Be Remediated

                              LIST OF TABLES
                                                    Resident
                                                    and 3  Resident
                                                    Resident
Table No.                           Title
   1       Summary of Soil Contaminants of Concern
   2       Summary of Chemical Cancer Risks — Zone I
   3       Summary of Chemical Cancer Risks — Zone 2
   4       Summary of Chemical Cancer Risks — Zone 4
   5       Summary of Chemical Cancer Risks—Worker Populations
   6       Summary of Chemical Cancer Risks—Park Visitors
   7       Summary of Hazard Indices—Zone 1 Resident
   8       Summary of Hazard Indices—Zone 2 and 3 Resident
   9       Summary of Hazard Indices—Zone 4 Resident
  10       Summary of Hazard Indices—Worker Populations
  11       Alternatives for Remediation of Soil
  12       Comparison of Soil Alternatives
  13       MTL Site Soil Cleanup Goals
Page
  26
  28
  29
  30
  31
  32
  33
  34
  35
  36
  42
  48
  57

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                               ACRONYM LIST
AEC        Army Environmental Center
ARARS      Applicable or Relevant and Appropriate Requirements
bgs        below ground surface
BRAG       Base Realignment and Closure
CERCLA     Comprehensive Environmental Response, Compensation, and Liability Act
EC50       effective concentration for 50% of the test organisms
EPA        U.S. Environmental Protection Agency
FFA        Federal Facilities Agreement
FS         Feasibility Study
GSA        General Services Administration
IRP        Installation Restoration Program
LC50       lethal concentration for 50% of the test organisms
MADEP      Massachusetts Department of Environmental Protection
MCP        Massachusetts Contingency Plan
mg/kg      milligram per kilogram
MTL        Materials Technology Laboratory
NCP        National Contingency Plan
NPL        National Priorities List
NRC        Nuclear Regulatory Commission
O&M        operation and maintenance
PAH        polynuclear aromatic hydrocarbon
PCB        polychlorinated biphenyl
PCE        tetrachloroethylene
POL        petroleum, oil, and lubricants
ppb        parts per billion
ppm        parts per million
RA         risk assessment
RAB        Restoration Advisory Board
RCRA       Resource Conservation and Recovery Act
RfD        reference dose
RI         Remedial Investigation
RI/FS      Remedial Investigation/Feasibility Study
SVOC       semivolatile organic compound
TBC        To Be Considered
TCA        1,1,1-trichloroethane
TCE        trichloroethylene
TCLP       Toxicity Characteristic Leaching Procedure
UCL        upper confidence limit
UST        underground storage tank
VOC        volatile organic compound

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DECLARATION FOR THE
RECORD OF DECISION

I. DECLARATION FOR THE RECORD OF DECISION

SITE NAME AND LOCATION

Soils and Groundwater
Army Materials Technology Laboratory
Watertown, Massachusetts

STATEMENT OF PURPOSE AND BASIS

This decision document presents the U.S. Army's selected remedial action for soils and groundwater at the
Army Materials Technology Laboratory (MTL), Watertown, Massachusetts. It was developed in accordance
with the Comprehensive Environmental Response, Compensation, and Liability Act of 1980 CERCLA as amended,
42 USC 9601 et seg. and the National Oil and Hazardous Substances Pollution Contingency Plan (NCP) , 40
CFR Part 300, to the extent practicable. The MTL Base Realignment Closure Environmental Coordinator; the
Chief of Staff at Army Materiel Command; and the Director of the Office of Site Remediation and
Restoration. U.S. Environmental Protection Agency (EPA) Region I have been delegated the authority to
approve this Record of Decision.

This decision is based on the Administrative Record that has been developed in accordance with Section
113(k) of CERCLA The Administrative Record is available for public review at the MTL Base Realignment and
Closure (BRAG) Office, Building 313, 395 Arsenal Street, Watertown, Massachusetts, and at the Main Branch
of the Watertown Public Library, Watertown, Massachusetts. The Administrative Record Index identifies
each of the items considered during the selection of the remedial action. This index is included in
Appendix A.

ASSESSMENT OF THE SITE

Actual or potential releases of hazardous substances from soil areas, if not addressed by implementing
the response action selected in this Record of Decision, may present an imminent and substantial
endangerment to the public health, welfare, or the environment.

DESCRIPTION OF THE SELECTED REMEDY

This remedial action addresses long-term residential and commercial exposure to contaminated soil. It
consists of excavating the contaminated soil and transporting the soil for off-site disposal and/or
reuse. Excavations are to be backfilled with clean soil. Once contaminated soil is removed, the bottom
and sidewalls of the excavation areas will be sampled and analyzed to ensure that site cleanup goals are
met. The remedy eliminates the source of the contamination and reduces the potential risk to residents
and workers at MTL. The remedy is consistent with the overall remedial strategy for MTL. This remedy
was presented as the contingency remedy in the Proposed Plan.

STATE CONCURRENCE

The Commonwealth of Massachusetts has concurred with the selected remedy. Appendix B of this Record of
Decision contains a copy of the Declaration of Concurrence.

DECLARATION

The selected remedy is consistent with CERCLA and to the extent practicable the NCP, is protective of
human health and the environment, complies with federal and state reguirements that are legally
applicable or relevant and appropriate to the remedial action, and is cost effective The remedy uses a
permanent solution for soil contamination. This remedy does not satisfy the statutory preference for
treatment as a principal element. This remedy will not result in hazardous substances, above cleanup
goals, remaining at MTL.

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The foregoing represents the selection of a remedial action by the U.S.  Department of the Army and the
U.S. Environmental Protection Agency, with the concurrence of the Commonwealth of Massachusetts
Department of Environmental Protection.



The foregoing represents the selection of a remedial action by the U.S.  Department of the Army and the
U.S. Environmental Protection Agency, with the concurrence of the Commonwealth of Massachusetts
Department of Environmental Protection.



The foregoing represents the selection of a remedial action by the U.S.  Department of the Army and the
U.S. Environmental Protection Agency, with the concurrence of the Commonwealth of Massachusetts
Department of Environmental Protection.

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II. SITE NAME, LOCATION, AND DESCRIPTION

Army Materials Technology Laboratory Site
Watertown, Massachusetts

The MTL property is located on 48 acres of land in Watertown, Massachusetts, on the north bank of the
Charles River, approximately 5 miles west of downtown Boston (see Figure 1). The installation is bounded
on the north by Arsenal Street, on the south by the Charles River, on the east by Talcott Avenue, and on
the west by the Veterans of Foreign Wars, USA, Burnham Manning Post No. 105, and private property (see
Figure 2). Figure 2 also shows the proposed reuse zones-Zones 1 through 3 represent developed areas of
the site, and Zone 4 and River Park represent undeveloped areas. MTL formerly contained 15 buildings and
15 associated structures. Included in the U.S. Army-owned Superfund Site are 11 acres of land south of
the enclosed portion of the installation and abutting the Charles River. This land consists of a public
park and a yacht club south of North Beacon Street. The Commonwealth of Massachusetts has been granted
an easement to this property.

The overburden deposits of the MTL site generally consist of (in ascending order) basal glacial till
directly overlying bedrock, silt clay with some fine sand and gravel, interlayered outwash deposits of
sand and gravel with some fine materials, and fill near the surface. In general, depth to groundwater is
within 5 to 10 ft of the ground surface along the southeastern boundary of the facility adjacent to the
Charles River. Depth to groundwater reaches a maximum of approximately 30 ft below ground surface (bgs)
along the eastern boundary of the site, where the ground surface reaches its maximum elevation and
coarse-grained deposits allow rapid soil drainage. Depth to groundwater in the central portion of the
facility is on the order of 15 to 20 ft bgs for shallow wells and 20 to 25 ft bgs for deep (A-series)
wells. Groundwater flow in both the deep and shallow overburden is south-southeast toward the Charles
River (see Figure 3). The site groundwater meets the Commonwealth of Massachusetts definition of a
nondrinking water aguifer (GW-3); therefore, there is no risk of exposure to human receptors. With the
exception of a small part of the River Park, the site is not located within the Charles River 100-year
floodplain and there are no wetlands on-site. A more complete description of the site is presented in
Sections 1 and 3 of the Remedial Investigation (RI) report (WESTON, 1994) .

Because of the complexity of this site, the site has been divided into three distinct operable units,
which are being handled separately. The first operable unit is for the outdoor areas of the site,
specifically soil and groundwater. This Record of Decision addresses this operable unit. A separate
CERCLA Record of Decision was signed in June 1996 to expedite the cleanup of a small area of soil
contamination adjacent to Building 131. This expedited cleanup was implemented to facilitate future
reuse. Contamination as a result of releases of petroleum, oil, and lubricants (POL) is not considered
part of the evaluation of this operable unit because remedial actions under CERCLA do not extend to POL.
Actions reguired to address POL are being conducted under the jurisdiction of the Massachusetts
Department of Environmental Protection (MADEP) . The second operable unit is for the remediation of site
buildings, which is being performed under state cleanup authority. A Massachusetts Contingency Plan
(MCP) Phase III Remedial Action Plan for the site buildings was submitted to MADEP in January 1996. The
third operable unit involves Charles River surface water and sediments. Investigation of the Charles
River is being implemented by the Army under CERCLA with EPA as the lead agency. Any future activities
for the Charles River operable unit will not impact site reuse.

III. SITE HISTORY AND ENFORCEMENT ACTIVITIES

A. Land Use and Response History

The Watertown Arsenal facility has been in operation since 1816. It was established for the purposes of
storage, repair, cleaning, and issue of small arms and ordnance supplies. Throughout the 1800s and until
World War II, the installation's mission was continually expanded to include weapons development and
production, and materials research experimentation and development. At the height of its activity (just
after World War II), the site encompassed 131 acres with 53 buildings and structures and employed 10,000
people. In 1960, the Army's first nuclear research reactor was constructed, and it was used in research
activities until its deactivation in 1970. Depleted uranium machining, milling, forging, and casting also
were conducted on-site. Decommissioning of the reactor in accordance with the Nuclear Regulatory
Commission (NRC) standards has been completed.

An operational phase out of the arsenal was begun in 1967. At that time, approximately 55 acres of land
were sold to the Town of Watertown, and 28.5 acres were transferred to the General Services

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Administration (GSA). At that time, the 48-acre MTL site was created from the remaining arsenal land.
The parcel sold to Watertown currently contains a shopping mall, condominiums, and a public park and
playground. Land transferred to GSA has undergone various improvements, including paving in some
portions.

Previous investigations that pertain to environmental conditions at MTL were completed between September
1968 and December 1987. In 1987, the Army Environmental Center (AEC) initiated additional environmental
investigations under the Army's Installation Restoration Program (IRP). A Preliminary Assessment/Site
Inspection completed in 1988 was performed as the first step of this program. In December 1988, MTL was
included on a list of U.S. Department of Defense installations recommended for closure; this list was
subseguently approved by Congress. In March 1989, AEC was assigned responsibility for centrally managing
the BRAG Environmental Restoration Program.

Although unrelated to the Superfund process, several cleanup activities have occurred at the MTL site.
In 1991, six on-site underground storage tanks (USTs) were removed. Also in 1991 during the RI, a fuel
oil leak was discovered at Building 227. A leaking oil line was repaired and contaminated soil was
excavated to a 14-ft depth next to the building. Excavation ceased when it was determined that building
structural damage would occur under continued excavation. The excavation was backfilled after approval
by MADEP. Residual contamination exists, and continued cleanup efforts are under the jurisdiction of
MADEP under the MCP. Because Section 101(14) of CERCLA contains an exclusion for petroleum, the cleanup
of petroleum-contaminated soils at MTL is being conducted under MADEP jurisdiction and is not addressed
in this Record of Decision.

The Army also has completed decommissioning of the nuclear reactor, and low-level radioactive waste has
been removed. In 1994, sitewide radiological decontamination was completed to meet cleanup standards set
by NRC, MADEP, and the Massachusetts Department of Public Health. Asbestos removal also has occurred in
some of the site buildings.

In addition to the work previously completed, the Army will be conducting remediation of chemical
contamination of interior building surfaces. For more information on this issue, refer to the Phase III
Remedial Action Plan. Concurrent with this remediation, the Army will be removing any loose and/or
flaking lead paint. The Army's effort will comply with the Department of Public Health's lead paint
reguirements. Additionally, the Army will provide lead paint notification as a property transfer
reguirement.

B. Enforcement History

The following list summarizes the significant dates in relation to environmental studies, remediation,
and base closure at MTL:

MTL was first listed by MADEP as a Location To Be Investigated on January 15, 1987.
• Phase 1 RI was completed in April 1991.
• MTL was subseguently confirmed as a disposal site by MADEP on January 15, 1992.
• A Phase 2 RI was completed in May 1994.
• In July 1993, the site was proposed for inclusion on the National Priorities List (NPL)
under Superfund; the site was added to the NPL on May 30, 1994.
• A Federal Facilities Agreement (FFA) between the Army and EPA became effective on July 25,
1995.
• The installation was officially closed on September 29, 1995.
• The FS for the Outdoor Operable Unit was completed in January 1996.
• A Record of Decision for Area I was signed June 28, 1996.

IV. COMMUNITY PARTICIPATION

Throughout the site's history, community concern and involvement have been high. The MTL Public Affairs
Office has been active in responding to reguests for information, concerns, and guestions from the
community. In March 1989, the Watertown Town Manager, in conjunction with the Town Council, formed the
Watertown Arsenal Reuse Committee to study the community impact of the MTL closure In addition, the MTL
Restoration Advisory Board (RAB) was established in January 1994 to facilitate the exchange of
information between MTL and the community. RAB members include members of the Army, EPA and state
regulatory officials, and members of the community. MTL, EPA, and MADEP officials have participated in
meetings of the Watertown Arsenal Reuse Committee as well as Town Council meetings, conducted public site
tours, and have met with a number of community leaders and environmental and community organizations.
The Army also has kept the community and other interested parties apprised of the site activities through
fact sheets and press releases.

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On June 7, 1991 the Army held an informational meeting in Watertown to discuss the results of the Phase 1
RI.

In February 1992, the Army released a Public Involvement and Response Plan outlining a program to address
community concerns and keep citizens informed about and involved in activities during remedial
activities.  The Army revised and updated this plan, and in May 1995 released an updated Community
Relations Plan, which summarized information about the environmental studies, identified community
concerns, and outlined additional community relations activities.

In November 1993, the MTL Reuse Plan was completed by Goody, Clancy, and Associates. This plan was
prepared by the Town of Watertown and the Watertown Arsenal Reuse Committee.  Within this plan, the site
was divided into zones that could be reused for commercial or residential development. The land reuse
scenarios developed in this plan were based on input from the Town Council.  The Reuse Plan was approved
and accepted by the Town Council in January 1994.

On June 24, 1996, the Army made the administrative record available for public review at the installation
and the Watertown Public Library.  A copy of the Administrative Record Index is on file at the EPA's
office in Boston.  The Army published a notice and brief analysis of the Proposed Plan in The Watertown
Sun on May 1 and May 8, 1996, and The Watertown Press on May 2 and May 9, 1996, and made the plan
available to the public in the Administrative Record.

On April 16, 1996, the Army held an informational meeting to discuss the results of the RI and the
cleanup alternatives presented in the FS and to present the Proposed Plan.  During this meeting, the Army
answered guestions from the public.  From April 22 to May 22, 1996, the Army held a 30 day public comment
period to accept public comments on the alternatives presented in the FS and the Proposed Plan, and on
any other documents released previously to the public.  On May 13, 1996, the Army held a public hearing
to discuss the Proposed Plan and to accept any oral comments.  A transcript of this meeting, the comments
received, and the Army's response to comments are included in the attached responsiveness summary in
Appendix C.

V.  SCOPE AND ROIiE OF RESPONSE ACTION

For the MTL Soils and Groundwater Operable Unit, a selected remedy has been identified.  The selected
remedy (S6) includes:

       •       Excavating contaminated soil.
       •       Off-site disposal or reuse of the soil.
       •       Backfilling the excavations with clean soil.

The selected remedy is described in greater detail in Section VIII.  This remedial action will address
soil contamination, which is the principal threat to human health and the environment posed by this
operable unit of the site.

The Army has selected the contingency alternative (Alternative S6) from the Proposed Plan.  The remedy
selection was due to two factors: the cost of remediation for Alternative S6 and the Town of Watertown's
desire for a more expedited remediation schedule.   The rationale for the change in remedy selection is
described in greater detail in Section XIII.

VI.  SUMMARY OF SITE CHARACTERISTICS

Section 1 of the FS contains an overview of the RI.   The significant findings of the RI specific to this
operable unit are summarized in the following sections.

A. Soil Investigation

Soil investigation results are as follows:

       •       Soil samples collected from beneath  concrete floors in Buildings 43,  311,  and 312 showed
              elevated concentrations of semivolatile organic compounds (SVOCs).  Contaminant
              concentrations were generally highest  at the ground surface

       •       Elevated concentrations of polynuclear aromatic hydrocarbons (PAHs)  were detected in soil
              samples collected from borings completed in the grassy area between North Beacon Street and
              the Charles River.   The highest levels of PAHs were detected adjacent to Buildings 39 and
              227/60,  and in the parking lot between Buildings 37 and 131 (see Figure 4).   The maximum
              concentration of total PAHs detected was 99 parts per million (ppm).

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• Polychlorinated biphenyls (PCBs) were detected at levels above the EPA action level of 1 ppm
maximum concentration of 4.9 ppm) at two site locations, near Structure 244/245 (propellant
storage area), and at the eastern fenceline, approximately 100 ft east of the tennis courts
(see Figure 4).

• The analytical results showed that the total uranium activity in all soils was below the
federal maximum allowable standards.

• Metals concentrations (primarily lead) had their highest concentrations reported in shallow
(less than 1 ft bgs) soil samples collected from immediately outside Buildings 39, 43, 311,
313, and 656, with a maximum lead concentration of 7,200 ppm (mg/kg)

• Pesticides were detected in surface soil samples, particularly in the grassy areas in the
southeastern and central portions of the site and along the southern fenceline (maximum
total pesticide concentration of 11 ppm).

In regard to the removal at Building 227 of soil contaminated by a fuel leak, analysis of excavated soils
indicated the presence of fuel-related compounds. Excavation of soil was stopped when it was determined
that structural damage to the building would occur if excavation continued Residual fuel-contaminated
soil remains and has yet to be fully characterized. Because Section 101(14) of CERCLA contains an
exclusion for petroleum, the cleanup of petroleum-contaminated soils at MTL is being conducted under
MADEP jurisdiction and is not addressed in this Record of Decision.

B. Groundwater Investigation

With the exception of one well, all upgradient wells showed detectable guantities of chlorinated
solvents, which suggests that off-site sources have caused or aggravated on-site groundwater
contamination. Chlorinated solvents identified in these wells include tetrachloroethylene (PCE),
trichloroethylene (TCE) , and 1,1,1-trichloroethane (TCA), with a maximum total volatile organic compound
(VOC) concentration detection in a single well of 14,000 parts per billion (ppb). In addition, one
upgradient well showed elevated concentrations of gasoline-related VOCs. Based on a site water table map,
groundwater flow paths indicate the potential for groundwater to glow away from the site in an area in
the northwestern part of the site before flowing toward the Charles River (see Figure 3). No evidence of
on-site contamination migrating off-site was found in groundwater samples collected from on-site wells
because the majority of contamination was detected in the upgradient wells. The on-site farthest
downgradient wells bordering the Charles River showed the lowest level of contamination. Most likely, a
groundwater divide exists under a short stretch of Arsenal Street near the northwestern corner of the
site. but groundwater does not flow from the site to the north of Arsenal Street.

Chlorinated solvents, including TCE and PCE, were detected in groundwater samples collected from 13
on-site monitor wells. Monitor wells located in the western portion of the site reported the highest
concentrations of TCE (93 ppb) and PCE (94 ppb). Few exceedances of drinking water standards occurred.

Elevated concentrations of 1,3-dimethylbenzene (1,700 ppb) and other xylenes (1,400 ppb) were detected in
one well located in the central portion of the site. Based on a petroleum odor present during
groundwater sampling, contamination is believed to be the result of a fuel release. Analytical results
from nearby monitor wells suggest the elevated concentrations are restricted to the area around this
well.

During drilling of a soil boring beneath the Building 36 parking lot, several inches of free-phase
product was observed at the water table. Analysis of a soil sample collected at the water table
indicated that the contaminant was a fuel oil product. The sample did not contain the more commonly
known gasoline-related compounds, but it did contain certain compounds found in heavier oils. This oil
may be resulting from a pipe release in the area of Building 227, as previously mentioned. The results
of groundwater samples collected from downgradient monitor wells did not contain evidence of the
free-phase product, indicating that there hag not been contaminant migration in this direction. Because
Section 101(14) of CERCLA contains an exclusion for petroleum, any cleanup of petroleum-contaminated
groundwater at MTL is being conducted under MADEP jurisdiction and is not addressed in this Record of
Decision.

C. Storm Sewer Investigation

The storm sewers contained little or no sediment; therefore, only liguid samples were obtained during the
rain event. The sampling results indicate that the site contributes small amounts of some metals and
pesticides to the storm sewer runoff. These metals include copper and zinc (maximum detected values of
600 and 500 ppb, respectively), both of which exceed site background values and the typical urban runoff
range for these metals. Pesticide concentrations exceeding background concentrations include alpha-,

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beta-, and delta-BHC; chlordane; DDE; and methoxychlor with a maximum total pesticide detection value of
0.9 ppb. No radiological contamination was detected in storm sewer runoff.

D. Sanitary Sewer Investigation

Uranium contamination was detected in several manholes on North Beacon Street and Arsenal Street (maximum
radiological value of 73 pCi/g). On Arsenal Street, uranium was detected in a manhole connected to the
drainlines from Building 43. Because uranium concentrations in two manholes upstream of Building 43 were
lower, the contamination in the manhole connected to the drainlines from Building 43 appeared to have
been augmented by former sources in Building 43. The storm sewer lines and sanitary sewer lines are
separate systems; there are no sanitary sewer outfalls on-site from MTL to the Charles River.

In separate remediation to remove radiological contamination, manholes along North Beacon Street,
Arsenal Street, and exiting Buildings 312 and 43 were remediated. A subseguent radiological survey of the
sewer line along Arsenal Street showed no remaining radiological contamination. The results are being
reviewed by the NRC to determine whether any additional measures are reguired.

A complete discussion of site characteristics is presented in the RI Report, Section 4.

VII. SUMMARY OF SITE RISKS

A risk assessment (RA) was prepared as part of the RI for the MTL site. The RA determines the present
and future potential risks to human health and the environment posed by the site based on existing
conditions determined by the RI. Separate RAs were conducted for risks to human and ecological
receptors, from site soils. The human health RA was conducted for the entire site; the ecological risk
assessment was conducted only for undeveloped areas of the site (i.e., the southern portion of the
installation near the Commander's guarters and the 11-acre River Park on the southern side of North
Beacon Street) . It was concluded that the major risk to human health and the environment could result
from incidental ingestion of and dermal contact with contaminated soils. Soil contaminants identified as
reguiring risk reduction include PAHs, pesticides, and PCBs. In addition, the ecological RA identified
certain metals as contaminants of concern, but concluded that sitewide concentrations in soil are
predominantly at normal background conditions. There are localized areas that may pose a risk to
ecological receptors.

No RA was performed for groundwater because of a lack of receptors. Although some contamination is
present in certain areas of on-site groundwater, this does not pose a current risk because the
groundwater is not used as a water supply, and no significant migration of contamination is occurring in
off-site groundwater. The site groundwater meets the Commonwealth of Massachusetts definition of a
nondrinking water aguifer (GW-3) as defined in 310 CMR 40; therefore, there is no risk of exposure to
human receptors. Groundwater does discharge from the site into the Charles River. Therefore, a model of
contaminant contribution via groundwater to the Charles River was developed. This model, as presented in
the FS, shows that no significant concentrations of contaminants migrate to the river from site
groundwater. Hence, there is no apparent risk to human health or the environment from site groundwater.
Based on the preceding information, no remediation of MTL groundwater is necessary.

A separate RA was conducted for human receptor exposure to the storm and sanitary sewer lines. The only
applicable exposure pathway was for exposure of sewer workers. The RA concluded that there was no
significant risk to sewer workers from exposure to contaminants in the sewer water or sediments.

At the time the soil RAs were prepared, the future use of the site (commercial or residential) was
undetermined. The site was divided into five unit areas, as shown in Figure 2. The MTL installation was
divided into four zones (Zones 1 through 4). The fifth unit was the 11-acre park south of the
installation (River Park). Zones 1 through 3 represent developed areas of the site, and Zone 4 and River
Park represent undeveloped areas.

The RAs evaluated each unit separately and determined contaminants of concern for each unit for each
possible site reuse scenario. The human health RA evaluated Zones 1, 2, and 3 for commercial and
residential reuse: Zone 4 for residential reuse and public use; and the River Park for public use only.
The ecological RA evaluated only Zone 4 and River Park because these areas were considered the only
potential ecological habitats on-site.

The RAs were performed to estimate the probability and magnitude of potential adverse human health and
environmental effects from exposure to contaminants associated with the contaminated site soil. The
human health and ecological RAs followed a four-step process:

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1. Contaminant identification, which identified those hazardous substances that, given the specific of
the site, were of significant concern.

2. Exposure assessment, which identified actual or potential exposure pathways, characterized the
potentially exposed population, and determined the extent of possible exposure

3. Toxicity assessment, which considered the types and magnitude of adverse health effects associated
with exposure to hazardous substances.

4. Risk characterization, which integrated the three earlier steps to summarize the potential and
actual risks posed by hazardous substances in the soil, including cancer and noncancer risks.

The results of the human health RA for this operable unit are discussed in the following subsections,
followed by the conclusions of the ecological RA.

A. Human Health Risks from Site Soils

Fifteen contaminants ot concern were selected for evaluation in the RA (see Table 1). These contaminants
constitute a representative subset of the more than 40 contaminants identified at the site during the RI.
Summaries of the health effects of each of the contaminants of concern are presented in Appendix R of the
RI. The RA was originally conducted outside of the CERCLA program and some aspects of the RA do not
strictly adhere to current guidance. However, these differences do not affect the overall outcome of the
RA.

Potential human health effects associated with exposure to the contaminants of concern were estimated
guantitatively or gualitatively through the development of several hypothetical exposure pathways. These
pathways were developed to reflect the potential for exposure to hazardous substances based on the
present uses, potential future uses, and location of the site. As stated previously, the site was divided
into five different units-Zones 1 through 4 and River Park. An assessment was performed for each possible
reuse; Zones 1 through 3 were assessed for commercial and residential reuse; Zone 4 was assessed for
residential and public access reuse: and River Park was assessed for public access only. The following
is a summary of the exposure pathways evaluated. A more thorough description is presented in Section 6
of the RI.

For future site residents, incidental soil ingestion and dermal contact were evaluated for the individual
young child (1 to 2 years) for 1 year, child (age 1 to 8 years) for 7 years, and adult for 30 years.
Resident exposure wag based on 153 days per year for soil ingestion and 107 days per year for dermal
contact. Adult and child visitors in Zone 4 were evaluated for soil exposure of 56 days to a 1-year
duration. Adult and child visitors to River Park had the same soil exposure scenario as Zone 4 visitors,
but also included incidental ingestion and dermal contact with Charles River surface water and sediments
during swimming activities; exposure was based on 56 days for a 1-year exposure. Exposure for commercial
workers was based on soil ingestion and dermal contact for 250 days per year for 25 years. Exposure for
construction workers was based on soil ingestion and dermal contact for 18 days over a 1-year period.

Excess lifetime cancer risks were determined for each exposure pathway by multiplying the exposure level
with the chemical-specific cancer factor. Cancer potency factors have been developed by EPA from
epidemiological or animal studies to reflect a conservative upper bound of the risk posed by potentially
carcinogenic compounds. That is, the true risk is unlikely to be greater than the risk predicted. The
resulting risk estimates are expressed in scientific notation as a probability (e.g. 1E-06 for 1 in
1,000,000) and indicate (using this example) that an average individual is not likely to have greater
than a 1-in-l-million chance of developing cancer over 70 years as a result of site-related exposure to
the compound at the stated concentration.

-------
Table 1
Summary of Soil Contaminants of Concern
Site Soils
Background Soils
Contaminant of
Concern
Benzo (a) anthracene
Benzo (a) pyrene
Benzo (b) f luoranthene
Benzo (k) f luoranthene
Chlordane
Chrysene
DDD
DDE
DDT
Dibenz (a,h) anthracene
Dieldrin
Heptachlor epoxide
Indeno (1,2, 3-cd) pyrene
Aroclor-1260
Geometric
Mean
Concentration
(mg/kg)
3,
8,
5,
4,
1.
3,
1.
1.
3,
2,
1.
7,
1.
5,
.7E-01
.2E-01
.3E-01
. 1E-01
.8E-01
.2E-01
. 1E-02
. 6E-02
. 8E-02
. 1E-01
. OE-02
.2E-03
. 1E+00
. 9E-02
Maximum
Concentration
(mg/kg)
3,
3,
1.
2,
9,
3,
3,
6,
5,
3,
4,
8,
1.
4,
.2E+01
. 7E+01
.5E+01
. 4E+01
. 4E+00
. 4E+01
.5E+00
. 3E+00
.2E+00
.3E+00
. OE+00
.7E-01
. 4E+01
. 9E+00
Geometric
Mean
Concentration
(mg/kg)
8,
7,
3,
1.
5,
7,
2,
2,
4,
1.
2,
1.
1.
3,
.3E-02
. 9E-01
.3E-01
.5E-01
. 8E-02
. 3E-02
. 1E-03
. 6E-03
. OE-03
. 9E-01
.5E-03
. 4E-03
. 5E+00
. 6E-02
Maximum
Concentration
(mg/kg)
6,
6,
7,
6,
1.
9,
4,
2,
1.
9,
6,
2,
7,
1.
. 1E+00
. 8E+00
. 6E+00
. 3E+00
. 9E+00
. 2E+00
.7E-02
.5E-01
. 9E-01
.7E-01
. 7E-02
. 4E-01
. 7E+00
. 6E+00
Current regulatory practice considers cancer risks to be additive when assessing exposure to a mixture of
hazardous substances.

A hazard index also was calculated for each pathway as the measure of the potential for noncancer health
effects. The hazard index for a pathway is determined by using the sum of the hazard guotients for each
contaminant in that specific pathway. A hazard guotient for each contaminant is calculated by dividing
the exposure level by the reference dose (RfD) or other suitable benchmark for noncancer health effects
for an individual compound. Reference doses have been developed by EPA to protect sensitive individuals
over the course of a lifetime, and they reflect a daily exposure level that is likely to be without an
appreciable risk of an adverse health effect. RfDs are derived from epidemiological or animal studies and
incorporate uncertainty factors to help ensure that adverse health effects will not occur. The hazard
guotient is often expressed as a single value (e.g., 0.3) indicating the ratio of the stated exposure as
defined to the reference dose value (in this example, the exposure as characterized is approximately
one-third of an acceptable exposure level for the given compound). The hazard guotient is considered
additive only for compounds that have the same or similar toxic endpoint and the sum is referred to as
the hazard index. For example, the hazard guotient for a compound known to produce liver damage should
not be added to a second whose toxic endpoint is kidney damage.

Tables 2 through 10 summarize the cancer and noncancer risks for the 14 contaminants of concern in soil,
listed in Table 1, for each of the possible site scenarios evaluated to reflect present and potential
future commercial or residential reuse. Based on this summary, the majority of the cancer risk is due to
soil ingestion. All 14 contaminants of concern contribute to this risk. There is no significant risk
from the construction worker scenario for all zones. The hazard index for all zones and all exposure
scenarios was less than the target number of 1.

As a separate document, a report entitled Addendum to Human Health Evaluation (WESTON, July 1996) was
prepared. This evaluated the risks to children (age 1 to 8 years) and youths (age 7 to 17) years as
trespassers onto areas of the site remediated to commercial cleanup levels. The results of this
evaluation showed that for exposure to soils (oral and dermal exposure), the total hazard index to both
children and youths was less than the target number of 1. The total cancer risk for children and youths
was within the EPA acceptable risk range.

B. Ecological Risks from Site Soils
As part of RI evaluations of the MTL facility, an assessment of risks to ecological receptors at the
installation was conducted. The results of this assessment are presented in a report entitled Baseline
Risk Assessment-Environmental Evaluation (Life Systems, Inc., December 1993). As part of the ecological
RA, it was determined that terrestrial populations and communities in the area of the installation were
not of ecological concern. For this reason, the only exposure endpoints evaluated were fish inhabiting
the Charles River, and migratory birds visiting the river on a transient basis.

