FIVE-YEAR REVIEW REPORT FOR
BAIRD & MCGUIRE SUPERFUND SITE
NORFOLK COUNTY, MASSACHUSETTS
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Prepared by
U.S. Environmental Protection Agency
Region 1, New England
Boston, Massachusetts
y—t£±-—
James T. Owens, III, Division Director Date
Office of Site Remediation and Restoration
U.S. EPA, New England
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i Mil i Of ( ON 1 IM S
LIST or ACRONYMS , iii
EXECUTIVE SUMMARY I S-1
I. INTRODUCTION !
II. PROGRESS SINCE THE LAST RI-.VIEW... 2
Remedy Implementation Activities 8
System Oporation'Operution and Maintenance Activities I I
III. FIVE-YEAR REVIEW PROCESS 17
Administrative Components 17
Community Notification and Involvement .....17
Document Review.. 17
Data Review,.., IS
Treatment Plant EOluent Monitoring IK
Cjroundwater Monitoring... 19
Cochato River Sediment. Surface Water, and Fish Tissue Monitoring 24
Wetland Monitoring 25
Site Inspection 26
Interviews 27
IV. TECHNICAL ASSKSSMHNT 29
Question A: Is the remedy functioning us intended by the decision documents".' 29
Question B: Are the exposure assumptions, toxicity data, cleanup levels, and remedial action
objectives (RAOs) used at the time of the remedy section still valid? ....29
Review of Human Health Risk Assessment.... 30
Review of Ecological Risk Assessment 36
ARARs Review........... ...,40
Quest ion C; Has any other information come to light that could call into question the
prolectiveness of the remedy'.' 42
Technical Assessment Summary 42
\ . ISSCS.S R! COMMENDATIONS AND EOEEOW-l PACTIONS 42
VE PROTECT!VENESS STATEMENT 46
VIE NEXT REVIEW ...48
i
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I Alii I:,5
Tabic 1 Protectivencss Determinations'Statemcnts from the 2009 FYR 2
Table 2 Status of Recommendations from the 2009 FYR 3
Tabic 3 Summary of Planned and or Implemented It's ...6
Table 4 Summary ofO&M Costs...... 8
Tabic 5 Summary ofGWTF Discharge Hxeeedanee 10
Table 6 (Jrourtdwater MCL Lxceedances in 2011 11
Table 7 Comparison of lcW) and 2014 Oral Reference Doses and Oral Cancer Slope Factors For
Compounds of Potential Concern 23
Table 8 Issues and Recommendations Follow-up Actions 34
apppndk \ s
Appendix A Existing Site Information
Appendix R Figures
Appendix C - Fist of Documents Reviewed and References
Appendix D Analytical Results
Appendix I7. ¦ Site Inspection
Appendix F - Interview Record Forms
Appendix G - Risk Calculations
Appendix 11 ARARs Review Tables
it
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( IS! Ol \CROM \JS
AAl- Acceptable Ambient Air Level
ARAft Applicable or Relevant and Appropriate Requirement
AUL Acti\ity and Use I.imitation
AWQl Ambient Water Quality Criteria
BOH Board of Health
CLRCLA Comprehensive Hnvironmental Response. Compensation, and Liability Act.
42 CSC § %0I et seq,
CI R Code of Federal Regulations
CIC Community involvement Coordinator
COC Contaminant of Concern
COD Chemical Oxygen Demand
COPC Contaminant of Potential Concern
CAVA Clean Water Act
DEM Department of Hnvironmental Management
DLQL Massachusetts Department of Ln\ ironmcntal Quality Lngineering
DOT Department of Transportation
lit) Executive Order
FPA F.nvironmentai Protection Agenc> (U.S. LP A - Region 1 >
L:RA Lcolog-cal Risk Assessment
FRFD Lnvironmental Residue 1: fleets Database
LSD Lxplanation of Signilleant D die re i ices
FW l-xtraetion Well
FDA U.S. Food and Drug Administration
1 (FR \ FederaI Insecticide. Fungicide, and Rodenticide Act of 194?
FS Feasibility Stud}'
CrAC Granular Activated Carbon
FYR Five Year Review
CiW'TT' Uroundwater Treatment Facility
I!Q I ia/ard Quotient
ICs Institutional Controls
IS Incineration and Stabilization
l.SAPL Light Non-Aqueous Phase Liquid
LOAFL Lowest Observed Adverse L fleets Level
LIRA Long-term Response Action
M&L Mclealf & Fddy
MassDLP Massachusetts Department of Lnvironmental Protection
M( Ls Maximum Contaminant Levels
iii
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Mi p \
Massachusetts Environmental Policy Act
MOD
Million Gallons Per Day
\!N A
Monitored Naiural Attenuation
NCP
National Contingency Plan, 4(1 O R Part 300
NO A A
National Oceanic and Atmospheric Administration
NO A EI .
No Adverse Effects Levels
\l'i
National Priority List
OK VI
Operation and Maintenance
OMFl
Ontario Ministry of Environment and Energy
ORP
Oxidation-Reduction Potential
OU-1
Operable Unit 1
OV-2
Operable Unit 2
01.5-3
Operable Unit 3
OlM
Operable Unit 4
PAHs
Polycyclie Aromatic Hydrocarbons
PLC
Programmable Logic Controller
PR P
potentially responsible party
RAC
Response Action Contract
RAO
Remedial Action Objective
RCRA
Resource Conservation and Recovery Act. 42 U.S.C
RID
Reference Dose
RI
Remedial Investigation
ROD
Record of Decision
RPVI
Remedial Project Manager
RSI
Remedial System Evaluation
S( ADA
Superv isory Control and Data Acquisition
SOW A
Safe Drinking Water Act
si-
Slope Factor
S< H ¦
Sediment Qua lit \ Criteria
SVOCs
Semivolatile Organic Compounds
TBC
To Be Considered
T PI 1
Total Petroleum Hydrocarbon
TLV
Threshold Limit Value
TRY
Toxicity Reference Value
UCL
Upper Concentration Limit
USACE
United States Army Corps of Engineers
\ ED
Variable Frequency Drive
VOCs
Volatile Organic Compound>
iv
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f \M ( Iivi SI MM \in
This is the fourth Five-Year Review (FYR) for the Baird & McGuire Supcrfund Site localed in
Holbrook,, Norfolk County, Massachusetts, The purpose of this FYR. is to review information to
determine if the remedy is and will continue to be protective of human health and the
environment. The triggering action for this statutory FYR was the .signing of the previous FYR
on 9.'2l),200t>.
The Baird & Met in ire Superfltnd Site is located on South Street in Holbrook. VIA (Figure 1 in
Appendix B) The Site boundary ant! coincident fence line are shown on Figure 2. based on a
Site sur\ ev conducted in May 198K. The Site designated on Figure 2 has been determined to
consist of approximately 32.5 acres. As illustrated on Figure 2, the Silc is not limited to land
within the former Baird & McGuire properties. Historically, Lots 130, 130-1 and 130-2 ha\e
had Baird & McGuire ownership. These lots consist of 9.33 acres, of which approximately 8
acres are within the Site boundaries. The remaining 24.5 acres of the Site consist of portions of
five privately owned lots and two lots jointly owned by the towns of Holbrook and Randolph. In
addition, four privately owned lots located east of the Coehato River (I ots 6, J 2-2 and 12-3, as
shown on Figure 2 in Appendix B) have restricted access to the river due to the presence of the
security fence.
At the time of the RODs. the Baird & McGuire Site was used for commercial and industrial
purposes. Currently, the Site is occupied by the Groundwater Treatment Facility (GWTF).
Current and planned uses are still commercial industrial in nature.
Site contamination occurred during the operations of a chemical manufacturing company (Baird
& McGuire) from 1c) 12 to 19X3, that produced herbicides, pesticides, disinfectants, soaps, floor
waxes and solvents. Waste disposal methods at the site included direct discharge into the soil, a
nearby brook and wetlands, a former gravel pit in the eastern portion of the site, and underground
disposal systems, Volatile organic compounds {VOCs'f, semi-volatile organic compounds
tSYOCs), polyeyelie aromatic hydrocarbons (PAHs), pesticides, and heavy metals including lead
and arsenic are the contaminants of concern in site soils, sediment, and groundwater.
Additionally, a light non-aqueous phase liquid (LNAPI.) plume has been determined to be the
primary source of contamination in groundwater,
li PA issued three RODs for the Site, defining lour operable units and describing selected
remedial alternatives. The first ROD, issued in September 1^80, specified groundwater
extraction and treatment via an on-site treatment plant (Ol -1) and soil excavation and treatment
via an on-site incinerator (OU-2). The second ROD, issued in September 1^X9. addressed
contamination in the Coehato River sediments (OU-3). FPA issued the final ROD in 1*W0. which
called for reopening the Donna Road well field to replace the lost supply resulting from
contamination of the South Street well Held (OU-4).
The construction of the GWTF (Ol I-1) was completed in 1W, Treatment of contaminated
groundwater is ongoing. Treated water is recharged to the groundsvalei through four infiltration
basins. The .source control remedy to remo\ e and treat contaminated soils I OU-2) was
completed in July 1W7, The removal and treatment of contaminated sediments from the
Coehato Ri\er (OU-3) was completed in June 1W5,
ES-1
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Ill 20(H), HPA provided funding to assist the towns of llolbrook and Randolph in expanding the
existing water supply capacity at the Upper Reservoir Great Pond. Two Explanations of
SigniIleum Differences (1 SI)) were issued in August, 21)03. An 1 SI) in connection with OU-l
described rhe expansion of water capacity in the Upper Reserve) ir/Greut Pond. A second ESD in
eonneeiton with OU-4 determined that the reactivation of the Donna Road well field was no
longer necessary due to the expanded water capacity in the Upper Reservoir Great Pond.
Until June 2004, HP A was responsible tor GWTP operation and maintenance; groundwater,
surface water, sediment, fish and wetland monitoring; and evaluation of long term protects eness
of the remedies and the need for institutional controls (It's), In June 2004, the Massachusetts
Department of Environmental Protection (MassDEP) assumed responsibility for the Site. In
2005, EPA issued an HSD to incorporate comprehensive institutional controls into the OUI and
OL«2 remedies.
This is the fourth five-year review for the Site. The first five-year review was completed in
September 1«J99 and subsequent re\ iews were completed every ll\e years following. The
triggering action for this statutory review is the completion date of the previous EYR. which was
September 2tMR The five-)ear review is required due to the tact that hazardous substances,
pollutants, or contaminants remain at the Site above levels that allow for unlimited use and
unrestricted exposure.
This five-year review concluded that the remedy is functioning as designed and continues to be
protectee of human health and the environment. I lowever. for the remedy to remain protective
in the long term, comprehensive institutional controls must be implemented. In addition, interim
cleanup levels and recommendations which ensure die remedy is functioning as intended will
also be evaluated. Continued monitoring of groundwater, sediment, and fish tissue is also
needed to evaluate remedy progress.
ES-2
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i
ES-3
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Five-Year Review Suninian Form (continued i
01 !4
[ IvMus.imi Ut>-..ninu-ml.nnmK idiniii'i..d >n il„ ( i\^i,n Knim.
Ol (s): OLll,
OU2, QUS
Issue 1 .atcyon; Institutional (. out rub
Issue: Institutional controls restricting land uses that may unpad the
protectiveness of the remedy (including preventing the use of groundwater
and preventing excavation into areas of the Site with residual soil and or
shallow groundwater) need to be established. The implementation of
comprehensive institutional controls is on-going, and when complete, will
provide long-term protectiveness for soil and groundwater remedies.
Recommendation: (PA. MassDEP, and the property owners should
complete development of the ICs and record them b> the next five-year
review.
Affect Current
ProfeetivcHess
Affect Future
Protectiveness
fart)
Responsible
<)\ ersi^lit
Parly
Milestone Date
Yes
UP A/State
1 PA
K/3 0/2019
Issues ami Recommendations Identified in llu- I i\i \ ear Re\ ion:
Ol'(s): OUf
Issue Category: Cleanup Levels
Issue; The 1986 OU1 ROD states that "after fi\e (5) years of operation,
the Agency will determine in a supplemental decision document if the
restoration target levels are achievable and if they are adequate to protect
public health and environment."
Recommendation: Determine whether current interim groundwater
cleanup levels are appropriate, and document changes as neeessar\.
\ fleet ( unent
Protect i\ eness
\ fleet Future
I'roU-ctm-m-ss
Party Oversight
Responsible Party
Milestone Date
No
Yes
liPA/State | IP A
12/51 2015
FS-4
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Kmivs atul Recommendations Identified in the I iu -Yeur Review:
Ol'(s): 01 7
Issue ( ate»oi> : Operations ami Mai ill en ante
Issue: Arsenic, benzene, othylbenzene, lindane, heimHa)pyrene, bis(2-
ethvlhe\yl)phthalate. mercury. and pentachlorophonol in select monitoring
wells continue 10 exceed VK Ls
Recommendation: Evaluate recommendations from the 2013
Optimization Report and implement investigations, as appropriate, In the
interim, operation and maintenance of the extraction wells and GWTF
should continue to contain the plume, and investigations should eontinue to
determine what improvements, if any. need to be made. Following
completion of the itnestigations, a meeting between 1 PA and MassDFP is
recommended to discuss the results of*the itnestigations. li s. as noted in a
previous recommendation, should also be implemented to ensure that no
private wells are installed at or near the site.
A fleet Current
Protects cucss
Affect Future
Proteetiveness
Part)
Responsible
Oversight
Party
Milestone Date
No
Yes
EPA. State
EPA
9/*2«>.*2019
Issues ami Recommendations identified in the J iu-\ ear Review:
O!
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Issue*. ;tmi Recommendations Identified in the I i\c-\ ear Review:
<)l (s): 01'3
issiH- < ate«i)r>. Monitoring
Issue: Elevated concentrations of PAHs and pesticides in samples from lee
Pond and Mary Lee Wetlands indicate some uncertainty in the distribution
of these contaminants along the banks of the river and wetlands
downstream of the site.
Recommendation: In order to confirm the protectiveness of the remedy,
the soils and sediment downstream of the site should be further sampled
and evaluated prior to the next Fixe Year Review,
Affect ( ut rent
Proteemeness
Affect Filliire
Protectiv entss
Parfv
Responsible
Oversight
Parts
Milestone Hate
No
Yes
State
1 I'A
12'31/2018
Proteetiveness Statement* si
Operable L nit. J'rofectiveness Determination; Addendum Due Lkae
Ol'l Short-term Protective (if applicable i.
Pmteetiwness Statement;
The remedy at OU~ I currently protects human health and the emirorimenl because the current
pathway for human health exposures has been eliminated as the contaminated aquifer is no
longer being used as a drinking water source. The aquifer in being remediated to mitigate a
future human health exposure pathway. However, in order for the remedy to be protective in
the long-term, groundwater should not be used for any purpose or directly contacted, due lo its
contamination and to the negative impact pumping could have on the effectiveness of the
extraction and treatment system, Comprehensive institutional controls at the site, including
OU1, must be implemented to ensure long-term protect!veness in and around the site.
ES-6
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ProUTtivrness StahiiHiiM st
Operatic I nit; Proteetiveness Determination; Addendum Din; Date
()l 2 Shon-term Protective (if applicable)-
Proteetiveness Statement:
The remedy at OU2 currently protects human health and the environment. As long as the Site
is not used for residential purposes or other purposes where children are present at u high
frequency (e.g., day care or parks), human health proteetiveness will be within the risk-based
concentrations established by FPA. Proteetiveness is achieved for future workers in a
commercial or industrial use scenario. However, in order for the remedy to be protective in the
long-term, comprehensive institutional controls should be implemented or an evaluation
should be performed to determine the potential risk to workers prior to initiating intrusive
activities as part of site re-development.
Proteitixcnew StatcininHM
Operable I 'nit; Proiecttvenes.s Determinatnm; Addendum Due Dale
OU3 Short-term Protective (if applicable)
Proiectiveness Statement.
The remedy at Of 3 is currently protective of human health and the environment because
sediment with high le\ els of contaminants was excavated and treated, and clean fill was used
to replace materials excavated. However, to minimize disruption to wetlands, sediments were
not removed from areas of the river where contaminant concentrations were low. Although
contaminated sediments remain, it is expected that natural degradative, deposkionul. ami
dispersal processes will gradually reduce remaining concentrations in the sediment In order
for the remedy to be protective in the long-term, it is recommended that long-term sediment
and fish tissue monitoring continue to evaluate contaminant levels/risks and contaminant
behavior over time, and maintain the current fish advisory signage.
>ite«ide Proteetiveness Statement
Proteetiveness Deienntnatian. Addendum Due Date (it
Short-term Protective applicable);
Proteetiveness Statement;
The remedies for the Site currently protect human health and the environment because current
exposure pathways that could result in unacceptable risks are being controlled. All threats at
the Site have been or are being addressed through groundwater treatment; removal,
incineration, and stabilization ofeontaminated soil and ash; site fencing; warning signage, and
expansion of an alternate water supply.
I iowever, in order for the reined)' to be protective in the long-term, comprehensive
institutional controls must be implemented to maintain a complete level of proteetiveness for
FS-7
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future activities in and around the site. Interim cleanup levels and recommendations whieh
ensure the remedy is functioning as intended will also he evaluated. Continued monitoring of
groundwater, sediment, and fish tissue is also needed to evaluate reined}'progress.
ES-8
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I, inik<»H(. iio\
The purpose of4 Five-Year Review (FYR) is to evaluate the implementation and performance of
a remedy in order to determine if the remedy will continue to be protective of human health and
the environment. The methods, findings, and conclusions of re\ iews are doeumented in live-year
review reports. In addition, FYR reports identify issues found during ihe review, if any, and
document recommendations to address them.
The U.S. Env ironmental Protection Agency (F PA) prepares FYRs pursuant to the
Comprehensive Environmental Response, Compensation, and Liability Act (CF.RCEA i Section
121 and the National Contingency Plan (NCR). CPRCLA 121 states:
"//the President selects a remedial action thai results in any hazardous substances,
pollutants, or contaminants remaining itt the site, the President shall review Mich
remedial action no less often than each Jive years after (he initiation
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the South Street well field. Figures show ing site features are presented in Appendix B,
11, PROC.Ri SS SIM I nil I AS J RI\ H \N
F h is is the fourth five year review for the Site. This see lion presents the proteetiveriess
statement, recommendations and follow-up actions identified in the third five year review,
followed by a summary of efforts since 20fW to address the recommendations. In addition, this
section includes a summary of other site activities and studies that have been conducted since
2009,
l ahle I: Protectivcncss Determinations Statements from tin -*t09 I \ K
ou#
ProtiTtiveness
Determination
Protectheruss Statement
I
Short-term Protective
The remedy at OU1 currently protects human health
and the environment because the current pathway for
human health exposures has been eliminated as the
contaminated aquifer is no longer being used as a
drinking water source. The aquifer is being
remediated to mitigate a future human health
exposure pathway, and data indicates that the plume
of organic contamination is shrinking. However, in
order for the remedy to be protective in the long-term,
the groundwater treatment plant, recharge basins,
monitoring wells, extraction wells, I.NAPI recovery
system, and piping network must remain operable and
undisturbed. Groundwater should not be used for any
purpose or directly contacted, due to its
contamination and to the negative impact pumping
could have on the effectiveness of the extraction and
treatment system. It is important to complete the
implementation of comprehensive institutional
controls at the site to ensure long-term protecttveness
in and around the site.
2
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m a
I'rotmivtiicss
Determination
Short-term Protective
Short-term Protective
Pi olccti\eness Statement
The remedy at OU2 currently protects human health
and the environment. As long as I he site is not used
for residential purples or other purposes where
children are present at a high frequency (e.g., day
care or parks), human health protect iveness will be
within the risk-based concentrations established by
FPA, Protect iveness is achieved for future worker
in a commercial or industrial use scenario,
Contaminants present at depths greater than 15 feet
he km grade are considered unlikely to he eontaeted
directly by individuals during future site development
acti\ities. including construction and utility work.
Ho\ve\er, in order for the remedy to he protective in
the long-term, completion ofeomprehenshe
institutional controls is needed.
The remedy at OU3 currently protects human health
and the en\ ironment because sediment with high
le\ets ofeonlaminants was excavated and treated, and
clean fill was used So replace materials excavated.
However, to minimize disruption to wetlands,
sediments were not removed from areas of the river
where contaminant concentrations were low.
Although contaminated sediments remain, it is
expected that natural degradative, depositional, and
dispersal processes will gradually reduce remaining
concentrations in the sediment. In order for the
remedy to be protective in the long-term, it i.s
recommended that long-term sediment and fish tissue
monitoring continue to evaluate contaminant levels
and their behavior over lime. However, the State
currently has no monitoring plan in place.
3
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or #
Sitew«Je
ProtvcmenesN
IKunnination
Short-term Protective
IVottdiuness Statement
Because all remedial actions at all (H n arc
protective. ihe site is protective ot"human health and
the environment. The remedy currently protects
hitman health and the environment because current
exposure pathways are being controlled. All threats
at the Site have been or are being addressed through
groundwater treatment; removal, incineration, and
stabilization of contaminated soil and ash; site
fencing: warning signage; and expansion of an
alternate water supply. However, for Ihe Site to be
protective in the long-term, it is important, to
complete the implementation ofeomprehensive
institutional controls at the site to maintain a
complete level of protect iveness for future activities
in and around the site, and through continued
monitoring of groundwater, sediment, and fish tissue.
It is essential that monitoring of these media continue
in order to ensure that long-term cleanup goals are
being met
4
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I iibic 2: Slatns of WaonummUHions from tin 2t
#
ItMlf
Reeommendat
ions/
I nlltm -up
Actions
Pum
Hesjj'i
nsiltlc
Oversight
Parly
Original
Milctotu
Date
( !U rent
Status
< timplctioM
Dale (if
applicable}
I
I
(iruundwater
Continue
State
KPA State
1 1 2014
Ongoing
at the she
operations of
contains
GWTl"; re-
contaminants
establish \tN A
abo\ e action
monitoring
limits
ptouniirt.
__
1
(iroundwater
at the site
contains
contaminants
abo\ c action
limits
Res isit
evaluation of
arsenic
presence and
mobility to
det en nine if
conclusions are
Mill \altd and
dc\ elop a plan
of action lo
address high
concentrations.
State
I:PA State
1 I 2014
Under
Discussion
y'l2M.2tHM
3
1
(iroundwaicr
at the %!tc
contains
contaminants
ubo\ e action
limits
()ptiini/e
extraction
s\stem
elTiciencv.
Slate
TP A State
1 1.2(114
Ongoing
tVl'PlltV)
4
1
Groundwater
at the site
contains
contaminants
above action
limits
Collect samples
for MX A
pautmetei's
from select
monitoring
welts.
State
EPA State
1,1 2014
Considered
Rut Not
Implement
ed
5
1
Groundwater
at the site
contains
contaminants
abo\ e action
limits
l-,\nluate the
INAPt.
collection
sWcm to
improve
LNAPL
remo\al. separa
tion.
State
1'PA Sta'e
1 I 2014
Considered
Rut Not
Implement
cd
5
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-
Rci-om
metulal
ion No.
Ot
#
Issue
kecommendat
tuns;
f-(dim*-up
Uiiims
I'ai t\
Kcspo
ONtbk*
Oversight
Party
Original
Mik-stonr
Datv
< urrrnt
Status
< nmplt'timi
Date tit"
applicable)
f.
y
f)tll ilig till' last
th e-year
review,
sediment
along flic river
contained
PAHs above
action limits
and
concentrations
of met a In and
pesticides had
not decreased
sigmfieatitk
since the
prc\ imis five-
year review.
Conduct
sediment
monitoring;
continue
operations ot"
the G\V I'l-;
maintain site
fencing.
State
fTA State
I.I _CH4
Addressed
in Next
l"YR
y;
r"i
r<*.
7
3
During the last
fi\c-yeui
review. fish
tissue
contained
PAS Is at
concent rations
ubo\ e action
limits.
Conduct fish
tissue
monitoring;
maintain
warning signs.
Stole
EPA State
1 I 2
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Recommendation 1
Operation of the CiWTF has continued, including implementation of a number of modi Heat ions
to optimi/e remedy performance; however, a monitored natural attenuation (MNA) program has
not yet been established.
Reeiimtiiejidaibji.2
Arsenic investigations were conducted by the MassDl-P in multiple phases, all of which are
summarized in Arsenic Summary Investigation Report - Pan ll ila (CHI S, 2014a). Discussion
of the findings is included in Section III.
Recommendation 3
In early 2014, MassDLP installed one new extraction well {I \\ -10) and two new monitoring
wells (MW14-01 and \1\V 14-02). conducted a pump test, and integrated FAV-10 into the
groundwater treatment system.
Recommendation 5
The MassDEP has evaluated IN AIM. characteristics and distribution throughout the Site.
LNAPL monitoring and recovery is taking place in select monitoring and extraction wells, and
LNAPL has been removed and disposed of oil-site when sufficient volume is detected.
Recommendation c)
Kit action was taken on this recommendation; however, control of one invasive plant species,
purple loosestrife, has been fairly successful, apparently through introduction of the Cialerucella
beetle, while several areas of the wetland are still dominated by another invasive species,
phragmites. Although control of the phragmites would enhance the wetland, overall it is in good
condition, and therefore no further action is recommended.
Since the last five year review, the following investigations have been conducted:
• Fish and Sediment Sampling (KSM, 2014)
• An arsenic investigation {( IK S, 2014a)
• Arsenic speciation analyses (data in Appendix d)
• An optimization review {USEFA. 2013)
lit addition, the following investigations or studies were initiated during this live year review
period:
• A trend analysis to evaluate data trends in groundwater, fish, and sediment data;
• A hydraulic capture analysis to assess plume containment;
7
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• An evaluation of the adequacy of the interim groundwater cleanup levels: and
• An evaluation of the need for additional I N API investigations, as necessary to assess
future protectiveness of the remedy.
The investigations and the optimization review are discussed further in this section and in
Section III,
Rimed) Implementation Aelis itics since last I he Year Ut \ ie«
1. i * .A issued three KODs for the Site, defining lour operable units and describing selected
remedial alternatives, Ihe tirst ROD, issued in September 19X6, specified groundwater
extraction and treatment via an on-site treatment plant (01;-1) and soil excavation and treatment
via an on-site incinerator (OU-2). The second ROD, issued in September 1989, addressed
contamination in the Coehato River sediments (OU-3). I PA issued the final ROD in ICW0, which
called for reopening the Donna Road well Held to replace the lost supply resulting from
contamination of the South Street well field (OlJ-4).
The construction of the GWTF <01 !-i) was completed in 1W1. Treatment of contaminated
groundwater is ongoing. Treated water recharges to the groundwater through four infiltration
basins. The source control remedy to remove and treat contaminated soils (OU-2) was
completed in July 1997. The removal and treatment of contaminated sediments from the
Coehato River (OU-3) was completed in June ll)95.
In 20(H), EPA provided funding to assist the towns of Holbrook and Randolph in expanding the
existing water supply capacity at the Upper Reservoir Cireat Pond. Two Explanations of
Significant Differences (1 SD) were issued in August, 2003, An ESP in connection with OU-1
described the expansion of water capacity in the Upper Rcservoir/Cireat Pond. A second USD in
connection with 01.1-4 determined that the reactivation of the Donna Road well field was no
longer necessary due to the expanded water capacity in the Upper Reservoir,'Great Pond.
Until June 2004. BP A was responsible for GWTE operation and maintenance; groundwater,
surface water, sediment, fish and wetland monitoring; and evaluation of long term protectiveness
of the remedies and the need for institutional controls ( ICs). In June 2004. the Massachusetts
Department of Environmental Protection (Massl)EP) assumed responsibility for (he Site. In
2005. EPA issued an ESI) to incorporate comprehensive institutional controls into the OUI and
OU2 remedies.
With the exception of Institutional Controls (ICs), detailed information regarding the
implementation of the OUI, Of 2. and OU3 remedies is discussed in Appendix A Existing Site
Information.
Institutional Controls
Implementation of Institutional Controls in Massachusetts, namely the recording of Grants of
Em iron mental Restrictions and Easements (GEREs). has been a continued challenge for the
8
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program. The need to complete It's has often been identified as an issue potentially impacting
future protect iveness as part of Five Year Re\ iews at this and other Massachusetts sites. In an
effort to address this issue and improve the process of completing It's at Massachusetts NPL
sites. KPA worked with the MassDHP to develop a new approach using Notices of Activity and
Use Limitations (AUL Notices), This process involved first working with MassDHP to update
and amend their regulations governing AUI.s (both Notices and GERFs) embodied in the
Massachusetts Contingency Plan (310 ('MR 40.0(1001. The MCP amendments published in May
2014 included new requirements allowing for use of AUt. Notices at NPL sites, I PA and
MassDf- P are currently work my on model documents and forms that will he used to implement
AUL Notices, Once fully implemented, the o\erall process for It' implementation will be
streamlined as AUL Notices do not require the signature of the MassDHP Commissioner nor do
they require Subordination Agreements from those holding prior encumbrances on properties.
Roth of these requirements served to slow the GERF. implementation process at many sites.
EPA and MussDLT will work together to determine whether specific circumstances at sites still
require GLRLs or whether the new AUL Notices can lie used instead. This new approach to It s
in Massachusetts should allow LP A to complete these activities more quickly and efficiently and
address these Five Year Review recommendations within a reasonable timeframe.
LPA and the MassDLP are in the process of developing (Cs for the Baird & MeC iuire Site. Table
3 presents a tentative list of institutional controls at the Baird & MeGuirc Site. The location of
each of the impacted parcels is shown on Figure 2 in Appendix B. In general, issues to be
addressed by the It s include preventing land uses that could interfere with the remedy;
preventing exposure to contaminated media; and securing access for EPA, MassDLP. and their
contractors in order to maintain and evaluate the remedy in the future.
table 3: Sunimarx «f Planned and ot Implemented l( s
Media,
enumeered
controls. ;t»d
areas that do not
support t r i r
basi c! on
l< s
Needed
K s ( ailed
lor hi the
Decision
Documents
i mpaeted
Parcels)
IC
Objective
Title of' l< Instrnnu iit
Implemented and Date
(or planned)
current
conditions
Provide access for
LPA and/or
MassDFP and iheir
(jW'TF.
extraction wells,
piping,
monitoring wells
Yes
Yes
Parcels
25-130-00-0,
25-130-01 -0,
25-130-024),
representatives on
all pa reels where
restrictions will be
placed until F.PA
It needed
PJ-012-00-0
and MassDLP
determine that
controls are no
lonucr neeessarv,
ta
9
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r Media. 7
engineered
controls. and
area* that do not K s
|
support 1 1 I l\ Needed
based on
current
conditions !
t( st alled ;
for in the Impacted
Decision Pareel(s)
Documents
ic:
Objeethe
I |
groundwater,
sediments)
|
i
i
1
| Parcels
25,130.0041
25-130-01-0.
| 25-130-02-0.
25-I2V-00-0,
25-12lM)2-0.
\ i\ 1
j 25-1 31-00 -d.
1^-003-00-0.
H-012-00-0.
j N-012-02-0
| 14-012-03-0
1
I
1
Prevent land uses
lhat would cause
reconiamimition of
clean soil, interfere
with the operation
and maintenance of
the remedy, or
which nm result in
unacceptable
exposures (e.g..
prohibition on
residential
development on
.some parcels).
Prevent the
extraction,
consumption, or
utili/ation of
ground water or the
migration of
contaminated
groundwater (with
the exception of
groundwater
monitoring and
collection of soil
samples and
sediment samples).
Pre\ ent land uses
that ma\ res jit in
unacceptable
exposures to
contaminated
sediment
Notice of AUL planned
Sediments J Yes
I
j 19-012-01-0,
j l'M)06-00-0
Yes I 14-102-00-0.
i
Notice of ALU. planned
10
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In addition to the tentative institutional controls identified above, fish advisory signs in multiple
languages hav e been installed on the banks of the Coehato River and in downstream Sylvan Lake
warning residents of the risks associated with eating the fish. The beat ions of the signs are
shown on Figure 6 in Appendix R,
Groundwater lH :itim nt Msti'in Operation Operation and Mainli nami- \cti\ ilit s
The majority of O&M activities at the site are related to the operations of the GWTF (OU-l).
for OU-l, O&M uctiv itics include the operation and maintenance of the GWTF, including the
groundwater extraction wells. LNAPL monitoring and eolleetion, and monitoring well sampling
and analyses. C urrently, the GWTF is staffed by two operators, ti\e days per week for 10 hours
per day, plus 4 hours on Saturdays end Sundays to provide routine operation, inspection, and
monitoring of the extraction and treatment systems. An operator is also on-eall during off-hours
lo address facility alarms or emergencies. One mechanic is on staff four days per week to handle
mechanical maintenance and repairs. Periodic monitoring activities include sample eolleetion
from plant monitoring points, monitoring wells, and extraction wells.
More specifically, operating the GWTF includes the addition of treatment chemicals such as
polymer and potassium permanganate used for groundwater treatment, change out of filter media
such as actuated carbon and filter sand, collecting samples from the process for laboratory
analyses, disposal of residuals (sludge), and the periodic collection and disposal of I.N \PL.
The FN API recovery system that was operated historically became inactive in March 20(19 due
lo diminishing recovery of LNAPL. LNAPL has continued to be detected in some wells;
however, the spec i lie gravity of the LNAPL appears to be close to water making LNAPL
recover) unsuccessful. LNAPL. continues to be monitored on a monthly basis at extraction and
monitoring wells. The system was not in operation during the beginning of 2010, then was only
intermittently turned on when measurable amounts of LNAPL were detected in the wells.
Overall, during 2010, only minimal amounts (less than G cup of oil) of recoverable LNAPL were
generated for disposal during the reporting period (('HI S. 2012). During 2011, 2012, and 2013
LNAPL was intermittently removed from fiW-6, an extraction well not associated with the
LNAPL recovery system fCflRS. 2013a).
Other disposal activities include the disposal of sludge from the metals removal process. The
sludge is transported off-site in roll-off containers for off-site disposal by Glean Harbors.
Typical routine maintenance items include gear lubrication, seal replacement, and pipe cleaning.
Due to the age of the facility, a good amount of non-routine maintenance involving repairing or
replacing worn-out or outdated equipment is also required. Other ()&M activities include
maintaining site security, such as fence repair, and general site maintenance such as mowing and
snow removal as needed. Problems associated with the O&M of the site include typical
mechanical and process issues that are addressed as needed. Repairs to and replacement of the
equipment continues to be a problem, particularly since it is difficult to find replacement and
spare parts tor some of the equipment due to its age. The O&M of the site is documented in daily
11
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and weekly quality control reports, which are compiled and included in an annual O&M report
and in monthly progress summary reports, which arc included as an Appendix of the annual
Evaluation of Groundwater Remediation Progress Annual Report - OU1 (CI ll:S 2010. 2012,
2013a, and 2013d). The daily and weekly reports include a summary of GWTF status, flow rates
and gallons treated and discharged, a description of maintenance and inspections performed,
identification of issues and corrective actions, and identification of monitoring performed. The
annual O&M reports include information on overall fact lit)'performance, plant influent and
effluent analytical results, and figures depicting contaminant trends for GWTI influent and
effluent data, and plant upgrades and modifications. Elements of the monthly report include a
summary of overall facility performance, monitoring information for the extraction wells,
treatment process information, problems i den idled and corrective actions taken, and a summary
of analytical data tor the process, including contaminant removal efficiency.
Contaminant removal rates for VGCs. SYOCs, metals, and pesticides have continued to exceed
99% removal GWTF eftluent concentrations meet ot exceed the discharge criteria for these
compounds.
A summary of GWTF O&M costs since the previous five year re\ iew is presented in Table 4.
I able 4: Sumuiar) of O&M Gusts
1 Tot
al Cost (to the nearest SltMH))
FY 2010
$901,000
21111
$820,000
2012
$949,000
2013
S815,000
1 2014 (est)
$730,000
Generally, O&M costs have decreased since the last live year review due to optimization and
cost saving measures described in Section IV.
Optimization kc\ ien anil Other ln\estimations
In addition to the progress made on the recommendations from the prior five year review, the
EPA and the MassDFP conducted a number of investigations and evaluations to assess progress
and to identify potential optimization actions that could benefit the remedial action.
The I-PA conducted an optimization review in 2012/2013 to identify specific actions that may be
taken to potentially improve the effectiveness and cost-efficiency of the remedy. The review
focused on remedy performance, protectivenes.s, cost-effectiveness. technical improvement, and
site closure strategy. The recommendations of the optimization review are documented in
Optimization Review for the Baird & McGuire Stiperfund Site, which was finali/ed in May 2013
(USFPA, 2013).
12
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Since l be review was completed, the VfassDHP has implemented some affile recommendations
of the Optimization Review and has evaluated and attempted others.
Optimization recommendations were divided into three categories: I) recommendations for
refining the conceptual site model; 2) recommendations to be considered if the focus moving
forward includes continued operation of the GWTF; and 3) recommendations to be considered if
the focus moving forward will he on additional source remediation. The following is a summary
of the recommendations of the optimization review and actions taken to date to address the
recommendations.
Recommendations and Actions Taken to Refine Conceptual Site Model
Recommendations for refining the conceptual model included: resuming fish sampling and
clarifying fish tissue criteria; sampling the Cochato River sediments; conducting a speciation
analysis for arsenic in select monitoring welts; adding TFii and 1 (X" analyses to routine
groundwater monitoring; performing leaching tests on site soils to better understand if ash is a
continuing source of arsenic; and recording and reporting ORP results with groundwater
monitoring data. Each of the recommendations and actions taken arc discussed below.
• Conduct fish tissue and Cochato Rivet sediment sampling. Fish tissue and sediment
sampling were conducted in October 21113. Results are discussed in Section 111 of this
report, and are presented in detail in the Cochato River Sampling Report (ESD. 2013).
• Add 1'FII and I OC analyses to routine groundwater monitoring and report ORP with
monitoring data. The optimization team recommended adding TIM 1 and 1 (X , and
reporting ORP data, in order to assess whether low ORP might be contributing to the
mobility of arsenic in situ groundwater. The team speculated that the lower ORP
contributes to mobilization of arsenic from native soils and or soil remedy ash, potentially
resulting in an additional ongoing source of arsenic. To the extent these speculations are
correct, as long as sufficient dissolved organic carbon is present in groundwater,
widespread continuing sources of arsenic will persist. The MassDFP added these
analyses and began reporting the ORP data in their 2012 and 2013 groundwater
monitoring events. TPH and TOC were included since VOCs and SVOCs make up only a
part of the organic compounds that contribute to low ORP (see additional discussion in
Section 111)
• Conduct speciation analyses and perform leaching tests for arsenic. The speciation
analysis was recommended to determine which species of arsenic exist in the
groundwater, and whether arsenic is in organic or inorganic form in the soil, to better
evaluate mobility and so that the impact of ORP can be better assessed, Leaching tests
were recommended to assess whether leaching of arsenic from site soils'ash is
contributing to the arsenic in the groundwater (e.g., whether there ts a continuing source
13
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of arsenic tram the ash). An arsenic investigation was conducted by tVlassDHP in
2013 2014 which addressed these recommendations (CI US 2014a). As part of the
arsenic investigation conducted by the MassDLP, leaching tests, using the Toxicity
Characteristic Leaching Procedure (TCLP) were performed on 7 of 66 samples collected
for arsenic analysis. Results were all below detectable levels. An additional locus of the
arsenic investigation was to better define the arsenic plume location.
