EPA/AMD/R01-99/001
1999

EPA Superfund

Record of Decision Amendment:

NEW BEDFORD
EPA ID: MAD980731335
OU 02

NEW BEDFORD, MA
04/27/1999


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NEW BEDFORD HARBOR SUPERFUND SITE
HOT SPOT OPERABLE UNIT
FINAL DRAFT AMENDED RECORD OF DECISION

April 1999

U.S. Environmental Protection Agency - Region I
New England


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DECLARATION FOR THE AMENDED RECORD OF DECISION

NEW BEDFORD HARBOR SUPERFUND SITE
HOT SPOT OPERABLE UNIT

STATEMENT OF PURPOSE

This decision document amends the selected remedial action for the New Bedford Harbor
Superfund Site, Hot Spot Operable Unit located in New Bedford, Massachusetts, as outlined in
the April 6, 1990 Record of Decision, and is developed in accordance with the Comprehensive
Environmental Response, Compensation and Liability Act of 1980 (CERCLA), 42 USC Part
9601 et seq.. as amended, and to the extent practicable, the National Oil and Hazardous
Substances Contingency Plan (NCP), 40 CFR Part 300 et seq.. as amended. The Director of the
Office of Site Remediation and Restoration has been delegated the authority to approve the
Amended Record Of Decision (ROD).

The Commonwealth of Massachusetts concurs with the selected remedy.

STATEMENT OF BASIS

This decision is based on the Administrative Record which has been developed in accordance
with Section 113 (k) of CERCLA and which is available for public review at the Wilks Branch
Library in New Bedford, Massachusetts and at the USEPA - Region I Office of Site Remediation
and Restoration Records Center in Boston, Massachusetts. The Administrative Record Index
(Appendix B to the Amended ROD) identifies each of the items comprising the Administrative
Record upon which the selection of the remedial action is based.

ASSESSMENT OF THE STTE

Actual or threatened releases of hazardous substances from this Site, if not addressed by
implementing the response action selected in this Amended ROD, may present an imminent and
substantial endangerment to the public health or welfare or to the environment.

DESCRIPTION OF THE SELECTED REMEDY

This decision document amends portions of EPA's 1990 ROD for the Hot Spot Operable Unit.
The 1990 ROD called for dredging contaminated sediments from the identified hot spot areas
with PCB concentrations of 4,000 ppm or greater, transporting the dredged sediments to a

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shoreline Confined Disposal Facility (CDF), treatment of the supernatant, dewatering the
sediments and destruction of the PCBs in an on-site incinerator. The ash generated from the
incineration process was to be solidified/stabilized if necessary and permanently contained in the
on-site CDF. A more detailed description of the 1990 remedy is provided in Section V of this
decision document. The activities associated with dredging the hot spot areas and treating the
supernatant have been completed. This decision document selects off-site landfilling instead of
on-site incineration. The modified remedy consists of the following activities:

1.	Upgrade Existing Site Facilities As Needed. To accommodate sediment handling and
dewatering activities it may be necessary to construct or improve access to the CDF and other
areas of the site. Treatment pads, temporary buildings and upgrades to site utilities may also be
needed.

2.	Sediment Dewatering and Water Treatment. The hot spot sediments currently stored in
the Sawyer Street CDF are approximately 50% water, which is too wet to be accepted by a TSCA
permitted hazardous waste landfill. The sediments will be dewatered to that level which is in
compliance with the permits and other requirements for the selected off-site TSCA permitted
landfill. Options for dewatering the sediments will be evaluated during the design process. The
sediment may be dewatered in-situ by extracting water via installed well points, or by removing
the sediment from the CDF and mechanically dewatering it ex-situ, or a combination of in-situ
and ex-situ dewatering.

3.	Transportation to an Off-Site TSCA Permitted Landfill. Following dewatering, the
sediments will be loaded into sealed containers for transport to a TSCA permitted off-site
hazardous waste landfill.

4.	Air Monitoring Program. There is a potential for air emissions of PCBs during the
sediment removal and dewatering activities. A comprehensive ambient air monitoring program
will be designed, documented and implemented during the sediment removal and dewatering
operations to ensure that engineering controls are effective at protecting site workers and the local
community.

SPECIAL FINDINGS

Issuance of this ROD Amendment embodies specific determinations made by the Regional
Administrator pursuant to CERCLA. Under section 121 (d)(4)(B) of CERCLA, the Regional
Administrator hereby waives 40 CFR 122.4(i) of the Clean Water Act (a regulation regarding
discharges to polluted water bodies). Due to the nature of the New Bedford Harbor site, full
compliance with this requirement would result in greater risk to human health and the
environment than non-compliance

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DECLARATION

The selected remedy is protective of human health and the environment, attains federal and state
requirements that are applicable or relevant and appropriate for this remedial action, and is cost
effective. The selected remedy provides a permanent solution for the hot spot sediments. While it
does not satisfy the statutory preference for remedies that utilize treatment as a principal element
to reduce the toxicity, mobility or volume of hazardous substances, it does permanently isolate
these sediments from human and environmental receptors by containing them in an off-site TSCA
permitted chemical waste landfill in perpetuity in a safe and protective fashion. In addition, water
removed from the hot spot sediments prior to off-site transportation to a TSCA landfill will be
treated to meet stringent discharge standards.

As the remedy for this operable unit will not result in hazardous substances remaining on site
above health-based levels, site reviews for this operable unit will not be needed every five years.
The remedy selected in the September 1998 ROD for the Upper and Lower Operable Unit of this
Site will result in hazardous substances remaining on site above health-based levels and,
therefore, site reviews will be conducted every five years after commencement of the upper and
lower harbor remedial action to ensure that the upper and lower harbor remedy continues to
provide adequate protection of human health and the environment.

Date

Office of Site Remediation and Restoration
EPA-New England

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Table of Contents

I.	SITE NAME, LOCATION, DESCRIPTION AND RATIONALE FOR
AMENDMENT 	 1

II.	SITE HISTORY AND ENFORCEMENT ACTIVITY 	 3

III.	COMMUNITY PARTICIPATION	 4

IV.	SCOPE AND ROLE OF OPERABLE UNIT 	 8

V.	DESCRIPTION OF CHANGES TO THE 1990 REMEDY	 8

DESCRIPTION OF THE 1990 REMEDY 	 8

1990 REMEDY ACTIVITIES COMPLETED TO DATE 	 9

CHANGES TO THE 1990 REMEDY 	 10

VI.	SUMMARY OF SITE CHARACTERISTICS 	 11

EXISTING SITE CONDITIONS 	 11

Overall Site Layout	 12

Existing CDF Conditions 	 12

HOT SPOT SEDIMENT CHARACTERIZATION 	 13

Chemical Characterization 	 15

Physical Characteristics 	 18

VII.	SUMMARY OF SITE RISKS 	 18

VIII.	DESCRIPTION OF AMENDMENT ALTERNATIVES EVALUATED 	 19

IX.	COMPARATIVE ANALYSIS OF THE ORIGINAL REMEDY AND

AMENDED REMEDY 	 20

X.	THE SELECTED REMEDY 		26

XI.	STATUTORY DETERMINATIONS 		27

XII.	DOCUMENTATION OF NO SIGNIFICANT CHANGES 		31

XIII.	STATEROLE		32

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Figures

1.	Study areas

2.	Fishing Closure Areas

3.	Aerial Photograph of the Sawyer Street site and the surrounding area

4.	Site Layout Plan

Tables

1 .Summary of PCB and Oil and Grease Data for the Hot Spot Sediments

2.	PCB and Oil and Grease Results for the USACE Samples Collected in June 1995

3.	Summary of Chlorinated Benzene Data for the Hot Spot Sediment (Third Pilot Study)

4.	Summary of PAH Concentrations for the Hot Spot Sediment (Third Pilot Study)

5.	Summary of (2,3,7,8 Substituted Isomers) Data for the Hot Spot Sediment (Third Pilot Study)

6.	Summary of Dioxin and Furan Data (Totals) for the Hot Spot Sediment (Third Pilot Study)

7.	Summary of Metals Data for the Hot Spot Sediment (Third Pilot Study)

8.	TCLP Results for Hot Spot Sediment (Third Pilot Study)

9.	Chemical Specific ARARs and TBCs

10.	Location Specific ARARs and TBCs

11.	Action Specific ARARs and TBCs

Appendices

Appendix A - Responsiveness Summary
Appendix B - Administrative Record Index
Appendix C - State Concurrence Letter
Appendix D - References Cited

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NEW BEDFORD HARBOR SUPERFUND SITE
HOT SPOT OPERABLE UNIT
AMENDED RECORD OF DECISION
APRIL, 1999

I SITE NAME, LOCATION, DESCRIPTION AND RATIONALE FOR
AMENDMENT

SITE NAME: The New Bedford Harbor Superfund Site.

SITE LOCATION: The New Bedford Harbor Superfund Site (the Site), located in Bristol County,
Massachusetts, extends from the shallow northern reaches of the Acushnet River estuary south
through the commercial harbor of New Bedford and into 17,000 adjacent acres of Buzzards Bay
(Figure 1).

SITE DESCRIPTION: Industrial and urban development surrounding the harbor has resulted in
sediments becoming contaminated with high concentrations of many pollutants, notably
polychlorinated biphenyls (PCBs) and heavy metals, with contaminant gradients decreasing from
north to south. From the 1940s into the 1970s two electrical capacitor manufacturing facilities, one
located near the northern boundary of the site (the Aero vox facility) and one located just south of the
New Bedford Harbor hurricane barrier (the Cornell-Dublier facility), discharged PCB-wastes either
directly into the harbor or indirectly via discharges to the City's sewerage system. The Site has been
divided into three geographical areas: upper harbor (including the hot spot area), lower harbor and
outer harbor (Figure 1). The hot spot is an area of approximately five acres with sediment PCB levels
in excess of 4,000 ppm located along the western bank of the upper harbor, directly adjacent to the
Aerovox facility (Figure 1). The Site is also defined by three state-sanctioned fishing closure areas
extending approximately 6.8 miles north to south and encompassing approximately 18,000 acres in
total (Figure 2).

The City of New Bedford, located along the western shore of the Site, is approximately 55
miles south of Boston. During most of the 1800s, New Bedford was a world renown center of the
whaling industry. More recently New Bedford has attracted large community of immigrants from
Portugal and the Cape Verde islands. As of 1990, approximately 27% of New Bedford's 99,922
residents spoke Portuguese in their homes (US Census Bureau, 1997). Including the neighboring
towns of Acushnet, Fairhaven and Dartmouth, the combined 1990 population of the New Bedford
area was approximately 153,000. NewBedford is currently home port to a large offshore fishing fleet
and is a densely populated manufacturing and commercial center. By comparison, in Fairhaven and
Acushnet, the eastern shore of the Acushnet River is predominantly residential or undeveloped. Some
of Fairhaven's shore is utilized by small boating related industries. A large (approximately 70 acre)
salt marsh system has formed along almost the entire eastern shore of the upper harbor.

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The Acushnet River's 16.5 square mile (43 km2) drainage basin (VHB, 1996) discharges to
New Bedford Harbor in the northern reaches of the Site, contributing relatively minor volumes of
fresh water to the tidally influenced harbor. Its estimated mean annual flow of 30 cubic feet per
second is only about 1% of the average tidal prism (the volume of water which flows into and out
of the Harbor during the course of a complete flood/ebb tide cycle) (NUS, 1984). Numerous storm
drains, combined sewer overflows (CSOs) and industrial discharges, as well as smaller brooks and
creeks, also discharge directly to the Site. The upper and lower harbors are believed to be areas of
net groundwater discharge and are generally described as a shallow, well-mixed estuary.

The upper harbor comprises approximately 187 acres, with current sediment PCB levels
ranging from below detection to approximately 4,000 ppm. Prior to the removal of the Hot Spot
sediments from the upper harbor in 1994 and 1995 as part ofEPA's original Hot Spot cleanup plan
(see Section V. below), sediment PCB levels were reported higher than 100,000 ppm in the upper
harbor. The boundary between the upper and lower harbor is the Coggeshall Street bridge where the
width of the harbor narrows to approximately 100 feet. The lower harbor comprises approximately
750 acres, with sediment PCB levels ranging from below detection to over 100 ppm. The boundary
between the lower and outer harbor is the 150 foot wide opening of the New Bedford hurricane
barrier. (The hurricane barrier was constructed in the mid-1960s). Sediment PCB levels in the outer
harbor are generally low, with only localized areas of PCBs in the 50-100 ppm range near the
Cornell-Dubilier facility and the City's sewage treatment plant's outfall pipes. However, this area is
still being characterized by EPA. The southern extent of the outer harbor and the Site is an imaginary
line drawn from Rock Point (the southern tip of West Island in Fairhaven) southwesterly to Negro
Ledge and then southwesterly to Mishaum Point in Dartmouth (Figure 2).

RATIONALE FOR AMENDMENT: In 1990, EPA issued the Record of Decision (1990 Hot
Spot ROD) for the Hot Spot Operable Unit of the Site (USEPA, 1990), in accordance with the
Comprehensive Environmental Response, Compensation and Liability Act (CERCLA), 42 USC §§
9601 etseq., and the National Oil and Hazardous Substances Pollution Consistency Plan (NCP), 40
CFR Part 300. Based on a vehement and Congressionally supported reversal in community
acceptance of the 1990 Hot Spot ROD's on-site incineration component of the remedy, EPA
suspended plans to incinerate the Hot Spot sediments in New Bedford. Working with the local
community, EPA agreed to study other options for treating the Hot Spot sediments and to amend the
1990 Hot Spot ROD with a consensus based cleanup plan. Refer to the Community Participation
section of this Amendment for additional details regarding community opposition to incineration and
the consensus building process. This ROD Amendment addresses the changes to the original 1990
Hot Spot ROD which resulted from both community input and additional research into treatment and
disposal alternatives for the Hot Spot sediments.

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II.

SITE HISTORY AND ENFORCEMENT ACTIVITIES

Details of the earlier Site History and Enforcement Activities are presented in the 1990 Hot
Spot ROD and the December 1997 Hot Spot Feasibility Study Addendum (Foster Wheeler, 1997a).
The following is an update to the Site History and Enforcement Activities which have occurred since
issuing the 1990 Hot Spot ROD.

In April 1990, EPA issued the Hot Spot ROD. The original cleanup plan set forth in the 1990
Hot Spot ROD called for dredging of the Site's most highly PCB-contaminated sediments from the
upper harbor, incinerating the sediments in an on-site treatment facility to destroy the PCBs, and
storage of the treated sediments in a shoreline disposal facility. This ROD specified a 4,000 ppm PCB
level to define the area of Hot Spot sediments to be dredged.

In 1991 and 1992, the Unites States, the Commonwealth and five defendants in litigation filed
by the EPA and Commonwealth of Massachusetts regarding this site - Aerovox Incorporated,
Belleville Industries, Inc., AVX Corporation, Cornell-Dubilier Electronics, Inc., and Federal Pacific
Electric Company (FPE)-reached settlement regarding the governments' claims. The governments'
claims against the sixth defendant, RTE Corporation, were dismissed on jurisdictional grounds. The
federal and state governments recovered a total of $99.6 million, plus interest, from the five settling
defendants.

The terms of the settlements are set forth in three separate consent decrees. Under the first
consent decree, Aerovox Incorporated and Belleville Industries, Inc. were required to pay a total of
$12.6 million, plus interest, to the United States and the Commonwealth for damages to natural
resources and for past and future Site response costs. The court approved and entered this consent
decree in July 1991. Under the second consent decree, AVX Corporation was required to pay $66
million, plus interest, to the governments for natural resource damages and for past and future Site
response costs. This decree was approved and entered by the court in February 1992. Under the third
consent decree, CDE and FPE paid $21 million, plus interest, to the governments for natural resource
damages and for past and future Site response costs. This decree was approved and entered by the
Court in November 1992.

In April 1992, EPA issued an Explanation of Significant Differences (USEPA, 1992) to
change the storage of ash generated from the incineration of Hot Spot sediments from temporary
storage in an on-site Confined Disposal Facility (CDF) to permanent storage in an on-site CDF.

In 1993, due to a vehement and Congressionally supported reversal in public support for the
incineration component of the cleanup plan at about the time the incinerator was being mobilized,
EPA agreed to terminate the incineration contract and begin studies of other possible options for
treating the Hot Spot sediments. The New Bedford Harbor Superfund Site Community Forum (see
Section III. below) was created in late 1993 to develop a consensus based cleanup plan to replace the
on-site incineration component of the original cleanup plan.

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During the 1994-95 construction seasons the dredging component of the 1990 Hot Spot
remedy decision was implemented. Dredging of about 14,000 cubic-yards in volume and 5 acres in
area began in April 1994 and was completed in September 1995. The dredged sediments are currently
stored in a shoreline confined disposal facility (CDF) located at the eastern end of Sawyer Street in
New Bedford.

In October 1995, the EPA issued an Explanation of Significant Differences (USEPA 1995)
to document the need for interim storage of the dredged Hot Spot sediments in the Sawyer Street CDF
while studies of treatment options not involving on-site incineration were conducted.

In December 1997, EPA issued a Hot Spot Feasibility Study Addendum Report (Foster
Wheeler, 1997a) which presented the evaluation of the non-incineration treatment options
investigated. In August 1998, EPA issued a Proposed Plan (USEPA, 1998a) to amend the 1990 Hot
Spot cleanup plan. The 1998 Proposed Plan called for dewatering the Hot Spot sediments and
transporting them to a permitted off-site hazardous waste landfill.

In September 1998, EPA issued the ROD for the Upper and Lower Harbor Operable Unit
(USEPA, 1998b). This ROD involves the dredging and containment of approximately 450,000
cubic-yards ofPCB-contaminated sediments spread over about 170 acres. The dredged sediments will
be placed in four shoreline confined disposal facilities (CDFs). Seawater decanted from these
sediments will be treated before discharge back to the harbor. Refer to the September 1998 Upper
and Lower Harbor ROD for a more detailed description of the remedy.

III. COMMUNITY PARTICIPATION

Community Participation in the decision-making process has always been and continues to
be at a high level for this Site. EPA went far beyond the regulatory requirements for public
involvement while developing the 1989 Proposed Plan and 1990 Hot Spot ROD (refer to the 1990
Hot Spot ROD for details). Even though EPA sought to ensure that the public was well informed and
accepted the proposed cleanup plan, public opposition to the incineration component of the Hot Spot
cleanup plan formed soon after issuing the ROD. In late 1990, a New Bedford citizen's group, Hands
Across the River (later renamed the Hands Across the River Coalition), formed in part to oppose
on-site incineration of the Hot Spot sediments. Another group, Concerned Parents of Fairhaven, also
organized to oppose on-site incineration. Finally, in the spring of 1993, a third citizen's group, the
Downwind Coalition, was formed to oppose on-site incineration. Later that year the New Bedford
City Council passed an ordinance (City of New Bedford, 1993) which required City approval to
transport the proposed incinerator through the City streets (however the ordinance was not signed by
the Mayor).

In December 1993, EPA and other site stakeholders initiated a professionally mediated
Community Forum process as an effort to build a lasting consensus for the Site's cleanup, including
the upper and lower harbor. Created to address public concerns raised by the incineration component

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of the 1990 Hot Spot cleanup plan, the Forum is made up of a wide variety of Site stakeholders,
including citizen group leaders, local and state elected officials, business representatives, EPA, the
MA DEP and other relevant state and federal agencies. The Forum continues to meet regularly and
has expanded its scope to include virtually all Site related cleanup issues. The Forum meetings are
taped and televised on local cable-access TV to reach as broad an audience as possible. All of the
Forum's proceedings have been documented in the Administrative Record for this Hot Spot ROD
Amendment and the Administrative Record for the September 1998 Upper and Lower Harbor ROD.

The Forum adopted, as part of its mission, the identification of viable innovative technologies
which could be used as an alternative to on-site incineration. During a six month period in 1994, the
Forum engaged in an extensive technology review consisting of company presentations and literature
reviews of alternative technologies for the on-site destruction of the PCB contaminated Hot Spot
sediments. Three general types of PCB treatment methods were selected by the Forum for treatability
studies: (1) solidification/stabilization; (2) contaminant destruction; and (3) contaminant separation
and destruction. In the summer of 1994, Forum members signed an agreement which states that "the
Forum favors a remedy for the Hot Sot sediments that permanently destroys the PCBs". The
agreement also outlined the Forum's continued involvement in the on-site treatability studies.

The treatability study program was initiated in early 1995 with the field testing occurring in
late fall 1995 through 1996. Forum members agreed that the sediment dredging component of the
1990 Hot Spot cleanup plan should be implemented while the treatability studies were being
completed. Dredging of the Hot Spot Sediments was completed in September 1995. As stated
previously, the sediments are currently being stored in a shoreline confined disposal facility at the
eastern end of Sawyer Street in New Bedford.

A series of frequent Forum meetings were held throughout 1997 and into the early summer
of 1998 to publicly discuss and debate the results of the treatability studies and work toward a
consensus on the best cleanup option for the Hot Spot sediments. The results of the treatability
studies are documented in the December 1997 Hot Spot Feasibility Study Addendum Report (Foster
Wheeler, 1997a). The Feasibility Study Addendum evaluated eleven cleanup alternatives. Refer to
Section VIII of this Addendum for a description of the eleven Alternatives evaluated. The eleven
alternatives were evaluated against the NCP criteria (except for State and Community Acceptance).
All the alternatives except No Further Action were found to satisfy the seven criteria evaluated
although some ranked better than others (see Section 6.3, Foster Wheeler, 1997a). The Community
Forum reviewed the findings of the Feasibility Study Addendum and provided feedback to EPA and
the State.

In addition to these Community Forum efforts, an independent panel session was assembled
by a local non-profit organization, Sea Change, Inc. Sea Change, an outgrowth of the Forum's work,
is a non-profit organization, which draws in outside independent experts to perform technical
evaluations of waste issues for local communities and the Government. Sea Change held this public
panel session on October 30, 1997.

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After extensive discussion of the treatability studies and the evaluations which used the nine
NCP criteria, the Forum developed an initial recommendation which narrowed the range of
alternatives to two cleanup options. One option was for the on-site dewatering of the sediments and
transportation of the dewatered sediments to an off-site permitted hazardous waste landfill. The other
option was for the on-site separation of the PCB's from the sediment by one of two innovative
technologies demonstrated during the treatability studies, thermal desorption or solvent extraction.
The resulting reduced volume of material containing the concentrated PCBs would be transported
off-site to a permitted hazardous waste incinerator. The remaining treated sediment, which would
contain small concentrations of heavy metals (but not at sufficient levels to be regulated as hazardous
waste) would be placed in one of the confined disposal facilities to be constructed as part of the
Upper and Lower Harbor ROD remedy to contain the less PCB-contaminated sediments to be
dredged from the upper and lower harbor (USEPA, 1998b).

The Form sponsored two open public meetings, on June 4, 1998, and June 10, 1998, to
discuss the two options presented above. Over 800 invitations, along with a public Forum statement
and informational materials describing the two options, were sent out prior to these meetings. In
addition, the first meeting was broadcast over the local cable television station. The meetings were
attended largely by residents of the neighborhoods in close proximity to the Sawyer Street CDF and
the site where the proposed treatment and/or dewatering facility would be built. The comments
received at these meetings strongly urged the Forum members to recommend off-site landfilling of
the Hot Spot sediments. The key reasons stated were concerns about the possibility of air emissions
or other problems occurring during the implementation of the separation technologies as well as
concerns about noise, lights and dust caused by the 24-hour per day operations. In addition, residents
pointed out that the landfilling option is significantly faster and less expensive than the
separation/destruction option.

After consideration of the public input received at the two Forum sponsored meetings and
after further discussion, the Forum made the following recommendations on June 17, 1998. For
reasons similar to those expressed at the open meetings by members of the public, a majority of the
Forum members recommend that the Hot Spot sediments be dewatered on-site and transported in
sealed containers to an off-site hazardous waste landfill permitted to accept PCB waste under the
Toxic Substances Control Act (TSCA), 15 USC §§ 2601 etseq. The reasons for this recommendation
are that the landfilling option presents fewer possibilities for operational problems resulting in
emissions or other impacts to the New Bedford community that the other options presents. Some
members ofthe Forum are particularly concerned about the possibility for problems arising at the site,
which is close to local businesses and residences, and thus feel that the Sawyer Street site is a
problematic location for the implementation of an innovative technology. In addition, landfilling
option can be done faster and at a lower cost than the other option. The Forum members urge the
EPA to select a landfill that is the most environmentally sound and impacts surrounding community
the least.

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A minority of the Forum members conscientiously recommend on-site separation by solvent
extraction and off-site destruction of the PCBs. The remaining treated sediment would be deposited
in one of the CDFs that are planned for the rest of the Harbor sediments. In making this
recommendation, the Forum minority's believes that EPA should choose an alternative that results
in the permanent destruction of the PCBs at an approved facility, as opposed to simply sending a
problem created in New Bedford to another community. The minority noted that this has been the
Forum's objective since it's inception. The Forum minority recommends solvent extraction because
it presents fewer possibilities for emissions than does thermal desorption. Further, the Forum minority
urges that the sediments be destroyed by an off-site method other than incineration. The Forum
minority is aware that all currently approved facilities for destruction of concentrated PCBs are
incinerators. However, the Forum minority is also aware that at least one non-incineration technology
(solvated electron technology) is under development and may be close to approval, and others may
emerge in the near future. The Forum minority urges that the possibilities for using non-incineration
technologies be maximized during the bid selection process.

Even though there were majority and minority recommendations, all Forum members reached
consensus on the off-site landfilling option. The Forum recommendation for the landfilling option
was officially confirmed as of the date of their signatures to a June 1998 document entitled New
Bedford Harbor Superfund Site Community Forum, Recommendation (Forum, 1998). The EPA and
MA DEP also signed this document as members of the Forum. However, the EPA indicated that by
concurring with the Forum consensus, EPA was not issuing a determination as to the remedy to be
selected for this Site and that the remedy selection will not be determined until after completion of
the requirements established under CERCLA and the NCP. The MA DEP also indicated that their
final decision on which remedy to support will be made after consideration of comments received
during the formal public comment period for the Proposed Plan, in accordance with CERCLA and
the NCP.

EPA published a Proposed Plan to Amend the 1990 Cleanup Plan in August 1998. The
proposed change calls for transporting the dewatered sediments to a TSCA permitted hazardous
waste landfill. The cleanup plan was recommended because EPA believed it offered the best balance
among the nine NCP criteria, including the protection of human health and the environment. EPA
held a public informational meeting on August 26, 1998 and a formal public hearing on September
16, 1998. An informal poster board presentation was provided prior to starting the informational
meeting and hearing. The public comment period ran from August 27-September 25, 1998. All
formal comments received on the August 1998 Proposed Plan are summarized and responded to in
the Responsiveness Summary, Appendix A. All original comments to the August 1998 Proposed Plan
are included in the Administrative Record.