-------
                                       Table 2
                  Summary of Chemical Cancer Risks—Zone 1 Resident
 Potentially Exposed
     Population

Resident Adult
 Exposure Point

Zone 1
 Exposure Medium

Soil
(not excavated)
Exposure
  Route

Ingestion
Dermal
Cancer
 Risk

7E-06
7E-06
                       River Park
                   Soil
                     Ingestion
                     Dermal
                                                                                  IE-OS
                                                                                  1E-06
                       Charles River
                                          Surface Water
                                        Ingestion
                                        Dermal
                                                                                  1E-10
                                                                                  8E-09
                                          Sediment
                                        Ingestion
                                        Dermal
                                                                                  2E-06
                                                                                  5E-09
                       Zone 4--Open
                       Area
                                          Fish

                                          Soil
                                        Ingestion

                                        Ingestion
                                        Dermal
                                        5E-08

                                        4E-06
                                        3E-06
                                                             Total Site Risk:
                                                                                  3E-05
Resident Adult
                       Zone 1
                   Soil
                   (excavated)
                     Ingestion
                     Dermal
                                                                                  6E-06
                                                                                  6E-06
                       River Park
                   Soil
                     Ingestion
                     Dermal
                                                                                  IE-OS
                                                                                  1E-06
                       Charles River
                                          Surface Water
                                        Ingestion
                                        Dermal
                                                                                  1E-10
                                                                                  8E-09
                                          Sediment
                                        Ingestion
                                        Dermal
                                                                                  2E-06
                                                                                  5E-09
                       Zone 4-Open
                       Area
                                          Fish

                                          Soil
                                        Ingestion

                                        Ingestion
                                        Dermal
                                        5E-08

                                        4E-06
                                        3E-06
                                                             Total Site Risk:
                                                                                  3E-05

-------
                                         Table 3
                  Summary of Chemical Cancer Risks-Zone 2 and 3 Resident
 Potentially Exposed      Exposure
     Population             Point
 Exposure Medium
Exposure
 Route
Cancer
 Risk
Resident Adult
                        Zone 2
Soil
(not excavated)
Ingestion
Dermal
                                                                                       4E-05
                                                                                       6E-06
                        River Park
Soil
Dermal
Ingestion
                                                                                       IE-OS
                                                                                       1E-06
                        Charles River
                                           Surface Water
                           Ingestion
                           Dermal
                                                                                       1E-10
                                                                                       8E-09
                                           Sediment
                           Ingestion
                           Dermal
                                                                                       2E-06
                                                                                       5E-09
                        Zone 4-
                        Open Area
                                           Fish

                                           Soil
                           Ingestion

                           Ingestion
                           Dermal
                 5E-08

                 4E-06
                 3E-06
                                                                   Total  Site Risk:
                                                                                       7E-05
Resident Adult
                        Zone 3
Soil
(not excavated)
Ingestion
Dermal
                                                                                       5E-05
                                                                                       6E-06
                        River Park
Soil
Ingestion
Dermal
                                                                                       IE-OS
                                                                                       1E-06
                        Charles River
                                           Surface Water
                           Ingestion
                           Dermal
                                                                                       1E-10
                                                                                       8E-09
                                           Sediment
                           Ingestion
                           Dermal
                                                                                       2E-06
                                                                                       5E-09
                        Zone 4-
                        Open Area
                                           Fish

                                           Soil
                           Ingestion

                           Ingestion
                           Dermal
                 5E-08

                 4E-06
                 3E-06
                                                                  Total  Site Risk:
                                                                                       8E-05

-------
                                       Table 4
                   Summary of Chemical Cancer Risks—Zone 4 Resident
    Potentially Exposed                      Exposure
        Population       Exposure Point      Medium
                                       Exposure
                                         Route
                                 Cancer Risk
Resident Adult
                        Zone 4
                    Soil
                    (excavated)
                   Ingestion
                   Dermal
                                                                               2E-05
                                                                               6E-06
                        River Park
                    Soil
                   Ingestion
                   Dermal
                                                                               IE-OS
                                                                               1E-06
                        Charles River
                                           Surface Water
                                       Ingestion
                                       Dermal
                                                                               1E-10
                                                                               8E-09
                                           Sediment
                                       Ingestion
                                       Dermal
                                                                               2E-06
                                                                               5E-09
                                           Fish
                                       Ingestion        5E-08

                                   Total Site Risk:      4E-05
                                      Table 5
                  Summary of Chemical Cancer Risks-Worker Populations
Potentially Exposed
    Population

Commercial Worker
                   Exposure
  Exposure Point    Medium
                        Zone 1
                        Zone 2
                        Zone 3
                    Soil
                    Soil
                    Soil
                    Exposure
                      Route

                   Ingestion
                   Ingestion
                   Ingestion
              Cancer Risk

                 3E-06
                 IE-OS
                 2E-05
Construction Worker
                        Zone 1
                    Soil
                    Dust
                   Ingestion
                   Inhalation
                                                                               6E-08
                                                                               9E-07
                                                                Total Risk:
                                                                               1E-06
                        Zone 4
                    Soil
                    Dust
                   Ingestion
                   Inhalation
                                                                               2E-07
                                                                               9E-07
                                                                Total Risk:
                                                                               1E-06
                                     Table 6
                  Summary of Chemical Cancer Risks-Park Visitors
 Potentially Exposed                         Exposure
      Population       Exposure Point         Medium
                                       Exposure
                                         Route
                                    Cancer
                                     Risk
Resident Adult
River Park
Soil
Ingestion
Dermal
                                                                               IE-OS
                                                                               1E-06
                       Charles River
                                           Surface Water
                                       Ingestion
                                       Dermal
                                                                               1E-10
                                                                               8E-09
                                           Sediment
                                       Ingestion
                                       Dermal
                                                                               2E-06
                                                                               5E-09
                                                              Ingestion        5E-08

                                                                 Total  Risk:    IE-OS
Resident Adult
                       Zone 4-Open
                       Area
                    Soil
                   Ingestion
                   Dermal
                                                        4E-06
                                                        3E-06
                                                                 Total  Risk:
                                                                               7E-06

-------
               Table 7
Summary of Hazard Indices-Zone 1 Resident
Potentially
Exposed
Population
Resident Child






Resident
Child





Exposure Exposure
Point Medium
Zone Soil
(not excavated)
River Park Soil
Charles Surface Water
River
Sediment
Fish
Zone 4- Soil
Open Area
Total Site
Zone 1 Soil
(excavated)
River Park Soil
Charles Surface Water
River
Sediment
Fish
Zone 4- Soil
Open Area
Exposure
Route
Ingestion
Dermal
Ingestion
Dermal
Ingestion
Dermal
Ingestion
Dermal
Ingestion
Ingestion
Dermal
Hazard Index:
Ingestion
Dermal
Ingestion
Dermal
Ingestion
Dermal
Ingestion
Dermal
Ingestion
Ingestion
Dermal
Subchronic
Hazard
Index
5E-02
1E-02
3E-02
4E-03
4E-06
1E-04
IE-OS
9E-04
-
7E-02
2E-02
2E-01
5E-02
9E-03
3E-02
4E-03
4E-06
1E-04
1E-03
9E-04
-
7E-02
2E-02
Chronic
Hazard
Index
5E-02
1E-02
2E-02
4E-03
3E-05
1E-03
2E-03
1E-02
1E-02
4E-02
2E-02
2E-01
4E-02
1E-02
2E-02
4E-03
3E-05
1E-03
2E-03
1E-02
1E-02
4E-02
2E-02
                   Total Site Hazard Index:
                                                 2E-01
                                                                  2E-01

-------
                    Table 8
Summary of Hazard Indices-Zone 2 and 3 Resident
Potentially
Exposed Exposure Exposure
Population Point Medium
Resident Child Zone 2 Soil
(not excavated)
River Park Soil
Charles Surface Water
River
Sediment
Fish
Zone 4- Soil
Open Area
Total Site
Resident Child Zone 3 Soil
(not excavated)
River Park Soil
Charles Surface Water
River
Sediment
Fish
Zone 4- Soil
Open Area
Exposure
Route
Ingestion
Dermal
Ingestion
Dermal
Ingestion
Dermal
Ingestion
Dermal
Ingestion
Ingestion
Dermal
Hazard Index:
Ingestion
Dermal
Ingestion
Dermal
Ingestion
Dermal
Ingestion
Dermal
Ingestion
Ingestion
Dermal
Subchronic
Hazard
Index
2E-01
3E-02
3E-02
4E-03
4E-06
1E-04
1E-03
9E-04
-
7E-02
2E-02
4E-01
1E-01
2E-02
3E-02
4E-03
4E-06
1E-04
1E-03
9E-04
-
7E-02
2E-02
Chronic
Hazard
Index
2E-01
4E-02
2E-02
4E-03
3E-05
1E-03
2E-03
1E-02
1E-02
4E-02
2E-02
3E-01
1E-01
6E-02
2E-02
4E-03
3E-05
1E-03
2E-03
1E-02
1E-02
4E-02
2E-02
                       Total Site Hazard Index:
                                                     2E-01
                                                                      3E-01

-------
                                              Table 9
                             Summary of Hazard Indices-Zone 4 Resident
Potentially
Exposed
Population
Resident Child







Potentially Exposed
Commercial Worker


Construction Worker




Exposure Exposure Exposure
Point Medium Route
Zone 2 Soil Ingestion
(excavated) Dermal
River Park Soil Ingestion
Dermal
Charles River Surface Water Ingestion
Dermal
Sediment Ingestion
Dermal
Fish Ingestion
Total Site Hazard Index:
Table 10
Summary of Hazard Indices—Worker Populations
Population Exposure Exposure
Point Medium
Zone 1 Soil
Zone 2 Soil
Zone 3 Soil
Zone 1 Soil
Dust

Zone 4 Soil
Dust

Subchronic
Hazard
Index
2E-01
2E-02
3E-02
4E-03
4E-06
1E-04
1E-03
9E-04
-
2E-01


Exposure
Route
Ingestion
Ingestion
Ingestion
Ingestion
Inhalation
Total:
Ingestion
Inhalation
Total:
Chronic
Hazard
Index
1E-01
3E-02
2E-02
4E-03
3E-05
1E-03
2E-03
1E-02
1E-02
2E-01


Hazard
Index*
7E-03
3E-02
2E-02
4E-03
4E-03
1E-02
2E-04
1E-02
*Hazard index is subchronic for the construction worker and chronic for the commercial  worker.

-------
After the MIL site was added to the NPL, at the request of EPA, the issue of risks posed to terrestrial
populations at the facility was revisited, and a Terrestrial Ecological Risk Assessment WESTON, 1995)
that complies with the substantive requirements of CERCLA was produced. This evaluation characterized
risk to terrestrial wildlife, terrestrial vegetation, and soil invertebrates posed by MTL soil
contaminants. Most of the MTL site has limited potential as ecological habitat. Suitable habitat for
terrestrial vegetation and wildlife is restricted to the southeastern corner of the site. This area of
the site, which includes Zone 4 and River Park, was the focus of the terrestrial ecological RA. The
terrestrial species evaluated and their relevant exposure pathways are as follows:

• Short-tailed shrew:

Ingestion of soil invertebrates (e.g., earthworms).
Incidental ingestion of soil.

• White-footed mouse:

Ingestion of vegetation (e.g., seeds).
Incidental ingestion of soil.
American robin:
Song sparrow:
Ingestion of soil invertebrates (e.g., earthworms).
Incidental ingestion of soil.
Ingestion of vegetation (e.g., seeds).
Incidental ingestion of soil.
Terrestrial plants:
Direct contact with soil.
Absorption/concentration from soil.
Soil invertebrates:
Direct contact with soil.
Absorption/concentration from soil.

The potential risk posed to ecological receptors (i.e., shrew, mouse, robin, and sparrow) was assessed by
comparing estimated daily doses to reference toxicity values. This comparison, described as a hazard
quotient, was calculated for each contaminant by dividing the estimated daily dose by the reference
toxicity values. Hazard quotients were summed across all exposure pathways to each contaminant, by
receptor, to develop chemical-specific hazard indices. Hazard quotients and hazard indices were not
calculated for plants and soil invertebrates. Instead, available toxicity data were presented and
compared directly to soil chemical data.

The hazard indices for all ecological receptors are presented in Section 5 of the Terrestrial Ecological
Risk Assessment (WESTON, June 1995). The hazard quotients and hazard indices for ecological receptors
were calculated using two exposure concentrations: the mean and the 95% upper confidence limit (UCL) of
the mean.

A hazard index at < I indicates that adverse effects are not likely to occur, and no action is required.
A hazard index of > 10 indicates that risks are at a level of potential concern, and may warrant action,
depending on the nature of the risk, the nature of the site and surrounding properties, evaluations of
background levels of contaminants in the area under investigation, and uncertainties associated with the
risk calculation.

A hazard index between 1 and 10 is subject to interpretation based on the toxicity of the chemical and
the uncertainty in the calculation. In addition, the frequency of detection and reproducibility of the
data should be investigated. Whether a remedial action must be initiated should be examined on a
site-by-site basis, after careful consideration of the levels of the hazard indices compared to the
possible adverse impacts of remedial action on the ecological habitat (e.g., loss of existing wetland
communities and other habitats, or increased contaminant migration resulting from resuspension of
contaminated fine-grained particles). The only receptors whose exposure to soil contaminants at MTL
would result in hazard indices exceeding 10 are the shrew, white-footed mouse, and robin.

-------
An overview of the findings of the ecological RA and the contaminants that contributed substantially to
the total hazard for each receptor is as follows:

• Northern short-tailed shrew--Based on the mean soil exposure concentrations, chemical-specific
hazard indices that exceeded 10 were chlordane (12), chromium (22), nickel (360), and zinc (13).
Based on the 95% UCL exposure concentrations, chlordane (41) , DDT (46) , arsenic (13) , chromium
(24), lead (37), nickel (430), and zinc (15) result in exceedances of a hazard index of 10.
Approximately 87% to 93% of the hazard indices can be attributed to the earthworm ingestion
exposure route.

• White-footed mouse-Nickel was the only contaminant that exceeded a hazard index of 10 for the
mouse. The hazard indices calculated for nickel were 16 and 19, based on the mean and the 95% UCL
exposure concentrations, respectively. Seed ingestion contributed the majority of the risk
• American robin--The exposure route that contributed the most risk to the robin was the earthworm
ingestion route (>95%) . Within this pathway, pesticides contributed the largest portion of the
risk (86% for mean exposure concentrations: 96% for the UCL) . Based on the mean soil exposure
concentrations, hazard indices that exceeded 10 were DDE (40) and DDT (48) . Based on the 95% UCL
exposure concentrations, hazard indices that exceeded 10 were DDE (180) , DDT (280) , and endrin
(16) .

• Song sparrow-No chemical-specific hazard indices exceeded 10 for the song sparrow. Only two hazard
indices exceeded 1 (DDT-2.2 and endrin-1.9), based on the 95% UCL exposure concentrations.

A comparison of soil concentrations at the site with phytotoxicity data shows the potential for
phytotoxic effects to occur at some locations on-site. Exceedances of phytotoxicity data occurred for
arsenic, cadmium, copper, lead, and zinc. These metals occurred on-site at concentrations that have been
shown to cause yield reductions, growth retardation, leaf discoloration, and reduced germination.

Potential effects on soil invertebrates also may occur at some locations at the site. Exeeedances of
toxicity data were observed for chlordane, DDE, copper, and zinc. The maximum detected concentrations of
copper and zinc at the site exceed the LC50 (the lethal concentration for 50% of the test organisms) for
earthworms, and a number of other locations exceeded the EC50 (the effective concentration for 50% of the
test organisms) for cocoon production in earthworms.

Chlordane exceeded concentrations at which sperm count depressions have been observed in earthworms, and
DDE exceeded concentrations at which epidermal changes have been observed in earthworms.

The presence of hazardous substances in soil at this operable unit, if not addressed by implementing the
remedial action selected in this Record of Decision, may present an unacceptable risk to human health and
the environment. Remedial actions were developed to address the risks associated with site soils.

VIII. DEVELOPMENT AND SCREENING OF ALTERNATIVES

A. Statutory Requirements/Remedial Action Objectives

Under its legal authorities, EPA' s primary responsibility at Superfund sites is to undertake remedial
actions that are protective of human health and the environment. In addition, Section 121 of CERCLA
establishes several other statutory reguirements and preferences, including the following:

• A reguirement that the remedial action, when complete, comply with all federal and more
stringent state environmental standards, reguirements, criteria, or limitations, unless a
waiver is invoked.

• A reguirement that a remedial action be selected that is cost-effective and that uses
permanent solutions and alternative treatment technologies or resource recovery technologies
to the maximum extent practicable.

• A preference for remedies in which treatment that permanently and significantly reduces the
volume, toxicity, or mobility of the hazardous substances is a principal element over
remedies nor involving such treatment.

Remedial alternatives were developed to be consistent with these Congressional mandates.

-------
Based on information from the RI relating to types of contaminants, environmental media of concern, and
potential exposure pathways, remedial action objectives were developed to aid in the development and
screening of alternatives. These remedial action objectives were developed to mitigate existing and
future potential threats to human health and the environment. At this site, for this operable unit, one
remedial action objective was identified. This objective was to mitigate the risks to human health and
the environment posed by direct contact with and incidental ingestion of contaminated soils.

B. Technology and Alternative Development and Screening

CERCIA and the NCP set forth the process by which remedial actions are evaluated and selected. In
accordance with these reguirements, a range of alternatives was developed for the site.

With respect to soil contamination, the RI/FS developed a range of alternatives in which treatment that
reduces the toxicity, mobility, or volume of the hazardous substances is a principal element. This range
of alternatives included the following:

• An alternative that removes or destroys hazardous substances to the maximum extent feasible,
eliminating or minimizing to the degree possible the need for long-term management.

• Alternatives that treat the principal threats posed by the site, but vary in the degree of
treatment used and the guantities and characteristics of the treatment residuals and
untreated waste that must be managed.

• Alternative(s) that involve little or no treatment but provide protection through
engineering or institutional controls.

• A no-action alternative.

As discussed in Section 3 of the FS, the RI/FS identified, assessed, and screened technologies based on
implementability, effectiveness, and cost. These technologies were combined into alternatives for soil
remediation. Section 4 of the FS presented the remedial alternatives developed by combining the
technologies identified in the previous screening process in the categories identified in Section
300.430(e)(3) of the NCP. The purpose of the initial screening was to narrow the number of potential
remedial actions for further detailed analysis while preserving a range of options. Each alternative was
then evaluated and screened in Section 4 of the FS.

In summary, of the six soil remedial alternatives screened in Section 4 of the FS, all six were retained
for detailed analysis Table 11 identifies the six alternatives that were retained through the screening
process.

-------
Table 11
Alternatives for Remediation of Soil

Alternative Si-No Action

• No remedial actions implemented at the site.

Alternative S2-Institutional Controls

• Access restrictions to prevent entry into contaminated areas.
• Deed restrictions to restrict site development.
• Five-year site reviews to assess conditions.

Alternative S3--Capping of Soils

• Institutional controls.
• Five-year site reviews to assess conditions.
• Construction of asphalt cap over contaminated soils.
• Use of runon/runoff controls during cap placement.
• Continued monitoring of cap and repair of cap as necessary.

Alternative S4--Soil Excavation and Thermal Treatment

• Excavation of soil contaminated at levels greater than action levels.
• Transportation of soil to:

- Option A-On-site incinerator.
- Option B-Off-site incinerator.
- Option C-On-site low-temperature thermal desorber.
- Backfilling of site with uncontaminated soil (Option B) or treated soil (Options A and C)

Alternative S5-Soil Excavation and On-Site Physical/Chemical Treatment

• Excavation of soil contaminated at levels greater than action levels.
• On-site treatment of contaminated soil by:

Option A-Chemical oxidation.
Option B-Solvent extraction.

• Treatment or disposal of treatment residues.
• Backfilling of site with treated soil.

Alternative S6-Soil Excavation and Off-Site Disposal or Reuse (Selected Remedy)

• Excavation of soil contaminated at levels greater than action levels.
• Transportation of soil for off-site recycling or to a hazardous or nonhazardous landfill
• Backfilling of site with uncontaminated soil.

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IX. DESCRIPTION OF ALTERNATIVES

This section provides a narrative summary of each alternative evaluated. A detailed tabular assessment
of each alternative is presented in Table 6-1 of the FS.

In the FS, all alternatives were analyzed and costs determined for the three possible site reuse
scenarios (as developed previously by the Watertown Arsenal Reuse Committees approved MTL Reuse Plan).
These scenarios are defined fully in Section 3 of the FS. The scenario defined as Reuse Scenario 3 is
consistent with the Town of Watertown's intended future use of MTL as outlined in the Reuse Plan. The
Reuse Plan was developed by the Arsenal Reuse Committee and approved by the Watertown Town Council. This
reuse scenario, is defined as a mixture of commercial and residential reuse for developed areas
(commercial reuse for Zones 1 and 2 and residential reuse for Zone 3) and public access for undeveloped
areas (Zone 4 and the River Park). This reuse scenario was used in establishing specific soil cleanup
goals in each zone and determining the soil areas to be remediated. The approximate locations of areas
reguiring remediation are shown in Figure 4. An estimated total soil volume of 23,600 yd3 will eguate
remediation. This represents an increase in soil volume of approximately 800 yd3 from the Proposed Plan.
Cost estimates for the alternatives below have been adjusted accordingly to reflect the change in soil
volume. See Section XIII for further description of soil volume and cost changes

The following alternatives were evaluated (the designation "S" indicates that these alternatives refer to
soil):

Alternative Si-No Action: This alternative was evaluated in detail in the FS to serve as a baseline for
comparison with the other remedial alternatives under consideration. Under this alternative, no active
or passive treatment or containment of contaminated areas would occur. The only activity would be an
EPA-reguired site review every 5 years.

Estimated Time for Design and Construction: None.
Estimated time of Operation: Indefinitely.
Estimated Capital Cost: None.
Estimated Operation and Maintenance Cost (30-year net present worth): $27,400.
Estimated Total Cost (30-year net present worth): $27,400.

Alternative S2-Institutional Controls: Under this alternative, no treatment or containment of
contaminated areas would occur. The only effort that would be made to restrict potential exposure to
site contaminants would be through the use of institutional controls, such as installing warning signs
and fences around contaminated areas and imposing deed restrictions on site real estate transfer.

Estimated Time for Design and Construction: 6 months.
Estimated Time of Operation: Indefinitely.
Estimated Capital Cost: $12,000.
Estimated Operations and Maintenance Cost (30-year net present worth):$166,600.
Estimated Total Cost (30-year net present worth): $178,600.

Alternative 53-Capping of Soils: Alternative S3 would not involve removal of the contaminated soil.
Instead the contaminated areas would be covered with a permanent asphalt cap. The cap, which would
prevent contact with the contaminated soil, would reguire long-term maintenance.

Estimated Time for Design and Construction: 32 months.
Estimated Time of Operation: Indefinitely.
Estimated Capital Cost: $2,868,000.
Estimated Operation and Maintenance Cost (30-year net present worth): $2,388,000.
Estimated Total Cost (30-year net present worth): $5,256,000.

Alternative S4-Option A: Soil Excavation and Treatment Using On-Site Incineration: In this alternative,
all soil exceeding cleanup criteria would be excavated. Excavated material would be stockpiled on-site
until treatment. Treatment would be conducted using an on-site mobile incinerator. Prior to full-scale
operation, trial burns would be conducted to determine incinerator operating conditions. Air emission
controls would be implemented. Treatment ash would be analyzed and disposed of on- or off-site depending
on its characteristics. Any metals-contaminated soil reguiring remediation would be excavated and
disposed of off-site. Clean soil would be used to backfill the excavations.

-------
Estimated Time for Design and Construction: 36 months.
Estimated Time of Operation: 12 to 18 months.
Estimated Capital Cost: $13,627,000.
Estimated Operation and Maintenance Cost (30-year net present worth): $27,000.
Estimated Total Cost (30-year net present worth): $13,654,000.

Alternative S4-Option B: Soil Excavation and Treatment Using Off-Site Incineration: In this alternative,
all soil exceeding cleanup criteria would be excavated. Excavated material would be stockpiled on-site.
Soil would be transported to an off-site incinerator for treatment. Treatment ash would be disposed of
at the off-site facility. Any metals-contaminated soil requiring remediation would be excavated and
disposed of off-site. Clean soil would be used to backfill the excavations

Estimated Time for Design and Construction: 27 months.
Estimated Time of Operation: 9 to 12 months.
Estimated Capital Cost: $51,033,000.
Estimated Operation and Maintenance Cost (30-year net present worth): $27,000.
Estimated Total Cost (30-year net present worth): $51,060,000.

Alternative S4-Option C: Soil Excavation and Treatment Using On-Site Thermal Desorption: In this
alternative, all soil exceeding cleanup criteria would be excavated. Excavated material would be
stockpiled on-site until treatment. Treatment would be conducted using an on-site mobile thermal
desorber. Prior to full-scale operation, a trial system operation would be performed to determine proper
operating conditions. Removed contaminants would be collected and disposed of off-site or treated
on-site. The treated soil would be used to backfill the excavations. Any metals-contaminated soil
requiring remediation would be excavated and disposed of off-site.

Estimated Time for Design and Construction: 36 months.
Estimated Time of Operation: 12 to 18 months.
Estimated Capital Cost: $17,500,000.
Estimated Operation and Maintenance Cost (30-year net present worth): $27,000.
Estimated Total Cost (30-year net present worth): $17,527,000.

Alternative S5-Option A: Soil Excavation and Treatment Using On-Site Chemical Oxidation: In this
alternative, all soil exceeding cleanup criteria would be excavated. Excavated material would be
stockpiled on-site until treatment. During treatment, the soil would be mixed with water and a chemical
oxidizing agent. Organic contaminants would be destroyed in a chemical reaction. No treatment residuals
would remain. The treated soil would be used as on-site backfill in the excavations. Any
metals-contaminated soil requiring remediation would be excavated and disposed of off-site. Prior to
full-scale operation, a bench-scale test would be performed to determine the required dosage of oxidant.

Estimated Time for Design and Construction: 24 months.
Estimated Time of Operation: 6 to 8 months.
Estimated Capital Cost: $5,556,000.
Estimated Operations and Maintenance Cost (30-year net present worth) :$27, 000.
Estimated ?oral Cost (30-year net present worth): $5,583,000.

Alternative S5-Option B: Soil Excavation and Treatment Using On-Site Solvent Extraction: This alternative
revolves an on-site physical separation treatment called solvent extraction. In this alternative, all
soil exceeding cleanup criteria would be excavated. Excavated material would be stockpiled on-site until
treatment. During treatment, the contaminants in the soil would be removed by mixing the soil with a
nontoxic solvent. Contaminants would be dissolved from the soil into the solvent. The solvent would be
collected and the contaminants recovered from the solvent. The solvent would be recycled, and recovered
contaminants would be disposed of off-site or treated on-site. The treated soil would be used to
backfill the excavations. Any metals-contaminated soil requiring remediation would be excavated and
disposed of off-site.

Estimated Time for Design and Construction: 30 months.
Estimated Time of Operation: 9 to 12 months.
Estimated Capital Cost: $11,828,000.
Estimated Operation and Maintenance Cost (30-year net present worth): $27,000
Estimated Total Cost (30-year net present worth): $11,855,000.

Alternative S6-Soil Excavation and Off-Site Disposal/Reuse: In this alternative, all soil exceeding
cleanup criteria would be excavated. Excavated material would be divided into hazardous and nonhazardous
waste. All excavated soil would be disposed of off-site. Hazardous soil would be disposed of at a
hazardous waste landfill. Nonhazardous waste would be disposed of at a nonhazardous landfill and/or an
asphalt batching facility. The excavations would be backfilled with clean soil.

-------
Estimated Time for Design and Construction: 6 months.
Estimated Time of Operation: 6 to 9 months.
Estimated Capital Cost: $5,741,000.
Estimated Operation and Maintenance Cost (30-year net present worth): $27,000
Estimated Total Cost (30-year net present worth): $5,768,000.

X. SUMMARY OF THE COMPARATIVE ANALYSIS OF ALTERNATIVES

Section 121(b)(1) CERCLA presents several factors that at a minimum are required to be considered in the
assessment of alternatives. Building on these specific statutory mandates, the NCP presents nine
evaluation criteria to be used in assessing the individual remedial alternatives.

A detailed alternative analysis using the nine evaluation criteria was performed to select a site remedy.
This section presents a summary of the comparison of each alternative's strengths and weaknesses with
respect to the nine evaluation criteria.

A. Summary of Evaluation Criteria

The criteria are summarized as follows:

Threshold Criteria—The following two threshold criteria must be met for alternatives to be eligible for
selection in accordance with the NCP:

1. Overall protection of human health and the environment addresses whether a remedy provides
adequate protection and describes how risks posed through each pathway are eliminated, reduced, or
controlled through treatment, engineering controls, or institutional controls.

2. Compliance with Applicable or Relevant and Appropriate Requirements (ARARs) addresses whether a
remedy will meet all of the ARARs of other federal and state environmental laws and/or will provide
grounds for invoking a waiver.

Primary Balancing Criteria-Once an alternative satisfies the threshold criteria, the following five
criteria are used to compare and evaluate the elements of the alternatives.

3. Long-term effectiveness and permanence addresses the criteria that are used to assess alternatives
for the long-term effectiveness and permanence they afford, along with the degree of certainty that
they will prove successful.

4. Reduction of toxicity, mobility, or volume through treatment addresses the degree to which
alternatives use recycling or treatment that reduces toxicity, mobility, or volume, including how
treatment is used to address the principal threats posed by the site.

5. Short-term effectiveness addresses the period of time needed to achieve protection and any adverse
impacts on human health and the environment that may be posed during the construction and
implementation period, until cleanup goals are achieved.

6. Implementability addresses the technical and administrative feasibility of a remedy, including the
availability of materials and services needed to implement a particular option.

7. Cost includes estimated capital, operation and maintenance (O&M), and present-worth costs.

Modifying Criteria-The modifying criteria are used in the final evaluation of remedial alternatives
generally after the lead agency has received public comment on the RI/FS and Proposed Plan.

8. State acceptance addresses the state's position and key concerns related to the selected remedy and
other alternatives, and the state's comments on ARARs or the proposed use of waivers.

9. Community acceptance addresses the public's general response to the alternatives described in the
Proposed Plan and RI/FS.

A detailed assessment of each alternative according to the nine criteria is presented in Table 12.

Following the detailed analysis of each individual alternative, a comparative analysis, focusing on the
relative performance of each alternative against the nine criteria, was conducted. This comparative
analysts is included in Section 6 of the FS.

-------
B. Discussion of Alternatives

The following subsections present the nine criteria and brief narrative summaries of the alternatives and
the strengths and weaknesses according to the detailed comparative analysis.

Overall Protection of Human Health and the Environment-Successful application of Alternatives S4 (Options
A, B, and C); S5 (Options A and B); and S6 would provide the highest level of overall protection by
preventing direct contact with and ingestion of contaminants in site soil. Under these alternatives, the
soil contaminants would be removed and treated on-site, treated off-site, or disposed of off-site.
Alternative S4-Options A and C and Alternative 35-Options A and B would reguire treatability testing
and/or pilot testing to determine whether cleanup goals would be achieved.

Alternative S3 also provides protection, but at a lesser level than Alternatives S4 through S6. Under
Alternative S3, protection is provided by a cap, which would prevent direct contact with contaminated
soil, however, contaminants would remain in-place, and protection would depend on continued cap
maintenance. Under Alternative S2, protection of human health would be achieved through certain measures
already taken to prevent people from coming into direct contact with and possible ingestion of
contaminated materials at the site, provided such measures are maintained and/or improved. However,
risks to the environment would not be controlled through such security measures, therefore, Alternative
S2 would provide a minimal level of overall protection. Alternative SI provides no level of overall
protection.

Compliance with ARARs-There are no chemical-specific ARARs for this site because there are no
promulgated soil cleanup standards. All of the alternatives meet the location- and action-specific ARARs
(if applicable).

-------
Table 12
Comparison of Soil Alternatives
Overall Protection of
Human Health and the
Environment
Compliance with
ARARs
Alternative S4 Alternative S4
Option A Option B

Alternative SI
No Action
Would fail to
achieve
remedial action
obj ectives for
contaminated
soils.

None .
Not applicable .

Alternative S2
Institutional
Controls
Would fail to
achieve
remedial action
obj ectives for
contaminated
soils .

None.
Would meet
location-
specific
ARARs.
Alternative S3
Capping of
Soils
Would protect
human health
and the
environment by
preventing direct
human receptor
contact with
risk-based soils .
None.
Would meet
location-specific
ARARs.

Treatment
Using On-Site
Incineration
Would protect
human health
and {he
environment by
permanently
destroying all
soil
contaminants .
None.
Would meet
locat ion- sped fie
ARARs.

Treatment
Using Off-Site
Incineration
Would protect
human health
and the
environment by
permanently
destroying all
soil
contaminants .
None.
Would meet
locat ion- sped fie
ARARs .

Treatment Using
Thermal
Desorption
Would protect
human health and
the environment by
permanently
removing
contaminants from
site soil.

None.
Would meet
location-specific
ARARs .

Not applicable.
Not applicable.
Would meet
act ion-sped fie
ARARs.
Alternative S4
Option C
Treatment Using
Chemical
Oxidation
Would protect
human health and
the environment by
permanently
destroying
soils.

None.
Would meet
location-specific
ARARs .
Would meet action-
specific ARARs.
Alternative S5
Option A
Treatment
Using Solvent
Extraction
Would protect
human health
and the
environment by
extracting
from soils.

None.
Would meet
location-specific
ARARs .
Would meet
act ion -sped fie
Alternative S5
Option B
Alternative S6
Off-Site Disposal
or Reuse
Would protect
human health and
the environment by
removing
contaminated soils
disposing of them ir
an approved
landfill.
None.
Would meet
location-specific
ARARs.
Would meet action-
specific ARARs.

-------
Table 12
Comparison of Soil Alternatives
(Continued)
Adequacy and
Reliability of
Controls
Not applicable.
Magnitude of
Residual Risk
Not adequate to
meet remedial
action
obj ectives for
contaminated
soils .

No reduction in
risk to
ecoloqical
receptors .

Asphalt cap
would require
lonqterm
maintenance
commitment and
institutional
controls .

Residual risk
would be
minimized as
lonq as cap is
properly
maintained .

Soil
contaminants
would be
destroyed by
incineration,
thereby
eliminatinq the
need for lonq
term controls .
Risk would be
reduced to
backqround
levels of
contaminants
(within NCP
acceptable
levels ) .
Soil
contaminants
would be
destroyed by
incineration,
thereby
eliminatinq the
need for lonq
term controls .
Risk would be
reduced to
backqround
levels of
contaminants
(within NCP
acceptable
levels ) .
Soil contaminants
would be removed
and treated
separately, thereby
eliminatinq the
need for lonq-term
controls .

Risk would be
reduced to
backqround levels
of contaminants
(within NCP
acceptable levels) .

Soil contaminants
would be destroyed
by chemical
oxidation, thereby
eliminatinq the
need for lonq-term
controls .

Risk would be
reduced in
backqround levels
of contaminants
(within NCP
acceptable levels) .

Soil
contaminants
would be
extracted,
thereby
eliminatinq the
need for lonq-
term controls .

Risk would be
reduced to
backqround
levels of
contaminants
(within NCP
acceptable
levels ) .
Contaminated soils
would be removed
from the site;
however disposed
of soils would have
to be manaqed in a
landfill indefinitely
Risk would be
reduced to
backqround levels
of contaminants
(within NCP
acceptable levels).
Treatment Process
Used and Materials
Treated
Not applicable.
Not applicable.
An asphalt cap
would provide a
physical barrier
preventinq direct
human receptor
contact with
risk-based
contaminated
soils.
Incineration
would
permanently
remove
contaminants of
concern by
thermal
destruction.
Incineration
would
permanently
remove
contaminants
concern by
thermal
destruction.
Thermal desorption
would permanently
remove
contaminants from
site soil to be
treated or
destroyed
separately.
Solvent
extraction would
permanently
remove soil
contaminants and
subsequently
treat them.
Excavation and of f-
site disposal would
not treat or destroy
contaminants but
would limit their
mobility.

-------
Not  applicable.
                  All soil
                  contaminants
                  would remain.
                                                                Table 12
                                                 Comparison of  Soil  Alternatives
                                                                (Continued)
                                                       Alternative S4
                                                                         Alternative S4
                                                                                            Alternative S4
All soil
contaminants of
concern would

Toxicity,
mobility, and
volume of
contaminants
would be
virtually
eliminated .



All soil
contaminants of
concern will be

Toxicity,
mobility, and
volume of
contaminants
will be virtually
eliminated.




Soil contaminants
of concern would
be removed and

Toxicity, mobility .
and volume of
contaminants
would be virtually
eliminated .





Soil contaminants
would be
permanently

Toxicity, mobility,
and volume of
contaminants would
be significantly
reduced.





Soil
contaminants
would be
soil and treated
Toxicity,
mobility, and
volume of
contaminants
would be
significantly
reduced through
removal of
contaminants
f r om site soil.
                                                                                                                                   None .
                                                                                                                                   Contaminated soils
                                                                                                                                   would not be treated
                                                                                                                                   but would be
                                                                                                                                   contained.

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Table 12
Comparison of Soil Alternatives
(Continued)
Alternative SI
No Action
Alternative S4
Option A
Treatment
Using Off-Site
Incineration
Alternative S4
Option B
Treatment Using
Thermal
Desorption
Protection of
Community
During
Implementation
Not applicable.
Institutional
controls would
restrict direct
contact with
soils.
Erosion and
s edimentat ion as
well as dust
controls would
be implemented
during paving
operations .
Heavy truck
traffic would
result .
Erosion and
sedimentation as
well as dust
controls would
be implemented
during
excavation .
Heavy truck
traffic would
result .
Erosion and
s edimentat ion
well as dust
controls would be
implemented
during
excavation.

Erosion and
sedimentation as
well as dust
controls would be
implemented
during excavation.

Erosion
well as
controls
be imple
and
dust
would
mented
during excavation .

Erosion and
as well as dust
would be
implemented
during
excavation. He a
truck traffic w
result .

controls

vy
ould

Protection of
Workers
Not applicable.
Not applicable.
Workers would be
adeguately
protected during
soil remediation.
Workers would be
adeguately
protected during
soil remediation.
Workers would
be adeguately protected
during soil
remediation.
Implementability
Not applicable.
Mobile
incinerators are
widely used and
easily
constructed and
operated. Test
burns would be
reguired.
Thermal desorption
units are
c omme r c i a11y
available and
easily operated.
Pilot tests would
be reguired.
Solvent
extraction units
are commercially
available and
easily installed
and operated.
Excavation
site disposal
easily implemented
through regular
excavation
activities.
Not applicable.
Not applicable.
Easily
performed.

-------
Not applicable.
Table 12
Comparison of Soil Alternatives
(Continued)
Alt
Ability to Monitor
Effectiveness
Not applicable.
Cap would be
periodically
inspected for
signs of
deterioration and
damage .
Treated soils and
site excavations
would be tested
to ensure that
treatment
standards are
met .
Treated soils and
site excavations
would be tested
to ensure that
treatment
standards are
met .
Treated soils and
site excavations
would be tested to
ensure that
treatment standards
are met.
Treated soils and
site excavations
would be tested to
ensure that
treatment standards
are met.
Treated soils and
site excavations
would be tested
to ensure that
treatment
standards are
met .
Confirmatory
sampling would
ensure complete
removal of
contaminated soil .
Not applicable.
Materials are
readily available.
Materials are
readily available.
Materials are
readily available.
Materials are
readily available.
Materials are
readily available.
Approval by a
landfill may be
difficult to obtain
Not applicable.
Not applicable.
Readily
available.
Readily available.
Not needed.

-------
Not considered
to be
acceptable
Does not
represent a
permanent
solution .
Not considered
to be
acceptable .
Does not
represent a
permanent
solution .
Not considered
to he accept abl'
Does not
represent a
permanent
solution .

                  Table 12
Comparison  of  Soil  Alternatives
                 (Continued)
         Alternative  S4
         Option A
        Treatment
         Using Off-Site
         Incineration
Alternative S4
Option B
Treatment Using
Thermal
Desorption

Is considered  to be
acceptable.
Represents a
permanent
solution.

-------
Long-Term Effectiveness and Permanence—Successful application of Alternatives S4 (Options A, B, and C);
S5 (Options A and B); and S6 provides a similar degree of long-term effectiveness and permanence because
all material that results in unacceptable risk based on intended use is removed and either treated
on-site or taken off-site for treatment or disposal. Alternative S3, which isolates, contaminants
beneath a cap, provides a lesser degree of effectiveness and permanence, because effective containment of
contaminants depends on continued cap maintenance. Alternatives SI and S2 are the least effective and
permanent of all alternatives evaluated because contaminants remain in-place. For Alternative S2,
exposure is controlled only through continued implementation of security measures at the site. There is
no level of controlling exposure for Alternative SI.

Reduction of Toxicitv, Mobility, or Volume Through Treatment-Only Alternatives S4 and S5 reduce toxicity,
mobility, or volume to some extent, as these are the only alternatives that revolve treatment.
Successful application of Alternative S4-Options A and B and Alternative 35-Option A would provide the
greatest level of reduction because they involve destruction of site contaminants Alternative S4-Option C
and Alternative 35-Option B provide a lesser degree of reduction because contaminants would be separated
from the soil and require additional treatment or disposal. Alternatives SI, S2, S3, and S6 do not meet
this criterion because they do not include treatment. Alternatives S3 and S6 reduce contaminant mobility
although no treatment is performed. Alternatives SI and S2 do not reduce contaminant mobility.