Kccnnmnndations and \ctious hi ken for( muiimcd < .W II Operation
Adit New F.xtraetion Wells
Recommendations in the Optimization Review Report included replacing EW-1) and EW-7, plus
adding one or more new wells between those wells, further recommendations made iri the
Arsenic Investigation Report included the installation of one or two new extraction wells
positioned to capture the arsenic plumes prior to reaching the Cochato River, installation of two
new monitoring wells within the arsenic plume for future monitoring, and additional
investigations for further plume delineation (CHi S. 2014a). Installation of one new extraction
well ( l-.W - ID) and two new monitoring wells IVIW 14-01 and MW 14-02), pump testing, and
integral ion of FAV-10 into the groundwater treatment system occurred in February and March
2014 (CI I IS 20l4d)
In addition, the FPA initiated a hydraulic capture analysis to determine whether the extraction
system is containing the plume, or whether additional data are needed. Results of the analysis
indicate adequate plume capture. A letter report will be prepared prior to the next five year
review documenting the results of the hydraulic capture analysis.
Install a New Treatment System for Long-Term Operation
Recommendations in this category included actions or modifications to reduce costs of the
existing system. Included were recommendations tor reducing treatment plant reporting
requirements; recommendations for optimizing the metals removal system: and a
recommendation lor discontinuing aeration in the activated sludge units.
• Re'ducjmj. (i\Y7T Rcj>orfjjie .Requirements. The optimization team recommended
eliminating the daily and weekly reports prepared by the O&M Contractor. This
recommendation was considered, but not implemented, since the (AV'fT staff collects
and compiles the information as part of routine O&M, regardless of reporting
requirements, so no cost savings would be realized.
• Optimizing metals removal system. Recommendations included replacing the existing
system with a new treatment system to streamline operations, if the CiWTF is anticipated
to continue operation for more than five years. If the existing facility is going to operate
for less than live >cars, the optimization team recommended making modifications to the
14
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chemical feed system, including changing ihe oxidant used lor arsenic removal from
potassium permanganate to hydrogen peroxide, changing the ORP set-point, and
improving the clarification stop. Several of the ^hort-term recommendations were
attempted or considered by the MassDEP Reducing the ORP set-point was attempted
but resulted in decreased effluent quality (loss of clarity). Reconfiguration of the
clarifiers was considered, bin could not he accomplished due to space limitations within
the tiWTF.
• S)iscon t imiej\cyanon. A recommendation was made to discontinue aeration in the
activated sludge units, which are currently used as air strippers. It was speculated by the
optimization team that the units provide little benefit to overall water treatment, and that
the aeration is likely contributing to biofouling of the granular activated carbon (GAC)
units, MassDEP attempted this modification; however, it was found that eliminating
aeration had the opposite effect, and resulted in clogging of downstream filters (CiAC and
sand filters). Consequently, the aeration units were put back in operation.
In addition to recommendations identified in the optimization review report, the MassDEP has
made additional optimization efforts and implemented cost-saving measures. Various upgrades
and safety measures have been implemented, including the replacement of high pressure sodium
lighting with energy efficient LID lamps; the addition of new variable frequency drives on the
aeration tank blowers; replacement of the potassium permanganate lank; replacement of the
CIAC media with a longer-lasting coarser grade of carbon, and installation of new tank railings
and restraints. It was reported that these measures resulted in significant cost savings.
Recommendations and Actions l akes! to Determine it Primm \ 1 nciis Will ik Source
( ontrol or ( ontainment
This recommendation and actions that will need to be taken to determine whether source
remediation should be the tbeus going forward are under evaluation.
In support of this evaluation. EPA has initiated an assessment of the interim groundwater
cleanup levels and an evaluation of whether additional IN API investigations are needed.
Sediment and I isli I issue Monitoring
In the last five year review, fish tissue and sediment monitoring were recommended, Sediment,
bank soil, and fish tissue samples were collected in October 2013 in support of this five-year
review (ES&M. 2014). Eleven sediment samples and four soil samples were collected from in
and along the Cochato River between October 9 and October II» 2013 (see figure 2 in Appendix
D). Station progression (upstream to downstream) is A, E (next to site), B. C, and D, Bank soil
samples were only collected at stations 0 and D. Samples were analyzed for 1 Ol, grain si/e,
PA!Is, organochlorinc pesticides, and arsenic. More discussion is provided in Section 111.
Analytical results are summarized in Appendix I).
15
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W (.1 hi hi I inspection
In the la>t five year review, it uas recommended that a program be initiated to monitor and
control invasive species in the site wetlands. Wetland inspection and control activities have not
been part of the MassDFP monitoring program over the past five years, However, a site
inspection to assess the condition of the restored wetland area, as well as the restored upland
area, was performed during the five year review process on August 8, 2014. Consistent with
observations from the prior five year res lew in 20(W, restored upland portions of the site
appeared lo be u ell-vegetated and stabilized. Vegetation in these upland areas are similar to thai
observed in 200*). further discussion of the findings is presented in Section III.
16
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III. H\ I A FAR RFVIFW PROCESS
\dministrative ( omponcnIs
The Baird & Melluirc Supcrliind Site Five-Year Review was led by kimherly While of the U.S.
EPA. Remedial Project Manager! RPM) for the Site, and Kelsey O'Neil, the Community
Involvement Coordinator
-------
Dala Ke\ ieu
Itvatmcnt i'liiiil I ftlm-nt Moniloi inn
The effluent from the groundwater treatment plant is analyzed on a weekly basis fur tola! arsenic,
on a monthly basis tor VOCs„ SVOC's. pesticides, copper, iron, barium, chloride, and sulfate, and
on a quarterly basis for total metals and oil and grease. Additional!), daily process control
observations made by plant operators include settleability (lest used to estimate sludge volume),
pi I, OR P. turbidity, and temperature.
Ifxccedanecs of the discharge criteria occurred on certain occasions within the past 5 years as
noted below in Table 5 I note that the most current data is from 2012):
1 abk- 5: Minimal) of (.\V| l: Disc ha rue I UTcdana
Reporting Period
| Exeeedanees
10't'OK - '30/09
[ - pi! exceeded the range of 6.5 to X.5 pi 1 units on 15 days due to carbon
change outs.(N.94
2-methylnaphthalene (23 |tg/IJ exceeded the discharge criteria of 10
j.ig''L on one occasion. Subsequent sampling did not detect 2-
| methylnaphthalene.
1 - Turbidity exceeded the discharge criterion of 1 MTU on 22 days.( 1)
10'HW - ty'30/J0
I - pll exceeded the acceptable range on 13 days due to carbon change
outs (8.69 9,5 7».
Turbidity exceeded the discharge criterion of 1 NTU on 14 days.(2)
10/1 10- 9 30/1 1
I - pll exceeded the acceptable range on 8 days due to carbon change outs
(8.62 - 9,5? h
Turbidity exceeded the discharge criterion of I NTU on 3 davs.( 1)
Iron exceeded the discharge criterion of0.3 mg/1 (SMCI.) on 2 days (35
10/ Ml 9 30/12
| - pi 1 exceeded the acceptable range on 3 days due to carbon change outs.
11) Turbidity cxeeeibnee** were either due to carbon change outs or to unknown causes.
121 Turbkiily evccetkmces due to pohmer pump malfunction and carbon change outs. Pump rnullunetson was
repaired.
13! liitiM.' and corrective net ton not known.
Over the period from October 1, 2008 to September 30. 2012, the final effluent contained no
delectable concentrations of pesticides and two detections of one VOC (naphthalene, which lias
no MCI), SVOCs were detected in the diluent on sporadic occasions over this period and were
generally at low concentrations. Overall. V< >('. SVOC. and pesticide effluent results indicated
greater than 99.99% removal
Arsenic was not detected above the reporting limit m any eftlueo! samples during the period
from October 1. 2008 to September 30, 2012. Iron was detected on several occasions at
concentrations below the SMCI (0.3 ntg l); however, there were two occasions tn July 2011, as
18
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noted above, where iron concentrations (0.4K and 0.5K ing.!) exceeded the SMC I . Lead was
detected on one occasion, copper was detected on 4 occasions, and barium was detected on 4
occasions; all detections were below the respective discharge criteria.
Effluent monitoring data are presented in Evaluation of Groundwater Remediation Progress
Annual Reports (CHES. 2010: CUES, 2012; CUES, 2013a; CUES. 2013d).
Groundwater Monitoring
Summary. Groundwater extraction wells at the site are sampled on a quarterly basis.
Additionally, annual rounds of groundwater sampling were performed over the past 5 years, I he
August 2001) and July 2010 annual monitoring events included 21 monitoring wells, the October
2012 annual monitoring event included 23 monitoring wells, and the September 2013 annual
monitoring event included il> monitoring wells. The July 2011 annual monitoring event was a
more comprehensive "5-year groundwater sampling round" that included 5 extraction wells and
61 monitoring wells located within and beyond the boundary of the contaminant plumes
identified at the site. Groundwater samples over the past five years have been analyzed tor
arsenic (all wells) and VOCs, SVOCs, and pesticides (all wells in 2011; select wells other vearsi.
The 2011 comprehensive monitoring round included a larger number of metals. Additionally,
chemical oxygen demand (COD), total petroleum hydrocarbons (TPli), and total organic carbon
('('(>(') were included in the 2012 and 2013 annual monitoring events at select wells. Arsenic
special ion data were collected in 2013 and 2014.
Annual evaluations of extraction system performance in regard to contaminated groundwater
remediation and containment ha\e been performed and arc included, along with the results of
quarterly and annual groundwater sampling for this fi\ e year period 2tKW to 2013, in Evaluation
of Groundwater Remediation Progress Annual Reports (CUES, 2010; CUES, 2012; CUES,
2013a; I HIS. 2013d). These reports include discussion of extraction well and monitoring well
analytical results, tabular presentation of alt data, a figure depicting the approximate extent of
arsenic contamination, ami an estimate of contaminant mass removal o\er the reporting period,
as well as a discussion of treatment system operation The annual progress report that will
document the September 2013 annual monitoring event has not been completed; however, the
groundwater laboratory analytical data lias been obtained from MiasDEP's contractor and is
included in Appendix D.
In order to depict the magnitude and location of remaining contamination, contour maps {'"plume
maps") for 2011 arsenic, VOC, and SVOC data were developed as part of this five year review.
The 2011 data was utilized since this was the most comprehensive sampling round over the past
five years and could be compared to previous plume maps included m the previous five year
reviews. Copies of the 2011 plume maps are located in Appendix I). >\s expected, the maximum
concentrations in the plumes have reduced over time. The plume extents appear to be similar or
reduced from previous plumes. Additional evaluation will be provided in a trend evaluation
update report which will be prepared in the near future. Preliminary findings of the trend
analysis update are included below.
19
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The following fable shows compounds which were detected in the 2011 comprehensive sampling
round at concentrations above the MCLs. Lxeecdances are presented for this sampling round m
Table 6 since it was the most comprehensive round of sampling in the past 5 years.
I utile 6: Cnnimiw ater \I( 1. I xcenlaiuus in 2(111
( ontaminant
SOW A
MCI.
(m'n
Location
( oiiccutt ation (uli. h in
2UI1
Benzene
5
MW04-0I,
MW97-28, and MW9X-1
5.77/5.67 (FD| - 10.6
Lthylben/enc
700
MW04-0! and
MWy7-2S
761 - 77L82X(FD)
Lindane (gamma-
BHCT
0.2
N1WQ7-I
0.84! 0.934 (1 D)
Bcn/o(a)p\rene
0.2
M7-SD and
M7-BR
0.271 -0.483
Bis< 2-
ethyliiexyl )phthalate
6
7 monitoring wells
6.35 70
Pentaehloropheno!
1
10 monitoring wells and
one extraction well
3.13 - 14.0:15.6 (FD)
Mercur\
1-7 and
MW97-32
Arsenic
10
25 monitoring wells and
all extraction wells
11.6 1,670
PI) - Field duplicate result
In the most recent 2013 annual sampling round, MCLs were exceeded for Lindane (ganima-
BI1C) (well M\V'>7-23: 0.203 ppb). bis(2~cthylhcxyl»phthalate (well MVW7-25; 21.X/20.0 [F I)|
ppb). and for arsenic in a total of 17 monitoring wells at concentrations ranging from 41 ppb to
U^O/1,340 (H.>) ppb.
VO< s and SVO( s. Total VOC and SVOC concentrations over time for site groundwater are
provided in a table in Appendix t) It should be noted that several site wells were replaced after
being destroyed by source control remediation. The original well name and the replacement well
name are listed in the table for clarity. The 2004 trend evaluation report concluded that
significant decreasing trends in VOC and SVOC concentrations exist for the majority of
overburden and bedrock wells monitored at the Site, The data collected since the previous live-
Year Review report and preliminary results of the trend analysis update for the monitoring wells
generally support this conclusion for VOC s; however, insufficient monitoring well data is
20
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available Id do an extensive trend update for VOCs. Far SVOCs, a downward trend was noted in
MW-97-32 and BM-2, while no trend was observed in BM-34A. BM-34, M-QT/WB, MW-^7-
29, and MW-97-31; and an upward trend was noted in well BM-3N. More discussion of these
observations will he provided in the 2014 Trend Analysis Report. VOC and SVOC
concentrations in monitoring wells on the east side of the C'oehato River have primarily been
non-deteet or very low, indicating that eontinued migration of the plume beneath and beyond the
river is not occurring. Plume maps depleting SVOC and VOC contamination based on the 2011
data are meluded in Appendix D. As shown in the table above, benzene, cthylben/enc.
ben/o(a)pyrene, his(2-ethylhexyhphihalate, and pentaehlorophenol (P( P} were detected above
enrrent VICl.s in overburden groundwater in 2011. Ben/om)pyrene. PCI5, and or bis(2-
ethylhexyl)phthalate were also detected above current MCl.s in three nedroek welts in 201 I.
Cine of the three bedrock wells, VI10-BR. is located on the east side of the C'oehato River and
contained PCP (3.13 pg 1) over the enrreru MCI. (1 pg/1). However, PC'P was not detected in
well M 10-BR the following year in 2012. VOCs and SVOC s deteeted at the highest
eoneentrations in site groundwater typically ineluded xylenes, naphthalene. 2-
methylnapluhalene, and ethylben/ene over the past several years.
Arsenic, Arsenie has generally been deteeted in the majority of overburden wells within the
plume and surrounding areas. A plume map depleting arsenie eontamination based on the 201 I
data is included in Appendix D, Within the plume area, overburden wells have not exhibited
eonsistent increasing or decreasing trends. This observation is supported by the initial results of
the trend analysis update. More discussion of the arsenie groundwater trends si nee 2004 will be
provided in the 2014 Trend Analysis Report. Historieal arsenie eoneentrations are provided in
Appendix 1). As shown in the table above, arsenie was detected above the current MCI (10
ftg/1) in all extraetion wells and in 25 other monitoring wells aeross the site in 2011. In 2013,
arsenie was deteeted above the current MCI in all of the 17 monitoring wells sampled tor
arsenic aeross the site. The highest eoneentrations were deteeted in overburden monitoring well
MW97-2K in 2011 (1670' 1630 (FT)] tig/1) and overburden monitoring well MW 97-21 in 2013
(1370/1340 [FDJ ug I).
In 2
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Arsenic special ion data were also collected in 201 3 and 2014. Samples were analyzed for
inorganic arsenic (trivalent fill) and pentavalent (V) and organic arsenic (dimethyl arsenic
(DMA) and mono methyl arsenic (MM A). Results are provided in Appendix D. ft was found
that the arsenic in the groundwater at the Baird & MeGuire Site is in inorganic form, primarily as
the more soluble trivalent arsenic. Trivalent arsenic is normally the predominant species in a
reducing aquifer em ironmcnt.
I'eMicides. As noted in the 2011 annual report, the pesticide plume is centered between
monitoring wells MW9S-I and MWl)7-2S, with extraction wells HW-4A and FW-6 most
appropriately sited to address this plume. 'The 2004 Trend Evaluation Report (M&F, 2004b) had
noted a decrease in the number of locations with detections of pesticides over the period from
2000 to 200.1 (41 wells down to 1 7 wells). During the comprehensive 201 1 sampling round,
pesticides were detected at 10 wells, indicating a possible further decrease in the size of the
plume. The 2004 Trend Evaluation Report had also noted that in 2003, lindane (gamma-BHC)
exceeded the MC'L a? five wells within the plume area, while die 20! 1 monitoring data indicates
excecdanees of the Mil. for lindane (gatnma-Bl 1C) at just one well within the plume area. In
general, pesticides have continued to fluctuate over this llve-year review period. For example, at
well MWl>7-23, concentrations of total pesticides jumped from 6.72 pg 1 in 2011 to 44 pg I (52.2
pgl in the field duplicate) in 2012 and then decreased to 1.4ft pg/1 in 2013. The detections of
lindane (gamma-BUC) and heptaehlor epoxide both exceeded the current MCI s in 2012, while
only lindane (gamma-BUC) exceeded the current Mt I in 2015 and heptachlor epoxide was not
detected.
I .N APL. An LN API recovery system has been in place since March WW to remove LNAPL:
however, the system became inactive in March 2009 due to diminishing recovery of LNAPL.
LNAPL has continued to be detected in some wells; however, the specific guv ity of the LNAPL
appears to be close to water making 1 NAPL recovery unsuccessful. The fluid entering the
system was found to be in an emulsified state which is not read ity separated by the system's
oil/water separator (OW'S). Historically, die water phase liquid from the LNAPL recovery
system was discharged into I V\ -X; however, a June 2000 sample of the liquid revealed higher
concentrations of dissolved phase contaminants than those present in the EW-X extraction well.
For example, 4.4-DDD was close to an order of magnitude greater in the discharge liquid
(CHI:S, 2013).
During the period of October 1. 2011 to October 30. 2012. no LNAPL was observed in the
LNAPL system wells (LW-N, MW97-1, and MW^S-l). excluding infrequent measurements of
0.01 foot of oil at HW-8 on November 4, 2011 and September 16 and 23, 2012, These infrequent
detections are consistent with recent years (CUES, 2013).
During the same reporting period (October 1. 2011 to October 30, 2012). a total of I1) wells at
the site were gauged on a monthly basis to evaluate the presence and thickness of LNAPL.
During the monthly gauging events, I NAPL was detected in 7 of the IV wells. Primarily only a
trace, non-measurcabie sheen of LNAPL was observed, except for MW97-24 (contained 0.01
feci in November 2011) and extraction well LW-o, which contained 0.01 feet to 0.80 feet of
22
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I.N API LNAPL recovery at LAV-6 is initiated atler one foot of LN API accumulates in the
extraction well and occurs via an inertial pumping system. Four attempts were made to recover
LNAPL from extraction well I:\Y-6 and a total 28 gallons of LNAPL was removed in total
during the reporting period on October 14 and November 22. 2011 and January 1 ^ and April 6,
2012KIILS, 2013).
As part of the arsenic investigation conducted by MassDLP in 2009 through 2011 and
summarized in Arsenic Summary Investigation Report Part II 1 la (CI1LS. 2014a). several soil
borings were conducted. Three soil borings located within or in close proximity to a former
gravel pit (ASB-13, ASB-20. and ASB-20) had evidence o!"organic vapor or LNAPL with
elevated P1D responses. Soil borings ASB-20 and ASB-21 encountered the groundwater table at
approximately 11 feet below ground surface (bgs) and showed evidence of LNAPL from I 1 to
14.5 feet bgs and 11 to 20 feet (bottom of boring), respectively In soil boring A SB-14, the
presence of LNAPL was observed from 16 to 20 feet bgs (bottom of boring). Samples of soil
containing LNAPL were collected from each of the three soil borings for 8VOC and pesticide
laboratory analysis. PAHs were detected above MCP regulatory standards in each soil sample,
while only the sample from ASB-21 contained pesticides above MCP regulatory standards. The
report concluded that the occurrence of LNAPL within the gravel pit did not appear to correlate
with elevated arsenic concentrations in groundwater.
The location ofl NAPI. is coincident with the hot spot of the organic plume. Therefore, it was
concluded that LNAPL is the primary source of the organic contaminants found in the
groundwater (C'HLS, 2014a). The groundwater evaluation reports for the site have concluded
that, because a significant amount of pure phase product (LNAPL) still exists in groundwater at
the site, biodegradation will have relatively little impact on contaminant destruction. If the
LNAPL can be removed such that only the dissolved phase remains, biodegradation could be a
significant factor in attaining cleanup goals. Biodegradation may be beneficial at die present
time in stabilizing the edges of the plume away from the plume source, such as across the river
and to the north of the extraction system. However, hydraulic containment achieved by the
groundwater extraction system is likely the primary reason for the stable or shrinking plume size.
Other Parameters. Additional parameters added to the 2012 and 20! 3 annual monitoring
events included COD. TPIL and TOC. These parameters were added in response to
recommendations made in LPA's Optimization Review for the Baird & McCiuire Superfund Site,
which was finalized in May 2013 (USEPA, 2013), The Optimization Review report
recommended that laboratory analysis for TPH and TOC be added to the groundwater
monitoring program to better correlate residual organic contamination with low oxidation-
reduction potential (ORP) and high arsenic concentrations. The report speculated that VOCs and
SVOCs are only a part of the organic compounds contributing to low ORP and arsenic mobility
in groundwater and that TPH are also a potential source. In 2012, groundwater samples from all
monitoring wells sampled, in addition to two well points (ASB-16 and ASB-22). were analyzed
for COD, while samples from one monitoring well (MW07-23) and the two well points were
analyzed for TPH and TOC. In 2013, groundwater samples from all monitoring wells sampled
were analyzed for COD, TPH. and TOC (see Appendix 1) for the results).
23
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COD is a measure of the oxygen demand of organic compounds in water, and is an indicator of
the amount of organic pollutants present. Based on review of the 2013 data which was the
largest data set for all three parameters, COD was detected in samples from 5 of 19 wells and
TOC was detected in 9 of 19 wells. The three wells with detectable COD were also the three
wells with the highest concentrations of TOC t BM-7. Y1W97-23, and MW<>7-12); however, the
TOC analysis appears to be a more sensitive indicator of the presence of organic pollutants based
on the higher number of detect ions. T PI I was detected in groundwater samples from 11 of 19
wells in 2013. The highest concentration of ITI i (5.05 mgl at MW97-23) corresponded to the
second highest TOC detection and third highest COD detection. The second highest detection of
"I Pi 1(1.11 mg/i in M W97-21} corresponded to a Sower detection of TOC. All other detections of
TP! I were less than 0.5 mg/1 and only one third of the detections corresponded with detectable
TOC
( ot halo River Sediment, Surface ^ utii\ mid I ish Tissue Monitoring
Long-lcrm monitoring of sediments in the Cochato River was performed on an annual basis from
19% to 2002. The OU-3 ROD called for long-term monitoring of sediments in portions of the
Cochato River downstream of the portion of the Cochato River where sediments were excavated
as part of the remedy. Long-term monitoring has also included analysis of fish tissue in order to
monitor the impact of the sediments on the fish population. Fish sampling was conducted in
1992, 1996, and annualh from 1999 through 2002. Surface water samples were collected from
the Cochato River in 2000 in order to establish baseline surface water qualify for the project.
Based on data trends identified from samples collected between 2000 and 2002, a sediment and
fish tissue sampling frequency of every five years was recommended ;n the second live-year
review (USLPA, 2004). No further surface water sampling was recommended. Sediment, bank
soil, and fish tissue samples were collected in October 2013 in support of this five-year review
(L5&M 2014),
Hleven sediment samples ami lour soil samples were collected from in and along the Cochato
River between October 9 and October I 1, 2013 (see Figure in Appendix 13). Station progression
(upstream to downstream) is A, F (next to site), B. C. and f). Bank soil samples were only
collected at stations C and I) Samples were analyzed for TOC, grain size. PAI Is,
organochlorine pesticides, and arsenic. Analytical results are summan/ed in Appendix P. Line
graphs are also included which show the mean concentrations of! OC. PAI Is, Arsenic. Total
Chlordane, and Total DOT detected in river sediment and bank soil samples collected at each
station.
PAHs were detected in all the samples including upstream samples collected from station A.
The highest concentrations were detected in the sediment sample collected at station I: where
naphthalene was detected at 19.5 mg'kg. The highest pesticide concentrations were detected in
the sediment sample collected at station I) farthest downstream of the site where 4.4"-l)l)l) was
detected at a concentration of 13.1 mg'kg. Arsenic concentrations above 100 nig/kg were
detected in samples collected at stations A, C, and D. with the highest concentration (I 79 mg/kg)
24
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delected in the sediment sample collected from transect 7 at station A |the upstream location).
Table 13-3 in Appendix I) compares the 2013 sediment and soil results to historical results and
the sediment cleanup levels developed in the 1989 ROD < listed under "Program Action Limit -
River" in the table). Values listed as Program Action Limits for hank soils are not established
project cleanup levels, but rather concentrations used for evaluation of results in historic trend
analysis documents, developed to he protective of humans participating in recreational activities.
The results presented show total PAH concentrations which are higher than the previous (2002)
monitoring round in all samples. The total PAH concentrations exceed the sediment cleanup
level at Stations A (upstream) (2V.K70 tig/kg) and 1; (adjacent to site) (76,664 ug/kg). Station D
also showed an exeeedance of the total DDT sediment cleanup level (19,559 ug/kg). In general
concentrations of detected conlaminants were greater than the previous monitoring round.
Table D-4 in Appendix D presents the 2013 fish tissue results compared to historical results.
The results presented show that there were no PA lis detected in any of the llsh tissue samples in
2013. Total ehlordane detections were similar in magnitude to the previous two monitoring
rounds (2001 and 2002), except tor Station A (upgradientj. which showed a high concentration
in the American Eel. This high result was based on one eel sample which was much higher in
concentration than the other. Similarly, this same eel sample resulted in a high total DDF result
at Station A. Other detections of total DDT were similar in magnitude to the previous two
monitoring rounds.
Wetland IVlunUorinn
Because on-siie wetlands were impacted during implementation of the OU2 remedy, as necessary
to remove and remediate contaminated soil, wetland restoration was required. A site inspection to
assess the condition of the restored wetland area, as well as the restored upland area, was
performed during the five year review process on August 8, 2014
In general, the wetland vegetation was well-established at all of the wetland areas inspected.
Typical wetland vegetation included: soft rush (./uncus effususL American burr-reed
{S/hirgitiiium (iimriixutum). woolgrass (Scirpus trperimtsh dark-green bulrush {Scirpus
lilntviivus), wide-leaf cattail t Typhu lali/ohai. narrow-leaved cattail (lyphd un^usii/oliul, reed
canary grass (Piuiiaris untmiinuceaL giant goklenrod (Sofida^o gigantcaK lurid sedge (Carc.x
lunda). fox sedge (( drc.x vulpinoidcui. water horehound (l.ycopus atucrkanus}. spotted touch-
me-not Ihnpotiens capensts), Canada rush (Jimats canadensis), deer-tongue grass
iPichanthclium chwdcstinumK rough-stem goklenrod tSoiidasio rttgo.MO. sensitive fern (Onoclca
sciisthfhs), flat-top goklenrod (Euthamia ^rainint/bliaj. and poison ivy (Toxicodendron
rod icons). Silky dogwood f( 'ornus amomum). Bebb willow (Stdtx hchhiana). elderberry
(Sambucns spj, red maple {Acer rttbruni). Northern arrow1 wood (Viburnum denhmtmi, green ash
(h'mxinus pciwwlvamcah eoltomvood saplings {Popuhc* dciioidc^l. speckled alder (,-thins
rugosah highbush blueberry tI acciniuni corymhtnimu. and grey birch (Bctuta poputifoha) were
observ ed in the shrub layer of the restored wetland areas at the site.
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Consistent with observations from the prior five year review in 2009, restored upland
portions of the site appeared to be well-vegetated and stabilized. Vegetation in these
upland areas arc similar to that observed in 20(H). The dominant species consisted of
various grasses (Family: Poaccae), black locust trees and saplings (Rohinia
pscuJoihucia). various goklenrods ( Snlniit^a spp.h common blackberry (Ritbits
lilieghi'fiieitsi.sh bird's foot trefoil {f.ottts cornictt/utus). knapweed {Centilitrea stoebe).
white pine (Pimis strohu.s), milkweed {Asclc/u
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personnel said lhat they are experiencing problems with F.W-6 that indicate that maintenance
ma\ be required soon, O&M personnel suited thai EW-9 is in need of a new motor and
redevelopment. This well currently produces approximately I gpm, A new extraction well. I W-
10. was recent K installed (work was being done on the well at the time of the site inspection).
The location ofIAV-10 was selected based on results of an arsenic study that was conducted by
the MassDF.P to better define the location of the arsenic plume.
The Extraction Well Control Building was briefly visited, The variable frequency drives (VI Ds)
for the wells, located in the building, are no longer used to control flow, but are let! open. Total
flow to the CiWTP is approximately 80 gpm. The LNAPL collection system is no longer in use.
Currently, NAPI. is collected manually from extraction well F.W-6. When collected, the NAPI. is
allowed to separate over time before being drummed and shipped off-site. Approximately 2.5
gallons ofNAPL were last collected in December 2013.
In general, the CiVVI'F continues to meet effluent discharge limits; however, the age of the
equipment has resulted in some difficulty for the operators, including difficulty finding spare and
replacement parts. Various upgrades and safety measures that have been implemented since the
last five year review were noted, including the replacement of high pressure sodium lighting with
energy efficient l.f- D lamps; the addition of new variable fret|tiency drives on the aeration tank
blowers; replacement of the potassium permanganate tank; replacement of the CiAC media with
a longer-lasting coarser grade of carbon, and installation of new tank railings and restraints.
More detail of the improvements is provided in Section IV.
More detail tin the site inspection, including photographs, are included in Appendix F.
Inln vims
The MassDl P Project Manager, the O&M Contractor personnel, and the Town Administrator for
the Town of I lolbrook were interviewed as part of the live year review process- The Holbrook
Town Administrator was interviewed by telephone, and the MassDFP Project Manager and the
O&fvl Contractor were interviewed as a group during the site inspection.
In general, the Holbrook Town Administrator was not aware of am problems or complaints
related to the Site, and said that he last visited the Site about 3 years ago. The one concern noted
by the Town Administrator is the back taxes owed to the town by the properly owners.
The overall sentiment of the MassDF.P Project Manager is that decisions need to he made at a
higher level regarding the source of continuing contamination (particularly arsenic), and an
approach to future remediation needs to be developed. She said that she agrees with
recommendations in the Optimization Rev iew.
O&M Contractor personnel staled that the (SWTF is functioning well, although due to ihe age of
the facility, it has been difficult to find spare and replacement parts. Their main issue is the high
arsenic concentration in the groundwater. They hav e tried to pinpoint the source of the arsenic
27
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and to locate the new extract ion well to best capture the arsenic plume. Imprmements and
modifications to the feci I it v. as well as monitoring frequency and Muffing, were discussed. No
complaints or intruders were noted, other than kids cutting through the town land on the other
side of the fence near the extraction wells. The O&M staff did express concern regarding the
impact that proposed redevelopment of a bordering lot of land will have on site operations and
access (parcel 19-003-00-0 in Table 3). Part of this property is currently located within the site
perimeter fence, however, the developer is proposing to move the fence to the property line as
part of the redevelopment.
More detail is provided in Appendix F.
28
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(\ , i i t IIMC VI. ASJsFSSM! Vi
Question A: |\ tin remedy functioning as intended In the tfccisinii documents?
Remedial Action Performance
The review of the documents, ARAKs. and risk assumptions indicates dial the remedy continues
to operate and function as designed and is currently protective; however, the GWTF equipment
and most of the extraction wells are very old and require considerable maintenance.
(I u nil it > for Optimization
Ah discussed in Section II, the EPA conducted an optimization review in 2012/2013 to identify
specific actions that may he taken to potentially improve the effectiveness and cost-efficiency of
the remedy. The review focused on remedy performance, protectiveness. cost-effectiveness,
technical improvement, and site closure strategy. The recommendations of the optimization
review are documented in Optimization Review for the Baird & MeGuire Super fund Site, which
was finalized in May 2013 (I'SHPA. 2013), \ number of the recommendations have been
implemented; others were considered, but not implemented; and others are still being evaluated.
See Section II for a detailed discussed on the optimization review and efforts made to implement
the recommendations.
l ath Indicators of Potential Issues
As noted above, the age of the (iWTF equipment and the extraction wells present ongoing
maintenance issues.
Implementation of Institutional ( onhols and Other Measures
Site perimeter fencing lias been effective at preventing unauthorized access to the Site, fish
advisory signs are being maintained, and the I J5 A and MassDEP are in the process of developing
ICs for the Site.
Question B; Are (he exposure assumptions, to\icit> data, cleanup levels, and remedial
action objectives (k \(M used at the lime of (lie reused) section still valid?
With respect to human health risk, while there have been changes to toxicity values and exposure
parameters, the changes do not impact the protectiveness of the remedy. With respect to
ecological risk, there arc no newly promulgated standards relevant to the site, which bear on the
protectiveness of the remedy There are no major changes in site conditions or exposure
assumptions upon which the ecological risk assessment was based that would result in increased
exposure or risk. The overall conclusion is that the remedy, as implemented, is protective of
human health and the environment
29
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Ko% icw of Human Health Risk \ssesM»cni
The risk assessment performed for she 1 C)K6 feasibility Study (FS) report (GHR. 1986a)
concluded that there would be significant risk to human health if groundwater from the site
containing VOCs, SVOCs, and metals was ingested in the future. The risk assessment further
determined that trespasser exposures to site soil containing arsenic, chlordane, and dioxins
exceeded 1 PA risk management guidelines. Direct contact recreational exposures to ("ochato
River sediments containing elevated levels of arsenic. DDT. PA1K and chlordane also exceeded
regulatory limits. Maximum Contaminant Levels (MCl.s) were selected as interim cleanup
levels for groundwater. The results of the risk assessment were used to determine the lateral and
vertical limits of soil excavation, and to establish cleanup levels for sediment. There was no
evaluation of the fish consumption pathway in the risk assessment.
In W7, a supplemental risk evaluation was performed by Metcalf & Fddy (Vl&f) as part of the
Site Reuse Study (M&1;. WK) to determine the potential risk associated with future
commercial industrial site re-use. Child trespasser risks were also evaluated. Because soils had
been excavated, incinerated, and backfilled on-site, the risk evaluation focused on residual risks
associated with backfilled ash. contaminated soils remaining below the bottom depth of
excavation, and 20 acres of soil remaining outside the limits of excavation, lite study concluded
that, based on the results of the qualitative risk evaluation, the site could be developed for
commercial or industrial use and would not pose harm to children periodically trespassing onto
the site.
The toxicity values that served as the basis Ibr the sediment cleanup levels, as contained in the
1989 ROD. have been re-evaluated to determine whether any changes in toxicity impact the
protect iveucss of the remedy. Changes in toxicity values since the |9y? risk evaluation arc also
discussed below to determine whether reuse decisions remain valid. Any changes in current or
potential future exposure pathways or exposure assumptions that may impact remedy
protectiveness are also noted.
Changes in Toxicity. Table 7 presents a summary of the changes in toxicity values (oral
reference doses and oral cancer slope factors) for compounds selected as Contaminants of
Potential Concent (COPCs) as identified in the 1989 risk assessment. Updated toxicity
information was obtained from the Integrated Risk Information System (IRIS; I'SI-PA. 2014a)
and other current EPA sources (e.g., the Superfund Health Risk Technical Support Center).
Toxicity values for contaminants identified as COPCs during the 1997 risk evaluation,
performed as part of the Site Reuse Study, have also been listed. Note that an increase in an oral
reference dose will decrease the resulting hazard quotient, while an increase in an oral slope
factor will increase the resulting cancer risk.
For most contaminants, changes to toxicity information have been minimal. Changes in toxicity
values lor groundwater O )PCs (e.g.. ethylben/cnc. trichlorocthene. tctrachloroethcne, and vinyl
chloride) would not affect remedy proteetiveness since cleanup levels for groundwater arc based
on federal MCI v Until groundwater cleanup levels are achieved and groundwater use is
demonstrated to not pose a risk to human health, the installation of private wells and associated
30
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groundwater exposure pathways should he prevented. Though no formal mechanism is yet in
place to control groundwater use in the vicinity o f the site, a local Board of Health (BOH)
ordinance discourager groundwater use by requiring that property owners obtain BOH and
Department of Public Works approval prior to installing wells.
A noteworthy change between 1997 and 2014 toxicity values is for ehiordane, a significant
contaminant in residual soils remaining at the site. The oral slope factor for chlordane has been
decreased o\erall by a factor of approximately three, which results in a decrease in the estimation
of cancer risk associated with chlordane in residual soil. Therefore, the conclusions of the W?
risk evaluation remain valid, based on the toxicity evaluation.
An additional noteworthy change between KW anil 2014 toxicity values is for dioxin, On
February 1 7. 2012, FPA finalized the non-cancer toxicity assessment for 2..1,7.K -
tctrachlordiben/o-p-dioxin iTCDO). indicating that non-cancer health effects from exposure to
dioxin can now be quantified. liPA's dioxin reassessment has been developed and undergone
review for many years, with the participation of scientific experts in f-PA and other federal
agencies, as well as scientific experts in the private sector and academia. The Agency followed
current guidelines and incorporated the latest data and physiological/biochemical research into
the reassessment. With the release of the Una! human health non-cancer dioxin reassessment,
EPA also published an oral non-eaner toxicity value, or reference dose (Rfl)). of 7x10'10 mg/kg-
day for 2.3,7,8 - TCDD in EPA's Integrated Risk Information System (IRIS). The dioxin cancer
reassessment will follow thereafter. The dioxin Rfl) was approved for immediate use at
Superftmd sites to ensure protection of human health. While this change increases the hazard
quotient for the site, the result is still below I when applying the current Rfl) ami the site specific
parameters utilized in the 1997 evaluation (see Appendix Ci). Therefore, the remedy is still
eo ns i tie red protect ive.
In addition, based on is compilation and review of data on relative bioavailability of arsenic in
soil (USbPA, 2012), arsenic was found to be less bioavailable via soil ingestion re lathe to other
analytes. A relative bioax oilability factor is now-' applied during soil'sediment ingestion
calculations of risk cleanup levels. This factor reduces arsenic contribution to risk and or
increases cleanup levels. Therefore, the conclusions of the 1LW risk evaluation remain valid,
based on the toxicity evaluation.
31
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! :
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Contaminant of
Oral Reference Dose (RfD)
Oral Slope Factor (SFj
Potential Concern
(mg'kg-day)
(mg/kg-day)"'
1989 199?'
20H
1989
1997"
2014
Xylenes
0.01 b
0.2
N/A
N/A
Zinc
0.21 b
03
N/A
N/A
Dibenzofuran
N/A
0,001
N/A
N/A
2-Methylnaphtbalene
N/A
0,004
N/A
N/A
Acenaphthene
N/A
0.06
N/A
N/A
Acenaphthylene (gj
N/A
0 06
N/A
N/A
Anthracene
N/A
0 3
N/A
N/A
Banzofaianthraeene
N/A
N/A
N/A
0.73
Benzo(b)fluoranthene
N/A
N/A
N/A
0.73
Benzofg.h i)perylene (h)
N/A
0.03
N/A
N/A
Benro( k )f luoranthene
N/A
N/A
N/A
0 073
Chrysene
N/A
N/A
N/A
0.0073
Dibenz(a tviantbracene
N/A
N/A
N/A
7.3
Fluorene
N/A
0.04
N/A
N/A
tnrtenofl 2,3-cdtpyrene
N/A
N/A
N/A
0,73
Naphthalene
N'A
0.02
NjA
N/A
Phenanthrene (h)
N, A
0 03
N/A
N/A
Pyrene
N/A
0.03
N/A
N/A
N/A = Not Applicable or Not Available
a. Derived from Acceptable Daily Intake (mg/day) divided by assumed body weight of 70 kg,
t> Derived from Acceptable Intake Chronic (mg/day) divided by assumed body weight of 70 kg.
c. Derived from Risk Reference Dose (my/day) divided by assumed body weight of 70 kg.
d. Lead is currently evaluated through the use of exposure modeling for adults and children,
e 1997 evaluation only looked at the analytes noted.
f Vinyl chloride has toxicity values for both adult and child to account for mutagenic mode of action (see discussion
below). Toxicity values presented in table are for adult receptors,
g. Acenaphthene usee) as a surrogate due to structural similarities,
b Pyrene used as a surrogate cite to structural similarities
Changes in Exposure I'athwaW Assumptions. There have been no changes in land use since
the last five-year review. Current and future planned uses are still commercial industrial in
nature.
