New Bedford Harbor Super fund Site
Operable Unit (OU) 1
Focused Feasibility Evaluation:
Comparison of
Confined Disposal Facilities (CDFs) A, B &C versus
Off-Site Disposal
for PCB Contaminated Sediment
Prepared by EPA Region 1
Office of Site Remediation and Restoration
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April 2015
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SDMS Doc ID 574356
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Table of Contents
Section Page
1.0 Introduction 1
1.1 Site Background 1
1.2 Summary of OU1 Remedy Decision Documents 2
1.3 Current Status of OU1 Cleanup Efforts 3
1.4 Purpose of the Focused Feasibility Evaluation 3
1.5 Background on Selection of CDFs and CDF Capacity 4
2.0 Development of Disposal Alternatives for the FFE 6
2.1 Disposal Alternatives Evaluated 7
2.1.1 Alternative 1 - Confined Disposal Facilities (CDFs) 7
2.1.2 Alternative 2 - Off-Site Transportation and Disposal 7
3.0 Detailed Analysis of Alternatives 8
3.1 Evaluation Criteria 8
3.1.1 Threshold Criteria 8
3.1.2 Primary Balancing Criteria 8
3.1.3 Modifying Criteria 10
3.2 Individual Analysis of Alternatives 10
3.2.1 Alternative 1 - Confined Disposal Facilities (CDFs) 10
3.2.1.1 Threshold Criteria 10
3.2.1.2 Primary Balancing Criteria 12
3.2.2 Alternative 2 - Off-Site Transportation and Disposal 14
3.2.2.1 Threshold Criteria 15
3.2.2.2 Primary Balancing Criteria 16
3.3 Comparative Analysis of Disposal Alternatives 17
3.3.1 Threshold Criteria 18
3.3.2 Primary Balancing Criteria 18
3.3.2.1 Effectiveness 18
3.3.2.2 Implementability 19
3.3.2.3 Cost 20
3.3.3 Modifying Criteria 20
4.0 References 20
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List of Figures
Figure 1, Site Location Map
Figure 2, Areas Dredged in New Bedford Harbor through 2013
Figure 3, Dredge Areas Scheduled for 2014 Dredge Season
Figure 4, Conceptual Locations of CDFs A, B and C (ROD Figure 21a)
Figure 5, Conceptual Location of CDF D (ROD Figure 21b)
List of Tables
Table 1, Detailed Analysis of Alternative 1 - Confined Disposal Facilities (CDFs)
Table 2, Summary of Cost Estimate for CDF Disposal Alternative
Table 3, Detailed Analysis of Alternative 2 - Off-Site Transportation and Disposal
Table 4, Summary of Cost Estimate for Off-Site Transportation and Disposal
Table 5, Comparative Analysis of Alternatives
Attachments
Attachment A: 1998 ROD ARARs Table
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1.0 Introduction
1.1 Site Background
The New Bedford Harbor Superfund Site (the Site), located in Bristol County,
Massachusetts, encompasses approximately 18,000 acres and extends from the shallow northern
reaches of the Acushnet River estuary south through the commercial harbor of New Bedford and
into Buzzards Bay (Figure 1, Site Location Map). The Site has been divided into three areas
consistent with geographical features of the area and gradients of contamination. The Upper
Harbor comprises approximately 200 acres. The boundary between the Upper and Lower Harbor
is the Coggeshall Street Bridge, where the width of the harbor narrows to approximately 100
feet. The Lower Harbor comprises approximately 750 acres. The boundary between the Lower
and Outer Harbor is the New Bedford hurricane barrier (constructed in the mid-1960s). The
Outer Harbor area extends to its southern (and the Site's) boundary formed by an imaginary line
drawn from Rock Point (the southern tip of West Island in Fairhaven) southwesterly to Negro
Ledge and then southwesterly to Mishaum Point in Dartmouth and encompasses an area of
approximately 17,000 acres.
The Site has been divided into three Operable Units (OUs), or phases of cleanup. The
Upper Harbor and Lower Harbor (OU1); the Hot Spot area (OU2); and the Outer Harbor (OU3).
The Record of Decision (ROD) for OU2 was signed on April 6, 1990; an Explanation of
Significant Differences (ESD) was issued in April 1992; a second ESD was issued in October
1995; and finally, a ROD Amendment for OU2 was issued in April 1999. The OU2 remedy
provided for the dredging of approximately 14,000 cubic yards (cy) of the most highly
contaminated sediment (PCB concentrations ranging from 4,000-100,000 parts per million
(ppm)), dewatering, water treatment, air monitoring and disposal of the dewatered sediment at an
off-site TSCA-permitted disposal facility. [TSCA is the Toxic Substances Control Act, which,
among other things, regulates management and disposal of PCB-contaminated waste.] The OU2
remedial efforts were completed in May 2000 and OU2 is considered closed. The OU2
geographical area was generally located in a five-acre area in the Upper Harbor near the Aerovox
facility, which was the primary source of PCB contamination to the Site. This area is within the
OU1 geographical area (contaminated sediment remaining in the Upper and Lower Harbor areas
are addressed under the OU1 remedy (see below)).
The ROD for OU3 is currently unscheduled. EPA is in the process of performing the
remedial investigation for OU3 and has not yet selected a remedy.
This Focused Feasibility Evaluation (FFE) is issued with respect to an element of the
OU1 ROD: the disposal of approximately 175,000 cy of PCB-contaminated sediment currently
slated for CDF disposal. A summary of the OU1 remedy and the purpose of the FFE are detailed
below.
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1.2 Summary of OU1 Remedy Decision Documents
The ROD for OU1 (also known as ROD 2 or the 1998 ROD) was signed on September
25, 1998. The cleanup plan selected in the ROD called for dredging of approximately 450,000
cy of in situ sediment in the Upper Harbor and Lower Harbor with PCBs above the selected
cleanup goals:
• Upper Harbor subtidal and mudflat areas: 10 ppm PCBs
• Lower Harbor subtidal and mudflat areas: 50 ppm PCBs
• Intertidal areas with abutting residential land use: 1 ppm PCBs
• Intertidal areas with public access of abutting recreational land use: 25 ppm PCBs
• Saltmarsh areas with little or no public access: 50 ppm PCBs.
The OU1 ROD called for the construction of four shoreline confined disposal facilities
(CDFs) (A, B, C, and D) to contain and isolate the dredged sediment (further discussed in
Section 1.5 below), associated water treatment, capping of the CDFs, long-term monitoring and
maintenance, and institutional controls. The CDFs were conceptually located in PCB-
contaminated areas to avoid the need to dredge an additional approximately 126,000 cy of in situ
sediment, which instead would have been contained within the footprint of the CDFs.
In September 2001, EPA issued an ESD revising the OU1 remedy (ESDI). ESDI,
among other changes, reduced the footprint of CDF D, revised the CDF D wall design,
incorporated the use of mechanical dewatering for the dredged sediments (to reduce the disposal
volume), and incorporated a rail spur for use in the cleanup efforts. Benefits of dewatering are
detailed in ESDI and include the production of a dewatered sediment "filter cake" that could be
placed mechanically into the CDFs and is drier than the slurry from hydraulic dredging. This
would reduce the time required for consolidation, capping and beneficial reuse of the final CDFs.
This ESD also noted that the total estimated volume of in situ sediment to be dredged could be as
high as 800,000 cy.
In August 2002, EPA issued the second ESD revising the OU1 remedy (ESD2). ESD2
eliminated the construction of the planned 17-acre CDF D (the largest of the four CDFs), and
instead selected off-site disposal for the dredged and dewatered sediment slated for that CDF
(further discussed in Section 1.5 below). A smaller shoreline facility, Area D, replaced CDF D
in the same area to support both the sediment dewatering building and the rail car and truck
loading area required for off-site disposal of the dewatered sediment. ESD2 also added the
desanding operation at EPA's Sawyer Street facility as a component of the remedy, which
improves the efficiency of the dewatering operation.
In March 2010, EPA issued the third ESD revising the OU1 remedy (ESD3). ESD3
documented the use of Cell #1 (located at Sawyer Street) for temporary storage of PCB- and
hazardous waste-contaminated sediment from OU 1.
In March 2011, EPA issued the fourth ESD revising the OU1 remedy (ESD4). ESD4
incorporated the construction and use of a Lower Harbor Confined Aquatic Disposal (CAD) cell
(LHCC) for permanent disposal of approximately 300,000 cy of mechanically dredged sediment.
The fourth ESD also updated the volume of total in situ contaminated sediment to be addressed
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to meet cleanup goals to be approximately 900,000 cy, of which approximately 425,000 cy
would be disposed of off-site, approximately 300,000 cy would be disposed of in the LHCC, and
approximately 175,000 cy would be disposed of in remaining CDFs A, B, and C.
1.3 Current Status of OU1 Cleanup Efforts
The end of the 2014 dredge season marked the successful completion of the eleventh
season of OU1 remedial dredging at the New Bedford Harbor Superfund Site. Over the 11
seasons of dredging, EPA has completed the dredging and removal of approximately 327,000 cy
of in situ sediment mainly from the Upper Harbor. Incorporating dredging conducted in early
action efforts prior to the implementation of full-scale dredging, the total volume of
contaminated sediment dredged from the New Bedford Harbor Superfund site since the issuance
of the OU1 ROD is approximately 365,000 cy. Figure 2 shows the areas dredged through 2013.
In September 2013, the U.S. District Court approved a landmark $366.25 million cash-
out settlement with AVX Corp., whose corporate predecessor, Aerovox Corp., owned and
operated what was known as the Aerovox facility, an electrical manufacturing plant located on
the western shore of New Bedford Harbor (through "reopeners" of a 1992 settlement with AVX).
Due to prior limitations in Superfund funding (which had typically been $15 million per year for
this Site), the project was expected to take another 40 years. With this settlement, this project
will be accelerated to be substantially completed within 5 to 7 years.
As a result of the settlement, EPA was able to implement equipment upgrades and
improvements for the 2014 dredge season and fund a much longer dredge season than was
feasible at a lower funding level over the prior 10 years. Figure 3 shows the dredge areas
completed during the 2014 dredge season. EPA dredged approximately 77,000 cy in situ PCB-
contaminated sediment during the 2014 dredge season. This represents almost a four-fold
increase in annual dredge production over past years and is the first demonstration of the
expedited cleanup of the New Bedford Harbor Superfund Site as a result of the settlement.
In addition, construction of the LHCC is underway and expected to be completed in
2015. Following completion of CAD cell construction, mechanical dredging of contaminated
sediment and disposal into the LHCC will likely be performed in 2016 through 2018, and the
dredged sediment will be allowed to consolidate in the cell followed by capping, consistent with
ESD4.
With the accelerated pace of cleanup, EPA will shortly need to build CDFs A, B, and C
for the disposal of approximately 175,000 cy of in-situ PCB-contaminated sediment, or consider
alternative(s).
1.4 Purpose of the Focused Feasibility Evaluation
As detailed above in Section 1.2, the New Bedford Harbor OU1 remedy currently
includes a combination of technologies for disposal of contaminated sediment from the Upper
and Lower Harbors, including shoreline Confined Disposal Facilities (CDFs), a Confined
Aquatic Disposal (CAD) cell, and off-site disposal. With respect to the CDFs, as discussed in
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detail in ESD2, preliminary design work indicated that significant cost and implementability
concerns exist and that EPA would need to re-evaluate their use going forward.
Consistent with ESD2, EPA, in responses to comments on the settlement, notified the
public that we would evaluate alternative disposal options and consider other protective, cost-
effective alternatives for the disposal of contaminated sediment other than the selected CDFs A,
B and C.
This FFE documents EPA's analysis and comparison of disposal in the CDFs versus off-
site disposal for PCB-contaminated sediment. Although not required to be prepared, consistent
with "A Guide to Preparing Superfund Proposed Plans, Records of Decision, and Other Remedy
Selection Decision Documents", this FFE may be used to support an Explanation of Significant
Differences (ESD) by offering a comparison of the original and alternative remedial disposal
alternatives. The purpose of this FFE is to offer a "focused" evaluation of disposal alternatives
for contaminated sediment slated for disposal in CDFs A, B and C, and thus, this FFE limits
discussion to that purpose. For overall information on the Site, please visit the New Bedford
Harbor Superfund Site website at http://www2.epa.gov/new-bedford-harbor.