Short-Term Effectiveness-All of the alternatives retained for detailed analysis in the FS would be
effective in the short term. Alternatives SI and S2 would not have significant short-term impacts
because no active remedial measures would be taken. However, because of the potential for release of
contaminants during the excavation activities under Alternatives S3 through S6, special engineering
precautions would be taken to minimize the potential for contaminant emissions to ensure short-term
protection of workers and area residents during cleanup-related construction activities. Some risk may
be imposed on the community because of heavy truck traffic around the site. This would be required for
Alternatives S3 through S6 to mobilize for excavation activities; Alternative S4-Options A and C and
Alternative 35-Options A and B to transport on-site treatment equipment to the site; and Alternatives S3,
and S4-Option B, and S6 to transport contaminated soil from the site. Impacts from truck traffic can be
minimized by using only truck routes for transportation.

Prior to implementation of an alternative, the Army estimates that the time to complete documents
required by the FFA between the Army and EPA and to complete the procurement process will be
approximately 18 to 24 months. This time frame has been included for each alternative in the Estimated
Time for Construction and Design in Section IX of this Record of Decision. This time frame would not be
required for Alternatives SI, S2, or S6. There would be no such requirements for the no action
alternative. For Alternatives S2 and S6, this time frame is approximately 3 months and has been included
in the Estimated Time for Construction and Design in Section IX.

Under Alternative SI, protection would not likely achieve any level of protectiveness in the short-term.
For Alternative S2, an additional 3 months would be required to achieve protection. For Alternative S3,
an additional 7 to 10 months is expected to achieve protection. Alternatives S4 and S5 would both
require design work and/or bench- and pilot-scale testing. After this work is completed, implementation
of Alternative S4 is expected to require 12 to 18 months. Alternative S5 is expected to take
approximately 6 to 8 months to implement. Protection is expected to be achieved for Alternative S6 in
approximately 9 months after completion of procurement.

Implementability-All the options of Alternative S4 may be time consuming to implement as a result of the
trial burns and/or scheduling delays. Alternative 35-Option A is implementable and has been used
successfully at other sites. This option would require a proprietary reagent that is available through
only one vendor. Prior to implementation, treatability tests on the oxidation technology would be
conducted to verify, that the soil cleanup goals can be achieved in a cost-effective manner. Alternative
35-Option B could require multiple pilot studies to establish the best specific solvent to use; there are
several proprietary solvent extraction systems that use different solvents. Alternative 36 is proven and
can be implemented without requiring treatability testing. Implementation could be lengthy because of
the volume of soil and waste that would have to be shipped to a hazardous waste and/or nonhazardous waste
disposal facility Delays in transportation for disposal could be possible. Alternatives SI and 32 do not
have significant implementation issues because no active remedial measures would be taken.

Cost-The capital, O&M, and total costs (present worth) for each alternative are included in Section IX.
For alternatives involving removal and treatment/disposal of contaminated soil, Alternative 35-Option A
and Alternative S6 are the most cost effective with total costs nearly equal for these two options. The
next most cost effective is Alternative 35-Option B, the costs of which are more than twice that of
Alternatives 35-Option A and 36. The least cost effective is Alternative S4-Option B. The costs of
which are nearly 10 times those of Alternatives 35-Option A and S6.

-------
State Acceptance-MADEP has been involved with this site since the beginning of closure activities and has
reviewed the RI/FS and Proposed Plan. MADEP prefers that a permanent solution be selected if the aspects
of the other eight criteria are relatively equal. The selected remedy represents a permanent solution,
and MADEP concurs with the selection of Alternative

Community Acceptance -In general, the community has supported the conclusions ot the RI/FS and the
alternatives presented in the Proposed Plan. The RAB co-chair, the technical advisor to the Watertown
Citizens for Environmental Safety (recipient of the EPA Technical Assistance Grant), and other members of
the community expressed their support, during the public comment period, of the Army's intended remedial
action. In addition, some members of the community expressed a desire to remediate the entire site to
residential standards, rather than the mixed commercial and residential site reuse, which is consistent
with the intended reuse of the site as outlined in the Town-approved Arsenal Reuse Plan.

XI. THE SEIiECTED REMEDY

The selected remedy is soil excavation and off-site disposal/reuse (Alternative S6). This remedy is
described in Section IX. This remedy is comprehensive for site soils.

A. Soil Cleanup Levels

Using the information gathered during the RI/FS, remedial action objectives were identified for cleanup
of the MTL site. The cleanup objective for this site is to minimize the risks to human health and the
environment posed by direct contact with and incidental ingestion of contaminated soils.

To meet this objective, site-specific cleanup levels were established that will be protective of human
health and the environment. These levels were established by calculating risk-based cleanup goals to
comply with the requirements of CERCLA as well as MCP requirements, as discussed in Section VII.

For human health, risk-based goals for 14 different compounds detected in soil were determined. With the
exception of one compound, the risk-based goals were all lower than local background concentrations so
that the actual cleanup goals for these compounds are background levels. The MCP and CERCLA do not
require remediation to below background levels. Background concentrations were determined using soil
data collected from numerous points off-site from the MTL property and from points near or along the
northern property boundary (Arsenal Street).

An EPA-approved statistical evaluation of the background soil data set was used to calculate the 90% UCL.
The UCL calculated for each contaminant was used as the contaminant's background level and hence as the
MTL site cleanup goal. For more detail on the statistical evaluation, refer to Section 2 of the FS. The
compounds for which specific cleanup goals have been set for the MTL site for human health include six
pesticides, seven SVOCs, and one PCB. The one compound for which the background level was not
appropriate was the PCB Aroclor-1260. The cleanup goal for Aroclor-1260 is based on the EPA-issued
cleanup guidance for PCBs at Superfund sites.

For ecological risk, separate cleanup goals were determined for the undeveloped areas of the site for 6
pesticides, 11 SVOCs, 1 PCB, and 8 metals. The derived ecological goals for SVOCs and the PCB were
greater than those cleanup goals established for human health, and/or the ecological cleanup goals
exceeded concentrations detected on-site. Hence, these goals were not used because the greater risk from
these contaminants is to human health. The metals cleanup goals were not included in the remediation
plan, as discussed in Section VII, because on-site metals concentrations are generally consistent with
normal background levels. Any areas with metals contamination posing an unacceptable localized risk will
be handled in the site remediation. For pesticides, instead of applying the cleanup goals sitewide,
specific locations with unacceptable ecological risk were identified and included in the remediation
plan. These areas will be remediated to the ecological cleanup goals for pesticides.

To be consistent with the site RAs, cleanup goals were determined for each site zone. The individual zone
cleanup goals are summarized in Table 13. In the table, a "—" listed as the cleanup goal for a chemical
indicates that the chemical was not a contaminant of concern for that particular zone. The soil cleanup
goals do not differ for the different future uses (i.e., commercial or residential) because background
concentrations are used to set the cleanup goals. The future use scenario does determine which
contaminants are to be remediated in the different zones because the RAs based on commercial and
residential reuse yielded different contaminants of concern.

The locations of soil areas to be remediated are shown in Figure 4. The approximate depth of soil
requiring remediation is 3 ft bgs. The cleanup goals will be achieved within the excavations.

-------
B. Description of Components of Selected Remedy

The selected remedy for soil remediation consists of excavation and off-site disposal or reuse of
contaminated soil. This remedy includes the following:

• Excavation of areas with contaminated soils that are above cleanup goals
• Confirmatory soil sampling within excavations after contaminated soil removal.
• Off-site landfill disposal or reuse of the excavated soil.
• Backfilling of clean fill soils into the excavations.
• Institutional controls with 5-year site reviews.

For this remedy, all soil exceeding cleanup criteria would be excavated. All excavated areas would be
sampled to ensure that cleanup goals are met. Excavated material would be divided into hazardous and
nonhazardous waste. Prior to off-site transport, excavated soil would be staged and covered to prevent
contaminant migration and to protect the stockpiles from wind and rain. All excavated soil would be
disposed of off-site. Hazardous soil would be disposed of at a hazardous waste landfill. Nonhazardous
waste would be disposed of at a nonhazardous landfill and/or asphalt batching facility. The excavations
would be backfilled with clean soil. This remedy would not reguire any treatability testing. This
remedy would reguire substantial trucking for both contaminated soil removal and import of clean soil.
Trucking activities will be coordinated by the Army in conjunction with the Town of Watertown and other
pertinent officials to ensure that proper truck routes are used and optimal trucking operation hours
established to minimize any traffic disruption for the community.

Institutional controls for this site would be deed restrictions, which will be necessary only in the
areas slated for commercial reuse where the level of cleanup is not as stringent as for areas remediated
to residential use or public use as well as for contaminated soil underneath buildings that will not be
remediated. The deed restrictions would prevent the use of areas remediated to commercial reuse levels
for uses other than commercial. The restrictions also would not allow the demolition of buildings under
which soil contamination above cleanup goals was detected without proper handling of any contaminated
soils (i.e., excavation and disposal). To the extent reguired by law, EPA and the Army will review the
site at least once every 5 years after the initiation of remedial action at the site for the areas where
any hazardous contaminants remain to ensure that the deed restrictions continue to protect human health
and the environment. Specifically, the reviews will be performed to determine if deed restrictions are
effective and that land use has not changed.

-------
    Chemical
       Zone 1
Commercial Reuse
        (mg/kg)
Benzo(a)anthracene

Benzo(a)pyrene

Benzo(b)fluoranthene

Benzo(k)fluoranthene

Chlordane

Chrysene

4,4'-DDD

4,4'-DDE

4,4'-DDT

Dibenz(a,h,)anthracene

Dieldrin

Heptachlor epoxide

Indeno(1,2,3-cd)pyrene

Aroclor-1260
          Table  13

MTL Site Soil Cleanup Goals  *

         Zone 2             Zo
Commercial  Reuse      Resident
        (mg/kg)                i


         8.5

         2.0

         7.9

         6.2
                                 3.0
.e 3
al Reuse
ng/kg)
8.5
2.0
7.9
6.2
1.5
11.1
-
-
-
2.7E-01
_
Zone 4
Public Access
(mg/kg)
8.5
2.0
7.9
6.2
1.4
11.1
13.7
1.4E-01
1.7E-01
-
3.5E-01

River Park
(mg/kg)
8.5
2.0
7.9
6.2
1.4
11.1
13.7
1.4E-01
1.7E-01
2.7E-01
3.5E-01
                                                      3.0

                                                      1.0
                                                     3.0

                                                     1.0
                                                                                            3.0
*The cleanup goals correspond to soil background concentrations, with the exception of Aroclor-1260, which is based on EPA guidance.
Pesticide cleanup goals for Zone 4 Public Access and River
Park are based on ecological risk.

-------
XII. STATUTORY DETERMINATIONS

The remedial action selected for implementation at the MTL site is consistent with CERCLA and, to the
extent practicable, the NCP. The selected remedy is protective of human health and the environment,
attains ARARs, and is cost effective. The selected remedy does not satisfy the statutory preference for
treatment that permanently and significantly reduces the mobility, toxicity, or volume of hazardous
substances a principal element. The selected remedy uses resource recovery 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 permanently reduce the risks posed to human health and the
environment by eliminating, reducing, or controlling exposures to human and ecological receptors through
soil excavation and off-site disposal/reuse. Institutional controls will be used for any soil areas not
remediated to residential reuse cleanup levels. Deed restrictions, as discussed earlier, will be placed
on the property at the time of transfer.

Moreover, the selected remedy will achieve a maximum level of protection of human health and environment
for the intended future site reuse to the extent allowable by CERCLA and the NCP. The site soil cleanup
goals to be achieved are background levels (with the exception of PCBs, which are based on EPA guidance).

B. The Selected Remedy Attains ARARs

This remedy will attain all applicable or relevant and appropriate federal and state reguirements that
apply to the site. The principal environmental laws from which ARARs are derived and the specific ARARs
include:

• Resource Conservation and Recovery Act.
Clean Air Act.
• Federal Protection of Floodplains Executive Order.
• National Historic Preservation Act.
• Archaeological and Historic Preservation Act.
• Massachusetts Hazardous Waste Management.
• Massachusetts Solid Waste Management.
• Massachusetts Air Pollution Control.
• Massachusetts Historical Commission Regulations.

The following policies, criteria, and guidances are to be considered (TBC) criteria for implementation of
the remedial action:

EPA Risk Reference Doses.
• EPA Carcinogen Assessment Group Potency Factors.
• Guidance on Remedial Actions for Superfund Sites with PCB Contamination.
• Test Methods for Evaluating Solid Waste and Physical/Chemical Methods.
• Massachusetts Policy on Allowable Sound Emissions.

A tabular summary of the ARARs and TBCs for the selected remedy is included in Appendix D.

C. The Selected Remedy Is Cost Effective

The selected remedy is cost effective, i.e., the remedy affords overall effectiveness proportional to the
costs. In selecting the remedy, once the Army identified alternatives that are protective of human health
and the environment and that attain, or, as appropriate, waive ARARs, the Army evaluated the overall
effectiveness of each alternative by assessing the relevant three criteria-long-term effectiveness and
permanence; reduction in toxicity, mobility, and volume through treatment; and short-term effectiveness.
The costs of the selected remedy are:

Estimated Time for Design and Construction: 6 months.
Estimated Time of Operation: 6 to 9 months.
Estimated Capital Cost: $5,741,000.
Estimated Operation and Maintenance Cost (30-year net present worth):$27,000
Estimated Total Cost (net present worth): $5,768,000.

In evaluating the remedial alternatives, for those alternatives that achieved the maximum extent of
overall protection of human health and the environment, the selected remedy had the lowest costs to
achieve the same results.

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

Once the Army identified those alternatives that attain or, as appropriate, waive ARARs and are
protective of human health and the environment, the Army identified the alternatives that use permanent
solutions and alternative treatment or resource recovery technologies to the maximum extent practicable.
This determination was made by deciding which of the identified alternatives provides the best balance of
trade-offs among alternatives in terms of: 1) longterm effectiveness and permanence; 2) reduction of
toxicity, mobility, or volume through treatment: 3) short-term effectiveness; 4) implementability; and 5)
cost. The balancing test emphasized long-term effectiveness and permanence and the reduction of
toxicity, mobility, and volume through treatment and considered the preference for treatment as a
principal element, the bias against off-site and disposal of untreated waste, and community and state
acceptance.

The selected remedy provides the best balance of trade-offs among the alternatives. When compared to
other alternatives that provide an equal level of overall protection as the selected remedy (Alternatives
S4 through S6), the selected remedy is similar to the other alternatives in relation to short-term
effectiveness, long-term effectiveness, and the attainment of ARARs. With regard to reduction of volume,
mobility, and toxicity of the contaminants, the selected remedy does not meet this criterion as no
treatment is included; however, this remedy includes reuse of the excavated soil to the maximum extent
possible for a nontreatment remedy (i.e., nonhazardous soil is reused). Alternative S4-Options A and B
and Alternative 35-Option A provide the highest level of reduction because the contaminants are
destroyed. Alternative S4-Option C and Alternative 55-Option B provide a lesser level of reduction
because the contaminants are separated from the soil but would require further treatment.

In terms of implementability, all these alternatives, except the selected remedy and Alternative
S4-Option B, would require some form of bench-scale treatability testing and/or pilot-scale tests. All
these alternatives would require the same implementation procedures for soil excavation and staging. The
selected remedy and Alternative S4-Option B are the most easily implemented because they require only the
off-site transportation of excavated soil for treatment or disposal.

For the remaining on-site treatment alternatives, Alternative 35-Option A is the most easily implemented
because this remedy requires the least amount of treatability testing and because its on-site treatment
system is the simplest to construct and operate. This results in shorter mobilization duration and a
lower frequency of potential equipment failure causing temporary system shutdown. However, all
alternatives that require treatability studies have the potential risk of not being able to achieve the
desired cleanup goals. This is especially true for the more innovative soil treatment approaches of
Alternative 35-Options A and B.

The selected remedy also is cost effective for the alternatives that can achieve overall protection of
human health and the environment. The present-worth cost of the selected remedy ($5,768,000) is almost
the same as the most cost-effective alternative, which is Alternative 35-Option A ($5,583,000).
Present-worth costs of the remaining alternatives range from $11,855,000 for Alternative S5-Option B to
$51,060,000 for Alternative S4-Option B.

In selecting the selected remedy, the factors that were the most determinative in the decision were
implementability and cost-effectiveness. The selected remedy provided the lowest overall remediation
cost, while also being the easiest and quickest to implement. Whereas similar remediation costs could be
achieved for Alternative S5-Option A, this alternative could not be implemented as quickly as the
selected remedy. Also, treatability tests for the alternative could have concluded that the remediation
technology could not have achieved the desired goals, or could not have done so in a more cost-effective
manner than the selected alternative. Both the state and the community concur with the selected remedy.

While the selected remedy does not achieve a reduction of toxicity, mobility, or volume of contaminants
through treatment, this factor is outweighed by the level of the cost-effectiveness and implementability
the selected remedy affords. In addition, the state and community support this remedy.

E. The Selected Remedy Does Not Satisfy the Preference for Treatment That Permanently and Significantly
Reduces the Toxicitv, Mobility, or Volume of the Hazardous Substances as a Principal Element

The statutory preference for treatment as a principal element is not satisfied by the selected remedy,
because this remedy results in off-site disposal/reuse of contaminated soil. The fact that the selected
remedy does not meet this statutory preference did not exclude this alternative from selection because
there were no other equally cost-effective and easily implemented alternatives that could achieve the
maximum extent of overall protection of human health and the environment. The selected remedy will
result in reduction in mobility of contaminants through soil reuse in landfill or through immobilization
as reuse in asphalt batching.

-------
XIII. DOCUMENTATION OF SIGNIFICANT CHANGES

The Army presented a Proposed Plan (preferred and contingency alternatives) for remediation of the site
on April 16, 1996. The preferred alternative (Alternative 35-Option A) presented at that time included:

• Excavation of areas with contaminated soils that are above cleanup goals. The excavated
soils would be stockpiled on-site until treatment. Stockpiles would be managed to prevent
contaminated soil migration.
• Treatment of the excavated soil on-site using chemical oxidation.
• Backfilling of the treated soils into the excavations.
• Institutional controls with 5-year site reviews.

The contingency alternative was Alternative S6 (the selected remedy in this Record of Decision) and
included:

• Excavation of areas with contaminated soils that are above cleanup goals. Off-site landfill
disposal or reuse of excavated soil.
• Backfilling of clean fill soil into the excavations.
• Institutional controls with 5-year site reviews.

There are three significant changes from the Proposed Plan in this Record of Decision:

1. The Army has changed the recommended alternative for selection from the preferred alternative in the
Proposed Plan (Alternative S5-Option A) to the selected remedy (Alternative S6). The change in remedy
selection was due to two factors; cost of remediation for Alternative S6 and the Town of Watertown's
desire for a more expedited remediation schedule.

Subseguent to the release of the Proposed Plan, as part of the predesign effort, soil samples were
collected from the specific areas that reguire remediation. Toxicity Characteristic Leaching
Procedure (TCLP) analysis was performed on these samples to determine if excavated soils from
remediation would be classified as a Resource Conservation and Recovery Act (RCRA) and state
hazardous waste. The results of this testing indicated that only samples from Area M (Yacht Club)
would be a characteristic hazardous waste based on lead. Based on the testing results, all remaining
soil to be excavated is considered nonhazardous for disposal purposes.

This new information has resulted in a substantial change in the estimated cost of the off-site
disposal/reuse alternative. The original estimate assumed 50% of the excavated soil would be
classified as hazardous waste. A new cost estimate has been prepared assuming all soil, except Area
M would be disposed of as nonhazardous waste. Keeping all other cost estimate assumptions the same
as the original estimate the cost of implementing the selected remedy has been reduced to
approximately $5,741,000 (from the original $10,700,000). The selected remedy cost estimates in
Sections IX and XIII in this Record of Decision have been revised from the Proposed Plan to account
for this soil classification data. More specific information on the analytical data and the new cost
estimate is provided in Appendix C.4 and in the Administrative Record.

A meeting was held on August 8, 1996 to explain this information to members of the public. As a
result of the change in remediation cost for the selected remedy, members of the community have
reguested that the Army implement the selected remedy. In a letter dated August 14, 1996 from the
Arsenal Reuse Committee, a reguest was made to implement the selected remedy because this would allow
the soil remediation to be completed 1 year in advance of the original schedule for implementation of
Alternative S5-Option A. This would allow, for optimal economic redevelopment potential of the site
for the town, the transcript of the August 8, 1996 meeting and public comment letters received are
included in Appendix C.4.

2. The second change affects the amount of soil to be remediated. Based on several public comments to
have the entire site remediated to residential levels instead of the mixed commercial and residential
reuse identified in the Reuse Plan, the Army has decided to increase the level of remediation in two
areas of concern in Zone 2 from commercial cleanup goals to residential cleanup goals. These two
areas are shown in Figure 4 as Areas F and T.

Area F was previously identified as an area of concern for commercial cleanup; under this Record of
Decision, this area will be remediated to residential cleanup goals. Although this does not change
the estimated soil remediation volume for this area. The number of contaminants of concern in this
area is increased from four to 11.

-------
Area T is an area that was not included for remediation in the Proposed Plan because no contaminants
in this area exceeded the commercial cleanup goals. However, for the residential reuse scenario,
this was an area of concern. This area was previously delineated in the FS for site residential
reuse as Area H (see Figure 3-2 of the FS). Adding this area to the total remediation volume will
result in an estimated increase in soil volume of 800 yd3. This also results in an increase in the
cost estimate for remediation. The remediation alternative cost estimates and the selected remedy
cost estimates in Sections IX and XII in this Record of Decision have been revised from the Proposed
Plan to account for this increase in soil volume.

3. The third change refers to a change in the Accelerated Action for Area I/Building 131 vicinity and
Area M Yacht Club Tank Area) as discussed in the Proposed Plan. This Accelerated Action was to
involve the separate remediation of Areas I and M as shown in Figure 4. The Area I accelerated
action was deemed necessary to facilitate an anticipated transfer of Building 131 to the
Massachusetts College of Professional Psychology in the spring of 1997. At the same time. The Yacht
Club reguested that the soil at Area M be remediated early to allow them to replace a UST used to
store fuel for their boats. These two actions were included in the Proposed Plan as the Accelerated
Action.

The Accelerated Action could result in a slight overall increase in site remediation cost to the
Army. Because of the replacement of the UST. The Army Materiel Command Legal Office reguested that
Area M be deleted from the Accelerated Action and be included in the overall remedial action.
Therefore, the Record of Decision signed on June 28, 1996 for the Accelerated Action included Area 1
only. The remediation of Area M is included under this Record of Decision.

XIV. STATE ROIiE

MADEP has reviewed the various alternatives and has indicated its support for the selected remedy. The
state also has reviewed the RI/FS (including the RA) to determine whether the selected remedy is in
compliance with applicable or relevant and appropriate state environmental laws and regulations. MADEP
concurs with the selected remedy for the MTL site. A copy of the Declaration of Concurrence is included
in Appendix B.

-------
                             APPENDIX A
                     ADMINISTRATIVE RECORD INDEX
US.  Army  Materials  Technology  Lab
Watertown,  Ma
Administrative   Record
DOC. #      DESCRIPTION

       FACTUAL  INFORMATION
 AUTHOR
                       DATE
1.     Preliminary Assessment Site Inspection
2.     Technical Plans for USAMTL Remedial Investigation and Feasibility Study
3.     USAMTL Remedial Investigation (Volume I and II)
4.     Final Phase II Remedial Investigation Report (Volume I through III)
5.     Final Phase II Remedial Investigation Report (Volume I through V)
6.     Baseline Risk Assessment Environmental Evaluation
7.     Final Terrestrial Risk Assessment
8.     Final Feasability Study Report (Outdoor)  (Volume I and II)
9.     Draft Addendum to Human Health Evaluation
10.    Feasibility Study for Base Closure RI/FS Responsiveness Summary
11.    Feasibility Study for Base Closure RI/FS Responsiveness Summary
12.    Final Proposed Plan
13.    Draft Final Proposed Plan for Base Closure Responsiveness Summary
14.    USAMTL Remedial Investigation Responsiveness Summary
15.    Phase II Remedial Investigation Comments
16.    Terrestrial Ecological Risk Assessment Comments
17.    Terrestrial Ecological Risk Assessment Response to Comments
18.    Feasibility Study Comments
19.    Proposed Plan Comments
20.    Community Comments on Residential vs. Commercial Cleanup Standard
21.    Phase I Remedial Investigation Report
22.    Community Environmental Response Facilitation Act Report
23.    Final Hazard Ranking Package for AMTL
24.    Federal Facilities Agreement
25.    Phase I RI Comments
26.    Army Regulation 200-1, Environment Protection and Enhancement,
       and 200-2, Environmental Effects of Army Actions
E G&G Idaho Inc
E G&G Idaho Inc
E G&G Idaho Inc
Roy F. Weston
       Weston
       Weston
       Weston
       Weston
       Weston
       Weston
       Weston
       Weston
       Weston
       Weston
Roy F.
Roy F.
Roy F.
Roy F.
Roy F.
Roy F.
Roy F.
Roy F.
Roy F.
Roy F.
NONE
NONE
Roy F. Weston
NONE
NONE
NONE
Roy F. Weston
Environ. Res. Mgt.
Halliburton Nus
EPA/Army
NONE
Army
Army
3/88
5/88
9/89
12/93
5/94
12/93
8/95
1/96
2/96
11/95
1/96
4/96
4/96
4/93
MISC.
MISC.
6/95
MISC.
MISC.
MISC.
4/91
4/94
4/93
5/95
MISC.
5/90, &
12/88

-------
DOC. #
DESCRIPTION
AUTHOR
DATE
PUBLIC PARTICIPATION

27. BRAG Cleanup Plan Guidebook
28. Base Realignment and Closure Plan Version I
29. Base Realignment and Closure Plan Version II
30. Comments on BCP
31. Media Coverage
32 . Site Tour Handouts
33. Site Tour Handouts
34. Site Tour Handouts
35. Site Tour/Information Session Handouts
36. Information Session- Outdoor Remediation
37. Community Relations Mailing List
38. Restoration Advisory Board Meeting Dates
39. Project Team Meeting Dates
40. Public Involvement and Response Plan
41. Community Relations Plan
42. LTC Blose's Brief to Reuse Committee
43. Public Hearing Proposed Plan Transcript and Comments

OTHER INFORMATION
Dept. of Defense
Earthtech
Earthtech
NONE
NONE
NONE
NONE
NONE
Army
Army
Army
Army
Army
Roy F. Weston
Roy F. Weston
Army
Army
10/93
3/94
3/95
MISC.
MISC.
6/94
10/94
6/95
1/96
4/96
MISC.
MISC.
MISC.
2/92
5/95
4/96
5/96
44. Trustee Notification Letters
45. Watertown Arsenal Reuse and Feasibility Study (Town Reuse Plan)
46. EIS for Disposal and Reuse
47. Public Health Assessment for MTL
48. Health Consultation for MTL
49. Guidance List
50. OSWER Directive 9355.7-04 Land Use in the CERCLA Remedy Process
51. Technical Memorandum for Area I
Army
Goody-Clancy
Jaycor
AT SDR
AT SDR
None
EPA
Army
7/94
11/93
9/95
2/96
3/96
N/A
5/95
6/96

-------

                                                                APPENDIX B
                                           MASSACHUSETTS DEPARTMENT OF ENVIRONMENTAL PROTECTION
                                                      DECLARATION OF CONCURRENCE
                                         COMMONWEALTH OF MASSACHUSETTS
                                         EXECUTIVE OFFICE OF ENVIRONMENTAL AFFAIRS
                                       DEPARTMENT OF ENVIRONMENTAL PROTECTION
                                         ONE WINTER STREET, BOSTON MA 02108  (617) 292-5500
WILLIAM F. WELD
Governor
TRUDY COXE
 Secretary
ARGEO PAUL CELLUCCI
Lt.  Governor
DAVID B. STRUHS
Commissioner
                                                          September 20, 1996

Linda Murphy
Director,  Waste Management Division
U.S. Environmental Protection Agency
Region I, JFK Building
Boston, MA 02203-2211

RE:    Materials Technology Laboratory; Watertown, MA
       Soil and Groundwater Operable Unit

Dear Ms. Murphy:

The Massachusetts Department of Environmental Protection  (Department) has reviewed the September 18, 1996
Record of Decision (ROD) regarding the Soil and Groundwater Operable Unit.  The Department has reviewed
the Army's selection of off-site disposal  (the back-up remedy contained in the Proposed Plan) as the
selected remedial action for its consistency with Massachusetts General Law Chapter 21E and the
Massachusetts Contingency Plan.  Based upon this review, the Department concurs with the selected
remedial action.  The selected remedial action will be protective of human health, welfare and the
environment for the Soil and Groundwater OU areas.  Additionally, the selected remedial action will meet
state ARARs, provide the Watertown community with a timely transfer of the AMTL property, and will be
cost effective.

The selected remedial action will have the following components:

       1)     Excavation of contaminated soils;
       2)     Characterization of soil contaminants to determine appropriate disposal methods;
       3)     Transportation of soils off-site for recycling,  reuse,  or disposal;
       4)     Backfilling of remediated areas with clean soil;

Based on evaluation of information gathered during remedial investigations, no groundwater remediation is
reguired.

The Town of Watertown's reguest for the use of the Proposed Plan's contingency remedy as the selected
remedy was based on its need for the earliest possible transfer of AMTL property and the Army's updated
cost estimates for off-site disposal of contaminated soils.  The transportation routes for the disposal
of contaminated soils will be based on Town input and all other applicable regulations.  The cleanup plan
for the site is consistent with local reuse plan and will reguire the implementation of institutional
controls for those areas that are not available for unrestricted future use.
The Department looks forward to working with EPA and the Army in this common endeavor and we are pleased
to assist in the transfer of Army property in a manner that is protective of human health, welfare, and
the environment.  If you have any guestions please feel free to contact me at  (617) 292-5648.

-------

              Mr.  Steven Ward,  Watertown Board of Health
              Mr.  John Airasian,  Chairman Watertown Reuse Committee
              Honorable Warren Tolman,  State Senator
              Honorable Rachel Kaprielian,  State Representative
              Mr.  Matt O'Neill,  Office  of the Honorable Joseph P.  Kennedy II
              Ms.  Megan Cassidy,  Environmental Protection Agency
              Mr.  Robert Chase,  AMSRL-OP-RK-WT
              Mr.  Steve Johnson,  DEP BWSC - NERO

-------
APPENDIX C

PUBLIC COMMENTS AND RESPONSIVENESS SUMMARY

APPENDIX C.I

COMMENT RESPONSIVENESS SUMMARY

Comments were received from the public both during the 30-day public comment period and during the formal
public hearing on the Proposed Plan. Comment letters are presented in Appendix C.2. The transcript of
the public hearing is included as Appendix C.3. There were four main concerns voiced in the comments
received. They are summarized as follows:

1. Comment: Three commentors supported the Proposed Plan with the addition of residential cleanup
standards applied to Areas F and T as mentioned by Lieutenant Colonel Todd Blose in meeting with the
Watertown Reuse Committee on April 29, 1996.

Response: While this comment does not reguire a response, it should be noted that the two areas were
added after the issuance of the Proposed Plan. The areas will be included in the list of Significant
Changes in the Record of Decision.

2. Comment: Five commentors did not agree that the proposed cleanup standards based on mixed reuse
were protective of human health and wanted all of the soil to be remediated to residential standards.

Response: We disagreed with their conclusion. The cleanup standards were based on the proposed reuse of
the facility as set by the Town's Reuse Plan. These standards have been reviewed by the Army's Center
for Health Promotion and Preventive Medicine, who have determined that they are protective of human
health based on the proposed mixed reuse of the facility. The Massachusetts Department of Environmental
Protection (MADEP) and the U.S. Environmental Protection Agency (EPA) Region I are reviewing the Army's
proposal for cleanup. They must concur with the final cleanup standard that will be provided in the
Record of Decision. Their preliminary comments on the FS and Proposed Plan are that for the proposed
mixed reuse of the facility, the proposed remediation will be protective of human health.

3. Comment: The commentors also stated that additional housing is needed in the town and that the
proposed cleanup for mixed reuse would not allow the town to use the property for residential housing.

Response: The Army was not involved in the development of the Reuse Plan. It was developed and approved
solely by the town. The town has indicated to the Army that it would like the property to be transferred
under an economic development conveyance to allow for commercial development. We would like to note that
the town's Reuse Plan examined the feasibility of converting the existing structures into residential
housing. With the exception of Building 39, all of the buildings cited as being suitable for residential
housing are now included in areas being cleaned up to residential standards.

The imposition of reuse restrictions does not prevent the town from redeveloping the property for
residential use in the future. At that time, the town or developer could petition MADEP and EPA to
remove the restrictions.

4. Comment: A comment was raised that because of the town's past experience with redeveloping
previously excessed Army property, remediating to all residential standards would provide a level of
increased comfort to the citizens.

Response: We believe that this would be a misappropriation of taxpayer dollars to do additional cleanup
solely to increase citizens' "comfort." The cleanup is based on independently validated standards for
the protection of human health and the environment. We believe that if this information is accurately
communicated, citizens will feel comfortable with the proposed site cleanup.

One commentor (Rich Rago, Restoration Advisory Board) provided the following three specific comments to
the final Proposed Plan:

5. Comment: Page 6, Section 2: Have the 14 ppm chlorinated solvents that were detected in the well
been confirmed to be from an off-site source? This concentration appears too high for such a suggestion.

Response: The monitor well that contained the 14 ppm concentration of chlorinated solvents was MW-23.
This well is located upgradient of MTL north of Arsenal Street. This well is not located on the
installation. Contamination in this well is from an off-site source(s). Please refer to the RI and/or
FS for more information on groundwater characterization.

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6. Comment: Page 8. Paragraph 1-4: Does the text infer that the soil risk assessments do not
address future use scenarios? Have exposure pathways been considered for the site construction worker or
utility worker? It is inevitable that these activities will occur in the future.

Does the text infer that a GW-2 scenario is, in no case, appropriate for some of the site groundwater?
Has the migration of vapors into site buildings been assessed? I am concerned that an earlier lack of
attention to site groundwater will be a later problem.

Response: In accordance with EPA and MADEP risk assessment reguirements, all applicable potential future
use exposure pathways were assessed. The soil risk assessment assessed exposure for future residents,
commercial workers, construction and utility workers, and public park visitors. Please refer to the
RI/FS for a complete discussion on the risk assessment.

MADEP has classified the groundwater at the MTL site as a GW-3. MADEP has made this classification
because the site groundwater does not meet the Massachusetts Contingency Plan definition for either a
GW-1 or GW-2 aguifer. MADEP has determined that migration of vapors from groundwater into building
basements is not an appropriate exposure scenario based on the groundwater characterization.

7. Comment: Page 9. Paragraph 1-2: Is it reasonable to say that there is a "background
concentration" of pesticides? I understand that PAHs have been associated with urban fills and certain
other soils. It would appear that the appropriate background concentration for pesticides would be "ND."

Response: Determining a background concentration for pesticides is considered appropriate for this site.
No mission operations at MTL involved pesticides; pesticides were used only for weed and insect control.
Pesticides were detected in the background samples collected in Watertown, indicating a widespread usage
of pesticide products in the area for similar reasons as their usage at MTL. Since part of the
regulatory definition of background is contaminant concentrations that would be present to the absence of
the site, it is clear that pesticides would still be present in the absence of the MTL site. EPA and
MADEP concur with this position.

Concern was also expressed about health issues of past MTL workers and long-time Watertown residents near
the MTL site. In response to this concern, the U.S. Department of Health and Human Services Agency for
Toxic Substances and Disease Registry prepared a health assessment for the MTL property. This report was
completed on March 29, 1996. A copy of the report is located in the MTL Administrative Record located at
the installation and at the Watertown Free Public Library.

Additionally, public comments were received relating to reguests for information on the radiation
decontamination of MTL. Information and documents on radiological decontamination for MTL can be found
at the installation and at the Watertown Free Public Library. Also, for more information on this issue
please contact Dennis Waskiewicz at the following address:

U.S. Army Corps of Engineers
New England District
424 Trapelo Road
Waltham, MA 02254-9149

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APPENDIX C.2
WRITTEN PUBLIC COMMENT LETTERS
(MAY 13, 1996)

May 13, 1996

Todd Blose, Colonel, USA
Assistant Chief of Staff
BRAG Installation Management
600 Army Pentagon
Washington, B.C. 20310

Dear Colonel Blose:

As President of the Watertown, Massachusetts Town Council, I write to provide my views, and those of the
Town Council as expressed in an unanimous resolution on February 13, 1996, regarding the cleanup and
reuse of the property known as the Watertown Arsenal site.