One pathway of potential concern that was not evaluated in the ll)K9 risk assessment was the
vapor intrusion pathway. This pathway may be of eoncern at Mies where soil and shallow
groundwater contaminated w ith VOCs exists in close proximity to occupied buildings- LNAf'L
has been detected between I I and 20 feet bgs, F.xeept for the I NAPI Process Building and the
Extraction Well Control Building, there are no buildings located above the shallow groundwater
VOC illume that contains concentrations of naphthalene, 2-tnethy (naphthalene, ethylben/ene,
toluene, xylene and other VOCs above vapor intrusion groundwater screening values. These two
buildings are only visited occasionally (i e., a few hours per week) to make sure they are secure
or to perform periodic maintenance and monitoring of equipment: therefore performance of a
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screening evaluation for vapor intrusion is not warranted at this time. However, should shallow
groundwater VOC contamination continue to exist coincident with future site development
involving the construction of buildings that will be occupied consistently (e.g.. office space), the
vapor intrusion pathway should he further evaluated to determine the potential risk to on-site
workers. Because much of the site is located within wetland areas or the 100-year flood plain,
existing zoning by-laws which establish use restrictions in floodplains and wetlands provide a
degree of protection in that site re-development will be monitored or discouraged.
Neither the l(M(-> risk assessment nor the 1997 supplemental risk evaluation specifically assessed
the risk to construction or excavation workers exposed to residual soil or shallow groundwater
contamination during intrusive activities. Because this receptor population has not been
evaluated, institutional controls preventing excavations into areas of the site with residual soil
and or shallow groundwater contamination should be established, or an evaluation should be
performed to determine the potential risk to workers prior to initiating intrusive activities as part
of site re-development.
Changes in Risk Assessment (itiidanee. SuKeiueut to the h}i>7
supplemental risk evaluation, a new method to evaluate compounds with mutagenic modes of
action such as the carcinogenic PAHs is now recommended by hPA. The current methodology
calls for the use of age-specific adjustment factors to account for an increased sensitivity during
early life. The early-life calculation does not affect the conclusions of the 199? evaluation for
the commercial scenario because workers are assumed to be greater than 16 years of age for
which the early-life component is not applicable. The I1)1)7 evaluation showed that the cancer
risk for the child trespasser scenario was less than that for the commercial worker scenario.
However, the supplemental early-life calculation for child trespassers was not included as part of
the W7 evaluation since the F.PA carcinogen risk assessment guidance was published
subsequent to the completion of the site-specific risk evaluation. A supplemental calculation that
included the earlv-lifc component for carcinogens with mutagenic modes of action, performed as
part of the previous (2009) five-year review, continued the conclusion that child trespasser
cancer risk is less than the commercial worker risk. Therefore, the conclusions of the 1997
supplemental risk evaluation continue to be valid. Institutional controls should be implemented
to assure that future use of the site is consistent with the commercial land use assumptions used
in the Site Reuse Study risk evaluation, and that child exposures of greater frequency and
intensity than assumed for trespassing (50 da>s per year for 10 years) do not occur. The
implementation of comprehensive institutional controls is on-going, and when complete, will
pan ide long-term protcctiveness lor soil and groundwater remedies.
A recent liPA directive (USPPA. 2014b) was published which provides revised default exposure
parameter assumptions for various exposure scenarios. Many of these parameters differ from
those utilized in the previous risk evaluations. Most are related to residential exposures, which
would not impact the protcctiveness of the reined). There are, however, changes to the worker
soil adherence factor, skin surface area, and body weight. While not specified in the guidance,
similar changes to trespasser exposure parameters would also be appropriate. These changes
would generally result in reduced risk an increase in the risk-based cleanup levels (for all media)
providing the same level of risk defined in previous site documents.
34
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Because of the significant changes in risk assessment methods and assumptions since 19X6, the
previous like-year reviews performed re-evaluations of the sediment cleanup levels to determine
whether the changes in risk assessment methods affect remedy protectiveness. The evaluation
performed in 200') concluded that the ROD cleanup levels for sediment (arsenic 250 mg/kg;
PAHs - 22 mg/kg; DDT - 19 me,'kg; and ehlordanc - 5 mgdcg) were within EPA's target risk
range (10h to 10 with arsenic and PAHs (using conservative assumptions) being at the top of
the target risk range, The recent directive noted above would lower the overall risk related to the
sediment exposures. Furthermore, the reduced bioavailability id"arsenic (also noted above in the
toxicity changes) would lower the overall risk associated with the ROD cleanup levels.
With respect to these recent exposure assumption changes, the 14W? evaluation of residual
soil'ash would show a low ered risk related to the exposures evaluated, thereby maintaining the
conclusion of proteetiveness.
Fish Tissue. There have been no site-specific cleanup levels associated u iih the fish tissue
ingestion pathway. Previous evaluations and five-year reviews have utilized action limits
developed by the Food and Drug Administration (FDA) as guidance values for comparison
purposes even though they are not intended for applies!ion to reereationally-caught fish. More
appropriate comparison methods arc now available. The Regional Screening Level (RSL.) online
calculator (http: 'cpa-prgs.omkgov/cgi-bitvchcniicals,csl search) was used to generate screening
levels for a range of fish consumption rates (i.e., 50ih percentile and 95"' percentile I taken from
Table 8a of HPA-X20-R-14-002 (Hstimatcd Fish Consumption Rates for the U. S. Population and
Selected Subpopulations (NIIANFS 2003-2010 Final Report April 2014) for the inland northeast
adult population. These values are 22.1 g day for the 50lh percentile and 76.1 g day for the
percentile). The resulting screening levels are as follows:
Anal> tc
Screening 1 evelv 1
Ingestion Rate = 76,1 g/day Inuesiion Rate =¦ 22 g'"day !
Chlordane
Risk - 1F-06
8.43
HI 1 Risk - IF-06
548 J 29'
III - 1
"l K90 •
DDI
8.68
548 1 29.9
1X90
Ben/o(a)pyrcne
0.404
NA j 1.39
NA |
1 :se of these screening levels for the evaluation offish ingestion (see below) in more appropriate
than use of the FDA values. Note that the RSI, calculator does not evaluate total PAHs, so
hen/o(a)pyrene is used as a surrogate
Kvalmitioti of Recent Sampling Data, A> di^cu^ed in Section 111. arsenic, hen/em..
ethvlben/ene. lindane,, benzol a)pyrene, bis(2-ethylhe\yl)phthalate. mercury, and
pentachlorophenol in select monitoring wells continue to exceed MCLs. Continued exeeedances
of MCFs indicate that completion of the drinking water ingestion pathway would present a risk
to residents. Since groundwater Irom the site is not currently used by area residents as a source
of potable water, the drinking water exposure pathway is incomplete. Until groundwater
concentrations meet interim cleanup levels (MCLs), institutional controls should be implemented
35
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at the site to ensure that no private wells are installed at or near the site.
Surface water monitoring data are no longer eoHeeled as the prior two live-year reviews
evaluated the most recent data (from 2000) and found results to be well below HPA\s target risk
range of 10'" to It!'1.
Sediment monitoring data were eolleeted in 2013 (see Section lilt While there was one
exeeedance (Station IX downstream of site) of the DDT cleanup level, as discussed in the third
llve-year review, the cleanup level was developed at the 1 E-06 risk level and, based on changes
to toxicity values and exposure parameters, would actually be higher than determined in the
ROD. As the exeeedance is just above the ROD cleanup level, the resulting risk would be within
FP/Vs target risk range. As discussed earlier, the ROD cleanup le\el for I'Alls is at the top of
the target risk range. The 2013 data show exeeednnees of the PAH cleanup level at Stations F
(adjacent to the site) and A (upstream of the project area). The exeeedance at Station E is within
the range of historic detections {although much higher than I he last two monitoring events).
Station F is located within the site perimeter fence and therefore there is very limited human
exposure potential. The upstream sample (Station A) is at least one order of magnitude above
any historic detections in this area. It appears that further monitoring should be performed for
confirmation of these exceedances, and that additional upstream characterization may also be
needed to determine if there have been any recent upstream releases contributing to the residual
contamination in the sediment adjacent to the site.
Fish (issue (fillet) data were collected in 2013. While 2002 fish samphng data indicated a
potential issue with PA1I detections, there were no PA!Is detected in 2013. As discussed in
Section III, there have been no site-specific cleanup levels developed for the fish tissue ingestion
pathway. However, the screening levels developed above have been used to euiluatc risks
associated with detected concentrations. Note that CPA has a target cancer risk range of 10 " to
I0~ and a target hazard index of 1. The cancer screening levels presented above are for I x 10'",
To establish the approximate upper bound of the target cancer risk range (related to 10 1 >, the
cancer screening levels are multiplied by 100, For ehtordane and DDT. the upper bound related
to cancer risk is above the screening levels related to a target hazard index of 1. thereby making
discussion of hazard index screening levels more significant than the cancer screening levels. Of
the DDT and chlordane detections observed, only DDT found in the American eel at Station A
(upstream) was high enough to be above FPA's target hazard index of 1 for a higher ingestion
rate of 76.1 g performed for the FS
Report fOHR, 1986a) was conducted using standard science, methodologies, and professional
judgment available at the time.
The media of concern were on-site soils and Coehato River sediments. The FRA concluded that
36
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there would he significant risk to ecological receptors from pesticides, SYOCV and dioxin,
although the ERA did not recommend site specific clean-up levels derived from ecological
end points (as would he done using current guidelines). Hie limits of cleanup were based on the
nature and extent of soil contamination documented in the Rl IS; the ROD specified the
excavation of soil from areas based on contamination profiles developed in the R1 Addendum
(Cil lR, 1 l>N6b). The limits of excavation were established no that contaminant concentrations
outside of the hot areas were one to two orders of magnitude lower than the concentrations inside
the hot areas. Excavated soil and sediment were treated by on-site incineration and backfilled in
upland areas. L imits of excavation were established to minimize disruption to wetlands.
In IWY, the ROD for the sediment study area (designated as Operable Unit 3 |OU-3|) was
signed. This ROD covered the excavation and incineration of sediments from a length of the
Cochato Ri\er extending from the liaird & McCiuire site to (he Union Street crossing, placement
of clean backfill in excavated areas, and long-term monitoring of downstream portions of the
Cochato River beyond the excavated areas. Sediments were dredged to a minimum depth of six
inches and a maximum depth of 24 inches along a 2,100-fool reach of the Cochato Ri\cr. A total
of 4,712 cubic yards of sediment was removed. A small portion of the riverbed where
contaminated groundwater was suspected to discharge to the river was backfilled with clean
organic fill (approximately 438 cubic yards).
Since the ERA was written in 1986, EPA has promulgated guidelines to address screening
chemicals, selecting contaminants of concern, and performing risk calculations. Furthermore,
many of the tools available today had not yet been created, such as benchmark screening values,
toxicity data, or improved laboratory detection levels. In order to address these changes in
guidelines and available toxicity reference values, additional evaluations were performed in the
second five-year review to assess risk to ecological receptors. These evaluations included
modeling of the exposure of a small mammalian receptor exposed to the soils in the remedial ion
area and comparison of fish tissue concentrations to toxicity reference values to assess potential
adverse effects on fish exposed to site contaminants in the Cochato River. Since the last five-
year review, there are no newly promulgated standards, relevant to the site, which bear on the
evaluation of risk or the protectiveness of the remedy. There are no major changes in site
conditions or exposure assumptions on which the risk assessment was based that would result in
increased exposure or risk.
Soil Excavation, Although the limits of excavation were not determined using ecological!)
based risk criteria, the remedy likely eliminated risk to ecological receptors from pesticides and
other organic contaminants in soil w ithin the excavated area. As part of the second the year
review, an evaluation was performed to estimate the exposure of a short-tail shrew as a receptor
exposed to the soils in the remediated area. I 'sing the maximum analyfe concentrations in
quarterly ash samples reported in Table A-1 of the Evaluation of Potential future Reuse
Opportunities of the Baird & McCiuire Site report (M&E. 1998), a preliminary model was run to
estimate exposure of selected SVOCs and inorganics to a small mammal (shrew) living in the
remediated area. Based on this preliminary model, the second five-year review concluded that
the remedy implemented for upland soils was protective for ecological receptors, although a
more thorough model which uses UCLs and average concentrations, and evaluates risk from all
site contaminants would he needed to confirm this conclusion with greater certainty. No
37
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confirmatory samples were collected during soil excavation, nor was additional soil sample data
collected for the third five-year review, thus it could not be determined whether or not the limits
of excavation were sufficient to remove concentrations of contaminants to levels that are
protecti\e to ecological receptor under contemporary ARARs.
As summarized in the Data Review section, soil data were collected in 2013 from two areas
(stations C and I)) along the rtverbank of the C'ochato River. The samples were analyzed for
PAIis, organochlorine pesticides, and arsenic. Table D-3 in Appendix I) compares the 2013 soil
data (hunk samples) to historical results and to clean-up levels developed in the 19X9 ROD.
Table D-5 compares these same results to soil screening levels that are used in current-day risk
evaluations. The screening values are conservative, but indicate cxcecdances of screening le\els
for PAIls, DDT. ehlordane and arsenic in both of the soil samples collected in 201 3. The levels
measured in 2013 in the Mary I ee Wetlands and on the hank locations of lee Pond were higher
than 2002. although only the PAH concentrations in soils of the Mary Lee Wetlands were the
highest concent rations observed among all of the historic samples from 19% to 2002. The soil
data show a substantial amount of variation between \ ears, indicating that there may be
significant spatial variation in the distribution of contaminants along the banks. The analysis
conducted in the second Five Year Review to model potential risk to small mammals from
exposure to soils used soil concentrations (hat were substantially lower than concentrations of
PAHs and pesticides measured in bank samples collected in 2013.
River Sediments, Action limits for river sediments and river bank soils were based on human
health criteria, thus the top six inches of sediment were returned from the exeavat ion area, and
riverbanks were restored with clean material. Because action limits were not based on ecological
criteria, it could not be determined with certainty whether or not the action limits were sufficient
to remo\ e concentrations of contaminants to levels which are protective of ecological receptors
under contemporary ARARs. 1 knvever, because the /one of biological activity in sediments
(i.e., the oxidi/ed /one) typically consists of the top six inches (Rosenberg and Resh. 1993), and
because the oxidized zone is where most species concentrate their interaction with their
environment (USHPA, 2000). removal of the top six inches of sediment and replacement with
clean material likely mitigates the risk of contaminants to benthic and aquatic ecological
receptors.
No confirmatory samples were collected during sediment excavation, nor were there additional
sediment sample data collected for the previous five-Near review. Thus in the previous five-vear
reviews, it could not be confirmed whether or not the limits of excavation were sufficient to
remove concentrations of contaminants to le\els which are protective to ecological receptors
under contemporary ARARs. 1 low ever, samples were collected from the Coehato River in 2013
and the results can be compared to contemporary screening values tor sediment contaminants.
Sediment samples collected in the river at Stations A. E, B. C and D were analyzed for PA1 is.
arsenic, ehlordane, and DDT. Table D-5 compares the sediment results to screening levels that
arc based on probable effects concentrations fPEC's), The results show total PAII concentrations
which are higher than the previous (2002) monitoring round in all samples, The total PAH
concentrations exceed the sediment screening levels at Stations A (upstream) and E (adjacent to
site). In general, pesticide concentrations were above screening lex els for most sampling rounds
38
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at all locations except the Station A (upstream). Highest concentrations of both DDT and
chlordane were detected in 2013 at stations E (adjacent to site), and all downstream locations in
the river sediment. In order lo confirm thai the higher concentrations of contaminants measured
in 2013 in sediments, additional sampling of sediments to determine the extent of the elevated
PAIls and pesticides will he conducted so that further risk evaluation can he performed to
determine the long-term protectiveness of the remedy prior to the next five year review.
I-'isli Tissue. The rented)- also included conducting long-term fish tissue monitoring in the river.
In the second five-year rev iew, maximum llsh body burden data collected during the
September October 2002 round of sampling (M&h. 2003) were compared to toxicity reference
values (TRVs). TRVs were obtained from the Environmental Residue Effects Database < f Rl I);
I'SAC'P, 2004). TRVs were selected from chronic no-observed effects-dose (NOPD) studies
with reproductive endpoints The comparison indicated that because fish body burdens are
below TRVs. there is negligible risk to fish, thus the remedy is protective offish. No studies
added to the 1-Ri.D database since the last five-year review would alter the selection of TRVs
used. A re\ iew of the database in 2014 did not identify any studies providing new TRVs from
chronic no-observed effects-dose (NOI D) studies with reproductive endpoints for fish species
since 2004 for COC's used to ev aluate lish tissue in 2004.
Additional fish tissue data were collected for this fourth five-year review. However, the fish
tissue was analyzed only for the concentration of selected contaminants in the fillet portions of
the fish, which is the portion of the fish used to evaluate risk to human health, fillet
concentrations typically under-represent the whole body burden of contaminants that cause
effects tin fish. Table D-4 in Appendix f> compares the 2013 fish fillet data to historical results
for fillet data. The results presented show that there were no PAHs detected in any of the fish
fillet (issue samples. Total chlordane detections were similar in magnitude to I he prev ions two
monitoring rounds (2001 and 2002), except for Station A tupgradient), which showed a high
concentration in the American lie!. This same eel sample resulted in a high total DPT result at
Station A. Other detections of total DDT were similar in magnitude to the previous two
monitoring rounds.
The TRVs that were used in the second five-year review to compare maximum fish body
burdens are not appropriate to evaluate effects on fish using the 2013 fillet-only data. The fillet
data under-represent the body burdens and do not provide conclusive comparisons for ecological
risk to fish. However, since the majority of the concentrations of contaminants measured in fillet
are lower in the 2013 compared to the 2002 fi I let-only result, it is likely that the conclusions
from the 2002 evaluation are still applicable. The second Five Year Review concluded that since
fish body burdens were below TRVs, there is negligible risk to llsh. thus the remedy is protective
offish. Since the fillet data indicate that the concentrations in fish have not increased, it is likely
that this conclusion is still valid. Prior lo the next Five Year Review, another round offish tissue
data should be collected.
Summon am! < (inclusions Relative to I cnlogicai Kiskv In conclusion, since the I RA was
prepared in 1986. there are updated soil and sediment screening values not previously used to
select COCs potentially posing risk to ecological receptors. There arc no newly promulgated
-------
standards, relevant to the she, which hear on the protectivcness of the remedy. There are no
major changes in site conditions or exposure assumptions upon which the risk assessment was
based that would result in increased exposure or risk. The reference values and exposure
assumptions in the KRA were re-evaluated in the second FYR, were found to he generally
conservative. and were concluded to tie protective. Review of these assumptions and reference
values did not result in the identification of standards or reference values that would have
significantly changed for Ihc site evaluation since 2004.
Soil, sediment, and fish tissue data eoHeeled in 2013 were compared to updated ecological
screening values in this Five-Year Review Report. The 2013 data for sediment and soils were
generally above ecological screening levels. Elevated concentrations of PAHs and pesticides in
samples from Ice Pond and Mary Lee Wetlands indicate some uncertainty in the distribution of
these contaminants along the hanks of the river and wetlands downstream of the site. Since the
arsenic, PAH and pesticide concentrations were not the highest historically observed in these
local ions, the elevated levels may be a result of substantial spatial variation (e.g., two samples
could be collected within one foot of each other and show significant concentration differences).
In order to confirm the long-term protectivcness of the remedy, the concentrations of
contaminants in soils downstream should be further sampled prior to the next Five N ear Review
in order lo confirm risks to small mammal populations. Similarly, in order to confirm that the
higher concentrations of contaminants measured in 2013 in sediments do not represent a risk to
aquatic receptors, additional sampling of sediments to determine the extent of the elevated PAHs
and pesticides should be conducted so that further risk evaluation can be performed.
Data collected for evaluation of concentrations of contaminants in 2013 were collected for fish
fillets, only and not whole body tissue samples. The fillet data indicated that in fillet tissue there
were no PAHs detected in any of the fish samples. Total ehlordane detections were similar in
magnitude to the pre\ ious monitoring rounds. Since the majority of the concentrations of
contaminants measured in lit let are lower in the 2013 compared to I he 2002 fillet results, it is
likely that the conclusion from the 2002 evaluation that there is negligible risk to fish population
is still applicable.
AKAKs Review
A review of Applicable or Relevant and Appropriate Requirements was performed to check the
impact on the remedy due to any changes in standards that were identified as ARARs in the three
RODs and in the previous live-}ear review reports, newly promulgated standards tor chemicals
of potential concern, and TBCs tio be considered) thai may affect the protectivcness of the
remedy. Tables documenting the review of each ARAR, using the regulations and requirement
synopses listed in the ROD as a basis, are provided in Appendix H. The evaluation included a
determination of whether the regulation is currently ARAR or I IK and whether the
requirements have been met. A discussion of the review is summarized below.
40
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The ARARs identified fl»r the selected remedies include:
Location-Specific:
• Resource Conservation and Recover}' Act (RCRA)
• (.'lean Water Act (CAVA)
• Fish and Wildlife Coordination Act (16 t\S.C. 661)
• Wetlands Executive Order (E< > 11 Wd)
• Executive Order (Hi) ! I^88)
• Massachusetts Wetlands Protection Regulations
• Massachusetts Hazardous Waste Facility Location Regulations
• Massachusetts Environmental Policy Act (V1I-PA) Regulations
• Massachusetts Certification for Dredging. Dredged Material Disposal and Filling m Waters
• Department of Environmental Management (DEM) Inland Wetland Orders
Che m ic al- Spec i lie:
• Sale Drinking Water Act (SDWA >
• Resource Conservation and Reco\erv Act (RCRA)
• Federal Ambient Water Quality Criteria < \WOC)
• EPA Office of Water Guidance - Water-re la led Fate of 12*) Priorit s Pollutants (I971))
• Threshold Limit Values (TL Y>)
• National <)ceanic Atmospheric Administration (NOAA)
• Ontario Ministry of Environntent and Energy (OMEF)
• Massachusetts Drinking Water Requirements
• Massachusetts Surface Water Qualits Standards
• Massachusetts Air Quality-''Air Pollution Regulations
• Massachusetts Guidance on Acceptable Ambient Air Levels | AALs)
Action-Spcci lie:
• Resource Conservation and Recovery Act (RCRA)
• Clean Water Act <(.AVA)
• Clean Air Act (CAA)
• Department of Transportation (DOT) Rules for Transportation of I la/ardous Materials
• Massachusetts Hazardous Waste Regulations, Phase I and II
• Massachusetts Solid Waste Management Regulations
• Massachusetts Wetlands Protection Regulations
• Massachusetts Surface Water Discharge Permit Program Regulations
• Massachusetts Certification for Dredging, Dredged Material Disposal, and Filling in Waters
• OSHA General Industry Standards, Recordkeeping and Reporting, arid Standards for
Hazardous Waste Site Operations
Most of the listed ARARs remain applicable or relevant and appropriate to the site. Sonic of the
listed ARARs were for the soil remediation phase of the remedy, which was completed in IW?,
41
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and hence they are listed as formerly applicable or formerly relevant and appropriate. Those that
are still applicable or relevant and appropriate are being complied with.
As discussed above m the Review of Human Health Risk Assessment, the vapor intrusion
pathway was not evaluated in the 19Sl> risk assessment. As discussed above, performance of a
screening evaluation lor vapor intrusion is not warranted at this time, based on the amount of
time the onsite buildings are visited. Should shallow groundwater VOC contamination or
I.N API continue to exist coincident with future site development involving the construction of
buildings that will be occupied consistently (e.g.. office space), the VI pathway should be re-
evaluated based on available guidance at the time, particularly as it relates to institutional
controls and future site development.
Question ( : Has a in other information conn to li^ht that could call into question tlu
protect i\ eness of the reimdv ?
No other information that calls into question the protect i\eness of the remedy has been
identified during this f ive-Year Review process.
Technical \ssissment Suinmai >
According to the data reviewed, the site inspection, and the interviews, the remedy is functioning
as intended by the RODs. as modified by the two ESD documents. There have been no changes
in the physical conditions of the Site that would a fleet the protcetiveness of the remedy. Most of
the ARARs identified in the RODs remain applicable or relevant ami appropriate and either have
been met or are being complied with. An optimization review of the remedy was conducted and
many of the recommendations have been implemented or attempted, resulting in an overall cost
savings.
The toxicity values that served as the basis for the soil, groundwater, and sediment cleanup
levels, as contained in the OU-1, Ol 2. and 011-3 RODs, as well as the toxicity values used for
the soil "indicator chemicals" were re-evaluated to determine whether any changes in toxicity
impact the protcetiveness of the remedy, and no changes affecting protcetiveness were noted.
There are no major changes in site conditions, risk assessment methods, or exposure assumptions
upon which the risk assessment was based that would result in increased exposure risk.
Further monitoring of sediment for P\lls, including upstream sources, is needed to confirm
exeeedatiees and to support future risk evaluations.
Long-term protcetiveness is dependent upon implementation of institutional controls.
ISM KS Rl.( OMMIMJA I IONS AM) I Of IOW-l i' \( HONS
Table 8: Issues and Recommendations lollon-up \ctioiis
42
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ok n
ISSIH*
Rrcoinmemlnliriiiv
1 olhm-up \cti(in\
Party
*'
Responsible
Oversight
Agency
Milt stone
Date
Affects
Protect iveness?
(Y/N)
Current
Future
1.2,
3
institutional controls
restricting land uses
that may impact the
protect iveness of the
remedy (including
preventing the use of
groundwater and
preventing
excavation into areas
ol the Site with
residual soil and or
shallow
groundwater) need
to be established,
The implementation
of comprehensive
institutional controls
is on-going, and
when complete, will
provide long-term
protect iveness for
soil and groundwater
remedies.
EPA, MassDEP,
and the property
owners should
complete
development of the
iCs and record them
by the next five-
year review
Stale
EPA
8/30/2(119
No
Yes
1
The 1986 GUI ROD
states that "alter fne
(5) years of
operation, the
Agency w ill
determine in a
supplemental
decision document if
the restoration target
levels are achievable
and if they are
adequate to protect
public health and
environment."
Determine whether
current interim
groundwater
cleanup levels are
appropriate, and
document changes
us necessary.
I:PA, State
LPA
12 31 2015
No
Yes
43
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Oil #
issue
—
Kccniiimemhttiniis'
I o!lo\\-up Wtions
Party
Responsible
Ovcrsiuhl Milestone
Agencv Dale
Affects
Protect iveness?
(V.'N)
Current
Future
1
Arsenic, benzene,
ethylben/coe,
lindane.
bert/o(a)pyrene.
bisf 2-
ethyihexyl )phthalate,
mercury, and
pentachlorophenol in
select monitoring
wells continue to
exceed MC'Ls.
Evaluate
recommendations
from the 2013
Optimization
Report and
implement
investigations, as
appropriate. In the
interim, operation
and maintenanee of
the extraction wells
arid C1WTF should
continue to contain
the plume, and
investigations
should continue to
determine what
improvements, if
any, need to be
made, following
completion of the
investigations, a
meeting between
EPA and MassDEP
is recommended to
discuss the results
of the
investigations, ICs,
as noted in a
pre\ ious
recommendation,
should also be
implemented to
ensure that no
private wells are
installed at or near
the site.
HP A/State
EPA 9/29'2019
No
Yes
44
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OH #
¦-
Issue
KirimimriHhttimts
follow-up Actions
Party
Responsible
Oversiuhl
Agency
Milestone'
Date
Affects
Protectiveness?
(Y/N)
< ut rent
Fit lure
3
The 20] 3 sediment
data show
exeeedances of'the
PAI I cleanup level at
a sampling location
adjacent to the site.
The exeeedanee at
the location adjacent
to the .site dues not
impact current
protectiveness since
the area is within the
site perimeter fence,
Further monitoring
should be
performed tor
confirmation of the
exceedance.
EPA/State
EPA
12/3) <201X
No
Yes
3
Elevated
concentrations of
I'M In and pesticides
in samples from Ice
Pond and Mary Lee
Wetlands indicate
some uncertainty in
the distribution of
these contaminants
along the banks of
the river and
wetlands
downstream of the
site.
In order to confirm
the protectiveness
of the remedy, the
soils and sediment
downstream of the
site should be
further sampled and
evaluated prior to
the next Five Year
Rev Sew.
Sttiie
HP A
1J 31 201K
N
¦V
45
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VI, PRO II C 11% IMS.S SI \IIM1 M
Pru(iTti\ flit s'* MaUnuiH(s)
Operable ("nil. Proleviiveiiess Ikienninaiion: Addendum Due Pate
Ol11 Short-term Protective (if applicable)
I'rokx livettesx Statement;
I Ik- remedy ai Oil-1 currently protects human health and the en\ lronmcnt because the current
pathway for human health exposures has been eliminated as the contaminated aquifer is no
longer being used as a drinking water source. The aquifer is being remediated to mitigate a
future human health exposure pathway However, in order for the remedy lo be protective in
the long-term, groundwater should not he used for any purpose or directly contacted, due to its
contamination and to the negative impact pumping could have on the effectiveness of the
extract ion and treatment system. Comprehensive institutional controls at the site, including
GUI, must be implemented to ensure long-term protectivene-ss in and around the site.
PrutectivciKss Statementi*
Operable ( mi: Protect tvenes.s Determination: Addendum Dae Date
OU2 Short-term Protective (if applicable)'
Proicctivencas Statement;
The remedy at OU2 currently protects human health and the environment. As long as the Site
is not used for residential purposes or other purposes where children are present at a high
frequency (e.g., day care or parks), human health protect iveness will be within the risk-based
concentrations established by EPA. Proteetiicness is achieved for future workers in a
commercial or industrial use scenario. However, in order for the remedy to be protective in
the long-term, comprehensive institutional controls should be implemented or an evaluation
should be performed to determine the potential risk to workers prior to initiating intrusive
activities as part of site re-development
46
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Protect iveness Statcnu'iH(>)
Operable I "nil:
Protectivenes.s Diiermiiui/km:
Addendum Due Date
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vii. \i.\ r kt;\ si w
The next five-year re\ iew report lor the Baird & Mctiuire Super fund Site is required five years from the
completion date of this review.
4S
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APPENDIX A - EXISTING SITE INFORMATION
A. SITE CHRONOLOGY
Table A-1: Site Chronology
TV-iit
Date
Baird & McGuire Inc. operated a chemical mixing and batching
company.
1912 - 1983
Commonwealth of Massachusetts becomes involved and fines the
company at least thirty-five times for violations of the Federal
Insecticide. Fungicide and Rodenticide Act of 1947(FIFRA)
1954 - 1977
Massachusetts Department of Environmental Quality Engineering
{DEQE f (currently Department of Environmental Protection, or
MassDEP) documents a number of questionable disposal
practices
1981 - 1982
Baird & McGuire Inc. carries out a number of voluntary remedial
actions.
South Street municipal well field shut down.
February ¦ April 1982
1982
The Board of Selectmen of Hoi brook revoke Baird & McGuire s
permit to store chemicals at the Site and order the dismantling of
existing storage facilities. As a result operations were terminated.
May 2, 1983
The Site is added to the National Priority List (NPL).
September 8, 1983
EPA begins removal actions including removing 1,000 cubic yards
of contaminated soil, the constructing of a clay cap installing a
groundwater interception/recirculation system and erecting some
fencing
1983
EPA constructs a security fence to enclose the site.
Remedial Investigation {Rl) performed by GHR Engineering
Associates,
Feasibility Study (FS) performed by GHR Engineering Associates.
EPA issues the first ROD which specifies groundwater extraction
and treatment via an on-site treatment plant (OU-1) and soil
excavation and treatment via an on-site incinerator fOU-2).
EPA issues the second ROD to address contamination in the
Coehato River sediments (OU-3),
July 1985
May 1985
1986
September 30. 1988
October9. 1389
EPA issues the final ROD that calls for reopening the Donna Road
well field to replace the lost supply resulting from contamination of
the South Street wellfield (GU-41
A groundwater treatment facility (GWTF) and extraction/recharge
system is built (OU-1} and treatment of groundwater begins
Removal of contaminated sediments from the Coehato River by
_ the New England Division of the UJ3 Arm^ Corps of Engineers
September 27, 1990
1991 to present
May 1994 - June 1995
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Event
l") air-
(OU-3)
Source control remedy to remove and treat contaminated soils
(OU-2) and on-site disposal of OU-? soils and OU-3 sediments
June 1995 - July 1997
LNAPL recovery system is constructed and becomes operational.
1998
Completion of the first Five-Year Review for the Site
September 1999
A Remedial System Evaluation (RSE ) is completed for the GWTF
January 2002
EPA signed two ESD documents for OU-1 and OU-4. allowing for
partial funding of an off-stte municipal water supply expansion
project.
August 2003
MassDEP assumes site-wide O&M responsibility from EPA,
June 2004
Completion of the second Five-Year Review for the Site
September 2004
EPA issues an ESD for Institutional Control
April 2QC
MassDEP completed contractual agreement with
Randolph/Holbrook Water District for alternate water supply
capacity
June 2008
Completion of the Third Five-Year Review for the Site
September 2009
EPA conducts an optimization review to identify actions that may
be taken to improve the effectiveness and cost-efficiency of She
remedy
May 2013
Arsenic Summary Investigation Report produced
February 2014
B. BACKGROUND
Physical Characteristics and Land and Resource Use
The Baird & McGuire Superfund Site is located on South Street in Holbrook, MA (Figure 1 in Appendix
B). The 1986 ROD defines the Site as the area within the EPA security fence constructed in July 1985.
According to the FS, this fence encompasses all known areas of soil contamination related to Baird &
McGuire (GHR, 1988a). The Site boundary and coincident fence line are shown on figure 2, based on
a Site survey conducted in May 1988. The Site designated on Figure 2 has been determined to consist
of approximately 32.5 acres. For the purpose of increased security and access control measures
during remedial actions, additional fencing was constructed in some areas beyond the Site boundary.
This includes fencing around the groundwater treatment plant and recharge basins, and fencing beyond
the southern Site boundary.
As illustrated on Figure 2, the Site is not limited to land within the former Baird & McGuire properties.
Historically, Lots 130, 130-1 and 130-2 have had Baird & McGuire ownership, These lots consist of
9,33 acres, of which approximately 8 acres are within the Site boundaries. The remaining 24,5 acres of
the Site consist of portions of five privately owned lots and two tots jointly owned by the towns of
Holbrook and Randolph, In addition, four privately owned lots located west of the Cochato River (Lots
6, 12-2 and 12-3) have restricted access to the river due to the presence of the security fence.
Figure J also shows significant ecological Site features, including the Cochato River, the unnamed
brook, the 100-year floodplain, and wetland areas. Based on a wetland boundary delineation
conducted during Rl investigations, wetlands occupied approximately 44 percent of the Site. In
addition, 88 percent of the Site was determined to be within the 100-year floodplain (GHR, 1988a),
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At the time of the ROD, the Baird & McGwire Site was used for commercial and industrial purposes.
Currently, the Site is occupied by the Groundwater Treatment Facility. Current and planned uses are
still commercial/industrial in nature.
Hydrology
The onsite geology is representative of processes associated with glaciation. The geologic units include
bedrock, till, outwash deposits of stratified sands, gravel and silts, organic soils, and fill materials.
Glacial till and bedrock are found in the topographically high areas of the Site. In the topographically
lower portions of the Site, fill arid stratified sands gravel, and silt deposits overlie unstratified glacial till.
In the wetland areas and topographically low areas of the Site, the stratified deposits are overlain by
organic soils. In general, stratified sediments are underlain by till over weathered bedrock. In the
eastern portion of the Site, near the Cochato River, the total thickness of stratified material is
approximately 50 feet (GHR 1986). The till is underlain by two igneous rock units: granite, apparently
part of the Dedham Granodiorite Formation, and Salem Sabbro-Diorite. The bedrock formations are
variable in competency between highly weathered and fractured in certain areas of the Site, and
competent in other areas- The 1988 Feasibility Study (FS) indicated no major faults or other structural
features were reported at the Site or the surrounding area (GHR 1988).
Prior studies conducted at the Site reported on the hydrogeologic properties of the subsurface materials
underlying the Site. The characteristics of the soil and bedrock at the Site, in terms of hydrogeology,
are critical to an understanding of the fate of contaminants that have entered the aquifer at the Site.
Based on information in the FS, average values of hydraulic conductivity of the principal overburden
units at the Site are 1 x 10-3 cm/sec for silty sands, sand, and silt; 1.8 x 10-2 cm/sec for fine to medium,
and fine to coarse-grained sands; and 3.5 x 10-3 cm/sec for glacial till.
A Conceptual Site Model {CSM) was developed by SAIC using previous documents by M&E (M&E
1999, M&E 2001 through 2004), USEPA {USEPA 2004), and GHR (GHR 1988). The CSM was
presented in the 200? Sampling and Analysis Plan {SAIC 2007). In general, the CSM considered the
following to be representative of the aquifer at OU-1:
• The saturated zone of the OU-1 aquifer consists of four layers. The upper portion is a zone of
relatively permeable stratified clean sand and gravel with a trace of silt to silty sands with little
gravel, This stratified sand overlies a zone of unstratified glacial till. Beneath the till and portions
of the stratified sand is a deposit of weathered and intact bedrock. In addition, localized deposits
of organic, sandy silt are present in the upper layer near the Cochato River (M&E 2001 and
GHR 1988).
• The upper aquifer at OU-1 exhibits the characteristics of unconfined groundwater flow.
• Groundwater flow is fo the east-northeast across OU-1 in the upper unconfined aquifer and
bedrock.
The continuous pumping of the groundwater remedial system appears to have a localized effect on the
groundwater flow in the upper unconfined aquifer. Groundwater flow in the bedrock does not appear
to be affected by the continuous pumping of the groundwater remedial system. In addition, there are
localized areas of groundwater flow to the east toward the Cochato River (U.S. Geological Survey
[USGS] 1999).
History of Contamination
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Baird & McGuire Inc. operated a chemical mixing and batching facility in northwest Holbrook,
Massachusetts from 1912 to 1983. Manufactured products included herbicides, pesticides,
disinfectants, soaps, floor waxes and solvents. Waste disposal methods at the site included direct
discharge into the soil, a nearby brook and wetlands, and a former gravel pit in the eastern portion of
the site. Underground disposal systems were also used.
The state became involved between 1954 and 1977 and fined the company at least thirty-five times for
violations of the Federal Insecticide, Fungicide and Rodenticide Act of 1947 (FIFRA), In 1981 and 1982
the Massachusetts Department of Environmental Quality Engineering (DEQE) documented a number of
questionable disposal practices. Baird & McGuire Inc. performed voluntary remedial actions from
February to April of 1982. In May 1982, the Board of Selectmen of Holbrook revoked Baird &
McGuire's permit to store chemicals at the Site and ordered that existing storage facilities be
dismantled. As a result operations were terminated.