It is important to note that included in the 900,000 cy estimate of contaminated sediment
to be addressed under the OU1 remedy is approximately 48,000 cy of intertidal vegetated
material. This vegetated contaminated sediment volume from the intertidal saltmarsh and fringe
wetland areas is planned for mechanical excavation, likely from shoreline locations. Due to the
presence of vegetation and the nature of this material, this contaminated sediment volume would
not be processed through desanding or dewatering equipment. Since the approximately 725,000
cy of contaminated sediment currently slated for disposal via the LHCC or desanding,
dewatering and off-site disposal is subtidal, this vegetated contaminated sediment volume needs
to be accounted for in the 175,000 cy of contaminated sediment for which disposal alternatives
are being evaluated in this FFE. As such, the volume of contaminated sediment under evaluation
includes the 48,000 cy of in situ vegetated contaminated sediment and 127,000 cy of in situ
subtidal sediment.
Following issuance of this FFE, if EPA proposes to change the disposal of the
approximately 175,000 cy of in situ PCB-contaminated sediment from CDFs A, B and C to off-
site disposal, then EPA intends to issue a draft ESD to propose such change. The basis for the
modification of the OU1 remedy would include the analysis performed in this FFE. EPA will
accept comments on the draft ESD during a formal public comment period.
1.5 Background on Selection of CDFs and CDF Capacity
The cleanup plan selected in the OU1 ROD included the construction and operation of
four shoreline CDFs and water treatment facilities. The conceptual locations of the four CDFs
are depicted in OU1 ROD Figures 21a and 21b, replicated here as Figures 4 and 5. As
envisioned, contaminated sediment disposed in the CDFs would be allowed to consolidate and
then capped. Institutional controls and long-term monitoring would be implemented to ensure
long-term protectiveness.
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The conceptual 'air' capacities of the four CDFs as documented in the Administrative
Record for the OU1 ROD, are as follows:
CDF A = Capacity of 56,400 cy
CDF B = Capacity of 50,700 cy
CDF C = Capacity of 93,800 cy
CDF D = Capacity of 435,000 cy
A total storage capacity of approximately 635,900 cy was needed for the approximately
450,000 cy of in situ contaminated sediment to be dredged and placed into the CDFs. The
increased volume results from the hydraulic dredging of the sediment which can account for an
increase in volume between an estimated 30 to 40% (referred to as the 'bulking factor'). At the
time of the OU1 ROD, mechanical dewatering was not part of the remedy. Mechanical
dewatering and making of filter cake from hydraulic slurry greatly reduces the volume of the
contaminated sediment needing disposal. Mechanical dewatering was added as a component of
the remedy in 2001 with ESDI.
Note that the four originally proposed CDFs were sited so as to avoid dredging
approximately 126,000 cy of in situ PCB-contaminated sediment within footprints of the CDFs;
thus the actual estimate of OU1 contaminated sediment to be addressed under the OU1 ROD was
approximately 576,000 cy in situ.
As noted in Section 1.2, ESD2 eliminated CDF D for a variety of cost and engineering
reasons and selected off-site disposal for the sediment slated for CDF D, which was later
modified by ESD4 to include disposal in the LHCC.
As further noted above in Section 1.2, ESD4 updated the estimate of in situ contaminated
sediment to be addressed under the OU1 ROD to approximately 900,000 cy (versus the 576,000
cy initially estimated in the OU1 ROD). ESD4 provides an analysis, in Section II.C.,
documenting that the 435,000 cy 'air' capacity of CDF D translates to 725,000 cy of in situ
sediment capacity.1 Of the 725,000 cy of in-situ PCB-contaminated sediment originally slated to
be disposed of in CDF D, approximately 425,000 cy would be disposed of off-site2, and
approximately 300,000 cy would be disposed of in the LHCC.
Based on the updated contaminated sediment estimate of 900,000 cy of in situ sediment
to be addressed and the estimated volume of 725,000 cy originally slated for CDF D (now slated
1 As a result of desanding and dewatering operations that are now part of the remedy (ESDI and
ESD2), the conceptual "air space" capacity of the CDF can be assumed to reflect dewatered sediment.
The original capacity is divided by a 0.6 conversion factor to calculate the volume of in situ sediment that
could be accommodated in that available air space. Therefore, the total volume currently slated for off-
site disposal and disposal in the LHCC is considered to be approximately 725,000 cy of in situ sediment.
See ESD4, Section II.C.
2 Included in this estimate of 425,000 cubic yards is approximately 10,000 cubic yards of
contaminated sediment in the Outer Harbor just south of the New Bedford Hurricane Barrier near the
New Bedford shore that have been addressed by a pilot underwater cap.
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for off-site disposal and the LHCC), approximately 175,000 cy (900,000 cy minus 725,000 cy)
of in situ contaminated sediment is currently slated for disposal in CDFs A, B and C.
In January 2014, EPA determined that construction of CFD C within the area between
Sawyer Street and Coggeshall Street could be avoided and limited the overall size of CDF C to
only the area adjacent to the previously constructed Pilot CDF. This remedial design change was
determined to be a non-significant or minor change. This change was estimated to result in a
reduction in capacity of CDF C by one-half to two-thirds the original conceptual design capacity
(hereinafter "modified-C").
Using the 'air space' capacities listed above, under the current OU1 remedy, CDFs A, B
and modified-C have the conceptual 'air' capacity of 140,000-154,000 cy (56,400 + 50,700 +
(93,800 / 2 or 3)), more than adequate to accommodate the approximately 175,000 cy in situ
contaminated sediments currently slated for CDFs.3
2.0 Development of Disposal Alternatives for the FFE
EPA prepared a Feasibility Study (FS) for OU1 for the Site in 1990 that lead to the 1998
OU1 ROD. The 1990 FS considered a range of disposal alternatives for dredged sediment,
including CDFs, CAD cells, upland disposal, ocean disposal, and off-site disposal. Currently,
the OU1 remedy (1998 OU1 ROD as modified by four ESDs) includes a combination of disposal
alternatives - CDFs, a CAD cell and off-site disposal - for the disposal of contaminated
sediments.
In the 1990 FS, EPA evaluated a "No Action" alternative for OU1 that involved no active
remediation for the Upper Harbor and Lower Harbor. This "No Action" alternative for OU1 was
determined to fail to meet the two NCP threshold criteria since it would not be protective of
human health or the environment and would not meet applicable or relevant and appropriate
requirements (ARARs). For the purpose of this FFE, the "No Action" alternative for the
disposal is the construction and use of CDFs A, B and modified-C.
At the time of the 1990 FS, disposal of PCB-contaminated sediment in upland disposal
locations in the New Bedford Harbor area, but away from the harbor, and in offshore (i.e., ocean)
open water disposal locations were eliminated from further consideration. Although these
disposal options are technically feasible, lack of suitable sites, permitting conflicts, and the
regulatory environment led to the determination that neither disposal option would be acceptable.
3 As noted in Section 1.4, the volume of contaminated sediment under evaluation includes
approximately 48,000 cy of in situ vegetated contaminated sediment and 127,000 cy of in situ subtidal
sediment. The approximately 48,000 cy of contaminated vegetated material would be stabilized for
transportation through the addition of Portland cement, resulting in an estimated volume increase of 13%,
making the volume for disposal approximately 54,000 cy. For the purpose of this FFE, for subtidal
sediments, the conversion factor discussed above (see footnote 1) was adjusted to a 0.65 conversion factor
to account for both sand and dewatered sediment filter cake. As such, 127,000 cy of in situ subtidal
sediment translates to approximately 83,000 cy of sand and dewatered sediment filter cake. Therefore,
the storage volume, or "air" capacity, of the CDF would need to be approximately 137,000 cy with
additional adequate capacity for interim and final cap material.
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These same concerns exist today for upland disposal and offshore open water disposal.
Therefore, the disposal alternatives of upland disposal and offshore disposal were not evaluated
in this FFE.
With respect to disposal in a CAD cell, ESD4 called for using the LHCC for disposal of
approximately 300,000 cy of OUl's approximately 900,000 cy of contaminated sediment. There
are complex and time-consuming approval, design, engineering and contracting efforts that
would need to be conducted to provide for the construction of another Superfund CAD cell.
Using EPA's experience with the LHCC, siting, design, contracting and construction of another
CAD cell could take 4-5 years and would need to be followed by mechanical dredging and filling
of the CAD and ultimately capping. In addition, the 48,000 cy of vegetated material is not
suitable for disposal in a CAD due to the presence of vegetation. EPA is committed to an
accelerated cleanup, and therefore another Superfund CAD cell was not evaluated in this FFE.
In this FFE, EPA evaluated the CDF disposal and off-site disposal for the 175,000 cy of
in situ contaminated sediment currently slated for disposal in CDFs A, B and modified-C.
2.1 Disposal Alternatives Evaluated
2.1.1 Alternative 1 - Confined Disposal Facilities (CDFs)
A CDF is an engineered structure consisting of dikes or other structures that enclose a
disposal area for containment of dredged sediment and is designed to provide the required
storage volume for dredged material. A CDF may be constructed as an upland site, as a
shoreline site with one or more sides exposed to the water, or as an island containment area. As
conceptually planned under the OU1 ROD, CDFs A, B and modified-C were to be shoreline
structures. See Figure 4. For the purpose of this FFE, primarily to simplify the cost estimate, it
was assumed that only one shoreline CDF would need to be constructed to accommodate the
175,000 cy of in situ sediment. As detailed in Section 1.5 above, the storage volume or "air
space" of the CDF would need to be approximately 137,000 cy with additional adequate capacity
for interim and final cap material (for a total capacity estimated as 145,000 cy).
2.1.2 Alternative 2 - Off-Site Transportation and Disposal
Off-site disposal is the transportation and permanent disposal of contaminated material at
a facility that is permitted to accept and dispose of the material. Prior to disposal, the
contaminated material would be characterized and classified as either a non-hazardous or
hazardous material based on RCRA regulations and as either a TSCA waste (>50 ppm PCBs) or
non-TSCA. As currently performed at the Site, disposal of contaminated sediment via off-site
transportation and disposal provides for the disposal of dewatered sediment filter cake with > 50
ppm PCB at a TSCA-permitted facility or a RCRA hazardous waste-permitted landfill and
disposal of material with <50 ppm PCBs at a state-permitted non-hazardous waste RCRA
Subtitle D landfill. For this analysis, accounting for desanding and dewatering and disposal of
the stabilized vegetated contaminated sediment, the volume of material for off-site disposal
would be approximately 137,000 cy.
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3.0 Detailed Analysis of Alternatives
3.1 Evaluation Criteria
3.1.1 Threshold Criteria
In accordance with the NCP, two threshold criteria must be met in order for the
alternative to be eligible for selection.
1. Overall Protection of Human Health and the Environment: This evaluation criterion
provides an assessment as to whether the alternative adequately protects human health
and the environment, and draws on the assessments conducted under other evaluation
criteria, especially long-term effectiveness and permanence, short-term effectiveness, and
compliance with ARARs. As part of the determination of protectiveness, the evaluation
describes how risks through each pathway would be eliminated, reduced, or controlled
through treatment, engineering, or institutional controls.
2. Compliance with Applicable or Relevant and Appropriate Requirements (ARARs):
Alternatives are assessed as to whether they attain federal and state legally applicable or
relevant and appropriate requirements (ARARs), including:
• Chemical-specific ARARs (e.g., maximum contaminant levels [MCLs], Ambient
Water Quality Criteria [AWQC]);
• Location-specific ARARs (e.g., requirements for constructing a hazardous waste
facility in a floodplain);
• Action-specific ARARs (e.g., Toxic Substances Control Act requirements for PCB
remediation waste); and,
• Other criteria, advisories, and guidelines, as appropriate.
3.1.2 Primary Balancing Criteria
The following five criteria are used to compare and evaluate those alternatives which
fulfill the two threshold criteria.