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IV

SCOPE AND ROLE OF OPERABLE UNIT

The New Bedford Harbor Site has been divided into three operable units, or phases of site
cleanup: The Hot Spot Operable Unit (which the April 1990 Hot Spot ROD and this Amendment
encompasses), the Upper and Lower Harbor Operable Unit, and the Buzzards Bay or Outer Harbor
Operable Unit. The ROD for the Upper and Lower Harbor Operable Unit was issued on September
25, 1998. The ROD for the Outer Harbor Operable Unit is currently unscheduled pending additional
investigation in the outer harbor.

The hot spot areas are defined as those areas in the upper harbor with sediments contaminated
above 4,000 ppmPCBs. Most of the hot spot areas were dredged from the harbor in 1994 and 1995.
However, one of the hot spot areas (Area B, see US ACE, 1991) was not dredged during the hot spot
dredging operations due to its proximity to submerged high voltage power lines serving the City of
New Bedford. The remedy for the Upper and Lower Harbor Operable Unit includes the relocation
of the power lines and dredging of this last remaining hot spot area. See section XII of the September
1998 Upper and Lower Harbor ROD (USEPA, 1998b) for additional discussion regarding the
cleanup approach for the submerged power line area.

V. DESCRIPTION OF CHANGES TO THE 1990 ROD

DESCRIPTION OF 1990 REMEDY

The remedy selected by the 1990 Hot Spot ROD was developed to satisfy the following
remedial objectives:

•	Significantly reduce PCB migration from the Hot Spot area sediment, which acts as
a PCB source to the water column and to the remainder of the sediments in the harbor.

•	Significantly reduce the amount of remaining PCB contamination that would need to
be remediated in order to achieve overall harbor cleanup.

•	Protect public health by preventing direct contact with Hot Spot sediments.

•	Protect marine life by preventing direct contact with Hot Spot sediments.

The design and specifications for the remedy selected in the 1990 Hot Spot ROD to meet the
above remedial objectives were completed in December 1991 (USACE, 1991b,c) and called for the
following major activities:

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1.	Dredging. Dredging approximately 10,000 cubic yards of PCB-contaminated (from 4,000
to over 100,000 ppm) sediments and pumping this material to on-shore CDF (Sawyer Street Facility)
for subsequent treatment.

2.	Treating Supernatant. A large volume of water co-dredged along with the sediments
requires treatment. As the dredged sediments settle in the CDF, the clarified surface layer, or
supernatant will be removed or decanted and treated on-site using the following unit processes:

•	equalization

•	coagulation and flocculation

•	settling

•	filtration

•	UV/oxidation

3.	Sediment Removal Dewatering and Water Treatment After the sediments are decanted and
the wastewater treated, the sediments will be removed from the CDF for dewatering prior to
incineration. Water from the dewatering operation will be treated on-site prior to discharge to the
harbor.

4.	On-site Incineration. The dewatered sediments will be incinerated in a transportable
incinerator that will be sited at the Sawyer Street location. The extremely high temperatures achieved
by the incinerator will result in 99.9999% destruction of PCBs. Exhaust gases will be passed through
air pollution control devices before being released into the atmosphere to ensure that appropriate
health and safety and air quality requirements are met.

5.Stabilization (if determined to be necessary). Following incineration, the Toxicity
Characteristic Leaching Procedure (TCLP), a leaching test, will be performed on the ash to determine
if it exhibits the characteristic of toxicity and is, therefore, considered a hazardous waste under the
Resource Conservation and Recovery Act (RCRA), 42 USC §§ 6901 etseq. If the TCLP test reveals
that the ash is a RCRA hazardous waste, the ash will be solidified such that the metals no longer
leach from the ash at concentrations that exceed the standards set forth for determining the toxicity
of a material.

6. On-site Disposal of Incinerator Ash . The ash from the incinerator will be permanently
disposed of in the Sawyer Street CDF. To ensure protectiveness, the CDF win be closed in
accordance with RCRA hazardous waste regulations for landfills.

1990 REMEDY ACTIVITES COMPLETED TO DATE

Activities associated with the first two major components of the 1990 remedy, dredging and
treating the supernatant, have been completed. The CDF was upgraded in 1993 to include a double
high density polyethylene liner system. The CDF was originally constructed in 1988 as part of a pilot
dredging and disposal study conducted by the EPA and the U.S. Army Corps of Engineers

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(USACE). Construction of a wastewater treatment facility consisting of the unit processes described
above was completed in June 1994. Dredging and treatment of the supernatant was completed in
September 1995. It was estimated that about 10,000 cubic yards of sediments needed to be dredged.
About 14,000 cubic yards of Hot Spot sediments were actually removed from the upper harbor via
hydraulic dredging and placed for interim storage in the Sawyer Street CDF. In October 1995, EPA
prepared an Explanation of Significant Difference to the 1990 Hot Spot ROD to address the need for
temporary storage of the Hot Spot sediment in the CDF while studies of alternatives to incineration
(the fourth component of the 1990 remedy) were being completed.

A concrete decontamination pad equipped with a steam cleaner and sump pump is also
located on the site. Six trailers are currently located on the site and are used as
shower/decontamination, laboratory, and office trailers. Six air monitoring stations are located on
platforms around the site. Electric power, potable water, and sewage facilities are also available on
the site. USACE staff are present at the site during the day and a guard provides security at night.
Overall site security is provided by a six foot tall chain link fence. An aerial photograph of the
Sawyer Street Facility is provided as Figure 3.

CHANGES TO THE 1990 REMEDY

As discussed previously, EPA terminated the incineration component of the 1990 remedy and
worked with the New Bedford Harbor Community Forum to find an alternative to on-site
incineration of the Hot Spot sediments. This ROD Amendment selects off-site landfilling instead of
on-site incineration. This ROD Amendment satisfies the original remedial action objectives presented
above. The amended remedy replaces major activities three through six of the 1990 remedy described
above with the following major activities:

1.	Sediment Dewatering and Water Treatment. The sediments stored in the CDF are
approximately 50% water, which is too wet to be accepted by a TSCA permitted hazardous waste
landfill. The sediments will be dewatered to at least that level which is in compliance with the
permits for the selected off-site TSCA permitted landfill. Options for dewatering the sediments will
be evaluated during the design process. The amount of dewatering required for the landfilling option
will be less than the amount of dewatering that would have been required prior to on-site incineration
of the sediments.

2.	Transportation to an Off-Site TSCA Permitted Landfill. Following dewatering, the
sediments will be loaded into sealed containers for transport to a TSCA permitted off-site hazardous
waste landfill.

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A comparison of the original 1990 remedy and the modified remedy is provided below.

Original Remedy

Dredge the Hot Spot sediments from the harbor
and pump to Sawyer Street CDF (completed in
September 1995)

Decant supernatant, treat supernatant on-site
and discharge to the harbor (completed in
September 1995)

Dewater sediments prior to incineration, on-site
treatment of the water from dewatering process
and discharge of treated water to the harbor

On-site incineration of the dewatered sediments

Perform TCLP testing ofthe incinerator ash and
stabilize as necessary

Place incinerator ash in Sawyer Street CDF and
close in accordance with RCRA regulations for
hazardous waste landfills.

Modified Remedy

Dredge the Hot Spot sediments from the harbor
and pump to Sawyer Street CDF (Completed in
September 1995)

Decant supernatant, treat supernatant on-site
and discharge to the harbor (completed in
September 1995)

Dewater sediments prior to off-site landfilling.
on-site treatment of the water from dewatering
process and discharge of treated water to the
harbor

Load dewatered sediments into sealed
containers and transport to a TSCA permitted
landfill

VI. SUMMARY OF SITE CHARACTERISTICS

This section of the report provides a description of the existing Sawyer Street Confined
Disposal Facility (CDF) that is currently being used to store the Hot Spot sediments and a chemical
and physical description of these sediments.

EXISTING SITE CONDITIONS

The Hot Spot sediments are currently stored in a double-lined CDF constructed along the New
Bedford Harbor shoreline. This CDF is adjacent to facilities at the Sawyer Street site remaining from
the Hot Spot dredging activities that were conducted by EPA and the US ACE during 1994 and 1995.
The Sawyer Street site was also the location where the treatability studies were conducted. The
following subsections describe the overall site layout and the existing CDF conditions.

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Overall Site Layout:

The Sawyer Street location of the New Bedford Harbor Site is approximately eight acres in
size, including approximately three acres occupied by the CDF. The site is located at the eastern end
of Sawyer Street, on its north side, and abuts the Acushnet River to the east and vacant land to the
north and west. Land use in the vicinity of the site is a mixture of urban industrial and residential. An
aerial photograph of the site and surrounding area is included as Figure 3. A Site Layout Plan is
included as Figure 4.

An 80 foot x 120 foot bermed asphalt pad is located on the western side of the site. The pad
was constructed for the treatability study program. During the testing, the pad was covered with an
impermeable liner to prevent an inadvertent release of sediment or treatment reagents to the soil on
the site. Sump drainage from this pad was routed to the on-site water treatment facility. Following
completion of the treatability studies in 1996, this liner was appropriately decontaminated.

The site also includes a 350 gallon per minute (gpm) water treatment system enclosed within
a building. A concrete decontamination pad equipped with a steam cleaner and sump pump is also
located on the site. Several trailers are currently located on the site, these are used as
shower/decontamination, laboratory, and office trailers. Six air monitoring stations are located on
platforms around the site. Electric power, potable water, and sewage facilities are currently available
on the site. Overall site security is provided by a six foot tall chain link fence.

Existing CDF Conditions:

The CDF is illustrated on Figure 4 and can be seen in the aerial photograph included as Figure
3. As shown in Figure 2, the CDF has three individual cells. Cell #1 was used as the initial settling
basin where the Hot Spot sediments were pumped following dredging. The cell has a double HDPE
liner and is approximately 200 feet by 400 feet wide and approximately nine feet deep. The Hot Spot
sediment in this cell is approximately six to seven feet deep.

The contaminated sediments in the CDF are currently covered with a 10-mil permalon
cover. This relatively thin cover was placed over the sediments as a temporary measure to minimize
volatilization and potential direct contact by human and/or ecological receptors. The cover is
weighted down with sand bags to prevent wind-damage. A layer of water is often maintained over
the cover during the summer months to assist in controlling PCB emissions.

As the dredged material settled in Cell #1, the clarified surface layer, or supernatant was
routed to Cell #2 for temporary storage/flow equalization before receiving additional water treatment.
The supernatant was then pumped into the treatment building where a polymer was added to enhance
additional settling of solids in Cell #3, which acted as a secondary clarifier. Subsequent water
treatment steps included sand filtration and treatment of the PCBs through Ultra Violet Oxidation
(UV/Ox) prior to discharge to the Acushnet River.

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As mentioned previously, during 1994 and 1995, the Hot Spot sediments were dredged from
the northern portion of the Acushnet River and placed in the Sawyer Street CDF. The dredging was
continued until analysis of post-dredging samples indicated that the Hot Spot sediments had been
removed and the cleanup goal of4,000 ppmwas achieved. In total, approximately 14,000 cubic yards
of sediment, weighing approximately 18,000 tons, were removed from the harbor and placed in CDF
Cell #1. Additional description of the Hot Spot sediments and their chemical and physical
composition are presented in the following section.

HOT SPOT SEDIMENT CHARACTERIZATION

The chemical and physical characteristics of the Hot Spot sediments are described in this
section. These descriptions are based largely on recent pilot study data, with reference to historical
data, as appropriate. The source of the data points and the results used to characterize the material
are discussed below.

Hot Spot sediments were initially defined in-situ as having total PCB concentrations greater
than 4,000 ppm and averaging approximately 20,000 ppm, to 30,000 ppm. Removal of this Hot Spot
sediment was estimated to result in a total reduction of PCB s in the upper harbor by approximately
50 percent.

Sediment PCB concentrations determined during recent sampling of sediments from the CDF
ranged from 1,600 to 7,700 ppm. Based on results for samples collected from the CDF, in
conjunction with available historical data on the physical and chemical nature of the sediment,
average PCB concentrations in the CDF are estimated to be approximately 6,000 ppm.

This is lower than the historical in situ average of approximately 20,000 to 30,000 ppm. The
reason for this difference may be due to a variety of reasons including a biased CDF sampling
approach due to the limited number of sampling points, the heterogeneous nature of the dredged
material, treatment of PCBs that were transferred to the aqueous and colloidal phases during
sediment dredging and disposal within the CDF, dredging more sediments than originally planned,
and changes in analytical methodology.

In addition to PCBs, the Hot Spot sediment contains several other organic and inorganic
contaminants. Extractable oil and grease, as measured gravimetrically, comprise approximately two
to three percent of the sediment matrix. The sediment contains concentrations of other organic
compounds including chlorinated benzenes, polynuclear aromatic hydrocarbons (PAHs),
poly chlorinated dibenzo-p-dioxins (dioxins) and polychlorinated dibenzofurans (furans). Several
heavy metals including arsenic, cadmium, chromium, copper, lead and zinc, were also detected at
elevated concentrations in the samples collected from the CDF. None of these contaminants have
been measured at sufficient levels so that the sediments would be regulated as hazardous waste. Each
of these contaminant groups are described in more detail below.

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Samples were collected from the CDF during several recent sampling events. The analytical
findings from these events are summarized in this section and, where appropriate, compared with
available historical data. The analytical methodologies and associated measures of quality control and
quality assurance are discussed in more detail in Section 4.3 of the December 1997 Hot Spot
Feasibiliy Study Addendum Report. Laboratory data reporting forms for the samples collected during
the pilot study program are included in the Data Compendium (Foster Wheeler 1997b).

Hot Spot sediment contained in the CDF was sampled on four occasions. These events
include a sampling event conducted by the US ACE in June 1995 and sampling conducted for each
of the three pilot study treatment processes tested in 1996. These three pilot scale studies (Ionics
RCC, Geo safe and S AIC/Eco Logic) are hereafter referred to as the first, second and third pilot
studies. The results from these four sampling events provide the basis for the Hot Spot sediment
characterization described in this section.

Samples collected by the US ACE in June 1995 were collected directly from six locations in
the CDF. Sediment for the first two pilot studies was removed from the CDF in the spring of 1996
and placed into oversized drums. Samples of this material were collected from the drums prior to its
use as feed material for the first and second pilot studies. Sediment for the third study was removed
from the CDF, transferred to drums, and sampled from the drums in the fall of 1996. This sediment
was removed from a similar location within the CDF. However, the material was retrieved from a
greater depth.

Chemical and physical data from the various sampling events are detailed in the following
subsections. In summary, the results for samples collected during the third pilot study were chosen
as the representative profile of the Hot Spot sediment. These results were generally consistent with
the historical Hot Spot data, although the PCB results were lower than the historical average of
approximately 20,000 ppm, to 30,000 ppm Results for oil and grease and four heavy metals of
concern were essentially the same for the third pilot study and the historical data. Based on the
available data, the results from the third pilot study appear to represent a reasonable average
concentration of contaminants in the CDF.

Initial in-situ sampling of the Hot Spot sediments was conducted from 1982 through 1988.
These data sets provide the basis for the historical information on the Hot Spot sediment. The
following five sediment sampling data sets were used to determine the nature and extent of PCB
contamination in sediment of the Acushnet River Estuary:

•	U.S. Coast Guard Sediment Sampling Program (1982)

•	US ACE FIT Sampling Program (1986)

•	Battelle Hot Spot Sediment Sampling Program (1987)

•	US ACE Wetlands and Benthic, Sediment Sampling Program (1988)

•	USACE Hot Spot Sediment Sampling Program (1988)

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The data sets listed above were used by EPA to support the 1990 Hot Spot ROD. Other
relevant data sets that were included by EPA in the Administrative Record:

•	DEQE sampling (1981)

•	EPA sampling (November 1981)

•	Aero vox sampling (March 1982)

•	Aerovox/GE sampling (June 1986)

In summary, these four data sets are consistent with the magnitude and location of PCB
identified within the five data sets used to support the 1990 Hot Spot ROD.

Chemical Characterization:

PCB, oil and grease, selected semi-volatile, and Toxicity Characteristic Leaching Procedure
(TCLP) results for the sediment samples collected during the pilot study program are discussed in
this section. Where appropriate, the data are compared with the US ACE sampling conducted in June
1995. PCB data from the third pilot study and the US ACE 1995 samples 4 through 6 appear to be
most representative of the sediment contained within the CDF, based on historical data for the
sediment. Samples collected during the first and second pilot study and 1995 samples 1 through 3
appear to represent uncharacteristically low concentrations of contaminants due to settling at the end
of the dredge pipe. These results are further summarized and discussed below.

Sediment PCB and Oil and Grease Concentrations:

PCB and oil and grease data for the pilot study feed sediment samples are summarized in
Table 1. The results are presented as averages for the first and second studies, and averages for the
third pilot scale study. This reflects the manner in which the sediment was collected and
homogenized for each study. During the spring of 1996, approximately five cubic yards of Hot Spot
sediment was removed from the CDF and homogenized. A similar procedure was performed in the
summer of 1996 to gather and homogenize feed sediment for the third pilot scale study. As shown
in the table, the average results for the first and second pilot studies were lower than for the third pilot
study.

The difference in average PCB concentrations between these two sediment removal exercises
is not surprising given the variability that is likely to exist throughout the CDF. However, it would
appear that sediment removed to support the third treatability study may be more representative of
the CDF as a whole. This judgment is in part, based on the PCB results obtained by the USACE
during the June 1995 sampling event and the historical in-situ measurements. These results of the
USACE's sampling of the CDF are summarized in Table 2.

In addition to the chemical analyses, the USACE evaluated the physical and chemical
composition of these samples. The results of this evaluation identified two distinctly different types
of sediment along the eastern wall of Cell #1 of the CDF. These included, the coarser material

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which had settled out at the end of the dredge discharge pipe (samples 1 through 3), and the samples
that were beyond the initial settling zone (samples 4 through 6). Given the hydrodynamic profile of
the CDF as a settling lagoon and based on a comparison with historical data, samples 4 through 6
appeared more likely to be representative of the CDF material than samples 1 through 3.

Sediment Semivolatile Concentrations:

Feed sample results from the third pilot study for chlorinated benzenes are summarized in
Table 3. Similar to the PCB and oil and grease results, chlorinated benzene results were slightly
lower in the samples collected during the first and second studies that those collected during the third
study, indicating that the chlorinated benzene concentrations may be somewhat proportional to the
PCB concentrations.

PAH results from the third pilot study are summarized in Table 4. In contrast to the
chlorinated benzenes, the results for PAHs were actually slightly higher in the samples for the first
and second study than in those collected during the third study. The average total PAHs were
reported to be 65 ppm in the first and second study, almost twice the 37 ppm average reported for
the third study. The pattern of PAH contamination does not correlate with the PCB observations. This
is likely due to historical point and non-point sources of PAHs along the harbor's edge. These sources
likely contributed PAHs to the harbor in a manner different from that of PCB. To maintain
consistency, the data from the third pilot study was used in Table 4 to categorize the sediment.

CDF sample results are consistent with previous in-situ sampling, where total PAH concentrations
averaged approximately 70 ppm (the highest PAH concentration of930 ppm was detected in the Hot
Spot area). No discrete areas of elevated levels of PAH compounds were observed in the in-situ
sampling, suggesting that the PAH contamination is from non-point sources such as urban runoff.
PAH concentrations detected in the upper estuary sediment were similar to PAH concentrations
detected in other urban and industrialized areas (EPA, 1992).

Overall, concentrations of the semivolatile compounds, including the PAHs and the
chlorinated benzenes, total less than three percent of the PCB concentration. This, in addition to the
relatively lower toxicity of most of these semivolatile compounds with respect to PCBs, indicates that
the majority of risk associated with the Hot Spot is attributable to PCBs.

Sediment Dioxin and Furan Concentrations:

Data for 2,3,7,8-substituted dioxins and furans from the third pilot study and the 2,3,7,8
tetrachlorodibenzo (2,3,7,8-TCDD) toxicity equivalents (TEQs) are summarized in Table 5. TEQs
were calculated by multiplying the concentration of the specific 2,3,7,8- substituted congener by its
specific toxicity equivalent factor (TEFs). Further discussion of TEFs and a table the TEF values are
included in Section 4.3 of the December 1997 Hot Spot Feasibility Study Addendum Report. The
TEF calculation adjusts the concentration of the less toxic 2,3,7,8- substituted congeners to the
equivalent concentration (based on toxicity) of the most toxic dioxin/furan congener

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(2,3,7,8-TCDD). Note that, by definition, the TEQ is related to the concentration of 2, 3, 7, 8-
substituted congeners but is not necessarily related to the total dioxin/furan concentration.

As was the case for the PCBs, dioxin and furan results from the first and second pilot studies
were slightly lower than for the third pilot study. The total 2,3,7,8-substituted isomer concentration
was 16.8 (ng/gm) (parts per billion or ppb) for the first and second studies, with a total TEQ
concentration of 1.3 ng/gm.

Table 6 summarizes the total dioxin and furan results from the third pilot study. Total dioxins
and furans total approximately 30 to 40 parts per billion (ppb). The total 2,3,7,8-TCDD toxicity
equivalent averages were approximately one to two ppb, over one million times less than the total
PCB concentration.

Sediment Metals Concentrations:

Metals results from the third pilot study are summarized in Table 7. Arsenic, cadmium,
chromium, copper, lead and zinc were identified as metals of concern for the site during the initial
phases of RI/FS studies conducted during the early 1980's. In addition to potential risks associated
with these contaminants, metals contamination in the sediment is a concern from an engineering
perspective.

There are some public health risks associated with exposure to these metals; however, this
exposure is expected to comprise a small component of the total risk when compared to risks
associated with exposure to PCB-contaminated sediment. The interim storage of the Hot Spot
Sediment in the Sawyer Street CDF is currently preventing exposure.

TCLP Concentrations:

TCLP results for key contaminants are summarized in Table 8. The complete data set of
TCLP analysis results, including the raw data sheets for the three pilot studies, is included in the Data
Compendium (Foster Wheeler 1997b). The key contaminants summarized in Table 8 were chosen
based on their presence in the Hot Spot sediment and/or because there is a TCLP regulatory criteria
for the contaminant. Some organic contaminants which have a regulatory criteria were not included
in this summary table, as they were reported as non-detect by the laboratory. As discussed above,
results from the third pilot study were chosen as representative of the Hot Spot sediment, although
the results from the first and second studies were similar. TCLP results for the sediment do not
exceed regulatory criteria for being regulated as hazardous waste for any of the listed contaminants.

No regulatory criteria are available for TCLP PCBs. Because PCBs are the primary
contaminant of concern in the Hot Spot sediment, the leachability (TCLP) data for PCBs are of
interest. The average TCLP PCB result was approximately 28 ug/L (ppb). In comparison with the
sediment concentration of 5,700 ppm, very little of the PCBs in the Hot Spot sediment leached into

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the TCLP aqueous solution. This is presumably because the PCBs are preferentially entrained in the
high organic matrix of the sediments.

Physical Characteristics

The Hot Spot sediments are generally a fine-sandy silt with some clay sized particles present.
The sediments are roughly 50 percent solids and 50 percent water with a wet unit weight of
approximately 1.2 tons per cubic yard. The specific gravity of the solid particles within the sediment
matrix is on the order of 2.4 to 2.5. The sediments also contain some shell fragments. However, the
majority of these fragments, passed a one-inch sieve that was used to pre-screen feed material for two
of the three pilot scale treatability studies.

Sediment from the third pilot study was evaluated for grain size distribution and found to be
similar in nature to the sediments from stations 4 through 6 of the 1995 US ACE CDF sampling
program. The results of a comparison of PCB concentrations from these samples have shown similar
consistency.

For potential full-scale treatment operations, the sediment would likely be a fine sandy silt,
with approximately 50% to 70% of the sediment passing the number 200 sieve. The sediment is also
approximately 50 percent moisture by weight. A small volume of larger sized particles is located in
the northeastern corner of the CDF, adjacent to the dredge disposal pipe terminus. In addition, the
contaminant levels associated with these larger particles are generally lower than the average Hot
Spot concentrations.

VII. SUMMARY OF SITE RISKS

Risks associated with exposure to the contaminants of concern (PCBs, cadmium, copper and
lead) in the Hot Spot sediments prior to their removal from the harbor were evaluated and discussed
in the 1990 Hot Spot ROD. As discussed previously, dredging of hot spot areas was completed in
1995 and the dredged sediments are currently stored in the Sawyer Street CDF.

The interim storage of the Hot Spot sediments in the Sawyer Street CDF has been protective
of human health and the environment but provides limited long-term protection. The limitation in
long-term protection is due, primarily, to the limitations of the existing cover in containing the Hot
Spot sediments for a long period of time. The Sawyer Street CDF is currently operated as a temporary
storage facility and does not include a cover system which would provide long-term isolation of
contaminants within the CDF.

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VIII. DESCRIPTION OF AMENDMENT ALTERNATIVES EVALUATED

The New Bedford Harbor Hot Spot Feasibility Study Addendum Report (Foster Wheeler,
1997a) presents and analyzes all of the options EPA considered to replace the on-site incineration
component of the original remedy. EPA developed eleven options for the Hot Spot sediments
currently stored in the Sawyer Street CDF. These options are summarized below. More detailed
information on each option and a comparative analysis of the options can be found in the Feasibility
Study Addendum Report.

A.	Limited or No Further Action (HS-1)

1.	No Further Action HS-1): The Sawyer Street facility would be operated and maintained as
it is today. This includes maintenance of the CDF cover, the current institutional controls of fencing
and site security, and continuation of the air and groundwater monitoring programs.

B.	Treat Contaminants On-site

2.	Solvent Extraction and Solid Phase Chemical Destruction HS-2A): Removal of the Hot
Spot sediments from the Sawyer Street CDF and separation of the PCBs and other organics through
solvent extraction. The concentrated oily extract would subsequently be treated on-site with solid
phase chemical dechlorination to destroy the PCBs. The final step involves placement of the
treatment residuals within a shoreline CDF.

3.	Solvent Extraction and Gas Phase Chemical Destruction (HS-2B): Separation of the PCBs
and other organics through solvent extraction as described for HS-2A. The concentrated oily extract
would then be heated such that the waste would be transformed into a vapor and subsequently treated
with an on-site gas phase reduction reactor to destroy the PCBs. The final step involves placement
of the treatment residuals within a shoreline CDF.

4.	Solvent Extraction and Off-Site Incineration (HS-2C): Separation of the PCBs and other
organics through solvent extraction as described for HS-2A. The concentrated oily extract would then
be transported off-site for incineration at a permitted TSCA facility to destroy the PCBs. The final
step involves placement of the treatment residuals within a shoreline CDF.

5.	Thermal Desorption and Solid Phase Chemical Destruction (HS-3 A): Removal of the Hot
Spot sediments from the CDF followed by a mechanical dewatering step. The PCBs and other
organics would be separated through thermal desorption. The concentrated oily extract generated by
the thermal desorption process would subsequently be treated on-site with a solid phase chemical
dechlorination agent to destroy the PCBs. The final step involves placement ofthe treatment residuals
within a shoreline CDF.