Initial Response
A hydrologtcal study was completed by EPA which initiated some removal actions in 1383. These
actions included the removal of 1,020 cubic yards of contaminated soil, 1 ton of waste creosote, 25
gallons of waste coal tar, 155 pounds of solid hazardous waste and 4? drums of flammable liquids and
solids, and 2 drums of corrosives. EPA also oversaw construction of a clay cap, installation of a
groundwater interception-recirculation system, and erection of fencing. The Site was added to the
National Priority List (NPL) on September 8, 1983, EPA constructed a security fence in July 1985 to
enclose the Site,
An RI/FS (1985/1986a, GHR) identified and described the presence of a groundwater contamination
plume, originating from the Baird & McGuire property and extending beyond the Cochato River. EPA
issued three RGDs for the Site, defining four operable units and describing selected remedial
alternatives. The first ROD, issued in September 1986, specified groundwater extraction and treatment
at an on-site treatment plant (OU-1} and soil excavation, treatment at an on-site incinerator, and
disposal of ash on-site (OU-2). The second ROD, issued in September 1989, addressed contamination
in the Cochato River sediments (OU-3). EPA issued the final ROD in 1990, which called for reopening
the Donna Road well field to replace the lost supply resulting from contamination of the South Street
wellfield (OU-4).
Basis for Taking Action
The following summarizes the contaminants detected at the Site, as identified in the Rl and during
subsequent investigations.
Soil. Contaminants such as volatile organic compounds (VOCs}. poiycyclic aromatic hydrocarbons
(PAHs), other organic compounds, pesticides, dioxin, and heavy metals such as lead and arsenic have
been detected in soils across the site, Dioxin also has been detected in area wetland soils. Although
the Site was fenced off, both direct contact and accidental human ingestion of site soils posed an
imminent threat to human health due to the high levels of pesticides and dioxin, as identified in the Rl,
Groundwater. During the Rl, VOCs, SVOCs, PAHs, pesticides, and metals (arsenic and lead) were
detected in site groundwater and downgradient of the site, beyond the Cochato River. Direct contact or
accidental ingestion of groundwater posed an imminent threat to public health. The contaminated
groundwater resulted in the shut down of public wells (South Street well field). In a subsequent
investigation, conducted by EPA in 1997, it was confirmed that light non-aqueous phase liquids
(LNAPL) exist near the center of the plume. LNAPLs. undissolved chemicals that are less dense than
water and thus float on top of the groundwater, have been determined to be a continuing source of
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contamination in groundwater at this site, Groundwater monitoring has continued to indicate the
presence of VOCs, SVOCs, pesticides, solvents, arsenic and other inorganic chemicals.
Sediments. Contaminants of concern, detected in Cochato River and Unnamed Brook sediments at
the site, include VOCs, PAHs, arsenic, and pesticides including DDT and chtordane. The
concentrations detected were greatest in the portions of the river on Site and approximately 500 feet
downgradient of the existing site fence. These sediments were determined to be acutely toxic to
aquatic life (EPA. 1989); and were associated with an excess cancer risk level in excess of 1x10(-6).
These conclusions formed the basis of the selected remedies (past and present) for the Site as outlined
in the RODs. See Section C for additional details.
C. REMEDIAL ACTIONS
Remedy Selection
EPA issued three RODs for the Site, defining four operable units and describing selected remedial
alternatives. The first ROD, issued in September 1986, specified groundwater extraction and treatment
via an on-site treatment plant (OU-1) and soil excavation and treatment via an on-site incinerator (OU-
2), The second ROD, issued in September 1989, addressed contamination in the Cochato River
sediments (OU-3). EPA issued the final ROD in 1990, which called for reopening the Donna Road well
field to replace the lost supply resulting from contamination of the South Street weltfield (OU-4)
The following sections summarize the selected remedies for Operable Units 1,2,3, and 4.
Operable Unit 1
The remedial objectives for OU-1 groundwater are:
• Remediate the contaminated aquifer within a reasonable time period to prevent present or
future impacts to groundwater drinking supplies;
• Protect surface waters from future contaminant migration; and
• Minimize long-term damage and/or maintenance requirements.
The selected remedial action for OU-1 includes the following components:
• Groundwater Extraction System;
• On-site Groundwater Treatment Facility; and
• Groundwater Recharge System.
The current system consists of eight extraction wells (EW-2, EW-3. EW-4A. EW-5 EW-6, EW-7, EW-8.
and EW-9) that pump contaminated groundwater to a groundwater treatment facility, and four recharge
basins for discharge of treated groundwater back to the aquifer. Extraction wells EW-t and EW-4 are
currently off-line. The groundwater extraction wells were located to contain the plume.
Operable Unit 2
The remedial objectives for OU-2 soil were:
• Minimize the risk to the human population from direct contact with contaminated
soils/sediments;
• Protect surface waters from future contaminant migration; and
• Minimize long-term damage and/or maintenance requirements.
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Based on the nature and extent of soil contamination documented in the RI/FS, the 1986 ROD
specified the excavation of soil from "hot areas" with subsequent treatment in an on-site incinerator,
and on-site disposal of the treated soil (ash). The hot areas were delineated in the ROD based on
contamination profiles developed in the Rt Addendum (GHR. 1988b}. The limits of excavation were
established so that contaminant concentrations outside of the hot areas were one to two orders of
magnitude lower than the concentrations inside the hot areas. Also considered was the presence of
wetlands and the extent of contamination in those wetlands, with the intent of minimizing disruption to
wetlands. The ROD notes that although this approach results in residual soil contamination, future
health risk for a trespasser scenario would be within an acceptable range.
The selected remedial actions for QU-2 include the following components:
• Excavation with associated dewatering and erosion control;
• Backfilling using treated soil into the excavation area;
• Extraction Well Piping Relocation at the end of the excavation process;
• Temporary relocation of the Unnamed Stream during remediation followed by restoration of its
natural course;
• On-Site Incineration and Stabilization (IS) Facility;
• Site Closure upon the completion of soil excavation and treatment;
• Site Restoration;
• Wetlands Restoration; and
• Continued Monitoring.
Operabie Unit 3
The remedial objectives for OU-3 (sediment in river) were:
• Reduce human exposure to arsenic. DDT, PAHs, and chlordane in sediment by excavating to
an average depth of six (6) inches and by achieving the following levels of contaminants; 260
ppm for arsenic: 19 ppm for DDT; 5 ppm for chlordane; and 22 ppm for total PAHs. These
concentrations correspond to a 1 x 10to 1 x 10 excess cancer risk level; and
• Reduce environmental exposure to those contaminants of concern to concentrations
corresponding to the mean sediment quality criteria (SQC) (EPA, 1989) in the river bed, and to
the upper bound SQC in the wetland area north of Ice Pond.
The ROD specified excavation and incineration of approximately 1,500 cubic yards of contaminated
sediments for protection of public health and the environment. Sediments were to be excavated to an
average depth of six inches from approximately the center of the fenced Site area downstream to Union
Street. Sediments were to be transported to the on-site treatment facility, implemented under OU-2.
and subsequently placed as backfill on the Site.
The ROD also required erosion control, wetlands restoration, placement of organic fill in the excavated
areas of the river in the vicinity of the groundwater plume and long-term monitoring of downstream
portions of the river where sediments were not excavated.
To minimize the disruption of wetlands, sediments were not to be removed from areas of the river
where contaminant concentrations were low, calculated risks were low, and no impacts were observed.
Sn accordance with the ROD for OU-3, long term monitoring is to be conducted to evaluate remaining
contaminant levels and their behavior over time (EPA. 1989),
Operable Unit 4
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The remedial objectives for QU-4 were:
• To identify a candidate water source to replace the 0 31 million gallons per day (MGD) lost
supply from the closing of the South Street municipal well field in an environmentally sound,
cost effective manner without placing additional stress on the Great Pond Reservoir system or
existing water treatment facilities.
The selected remedy for OU-4 consisted of the following components
• Permitting/Pre-design Studies;
• Groundwater Extraction;
• Groundwater Treatment; and
• Delivery to the Distribution System
On August 21, 2003, an Explanation of Significant Differences document (ESD) was issued for the
groundwater remedy (OU-1) specified in the 1986 ROD. The ROD was changed to include excavation
of soil from the Upper Reservoir/Great Pond located in Braintree and Randolph {approximately 400,000
cubic yards) to provide an additional storage capacity resulting in an estimated additional supply of 0.31
MGD to be used in the interim to supplement the community's drinking water until the groundwater
remedial action is complete. On this date, EPA also issued an ESD document for OU-4 stating that no
further action will be taken under this ROD.
Remedy Implementation
This section presents summaries of the remedial actions conducted or being conducted at the site in
accordance with the RODs' objectives.
OU-1 Remedy Implementation
The groundwater remedy at the Site is ongoing. A groundwater treatment facility (GWTF) and
extraction/recharge system were built in 1991 and remain in operation, with modifications.
The three main components of the groundwater remedy are extraction, on-site treatment, and recharge
as specified by the 1988 ROD.
Groundwater Extraction. The groundwater extraction system consists of eight extraction wells (EW 2,
EW-3, EW-4A, EW-5, EW-6, EW-7. EW-8, and EVV-9) Operation of EW-2 was discontinued in 2006.
The remaining wells operate at flow rates ranging from less than 1 to 21 gpm (Clean Harbors, 2009).
Well EW-9 has not operated properly since installation, producing a very low (<1 gpm) flow rate. The
extraction well locations are shown on Figure 3. The system was originally designed to pump at a
maximum total rate of 200 gpm. During the period of July 2008 to September 2007, the system pumped
an average of 87 gpm. The wells pump the groundwater via separate pipes to an extraction well
control building, located south of the extraction system, where the water converges to a single header
pipe that conveys the water to the GWTF. All extraction system controls (e.g.. valves, flow meters,
electrical switches) are housed within the extraction system control building. The wells are operated
remotely through use of a programmable logic controller (PLC) located at the GWTF.
Figure 3 also shows the locations of the numerous monitoring wells that exist at the Site. At many of
the monitored locations, multiple wells have been constructed. These well clusters allow water levels
and water quality to be determined at different depths in the stratified drift deposits, in the till deposits
and weathered bedrock zone, and in the underlying fractured bedrock. Data gathered from the
monitoring wells are used both to develop groundwater contour maps from which the area of capture of
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the extraction well system can be inferred, and to monitor the improvements in water quality resulting
from groundwater extraction and treatment.
LNAPL Collection. As an enhancement to the groundwater extraction and treatment systems, LNAPl
is pumped directly from 3 wells (EW-8, MW-97-1, and MW-98-1) to a separate collection tank. The
recovered LNAPL is disposed off-site. Until June, 2004, the LNAPL was mixed with an absorbent,
crushed corncobs, prior to off-site disposal. The State is currently shipping the LNAPL off-site in liquid
form. The LNAPL system is currently operated intermittently, when dissolved phase is noted to be
presented.
Groundwater Treatment. The Groundwater Treatment Facility (GWTF) is located off South Street as
shown on Figure 3, All unit operations are contained in the same building including:
• Metals pretreatment consisting of potassium permanganate to remove heavy metals and
arsenic, and the addition of polymer to enhance iron removal;
• Filtration for removing suspended solids carried over from the metals removal process;
• Granular activated carbon (GAC) adsorption for removing organic compounds;
• Sludge dewatering used for decreasing the water content of the metals hydroxide sludge;
• Metals hydroxide sludge disposal in a RCRA hazardous waste landfill; and
• Vapor phase carbon adsorption for treating off-gases from various tanks.
Monitoring points throughout the system allow for in-line instruments to measure flow and indicator
parameters, and allow for the collection of samples for off-site laboratory analyses. The GWTF
operation is currently staffed 10 hours a day, 7 days per week. Groundwater is treated to meet the
SDWA MCLs.
Groundwater Recharge System. Treated water from the GWTF is recharged back to the
groundwater through four infiltration basins (each 100 feet by 100 feet). Water is discharged to one
basin at a time while the other three basins remain inactive. Discharge is rotated on a weekly basis to
other basins to prevent overuse of any one basin and allow maintenance of a particular basin if
recharge capacity is diminished.
OU-2 Remedy implementation
The selected remedy for OU-2 consisted of soil excavation and incineration, erosion control,
dewatering, backfilling of incinerated material, relocation of the unnamed stream, site restoration,
wetlands restoration and monitoring.
This source control remedy (removal and treatment of contaminated soils) commenced in June 1995
and was completed in July 1997. All soils excavation and treatment facilities have been
decommissioned and removed. To summarize, the OU-2 remedial activities consisted of:
• Approximately 248,000 tons of soil and sediment were excavated and treated by on-site
incineration. Soils were excavated to approximately one foot below the seasonal low water
table within the excavation limits, with excavation depths ranging from approximately 3 to 33
feet below grade,
• Approximately 250,000 tons of the treated soil (i.e.. ash) were backfilled into the 12.5-acre
excavation area;
• TCLP tests were performed on the ash, and approximately 320 tons of ash which failed the
leaching criteria were stabilized with cement prior to backfilling to reduce the potential for
leaching of contaminants;
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• The incinerator building and equipment were demobilized and removed from the site and the
incinerator building foundation was crushed and buried on-site; and
• Approximately 7-4 acres of forested and scrub/shrub fioodplain wetlands underwent on-site
restoration, including a small peat bog and 1,000 linear feet of the unnamed brook,
EPA and M&E concluded from the site visit conducted for the first five-year review that, although the
wetland was not restored with the organic soils recommended in the final Restoration Plan, the
mitigative measures required by EPA and USAGE were met. Initially, the wetland was monitored
annually in order to assess the success of the wetland restoration effort. During the site visit on June
23, 2009, it appeared that the restored wetland was well established and in good condition.
QU-3 Remedy Implementation
The remedy for OU-3 involved removal of contaminated sediments from the Cochato River. This
remedy commenced in May 1994 and was completed in June 1995. Major components of the
sediment remedy were site preparation, sediment dredging, placement of organic fill and monitoring.
In preparation for river excavation, the river banks were cleared and grubbed. A detention basin was
built in the river just downstream of the Union Street bridge to trap suspended sediments during
dredging and was subsequently removed. Temporary haul roads were constructed and then removed
after testing showed no residual contamination. Sediments were dredged from a 2,100-foot reach of
river extending from the Batrd & McGuire Site to the Union Street bridge. Sediments were dredged to a
minimum depth of six inches and a maximum depth of 24 inches in some areas. Dredged material was
placed in sealable containers and transported to the Baird & McGuire exclusion zone where it was
stored for subsequent incineration. A total of 4,712 cubic yards of material were removed from the
river. Dredged material was transported to the IS facility, incinerated anc placed as backfill within the
OU-2 soil excavation area. Wetlands adversely impacted by the dredging and the installation of haul
roads were restored under the OU-2 Final Restoration Plan.
The portion of the river where contaminated groundwater underlies the riverbed was backfilled with
approximately 438 cubic yards of clean organic fill. This organic fill acts as a filter which will attenuate
contaminated groundwater that may discharge into the river.
Following completion of the remedy, EPA implemented a long term monitoring plan of the Cochato
River downstream of the dredged area including analyses of sediment and fish. The plan includes
collection and analysis of sediment samples annually for the first five years and fish samples every 5
years, followed by a review of the data and trends. Sediment samples were last collected in 2002.
QU-4 Remedy Implementation
The ROD for OU-4 was issued to address alternate water supply/replacement of lost supply that
resulted from the contamination and subsequent shutdown of the South Street well field, which was
part of the water supply for Holbrook in 1982. The reactivation of the Donna Road well field was
selected as the alternate water supply.
In 2001, EPA provided funding to MassDEP through a Cooperative Agreement to assist the towns of
Holbrook and Randolph in expanding existing water capacity at the Upper Reservoir/Great Pond.
MassDEP actually provided the funding (along with its 10% RA cost share) for the project to the local
water board through a contract. This was addressed in an ESD document in August 2003 for the
groundwater remedy (OU-1} EPA believes the increase in additional drinking water capacity of the
Upper Reservoir/Great Pond as provided by the ESD document for OU-1, should be sufficient to
eliminate any interim risk until interim cleanup levels are met for the groundwater remedy. As a result,
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the reactivation of the Donna Road welffteid was determined to be not necessary. Thus, an ESD
document was issued on August 21, 2003 for OlM. which states that EPA will not implement the
selected OlM remedy and no further action will be taken under GU-4.
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APPENDIX B
FIGURES
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|\J Ho,fbtmk,m
^ KksGIS Scanned OSGS Quae* \
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\
\\
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¦¦
Site Boundary
' and Perimeter
Security fence
t/
Goch'ato. River
SO
¦..XN»
>
.. s
—J \
Groundwater
Recharge,
Basins ,
i ¦'% •
• ; Town
ar .~*
V
-Treatment \\^
P acility
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.
-
- •
*•»
'V, **.
YA X\
*****
/
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A\
LEGEND
Limits of Excavation
— » — "
Property Lines
Site Boundary
Additional Fencing
___
Road*
Streams
Extraction Piping
EW ~
Extraction Well
*
Town Well
MW •
Monitoring Wei!
Ponds and Walerbodies
MAP SOURCE,
Base Map is from Eustem Topographies
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FIGURE. 4
¦
©
September 2014
A^ern
BAIRD & MCGUIRE
FISH ADVISORY
SIGN LOCATIONS
300
600
l Feet
1 inch = 600 feet
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\PPK\IIIX C
I IS I I >1 !)()( I MINIS Rf \ if \\ in \\|» HI si RJ \( I s
Clean Harbors Environmental Services (CUES), 2010. Evaluation qfOrmmdmiter Remediation
Progress, Annual Report ()pe ruble ('iiit-l, October 1, 200$ through Sept em her SO, 2009,
Baird tV MeChiire Super/anil Site. Prepared lor Massachusetts Department oi l in ironmcntal
Protection. September 27. 2010.
Clean Harbors Environmental Serviees (CI U S), 20! 2. l:\altiaiioii ofOroiimbvater Remediation
Progress, Aiuniui Report Operable I'nit-1, October I, 20(N through September 30, 2010,
Ha in I & \fe( dure Superfuikl Site. Prepared for Massachusetts Department of Environmental
Protection. February 28. 2012.
Clean Harbors Environmental Serviees (CUES), 2015a. Evaluation ofOrouiuhvatcr
Remediation Progress, Animal Repon - Operable Unit-1, October I, 2010 through September
30, 2011. Baird <<- MeCntire Snperfiind Site, Prepared for Massachusetts Department of
Environmental Protection. February 11, 2013.
Clean Harbors Environmental Services (CHES), 2013b. Letter Re; Work and Cost Plan
Extraction Well EW-10 installation, Baird & Metiuire Super fund Site, Prepared for
Massachusetts Department of Environmental Protection. Revision 1: June 8, 2013.
Clean Harbors Environmental Services (CUES), 2013c. Quarterly Extraction Well Report, 4,h
Quarter 2012, Baird & McGuire Supcrfund Site. Prepared for Massachusetts Department of
Environmental Protection. Revision 1: June 21, 2013.
Clean Harbors Environmental Services (CUES), 2013d. Evaluation of (iroundwater
Remediation Progress, Animal Report Operable Unit-1, October I, 2011 through September
30, 20J2, Baird ct ,\ leCttire Superfnnd Site. Prepared for Massachusetts Department of
En\ironmental Protection. November 1 I, 2013.
Clean Harbors Environmental Services (CUE'S), 2014a. . Irseitte Summary Investigation Report
Part 11 Ha, Baird <{• MeCntire Superfnnd Site, Prepared for Massachusetts Department of
Environmental Protection. February IS, 2014
Clean Harbors Environmental Services (CHES). 2014b. Quarterly Extraction Well Report, 3n"
Othtiier 20/3, Batrd Me(dure Super/ami Site. Prepared for Massachusetts Department of
Environmental Protection. February 18, 2014.
Clean Harbors Environmental Services tCEIF.S),20l4c. Ouorterly Extraction Well Report, 4"!
Ouarter 2013. Baird S McUaire Superfnnd Site. Prepared for Massachusetts Department of
Environmental Protection. 2014.
Clean Harbors Draft Summary of EW-10 Installation (CUES), 20l4d
Environmental Strategies & Management (ES&ME 2014. Final (hehato River Sampling
Report, October 2013, SARSS V Baird A- MeCntire Super fund Sue, i'oehato River investigation.
Prepared for Massachusetts Department of Environmental Protection. February 24. 2014.
til IR Engineering Associates (GHR). 1^86a. Etna I Feasibility Stiuly Report, Baird Mc( iuire
Site, Holhrook, MA, Prepared for NUS Corporation, and ELS. Environmental Protection Agency.
July 18. 1986a.
GHR Engineering Associates (< IHR) I c)S6b, Final iddenditm Report, RemeiHal Investigitttim
Phase If June 1986.
Metcalf & Eddy, Inc. (M&E). 1QQ8. Evaluation of Potential Future Reuse Opportunities for the
Baird & Med aire Site. Prepared for the U.S. Environmental Protection Agency. June 5, 1998,
-------
Metcalf & Eddy, inc. (M&F), 1 999. Final / )ve- Year Review for the Haird and Ski in ire
Superfund Siie, Prepared for the U.S. Environmental Protection Agency, September 1999.
Metcalf & Eddy, Inc. (M&F), 2001. Evaluation of Groundwater Remediation Progress at file
Baird A' \fcGnire Siiperfiim/ Site. Prepared for the U.S. Environmental Protection Agenes.
January 2001.
Metcalf & Eddy. Inc. (M&F). 2002. Evaluation of Groundwater Remediation Progress at the
Hatrd $ AfcGnirc Snperfiiikl Sue. Prepared fur the t '.S. Environmental Protection Agenev
March 2002,
Metcalf & I:ddy, lite, (M&F). 2003. Evaluation of Gnmndwater Remediation Progress at the
BatrJ
-------
APPENDIX D
ANALYTICAL RESULTS
-------
GROUNDWATER ANALYTICAL RESULTS
-------
iP 1 Suuim.jfv ut L'013 Gr(jur>-1«;ilci AnMvttoil Dou
loirtriiiifci (torn Cluan Hartv.ita Erivirctnniomal Serves)
Knit- 1 m| 4
-------
Tatite 0-1 Summary of SopUumbor 2013 Gmmtmt* Analytical Date
(obtoirtiicl from Clean Mat-tats Enwicwwwtal Services)
WELL
9HA*
BM-7
BM-7
(DUP-1)
BM-8"
BM-13B"
BM-18R
MS-T"
MW04-02
MW97-9
MW87-9
MW97-10"
MW97-12*
MW97-13-
MW97-17
1 wft<
')i 1R/2013
WS/W":
£»'3D/201->
f»/)S'2013
3#18/20!0
9/1^201 .<
9/23,<2013
0'!'?„ 201 J
9/^0-20-13
9' 19/20* ^
9/10/2013
9'19-7013
0i'30/2Ct13
Blb-;2-tTHVtt-CXYL) PHTHALATE
1 56
...
1
2 et
<1 05
-
—
>-1.05
...
1 I?
CARBA20LE
• t Ofi
i no
<1 00
< I OS
- 1 00
...
..
< 1 05
RYSENE
< t 00
—
<1 00
<1.00
<1.05
—
—
<1 05
'1 05
DIBENZOFURAN
<1 00
—
—
<1 00
—
—
<1 00
<1 05
—
—
<1 05
—
—
4 01
DlCFH'it PHTHAiATr
1 (!,>!
..
...
1 00
1
* 1
* I Of;
-•
< 1 05
—
UO
FlUORAN"
i Hi.'
...
¦'1 0(1
| -
*1.00
«IM
...
..
'¦ 1 06
•-1 06
¦ JORI
<1.00
—
•" I tRI
—
<1,00
' I 0'.'
1 Ui>
«4i
¦ 3 i !.2,3-CDi PYRE'
<0 10C
<0 100
§ —
J-100
<0.105
—
<0 105
_
<0.105
NAPHTHALENE
•* ! 00 J
...
-'1 00
• 1 00
¦1 05
-
—
- I 05
...
I 19 6
NITROBENZENE
«-•*: 00 I
—
-1 *.>0
...
1,00
<1 05
-
-'1 05
_
<1 ns
JITROSODIPHENVL AMINE
__ | -
•- h t'»3
...
<5.00
;5 26
-
<5 20
PENTACHlOROPHENQL
_ ^ I ———
<1 00
..
....
<1.00
¦
..
< I 00
—
< 1,00
PHEMANTHRENE
<< .00
—
—
1 00
—
—
<1.05
—
<1 05
—
-
2.34
PHENOL
—
—
56 9
VOC iug/L)
1
1 2.4-TRIMETHYLBENZENE
—
—
—
<2 00 1
—
<2,00
—
-
<2.00
—
1 I'-DICHLOROETHANE
I
_
"-2 00
—
-------
Table D*1 Summary of Sftptember 2013 G»uofi«Mar Analytical Dsla
(oMaiiwcl from Clean Harbors Eiwfronnwnlai Services)
| WELL
ftflW.97-18"
.
MW37-21
MW97-21 tOUP
1!
MW97-23
MA.-
MW97-25
(DUP-2)
MW97-27
MW97.29
Y.vV ¦ ¦
TripBiank j
1}:^:
¦ 'i
11 >
1-1.
9/20/2013
:0 ;•; ,.:0 ! '¦
•j
i .'"01.;( -! '•
I
L
^ t
1
¦
-25 j
2 m i'
¦ TP*f
<•¦.! 155
5 05 i!
...
<¦¦ 'OS
<0 *->;
o. i >¦><;
" ;
: lOOi'mvti
1'" ' . . - - , , i ¦ .
!
r ~
... 1 , ,
1
: ML 141.5 l
j. ;v:. ' -j?;
0.37«5 6d
j '¦'•^tNltOUlftL)
U . 04
i m
I 44
u 224
U 164
U, I 1 M
|
1 MERCURY
— I - I <0,000200
0 00O'252
....
...
...
1 Total Metals
9 264
: 37
1 34
0.376
0.769
0.234
0 224
0 164
0.175
—
| rcsitaDi-y ;«un.>
___JL
| SH
JL
4 4-DDD
—
...
. .253
<0.0255
<0,0255
—
0.312
0.0327
—
4 4-DDE
—
—
_
<0,0253
<0.0255
<0,0255
—
<0.0281
<0,0281
—
ALDRiN R —
_
—
0,0411
0.0428
0,0495
~
<0.0281
<0.0281
_
ALPHA-BHC
_
<0.0253
<0 0255
<0 0255
—
<0 0261
<0,0281
...
DELTA-BHC
| <0,0253
<0 0255
<0 0255
<0 0281
<0 0261
DIE LOR IN
0 <-»B3
o Qvm
il//.1'
-
23'
n 0//4
ENDOSULFAN 1
0,0711
--0 0255
<0.0255
—
<0,0281
<0.0281
ENDOStitFAW II
__
_
—
<0 0253
<0 0255
'0 0255
<0 0281
<0.0281
NDR ¦
...
...
...
<0 0253
METHANE
<1 02
<1 00
<1 00
_
<1 05
<1 OR
<1 01
•-1 14
"'1.03
...
[2-CHLOROETHYL) ETHER
<1 02
< I 00
<1 00
—
¦= 1 05
<1 06
<•1 0!
< I 14
<1 03
I
3 (2'CHLOROISOPROPYl.! ETHER
<1 02
-1 (SO
<1 00
t 05
< 1 Of.
¦-1 01
• 1 14
-1 03
j
Pjxjt- j •>! <1
-------
tattle [3-1 S,rrcmvifv v".t S«ptonb»?i 2013 Gfo»nrK>.'iU>r Ati.iivW.al Dfit/i
tottiani"Hl (tori! CI'Fdii Hattefh Envtronttn>nial » »»l
WELL
MW97-18"
MW97-21
MW97-25
MW97-25
(DUP-2)
MW97 27
MW97-29
MW97-31
Trip Blank
D.tU> Sa.npleit
it'20/2013
9/20/2013
3/20/20 Vi 9!iV201'l
20/2013
9/20/2012
y/23/201 i
9/20/2013
9/20/20* «
9/2:--.'201
Blb-(2-FiTHYLH£XYl i PHTHftLATE
1 1)4
<1.00
< 1 'Hi I ~
.'1 2
20 0
*.
1 61
CARBA701E
-1 02
2 62
__
<1.05
<1 Ofi
<1 01
* 1 14
1 oa
...
CHRYSENE
<1 02
<1 00
* 1.0c
<1 01
<1 14
< 1 03
...
To,*ai Semi Vviahifx
f 04
2 4
249 t
...
?t f
20 0
hiD
?.?e
206
VOC (Uflti
1
________
1,2,4-TR!METHYLBENZENE
<2 00
—
_
...
<> ou
<2 00 1 ^2 00
_
<2 00
1,2-OiCHLQROETHANE
<2 00
—
...
»*2 no
- 2 00
^ 00
_
...
<2 00
1,3.5-TRlME THYLBENZENE
<2 00
_
I
<2 »U
<2 00
- 2 00
_
<2 00
,2-QlCHLOROPROPANE
<¦2 00
..
*2 00
"2 00
<2 00
...
*-2.00
BENZENE
"2 CO
_
_
2 00
2 00
<2 00
CHLOROBENZENE
<2 00
—
—
¦-J. 00
-.2 00
<2 00
...
—
<2 00
ETHYLBEMZENE
<2 00
--
—
' 2 00
<2.00
<2 00
<2 00 |
ISOPROPYLBENZENE
<2 00
-¦
2 00
<2.00
-2,00
-
<2 00 1
METHYL TERT-BUTYL E CHER
2 (ii i
2 0.1
•'2 00
<2 00
_
<2 00
NAPHTHALENE
<2 00
-
<-2 HO
<'UC
-•2 00
_
coo" j
n-BUTYLBENZENE
<2.00
_
_
-2 00
<2.00
<=2 00
_
<2.00
n-PROPLYBENZENE
<2 00
—
<2.00
<2 00
<2 00
_
—
<2 00 1
;-8UTYLBENZENE
<2 00
...
...
..
<2,00
<2 00
<2 00
..
A
|M
8
' ZENi
<2 00
<2 Of.
-•2 00
< 2 00
2 00
ILOROETHEN
<2 00
--
--
_
<2 00
<2 00
<2 00
—
_
-i no
11UENE
*=2 00
-
..
....
<« "!¦'.»
<' 00
'.2 00
'.if, 00
XYLENES !TOTAL)
<2 00
...
—
<_ i U
<2.00
<2 00
_
-2.00
Total VolaMes
ND
—
—
—
ND
ND
ND
—
--
ND 1
f-'.iitc «S nl
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Page £ ot 6
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I Alii I l>-2;i
AUSI-:M< Sl't x IA f ION
BAiko & MC the MDL, but < the MRl . Result is reported and considered an estimate.
Total arsenic (EPA Method 60IOC). COD. TPH, and TOC analyses conducted by Geolabs. Inc.;
arsenic speeiation conducted by Brooks Rand Labs (EPA Method 1632)
-------
I ABU. l)-2a t continued)
ARShM< SIM ( IA J ION (I W 1(1. MW 14-01. anil MW 14 (12)
BAIKI) & MC<;i'IRKSI PKRI lNDSiTi,
Sample:
Arsenic Speciation
trivalent arsenic (III)
inorganic arsenic
pentavalent arsenic (V)
dimethyl arsenic (DMA)
monomethyl arsenic (VIMA)
i dditional I naiytieaI
chemical oxygen demand (COD)
tola! petroleum hydrocarbon (TPli)
total organic carbon (TOO
total arsenic
Monitoring it el! Held Screening Parameters
Oxidation Reduction Potential (millivolts)
pll |pi 1 units)
i:\V-iO MW 1-l~t.il MW 14-02
21.3 3.0? 812
82.2 3,33 810
60.9 <0.320 <6.40
<0.480 <0.018 <4.80
<0,373 <0.014 <3.73
•-25,000 <25,000 32,400
<156 <155 441
1.300 1,000 7,000
34.0 20 884
84.4 140.3 -36.1
6.15 5.51 ft. 10
Notes:
unit of measure is ug.'L = microgram per liter or as noted
Samples collected in March 2014
-------
SVOCs (concentrations in ppb) - 2011
-------
As (concentrations in ppm) - 2011
-------
VOCs (concentrations in ppb) - 2011
-------
SEDIMENT/SOIL AND FISH ANALY1ICAL RESULTS
-------
-------
TaWe IM Sediment/Soil Results for Common ContMHiiurai Parameters, 19N - 201A ami CwqnriMi w» Project Action Unto
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245
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mi le. tlt\
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r,2
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cc I'mul (Bank L
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ilj.' V.t'. iir>
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At Willi
nil1, kf, itr\
4"
,
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lis
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tH
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IS
Statuin I), NKsrv i t\ WeitamK {RI \cr 1 ne.iHiim< in-" tut aeh
¦ umm and >c:ir CM'cpl 2o|
\s ht*ri' ri"
1 I'lrial I' \IK
Hi! ii!. dl>
5 J OH
\n
i:>ii
10,0011
1J40
12,502
22.N001'
!JO| l"
1 I otal 1 >1)1
Hi! i.e. dr.
l, ?4l.
"Hi
2,4<>o
150
',.<»4'i
p,:
JJ4'1
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in-.' ki.*, dn
ND
*,)i
45
2") >)
so,'
>«.
1 141
IX
M.ltMt l>. Mal'V ! .CC Weiialhi's llllxk 1 tkalHHisi Itl
lui,' t'licll
i.iliuit .tihf 1,i.as c\Lo.'pl 2
••if
JM
124
2.^,2
IS
-
21 *
P.2
22J
\rseioe
nk< lg, iIn
Ki)
Hi1-'
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'
5 t)
s
'
0 1
\)'
1^
1 S.impimi; ui Suiion I bciran in 1
1 i ickl duplicate samples foe 2001 ami ?0<)2 Mine1, were combined prior to eitlcoLtUitn ,«f sChhw meraci-.
1 Srtltmeul seo.vntnt: %,ihic•> apph In met samples .nth
" Suil M-recnini.' \ nines apph tn hank sanl el al , -(Mil
t'CdSSI (! St f* \, :ihi7| hasetJ i>n llieli Mt.locnl.il Weit'lit >I1\1VU expt.Mtte in mammalian tnseenutu/tslttcw)
K'uSSt il'M PA. 20071 f.;»%cd on expos, iiv lt» nummtalian eaomuie (weasel!
! SI I * \. Rcl'ikd 5 I tokiL'tc.il Saeenmg I e\le\ ll SI l'\. 2oo5| liasetl .m evptt.iiie lit pkuiis
lettSM. < I SI 1* 2oo51 h.tsed mi cvpns.itc li> pi.mis
I hiihlpjliievl eeils c\eeeii €t>ii mr \e
-------
FIGURE 4
CONCENTRATION HI SI HIPUI ION GRAPHS
Baud MuGuire Hbh Jfamplmy
Cochatn River lnv»sHoain
Holt A. tvt/>
TOC Distribution
14 00".,
12 00%
10 00',"v
8 00%
% Dry
6 00% - Rivet
4.00% |j§ •Bank
2.00%
| : 9HB HHR
0,00^
I
Station A Station £ Stat«on 6 Station C Station H
Station
Figu.-e 4 1 Station Mean Concentrations tor TOC in River Sediment and Bank Soil Samples
Total PAH Distribution
90000 r
80000 j-
70000 j-
60000 j-
50000 4-
Ut/kg 40000 -j— " — < River
30000
10000
10000
0 :
Stiffen A Station f Station B Station C Stat on D
Station
I
.% Bank
Figure 4 2 - Station Mean Concentrations for Total PAHs in River Sediment and Bank soil Samples
5 ^ A R S & i-vires Bird fi&n Snriplir j flSH 5AMPL ING TABlErS'G'jh'.ifnin^-t Dis'1 ,Uut;on >JFiL.*!S els.*
A, f
" &¦ Mamgmmtt
-------
FIGURE 4
CONCENTRATION DISTRIBUTION GRAPHS
Ba"d Mij'june f-ish Sampling
Gechato River Invesiioaiion
HolbtoiA, WW
mg/kg
Arsenic Distribution
Station A Station E Station I
Station
Station C station D
figure 4,3 - Station Mean Concentrations for Arsenic in River Sediment and Bank Sort Samples
Total Chlordane Distribution
ug/kg
Station A Station E Station B Station C Station D
Switon
rtQufc 4 4 Statplii'j TISH >AMPI INb TAtlt £ 5 Omi Mi'ii" Out itxit.on gi ic'ii ,ls
,*»- IT,, rW»vv««,I,|»
mp- ntm
aanJBLaA, „
" &' rnwmgmmtt
-------
FIGURE 4
CONCENTRATION DISTRIBUTION GRAPhb
Baud Mi-Ginre !•
-------
FIGURE 4
CONCENT RAT ION DISTRIBUTION GRAPHS
Band McGuite F-ish Satnpitrw
Ccchato River Investigation
Total Chlordane
107
_ _ L
1J-* Station E 0 Station B
.static
0 - 0 8J 0 115
I
C////
fish Samples *Tatal ChlbrAme
figure4.6 , Concentration* of Total Ctitaxdaiie in fitft Tissue $#frtf»tes ColWM in OWnBer 2013
Total DDT
H«, Samples »Tot*IDt>T
figure 4 7 - Concentrations of Tolal DOT in fish Tissue Samples Collected In October JQli
S Cu-'^mors S A K ^ 'i i-sh s>iiTp k*q *¦ S' f V^HOi'G 1 ABL£b'Co"!?m'rT-i" - q'.torsj 5«
*¦* M'tnuycfrni
-------
TABLE 1
SAMPLING LOCATIONS AND ANALYSES
Bairci and (VlcGuire Site
Cochato River Investigation
Moinx -iiics SoTiphng Lck.,t::o! SJ>n>pic- Collection Oet.iils Ar>.-:!yrKT:! ^'ameters
PAHs by EPA Method 8270D,
Organochlorine Pesticides by
EPA Method 808IB,
Arsenic by EPA Method 6G20A,
Grain Sine by ASTM D422, and
Percent Solids by EPA Method
2540G.
Soili
Stations € and D
Three transects used at two
stations. One composite sample
was collected per transect.
TOCby EPA Method 9060',
PAHs by EPA Method 8270D,
Organochlorine Pesticides by
EPA Method 8081B,
Arsenic by EPA Method 6020A,
Grain Site by ASTM D422, and
Percent Solids by EPA Method
25406.
Stations A, B, €,, and E
{Station B is Sylvan Late)
At each of four stations (A. B, C,
and E), six or more fish were
collected to represent several
types of fish species - 3 fish each
of abundant and predatory were
preferred, fish greater than 60
grams in weight were preferred
to provide adequate sample
from fillet. Fish smaller than 60
grams were combined with
other fish of similar species and
size for compositing. Station C
was chosen over station D
because of access to fishing.
PAHs by EPA 8270D,
Organochlorine Pesticides by
EPA 8081B, and
Percent Lipids by NOAA
Methodology,
fish age determination by
examining fish scales and
pectoral spines (for scale-less
fish).
Stations A, B, C, D. and E
(Site B is the section of river that
runs parallel with Sylvan take)
five stations will be sampled.