3. Long-Term Effectiveness and Permanence: Alternatives are assessed for the long-term
effectiveness and permanence they afford, and the degree of certainty that the alternative
will prove successful. Factors that can be considered, according to the NCP and RI/FS
Guidance, are as follows:
• Long-term reliability and adequacy of the engineering and institutional controls,
including uncertainties associated with land disposal of untreated wastes and
residuals.
• Magnitude of residual risks in terms of amounts and concentrations of wastes
remaining following implementation of a remedial action, considering the
persistence, toxicity, mobility, and propensity to bioaccumulate of such hazardous
substances and their constituents.
4. Reduction of Toxicity, Mobility or Volume through Treatment: CERCLA expresses
a preference for remedial alternatives that employ treatment that reduces the toxicity,
mobility, or volume of hazardous substances. Relevant factors include:
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• The treatment processes that the remedies employ and the materials they will treat;
• The amount of hazardous materials that will be destroyed or treated;
• The degree of expected reduction in toxicity, mobility, or volume;
• The degree to which the treatment is irreversible; and,
• The type and quantity of residuals that will remain following treatment, considering
the persistence, toxicity, mobility, and propensity to bioaccumulate of such hazardous
substances and their constituents.
Short-Term Effectiveness: The short-term effectiveness of alternatives is assessed
considering such appropriate factors as:
• Protection of the community during remedial actions;
• Protection of the workers during remedial actions;
• Potential adverse environmental impacts resulting from construction and
implementation; and
• Time until remedial response objectives {i.e., RAOs and PRGs) are achieved.
Implementability: The ease or difficulty of implementing the alternatives are assessed
by considering the following factors:
• Technical Feasibility
- Degree of difficulty associated with constructing and operating the technology;
- Expected operational reliability of the technologies;
- Ease of undertaking additional remedial actions, if necessary; and
Ability to monitor the effectiveness of the alternative.
• Administrative Feasibility
- Need to coordinate with and obtain necessary approvals and permits {e.g.,
obtaining permits for off-site activities, rights-of-way for construction, etc.) from
other agencies and offices.
• Availability of Services and Materials
Availability of necessary equipment and specialists;
Availability of adequate capacity and location of needed treatment, storage, and
disposal services;
Availability of prospective technologies; and
Availability of services and materials, plus the potential for obtaining competitive
bids.
Cost: Costs for CERCLA evaluation are divided into two principal categories (i.e.,
capital costs and annual operation and maintenance (O&M) costs). A number of
principal elements of a remedial alternative may fall into the category of direct and
indirect capital costs:
• Construction costs;
• Equipment costs;
• Site development costs;
• Building and services costs;
• Transport and disposal costs;
• Engineering expenses;
• Startup and shakedown costs; and
• Contingency allowances.
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Those items not placed into the capital cost category are considered to be O&M costs,
among which are the following:
• Operating labor costs;
• Materials and energy costs;
• Purchased services;
• Administrative and insurance costs; and
• Costs of periodic site reviews.
Costs are estimated and translated into present worth costs for comparison. Present worth
is the amount required to fund a project assuming that amount can be invested at the start
of the project for a given rate of return as the project progresses. Present worth estimates
help evaluate various options on an equal basis.
3.1.3 Modifying Criteria
The two modifying criteria discussed below are used in the final evaluation of remedial
alternatives generally after EPA has received public comment on the RI/FS and Proposed Plan.
8. State Acceptance: This criterion addresses the State's position and key concerns related
to the preferred alternative and other alternatives, and the State's comments on ARARs or
the proposed use of waivers. This criterion provides the state with the opportunity to
assess any technical or administrative issues and concerns regarding each of the
alternatives. State acceptance is not addressed in this FFE, but would be addressed
following public comment on the ESD.
9. Community Acceptance: This criterion addresses the public's general response to the
alternatives described in the FFE and follow-on decision document. Issues and concerns
the public may have regarding each of the alternatives falls into this category of
evaluation. Community acceptance is not addressed in this FFE document, but would be
addressed following public comment on the ESD.
3.2 Individual Analysis of Alternatives
3.2.1 Alternative 1 - Confined Disposal Facilities (CDFs)
See Section 2.1.1 for a description of this alternative. As this disposal option for the
approximately 175,000 cy of PCB-contaminated sediment to be disposed of in CDFs A, B and
modified-C is currently part of the OU1 remedy, this alternative has already been determined to
meet the NCP's nine criteria. Nonetheless, this subsection presents an updated analysis of the
CDF disposal component, which is the "No Action" alternative for this FFE. A summary of the
analysis is presented in Table 1.
3.2.1.1 Threshold Criteria
Criteria 1: Overall Protection of Human Health and the Environment
Contaminated sediment above cleanup goals that drive unacceptable risks would be
removed through dredging and permanently isolated in CDFs. Dredging of contaminated
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sediment and disposal in shoreline CDFs would effectively reduce the potential for direct contact
exposure and limit the source of PCB contamination in surface water and biota. Exposure
pathways would be eliminated or addressed through the implementation of institutional controls
and long-term monitoring to ensure that the remedy remains protective of human health and the
environment.
The CDF construction and permanent location of the CDF facilities would cause
environmental impacts, as the biota and intertidal and subtidal resource within the footprint of
the CDFs would be permanently destroyed. However, any wetland habitat impacted by the
remedial efforts would be restored or mitigated.
Criteria 2: Compliance with ARARs
Section XII and Table 8 of the OU1 ROD provide a detailed discussion and listing of
ARARs for the New Bedford Harbor Superfund Site. The ARARs table (Table 8) from the OU1
ROD is reproduced herein as Attachment A. However, former regulations that incorporated
requirements of Executive Orders 11988 (Management of Floodplain) and 11990 (Protection of
Wetlands) at 40 CFR Part 6, Appendix A, as cited in the 1998 ROD, no longer exist. Federal
Emergency Management Agency (FEMA) regulations at 44 CFR § 9, which set forth the policy,
procedure and responsibilities to implement and enforce these Executive Orders, are considered
relevant and appropriate. These regulations have been previously cited as an ARAR in ESD4 for
the LHCC component of the OU1 remedy.
The goal of the remedy, including the disposal component, is to reduce health risks due to
consumption of PCB-contaminated local seafood, as well as reduce health risks due to contact
with or incidental ingestion of PCB-contaminated shoreline sediment and improve the severely
degraded ecosystem. This will be accomplished by dredging and off-site disposal of PCB-
contaminated sediment in order to lower PCB concentrations in sediment and in the water
column. The State fishing ban will continue, along with other institutional controls, to minimize
consumption of local seafood.
CDFs would be designed and constructed to ensure that wetlands, fish and wildlife
habitat related ARARs and ARARs for the preservation of historical and archeological data were
met and to protect against storm damage and control flooding. Some unavoidable interference
with public access would temporarily occur during construction and filling of the CDFs.
However, once CDFs are permanently capped, access across CDFs is feasible.
Consistent with the 1998 ROD, PCB-contaminated sediment above EPA's clean up levels
must be handled and disposed of in accordance with 40 CFR 761.61(c) of TSCA, which requires
that the methods used will not pose an unreasonable risk of injury to health or the environment.
CDFs would be constructed to meet the substantive requirements for remedy implementation,
including TSCA PCB disposal requirements, TSCA chemical waste landfill standards, the CWA
and CAA, and Massachusetts hazardous waste regulations. The conceptual CDF design includes
groundwater, surface water and air emission monitoring during operation, closure and post
closure requirements, and erosion and stormwater drainage controls. Substantive standards of all
applicable TSCA decontamination requirements would be followed.
11
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3.2.1.2 Primary Balancing Criteria
Criteria 3: Long-Term Effectiveness
Dredging and disposal of contaminated sediment above the cleanup levels and effective
disposal of dredged sediment in CDFs would remove a substantial mass of PCBs from the
Harbor. Remediation and disposal of sediments in constructed CDFs would result in significant
and consistent reduction of PCB flux and water column PCB concentrations. These
improvements would be reflected in biota over time. Following dredging and disposal in CDFs,
naturally occurring sedimentation within the Harbor should assist in lowering PCB levels further
over time. Until PCB levels in seafood reach the risk-based site-specific threshold of 0.02 ppm,
the remedy will include institutional controls to minimize ingestion of local PCB-contaminated
seafood.
The effectiveness of disposal in CDFs depends on the design, construction, operation,
and management of the facility. In order to achieve long-term effectiveness, CDFs would
require adequate long-term operation, maintenance, and monitoring. Disposal of sediment
containing PCBs in CDFs is not expected to present long-term risks to human health or the
environment. The concentration of PCBs or other contaminants in any leachate generated is
expected to be minimal. Placement of a cap on the CDF would reduce the potential for leachate
generation due to infiltration of precipitation and surface runoff. Long-term monitoring and
maintenance of the CDF cover and monitoring of the CDF dike would be necessary to assess
leachate migration and contamination concentration.
Criteria 4: Reduction in Mobility. Toxicity, and Volume
CDFs as a disposal alternative do not employ sediment treatment, so no reduction in
toxicity of contaminants would be achieved through treatment. However, disposal of the
contaminated sediment in the CDFs is expected to significantly reduce the potential migration of
PCBs thereby reducing mobility of contaminants. Further, water decanted from the sediment
would reduce the volume of the contaminated sediment to be disposed, and decanted water
would be treated to meet site-specific discharge standards before being discharged back into the
harbor.
Criteria 5: Short-Term Effectiveness
At the time of the OU1 ROD, disposal in CDFs was considered to present minimal short-
term risks to the community because the CDFs were located in commercial/industrial zones.
CDFs were located "near industrial areas to avoid potential impacts of CDF construction and
operation (e.g., truck traffic, noise, air quality) on residential areas." Use of fencing and other
security measures were planned to preclude unauthorized entry and protect the public from direct
contact. However, in the 15 years since the issuance of the OU1 ROD, redevelopment along the
river has included significant repurposing of industrial mill buildings to residential and
commercial properties. Further, the City of New Bedford is in the process of designing a
shoreline "Riverwalk," envisioned as a passive recreational walkway to reconnect the
12
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community with the view-scape and environmental resource that the river represents. Significant
habitat restoration is planned as part of the Riverwalk.
As such, there could be significant short-term impacts to the community to facilitate the
construction of these proposed shoreline facilities, as they are conceptually planned for
construction adjacent to what is now active residential and commercial properties. Further, there
would be additional significant short-term impacts to the community and potential restrictions on
use of adjacent shoreline properties during the transport of the dewatered sediment to the CDF
facility for disposal. However, once capped, CDFs could accommodate passive recreational use.
Workers on-site during remedial activities would use personal protective equipment as
needed to prevent exposure to contaminants. CDF construction and filling operations may pose
some short-term worker risks (e.g., spills, accidents). However, these are mitigated by worker
safety and health programs and the use of proper pollution controls.
The CDF construction and permanent location of the CDF facilities would cause
environmental impacts, as the biota and subtidal resource within the footprint of the CDFs would
be permanently destroyed. However, consistent with ARARs, EPA would mitigate these
impacts.
Design, construction and filling of the CDFs would likely take on the order of 5 or more
years, with interim and then final capping likely adding 1-2 years. Operation, maintenance and
monitoring of the CDFs would need to be performed in perpetuity.
Criteria 6: Implementabilitv
CDFs are considered a demonstrated technology. Experience gained by the construction
of the pilot CDF demonstrated the site-specific application of this technology. However, since
the time of the OU1 ROD, EPA has determined that there are significant technical feasibility
concerns with construction of CDFs at this Site.
CDF D was eliminated under ESD2 as a result of cost and engineering concerns. The
primary constructability concern was the presence of soft, fine-grained sediment, which from a
geotechnical and structural standpoint, would be an unsuitable base or foundation for any
wall/dike design of the CDF. Other engineering challenges citied in ESD2 were managing a
complex, in-water construction and filling project in a busy harbor, dewatering the CDF prior to
filling with filter cake, and controlling air emissions from within the large CDF footprint. Many
of these same challenges would be implementability issues for other CDF locations at the Site.
