EXPLANATION OF SIGNIFICANT
DIFFERENCES
(ESD)
INDUSTRI-PLEX SUPERFUND SITE
OPERABLE UNIT 2
WOBURN, MASSACHUSETTS
DRAFT FOR PUBLIC COMMENT
PRO1
U.S. ENVIRONMENTAL PROTECTION AGENCY
NEW ENGLAND - REGION 1
5 POST OFFICE SQUARE
BOSTON, MA 02109-3912
SDMS Doc ID 564614
-------
U.S. EPA Region 1
Explanation of Significant Differences (ESD)
Industri-Plex Superfund Site, Operable Unit 2
August 2014
Contents
I. INTRODUCTION 4
A. Site Name and Location 4
B. Lead and Support Agencies 5
C. Legal Authority for ESD 5
D. Summary of Circumstances Necessitating this ESD 5
II. SUMMARY OF SITE HISTORY, CONTAMINATION PROBI.F.YIS AND
SELECTED REMEDY 7
A. Site History and Contamination Problems 7
B. Summary of the Selected Remedy 8
III. BASIS I OR THE DOCUMENT 9
IV. DESCRIPTION OF SIGNIFICANT DIFFERENCES.. lOFrror! Bookmark not defined.
A. Modification of Interim Cleanup Standards 10
B. Updating the ARARs 11
C. Summary of Costs 12
V. SI PPORT AGENCY COMMENTS 12
VI STATUTORY DETERMINATION 12
Ml PUBLIC INFORMATION 12
FIGURES
Figure 1 Inckisiri-plcx OU-2 Area Impacted by ESD
Figure 2 - Sediment Sample I .ocations and Approximate Limits of Benzene-
Contaminated Sediments in I.SP
TABLES:
Table 1 - Sediment Samples in LSP Data Summary
ATTACHMENTS:
Attachment 1 - Preliminary Remediation Goal Summary
Attachment 2 - ARARs for Lower South Pond Sediment Dredging and Off-Site
ESD Industri-Plex OU2
Page 2
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Disposal, and Restoration of all Disturbed Areas
Attachment 3 - Tables of Revised Applicable and Relevant and Appropriate Standards
(ARARs)
Attachment 4 - Cost Evaluation
Attachment 5 - MassDEP ESD Letter of Support
ESD Industri-Plex 0U2
Page 3
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I. INTRODUCTION
A. SITE NAME & LOCATION
Site Name: Industri-Plex Superfund Site, Operable Unit 2 (OU-2)
Site Location: Woburn, Middlesex County, Massachusetts
Mtrtac mxim
<7 ear mw
Industri-Plex Superfund Site, OU-2
ESD Industri-Plex OU2
Page 4
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B. LEAD & SUPPORT AGENCIES
Lead Agency: United States Environmental Protection Agency (EPA)
Contact: Joseph LeMay, EPA Remedial Project Manager, (617) 918-1323
Support Agency: Massachusetts Department of Environmental Protection (MassDEP)
Contact: Jay Naparstek, MassDEP Deputy Division Director, (617) 292 -5697
C. LEGAL AUTHORITY FOR ESD
This Explanation of Significant Differences (ESD) for the Induslri-Plex Superfund
Site, Operable Unit 2 (Site), documents differences in cerium components of the
remedy as originally set forth in the January 3 1, 7 06 Record of Decision (ROD).
This ESD has been prepared to provide the ¦ .ilic with an explanation of and an
opportunity to comment on an EPA mod:. n.. n of the selected remedy for Operable
Unit 2 (OU2) of the Site. The United States En. omenta Protection Agency (EPA) is
required to publish this ESD by Section 117(c) ot. Cor .tensive Environmental
Response, Compensation and Liability Act (CERCLA). 42 U.S.C. § 9617(c), and the
rule at 40 C.F.R. § 300.435(c)(2)(i). EPA is seeking public comment on this ESD
pursuant to 40 C.F.R. § 300.825(b).
Under Section 117(c) of CERCLA, 42 U.S.C. § 9617(c), the rule at 40 C.F.R.
300.435(c)(2)(i), and EPA guidance (Office of Solid Waste and Emergency Response
[OSWER] Directive 9200.1-23P), if the EPA determines that differences in the
remedial action significantly change but do not fundamentally alter the remedy selected
in the ROD, with respect to scope, performance, or cost, the EPA shall publish an ESD
to describe the differences between the remedial action being undertaken and the
remedial action set forth in the ROD, and the reasons such changes are being made.
EPA has determined thai the adjustments to the ROD provided in this ESD are
significant, but do not fundamentally alter the overall remedy for the Industri-Plex
Superfund Site, Operable I nit 2, with respect to scope, performance, or cost.
Therefore, this ESD is properly issuec
D. SUMMARY OF CIRCUMSTANCES NECESSITATING THIS ESD
1. The January 200<-> ROD for Industri-Plex Superfund Site, OU2 requires the
dredging and off-site disposal of contaminated sediments in the southern portion of
the Halls Brook Holding Area (HBHA) Pond; dredging and off-site disposal of
contaminated near shore sediments at the Wells G&H Wetland and Cranberry Bog
Conservation Area; and restoration of all disturbed areas (Figure 1). This
component of the ROD will address sediments posing unacceptable human health
risks for near shore sediments and unacceptable ecological risks for the southern
portion of HBHA Pond .
ESD Industri-Plex OU2
Page 5
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Pursuant to the ROD, groundwater, surface water and sediments near the West Hide
Pile (WHP) were investigated during the pre-design activities. Benzene
concentrations in sediments of the Lower South Pond (LSP) adjacent to the WHP
were found to be elevated above levels that would contribute to a potential
ecological risk. See Figure 2 for approximate sediment sample locations in LSP
and Table 1 for data summary. The predesign data indicates that the benzene is
strongly sorbed to organic silt layer in the sediments and the organic silt has a low
hydraulic conductivity. The predesign data also suggests the organic silt containing
benzene may have been associated with historical deposition (e.g. when the WHP
was formed in the 1970s).
One purpose of this ESD is to add to the OU2 remedy an ecological Preliminary
Remediation Goal (PRG) for benzene in sediments of the LSP adjacent to the WHP
at 1.290 mg/kg based on data for benzene toxicity in freshwater as detailed in
Attachment 1. This PRG will serve as a new cleanup level for sediments in the LSP
adjacent to the WHP. The sediments above the benzene cleanup standard will be
dredged and disposed off-site, and all disturbed areas will be restored lo a native
wetland habitat. The estimated volume of sediments contaminated with benzene
above the 1.290 mg/kg cleanup standard is approximately 900 cubic yards (see
Figure 2). ARARs that address the additional statutory and regulatory requirements
for this remedial work and which will be incorporated into the OU2 remedy are
cited in Attachment 2.
This remedial approach is consistent with ihe sediment remedial approach described
in the ROD for dredging, off-site disposal and restoration of all disturbed areas for
the Southern Portion of the HBHA Pond, Wells G&H Wetland and Cranberry Bog
Conservation Area. This remedial approach also includes post-excavation sediment
confirmation sampling and monitoring of the wetland restoration measures. Long-
term groundwater, surface water and sediment monitoring of the area will be
ongoing as part of this ESD and the OU2 monitoring requirements for the adjacent
wiip.
2. This ESD also updates a number of federal and state ARARs cited in the 2006 ROD that
either have been eliminated, modified or otherwise changed from when the 2006 ROD was
issued. The revised ARARs tables also cite a number of additional standards not identified
in the 2006 ROD. including federal wetland, floodplain. and stormwater standards
(Attachment 3). None of these changes fundamentally alters the selected remedy.
3. The supporting documentation for this ESD, and the Administrative Record are
available to the public at the following locations and may be reviewed at the times
listed:
U.S. Environmental Protection Agency
Records Center
5 Post Office Square, Suite 100
Boston, MA 02109
617-918-1440
ESD Industri-Plex OU2
Page 6
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Monday-Friday: 9:00 am - 5:00 pm
Saturday and Sunday: Closed
Woburn Public Library (summer hours)
45 Pleasant Street
Woburn, MA 01801
781-933-0148
Monday-Thursday: 9:00 am - 9:00 pm
Friday: 9:00 am - 5:30 pm
Saturday & Sunday: Closed
II. SUMMARY OF SITE HISTORY, CONTAMINATION AND SELECTED REMEDY
A. SITE HISTORY, CONTAMINATION AND r ,£ RISKS
Various chemical and glue manufacturing facii. ~ opera H on the Induslri-plcx
Superfund Site from 1853 to 1969. EPA established a 1986 Record of Decision for
the first phase of cleanup at Industri-plex (known as Operable Unit 1 or OU-1), which
included the construction of protecli\ e caps over approximately 110 acres of soils
contaminated with heavy metals and animal wastes (permeable cap over
approximately 105 acres, impermeable cap over approximately 5 acres) to prevent
people from coming into contact with the contamination The construction of OU-1
was completed in 1998.
EPA established a January 2006 ROD for the final phase of cleanup at the Industri-
plex Superfund Site, (OU-2. The January 2006 Industri-plex Superfund Site OU-2
ROD addressed contamination originating from Industri-plex OU-1 and downstream
migration of OU-1 contamination via ground water discharges. Ingestion of, dermal
contact with, and inhalation of volatile compounds released from extracted
groundwater within this aquifer poses a potential future risk to human health because
EPA's acceptable risk range is exceeded. The ROD also addresses the contamination
of soils and sediments. Ingestion of and dermal contact with these soils and sediments
poses a potential current and/or future risk to humans because EPA's acceptable risk
range is exceeded. Exposure to these sediments also poses an unacceptable ecological
risk to benthic communities in these areas. Finally, the ROD addresses the
contamination of surface water. Exposure to these surface waters poses an
unacceptable ecological risk to aquatic life.
The ROD addresses the threats at Industri-plex OU-2 through interception, treatment
and sequestration of contaminated groundwater plumes at the northern portion of the
HBHA Pond (primary and secondary treatment cells) and the WHP (enhanced in-situ
bioremediation), periodic removal of sediments accumulating at the northern portion
of the HBHA Pond, sediment removal and restoration at the southern portion of the
HBHA Pond and near shore sediment areas, capping (impermeable) stream channels
impacted by contaminated groundwater plumes discharge (including New Boston
ESD Industri-Plex OU2
Page 7
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Street Drainway), capping contaminated soils adjacent to the HBHA Pond,
establishing institutional controls for groundwater, soils, and sediments to prevent
exposures to contamination above cleanup standards (outlined in Section L of Industri-
plex OU-2 ROD) and protect the remedy, compensation for any wetland function and
value losses nearby in the watershed, and long-term monitoring of groundwater,
surface water, and sediments. On November 24, 2008, EPA entered into a Consent
Decree with two Settling Defendants to perform the Industri-plex OU-2 RD/RA
consistent with the ROD. On March 24, 2011, EPA approved the Remedial Design
Work Plan consistent with the ROD.
Additional details regarding history, contamination and risks can be found in the ROD
and its Administrative Record.
B. SUMMARY OF THE OU-2 ROD SELECTED REMEDY
The selected remedy is a comprehensive approach for Industri-plex OL-2 that
addresses all current and potential future risks caused by contaminated groundw ater,
soil, sediment, and surface water. Specifically, this remedial action addresses
contamination in:
Groundwater originating at Incliislri-ple\ OIJ-1 and extending to the HBHA Pond;
Sediments in the HBHA Pond, HBHA Wetlands, Wells G&H Wetland, and
Cranberry Bog Conservation Area;
Surface and subsurface soil in the vicinity of the former (now buried) Mishawum
Lake; and
Surface water in the Hlil l.\ Pond.
The remedial measures will prevent future unacceptable risks from sediments and
soils, and untreated groundwater and surface water, and will allow for restoration of
Industri-plex OU-2 to beneficial uses. Institutional controls will be required to prevent
unacceptable exposures to hazardous substances and contaminated materials in
groundwater, soils, and deeper wetland sediments in the future. Also, long-term
monitoring, operation and maintenance, and periodic five-year remedy reviews will be
performed.
The major components of this remedy are:
Dredging and off-site disposal of contaminated sediments in the southern portion of
the HBHA Pond; dredging and off-site disposal of contaminated near shore sediments
at the Wells G&H Wetland and Cranberry Bog Conservation Area; and restoration of
all disturbed areas. This component will address sediments posing unacceptable
human health risks for near shore sediments and unacceptable ecological risks for the
southern portion of HBHA Pond. Identified contaminants sediments which were
identified as Contaminants of Concern in the ROD were: Arsenic and Benzo(a)pyrene.