6.	Thermal Desorption and Gas Phase Chemical Destruction (HS-3B): Separation ofthe PCBs
and other organics via thermal desorption as described for HS-3 A. The separated

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contaminants would subsequently be destroyed on-site in a gas phase reduction unit. The final step
involves placement of the treatment residuals within a shoreline CDF..

7.	Thermal Desorption and Off-Site Incineration (HS-3C): Separation of the PCBs and
other organics via thermal desorption as described for HS-3 A. The concentrated oily extract would
be transported off-site for incineration at a permitted TSCA facility to destroy the PCBs. The final
step involves placement of the treatment residuals within a shoreline CDF.

8.	Staged Vitrification (HS-4): Removal of the Hot Spot sediments from the Sawyer Street
CDF followed by a thermal dewatering step to significantly reduce the moisture content. The dried
sediments would be placed within a portion of the CDF and treated through electrically generated
high temperatures (pyrolisis). The resulting product is an inert glass-like solid in which the PCBs and
other organics are thermally destroyed and any metals or other inorganics are immobilized into a
non-leachable form.

C. Contain Contaminants

9.	In-Place Capping (HS-5): Following in place dewatering of the sediments with wick drains,
the sediments would be capped in-place using a multiple layer impermeable cap. This alternative
includes a significant long-term monitoring program for groundwater quality in the vicinity of the
CDF and potential air releases.

E. Move Contaminants Off-site

10.	Off-Site Landfilling HS-6): This alternative involves dewatering the sediments either
in-situ or removing them from the Sawyer Street CDF and mechanically dewatering them.
Following dewatering, the sediments are transported off-site to a TSCA permitted hazardous waste
landfill.

11.	Off-Site Incineration (HS-7): This alternative involves dewatering and removal of the
sediments from the CDF as described in alternative HS-6. The dewatered sediments would then be
transported off-site to a TSCA permitted incinerator to destroy the PCBs.

IX. COMPARATIVE ANALYSIS OF THE ORIGINAL REMEDY AND AMENDED
REMEDY

Section 121 (b)(1) of CERCLA presents several factors that EPA is required to consider in
its assessment of alternatives. Building upon these specific statutory mandates, the NCP articulates
nine evaluation criteria to be used in assessing remedial alternatives. These criteria are as follows:

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Threshold Criteria

In accordance with the NCP, two threshold criteria must be met in order for the alternative

to be eligible for selection:

1.	Overall protection of human health and the environmentaddresses whether or not
a remedy provides adequate protection, and describes how risks posed through each
exposure pathway are eliminated, reduced or controlled through treatment,
engineering controls or institutional controls.

2.	Compliancewith applicable or relevant and appropriate requirements (ARARs)

addresses whether or not a remedy will meet all of the ARARs of promulgated state
and federal environmental and facility-siting requirements, and if not, provides the
grounds for invoking a CERCLA waiver(s) for those requirements.

Primary Balancing Criteria

The following five criteria are used to compare and evaluate those alternatives which fulfill

the two threshold criteria.

3.	Long-term effectiveness and permanence assesses alternatives for the long-term
effectiveness and permanence they afford, along with the degree of certainty that they
will be successful.

4.	Reduction of toxicity, mobility or volume through treatmenfaddresses the degree
to which alternatives employ recycling or treatment to reduce toxicity, mobility or
volume, and how treatment is used to address the principle threats posed by the site.

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

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

7.	Cost includes estimated capital as well as operation and maintenance costs, on a net
present-worth basis.

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Modifying Criteria

The two modifying criteria discussed below are used in the final evaluation of remedial

alternatives generally after EPA has received public comment on the RI/FS and Proposed

Plan.

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

9.	Community acceptance addresses the public's general response to the alternatives
described in the remedial investigation, feasibility study and Proposed Plan.

The following is a comparison of the 1990 Hot Spot ROD remedy and the Amended ROD
remedy, contrasting each remedy's strength and weaknesses with respect to the nine evaluation
criteria.

1. Overall Protection of Human Health and the Environment

This criterion considers whether the remedy, as a whole, will protect human health and the
environment. This includes an assessment of how public health and environmental risks are properly
eliminated, reduced, or controlled through treatment, engineering controls, or institutional controls.

The original remedy and amended remedy are both protective of human health and the
environment. The original remedy called for dredging the Hot Spot sediments from the harbor,
dewatering the sediments, and destroying the PCBs in an on-site incinerator. Incineration is a proven
technology for the destruction of PCBs, and air pollution control devices are routinely used to meet
allowable levels of air emissions. The residual ash from the incineration process was to be
permanently stored in the Sawyer Street CDF. To ensure protectiveness of human health and the
environment the CDF was to be closed in accordance with the RCRA Hazardous Waste Regulations
for landfills.

The amended remedy calls for transporting the dredged Hot Spot sediments, after dewatering
on-site, to a TSCA permitted off-site hazardous waste landfill instead of on-site incineration.
Therefore, no risks to the health of the community or harbor due to potential exposure to the Hot Spot
sediments will remain at the Site. As with the original remedy, removing the sediments from the
Sawyer Street CDF may pose some risk of exposure to PCB emissions during the removal and
dewatering operations. These short-term risks can be easily minimized using engineering controls
and are relatively minor in comparison with the long-term risks associated with leaving the sediments
in place.

22


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2.

Compliance with Applicable and Relevant and Appropriate Requirements

This criterion addresses whether or not a remedy complies with all promulgated state and
federal environmental and facility siting requirements that apply or are relevant and appropriate to
the conditions and remedy at a specific site. If an Applicable or Relevant and Appropriate
Requirement (ARAR) cannot be met, the analysis of a remedy must provide the grounds for invoking
a statutory waiver.

The original and amended remedy comply with all Federal and State ARARs with only one
waiver. The sediment dewatering component of the original and amended remedy requires
discharging treated water into the upper harbor. Water discharges are regulated under state and
federal water quality ARARs. Operation of the Sawyer Street treatment plants requires a waiver of
a provision of the National Pollutant Discharge Elimination System requirements of the federal Clean
Water Act (CWA), Section 402. The provision can be interpreted to prohibit new discharges into
waters that do not meet applicable water quality criteria, unless certain conditions are met (40 CFR
122.4(i)). Harbor waters are presently degraded; they neither meet AWQCs for copper and PCBs nor
are conditions concerning pollutant load allocations and compliance schedules for the upper harbor
waters likely to be accomplished within a reasonable time before the remedy is implemented. A
CERCLA waiver under Section 121(d)(4)(B) was invoked in the Proposed Plan to Amend the
Original Remedy and public comment specifically requested. The waiver was invoked since
compliance would essentially prevent the cleanup of this Site, resulting in greater risk to human
health and the environment. No comments were received on this particular waiver. Issuance of the
ROD enacts the waiver.

Further, since New Bedford Harbor water quality is so degraded as to preclude dilution of any
proposed discharge of PCBs and copper, Section 402 of the CWA requires that discharges of PCBs
and copper meet the respective AWQCs at the discharge point. Consistent with Section 303 of the
CWA and its Total Maximum Daily Load (TMDL) approach, however, discharge limits for copper
and PCBs will be below current background levels but above AWQCs. This approach allows for
attainment of the water quality standards for copper and PCBs throughout the water body in a phased
or step-wise approach. The amount of copper and PCBs that will be discharged from the treatment
plants will be more than offset by the permanent removal of copper and PCB contaminated Hot Spot
sediments from the Harbor. It is expected that the treatment facilities can attain the AWQCs for
cadmium, chromium and lead, the other contaminants of concern from a wastewater discharge
standpoint.

3. Long-term Effectiveness and Permanence

This criterion refers to the ability of a remedy to maintain reliable protection of human health
and the environment over time once the remedial action is complete.

The original incineration remedy would have provided long-term protection and permanence
since the PCBs would have been destroyed during the incineration process. The residual ash, which

23


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could have been considered a hazardous waste, would have been safely contained and monitored in
a facility built to comply with RCRA Hazardous Waste Regulations for landfills.

The amended remedy will provides long-term protection and permanence since the Hot Spot
sediments will be transported from the Sawyer Street site to an off-site TSCA permitted hazardous
waste landfill.

4.	Reduction of Toxicity. Mobility, and Volume through Treatment

This criterion contains three measures of the overall performance of a remedy. The 1986
amendments to the Superfund statute emphasize that, whenever possible, EPA should select a remedy
that uses a treatment process to permanently reduce the level of toxicity of contaminants at the Site,
inhibit or eliminate the spread of contaminants away from the source of contamination, and reduce
the volume, or amount of contamination at the Site.

The original remedy uses a proven treatment technology, incineration, to reduce the toxicity,
mobility and volume of contaminants. Incineration would remove 99.9999% of the PCBs from the
sediments.

The amended remedy does not use treatment to reduce the mobility or toxicity of
contaminants. Although the 1986 amendments to CERCLA and the NCP states a preference for
treatment, an evaluation of site conditions, such as proximity to urban communities, concluded that
there were sufficient negative effects from operating innovative treatment technologies at the site to
warrant selecting off-site landfilling over on-site treatment. The Hot Spot sediment dewatering
process will reduce the volume of contaminated sediments by 20% to 30%.

5.	Short-term Effectiveness

This criterion refers to the likelihood of adverse impacts on human health or the environment
that may be posed during the construction and implementation of a remedy.

EPA does not believe that the original remedy or amended remedy pose significant short-term
effectiveness concerns. The potential exposure of site workers and area residents to contaminated
sediments or air emissions during implementation of the on-site incineration remedy or off-site
landfilling would be minimized by using safety plans that include air emissions controls and a
network of ambient air monitors to assess potential releases to the air during cleanup operations.
Off-site transportation of the Hot Spot sediments will result in a small increase in truck traffic
through the community. The trucks will be routed to minimize the impact to local traffic. The time
to complete either the original or amended remedy is the same, about one year.

24


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6. Implementabilitv

This criterion refers to the technical and administrative feasibility of a remedy, including the
availability of materials and services needed to implement the remedy.

EPA considers both the original and amended remedy to be implementable. The amended
remedy is routine in comparison to the original remedy. While incineration is known to be a proven
technology for the destruction of PCBs, testing in the form of a test bum would have been required
to determine optimum equipment configuration and operating parameters. The technology to
implement the amended remedy is routinely available and there are currently several off-site TSCA
permitted hazardous waste landfills available for disposal of the Hot Spot sediments.

7. Cost

This criterion includes the capital (up-front) cost of implementing each remedy. The costs
described below do not include previous costs which are substantial. The cost estimates only reflect
those costs that would be incurred henceforth to implement either the unfinished components of the
original on-site incineration remedy or the amended remedy.

Original On-Site Incineration Remedy: Total capital cost = $18,200,000
Amended Remedy (Off-Site Landfllling): Total capital cost = $14,800,000

Note: The original on-site incineration remedy included disposing the incinerator ash in an
on-site CDF and capping the CDF. The long-term O&M costs for this component of the original
remedy is not included in the capital cost of $18,200,000. The amended remedy does not require any
long-term O&M.

8.	State Acceptance

This criterion addresses whether, based on its review of the data derived from the Site and the
Proposed Plan, the State concurs with, opposes, or has no comment on the Amendment EPA has
selected for the Site.

The Massachusetts Department of Environmental Protection (DEP) has reviewed the August
1998 Proposed Plan to Amend the 1990 Cleanup Plan and a draft of this Amendment. The DEP
concurs with the remedy change. The DEP has provided a letter of concurrence which is provided
in Appendix C.

9.	Community Acceptance

This criterion addresses whether the public concurs with EPA's proposed Amendment.
Community acceptance of this Amendment to the 1990 Hot Spot ROD was evaluated based on

25


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comments received at the public hearing and a recommendation from the New Bedford Harbor
Community Forum discussed in Section III of this Amendment.

As discussed in Section III, EPA's proposed Amendment is also the consensus
recommendation of the New Bedford Harbor Superfund Site Community Forum. Based on the Public
Hearing and comments received during the public comment period, it appears that the proposed
Amendment has broad community support. The proposed Amendment is also supported by the Mayor
of New Bedford and Congressman Barney Frank.

X. THE SELECTED REMEDY

After an extensive process of evaluating alternatives to the on-site incineration component of
the original remedy and developing a consensus among Site stakeholders, EPA has selected the
remedy described below as the best balance between the nine criteria. The selected remedy is a
removal and disposal alternative using a permitted off-site facility. The cleanup operations will
include the following activities:

1.	Upgrade Existing Site Facilities As Needed. To accommodate sediment handling and
dewatering activities is may be necessary to construct or improve access to the CDF and other areas
of the site. Treatment pads, temporary buildings and upgrades to site utilities may also be needed.

2.	Sediment Dewatering and Water Treatment. The Hot Spot sediments currently stored in
the Sawyer Street CDF are approximately 50% water, which is too wet to be accepted by a TSCA
permitted hazardous waste landfill. The sediments will be dewatered to that level which is in
compliance with the permits and other requirements for the selected off-site TSCA permitted landfill.
Options for dewatering the sediments will be evaluated during the design process. The sediment may
be dewatered in-situ by extracting water via installed well points, or by removing the sediment from
the CDF and mechanically dewatering it ex-situ, or a combination of in-situ and ex-situ dewatering.
Water extracted from the Hot Spot sediment during the dewatering operations will be treated in the
existing Sawyer Street wastewater treatment plant prior to discharge into the harbor.

3.	Transportation to an Off-Site TSCA Permitted Landfill. Following dewatering, the
sediments will be loaded into sealed containers for transport to a TSCA permitted off-site hazardous
waste landfill. Trucks leaving the Sawyer Street Site will be routed to minimize their impact to local
traffic

4.	Air Monitoring Program. There is a potential for air emissions of PCBs during the sediment
removal and dewatering activities. A comprehensive ambient air monitoring program will be
implemented during the sediment removal and dewatering operations to ensure that engineering
controls are effective at protecting site workers and the local community.

The time to complete the activities describe above has been estimated at no more than two years, and

26


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a cost of $14,800,000. EPA may use the Sawyer Street site, including the three cells of the CDF and
the water treatment plant to support Phase II of the harbor cleanup. The Upper and Lower Harbor
ROD for Phase II was released in September 1998 and calls for dredging an additional 450,000 cubic
yards of PCB-contaminated sediments from the harbor and containing the dredged sediments in
shoreline CDFs. The future use of the Sawyer Street site and facilities will be determined during
implementation of the Phase II remedy.

XI. STATUTORY DETERMINATIONS

The remedial action selected herein for implementation at the New Bedford Harbor Site is
consistent with CERCLA and, to the extent practicable, the NCP.

A.	The Selected Remedy is Protective of Human Health and the Environment

The selected remedy will be protective of human health and the environment. There will be
no Hot Spot sediments remaining at the Site after the cleanup is completed. Therefore, no risks to
the health of the community or the environment due to potential exposure to the Hot Spot sediments
will remain. There are no significant short-term risks to human health or the environment during
implementation of the selected remedy. The potential exposure of site workers and area residents to
contaminated sediments will be minimized by using safety plans that include air emission controls
and a network of ambient air monitors to assess potential releases to the air during cleanup
operations. Tables 9,10 and 11 summarize the various chemical, location and action specific ARARs
discussed below, as well as their impact on remedial activities.

B.	The Selected Remedy Attains or Appropriately Waives ARARs

This section briefly summarizes the most significant chemical, location and action specific
ARARs for the remedy.

Chemical-Specific ARARs

Chemical-specific ARARs govern the extent of site cleanup and provide either actual cleanup
levels or a basis for calculating such levels. These requirements are usually health- or risk-based
numerical values or methodologies which, when applied to site-specific conditions, result in
numerical values which help define the degree of cleanup.

There are no "applicable" or "relevant and appropriate" federal or state chemical-specific
ARARs for the selected remedy. All of the Hot Spot sediments currently contained in the Sawyer
Street CDF will be removed and transported to a TSCA permitted chemical waste landfill.

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Location-Specific ARARs

Location-specific ARARs are restrictions relating more directly to the geographical or
physical setting of the site. These locations include natural site features such as wetlands and flood
plains, as well as manmade features including existing landfills, disposal areas, and local historic
buildings. Location-specific ARARs are generally restrictions on the concentration of hazardous
substances or the conduct of activities solely because of the site's particular characteristics or location.
These ARARs provide a basis for assessing existing site conditions and subsequently aid in assessing
potential remedial alternatives.

Location-specific ARARs pertain to the site's location within a coastal flood plain, adjacent
to the Harbor. Federal ARARs address flood plain management, protection of fish and wildlife
resources, and coastal zone management. Alternatives located in a flood plain may not be selected
unless a determination is made that no practicable alternative exists outside the flood plain- Under
such circumstances the potential harm must be minimized and action taken to restore and preserve
natural and beneficial values. The U.S. Fish and Wildlife Service must be consulted regarding
preventing and mitigating any potential losses to fish and wildlife resources.

State ARARs address coastal zone management, work within flowed and filled tidelands, and
wetlands protection. The state wetlands protection statute identifies the following protected resource
areas that occur on or adjacent to the site: Land Subject to Coastal Storm Flowage, Land Under
Ocean, Designated Port Area, Coastal Beaches (including tidal flats), Coastal Bank (including a 100-
foot buffer zone inland from the edge of the bank), and Land Containing Shellfish.

Action-Specific ARARs

Action-specific ARARs are usually technology or activity-based limitations or requirements
that control actions at CERCLA sites. After remedial alternatives are developed, action-specific
ARARs pertaining to proposed site remedies provide a basis for assessing the feasibility and
effectiveness of the remedies. These requirements generally define acceptable treatment, storage, and
disposal procedures for PCB-contaminated and hazardous substances during the response action.

The primary action-specific ARARs are requirements regarding waste management and
treatment. These ARARs include PCB storage, treatment and disposal requirements under TSCA and
identification and regulation of characteristic hazardous waste under Massachusetts Hazardous Waste
Management standards.

TSCA requires that any PCB contaminated dredge spoil with a concentration of 50 ppm or
greater be disposed of either in an approved incinerator, an approved chemical waste landfill, or by
using a disposal method to be approved by the Regional Administrator. Approval must be based on
a finding that, based on technical, environmental, and economic considerations, disposal in an
incinerator or chemical waste landfill is not reasonable and appropriate, and that the alternative
disposal method will provide adequate protection to health and the environment.

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The selected remedy complies with one ofthe TSCA approved disposal methods, i.e., disposal
in an approved chemical waste landfill. The selected remedy requires temporary storage of the PCB
sediment for greater than one year. TSCA regulations, 40 CFR 761.65(2), allow for a one-year
extension of TSCA's one-year storage limitation upon the written notice to the Regional
Administrator of the reasons for the delay in disposing of the material.

Massachusetts Hazardous Waste ARAR's apply to all non-PCB contaminants that meet
characteristic hazardous waste standards. Recent toxicity characteristic leaching procedure (TCLP)
data on the dredged sediment samples show the sediment does not meet the definition of a RCRA
characteristic waste. Toxicity characteristic (TC) constituent concentrations are below TC regulatory
limits for hazardous waste. Sediments, process wastes, and discharges from monitoring, operations,
and/or maintenance will be tested for hazardous constituents. Any characteristic wastes identified will
be stored, treated, and/or disposed of in compliance with state hazardous waste requirements.

Other federal and state action-specific ARARs include air quality and air pollution
requirements, which preclude the release of PCBs and other contaminants. Air emissions from the
proposed alternatives may result from Hot Spot sediment handling/dewatering operations before
off-site transportation and disposal. Air emissions will be addressed by using safety plans that include
air emission controls and a network of ambient air monitors to assess potential releases to the air
during handling/dewatering

Water discharges are regulated under state and federal water quality ARARs. Water treatment
at the facility's on-site water treatment plant will be required to treat the water derived from the Hot
Spot sediment dewatering operation. Operation of the treatment plant requires a waiver of a provision
of the National Pollutant Discharge Elimination System requirements of the federal Clean Water Act
(CWA), Section 402. The provision prohibits new discharges into waters that do not meet applicable
water quality criteria, unless certain conditions are met (40 CFR 122.4(i)). The plan proposed that
a protectiveness waiver under Section 121(d)(4)(B) of CERCLA be used for this ARAR since
compliance would essentially prevent the cleanup of this Site and result in greater risk to human
health and the environment than other alternatives. The issue is the result of the degraded water
quality in the Harbor, where permitting any new discharge is not possible unless the Harbor's waters
reach water quality standards or until the other conditions of the regulations are met. Neither of these
conditions are likely to be accomplished in a reasonable time. Therefore, this ARAR is waived.

Furthermore, since New Bedford Harbor water quality is so degraded as to preclude diluting
any proposed discharge, Section 402 of the CWA requires that discharges meet ambient water quality
criteria (WQC) at the discharge point. Except for copper and PCBs, it is expected that the treatment
facility can attain compliance with WQC during the remedial activities. Consistent with Section 303
of the CWA and its Total Maximum Daily Load (TMDL) approach, it is proposed that discharge
limits for the water treatment plant be implemented that are below current background levels of
copper and PCBs, but above WQC. This approach helps achieve attainment of ambient WQC
throughout the waterbody in a phased or step-wise approach, consistent with EPA's

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September 1998 Record of Decision for the Upper and Lower Harbor Unit (USEPA, 1998b). The
copper and PCBs that will be discharged from the treatment plant will be offset by the copper and
PCB contaminated sediments which have been permanently removed from the Harbor as part of the
1994/1995 Hot Spot dredging operation..

Federal PCB policies and guidance regarding PCB air releases and treatment technologies
for CERCLA remedial actions win be considered. Massachusetts guidelines to be considered include
ambient air limits and noise levels. The Allowable Ambient Limits and Threshold Exposure Limits
will be considered for air emissions. Revised TEF and the air dioxin guideline Will be considered
for evaluation of air emissions. Noise levels will be minimized to the extent practicable.

C.	The Selected Remedial Action is Cost-Effective

The selected remedy is cost-effective since it provides overall effectiveness proportional to
its cost. The costs for the eleven cleanup plans evaluated range from $5.4 minion to $48.5 minion.
The two cleanup alternatives at the low end of the range (HS-1 at $5.4 million and HS-5 at $10.3
million), are alternatives that do not treat or remove the Hot Spot sediments from the Site. The
selected remedy, at an estimated cost of $14.8 million, does not treat the sediments but does remove
them from the site providing a higher level of protection than alternatives HS-1 and HS-5. The
remaining eight cleanup plans evaluated are treatment alternatives ranging in cost from $19 million
to $48.5 million. Since the selected remedy removes all of the Hot Spot sediments from the Sawyer
Street CDF and transports them off-site, there will be no remaining risks at the Site. Therefore , a
more costly treatment alternative will not provide more protection to the community or the harbor.

D.	The Selected Remedy Utilizes Permanent Solutions and Alternative Treatment or

Resource Recovery Technologies to the Maximum Extent Practicable

The selected remedy provides a permanent solution for the Hot Spot sediments currently
stored on the Sawyer Street CDF. It permanently isolates these sediments from human and
environmental receptors by containing them in a TSCA permitted off-site chemical waste landfill.
Alternatives involving on-site treatment of the Hot Spot sediment were considered, but lack the
community support that would make them a practicable option at this Site. Although the Hot Spot
sediments will not be treated, a large volume of PCBs and metals contaminated water which was
decanted during the dredging operation has been treated to meet stringent discharge standards.
Furthermore, the contaminated water from the dewatering operations will also be treated to meet
stringent discharge standards.

E.	The Selected Remedy Does Not Satisfy the Preference for Treatment as a Principle

Element

The selected remedy does not use treatment of the PCB-contaminated sediments as a principle
element of the remedy, although as described above, decanted water from the Hot Spot dredging
operations was treated. In addition, the Hot Spot sediment dewatering to be performed as

30


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a part of the selected remedy will involve extensive treatment prior to discharging to the harbor.
Protection against the future ecological and human health risks posed by the Hot Spot sediments is
provided by removing them from the Sawyer Street CDF and permanently isolating them in a TSCA
permitted off-site chemical waste landfill.

XII. DOCUMENTATION OF NO SIGNIFICANT CHANGES

The Proposed Plan to Amend the 1990 Cleanup Plan was released for public comment in
August 1998. The proposed change calls for transporting the Hot Spot sediments off-site to a TSCA
permitted chemical waste landfill rather than on-site incineration as called for in the 1990 cleanup
plan. The amended cleanup plan includes:

1.	Upgrade Existing Site Facilities As Needed. To accommodate sediment handling and
dewatering activities it may be necessary to construct or improve access to the CDF
and other areas of the site. Treatment pads, temporary buildings and upgrades to site
utilities may also be needed.

2.	Sediment Dewatering and Water Treatment. The Hot Spot sediments currently stored
in the Sawyer Street CDF are approximately 50% water, which is too wet to be
accepted by a TSCA permitted hazardous waste landfill. The sediments will be
dewatered to that level which is in compliance with the permits and other
requirements for the selected off-site TSCA permitted landfill. Options for dewatering
the sediments will be evaluated during the design process. The sediment may be
dewatered in-situ by extracting water via installed well points, or by removing the
sediment from the CDF and mechanically dewatering it ex-situ, or a combination of
in-situ and ex-situ dewatering. Water extracted from the Hot Spot sediment during the
dewatering operations will be treated in the existing Sawyer Street wastewater
treatment plant prior to discharge into the harbor.

3.	Transportation to an Off-Site TSCA Permitted Landfill. Following dewatering, the
sediments will be loaded into sealed containers for transport to a TSCA permitted
off-site hazardous waste landfill. Trucks leaving the Sawyer Street Site will be routed
to minimize their impact to local traffic.

4.	Air Monitoring. There is a potential for air emissions of PCBs during the sediment
removal and dewatering activities. A comprehensive ambient air monitoring program
will be implemented during the sediment removal and dewatering operations to ensure
that engineering controls are effective at protecting site workers and the local
community.

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EPA determined that, based on public comment, no significant change is needed to the
proposed amended cleanup plan. EPA will evaluate potential dewatering strategies further during the
design phase. Based on the results of these further evaluations, EPA may decide to dewater the
sediments before removing them from the CDF by extracting water from well points or mechanically
dewatering the sediments ex-situ as discussed above or a combination of in-situ and ex-situ
dewatering.

XIII. STATE ROLE

The Massachusetts Department of Environmental Protection has reviewed the remedy change
and concurs with the selected remedy described in Section X of this Amendment. A copy of the State
concurrence letter is attached as Appendix C.

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M5SHAUM POINT

APfttOXIMAtC SCAU IN Ft FT


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Figure 3: Sawyer Street Facility
Sawyer Street

Water Treatment Bufldlng

CDF where Hot Spot sediments
are currently stored

Upper New Bedford Harbor
{Acushnet River and Estuary)


-------
m MONITORING ¦

mm





/IR MONnOnWC

STXnON
(MOffitf LOCATION)

f CONFKD
OW>OSAl

.

