EP A/ROD/RO1 -04/613
2004

EPA Super fund

Record of Decision:

IRON HORSE PARK
EPA ID: MAD051787323
OU 03

BILLERICA, MA
09/30/2004

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U.S. EPA New England, Region 1

Record of Decision

For

Iron Horse Park Superfund Site
Operable Unit 03

Billerica, Massachusetts

September 30, 2004

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U.S. ENVIRONMENTAL PROTECTION AGENCY

REGION 1

IRON HORSE PARK SUPERFUND SITE, OU3
RECORD OF DECISION SUMMARY
SEPTEMBER 2004

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Record of Decision
Table of Contents

PART 1: THE DECLARATION

SITE NAME AND LOCATION

A.	STATEMENT OF BASIS AND PURPOSE

B.	ASSESSMENT OF SITE

C.	DESCRIPTION OF SELECTED REMEDY

D.	STATUTORY DETERMINATIONS

E.	DATA CERTIFICATION CHECKLIST

F.	AUTHORIZING SIGNATURES

PART 2: THE DECISION SUMMARY

A.	SITE NAME, LOCATION AND BRIEF DESCRIPTION

B.	SITE HISTORY AND ENFORCEMENT ACTIVITIES

1.	History of Site Activities

2.	History of Federal and State Investigations and Removal
and Remedial Actions

3.	History of CERCLA Enforcement Activities
c. COMMUNITY PARTICIPATION

D.	SCOPE AND ROLE OF OPERABLE UNIT OR RESPONSE ACTION

E.	SITE CHARACTERISTICS

F.	CURRENT AND POTENTIAL FUTURE SITE AND RESOURCE USES

1.	Land Uses

2.	Groundwater Uses

G.	SUMMARY OF SITE RISKS

1.	Human Health Risks

2.	Ecological Risks

3.	Basis for Response Action

H.	REMEDIATION OBJECTIVES

I.	DEVELOPMENT AND SCREENING OF ALTERNATIVES
J. DESCRIPTION OF ALTERNATIVES

K.	SUMMARY OF COMPARATIVE ANALYSIS OF ALTERNATIVES

L.	THE SELECTED REMEDY

M.	STATUTORY DETERMINATIONS

N.	DOCUMENTATION OF SIGNIFICANT CHANGES

0.	STATE ROLE

PART 3: THE RESPONSIVENESS SUMMARY

A.	FULL COMMENTS

B.	SUMMARIZED COMMENTS AND EPA RESPONSES

APPENDICES

Appendix A:	State Letter of Concurrence

Appendix B:	Figures

Appendix C:	Tables

Appendix D:	Glossary of Terms and Acronyms

Appendix E:	Administrative Record Index and Guidance Documents

Page 1
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Page 3
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Page 19
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Page 2 6
Page 27
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PART 1: THE DECLARATION

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DECLARATION FOR THE RECORD OF DECISION

Iron Horse Park
Billerica, Massachusetts
MAD051787323
Operable Unit 3

A.	STATEMENT OF BASIS AND PURPOSE

This decision document presents the selected remedial action for the Iron Horse Park
Superfund Site, Operable Unit 3 (0U3) (Site), in Billerica, Massachusetts, which was chosen in
accordance with the Comprehensive Environmental Response, Compensation and Liability Act
of 1980 (CERCLA), 42 USC ( 9601 et seq., as amended by the Superfund Amendments and
Reauthorization Act of 1986 (SARA), and, to the extent practicable, the National Oil and
Hazardous Substances Pollution Contingency Plan (NCP), 40 CFR Part 300, as amended. The
Director of the Office of Site Remediation and Restoration (OSRR) has been delegated the
authority to approve this Record of Decision.

This decision was based on the Administrative Record, which has been developed in accordance
with Section 113 (k) of CERCLA, and which is available for review at the Billerica Public
Library and at the United States Environmental Protection Agency (EPA) Region 1 OSRR Records
Center in Boston, Massachusetts. The Administrative Record Index (Appendix E to the ROD)
identifies each of the items comprising the Administrative Record upon which the selection of
the remedial action is based.

The Commonwealth of Massachusetts concurs with the Selected Remedy

B.	ASSESSMENT OF THE SITE

The response action selected in this ROD is necessary to protect the public health or
welfare or the environment from actual or threatened releases of hazardous substances into
the environment.

C.	DESCRIPTION OF THE SEIiECTED REMEDY

This ROD sets forth the selected remedy for OU3 at the Iron Horse Park Superfund Site, which
involves the capping (source control) of landfills and contaminated soil areas at six
different Areas of Concern (AOCs) and the maintenance of an existing landfill cap at a
seventh AOC. Institutional controls, in the form of land use restrictions, will be used to
prevent exposures and preserve elements of the remedy. The selected remedy is a comprehensive
approach for this operable unit that addresses all current and potential future risks caused
by soil contamination. Specifically, this remedial action includes waste and contamination
associated with the B&M Railroad Landfill, the RSI Landfill, the B&M Locomotive Shop Disposal
Areas, the Old B&M Oil/Sludge Recycling Area, the Contaminated Soils Area, the Asbestos
Landfill and the Asbestos Lagoons. The remedial measures will ensure that: soil from the
B&M Locomotive Shop Disposal Area, the Old B&M Oil/Sludge Recycling Area and the Contaminated
Soils Area will no longer present an unacceptable risk to human health via ingestion of lead;
that the Asbestos Landfill and the Asbestos Lagoons will no longer present a potential human
health risk via inhalation of asbestos; and, that the BdkM Railroad Landfill and the B&M
Locomotive Shop Disposal Area will no longer present an unacceptable environmental risk from
ecological receptors' ingestion and direct contact with cadmium, copper, and lead. An
additional expected outcome is that source control actions, specifically capping, will remove
the B&M Railroad Landfill, the RSI Landfill, the B&M Locomotive Shop Disposal Areas, the Old
B&M Oil/Sludge Recycling Area, the Contaminated Soils Area and the Asbestos Lagoons as
ongoing contributors of contamination to local groundwater by volatile organic compounds
(VOCs), semi-volatile organic compound (SVOCs), pesticides, polychlorinated biphenyls (PCBs),
and inorganics.

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The maior comgonents of this remedy are

1.	Capping of source areas (with the capping standards that apply):

•	At the B&M Railroad Landfill - Hazardous Waste Cap - Region 1 Alternative Cap
Design/Solid Waste Disposal let (SWDA), Subtitle C 1

•	At the RSI Landfill, B&M Locomotive Shop Disposal Areas and the Asbestos Lagoons -

Solid Waste Cap - SWDA, Subtitle D 2

•	At the Old B&M Oil/Sludge Recycling Area and the Contaminated Soils Area - Solid
Waste/Asphalt Cap - Massachusetts DEP Landfill Technical Guidance Manual/Solid Waste
Disposal Act (SWDA), Subtitle D

•	At the Asbestos Landfill - Maintenance of the existing Toxic Substances Control Act

(TSCA) 3 cap

2.	Institutional Controls in the form of land use restrictions to be implemented by
responsible parties

3.	Groundwater monitoring to assess effectiveness of source control actions

The total estimated cost of the selected remedy for 0U3 is: $23.53 million

This OU is one of four operable units at this site. While part of the same superfund site,
0U1 (the B&M Wastewater Lagoons) and 0U2 (Shaffer Landfill) are distinct areas of the Site,
with unigue contamination histories and which are essentially independent of other parts of
the site with regards to remedial action. The intention of 0U3 is to address the remaining
source areas, while 0U4 will address site-wide groundwater, surface water and sediment. EPA
is in the process of gathering site specific toxicity data related to surface water and
sediment. The 0U4 ROD is scheduled for 2006.

The selected response action addresses low-level threat wastes at the site by: eliminating
exposure to human and ecological receptors from contaminated soil and airborne asbestos. This
is accomplished through source control actions at the affected AOCs (capping of landfills and
contaminated soil areas). In addition, the source control actions will help eliminate the
ongoing migration of contaminants from the source areas to groundwater or surface water. Long
term monitoring/maintenance and institutional controls will ensure that the remedy remains
protective in the future. There are no principal threat wastes at OU3.

D. STATUTORY DETERMINATIONS

The selected remedy is protective of human health and the environment, complies with
Federal and State reguirements that are applicable or relevant and appropriate to the
remedial action (unless justified by a waiver), is cost-effective, and utilizes permanent
solutions and alternative treatment (or resource recovery) technologies to the maximum extent
practicable.

Based on the size and location of the landfills and contaminated soil areas, EPA concluded
that it was impracticable to excavate and treat the chemicals of concern in a cost-effective
manner. Thus, the selected remedy does not satisfy the statutory preference for treatment as
a principal element of the remedy.

1	As enacted under the Resource Conservation and Recovery Act, 42 U.S. §§ 6921 et seq.

2	42 U.S.C. §§ 6941 et seg.

3	15 U.S.C. §§ 2601 et seg.

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Because this remedy will result in hazardous substances remaining on-site above levels that
allow for unlimited use and unrestricted exposure (and groundwater and/or land use
restrictions are necessary), a review will be conducted within five years after initiation of
remedial action to ensure that the remedy continues to provide adeguate protection of human
health and the environment. Hazardous substances already remain at the Site due to previous
actions (0U2 Shaffer Landfill closure). Because of this, the most recent Five-Year Review was
completed by EPA in September 2003. The next review will be reguired by September 2008.

E. SPECIAL FINDINGS

Issuance of this ROD embodies specific determinations made by the Regional Administrator
pursuant to CERCLA and section 404 of the Clean Water Act, 33 U.S.C. § 1251 et seg., the
remedy is the least damaging practicable alternative for protecting aguatic ecosystems at the
site under the standards of 40 CFR Part 230. Specifically, at the B&M Railroad Landfill EPA
expects impacts to both wetlands and the 100-year floodplain. At the B&M Railroad Landfill,
the RSI Landfill, and the B&M Locomotive Shop Disposal Areas, EPA proposes capping the
waste in place, which will potentially result in minor to moderate disturbances to wetlands
as landfill area is moved back; EPA anticipates potentially moderate loss of floodplain/
storage capacity at the B&M Railroad Landfill due to increased landfill cap elevation. At the
Asbestos Landfill, EPA expects temporary and minor wetland disturbance due to fence
installation. The potential need for replacement floodplain storage capacity will be
addressed during the design process and alteration of wetlands will be addressed through
mitigation measures. Due to the location of these AOCs in or near wetlands and/or floodplain
areas, EPA cannot identify a less damaging practicable alternative for each AOC which would
avoid impacting the wetland and/or floodplain areas while adeguately addressing site risks.

E. ROD DATA CERTIFICATION CHECKLIST

The following information is included in the Decision Summary section of this Record of
Decision. Additional information can be found in the Administrative Record file for this
site.

1.	Chemicals of concern (COCs) and their respective concentrations

(Table G-l, G-2, G-3, G-8, G-9, G-10)

2.	Baseline risk represented by the COCs

(Table G-6, G-l, 6-8, G-9, 6-10)

3.	Cleanup levels established for COCs and the basis for the levels

(Table CL-1 and CL-2, pages 56-57)

4.	Current and future land and ground-water use assumptions used in the baseline risk
assessment and ROD (pages 17-19)

5.	Land and groundwater use that will be available at the site as a result of the selected
remedy (page 55)

6.	Estimated capital, operation and maintenance (O&M), and total present worth costs;
discount rate; and the number of years over which the remedy cost estimates are projected
(Table L-l thru L-7)

7.	Decisive factor(s) that led to selecting the remedy (page 26)

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F. AUTHORIZING SIGNATURES

This ROD documents the selected remedy for soil at 0U3 at the Iron Horse Park Superfund
Site. This remedy was selected by the EPA with concurrence of the Massachusetts Department
of Environmental Protection.

Concur and recommended for immediate implementation:

U.S. Environmental Protection Agency

Date:	Jl»V

Susan Studlien
Director

Office of Site Remediation and Restoration
Region 1

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PART 2: THE DECISION SUMMARY

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A. SITE NAME, LOCATION AND DESCRIPTION

•	Address

Iron Horse Park

High Street

North Billerica, MA.

•	National Superfund electronic database identification number, e. g. , CERCLIS
identification number for Iron Horse Park is: MAD051787323

•	The lead entity for Operable Unit 3 of Iron Horse Park is EPA
Site Description

The Iron Horse Park site, located in Billerica Massachusetts, is a 553-acre industrial
complex which includes manufacturing and railyard maintenance facilities, open storage
areas, landfills, and wastewater lagoons. A long history of activities at the site,
beginning in 1913, has resulted in the contamination of soil, groundwater, and surface
water. Under the Comprehensive Environmental Response, Compensation, and Liability Act
(CERCLA), 42 U.S.C. §§ 9601, et seg. , the site was listed on the National Priorities List
(NPL) in 1984 and was subseguently divided into three operable units (OU). Although part of
the same NPL listing, these three operable units are distinct areas of the Site. OU1, which
consists of a former 15 acre wastewater lagoon area and OU2, a 60-acre landfill have both
completed remedial action. The OU3 study area encompasses the rest of the site.

Operable Unit 3 is characterized by numerous source areas, an extensive wetland system,
multiple property owners, a complex history and widespread environmental impacts. Due to the
complicated nature of the original operable unit, OU3 was ultimately divided into two
operable units. This Record of Decision ( ROD) addresses the 7 Areas of Concern located
within the original OU3. What is now defined as Operable Unit 3 will address Capping and
Source Control measures which will be implemented to address potential sources of
contamination, and are intended to prevent further spread of contamination to groundwater,
surface water and sediment. The potential remediation of site wide surface water, sediment
and groundwater will be addressed as a part of Operable Unit 4.

The source areas addressed are (See Figure 1-2):

B& M Railroad Landfill - A 14-acre landfill near the commuter rail line.

RSI Landfill - A 6-acre landfill adjacent to the rail yard.

B& M Locomotive Shop Disposal Areas - There are two disposal areas which total approximately
land 3 acres in area. They are separated by a man-made channel.

Old B&M Oil/Sludge Recycling Area - Approximate 6-acre area was established sometime prior
to 1938 for the purpose of recycling oil. It was filled in at a later date and until recently
was primarily owned by the Penn Culvert Company.

Contaminated Soils Area - Approximate 50 acre area is located in the center of the Iron Horse
Park Superfund Site.

Asbestos Landfill - Previously utilized by Johns-Manville for disposal of asbestos- related
materials, 13-acre landfill capped by EPA in 1984 as part of a removal action.

Asbestos Lagoons - Three unlined former asbestos lagoons on Johns-Manville (currently BNZ
Materials) property which received an asbestos slurry pumped from the adjacent manufacturing
operation. Asbestos from these lagoons was disposed of in the asbestos landfill.

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A more complete description of the Site can be found in Section 1 of the Remedial
Investigation Report.

B. SITE HISTORY AND ENFORCEMENT ACTIVITIES

1. History of 0U3 Activities

The 553 acres of land that now make up 0U3 were first purchased by the B&M Railroad (now
known as B&M Corporation) in 1911. Prior to that year, the Site consisted of approximately 18
privately owned parcels that B&M Corporation consolidated. Since 1911, a variety of
industrial disposal practices have resulted in the creation of numerous lagoons, landfills,
and open storage areas. At various times over the years, B&M Corporation has sold or leased
several parcels of the land and some of the buildings on the Site to various companies. B&M
operated an oil and sludge recycling area beginning sometime prior to 1938. This operation
took place on property which was subseguently owned by Penn Culvert and currently,

Cooperative Reserve Supply, Inc. In 1944, the B&M Railroad sold approximately 70 acres of
land in the western portion of the Site to Johns-Manville Products Corporation, which at that
time began to manufacture structural insulating board that contained asbestos. Three unlined
lagoons were built to dispose of the resulting asbestos sludge waste. At approximately the
same time, the B&M Railroad leased approximately 15 acres of land in the eastern portion of
the Site to Johns-Manville to be used as a landfill for asbestos sludge and other asbestos
mill wastes generated by their manufacturing operations. EPA capped this landfill in 1984 as
part of an "Immediate Removal Action" under CERCLA. The B&M Landfill, the RSI Landfill, and
the B&M Locomotive Shop Disposal Areas were unmonitored landfill/disposal operations.

A more detailed description of the Site history can be found in Section 1 of the Remedial
Investigation Report.

2. History of Federal and State Investigations and Removal and Remedial Actions

Date

Action

Legal
Authority

Who
Undertook

Results

Related
Documents

1984

Time Critical
Removal

CERCLA

EPA

Consolidation
and capping
of asbestos waste

Action
Memorandum

1987

Site Investigation

CERCLA

EPA

Division of Iron
Horse Park into
operable units

Phase 1A
Remedial
Investigation

1997

Site Investigation

CERCLA

EPA

Risk Assessment

Remedial
Investigation
Final Report
(OU3)

2004

Feasibility
Study

CERCLA

EPA



Proposed Plan

3. History of CERCLA Enforcement Activities

On May 6, 2004, EPA notified five (5) potentially responsible parties (PRPs) who either
owned or operated the facility, generated wastes that were shipped to the facility, arranged
for the disposal of wastes at the facility, or transported wastes to the facility of their
potential liability with respect to the Site. In addition, on May 13, 2004, EPA issued
Potentially Interested Party (PIP) letters to ten (10) parties. Negotiations with the PRPs
have not yet commenced regarding the settlement of the PRPs' liability at OU3.

The PRPs have been active in the remedy selection process for this Site. One PRP submitted
comments on the Proposed Plan. The PRP comment letter (as well as other comments received
during the comment period) is included in the Administrative Record. The comments are

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summarized and responded to in the Responsiveness Summary section of this ROD.

C.	COMMUNITY PARTICIPATION

Throughout the Site's history, community concern and involvement with 0U3 has been moderate
(historically the community has been most concerned and involved with 0U2, Shaffer Landfill).
EPA has kept the community and other interested parties apprized of 0U3 activities through
informational meetings, fact sheets, press releases and public meetings. Below is a brief
chronology of public outreach efforts.

•	In September and December of 1983, and March and August of 1984, EPA held meetings in
Billerica regarding environmental sampling and the Asbestos Landfill.

•	In August 1985, the EPA released a community relations plan that outlined a program to
address community concerns and keep citizens informed about and involved in remedial
activities.

•	Local residents formed the Earthwatch Coalition to monitor Site activities. On
September 29, 1993, they applied for a Technical Assistance Grant (TAG). The grant was
awarded on March 4, 1994 and the Earthwatch Coalition retained a TAG consultant that
has attended some technical project meetings.

•	In November 1998, EPA issued a Fact Sheet which discussed the results of the Remedial
Investigation and announced the upcoming informational meeting in Billerica.

•	On December 1, 1998, EPA held an informational meeting in Billerica to discuss the
results of the Remedial Investigation.

•	On June 2, 2004, EPA made the administrative record available for public review at
EPA's offices in Boston and at the Billerica Public Library, 15 Concord Road,

Billerica. This was established as the primary information repository for local
residents and has been kept up to date by EPA.

•	EPA published a notice and brief analysis of the Proposed Plan on June 6, 2004 in the
Lowell Sun and on June 10, 2004 in the Billerica Minuteman and made the plan available
to the public at the Billerica Public Library, 15 Concord Road, Billerica.

•	From June 16, 2004 to July 16, 2004, the Agency held a 30 day public comment period to
accept public comment on the alternatives presented in the Feasibility Study and the
Proposed Plan and on any other documents previously released to the public. An
extension to the public comment period was reguested and as a result, it was extended
to August 13, 2004.

•	On, June 16, 2004 EPA held an informational meeting to discuss the results of the
Remedial Investigation and the cleanup alternatives presented in the Feasibility Study
and to present the Agency's Proposed Plan to a broader community audience than those
that had already been involved at the Site. At this meeting, representatives from EPA
answered guestions from the public.

•	Also on June 16, 2004, the Agency held a public hearing to discuss the Proposed Plan
and to accept any oral comments. A transcript of this meeting and the comments and the
Agency's response to comments are included in the Responsiveness Summary, which is part
of this Record of Decision.

D.	SCOPE AND ROLE OF OPERABLE UNIT OR RESPONSE ACTION

As with many Superfund sites, the problems at Iron Horse Park are complex. As a result, EPA
has organized the work into 4 operable units (OUs):

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•	0U1: The BSM Wastewater Lagoons addressed contamination in an approximately 15

acre area, in and around the former wastewater lagoons. EPA selected a remedy for 0U1
in a September 1988 ROD. The ROD selected bioremediation to address contamination
in soil and sediment. This remedy was later modified to utilize off-site asphalt
batching. The remedy for 0U1 was completed in 2003 with an Remedial Action (RA) Report.

•	OU2: The Shaffer Landfill addressed contamination at the 60 acre former mixed waste
landfill. EPA selected a remedy for OU2 in a June 1991 ROD. The ROD selected capping
and collection and disposal of leachate to address groundwater contamination.
Construction of the remedy for OU2 was completed in 2003 with an Interim RA Report. OU2
is currently in the Operation and Maintenance phase.

•	OU3: This ROD, for OU3, addresses the remaining, previously identified source areas
within Iron Horse Park utilizing source control technologies to prevent direct contact
with contaminants by human and ecological receptors and to prevent the spread of
contamination to groundwater and surface water.

•	OU4: During the OU3 Remedial Investigation and for most of the Feasibility Study (FS),
it was intended that the OU3 ROD was to be the Final ROD for Iron Horse Park. During
the FS, modeling was conducted on the alternatives being considered to address
groundwater contamination. According to the modeling results, none of the remedial
measures would have achieved cleanup reguirements in a reasonable time period (modeling
generally predicted in excess of 200 years). Groundwater will be re-evaluated as to
whether further characterization is reguired or whether other measures are necessary in
order to address site-wide groundwater in the ROD for OU4

With regard to surface water and sediment, site-specific toxicity data has not been
previously collected for these media. EPA feels that the lack of this data, prevents a
high enough degree of confidence in ecological risk conclusions to be able to choose a
remedy at this time. Therefore, the site-specific toxicity data will be collected and
incorporated into an amended risk assessment and remedy decisions for surface water and
sediment will be included in the ROD for OU4.

The selected response action for OU3 addresses low-level threat wastes by eliminating
exposure to human and ecological receptors from contaminated soil and airborne asbestos. This
is accomplished through source control actions at the affected AOCs (capping of landfills and
contaminated soil areas) . In addition, the source control actions will help eliminate the
ongoing migration of contaminants from the source areas to groundwater or surface water.

There are no principal threat wastes at OU3.

E. SITE CHARACTERISTICS

Section 1 of the Final Feasibility Study of May 2004 contains an overview of the Remedial
Investigation. The significant findings of the Remedial Investigation are summarized below.

The 553 acres of land that comprise the Site (Figure 1-2) were first purchased by the B&M
Railroad (now known as B&M Corporation) in 1911. Prior to that year, the Site consisted of
approximately 18 privately owned parcels that B&M Corporation consolidated. Land-use
records for these parcels prior to 1911 were not recorded. However, since 1911, a variety of
industrial disposal practices have resulted in the creation of numerous lagoons, landfills,
and open storage areas. Table 1-1 of the May 2004 FS Report provides a chronology of the
activities at the Site.

As a result of the Phase 1A RI completed in 1987, areas of concern identified at the Site
were divided into three operable units: the B&M Wastewater Lagoons (operable unit 1), the
Shaffer Landfill (operable unit 2), and the remaining areas of concern (operable unit 3)
including the B&M Railroad Landfill, B&M Locomotive Shop Disposal Areas (A and B), the
Reclamation Services Inc. (RSI) Landfill, the Old B&M Oil/Sludge Recycling Area, the
Contaminated Soils Area, the Asbestos Landfill, the Asbestos Lagoons, and Site-Wide Surface

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Water and Sediment Contamination. Operable unit 3 is addressed in the May 2004 FS Report.
Selected surface water and sediment locations are being evaluated to further determine
potential ecological effects as part of operable unit 4.

The area of study evaluated during the RI included not only the applicable portions of the
Site, but also surrounding areas and water bodies that are potentially affected by operable
unit 3 (the 3rd operable unit). For this reason, the entire study area evaluated during the
RI is referred to throughout this report as "the Site." The area of study that was evaluated
during the Remedial Investigation is shown in Figure 1-1.

Areas of concern (AOCs) in OU3 consist of the B&M Railroad Landfill, the B&M Shop Disposal
Areas (A and B), the RSI Landfill, the Old B&M Oil/Sludge Recycling Area, the Contaminated
Soils Area, and the asbestos contamination areas (including the Asbestos Landfill and the
Asbestos Lagoons). Surface water and sediment contamination by wetland group (West Middlesex,
Wetland 2, East Middlesex, Richardson Pond, and Content Brook) will be addressed in OU4. The
media of concern in OU3 is surface and subsurface soil, while groundwater, surface water, and
sediment will be the media of concern in OU4. Contaminants detected most frequently on site
included volatiles, semi-volatiles, pesticides, polychlorinated biphenyls (PCBs), asbestos,
and metals.

Waste Disposal Practices and Contaminant Sources by Area of Concern

B&M Railroad Landfill. The B&M Railroad landfill is approximately 14 acres in size and is
located in a wetland area, north of the Middlesex Canal and east of the rail yard. The
wetland was filled in by the B&M Railroad and used to dispose of various kinds of debris.
Partially buried drums and railroad ties with creosote have been observed in this area.

RSI Landfill. The 6-acre RSI Landfill, located east of the B&M rail yard near the
Johns-Manville Asbestos Landfill, is bounded on the south by an unnamed brook and on the east
by a wetland, which the Middlesex Canal drains. This area was used by B&M as a borrow pit for
sand and gravel sometime between 1961 and 1969.

From June of 1971 until August of 1971, the Massachusetts Division of Environmental Health
granted RSI permission to use the B&M land to dispose of its loose, burnt refuse. The waste
disposed of by RSI on B&M land was classified as municipal and light industrial solid wastes
from the cities of Cambridge and Somerville.

B&M Locomotive Shop Disposal Areas. The B&M Locomotive Shop Disposal Areas consist of two
disposal areas separated by a manmade channel that flows into an unnamed brook. The first
area, located on the north side of the channel and approximately 1 acre in size is referred
to as Area A.

The second area located on the south side of the channels is approximately 3 acres in size
and is referred to as Area B. Prior to 1938 and until about 1979, Area B was used to dispose
of various kinds of "light and dark-toned materials." Various kinds of debris, including
deteriorated drums have been observed in this area.

Old B&M Oil/Sludge Recycling Area. The 6-acre, Old B&M Oil/Sludge Recycling Area was
established sometime prior to 1938 for the purpose of recycling oil. A B&M Railroad site
plan, dated 1972, shows two adjacent areas designated as "oil and sludge" which appear to be
located about 300 feet west of the B&M locomotive shop repair facility. These two areas,
where the oil and sludge pooled, had a combined dimension of 600 by 200 feet. In 1973, the
Penn Culvert Company purchased the parcel of land containing these two disposal areas and
sometime later filled them in.

Contaminated Soils Area. The Contaminated Soils Area is located in the center of the Iron
Horse Park Superfund Site and is approximately 50 acres in size. The Contaminated Soils Area
encompasses properties owned by Eastern Terminals, Inc., Wood Fabricators, and the
Massachusetts Bay Transportation Authority (MBTA) (Figure 1-3).

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Contaminated soil was first identified as a problem in the central portion of the Iron Horse
Park Superfund Site after a random soil boring program conducted across the Site indicated
elevated levels of lead (310 to 76,600 ppm) at nine out of forty locations.

Asbestos Landfill. The Site has historically been identified with asbestos contamination due
to asbestos landfilling operations conducted by Johns-Manville over a 32-year period.

Although EPA capped the Asbestos Landfill in 1984, "asbestos contamination" was identified as
a potential operable unit because the cap was not maintained. The integrity of the cap was
evaluated as part of the RI. The entire western boundary of the cap is not fenced.

In 1985, during the Phase 1A RI, surficial soils (0 to 3 inches) from 40 random boring
locations were analyzed for the presence of asbestos. Asbestos was detected at 28 of the
locations sampled and, at eight of these located on Johns-Manville (currently BNZ Materials),
Penn Culvert, and B&M properties, asbestos was present at levels greater than 1%. This
suggested that wind-blown deposition of asbestos had occurred in portions of the Site on B&M
property adjacent to the landfill, as well as on Johns- Manville (currently BNZ Materials)
property where the asbestos waste originated. These sample results outside BNZ Materials
property, are sporadic in nature, and with two exceptions, the results are either non- detect
for asbestos, or contain less than 1% asbestos. These results do not suggest a pattern of
asbestos contamination outside of the BNZ Materials property.

An off-site soil sampling program was also conducted to determine the extent, if any, of
windnblown asbestos in residential areas bordering the Site. The results of the off-site
soil sampling indicated that, with one exception, there were no detectable levels of asbestos
in these residential areas and the Draft Phase 1A RI report, concluded that deposition of
wind- blown asbestos from the Site on off-site areas most likely did not occur.

The Asbestos Landfill Cap Evaluation Report was submitted to EPA in February 1994. This
report documents the evaluation of the current condition of the landfill cap surface and
recommends corrective actions to be implemented to protect public health and comply with
state and federal regulations.

Asbestos Lagoons. In addition to the Asbestos Landfill, there are three unlined asbestos
lagoons on Johns-Manville (currently BNZ Materials) property. One of these lagoons has been
filled and covered. "When the lagoons were operated by Johns-Manville, they received an
asbestos slurry pumped from the adjacent manufacturing operations. Asbestos from these
lagoons was disposed of in the Asbestos Landfill; however, the lagoons still contain some
asbestos, as well as other wastes.

The lagoons continued to receive wastewater from Johns-Manville operations after asbestos
manufacturing operations closed. While this discharge allegedly did not contain asbestos, it
may have contained some other hazardous substances. During the Remedial Investigation
xylenes, toluene, manganese and other contaminants were detected in Asbestos Lagoons
sediments.

Site-Wide Surface Water and Sediment Contamination. The Middlesex Canal, as well as several
ponds, wetlands, and streams ( which will be addressed under OU 4) flow through and are
adjacent to the OU3 areas of concern at the Site. Potential contamination of surface water
and sediment as a result of surface runoff and groundwater contamination migration and
discharge are of concern and are addressed under source control provisions within the OU3
remedy.

The quantity/volume of waste that may need to be addressed by media and disposal area are
presented in Table 2-12 of the May 2004 Feasibility Study Report.

Geographic Setting

The Site is located in North Billerica, Massachusetts, approximately 8 miles south of the New
Hampshire border, at an elevation of about 115 feet above sea level.

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Located in eastern Massachusetts, the Site is on the western side of the Seaboard Lowland
section of the New England physiographic province, a subdivision of the Appalachian
Highlands. The Seaboard Lowlands are characterized by extensive glacial outwash and till
deposits overlying a complex of igneous and metamorphic rocks.

The Site lies on the western edge of the Shawsheen River drainage basin and is approximately
1.5 miles from the northward- flowing Shawsheen River. The Iron Horse Park Superfund Site is
surrounded by upland areas on the southeast side, including several small forested hills near
Pond Street, and low lying wetland areas on the western, northern, and northeastern side of
the Site. Currently, 17% of the Site is characterized as wetlands.

Soils on and in the immediate vicinity of the Site are classified as predominantly urban land
with other soil types to a lesser extent. Urban land is indicated in areas where the soil has
been disturbed or altered, is obscured by cultural features (e.g., buildings, industrial
areas, roads, rail yards) and where these features cover more than 75% of the surface area.

The Site is used for industrial purposes, with no residential use. Some parts of the Site are
fenced, but most is accessible to passers- by. The area within one mile of the Site boundary
is primarily forest and residential, consisting primarily of single-family residential
properties.

Surface waters in the vicinity of the Shaffer Landfill (0U2) on the Site are classified as
Class B waters by the Commonwealth of Massachusetts and are designated for use as warm water
fisheries and contact recreation. The Middlesex Canal, linking the Merrimack River to the
Boston basin, runs through the Site, and some of its original features remain. It is
essentially impassable for recreation or economic purposes. Histories of the canal indicate
that clay was used along the canal banks to limit seepage of the canal water into neighboring
lowlands. However, use of the clay liner in the canal may have been limited in extent.

A town inventory of historical properties revealed two historical assets within the site
boundaries. The Small Pox Cemetery, dating back to 1811, is located between the Middlesex
Canal and the MBTA commuter railroad line. The Content Brook Mill is located at the eastern
end of the Shaffer Landfill property.

Files on five historic locations within or adjacent to the Site are maintained by the
Massachusetts Historical Commission (MHC). These include the Pond Street Bridge over the B&M
Railroad at the Site boundary (inventoried as BIL. 917) , the Middlesex Canal (BIL 934, BIL K
and BIL P), the B&M Railroad Billerica Shop Complex (BIL. 299), the Eguipment Storage Shed
(BIL. 300), the Maintenance Shed (BIL. 301), and the Power Plant (BIL. 302), the last four
being centrally located on the Site.

As shown in Figure 1-4, part of the Site overlies what is expected to be a medium-yield
aguifer. The remainder is expected to be a low-yield aguifer. No public water supply sources
are located within the medium-yield aguifer on the Site, but the groundwater beneath the
medium-yield aguifer is considered a potential drinking water source by both EPA and the
Commonwealth of Massachusetts.

Although not currently in use, community public water supply wells are located less than 1
mile east of the Site in Tewksbury. The is-mile-radius Interim Wellhead Protection Area (IWPA)
for one of the Tewksbury wells extends to within approximately 500 feet of the Site on the
northeast side. Surface water and other groundwater community public water supplies are
located at North Billerica on the Concord River, just north of the Route 3A bridge, where a
filtration plant is located. The southwestern corner of the Site is close to the mile IWPA
for the North Billerica Well. However, like the Tewksbury wells, this well is not currently
in use.

There may be private wells along Gray Street, which is east of the Shaffer Landfill section
of the Site, based on the knowledge of personnel at the Billerica Health Department. It is
not known whether any such private wells are used as sources of drinking water or for other
domestic uses.

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Geology

Bedrock underlying the Site is comprised of granite, schist, and diorite. Bedrock surface
elevations suggest the presence of a trough in the bedrock surface trending northeast from
the Old B&M Oil/Sludge Recycling Area to the Unnamed Brook, then northwest toward the
Asbestos Lagoons. Bedrock fractures were found trending north-northeast and east-west.

The overburden primarily consists of glacial drift deposits including basal and ablation till
and glacial outwash deposits. Basal till was found primarily on the southwestern portion of
the Site, and ablation till was found primarily in the western and southern portion of the
Site overlying basal till. Glacial outwash deposits were encountered throughout the Site.

Peat deposits were encountered underlying fill materials near streams, ponds, and wetlands at
the Site.

Hvdrogeology

The overburden aguifer was subdivided into shallow and deep zones to aid in determining the
potential migration pathways. Groundwater is also contained and transmitted in weathered and
fractured bedrock zones. Groundwater in both the overburden and bedrock aguifers generally
enters the Site from the southwest and flows to the northeast. Similarly, surface water flows
onto the Site from the south and flows to the northeast, where it converges with B&M Pond and
associated wetlands. Based on seepage meter, staff gauge, and mini-piezometer results, the
potential for groundwater to discharge to surface water was evident throughout most of the
Site. Vertical gradients measured throughout the site indicates groundwater movement is much
more horizontal than vertical.

Remedial Investigation Sampling Strategy

Immediate Removal Sampling. On- and off-site sampling for asbestos was conducted associated
with the immediate removal action which resulted in the cover being placed on the Asbestos
Landfill in 1984. While off-site impacts were not indicated, on-site sampling documented
significant asbestos containing material and aided in the consolidation of material prior to
capping.

The Remedial Investigation sampling program included the sampling of surface soil, subsurface
soil (test pits and borehole soil) , surface water, sediment and (shallow overburden, deep
overburden, and bedrock) throughout the Site.

Surface soils. A total of 79 surface soils including background and historical locations were
collected throughout the Site from July 22 through September 5, 1993 at locations presented
in Figure 2-12 of the September 1997 RI Report. Five samples collected over a one acre area
were composited and analyzed for volatile organic compounds (VOCs), semivolatile organic
compounds (SVOCs), pesticides/PCBs, metals, cyanide, total petroleum hydrocarbons (TPH),
total combustible organics (TCO), and moisture content.

Test Pits. Twenty seven test pits were excavated in the B&M Railroad Landfill, RSI Landfill,
B&M Shop Disposal Area, and the Old B&M Oil/Sludge Recycling Area from August 16 to 24, 1993
at locations shown in Figures 2-7 to 2-9 of the September 1997 RI Report. Soil samples were
analyzed for VOCs, SVOCs, pesticides/PCBs, metals, cyanide, and TPH. Test pit locations were
selected in potential source areas based on results of the geophysical surveys.

Soil borings. A total of 4 6 soil borings were advanced in the B&M Railroad Landfill, RSI
Landfill, B&M Shop Disposal Area, and the Old B&M Oil/Sludge Recycling Area from August 24,
to September 3, 1993 at locations shown in Figures 2-7 to 2-10 of the September 1997 RI
Report. Soil samples were analyzed for VOCs, SVOCs, pesticides/ PCBs, metals, cyanide, TPH,
TCO, and grain size. Boring locations were selected in potential source areas based on
results of the geophysical surveys.

Surface water and Sediment Sampling. Forty six surface water and sediment samples were
collected across the Site and study area during periods of high and low flow from June 9

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through 22, 1993 and September 14 to 22, 1993 as shown in Figure 2-6 of the September 1997 RI
Report. Surface water samples were analyzed for VOCs, SVOCs, pesticides/PCBs, metals,
cyanide, TOC, and alkalinity samples and sediment samples were analyzed for VOCs, SVOCs,
pesticide/PCBs, metals, cyanide, TPH, TCO, moisture content, and grain size.

Groundwater Samples. Fifty groundwater screening samples were collected from shallow
groundwater downgradient of suspected source areas and measured by field GC for chlorinated
and aromatic VOCs from September 27 through October 8, 1993 to assist in the location of
monitoring wells. Groundwater samples were collected from monitoring wells screened in
shallow overburden, deep overburden, and bedrock during the RI. A total of 77 monitoring
wells shown on Figure 2-13 of the September 1997 RI Report were sampled during each of two
rounds: March 28 to April 10, 1995 and July 17 to 28, 1995. The strategy included sampling
wells upgradient, downgradient, and in the vicinity of source areas in which groundwater
contamination was of concern. These areas included: the B&M Railroad Landfill, the RSI
Landfill, the B&M Shop Disposal Area, the Old B&M Oil/Sludge Recycling Area, and the
Asbestos Lagoons.

The Conceptual Site Model (CSM) for groundwater, surface water, and sediment is provided in
Figure E-l and the CSM for soil is provided in Figure E-2. The CSM is a three- dimensional
"picture" of site conditions that illustrates contaminant sources, release mechanisms,
exposure path ways, migration routes, and potential human and ecological receptors. It
documents current and potential future site conditions and shows what is known about human
and environmental exposure through contaminant release and migration to potential receptors.
The risk assessment and response action for the media at OU3 is based on this CSM.

Nature and Extent of Contamination

The distribution of contaminants by media and area of concern, as well as contaminant fate
and transport, are described in the following sections. The Asbestos Landfill has been
omitted, since analytical samples were not collected in that area during the Remedial
Investigation. (Note: Confirmatory sampling of asbestos to aid in efforts to consolidate the
landfill prior to capping, was conducted during the immediate removal in 1984).

The concentration ranges of detected compounds for samples collected by area, media and
analyte group are presented in detail in the Section 4 text and tables of the September 1997
Final RI Report. The guantity/ volume of waste by media and disposal area that need to be
addressed are presented in Table 2-12 of the 2004 Feasibility Study Report.

B&M Railroad Landfill. Similar types of organic compounds including VOCs, PAHs, phthalates,
petroleum hydrocarbons, and pesticides were detected in surface and subsurface soils, with
the highest concentrations occurring in subsurface soils. These contaminants were also
present in lower concentrations in groundwater. Heavy metal concentrations in surface and
subsurface soils were higher than background soils. For soils, the southeastern half of the
landfill was more contaminated with both organic compounds and metals. High concentrations of
PCBs in subsurface soils suggest that PCB- contaminated material, possibly oils, was disposed
of. Aromatic VOCs, PAHs and petroleum hydrocarbons are indicative of petroleum- related
products that probably include coal tar and creosote waste.

In groundwater, wells located in the vicinity of the landfill exhibited the highest
concentrations of contaminants, especially organic compounds. Aromatic and chlorinated VOCs,
PAHs, pesticides, PCBs, and elevated metal concentrations were measured in groundwater, but
were present in lower concentrations than in soil. Although no non-aqueous phase liquids
(NAPLs) were found, oily sands were observed at several depths; in conjunction with the types
of organic compounds that were detected, this suggests the presence of NAPL. Degradation of
trichloroethylene (TCE) is evidenced by the presence of its potential byproducts, including
both isomers of dichloroethylene (DCE).

RSI Landfill. Waste and fill present in the west- central portion of the landfill include
organic compounds and heavy metals, detected in subsurface soils, and pesticides, PCBs, and
phthalates, found in subsurface and surface soils. Aromatic VOCs, pesticides, and PCBs were

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detected in groundwater at low concentrations. The detection of chlorinated VOCs in
upgradient, as well as downgradient and vicinity wells, indicates that upgradient sources may
be affecting groundwater guality. The presence of elevated vinyl chloride and dichlorinated
VOCs directly downgradient of landfilled wastes and near the water table (groundwater
screening locations) are indicative of the degradation of chlorinated VOCs. Aromatic VOCs
found in a groundwater cluster near the Asbestos Landfill and the RSI Landfill may be from
the Asbestos Landfill. The basis for this statement is: these wells are located immediately
downgradient of the Asbestos Landfill, the contaminant concentrations in these wells were
consistent between sampling rounds, and concentrations of aromatic compounds at the levels
detected in these downgradient wells were not found elsewhere on-site.

B&M Locomotive Shop Disposal Areas. Heavy metals and organic compounds including pesticides,
PAHs, and petroleum hydrocarbons were detected in surface and subsurface soils in both areas,
where waste or fill material was found. A few organic compounds (including one VOC, a few
pesticides, and one PCB Aroclor) and heavy metals were detected in groundwater in the
downgradient and vicinity wells. The detection of organic compounds and some heavy metals in
the upgradient cluster indicate that other sources may be present in the vicinity. Mercury
and copper were the only detected metals that were not found in the upgradient wells.

Old B&M Oil/Sludge Recycling Area. Two areas of oil/sludge, located on the northern and
southern edges of the area, were found to extend beyond the Penn Culvert fence perimeter,
with one area extending onto MBTA property. The predominant types of organic compounds found
were consistent with the oil/sludge reportedly disposed of in these areas. Contaminants
detected in surface and subsurface soils consist primarily of PAHs, long- chain alkanes, and
petroleum hydrocarbons. Numerous pesticides and PCBs were detected in the northern area, and
heavy metals were measured in both areas. Although aromatic VOCs, PAHs, and petroleum
hydrocarbons were generally not present in groundwater, chlorinated VOCs and heavy metals
were detected. Heavy metals, which were detected primarily in shallow overburden groundwater,
include arsenic, chromium, cobalt, lead, mercury, nickel, and zinc. Petroleum hydrocarbons
were measured in one well, and several inches of floating product were observed in one
piezometer in the southern oil/sludge area.

Contaminated Soils Area. Since surface soil contamination was of key concern in this area,
this was the only medium sampled. However, groundwater monitoring wells associated with other
AOCs are also downgradient of the Contaminated Soils Area. Organic compounds, including
PAHs, petroleum hydrocarbons, and pesticides, were measured in surface soils in localized
areas. Lead and manganese were the heavy metals that were detected most often and in the
highest concentrations. Cyanide was detected in a localized area along the southeastern
boundary.

Asbestos Lagoons. Sediment soil samples were collected at these lagoons during the RI.
Groundwater contaminants included VOCs (primarily aromatic and chlorinated VOCs), PAHs,

PCBs and pesticides. Several of the chlorinated VOCs (perchloroethylene (PCE),
trichloroethane (TCA) , and dichloroethane (DCA)) and heavy metals (arsenic, cobalt, lead, and
zinc) were detected in the shallow overburden, deep overburden and bedrock flow zones. The
types of contaminants found were similar to those detected in the 1980s during investigations
related to the Johns-Manville stormwater drainage system. Detected heavy metals and organic
compounds were primarily found in downgradient wells near the lagoons.

Contaminant Fate and Transport

In the following sections, contaminant fate and transport are described by area of concern.
In general contamination at the Site consists of low level threat wastes.

B&M Railroad Landfill. Since organic materials are prevalent in soils, PCBs, PAHs, and
pesticides are not expected to migrate appreciably in the unsaturated zone. It is also
expected that the mobility of metals will be limited due to adsorption and other processes in
soil. A migration pathway for VOCs in the unsaturated zone may be via vapor phase, since VOCs
were detected more often at the water table (in groundwater screening locations) than with
depth below it.

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With the exception of VOCs, most contaminants found in the saturated zone soils (pesticides,
PCBs, PAHs, phthalates, and heavy metals) will not migrate significantly in the dissolved
phase as evidenced by the groundwater guality in wells across from B&M Pond. The presence of
PCBs and pesticides below the limits of the waste indicate that residual or pooled dense non-
aqueous phase liquids (DNAPL) may be present, although none was observed. Groundwater levels
and analytical data indicate that groundwater is migrating vertically. Contaminants in the
dissolved phase may migrate from the landfill to the B&M Pond to the east and the Middlesex
Canal to the south as evidenced by downgradient contamination.

Measured vertical gradients indicate groundwater discharges to the Middlesex Canal and B&M
Pond. Contaminants are more prevalent in sediment than surface water due to attenuation
processes. Contaminants detected in sediments were also found in upgradient reaches. PCBs in
the Middlesex Canal may be a result of historic discharges from the stormwater drainage
system at the former Johns-Mansville facility.

RSI Landfill. Borings indicate that wastes exist above and below the water table. The absence
of a low-permeability cover allows for contaminant transport from the unsaturated to the
saturated zone. Similar to the B&M Railroad landfill, relatively elevated concentrations of
PCBs, PAHs, and phthalates are found in the unsaturated zone. These compounds in percolating
water may be highly attenuated through adsorption to organic matter in the soils. Although
these compounds may also migrate vertically in DNAPL form, no DNAPL was observed. Most metals
are fairly immobile due to adsorption and low solubility; however, leaching is possible.
Chlorinated VOCs (DCE and vinyl chloride) detected in groundwater screening samples indicate
the partitioning of these compounds to the vapor phase. Therefore, vapor phase movement may
be a prominent transport mechanism at the water table.

Most organic compounds with the exception of VOCs often do not migrate significantly in the
dissolved phase. Pesticides, PAHs, phthalates, and PCBs adsorb to organic matter in soils.
However, due to the presence of sandy soils with less organic material, contaminant transport
is of greater concern. Based on the direction of groundwater flow, contaminants in the
dissolved phase would likely migrate toward the Middlesex Canal to the northeast and the
unnamed brook to the southeast. Although vertical gradients are low, the existence of shallow
bedrock facilitates contaminant transport from the overburden to bedrock. The presence of
pesticides and PCBs in the deep overburden and bedrock groundwater indicates the potential
for localized DNAPL pools; however, this was not confirmed during the field activities.

B&M Locomotive Shop Disposal Areas. Borings indicate that wastes exist above and below
the water table. PAHs were found in the highest concentrations, especially in subsurface
soils, while pesticides, PCBs, VOCs, and petroleum hydrocarbons were found at lower
concentrations. The absence of a low-permeability cover facilitates contaminant transport
from the unsaturated to the saturated zone. However, pesticides, PCBs and PAHs in percolating
water may be highly attenuated through adsorption to organic matter in the soils.

Aromatic VOCs, PAHs, and petroleum hydrocarbons were notably absent in groundwater, although
they were prevalent in subsurface soils. The absence of PAHs may be attributed to adsorption
to soils. The absence of aromatic VOCs and petroleum hydrocarbons may be due to the placement
of well screens below the water table. The potential for biodegradation of chlorinated
compounds is evidenced by the existence of the breakdown products DCE and vinyl chloride near
the water table. Based on the direction of groundwater flow, contaminants in the dissolved
phase from both areas will migrate toward the northeast with potential downgradient discharge
to the unnamed brook. Although vertical hydraulic gradients tend to be downward, there is no
evidence that vertical migration of contaminants has occurred at this point.

Old B&M Oil/Sludge Recycling Area. Subsurface soils exhibited the highest concentrations of
contaminants including aromatic VOCs (BTEX compounds - benzene, toluene, ethylbenzene,
xylenes), PAHs, petroleum hydrocarbons, and metals. Although some of the area is covered with
asphalt, the absence of a low-permeability cover may facilitate contaminant transport to the
saturated zone (especially VOCs). However, PAHs, pesticides, and metals will tend to adsorb
to the organic matter (peat) prevalent in soils in this area. Based on observations of free
product in the area and the occurrence of PAHs and petroleum hydrocarbons, light non-aqueous

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phase liquids (LNAPL) in residual or mobile form may be widespread. It was not detected in
wells most likely because they are screened as much as 1 foot or more below the water table.
The presence of high concentrations of PAHs may also indicate the presence of DNAPL.

Contaminated Soils Area. Soil contamination is likely the result of surface discharge from
various work-related activities and is probably limited to surface soils. Evidence of free
product spills included visual observation of oil-soaked or stained soils. Elevated levels of
lead were detected throughout the area. Since lead is relatively insoluble and strongly
adsorbed, significant migration in the unsaturated zone is not expected.

Pesticides, PAHs, VOCs, and heavy metals (especially lead) were measured in sediment at
nearby water bodies. Overland flow runoff is the most likely transport pathway for this area.
Based on drainage patterns to the northeast, this area could be contributing to contaminants
in surface water and sediments in the Middlesex Canal, the unnamed brook, wetlands and ponds
in the vicinity, as well as drainage ditches that lead to these water bodies.

Asbestos Lagoons. The limits of waste relative to the water table were not defined, since
drilling was not conducted within the lagoons. The predominant types of compounds found in
groundwater include pesticides and PAHs, which are likely to be strongly adsorbed to soils.
Concentrations of several metals were elevated, with calcium levels most elevated. This was
to be expected due to the plasterboard materials that were disposed here.

Several metals, a few chlorinated VOCs, and PAHs were most prevalent in the deep overburden
and bedrock groundwater. PCBs were detected in a shallow well adjacent to catch basins. Past
wastewater discharges, stormwater drain leakages, and mounding caused by rainfall likely
induced vertical migration of contaminants beneath the area. Low concentrations of pesticides
in groundwater may be the result of percolating rainwater. Chlorinated VOCs are likely the
most mobile contaminants. Groundwater flow is divided, with flow to the northwest toward
Middlesex Canal and to the northeast. Vertical gradients tend to be downward from shallow to
deep overburden near the lagoons, but upward from bedrock to shallow overburden at the
downgradient wells.

Summary of Exposure Pathways and Receptors

Human Health. Surface soil exposures to human receptors were evaluated for five AOCs: B&M
Railroad Landfill, RSI Landfill, B&M Locomotive Shop Disposal Areas, Old B&M Oil/Sludge
Recycling Area, and Contaminated Soils Area. Subsurface soil exposures at the Old B&M
Oil/Sludge Recycling Area were also addressed.

Human receptors were identified as current and future adult workers based on the current
active industrial use of the Site. It was assumed that future land use will remain the same
as current land use. Worker exposures to soil were assumed to occur. Because the Site is not
completely secure, child/teenage trespassers were assumed to gain access to the Site
currently and in the future. Trespassers were assumed to contact on-site soil along with
sediment and surface water in the wetland and ponds associated with the Site. Area residents
are not currently using groundwater impacted by the Site for potable purposes. However,
residential groundwater use was evaluated as a future exposure medium. The following
summarizes the exposure pathways evaluated for each of the identified receptor populations:

•	Site adult worker, current and future

Ingestion pathways: surface soil
Dermal contact pathways: surface soil

•	Site child/teenage trespasser, current and future

Ingestion pathways: surface soil,

Dermal contact pathways: surface soil,

Trespassers and workers potentially may be chronically exposed to asbestos fibers released
from the Asbestos Lagoons as well as at the Asbestos Landfill, if the landfill cap is not
maintained.

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Effects on the lung resulting from inhalation of asbestos fibers is the major asbestos health
concern. Chronic inhalation exposure to asbestos can result in a lung disease termed
asbestosis which is characterized by shortness of breath and cough. Asbestosis may lead to
severe impairment of respiratory function and ultimately death. Other effects include
scarring of tissue surrounding the lungs, pulmonary hypertension and immunological effects.
Inhalation of asbestos fibers can cause lung cancer and mesothelioma (a rare cancer of the
thin membranes lining the abdominal cavity and surrounding internal organs).

Asbestos fibers in the Lagoons, have the potential to become airborne, posing a human health
threat via the inhalation pathway. Disposal of asbestos in these lagoons as well as
subseguent partial removal has been documented. Furthermore, sampling of material in the
lagoons confirms the presence of asbestos.

Under the National Emissions Standards for Hazardous Air Pollutants (NESHAP), in 1973 EPA
defined asbestos containing material as material containing 1% asbestos or greater based
detection limits available at the time. More recent data demonstrates that materials
containing less than 1% asbestos may also pose a potential health risk in some circumstances.

As discussed earlier, a random soil sampling effort was conducted as part of the Phase 1A RI
to analyze for asbestos. Asbestos was detected at a number of locations outside of the BNZ
Materials property. These sample results outside BNZ Materials property, are sporadic in
nature, and with two exceptions, the results are either non-detect for asbestos, or contain
less than 1% asbestos. These results do not suggest a pattern of asbestos contamination
outside of the BNZ Materials property indicative of a release to be remediated.

Ecological. Soil exposures were evaluated for ecological receptor populations within seven
distinct areas of concern (AOCs): Asbestos Lagoons, Old B&M Oil/Sludge Recycling Area,
Contaminated Soils Area, B&M Railroad Landfill, B&M Locomotive Shop Disposal Areas, RSI
Landfill, and site-wide surface water and sediment. The risk posed by exposure to
contaminants in surface water and sediment will be further addressed by Operable Unit 4 of
the Iron Horse Park Superfund Site. Two AOCs including the Asbestos Lagoons and the site-wide
surface water and sediment focused on exposures to aguatic and semi-aguatic species to
surface water and sediments. Conseguently, this section focuses on the ecological exposure to
soils at five AOCs: Old B&M Oil/Sludge Recycling Area, Contaminated Soils Area, B&M Railroad
Landfill, B&M Locomotive Shop Disposal Areas, and RSI Landfill.

Terrestrial receptors species and exposure pathways evaluated included:

•	earthworm (soil invertebrates)

Dermal absorption

Ingestion of contaminated soil, detritus, and animal matter

•	short tail shrew (small terrestrial mammals)

Consumption of soil invertebrates

Incidental ingestion of soil and surface water

Ingestion of surface water

The Contaminated Soils Area and the Old B&M Oil/Sludge Recycling Area were not guantitatively
evaluated because a gualitative evaluation indicated the lack of significant receptor
populations. Habitat in both of these areas is limited, as is the total area over which
significant populations of earthworms and other soil invertebrate would be expected. Without
a substantial prey base, shrews would not be expected to use these areas extensively.

It should be noted that contaminants associated with the Contaminated Soils Area and the Old
B&M Oil/Sludge Recycling Area that could be transported were included in the sediment and
surface water sampling program for adjacent and downgradient areas. Impacts to ecological
receptor populations exposed to surface water and sediment contamination will be addressed as
part of Iron Horse Park Operable Unit 4.

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F. CURRENT AND POTENTIAL FUTURE SITE AND RESOURCE USES

The land associated with 0U3 is used for industrial purposes, with no residential use. The
Middlesex Canal is essentially impassable for recreation or economic purposes, although it is
a historic structure that someday could be developed as parkland or utilized as a resource in
some other manner. Some parts of 0U3 are fenced, but most is accessible to passers-by. The
area within one mile of 0U3 boundary is primarily forest and residential, consisting
primarily of single family residential properties.

The town zoning map indicates that aside from a small section of commercially zoned land
toward the southwest corner, the Iron Horse Park Site is zoned industrial. Consultation with
the Billerica Planning Board and MADEP indicated that future land use is expected to remain
industrial. The industrial zoning extends beyond the boundary of Iron Horse Park. In
addition, the immediate surrounding area consists of rural residence and neighborhood
residence zoning categories with a few small areas of general business zoning.

• Ground/Surface Water Uses:

Massachusetts GIS has mapped water related resources in Massachusetts, including in the area
around the Iron Horse Park Site (Figure F-l). Part of the Site overlies what is classified as
a medium-yield aguifer. Due to the presence of a railyard over a portion of this aguifer, the
Massachusetts Department of Environmental Protection reclassified most of this aguifer as a
non-potential drinking water source and considered of low use and value. However, the portion
of the aguifer without the railyard remains a potential drinking water source, and is
considered of medium use and value. The remainder of the Site overlies what is expected to be
a low- yield aguifer. No public water supply sources are located within the medium-yield
aguifer on the Site.

The current use(s) of the surface water at the Site and surrounding areas is as a warm water
fishery and for contact recreation. On Site contact recreation would primarily be by
trespassers.

Community and stakeholder input was sought and incorporated through active outreach with the
Billerica Planning Board.

G. SUMMARY OF SITE RISKS

A baseline risk assessment was performed to estimate the probability and magnitude of
potential adverse human health and environmental effects from exposure to contaminants
associated with the Site assuming no remedial action was taken. It provides the basis for
taking action and identifies the contaminants and exposure pathways that need to be addressed
by the remedial action. The human health risk assessment followed a four step process: 1)
hazard identification, which identified those hazardous substances which, given the specifics
of the site were of significant concern; 2) exposure assessment, which identified actual or
potential exposure pathways, characterized the potentially exposed populations, and
determined the extent of possible exposure; 3) toxicity assessment, which considered the
types and magnitude of adverse health effects associated with exposure to hazardous
substances, and 4) risk characterization and uncertainty analysis, which integrated the three
earlier steps to summarize the potential and actual risks posed by hazardous substances at
the site, including carcinogenic and non- carcinogenic risks and a discussion of the
uncertainty in the risk estimates. A summary of those aspects of the human health risk
assessment which support the need for remedial action is discussed below followed by a
summary of the environmental risk assessment.

1. Human Health Risk Assessment

Fifty of the more than 110 chemicals detected at the site were selected for evaluation in the
human health risk assessment as chemicals of potential concern. The chemicals of potential
concern were selected to represent potential site related hazards based on toxicity,

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concentration, frequency of detection, and mobility and persistence in the environment and
can be found in Tables 6-11 through 6-14 of the RI and in Table 2 of Appendix I to the FS.
From this, a subset of the chemicals were identified in the Feasibility Study as presenting a
significant current or future risk and are referred to as the chemicals of concern in this
ROD and summarized in Tables G-l through G-3 for surface soil, surface soil/subsurface soil,
and groundwater, respectively. These tables contain the exposure point concentrations used to
evaluate the reasonable maximum exposure (RME) scenario in the baseline risk assessment for
the chemicals of concern. Estimates of average or central tendency exposure concentrations
for the chemicals of concern and all chemicals of potential concern can be found in Tables
6-15 through 6-18 of the RI and in Table 3 of Appendix I to the FS.

Potential human health effects associated with exposure to the chemicals of potential concern
were estimated quantitatively or qualitatively through the development of several
hypothetical exposure pathways. These pathways were developed to reflect the potential for
exposure to hazardous substances based on the present uses, potential future uses, and
location of the Site. The Site is an active industrial area. Fencing and signs discourage
access to the Site by nonnworkers. However, it is possible for trespassers to enter the
Site. Land use in the area surrounding the Site is primarily residential. Future use of the
Site is expected to remain industrial. However, because of nearby residential areas, future
residential use of groundwater impacted by the Site was considered. The following is a brief
summary of just the exposure pathways that were found to present a significant risk. A more
thorough description of all exposure pathways evaluated in the risk assessment including
estimates for an average exposure scenario, can be found in Section 6.0 of the RI and in
Appendix I of the FS. For lead contaminated soil, a lead model was used to evaluate potential
risks to workers of child-bearing age. For contaminated groundwater, ingestion of 2 1/day,
350 days/year for 30 yrs was presumed for an adult.