Use of the northern portion of HBHA Pond as a sediment retention area (primary and
secondary treatment cells) that will intercept contaminated groundwater plumes
(including arsenic, benzene, ammonia, 1,2-dichloroethane, trichloroethene,
ESD Industri-Plex OU2
Page 8
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naphthalene) from Industri-plex OU-1, treat/sequester contaminants of concern
(including arsenic, benzene, ammonia), and minimize downstream migration of
contaminants (including arsenic, benzene, ammonia). The primary treatment cell will
intercept the contaminated groundwater plumes discharging in the HBHA Pond. The
effluent from northern portion of the HBHA Pond (secondary treatment cell outlet)
will serve as the surface water compliance boundary, and achieve National
Recommended Water Quality Criteria (NRWQC). Sediments which accumulate in the
northern portion of the HBHA Pond will be periodically dredged and sent off-site for
disposal. Portions of storm water from Halls Brook, which may interfere with the
natural treatment processes occurring within the northern portion of the HBHA Pond,
will be diverted to the southern portion of HBHA Pond.
If necessary, In-situ Enhanced Bioremediation of contaminated groundwater plumes
(e.g., benzene) at the WHP.
Construction of an impermeable cap to line e ¦:hannels (e.g. New Boston Street
Drainway), and to prevent the discharge of contaminated groundwater plumes,
contamination of stream sediments, downstream migration of contaminants of
concern, and potential impacts to other components of the selected remedy
Construction of a permeable cap to prevent contaminated soil erosion (e.g. Area A6),
downstream migration of contaminants of concern, and potential impacts to other
components of the selected remedy
Establishing institutional controls to restrict contact with soils, groundwater, or
deeper interior wetland sediments with concentrations above cleanup standards and
protect the remedy.
Construction of compensatory wetlands for any loss of wetland functions and values
associated with the selected remedy (e.g. northern portion of HBHA Pond, Halls
Brook storm water by-pass, capped stream channels) nearby in the watershed.
Long-term monitoring of the groundwater, surface water, and sediments, and
periodic Five-year Reviews of the remedy
III. BASIS FOR THE DOCUMENT
This ESD is an expansion of the ROD and documents an ecological Preliminary
Remediation Goal (PRG) for benzene in sediments of the LSP adjacent to the WHP at
1.290 mg/kg based on data for benzene toxicity to aquatic organisms as detailed in an
attached benzene PRG Summary (Attachment 1). This PRG will serve as the remediation
goal and new cleanup standard for sediments in the LSP adjacent to the WHP. The
sediments above the benzene cleanup standard will be dredged, dewatered, and disposed
off-site, and all disturbed areas will be restored. A portadam/cofferdam will be installed
and a small portion of the LSP (approximately 0.5 acres) will be dewatered so that the
sediments may be mechanically dredged. Once dredged the contaminated sediments will
be further dewatered by gravity and/or amendments, placed in containers, and shipped
off-site to an approved disposal facility. All dewatered water will be contained,
sampled/treated, and discharged to the surface water in compliance with ARARs. The
ESD Industri-Plex OU2
Page 9
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estimated volume of sediments contaminated with benzene above the 1.290 mg/kg
cleanup standard is approximately 900 cubic yards over an area of approximately 4,800
square feet (0.11 acres) (see Figure 2). Once this contaminated sediment is removed and
the wetland restored, no further sediment remediation will be required in this area.
This remedial approach is consistent with the sediment remedial approach described in
the ROD for dredging, off-site disposal and restoration of all disturbed areas for the
Southern Portion of the HBHA Pond, Wells G&H Wetland and Cranberry Bog
Conservation Area. This remedial approach also includes posi-excavation sediment
confirmation sampling and monitoring of wetland mitigation measures. Long-term
groundwater, surface water and sediment monitoring of the area will continue as part of
OU2 monitoring requirements for the adjacent WHP. No furl her action for the LSP
sediments will be required through the OU2 remedy.
All other soil, sediment and groundwater components of the remedy documented in the
ROD are unchanged and are not impacted by this F.SD.
This ESD also updates a number of federal and state ARARs cited in the 2006 ROD that cither
have been eliminated, modified or otherwise changed from when the 2006 ROD was issued. The
revised ARARs tables also cite a number of additional standards not identified in the 2006 ROD,
including federal wetland, floodplain, and storm water standards (Attachment 3). None of these
changes fundamentally alters the selected ivmedx
IV. DESCRIPTION OF SIGNIFICANT DIFFERENCES
A. Addition of LSP Sediment Cleanup Standards
For the I SP sediment, sediment cleanup standard for benzene has been established
through this ESI) lor ecological protection in the portions of the pond (e.g. adjacent to the
WHP) where significant adverse impacts are anticipated from high exposures to benzene
in sediments The cleanup standard for benzene in the LSP sediment is 1.290 mg/kg.
The review of a\ ailable toxicity data resulted in the calculation of a sediment benchmark
values and potential PRG value based on site-specific sediment organic carbon content of
3.5%. A recommended PRG for benzene of 1.290 mg/kg was calculated using a
conservative water quality guideline for the protection of sensitive aquatic organisms and
an equilibrium partitioning method (Attachment 1).
Sediment cleanup standard for LSP is summarized below.
SUMMARY OF SEDIMENT CLEANUP STANDARD
Lower South Pond (ecological)
Benzene
1.290 mg/kg
All other cleanup standards documented in the ROD are unchanged and are not impacted
by this ESD.
ESD Industri-Plex OU2
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B. Remediation of LSP Sediments
This ESD adds cleanup of contaminated sediments in the LSP wetland to the OU2
remedial action. Sediments exceeding benzene cleanup standards will be dredged [or
excavated], dewatered, and sent for disposal in an off-site licensed disposal facility. The
sediment removal/disposal process was previously described and analyzed under criteria
established under the National Contingency Plan (40 C.F.R. Part 300) in the OU2 ROD.
EPA has determined that the removal and off-site disposal, along with restoration of
altered wetlands is the Least Environmentally Damaging Pi aclicahle Alternative under
Section 404 of the federal Clean Water Act.
Specifically, the cleanup plan proposed by EPA i.r : '^s activities that would impact
wetlands (dredging, dewatering, handling, and off-site disposal of contaminated
sediments). Before EPA can select a cleanup plan that would impact wetlands, federal
statutes and regulations (found in Appendix 3) require EPA to make a determination that
there is no practicable alternative to conducting work that will impact wetlands and that
the cleanup activities conducted are the Least Environmentally Damaging Practicable
Alternative (LEDPA), as defined by Section 404(b) of the Clean Water Act and
regulations promulgated under the Act al 4<) C.F.R. Part 230, 23 1 and 33 C.F.R. Parts
320-323. Protection of Wetlands regulations at 44 C.F.R. Section 9 require EPA to solicit
public comment, which is being done through this ESD, regarding proposed alterations to
wetland resources. To the extent that any of these federal statutes and regulations apply,
EPA has determined: that because significant levels of contamination exist in wetlands
within the cleanup areas, there is no practicable alternative to conducting work in these
wetlands; and that the proposed cleanup activities that impact wetlands are the LEDPA.
Wetlands will be restored and/or replicated consistent with the requirements of federal
and stale wetlands protection standards
Also, the cleanup plan proposed by EPA includes activities that result in the temporary
occupancy of the floodplain during remedial activities. Before selecting a cleanup
alternative, federal Floodplain Management regulations at 44 C.F.R. Section 9 require
EPA to make a determination that there is no practicable alternative to the proposed
actions within lloodplains and to solicit public comment, which is being done through
this ESD, regarding proposed alterations to floodplain resources. To the extent that any of
these federal statutes and regulations apply, EPA has determined there is no practicable
alternative to occupancy and/or modification of portions of the floodplain within the area
to be remediated and any areas needed for access or for staging remedial operations.
EPA will conduct necessary mitigation measures to protect downstream receptors in the
floodplain.
Once EPA reviews any comments that are received after the public comment period ends,
EPA will be determined whether the proposed remedial action needs to be modified or
changed and will then issue a Final ESD.
ESD Industri-Plex OU2
Page 11
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C. Updating the ARARs
This ESD also updates a number of federal and state ARARs cited in the 2006 ROD that either
have been eliminated, modified or otherwise changed from when the 2006 ROD was issued. The
revised ARARs tables also cite a number of additional standards not identified in the 2006 ROD,
including federal wetland, floodplain, and stormwater standards (Attachment 3). None of these
changes fundamentally alters the selected remedy.
D. Summary of Costs
Based on an estimated volume of benzene impacted sediment of approximately 900 cubic
yards in the LSP adjacent to the WHP, the estimated additional capital cost to dredging,
off-site disposal, and restoration of all disturbed areas would be approximately $1.3
million (Attachment 4). This modification to the ROD serves to increase the total
approximate cost of the remedy from $25.7 Million to $27.0 Million which represents an
approximate increase of 5%.
V. SUPPORTING AGENCY COMMENTS
The State of Massachusetts is reviewing the ESD and will pro\ ide its final comments
and/or approval after the close of the public comment period
VI. STATUTORY DETERMINATIONS
This ESD documents EPAs modification of the ROD lo establish a benzene cleanup
standard for sediments of 1.290 mg/kg in the LSP adjacent, lo the WHP. Sediments
above this benzene cleanup standard will be dredged and disposed off-site, and all
disturbed areas will be restored. EPA has made a determination, pending review of any
public comments, that the removal and off-site disposal, along with restoration of altered
wetlands is the Least Environmentally Damaging Practicable Alternative under Section
404 of the federal Clean Water Act. EPA believes that the modified remedy as stated in
this ESD remains protective of human health and the environment, complies with all
Federal and State requirements that are applicable or relevant and appropriate to this
remedial action, meets the remedial action objectives specified in the ROD, and is cost-
effective.
VII. PUBLIC PARTICIPATION COMPLIANCE
EPA is providing a 14-day public comment period on this ESD from August 19, 2014
through September 3, 2014. Notice of availability for review of the ESD and the
Administrative Record will be published in the Woburn Daily Times Chronicle
newspaper on August 19, 2014 encouraging the public to submit comments on this ESD.
Any significant comments received during the public comment period will be addressed
in a responsiveness summary. In accordance with Section 117(d) of CERCLA and
Section 300.825(a) of the National Contingency Plan (NCP), the final ESD and
supporting documentation shall become part of the Administrative Record for the Site.
ESD Industri-Plex OU2
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This ESD and the Administrative Record are available for public review at the locations
and times listed in Section 1(D) above.
James T. Owens III, Director date
Office of Site Remediation and Restoration
Figures
Tables
Attachment 1 - Preliminary Remediation Goal Summary
Attachment 2 - ARARs for Lower South Pond Sediment Dredging and Off-Site Disposal,
and Restoration of all Disturbed Areas
Attachment 3 - Tables of Revised Applicable and Relevant and Appropriate Standards
(ARARs)
Attachment 4 - Cost Evaluation
Attachment 5 - MassDFP FSD Letter of Support
ESD Industri-Plex 0U2
Page 13
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OLIN \M33
WOBURNK
WELLS G & H
SITE
CftAHfliiRRV aOG
DONSeRVA?IONA«M
APPROXIMATE BOUNDARY
OF INDUSTRI-PLEX OU-2
FIGURE 1
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TABLE 1
Lower South Pond - Sediment Samples
Benzene Summary Data
Industri-plex Superfund Site OU-2, Woburn, MA
Location
CS-1
CS-1
CS-1
CS-2
Sample ID
CS-l-SE-01-060412
CS-l-SE-04-060412
CS-l-SE-05-060412
CS-2-SE-01-060412
Sample Date
6/4/2012
6/4/2012 9:20
6/4/2012 9:30
6/4/2012 11:05
Sample Depth
o
o
Ln
2.5' -3.5'
3.5' -4.5'
o
o
Ln
Lab Sample ID
L1209866-01
L1209866-02
L1209866-03
L1209866-04
Benzene (ug/kg)
23000
14000
100J
3.8U
Notes:
1. : Foot.
2. "U": Analyte undetected, value
shown is equal to reporting limit.
3. "J": Estimated value. Below
the quantitation limit but above
one half reporting limit.
4. "R": Data rejected due to low
total solids and high water
content.
5. "UR": Analyte undetected, data
rejected due to low total solids
and high water content.
-------
TABLE 1
Lower South Pond - Sediment Samples
Benzene Summary Data
Industri-plex Superfund Site OU-2, Woburn, MA
Location
CS-2
CS-2
CS-2
CS-3
Sample ID
CS-2-SE-02-060412
CS-2-SE-03-060412
CS-2-SE-04-060412
CS-3-SE-01-060412
Sample Date
6/4/2012 11:08
6/4/2012 11:10
6/4/2012 11:12
6/4/2012 12:02
Sample Depth
0.5' -1.5'
1.5' -2.4'
2.4' -3'
o
o
Ln
Lab Sample ID
L1209866-05
L1209866-06
L1209866-07
L1209866-08
Benzene (ug/kg)
3.8R
8.7J
160
1.5U
Notes:
1. : Foot.