PAOUTY

conncc* dispose r/wrt

COl #3

coi.lt

CONFINED
06P0SAI
mouiY



COL |2



V



SCAil IN FEET

Figure 4

tOf BEDFORD HARBOR
HOT SPOT raASBUTY STUDY ADOBCXM

EXISTING SITE CONDITIONS
SAWYER STREET LOCATION
NEW BEDFORD HARBOR
SITE

F087EH mweum ENVftONMENTAl. corporation
US EPA ARCS 1 PROGRAM


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Table 1

Summary of PCB and Oil and Grease Data for the Hot Spot Sediment



1 si mid 2nd Pilot Smd\

3rd Pilot S(ud\

1st &
2nd
Pilot
Smd\

3rd
Pilot
Stiid\



( oiKvnlralion Ranye ippnu

( oiKvnlr;

lion RaiiL!o

Awrauo

Awra^e

I'aiaillekT

Minimum

\la\imum

Minimum

Maximum

( OI1C
I ppill I

('one
(ppm)

PCB

1,600

2,990

3,800

7,700

2,308

5,667

Oil and Grease

11,700

21,800

28,100

36,900

17,863

32,392

Table 2

PCB and Oil and Grease Results for the USACE Samples
Collected in June 1995



Siiinnle N ii in her ;ind ( oneeni

rntion (nniii)

Cone.

A\er:i«ie

P;i r;i meter

1

2

3

4

5

6

K:ini>e (ppm)

( one. (ppm)

Total PCB

492

763

3,005

14,412

10,924

7,405

492 - 14,412

6,167

Oil & Grease

780

980

14,000

30,000

34,000

22,000

780 - 34,000

16,960

Table 3

Summary of Chlorinated Benzene Data for the Hot Spot Sediment

(Third Pilot Study)

P;i r;i meter

Minimum

M;i\imiim

A\er:iiie



( one. (ppm)

( one. (ppm)

( one. (ppm)

1,3 -Dichlorobenzene

3.9

10

6.8

1,4 -Dichlorobenzene

13

28

20

1,2 -Dichlorobenzene

0.32

0.90

0.49

1,2,4-Trichlorobenzene

7.7

38

15


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Table 4

Summary of PAH Concentrations for the
Hot Spot Sediment
(Third Pilot Study)

I'iini meter

Minimum

Minimum

A\er:i}>e



Cone. (ppm)

Cone,
(ppm)

Cone, (ppm)

Naphthalene

0.31

0.78

0.50

2-Methylnaphthalene

0.50

1.3

0.84

Acenaphthylene

0.16

8.2

1.4

Acenaphthene

0.45

1.9

0.91

Fluorene

0.44

1.7

0.88

Phenanthrene

1.1

6.4

2.3

Anthracene

0.3

1.7

0.62

Fluoranthene

1.8

12

3.9

Pyrene

2.6

8.2

4.8

Benzo(a)anthracene

1.9

6.4

3.7

Chrysene

2.1

7.3

4.1

Benzo(b)fluoranthene

2.0

10

4.2

Benzo(k)fluoranthene

1.5

8.5

3.9

Benzo(a)pyrene

1.8

6.6

3.7

Indeno( l,2,3-cd)pyrene

0.13

0.72

0.28

Didenz(a,h)anthracene

0.07

3.3

1.1

Benzo(g.h.i)perylene

0.08

0.4

0.22

Total PAH:





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Table 5

Summary of {2, 3, 7, 8 Substituted Isomers} Data
for the Hot Spot Sediment
(Third Pilot Study)

I'iini meter

3rd Pilot Si mlv

3"' Pilot Study 1 KQ



Cone, (pii/iiin) A\er:i»e

(|)»/»m)

2,3,7,8-TCDD

3.6

3.6

1,2,3,7,8-PeCDD

9.1

4.5

1,2,3,4,7,8-HxCDD

7.9

0.79

1,2,3,6,7,8-HxCDD

31

3.1

1,2,3,7,8,9-HxCDD

20

2.0

1,2,3,4,6,7,8-HpCDD

386

3.9

OCDD

3,000

3

2,3,7,8-TCDF

690

69

1,2,3,7,8-PeCDF

276

14

2,3,4,7,8-PeCDF

1,520

760

1,2,3,4,7,8-HxCDF

4,440

444

1,2,3,6,7,8-HxCDF

1,920

192

2,3,4,6,7,8-HxCDF

844

84

1,2,3,7,8,9-HxCDF

986

99

1,2,3,4,6,7,8-HpCDF

1,680

17

1,2,3,4,7,8,9-HpCDF

1,260

13

OCDF

1.860

1.9

Total:

18.933

1.714


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Table 6

Summary of Dioxin and Furan Data (Totals)
for the Hot Spot Sediment
(Third Pilot Study)

Pa ram el or

3rd Pilot



Siudv Average (ng/gm)

Total TCDD

17

Total PeCDD

50

Total-HxCDD

284

Total-HpCDD

770

OCDD

3,000

Total TCDF

5,080

Total PeCDF

3,920

Total-HxCDF

10,520

Total-HpCDF

4,580

OCDF

1,860

Total PCDD/PCDF

30,081

(pg/gm):




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Table 7

Summary of Metals Data for the Hot Spot Sediment
(Third Pilot Study)

I'si rsimeter

Minimum
('oiHTiilnilion

Miiximiim
(oiHTiili'iilion

A\ersi«»e
('oiHTiilnition

Aluminum

13,300

17,200

15,658

Antimony

2.9

8.7

5.1

Arsenic

10.2

14.4

11.9

Barium

145

221

159

Beryllium

0.49

0.55

0.51

Cadmium

13.4

17.0

15.1

Calcium

5,910

8,960

7,275

Chromium

295

366

330

Cobalt

7.3

9.3

8.3

Copper

656

861

762

Iron

21,200

28,000

25,533

Lead

550

632

600

Magnesium

6,980

9,210

8,278

Manganese

200

243

223

Mercury

0.87

3.6

1.3

Nickel

56.7

73.7

64.6

Potassium

3,040

3,950

3,458

Selenium

2.4

3.6

3.0

Silver

2.5

4.4

3.2

Sodium

12,200

16,900

14,083

Thallium

ND

0

ND

Vanadium

48.6

69.2

56.8

Zinc

1,720

2,130

1,924

Results are reported in mg/kg
ND = Not Detected


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Table 8

TCLP Results for Hot Spot Sediment
(Third Pilot Study)

TCI.I* Ansilvlc

Uoi>iil
-------
Table 9

Chemical Specific ARARs and TBCs

Requirement

Citation

Stains

Requirement Synopsis

Actions To Be Taken To Attain AUAUs

Federal

Cancer Slope Factors (CSFs)



To Be
Considered

These am guidance values used to evaluate the potential
carcinogenic hazard caused by exposure to
contaminants.

Operation and maintenance of the facility will minimize
exposure to potential receptors.

Reference Doses (RfDs)



To Be
Considered

These are guidance values used to evaluate the potential
non-carcinogenic hazard caused by exposure to
contaminants.

Operation and maintenance of the facility will minimize
exposure to potential receptors.

Massachusetts

There are no state chemical-specific ARARs.


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Table 10

Location Specific ARARs and TBCs

Requirement

Citation

Status

Ueq ii i rem en t Sy n o ps is

Actions To lie Taken To Attain
ARAUs

Federal

Floodplain Management - Executive
Order 11988

40 CFR Part 6,
Appendix A

Applicable

Federal agencies are required to reduce the risk of flood
loss, minimize impact of floods, and restore and
preserve the natural and beneficial values of
floodplains.

The facility lies within the 100-year coastal
floodplain. The potential effects of any action
must be evaluted to ensure that the planning
and decision making reflect consideration of
flood hazards and floodplain management,
including restoration and perservation of
natual and beneficial values, wherever
feasible.

Fish and Wildlife Coordination Act

16 USC Part
661 et seq.; 40
CFR 6.302

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.

Appropriate agencies will be consulted prior
to implementation to find ways to minimize
adverse effects to fish and wildlife from
facility operation and maintenance.

Coastal Zone Management Act

16 USC Parts
1451 et seq.

Applicable

Requires that any actions must be conducted in a
manner cinsistent with state approved management
programs.

The entire site is located in a coastal zone
management area, therefore applicable coastal
zone management requirements will be met.

Massachusetts

Wetlands Protection Act

131MGL 40;
310 CMR
10.00

Applicable

These standards regulate the dredging, filling, altering,
or polluting of coastal and inland wetland resource
areas. Protected resource area within and adjacent
to the site include: Land Subject to Coastal Storm
Flowage (Sec.l0.02(l)(d)), Land Under Ocean (Sec.
10.25), Designated Port Area (Sec. 10.26), Coastal
Beaches (including tidal flats)(Sec. 10.27), Coastal
Bank (Sec. 10.30), and Land Containing Shellfish (Sec
10.34). There is a 100-foot buffer zone landward of the
Coastal Bank.

Operation and maintenance of the facility
within the 100-year floodplain and the
100-foot buffer zone to the coastal bank will
comply with the substantive requirements of
the standards. Dewatering and loading
facilities will be protected from flooding.

Coastal Zone Management

301 CMR
21.00

Applicable

Requires that any actions must be conducted in a
manner consistent with state approved management
programs.

The entire site is located in a coastal zone
management area, therefore substantive
coastal zone management requirements will
be met.


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Table 10, Continued
Location Specific ARARs and TBCs

Requirement

Citation

Status

Requirement Synopsis

Actions To lie Taken To Attain AUAUs

Waterways

310 CMR 9.00

Applicable

Sets forth criteria for work within flowed and filled
tidelands. Waterways concern focus on the long term
viability of marine uses and protecting public rights in
tidelands, including fishing and access.

Actions within filled and flowed tidelands at the site
will comply with the regulation's environmental
standards.


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Table 11

Action Specific ARARs and TBCs

.Medium/Authority

Citation

Status

Ueq ii i rem en 1 S v n o ps is

Actions To lie Taken To Attain
AUARs

Federal

Toxic Substances Control
Act (TSCA), Disposal
Requirements- PCBs
Contaminated Dredged
Spoil

15 USC 2601-
2692; 40 CFR
761.60(a)(5)

Applicable

Dredged materialls with PCBs at concentrations
greater than 50 pprn must be disposed of either in an
incinerator, or in a chemical waste landfill, or, when
the first 2 options are not reasonable and appropriate,
by a disposal method which will protect health and the
environment.

Sediments will be disposed of in a permitted TSCA
facility.

TSCA PCB Storgae
Regulations

40 CFR
761.65 (a)

Applicable

PCBs stored for disposal must be properly disposed of
within one-year of being placed in storage. A one-year
extension is granted upon notification to the Regional
Administrator.

If the remedy requires on-site storage of PCB
contaminated material for more than one-year an
extension will be required.

TSCA PCB Storage
Regulations

40 CFR
761.65
(b)(l)(i)

Applicable

Storage facilities must have adequate roof and walls to
prevent rainwater from reaching the stored PCBs.

Present cover, if properly maintained, does prevent
rainwater from reaching the stored PCBs.
Rainwater that falls directly on Cell # 1 may
reauire treatment if contamination occurs.

TSCA PCB Storage
Regulations

40 CFR
761.65(b)(1)

Applicable

Storage facilities cannot have floor drains or openings
that would allow liquids to flow from the storage area.

Cell # 1 has two continuous, impermeable bottom
liners.


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Table 11, Continued
Action Specific ARARs and TBCs

Medium/Authority

Citation

Status

Requirement Synopsis

Actions To Be Taken To Attain ARARs

TSCA PCB Storage
Regulations

40 CFR
761.65 (b)(1)
fiv)

Applicable

Storage facilities must have floors and curbs
made of smooth impervious material to prevent
PCB penetration.

Cell #1 has two liners made of F1DPE which is smooth
and impermeable.

TSCA PCB Storage
Regulations

40 CFR
761.65 (b)(1)
(v)

Applicable

Storage facilities must not be located below the
100-year floodwater elevation.

The CDF's top-of-berm elevation is two feet higher
than the 100-year flood elevation. If a dewatering
facility is needed it will constructed so that it is above
the 100-year flood elevation.

TSCA PCB Commercial
Storage Regulations

40 CFR
761.65 (d)(2)
(ii)

Relevant and
Appropriate

CDF facilities must possess the capacity to
handle the maximum quantity of PCB waste
that will be handled at any one time.

The CDF has the capacity to contain all of the dredged
hot spot sediments.

TSCA PCB Commercial
Storage Regulations

40 CFR
761.65 (d)(2)
(vi)

Relevant and
Appropriate

T'he operation of a commercial storage facility
must not pose an unreasonable risk of injury to
health or the environment.

The cover for Cell #1 would have to be extended to
overlap the cell walls to prevent persons from falling
in. Air, groundwater, and surface water monitoring in
the vicinity of the CDF will be continued to verify
protectiveness of controls until all of the sediments are
removed off-site.

TSCA PCB Spill Cleanup
Policy

40 CFR
761.120 -.135

Relevant and
Appropriate

Establishes criteria to determine adequacy of
the cleanup of spills (occurring after 5/4/87)
from the release of materials with > 50 ppm
PCBs.

Although this policy is directed at electrical
equipment-type spills, it will be considered to address
any PCB leakage or spillage from the CDF.

Clean Water Act (CWA)
Section 402, National
Pollutant Discharge
Elimination System
(NPDES)

33 USC 1342;
40 CFR 122-
125, 131

Applicable

These standards govern discharge of water into
surface waters. Due to the degraded nature of
New Bedford Flarbor waters, regulated
discharges into the waterway must meet
ambient water quality criteria (WQC) at the
discharge point.

Any drainage off the site which becomes contaminated
by the stored sediments and any process or dewatering
discharge will be treated by the on-site treatment plant
and discharged to the harbor. Ambient water quality
criteria, particularly for copper and PCBs, will be
addressed through a phased Total Maximum Daily
Load (TMDL) approach

CWA, Section 402,
NPDES, Prohibitions

40 CFR
122.4(i)

Applicable

Prohibition on new discharges into waters that
do not meet applicable water quality criteria
(WQC) unless certain conditions are met.

A waiver will be sought for this provision since
compliance would prevent cleanup of the site until
Flarbor waters either reach water quality standards or
until the other conditions in the regulation are met.
Neither of which can be accomplished in a reasonable
time frame.


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Table 11, Continued
Action Specific ARARs and TBCs

Medium/Authority

Citation

Status

Ueq ii i rem en t Sy n o ps is

Actions To lie Taken To Attain AUAUs

Clean Air Act (CAA),
National Emmissions
Standards for Hazardous Air
Pollutants (NESHAPS)

42 USC 7401
et seq.; 40
CFR Part 61

Applicable

NESHAPS are a set of emissions standards for
specific chemicals, including PCBs, from
specific production activities.

Monitoring of air emissions from the facility,
including from the dewatering process, will be used to
assess compliance with these standards. Operation and
maintenance activities will be carried out in a manner
which will minimize potential air releases.

Guidance on Remedial
Actions for Superfund Sites
with PCB Contamination
(OSWER Directive)



To Be
Considered

Describes the recommended approach for
evaluating and remediating CERCLA sites with
PCB contamination.

This guidance will be considered when evaluating
PCB issues associated with removal, dewatering, and
offsite disposal of contaminated sediment.

Massachusetts

Hazardous Waste
Management - Identification
and Listing

21C MGL 4
and 6; 310
CMR 30.100

Relevant and
Appropriate

Establishes standards for identifying and listing
hazardous waste.

Monitoring will assess whether hazardous wastes are
present in discharges or dewatering wastes from the
facility.

Hazardous Waste
Management - Requirements
for Generators of Hazardous
Waste

21C MGL 4
and 6; 310
CMR 30.300

Relevant and
Appropriate

Establishes standards for various classes of
generators.

Any hazardous waste generated from the facility will
be managed in accordance with the substantive
requirements of these regulations.

Hazardous Waste
Management - Management
Standards for all Hazardous
Waste Facilities

21C MGL 4
and 6; 310
CMR 30.500

Relevant and
Appropriate

Establishes standards for treatment, storage, and
disposal of hazardous waste, and establishes
standards for closure, post closure and ground
water monitoring. Sec. 30.501(3)(a) exempts
facilities which treat, dispose or store hazardous
waste containing 50 ppm or more PCBs if they
are adequately regulated under TSCA, 40 CFR
761.

Any non-PCB hazardous waft which is treated,stored
or disposed of at this facility as part of the remedy will
be managed in accordance with the substantive
requirements of this section.

Supplemental Requirements
for Hazardous Waste
Management Facilities

21 MGL
27(12), 34 and
43; 314 CMR
8.00

Relevant and
Appropriate

This regulation outlines the additional
requirements that must be satisfied in order for a
RCRA facility to comply with the NPDES
regulation.

The substantive requirements of these provisions will
be met.


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Table 11, Continued
Action Specific ARARs and TBCs

Medium/Authority

Citation

Status

Requirement Synopsis

Actions To Be Taken To Attain ARARs

Surface Water Discharge

21 MGL
23(12) and 34;
314 CMR 1.00-
7.00

Applicable

This section outlines the requirements for
obtaining a National Pollutant Discharge
Elimination System (NPDES) permit in
Massachusetts. The waters of New
Bedford Harbor adjacent to the site are
classified as SB.

Any drainage off the site which becomes contaminated
by the stored sediments and the water from dewatering
will be treated by the on- site treatment plant and
discharged in accordance with the substantive
provisions of the regulations.

Surface Water Quality
Standards

27 MGL 27;
314 CMR 4.00

Applicable

MADEP surface water quality standards
incorporate the federal AWQC as
standards for surface waters of the state.
Standards establish acute and chronic
effects on aquatic life for contaminants
including PCBs, cadmium, copper, and
lead.

Ambient water quality criteria, particularly for copper,
will be addressed through a phased Total Maximum
Daily Load (TMDL) approach.

Rules for the Prevention and
Control of Oil Pollution in
the Waters of the
Commonwealth

21 MGL 26-
53; 314 CMR
15.000

Applicable

Regulates the discharge of oil or sewage,
industrial waste or other material
containing oil into waters of the
Commonwealth.

The remedy will comply with the substantive
requirements of the provisions.

Massachusetts Water Quality
Standards Implementation
Policy of Toxic Pollutants in
Surface Waters (2/23/90)



To Be
Considered

Recommends surface water quality
standards for specified contaminants and
implementation to achieve standards.

This implementation policy and appropriate standards
will be considered for alternatives which impact
surface water quality.

Ambient Air Quality
Standards

111 MGL
142D; 310
CMR 6.00

Applicable

Establishes ambient air level for
contaminants including PCBs and
particulates.

Emissions from the CDF and the dewatering facility
will comply with these standards. Dust suppression
will be used to reduce particulate emissions.

Air Pollution Control

111 MGL
142A-J, 310
CMR 7.00

Applicable

Standards for sources of emissions.
Pollution abatement controls may be
required.

Operation and maintenance of the CDF and the
dewatering facility will comply with the substantive
requirements of these provisions.

MADEP - Recommended
Threshold Effect Exposure
Limits (TELs) and Allowable
Ambient Limits (AALs)



To Be
Considered

Establishes exposure concentrations for
air contaminants developed and
recommended by the Office of Research
and Standards to protect public health.

On-site containment and dewatering technologies
having air emissions will consider the TELs and
AALs.


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Table 11, Continued
Action Specific ARARs and TBCs

Medium/Authority

Citation

Status

Kcq u irein cn t Sv no ps is

Actions To Be Taken To Attain ARARs

DACQ Policy (90.001):
Allowable Sound
Emmissions (2/1/90)



To Be
Considered

Establishes guidelines where the source of new
noise should not emit more than 10 decibels
above the existing (background) level.

Site, operations noise level will be minimized and will
follow the suggested noise limit to the extent
practicable.

MA DEP - Assessment and
Control of Dioxin in
Massachusetts (10/31/91)



To Be
Considered

Recommends revisions to Toxicity Equivalence
Factors (TEFs) for polychlorinated
dibenzodioxins (PCDDs) and dibenzofurans;
(PCDFs) in air/emissions.

Alternatives with on-site sediment dewatering
technologies that potentially include air emissions of
PCDDs and PCDFs will consider the revised TEFs for
evaluating the toxicity of these air emissions.


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Appendix A - Responsiveness Summary

New Bedford Harbor Superfund Site
Amended Record of Decision for the Hot Spot Sediments


-------
1.0 INTRODUCTION

This responsiveness summary summarizes and provides EPA's responses to formal
comments regarding the Proposed Plan to amend the 1990 cleanup plan for the New Bedford
Harbor Hot Spot Sediments. These comments were received during the period August 27-
September 25, 1998. The comments and responses are organized into the following categories.

Section

Tvpe of Comment

Paae

2.1

Citizen

A-l

2.2

Local Government

A-l

2.3

State Government

A-8

2.4

Congressional

A-9

2.5

AVX Corporation

A-10

2.0	SUMMARY OF COMMENTS RECEIVED DURING THE AUGUST 27-
SEPTEMBER 25,1998 PUBLIC COMMENT PERIOD

2.1	Citizen Comments

2.1.1 Mr. Barrett:

Mr. Barrett supports the Proposed Plan. He commented that in his opinion off-site
landfilling would be the fastest, the safest and the most economical way to dispose of the Hot
Spot sediments. However, he commented further that the off-site landfill chosen should not
necessarily be the least expensive, but, the most secluded site and the least likely to cause
any damage to the environment. He also commented that he believes transport by rail will
be the safest and less likeliness for accidents that endanger public safety.

EPA Response:

The selection of an off-site landfill will be based on a competitive bidding process which
involves an evaluation of the off-site transportation and disposal proposals received from various
Offerors during that competitive bidding process. Price is one of five criteria which will be used
to evaluate the various proposals. The other four criteria are: technical approach; relevant
experience; management approach, and available resources. Lowest price does not guarantee
award of the off-site disposal contract.

A-l


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The selection of the off-site landfill must be done in accordance with EPA Off-site Rule
which became effective on October 22, 1993. The purpose of the Off-site Rule is to ensure that
wastes shipped off-site from Superfund clean-ups are sent to environmentally sound waste
management facilities. The rule describes the criteria that off-site waste management facilities
must meet when taking waste from Superfund sites and the procedures that EPA must follow
when making determinations on the acceptability of these facilities. Any facility which meets the
requirements of the Off-site rule is acceptable to EPA. A requirement that the site be the most
secluded site is not a criteria under the Off-site Rule.

EPA appreciates your concern over the possibility of an accident occurring while
transporting the hot spot sediments to a landfill. EPA believes that both trucking and rail are safe
means of transporting the dewatered Hot Spot sediments to a landfill. Traffic accidents involving
hazardous waste transportation are very rare events.

2.1.2	Ms. Jacobsen:

Ms. Jacobsen supports the Proposed Plan. She commented that she is very happy that
the situation is finally being addressed and resolved.

EPA Response:

The EPA appreciates your support for the Proposed Plan.

2.1.3	Ms. Kirk

Ms Kirk commented that as a member of Concerned Parents of Fairhaven and the
New Bedford Harbor Superfund Site Community Forum (Forum) she is disappointed and
opposes the Proposed Plan. She commented further that in 1993, community groups wanted
EPA to find in innovative, non-incineration PCB destruction technology that could be used
on-site and that landfilling was not an alternative favored by the community groups. She
discussed the creation of the Forum and the results of innovative technology pilot scale
testing performed by EPA at the New Bedford Harbor site which concluded that there were
innovative technologies that could be safely used on-site at full scale. Ms Kirk concluded her
comments with the following:

"In conclusion, I am disappointed in the decision of the majority of the Forum
members to off-site landfill. In my mind, landfill does not treat or destroy. The hot
spot sediments will be buried forever. To send it an off-site facility adds insult to
injury. It simply sends a problem created in New Bedford to another community.
Off-site landfill goes against our mission since the beginning and we demonstrated
that there are alternative, innovative technologies that could have been chosen that
could have destroyed PCB's and been safe for human health and the environment. It
was a rushed decision, with a lot of misinformation and fear fed to a community

A-2


-------
about health and safety issues that were resolved long before. The neighborhood that
came to these last meetings was not involved from the beginning and was not part of
our learning process. Off-site landfilling will move the problem but does not solve the
problem."

EPA Response

EPA agrees that the results of pilot scale studies of innovative treatment technologies did
show that there are non-incineration destruction technologies which EPA believes could be safely
implemented on-site to destroy the PCB-contarninated hot spot sediments. Although EPA is also
disappointed that a treatment alternative which is acceptable to the community could not be
found, we do believe that the off-site landfilling alternative does provide the beast balance among
the nine NCP remedy selection criteria. EPA's rationale for selecting the off-site landfilling
alternative, using the NCP criteria, is provided on page 6 of the August 1998 Proposed Plan.

2.1.4	Mr. Kopcych

Mr. Kopeych commented at the public hearing that he is in favor of dewatering the
sediments, placing them in sealed containers and transporting them off-site. He commented
further that he would like to see the dewatered sediments taken over to the New Bedford
rail yard which he said the city owns and which is also contaminated with PCB's. He would
like the sediment to be shipped out of the city by rail from the New Bedford rail yard. He
believes the city is allowed to charge a tipping fee, which would assists them in cleaning up
the PCB contamination at the rail yard.

EPA Response

As discussed in EPA's response to Mr. Barrett's comments above, the transportation
component of the Proposed Plan will be determined as part of a competitive bidding process.
EPA has no objection to bidders including the use of the New Bedford rail yard in their proposals
provided that it can be demonstrated that the rail yard is an approved facility in compliance with
all appropriate local and state regulations.

2.1.5	Mr. Lapointe

Mr. Lapointe provided verbal comments at the public hearing. Mr Lapointe's
comments appear to support the proposed plan. He stated:

"I wish they would just take it out of the site, bring it to wherever they bring it. Just
don't burn it. Dioxin scares me."

EPA Response

A-3


-------
EPA appreciates your support for the Proposed Plan. The Proposed Plan does not include
burning the Hot Spot sediments. The sediments will be transported to a TSCA permitted chemical
waste landfill.

2.1.6	Mr. Nadeau

Mr. Nadeau provided verbal comments at the public hearing. Mr. Nadeau's supports
the proposed plan. However, he did not believe that the hearing was adequately publicized.
He stated that his name is on the mailing list, but, he never received a letter notifying him of
the public hearing.

EPA Response

EPA is disappointed to hear that you did not receive notice of the public informational
meeting and hearing. EPA sent out notices to over 800 people, advertised the meeting in the local
paper and sent out press releases to local radio stations. We will make sure that you are on our
mailing list and receive all future planned mailings and notices of any future public hearings.

2.1.7	Mr. Rusinoski

Mr. Rusinoski provided oral comments at the public hearing and written comments
in a letter dated September 14,1998. Mr. Rusinoski does not agree with EPA's Proposed
Plan. Mr. Rusinoski believes a better approach is to deposit the Hot Spot sediments in a
lined cofferdam which could be used in the construction of a pier or wharf north and east of
Fairhaven Hardware, on the New Bedford and Fairhaven bridge.