Three (of nine) transects were
used at three stations (A, B, and
C) and one transect at stations D
and E. One composite sample
will be collected per transect,
Environmental
» Stmiegiis
& Mmugemmtl
-------
TABLE 2
GPS COORDINATES FOR SAMPLING LOCATIONS
Baird and McGuire Site
Cochato River Investigation
October 2013
bir'" 11>;r-' i.-u .itn'!":
; .ifi'idc IN r >: t hi
! CN'MUOi.1 { Vv "si 1
A1
42WS8 68820"
71"01'23.79837"
A2
42°08'58.77351"
71"01'24 88Q97"
A4
42 08'58.91187"
7 i'01'26.09673"
A5
42"08'59 01855"
?r01'2? 022/6"
A6
42"08'59.13384"
71"01'28 01546"
A7
42"08'59 39053"
71*01'28 77968"
A8
42"08'59.58336"
71*01'29.38427"
A9
42n09'00.01520"
71"01'29.83190"
42 09'22 79
71°01'34.61762"
B2
42W23.17730"
? 1"01'34.35254"
B3
42°09'24.03501"
1.21767"
B4
42a09'24 33880"
7r01'34 15913"
1
42*09'24.794S3
?rQl'33,38897"
86
42"09'2S 262 71"
71'01'33,89832"
67
42 09'25 83390"
7i'01'3i.841S0"
68
42"09'26 33466"
7r01'3 3.76703"
B9
42"09'26.83388"
?r01'33,61347"
CI
42*09'30 57056"
7r01'37 28341"
a
42"09'31.30673"
7r01'37.28858"
C3
4 2'09'3 2.2 9407"
71 "01'37.63201"
C4
42 09 33 30155"
7r01'37.59233"
CS
42"09 34.26767"
71"01'37.11742"
C7
42W35.99072"
71°01'36.35008"
C8
47W36 87861"
71a01'36.87476"
C9
42°09'37,78651"
7r01'36.71841"
05
42W43J6129"
71 "01 *32 68422"
E0
42'0901.08900"
71°G1'31.50619"
"Data is in Massachusetts State Plane
Jjk Lumrmmmtlal
megm
¦¦ bMmmgerncnt
-------
TABLE 3
SUMMARY OF
SEDIMENT ANALYTICAL RESULTS
INORGANICS
Batrd McGuire Fish Sampling
Cochalo River investigation
Holbrooh, MA
(repotted on a ay weight basisi
Totai
Total Organic
Organic
Sample
Carbon
Carbon
% Coarse
% Fine
% Total
% Coarse
% Medium
% Fine
% Total
Solids,
Client ID
Date
(Repl)
(Rep2l
Ccbbies
Gravel
Gravel
Gtavel
Sand
Sand
Sand
Fuses
Tola!
A3 SED
11 -OcM3
1.92%
1.68%
--0 100
<0 100
! 59
1 59
7 91
43.1
40.4
7 00
69.4
A5 SED
11 -Oct-13
4.03V
4.08%
<0 100
<0 too
i 68
1 68
3.78
18.2
64.4
11.9
40.0
A7 SED
11-Oct-13
8.03%
8.79%,
<0 100
<0 100
0 87
0,87
4 24
26.0
57.1
11.8
25 1
E0 SED
11-Oct 13
1.82%
1,74%.
o
o
o
l/
<0 100
9.42
9.42
3.84
31.8
43 3
11.3
69,4
B3 SED
09-Oc!-13
1.01%
1.22%
<0 too
<0 100
0 66
0 68
241
23.4
66 0
7 54
68.4
B5 SED
09-OCM3
2.35%
2 81%
*0.100
<0 100
0.100
0 100
2.36
47.5
46 5
3.56
57.4
B7SED
09-Oct-13
0,658%
0 825%
*.0 100
<0 100
0.25
0.25
2,31
31,8
61 6
4 06
55,5
C3 SED
IO-Oct-13
2 76%
2.29%
..0 100
<0 10(1
' .73
1 73
6.63
22 7
46,2
22.7
57 0
C5 SED
10-OCM3
9,8~%
7 33%
<0 100
<0 100
1 05
1 05
6 41
30,0
54 9
7 65
40 7
C7 SED
10-OCM3
5.83%
6 72%
<0 100
-rO 100
f 40
! 40
9.94
88 5
18.4
1 67
51.8
D5 SED
11 -Oct-13
12 1%
12 1%
<0 100
<0.100
3,25
3-25
11 5
37 8
29-5
18,0
20.2
2.''28'2014
.¦+. environmental
, * sj,,legit,
&• Management
-------
TABLE 3
SUMMARY OF
SEDIMENT ANALYTICAL RESULTS
PAH
Baiicl McGuire Fish Sampling
Cocitalo Rive/ Invesltgalitxi
Holbrook, MA
uestilts reported on a dry weight basis in ugikgt
Client ID
Sample
Date
1 -Mothyinaphthatene
2-MetliytnapMtelene Acenaphtbene
Accivaphthylene
Anthracene
Ben?
-------
TABLE 3
SUMMARY OF
SEDIMENT ANALYTICAL RESULTS
PAH
Baird McGuice Fish Sarnpsintj
Gociiato Rivet Invessliyalion
Hotbrook. MA
(results reported on a dry weight basis in ug
-------
TABLE 3
SUMMARY OF
SEDIMENT ANALYTICAL RESULTS
PESTICIDES
Baird McGuire Fish Sampling
Cochato Rivet Investigation
Hotorook. MA
(results reported on a dry weight base m ug/kg)
Sample
Alpha
Beta-
CIS-
cis-
Client ID
Date
2 4--DDD
2,4'-DDE
2.4--DDT
4,4-DDD
4,4'-DDE
4,4'-DDT
Aldrin
BHC
BBC
Chlordane
Chlordane
Ncmachlor
Delta-BHC
A3 SED
11-Oct-13
0,998
<¦ 0 572
< 0,572
3.23
14 5 P
< 0 572
< 0 572
< 0.572
< 13.7
< 28.6
1,85
< 0.572
< 0 572
AS SED
11 Ocl-13
5.18
< 0.982
* 0.982
9.63
192 P
< 0 982
< 0 982
< 0.982
<23 6
< 49 1
3 39
2.99
< 0.982
A? SED
11-Oct-13
31,4
6,40 P
< 1,53
61.1
26 8
5,15 P
< 1,53
-------
TABLE 3
SUMMARY OF
SEDIMENT ANALYTICAL RESULTS
PESTICIDES
Baird McGuire Fish Sampling
Cochaio River Investigation
Hotbrook. MA
(results reported on a dry weight basis in ug/kg)
Sample
Endosulfan
Endosulfan
Endosulfan
Endrin
Endrin
gamma-
Heptachlor
Hexachloro
Client ID
Date
Dieldnn
1
II
sulfate
Endrin
aldehyde
ketone
" BHC
Heptachlor
epoxide
benzene
Melhoxychlor
Mirex
A3 SED
11-Oct-13
< 0.572
< 0,572
< 0,572
< 0.572
<1.11
< 0,572
< 0.572
< 0.572
< 0.572
< 0.572
< 0,572
6.60 I
< 0.572
A5 SED
11'Oct-13
< 0.982
< 0,982
< 0.982
< 0.982
< 1.92
< 0 382
< 0.982
< 0.982
< 0 982
<0.982
< 0,982
8.40
< 0 982
A? SEO
11-Oct-13
< 1.53
< 1.53
< 1.53
< 1,53
< 2.98
< 1,53
•4 1.53
< 1.53
< 1 53
< 1.53
<1.53
< 9.18
< 1.53
EO SEO
11-Oct-13
28 1
< 2,78
6.03
4.12
< 5.42
<2 78
<2.78
<2 78
< 2,73
9,55
< 2,78
< 16.7
< 2.78
B3 SED
03-Oct-13
<11.7
<11.7
< 11.7
< 11.7
<22,8
C 11.7
<11.7
< 11.7
< 11.7
<11.7
< 11.7
< 70
< 11,7
B5 SED
09-Oct -13
< 13.6
< 13.6
< 13.8
< 13,6
< 26,4
< 13,6
< 13.6
< 13,6
< 13.6
< 13.6
< 13.6
< 81.3
< 13.6
87 SED
09-Oct-13
< 13.9
< 13.9
< 13.9
< 13.9
< 27.1
< 13,9
< 13.9
< 13.9
< 13.9
< 13.9
< 13.9
< 83.3
< 13.9
C3SED
IO-Oct-13
< 13.8
< 13.8
< 13.8
<. 13-8
< 28.9
< 13-8
< 13.8
< 13.8
< 13.8
< 13.8
< 13,8
<82 9
< 13.8
C5 SED
10-Oct-13
< 19 1
< 19.1
< 19.1
< 19 1
C 37,3
< 19.1
< 19 1
< 19.1
< 19.1
< 19.1
< 19.1
<115
< 19,1
C7 SED
IO-Oct-13
< 0.733
<0.733
< 0.733
< 0.733
< 1
< 0.733
< 0.733
« 0.733
<0.733
< 0.733
< 0 733
8.54 P
< 0.733
D5SED
11-Oct-13
« 38.4
<38.4
< 38,4
< 38.4
75
v 38.4
<38 4
< 38.4
<38 4
< 38.4
< 38.4
<231
< 38.4
Results reported as
-------
TABLE 3
SUMMARY OF
SEDIMENT ANALYTICAL RESULTS
PESTICIDES
Baird McGwire Fish Sampling
Cocbato River Investigation
Holbrook. MA
iiesuHs reported on a dry weight basis in uyikgi
Sample
trans-
trans-
Client ID
Date
Oxychlordane
Toxaphene
Cfilordane
Nonachlor
A3 SED
11-Oct-13
<: 0.572
<28.6
1.26
< 0.572
A5 SED
11 Ocl-13
< 0.982
<49.1
2.51
7 71 P
A? SEO
11-Oct-13
< 1.53
< 76.5
3 9C
5 02 P
EO SEO
11-Oct-13
< 2.78
< 139
488
152
B3 SED
Q9-Oct-13
<11,7
<584
48.1
16.6
B5 SED
0&-Ocl-13
< 13.8
<678
61.3
22.9
87 SED
09-Oct-13
« 13.9
<694
53.5
17.4 P I
C3SED
tO-Oct-13
< 13.8
<691
824
424
C5 SED
IO-Oct-13
< 19.1
<.956
214C
582
C? SED
IO-Oct-13
< 0.733
<38.6
8 2C
2.36
D5SED
11-Oct-13
<38 4
< 1920
231C
871
Results reported as indicate that compound was no! delected above the repotting limit (Rl).
Reporting Limit jRU is the value at which an instrument can accurately measure an anaiyte at a specific concentration.
The Rl. mcii'des a<»y adjustments from dilutions, concentrations or moisture content, where applicable
Data Qualifiers
P • The RPD between the results for the two columns exceeds the method-specitied criteria.
E- Concentration ot anaiyte exceeds the range of the calibration curve anctot linear range ot the instrument.
I ¦ The lower value lor the two columns has been reported clue to obvious interference
D ¦ The concentration of anaiyte exceeded the range ot the calibration curve and;'t>r linear range ot the instrument
therefore the sample required dilution The diluted analysis was over the calibration range of the analytical instrument.
2.'28,2014
Invmmmmktl
&• Mimngt'tftml
-------
TABLE 3
SUMMARY OF
SEDIMENT ANALYTICAL RESULTS
METALS
Batrd McGuire Fish Sampling
Couhalo River Investigation
Hotbrook, MA
i'esuits repotted on a dry weight basts in «ig l«gi
Client ID Sample Date
Afsertic,
Total
A3SED I ~ -Oct-* 3
A5SED 11 Oct-13
A? SEP 11 -Oct-13
EOSED t f •Oct-13
83SED 09-Oct-13
B5SEO 09-OCM3
B7SED 09-Oct-'3
C3SED IO-Oct-13
G5SE0 IO-Ocl-13
C7SEO 10-OOM3
D5SED 11 -Oct-13
I 45
3.59
179
18,5
6,85
8,76
6 49
II 2
M6
25 2
115
2/21/2014
Etteifmtmtmi
~ Strategies
& Management
-------
TABLE 4
SUMMARY OF
SOU ANALYTICAL RESULTS
INORGANICS
Baird McGutre Fish Sampling
Cociialo Rivtn Investigation
Hotorook, MA
(results reported on a dty weight basisi
Sample
Total Oigaiwc
Total Organic
%
'•:« Coarse
% fine
:ib Total
Coarse
% Medium
% Fine
% Total
Client ID
Date
Carbon (Repl1
Carbon (Rep2i
Cobbles
Gravel
Gtavel
Qiavc-I
Sand
Sand
Sand
Fines
Solids. Total
C3 SOU
IO-Oct-13
5.81%
5.55%
<0,100
<0.100
15.1
15 1
4 45
25.6
47 5
7 32
89.6
C5 SOIL
IO-Oet-13
8,88°'o
0.058
<0 too
<0.100
<0.100
<0.100
0 18
17.9
62.8
19.4
45,3
C? SOIL
10-OcM3
7.83%
7.07%
<0 100
<0 100
<0.100
<0.100
0.72
133
52.1
33.9
41 5
05 SOIL
11-Oc!-13
12.20%
12.20%
<0 100
<0,100
<0.100
<0.100
3 04
31 9
32.3
32.3
25 0
2 28 2014
A kaoirmmmmil
Stmlegim
& Mamigerment
-------
TABLE 4
SUMMARY OF
SOIL ANALYTICAL RESULTS
PAH
Baifd McGuiro Fish Sampling
Cocbato Rive' investigation
HolbrooK, MA
(results reported on a ory weight basis in ug-'kg)
Client ID S; 1 '' ithylnaphtnalene 2-Melhyinaphihaiene Acenaphthene Acenaphthylene Anthracene Beaz(atenthrac3oe Benzola)pyi ¦ uo(b)
-------
TABLE 4
SUMMARY OF
SOIL ANALYTICAL RESULTS
PAH
Baird McGuiro Fish Sampling
Cochato Rive' Investigation
Hoibrook, MA
lresults reported on a dry weight basis in ug;kg)
Clieni ID
Sample Date
Benzofg-h.isperyleiie
Ben?o(k)fluoranthone
Chrysene Dtben?
-------
TABLE 4
SUMMARY OF
SOU ANALYTICAL RESULTS
PESTICIDES
Baird McGuire Fish Sampling
Cocttalo Rivet Investigation
Holbrook, MA
(lesuHs reoorled on a dry weight basis m ugkgi
Sample cis- cis-
Client ID
Date
2.4'-ODD
2.4--DDE
2,4'-DDT
4,4'-CDO
4,4'-DDE
4,4'-DOT
Aldnn
Alpha-BHC
Beta-BHC
Chlordane
Chlordarte
Nonachlor
Delta-BHC
Dteldrtn
C3 SOIL
10-OcM3
19,0
< 11.4
15-8
84.9
228
139
<11.4
<11.4
<273
< 569
106
39.8
c 11.4
34.9
C5 SOU
10-Oct-13
270
19,2
<168
876
297
37.0
< 16.8
< 18.8
< 404
< 842
248
69 1
< 18,8
50.9
C? SOU
10 Oct-13
216
26,1
< 17-8
543
300
32.1
< 17.6
< 17.6
< 424
<=883
150
51 7
< 17,8
C 17,6
D5 SOIL
11 -Oct-13
304
<¦ 30.6
< 30,6
660
290
32.4
<30.6
< 30.6
< 736
< 1530
109
45,1
c 30.6
< 30.6
Results reported as <# indicate that compound was not, detected above the reporting limit (Rt).
Reporting limit |RL) is the value at wiiicti an instrument can accurately measure an anatyte at a specific concentration.
The RL includes any adjustments from dilutions, concentrations or moisture content where applicable
2'28/2014
Cnmnmmmkti
K" &Managemr»t
-------
TABLE 4
SUMMARY OF
SOIL ANALYTICAL RESULTS
PESTICIDES
Baird McGuire Fish Sampling
Cociiato Rivoi Investigation
Holbfook, MA
cesuits reported on a city weight basis m uy-kgi
Sample
Endosulian
Endrin
Endrin
gamma
Heptachict
Hexachloro
Client ID
Date
Endosulfan 1
Endosollan II
sulfate
Endrin
aldehyde
ketone
BHC
Hepiachtor
epoxide
benzene
Methoxycfilor
tvtirex
Oxychlordane
C3 SOIL
10-OcM3
<114
<11.4
< r .4
< 22.2
< 11.4
f 11 4
<11,4
<114
< 11.4
<11.4
< 68,3
.
26.2
C5 SOIL
10-Oct-13
«. 16.8
<168
< 16.8
< 32.8
< 16.8
<, 16 8
< 16.8
< 16.8
< 1E.8
< 18,8
< 101
< 16.8
< 16.8
C7 SOU
1Q-OC-M3
< 17.6
< 17.6
< 17 6
< 34,4
< 17.6
<17 6
< 17.6
<176
< 17.6
< 17.6
< 106
< 17,6
< 17.6
D5 SOIL
11-Oct-13
< 30.6
< 30 6
< 30.6
< 59,8
< 30.8
< 30.6
<306
< 30,6
< 3C 6
< 30.6
«. 184
< 30.6
< 30'. 6
Results reported as
-------
TABLE 4
SUMMARY OF
SOIL ANALYTICAL RESULTS
PESTICIDES
Baird McGuire Fish Sampling
Cocitalo Rivut Investigation
HolOrook, MA
(results reported on a dry weight basis in ug;kg)
Sample
trans-
trans
Client ID
Date
Toxaphene
ChtorcJano
Nonachlor
C3 SOIL
IO-Oct-13
< 589
55.8
107
C5 SOIL
10-Oct*13
< 842
249
166
C? SOU
IO-Oct-13
< 883
173
12?
05 SOIL
11-Oct-13
< 1530
164
80.1
Results reported as « # indicate thai compound was not detected above the reporting limit iRL).
Reporting Limit iRL! is tte value at which an instrument can accurately measure an analyse at a specific concentration
The RL includes any adjust men Is from dilutions, concentrations or moisture content where applicable
2;28/2Ql4
environmental
K" & Marmgrmrnt
-------
TABLE 4
SUMMARY OF
SOU ANALYTICAL RESULTS
METALS
Batrd McGuiie Fish Sampling
Cochaio Rive* Investigation
Hotbrook, MA
(results (opoMed on a dry woight oasis in trig kg!
Arsenic.
Client ID
Sample Date
Total
C3 SOIL
10-Oci-13
10,3
C5 SOIL
IO-Oct-13
28 1
C7 SOil
10-Oci 13
39.4
D5 SOU
11 -Oct-13
64,0
2'2i 2014
A Envimmtmul
& Manti&ment
-------
TABLE 5
SUMMARY OF
FISH SAMPLE ANALYTICAL RESULTS
PAH
Baiid McGuite Fish Sampling
Gochato River Investigation
Holbrook. MA
(results reported on a wet weigh! basis In og-kgi
LOCATION
Composite
Sampling Date
Naphthalene
Acenaptithylene
Acenaphthene
Fluor ene
Phiiiianthrene
Anthracene
Ftuoranthene
Pyrene
At
10'24 '2013
< 148
« 148
< 148
< 148
< 148
< 148
< 148
* 148
A2A.A2B
Composite
10'24.'2013
146
< 146
< 146
< 146
<. 148
< 146
< 146
< 146
A3
10 24.2013
< 154
< 154
c 154
< 154
< 154
154
< 154
< 154
A4
10.24/2013
< 153
< 159
<• 159
« 159
< 159
< 159
< 159
< 159
ASA
10 24.2013
< 149
< 149
< 149
< 149
< 149
< 149
< 149
< 149
A5B
10'24.'2Q13
158
< 158
< 158
< 158
158
< 158
< 158
« 158
Et
10(22'2013
C 158
< 158
< 158
< 158
< 158
< 158
< 158
< 158
E2
10'22'2013
< 156
< 156
< 156
- 156
< 158
< 156
< 156
<. 156
E3A.E3B.E3C
Composite
10/22'2013
< 141
< Hi
<: 141
< 141
< 141
< 141
v 141
< 141
E4A.E4B.E4C.E4D.E4E E4F
Composite
10,-22.2013
< 154
< 154
< 154
< 154
< 154
< 154
< 154
< 154
B!
10/29-2013
15?
< 157
< 157
< 157
< 157
< 157
< 157
< 157
B2
10.'29''2013
< 160
< 160
< 180
160
< 160
< 180
< 160
<, 160
B3
10/29.2013
< 152
152
< 152
< 152
< 152
< 152
< 152
<¦ 152
B4
10,'29.'2013
< 158
v 156
< 156
< 156
< 158
< 156
< 156
< 156
BS
10'29.'2013
-------
TABLE 5
SUMMARY OF
FISH SAMPLE ANALYTICAL RESULTS
PAH
Band McGiwa Fish Sampling
Cochato River Irtvessligufton
HofbrOOk. MA
iresults reported on a wet weigh! basis m ug'kgi
Berufa)
Benzo(b)
Benzo{k)
Benzol at
Intfenol 1.2,3 •
Dibenz(a.h)
Benzo(g.hj)
LOCATION
Composite
Sampling Date
anthracene
Chrysene
ttuoianthene
fluoranthene
pyrene
cd) pysene
anthracene
perylene
At
10/24^2013
« 148
«. 148
< 148
< 148
< 148
* 148
< 148
< 148
A2A.A2B
Composite
10/24/2013
< 148
«. 148
•- 146
< 1 4$
< 146
< 146
< 146
< 146
A3
10-24/2013
< 154
< 154
c 154
< 154
«¦ 154
< 154
< 154
< 154
A4
1Q/24>'2013
< 159
< 159
< 159
«r 169
< 159
159
159
< 159
ASA
10,242013
< 149
v 149
< 149
c f 49
< 149
< 149
< 149
< 149
A5B
10/24>'2013
< 158
< 158
< 158
< 158
v 158
<• 168
< 158
-r 158
Ei
10/22/2013
158
« 158
< 158
< 158
< 158
< 158
C 158
< 158
E2
10/22'2013
< 156
< 156
<- 156
« 156
«• 156
156
<- 156
< 158
E3A.E3B.E3C
Composite
10/22''2013
< 141
< 141
141
< 141
v 141
141
< 141
< 141
E4A.E4B.E4C.E4D.E4E E4F
Composite
10/22'2013
< 154
< 154
c 154
«• 154
< 154
154
< 154
< 154
B!
10/29/2013
< 157
< 157
< 157
< 157
< 157
*¦ 157
< 157
<¦ 157
B2
10/29/2013
< 160
< 180
« 180
< 160
«. 160
<160
< 160
< 160
B3
10/29/2013
< 152
< 152
< 152
< 152
< 152
< 152
< 152
< 152
B4
10/29/2013
< 156
< 156
< 156
< 156
v 156
< 156
156
< 156
B5
10.29''2013
< 140
< 140
< 140
«• 140
«¦ 140
<=• 140
< 140
< 140
B6
10/30/2013
< 154
<• 154
< 154
< 154
< 154
< 154
< 154
< 154
B7
10/30' 2013
< 156
< 156
« 158
¦<. 156
< 156
^ 156
< 156
< 156
Cl.C2.C3
Composite
10/17'f2013
< 159
< 159
»• 159
< 159
- 159
< 159
< 159
< 159
C4.CS.C6A
Composite
10/17/2013
< 157
< 157
< 157
< 157
< 157
<157
< 157
_• 157
C10.C11
Composite
10/18'2013
< 152
< 152
* 152
< 152
«• 152
- 152
¦r 152
- 152
C13
10/18/2013
< 158
<¦ 158
< 158
< 158
<• 158
< 158
158
¦= 158
C17C18
Composite
10/18 '2013
- 147
< 147
< 147
< 147
< 147
c 147
< 147
< 147
Ct9
10/18/2013
< 159
< 159
<. 159
< 159
< 159
< 159
< 159
< 159
C20
10/16 '2013
< 159
< 159
« 159
< 159
* 159
< 159
< 159
< 159
Results reported as <* indicate that compound was not detected above (he reporting limit (Rtl
Reporting Limit tRtf is the value at which an instrument can accurately measure an anaiyte at a specific concentration
The RL includes any adjustments from dilutions, concentrations or moisture content, where applicable.
gtmrmtmmfoil
• Strategies
2 232014 " *"•' £, Mmagemmt
• &
-------
TABLE 5
SUMMARY OF
FISH SAMPLE ANALYTICAL RESULTS
PAH
Band McGuire Fish Sampling
Cochato Rivef Investigation
Hotbrook. MA
i results reponed on a wet weight basis in tig Kgi
LOCATION
Composite
Sampling Date
2
Methylnaphthaiene
1-
Methy (naphthalene
A1
10W2013
< 148
< 148
A2A.A2B
Composite
10/24'2013
146
<. 146
A3
10,'24'2013
< 154
154
A4
10.'24/2013
< 159
< 159
ASA
10;24/2013
< 149
< 149
A5B
10/24/2013
< 158
< 158
E»
10/22 "2013
< 158
c 158
E2
10/22/2013
< 156
< 156
E3A.E3B.E3C
Composite
10/22'2013
< 14!
< 141
E4A.E4B.E4C.E4D, E4E.E4F
Composite?
10/22/2013
< 154
« 154
Bl
10/2& 2013
•: 157
< 157
B2
10/29-2013
•: 180
< 160
B3
10/29/2013
< 152
152
B4
10:29/2013
< 156
< 156
B5
10 29 '2013
< 140
c 140
B6
10.30'2013
« 154
< 154
B7
10/30/2013
< 158
156
CI C2.C3
Composite
10/17'2013
< 159
< 153
C4,C5,C6A
Composite
10/17/2013
< 157
< 157
C10C11
Composite
10/18'2013
< 152
-- 152
C13
10/18,2013
< 158
< 158
C17.CI8
Composite
10/'18'2013
< 147
147
Ct9
10/18-2013
<. 159
< 159
C20
10/18/2013
< 159
< 159
Results reported as .
Repoitmg Limit iRL» is the value al which an instrument can accurately measure an analyte at a specific concentration
The RL includes any adjustments from dilutions, concentrations or motslure content, where applicable.
2 23'2014
s'-'. Bfii'mmmaikM
> Mafc-jpes
& Mamtxemmtl
-------
TABLE 5
SUMMARY OF
FISH SAMPLE ANALYTICAL RESULTS
PESTICIDES
Baiid McGuire Fish Sampling
Cochato River Investigation
Htttfarook. MA
tresuits reported on a wet weight basis m ug'kgj
Sampling
alpha.
alpha-
beta-
CIS'
delta-
LOCATION
Composite
Date
2,4'-ODO
2,4'-DDE
2.4'-DOT
4.4'-ODD
4,4"-DDE
4.4'-DDT
Atarin
BHC Chlordane
BHC
nonachlor
BHC
A1
10/24 .'2013
< 7.30
< 7,30
< 7.30
< 7.30
< 7.30
< 7,30
< 7 30
< 7.30
< 7.30
< 73 0
< 7,30
< 7.30
A2A.A2B
Composite
10:24.2013
<3.eo
< 3.80
<3.80
11.4
9.59
< 3.80
< 3.80
<3.80
< 3.80
<38.0
<3,80
<3 80
A3
10,'24,'2013
< 7.63
<7 83
•: 7.83
11.2
11.2
< 7,83
<, 7.83
< 7.83
<7 83
< 78.3
< 7,83
<7 83
A 4
10/24/2013
6.12
1 29
< 0,391
79,7
38.8
2,29 P
< 0.391
< 0.391
9.46
< 3.91
< 0.391
«, 0,391
ASA
10,24.2013
<0.381
< 0.381
< 0.381
105
184
3.02 P
<0.381
< 0.381
2,04
<3 81
< 0 381
< 0 381
A58
10''24/2013
177
< 7.89
< 7.89
< 7,89
1210
180
< 7 89
< 7 89
473
< 78 9
103
< 7,89
El
10/22,2013
9.18 P
2.22 P
<0 398
82 7
57.2
2,81 P
<0 398
< 0,398
14.8
< 3,98
4 38
< 0,398
ES
10:22.2013
4 89
t 21
« 0,393
55 9
26.2
1.87 P
< 0 393
< 0.393
9.40
< 3 93
< 0 393
< 0.393
E3A.E3B.E3C
Composite
10/22/2013
7.62 P
< 3 94
< 3.94
17.9
18.1
< 3.94
= 3.94
<3,94
<3.94
< 39.4
< 3.94
< 3.94
E4A,E4B,E4C,E4D.E4E,E4
Composite
10'22/2013
< 7 57
< 7,97
< 7,97
17.0
10 7
< 7.97
< 7 97
< 7.97
< 7.97
< 79 7
< 7.97
<7 97
Bl
i0/29."2f}13
< 7,55
< 7.55
<7.55
13,7
54,3
< 7.55
< 7,55
< 7.55
< 7,55
< 75.5
< 7.55
<7,55
B2
10-29.2013
c 7 59
< 7 59
<7 59
10.6
! 1 3
< 7.59
< 7,59
< 7 59
< 7 59
< 75.9
< 7.59
< 7.59
B3
10/29/2013
7X9
< 7,09
< 7 09
19.6
128
< 7.09
c 7,09
< 7,09
< 7,09
< 70,9
< 7,09
< 7.09
B4
10/29/2013
8S9
2,54 P
< 0,386
123
80.3
2,32 P
< 0.386
< 0.386
14,8
< 3,86
4,44
< 0.386
B5
10/29/2013
3.88
< 0.360
< 0.360
50.2
38.9
< 0,380
< 0.380
< 0.380
5.82
< 3,80
< 0.360
< 0.380
B6
tO, 30.2013
< 3.S1
< 3,31
< 3,91
14,6
26.7
< 3.91
< 3.91
< 3.91
< 3.91
< 39,1
< 3.91
< 3,91
B7
10/30'2013
< 3,45
<,3 45
<3.45
9.85
13
< 3,45
<3.45
< 3,45
<3.45
< 34,5
< 3.45
< 3.45
C1.C2.C3
Composite
10'17.'2013
14,1 P
< 3,97
<3.97
41,1
30-9
< 3.97
c 3,97
< 3,97
5.70
< 39.7
<3.97
< 3.97
C4,C5,C6A
Composite
ia 17-2013
< 3,63
<3.93
<3.93
32 3
22.5
<3.93
< 3,93
< 3,93
< 3,93
< 39.3
<3.93
< 3.93
cio.cn
Composite
10/18.2013
25 6 P
< 3.35
<3,95
74.0
50,4
< 3.95
< 3,95
< 3,95
11.4
<39.5
< 3.95
< 3.95
Cl3
1Q'18-'2013
<7 77
< 7.77
< 7.77
8,90
< 7.77
< 7.77
< 7,77
< 7,77
< 7.77
< 77.7
<7,77
< 7,77
CI7.C18
Composite
10/18/2013
22 t P
< 3.38
<3.98
58.5
37.2
<3.98
<: 3,98
< 3.98
8,96
<39.8
<3.98
< 3.98
C19
10/18/2013
15,2
0,722 P f
< 0.389
38,3
25.2
1.58 P
<0,389
< 0.389
7,56
< 3.89
< 0.389
< 0.389
C20
10/182013
15,4
< 7,78
< 7 78
< 7.78
250
28.1
< 7,78
< 7,78
71,2
< 77.8
28.4
<7 78
Results reponea as <# indicate that compound was not detected atxrve the reporting limit (RL).
Reporting Limit (RL) is the value at which an instrument can accurately measure an analyte at a specific concentration
The RL includes any adjustments from dilutions, concentrations or moisture content, where applicable.
P - The RPD between the results for the two columns exceeds the method-specified criteria,
E- Concentration of analyte exceeds the range ot the calibration curve and,'or linear range of the instrument,
I - The lower value for the two columns has been reported due to obvious interference.
2 23'2014
A Environmental
tr Management
-------
TABLE 5
SUMMARY OF
FISH SAMPLE ANALYTICAL RESULTS
PESTICIDES
Baiid McGuire Fish Sampling
Cochato Rivet Investigation
Hofcrook. MA
(results reported on a wet weight basis in ug.'kgi
LOCATION
Composite
Sampling
Date
DieW-in
Enctosutian 1
Endosulfan II
Ertdosultan
sulfate
Endrir)
Endrin
aldehyde
Endrin
ketone
gamma- gamma-
BHC Cbtordane
Heptacntor
At
10,24/2013
« 7,30
< 7.30
< 7.30
< 7,30
< 7.30
< 7,30
< 7,30
<7 30
<
7,30
<7 30
A2A.A2B
Composite
10*24.2013
< 3.30
< 3.80
< 3.80
< 3 80
< 3.80
<3.80
< 3.S0
<3.80
<
3,80
<3 80
A3
1Q'24<2Q13
7.33
< 7.83
< 7.83
< 7 83
< 7.83
< 7 83
< 7.83
< 7.83
<
7.83
< 7.83
A 4
10,'24/2013
< 0.391
< 0,391
< 0,391
< 0.331
< 0 391
< 0.391
<0,391
< 0.391
5,80
< 0.391
ASA
10,24:2013
< 0.331
<0.381
< 0,381
< 0,381
<0 381
< 0.381
< 0,381
< 0,381
1,00
< 0.381
A5B
10,'24'2Q13
135
< 7.89
< 7,89
< 7,89
< 7.89
< 7,89
< 7,89
< 7,89
314
< 7,89
El
10/22,2013
3,28 P
< 0-398
< 0,398
< 0 398
< 0,398
< 0,398
< 0,398
< 0,398
9,34
< 0.398
E2
10/22/2013
0 713
< 0.393
< 0.393
< 0 393
< 0 393
< 0 393
< 0 393
< 0 393
5,35
< 0 393
E3A.E3B.E3C
Composite
10;22'2013
<3 34
< 3.94
< 3,94
< 3 94
< 3,94
<3,94
< 3.94
< 3,94
<
3.94
< 3.94
E4A.E4B.E4C.E4D.E4E.E4
Composite
<0.22/2013
<7 37
< 7,97
< 7.97
< 7 97
* 7,97
< 7,97
< 7.97
< 7,97
<
7.37
< 7,97
Bl
10:29'2013
< 7,55
< 7.55
< 7.55
< 7 55
< 7 55
< 7.55
< 7.55
< 7.55
<
7.55
< 7.55
B2
1C29-2013
< 7 59
< 7.59
< 7,59
< 7 59
< 7,59
< 7,59
< 7.59
< 7.53
<
7 59
< 7.59
B3
10; 29'2013
< 7.39
< 7.09
< 7,09
< 7 09
<7 09
< 7.09
< 7,09
< 7,09
<
7.09
< 7,09
B4
10/29<2013
1,38
< 0.386
<0,388
v 0 386
< 0,386
< 0 386
< 0.388
< 0,386
10,4
< 0 386
B5
'0/29.'2013
< 0.330
< 0,360
< 0,380
.. 0.360
< 0 380
< 0,360
< 0,360
< 0,360
3,45 P
< 0.360
B8
10,30'2013
< 3.31
< 3.91
< 3,91
« 3 91
< 3.91
< 3,91
< 3,91
< 3.91
<
3,91
< 3,91
B?
10/30.2013
3 45
< 3,45
< 3,45
* 3 45
< 3.45
<3.45
< 3,45
< 3.45
<
3,45
<3 45
C1.C2.C3
Composite
10 17/2013
3.3 /
< 3,97
< 3,97
< 3,97
< 3.97
< 3,97
< 3,97
< 3.97
<
3,97
< 3,97
C4.C5.C6A
Composite
10/17 2013
< 3,33
< 3 93
< 3.93
3 93
< 3.93
<3,93
<3,93
< 3.93
<
3,93
< 3.93
ClO.Cn
Composite
10/18.2013
< 3.35
< 3.95
< 3,95
< 3.95
< 3.95
< 3.95
< 3,95
< 3,95
<
3.95
< 3,95
Cl3
10 16.2013
< 7,77
<7 77
< 7,77
< 7 77
< 7,77
< 7.77
< 7,77
< 7,77
<
7.77
< 7.77
C17.C18
Composite
10/18/2013
< 3 38
< 3,98
< 3.98
<3 98
< 3.98
< 3.93
< 3,98
<3.98
<
3.98
< 3,98
C19
10/18/2013
<0.339 1
C 0.389
< 0.389
< 0.389
< 0.389
< 0.389
< 0.389
< 0,389
3.90
< 0.389
C20
10/18'2013
19 5
< 7.78
< 7,78
7 78
< 7,78
< 7 78
< 7.78
< 7 78
35.9
< 7 78
Results reported as <# indicate that compound was not detected above the reporting limit iRL)
Reporting LhtiiI
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TABLE 5
SUMMARY OF
FISH SAMPLE ANALYTICAL RESULTS
PESTICIDES
Baird McGuire Fish Sampling
Cochata Rivet Investigation
Holbrook. MA
(results repotted on a wet weight basis in ug.'kgi
Sampling
Heptachloi
Technical
trans-
LOCATION
Composite
Date
epoxide
-------
TABLE 5
SUMMARY OF
FISH SPECIES AND PERCENT LIPIDS
Baird McGuire Fish Sampling
Cochato River Investigation
Holbrook. MA
(results reported on a we! weight basis)
Sample ID
Composite
Sample Date
Species Name
Percent lipids
¦ ¦
10!24,l2013
Pumpkmseed (Lepomis gibbosus)
0 649 'V,
ASA. A2B
Composite
10'24/2013
PumpKinseed (Lepomis gibbosus)
0 791 %
A3
10'24/20l3
Pumpkiriseed (Lepomis gibbosus!
0 771
A4
10/24/2013
Brcwn BulUtoad (Amoirus nebulosusi
1 56
ASA
10'24-/2013
American Eel (Anguilla rostrata)
1 82 %
A5B
10.'24/2013
American Eel (Anguilla rostrafaj
15 3 %
El
10 22-2013
Brcwn Bullhead (Ameirus nebulosusi
8 62 %
E2
10 '22 '2013
Brcwn Bullhead (Ameirus nebulosusi
1 59
E3A. E3B, ESC
Composite
10'22'2013
ReciFwi Pickerel (Esox amencanus)
0 762
E4A. E4B, E4C, E4D, E4E, E4F
Composite
10.'22'2013
PumpKinseed (Lepomis gibbosus!
1 11
Bi
10 '23/2013
PumpKinseed ('Lepomis gibbosus)
0 597
B2
10/29'2013
PumpKinseed (Lepomis gibbosus|
0 639 V
83
10.29,20! 3
Bluegill (Lepomis macrochirus)
0.669 -v
84
10*29/2013
Brcwn Bullhead (Ameirus nebulosusi
A 18 11,
B5
10'29/2013
Brown Bullhead (Ameirus ne&ulosusS
1 48
B6
10/30'2013
Black Ctappie (Pomoxis nigromaculatusf
0.645 %
B?
10'30 2013
Large Mouth Bass (Micropterus
8 36 "r
CI, C2, C3
Composite
10' 17/2013
RedFm Pickerel (Esox amcricanust
0 892
C4, C5 C8A
Composite
1 on 7/2013
Pumpkinseed (Lepomis gibbosus|
0 882 %
C10.CH
Composite
10't S'20i 3
RedF»n Pickerel (Esox acmencanus)
0 789 %
C13
10' IS/2013
PumpKinseed (Lepomis gibbosus!
0 855 '\
C17. Ci8
Composite
1O'W20i3
RedFin Pickerel (Esox atnericanus)
0.646 °r
C19
10-182013
Large Mouth Bass (Miciopterus
0 762
C20
10' IS'2013
American Eel (Anguilla rostrata!
8 08 "a
2/21/2014
Jjk Environmental
' v-ifegte
& Management
-------
TABLE 0
FISH WEIGHT, LENGTH, AND AG I AT LENGTH
Baird and McGwire Site
Cochato River Investigation
October 2013
fM: 4i~ iivife "V Sill
vvoinht jt
Cap Tire
i
¦ engtr- a'
'Jprtii
fish
Lyngt*'. Jt Age
lyrsj j ftgei
—
,
J' ¦>.«
Lab,. f-K-'iti-J ir.-'i * \ | s ^ J i
ibu
50
80
122
150
A2A
Lepmtiis gibbrnm (pumpkinseed)
32
114
3+
49
77
£4
A2B
mis gihfmsm (pumpkinsced)
28
112
? +
47
82
105
m
mm gibboxm (pumpkiriseed)
77
160
4*
56
•w
130
A4
Ameitmis atMmm (brown bullhead)
60
155
2+
ASA
Anmuiia rostrata (american eel)
60
.
.
ASB
An gut! la rmtmm (american eel)
43
-
.