Constructing shoreline CDFs requires a thorough evaluation of complex engineering and
design considerations, including the geotechnical suitability of the material in the footprint of the
CDF in order to assess structural integrity. The complex design and construction considerations
make CDFs challenging to implement and represent design and construction risks. Long-term
performance of the CDFs would be assessed through a long-term monitoring program.
However, data collected from the pilot CDF do not indicate any movement of contaminants from
the Site.
13
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Site preparation and land acquisition would be the initial activities necessary for the
development of the shoreline disposal sites. Complex legal and real estate issues would need to
be addressed with the adjacent shoreline property owners to facilitate CDF construction.
Due to the size and complexity of this Site, remedy implementation would require
significant coordination of the dredging efforts, material handling activities, and CDFs planning,
design and construction logistics. Coordination between EPA, the Corps, the City of New
Bedford, the Towns of Fairhaven and Acushnet, and the Commonwealth of Massachusetts would
be important.
In addition to these technical, legal, regulatory and real estate implementability concerns,
there may be administrative implementability issues due to changing land uses. Redevelopment
and recreational uses are now planned along the New Bedford Harbor shoreline where CDFs are
conceptually planned. These implementability concerns could impact cleanup costs and
schedule.
All activities and technologies associated with this alternative, including dredging
equipment and land-based heavy construction equipment for construction of CDFs, are readily
available. Vendors and contractors specializing in marine construction can provide the
equipment and personnel to conduct the remediation and construction activities.
Criteria 7: Cost
For the purpose of this FFE, the cost estimate provided is only for the CDF disposal
component of the remedy. The cost of disposal in CDFs has significantly increased since the
time of the OU1 ROD. To develop a conservative cost estimate for the purpose of the FFE, EPA
assumed that one CDF facility would be constructed with a capacity of 145,000 cy to
accommodate the disposal of the 175,000 cy of in situ sediment and capping material. The
present worth cost estimate for construction of the CDF facility, transportation and disposal of
the vegetated sediment and dewatered sediment into the CDF, capping, and O&M is
approximately $56 million. The cost estimate does not include the costs associated with
excavation or dredging and processing of the in situ sediment to produce the sand, dewatered
sediment filter cake, and vegetated sediment for disposal. These elements of the remedy are
already in place and are not being modified and are the same preceding operations for either
disposal alternative. A summary of the cost estimate is included in Table 2. If construction of
two or three CDFs was necessary, the cost estimate would need to be increased. Land
acquisition costs are not included, but could be significant. The costs for constructing CDFs
were derived from past CDF construction experience in similar conditions and costs that were
incurred for the construction of the pilot CDF.
3.2.2 Alternative 2 - Off-Site Transportation and Disposal
See Section 2.1.3 for a description of this alternative. This subsection presents the
individual analysis of the off-site transportation and disposal component, as an element of the
overall remedial approach. A summary of the analysis is presented in Table 3.
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3.2.2.1 Threshold Criteria
Criteria 1: Overall Protection of Human Health and the Environment
Contaminated sediment above cleanup goals that drives the unacceptable risks would be
removed through dredging and excavation and would be permanently isolated in off-site
permitted disposal facilities. Dredging of contaminated sediment and off-site disposal would
effectively reduce the potential for direct contact exposure and limit the source of PCB
contamination in surface water and biota. Exposure pathways would be eliminated or addressed
through the implementation of institutional controls and long-term monitoring to ensure that the
remedy remains protective of human health and the environment.
Management and off-site disposal of dredged material would comply with the
requirements of RCRA, TSCA, and with the Off-Site Rule, which requires that CERCLA wastes
be placed in a facility operating in compliance with RCRA or other applicable Federal or State
requirements. The long-term effectiveness is assured as the material is disposed at a facility that
is permitted to manage and dispose of PCB-contaminated materials and this facility is operated
and maintained to ensure long-term protectiveness under the RCRA and TSCA regulatory
programs.
Criteria 2: Compliance with ARARs
Section XII and Table 8 of the OU1 ROD provided a detailed discussion and listing of
ARARs for the New Bedford Harbor Superfund Site. The ARARs table (Table 8) from the OU1
ROD is reproduced herein as Attachment A. Section IV of ESD2 provides a detailed discussion
of ARARs for off-site disposal; however, no new ARARs were added in ESD2 or the other
ESDs, so the OU1 ROD ARARs Table still serves as the complete listing of ARARs for the
remedy. However, former regulations that incorporated requirements of Executive Orders 11988
(Management of Floodplain) and 11990 (Protection of Wetlands) at 40 CFR Part 6, Appendix A,
as cited in the 1998 ROD, no longer exist. Federal Emergency Management Agency (FEMA)
regulations at 44 CFR § 9, which set forth the policy, procedure and responsibilities to
implement and enforce these Executive Orders, are considered relevant and appropriate.
The goal of the remedy, including the disposal component, is to reduce health risks due to
consumption of PCB-contaminated local seafood, as well as reduce health risks due to contact
with or incidental ingestion of PCB-contaminated shoreline sediment and improve the severely
degraded ecosystem. This will be accomplished by dredging and containing PCB-contaminated
sediment in order to lower PCB concentrations in sediment and in the water column. The State
fishing ban will continue, along with other institutional controls, to minimize consumption of
local seafood.
Consistent with the 1998 ROD, PCB-contaminated sediment above EPA's clean up levels
must be handled and disposed of in accordance with 40 CFR 761.61(c) of TSCA, which requires
that the methods used will not pose an unreasonable risk of injury to health or the environment.
15
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Off-site disposal would meet any applicable requirements, such as TSCA PCB disposal
requirements.
3.2.2.2 Primary Balancing Criteria
Criteria 3: Long-Term Effectiveness
Dredging and off-site disposal of contaminated sediment above the cleanup levels would
remove a substantial mass of PCBs from the Harbor. Remediation and off-site disposal at a
permitted facility would result in significant and consistent reduction of PCB flux and water
column PCB concentrations. These improvements would be reflected in biota over time.
Following dredging and off-site disposal of contaminated sediments, naturally occurring
sedimentation within the Harbor should assist in lowering PCB levels further over time. Until
PCB levels in seafood reach the risk-based site-specific threshold of 0.02 ppm, the remedy will
include institutional controls to minimize ingestion of local PCB-contaminated seafood.
Off-site transportation and disposal at a TSCA-permitted facility is an effective disposal
alternative in the long-term. Off-site transportation and disposal of sand and dewatered sediment
filter cake are currently being implemented as part of the ongoing cleanup efforts. The
infrastructure and equipment is in place and operational. The long-term effectiveness is assured
as the material is disposed at a facility that is permitted to manage and dispose of PCB-
contaminated materials, and this facility is operated and maintained to ensure long-term
protectiveness under the RCRA and TSCA regulatory programs.
Criteria 4: Reduction in Mobility. Toxicity, and Volume
Since this disposal alternative does not employ sediment treatment, no reduction in
toxicity of contaminants would be achieved through treatment. However, disposal of the
contaminated sediment at permitted off-site disposal facilities is expected to reduce the potential
migration of PCBs thereby reducing mobility of contaminants. Further, water decanted from the
sediment would reduce the volume of sediment for disposal, and water would be treated to meet
site-specific discharge standards before being discharged back into the harbor.
Criteria 5: Short-Term Effectiveness
Transport of contaminated sediment to off-site disposal facilities could pose some short-
term impacts to the community from increased truck traffic, accidents or spills in the community
between the Area C Sawyer Street facility or Area D and the highway. Rail transport generally
presents fewer risks than road transport. This disposal alternative would utilize transportation by
rail of the dewatered sediment filter cake to the maximum extent practicable, thereby
significantly reducing any short-term impacts.
Workers on-site during remedial activities would use personal protective equipment as
needed to prevent exposure to contaminants. Loading operations may pose some short-term
worker risks (e.g., spills, accidents). However, these are mitigated by worker safety and health
programs and the use of proper pollution controls.
16
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Off-site transportation and disposal is currently ongoing for disposal of sand and
dewatered sediment filter cake for approximately 425,000 cy of in situ contaminated sediment in
accordance with the current OU1 remedy, and would continue with this off-site disposal
alternative for the approximately 175,000 cy of in situ contaminated sediment currently slated to
be disposed of in CDFs A, B and modified-C. Under this disposal alternative, there would be no
delay to cleanup operations, as the facilities and equipment to transport and dispose of off-site
sand and dewatered sediment filter cake is already in place and operational.
Criteria 6: Implementabilitv
Off-site transportation and disposal is readily implementable, as it is currently being
implemented as part of the ongoing cleanup efforts. At the time of the 1990 FS, off-site disposal
was eliminated from the detailed analysis of alternatives because there was not adequate capacity
at permitted facilities to accommodate the dredged material slated for disposal. However,
permitted capacity has been approved since the time of the FS, and there is now adequate
capacity at existing TSCA-permitted disposal facilities to accommodate the potential additional
PCB-contaminated sediments.
Due to the size and complexity of this Site, remedy implementation would require
significant coordination of the dredging efforts, material handling activities, and off-site
transportation logistics. Coordination between EPA, the Corps, the City of New Bedford, the
Towns of Fairhaven and Acushnet, the Commonwealth of Massachusetts would be important.
All activities and technologies associated with off-site transportation equipment to
accommodate truck- or rail-transport are readily available and in place. Vendors and contractors
specializing in marine construction and off-site transportation can provide the equipment and
personnel to conduct the transportation and disposal operations.
Criteria 7: Cost
The estimated present worth cost for off-site transportation and disposal of approximately
137,000 cy of stabilized vegetated sediment, sand and dewatered sediment filter cake is
approximately $33 million. The cost estimates does not include the costs associated with
excavation of vegetated sediment or dredging and processing of the in situ subtidal sediment to
produce the sand and dewatered sediment filter cake for disposal. These elements of the remedy
are already in place and are not being modified and are the same preceding operations for either
disposal alternative. A summary of the cost estimate is provided in Table 4. Since the costs
supporting the off-site transportation and disposal cost estimates are based on actual current
costs, this cost estimate is considered more accurate than the -30 percent to +50 percent accuracy
range for feasibility study cost estimates.
3.3 Comparative Analysis of Disposal Alternatives
As detailed in Section 1.4, the purpose of this FFE is to offer a "focused" evaluation of
disposal of contaminated sediments in CDFs versus off-site disposal. Therefore, the NCP's nine
17
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evaluation criteria are discussed below in the comparative analysis for CDFs and off-site
transportation and disposal, as elements of the overall remedial approach. The analysis
compares disposal of the approximately 175,000 cy of in situ contaminated sediment in the
CDFs under the selected remedial approach versus off-site transportation and disposal of this
volume of contaminated sediment.
Table 5 presents a summary of the comparative analysis.
3.3.1 Threshold Criteria
Disposal via CDFs or off-site disposal are both equally protective of human health and
the environment, because under either disposal scenario the contaminated sediment driving the
unacceptable risks would be removed and exposure pathways would be eliminated or controlled.
In addition, both disposal alternatives are equally compliant with ARARs already included in the
OU1 ROD and ESD2. As such, both disposal in CDFs and off-site disposal meet the two
threshold criteria. Further, construction of CDFs A, B and modified-C would require filling of
on the order of 10 acres of intertidal and subtidal areas. Off-site disposal would eliminate this
filling activity, but would require dredging in the areas where the CDFs were conceptually
planned. In accordance with Section 404 of the Clean Water Act and 40 CFR Part 230, EPA
would need to determine that off-site disposal for the approximately 175,000 cubic yards of in
situ PCB-contaminated sediment previously slated for disposal in CDFs A, B and modified-C
would be the least environmentally damaging practicable alternative for addressing these PCB-
contaminated sediments at the Site with respect to potential impacts to federal jurisdictional
wetlands and aquatic habitats.
3.3.2 Primary Balancing Criteria
3.3.2.1 Effectiveness
Regardless of whether disposal is via CDFs or off-site, the overall remedy relies on
institutional controls to minimize ingestion of local PCB-contaminated seafood.