Excess lifetime cancer risks were determined for each exposure pathway by multiplying a daily
intake level with the chemical specific cancer potency factor. Cancer potency factors have
been developed by EPA from epidemiological or animal studies to reflect a conservative "upper
bound" of the risk posed by potentially carcinogenic compounds. That is, the true risk is
unlikely to be greater than the risk predicted. The resulting risk estimates are expressed in
scientific notation as a probability (e.g. 1 x 10-6 for 1/1,000,000) and indicate (using this
example), that an average individual is not likely to have greater that a one in a million
chance of developing cancer over 70 years as a result of site-related exposure (as defined)
to the compound at the stated concentration. All risks estimated represent an "excess
lifetime cancer risk" - or the additional cancer risk on top of that which we all face from
other causes such as cigarette smoke or exposure to ultraviolet radiation from the sun. The
chance of an individual developing cancer from all other (non-site related) causes has been
estimated to be as high as one in three. EPA's generally acceptable risk range for site
related exposure is 10-4 to 10-6. Current EPA practice considers carcinogenic risks to be
additive when assessing exposure to a mixture of hazardous substances. A summary of the
cancer toxicity data relevant to the chemicals of concern is presented in Table G-4.

In assessing the potential for adverse effects other than cancer, a hazard quotient (HQ) is
calculated by dividing the daily intake level by the reference dose (RfD) or other suitable
benchmark. Reference doses have been developed by EPA and they represent a level to which an
individual may be exposed that is not expected to result in any deleterious effect. RfDs are
derived from epidemiological or animal studies and incorporate uncertainty factors to help
ensure that adverse health effects will not occur. A HQ <1 indicates that a receptor's dose
of a single contaminant is less than the RfD, and that toxic noncarcinogenic effects from
that chemical are unlikely. The Hazard Index (HI) is generated by adding the HQs for all
chemical(s) of concern that affect the same target organ (e.g., liver) within or across those
media to which the same individual may reasonably be exposed. A HI <1 indicates that toxic
noncarcinogenic effects are unlikely. A summary of the noncarcinogenic toxicity data relevant
to the chemicals of concern is presented in Table G-5.

Tables G-6 and G-l, respectively, depict the carcinogenic and non-carcinogenic risk summary
for the chemicals of concern in groundwater evaluated to reflect potential future residential
groundwater ingestion corresponding to the reasonable maximum exposure (RME) scenario.

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Groundwater was evaluated by flow zone (i.e., shallow overburden, deep overburden, and
bedrock) for on-site Areas of Concern (AOCs). Only those exposure pathways deemed relevant
to the source control remedy being proposed are presented in this ROD. Readers are referred
to Section 6.0 of the RI and Appendix I of the FS for a more comprehensive risk summary of
all exposure pathways evaluated for all chemicals of potential concern and for estimates of
the central tendency risk.

Compounds determined to be significant risk contributors for groundwater overall include
benzene, 1,2-dichloroethane, 1,1-dichloroethene, 1,1,2,2-tetrachloroethane,
tetrachloroethene, trichloroethene, bis(2-ethylhexyl) phthalate, aldrin, PCBs, arsenic,
beryllium, manganese, and thallium. MCL exceedances were noted for the following compounds,
listed by AOC:

•	B&M Railroad Landfill: 1,2-dichloroethane, trichloroethene, and lead;

•	RSI Landfill: benzene, trichloroethene, arsenic, lead, and thallium;

•	B& M Locomotive Shop Disposal Areas: no exceedances noted;

•	Old B&M Oil/Sludge Recycling Area: 1,2-dichloroethane, 1,1-dichloroethene,
trichloroethene, bis(2-ethylhexyl) phthalate, arsenic, and lead; and

•	Asbestos Lagoons: 1,2-dichloroethane, lead, and nickel.

The Adult Lead Model was used to evaluate the hazard potential posed by exposure of the
developing fetus as the most sensitive receptor group. A geometric standard deviation (GSD)
in blood lead concentration of 1.8 was used in the model. A GSD of 1.8 is typical of
populations in which the factors that may affect blood lead concentrations are less
heterogeneous than other populations in the United States. A typical blood lead concentration
in the absence of site exposures was assumed to be 1.7 ng/dL, which is at the lower end of
the plausible range observed in the National Health and Nutrition Examination Survey (NHANES
III) conducted from 1988 to 1991. A representative intake rate of soil was assumed to be 50
mg/day based on occupational, indoor exposures to dust from outdoor soil. The absolute
gastrointestinal absorption fraction for ingested lead in soil and soil-derived dust was
assumed to be 0.12. The freguency of exposure was assumed to be 219 days per year. The
outcome of the model revealed that greater than 5% of an exposed population was predicted to
have blood lead levels greater than 10 ng/dL based on surface soil lead levels at the
Contaminated Soil Area and the B&M Locomotive Shop Disposal Area, and on surface/subsurface
soil lead levels combined at the Old B&M Oil-Sludge Recycling Area. It is EPA's goal to
protect 95% of the sensitive population against blood lead levels in excess of 10 ng/dL
blood. A lead concentration of 1,736 mg/kg in surface soil at the Contaminated Soil Area and
the B&M Locomotive Shop Disposal Area, and in surface/subsurface soil lead levels combined at
the Old B&M Oil-Sludge Recycling Area is considered protective of 95% of the sensitive
population.

There are uncertainties that may affect the final estimates of human health risk at this
Site. One assumption in the risk assessment was that the concentrations of chemicals would
remain constant over time. This assumption may overestimate risks, depending on the degree of
chemical degradation or transport to other media. Conversely, biodegradation of chemicals to
more toxic chemicals was also not considered. RME risks are conservative since estimated
risks are based on upper-bound exposure assumptions. Actual risks for some individuals within
an exposed population may vary from those predicted depending upon their actual intake rates
(e.g., drinking water ingestion rates) or body weights. Therefore, exposures and estimated
risks are likely to be overestimated.

As discussed in Section E, above, trespassers and workers potentially may be chronically
exposed to asbestos fibers released from the Asbestos Lagoons and the Asbestos Landfill.

Asbestos fibers in the Lagoons and the Asbestos Landfill, have the potential to become
airborne, posing a human health threat via the inhalation pathway. Disposal of asbestos in
the lagoons as well as subseguent partial removal has been documented. Furthermore, sampling
of material in the lagoons confirms the presence of asbestos.

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Under the National Emissions Standards for Hazardous Air Pollutants (NESHAP), in 1973 EPA
defined asbestos containing material as material containing 1% asbestos or greater based
detection limits available at the time. More recent data demonstrates that materials
containing less than 1% asbestos may also pose a potential health risk in some circumstances.

2. Ecological Risk Assessment

The ERA evaluated the potential for contaminants in soil, surface water, and sediment to
impact ecological receptor populations within seven distinct areas of concern (AOCs):

Asbestos Lagoons, Old B&M Oil/Sludge Recycling Area, Contaminated Soils Area, B&M Railroad
Landfill, B&M Locomotive Shop Disposal Areas, RSI Landfill, and site-wide surface water and
sediment. The risk posed by exposure contaminants in surface water and sediment, will be
further addressed in IHP 0U4. Two AOCs, including the Asbestos Lagoons and the site-wide
surface water and sediment data group, focused on exposures to aguatic and semi-aguatic
species to surface water and sediments. Conseguently, this ROD focuses on the ecological risk
from exposure to soils, at five AOCs: Old B&M Oil/Sludge Recycling Area, Contaminated Soils
Area, B&M Railroad Landfill, B&M Locomotive Shop Disposal Areas, and RSI Landfill.

Based on the ERA, it was determined that two of the AOCs, the Old B&M Oil/Sludge Recycling
Area and Contaminated Soils Area, are unlikely to provide suitable habitat for terrestrial
receptors, including soil invertebrates and terrestrial mammals, due primarily to the
physical alteration of the habitats from industrial activities. As a result, additional
evaluation of ecological risk within these two AOCs was not necessary since risk associated
with potential exposure to site-related contaminants did not represent a complete exposure
pathway for any receptor group. Therefore, evaluations associated with Old B&M Oil/Sludge
Recycling Area and Contaminated Soils Area, are not included in the ERA and are not included
in the ROD.

Identification of Chemicals of Concern

Contaminants of concern (COCs) were identified using an effects-based screening involving the
comparison of maximum contaminant concentrations to ecological benchmarks for soils within
each of the three AOCs. Data used to identify COCs are summarized below in Table G-8 (B&M
Railroad Landfill), Table G-9 (RSI Landfill), and Table G-10 (B&M Locomotive Shop Disposal
Areas) .

Exposure Assessment

The upland habitats of the B&M Railroad Landfill, B&M Locomotive Shop Disposal Areas, and RSI
Landfill provide habitat for a variety of terrestrial receptors, including soil invertebrates
and small mammals. Terrestrial receptors may accumulate COCs through consumption of
contaminated prey and incidental soil ingestion. Earthworms have significant exposure to soil
contaminants both through direct dermal contact and through ingestion of large guantities of
soil and detritus. Soil invertebrates such as earthworms serve as a prey base for other
predators. Birds, as well as small terrestrial mammals like the northern short-tail shrew
(Blarina brevicauda) may consume earthworms as a large portion of their diets. Small mammals
such as shrews may serve as a significant food base for carnivorous wildlife. Exposure
pathways, assessment endpoints, and measurement endpoints are summarized below in Table
ECO-1.

Risk to soil invertebrates was evaluated by comparing soil concentrations to soil ecological
benchmarks. Exposure point concentrations consisted of the mean and maximum soil
concentration (0-1 ft depth interval) for each COC. Earthworm toxicity reference values
(TRVs) consisted of toxicological benchmarks developed for earthworms, as well as ecological
screening values for soils, and maximum allowable contaminant levels derived for the
protection of the environment.

Short-tailed shrew, representing small terrestrial mammals, were selected as the assessment
population to evaluate risks associated with exposure to COCs in each AOC. Potential risk
from soil COCs to assessment populations was estimated using dietary exposure models. Because
site-specific tissue data were not available, dietary doses were modeled from soil

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concentrations. To assist in exposure estimation for small terrestrial mammals, COC
concentrations in prey (earthworms) were modeled directly from COC concentrations in soil.
Exposure point concentrations consisted of the mean and maximum soil concentration (0-1 ft
depth interval) for each COC, and modeled earthworm tissue concentrations based on these
values.

Table ECO-1

Ecological Exposure Pathways of Concern - Surface Soil

Exposure
Medium

Sensitive
Environment
Flag
Y or N

Receptor

Endangered/
Threatened
Species Flag
Y or N

Exposure
Routes

Assessment
Endpoints

Measurement
Endpoints

Soil

N

Soil

Invertebrates

N

Ingestion and
direct contact
with chemicals
in soil.

Sustainability
(survival,
growth,
reproduction)
of local
populations of
soil

invertebrates

Compare

chemical

concentrations

in soil to

toxicity

benchmarks

which are

indicative of

potential

impairment

Soil

N

Small

terrestrial
mammals

N

Ingestion and
direct contact
with chemicals
in soil.

Sustainability
(survival,
growth,
reproduction)
of local
populations of
soil

invertebrates

Compare
modeled
exposures to
published
values which
are indicative
of potential
impairment.

Ecological Effects Assessment

Risk to soil invertebrates was evaluated by comparing COC concentrations in soil to soil
ecological benchmarks. Whether COCs exceeded lower risk thresholds or upper risk thresholds
for soil invertebrates was based on the magnitude of the exceedences of benchmark values.

Modeled dietary doses for shrew were compared to toxicity reference values (TRVs) obtained
from the literature. TRVs were predominantly selected from studies which reported
no-observed-adverse-effects-levels (NOAELs). When a suitable NOAEL was unavailable, studies
which reported lowest-observed-adverse-effects-levels (LOAELs) were used and adjusted
downward with an uncertainty factor of 10. Hazard guotients (HQs) were then calculated for
each COC using the modeled doses and NOAEL TRVs.

Based on further data evaluation following the remedial investigation, the models/endpoints
were revised. Background information on the updated calculations is presented in the FS.

Risk Characterization

The RI ecological risk assessment indicated soil COCs potentially posed a risk to populations
of both earthworms (representative of soil invertebrates) and shrews (representative of the
small mammal community) at B&M Railroad Landfill and the B&M Locomotive Shop Disposal Areas.
Risks to terrestrial receptors from exposure to soils at RSI Landfill were minimal.

Although potential risks were identified in the ERA for soil invertebrates, the confidence in
the conclusions were low, as these were based on conservative screening benchmarks.
Development of the preliminary remediation goals (PRGs) was based on shrew endpoints to
emphasize the importance of contamination in the food chain and risk to the small mammal
community. Risks were identified for exposures of shrew to high concentrations of cadmium in
soil at the B&M Railroad Landfill and to copper and lead in soils at the B&M Locomotive Shop

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Disposal Areas.

PRGs were developed to identify a soil concentration at which ecological effects are likely
to occur. The PRGs are based on a daily dose resulting in a hazard guotient (HQ) of 1.0, and
using a protective NOAEL TRV. Since food COC concentrations were estimated from soil
concentrations, the food chain models were used to back-calculate a soil concentration that
corresponds to a daily dose resulting in an HQ of 1.0. This approach assumes that
concentrations are evenly distributed throughout the site or foraging area. PRGs are
summarized below (Table ECO-2) for those COCs identified as posing risk to small terrestrial
mammals.

Table ECO-2

COC Concentrations Expected to Provide Adequate Protection of Ecological Receptors

Habitat
Type/Name

Exposure
Medium

COC

Protective
Level

Units

Basis 1

Assessment
Endpoint

B&M

Railroad
Landfill

Soil

Cadmium

15.4

mg/kg

Food chain models, NOAEL

Sustainability
(survival, growth,
reproduction) of
local populations
of small terrestrial
mammals

B&M

Locomotive
Shop

Disposal
Area

Soil

Copper

2,213

mg/kg

Food chain models, NOAEL

Sustainability
(survival, growth,
reproduction) of
local populations
of small terrestrial
mammals



Soil

Lead

CO
Ch
CO

mg/kg

Food chain models, NOAEL

Sustainability
(survival, growth,
reproduction) of
local populations
of small terrestrial
mammals

1 Exposure factors and toxicity reference values for the development of Preliminary Remediation Goals
for soils are provided in Appendix B.2 of the Feasibility Study for Iron Horse Park Superfund Site, 3rd
Operable Unit (M&E, 2004)

3. Basis for Response Action

Because the baseline human health and ecological risk assessments revealed that adult workers
and small mammals potentially exposed to compounds of concern in soil via ingestion and
contact may present an unacceptable human health risk as evaluated by the Adult Lead Model or
unacceptable ecological risk (exceedance of NOEL TRVs), actual or threatened releases of
hazardous substances from this site, if not addressed by implementing the response action
selected in this ROD, may present an imminent and substantial endangerment to public health,
welfare, or the environment. Workers and trespassers may also potentially be exposed to
released asbestos fibers via inhalation. A response action will be selected and implemented
to address risks associated with soil.

H. REMEDIATION OBJECTIVES

As stated previously, the reasonable, expected, future use for the site is industrial. The
risk assessment evaluated exposure pathways associated with site workers as well as potential
trespassers. Based on preliminary information relating to types of contaminants,
environmental media of concern, and potential exposure pathways, remedial action objectives
(RAOs) were developed to aid in the development and screening of alternatives. These RAOs
were developed to mitigate, restore and/or prevent existing and future potential threats to

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human health and the environment. The RAOs for the selected remedy for 0U3 are:

Human Health

•	Soil - Prevent ingestion of lead from soil-derived dust at the B&M Locomotive Shop
Disposal Areas, Old B&M Oil/Sludge Recycling Area, and Contaminated Soils Area that
results in estimated maternal blood levels of greater than 4.2 jlg/dL, a site-specific
level protective of a 95th percentile fetal blood lead level of 10 jlg/dL. This results
in preventing exposure to lead soil concentrations greater than 1,736 mg/kg

•	Soil - Prevent exposure to asbestos at the Asbestos Landfill.

•	Soil - Prevent exposure to asbestos at the Asbestos Lagoons.

•	Groundwater - Limit migration of contaminants in the B&M Landfill, RSI Landfill, B&M
Locomotive Shop Disposal Areas, Old B&M Oil/Sludge Recycling Area, Contaminated Soils
Area and Asbestos Lagoons into groundwater.

Ecological

•	Protect short-tailed shrews and other smalls mammals from exposure to levels of metals
associated with a HQ greater than 1 (cadmium) in soils at the B&M Railroad Landfill.

•	Protect short-tailed shrews and other smalls mammals from exposure to levels of metals
associated with a HQ greater than 1 (copper and lead) in soils at the B&M Locomotive
Shop Disposal Areas.

(Other RAOs were developed and presented in the FS. However, those related to surface water
and sediment, and management of migration of groundwater (i.e. potential ingestion) will be
addressed as part of OU4.)

I. DEVELOPMENT AND SCREENING OF ALTERNATIVES

A.	Statutory Requirements/ Response Objectives

Under its legal authorities, EPA's primary responsibility at Superfund sites is to undertake
remedial actions that are protective of human health and the environment. In addition,

Section 121 of CERCLA establishes several other statutory requirements and preferences,
including: a requirement that EPA's remedial action, when complete, must comply with all
federal and more stringent state environmental and facility siting standards, requirements,
criteria or limitations, unless a waiver is invoked; a requirement that EPA select a remedial
action that is cost-effective and that utilizes permanent solutions and alternative treatment
technologies or resource recovery technologies to the maximum extent practicable; and a
preference for remedies in which treatment which permanently and significantly reduces the
volume, toxicity or mobility of the hazardous substances is a principal element over remedies
not involving such treatment. Response alternatives were developed to be consistent with
these Congressional mandates.

B.	Technology and Alternative Development and Screening

CERCLA and the National Contingency Plan (NCP) , 40 CFR Part 300, set forth the process by
which remedial actions are evaluated and selected. In accordance with these requirements, a
range of alternatives were developed for the site.

With respect to source control, the RI/FS developed a range of alternatives in which
treatment that reduces the toxicity, mobility, or volume of the hazardous substances is a
principal element. This range included an alternative that removes or destroys hazardous
substances to the maximum extent feasible, eliminating or minimizing to the degree possible
the need for long term management. This range also included alternatives that treat the
principal threats posed by the site but vary in the degree of treatment employed and the
quantities and characteristics of the treatment residuals and untreated waste that must be

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managed; alternative(s) that involve little or no treatment but provide protection through
engineering or institutional controls; and a no action alternative at each Area of Concern.

As discussed in Section 2 of the FS, soil and groundwater treatment technology options were
identified, assessed and screened based on implementability, effectiveness, and cost. These
technologies were combined into source control (SC) and management of migration (MM)
alternatives for each Area of Concern. Section 4 of the FS presented the remedial
alternatives developed by combining the technologies identified in the previous screening
process in the categories identified in Section 300.430(e)(3) of the NCP, as well as by
combining the technologies for each Area of Concern in to Site Wide remedial alternatives.
The purpose of the initial screening was to narrow the number of potential remedial actions
for further detailed analysis while preserving a range of options. By this process, EPA
initially developed 72 Site Wide remedial alternatives which contained source control and
management of migration measures. Of these 72 alternatives EPA retained 15 alternatives for
detailed analysis. Each alternative was then evaluated in detail in Section(s) 5 of the FS.

As discussed above in Section D. of this ROD, during the alternatives analysis development
process of the FS, groundwater modeling demonstrated that groundwater cleanup alternatives
being considered would not be effective in achieving RAOs in a reasonable time period.

Because of this, the selection of a remedy for groundwater was deferred to OU4. A new
section, Section 7, was developed to conduct the comparative analysis process for source
control alternatives by Area of Concern. As discussed earlier, each Area of Concern tends to
be distinct with regard to source control issues (i.e. contamination and risk). Section 7
evaluates the source control alternatives for each Area of Concern separately.

J. DESCRIPTION OF ALTERNATIVES

This Section provides a narrative summary of each source control and management of
migration alternative evaluated.

Source Control Alternatives Analyzed

The source control alternatives analyzed for the Site discussed by Area of Concern are
summarized below. A more complete, detailed presentation of each alternative is found in
Section 7 of the FS.

B&M RAIIiROAD LANDFILL

Table 7-1 presents a summary of the primary evaluation factors and a comparative assessment
of the technologies/process options evaluated for AOC #1 , B&M Railroad Landfill which
encompasses 12.4 acres. Table L-8 presents a summary of the ARARs associated with this AOC.
The media of concern was soil and source control of contaminants in the landfill to protect
groundwater. These technologies/process options for remediation of soil include:

•	No Action

-	Reevaluate taking no action at a minimum once every 5 years as part of the 5-year
review process for the entire Site

•	Institutional Action n

-	Institutional actions consisting of access restrictions (i.e., land use
restrictions, fencing and security measures)

-	Monitoring of soil and groundwater;

•	InSitu-1 - Monitored Natural Attenuation

-	In-situ remedy of monitored natural attenuation

-	Institutional actions consisting of access restrictions (i.e., land use
restrictions, fencing and security measures)

-	monitoring of soil and groundwater;

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•	Source Control-1 - Capping

-	Excavation of landfill material from the edge of the wetland, to minimize impacts
on the wetland

-	Construction of double-barrier (EPA Region 1, Alternative CERCLA) landfill cap

-	Maintenance of cap

-	Institutional actions consisting of access restrictions (i.e., land use
restrictions, fencing and security measures)

-	Restoring wetlands impacted by the cleanup

-	Monitoring of groundwater to assess the protectiveness of the cap;

Table 7-3 presents a summary of the primary evaluation factors and a comparative assessment
of the technologies/process options evaluated for AOC #2, RSI Landfill which encompasses 2.5
acres. Table L-9 presents a summary of the ARARs associated with this AOC. Human health
and ecological risk limits were not exceeded at this AOC for soil, but contaminants in the
soil have the potential to migrate into groundwater. Therefore, single-barrier capping (SC-1)
as part of source control for groundwater has been established as a technology/ process
option for remediation in this area.

•	No Action

-	Reevaluate taking no action at a minimum once every 5 years as part of the 5- year
review process for the entire Site

•	Source Control-1 - Capping

-	Construction of single-barrier (Subtitle D - Solid Waste) landfill cap

-	Maintenance of cap

-	Institutional actions consisting of access restrictions (i.e., land use
restrictions, fencing and security measures)

-	Monitoring of groundwater to assess the protectiveness of the cap;

B&M LOCOMOTIVE SHOP DISPOSAL AREAS

Table 7-5 presents a summary of the primary evaluation factors and a comparative assessment
of the technologies/ process options evaluated for AOC # , B&M Locomotive Shop Disposal Areas
which together encompass 4.7 acres. Table L-10 presents a summary of the ARARs associated
with this AOC. The media of concern was soil and source control of contaminants in the
disposal area to protect groundwater. These technologies/process options for remediation of
soil include:

•	No Action

-	Reevaluate taking no action at a minimum once every 5 years as part of the 5-year
review process for the entire Site

•	Institutional Action -

-	Institutional actions consisting of access restrictions (i.e., land use
restrictions, fencing and security measures)

-	Monitoring;

•	InSitu-1 - Monitored Natural Attenuation

-	In-situ remedy of monitored natural attenuation

-	Institutional actions consisting of access restrictions (i.e., land use
restrictions, fencing and security measures)

-	Monitoring of groundwater

•	Source Control-1 - Capping

-	Construction of single- barrier (Subtitle D - Solid Waste) landfill cap

-	Maintenance of cap

-	Institutional actions consisting of access restrictions (i.e., land use
restrictions, fencing and security measures)

-	Monitoring of groundwater to assess the protectiveness of the cap

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Source Control-2 On-Site Disposal

- Excavation of soil/waste and placement under caps at other on-site AOCs;

•	OnSite-1 - Solidification/Stabilization

-	Excavation of soil/ waste to local staging area

-	Remove debris and large(>3/4 inch) stones for disposal under landfill cap at B&M
or RSI Landfill

-	Mix excavated material with stabilizing additives

-	Place stabilized material as backfill (depending on what additives are used,
pending predesign treatability studies, it is possible that mixing/treatment with
asphalt emulsion may be feasible. In that event, treated material may be suitable
for a paving sub-grade layer

-	Institutional actions consisting of access restrictions (i.e., land use
restrictions, fencing and security measures)

-	Monitoring of groundwater to assess the protectiveness of the treatment

•	OnSite-2 - Soil Washing/Chemical Extraction

-	Excavation of soil/waste to local staging area

-	Remove debris and large(>3/4 inch) stones for disposal under landfill cap at B&M
or RSI Landfill

-	Soils are rinsed of fine material(<2mm) and returned for placement as backfill

-	Fines are mixed with additives (pending pre-design treatability studies) to remove
site contaminants

-	Clean fines are returned as backfill

-	Sludge is dewatered prior to disposal

-	Treated water is discharged to groundwater via injection wells

-	Institutional actions consisting of access restrictions (i.e., land use
restrictions, fencing and security measures)

-	Monitoring of groundwater to assess the protectiveness of the treatment

OLD B&M OIL/SLUDGE RECYCLING AREA

Table 7-7 presents a summary of the primary evaluation factors and a comparative assessment
of the technologies/process options evaluated for AOC # , Old B&M Oil/Sludge Recycling Area
which encompasses 7 acres. Table L-ll presents a summary of the ARARs associated with this
AOC. The media of concern was soil and source control of contaminants in the soil to prevent
migration into groundwater. These technologies/ process options for remediation of soil
include:

•	No Action

-	Reevaluate taking no action at a minimum once every 5 years as part of the 5-year
review process for the entire Site

•	Institutional Action -

-	Institutional actions consisting of access restrictions (i.e., land use
restrictions, fencing and security measures)

-	Monitoring;

•	InSitu-1 - Monitored Natural Attenuation

-	In-situ remedy of monitored natural attenuation

-	Institutional actions consisting of access restrictions (i.e., land use
restrictions, fencing and security measures)

-	Monitoring of groundwater

•	Source Control-1- Capping

-	Construction of single-barrier asphalt cap (Subtitle D - Solid Waste standards to
prevent direct contact with contaminated soil and prevent migration of
contaminants to groundwater)

-	Institutional actions consisting of access restrictions (i.e., land use
restrictions, fencing and security measures)

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- Monitoring of groundwater to assess the protectiveness of the cap

•	Source Control-2 - On-Site Disposal

-	Excavation of soil/waste and placement under caps at other on-site AOCs;

-	Backfilling of excavated area

•	OnSite-1 - Solidification/Stabilization

-	Excavation of soil/ waste to local staging area

-	Remove debris and large(>3/4 inch) stones for disposal under landfill cap at B&M
or RSI Landfill

-	Mix excavated material with stabilizing additives

-	Place stabilized material as backfill (depending on what additives are used,
pending predesign treatability studies, it is possible that mixing/treatment with
asphalt emulsion may be feasible. In that event, treated material may be suitable
for a paving sub-grade layer

-	Institutional actions consisting of access restrictions (i.e., land use
restrictions, fencing and security measures)

-	Monitoring of groundwater to assess the protectiveness of the treatment

•	OnSite-2 - Soil Washing/Chemical Extraction

-	Excavation of soil/ waste to local staging area

-	Remove debris and large(>3/4 inch) stones for disposal under landfill cap at B&M
or RSI Landfill

-	Soils are rinsed of fine material(<2mm) and returned for placement as backfill

-	Fines are mixed with additives( pending pre-design treatability studies) to
remove site contaminants

-	Clean fines are returned as backfill

-	Sludge is dewatered prior to disposal

-	Treated water is discharged to groundwater via injection wells

-	Institutional actions consisting of access restrictions (i.e., land use
restrictions, fencing and security measures)

-	Monitoring of groundwater to assess the protectiveness of the treatment

CONTAMINATED SOILS AREA

Table 7-9 presents a summary of the primary evaluation factors and a comparative assessment
of the technologies/process options evaluated for AOC #5, Contaminated Soils Area which
encompasses approximately 6.7 acres. Table L-12 presents a summary of the ARARs associated
with this AOC. The media of concern was soil and source control of contaminants to prevent
migration into groundwater. These technologies/process options for remediation of soil
include:

•	No Action

-	Reevaluate taking no action at a minimum once every 5 years as part of the 5-year
review process for the entire Site

•	Institutional Action -

-	Institutional actions consisting of access restrictions (i.e., land use
restrictions, fencing and security measures)

-	Monitoring;

•	InSitu-1 - Monitored Natural Attenuation

-	In-situ remedy of monitored natural attenuation

-	Institutional actions consisting of access restrictions (i.e., land use
restrictions, fencing and security measures)

-	Monitoring of groundwater

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•	InSitu-2 - In- Situ Solidification/Stabilization

-	application of solidification/stabilization agents (agent reguirements to be
determined through pre- design analysis)

-	rototill/mixing of agents with contaminated soil

-	Institutional actions consisting of access restrictions (i.e., land use
restrictions, fencing and security measures)

-	Monitoring of groundwater to assess the protectiveness of the treatment

•	InSitu-3 - In-Situ Soil Flushing

-	Application of flushing solvents (following pre-design studies) to leach
contaminants into groundwater

-	Collection of contaminated groundwater for treatment via extraction wells

-	Institutional actions consisting of access restrictions (i.e., land use
restrictions, fencing and security measures)

-	Monitoring of groundwater to assess the protectiveness of the treatment

•	Source Control-1- Capping

-	Construction of single-barrier asphalt cap (Subtitle D - Solid Waste standards to
prevent direct contact with contaminated soil and to prevent migration of
contaminants to groundwater

-	Institutional actions consisting of access restrictions (i.e., land use
restrictions, fencing and security measures)

-	Monitoring of groundwater to assess the protectiveness of the cap

•	Off Site - Soil Excavation and Off Site Treatment/Disposal

-	Removal and disposal of existing asphalt

-	Excavation of contaminated soil

-	Transport contaminated soil to treatment facility for treatment by asphalt
batching (pending pre-design treatability studies)

-	Backfill excavated area with clean soil

•	OnSite-1 - Solidification/Stabilization

-	Excavation of soil/ waste to local staging area

-	Remove debris and large(>3/4 inch) stones for disposal under landfill cap at B&M
or RSI Landfill

-	Mix excavated material with stabilizing additives(pending pre-design treatability
studies)

-	Place stabilized material as backfill (depending on what additives are used, it is
possible that mixing/treatment with asphalt emulsion may be feasible. In that
event, treated material may be suitable for a paving sub-grade layer

-	Institutional actions consisting of access restrictions (i.e., land use
restrictions, fencing and security measures)

-	Monitoring of groundwater to assess the protectiveness of the treatment

•	OnSite-2 - Soil Washing/Chemical Extraction

-	Excavation of soil/ waste to local staging area

-	Remove debris and large(>3/4 inch) stones for disposal under landfill cap at B&M
or RSI Landfill

-	Soils are rinsed of fine material(<2mm) and returned for placement as backfill

-	Fines are mixed with additives to remove site contaminants(pending pre-design
treatability studies)

-	Clean fines are returned as backfill

-	Sludge is dewatered prior to disposal

-	Treated water is discharged to groundwater via injection wells

-	Institutional actions consisting of access restrictions (i.e., land use
restrictions, fencing and security measures)

-	Monitoring of groundwater to assess the protectiveness of the treatment

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ASBESTOS LANDFILL

Table 7-11 presents a summary of the primary evaluation factors and a comparative assessment
of the technologies/ process options evaluated for AOC #6, Asbestos Landfill which
encompasses 13.3 acres. Table L-13 presents a summary of the ARARs associated with this AOC.
The only media of concern was soil. Previous sections of this report provided the option of
capping this AOC under the assumption that the existing cap may not be adeguately protective.
However, recent Site visits have determined that the existing cap is protective if maintained
properly. Therefore, the technologies/ process options for remediation of soil include:

•	No Action

-	Reevaluate taking no action at a minimum once every 5 years as part of the 5-year
review process for the entire Site

•	Institutional Action -

-	Institutional actions consisting of access restrictions (i.e., land use
restrictions, fencing and security measures)

-	Construction of perimeter fence

-	Maintenance of cap

-	Monitoring to assess the protectiveness of the cap;

ASBESTOS LAGOONS

Table 7-13 presents a summary of the primary evaluation factors and a comparative assessment
of the technologies/process options evaluated for AOC #7, Asbestos Lagoons which encompass
1.9 acres. Table L-14 presents a summary of the ARARs associated with this AOC. The media of
concern was soil and source control of contaminants in the lagoon sediment to protect
groundwater. These technologies/ process options for remediation of soil include:

•	No Action

-	Reevaluate taking no action at a minimum once every 5 years as part of the 5-year
review process for the entire Site

•	Institutional Action -

-	Institutional actions consisting of access restrictions (i.e., land use
restrictions, fencing and security measures)

-	Monitoring;

•	Source Control-1- Capping

-	Construction of single-barrier (Subtitle D - Solid Waste) landfill cap

-	Institutional actions consisting of access restrictions (i.e., land use
restrictions, fencing and security measures)

-	Maintenance of cap

-	Monitoring of groundwater to assess the protectiveness of the cap

•	Source Control-2 - On-Site Disposal

-	Excavation of soil/waste and placement under caps at other on-site AOC

-	Backfilling of excavated area

K. SUMMARY OF THE COMPARATIVE ANALYSIS OF ALTERNATIVES

Section 121(b)(1) of CERCLA presents several factors that at a minimum EPA is reguired to
consider in its assessment of alternatives. Building upon these specific statutory mandates,
the NCP articulates nine evaluation criteria to be used in assessing the individual remedial
alternatives.

A detailed analysis was performed on the alternatives using the nine evaluation criteria in
order to select a site remedy. The following is a summary of the comparison of each
alternative's strengths and weaknesses with respect to the nine evaluation criteria. These

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criteria are summarized as follows:

Threshold Criteria

The two threshold criteria described below must be met in order for the alternatives to be
eligible for selection in accordance with the NCP:

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

2.	Compliance with applicable or relevant and appropriate requirements (ARARs) addresses
whether or not a remedy will meet all Federal environmental and more stringent State
environmental and facility siting standards, requirements, criteria or limitations, unless
a waiver is invoked.

Primary Balancincr Criteria

The following five criteria are utilized to compare and evaluate the elements of one
alternative to another that meet the threshold criteria:

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

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

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

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

7.	Cost includes estimated capital and Operation Maintenance (O&M) costs, as well as
present-worth costs.

Modifying Criteria

The modifying criteria are used as the final evaluation of remedial alternatives, generally
after EPA has received public comment on the RI/FS and Proposed Plan:

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

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

COMPARISON OF SOURCE CONTROL CLEANUP OPTIONS BY AREA OF CONCERN (AOC)

Following the detailed analysis of each individual alternative, a comparative analysis,
focusing on the relative performance of each alternative against the nine criteria, was
conducted. This comparative analysis can be found in Tables 7-1 through 7-13 of the FS, which
are also attached to this ROD.

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The section below presents the nine criteria and a brief narrative summary of the
alternatives and the strengths and weaknesses according to the detailed and comparative
analysis. Only those alternatives which satisfied the first two threshold criteria were
balanced and modified using the remaining seven criteria.

Discussed briefly below are the relative strengths and weaknesses of the cleanup alternatives
considered for the different areas of concern. In addition, a graphic comparison is presented
in the tables that follow the discussion. The cleanup alternatives are compared against the
list of nine evaluation criteria that were described earlier. Of these, the criteria for
State Acceptance and Community Acceptance are evaluated after the public comment period. For
these criteria, see the state concurrence letter (Appendix A) and the Responsiveness Summary
(Part 3) .

I. B&M Railroad Landfill. The media of concern soil and source control of contaminants in
the landfill to protect groundwater. There is a risk from soil contamination to ecological
receptors (from metals). Table 7-1 presents a summary of the primary evaluation factors and a
comparative assessment of the technologies/process options evaluated for AOC #1, B&M
Railroad Landfill which encompasses 12.4 acres. The technologies/ process options to control
these risks include:

No Action	Subject to a review at least every five years as reguired by CERCLA

since wastes would be left in place;

Inst. Action:

Institutional actions consisting of access restrictions (i.e., land use
restrictions, fencing and security measures) as well as monitoring;

InSitu-1:

In-situ remedy of monitored natural attenuation and institutional
actions consisting of access restrictions (i.e., land use restrictions,
fencing and security measures) as well as monitoring;

SC-1:

Source control remedy consisting of horizontal containment (i.e., cap),
institutional actions consisting of access restrictions (i.e., land use
restrictions, fencing and security measures) as well as monitoring.

Analysis of Nine Criteria

Overall Protection of Human Health and the Environment:

The Source Control (SC-1) alternative is the only alternative which provides overall
protection, through capping. Capping prevents exposure to the environment from unacceptable
contaminant levels in soils. Migration of contaminants into groundwater is also prevented.
Institutional actions and monitoring will ensure that the cap is maintained and remains
protective. The other alternatives do not reduce or eliminate the potential for exposure to
unacceptable contaminant levels in soils for ecological receptors. The other alternatives
also don't prevent the migration of contaminants into groundwater.

Compliance with ARARs:

This AOC is adjacent to a wetland/surface water body. As such there are numerous federal and
state stream, wetland and floodplain regulations, which any chosen alternative must meet. In
addition, this AOC is an uncapped landfill. Because of this, there are numerous regulations
related to landfill closure and post- closure reguirements. Only the Source Control (SC-1)
alternative meets the reguirements of the closure and post- closure regulations, in
particular landfill capping reguirements. The other alternatives do not provide for any
activities that could constitute closure or post-closure under the regulations.

Long-Term Effectiveness and Permanence:

Only the Source Control (SC-1) alternative will provide continued long- term protection.

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Installation, maintenance, and monitoring of a cap will virtually eliminate exposure and risk
to ecological receptors and will prevent migration of contaminants into groundwater. The
other alternatives do not require actions that prevent ecological receptors from coming onto
contact with contaminated media, and therefore do not provide long- term protection. The
other alternatives also will not prevent contaminants from migrating into groundwater.

Reduction of Toxicity, Mobility and Volume through Treatment:

None of the alternatives involve treatment. Although the FS reviewed treatment alternatives
no treatment alternative was found suitable for this area.

Short-Term Effectiveness:

While this criterion encompasses a number of issues, the most significant issue is time until
Remedial Action Objectives are achieved. For the Source Control (SC-1) alternative, this time
period is 2 years. For the other alternatives, the time period is estimated at greater than
30 years.

Implementability:

Implementability is primarily related to three factors: technical feasibility (i.e., can it
be constructed, is it reliable); administrative feasibility; and the availability of services
and materials to implement the remedy. First, all of the alternatives are implementable from
a construction standpoint. The Source Control (SC-1) alternative is the most reliable in
meeting Remedial Action Objectives, while the No Action and Institutional Action alternatives
are the least reliable. Second, to varying degrees, all of the alternatives are
administratively feasible, with all but the No Action alternative containing provisions for
institutional controls such as deed restrictions. Therefore, these alternatives will require
a higher degree of administrative effort than the No Action alternative. Third, services and
materials are available for all alternatives.

Cost:

No-Action	$0 (there will be a slight incremental cost associated with site wide

Five-Year Review)

Institutional Action	$0.90 million

In-Situ	$0.97 million

Source Control	$9.66 million

II. RSI Landfill. The only media of concern is source control of contaminants in the landfill
to protect groundwater. Risk limits for human health or ecological receptors from contact
with soil were not exceeded at this AOC. Two technology/process options were considered:
capping (SCI) ; and No Action. Table 7-3 presents a summary of the primary evaluation factors
and a comparative assessment of the technologies/process options evaluated for AOC #2, RSI
Landfill which encompasses 2.5 acres. Capping was considered as part of source control for
groundwater cleanup. The technologies/process options to control these risks include:

•	No Action	Subject to a review at least every five years as required by CERCLA

since wastes would be left in place;

•	SC-1:	Source control remedy consisting of horizontal containment (i.e., cap),

institutional actions consisting of access restrictions (i.e., land use
restrictions, fencing and security measures) as well as monitoring.

Compliance with ARARs:

This AOC is an uncapped landfill. Therefore, there are numerous regulations related to
landfill closure and post-closure requirements, particularly regarding landfill capping.
Although OU3 does not address groundwater directly, the source control remedies to be

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implemented as part of the 0U3 ROD will have a positive impact on groundwater quality.

Capping the landfill will help prevent further migration of contaminants (arsenic and
manganese) from soil to groundwater, where a potential risk has been demonstrated. The Source
Control (SC-1) alternative meets the requirements of the closure and post-closure
regulations. The No Action alternative does not satisfy this criteria since it does not
provide for any activities that could constitute closure or post-closure under the
regulations.

Long-Term Effectiveness and Permanence:

Only the Source Control (SC-1) alternative will provide continued long-term protection.
Installation, maintenance, and monitoring of a cap will virtually eliminate migration of
contaminants from the landfill into groundwater. The No Action alternative does not require
actions that prevent migration of contaminants from contaminated media, and therefore do not
provide long-term protection.

Reduction of Toxicity, Mobility and Volume through Treatment:

None of the alternatives involve treatment. Although the FS reviewed treatment alternatives
no treatment alternative was found suitable for this area.

Short-Term Effectiveness:

While this criterion encompasses a number of issues, the most significant issue is time until
Remedial Action Objectives are achieved. For the Source Control (SC-1) alternative, this time
period is 2 years for construction and implementation of institutional controls. For the No
Action alternative, the time period is estimated at greater than 30 years.

Implementability:

Implementability is primarily related to three factors: technical feasibility (i.e., can it
be constructed, is it reliable); administrative feasibility; and the availability of services
and materials to implement the remedy. First, both alternatives are implementable from a
construction standpoint. The Source Control (SC-1) alternative is the most reliable in
meeting Remedial Action Objectives, while the No Action alternative is the least reliable.

Second, to varying degrees, both alternatives are administratively feasible, but the No
Action alternative does not contain provisions for institutional controls such as deed
restrictions. Therefore, the Source Control alternative will require a higher degree of
administrative effort than the No Action alternative. Third, services and materials are
available for both alternatives.

Cost:

No-Action	$0 (there will be a slight incremental cost associated with site wide

Five-Year Review)

Source Control	$2.49 million

III. B&M Locomotive Shop Disposal Areas. The media of concern are soil and source control of
contaminants in the disposal area to protect groundwater. There is potential risk in soil
to both human health (from lead) and ecological (from metals) receptors. Table 7-5 presents a
summary of the primary evaluation factors and a comparative assessment of the technologies/
process options evaluated for AOC #3, B&M Locomotive Shop Disposal Areas which together
encompass 4.7 acres. The technologies/process options to control these risks include:

•	No Action	Subject to a review at least every five years as required by CERCLA

since wastes would be left in place;

•	Inst. Action:	Institutional actions consisting of access restrictions (i.e., land

use restrictions, fencing and security measures) as well as
monitoring;

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OnSite-2:

OnSite-l:

InSitu-1:

SC-1:

SC-2:

In-situ remedy of monitored natural attenuation and institutional
actions consisting of access restrictions (i.e., land use
restrictions, fencing and security measures) as well as monitoring;
Source control remedy consisting of horizontal containment (i.e.
cap), institutional actions consisting of access restrictions (i.e.,
land use restrictions, fencing and security measures) as well as
monitoring;

Source control remedy consisting of soil/waste excavation and
placement under caps at other on-site AOCs;

Remedy consisting of soil/waste excavation and on-site treatment via
solidification/stabilization;

Remedy consisting of soil/waste excavation and on- site treatment via
soil washing/chemical extraction.

Analysis of Nine Criteria

Overall Protection of Human Health and the Environment:

The No Action alternative will not be protective of human health or the environment as it
does not significantly reduce or eliminate potential exposures to human or ecological
receptors, nor will migration of contaminants into groundwater be addressed. The
Institutional Action and InSitu-1 alternatives will be somewhat more protective of human
health, but not the environment, in that access (and exposure) to contaminated material will
be controlled. Furthermore, migration of contaminants into groundwater will not be addressed.
The SC-1, SC-2, OnSite-l and OnSite-2 alternatives will provide overall protection of human
health and the environment by effectively reducing or eliminating potential exposure to
contaminated soil and dust and eliminating migration of contaminants from soil to
groundwater.

Compliance with ARARs:

Of the seven alternatives considered, four (SC-1, SC-2, OnSite-l and OnSite-2) will have
activities that impact wetland areas. These impacts would need to be limited or mitigated in
order to meet ARARs. The nature of this AOC reguires that landfill closure and post-closure
reguirements be met. These four alternatives would meet the landfill closure and post-closure
reguirements. The No Action, Institutional Action and InSitu-1 alternatives would not meet
the landfill closure and post-closure reguirements.

Long-Term Effectiveness and Permanence:

Under the No Action alternative residual risks from soil contaminants will remain. Therefore,
it would not provide overall protection from exposures to both human and ecological receptors
nor prevent migration of contaminants into groundwater and therefore will not provide
long-term effectiveness. Under the Institutional Action and InSitu-1 alternatives, while
access to contaminated material will be controlled, over time migration of contaminants may
occur. The Institutional Action and InSitu-1, while exhibiting greater effectiveness than the
No Action alternative, still only achieve a moderate level of effectiveness.

The SC-1, SC-2, OnSite-l and OnSite-2 alternatives will provide long- term effectiveness in
protecting from exposures to both human health and ecological receptors and preventing
migration of contaminants into groundwater. The SC-1 and SC-2 caps must be constructed,
maintained, and monitored to ensure continued protection; the OnSite-l and OnSite-2 treatment
alternatives are effectively permanent.

Reduction of Toxicity, Mobility and Volume through Treatment:

The No Action, Institutional Action, InSitu-1, SC-1 and SC-2 alternatives do not utilize
treatment and therefore provide no reduction of toxicity, mobility and volume through
treatment. The OnSite-l and OnSite-2 alternatives do utilize treatment and would result in

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permanent reduction of toxicity, mobility and volume through treatment.

Short-Term Effectiveness:

The No Action alternative takes no actions and therefore does not cause any increase in
short-term risk. With standard control measures (dust control, air monitoring) , none of the
alternatives will cause increases of short-term risk to the community or workers. The
environmental impacts to natural habitats from the implementation of these alternatives,
range from: no impact (No Action); temporary and relatively minor impacts (Institutional
Action and InSitu-1); and greater impacts (SC-1, SC-2, OnSite-1 and OnSite-2). The potential
impacts to adjacent wetlands from disturbance during implementation of these alternatives is
expected to be moderate and would be mitigated.

The time until Remedial Action Objectives are achieved varies considerably. The No Action,
Institutional Action and InSitu-1 alternatives are expected to take greater than 30 years.
The SC-1, SC-2, OnSite-1 and OnSite-2 alternatives are expected to take 2 to 3 years.

Implementability:

Implementability is primarily related to three factors: technical feasibility (i.e., can it
be constructed, is it reliable); administrative feasibility; and the availability of services
and materials to implement the remedy. First, all of the alternatives are feasible to
implement. The No Action, Institutional Action and InSitu-1 alternatives would each take
little effort to construct; the SC-1, SC-2, OnSite-1 and OnSite-2 alternatives would reguire
a greater effort to construct. The No Action and Institutional Action alternatives are not
considered reliable in achieving Remedial Action Objectives. The InSitu-1 alternative is
considered slightly reliable in achieving Remedial Action Objectives. The SC-1, SC-2,

OnSite-1 and OnSite-2 alternatives are considered reliable in achieving Remedial Action
Objectives. Second, all of the alternatives are considered administratively feasible. Third,
services and materials are available for implementation of all alternatives. Services for the
OnSite-1 and OnSite-2 alternatives are somewhat less commonly available when compared with
the other alternatives.

Cost:

No-Action	$0 (there will be a slight incremental cost associated with site wide

Five-Year Review)

Institutional Action	$0.77 million

InSitu	$0.83 million

Source Control-1	$2.61 million

Source Control-2	$8.68 million

OnSite-1	$34.16 million

OnSite-2	$42.59 million

IV. Old B&M Oil/Sludge Recycling Area. The media of concern being addressed is soil with
potential human health risk ( from lead) and source control of contaminants in the soil to
prevent migration into groundwater. Table 7-7 presents a summary of the primary evaluation
factors and a comparative assessment of the technologies/process options evaluated for AOC
#4, Old B&M Oil/Sludge Recycling Area which encompasses 7 acres. The technologies/process
options for soil cleanup include:

•	No Action	Subject to a review at least every five years as reguired by CERCLA

since wastes would be left in place;

•	Inst. Action:	Institutional actions consisting of access restrictions (i.e., land

use restrictions, fencing and security measures) as well as
monitoring;

•	InSitu-1:	In-situ remedy of monitored natural attenuation and institutional

actions consisting of access restrictions (i.e., land use
restrictions, fencing and security measures) as well as monitoring;

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OnSite-2:

OnSite-l:

SC-1:

SC-2:

Source control remedy consisting of horizontal containment (i.e.
cap), institutional actions consisting of access restrictions (i.e.,
land use restrictions, fencing and security measures) as well as
monitoring;

Source control remedy consisting of soil excavation and placement
under caps at other on-site AOCs;

Remedy consisting of soil excavation and on-site treatment via
solidification/stabilization;

Remedy consisting of soil excavation and on-site treatment via soil
washing/chemical extraction.

Analysis of Nine Criteria

Overall Protection of Human Health and the Environment:

The No Action alternative will not be protective of human health or the environment as it
does not significantly reduce or eliminate potential exposures to human receptors, nor does
it prevent contaminant migration to groundwater. The Institutional Action and InSitu-1
alternatives will be somewhat more protective in that human access (and exposure) to
contaminated material will be controlled, but migration of contaminants into groundwater
would not be addressed. The SC-1, SC-2, OnSite-l and OnSite-2 alternatives will provide
overall protection of human health by effectively reducing or eliminating potential exposure
to soil and dust and preventing the migration of contaminants into groundwater. There are no
ecological risks due to soil at this area.

Compliance with ARARs:

The SC-1, SC-2, OnSite-l and OnSite-2 alternatives will meet the closure and post- closure
reguirements. The No Action, Institutional Action and InSitu-1 alternatives do not provide
for any activities that could constitute closure or post- closure under the regulations.

Long-Term Effectiveness and Permanence:

Under the No Action alternative, residual risks from soil contaminants will remain.

Therefore, they would not provide overall protection from exposures to human receptors and
therefore will not provide long-term effectiveness. Under the Institutional Action and
InSitu-1 alternatives, while access to contaminated material will be controlled, over time
migration of contaminants may occur. The Institutional Action and InSitu-1, while exhibiting
greater effectiveness than the No Action alternative, still only achieve a moderate level of
effectiveness.

The SC-1, SC-2, OnSite-l and OnSite-2 alternatives soil will provide long- term effectiveness
in protecting from exposure to human receptors. The SC-1 and SC-2 caps must be maintained and
monitored to ensure continued protection; the OnSite-l and OnSite-2 treatment alternatives
are effectively permanent.

Reduction of Toxicity, Mobility and Volume through Treatment:

The No Action, Institutional Action, InSitu-1, SC-1 and SC-2 alternatives do not utilize
treatment and therefore provide no reduction of toxicity, mobility and volume through
treatment. The OnSite-l and OnSite-2 alternatives do utilize treatment and would result in
permanent reduction of toxicity, mobility and volume through treatment.

Short-Term Effectiveness:

For all of the alternatives except No Action, with standard control measures (dust control,
air monitoring) none of the alternatives will cause increases of short-term risk to the
community or workers. The environmental impacts to natural habitats from the implementation
of these alternatives range from: no impact (No Action); temporary and relatively minor

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impacts (Institutional Action and InSitu-1) ; and greater impacts (SC-1, SC-2, OnSite-1 and
OnSite-2) due to ground disturbance and excavation.

The time until Remedial Action Objectives are achieved varies considerably. The No Action,
Institutional Action and InSitu-1 alternatives are expected to take greater than 30 years.
The SC-1, SC-2, OnSite-1 and OnSite-2 alternatives are expected to take 2 years.

Implementability:

Implementability is primarily related to three factors: technical feasibility (i.e., can it
be constructed, is it reliable); administrative feasibility; and the availability of services
and materials to implement the remedy. First, all of the alternatives are feasible to
implement. The No Action, Institutional Action and InSitu-1 alternatives would each take
little effort to implement; the SC-1, SC-2, OnSite-1 and OnSite-2 alternatives would reguire
greater effort to implement. The No Action and Institutional Action alternatives are not
considered reliable in achieving Remedial Action Objectives. The SC-1, SC-2, OnSite-1 and
OnSite-2 alternatives are considered reliable in achieving Remedial Action Objectives, and
the InSitu-1 alternative is considered slightly reliably in achieving Remedial Action
Objectives. Second, all of the alternatives are considered administratively feasible. Third,
services and materials are available for implementation of all alternatives; services for the
OnSite-1 and OnSite-2 alternatives are somewhat less commonly available.

Cost:

No-Action	$0 (there will be a slight incremental cost associated with site wide

Five-Year Review)

Institutional Action	$0.85 million

InSitu-1	$0.90 million

SC-1	$2.11 million

SC-2	$5.61 million

OnSite-1	$16.22 million

OnSite-2	$21.18 million

V. Contaminated Soils Area. The only media of concern being addressed is soil with potential
human health risk (from lead) and source control of contaminants to prevent migration into
groundwater. Table 7-9 presents a summary of the primary evaluation factors and a comparative
assessment of the technologies/process options evaluated for AOC #5, Contaminated Soils Area
which encompasses approximately 6.7 acres (the area in need of remediation). The
technologies/ process options for cleanup of soil include:

No Action
Inst. Action:

InSitu-1:

InSitu-2:
InSitu-3:

SC-1:
Off Site:

Subject to a review at least every five years as reguired by CERCLA
since wastes would be left in place;

Institutional actions consisting of access restrictions (i.e., land
use restrictions, fencing and security measures) as well as
monitoring;

In-situ remedy of monitored natural attenuation and institutional
actions consisting of access restrictions (i.e., land use
restrictions, fencing and security measures);

In-situ remedy consisting of solidification/stabilization and access
restrictions (i.e., land use restrictions) as well as monitoring;
In-situ remedy consisting of soil flushing, enhanced biodegradation,
and access restrictions (i.e., land use restrictions) as well as
monitoring;

Source control remedy consisting of horizontal containment (i.e.,
cap), institutional actions consisting of access restrictions (i.e.,
land use restrictions, fencing and security measures) as well as
monitoring.

Remedy consisting of soil excavation and off site treatment/disposal;

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•	OnSite-1:	Remedy consisting of soil excavation and on-site treatment via

solidification/stabilization;

•	OnSite-2:	Remedy consisting of soil excavation and on-site treatment via soil

washing/chemical extraction.

Analysis of Nine Criteria

Overall Protection of Human Health and the Environment:

The No Action alternative will not be protective of human health or the environment as it
does not significantly reduce or eliminate potential exposures to human receptors, nor does
it prevent contaminant migration to groundwater. The Institutional Action and InSitu-1
alternatives will be somewhat more protective in that access (and exposure) to contaminated
material will be controlled, but migration of contaminants into groundwater would not be
addressed. The InSitu-2, InSitu-3, SC-1, Off Site, OnSite-1 and OnSite-2 alternatives will
provide overall protection of human health by effectively reducing or eliminating potential
exposure to soil and dust and will prevent migration of contaminants into groundwater. There
are no ecological risks due to soil at this area.

Compliance with ARARs:

The InSitu-2, InSitu-3, will meet treatment standards by treating contaminated material to
eliminate risks from contact and migration to groundwater. The Off Site, OnSite-1 and
OnSite-2 alternatives will excavate contaminated soil for treatment or off-site disposal
eliminating the risks. The SC-1 alternative will meet closure reguirements by providing a
barrier to prevent contact and ingestion of contaminated soil thereby eliminating the risk.
Post- closure reguirements will be met through monitoring and inspections. The No Action,
Institutional Action and InSitu-1 alternatives would not meet closure and post-closure
reguirements, because they do not provide for any activities that could constitute closure or
post-closure under the regulations.

Long-Term Effectiveness and Permanence:

Under the No Action alternative residual risks from soil contaminants will remain. Therefore,
they would not provide overall protection from exposures to human receptors nor prevent
migration of contaminants into groundwater and therefore will not provide long-term
effectiveness. Under the Institutional Action and InSitu-1 alternatives, while access to
contaminated material will be controlled, over time migration of contaminants may occur.
Therefore, they would not provide overall protection from exposure to human receptors and
will not provide long-term effectiveness.

The InSitu-2, InSitu-3, SC-1, Off Site, OnSite-1 and OnSite-2 alternatives will provide long-
term effectiveness in protecting human receptors from exposure to contaminated soil and will
prevent migration of contaminants into groundwater. The SC-1 cap must be maintained and
monitored to ensure continued protection; the OnSite-1 and OnSite-2 treatment alternatives
are effectively permanent.

Reduction of Toxicity, Mobility and Volume through Treatment:

The No Action, Institutional Action, InSitu-1, and SC-1 alternatives do not utilize treatment
and therefore provide no reduction of toxicity, mobility and volume through treatment. The
InSitu-2, InSitu-3, Off Site, OnSite-1 and OnSite-2 alternatives do utilize treatment; the
InSitu-2, InSitu-3, Off Site, OnSite-1 and OnSite-2 alternatives provide the greatest degree
of expected reduction of toxicity, mobility and with the exception of the InSitu-2
alternative, volume through treatment. While the InSitu-2 alternative provides treatment, the
solidification/stabilization treatment process is accompanied by a potentially significant
increase in volume.

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Short-Term Effectiveness:

For all of the alternatives except No Action, with standard control measures (dust control,
air monitoring) none of the alternatives will cause increases of short-term risk to the
community or workers. The environmental impacts to natural habitats from the implementation
of these alternatives, range from: no impact (No Action); temporary and relatively minor
impacts (Institutional Action and InSitu-1); and greater impacts (InSitu-2, InSitu-3, SC-1,
Off Site, OnSite-1 and OnSite-2) due to ground disturbance and excavation.

The time until Remedial Action Objectives are achieved varies considerably. The No Action,
Institutional Action and InSitu-1 alternatives are expected to take greater than 30 years.
The InSitu-2, InSitu-3, SC-1, Off Site, OnSite-1 and OnSite-2 alternatives are expected to
take 2 years.

Implementability:

Implementability is primarily related to three factors: technical feasibility (i.e., can it
be constructed, is it reliable); administrative feasibility; and the availability of services
and materials to implement the remedy. First, all of the alternatives are feasible to
implement. The No Action, Institutional Action and InSitu-1 alternatives would each take
little effort to implement; the InSitu-2, InSitu-3, SC-1, Off Site, OnSite-1 and OnSite-2
alternatives would reguire a greater effort to implement, since the AOC is within an active
rail yard. The No Action and Institutional Action alternatives are not considered reliable in
achieving Remedial Action Objectives. The InSitu-2, InSitu-3, SC-1, Off Site, OnSite-1 and
OnSite-2 alternatives are considered reliable in achieving Remedial Action Objectives, with
the InSitu-2 alternative potentially less reliable. The InSitu-1 alternative is considered
moderately slightly reliable in achieving Remedial Action Objectives. Second, all of the
alternatives are considered administratively feasible. Third, services and materials are
available for implementation of all alternatives; services for the InSitu-2, InSitu-3,
OnSite-1 and OnSite-2 alternatives are somewhat less commonly available.

Cost:

No-Action	$0 (there will be a slight incremental cost associated with site wide

Five-Year Review)

Institutional Action	$1.54 million

InSitu-1	$1.58 million

InSitu-2	$2.25 million

InSitu-3	$10.23 million

SC-1	$2.40 million

Off Site	$7.83 million

OnSite-1	$8.20 million

OnSite-2	$11.59 million

VI. Asbestos Landfill. The media of concern was soil with the potential for human health risk
(from asbestos). As the Asbestos Landfill had previously been capped, only maintenance
activities were considered. Table 7-11 presents a summary of the primary evaluation factors
and a comparative assessment of the technologies/process options evaluated for AOC #6,
Asbestos Landfill which encompasses 13.3 acres. The options for cleanup of soil include:

•	No Action	Subject to a review at least every five years as reguired by CERCLA

since wastes would be left in place;

•	Inst. Action:	Institutional actions consisting of access restrictions (i.e., land

use restrictions, fencing and security measures) as well as
monitoring and maintenance of the existing cap.