EPA Response

EPA believes that transporting the Hot Spot sediments to an off-site landfal provides
greater long-term protection of human health and the environment than the approach suggested
by Mr. Rusinoski. Although the construction of a pier or a wharf was not discussed with the
Forum and the community, on-site containment was discussed and is one of the alternatives that
EPA evaluated in the December 1997 Hot Spot Feasibility Study Addendum Report. On-site
containment is not acceptable to the Forum and the majority of public comments received support
off-site landfilling.

2.1.8	Ms. Sanz

Ms. Sanz submitted written comments in a letter to EPA dated September 23,1998.
She stated:

"As a citizen member of the New Bedford Harbor Superfund Community Forum, I

A-4


-------
am extremely disappointed in the Forum's recommendation to the EPA. The Forum
followed the process we all agreed upon to find a technology, alternative to on-site
incineration, which would clean up the hot spot material stored in a CDF. Viable
alternatives were found after lengthy and costly treatability studies. But at the very
last moment and after no study of landfill, the majority decision was to recommend
landfill, a decision, I believe, that was forced by the political motives of some
members of the Forum.

The Forum process worked in general, and my hope now is that what was learned
from both the process and the technology studies will be applied to other Superfund
sites across the country."

EPA Response

As stated above in EPA's response to Ms. Kirk's comments, we are also disappointed that
we could not find a on-site treatment technology that is acceptable to the community. EPA does
not agree with the comment that landfilling received no study. The Proposed Plan, off-site
landfilling, was evaluated in the December 1997 Feasibility Study Addendum Report and
discussed and compared against the other alternatives at several of the Forum meetings.

2.1.9 Mr. Simmons

Mr. Simmons provided oral comments and submitted written comments at the public
hearing. He read a comment letter submitted by a Mr. Barret. A summary of Mr. Barret's
comments and EPA's response is provided above in section 2.1.1. Mr. Simmons also read a
comment letter submitted by a Ms. And Mr. Sylvia. A summary of Ms. And Mr. Sylvia's
comments and EPA's response is provided below in section 2.1.11. Mr. Simons provided
comments on behalf of Hands Across the River Coalition. Hands Across the River is
generally supportive of the Proposed Plan. But, they request that the sediments be
transported out of New Bedford via rail utilizing the New Bedford rail yard and that the
sediments be transported to a landfill in the state of Nevada. He also stated that:

"I think in my opinion, aside from Hands Across the River, that everything that
we've looked at, the safest, fastest, cheapest, best way to go would be by rail to a
desert facility to get this stuff out of here as fast as possible. And I also think in my
opinion if that is done that Phase II would move a lot faster and we might find
something out from this endeavor that might help us in Phase II."

EPA Response

EPA appreciates your support for the Proposed Plan. Your comments regarding the use of
the New Bedford rail yard and the location of the off-site landfill are addressed in EPA's

A-5


-------
response to Mr. Barrett's and Mr. Kopcych's comments. In summary, the means of transportation
and the location of the off-site landfill will be decided during the competitive bidding process.

2.1.10	Ms. Sousa

Ms. Sousa provided oral comments at the public hearing. Ms. Souza expressed no
objections to the Proposed Plan. Ms. Sousa's congratulated the EPA and the Forum for
their efforts. She stated:

"There are many years and much to do ahead of us, but we as a community of
Southeastern Massachusetts have spoken to the government and the government has
listened to us. Thank you."

EPA Response

EPA appreciates your support for the Proposed Plan.

2.1.11	Mr. Sylvia

Mr. Sylvia provided oral comments and a comment letter (presented by Mr.
Simmons) at the public hearing. Mr. Sylvia's oral comments support the Proposed Plan. He
prefers that the sediments be transported by rail to Nevada. Mr. Sylvia's written comments
also support the Proposed Plan and his letter included it petition signed by over 400 people.
The petition reads:

"The undersigned respectfully asks that the New Bedford Harbor-Superfund Forum
members recommend that the contaminated soils at the Sawyer St. site be dewatered
and the remaining sediment be transported by rail to a permitted landfill as far from
New Bedford as possible, and that the clean-up of the railroad terminal in New
Bedford proceed in conjunction with this remedy."

EPA Response

The EPA appreciates your support for the Proposed Plan. Your comment regarding
transportation by rail is addressed in EPA's response to Mr. Barrett's, Mr. Kopcych's, and Mr.
Simmons' comments. The New Bedford railroad terminal is not part of the New Bedford Harbor
Superfund Site and is being addressed by the Massachusetts Department of Environmental
Protection under State cleanup standards.

A-6


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2.2

Local Government Comments

2.2.1	Mayor Kalisz, Mayor of New Bedford

Mayor Kalisz submitted a letter dated September 22,19998 which supports the
Proposed Plan. In his letter he also stated that EPA should carefully consider the feasibility
of shipping these sediments via rail from the City to the off-site disposal location. He also
asks that the EPA, through all means possible, make every effort to employ local businesses
and residents on this, and all future cleanup efforts in New Bedford. There is a skilled
workforce in New Bedford, and there are local businesses that could aid in this process.

EPA Response

EPA appreciates Mayor Kalisz's support for the Proposed Plan. Your comments regarding
the use of the New Bedford rail yard is addressed in EPA's response to Mr. Barrett's and Mr.
Kopcych's comments. In summary, the means of transportation and the location of the off-site
landfill will be decided during the competitive bidding process.

EPA supports the goal of using local labor to the maximum extent practicable. EPA will
not be directly responsible for hiring during the cleanup. However, we will continue to work with
the U.S. Army Corps of Engineers, their contractors and the City toward the goal of using local
labor. EPA has asked the City council to provide us with a list of local contractors that could
possibly be used during the harbor cleanup. Contractors on this list may be notified by the Corps
of Engineers and their contractors of job opportunities during the harbor cleanup.

2.2.2	Councilman Rogers, New Bedford

Councilman Rogers provided oral comments at the public hearing. Councilman
Rogers "wholeheartedly" endorses the Proposed Plan. Councilman Rogers encourage EPA
to use local labor and if possible ship the material out of New Bedford by rail. Councilman
Rogers also recommends that a location remote to any community be chosen as the off-site
disposal location and suggests that a Nevada landfill be selected.

EPA Response

EPA appreciates Councilman Roger's support for the Proposed Plan. EPA supports the
goal of using local labor to the maximum extent practicable. EPA will not be directly responsible
for hiring during the cleanup. However, we will continue to work with the U.S. Army Corps of
Engineers, their contractors and the City toward the goal of using local labor. EPA has asked the
City council to provide us with a list of local contractors that could possibly be used during the
harbor cleanup. Contractors on this list may be notified by the Corps of

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Engineers and their contractors of job opportunities during the harbor cleanup.

Your comments regarding the use of the New Bedford rail yard is addressed in EPA's
response to Mr. Barrett's and Mr. Kopcych's comments. In summary, the means of transportation
and the location of the off-site landfill will be decided during the competitive bidding process.

2.3 State Government Comments

2.3.1 Commonwealth of Massachusetts, Executive Office of Environmental Affairs,

Department of Environmental Protection

The Commonwealth submitted written comments on the Proposed Plan in a letter
dated September 24,1998. The Commonwealth reserves its concurrence of the amended
Record of Decision until all public comments have been received and reviewed. However,
the DEP has the following comments on the Proposed Plan.

1.	The DEP appreciates the EPA's efforts in participating in the New Bedford
Harbor Community Forum in an attempt to gain a consensus on the final resolution for the
Hot Spot sediments. Both the DEP and EPA reached basically the same conclusion
regarding a preference for treatment of the Hot Spot material. However, the Forum's
consensus was the off-site landfilling alternative in the Proposed Plan. The DEP will accept
this alternative pending review of the comments received during the comment period.

2.	While the DEP will support the off-site landfilling option, if supported by the
public, it is disappointing that a treatment option was not selected. Both conventional and
innovative destruction technologies are readily available and were reviewed by the Forum.
While the difficulties in treatment of all the contamination at the Site are insurmountable,
the original intent of having the Hot Spot Operable unit was to treat the most highly
contaminated material. The Hot Spot contains about 45% of the total PCBs at the Site in
about 15,000 cubic yards of highly contaminated sediment. It is the DEP's opinion that
there are on-site and off-site treatment options that can be implemented in a manner
protective of both human health and the environment which would result in destruction of
the PCBs and therefore a better long term outcome.

EPA Response

The EPA appreciates and agrees with DEP's comments. We also believe that an on-site
treatment option could have been safely implemented.

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2.4 Congressional Comments

2.4.1 Congressman Frank

Congressman Frank prepared written comments dated September 16, 1998 which
were read by Ms. Elsie Sousa at the public hearing. Congressman Frank's comments are as
follows:

First:

Concerning the clean up alternatives for the Hot Spot sediments, I support the
proposed changes to the 1990 clean up plan which were generated by discussions in the
Forum.

EPA Response:

EPA appreciates Congressman Frank"s support for the Proposed Plan.

Second:

It is my very strong belief that it is in the best interests of the harbor, and of the
community as a whole, for the Record of Decision on Phase II of the Clean Up be expedited,
so that it is published as quickly as is allowable.

EPA Response

The Record of Decision on Phase II was signed on September 25, 1998.

Third:

I want to take this opportunity to state that I support the linkage of navigational
dredging with Superfund dredging wherever possible.

EPA Response:

EPA also supports the linkage of navigational dredging with Superfund dredging
wherever possible. EPA will cooperate with the Commonwealth of Massachusetts and the City of
New Bedford in its efforts to implement an effective and timely navigational dredging program. It
should be noted that the opportunities for linkage exists with the Phase II cleanup, not the Hot
Spot cleanup.

Finally:

I strongly support the development of a more comprehensive process for ensuring
that local residents receive hiring preference over non local residents for jobs created as a
result of the clean up.

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EPA Response

EPA supports the goal of using local labor to the maximum extent practicable. EPA will
not be directly responsible for hiring during the cleanup. However, we will continue to work with
the U.S. Army Corps of Engineers, their contractors and the City toward the goal of using local
labor. EPA has asked the City council to provide us with a list of local contractors that could
possibly be used during the harbor cleanup. Contractors on this list may be notified by the Corps
of Engineers and their contractors of job opportunities during the harbor cleanup.

2.5 AVX Corporation's Comments

AVX Corporation, one of the settling parties involved in Site-related litigation, submitted
written comments in a letter to EPA dated September 25, 1998. The AVX comments consisted of
four parts: Part I is titled "Consent Decree Reopeners Are Not Available"; Part II is titled "The
Proposed ROD Amendment's Cleanup Plan Is Likely to Cost More and Take Longer Than Now
Estimated"; Part III is titled "The Proposed ROD Amendment Fails to Evaluate Comparative
Risk"; and Part IV is titled "Now Is the Time for EPA to Learn From the OU1 Experience and
Reconsider the Plan for the Rest of the New Bedford Harbor."

AVX requested that their comments be included in the Administrative Record for both
OU1 and OU2. EPA will include these comments in the Administrative Record for the Hot Spot
Operable Unit (OU2). However, since these comments were received long after the public
comment period for OU1 ended, they will not be added to the OU1 Administrative Record.

2.5.1 Part I (Consent Decree Reopeners Are Not Available)

AVX Comment #1

The definition of "Remedial Costs" in the Consent Decree entered by the United
States District Court for the District of Massachusetts in Civil Action No. 83-3882-Y
excludes "any increase in costs resulting from any amendments to the RODS" for the first
and second operable units at the New Bedford Harbor Site. AVX believes that they should
not be subject to any future efforts to seek additional reimbursement of costs for this
Amended ROD.

EPA Response

While EPA understands AVX's concern about future government demands for
reimbursement for costs associated with this Amendment to the Hot Spot Rod, this document is
not the forum for interpreting the provisions of the Consent Decree. The remedy selection process
is based on the nine criteria of the NCP, one of which is a consideration of the cost of the remedy.
However, the source of funding for the remedy is not part of the cost criteria.

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2.5.2 Part II (The Proposed ROD Amendment's Cleanup Plan Is likely to Cost More and Take

Longer Than Now Estimated)

AVX Comment #1

EPA has consistently underestimated the costs and time required to implement the
work at the New Bedford Harbor Superfund Site.

EPA Response

AVX claims that EPA spent $33,700,000 on dredging. The costs which EPA incurred
were for much more than dredging the Hot Spot sediments. EPA incurred costs associated with
the design of the entire remedy including dredging and incineration of the sediments, all site
upgrades in preparation of dredging and incineration, award and subsequent cancellation of the
remedial action contract for incineration, construction and operation of the waste water treatment
plant, modifications to the CDF for interim storage of the Hot Spot sediments, dredging of the
sediments, environmental monitoring during dredging, and continued operations and maintenance
of the Sawyer Street CDF since 1995. EPA admits that the number of days to dredge the
sediments were significantly greater than originally estimated and the total project costs were also
significantly greater than originally estimated. As AVX pointed out, the intended accuracy of
EPA's original estimate was +50%/-30%, which means that the original estimate could be low by
as much as 50%. A significant portion of the total project delays and increased costs were due to
delays associated with the post-ROD, congressionally supported public opposition to the
incineration component of the original remedy. This public opposition could not have been
predicted at the time the ROD was released in 1990.

AVX Comment #2

EPA's present selection of a comparatively low cost remedial option for OU1 suggests
an effort to avoid unnecessary costs and to limit the grossly protracted schedule, but AVX's
and the public's confidence in EPA was long ago lost due to the indefensible escalation of
costs, extension of time and erratic remedy selection process. AVX believes that EPA's track
record at the New Bedford Harbor Superfund Site strongly suggests the great likelihood of
further cost increases and scheduling extensions, which EPA should consider now, rather
than later.

EPA Response

EPA's selection of off-site landfilling was based on a comparative analysis of eleven
remedial options using the nine NCP criteria. Cost was only one of the nine NCP criteria. EPA's
rationale for selecting the off-ste landfilling option was presented in the August 1998 Proposed
Plan. Off-site landfilling was also the consensus decision of the Community Forum which was
established in late 1993 to help regain the public's trust. The EPA is confident in the

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public's support for the Proposed Plan and EPA is confident that off-site landfilling can be
completed in the two year estimate and that the cost estimate is within the +50%/-30% range.

2.5.3	Part III (The Proposed ROD Amendment Fails to Evaluate Comparative Risk)

AVX commented that it appears that EPAfc Hot Spot Feasibility Study Addendum
(December 1997) does not include an evaluation of the risk associated with implementation
of the Proposed ROD Amendment, i.e., transporting the Hot Spot sediments off site and
placing them in a landfill. AVX commented further that since trucks will be operating in an
urban environment for at least two years and driving collectively thousands of miles over
public highways, and since large volumes of contaminated sediments will be placed in a
landfill, it is extremely important to evaluate the incremental risk to the public. It could be
that the risk to the public from these relatively risky operations would exceed the risks
associated with leaving the Hot Spot sediments in place

EPA Response

EPA discussed the risks associated with the Proposed ROD Amendment in Section 6.2.
10 of the December 1997 Hot Spot Feasibility Study Addendum and in the August 1998
Proposed Plan.

The off-site transportation of dewatered sediments may be accomplished using trucks or a
combination of trucks and rail. It has been approximated that seven trucks per day, five days per
week will enter and leave the site for a period of six months to a year, not two years. EPA does
not consider of transportation of the dewatered Hot Spot sediment via truck or rail and disposal in
a TSCA permitted chemical waste landfill to be relatively risky operations. These activities are
routine. EPA believes that the continued storage of the Hot Spot sediments in the Sawyer Street
CDF will pose a greater potential future risk to the public health and the environment than any
risk associated with off-site transportation and disposal.

2.5.4	Part IV (Now Is the Time for EPA to Learn From the OU1 Experience and Reconsider the

Plan for the Rest of the New Bedford Harbor)

AVXfc comments in this section appear to be primarily focused on EPA's cleanup
plan for the Upper and Lower Harbor Operable Unit, not the Hot Spot Operable Unit.
AVX refers to the plan for the rest of the harbor as OU2. For the record, the Hot Spot
Operable Unit is OU2 and the Upper and Lower Harbor Operable Unit is OU1. AVX
commented that in its selection of the OU2 remedy (actually OU1, see preceding sentence)
should not repeat the errors made patent by the Hot Spot remedy and its selection
(including its modification and amendment).

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EPA Response

AVX had ample opportunity to comment on the Upper and Lower Harbor cleanup plan
during the formal public comment period for that operable unit and, in fact, did submit many
comments to EPA during the Upper and Lower Harbor comment period. EPA will not respond to
these comments to the OU1 cleanup plan in this OU2 Responsiveness Summary.

A-13


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Appendix B - Administrative Record Index

New Bedford Harbor Superfund Site
Amended Record of Decision for the Hot Spot Sediments


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New Bedford Harbor
Hot Spot Operable Unit

NPL Site

Administrative Record
for the Amended Record of Decision

Index

Compiled: April 22, 1999

Prepared by
EPA New England
Office of Site Remediation & Restoration

With Assistance from
ads

2070 Chain Bridge Road
Vienna, VA 22182


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Introduction

This document is the Index to the Administrative Record for the Amended Record of
Decision at the New Bedford Harbor Superfund Site Hot Spot Operable Unit. The citations in the
Index are for those documents that EPA relied upon in selecting a response action at the Site.
Site-specific documents are cited in Section I of the Index, and EPA guidance documents are
cited in Section II. Documents cited in Section I of the Index are ordered by the Documents
Number that appears at the end of each citation,

The Administrative Record is available for public review at the EPA Region I Superfund
Records Center, One Congress Street, Boston, MA 02114 [(617) 918-1440], and Wilkes Library,
1911 Acushnet Avenue, New Bedford, MA 02740. Please note that this Administrative Record
also includes documents from Administrative Records for this Site that were issued on April 6,
1990, April 27, 1992, October 30, 1995 and September 25, 1998. EPA guidance documents cited
in Section II are available for review only at the EPA Region I Superfund Records Center. The
Staff of the EPA Region I Superfund Records Center recommends that you set up an appointment
prior to your visit.

Questions concerning the Administrative Record should be addressed to the Project
Manager for the New Bedford Harbor Superfund Site Hot Spot Operable Unit.

An Administrative Record is required by the Comprehensive Environmental Response,
Compensation and Liability Act (CERCLA), as amended by the Superfund Amendments and
Reauthorization Act (SARA).


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ADMINISTRATIVE RECORD INDEX	04/23/99

NEW BEDFORD HARBOR	Page	1

HOT SPOT OPERABLE UNIT

04 .01

FEASIBILITY STUDY - CORRESPONDENCE

Title:	Concerning Approval to Dispose PCBs.

Addressee:	DR. NIEL L. DROBNY - COMMODORE REMEDIATON

TECHNOLOGIES, INC.

Authors:	JOHN W. MELONE - EPA-HEADQUARTERS

Date:	March 7, 1996

Format:	LETTER	No. Pgs : 5

AR NO.	04.01.1	Document No. 000064

Title:

Addressee:
Authors:
Date:
Format:
AR NO.

Request from Molten Metal Technology to Deploy its
Catalytic Extraction Processing System in Order to
Process PCB Sediment.

THEODORE NIXON - EBASCO SERVICES INC
VICTOR GATTO - MOLTEN METAL TECHNOLOGY INC.

March 8, 1996

LETTER	No. Pgs: 1

04.01.2	Document No. 000135

Title:

Addressee:
Authors:

Date:
Format:
AR No .

Letter Concerning the Shipment of a Few Gallons of
a Sediment to Commodore's Ohio Facility.

DAVE DICKERSON - EPA - REGION I

O.M. JONES, JR. - COMMODORE SOLUTION TECHNOLOGIES,
INC.

November 1, 1996

LETTER	No . Pgs : 5

04.01.3	Document No.

000134

Title:	Recommendation That a New Commodore Technology Be

Used to Treat Hot Spot Sediments.

Addressee: DAVE DICKERSON - EPA - REGION - I
Authors:	O.M. JONES, JR. - COMMODORE SOLUTION

TECHNOLOGIES, INC.

Date:	November 15, 1996

Format:	LETTER	No Pgs: 1

AR No.	04.01.4	Document No. 000110


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ADMINISTRATIVE RECORD INDEX
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HOT SPOT OPERABLE UNIT

04/23/99
Page	2

Title:

Addressee:

Authors:
Date:
Format:
AR No .

Conditional Approval to Commodore to Address
Untreated Sediment from the Hot Spot Confined
Disposal Facility.

O.M. JONES, JR. - COMMODORE SOLUTION TECHNOLOGIES,
INC.

DAVE DICKERSON - EPA - REGION I
January 24, 1997

LETTER	No. Pgs: 1

04.01.5

Document No. 000109

Title:

Addressee:

Authors:
Date:
Format:
AR No .

Authorization to Commodore to Use Its
Ultrafiltration Unit.

DR. NEIL L. DROBNY - COMMODORE REMEDIATION
TECHNOLOGIES, INC.

JOHN W. MELONE - EPA-HEADQUARTERS
June 9, 1997

LETTER	No. Pgs: 14

04.01.6	Document No. 00010S

Title:

Addressee:
Authors:

Date:
Format:
AR No .

Discussion of SET Process and Its Ability to
Remediate Contaminated New Bedford Harbor
Sediments.

NEW BEDFORD HARBOR SUPERFUND FORUM
PAUL E. HANNESSON - COMMODORE SOLUTION
TECHNOLOGIES, INC.

October 15, 1997

LETTER	No. Pgs: 1

04.01.7	Document No. 000107

Title:

Addressee:
Authors:
Date:
Format:
AR No .

Issues Concerning ETHEC's Process for On-Site
Remediation of Contaminated New Bedford Harbor
Sediments.

JIM BROWN - EPA - REGION I

WILL N. CLURMAN, ALEXANDER GURFINKEL - ETHEC, INC.
January 9, 1998

LETTER	No. Pgs. 1

04.01.8	Document No. 000106


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HOT SPOT OPERABLE UNIT

04/23/99
Page	3

Title:	Retention of One of the Four Drums of New Bedford

Harbor Sludge by Commodore.

Addressee:	JIM BROWN - EPA - REGION I

Authors:	GLEN JONES - COMMODORE SOLUTION TECHNOLOGIES, INC.

Date:	March 10, 1998

Format:	LETTER	No. Pgs: 1

AR No.	04.01.9	Document No. 000105

Title:	Commodore's PCB Permits.

Addressee:	HARLEY LAING - EPA - REGION I

Authors:	RAYBURN HANZLIK - COMMODORE SOLUTION TECHNOLOGIES,
INC.

Date:	May 21, 1998

Format:	LETTER	No. Pgs: 3

AR No.	04.01.10	Document No. 000063

Title:	Authorization to Destroy Waste Oils Containing PCBs

Addressee:	VINCE VALERI - COMMODORE APPLIED TECHNOLOGIES, INC.

Authors:	JOHN W. MELONE - EPA-HEADQUARTERS

Date:	May 29, 1998

Format:	LETTER	No. Pgs: 38

AR No.	04.01.11	Document No. 000062

Title:	Certificate of Destruction Regarding Three of Four

Drums of New Bedford Harbor Sludge.

Addressee:	JIM BROWN - EPA - REGION I

Authors:	GLEN JONES - COMMODORE APPLIED TECHNOLOGIES, INC.

Date:	June 23, 1998

Format:	LETTER	No. Pgs. 9

AR No.	Document No. 000061

04 .03

FEASIBILITY STUDY - SCOPE OF WORK

Title:	New Bedford Harbor Treatability Study Scope of Work.

Addressee:	KATHLENE HUNT

Authors:	DAVE DICKERSON - EPA - REGION I

Date:	January 1995

Format:	REPORT, STUDY

AR No.	04.03.1

No. Pgs: 19
Document No.

000184


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HOT SPOT OPERABLE UNIT

04/23/99
Page	4

04 .04

FEASIBILITY STUDY - INTERIM DELIVERABLES

Title:

Addressee:
Authors:
Date:
Format:
AR No .

Draft Work Plan, New Bedford Harbor RI/FS, Hot Spot

Sediment Treatability Studies, New Bedford,

Massachusetts.

EPA - REGION I

EBASCO SERVICES INC

February 1995

REPORT, STUDY	No. Pgs : 153

04.04.1	Document No. 000111

Title:	Massachusetts Department of Environmental Protection

Review of Draft Work Plan - Treatability Studies.

Addressee:	DAVE DICKERSON - EPA - REGION I

Authors:	JAY NAPARSTEK - MA DEPT OF ENVIRONMENTAL PROTECTION

Date:	February 24, 1995

Format:	LETTER	No. Pgs: 4

AR No.	04.04.2	Document No. 000185

Title:

Addressee:
Authors:
Date:
Format:
AR No .

Pilot Scale
- Overall Pilot Scale

Draft Field Operations Plan
Treatability Studies (Vol. I
Test Program.)

FOSTER WHEELER ENVIRONMENTAL CORPORATION
EBASCO SERVICES INC
March 1996

REPORT, STUDY	No. Pgs: 73

04.04.3	Document No. 000099

Title:

Addressee:
Authors:
Date:
Format:
AR No .

Draft Field Operations Plan - Pilot Scale
Treatablility Studies (Vol. II - Ionics RCC Detailed
Demonstration Plan.)

FOSTER WHEELER ENVIRONMENTAL CORPORATION
EBASCO SERVICES INC
March 1996

REPORT, STUDY	No. Pgs. Ill

04.04.4	Document No. 000100


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04/23/99
Page	5

Title:

Authors:
Date:
Format:
AR No .

Review Draft - Field Operations Plan-Pilot Scale

Treatability Studies - (Volume II of V - Ionics RCC

Detailed Demonstration Plan.

FOSTER WHEELER ENVIRONMENTAL CORPORATION

May 1996

REPORT, STUDY	No. Pgs: 168

04.04.5	Document No. 000101

Title:

Authors:
Date:
Format:
AR No .

Site Specific Safety & Health Plan - Pilot-Scale
Treatability Studies - (Vol V of V - Overall Pilot-
Scale Test Program.)

FOSTER WHEELER ENVIRONMENTAL CORPORATION
May 1996

REPORT, STUDY	No. Pgs: 247

04.04.6	Document No. 000102

Title:	Field Laboratory Technical Systems Audit Report.

Addressee:	DAVE DICKERSON - EPA - REGION I

Authors:	ANN JEFFERIES, NORA CONLON - EPA-ENVIRO MEASUREMENT &

EVALUATION

Date:	June 21, 1996

Format:	MEMORANDUM	No. Pgs: 4

AR No.	04.04.7	Document No. 000160

Title:

Authors:
Date:
Format:
AR No .

Field Operations Plan - Pilot Scale Treatablility
Studies - (Vol. Ill of V - Geosafe Detailed
Demonstration Plan.)