The effectiveness of disposal in CDFs depends on the design, construction, operation,
and management of the facility. Institutional controls would be required for CDF properties to
ensure the integrity of the caps over time and restrict property uses that could damage the caps
and structures. Effectiveness of off-site transportation and disposal at a TSCA-permitted facility
is assured as the material is disposed at a facility that is permitted to manage and dispose of
PCB-contaminated materials.
There would be significant short-term impacts to facilitate the construction of CDFs, as
they are conceptually planned adjacent to now active residential and commercial properties. For
off-site disposal, road transport by truck can result in short-term impacts to the community. Rail
transport generally presents fewer risks than road transport. The off-site disposal alternative
would utilize transportation by rail of the dewatered sediment filter cake to the maximum extent
practicable, thereby significantly reducing any short-term impacts.
18
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Under either disposal alternative, workers would use personal protective equipment or
pollution controls would be installed as needed to prevent worker exposure to workplace
hazards.
Under either disposal alternative, there would be short-term impacts to the environment
from dredging operations. However, the CDF construction and permanent location of the CDF
facilities would cause further environmental impacts, as the biota and intertidal and subtidal
resource within the footprint of the CDFs would be permanently destroyed. However, any
wetland habitat impacted by the remedial efforts would be restored or mitigated. Off-site
transport and disposal would result in minimal short term and sustained environmental impacts
as compared to CDFs.
Design, construction and filling of the CDFs would likely take on the order of 5 or more
years, with interim and then final capping likely adding another 1-2 years. Operation,
maintenance and monitoring of the CDFs would need to be performed in perpetuity. Off-site
transportation and disposal is currently ongoing for disposal of sand and dewatered sediment
filter cake for approximately 425,000 cy of in situ contaminated sediment in accordance with the
current OU1 remedy, and would continue with this off-site disposal alternative for the
approximately 175,000 cy of in situ contaminated sediment currently slated to be disposed of in
CDFs A, B and modified-C. There would be no delay to cleanup operations for off-site disposal.
3.3.2.2 Implementability
Dredging, desanding, dewatering, and water treatment operations are common to either
disposal alternative and are readily implementable operations.
CDFs are considered a demonstrated technology. However, there are significant
technical feasibility concerns with construction of CDFs at this Site. Constructing shoreline
facilities requires a thorough evaluation of complex engineering and design considerations,
including the geotechnical suitability of the material in the footprint of the CDF in order to assess
structural integrity. Complex legal and real estate issues would need to be addressed with the
adjacent shoreline properties to facilitate CDF construction. Changes in land use since the
issuance of the OU1 ROD along the New Bedford Harbor shoreline where CDFs are
conceptually planned would make the administrative feasibility of constructing CDFs
challenging. Disposal in CDFs has short-term effectiveness impacts and complex engineering
and administrative implementability issues.
Off-site transportation and disposal is readily implementable. There is adequate capacity
at existing TSCA-permitted disposal facilities to accommodate the additional PCB-contaminated
sediment. Since this disposal alternative is currently being used for the approximately 425,000
cy of in situ contaminated sediment, there are no significant technical or administrative
implementability issues expected.
All activities and technologies associated with either disposal alternative are readily
available.
19
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3.3.2.3 Cost
The cost estimates discussed herein do not include the costs associated with excavation or
dredging and processing of the in situ sediment to produce the sand, dewatered sediment filter
cake, and vegetated sediment for disposal. These elements of the remedy are already in place
and are not being modified and are the same preceding operations for either disposal alternative.
The present worth cost of disposal in CDFs is estimated as $56 million. Whereas the
present worth cost of disposal via off-site transportation and disposal is estimated as $33 million.
Disposal via off-site transportation and disposal at a TSCA-permitted facility would save
approximately $23 million over CDF construction and disposal in shoreline CDFs. The actual
cost savings is likely greater since the CDF cost estimate was conservatively calculated assuming
one CDF when two or three CDFs could be necessary, and since the cost estimate did not include
land acquisition costs.
3.3.3 Modifying Criteria
Following issuance of this FFE, if EPA proposes to change the disposal of the
approximately 175,000 cy of in situ PCB-contaminated sediment from CDFs A, B and modified-
C to off-site disposal, then EPA intends to issue a draft ESD to propose such change. The basis
for the modification of the OU1 remedy would include the analysis performed in this FFE. EPA
will accept comments on the draft ESD during a formal public comment period.
In its final selection of a disposal alternative, EPA will consider comments the State may
provide on the draft ESD and ultimately whether the State concurs with or opposes the remedy
modification proposed. State comments or other information received from the State may result
in the choice of an alternative other than the preferred alternative.
In the Final ESD, EPA will also respond to comments it has received from the public on
the draft ESD. EPA may modify or choose an alternative other than the preferred alternative
based on comments or other information it receives from the public.
4.0 References
Ebasco Services Incorporated, 1990. Draft Final Feasibility Study of Remedial Alternatives for
the Estuary and Lower Harbor/Bay, New Bedford, Massachusetts. Volumes I, II and III. August
1990.
Ebasco Services Incorporated, 1992. Draft Final Supplemental Feasibility Study Evaluation for
Upper Buzzards Bay, New Bedford Harbor RI/FS, New Bedford, Massachusetts. May 1992.
Foster Wheeler Environmental Corp., 2003. Volumes, Area and Properties of Sediment by
Management Units, New Bedford Harbor Superfund Site, New Bedford, MA. June 2003;
Revision 2 September 2003.
Jacobs Engineering Group, 2014. Dredge Work Plan Addendum No. 10, New Bedford Harbor
Remedial Action, New Bedford Harbor Superfund Site. June 2014.
20
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Jacobs Engineering Group, 2014. 2013 Dredge Season Data Submittal, New Bedford Harbor
Superfund Site. December 2014.
Jacobs Engineering Group, 2015. New Bedford Harbor Superfund Site Focused Feasibility
Evaluation Cost Estimate Summary. March 2015.
USEPA, 1998. Record of Decision for the Upper and Lower Harbor Operable Unit, New
Bedford Harbor Superfund Site, New Bedford, MA. September 1998.
USEPA, 1988b. Guidance for Conducting Remedial Investigations and Feasibility Studies Under
CERCLA, Interim Final. OSWER Directive 9355.3-01. October 1988.
USEPA, 1999. A Guide to Preparing Superfund Proposed Plans, Records of Decision, and Other
Remedy Selection Decision Documents. July 1999.
USEPA, 2001. Explanation of Significant Differences for the Upper and Lower Harbor
Operable Unit, New Bedford Harbor Superfund Site, New Bedford, MA. September 2001.
USEPA, 2002. Explanation of Significant Differences for the Upper and Lower Harbor
Operable Unit, New Bedford Harbor Superfund Site, New Bedford, MA. August 2002.
USEPA, 2010. Third Explanation of Significant Differences, New Bedford Harbor Superfund
Site Operable Unit #1, New Bedford, MA. March 2010.
USEPA, 2011. Forth Explanation of Significant Differences for Use of a Lower Harbor CAD
Cell (LHCC), New Bedford Harbor Superfund Site Operable Unit #1, New Bedford, MA.
March 2011.
USEPA, 2013. Supplemental Consent Decree with Defendant AVX Corporation. September
2013.
USEPA, 2014. Memorandum Prepared by Ginny Lombardo, EPA, to New Bedford Harbor OU1
RD/RA File Regarding Revisions to Conceptual Plan for Design of CDF C. January 2014.
21
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Figures
-------
Fairhaven
Mattapoisett
Ufcstj
.fcland'
CMcls
P:drt.
INUju:
fc in
Hdeetsoris
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Outer Harbor
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Figure 1
Site Location Map
New Bedford Harbor Superfund Site
New Bedford, MA
-------
Management Units
NSTAR Cabte Crossing
1:1C,8D0
JACOBS
Areas Dredged through
2013
New Be*?ari haroot &.®e«fira
Ste
Figure 2
Leaefia
Areas Dredged through 2013
¦i t9&3-1935 2005 |
I 15&4-199S I
2C01
2002-2003
2C03
2COi
-------
nifiTfS
Eormer.Aerpyojc
^¦Facility , H
WManomet Street
~ ¦ |: | i
y. Booster Pump.
Pipeline
Length (ft)
From Dredge Area 0 to Manomet Street
From Manomet Street to Desanding
From Dredge Area L, Dredge Area P, &
Dredge Area R to Manomet
Cog qeshal l[5tr.eetlBri"dqe.
Ieaend
2014 Dredge Area O
Management Units
2014 Dredge Area L
2014 Dredge Area P
2014 Dredge Area R
OATE: OV17/20I
~
Pipeline from Dredge Area O
to Manomet Street Booster Pump
Pipeline from Dredge Areas L, P, & R
to Manomet Street Booster Pump
Pipeline to Desanding Building
Pipeline from Area C to Area D
Manomet Street Booster Pump
600
JACOBS
Dredge Areas Scheduled for
2014 Dredge Season
New Bedford Harbor Superfund Site
Figure 3
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Figure 4: Conceptual Locations of CDFs A, B and C
i . ¦
Coffin
Sav^er
Coggeshall Street
Figure 21a - Conceptual locations of upper harbor CDFs A, B and C
New Bedford Harbor Superfund Site, ROD 2
_ *_ - _ 1. * .1 « i _ i t |
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Figure 5: Conceptual Location of CDF D
Sheet pile wall
CDF D
New Bedford Harbor
'*v
>_v
400
feet
Figure 21b - Concep.ua! local,on of the lower harbor CDF D
New Bedford Harbor Superfimd Site, ROD L
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Tables
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Table 1: Detailed Analysis of Alternative 1 - Confined Disposal Facilities (CDFs)
Evaluation Criteria
Overall Protection of Human Health and the Environment
Human Health and
Environment Protection
Contaminated sediment above cleanup goals that drive unacceptable
risks would be removed through dredging and permanently isolated in
CDFs. Dredging of contaminated sediment and disposal in shoreline
CDFs would effectively reduce the potential for direct contact
exposure and limit the source of PCB contamination in surface water
and biota. Exposure pathways would be eliminated or addressed
through the implementation of institutional controls and long-term
monitoring to ensure that the remedy remains protective of human
health and the environment.
Compliance with ARARs
Chemical-Specific
The goal of the remedy, including the disposal component, is to reduce
health risks due to consumption of PCB-contaminated local seafood,
as well as reduce health risks due to contact with or incidental
ingestion of PCB-contaminated shoreline sediment and improve the
severely degraded ecosystem. The State fishing ban will continue,
along with other institutional controls, to minimize consumption of
local seafood.
Location-Specific
CDFs would be designed and constructed to ensure that wetlands, fish
and wildlife habitat related ARARs and ARARs for the preservation of
historical and archeological data were met and to protect against storm
damage and control flooding. The State fishing ban will continue,
along with other institutional controls, to minimize consumption of
local seafood.
Action-Specific
CDFs would be designed to meet the substantive requirements for
remedy implementation, including TSCA PCB disposal requirements,
TSCA chemical waste landfill standards, the CWA and CAA, and
Massachusetts hazardous waste regulations. The conceptual CDF
design includes groundwater, surface water and air emission
monitoring during operation, closure and post closure, and erosion and
stormwater drainage controls. Substantive standards of all applicable
TSCA decontamination requirements would be followed.
Long-Term Effectiveness and Permanence
Magnitude of Residual
Risk Remaining
Dredging of contaminated sediment above the cleanup levels and
effective disposal of dredged sediment in CDFs would remove a
substantial mass of PCBs from the Harbor and result in significant and
consistent reduction of PCB flux and water column PCB
concentrations. These improvements would be reflected in biota over
time. Naturally occurring sedimentation within the harbor should
assist in lowering PCB levels further over time. Until PCB levels in
seafood reach the risk-based site-specific threshold of 0.02 ppm, the
remedy will include institutional controls to minimize ingestion of
local PCB-contaminated seafood.
Adequacy and
Reliability of Controls
The effectiveness of disposal in CDFs depends on the design,
construction, operation, and management of the facility. For long-term
effectiveness, CDFs would require adequate long-term operation,
maintenance, and monitoring. Institutional controls would be required
Table 1
Page 1
-------
for CDF properties to ensure the integrity of the caps over time and
restrict property uses that could damage the caps and structures.