B1
Lepomis gibhmux (pumpkinseed)
100
165
4+
53
77
123
147
82
Leptmm gikhmm (pumpkinseed)
71
1S8
•J*
60
•*s
1H
142
B3
Lepmnis macmchina Iblucgillj
152
180
4-f
59
79
122
153
B4
Amthmtx nebttlmm (brown bullhead)
370
290
4-f
is
Atticiuni\ in S>llhnu\ (htou n htlllhc.Rli
321
280
B6
f'nnht\i\ nivr^mwtiUttm ihl.ivk crappte i
19S
235
4+
92
133
185
209
B7
Mi- ni,ul>h'ivnv 1 pumpkinseed!
25
101
—JT1
48
C6A
Lci>fiiii,s tIpumpkiiheedi
IS
92
2*
45
68
CIO
/{mi K«ii riaiiti/s (red 1 in pickerel!
37
174
2+
74
132
CI 1
l..wn imit isftinin (red !in pickereli
i7
175
2 +
«
141
€13
Leptunis t;iifhr\t>s ipumpkindeed)
49
137
3+
J8
69
100
CI?
l.stn yttiu'tii-tHitn ired I'm pickerel*
35
166
24
90
146
CIS
£w.» tttiwi o. nitii\ ipitkeirh
32
160
2+
_
115
C19
Mivrt>p!rm\ > hirgemoulh b;e>s)
258
255
4+
89
113
172
239
_
HistHiiii 1amene:tt' eel)
85
h
Xith'iiints nvhuhniis tbiowts bullhead 1
80
181
2+
E2
Amcinius r>tiwhf\us (bri>wn btillheadi
68
160
2+
E3A
t so\ tmifnatmf. (red fin pickerel)
2?
158
2+
94
139
E3B
tsm 1 red I'm pickerel)
28
15S
24
91
——
331
E3C
f-.Mn anient nnt/\ ! ied I'm piekeiel S
9
156
3*
89
118
F4A
/ i'/v>>iui\ vjhhrsin ipuiiipkmx'i'd<
5
b I
14
61
4kt*
Cnpimmmm t*l
5lnll«;fw
ir Mmwgumtnl
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APPENDIX E
SITE INSPECTION
Management System Review Memorandum
Wetland Inspection Memorandum
-------
MEMORANDUM
TO.
Cindy Me lane
DATE: August 15. 2014
l;ROM: Deborah A, Roberts, Ph.D., PWS
SUIilliCT: Bainl & Mdiuire Wetland Restoration Areas Assessment
On August 8, 2014, I conducted a site visit to assess the restored wetland and upland areas at the Baud
& McCiuire Superfund Site in flolbrook, MA. I met with Clean Harbors employees and conducted an
inspection of the restored areas of the site. The former monitoring locations, as documented in the
Final (2001) Vegetation Monitoring Report (Prepared by ENSR International dated December 2002),
no longer have existing stakes or markings. Approximate GPS locations, established from drawings in
the l-NSR, 2001 report were placed on a Google Earth hasemap and used to assist in finding the areas
where the former vegetation monitoring plots (U-1 to IM0 in the upland areas, and W-1 to \V-i() in the
wetland areas! were located. These GPS points, along with existing roads and monitoring wells were
used to navigate on site and the approximate areas of the former \egetati\e plots were assessed for the
five year review. A map with the approximate GPS points is attached as figure I.
In general, the wetland vegetation was well-established at all of the wetland areas inspected. Typical
wetland vegetation included: soft rush (./uncus e/fusasL American buir-reed (Spar^amuni
cimericaniim h woolgrass fSarpus cyperinusJ, dark-green bulrush {Scirptts uirorirens), wide-leaf cattail
I Typhii IdtifolktL narrow-leaved cattail f Typhit angttsttfolia), reed canary grass (I'halaris arttmitinnvith
giant goldenrod t'Soiulago xiganteu). lurid sedge (Carex htrida). fox sedge fCarex viiipinoidea). water
horehoiuid (fyct)piis ttmericannsK spotted touch-me-not (Inipatieth ar/w/v/.v). Canada rush fJuncas
canadensis). deer-tongue grass iDichanlheHwn clundestinum). rough-stem goldenrod (Solidago
rn^osai. sensitive ferti (thiocica sensihihsh Oat-top goldenrod (h'ulhamia i^raniinifohah and poison ivy
(Toxicodendron radicans). among others, were present in the herbaceous layer. Silky dogwood
(Comas atnomitm), Bebb wallow (Salix hchhiana), elderberry (Samhuais spj, red maple (Acer
ruhrumh Northern arrow-wood (I thurmtm dentaimn), green ash (T'raxinus pemtsyhantca). Cottonwood
saplings (Populus dehoides). speckled alder (Alnus riigo.su), highbush blueberry (I'uccmiitm
vorymbasitmh and grey birch (Ihinhi ptjpu/ifolia) were observ ed in the shrub layer of the restored
wetland areas at the site. Representative photos of the wetlands are included as Photos 1 to 5.
Consistent with observations from the prior five year review in 2009, restored upland
portions of the site appeared to be w ell-vegetated and stabilized. Vegetation in these upland
areas are similar to that observed in 2009. The dominant species consisted of various
grasses {Family: Poaeeae), black locust trees and saplings (Rahinia pseitdoacuciu), various
goklenrods {Solidago spp). common blackberry (Rubiis ailcghentensis)* bird's foot trefoil
(Lotus vormadaim). knapweed (Centaurca xtoebe), white pine f 1'ituis stntfwsh milkweed
{Asclephn spp,} and Quaking aspen (I'ofndtts ircmulokles). Common tansy (Tanaeetum
vulgate) lias become a dominant species over many areas. The white pine and black locust
trees ha\e shown significant growth.
-------
A new access road was constructed in the vieinit} of sampling plot W-6 to access a new
extraction well (RW ~10), The vegetation immediately in the vicinity of W-6 was not
disturbed (Photo 5), However, a small amount of till was placed in the wetland to construct
the access road (Photo 6).
Occasional patches of purple loosestrife were observed in the restored wetland areas.
Photographs included in the I NSR 2001 wetland plots indicated a dominance of purple
loosestrife, which is not as apparent under current conditions. In 2(KW, the field assessment
documented that the larvae uf (he Galerucella beetle were present on site. This beetle, along
with other species, has been released in Massachusetts as part of a biological control
program for purple loosestrife. Although no beetles were observed in 2014, active herbivorv
was apparent in the form of damaged leaves, and it appears this activity may be assisting in
controlling the purple loosestrife on site from becoming more dominant.
Several wetland areas onsite were dominated by phragmites fPhntgrnites ansira/L\i and
should be controlled by methods compatible with the site. Phragmites was the invasive
species which covered the most area at the site. Other invasive species, such as glossy
buckthorn (Rluimims frangHin) and reed canary grass (Phataris arnmifnaceu) were also
observed. The removal or control of these invasive species would enhance the habitat on
site. However, the wetland and upland vegetative communities appear to be thriving and
stable, and additional habitat enhancement is not required to meet the basic objectives of the
remedy.
environmental com
-------
Figure I. Approximate locations of former vegetation monitoring plots (W-l to W-10 and LJ-I to U-
10) at the Baird & McGwire Superfund Site in Holbrook, MA.
-------
Photographs
August 7, 2014
-------
mm
9PBBB1V
Photo 1. Wetland in the vicinity of W-l.
Photo 2. Wetland in the vicinity of W-9.
-------
Photo 4, Cochato River near W-8.
-------
Photo 6. Access to EW-10.
-------
Photo 7. Upland in the vicinity of U-l.
Photo 8, Upland in the vicinity of U-9.
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TECHNICAL MEMORANDUM
MANAGEMENT SYSTEM REVIEW AND TECHNICAL COMPLIANCE EVALUATION
BAIRD AND MCGUIRE SUPERFUND SITE
MANSFIELD. MASSACHUSETTS
JULY 2014
As part of the Five-Year Review for the Baird & McGwire Superfund Site in Holbrook, MA, a Management
System Review (MSR) has been performed which includes performance of a site inspection, review of the
remedy, and a technical compliance evaluation in order to evaluate whether each element of the remedy
is being maintained and operated in accordance with its intended function. This technical memorandum
includes a summary of the site inspection performed on June 11, 2014, as well as annotated photographs
of various site features taken on that date, and a technical assessment of physical features of the
remedy. The portion of the review associated with risk standards was submitted under separate cover on
July 21, 2014, in a memorandum entitled Assessment of Changes in Standards Memorandum
Background
The Baird & McGwire Superfund Site is located on South Street in Holbrook, MA (see Figure 1). The 1988
Record of Decision (ROD) defines the Site as the area within the EPA security fence constructed in July
1985. According to the Feasibility Study FS this fence encompasses all known areas of soil
contamination related to Baird & McGuire (GHR, 1988a). The Site boundary and coincident fence line
are shown on Figure 2, based on a Site survey conducted in May 1988 The Site designated on Figure 2
has been determined to consist of approximately 32.5 acres. For the purpose of increased security and
access control measures during remedial actions, additional fencing was constructed in some areas
beyond the Site boundary. This includes fencing around the groundwater treatment plant and recharge
basins, and fencing beyond the southern Site boundary.
As illustrated on Figure 2, the Site is not limited to land within the former Baird & McGuire properties.
Historically, Lots 130, 130-1 and 130-2 have had Baird & McGuire ownership. These tots consist of 9.33
acres, of which approximately 8 acres are within the Site boundaries. The remaining 24.5 acres of the
Site consist of portions of five privately owned lots and two lots jointly ownec by the towns of Holbrook
and Randolph. In addition, fojr privately owned tots located west of the Cochato River (Lots 6, 12-2 and
12-3) access to the river is restricted due to the presence of the security fence.
Figure 2 also shows significant ecological Site features, including the Cochato River, the unnamed brook,
the 100-year floodplain, and wetland areas. Based on a wetland boundary delineation conducted during
Rl investigations, wetlands occupied approximately 44 percent of the Site. In addition, 66 percent of the
Site was determined to be within the 100-year floodplain
History of Contamination
Baird & McGuire Inc. operated a chemical mixing and batching facility in northwest Holbrook.
Massachusetts from 1912 to "983. Manufactured products included herbicides, pesticides, disinfectants,
soaps, floor waxes and solvents. Waste disposal methods at the site included direct discharge into the
soil, a nearby brook and wetlands, and a former gravel pit in the eastern portion of the site. Underground
disposal systems were also used.
The state became involved between 1954 and 1977 and fined the company at least thirty-five times for
violations of the Federal Insecticide, Fungicide and Rodenticide Act of 194?
-------
questionable disposal practices, Baird & McGuire Inc. performed voluntary remedial actions from
February to April of 1982. In May 1982, the Board of Selectmen of Hoi brook revoked Baird & McGuire's
permit to store chemicals at the Site and ordered that existing storage facilities be dismantled As a
result, operations were terminated.
Initial Response
A hydrotogical study was completed by EPA which initiated some removal actions in 1983. These actions
included the removal of 1,020 cubic yards of contaminated soil. 1 ton of waste creosote. 25 gallons of
waste coal tar, 155 pounds of solid hazardous waste and 47 drums of flammable liquids and solids, and 2
drums of corrosives, EPA also oversaw construction of a clay cap, installation of a groundwater
interception-recirculation system, and erection of fencing. The Site was added to the National Priority List
(NPL) on September 8. 1983. EPA constructed a security fence in July 1985 to enclose the Site.
An RI/FS (1985/1986a, GHR) identified and described the presence of a groundwater contamination
plume, originating from the Baird & McGuire property and extending beyond the Cochato River, EPA
issued three RODs for the Site, defining four operable units and describing selected remedial alternatives.
More detail is provided in Appendix A of the Baird & McGuire Five Year Review Report.
At the time of the ROD, the Baird & McGuire Site was used for commercial and industrial purposes.
Currently, the Site is occupiec by the Groundwater Treatment Facility. Current and planned uses are still
commercial/industrial in nature,
REMEDIAL ACTIONS
Remedy Selection
EPA issued three RODs for tl-e Site, defining four operable units and describing selected remedial
alternatives. The first ROD. issued in September 1986. specified groundwater extraction and treatment
via art on-site treatment plant (OU-1) and soil excavation and treatment via an on-site incinerator {QU-2).
The second ROD, issued in September 1989. addressed contamination in the Cochato River sediments
(OU-3) EPA issued the final ROD in 1990. which called for reopening the Donna Road well field to
replace the lost supply resulting from contamination of the South Street wellfeld {GU-4).
The following sections summarize the selected remedies for Operable Units 1, 2, 3, and 4,
Operable Units 1 and 2
The remedial objectives for OU-1 groundwater and QU-2 soil are:
• Minimize the risk for tie human population of direct contact with soils/sediments
• Remediate the contaminated aquifer within a reasonable time period to prevent present or future
impacts to groundwater drinking supplies;
• Protect surface waters from future contaminant migration; and
• Minimize long-term management and/or maintenance requirements.
The selected remedial action for OU-1 includes the following components;
• Groundwater Extraction System:
• On-site Groundwater Treatment Facility: and
• Groundwater Recharge System
The extraction system consists of eight extraction wells. Currently, si* extraction wells (EW-3. EW-4A,
EW-6 EW-7 EW-8. and EW-9) are actively pumping contaminated groundwater to a groundwater
treatment facility, and four recharge basins are used to discharge treated groundwater back to the
aquifer. Extraction wells EW-i and EW-4 have been removed from service, and EW-2 and EW-5 are
2
-------
currently off-line. The groundwater extraction wells were located to contain the plume, A new extraction
well, EW-10, was installed in early 2014. The implementation of this system is described in the five year
review report
Based on the nature and extent of soil contamination documented in the Rt/FS, the 1986 ROD specified
Ihe excavation of soil from "hot areas" with subsequent treatment in an on-site incinerator, and on-site
disposal of the treated soil (ash). The hot areas were delineated in the ROD based on contamination
profiles developed in the Rt Addendum (GHR, 1936b). The limits of excavation were established so that
contaminant concentrations outside of the hot areas were one to two orders of magnitude lower than the
concentrations inside the hot areas. Also considered were the presence of wetlands and the extent of
contamination in those wetlands, with the intent of minimizing disruption to wetlands. The ROD notes that
although this approach results in residual soil contamination, future health risk for a trespasser scenario
would be within an acceptable range.
The selected remedial actions for GU-2 include the following components.
• Excavation with associated dewateririg and erosion control;
• Backfilling using treated soil into the excavation area,
• Extraction Well Piping Relocation at the end of the excavation process;
• Temporary relocation of the Unnamed Stream during remediation followed by restoration of its
natural course;
• On-Site Incineration and Stabilization (IS) Facility;
• Site Closure upon the completion of soil excavation and treatment;
• Site Restoration;
• Wetlands Restoration: and
• Continued Monitoring.
Operable Unit 3
The remedial objectives for OJ-3 (sediment in nver) were.
• Reduce human exposure to arsenic. DDT, PAHs, and chlordone in sediment by excavating to an
average depth of six (6 s inches and by achieving the following levels of contaminants. 250 ppm
for arsenic; 19 ppm for DDT; 5 ppm for chlordane; and 22 ppm for total PAHs These
concentrations correspond to a 1 x 10b to 1 x 10-' excess cancer risk level; and
• Reduce environmental exposure to those contaminants of concern to concentrations
corresponding to the mean sediment quality cnteria (SQC) (EPA, 1989) in the river bed. and to
the upper bound SQC in the wetland area north of Ice Pond,
The ROD specified excavation and incineration of approximately 1,500 cubic yards of contaminated
sediments for protection of public health and the environment. Sediments were to be excavated to an
average depth of six inches from approximately the center of the fenced Site area downstream to Union
Street. Sediments were to be transported to the on-site treatment facility, irrplernented under OU-2, and
subsequently placed as backfill on the Site.
The ROD also required erosion control, wetlands restoration, placement of organic fill in the excavated
areas of the river in the vicinity of the groundwater plume, and long-term monitoring of downstream
portions of the river where sediments were not excavated.
To minimize the disruption of wetlands, sediments were not to be removed from areas of the river where
contaminant concentrations were low. calculated risks were low, and no impacts were observed. In
accordance with ihe ROD for OU-3, long term monitoring is to be conducted to evaluate remaining
contaminant levels and their trends over time (EPA, 1989),
3
-------
Operable Unit 4
The remedial objectives for OU-4 were,
• To identify a candidate water source to replace the 0,31 million gallons per day (MGD) lost supply
from the closing of the South Street municipal well field in an environmentally sound, cost
effective manner without placing additional stress on the Great Pond Reservoir system or existing
water treatment facilities.
The selected remedy for 01)4 consisted of the following components:
• Permitting/Pre-design Studies;
• Groundwater Extraction;
• Groundwater Treatment: and
• Delivery to the Distribution System
On August 21, 2003, an Explanation of Significant Differences document (ESD) was issued for the
groundwater remedy (OU-1) specified in the 1986 ROD, The ROD was changed to include excavation of
soil from the Upper Reservoir/Great Pond located in Braintree and Randolph (approximately 400,000
cubic yards) to provide an additional storage capacity resulting in an estimated additional supply of 0.31
MGD to be used in the interim to supplement the community's drinking water until the groundwater
remedial action is complete. On this date, EPA also issued an ESD document for OU-4 stating that no
further action will be taken under this ROD.
Site Inspection
On June 11, 2014, Kimberly White of the US EPA and Cinthia McLane of AEGOM performed an
inspection of the Baird & McGuire site, Also present were Dorothy Allen and Patrick Hurley (part time) of
MassDEP. and Lisa Irwin, John Irwin (part time), Kandi Prentiss and Maggie Legorete of Clean Harbors
(the O&M Contractor for the MassDEP). The site inspection photos are included as Attachment 1.
The infiltration basins appeared to be in good condition, aside from some overgrowth. Portions of the
perimeter fence that could be observed from the site roads were in good condition. An attempt was made
to observe a number of the monitoring and extraction wells. Due to heavy overgrowth, not all of the wells
could be observed. Six of the eight extraction wells are in service. Extraction wells EW 2 and EW-S are no
longer in service, and personnel from the O&M Contractor Clean Harbors (CH) said that they are
experiencing problems with EW-6 that indicate that maintenance may be required soon. CH personnel
stated that EW-9 is in need of a new motor and redevelopment. This well currently produces
approximately 1 gpm. A new extraction well. EW-10. was recently installed (work was being done on the
well at the time of the site inspection) The location of EW-10 was selected based on results of an arsenic
study that was conducted by the MassDEP to better define the location of the arsenic plume.
The Extraction Well Control Building was briefly visited. The variable frequency drives (VFDs) for the
wells, located in the building, are no longer used to control flow, but are ieft open. Total flow to the GWTF
is approximately 80 gpm. The INAPL collection system is no longer in use. Currently, WAPt is collected
manually from extraction well EW-6, When collected, the NAPl is allowed to separate over time before
being drummed and shipped off-site. Approximately 2,5 gallons of NAPL were last collected in December
2013,
Patrick Hurley of the MassDEP led a tour of the GWTF and provided information on improvements that
have been made within the past five years, along with maintenance issues resulting from the age of much
of the equipment. In general, the GWTF continues to meet effluent discharge limits; however, the age of
the equipment has resulted in some difficulty for the operators, including difficulty finding spare and
replacement parts Various upgrades and safety measures have been implemented, including the
4
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replacement of high pressure sodium lighting with energy efficient LED lamps; the addition of new
variable frequency drives on tne aeration tank blowers: replacement of the potassium permanganate
tank; replacement of the GAC media with a longer-lasting coarser grade of carbon, and installation of new
tank railings and restraints. More detail of the improvements is provided in the attached Interview Record
for the O&M Contractor.
During the site visit and the interviews, effort to implement various recommendations from the 2013
Optimization Review Report (EPA, 2013) was discussed. Some of the recommendations were
implemented, such as completion of an arsenic speciation evaluation, installation of a new extraction well,
and collection of fish and sediment samples. Other recommendations were attempted or considered but
found not to be practical. These included discontinuing aeration in the activated sludge units, which was
attempted but resulted in clogging of downstream filters; and optimizing the metals removal system by re-
piping the two clarifiers to operate in parallel, which could not be accomplished due to space limitations in
the GWTf.
Interviews
The MassDEP Project Manager, the O&M Contractor (CH) personnel, and the Town Administrator for the
Town of Hoi brook were interviewed as part of the five year review process. The Holbrook Town
Administrator was interviewed by telephone, and the MassDEP Project Manager and CH personnel were
interviewed as a group during the site inspection. The Attachment 2 includes a detailed summary of the
interviews. In general, the Holbrook Town Administrator was not aware of any problems or complaints
related to the Site, and said that he last visited the Site about 3 years ago. The one concern noted by the
Town Administrator is the back taxes owed to the town by the property owners.
The overall sentiment of the MassDEP Project Manager is that decisions need to be made at a higher
level regarding the source of continuing contamination (particularly arsenic) and approach to future
remediation developed. She said that she agrees with recommendations in the Optimization Review and
referenced a Decision Tree that she had prepared, which she provided by email following the Site
Inspection, Details of the interview and a copy of the Decision Tree are included in Attachment 2.
CH personnel stated that the GWTF is functioning well, although due to the age of the facility, it has been
difficult to find spare and replacement parts, Their main issue is the high arsenic concentration in the
groundwater. They have tried to pinpoint the source of the arsenic and to locate the new extraction well to
best capture the arsenic plume. Improvements and modifications to the facility were discussed, as
described above. Monitoring frequency and staffing were discussed (see the Interview Record in
Attachment 2 for details). No complaints or intruders were noted, other than kids cutting through the town
land on the other side of the fence near the extraction wells. The O&M staff did express concern
regarding the impact that the proposed redevelopment of Lot 3 will have on site operations and access to
the extraction and monitoring wells due to the developer's proposal to move the fence to the property line
(the fence currently crosses part of Lot 3 and would be relocated as part of the redevelopment).
j6^0jcM^or^i[an^^__Evak^ahon_o£R^ie^_,Cj^i|2O£ejife
The technical compliance evaluation is conducted to determine whether the individual components of the
remedy are being maintained and operated in accordance with their intended functions.
Evaluation of Intended Function;
OU1 and OU2
5
-------
• The MassDEP and O&M Contractor Clean Harbors continue to operate and maintain the
GWTF The RAOs of remediating the contaminated aquifer within a reasonable time period is
being addressed by the GWTF, Improvements and investigations intended to optimize
operations are ongoing
* The RAO of protecting surface waters from future contaminant migration is being addressed
by containment via the groundwater extraction system. Surface water monitoring data are no
longer collected as the prior two five-year reviews evaluated the most recent data (from 2000)
and found results to be well below EPA's target risk range of 10" to 104.
• The EPA conducted an Optimization Review which considered remedy performance,
protectiveness, cost-effectiveness, technical improvement, and site closure strategy. As
discussed above, the MassDEP has implemented some of the recommendations of the
Optimization Review and has evaluated and attempted others. This effort is ongoing, and
addresses the RAO of minimizing long-term management and/or maintenance.
OU3
• The 2013 data show exceedsnces of the PAH cleanup level at Stations E {adjacent to the
site) and A (upstream of the project area). The exceedance at Station E is within the range of
historic detections (although much higher than the last two monitoring events), but the
upstream sample {Station A) is at least one order of magnitude above any historic detections.
It appears that further monitoring should be performed for confirmation of these
exceedances, and that additional upstream characterization may also be needed to
determine if there have been any recent upstream releases contributing to the residual
contamination in the sediment adjacent to the site. More detail is provided in the five year
review report
References
GHR Engineering Associates (GHRi 1986a, Final Feasibility Study Report, Baird & McGuire Site.
Holbrook, MA. Prepared for NUS Corporation, and U.S. Environmental Protection Agency. July 18.
1986a..
GHR Engineering Associates (GHR). 1988b. Final Addendum Report, Remedial Investigation Phase If.
June 1986
U.S. Environmental Protection Agency (USEPA). 1986. Record of Decision Baird & McGuire Site,
Holbrook. Massachusetts September 30, 1986.
U.S. Environmental Protection Agency (USEPA). 1989 Record of Decision Summary, Baird «8 McGuire
Site/Sediment Study Area. Holbmok. Massachusetts. September 14. 1989.
U.S. Environmental Protection Agency (USEPA). 1990, Record of Decision. Baird & McGuire/Aiternate
Water Supply. Holbrook. Massachusetts. September 27.1990.
U.S. Environmental Protection Agency (USEPA). 2013. Optimization Review. Baird & McGuire Superfund
Site, Town of Holbrook. Norfolk County. Massachusetts. EPA-542-R-13-003 May 2013.
6
-------
FIGURES
-------
|\J Ho,fbtmk,m
^ KksGIS Scanned OSGS Quae* \
-------
\
\\
-------
ATTACHMENT 1
SITE PHOTOS
-------
BAIRD & McGUIRE SUPERFUND SITE
June 11, 2014 - SITE INSPECTION PHOTOGRAPHS
Pnoti- #1. L-'1' k"1'.! n"-rtiir,i--t -i • ross nif lr.it on 'is
Photo #2. Looking southeast across infiltration Basin
TO0088-BAIRD McGUIRE SITE INSP-061114-500 1
-------
Photo #3, MW 906
Photo #4, Looking southeast towards the gate on Holbrook Property
TO0068-BAIRD McGUIRE SITE INSP-061114-500 2
-------
Pho to »5 ! O'.-kiii!! southwest towanls tnc S.v pcii noter fence
Photo #6. Reconstructed Wetlands
T00068-8AIRD McGUIRE SITE INSP-061114-500 3
-------
Photo #7. Monitoring well along road bordering Lot 3
Photo #8, Looking north towards Lot 3. proposed for redevelopment
T00066-BAIRD McGUIRE SITE INSP-061114-500
4
-------
Photo #9. Looking north towards MW 913 on Lot 3. proposed to-- rcticvuiopment
Photo #10. New Extraction well EW-10
T00066-BAIRD McGUIRE SITE INSP-061114-500 5
-------
Photo #12. Looking east from EW-10 towards new monitoring welt MW14-02
TO006&-BAIRD_McGUIRE.S!TE INSP-061114-500 8
-------
Photo #13. L. "ikni") s.- uiiKvest on Lot 130-2 towards area of proposed solar panel development
Photo = 1 -i. vfd iur new EW-10
T00066-BAIRD_McGUIRE SITE INSP-061114-500 ?
-------
Photo #16. Aeration Tanks
T00066-BAIRDMcGUIRE SITEJNSP-061114-500 8
-------
Photo #1?. Fish advisory sign, located on Centre Street in Holbrook near western shore of Sylvan
Lake
Photo #18, Fish advisory sign, located on Centre Street in Holbrook near western shore of Sylvan
Lake
TOOO86-BAIRD McGUIRE SITE INSP-Q8! 114-500 9
-------
ATTACHMENT 2
INTERVIEW RECORDS
-------
INTERVIEW RECORD
Site Name: Baird & McGuire Superfund Site (Hoibrook, MA)
EPA ID No.: MADO01041987
Subject: Five Vear Review
Time: 1322
Date: 7-21-14
Type: GO Telephone
Location of Visit:
O Visit
O Other
~ Incoming El Outgoing
Contact Made By:
Name: Joel Mourner
Title: Project Scientist
Organization: AECOM
individual Contacted:
Name: William J, Phelan
Title: Town
Administrator
Organization: Town of Holbrook
Telephone No; 781-787-4312
E-Mail:
wphelan@h0lbrookma55acbu5etts.us
Street Address: Holbrook Town Ha!!
50 North Franklin Stiw-i
Holbrook MA 02343
1. What is your overaH impression of the project? (general sentiment)
Mr, Phelan stated that the Site has almost been forgotten about.
2. Do you feel welt informed about site activities and progress?
Not particularly; Mr Phelan said he has never read or seen a report for the Site
(although he was aware that the public library was the repository for said reports)
3 What are the current uses of the property"?
Mr, Phelan said that the Site was currently unused
4. What are the planned future uses of the property (if different from current
uses)?
Mr. Phelan stated that he had heard a rumor that someone wanted to place a solar
farm on the Site property
P.im l uil
-------
5. is there evidence or sightings of trespassers on the property? if yes, how
often and what type of activities do they engage in?
Mr. Phelan stated that he had not seen or heard of any trespassers on the Site
property.
6. Have there been any events of vandalism at the property?
Mr. Phelan stated that he was unaware of arty vandalism at the Site property
7. Have there been any unusual or unexpected activities or events at the site
(e.g., flooding)? If so. what if anything was done to address these issues?
Mr. Phelan stated that he was unaware of any unusual or unexpected activities or
events at the site.
8. Have any problems been encountered or changes in the site conditions that
affect the current operations at the site?
Mr. Phelan stated that he was unaware of any such problems.
9. Has the site been the subject of any community complaints (e.g., odor,
noise, health, etc..)?
Mr. Phelan stated that he was not aware of any such complaints
10. Are you aware of any community concerns regarding the site or remedial
actions performed? ff so, please provide details.
Mr. Phelan stated that ho was not aware of any such concerns
11. Have there been routine communications or activities (site visits,
inspections, reporting activities, etc.) conducted by your office regarding the
site? If so. please give purpose and results.
Mr. Phelan and a selectman went to the Site about 3 years ago to visit the site.
12. Do you have any comments, suggestions, or recommendations regarding
site management or operation?
Mr. Phelan stated that he had nothing additional to add.
13. Is there any other information that you wish to share that might be of use?
Mr, Phelan stated that back taxes are owed on the property and he would like to see
the paid.
2 «i:
-------
INTERVIEW RECORD
Site Name: Baird & McGuire Superfund Site (Holbrook, MA)
EPA ID No : MAD001041987
Subject: Five Year Review
Time:
Date: 6/11/14
Type: O Telephone S Visit O Other
Location of Visit: Baird & McGuire GWTF
O Incoming ~ Outgoing
Contact Made By:
Name: Cinthia Mclane
Title: Project Manager
Organization. AECOM
individual Contacted:
Name: Dorothy Allen (with input from Pat
Hurley during GWTF inspection/tour)
Title: State
Remedial
Project manager
Organization: MassDEP
Telephone No: {617)292-5795
E-Mail Address:
dorothytallen@state.ma. us
Street Address:
I Winter Street
Boston, MA 02108
{Note - MassDEP is currently the lead agency for the site and maintains a full-time presence. A
group interview was conducted with the MassDEP and the O&M Contractor, Clean
Harbors)
1. What is your overall impression of the project? (general sentiment). Ms Alien stated that
she agrees with the optimization study, and the need to make decisions arid follow-up on them
2. ts the remedy functioning as expected? How well is the remedy performing? She
questioned whether pumping
-------
7.
8.
9.
10.
11.
task force meetings, but few people showed up for them and they were discontinued.
Do you have any comments, suggestions, or recommendations regarding the site's
management or operation? Ms. Allen stated that she would prov de a Decision Tree by email
following the meeting (attached). Decisions need to be made at the upper management level.
Are you aware of any problems or issues that wilt affect the progress or implementability
of the proposed institutional controls? Ms. Allen questioned the status of the proposed
transfer station [on Lot 3], how to document to the owner what the ICs will be based on, whether
soil/ash will be a factor in developing the ICs. Will need to negotate with the transfer station
regarding fence line.
Is there evidence or sightings of trespassers on the property, or evidence of vandalism?
If yes, how often and what type of activities do they engage in?
See interview with Clean Harbors (O&M Contractor).
Have there been any unusual or unexpected activities or events at the site (e.g..
flooding)? If so. has this resulted in any damage or had an impact on operations at the
site?
See interview with Clean Harbors (O&M Contractor),
ts there any other information that you wish to share that might be of use9 Mr- All.:,?
stated that she does not want to wait for another five year review before moving forward with
the decision tree (attached).
Pnm 2 2
-------
INTERVIEW RECORD
Site Name: Baird & McGuire Superfund Site (Hoibrook, MA)
EPA ID No : MAD001041987
Subject: Five Year Review
Time: Date:
Type: ~ Telephone B Visit O Other
Location of Visit: Baird & McGuire GWTF
~ Incoming ~ Outgoing
Contact Made By;
Name: Cinthta McLane Title: Project Manager
Organization: AECOM
Individ
ual Contacted;
Name: Lisa Irwin, John Irwin, Maggie
Legorete, Kandi Prentiss (with input from Pat
Hurley during GWTF inspection/tour).
Title: O&M
Contractor
Manager/Operator
Organization: Clean Harbors
Telephone No:
E-Mail Address:
Street Address:
775 South Street
Hoi brook, MA 02343
1. Is the remedy functioning as expected? How well is the remedy performing7 The GWTF
is functioning well. The main issue is arsenic concentration in groundwater, which is up to 2.9
ppm.
2. What does the monitoring data show? Are there any data trends that appear unusual?
What is the current monitoring program for the GWTF and lNAPL systems? Arsenic
pesticides. VOCs. SVOCs are present m separate areas. CH has tried to pin-point the center of
the elevated arsenic to best locate new extraction well EW-10. Arsenic in some wells declined
while no trend was noted in others, Organics concentrations decreased,
All monitoring wells arc sampled every five years; 20 wells arc sampled annually, extraction
wells are sampled quarterly.
3. Please describe the O&M staff and activities, including frequency of inspections and
O&M activities. The facility is staffed as follows: one mechanic 4 days/week; 2 operators 5
days/week; 1 operator for 4 hours on Saturdays and Sundays; plus an operator on-call during
off-hours and all day Saturday and Sunday. O&M activities are described in the O&M reports.
4, Have there been unexpected O&M difficulties or costs at the site in the last five years? if
so, give details. In general, most of the equipment is so old that finding spare or replacement
parts has been difficult. An attempt was made to take the bio tanks off-line, but this resulted in
clogging of the 6AC units and filters
I'atii 1 ni 3
-------
5. Have there been any updates to the O&M manual since the last 5-year review, and are the
O&M activities being performed consistently with the approved O&M and monitoring
plans? The O&M manual was revised when O&M of the facility went out to bid last year;
however changes were insubstantial. Plant upgrades that have been made over the years
haven't required changes to the manual.
Monitoring is conducted in accordance with the plan.
(v What are the annual system operation/O&M costs for OU-1 since the previous 5-year
review in 2009? Information provided by Patrick Hurley;
Total Cost
FY 2010
900,876,69
2011
820,363,05
2012
948,887.00
2013
814,787.95
2014 (est)
730,175.87
7 Have there been any significant changes in the O&M requirements, maintenance
schedules, or sampling routines in the last five years? If so. do they affect the
protectiveness or effectiveness of the remedy? Ptease describe changes and impacts.
None noted.
3, Have there been opportunities to optimize O&M, or sampling efforts since the last five
year review? Please describe changes and resultant or desired cost savings or
Improved efficiency. High pressure sodium lamps were replaced with LED lighting and new
VFDs on the aeration blowers were installed, decreasing electric costs from approximately $550
per month to between S200 to $300 per month.
An attempt to lower potassium permanganate dosage, but this resoled in a loss of clarity.
A change to a coarser GAC media was made, which resulted in a significantly longer GAC life.
The old type of media had to be replaced every 4 months; the new media lasts up to 14 months.
Mew safety features, including new railings on tanks and restraints with hook-ups to prevent
falls have been installed in the GWTF.
3. Have there been any security issues in the last 5 years? Is there evidence or sightings of
trespassers on the property, or evidence of vandalism? If yes. how often and what type
of activities do they engage in? Nothing on-site. Kids cut through the town land on the other
side of the fence near the extraction wells.
10. Have there been any complaints, violations, or other incidents related to the site? If so,
please give details of the events and results of the responses. Non«
11. Have there been any unusual or unexpected activities or events at the site (e.g..
flooding)? If so, has this resulted in any damage or had an impact on operations at the
site?' The river periodically floods. Most of the extraction wells are located above the flood
elevation, except EVV-2. flooding has not resulted in a plant shut-down
I'ayc 2 of 3
-------
12. Do you have any comments, suggestions, or recommendations'regarding the site's
management or operation? None noted (Dorothy Alien of MassDEP responded to this
question).
13. Is there any other information that you wish to share that might be of use? Concerns were
expressed regarding the potential impact that the proposed transfer facility could have on the
Site, including concerns with access to the well fields and the on-site roads. MassDEP/EPA
and the developers will need to work together on the institutional conti
I'aije 3 of 3
-------
Decision Chart for k Remediation
Existing P&T (600K/yr) with Monitoring
(lOOK/yr).
Continue Arsenic
treatment via P&T in all
areas of the site and
remove LNAPL as
encountered.
Operate (400K/yr) and
Monitor (lOOK/y;
no
Perform Capture Zone Analysis and If;
Extraction wells {250K}.
Perform Plant Up-grade (1,25 Mi.
Consider Third P^.tv PV tc save ?.QK/y
OONtW*
M o 11 i t o >'i i -i s (S ? i.
Are Aise
Arsenic ORP Bench Scale Study (25KI.
tvafuate Feasibility of
and Monitoring,* >
no
X
T
i®|HllRlllililt^SW:4tt-
Perform Fu;J Site
Oiaiacteriistion of INAPl
Standards, Cieanuo Cr.-terip
and Monitonns *'
(Costs) Estimates developed for some action items in EPA Optimization
Study, May 2013,
* Program decisions required in coordination with EPA.
** EPA ROD changes required.
-------
APPENDIX F
INTERVIEW RECORD FORMS
-------
INTERVIEW RECORD
Site Name: Baird & McGuire Superfund Site (Hoibrook, MA)
EPA ID No.: MADO01041987
Subject: Five Vear Review
Time: 1322
Date: 7-21-14
Type: GO Telephone
Location of Visit:
O Visit
O Other
~ Incoming El Outgoing
Contact Made By:
Name: Joel Mourner
Title: Project Scientist
Organization: AECOM
individual Contacted:
Name: William J, Phelan
Title: Town
Administrator
Organization: Town of Holbrook
Telephone No; 781-787-4312
E-Mail:
wphelan@h0lbrookma55acbu5etts.us
Street Address: Holbrook Town Ha!!
50 North Franklin Stiw-i
Holbrook MA 02343
1. What is your overaH impression of the project? (general sentiment)
Mr, Phelan stated that the Site has almost been forgotten about.
2. Do you feel welt informed about site activities and progress?
Not particularly; Mr Phelan said he has never read or seen a report for the Site
(although he was aware that the public library was the repository for said reports)
3 What are the current uses of the property"?
Mr, Phelan said that the Site was currently unused
4. What are the planned future uses of the property (if different from current
uses)?
Mr. Phelan stated that he had heard a rumor that someone wanted to place a solar
farm on the Site property
P.im l uil
-------
5. is there evidence or sightings of trespassers on the property? if yes, how
often and what type of activities do they engage in?
Mr. Phelan stated that he had not seen or heard of any trespassers on the Site
property.
6. Have there been any events of vandalism at the property?
Mr. Phelan stated that he was unaware of arty vandalism at the Site property
7. Have there been any unusual or unexpected activities or events at the site
(e.g., flooding)? If so. what if anything was done to address these issues?
Mr. Phelan stated that he was unaware of any unusual or unexpected activities or
events at the site.
8. Have any problems been encountered or changes in the site conditions that
affect the current operations at the site?
Mr. Phelan stated that he was unaware of any such problems.
9. Has the site been the subject of any community complaints (e.g., odor,
noise, health, etc..)?
Mr. Phelan stated that he was not aware of any such complaints
10. Are you aware of any community concerns regarding the site or remedial
actions performed? ff so, please provide details.
Mr. Phelan stated that ho was not aware of any such concerns
11. Have there been routine communications or activities (site visits,
inspections, reporting activities, etc.) conducted by your office regarding the
site? If so. please give purpose and results.
Mr. Phelan and a selectman went to the Site about 3 years ago to visit the site.