In its unanimous resolution, the Town Council voted to reguest the maximum level of cleanup possible.
The Arsenal site represents the last significant property in the entire community, available for
development or redevelopment. It is essential to the Town that it be developed in a careful and planned
way to assure that it contributes to the character of the Town - and, as appropriate to its reuse, to our
tax base. Through our community's re-use committee, the Town has endorsed a mixed-use of commercial,
residential and open space for the site. As President of the Town Council, however, I share the concern
of my colleagues that our principle concern must be for the health and safety of Watertown's residents,
and to those who will one day soon live and work on the site.

Assuring that the site is cleaned to a higher, residential, standard is not a reguest to change the use
of the property. Rather, it is meant to ensure that what is done is what is best for the Town of
Watertown. That is why we have reguested that the United States government bring the clean-up of the
site to the highest standards of the United States Army.

Like others of my colleagues on the Town Council and residents generally, I am disappointed the general
response to the Town Council's resolution. It is our understanding that other bases across the country
must also be cleaned, and from prior service as Assistant to the Secretary of Defense during a major base
realignment, there are only so many dollars to do the job. That said, I feel it my responsibility to the
residents of Watertown to point out once again the clear hope of the town, as represented in the Town
Council's resolution of February 13, 1996. The estimates for the cleanup we would hope for add between
$1.5 and $5 million to the $83 million to be spent on the site. Perhaps there are other economies which,
if considered at the beginning of the project, may allow the clean up to be done at the higher level
within the budgeted amount. If not, it would be our hope that the funding could be found to do the clean
up to the higher residential standards -- especially in a situation where residential use is clearly
among the uses contemplated for the property.

The Town Council and I do appreciate the addition of Areas F and T to the areas to be cleaned to the
higher standard, as an indication of the U.S. Army's understanding of our plight and our plea, and thank
you for that consideration of our resolution.

It is important that as the clean up process moves forward, the Town Council, the re-use committee and --
most importantly, the neighbors and residents of Watertown and surrounding communities can feel confident
that every precaution is taken to protect the health and safety of the people, especially those who live
in the surrounding residences.

Once clean up has been completed, the Town can look forward to the final phases of reuse, which, will
present Watertown great opportunity for business, housing and recreation. Yet, understand, for
generations to come it will still be the Watertown Arsenal to a community which has proudly housed this
important military facility for so may years.

Respectfully submitted,
Sincerely,

cc: Town Council
Clerk of the Council
Town Manager
Arsenal Reuse Committee

-------

TOWN OF WATERTOWN
ADMINISTRATION BUILDING
WATERTOWN, MASSACHUSETTS 02172

ARSENAL REUSE COMMITTEE

May 20, 1996

Mr. Jeffrey Waugh
US Army Environmental Center, Attn: CEAEC-BC
Aberdeen Proving Ground
Aberdeen, MD 21010-5401

RE: Proposed Plan for the Environmental Remediation of the Former US Army Arsenal-
Research Laboratory, Watertown, MA

Dear Mr. Waugh:

The Town of Watertown's Arsenal Reuse Committee has reviewed the Proposed Plan for the clean-up of the
former US Army Research Laboratory.

Based upon all of the alternative methods evaluated, we concur that chemical oxidization is the safest
and most thorough technigue to clean contaminated soil on the site.

With regard to the level of remediation, we preferred an entirely "residential" standard for the reasons
stated in our February 14 letter to Chuck Paone, Base Transition Coordinator. However, based upon
Col.Dennis Cochran's response letter of March 22, and Col.Blose's meeting with our Committee on April 29,
we are satisfied with the Army's plan for clean-up levels consistent with our Reuse Plan. As you know, a
consensus of the Committee was achieved when Areas F&T were added to the "residential" clean-up zone.

The Committee was further made comfortable with the Plan based upon statements from the United States
Environmental Protection Agency (EPA) and the Massachusetts Department of Environmental Protection (DEP)
that following remediation, the site will be protective of human health and safe for redevelopment.
Attached please find letters from those agencies documenting this position.

For the above stated reasons, we are satisfied with the Army's extensive analysis of and plan to
remediate environmental issues at the facility. We are now prepared to move forward with the final
planning and implementation of the economic conversion and revitalization of the property.

Thank you for your continued cooperation on this important project.

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                   UNITED STATES ENVIRONMENTAL PROTECTION AGENCY

                                   REGION I

           J.F. KENNEDY FEDERAL BUILDING, BOSTON, MASSACHUSETTS 02203-2211

May 9 1996

Mr. John Airasian
Arsenal Reuse Committee
Town of Watertown
Administration Building
Watertown, MA 02172

Dear Mr. Airasian:

As the Remedial Project Manager for the United States Environmental Protection Agency (EPA), I was asked
at the April 29, 1996 Arsenal Reuse Committee meeting to comment on the Army's  current proposal to
clean-up the Army Materials Technology Laboratory  (AMTL) under the Superfund program.  As a follow-up to
this meeting, you requested that I also provide my comments to  the Arsenal Reuse Committee in writing.

Pursuant to the comprehensive Environmental Response, Compensation and Liability Act (CERCLA) , the Army
has proposed cleaning the soils at AMTL to levels that will allow the Town of  Watertown to develop the
property as outlined in the approved Arsenal Reuse Plan.  The Army's preferred clean-up approach is
outlined in a document called the Proposed Plan.  The Proposed  Plan is currently out for a thirty-day
public comment period during which time community acceptance of the plan is being solicited.  Following
evaluation and consideration of comments  received, the Army, the EPA and the Massachusetts Department of
Environmental Protection will document the final clean-up plan in a Record of Decision.   The Record of
Decision will include  responses to all public comments.

As stated at the April 29, 1996 Reuse Committee meeting, EPA believes that the Army's proposal for
cleanup of the AMTL as outlined in the Proposed Plan is protective of human health and  the environment,
a threshold criteria for remedy selection.  In addition, it is consistent with EPA and Department of
Defense policy on the role of future land use in the remedy selection process.

As stated above, EPA will evaluate and consider all comments submitted during the public comment period.
Public comment is an important part of the process.  Comments received will be weighed against other
pertinent criteria for remedy selection before EPA provides concurrence on the final decision.

It you have any guestions regarding AMTL, please contact me at 573-5785.



cc:    Bob Chase/AMTL
       Jeff Waugh/Army Environmental Center
       Albe Simenas/MA DEP
       Dennis Waskiewicz/Army Corps of Engineers
       Susan Falkoff/WCES
       Jim Okun/0'Reilly, Talbot and Okun
       Mary Sanderson/EPA Federal Facilities Superfund Section

-------

COMMONWEALTH OF MASSACHUSETTS
EXECUTIVE OFFICE OF ENVIRONMENTAL AFFAIRS
DEPARTMENT OF ENVIRONMENTAL PROTECTION
ONE WINTER STREET, BOSTON MA 02108 (817) 292-5500
WILLIAM F WELD
Governor

ARGEO PAUL CELLUCCI
Lt. Governor
TRUDY COX
Secretary

DAVID B STRUTH
Commissions
May 3, 1996

John Airasian, Chair
Arsenal Reuse Committee
Town of Watertown
Administrative Building
Watertown, MA. 02172

Dear Mr. Airasian:

The Department of Environmental Protection would like to take this opportunity to reiterate the comments
made by DEP Project Manager, Albe, Simenas, at the April 29, 1996 Arsenal Reuse Committee Meeting. The
Department has been working closely with various state and federal agencies as well as the community to
ensure that the remedial investigations and the cleanup activities at the Army Material Technology
Laboratory (AMTL) are protective of human health as well as the environment.

The Department has reviewed the proposed cleanup plan for this site and has determined that the cleanup
levels are protective for the future residential, commercial, and open space land uses as outlined in
reuse plan adopted by the Town Council. In addition please note, that the Department does not consider
the Army's funding availability as a criteria to establish these cleanup levels.

The Department will continue to oversee remedial activities at this site through completion to ensure
that they continue to be consistent with statewide cleanup activities and protective of public health,
safety and the environment.

If you or any member of the Reuse Committee have any guestions regarding remedial activities at the AMTL
please contact Albe Simenas, Project Manager, at (617) 292-5507 or Anne Malewicz, Federal Facilities
Section Chief, at (610) 292-5659.

JN/am/avs
Copy Furnished:
Mr. Steven Ward, Watertown Board of Health
Ms. Susan Falkoff, RAB Co-Chair, Environmental
Honorable Warren Tolman, State Senator
Honorable Rachel Kaprielian, State Representative
Mr. Matt O'Neill, Office of the Honorable Joseph P.
Ms. Megan Cassidy, Environmental Protection Agency
Dr. Lorna Bozeman, ATSDR
Mr. Dennis Waskiewicz, CENED-PD - L
Mr. Robert Chase, AMSRL-OP-RK-WT
Mr. Robert Hallisey, Dept. of Public Health
Mr. Jeffrey Waugh, AEC Base Closure Division
Mr. Steve Johnson, DEP BWSC - NERO
Kennedy II

-------
PAUL DENNING
DISTRICT B COUNCILLOR
P.O. Box 453
Watertown, MA 02272-0453
May 13, 1996

Col. Todd Blose
Assistant Chief of Staff
BRAG Installation Management
600 Army Pentagon
Washington, D.C. 20310-0600

Dear Col. Blose:

I submit these comments tonight to express my feelings and opinions regarding the cleanup of the Arsenal
property. Although I sponsored a resolution asking for a higher degree of cleanup of the Arsenal
property which was passed unanimously by the town council, I speak tonight as an individual town
councillor.

I have been involved in the Arsenal cleanup process since the beginning. First as a town councillor,
voting to approve a re-use committee and plan. Then again as a member of the Restoration Advisory Board.
And most importantly as a Watertown citizen.

The town council resolution I mentioned at the beginning asked for the maximum degree of cleanup of the
soil—what you call the "residential standard." This proposal met with much resistance from the Army,
the U.S. Environmental Protection Agency, and the Massachusetts Department of Environmental Protection,
threatening this was going to derail the cleanup process; the agencies claimed the town would lose the
progress it had made by making such an impossible request; these agencies further claimed they were
confused as to who was speaking for the town. Quite a response for such a safety request. My request
was based upon my own fears and those of most residents living in this area. Far too many to be shrugged
off as inconsequential.

However, the request followed a process: we went through the formal letter writing channel asking you
for better cleanup. Our federal representatives did this as well. Once the Council voted for the
resolution, we knew we had done all we could. The answer, not surprising, was N0--there isn't enough
money. I can't accept the notion that the Army won't do a complete and proper cleanup because of money.
You say approximately $90 million will be spent on the site before you're finished. I ask for the
additional $1.5 to $5 million (your estimates) needed to complete the cleanup job to which the citizens
of Watertown are entitled. This should not be treated as a frivolous request.

I believe we gave up the fight for this maximum cleanup too soon. After the Re-Use Committee letter was
written making the request, I informed Congressman Kennedy, Senator Kennedy and Senator Kerry. They made
inquiries and wrote letters supporting the council's resolution. I am not privy to what followed, but
the Army has come back and agreed to clean up an additional two small areas designated as areas F and T.
This is agreeable and would not have happened without the council resolution. We may never know what
would have happened had we as town officials stood firm and united to fight for the full cleanup. A short
delay would not have hurt any one, leaving a less than clean site could hurt many.

What happens now? Your cleanup process designates different levels of clean—more clean for residential
and open space and less clean for commercial. Your job is to convince us that less clean is just as safe
as more clean. Technical jargon aside, I look forward to a convincing explanation. In a simple analogy
which anyone could understand: If you clean your bathroom more in one corner and less in another,
because you don't step into the less clean area as often, will there be less germs in the bathroom?

History has taught me to be skeptical of the cleanup process. This entire area has a murky past since
the days when the Arsenal Mall went from a planning idea to a much regretted reality. There have been
repeated reports and concerns about contamination found in Arsenal Park and the Charles River. The
neighbors of the Arsenal area and the citizens of the town have reason to be skeptical.

In a recent issue of the Watertown Press, the Arsenal's Public Affairs Director Chuck Paone called this
request for additional cleanup a "non-issue." In his letter he portrayed the cleanup more as an
indulgence ignoring the fact that federal law requires all of what has been done. Don't rock the boat we
are told. Cleanup is the only issue. If you don't clean it properly now, how many years will it take
before we have a study showing those living, working or playing on or around the site have been exposed
to a higher health risk? These are my major concerns. That is why I sponsored an increased cleanup
resolution and why I am here this evening. I won't ever stop being concerned about the Watertown Arsenal
site. Especially when I her read about other sites around the country that were thought to be safe.

-------

Alex Liazos
11 Otis St.
Watertown, MA 02172
May 13, 1996
Jeffrey A. Waugh
U.S. Army Environmental Center
Base Closure Division
Building E 4480
APG-EA, MD 21010-5401

Dear Mr. Waugh:

I want to follow my comments at the public hearing tonight on the proposed outdoor remediation of the
Watertown Arsenal with a few additional comments.

First I want to thank everyone from the Army, EPA, Massachusetts DEP, and others who have been working
with the Watertown members of the RAB. As a member of the RAB, I have found them always helpful, willing
to get us the information we reguested. I want to thank them and compliment them on a job well done. My
following comments are no reflection of the work of any of these officials.

I believe the major mistake, from the point of view of what is best for the town of Watertown, was made
when the Arsenal Re-Use Committee submitted its re-use plan, calling for one-third housing and two-thirds
industrial. We now hear that they did not then realize that the Army would take their proposal as the
town's proposal, which the Army would use as the standard up to which they would clean the soil and
buildings. If so, what did they think the Army would do with their proposal?

That plan locked the town into a use plan that was and is inflexible and does not allow us to change as
our needs change or as the market demands change.

I want to close by noting that I agree the comments made at the meeting tonight by Lisa Bouchard of
Watertown Community Housing, Paul Denning to the RAB and the Town Council, and Dikran Kalligian of the
RAB and former town councillor. For all the reasons they gave, it would be best for the entire site to
be cleaned up to residential standards.

Again I want to thank the various officials on the RAB who have worked with town residents.

I should note that there is much distrust in town, reflecting past dumping of materials, assurances that
proved false, and so on. These things took place not long ago and unless you clean up to the highest
standard I think people will not feel safe.

-------
                                         Dr. Stephen Steadman
                                        91 Common Street
                                          Watertown, MA 02172

May 22, 1996

Mr. Jeffrey H. Waugh
US Army Environmental Center
Base Closure Division
Building E4480
APG-EA, MD 21010-5401

Dear Mr. Waugh:

These comments are in response to the Final Proposed Plan for the Remedial Investigation/Feasibility
Study at the Army Materials Technology Laboratory in Watertown,  MA.  As you know I am a member of the
Watertown Arsenal Re-use Committee and have been an occasional visitor to RAB meetings.  I was appointed
to the Reuse Committee by the Town of Watertown because of my professional occupation as a nuclear
physicist and also having a reasonable knowledge of chemistry.  In this capacity I have worked within the
Watertown Citizens for Environmental Safety in understanding the technical reports as prepared for the
Army and then working to explain them to my fellow Watertown citizens with less technical training.  This
was particularly important before the environmental consultant Jim Okun,  of O'Reilly, Talbot & Okun
Associates was retained by WCES through a TAG Grant.

With the proposed changes by the Army whereby Zone 3 has been expanded to include the area including
Buildings 117 and 118 (Zone F), which will bring this part of the site which has historically been used
for residential purposes also up to a Residential Reuse standard, one has a very satisfactory plan for
the site for the benefit of the citizens of Watertown.   I am aware that much of the proposed remediation
work within the Commercial/Industrial zone will indeed also bring these areas to a similar standard.
But, it is hard with the planned chemical oxidation process to guarantee up-front that the remediation
will result in a specific final low-level contamination.

Recent results in the scientific literature also point to the likely inadeguacy of the so-called linear
model, in which a low-level dosage over a very long period of time (a chronic exposure) would yield
eguivalent health hazard as a high-level dose over a short period of time (an acute exposure).  Most risk
assessment is based on the results of acute exposures.  It now appears, after many years of study, that
there is apparently a threshold effect, namely that biological organisms suffer no obvious damage from
very low-level chronic exposures to radiological or most toxic chemical contamination.  These results are
obviously difficult to confirm.  And, it is better in evaluating risk assessment to err on the
conservative side.  But, it does give confidence to the overall conclusion that the planned remediation
for the whole site will indeed result in a very safe environment for the citizens of Watertown.  Thus, I
find that the proposed plan is a very sound and reasonable one,  that will result in no unacceptable risk
for the public.

I thank the US Army for their very thorough approach in developing this plan, and particularly for their
responsiveness to public input.  Together, a better plan has been generated that is mutually
satisfactory.  I now hope that we can guickly proceed to the ROD and the subseguent remediation effort,
so that the site may once again be put to productive use.

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                         WATERTOWN COMMUNITY HOUSING INCORPORATED

               "Watertown's Community Development and Housing Organization"

60 Main Street  Third Floor  Watertown, Massachusetts 02172  Telephone (617) 923-3505  Fax (617) 923-9575


May 21, 1996

Mr. Jeffrey H. Waugh
U.S. Army Environmental
Base Closure Division
Building E4480
APG-EA, MD 21010-5401

Re:  Written Comment on Proposed Soil Remediation Plan for the Army Research Laboratory (ARL) Watertown,
     MA

Dear Mr. Waugh:

The Board of Directors and staff of Watertown Community Housing, Inc. (WCH) are submitting the following
comments for the record in response to the proposed soil remediation plan for the Army Research
Laboratory (ARL), Watertown, Massachusetts.  These comments are consistent with oral testimony that WCH
presented at the formal public hearing held on May 13, 1996.

We are disappointed with the proposed plan for soil remediation that only selects a subset of the
buildings and parcels on the site for clean-up to residential standards.   We feel that the Army and the
environmental regulatory agencies used the economic benefits conveyance process and the mixed-use
policies of the Arsenal Reuse Master Plan as shields for contending that a full-site clean-up to
residential standards is an incomparable goal.  We also feel that the Army's concern that a full soil
remediation to residential standards would create an undue budgetary constraint that would potentially
jeopardize the entire base closure and conveyance process does not appropriately reflect the actual costs
of the clean-up.  The Army's own estimates for the additional clean-up costs are a negligible percentage
of the overall remediation projections.

WCH is fully supportive of the work of the Arsenal Reuse Committee and the RAB and endorses the mixed use
recommendations of the Master Plan.  However, a mixed use plan does not preclude a full clean-up of the
site, nor does it prelude the possibilities that future decisions by the Watertown community will warrant
a revisiting of specific buildings or areas for residential use.  Watertown needs and merits the
flexibility to respond to changing demographics, particularly with the Arsenal site.

The current situation in Watertown already sends strong signals that there is a growing housing crisis.
There is a mismatch between the existing housing stock in Watertown and the changing demographic profile
of the community.  This mismatch is most evident in the following statistical conclusions called from the
1990 Census data, the Town's Comprehensive Housing Affordability Strategy  (CHAS), and the Metropolitan
Area Planning Council (MAPC) Demographic Trend Projections:

•      The proximity to Boston and community amenities has resulted in a higher-than-average median home
       price in Watertown,  and very low vacancy rates and high contract rents in rental units.   There is
       an increasing gap between income and housing costs and it is estimated that a family needs to earn
       160% of the median income to purchase a median priced home in the community.

•      Although the Town's overall population has decreased over the past several decades,  the number of
       family households has increased and the number of young children is on the rise. It is estimated
       that more than half (53%)  of Watertown's housing units are in 2-4  unit structures,  almost all
       built prior to 1960.  Given the likelihood that these units have an incidence of lead paint, there
       is a conclusion that the current housing stock is all-suited to the health and well-being of
       families.

•      Watertown currently has a disproportionately large elderly population with the trend projected to
       climb in the next decade.  Almost 2/3 of the elderly own their own homes and many live alone.  It
       is anticipated that many of Watertown's elderly are overhoused in older,  difficult-to-maintain
       housing stock is ill-suited to aging-in-place.
-------
•      There is a dearth of vacant land in the Town and the few privately owned vacant lots are
       expensively priced.  It is anticipated that private new construction housing on these sites will
       be smaller than average for family sized units (more suitable to single householders) given the
       density, and inaccessibly priced to low-and moderate-income first time homebuyers.

Based upon the above data, Watertown is already faced with the need to make important public policy
decisions that will guide its future.  The Arsenal site is the last great hope for the Town.  Any
proposed soil remediation plan that offers less than a complete clean-up  (to residential standards)
closes many doors for the Town now and in the future.

We urge the Army to revisit the soil remediation plan and do the  (only) right thing for the Watertown
community.

Sincerely,

The Board of Directors



cc:    Arsenal Reuse Committee
       RAB
       Michael Driscoll, Town Manager
       The Honorable Warren Tolman
       The Honorable Rachel Kaprielian
       The Honorable Joseph P. Kennedy
-------


This memorandum transmits comments on the Final Proposed Plan prepared by Roy F. Weston, Inc. for the
Army Materials Technology Laboratory (MTL) property in Watertown, Massachusetts.  These comments may
address text of the Proposed Plan, they do not specifically address chemical oxidation.

In days past, the Arsenal was an asset to the town o Watertown.  At this time,  I would like to thank the
United States Army for the hard work they have undertaken after the close of the MTL.  I am confidant
that the property left behind will continue to be an asset for the town. In my opinion, the Army has
worked hard to understand and address the concerns of the citizens of Watertown. As a resident of
Watertown and neighbor of the Arsenal property, I appreciate it very much.

Page 6, Section 2:  Has the 14 ppm chlorinated solvents that were detected in the well confirmed to be
from an off-site source?  This concentration appears too high for such a suggestion.

Page 8, Par. 1-4:  Does the text infer that the soil risk assessment do not address future use scenario?
Have exposure pathways been considered for the site construction worker or utility worker?  It is
inevitable that these activities will occur in the future.

Does the text infer that a GW-2 scenario is, in no case, appropriate for some of the site groundwater?
Has the migration of vapors into site buildings been assessed?  I am concerned that an earlier lack of
attention to site groundwater will be a later problem.

Page 9, Par. 1-2:  Is it reasonable to say that there is a "background concentration" of pesticides?  I
understand that PAHs have been associated with urban fills and certain other soils.  It would appear that
the appropriate background concentration for pesticides would be "ND."
-------
                               APPENDIX C.3
                TRANSCRIPT OF PROPOSED PLAN FORMAL HEARING
                              (MAY 13, 1996)
 1                            ORIGINAL

 2                        UNITED STATES OF AMERICA

 3                         DEPARTMENT OF THE ARMY

 4                     MATERIAL TECHNOLOGY LABORATORY

 5

 6     In the Matter of:

 7     PUBLIC HEARING,  RE:

 8     PROPOSED PLAN -  REMEDIATION OF OUTDOORS SOILS

 9

10                              Armenian Cultural Center
                                 47 Nichols Street
11                               Watertown, Massachusetts

12

13                               Monday
                                 May 13, 1996
14

15

16            The above entitled matter came on for hearing,

17     pursuant to Notice at 7:06 p.m.

18

19                           PANEL MEMBERS

20

21     BEFORE:              GREGORY  J.  MAHALL,  Chairman

22                      ROBERT CHASE, BRAG Environmental Coordinator

23                      JEFFREY WAUGH,  Army Environmental Center

24

25
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 1                        PUBLIC MEMBERS

 2

 3     ALEX LIAZOS

 4     AL DeVITO

 5     RUDY D'ALANNO

 6     ROBERT CHASE

 7      SUSAN FALKOFF

 8     KIRA BELYAVSKY

 9      LISA BOUCHARD

10     PAUL DENNING

11      DIKRAN KALIGIAN

12      MARILYN PETITTO DEVANEY

13      RUDY D'ALANNO

14

15

16

17

18

19

20

21

22

23

24

25

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 1                               INDEX

 2     SPEAKERS:                                       PAGE

 3

 4      GREGORY J. MAHALL                                 4

 5      BOB CHASE                                         5

 6      JEFF WAUGH                                        6

 7     SUSAN FALKOFF                                     9

 8      ROBERT CHASE                                     13                                       13

 9      KIRA BELYAVSKY                                   14

10        LISA BOUCHARD                                  17

11      PAUL DENNING                                     19                                       19

12      ALEX LIAZOS                                      23

13      DIKRAN KALIGIAN                                  23

14      MARILYN PETITTO DEVANEY                          26

15      RUDY D'ALANNO                                    30

16      UNKNOWN                                          32

17

18

19

20

21

22

23

24

25

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 1                              PROCEEDINGS

 2            THE CHAIRMAN:   First of all,  let me be the first

 3      to say,  welcome.

 4                  My  name  is,  for  those  of  you that  don't  know me

 5      and haven't seen me before, my name is Greg Mahall.  I'm a

 6      Public Affairs Specialist with the Army Environmental Center

 7      out of Aberdeen Proving Ground, Maryland.

 8              We are the Army agency that assists Army

 9      installations on both the base realignment and closure side

10      as well as the installation restoration side with the

11      cleanup of Army installations.

12            You're  here this  evening,  so,  I'll  assume that  you

13     all know why you're here,  but let me go over the purpose of

14      this evening's meeting.

15            This evening's  meeting is to  record comments,

16     concerns,  guestions and  commendations,  if  there are any,

17     into the public record regarding the proposed plan on the

18     remediation of outdoor soils at the  Army Research Laboratory

19     -- also known as  the Arsenal -- here in Watertown,

20     Massachusetts.

21            For those  of you  who may have what,  I think,  some

22            people  have proven  to be a big fear,  and that is a fear of

23      public speaking, there  are comment cards  available for you

24     if you do not wish to  approach our microphone during the

25      course of this evening, and your comments will be read into

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 1     the record and addressed accordingly.

 2            As  I  said,  we're  here  to  entertain comments  and

 3     concerns,  questions and  commendations.   These will  be

 4     responded  to in a responsiveness summary at the end of the

 5     public comment period on this proposed plan.   The comment

 6     period started on April  22nd  and runs  through May 22nd.

 7            Before we begin,  I'd like to introduce to you this

 8     evening, and I'm sure most of you all  know,  Mr. Bob Chase,

 9     the installation and environmental coordinator at the

10     Arsenal, and Bob will get the evening's events off  and

11     running, Bob.

12            MR.  BOB CHASE:  Good evening everyone.   Thank you

13     for taking time out from your busy schedules to partake in

14     our public hearing tonight.

15             As you are well  aware, the hearing is to discuss

16      or enter  into the record your concerns or comments on the

17     proposed plan for the Army Research Lab,  which is part of

18      the former Arsenal Area, the 37 acres that the Army has

19      recently  vacated.

20              The proposed plan is dealing with the alternative

21     for cleaning up the outdoor soil contamination.  We are

22      proposing a Chemical Oxidation Process and that is the

23      process which we intend to proceed with based on comments we

24     receive tonight.

25            There are two areas that  we are  also going to do

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 1     as an emergency action,  one down by the Yacht Club and one

 2     by Building 131,  which we will  dig and dispose of that

 3      material this summer, whereas  the Chemical Oxidation will

 4     take place next summer.

 5            If you do  not want to make a comment tonight,  we

 6     will receive written  comments through May 22nd.   The  address

 7      for comments is in the proposed plan and upon closing of the

 8     comment period,  we will develop a responsiveness  summary

 9     which will become part of the record of decision.

10            We hope to have the record of decision ready for

11     signature in June so  that we can do the initial work  around

12     Building 131 as soon  as possible.  Hopefully,  in  the  August

13     time frame.

14            Without further ado,  I would like to have  Jeff

15     Waugh from the Army Environmental Center briefly  discuss the

16     proposed plan for you.

17            Mr. WAUGH:   Evening.  As Bob mentioned, what we're

18     planning on doing,  is  digging up the soils in various

19     locations around the Arsenal where they've been found to

20     have levels  of contaminants above background.

21            We'd  be treating this soil using a Chemical

22     Oxidation process which removes the contaminants  leaving,

23     essentially, clean soil which will be put back in place.

24            Because of some early actions we want to take  at

25      Building 131, the Yacht Club,  not necessarily emergency, but

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 1     we're trying to do it a little bit faster than the normal

 2     process.

 3            We're going to be doing the removals  there  and

 4            just  disposing the soil in an approved landfill  or to meet

 5     the state requirements and they'd be disposed of off site,

 6     and then back filled with new, clean soil.

 7            We said we'd begin --  the,  there  are  basically --

 8     we're also looking comments on the levels of clean up.

 9     We're looking at basically three levels  at the Arsenal.

10     Commercial up in this area, residential  in this area, and

11     then open space down below.

12            And the levels are,  basically,  dependant on

13     different types of contaminants.  Where,  the final clean-up

14     level is pretty much based on background with some

15     contaminants based on the different risk levels.

16            Bob said we will be replying to all  comments

17     submitted tonight and in writing.   And we would,  this,  the

18     comments will be part of the  record decision which must be

19     approved by EPA.

20            EPA,  the Environmental Protection Agency,  and also

21     the Massachusetts Department  of Environment Protection  will

22     be reviewing all of our responses and all of your comments.

23            So,  they will be aware of it and  our  responses.

24     EPA and the State do have a role in this and EPA has to

25     approve our plan and then the State, also,  has a role in

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 1     accepting that plan,  and we have to follow the State

 2     regulations,  also.

 3            Bob said we'd  be,  there are several factors in

 4     making or decision for the proposed plan.   Not only, not

 5     meeting regulations and being protective of human health and

 6     the environment, but, also, how the public feels on how we

 7     propose our clean-up.  And that's one of the reasons you're

 8     here we're here tonight,  is to really get your concerns and

 9      comments.

10            And,  as I said,  the State and EPA will also be

11     aware of those.  So,  it's, your not just submitting it to

12     the Army.  And the final ROD will be issued probably, around

13     June 21st.

14            So, you'll see our responses or a draft log.

15            THE CHAIRMAN:   Okay.  As Jeff mentioned,  I'd like

16     to recognize a few people here tonight,  for those of you who

17     may not know them;  although,  I suspect that you do with

18     their close involvement with the site.

19            First,  I'd like to recognize Ms.  Meghan Cassidy

20     from EPA Region One is here tonight.  And, also, from the

21     Massachusetts DEP,  Mr. Albe Simenas is here tonight, also.

22            I probably butchered that name because I  kept

23     trying to get it right the whole evening.   Comments, if you

24     would,  as you notice, we do have the Court Reporter here

25     this evening to make  sure that exact, every exact comment

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 1     has been entered into the public record and as responded as

 2     such.

 3            We have  a microphone  here.   We  have  a microphone

 4     there.   We would appreciate  it if when making your comment,

 5     you identify,  of course,  who you are,  so that can be entered

 6     into the record, as well  as, if you do represent any kind of

 7     citizen group or public group or just  yourselves,  we'd like

 8     to know.

 9            So,  without  any further ado,  is there anyone that

10     would like to enter comments at this time?

11            Susan.

12            MS.  FALKOFF:   My name is Susan  Falkoff.   For the

13     past nine years, working  for a thorough evaluation and

14     clean-up of the Watertown Arsenal has  been  an important  part

15     of my life.

16            I've worn a  number of different hats in my

17     efforts.  I've  worked as  a member of Watertown Citizens  for

18     Environmental Safety, as  the WCES representative to the  Re-

19     use Committee,  as the Chair  of the Environmental Sub-

20     committee of the Re-use Committee,  and as the Community  Co-

21     chair of the Restoration  Advisory Board.

22            My work  and  the hard  work of many others will soon

23     culminate in the record of decision which will incorporate

24     the comments you are hearing tonight on the propose plan for

25      the outdoor remediation of  this site.

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 1            During these  years,  I've  seen the  military's

 2            respect for the  interests of citizens  affected by

 3     communities grow.  And  so,  my comments tonight are not in

 4     response to work which  was  completed in isolation,  but one

 5     which resulted from  a well  collaboration between the Defense

 6      Department, the regulators,  the members of the community and

 7     our elected officials.

 8            In this regard,  I  want to particularly mention the

 9     invaluable help the  community has received from

10     Representative Joe Kennedy  in our dealings with the Pentagon

11     and also the determined intervention of our State Senator,

12     Warren Tolman.

13            At Restoration Advisory Board Meetings,  Army and

14     regulatory officials have spent  many hours listening to and

15     communicating with citizens about the methods of cleaning

16     contaminated soil.

17            It took several  envisions of this  proposed plan

18     for the Army to explain clearly  its rational  for choosing

19     the method they have, Chemical Oxidation,  but in the

20     proposed plan we are commenting  on tonight,  I do believe the

21     explanation is clear and adequate.

22            And I believe that this method of  remediation is a

23     sensible and appropriate one  and that the back-up method of

24     off site disposal is a  realistic second choice.

25            Identifying an appropriate level of clean-up has

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 1     been much more controversial.   When the community began its

 2     discussions with the Army,  pristine clean-up was  our goal.

 3     At one early meeting I  stated:  'Why don't you just assume

 4     we want to build a really big day care center?'

 5            The problem with that was  that  no one in the town

 6     really believed this was the  best reuse for this  historic

 7     site.  We also came to  realize,  that once something was

 8     broken,  you can fix it,  but it will never be exactly the

 9     same.  And this land could never be really returned to any

10     state you could call pristine.

11            So,  we gradually modified our reguest to the more

12     technically acceptable  language for unrestricted  reuse.  And

13     for a long time,  the community was united around  that goal.

14            For some,  it remains a  goal which should not be

15     compromised.   And I respect them for stating forcefully

16     their case.  In the meantime,  however,  the Army has

17     developed guidance for  cleaning site to the intended reuse

18     as identified in the reuse plan.

19            This has not sat well with the  community that

20     developed a reuse plan  as a goal,  but wanted very much the

21     flexibility to adjust to new  ideas and changing economic

22     realities,  which could  potentially include more housing.

23            Gradually,  however,  our thinking evolved further

24     to guestion whether the flexibility to develop the entire

25      site for housing really was  necessary.  Some members of
  Some members of

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 1     WCES,  for example,  while doubtedly pursuing unrestricted

 2     reuse,  have one question building residential units in areas

 3     where  depleted uranium was burnt no matter how high the

 4     standards used for defining clean-up.

 5            With this in mind,  for the last  several months,  I,

 6     personally, have given much thought to  which aspects of the

 7     clean-up really mattered most.   For safety,  aesthetic,  and

 8     logical reasons, it was clear to me that all of the green

 9     areas  visible from the Commander's Mansion should be

10     available for unrestricted use.

11            Housing maybe;  day care maybe; university

12     classrooms perhaps; summer camp  programs for youth, anything

13     should be possible there.   This  lovely  area overlooking the

14     Charles River should not be carved up.   It clearly operates

15     from a landscaping point of view as a single entity

16     regardless of the way it is carved out  in the reuse plan.

17            Fortunately,  the Army has heard  this  request,

18     deemed it reasonable and feasible, and  on April 29th,

19      Colonel Blose came here from the Pentagon to a Re-use

20     Committee meeting to announce that there would be an

21     addendum to the record of decision in which the current

22     proposed plan is modified to include for the clean-up to

23     residential standards of the areas called F and T on this

2 4     map.

25            With this change,  the community  has achieved the

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 1     goal of restoring the green areas for safe and unrestricted

 2     future use.   The consensus of the Committee that night was

 3     that with this change,  the proposed plan is fully

 4     satisfactory of the Re-use Committee.

 5            On behalf of the community,  I thank Colonel  Blose

 6     for this change at the April 20th meeting, and I would like

 7     to do so tonight for the public record.   With the change

 8     presented by Colonel Blose,  I am satisfied with your

 9     proposed plan.

10            I believe it will protect the safety of users,

11     abutters, and trespassers on this property to the extent

12     possible by technical and scientific standards as we

13     understand them today.

14            I also would like to go on record as being

15     especially grateful to the Technical Assistance Program of

16     the EPA, without which, I would not be able to state these

17     opinions with level of confidence I feel tonight.

18            Thank you for the opportunity to  make these

19     remarks, and I look forward to continued collaboration with

20     military officials and state and federal regulators as we

21     move forward on the actual clean-up and development of this

22     site.

23            THE CHAIRMAN:   Thank you,  Susan.   There are

24     copies,  by the way, of the proposed plan on the table as  you

25     came in.  If you happen to pick one up,  very good.   If not,

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 1     they're also available in the information repositories  on

 2     this subject.

 3            Open for  another comment?   Sir.

 4              MR. ROBERT CHASE:  I'm Robert Chase.   I live at

 5     15 Franklin Street,  Watertown,  and have for the last 45,

 6     48 years.   Previous to that,  I  lived at 6 Patton Street,  in

 7     the interim between Patton Street and Franklin Street,  I

 8     served in the military, Naval Enlisted Man and then with the

 9     Marine Corps,  on Guam and Ulil  invasions when  we took those

10     places back from the Japanese.

11            I've been very concerned about the community and

12     depressed by one of the things  that happened in this

13      particular operation.

14            When I  realized I was  one  of the minority,  so,  I'm

15     not claiming any benefits from it,  but the problem of moving

16            hazardous wastes of a  nuclear generation is happening in

17            this country all over  the  place.

18            Primarily because we spread it out.   It's not

19     really a Chernobyl on the Charles,  but it's as close to it

20     as we can get.   It's like Three Mile Island, except that

21     we've inflicted  upon the people of South Carolina or North

22     Carolina,  I've forgotten which river basin we  dumped our  low

23     level radioactive waste in.