Reduction of Toxicity, Mobility or Volume
Treatment Process Used
and Materials Treated
CDFs as a disposal alternative does not employ sediment treatment.
However, disposal of the contaminated sediment in the CDFs is
expected to reduce the potential migration of PCBs thereby reducing
mobility of contaminants. Water decanted from the sediment is treated
to meet discharge standards.
Amount Destroyed or
Treated
Since this alternative does not employ sediment treatment, no
reduction in mobility, toxicity, or volume of contaminants would be
achieved through treatment.
Degree of Expected
Reductions of Toxicity,
Mobility, or Volume
through Treatment
Effluent discharged to the river from the water treatment processes
will meet discharge criteria.
Degree to Which
Treatment is Irreversible
Water treatment processes are irreversible.
Type and Quantity of
Residuals Remaining
after Treatment
PCB residuals removed during water treatment would be disposed
consistent with ROD requirements.
Short-Term Effectiveness
Protection of Community
During Remedial Action
There could be significant short-term impacts to the community to
facilitate the construction of these proposed shoreline facilities, as they
are conceptually planned for construction adjacent to what is now
active residential and commercial properties. Further, there would be
additional significant short-term impacts to the community and
potential restrictions on use of adjacent shoreline properties during the
transport of the dewatered sediment to the CDF facility for disposal.
Protection of Workers
During Remedial Action
Workers on-site during remedial activities would use personal
protective equipment as needed to prevent exposure to contaminants.
Environmental Impacts
The CDF construction and permanent location of the CDF facilities
would cause environmental impacts, as the biota and subtidal resource
within the footprint of the CDFs would be permanently destroyed.
However, consistent with ARARs, EPA would mitigate these impacts.
Time Until Remedial
Action Objectives are
Achieved
Design, construction and filling of the CDFs would likely take on the
order of 5 or more years, with interim and then final capping likely
adding another 1-2 years. Operation, maintenance and monitoring of
the CDFs would need to be performed in perpetuity.
Implement ability
Technical Feasibility
CDFs are considered a demonstrated technology. Experience gained
by the construction of the pilot CDF demonstrated the site-specific
application of this technology. However, since the time of the OU1
ROD, EPA has determined that there are significant technical
feasibility concerns with construction of CDFs at this Site.
Constructing shoreline facilities requires a thorough evaluation of
complex engineering and design considerations including the
geotechnical suitability of the material in the footprint of the CDF in
order to assess structural integrity. Complex legal and real estate
issues would need to be addressed with the adjacent shoreline
properties to facilitate CDF construction.
Table 1
Page 2
-------
Administrative
Feasibility
Redevelopment and recreational uses now planned along the New
Bedford Harbor shoreline where CDFs are conceptually planned will
make the administrative feasibility of planning and constructing CDFs
challenging. Coordination between EPA, the Corps, the City of New
Bedford, the Towns of Fairhaven and Acushnet, and the
Commonwealth of Massachusetts would be important.
Availability of Services
and Materials
All activities and technologies associated with this alternative,
including dredging equipment and land-based heavy construction
equipment for construction of CDFs, are readily available. Vendors
and contractors specializing in marine construction can provide the
equipment and personnel to conduct the remediation and construction
activities.
Cost
Estimated Capital Cost
(Present Worth)
$54,672,973
Estimated O&M Costs
(Present Worth)
$1,184,817
Total Estimated Costs
$55,857,790
Table 1
Page 3
-------
Table 2: Summary of the Cost of CDF Disposal Alternative
Item
Cost Estimate
Build CDF
CDF Construction
$42,527,416
Stormwater Management
$153,482
Monitoring Wells
$60,904
Subtotal
$42,741,802
Fill CDF
Transfer Materials
$10,709,631
Truck Decontamination
$279,946
Air Monitoring
$167,813
Stormwater Management
$501,199
Subtotal
$11,658,589
Cap CDF
Interim Cap
$701,614
Final Cap
$3,642,239
Subtotal
$4,343,853
Total Capital Cost
$58,744,244
Total Capital Cost
(Present Worth)
$54,672,973
CDF O&M
GW Monitoring Annual
$47,860
Cap Maintenance Annual
$65,405
Total Annual Cost
$113,265
30 Years O&M
$1,235,280
Total O&M
(Present Worth)
$1,184,817
Total Present Worth
Cost
$55,857,790
Table 2
Page 1
-------
Table 3: Detailed Analysis of Alternative 2 - Off-Site Transportation and
Disposal
Evaluation Criteria
Overall Protection of Human Health and the Environment
Human Health and
Environment Protection
Contaminated sediment above cleanup goals that drive unacceptable
risks would be removed through dredging and permanently isolated at
off-site permitted facilities. Dredging of contaminated sediment and
off-site disposal would effectively reduce the potential for direct
contact exposure and limit the source of PCB contamination in surface
water and biota. Exposure pathways would be eliminated or addressed
through the implementation of institutional controls and long-term
monitoring to ensure that the remedy remains protective of human
health and the environment.
Compliance with ARARs
Chemical-Specific
The goal of the remedy, including the disposal component, is to reduce
health risks due to consumption of PCB-contaminated local seafood,
as well as reduce health risks due to contact with or incidental
ingestion of PCB-contaminated shoreline sediment and improve the
severely degraded ecosystem. The State fishing ban will continue,
along with other institutional controls, to minimize consumption of
local seafood.
Location-Specific
The State fishing ban will continue, along with other institutional
controls, to minimize consumption of local seafood.
Action-Specific
PCB-contaminated sediment above EPA's clean up levels would be
handled and disposed of in accordance with 40 CFR 761.61(c) of
TSCA, which requires that the methods used will not pose an
unreasonable risk of injury to health or the environment. Off-site
disposal would meet any applicable requirements, such as TSCA PCB
disposal requirements.
Long-Term Effectiveness and Permanence
Magnitude of Residual
Risk Remaining
Dredging of contaminated sediment above the cleanup levels and
effective off-site disposal of dredged sediment would remove a
substantial mass of PCBs from the Harbor and would result in
significant and consistent reduction of PCB flux and water column
PCB concentrations. These improvements would be reflected in biota
over time. Naturally occurring sedimentation within the harbor should
assist in lowering PCB levels further over time. Until PCB levels in
seafood reach the risk-based site-specific threshold of 0.02 ppm, the
remedy will include institutional controls to minimize ingestion of
local PCB-contaminated seafood.
Adequacy and
Reliability of Controls
Off-site transportation and disposal at a TSCA-permitted facility is an
effective disposal alternative in the long-term. Off-site transportation
and disposal is currently being implemented as part of the ongoing
cleanup efforts. The long-term effectiveness is assured as the material
is disposed at a facility that is permitted to manage and dispose of
PCB-contaminated materials and this facility is operated and
maintained to ensure long-term protectiveness under the RCRA and
TSCA regulatory program.
Table 3
Page 1
-------
Reduction of Toxicity, Mobility or Volume
Treatment Process Used
and Materials Treated
The off-site disposal alternative does not employ sediment treatment.
However, disposal of the contaminated sediment at permitted off-site
disposal facilities is expected to reduce the potential migration of
PCBs thereby reducing mobility of contaminants. Water decanted
from the sediment is treated to meet discharge standards.
Amount Destroyed or
Treated
Since this alternative does not employ sediment treatment, no
reduction in mobility, toxicity, or volume of contaminants would be
achieved through treatment.
Degree of Expected
Reductions of Toxicity,
Mobility, or Volume
through Treatment
Effluent discharged to the river from the water treatment processes
will meet discharge criteria.
Degree to Which
Treatment is Irreversible
Water treatment processes are irreversible.
Type and Quantity of
Residuals Remaining
after Treatment
PCB residuals removed during water treatment would be disposed
consistent with ROD requirements.
Short-Term Effectiveness
Protection of Community
During Remedial Action
Although transportation by truck can result in short-term impacts to
the community, the OU1 remedy provides for transportation by rail of
the dewatered sediment significantly reducing any short-term impacts.
Protection of Workers
During Remedial Action
Workers on-site during remedial activities would use personal
protective equipment as needed to prevent exposure to contaminants.
Environmental Impacts
Off-site transport and disposal would result in minimal sustained
environmental impacts.
Time Until Remedial
Action Objectives are
Achieved
Off-site transportation and disposal is currently ongoing for disposal
of sand and dewatered sediment filter cake and would continue with
this alternative. There would be no delay to cleanup operations.
Implement ability
Technical Feasibility
Off-site transportation and disposal is readily implementable, as it is
currently being implemented as part of the ongoing cleanup efforts.
Although at the time of the 1990 FS, off-site disposal was eliminated
from the detailed analysis of alternatives because there was not
adequate capacity at permitted facilities to accommodate the dredged
material slated for disposal, there is now adequate capacity at existing
TSCA-permitted disposal facilities to accommodate the potential
additional PCB-contaminated sediments.
Administrative
Feasibility
Coordination between EPA, the Corps, the City of New Bedford, the
Towns of Fairhaven and Acushnet, the Commonwealth of
Massachusetts would be important.
Availability of Services
and Materials
All activities and technologies associated with this alternative,
including dredging equipment and off-site transportation equipment to
accommodate truck- or rail-transport, are readily available. Vendors
and contractors specializing in marine construction and off-site
transportation can provide the equipment and personnel to conduct the
remediation, transportation and disposal operations.
Table 3
Page 2
-------
Cost
Estimated Capital Cost
$33,008,084
(Present Worth)
Estimated O&M Costs
$0
(Present Worth)
Total Estimated Costs
$33,008,084
Table 3
Page 3
-------
Table 4: Summary of the Cost for Off-Site Transportation and Disposal
Item
Estimated Quantity
(CYs of Material for
Transport & Disposal)
Cost Estimate
Project Year 1
Filter Cake
34,925
$8,570,176
Sand
6,350
$1,000,444
Vegetated Material
24,000
$7,222,103
Project Year 2
Filter Cake
34,925
$8,862,341
Sand
6,350
$1,035,858
Vegetated Material
24,000
$7,448,976
Total Cost
$34,139,898
Total Present Worth
Cost
$33,008,084
Table 4
Page 1
-------
Table 5: Comparative Analysis of Alternatives
Assessment Factors
Alternative 1 - CDFs
Alternative 3 - Off-site Disposal
Overall Protection of Human
Health and the Environment
Protection of human health and the environment is
achieved by a combination of remedial action and
institutional controls. Exposure pathways will be
eliminated or addressed through implementation of
institutional controls and long-term monitoring to
ensure that the remedy remains protective of
human health and the environment.
Same as Alternative 1.
Compliance with ARARs
All ARARs will be met.
Same as Alternative 1.
Long-Term Effectiveness and
Permanence
- Magnitude of Residual
Risk Remaining
- Adequacy and
Reliability of
Controls
Until PCB levels in seafood reach the risk-based
site-specific threshold of 0.02 ppm, the remedy will
include institutional controls to minimize ingestion
of local PCB-contaminated seafood. The
effectiveness of disposal in CDFs depends on the
design, construction, operation and management of
the facility. Institutional controls would be required
for CDF properties to ensure the integrity of the
caps over time and restrict property uses that could
damage the caps and structures.
Until PCB levels in seafood reach the risk-based
site-specific threshold of 0.02 ppm, the remedy will
include institutional controls to minimize ingestion
of local PCB-contaminated seafood. Off-site
transportation and disposal at a TSCA-permitted
facility is an effective disposal alternative in the
long-term. The long-term effectiveness is assured as
the material is disposed at a facility that is permitted
to manage and dispose of PCB-contaminated
materials.
Reduction of Toxicity,
Mobility or Volume
Since this alternative does not employ sediment
treatment, no reduction in mobility, toxicity, or
volume of contaminants would be achieved
through treatment. However, disposal of the
contaminated sediment in the CDFs is expected to
reduce the potential migration of PCBs. Water
decanted from the sediment is treated to meet
discharge standards.