FOSTER WHEELER ENVIRONMENTAL CORPORATION
July 1996

REPORT, STUDY	No. Pgs. 431

04.04.8	Document No. 000104

Title:	Comments on the Draft	Volume III of the New Bedford

Hot Spot Treatability Study Field Operations Plan.
Addressee: ALAN FOWLER - FOSTER WHEELER ENVIRONMENTAL
CORPORATION

Authors:	ROBERT G. CIANCIARULO	- EPA - REGION I

Date:	July 11, 1996

Format:	LETTER	No. Pgs: 18

AR No.	04.04.9	Document No. 000159


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04/23/99
Page	6

Title:	New Bedford Risk Assessment.

Addressee:	NEW BEDFORD ARCS PERSONNEL

Authors:	PETER W. VERNON - FOSTER WHEELER ENVIRONMENTAL

CORPORATION

Date:	September 19, 1996

Format:	MEMORANDUM	No. Pgs: 4

AR No.	04.04.10	Document No. 000158

Title:

Addressee:

Authors:
Date:
Format:
AR No .

New Bedford Harbor Pilot-Scale Treatability Study
Project Schedule and Review of Draft SAIC Project
Plans.

ARTHUR SHATTUCK - SCIENCE APPLICATIONS INTERNATIONAL
CO .

ALAN FOWLER - FOSTER WHEELER ENVIRONMENTAL CORPORATION
October 2, 1996

LETTER	No. Pgs: 15

04.04.11	Document No. 000157

Title:

Authors:
Date:
Format:
AR No .

Field Operations Plan -	Pilot Scale Treatability

Studies - (vol. IV of V	- SAIC/ECO Logic Detailed
Demonstration Plan.)

FOSTER WHEELER ENVIRONMENTAL CORPORATION
November 1996

REPORT, STUDY	No. Pgs: 485

04.04.12	Document No. 000103

Title:	New Bedford RI/FS Response to EPA and DEP Comments on

the Draft Volume IV - Field Operations Plan.

Addressee:	DAVE DICKERSON - EPA - REGION I

Authors:	ALAN FOWLER - FOSTER WHEELER ENVIRONMENTAL CORPORATION

Date:	November 27, 1996

Format:	LETTER	No. Pgs. 15

AR No.	04.04.13	Document No. 000156


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04/23/99
Page	7

Title:

Addressee:
Authors:

Date:
Format:
AR No .

New Bedford Harbor RI/FS Response to Sea Change
Comments on the Draft Volume IV - Field Operations
Plan.

DAVE DICKERSON - EPA - REGION I

DAVE FOWLER - FOSTER WHEELER ENVIRONMENTAL

CORPORATION

December 5, 1996

LETTER	No. Pgs: 18

04.04.14	Document No. 000155

Title:	Third ISV Treatability Test at New Bedford Harbor

Addressee:	ALAN FOWLER - FOSTER WHEELER ENVIRONMENTAL
CORPORATION

Authors:	DALE M. TIMMONS - GEOSAFE CORPORATION

Date:	January 23, 1997

Format:	LETTER	No. Pgs: 3

AR No.	04.04.15	Document No. 000154

Title:	Comments on January 1997 Draft RCC/CRTI Test Report

Addressee:	ALAN FOWLER - FOSTER WHEELER ENVIRONMENTAL
CORPORATION

Authors:	DAVE DICKERSON - EPA - REGION I

Date:	January 28, 1997

Format:	LETTER	No. Pgs: 1

AR No.	04.04.16	Document No. 000153

Title:

Addressee:
Authors:
Date:
Format:
AR No .

Pilot Scale Treatability Testing of the In Situ
Vitrification Technology.

FOSTER WHEELER ENVIRONMENTAL CORPORATION
GEOSAFE CORPORATION
February 10, 1997

REPORT, STUDY	No. Pgs. 166

04.04.17	Document No. 000131

Title:	Response to Comments of Draft Report.

Addressee:	ALAN FOWLER - FOSTER WHEELER ENVIRONMENTAL
CORPORATION

Authors:	DALE M. TIMMINS - GEOSAFE CORPORATION

Date:	February 10, 1997

Format:	LETTER	No. Pgs: 5

AR No.	04.04.18	Document No. 000152


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ADMINISTRATIVE RECORD INDEX
NEW BEDFORD HARBOR
HOT SPOT OPERABLE UNIT

04/23/99
Page	8

Title:

Addressee:
Authors:
Date:
Format:
AR No .

Test Report for On Site Pilot Scale Demonstration

Testing of the B.E.S.T. Solvent Extraction Process

and Solvated Electron Technology.

FOSTER WHEELER ENVIRONMENTAL CORPORATION.

IONICS RESOURCES CONSERVATION COMPANY

March 1997

REPORT, STUDY	No. Pgs: 160

04.04.19	Document No. 000132

Title:	Follow-Up to ISV Treatibility Test at New Bedford.

Addressee:	DAVE DICKERSON - EPA - REGION I

Authors:	DALE M. TIMMONS - GEOSAFE CORPORATION

Date:	March 20, 1997

Format:	LETTER	No. Pgs: 12

AR No.	04.04.20	Document No. 000151

Title:	Final Report - On Site Pilot Scale Testing of the ECO

LOGIC Process.

Addressee:	FOSTER WHEELER ENVIRONMENTAL CORPORATION

Authors:	SCIENCE APPLICATIONS INTERNATIONAL CO.

Date:	May 15, 1997

Format:	REPORT STUDY	No. Pgs: 184

AR No.	04.04.21	Document No. 000133

Title:

Addressee:
Authors:

Date:
Format:
AR No .

New Bedford Harbor RI/FS, Hot Spot Treatability
Studies, SAIC/EOC Logic-Vendor Report of Pilot Study
Testing.

DAVE DICKERSON - EPA - REGION I

ALAN FLOWER - FOSTER WHEELER ENVIRONMENTAL

CORPORATION

May 15, 1997

LETTER	No. Pgs. 10

04.04.22	Document No. 000150

Title:	MA DEP Comments on Hot Spot Treatability Studies, New

Bedford Harbor Superfund Site.

Addressee:	JIM BROWN - EPA - REGION I

Authors:	PAUL CRAFFEY - MA DEPT OF ENVIRONMENTAL PROTECTION

Date:	July 8, 1997

Format:	LETTER	No. Pgs: 5

AR No.	04.04.23	Document No. 000149


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ADMINISTRATIVE RECORD INDEX
NEW BEDFORD HARBOR
HOT SPOT OPERABLE UNIT

04/23/99
Page	9

Title:

Addressee:

Authors:

Date:
Format:
AR No .

Response to Concerns Expressed in Foster Wheeler's
March 26, 1997 Letter.

ALAN FOWLER - FOSTER WHEELER ENVIRONMENTAL
CORPORATION

O.M. JONES, JR. - COMMODORE SOLUTION TECHNOLOGIES,
INC.

July 22, 1997

LETTER	No. Pgs: 3

04.04.24	Documents No. 000148

Title:

Addressee:
Authors:
Date:
Format:
AR No .

New Bedford Harbor RI/FS Hot Spot Treatability
Studies Data Compendium.

JIM BROWN - EPA - REGION I

ALAN FOWLER - FOSTER WHEELER ENVIRONMENTAL CORPORATION
September 25, 1997

LETTER	No. Pgs: 3

04.04.25	Document No. 000147

Title:

Addressee:
Authors:
Date:
Format:
AR No .

Drum and Waste Container Sampling, New Bedford Harbor

Superfund Site.

U.S. ARMY CORPS OF ENGINEERS

ROY F. WESTON

March 1998

REPORT, STUDY

04.04.26	Document No. 000041

04 .06

FEASIBILITY STUDY - FEASIBILITY STUDY REPORTS

Title:	New Bedford Harbor Hot Spot

Treatlbility Study Volume I.
Addressee: EPA - REGION I
Authors: FOSTER WHEELER ENVIRONMENTAL

CORPORATION
Date:	September 1997

Format:	REPORT, STUDY

AR No.	04.06.1

Document No. 000113


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ADMINISTRATIVE RECORD INDEX
NEW BEDFORD HARBOR
HOT SPOT OPERABLE UNIT

04/23/99
Page	10

Title:	New Bedford Harbor Bot Spot Treatability

Study Data Compendium Volume II.

Addressee: EPA - REGION I

Authors: FOSTER WHEELER ENVIRONMENTAL CORPORATION
Date:	September 1997

Format: REPORT, STUDY

AR No.	04.06.2	Document No.

000114

Title:	New Bedford Harbor Hot Spot Treatability

Study Data Compendium Volume III.

Addressee: EPA - REGION I

Authors: FOSTER WHEELER ENVIRONMENTAL CORPORATION
Date:	September 1997

Format: REPORT, STUDY

AR No.	04.06.3	Document No.

000115

Title:	New Bedford Harbor Hot Spot Treatability Study

Data Compendium Volume IV.

Addressee: EPA - REGION I

Authors: FOSTER WHEELER ENVIRONMENTAL CORPORATION
Date:	September 1997

Format: REPORT, STUDY	No. Pgs : 172

AR No.	04.06.4	Document No. 000116

Title:	New Bedford Harbor Hot Spot Treatability Study

Data Compendium Volume V.

Addressee: EPA - REGION I

Authors: FOSTER WHEELER ENVIRONMENTAL CORPORATION
Date:	September 1997

Format: REPORT, STUDY	No. Pgs: 336

AR No.	04.06.5	Document No. 000117

Title:	New Bedford Harbor Hot Spot Treatability Study

Data Compendium Volume VI.

Addressee: EPA - REGION I

Authors: FOSTER WHEELER ENVIRONMENTAL CORPORATION
Date:	September 1997

Format: REPORT, STUDY	No. Pgs: 307

AR No.	04.06.6	Document No. 000118


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ADMINISTRATIVE RECORD INDEX
NEW BEDFORD HARBOR
HOT SPOT OPERABLE UNIT

04/23/99
Page 11

Title:

Addressee:
Authors:
Date:
Format:
AR No .

New Bedford Harbor Bot Spot Treatability
Study Data Compendium Volume VII.

EPA - REGION I

FOSTER WHEELER ENVIRONMENTAL CORPORATION
September 1997

REPORT, STUDY	No. Pgs: 4 69

04.06.7	Document No. 000119

Title:

Addressee:
Authors:
Date:
Format:
AR No .

New Bedford Harbor Hot Spot Treatability Study Data
Compendium Volume VIII.

EPA - REGION I

FOSTER WHEELER ENVIRONMENTAL CORPORATION
September 1997

REPORT, STUDY	No. Pgs: 235

04.06.8	Document No. 000120

Title:

Addressee:
Authors:
Date:
Format:
AR No .

New Bedford Harbor Hot Spot Treatability Study Data
Compendium Volume IX.

EPA - REGION I

FOSTER WHEELER ENVIRONMENTAL CORPORATION
September 1997

REPORT, STUDY	No. Pgs: 412

04.06.9	Document No. 000121

Title:

Addressee:
Authors:
Date:
Format:
AR No .

New Bedford Harbor Hot Spot Treatability
Study Data Compendium Volume X.

EPA - REGION I

FOSTER WHEELER ENVIRONMENTAL CORPORATION
September 1997

REPORT, STUDY	No. Pgs: 303

04.06.10	Document No. 000122

Title:

Addressee:
Authors:

Date:
Format:
AR No.

Announcing the Results of a Revised Test of
the SET Process on Hot Spot Sediments.

NEW BEDFORD HARBOR SUPERFUND FORUM

PAUL E. HANNESSON - COMMODORE SOLUTION TECHNOLOGIES,
INC.

October 15, 1997

LETTER	No Pgs: 1

04.06.11	Document No. 000145


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ADMINISTRATIVE RECORD INDEX
NEW BEDFORD HARBOR
HOT SPOT OPERABLE UNIT

04/23/99
Page 12

Title:	Comments on Draft Feasibility Study Addendum Hot

Spot Operable Unit.

Addressee: JIM BROWN - EPA - REGION I
Authors: PAUL CRAFFEY - MA DEPT OF ENVIRONMENTAL

PROTECTION
Date:	November 13, 1997

Format:	LETTER

AR No.	04.06.12

No Pgs: 4
Document No.

000144

Title:	Comments of Draft New Bedford Harbor Hot Spot

Feasibility Study Addendum.

Addressee:	JIM BROWN - EPA - REGION I

Authors:	DALE M. TIMMONS - GEOSAFE CORPORATION

Date:	November 19, 1997

Format:	LETTER	No Pgs: 8

AR No.	04.06.13	Document No. 000143

Title:	Comments on the Foster Wheeler Draft New Bedford

Harbor Hot Spot Feasibility Study Addendum.

Addressee: JIM BROWN - EPA REGION I

Authors: ARTHUR SHATTUCK - SCIENCE APPLICATIONS INTERNATIONAL
CO .

Date:	November 26, 1997

Format:	LETTER	No Pgs: 35

AR No.	04.06.14	Document No. 000142

Title:	Draft Final New Bedford Harbor Hot Spot

Feasibility Study Addendum.

Addressee:	EPA - REGION I

Authors:	FOSTER WHEELER ENVIRONMENTAL CORPORATION

Date:	December 1997

Format:	REPORT, STUDY

AR No.	04.06.15	Document No.

000112

Title:

Addressee:
Authors:
Date:
Format:
AR No .

Comments on Draft Final Feasibility Study,

Addendum, Hot Spot Operable Unit, New Bedford
Superfund Site.

JIM BROWN - EPA - REGION I

PAUL CRAFFER - MA DEPT OF ENVIRONMENTAL PROTECTION
June 15, 1998

LETTER	No Pgs: 5

04.06.16	Document No. 000146


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ADMINISTRATIVE RECORD INDEX
NEW BEDFORD HARBOR
HOT SPOT OPERABLE UNIT

04/23/99
Page 13

04 .07

FEASIBILITY STUDY - WORK PLANS & PROGRESS REPORTS

New Bedford Harbor OU3 RI/FS Scoping
Acknowledgement Letter Hot Spot Sediment
Treatability Studies.

DAVE DICKERSON - EPA - REGIONAL I
ALAN FOWLER - EBASCO SERVICES INC
February 1, 1995

LETTER	No Pgs: 9

04.07.1	Document No.

Title:

Addressee:
Authors:
Date:
Format:
AR No .

000181

Title:

Addressee:
Authors:
Date:
Format:
AR No .

Scoping Ackowledgement Letter - Hot Spot
Sediment Treatability Studies
DAVE DICKERSON - EPA - REGION I
ALAN FOWLER - EBASCO SERVICES INC
February 1, 1995
LETTER
04.07 . 2

No. Pgs : 8
Document No.

000186

Title :

Addressee:
Authors:
Date:
Format:
AR No .

New Bedford Harbor - Hot Spot Treatability
Studies Draft Work Plan and Cost Estimate.
KATHLEEN HUNT - EPA - REGION I
ALAN FOWLER - EBASCO SERVICES INC
March 24, 1995

LETTER	No Pgs: 2

04.07.3	Document No.

000180

Title:

Addressee:
Authors:
Date:
Format:
AR No .

New Bedford Harbor RI/FS Hot Spot
Treatability Studies Work Plan Amendment No.

1.

KATHLEEN HUNT - EPA - REGION I

ALAN FOWLER - FOSTER WHEELER ENVIRONMENTAL CORPORATION
April 26, 1996

LETTER	No. Pgs: 2

04.07.4	Document No. 000179


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ADMINISTRATIVE RECORD INDEX
NEW BEDFORD HARBOR
HOT SPOT OPERABLE UNIT

04/23/99
Page 14

Title:	Technical Direction for Additional Work - Job

Change No. 01.

Addressee: THOMAS J. ABDELLA - ROY F. WESTON
Authors: MAURICE BEAUDOIN - U.S. ARMY CORPS OF

ENGINEERS
Date:	May 6, 1996

Format:	LETTER	No Pgs: 3

AR No.	04.07.5	Document No.

000178

Title:	Notification of Delay and Request for Contract

Change Order.

Addressee:	THEODORE NIXON - EBASCO SERVICES INC

Authors:	WILLIAM F. HEINS - RESOURCES CONSERVATION COMPANY

Date:	May 30, 1996

Format:	LETTER	No Pgs: 3

AR No.	04.07.6	Document No. 000177

Title:	New Bedford Harbor RI/FS Treatability Study

Activities and Schedule.

Addressee:	DAN SHEA - ST. LUKES HOSPITAL

Authors:	ALAN FOWLER - FOSTER WHEELER ENVIRONMENTAL CORPORATION

Date:	July 12, 1996

Format:	LETTER	No. Pgs: 1

AR No.	04.07.7	Document No. 000176

Title:	New Bedford RI/FS Limitation of Cost Notice.

Addressee:	LINDA BYRNE - EPA - REGION

Authors:	MARK TUCKER - FOSTER WHEELER ENVIRONMENTAL CORPORATION

Date:	August 12, 1996

Format:	LETTER	No. Pgs: 1

AR No.	04.07.8	Document No. 000175

Title:

Addressee:
Authors:
Date:
Format:
AR No .

New Bedford Harbor RI/FS Treatability Studies
Geosafe Corporation Testing Program Utility
Support Requirements.

MAURICE BEAUDON - U.S. ARMY CORPS OF ENGINEERS

ALAN FOWLER - FOSTER WHEELER ENVIRONMENTAL CORPORATION

August 16, 1996

LETTER	No. Pgs: 2

04.07.9	Document No. 000174


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ADMINISTRATIVE RECORD INDEX
NEW BEDFORD HARBOR
HOT SPOT OPERABLE UNIT

04/23/99
Page 15

Title:

Addressee:
Authors:

Date:
Format:
AR No .

New Bedford Harbor RI/FS OU3 Treatability Study
Request for Additional Information.

LINDA BYRNE - EPA - REGION I

MARK TUCKER - FOSTER WHEELER ENVIRONMENTAL

CORPORATION

September 4, 1996

LETTER	No Pgs: 4

04.07.10	Document No. 000173

Title:

Addressee:
Authors:
Date:
Format:
AR No .

New Bedford Harbor RI/FS OU3 Treatability Study
Request for Additional Information.

LINDA BYRNE - EPA - REGION I

MARK TUCKER - FOSTER WHEELER ENVIRONMENTAL CORPORATION
September 10, 1996

LETTER	No Pgs: 2

04.07.11	Document No. 000172

Title:

Addressee:
Authors:
Date:
Format:
AR No .

Consent to Subcontract with SAIC for the Third
Treatability Study.

MARK TUCKER - FOSTER WHEELER ENVIRONMENTAL CORPORATION
LINDA BYRNE - EPA - REGION I
September 12, 1996

LETTER	No. Pgs: 2

04.07.12	Document No. 000171

Title:

Addressee:
Authors:
Date:
Format:
AR No .

New Bedford Harbor RI/FS Treatability Studies SAIC

Testing Program Support Requirements

MAURICE BEAUDOIN - U.S. ARMY CORPS OF ENGINEERS

ALAN FOWLER - FOSTER WHEELER ENVIRONMENTAL CORPORATION

September 24, 1996

LETTER	No. Pgs: 1

04.07.13	Document No. 000170

Title:

Addressee:
Authors:
Date:
Format:
AR No .

New Bedford Harbor RI/FS Treatability Studies SAIC
Testing Program Site Lighting Requirements.

MAURICE BEAUDOIN - U.S. ARMY CORPS OF ENGINEERS
ALAN FOWLER - FOSTER WHEELER ENVIRONMENTAL CORPORATION
October 3, 1996

LETTER	No. Pgs: 1

04.07.14	Document No. 000169


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ADMINISTRATIVE RECORD INDEX
NEW BEDFORD HARBOR
HOT SPOT OPERABLE UNIT

04/23/99
Page 16

Title:

Addressee:

Authors:

Date:
Format:
AR No .

New Bedford Harbor Pilot-Scale Treatability Study
Revised Project Schedule.

ARTHUR SHATTUCK - SCIENCE APPLICATIONS
INTERNATIONAL CO.

ALAN FOWLER - FOSTER WHEELER ENVIRONMENTAL

CORPORATION

October 8, 1996

LETTER	No Pgs: 3

04.07.15	Document No. 00016S:

Title:

Addressee:

Authors:
Date:
Format:
AR No .

New Bedford Harbor Pilot-Scale Treatability Study
Outstanding Items for Draft Field Operation Plan.
ARTHUR SHATTUCK - SCIENCE APPLICATIONS INTERNATIONAL
CO .

ALAN FOWLER - FOSTER WHEELER ENVIRONMENTAL CORPORATION
October 15, 1996

LETTER	No Pgs: 2

04.07.16	Document No. 000167

Title:

Addressee:
Authors:
Date:
Format:
AR No .

Deliverable Promised
Bedford Project.
K. CAMPBELL
ARTHUR SHATTUCK
October 17, 1996
MEMORANDUM
04.07.17

to Foster Wheeler for the New

No. Pgs:
Document

1

No.

000166

Title:
Addressee:
Authors:
Date:
Format:
AR No .

New Bedford Harbor Work Plan Amendment No. 2

LINDA BYRNE

EPA

REGION I

ALAN FOWLER - FOSTER WHEELER ENVIRONMENTAL CORPORATION

October
LETTER
04.07.IE

18, 1996

No. Pgs : 4
Document No.

000165

Title:	New Bedford Harbor Pilot Scale Treatability Study

Notice to Cure.

Addressee: ROBERT W. LARRICK JR. - SCIENCE APPLICATIONS

INTERNATIONAL CO.

Authors: THEODORE NIXON - FOSTER WHEELER ENVIRONMENTAL

CORPORATION
Date:	October 28, 1996

Format:	LETTER	No. Pgs: 3

AR No.	04.07.19	Document No. 000164


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ADMINISTRATIVE RECORD INDEX
NEW BEDFORD HARBOR
HOT SPOT OPERABLE UNIT

04/23/99
Page 17

Title:

Addressee:
Authors:

Date:
Format:
AR No .

New Bedford Harbor RI/FS Work Plan Amendment No.
2, Revised Budget Recap Table and Technical
Memorandum.

LINDA BYRNE - EPA - REGION I

ALAN FOWLER - FOSTER WHEELER ENVIRONMENTAL
CORPORATION
November 1, 1996
LETTER
04 . 07.20

No Pgs: 5
Document No.

000163

Title:	Treatability Study Activities and Schedule.

Addressee:	DAN SHEA - ST. LUKES HOSPITAL

Authors:	ALAN FOWLER - FOSTER WHEELER ENVIRONMENTAL

CORPORATION

Date:	November 6, 1996

Format:	LETTER	No Pgs: 1

AR No.	04.07.21	Document No.

000141

Title:

Addressee:
Authors:

Date:
Format:
AR No .

New Bedford Harbor RI/FS Treatability Study

Activities and Schedule.

KEN SILVIA - CITY OF NEW BEDFORS

ALAN FOWLER - FOSTER WHEELER ENVIRONMENTAL

CORPORATION

November 6, 1996

LETTER	No. Pgs: 1

04.07.22	Document No.

000161

Title:

Addressee:

Authors:

Date:
Format:
AR No .

New Bedford Harbor Pilot-Scale Treatability Study
Notice to Proceed with Field Mobilization.

ARTHUR SHATTUCK - SCIENCE APPLICATIONS
INTERNATIONAL CO.

ALAN FOWLER - FOSTER WHEELER ENVIRONMENTAL

CORPORATION

November 6, 1996

LETTER	No. Pgs: 2

04.07.23	Document No. 000162


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NEW BEDFORD HARBOR
HOT SPOT OPERABLE UNIT

04/23/99
Page 18

Title:	New Bedford Harbor Treatability Study - Work

Assignment #30

Addressee: HEIDI HORAHAN - FOSTER WHEELER ENVIRONMENTAL

CORPORATION
Authors: DAVE DICKERSON - EPA - REGION I
Date:	November 14, 1996

Format:	MEMORANDUM

AR No.	04.07.24

No Pgs: 2
Document No.

000140

Title:	Request for a No-Cost Extension to the Project

Schedule and Extending Working Hours During
System Integrity Testing.

Addressee: ALAN FOWLER - FOSTER WHEELER ENVIRONMENTAL
CORPORATION

Authors: ARTHUR SHATTUCK - SCIENCE APPLICATIONS

INTERNATIONAL CO.

Date:	November 15, 1996

Format:	LETTER	No Pgs: 1

AR No.	04.07.25	Document No.

000139

Title:	852 Hours of Proposed "New Scope'

Plan Amendment of 10/18/96.

Addressee:	LINDA BYRNE - EPA - REGION I

Authors:	DAVE DICKERSON - EPA - REGION I

Date:	November 19, 1996

Format:	MISCELLANEOUS

AR No.	04.07 . 26

in the work

No. Pgs : 1
Document No.

000138

Title:	Work Plan Amendment No. 3

Addressee:	LINDA BYRNE - EPA - REGION I

Authors:	MARK TUCKER - FOSTER WHEELER ENVIRONMENTAL

CORPORATION

Date:	February 24, 1997

Format:	LETTER	No. Pgs: 3

AR No.	04.07.27	Document No. 000137

Title:	Work Plan - Scoping for Time Extension and New

Tasking.

Addressee: DAVE DICKERSON - EPA - REGION I

Authors: HELEN DOUGLAS - FOSTER WHEELER ENVIRONMENTAL

CORPORATION
Date:	June 27, 1997

Format:	LETTER	No. Pgs: 3

AR No.	04.07.28	Document No.

000136


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NEW BEDFORD HARBOR
HOT SPOT OPERABLE UNIT

04/23/99
Page 19

04 .09

FEASIBILITY STUDY - PROPOSED PLANS FOR SELECTED REMEDIAL ACTION

Title:	Draft Proposal Plan.

Addressee:	JIM BROWN - EPA - REGION I

Authors:	DEBORAH M. SIMONE - METCALF

Date:	July 20, 1998

Format:	FACT SHEET, PRESS RELEASE

AR No.	04.09.1

& EDDY

No Pgs: 14
Document No.

000060

Title:
Addressee:
Authors:

Date:
Format:
AR No .

Agency Comments of Draft Proposed Plan.

JIM BROWN - EPA - REGION I

PAUL CRAFFER - MA DEPT OF ENVIRONMENTAL

PROTECTION

July 24, 1998

LETTER	No Pgs:

04.09.2

Document No. 000059

Title:	Proposed Plan to Amend the 1990 Cleanup Plan for

the New Bedford Harbor Hot Spot Sediments.

Authors: EPA - REGION I
Date:	August 1998

Format:	FACT SHEET, PRESS RELEASE	No. Pgs: 13

AR No.	04.09.3	Document No. 000057

Title:

Authors:
Date:
Format:
AR No .

Piano Proposto Emendar o Piano de Limpeza de 1990

dos Sedimentos no ''Hot Spot' do Porto de New

Bedford.

EPA - REGION I

August 1998

FACT SHEET, PRESS RELEASE	No. Pgs: 13

04.09.4	Document No. 000058

05.01

RECORD OF DECISION - CORRESPONDENCE

Title:
Addressee:
Authors:
Date:
Format:
AR No .

DEP Concurrence with Proposed Second ESD.