24            But,  I  would like to know  because I  have a,  sort

25      of a devious mind,  who the major contractors  were, whether

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 1     they were private,  whether they were federal -- what

 2     trucking companies,  perhaps are arranging this

 3     transportation for various hazardous waste areas around the

 4      country.

 5            I hope  we can publish the names  of the private

 6     contractors that are indulging in this  military reparations

 7     program.  I thank you very much.

 8            THE CHAIRMAN:   Thank you Mr.  Chase.   The podium
The podium

 9     stands open for guestions, comments? Ma'am.

10            MS.  BELYAVSKY:   Good evening,  everyone.   I

11     represent maybe people who live in Watertown, because  I have

12     been living for five year, 465 Arsenal  Street.   It's very

13     close to former laboratory.

14            We all  know history of laboratory.   Before  55

15     acres of land from the laboratory were  sold to Town of

16     Watertown,  it was used during 150 years.

17            And I  don't think so,  that this  soil was less

18     contaminated than soil of laboratory.  It would mean very

19     much because this territory,  what was sold to Town of

20     Watertown,  became a shopping mall,  Arsenal Park, condo and a

21     public park.

22            Arsenal Park,  it is wonderful recreation area

23     where every year, in almost all year around and especially

24     the summertime,  are a lot of the children,  a lot of young

25     people who play soccer, volleyball,  basketball and cook

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 1     barbecue and rest on the grass.

 2            In addition,  in Arsenal  Park,  is  our five  mulberry

 3     tree.   And a lot of Armenian people and  kids among them eat

 4     mulberry all summer.  I don't know how it is contaminated

 5     soil of Arsenal Park,  but I know that a  lot of people rest

 6     here.

 7            I'm not  interested in territory of former  MTL,  but

 8     I am interested very much of territory of Arsenal Park.   I

 9     have one observation which all  time surprise and  trouble me.

10     Arsenal Park is wonderful area,  but I saw there only a few

11     ducks.

12            I don't  know why ducks never settled there.   I

13     think maybe ducks have special  instincts which prevent them

14     to settle there.  I don't know.   Maybe you'll explain me

15     this phenomenon.

16            I have one proposal.   What if to  take one  sguirrel

17     from Arsenal Park because -- and make autopsy of  this

18     sguirrel and examine its liver,  brain, and bones.

19            It will  be possible to know how is contaminated

20     the body because sguirrel live  in Arsenal Park the whole

21     year round and  their nutrition  consists  from berry,

22     mushrooms, and  seeds from Arsenal Park.

23            It's possible,  it would  be possible to find out

24     how big is contamination of the body. I think you should

25     interested in the soil of Arsenal Park,  maybe more than soil

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 1     of former laboratory because in laboratory work limited

 2     amount of people.

 3            Arsenal  Park  and the  public  park  is wonderful

 4     recreation area.   I'm so sorry about my  language because  I

 5     only have been  living here for five years, but I want to

 6     make this comment.

 7            My name  is  Kira Belyavsky, B-E-L-Y-A-V-S-K-Y.   All

 8     set?

 9             THE CHAIRMAN:   Thank you.   Once  again,  I would

10     like to,  while  there are guestions  and concerns raised here

11     tonight,  we are talking on the soil remediation on the

12     current site.

13            So,  Mr.  Chase and Mr.  Paone  and the rest of us

14     will be here after,  when we're off  line  and maybe we'll talk

15     about some of those  subjects as well.  But,  I  would like  to

16     bring the focus back to the  remediation  of the soils.

17            And having  said that,  I would like  to introduce or

18     call up a Ms. Lisa Bouchard.   She would  like to comment on

19     behalf of the Watertown Community Housing  Incorporated.  And

20     I won't read the rest of the card out loud,  Lisa.

21            MS.  BOUCHARD:   Thank  you.  My name  is Lisa

22     Bouchard,  and I'm the Executive Director of Watertown

23     Community Housing Incorporated,  which is the local 501C3

24     Community Development Corporation here in  Watertown.

25            We're charged with assisting first  time home
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 1     buyers with counseling homeowners,  trying to help renters to

 2     either preserve or locate affordable housing.

 3            I  come  here representing my  Board of Directors  and

 4     our constituency,  and as I've said  their homeowners,  rent,

 5     renters,  business  owners,  et cetera.

 6            We're particularly concerned about our  mandate,

 7     which is  affordable housing.  And so,  we have very general

 8     comments  about soil remediation as  it affects,  as we  see it

 9     as having a long term affect on limiting the opportunities

10     for affordable housing here in Watertown.

11            My organization is  generally disappointed in the

12     end result of  this process,  although we are very respectful

13     and mindful of the hard work that everybody's put into it,

14     and we are happy to be here to give you these comments.

15            Our sense is that without a  complete clean-up,  any

16     possible  future flexibility for housing opportunities  is

17     severely  limited.   And,  as we know, Watertown is an

18     extremely densely  developed community.

19            There are very few existing  housing opportunities

20     and it is a current mismatch between the housing stock that

21     we have now and the changing demographics.  The town  is

22     growing both older in terms of the  65 to 85 year old  set and

23     families  are having more children.

24            But the existing housing stock is older,  its got

25     lead paint, it's inaccessible to many of our elders who  are
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 1     aging in place and need either ramping or wheelchair

 2     accessibility.

 3            So,  our feeling is  that the  one opportunity that

 4      the Town has is the Arsenal site.   And although we are very

 5     pleased that there's a mix use development plan on the table

 6      and think that the Arsenal Re-use committee and the RAB has

 7     done an excellent job of developing a sustainable plan,  our

 8     feeling is what as the Town's demographics change, there

 9     needs to be opportunities  to change with it.

10            And by limited the  soil remediation in some areas

11     to less than residential levels,  our feeling is that it, it

12     doesn't give the town flexibility in the future to make

13     other kinds of decisions based on their housing needs.

14            The median home priced here  in Watertown is

15     rising, disproportionately to the median income.   So,  it's a

16     mismatch of factors and we had very high hopes for the

17     Arsenal site being that opportunity for the town to be able

18     to grow and to provide housing for its current residents and

19     its future residents.

20            So,  in general,  we  appreciate all of your  hard

21     work, but we are disappointed and hope that you will

22     reconsider in terms of the soil remediation.   Thank you.

23            THE CHAIRMAN:  Thank you, Ms.  Bouchard.   At this

24     point,  I would like to introduce  Mr. Paul Denning.  Mr.

25     Denning handed a card in as he came in this evening, and I'd

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 1     like to turn the podium over to him.

 2            Mr.  Denning:   Thank  you.   My name  is  Paul  Denning.

 3     I'm a member of the Watertown Town Counsel representing the

 4     area just surrounding the Arsenal.  As I  later hear tonight

 5     from Town Counsel President,  Richard  Mastrangelo,  I'll

 6     submit,  but I won't read.

 7            I  submit these comments tonight to express  my

 8     feelings  and opinions regarding the clean-up of the Arsenal

 9     property.  Although I sponsored a resolution asking for a

10     higher degree of clean-up of the Arsenal  property which was

11     passed unanimously by the Town Counsel,  I speak tonight as

12     an individual Town Counselor.

13            I  have been involved in the  Arsenal clean-up

14     process since the beginning.   First as the Town Counselor

15     voting to approve a re-use  committee  and  plan.   Then,  again,

16     as a member of the Restoration Advisory Board,  and most

17     importantly as a Watertown  citizen.

18            The  Town Counsel Resolution  I  mentioned at  the

19     beginning asked for the maximum degree of clean-up of  the

20     soil.  What you call the "residential standard."

21            This proposal met with  much  resistance from the

22     Army, the U.S. Environmental Protection Agency and the  Mass

23     Department  of Environmental Protection.   Threatening this

24     was going to derail the clean-up process.

25            The  agencies claimed the town  would lose the

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 1      progress it has made by making such an impossible request.

 2     These agencies further claimed they were confused as to who

 3      was speaking for the town.

 4            Quite a response for  such a safety request.   My

 5     request was based upon my own fears and those most residents

 6     living in this area.   Far too many to be shrugged off as

 7     inconsequential.   However,  the request file process, we went

 8     through the formal letter writing channel asking you for

 9     better clean-up.

10            Our federal representatives did this as well.

11     Once the counsel voted for the resolution,  we knew we had

12     done all we could.  The answer,  not surprising was:  "No

13     there isn't enough money."

14            I can't accept the notion that the Army won't do a

15     complete and proper clean-up because of money.  You say

16     approximately $90 million will be spent on the site before

17     you're finished.

18            I ask for the  $1.5 to $5  million,  your estimates,

19     needed to complete the clean-up job to which the citizens of

20     Watertown are entitled.

21            This should not be treated as a frivolous request.

22     I believe we gave up the fight for this maximum clean-up too

23     soon.  After the Re-use Committee letter was written making

24     the request, informed Congressman Kennedy,  Senator Kennedy

25     and Senator Kerry.

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 1            They all  made  inquiries  and wrote  letters

 2     supporting the counsel's resolution.   I  am not privy to what

 3     followed,  but the Army has come back  and agreed to clean-up

 4     an additional two small areas designated as areas F and T.

 5            This is agreeable and I  would  not,  it would not

 6     have happened without the counsel resolution.   We may never

 7     know what  would have  happened had we,  as  town  officials,

 8     stood firm and united to fight for the full clean-up.   A

 9     short delay would not have hurt anyone leaving a less than

10     clean site could hurt many.

11            What happens now?  Your  clean-up process

12     designates different  levels of clean.   More clean for

13     residential and open  space and less clean for  commercial.

14     Your job is to convince us that less  clean is  just as safe

15     as more clean.

16            Technical jargon aside,  I  look forward  to  a

17     convincing explanation.  In a simple  analogy which anyone

18     could understand,  if  you clean your bathroom more in one

19      corner and less in another, because  you don't step into the

20     less clean area as often,  will  there  be  less germs in the

21     bathroom?

22            History has taught me to be skeptical of the

23     clean-up process.   The entire area has a  murky past since

24     the days when the Arsenal Mall  went from a planning idea

25     into a much regretted reality.

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 1            There  have  been repeated reports  and concerns

 2     about contamination found in Arsenal Park and the Charles

 3     River.   The neighbors of the Arsenal area and the citizens

 4     of the town have reason to be skeptical.

 5            In a recent issue of the Watertown Press,  the

 6      Arsenal's Public  Affairs Director,  Chuck Paone,  called this

 7      request for additional clean-up a non-issue.

 8            In his letter,  he portrayed the clean-up more  as

 9     an indulgence ignoring the fact that federal law  requires

10     all of what has been done.  "Don't rock  the boat,  we  are

11     told.

12            Clean-up in my view is the only issue.  If you

13     don't clean it properly now,  how many years will  it take

14     before we have a study showing those living, working, or

15     playing around the site have been exposed to a higher health

16     risk.

17            These  are my major concerns.   That is why  I

18     sponsored an increased clean-up resolution and why I'm here

19     this evening.  I won't ever stop being concerned  about the

20     Arsenal,  Watertown, Arsenal site.

21            Especially  when I read about  other sites around

22     the country that were thought to be safe.  Thank  you.

23            THE CHAIRMAN:  Let the record show that  I've

24      accepted Mr. Denning's letter and included with  the  Court

25      Reporter for inclusion into the public  record, as well as,

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 1     the second letter.   Thank you.

 2            The podium and the mic.  are  open,  other comments?

 3     Sir.

 4            MR.  LIAZOS:  My name is Alex  Liazos,  and I  serve

 5     on the Restoration Area Board,  and  I'll be very brief.

 6            I  share  the  spirits and  the  concerns of the  last

 7     two speakers.   I don't need to  repeat what they said.   Thank

 8     you.   And I will be writing a  short letter to the committee.

 9            THE CHAIRMAN:  Thank you,  sir.   Again,  an open

10     podium.  Sir.

11            Mr.  KALIGIAN:  My name is  Dikran Kaligian.   I live

12     at 56 Prentice  Street.  I'm also a  member of the Restoration

13     Advisory Board.

14            In addition,  I was a member  of the Town Counsel

15     that  approved the re-use plan  that  is the basis,  we

16     understand, of  the clean-up plan that we are now presented

17     with.

18            Having been involved in  this process from the

19     beginning,  I'd  have to say it,  it has been a long process

20     and the final  resolution; however,  is disappointing.

21                  We have gotten more clean-up  than was originally

22      planned; however,  there is still significant soil

23     contamination remaining on the  site that will remain on the

24      site according to the plan that's  before us today.

25            I  think,  in particular,  I understand the concerns

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 1     about the lack of money,  the fact that there is  a limited

 2     amount of funds to clean up sites throughout the country.

 3      However, I think for two reasons it is necessary for us to

 4     reconsider,  I would hope the Army would reconsider in the

 5     case of Watertown.

 6            Unlike most  of the other  sites,  where we  have  shut

 7     down Army bases nationwide,  number one,  this is  a very urban

 8     site.  The majority of formerly  used defense sites, be they

 9     Army bases,  Air Force bases,  Naval stations are  not densely

10     urban areas.

11            And therefore,  any soil,  any property which is  not

12     able to be use to its fullest potential does not have the

13     same value,  does not have the same great need as is

14     necessary here in Watertown,  where we have only  four  sguare

15     miles to work with.

16            Secondly,  unlike probably the vast majority of

17     defense sites that have been shut down nationally,  we have a

18     prior history here in Watertown  where,  in fact,  the majority

19     of the formal Arsenal property has already been  turned over

20     to the town.

21            And it was turned over the town at a time where

22     there were no or few environmental regulations.   And  the

23     concerns of the people of Watertown are still there that

24     there is significant contamination in the area that has

25     already been turned over to the  town with very little, if

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 1     any,  soil,  remediation.

 2            Given the  fact  that  back  in the  '70s  when

 3     Watertown received the property,  the Army did not do a

 4     complete clean-up,  did not  do any clean-up to speak of and

 5     left  the town with a significant burden,  at  least

 6     psychologically,  if not in  actuality of potential health

 7     hazards.

 8            It would,  I  believe,  it would be in the best

 9     interests of both Watertown and  the Army to  have a more

10     complete clean-up here in 1996 when we  do have the

11     regulations, where we  do have the opportunity for only

12     percentage  wise a little amount  more.

13            And  we speak of,  perhaps,  an extra five to six

14     percent costs maximum on top of  the $80 million spent to

15     date.   It would seem silly  not to go that,  that extra yard

16     in order, the extra small amount in order to make sure that

17      there will be peace of mind to  the people of Watertown.

18                   That,  although,  the,  it is  going to be  difficult

19      for  the prior property be  cleaned-up because the formerly

20     used  defense site law  has very little money  in it to clean

21      up the area that is now covered, that's under the Arsenal

22      Mall, that is the Arsenal  Apartments,  the elderly housing

23     there and other sites  that  at least in  the case of the

24     property being turned  over  in the near  future, this should

25     have  been cleaned up to a greater extent.

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 1            In particular,  I  appreciate  the  fact  that  there  is

 2     a greater,  that after the original  proposal  there is more

 3     being cleaned up,  the two additional areas F and  T.

 4            However,  as we can see  from  the  map,  there are a

 5     number of other areas.   And even if it  were  not possible to

 6     clean the entire site up to residential,  I do believe the

 7     Army could have done much more.

 8            I  would ask that  the Army consider the,  for a

 9     small additional cost to do the  greater clean-up  to allow

10     the piece of mind of the people  of  Watertown to allow the

11     less fear of health hazards in the  future in the  soil

12     contamination that will  be remaining when the Army leaves.

13     Thankyou

14            THE CHAIRMAN:   I  do not believe  we've heard from

15     everyone in the audience.  Open  podium.  Ma'am.

16            MS.  PETITTO DEVANEY:  My name is  Marilyn Petitto

17     Devaney.   I'm a life long resident  of Watertown.   I don't

18     have a prepared statement, but I will give a written

19     statement.   I understand we have a  couple of more weeks.

20            I  expected to hear more this evening.   I can't

21     remember when I wasn't involved  in  the  Arsenal.  I remember

22     in 1978 asking,  guestioning about the nuclear reactor.   At

23     that time,  I was told it was disassembled and it  was gone.

24            And I find out a  few years ago that I was  lied to.

25     So,  I didn't start out with a very  good impression.   I'm

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 1     very concerned of the safety of Watertown and the Arsenal

 2     because as a life long resident,  I  know that the Army dumped

 3     a lot of things.

 4            And my generation knows  that,  and I  have  friends

 5     that grew up in that area that  saw  them dumping  and saw  all

 6     of this before regulations,  you know,  warranted  that they

 7     dispose of things in the proper way.

 8            My reguest would be,  probably,  the first  thing I

 9     would like to mention -- and as I said,  I will have a

10     written statement later -- that I would like to  know, I'd

11     like to see a report of the,  there's  a safety issues, of

12     standards and reguirements by the Nuclear Regulation

13     Commission.  They have a report about standards  and

14     reguirements.  I  would like to  see  that.

15            There's something I'd like to  mention that's not

16     included in the clean-up per se,  and  that is two areas that

17     I'm very concerned about.   You  will be cleaning  more of  the

18     GSA land.

19            There is contamination in, in  the ground  there

20     that are above limits,  and I'm concerned about it because  I,

21     I've talked to some people who  are  working there,  workers

22     that were on the  site.   And when they were leaving, when I

23     talked with them aside,  they were concerned.

24            In their expertise,  they told  me  that they felt it

25     would cost $3 billion just for  the  GSA land to be cleaned

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 1     up.   And they were called off the job at that point.   That

 2     scares me.

 3            Fillipolo Park  is  not  included.   This  is  the

 4     former Arlington Street Park.  I'm very concerned about it

 5     because I have friends of my  generation that  were there

 6     playing as kids and saw the Army coming in in the trucks and

 7     dumping in Solland's Pond and so forth.

 8            I know fire fighters that were there fighting  the,

 9     we used to be a dump,  and they dumped a lot of things there.

10     And they'd be standing there  and they would see  that  the

11     water was yellow,  gold,  orangey.  This is scary,  you  know,

12     I'm afraid of the rate of cancer.  I'm very concerned about

13     that,  about the area of people who work there.

14            I worked there  myself  for a time,  so,  I don't  know

15     who much I was exposed to,  but I know that children are

16     playing on that park in Fillipolo.

17            And it's a deep concern to me,  and I'm going to do

18     everything that I can to see  that that is,  that  we test down

19     there because we don't know what we're doing  with our

20     children.

21            You know,  we see it  in other towns and cities  and

22     this is another subject,  but  I have a friend  that lost a

23     child in Woburn.   So,  I know, and that was 13 years ago.

24     So,  I'm very worried.   My daughter played on  Fillipolo,  too.

25            So,  I just wanted to give those,  just  those kind

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 1     of suggestions or requests and I will have something that's

 2     written.   And I apologize for,  you know,  rambling on,  but I

 3     care and I hoped I could work in a way that,  that we could

 4     accomplish this.

 5            But I'm concerned and I'm sorry I  don't  trust

 6     because I haven't had reason to, and I think that it has to

 7     be cleaned up as,  and get as much money as we can from the

 8     super fund or where ever to do this.

 9            And if we  don't do Fillipolo Park  and do GSA land

10     the way it should be,  then we're not doing our  part.  And I

11     was around,  I hate to admit, when we bought the Arsenal.

12     And we didn't know then that somehow along the  way,  the

13     Nuclear Regulation Commission -- I found out in recent years

14      -- never signed off on that.

15            And I  don't know what happened,  how they missed

16     this one.  But, you know, we can't repeat the mistakes of

17     the past and, so,  that's why I'm here.

18            Thank  you  very much.

19            THE CHAIRMAN:   Thank you.

20            MS.  PETITTO DEVANEY:   I  just want  to say something

21     about the elderly housing which is aside  the mall.

22            THE CHAIRMAN:   Arsenal Mall,  right,  the  elderly

23     housing.

24            MS.  PETITTO DEVANEY:   It was never approved to  go

25     to that state recommendation.

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 1            THE  CHAIRMAN:   Okay.   Thank you.   Just  to

 2     reiterate.   This is not,  this is not the final step of the

 3     process,  once again.

 4            We are in the  middle  of the comment  period and if

 5     you walk out of here  tonight with other concerns  or concerns

 6     that you did not voice here  tonight,  this comment period

 7     runs up until May 22nd.

 8            So,  as you mentioned  sending a letter in,  by all

 9     means.   If  there are  other that want to follow the same

10     track,  please do so.   Get them to us, I guess  postmarked  by

11     the 22nd of May and they'll  be entered into the record and

12     will be dealt with in a responsiveness summary.

13            We have an open podium.   Sir.

14            MR.  D'ALANNO:   My  name is Rudy D'Alanno.  I was

15     former  President of the East Watertown Betterment

16     Association for 25 years.  I'm not Vice President.

17            And  I'm sorry  our  President is in the back of the

18     hall here and I didn't see him come in,  and I  thought he

19     wasn't  able to come so I  was going to say a few words, but

20     maybe he'll follow up on what I have to day.

21            I  was born and brought up in East Watertown,  and

22     I'm not ashamed to say I've  been here for 71 years.   Always

23     in the  same local, in fact,  I just build a  new home, just

24     lived in it last year.  I'm very proud of East Watertown.

25            The  main thing that bothers me and I don't hate,

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 1     don't like to be repetitious,  but Marilyn and Paul Denning

 2     and all of the other who spoke here tonight spoke about

 3     Fillipolo Park,  spoke about the GSA land.

 4            The people in East Watertown are  very skeptical.

 5     It's a hard thing to say and some of these gentlemen here

 6     that come to most of these  meetings,  we  try to get people to

 7     come and voice their opinion.   They're all afraid to.

 8            But all I would like to say is,  I do not wish to

 9     see what happened on the big cover up and I have yet to say

10     it's Fillipolo Park.  It's  a shame that  all of the work we

11     put in and one of the young ladies,  she's moved out of

12     Watertown now, but she put  a good five or six,  at least five

13     or six years in research.

14            But this  is one of the  reasons we want to be sure

15     that everything is all cleaned up.  I worked in BF Goodrich,

16     maybe I shouldn't bring this on either,  but I worked in

17     there for 25 years and the  stuff that was really dumped,

18     you'd never imagine.

19

20            I bet a lot of it is still buried there,  and we

21     don't want this  to happen to the Watertown/Arsenal property

22     You people have  done -- I wish to compliment all of, all of

23     the hard workers, and I'm very please what has been, the

24     progress that's  been made there and I hope that we just

25     continue on.

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 1            Thank you very much.

 2            THE  CHAIRMAN:   Sir,  I'll  assume  you're  the

 3     President.   He kind of put the,  put the onus on you to say

 4     something.   Did you want to come up?

 5            UNKNOWN:   After listening to the speakers here

 6     tonight,  and I've regretted the  health, the health

 7     assessments, I'm afraid.  Am I  going to be living  next year?

 8     I'm afraid  of to talk anymore.

 9            Just this morning I  had breakfast with  a retired

10     engineer of 40 years of the Arsenal. He said to me,  I've

11     been there  for 40 years now,  I'm still  living.   I  have no

12     problems.   But,  who blame here.   It seems to be guite  a

13     problem according to our elected town officials who voted on

14     or had some part in voting on the committee's  here in

15     directly to the town manager.

16            And  here,  tonight we find out that they're

17     concerned about our health after the fact.  Can we get some

18     answer here tonight.   Is there  a problem?  Is  there a  risk

19     problem? Am I safe to walk down the Arsenal Mall?  Am I

20     safe to walk into the Arsenal?

21            I  see,  Carmen over there,  he's worked the Arsenal

22     for many years.   We grew up together in these  chambers, he

23     and I and we're still living.   I don't  know, is there  a

24     risk, is or isn't there a health factor here?   Can we  get an

25     answer?

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 1            I  see  some  gentlemen on my right,  whom I  don't

 2     recognize,  but I've seen them around the Arsenal,  maybe they

 3     have an answer.   Is there a problem?  Is that reasonable

 4     guestion?

 5            THE  CHAIRMAN:  I  think all  guestions  are

 6     reasonable,  sir.   However,  I'd like to bring it  back—

 7            UNKNOWN: Can we  get  an answer?

 8            THE  CHAIRMAN:  Pardon me,  sir?

 9             UNKNOWN:  Can we get an answer?

10            THE  CHAIRMAN:  We're  going  to have to talk off

11     line because,  once again,  I'm going to have to bring it back

12     to the fact that  this is on the soil remediation,  but  we

13     will stay here afterwards and try to answer those guestions

14     for you.

15            UNKNOWN:  We're  here is the DEP now.   Is  there  a

16     health problem there?  Is it safe to walk through that area?

17            THE  CHAIRMAN:   I've  been all through it,  I  would

18      say so.

19            UNKNOWN:  We're  talking about soil remediation  or

20     soil removal  and  then the guestion we want to know as  an

21     ordinary citizen,  not being engineers and not being

22     environmentalists,  is there, is the area safe?

23            THE  CHAIRMAN:   Sir,  can we talk off  line?

24             UNKNOWN:   You can talk whichever way you like,

25     sir.

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 1            THE  CHAIRMAN:   Thank you.   I  have  an open podium

 2     again.   Other concerns?  Other comments?

 3            (No  response.)

 4            THE  CHAIRMAN:   No other comments?   No other

 5     records to  enter into the public record?   Yes,  ma'am.

 6            MS.  PETITTO DEVANEY:   I'd just  like say,  I was

 7     talking as  a life long citizen,  what I feel from my heart,

 8     but I was not talking for the counsel, but I am a member of

 9     the,  I  represent everyone in Watertown on every street.   I

10     am a counselor at large.

11            THE  CHAIRMAN:   Okay.  And will you,  can you note

12     that in your letter that you are sending  to us?

13            MS.  PETITTO DEVANEY:   I can.

14            THE  CHAIRMAN:   Either way you want to go with that

15       one.   Sir?

16                   MS.  ROBERT CHASE:   I'm sorry to come up with  a

17            seconds comment,  but it's Bob Chase again,  only  as local

18     resident, and we did have a problem when  we took over  the

19     first part  of the Arsenal.

20            We didn't have the resources  that  have been made

21     available on this second step on the Arsenal recovery,  but

22     we tried to be as rational as we could.

23            And  one of the hottest areas  that  we new of,  but

24     we never got a report on it.  We ask for  reports from  people

25     that we thought were responsible,  but  there weren't any

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 1     responsible people in those days.

 2            We  put  the  worst  area that  we  knew of under the

 3     tennis courts,  because we figured  the asphalt that we

 4     covered the area with would help to reduce the amount of

 5     radiation.

 6             In a joking manner, we said,  'Well, when they're

 7     playing tennis,  the only stand on  one foot at a time so the

 8     radiation  will be  cut in half.'

 9            This is  how the citizens  approach these technical

10     problems.   It's not good,  but it's been made into a big

11     business now,  the  recovery, the  restoration of values which

12     have been  destroyed and  is currently all over the country,

13     has been made  into a super large business.

14            I am concerned about people that are deriving

15     great profits  from this  effort.  I think they are not

16     working in the interest  of the citizenry,  they're working

17     for their  own  benefit.  And unfortunately this attitude of

18     mine has not spread throughout the country so that very few

19     people will even vote.

20            I vote  as a matter of conscious.   I'm not happy

21     with who I vote for,  but I don't miss an election, and I

22     think it's one of  the last privileges of citizenship.  It

23     doesn't mean anything from your  vote, except you get it off

24     your back.

25            And I'm sorry to  make these comments in public,

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 1     but I,  I just,  I still think this is the greatest place in

 2     the world to live.   One the other hand,  our government is

 3     continually degrading the process.

 4            And Grecian's Law operates in political,  as well

 5     as,  economic areas.

 6            THE CHAIRMAN:  Let me bring it back again.   Let me

 7     bring back the  soil  remediation.   And let me see,  do we have

 8     any more comments regarding our proposed plan for soil

 9            remediation at the Arsenal.

10            (No response.)

11            THE CHAIRMAN:  With no other comments for the

12     record, I'll call the public hearing to a close.

13            (Whereupon, at 7:58 p.m.,  May 13,  1996 the above

14     hearing was concluded.)

15

16

17

18

19

20

21

22

23

24

25

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 1

 2               CERTIFICATE OF REPORTER AND TRANSCRIBER

 3                 This is to certify that the attached proceedings

 4
       in the Matter of:
 5
       HEARING RE:
 6
              INFORMATION SESSION -  OUTDOOR REMEDIATION OF SOIL
 7
 9

10

11      Place:  Watertown,  Massachusetts

12     Date:  May 13,  1996

13

14     were held as herein appears,  and that this is the true,

15     accurate and complete transcript prepared from the notes

16     and/or recordings taken of the above entitled proceeding.

17

18

19      E. Pederson                             05/13/96

20     Reporter                          Date

21

22     L.  Gallo                          5/20/96

23     Transcriber                       Date

24

25

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                                APPENDIX C.4

           SUPPIiEMENTAL DOCUMENTATION ON CHANGE IN SEIiECTED REMEDY




MEMORANDUM FOR COMMANDER, U.S. Army Environmental Center, ATTN:
                   SFIM-AEC-BCB,  (Mr. Waugh)  Aberdeen Proving Ground, MD 21010-5401

SUBJECT:  U.S. Army Materials Technology Laboratory  (MTL), Watertown, MA, Comments on Draft Record of
Decision (ROD)

1.     Reference:  Draft ROD Summary dtd June 96.

2.     We are providing updated information for your reference in the ROD.  As part of our predesign
efforts, our office contracted with ABB Environmental Services to perform Toxicity Characteristic
Leachate Potential (TCLP) sampling on soils at the MTL site.  Earlier this month we reported that the
test results for Area I were negative indicating non hazardous material; and positive for Area M,
indicating a hazardous classification.  Subseguent laboratory reports for the remainder of the sampled
areas at MTL show no further failures, indicating the soil would be classified as non-hazardous.

3.     The above information will impact the cost information presented for alternative  S6, Soil
Excavation and Off-Site Disposal/Reuse.  We estimate that project costs for this alternative would now be
in the $5-6 million range, but leave the detailed estimate to your office and contractor.  Also,
performance times, while not TCLP related, should be reduced.  We estimate that design/contracting
reguirements for this alternative would allow construction to begin in about six months and remediation
could be completed in six to nine months.

4.     If you have any guestions, please call Mr.  Waskiewicz at 617-647-8607.

FOR THE COMMANDER:



Copies Furnished:

U.S. Army Material Technology Laboratory, ATTN:  AMSRL-OP-WT-BR
       (Ms.  Tringali), CARETAKER FORCE, 395 Arsenal St., Watertown, MA 02172-0001
Meghan Cassidy  (HAN-CANI), US Environmental Protection Agency, JFK Federal
      Building, Boston, MA  02203
Albe Simenas, Massachusetts Department of Environmental Protection, Bureau
      of Waste Site Cleanup, 1 Winter Street, 5th Floor, Boston, MA  02108
-------


7464-00
August 1, 1996

Ms. Simone Shields
U.S. Army Corps of Engineers
New England Division
424 Trapelo Road, Building 112S
Waltham, Massachusetts 02254-9149

Subject:      TCLP Soil Sampling Results
              Army Research Laboratory-Watertown, Massachusetts

Dear Ms. Shields:

On June 25 and 26, 1996, ABB Environmental Services, Inc.  (ABB_ES) collected a total of ten soil samples
from areas identified for remediation in the Remedial Investigation Report  (Weston, 1996).   All sampling
areas are shown on Figure 1.  Soil samples were collected in accordance with the Chemical Data
Acguisition Plan  (CSAP) using a lined stainless steel hand probe to retrieve a soil sample from 0 to 2
foot below ground surface. The hand probe was advanced through paved areas utilizing an electric jack
hammer, and through lawned areas utilizing a 30 pound slide hammer.  The dedicated acetate sleeve was
replaced before collecting each sample and the stainless steel hand probe was decontaminated with an
alconox and a deionized water rinse between sampling areas.

Nine of the ten samples consisted of a five-part composite, however, due to the thickness of the road bed
material beneath Kingsbury Avenue, one soil sample  (collected from Area I) consisted of a three-part
composite.  Sampling locations were chosen to bias the composite while still collecting a representative
sample.  All composite samples were mixed throughly in the field using dedicated stainless steel bowls
and spoons, and then allocated into the appropriate sampling jars.  Sample were submitted to National
Environmental Testing, Inc. (NET) of Bedford, Massachusetts for one or more of the following analyses:
Toxicity Characteristic Leaching Procedure (TCLP) semivolatile organic compounds (SVOCs), TCLP metals,
and TCLP pesticides and herbicides.

Soil samples collected from Areas I and M were submitted to NET with a reguested turn around time of 48
hours.  Samples submitted from the eight other sampling areas were submitted for the standard 30 day turn
around.  Sampling locations are shown on the Surface Soil Sample Field Data Records (Attachment A)  and
the sampling results are summarized in Table 1.  All laboratory results are provided in Attachment B.  A
Data Validation Memorandum  (Attachment C) documents the data validation process which was performed in
accordance with the CDAP.

                            ABB Environmental Services, Inc.

110 Free Street                   Telephone  (207) 775-5400           Fax  (207)  772-4762
P.O. Box 7050
Portland, Maine 04112-7050
-------
Ms. Shields
08/01/96
Page 2 of 2

No constituents were detected above the practical quantitation limits in the  soil  samples  collected  from
Areas D, H, I, and 0; therefore, soils from these areas are not considered hazardous material.

Because the sampling results from Areas B, F, J, K, and L did not exceed regulatory levels,  soils  from
these areas are also considered nonhazardous.   With the exception of Barium, no other  sampling  results
from these areas were reported above the practical guantitation limits.  Barium results  range  from 0.52
to 1.1 milligrams per liter  (mg/L) which are significantly lower than the regulatory level of  100  mg/L.

No SVOCs, pesticides or herbicides were detected above the practical guantitation  limits in the  soil
samples collected from Area M.  However, three metals barium, chromium, and lead were reported at  0.91
mg/L, 0.054 mg/L, and 5.1 mg/L, respectively.  Only lead  (5.1 mg/L) was detected at a concentration  that
exceeded the regulatory level of 5.0 mg/L. Because the results slightly exceeded the regulatory  level  for
lead, soils removed from Area M may reguire hazardous classification.

If you have any guestions regarding this submittal or reguire additional information, please do  not
hesitate to contact me at  (207) 775-5401 ext. 3637;

Sincerely,

ABB ENVIRONMENTAL SERVICES, INC,



Neison Walter. P.E
Project Manager

Enclosures
       K. Tringali (ARL-WT)        J.
       M. Borisky (ARL-Adelphi)    F.
       R. Hager (MRD)              B.
       A. Simenas (MADEP)          P.
       M. Cassidy (USEPA)          J.
       S. Ferguson (SWETS)         A.
       S. Falkoff (WCES)           N.
       File
Okun  (O'Reilly, Talbot & Okun)
Mack  (Watertown Free Library)
Chase  (RAB)
Hoskins  (Weston)
Waugh  (AEC)
Bates  (ABB-ES)
Glucksberg  (ABB-ES)
-------
                                                                                                                                Table  1
                                                                                                               Summary of TCLP Soil  Sampling Results
                                                                                                                        Army  Research  Laboratory
                                                                                                                        Watertown, Massachusetts
                                                                                                                    Sampling Area
                                                                                                            Area H             Area I             Area J
  m-Creaol
  o-Creaol
  p-Creaol
  Total  Creaol
  1,4-Dichlorobenzene
  2,4-Dinitrotoluene
  Hexachlorobenzene
  Hexachlorobutadiene
  Hexachloroethaoe
  Nitrobenzene
  Pentachlorophenol
  Pyridine
  2,4,5-Trichlorophenol
  2,4,6-Trichlorophenol
Herbicides and Pesticides  (mg/L)
  Chlordane
  Endria
  Heptachlor  (and its epoxide)
  Gamma-BHC  (Lindane)
  Methoxychlor
  Toxaphene
  2,4-D
  2,4,5-TP(Silex)
Inorganics  (mg/L)
  Arsenic
  Barium
  Cadmium
  Chormium
  Lead
  Mercury
  Selemium
  Silver
<0.020
<0.020
<0.020
<0.020
<0.020
<0.020
<0.020
<0.020
<0.020
<0.020
<0.020
<0.020
<0.020
<0.020
<0.020
<0.020
<0.020
<0.020
<0.020
<0.020
<0.020
<0.020
<0.020
<0.020
<0.020
<0.020
<0.020
 <0.020
 <0. 020
 <0.020
 <0.020
 <0. 020
 <0.020
 <0.020
 <0.020
 <0.020
 <0.020
 <0.020
 <0.020
-------
                                                   Estimated Capital Costs for Alternative
                                       Soil Excavation and Off-Site Disposal or Reuse-Site
                                                                             S6:
                                                                             Reuse Scenario 3
Item

 1

 2
 4

 5

 6

 7

 8

 9

 10

 11

 12
 13
 14
 15

 16

 17
 18
                Description

Excavate, transport, and stage contaminated material

Transport and dispose of excavated material as
contaminated waste at a landfill (without stabilization)

    •  Hazardous waste (550 yd3 @ 1.4 tons/ydS =
    •  Nonhazardous waste  (23,050 yd3 @ 1.4
         tons/ydS = 32,270 tons)

Backfill excavated areas:

    •  Import and place clean soil at excavated areas,
       grade and contour
    •  Import and place topsoil, 6 inches thick
    •  Seeding and mulching,  revegetation

Other restoration issues and landscaping

Construction air monitoring

Health and safety during excavation

Excavation stockpile sampling and analysis

Excavation delineation sampling, mobile laboratory

Erosion and sediment controls

Permitting

Mobilization/demobilization

Institutional controls for contaminated soil underneath
buildings

                  Subtotal
Engineering,  procurement, administrative, and legal
costs (20%)

                  Subtotal

Government construction management (7.5%)

Contingency (25%)
                Total (Rounded)

Quantity
23,600 yd3
770 tons
32,270 tons
23, 600 yd3
3,940 yd3
23,600 yd3
lump sum
lump sum
113 days
95 samples
113 days
lump sum
lump sum
lump sum
lump sum




Unit Cost
($)
13.60/yd3
246/ton
65/ton
16.10/yd3
13.80/yd3
0.72/yd3
8,000
10,000
750/day
2, 000/sample
2,000/day
10,000
7,500
10,000
5,000




Total Cost
($)
320,960
189,420
2,097,550
379,960
54,372
16,992
8,000
10,000
84,750
190,000
226,000
10,000
7,500
10,000
5,000
3,610,504
722,100
4,332,605
324,945
1,083,151
5,741,000
-------
         TOWN OF WATERTOWN
                             ADMINISTRATION BUILDING
                         WATERTOWN,  MASSACHUSETTS 02172
                             ARSENAL REUSE COMMITTEE

                                                        August 14, 1996
Mr. Chuck Paone
Base Transition Coordinator
US Army Caretaker Force
395 Arsenal Street
Watertown, MA  02172-2700

RE:    Proposed Plan for the Clean-up of the Former US Army Materials Technology Laboratory

Dear Chuck:

At a joint meeting held on August 8,  1996 with the Restoration Advisory Board (RAB),  the Arsenal Reuse
Committee voted to reguest that the Army utilize the Contingency Alternative of off-site disposal as the
method to remove contaminated soil from the former AMTL property.