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Analysis of Nine Criteria

Overall Protection of Human Health and the Environment:

As long as the existing cap is maintained, it will remain protective of human health.

Therefore, both the No Action and Institutional Action alternatives would be protective.
However, the lack of maintenance would eventually cause the No Action alternative to be
unprotective.

Compliance with ARARs:

Reguirements related to the disturbance and handling of asbestos containing materials are the
most significant for this area. Under the Institutional Action, activities(i.e., fence
installation) that may impact wetlands must be conducted in such a way as to minimize wetland
impacts in order to meet associated reguirements. The cap will be maintained to satisfy
asbestos capping reguirements under the Institutional Action, but not under the No Action
alternative.

Long-Term Effectiveness and Permanence:

Under the Institutional Action, but not under the No Action alternative, with continued
maintenance of the existing cap, there will be no risk to human receptors due to potential
exposure to asbestos.

Reduction of Toxicity, Mobility and Volume through Treatment:

Neither alternative utilizes treatment processes and therefore provide no reduction of
toxicity, mobility and volume through treatment.

Short-Term Effectiveness:

The Institutional Action alternative will be accompanied by a nominal increase of potential
short-term risk of exposure, due primarily to soil disturbance for fence installation. Air
monitoring and engineering controls to control dust will be reguired to manage potential risk
from inhalation.

Implementability:

Implementability is primarily related to three factors: technical feasibility (i.e., can it
be constructed, is it reliable); administrative feasibility; and the availability of services
and materials to implement the remedy. Both alternatives are technically and administratively
feasible to implement. Services and materials for the alternatives are available.

Cost:

No-Action

Institutional Action
(including monitoring
and maintaining the cap)

VII. Asbestos Lagoons. The media of concern being addressed is soil with the potential for
human health risk (from asbestos) and source control of contaminants in the lagoon sediment
to protect groundwater. Table 7-13 presents a summary of the primary evaluation factors and a
comparative assessment of the technologies/process options evaluated for AOC #7, Asbestos
Lagoons which encompass 1.9 acres. The technologies/process options for soil cleanup include:

• No Action	Subject to a review at least every five years as reguired by CERCLA

since wastes would be left in place;

$0 (there will be a slight incremental cost associated with site wide

Five-Year Review)

$1.31 million

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•	Inst. Action:	Institutional actions consisting of access restrictions (i.e., land

use restrictions, fencing and security measures) as well as
monitoring;

•	SC-1:	Source control remedy consisting of horizontal containment (i.e.,

cap), institutional actions consisting of access restrictions (i.e.,
land use restrictions, fencing and security measures) as well as
monitoring;

•	SC-2:	Source control remedy consisting of soil excavation and placement

under caps at other on-site AOCs.

Analysis of Nine Criteria

Overall Protection of Human Health and the Environment:

The No Action alternative will not be protective of human health or the environment as it
does not significantly reduce or eliminate potential exposure of human receptors to soil nor
does it prevent migration of contaminants into groundwater. The Institutional Action
alternative will be somewhat more protective in that access (and exposure) to contaminated
material will be controlled, but migration of contaminants into groundwater would not be
addressed. The SC-1 and SC-2 alternatives will provide overall protection of human health by
effectively reducing or eliminating potential exposure of human receptors to soil and
preventing the migration of contaminants into groundwater.

Compliance with ARARs:

Reguirements related to the disturbance and handling of asbestos containing materials and the
closure/post closure of waste facilities are the most significant for this area. The SC-1 and
SC-2 alternatives would achieve these reguirements. No Action and Institutional Action do not
provide for any activities that would meet these reguirements, nor would they meet
closure/post closure standards.

Long-Term Effectiveness and Permanence:

The No Action and Institutional Action alternatives will allow residual risks to remain at
unacceptable levels. The SC-1 and SC-2 alternatives will provide long-term effectiveness in
protecting from exposure of human receptors to asbestos containing material and prevent the
migration of contaminants into groundwater. Cap maintenance and monitoring will be necessary
to ensure continued effectiveness.

Reduction of Toxicity, Mobility and Volume through Treatment:

None of the considered alternatives utilize treatment processes and therefore provide no
reduction of toxicity, mobility and volume through treatment.

Short-Term Effectiveness:

The Institutional Action alternative will be accompanied by a nominal increase of potential
short-term risk of exposure, due primarily to soil disturbance for fence installation. Air
monitoring and engineering controls to control dust will be reguired to manage potential risk
from inhalation. The SC-1 and SC-2 alternatives will be accompanied by a somewhat greater
potential short-term risk of exposure, due to capping and the handling of asbestos containing
material which is necessary in these alternatives. As alternative SC-2 involves transport of
material to another AOC, short term risks (from asbestos material becoming airborne) are
potentially greater than for SC-1. Air monitoring, dust control/suppression measures will be
employed, and workers will wear necessary protective eguipment.

Implementability:

Implementability is primarily related to three factors: technical feasibility (i.e., can it

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be constructed, is it reliable); administrative feasibility; and the availability of services
and materials to implement the remedy. These alternatives are all technically and
administratively feasible to implement. Services and materials for the alternatives are
available.

Cost:

No-Action

Institutional Action
SC-1
SC-2

L. THE SELECTED REMEDY

1.	Summary of the Rationale for the Selected Remedy

The selected remedy is a combination of individual source control remedies which addresses
risks associated with the seven Areas of Concern (AOCs) at Operable Unit 3 (0U3) of Iron
Horse Park.

The capping components of the remedy will prevent direct contact with contaminants by human
and ecological receptors. In addition these components will help prevent migration of
contaminants to groundwater and surface water.

A source control remedy was chosen for implementation at each area of concern.

2.	Description of Remedial Components

The selected remedy for the B&M Railroad Landfill involves:

•	excavating landfill material from the edge of the wetland to minimize impacts of the
cleanup action;

Install sheet piling along the edge of the wetland. Excavate waste material 5 feet deep and
50 feet wide along edge of wetland. Place excavated material on landfill

•	capping landfill material;

Cap landfill: grade slopes, install: Double barrier cap (Region 1 Alternative Cap Design). An
example of a cap utilizing the Region 1 Alternative Cap Design, would include installation
of: soil sub-grade layer; suitable gas vent layer; low-permeability soil layer (<10-4 cm/sec)
>12 inches; 60 mil low-density polyethylene membrane liner; drainage layer; 24 inch cover
soil layer; 6 inch topsoil layer and hydro-seed( Figure L-l). In addition, storm-water
drainage structures (swales, rip-rap, perimeter drains) , detention basins and gas vents, as
necessary.

•	erecting a fence around the landfill;

Install fence to prevent unauthorized access in order to safeguard the public, and prevent
damage to landfill structures.

•	instituting land use restrictions;

Restrict activities (like excavation and construction) which may damage the landfill cap and
cause exposure to and migration of landfill contaminants. To be implemented by responsible
parties.

•	restoring wetlands impacted by the cleanup;

Install wetland soils and replant with appropriate species as necessary. The limits of the
wetland restoration will be determined during remedial design.

$0 (there will be a slight incremental cost associated with site wide

Five-Year Review)

$0.85 million
$2.90 million
$1.97 million

inspecting & maintaining the landfill cap & fence on a periodic basis to ensure that it

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remains effective;

Maintenance program to inspect landfill structures and maintain/ repair as necessary.

•	sampling groundwater periodically to assess the effects of the source control action
(capping)& any ongoing impacts from the landfill. Installing, if necessary, new monitoring
wells.

Monitor groundwater quality downgradient of landfill
The selected remedy for the RSI Landfill involves:

•	capping landfill material;

Cap landfill: grade slopes, install: Single barrier - Subtitle D - Solid Waste cap. An
example of a Subtitle D - Solid Waste cap would include installation of: soil sub-grade
layer; suitable gas vent layer; 60 mil low- density polyethylene membrane liner; drainage
layer; 24 inch cover soil layer; 6 inch topsoil layer and hydro-seed(Figure L-2). In
addition, storm-water drainage structures (swales, rip-rap, perimeter drains) , detention
basins and gas vents, as necessary.

•	erecting a fence around the landfill;

Install fence to prevent unauthorized access in order to safeguard the public, and prevent
damage to landfill structures.

•	instituting land use restrictions;

Restrict activities (like excavation and construction) which may damage the landfill cap and
cause exposure to and migration of landfill contaminants. To be implemented by responsible
parties.

•	inspecting & maintaining the landfill cap & fence on a periodic basis to ensure that it
remains effective;

Maintenance program to inspect landfill structures and maintain/ repair as necessary.

•	sampling groundwater periodically to assess the effects of the source control action
(capping)& any ongoing impacts from the landfill. Installing, if necessary, new monitoring
wells.

Monitor groundwater quality downgradient of landfill

The selected remedy for the B&M Locomotive Shop Disposal Areas involves:

•	capping disposal area;

Cap disposal area: Grade slopes, install: Single barrier - Subtitle D - Solid Waste cap. An
example of a Subtitle D - Solid Waste cap would include installation of: soil sub-grade
layer; suitable gas vent layer; 60 mil low-density polyethylene membrane liner; drainage
layer; 24 inch cover soil layer; 6 inch topsoil layer and hydro-seed( Figure L-2). In
addition, storm-water drainage structures (swales, rip-rap, perimeter drains), detention
basins and gas vents, as necessary.

•	erecting a fence around the landfill;

Install fence to prevent unauthorized access in order to safeguard the public, and prevent
damage to landfill structures.

•	instituting land use restrictions;

Restrict activities (like excavation and construction) which may damage the landfill cap and
cause exposure to and migration of landfill contaminants. To be implemented by responsible
parties.

•	restoring wetlands impacted by the cleanup;

Install wetland soils and replant with appropriate species as necessary.

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•	inspecting & maintaining the landfill cap & fencing on a periodic basis to ensure that it
remains effective;

Maintenance program to inspect landfill structures and maintain/ repair as necessary.

•	sampling groundwater periodically to assess the effects of the source control action
(capping)& any ongoing impacts from the landfill. Installing, if necessary, new monitoring
wells.

Monitor groundwater quality downgradient of landfill

The selected remedy for the Old B&M Oil/Sludge Recycling Area involves:

•	capping contaminated soils with a gravel/asphalt barrier (final area to be capped will be
determined via a pre-design study);

Cap area with a gravel/asphalt barrier based on relevant and appropriate Subtitle D Solid
Waste capping standards (final area to be capped will be determined via a pre-design study -
assumed to be 7 acres). An example of relevant and appropriate Subtitle D Solid Waste capping
standards would include installing gravel sub-grade layer as necessary, bituminous concrete
intermediate course and bituminous concrete top course (Figure L-3)

•	instituting land use restrictions;

Restrict activities (excavation and construction) which may damage the cap and permit
exposure to contaminated material. To be implemented by responsible parties.

•	sampling groundwater periodically to assess the effects of the source control action
(capping). Installing, if necessary, new monitoring wells.

Monitor downgradient groundwater quality

The selected remedy for the Contaminated Soils Area involves:

•	capping contaminated soils;

Cap area with a gravel/asphalt barrier based on relevant and appropriate Subtitle D Solid
Waste capping standards. An example of relevant and appropriate Subtitle D Solid Waste
capping standards would include installing a gravel sub-grade layer, bituminous concrete
intermediate course and bituminous concrete top course(Figure L-3). Special care will be
required to conduct capping activities in rail yard areas;

•	instituting land use restrictions;

Restrict activities (excavation and construction) which may damage the cap and permit
exposure to contaminated material. To be implemented by responsible parties.

•	sampling groundwater periodically to assess the effects of the source control action (
capping). Installing, if necessary, new monitoring wells.

Monitor downgradient groundwater quality

The selected remedy for the Asbestos Landfill involves:

•	inspecting & maintaining the existing gravel & vegetated soil cap to ensure asbestos
material does not become airborne;

Maintenance program to inspect existing landfill structures and maintain/repair as necessary.

•	erecting & maintaining a fence around the landfill;

Install fence to prevent unauthorized access in order to safeguard the public, and prevent
damage to landfill structures.

•	instituting land use restrictions;

Restrict activities (like excavation and construction, residential use) which may damage the
landfill cap and cause exposure to and migration of landfill contaminants(asbestos). To be
implemented by responsible parties.

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•	sampling groundwater periodically to assess the effects of the source control action
(capping)& any ongoing impacts from the landfill Installing, if necessary, new monitoring
wells.

Monitor downgradient groundwater guality

The selected remedy for the Asbestos Lagoons involves:

•	capping lagoon material;

Cap lagoons: define limits of contamination, including potential satellite deposits, grade
slopes/berms, install: soil/fill if necessary for subgrade; Single barrier - Subtitle D -
Solid Waste cap. An example of a Subtitle D - Solid Waste cap would include installation of:
soil sub-grade layer; suitable gas vent layer; 60 mil low-density polyethylene membrane
liner; drainage layer; 24 inch cover soil layer; 6 inch topsoil layer and hydro-seed( Figure
L-2). In addition, storm- water drainage structures (swales, rip-rap, perimeter drains),
detention basins, as necessary.

•	erecting a fence around the capped material;

Install fence to prevent unauthorized access in order to safeguard the public, and prevent
damage to cap structures.

•	instituting land use restrictions;

Restrict activities (like excavation and construction, residential use) which may damage the
cap and cause exposure to and migration of capped contaminants. To be implemented by
responsible parties.

•	inspecting & maintaining the cap & fence on a periodic basis to ensure that it remains
effective;

Maintenance program to inspect cap structures and maintain/ repair as necessary.

•	sampling groundwater periodically to assess the effects of the source control action
(capping)& any ongoing impacts from the landfill. Installing, if necessary, new monitoring
wells.

Monitor groundwater quality downgradient of lagoons.

The ground water monitoring system will be utilized to collect information semi-annually
regarding groundwater quality down gradient of individual source areas to help assess the
effectiveness of the source control remedies.

Hazardous substances, pollutants or contaminants already remain at the Site due to previous
actions (OU2 Shaffer Landfill closure). Because of this, EPA has and will continue to review
the Iron Horse Park Site at least once every five years to assure that the implemented
remedial actions continue to protect human health and the environment. The most recent
Five-Year Review was completed by EPA in September 2003. The next review will be required by
September 2008.

The selected remedy may change somewhat as a result of the remedial design and construction
processes. Changes to the remedy described in this Record of Decision will be documented in a
technical memorandum in the Administrative Record for the Site, an Explanation of Significant
Differences ("ESD") or a Record of Decision Amendment, as appropriate.

3. Summary of the Estimated Remedy Costs

See Tables L-l thru L-7 for a summary of Estimated Remedy Costs by AOC.

The information in this cost estimate summary table is based on the best available
information regarding the anticipated scope of the remedial alternative. Changes in the cost
elements are likely to occur as a result of new information and data collected during the
engineering design of the remedial alternative. Major changes may be documented in the form
of a memorandum in the Administrative Record file, an ESD, or a ROD amendment. This is an

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order-of-magnitude engineering cost estimate that is expected to be within +50 to -30 percent
of the actual project cost.

The total estimated cost of the selected remedy for all AOCs is $23.53 million.

4. Expected Outcomes of the Selected Remedy

An expected outcome of the selected remedy is that the B&M Locomotive Shop Disposal Areas,
the Old B&M Oil/Sludge Recycling Area and the Contaminated Soils Area will no longer present
an unacceptable risk to human health via ingestion. Another expected outcome of the selected
remedy is that the Asbestos Landfill and the Asbestos Lagoons will no longer present a
potential human health risk via inhalation of asbestos. Another expected outcome is that the
B&M Landfill and the B&M Locomotive Shop Disposal Area will no longer present an unacceptable
environmental risk via ingestion and direct contact. An additional expected outcome is the
source control actions, specifically capping, removing the B&M Landfill, the RSI Landfill,
the B&M Locomotive Shop Disposal Areas, the Old B&M Oil/Sludge Recycling Area, the
Contaminated Soils Area, and the Asbestos Lagoons as source areas and ongoing contributors of
contamination to local groundwater.

The selected remedy will also provide environmental and ecological benefits such as
preventing further negative impacts from the B&M Landfill and the B&M Locomotive Shop
Disposal Area on adjacent wetlands.

a. Soil Cleanup Levels

The current and anticipated future use of the Site is industrial. The Site is zoned
industrial with the industrial zoning extending somewhat beyond the site limits. The
Middlesex Canal,, which flows through the Site, is essentially impassible for recreational or
economic purposes. The Middlesex Canal is listed on the National Register of Historic Places.
Current landowners and operating companies at the Iron Horse Industrial Park include: B&M
Corporation, MBTA, General Latex, Penn Culvert (most recently Cooperative Reserve Supply),
Spincraft, Wood Fabricators, BNZ Materials, and Eastern Terminals, Inc. The Purity Supreme
warehouse abuts the Site to the south. The area within one mile of the Site is primarily
forested and residential, with "rural residential" being the predominant zoning category.

A soil cleanup level for lead was developed to protect a current female site worker of child-
bearing age. The cleanup level is based on the methodology described in Interim Approach to
Assessing Risk Associated with Adult Exposures to Lead in Soil (U.S. EPA, 1996) . The cleanup
level is based on the site- specific maternal blood level of 4.2 ng/dL, developed in the RI
risk assessment as a level protective of a 95th percentile fetal blood lead level of 10
Hg/dL. The lead cleanup level applies to the B&M Locomotive Shop Disposal Areas, Old B&M
Oil/Sludge Recycling Area, and Contaminated Soils Area.

Table CL-1 summarizes the cleanup level for lead in soils.

Table CL-1: Soil Cleanup Levels for the Protection of Human Receptors

Non-Carcinogenic
Compounds of Quotient
Concern

Target Endpoint

Soil Cleanup Level
(mg/kg)

Basis

RME Hazard
Quotient

Lead

Central Nervous
System

1,736

Adult Lead Model

N/A

Development of soil cleanup levels for ecological receptors was based on shrew endpoints to
emphasize the importance of contamination in the food chain and risk to the small mammal
community. Risks were identified for exposures of shrew to high concentrations of cadmium in
soil at the B&M Railroad Landfill and to copper and lead in soils at the B&M Locomotive Shop
Disposal Areas.

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Cleanup levels were developed to identify a soil concentration at which ecological effects
are likely to occur. The cleanup levels are based on a daily dose resulting in a hazard
guotient (HQ) of 1.0, and using a protective NOAEL TRV. Since food COC concentrations were
estimated from soil concentrations, the food chain models were used to back-calculate a soil
concentration that corresponds to a daily dose resulting in an HQ of 1.0. This approach
assumes that concentrations are evenly distributed throughout the site or foraging area.
Cleanup levels are summarized below (Table CL-2) for those COCs identified as posing risk to
small terrestrial mammals. The cleanup levels are based on modeling of receptor dietary doses
from soil concentrations.

Table CL-2: Soil Cleanup Levels for the Protection of Ecological Receptors

AOC

Compounds of
Concern

Soil Cleanup
Level (mg/kg)

Basis

Assessment
Endpoint

B&M Railroad Landfill

Cadmium

15.4

Food chain models,
NOAEL

Sustainability
(survival, growth,
reproduction) of local
populations of small
terrestrial mammals

B&M Locomotive
Shop Disposal Areas

Copper

2,213

Food chain models,
NOAEL

Sustainability
(survival, growth,
reproduction) of local
populations of small
terrestrial mammals

Lead

CO
Ch
CO

Food chain models,
NOAEL

Sustainability
(survival, growth,
reproduction) of local
populations of small
terrestrial mammals

These soil cleanup levels must be met at the completion of the remedial action at the points
of compliance. These soil cleanup levels attain EPA's risk management goal for remedial
actions and have been determined by EPA to be protective.

b. Soil - Source Control

A significant component of the Iron Horse Park OU3 Remedy involves source control actions.
The source control actions at the B&M Landfill, the RSI Landfill, the B&M Locomotive Shop
Disposal Areas, the Old B&M Oil/Sludge Recycling Area, the Contaminated Soils Area and
the Asbestos Lagoons have two purposes. One purpose is to prevent exposure to contaminated
material (metals or asbestos). Another purpose is to prevent the migration of contaminants
from soil to groundwater. At these AOCs there are many instances of a particular contaminant
being present in both soil(surface or sub-surface) and in downgradient groundwater. At the
B&M Landfill, toluene, xylenes, arsenic, manganese, lead, barium, chromium, vanadium and zinc
are present in both media. At the RSI Landfill, chlorobenzene, 1,2 dichloroethene, arsenic,
manganese, barium and lead are present in both media. At the B&M Locomotive Shop Disposal
Areas, arsenic, manganese, barium, copper, lead and zinc are present in both media. At the
Old B&M Oil/Sludge Recycling Area, arsenic, manganese, lead, barium, cobalt, chromium and
vanadium are present in both media. At the Contaminated Soils Area, arsenic, manganese,
copper and zinc are present in both media. At the Asbestos Lagoons, xylenes, arsenic,
manganese, barium, lead, chromium and zinc are present in both sediment (i.e. the solid
material within the lagoons which was sampled) and downgradient groundwater. The occurrence
of contaminants will be evaluated for inclusion in post-closure monitoring, in order to
evaluate the effectiveness of the source control actions at these AOCs in preventing
migration of contaminants to groundwater.

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c. Soil - Asbestos

Trespassers and workers potentially may be chronically exposed to asbestos fibers released
from the Asbestos Lagoons as well as at the Asbestos Landfill, if the landfill cap is not
maintained.

Effects on the lung resulting from inhalation of asbestos fibers is the major asbestos health
concern. Chronic inhalation exposure to asbestos can result in a lung disease termed
asbestosis which is characterized by shortness of breath and cough. Asbestosis may lead to
severe impairment of respiratory function and ultimately death. Other effects include
scarring of tissue surrounding the lungs, pulmonary hypertension and immunological effects.
Inhalation of asbestos fibers can cause lung cancer and mesothelioma (a rare cancer of the
thin membranes lining the abdominal cavity and surrounding internal organs).

Asbestos fibers in the Lagoons, have the potential to become airborne, posing a human health
threat via the inhalation pathway. Disposal of asbestos in these lagoons as well as
subseguent partial removal has been documented. Furthermore, sampling of material in the
lagoons confirms the presence of asbestos.

Under the National Emissions Standards for Hazardous Air Pollutants (NESHAP), in 1973 EPA
defined asbestos containing material as material containing 1% asbestos or greater based
detection limits available at the time. More recent data demonstrates that materials
containing less than 1% asbestos may also pose a potential health risk in some circumstances.

M. STATUTORY DETERMINATIONS

The remedial action selected for implementation at the Iron Horse Park 0U3 Site is consistent
with CERCLA and, to the extent practicable, the NCP. The selected remedy is protective of
human health and the environment, will comply with ARARs and is cost effective. In addition,
the selected remedy utilizes permanent solutions and alternate treatment technologies or
resource recovery technologies to the maximum extent practicable, and satisfies the statutory
preference for treatment that permanently and significantly reduces the mobility, toxicity or
volume of hazardous substances as a principal element.

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

The remedy at this Site will adeguately protect human health and the environment by
eliminating, reducing or controlling exposures to human and environmental receptors through
engineering controls and institutional controls. More specifically capping of contaminated
material, maintenance of an existing cap, fencing and land use restrictions will control and
eliminate potential risks posed by Operable Unit 3 of Iron Horse Park. Capping will prevent
direct contact with contaminated material. Capping and maintenance of an existing cap will
prevent asbestos from becoming airborne. Capping will prevent migration of contaminants into
groundwater. Fencing and land use restrictions, will ensure that remedial measures are
preserved and continue to prevent exposure and further releases.

The selected remedy will reduce potential human health risk levels such that the
nonncarcinogenic hazard is below a level of concern. It will reduce potential human health
risk levels to protective ARARs levels, i.e., the remedy will comply with ARARs and To Be
Considered criteria. The selected remedy will control ecological risk by eliminating direct
contact with and ingestion of contaminants above acceptable ecological risk levels in soil
and preventing migration of contaminants into surface waters. Implementation of the selected
remedy will not pose any unacceptable short-term risks or cause any cross-media impacts.

The selected response action addresses low-level threat wastes at the site by: eliminating
exposure to human and ecological receptors from contaminated soil and airborne asbestos. This
is accomplished through source control actions at the affected AOCs (capping of landfills and
contaminated soil areas). In addition, the source control actions will help eliminate the
ongoing migration of contaminants from the source areas to groundwater or surface water. Long

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term monitoring/maintenance and institutional controls will ensure that the remedy remains
protective in the future. There are no principal threat wastes at 0U3.

2. The Selected Remedy Complies With ARARs

The selected remedy, consisting of capping six of the AOCs and maintaining a cap previously
constructed at the seventh AOC, will comply with all federal and any more stringent state
ARARs that pertain to the Site (see Tables L-8 thru L-14). Federal ARARs, and the AOC's they
apply to, are:

1.	Resource Conservation and Recovery Act - B&M Landfill (closure/post closure and floodplain
standards); All AOCs except the Asbestos Landfill (waste characterization)

2.	Toxic Substances Control Act - Asbestos Landfill and Asbestos Lagoons

3.	Clean Water Act - B&M Landfill, RSI Landfill, B&M Disposal Areas, Asbestos Landfill

4.	Executive Order 11988 (Floodplain Management) - B&M Landfill

5.	Executive Order 11990 ( Protection of Wetlands) - B&M Landfill, RSI Landfill, B&M Disposal
Areas, Asbestos Landfill

6.	Fish & Wildlife Coordination Act - B&M Landfill, RSI Landfill, B&M Disposal Areas,

Asbestos Landfill

7.	National Historic Preservation Act - B&M Landfill and RSI Landfill

8.	Historic Sites Act - B&M Landfill and RSI Landfill

9.	Clean Air Act, National Emission Standard for Asbestos, Subpart M - Asbestos Landfill and
Asbestos Lagoons

The ARARs for each AOC vary depending on the type of cap reguired (TSCA, hazardous
waste, or solid waste); the location of the AOC relative to wetlands, floodplains, and
historic structures; the contaminants present (including, but not limited to asbestos, lead);
and whether the AOC is a source control remedy or not (see Tables L-8 thru L-14). RCRA Land
Ban reguirements (40 CFR Part 268) are not ARARs at this Site.

In addition, the selected remedies for each AOC will comply with the following more stringent
state ARARs that are described in more detail in Tables L-8 thru L-14:

1.	Massachusetts Solid Waste Management Regulations - All AOCs except B&M Landfill and
Asbestos Landfill

2.	Massachusetts Hazardous Waste Management Regulations - B&M Landfill (capping standards);
All AOCs except the Asbestos Landfill ( waste characterization)

3.	Massachusetts Clean Waters Act - B&M Landfill, RSI Landfill, B&M Disposal Areas, Asbestos
Landfill

4.	Massachusetts Wetlands Protection Act - All AOCs

5.	Massachusetts Antiquities Act and Regulations - B&M Landfill and RSI Landfill

6.	Massachusetts Air Pollution Control Regulations - All AOCs

The specific State ARARs for each selected remedy for each of the seven AOC are listed in
Tables L-8 thru L-14 and, as with the federal ARARs, they vary based on the type of cap
reguired (hazardous waste or solid waste); the location of the AOC relative to wetlands,
floodplains, and historic structures; the contaminants present (including, but not limited to
asbestos, lead); and whether the AOC is a source control remedy or not.

The following policies, advisories, criteria, and guidances (TBCs) were also be considered
for each selected remedy for each of the seven AOCs listed in Tables L-8 thru L-14. The TBCs
pertain either to assessing risk or to providing guidance on capping standards.

a.	Clarifying Cleanup Goals and Identification of New Assessment Tools for Evaluating
Asbestos at Superfund Cleanups (EPA) - Asbestos Lagoons and Asbestos Landfill

b.	Recommendations of the Technical Review Workgroup for Lead for an Approach to Assessing
Risks Associated with Adult Exposure to Lead in Soil (EPA) - B&M Disposal Areas, B&M
Oil/Sludge Recycling Area, Contaminated Soil Area

c.	EPA Cancer Slope Factors - All AOCs, except the Asbestos Landfill

d.	EPA Reference Dose - All AOCs except the Asbestos Landfill

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e.	EPA Alternative Cap Guidance - B&M Landfill

f.	Massachusetts DEP Landfill Technical Guidance Manual - All AOCs except B&M Landfill and
Asbestos Landfill

3.	The Selected Remedy is Cost-Effective

In the Lead Agency's judgment, the selected remedy is cost-effective because the remedy's
costs are proportional to its overall effectiveness (see 40 CFR 300.430(f) (1) (ii) (D)). This
determination was made by evaluating the overall effectiveness of those alternatives that
satisfied the threshold criteria (i.e., that are protective of human health and the
environment and comply with all federal and any more stringent ARARs, or as appropriate,
waive ARARs). Overall effectiveness was evaluated by assessing three of the five balancing
criteria -- long-term effectiveness and permanence; reduction in toxicity, mobility, and
volume through treatment; and short- term effectiveness, in combination. The overall
effectiveness of each alternative then was compared to the alternative's costs to determine
cost- effectiveness. The relationship of the overall effectiveness of this remedial
alternative was determined to be proportional to its costs and hence represents a reasonable
value for the money to be spent.

Tables 7-1, 7-3, 7-5, 7-7, 7-9, 7-11 and 7-13 help demonstrate the cost-effectiveness of the
selected remedy. In general, the cost differences between different protective alternatives
at each AOC are so extensive, and the increase in overall effectiveness (if any) is so
modest, that the cost effectiveness of the selected remedy is self-evident. It should be
noted that at the Contaminated Soils AOC, the selected remedy of capping appears to compare
very closely with the in-situ solidification/ stabilization alternative. In addition, the
solidification/stabilization alternative utilizes treatment. However, this AOC is in the
midst of the active rail yard at Iron Horse Park. The solidification/stabilization process
has the potential for a significant volumetric increase (up to 50%) in material due to
additives in the solidification/stabilization process. The rail yard with active tracks, is
an area where this kind of additional volume would be very problematic due to impacts on the
railroad tracks.

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

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

Tables 7-1, 7-3, 7-5, 7-7, 7-9, 7-11 and 7-13 demonstrate how the respective selected
remedies, provide the best balance of trade-offs when compared against the evaluation
criteria. As discussed previously, the cost difference between different protective
alternatives at each AOC is typically so extensive, and the increase in overall effectiveness
(if any) is so modest, that even with the balance emphasis on reduction of toxicity, mobility
and volume through treatment, the relative merits of the selected remedies are self-evident.

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

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The principal element of the selected remedy at the various AOCs is source control by
containment (capping). This element addresses the primary threat at the Site, contamination
of soil and migration of soil contaminants into surface and groundwater. The remedy does not
satisfy the statutory preference for treatment as a principal element. Treatment alternatives
evaluated in the Feasibility Study were not practicable, primarily due to cost. At one AOC
(the Contaminated Soils Area) a treatment alternative (in-situ solidification/stabilization)
was impracticable due to implementability (volume increase of treated material in an area
where an increase in volume would be problematic due to the area's use as an active rail
yard).

6. Five-Year Reviews of the Selected Remedy are Required.

Because this remedy will result in hazardous substances remaining on- site above levels that
allow for unlimited use and unrestricted exposure, a review will be conducted within five
years after initiation of the remedial action to ensure that the remedy continues to provide
adeguate protection of human health and the environment. In addition, Five-Year Reviews are
already reguired for the entire Iron Horse Park Superfund Site due to the prior initiation of
remedial action at Shaffer Landfill (0U2). The next Five-Year Review for Iron Horse Park is
due in September 2008.

N. DOCUMENTATION OF SIGNIFICANT CHANGES

The June 2004 Proposed Plan for Operable Unit 3 presented, for the Asbestos Lagoons AOC a
source control remedy (SC-2) consisting of excavation of asbestos containing material for
placement under the cap of a different on- site AOC. After further consideration, and upon
receipt of public comment, EPA has determined to select a different alternative for the
Asbestos Lagoons AOC, the source control remedy (SC-1) which consists of capping the material
in place. Both alternatives were considered and evaluated during the Feasibility Study and
were discussed in the Proposed Plan. Both alternatives are considered protective. The change
will provide some benefit with regard to the Short-Term Effectiveness criteria, in that
special provisions for handling and transporting asbestos containing material will be limited
significantly. Comments made on behalf of the BNZ Materials, Inc, the owner of the property
where the lagoons are located, also indicated a preference for capping and managing the
material within the same property.

There are no other significant changes from the alternatives presented in the Proposed Plan.
O. STATE ROLE

The Massachusetts Department of Environmental Protection (MADEP) has reviewed the
various alternatives and has indicated its support for many components of the selected remedy
as presented in the Proposed Plan. MADEP expressed concerns with the preferred alternatives
at two AOC's. At one AOC (the Asbestos Lagoons) MADEP indicated concern over uncertainties
related to the volume of material to be excavated for placement and capping at another AOC.
However, EPA is selecting the alternative whereby the lagoon material will be capped in place
(see Section N. Documentation of Significant Change, above). Because of this, excavation
volume will no longer be a concern. The other AOC where MADEP expressed concern with the
preferred alternative is the B&M Locomotive Shop Disposal Areas. MADEP expressed a preference
for the alternative (SC-2) which calls for excavation of material and placement under the cap
at another AOC, rather than capping in place ( SC- 1), as proposed. In its comments MADEP
suggests that the volume of material that would need to be excavated and therefore the cost
of the alternative, have been overestimated. The volume estimates were based on identifying
areas of fill utilizing terrain conductivity and ground penetrating radar surveys. There is a
good degree of confidence in the associated data, and therefore in the estimate of fill
volume that would need to be excavated. While the volume estimates are undoubtedly not exact,
they provide ample information to support a ROD cost estimate. Because of this, EPA does not
feel that it is necessary to renassess the cost estimate. An additional issue raised
concerns potential negative impacts to wetlands from the capping in place alternative. Due to
the proximity of wetlands to the B&M Locomotive Shop Disposal Areas, some wetland impacts are

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likely with either SC-1 or SC-2 alternatives. Normal construction safeguards, to minimize
wetland impacts during construction, as well as provisions for wetland restoration/
replication, will ensure that necessary wetland reguirements are addressed.

The State has also reviewed the Remedial Investigation, Risk Assessment and Feasibility Study
to determine if the selected remedy is in compliance with applicable or relevant and
appropriate State environmental and facility siting laws and regulations. The Massachusetts
Department of Environmental Protection concurs with the selected remedy for the Iron Horse
Park 0U3 Site. A copy of the declaration of concurrence is attached as Appendix A.

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PART 3: THE RESPONSIVENESS SUMMARY

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¦ r. '

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

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

MITT ROMNBY
Governor

KERRY HEALEY
Lieutenant Governor

ELLEN ROY HERZFELDER
Secretary

ROBERT W GOLLEDGK, Jr.

Commissioner

July 16, 2004

Mr. Don McElroy	RE: Proposed Plan. Iron Horse

US EPA, HBO	Park OU #3.

One Congress St., Suite 1100
Boston, MA 02114-2023

in
O
2


Dear Mr. McElroy:	o

o
n

5

The Department has reviewed the June 2004 Proposed Plan (the Plan) for Remedial Action at the
Third Operable Unit (OU #3) for the Iron Horse Park Superfund site in Billerica and is	0

submitting the following formal comments.	o

NJ

1) As the Preliminary Remediation goals (cleanup goals) for soils were not included in this	JS

i/i

Plan, DEP expects an opportunity to review and comment on them before the Record of Decision
(ROD) is made final.

2)	As stated on page 7 of the Plan, the proposal "presents cleanup approaches for soil
contamination only." The proposed remedy does not take measures to actively cleanup
groundwater as models predicted it would take a very long time (greater than 200 years) to
achieve cleanup goals for groundwater, even with source control measures. EPA states that
groundwater monitoring will be conducted and trends in contaminant concentrations evaluated.
If the groundwater is being monitored to determine whether it is technically impracticable to
achieve specific cleanup goals for groundwater, EPA should be conducting this monitoring as a
Remedial Investigation activity, not as part of the remedy for this Operable Unit. EPA will
then, at a later time, issue a decision document for groundwater.

3)	The Plan does not discuss the evaluation of the VOCs found in groundwater monitoring wells
adjacent to the asbestos landfill. DEP was previously informed that the source of VOCs would
be investigated during the design process for the Remedial Action. No mention has been made
of this in the Plan. The Department is concerned that the VOCs be investigated either during
the design process or during the investigation for OU 04.

This information is available in alternate format. Call Debra Doherty ADA Coordinator at 617-292-55656. TDD Service - 1-800-292-2207

DEP on the World Wide Web http//:www.mass.gov/dep
Printed on Recycled Paper

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Comments on the April Proposed Plan Draft
April 22, 2004
Page 2

4)	All of the preferred alternatives will require Institutional Controls to maintain the
effectiveness of the remedy and prevent future exposure to contaminants that will remain in
place at the Site.

Proposed Plan Source Control Cleanup Options

5)	Pending review of public comments, the DEP is in general agreement with the following
preferred alternatives.

B&M Railroad Landfill

The DEP agrees with the preferred alternative for the landfill, which includes capping the
landfill (SC-1).

RSI Landfill

The DEP agrees with the preferred alternative for the landfill, which includes capping the
landfill (SC-1) .

Contaminated Soils Area

The DEP agrees with the preferred alternative of capping in place (SC-1).

Asbestos Landfill

The DEP agrees with the preferred alternative of capping in place (SC-1).

Asbestos Lagoons

The DEP agrees with the preferred alternative of excavation of waste and capping elsewhere
on-site (SC-2). The FS stated that the Asbestos Lagoons would be excavated to a depth of 1
foot. Since soil was not sampled within the lagoons, it is possible that greater depths may
need to be excavated to remove the contamination.

Old B&M Oil/Sludge Recycling Area

The DEP agrees with the preferred alternative of capping in place (SC-1) as long as the cap
constitutes an engineered barrier as described under the Massachusetts Contingency Plan.
During historical investigations of this area, LNAPL has periodically been found. Although
cleanup goals have not been established for this OU yet, DEP considers NAPL thickness in
excess of H inch to constitute an exceedance of the Upper Concentration Limit (UCL). An
engineered barrier would be required if the NAPL were left in place without being fixated
(immobilized) and if it were less than 15 feet below the ground surface. DEP UCLs have been
incorporated as cleanup goals at Superfund sites in Massachusetts and we would expect them to
be incorporated into the ROD for this OU.

6)	B&M Locomotive Shop Disposal Areas

The RI described samples taken up to 12 feet deep with one isolated location containing
elevated levels of PCBs. The Feasibility Study discussed excavating the two areas 20 feet
deep. It does not seem likely that the entire 5 acres (both areas combined) needs to be
excavated to 20 feet. Perhaps just the "hot spot" where PCBs were detected needs to be
excavated. The volume should be recalculated. It may be that excavation and capping elsewhere
on-site wi] I be a better remedial action than capping in place.

The DEP would prefer that the two areas be excavated (SC-2) rather than capped (SC-1). From
discussions held during the preparation of the Feasibility Study (FS) , it appeared that
excavating these areas was more appropriate due to the engineering difficulties with capping
being so close to the man-made canal and/or wetlands. The preferred alternative calls for
capping in place. Due to engineering issues, DEP believes that the Locomotive Shop Disposal
Areas should be excavated and placed under one of the on-site caps (RSI Landfill) rather than
being capped in place.

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Comments on the April Proposed Plan Draft
April 22, 2004
Page 3

DEP appreciates the opportunity to submit formal comments on the Proposed Plan for Operable
Unit #3 of the Iron Horse Park Superfund Site. We look forward to your response to our
comments.

Sincerely,

Janet S. Waldron
DEP Project Manager

e-file: 4.09 Proposed Plans for Selected RA/Proposed Plan Formal Comments

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2/37

Johns Manville

A Berkshire Hathaway Company

life-..
Otiier:

	y -y

f'	•' J	/	.



Bruce D. Ray

Associate General Counsel
717 17'" Street (80202)
P O Box 5108
Denver, CO 60217-5108
303 976-3527
303 978-2632 Fax
ray0@jm com

VIA ELECTRONIC MAIL: mcelrov.don@epa.gov
Don McElroy

Remedial Project Manager

U.S. Environmental Protection Agency

Region I (HRO)

1 Congress Street

Suite 1100

Boston, Massachusetts 02114

Re: Proposed Plan for Iron Horse Park Superfund Site; Asbestos Lagoons

Dear Mr. McElroy:

The purpose of this letter is to provide comments on the Proposed Plan for the Asbestos
Lagoons area of concern at the Iron Horse Park Superfund Site.

Specifically, it would seem that the cost estimated for the on-site capping option is
significantly too high. Based on Johns Manville's prior experience, effective asbestos
settling basin caps cost in the range of $30,000 to $50,000 per foot of thickness per acre.
If the asbestos lagoons are approximately three acres and a three-foot thick engineered cap
is necessary, the total cost of on-site cap should not exceed $450, 000 (3*3*$50, 000) .
Construction and agency oversight along with safety and other costs could increase this by
$100,000 for a total of $550,000 but certainly not the $2,900,000 referenced in the proposed
plan.

Given that the remedial action objective here is prevention of exposure to lagoon-related
asbestos and because asbestos, unlike dissolved substances, does not migrate in groundwater,
the better alternative would be to install an effective cap on the lagoons.

If you have any guestions concerning this matter, please do not hesitate to call me.

Sincerely,

Bruce D. Ray
Associate General Counsel

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WILMER CUTLER PICKERING	. ; V . J, -

HALE AND DORRu,	t	^

Via Email and First Class Mail
August 13, 2004

Robert F. Fitzpatrickjr.

60 STATE 5TR£ET
BOSTON. MA 02109
" 617 526 6362
-I 617 526 5000

Donald McElroy
Remedial Project Manager

U.S. Environmental Protection Agency	rTjberiftipjtnckewilrnwtuiecorn

Region I, (HBO)

1 Congress Street, Suite 1100
Boston, MA 02114

Re:	Comments on EPA's Proposed Plan For Lagoons At

Operable Unit 3 of the Ironhorse Park Superfund Site

Dear Mr. McElroy:

This letter and the enclosed letter from BNZ's consultant, ESS Group, Inc., are the comments
of BNZ Materials, Inc. ("BNZ") on EPA's proposed plan for the lagoons in Operable Unit 3 of
the Iron Horse Park Superfund Site (so-called "Area of Concern 7").



O
o

o

EPA has proposed excavating the lagoons and transporting the excavated material to the B&M
landfill for disposal under an expanded cap. The lagoons are located on BNZ's property on
High Street. BNZ acguired this Property from Johns Manville in 1987. BNZ has never used or	o

manufactured products containing asbestos. Johns Manville, not BNZ, used the lagoons for the
disposal of asbestos slurry.

EPA should reconsider its proposed lagoon remedy. For the reasons described in ESS' letter,
managing the lagoons in place rather than excavating and transporting the excavated material
to the B&M landfill will produce a faster, less expensive and more protective remedy during
construction.

BNZ is a small company with limited resources. Reducing the cost and logistical complexity of
the lagoon remedy consistent with ESS's comments will yield a remedy that can be more readily
implemented.

Nothing in this letter or ESS' letter is or should be construed as an acknowledgment or
admission of any fact or liability. BNZ reserves all rights and defenses.

BALTIMORE BERLIN BOSTON BRUSSELS LONDON MUNICH
NEW YORK NORTHERN VIRGINIA OXFORD PRINCETON WALTHAM WASHINGTON

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Donald McElroy
August 13, 2004
Page 2

Please let me know if you would like to discuss BNZ's comments.

Very truly yours,

RFFj r.cmd
Enclosure

cc:

Mr. Josh Hulce

Peter E. Nangeroni, P.E., LSP

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Engineers
Scientists
Consultants

August 13, 2004

Mr. Don McBroy

Remedial Project Manager

U.S. Environmental Protection Agency

Region I (HBO)

1 Congress Street, Suite 1100

Boston, Massachusetts 02114-2023

888 Worcester Street
Suite 240
Wellesley
Massachusetts
02482

p 781.431.0500
f 781.431.7434

Re: Formal Comments on Proposed Man - Operable Unit 3, Iron Horse Park
Superfund Sfte^ North BUtorlca, MA
ESS Project No. BS4S-000

Dear Don,

ESS Group, Inc., (ESS) is providing these Formal Comments on the Proposed Plan for
Operable Unit 3 at the Iron Horse Park Superfund Site on behalf of our client, BNZ Materials,
Inc Our comments are focused on the lagoons (Area of Concern 7) since our dient has had
no Involvement in any other portion of the Iron Horse Park Superfund Site.

With respect to the lagoons, the proposed remedy (SC-2) calls for the excavation of
approximately 15,200 cubic yards of what EPA presumes to be asbestos containing soil, with
an assumed average depth of asbestos containing soil in the lagoons of 5 feet The excavated
soli would then be trucked to the B & M Landfill (Area of Concern I) and placed under the cap
of the B & M Landfill. The lagoon excavations would then be backflSed wfth 1 foot of dean son
followed by 6 Inches of topsoil and seeding. The oost estimate Ihdudes provisions for dust
control, dewatering and a modest allowance (approximately $2.13 per cubic yard of soil) for
"Cap Expansion" to address Incremental costs of capping the B & M Landfill.

An alternative remedy considered by EPA for the lagoons (that provides the same level of
protection as remedy SC-2) is capping the lagoons in place (SC-1) combined with land use
restrictions and monitoring. EPA apparently eliminated this option since its cost of $2.90
million was approximately $1 million higher than remedy SC-2. The cost estimate for the
lagoon capping remedy was based on the use of single barrier cap with an overall thickness of
30 indies and Induded a 60 mil Low Density Polyethylene Geomembrane and the requisite
Drainage Composite layer. The estimate also assumed that the cap would extend over the
current footprint of the 3 lagoons and that approximately 21,000 cubic yards of granular fill
would be required to provide an adequate slope (5%) on the lagoon cap.

GENERAL COMMENTS:

The selection of remedy SC-2 for the lagoons requires that the lagoon work be coordinated
with and Integrated into the B & M Landfill capping, which lr» turn wffi likely be coordinated
with the work at the remaining Areas of Conoern (AOC5). This approach will be much slower
than In-ptoce closure of the lagoons, which can be accomplished independent of the planning
or Implementation of work at the other AOCs. EPA's proposed approach also significantly
Wndens BNZ's ability to plan for and implement a program geared towards the benefldal re-
use of the lagoon area since BNZ will have no control over the project



j:\U34frti00 Dm	pp comments epa.doc

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Don MOEIroy
August 13, 2004

¦Hie Plan should provide for an in-place capping approach for the lagoons that Is planned and
Implemented separately from the work at the other AOCs in OU-3. The in-place capping
approach would protect human health and the environment and would be consistent with
ARARs, inducing MADEP's Draft Asbestos In Soil Streamlining Regulations and Management,
Policy and Technical Support Document (February 2, 2004XDraft MADEP Policy). This
approach will allow BNZ to plan for and implement a cost-effective benefidal reuse plan for
the lagoon area that Is consistent with the goals of EPA and MADEP. BNZ is currently
evaluating redeveloping the lagoon area for recreational vehicle and boat storage. Of the
viable options identified by the EPA (SC-1 and SC-2), in place capping approach (SC-1) would
be most protective to site workers and local residents during construction due to the more
limited asbestos handling.

Capping the lagoons in place would be less expensive than excavating and transporting
material from the lagoons to the B & M Landfill. The primary reason for the high cost of the
lagoon capping option under the EPA's analysis is the cost associated with providing 21,385
cubic yards of dean fill required for slope/grading purposes. This material represents about
$400,000 of EPA's $1.1 mifllon base estimate. A more cost effective approach would be to
consolidate the lagoons prior to capping, thereby reducing the cost for imported fill material.
The components of the low permeability barrier represent another $236,000 of EPA's base
estimate. ESS does not agree that a low permeabitty barrier is required for the lagoons.

In addition, the types of property reuse currently being evaluated would further reduce
capping costs by $85,000 or more. This would be accomplished by incorporating pavement
into the cap thereby eliminating the need for the hydroseed, topsofl, and a part, if not the
entire proposed 24-Inch thick cover soil layer. This would lead to additional costs savings of
$85,000 to $230,000. This estimate is based upon a planning price provided by a local
contractor to place 3-inches of asphalt over 8 to 12 Inches of bedding at the site. In
summary, the cost estimate for SC-1 is believed to over state the costs required to cap the
lagoons in a manner that is protective of human health and the environment and by
incorporating reuse options Into the In place dosure option, additional costs savings can be
achieved.

SPECIFIC COMMENTS:

1.	Operable Unit 3 attempts to simultaneously address seven unique AOCs that are quite
distinct and dearly represent separate potential source areas. In fact, EPA in Its
September 24, 2003 Five Year Review Report states in section n that '...each potential
source area In OU3 is unique...". Property owners should be allowed to address AOCs that
are self contained on their property on an Individual basis. This approach would lead to
more efficient and timely Implementation of the remedies, whfle providing property
owners more opportunity to consider and Implement beneficial re-use of their property.
For a property owner to develop and implement a re-use plan, they need the highest level
of certainty and control over remedation costs and schedule. Under the remedy proposed
by the EPA, BNZ would have to coordinate their re-use efforts with remediation of the B &
M Landfill The B & M Landfill has a number of technical and regulatory challenges (e.g.
removing waste from wetlands) that add significant uncertainty to costs and schedule.
These uncertainties would be eliminated If the lagoons were managed on the BNZ
property, thereby enhandng the ability to effectively re-use the BNZ property.

2.	The selection of remedy SC-2 over SC-1 was apparently made based primarily on cost
since both approaches provide similar levels of protection to human health and the
environment Given the uncertainty in the cost estimates and the desire of BNZ to more

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Group, toe.

Don McElroy
August 13. 2004

directly control work on their property, the Plan should provide for implementation of an
approach similar to option SC-1, because it is as protective to human health and the
environment, as compliant with ARARs as predicted by the EPA's Feasibility Study and
otherwise more beneficial than option SC-2 based upon cost-effectiveness and ability to
support property reuse.

3.	The Proposed Plan states on page 4 that there are "risks from asbestos at two of the
areas". The data and analysis presented in the Remedial Investigation (RI) do not
support this statement with respect to asbestos containing soils that may be present in
the lagoons. There has been no quantitative risk assessment performed to confirm that
the asbestos containing soils present in the lagoons present a current or future risk to
human health or the environment.

4.	The Proposed Plan recommends excavating the contents of the lagoons and trucking the
contents to the B & M Landfill for disposal under the cap of the B & M Landfill (option SC-
2). The Feasibility Study (FS) and Proposed Plan do not take into consideration the
potential short term risk associated with the excavation, handling, trucking and re-
deposition of asbestos containing soils. In many instances leaving unconsolidated
asbestos fiber containing soils or materials in place and minimizing the handling of the
materials presents less risk than the potential risk posed by generating airborne asbestos
during excavation, trucking and re-deposition of asbestos containing soils. The Draft
MADEP Policy acknowledges that leaving asbestos containing materials in place will avoid
asbestos releases and potential exposures, if re-use plans for the property allow the
material to remain in place.

5.	The Proposed Plan includes a low permeability cap in the alternative that was considered
for the in-place capping of the lagoons (option SC-1). The data presented by EPA in the
RI does not indicate that a low permeability cap is required for the lagoons since a)
asbestos is known to be insoluble and therefore would not require a low permeability cap
as exemplified by the cap design used for the Asbestos Landfill, b) there is no current risk
posed by the groundwater in the vicinity of the lagoons, and c) even if there is a potential
future risk associated with the groundwater, there is no identified correlation between the
contents of the lagoon and the metals detected in groundwater in the vicinity of the
lagoons which drive the risk assessment.

6.	The evaluation of the on-site capping option should have considered consolidation of the
lagoons to reduce overall capping requirements and costs. For example, if the 5% slope
assumed by EPA for option SC-1 is required for the cap, the contents of one lagoon could
be used as fill material on the adjacent lagoon rather than importing fill for use in grading.
This approach would reduce costs by reducing the amount of imported fill required and by
creating a smaller cap footprint, thereby reducing capping and long term maintenance
costs. Lagoon consolidation and in-place capping should be included as a viable option for
the lagoons in the Plan.

7.	Consideration should be given to an in-place capping approach for the lagoons that
includes the beneficial re-use of the lagoon area such that the capping could be
incorporated into the future site use, thereby potentially reducing capping costs and
generating revenue for the long term maintenance of the cap. The use of an asphalt cap
or construction of a building over the lagoons, for example, which are both included as
presumptive remedies in the Draft MADEP Policy, would provide a multi-purpose benefit
for the lagoon closure and re-use of the lagoon area.

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Don McElroy
August 13, 2004

Gram Inc.

8.	In consideration of comment number 4 above, it is not apparent in the cost estimate
backup in the FS for the recommended option SC-2 that sufficient allowances are provided
for dust control and monitoring during the excavation, loading, transport, and placement
of the lagoon materials.

9.	The "cap expansion" allowance of $32,500 in the recommended remedy (SC-2) for the
lagoons does not accurately reflect the true cost of incorporating the excavated solids into
the B & M Landfill based upon our experience. There is also uncertainty associated with
the vertical extent of materials that would be removed from the lagoons and the type of
post-excavation surface restoration and land use controls that will be required. The fact
that remediation goals for unconsolidated asbestos fibers are not established in the
Feasibility Study further increases the uncertainty associated with excavating this material.
This may lead to significantly higher restoration costs than included in the cost estimate.
Therefore, it is likely that the actual costs would be greater to manage the lagoons
materials at the B&M Landfill than to manage the material in place.

10.	The placement of the excavated lagoon material under the B&M Landfill cap in the
recommended remedy (SC-2) will increase the impacts to wetlands and the floodplain in
the vicinity of the B&M Landfill by increasing the volume of material to be placed in the
landfill. The in-place capping of the lagoons (remedy SC-1) will have no impact on
wetlands or floodplains.

11.	A number of action specific asbestos management related ARARs are identified for the
work associated with implementing the recommended remedy (SC-2) at the lagoons. By
transporting the asbestos containing soil to the B&M Landfill many of these ARARs would
also apply at the B&M Landfill AOC. The FS does not identify asbestos related ARARs for
the B&M Landfill AOC and the asbestos is not identified as a contaminant of concern. It
appears this has caused an under-estimation of the level of effort and costs for disposing
the excavated lagoon material at the B&M Landfill.

Thank you for your consideration of these comments. If you should have any questions

please contact Peter Nangeroni at 781-489-1106.

Sincerely,

ESS GROUP, INC.

Peter E. Nangeroni, P.E., LSP
Senior Vice President

Michael S. Gitten, P.E., LSP
Vice President

C: Robert F. Fitzpatrick, Jr., Esq.

Q*B

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1

1-13

UNITED STATES OF AMERICA
ENVIRONMENTAL PROTECTION AGENCY

BOSTON REGION

In the Matter of:

PUBLIC HEARING:

RE: PROPOSED CLEAN-UP PLAN FOR OPERABLE UNIT 3 AT THE
IRON HORSE PARK SUPERFUND SITE

Billerica Town Hall
Room 210
365 Boston Road,

Billerica, Massachusetts

Wednesday
June 16, 2004

The above entitled matter came on for hearing,

pursuant to Notice at 8:15 p.m.

BEFORE:

ROBERT CIANCIARULO, Chief
Massachusetts Superfund Section
DON MCELROY, Remedial Project Manager
STACEY GREENDLINGER
EPA, Region 1

1 Congress St., Suite 1100
Boston, MA 02114-2023

Other:	T

.... ———

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INDEX

SPEAKERS:	PAGE

David Johnson	5

Joanne Giovino	6

Barbara Morrissey	7

A1 Ramos	8

Judy Lieberman	8

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1	PROCEEDINGS

2	MR. CIANCIARULO: Good evening. I'm Bob

3	Cianciarulo. I am Chief of the Massachusetts Superfund

4	Section at EPA, and I'll be the Hearing Officer for

5	tonight's hearing on the proposed clean-up plan for what's

6	called Operable Unit 3 at the Iron Horse Park Superfund

7	site.

8	As Stacey and Don mentioned, the purpose of this

9	hearing is really to get your comments formally on the

10	record so your voice can be heard on this clean-up proposal.

11	As Don outlined earlier in the meeting, community acceptance

12	is one of the nine criteria we use set forth by the

13	Superfund law. We use those to select a clean-up plan.

14	It's a critical part of our decision-making process.

15	Again, as noted earlier, and in the proposed plan

16	at the back of the room, the public comment period

17	officially begins today, and it's scheduled to run 30 days,

18	to July 16th. You've heard this, and this will be the fifth

19	time you've heard this, as far as how you can make a

20	comment. There's no obligation to sort of make an oral

21	comment here. This is really, hopefully, a matter of

22	convenience to the extent that you don't want to otherwise

23	submit written comments either by mail, by fax or by email

24	all to Don's attention. And those addresses and phone

25	numbers are in the proposed plan. So you can comment orally

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1	today and in writing, or in writing, your choice.

2	We'll be transcribing the meeting, as we

3	discussed, and we'll produce a printed transcript which will

4	make part of the record. That will go in the library with

5	the other materials we discussed earlier. And we'll also

6	then be responding to comments that we receive on the

7	proposed plan in what's called a responsiveness summary that

8	we'll publish in conjunction with our Record of Decision.

9	The hearing process is rigid, and I hope it's not

10	too frustrating. We will be accepting your comments. It

11	won't be a dialogue. We won't be responding to them

12	verbally. So don't take it out on me if you ask a bunch of

13	guestions and I say thank you. Because really, again, this

14	process is get your comments formally on the record.

15	I'd ask when you do come up and make a comment,

16	you state your name, address, and affiliation, if any, also

17	for the record. I'm going to try to limit people to five

18	minutes each, just to make sure that everybody who wants to

19	make a formal statement does so.

20	And again, we'll make ourselves available at the

21	close of the meeting to the extent there is additional

22	guestions and answers, more informal dialogue you'd like to
2 3 have.

24	So to the extent that people have signed up at the

25	back or, you know, we can sort of, in an orderly fashion,

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1	figure out who wants to make -- who wants to be first. And

2	it may not be necessarily again if you're just stating your

3	name and address. It's a small enough crowd. Just as long

4	as someone's willing to break the ice.

5	MS. GREENDLINGER: Do you want to go first? You

6	can feel free to go first.

7	MR. CIANCIARULO: Okay, I need you to just stand

8	up there.

9	MR. JOHNSON: Okay. Do I hit you?

10	MR. CIANCIARULO: Not yet.

11	MR. JOHNSON: Not yet, okay. I talked to you

12	earlier, Don, about the proposed clean-up and how to

13	determine the effectiveness of the clean-up, and also, to

14	assess what is going to be done of the plan. To do that,

15	would like to have on-line access to all of the ground

16	water, surface water, sediment and air monitoring results

17	that are taken at this site. And I'd also like to have it

18	for -- instituted for all of the other sites that are

19	included in this overall Iron Horse Superfund Park. That's

20	my comment, and I feel that the plan needs to include making

21	that information available on line, both now, and as part of

22	the ongoing maintenance.

23	Oh, my name is David Johnson, and it's 113 Gray

24	Street, Billerica. And soon to be, I'm affiliated with the

25	Earth Watch Coalition. Thank you.

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1

MR. CIANCIARULO: Okay, thank you. All yours.

2 You can stand on either side.

3

MS. GIOVINO: Dangerous to give me a mike -- No,

4 I'm kidding.

5

MR. CIANCIARULO: Again, if you could, name and

6 address.

7

MS. GIOVINO: Yes.

8

MR. CEANCIARULO: And maybe you want to stand

9 facing everyone else.

10

MS. GIOVINO: All right, Joanne Giovino, 10

11	Eastview Ave., Billerica; President of the Earth Watch

12	Coalition, which is the organization that has been the

13	liaison with the EPA over these last 22 years. We were

14	formerly known as the Superfund Action Committee, which we

15	will soon be going back to the Superfund Action Committee.