DAVE DICKERSON - EPA - REGION I

MADELINE SNOW - MA DEPT OF ENVIRONMENTAL PROTECTION
March 28, 1995

LETTER	No. Pgs: 2

05.01.1	Document No. 000194


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NEW BEDFORD HARBOR
HOT SPOT OPERABLE UNIT

04/23/99
Page 20

05.03

RECORD OF DECISION - RESPONSIVENESS SUMMARIES

Title:	Comments on the Proposed Plan (Cross Reference to

13.1. ) .

Addressee: EPA - REGION I
Authors: MANUEL SYLVIA, BERYL SYLVIA

Format:	LETTER	No Pgs: 44

AR No.	05.03.1	Document No. 000195

Title:	Comments on the Proposed Plan

Addressee:	JIM BROWN - EPA - REGION I

Authors:	CLAUDIA JACOBSEN

Date:	August 28, 1998

Format:	CORRESPONDENCE

AR No.	05.03.2

No Pgs: 1

Document No. 000190

Title:	Comments on the Proposed Plan.

Addressee:	JIM BROWN - EPA - REGION I

Authors:	ROMAN RUSINOSKI

Date:	September 14, 1998

Format:	CORRESPONDENCE

AR No.	05.03.3

No. Pgs: 2
Document No. 000192

Title:	Comments on the Proposed Plan.

Addressee:	JAMES SIMMONS - HANDS ACROSS THE RIVER COALITION

Authors:	DAVE BARRETT

Date:	September 16, 1998

Format:	MISCELLANEOUS	No. Pgs: 1

AR No.	05.03.4	Document No. 000187

Title:	Comments on the Proposed Plan.

Addressee:	JIM BROWN - EPA - REGION I

Authors:	CAROL SANZ - DOWNWIND COALITION

Date:	September 23, 1998

Format:	LETTER

AR No.	05.03.5

No. Pgs: 1
Document No. 000191


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HOT SPOT OPERABLE UNIT

04/23/99
Page 21

Title:	Comments on the Proposed Plan.

Addressee:	JIM BROWN - EPA - REGION I

Authors:	CLAUDIA KIRK

Date:	September 24, 1998

Format:	LETTER

AR No.	05.03.6

No Pgs: 2
Document No. 0001S:

Title:	Comments on the Proposed Plan.

Addressee:	JIM BROWN - EPA - REGION I

Authors:	MARY RYAN - NUTTER MC CLENNEN & FISH

Date:	September 25, 1998

Format:	LETTER	No Pgs: 9

AR No.	05.03.7	Document No,

000193

06.01 REMEDIAL DESIGN - CORRESPONDENCE

Title:	Review of the Draft Report on Pilot Scale

Incineration of Hot Spot Sediments.
Addressee: KEVIN HOWE - U.S. ARMY CORPS OF ENGINEERS

Authors:

GAYLE GARMAN - EPA - REGION I



Date:

October 17, 1991



Format:

MEMORANDUM

No. Pgs: 4

AR No .

06.01.1

Document No. 000125

Title:

Comments on the Draft Test Burn

Report.

Addressee:

KEVIN HOWE - U.S. ARMY CORPS OF

ENGINEERS

Authors:

PAUL CRAFFEY - MA DEPT OF ENVIRONMENTAL PROTECTION

Date:

October 24, 1991



Format:

LETTER

No. Pgs: 2

AR No .

06.01.2

Document No. 000124

Title:

Cover Letter - Submittal of the

100% Design



Report.



Addressee:

KEVIN HOWE - U.S. ARMY CORPS OF

ENGINEERS

Authors:

ROBERT FOXEN, JAMES FITZGERALD -

¦ ERM-NEW ENGLAND INC.

Date:

November 27, 1991



Format:

LETTER

No. Pgs: 1

AR No .

06.01.3

Document No. 000123


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HOT SPOT OPERABLE UNIT

04/23/99
Page 22

06.04

REMEDIAL DESIGN - REMEDIAL DESIGN DOCUMENTS

Title:

Addressee:
Authors:
Date:
Format:
AR No .

Preliminary Data Summary Report for Evaluating
the Incinerability of the New Bedford/Hot Spot
Operable Unit at the EPA Incineration Research
Facility.

EPA OFFICE OF R & D - CINCINNATI
ACUREX CORPORATION
August 28, 1991

REPORT, STUDY	No Pgs: 96

06.04.1	Document No. 000183

Title:	Final Design Analysis

Addressee:	U.S. ARMY CORPS OF ENGINEERS

Authors:	ERM-NEW ENGLAN INC.

Date:	November 1991

Format:	REPORT, STUDY

AR No.	06.04.2

No Pgs: 606
Document No. 00012S

Title:

Authors
Date:
Format:
AR No .

Specific for Construction Contract - Hazardous
Waste Cleanup (Vol. 1 of 2 - Proposal
Information - Divisions 1 and 2).

U.S. ARMY CORPS OF ENGINEERS
December 1991

REPORT, STUDY	No. Pgs: 431

06.04.3	Document No. 000126

Title:

Authors
Date:
Format:
AR No .

Specifications for Construction Project -
Hazardous Waste Cleanup (Vol. 2 of 2 Divisions 3
thru 16).

U.S. ARMY CORPS OF ENGINEERS
December 1991
REPORT, STUDY
06.04.4

No. Pgs: 241
Document No. 000127

Title:	Specifications for the Pilot-Scale Incineration.

Authors:	U.S. ARMY CORPS OF ENGINEERS

Date:	February 12, 1992

Format:	REPORT, STUDY	No. Pgs: 257

AR No.	06.04.5	Document No. 000130


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ADMINISTRATIVE RECORD INDEX
NEW BEDFORD HARBOR
HOT SPOT OPERABLE UNIT

04/23/99
Page 23

06. 90

REMEDIAL DESIGN - BID DOCUMENTS

Title:	Request for Proposal For Construction Contract

New Bedford Harbor/Hot Spot Operable Unit.

Authors: U.S. ARMY CORPS OF ENGINEERS
Date:	November 1991

Format:	REPORT, STUDY	No Pgs: 627

AR No.	06.09.1	Document No. 000129

09.01 STATE COORDINATION - CORRESPONDENCE

Title:	Comments on Proposed Plan (Cross Reference to
5.3.) .

Addressee:	JIM BROWN - EPA - REGION I

Authors:	PAUL CRAFFEY - MA DEPT OF ENVIRONMENTAL PROTECTION

Date:	September 24, 1998

Format:	LETTER	No Pgs: 2

AR No.	09.01.1	Document No. 000189

09.10

STATE COORDINATION - STATE TECHNICAL AND HISTORICAL RECORDS

Title:	Final Record of Decision for the New Bedford

Harbor Hot Spot Operable Unit.

Authors: JOHN DEVILLARS - MASSACHUSETTS OFFICE OF ENVIR.
AFFAIRS

Date:	December 14, 1990

Format:	MISCELLANEOUS	No. Pgs: 5

AR No.	09.10.1	Document No. 000197

*Attached to Document No. 000196 In 13.01

13.10

COMMUNITY RELATIONS - CORRESPONDENCE

Title:	EPA Remedy Selection Process.

Addressee: PETER KOCZERA - TOWN OF ACUSHNET BOARD OF
SELECTMAN

Authors: JOHN DEVILLARS - EPA - REGION I

Format:	LETTER	No. Pgs: 2

AR No.	13.01.1	Document No,

000046


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ADMINISTRATIVE RECORD INDEX
NEW BEDFORD HARBOR
HOT SPOT OPERABLE UNIT

04/23/99
Page 24

Title:	Letter of Appreciation for Jane Wells on Serving

as a Neutral Facilitator for the New Bedford
Harbor Forum.

Addressee: JANE WELLS - MASSACHUSETTS OFFICE OF DISPUTE
RESOLUT

Authors: PAUL KEOUGH - EPA - REGION I

Format:	LETTER	No Pgs: 1

AR No.	13.01.2	Document No. 000199

Title:

Addressee:
Authors:
Date:
Format:
AR No.

Response to the August 31, 1993 Newspaper

Article, "What's the Rush to Incinerate? It's

Time for EPA to Look Again."

STEVE URBON - NEW BEDFORD STANDARD TIMES

PAUL KEOUGH - EPA - REGION I

September 16, 1993

LETTER	No Pgs: 1

13.01.3	Document No.

000200

Title:

Addressee:
Authors:

Date:
Format:
AR No.

Response to George Rogers Letter of October 4,
1993 Regarding Hot Spot Remediation - (Cross
Reference to 5.3)

GEORGE ROGERS - CITY OF NEW BEDFORD
DANIEL GREENBAUM - MA DEPT OF ENVIRONMENTAL
PROTECTION
October 13, 1993

LETTER	No. Pgs: 12

13.01.4	Document No.

000196

Title:	Letter Which Requests Jonathan Cairns's Support

for a Review of Strategies for PCB Cleanup.

Addressee:	JOHNATHAN CAIRNS

Authors:	HENRY LONGEST - EPA - REGION I

Date:	November 12, 1993

Format:	LETTER	No. Pgs: 1

AR No.	13.01.5	Document No. 000201

Title:	Letter Which Requests Claudia Kirk's Support of

Strategies for PCB Cleanup.

Addressee:	CLAUDIA KIRK - CONCERNED PARENTS OF FAIRHAVEN

Authors:	HENRY LONGEST - EPA - REGION I

Date:	November 19, 1993

Format:	LETTER	No. Pgs: 1

AR No.	13.01.6	Document No. 000202


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ADMINISTRATIVE RECORD INDEX
NEW BEDFORD HARBOR
HOT SPOT OPERABLE UNIT

04/23/99
Page 25

Title:

Addressee:
Authors:
Date:
Format:
AR No .

Response to Susan Grace's September 20, 1993
Letter Expressing Opposition to Incineration as
an Alternative Technology.

SUSAN GRACE

PAUL KEOUGH - EPA - REGION I
December 23, 1993

LETTER	No Pgs: 1

13.01.7	Document No. 000203

Title:	Letter Concerning Future Decisions on the New

Bedford Harbor Cleanup.

Addressee:	DAVID HAMMOND - HANDS ACROSS THE RIVER COALITION

Authors:	HARLEY LAING - EPA - REGION I

Date:	June 14, 1994

Format:	LETTER	No Pgs: 2

AR No.	13.01.8	Document No. 000204

Title:

Addressee:
Authors:

Date:
Format:
AR No .

Article Requested by Diana Cobbold of Sea Change
on the Long Term Stability and Leaching of ISV
Products.

DAVE DICKERSON - EPA - REGION I

ALAN FOWLER - FOSTER WHEELER ENVIRONMENTAL

CORPORATION

August 30, 1996

LETTER	No. Pgs: 12

13.01.9	Document No. 000069

Title:
Addressee:
Authors:

Date:
Format:
AR No .

Support Thermal Disorption as a Cleanup Remedy.

JOHN DEVILLARS - EPA - REGION I

JAMES SIMMONS, DANIEL MATTO, MAUREEN SANTOS,

ELIZABETH TAYLOR - HANDS ACROSS THE RIVER

COALITION

June 13, 1997

LETTER	No. Pgs: 2

13.01.10	Document No. 000068

Title:	PCB Harbor Forum.

Addressee:	JOHN DEVILLARS - EPA - REGION I

Authors:	PETER KOCZERA - TOWN OF ACUSHNET BOARD OF

SELECTMAN

Date:	July 14, 1997

Format:	LETTER	No. Pgs: 2

AR No.	13.01.11	Document No. 000067


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ADMINISTRATIVE RECORD INDEX
NEW BEDFORD HARBOR
HOT SPOT OPERABLE UNIT

04/23/99
Page 26

Title:	Development of the Feasibility Study

Addendum Report.

Addressee: JAMES SIMMONS - HANDS ACROSS THE RIVER
COALITION

Authors: HARLEY LAING - EPA - REGION I
Date:	July 18, 1997

Format:	LETTER	No Pgs: 3

AR No.	13.01.12	Document No. 000066

Title:	Selection of One Remedial Technology Over

Another.

Addressee:	CAROL SANZ

Authors:	JOHN DEVILLARS - EPA - REGION I

Date:	August 19, 1997

Format:	LETTER	No Pgs: 1

AR No.	13.01.13	Document No. 000045

Title:	List on Question to Submit ti the Sea Change

Panel Review.

Addressee:	DIANA COBBOLD - SEA CHANGE INC.

Authors:	JIM BROWN - EPA - REGION I

Date:	October 22, 1997

Format:	LETTER	No. Pgs: 1

AR No.	13.01.14	Document No.

000044

Title:

Addressee:
Authors:
Date:
Format:
AR No .

Organization of the October 30, 1997 Public Sea
Change Review of the Technologies for New
Bedford.

DIANA COBBOLD - SEA CHANGE INC.

HARLEY LAING - EPA - REGION I
December 12, 1997

LETTER	No. Pgs: 1

13.01.15	Document No. 000043

Title:	Resumes of Jim Brown and Dave
Dickerson.

Addressee:	JAMES SIMMONS - HANDS ACROSS THE RIVER COALITION

Authors:	HARLEY LAING - EPA - REGION I

Date:	December 23, 1997

Format:	LETTER	No. Pgs: 4

AR No.	13.10.16	Document No. 000042


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ADMINISTRATIVE RECORD INDEX
NEW BEDFORD HARBOR
HOT SPOT OPERABLE UNIT

04/23/99
Page 27

Title:	Complaint from a Resident Regarding a Release of

Hazardous Materials from the Sawyer Street
Facility.

Addressee: WARREN IDE - CITY OF NEW BEDFORD FIRE DEPARTMENT
Authors: JIM BROWN - EPA - REGION I
Date:	June 3, 1998

Format:	LETTER	No Pgs: 1

AR No.	13.01.17	Document No. 000065

13.03 COMMUNITY RELATIONS - NEWS CLIPPINGS/PRESS RELEASES

Title:	New Bedford Still Seeks Way to Deal with PCBs.

Authors:	PETER HOWE - BOSTON GLOBE

Format:	NEWS CLIPPING	No Pgs: 2

AR No.	13.03.1	Document No. 000052

Title:

Authors:
Format:
AR No .

EPA Announces a Meeting and Invites Public
Comment on the Explanation of Significant
Differences.

EPA - REGION I

NEWS CLIPPING	No. Pgs: 1

13.03.2	Document No,

000208

Title:	What's the Rush to Incinerate?

It's Time for EPA to Look Again.

Authors: STEVE URBON - NEW BEDFORD STANDARD TIMES
Date:	August 31, 1993

Format:	NEWS CLIPPING	No. Pgs: 1

AR No.	13.03.3	Document No.

000205

*Attached to Document No. 000200 In 13.01

Title:	EPA Virtually Abandons Plan to Burn PCB's.

Authors:	NATALIE WHITE - NEW BEDFORD STANDARD TIMES

Date:	January 27, 1994

Format:	NEWS CLIPPING	No. Pgs: 2

AR No.	13.03.4	Document No. 000207


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ADMINISTRATIVE RECORD INDEX
NEW BEDFORD HARBOR
HOT SPOT OPERABLE UNIT

04/23/99
Page 28

Title:	EPA Will Proceed with Dredging New Bedford Harbor

Hot Spots.

Authors: EPA - REGION I
Date:	February 10, 1994

Format:	NEWS CLIPPING	No Pgs: 1

AR No.	13.03.5	Document No. 000206

Title:	Briton to Document Agency's Victory Against PCB

Incineration.

Authors: WILLIAM COREY - STANDARD-TIMES
Date:	January 16, 1998

Format:	NEWS CLIPPING

AR No.	13.03.6

No Pgs: 2
Document No.

000049

Title:	Harbor Cleanup of PCBs is Still a Long Way Away.

Authors:	RACHEL G. THOMAS - STANDARD-TIMES

Date:	January 22, 1998

Format:	NEWS CLIPPING	No. Pgs: 1

AR No.	13.03.7	Document No. 000048

Title:	Time's a Wasting.

Authors:	JACK STEWARDSON - STANDARD-TIMES

Date:	February 7, 1998

Format:	NEWS CLIPPING

AR No.	13.03.8

No. Pgs : 5
Document No.

000047

Title:	Still No Decision on Disposal of PCBs.

Authors:	JACK STEWARDSON - STANDARD-TIMES

Date:	April 1, 1998

Format:	NEWS CLIPPING	No. Pgs: 1

AR No.	13.03.9	Document No.

000051

Title:	Forum Winding Up PCB Talks, Ready for Action.

Authors;	JACK STEWARDSON - STANDARD-TIMES

Date:	April 29,1998

Format:	NEWS CLIPPING	No. Pgs: 2

AR No.	13.03.10	Document No.

000053


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ADMINISTRATIVE RECORD INDEX
NEW BEDFORD HARBOR
HOT SPOT OPERABLE UNIT

04/23/99
Page 29

Title:	EPA Agrees to Meet Over Hiring Complaint.

Authors:	STANDARD-TIMES

Date:	May 1, 1998

Format:	NEWS CLIPPING

AR No.	13.03.11

No. Pgs : 4
Document No. 000054

Title:	PCBs: To Fill or Not To Fill.

Authors:	JACK STEWARDSON - STANDARD-TIMES

Date:	June 6, 1998

Format:	NEWS CLIPPING

AR No.	13.03.12

No. Pgs : 2
Document No.

000056

Title:	River Cleanup Takes a Giant Step.

Authors:	JACK STEWARDSON - STANDARD-TIMES

Date:	June 19, 1998

Format:	NEWS CLIPPING

AR No.	13.03. 13

No. Pgs : 2
Document No.

000055

13.04

COMMUNITY RELATIONS - PUBLIC MEETINGS

Title:

Authors
Date:
Format:
AR No .

Invitation to Attend Two Meetings to Discuss the
Treatment of the Hot Spot Sediment.

NEW BEDFORD SITE COMMUNITY FORUM

FACT SHEET, PRESS RELEASE
13.04 . 1

No. Pgs : 2
Document No.

000094

Title:	Minute of Meeting Held on December 7, 1993.

Date:	December 16, 1993

Format:	PUBLIC MEETING RECORDS	No. Pgs: 4

AR No.	13.04.2	Document No.

000209

Title:	Minutes of Meeting Held January 5, 1994.

Date:	January 5, 1994

Format:	PUBLIC MEETING RECORD	No. Pgs: 8

AR No.	13.04.3	Document No.

000210


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NEW BEDFORD HARBOR
HOT SPOT OPERABLE UNIT

04/23/99
Page	30

Title:	New Bedford Superfund Site Meeting Agenda -

January 12, 1994.

Date:	January 12, 1994

Format:	PUBLIC MEETING RECORD	No. Pgs: 1

AR No.	13.04.4	Document No. 000211

Title:	Minutes of Meeting Held January 12, 1994.

Date:	January 12, 1994

Format:	PUBLIC MEETING RECORDS	No Pgs: 3

AR No.	13.04.5	Document No. 000212

Title:	New Bedford Harbor Superfund Site Meeting Agenda

- January 26, 1994.

Date:	January 26, 1994

Format:	PUBLIC MEETING RECORDS	No. Pgs: 1

AR No.	13.04.6	Document No. 000213

Title:	Minute of Meeting Held January 26, 1994.

Date:	January 26, 1994

Format:	PUBLIC MEETING RECORDS	No. Pgs: 1

AR No.	13.04.7	Document No. 000214

Title:	Minutes of Meeting Held	February 9, 1994.

Date:	February 9, 1994

Format:	PUBLIC MEETING RECORDS	No. Pgs: 2

AR No.	13.04.8	Document No. 000215

Title:	New Bedford Harbor Superfund Forum Meeting Agenda

- March 1, 19 94.

Date:	March 1, 1994

Format:	PUBLIC MEETING RECORDS	No. Pgs: 6

AR No.	13.04.9	Document No. 000216

Title:	Minute of Meeting Held

Date:	March 1, 1994

Format:	PUBLIC MEETING RECORDS

AR No.	13.04.10

March 1, 19 94.

No. Pgs: 5
Document No. 000217


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NEW BEDFORD HARBOR
HOT SPOT OPERABLE UNIT

04/23/99
Page 31

Title:	New Bedford Harbor Superfund Site Meeting Agenda

- March 9, 19 94.

Date:	March 9, 1994

Format:	PUBLIC MEETING RECORDS	No. Pgs : 1

AR No.	13.04.11	Document No. 000218

Title:	Minutes of Meeting Held March 9, 1994.

Date:	March 9,1994

Format:	PUBLIC MEETING RECORDS	No. Pgs: 2

AR No.	13.04.12	Document No. 000219

Title:	Minutes of Meeting Held March 30, 1994.

Date:	March 30, 1994

Format:	PUBLIC MEETING RECORDS	No. Pgs: 2

AR No .	13.04.13	Document No. 000220

Title:	Minutes of Meeting Held April 6, 1994.

Date:	April 6, 1994

Format:	PUBLIC MEETING RECORDS	No. Pgs: 3

AR No.	13.04.14	Document No. 000221

Title:	Minutes of Meeting Held April 13, 1994.

Date:	April 13, 1994

Format:	PUBLIC MEETING RECORDS	No. Pgs: 2

AR No.	13.04.15	Document No. 000222

Title:	Minutes of Meeting Held April 26,	1994.

Date:	April 26, 1994

Format:	PUBLIC MEETING RECORDS	No. Pgs: 2

AR No.	13.04.16	Document No.

000223

Title:	Minutes of Meeting Held May 18,

1994 .

Date:	May 18, 1994

Format:	PUBLIC MEETING RECORDS	No. Pgs: 2

AR No.	13.04.17	Document No. 000224

Title:	New Bedford Harbor Superfund Site Meeting Agenda

- June 14, 1994.

Date:	June 14, 1994.

Format:	PUBLIC MEETING RECORDS	No. Pgs: 1

AR No.	13.04.18	Document No. 000226


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NEW BEDFORD HARBOR
HOT SPOT OPERABLE UNIT

04/23/99
Page 32

Title:
Date:
Format:
AR No .

Minutes of Meeting Held	June 14, 1994.

June 14, 1994

PUBLIC MEETING RECORDS	No. Pgs: 2

13.04.19	Document No. 000227

Title:
Date:
Format:
AR No .

Minutes of Meeting Held July	12, 1994.

July 12, 1994

PUBLIC MEETING RECORDS	No. Pgs: 3

13.04.20	Document No. 000228

Title:
Date:
Format:
AR No .

Minutes of Meeting Held August	9, 1994.

August 9, 1994

PUBLIC MEETING RECORDS	No. Pgs: 6

13.04.21	Document No. 000230

Title:

Date:
Format:
AR No .

New Bedford Harbor Superfund Site Community Forum
Agreement - (Cross Reference to 13.1.).

November 21, 1994

PUBLIC MEETING RECORDS	No. Pgs: 13

13.04.22	Document No. 000231

Title:

Date:
Format:
AR No .

New Bedford Harbor Superfund Forum - May 21,

1997 .

May 21, 1997

PUBLIC MEETING RECORDS	No. Pgs: 19

13.04.23	Document No. 000070

Title:

Date:
Format:
AR No .

New Bedford Harbor Treatability Study
Subcommittee Meeting.

July 16, 1997

PUBLIC MEETING RECORDS	No. Pgs: 8

13.04.24	Document No. 000071

Title:

Date:
Format:
AR No.:

New Bedford Superfund Forum Meeting - July 30,

1997 .

July 30, 1997

PUBLIC MEETING RECORDS	No. Pgs: 17

13.04.25	Document No. 000072


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NEW BEDFORD HARBOR
HOT SPOT OPERABLE UNIT

04/23/99
Page 33

Title:

New Bedford Harbor Treatability Subcommittee
Meeting - October 8, 1997.



Date:

October 8, 1997





Format:

PUBLIC MEETING RECORDS No. Pgs:

8



AR No .

13.04.2 6 Document

No .

000073

Title:

New Bedford Harbor Superfund Forum Meeting -
October 20, 1997.





Date:

October 20, 1997





Format:

PUBLIC MEETING RECORDS No. Pgs:

48



AR No .

13.04.27 Document

No .

000074

Title:

Sea Change Panel - New Bedford Harbor
Treatability Studies.





Date:

October 30, 1997





Format:

PUBLIC MEETING RECORDS No. Pgs:

27



AR No .

13.04.28 Document

No .

000075

Title:

New Bedford Harbor Superfund Forum Meeting -
November 6, 1997.





Date:

November 6, 1997





Format:

PUBLIC MEETING RECORDS No. Pgs:

4



AR No .

13.04.2 9 Document

No .

000076

Title:

New Bedford Harbor

Superfund Site Treatability



Study Participants

- Presentations.

Addressee:

TREATABILITY STUDY

PARTICIPANTS

Authors:

JIM BROWN - EPA -

REGION I

Date:

November 18, 19 97



Format:

LETTER

No. Pgs: 3

AR No .

13.04.30

Document No. 000077

Title:

Date:
Format:
AR No .

New Bedford Harbor Superfund Forum - December 1,
1997 .

December 1, 1997
PUBLIC MEETING RECORDS
13 .04.31

No. Pgs: 15
Document No.
000078


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NEW BEDFORD HARBOR
HOT SPOT OPERABLE UNIT

04/23/99
Page 34

Title:

Date:
Format:
AR No .

New Bedford Harbor Superfund Forum - December 8,

1997 .

December 8, 1997

PUBLIC MEETING RECORDS	No. Pgs: 28

13.04.32	Document No. 000079

Title:

Date:
Format:
AR No .

Summary of Meeting of the New Bedford Harbor
Forum - December 16, 1997.

December 16, 1997

PUBLIC MEETING RECORDS	No. Pgs: 5

13.04.33	Document No. 000080

Title:

Date:
Format:
AR No .

New Bedford Harbor Superfund Forum - January 21,

1998 .

January 21, 1998

PUBLIC MEETING RECORDS	No. Pgs: 16

13.04.34	Document No. 000081

Title:

Date:
Format:
AR No .

New Bedford Harbor Superfund Forum - January 21,

1998 .

January 21, 1998

PUBLIC MEETING RECORDS	No. Pgs: 9

13.04.35	Document No. 000098

Title:

Date:
Format:
AR No .

New Bedford Harbor Superfund Forum - February 5,

1998 .

February 5, 1998

PUBLIC MEETING RECORDS	No. Pgs: 3

13.04.36	Document No. 000082

Title:

Date:
Format:
AR No .

New Bedford Harbor Superfund Forum - February 12,
1998 .

February 12, 1998

PUBLIC MEETING RECORDS	No. Pgs: 6

13.04.37	Document No.

000083

Title:
Date:
Format:
AR No.:

New Bedford Community Meeting.
February 19, 1998
PUBLIC MEETING RECORDS
13.04.38

No. Pgs: 2

Document No.
000084


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NEW BEDFORD HARBOR
HOT SPOT OPERABLE UNIT

04/23/99
Page 35

Title:

Date:
Format:
AR No .

New Bedford Harbor Superfund Forum - February 25,

1998 .

February 25, 1998

PUBLIC MEETING RECORDS	No. Pgs: 5

13.04.39	Document No. 000085

Title:

Date:
Format:
AR No .