As you know, representatives from the Army, Environmental Protection Agency, and Mass Department of
Environmental Protection were present to explain the process by which the alternative became feasible,
and to answer guestions regarding its safety and effectiveness.  We appreciate the sincere and thorough
manner in which all concerns were addressed.

The Reuse Committee expressed its preference for the alternative based upon the conclusion that it will
be egually safe to human health and the environment, it is a proven technigue, and it will allow for a
shorter remediation timetable by approximately one year.

During the meeting, several concerns regarding the trucking of the soil were voiced.  As part of this
reguest, we would urge that the Army work closely with community residents and public health and safety
officials to mitigate any offensive impacts.  For example, truck routes, access, and hours of operation
must be closely regulated to prevent negative effects. Our input should be considered while your workplan
is being developed.

Thank you for your continuing cooperation on this important project and please contact us if you have any
guestions or need further information.
                                                
       Town Council
       Town Manager
       Rep. Jos. P. Kennedy
-------
  Alex Liazos; 11 Otis St.; Watertown, MA  02172
                 15 August 1996

Bob Chase, RAB co-chair
Army Research Laboratory
395 Arsenal Street
Watertown, MA  02172

Dear Bob:

This letter is in response to your 9 August 1996 memo to the RAB.

First, let me state plainly that at the 8 August meeting I did not oppose off-site disposal of the soil.
Rather ,  I did not think that we could or should decide on the proposed change in clean-up that night.
This was a major change and it should be given more thought and debate than one night could afford.
Given that we have been meeting for years, and given that we never discussed at any length off-site
disposal  (since it never seemed a viable option), it seemed wise to wait a few days.  I regret that there
will not be a RAB meeting before 21 August so we could discuss, ask questions, and debate before we made
recommendations. That would have been the best course for Watertown and for the environment.

First, let me applaud the EPA's preference for cleaning up soil instead of burying it somewhere else,
even if it does meet standards for other uses.  We should clean up, not move to another community.

Second, there is a new issue that occurred to me a few days after the meeting.  Since all soil will be
new and clean soil, does that mean that we will now have residential clean-up standards throughout the
site?  In a conversation 13 August Dennis Waskiewicz told me that he thinks that will be the case.  If
so, it should give the town more flexibility of future uses.


Third, we need some explanation of the process of off-site disposal.  Are there any possible hazards,
such as dust created during the clean up?  I do not assume there are hazards, but some of us need some
explanation and assurance.

In conclusion, I offer a qualified endorsement of off-site disposal. We need answers to the above
questions.  But even more, as I note above, it would have been much better if there were more discussion
before the 21 August deadline.  I hope there will be an opportunity to explore all concerns and questions
at our Sept. meeting.
                          
-------
                                 THOMAS J. STEVENS
              13 LAWRENCE STREET, WATERTOWN, MASSACHUSETTS  02172-1859

Mr. Robert Chase
Co-Chair, Restoration Advisory Board  (RAB)
U.S. Army Research Laboratory Caretaker Force
ATTENTION:  AMSRL-OP-WT
395 Arsenal Street
WATERTOWN MA  02172-2700

                               RE:  Your Memorandum of 9 Aug 1996 to RAB

Dear Bob:

It was nice to have finally again been able to attend a RAB meeting, specifically the one held jointly
last Thursday (8 August) with the Town of Watertown's Arsenal Reuse Committee.  Although I walked in
late, the discussion, documentation provided and prior correspondence, meetings and experience allowed me
to get "up-to-speed" rather quickly.

Your recent memorandum  (dated 9 August 1996) further summarized the meeting and invited RAB members to
express their views on their preference of either chemical oxidation or off-site soil disposal as
remediation methods for the former MTL site.  I sensed that my animated response may have been
mis-interpreted as adversarial or at least attitudinal, so I would like to take this opportunity to
recapitulate my preference for chemical oxidation to remediate the soil contamination at the "Arsenal"
site.

The way I see it, both methods are time-uncertain in reality, but one has the potential for an earlier
completion by about one year.  Both involve certain assumptions, such as no "new" contamination will be
"discovered", funding remaining intact, safety concerns being met and cost/time estimates proving to be
accurate.  The risks and benefits for each may be found to be inaccurate but likewise may well prove to
be correct.  It seems to me that the potential (i.e., unproven) savings of one year provides a minimal
benefit to the Town in that only one year of additional tax revenue MIGHT be realized, assuming that
development and any related Town-acguisition actually goes on-schedule.  Historically these "golden egg"
delusions realize a lot of false leads, broken promises and delays.  Even if both plans could guarantee a
definite time-line, I would still prefer the on-site chemical oxidation method for environmental, safety
and ethical reasons.  I would also feel that the chemical oxidation method would best address any new
"discoveries" of previously unrecognized contamination that off-site disposal could not.  I have briefly
summarized my comparison of the two methods as follows:
-------
Method
                                  PROS
                                                              CONS
Chemical
Oxidation
Off-Site Disposal
Lower Cost

Elimination or
containment of
contaminants

Provides for an
alternative
method

No "en-route"
risk of human
exposure to soil

Method of choice
of US Army and
regulators
Potential 1-year
savings in time-
to-completion

Proven
technology
Unproven
technology
Higher cost

Higher risk of
exposure

Lacks alternative
 method

Simply relocates
problems - perhaps
with future
remediation cost
elsewhere

-------
 1                                                     1-77

 2

 3                          UNITED STATES OF AMERICA

 4                         DEPARTMENT OF THE ARMY

 5                         RESTORATION ADVISORY BOARD

 6

 7

 8  In the Matter of:

 9  HEARING RE:

10  FEASIBILITY STUDY REPORT
    REFUSE PLAN
11

12
                           Town Hall
13                            Lower Conference Room
                              Watertown, Massachusetts
14

15                            Thursday
                              August 8, 1996
16

17

18
              The above entitled matter came on for hearing,
19
    pursuant to Notice at 7:00 p.m.
20

21
    BEFORE:  ROBERT CHASE
22           U.S. Army Research Laboratory
             395 Arsenal Street
23           Watertown, MA  02172

24

25

                             APEX Reporting
                              (617) 426-3077
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    PRESENT:

 1
        SUSAN FALKOFF
 2
        ALEX LIAZOS
 3
        RICH RAGO
 4
        DENNIS WASKIEWICZ
 5
        PAUL DENNING
 6
         THOMAS SHERRY
 7
        ROBERT CHASE
 8
        TOM STEDMAN
 9
        JOHN PORTZ
10
        BILL YORK
11
        MARK BOYLE
12

13

14

15

16

17

18

19

20

21

22

23

24

25
                             APEX Reporting
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 1                         PROCEEDINGS

 2                                                      [7:00 p.m.]

 3            MS.  FALKOFF:   The Reuse Committee would be

 4  interested to know,  John Arasian [phonetic] is very

 5  regretfully not able to be here this evening and has asked

 6  me to chair in his absence.  He notified the Reuse Committee

 7  of that,  but RAB members are probably hearing that for the

 8  first time, so he is really sorry not to be here.

 9     John also sent a  letter that the Reuse Committee

10  members have received.   Are there copies for the RAB

11  members?  Okay.  So, we will pass that around.

12     Since not all the Reuse Committee members and the RAB

13  members know each other, I want to -- Maybe people can say

14  who they are and which group they're part of, around the

15  table.

16     I'm Susan Falkoff,  co-chair of the RAB and chair of the

17  Environmental Subcommittee of the Reuse Committee.

18          MR. DENNING:  I'm Paul Denning of the RAB and also

19  on the Town Council.

20          MR. RAGO:  I'm Richard Rago and I'm on the RAB.

21           MR. STEDMAN:   I'm Steve Stedman and I'm on the

22  Reuse Committee.

23          MR. CHASE:   Bob Chase, Reuse Committee.

24          MR. SHERRY:   Tom Sherry on the Reuse Committee.

25          MR. PORTZ:   John Portz on the Reuse Committee.

                             APEX Reporting
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 1          MR.  YORK:   Bill York on the Reuse Committee.

 2          MR.  LIAZOS:   Alex Liazos on the RAB.

 3           MR. BOYLE:   Mark Boyle from the Town Planning.

 4           MS. FALKOFF:  Okay.  Good.  As you know,  we're

 5  here because there's some new information that's led to some

 6  new thinking about the clean-up and I think I'll just turn

 7  the meeting over to Dennis,  who's going to tell us about

 8  this.

 9     Dennis Waskiewicz from the Corps of Engineers.

10           MR. WASKIEWICZ:  All the slides that I have are

11  all in the packet that you got.  Does everybody have a

12  packet?  Or, anybody that didn't get a packet.   Okay.

13     What I'd like to do is to just briefly go  over  what's

14  in the proposed plan for the remediation, the soil

15  remediation at MTL,  and then, go into some of the  test

16  results that we had from sampling we did this summer and

17  indicate what it does to both the preferred plan,  preferred

18  remedy, and the contingency alternative.

19     The proposed plan lists a preferred remedy of

20  excavation and treatment with chemical oxidation.

21  Basically, what this means is that we're going to  excavate

22  soil to approximately three feet deep, initially,  and in an

23  aerial extent until     we find that we  have  soil  that needs

24  clean-up holes.

25     The chemical oxidation involves adding water and

                             APEX Reporting
                             (617)  426-3077
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 1  chemicals,  which are silicates and various oxides which are

 2  proprietary to a couple of companies that do this; mix it

 3  all together and what it does is,  it oxidizes organics and

 4  in some cases, what they call complexes heavy metals to put

 5  them in a different form.

 6     Because  it's an innovative technology,  we're not sure

 7  it's going to work for the soils at Watertown, so we've

 8  always been carrying a contingency alternative, which is

 9  excavation, the same as the other one,  and off-site disposal

10  or reuse.  This will be implemented --  the proposed plan

11  indicates that it will be implemented for a couple of

12  reasons; if the treatability studies on the chemical

13  oxidation fail, or if the economics change such that

14  chemical oxidation is no longer advantageous.

15     The Army has a proposed plan and a preferred

16  alternative; so, why are we here?

17     As part  of our general information gathering,  as part

18  of our pre-design activities, we did some sampling and did

19  some, what we call, TCLP, or toxicity leaching procedure.

20  It's on the next page.  And, those test results provides

21  some information which changed some of  the evaluation

22  criteria for the alternative plan; mainly, they reduced the

23  cost by about one-half.  Because of this and because these

24  are part of the factors in selecting the preferred remedy,

25  we thought it would be important to bring it back before the

                             APEX Reporting
                             (617) 426-3077
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 1  community to reevaluate these

 2     I'd like to spend just a minute on -- Let me go to

 3  another slide here.   Okay.

 4     So,  what is a toxicity characteristic leaching

 5  procedure?

 6     Why we gathered it is because it provides information

 7  that allow us to evaluate disposal options.   More basic

 8  than that, what it does is, it takes a sample of soil,  runs

 9  a liguid through it, like water or an acedic acid and

10  measures the amount of contaminants that come out in that

11  liguid.  It's used to identify what's hazardous in terms of

12  a definition and what's non-hazardous.

13     Up to this point, all our studies to date in the

14  remedial investigation and the feasibility study, we have

15  been making various assumptions as to what the hazard

16 classification would be.  And, for disposal purposes, we're

17  assuming a 50/50  mix; 50 percent hazardous and 50 percent

18  non-hazardous.

19     What really drove us to doing some additional testing

20  this summer was — you're aware that we're trying to

21  accelerate clean up of Building 131 and adjacent soils.  We

22  knew we were going to do off-site disposal for that one area

23  of soil remediation, so we did a TCLP test specifically for

24  that, but then expanded it to the rest of the MTL site to

25  evaluate that also.

                             APEX Reporting
                              (617) 426-3077
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 1     Now,  one thing that TCLP does not do,  it doesn't affect

 2  the risk.  So,  all the clean-up plans and the preferred plan

 3  that was developed through the whole RI/FS process remains

 4  the same.  In other words, the basic testing that was

 5  performed since 1991 defines which contaminants are

 6  contaminants of concern,  which ones cause risk and which

 7  ones reguire remediation.

 8     Just  guickly going over what these TCLP results were.

 9  You can see -- Basically, I'11 sum up some data tables and

10  various  people have this.

11     For the whole MTL site, except what we call area "M",

12  the TCLP results were negative.  In other words,  the

13  contaminants were not leached out by passing a liguid

14  through them.  This puts the soil into a non-hazardous

15  classification.  Area "M", which is an area along the

16  Charles  River,  on the south side of North Beacon Street,  did

17  have a positive TCLP test, which classifies it as hazardous.

18     Now,  I didn't know whether I was going to get  into any

19  data,  but just in looking at some of the levels that were

20  reached in this TCLP test, and I've got a couple of

21  footnotes down at the bottom talking about that the

22  contaminants coming out are the analytes, were not detected

23  about the Practical Quantification Limits, those things that

24  can be measured in the lab, except Barium and Chromium.

25  And, I'm talking about two orders of magnitude here.  There

                             APEX Reporting
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 1  were two orders of magnitude less than evaluation criteria.

 2  And, what that means is,  like for Barium, the TCLP test was

 3  yielding results of one.   The evaluation criteria is a

 4  hundred.  And, that's what we mean by two levels of

 5  magnitude here.  Similar for Chromium, .05 versus 5.

 6     The area M failed for lead only.   There was Barium and

 7  Chromium there, but it didn't fail for those.

 8     The significance of this is,  I mentioned that we

 9  gathered TCLP to evaluate disposal options.  Non-hazardous

10  soils can be used in reuse as a daily cover at landfills, or

11  in asphalt batching.  Hazardous materials have to go in a

12  landfill as a hazardous material.

13     What really becomes important is  the cost to do this.

14  Right now, costs for daily cover, and even though somebody's

15  using this material, we still pay to take it there, are $65

16  a ton.  Hazardous material is $245 a ton.  So, there's a

17  factor of four here.

18          FROM THE FLOOR:  It seems like the biggest problem

19  is the organics.

20          MR. WASKIEWICZ:  TCLP is done for the organics,

21  for the pesticides and the others.  In effect, all the

22  organics were leaching out at less than the guantification

23  level.

24          MS. FALKOFF:  Are you saying that all the soil

25  except for Area M is reusable?

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 1          MR.  WASKIEWICZ:   In terms of daily cover and

 2  landfill or asphalt batching,  yes.

 3          MS.  FALKOFF:   One hundred percent,  except for Area

 4  M,  can be reused?

 5          MR.  WASKIEWICZ:   That's the way our tests show

 6  right now; yes.

 7          FROM THE FLOOR:   Dennis,  could you just explain

 8  Area M.

 9          MR.  WASKIEWICZ:   Area  M is at the east end of the

10  MTL property, actually on the  yacht club property, and the

11  TCLP there failed for lead.

12          FROM THE FLOOR:   What  do you mean,  on the yacht

13  club property?  Is it on the site?

14          MR.  WASKIEWICZ:   It's  on the property, but it's on

15  the yacht club site.

16          MS.  FALKOFF:   So,  it's not the grassy area down by

17  the bridge.   It's a little bit west of that.

18          MR.  WASKIEWICZ:   It's  in the boat storage area,

19  right by the boats.

20          MR.  LIAZOS:  It's across from North Beacon Street.

21          MR.  WASKIEWICZ:   Yes.

22          MR.  LIAZOS:  It's the  site that's going to be

23  reused.

24          MR.  WASKIEWICZ:   It's  on the site which is

25  proposed to go to the MDC.  The whole south side of North

                             APEX  Reporting
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 1  Beacon Street.   I don't have a drawing.

 2          FROM THE FLOOR:   When you say "reusable",  do you

 3  mean used in the arsenal or some other place?

 4          MR.  WASKIEWICZ:   At an approved landfill.   All

 5  landfills,  the way they operate, they bring in our trash and

 6  spread it out and every day they put a layer of soil over

 7  it.   This can be used as a daily cover that's needed to do

 8  that.

 9          FROM THE FLOOR:   And,  if you do that,  then,  are

10  you going to replace it with different soil here?

11          MR.  WASKIEWICZ:   That's correct.   What we do is,

12  we excavate and we have a hole and then we have to bring in

13  clean fill.

14          FROM THE FLOOR:   How clean is that fill?  I'm

15  serious.

16          MR.  WASKIEWICZ:   Let me just relate to another

17  major backfilling thing we did.  When we backfilled the fuel

18  tank farm.   In fact, let me talk about backfilling totally.

19          FROM THE FLOOR:   Can you test the soil for Arsenal

20  Park,  what laboratory used given the 150 years?

21          MR.  WASKIEWICZ:   I guess that's  a different

22  subject, but, yes, we have.  We have --

23          FROM THE FLOOR:   Both times.  This time it is

24  different.

25          MR.  WASKIEWICZ:   We have tested it in 1994 and

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 1  we're doing the second round of testing right now.   So,  we

 2  have and we're going to evaluate the test results and we're

 3  going to come to some sort of conclusion as to whether

 4  there's risk or not, just like we've done at the MTL site.

 5          FROM THE FLOOR:   Where is this result?

 6          MR.  WASKIEWICZ:   Excuse me?

 7          FROM THE FLOOR:   Where is this result?

 8          MR.  WASKIEWICZ:   We have published two reports so

 9  far, a preliminary assessment in 1993 and that report is in

10  the library.  Then,  in 1995, we have published a

11  supplemental investigation report,  which reports on all the

12  data points that we took, and that report is also in the

13  library.  And, if you can't get it, call me and I will see

14  that you get one.

15          MS.  FALKOFF:  Are you surprised by the fact that

16  you found so little, on the basis of your previous testing,

17  are you surprised to have arrived at these results now?  I'm

18  just wondering to what to attribute the difference.

19          MR.  WASKIEWICZ:   Well,  we've never done a TCLP

20  test.  We've made an assumption which is pretty much

21  standard procedure during the investigation phase.

22          MS.  FALKOFF:  I  was just wondering how you made

23  your assumptions.

24          MR.  WASKIEWICZ:   For one thing,  we're in the

25  investigation phase.  What we're really looking to do is to

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 1  define risk.   And,  like I said,  TCLP does not affect risk.

 2  So,  it's the bulk sampling analysis, just how much stuff is

 3  there that determines the risk.

 4          MS.  FALKOFF:   So,  first  you figured out what was

 5  there and what was  risky that was there.

 6          MR.  WASKIEWICZ:   Right.   Then,  you're able to

 7  define your areas that don't meet the clean-up standards.

 8  Then, from there, you develop alternatives.

 9     So,  to do TCLP really in the  ball game,  is — Well,

10  TCLP's are expensive, for one thing.  I don't know exactly

11  how much, but they're expensive.  So, you don't want to do

12  them just casually.

13     I've been told that a trained eye could have looked at

14  the data and said your contamination levels aren't really

15  high and we could have predicted that these may not have

16  failed TCLP.   Right now, that's  second guessing as far as

17  we're concerned.

18          MS.  FALKOFF:   So,  was this the first time that you

19  actually measured guantitatively?

20          MR.  WASKIEWICZ:   This is the first time we've

21  determined whether  or not the soils would be classified as

22  either hazardous or non-hazardous.  And, that's different

23  than whether or not they have risk.  Maybe somebody can

24  explain it better than I can.  I'm not sure.

25          FROM THE FLOOR:   What's  the difference between

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 1  being hazardous and being at risk?

 2          MR.  WASKIEWICZ:   Okay.   There's about four ways

 3  and I think the EPA defines whether a material is hazardous.

 4  Whether it's toxic, and that's what we're looking at here.

 5  Whether it's ignitable,  like gasoline, corrosive, or gases,

 6  or reactive.  I don't know it would be reactive.

 7     So,  those are four ways that you can tell if it's a

 8  hazardous material, if they exhibit characteristics.  And,

 9  they get special attention because they are hazardous and

10  they exhibit a special problem.

11     In terms  of the TCLP,  again, we're back to the

12  definition and toxicity is right there.  What we're looking

13  at is toxicity.  So,  we've looked at the soil and determined

14  concentrations of contaminants.  In this case we determined

15  that PAH's,  pesticides are primary contaminants which are a

16  driving risk on the MTL site.  There's also some metals in

17  the soil.  Those are risk drives.

18     We could proceed ahead without ever determining

19  hazardous classifications.  If we were to stay with the

20  chemical oxidation, we would treat that soil and supposedly

21  reduce the contaminants,  or we would take it off to a

22  landfill and it would confine those contaminants in such a

23  way that it wouldn't -- they wouldn't be a problem.

24     If we were ever going  to take it to a landfill,  we

25  would always have to go back and do a TCLP because the

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 1  landfill wouldn't accept it without that.

 2          MS.  FALKOFF:   Are you saying this  is more

 3  extensive testing?  I feel still not really like I'm

 4  understanding the difference between the two kinds of tests.

 5  Are you saying that risk just has to do with we'll set the

 6  levels that were predefined as clean, but we don't yet know

 7  how dirty it is?  Are you saying that?  Can you help, Megan?

 8          MS.  CASSIDY:   If we were treating the soil on

 9  site,  we would never need to know whether it was hazardous

10  or non-hazardous.  As Dennis said,  the purpose of the

11  remedial investigation --

12          MR.  WASKIEWICZ:   Megan,  would you mind just

13  identifying yourself?

14          MS.  CASSIDY:   Sorry.   Megan Cassidy,  EPA,

15  Environmental Protection Agency.

16     As  Dennis just said,  remedial investigation and the

17  baseline was successful for trying to establish whether

18  there  is risk and at what level that risk is.  That's your

19  standard testing.

20     The TCLP information that was collected affects cost

21  because TCLP, hazardous versus non-hazardous impacts only

22  the cost estimate, if the material is going off site.  If

23  you're treating the material on site, i.e.,  chemical

24  oxidation,  hazardous versus non-hazardous is not an issue

25  because you're cleaning the soils to the risk base number,

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 1  so it has no implications,  which is why it is not uncommon

 2  that in the early phases you do not automatically take TCLP

 3  data because,  again,  unless you're looking at an alternative

 4  which is to take the materials off site to a landfill or

 5  some other type of reuse,  you don't necessarily need to have

 6  that much detail on the classification.  It really only

 7  impacts off site disposal issues.  Again,  it does not impact

 8  any kind of chemical or insitue treatment that you would do

 9  on the site.  So, it doesn't affect the risk number, but

10  rather what can be done with the soil once you've picked it

11  up and now are going to take it somewhere.

12          MR.  OKUN:  Jim Okun,  consultant to WCES.   Let me

13  add one more piece to what you just heard.  I'll just try to

14  explain this to you.

15     When Dennis and Megan use the term,  hazardous,  they

16  don't mean it the way you would commonly use the word

17  hazardous.  What it means is, it ties into a set of

18  regulations and when something is a hazardous waste, it has

19  to be disposed of in accordance with the hazardous waste

20  regulations.  If it is a non-hazardous waste, then it can be

21  disposed of in accordance with the regulations that govern

22  the management of non-hazardous waste.   So, when they use

23  the word, hazardous,  they don't mean hazardous as synonymous

24  with dangerous.  They mean hazardous as it pertains to a

25  certain set of regulations of how you gave to manage the material.

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 1          MR.  LIAZOS:   Unless you explain those words.

 2  Hazardous is something that means there's something

 3  dangerous about it,  otherwise there wouldn't be any

 4  regulations.

 5          MS.  CASSIDY:   This doesn't impact at all clean-up

 6  standards.

 7          MR.  LIAZOS:   I understand that.

 8          MS.  CASSIDY:   If we look at TCLP, toxicity,  we're

 9  saying that there's something probably in the soil that is

10  considered toxic or has some toxic features to it.  But, the

11  leaching part is what we're looking at here.  This is

12  saying,  if we take this material and put it somewhere, i.e.,

13  in a landfill,  is it going to -- is the material going to

14  leach out and get into the ground.  That's what this is

15  all -- That's why, you know, if you have a hazardous waste

16  landfill, it's very much controlled to ensure that doesn't

17  happen.   It has different collection systems.  That's the

18  TCLP.  We've got something toxic in it, but is it going to

19  leach out and impact the ground water.

20     So,  this, again,  has to do with management of the

21  material, as Jim said, for what you can do with it,  not —

22  it's not a risk issue.  We don't say hazardous, non-

23  hazardous.   We only have to clean up hazardous.  That's not

24  necessarily the case, because you can have unacceptable risk

25  from non-hazardous materials.

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 1          FROM THE FLOOR:   I think I just translated this

 2  into my mind layman's language?  You do the TCLP to

 3  determine what you can do with the soil.

 4          MS.  CASSIDY:   Exactly.

 5          FROM THE FLOOR:   So,  you didn't do the TCLP before

 6  because you weren't going to move the soil, you were just

 7  going to put chemicals on it to remediate it.  But, if you

 8  had -- If you did the TCLP and you found that there was —

 9  that it was going to be classified as hazardous waste, it

10  was going to leach out,  then it would have cost you a lot

11  more to get rid of the dirt.   Is that right?

12          MS.  CASSIDY:   Exactly.

13          FROM THE FLOOR:   You did the TCLP,  you found out

14  it's not leaching.  It's cheaper to get rid of the dirt.

15          MS.  FALKOFF:   What did you do differently to test

16  the soil?

17           MR.  WASKIEWICZ:   We added one test.   You take the

18  sample of the soil and run a liguid through it, either water

19  or acidic acid and measure what comes out the bottom.

20          MS.  FALKOFF:   So,  you did know,  or you might have

21  tested what was there, but you didn't know if it was going

22  to be immobilized or it was going to move.

23          MR.  WASKIEWICZ:   That's right.  It measures the

24  mobility.

25          MS.  FALKOFF:   And, you don't know what contaminant

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 1  it is?

 2          MR.  WASKIEWICZ:   No,  because sometimes you look at

 3  a soil and see contaminants in it and that's -- the

 4  contaminants may be locked up within that soil and not come

 5  out.

 6          MR.  BOYLE:   You don't know the chemical state.   It

 7  could be metal.

 8          FROM THE FLOOR:   You still have to clean it up.

 9  But,  now it's cheaper to remove it.

10          MS.  FALOFF:   That's what we're talking about.

11  It's  still -- It doesn't change the hazardous information.

12          TOWN COUNCILOR:   I think Steve pointed out where

13  Area  "M" is.  Just out if curiosity, why would that be more

14  hazardous?

15          MR.  RAGO:   Area "M",  lead was detected at 5.1

16  milligrams per year.  The criteria is 5.0.  So, it failed

17  that  criteria.  The soil is considered to be hazardous waste

18  because it exhibits that characteristic.

19          FROM THE FLOOR:   Why that area as compared to

20  others?

21          TOWN COUNCILOR:   I'm just curious.

22          Mr.  Rago:    It could be historic use of the

23  property.  It's  over a hill,  right over the road.  It  could

24  be lead from an old gasoline tank.

25          TOWN COUNCILOR:   Thank you.

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 1          FROM THE FLOOR:   Slide 2,  which was entitled,  Soil

 2  Recommendation and Slide 5,  which was TCLP.  Does that imply

 3  that the only soil that would be transferred out of town

 4  would be from Area M?

 5          MR.  WASKIEWICZ:   If  we go ahead with the on-site

 6  disposal,  right now --

 7          FROM THE FLOOR:   I'm sorry.   If you do go ahead

 8  with the off-site, all of M will be taken?

 9          MR.  WASKIEWICZ:   No.   If we go with the off-site

10 disposal, it will all be taken out of town, but Area M will

11  have to go to a different place.

12          FROM THE FLOOR:   Okay.  Now,  the next thing I

13  wanted to know is, the route.  I'm sure you're going to go

14  by DOT, the truckers will go by DOT standards, but I'd like

15  to know the route and maybe  if the cops are going to explain

16  this thing.

17          MR.  WASKIEWICZ:   Let me discuss the trucking of

18  the material because I wanted to bring that out.

19          MR.  YORK:   Given the level at which Area M soil

20  missed concerning the rest of the soil, would you no9t want

21  to verify that?

22          MR.  WASKIEWICZ:   I believe at the time that we're

23  actually doing the remediation, we would verify those

24  factors.

25          MR.  YORK:  It's very  close.

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 1          MR.  WASKIEWICZ:   Yes.   That's true.   As of this

 2  stage --

 3          MR.  YORK:   It has a very large area  on it.

 4          MR.  WASKIEWICZ:   As of this date,  it's still over

 5  the line that's what we're referring to.

 6          MR.  YORK:   I have another point on that.   I knew

 7  we'd find out this time,  but not everything is

 8  necessarily linear.  In other words, the 5.1 might be

 9  extremely high and if we look at it as 5.1  and being very

10  close to 5,  it might be something that's guite high.

11          MR.  WASKIEWICZ:   Again,  I don't know if anybody

12  does.  That point is taken care of.

13     Is there another guestion?

14          MR.  RAGO:   I think the guestion we started on and

15  we went off was, the soil that's coming to replace that

16  which is removed and the guality of that.

17          MR.  WASKIEWICZ:   Let me talk about the trucking,

18  taking the material away to the off-site disposal option and

19  bringing new on.

20     What we're talking about is 24,000 cubic  yards of soil

21  right now; that's our estimate.  What's 24,000 cubic yards?

22  A really large hauling dump truck carries 30 yards.  Some of

23  them carry 20.  So, what we're talking are between 800 and

24  1,200 trucks moving soil off.   I've got an estimated

25  remediation time of eight months.

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 1          MS.  FALKOFF:   How many trucks a day is that?

 2          MR.  WASKIEWICZ:   This is between five to eight

 3  trucks,  depending on the size, taking the material away.

 4  And,  another five to eight bringing the material back on.

 5  So,  we're talking between ten to 16 trucks a day, unless

 6  that same truck is used to do both, which is a possibility.

 7  When he takes away a truck load, he could come back with a

 8  truck load.

 9          MS.  FALKOFF:   They'll be taking it some place that

10  close?

11          MR.  WASKIEWICZ:   We don't direct our contractors

12  where to do this.  In terms of having an influence, yeah, we

13  can influence that.  I know that's been a sensitive issue.

14          MS.  FALOFF:  My guestion is,  where will this

15  asphalt batching plant be?

16          MR.  WASKIEWICZ:   Right now, there's about — DEP

17  lists about nine facilities in the state, about seven of

18  which are from central Mass.  to the east.

19          FROM THE FLOOR:   So, this could be fairly local.

20          MS.  FALKOFF:   A truck could make a round trip in a

21  day.

22          MR.  YORK:  The closest one is in Avon.

23          MR.  DENNING:   Dennis, this is obviously very

24  important to the residential neighborhoods, that the truck

25  be as far removed from them as is possible.

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 1          MR.  WASKIEWICZ:   I can relate — I started

 2  mentioning the job and there we moved about eight or nine

 3  thousand cubic yards in a two-week period, and that

 4  translated into about 350 trucks over ten days, 35 trucks a

 5  day.   So,  we've already seen worse than what we're planning

 6  here and maybe you didn't see it, which is all right, also.

 7          MR.  RAGO:   Which roads are these?

 8          MR.  WASKIEWICZ:   I tried to find out and I

 9  couldn't.   But, basically, that was all backfill and it came

10  from Plymouth.

11          MS.  FALKOFF:   The route was up Route 20 to 128.

12          FROM THE FLOOR:   This past year?

13          MS.  FALKOFF:   Yes.  Through Waltham.

14          FROM THE FLOOR:   Through the town?

15          MS.  FALKOFF:   Oh,  no.  That was the radioactive.

16          MR.  YORK:   I'm going to guess, they may have come

17  up 128 to the Mass. Pike.

18          MS.  FALKOFF:   And, the reason for that was it had

19  to be a state road, which has a different level of

20  construction and an alternative.  I suppose you want to go

21  up Galen Street and minimize the amount of traffic you're

22  going through.  Downtown Waltham is difficult.

23          FROM THE FLOOR:   I've got a guestion.   Now,  we're

24  talking about contaminants.  A truck load of asphalt dug up,

25  dust and everything now, is that dangerous?  I have to ask

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 1 something about this now.   Compared to the stuff they're

 2  taking out of there,  how about a truck load of asphalt?  How

 3  dangerous is that?

 4          MR.  WASKIEWICZ:   Well,  it carries a whole lot more

 5  PR's than the soil.

 6          FROM THE FLOOR:   That's going on at Perkins School

 7  for the Blind for a week.  None of you people knew about it.

 8  Right to Alban Street to Watertown.   Now, nobody worried

 9  about that.   Now, we have something less contaminated here,

10  we're all up in arms.  It's something that's been going on

11  for a while over there.

12          FROM THE FLOOR:   We're worrying about it.  We're

13  making sure we don't have to worry about it.

14          FROM THE FLOOR:   This is more contaminating than

15  this stuff here we're taking out of the arsenal, the stuff,

16  that asphalt.

17          FROM THE FLOOR:   I don't want these things running

18  up my street.

19          MS.  FALKOFF:   Will there be  further — In what

20  form will there be further information available to the

21  community about the impact on the neighborhoods?

22          MR.  WASKIEWICZ:   Well,  we continue to interact

23  with you with whoever wants to talk.

24          MS.  FALKOFF:   I  guess my guestion is —

25          MR.  WASKIEWICZ:   How are we  going to select the

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 1  route?

 2          MS.  FALKOFF:   Will there be a document on the

 3  actual method of implementation of this?

 4          MS.  WASKIEWICZ:   Before we get to that point,

 5  shall we talk about whether we're going to shift plans?  Our

 6  plan right now,  as of today, is still the preferred remedy.

 7  Let me just mention a couple of criteria that we looked at

 8  here, to compare the two.

 9          MS.  FALKOFF:   I  don't mind waiting,  but it feels

10  like this is information I want to have to think about in

11  order to decide.

12          MR.  WASKIEWICZ:   The time on that would be

13  developed, some of the routes would be dependent upon where

14  the final destination was for the taken away material and

15  the stores for the backfill.  That won't be selected until

16  we actually have awarded a remediation contract.  So,  it

17  would be our remediation contractor that would locate his

18  disposal facility and his source of fill.

19          MR.  DENNING:   Could the town put reguirements on

20  what streets not to use  and which streets they could use?

21          MR.  WASKIEWICZ:   Okay.   In terms of — We would

22  not direct the contractor which landfill to go to.  We could

23  direct him which routes  to use.  And, if it was a more

24  expensive route than he  originally considered, then the

25  payment, the differential in payment --

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 1          MS.  FALKOFF:   There's the idea that there would be

 2  roads adequate for these trucks.

 3          MR.  WASKIEWICZ:   That's true.   That's right.

 4          MR.  DENNING:   And,  I wouldn't  want to have a lot

 5  of equipment qoinq through.

 6          MR.  WASKIEWICZ:   That information would be

 7  developed by the contractor in the work plans.

 8          FROM THE FLOOR:   Before you put the bid spec on

 9  the street,  can't you -- you could specify a route in the

10  bid spec.

11          MR WASKIEWICZ:  We  actually anticipate,  if we go

12  to the off-site disposal, we would not have a bid spec.

13  That we will go to a work plan, or a work plan type of a

14  contract procurement here.   In other words, we'd give a

15  scope -- We  would give a scope of work and we could do that.

16          FROM THE FLOOR:   In other words,  rather to create

17  the opportunity.