16	And we have received technical assistance grant money. And

17	Dave Johnson is a member. Barbara Morrissey and Helen

18	Knight are the core members. And these are the people that,

19	for the rest of you who are here, we are the people for 22

20	years that have bean working to see that this is taken care

21	of properly.

22	My comment is, in looking at the matrix for the

23	proposed options, I would like to see, on the mobility and

24	toxicity and volume -- but primarily on the mobility - I

25	would like all the areas that are to be capped to have the

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1	EPA determine the depth to the high seasonal water

2	elevations, and develop a matrix indicating the contaminants

3	and the mobility rate, and then the cost so that EPA could

4	make a determination whether, in some instances, if there's

5	a high mobility rate of particularly onerous contaminants,

6	that it may be very well worth it to then examine options or

7	methods of installing a non-porous liner in the bottom and

8	the sides.

9	MR. CIANCIARULO: Okay, thank you. Others?

10	MS. MORRISSEY: My name is Barbara Morrissey. I

11	live at 10 Sumac Street. I'm also a member of Earth Watch

12	Coalition. And I just want to basically say ditto to what

13	Joanne said. Many of the problems with the Superfund site

14	that we have in town is that it is in a wetland area. And

15	because of that, even if something may not be mobile during

16	a dry or a drought-type season, whenever there is any heavy

17	rain, those areas flood dramatically. I live near there. I

18	see the flooding.

19	So there is going to be a sponge effect. There

20	will be mobility. There is no way, when the water does go

21	up into the mounds of these landfills that are going to be

22	created, that it will not be giving the contaminants the

23	ability to move, and possibly to go to another area in town.

24	And I do want to see every effort made to contain this by

25	putting some type of a liner in there. Thank you very much.

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1	MR. CIANCIARULO: Okay, others? You can be next.

2	No? Has everyone made a comment for the -- Oh, would you

3	like to? Sure.

4	MR. RAMOS: My name is A1 Ramos. I live at 39 Mt.

5	Pleasant Street, and I have no affiliation. I just live in

6	the neighborhood. And my only comment is I'd like somebody

7	to somehow do like a definitive study on the cancer rate

8	because I've only lived here ten years. But talking to

9	long-term neighbors, they said there is clusters,

10	apparently, of cancer in the area. And that's extremely

11	important. And two neighbors within about five houses of

12	me, both in their 40s and 50s, one has succumbed, and the

13	other one is not doing very well at all. And the one that's

14	not doing very well at all, he basically never smoked, never

15	drank, and he has throat cancer. And he's lived there about

16	25 years. So this brings that into guestion. And I've got

17	three little children. So that's one of the biggest

18	concerns that I have.

19	And, yeah, just basically, if somebody could

20	conduct a definitive study. And I know there's a lot of

21	analysis and stuff. But maybe it'll speak for itself if the

22	data, if it's real obvious, you know, so better decisions

23	can be made on the priority of the fund. Thank you.

24	MR. CIANCIARULO: Thank you.

25	MS. LIEBERMAN: My name is Judy Lieberman, and I

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1	live at 201 High Street. And I'm getting up basically

2	because of what you just said about people coming down with

3	cancer. I own horses. And back in 2001 -- and I take very

4	good care of my horses. Actually, I take better care of

5	them than I do myself. And I experienced some very strange

6	happenings in my stable with my animals.

7	I went out one evening. It was in December of

8	2000. And my horses were bleeding around the coronary

9	bands. It's where the hoof and the ankle meet. My horses,

10	you know, they didn't have thrush, or they didn't have any

11	other, you know, ailments, any, you know, horse-related

12	diseases or anything like that. They were gust bleeding

13	around the coronary bands. And also their argots. It's

14	another little piece of skin up above their knee. And all

15	of my horses had the same symptoms. I've never seen

16	anything like it. I've had horses for over 30 years.

17	I called my veterinarian. And he said, you know,

18	obviously, they either ingested some kind of a toxin --

19	whether it was from the soil, the feed or, you know,

20	something aerial. I did call the EPA, and eventually, I had

21	them come out. At first, they were a little reluctant to

22	come out. And then I said that I would call Christine Todd

23	Whitman, and they came out within two weeks, and we started

24	to do a study.

25	I also consulted with some veterinarians that are

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1	hired by the United States government because I'm a member

2	of the United States Equestrian Team. And I got some very

3	good advice from them. And they said it was definitely some

4	form of a poisoning or something.

5	When the EPA came out, they did some testing.

6	They did everything but water samples in my yard, which I

7	did request them to do. The only thing that they did was

8	inside the barn, they tested my shavings. We did some feed

9	testing. Everything, you know, came back within, you know,

10	a normal range. I do have the results here. Some of the

11	results did come back inconclusive. And I haven't been able

12	to complete my study with the EPA yet on all of the

13	findings. I'm still working on it.

14	But something happened in 2001. It is on the

15	Internet. If you, you know, just type in Judy Lieberman,

16	North Billerica, the Republican Committee, which I'm on,

17	you'll find that I did do this study. And again, the

18	results are inconclusive. I'm still working on it.

19	I also have a suspicion about the biological

20	pellets that they've been dropping for the West Nile Virus.

21	I've been working with some agents from the EPA. Dan Granz

22	is one of them, and Amy Jane Lussier, who is with Region 1

23	in Boston, and a couple of other United States federal

24	agents from Washington, D.C.

25	I don't have all of the results back from the

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1	study. But I just wanted to let the residents know that I

2	am working on this. I don't know what happened. I don't

3	know if there's any connection to Iron Horse Park, or if

4	there is actually something else that's going on in the

5	environment in North Billerica. But obviously, there is

6	something going on. And just for the record, I wanted to

7	let you know. If you have any -- I'm a little bit nervous

8	right now. I apologize. I'm not really a good public

9	speaker. But I have a lot of information, and I have a got

10	of good resources. And I'm in contact with chemists and

11	biologists and veterinarians from all over the country. And

12	I can guarantee you that I will get to the bottom of this,

13	and I'll find out what happened.

14	As a matter of fact, I wanted to mention for the

15	record, my problems escalated right before the terrorist

16	attack in September. My horses were bleeding extensively

17	around the coronary bands, and I just went into a frenzy, a

18	complete panic. And I thought, even before I heard about,

19	you know, the terrorist and, you know, what they were -- I

20	had no idea what was going on, but I knew something was

21	going on. And the EPA was made aware of this well in

22	advance. And that has been documented, and I have

23	everything on record. So residents, you're more than

24	welcome to contact me and look at anything that I have. And

25	that's all I have to say for right now. Thank you.

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1	MR. CIANCIARULO: Anyone else who would like to

2	make a comment for the record tonight? Hearing none -

3	Again, if there's no one else who wishes to make a

4	statement, I'm going to close the hearing. Again, the

5	public comment period begins today, a 30-day comment period.

6	Please make sure you have a copy of that proposed plan, and

7	you can respond in writing, U.S. Mail, fax or email to Don

8	McElroy, and Don's phone number is there, as well. So thank

9	you. Thank you for attending. Again, thank you for your

10	participation here today, and your interest in this site,

11	and your assistance in helping us make a final decision on

12	this clean-up plan. Thank you.

13	(Whereupon, the proceedings were concluded.)

14

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CERTIFICATE OF REPORTER AND TRANSCRIBER
This is to certify that the attached proceedings
in the Matter of:

RE: PROPOSED CLEAN-UP PLAN FOR OPERABLE UNIT 3 AT THE
IRON HORSE PARK SUPERFUND SITE

Place: Billerica, Massachusetts
Date: June 16, 2004

were held as herein appears, and that this is the true,
accurate and complete transcript prepared from the notes
and/or recordings taken of the above entitled proceeding.

Suzanne French
Reporter

Patricia Nellicran
Transcriber

June 16. 2004
Date

July 8. 2004
Date

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Robert Stanton



08/05/2004 12:04 PM

To: Don Mcelroy/R1/USEPA/US@EPA
cc.

Subject: Iron Horse Park Clean up Plan

Dear Mr. McElroy,

I received a copy of the proposed clean up plan for Iron Horse Park.
Unfortunately I was unable to attend your meeting back in June. I think it's
great that there is a concerted effort to "clean" this site up. However, I do
have some comments I would like to share...

First, I am concerned about the recent expansions of existing companies
currently in the Iron Horse Park site such as McQuesten Lumber Co. They
recently expanded in the former Penn Culvert property. This expansion includes
a large storage shed/building and paved parking throughout this site which
appears to be located on top of the Old B&M Oil/Sludge Recycling Area.
Associated with this expansion is an increase of tractor trailor activity. How
does this coincide with clean up efforts or is paving over certain areas and
letting companies expand the answer?

A recent trip through the "Park", I noticed many abandoned MBTA buses stored
next to the large B&M building. Why are they now parking such vehicles there
and what impact (oil, antifreeze, transmission fluid) will this have on clean
up efforts?

Second, as a resident of the area, how can I be assured that the current
companies are not contributing to the problem at hand. A lot of vehicles both
active and inactive, exposed wood products, general waste and by products of
other companies currently operating there. Is the EPA monitoring these
companies? Seems to me that a superfund site should reduce such activities not
increase.

Sincerely,

Robert J. Stanton
7 Whitegate Rd.

Billerica, Ma. 01862
Email: rbtstanton@msn.com
Phone: (978)663-5160

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7 Oxford Road

North Billerica, MA 01862

June 17, 2004

Mr. Don McElroy
Remedial Project Manager
U.S. Environmental Protection Agency
Region 1, (HBO)

1 Congress Street, Suite 1100
Boston, MA 02114

RE: Iron Horse Park
Superfund Site

Dear Mr. McElroy:

I read your brochure about the proposed cleanup of Iron Horse Park, Superfund
Site, in North Billerica, with great interest. My home is within a close
proximity to Iron Horse Park. The Middlesex Canal is right behind my house.
The water in the Canal does not flow as it should due to a dam in Iron Horse
Park. My guestions are as follows:

1.	After the cleanup, will the Canal water be allowed to flow through
Iron Horse Park as it should?

2.	Will the "Superfund Site" name be removed?

3.	Will the neighbors still have to disclose that the homes are located
near the "Superfund Site" when selling their homes?

4.	Should people in the area be concerned about planting vegetable
gardens? Is the ground water in the area contaminated?

Thank you for your attention to the problems at Iron Horse Park. I do hope to
hear from you on the above issues.

Thank you.

Hrc-'.
Olhcr:

Jeanne LeGallo

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Responsiveness Summary - Comments

PRP Comments

1)	The preferred alternative for the Asbestos Lagoons (excavation and placement of material
under the cap at another AOC) is more complicated and will take longer to implement than
capping in-place. The preferred alternative hinders the owners ability to plan for and
implement beneficial re-use of the lagoon area. The property owner should be allowed to
address this self-contained AOC. This would be more efficient and would allow the owner more
opportunity to consider and implement plans for beneficial re-use of their property. Of the
alternatives proposed, EPA should choose SC-1. It would provide more short-term
protectiveness to workers and residents due to less handling and transport of asbestos
containing material.

EPA agrees that excavation of material for placement at another AOC may add additional
complication and potentially higher short-term risk to workers and residents. In part because
of comments received during the public comment period, EPA is selecting SC-1, capping in
place. Additional explanation is provided in Section N. of the ROD. EPA is of the opinion
that beneficial reuse of the lagoon area would be easier if asbestos containing material was
no longer present in the lagoon area. However, the lagoons are all on one property, the two
alternatives in guestion (SC-1 - capping in-place and SC-2 - excavation for placement at
another AOC) are both considered protective of human health and the environment and the cost
estimates for the alternatives do not differ greatly. Therefore it is reasonable to attempt
to accommodate the preference of the property owner and allow the material to be capped in
place.

2)	For the Asbestos Lagoons AOC, EPA has overestimated the cost of capping in-place, and
underestimated the cost of excavation for placement at another AOC. There are more cost-
effective means for capping in-place. Capping in-place would be less expensive than the
excavation option.

While EPA does not agree with the commentor's assessment with regard to cost, we have chosen
Alternative SC-1, capping in place. Specific issues related to design, construction and cost,
can be resolved during the remedial design process.

3)	A low permeability layer is not warranted at the Asbestos Lagoons, because; there is no
risk associated with groundwater, and there is no correlation between contaminants in the
lagoons and associated impacted groundwater.

EPA does not agree with the comment. While this ROD does not address groundwater remedies,
it does address source control issues. As documented in the RI, a risk assessment was
conducted for groundwater. There is groundwater risk associated with the Asbestos Lagoons
area. In addition, there are a number of contaminants, including: xylenes, arsenic,
manganese, barium lead, chromium and zinc, which are present in both the lagoon sediment as
well as in groundwater associated with the Asbestos Lagoons AOC. These contaminant results
are also documented in the RI.

4)	No quantitative risk assessment was performed to support the statement that asbestos in
the lagoons presents a current or future risk to human health or the environment.

Risk from exposure to asbestos can be guantified when the concentration of asbestos fiber in
air is known. The amount of asbestos in soil that may become airborne can vary depending on
activities occurring at a site under current or future land use. Methods for guantifying
these amounts are under development. Because of the difficulties in guantifying the amount of
asbestos fiber that may become airborne, EPA has relied on its definition of asbestos-
containing material in determining whether potential risk exists in past decisions. EPA's
National Emissions Standards for Hazardous Air Pollutants defined material with 1% or greater
asbestos as asbestos- containing material. Recent information indicates that the 1% threshold

-------
definition may not be conservative enough in assessing human health risks.

Since methods for guantifying risks associated with asbestos fibers in soil that may become
airborne are still under development, EPA has conservatively assumed that asbestos material
that has been identified as still present in the lagoons may potentially pose a risk.

5) The preferred alternative (for the Asbestos Lagoons) will increase impacts on wetlands and
the floodplain by increasing the volume within the B&M Landfill.

EPA has selected the alternative SC-1, capping in-place, for the Asbestos Lagoons, therefore
there will be no increase in volume of the B&M Landfill from Asbestos Lagoon material.

Comments from the public

1)	Concern was expressed regarding the perceived expansion of companies and activities within
Iron Horse Park, (the Cooperative Reserve property - formerly Penn Culvert was specifically
referenced). How does this expansion coincide with cleanup efforts.

A historic Superfund problem has been that properties associated with superfund sites, have
often been left unused or under-used even when this was not warranted due to contamination on
the property. One of the goals of the Superfund program is land/ property re-use. In other
words, taking cleanup actions necessary to allow for some desired future use, whether
restricted or unrestricted. An unrestricted use is typically a property which has achieved a
level of cleanup such that it would be appropriate for residential use. Under commercial or
industrial uses (where perhaps a worker is present on site for a limited number of days a
year and no children or other sensitive populations are present) some levels of residual
contamination may still be considered protective, while those same levels of contamination
would not be considered protective in a residential setting (where children, for example may
play on the ground and use the site for a much longer period of time during the year).

At Iron Horse Park, Cooperative Reserve, Inc. has purchased property from Penn Culvert and
has been improving the property for its lumber business. While this property was not unused
previously, it is certainly being used more now. This activity and these improvements are not
in opposition to the cleanup efforts at Iron Horse Park. Companies may utilize superfund
sites as long as they don't interfere with the remedy, contribute additional contamination,
or create a situation where site contamination is released into the environment. If a company
were to carry out any of these actions on a site they would risk incurring liability under
CERCLA and being named a responsible party for the cost of the entire Superfund remedy.

2)	How can it be assured that the activities of current companies (vehicle storage, exposed
wood products, general waste) are not contributing to the problem? Is EPA monitoring these
companies? A Superfund Site should reduce activities such as these.

See previous comment concerning actions by companies that might incur Superfund liability.
EPA and its contractors, along with the State, will be active on the Site during the remedial
action period and may be in a position to observe any potential problems with the operations
of the companies operating within the Site.

3)	The Middlesex Canal does not flow as it should due to a dam within Iron Horse Park. After
the cleanup will the Canal water be allowed to flow as it should?

The only dams that EPA is aware of in the Middlesex Canal have been beaver dams. At this
time, based on EPA's knowledge of the Site to date, the beaver dams and any cleanup
activities are unrelated. Any future remedial action concerning surface waters at the Site
will be addressed under 0U4.

4) Will the "Superfund Site" name be removed?

-------
Iron Horse Park was listed on the Superfund National Priorities List (NPL) in 1984. Sites are
not eligible for deletion from the NPL until all cleanup activities are completed and
Remedial Action Objectives have been achieved. Therefore, EPA cannot consider deleting this
site from the Superfund list until the cleanup activities outlined in this Record of Decision
(and future Records of Decision, namely for the newly created Operable Unit 4) are completed.
Since a capped landfill has already been left on Site (Shaffer Landfill, 0U2), and under this
remedy additional areas of contamination will be capped, the Site is currently not a
candidate for delisting from the NPL.

5)	Will neighbors who are selling homes still need to disclose that homes are near the
Superfund Site?

Disclosure of the proximity of a property to a Superfund site is not a reguirement under
CERCLA (the "Superfund" law). Iron Horse Park will continue to be a Superfund site until such
time as EPA deletes it from the National Priorities List (NPL). (See response to previous
guestion)

6)	Should people in the area be concerned about planting vegetable gardens?

EPA is unaware of any Iron Horse Park Site conditions or contamination that would have
affected residential gardens.

7)	Is groundwater in the area contaminated?

There is groundwater contamination associated with Iron Horse Park. Various contaminants are
present above either Maximum Contaminant Levels (MCLs - or drinking water standards) or
health based contaminant levels. EPA is not aware of any human receptors exposed to
groundwater (i.e. anyone drinking this groundwater). As discussed in the ROD, the selected
remedies address source control of contaminants that may migrate into groundwater and are
present in the areas to be capped. The remediaton of groundwater, surface water and sediment
will be addressed in the ROD for 0U4.

Comments from the Public Hearing

1)	EPA should make data associated with groundwater, surface water, sediment and air
monitoring accessible on-line, so that the effectiveness of the cleanup can be determined.

EPA will post new monitoring data on-line. The link where data as well as other site
information can be found is www.epa. crov/ne/superfund/sites/ironhorse.

2)	EPA should examine contaminant mobility rates and the proximity of waste to groundwater to
determine if at any areas to be capped, installation of an impermeable liner under and around
the waste, would be warranted.

EPA has examined the concentration, mobility and proximity to groundwater of contaminants in
the source areas at 0U3. This is discussed in Section E. of the ROD and is discussed in
greater detail in the Remedial Investigation, primarily in the sections addressing Nature and
Extent of Contamination, and Contaminant Fate and Transport. The additional cost that would
be associated with excavation of all of these source areas for placement of liners (which
would be in the 10's of millions of dollars) would be prohibitively expensive, with limited
environmental benefit. As discussed previously, groundwater cleanup will be addressed in the
ROD for OU4.

3)	A study should be conducted regarding cancer rates and potential cancer clusters in the
area.

The Department of Health and Human Services' Agency for Toxic Substances and Disease Registry
(ATSDR) is the Federal agency responsible for evaluating such reguests, typically in
conjunction with the state Department of Public Health. This comment has been forwarded to

-------
ATSDR for their consideration and follow-up.

Comments from MADEP

1)	MADEP expects the opportunity to review and comment on cleanup goals for soils prior to
finalization of the ROD.

MADEP has had the opportunity to review and comment on cleanup goals for soils as well as the
rest of the ROD.

2)	This proposed plan addresses soil contamination. Groundwater monitoring should be
conducted as a remedial investigation activity, not as a part of the remedy for 0U3.

Capping is being conducted at all of the AOCs in accordance with toxics, solid waste or
hazardous waste regulations. These regulations reguire monitoring (including groundwater
monitoring) as a part of post-closure activities. Therefore, groundwater monitoring will be
conducted in the vicinity of the capped areas to assess the effectiveness of the caps.

3)	The proposed plan does not discuss VOC's in a monitoring well adjacent to the Asbestos
Landfill. The VOC's should be investigated either during the design process or during the 0U4
investigation.

The VOC issue noted will be addressed as part of the 0U4 investigation.

4)	The preferred alternatives will require Institutional Controls to maintain the
effectiveness of the remedy and prevent future exposure to contaminants that will remain on
site.

EPA agrees that Institutional Controls will be necessary as part of the remedy for 0U3.
Institutional Controls, primarily in the form of land use restrictions, are discussed in
Section L. of the ROD which describes the selected remedy.

5)	MADEP questions whether the FS assumption with regard to excavating the Asbestos
Lagoons to a depth of 1 foot is valid, or whether more extensive excavation may be necessary.

As discussed earlier, EPA has selected SC-1, capping in-place, as the remedy at the Asbestos
Lagoons.

6)	DEP notes that at the Old B&M Oil/Sludge Recycling Area, the cap needs to constitute an
"Engineered Barrier" as defined in the MCP. MADEP also notes an issue regarding non
aqueous phase liquid (NAPL) associated with groundwater.

The selected remedy for the Old B&M Oil/Sludge Recycling Area states that this area must be
capped in accordance with the relevant and appropriate portions of the State Solid Waste
regulations. In addition, EPA has designated the MADEP "Landfill Technical Guidance Manual"
as a document "To Be Considered" in association with the implementation of the remedy at the
Old B&M Oil/Sludge Recycling Area.

7)	At the B&M Locomotive Shop Disposal Areas, MADEP indicates a preference for excavation
and consolidation of material (SC-2), rather than capping in-place (SC-1). In support of this
preference, MADEP cites, in part, the potential difficulty of performing the construction in
close proximity to the wetlands.

In EPA's judgement, the increased cost (approximately $6 million) associated with the
implementation of the SC-2 alternative is not warranted, given the limited additional benefit
that would be realized. While there will be issues associated with construction in close
proximity to wetlands, this would also be an issue if SC-2 were implemented. Protection and
potential restoration of wetlands would be necessary with either alternative and does not

-------
pose a problem in implementing the remedy.

8) MADEP questions whether the volume of material to be excavated at the B&M Locomotive
Shop Disposal Areas, is overestimated.

During the RI, EPA conducted subsurface profiling using ground penetrating radar and
electro-magnetic surveying, in addition to soil borings and test pits in order to help define
the nature and extent of waste. EPA is confident that this combined information, provides a
reasonably accurate assessment of the volume of the B&M Locomotive Shop Disposal Areas.
However, EPA has determined not to excavate the B&M Locomotive Shop, but instead to cap
the Site.

-------
APPENDICES

-------
APPENDIX A: Commonwealth Letter of Concurrence

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

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

ELLEN ROY HERZFELDER
Secretary

ROBERT VV. GOLLEDGE, Jr.

Commissioner

September 24, 2004

Susan Studlien, Director	Re: ROD Concurrence Letter

Office of Site Remediation and Restoration	Operable Unit #3

U.S. EPA	Iron Horse Park Superfiind Site

One Congress Street, Suite 1100 (HIO)

Boston, MA 02114

Dear Ms. Studlien:

The Department of Environmental Protection (DEP) has reviewed the Selected Remedial Action alternative
for the cleanup of the Third Operable Unit at the Iron Horse Park Superfund Site. The selected alternative
addresses several source areas within the Iron Horse Park Site. The DEP concurs with the selection of this
alternative for this operable unit.

This Operable Unit's remedial action has three components:

•	Control the sources of contamination and limit or prevent future contaminant migration by capping;

•	Monitor groundwater, including conducting an evaluation of the trend in groundwater contaminant
concentrations;

MITT ROMNEY
Governor

KERRY HEALEY
Lieutenant Governor

• Conduct an evaluation to determine if the source control measures alone can be protective of human
health and the environment, whether active groundwater cleanup is viable, and whether the cleanup
approach needs to be reevaluated.

Based on the information presented to date, DEP believes that the selected remedial actions of capping and
monitoring of groundwater will be protective of human health and the environment.

The Department looks forward to working with you in implementing the selected alternative. If you have any
questions, please contact Janet Waldron at 617-556-1156.

Very truly yours,

CiuX

tt

Richard C. Cnalpin
Acting Assistant Commissioner

DC/jsw

Efile: 5.01 Correspondence/DEP OU 3 Concurrence Letter 092004

This information is available in alternate format. Call Donald M. Gomes, ADA Coordinator at 617-556-1057. TDD Service - 1-800-298-2207.

DEP on the World Wide Web: http://www.mass.gov/dep
O Printed on Recycled Paper

-------
APPENDIX B: Figures

-------
FIGURE 1-1. GEOGRAPHICAL LOCATION OFTHEIRON HOUSE PARK M 'TV\ : M» ••! i !¦

*•«*«« lm.

-------
FIGURE 1-2. SITE BASE MAP

Iron Horse Park Superfund Site

3rd Operable Unit
	North Billerica, MA	

figl-a.aml October 1999

I I I I I I I I I I I

X	H-

LEGEND

-X

Road
Railroad
Stream
Fence

Disposal Area
Boundary

Study Area
Boundary

Iron Horse

Site Boundary

Surface
Water

Wetland

Lagoon

Building

Canal



E

SCALE IN FEET

Locations for All Features Shown are Approximate.

Extent of Wetland and Surface Waters are Limited to Areas Confirmed

During Wetlands Reconnaissance on July 15,1993 and Novembers, 1994.

Met calf & Eddy

-------
prop.aml October 1999

Metcalf & Eddy

-------


LEGEND

x-



-X

Road
Railroad
Stream
Fence

Disposal Area
Boundary

Iran Horse
Site Boundary

Surface
Water

Wetland

Lagoon

Canal

n

u

Medium Yield

Aquifer

Open Space

Interim Wellhead
Protection Area



FIGURE 1-4. AQUIFERS,

SCALE IN FEET

Ldcations for All Features Shown are Approximate. Extent of Wetland and Surface Waters are Limited to Areas
Confirmed During Wetlands Reconnaissance on July 15,1993, and November 8,1994. MASSGIS DATA SOURCES:
AQUIFERS: USGS Water Resources Div. hydrologic atlas series manuscript, 1:48,000,1977 to 1988. INTERIM
WELLHEAD PROTECTION AREAS: MASSDEP/DWS, 1:25,000. OPEN SPACE: MA DFWELE/MASSGIS, 1:25,000,1993.

Iron Horse Park Superfund Site
3rd Operable Unit
North Billerica, MA

massgis.aml October 1999

Met calf & Eddy

-------
Figure E-l CONCEPTUAL SITE MODEL FOR CONTAMINATED GROUNDWATER, SURFACE WATER, AND SEDIMENT

Primary Sources

Secondary Release
Mechanism

Pathway

Receptors

Exposure

Site

Site

Area

Route

Trespasser

Workers

Residents

Landfills, Lagoons, and
Waste Disposal Areas

Infiltration/ Percolation

Storm Water
Runoff



Groundwater

	~

Ingestion





•



Inhalation







Dermal









1







Surface Water



Ingestion







Inhalation







w

w

Dermal

•







1







Sediment

-



Ingestion

•





Inhalation







w

w

Dermal

•

-------
Figure E-2 CONCEPTUAL SITE MODEL FOR CONTAMINATED SOIL

Primary Sources

Pathway

Receptors

Soils at Landfills,
Lagoons, and Waste
Disposal Areas

Soil



Human Health

Ecological

Exposure

Site

Site

Area

Soil

Short-tailed

Route

Trespasser

Workers

Residents

Invertebrates

Shrew



Ingestion

•

•



•

•

Inhalation











Dermal

•

•



•

-------
MA DEP - Bureau of Waste Site Cleanup

srnE name: Preliminary Assessment Map: 1,1/2, & 1/4 Mile Redly

Iran Hoim tak 0U*2
MM0-02

¦wMn; Milt^iLtn'IW^ii	 — —

MvAmtePferira 	 t-i-HH o c

			

cHiwid^*niiUH,
-------
>6"

>18"

\l/\U\l/\U\l/\U\U\U\U\U\U\U\U\UsU

Topsoil

Cover Soil

>c^

//////////////////,!'/('//////

• t / f f t * f t f * ?? f * f * f * f * / f * * f f *
' ' 3k S^SS ,» «» A A A A .N jJ>' J> A A A ,A V» A J. A .N » ,jfc ;ji

6-12"

To Bottom
of Waste

Vent Layer (Optional)(2)

Graded Waste

V

- Drainage
GeocompositeO)

-i 60-Mil
—f- Geomembrane
	Geotextile (Typ.)

NOTES:

SECTION VIEW: SUBTITLE D
SOLID WASTE CAP

1.	Drainage Geocomposite to be two non-woven geotextiles heat bonded to a
drain core. Minimum hydraulic transmissivity of 3 x 104 m2/sec.

2.	Used if gas generation from waste is possible.

FIGURE L-2. HORIZONTAL CONTAINMENT SINGLE BARRIER LANDFILL CAP

01 a/6413j

-------
High Traffic Area for Cap

Bituminous Concrete
Top Course

3"
2"

\ Surface Runoff *

V 1

it

v////)y////////////////////.



SS^ Bituminous Concrete-Binder CoarseSSS\

it

Gravel Base Course^) ^



Existing Contaminated Grade

it

\

it

<3^

6" x 18" Concrete
or Granite Curbing	

it
' it

Existing Rail Bed (Uncapped)-

o

Wood Tie

Bedding Stone ¦

NOTES:

1. No gravel base course in areas of existing pavement.

FIGURE L-3. HORIZONTAL CONTAINMENT - SINGLE BARRIER CAP

02/'64l3jp

-------
>6"

>18"

U\U\U\U\U\U\l/\U\U\l/\l/\U\l/\U\U

>12"

6-12"

To Bottom
of Waste

Low-Permeability
Soil (-10-4 cm/sec)

Vent Layer (Optional)!2)

V V WSitf \Jf V V W

Graded Waste

Drainage
Geocomposite(1)

lb 60-Mil

Geomembrane

Geotextile (Typ.)

NOTES:

SECTION VIEW: EPA REGION I
ALTERNATIVE CERCLACAP

1.	Drainage Geocomposite to be two non-woven geotextiles heat bonded to a
drain core. Minimum hydraulic transmissivity of 3 x 1CM m2/sec.

2.	Used if gas generation from waste is possible.

FIGURE L-l. HORIZONTAL CONTAINMENT COMPOSITE/DOUBLE BARRIER

01/6413jp

-------
APPENDIX C: Tables

-------
ROD RISK WORKSHEET

Table G-1

Summary of Chemical of Concern and Medium-Specific Exposure Point Concentration

Scenario Timeframe: Current/Future
Medium: Soil

Exposure Medium: Surface Soil

Exposure Point

Chemical of
Concern

Concentration Detected

Minimum

Maximum

Units

Frequency of
Detection

Exposure Point
Concentration

Exposure Point
Concentration
Units

Statistical
Measure

(1)

BSM Locomotive Shop Disposal Area

Lead

13.2

2,370

mgfrg

4/5

2.370

mg/kg

Max

Contaminated Soils Area

Lead

69.1

10,800

mg/Kg

46/46

1,830

mg/kg

95% UCL

Key

(1) Statistics: Maximum Detected Value (Max); 95% UCL (95% UCL);
Arithmetic Mean (Mean)

The table represents the chemicals of concern (COCs) and exposure point concentrations (EPCs) (or the COCs detected in surface soil (i.e., the concentrations that will be used to estimate the exposure and risk (or
each COC in surface soil). The table includes the range of concentrations detected for each COC. as well as the frequency of detection (i.e., the number of times the chemical was detected in the samples collected at
the site), the EPC, and how the EPC was derived. This table indicates that lead was detected more frequently at the Contaminated Soil Area than at the B&M Locomotive Shop Disposal Area, The 95% UCL on the
arithmetic mean was used as the EPC for lead at the Contaminated Soil Area. However, due to the limited amount of sample data available for lead at the B&M Locomotive Shop Disposal Area, the maximum detected
concentration was used as the default EPC.

Source; A Guide to Preparing Superfund Proposed Plans, Records of Decision, and Othar Remedy Selection Decision Documents (U.S. EPA, 1999)

Page 1 of 1

IHP HH Tables.xls

-------
ROD RISK WORKSHEET

Table G-2

Summary of Chemical of Concern and Medium-Specific Exposure Point Concentration

Scenario Timeframe: Future
Medium: Soil
Exposure Medium: Surface and Subsurface Soil

Exposure Point

Chemical of
Concern

Concentration Detected

Old B&M Oil/Sludge Recycling Area
Lead

Minimum

8.9

Maximum

4,120

Units

mpfkg

Frequency of
Detection

24/27

Exposure Point
Concentration

4,120

Exposure Point
Concentration
Units



Statistical
Measure

(D

Max

Key

(1) Statistics: Maximum Delected Value (Max); 95% UCL (95% UCl):
Arithmetic Mean (Mean)

The table represents the chemicals of concern (COCs) and exposure point concentrations (EPCs) for each of the COCs detected in surface soil/subsurface soil (i.e., the concentrations that will be used to estimate the
exposure and risk for each COC in surface soil/subsurface soil). The table includes the range of concentrations detected for each COC, as well as the frequency of detection (i.e., the number of times the chemical was
detected in the samples collected at the site), the EPC, and how the EPC was derived. Due to the variability of the data available for lead at the Old B&M Oil/Sludge Recycling Area, the maximum detected
concentration was used as the default EPC.

Source: A Guide to Preparing Suporfund Proposed Plans, Records of Decision, and Other Remedy Selection Decision Documents (U.S. EPA, 1999)

Page 1 of 1	IHP HH Tables.xls

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ROD RISK WORKSHEET

Table G-3

Summary of Chemical of Concern and Medium-Specific Exposure Point Concentration

Scenario Timeframe: Future















Medium: Groundwater















Exposure Madlur

n: Groundwater















Exposure Point

Chemical of
Concern

Concentration Detected

Units

Frequency of
Detection

Exposure Point
Concentration

Exposure Point
Concentration
Units

Statistical
Measure





Minimum

Maximum







(1)

B&M Railroad l andfill -

Shallow Overburden

















Aidrin
PCBs

0,010
0,060

0-010
0.15

ug/l
ug/l

1/10
3/10

0.010
0.15

ugfl
ugfl

Max

Max



Arsenfc
Manganese

3.1
12.5

55.6
5,420

ug/l
ug/l

3/10
7/10

55.6
5,420

ug/1
ug/i

Max
Max

B&M Railroad Landfill -

Bedrock

















1,2-Dlchlorwithane
t, 1-Diohloroetheiia
TrieWoroettiene

6.0
3.0
22

9.0
9.0
SO

ugfl
ug/I

4/10
4/10
4/10

so

9.0
50

ug/l
ug/i
ug/l

Ma*
Max
Ma*



Arsenic

3.8

19.6

~g/1

4/10

19.6

ug/1

Ma*

RSi Landfill - Shallow Overburden

















Benzene

345

350

U01

2/14

350

Uflfl

Max



Arsenic
Manganese

5.5
11.7

186
2,440

ug/1
ug/1

12/14
14/14

186
2,440

ug/1
ug/1

Ma*
Ma*

RSI Landfill - Deep Overburden

















1,1,2.2-T elrachloroethane
Trichloroethene

5.0
21

5.0
23

ug/l

ug/1

1/10
2/10

5.0
23

ug/l
ugfl

Max
Max



PCBs

0.0060

0.080

ugfl

4/10

0,080

ug/I

Max



Arsenic

Manganese

Thallium

3.1
1,100
8,9

345
6,400
9.0

ug/i
ugfl
ugfl

7/10
10/10

2/10

345

6.400
e.o

ug/l
ug/l
ug/l

Ma*
Max
Max





















1.2-Oichlo methane
1.1-Oichloroethene
Telrachloroelhene

2.0
20
3.0

6.0
2.0
3.0

Ufl/I
ug/1
ugfl

5/10
1 /10
2/ 10

6.0
2.0
3.0

ug/l
ug/l
ugfl

Max
Max

Max



PCBs

0,080

0.080

ugfl

1/10

0.080

ug/l

Max



Arsenic

Manganese j

2-125
10.35

11.9

2.690

ug/i
ug/I

4/10

8/10

11.9

2,690

ug/l
ugfl

Max
Max

Page 1 of 3

IHP HH Tables.xls

-------
ROD RISK WORKSHEET

Table G-3

Summary of Chemical of Concern and Medium-Specific Exposure Point Concentration

Scenario Timeframe: Future















Medium; Groundwater















Exposure Medium: Groundwater















Exposure Point

Chemical of

Concentration Detected

Units

Frequency of

Exposure Point

Exposure Point
Concentration

Statistical

Concern





Detection

Concentration

Units

Measure





Minimum

Maximum









(D

B&M Locomotive Shop Disposal Area - Shallow Overburden















Manganese

10.5

11,000

ugfl

7/8

11.000

ugfl

Max

B&M Locomotive Shop Disposal Area - Deep Overburden















Arsenic

11.8

16.6

ugfl

2/8

i6,e

ugfl

Max

Old B&M Oil/Sludge Recycling Area - Shallow Overburden















Arsenic

9.9

27.1

ugfl

4/12

27.1

ug/l

Max



Manganese

56.4

1.490

ugfl

12/12

1.460

ugfl

Max

Old B&M Oil/Sludge Recycling Area - Deep Overburden















Manganese

10,2

1.370

U0/1

12/12

1,370

ugfl

Max

Old B&M Oil/Sludge Recycling Area • Bedrock

















Arsenic

3.0

9.6

ugfl

4/10

9.6

ug/l

Max



Manganese

10.2

1,370

ug/l

10/10

1,370

ugfl

Max

Asbestos Lagoons - Shallow Overburden

















1,1,2,2-Telrachloraethane

3,0

3.0

ug/l

1/10

3.0

ug/l

Max



Arsenic

12.1

58.1

ug/l

6/10

58.1

ug/l

Max

Asbestos Lagoons - Deep Overburden

















1,2-DicNoroeihane

3.0

3.0

ug/l

2/8

3.0

ug/l

Max



Bis(2-elhylhexyi)phthatate

3.0

13

ugfl

2/8

13

ug/l

Max



Arsenic

12

17.3

ug/i

2/8

17.3

ug/l

Max



Beryllium

2.4

24

ugfl

i / a

24

ug/l

Max



Manganese

853

4,160

ugfl

8/8

4,160

ug/l

Max

Asbestos Lagoons - Bedrock

















1,2-Oichtoroelhane

3.0

39

Ufl/I

6/6

39

ug/l

Max



Bis(2-elhyfhexyl)phlhalate

17

17

ug/l

1 / 6

17

ug/i

Max



PCBs

0.10

0.10

ug/l

1 / 6

0.10

ug/l

Max



Beryllium

2.1

2.1

ugfl

116

2.1

ug/l

Max



Manganese

453

8,745

ugfl

0/0

8.745

ug/l

Max



Page 2 of 3

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Table G-3

Summary of Chemical of Concern and Medium-Specific Exposure Point Concentration

Scenario Timeframe: Future
Medium: Groundwater
Exposure Medium: Groundwater

Exposure Point

Chemical of
Concern

Concentration Detected

Minimum

Maximum

Units

Frequency of
Detection

Exposure Point
Concentration

Exposure Point
Concentration
Units

Statistical
Measure

(H

Key

J Statistics: Maximum Detected Value (Max); 35% UCL (95% UCL);
Arithmetic Mean {Mean)

The table represents the chemicals of concern (COCs) and exposure point concentrations (FPCs) for each of the COCs detected In groundwater {i.e., the concentrations that will be used Jo estimate ihe exposure and
risk I or each COC in groundwater). The table includes (he range of concentrations detected lor each COC. as well as the frequency ol detection {i.e., the number of times the chemical was detected in the samples
collected at the site}, the EPC, and how the EPC was derived. This table indicates that inorganic chemicals are the most frequently detected COCs in groundwater at the site. As preseoibed by EPA guidance, the
maximum delected concentration was used as ihe EPC for alt COCs detected In groundwater within each flow zone for each Area of Concern (AOC),

Source: A Guide to Preparing Superfund Proposed Plans, Records of Decision, and Other Remedy Selection Decision Documents (U.S. EPA, 1999)

Page 3 of 3

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Table G^l

Cancer Toxicity Data Summary

Pathway: Ingestion, Dermal

Chemical of
Concern

Oral Cancer
Slope Factor

Dermal Cancer
Slope Factor

Slope Factor
Units

Weight of
Evidence/Cancer
Guideline Description

Source

Date
(MM/DD/YYYY)

Benzene

2.9E-02

N/A

(mg/kg-day)"

A

IRIS

01/01/96

1,2-Dichloroethane

9.1E-02

N/A

(mg/kg-day)"

B2

IRIS

01/01/96

1,1-Dichloroethene

6.0E-Q1

N/A

(mg/kg-day)''

€

IRIS

01/01/96

1, t ,2,2-TetrachIoroetbane

2.0E-01

N/A

(mg/kg-day)"

C

IRIS

01/01/96

T etrachloroethene

5.2E-02

N/A

(mg/kg-day)'1

B2/C

IRIS

01/01/96

Trichloroethene*

1.1E-02

N/A

(mg/kg-day)"

B2/C

IRIS

01/01/96















bis(2-Ethylhexyl)phthalate

1.4E-02

N/A

(mg/kg-day)"

B2

IRIS

01/01/96















Aldrin

1.7E+01

N/A

(mg/kg-day)"

82

IRIS

01/01/96

PCBs (carcinogenic)

7.7E+00

N/A

(mg/kg-day)"

82

IRIS

01/01/96

PCBs (noncarcinogenic)













Aroclor 1016

N/A

N/A

(mg/kg-day)"

N/A

N/A

N/A

Aroclor 1254

N/A

N/A

(mg/kg-day)"

N/A

N/A

N/A















Arsenic

1.5E+00

N/A

(mg/kg-day)"

A

IRIS

01/01/96

Beryllium

4.3E+00

N/A

(mg/kg-day)"

B2

IRIS

01/01/96

Lead

N/A

N/A

(mg/kg-day)"

B2

IRIS

01/01/96

Manganese

N/A

N/A

(mg/kg-day)"

D

IRIS

01/01/96

Thallium

N/A

N/A

(mg/kg-day)'

D

IRIS

01/01/96

Key

N/A: Not applicable

IRIS: Integrated Risk Information System, U.S. EPA
NCSA: National Center for Environmental Assessment, U.S. EPA
HEAST: Health Effects Assessment Summary Tables, U.S. EPA
USEPA 1994: U.S. EPA Region 1 Risk Update

EPA Group

A - Human carcinogen

B1 - Probable human carcinogen - Indicates that limited human data are available

B2 - Probable human carcinogen • indicates sufficient evidence in animals and inadequate or no

evidence in humans
C - Possible human carcinogen
D - Not classifiable as a human carcinogen
E - Evidence of noncarcinogenicity

Page 1 of 2

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Table G-4

Cancer Toxicity Data Summary

Pathway: Ingestion, Dermal

Chemical of
Concern

Oral Cartcer
Slope Factor

Dermal Cancer
Slope Factor

Slope Factor
Units

Weight of
Evidence/Cancer
Guideline Description

Source

Date
(MM/DD/YYYY)

'There is a new draft slope factor for TCE which will increase risk by approximately 60-fold, but the cleanup level will still be the MCL.

This table provides the carcinogenic risk information which is relevant to the contaminants of concern in soil and groundwater, Because the dermal route was not assessed for
groundwater exposures and lead was evaluated through use of a lead model, dermal slope factors are not applicable to this assessment.

Source; A Guide to Preparing Superfund Proposed Plans, Records of Decision, and Other Ramedy Selection Decision Documents (U.S. EPA, 1999)

Page 2 of 2

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Table G-5

Non-Cancer Toxicity Data Summary

Pathway: Ingestion, Dermal

Chemical of
Concern

Chronic/
Subchronic

Oral RfD Value

Oral RfD Units

Dermal RfD

Dermal RfD

Units

Primary Target
Organ

Combined
Uncertainty/

Modifying
Factors

Sources of RfD:
Target Organ

Dates of Rfd:
Target Organ
(MM/DD/YYYY)

Benzene

N/A

N/A

N/A

N/A

N/A

N/A

N/A

WA

N/A

1,2-DichlQFOelhane

N/A

N/A

N/A

N/A

N/A

N/A

N/A

N/A

N/A

1.1-Dichloroethene

Chronic

9.0E-03

mg/kg-day

N/A

mg/kg-day

liver

1000

IRIS

61/01/96

1,1,2,2-Teiraehioroe thane

N/A

N/A

N/A

N/A

N/A

N/A

N/A

N/A

N/A

Tetrachloroeihene

Chronic

1.0E-02

mg/kg-day

N/A

mg/kg-day

liver

1000

IRIS

01/01/96

Trichioroelhene

WA

N/A

WA

N/A

N/A

N/A

N/A

WA

N/A

Dls(2-Ethyihexyl)phihaiaie

Chronic

2.0E-02

mg/kg-day

N/A

mg/kg-day

Irver

1000

IRIS

01/01/96

Aldrin

Chronic

3.CE-05

rng/kg-dgy

N/A

mg/kg-day

liver

1000

HEAST

01/01/96

PCBs (carcinogenic)

N/A

WA

WA

N/A

N/A

N/A

N/A

N/A

N/A

PCBs {noncarcinogenic)



















Amcior 1016

Chronic

7.GE-05

mg/kg-day

N/A

mg/kg-day

low birth weight

100

IRIS

01/01/96

Aroclor 1254

Chrome

2.0E-05

mg/kg-day

N/A

mg/kg-day

immune system

300

IRIS

01/01/96

Arsenic

Chronic

3.OE-04

mg/kg-day

N/A

mg/kg-day

skin

I3i

IRIS

01/01/55

Beryllium

Chronic

5.0E-03

mg/kg-d ay

N/A

mg/kg-day

none observed

nooj

IRIS

01/01/96

Lead

N/A

N/A

N/A

N/A

N/A

WA

N/A

N/A

N/A

Manganese

Chronic

2.4E-02

mg/kg-day

N/A

mg/kg-day

CHS

|3]

IRIS

01/61/96

Thallium

Chronic

8.0E-05

mg/kg-day

N/A

mg/kg-day

fiver

[3000]

IRIS

01/01/96

Key



















N/A- No Information available

















IRIS - Integrated Risk Information System, U.S. EPA















NCEA - National Center for Environmental Assessment U.S. EPA















HEAST -Health Effects Assessment Summary Tab

es. U.S. EPA















This (able provides non-carcinogenic risk Information which is relevant to the contaminants ol concern in soil and groundwater. Nine of the COCst have toxicity data indicating their potential tor adverse non-carcinogenic health effects in
humans. Chronic toxicity data available for the nine COCs for oral exposures have been used to develop chronic oral reference doses (RfDs), provided in this table. The available chronic loxicty data Indfcate that 1,1-dichloroet»iene,
letrachkxnethene, bis(2-«thylhaxyl)phthaiate. aldiin, and thallium affect the Svor, Aroclor-1254 (a PCB) affects iht immune system, arsenic effects the skirt, manganese affects the nervous system, and Aroctor 1016 (a PCBJ causes low birth
weight Reference doses were not available for the benzene. 1,2-dtehlonoethane. 1.1,2.2-tetrachloroe thane, tnchtoroethene. and lead. Dermal RfDs are not applicable for this assessment because the dermal route was nol evaluated for
groundwater exposures and lead was evaluated through the use of a lead model.

Source; A Quid# to Preparing Suparfund Proposed Plans, Records of Decision, and Other Remedy Selection Decision Document® (U.S. EPA, 1989)

Page 1 of 1	IHP HH Tables.xls

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Table G-6

Risk Characterization Summary - Carcinogens

Scenario Timeframe: Future
Receptor Population: Resident
Receptor Age: Adult

Medium

Exposure
Medium

Exposure Point

Chemical of
Concern

Carcinogenic Risk

Ingestion

Inhalation

Dermal

External
(Radiation)

Exposure
Routes Total

Groundwater

Groundwater

B&M Railroad Landfill -

Shallow Overburden

Aldrin

PCBs

Arsenic

2E-06
4E-Q6

1E-03

--

--

--

2E-06
4E-06

1E-03

Exposure Point Groundwater Risk Total *

1E-03

Groundwater

Groundwater

B&M Railroad Landfill -

Bedrock

1,2-Dicbloroethane
1,1-Dichloroethene
Tricworoethene

Arsenic

1E-05
6E-05
6E-06

3E-04

--

--

--

IE-OS

SE-05
SE-06

3E-04

Exposure Point Groundwater Risk Total¦

4E-04

Groundwater

Groundwater

RSI Landfill - Shallow C

yartsunJen
Benzene

Arsenic

1E-Q4
3E-03



--

--

1E-04

3E-03

Exposure Point Groundwater Risk Total =

3E-03

Groundwater

Groundwater

RSI Landfill - Deep Ove

rburdan

1,1,2,2-Tetrachloroethane
TricWoroelhene

PCBs

Arsenic

1E-05
3E-06

ZE-06

6E-03

--

--

--

IE-OS

3E-06

2E-08
6E-03

Exposure Point Groundwater Risk Total -

6E-03

Page 1 of 4

IHP HH Tables.xls

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Table G-6

Risk Characterization Summary - Carcinogens

Scenario Timefra
Receptor Populal
Receptor Age: Ac

ma: Future
ion: Resident
iult

Medium

Exposure
Medium

*

Exposure Point

Chemical of
Concern

Carcinogenic Risk

Ingestion

Inhalation

Dermal

External
(Radiation)

Exposure

Groundwater

Groundwater

RSI Landfill - Bedrock

1.2-Dichloroelhane
1,1-Oictiloroethene
Telrachloroethene

PCBs

Arsenic

6E-Q6
1E-05
2E-06

2E-06

2E-04

--

-•

--

6E-06
1E-05

2E-06

2E-06
2E-04



Exposure Point Groundwater Risk Total ™

2E-04

Groundwater

Groundwater

B8M Locomotive Shop

Disposal Area - Deep Overt
Arsenic

urden

3E-04

--

--

--

3E-04

Exposure Point Groundwater Risk Total *

3E-04

Groundwater

Groundwater

Old B&M Oil/Sludge Recycling Area - Shallow Over
[Arsenic

sunden

5E-04

--

--

--

5E-04

Exposure Point Gro

undwater Risk Total ¦

5E-04

Groundwater

Groundwater

Old B8M Oil/Sludge Re

cycling Area - Bedrock
Arsenic

2E-04

--

--

--

2E-04

Exposure Point Gro

undwatw Risk Total *

2E-04

Groundwater

Groundwater

Asbestos Lagoons ¦ Sti

allow Overtjurden

1.1.2,2-T elrachioroethane

Arsenic

7E-06
tE-03



--

--

7E-06
1E-03

	 Exposure Point Gro

undwater Risk Total =

1E-03

Page 2 of4

(HP HH Tables.xls

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Table G-6

Risk Characterization Summary - Carcinogens

Scenario Tlmefra
Receptor Populat
Receptor Age; Ac

me; Future
ion; Resident
lult



Medium

Exposure
Medium

Exposure Point

Chemical of
Concern

Carcinogenic Risk

Ingestion

Inhalation

Dermal

External

Exposure
Routes Total

Groundwater

Groundwater

Asbestos Lagoons - De

«p Overburden
1,2-Dichtoroethane

Bis[2-elhylhexyl)phthalate

Arsenic
Berytium

3E-Q6

2E-06

3E-04
1E-04

-•

--



3E-06

2E-Q6

3E-04
1E-04







Exposure Point Gro

undwater Risk Total =

4E-04

Groundwater

Groundwater

Asbestos Lagoons - Be

droek

1,2-Dichloroelharie

Bis(2-ethylhexyt)phthalate

PCBs

Beryllium

4E-0S
3E-06
2E-06
1E-04

--



--

4E-0S
3E-06
2E-06
1E-04



Exposure Point Gro

undwater Risk Total ¦

2E-04





Page 3 of 4

IHP HH Tables.xls

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Table G-6

Risk Characterization Summary - Carcinogens

Scenario Timeframe: Future
Receptor Population: Resident
Receptor Age; Adult

Medium

Exposure
Medium

Exposure Point

Chemical of
Concern

Carcinogenic Risk

Ingestion

Inhalation

Dermal

External
JRadiation^

Exposure
Routes Total

Key

Route of exposure is not applicable lo (his medium.

This table provides risk estimates by flow zone arid Area of Concern for the drinking water ingestion route of exposure. These risk estimates are based on a reasonable maximum exposure and were developed by taking
into account various conservative assumptions about Ihe frequency and duration of an adult's exposure to groundwater, as well as the toxicity of the COCs (bervere, 1,2-dichloroelhana, 1,1 -dichloroethene, 1,1,2,2-
telrachloroethane, tetraehioroethene, trichtoroethanB, bis{2-ethylhexyl}phthalale, aBrin, PCBs, arsenic, beryllium, manganese, and Itiallium). The total risk from direct exposure to contaminated groundwater at this site lo
a future aduii resident is estimated to be between 2x10"* and 6 x 103. The COC contributing the most to these risk levels is arsenic in groundwater. This risk level indicates lhat if no clean-up action is laken, an
individual would have an increased probability of between 2 in 10,000 and 6 in 1,000 of developing cancer as a result of site-related exposure to the COCs.

Source: A Guide to Preparing Superfund Proposed Plans, Records of Decision, and Other Remedy Selection Decision Documents (U.S. EPA, 1909)

Page 4 of 4

IHP HH Tables.xls

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Table G-7

Risk Characterization Summary - Non-Carcinogens

Scenario Timeframe: Future
Receptor Population; Resident
Receptor Age: Adult

Medium

Exposure
Medium

Exposure Point

Chemical of
Concern

Primary Target
Organ

Non-Carcinogenic Hazard Quotient

Ingestion

Inhalation

Dermal

Exposure

Groundwater

Groundwater

B&M Railroad Landfill -

Shallow Overburden

Arsenic

Manganese

Skin
Nervous System

5E+0Q
6E+00

--

--

5E+00
6E+00

Groundwater Hazard Index Total =

1E+01

Receptor Hazard Index *

1E+01

Nbtvoiis System Hupnrrt inrtoir m

6E+00



Skin Hazard Index ¦

5E+Q0

Groundwater

Groundwater

B6M Railroad Landfill - Bedrock
jArsenic

Skin

2E+00

--

--

2E+00

Groundwater Hazard Index Total =

2E+Q0

Receptor Hazard Index -

2E+00



Skin Hazard Index ¦

2E+00

Groundwater

Groundwater

RS! Landfill - Shallow 0

verburden

Arsenic

Manganese

Skin
Nervous System

2E+01

3E+00

••

--

2E+01

3E+00

Groundwater Hazard Index Total ¦

2E+01

Receptor Hazard Index ¦

2E+01

Narvoui Syatem Hazard Index »

3E+00

Skin Hazard Index »

2E*01

Page 1 of 4

1HP HH Tables.xls

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Table G-7

Risk Characterization Summary - Non-Carcinogens

Scenario Timefra
Receptor Populat
Receptor Age: A

me: Future
tion: Resident
duit

Medium

Exposure
Medium

Exposure Point

Chemical of
Concern

Primary Target
Organ

Non-Carcinogenic Hazard Quotient

Ingestion

Inhalation

Dermal

Exposure

Groundwater

Groundwater

RSI landfill - Deep Ovt

rburden
Arsenic
Manganese
Thallium

Skin
Nervous System
Liver

3E+01
7E+0O
3E+00



--

3E*01
7E*0O
3E+00

	 Groundwato

r Hazanl Indax Total =

4E*01

		 Receptor Hazard Index *

4E-KJ1

		 Livor Hazanl Index ¦

3E+QQ

	——	 Nervous System Hazard Index ¦

7E+O0







3E+01

Groundwater

Groundwater

RSI Landfill - Bedrock

Manganese

Nervous System

3E+00

--

--

3E+00

	 Groundwate

Hazanl Indax Total¦

3E-HX3

		 Receptor Hazanl Index =

3E+00





Norvftnc System Iprii)* =

3E+00

Groundwater

Groundwater

B8M Locomotive Shop Disposal Area - Shallow Overtjurden

| Manganese j Nervous System

1E+01

--

--

tE+Ot



Groundwate

Hazard Indax Total ¦=

1E+01

^		 Receotor Hazanl Index m

1E+01







1E-KJ1

Groundwater

Groundwater

BSM Locomotive Shop Disposal Area - Deep 0
|Arsenic

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ROD RISK WORKSHEET

Table G-7

Risk Characterization Summary - Non-Carcinogens

Scenario Tlmefra
Receptor Populal
Receptor Age; A

ma; Future
Ion: Resident
dult

Medium

Exposure
Medium

Exposure Point

Chemical of
Concern

Primary Target
Organ

Non-Carcinogenic Hazard Quotient

Ingestion

Inhalation

Dermal

Exposure

Groundwater

Groundwater

Old B&M Oil/Sludge Re

cycling Area - Shallow <

Arsenic

Manganese

)verburden

Skin
Nervous System

2E+00
2E+00

--

--

2E+Q0
2E+M

Groundwater Hazard Index Total»

4E+00

	 Receptor Hazard Index =

4E+00

Nervous System Hazard Index ¦

2E+00







2E+QQ

Groundwater

Groundwater

Old B&M Oil/Sludge Recycling Area - Oeep Overburden

|Manganese | Nervous System

2E+00

--

--

2E+00

		 Groundwate

Hazard Index Total ¦

2E+00

		 Receptor Hazard Index ¦

2E+0Q





2E+00

Groundwater

Groundwater

Old B&M Of 1/Sludge Re

cycling Area - Bedrock
Manganese

Nervous System

2E+00

--



2E+00

Groundwale

Hazard Index Total »

2E+00

		 Receotor Hazard Index b

2E-MJ0







2E+00

Groundwater

Groundwater

Asbestos Lagoons - Shallow Overburden
Arsenic

Skin

5E+00

--



SE+OO

	 Ground wate

Hazard Index Total =

SE+00

	 Receptor Hazard Index =

5E+00



5E+00

Page 3 of 4

IHP HH Tables.xls

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Table G-7





Risk Characterization Summary

Non-Carcinogens





Scenario Timeframe: Future
Receptor Population: Resident
Receptor Age: Adult

Medium

Exposure
Medium

Exposure Point

Chemical of
Concern

Primary Target
Organ

Non-Carcinogenic Hazard Quotient











ingestion

Inhalation

Dermal

Exposure

Groundwater

Groundwater

Asbestos Lagoons - De

ep Overburden

Arsenic

Manganese

Skin
Nervous System

2E+00
5E+0Q

--

--

2E+Q0
5E+00

Groundwater Hazard Index Total ¦=

6E+00

		 Receptor Hazard Index u

6E+0Q

	 Nervous System Hazard Index «

5E+00





2E+00

Groundwater

Groundwater

Asbestos Lagoons - Be<

drock

Manganese

Nervous System

1E+01

--

--

1E+01

	 Groundwater Hazard Index Total ¦

1E+Q1

Receptor Hazard Index =

1E+Q1



1E+01

Key

NIA - Toxicity criteria are not available to quantitatively address this route of exposure.
- Route of exposure is not applicable to this medium.



This table provides, by flow zone for each Area of Concern, hazard quotients (HQs) (or each COC in groundwater and the hazard Index (sum of the hazard quotients) for the drinking water ingestion route o(
exposure. The Risk Assessment Guidance (RAGS) for Superfund states that, generally, a hazard index (HI) of greater than 1 indictes the potential for adverse noncancer effects. The estimated range of His of
between 2 and 40 indicates that the potential for adverse noncanoer effects could occur from exposure to contaminated groundwater containing arsenic, manganese, and thallium,

Source: A Guide to Preparing Superfund Proposed Plans, Records of Decision, and Other Remedy Selection Decision Documents (U.S. EPA, 1999)

Page 4 of 4	IHP HH Tables.xls

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TABLE G-8
SOIL COPC SCREENING
B&M RAILROAD LANDFILL
Iron Horse ParkSuperfund Site, OIU
North Billericx, MA







Maximum



Source of









Frequency of

Maximum

Background

Ecological Soil

Ecological





Hazard

Anaiyte

Detection

Soli Cone.

Soil Cooc.

Screening Level

Screening Level

coc?