12. Do you have any comments, suggestions, or recommendations regarding
site management or operation?
Mr. Phelan stated that he had nothing additional to add.
13. Is there any other information that you wish to share that might be of use?
Mr, Phelan stated that back taxes are owed on the property and he would like to see
the paid.
2 «i:
-------
INTERVIEW RECORD
Site Name: Baird & McGuire Superfund Site (Hoibrook, MA)
EPA ID No : MAD001041987
Subject: Five Year Review
Time: Date:
Type: ~ Telephone B Visit O Other
Location of Visit: Baird & McGuire GWTF
~ Incoming ~ Outgoing
Contact Made By;
Name: Cinthta McLane Title: Project Manager
Organization: AECOM
Individ
ual Contacted;
Name: Lisa Irwin, John Irwin, Maggie
Legorete, Kandi Prentiss (with input from Pat
Hurley during GWTF inspection/tour).
Title: O&M
Contractor
Manager/Operator
Organization: Clean Harbors
Telephone No:
E-Mail Address:
Street Address:
775 South Street
Hoi brook, MA 02343
1. Is the remedy functioning as expected? How well is the remedy performing7 The GWTF
is functioning well. The main issue is arsenic concentration in groundwater, which is up to 2.9
ppm.
2. What does the monitoring data show? Are there any data trends that appear unusual?
What is the current monitoring program for the GWTF and lNAPL systems? Arsenic
pesticides. VOCs. SVOCs are present m separate areas. CH has tried to pin-point the center of
the elevated arsenic to best locate new extraction well EW-10. Arsenic in some wells declined
while no trend was noted in others, Organics concentrations decreased,
All monitoring wells arc sampled every five years; 20 wells arc sampled annually, extraction
wells are sampled quarterly.
3. Please describe the O&M staff and activities, including frequency of inspections and
O&M activities. The facility is staffed as follows: one mechanic 4 days/week; 2 operators 5
days/week; 1 operator for 4 hours on Saturdays and Sundays; plus an operator on-call during
off-hours and all day Saturday and Sunday. O&M activities are described in the O&M reports.
4, Have there been unexpected O&M difficulties or costs at the site in the last five years? if
so, give details. In general, most of the equipment is so old that finding spare or replacement
parts has been difficult. An attempt was made to take the bio tanks off-line, but this resulted in
clogging of the 6AC units and filters
I'atii 1 ni 3
-------
5. Have there been any updates to the O&M manual since the last 5-year review, and are the
O&M activities being performed consistently with the approved O&M and monitoring
plans? The O&M manual was revised when O&M of the facility went out to bid last year;
however changes were insubstantial. Plant upgrades that have been made over the years
haven't required changes to the manual.
Monitoring is conducted in accordance with the plan.
(v What are the annual system operation/O&M costs for OU-1 since the previous 5-year
review in 2009? Information provided by Patrick Hurley;
Total Cost
FY 2010
900,876,69
2011
820,363,05
2012
948,887.00
2013
814,787.95
2014 (est)
730,175.87
7 Have there been any significant changes in the O&M requirements, maintenance
schedules, or sampling routines in the last five years? If so. do they affect the
protectiveness or effectiveness of the remedy? Ptease describe changes and impacts.
None noted.
3, Have there been opportunities to optimize O&M, or sampling efforts since the last five
year review? Please describe changes and resultant or desired cost savings or
Improved efficiency. High pressure sodium lamps were replaced with LED lighting and new
VFDs on the aeration blowers were installed, decreasing electric costs from approximately $550
per month to between S200 to $300 per month.
An attempt to lower potassium permanganate dosage, but this resoled in a loss of clarity.
A change to a coarser GAC media was made, which resulted in a significantly longer GAC life.
The old type of media had to be replaced every 4 months; the new media lasts up to 14 months.
Mew safety features, including new railings on tanks and restraints with hook-ups to prevent
falls have been installed in the GWTF.
3. Have there been any security issues in the last 5 years? Is there evidence or sightings of
trespassers on the property, or evidence of vandalism? If yes. how often and what type
of activities do they engage in? Nothing on-site. Kids cut through the town land on the other
side of the fence near the extraction wells.
10. Have there been any complaints, violations, or other incidents related to the site? If so,
please give details of the events and results of the responses. Non«
11. Have there been any unusual or unexpected activities or events at the site (e.g..
flooding)? If so, has this resulted in any damage or had an impact on operations at the
site?' The river periodically floods. Most of the extraction wells are located above the flood
elevation, except EVV-2. flooding has not resulted in a plant shut-down
I'ayc 2 of 3
-------
12. Do you have any comments, suggestions, or recommendations'regarding the site's
management or operation? None noted (Dorothy Alien of MassDEP responded to this
question).
13. Is there any other information that you wish to share that might be of use? Concerns were
expressed regarding the potential impact that the proposed transfer facility could have on the
Site, including concerns with access to the well fields and the on-site roads. MassDEP/EPA
and the developers will need to work together on the institutional conti
I'aije 3 of 3
-------
INTERVIEW RECORD
Site Name: Baird & McGuire Superfund Site (Holbrook, MA)
EPA ID No : MAD001041987
Subject: Five Year Review
Time:
Date: 6/11/14
Type: O Telephone S Visit O Other
Location of Visit: Baird & McGuire GWTF
O Incoming ~ Outgoing
Contact Made By:
Name: Cinthia Mclane
Title: Project Manager
Organization. AECOM
individual Contacted:
Name: Dorothy Allen (with input from Pat
Hurley during GWTF inspection/tour)
Title: State
Remedial
Project manager
Organization: MassDEP
Telephone No: {617)292-5795
E-Mail Address:
dorothytallen@state.ma. us
Street Address:
I Winter Street
Boston, MA 02108
{Note - MassDEP is currently the lead agency for the site and maintains a full-time presence. A
group interview was conducted with the MassDEP and the O&M Contractor, Clean
Harbors)
1. What is your overall impression of the project? (general sentiment). Ms Alien stated that
she agrees with the optimization study, and the need to make decisions arid follow-up on them
2. ts the remedy functioning as expected? How well is the remedy performing? She
questioned whether pumping
-------
7.
8.
9.
10.
11.
task force meetings, but few people showed up for them and they were discontinued.
Do you have any comments, suggestions, or recommendations regarding the site's
management or operation? Ms. Allen stated that she would prov de a Decision Tree by email
following the meeting (attached). Decisions need to be made at the upper management level.
Are you aware of any problems or issues that wilt affect the progress or implementability
of the proposed institutional controls? Ms. Allen questioned the status of the proposed
transfer station [on Lot 3], how to document to the owner what the ICs will be based on, whether
soil/ash will be a factor in developing the ICs. Will need to negotate with the transfer station
regarding fence line.
Is there evidence or sightings of trespassers on the property, or evidence of vandalism?
If yes, how often and what type of activities do they engage in?
See interview with Clean Harbors (O&M Contractor).
Have there been any unusual or unexpected activities or events at the site (e.g..
flooding)? If so. has this resulted in any damage or had an impact on operations at the
site?
See interview with Clean Harbors (O&M Contractor),
ts there any other information that you wish to share that might be of use9 Mr- All.:,?
stated that she does not want to wait for another five year review before moving forward with
the decision tree (attached).
Pnm 2 2
-------
Decision Chart for Baird&McGuire Remediation
Containment
Potential Source Remedy
Existing P&T (600K/yr) with Monitoring
(lOOK/yr).
1
r
Refine Conceptual Model ( $?) of Arsenic
contamination using existing and new
site data. Collect new data and Perform
Arsenic ORP Bench Scale Study (25K).
Continue Arsenic
treatment via P&T in ail
areas of the site and
remove LNAPL as
encountered.
Operate (400K/yr) and
Monitor (lOOK/yr) long
term after improvements.
Perform Capture Zone Analysis and Install
Extraction wells (250K).
Perform Plant Up-grade (1.25 M).
Consider Third Party PV to save 20K/yr on
power.
Implement Source Remv, y
wo P&T (8.2M).
Monitoring ($?).
Implement Source Remedy
(8.45M) w/existing P&T
(700K/yr). Monitoring ($?)
Implement Source Remedy
(9.7M) w/up-graded P&T.
(500K/yr). Monitoring ($?)
Perform Full Site
Characterization of LNAPL
(400K) and Design Full-Scale
Source Remediation ($?).
Develop Performance
Standards, Cleanup Criteria
and Monitoring.**
(Costs) Estimates developed for some action items in EPA Optimization
Study, May 2013.
* Program decisions required in coordination with EPA.
** EPA ROD changes required.
-------
APPENDIX G
RISK CALCULATIONS
-------
TABLE 4 RME
VALUES USED FOR DAILY INTAKE CALCULATIONS
REASONABLE MAXIMUM EXPOSURE
BAIRD 5, MCGUIRE SUPERFUND SITE
See nana Timotramo Future
Medium Ash
Exposure Medium Ash
Exposure Route
Receptor Population
Receptor Age
EL»0O3ur» Point
ParamBiBf
Parameter DetVUion
Va tuw
linos
Rationale/
intake EquatoiV
Code
Reference
Model Name
Ingestion
Comm Worker
AduH
Site
CS
Chemical Concentration in Ash
mg/kg
Chronc Daify Intake (CDI) imgiKg-day) =
tR
Ing&fcrion Ra te of Soil
50
Wtey
USEPA. 1997a
CS MR ? F1 ? EF * ED * CF *! RBA
R
Fr#c<'on Ingested
1
unities*
Prof Judgement
BW* AT
EF
Exposure Frequency
250
diiyVy^sr
Prof Judgement
ED
Exposure Duration
25
years.
Prof Judgement
BW
Body Weight
80
Kg
USEPA. 2014b
RBA
Relative Bioavailability
0 6 tor Arsenic/1 for all
USEPA, 2012
other anatytes
AT-C
Averaging Time (Cancer)
25550
days
IJSEPA 1989
AT-N
Averaging Time (Non-Cancer)
9,125
days
USEPA. J 909
CF
Convers»ooFecto«
0 000(101
kg^ng
..
Ingestion
Tnespascsr*
Adolescent
S«c
CS
Chemcal Concentration in Ash
mgfcg
Chronic Daily Intake (CDI) (mg/kg-day) =
(ages 7.17}
IR
Ingestion Rate of Soil
~00
mtyday
USEPA 1997a
CS * IF* * Ft K EF * ED * CF « R0A
Fl
Fraction Ingested
i
unities*
Prof Judgement
BWxAT
EF
Exposure Frequency
60
days/year
Prof Judgement
ED
Exposure Duration
10
years
Prof Judgement
BW
Bod1/ Weight
40
Kg
USEPA. 2014b
RBA
Relative Bioavaibtatfy
li 6 tor Arsenic 1 for alt
•-
USEPA. 2012
off (fit anat/tes
AT-C
Averaging Tim* (Cancer)
25.550
days
USEPA. 1989
ATM
Averaging Time (Nnn Cancer)
3.550
day*
USEPA, 1989
CF
Conversion Factor
0000001
kgfrng
talJetA I
UMlrl MiMia4lli>u|Tiw«t» UML-(iiuH
-------
TABLES
NON-CANCER TOXICITY DATA - ORAUDERMAL
Chemcal
of Potential
Concam
Chrome/
Subchromc
Oral RfD
Oral Absorption
EfflcJuncy tar Donrel
(1)
Absorbed RfD for Dermal
(2)
Primary
Target
Organic)
ComDinoo
Uncertainty/Modifying
Factor*
RfD Target Organs)
Value
Units
Valuti
Units
SuLJCotsi
Date(s)
iMM/DDAVYY)
Diown TEQ
Chronic
7E-10
mgl^o-day
(4)
7E-10
mg/kg-OBy
Reproductive
30
IRIS
05/29/W
Ar««mc
Chronic
3E-04
mO^g-day
W
3E-04
mg/Vcg-uay
Stun
3
IRIS
0SJ28/H
O'Qxtn TEC
SubcfjnorMc
7E-10
»ngfcg-«1ay
(4}
7E-10
mQ/fco-ilay
Reproductive
30
IRIS
05/29/14
Areerwc
Subchromc
3E-04
mgfcg-day
<4J
.TE-04
rngA^rtsy
Skin
3
IRIS
05/29/14
(11 Oral absorption effiuencies from RAGS Part E (L'SEPA. 2004a> IRIS = Integrated Risk Information System
N'A s Not Apphcat*
(?) OlculflteO a* {oral RfD J x {oral lo dormai ad,uslnmni factor)
(41 Oral at*orp hnaro(a(f.yr«nn = 0 3, p**ntncWe>rot*ienoA = 0 dioxm and or sonic = D 0.1
tnkj^At
••Hint
UtlM
-------
TABLE 6
CANCER TOXICITY DATA - QRAL/OERMAL
Chemical
Oral Cancar Sope Factor
Oral Absorption
Absoroed Cancer Stope Factor
Weight ot Evidence/
Oral CSF
of Potential
Efficiency for Dermal
far Dermal
Cancer Guideline
Concern
Value
Units
Value
Unrts
Description
Sources)
Date^sj
111
i2}
(MMVDD/VYYY)
Dioxin TEO
1 3OE+05
(mgrtttHtoVJ '
in
1 3QEM15
(raq^taCHifty) 1
B2
OHEA
1985
Arsenic
15E+00
irnjrt«>aay) '
m
1 5E+00
Img^m-dayi
A
IRIS
(fc/29/14
IRIS = mtograteo Risk information Sysfatnn
OHEA = Office of Health and Environmental AisassmerB
RME - Reasonable Maximum Exposure
CT - Central Tendency
hi A - Nol Apptcabta
11 i Oral absorption efficiency exceeds 50% Therefore, no Bdlustmcnt ol the oral slope factor is necessary
(2) Caltufeted as (oral slope factor) l |oi«i (o dermal adjustment factor!
EPA Group
A - Human carcinogen
61 - Probable human carcinogen - indicates that IrnHftdhuman data am availafie
B2 • Probable human carcinogen - indicates sufficient evitence in animate and
inadequate or no evidence n humans
C - Possible human carcinogen
D - No! classifiable as a human carcinopm (by trw oral 'cmJ**!
E - Evidence at noncarcmogemcify
1/lVWI
UM»^u«lu>n0^ir|M»H
-------
TABLE 7.RME
CALCULATION Of CHEMICAL CANCER RISKS AND NON-CANCER HAZARDS
REASONABLE MAXIMUM EXPOSURE
BAWD * MCGURE SUPERFUND SITE
|Sc»narw> Timeframe Future
Recent* Population Goron Wortw
|ftec«pfcw Age AtM
Mat»u"
Exposure Martian
Expos*re Point
E*po4ure Roule
Chemcal n<
EPC
Cjpt*r RisM Calculations
Non-Cap«?r Hazard CafcutetWrs
Polecat Concern
VaUe
Untla
iniaWe'E^pos^re Concaniratian
CSFajnURte*
Cancer Risfc
lnldke'E*posu/e Concentration
WB-RfC
Haartl Quotient
Value
Units
Value
Urn Is
V3LH
Units
Value
Units
Am
AW1
&I8
lr«»stii>-.
Oto«in TEQ
1E-03
^'VO
t 7E-10
rrg/Vg-day
I.S6E-05
(mgrM?***) 1
26E-D5
4 7E.1Q
rngftg«<1ay
7DE.10
ITO^Q-rlflY
6 7E-01
Af+aruc
TEH) 1
mp*B
0 ^E-C»«
rngr>Q-<]t»y
t SE'OO
(n^riq-ttftyl •'
1»2E-06
1 ?E-06
rrg^g-<)ey
94E4*
tr^k^Hjey
5 7E-OT
E*p HcMe Tp«il
4E-05
7E-01
Expc<$ttna Poirtl Total
4E-Q5
7E-01
E«rcs»re Meoiurn Total
N/A
UfA
MnJin Totat
HtA
f* A
Total of Receptor Ri»*» Aero*» AH Mink
NtA
Total of Rrtcvpira Meow* Amm All Medio
Uf A
EPC (mm 1BV7 nvaluaitnn
-------
TABLE 7.RME
CALCULATION Of CHEMICAL CANCER RISKS AND NON-CANCER HAZARDS
REASONABLE MAXIMUM EXPOSURE
WIRD S MCGWRE SUPERFUND SITE
Scanarej rime frame Future
R»)C«V«Ot Po{Ml»tiOfT T'TOmw*
PtoCtffHpt Age Adolfflmconrt japgt 7-17)
Met»un
Ensure Madk#n
Expos*re Point
Ejpoiure ftoule
Chemcal n<
EPC
Career RisM Cateulauons
Mors Carter Hazard Cateufcrttor*
Polecat Concern
VaUe
Untla
intaKe'E«&osure Concentration
CSF/UnHHisfc
Cancer Rich
lnidke'E*t»&u/e Concentration
RJD'RJC
Hazard Quotient
Vafcje
Units
Vaiue.
Urals
V34jB
Units
Value
Urals
Afch
At*i
&I8
irtwsiio-.
Oitwin TEQ
1E.03
&4E-11
mo'Vg-dav
1.56E*05
(n^bQ^la,) 1
S4e.ee
3 6E.1Q
rrxykg-dav
7UE.T0
•TO'hQ-rlflY
54E.01
Ar%«mc
7EH)1
mp*B
24E4Q
rngf>Q-()a»y
1 5E»00
soe-wt
1 4E-05
mgfcfl-dav
I4E4H
ir^hg-day
4 6E-02
E*p HcMe Tptfl
1E-Q5
6E-01
Expc<$ttna Poirtl Total
1E-05
RE-Q1
Ecci»f0 Mooum Total
WA
NfA
MmSam Tota»
N/A
WA
Total of Recvplor Ri»v* *crxr%% AH Mw*«
Nt A
Total of Puc*jrto» Hajunft Amm All Media
WA
EPC (mm 1BV7 nvaUaitnn
•t U IB M rHXHM UM |l«r I "U
-------
APPENDIX H
ARARs REVIEW TABLES
-------
TABLE A7-1. POTENTIAL CHEMICAL-SPECIFIC ARARS AND CRITERIA, ADVISORIES, AND GUIDANCE
BAIRD & MCGUIRE SUPERFUND SITE - OPERABLE UNITS 1 AND 2, HOLBROOK, MASSACHUSETTS
Media and
Authority
Requirement
ROD Status
ROD requirements synopsis and
eonsideration in RI/FS
Five-Year Review
Groundwater
Federal Regulatory
Requirements
SDWA - Maximum
Contaminant Levels
(MCLs) (40 CFR
141.1 1 B 141.16)
Applicable
Maximum Contaminant Levels (MCLs)
have been promulgated for a number of
common organic and inorganic analytes.
These levels regulate the concentration of
analytes in public drinking water supplies,
but may also be considered relevant and
appropriate for groundwater aquifers used
for drinking water. The Holbrook
Municipal South Street well field was closed
due to Baird & McGuire Site contamination.
Private drinking water wells exist in the
vicinity.
Although the municipal wells have been
closed, the Site is located in a state-designated
interim wellhead protection area. Drinking
water rules are therefore relevant and
appropriate. MCLs and non-zero MCLGs
have the status of ARARs for areas
surrounding the Baird & McGuire Site
boundaries. Many of the MCLs and MCLGs
have changed since ROD completion.
MCLs/MCLGs for OU-I are provided in
Table A7-2. Since the first five-year review in
1999, the MCL for arsenic was lowered from
50 ng/l to 10 ng/1. Constituents in Site
groundwater still exceed criteria for arsenic,
mercury, lindane (gamma-BHC), VOCs,
SVOCs, and the secondary MCL for iron.
Groundwater treatment is currently being
conducted. The treated groundwater is being
discharged back to groundwater and meets the
standards for this rule. Groundwater
contamination remains, however, and
treatment is expected to continue for several
years. Groundwater requires continued
remediation under this rule.
-------
TABLE A7-1. POTENTIAL CHEMICAL-SPECIFIC ARARS AND CRITERIA, ADVISORIES, AND GUIDANCE
BAIRD & MCGUIRE SUPERFUND SITE - OPERABLE UNITS 1 AND 2, HOLBROOK, MASSACHUSETTS
Media and
Authority
Requirement
ROD Status
ROD requirements synopsis and
consideration in RI/FS
Five-Year Review
RCRA - Subpart F,
Groundwater
Protection Standards,
Concentration Limits
(40 CFR 264.94(a))
Relevant and
Appropriate
Standards for 14 toxic compounds have
been adopted as part of RCRA groundwater
protection standards. These limits were
originally set at MCLs. The groundwater
protection regulations require the setting of
groundwater protection standards which
must be protective of the public health and
the environment. During the design of the
groundwater interception and treatment
system, restoration target levels were
proposed based on existing data.
RCRA sets the limit for organic constituents
at background levels. Constituents in Site
groundwater exceed RCRA MCLs for arsenic
and mercury and exceed background
concentrations for all organic COCs.
Groundwater treatment is currently being
conducted. The treated groundwater is being
discharged back to groundwater and meets the
standards for this rule. Groundwater
contamination remains, however, and
treatment is expected to continue for several
years. Groundwater still requires remediation
under this rule.
Massachusetts
Regulatory
Requirements
Massachusetts
Drinking Water
Requirements (310
CMR 22.05 to 22.09)
Applicable
The Massachusetts Drinking Water
Standards and Guidelines list Massachusetts
Maximum Contaminant Levels (MMCLs)
that apply to water delivered to any user of a
public water supply system as defined by the
rule.
The Site is located in a designated Mass.
Wellhead Protection Area. Drinking water
standards are applicable to groundwater
supplies surrounding the Baird & McGuire
Site. MMCLs for OU-1 are provided in
Table A7-2. Constituents in Site groundwater
still exceed criteria for arsenic, mercury,
lindane (gamma-BHC), VOCs. and SVOCs.
Groundwater treatment is currently being
conducted. The treated groundwater is being
discharged back to groundwater and meets the
standards for this rule. Groundwater
contamination remains, however, and
treatment is expected to continue. Site
groundwater requires continued remediation to
protect outlying groundwater supplies.
Federal Criteria,
SDWA - Maximum
Relevant and
Maximum contaminant level goals
MCLs and non-zero MCLGs have the status
2
-------
TABLE A7-1. POTENTIAL CHEMICAL-SPECIFIC ARARS AND CRITERIA, ADVISORIES, AND GUIDANCE
BAIRD & MCGUIRE SIJPERFUND SITE - OPERABLE UNITS 1 AND 2, HOLBROOK, MASSACHUSETTS
Media and
Authority
Requirement
ROD Status
ROD requirements synopsis and
consideration in RI/FS
Five-Year Review
Advisories, and
Guidance
Contaminant Level
Goals (MCLGs)
Appropriate/
To Be
Considered
(MCLGs) are health-based criteria that are
to be considered for drinking water sources
as a result of SARA. These goals are
available for a number of organic and
inorganic contaminants.
Projected groundwater concentrations were
compared to their MCLGs in documents
supporting the ROD.
of ARARs for areas outside of the Baird &
McGuire Site boundaries. Zero MCLGs are
criteria to be considered. Many of the MCLs
and MCLGs have changed since ROD
completion. MCLs/MC'LGs for OU-1 are
provided in Table A7-2. Groundwater
requires continued remediation under this rule
to protect outlying resources.
Discharae to
Surface Water
Massachusetts
Regulatory
Requirements
Massachusetts Surface
Water Quality
Standards (314 CMR
4.05)
Applicable
DEP Surface Water Quality Standards are
given for dissolved oxygen, temperature
increase, pH, and total coliform and there is
a narrative requirement for toxicants in toxic
amounts. In the absence of a state standard
for a compound, federal AWQC would be
appropriate.
Requirements were considered; however, no
numerical standards exist for contaminants
found in Site groundwater which would be
discharged to surface water. Federal
AWQC will be used in the absence of
narrative standards.
These regulations classify the surface waters
of the Commonwealth according to the uses of
those waters. The wetland has a Class A
waterway classification. Class A waters are
designated as habitat for fish, other aquatic
and wildlife, and for primary and secondary
contact recreation. The state surface water
minimum criteria for Class A waters are
consistent with federal AWQC. These rules
are applicable to the C'ochato River and
unnamed brook. Discharge is not directly to
the Cochato River. This ARAR is more
appropriate as an Action-Specific ARAR and,
as the groundwater discharge is not directly to
a surface water body, should not be an ARAR.
Federal Criteria,
Advisories, and
Guidance
Federal Ambient Water
Quality Criteria
(AWQC)
Relevant and
Appropriate
Federal AWQC are health-based and
ecologically based criteria which have been
developed for 95 carcinogenic and non-
carcinogenic compounds.
CERC'LA Sec. 121 (d)(2)(A) Specifically
states that remedial actions shall at least attain
federal AWQC established under the Clean
Water Act if they are relevant and appropriate.
3
-------
TABLE A7-1. POTENTIAL CHEMICAL-SPECIFIC ARARS AND CRITERIA, ADVISORIES, AND GUIDANCE
BAIRD & MCGUIRE SIJPERFUND SITE - OPERABLE UNITS 1 AND 2, HOLBROOK, MASSACHUSETTS
Media and
Authority
Requirement
ROD Status
ROD requirements synopsis and
consideration in RI/FS
Five-Year Review
AWQC were considered in characterizing
public health risks to aquatic organisms due
to contaminant concentrations in surface
water at Cochato River. Because this water
is not used as a drinking water source, the
criteria developed for aquatic organisms
protection and ingestion of contaminated
aquatic organisms were considered.
AWQC for protection of human health from
ingestion of water and aquatic organisms are
relevant and appropriate. Current AWQC are
listed in Table A7-6. Discharge is not directly
to the Cochato River. This ARAR is more
appropriate as an Action-Specific ARAR and,
as the groundwater discharge is not directly to
a surface water body, should not be an ARAR.
Air
Massachusetts
Regulatory
Requirements
Massachusetts B Air
Quality, Air Pollution
(310 C'MR 6.00-8.00)
Formerly
Applicable
now Not
ARAR
These standards were primarily developed to
regulate stack and automobile emissions.
310 CMR 6.00 provide ambient air quality
standards for the Commonwealth, standards
for dust are contained in 310 CMR 7.09, and
310 CMR 7.08 provides incinerator standards.
These standards were used in establishing
discharge limits from the incinerator. The
incinerator has been dismantled and these
requirements are no longer applicable, relevant
or appropriate. Should excavation occur in the
future, dust control standards would need to be
reconsidered. This ARAR is more appropriate
as an Action-Specific ARAR.
Federal Criteria,
Advisories, and
Guidance
Threshold Limit
Values (TLVs)
Formerly To
Be
Considered
now Not
ARAR
These standards were issued as consensus
standards for controlling air quality in
workplace environments.
TLVs could be used to assess Site inhalation
risks for soil removal operations.
The incinerator has been dismantled and these
requirements are no longer applicable, relevant
or appropriate. Should excavation be
considered in the future, these values would
need to be reconsidered. This ARAR is more
appropriate as an Action-Specific ARAR.
Massachusetts
Criteria, Advisories,
Massachusetts
Guidance on
Acceptable Ambient
Formerly To
Be
Considered
AALs were considered when assessing the
significance of monitored and modeled
residential contamination from air
The incinerator has been dismantled and these
requirements are no longer applicable, relevant
or appropriate. This ARAR is more
4
-------
TABLE A7-1. POTENTIAL CHEMICAL-SPECIFIC ARARS AND CRITERIA, ADVISORIES, AND GUIDANCE
BAIRD & MCGKIRE SUPERFIJND SITE - OPERABLE UNITS I AND 2, HOLBROOK, MASSACHUSETTS
Media and
Authority
Requirement
ROD Status
ROD requirements synopsis and
consideration in RI/FS
Five-Year Review
and Guidance
Air Levels (AALs)
now Not
ARAR
emissions.
appropriate as an Action-Specific ARAR.
5
-------
TABLE A7-2. NUMERICAL STAN DAP
IDS FOR BAIRD & MCGIJIRE GROUNDWATER
CHEMICAL 1
SDWA MCL1
(mg/L)
SDWA MCLG3
(mg/L)
RCRA MCL4
(mg/L)
Mass. Drinking Water
Stds/(mg/L)
Organics, I'esticides, PC'Bs
Acenapthalene*, **
—
—
—
—
Aldrin
—
—
—
—
Benzene*
0.005
0
—
0.005
Benzidine
—
—
—
—
Benzo(a)pyrene
0.0002
0
—
0.0002
Butanone, 2-
--
—
—
—
Chlordane*
0.002
0
—
0.002
Chloroform
—
—
—
—
DDD. 4, 4-
—
—
—
—
DDE, 4. 4-
—
—
—
—
DDT, 4. 4-
—
—
—
—
Dibenzofiiran*
—
—
—
—
DicWoroethane, 1,2-
0.005
0
—
0.005
Dichloroethylene, 1,2-trans*
0.1
0.1
—
0.1
Dichloropropylene, 1,3-trans
—
—
—
—
Dieldrin*
—
—
—
—
Dimethylphenol, 2,4-*
—
—
—
—
Dioxin (2, 3, 7, 8-TCDD)
3x10"8
0
—
3x10^
Ethyl benzene*
0.7
0.7
—
0.7
Fluoranthene
—
—
—
—
Fluorene*. **
—
—
—
—
Heptachlor
0.0004
0
—
0.0004
Heptaehlor epoxide
0.0002
0
—
0.0002
Lindane (gamma-BHC)
0.0002
0.0002
0.004
0.0002
-------
TABLE A7-2. NUMERICAL STAN DAP
IDS FOR BAIRD & MCGIJIRE GROUNDWATER
CHEMICAL 1
SDWA MCL1
(mg/L)
SDWA MCLG3
(mg/L)
RCRA MCL4
(mg/L)
Mass. Drinking Water
Stds/(mg/L)
Methyl naphthalene. 2-*, **
—
—
—
—
Methylphenol, 4-*
—
—
—
—
Naphthalene*, **
—
—
—
—
Phenanthrene*, **
—
—
—
—
Total Other PAHs (**)
—
—
—
—
T etrachloroethvlene
0.005
0
—
0.005
T oluene*
1
1
--
1
Trichloroethane. 1,1,1-
0.2
0.20
—
0.2
T richJoroethylene (TCE)
0.005
0
—
0.005
Vinyl chloride
0.002
0
—
0.002
Xylenes (total)*
10
10
—
10
Inorganics
Antimony
0.006
0.006
—
0.006
Arsenic*
0.010
0
0.05
0.010
Barium
2
2
1.0
2
Beryllium
0.004
0.004
—
0.004
Cadmium
0.005
0.005
0.01
0.005
Iron
--
0.3 (SMCL)
—
0.3 (SMCL)
Lead*
Treatment technique6
0
0.05
Treatment technique6
Mercury
0.002
0.002
0.002
0.002
Nickel
—
—
—
Silver
0.10 (SMCL)
0.05
0.10 (SMCL)
Zinc
5 (SMCL)
-
5 (SMCL)
2
-------
TABLE A7-2. NUMERICAL STANDARDS FOR BAIRD & MCGUIRE GROUNDWATER
Notes
1. Chemicals listed in this table include selected critical contaminants identified in Table 1 of the 9/30/86 ROD, indicator compounds as defined in the
Site Maintenance Plan (see * below), and other compounds detected at levels exceeding SDWA MCLs during 2003, 2007, or 2011 groundwater
monitoring.
2. National Primary Drinking Water Regulations under Safe Drinking Water Act (SDWA), 40 CFR Part 141, Subpart G, Maximum Contaminant
Levels (MCLs)
3. National Primary Drinking Water Regulations under Safe Drinking Water Act, 40 CFR Part 141, Subpart F, Maximum Contaminant Level Goals
(MCLGs)
4. Federal Resource Conservation and Recovery Act Maximum concentration of Constituents for Groundwater Protection, 40 CFR 264.94, Table 1.
5. Massachusetts Drinking Water Regulations. 310 CMR 22.00
6. The MCL for lead was replaced by an action level of 15 ppb (0.015 mg/L) at the tap, 0.005 mg/L in the system. Public water systems exceeding
the action level must for further treatment; b) undertake a public education program to inform consumers about how lo reduce exposure to lead in
drinking level continues, replace all lead service pipes.
These compounds are contamination indicator compounds as defined in the Site Maintenance Plan for the Baird & McGuire Groundwater Treatment
Plant and Extraction/Recharge System prepared by Metcalf & Eddy, April 25. 1989, for the U.S. Army Engineer District, Omaha.
**PAH compounds listed in Table 2 of 9/30/86 Record of Decision: 2-methylnapthalene, acenapthene, acenapthylene, anthracene, benzo(a)anthracene,
benzo(b)fluoranthene, chrysene, dibenzo(a,h)anthracene, fluorene, indeno( 1,2,3-cd)pyrene, napthalene, phenanthrene, and pyrene.
SMCL - Secondary Maximum Contaminant Level
3
-------
TABLE A7-3. POTENTIAL LOCATION-SPECIFIC ARARS AND CRITERIA, ADVISORIES, AND GUIDANCE
BAIRD & MCGU1RE SITE (ALL OPERABLE UNITS), IIOLBROOK, MASSACHUSETTS
SITE FEATURE
AND
AUTHORITY
REQUIREMENTS
ROD
STATUS
REQUIREMENT SYNOPSIS AND
CONSIDERATION IN RI/FS
FIVE-YEAR REVIEW
Wetlands
Federal Regulatory
Requirements
Clean Water Act
(CWA) Section 404 B
(40 CFR Part 230)
Applicable
Under this requirement, no activity that
adversely affects a wetland shall be permitted if
a practicable alternative that has less effect is
available. Permits are required to be obtained
from the US Army Corps of Engineers for
dredge and 1111 activities in off-site wetlands.
During identification, screening, and evaluation
of alternatives, the effects on wetlands are
evaluated. Wetland impacts must be avoided,
minimized, mitigated.
To mitigate unavoidable wetland impacts, a
Final Site Restoration Plan was developed that
requires the restoration of approximately 7.4
acres of forested and scrub/shrub floodplain
wetlands, including a small peat bog and 1,000
linear feet of intermittent stream, impacted by
the remedial action. The plan required restoring
the wetland to the approximate original grades
and elevations, backfilling with organic topsoil
(at least 20 percent organic matter by weight)
and seeding and planting with appropriate
herbaceous, shrub, and tree species. The
wetland was monitored for four years in order lo
assess the success of the wetland restoration
effort. The final monitoring report was
completed in 2002.
Executive Order,
11990; Wetlands
Protection; Clean
Water Act (40 CFR 6,
Appendix A)
Applicable
Under this requirement, no activity that
adversely affects a wetland shall be permitted if
a practicable alternative that has less effect is
available. All operable units include wetlands.
To mitigate unavoidable wetland impacts, a
Final Site Restoration Plan was developed. The
plan required the restoration of forested and
scrub/shrub floodplain wetlands, including a
small peat bog, and an intermittent stream
impacted by the remedial action. The plan also
required annual monitoring of the wetlands for
at least three years following completion of the
restoration efforts. Four years of monitoring
data were collected and the final monitoring
report was completed in 2002.
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TABLE A7-3. POTENTIAL LOCATION-SPECIFIC ARARS AND CRITERIA, ADVISORIES, AND GUIDANCE
BAIRD & MCGUIRE SITE (ALL OPERABLE UNITS), HOLBROOK, MASSACHUSETTS
SITE FEATURE
AND
AUTHORITY
REQUIREMENTS
ROD
STATUS
REQUIREMENT SYNOPSIS AND
CONSIDERATION IN RI/FS
FIVE-YEAR REVIEW
Fish and Wildlife
Coordination Act
(16 U.S.C. 661)
Applicable
The Fish and Wildlife Coordination Act (16
USC 661 el. seq.) requires that, before issuing
a federal permit or undertaking any federal
action that causes the impoundment (with
certain exemptions), diversion, or other control
or modification of any body of water, the
applicable federal agency must consult with (1)
the appropriate state agency exercising
jurisdictions over wildlife resources; (2) the
U.S. Fish and Wildlife Sen ice (USFWS) and
the National Marine Fisheries Service, within
the Department of Interior; and (3 ) the National
Marine Fisheries Service, within the
Department of Commerce. The Baird &
McGuire Site includes significant wetlands.
This requirement is addressed under CWA
Section 404.
Consultation occurred as part of the RI/FS
process.
State Regulatory
Requirements
Massachusetts B
Wetlands
Protection(310 CMR
10.00)
Applicable
These requirements are promulgated under
Wetlands Protection Laws, which regulate
dredging, filling, altering, or polluting
wetlands. Work within 100 feet of a wetland is
also regulated under this requirement. The
requirement defines wetlands based on
vegetation type and requires that effects on
wetlands be mitigated.
If alternatives require that work be completed
within 100 feet of a defined wetland, these
regulations are to be considered. Mitigation of
impacts on wetlands is addressed under
CWA 404.
To mitigate unavoidable wetland impacts, a
Final Site Restoration Plan was developed. The
plan required the restoration of forested and
scrub/shrub floodplain wetlands, including a
small peat bog, and an intermittent stream
impacted by the remedial action. The plan also
required annual monitoring of the wetlands for
at least three years following completion of the
restoration efforts. Four years of monitoring
data were collected and the final monitoring
report was completed in 2002.
2
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TABLE A7-3. POTENTIAL LOCATION-SPECIFIC ARARS AND CRITERIA, ADVISORIES, AND GUIDANCE
BAIRD & MCGUIRE SITE (ALL OPERABLE UNITS), HOLBROOK, MASSACHUSETTS
SITE FEATURE
AND
AUTHORITY
REQUIREMENTS
ROD
STATUS
REQUIREMENT SYNOPSIS AND
CONSIDERATION IN RI/FS
FIVE-YEAR REVIEW
Massachusetts
Environmental Policy
Act (MEPA)
Regulations (301 CMR
11.00)
Formerly
Applicable,
Now not
ARAR
These regulations require that all actions
exceeding specified threshold established under
MEPA, requiring funding, or requiring a major
permit, prepare and file an Environmental
Notification Form (ENF). MEPA has
determined that the reports generated during
Baird & McGuire investigations essentially
constitute an Environmental Impact Report.
During development of alternatives, impacts to
wetlands and fioodplains were evaluated.
The CERCLA process generates evaluations and
reports that are equivalent to those required by
MEPA. To eliminate redundancy, these rules
are no longer considered ARAR.
Department of
Environmental
Management (DEM)
Inland Wetland Orders
(302 CMR 6.00)
Applicable
Pursuant to these regulations, DEM has
authority to adopt orders restricting activities or
uses of inland wetlands in order to preserve and
promote public safety, property, wildlife and
water resources, and floodplain areas.
DEM was apprised of remedial actions which
may impact inland wetlands.
To mitigate unavoidable wetland impacts, a
Final Site Restoration Plan was developed. The
plan required the restoration of forested and
scrub/shrub floodplain wetlands, including a
small peat bog, and an intermittent stream
impacted by the remedial action. The plan also
required annual monitoring of the wetlands for
at least three years following completion of the
restoration efforts. Four years of monitoring
data were collected and the final monitoring
report was completed in 2002.
Floodplains
Federal Regulatory
Requirements
RCRA Location
Standards 40 CFR
264.18(b)
Relevant
and
Appropriate
RCRA-defined listed or characteristic
hazardous waste (40 CFR 261) facility must be
designed, constructed, operated, and
maintained to prevent washout by 100-year
flood.
This ARAR has been met. All hazardous waste
facilities are outside of the 100-year flood plain.