2. "U": Analyte undetected, value
shown is equal to reporting limit.
3. "J": Estimated value. Below
the quantitation limit but above
one half reporting limit.
4. "R": Data rejected due to low
total solids and high water
content.
5. "UR": Analyte undetected, data
rejected due to low total solids
and high water content.
-------
TABLE 1
Lower South Pond - Sediment Samples
Benzene Summary Data
Industri-plex Superfund Site OU-2, Woburn, MA
Location
CS-3
PZ-101EE-SE
PZ-101E-SE
PZ-101NNE-SE
Sample ID
CS-3-SE-02-060412
PZ-101EE-SE-01-092211
PZ-101E-SE-081811
PZ-101NNE-SE-01-092211
Sample Date
6/4/2012 12:05
9/22/2011 14:00
8/18/2011 9:10
9/22/2011 13:50
Sample Depth
0.5'- 1.3'
o
o
Ln
o
o
Ln
o
o
Ln
Lab Sample ID
L1209866-09
L1115141-03
L1112788-04
L1115141-02
Benzene (ug/kg)
1.1U
14000J
36000
14U
Notes:
1. : Foot.
2. "U": Analyte undetected, value
shown is equal to reporting limit.
3. "J": Estimated value. Below
the quantitation limit but above
one half reporting limit.
4. "R": Data rejected due to low
total solids and high water
content.
5. "UR": Analyte undetected, data
rejected due to low total solids
and high water content.
-------
TABLE 1
Lower South Pond - Sediment Samples
Benzene Summary Data
Industri-plex Superfund Site OU-2, Woburn, MA
Location
PZ-101NN-SE
PZ-101NNW-SE
PZ-101N-SE
PZ-101-SE
Sample ID
PZ-101NN-SE-01-092211
PZ-101NNW-SE-01-092211
PZ-101N-SE-081811
2287-FD-001-062811
Sample Date
9/22/2011 13:30
9/22/2011 14:35
8/18/2011 9:25
6/28/2011
Sample Depth
o
o
Ln
o
o
Ln
o
o
Ln
o
o
Ln
Lab Sample ID
L1115141-01
L1115141-04
L1112788-03
L1109541-02
Benzene (ug/kg)
2100J
99J
3300
12000J
Notes:
1. : Foot.
2. "U": Analyte undetected, value
shown is equal to reporting limit.
3. "J": Estimated value. Below
the quantitation limit but above
one half reporting limit.
4. "R": Data rejected due to low
total solids and high water
content.
5. "UR": Analyte undetected, data
rejected due to low total solids
and high water content.
-------
TABLE 1
Lower South Pond - Sediment Samples
Benzene Summary Data
Industri-plex Superfund Site OU-2, Woburn, MA
Location
PZ-101-SE
PZ-101S-SE
PZ-101SSE-SE
PZ-102-SE
Sample ID
PZ-101-SE-01-062811
PZ-101S-SE-081811
PZ-101SSE-SE-01-092211
PZ-102-SE-01-062711
Sample Date
6/28/2011 14:39
8/18/2011 9:00
9/22/2011 14:50
6/27/2011 12:15
Sample Depth
o
o
Ln
o
o
Ln
o
o
Ln
o
o
Ln
Lab Sample ID
L1109541-10
L1112788-02
L1115141-05
L1109441-05
Benzene (ug/kg)
30000J
62000
380000J
2.3U
Notes:
1. : Foot.
2. "U": Analyte undetected, value
shown is equal to reporting limit.
3. "J": Estimated value. Below
the quantitation limit but above
one half reporting limit.
4. "R": Data rejected due to low
total solids and high water
content.
5. "UR": Analyte undetected, data
rejected due to low total solids
and high water content.
-------
TABLE 1
Lower South Pond - Sediment Samples
Benzene Summary Data
Industri-plex Superfund Site OU-2, Woburn, MA
Location
PZ-103-SE
PZ-104-SE
PZ-105-SE
PZ-106-SE
Sample ID
PZ-103-SE-01-062811
PZ-104-SE-01-062811
PZ-105-SE-01-062711
PZ-106-SE-01-062811
Sample Date
6/28/2011 14:10
6/28/2011 12:08
6/27/2011 11:20
6/28/2011 11:21
Sample Depth
o
o
Ln
o
o
Ln
0' - 0.25'
o
o
Ln
Lab Sample ID
L1109541-09
L1109541-08
L1109441-04
L1109541-07
Benzene (ug/kg)
2.4U
3.1U
2.3U
1.4U
Notes:
1. : Foot.
2. "U": Analyte undetected, value
shown is equal to reporting limit.
3. "J": Estimated value. Below
the quantitation limit but above
one half reporting limit.
4. "R": Data rejected due to low
total solids and high water
content.
5. "UR": Analyte undetected, data
rejected due to low total solids
and high water content.
-------
TABLE 1
Lower South Pond - Sediment Samples
Benzene Summary Data
Industri-plex Superfund Site OU-2, Woburn, MA
Location
PZ-107-SE
PZ-110-SE
PZ-111-SE
PZ-112-SE
Sample ID
PZ-107-SE-01-062711
PZ-110-SE-01-062711
PZ-lll-SE-01-062811
PZ-112-SE-01-062711
Sample Date
6/27/2011 10:24
6/27/2011 14:44
6/28/2011 10:05
6/27/2011 14:00
Sample Depth
o
o
Ln
o
o
Ln
o
o
Ln
o
o
Ln
Lab Sample ID
L1109441-03
L1109441-08
L1109541-05
L1109441-06
Benzene (ug/kg)
2.7
1.9U
1.6U
2.1U
Notes:
1. : Foot.
2. "U": Analyte undetected, value
shown is equal to reporting limit.
3. "J": Estimated value. Below
the quantitation limit but above
one half reporting limit.
4. "R": Data rejected due to low
total solids and high water
content.
5. "UR": Analyte undetected, data
rejected due to low total solids
and high water content.
-------
TABLE 1
Lower South Pond - Sediment Samples
Benzene Summary Data
Industri-plex Superfund Site OU-2, Woburn, MA
Location
PZ-114-SE
PZ-115-SE
PZ-116-SE
PZ-117-SE
Sample ID
PZ-114-SE-01-062811
PZ-115-SE-01-062811
PZ-116-SE-01-070811
PZ-117-SE-01-070111
Sample Date
6/28/2011 8:50
6/28/2011 9:35
7/8/2011 11:45
7/1/201112:05
Sample Depth
o
o
Ln
o
o
Ln
o
o
Ln
0' - 6'
Lab Sample ID
L1109541-03
L1109541-04
L1110149-04
L1109834-01
Benzene (ug/kg)
2.4U
1.7U
10U
17U
Notes:
1. : Foot.
2. "U": Analyte undetected, value
shown is equal to reporting limit.
3. "J": Estimated value. Below
the quantitation limit but above
one half reporting limit.
4. "R": Data rejected due to low
total solids and high water
content.
5. "UR": Analyte undetected, data
rejected due to low total solids
and high water content.
-------
TABLE 1
Lower South Pond - Sediment Samples
Benzene Summary Data
Industri-plex Superfund Site OU-2, Woburn, MA
Location
SE-300
SE-301
SE-302
SE-303
Sample ID
SE-300-SE-01-092211
SE-301-SE-01-092211
SE-302-SE-01-103111
SE-303-SE-01-103111
Sample Date
9/22/2011 14:15
9/22/2011 15:10
10/31/201113:10
10/31/201113:55
Sample Depth
o
o
Ln
o
o
Ln
o
o
Ln
o
o
Ln
Lab Sample ID
L1115141-06
L1115141-07
L1118011-01
L1118011-02
Benzene (ug/kg)
32J
120000J
3.7U
2.6U
Notes:
1. : Foot.
2. "U": Analyte undetected, value
shown is equal to reporting limit.
3. "J": Estimated value. Below
the quantitation limit but above
one half reporting limit.
4. "R": Data rejected due to low
total solids and high water
content.
5. "UR": Analyte undetected, data
rejected due to low total solids
and high water content.
-------
TABLE 1
Lower South Pond - Sediment Samples
Benzene Summary Data
Industri-plex Superfund Site OU-2, Woburn, MA
Location
SE-317
SE-318
SE-319
SP-1
Sample ID
SE-317-SE-01-100212
SE-318-SE-01-100212
SE-319-SE-01-100212
SP-1-SE-01-101812
Sample Date
10/2/2012 10:10
10/2/2012 9:30
10/2/2012 10:00
10/18/2012 13:05
Sample Depth
o
o
Ln
o
o
Ln
o
o
Ln
0.5'- 1'
Lab Sample ID
L1217676-01
L1217676-02
L1217676-03
L1218828-01
Benzene(ug/kg)
13
22UR
12UR
4800
Notes:
1. : Foot.
2. "U": Analyte undetected, value
shown is equal to reporting limit.
3. "J": Estimated value. Below
the quantitation limit but above
one half reporting limit.
4. "R": Data rejected due to low
total solids and high water
content.
5. "UR": Analyte undetected, data
rejected due to low total solids
and high water content.
-------
TABLE 1
Lower South Pond - Sediment Samples
Benzene Summary Data
Industri-plex Superfund Site OU-2, Woburn, MA
Location
SP-1
SP-1
SP-2
SP-2
Sample ID
SP-l-SE-02-101812
SP-l-SE-03-101812
SP-2-SE-01-101812
SP-2-SE-02-101812
Sample Date
10/18/2012 13:10
10/18/2012 13:15
10/18/2012 13:50
10/18/2012 13:55
Sample Depth
1.5' -2'
2.5' -3'
0.5'- 1'
1.5'- 2'
Lab Sample ID
L1218828-02
L1218828-03
L1218828-04
L1218828-05
Benzene(ug/kg)
29000
28000
940000
110000
Notes:
1. : Foot.
2. "U": Analyte undetected, value
shown is equal to reporting limit.
3. "J": Estimated value. Below
the quantitation limit but above
one half reporting limit.
4. "R": Data rejected due to low
total solids and high water
content.
5. "UR": Analyte undetected, data
rejected due to low total solids
and high water content.
-------
TABLE 1
Lower South Pond - Sediment Samples
Benzene Summary Data
Industri-plex Superfund Site OU-2, Woburn, MA
Location
SP-2
SP-3
SP-3
SP-3
Sample ID
SP-2-SE-03-101812
SP-3-SE-01-101812
SP-3-SE-02-101812
SP-3-SE-03-101812
Sample Date
10/18/2012 14:00
10/18/2012 14:30
10/18/2012 14:35
10/18/2012 14:40
Sample Depth
2.5' -3'
0.5'- 1'
1.5'- 2'
2.5' -3'
Lab Sample ID
L1218828-06
L1218828-07
L1218828-08
L1218828-09
Benzene (ug/kg)
460000J
11UJR
180J
52
Notes:
1. : Foot.
2. "U": Analyte undetected, value
shown is equal to reporting limit.
3. "J": Estimated value. Below
the quantitation limit but above
one half reporting limit.
4. "R": Data rejected due to low
total solids and high water
content.
5. "UR": Analyte undetected, data
rejected due to low total solids
and high water content.
-------
TABLE 1
Lower South Pond - Sediment Samples
Benzene Summary Data
Industri-plex Superfund Site OU-2, Woburn, MA
Location
DC-03
DC-03
DC-04
DC-04
Sample ID
DC-3-SE-01-040914-1100
DC-3-SE-02-040914-1105
DC-4-SE-01-040914-1120
DC-4-SE-02-040914-1125
Sample Date
4/9/2014 11:00
4/9/2014 11:05
4/9/2014 11:20
4/9/2014 11:25
Sample Depth
0.0'-0.5'
2.5'-3.5'
0.0'-0.5'
1.5'-2.5'
Lab Sample ID
L1407363-11
L1407363-12
L1407363-13
L1407363-14
Benzene (ug/kg)
980
770
18
110
Notes:
1. : Foot.
2. "U": Analyte undetected, value
shown is equal to reporting limit.
3. "J": Estimated value. Below
the quantitation limit but above
one half reporting limit.
4. "R": Data rejected due to low
total solids and high water
content.
5. "UR": Analyte undetected, data
rejected due to low total solids
and high water content.