18          MR.  WASKIEWICZ:   We could direct the route,  but,

19  again, we may have to direct many because if he were going

20  north, south, there would be three different routes,

21  perhaps.

22          MS.  FALKOFF:   Something I never thought to ask

23  about is chemical oxidation, those machines that treat the

24  soil, are they noisy, and how would you assess the relative

25  noise of these two methods?

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 1          MR.  WASKIEWICZ:   Chemical oxidation,  I don't think

 2  any of us have seen the plant work.   It's a mobile plant and

 3  it come to the site.   What it is, it's a -- the soil goes

 4  into a hopper, a conveyor, into a large mixing where the

 5  water and the chemicals are mixed together and there's,  yes,

 6  there's a motor running with that.

 7          MS.  FALKOFF:   It could potentially be more

 8  destructive.

 9          MR.  WASKIEWICZ:   There would be some noise with

10  it.  It would be isolated somewhere within the MTL confines,

11  not out in the community.

12          FROM THE FLOOR:   Would it be louder than a

13  jackhammer?

14          MR WASKIWICZ:   No.  I think this thing runs on a

15  diesel engine.

16          FROM THE FLOOR:   When there's a jackhammer going,

17  it's annoying, but we still have to put up with it.

18          FROM THE FLOOR:   I'd like to extend to feel

19  comfortable  that the soils that will be replacing, if we do

20  the disposal, would have to come from pits.  They come from

21  pits, like pits in Charlton, or the side of a hill in New

22  Hampshire.

23          FROM THE FLOOR:   Is it top soil or deep soil?

24          MR WASKIEWICZ:   It's deep soil.

25          FROM THE FLOOR:   I'd like to have some level of

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 1  comfort that sometimes those soils are actually worse than

 2  the ones that do come out.

 3          MR WASKIEWICZ:  We do specify that the soil

 4  coming in be clean and we could test that also.

 5          MR. RAGO:   We've gotten soil from pits many times

 6  and we've also had samples sent in ahead of time and we

 7  tested them.  As long as that level is maintained,  we can

 8  take it from there.  As soon as the level drops, we shut

 9  them off.  You can control it.

10          MR. LIAZOS:  Why don't we just mention those as

11  concerns.

12          FROM THE FLOOR:   So,  this seems to set the

13  schedule up a year and costs a little bit more.

14          MR. WASKIEWICZ:   The numbers work out to be a

15  little bit more, but I would say they're within the range of

16  the contingency we're using,  so I would call them

17  basically 	

18          MR. STEDMAN:   Plus,  you also save,  if the schedule

19  is done a year earlier,  you can save money.

20          MR. RAGO:   That's true,  providing that the

21  property can actually be turned over for reuse.

22          MR. STEDMAN:   Right.

23          MR. PAONE:   I mean,  if there's a reuse available

24  at that time, so we could get out of the caretaker business,

25  that's absolutely true.   Otherwise the caretaker costs

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 1  really don't change.

 2          MS.  FALKOFF:   We know that Chuck makes a lot.

 3          MR.  PAONE:   Right there,  what a master saving.

 4          MR.  WASKIEWICZ:   In this   slide here,  some of the

 5  main comparison criteria between the preferred chemical

 6  oxidation and the alternative off-site disposal.  One of the

 7  key things we're always concerned with is the protectiveness

 8  of human health and the environment.  Yes and yes.  They

 9  both do that.  And, they did before and they would and this

10  doesn't affect that.

11     The same thing with complying  with the rags.   Both do

12  that.

13     Here we come into a change now.  In the capital cost,

14  we now have about five million dollars for each alternative

15  Previously,  we had about ten million dollars for off-site

16  disposal, because of that $245 a unit cost of ton that I

17  mentioned.  So, now that we're down into $65 a ton, the cost

18  becomes egual here, basically.

19     The other thing that's changed and it changed because

20  we never really looked at it before, the off-site disposal

21  is obviously a whole lot easier to implement and we could do

22  that without a lot of design and I'll get into that in terms

23  of some of the schedule reguirements on the next two pages.

24  But, basically we're cutting a year off of the schedule.

25  And, as was mentioned in that letter that you received from

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 1  John and Susan,  a year could be important.

 2     One of the things that we look at as kind of a negative

 3  by going to off-site disposal is that it's  not a treatment.

 4  And, one of the things that the government  is trying to do

 5  here is to treat soil and put it back.   And, not only that,

 6  chemical oxidation is called innovative, which is really a

 7  big test.  So we're losing that if we go to off-site

 8  disposal.

 9     Basically,  our trade-off becomes the treatment thing

10  versus a year.

11          MS.  FALKOFF:  Why do you say that it's a plus?

12          MR.  WASKISWICZ:   Well,  it's a plus  because the

13  traditional thing has been to take waste away and simulate

14  it sometimes.  And, this does things fairly innocuously.  In

15  other words, we add some chemicals in water and it

16  neutralizes the risk on this.  And, because it is

17  innovative,  that's why we need to do treatability studies

18  and we're not sure that — You know, there's not a whole lot

19  of track record to say that these tests work.

20          MS.  FALKOFF:  I  mean, what you said puzzle me

21  because I would think that innovative would be considered a

22  negative in that it means that it's not tried and true.

23          MS.  CASSIDY:  Susan,  the Super Fund Statute has

24  what's called a preference for treatment, an incentive for

25  looking for innovative technology to prevent the constant

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 1  moving of,  you know,  material from one site to another.

 2  But,  again,  that is more for the hazardous kind of situation

 3  where you have,  you know, a lot of hazardous material that

 4  that method is meant to prevent just moving it from one

 5  place to another.  But, there is statutory language that

 6  says preference for technologies.

 7          MR.  WASKIEWICZ:  They'll probably have — I don't

 8  know about the landfill there,  or the asphalt batching

 9  plant.  But, they're probably having some material already

10  because this is not the first time this has happened.  This

11  is fairly common now,  to use it in asphalt batching and

12  covering.

13          MR.  PORTZ:   So, what you're doing is through the

14  off-site disposal,  you're not really taking this land, this

15  earth some place else and kind of, you know, be a problem

16  there.  You're actually reusing it in a sense that it's

17  being reused for a landfill.  I mean, the landfill would

18  have to find soil some place for that capping process.  And,

19  this is being used for that.

20          MR.  SIMENAS:   I'm Albe  Simenas from the Mass.  DEP.

21  I'm the project manager for the state here.  Those areas,

22  whatever landfill  that it's going to, they will have to, in

23  negotiations with either the contract or the court, it will

24  be permitted.  And, that landfill will say we can receive X

25  amount of that soil to be used as daily cover because in

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 1  part of their operation and the oversight for the operation

 2  of the landfill is you don't want to have piles of soil

 3  sitting there that can't be used for daily cover.  And, it's

 4  the same situation with an asphalt batching plant.  If the

 5  soil is removed in the wintertime, the asphalt batching

 6  plants aren't in operation, so they can't accept it.   If

 7  it's done in the late summer,  early fall, when they're

 8  trying to do a lot of highway work to complete things, they

 9  will be accepting more soil for doing these things.  So, it

10  is part of a standard practice of them receiving it,  but it

11 is overseen and they do have permits for doing that.

12          MS.  FALKOFF:   Well, it just seems that you didn't

13  want to use perfectly good soil.

14          MR.  SIMENAS:   Correct.

15          MR.  WASKIWICZ:  That's why it's listed as one of

16  the nine criteria, nine evaluation criteria.

17          FROM THE FLOOR:   You have said that there is

18  approximately 24,000 cubic yards of soil to be removed?

19          MR.  WASKIEWICZ:   Yes.

20          FROM THE FLOOR:   How much of that is coming from

21  Area M, do you know?

22          MR.  WASKIEWICZ:   Nine hundred.

23          FROM THE FLOOR:   Nine hundred?

24          MR.  WAKIEWICZ:  Nine hundred or five hundred.

25          MR.  RAGO:   Is that small to use the chemical

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 1  oxidation?  Is there a possibility that chemical oxidation

 2  can be used,  that would be considered to be hazardous?

 3          MR. WASKIEWICZ:   I think that would be too small

 4  to bring in the chemical oxidation.  That's another thing

 5  that somebody would have to prove to us.  The company that

 6  doesn't actually do this.  They call it complexing - That

 7  would come out in the treatability studies, if they were to

 8  do that.  A sample of the soil would go to a laboratory, the

 9  chemicals would be added and then hopefully you'd get the

10  right mix of  chemicals to the amount of soil.  And,

11 hopefully, the goal is to make it work.  If it doesn't, then

12  that means the treatability has failed.  Whether or not it

13  handled the lead would come out at that time.

14          MR. YORK:   Do you know that  the oxidation

15  procedure would work?

16          MR. WASKIEWICZ:   It has been used and it's been on

17  a lot of projects in the country and it has worked.   So,

18  that's why it's called innovative.  It doesn't have a whole

19  long track record, but it does have  --

20          MR. YORK:   Does  it have any  history of failure?

21          MR. WASKIEWICZ:   I don't know.  The companies

22  probably wouldn't say that.  But, we don't hear about the

23  failures.  We hear about the successes.

24          MS. CASSIDY:   That's why we  would have

25  treatability  work though, to ensure  that it would work, that

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 1  we're not making a,  you know,  a five million dollar

 2  investment to bring,  you know,  the machinery here and then,

 3  you know, run the entire process through and then find out

 4  it failed.  That's why we would be doing tenability work

 5  up front.

 6          MR.  YORK:   So,  at this  point,  you folks have not

 7  determined that the oxidation procedure is foolproof.

 8          MS.  CASSIDY:   Chemical  oxidation is a technology

 9  that works,  but you have to look at it on a site specific,

10  you know, you have to look at the soils here.  It would have

11  to go through treatability work and there is a possibility

12  that we may find it cannot achieve the clean up level we

13  have here.

14          FROM THE FLOOR:   Whereas,  if you remove the soil,

15  the only test you have to get to is the soil that you're

16  bringing in to assure that that is of sufficient guality.

17          MS.  CASSIDY:   That's correct.

18          FROM THE FLOOR:   So, a  safer course might be to

19  get rid of it as opposed to try to treat it and hope it

20  works.  See if it works.  Try to guaranty it works on this

21  one site.

22          MS.  CASSIDY:   Yes.

23          MR.  RAGO:   That is why  we have a contingency plan

24  in the proposed plans.   And, the way it is now, if we have

25  some new information to shed more light on that, than that

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 1  would be great.

 2          FROM THE FLOOR:   So,  if it was,  and I'll  use the

 3  words of a layman,  more hazardous, it was more expensive to

 4  remove because it had to go to Super Fund sites.  And, now

 5  since it is not at that level, it's less expensive and,

 6  therefore, possibly the preferable procedure is also cost

 7  effective, egually cost effective.

 8          MR.  RAGO:   The gentleman in the  back's proposal

 9  that they bring in the oxidation for Area M, I just noticed

10  here, a hundred and ninety-five days to  move 900 yards in

11  one day.  Would the Army doing both, additional

12  testing, and doing that?

13          MR.  WASKIWICZ:  I believe we have considered that

14  and didn't have enough information to know whether it might

15  work or it didn't work.

16          MR.  RAGO:   Like  it doesn't seem  worth it to do it

17  for a 70 by 70 area.

18          MR.  WASKIEWICZ:   I don't know where the cutoff

19  point would be,  Rich.  The unit is mobile.  It comes up on

20  trucks.  I'm sure there's a set up time  of a certain amount.

21     In addition to bent scale  tests done  in a laboratory,

22  we would look to some sort of pilot scale.  Right now, the

23  only pilot scale that we can figure out  is to bring this

24  unit up for a short period of time and just work on it.   If

25  we had to do this too many times, it would be a little bit

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 1  extra.

 2     But,  actually,  the -- Somebody else mentioned weather

 3  related restrictions of off-site disposal.  There's probably

 4  some other related restrictions on chemical oxidation.

 5          MR.  WASKIEWICZ:   Well,  it really wouldn't work in

 6  the dead of winter very well.  So, the time frames that I

 7  have here, are actually very good.

 8          MR.  DENNING:   When you talked about the chemical

 9  oxidation process and what that would mean, how far you

10  would have to dig down to treat the soil?

11          MR WASKIEWICZ:  Yes.

12          MR.  DENNING:   Will you,  if you are to remove the

13  soil, dig down as deep as it is contaminated?

14          MR.  WASKIEWICZ:   Yes.

15          MR.  DENNING:   So,  it really would be the same,

16  only you're taking it away rather than treating it?

17          MR.  WASKIEWICZ:   Right.   Again,  the depth would be

18  — We would stop at what would typically be a foundation

19  excavation.   I don't know if that's ten feet, or somewhere

20  around there.  Then,  we'd probably stop there.  But, the

21  actual moorings that have been done to date, most of the

22  contamination was found at two feet.  The PAH's have come

23  from surface contamination and the pesticides have come from

24  the same thing, so it really hasn't traveled deeply.

25          MR.  DENNING:   On the face of what you're

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 1  proposing,  I think the residents probably would feel more

 2  comfortable with it being taken away and treated and not

 3  still knowing for sure,  for certain,  whether it was safe.

 4  You know,  barring the truck trips,  probably would be less

 5  hazardous  to the community because hauling it away rather

 6  than treating it.  I guess my only concern is that it's a

 7  major change -- it's such a major change at a late date and

 8  I just wouldn't feel very comfortable that it wasn't being

 9  done in exchange to saving a year or saving money.  That's

10  really my  biggest concern in making such a --

11          MR.  WASKIEWICZ:   Right now,  the — Well,  based on

12  the information we have,  the money is not a factor here to

13  the Army because they both look the same.

14          MR.  DENNING:   But,  if you cut a year off.

15          MR.  WASKIEWICZ:   Yes,  but I  don't think that's

16  being considered here because like Bob said, the property

17  has to be  sold in order to realize that savings.

18          MR.  DENNING:   We  have tenants who are trying to

19  move in and I just want to make sure that we're not rushing

20  things or  changing things just to accommodate,  you know,

21  what's in  front of us.

22          MR.  WASKIEWICZ:   I guess that's a community thing

23  as to how  important that  is.

24          MR.  YORK:  But, the guestion is,  Dennis,  the cost

25  of removal as compared to the cost of on-site treatment, are

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 1  they the same?  Is there a disparity in those?

 2

 3          MR.  SIMENAS:   The off-site disposal is about

 4  $300,00 more expense.  But,  it's so close in relative clean-

 5  up costs.

 6          MR.  WASKIEWICZ:   There's contingencies in each of

 7  these cost estimates that are probably 20 percent of the

 8  total.

 9          MS FALKOFF:   Dennis,  first of all,  I'd like to

10  focus that chart a little bit that Bob just put up.  I

11  notice on that chart and on the next page,  also, that talks

12  about the off-site disposal.   It's got from tomorrow until

13  August 23rd as the decision phase.  What I'm wondering is,

14  if there's a consensus among the community tonight that this

15  sounds fine, what also has to happen in order to make a

16  decision?

17          MR.  WASKIEWICZ:   Well,  I guess that was an issue

18  that I thought about and that I talked about with out clean-

19  up team as to what would be a legitimate time to expect the

20  decision.

21          MS.  FALKOFF:   Who makes the decision?

22          MR.  WASKIEWICZ:   Just to tell you what the

23  decision time means.   Right now, we're on hold and we're not

24  doing anything.  So,  we're not for chemical oxidation.  And,

25  we're looking at off-site disposal.  We're waiting for a

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 1  decision here.

 2     You know,  there's a  couple of things right here,

 3  mainly,  pre-design work plans and treatability study work

 4  plans.  Both of those are in progress in draft reports sent

 5  out for review and we're basically on hold with those until

 6  we get a decision.

 7     How long is it going to take.   Right now --

 8          MS.  FALKOFF:  It's August and I could understand

 9  if you told me the whole BCP's going on vacation for the

10  next two weeks and that's why it's going to take --

11          MS.  CASSIDY:  I think that was like we couldn't go

12  beyond that point without really losing time.  I mean, I

13  don't think there's anything to say that, you know, if we

14  get a feel in a day or so that that two weeks was sort of, I

15  think, from the onset, the worst that Dennis could do for

16  contracting reasons.

17          MS.  FALKOFF:  Okay.

18          MS.  CASSIDY:  They have rod schedules that are

19  deliverable to the EPA that a re reguirements.

20          MS.  FALKOFF:  What I want is,  are there other

21  factors that you're still waiting, that will come into play

22  in the next two weeks?

23          MR.  CHASE:  No, the proposal right now is to

24  continue with chemical oxidation.  In answer to Paul's

25  guestion, does this Army last minute change?  No.  The Army

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 1  is planning to go forward with chemical oxidation.   We got

 2  this information on TCLP.  We felt we should bring it to the

 3  community for their decision, discussion,  whatever.   If the

 4  community feels that they would like to save some time and

 5  the Army can reasonably meet all the other goals of safety

 6  health protection of the environment, this is a point that a

 7  community could advise the Army that they would prefer to

 8  change our remediation concepts.

 9          MS.  FALKOFF:   So, our input tonight is critical.

10          MR.  CHASE:   Yes.

11          MS.  FALKOFF:   We have EPA approval.  We have state

12  approval.  We have Pentagon approval.  You're just waiting

13  for the community approval.

14          FROM THE FLOOR:   I'd like to comment that I  think

15  it would be presumptuous to immediately say that trucking

16  would be the preferred option.  There's a lot of talk in the

17  discussion on reuse that one reason not to go to residential

18  standards was because there would be all this -- you'd have

19  to remove that much more soil and be trucking it around town

20  and that was a very divisive and undesirable thing.   For my

21  own personal viewpoint,  I don't like the trucking

22  possibility.

23     I would also like to say that there is  something very

24  valuable with chemical oxidation in a sense for two reasons.

25  One, is that we all know that toxic waste, when you take it

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 1  some place else,  it's not going away.   Chemical oxidation is

 2  possibly a way to remediate the soil in a more permanent

 3  fashion.

 4     Secondly,  there is a real -- there  is a moral

 5  imperative to support the testing of these procedures

 6  because there will be place where it is not cheaper to truck

 7  the soil off site and in those places  the chemical oxidation

 8  will be — that technology could be really key in reducing

 9  an environmental hazard.

10     So,  I applaud the federal tendency  to look to

11  innovative procedures.  And, I would also like to say, as a

12  citizen, I'm not at all sure that I would prefer the

13  trucking, even if the chemical oxidation takes a little

14  longer.  And, also, I think that, you  know, it sounds to me

15  like further tests are going to be done on the soil and it

16  sounds to me like there's not a hundred percent certainty

17  which way it's going to go, even with  disposal.

18     I mean,  I  don't know if you've done that in a fine

19  enough manner to determine that all of this really is going

20  to be hazardous to a lesser degree and cheaper to dispose.

21  Maybe,  it like either option, either the trucking or

22  chemical oxidation, there's going to be some surprises in

23  the budget department and the procedure department, isn't

24  that the case?

25          MR.  WASKIEWICZ:  Right.  There's unknowns here in

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 1  terms of the volume of soil,  that's an estimate right now.

 2  But,  I guess, again,  it probably wouldn't -- the full cost

 3  would probably estimate similarly to an increased volume.

 4            MR.  LIAZOS:   I  have a guestion.   I haven't talked

 5  about today.  I don't understand why you can't start

 6  oxidation now.  Why does it take so much longer to do the

 7  oxidation?

 8            FROM THE  FLOOR:   We actually have started on our

 9  project.  Just in terms of defining where we're going with

10  the Corps of Engineer activities.  As soon as we had a

11  proposed plan, the chemical oxidation, we started our pre-

12  design activities,  which was  developing pre-designed work

13  plans, sampling and analysis  plans, treatability work plans.

14  So, all of that has been ongoing right now ever since we --

15            MR.  LIAZOS:   You still haven't answered my

16  guestion.  Why is it almost two years away?

17            MR.  SIMENAS:   February '98  is the date,  according

18  to that previous slide.  Is that correct?

              MR.  WASKIEWICZ:   The reason why,  is it before you

20  can mobilize the actual eguipment on site,  all of those

21  columns have to happen first.

22            MS.  CASSIDY:  We don't design off-site disposal.

23  We have to design chemical oxidation.  It's an engineering

24  project.

25            MR.  LIAZOS:   Do you want  to hurry it up?

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 1            MR.  SIMENAS:   They're  already doing the  pre-design

 2  work before they have a record of decision.   So,  the Army is

 3  already going somewhat at risk doing all of this  pre-design

 4  work that it's talked about earlier that is on hold right

 5  now.  They started that stuff early to try to cut the time

 6  frame down as much as possible.

 7            MR.  WASKIEWICZ:   We have  worked out a schedule,  in

 8  fact, with Megan to short cut the normal Super Fund losses

 9  by guite a bit in terms of design and to review documents

10  especially.  I wouldn't want at this time to say we can

11  accelerate the process.

12            MR.  PORTZ:   Does the DEP  and the EPA have

13  recommendations on the alternative?

14            MR.  SIMENAS:   One of the  things that we're looking

15  back at the slide is that both are methods that we've looked

16  at.   We have a contingency in there in the event  the

17  situation changes,  particularly is chemical oxidation does

18  not work, we wanted to have the off-site disposal as an

19  option to remove it.  The things that you did mention are

20  one of those balancing things.  And, what balances it is

21  that there is a thriving need to have the property guicker.

22  It's something that balances off, whether we bring

23  innovative technology to balance off that.  I mean, one of

24  the things we are talking about and I'm concerned with is,

25  the soil is recycled and reused, so that the batching plant

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 1  does,  although it doesn't destroy it,  it binds it into

 2  asphalt and they have to do it anyway for the roads.  So,

 3  this soil something that would be appropriate use for a

 4  batch plant.

 5     So,  they're not making recommendations for either or,

 6  but it's that sheet that Dennis had up earlier shows that

 7  it's in a balance right now.  And,  whichever way the Army

 8  wishes to go in terms of community input, I can see

 9  supporting and working with them on either of those methods.

10            MS.  CASSIDY:   From the  EPA's perspective.   As you

11  see the first two criteria there, those are -- I can't

12  support any remedy that doesn't meet those two criteria.

13  And, obviously, now,  I have two,  which I have two

14  alternatives that meet those criteria, which, of course,  is

15  why they were in the proposed plan.  Off-site disposal would

16  not have been accepted to put forth as a contingency if it

17  wasn't an acceptable alternative.

18     Then,  we get into why you spend six or seven other

19  factors as defined by the Super Fund law that are what we

20  call balancing criteria and that's exactly where we are at

21  this point.  We have two alternatives, both of which are

22  acceptable and, you know, both have either pros and cons, if

23  you will, or,  you know, get a plus or a check.  So,  really,

24  at this point, EPA, which is a procedure the Army has to

25  submit to us what their proposal is, we would be in a

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 1  position to concur with either of these,  these alternatives.

 2            MR.  YORK:   Are  you saying that  both are  safe  and

 3  they're both effective?

 4            MS.  CASSIDY:  Again,  the  first  criteria  there —

 5  we cannot accept anything that doesn't meet that first

 6  criteria.  And,  they both meet the overall protection.

 7            MR.  SIMENAS:   ...  and the DEP reviewed the

 8  materials that the government has reviewed --

 9            MS.  CASSIDY:  Yes.   We have  reviewed all the  data.

10            MR.  SIMENAS:  The  phase we're in right now  is,

11  there is a proposed plan that has gone through the legal

12  process.  The proposed plan had both of these pieces  in it.

13  Where we are right now is a thing that's  called a  record of

14  decision.  And,  what that does is,  it actually puts in a

15  document exactly what will be done.  And, we're in a

16  position right now where we can look at either one.

17     And,  right now,  the Army has said to me that they're

18  going with their chemical oxidation; that was their selected

19  remedy in the proposed plan.  But,  there's this new

20  information the Dennis presented today that shows  that the

21  contingency plan wasn't expected expensive as it was

22  originally put in the proposed plan.  That's really the only

23  thing that's changed right now is the cost of going to the

24  contingency plan.

25            MR.  SHERRY:   But,  at the  some point in time,  where  is

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 1  your breaking point?  Where do you cut bait?  Which way are

 2  you going to recommend to go?  Are you going to recommend --

 3            MS.  CASSIDY:   In that record of decision,  that's

 4  the legal document that is reguired under the Super Fund

 5  law, again,  right now,  the Army is obligated to give us that

 6  document, that legal document with their preferred

 7  alternative.  We've seen one draft.  Another one is due.

 8  But, by the end of September, we are supposed to be signing

 9  off on the decision here.  So, this is a critical time.

10     Another point that I do want to make sure everyone

11  understands because I'd hate to be back here in this room a

12  year from now to explain to you that with chemical

13  oxidation, with the treatability work, there is the

14  possibility that it fails and we still go to off-site

15  disposal.  So, I mean,  that's, again, why there has always

16  been a contingency.  So, we could down the treatability

17  track and find that it's not going to be implementable and

18  go to off-site disposal at some point in the future, anyway.

19     FROM THE FLOOR:   When could you find that out?  At

20  what point -- Does that mean that you don't start to look at

21  the feasibility of the chemical oxidation until '98, or are

22  you looking at that now?

23            MS.  CASSIDY:   In the design phase.   Dennis —

24              MR. WASKIEWICZ:  Right here, somewhere in the

25  November time frame.

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 1            FROM THE  FLOOR:   November of?

 2            MR.  WASKIEWICZ:   This  year.  November of this

 3  year.

 4            FROM THE  FLOOR:   This  year.  So,  you'd be

 5  determining the feasibility of chemical  oxidation this fall;

 6  is that correct?

 7            MR.  WASKIEWICZ:   Yes.

 8            FROM THE  FLOOR:   Hopefully?

 9            MR.  WASKIEWICZ:   Yes

10            FROM THE  FLOOR:   So, it's not  like we're going to

11  wait two years and then find out.

12     I also just want to clarify,  the you  able to dig up the

13  soil and remove it in the dead of winter,  either; is that

14  correct?

15            MR.  SHERRY:   It  says February.

16            FROM THE  FLOOR:   The time frame  is actually good

17  if we mobilize in February, we could start putting -- you

18  know,  bringing in the eguipment  and stuff that's needed on

19  site and start digging in March, or whatever.  That makes

20  for the long season.

21            FROM THE  FLOOR:   Okay.   And, are you going to use

22  Ryder trucks?

23            FROM THE  FLOOR:   I'm a member  of the town council.

24  Assuming both plans are safe,  one of the concerns I have as

25  a councilor is to have progress  as guickly as possible, but

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 1  as safe as possible as mentioned earlier.  It's our last

 2  chance to improve on tax base and also provide opportunity

 3  for employment.  If they're both safe and you save a whole

 4  year,  certainly would encourage the members of the board

 5  to go for the off-site, from what we've heard so far.  I

 6  know that the sentiment of the people in town.  We want to

 7  see this developed as guickly as possible,  but of course,

 8  with all the safety factors considered.

 9            MS.  RAGO:   But,  you've got one more consideration

10  here to consider at this stage.  We're going to reach a

11  point where the chemical oxidation process isn't doing.

12  What do you do then?  Do you then start to go to the off-

13  site proposal?  I'm saying, do you have to wait?  I'm not

14  disagreeing with what you're advocating.  I'm saying,

15  suppose is you don't and then when you reach the point that

16  you're going the other route, chemical oxidation, and then

17  you find out you can't do it that way, where can you make

18  the right decision,  or when can you make it?

19            FROM THE FLOOR:   I think the decision has to be

20  made as soon as possible.

21            FROM THE FLOOR:   It's a tough one,  isn't it?

22            MR.  LIAZOS:   That's very clear.

23            MR.  CHASE:   Right now,  we currently have a record

24  of decision draft, which the regulators have reviewed, that

25  says chemical oxidation.  If we get some guidance from the

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 1  community,  that they would prefer us to do off-site

 2  disposal,  we would have to re-write our record of decision

 3  and resubmit that to the regulators for approval.  Right

 4  now,  our document says chemical oxidation and that's the way

 5  we will proceed unless we get some guidance from the

 6  community that you have a desire to get us to use the off-

 7  site disposal, which may save a year in remediating the soil

 8  there.

 9           MR.  LIAZOS:   Whatever guidance you get  tonight,

10  it's guidance.  You decide whether to accept it or not.

11           MR.  CHASE:   If the town's guidance is strong that

12  says that they would prefer us to change our alternative to

13  off-site disposal, we will do that.

14           MR.  LIAZOS:   Thank you.

15           MR.  YORK:   Megan or Albe,  a couple guestions.   If

16  we go to the haul-off/replace, what criteria are there to

17  give assurance that the replacement soil that's coming back

18  is of a sufficient guality, and to make sure that the trucks

19  bringing that in are bringing in the guality that we have

20  been assured?

21           MS.  CASSIDY:   I'm not sure I remember your name.

22           MR.  SHERRY:   I think we  can control that.

23           MR.  YORK:   I  understand  that,  Tom,  but  I  want to

24  hear it from the state.

25           MS.  CASSIDY:   With the work plans that  would

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 1  specify the nature of the testing to be done at the location

 2  that you're getting the soil.  If you went to the

 3  alternative location, they would have to, you know, retest.

 4            MR.  YORK:   And,  as  far as  the government is

 5  concerned, when we look at the contracts, if we happen to go

 6  the haul-away route,  would the types of conditions that

 7  we're talking about as to trucking routes, guality assurance

 8  review, those documents would be able to be looked at by not

 9  only the Reuse Committee,  but Mr. Okun, the EPA and the DEP,

10  prior to any final signatures?

11            MR.  WASKIEWICZ:   We do have,  we have inspectors

12  on-site to verify its condition.  In fact, I mentioned the

13  backfill of the tank farm.  We rejected the fill that was

14  brought on that didn't meet our standards.  So, we do

15  checks.  That's a normal procedure,  also.

16            MS.  CASSIDY:   There's a standard list of documents

17  that they are under agreement because of their Super Fund

18  nature, they have to provide us and we have to review.  All

19  of the line items up there are submitted for review.  And,

20  typically historically, they've always been given, every

21  time we get a document, it's also put out to the public

22  through the round and information and things like that.  I

23  can't envision that would be any different.

24             MR.  CHASE:   The program managers for EPA and DEP

25  and myself meet either every three or four weeks, reviewing
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 1  all these documents.  And,  we will continue to do that

 2  through the remediation process.

 3            MR.  LIAZOS:   Where there was a contractor who's

 4  done that kind of work all the time and they still violated

 5  some kind of guidelines.  So, the guestion I have in mind,

 6  can we have some assurance that in fact there's control

 7  exercised?

 8            MR.  YORK:   Yes.   I just want to make sure that all

 9  of this has been looked at by the EPA and by the DEP, which

10  I'm sure that it has,  and that the contracts that they will

11  look at give us the ability to set forth the specs or the

12  conditions that give the guaranties that the community

13  needs.

14            MS.  CASSIDY:   To  the extent that federal

15  procurement regulations allow it, the courts submit their

16  scopes of work, et cetera,  to me and the Albe for review,

17  that obviously the contractor's costs, you know, there is

18  some of that that is not a public sort of issue.  But, on

19  the technical merits of a contract, we are consulted.

20     The only thing I just want to mention on the truck

21  routes is, the only control that we can't have is, these

22  truck routes do have to go by DOT regulations.  And, some

23  streets, as Susan said, they can't use.  So, I mean, while

24  you can have input, you can't send them down a street that

25  DOT says they can't use, obviously.  So, you know, you have
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 1  to work within some constraints.

 2            MR.  DENNING:   Most  of the  streets  are  major -

 3            MS.  CASSIDY:   Except  Galen Street.

 4            MR.  DENNING:   We  would never send  them down a  side

 5  street, anyway.

 6            MS.  CASSIDY:   Right.   But  --

 7            MR.  PAONE:   If you  don't do that you're in

 8  violation.  And,  the other slide had it where there's

 9  regulations, transportation regulations.

10            MR.  DENNING:   But,  when they were  hauling

11  materials the last time, they were  where they shouldn't  have

12  been.

13            MS.  CASSIDY:   And,  there was no — There was very

14  little town oversight when they were taking  radioactive

15  stuff.  It's kind of like you called the police department

16  and said, oh,  you know,  where are the trucks with the

17  radioactive material going to go?  Huh?  I would like to

18  have a guaranty if we're going to be doing  that trucking

19  that it be -- that the police department is  going to be  kept

20  informed and able to be involved.

21            MR.  BOYLE:   Susan,  in the  context  of the

22  discussion relative to the schedule, I think that the public

23  needs  to know that through the consultants  of the Reuse

24  Committee, they've advised the committee that there's a  very

25  tight  real estate market presently in the Greater Boston
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 1  Area,  that there's a window of opportunity in the next two

 2  years  before new space comes on line that to position the

 3  property quite well for economic revitalization,  at the same

 4  time,  we have several high-quality companies have approached

 5  the town with stronq interest in the site.  Computer

 6  software.  Corporate offices are in need, biotechnology.

 7     There are windows of looking at real estate space needs

 8  that they have right now are in the next year to two, rather

 9  than two to four.  Those people who know of the real estate

10  process, know that they're always looking at needs.  In the

11  space  needs that they're talking about are very consistent

12  with the schedule for off-site.

13     Now,  we're talking about the ability to attract the

14  types  of jobs and the types of economic revenue to the

15  community that had been used in the reused planning process.

16  The companies that I mentioned are consistent also with the

17  types  of jobs that we had talked about.  And, certainly, the

18  tax revenue that would be generated by that, if all other

19  factors, environmental factors are equal.

20     So,  I think that the community might say, well,  wait a

21  minute,  you had the opportunity to create jobs one year

22  earlier.  You had the opportunity to create tax revenue for

23  the community one year earlier.  And,  if there's no other

24  problem or difference with the environmental process, I

25  think  there's a moral obligation to, as was quoted earlier,

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 1  to talk about the types of economic revitalization that's

 2  envisioned for the property.

 3     With regard to the property itself,  as you know,  it's

 4  now vacant.   The longer buildings and properties remain

 5  vacant, the harder it is and the more expensive it is, also,

 6  to rehab and to reuse them.  Not to mention the fact that

 7  with regard to the Army's budget, it's more expensive for

 8  them to, guote, carry.

 9     But, as you know,  if the town moves forward with an

10  economic development conveyance, that's going to be the

11  town's project, certainly, initially, under a master lease,

12  or a lease in furtherance of conveyance, and ultimately, to

13  an actual deed transfer.  So, the community needs to know

14  that if it takes on a multi-million dollar project in an

15  enormous piece of real estate, that it needs to be concerned

16  about the ability to guickly turn that around, to get it off

17  the town's carrying costs and to get it into private hands,

18  as I said earlier, to provide jobs and tax revenue for the

19  community, not to mention the property, the physical

20  property, revitalization of the site as well.

21     Jonathan,  who is on the Reuse Committee and not able to

22  be here, did ask me to express a couple of issues and ask a

23  couple of guestions which Dennis did answer.  She did ask in

24  terms of the volume of the trucks, how long it was going to

25  take.  She was concerned about the entrances and exits.

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 1  But,  she also did express a strong hesitancy and concern

 2  about the chemical oxidation in the it's not sure that it's

 3  going to work.  She wasn't sure that she wanted that type of

 4  technology taking place,  and cooking,  to use her term, 300

 5  yards from her home.

 6            MS.  FALKOFF:  How about  economics?

 7            MR.  BOYLE:   On  the economic  and real  estate

 8  points,  I think that they can't be separated from this

 9  discussion,  but they are  closely related to the discussion

10  in that one of the changes or benefits or differences  of one

11  alternative to the other  is the standing of that one year,

12  and given the information that we have,  that one year  may be

13  very critical to, you know, attracting and landing,  so to

14  speak,  a key cornerstone  company that  the community would be

15  proud to have as its new  tenant, as its  first tenant,  or as

16  its major tenant on the property.

17            MS.  FALKOFF:  You know,  I can  answer  that  often

18  what the consultants say  seem like they're sort of busy in

19  ivory towers,  but I work  for a company that needs to

20  relocate and cannot find  space anywhere.  So, I've had some

21  real life corroboration of the type real estate market.

22            MR.  SHERRY:   I'd like to ask one guestion, too.

23            MR.  LIAZOS:   I  don't like to keep jumping  in.   I

24  appreciate what you've said, but I want  to just put it in

25  perspective.  This project started in  1988 and it's been

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 1  testing and retesting and tested a fair amount and the

 2  original clean up file date was like two years ago,  whatever

 3  it was.  And,  I find it a little bit unnerving, I think,

 4  that with the whole new plan that within the next ten days,

 5  you know.  you need that.  This has been a long process, you

 6  know,  this is kind of all of a sudden,  you know?  There was

 7  a long time.   There's a lot of meetings we went to every

 8  month and all these details and the Army came out with a

 9  decision.  But now the whole thing has changed.  I don't

10  know guite how to react to this.  I just think it sounds to

11  me like Russian or something.  All this time, all these

12  years, why all of a sudden, ten days,  we have to say we want

13  this change.   I'm confused about it.  I want to see a long

14  time ago.