Renon

Quotient (a)

VOCi (ug/fcg)

















Acetone

5 14

42

N A

10.000

fl>

N

BSV

Q.0G42

2-Butanorre

1 14

¦>,o

X A

10.000

(1)

N

KI*>

0.00070

Methylene Chloride

8.' 14

280

36

N.A



Y



N-A

SVOCi (ug/kgj

















Acenaphlhene

5 / 14

340

N*A

NA



Y



N'A

Accnaphlhylcne

11 ¦' 14

3.2QO

N-A

N-A



Y



N'A

Anthracene

12 ; 14

5,800

N'A

10,000

(U)

N

BSV

0.58

Beiu:o{a)ariihnjcene

14 ¦ 14

16,000

N'A

1.000

W

Y



16

BcnzoCaJpyrenc

14-14

18.000

N'A

>

(5)

y



3600

Bcnzo(b)nuorarnhenc

14 ¦ 14

33,000

N'A

19.000

m

Y



1.7

Benzo(g.hJ)fKivlciK

12 ¦ 14

10.000

N'A

1,000

m

Y



10

Bisp-chlorocthyl) ether

I14

280

N'A

N-'A



Y



VA

Bis<2-eihylhc?

V



1,7

Calcium

14 • 14

14.700

949

N-'A



N

KAN

N'A

Chromium

13 ' 14

304

N'A

0.4

02)

Y



760

Cobalt

13 ; 14

26

N'A

50

 14

T.03Q

g.9

50

(12)

Y



21

Cyanide

10 ¦¦ 14

39

N-A

N-A



Y



N.-A

Iron

14 ¦ 14

76.800

S.350

N-'A



Y



N A

Lead

14 ¦ 14

1,130

102

500

(i2)

Y



2.3

Page I of 2

-------
TABLE G-8
SOIL COPC SCREENING
B&M RAILROAD LANDFILL
Iron Horse Park Supcrfund Site, OU3
North Billtriea, MA







Maximum



Source of









Frequency of

Maximum

Background

Ecological SolJ

Ecological





Hazard

Analyte

Detection

Soil Cone.

Soil Cone.

Screening Level

Screening Level

COC?

Reason

Quotient (a)

Magnesium

14 ' 14

4,300

1480

N/A



N

EAN

N.'A

Manganese

14 • 14

1.0B0

206

I.SD0

(2)

N

BSV

0,72

Mercury

12*14

3.4

N'A

0.1

(12)

Y



34

Nickel

9-' 14

1S4

N A

200

(12)

N

BSV

0.77

Potassium

8 ,* 14

792

N'A

N.-A



\

RAN

N.'A

Selenium

4 .* 14

3.1

N'A

70

(12)

N

BSV

0.044

Silver

3 "9

1.2

N'A

10

m

N

DF

a ia

Vanadium

U 14

35

14

ISO

Q)

N

BSV

0.23

Zinc

H - H

4.400

4?

200

(12}

Y



22

~.	In c.his screening table, [he hazard quotient is calculated by dividing the nmimurii detection by ihc screening value.

N.'A ¦ Soi Applicable or Not Available

COC - Contminani ofConcern

BSV - Below screening value

DF - Deciion frequency less than 5% sue-wide

EAN- Essential animal nutrient

BKGD - Background comparison

Sources:

1.	Fiichko (1989),

2.	Maximum allowable soil concentration in (he former Soviet L'nion (as cited in Beyer 1990),

3.	Value for gamma-BHC(Lindane) conservatively used.

4.	Indicative of moderate soil contamination as designated by ihe soil cleanup criteria of Quebec (as cited in Beyer 1990),

5.	Acceptable concentration proposed by Ontario Ministry of Environment (as cited in Beyer 1990)

~.	Kappiernaii (1993).

7.	For Screening purposes, maximum allowable DDT concentration was used for DDE and DDT.

8.	Decreased cocoon production by Eisenia ferida (Reinccke and Venter 1985 as cited in Beyer (990).

9.	Tcnative allowable concentration for endosulfan in the former Soviet Union (as cited in Beyer 1990).

IQ. Value for Heptachlor,

11.	Soil criteria for evaluating the severity of contamination under the Dutch Soil Cleanup (Interim) Act (as cited in Beyer 1990).

12.	Will and Surer <1994).

13.	Guidelines for the New Jersey Environmental Cleanup Responsibility Act (as cited in Beyer 1990).

Page 2 of2

-------
TABLE G-9
SOIL CO PC SCREENING
RSI LANDFILL
iron Horse Park Superfund Site, OL*3
North Blllerfca, MA







Maximum



Source of









Frequency of

Maximum

Background

Ecological Soil

Ecological





Hazard

Analvie

Detection

Soli Cone.

Soil Cone.

Screening Level

ScreenlDg Level

coc?

Reason

Quotient (a)

VOC» (u^kg)

















Methylene Chloride

2 ' 6



36

NA



Y



N-A

SVOCs 

N

BSV

0,00066

4.4'-DDD

S -6

1.6

2.6

100

£2.?)

N

BSV

0.016

4,4-DDE

5/6

1.4

4.9

100

£2,7)

N

BSV

0.014

4,4'-DDT

6 -6

5.2

7.7

100

m

N

BSV

O.O 52

Endosulfan II

1 -6

0,51

1.0

100



N

BSV

0,0051

Endrin

4-6

\A

N'A

N'A



Y



N-A

Endrin Ketone

36

0.87

N"-A

N'A



Y



N-A

Heptachlor Epoxide

2-6

0,75

2.0

50

(2. 10)

N

BSV

0.015

Methosychlor

3 6

4,(3

l.B

N-A



Y



N-A

M eta If (mg/kg)

















Aluminum

6 -6

9.470

9630

NA



N

I4KGD

N'A

Arsenic

6-6

4,S

7.6

60

(12)

N

BSV

0.080

Barium

6 6

46

32

400

(13)

N

BSV

0.12

Calcium

6*6

1.180

949

K-A



N

EAX

N-'A

Chromium

4/6

24

N A

0.4

' (12)

Y



59

Cobalt

6 *6

6.5

NA

50

(51)

N

BSV

0.13

Copper

5-6

20

8.9

50

(12)

N

BSV

0.39

Iron

6 / 6

13,600

8.350

N-A



Y



NA

Ixa d

6.- 6

248

102

500

(12)

N

BSV

0.50

Magnesium

6 - 6

3.780

1.480

N;A



N

HAN

N'A

Manganese

6 / 6

212

206

1.500

(2)

N

BSV

0.14

Potassium

5/6

E.990

N'A

N.A



N

BAN

N-A

Vanadium

6: 6

20

14

150

(2)

N

BSV

0.13

Zinc

6 - 6

59

47

200

(12)

N

BSV

0,30

~.	In ihis screening table, the hazard quotient is calculated by dividing the maximum detection by the screening value,

N-'A - Not Applicable or Not Available

CQC - Confminam of Concern

BSV - Below screening value

DF - Dec (ion frequency less than 5% site-wide

EAN- Essential animal nutrient

BKGD* Background comparison

Souses:

1.	Fitchko,

2.	Maximum allowable soil concenmaiion in the former Soviet Union (as cited in Beyer 1990),

3.	Value for ga mma-B HC( Li rtdane) conservatively used.

4.	indicative of moderate soil contamination as designated by the soil cleanup criteria of Quebec (as cited in Beyer 1990),

5.	Acceptable concentration proposed by Ontario Ministry of Environment fas cited in Beyer 1990)

~,	Kappieman (1993),

7. For Screening purposes, maximum allowable DDT concentration was used for DDE and DDT.
fi. Decreased cocoon production by Eisenia fetida (Reinccke and Venter 1985 as cited in Beyer 1990).

9.	Tenative allowable concentration for endosulfan in the former Soviet Union (as cited in Beyer 1990).

10.	Value for heplachlar,

H. Soil criteria for evaluating the severity of contamination under the Dutch Soil Cleanup (Interim) Act (as cited in Beyer 1990).

12.	Will and Suter(l994).

13.	Guidelines for the New Jersey Environmental Cleanup Responsibility Act (as cited in Beyer 1990).

Page I of I

-------
TABLE G-iO
SOIL COPC SCREENING
B&M LOCOMOTIVE SHOP DISPOSAL AREA
Iron Horse Park Superfund Site, 013
North Billeriea, MA







Maximum



Source of









Frequency of

Maximum

Background

F,cofogical Soil

Ecological





Hiiird

Aoalvte

Detecdoa

Soil Cone,

Soil Cone.

Screening Level

Screening Level

COC?

Reason

Quotient {a)

VOCl (ug/kgt

















Methylene Chloride

2-5

-t |

36

N-A



V



N'A

SVOCs (ug/kg)

















Accnaphihene

I S

790

VA

NA



Y



N'A

Acenaphihylene

i-S

20

N-A

N-A



Y



N-A

Anthracene

2; 5

1.500

N-A

10.000

(11)

N

BSV

0.15

Benzo{a}ai«hraeene

4; 5

2.300

NVA

1.000

(4)

Y



2.3

Beazo{a)pyn:nc

4.' S

1.700

K'A

5

(5)

Y



340

BcnzoCblHuDranthcne

4 •' 5

2.900

N-A

19.000

(6)

N

BSV

0.15

Bcnzo{ g,h.i)pcrvlene

3/5

960

N.'A

1,000

(I)

N

BSV

0,96

BenzoA

Fluoranlhcnc

5/5

4.20Q

NVA

10,000

{iii

N

BSV

0.42

Fluorene

1 .-5

760

N-A

30.000

(12)

N

BSV

0.025

lndeno(1,2,3-cd)pyrene

3 5

920

N-"A

1.000

£U

N

BSV

0.92

2-Methylriaphthalene

25

370

N-A

NVA



Y



NA

Naphiharene

2-'S

im

NA

5,000

(U)

N

BSV

0,058

Phenamhrene

5-5

5.900

N'A

5,000

(11)

Y



1.2

Pyrcne

5:5

4,800

N-A

10,000

(in

N

BSV

0.48

PCBi/PeiticIdes (ugftig)

















Aldrin

3.-5

2.8

N-A

N;A



Y



NA

bcia-BHC

1 ¦ 5

0.96

N;A

100

(2. 3)

N

BSV

0.0096

alpha-Chlordane

3/5

1.0

0,2?

500

(O

N

BSV

0.0920

ga mma • Chlordane

3 / 5

4.0

VA

500

O)

N

BSV

0.0080

4.4-DDD

4-5

s.o

2.6

100

(2.?)

N

BSV

0.050

4,4'-DDE

3 *5

2.4

4.9

100

(2.7)

N

BSV

0,024

4.4-DDT

4*' 5

9.3

1,1

100

<21

N

BSV

0.093

Dietdrin

1 -5

1.7

2,1

10

<«>

N

BSV

O.i?

Endosulfan II

3 -5

2,0

1.0

100

m

N

BSV

0,020

Endrin

5 •' 5

3.5

N-'A

N.A



Y



N'A

Endrin Ketone

1 -5

5.6

N»'A

NA



Y



N-A

Hepiachlor Epoxide

3 5

1.8

2.0

50

a. io)

N

BSV

0.036

Methoxvehlor

2 - 5

19

1.8

N-A



Y



N-A

Aroclor-1016

I '5

2 2

N-A

N.'A



N

f)F

N'A

Metali (mg/kg)

















Aluminum

5 5

7.660

0.630

N-A



N

BKGI)

N'A

Antimony

2 ¦ 5

53

N.'A

4.5

(2)

Y



12

Arsenic

5-'5

49

7.6

60

on

N

BSV

0.82

Barium

5-5

342

32

400

(13)

N

BSV

0.85

Beryllium

1 -5

0.85

N-A

1

(13)

N

DY

0.85

Cadmium

I -5

1.0

N-'A

20

(2)

N

BSV

o.oso

Calcium

5 5

6.090

949

N-A



N

EAN

N-'A

Chromium

4-5

87

N-A

0.4

(12)

Y



219

Cob all

4-5

14

N-'A

50

(in

N

BSV

0.28

Copper

5-5

3.135

8,9

50

£12}

Y



63

Cyanide

2-5

0,94

N-A

50

(11)

N

BSV

0.0(9

Iron

5-'5

101.350

8.350

N-A



Y



N-A

Lead

4*5

2.370

102

500

(12}

Y



4,7

Magnesium

5-5

4.225

1.480

N-A



N

EAN

N-'A

Manganese

5-5

91?

206

1500

(2)

N

BSV

0.61

Mercury

1 -'5

0.19

N-'A

0,1

£12)

Y



1,9

Nickel

3 - 5

46

N A

200

(12)

N

BSV

0.23

Potassium

3 '5

1.660

N-'A

N A



N

FAN

N-'A

Selenium

2 - 5

5.5

N-A

70

(12)

N

BSV

0.079

Sodium

I -"5

13,000

N-A

VA



N

FAN

HA

Tha Ilium

1 -5

0,57

N-A

N-'A



N

DF

N'A

Vanadium

5-5

IB

34

150

(2)

N

BSV

0.12

Elite

5 5

m

4?

200

(12)

Y



4.1

Page I of 2

-------
TABLE G-iO
SOIL COPC SCREENING
BSOA LOCOMOTIVE SHOP DISPOSAL AREA
Iron Horse Park Superfund She, Ot.'3
North BiHeiica, MA







Maximum



Source of









Frequency of

Maximum

Background

Ecological Soli

Ecological





Hazard

Analyte

Detection

Soil Corn:.

Soil Cone.

Screening Level

Screening Level

COC?

Reason

Quotient (a)

~.	In ill is screening table. the hazard quotient is calculated by dividing the maximum detection by the screening value.

N'A ¦ Not Applicable or Not Available

COC - Contmmam of Concern

BSV - Below screening value

DF • Dec Hon frequency less than 5% site-wide

EAN- Essential animal nutrient

BKGD - Background comparison

Sources:

1.	Fitchko(1989).

2.	Maximum allowable soil concentration in (lie former Soviet Union (as cited in Beyer 1990).

3.	Value for gamma¦ BHCf Lindane) conservatively used.

4.	indicative of moderate soil contamination as designated by the soil cleanup criteria of Quebec (as cited in Beyer 1990),

5.	Acceptable concentration proposed by Ontario Ministry of Environment (as cited in Beyer 1990).

~.	Kappleman (1993).

1. For Screening purposes, maximum allowable DDT concentration was used for DDE and DDT.

8.	Decreased cocoon production by Eisenia fetida (Reinecke and Venter 1985 as cited in Beyer 1990),

9.	Tenative allowable concentration forendosulfan in the former Soviet Union (as cited in Beyer 1990),

10.	Value for heptachlor,

11 - Soil criteria for evaluating the severity of contamination under.the Dutch Soil Cleanup (Interim) Act (as cited in Beyer 1990).

12.	will and Sucer( 1994),

13,	Guidelines for the New Jersey Environmental Cleanup Responsibility Act (as cited in Beyer 1990).

Page 2 of 2

-------
TABLE 7-1. ABBREVIATED COMPARATIVE ANALYSIS OF THE REMEDIAL TECHNOLOGIES FOR

B&M RAILROAD LANDFILL

V

Overall Protection nf Humm Health and the

Environment

Protection of Human Health:

Docs naUscccd risk limits

Ecological Prelection:

~ ¦ No Protection, CI - Partial!)

WA
~

Protective, ¦ - Protective

N/A
~

N/A
~

¦
¦

Compliance with ARARs

~ ¦ Does Not Meet, E2 - May Not Met l/Partially Meets, ¦ - Met

a ~

ts

D

¦

Lone-Term Effectiveness And Permanence

Magnitude of Residual Risk - Human Health:
Docs no! exceed risk limits

Magnitude of Rciidum] Ruk - Ecological:

~ - No Protection, B - Partially
N/A

Q

Protective, ¦ - Protective
N/A

a

N/A
~

¦
¦

Reduction ofToiiciiv, Mohilitv and Volume
through Treatment

Treatment/Recycling Processes Utilized

Amount of Hazardous Maieriuls Treated or
Recycled:

None

D - tow, B - Moderate, ¦ - Hi
N/A - No treatment

None

gh

N/A - No treatment

None
N/A * No treatment

None
N/A - No treatment

Degree oT Expected Reductionsin Toxicity,
Mobility or Volume;

Irreversibility

~	- Low, ~ - Moderate, ¦ • High

N/A - No ETtaimcm | N/A - No treatment

~	- Reversible, £2 - Moderately Reversible, ¦ - Irreversible

N/A ¦ No tfeatmcnl J N/A - No treatment

N/A - No treatment.
N/A - No treatment

N/A - No treatment
N/A-No treatment

Type and Quantity of (Process] Residuals

~ - High, B - Moderate, ¦ - Low

N/A - No irefl tment 1 N/A - No treatment

N/A - No treatment

N/A - No treatment

Short-Term Effectiveness

Protection of Community and Workers

During Remedial Actions
Environmental Impacts
Time Until Remedial Action Objectives
arte Achieved

~ - High Impacts, S - Mwfcrat

¦

¦

>30 yeans

Impacts, ¦ - Low Impacts

¦

¦

>30 years

¦

¦

>30 years

¦

£2

2 years

Imolpmentabllltv

Technical Feasibility:

Construction, operation & maintcnatKC
Reliability in achieving RAOs
Implementation of future actions

~ - High Eflbri/Low Reliability

¦

~

¦

B - Moderate Effort/Moderate

¦

~

¦

.^liability. ¦ - Low Effort/H igh

¦

3
¦

Reliability

~
¦

H

Administrative Feasibility

~ - High Effort, B - Moderate to High Elton, ¦ - Low to Moderaie Effort

¦ 1 ¦ | ¦

¦

Availability of Services and Material!

~ • High Effort/Not Commonly

¦m

Available, B - Moderate Effort <
¦

c Availability, ¦ - Low EfTort/Cc
¦

mmortly Available
¦

Cost

Capital (Smiliion)

O&M (Smiliion)

Total (Smiliion)

Additional Groundwater Monitoring •
Five years - Total (Smiliion)

$0,00
SQ.OO
50.00

$0.00

SO. 16
SO. 12
$0.28

$0.62

SO. 16
SO. 19
$0.35

S0.62

$8.87
SfiJl
$9.04

$0.62

N/A ¦ Not Applicable

Iron Hotsc Park 3rd OU-FS

Page 1 of7

Version: January 2004

-------
TABLE 7-3. ABBREVIATED COMPARATIVE ANALYSIS OF THE REMEDIAL TECHNOLOGIES FOR

RSI LANDFILL

T

£

41 A A SS A* ss

£ * fi
* /**#£

	

Overall Protection of Human Health and Ihe
Environment

Protection of Human Health;

Docs no! exceed risk limits

Ecological Protection:

Does not exceed risk limits

0 - No Protection, 3 - Partially Protective, ¦ - Protective

N/A
N/A

¦

N/A

CompllBiige with ftRARa

~ • Docs Not Meet, B - May Not Mcct/Pariially Meets, ¦

~

Mix Is

¦

Lonp-Term Effectiveness And Permanence

Magnitude of Residual Risk - Human Health:
Docs not exceed risk limits

Magnitude of Residual Risk - Ecological:

Docs not exceed risk limits

~ - No Protection, B - Partially Protective, ¦ - Protective

WA
N/A

¦

N/A

Reduction of Toxicity. Mobility and Volume
throuph Treatment

Treatment/Recycling Processes Utilized

Amount of Hazardous Materials Treated or
Recycled:

None

~ - Low, ~ - Moderate, ¦ - High
N/A

None
N/A

Degree of E*pcetcd Reductions in Toxicity,
Mobility or Volume:

Irreversibility

Type and Quantity of [Process] Residuals

~	- Low, B - Moderate, ¦ - High

N/A

~	- Reversible, B - Moderately Reversible, ¦ - Irreversible

N/A

~	- High, B - Moderate, B • Low

WA

N/A
N/A
N/A

Short-Term Effectiveness

Protection nf Community and Workers

During Remedial Actions
Environmental Impacts
Time Until Remedial Action Objectives
arc Achieved

~ ¦ High Impacts, B - Moderate Impacts, ¦ - Low Impacts

¦

¦

N/A

¦

OF

WA™

rmulementnhilitv

Technical Feasibility;

Construction, operation & maintenance
Reliability in achieving RAOs
Implementation of future actions

~ - High Effort/Low Reliability, B - Moderate Effort/Mode
¦

WA
¦

rate Reliability, ¦ - Low Effort/High Reliability

m

N/A'1'
a

Administrative Feasibility

~ • High Effort, S • Moderate to High Effort, ¦ - Low lo Moderate Effort

¦ j ¦

Availability oF Services and Materials

O * High Effort/Not Commonly Available, B - Moderate EJ
¦

bit & Availability, ¦ - Low Effort/Commonly Available
¦

Cost

Capital (Smillion)

O&M (Smillion)

Total (Smillion)

Additional Groundwater Monitoring ~
Five years - Total (Smillion)

S0.00
S0.00
S0.0G

so.oo

$1.84

S0.03
51.87

$0.62

N/A - Not Applicable

(i) There arc no remedial action objectives (RAOs) for contaminated soils at this AOC, However, RAOs exist for groundwater, and installation of a cap is a groundwater
source control remedy, RAOs for groundwater source control arc expected to be achieved in 2 years and capping for groundwater source control is considered highly
reliable.

Iron Horse Park 3rd OU-FS

Page 2 of7

Version; January 2004

-------
TABLE 7-5. ABBREVIATED COMPARATIVE ANALYSIS OF THE REMEDIAL TECHNOLOGIES FOR
B&M LOCOMOTIVE SHOP DISPOSAL AREAS

/ ^ / t / > / // / / ? / y /

/ ? / s• / J / ¦&£/.>/ 4 / J /

/ ? / S / # / ££ / & / 9 / 9 /
/ * / J / * / / / ° / ° /

/ / * / /**/ / / /

Overall Protection of Humm Health *nd the
Environment

Protection of Humm Health:

Ecological Protection:

~ ~ I

R
$

1 - Partially Protect!

~

O

ve, ¦ • Protective

0
0

¦

¦

¦

¦

¦

¦

¦
¦



~ • Does Not Meet* £2 - May Nal Meet/Partially Meets,¦ - 1

~ on

rlcCtS

a

¦

¦

¦

Lone-Term Effectiveness And Permanence
Magnitude of Rtsldual Risk - Human Health:

Magnitude of i&sldual Risk - Ecological;

~ ¦ No Protection.

o
o

2 - Partially Protect!

o

o

ve,B - Protective
~

O

¦

¦

¦

¦

¦

¦

¦
¦

Reduction of Toilrltv. Mobility and Volume
through Treatment

Treatment/Recycling Processes Utilized

Amount of Hazardous Materials Treated or
Recycled;

Degree of Expected Reductions la Toxicity,
Mobility or Volume;

None

~	- Low, Q - Mode

N/A

~	- Low, QT - Mode

WA

None

rate, 11 - High

N/A

rate, ¦ - High
N/A

None

N/A
N/A

None

N/A
N/A

None

N/A
N/A

Solidification/
Stabilization

¦

¦

Soil Washing/
Chemical
Extraction

¦

¦

Irrevcnlblllty

~ • Reversible, B - Moderately Reverse

N/A j N/A

lc.ll - Irreversible
N/A

N/A

N/A

a

¦

Type sad Quantity of |Procru| Residuals

~ - High, (2 - Moderate, ¦ • Low

N/A 1 N/A

N/A

N/A

N/A

m

a

Short-Term Effectiveness

Prelection of Community and Workers

During Remedial Actions
Environmental Impacts
Time Until Remedial Action Objectives
are Achieved

~ -IHgh Impacts, G

¦

¦

>30years

[ - Moderate Impact.

¦

¦

>30 years

,¦ - Low Impairs

¦

¦

>30 yews

¦

a

2 yea ra

¦

a

2 years

m

a

3 years

m

a

3 years

ImDlcmentabllltv

Technical Fewlblllty:

Construction, operation & maintenance
Reliability m achieving RAOa
Implementation of funs re actions

~ ¦ High EtToft/Lov

¦

a
¦

t Reliability, Ql - Mo

¦

D
¦

derate Effort/Modem

¦

CI
¦

tc Reliability,!»Lc

a
¦

a

w EfTon/Iligh Relia

a
¦

a

?ility

a
¦

a

a
¦

a

Administrative Feasibility
Availability ofServIca and Materials

~ - High Elton, Q
¦

~«High Effort/Nat
¦

Moderate to High £
¦

Commonly Availab
¦

nbrt, ¦ - Low to Mc
¦

e.H • Moderate Effc
¦

idcfaEc Effort
¦

n £ Availability, ¦
¦

¦

• Low Effort/Commc
¦

¦

mly Available
~

¦

a

Coti

Capital (Smiliion)

O&M (5 million)

Total (Stnillion)

Additions) Groundwajer Monitoring •
Five years - Total (SmilJion)

so.oo

S0.00

so.oo
so.oo

SO, 13
SO. 11

S0.24

S0.53

SO. 13
SO. 17

50,30
S0.53

S1.96
SO. 12
S2.0S

S053

58,15
SO.OO
SS.IS

S0.53

533.63
SO.OO
$33.63

S0.S3

S42.Q6
so.oo
542.06

Sfl.53

N/A - Nol Applicable

Iron Ilorsc Park 3rd OU-FS

Pitgc 3 of?

Version: January 20Q4

-------
TABLE 1-1. ABBREVIATED COMPARATIVE ANALYSIS OF THE REMEDIAL TECHNOLOGIES FOR
OLD B&M OIL/SLUDGE RECYCLING AREA

Overall Protection of Human Health and the
Environment

Protection of Huniia Health:

Ecological Protection:

Docs not exceed risk limits

~ -No Prelection,

o

N/A

i • Partially Protecti

o

N/A

vc,l - Protective

o

N/A

¦

N/A

¦

N/A

¦

N/A

¦

N/A

ComBliincc with ARARs

~ - Docs Not Meet, S - May Not Meet/fanially Mccts,B -1

~ 1 ~ 1 O

rfects

¦

¦

¦

m

Lone-Term Eflfretlvetnai And Permanence
Magnitude of Rotdoml Rlifc - Human Heilth:

Magnitude of Residual Risk - Ecological:
Docs not. exceed risk limils

~ - No Protection,
~

N/A

2 * Partially Praiccti
~

N/A

wc,B • Protective

o

N/A

¦

N/A

¦

N/A

¦

N/A

m

N/A

Reduction of Toiicitv. Mobility and Volume
throueh T reatmem

rretttmem/RccycHo|j Protects Utilized

None

None

None

None

None

Salidi nation/
Stabilization

¦

Soil Washing/
Chemical
Extraction

¦

Amount of Hazardous Materials Treaftd or
Recycled:

0 - Low, 9 - Moderate, ¦ - High

N/A | N/A

N/A

N/A

N/A

Degree or Eipected Reductions In Tonicity,
Mobility or Volume:

Irreversibility

~	-Law, B - Moderate. ¦ - High

N/A | N/A

~	- Reversible, H - Moderately Revefsii

WA I N/A

N/A

ic,Ri - Irreversible
N/A

N/A
N/A

N/A
N/A

¦

a

¦
¦

Type sod Quantity of|Procaj| ReaJduali

~ • High, (2 • Moderate. ¦ - Low

N/A N/A

N/A

N/A

N/A

¦

a

Short-Term Effectiveness

Prelection of ComcnuDify and Workers

During Remedial Actions
Environmental Impacts
rime Until Remedial Action Objective*
art Achieved

~ - High Impacts, Eli

¦

¦

>30 years

: ¦ Moderate Impact

¦

¦

>30 year?

„¦ - Low Impacts

¦

¦

>30 year?

¦

a

2 years

¦

ia

2 year*

¦

a

2 year?

¦

a

2 years

ItnDlcmentiblNtv

Technical Feasibility:

Construction, operation & maintenance
Reliability in achieving RAOs
Implementation or future actions

Administrative Feasibility

~	• High Eflbn/Lou

¦

O
¦

~	- High Effort, Q

¦

i?Reliability,a-Ma

¦

~

¦

Moderate to High E
¦

derate E Hart/Mod en

¦

a
¦

flart. ¦ - Low to M
¦

le Reliability,! - Le

a
¦

a

xierate Effort
¦

w EiTort/High Relia

a
¦

a

¦

jillty

Q
¦

a

m

a
¦

a

¦

Avi llibllJ ty oT Service* an d Mate rl all

~ - High Eflbrl/No
¦

Commonly Avaitab

m

c.D • Moderate Elf
¦

n & Availability, ¦
¦

- Low EfTon/Commc
¦

nly Available

m

m

Cost

Cap ita!(Smi1 lion)

0<&M (Smillion)

Total (Smillion)

Additional Groundwater Monitoring-
Five yean - Total (Smil 1 ion)

SG.OO
SQ.QQ
moo

$0.00

SO. 12

sa.il

SO,23
50,62

SO. 12
SQ.I6
S028

S0.62

SI.16
SQ.33
SI.49

SO,62

S4.99
SO.OO
S4.99

50,62

SI 5.60
SO.OO
SI 5,60

S0.62

S 20.56

SO.OO
520,56

S0.62

N/A - Not Applicable

Iron liorec Park 3rd OU-FS

Page 4 of7

Version: January200-1

-------
TABLE 7-9. ABBREVIATED COMPARATIVE ANALYSIS OF THE REMEDIAL TECHNOLOGIES FOR

CONTAMINATED SOILS AREA

Overall Protection of Human Health and Ihr
Environment

Protection of Human Health;

Ecological Protection:

Docs not exceed risk Limits

~ - No Fral

O

N/A

:ciion, B Pi

o
N/A

lriially Protec
~

N/A

ivc, ¦ • Prat
¦

N/A

relive

¦

N/A

¦

N/A

m

N/A

¦

N/A

¦

Wh

Comoliancc with ARARs

~ - Docs Not Meet, B - May Not Meet/Partially Meets, ¦ - Meet

~ 1 ~ | ~ I ¦ 1 ¦

¦

¦

¦

¦

Lone-Term Effectiveness And Permenrnrp
Magnitude of Residual Risk - Human Health:

Magnitude orRcsidual Risk - Ecological;
Docs not exceed risk limits

~ -NoProl
~

N/A

etion, B - Pa

O

N/A

irtially Protec

O

N/A

ivc, ¦ • Prat
¦

N/A

*tfivc

¦

N/A

¦

N/A

¦

N/A

¦

N/A

¦

N/A

Reduction of Toxicity. Mobilitv and Volume
through Treatment

Treatment/Recycling Processes Utilized

None

None

None

Solidifica-
liorv'Stabili-
zalion

Enhanced
Biodcgr./
Soil

Flushing

None

Assume Off

Site
Solidiflca-
tion/SiabilU
zation

Solidifica-
ii on/Stabili-
sation

Soil
Washing/
Chemical
Extraction

Amount of Hazardous Materials Treated or
Recycled:

Degree of Expected Rcduclions in Toxicity,
Mobility or Volume:

~	- Low, B - Moderate, ¦ ¦ High

N/A j N/A | N/A

~	- Low, Q • Moderate, ¦ - High

N/A 1 N/A 1 N/A

¦

a

¦

a

N/A
N/A

¦
¦

¦
¦

¦
¦

Irreversibility

O - Reversible, 9 Moderately Revere

N/A j N/A 1 N/A

hie, ¦ • Irrev

a

ersibfe
¦

N/A

¦

a

¦

Type and Quantity of|Proccss] Residuals

~ - High, B - Moderate, ¦ - Low

N/A 1 N/A I N/A

¦

¦

N/A

¦

¦

a

Short-Term Effectiveness

Protection of Community and Workers

During Remedial Actions
Environmental Impacts
Time Until Remedial Action Objectives
arc Acbieved

~ - High lm

¦

¦

>30 years

?3CtS, B - Mc

¦

¦

>30 years

derate Impac

¦

¦

>30 years

LS, ¦ - Low [

¦

a

2 years

npacts

¦

a

2 years

¦

a

2 years

¦

a

2 years

¦

B

2 years

¦

a

2 years

Implemenlabilitv

Technical Feasibility:

Construe lion, operation & maintenance
Reliability in achieving RAOs
Implementation of future actions

D ¦ High Efl

¦

~

¦

1 ¦ a ¦

*
o

ct;

|f

¦ ~ ¦ Q

2

ode rate Effon

a
a
a

[/Moderate R<

a
m

a

liability, ¦ -

~

¦

a

Low Effart/H

m
¦

a

igh Reliabilit

a
¦

a

y

a
¦

a

Administrative Feasibility

~ ¦ High Effort., £3 - Moderate to High Effort, ¦ - Low to Moderate Effort
¦ ¦¦¦¦¦

¦

¦

¦

Availability of Services and Materials

~ - High Eff
¦

on/Not Comn
¦

nonly Availal
¦

ile, B - Mode

a

rate Effort &

m

Availability,
¦

¦ • Low EfTo

a

it/Commonly

a

Available

m

Cost

Capital (Smillion)

O&M (Smillion)

Total (Smillion)

Additional Groundwater Monitoring -
Five years - Total (Smillion)

so.oo

SO.OO
SO.OO

SO.OO

50.	15
50,20
$0.35

51.E9

$0.15
SQ.24
$0.39

SI, 19

SI.06
SO.OO
SI.06

SI.19

S9.Q4
S0.Q0
S9.04

SI.19

S0J9
S0.32
SI.21

SI, 19

S6.64
SO.OO
S6.64

SI.19

57.01

SO.OO
$7,01

SI,19

$10.40
SO.OO
SI 0.40

sue

N/A - Nol Applicable

Iron Horse Park 3rd OU-FS

Page 5 of?

Version: January 2004

-------
TABLE 7-11. ABBREVIATED COMPARATIVE ANALYSIS OF THE REMEDIAL TECHNOLOGIES FOR

ASBESTOS LANDFILL

.£ ^

Overall Protection of Human Health and Ihc
Environment

Protection of Human Health:

Ecological Protection;

Docs not exceed risk limits

0 • No Protection, B - Partially Protective, ¦ - Protective

a

N/A

¦

N/A

ComnNancc with ARARx

~ - Docs Not Meet, B - May Not Meet/Partially Meets, ¦

~

Meets

¦

Lonp-Term ElTccrivcncss And Permanence
Magnitude of Residual Risk - Human Health:

Magnitude of Residual Risk- Ecological;
Docs not exceed risk limits

~ - No Protection, £2 - Partially Protective, ¦ - Protective
U

N/A

¦

WA

Reduction of Toxicity. Mobility and Volume
throuah Treatment

rrcoEmcnt/Recycling Processes Utilized

Amount of Hazardous Materials Treated or
Recycled:

Degree of Expected Reductions In Toxicity,
Mobility or Volumci

None

~	- Low, 9 - Moderate, ¦ - High

N/A

~	- Low. B - Moderate, ¦ - High

WA

None

N/A

N/A

Irreversibility

~ - Reversible, £2 * Modcralcly Reversible, ¦ - Irreversible
N/A

N/A

Type and Quantity of [Process] Residual*

~ - High, B - Moderate. ¦ - Low

N/A

M/A

Short-Term Effectiveness

Protection of Community and Workers

During Remedial Actions
Environmental Impacts

Time Until Remedial Action Objectives
arc Achieved

~ - High Impacts, fit - Moderate Impacts, ¦ - Low Impacts
N/A
¦

0 years

¦

¦

0 years (existing cap is protective)

Ittiolciti ratability

Technical Feasibility:

Construction, operation & maintenance
Reliability in achieving RAOs
Implementation of future actions

~ - High Effort/Low Reliability, B - Moderate Effort/Mode

~
a

~

rate Reliability, ¦ - Law Effort/High Reliability

¦

¦

¦

Administrative Feasibility

~ - High Effort, B - Moderate to High Effort, ¦ • Low to Moderate Effort

¦ ¦

Availability of Services and Materials

~ - High Effort/Not Commonly Available, B - Moderate El
¦

bit & Availability, ¦ - Low Effort/Commonly Available
¦

Cost

Capita! (Smillion)

O&M (Smillion)

Total (Smillion)

Additional Groundwater Monitoring *
Five ycare ¦ Total (Smillion)

S0.GO
S0.00
S0.OO

S0.0Q

$0.20
$0,4$

$0.91

N/A • Not Applicable

Iron Horse Park 3rd OU-FS

Page 6 of 7

Version: January 2004

-------
TABLE 7-13. ABBREVIATED COMPARATIVE ANALYSIS OF THE REMEDIAL TECHNOLOGIES FOR

ASBESTOS LAGOONS

//
& V

$

Overall Prolrctlsn of Human Health and the
Environment

Protection of Human Health;

Ecological Protection:

Docs not exceed risk limils

~ • No Protection, D - PariJali

~

N/A

y Praieclive, ¦ Protective

~

N/A

¦

N/A

¦

N/A

Compliance with ARARs

~ - Does Not Meet, H - May Not Meet/Partially Meets, ¦ - M

~ Q

tets

¦

¦

Lonc-Tcrm Effectiveness And Permanence
Magnitude of Residue! Risk- Human Health:

Magnitude of Residual Risk - Ecological:
Does not exceed risk limils

~ - No Protection, B - Partial I

~

N/A

i Protective, ¦ - Protective
B

N/A

¦

n/a

¦

N/A

Reduction ofToilcUv. Mobility and Volume
throuph Treatment

rrea tin ent/Rccye Ling Processes Utilized

None

None

None

None

Amount oT Hazardous Materials Treated or
Recycled:

~ - Low, Of - Moderate, ¦ - High.

N/A j N/A

N/A

N/A

Degree of Expected Reductions In Toxicity,
Mobility or Volume;

O • Low, 3 - Moderate, ¦ - High

N/A 1 N/A

N/A

N/A

Irreversibility

Type and Quantity of [Process! Residuals

~	- Reversible, E2 - Moderately Reversible, ¦ - Irreversible

N/A | N/A

~	- High, 9 - Moderate, ¦ - Low

WA N/A

N/A

N/A

N/A
N/A

Short-Term Effectiveness

Protection of Community and Workers

During Remedial Actions
Environmental Impacts
Time Until Remedial Action Objectives
arc Achieved

~ ¦ High Impacts, 9 - Modcra

¦

¦

>30 years

e Impacts, ¦ - Low Impacts

¦

¦

>30 years

¦

a

2 years

¦

a

2 yeais

lirolemenlabllltv

Technical Feasibility:

Construction, operation & maintenance
Reliability in achieving RAOs
Implementation of fulure actions

~ • High Effort/Low Reliabilit;

¦

O
¦

, 3 - Moderate Effort/Moderate

¦

~

¦

Reliability, ¦ - Low EJTort/Hig

a
¦

m

i Reliability

~
¦

B

Administrative Feasibility

~ - High Effort, S • Moderate Id High Effort, ¦ • Low to Moderate Effort

¦ ¦ ! ¦

¦

Availability of Services and Materials

~ - High E[Tort/Not Commonly
¦

Available, £2' Moderate Effort
¦

St Availability, ¦ - Low Effort/
¦

I

a
>

m 1

&

Cost

Capital (Sm ill ion)

0&M(Smillion)

Total (Smiilion)

Additional Groundwater Monitoring -
Five yean - Total (Smiilion)

S0.00
SM
50.00

so,00

$0.08

SO. 13
50,21

S0.64

S2J5

mi

S2.26

50.64

$1.33
S0.00
SI.33

S0.64

N/A - Not Applicable

Iron Horse Park 3rdOU-FS

Page 7 of?

Vcrsrour January 2004

-------
TABLE L-1. COST ESTIMATE SUMMARY FOR THE SELECTED REMEDY

Capital Costs fat Remedy - MM Railroad Landfill





QUAN-
TITY



HANI

IOURS

MATERIAL

LABOR

equipment

TOTAL



BASIS

UN

MH/
UNIT

TOTAL
MH

UNIT
COST

TOTAL
MATL

WAGE
RATE

TOTAL
LABOR

UNIT
RATE

TOTAL
EQUIP

DIRECT
COST

Horizontal Conlainmrnl

























CompoiiK I Double Barrier Cap
Demolition, Removal & Disposal

Site Preparation
Krosion Control

Dust Control

Clearing & grubbing - very light effort
(mow)

llaybak/sill fence perimeter
large effort during excavation and
grading

1.0

11.0

2.62}

1

AC

AC
LF

LS

200.00

48.00
0.05

640.00

2.100

528
131

640

0.00

0,00
1.75

0.00

0
0

4.594
0

$50,00

$50.00
$50.00

5SO.OO

UO.DOO

26,400
6.563

32.000

12.000
1.150,00

56.000

132,000

12,650
0

56.000

$242,000

$39,050
SI 1.156

$88,000

Waste Excavation
Sheet Piling

Excavate 50' width of waste, S feel deep
l-'se for excavation along wetland
perimeter

16.315
17.620

CY
SF

O.IO
0.08

1.632
1.410

0.00
12.00

0

211,440

$50.00
$50.00

H 1.5 75
70.4*0

1.41
2.00

23.004
35,240

$104,579
S317,160

Groundwater Collection and Treatment

Use during excavation, SOgpm

I

I.S

500.00

500

50,000

50,000

$50.00

25.000

10.000

10.000

$H 5.000

Backfill

Place in excavation, ordinary borrow

20,400

CY

0.10

2.040

12.00

244,800

550.00

102.000

1,41

28,764

$375,564

Landfill Grading

Soil Subgrade
Gas Vent Ijyer
Gcotextile

Grade waste and slopes of landfill
Granular fill c|,5 inches, 12". 1 lia
likely

Sand layvr - 12" thickness
Typical, 12 oz.

11

21,800
21,»00
52.229

AC

CY
CY
SY

20.00

0.10
0.12
0.01

220

2,1X0
2.616
522

0,00

12.00
R.OO
1.35

0

261.600
174.400
70.509

550.00

$50.00
S50.00
550.00

11.000

109,000
130.800
26.115

600,00

2.00
1.65
0.05

6.600

43.600
35.970
2.611

$17,600

$414,200
1341.170
599,236

Low Permeability Soil 
-------
TABLE L-l. COST ESTIMATE SUMMARY FOR THE SELECTED REMEDY

DESCRIPTION







MANHOURS

| MATERIAL

LABOR

EQUIPMENT

TOTAL

BASIS

QUAN-
TITY

UN

HW
UNIT

TOTAL
MH

UNIT

COST

TOTAL
MATL

WAGE
RATE

TOTAL
LABOR

UNIT
RATE

TOTAL
EQUIP

DIRECT

COST

Detention Basins

Use 2 basins, 100' x 75' * 4' depth

2.222

CY

0,10

222

0.00

0

550.00

11.110

1.41

3,133

514,243

Geotexttle
3as Vents

Settling Monuments

I Ise for toe drains and swales. 12 at.
Use 11 vcnls - typical vents & risers (-18

ft)

4.083

11

2

SY

f.a

EA

0,01

30,00
4.00

41

330
H

1.35

400,00
100.00

5.513

4,400
200

$50.00

$50,00
$50.00

2.042

16.500
4K1

0,05
100,00

204

1.100
0

57.758

522,000
$600

Piezometer Installation, 1" ScH. 80 PVC
Piezometer Wellheads • Corrugated HDPl:
[."overs

Security Fencing - 8' Chain Link
Gales - Double Swing Door (20')

6 @ 40ft deep
6 piezometers

Perimeter, top rail and bottom tension
wire

240
6

3.150
2

LP

EA

IE

EA

0.30

1.00

0.16
22.00

72
6

504
44

6.00

100.00

16.00
1,200

1,440

600

50,400
2,400

$50.00

550.00

150,00
$50.00

3.600

300

25,200
2,200

H.Q0

3.00
370.00

1.920
0

9.450
740

».9M>

5900

585,050
$5,340

Signage •• Warning: Hazardous Waste Area



1

IS

2.00

2

100.00

1(H)

$50,00

100



0

$200

Access Roadway - grading & compaction
Access Roadway - gravel

10 ft wide. 1575 ft long
10 ft wide w/6" crashed stone

1.750
1,750

SY

SY

0.05
0-01

84
49

0.00
7.70

0

13,475

$50.00
S50.0CS

4.200
2.450

1.62
1 42

2.835
2.485

$7,035
Sti.410

SUBTOTAL DIRECT COSTS









36,197



2,537,909



1 J09.R75



599.268

54.947.052

CONTRACTOR OVERHEAD & PROFIT
SUBTOTAL

C ONTRACTOR'S CONTINGENCY
SUBTOTAL (rounded)
BIDDING/DESIGN,CONSTRUCTION
SUPERVISION
EP/VMADHP OVERSIGHT



21.00%
20,00%



















51.038.881
55.985.933
SI,197.187
$7,183,000

5955.700
$733,950

IOTAI. CAPITAL ¦ SOURCE CONTROL























$8,872,650

Page 2 of 4

remedy cost rables.xls [BM SS SC-I]

-------
TABLE L-I. COST ESTIMATE SUMMARY FOR THE SELECTED REMEDY



BASIS





MANI

IOURS

MATERIAL

LABOR

EQUIPMENT

TOTAL



QUAN-

UN

MH/

TOTAL

UNIT

TOTAL

WAGE

TOTAL

UNIT

TOTAL

DIRECT





TITY



UNIT

MH

COST

MATL

RATE

LABOR

RATE

EQUIP

COST

Monitoring

























Grautidv.'ater Monitoring

























Monitoring Well Installation. 2" PVC.

























overburden

4 clusters (clslr-1 SOB, IDOB. 1BR)

240

LF

0J0

72

6.00

1.440

550.00

.1.600

R.00

1.920

$6,960

Monitoring Well Installation. 2" PVC. bedrock
Steel Casing & Locks
Protective Bollards
MOB-DEMOB

4clusters (dslnOSOB. IDOB, I BR)
12 wells
2 per well

240
12
24
1

LF
EA
KA
LS

0.90
1.00
1.20
16.00

216
12
29
16

10.00
100.00
160.00

2.400
1.200
3.840
0

SSO.OU
550.00
550.00
550.00

I0.SO0
600
1.440
800

24.00
1.200.00

5.760

0
0

1.200

$18,960
51.800
55.280
52.000











345



8,880



I 7.240



8.880

S35.OO0

CONTRACTOR OVERHKAD & PROMT
SUBTOTAL



21,00%



















$7,350

C ONTRACTOR'S CONT1N0KNCY
SUBTOTAL (rounded)



20.00%



















542.350
SS.470

bidding/dfsigsvconstrlxtion























S31.000

SUPERVISION

























EPA/MADEP OVERSIGHT

TOTAL rAWTAI - MOSIITORIKG	

i'OlAL CAPITAL		

				

















1



$2,550
57.650
$61,200
I8.933.g501

Page 3 of 4

remedy cost tables.xls [BM_SS_SC-1]

-------
TABLE L-I. COST ESTIMATE SUMMARY FOR THE SELECTED REMEDY

Operation and Maintenance Casts for Remedy - BAM Railroad Landfill

DESCRIPTION

ANNUAL
QUAN-
TITY

UN

QUANTITY
BASIS

UNIT
COST

COST
BASIS

ANNUAL

COST
(S/YEAR)

wv j

SOURCE CONTROL

n (years) - 30

• m 3

d !'/.) 7

Horizontal Containment
Composite i Double Burner Cap
Labor

Specialist (eng., specially reps)

General Maintenance

SO
11,0

HR
AC

5 specialist-days per year (u': 10 hrs»'5010 -J0% accuracy expectation.

AC - acre	j. interest rale	R[>. round

CY - cubic yard	l.F - linear foot	SF - square fool

d ¦ discount rale	I .S. lump sum	SY ¦ square >mrd

EA-each	MH • manhours	UN - unite
HR - hour

Page 4 of 4

remedy cost tables.xls [BM_SS_SC-1 ]

-------
TABLE L-2 COST ESTIMATE SUMMARY TOR THE SELECTED REMEDY

Capital Com far Remedy - MSI Landfill



basis

QUAN-
TITY



MANI

fOURS

MATERIAL

LABOR

EQUI

PMENT

TOTAL 1



UN

MH/
UNIT

TOTAL
MH

UNIT
COST

TOTAL
MATL

WAGE
RATE

TOTAL
LABOR

UNIT
RATE

TOTAL
EQUIP

DIRECT
COST

SOURCE CONTROL

Horizontal Containment
Single Barrier Cap

























She Preparation
Erosion Control
Dust Control

Clearing & grubbing - very light effort
(mow)

Haybale/silt fence perimeter
During initial grading

2.2
2.200
2

AC
LF
MO

48.00
0.05
80.00

106
no

160

0,00
1,75
0.00

0

3,850
0

S50.00
$50.00
550.00

5.280

5,500

sumo

1.150.00
7.000.00

2.530
0

14.000

$7,810
$9,350
$22,000

Soil Suhgrade
Gas Vent Layer
Geotextilc

Granular fill < J.J inches, 12 lids likely
Sand layer - 12" thickness
Typical, 12 oz.

14,335
4,450
10,540

CY
CY

SY

0.10
0.12
0.01

1,434
534
106

12,00
8,00
1.35

172,020
35,600
14,364

$50.00
S50.00
$50.00

71.675
26.700
5,320

2.00
1.65
0.05

28.670
7.343
532

S272.365
$69,643
520.216

Low Density PE Geomcmbrane - 60 mil
Drainage Geocomposite
Cover Soil
Ibpsoit

Toe Drain stone

60 mil l.DPE
Typical

Sotl/pavel mi*. 24"
l-oam'soil mis. 6"
3*4-inch washed stone

95,760
95,760
8.875
2,220
47

SF
SF
CY
CY
CY

0.012
0.009
0.12
0.12
0,15

1,149
862
1,065
266
7

0.42
0.40
12.00
15,00
18.00

40,219
38,304
106.500
33,300
846

$50.00
550.00
150.00

$50,00
$50.00

57,456
43,092
53,250
13.320
353

0.05
0,05
1.65
1,65
2-00

4.788
4.788
14.644
3.663
94

$102,463
586.184
SI 74.394
$50,283
$1,293

Drainage Pipe, 6" PVC. perforated
Hydrosecd

6" PVC perforated pipe with Toe Drain
I.awn mix, mt clover

1.260
2.3

LF
AC

0.16
14.00

202
32

2,66
1.100

3,352
2.530

550.00
$50.00

10.0X0
1.610

330.00

0

759

S 13.432
54.899

Drainage Swales
Rip-Rap

Bottom width 4", total width ¦ 12'
l.ine drainage swale, 1" depth

1.440
640

LF
CY

0.10
0.26

144
165

0,00
16.00

0

10,240

$50,00
550.00

7.200
a.256

1.60
*.00

2.304
5.120

59,504
523.616

Crushed stone

1 .ine bottom of drainage swales. 6 inches

110

CY

• 0.15

17

15.00

1,650

550,00

825

2.00

220

$2,695

Detention Basins

l-Se 2 hasins, 75" x 75" x 4" depth

1,670

CY

0.10

167

0.00

0

150,00

8,350

1.41

2.355

510,705

Gcoiexiile
Gas Vents

Settling Monuments

Use for toe drains and swales. 12 oz-
Usc4 vents • typical vents & risers {~I8
ft)

1.840

4

2

SY
EA

i:a

0,01

30.00
4.00

IS

120
S

1.35

400.00
100,00

2.484

1,600
200

550.00

550.00
150.00

020

6.000

40(1

(1.05
100.00

92

400

0

S3.496

58.000
$600

Piezometer Installation. 1" Sch. 80 PVC
Piezometer Wellheads - C'omigated HDPK
Covers

Security Fencing. 8" Chain Link
Gates - Double Swing Door (20s)

Signage ¦- Restricted Personnel Only

4 (u140ft deep
4 piezometers

Perimeter, lop rail and bottom tension
*'ire

160
4

2,200
2
1

LF

KA

LF
EA
LS

0.J0

1.00

0.16
22,00
2,00

48
4

352
44
2

6.00

100.00

16.00
1,200
100.00

960

400

35,200
2.400
100

$50.00

550,00

S50.00
$50.00
$50.00

2.401)
200

17.600

2,200
100

K.no

3.00
370,IK!

1.280
0

6.600
740
0

S4.640

S60Q

559,400
55,340
$200

Access Roadway - grading & compaction

0 ft wide, 150 ft long

200

SY

0.05 1

10

0.00

0

$50.00

480

1.62

324

5804

Page i of 3	remedy cost tables xls [RSI_SS_SC-1 single]

-------
TABLE 1^2 COST ESTIMATE SUMMARY TOR THE SELECTED REMEDY

DESCRIPTION

BASIS

QUAN-
TITY

UN

MAN!

hours

MATERIAL

LABOR

EQUIPMENT

TOTAL

MH'

UNIT

TOTAL
MK

UNIT
COST

TOTAL
MATL

WAGE
RATE

TOTAL
LABOR

UNIT
RATE

TOTAL

EQUIP

DIRECT
COST



10 ft wide w/6" crushed stone

200

SY

0.03

6

7.70

1.540

$50.00

280

1,42

294

$2,104

CONTRACTOR OVERHEAD & PROFIT
SUBTOTAL

rONTRACTOR'S CONTINCSKNCY
SUBTOTAL (rounded)

B1DD1 NG'D F.S IGN/f ON S I R I: ( " r 1 ON
SUPERVISION
EPA/MADEP OVERSIGHT



21.00%
20.00%





7.137



507,659



J56.X47



101.529

$966,034

$202,867
$1,168,901
S233.780
$1,403,000

$249,256

TOTAL CAPITAL - SOURCE CONTROL























$1 840 317 J

Monitoring

Groundwater Monitoring
Monitoring Well Installation, 2" PVC.
overburden

Monitoring Well Installation. 2" PVC. bedrock
Mobilize.'Dernobilizc Drilling S-C
Steel Casing & Locks
Protective Bollards

2 clustersIclsir- ISOB, IDOB, ]RR)

2 clusters(cIsEr ¦ ISOB, IDOB, 1BR)

1	lime
6 wells

2	per noil

120

120
1

6
12

LF

LF
LA
EA
EA

OJO

0.90
16.00
1.00
1.20

36

IDS
16
6
14

6.00

10.00
0.00
100,00
160.00

720

1.200
0
600
1.920

$50.00

550,00
550,00
150,00
$50.00

1,800

5.400
800
300
720

R.OO

24.00
1.200.00

960

2.880
1.200
0
0

S3.480

$9,480
$2,000
$900
$2,640

CONTRACTOR OVERHEAD & PROMT
SUBTOTAL

CONTRACTOR'S CONTINC iF.NCY
il'OTOTAL (rounded)

BI DOING® ESIGN.'CONSTRl 'C HON

SUPERVISION

KPA/MAUEP OVERSIGHT

I'OIAL CAPITAL ¦ MOSilTOftlK'C	

rortrrspiro		

i

21.00%
20.00%

1





ISO



4.440

1



9.020



5.040

1

$18,500

$3.8115
$22,385
$4,477
$27,000

$1,350
$4,050
$32,400
SI.S72.7I7

Page 2 of3

remedy cost tables.xls [RS1_SS_SC-I single]

-------
TABLE l/l COST ESTIMATE SUMMARY FOR THE SELECTED REMEDY'

Oytmion and Maintenance Cons for Remedy - RSI Landfill

DESCRIPTION

ANNUAL
QUAN-
TITY

UN

QUANTITY
BASIS

UNIT
COST

COST
BASIS

ANNUAL

COST
(SA'EAR)

NPV

SOURCE CONTROL

n (years) 30
i (%) 3
d {%) 7















Single Barrier Cap
labor

.Specialist (eng., specialty reps)

General Maintenance

50

2.2

HR

AC

5 specialist-days per year 
-------
TABLE 1.-3 COST ESTIMATE SUMMARY FOB THE SELECTED REMEDY

Capital Cam far Remedy - B&M Locomotive Shop Disposal Areas

( DESCRIPTION

BASIS

QUAN-
TITY



MAN]

HOURS

MATERIAL

LABOR

EQUI

PMENT

TOTAL

VN

MIU
UNIT

TOTAL
MH

UNIT
COST

TOTAL
MATL

WAGE
RATE

TOTAL
LABOR

UNIT
RATE

TOTAL
EQUIP

DIRECT-
COST

Horizontal Containment

























Single Barrier Cap

























Site Preparation
Erosion Control
Dusi Control

Soil Subgrade/Gas Vent Layer
LDPE Geomcmbranc
Drainage Geocomposirc
Cover Soil
Fopsotl

Toe Drain stone
Mydroseed

Clearing & grubbing - very light effort
(mow)

Haybale/sili fence perimeter
During initial grading
Sand fill (12 inches)

60 mil
Typical

Soil/gravel mix. 24"

Ijsam/soil mix, 6"

3/4-inch washed stone
Lawn mix. no clover

4,7
3.000

1

9.478
204.732
204,732
18.957

4.739
47

4.7

AC

LF

MO

CY

SF

SF

CY

CY

CY

AC

48,00
0.05
80.00
0.05
0.012
0.009
o.os
0.12
0.15
14.00

226
150
80
474
2.45?
1.843
948
569
7
6b

0,00
1,75
0.00
10.00
0.42
0.40
10.00
15.00
18.00
1.100

0

5,250
0

94,783
85,987
81,893
189,567
71,088
846
5.170

$50.00
$50.00
$50.00
$50,00
530.00
$30,00
$50,00
$50,00
$50,00
$50.00

11.280
7.500
4.001)
23.696
73,704
55.27K
47.392
28.435
353
3.290

1.150,00

7.000.00
2.00
0.05
0.05
1.65
1.65
2,00
330,00

5.405
0

7.000
18.957
10.237
10.237
31.279
7.820
94
1.551

$16,685
$12,750
$11,000
$137,436
$ 169,92ft
$147,40?
$268,237
S107.342
51.293
$10,011

Drainage Swales
Rip-Rap

Bottom width 4', total width =12'
Line drainage swale, 1'depth

1,440
640

LF
CY

0,10
0.26

144
165

0.00
16,00

0

t0.240

S5Q.00
550.00

7,200
8.256

1.60
8.00

2,304
5.120

59.504
S23.6I&

Crushed stone

Line bottom of drainage swales. 6 inches

110

CY

0.15

17

15.00

1.650

$50.00

825

2.00

220

52.695

ueoteatilc

Gas Vents

Settling Monuments

I se for loe drams and swales. 12 0/.
Use 4 vems * typical venls& risers (-18
ft)

f,K40

4

2

SY

EA
EA

0.01

30.00
4.00

18

120
8

1.35

400.00
100.00

2,484

1.600
200

550,00

$50.00
$50.00

920

6.000

<100

0.05
100,00

92

400

0

53.496

58.000
$600

Piezometer Installation, 1" Sch. 80 PVC

4 {it) 40ft deep

160



0.J0

48

6,00

960











Pie/ometer Wellheads - Conugated HDPI-



SSO.OO

2.400

H.OO

1,280

54.640

Covers

Security Fencing - 8' Chain Link
Gates - Double Swing Door (20^)
Signage - Restricted Personnel Only-

4 piezometers

Perimeter, top rail and bottom tension
wire

4

3,000

2
\

KA

LF
EA
LS

1.00

0.16
22.00
2.00

4

480

44
2

100.00

16.00
1,200
! 00,00

400

48.000
2,400
100

$50,90

$50.00
$50,00
$50.00

200

24,000
2.200
100

3.00
."0.00

0

9,000
740
0

$600

$81,000
$5,340
$200

Access Roadway - grading & compaction
Access Roadway - gravel

Cttlvcri Access to 1-arge Area

0 ft wide, 150 ft long
0 ft wide w/&" crushed stone
8 foot wide cart hem culvert with dual
14 inch CMP

200
200

j j

SY
SY

-S

0,05
0.03

10

t>

0.00
7,70

0

1,540

$50.00
$50.00

4 HO
280

1.62

1.42

324
284

$804
$2,104























$10,000

Page I of 3

remedy cost tables, xls [LOC_SS_SC-I single]

-------
TABLE 1-3 COST ESTIMATE SUMMARY FOR THE SELECTED REMEDY

DESCRIPTION

-

BASIS

QUAN-
TITY

UN

MANI

lOURS

MATERIAL

LABOR 1 EQUIPMENT

TOTAL

MH/
UNIT

TOTAL
MH

UNIT
COST

TOTAL
MATL

WAGE
HATE

TOTAL
LABOR

UNIT
RATE

TOTAL
EQUIP

DIRECT-
COST

CONTRACTOR OVERHEAD & PROFIT
SUBTOTAL

CONTRACTOR'S CONTINGENCY
SUBTOTAL (rounded)
BIDDiNG/DESIGN/COKSTRUC" DON
SUPERVISION
EPA/MADEP OVBRSIG1 IT



21.00%
20.00%





7.883



604.158



308.117



112,342

11.034.687

1217,284
$1,251,971
1250.394
SI.502.000

1261.356

TOTAL CAPITAL - SOURCE CONTROL

























Groundwater Monitoring
Monitoring Weil Installation, 2" PVC.
averburden

Monitoring Well Installation. 2" PVC, bedrock
Mobilize/Demobilize Drilling SC
Steel Casing & Ijocks
Protective Bollards

3clusters(elslr ISOB. IDOB. 1 BR)

3 clusters(dstr ISOB. IDOB, IBR)

1	lime
9 wells

2	per well

ISO

1X0
1

9

m

LP

LF
EA
EA
KA

0.30

0,90
16.00
L00
1.20

54

162

16
9
22

6.00

10.00
0.00
100.00
160.00

1.080

1.800
0
900
2,180

550,00

S50.00
$50.00

tso.oo

S50.00

2.700

K.I 00
«00
450
1,080

8.0Q

24.00
1.200.00

¦

1.440

4.320
1.200
0
0

55.220

$ 14,220
$2,000
51,350
$3,960

CONTRACTOR OVERHEAD & PROFIT
SUBTOTAL

CONTRACTOR'S CONTINGENCY
SUBTOTAL (rounded)
BIDDING/DESIGN,CONSTRUCTION
[SUPERVISION
|EPArt4ADEP OVERSIGHT
| TOTAL CAPITAL - MENTORING	



21.00%
20.00V.