Since this alternative does not employ sediment
treatment, no reduction in mobility, toxicity, or
volume of contaminants would be achieved through
treatment. However, disposal of the contaminated
sediment at permitted off-site disposal facilities is
expected to reduce the potential migration of PCBs.
Water decanted from the sediment is treated to meet
discharge standards.
Table 5
Page 1
-------
Short-Term Effectiveness
- Protection of
Community During
Remedial Action
- Protection of Workers
During Remedial
Action
- Environmental
Impacts
- Time Until Remedial
Action Objectives are
Achieved
There could be significant short-term impacts to
facilitate the construction of CDFs, as they are
conceptually planned adjacent to active residential
and commercial properties. Workers would use
personal protective equipment as needed to prevent
exposure to contaminants. The CDF construction
and permanent location of the CDF facilities would
cause environmental impacts, as the biota within
the footprint of the CDFs would be permanently
destroyed. Design, construction and filling of the
CDFs would likely take on the order of 5 or more
years, with interim and then final capping likely
adding another 1-2 years. Operation, maintenance
and monitoring of the CDFs would need to be
performed in perpetuity.
Although transportation by truck can result in short-
term impacts to the community, the OU1 remedy
provides for transportation by rail of the dewatered
sediment significantly reducing any short-term
impacts. Workers would use personal protective
equipment as needed to prevent exposure to
contaminants. Off-site transport and disposal would
result in minimal sustained environmental impacts.
Off-site transportation and disposal is currently
ongoing and would continue with this alternative.
There would be no delay to cleanup operations.
Implement ability
- Technical Feasibility
- Administrative
Feasibility
- Availability of
Services and
Materials
CDFs are considered a demonstrated technology.
However, there are significant technical feasibility
concerns with construction of CDFs at this Site.
Constructing shoreline facilities requires a
thorough evaluation of complex engineering and
design considerations. Complex legal and real
estate issues would need to be addressed with the
adjacent shoreline properties to facilitate CDF
construction. Redevelopment and recreational uses
now planned along the New Bedford Harbor
shoreline where CDFs are conceptually planned
will make the administrative feasibility of planning
and constructing CDFs challenging. All activities
and technologies associated with this alternative,
including dredging equipment and land-based
heavy construction equipment for construction of
CDFs, are readily available.
Off-site transportation and disposal is readily
implementable. There is adequate capacity at
existing TSCA-permitted disposal facilities to
accommodate the potential additional PCB-
contaminated sediments. All activities and
technologies associated with this alternative,
including dredging equipment and off-site
transportation equipment to accommodate truck- or
rail-transport, are readily available.
Cost (Present Worth)
$55,857,790
$33,008,084
Table 5
Page 2
-------
Attachment A
1998 ROD ARARs Table
Note: In the attached reproduced tables from the 1998 ROD, the table column titles are unreadable. For Chemical-
Specific ARARs, the 5 Column titles in order are: Requirement; Citation; Status; Requirement Synopsis; and,
Actions to be Taken to Attain ARARs. For Location-Specific ARARs, the 5 Column titles in order are:
Requirement; Citation; Status; Requirement Synopsis; and, Actions to be Taken to Attain ARARs. For Action-
Specific ARARs, the 5 Column titles in order are: Medium/Authority; Citation; Status; Requirement Synopsis; and,
Actions to be Taken to Attain ARARs.
-------
Table 8 - New Bedford Harbor Upper and Lower Harbor ROD - Chemical Specific ARARS
S rt4tn)
jCanccr Slope Factocs (CSF*)
| Reference Bass (RfBsJ
iFCBs: Cmcer Dose - RespaAM
) AHamat and Application to
Environment^ Mixtures
¦ Peieial foot, Diuc«nd Cosmetic
iAm
Ohm Water Art (CWA), Wifer
Quality Cfllirt*
Surface Water Quality Sun&rtfc
EPA/66WP-
W1F,
SegEmbe.-.
To Be CansMercd
To Is Considered
I'M
cm Mm I
33 USCitlil,
I lilt
laiMGOT,
I3M CMR*.
mm
W)
flKse ac |oidaBi:e value* ««4 to «va»u«t» the potential
caretatipfle hazard cauted by exjMCum lo ooatamiMm
TV** ire mfiiasi viltiei used to evaluate the potential
mm-carefnopaic tuawl taoal ky expense to
oontMaiiwo.
Guidaace » » Agency's (etuanntcm of the
estreiaofinidiy efPCfti. It includes Kvised slope
ftwtots for PCSs basest
-------
Table 8 - New Bedford Harbor Upper and Lower Harbor ROD - Location Specific ARARs
m
BoodpUm Maataaemet* - Executive
Order USU&
40 CfR fm.
#, Appendix
Applicable
Fedtttl agencies are repifei to «A*e the htk of flood
loss, wtaimtas impart of Bswfc, and restore aa»d jweree
the utotil and beneficial waines of ioodphtinj.
lie remedy will occar wldiia ite 1Q0-ynr coaatal fcodpiwt is rtte* t> no practical
•oceptaMt alternative location, TheCDFs will he constructed to minimize potential
hium to the floo^pl ain ami will be built in ««fdaaee with flood protectiea meaauitg.,
Wetland Pwmuloa -EmmNw
Order 11990
40 CFR Part
¦ 6, Appendix
A
Afpi-snMc
Federal agencies are required to atoii adveracly
impacting walamb whatever possible, minimize
wetland aefflucdoit *4 pratnt the *atwc of wetlanda.
Tta is Si* «m practical ^tentative for weMMngflhe Hartor. The %eney will
rbc deanueitai, loss and degntiatfoa of wetlands *> mach » pe*siblc tswn She
nd localatn at MtniiiiiMUitBi aedlmcnt. When ever pusifele, higher turpi
fcwls umitiia wttlm*» minimise destruction. Replanting of toslgai
»1I occur.
I« use Part
fish and Wildlife CwjfdteaBon Art « CTR?":
Applieabte
Requirei eoiBufataoo Willi uppfOOfiale agencies to ; . ———jja,
protect fall rat) wildlife when feaeral actions mas riter l
waterways. M«atde«^o|} measures to prevent and j™
mitigate potential less»«he nMaunum extern potslMe. I
HgSKis will be eonsatttd prior to impawn at»n tu ftnd ways » mtftimiw
eflfeas m fall tod wildlife torn harbor iwJgtaf and 6ora conHMCtiott and
a of CDFf-
E.-Miangffsd Specks Art
16 USC Part
[S3] et. «eq.;
40 CFR 6.
| JOJflt)
Requites mnsufalion. with sppsspf L«tt agencies if a
Applicable tiaeaMaul or listed »peci« or thetr habitat aaay be
iffiwted by » Cedent actios
j EPA will omisuU urtih ippof lift* agencies to consider mitigation meaaiwi for nansdial
> M||«Hec affect lag the ideaKtOed fesiliig. pound* fer roseate (cm,
Preservation of Historical and
Aistefttegkal Diet Aetof 197#
Cojetal Zone M*s»gen»e«iil Act
MaMacfciuetts " *
Wetlands Protection Act
116 use 469
leLseq..
L
116 O'SC Pats
11451 cE scq.
Applicable
AppiMe
Re^aiies resBvaiag and ptaarmt sipifissnt fcislwfcM
ftr»«lKDlo|Jea3 duawttenaich diu is ltM»s«ne4 by »
iakial ietksa or federally Ikease-i amtoa whitli ifcfs
amy larain wbeic ssk4 data is tocMEl.
Requires that my tctkjns must iw toadu«c.'J in a monnrr
conwtent with state «ppn»wd ,mmiBgeH»a»t profnm].
Alt awtwmt of (he Hatfaor for putenlM locatfcw of hislnrfe-al or .aretieologioal data
will be cMtfetsl. LeeaMofcjtet* will I* mown! In wwirtniM wMi At aifcstmftv
nquifemaarii.
Hm !i hamt in • «0iHi wm iiwbhihw aaw, Hw rat*# is tmtim*
wilh Ihe am mmtM mat mm^mtrntftagmau thernatmuM ou-mi possihfc
131 MCL40;
J10CMB 10
Applicable
Wetlands Pnjtectkxi Ac< (c-ontinuei)
j Coastal Zone Manajemern
&ta»dvdi regutae drcdfiiML. fillint, »ltariiig. Of
potiutaicofcoakUl md hlaad wtUajul tfsstfoe ar«B.
Prattctra rcaource arcs witMn and adjacent ts tie site
inclede: l-aod Subject to Cntsul Scmth Flow are 10.
WflMdl; Coastal Wctfaaxk l«,M{7Mb}» (eKO; uwd
Under Oeew 10.21(5)#); DeetpMedPertAiei 10.
2St3K:i);C«»M3 Beedm {iaelrfiig tidal flail 10a?(fi);
Ctuutal UmAs 1030(6-7); Sah Mushts I iJlf#,
SheUfisli W.J#(S)(7);
BtS available measures 'Will to used to minimize advcise c
mm mi «rM WO fc«» Wtn wm Mb| telgn a
ftrfge# salt ifMwstei wll! be itpl*nl®d. 'B4F wsi be hh
fish and staillil halrilat.
Anpft-oMe
Baai3..Iiaid IfiilarJPUi Buns »35 mi
Rsqalm that any acttoas mat be In t thaiuief
t.'O't^liv.erd wills SI4IS approved tskaotafcroeot proframs.
i iite s feeiwi 1» • «8ssal iw
MllisKriMitJl kubctaolivr pon iocs of
a. a3obs taken '«ii! fci
poiicia ofCZM.
Attachment A
Page 2
-------
Table » - New Bedford Harbor Upper and Lower Hartjor ROD
- Location Specific ARARs
Coast* Zone M)ri|«m Policies
MCZM
To Be Cocsidefed
Mtatimsiratiaii of Waterways
Lwssses Law
Prohibition Against C«uin FUhir-E
in New BrfSsrt tiaibor
I'JlMGLtUQ
! cl «4,101
, CMK 9 lit!
ill! MOl 5
aid 6,94
MGL 116
and 192,30 a
MO 2, 105
1CMR ISO 005
Applicable
Applicable
i of the sane MftotaiKilil policy tor eosuttl
•kick «e ia»pfc*HKi iwwifc nfeafifiii!
ARAR*. pmuuMy Wettexh Act and
lie Wkwwsm Lw. MSefes»lew*iife«t|ai®
B*MM I; Water qnaMy U CoMrt Htztrd2A Pttttl.
2,3; fwu Maftigeipert Principle 1; Proteaad Aim 3;
PuMie Aeeesl; Public A«»» MawippKia Hnsipte 2»
4; and Growth ManaccmaK Principle I.
Criteria far woiik wilMo Bowed mt filled cidehnds.
Poem m Im« mm vtMRy limmtm am m»
protecting (stiWis rights to adeluds, Applicable
BMvkiMU are Rmtrkdoni on Fill md Sttactufes
9320}
fa®JMWMi: Preserving Wiiw-Retaw! Public Rftttt
»d 3 (• tad M; ftmsOtm W««f.
Dependent Uses 9. 16 ppx"4«M»X 1JX?#;
Ejigiiealni and CaosUuctiMi Standiisis 9Jlt I Xe)„ {3)
(a),(k)f4); aid Pushing and Dre%ci Material PSjmkbI
M0ObOX«>-
Ptohibia teling of idling of contaminated iobam and
certain iwh in designated areas of New Bedford ll«ter.
Ttese peliefcs win be consirfeied flaa^toat censtnMloit, imlgiag and operao on and
mtlmnaMWe of tie »*#. Compliance with the identified sisbslaatree portions of if*
Suce AMJfe will: meet lie Intent of iiese policies.
Tecrporary utavoidabfe impacts to poMk access ngtift to water and (o w#ec dependent
ANfttiHr jutttwiH be available. CDFs will he Aligns 4 to
Kiowrwiste liitmre me,, m!k:i to jraAutiMMt oontroh, meh m prtt, sports Oehfe,
and ll designated port »«, rmrfnas.