-------
TABLE 1
Lower South Pond - Sediment Samples
Benzene Summary Data
Industri-plex Superfund Site OU-2, Woburn, MA
Location
DC-05
DC-05
DC-06
Sample ID
DC-05-SE-01-041014-0840
DC-05-SE-02-041014-0845
DC-06-SE-01-041014-0910
Sample Date
4/10/2014 8:40
4/10/2014 8:45
4/10/2014 9:10
Sample Depth
0.0' -0.5'
1.0'-2.3'
0.0' -0.5'
Lab Sample ID
L1407532-01
L1407532-02, R1
L1407532-03, R1
Benzene (ug/kg)
12U
18U
10U
Notes:
1. : Foot.
2. "U": Analyte undetected, value
shown is equal to reporting limit.
3. "J": Estimated value. Below
the quantitation limit but above
one half reporting limit.
4. "R": Data rejected due to low
total solids and high water
content.
5. "UR": Analyte undetected, data
rejected due to low total solids
and high water content.
-------
TABLE 1
Lower South Pond - Sediment Samples
Benzene Summary Data
Industri-plex Superfund Site OU-2, Woburn, MA
Location
DC-06
DC-06
DC-08
Sample ID
DC-06-SE-02-041014-0915
2287-FD-01-041014(DC-06-SE-02-041014-0915)
DC-08-SE-01-041014-1050
Sample Date
4/10/2014 9:15
4/10/2014
4/10/2014 10:50
Sample Depth
1.0' -2.7'
In
d
d
d
Lab Sample ID
L1407532-04, R1
L1407532-09, R1
L1407532-07, R1
Benzene (ug/kg)
6.2U
9.6U
12U
Notes:
1. : Foot.
2. "U": Analyte undetected, value
shown is equal to reporting limit.
3. "J": Estimated value. Below
the quantitation limit but above
one half reporting limit.
4. "R": Data rejected due to low
total solids and high water
content.
5. "UR": Analyte undetected, data
rejected due to low total solids
and high water content.
-------
TABLE 1
Lower South Pond - Sediment Samples
Benzene Summary Data
Industri-plex Superfund Site OU-2, Woburn, MA
Location
DC-08
DC-09
DC-09
Sample ID
DC-08-SE-02-041014-1055
DC-9-SE-01-040914-1440
DC-9-SE-02-040914-1445
Sample Date
4/10/2014 10:55
4/9/2014 14:40
4/9/2014 14:45
Sample Depth
2.0' -3.5'
In
d
d
d
1.0'- 1.5'
Lab Sample ID
L1407532-08, R1
L1407363-04
L1407363-05
Benzene (ug/kg)
17U
13U
20U
Notes:
1. : Foot.
2. "U": Analyte undetected, value
shown is equal to reporting limit.
3. "J": Estimated value. Below
the quantitation limit but above
one half reporting limit.
4. "R": Data rejected due to low
total solids and high water
content.
5. "UR": Analyte undetected, data
rejected due to low total solids
and high water content.
-------
TABLE 1
Lower South Pond - Sediment Samples
Benzene Summary Data
Industri-plex Superfund Site OU-2, Woburn, MA
Location
DC-10
DC-10
DC-10
Sample ID
DC-10-SE-01-040914-1400
2287-FD-01-040914(DC-10-SE-01-040914-1400)
DC-10-SE-02-040914-1405
Sample Date
4/9/2014 14:00
4/9/2014
4/9/2014 14:05
Sample Depth
0.0' -0.5'
2.0'-3.4'
Lab Sample ID
L1407363-02
L1407363-06
L1407363-03
Benzene (ug/kg)
14U
18U
18
Notes:
1. : Foot.
2. "U": Analyte undetected, value
shown is equal to reporting limit.
3. "J": Estimated value. Below
the quantitation limit but above
one half reporting limit.
4. "R": Data rejected due to low
total solids and high water
content.
5. "UR": Analyte undetected, data
rejected due to low total solids
and high water content.
-------
TABLE 1
Lower South Pond - Sediment Samples
Benzene Summary Data
Industri-plex Superfund Site OU-2, Woburn, MA
Location
DC-11
DC-11
DC-12
DC-12
Sample ID
DC-ll-SE-01-040914-1250
DC-ll-SE-02-040914-1255
DC-12-SE-01-040914-1015
DC-12-SE-02-040914-1020
Sample Date
4/9/2014 12:50
4/9/2014 12:55
4/9/2014 10:15
4/9/2014 10:20
Sample Depth
0.0'-0.5'
1.0' -2.2'
0.0' -0.5'
2.5'-3.5'
Lab Sample ID
L1407363-15
L1407363-16
L1407363-09
L1407363-10
Benzene (ug/kg)
2900
12
8.4
1800
Notes:
1. : Foot.
2. "U": Analyte undetected, value
shown is equal to reporting limit.
3. "J": Estimated value. Below
the quantitation limit but above
one half reporting limit.
4. "R": Data rejected due to low
total solids and high water
content.
5. "UR": Analyte undetected, data
rejected due to low total solids
and high water content.
-------
TABLE 1
Lower South Pond - Sediment Samples
Benzene Summary Data
Industri-plex Superfund Site OU-2, Woburn, MA
Location
DC-14
DC-14
DC-15
DC-15
Sample ID
DC-14-SE-01-041014-0945
DC-14-SE-02-041014-0950
DC-15-SE-01-041014-1120
DC-15-SE-02-041014-1125
Sample Date
4/10/2014 9:45
4/10/2014 9:50
4/10/2014 11:20
4/10/2014 11:25
Sample Depth
0.0' -0.5'
1.0' -3.0'
0.0' -0.5'
2.0' -3.5'
Lab Sample ID
L1407532-05, R1
L1407532-06, R1
L1407532-11, R1
L1407532-12
Benzene (ug/kg)
111!
18U
9.2U
8.2
Notes:
1. : Foot.
2. "U": Analyte undetected, value
shown is equal to reporting limit.
3. "J": Estimated value. Below
the quantitation limit but above
one half reporting limit.
4. "R": Data rejected due to low
total solids and high water
content.
5. "UR": Analyte undetected, data
rejected due to low total solids
and high water content.
-------
TABLE 1
Lower South Pond - Sediment Samples
Benzene Summary Data
Industri-plex Superfund Site OU-2, Woburn, MA
Location
DC-16
DC-16
DC-16
Sample ID
DC-16-SE-01-050814-1125
DC-16-SE-02-050814-1130
0774-FD-050814(DC-16-SE-02-050814-1130)
Sample Date
5/8/2014 11:25
5/8/2014 11:30
5/11/2014
Sample Depth
0.0' -0.5'
1.5' -2.5'
Lab Sample ID
L1409827-01
L1409827-02
L1409827-06
Benzene (ug/kg)
13
20
38
Notes:
1. : Foot.
2. "U": Analyte undetected, value
shown is equal to reporting limit.
3. "J": Estimated value. Below
the quantitation limit but above
one half reporting limit.
4. "R": Data rejected due to low
total solids and high water
content.
5. "UR": Analyte undetected, data
rejected due to low total solids
and high water content.
-------
TABLE 1
Lower South Pond - Sediment Samples
Benzene Summary Data
Industri-plex Superfund Site OU-2, Woburn, MA
Location
DC-18
DC-18
DC-20
DC-22
Sample ID
DC-18-SE-01-050814-1150
DC-18-SE-01-050814-1155
DC-20-SE-01-050814-1100
DC-22-SE-01-053014-0945
Sample Date
5/8/2014 11:50
5/8/2014 11:55
5/8/2014 11:50
5/30/2014 9:45
Sample Depth
In
d
d
d
1.5' - 2.5'
0.0' -0.5'
0.0' -0.5'
Lab Sample ID
L1409827-03
L1409827-04
L1409827-05
L1411715-01
Benzene (ug/kg)
6.9
1800
1.7U
4.7
Notes:
1. : Foot.
2. "U": Analyte undetected, value
shown is equal to reporting limit.
3. "J": Estimated value. Below
the quantitation limit but above
one half reporting limit.
4. "R": Data rejected due to low
total solids and high water
content.
5. "UR": Analyte undetected, data
rejected due to low total solids
and high water content.
-------
TABLE 1
Lower South Pond - Sediment Samples
Benzene Summary Data
Industri-plex Superfund Site OU-2, Woburn, MA
Location
DC-22
DC-23
DC-23
Sample ID
DC-22-SE-02-053014-0950
DC-23-SE-01-053014-1035
DC-23-SE-02-053014-1040
Sample Date
5/30/2014 9:50
5/30/2014 10:35
5/30/2014 10:40
Sample Depth
1.0'- 2.0'
0.0'-0.5'
1.0' -2.0'
Lab Sample ID
L1411715-02
L1411715-03
L1411715-04
Benzene (ug/kg)
1600
3.4U
130
Notes:
1. : Foot.
2. "U": Analyte undetected, value
shown is equal to reporting limit.
3. "J": Estimated value. Below
the quantitation limit but above
one half reporting limit.
4. "R": Data rejected due to low
total solids and high water
content.
5. "UR": Analyte undetected, data
rejected due to low total solids
and high water content.
-------
TABLE 1
Lower South Pond - Sediment Samples
Benzene Summary Data
Industri-plex Superfund Site OU-2, Woburn, MA
Location
DC-23
DC-24
DC-24
Sample ID
5052-FD-01-053014(DC-23-SE-02-053014-1040)
DC-24-SE-01-053014-1110
DC-24-SE-02-053014-1115
Sample Date
5/30/2014
5/30/2014 11:10
5/30/2014 11:15
Sample Depth
0.0' -0.5'
0.5'- 1.5'
Lab Sample ID
L1411715-09
L1411715-05
L1411715-06
Benzene (ug/kg)
23
3.6U
4.4U
Notes:
1. : Foot.
2. "U": Analyte undetected, value
shown is equal to reporting limit.
3. "J": Estimated value. Below
the quantitation limit but above
one half reporting limit.
4. "R": Data rejected due to low
total solids and high water
content.
5. "UR": Analyte undetected, data
rejected due to low total solids
and high water content.
-------
TABLE 1
Lower South Pond - Sediment Samples
Benzene Summary Data
Industri-plex Superfund Site OU-2, Woburn, MA
Location
DC-25
DC-25
Sample ID
DC-25-SE-01-053014-1200
DC-25-SE-02-053014-1205
Sample Date
5/30/2014 12:00:00 AM
5/30/2014 12:05:00 AM
Sample Depth
In
d
d
d
0.5' -1.5'
Lab Sample ID
L1411715-07
L1411715-08
Benzene (ug/kg)
2.4U
2.8U
Notes:
1. : Foot.
2. "U": Analyte undetected, value
shown is equal to reporting limit.
3. "J": Estimated value. Below
the quantitation limit but above
one half reporting limit.
4. "R": Data rejected due to low
total solids and high water
content.
5. "UR": Analyte undetected, data
rejected due to low total solids
and high water content.
-------
Attachment 1
Preliminary Remediation Goal Summary
-------
Attachment 1 - PRG Summary
Explanation of Significant Differences (ESD)
Industri-Plex Superfund Site, Operable Unit 2
REVISED AUGUST 11, 2014
Background
This summary provides information to evaluate existing data on benzene toxicity in freshwater sediments
and to support the development of a site-specific Preliminary Remediation Goal (PRG) for the sediments
in Lower South Pond (LSP) in the vicinity of the West Hide Pile on the Industri-Plex Site, Operable Unit
2 (OU-2), in Woburn, Massachusetts.
Habitat. Receptors and Complete Exposure Pathways
Lower South Pond is a shallow aquatic habitat. Recent site activities during the OU-2 Pre-Design
Investigations have focused on characterization of groundwater migration in the vicinity of the West
Hide Pile, adjacent to Lower South Pond, and the evaluation of the extent of potential aquatic impacts.
The area of interest is located between the East and West Hide Piles in Lower South Pond. The data
collected in sediments in as part of the pre-design investigation in 2011 and in subsequent samples have
indicated concentrations of benzene in sediments up to 380,000 ug/kg. Benzene was detected in
sediment samples collected in shallow cores (0-6 inches) in the surface sediments, in particular along the
shore with the West Hide Pile. There have not been any detections of benzene in surface water samples
along the shore of the West Hide Pile. Therefore, it is assumed that the surface water exposure pathway
of fish and aquatic invertebrates exposed to benzene is likely to be minor. Based on the presence of
benzene detected in sediment samples, the primary receptors are those exposed directly to sediments, and
those that may be exposed by feeding on organisms in the sediment. The highest exposures are likely to
occur to benthic organisms that are exposed to high concentrations of benzene in pore water. These
organisms include benthic invertebrates and possibly amphibians that burrow in sediments. Incidental
ingestion by sediment-feeding organisms such as fish is also a potential exposure pathway, but exposures
would be lower than those of the benthic organisms.