New Bedford Harbor Superfund Forum - March 15,

1998 .

March 15, 1998
PUBLIC MEETING RECORDS	No Pgs: 21

13.04.40	Document No. 000086

Title:

Date:
Format:
AR No .

New Bedford Harbor Superfund Forum - March 24,

1998 .

March 24, 1998

PUBLIC MEETING RECORDS	No. Pgs: 7

13.04.41	Document No. 000087

Title:

Date:
Format:
AR No .

New Bedford Harbor Superfund Forum - March 31,

1998 .

March 31, 1998

PUBLIC MEETING RECORDS	No. Pgs: 34

13.04.42	Document No. 000088

Title:

Date:
Format:
AR No .

New Bedford Harbor Superfund Forum - April 28,

1998 .

April 28, 1998

PUBLIC MEETING RECORDS	No. Pgs: 15

13.04.43	Document No. 000089

Title:
Date:
Format:
AR No .

New Bedford Harbor Superfund Forum - May 7, 1998.
May 7, 1998

PUBLIC MEETING RECORDS	No. Pgs: 6

13.04.44	Document No. 000090

Title:

Date:
Format:
AR No..

New Bedford Harbor Superfund Forum - May 22,
1998 .

May 22, 1998

PUBLIC MEETING RECORDS	No. Pgs: 6

13.04.45	Document No.

000091


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NEW BEDFORD HARBOR	Page 36



HOT SPOT OPERABLE UNIT





Title:

New Bedford Harbor Superfund Forum
1998 .

- June 4,



Date:

June 4, 1998





Format:

PUBLIC MEETING RECORDS

No. Pgs : 6



AR No .

13 . 04 . 46

Document No.

000092

Title:

New Bedford Harbor Superfund Forum
1998 .

- June 17,



Date:

June 17, 1998





Format:

PUBLIC MEETING RECORDS

No. Pgs: 2 6



AR No .

13 .04.47

Document No.

000093

Title:

New Bedford Harbor Superfund Site
Recommendation.

Community Forum

Authors:

NEW BEDFORD SITE COMMUNITY FORUM





Date:

July 1998





Format:

MEMORANDUM

No. Pgs: 17



AR No .

13 . 04 . 48

Document No.

000234

Title:

Notice of a Public Meeting on the

Proposed Plan

.

Authors;

EPA - REGION I





Date:

August 7, 1998





Format:

NEWS CLIPPING

No. Pgs : 1



AR No .

13 . 04 . 49

Document No.

000050

Title:

Proposed Cleanup Plan for the Hot
Public Informational Meeting.

Spot Sediment

—

Date:

August 26, 1998





Format:

PUBLIC MEETING RECORDS

No. Pgs: 12



AR No .

13 . 04 . 50

Document No.

000096

Title:

Attendance List - Proposed Plan to
Cleanup Plan - Public Hearing.

Amend the 1990

Date:

September 16, 1998





Format:

LIST

No. Pgs : 2



AR No .

13 . 04.51

Document No.

000097


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NEW BEDFORD HARBOR
HOT SPOT OPERABLE UNIT

04/23/99
Page 37

Title:	EPA Public Hearing - Cleanup Plan for the New

Bedford Harbor Hot Spot Sediments.

Date:	September 16, 1998

Format:	PUBLIC MEETING RECORDS	No. Pgs: 50

AR No.	13.04.52	Document No. 000232

13.05 COMMUNITY RELATIONS - FACT SHEETS

Title:

Authors:
Format:
AR No .

New Bedford Harbor Superfund Site: The Community

Forum's Focus on Cleanup of the Hot Spot

Sediment.

EPA - REGION I

FACT SHEET, PRESS RELEASE

13.05.1	Document No. 00003

Title:

Format:
AR No .

The USEPA Announces the Scheduling of a Public
Meeting, Hearing, and Public Comment Period on
the Proposed Plan.

FACT SHEET, PRESS RELEASE	No. Pgs: 2

13.05.2	Document No. 000095

Title:	An open Letter to the Members of the New Bedford

Harbor Superfund Forum.

Addressee:	NEW BEDFORD HARBOR SUPERFUND FORUM

Authors:	THOMAS E. NOEL - COMMODORE ADVANCES SCIENCES

Date:	July 30, 1997

Format:	LETTER	No. Pgs: 1

AR No.	13..05.3	Document No. 000037

Title:	New Bedford Harbor Superfund Site Verification

Test Program.

Authors:	COMMODORE SOLUTION TECHNOLOGIES,

INC.

Date:	August 1997

Format:	REPORT, STUDY

AR No.	13.05.4	Document No. 000035


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ADMINISTRATIVE RECORD INDEX
NEW BEDFORD HARBOR
HOT SPOT OPERABLE UNIT

04/23/99
Page 38

Title:	Explanation of the Merits of the Commodore SET

Process in Remediation PCB Waste.

Addressee: NEW BEDFORD HARBOR SUPERFUND FORUM
Authors:	PAUL E. HANNESSON - COMMODORE APPLIED

TECHNOLOGIES, INC.

Date:	November 5, 1997

Format:	LETTER	No. Pgs: 1

AR No.	13.05.5	Document No. 000036

Title:	Innovative Treatment Technology Proposal

Evaluation Criteria.

Authors:	JIM BROWN - EPA - REGION I

Date:	January 16, 1998

Format:	CORRESPONDENCE

AR No.	13.05.6

No. Pgs: 5
Document No.

000034

Title:

Date:
Format:
AR No .

New Bedford Harbor Superfund Site Community Forum
Recommendation.

July 1998
REPORT, STUDY

13.05.7	Document No. 000039

Title:	Update on the Release of the Proposed Plan.

Addressee:	NEW BEDFORD HARBOR SUPERFUND FORUM

Authors:	JIM BROWN - EPA - REGION I

Date:	July 17, 1998

Format:	LETTER	No. Pgs: 1

AR No.	13.05.8	Document No. 000038

14 . 01 CONGRESSIONAL RELATIONS - CORRESPONDENCE

Title:

Addressee:
Authors:

Date:
Format:
AR No .

Request for Participation in Workshop -
Alternatives to Incineration for Disposal of PCB
Contaminates.

JULIE BELAGA - EPA - REGION I
GERRY STUDDS - U.S. HOUSE OF
REPRESENTATIVES
January 29, 1992
LETTER
14.01.1

No. Pgs: 2
Document No.

000001


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ADMINISTRATIVE RECORD INDEX
NEW BEDFORD HARBOR
HOT SPOT OPERABLE UNIT

04/23/99
Page 39

Title:

Addressee:
Authors:
Date:
Format:
AR No .

Response to Representative Studds Letter of
January 29, 1992 Requesting EPA Participation in
a Workshop.

GERRY STUDDS - U.S. HOUSE OF REPRESENTATIVES
JULIE BELAGA - EPA - REGION I
February 27, 1992

LETTER	No. Pgs: 2

14.01.2	Document No. 000002

Title:	Results of the Alternative Treatment Technologies

Workshop Conducted on March 5, 1992.

Addressee: GERRY STUDDS - U.S. HOUSE OF REPRESENTATIVES
Authors: JULIE BELAGA - EPA - REGION I
Date:	Marcg 18, 1992

Format: LETTER	No. Pgs: 1

AR No.	14.01.3	Document No. 000003

Title:

Addressee:
Authors:
Date:
Format:
AR No .

Letter Congratulating EPA On Its Research into
Treatment Technologies at the New Bedford
Superfund Site.

JULIE BELAGA - EPA - REGION I

EDWARD KENNEDY, JOHN KERRY - U.S. SENATE

March 24, 1992

LETTER	No. Pgs: 1

14.01.4	Document No. 000004

Title:

Addressee:
Authors:
Date:
Format:
AR No .

Cover letter - Letter Sent to Congressman Studds
on April 21, 1992 Reguarding Use of Alternative
Treatment Technologies.

EDWARD KENNEDY - U.S. SENATE
JULIE BELAGA - EPA - REGION I
April 21, 19 92
LETTER
14.01.5

No. Pgs : 1
Document No.

000005

Title :

Addressee:
Authors:
Date:
Format:
AR No .

Cover letter - Letter Sent to Congressman Studds

on April 21, 1992 Regarding Use of Alternative

Treatment Technologies.

JOHN KERRY - U.S. SENATE

JULIE BELAGA - EPA - REGION I

April 21, 19 92

LETTER	No. Pgs: 1

14.01.6	Document No. 000006


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ADMINISTRATIVE RECORD INDEX
NEW BEDFORD HARBOR
HOT SPOT OPERABLE UNIT

04/23/99
Page 40

Title:

Addressee:

Authors:
Date:
Format:
AR No .

Incineration Considered as Best Treatment

Technology for the New Bedford Harbor Superfund

Site (Hot Spot).

GERRY STUDDS - U.S. HOUSE OF

REPRESENTATIVES

JULIE BELAGA - EPA - REGION I

April 21, 19 92

LETTER	No. Pgs: 2

14.01.7	Document No. 000007

Title:

Addressee:
Authors:
Date:
Format:
AR No .

Letter in Response to the Review of Technologies

as Alternatives to Incineration for the New

Bedford Superfund Site.

JULIE BELAGA - EPA - REGION I

EDWARD KENNEDY, JOHN KERRY - U.S. SENATE

May 11, 1992

LETTER	No. Pgs: 2

14.01.8	Document No. 000009

Title:

Addressee:
Authors:
Date:
Format:
AR No .

Letter Expressing Concerns Regarding EPA's
Proposed Cleanup Plan for the Acushnet Bay, Lower
New Bedford Harbor, and Parts of Buzzards Bay.
JULIE BELAGA - EPA - REGION I

GERRY STUDDS - EPA - U.S. HOUSE OF REPRESENTATIVES
May 15, 1992

LETTER	No. Pgs: 2

14.01.9	Document No. 000010

Title:

Addressee:
Authors:
Date:
Format:
AR No .

Response to Letter of May 11, 1992 Requesting
Additional Information on EPA's Review of
Technologies for the Remediation of the Hot Spot.
JOHN KERRY - U.S. SENATE
JULIE BELAGA - EPA - REGION I
June 12, 1992

LETTER	No. Pgs: 3

14.01.10	Document No. 000011

Title:

Addressee:
Authors:
Date:
Format:
AR No .

Response to Letter of May 11, 1992 Requesting
Additional Information on EPA's Review of
Technologies for the Remediation of the Hot Spot.
EDWARD KENNEDY - U.S. SENATE
JULIE BELAGA - EPA - REGION I
June 12, 1992

LETTER	No. Pgs: 3

14.01.11	Document No. 000012


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ADMINISTRATIVE RECORD INDEX
NEW BEDFORD HARBOR
HOT SPOT OPERABLE UNIT

04/23/99
Page	41

Title:	Letter of Support for Overturning the Decision to

Incinerate PCBs.

Addressee: WILLIAM REILLY - EPA-HEADQUARTERS
Authors:	BARNEY FRANK - U.S. HOUSE OF

REPRESENTATIVES
Date:	June 17, 1992

Format:	LETTER

AR No.	14.01.12

No Pgs: 1

Document No. 000013

Title:

Addressee:
Authors:
Date:
Format:
AR No .

Response to Gerry Studds Letter of May 15, 1992
Which Commented on the Proposed Plan for the
Estuary/Lower Harbor/Bay Portion of New Bedford
Harbor.

GERRY STUDDS - U.S. HOUSE OF REPRESENTATIVES
JULIE BELAGA - EPA - REGION I
June 18, 1992

LETTER	No Pgs: 2

14.01.13	Document No. 000014

Title:	Request Suspension of the Incineration of PCBs in

Favor of an Alternative Method.

Addressee:	CAROL BROWNER - EPA-HEADQUARTERS

Authors:	BARNEY FRANK - U.S. HOUSE OF REPRESENTATIVES

Date:	January 22, 1993

Format:	LETTER	No. Pgs: 2

AR No.	14.01.14	Document No. 000017

Title:	Letter Identifying Incineration as the Best

Treatment Technology.

Addressee:	BARNEY FRANK - U.S. HOUSE OF REPRESENTATIVES

Authors:	RICHARD GUIMOND - EPA-HEADQUARTERS

Date:	March 8, 1993

Format:	LETTER	No. Pgs: 3

AR No.	14.01.15	Document No. 000015

Title:

Addressee:
Authors:
Date:
Format:
AR No .

Request for an On-Site Test of Thermal Gas-Phase

Reductive Chlorination.

CAROL BROWNER - EPA-HEADQUARTERS

EDWARD KENNEDY, JOHN KERRY - U.S. SENATE

July 9, 1993

LETTER	No. Pgs: 2

14.01.16

Document No. 000016


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ADMINISTRATIVE RECORD INDEX
NEW BEDFORD HARBOR
HOT SPOT OPERABLE UNIT

04/23/99
Page 42

Title:

Addressee:
Authors:
Date:
Format:
AR No .

Support for Incineration as the Established
Remedy for the New Bedford Superfund Site.

EDWARD KENNEDY - U.S. SENATE
HENRY LONGEST - EPA-HEADQUARTERS
August 18, 1993

LETTER	No Pgs: 2

14.01.17	Document No. 000018

Title:

Addressee:
Authors:
Date:
Format:
AR No .

Request to Reconsider the Termination of the
Incineration Remedial Treatment Technology.

BARNEY FRANK - U.S. HOUSE OF REPRESENTATIVES
JOHN MORAN - LABORERS HEALTH & SAFETY FUND
August 20, 1993

LETTER	No Pgs: 6

14.01.18	Document No. 000019

Title:

Addressee:
Authors:
Date:
Format:
AR No .

Discussion of Issues Involving the Incineration

of PCBs in New Bedford.

CAROL BROWNER - EPA-HEADQUARTERS

BARNEY FRANK - U.S. HOUSE OF REPRESENTATIVES

October 12, 1993

LETTER	No. Pgs: 3

14.01.19	Document No. 000021

Title:

Addressee:
Authors:

Date:
Format:
AR No .

Reopening Discussions about the Method of Cleanup
at the New Bedford Harbor Superfund Site.

PAUL KEOUGH - EPA - REGION I

EDWARD KENNEDY, JOHN KERRY, BARNEY FRANK - U.S.
SENATE

October 19, 1993

LETTER

14.01.20

No. Pgs: 2
Document No. 000020

Title:

Addressee:
Authors:
Date:
Format:
AR No .

Reopening the Question of How Best to Deal with
the PCB Problem in New Bedford.

PAUL KEOUGH - EPA - REGION I

BARNEY FRANK - U.S. HOUSE OF REPRESENTATIVES
November 2, 1993

LETTER	No. Pgs: 1

14.01.21	Document No. 000027


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ADMINISTRATIVE RECORD INDEX
NEW BEDFORD HARBOR
HOT SPOT OPERABLE UNIT

04/23/99
Page 43

Title:

Addressee:
Authors:
Date:
Format:
AR No .

Response to Senator Edward Kennedy's Letter of
October 19, 1993 to Hold a Forum on the Issue of
Incineration.

EDWARD KENNEDY - U.S. SENATE
PAUL KEOUGH - EPA - REGION I
November 8, 1993

LETTER	No Pgs: 2

14.01.22	Document No. 000022

Title:

Addressee:
Authors:
Date:
Format:
AR No .

Response to Representative Barney Frank's Letter

of October 19, 1993 to Hold
of Incineration.

BARNEY FRANK - U.S.

PAUL KEOUGH - EPA - REGION
November 8, 1993
LETTER
14 .01.23

a Forum on the Issue

HOUSE OF REPRESENTATIVES
I

No Pgs: 2
Document No.

000023

Title:

Addressee:
Authors:
Date:
Format:
AR No .

Response to Senator John Kerry's Letter of

October 19, 1993 to Hold a Forum on the Issue of

Incineration.

JOHN KERRY - U.S. SENATE

PAUL KEOUGH - EPA - REGION I

November 8, 1993

LETTER	No. Pgs: 2

14.01.24	Document No. 000024

Title:	Reconsider Support of Incineration as the

Acceptable Treatment Technology.

Addressee: DANIEL GREENBAUM - MA DEPT OF ENVIRONMENTAL
PROTECTION

Authors:	BARNEY FRANK - U.S. HOUSE OF REPRESENTATIVES

Date:	December 16, 1993

Format:	LETTER	No. Pgs: 1

AR No.	14.01.25	Document No. 000025

Title:

Addressee:
Authors:

Date:
Format:
AR No .

Response to Representative Barney Frank's Letter
on the Reconsideration of Incineration as the
Chosen Treatment Technology.

BARNEY FRANK - U.S,

DANIEL GREENBAUM -

PROTECTION

December 29, 1993

LETTER

14.01.26

HOUSE OF REPRESENTATIVES
MA DEPT OF ENVIRONMENTAL

No. Pgs : 2
Document No.

000026


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ADMINISTRATIVE RECORD INDEX
NEW BEDFORD HARBOR
HOT SPOT OPERABLE UNIT

04/23/99
Page 44

Title:	Concern Regarding Change in the Cleanup Remedy at

the New Bedford Harbor Superfund Site.

Addressee:	STROM THURMOND - U.S. SENATE

Authors:	BENEDICT ROSEN - AVX CORPORATION

Date:	March 24, 1994

Format:	LETTER	No Pgs: 4

AR No.	14.01.27	Document No. 000029

Title:	Established of a Community Forum to Review

Alternatives to On-Site Incineration.

Addressee:	STORM THURMOND - U.S. SENATE

Authors:	JOHN DEVILLARS - EPA - REGION I

Date:	May 11, 1994

Format:	LETTER	No Pgs: 3

AR No.	14.01.28	Document No.

000028

Title:	EPA Reviewing Alternatives to On-Site

Incineration at Community Forum.

Addressee:	ERNEST HOLLINGS - U.S. SENATE

Authors:	JOHN DEVILLARS - EPA - REGION I

Date:	May 27, 1994

Format:	LETTER	No. Pgs: 3

AR No.	14.01.2 9	Document No,

000031

Title:	EPA Reviewing Alternatives to On-Site

Incineration at Community Forum.

Addressee:	ARTHUR RAVENEL - U.S. HOUSE OF REPRESENTATIVES

Authors:	JOHN DEVILLARS - EPA - REGION I

Date:	June 1, 1994

Format:	LETTER	No. Pgs: 3

AR No.	14.01.30	Document No. 000030

Title:	Response to Representative Barney Frank's Letter

of January 25, 1996 Reguarding the Performance of
Treatability Studies.

Addressee: BARNEY FRANK - U.S. HOUSE OF REPRESENTATIVES
Authors:	JOHN DEVILLARS - EPA - REGION I

Date:	March 1, 1996

Format:	LETTER	No. Pgs: 2

AR No.	14.01.31	Document No. 000032


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ADMINISTRATIVE RECORD INDEX
NEW BEDFORD HARBOR
HOT SPOT OPERABLE UNIT

04/23/99
Page 45

Title:

Addressee:
Authors:

Date:
Format:
AR No .

Discussion of New Bedford Harbor Superfund
Community Forum's Position On Site Cleanup.
BARNEY FRANK - U.S. HOUSE OF REPRESENTATIVES
CLAUDIA KIRK - NEW BEDFORD HARBOR
SUPERFUND FORUM
July 26, 1997

LETTER	No Pgs: 10

14.01.32	Document No. 000040

Title:

Addressee:
Authors:
Date:
Format:
AR No .

Issues Raised Regarding the New Bedford Harbor

Cleanup Process.

JIM BROWN - EPA - REGION I

BARNEY FRANK - U.S. HOUSE OF REPRESENTATIVES
September 16, 1998

LETTER	No Pgs: 1

14.01.33	Document No. 000233

17.08

SITE MANAGEMENT RECORDS - STATE AND LOCAL TECHNICAL RECORDS

Title:	Letter Against the Incineration Process at the

New Bedford Harbor Superfund Site/Hot Spot.
Addressee: DANIEL GREENBAUM - MA DEPT OF ENVIRONMENTAL
PROTECTION

Authors: GEORGE ROGERS - CITY OF NEW BEDFORD
Date:	Octeober 4, 1993

Format:	LETTER	No. Pgs: 2

AR No.	17.08.1	Document No. 00019S:

*Attached to Document No. 000196 In 13.01


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Guidance Documents

The EPA guidance documents listed below were considered during the process of selecting the
response action for the New Bedford Harbor Hot Spot Operable Unit. These EPA guidance
documents may be reviewed at the EPA Region I Superfund Records Center.

1.	Conducting Remedial Investigations/Feasibility Studies for CERCLAMunicipal Landfill Sites.
OSWER #9355.3-11. February 1, 1991. [C177]

2.	Feasibility Study - Development and Screening of Remedial Action Alternatives [Quick
Reference Fact Sheet], OSWER #9355.3-01FS3. November 1, 1989. [2018]

3.	Guidance on Feasibility Studies Under CERCLA. EPA540/G-85-003. June 1,1985. [C034]

4.	Guidance on Preparing Superfund Decision Documents: The Proposed Plan, the Record of
Decision. ESD's ROD Amendment. Interim Final. OSWER #9355.3-02. April 3, 1989.
[CI 79]

5.	Guidance on Remedial Actions for Superfund Sites with PCB Contamination. OSWER
#9355.4-01. August 1, 1990. [2014]

6.	Guide for Conducting Treatability Studies Under CERCLA. Interim Final. EPA/540/2-
89/058. December 1, 1989. [2015]

7.	Guide on Remedial Actions at Superfund Sites with PCB Contamination [Quick Reference
Fact Sheet], OSWER #9355.4-01FS. August 1, 1990. [C254]

8.	Guide to Addressing Pre-ROD and Post-ROD Changes. OSWER #9355.3-02FS-4. April
1, 1991. [C259]

9.	Guide to Selecting Superfund Remedial Actions. EPA/540/2-89/052. March 1, 1989.
[2322],


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Appendix C-State Concurrence Letter

New Bedford Harbor Superfund Site
Amended Record of Decision for the Hot Spot Sediments


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Commonwealth of Massachusetts
Executive Office of Environmental Affairs
Department of Environmental Protection

ONE WINTER STREET, BOSTON, MA 02108 617-292-5500

ARGEO PAUL CELLUCCI
Governor

BOB DURAND

Secretary

JANE SWIFT
Lieutenant Governor

EDWARD P. KUNCE

Acting Commissioner

April 23,1999

Ms. Patricia Meaney, Director

Office of Site Remediation and Restoration

U.S. EPA

JFK Federal Building
Boston, MA 02203

Dear Ms. Meaney:

The Department of Environmental Protection (DEP) has reviewed the preferred remedial action
alternative recommended by the EPA for the cleanup of the Hot Spot Operable Unit at the New
Bedford Harbor Superfimd Site. The DEP concurs with the selection of the preferred alternative for
this operable unit.

The DEP has evaluated the EPA's preferred alternative for consistency with M.G.L. Chapter 21E,
and the Massachusetts Contingency Plan (MCP). The preferred alternative addresses the
contaminated sediments that were previously dredged and are currently being stored in a Confined
Disposal Facility in New Bedford. This Operable Unit's amended remedial action has four
components:

1)	Upgrade site facilities;

2)	Remove the Hot Spot sediment from the Confined Disposal Facility (CDF);

3)	Sediment dewatering and water treatment; and

4)	Sediment disposal to an appropriate disposal facility off site.

The DEP has determined that the preferred alternative for this Operable Unit is a remedial action on
a portion of the disposal site which would be consistent with a future permanent or temporary
solution for the entire disposal site. M.G.L. Chapter 21E allows the implementation of remedies on
portions of a disposal site.

Re: Amended ROD - State Concurrence Letter
Hot Spot Operable Unit #2
New Bedford Harbor Superfund Site


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State ROD Concurrence
April 23, 1999
Page 2

EPA's current project managers, Jim Brown and Dave Dickerson, should be commended for a superb
job in managing this complex project. Their efforts to include the State and the public in the
Superfund process at this site have been greatly appreciated.

The Department looks forward to working with you in implementing the preferred alternative. If you
have any questions, please contact Paul Craffey at 292-5591.

Very truly yours,

Deirdre C. Menoyo,

Assistant Commissioner
Bureau of Waste Site Cleanup

cc: Millie Garcia-Surette, Deputy Regional Director, SERO

DBS/BWSC /pc


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APPENDIX D - References Cited

New Bedford Harbor Superfund Site
Amended Record of Decision for the Hot Spot Sediments


-------
APPENDIX D - REFERENCES CITED

City of New Bedford, 1993. City of New Bedford, Code of City Ordinances, Chapter 15,

Licenses and Permits; Business Regulations, Article III, Proposed amendments to Sec. 15-70
(June 10, 1993).

Forum Agreement, 1998. New Bedford Harbor Superfund Site Community Forum
Recommendation. June-July 1998.

Foster Wheeler, 1997a. Draft Final New Bedford Harbor Hot Spot Feasibility Study Addendum,
New Bedford, Massachusetts. December 1997.

Foster Wheeler, 1997b. New Bedford Harbor Hot Spot Treatability Study Data Compendium
Volumes II-X. September 1997.

NUS Corporation (NUS), 1994. Draft Feasibility Study of Remedial Action Alternatives,

Acushnet River Estuary Above Coggeshall Street Bridge, New Bedford Site, Bristol County,
Massachusetts. August 1984.

US ACE, 1991a. Construction Plans for the New Bedford Harbor Superfund Hazardous Waste
Cleanup, Hot Spot Operable Unit, New Bedford, Massachusetts. US Army Corps of Engineers,
Omaha District. December 1991.

USACE, 1991b. Final Design Analysis, New Bedford Harbor/Hot Spot Operable Unit Superfund
Site, Contract No. DACW 45-91-C-0010, Interagency Agreement No. DW96934684-0, New
Bedford, Massachusetts. November 1991.

USACE, 1991c. Specifications (For Construction Contract), Request for Proposal No.
DACW45-92-R-0020, Hazardous Waste Cleanup, New Bedford Harbor/Hot Spot Operable Unit,
Volumes 1-2. December 1991,

USEPA, 1990. Record of Decision, New Bedford Harbor Hot Spot Operable Unit, New Bedford,
Massachusetts. U.S. Environmental Protection Agency, Region I. April 1990.

USEPA, 1992. New Bedford Harbor Site, Hot Spot Operable Unit Explanation Of Significant
Difference, April 1992.

USEPA, 1995. New Bedford Harbor Superfund Site, Hot Spot Operable Unit, Explanation Of
Significant Difference for Continued Storage of Hot Spot Sediments. Prepared by the EPA-New
England. October 1995.

USEPA 1998a. Proposed Plan to Amend the 1990 Cleanup Plan for the New Bedford Hot Spot
Sediments, New Bedford, MA. August 1998.


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USEPA 1998b. Record Of Decision for the Upper and Lower Operable Unit, New Bedford
Harbor Superfund Site, New Bedford, Massachusetts. September 1998.

VHB, 1996. New Bedford Harbor Historic Overview, Natural Resources Uses Status Report.
Prepared by Vanasse Hangen Brustlin, Inc. For New Bedford Harbor Trustee Council. July 1996.


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