, fc«a fii Aw* I, II, and III will be inoorporilcd into «bc seine# « hi Misting
cocaoi far protection ofbtactii heahn. State remain* as onforcemrat
Attachment A
Page 3
-------
Table 8
- New Bedford Harbor Upper and Lower Harbor ROD - Action Specie ARARs
Toxic Substances Control Act
(TSCA), PCB Disposal
Requirements
TSCA PCB Remediation Waste
TSCA Chemical Waste Landfli
Stendtards
TSCA Decontamination
is use 260r-
2692,40 CTK
761.50(k){3); ,
,'bKJXiXA)
40 CFR 761
61(c)
40 CFR 76).
73 See
synopsis for
spseffle
Applicable
Applicable
Applicable
40 CFR 761.
79
Applicable
General PCB Disposal requirtrawits for ill actions and
I provides jurisdiction for EPA cieanup.
Provides for & risk-based disposal method wMch will not pose
an unreasonable risk of injury to human health or the
environment.
TSCA PCB Spill Cleanup Policy
¦ft) CFR 761,
120-.135
To Be Considered
Standards for the construction, operation, and monitorine of
facilities used to dispose ofPCB's, unless a waiver is putted
(bXQno
facilities;
an J (c)(4) waivers.
Sets decontamination standards for removal of PCBs ft*
-water, organic liquids, nor>-porous surfaces, concrete *1
iiom-pofwis surfaces covered with a porous surface, Allows tor
alternative method* of decontamination.
Establishes criteria to determine adequacy of die cleanup of
spills (occulting after 5/4/tf) from the release of materials with
> 50- ppm PCBs.
Uncharges Prom water treatment plants will meet PCB
AWQC through phased TMDL approach. He Regional
Administwtt* finds the site pom an unreasonable risk, to
health and the environment and requires remediation.
Diipoal of the contaminated dredged aed totems in CDFs
will not pose unreasonable risk and is approved by the
Regional Adiniiiisttatof throu&h issuance of the illJL).
CDPs will be constructed, operated and maintained to
satisfy the substantive reouirements. TSCA wiivers
respired f« weifie reqiurenwmls regarding soil (soil
underlying CDFs will moat permeability standard of I0E-
07 em/see); synthetic bottom liner (CW'J will have
synthetic side liner); tydrogttfogic conditions; and
leachate collection. Regional Administrator finds CDFs
will not preaeM unreasonable risk, of injury to health or the
environment and approves of remedy without these specific
features.
personal protective gear will, be
in accordance wib tfaese substantive-
Atthftugh this policy is directed at eiKtrieul equipmatt
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Table S - New Bedford Harbor Upper and Lower Harbor ROD - Action Specific ARARs
33 USC J 342;
Clean Water Act (CW A),
Section 402, National Pal hutont , j-™* n?
DischargeElimination System i tl?
* (NPDES) U5, ' 1
Applicable
CWAj Section 402. NPDES*
Prohibitions
40 CTR 122.
4a
CWA, Section 404, Diedge Bid
Fill Activities
Rivers ml Harfjors Act
Ctean Air Act |CA^ WitlmM
40CFR33D
33 USC 401-
426m
11®c standards govern discharge of water into suriace wafers,
i Due to the degraded nature of New Bedford Harbor water*,
| dischaiges of Ob wid PCfls into the waterway must meet
' ambient water quality criteria (AWQC) at the discharge point.
Applicable
Prohibits new discharges into waters thai do not unset
applicable water quality criteria (AWQC) unless «rtain
conditions are .met
Discharge from she wafer treatment plants associated with
the remedial dredging wilJ meet AWQC fir Cd, Cr and PI,
Copper aod PCBs will meet AWQC through a phased
Total Maximum Daily Load (TMDL) approach.
Meeting this requirement will mult in greaser risk to
human health M the environment sta« compliance would
prevent cleanup of the Site until the Hutar waters reach
water quality standard} or until other conditions in the
attadwd we met, neither of-which can be accomplisihed in a
reasonable time frame. Regulation is waived purcoant to
CERCLA Section l21(d)(4KB>.
To Be Considered Guidance clarifies TMDL concept's swipe and AexibUil.
Applicable
TMDL guidance considered in phased TMDL tpprotcl to
weeing AWQC for copper awl PCI dlfctasiges mm site
treatment plants.
alssio
• for
Hazardous Air Poliujunis
(NESHAPS)
42 t'Sf 74fS!
ct*H ; 40
CFR Part 63
Applicable
Centre! discharge* of diedgcd or fill material in orier to restore
mi maintain the chewiest, physic#! and biotog.Seal integrity of
wiles of the United States.
Requires coordination aid appro®! of U.S. Army Corps of
BajgitteefS for dredging and for construction and (tare use of
CDFs In navigable waters of the United Sat*
NESHAPS are a set of air emissions standards for specific
chemicals, including PCBs, from specific production activities.
EPA finds that ihe rem«tj Is the least damngiiig alterative
j t® coMKSMtnt the 'Harbor, Diedging of sediments and
} lliiiii 'CDFs will be implementedso as to mfaiffliae to the
i maunum extent possible any adverse environmental
J impacts through utgineering controls «cfe as type of
I dredge used, rate of dredging, varying target cleanup levels
i irt wetland*), and salt marsh rewge&titm.
j All dredging activities and remedial design, construction
¦ and future use dedans coecembig the CDFs will comply
| with substantive retjttimtiaits of this chapter that apply to
j She remedy. Remedy wW be coordinated with and carried
1 mi with the approval aid participation of tic USAGE.
Monitoring of air emission from the CDFs daring dredging
sad during temporary aod final closure will be performed to
! assess compliance with these standards. Operation and
_ maintenance activities will be carried nut in t manner which
: will minimize potential air releases,.
Attachment A
Page 5
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Table 8 - New Bedford Harbor Upper and Lower Harbor ROD - Action Specific ARARs
Guidance on Remedial Actions
1* Superfund Sites, with PCB
C«i<*rtinafi«n
OSWER Dir. |
9355.4-01 1 To- Be Considered
(August 1990),
1
Describes the wcofiinended approach for evaluating and
remediating CERCLA sites witfi KB contamination.
1 his guidance was considered when setting remedial
objectives and target efenmip levels and will be considered !
during remedial design and when Implinenting long term 1
management controls of the CDFs.
M3muIuh^
I
j
hS®"*1" 1 1 Applicable I *>*»*"* ***** U«>W*m "J IW»«f
laaiBiieaaon ai*i l CMR 30,100 | .waste,
i 1 ;
Testing as apfwoprisite will assess wlertier hazardous www j
are present in dtaduvges, process wastes or in. material 1
generated from cable or CSO relocation projects.
Hazardous Waste Management -
Requirements for Generators of
Hazardous Waste
>
21CMGI. 4 '
and 6; 310 ' Applicable
OMR 30 J 00 ,
Establishes standards few various classes of generates.
Any hazardous waste generated from the cable and CSO' 1
rdocation projects or hazardous process wastes will be j
managed in accordance with the substantive requirements :
df these regulations and sent offihe to a hazardous waste j
disposal fid lily, |
Hazardous Waste Management - 2IC, "f'1, ,t ,
Management Standards for all i „ , Applicable
Haamlosjs Waste Facilities I UWKMlI, .
i 1
MWWw isas® for Swap jS 8T5spsa1 of
hazardous waaa. Sec, 30,501(3X4) exempts facilities which
Heal, dispose or store hazardous waste containing 50 ppm or
more ofKBs if they are adequately regulated under TSCA, 40
CFR m.
Any traardous waste generated from the cable and t.'SO j
relocation projects or hazardous process wastes will be f
maoqged In accordance with tie substantive requirements j
of this section.
Supplemental Requirements for
Hazardous Waste Management
Facilities
21 MOt.
27112), 34 Relevant and
and 43: 314 Appropriate
CMR 8.U3 ¦
This regulation outlines lie additional requirements that must
be satisfied in order for a RCRA facility to comply with the
NPPBS rc£iil*t«x,.
The inter treatment facilities will meet (lie* regulations
tfaroBgk a monitoring program and engineering controls if '
neeesaty. 1
Solid Waste Management
2t A MGt 2 !
and S; 3)0 '
CMR) 9.130- Relevant mm!
118; 19,130; | Appropriate
19.132 133; ,
19.143,
Establishes rules and requirements for solid waste facilities;
including cffversysteHs; suffice water and gr^trodwater
pratectfoo; Monitoring awl post*dosurc.
Disposal of sediments will meet the substantive j
Surface Water Discharge
21 MO|. | t
2 rs'4 CMR ' i t kc&hi outlines the requirements for obtaining a National
iiv«v^apm,' a iuoHj ilMii '¦ PoU118"* Discharge Elimination System (WOES) petnth in
^ Applicable llew»tMofNewiWfcTdH«te?«Jjaaat»
U 0M12Ha-bi, fJite ¦* Classified « SB.
"{13) ' |
Discharge from mm treatment facilities will meet |
stringent effluent limitation*. DHoctwges will bs monitored
ta accordance wift Site moolloring plans. Plants shall be
properly operated and maintained; Ascfcwge will be
reduced 01 tailed if plants fail t« ftmctkm properly wie
corrective action undertaken. I
Attachment A
Page 6
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Tsbfe S - New Bedford Harbor Upper and Lower Harbor ROD - Action Specific ARARs
i Surface Water Quaitf> Standards
Rules for the Prevention and
Control of Oil Pollution iti the
Wafers of the Commonwealth
Operation Mid Maintenance and
Pretreabnent StwdsKb for
Wastewater Trtatmem Works,
mi Indirect Disc-targets
Certification for Ondgiig,
Jfedged Material Disposal turf
Fitting in Waters
Massachusetts Water Quality
Standards Implementation
Policy ofTntfe Pollutants to
Surface Wafers (2013/90)
2? MOl
, 314-CMR4.
i)3l I ((.J)! cC 4 "
; ; 4.0Wa-b), '
l5t
, 21 MQL 26- I
53; 314 CMR
15,03(1),0-5)
; 15 (>60-5) '
^ 21 MGL "
27H2 -34;
314 CMR 12.
, 03(8>, 11
, 04(2), (3 W5J.
, fS-12); 12.
12 06
21 MGL 26-
S3; 314 CMR
v.«k 1-2)
Applicable
Ambient Air Quality Standards
HI MGL
I42U; Jin
CMR 6,04(21
Applicable
Applicable
To Be Considered
MADEP surfee water quality standards incorporate the federal
AWQCss standards for surface waters of the state. Standards
establish acute and chronic effects on aquatic life for
cooumtnamt including PCBs» cadmium, chromium, copper,
and lead-
¦ the discharge of oil or sewage, iadustriit! waste or
eriml containing oil into waten of the CmmmwwmHi.
PCBs contain oil, some of which floats on surface w ater.
Relevant and
Appropriate
Establishes operation and maintenance standards for i eai it
worts.
Recommends surface water quality standards for specified
contaminants and inplementation measures to achieve
Effluent discharged to Use River from the water treatment
plants shall meet ambient waer quality criteria for
cadmium, chromium and lead. Copper and PCB
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Table 8 -- New Bedford Harbor Upper and Lower Harbor ROD - Action Specific ARARs
Air Pollution Control
MADEP • Recommended
Threshold Effect Exposure
Limits (TELsJ and Allowable
Ambient Limits (AALs)
Allowable Sound Emissions
111 MuL
142A-J, J10
CMR 7-0'J< t •
4)- 7.10(1-2)
Applicable
To Be ConsWweJ
Standards for, among other dust, odor and noise at
construction sites. Pollution abatement ciMitrols may fa©
required.
Establishes exposure concentrations for air ccnun hunts
developed and recommended by the (J trice of Research and
Standards to prelect public health
' DAQC policy
: , 2/i/wj;
1 o Be Considered
Establishes gBiJeSneSai'soli'Ee 'of new noise shotiM not
cm:: mere than 10 decibels above the existing (background)
«level.
Dredging, Mid CDF construction will be imptmcntod «o as
to avoid air pollution. Engineering ooocroti will be used as
necessary.
EwalBMion of air emissions will consider the TELs and
AALs.
Site operBtior.s noise level will be minimized ami will
fellow the suggested neiite limit to the extern practicable.
Attachment A
Page 8
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