Benzene toxicity
For non-polar organic chemicals, including benzene, properties such as water solubility, sorption to
sediment particles, and toxicity are proportional to hydrophobicity, which is expressed as the octanol-
water partition coefficient (KoW). Hydrocarbons are lost from buried sediment layers mainly by
dissolution or dispersion in water percolating through sediment layers, or by microbial degradation. In
sediment porewater (in solution), benzene is more bioavailable and toxic to sediment-dwelling organisms
than when adsorbed to sediment particles. Bioaccumulation of hydrocarbons sorbed to sediments by
direct contact with external body surfaces or following ingestion of the particles is thought to involve an
intermediate step in which the chemicals desorb from the particle into the water and then are absorbed
into an organism (Di Toro et al., 1991; 2000; Hansen et al., 2003).
Hydrocarbons associated with sediment particles must partition from the sediment particles into solution
before they can move across biological membranes and be taken up by the organism. For low molecular
weight hydrocarbons like benzene (log Kow = 2.13) with high solubility, sufficient levels in the porewater
allow rapid bioaccumulation across external permeable membranes or across the gut of organisms when
sediment and porewater are ingested.
-------
Generally, the best approach for estimating the toxicity of low molecular weight hydrocarbons in
sediments to benthic organisms is to estimate the hydrocarbon concentration in sediment porewater and
then compare the estimated concentration to water quality criteria for the hydrocarbon as described in
USEPA Guidance (Hansen et al., 2003). The dissolved phase of hydrocarbons in sediment porewater
can be estimated based on equilibrium partitioning theory (EqP) as described by Hansen et al. (2003).
Assumptions and limitations of these calculations are well-documented. The fundamental assumption
for this method is that the derived sediment benchmark, based on toxicity of benzene to surface water
organisms, is protective of benthic organisms exposed to similar porewater concentrations.
There are a limited number of studies of water column invertebrates, frogs and fish sensitivity to
benzene that have led to development of water quality benchmarks. In general these data are available
in the ECOTOX database (http://www.epa.gov/ecotox). There have never been enough data on benzene
toxicity for EPA to calculate a National Ambient Water Quality Criteria (NAWQC) value for benzene.
Several sources have used various methods and assumptions to develop water quality benchmarks based
on available surface water toxicity data.
Using the EqP approach, water quality benchmark values can be used to derive sediment screening values
through equilibrium partitioning.
A sediment benchmark was calculated using the recommended Canadian Water Quality Guideline (surface
water value of 370 ug/L), which was based on leopard frog toxicity (CCME, 1999). This Canadian water
quality guideline for benzene was derived from a 9-day study of the early life stages of the leopard frog,
which was the most sensitive organism represented in the toxicity dataset. The final chronic value was
derived by multiplying the endpoint from this study (LC50 = 3.7 mg/L) by a safety factor of 0.1.
The sediment benchmark for benzene was then determined from the Final Chronic Value (FCV), Kow,
Koc, and the fraction of organic carbon in sediment (foc). Site-specific sampling data were collected from
Lower South Pond during pre-design investigation in 2011 and 2012 in the vicinity of the West Hide
Pile (Table 1). From these data a site-specific TOC was calculated as 3.5% organic carbon (geometric
mean, since concentration range is greater than an order of magnitude). This mean TOC value included
samples up to 5 ft below the surface. If the data are calculated for shallow sediments only (1 to 2 ft
depth), the resulting geometric mean is similar (3.8%).
The Log organic carbon-to-water partitioning coefficient (Log Koc) is related to Log Kow for each
hydrocarbon by the following equation (Di Toro et al., 1991):
Log Koc = 0.00028 + 0.938Log Kow
Using the Kow values benzene (log Kow = 2.13), the Log Koc from the above equation for benzene is
equal to 1.998 and Koc is 99.59.
A Sediment Benchmark is then calculated from the equation:
Sediment Benchmark (mg/kg sediment) = Koc x FCV (mg/L) x foc (0.035) Where foc
is the assumed site-specific fraction of organic carbon, at 3.5%.
For benzene in sediment, the calculated sediment benchmark is:
-------
Sediment Benchmark (mg/kg oc) = 99.59 x 370 ug/L x 0.001 mg/ug = 36.8 mg/kg oc
or assuming 3.5% organic carbon, the benchmark is 1.290 mg/kg sediment (36.8 mg/kg oc * 0.035 kg
oc/kg sediment)-
Converting this result to ug/kg sediment, results in a recommended PRG for benzene of 1,290 ug/kg.
References
Canadian Council of Ministers of the Environment (CCME). 1999. Canadian water quality guidelines for
the protection of aquatic life: Benzene. In: Canadian environmental quality, 1999, Canadian Council of
Ministers of the Environment, Winnipeg.
Di Toro, D.M., J.A. McGrath, and D.J. Hansen. 2000. Technical basis for narcotic chemicals and
polycyclic aromatic hydrocarbon criteria. I. Water and tissue. Environ. Toxicol. Chem. 19:1951-
1970.
Di Toro, D M., C.S. Zarba, D.J. Hansen, W.J. Berry, R.C. Swartz, C.E. Cowan, S.P. Pavlou, HE.
Allen, N.A. Thomas, and P.R. Paquin. 1991. Technical basis for establishing sediment quality criteria
for nonionic organic chemicals by using equilibrium partitioning. Environ. Toxicol. Chem. 10(12):
1541-1583.
Hansen, D.J., DiToro, D M., McGrath, J.A., Swartz, R.C., Mount, D R., Spehar, R.L., Burgess, R.M.,
Ozretich, R.J., Bell, H.E., Reiley, M.C., and T.K. Linton. 2003. Procedures for the Derivation of
Equilibrium Partitioning Sediment Benchmarks (ESBs) for the Protection of Benthic
Organisms: PAH Mixtures. United States Environmental Protection Agency Office of Research
and Development. Washington, D.C. EPA-600-R-02-013. November.
-------
Table 1. Total Organic Carbon Data for Sediments in Lower South Pond
Sample ID
Sampling round1
TOC (%)
PZ-101-SE
2011 PDI Data2
1.67
PZ-103-SE
2011 PDI Data2
3.64
CS-1 (1')
2012 PDI Followup
Data 3
2.8
CS-1 (4')
2012 PDI Followup
Data 3
0.522
CS-1 (5')
2012 PDI Followup
Data 3
11
CS-2 (1')
2012 PDI Followup
Data 3
4.06
CS-2 (2')
2012 PDI Followup
Data 3
11.6
CS-2 (3')
2012 PDI Followup
Data 3
12.3
CS-2 (4')
2012 PDI Followup
Data 3
1.28
Average 5.4
Geometric Mean 3.5
Median 3.6
Minimum 0.5
Maximum 12.3
Notes:
1) Samples include all data along West Hide Pile, near elevated benzene (PZ-101, PZ-103, CS-1, CS-2)
PDI - Pre-Design Investigation
TOC - Total Organic Carbon content measured in sediment samples
2) Haley and Aldrich, 2012. 30% Remedial Design Report, Appendix A
3) Haley and Aldrich, 2012. Sediment: Total Organic Carbon Results, June 2012. Provided via
email from Russell Schuck June 26, 2012.
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Attachment 2
ARARs for Lower South Pond Sediment Dredging and
Off-Site Disposal, and Restoration of all Disturbed Areas
-------
ATTACHMENT 2 -LOWER SOUTH POND (LSP) SEDIMENTS DREDGING AND OFF-SITE DISPOSAL,
AND RESTORATION OF ALL DISTURBED AREAS
ACTION-SPECIFIC ARARs
AUTHORITY
REQUIREMENT
STATUS
REQUIREMENT SYNOPSIS
ACTIONS TO BE TAKEN TO ATTAIN REQUIREMENT
Federal Regulatory
Requirements
RCRA Identification
and Listing of
Hazardous Wastes, 40
C.F.R. 261.3
Applicable
Criteria for determining if a waste or contaminated
media is a hazardous waste subject to regulation. If
a contaminated media exhibits the characteristics of
a hazardous waste, RCRA hazardous waste
regulations are applicable.
EPA will assess the contaminated sediments using this
criteria to determine whether they should be managed
as hazardous waste.
RCRA Hazardous
Waste Regulations
(Storage and Disposal
of Hazardous Waste)
40 C.F.R. Part 262,
Subpart A, 40 C.F.R.
Part 264, Subparts I
and J.
Relevant and
Appropriate
Subparts I and J of Part 264 identify design,
operating, monitoring, closure, and post-closure
care requirements for RCRA hazardous waste in
containers and tank systems, respectively.
However, Section 262.34(a) allows accumulation of
RCRA hazardous wastes for up to 90 days in
containers or tanks provided generator complies
with requirements of Subparts I and J of Part 265.
Relevant and appropriate standards for less than 90
storage.
Any hazardous waste generated from the sediment
removal will be managed in accordance with these
standards.
RCRA Closure and
Post-Closure
Requirements, 40
C.F.R. Subpart G
Applicable
If contaminated sediments constitute characteristic
hazardous waste these regulations are applicable.
Closure must be completed in a manner that
minimizes the need for further maintenance, and
controls, minimizes or eliminates, to the extent
necessary to protect human health and the
environment, post-closure escape of hazardous
waste, hazardous constituents, leachate,
contaminated run-off, or hazardous waste
decomposition products to the ground or surface
waters or to the atmosphere.
Closure of units which contain sediments which are
characteristic hazardous wastes, or which are sufficiently
similar to hazardous wastes, would attain compliance
with this standard.
1
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ATTACHMENT 2 -LOWER SOUTH POND (LSP) SEDIMENTS DREDGING AND OFF-SITE DISPOSAL,
AND RESTORATION OF ALL DISTURBED AREAS
ACTION-SPECIFIC ARARs (cont.)
AUTHORITY
REQUIREMENT
STATUS
REQUIREMENT SYNOPSIS
ACTIONS TO BE TAKEN TO ATTAIN REQUIREMENT
Federal Regulatory
Requirements (cont.)
Clean Water Act,
National Pollutant
Discharge Elimination
System (NPDES),40
CFR 122 and 450
Applicable for
discharge to
surface water
standards;
Stormwater
standards
Applicable for
over one acre,
Relevant and
Appropriate for
under one acre
Regulates the discharge of water into public
surface waters. Major requirements include the
following:
Use of best available technology economically
achievable is required to control toxic and non-
conventional pollutants. Use of best
conventional pollutant control technology is
required to control conventional pollutants.
Technology-based limitations may be
determined on a case-by-case basis.
Applicable federally-approved state water
quality standards must be complied with.
These standards may be in addition to or more
stringent than other federal standards under
the CWA.
Requires the use of best practicable technology
(as defined at 40 C.F.R. 450.21) for disturbances
of less than 10 acres and best available technology
(as defined at 40 C.F.R. 450.22) for disturbance of
over 10 acres to control stormwater discharges
from construction activity.
Design specifications for the removal methods and
procedures and design of the dewatering treatment
system would ensure compliance with applicable
discharge standards to protect surface waters.
The best practicable technology (as defined by the
regulations) will be used to meet stormwater
requirements.
Clean Water Act,
Section 304(1 )(1)
National
Recommended Water
Quality Criteria
Relevant and
Appropriate
Provides surface water quality standards for a
number of organic and inorganic contaminants.
Water quality criteria will be used to establish monitoring
standards for the remedial action to protect surface
water quality.
Clean Air Act (CAA),
Hazardous Air
Pollutants, 42.U.S.C. §
112(b)(1), National
Emission Standards for
Hazardous Air
Pollutants (NESHAPS),
40 C.F.R. Part 61
Applicable
The regulations establish emissions standards for
189 hazardous air pollutants. Standards set for
dust and other release sources.
Dust and other emissions exceeding regulatory
standards will be controlled during the implementation of
the remedial action. Air monitoring may be implemented
if determined to be necessary.
2
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ATTACHMENT 2 -LOWER SOUTH POND (LSP) SEDIMENTS DREDGING AND OFF-SITE DISPOSAL,
AND RESTORATION OF ALL DISTURBED AREAS
ACTION-SPECIFIC ARARs (cont.)
AUTHORITY
REQUIREMENT
STATUS
REQUIREMENT SYNOPSIS
ACTION TO BE TAKEN TO ATTAIN REQUIREMENT
State Regulatory
Requirements
Massachusetts Surface
Water Quality
Standards 314 CMR
4.00
Applicable
These standards designate the most sensitive
uses for which the various waters of the
Commonwealth shall be enhanced, maintained, or
protected. Minimum water quality criteria required
to sustain the designated uses are established.