263



6.660



13.130



6.950

S26.750

55,61 S
532,368
56.474
$39,000

S 1.950
S5.R50

P'OTALCAMTJO:			















|



I



546,8001
52,007,567 |

Page 2 of 3

remedy cost tables.xls [LOC SS_SC-1 single]

-------
TABLE 1,-3 COST ESTIMATE SUMMARY FOR THE SELECTED REMEDY

jtggjj?" ""<* MaimleimiKe Com for Remedy - BAM Locomotive Shop Disposal Areas

DESCRIPTION

ANNUAL
QUAN-
TITY

UN

QUANTITY
BASIS

UNIT
COST

COST
BASIS

ANNUAL

COST
(SfYEAR)

NPV

SOURCE CONTROL

n (years) 30

* m s

ti {%) - 1

Horizontal Containment
Single Barrier Cap
Labor















Specialist (eng.. specialty reps)

General Maintenance

SO
4.7

HR
AC

5 specialist-days per year (£• 10 hrs/day
Size of area Co be capped

85.00
400

Putnam I.FClosure/Post
Closure Plan (Feh, 1998!

4.250
1,880

S72.000
$32,000

CONTINGENCY ,Ji00%
TQTALO&M-SOURCE CONTROL











6,130

$104,000
SI 6.000
SI20000

«(years! 5
i 3
d!%! 7

iiraundwmer Morttiormg

laboratory- Analytical Costs 13 locations
Field Sampling Costs 13 locations
Dala Validation and Reporting 13 locations

Capital Repair /Replacement

2
2
2

3%

RD
RD
RD

Semi-annual monitoring
Semi-annual monitoring
Semiannual monitoring

Percentage ofdireet capital cosi

12.100
20,5 DO
15.600

26,750

5 muiluxis'^rniipiri^s
5 methods/groupings
5 meihoifs-'groupings

24.200
41,000
31,200

803

SI04.900
5177,800
$135,300

$3,500

CONTINGENCY !500%
rOTALO&M • SOURCE CONTROL

TO TAL OPERATIONS & MAINTENANCE NET PRESENT VALUE 1
[TOTAL NET PRESENT VALUE OF REMEDY

1

1

—			

1



97,203

$422,000
$63,000
$485,000
$605,000

$2,6123H

+50 lo -30% accuracy expectation.

RD ¦ round
SF - square fool
SV - square yard
I'N ¦ tmils

Notes

( ost estimates may be refined when remedy is designed and are wilhin

" acrc	i ¦ intercsi rate

C Y ¦ cubic yard	LP - linear Iboi

d - discount rate	LS-lump sum

EA - each	yUj. manhours
HR - hour

Page 3 of 3	remedy cost tablcs.xls [LOC_SS_SC-1 single]

-------
TABLE L-4 COST ESTIMATE SUMMARY FOR THE SELECTED REMEDY

eReqtdfagArva

DESCRIPTION

BASIS





MANI

IOURS

MATERIAL

LABOR

EQUIPMENT

TOTAL

QUAN-
TITY

UN

MH/
UNIT

TOTAL
MH

UNIT

COST

TOTAL
MATL

WAGE
RATE

TOTAL
LABOR

UNIT
RATE

TOTAL
EQUIP

DIRECT-
COST

SOURCE CONTROL

Single Barrier Cap

























Demolition. Removal & Disposal
Site Preparation
Erosion Control
Dust Control

Excavation and Grading
Gravel Base Course, 2"

Includes asphalt removal of entire area
Perimeter

Assume excavate S inches and grade
entire area
Kmire area

7.0
7.0
2.100
1

4,707
1,883

AC-
AC
LF
LS

CY
CY

20000
48.00
O.OS
160,00

0,10
0,12

1.400
.136
105
160

471
226

0.00
0.00
1.75
0.00

0.00
15.00

0
0

3.675
0

0

28,241

$50.00
S50.00
S50.00
$50.00

$50,00
$50.00

70.000
16.800
5.250
8.000

23.5,U
11.296

12,000
1.150

14.000

1.41

1.65

84,000
8.050

0

M.OOO

6.637
3,106

SI 54.000
$24,850
$8,925
522.0*10

530,171
$42,644

Bituminous Concrete Intermediate Course, V

Kntire area

53.900

SY

0.018

610

3.89

131.871

$50,013

30.51(1

0.35

11,865

$174,246

Diluminous Concrete Surface Course, J"

Kntire area

33.900

SY

0.009

305

1.53

51.867

S5H.0O

15,255

0,19

6,441

$73,563

Concrete' Granite Edging. 4 1/2" x 12"
Concrete / Granite Curb, 6" * 18"
Manhole Repositioning
Caichbasin ' Drain Repositioning

Assume half of perimeter
Assume half of perimeter
Assume 2 per aeie
Assume 2 per acre

1,050
1.050
14
14

l.F
LF

EA
ISA

0.187
0.096
0..14
0.34

1%
101

5
5

5,00
1.77
0.00
0.00

5.250
1.859
0
0

S50.00
150.00
s.moo

SSO.OO

9,818
5,040
238
238

2.09

30.50
30.50

2,195
0
427
427

$17,262
$6,899
S665
5665











.1.920



222.762



195.979



137,148

S555.S89

CONTRACTOROVKRIIKAD& PROMT
SUBTOTAL



21,00%



















$116,737

CONTRACTOR'S CONTINGENCY
SUBTOTAL (founded)



20.00%



















$672,625
$134,525

BlDDINGTOiSIONTONSTRWl ION
SUPERVISION























$807,000

EPAAtADEP OVERSIGHT























5200.000

TOTAL CAPITAL • SOURCE CONTROL























SI.157.000

Page I of3

remedy cosi tablcs.xls [OLD SS SC-1]

-------
TABLE L-4 COST ESTIMATE SUMMARY FOR THE SELECTED REMEDY









MANHOURS

MATE RIAL

LABOR

EQUIPMENT

TOTAL

DESCRIPTION

BASIS

QUAN-

UN

MH/

TOTAL

UNIT

TOTAL

WAGE

TOTAL

UNIT

TOTAL

DIRECT





TITY



UNIT

MH

COST

MATL

RATE

LABOR

KATE

EQUIP

COST

Monitoring

























Groundwater Mom faring

























Monitoring Well Installation, 2" PV(",

























overburden

•J clusters (clstr ISOB. IDOB. 1BR)

240

LF

0.30

72

6.00

1,440

$50.00

3,600

8.00

1,920

S6.%0

Monitoring Well Installation. 2" PVC, bedrock

4 clusters (cIstr-lSOB. 1IXJB, IBR)

240

LP

0.90

216

10.00

2.400

$50.00

10.800

24.00

5.760

SI 8.960

Mobilize/Demobilizc Drilling S-'C

1 time

1

EA

16.00

16

0.00

0

150.00

800

1.200.00

1.200

$2,000

Steel Cosing & Locks

12 wells

12

EA

1.00

12

100.00

1.200

150.00

600



0

$1,800

Protective Bollards

2 per well

24

EA

1.20

29

160.00

3,840

$50,00

1.440



0

S5.280

SUBTOTAL DIRECT COSTS









345



8.8SO



17,240



8.880

535.000

CONTRACTOR OVERHEAD & PROMT



21.00%



















$7,350

SUBTOTAL























$42,350

CONTRAC TOR'S CONTINGENCY



20.00%



















$8,470

SUBTOTAL (rounded)























$51,000

BIDDING-DF.SIGN/CONST Rl C 1 ION

























SUPERVISION























$2,550

EPA/MADEP OVERSIGH1























$7,650

TOTAL CAPITAL - MONITORING























$61,200

fOTAL CAPITAL























S1.2IS.200

Page 2 of 3

remedy cost tables.xls [OLD_SS_SC-1 ]

-------
TABLE I,*4 COST ESTIMATE SUMMARY FOR THE SELECTED REMEDY

Operation and Maintenance Costs for Remedy - Old B&M Oil/Sludge Recycling Area

DESCRIPTION

ANNUAL
QUAN-
TITY

UN

QUANTITY
BASIS

UNIT
COST

COST
BASIS

ANNUAL

COST
(S/YEAR)

NFV

SOURCE CONTROL

Ti (years) ¦ JO
t (%! - 3
d (%) 7

Horizontal Containment
Single Barrier Cap
Labor

Specialist (eng.. specially reps)

50

HR

5 specialist-days per year 
-------
TABLE L-S COST ESTIMATE SUMMARY FOR THE SELECTED REMEDY

Capital Costs for Remedy - Contaminated Soils Area

DESCRIPTION

BASIS





HANHOIIRS

MATERIAL

LABOR

EQUIPMENT

TOTAL

QUAN-

UN

MW

TOTAL

UNIT

TOTAL

WAGE

TOTAL

UNIT

TOTAL

DIRECT





TITY



UNIT

MH

COST

MATI.

RATE

LABOR

RATE

EQUIP

COST

SOURCE CONTROL

























Horizontal Containment

























Single Barrier Cop

























Demolition. Removal & Disposal
Site Preparation

Erosion Control
Dust Control
Kjcavalion and Grading

Gravel Base Course, 2"

Includes asphalt removal for half the
urea

Assume perimeter of PRG excecdance
area plus

Only on areas not currently paved -
Assume half the area

6.7
6.7

3.000
1

2.400
903

AC
AC

LF

LS
CY

CY

200.00
48.00

0.05
160.00
0.10

0.12

1.343
322

150
160
240

108

0.00
0.00

1.75
0,00
0,00

15.00

0
0

5.250
0
0

13.542

150.00
$50.00

$50,00
$50,00
$50.00

$50.00

67.149
16.080

7.500
8,000
12,000

5,417

12.000
1.150

14.000

1.41

1.65

80.579
7,705

0

14.000
3.384

1.490

$147,727
$23,785

$12,750
S22.Q00
SI5.3S4

520.448

Bituminous Concrete Intermediate Course. 3"

Entire area

32.500

SY

0.0 IK

585

3.89

126.425

$50.00

29.250

0.35

11.375

$167,050

Bituminous Concrete Surface Course. 1"

Entire area

32.SOO

SY

0.009

29.1

1.53

49.725

$50.00

14.625

0.19

6.175

$70,525

Concrete / Granite Fdging. 4 1.-2" x 12"
Concrete .'Granite Curb. 6" x IK"
Manhole Repositioning
Catchbasin.' Drain Repositioning

Assume half of perimeter
Assume half of perimeter
Assume 2 per acre
Assume 2 per acre

1.400
1.400
14
14

LF
LF

HA
EA

0.187
0,096
0.34
0,34

262
134
5

5

5.00
1.77
0.00
0.00

7.000
2.478
0
0

$50,00
$50.00
$50.0*1

$50.00

13.090

6.720
23K
238

2.09

30.50
30,50

2.926
0
427
427

523.016
S9.I98
$665
$665

SUBTOTAL DIRECT COSTS









3.606,



204,420



I R0.306



128.487

$513,213

CONTRACTOR OVERHHAD & PROFIT
SUBTOTAL



21.00%



















$107,775

CONTRACTOR'S CONTINGENC Y
SUBTOTAL (rounded)



20.00%



















$620,988
$124,198

BIDDINGfDESICN/f'ONSTRlCriON























$745,000

SUPERVISION























$37,250
Sll 1.750

EPA/M ADEP OVERSIGHT























TOTAL CAPITAL - SOLRCL CON 1 ROl.























1894.000 1

Page 1 of 3

remedy cost lables.xls [CONT_SS_SC-1 ]

-------
TABLE L-5 COST ESTIMATE SUMMARY FOR THE SELECTED REMEDY

DESCRIPTION

BASIS





MANKOU RS

MATERIAL

LABOR

EQUIPMENT

TOTAL

QUAN-
TITY

UN

MH,'
UNIT

TOTAL
MH

UNIT
COST

TOTAL
MATL

WAGE
RATE

TOTAL
LABOR

UNIT
RATE

TOTAL
EQUIP

DIRECT
COST

Groundwater Monitoring
Monitoring Well Installation, 2" PVC.
sverbufdfin

4 clusters (cIslr -ISOB. 1DOB. 1BR)

240

LF

0.30

72

6,00

1,440

S50.00

3.600

8.00

1.920

$6,960

Monitoring Well Installation. 2" PVC, bedrock
Steel Casing & Locks
Protective Bollards
MOB-DEMOB

4 clusters [clsIr-lSQB, 1IX)B. IBR)
12 wells
2 per well

240
12

24

1

LP
EA
EA
IS

0.90
1.00
1.20
16.00

216
12
29
16

10.00
100.00
160.00
0.00

2.400
U00

3.840
0

$50.00
$50.00
$50.00
550.00

10.800
500
1.440
son

24.00
1.200.00

5.760
0
0

1.200

St 8.960
$1,800
$5,280
52,000

SUBTOTAL DIRECT COSTS









MS



S.8S0



17.240



8.880

$35,000

CONTRACTOR OVERHEAD & PROFIT
SUBTOTAL

CONTRACTOR'S CONTINGKM Y
5UBT OT A L (rounded)

BIDDING/DESiGN.CONSTRl'C HON

SUPERVISION

EPA/MADEP OVF.RSIC1 IT



21,00%
20.00%



















$7,350
$42,350
$8,410
$51.000

52,550
57.650

IU1AL. LAPil AL * MUNI 1 UKJNd























$61,200

TOTAL CAPITAL



















1

$955,200

Page 2 of 3

remedy cost tabies.xls [CONT SS SC-IJ

-------
TABLE L-5 COST ESTIMATE SUMMARY FOR THE SELECTED REMEDY

Operation and MakUemnce Casts for Remedy - Contaminated Sails Area

DESCRIPTION

ANNUAL
QUAN-
TITY

UN

QUANTITY
BASIS

UNIT

COST

COST
BASIS

ANNUAL

COST
(S/YCAR)

NPV

SOURCE CONTROL

n (years) - JO
/ ('/.) 3
d m ?

Hori zonal Containment
Single Barrier Cap
Labor

Specialist (eng., specially reps)

50

HR

5 specialist-days per year @ 10 brs'day

85.00



4.250

$72,000

General Maintenance

1,625

SY

Replace 50% of balh asphalt layers every 10 years

7.31

Price Tor both asphalt layers

11,879

$202,000

SUBTOTAL COSTS

CONTINGENCY 15.00%
TOTAL O&M - SOURCE CONTROL











16,129

S2 74,000
S 41.000
S315.000

Monitoring

n(years) 5

i CM 3

d (%) 7

UrowidnnH'r Xfotmoring

laboratory Analytical Costs 25 locations
Field Sampling Costs 25 locations
Data Validation and Reporting 25 locations

2
2
2

RD
RD
RD

Semi-annual monitoring
Semi-annual monitoring
Semi-annual monitoring

15.200
40,900
36.700

6 methmJ-i-'groupintts
6 melhiKlx-groupings
6 rn£lhod:v ^jotipirnis

70.400
*1,800
73.400

5305,300
5354.700
5318,300

Capital Repair' Replacement

3%



Percentage of direct capital cost

33,000



WO

S4.300

SUBTOTAL COSTS

CONTINGENCY 15.00%
TOTAL O&M - SOURCE CONTROL











226.590

S9SJ.000
SI 47.000
$1,130,000

TOTAL OPERATIONS & MAINTENANCE NET PRESENT VALUE













51,445.000

[TOTAL NET PRESENT VALUE OF REMEDY

Notes

Cost estimates may be refined when remedy is designed and arc within *50 to 00% accuracy expectation.

i • interest rate	RD - round

IJK - linear foot	SF - square fool

J-S-Iumpsym	SY - square yaid

MH - manhours	UN - units

AC ¦ acre
CY - cubic yaid
d * discount rate
HA - each
MR - Vioui

Page 3 of 3

remedy cost tab1cs.xls [CONT_SS_SC-l]

-------
TABLE L-6 COST ESTIMATE SUMMARY TOR THE SELECTED REMEDY

Capital Casts for Remedy - Asbestos Land/lit

BESCRIPTIOM





MANHOURS

MATERIAL

LABOR

EQUIPMENT

TOTAL

BASIS

QIIAN-

UN

MH/

TOTAL

UNIT

TOTAL

WAGE

TOTAL

UNIT

TOTAL

DIRECT

1

1 TITY



IWIT

MH

COST

MATL

RATE

LABOR

RATE

EQUIP

COST

BNSTITUTIONAI. ACTIONS

























KAccess Restrictions

























1 Deed Restrictions

























Legal Fees and Investigation

MB ) A, B&M Corp.

2

Lot

12.00

24

0.00

0

SI 50

3,600



0

13.600

Fencing tS Securtty Measures

























Security Fencing - 8' Chain Link
Gales - Double Swing Door (20')

Perimeter on figure is 3952 ft

4,000
2

LF
EA

0.16
22.00

640
44

16
1,200

64,000
2.400

550.00
$50,00

32.000
2.200

3.00
370.00

12,000
740

S108.000
$5,340

Signage-- Warning: Hazardous Waste Area



1

LS

2.00

2

100.00

100

S50.00

100



0

$200

SUBTOTAL DIRECT COSTS









710



66.SOO



37,900



12,740

$117,140

C ONTRACTOR OVERHEAD & PROFI'I
SUBTOTAL



21.00%



















S24.599

C ONTRACTORS CONTINGENCY
SUBTOTAL (rounded)



20.00%



















SI41.739
S28.J48
SI 70,000

BIDDINODESIGNCONSTRICTION























SUPERVISION























$8,500
$25,500

KPA/MADKP OVERSIGHT























rOTAl. CAPITAL - SOURCk C'ONTROI.























1204,000

Page 1 of 3

remedy cost tables.xls [ALF_SS Inst. Action]

-------
TABLE K COST ESTIMATE SUMMARY FOR THE SELECTED REMEDY

DESCRIPTION







MANHOURS

MATERIAL

LABOR

EQUIPMENT

TOTAL

BASIS

QUAN-

UN

MK/

TOTAL

UNIT

TOTAL

WAGE

TOTAL

UNIT

TOTAL

DIRECT





TITY



UNIT

MH

COST

MAT!.

RATE

LABOR

RATI

EQUIP

COST

Monitoring

























Groundwater Monitoring

























Monitoring Well Installation, 2" PVC,

























overburden

5 chLsicrs jcislr' 1 SOB. I DOB, 1BR)

100

I.F

0.30

90

6.00

1,800

$50.00

4.500

8.00

2,400

$8,700

Monitoring Well Installation. 2" PVC, bedrock
MobiIize/Demobi 1 ize drilling s^c
Steel Casing & Locks
Protective Bollards

5 clusters .500
TOO
750
1.H00

24.00
1,200.00

7,200
1,200
0
0

523.700
$2,000
$2,250
$6,600

SUBTOTAL DIRECT COSTS









427



11.100



21.350



10.800

$43,250

CONTRACTOR OVERHEAD & PROFIT
SUBTOTAL

CONTRACTORS CONTINGENCY
SUBTOTAL (rounded)
BIDDING/DESIGN/CONSTRUCTION



21.00%
20.00%



















$9,083
552,333
510.467
563,000

SUPERVISION























S3.IS0

$9,450

EPA/MADEP OVERSIGHT























JUIALC API TAL- MONITORING























$75,600

I'OTAL CAPITAL























$279,500

Operation and Maintenance Costs for Remedy • Asbestos Landfill

DESCRIPTION

ANNI'AL

QUAN-
TITY

UN

QUANTITY

BASIS

UNIT
COST

COSI
BASIS

ANNUAL

COST
(S/YEAR)

NPV

INSTITUTIONAL ACTIONS

n(years) 30
< (%) 3

d {%» 7

Access Restrictions

Deed Restrictions (no O&M costs)

Fencing & Security Measures
Capital Repair i Replacement

1%



Percentage ol"direct capital cosl

113.540



1.135

$19,000

Page 2 of 3	remedy cost tables.xls [ALF_SS_lnst. Action]

-------
TABLE L-6 COST ESTIMATE SUMMARY FOR THE SELECTED REMEDY

DESCRIPTION

ANNUAL
QUAN-
TITY

UN

QUANTITY
BASIS

UNIT
COST

COST
BASIS

ANNUAL

COST
(S/YIAR)

NPV

Horizontal Containment

Existing Cap

Labor

Specialist (eng.. specially reps)

General Maintenance

SO
12.0

HR
AC

5 spccialisl-days per year @ 10 hrs/day
Size of capped area

K5.00
400

Putnam I.K Closure/Post
Closure Plan tFeb. 1998)

4.250
4.800

$72,000
S82.000

SUBTOTAL COSTS

CONTINGENCY 15.00%
TOTAL O&M - SOURCE CONTROL











10.185

SI 73.000
$26,000
SI99.000

Monilorim:

n(years) - 5
< (%1 3
d (%) 7

Groundwater Monitoring

Laboratory Analytical Costs 16 locations
field Sampling Costs 16 locations
Data Valkldliun and Reporting 16 locations

1

2
2

Rli
RD
R!>

Semi-annual monitoring
Semi-annual monitoring
Semi-annual monitoring

26.100
25.100
31.300

6 methods-groupings
6 methiKis/grnupings
6 methods-groupings

52,200
50,200
62,600

5226.400
1217.700
$271,500

Capital Repair i Replacement

3%



Percentage or direct capital cost

4J.2S0



1,298

55,600

SUBTOTAL COSTS

CONTINGENCY 15.00%
TOTAL O&M - SOURCE CONTROL











166.298

$721,000
$108,000
$829,000

TOTAL OPERATIONS & MAINTENANCE NET PRESENT VALUE













S 1.028,000

fl O I AL NET PRESENT VALUE OF REMEDY

Notes

Cost estimates may be refined! >*hen remedy is designed and are within -50 to -30% accuracy expectation.

i - interest rale	RD - round

1 ,F- linear foot	SK • square foal

IS - lump sum	SY - square yard

MH • manhcurs	UN • units

AC - acre
C'Y * cubic yard
d - discount rate
EA - each
HR ¦ hour

Page 3 of 3

remedy cost tables.xls [ALF SS Irsi. Action]

-------
TABLE 1.-7 COST ESTIMATE SUMMARY FOR THE SELECTED REMEDY

Capital Casts for Remedy - Asbestos Lagooni

1 DESCRIPTION







MANHOIIRS

MATERIAL

LABOR

EQU1 PMENT

TOTAL

BASIS

QUAN-

UN

MHZ

TOTAL

UNIT

TOTAL

wage

TOTAL

UNIT

TOTAL

DIRECT





TITY



UNIT

MH

COST

MATL

RATE

LABOR

RATE

EQUIP

COST

SOURCE CONTROL

























Horizontal Containment

























Singh Barrier Cap

























Site Preparation

Clearing and grubbing - very light effort

2 8

AC

48,00

132

0.00

0

S50.00

6.600

1.150.00

3.163

59,763

Erosion Control

Haybalc/sill fence perimeter

2.025

LF

0,05

101

1.75

3,544

$50.00

5.063



0

58,606

Dust Conlrol

During initial grading - maybe level C

1

l.S

160,00

160

0.00

0

S5Q.00

S.000

14.000

14.000

522,000

Excavation and Grading

Grade be mis for sloping ¦ maybe level ('

2,700

CY

0,10

270

0.00

0

S50.W)

13,500

1.41

3.807

SI 7.307



Granular fill <1.5 inches, 5 lifts likely























Soil Subgrade

Tor slope

21,385

CY

0.10

2.139

12.00

256.620

SS0.00

106,925

2.00

42,770

$406.315

Gcotexlile

Typical, 12az.

I3..1.U

SY

0.01

133

1.35

18.000

S50.00

6.667

0.05

567

525.333

l.ow Density PE Geomembrane - 60 mil

60 rail I.UPI;

120,000

SF

0.012

1.440

0.42

50,400

S50.00

72,000

(1,05

6,000

5128.400

Drainage Geocomposite

Typical

120,000

SF

0.009

I.0S0

0.40

48,000

550,00

54.000

0.05

6.000

5108,000

Cover Soil

Soil/gravel mix, 24"

II,ISO

CY

0,12

1,338

12.00

133,800

550,00

66.900

1.65

18.398

5219,098

Topsoil

1 cam/soil mi*. 6"

2,800

CY

D.12

336

15.00

42,000

550,00

16.800

1.65

4,620

563.420

Toe Drain stone

J.'4-inch washed stone

52

CY

0.15

8

18.00

936

550.00

390

2.00

104

$1,430

Drainage Pip;, 6" PVC, perforated

6" PVC perforated pipe with Toe Drain

1.400

IF

0.1 A

224

2,66

3,724

550,00

11.200



0

514.924

GeotesUile

I se tor loe drains and swales, 12 vs.

1.920

SY

0,01

n

1,35

2.592

$50.00

¦>60

0.05

96

53.648

Hydtoseed

1-awn mix, no clover

2.0

AC

14.00

41

1,100

3,190

$50.00

2.030

330.00

957

56,177

Drainage Swales

Riprap swales. 12" wide, 1" thick riprap

1,400

LF

0.10

140

0,00

0

S50.0O

7.000

1.60

2.240

59.240

Rip-Rap

For drainage swales

625

CY

(1.26

163

16,00

10,000

550.00

K. 125

ft.QO

5,000

523,125

Crashed stone

6" layer. -1' width along swales

105

CY

0.15

16

15,00

1,575

550.00

78B

2.00

210

52.573

Detention Basins

l.'se 2 basins. 75' x 75' x 4' depth

1,670

CY

0.10

167

0.00

0

550.00

8,350

1.41

2.355

$10,705

Piezometer Installation. 1" Sch. 80 PVC

4 
-------
TABLE L-7 COST ESTIMATE SUMMARY FOR THE SELECTED REMEDY

DESCRIPTION







MAN HOURS

MATERIAL

LABOR

EQUIPMENT

TOTAL

BASIS

QUAN-
TITY

UN

MH/

UNIT

TOTAL
MH

UNIT

COST

TOTAL
MATL

WAGE
RATE

TOTAL
LABOR

UNrr

RATE

TOTAL
EQUIP

DIRECT
COST

SUBTOTAL DIRECT COSTS









8,292



607.041



414.597



117,805

5I.IJ9.443

CONTRACTOR OVERHEAD & PROFIT
SUBTOTAL

CONTRACTOR'S CONTINGENCY
SUBTOTAL (rounded)

BIDDING'DES ION/CONSTRUCTION

SUPERVISION

EPA/MADEP OVERSIGHT



21,00%
20.00%



















$239,281
Sl.378.726
$275,745
SI.654.000

5279.933
$211.767

TOTAL CAPITAL - SOURCE CONTROL























S2.145.700

Monitoring

Groundwater Monitoring
Monitoring Well Insrallalion, 2" PVC'.
overburden

4 clusters (clslr ISOB. 1DOB. 1BR)

240

I>

0.30

72

6.00

1.440

$50.00

1.60(1

8.00

1.920

$6,960

Moniloring Well Installation, 2" PVC. bedrock
Mobilize/Demobilise Drilling S/C
Sleet Casing & Locks
Protective Bollards

4clusters (dsir-lSOB. IIIOB. IBR)

1	lime
12 wells

2	per well

240
1

12
24

l.K
EA
EA
EA

0,90
16.00
1.00
1.20

216
16
12
29

10.00
0.00
100.00
160.00

2.400
0

1.200
3.840

$50.00
150.00
S50.00
$50.00

10,800
80(1

600
1.-140

24.00
1.200.00

5.760
1.200
0
0

SIS,960
$2,000
SI,800

$5,280

SUBTOTAL DIRECT COSTS









345



B.8S0



17.240



8.880

$35,000

CONTRACTOR OVERHEAR & PROMT
SUBTOTAL

CONTRACTOR'S CONTINGENCY
5UBT OT A1. (rountled)
BIDDINGI)!-SIGN/CONSTRUCTION
SUPERVISION
KPAMADEP OVERSIGHT



21.00%
20.00%



















57,350
$42,350
SK.470
551.000

S2.J50
$7,650

IUIAH APIIAL-MUNIIOKING









I











$61,200

IOIAL CAPITAL





1 1 1



1

1

$2,206,900

Page 2 of 3

remedy cos! tables.xls [ALG SS_SC-I single]

-------
TABLE L-7 COST ESTIMATE SUMMARY FOR THE SELECTED REMEDY

Operation and Maintenance Costs for Remedy - Asbestas Lagoons

DESCRIPTION

ANNUAL
QUAN-
TITY

UN

QUANTITY
BASIS

UNIT
COST

COST
BASIS

ANNUAL

COST
(S/YEAR)

NPV

SOURCE CONTROL

n (years) 30

i m * s

d (%) 7

Horizontal C ~n'^imncnt
Single Barrier Cop
Labor

Specialist (eng.. specially reps)

Cienerat Maintenance

50
2.8

HR

AC

5 special ist-days per year @ 10 Ins/day
Size of area to be capped

85-00
400

Putnam I.I Closure Post

Closure Plan f F eb 1998)

4.250
1,100

$72,000
$19,000

SUBTOTAL COSTS

CONTINGENCY 15,00%
TOTAL O&M - SOURCE CONTROL











5.350

$91,000

$14,000
$105,000

Monitoring

n{years) 5
i {%) J
d (%! 7

Groundwater Monitoring

laboratory Analytical Costs 13 locations
Field Sampling Costs 13 locations
Data Validation and Reporting 1} localions

2
2
2

RD
RD
RD

Semi-annual manitoriny
Semi-annual monitoring
Semi-annual monitoring

18.100
21.000
18.700

6 methods/grouping
6 methods-groupings
ft melhods-'groupintts

36.200
42.000
37.400

$157,000
5182.100
SI 62.200

Capital Repair 1 Replacement

3%



Percentage of direct capita) cost

35.000



1.050

S4.600

SUBTOTAL COSTS

CONTINGENCY 15.00%
TOTAL O&M - SOURCE CONTROL











116.650

5506.000
576.000
5582.000

TOTAL OPERATIONS & MAINTENANCE NET PRESENT VALUE













$687,000

[TOTAL net present value op remedy

Notes

Cost estimates may be refined when remedy is designed and arc within < 50 lo -30% accuracy expectation.

AC ¦ acre
CY - cubic yard
d • discount rate
EA ¦ each
HR - hour

i • interest rale
I.F - linear foot
J.S - lump sum
MM • manhours

RD - round
SF ¦ square foot
SY - square yard
l.'N' - uniis

52.893.9WH

Page 3 or3

remedy cost tab1es.xls [ALG_SS_SC-I single]

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TABLE L-8. ARARS, CRITERIA, ADVISORIES, AND GUIDANCE FOR THE B&M RAILROAD LANDFILL

Alternative

Media and Authority

Requirements

Status

Triggering Action & Requirement
Synopsis

Action to be taken to attain ARAR

No Action













Chemical Specific

YES









Federal Regulatory
Requirements

Cancer Slope Factors (CSF).

To Be Considered

Guidance used to compute the individual
incremental cancer risk resulting from
exposure to carcinogenic contaminants in
site media.

This alternative will not meet this standard
since potential carcinogenic hazards caused
by exposure to contaminants not addressed.



Federal Regulatory
Requirements

Reference Dose (RtD)

To Be Considered

Guidance used to characterize human health
risks due to non-carcinogens in site media.

This alternative will not meet this standard
since potential non-carcinogenic hazards
caused by exposure to contaminants not
addressed.



Location Specific

NO









Action Specific

NO







Iron Horse Park 3rd OU-FS

Page

1

of 83

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TABLE L-8. ARARS, CRITERIA, ADVISORIES, AND GUIDANCE FOR THE B&M RAILROAD LANDFILL

Alternative

Media and Authority

Requirements

Status

Triggering Action & Requirement
Synopsis

Action to be taken to attain ARAR

Limited Action:

Institutional

Controls













Chemical Specific

YES









Federal Regulatory
Requirements

Cancer Slope Factors (CSF).

To Be Considered

Guidance used to compute the individual
incremental cancer risk resulting from
exposure to carcinogenic contaminants in
site media.

This alternative will not meet this standard
since potential carcinogenic hazards caused
by migration of contaminants into
groundwater will not be addressed through
institutional controls.



Federal Regulatory
Requirements

Reference Dose (RfD)

To Be Considered

Guidance used to characterize human health
risks due to non-carcinogens in site media.

This alternative will not meet this standard
since potential carcinogenic hazards caused
by migration of contaminants into
groundwater will not be addressed through
institutional controls.



Location Specific

YES









Federal Regulatory
Requirements

Clean Water Act (33 U.S.C. §
125 i el seq.); Section
404(b)(1) Guidelines for
Specification of Disposal Sites
for Dredged or Fill Material (40
CFR Part 230,231 and 33 CFR
Parts 320-323)

Applicable

This alternative includes work to be
performed in or near a wetland. Under this
requirement, no activity that adversely
affects a wetland shall be permitted if a
practicable alternative with lesser effects is
available. If activity takes place, impacts
must be minimized to the maximum extent.
Controls discharges of dredged or fill
material to protect aquatic ecosystems.

If new monitoring wells are needed, and no
practical alternative to locating in wetlands,
then measures will be taken to minimize
impacts.



Federal Regulatory
Requirements

Executive Order 11990;
"Protection of Wetlands" (40
CFR Part 6, Appendix A)

Applicable

This alternative includes work to be
performed in or near a wetland. Under this
requirement, no activity that adversely
affects a wetland shall be permitted if a
practicable alternative with lesser effects is
available. If activity lakes place, impacts
must be minimized to the maximum extent.

If new monitoring wells are needed, and no
practical alternative to locating in wetlands,
then measures will be taken to minimize
impacts.

Iron Horse Park 3rd OU-FS

Page 2 of 83

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TABLE L-8. ARARS, CRITERIA, ADVISORIES, AND GUIDANCE FOR T

Alternative

Media and Authority

Requirements

Status

Triggcriiij

Action & Requirement
Synopsis

Action to be taken to attain ARAR



Federal Regulatory
Requirements

Fish and Wildlife Coordination
Act(16U,S.C. |661 etseq.);
Fish and wildlife protection (40
CFR §6.302(g))

Applicable

This alternativt
performed in oi
areas, Any mo
requires consul
Wildlife Servic
wildlife agency
prevent, miliga
fish and wildlif

includes work to be
near wetland and floodplain
lification of a body of water
ation with the U.S. Fish and
: and the appropriate state
to develop measures to
e or compensate for losses of

EPA will consult with U.S. Fish and
Wildlife Service should Remedial Activities
involve the modification of a body of water.



Federal Regulatory
Requirements

Executive Order 11988;
"Floodplain Management" (40
CFR Part 6, Appendix A)

Applicable

This alternative
performed in oi
Action to avoic
and short-term
occupancy and
development, v
alternative. Pre
restoration of f
natural and ben

includes work to be
near a 100-year floodplain.
whenever possible, the long

mpaets associated with the
modifications of floodplains
hcrevcr there is a practical
motes the preservation and
wdplains so that their
ificial value can be realized.

If new monitoring wells are needed, and no
practical alternative to locating them in
floodplain, then measures will be taken to
minimize impacts.



Federal Regulatory
Requirements

National Historic Preservation
Act of 1966 (16 U.S.C. §470 et_
scq."i: Protection of Historic
Properties (36 CFR part 800)

Applicable

This altemalivj
historic Middle
the N11PA reqi
into account ih<
on historic proj
Advisory Coun
reasonable opp

includes work near the
>ex Canal. Section 106 of
ires federal agencies to take
effects of their undertakings
erties and afford the
;il on Historic Preservation a
irtunity to comment,

Should this alternative impact historical
properties (such as the Middlesex Canal),
activities will be coordinated with the
Advisory Council on Historic Preservation.



Federal Regulatory
Requirements

Historic Sites Act of 1935 (16
U.S.C. §469 slseq. ); National
historic landmarks (36 CFR
Part 65)

Applicable

This alternative
historic Middle
the National Hi
to identify and
Landmarks, am
preservation of
properties that
the history and
States.

includes work near the
;ex Canal. The purpose of
stone Landmarks program is
lesignate National Historic
encourage the long range
nationally significant
llustrate or commemorate
jrehistoiy of the United

Should this alternative impact historical
properties (such as the Middlesex Canal),
activities will be coordinated with ibe
Department of the Interior,

EIE B&M RAILROAD LANDFILL

Iron Horse Park 3rd OU-FS

Page 3 of 83

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TABLE L-8. ARARS, CRITERIA, ADVISORIES, AND GUIDANCE FOR THE B&M RAILROAD LANDFILL

Alternative

Media and Authority

Requirements

Status

Triggering Action & Requirement
Synopsis

Action to be taken to attain ARAR



Massachusetts

Regulatory

Requirements

Wetlands Protection Act {Mass,
Gen. Laws ch. 131, §40);
Wetlands Protection
Regulations (310 CM R § 10.00)

Applicable

This alternative includes work to be
performed within 100 feet of a wetland,
Sets performance standards for dredging,
filling, altering of inland wetlands and
within 100 feet of a wetland. The
requirement also defines wetlands based on
vegetation type and requires that effects on
wetlands be mitigated. Resource areas at
the site covered by the regulations include
banks, bordering vegetated wetlands, land
under bodies of water, land subject to
flooding, riverfront, and estimated habitats
of rare wildlife.

If new monitoring wells are needed, and no
practical alternative to locating in wetlands,
then measures will be taken to minimize
impacts.



Massachusetts

Regulatory

Requirements

Antiquities Act and Regulations
(Mass. Gen. Laws. ch. 9, §§26-
27; Massachusetts Historical
Commission (Mass. Regs. Code
tit, 950, §70.00); Antiquities
Act and Regulations
(Mass.Gen.Laws. ch. 9, §§26-
27; Protection of Properties
Included in the State Register of
Historic Places (950 CMR
§71.00)

Relevant and Appropriate

This alternative includes work near the
historic Middlesex Canal, Projects which
are state-funded or state-licensed or which
are on state property must eliminate,
minimize, or mitigate adverse effects to
properties listed in the register of historic
places. Establishes requirements for review
of impacts for state-funded or state-licensed
projects and projects on state-owned
property. Establishes state register of
historic places. Establishes coordination
with the National Historic Preservation Act,

Should this alternative impact (he historical,
architectural, archaeological, or cultural
qualities of a property, whether listed or not,
activities will be coordinated with the
Massachusetts Historical Commission.



Action Specific

YES







Iron Horse Park 3rd OU-FS

Page 4 of 83

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TABLE L-8. ARARS, CRITERIA, ADVISORIES, AND GUIDANCE FOR THE B&M RAILROAD LANDFILL

Alternative

Media and Authority

Requirements

Status

Triggering Action & Requirement
Synopsis

Action to be taken to attain ARAR



Federal Regulatory
Requirements

RCRA Subtitle C- Hazardous
Waste Identification and Listing
Regulations; Generator and
Handler Requirements, Closure
and Post-Closure (40 CFR Parts
260-262 and 264}

Applicable for disposal standards; Relevant
and Appropriate for Closure/Post Closure
Standards

These rules are used to identify, manage,
and dispose of hazardous waste.

Any media generated as part of monitoring
activities will be tested for hazardous waste
characteristics. If determined to be
hazardous waste, then they will be stored,
transported, and disposed off site in
accordance with these standards, However
this Alternative will not be meet the
closure/post closure standards because
institutional controls alone will not address
requirements to prevent ecological risks nor
prevent migration of contaminants to
surface and groundwater,



Federal Regulatory
Requirements

EPA Alternative Cap Guidance

To be Considered

Provides standards for alternative cap design
to address risks from wastes left in place
from human exposure, ecological risk, and
migration to surface and groundwater.

These standards will not be met because
institutional controls alone will not address
requirements to prevent ecological risks nor
prevent migration of contaminants to
surface and groundwater.



Massachusetts

Regulatory

Requirements

Hazardous Waste Management
Regulations (310 CMR
30.500); - Waste Analysis (310
CMR 30.513),Closure (310
CMR 30.580), Post-Closure
(310 CMR 30.590), Landfill
Closure (310 CMR 30.633)

Applicable for disposal standards; Relevant
and Appropriate for Closure/Post Closure
Standards

Because of the past disposal of wastes at
AOC #] that would be considered hazardous
wastes by today's standards, all remedial
actions must be in conformance with these
rules. Waste analysis, closure and post-
closure performance standards arc spelled
out. A final cover will be designed and
constructed to provide long-term
minimization of migration of liquids. After
final closure, maintenance and monitoring
will be conducted throughout the post-
closure care period.

Any media generated as part of monitoring
activities will be tested for hazardous waste
characteristics. If determined to be
hazardous waste, then Ihey will be stored,
transported, and disposed off site in
accordance with these standards. However
this Alternative will not be meet the
closure/post closure standards because
institutional controls alone will not address
requirements to prevent ecological risks nor
prevent migration of contaminants to
surface and groundwater.

Iron Horse Park 3rd OU-FS

Page 5 of 83

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TABLE L-8. ARARS, CRITERIA, ADVISORIES, AND GUIDANCE FOR THE B&M RAILROAD LANDFILL

Alternative

Media and Authority

Requirements

Status

Triggering Action & Requirement
Synopsis

Action to be taken to attain ARAR



Massachusetts

Regulatory

Requirements

Massachusetts Clean Waters
Act (Mass. Gun. Laws ch. 21,
§§26-53); Water Quality
Certification for Discharge of
Dredged or Fill Material,
Dredging, and Dredged
Materials in Waters of the
United States within the
Commonwealth (314 CMR
§9.00)

Applicable

This alternative includes remediation
activities in wetlands and buffer zones,
Establishes criteria and standards for
dredging, handling and disposal of fill
material and dredged material,

Any discharges from well installation or
monitoring will be managed in compliance
with these standards.

Iron Horse Park 3rd QU-FS

Page 6 of83

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TABLE L-8. ARARS, CRITERIA, ADVISORIES, AND GUIDANCE FOR THE B&M RAILROAD LANDFILL

Alternative

Media and Authority

Requirements

Status

Triggering Action & Requirement
Synopsis

Action to be taken to attain ARAR

Monitored
Natural

Attenuation (in-
situ)













Chemical Specific

YES









Federal Regulatory
Requirements

Cancer Slope Factors (CSF).

To Be Considered

Guidance used to compute the individual
incremental cancer risk resulting from
exposure to carcinogenic contaminants in
site media.

This alternative might meet this standard if
potential carcinogenic hazards caused by
migration of contaminants into groundwater
are naturally attenuated over lime.



Federal Regulatory
Requirements

Reference Dose (RfD)

To Be Considered

Guidance used to characterize human health
risks due to noil-carcinogens in site media.

This alternative might meet this standard if
potential carcinogenic hazards caused by
migration of contaminants into groundwater
are naturally attenuated over time.



Location Specific

YES









Federal Regulatory
Requirements

Clean Water Act (33 U.S.C.
§1251 etssq.); Section
404(b)(1) Guidelines for
Specification of Disposal Sites
for Dredged or Fill Material (40
CFR Part 230, 231 and 33 CFR
Parts 320-323)

Applicable

This alternative includes work so be
performed in or near a wetland. Under this
requirement, no activity that adversely
affects a wetland shall be permitted if a
practicable alternative with lesser effects is
available. If activity takes place, impacts
must be minimized to the maximum extent,
Controls discharges of dredged or fill
material to protect aquatic ecosystems.

If new monitoring wells are needed, and no
practical alternative to locating in wetlands,
then measures will be taken to minimize
impacts.



Federal Regulatory
Requirements

Executive Order 11990;
"Protection of Wetlands" (40
CFR Pari 6, Appendix A)

Applicable

This alternative includes work to be
completed in a wetland. Under this
requirement, no activity that adversely
affects a wetland shall be permitted if a
practicable alternative with lesser effects is
available. If activity takes place, impacts
must be minimized to the maximum extent,

If new monitoring wells are needed, and no
practical alternative to locating in wetlands,
then measures will be taken to minimize
impacts.

Iron Horse Park 3rd OU-FS

Page 7 of 83

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TABLE L-8. ARARS, CRITERIA, ADVISORIES, AND GUIDANCE FOR THE B&M RAILROAD LANDFILL

Alternative

Media and Authority

Requirements

Status

Triggering Action & Requirement
Synopsis

Action to be taken to attain ARAR



Federal Regulatory
Requirements

Fish and Wildlife Coordination
Act (16 U.S.C. §661 et seq.);
Fish and wildlife protection (40
CFR 86.302(g))

Applicable

This alternative includes work to be
performed in or near wetland and floodplain
areas, 'Any modification of a body of water
requires consultation with the U.S. Fish and
Wildlife Service and the appropriate state
wildlife agency to develop measures to
prevent, mitigate or compensate for losses of
fish and wildlife,

EPA will consult with U.S. Fish and
Wildlife Service should Remedial Activities
involve the modi cation of a body of water.



Federal Regulatory
Requirements

Executive Order 1198S;
"Floodplain Management" (40
CFR Part 6, Appendix A)

Applicable

This alternative includes work to be
performed in or near a 100-year floodplain.
Action to avoid, whenever possible, the long
and short-term impacts associated with the
occupancy and modifications of floodplains
development, wherever there is a practical
alternative. Promotes the preservation and
restoration of floodplains so that their
natural and beneficial value can be realized,

A determination has been made that there is
no practical alternative to these construction
activities in the floodplain. Remedial actions
that involve construction in the floodplain
will include all practicable means to
minimize harm to and preserve beneficial
values of floodplains,



Federal Regulatory
Requirements

National Historic Preservation
Act of 1966 (16 U.S.C. §470 et_
sea,): Protection of Historic
Properties (36 CFR part 800)

Applicable

This alternative includes work near the
historic Middlesex Canal, Section 106 of
the NHPA requires federal agencies to take
into account the effects of their undertakings
on historic properties and afford the
Advisory Council on Historic Preservation a
reasonable opportunity to comment.

Should this alternative impact historical
properties (such as the Middlesex Canal),
activities will be coordinated with the
Advisory Council on Historic Preservation.



Federal Regulatory
Requirements

Historic Sites Act of 1935 (16
U.S.C. §469 et seq,); National
historic landmarks (36 CFR
Part 65)

Applicable

This alternative includes work near the
historic Middlesex Canal, The purpose of
the National Historic Landmarks program is
to identity and designate National Historic
Landmarks, and encourage the long range
preservation of nationally significant
properties that illustrate or commemorate
the history and prehistory of the United
States.

Should this alternative impact historical
properties (such as the Middlesex Canal),
activities will be coordinated with the
Department of the Interior.

Iron Horse Parte 3rd OU-FS

Page 8 of 83

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TABLE L-8. ARARS, CRITERIA, ADVISORIES, AND GUIDANCE FOR THE B&M RAILROAD LANDFILL

Alternative

Media and Authority

Requirements

Status

Triggering Action & Requirement
Synopsis

Action to be taken to attain ARAR



Massachusetts

Regulatory

Requirements

Wetlands Protection Act (Mass.
Gen. Laws ch. 131, §40);
Wetlands Protection
Regulations (310 CMR §10.00}

Applicable

This alternative includes work to be
performed within 100 feet of a wetland.
Sets performance standards for dredging,
filling, altering of inland wetlands and
within 100 feet of a wetland. The
requirement also defines wetlands based on
vegetation type and requires that effects on
wetlands be mitigated. Resource areas at
the site covered by the regulations include
banks, bordering vegetated wetlands, land
under bodies of water, land subject to
flooding, riverfront, and estimated habitats
of rare wildlife.

If new monitoring wells are needed, and no
practical alternative to locating in wetlands
or regulated buffer zones, then measures will
be taken to minimize impacts.



Massachusetts

Regulator)'

Requirements

Antiquities Act and Regulations
(Mass, Gen. Laws. ch. 9, §§26-
27; Massachusetts Historical
Commission (Mass. Regs, Code
tit. 950, §70,00); Antiquities
Act and Regulations
(Mass.Gen.Laws. ch. 9, §§26-
27; Protection of Properties
Included in the State Register of
Historic Places (950 CMR
§71.00)

Relevant and Appropriate

This alternative includes work near the
historic Middlesex Canal. Projects which
are state-funded or state-licensed or which
are on state property must eliminate,
minimize, or mitigate adverse effects to
properties listed in the register of historic
places. Establishes requirements for review
of impacts for slate-funded or state-licensed
projects and projects on state-owned
property. Establishes state register of
historic places. Establishes coordination
with the national Historic Preservation Act.

Should this alternative impact the historical,
architectural, archaeological, or cultural
qualities of a property, whether listed or not,
activities will be coordinated with the
Massachusetts Historical Commission.



Action Specific

YES









Federal Regulatory
Requirements

RCRA Subtitle C- Hazardous
Waste Identification and Listing
Regulations; Generator and
Handler Requirements, Closure
and Post-Closure (40 CFR Parts
260-262 and 264)

Applicable for disposal standards; Relevant
and Appropriate for Closure/Post Closure
Standards

These rules arc used to identify, manage,
and dispose of hazardous waste.

Any media generated as part of monitoring
activities will be tested for hazardous waste
characteristics. If determined to be
hazardous waste, then they will be stored,
transported, and disposed off site in
accordance with these standards. However
this Alternative will not be meet the
standards for landfill closure.

Iron Horse Park 3rd OU-FS

Page 9 of83

-------
TABLE L-8. ARARS, CRITERIA, ADVISORIES, AND GUIDANCE FOR THE B&M RAILROAD LANDFILL

Alternative

Media and Authority

Requirements

Status

Triggering Action & Requirement
Synopsis

Action to be taken to attain ARAR



Federal Regulatory
Requirements

EPA Alternative Cap Guidance

To be Considered

Provides standards for alternative cap design
to address risks from wastes left in place
from human exposure, ecological risk, and
migration to surface and groundwater.

This Alternative will not be meet the
standards for landfill closure,



Massachusetts

Regulatory

Requirements

Hazardous Waste Management
Regulations (310 CMR
30,500); - Waste Analysis (310
CMR 30.513), Closure (310
CMR 30.580), Post-Closure
(310 CMR 30.590), Landfill
Closure (310 CMR 30,633)

Applicable for disposal standards; Relevant
and Appropriate for Closure/Post Closure
Standards

Because of the past disposal of wastes at
AOC #1 that would be considered hazardous
wastes by today's standards, all remedial
actions must be in conformance with these
rules. Waste analysis, closure and post-
closure performance standards are spelled
out, A final cover will be designed and
constructed to provide long-term
minimization of migration of liquids, After
final closure, maintenance and monitoring
will be conducted throughout the post-
closure care period.

Any media generated as part of monitoring
activities will be tested for hazardous waste
characteristics. If determined to be
hazardous waste, then they will be stored,
transported, and disposed off site in
accordance with these standards. However
this Alternative will not be meet the
standards because natural attenuation alone
will not meet the standards for landfill
closure.



Massachusetts

Regulatory

Requirements

Massachusetts Clean Waters
Act (Mass, Gen. Laws eh, 21,
§§26-53); Water Quality
Certification for Discharge of
Dredged or Fill Material,
Dredging, and Dredged
Materials in Waters of the
United States within the
Commonwealth (314 CMR
§9.00)

Applicable

This alternative includes work to be
performed in or near a wetland. Establishes
criteria and standards for dredging, handling
and disposal of fill material and dredged
material.

If new monitoring wells are needed, and no
practical alternative to locating in wetlands
or buffer zones, then measure will be taken
to minimize impacts.

Cap Waste

Chemical Specific

YES









Federal Regulatory
Requirements

Cancer Slope Factors (CSF),

To Be Considered

Guidance used to compute the individual
incremental cancer risk resulting from
exposure to carcinogenic contaminants in
site media.

This alternative will meet this standard by
capping potential carcinogenic hazards and
maintaining and monitoring the cap.

Iron Horse Park 3rd OU-FS

Page 10 of 83

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TABLE L-8. ARARS, CRITERIA, ADVISORIES, AND GUIDANCE FOR THE B&M RAILROAD LANDFILL

Alternative

Media and Authority

Requirements

Status

Triggering Action & Requirement
Synopsis

Action to be taken to attain ARAR



Federal Regulatory
Requirements

Reference Dose (RfD)

To Be Considered

Guidance used to characterize human health
risks due to non-carcinogens in site media.

This alternative will meet this standard by
capping potential non-carcinogenic hazards
and maintaining and monitoring the cap,



Location Specific

YES









Federal Regulatory
Requirements

Clean Water Act (33 U.S.C. §
1251 et seq.); Section
404(b)(1) Guidelines for
Specification of Disposal Sites
for Dredged or Fill Material (40
CFR Fart 230, 231 and 33 CFR
Parts 320-323)

Applicable

This alternative includes work to be
performed in or near a wetland. Under this
requirement, no activity that adversely
affects a wetland shall be permitted if a
practicable alternative with lesser effects is
available. If activity takes place, impacts
must be minimized to the maximum extent.
Controls discharges of dredged or fill
material to protect aquatic ecosystems.

Given the location of contamination in
wetlands, this Alternative has been
determined to be the best practical
alternative. Adverse impacts to wetland
resources will be minimized to the
maximum extent practical and mitigation
conducted if required.



Federal Regulatory
Requirements

Executive Order 11990;
"Protection of Wetlands" (40
CFR Part 6, Appendix A)

Applicable

This alternative includes work to be
performed in or near a wetland. This
alternative includes work to be completed in
a defined wetland. Under this requirement,
no activity that adversely affects a wetland
shall be permitted if a practicable alternative
with lesser effects is available, If activity
lakes place, impacts must be minimized to
the maximum extent.

Given the location of contamination in
wetlands, this Alternative has been
determined to be the best practical
alternative, Adverse impacts to wetland
resources will be minimized to the
maximum extent practical and mitigation
conducted if required.



Federal Regulatory
Requirements

Resource Conservation and
Recovery Act (42 U.S.C. §6901
el seq. J; Location Standards
(40 CFR §264,18)

Relevant and Appropriate

This altenative includes work to be
performed in or near a 100-year floodplain,
This regulation places limitations on where
RCRA TSDFs may be located. It also
outlines the criteria for constructing a
RCRA facility on a 100-year floodplain.

A determination has been made that there is
no practical alternative to these construction
activities in the flood plain, Remedial
actions that involve construction in the
floodplain areas will include all practicable
means to minimize harm to and preserve
beneficial values of floodplains,

Iron Horse Park 3rd OU-FS

Page II of S3

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TABLE L-S. ARARS, CRITERIA, ADVISORIES, AND GUIDANCE FOR THE B&M RAILROAD LANDFILL

Alternative

Media and Authority

Requirements

Status

Triggering Action & Requirement
Synopsis

Action to be taken to attain ARAR



Federal Regulatoiy
Requirements

Fish and Wildlife Coordination
Act (16 U.S.C. §661 etseq.);
Fish end wildlife protection (40
CFR §6.302(g))

Applicable

This alternative includes work to be
performed in or near defined wetland and
floodplain areas. Any modification of a
body of water requires consultation with the
U.S. Fish and "Wildlife Services and the
appropriate state wildlife agency to develop
measures to prevent, mitigate or compensate
for losses of fish and wildlife.

EPA will consult with U.S. Fish and
Wildlife Services should Remedial
Activities involve the modification of a body
of water.



Federal Regulatory
Requirements

Executive Order 11988;
"Floodplain Management" (40
CFR Part 6, Appendix A)

Applicable

This alternative includes work to be
performed in or near a 100-year floodplain.
Action to avoid, whenever possible, the long
and short-term impacts associated with the
occupancy and modifications of floodplains
development, wherever there is a practical
alternative. Promotes the preservation and
restoration of floodplains so that their
natural and beneficial value can be realized,

A determination has been made that there is
no practical alternative to these construction
activities in the floodplain. Remedial actions
that involve construction in the floodplain
areas will include all practicable means to
minimize harm to and preserve beneficial
values of floodplains.



Federal Regulatory
Requirements

National Historic Preservation
Act of 1966 (16 U.S.C, §470 eL
seo.l: Protection of Historic
Properties (36 CFR part 800)

Applicable

This alternative includes work near the
historic Middlesex Canal. Section 106 of
the NHPA requires federal agencies to take
into account the effects of their undertakings
on historic properties and afford the
Advisory Council on Historic Preservation a
reasonable opportunity to comment.

Should this alternative impact historical
properties (such as the Middlesex Canal),
activities will be coordinated with the
Advisory Council on Historic Preservation.



Federal Regulatoiy
Requirements

Historic Sites Act of 1935 (16
U.S.C. §469 etseq. ); National
historic landmarks (36 CFR
Part 65)

Applicable

This alternative includes work near the
historic Middlesex Canal. The purpose of
the National Historic Landmarks program is
lo identify and designate National Historic
Landmarks, and encourage the long range
preservation of nationally significant
properties that illustrate or commemorate
the history and prehistory of the United
States,

Should this alternative impact historical
properties (such as the Middlesex Canal),
activities will be coordinated with the
Department of the Interior.

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TABLE L-8. ARARS, CRITERIA, ADVISORIES, AND GUIDANCE FOR THE B&M RAILROAD LANDFILL

Alternative

Media and Authority

Requirements

Status

Triggering Action & Requirement
Synopsis

Action to be taken to attain ARAR



Massachusetts

Regulatory

Requirements

Wetlands Protection Act (Mass.
Gen. Laws ch. 131, §40);
Wetlands Protection
Regulations (310 CMR §10.00)

Applicable

This alternative includes work to be
performed within 100 feet of a wetland,
Seta performance standards for dredging,
filling, altering of inland wetlands and
within 100 feet of a wetland. The
requirement also defines wetlands based on
vegetation type and requires that effects on
wetlands be mitigated. Resource areas at
the site covered by the regulations include
banks, bordering vegetated wetlands, land
under bodies of water, land subject to
flooding, riverfront, and estimated habitats
of rare wildlife.

Substantive standards for protecting Slate
wetland resources will be complied with.
Mitigation of impacts on wetlands and
regulated buffer zones will be addressed.



Massachusetts

Regulatory

Requirements

Antiquities Act and Regulations
(Mass. Gen, Laws, ch, 9, §§26-
27; Massachusetts Historical
Commission (Mass. Regs. Code
tit. 950, §70.00); Antiquities
Act and Regulations
(Mass.Gen.Laws. ch. 9, §§26-
27; Protection of Properties
Included in the State Register of
Historic Places (950 CMR
§71.00)

Relevant and Appropriate

This alternative includes work near the
historic Middlesex Canal. Projects which
are state-funded or slate-licensed or which
are on stale property must eliminate,
minimize, or mitigate adverse effects to
properties listed in the register of historic
places. Establishes requirements for review
of impacts for slate-funded or state-licensed
projects and projects on state-owned
property. Establishes state register of
historic places. Establishes coordination
with the national Historic Preservation Act.

Should this alternative impact the historical,
architectural, archaeological, or cultural
qualities of a properly, whether listed or not,
activities will be coordinated with the
Massachusetts Historical Commission.



Action Specific

YES









Federal Regulatory
Requirements

RCRA Subtitle C- Hazardous
Waste Identification and Listing
Regulations; Generator and
Handler Requirements, Closure
and Post-Closure (40 CFR Parts
260-262 and 264)

Applicable for disposal standards; Relevant
and Appropriate for Closure/Post Closure
Standards

These rules are used to identify, manage,
and dispose of hazardous waste.