3
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TABLE A7-3. POTENTIAL LOCATION-SPECIFIC ARARS AND CRITERIA, ADVISORIES, AND GUIDANCE
BAIRD & MCGUIRE SITE (ALL OPERABLE UNITS), HOLBROOK, MASSACHUSETTS
SITE FEATURE
AND
AUTHORITY
REQUIREMENTS
ROD
STATUS
REQUIREMENT SYNOPSIS AND
CONSIDERATION IN RI/FS
FIVE-YEAR REVIEW
Floodplains Protection
Executive Order
11988; Clean Water
Act (40 CFR
6.302(b),Appendix A)
Applicable
Federal agencies shall lake action to reduce the
risk of flood loss, minimize the impact of
floods on human safety, health and welfare, and
restore and preserve the natural and beneficial
values of floodplains. Federal agencies shall
also evaluate potential effects of actions in
floodplains and ensure consideration of flood
hazards and floodplain management. If action
is taken in floodplains, alternatives to avoid
adverse effects, and minimize potential harm
must be taken.
This ARAR has been met. The Site was re-
graded according to plan and according to
former floodplain delineation.
State Regulatory
Requirements
Massachusetts
Wetlands Protection
(310 CMR 10.57 (2),
10.04)
Applicable
Actions in "bordering land subject to flooding"
shall provide compensatory storage for Hood
storage volume lost as a result of the project,
shall not restrict flows so as to cause an
increase in flood stage or velocity, and shall not
impair its capacity to provide important
wildlife habitat functions or alter vernal pool
habitat. Actions in "isolated land subject to
flooding" shall not result in flood damage
because of lateral displacement of water that
would otherwise be confined within the area,
adverse effects on water supply, adverse effects
on the capacity of the area to prevent
groundwater pollution, or adverse effects on
vernal pool habitat.
This ARAR has been met. The site was re-
graded according to plan and according to
former floodplain delineation.
4
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TABLE A7-3. POTENTIAL LOCATION-SPECIFIC ARARS AND CRITERIA, ADVISORIES, AND GUIDANCE
BAIRD & MCGUIRE SITE (ALL OPERABLE UNITS), HOLBROOK, MASSACHUSETTS
SITE FEATURE
AND
AUTHORITY
REQUIREMENTS
ROD
STATUS
REQUIREMENT SYNOPSIS AND
CONSIDERATION IN RI/FS
FIVE-YEAR REVIEW
Massachusetts
Hazardous Waste
Management Rules,
Facility Location
Regulations (310 CMR
30.700-30.707)
Relevant
and
Appropriate
No new facility may be located in an area
subject to flooding, within the watershed of
class A or class SA segment of a surface water
body (unless DEP determines these is no
feasible alternative), on land overlying an
actual planned, or potential public or private
drinking water source, or in the flow path of
groundwater supplying water to an existing
well. Variances and exceptions are noted in the
regulations.
The impact of the construction and operation of
an on-site hazardous waste treatment, storage
or disposal facility on the floodplain must be
considered during the development of remedial
alternatives.
As there was no feasible alternative, the
groundwater treatment facility was constructed
at this Site. The groundwater treatment facility
treats materials that may be classified as RCRA
hazardous by toxicity. While these rules may be
relevant, they are not appropriate based on the
nature of the treatment (remediation).
Massachusetts
Certification for
Dredging, Dredged
Material Disposal and
Filling in Waters (314
CMR 9.00)
Applicable
A water quality certification is required for any
activity that involves dredging in a waterway or
wetland in Massachusetts that is also subject to
a U.S. Army Corps of Engineers CWA Permit,
a EPA NPDES permit, or a Massachusetts
Wetlands or Waterways Order of Conditions or
License. Application must be made to DEP to
certify that a proposed project will attain or
maintain the Massachusetts Water Quality
Standards and minimize adverse impacts to
water quality.
To mitigate unavoidable wetland impacts, a
Final Site Restoration Plan was developed. The
plan required the restoration of forested and
scrub/shrub floodplain wetlands, including a
small peat bog, and an intermittent stream
impacted by the remedial action. The plan also
required annual monitoring of the wetlands for
at least three years following completion of the
restoration efforts. Four years of monitoring
data were collected and the final monitoring
report was completed in 2002. This work has
been completed and substantive requirements
have been attained.
5
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TABLE A7-4. POTENTIAL ACTION-SPECIFIC ARARS FOR OPERABLE UNITS 1 AND 2
BAIRD & MCGUIRE SITE, HOLBROOK, MASSACHUSETTS
ARAR
REQUIREMENT SYNOPSIS
AND STATUS
ACTION TAKEN TO ATTAIN
ARARS
FIVE-YEAR REVIEW
Federal Reeulatorv Reciuirements
RCRA - Generator
Standards (40 CFR
261, 265.170 -
265.174, 262.10 -
262.34)
If Contaminated substances meet the
definition of RCR A-hazardous under
40 CFR 261, RCRA requirements are
applicable. If contaminated
substances at CERCLA sites are
determined to be sufficiently similar
to RCRA hazardous wastes, technical
aspects of RCRA requirements are
considered relevant and appropriate.
If removed from their existing
locations, hazardous substances
should be handled, transported, and
treated as RCRA hazardous waste.
General generator requirements
outline waste characterization,
management of containers, packaging,
labeling and manifesting,
ROD Status: ARAR
5-Year Status: Relevant and
Appropriate
Treatment residuals from wastewater
treatment will be disposed of
according to RCRA. Waste
containers will be handled and
managed in accordance with RCRA.
These requirements are relevant and appropriate to
operations at the groundwater treatment facility.
Although the GWTP does not treat RCRA-designated
hazardous waste, it does generate a treatment residual
that may, at times, meet the definition of a RCRA
hazardous waste. Generator requirements are therefore
being complied with at the facility.
RCRA - Standards
If a facility operated pursuant to
All facilities on-site will be
These requirements were relevant and appropriate to the
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TABLE A7-4. POTENTIAL ACTION-SPECIFIC ARARS FOR OPERABLE UNITS 1 AND 2
BAIRD & MCGUIRE SITE, HOLBROOK, MASSACHUSETTS
ARAR
REQUIREMENT SYNOPSIS
AND STATUS
ACTION TAKEN TO ATTAIN
ARARS
FIVE-YEAR REVIEW
for Owners and
Operators of
Permitted 1 lazardous
Waste Facilities (40
CFR 264.10 -
264.18)
RCRA regulations, RCRA
requirements are applicable. If
contaminated substances at CERCLA
sites are determined to be sufficiently
similar to RCRA hazardous wastes,
technical aspects of RCRA
requirements are considered relevant
and appropriate. If removed from
their existing locations, hazardous
substances should be handled,
transported, and treated as RCRA
hazardous waste. General facility
requirements outline general waste
analysis, security measures,
inspections, and training
requirements.
ROD Status: ARAR
5-Year Status: Not ARAR
constructed, fenced, posted, and
operated in accordance with this
requirement. All workers will be
properly trained. Process wastes will
be evaluated for the characteristics of
hazardous wastes to assess further
requirements. Treatment residuals
from wastewater treatment will be
disposed of according to RCRA.
incinerator. The incinerator has been dismantled. The
groundwater treatment facility does not treat hazardous
waste and does not meet the standards for being
sufficiently similar to a hazardous waste treatment
facility. These rules are no longer considered
applicable, relevant or appropriate.
RCRA -
Preparedness and
Prevention (40 CFR
265.30-265.37)
This regulation outlines safety
equipment and spill control
requirements for hazardous waste
facilities. Part of the regulation
includes a requirement that facilities
be designed, maintained, constructed,
and operated so that the possibility of
an unplanned release which could
threaten public health or the
environment is minimized.
ROD Status: ARAR
5-Year Status: Relevant and
Appropriate
Safety and communication
equipment will be installed at the
Site; local authorities will be
familiarized with Site operations.
These requirements are relevant and appropriate to
operations at the groundwater treatment facility.
Although the GWTP does not treat RCRA-designated
hazardous waste, it does generate a treatment residual
that may, at times, meet the definition of a RCRA
hazardous waste. Generator requirements are therefore
being complied with at the facility. Local authorities
are familiar with Site operations and safety equipment
is in place.
2
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TABLE A7-4. POTENTIAL ACTION-SPECIFIC ARARS FOR OPERABLE UNITS 1 AND 2
BAIRD & MCGUIRE SITE, HOLBROOK, MASSACHUSETTS
ARAR
REQUIREMENT SYNOPSIS
AND STATUS
ACTION TAKEN TO ATTAIN
ARARS
FIVE-YEAR REVIEW
RCRA -
Contingency Plan
and Emergency
Procedures (40 CFR
265.50-265.56)
This regulation outlines the
requirements for emergency
procedures to be used following
explosions, fires, etc. This regulation
also requires that threats to public
health and the environment be
minimized.
ROD Status: ARAR
5-Year Status: Relevant and
Appropriate
Plans will be developed and
implemented during Site work
including installation of monitoring
wells, and implementation of Site
remedies. Copies of the plans will
be kept on-site.
These requirements are relevant and appropriate to
operations at the groundwater treatment facility.
Although the GWTP does not treat RC'RA-designated
hazardous waste, it does generate a treatment residual
that may, at times, meet the definition of a RCRA
hazardous waste. Generator requirements are therefore
being complied with at the facility. A contingency plan
is available at the Site.
RCRA Subpart F -
Groundwater
Protection (40 CFR
264.90-264.109)
This regulation details requirements
for a groundwater monitoring
program to be installed at the Site.
ROD Status: ARAR
5-Year Status: Relevant and
Appropriate
A groundwater monitoring system
must be installed as part of any
alternative. During Site
characterization, the location and
depth of monitoring wells will be
evaluated for use in this monitoring
program.
Groundwater corrective action rules have changed
significantly since the ROD was issued. A groundwater
monitoring program has been implemented at the Site.
Monthly water level monitoring and quarterly
groundwater sampling is performed under this plan.
These requirements are relevant and appropriate to the
Site due to its former use. Substantive rules are being
complied with.
RCRA Subpart G -
Closure and Post-
Closure (40 CFR
264.1 10-264.120)
This regulation details specific
requirements for closure and post-
closure of hazardous waste facilities.
ROD Status: ARAR
5-Year Status: Not ARAR
Those parts of the regulations
concerned with long-term monitoring
and maintenance of the Site will be
considered during remedial design.
A post-closure plan will be
developed.
These requirements were relevant and appropriate to the
incinerator. The incinerator has been dismantled. The
groundwater treatment facility does not treat hazardous
waste and does not meet the standards for being
sufficiently similar to a hazardous waste treatment
facility. These rules are no longer considered
applicable, relevant or appropriate.
3
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TABLE A7-4. POTENTIAL ACTION-SPECIFIC ARARS FOR OPERABLE UNITS 1 AND 2
BAIRD & MCGUIRE SITE, HOLBROOK, MASSACHUSETTS
ARAR
REQUIREMENT SYNOPSIS
AND STATUS
ACTION TAKEN TO ATTAIN
ARARS
FIVE-YEAR REVIEW
RCRA Subpart K -
Surface
Impoundments
(264.220 - 264.232)
This regulation specifies design,
operation and closure requirements
for surface impoundments containing
hazardous waste.
ROD Status: ARAR
5-Year Status: Not ARAR
Design and operating requirements
for a liner, leachate collection and
removal system and closure are
detailed.
There are no waste impoundments on-site. These rules
are not applicable, relevant or appropriate.
RCRA Subpart N -
Landfills (40 CFR
(264.300-264.317)
This regulation details design and
operating, monitoring, closure and
post-closure requirements for
hazardous waste landfills.
ROD Status: ARAR
5-Year Status: Not ARAR
Landfills must be designed with a
liner leachate collection and
monitoring, and a specific cap. In
addition, long-term monitoring and a
post-closure plan must be developed.
As RCRA Subtitle C hazardous wastes were not land
disposed on-site, these rules are not applicable, relevant
or appropriate.
RCRA Subpart 0 -
Incinerators (40 CFR
264.340-264.351)
This regulation details specific
requirements for the design, operation
and closure of a hazardous waste
incinerator.
ROD Status: ARAR
5-Year Status: Not ARAR
Performance standards, waste
analysis, operating requirements,
monitoring, inspection and closure
are specified.
These requirements were relevant and appropriate to the
incinerator. The incinerator has been dismantled. The
groundwater treatment facility does not treat hazardous
waste and does not meet the standards for being
sufficiently similar to a hazardous waste treatment
facility. These rules are no longer considered
applicable, relevant or appropriate.
4
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TABLE A7-4. POTENTIAL ACTION-SPECIFIC ARARS FOR OPERABLE UNITS 1 AND 2
BAIRD & MCGUIRE SITE, HOLBROOK, MASSACHUSETTS
ARAR
REQUIREMENT SYNOPSIS
AND STATUS
ACTION TAKEN TO ATTAIN
ARARS
FIVE-YEAR REVIEW
Clean Water Act -
Surface Water
Discharges (40 CFR
Parts 122, 125)
Any point source discharges must
meet NPDES permitting
requirements, which include
compliance with applicable water
quality standards; establishment of a
discharge monitoring system; and
routine completion of discharge
monitoring records.
ROD Status: ARAR
5-Year Status: Not ARAR
If groundwater that has been treated
by on-site treatment processes is
discharged to surface waters on-site,
treated groundwater must be in
compliance with applicable water
quality standards. In addition, a
discharge monitoring program must
be implemented. Routine discharge
monitoring records must be
completed.
Treated groundwater is being discharged back to
groundwater. No direct, point-source surface water
discharge is occurring.
CWA - 40 CFR Part
230
This regulation outlines requirements
for discharges of dredged or Fill
material. Under this requirement no
activity that impacts a wetland will be
permitted if a practicable alternative
that has less impact on the wetland is
available. If there is no other
practicable alternative, impacts must
be mitigated.
ROD Status: ARAR
5-Year Status: Applicable
During the identification, screening,
and evaluation of alternatives, the
effects on wetlands must be
evaluated.
A Wetlands Restoration Plan has been implemented at
the Site.
CAA - NAAQS for
Total Suspended
Particulates (40 CFR
129.105.50)
This regulation specifies maximum
primary and secondary 24-hour
concentrations for particulate matter.
ROD Status: ARAR
5-Year Status: Not ARAR
Fugitive dust emissions from Site
excavation activities will be
maintained below 260 pg/m3
(primary standard) by dust
suppressants, if necessary.
These requirements were applicable to the excavation
and incineration of debris. These activities are
completed. These requirements are only applicable if
further land disturbing activities are conducted. None
are currently planned,
5
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TABLE A7-4. POTENTIAL ACTION-SPECIFIC ARARS FOR OPERABLE UNITS 1 AND 2
BAIRD & MCGUIRE SITE, HOLBROOK, MASSACHUSETTS
ARAR
REQUIREMENT SYNOPSIS
AND STATUS
ACTION TAKEN TO ATTAIN
ARARS
FIVE-YEAR REVIEW
DOT Rules for
Transportation of
Hazardous Materials
(49CFR Parts 107,
171.1-171.5)
This regulation outlines procedures
for the packaging, labeling,
manifesting, and transportation of
hazardous materials.
ROD Status: ARAR
5-Year Status: Not ARAR
Contaminated materials shipped off-
site will be packaged, manifested,
and transported to a licensed off-site
disposal facility in compliance with
these regulations.
Shipping of hazardous materials has been in
compliance. EPA no longer considers DOT rules an
ARAR as they are not environmental rules and must
always be complied with for all off-site shipments.
State Regulatory Reauirements
Massachusetts
Hazardous Waste
Regulations (310
CMR 30.000. MGL
Ch. 21C)
These regulations provide a
comprehensive program for the
handling, storage, and recordkeeping
at hazardous waste facilities. They
implement federal RCRA regulations.
ROD Status: ARAR
5-Year Status: Relevant and
Appropriate
Because these requirements
supplement RCRA hazardous waste
regulations, they must also be
considered at the Site.
These requirements are relevant and appropriate to
operations at the groundwater treatment facility.
Although the GWTP does not treat RCRA-dcsignated
hazardous waste, it does generate a treatment residual
that may, at times, meet the definition of an RCRA
hazardous waste. Generator requirements are therefore
being complied with at the facility.
Massachusetts Solid
Waste Management
regulations (310
CMR 19.141)
This regulation requires that notice be
recorded in the Registry of Deeds
whenever certain types of solid or
hazardous waste activity occur on
property.
ROD Status: ARAR
5-Year Status: Applicable
Notification of remedial actions will
be given to the County Registry of
Deeds.
This has not been completed to date.
6
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TABLE A7-4. POTENTIAL ACTION-SPECIFIC ARARS FOR OPERABLE UNITS 1 AND 2
BAIRD & MCGUIRE SITE, HOLBROOK, MASSACHUSETTS
ARAR
REQUIREMENT SYNOPSIS
AND STATUS
ACTION TAKEN TO ATTAIN
ARARS
FIVE-YEAR REVIEW
Massachusetts
Wetlands Protection
(310 CMR 10.00)
This regulation outlines the
requirements necessary to work
within 100 feet of a coastal or inland
wetland. The act sets forth a public
review and decision-making process
by which activities affecting waters of
the state are to be regulated to
contribute to their protection.
ROD Status: ARAR
5-Year Status: Applicable
Wetland remediation will comply
with the substantive but not the
administrative requirements for
wetland protection.
To mitigate unavoidable wetland impacts, a Final Site
Restoration Plan was developed. The plan required the
restoration of forested and scrub/shrub floodplain
wetlands, including a small peat bog, and an
intermittent stream impacted by the remedial action.
The plan also required annual monitoring of the
wetlands for at least three years following completion of
the restoration efforts. Four years of monitoring data
were collected and the final monitoring report was
completed in 2002.
Massachusetts
Surface Water
Discharge Permit
Program (314 CMR
2.00-4.00)
This section outlines the requirements
for obtaining an NPDES permit in
Massachusetts.
ROD Status: ARAR
5-Year Status: Not ARAR
Pollutant discharges to surface water
must comply with NPDES permit
requirements. Permit conditions and
standards for different classes of
water are specified.
No direct point-source discharges to surface water are
occurring.
Certification for
Dredging, Dredged
Material Disposal,
and Filling Waters
(314 CMR 9.00,
MGL Ch. 21, ss. 26-
53)
This regulation is promulgated to
establish procedures, criteria, and
standards for the water quality
certification of dredging and dredged
material disposal.
ROD Status: ARAR
5-Year Status: Applicable
Applications for proposed
dredging/till work need to be
submitted and approved before work
commences. Three categories have
been established for dredge or fill
material based on the chemical
constituents. Approved methods for
dredging, handling, and disposal
options for the three categories must
be met.
To mitigate unavoidable wetland impacts, a Final Site
Restoration Plan was developed. The plan required the
restoration of forested and scrub/shrub floodplain
wetlands, including a small peat bog, and an
intermittent stream impacted by the remedial action.
The plan also required annual monitoring of the
wetlands for at least three years following completion of
the restoration efforts. Four years of monitoring data
were collected and the final monitoring report was
completed in 2002.
7
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TABLE A7-5. POTENTIAL CHEMICAL-SPECIFIC CRITERIA, ADVISORIES, AND GUIDANCE FOR OU-3.
BAIRD & MCGUIRE SITE, HOLBROOK, MASSACHUSETTS
MEDIA AND
AUTHORITY
REQUIREMENT
ROD
STATUS
ROD REQUIREMENT SYNOPSIS AND
CONSIDERATION IN THE FES
FIVE-YEAR REVIEW
Surface Water
Federal Regulatory
Requirements
SDWA - MCLs
(40CFR 141.1 1
141.16)
Relevant and
Appropriate
Maximum contaminant levels (MCLs) have
been promulgated for a number of common
organic and inorganic contaminants. These
levels regulate the concentration of
contaminants in public drinking water supplies,
but may also be considered relevant and
appropriate for surface water bodies used for
drinking water.
When the risks to public health due to
consumption of surface water were assessed,
concentrations of contaminants of concern were
compared to federal MCLs.
MCLs and non-zero MCLGs have the status of
ARARs for surface water downgradient of the
Baird & McGuire Site boundaries. Many of the
MCLs and MCLGs have changed since ROD
completion. MCLs/MCLGs for site
contaminants are provided in Table A7-2.
Contaminated sediments have been removed
and are no longer expected to leach
contamination to the Cochato River. This
requirement has been attained for OU-3. These
criteria arc not currently ARAR; however, they
may become relevant and appropriate if the
Cochato River is considered for a potential
public water supply.
SDWA - MCLGs
(40CFR 141.50-
141,51)
Relevant and
Appropriate
MCLGs are health-based criteria that are used
for the protection of drinking water sources as a
result of SARA. These unenforceable goals are
available for a number of organic and inorganic
contaminants.
MCLGs will be used when an extraordinary
risk is associated with contaminants in the
Cochato River surface water and sediment.
MCLs and non-zero MCLGs have the status of
ARARs for surface water downgradient of the
Baird & McGuire Site boundaries. Zero
MCLGs are criteria to be considered. Many of
the MCLs and MCLGs have changed since
ROD completion. MCLs/MCLGs for site
contaminants are provided in Table A7-2.
Contaminated sediments have been removed
and are no longer expected to leach
contamination to the Cochato River. This
requirement has been attained for OU-3. It
would be relevant and appropriate if the
Cochato River is considered for a potential
public water supply.
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TABLE A7-5. POTENTIAL CHEMICAL-SPECIFIC CRITERIA, ADVISORIES, AND GUIDANCE FOR OU-3.
BAIRD & MCGUIRE SITE, HOLBROOK, MASSACHUSETTS
MEDIA AND
AUTHORITY
REQUIREMENT
ROD
STATUS
ROD REQUIREMENT SYNOPSIS AND
CONSIDERATION IN THE FES
FIVE-YEAR REVIEW
Federal Ambient
Water Quality
Criteria (AVVQC)
under the Clean
Water Act
Relevant and
Appropriate
Remedial actions involving contaminated
surface water or groundwater must consider the
uses of the water and the circumstances of the
release or threatened release; this determines
the relevance and appropriateness.
This requirement will be considered when
determining clean-up levels or potential
discharge limits.
CERCLA Sec. 121 (d)(2)(A) Specifically states
that remedial actions shall at least attain federal
AWQC established under the Clean Water Act
if they are relevant and appropriate. These
criteria are not currently ARAR; however, they
may become relevant and appropriate if the
Cochato River is considered for a potential
public water supply. Current AWQC are listed
in Table A7-6.
State Regulatory
Requirements
Massachusetts
Drinking Water
Standards (310
CMR 22.00)
Relevant and
Appropriate
Massachusetts adopted the federal SDWA
Maximum Contaminant Levels (MCLs) as its
drinking water standards. MCLs regulate the
concentration of contaminants in public
drinking water supplies.
When risks to public health due to consumption
of surface water were assessed, concentrations
of contaminants of concern were compared to
Massachusetts MCLs.
The Site is located in a designated Mass.
Wellhead Protection Area. Drinking water
standards are applicable to drinking water
sources surrounding the Baird & McGuire Site.
MMC'Ls for site contaminants are provided in
Table A7-2. Contaminated sediments have
been removed and are no longer expected to
leach contamination to the Cochato River. This
requirement has been attained for OU-3. It
does, however, remain relevant and
appropriate.
Massachusetts
Surface Water
Quality Standards
(314 C'MR 4.00)
Applicable
Surface water quality standards are specified
for the major surface water bodies of the
Commonwealth. Surface waters were classified
with respect to designated uses. Each class of
surface water has a criteria associated with it
(e.g., dissolved oxygen, temperature, pH, total
coliform).
The Cochato River is designated as a Class B
River. Actions will take into account the
designated use(s) and will comply with
These regulations classify the surface waters of
the Commonwealth according to the uses of
those waters. The wetland has a Class A
waterway classification. Class A waters are
designated as habitat for fish, other aquatic and
wildlife, and for primary and secondary contact
recreation. The state surface water minimum
criteria for Class A waters are consistent with
federal AWQC. These rules are applicable to
the Cochato River and unnamed brook.
2
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TABLE A7-5. POTENTIAL CHEMICAL-SPECIFIC CRITERIA, ADV ISORIES, AND GUIDANCE FOR OU-3.
BAIRD & MCGUIRE SITE, HOLBROOK, MASSACHUSETTS
MEDIA AND
AUTHORITY
REQUIREMENT
ROD
STATUS
ROD REQUIREMENT SYNOPSIS AND
CONSIDERATION IN THE FFS
FIVE-YEAR REVIEW
specified water quality standards.
Air
State Regulatory
Requirements
Massachusetts Air
Pollution Control
Regulations (310
CMR6.04)
Relevant and
Appropriate
Massachusetts has promulgated ambient air
quality standards for six pollutants (e.g., sulfur
oxides, particulate matter, carbon, ozone,
nitrogen, and lead).
During excavation activities these standards
will be complied with.
310 CMR 6.00 provide ambient air quality
standards for the Commonwealth, standards for
dust are contained in 310 CMR 7.09, and 310
CMR 7.08 provides incinerator standards.
These standards were used in establishing
discharge limits from the incinerator. The
incinerator has been dismantled and these
requirements are no longer applicable, relevant
or appropriate. Should excavation occur in the
future, dust control standards would need to be
reconsidered.
Federal Criteria,
Advisories, and
Guidance
EPA Office of
Water Guidance,
Water-Related
Fate of 129
Priority Pollutants
(1979).
To Be
Considered
This guidance manual gives transport and fate
information for 129 priority pollutants.
These criteria were considered during the risk
assessment.
There is no change from the ROD presentation
for this ARAR.
State Criteria,
Advisories and
Guidance
Massachusetts
Guidance on
Allowable Ambient
Levels (AALs),
cited in Chemical
1 iealth Effects
Assessment
Methodoloev and
Methodoloev to
Derive Allowable
Ambient Levels.
To Be
Considered
This guidance evaluates acute and chronic
toxicity and sets draft AALs for 106 chemicals.
Final AALs will be issued in 1989.
These levels will be considered when evaluating
excavation and treatment technologies that
have potential hazardous air emissions.
These requirements are no longer to be
considered for this operable unit. The
incinerator has been dismantled.
3
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TABLE A7-5. POTENTIAL CHEMICAL-SPECIFIC CRITERIA, ADVISORIES, AND GUIDANCE FOR OU-3.
BAIRD & MCGUIRE SITE, HOLBROOK, MASSACHUSETTS
MEDIA AND
AUTHORITY
REQUIREMENT
ROD
STATUS
ROD REQUIREMENT SYNOPSIS AND
CONSIDERATION IN THE FES
FIVE-YEAR REVIEW
Draft. DEQE,
1987.
Soil/Sediment
Federal Criteria,
Advisories and
Guidance
EPA Future
Interim Sediment
Criteria Values for
Nonpolar
Hydrophobic
Organic
Contaminants
(SCDNo. 17: May
1988)
To Be
Considered
These criteria have been recently developed by
EPA for 16 organic compounds. These criteria
represent levels protective of aquatic life.
These criteria were used to generate sediment
quality criteria values during the risk
assessment.
These criteria were never finalized and are no
longer used, having been replaced by other,
more appropriate criteria such as EPA Ecotax
Thresholds and Guidelines for the Protection
and Management of Aquatic Sediment Quality
in Ontario. These criteria are no longer to be
considered. See Table A7-6 for the
replacement criteria which are to be considered
during risk evaluation of sediment.
State Regulatory
Requirements
Soil Standards for
S-3 (310 CMR
40.0975(6)(c)
Applicable
The MCP establishes requirements and
procedures for the discovery, notification,
assessment of, and responses to, releases and
threats of release of oil or hazardous materials.
Pursuant to MCL c21 E and the MCP, the
Commonwealth of Massachusetts publishes a
list of confirmed oil or hazardous material to be
investigated. Because the Baird & McGuire
Site is a confirmed state hazardous material
Site and listed on the National Priorities List,
joint federal and state jurisdiction exists.
Cooperative agreements and contracts with the
federal government shall incorporate, to the
extent possible, the deadlines and specifications
of MCL c21E and the MCP.
The MCP includes a specific reference to
remediation at CERCLA sites (40.0 111) where
it is stated that the MCP does not apply to sites
adequately regulated under CERCLA. provided
that DEP concurs with the ROD and that
CERCLA addresses all contaminants. DEP
concurred with the ROD for this site.
Therefore, these rules are no longer considered
ARAR.
4
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TABLE A7-6. NUMERICAL CHEMICAL-SPEC IFIC ARARS CRITERIA,
ADVISORIES, AND GUIDANCE
FOR CONTAMINANTS OF CONCERN FOR OU-3
BAIRD & MCGUIRE SITE, HOLBROOK, MASSACHUSETTS
CHEMIC AL OF CONCERN
Surface Water
Sediment
Water Quality
Guideline
(Mg/I)
Source1
Sediment
Quality
Guideline
(mg/kg)
Source*
Organic Compounds:
Acenaphthalene
—
—
0.044
ER-L
Benzene
46
ET Tier II
0.057
SQB
Chlordane
0.0043
AWQC
0.00324
TEC
DDT (4.4'-)
0.001
AWQC
0.00416
TEC
Di(2-ethylhexyl)phthalate (DEHP)
32
ET Tier II
~
—
Dibenzofuran
20
ET Tier II
2
SQB
Dichloroethylene. 1,2-trans
590
SCV
—
--
Dichloromethane (Methylene chloride)
2200
SCV
—
-
Dieldrin
0.056
AWQC
0.0019
TEC
Dimethylphenol, 2,4-
—
—
..
—
Ethyl benzene
290
ET Tier II
3.6
SQC
Fluorene
3.9
ET Tier II
0.0774
TEC
Methylnaphthalcne, 2-
330
Region V
0.070
ER-L
Methylphenol, 4-
—
—
—
--
MonochJorobenzene
130
ET Tier II
0.82
SQB
Naphthalene
24
ET Tier II
0.176
TEC
PAHs'3'
....
—
1.61
TEC
Toluene
130
ET Tier II
0.67
SQB
T nchloroethane, 1,1,1-
62
ET Tier II
0.17
SQB
Tnchloroethvlene(TCE)
350
ET Tier 11
1.6
SQB
Xylenes (total)
13
SCV
0.025 4
SQB
Inorganics:
Arsenic
150
AWQC
9.79
TEC
Lead
2.5 5
AWQC
35.8
TEC
NOTES:
Current surface water quality guidelines were selected based on the following hierarchy:
I) EPA National Recommended Water Quality Criteria (AWQC) {EPA, 2013)
2) EPA Ecotox Thresholds (ET TIER II) for Surface Water (EPA. 1996)
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TABLE A7-6. NUMERICAL CHEMICAL-SPECIFIC ARARS CRITERIA,
ADVISORIES, AND GUIDANCE
FOR CONTAMINANTS OF CONCERN FOR OU-3
BAIRD & MCGUIRE SITE, HOLBROOK, MASSACHUSETTS
3) Secondary Chronic Values (SCVs) for aquatic biota developed by Oak Ridge National
Laboratory (Sulcr and Tsao, 1996)
4) Region V screening levels. US EPA Region V Ecological Screening Levels (EPA, 2003)
at httn:www.ena.tiov/rcg5 rcra/ca edo I. htm
Current sediment quality guidelines were selected based on the following hierarchy:
1) Consensus-based Threshold Effects Concentrations (TEC) for sediments (MacDonald el
al„ 2000)
2) EPA Ecotox Thresholds for Sediment (EPA, 1996). Citation for both EPA Sediment
Quality benchmarks by equilibrium partitioning (SQB) or EPA Sediment Quality Criteria
(SQC).
3) National Oceanic and Atmospheric Administration (NOAA) Effects Range -Low (ER-L)
for sediments (Long & Morgan, 1990; Long et ah 1995; respectively cited in Jones, Suter &
Hull, 1997)
Polycyclic Aromatic Hydrocarbons. Sediment quality guidelines are for total PAH
Sediment quality criteria for Xylenes is for m-Xylene
Hardness dependent
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TABLE A7-7. POTENTIAL ACTION-SPECIFIC ARARs FOR OU-3
BAIRD & MCGUIRE SITE, HOLBROOK, MASSACHUSETTS
ARAR
ROD REQUIREMENT SYNOPIS AND
STATUS
ACTION TO BE TAKEN TO
ATTAIN ARAR
FIVE-YEAR REVIEW
Federal Reaulatorv Requirements
RCRA - Generator
Standards (40 CFR
261, 265.170 -
265.174, 262.10 -
262.34)
If contaminated substances meet the definition
of RCR A-hazardous under 40 CFR 261,
RCRA requirements are applicable. If
contaminated substances at CERCLA sites are
determined to be sufficiently similar to RCRA
hazardous wastes, technical aspects of RCRA
requirements are considered relevant and
appropriate.
If removed from their existing location,
hazardous substances should be handled,
transported, and treated as RCRA hazardous
waste.
General generator requirements outline waste
characterization, management of containers,
packaging, labeling and manifesting.
ROD Status: Applicable
5-Year Status: Not ARAR
Treatment residuals from wastewater
treatment will be disposed of
according to RCRA. Waste
containers will be handled and
managed in accordance with RCRA.
These requirements were relevant and
appropriate to the incinerator. Sediments
have been remediated and may no longer be
considered a hazardous material. These rules
are no longer considered applicable, relevant
or appropriate to OU-3.
RCRA Land
Disposal Restrictions
(40 CFR 268)
If contaminated substances that meet the
definition of RCRA-hazardous. or are
sufficiently similar to RCRA hazardous wastes,
and are land disposed, RCRA LDR rules are
ARAR.
ROD Status: Applicable
5-Year Status: Not ARAR
RCRA land disposal requirements,
including treatment standards and
landfill requirements, must be
followed.
No materials meeting the definition of
RCRA-hazardous under 40 CFR Part 261
were land disposed on site. These rules are
not applicable or appropriate.
1
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TABLE A7-7. POTENTIAL ACTION-SPECIFIC ARARs FOR OU-3
BAIRD & MCGUIRE SITE, HOLBROOK, MASSACHUSETTS
ARAR
ROD REQUIREMENT SYNOPIS AND
STATUS
ACTION TO BE TAKEN TO
ATTAIN ARAR
FIVE-YEAR REVIEW
RCRA - Standards
for Owners and
Operators of
Pemiitted Hazardous
Waste Facilities (40
CFR 264.10-
264.18)
If a facility operated pursuant to RCRA
regulations. RCRA requirements are
applicable. If contaminated substances at
CERCLA sites are determined to be sufficiently
similar to RCRA hazardous wastes, technical
aspects of RCRA requirements are considered
relevant and appropriate.
If removed from their existing location,
hazardous substances should be handled,
transported, and treated as RCRA hazardous
waste.
General generator requirements outline general
waste analysis, security measures, inspections,
and training requirements.
ROD Status: Applicable
5-Year Status: Not ARAR
All facilities on-site will be
constructed, fenced, posted, and
operated in accordance with this
requirement. All workers will be
properly trained. Process wastes will
be evaluated for the characteristics of
hazardous wastes to assess further
requirements. Treatment residuals
from wastewater treatment will be
disposed of according to RCRA.
These requirements were relevant and
appropriate to the incinerator. The
incinerator has been dismantled. These rules
are no longer considered applicable, relevant
or appropriate to OU-3,
Clean Air Act
(CAA) Regulations,
NAAQs for
Particulates (40 CFR
50)
Site remediation activities, including
excavation and treatment, must comply with
NAAQS. The most relevant pollutant standard
at remedial response sites is for particulate
matter.
ROD Status: ARAR
5-Year Status: Not ARAR
This regulation specifies maximum
primary and secondary 24-hour
concentrations for fugitive dust.
Fugitive dust emissions from Site
activities must be maintained below
260 ug/m! (primary standard) by dust
suppressants if necessary.
These requirements were applicable to
excavation and incineration activities, which
are now complete. No further land disturbing
activities are planned, thus these rules are no
longer ARAR.
OSIIA General
These standards specify the type of safety
Worker safety rules are to be adhered
OSI IA requirements have been followed.
2
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TABLE A7-7. POTENTIAL ACTION-SPECIFIC ARARs FOR OU-3
BAIRD & MCGUIRE SITE, HOLBROOK, MASSACHUSETTS
ARAR
ROD REQUIREMENT SYNOPIS AND
STATUS
ACTION TO BE TAKEN TO
ATTAIN ARAR
FIVE-YEAR REVIEW
Industry Standards,
Recordkeeping and
Reporting, and
Standards for
Hazardous Waste
Site Operations
1926,1904, 1910
(29 CFR)
equipment and other worker safety procedures
to be followed during all remedial activities.
ROD Status: Applicable
5-Year Status: Not ARAR
to an all workplace risks are to be
communicated to employees.
EPA no longer considers OSHA rules ARAR
as they are worker safety rules that must
always be complied with.
State Regulatory Requirements
Massachusetts
Hazardous Waste
Management Rules
(MHWMR) (310
CMR 30.00)
Massachusetts is authorized by EPA to
administer substantial portions of the federal
RC'RA program. I f a facility operated pursuant
to RCRA regulations, RCRA requirements are
applicable. Similar to the RCRA regulations,
these rules will be considered relevant and
appropriate at CERCLA sites where the
hazardous contaminants have been determined
to be sufficiently similar to the designated
hazardous wastes, and proposed remedial
actions are similar to hazardous waste
treatment, storage, and/or disposal.
ROD Status: Applicable
5-Year Status: Not ARAR for OU-3
Because these regulations supplement
RCRA hazardous waste regulations,
they must also be considered at the
Site.
These requirements are relevant and
appropriate to operations at the groundwater
treatment facility (OU-1). These rules are no
longer considered applicable to OU-3.
Massachusetts
Contingency Plan
The MCP establishes requirements and
procedures for the discovery, notification,
The revised MCP sets applicable
standards in soil. The MCP method 1
The MCP includes a specific reference to
remediation at CERCLA sites (40.0111)
3
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TABLE A7-7. POTENTIAL ACTION-SPECIFIC ARARs FOR OU-3
BAIRD & MCGUIRE SITE, HOLBROOK, MASSACHUSETTS
ARAR
ROD REQUIREMENT SYNOPIS AND
STATUS
ACTION TO BE TAKEN TO
ATTAIN ARAR
FIVE-YEAR REVIEW
(MCP) (310 CMR
40.0000)
assessment of, and response to, releases and
threats of release of oil or hazardous materials.
Pursuant to MCL c. 21E and the MCP, the
Commonwealth of Massachusetts publishes a
list of confirmed oil or hazardous material to be
investigated. Because the Baird & McGuire
Site is a confirmed state hazardous material
Site and listed on the National Priorities List,
joint federal and state jurisdiction exists.
Cooperative agreements and contracts with the
federal government shall incorporate, to the
extent possible, the deadlines and specifications
ofMGL c21E and the MCP.
ROD Status: Applicable
5-Ycar Status: Not ARAR
soil standards consider both the
potential risk of harm resulting from
direct exposure to the contaminated
soil and potential impacts at the Site
via leaching. On-site soils are
classified according to the frequency
and intensity to which human contact
may occur.
where it is stated that the MCP does not
apply to sites adequately regulated under
CERCLA, provided that DEP concurs with
the ROD and that CERCLA addresses all
contaminants. DEP concurred with the ROD
for this site, therefore, these rules are no
longer considered ARARs.
Massachusetts Air
Pollution Control
Regulations (310
CMR 6.00 through
8.00)
These regulations outline the standards and
requirements for air pollution control in
Massachusetts. Specific regulations generally
considered ARARs at CERCLA sites include
the particulate matter standard (for excavation
and treatment activities), and plan approval and
emission limitations (for treatment activities,
such as incineration, generating pollutant
emissions).
ROD Status: Applicable
5-Year Status: Not ARAR
310 CMR 6.00 provide ambient air
quality standards for the
Commonwealth. 310 CMR 7.09
provides dust standards and 310
CMR 7.08 provides incinerator
standards for establishing discharge
limits.
These requirements were applicable to the
excavation and incineration of debris. These
activities are completed, and no further land
disturbing activities are planned. There are
no air emission sources on site. These rules
are no longer ARAR.
4
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