Federal NRWQCs are to be considered in
determining effluent discharge limits. Where
recommended limits are not available, site-specific
limits shall be developed.
Will comply with this ARAR through the use of
engineering controls and protective construction
methods and procedures that will be specified during the
pre-design and design phase of remediation. Treatment
standards and methods would be instituted for sediment
dewatering effluent. Will also be used to establish
monitoring standards for the remedial action to protect
surface water quality.
Water Quality
Certification for
Discharge of Dredged
or Fill Material,
Dredging and Dredged
Material Disposal in
Waters of the United
States within the
Commonwealth, 314
CMR 9.06
Applicable
For discharge of dredged or fill material, there must
be no practicable alternative with less adverse
impact on aquatic ecosystem; must take
practicable steps to minimize adverse impacts on
wetlands or land underwater; stormwater
discharges must be controlled with BMPs; must be
no substantial adverse impact to physical,
chemical, or biological integrity of surface waters.
Will be attained because (a) there is no practicable
alternative method with less adverse impact on the
aquatic ecosystem; (b) all practical measures would be
taken to minimize adverse impacts on wetlands and land
underwater; (c) stormwater discharges would be
controlled through BMPs; and (d) there would be no
substantial long-term adverse impacts to integrity of
surface waters.
Water Quality
Certification for
Discharge of Dredged
or Fill Material,
Dredging and Dredged
Material Disposal in
Waters of the United
States within the
Commonwealth, 314
CMR 9.07
Applicable
Hydraulic or mechanical dredging allowed; must
avoid fisheries impacts.
There are no significant fisheries in area at present,
water quality will be protected by best management
practices during the dredging and filling operations, and
aquatic habitat will be restored.
3
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ATTACHMENT 2 -LOWER SOUTH POND (LSP) SEDIMENTS DREDGING AND OFF-SITE DISPOSAL,
AND RESTORATION OF ALL DISTURBED AREAS
ACTION-SPECIFIC ARARs (cont.)
AUTHORITY
REQUIREMENT
STATUS
REQUIREMENT SYNOPSIS
ACTIONS TO BE TAKEN TO ATTAIN REQUIREMENT
State Regulatory
Requirements
(cont.)
Massachusetts Surface
Water Discharge Permit
Regulations, 314 CMR
3.00
Applicable
Regulates the discharge of water into public
surface waters, allows Commonwealth to establish
state standards under federal NPDES program.
See above discussion of federal NPDES requirements.
Mass. Hazardous
Waste Regulations
(Storage of Hazardous
Waste), 310 CMR
30.300, 30.680, 30.690
310 CMR 30.340
Applicable
Requirements for long-term storage, transport and
disposal of RCRA hazardous waste in containers
and tank systems
See discussion of federal RCRA Hazardous Waste
Regulations above.
Massachusetts Ambient
Air Quality standards,
310 C.M.R. 6.0
Applicable
These regulations contain standard for fugitive
emissions, dust, and particulates that may be
generated from the remedial action.
Dust and other emissions exceeding regulatory
standards will be controlled during the implementation of
the remedial action. Air monitoring may be implemented
if determined to be necessary.
Massachusetts Air
Pollution Control
Regulations, 310
C.M.R. 7.00
Applicable
These regulations contain standard for fugitive
emissions, dust, and particulates that may be
generated from the remedial action.
Dust and other emissions exceeding regulatory
standards will be controlled during the implementation of
the remedial action. Air monitoring may be implemented
if determined to be necessary.
Criteria, Advisories,
and Guidance
Contaminated
Sediment Remediation
Guidance for
Hazardous Waste
Sites, EPA-540-R-05-
012 OSWER
9355.0-85
(December 2005)
To Be
Considered
Guidance for making remedy decisions for
contaminated sediment sites. Some of the relevant
sections of the guidance address Remedial
Investigations (Ch. 2), FS Considerations (Ch. 3),
and Dredging and Excavation (Ch. 6).
Removal of all contaminated sediment, along with
dewatering and off-site disposal meets guidance
standards for addressing contaminated sediments in the
wetlands (as long as habitat restoration requirements
can be met).
Massachusetts
Sedimentation and
Erosion Control
Guidance
To Be
Considered
Standards for preventing erosion and
sedimentation.
Remedial actions will be managed to control erosion
and sedimentation
4
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ATTACHMENT 2 -LOWER SOUTH POND (LSP) SEDIMENTS DREDGING AND OFF-SITE DISPOSAL,
AND RESTORATION OF ALL DISTURBED AREAS
LOCATION-SPECIFIC ARARs
AUTHORITY
REQUIREMENT
STATUS
REQUIREMENT SYNOPSIS
ACTIONS TO BE TAKEN TO ATTAIN REQUIREMENT
Federal Regulatory
Requirements
Floodplain
Management and
Protection of Wetlands,
44 C.F.R. 9
Relevant and
Appropriate
FEMA regulations that set forth the policy,
procedure and responsibilities to implement and
enforce Executive Order 11988 (Floodplain
Management) and Executive Order 11990
(Protection of Wetlands). Prohibits activities that
adversely affect a federally-regulated wetland
unless there is no practicable alternative and the
proposed action includes all practicable measures
to minimize harm to wetlands that may result from
such use. Requires the avoidance of impacts
associated with the occupancy and modification of
federally-designated 100-year and 500-year
floodplain and to avoid development within
floodplain wherever there is a practicable
alternative. An assessment of impacts to 500-year
floodplain is required for critical actions - which
includes siting hazardous waste facilities in a
floodplain. Requires public notice when proposing
any action in or affecting floodplain or wetlands.
There is no practicable alternative method to work in
federal jurisdictional wetlands with less adverse impact
and all practicable measures would be taken to minimize
and mitigate any adverse impacts. Erosion and
sedimentation control measures would be adopted during
construction and restoration activities within federal
jurisdictional wetlands. Standards for work within
regulated floodplain will be attained in part because (a)
there is no practical alternative method that will achieve
cleanup objectives with less adverse impact; (b) all
practical measures would be taken to minimize and
mitigate any adverse impacts from the work; (c) there
would be no likely impact on T&E species; (d) actions
would be taken to minimize impact of hydrologic changes
during the work; (e) after completion of the work, there
would be no significant net loss of flood storage capacity,
and no significant net increase in flood stage or velocities;
and (f) river and riverbanks would be restored and habitat
will be improved. Public comment is being solicited on this
draft ESD concerning the proposed alteration to wetlands
and floodplain.
5
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ATTACHMENT 2 -LOWER SOUTH POND (LSP) SEDIMENTS DREDGING AND OFF-SITE DISPOSAL,
AND RESTORATION OF ALL DISTURBED AREAS
AUTHORITY
REQUIREMENT
STATUS
REQUIREMENT SYNOPSIS
ACTIONS TO BE TAKEN TO ATTAIN REQUIREMENT
Federal Regulatory
Requirements
(cont.)
Clean Water Act §404,
and regulations, 33
USC 1344, 40CFR,
230
Applicable
For discharge of dredged or fill material into water
bodies or wetlands, there must be no practical
alternative with less adverse impact on aquatic
ecosystem; discharge cannot cause or contribute
to violation of state water quality standard or toxic
effluent standard or jeopardize threatened or
endangered (T&E) species; discharge cannot
significantly degrade waters of U.S.; must take
practicable steps to minimize and mitigate adverse
impacts; must evaluate impacts on flood level,
flood velocity, and flood storage capacity. Sets
standards for restoration and mitigation required
as a result of unavoidable impacts to aquatic
resources. EPA must determine which alternative
is the "Least Environmentally Damaging
Practicable Alternative" (LEDPA) to protect
wetland and aquatic resources.
EPA has determined that the proposed remediation is the
Least Environmentally Damaging Practicable Alternative
(LEDPA) because (a) there is no practical alternative
method that will achieve cleanup objectives with less
adverse impact; (b) all practical measures would be taken
to minimize and mitigate any adverse impacts from the
work; (c) there would be no likely impact on T&E species;
(d) actions would be taken to minimize impact of
hydrologic changes during the work; (e) after completion of
the work, there would be no significant net loss of flood
storage capacity, and no significant net increase in flood
stage or velocities; and (f) river and riverbanks would be
restored and habitat will be improved. Public comment is
being solicited on this draft ESD concerning EPA's LEDPA
finding.
Fish and Wildlife
Coordination Act
16 USC 662, 663
Applicable
Requires consultation with appropriate agencies to
protect fish and wildlife when federal actions may
alter waterways. Must develop measures to
prevent and mitigate potential loss to the
maximum extent possible.
Consultations with the USFWS will be made during the
design phase. Measures to mitigate or compensate
adverse project related impacts to fish and wildlife
resources will betaken, if determined necessary.
State Regulatory
Requirements
Massachusetts
Wetlands Protection
Act and Regulations,
MGL c. 131 §40, 310
CMR 10.00
Applicable
Regulations restrict dredging, filling, altering, or
polluting inland wetland resource areas and buffer
zones and impose performance standards for work
in such areas. Protected resource areas include:
10.54 (Bank); 10.55 (Bordering Vegetated
Wetlands); 10.56 (Land underWater); 10.57
(Bordering Land subject to Flooding); and 10.58
(Riverfront Area).
Will be attained because (a) there is no practicable
alternative that would be less damaging to resource areas;
(b) all practical measures will be taken to minimize
adverse impacts on wetlands; (c) stormwater discharges
will be controlled through best management practices
(BMPs); (d) actions will be taken to minimize impact of
hydrologic changes during the work to the extent
practicable; (e) after completion of the work, there will be
no significant net loss of flood storage capacity and no
significant net increase in flood storage or velocities; and
(f) disturbed vegetation, river, and riverbank will be
restored.
6
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ATTACHMENT 2 -LOWER SOUTH POND (LSP) SEDIMENTS DREDGING AND OFF-SITE DISPOSAL,
AND RESTORATION OF ALL DISTURBED AREAS
CHEMICAL-SPECIFIC ARARs
AUTHORITY
REQUIREMENT
STATUS
REQUIREMENT SYNOPSIS
ACTIONS TO BE TAKEN TO ATTAIN REQUIREMENT
Criteria, Advisories,
and Guidance
Canadian Council of
Ministers of the
Environment (CCME).
1999. Canadian water
quality guidelines for
the protection of
aquatic life: Benzene.
In: Canadian
environmental quality,
1999, Canadian
Council of Ministers of
the Environment,
Winnipeg.
To Be
Considered
Guidance used to develop benzene sediment
cleanup level based on the water quality
guidelines and site specific calculation of a
sediment benchmark for the protection of
freshwater aquatic life due to chronic exposure.
All sediments exceeding the cleanup standard for
benzene will be removed from the wetland and disposed
of off-site. Confirmatory sampling will be used to ensure
all sediments exceeding the standard are removed.
7
-------
Attachment 3
Tables of Revised Applicable and Relevant and Appropriate Standards (ARARs)
-------
ATTACHMENT 3 - CHANGES IN APPLICABLE OR RELEVANT AND APPROPRIATE REQUIREMENTS (ARARs)
FROM THE 2006 ROD
LOCATION-SPECIFIC ARARs
AUTHORITY
REQUIREMENT
STATUS
REQUIREMENT SYNOPSIS
CHANGE FROM 2006 ROD
ROD TABLES
WHERE LOCATED
Federal
Regulatory
Requirements
FloodDlain
Manaaement and
Protection of
Wetlands. 44 C.F.R. 9
Changed
Relevant and
Appropriate
FEMA regulations that set forth the policy,
procedure and responsibilities to
implement and enforce Executive Order
11988 (Floodplain Management) and
Executive Order 11990 (Protection of
Wetlands). Prohibits activities that
adversely affect a federally-regulated
wetland unless there is no practicable
alternative and the proposed action
includes all practicable measures to
minimize harm to wetlands that may result
from such use. Requires the avoidance
of impacts associated with the occupancy
and modification of federally-designated
100-year and 500-year floodplain and to
avoid development within floodplain
wherever there is a practicable
alternative. An assessment of impacts to
500-year floodplain is required for critical
actions - which includes siting hazardous
waste facilities in a floodplain. Requires
public notice when proposing any action
in or affecting floodplain or wetlands.
The ROD cited regulations in the Action- and
Location-Specific ARARs tables for components
of the ROD remedy affecting wetlands/
floodplain at 40 C.F.R. Part 6, Appendix A and
40 C.F.R. 6.302(a) and 6.302(b). These
regulations have been removed from the Code
of Federal Regulations. The new regulatory
ARAR citation at 44 C.F.R. 9 is added for each
component of the remedy, which formerly cited
40 C.F.R Part 6, Appendix A and 40 C.F.R.
6.302(a) and 6.302(b).