Any media generated as part of monitoring
activities will be tested for hazardous waste
characteristics. If determined to be
hazardous waste, then they will be stored,
transported, and disposed off site in
accordance with these standards, This
Alternative will meet the closure/post
closure standards Ihrough capping,
monitoring and institutional controls.

Iron Horse Park 3rd OU-FS

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TABLE L-8. ARARS, CRITERIA, ADVISORIES, AND GUIDANCE FOR THE B&M RAILROAD LANDFILL

Alternative

Media and Authority

Requirements

Status

Triggering Action & Requirement
Synopsis

Action to be taken to attain ARAR



Federal Regulatory
Requirements

EPA Alternative Cap Guidance

To be Considered

Provides standards for alternative cap design
to address risks from wastes left in place
from human exposure, ecological risk, and
migration to surface and poundwater.

These standards will be met because because
the alternative cap design will prevent risks
to human health and the environment and
prevent migration of contaminants to
surface and groundwater.



Federal Regulatory
Requirements

CWA Ambient Water Quality
Criteria (AWQC) (40 CFR 120)

Relevant and Appropriate

This provision sels standards for protecting
surface water quality.

Activities will be conducted to ensure that
the impact of site-related contaminants to
surface water will be minimzed.



Massachusetts

Regulatory

Requirements

Hazardous Waste Management
Regulations (310 CMR
30.500); - Waste Analysis (310
CMR 30.513), Closure (310
CMR 30.580), Post-Closure
(310 CMR 30.590), Landfill
Closure (310 CMR 30,633)

Applicable for disposal standards; Relevant
and Appropriate for Closure/Post Closure
Standards

Because of the past disposal of wastes at
AOC #1 that would be considered hazardous
wastes by today's standards, all remedial
actions must be in conformance with these
rules. Waste analysis, closure and post-
closure performance standards are spelled
out. A final cover will be designed and
constructed to provide long-term
minimization of migration of liquids. A Iter
final closure, maintenance and monitoring
will be conducted throughout the post-
closure care period.

Any media generated as part of monitoring
activities will be tested for hazardous waste
characteristics. If determined to be
hazardous waste, then they will be stored,
transported, and disposed off site in
accordance with these standards. This
Alternative will meet all closure/past closure
standards.



Massachusetts

Regulatory

Requirements

Management Slandards for all
Hazardous Waste Facilities
(310 CMR 30.500),
Contingency Plan, Emergency
Procedures, Preparedness, and
Prevention (310 CMR 30.520)

Relevant and Appropriate

This area is being closed in accordance with
hazardous waste requirements. Includes
requriemcnLs for contingency plan,
emergency procedures, preaparedness and
prevention.

This requirement will be met for this
alternative

Iron Horse Park 3rd OU-FS

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TABLE L-8. ARARS, CRITERIA, ADVISORIES, AND GUIDANCE FOR THE B&M RAILROAD LANDFILL

Alternative

Media and Authority

Requirements

Status

Triggering Action & Requirement
Synopsis

Action to be taken to attain ARAR



Massachusetts

Regulatory
Requirements

Massachusetts Clean Waters
Act (Mass. Gen. Laws ch. 21,
§§26-53); Water Quality
Certification for Discharge of
Dredged or Fill Material,
Dredging, and Dredged
Materials in Waters of the
United States within the
Commonwealth (314 CMR
§9.00)

Applicable

This alternative includes remediation
activities in wetlands and buffer zones.
Establishes criteria and standards for
dredging, handling and disposal of fill
material and dredged material.

Activities will be conducted in accordance
with these requirements to protect State
wetland resources.



Massachusetts

Regulatory

Requirements

Massachusetts Air Pollution
Control Regulations (310 CMR
7.09)

Applicable

This alternative includes excavation and/or
earthwork. Prohibits burning or emissions
of dust which causes or contributes to a
condition of air pollution. Standards for dust
are contained in 310 CMR 7.09.

These standards will be complied with
during any excavation of materials at the
Site.

Iron Horse Park 3rd OU-FS

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TABLE L-9. ARARS, CRITERIA, ADVISORIES, AND GUIDANCE FOR THE RSI LANDFILL

Alternative

ARAR. Media and
Authority

Requirements

Status

Triggering Action & Requirement
Synopsis

Action to be taken to attain AKAR

No Action













Chemical Specific

YES









Federal Regulatory
Requirements

Cancer Slope Factors (CSF).

To Be Considered

Guidance used to compute the individual
incremental cancer risk resulting from
exposure to carcinogenic contaminants in
site media.

This alternative will not meet this standard
since potential carcinogenic hazards caused
by exposure to contaminants not addressed.



Federal Regulatory
Requirements

Reference Dose (RfD)

To Be Considered

Guidance used to characterize human health
risks due to non-carcinogens in site media.

This alternative will not meet this standard
since potential non-carcinogenic hazards
caused by exposure to contaminants not
addressed.



Location Specific

NO









Action Specific

NO







Iron Horse Park 3rd OU-FS

Page 16 of83

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TABLE L-9. ARARS, CRITERIA, ADVISORIES, AND GUIDANCE FOR THE RSI LANDFILL

Alternative

ARAR, Media and
Authority

Requirements

Status

Triggering Action & Requirement
Synopsis

Action to be taken to attain ARAR

Cap Waste













Chemical Specific

YES









Federal Regulatory
Requirements

Cancer Slope Factors (CSF).

To Be Considered

Guidance used to compute the individual
incremental cancer risk resulting from
exposure to carcinogenic contaminants in
site media.

This alternative will meet this standard by
capping potential carcinogenic hazards and
maintaining and monitoring the cap.



Federal Regulatory
Requirements

Reference Dose (RfD)

To Be Considered

Guidance used to characterize human health
risks due to non-carcinogens in site media.

This alternative will meet this standard by
capping potential non-carcinogenic hazards
and maintaining and monitoring the cap.



Location Specific

YES









Federal Regulatory
Requirements

Clean Water Act £33 U.S.C.
§ 1251 et seq.); Section
404(b)(1) Guidelines for
Specification of Disposal Sites
for Dredged or Fill Material (40
CFR Part 230,231 and 33 CFR
Parts 320-323)

Applicable

This alternative includes work to be
performed in or near a wetland. Under this
requirement, no activity that adversely
affects a wetland shall be permitted if a
practicable alternative with lesser effects is
available. If activity takes place, impacts
must be minimized to the maximum extent.
Controls discharges of dredged or fill
material to protect aquatic ecosystems.

Given the location of contamination in
wetlands, this Alternative has been
determined to be the best practical
alternative. Adverse impacts to wetland
resources will be minimized to the
maximum extent practical and mitigation
conducted if required.



Federal Regulatory
Requirements

Executive Order 11990;
"Protection of Wetlands" (40
CFR Part 6, Appendix A)

Applicable

This alternative includes work to be
performed in or near a wetland. Under this
requirement, no activity that adversely
affects a wetland shall be permitted if a
practicable alternative with lesser effects is
available, If activity takes place, impacts
must be minimized to the maximum extent.

Given the location of contamination in
wetlands, this Alternative has been
determined to be the best practical
alternative. Adverse impacts to wetland
resources will be minimized to the
maximum extent practical and mitigation
conducted if required.



Federal Regulatory
Requirements

Fish and Wildlife Coordination
Act (16 U.S.C, §661 etseq.);
Fish and wildlife protection (40
CFR §6 302(g))

Applicable

Any modification of a body of water
requires consultation with the U.S. Fish and
Wildlife Service and the appropriate state
wildlife agency to develop measures to
prevent, mitigate or compensate for losses of
fish and wildlife.

EPA will consult with U.S. Fish and
Wildlife Service should Remedial Activities
involve the modification of a body of water.

Iron Horse Park 3rd OU-FS

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TABLE L-9. ARARS, CRITERIA, ADVISORIES, AND GUIDANCE FOR THE RSI LANDFILL

Alternative

ARAR, Media and
Authority

Requirements

Status

Triggering Action & Requirement
Synopsis

Action to be taken to attain ARAR



Massachusetts

Regulatory

Requirements

Wetlands Protection Act (Mass,
Gen, Laws ch. 131, §40);
Wetlands Protection
Regulations (310 CMR § 10,00)

Applicable

This alternative includes work to be
performed within 100 feet of a wetland,
Sets performance standards for dredging,
filling, altering of inland wetlands and
within 100 feet of a wetland, The
requirement also defines wetlands based on
vegetation type and requires that effects on
wetlands be mitigated. Resource areas at
the site covered by the regulations include
batiks, bordering vegetated wetlands, land
under bodies of water, land subject to
flooding, riverfront, and estimated habitats
of rare wildlife.

Substantive standards for protecting State
wetland resources will be complied with,
Mitigation of impacts on wetlands and
regulated buffer zones will be addressed.



Federal Regulatory
Requirements

National Historic Preservation
Act of 1966 (16 U.S.C. §470 et_
¦sea,): Protection of Historic
Properties (36 CFR part 800)

Applicable

This work includes work to be performed
near the historic Middlesex Canal. Section
106 of the NHPA requires federal agencies
to take into account the effects of their
undertakings on historic properties and
afford the Advisory Council on Historic
Preservation a reasonable opportunity to
comment.

Should this alternative impact historical
properties (such as the Middlesex Canal),
activities will be coordinated with the
Advisory Council on Historic Preservation.



Federal Regulatory
Requirements

Historic Sites Act of 1935 (16

U.S.C. §469 elseq.); National
historic landmarks (36 CFR
Part 65)

Applicable

This alternative includes work to bo
performed near the historic Middlesex
Canal. The purpose of the National Historic
Landmarks program is to identify and
designate National Historic Landmarks, and
encourage the long range preservation of
nationally significant properties that
illustrate or commemorate the history and
prehistory of the United States.

Should this alternative impact historical
properties (such as the Middlesex Canal),
activities will be coordinated with the
Department of the Interior.

Iron Horse Park 3rd OU-FS

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TABLE L-9. ARARS, CRITERIA, ADVISORIES, AND GUIDANCE FOR THE RSI LANDFILL

Alternative

ARAR, Media and
Authority

Requirements

Status

Triggering Action & Requirement
Synopsis

Action to be taken to attain ARAR



Massachusetts

Regulatory

Requirements

Antiquities Act and Regulations
(Mass. Gen. Laws. eh. 9, §§26-
27; Massachusetts Historical
Commission (Mass. Regs. Code
lit. 950, §70.00); Antiquities
Act and Regulations
(Mass.Gen.Laws. ch. 9, §§26-
27; Protection of Properties
Included in the State Register of
Historic Places (950 CMR
§71.00)

Relevant and Appropriate

This alternative includes work to be
performed near the historic Middlesex
Canal. Projects which are state-fiinded or
state-licensed or which are on state property
must eliminate, minimize, or mitigate
adverse effects to properties listed in the
register of historic places. Establishes
requirements for review of impacts for state-
fiinded or staic-licenscd projects and
projects on state-owned property.

Establishes state register of historic places.
Establishes coordination with the national
Historic Preservation Act.

Should this alternative impact the historical,
architectural, archaeological, or cultural
qualities of a property, whether listed or not,
activities will be coordinated with the
Massachusetts Historical Commission.



Action Specific

YES





















Federal Regulatory
Requirements

CWA Ambient Water Quality
Criteria (AWQQ (40 CFR 120)

Relevant and Appropriate

This provision sets standards for protecting
surface water quality.

Activities will be conducted to ensure that
the impact of site-related contaminants to
surface water will be minimzed.



Massachusetts

Regulatory

Requirements

Mass Solid Waste Management
Regulations (310 CMR 19.00)

Applicable for disposal standards; Relevant
and Appropriate for Closure/Post Closure
Standards

These regulations address disposal of non-
hazardous waste and closure, post-closure,
and maintenance of solid waste landfills.

Any media generated as part of monitoring
activities that is determined to be non-
hazardous would be managed and disposed
of in accordance with these standards. This
Alternative will be meet the closure/post
closure standards to prevent human contact
and migration of contaminants to surface
and groundwater.



Massachusetts

Regulatory

Requirements

Management Standards for all
Hazardous Waste Facilities
(310 CMR 30.500), Waste
Analysis (310 CMR 30.513);
Management Standards (310
CMR 510)

Applicable

These rules are used to identity, manage,
and dispose of hazardous waste.

Any media generated as part of monitoring
activities will be tested for hazardous waste
characteristics. If determined to be
hazardous waste, then they will be stored,
transported, and disposed off site in
accordance with these standards.



Massachusetts

Regulatory

Requirements

Massachusetts DEP Landfill
Technical Guidance Manual

To be Considered

Provides a standard reference for and
guidance on landfill design, construction

and QA/QC procedures in accordance with
310 CMR 19,00

This Alternative will be meet the landfill
design standards to prevent human contact
and migration of contaminants to surface
and groundwater,

Iron Horse Park 3rd OU-FS

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TABLE L-9. ARARS, CRITERIA, ADVISORIES, AND GUIDANCE FOR THE RSI LANDFILL

Alternative

ARAR, Media and
Authority

Requirements

Status

Triggering Action & Requirement
Synopsis

Action to be taken to attain ARAR



Massachusetts

Regulatory

Requirements

Massachusetts Clean Waters
Act (Mass. Gen. Laws eh. 21,
§§26-53); Water Quality
Certification for Discharge of
Dredged or Fill Material,
Dredging, and Dredged
Materials in Waters of the
United States within the
Commonwealth (314 CMR
§9.00)

Applicable

This alternative includes work to be
performed in or near a wetland. Establishes
criteria and standards for dredging, handling
and disposal of fill material and dredged
material.

Activities will be conducted in accordance
with these requriements to protect State
wetland resources.



Massachusetts

Regulatory

Requirements

Massachusetts Air Pollution
Control Regulations (310 CMR
7.09)

Applicable

This alternative includes excavation and/or
earthwork. Prohibits burning or emissions
of dust which causes or contributes to a
condition of air pollution. Standards for dust
are contained in 310 CMR 7.09.

These standards will be complied with
during any excavation of materials at the
Site.

Iron Horse Park 3rd OU-FS

Page 20 of 83

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TABLE L-10. ARARS, CRITERIA, ADVISORIES, AND GUIDANCE FOR THE B&M LOCOMOTIVE SHOP DISPOSAL AREAS

Alternative

ARAR, Media and
Authority

Requirements

Status

Triggering Action & Requirement
Synopsis

Action to be taken to attain ARAR

No Action













Chemical Specific

YES









Federal Regulatory
Requirements

Recommendations of the
Technical Review Workgroup
for Lead for an Approach to
Assessing Risks Associated
with Adult Exposured to Lead
in Soil

To be Considered

EPA guidance for evaluating the risks posed
by lead in soil.

Standard noi met since alternative does not
address lead soil risks.



Federal Regulatory
Requirements

Cancer Slope Factors (CSF),

To Be Considered

Guidance used to compute the individual
incremental cancer risk resulting from
exposure to carcinogenic contaminants in
site media,

This alternative will not meet this standard
since potential carcinogenic hazards caused
by exposure to contaminants not addressed.



Federal Regulatory
Requirements

Reference Dose (RfD)

To Be Considered

Guidance used to characterize human health
risks due to non-carcinogens in site media.

This alternative will not meet this standard
since potential non-carcinogenic hazards
caused by exposure to contaminants not
addressed.



Location Specific

No









Action Specific

No







Iron Horse Park 3rd OU-FS

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TABLE L-10. ARARS, CRITERIA, ADVISORIES, AND GUIDANCE FOR THE B&M LOCOMOTIVE SHOP DISPOSAL AREAS

Alternative

AltAR, Media and
Authority

Requirements

Status

Triggering Action & Requirement
Synopsis

Action to be taken to attain ARAR

Limited Action:

Institutional

Controls













Chemical Specific

YES









Federal Regulatory
Requirements

Recommendations of the
Technical Review Workgroup
for Lead for an Approach to
Assessing Risks Associated
with Adult Exposured to Lead
in Soil

To be Considered

EPA guidance for evaluating the risks posed
by lead in soil,

Standard will be met by preventing human
access to lead contaminated soil.



Federal Regulatory
Requirements

Cancer Slope Factors (CSF).

To Be Considered

Guidance used to compute the individual
incremental cancer risk resulting from
exposure to carcinogenic contaminants in
site media.

This alternative will not meet this standard
since potential carcinogenic hazards caused
by migration of contaminants into
groundwater will not be addressed through
institutional controls.



Federal Regulatory
Requirements

Reference Dose (RfD)

To Be Considered

Guidance used to characterize human health
risks due to non-carcinogens in site media,

This alternative will not meet this standard
since potential carcinogenic hazards caused
by migration of contaminants into
groundwater will not be addressed through
institutional controls,



Location Specific

YES









Federal Regulatory
Requirements

Clean Water Act (33 U.S.C.
§ 1251 el seq,); Section
404(b)(1) Guidelines for
Specification of Disposal Sites
for Dredged or Fill Material (40
CFR Part 230,231 and 33 CFR
Parts 320-323)

Applicable

This alternative includes work to be
performed in or near a wetland. Under (his
requirement, no activity that adversely
affects a wetland shall be permitted if a
practicable alternative with lesser effects is
available, If activity takes place, impacts
must be minimized to the maximum extent.
Controls discharges of dredged or fill
material to protect aquatic ecosystems.

If new monitoring wells are needed, and no
practical alternative to locating in wetlands,
then measures will be taken to minimize
impacts.

Iron Horse Park 3rd OU-FS

Page 22 of 83

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TABLE L-10. ARARS, CRITERIA, ADVISORIES, AND GUIDANCE FOR THE B&M LOCOMOTIVE SHOP DISPOSAL AREAS

Alternative

ARAR, Media and
Authority

| Requirements

Status

Triggering Action & Requirement
Synopsis

Action to be taken to attain ARAR



Federal Regulatory
Requirements

Executive Order 11990;
"Protection of Wetlands" (40
CFR Part 6, Appendix A)

Applicable

This alternative includes work to be
performed in or near a wetland. Under this
requirement, no activity that adversely
affects a wetland shall be permitted if a
practicable alternative with lesser effects is
available. If activity takes place, impacts
must be minimized to the maximum extent,

If new monitoring wells are needed,and no
practical alternative to locating in wetlands,
then measures will be taken to minimize
impacts.



Federal Regulatory
Requirements

Fish and Wildlife Coordination
Act (I6U.S.C. §661 et seq.);
Fish and wildlife protection (40
CFR §6.302{g))

Applicable

Any modification of a body of water
requires consultation with the U.S. Fish and
Wildlife Service and the appropriate state
wildlife agency to develop measures to
prevent, mitigate or compensate for losses of
fish and wildlife,

EPA will consult with U.S. Fish and
Wildlife Service should Remedial Activities
involve the modification of a body of water,



Massachusetts

Regulatory

Requirements

Wetlands Protection Act (Mass,
Gen, Laws ch, 131, §40);
Wetlands Protection
Regulations (310 CM R §10,00)

Applicable

This alternative includes work to be
performed within 100 feet of a wetland.
Sets performance standards for dredging,
filling, altering of inland wetlands and
within 100 feet of a wetland, The
requirement also defines wetlands based on
vegetation type and requires that effects on
wetlands be mitigated. Resource areas at
the site covered by the regulations include
banks, bordering vegetated wetlands, land
under bodies of water, land subject to
flooding, riverfront, and estimated habitats
of rare wildlife.

If new monitoring wells are needed, and no
practical alternative to locating in wetlands
or regulated buffer zone, then measures will
be taken to minimize impacts.



Action Specific

YES









Federal Regulatory
Requirements

RCRA Subtitle C- Hazardous
Waste Identification and Listing
Regulations; Generator and
Handler Requirements (40 CFR
Ports 260-262 and 264)

Applicable

These rales are used to identify, manage,
and dispose of hazardous waste.

Any media generated as part of monitoring
activities will be tested for hazardous waste
characteristics. If determined to be
hazardous waste, then they will be stored,
transported, and disposed off site in
accordance with these standards.



Federal Regulatory
Requirements

CWA Ambient Water Quality
Criteria (AWQC) (40 CFR 120)

Relevant and Appropriate

This provision sets standards for protecting
surface water quality.

Activities will be conducted to ensure that
the impact of site-related contaminants to
surface water will be minimzed.

Iron Horse Park 3rd OU-FS

Page 23 of 83

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TABLE L-10. ARARS, CMTERIA, ADVISORIES, AND GUIDANCE FOR THE B&M LOCOMOTIVE SHOP DISPOSAL AREAS

Alternative

ARAR, Media and
Authority

Requirements

Status

Triggering Action & Requirement
Synopsis

Action to be taken to attain ARAR



Massachusetts

Regulatory

Requirements

Mass Solid Waste Management
Regulations (310 CMR 19.00)

Applicable for disposal standards; Relevant
and Appropriate for Closure/Post Closure
Standards

These regulations address management and
disposal of non-hazardous waste, closure,
post-closure, and maintenance of solid waste
landfills.

Any media generated as part of mon itoring
activities that is determined to be non-
hazardous would be managed and disposed
of in accordance with these standards.
However this Alternative will not be meet
the closure/post closure standards because
institutional controls alone will not address
requirements to protect ecological receptors
and prevent migration of contaminants to
surface and groundwater,



Massachusetts

Regulatory
Requirements

Hazardous Waste Management
Regulations (310 CMR
30,500); Waste Analysis (310
CMR 30.513); Management
Standards (310 CMR 510)

Applicable

Waste analysis performance standards are
spelled out.

Any media generated as part of monitoring
activities will be tested for hazardous waste
characteristics, If determined to be
hazardous waste, then they will be stored,
transported, and disposed off site in
accordance with these standards.



Massachusetts

Regulatory

Requirements

Massachusetts DEP Landfill
Technical Guidance Manual

To be Considered

Provides a standard reference for and
guidance on landfill design, construction
and QA/QC procedures in accordance with
310 CMR 19.00

These standards will not be met because
institutional controls alone will not address
landfill design standards.



Massachusetts

Regulatory

Requirements

Massachusetts Clean Waters
Act (Mass. Gen. Laws ch. 21,
§§26-53); Water Quality
Certification for Discharge of
Dredged or Fill Material,
Dredging, and Dredged
Materials in Waters of the
United States within the
Commonwealth (314 CMR
§9.00)

Applicable

Establishes criteria and standards for
discharging into wetlands and surface waters

If new monitoring welis are needed, any
discharges from well installation or
maintenance will meet these standards

Iron Horse Park 3rd OU-FS

Page 24 of 83

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TABLE L-10. ARARS, CRITERIA, ADVISORIES, AND GUIDANCE FOR THE B&M LOCOMOTIVE SHOP DISPOSAL AREAS

Alternative

ARAR, Media and
Authority

Requirements

Status

Triggering Action & Requirement
Synopsis

Action lo be taken to attain ARAR

Monitored
Natural

Attenuation {in-
situ)













Chemical Specific

YES









Federal Regulatory
Requirements

Recommendations of the
Technical Review Workgroup
for Lead for an Approach to
Assessing Risks Associated
with Adult Exposurcd to Lead
in Soil

To be Considered

EPA guidance for evaluating the risks posed
by lead in soil.

Standard will be met by preventing human
access to lead contaminated soil through
institutional controls as part of the remedy.



Federal Regulatory
Requirements

Cancer Slope Factors (CSF),

To Be Considered

Guidance used to compute the individual
incremental cancer risk resulting from
exposure to carcinogenic contaminants in
site media.

This alternative might meet this standard if
potential carcinogenic hazards caused by
migration of contaminants into groundwater
are naturally attenuated over time. Potential
carcinogenic hazards caused by exposure lo
contaminants would be addressed through
institutional controls.



Federal Regulatory
Requirements

Reference Dose (RfD)

To Be Considered

Guidance used to characterize human health
risks due to non-carcinogens in site media.

This alternative might meet this standard if
potential carcinogenic hazards caused by
migration of contaminants into groundwater
are naturally attenuated over time. Potential
carcinogenic hazards caused by exposure to
contaminants would be addressed through
institutional controls.



Location Specific

YES









Federal Regulatory
Requirements

Clean Water Act (33 U.S.C.
§ 1251 el sec/.); Section
404(b)(1) Guidelines for
Specification of Disposal Sites
for Dredged or Fill Material (40
CFR Part 230, 231 and 33 CFR
Parts 320-323)

Applicable

This alternative includes work to be
performed in or near a wetland. Under this
requirement, no activity that adversely
affects a wetland shall be permitted if a
practicable alternative with lesser effects is
available. If activity takes place, impacts
must be minimized to the maximum extent.
Controls discharges of dredged or fill
material to protect aquatic ecosystems.

If new monitoring wells are needed, and no
practical alternative to locating in wetlands,
then measures will be taken to minimize
impacts.

Iron Horse Park 3rd OU-FS

Page 25 of 83

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TABLE L-10. ARARS, CRITERIA, ADVISORIES, AND GUIDANCE FOR THE B&M LOCOMOTIVE SHOP DISPOSAL AREAS

Alternative

ARAR, Media and
Authority

Requirements

Status

Triggering Action & Requirement
Synopsis

Action to be taken to attain ARAR



Federal Regulatory
Requirements

Executive Order 11990;
"Protection of Wetlands" (40
CFR Part 6, Appendix A)

Applicable

This alternative includes work to be
performed in or near a wetland. Under this
requirement, no activity that adversely
affects a wetland shall be permitted if a
practicable alternative with lesser effects is
available, If activity takes place, impacts
must be minimized to the maximum extent.

If new monitoring wells are needed, and no
practical alternative to locating in wetlands,
then measures will be taken to minimize
impacts.



Massachusetts

Regulatory

Requirements

Wetlands Protection Act (Mass.
Gen, Laws ch. 131, §40);
Wetlands Protection
Regulations (310 CMR § 10,00}

Applicable

This alternative includes work to be
performed in or near a wetland. Sets
performance standards for dredging, filling,
altering of inland wetlands and within 100
feet of a wetland, The requirement also
defines wetlands based on vegetation type
and requires that effects on wetlands be
mitigated. Resource areas at the site
coveted by the regulations include banks,
bordering vegetated wetlands, land under
bodies of water, land subject to flooding,
riverfront, and estimated habitats of rare
wildlife.

If new monitoring wells are needed, and no
practical alternative to locating in wetlands
or regulated buffer zones, then measures will
be taken to minimize impacts.



Action Specific

YES









Federal Regulatory
Requirements

RCRA Subtitle C- Hazardous
Waste Identification and Listing
Regulations; Generator and
Handler Requirements (40
CFR Parts 260-262 and 264)

Applicable

These rules are used to identify, manage,
and dispose of hazardous waste.

Any media generated as part of monitoring
activities will be tested for hazardous waste
characteristics. If determined to be
hazardous waste, then they will be stored,
transported, and disposed off site in
accordance with these standards.



Federal Regulatory
Requirements

CWA Ambient Water Quality
Criteria (AWQC) (40 CFR 120)

Relevant and Appropriate

This provision sets standards for protecting
surface water quality.

Activities will be conducted to ensure that
the impact of site-related contaminants to
surface water will be minimzed.

Iron Horse Park 3rd OU-FS

Page 26 of 83

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TABLE L-10. ARARS, CRITERIA, ADVISORIES, AND GUIDANCE FOR THE B&M LOCOMOTIVE SHOP DISPOSAL AREAS

Alternative

ARAR, Media and
Authority

Requirements

Status

Triggering Action & Requirement
Synopsis

Action to be taken to attain ARAR



Massachusetts

Regulatory
Requirements

Mass Solid Waste Management
Regulations (310 CMR 19.00)

Applicable for disposal standards; Relevant
and Appropriate for Closure/Post Closure
Standards

These regulations address management and
disposal of non-hazardous waste, closure,
post-closure, and maintenance of solid waste
landfills.

Any media generated as part of monitoring
activities that is determined to be non-
hazardous would be managed and disposed
of in accordance with these standards.
However this Alternative will not be meet
the closure/post closure standards because it
will not address requirements to protect
ecological receptors and prevent migration
of contaminants to surface and groundwater.



Massachusetts

Regulatory

Requirements

Hazardous Waste Management
Regulations (310 CMR
30.500); Waste Analysis (310
CMR 30,513); Management
Standards(310CMR 510)

Applicable

Waste analysis performance standards are
spelled out.

Any media generated as part of monitoring
activities will be tested for hazardous waste
characteristics. If determined to "be
hazardous waste, then they will be stored,
transported, and disposed off site in
accordance with these standards.



Massachusetts

Regulatory

Requirements

Massachusetts DEP Landfill
Technical Guidance Manual

To be Considered

Provides a standard reference for and
guidance on landfill design, construction
and QA/QC procedures in accordance with
310 CMR 19.00

These standards will not be met because
institutional controls alone will not address
standards for landfill design.



Massachusetts

Regulatory

Requirements

Massachusetts Clean Waters
Act (Mass. Gen, Laws ch. 21,
§§26-53); Water Quality
Certification for Discharge of
Dredged or Fill Material,
Dredging, and Dredged
Materials in Waters of the
United States within the
Commonwealth (314 CMR
§9.00)

Applicable

Establishes criteria and standards for
discharging into wetlands and surface waters

If new monitoring wells are needed, any
discharges from well installation or
maintenance will meet these standards

Iron Horse Park 3rd OU-FS

Page 27 of 83

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TABLE L-10. ARARS, CRITEMA, ADVISORIES, AND GUIDANCE FOR THE B&M LOCOMOTIVE SHOP DISPOSAL AREAS

Alternative

ARAR, Media and
Authority

Requirements

Status

Triggering Action & Requirement
Synopsis

Action to be taken to attain ARAR

Excavate and
Place Under
Another On-Site
AOC Cap













Chemical Specific

YES









Federal Regulatory
Requirements

Recommendations of the
Technical Review Workgroup
for Lead for an Approach to
Assessing Risks Associated
with Adult Exposured to Lead
in Soil

To be Considered

EPA guidance for evaluating the risks posed
by lead in soil.

Standard will be met by removing lead
contaminated soil and placing it under a
cap.



Federal Regulatory
Requirements

Cancer Slope Factors (CSF).

To Be Considered

Guidance used to compute the individual
incremental cancer risk resulting from
exposure to carcinogenic contaminants in
site media.

This alternative will meet this standard by
removing potential carcinogenic hazards and
putting it under a cap at another AOC where
it will be properly managed and monitored.



Federal Regulatory
Requirements

Reference Dose (RfD)

To Be Considered

Guidance used to characterize human health
risks due to non-carcinogens in site media.

This alternative will meet this standard by
removing potential non-carcinogenic
hazards and putting it under a cap at another
AOC where it will be properly managed and
monitored.



Location Specific

YES









Federal Regulatory
Requirements

Clean Water Act (33 U.S.C.
§ 1251 el seq,); Section
404(b)(1) Guidelines for
Specification of Disposal Sites
for Dredged or Fill Material (40
CFR Part 230, 231 and 33 CFR
Parts 320-323)

Applicable

This alternative includes work to be
performed in or near a wetland, Under this
requirement, no activity that adversely
affects a wetland shall be permitted if a
practicable alternative with lesser effects is
available. If activity takes place, impacts
must be minimized to the maximum extent.
Controls discharges of dredged or fill
material to protect aquatic ecosystems.

Adverse impacts will be minimized (o the
maximum extent practical.

Iron Horse Park 3rd OU-FS

Page 28 of 83

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TABLE L-10. ARARS, CRITERIA, ADVISORIES, AND GUIDANCE FOR THE B&M LOCOMOTIVE SHOP DISPOSAL AREAS

Alternative

ARAR, Media and
Authority

Requirements

Status

Triggering Action & Requirement
Synopsis

Action to be tahen to attain ARAR



Federal Regulatory
Requirements

Executive Order 11990;
"Protection of Wetlands" (40
CFR Part 6, Appendix A)

Applicable

This alternative includes work to be
performed in or near a wetland, Under this
requirement, no activity that adversely
affects a wetland shall be permitted if a
practicable alternative with lesser effects is
available. Ifactivity takes place, impacts
must be minimized to the maximum extent.

Adverse impacts will be minimized to the
maximum extent practical.



Federal Regulatory
Requirements

Fish and Wildlife Coordination
Act (16 U.S.C. §661 et seq.);
Fish and wildlife protection (40
CFR §6.302(g))

Applicable

This alternative includes work to be
performed in or near a wetland. Any
modification of a body of water requires
consultation with the U.S. Fish and Wildlife
Service and the appropriate state wildlife
agency to develop measures to prevent,
mitigate or compensate for losses of fish and
wildlife.

EPA will consult with U.S. Fish and
Wildlife Service should Remedial Activities
involve the modification of a body of water.



Massachusetts

Regulatory

Requirements

Wetlands Protection Act (Mass.
Gen. Laws ch. 131, §40);
Wetlands Protection
Regulations (310 CMR § 10.00)

Applicable

This alternative includes work to be
performed in or near a wetland. Sets
performance standards for dredging, filling,
altering of inland wetlands and within 100
feet of a wetland. The requirement also
defines wetlands based on vegetation type
and requires that effects on wetlands be
mitigated. Resource areas at the site
covered by the regulations include banks,
bordering vegetated wetlands, land under
bodies of water, land subject to flooding,
riverfront, and estimated habitats of rare
wildlife.

Adverse impacts to wetlands and regulated
buffer zones will be minimized to the
maximum extent practical,



Action Specific

YES









Federal Regulatory
Requirements

RCRA Subtitle C- Hazardous
Waste Identification and Listing
Regulations; Generator and
Handler Requirements (40
CFR Farts 260-262 and 264)

Applicable

These rules are used to identify, manage,
and dispose of hazardous waste.

Any media generated as part of excavation
activities will be tested for hazardous waste
characteristics. If determined to be
hazardous waste, then they will be stored,
transported, and disposed off site in
accordance with these standards.

Iron Horse Park 3rd OU-FS

Page 29 of 83

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TABLE L-10. ARARS, CRITERIA, ADVISORIES, AND GUIDANCE FOR THE B&M LOCOMOTIVE SHOP DISPOSAL AREAS

Alternative

ARAR, Media and
Authority

Requirements

Status

Triggering Action & Requirement
Synopsis

Action to be taken to attain ARAR



Fcderal Regulatory
Requirements

CWA Ambient Water Quality
Criteria (AWQC) (40 CFR 120)

Relevant and Appropriate

This provision sets standards for protecting
surface water quality.

Activities will be conducted to ensure that
the impact of site-related contaminants to
surface water will be minimzed,



Massachusetts

Regulatory

Requirements

Mass Solid Waste Management
Regulations (310 CMR 19,00)

Applicable for disposal standards; Relevant
aid Appropriate for Closure/Post Closure
Standards

These regulations address disposal of non-
hazardous waste and closure, post-closure,
and maintenance of solid waste landfills.

Any media generated as part of excavation
activities that is determined to be non-
hazardous would be managed and disposed
of in accordance with these standards. This
Alternative will be meet the closure/post
closure standards to prevent human contact,
ecological risk, and migration of
contaminants to surface and groundwater.



Massachusetts

Regulatory

Requirements

Management Standards for all
Hazardous Waste Facilities
(310 CMR 30,500), Waste
Analysis (310 CMR 30,513);
Management Standards (310
CMR 510)

Applicable

These rules are used to identify, manage,
and dispose of hazardous waste.

Any media generated as part of excavation
activities will be tested for hazardous waste
characteristics, If determined to be
hazardous waste, then they will be stored,
transported, and disposed off site in
accordance with these standards.



Massachusetts

Regulatory

Requirements

Massachusetts Clean Waters
Act (Mass, Gen. Laws ch. 21,
§§26-53); Water Quality
Certification for Discharge of
Dredged or Fill Material,
Dredging, and Dredged
Materials in Waters of the
United Slates within the
Commonwealth (314 CMR
§9.00)

Applicable

This alternative includes work to be
performed in or near a wetland. Establishes
criteria and standards for dredging, handling
and disposal of fill material and dredged
material.

Activities will be conducted in accordance
with these requriements to protect State
wetland resources.



Massachusetts

Regulatory

Requirements

Massachusetts Air Pollution
Control Regulations (310 CMR
7.09)

Applicable

This alternative includes excavation and/or
earthwork. Prohibits burning or emissions
of dust which causes or contributes to a
condition of air pollution. Standards for dust
are contained in 310 CMR 7.09.

These standards will be complied with
during any excavation of materials,

Iron Horse Park 3rd OU-FS

Page 30 of 83

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TABLE L-10. ARARS, CRITERIA, ADVISORIES, AND GUIDANCE FOR THE B&M LOCOMOTIVE SHOP DISPOSAL AREAS

Alternative

ARAR, Media and
Authority

Requirements

Status

Triggering Action & Requirement
Synopsis

Action to be taken to attain ARAR

Excavate & Treat
On-Site;
solidification &
stabilization













Chemical Specific

YES









Federal Regulatory
Requirements

Recommendations of the
Technical Review Workgroup
For Lead for an Approach to
Assessing Risks Associated
with Adult Exposured to Lead
in Soil

To be Considered

EPA guidance far evaluating the risks posed
by lead in soil.

Standard will be met by treating soil to
eliminate lead risk.



Federal Regulatory
Requirements

Cancer Slope Factors (CSF),

To Be Considered

Guidance used to compute the individual
incremental cancer risk resulting ftom
exposure to carcinogenic contaminants in
site media,

Standard will be met by treating soil to
eliminate risks from carcinogenic
contaminants.



Federal Regulatory
Requirements

Reference Dose (RfD)

To Be Considered

Guidance used to characterize human health
risks due to non-carcinogens in site media,

Standard will be met by treating soil to
eliminate risks from non-carcinogenic
contaminants,



Location Specific

YES









Federal Regulatory
Requirements

Clean Water Act (33 U.S.C. §
1251 el set/.); Section
404(b)(1) Guidelines for
Specification of Disposal Sites
for Dredged or Fill Material (40
CFR Part 230, 231 and 33 CFR
Parts 320-323)

Applicable

This alternative includes work to be
performed in or near a wetland. Under this
requirement, no activity that adversely
affects a wetland shall be permitted if a
practicable alternative with lesser effects is
available. If activity takes place, impacts
must be minimized to the maximum extent.
Controls discharges of dredged or fill
material to protect aquatic ecosystems.

Adverse impacts will be minimized to the
maximum extent practical.



Federal Regulatory
Requirements

Fish and Wildlife Coordination
Act (16 U.S.C. §661 et seq.);
Fish and wildlife protection (40
CFR §6.302(g))

Applicable

This alternative includes work to be
perfomed in or near a wetland. Any
modification of a body of water requires
consultation with the U.S. Fish and Wildlife
Service and the appropriate state wildlife
agency to develop measures to prevent,
mitigate or compensate for losses of fish and
wildlife,

Adverse impacts will be minimized to the
maximum extent practical,

Iron Horse Park 3rd OU-FS

Page 31 of83

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TABLE L-10. ARARS, CRITERIA, ADVISORIES, AND GUIDANCE FOR THE B&M LOCOMOTIVE SHOP DISPOSAL AREAS

Alternative

ARAR, Media and
Authority

Requirements

Status

Triggering Action & Requirement
Synopsis

Action to be taken to attain ARAR



Federal Regulatory
Requirements

Executive Order 11990;
"Protection of Wetlands" (40
CFR Part 6, Appendix A)

Applicable

This alternative includes work to be
performed in or near a wetland, Under this
requirement, no activity that adversely
affects a wetland shall be permitted if a
practicable alternative with lesser effects is
available. If activity takes place, impacts
must be minimized to the maximum extent,

Adverse impacts will be minimized to the
maximum extent practical,



Massachusetts

Regulatory

Requirements

Wetlands Protection Act (Mass.
Gen. Lews eh, 131, §40);
Weilands Protection
Regulations (310 CMR § 10.00)

Applicable

This alternative includes work to be
performed within 100 feet of a wetland.
Sets performance standards for dredging,
filling, altering of inland wetlands and
within 100 feet of a wetland. The
requirement also defines wetlands based on
vegetation type and requires that effects on
wetlands be mitigated. Resource areas at
the site covered by the regulations include
banks, bordering vegetated wetlands, land
under bodies of water, land subject to
flooding, riverfront, and estimated habitats
of rare wildlife.

Adverse impacts to wetlands and regulated
buffer zones will be minimized to the
maximum extent practical.



Action Specific

YES









Federal Regulatory
Requirements

RCRA Subtitle C- Hazardous
Waste Identification and Listing
Regulations; Generator and
Handler Requirements (40
CFR Parts 260-262 and 264)

Applicable

These rules are used to identify, manage,
and dispose of hazardous waste.

Any media generated as part of treatment
activities will be tested for hazardous waste
characteristics. If determined to be
hazardous waste, then they will be stored,
transported, and disposed off site in
accordance with these standards.



Federal Regulatory
Requirements

CWA Ambient Water Quality
Criteria (AWQC) (40 CFR 120)

Relevant and Appropriate

This provision sets standards for protecting
surface water quality.

Activities will be conducted to ensure that
the impact of site-related contaminants to
surface water will be minimzed.

Iron Horse Park 3rd OU-FS

Page 32 of 83

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TABLE L-10. ARARS, CRITERIA, ADVISORIES, AND GUIDANCE FOR THE B&M LOCOMOTIVE SHOP DISPOSAL AREAS

Alternative

ARAR, Media and
Authority

Requirements

Status

Triggering Action & Requirement
Synopsis

Action to be taken to attain ARAR



Massachusetts

Regulatory

Requirements

Mass Solid Waste Management
Regulations (310 CMR 19.00}

Applicable for disposal standards; Relevant
and Appropriate for Closure/Post Closure
Standards

These regulations address disposal of non-
hazardous waste and closure, post-closure,
and maintenance of solid -waste landfills.

Any media generated as part of treatment
activities that is determined to be non-
hazardous would be managed and disposed
of in accordance with these standards. This
Alternative will meet the closure/post
closure standards Co prevent human contact,
ecological risk, and migration of
contaminants to surface and groundwater.



Massachusetts

Regulatory
Requirements

Management Standards for all
Hazardous Waste Facilities
(310 CMR 30.500), Waste
Analysis (310 CMR 30.513);
Management Standards (310
CMR 510)

Applicable

These rules are used to identify, manage,
and dispose of hazardous waste.

Any media generated as part of excavation
activities will be tested for hazardous waste
characteristics. If determined to be
hazardous waste, then they will be stored,
transported, and disposed off site in
accordance with these standards.



Massachusetts

Regulatory

Requirements

Hazardous Waste Management
Storage and Treatment in Tanks
(310 CMR 30.690)

Applicable

This alternative includes treatment of wastes
in tanks. Specifies requirements for lank
systems used to store or treat hazardous
wastes in tanks. Provides specifications for
design and installation of tank systems.
Requires secondary containment, leak
detection systems, and inspections.

Identifies general operating requirements,
and closure and post-closure care,

Design and installation requirements will be
followed for any on-site treatment of
hazardous wastes in tanks. Since the
classification of wastes has not been
established as characteristic hazardous
waste, the need for compliance with these
regulations will be determined after
sampling and analysis of each media to be
treated or handled. Specifications will
include secondary containment, if necessary.



Massachusetts

Regulatory

Requirements

Massachusetts Clean Waters
Act (Mass. Gen. Laws ch. 21,
§§26-53); Water Quality
Certification for Discharge of
Dredged or Fill Material,
Dredging, and Dredged
Materials in Waters of the
United States within the
Commonwealth (314 CMR
§9.00)

Applicable

This alternative includes remediation
activities in wetlands and buffer zones.
Establishes criteria and standards for
dredging, handling and disposal of fill
material and dredged material.

Adverse impacts will be minimized to the
maximum extent practical to protect State
wetland resources,

Iron Horse Park 3rd OU-FS

Page 33 of 83

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TABLE L-10. ARARS, CRITERIA, ADVISORIES, AND GUIDANCE FOR THE B&M LOCOMOTIVE SHOP DISPOSAL AREAS

Alternative

ARAR, Media and
Authority

Requirements

Status

Triggering Action & Requirement
Synopsis

Action to be taken to attain ARAR



Massachusetts

Regulatory

Requirements

Massachusetts Air Pollution
Control Regulations (310 CMR
7.09)

Applicable

This alternative includes excavation and/or
earthwork, Prohibits burning or emissions
of dust which causes or contributes to a
condition of air pollution. Standards for dust
are contained in 310 CMR 7.09.

These standards will be complied with
during any excavation of materials.

Iron Horse Park 3rd OU-FS

Page 34 of 83

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TABLE L-10. ARARS, CRITERIA, ADVISORIES, AND GUIDANCE FOR THE B&M LOCOMOTIVE SHOP DISPOSAL AREAS

Alternative

ARAR, Media and
Authority

Requirements

Status

Triggering Action & Requirement
Synopsis

Action to be taken to attain ARAR

Excavate & Treat
On-Site: soil
washing & chemical
extraction













Chemical Specific

YES







-

Federal Regulatory
Requirements

Recommendations of the
Technical Review Workgroup
for Lead for an Approach to
Assessing Risks Associated
with Adult Exposured to Lead
in Soil

To be Considered

EPA guidance for evaluating the risks posed
by lead in soil.

Standard will be met by treating soil to
eliminate lead risk.



Federal Regulatory
Requirements

Cancer Slope Factors (CSF).

To Be Considered

Guidance used to compute the individual
incremental cancer risk resulting from
exposure to carcinogenic contaminants in
site media,

Standard will be met by treating soil to
eliminate risks from carcinogenic
contaminants.



Federal Regulatory
Requirements

Reference Dose (RfD)

To Be Considered

Guidance used to characterize human health
risks due to non-carcinogens in site media.

Standard will be met by treating soil to
eliminate risks from non-carcinogenic
contaminants.



Location Specific

YES









Federal Regulatory
Requirements

Clean Water Act (33 U.S.C. §
1251 el aeq.); Section
404(b)(1) Guidelines for
Specification of Disposal Sites
for Dredged or Fill Material (40
CFR Part 230, 231 and 33 CFR
Parts 320-323)

Applicable

This alternative includes work to be
performed in or near a wetland. Under this
requirement, no activity that adversely
affects a wetland shall be permitted if a
practicable alternative with lesser effects is
available. If activity takes place, impacts
must be minimized to the maximum extent.
Controls discharges of dredged or fill
material to protect aquatic ecosystems.

Adverse impacts will be minimized to the
maximum extent practical,



Federal Regulatory
Requirements

Fish and Wildlife Coordination
Act (16 U.S.C. §661 etseq.);
Fish and wildlife protection (40
CFR §6.302(g))

Applicable

This alternative includes work to be
performed in or near a wetland. Any
modification of a body of water requires
consultation with the U.S. Fish and Wildlife
Service and the appropriate state wildlife
agency to develop measures to prevent,
mitigate or compensate for losses of fish and
wildlife.

EPA will consult with U.S. Fish and
Wildlife Service should Remedial Activities
involve the modification of a body of water.

Iron Horse Park 3rd OU-FS

Page 35 of S3

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TABLE L-1Q. ARARS, CRITERIA, ADVISORIES, AND GUIDANCE FOR THE B&M LOCOMOTIVE SHOP DISPOSAL AREAS

Alternative

ARAR, Media and
Authority

Requirements

Status

Triggering Action & Requirement
Synopsis

Action to be taken to attain ARAR



Federal Regulatoiy
Requirements

Executive Order 11990;
"Protection of Wetlands" (40
CFR Part 6, Appendix A)

Applicable

This alternative includes work to be
performed in or near a wetland. Under this
requirement, no activity that adversely
affects a wetland shall be permitted if a
practicable alternative with lesser effects is
available. If activity lakes place, impacts
must be minimized to the maximum extent.

Adverse impacts will be minimized to the
maximum extent practical.



Massachusetts

Regulatory

Requirements

Wetlands Protection Act (Mass.
Gen. Laws ch. 131, §40);
Wetlands Protection
Regulations (310 CMR §10.00)

Applicable

This alternative includes work to be
performed within 100 feet of a wetland.
Sets performance standards for dredging,
filling, altering of inland wetlands and
within 100 feet of a wetland, The
requirement also defines wetlands based on
vegetation type and requires that effects on
wetlands be mitigated, Resource areas at
the site covered by the regulations include
banks, bordering vegetated wetlands, land
under bodies of water, land subject to
flooding, riverfront, and estimated habitats
of rare wildlife.

Adverse impacts to wetlands and regulated
buffer zones will be minimized to the
maximum extent practical.

Iron Horse Park 3rd OU-FS

Page 36 of 83

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TABLE L-10. ARARS, CRITERIA, ADVISORIES, AND GUIDANCE FOR THE B&M LOCOMOTIVE SHOP DISPOSAL AREAS

Alternative

ARAR, Media and
Authority

Requirements

Status

Triggering Action & Requirement
Synopsis

Action to be taken to attain ARAR



Action Specific

YES









Federal Regulatory
Requirements

RCRA Subtitle C- Hazardous
Waste Identification and Listing
Regulations; Generator and
Handler Requirements (40
CFR Parts 260-262 and 264)

Applicable

These rules are used to identify, manage,
and dispose of hazardous waste.

Any media generated as part of treatment
activities will be tested for hazardous waste
characteristics. If determined to be
hazardous waste, then they will be stored,
transported, and disposed off site in
accordance with these standards.



Federal Regulatory
Requirements

CWA Ambient Water Quality
Criteria (AWQC) (40 CFR 120)

Relevant and Appropriate

This provision sets standards for protecting
surface water quality.

Activities will be conducted to ensure that
the impact of site-related contaminants to
surface water will be minimzed.



Massachusetts

Regulatory

Requirements

Mass Solid Waste Management
Regulations (310 CMR 19.00)

Applicable for disposal standards; Relevant
and Appropriate for Closure/Post Closure
Standards

These regulations address disposal of non-
hazardous waste and closure, post-closure,
and maintenance of solid waste landfills.

Any media generated as part of treatment
activities that is determined to be non-
hazardous would be managed and disposed
of in accordance with these standards. This
Alternative will meet the closure/post
closure standards to prevent human contact,
ecological risk, and migration of
contaminants to surface and groundwater.



Massachusetts

Regulatory

Requirements

Management Standards for all
Hazardous Waste Facilities
(310 CMR 30.500), Waste
Analysis (310 CMR 30.513);
Management Standards (310
CMR 510)

Applicable

These rules are used to identify, manage,
and dispose of hazardous waste.

Any media generated as part of excavation
activities will be tested for hazardous waste
characteristics. If determined to be
hazardous waste, then they will be stored,
transported, and disposed off site in
accordance with these standards.



Massachusetts

Regulatory

Requirements

Hazardous Waste Management
Storage and Treatment in Tanks
(310 CMR 30.690)

Applicable

This alternative includes treatment of wastes
in tanks. Specifies requirements for tank
systems used to store or treat hazardous
wastes in tanks. Provides specifications for
design and installation of tank systems.
Requires secondary containment, leak
detection systems, and inspections.

Identifies general operating requirements,
and closure and post-closure care.

Design and installation requirements will be
followed for any on-site treatment of
hazardous wastes in tanks. Since the
classification of wastes has not been
established as characteristic hazardous
waste, the need for compliance with these
regulations will be determined after
sampling and analysis of each media to be
treated or handled. Specifications will
include secondary containment, if necessary.

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TABLE L-10. ARARS, CRITERIA, ADVISORIES, AND GUIDANCE FOR THE B&M LOCOMOTIVE SHOP DISPOSAL AREAS

Alternative

ARAR, Media and
Authority

Requirements

Status

Triggering Action & Requirement
Synopsis

Action to be taken to attain ARAR



Massachusetts

Regulatory

Requirements

Massachusetts Clean Waters
Act (Mass. Gen. Laws ch. 21,
§§26-53); Water Quality
Certification for Discharge of
Dredged or Fill Material,
Dredging, and Dredged
Materials in Waters of the
United States within the
Commonwealth (314 CMR
§9.00)

Applicable

This alternative includes remediation
activities in wetlands and buffer zones.
Establishes criteria and standards for
dredging, handling and disposal of fill
material and dredged material.

Adverse impacts will be minimized to the
maximum extent practical to protect State
wetland resources.



Massachusetts

Regulatory

Requirements

Massachusetts Air Pollution
Control Regulations (310 CMR
7.09)

Relevant and Appropriate

This alternative includes excavation and/or
earthwork. Prohibits burning or emissions
of dust which causes or contributes to a
condition of air pollution. Standards for dust
are contained in 310 CMR 7.09.

These standards will be met during any
excavation of materials.

Iron Horse Park 3rd OU-FS

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TABLE L-10. ARARS, CRITERIA, ADVISORIES, AND GUIDANCE FOR THE B&M LOCOMOTIVE SHOP DISPOSAL AREAS

Alternative

ARAR, Media and
Authority

Requirements

Status

Triggering Action & Requirement
Synopsis

Action to be taken to attain ARAR

Cap Waste













Chemical Specific

YES









Federal Regulatory
Requirements

Recommendations of the
Technical Review Workgroup
for Lead for an Approach to
Assessing Risks Associated
with Adult Exposured to Lead
in Soil

To be Considered

EPA guidance for evaluating the risks posed
by lead in soil.

Standard will be met by capping soil and
maintaining institutional controls to
eliminate lead risk.



Federal Regulatory
Requirements

Cancer Slope Factors (CSF).

To Be Considered

Guidance used to compute the individual
incremental cancer risk resulting from
exposure to carcinogenic contaminants in
site media.

This alternative will meet this standard by
capping potential carcinogenic hazards and
maintaining and monitoring the cap.



Federal Regulatory
Requirements

Reference Dose (RfD)

To Be Considered

Guidance used to characterize human health
risks due to non-carcinogens in site media.

This alternative will meet this standard by
capping potential non-carcinogenic hazards
and maintaining and monitoring the cap.



Location Specific

YES









Federal Regulatory
Requirements

Clean Water Act (33 U.S.C. §
1251 etseq.); Section
404(b)(1) Guidelines for
Specification of Disposal Sites
for Dredged or Fill Material (40
CFR Part 230, 231 and 33 CFR
Parts 320-323)

Applicable

This alternative includes work to be
performed in or near a wetland. Under this
requirement, no activity that adversely
affects a wetland shall be permitted if a
practicable alternative with lesser effects is
available. If activity takes place, impacts
must be minimized to the maximum extent.
Controls discharges of dredged or fill
material to protect aquatic ecosystems.

Given the location of contamination on the
edge of wetlands, this Alternative has been
determined to be the best practical
alternative. Adverse impacts to wetland
resources will be minimized to the
maximum extent practical and mitigation
conducted if required.



Federal Regulatory
Requirements

Executive Order 11990;
"Protection of Wetlands" (40
CFR Part 6, Appendix A)

Applicable

This alternative includes work to be
completed in a defined wetland. Under this
requirement, no activity that adversely
affects a wetland shall be permitted if a
practicable alternative with lesser effects is
available. If activity takes place, impacts
must be minimized to the maximum extent.

Given the location of contamination on the
edge of wetlands, this Alternative has been
determined to be the best practical
alternative. Adverse impacts to wetland
resources will be minimized to the
maximum extent practical and mitigation
conducted if required.

Iron Horse Park 3rd OU-FS

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TABLE L-10. ARARS, CRITERIA, ADVISORIES, AND GUIDANCE FOR THE B&M LOCOMOTIVE SHOP DISPOSAL AREAS

Alternative

ARAR, Media and
Authority

Requirements

Status

Triggering Action & Requirement
Synopsis

Action to be taken to attain ARAR



Federal Regulatory
Requirements

Fish and Wildlife Coordination
Act (16 U.S.C. §661 etseq.);
Fish and wildlife protection (40
CFR §6.302(g))

Applicable

This alternative includes work to be
performed in or near a wetland. Any
modification of a body of water requires
consultation with the U.S. Fish and Wildlife
Service and the appropriate state wildlife
agency to develop measures to prevent,
mitigate or compensate for losses of fish and
wildlife.

EPA will consult with U.S. Fish and
Wildlife Service should Remedial Activities
involve the modification of a body of water.



Massachusetts

Regulatory

Requirements

Wetlands Protection Act (Mass.
Gen. Laws ch. 131, §40);
Wetlands Protection
Regulations (310 CMR §10.00)

Applicable

This alternative includes work to be
performed within 100 feet of a wetland.
Sets performance standards for dredging,
filling, altering of inland wetlands and
within 100 feet of a wetland. The
requirement also defines wetlands based on
vegetation type and requires that effects on
wetlands be mitigated. Resource areas at
the site covered by the regulations include
banks, bordering vegetated wetlands, land
under bodies of water, land subject to
flooding, riverfront, and estimated habitats
of rare wildlife.

Substantive standards for protecting State
wetland resources will be complied with.
Mitigation of impacts on wetlands and
regulated buffer zones will be addressed.



Action Specific

YES









Federal Regulatory
Requirements

RCRA Subtitle C- Hazardous
Waste Identification and Listing
Regulations; Generator and
Handler Requirements (40
CFR Parts 260-262 and 264)

Applicable

These rules are used to identify, manage,
and dispose of hazardous waste.

Any media generated as part of monitoring
activities will be tested for hazardous waste
characteristics. If determined to be
hazardous waste, then they will be stored,
transported, and disposed off site in
accordance with these standards.



Federal Regulatory
Requirements

CWA Ambient Water Quality
Criteria (AWQC) (40 CFR 120)

Relevant and Appropriate

This provision sets standards for protecting
surface water quality.

Activities will be conducted to ensure that
the impact of site-related contaminants to
surface water will be minimzed.

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TABLE L-10. ARARS, CRITERIA, ADVISORIES, AND GUIDANCE FOR THE B&M LOCOMOTIVE SHOP DISPOSAL AREAS

Alternative

ARAR, Media and
Authority

Requirements

Status

Triggering Action & Requirement
Synopsis

Action to be taken to attain ARAR



Massachusetts

Regulatory

Requirements

Mass Solid Waste Management
Regulations (310 CMR 19.00)

Applicable for disposal standards; Relevant
and Appropriate for Closure/Post Closure
Standards

These regulations address disposal of non-
hazardous waste and closure, post-closure,
and maintenance of solid waste landfills.

Any media generated as part of monitoring
activities that is determined to be non-
hazardous would be managed and disposed
of in accordance with these standards. This
Alternative will be meet the closure/post
closure standards to prevent human contact,
ecological risk, and migration of
contaminants to surface and groundwater.



Massachusetts

Regulatory

Requirements

Management Standards for all
Hazardous Waste Facilities
(310 CMR 30.500), Waste
Analysis (310 CMR 30.513);
Management Standards (310
CMR 510)

Applicable

These rules are used to identify, manage,
and dispose of hazardous waste.

Any media generated as part of monitoring
activities will be tested for hazardous waste
characteristics. If determined to be
hazardous waste, then they will be stored,
transported, and disposed off site in
accordance with these standards.



Massachusetts

Regulatory

Requirements

Massachusetts DEP Landfill
Technical Guidance Manual

To be Considered

Provides a standard reference for and
guidance on landfill design, construction
and QA/QC procedures in accordance with
310 CMR 19.00

This Alternative will be meet the landfill
design standards to prevent human contact,
ecological risk, and migration of
contaminants to surface and groundwater.



Massachusetts

Regulatory

Requirements

Massachusetts Clean Waters
Act (Mass. Gen. Laws ch. 21,
§§26-53); Water Quality
Certification for Discharge of
Dredged or Fill Material,
Dredging, and Dredged
Materials in Waters of the
United States within the
Commonwealth (314 CMR
§9.00)

Applicable

This alternative includes work to be
performed in or near a wetland. Establishes
criteria and standards for dredging, handling
and disposal of fill material and dredged
material.

Activities will be conducted in accordance
with these requirements to protect State
wetland resources.



Massachusetts

Regulatory

Requirements

Massachusetts Air Pollution
Control Regulations (310 CMR
7.09)

Applicable

This alternative includes excavation and/or
earthwork. Prohibits burning or emissions
of dust which causes or contributes to a
condition of air pollution. Standards for dust
are contained in 310 CMR 7.09.

These standards will be complied with
during any excavation of materials at the
Site.