15            MR.  SHERRY:   I'll make a remark,  basically.   I

16  would feel very comfortable as long as the EPA and the DEP

17  and the agencies to whom we're looking for to support us,

18  give us a kind of input we need when these type of decisions

19  are going to be made.  We don't have the expertise or the

20  know-how.  We do have to rely upon the state and the

21  could federal government and those people to supply it.

22     I don't know how you can say this is a mystery or

23  not.  If you have the data and it's brought forward now and

24  it says you can do it, what are we losing?  Why don't we go

25  ahead and do it and then depend upon these other agencies to

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 1  support us.   If they say in the middle,  we can't do it, then

 2  say,  don't do it.  What else are you going to say?

 3            MR.  YORK:   What  I  want to say,  Albe and Megan,  I

 4  appreciate your input from the DEP and the EPA throughout

 5  the process  and particularly this evening.  Do you folks

 6  feel that you've been hurried at all?

 7            MS.  CASSIDY:   I  'm not sure I  understand —

 8            MR.  YORK:   We've now come to a conclusion this

 9  evening that you've done the studies that you've wanted to

10  do and feel  comfortable in the opinions  that you've given.

11            MS.  CASSIDY:   Yes.   From my perspective,  I don't

12  see that this is new.  It was in the feasibility study.  It

13  was in the proposed plan.   Again, the reason we put the

14  contingency out there was the possibility that, you know, we

15  would use the contingency.  Again, that's why we set it up

16  this way.  Both Albe and I worked very closely with the

17  Army, so, you know,  none of this in new.  So, I, personally,

18  don't feel that I've been rushed through reviewing anything.

19  Again, we get all the information in real time.  And,  as Bob

20  said, we meet very regularly.

21            MR.  YORK:   Albe?

22            MR.  SIMENAS:   I'd  say the same thing.   It is  the

23  contingency plan and at what point we pay for the process we

24  invoke it is really not a regulated decision at this point

25  in time.  For me, both of those — the contingency of off-

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 1  site disposal and chemical oxidation,  both will leave the

 2  site safe with the clean-up levels that we were talking

 3  about.

 4            MS.  FALKOFF:   In response  to what Tom said,  the

 5  community does have its own consultants and I wonder if Jim

 6  Okun would like to comment on that what you think about

 7  these two alternatives?

 8            MR.  OKUN:   I  was going to  say,  Susan,  that two  or

 9  three weeks ago,  Susan and I were at a meeting and I was

10  hired by Watertown Citizens for Environmental Safety through

11  a grant that they received from EPA, that supports --

12            MS.  FALKOFF:   And,  we said that we would only —

13  that part of our deal with the EPA was that Jim would be

14  available to the community.

15            MR.  OKUN:   Okay.   So,  I don't have an axe to grind

16  here.  Susan and I attended the last regulators meeting

17  which is where the Army gets together  with EPA and DEP and

18  other interested regulatory bodies.  And, Susan and I were

19  sitting there and heard Dennis say,  Well, we just got this

20  new data from the TCLP tests, and, now, we're taking a

21  second look at what the proper plan's  going to be for

22  cleaning up the site.  And, to be honest, Susan and I sat

23  there kind of dumbfounded because we felt we had just gone

24  through a very lengthy detailed process to develop a plan

25  that was on the table.   Probably, most of us were in this

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 1  room this spring when Carl Blows (phonetic)  was here and

 2  made the official announcement,  this was the approach that

 3  the Army was going to take.  It all seemed that it was

 4  signed,  sealed and delivered.  So,  we were very surprised to

 5  have Dennis tell us that they were now reconsidering what

 6  the plan was going to be.

 7     We told them at that meeting that we weren't objecting

 8  to a possible revision of the plan, but we were very

 9  surprised.  And, we thought it was late in the game for this

10  kind of change, which, to us, seemed like a significant

11  change to be cropping up.  And,  none of that is to discount

12  anything that Mark just said.  But, our reaction was this is

13  a significant change, seemingly coming late in the game.

14     I'll  give you my honest opinion, which I  have voiced at

15  other forums, which is, in general, I think that the manner

16  in which the testing was done could have been better thought

17  out.  I  think it shouldn't have happened this late in the

18  game, that this data was available.  Hindsight is always

19  20/20, as people say.

20     One question I was going to ask Dennis is,  one of the

21  things I heard as people were asking guestions was, do we

22  know whether the chemical oxidation will work.  That's a

23  question that I think has been discussed.  Is there some way

24  to get an answer to that question in some kind of expedient

25  time frame?  I know you show it starting, you know, in

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 1  September and ending in November.   Is there some way that

 2  you can get the community information on that in a more

 3  expedited fashion?

 4            MR.  WASKIEWICZ:   Typically,  we do things,  like  we

 5  have a treatability work plan right now.  We don't normally

 6  go ahead unless we get general concurrence from EPA and the

 7  state on the procedures that we're following.  I'd hate to

 8  just jump in and send out soil samples to somebody and tell

 9  them to run it guickly without having authority of the

10  controllers.

11            MR.  SIMENAS:   What Megan and I hear is  that  were

12  to happen, then I would feel pushed.

13            MS.  CASSIDY:   Right.

14            MR.  SIMENAS:   I  would feel — If we're  going to go

15  with something that I don't know whether it's going to work,

16  I want to make sure that I've had enough time to review what

17  we're looking at, how we're comparing it.  Because,  one

18  thing I've always been concerned about on chemical oxidation

19  is, it's a proprietary agent that's going to be used from

20  the oxidation.  I want it compared to other oxidizing

21  agents.  I want to make sure that it isn't this sort of like

22  voodoo chemical that's also going to change and take care of

23  the metals and all these other things.

24     That time frame has been in there for the plan,  it

25  still has it up there on the sheet, so that that's the time

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 1  frame and that's why we're not going to get there until

 2  February of '98, because all those things need to done.

 3            MS.  CASSIDY:   I  would just reiterate that  time

 4  frames you see here for treatability, in my mind, are as

 5  tight as they possibly can be with your expectation that

 6  we're overseeing things.  I mean,  Dennis and I and Albe have

 7  worked on this schedule to see where we could cut time.

 8  And,  cutting any more time means we'd give up our right to,

 9  you know, look at the documents.  So, there is some trade-

10  off.   Even to say November that we would know whether it's

11  going to work, is very, very optimistic.

12            MR.  WASKIEWICZ:   Let me  explain just a  couple of

13  things to at least put it in place.  While we've been doing

14  this  work plan,  our contractor has actually been out

15  selecting an independent laboratory to do the actual bench

16  scale tests.  Yeah, we could send -- Albe mentioned the

17  companies of the proprietary chemicals.  We could send them

18  a soil sample and say,  turn it around guickly and probably

19  in a  month they might be able to give us something like

20  that.  But, again, we would have no confidence.

21     Not only that,  we've also located additional companies

22  that  probably have chemicals that do the same thing.  The

23  federal government in their procurement has to be very

24  careful about sole sourcing.  If there's more than one

25  process out there, we have to look at those.  And, that's

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 1  why we've gone through and we selected an independent lab,

 2  so that they can get the various chemicals from the

 3  companies that want to compete and they will do the tests.

 4  So, that's —

 5            MR.  OKUN:   Assuming you get that done by the end

 6  of November which is what your schedule calls for, would it

 7  make more sense — You would lose August, September,  October

 8  and November.  You'd lose four months.

 9            MR.  WASKIEWICZ:   I  see two check points  here.   The

10  actual bench scale laboratory evaluation of the process.  We

11  always like to add in a pilot scale study.  But, we don't

12  see an easy way to do it here, except to bring this mobile

13  unit to the place and start running the soil.  You know,

14  that's somewhere down in here.

15            MS.  FALKOFF:   Jim,  in asking these guestions,  are

16  you implying that you consider chemical oxidation

17  preferable, if you know it would work?

18            MR.  OKUN:   I  just heard a lot of guestions  and a

19  few concerns in this room.  And, Dennis is concerned that --

20  the biggest concern, that there is a preference for

21  treatment technologies that actually destroy contaminants

22  and at the same time I was hearing people say, we don't know

23  if that would work,  anyway.  We don't know if chemical

24  oxidation would really work.   And, I thought maybe there'd

25  be a way to answer that guestion which would then, if it

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 1  doesn't work --

 2            MR.  YORK:   Jim,  what  do you think of hauling it

 3  off and the EPA and the DEP's conclusion that that is at

 4  least equally safe?  Hauling it off and bringing in new

 5  soil.

 6            MR.  OKUN:   I  would  agree with that.   I  would

 7  concur.

 8            MR.  YORK:   So,  you  think that that's the safe

 9  course.

10            MR.  OKUN:   I  assume the trucking can be arranged.

11            MR.  YORK:   It seems to me,  and I've  come to a

12  conclusion, I am a layman trying to get all the input.  I

13  appreciate everyone being here.  I actually think the

14  removal is safer because we know that that will work,

15  whereas, the oxidation at this  site,  we don't know.  I also

16  feel that that being the case with it equally safe, that the

17  time factor of the wonderful  opportunity of developing this

18  site and being assured of the safety of what is removed and

19  what is brought in,  is an opportunity that some would say is

20  a moral obligation to the town.

21     We have also been taught,  I  hope,  to sit and think

22  globally, which the woman in orange has pointed out.  I

23  don't think she identified herself.  And, that's important

24  too.  But, I'm glad that Megan  and Albe have indicated that

25  whatever batching areas they are taken to or landfills are

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 1  approved and that those will be safe and appropriate uses.

 2     I am pleased and not surprised with what is presented.

 3  I know from the beginning and,  God,  we're going back too

 4  many years,  to the course at the beginning when the

 5  government started talking about oxidation and treatment on-

 6  site, that the pushing at that point was, we'd rather take

 7  out what is bad and make sure that what comes in is clean.

 8  So, I would just say that in my conclusion, I am pleased

 9  with the option of the removal and the benefit it brings to

10  the town.

11            MS.  FALKOFF:   Rich has been very eager to say

12  something.

13            MR.  RAGO:   I  have  two guick guestions.   One of

14  them is, there are PCB contaminated soils, I think.  Now,

15  those aren't TCLP type things and they can't go to a

16  landfill, so are they handled separately?  We haven't really

17  talked about that tonight.  How do you handle those?

18            MR.  WASKIEWICZ:   I'm not sure,  Rich.   Albe?

19            MR.  SIMENAS:   Looking at one of my sheets here

20  that I brought with me, the actual value.  If I remember

21  correctly, the landfill, Title B landfills can accept it if

22  it's above two parts per million.  I don't have my data

23  sheet here.   We're close for that one area.  It could be

24  like the Area "M", or one other area.

25            MS.  CASSIDY:   It's going to be  close.

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 1            MR.  RAGO:   And,  the second question is,  this cost

 2  page,  it says originally 9.7 million, which would go for

 3  hazard.  I have a strong suspicion that it's going to be

 4  less than that based on the cost of disposing the landfills

 5  and that was during the last couple of years.  Is this based

 6  on August 1996 prices?

 7            MR.  WASKIEWICZ:   Based on early '96 prices

 8  probably.  Actually, you know, our offices continually check

 9  with vendors.  The actual landfill cost itself is $35 a ton.

10            MR.  LIAZOS:   We're being told tonight that a

11  decision was made to do chemical oxidation, which is not

12  apparently sure it will work on this site, based entirely on

13  cost.   You just said that it's totally safe for Watertown to

14  take the soil out, the hazardous waste, which is, of course,

15  more money.  But, it's safe for Watertown to move it.

16  And, so far as you can tell, the only reason you can do it

17  is 5.1 versus 9.7 million.

18            MR.  WASKIEWICZ:   Well,  that's not a bad

19  conclusion.

20            MR.  LIAZOS:   I  think that's brilliant.   But,  if

21  that's the case,  why didn't the town commission say, well,

22  we want it here,  you know, we'll save a million and a half

23  over ten million in storage.  I'm just confused 	

24            MS.  FALKOFF:   I  would not have approved it until

25  this new information.  I really lean to off-site disposal

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 1  and the really critical piece for me is that there's a

 2  really moral reuse for the soil.

 3            MR.  STEDMAN:   Beneficial.   Beneficial reuse for

 4  the soil.

 5            MS.  FALKOFF:   Yeah,  beneficial.   I feel  really

 6  good about that.

 7            MS.  CASSIDY:   Just  for the record.  No decision

 8  Has been made until EPA finds the rod,  there is no decision.

 9            MR.  DENNING:   Bob had said,  you  know,  they're

10  going toward chemical oxidation and unless there's a strong,

11  you know, desire shown by the community.  And, I guess I'm

12  wondering what form is that going to take?

13            MS.  FALKOFF:   I  think that there's a clear

14  consensus here among the people tonight.  I think it's been

15  a really good meeting.  People have aired a lot of issues.

16  Maybe John may want the Reuse Committee to take a formal

17  vote and I wanted to get a sense of the values as  it relates

18  to render opinions.  I'm wondering if we can move  toward a

19  process like that.

20            MR.  DENNING:   Well,  as someone who represents a

21  good chunk of the town that abuts the arsenal, I have no

22  clue what they think.  I don't even know what Larry thinks

23  is best.  So,  when you say a strong decision by the

24  community, a recommendation by the community, I take that to

25  mean people who live in the community,  not just us on the

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 1  board and not just a few people here tonight.

 2     So,  I would feel uncomfortable making a recommendation

 3  until I knew more and polled the people who live down there.

 4            MS.  FALKOFF:   There are guite a few people on the

 5  Reuse Committee.  John?

 6            MR.  PORTZ:  Well,  certainly pros and cons

 7  to the different options.  But, I think given that both

 8  options in terms of the disposal, you know, protect the

 9  basic health and safety.  I would certainly opt for the off-

10  site disposal because it seems to me, it has the weight of

11  factors on the positive side.  I mean, I have my little

12  sheet here that I put down the major points and I think

13  you've already mentioned those.

14     Now,  I agree, too, with you, Susan, that the reuse of

15  the soil is an important -- it's not a glamorous reuse

16  perhaps, but it's reuse.  So, we're not talking about taking

17  it somewhere and encapsulating it and just kind of passing

18  on the problem to somebody else.  It's going to be used.

19            MS.  FALKOFF:   I think about the morality of taking

20  good soil for a use like that and feel upset.  I just feel

21  like it's really appropriate.

22            MR.  PORTZ:  To me,  that's certainly a positive

23  issue,  or a positive factor.  And, the, the fact that off-

24  site disposal is a more certain method.  You know, it will

25  work.  The chemical oxidation, there's a guestion about

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 1  probably it will,  but there's an element of uncertainty

 2  there.  Certainly,  to have the site available a year earlier

 3  for development purposes, I think is certainly -- it is an

 4  advantage to the town, to the entire town.

 5     I think the negative that we have to deal with

 6  primarily is the trips, the trucks moving in and out of the

 7  community, and I think that can be handled.  You know,

 8  there's going to be down sides to everything, but I think

 9  that can be appropriately dealt with.

10     I think,  you know,  the Reuse Committee and the RAB have

11  been looking at these kinds of issues for a long time and, I

12  mean, I appreciate Paul's point about wanted to get citizen

13  input, but I think, also, people on the Reuse Committee and

14  the RAB that have been looking at these issues for so long,

15  can speak their minds and move on from there.

16     I don't know how you would go about doing some kind of

17  polling of the community.  I don't know how you'd do it.

18            MR.  DENNING:  We do surveys for other things.

19            MR.  PORTZ:   Pardon?

20            MR.  DENNING:  We do surveys for other things.

21            MR.  PORTZ:   Well,  this is to me — this is a

22  somewhat technical issue.  I don't know how you would poll

23  people about whether they want a chemical oxidation versus

24  off-site disposal.

25            MR.  DENNING:  There's a couple of citizens.

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 1            FROM THE  FLOOR:   It was  in the  papers.   It was

 2  announced in all the town papers.   Who showed up?

 3            FROM THE  FLOOR:   Basically,  we  are here.   Why

 4  don't you take a poll of us that are so interested and came

 5  out tonight to listen to this.

 6            MR.  PORTZ:   What is your feeling,  ma'am?

 7            FROM THE  FLOOR:   Apparently,  the  off-site because

 8  it would speed things up and we're not taking a chance that

 9  the chemical oxidation may not work.  So, I vote for the

10  off-site.

11            MS.   FALKOFF:   Could you identify yourself,  please?

12            MS.  LOFTUS:   I'm sorry.   Mai Loftus.   A resident

13  of Watertown.

14            MS.  FALKOFF:   Anyone else?

15            FROM THE  FLOOR:   Yeah.   I'm still so confused

16  because a lot of what we heard when we were talking about

17  cleaning up the site to residential use.   One of the main

18  arguments for not doing that was that it was going to

19  involve digging up so much soil and trucking it away in

20  which case the cure would be worse that the problem.  This

21  is something that was battered about at least at the level

22  of the neighborhood.   This was going to be, you know, so

23  awful.  That I heard coming out of the mouths of people as

24  an argument against perfection precisionists.

25     So, this is part of the source  of my concern,  this

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 1  previous discussion about the conditions.  Now,  maybe the

 2  trucking is safer,  the stuff isn't leachable.  But,  one of

 3  my main concerns is accountability on that trucking process

 4  and I can't say that past records, look at what happened to

 5  the GSC site.   I've know we've come a long way since the

 6  days that uranium was found and they were bouncing out of

 7  barrels, but,  still, that happened.  And, I would like to

 8  see, you know -- I think that I would like to see a very

 9  clear community friendly effort to just make sure that

10  that's really -- that those contractors are kept to the

11  letter of the law and that they don't come up Irving Street

12  and go to Dunkin Donuts over there, which certainly happens

13  and I nave every sympathy with their desire for Dunkin

14  Donuts.  I am concerned abut that.

15     I do also have sympathy with the desire to get this

16  thing on the road and get it done.  I completely understand

17  that.

18            MR.  BOYLE:   We can pay closer attention in the

19  past, than we have in the past and we have been delinguent

20  in that.

21            FROM THE  FLOOR:   There were the Ryder  trucks.

22  There have been problems in the past that, you know, I'm not

23  sure that -- I think at the point where the chain of command

24  does get a little loose there, once you get a whole lot of

25  back offers and trucker and stuff, it just gets a little

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 1  more chaotic by the nature of the game.  Right?  So, it

 2  would be nice,  you know, if we're going to do that, then I

 3  really want to see care.

 4            MR.  BOYLE:   I  think that's a good plan and that if

 5  it is going to the other one that there is some type of

 6  public information or oversight process on that, including

 7  abutters, the Reuse Committee, the RAB and, obviously, the

 8  police department as well, and, Steve Lord, of the town's

 9  health directors here, as well.  So, I think that is -- if

10  that ultimately is what the decision is,  that there be a

11  process or committee or something set up because that is a

12  very strong concern,  as I said earlier, I certainly express

13  that as well.   So, I think we ought to look closely at a

14  group that can do the public information and the oversight

15  work, working closely with the police and health department.

16            MS.  FALKOFF:   Rich,  did you?

17            MR.  RAGO:   Yeah.   Based on the  data set that I've

18  seen for the whole site to date,  it all seems like a waste

19  of money to go through all this for such a low level of

20  contamination.   It's not as bad as the gas station over

21  there and the machine shop over there or the dry cleaner

22  next door.  I would think that I  emphatically would vote for

23  off-site disposal, given this time schedule.

24            MS.  FALKOFF:   All right.   Let's see if we're ready

25  to move this toward a vote.

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 1            MR.  LIAZOS:   Not all the Reuse Committee members

 2  are here tonight.

 3            MS.  FALKOFF:   Right.  I  think we'll have to

 4  specify that this is simply a -- Although, I'm not sure —

 5  We have a number of Reuse Committee members.  We may have a

 6  quorum.

 7            MR.  LIAZOS:   Four RAB members.  That's it.

 8            MS.  FALKOFF:  We may have a quorum on the Reuse

 9  Committee.

10            MR.  YORK:  And,  I think  also have — has John

11  Arasian indicated a preference, as Cathy said?

12            MR.  BOYLE:  Well,  John has indicated in a letter

13  that he wrote, which --

14            MS.  FALKOFF:   And,  Rudy  Delano has, on the RAB,

15  indicated his preference for off-site disposal, in a

16  conversation I had with him.  Tom Stevens is here.  I don't

17  know you counted Tom.

18            MR.  STEVENS:   Quite frankly,  I'd rather opt for

19  the chemical oxidation.  It's a possibility it might not

20  work,  well,  that leaves out one option, you know, that it

21  might actually work.  You don't know what you're going to

22  discover as you uncover this earth for off-site disposal.

23  You might find that the testing was insufficient to reveal

24  some additional contamination, which was more severe, that

25  could have been handled by the chemical oxidation.  You

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 1  might wind up trying to reach a Canadian trucker that go

 2  over the Tobin Bridge with all this stuff and wind up

 3  dumping it into the harbor,  and,  you know,  poor Deer Island,

 4  and the MWRA schedule is two years behind.   So, you don't

 5  know where that's going to go.

 6     There's a number of assumptions that are made.   You're

 7  assuming that these wonderful companies are already to pack

 8  up and move to Watertown,  A, aren't looking at other sites;

 9  and, B, are ready to actually commit themselves here, which

10  isn't often the case.  We have a lot of false leads.  There

11  might be another company lurking in the shadows that has a

12  time frame of three to four years, that says, well, we can

13  come in and solve all of life's problems in Watertown

14  because that site is available, you know, in a couple of

15  years.  And, maybe they'd like progressive things like

16  chemical oxidation.

17     I would have to opt for the more environmentally thing,

18  rather than truck something off to a site that is slated to

19  become a Super Fund site and my tax dollars are going to pay

20  to clean up the stuff that came from Watertown, you know, 20

21  years from now, down in New Jersey, or wherever.

22            MS,  FALKOFF:   Okay,  Tom.   Thank you.

23            MR.  STEVENS:   I  was  sitting here  guietly and you

24  asked.

25            MS.  FALKOFF:   I  propose that we start with the

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 1  Reuse Committee and someone make a motion.

 2            MR.  STEDMAN:   I  make a motion that we vote on the

 3  preference of how this is going to be handled.

 4            MS.  FALKOFF:   Do you want to —

 5            MR.  STEDMAN:   I  would recommend that we go for the

 6  off-site disposal.

 7            MS.  FALKOFF:   Okay.   Someone want to second that?

 8            MR.  CHASE:   Second.

 9            MS.  FALKOFF:   Okay.   All those in favor of off-

10  site disposal from the Reuse Committee, raise your left

11  hand.  All opposed?  Okay.  Of the people present, the vote

12  is five to one.

13            MR.  LIAZOS:   Excuse  me.   There are six people

14  present.  How many members of the Reuse Committee?

15            MS.  FALKOFF:   Altogether?

16            MR.  BOYLE:   Six.

17            FROM THE FLOOR:   Five to one,  that's pretty good.

18            MR.  BOYLE:   Is it Sue Persarian (phonetic)  here,

19  representing Warren.   Warren's delegate is here.

20            MS.  FALKOFF:   Does Warren have a vote?

21            FROM THE FLOOR:   I'm not comfortable voting for

22  Warren.

23            MS.  FALKOFF:   Okay.   We'll take that as an

24  abstention.

25            MR.  LIAZOS:   I just  don't see why we can't wait

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 1  another week.   This is such a big decision.

 2            MR.  YORK:   This  is  a recommendation.

 3            MR.  LIAZOS:   This committee never  votes  on

 4  anything.  This is unusual tonight.   So,  I'm not sure it

 5  means anything.  Why is this  discussion one  night?

 6            MR.  YORK:   I think  it is important to mention

 7  several thing.  Cathy Sentoian has looked at it.  John has

 8  looked at it long and hard.  The things that are very

 9  important to me,  the givens of expediting it, for getting

10  the site development,  everyone knows the benefits of that

11  because there's a market out  there.

12     The issue of the environmental preference, which is

13  better, my choice, I look very strongly to the state, to the

14  EPA,  to the DEP,  to Jim, and  they have answered me very,

15  very clearly,  that they see this, the off-site, as safe.

16  They see it as effective.   There are some guestion is raised

17  as to whether the chemical oxidation will work.  It seems to

18  me that it is a simple issue.  I don't feel  rushed in my

19  vote, whatsoever, or I wouldn't make it.   I  think I have

20  asked the members of the agencies, who are the experts,

21  whether or not they felt rushed and  they very clearly said

22  no and I think they continue  to say  that.  I feel very

23  comfortable in the vote and I've heard the Reuse and I think

24  we send that message along to the government.

25            MS.  FALKOFF:   Now,  it seems to  me,  there's five

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 1  RAB members here and it may be that the RAB is not

 2  comfortable rendering a clear vote for chemical oxidation.

 3  And, I vote for off-site disposal.  It may be that with

 4  Alex's feelings of being rushed and Paul's wanting to check

 5  into things further, that the RAB is not ready to --

 6            MR.  DENNING:   I  wouldn't want to vote.   I'd

 7  abstain.

 8            MR.  LIAZOS:   I would,  too.

 9            MR.  DENNING:   Until,  you know,  contrary to what

10  Larry feels,  you know,  that I have polled the community and

11  will do so.  I will talk to people who live down there to

12  see what they feel.  Now,  you know, Cathy Sentoian, who is

13  someone who really is active in that area, according to

14  Mark, feels that she would like to see it off-site because

15  that's an important factor for me to hear.  But,  there are

16  people on Frank Street, there are people all in that area

17  that I will approach and explain it to them, so they will

18  understand, and then I'll report back to you in some form, a

19  letter, or whatever.  I'm not sure how much time we have.

20            FROM THE FLOOR:   And,  they feel the same way you

21  do.  Off-site.

22            MR.  DENNING:   I'm going to still call because I

23  want to know.

24            MS.  FALKOFF:   I  think we probably need  to direct a

25  letter to Chuck to who?  How should Paul convey his opinion?

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 1  What does the BCT think?

 2     Think what feels most appropriate for where the RAB

 3  is, what if we simply record that there's no consensus among

 4  the RAB at this point?  Rich is favoring off-site disposal.

 5  I'm favoring off-site disposal.  Tom's favoring oxidation.

 6  I also have Rudy's vote for off-site disposal.  Then,  we

 7  have two members who want more time to think about it.  I

 8  think that is perfectly consistent with our charter,  that

 9  we're under no pressure to take a vote.

10     Does that feel comfortable for people?

11            MR.  DENNING:   Would the soil go on a bill of

12  lading?

13            FROM THE FLOOR:   If it  goes to a Title  B landfill,

14  there are material transport records.

15            MS.  FALKOFF:   Okay.   I  make a motion for

16  adjournment and would request that any further technical

17  questions you have you address to the BCP after the meeting.

18  Does someone want to state that motion out loud?

19            MR.  DENNING:   Do you want to set another meeting?

20            MS.  FALKOFF:   Should we adjourn this meeting?   All

21  right.  The meeting is adjourned.

22                          [Whereupon,  the  meeting was

23                          adjourned at  9:02  p.m.]
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 1

 2               CERTIFICATE OF REPORTER AND TRANSCRIBER

 3               This is to certify that the attached proceedings

 4  in the Matter of:

 5  HEARING RE:

 6  FEASIBILITY STUDY REPORT

 7  REUSE PLAN

 8

 9

10

11     Place:   Watertown,  Massachusetts

12     Date:   August 8,  1996

13

14  were held as herein appears, and that this is the true,

15  accurate and complete transcript prepared from the notes

16  and/or recordings taken of the above entitled proceeding.

17

18

19  S. French                            08/08/96
    Reporter                             Date

20  B. Breen                      08/19/96
    Transcriber                          Date

21

22

23

24

25

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                                 APPENDIX D
                  SUMMARY  OF  ARARS FOR THE SELECTED REMEDY
                                                                                      Table D-l
                                           ARARs for Selected Remedy  (Alternative S6))Soil Excavation and Off-site Disposal or Reuse
                                                                              MTL Site,  Watertown, MA
Media
Soil
                                 Requirement

                         CHEMICAL-SPECIFIC

                         FEDERAL-EPA Risk Reference Doses  (RfDs)
                                                                                  RfDs are dose levels developed based on  the
                                                                                  nonearcinogenie effects and are used to  develop
                                                                                  Hazard Indices.   A Hazard Index of less  than  or
                                                                                  equal to 1 is considered acceptable.
                                                                 Action To  Be  Taken  To
                                                                  Attain Requirements
                                                                 EPA RfDs have  been  used to
                                                                 character!ze risks  caused by exposure
                                                                 to contaminants  in  soil.   Excavation
                                                                 and off-site disposal  or reuse of
                                                                 contaminated soils  will minimi ze risks.
                                                                                                                                                                                                            TBC
                         FEDERAL-EPA Carcinogen Assessment Group
                         Potency Factors
Potency Factors are developed  by EPA from
Health Effects Assessments  or  evaluation by the
Carcinogenic Assessment Group  and are used to
develop excess cancer risks.   A range of 10-4 to
10-6 is considered acceptable.
EPA Carcinogenic  Potency  Factors
have been used to compute the
individual incremental  cancer  risk
resulting from exposure to site
contamination in  soil.  Excavation and
off-site disposal or  reuse of
contaminated soils will minimi ze  risks.
                                                                                                                                                                                                            TBC
Soil
                         FEDERAL-Guidance on Remedial Actions for
                         Superfund Sites with PCB Contamination,
                         OSWER  Directive No. 9355.4-01  (8/90)
Describes the recommended  approach  for
evaluating and remediating sites  with PCB
contamination.
This guidance has been  used in
establishing a cleanup  goal for PCBs at
the site.  Excavation and  off-site
disposal or reuse of contaminated soils
will attain the cleanup goals.
                                                                                                                                                                                                            TBC
                         LOCATION-SPECIFIC
Soil
                                                                                  Requires that action be taken to preserve  historic
                                                                                  properties.   Planning action is required to
                                                                                  minimi ze the harm to national historic
                                                                                  landmarks.
                                                                 MTL is a historic  district and the
                                                                 Commander's  Quarters  is on the
                                                                 National Register  of  Historic Places.
                                                                 Army will  consult  with State Historic
                                                                 Office to  ensure that actions that may
                                                                 cause structural damage to any
                                                                 building will  be minimized.
                                                         Applicable
-------
                                                                                      Table D-l
Media

Soil
                                           ARARs for Selected Remedy  (Alternative S6))Soil Excavation and Off-site  Disposal or Reuse
                                                                               MTL Site,  Watertown, MA
                                                                                     (Continued)
        Requirement

FEDERAL-16 USC 469A-1, Archaeological and
Historic Preservation Act
                                                                                  Provides for the preservation of historical  and
                                                                                  archaeological artifacts that might be  lost  from
                                                                                  alterations of the terrain.  The Act  requires  data
                                                                                  recovery and preservation activities  be conducted
                                                                                  if any project may cause irreparable  loss  or
                                                                                  destruction to scientific, prehistoric,  or
                                                                                  archaeological data.
                                                                         Action  To  Be  Taken To
                                                                         Attain  Requirements

                                                                 Actions involving  intrusive work (e.g.,
                                                                 excavation  and  construction)  will
                                                                 require involvement of archaeologists
                                                                 and regulatory  agencies if artifacts are
                                                                 found.  Two known  historic sites and
                                                                 one suspected prehistoric site are
                                                                 present at  the  MTL site.
                                                Applicable
                         FEDERAL-Executive Order 11988  (Protection of
                         Floodplains)  40 CFR 6, Appendix A
                                                         Requires that  any action within a floodplain be
                                                         conducted  so as  to avoid adverse effects,
                                                         minimi ze harm, and restore natural and
                                                         beneficial values.
                                                                 Part of the  River  Park is a designated
                                                                 floodplain.  Any excavation or other
                                                                 activities will  be conducted to
                                                                 minimi ze  harm  and  all  areas disturbed
                                                                 will be restored.
                                                 Applicable
Soil
                                                                                  Establishes regulations to minimi ze or mitigate
                                                                                  adverse effects to properties listed  in  the  State
                                                                                  Register of Historic Places.  MTL is  listed  in the
                                                                                  State Register.  The regulations contain standards
                                                                                  that protect the public's interest in preserving
                                                                                  historic and archaeological properties as early  as
                                                                                  possible in the planning process of any  proj ect.
                                                                                                                           Requirements include notification to
                                                                                                                           the  Massachusetts Historical
                                                                                                                           Commission (MHC).  MHC will make
                                                                                                                           a  determination as to whether the
                                                                                                                           actions  planned will have an adverse
                                                                                                                           impact.   If so,  the MHC and party
                                                                                                                           responsible for the action will consult
                                                                                                                           to determine ways to minimize adverse
                                                                                                                           impacts.
Soil,  Hazardous
Waste
FEDERAL-Test Methods  for  Evaluating Solid
Waste, Physical/Chemical  Methods,  EPA
Publication SW-846
This guidance document sets  forth  the  methods
for conducting TCLP testing.
The guidance will be  used  when
testing soils at the  site  to  determine
whether they constitute  hazardous
waste.  Any soils that are found to be
hazardous will be disposed of in a
licensed facility.
Soil,  Hazardous
Waste
STATE-310 CMR 30.300,  Hazardous Waste
Generator Requirements
Establishes requirements  for  generators of
hazardous wastes.
                                                 Applicable
-------
                                                                                      Table D-l
                                           ARARs for Selected Remedy  (Alternative  S6)) Soil Excavation and Off-site Disposal  or Reuse
                                                                              MTL  Site,  Watertown,  MA
                                                                                     (Continued)
Soil,  Hazardous
Waste
                                 Requirement

                         STATE-310  CMR 30.640,  Waste Piles
                                                                                                                                                                           Relevant and
                                                                                                                                                                           Appropriate,
                                                                                                                                                                           Applicable  for
                                                                                                                                                                           any soil
                                                                                                                                                                           class!fied  as
                                                                                                                                                                           hazardous
                                                                                                                                                                           waste.
Soil, Hazardous
Waste
                                                         Establishes requirements  for  the  management of
                                                         containers, such as drums,  that would hold field-
                                                         generated hazardous waste.
                                                 Relevant and
                                                 Appropriate,
                                                 Applicable for
                                                 any soil
                                                 class!fied as
                                                 hazardous
                                                 waste.
Air
STATE-310 CMR 19, Solid Waste Management                 Establishes requirements  for  the  treatment,
                                                         storage, and disposal  of  nonhazardous solid
                                                         waste.   Has additional rules  for  the  management
                                                         of Special Waste, which is  defined as solid waste
                                                         that is nonhazardous  for  which  special
                                                         management controls are necessary to  protect
                                                         adverse impacts.

FEDERAL-CAA 40 CFR Part 61, National                     Sets air emission standards for 189 designated
Emission Standards for Hazardous  Air  Pollutants hazardous air pollutants  (HAPs) from  designated
(NESHAPs)                                                source activities .
Nonhazardous excavated  soil  or
treatment residues will  be handled in
accordance with substantive
requirements.  If soils  or residues
meet the definition of  Special  Waste,
management will be in compliance
with these requirements.

Sampling at MTL has indicated the
presence of several HAPs  in  soils.
Since site remediation  is a  designated
source category  (but in  this case  is
unlikely to be a major  source),
NESHAPS are relevant and
appropriate and all remedial activities
will be designed to meet  Maximum
Achievable Control Technology
(MACT).
                                                                                                                                                                                                    Relevant and
                                                                                                                                                                                                    Appropriate
                                                                                                                                                                                                    Relevant and
                                                                                                                                                                                                    Appropriate
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                                                                                      Table D-l
                                           ARARs for Selected Remedy  (Alternative S6))Soil Excavation and Off-site Disposal or Reuse
                                                                               MTL Site,  Watertown, MA.
                                                                                     (Continued)
Media

Air
        Requirement

STATE-310 CMR 7, Air Pollution  Control
Regulations
                                                                                  Establishes requirements for attaining  ambient  air
                                                                                  quality standards by setting emission limitations ,
                                                                                  design sped fi cat ions ,  and permitting .  Watertown
                                                                                  is in an attainment area for lead, nitrous  oxide,
                                                                                  sulfur dioxide ,  and part icul ate matter, and is  in  a
                                                                                  nonattainment area for ozone and carbon
                                                                                  monoxide .   Pertinent sections of the regulation
                                                                                  include Visible Emissions  (310 CMR 7.06);
                                                                                  Dust ,  Odor, Construction, and Demolition  (310
                                                                                  CMR 7.09);  Noise (310 CMR 7.10); and
                                                                                  Volatile Organic Compounds  (310 CMR 7.18) .
Remedial activities will  be  conducted
so as to incorporate  Reasonably
Available Control  Technology (RACT)
for emissions of lead,  nitrous  oxide,
sulfur dioxide, and particulate matter
and to achieve Lowest Achievable
Emission Rate  (LAER)  for  VOCs and
carbon monoxide.
Applicable
(310 CMR
7 .06, 7.09,
and 7.10)
Relevant and
Appropriate
(310 CMR
7.18)
Air
                                                                                  This policy considers sound emissions  to  be  in
                                                                                  violation of 310 CMR 7.10 if the source
                                                                                  increases the broadband sound level by more
                                                                                  than 10 dB (A) above ambient, or produces  a
                                                                                  "pure tone" condition as measured at both the
                                                                                  property line and at the nearest inhabited
                                                                                  residence .
                                                                                                                                                                                                    TBC
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