Through this ESD these regulations are added
as Location-Specific ARARs in Tables D-7 and
D-8 because the remedial activities addressed in
these areas occur within or adjacent to federal
jurisdictional wetlands and/or floodplain.
D-1, D-2, D-3, D-4, D-
5, D-6
Added: D-7, D-8
Statement of
Procedures on
40 CFR Part 6, App.
A, Exoc. Ordor 11000
(1077)
AO CFR 6.302(a)
and
Executive Order for
Floodplain
Management
Exec. Order 11988
(1077)
40 CFR Part 6, App.
A.,40 CFR 6.302(b)
-------
ATTACHMENT 3 - CHANGES IN APPLICABLE OR RELEVANT AND APPROPRIATE REQUIREMENTS (ARARs)
FROM THE 2006 ROD
LOCATION-SPECIFIC ARARs
AUTHORITY
REQUIREMENT
STATUS
REQUIREMENT SYNOPSIS
CHANGE FROM 2006 ROD
ROD TABLES
WHERE LOCATED
Federal
Regulatory
Requirements
(cont.)
Clean Water Act
§404, and regulations,
33 U.S.C. 1344, 40
C.F.R., 230
Moved
Applicable
For discharge of dredged or fill material
into water bodies or wetlands, there must
be no practical alternative with less
adverse impact on aquatic ecosystem;
discharge cannot cause or contribute to
violation of state water quality standard or
toxic effluent standard or jeopardize
threatened or endangered (T&E) species;
discharge cannot significantly degrade
waters of U.S.; must take practicable
steps to minimize and mitigate adverse
impacts; must evaluate impacts on flood
level, flood velocity, and flood storage
capacity. Sets standards for restoration
and mitigation required as a result of
unavoidable impacts to aquatic
resources. EPA must determine that the
remedial action is the "Least
Environmentally Damaging Practicable
Alternative" (LEDPA) to protect wetland
and aquatic resources.
In the ROD identified in the Action-specific
ARARs tables for components of the ROD
remedy involving dredging/filling in federal
jurisdictional wetlands; moved to Location-
specific ARARs tables for each component of
the ROD remedy involving dredging/filling in
federal jurisdictional wetlands.
D-5, D-6
RCRA Floodplain
Restrictions for Solid
Waste Disposal
Facilities and
Practices, 40 C.F.R.
257.3-1
Relevant and
Appropriate
Solid waste practices must not restrict the
flow of a 100-year flood, reduce the
temporary water storage capacity of the
floodplain or result in washout of solid
waste, so as to pose a hazard to human
life, wildlife, or land or water resources.
No change from the ROD.
D-5, D-6
2
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ATTACHMENT 3 - CHANGES IN APPLICABLE OR RELEVANT AND APPROPRIATE REQUIREMENTS (ARARs)
FROM THE 2006 ROD
LOCATION-SPECIFIC ARARs
AUTHORITY
REQUIREMENT
STATUS
REQUIREMENT SYNOPSIS
CHANGE FROM THE 2006 ROD
ROD TABLES
WHERE LOCATED
Federal
Regulatory
Requirements
(cont.)
RCRA Floodplain
Restrictions for
Hazardous Waste
Facilities,
40 C.F.R. 264.18(b)
Relevant and
Appropriate
A hazardous waste treatment, storage, or
disposal facility located in a 100-year
floodplain must be designed, constructed,
operated, and maintained to prevent
washout or to result in no adverse effects
on human health or the environment if
washout were to occur.
No change from the ROD.
Fish and Wildlife
Coordination Act
regulations,
16 USC 662, 663
40 CFR 6.302(g)
Applicable
Requires consultation with appropriate
agencies to protect fish and wildlife when
federal actions may alter waterways.
Must develop measures to prevent and
mitigate potential loss to the maximum
extent possible.
The ROD cited these regulations for
components of the ROD remedy affecting
fish/wildlife habitat at 40 CFR 6.302(g). These
regulations have been removed from the Code
of Federal Regulations. Only the remaining
statutory requirements at 16 U.S.C. 662, 663
are retained for each component of the remedy
affecting fish/wildlife habitat.
D-5, D-6
State Regulatory
Requirements
Massachusetts
Wetlands Protection
Act and Regulations,
MGL c. 131 §40, 310
CMR 10.00
Applicable
Regulations restrict dredging, filling,
altering, or polluting inland wetland
resource areas and impose performance
standards for work in such areas.
Protected resource areas include: 10.54
(Bank); 10.55 (Bordering Vegetated
Wetlands); 10.56 (Land underWater);
10.57 (Bordering Land subject to
Flooding); and 10.58 (Riverfront Area).
Through this ESD these regulations are added
as Location-Specific ARARs in Tables D-7 and
D-8 because the remedial activities addressed
in these areas occur within or adjacent to state
jurisdictional wetlands and/or buffer zone.
D-1, D-2, D-3, D-4,
Added: D-7, D-8
3
-------
ATTACHMENT 3 - CHANGES IN APPLICABLE OR RELEVANT AND APPROPRIATE REQUIREMENTS (ARARs)
FROM THE 2006 ROD
CHEMICAL-SPECIFIC ARARs
AUTHORITY
REQUIREMENT
STATUS
REQUIREMENT SYNOPSIS
CHANGE FROM 2006 ROD
ROD TABLES
WHERE LOCATED
Federal
Regulatory
Requirements
Clean Water Act,
Ambient Water Quality
Criteria, 33 U.S.C. §
1314, 40 C.F.R.
131.36(b)(1)
Applicable
National recommended criteria for surface
water quality.
No change from the ROD, although currently
referred to as "National Recommended Water
Quality Criteria" (NRWQC).
D-3, D-4, D-5, D-6
State Regulatory
Requirements
Massachusetts
Contingency Plan
(MCP), 310 C.M.R.
Applicable
The MCP has established a set of risk-
based threshold concentrations (UCLs)
that must be attained in order to achieve a
condition of no significant risk for
groundwater or soil within a particular
groundwater classification area.
The ROD cited the Status of these standards as
"To Be Considered." The Status is changed to
"Applicable" because these are promulgated
standards within the MCP regulations.
D-1, D-2, D-3, D-4
Massachusetts
Surface Water Quality
Standards, 314
C.M.R. 4.05(5)(e)
Applicable
Establishes federal water quality criteria as
allowable water quality concentrations.
Allows for site-specific criteria where
federal criteria are invalid due to site-
specific characteristics.
No change for the ROD citations in Tables D-3,
D-4, D-5, and D-6.
The ROD cites these regulations in both
Chemical-Specific and Action-Specific ARARs in
Tables D-7 and D-8. Removed as Chemical-
Specific ARARs (not used to develop numeric
cleanup standards) and retained as Action-
Specific Standards for monitoring surface waters.
D-3, D-4, D-5, D-6
Removed: D-7, D-8
Massachusetts
Groundwater Quality
Standards, 314
C.M.R. 6.00
Applicable
These standards designate and assign
uses for which groundwater in the
Commonwealth shall be managed and
protected, and set forth water quality
criteria necessary to maintain the
designated areas.
No change from the ROD.
D-4
4
-------
ATTACHMENT 3 - CHANGES IN APPLICABLE OR RELEVANT AND APPROPRIATE REQUIREMENTS (ARARs)
FROM THE 2006 ROD
CHEMICAL-SPECIFIC ARARs
AUTHORITY
REQUIREMENT
STATUS
REQUIREMENT SYNOPSIS
CHANGE FROM 2006 ROD
ROD TABLES
WHERE LOCATED
State Regulatory
Requirements
(cont.)
Massachusetts
Ambiont Air Quality
standards (310
C.M.R. 6.0) and
Massachusetts Air
Pollution Control
Regulations (310
C.M.R. 7.00
Moved
This regulation also contains standards for
fugitive emissions, dust, and particulates
during construction.
The ROD cited these as Chemical-Specific
ARARs. Moved to the Action-Specific ARARs
table because the standards regulate emissions,
rather than establishing specific cleanup levels.
D-4
Criteria,
Advisories, and
Guidance
Cancer Slope Factors
(CSFs)
To Be
Considered
Guidance values used to evaluate the
potential carcinogenic risk caused by
exposure to contaminants.
No change from the ROD.
D-1, D-2, D-3, D-4
Reference Doses
(RfDs)
To Be
Considered
Guidance values used to evaluate the
potential non-carcinogenic hazard caused
by exposure to contaminants.
No change from the ROD.
D-1, D-2, D-3, D-4
EPA Health
Advisories, Human
Health Risk
Assessment
Guidance, and
Ecological Risk
Assessment Guidance
To Be
Considered
These advisories and guidance documents
provide guidance for developing health risk
information and environmental
assessments at Superfund sites.
No change from the ROD
D-1, D-2, D-3, D-4,
D-5, D-6
1999 Update of
Ambient Water Quality
Criteria for Ammonia,
EPQ-822-R-99-014
To Be
Considered
Ammonia water quality criteria for adjusted
for temperature and pH in accordance with
this guidance.
Cited in the ARARs tables in the Clean Water
Act, Ambient Water Quality Criteria synopsis.
D-3, D-4, D-5
5
-------
ATTACHMENT 3 - CHANGES IN APPLICABLE OR RELEVANT AND APPROPRIATE REQUIREMENTS (ARARs)
FROM THE 2006 ROD
ACTION-SPECIFIC ARARs
AUTHORITY
REQUIREMENT
STATUS
REQUIREMENT SYNOPSIS
CHANGE FROM THE 2006 ROD
ROD TABLES
WHERE LOCATED
Federal
Regulatory
Requirements
RCRA Identification
and Listing of
Hazardous Wastes,
40 C.F.R. 261.3
Applicable
Criteria for determining if a waste or
contaminated media is a hazardous waste
subject to regulation. If a contaminated
media exhibits the characteristics of a
hazardous waste, RCRA hazardous waste
regulations are applicable.
The Status of these standards is only Applicable
(the ROD lists as either being Applicable or
Relevant and Appropriate).
Add to Table D-2.
D-1, D-5, D-6
Added: D-2
RCRA Closure and
Post-Closure
Requirements, 40
C.F.R. Part 264.
Subpart G
Applicable
If contaminated sediments constitute
characteristic hazardous waste these
regulations are applicable. Closure must be
completed in a manner that minimizes the
need for further maintenance, and controls,
minimizes or eliminates, to the extent
necessary to protect human health and the
environment, post-closure escape of
hazardous waste, hazardous constituents,
leachate, contaminated run-off, or
hazardous waste decomposition products to
the ground or surface waters or to the
atmosphere.
The Status of these standards is Applicable (the
ROD lists as Relevant and Appropriate).
D-1, D-2, D-5, D-6
RCRA-
Groundwater
Monitoring, 40
C.F.R. Part 264.
Subpart F
Relevant and
Appropriate
This regulation details the requirements for
groundwater monitoring and responding to
releases from solid waste management
units.
No change from the ROD.
D-1, D-2, D-3, D-4
6
-------
ATTACHMENT 3 - CHANGES IN APPLICABLE OR RELEVANT AND APPROPRIATE REQUIREMENTS (ARARs)
FROM THE 2006 ROD
ACTION-SPECIFIC ARARs
AUTHORITY
REQUIREMENT
STATUS
REQUIREMENT SYNOPSIS
CHANGE FROM THE 2006 ROD
ROD TABLES
WHERE LOCATED
Federal
Regulatory
Requirements
(cont)
RCRA Hazardous
Waste Regulations
(Storage and
Disposal of
Hazardous Waste)
40 CFR Part 262,
Subpart A, 40 C.F.R.
Part 264, Subparts 1
and J.
Applicable
Subpart A of Part 262 provides that a
generator who treats, stores, or disposes of
hazardous waste on-site must determine
whether or not he has a hazardous waste,
obtain an EPA identification number for any
hazardous waste and comply with the
regulations regarding accumulation of
hazardous waste and recordkeeping.
Subparts 1 and J of Part 264 identify design,
operating, monitoring, closure, and post-
closure care requirements for long-term
storage of RCRA hazardous waste in
containers and tank systems, respectively.
However, Section 262.34(a) allows
accumulation of RCRA hazardous wastes
for up to 90 days in containers or tanks
provided generator complies with
requirements of Subparts 1 and J of Part
265.
No change from the ROD
D-5, D-6
7
-------
ATTACHMENT 3 - CHANGES IN APPLICABLE OR RELEVANT AND APPROPRIATE REQUIREMENTS (ARARs)
FROM THE 2006 ROD
ACTION-SPECIFIC ARARs
AUTHORITY
REQUIREMENT
STATUS
REQUIREMENT SYNOPSIS
CHANGE FROM THE 2006 ROD
ROD TABLES
WHERE LOCATED
Federal
Regulatory
Requirements
(cont.)
Clean Water Act,
National Pollutant
Discharge Elimination
System (NPDES),40
C.F.R. Parts 122 and
450
Applicable for
discharge to
surface water
standards;
Stormwater
standards
Applicable for
over one
acre,
Relevant and
Appropriate
for under one
acre
Regulates the discharge of water into public
surface waters. Major requirements include
the following:
Use of best available technology
economically achievable is required to
control toxic and non-conventional
pollutants. Use of best conventional
pollutant control technology is required
to control conventional pollutants.
Technology-based limitations may be
determined on a case-by-case basis.
Applicable federally-approved state
water quality standards must be
complied with. These standards may
be in addition to or more stringent than
other federal standards under the CWA.
Requires the use of best practicable
technoloqv (as defined at 40 C.F.R.
450.21) for disturbances of less than 10
acres and best available technoloav (as
defined at 40 C.F.R. 450.22) for
disturbance of over 10 acres to control
stormwater discharqes from
construction activity.
Added to the Action-Specific ARARs table at D-4
where there may be discharges to surface waters
The Status of the discharge to surface water
standards is Applicable (the ROD lists as
Relevant and Appropriate).
This ESD adds NPDES stormwater regulations
for construction activity at 40 C.F.R. 450 not
promulgated at the time of the ROD.
D-5, D-6
Added: D-4
Clean Water Act,
Section 304(1 )(1)
National
Recommended
Water Quality Criteria
Relevant and
Appropriate
Provides surface water quality standards for
a number of organic and inorganic
contaminants.
Added as surface water/sediment monitoring
standards for remedy components (Tables D-3,
D-4, D-5, D-6) where remedial activities may alter
water quality (including stormwater impacts).
D-7, D-8
Added: D-3, D-4 , D-
5, D-6
Underq round
Iniection Control, 40
C.F.R. 144. 146. 147
Relevant and
Appropriate
Establishes standards to prevent
underground injection from endangering
drinking water sources.
Not cited in the ROD.
Added as protective standards for remedy
components that involve in-situ treatment of
groundwater.
Added: D-4
8
-------
ATTACHMENT 3 - CHANGES IN APPLICABLE OR RELEVANT AND APPROPRIATE REQUIREMENTS (ARARs)
FROM THE 2006 ROD
ACTION-SPECIFIC ARARs
AUTHORITY
REQUIREMENT
STATUS
REQUIREMENT SYNOPSIS
CHANGE FROM THE 2006 ROD
ROD TABLES
WHERE LOCATED
Federal
Regulatory
Requirements
(cont.)
Clean Air Act (CAA).
Hazardous Air
Pollutants. 42.U.S.C.
§ 112(b)(1). National
Emission Standards
for Hazardous Air
Pollutants
(NESHAPS). 40
C.F.R. Part 61
Applicable
The regulations establish emissions
standards for 189 hazardous air pollutants.
Standards set for dust and other release
sources.
Not cited in the ROD.
Added as air monitoring and control standards for
remedy components (Tables D-3, D-4, D-5, D-6)
where remedial activities may generate dust or
emissions of regulated air pollutants.
Added: D-3, D-4, D-5,
D-6
State
Regulatory
Requirements
Massachusetts
Surface Water
Quality Standards
314 CMR 4.00
Applicable
These standards designate the most
sensitive uses for which the various waters
of the Commonwealth shall be enhanced,
maintained, or protected. Minimum water
quality criteria required to sustain the
designated uses are established. Federal
NRWQC are to be considered in
determining effluent discharge limits. Where
recommended limits are not available, site-
specific limits shall be developed.
Added as surface water/sediment monitoring
standards for remedy components (Tables D-3,
D-4, D-5, D-6) where remedial activities may alter
water quality (including stormwater impacts).
In the ROD, specifically cited as 4.05(5)(e) in
Tables D-5, D-7, and D-8. All of Section 4.00 is
applicable to the remedial activities addressed
under these tables.
D-5, D-6, D-7, D-8
Added: D-3, D-4
Water Quality
Certification for
Discharge of
Dredged or Fill
Material, Dredging
and Dredged Material
Disposal in Waters of
the United States
within the
Commonwealth, 314
CMR 9.06
Applicable
For discharge of dredged or fill material,
there must be no practicable alternative with
less adverse impact on aquatic ecosystem;
must take practicable steps to minimize
adverse impacts on wetlands or land under
water; stormwater discharges must be
controlled with BMPs; must be no
substantial adverse impact to physical,
chemical, or biological integrity of surface
waters.
No change from the ROD.
D-5, D-6
9
-------
ATTACHMENT 3 - CHANGES IN APPLICABLE OR RELEVANT AND APPROPRIATE REQUIREMENTS (ARARs)
FROM THE 2006 ROD
ACTION-SPECIFIC ARARs
AUTHORITY
REQUIREMENT
STATUS
REQUIREMENT SYNOPSIS
CHANGE FROM 2006 ROD
ROD TABLES
WHERE LOCATED
State Regulatory
Requirements
(cont.)
Water Quality
Certification for
Discharge of
Dredged or Fill
Material, Dredging
and Dredged
Material Disposal
in Waters of the
United States
within the
Commonwealth,
314 CMR 9.07
Applicable
Hydraulic or mechanical dredging allowed;
must avoid fisheries impacts.
No change from the ROD.
D-5, D-6
Massachusetts
Surface Water
Discharge Permit
Regulations, 314
C.M.R. 3.00
Applicable
Regulates the discharge of water into public
surface waters, allows Commonwealth to
establish state standards under federal
NPDES program.
The ROD cited these regulations in the Action-
and Chemical-Specific ARARs tables for
components of the ROD remedy affecting
discharges to surface waters (Tables D-5, D-6).
Removed from the Chemical-Specific ARARs
tables.
D-5, D-6
Underaround
Iniection Control.
310 C.M.R. 27
Relevant and
Appropriate
Establishes standards to prevent
underground injection from endangering
drinking water sources.
Not cited in the ROD.
Added as protective standards for remedy
components that involve in-situ treatment of
groundwater.
Added: D-4
Massachusetts
Groundwater
Discharge Permit
Program, 314,
C.M.R. 5.00
Moved
Relevant and
Appropriate
Groundwater discharges shall not result in a
violation of Massachusetts Surface Water
Quality Standards or Massachusetts
Groundwater Quality Standards.
The ROD cited these as Chemical-Specific
ARARs. Moved to the Action-Specific ARARs
table because the standards regulate discharges,
rather than establishing specific cleanup levels.
D-4
10
-------
ATTACHMENT 3 - CHANGES IN APPLICABLE OR RELEVANT AND APPROPRIATE REQUIREMENTS (ARARs)
FROM THE 2006 ROD
ACTION-SPECIFIC ARARs
AUTHORITY
REQUIREMENT
STATUS
REQUIREMENT SYNOPSIS
CHANGE FROM THE 2006 ROD
ROD TABLES
WHERE LOCATED
State Regulatory
Requirements
(cont.)
Mass. Hazardous
Waste
Regulations
(Storage of
Hazardous
Waste), 310 CMR
30.300, 30.680,
30.690
310 CMR 30.340
Relevant and
Appropriate
Requirements for long-term storage,
transport and disposal of RCRA hazardous
waste in containers and tank systems
No change from the ROD
D-5, D-6
Massachusetts
Ambient Air
Quality standards
(310 C.M.R. 6.0)
and
Massachusetts Air
Pollution Control
Regulations (310
C.M.R. 7.00
Moved
Applicable
These regulations also contains standards
for fugitive emissions, dust, and particulates
during construction.
The ROD cited these as Chemical-Specific
ARARs. Moved to the Action-Specific ARARs
table because the standards regulate emissions,
rather than establishing specific air cleanup
levels.
D-4
Criteria,
Advisories, and
Guidance
Contaminated
Sediment
Remediation
Guidance for
Hazardous Waste
Sites. EPA-540-R-
05-012 OSWER
9355.0-85
(December 2005)
To Be
Considered
Guidance for making remedy decisions for
contaminated sediment sites. Some of the
relevant sections of the guidance address
Remedial Investigations (Ch. 2), FS
Considerations (Ch. 3), and Dredging and
Excavation (Ch. 6).
Not cited in the ROD.
Added: D-5, D-6, D-7,
D-8
Massachusetts
Sedimentation
and Erosion
Control Guidance
To Be
Considered
Standards for preventing erosion and
sedimentation.
Not cited in the ROD.
Added: D-1, D-2, D-3,
D-4, D-5, D-6, D-7, D-
8
11
-------
Attachment 4
Cost Evaluation
-------
Attachment 4 - Cost Evaluation
Explanation of Significant Differences (ESD)
Industri-Plex Superfund Site, Operable Unit 2
August 2014
|Task Bid Item Notes
1 Mobilization/site prep
EA
1
office trailer/facilities
mo
2
$
25,000.00
$
50,000.00
Temporary utilities
Is
1
$
10,000.00
$
10,000.00
Mobilization
Is
1
$
10,000.00
$
10,000.00
Abandon Monitoring Wells in-place 8-10' each
well
6
$
1,000.00
$
6,000.00
Monitoring well protection
well
2
$
1,000.00
$
2,000.00
take-off from drawings (est avg
access road material
ton
1350
$
25.00
$
33,750.00
thickness at 3')
Staging area material
ton
1000
$
25.00
$
25,000.00
Materials placement and removal
ton
3200
$
15.00
$
48,000.00
Geotextile under roads
2250 sqft/roll
15
$
600.00
$
9,000.00
Survey (layout, construction control and as-builts)
Is
1
$
15,000.00
$
15,000.00
Construction OA/Field Eng
hr
352
$
75.00
$
26,400.00
2 Portadam/cofferdam
first month minimum rental period plus shipping
mo
1
$
28,000.00
$
28,000.00
250 LF Measured off of drawings
in-water crew, on-site, 10-hour weekday
day
5
$
4,200.00
$
21,000.00
crew travel expenses, each roundtrip
day
5
$
2,500.00
$
12,500.00
3 Dewatering
Slug Test
ea
1
$
5,000.00
$
5,000.00
pump test
ea
1
$
20,000.00
$
20,000.00
O&M
ea
1
$
50,000.00
$
50,000.00
turbidity curtains
If
250
$
30.00
$
7,500.00
take-off from drawings
straw wattles/erosion control
If
2000
$
5.00
$
10,000.00
take-off from drawings
4 Water Treatment System
cost from AECOM similar project
Carbon (10,000 pound)
per/gac
2
$
17,500.00
$
35,000.00
take-off from drawings
Sand Filter
per/filter
2
$
2,000.00
$
4,000.00
20,000 gal Frac tanks
per/tank
4
$
1,500.00
$
6,000.00
Tow Behind Pumps
per/pump
4
$
4,000.00
$
16,000.00
Oversight Set Up / Break Man
ea
1
$
20,000.00
$
20,000.00
5 Excavation & Backfill
mud mats
LS
1
$
5,000.00
$
5,000.00
300SF area measured off of drawing
excavator
mo
1
$
7,000.00
$
7,000.00
loader
mo
1
$
4,500.00
$
4,500.00
operator (3)
day
22
$
2,250.00
$
49,500.00
backfill
cy
900
$
15.00
$
13,500.00
0.5 W by 125'L x 8' H = 500CF
Aquagate and PAC
ton
21
$
650.00
$
13,650.00
85#/cuft = 42,000# = 21 tons
geotextile
Is
1
$
1,000.00
$
1,000.00
6 Material Disposal
Excavated Sediment
CY
900
(factor 1.6 tons per CY)
ton
1440
Portland Cement (amendment)
ton
144
$
95.00
$
13,680.00
Disposal
ton
1584
$
125.00
$
198,000.00
7 Restoration, Monitoring, Demobilization
Confirmatory Sampling and analysis
LS
1
$
20,000.00
$
20,000.00
Air Monitoring equipment
LS
1
$
15,000.00
$
15,000.00
Sampler, enviro tech
day
30
$
1,500.00
$
45,000.00
revegetation
SF
10000
$
1.00
$
10,000.00
8 Subtotal
$
865,980.00
Profit
%
0.15
$
129,897.00
taxes
%
0.07
$
86,598.00
Contingency
%
0.3
$
259,794.00
Total
s
1,342,269.00
-30%
s
939,588.30
+50%
s
2,013,403.50
-------
Attachment 5
MassDEP ESD Letter of Support
------- |