Iron Horse Park 3rd OU-FS

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TABLE L-ll. ARARS, CRITERIA, ADVISORIES, AND GUIDANCE FOR THE OLD B&M OIL/SLUDGE RECYCLING AREA

Alternative

ARAR, Media and
Authority

Requirements

Status

Triggering Action & Requirement
Synopsis

Action to be taken to attain ARAR

No Action













Chemical Specific

YES









Federal Regulatory
Requirements

Recommendations of the
Technical Review Workgroup
for Lead for an Approach to
Assessing Risks Associated
with Adult Exposured to Lead
in Soil

To be Considered

EPA guidance for evaluating the risks posed
by lead in soil.

Standard not met since alternative does not
address lead soil risks.



Federal Regulatory
Requirements

Cancer Slope Factors (CSF).

To Be Considered

Guidance used to compute the individual
incremental cancer risk resulting from
exposure to carcinogenic contaminants in
site media.

This alternative will not meet this standard
since potential carcinogenic hazards caused
by exposure to contaminants not addressed.



Federal Regulatory
Requirements

Reference Dose (RfD)

To Be Considered

Guidance used to characterize human health
risks due to non-carcinogens in site media.

This alternative will not meet this standard
since potential non-carcinogenic hazards
caused by exposure to contaminants not
addressed.



Location Specific

NO









Action Specific

NO







Iron Horse Park 3rd OU-FS

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TABLE L-ll. ARARS, CRITERIA, ADVISORIES, AND GUIDANCE FOR THE OLD B&M OIL/SLUDGE RECYCLING AREA

Alternative

ARAR, Media and
Authority

Requirements

Status

Triggering Action & Requirement
Synopsis

Action to be taken to attain ARAR

Limited Action:

Institutional

Controls













Chemical Specific

YES









Federal Regulatory
Requirements

Recommendations of the
Technical Review Workgroup
for Lead for an Approach to
Assessing Risks Associated
with Adult Exposured to Lead
in Soil

To be Considered

EPA guidance for evaluating the risks posed
by lead in soil.

Standard will be met through preventing
human access to lead contaminated soil.



Federal Regulatory
Requirements

Cancer Slope Factors (CSF).

To Be Considered

Guidance used to compute the individual
incremental cancer risk resulting from
exposure to carcinogenic contaminants in
site media.

This alternative will not meet this standard
since potential carcinogenic hazards caused
by migration of contaminants into
groundwater will not be addressed through
institutional controls.



Federal Regulatory
Requirements

Reference Dose (RfD)

To Be Considered

Guidance used to characterize human health
risks due to non-carcinogens in site media.

This alternative will not meet this standard
since potential carcinogenic hazards caused
by migration of contaminants into
groundwater will not be addressed through
institutional controls.



Location Specific

YES









Massachusetts

Regulatory

Requirements

Wetlands Protection Act (Mass.
Gen. Laws ch. 131, §40);
Wetlands Protection
Regulations (310 CMR § 10.00)

Applicable

This alternative includes work to be
performed within 100 feet of a wetland.
Sets performance standards for dredging,
filling, altering of inland wetlands and
within 100 feet of a wetland. The
requirement also defines wetlands based on
vegetation type and requires that effects on
wetlands be mitigated. Resource areas at
the site covered by the regulations include
banks, bordering vegetated wetlands, land
under bodies of water, land subject to
flooding, riverfront, and estimated habitats
of rare wildlife.

If new monitoring wells are needed, and no
practical alternative to locating in wetlands
or regulated buffer zone, then measures will
be taken to minimize impacts.



Action Specific

YES







Iron Horse Park 3rd OU-FS

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TABLE L-ll. ARARS, CRITERIA, ADVISORIES, AND GUIDANCE FOR THE OLD B&M OIL/SLUDGE RECYCLING AREA

Alternative

ARAR, Media and
Authority

Requirements

Status

Triggering Action & Requirement
Synopsis

Action to be taken to attain ARAR



Federal Regulatory
Requirements

RCRA Subtitle C- Hazardous
Waste Identification and Listing
Regulations; Generator and
Handler Requirements (40 CFR
Parts 260-262 and 264)

Applicable

These rules are used to identify, manage,
and dispose of hazardous waste.

Any media generated as part of monitoring
activities will be tested for hazardous waste
characteristics. If determined to be
hazardous waste, then they will be stored,
transported, and disposed off site in
accordance with these standards.



Massachusetts

Regulatory

Requirements

Hazardous Waste Management
Regulations (310 CMR
30.500); Waste Analysis (310
CMR 30.513); Management
Standards (310 CMR 510)

Applicable

Waste analysis performance standards are
spelled out.

Any media generated as part of monitoring
activities will be tested for hazardous waste
characteristics. If determined to be
hazardous waste, then they will be stored,
transported, and disposed off site in
accordance with these standards.



Massachusetts

Regulatory

Requirements

Mass Solid Waste Management
Regulations (310 CMR 19.00)

Applicable for disposal standards; Relevant
and Appropriate for Closure/Post Closure
Standards

These regulations address management and
disposal of non-hazardous waste, closure,
post-closure, and maintenance of solid waste
landfills.

Any media generated as part of monitoring
activities that is determined to be non-
hazardous would be managed and disposed
of in accordance with these standards.
However this Alternative will not meet the
closure/post closure standards because
institutional controls alone will not address
requirements to prevent migration of
contaminants to surface and groundwater.



Massachusetts

Regulatory

Requirements

Massachusetts DEP Landfill
Technical Guidance Manual

To be Considered

Provides a standard reference for and
guidance on landfill design, construction
and QA/QC procedures in accordance with
310 CMR 19.00

These standards will not be met because
institutional controls alone will not address
landfill design standards.

Iron Horse Park 3rd OU-FS

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TABLE L-ll. ARARS, CRITERIA, ADVISORIES, AND GUIDANCE FOR THE OLD B&M OIL/SLUDGE RECYCLING AREA

Alternative

ARAR, Media and
Authority

Requirements

Status

Triggering Action & Requirement
Synopsis

Action to be taken to attain ARAR

Monitored
Natural

Attenuation (in-
situ)













Chemical Specific

YES









Federal Regulatory
Requirements

Recommendations of the
Technical Review Workgroup
for Lead for an Approach to
Assessing Risks Associated
with Adult Exposured to Lead
in Soil

To be Considered

EPA guidance for evaluating the risks posed
by lead in soil.

Standard will be met by preventing human
access to lead contaminated soil through
institutional controls as part of the remedy.



Federal Regulatory
Requirements

Cancer Slope Factors (CSF).

To Be Considered

Guidance used to compute the individual
incremental cancer risk resulting from
exposure to carcinogenic contaminants in
site media.

This alternative might meet this standard if
potential carcinogenic hazards caused by
migration of contaminants into groundwater
are naturally attenuated over time. Potential
carcinogenic hazards caused by exposure to
contaminants would be addressed through
institutional controls.



Federal Regulatory
Requirements

Reference Dose (RfD)

To Be Considered

Guidance used to characterize human health
risks due to non-carcinogens in site media.

This alternative might meet this standard if
potential carcinogenic hazards caused by
migration of contaminants into groundwater
are naturally attenuated over time. Potential
carcinogenic hazards caused by exposure to
contaminants would be addressed through
institutional controls.



Location Specific

YES







Iron Horse Park 3rd OU-FS

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TABLE L-ll. ARARS, CRITERIA, ADVISORIES, AND GUIDANCE FOR THE OLD B&M OIL/SLUDGE RECYCLING AREA

Alternative

ARAR, Media and
Authority

Requirements

Status

Triggering Action & Requirement
Synopsis

Action to be taken to attain ARAR



Massachusetts

Regulatory

Requirements

Wetlands Protection Act (Mass.
Gen. Laws ch. 131, §40);
Wetlands Protection
Regulations (310 CMR §10.00)

Applicable

This alternative includes work to be
performed within 100 feet of a wetland.
Sets performance standards for dredging,
filling, altering of inland wetlands and
within 100 feet of a wetland. The
requirement also defines wetlands based on
vegetation type and requires that effects on
wetlands be mitigated. Resource areas at
the site covered by the regulations include
banks, bordering vegetated wetlands, land
under bodies of water, land subject to
flooding, riverfront, and estimated habitats
of rare wildlife.

If new monitoring wells are needed, and no
practical alternative to locating in wetlands
or regulated buffer zone, then measures will
be taken to minimize impacts.



Action Specific

YES









Federal Regulatory
Requirements

RCRA Subtitle C- Hazardous
Waste Identification and Listing
Regulations; Generator and
Handler Requirements (40 CFR
Parts 260-262 and 264)

Applicable

These rules are used to identify, manage,
and dispose of hazardous waste.

Any media generated as part of monitoring
activities will be tested for hazardous waste
characteristics. If determined to be
hazardous waste, then they will be stored,
transported, and disposed off site in
accordance with these standards.



Massachusetts

Regulatory

Requirements

Mass Solid Waste Management
Regulations (310 CMR 19.00)

Applicable for disposal standards; Relevant
and Appropriate for Closure/Post Closure
Standards

These regulations address management and
disposal of non-hazardous waste, closure,
post-closure, and maintenance of solid waste
landfills.

Any media generated as part of monitoring
activities that is determined to be non-
hazardous would be managed and disposed
of in accordance with these standards.
However this Alternative will not be meet
the closure/post closure standards.



Massachusetts

Regulatory

Requirements

Hazardous Waste Management
Regulations (310 CMR
30.500); Waste Analysis (310
CMR 30.513); Management
Standards (310 CMR 510)

Applicable

Waste analysis performance standards are
spelled out.

Any media generated as part of monitoring
activities will be tested for hazardous waste
characteristics. If determined to be
hazardous waste, then they will be stored,
transported, and disposed off site in
accordance with these standards.



Massachusetts

Regulatory

Requirements

Massachusetts DEP Landfill
Technical Guidance Manual

To be Considered

Provides a standard reference for and
guidance on landfill design, construction
and QA/QC procedures in accordance with
310 CMR 19.00

These standards will not be met because
institutional controls alone will not address
standards for landfill design.

Iron Horse Park 3rd OU-FS

Page 46 of 83

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TABLE L-ll. ARARS, CRITERIA, ADVISORIES, AND GUIDANCE FOR THE OLD B&M OIL/SLUDGE RECYCLING AREA

Alternative

ARAR, Media and
Authority

Requirements

Status

Triggering Action & Requirement
Synopsis

Action to be taken to attain ARAR

Excavate and
Place Under
Another On-Site
AOC Cap













Chemical Specific

YES









Federal Regulatory
Requirements

Recommendations of the
Technical Review Workgroup
for Lead for an Approach to
Assessing Risks Associated
with Adult Exposured to Lead
in Soil

To be Considered

EPA guidance for evaluating the risks posed
by lead in soil.

Standard will be met by removing lead
contaminated soil and placing it under a cap
at another AOC.



Federal Regulatory
Requirements

Cancer Slope Factors (CSF).

To Be Considered

Guidance used to compute the individual
incremental cancer risk resulting from
exposure to carcinogenic contaminants in
site media.

This alternative will meet this standard by
removing potential carcinogenic hazards and
putting it under a cap at another AOC where
it will be properly managed and monitored.



Federal Regulatory
Requirements

Reference Dose (RfD)

To Be Considered

Guidance used to characterize human health
risks due to non-carcinogens in site media.

This alternative will meet this standard by
removing potential non-carcinogenic
hazards and putting it under a cap at another
AOC where it will be properly managed and
monitored.



Location Specific

YES









Massachusetts

Regulatory

Requirements

Wetlands Protection Act (Mass.
Gen. Laws ch. 131, §40);
Wetlands Protection
Regulations (310 CMR §10.00)

Applicable

This alternative includes work to be
performed in or near a wetland. Sets
performance standards for dredging, filling,
altering of inland wetlands and within 100
feet of a wetland. The requirement also
defines wetlands based on vegetation type
and requires that effects on wetlands be
mitigated. Resource areas at the site
covered by the regulations include banks,
bordering vegetated wetlands, land under
bodies of water, land subject to flooding,
riverfront, and estimated habitats of rare
wildlife.

Adverse impacts to regulated wetland buffer
zones will be minimized to the maximum
extent practical.



Action Specific

YES







Iron Horse Park 3rd OU-FS

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TABLE L-ll. ARARS, CRITERIA, ADVISORIES, AND GUIDANCE FOR THE OLD B&M OIL/SLUDGE RECYCLING AREA

Alternative

ARAR, Media and
Authority

Requirements

Status

Triggering Action & Requirement
Synopsis

Action to be taken to attain ARAR



Federal Regulatory
Requirements

RCRA Subtitle C- Hazardous
Waste Identification and Listing
Regulations; Generator and
Handler Requirements (40
CFR Parts 260-262 and 264)

Applicable

These rules are used to identify, manage,
and dispose of hazardous waste.

Any media generated as part of excavation
activities will be tested for hazardous waste
characteristics. If determined to be
hazardous waste, then they will be stored,
transported, and disposed off site in
accordance with these standards.



Massachusetts

Regulatory

Requirements

Mass Solid Waste Management
Regulations (310 CMR 19.00)

Applicable for disposal standards; Relevant
and Appropriate for Closure/Post Closure
Standards

These regulations address disposal of non-
hazardous waste and closure, post-closure,
and maintenance of solid waste landfills.

Any media generated as part of excavation
activities that is determined to be non-
hazardous would be managed and disposed
of in accordance with these standards. This
Alternative will be meet the closure/post
closure standards to prevent human contact
and migration of contaminants to surface
and groundwater.



Massachusetts

Regulatory

Requirements

Management Standards for all
Hazardous Waste Facilities
(310 CMR 30.500), Waste
Analysis (310 CMR 30.513);
Management Standards (310
CMR 510)

Applicable

These rules are used to identify, manage,
and dispose of hazardous waste.

Any media generated as part of excavation
activities will be tested for hazardous waste
characteristics. If determined to be
hazardous waste, then they will be stored,
transported, and disposed off site in
accordance with these standards.



Massachusetts

Regulatory

Requirements

Massachusetts Air Pollution
Control Regulations (310 CMR
7.09)

Applicable

This alternative includes excavation and/or
earthwork. Prohibits burning or emissions
of dust which causes or contributes to a
condition of air pollution. Standards for dust
are contained in 310 CMR 7.09.

These standards will be complied with
during any excavation of materials.

Excavate & Treat
On-Site:
solidification &
stabilization













Chemical Specific

YES









Federal Regulatory
Requirements

Recommendations of the
Technical Review Workgroup
for Lead for an Approach to
Assessing Risks Associated
with Adult Exposured to Lead
in Soil

To be Considered

EPA guidance for evaluating the risks posed
by lead in soil.

Standard will be met by treating soil to
eliminate lead risk.

Iron Horse Park 3rd OU-FS

Page 48 of 83

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TABLE L-ll. ARARS, CRITERIA, ADVISORIES, AND GUIDANCE FOR THE OLD B&M OIL/SLUDGE RECYCLING AREA

Alternative

ARAR, Media and
Authority

Requirements

Status

Triggering Action & Requirement
Synopsis

Action to be taken to attain ARAR



Federal Regulatory
Requirements

Cancer Slope Factors (CSF).

To Be Considered

Guidance used to compute the individual
incremental cancer risk resulting from
exposure to carcinogenic contaminants in
site media.

Standard will be met by treating soil to
eliminate risks from carcinogenic
contaminants.



Federal Regulatory
Requirements

Reference Dose (RfD)

To Be Considered

Guidance used to characterize human health
risks due to non-carcinogens in site media.

Standard will be met by treating soil to
eliminate risks from non-carcinogenic
contaminants.



Location Specific

YES









Massachusetts

Regulatory

Requirements

Wetlands Protection Act (Mass.
Gen. Laws ch. 131, §40);
Wetlands Protection
Regulations (310 CMR §10.00)

Applicable

This alternative includes work to be
performed within 100 feet of a wetland.
Sets performance standards for dredging,
filling, altering of inland wetlands and
within 100 feet of a wetland. The
requirement also defines wetlands based on
vegetation type and requires that effects on
wetlands be mitigated. Resource areas at
the site covered by the regulations include
banks, bordering vegetated wetlands, land
under bodies of water, land subject to
flooding, riverfront, and estimated habitats
of rare wildlife.

Adverse impacts to regulated wetland buffer
zones will be minimized to the maximum
extent practical.



Action Specific

YES









Federal Regulatory
Requirements

RCRA Subtitle C- Hazardous
Waste Identification and Listing
Regulations; Generator and
Handler Requirements (40
CFR Parts 260-262 and 264)

Applicable

These rules are used to identify, manage,
and dispose of hazardous waste.

Any media generated as part of treatment
activities will be tested for hazardous waste
characteristics. If determined to be
hazardous waste, then they will be stored,
transported, and disposed off site in
accordance with these standards.



Massachusetts

Regulatory

Requirements

Mass Solid Waste Management
Regulations (310 CMR 19.00)

Applicable for disposal standards; Relevant
and Appropriate for Closure/Post Closure
Standards

These regulations address disposal of non-
hazardous waste and closure, post-closure,
and maintenance of solid waste landfills.

Any media generated as part of treatment
activities that is determined to be non-
hazardous would be managed and disposed
of in accordance with these standards. This
Alternative will meet the closure/post
closure standards to prevent human contact
and migration of contaminants to surface
and groundwater.

Iron Horse Park 3rd OU-FS

Page 49 of 83

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TABLE L-ll. ARARS, CRITERIA, ADVISORIES, AND GUIDANCE FOR THE OLD B&M OIL/SLUDGE RECYCLING AREA

Alternative

ARAR, Media and
Authority

Requirements

Status

Triggering Action & Requirement
Synopsis

Action to be taken to attain ARAR



Massachusetts

Regulatory

Requirements

Management Standards for all
Hazardous Waste Facilities
(310 CMR 30.500), Waste
Analysis (310 CMR 30.513);
Management Standards (310
CMR 510)

Applicable

These rules are used to identify, manage,
and dispose of hazardous waste.

Any media generated as part of excavation
activities will be tested for hazardous waste
characteristics. If determined to be
hazardous waste, then they will be stored,
transported, and disposed off site in
accordance with these standards.



Massachusetts

Regulatory

Requirements

Hazardous Waste Management
Storage and Treatment in Tanks
(310 CMR 30.690)

Applicable

This alternative includes treatment of wastes
in tanks. Specifies requirements for tank
systems used to store or treat hazardous
wastes in tanks. Provides specifications for
design and installation of tank systems.
Requires secondary containment, leak
detection systems, and inspections.

Identifies general operating requirements,
and closure and post-closure care.

Design and installation requirements will be
followed for any on-site treatment of
hazardous wastes in tanks. Since the
classification of wastes has not been
established as characteristic hazardous
waste, the need for compliance with these
regulations will be determined after
sampling and analysis of each media to be
treated or handled. Specifications will
include secondary containment, if necessary.



Massachusetts

Regulatory

Requirements

Massachusetts Air Pollution
Control Regulations (310 CMR
7.09)

Applicable

This alternative includes excavation and/or
earthwork. Prohibits burning or emissions
of dust which causes or contributes to a
condition of air pollution. Standards for dust
are contained in 310 CMR 7.09.

These standards will be complied with
during any excavation of materials.

Excavate & Treat
On-Site: soil
washing &
chemical
extraction













Chemical Specific

YES









Federal Regulatory
Requirements

Recommendations of the
Technical Review Workgroup
for Lead for an Approach to
Assessing Risks Associated
with Adult Exposured to Lead
in Soil

To be Considered

EPA guidance for evaluating the risks posed
by lead in soil.

Standard will be met by treating soil to
eliminate lead risk.

Iron Horse Park 3rd OU-FS

Page 50 of 83

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TABLE L-ll. ARARS, CRITERIA, ADVISORIES, AND GUIDANCE FOR THE OLD B&M OIL/SLUDGE RECYCLING AREA

Alternative

ARAR, Media and
Authority

Requirements

Status

Triggering Action & Requirement
Synopsis

Action to be taken to attain ARAR



Federal Regulatory
Requirements

Cancer Slope Factors (CSF).

To Be Considered

Guidance used to compute the individual
incremental cancer risk resulting from
exposure to carcinogenic contaminants in
site media.

Standard will be met by treating soil to
eliminate risks from carcinogenic
contaminants.



Federal Regulatory
Requirements

Reference Dose (RfD)

To Be Considered

Guidance used to characterize human health
risks due to non-carcinogens in site media.

Standard will be met by treating soil to
eliminate risks from non-carcinogenic
contaminants.



Location Specific

YES









Massachusetts

Regulatory

Requirements

Wetlands Protection Act (Mass.
Gen. Laws ch. 131, §40);
Wetlands Protection
Regulations (310 CMR §10.00)

Applicable

This alternative includes work to be
performed within 100 feet of a wetland.
Sets performance standards for dredging,
filling, altering of inland wetlands and
within 100 feet of a wetland. The
requirement also defines wetlands based on
vegetation type and requires that effects on
wetlands be mitigated. Resource areas at
the site covered by the regulations include
banks, bordering vegetated wetlands, land
under bodies of water, land subject to
flooding, riverfront, and estimated habitats
of rare wildlife.

Adverse impacts to regulated wetland buffer
zones will be minimized to the maximum
extent practical.



Action Specific

YES









Federal Regulatory
Requirements

RCRA Subtitle C- Hazardous
Waste Identification and Listing
Regulations; Generator and
Handler Requirements (40
CFR Parts 260-262 and 264)

Applicable

These rules are used to identify, manage,
and dispose of hazardous waste.

Any media generated as part of treatment
activities will be tested for hazardous waste
characteristics. If determined to be
hazardous waste, then they will be stored,
transported, and disposed off site in
accordance with these standards.



Massachusetts

Regulatory

Requirements

Mass Solid Waste Management
Regulations (310 CMR 19.00)

Applicable for disposal standards; Relevant
and Appropriate for Closure/Post Closure
Standards

These regulations address disposal of non-
hazardous waste and closure, post-closure,
and maintenance of solid waste landfills.

Any media generated as part of treatment
activities that is determined to be non-
hazardous would be managed and disposed
of in accordance with these standards. This
Alternative will meet the closure/post
closure standards to prevent human contact
and migration of contaminants to surface
and groundwater.

Iron Horse Park 3rd OU-FS

Page 51 of 83

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TABLE L-ll. ARARS, CRITERIA, ADVISORIES, AND GUIDANCE FOR THE OLD B&M OIL/SLUDGE RECYCLING AREA

Alternative

ARAR, Media and
Authority

Requirements

Status

Triggering Action & Requirement
Synopsis

Action to be taken to attain ARAR



Massachusetts

Regulatory

Requirements

Management Standards for all
Hazardous Waste Facilities
(310 CMR 30.500), Waste
Analysis (310 CMR 30.513);
Management Standards (310
CMR 510)

Applicable

These rules are used to identify, manage,
and dispose of hazardous waste.

Any media generated as part of excavation
activities will be tested for hazardous waste
characteristics. If determined to be
hazardous waste, then they will be stored,
transported, and disposed off site in
accordance with these standards.



Massachusetts

Regulatory

Requirements

Hazardous Waste Management
Storage and Treatment in Tanks
(310 CMR 30.690)

Applicable

This alternative includes treatment of wastes
in tanks. Specifies requirements for tank
systems used to store or treat hazardous
wastes in tanks. Provides specifications for
design and installation of tank systems.
Requires secondary containment, leak
detection systems, and inspections.

Identifies general operating requirements,
and closure and post-closure care.

Design and installation requirements will be
followed for any on-site treatment of
hazardous wastes in tanks. Since the
classification of wastes has not been
established as characteristic hazardous
waste, the need for compliance with these
regulations will be determined after
sampling and analysis of each media to be
treated or handled. Specifications will
include secondary containment, if necessary.



Massachusetts

Regulatory

Requirements

Massachusetts Air Pollution
Control Regulations (310 CMR
7.09)

Applicable

This alternative includes excavation and/or
earthwork. Prohibits burning or emissions
of dust which causes or contributes to a
condition of air pollution. Standards for dust
are contained in 310 CMR 7.09.

These standards will be complied with
during any excavation of materials.

Cap Waste













Chemical Specific

YES









Federal Regulatory
Requirements

Recommendations of the
Technical Review Workgroup
for Lead for an Approach to
Assessing Risks Associated
with Adult Exposured to Lead
in Soil

To be Considered

EPA guidance for evaluating the risks posed
by lead in soil.

Standard will be met by capping soil and
maintaining institutional controls to
eliminate lead risk.



Federal Regulatory
Requirements

Cancer Slope Factors (CSF).

To Be Considered

Guidance used to compute the individual
incremental cancer risk resulting from
exposure to carcinogenic contaminants in
site media.

This alternative will meet this standard by
capping potential carcinogenic hazards and
maintaining and monitoring the cap.

Iron Horse Park 3rd OU-FS

Page 52 of 83

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TABLE L-ll. ARARS, CRITERIA, ADVISORIES, AND GUIDANCE FOR THE OLD B&M OIL/SLUDGE RECYCLING AREA

Alternative

ARAR, Media and
Authority

Requirements

Status

Triggering Action & Requirement
Synopsis

Action to be taken to attain ARAR



Federal Regulatory
Requirements

Reference Dose (RfD)

To Be Considered

Guidance used to characterize human health
risks due to non-carcinogens in site media.

This alternative will meet this standard by
capping potential non-carcinogenic hazards
and maintaining and monitoring the cap.



Location Specific

YES









Massachusetts

Regulatory

Requirements

Wetlands Protection Act (Mass.
Gen. Laws ch. 131, §40);
Wetlands Protection
Regulations (310 CMR §10.00)

Applicable

This alternative includes work to be
performed within 100 feet of a wetland.
Sets performance standards for dredging,
filling, altering of inland wetlands and
within 100 feet of a wetland. The
requirement also defines wetlands based on
vegetation type and requires that effects on
wetlands be mitigated. Resource areas at
the site covered by the regulations include
banks, bordering vegetated wetlands, land
under bodies of water, land subject to
flooding, riverfront, and estimated habitats
of rare wildlife.

Adverse impacts to regulated wetland buffer
zones will be minimized to the maximum
extent practical.



Action Specific

YES









Federal Regulatory
Requirements

RCRA Subtitle C- Hazardous
Waste Identification and Listing
Regulations; Generator and
Handler Requirements (40
CFR Parts 260-262 and 264)

Applicable

These rules are used to identify, manage,
and dispose of hazardous waste.

Any media generated as part of monitoring
activities will be tested for hazardous waste
characteristics. If determined to be
hazardous waste, then they will be stored,
transported, and disposed off site in
accordance with these standards.

Iron Horse Park 3rd OU-FS

Page 53 of 83

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LE L-12. ARARS, CRITERIA, ADVISORIES, AND GUIDANCE FOR THE CONTAMINATED SOILS AREA

ARAR, Media and
Authority

Requirements

Status

Triggering Action & Requirement
Synopsis

Action to be taken to attain ARAR











Chemical Specific

YES







Federal Regulatory
Requirements

Recommendations of the
Technical Review Workgroup
for Lead for an Approach to
Assessing Risks Associated
with Adult Exposured to Lead
in Soil

To be Considered

EPA guidance for evaluating the risks posed
by lead in soil.

Standard not met since alternative does not
address lead soil risks.

Federal Regulatory
Requirements

Cancer Slope Factors (CSF).

To Be Considered

Guidance used to compute the individual
incremental cancer risk resulting from
exposure to carcinogenic contaminants in
site media.

This alternative will not meet this standard
since potential carcinogenic hazards caused
by exposure to contaminants not addressed.

Federal Regulatory
Requirements

Reference Dose (RfD)

To Be Considered

Guidance used to characterize human health
risks due to non-carcinogens in site media.

This alternative will not meet this standard
since potential non-carcinogenic hazards
caused by exposure to contaminants not
addressed.

Location Specific

NO







Action Specific

NO

















Chemical Specific

YES







Federal Regulatory
Requirements

Recommendations of the
Technical Review Workgroup
for Lead for an Approach to
Assessing Risks Associated
with Adult Exposured to Lead
in Soil

To be Considered

EPA guidance for evaluating the risks posed
by lead in soil.

Standard will be met through preventing
human access to lead contaminated soil.

Federal Regulatory
Requirements

Cancer Slope Factors (CSF).

To Be Considered

Guidance used to compute the individual
incremental cancer risk resulting from
exposure to carcinogenic contaminants in
site media.

This alternative will not meet this standard
since potential carcinogenic hazards caused
by migration of contaminants into
groundwater will not be addressed through
institutional controls.

Iron Horse Park 3rd OU-FS

Page 54 of 83

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LE L-12. ARARS, CRITERIA, ADVISORIES, AND GUIDANCE FOR THE CONTAMINATED SOILS AREA

ARAR, Media and
Authority

Requirements

Status

Triggering Action & Requirement
Synopsis

Action to be taken to attain ARAR

Federal Regulatory
Requirements

Reference Dose (RfD)

To Be Considered

Guidance used to characterize human health
risks due to non-carcinogens in site media.

This alternative will not meet this standard
since potential carcinogenic hazards caused
by migration of contaminants into
groundwater will not be addressed through
institutional controls.

Location Specific

YES







Action Specific

YES







Federal Regulatory
Requirements

RCRA Subtitle C- Hazardous
Waste Identification and Listing
Regulations; Generator and
Handler Requirements (40 CFR
Parts 260-262 and 264)

Applicable

These rules are used to identify, manage,
and dispose of hazardous waste.

Any media generated as part of monitoring
activities will be tested for hazardous waste
characteristics. If determined to be
hazardous waste, then they will be stored,
transported, and disposed off site in
accordance with these standards.

Massachusetts

Regulatory

Requirements

Management Standards for all
Hazardous Waste Facilities
(310 CMR 30.500); Waste
Analysis (310 CMR 30.513);
Management Standards (310
CMR 510)

Applicable

These rules are used to identify, manage,
and dispose of hazardous waste.

Any media generated as part of monitoring
activities will be tested for hazardous waste
characteristics. If determined to be
hazardous waste, then they will be stored,
transported, and disposed off site in
accordance with these standards.

Massachusetts

Regulatory

Requirements

Mass Solid Waste Management
Regulations (310 CMR 19.00)

Applicable for disposal standards; Relevant
and Appropriate for Closure/Post Closure
Standards

These regulations address management and
disposal of non-hazardous waste, closure,
post-closure, and maintenance of solid waste
landfills.

Any media generated as part of monitoring
activities that is determined to be non-
hazardous would be managed and disposed
of in accordance with these standards.
However this Alternative will not meet the
closure/post closure standards because
institutional controls alone will not address
requirements to prevent migration of
contaminants to surface and groundwater.

Massachusetts

Regulatory

Requirements

Massachusetts DEP Landfill
Technical Guidance Manual

To be Considered

Provides a standard reference for and
guidance on landfill design, construction
and QA/QC procedures in accordance with
310 CMR 19.00

These standards will not be met because
institutional controls alone will not address
landfill design standards.











Iron Horse Park 3rd OU-FS

Page 55 of 83

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LE L-12. ARARS, CRITERIA, ADVISORIES, AND GUIDANCE FOR THE CONTAMINATED SOILS AREA

ARAR, Media and
Authority

Requirements

Status

Triggering Action & Requirement
Synopsis

Action to be taken to attain ARAR

Chemical Specific

YES







Federal Regulatory
Requirements

Recommendations of the
Technical Review Workgroup
for Lead for an Approach to
Assessing Risks Associated
with Adult Exposured to Lead
in Soil

To be Considered

EPA guidance for evaluating the risks posed
by lead in soil.

Standard will be met by preventing human
access to lead contaminated soil through
institutional controls as part of the remedy.

Federal Regulatory
Requirements

Cancer Slope Factors (CSF).

To Be Considered

Guidance used to compute the individual
incremental cancer risk resulting from
exposure to carcinogenic contaminants in
site media.

This alternative might meet this standard if
potential carcinogenic hazards caused by
migration of contaminants into groundwater
are naturally attenuated over time. Potential
carcinogenic hazards caused by exposure to
contaminants would be addressed through
institutional controls.

Federal Regulatory
Requirements

Reference Dose (RfD)

To Be Considered

Guidance used to characterize human health
risks due to non-carcinogens in site media.

This alternative might meet this standard if
potential carcinogenic hazards caused by
migration of contaminants into groundwater
are naturally attenuated over time. Potential
carcinogenic hazards caused by exposure to
contaminants would be addressed through
institutional controls.

Location Specific

YES







Iron Horse Park 3rd OU-FS

Page 56 of 83

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LE L-12. ARARS, CRITERIA, ADVISORIES, AND GUIDANCE FOR THE CONTAMINATED SOILS AREA

ARAR, Media and
Authority

Requirements

Status

Triggering Action & Requirement
Synopsis

Action to be taken to attain ARAR

Massachusetts

Regulatory

Requirements

Wetlands Protection Act (Mass.
Gen. Laws ch. 131, §40);
Wetlands Protection
Regulations (310 CMR §10.00)

Applicable

This alternative includes work to be
performed within 100 feet of a wetland.
Sets performance standards for dredging,
filling, altering of inland wetlands and
within 100 feet of a wetland. The
requirement also defines wetlands based on
vegetation type and requires that effects on
wetlands be mitigated. Resource areas at
the site covered by the regulations include
banks, bordering vegetated wetlands, land
under bodies of water, land subject to
flooding, riverfront, and estimated habitats
of rare wildlife.

If new monitoring wells are needed, and no
practical alternative to locating in wetlands
or regulated buffer zone, then measures will
be taken to minimize impacts.

Action Specific

YES







Federal Regulatory
Requirements

RCRA Subtitle C- Hazardous
Waste Identification and Listing
Regulations; Generator and
Handler Requirements (40 CFR
Parts 260-262 and 264)

Applicable

These rules are used to identify, manage,
and dispose of hazardous waste.

Any media generated as part of monitoring
activities will be tested for hazardous waste
characteristics. If determined to be
hazardous waste, then they will be stored,
transported, and disposed off site in
accordance with these standards.

Massachusetts

Regulatory

Requirements

Management Standards for all
Hazardous Waste Facilities
(310 CMR 30.500); Waste
Analysis (310 CMR 30.513);
Management Standards (310
CMR 510)

Applicable

These rules are used to identify, manage,
and dispose of hazardous waste.

Any media generated as part of monitoring
activities will be tested for hazardous waste
characteristics. If determined to be
hazardous waste, then they will be stored,
transported, and disposed off site in
accordance with these standards.

Massachusetts

Regulatory

Requirements

Mass Solid Waste Management
Regulations (310 CMR 19.00)

Applicable for disposal standards; Relevant
and Appropriate for Closure/Post Closure
Standards

These regulations address management and
disposal of non-hazardous waste, closure,
post-closure, and maintenance of solid waste
landfills.

Any media generated as part of monitoring
activities that is determined to be non-
hazardous would be managed and disposed
of in accordance with these standards.
However this Alternative will not be meet
the closure/post closure standards.

Massachusetts

Regulatory

Requirements

Massachusetts DEP Landfill
Technical Guidance Manual

To be Considered

Provides a standard reference for and
guidance on landfill design, construction
and QA/QC procedures in accordance with
310 CMR 19.00

These standards will not be met because
institutional controls alone will not address
standards for landfill design.

Iron Horse Park 3rd OU-FS

Page 57 of 83

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LE L-12. ARARS, CRITERIA, ADVISORIES, AND GUIDANCE FOR THE CONTAMINATED SOILS AREA

ARAR, Media and
Authority

Requirements

Status

Triggering Action & Requirement
Synopsis

Action to be taken to attain ARAR











Chemical Specific

YES







Federal Regulatory
Requirements

Recommendations of the
Technical Review Workgroup
for Lead for an Approach to
Assessing Risks Associated
with Adult Exposured to Lead
in Soil

To be Considered

EPA guidance for evaluating the risks posed
by lead in soil.

Standard will be met by treating soil to
eliminate lead risk.

Federal Regulatory
Requirements

Cancer Slope Factors (CSF).

To Be Considered

Guidance used to compute the individual
incremental cancer risk resulting from
exposure to carcinogenic contaminants in
site media.

Standard will be met by treating soil to
eliminate risks from carcinogenic
contaminants.

Federal Regulatory
Requirements

Reference Dose (RfD)

To Be Considered

Guidance used to characterize human health
risks due to non-carcinogens in site media.

Standard will be met by treating soil to
eliminate risks from non-carcinogenic
contaminants.

Location Specific

YES







Massachusetts

Regulatory

Requirements

Wetlands Protection Act (Mass.
Gen. Laws ch. 131, §40);
Wetlands Protection
Regulations (310 CMR §10.00)

Applicable

This alternative includes work to be
performed within 100 feet of a wetland.
Sets performance standards for dredging,
filling, altering of inland wetlands and
within 100 feet of a wetland. The
requirement also defines wetlands based on
vegetation type and requires that effects on
wetlands be mitigated. Resource areas at
the site covered by the regulations include
banks, bordering vegetated wetlands, land
under bodies of water, land subject to
flooding, riverfront, and estimated habitats
of rare wildlife.

Adverse impacts to regulated wetland buffer
zones will be minimized to the maximum
extent practical.

Action Specific

YES







Iron Horse Park 3rd OU-FS

Page 58 of 83

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LE L-12. ARARS, CRITERIA, ADVISORIES, AND GUIDANCE FOR THE CONTAMINATED SOILS AREA

ARAR, Media and
Authority

Requirements

Status

Triggering Action & Requirement
Synopsis

Action to be taken to attain ARAR

Federal Regulatory
Requirements

RCRA Subtitle C- Hazardous
Waste Identification and Listing
Regulations; Generator and
Handler Requirements (40 CFR
Parts 260-262 and 264)

Applicable

These rules are used to identify, manage,
and dispose of hazardous waste.

Any media generated as part of treatment
activities will be tested for hazardous waste
characteristics. If determined to be
hazardous waste, then they will be stored,
transported, and disposed off site in
accordance with these standards.

Massachusetts

Regulatory

Requirements

Management Standards for all
Hazardous Waste Facilities
(310 CMR 30.500); Waste
Analysis (310 CMR 30.513);
Management Standards (310
CMR 510); Storage and
Treatment in Tanks (310 CMR
30.690)

Applicable

These rules are used to identify, manage,
and dispose of hazardous waste. This
alternative also includes treatment of wastes
in tanks. Specifies requirements for tank
systems used to store or treat hazardous
wastes in tanks. Provides specifications for
design and installation of tank systems.
Requires secondary containment, leak
detection systems, and inspections.

Identifies general operating requirements,
and closure and post-closure care.

Any media generated as part of monitoring
activities will be tested for hazardous waste
characteristics. If determined to be
hazardous waste, then they will be stored,
transported, and disposed off site in
accordance with these standards. Design and
installation requirements will be followed
for any on-site treatment of hazardous
wastes in tanks. Since the classification of
wastes has not been established as
characteristic hazardous waste, the need for
compliance with these regulations will be
determined after sampling and analysis of
each media to be treated or handled.
Specifications will include secondary
containment, if necessary.

Massachusetts

Regulatory

Requirements

Mass Solid Waste Management
Regulations (310 CMR 19.00)

Applicable for disposal standards; Relevant
and Appropriate for Closure/Post Closure
Standards

These regulations address disposal of non-
hazardous waste and closure, post-closure,
and maintenance of solid waste landfills.

Any media generated as part of treatment
activities that is determined to be non-
hazardous would be managed and disposed
of in accordance with these standards. This
Alternative will meet the closure/post
closure standards to prevent human contact
and migration of contaminants to surface
and groundwater.

Massachusetts

Regulatory

Requirements

Massachusetts Air Pollution
Control Regulations (310 CMR
7.09)

Relevant and Appropriate

This alternative includes excavation and/or
earthwork. Prohibits burning or emissions
of dust which causes or contributes to a
condition of air pollution. Standards for dust
are contained in 310 CMR 7.09.

These standards will be complied with
during any excavation of materials at the
Site.

Iron Horse Park 3rd OU-FS

Page 59 of 83

-------
LE L-12. ARARS, CRITERIA, ADVISORIES, AND GUIDANCE FOR THE CONTAMINATED SOILS AREA

ARAR, Media and
Authority

Requirements

Status

Triggering Action & Requirement
Synopsis

Action to be taken to attain ARAR











Chemical Specific

YES







Federal Regulatory
Requirements

Recommendations of the
Technical Review Workgroup
for Lead for an Approach to
Assessing Risks Associated
with Adult Exposured to Lead
in Soil

To be Considered

EPA guidance for evaluating the risks posed
by lead in soil.

Standard will be met by treating soil to
eliminate lead risk.

Federal Regulatory
Requirements

Cancer Slope Factors (CSF).

To Be Considered

Guidance used to compute the individual
incremental cancer risk resulting from
exposure to carcinogenic contaminants in
site media.

Standard will be met by treating soil to
eliminate risks from carcinogenic
contaminants.

Federal Regulatory
Requirements

Reference Dose (RfD)

To Be Considered

Guidance used to characterize human health
risks due to non-carcinogens in site media.

Standard will be met by treating soil to
eliminate risks from non-carcinogenic
contaminants.

Location Specific

YES







Massachusetts

Regulatory

Requirements

Wetlands Protection Act (Mass.
Gen. Laws ch. 131, §40);
Wetlands Protection
Regulations (310 CMR §10.00)

Applicable

This alternative includes work to be
performed within 100 feet of a wetland.
Sets performance standards for dredging,
filling, altering of inland wetlands and
within 100 feet of a wetland. The
requirement also defines wetlands based on
vegetation type and requires that effects on
wetlands be mitigated. Resource areas at
the site covered by the regulations include
banks, bordering vegetated wetlands, land
under bodies of water, land subject to
flooding, riverfront, and estimated habitats
of rare wildlife.

Adverse impacts to regulated wetland buffer
zones will be minimized to the maximum
extent practical.

Action Specific

YES







Iron Horse Park 3rd OU-FS

Page 60 of 83

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LE L-12. ARARS, CRITERIA, ADVISORIES, AND GUIDANCE FOR THE CONTAMINATED SOILS AREA

ARAR, Media and
Authority

Requirements

Status

Triggering Action & Requirement
Synopsis

Action to be taken to attain ARAR

Federal Regulatory
Requirements

RCRA Subtitle C- Hazardous
Waste Identification and Listing
Regulations; Generator and
Handler Requirements (40 CFR
Parts 260-262 and 264)

Applicable

These rules are used to identify, manage,
and dispose of hazardous waste.

Any media generated as part of treatment
activities will be tested for hazardous waste
characteristics. If determined to be
hazardous waste, then they will be stored,
transported, and disposed off site in
accordance with these standards.

Massachusetts

Regulatory

Requirements

Management Standards for all
Hazardous Waste Facilities
(310 CMR 30.500); Waste
Analysis (310 CMR 30.513);
Management Standards (310
CMR 510); Storage and
Treatment in Tanks (310 CMR
30.690)

Applicable

These rules are used to identify, manage,
and dispose of hazardous waste. This
alternative also includes treatment of wastes
in tanks. Specifies requirements for tank
systems used to store or treat hazardous
wastes in tanks. Provides specifications for
design and installation of tank systems.
Requires secondary containment, leak
detection systems, and inspections.
Identifies general operating requirements,
and closure and post-closure care.

Any media generated as part of monitoring
activities will be tested for hazardous waste
characteristics. If determined to be
hazardous waste, then they will be stored,
transported, and disposed off site in
accordance with these standards. Design and
installation requirements will be followed
for any on-site treatment of hazardous
wastes in tanks. Since the classification of
wastes has not been established as
characteristic hazardous waste, the need for
compliance with these regulations will be
determined after sampling and analysis of
each media to be treated or handled.
Specifications will include secondary
containment, if necessary.

Massachusetts

Regulatory

Requirements

Mass Solid Waste Management
Regulations (310 CMR 19.00)

Applicable for disposal standards; Relevant
and Appropriate for Closure/Post Closure
Standards

These regulations address disposal of non-
hazardous waste and closure, post-closure,
and maintenance of solid waste landfills.

Any media generated as part of treatment
activities that is determined to be non-
hazardous would be managed and disposed
of in accordance with these standards. This
Alternative will meet the closure/post
closure standards to prevent human contact
and migration of contaminants to surface
and groundwater.

Massachusetts

Regulatory

Requirements

Massachusetts Air Pollution
Control Regulations (310 CMR
7.09)

Relevant and Appropriate

This alternative includes excavation and/or
earthwork. Prohibits burning or emissions
of dust which causes or contributes to a
condition of air pollution. Standards for dust
are contained in 310 CMR 7.09.

These standards will be complied with
during any excavation of materials at the
Site.











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LE L-12. ARARS, CRITERIA, ADVISORIES, AND GUIDANCE FOR THE CONTAMINATED SOILS AREA

ARAR, Media and
Authority

Requirements

Status

Triggering Action & Requirement
Synopsis

Action to be taken to attain ARAR

Chemical Specific

YES







Federal Regulatory
Requirements

Recommendations of the
Technical Review Workgroup
for Lead for an Approach to
Assessing Risks Associated
with Adult Exposured to Lead
in Soil

To be Considered

EPA guidance for evaluating the risks posed
by lead in soil.

Standard will be met by capping soil and
maintaining institutional controls to
eliminate lead risk.

Federal Regulatory
Requirements

Cancer Slope Factors (CSF).

To Be Considered

Guidance used to compute the individual
incremental cancer risk resulting from
exposure to carcinogenic contaminants in
site media.

This alternative will meet this standard by
capping potential carcinogenic hazards and
maintaining and monitoring the cap.

Federal Regulatory
Requirements

Reference Dose (RfD)

To Be Considered

Guidance used to characterize human health
risks due to non-carcinogens in site media.

This alternative will meet this standard by
capping potential non-carcinogenic hazards
and maintaining and monitoring the cap.

Location Specific

YES







Massachusetts

Regulatory

Requirements

Wetlands Protection Act (Mass.
Gen. Laws ch. 131, §40);
Wetlands Protection
Regulations (310 CMR § 10.00)

Applicable

This alternative includes work to be
performed within 100 feet of a wetland.
Sets performance standards for dredging,
filling, altering of inland wetlands and
within 100 feet of a wetland. The
requirement also defines wetlands based on
vegetation type and requires that effects on
wetlands be mitigated. Resource areas at
the site covered by the regulations include
banks, bordering vegetated wetlands, land
under bodies of water, land subject to
flooding, riverfront, and estimated habitats
of rare wildlife.

Adverse impacts to regulated wetland buffer
zones will be minimized to the maximum
extent practical.

Action Specific

YES







Federal Regulatory
Requirements

RCRA Subtitle C- Hazardous
Waste Identification and Listing
Regulations; Generator and
Handler Requirements (40 CFR
Parts 260-262 and 264)

Applicable

These rules are used to identify, manage,
and dispose of hazardous waste.

Any media generated as part of monitoring
activities will be tested for hazardous waste
characteristics. If determined to be
hazardous waste, then they will be stored,
transported, and disposed off site in
accordance with these standards.

Iron Horse Park 3rd OU-FS

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LEL-12. ARARS, CRITERIA, ADVISORIES, AND GUIDANCE FOR THE CONTAMINATED SOILS AREA

ARAR, Media and
Authority

Requirements

Status

Triggering Action & Requirement
Synopsis

Action to be taken to attain ARAR

Massachusetts

Regulatory

Requirements

Management Standards for all
Hazardous Waste Facilities
(310 CMR 30.500); Waste
Analysis (310 CMR 30.513);
Management Standards (310
CMR 510)

Applicable

These rules are used to identify, manage,
and dispose of hazardous waste.

Any media generated as part of monitoring
activities will be tested for hazardous waste
characteristics. If determined to be
hazardous waste, then they will be stored,
transported, and disposed off site in
accordance with these standards.

Massachusetts

Regulatory

Requirements

Mass Solid Waste Management
Regulations (310 CMR 19.00)

Applicable for disposal standards; Relevant
and Appropriate for Closure/Post Closure
Standards

These regulations address disposal of non-
hazardous waste and closure, post-closure,
and maintenance of solid waste landfills.

Any media generated as part of monitoring
activities that is determined to be non-
hazardous would be managed and disposed
of in accordance with these standards. This
Alternative will be meet the closure/post
closure standards to prevent human contact
and migration of contaminants to surface
and groundwater.

Massachusetts

Regulatory

Requirements

Massachusetts DEP Landfill
Technical Guidance Manual

To be Considered

Provides a standard reference for and
guidance on landfill design, construction
and QA/QC procedures in accordance with
310 CMR 19.00

This Alternative will be meet the landfill
design standards to prevent human contact
and migration of contaminants to surface
and groundwater.

Massachusetts

Regulatory

Requirements

Massachusetts Air Pollution
Control Regulations (310 CMR
7.09)

Relevant and Appropriate

This alternative includes excavation and/or
earthwork. Prohibits burning or emissions
of dust which causes or contributes to a
condition of air pollution. Standards for dust
are contained in 310 CMR 7.09.

These standards will be complied with
during any excavation of materials at the
Site.











Chemical Specific

NO YES







Federal Regulatory
Requirements

Recommendations of the
Technical Review Workgroup
for Lead for an Approach to
Assessing Risks Associated
with Adult Exposured to Lead
in Soil

To be Considered

EPA guidance for evaluating the risks posed
by lead in soil.

Standard will be met by treating soil to
eliminate lead risk.

Iron Horse Park 3rd OU-FS

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LEL-12. ARARS, CRITERIA, ADVISORIES, AND GUIDANCE FOR THE CONTAMINATED SOILS AREA

ARAR, Media and
Authority

Requirements

Status

Triggering Action & Requirement
Synopsis

Action to be taken to attain ARAR

Federal Regulatory
Requirements

Cancer Slope Factors (CSF).

To Be Considered

Guidance used to compute the individual
incremental cancer risk resulting from
exposure to carcinogenic contaminants in
site media.

Standard will be met by treating soil to
eliminate risks from carcinogenic
contaminants.

Federal Regulatory
Requirements

Reference Dose (RfD)

To Be Considered

Guidance used to characterize human health
risks due to non-carcinogens in site media.

Standard will be met by treating soil to
eliminate risks from non-carcinogenic
contaminants.

Location Specific

YES







Massachusetts

Regulatory

Requirements

Wetlands Protection Act (Mass.
Gen. Laws ch. 131, §40);
Wetlands Protection
Regulations (310 CMR §10.00)

Applicable

This alternative includes work to be
performed within 100 feet of a wetland.
Sets performance standards for dredging,
filling, altering of inland wetlands and
within 100 feet of a wetland. The
requirement also defines wetlands based on
vegetation type and requires that effects on
wetlands be mitigated. Resource areas at
the site covered by the regulations include
banks, bordering vegetated wetlands, land
under bodies of water, land subject to
flooding, riverfront, and estimated habitats
of rare wildlife.

Adverse impacts to regulated wetland buffer
zones will be minimized to the maximum
extent practical.

Action Specific

YES







Federal Regulatory
Requirements

RCRA Subtitle C- Hazardous
Waste Identification and Listing
Regulations; Generator and
Handler Requirements (40 CFR
Parts 260-262 and 264)

Applicable

These rules are used to identify, manage,
and dispose of hazardous waste.

Any media generated as part of treatment
activities will be tested for hazardous waste
characteristics. If determined to be
hazardous waste, then they will be stored,
transported, and disposed off site in
accordance with these standards.

Iron Horse Park 3rd OU-FS

Page 64 of 83

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LE L-12. ARARS, CRITERIA, ADVISORIES, AND GUIDANCE FOR THE CONTAMINATED SOILS AREA

ARAR, Media and
Authority

Requirements

Status

Triggering Action & Requirement
Synopsis

Action to be taken to attain ARAR

Massachusetts

Regulatory

Requirements

Management Standards for all
Hazardous Waste Facilities
(310 CMR 30.500); Waste
Analysis (310 CMR 30.513);
Management Standards (310
CMR 510); Storage and
Treatment in Tanks (310 CMR
30.690)

Applicable

These rules are used to identify, manage,
and dispose of hazardous waste. This
alternative also includes treatment of wastes
in tanks. Specifies requirements for tank
systems used to store or treat hazardous
wastes in tanks. Provides specifications for
design and installation of tank systems.
Requires secondary containment, leak
detection systems, and inspections.
Identifies general operating requirements,
and closure and post-closure care.

Any media generated as part of monitoring
activities will be tested for hazardous waste
characteristics. If determined to be
hazardous waste, then they will be stored,
transported, and disposed off site in
accordance with these standards. Design and
installation requirements will be followed
for any on-site treatment of hazardous
wastes in tanks. Since the classification of
wastes has not been established as
characteristic hazardous waste, the need for
compliance with these regulations will be
determined after sampling and analysis of
each media to be treated or handled.
Specifications will include secondary
containment, if necessary.

Massachusetts

Regulatory

Requirements

Mass Solid Waste Management
Regulations (310 CMR 19.00)

Applicable for disposal standards; Relevant
and Appropriate for Closure/Post Closure
Standards

These regulations address disposal of non-
hazardous waste and closure, post-closure,
and maintenance of solid waste landfills.

Any media generated as part of treatment
activities that is determined to be non-
hazardous would be managed and disposed
of in accordance with these standards. This
Alternative will meet the closure/post
closure standards to prevent human contact
and migration of contaminants to surface
and groundwater.

Massachusetts

Regulatory

Requirements

Massachusetts Air Pollution
Control Regulations (310 CMR
7.09)

Relevant and Appropriate

This alternative includes excavation and/or
earthwork. Prohibits burning or emissions
of dust which causes or contributes to a
condition of air pollution. Standards for dust
are contained in 310 CMR 7.09.

These standards will be complied with
during any excavation of materials at the
Site.











Chemical Specific

NO YES







Iron Horse Park 3rd OU-FS

Page 65 of 83

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LE L-12. ARARS, CRITERIA, ADVISORIES, AND GUIDANCE FOR THE CONTAMINATED SOILS AREA

ARAR, Media and
Authority

Requirements

Status

Triggering Action & Requirement
Synopsis

Action to be taken to attain ARAR

Federal Regulatory
Requirements

Recommendations of the
Technical Review Workgroup
for Lead for an Approach to
Assessing Risks Associated
with Adult Exposured to Lead
in Soil

To be Considered

EPA guidance for evaluating the risks posed
by lead in soil.

Standard will be met by treating soil to
eliminate lead risk.

Federal Regulatory
Requirements

Cancer Slope Factors (CSF).

To Be Considered

Guidance used to compute the individual
incremental cancer risk resulting from
exposure to carcinogenic contaminants in
site media.

Standard will be met by treating soil to
eliminate risks from carcinogenic
contaminants.

Federal Regulatory
Requirements

Reference Dose (RfD)

To Be Considered

Guidance used to characterize human health
risks due to non-carcinogens in site media.

Standard will be met by treating soil to
eliminate risks from non-carcinogenic
contaminants.

Location Specific

YES







Massachusetts

Regulatory

Requirements

Massachusetts Endangered
Species Act (Mass. Gen. Laws
ch. 131, §40); Massachusetts
Endangered Species Act
Regulations, Part III: Alteration
of Significant Habitat (321
CMR §§10.30-10.43)

Applicable

The MESA establishes state's list of
threatened and endangered species and
species of special concern. Habitat of such
species is protected by the regulations
promulgated under the MA Wetlands
Protection Act.

Should this alternative alter this habitat, it
will comply with the substantive
requirements of these regulations.

Action Specific

YES







Federal Regulatory
Requirements

RCRA Subtitle C- Hazardous
Waste Identification and Listing
Regulations; Generator and
Handler Requirements (40 CFR
Parts 260-262 and 264)

Applicable

These rules are used to identify, manage,
and dispose of hazardous waste.

Any media generated as part of treatment
activities will be tested for hazardous waste
characteristics. If determined to be
hazardous waste, then they will be stored,
transported, and disposed off site in
accordance with these standards.

Federal Regulatory
Requirements

RCRA Subtitle D (40 U.S.C. §
6901)

Applicable

These standards govern the disposal of non-
hazardous waste.

This Alternative meets the closure/post
closure standards by treating the waste so
that it no longer poses a risk

Iron Horse Park 3rd OU-FS

Page 66 of 83

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LE L-12. ARARS, CRITERIA, ADVISORIES, AND GUIDANCE FOR THE CONTAMINATED SOILS AREA

ARAR, Media and
Authority

Requirements

Status

Triggering Action & Requirement
Synopsis

Action to be taken to attain ARAR

Massachusetts

Regulatory

Requirements

Management Standards for all
Hazardous Waste Facilities
(310CMR 30.500); Waste
Analysis (310 CMR 30.513);
Management Standards (310
CMR 510); Storage and
Treatment in Tanks (310 CMR
30.690)

Applicable

These rules are used to identify, manage,
and dispose of hazardous waste. This
alternative also includes treatment of wastes
in tanks. Specifies requirements for tank
systems used to store or treat hazardous
wastes in tanks. Provides specifications for
design and installation of tank systems.
Requires secondary containment, leak
detection systems, and inspections.

Identifies general operating requirements,
and closure and post-closure care.

Any media generated as part of monitoring
activities will be tested for hazardous waste
characteristics. If determined to be
hazardous waste, then they will be stored,
transported, and disposed off site in
accordance with these standards. Design and
installation requirements will be followed
for any on-site treatment of hazardous
wastes in tanks. Since the classification of
wastes has not been established as
characteristic hazardous waste, the need for
compliance with these regulations will be
determined after sampling and analysis of
each media to be treated or handled.
Specifications will include secondary
containment, if necessary.

Massachusetts

Regulatory

Requirements

Mass Solid Waste Management
Regulations (310 CMR 19.00)

Applicable for disposal standards; Relevant
and Appropriate for Closure/Post Closure
Standards

These regulations address disposal of non-
hazardous waste and closure, post-closure,
and maintenance of solid waste landfills.

Any media generated as part of treatment
activities that is determined to be non-
hazardous would be managed and disposed
of in accordance with these standards. This
Alternative will meet the closure/post
closure standards to prevent human contact
and migration of contaminants to surface
and groundwater.

Massachusetts

Regulatory

Requirements

Massachusetts Air Pollution
Control Regulations (310 CMR
7.09)

Relevant and Appropriate

This alternative includes excavation and/or
earthwork. Prohibits burning or emissions
of dust which causes or contributes to a
condition of air pollution. Standards for dust
are contained in 310 CMR 7.09.

These standards will be complied with
during any excavation of materials at the
Site.











Chemical Specific

YES







Iron Horse Park 3rd OU-FS

Page 67 of 83

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LE L-12. ARARS, CRITERIA, ADVISORIES, AND GUIDANCE FOR THE CONTAMINATED SOILS AREA

ARAR, Media and
Authority

Requirements

Status

Triggering Action & Requirement
Synopsis

Action to be taken to attain ARAR

Federal Regulatory
Requirements

Recommendations of the
Technical Review Workgroup
for Lead for an Approach to
Assessing Risks Associated
with Adult Exposured to Lead
in Soil

To be Considered

EPA guidance for evaluating the risks posed
by lead in soil.

Standard will be met by removing
contaminated soil and disposing off-site.

Federal Regulatory
Requirements

Cancer Slope Factors (CSF).

To Be Considered

Guidance used to compute the individual
incremental cancer risk resulting from
exposure to carcinogenic contaminants in
site media.

This alternative will meet this standard by
removing potential carcinogenic hazards and
putting it under a cap at another AOC where
it will be properly managed and monitored.

Federal Regulatory
Requirements

Reference Dose (RfD)

To Be Considered

Guidance used to characterize human health
risks due to non-carcinogens in site media.

This alternative will meet this standard by
removing potential non-carcinogenic
hazards and putting it under a cap at another
AOC where it will be properly managed and
monitored.

Location Specific

YES







Massachusetts

Regulatory

Requirements

Wetlands Protection Act (Mass.
Gen. Laws ch. 131, §40);
Wetlands Protection
Regulations (310 CMR §10.00)

Applicable

This alternative includes work to be
performed within 100 feet of a wetland.
Sets performance standards for dredging,
filling, altering of inland wetlands and
within 100 feet of a wetland. The
requirement also defines wetlands based on
vegetation type and requires that effects on
wetlands be mitigated. Resource areas at
the site covered by the regulations include
banks, bordering vegetated wetlands, land
under bodies of water, land subject to
flooding, riverfront, and estimated habitats
of rare wildlife.

Adverse impacts to regulated wetland buffer
zones will be minimized to the maximum
extent practical.

Action Specific

YES







Federal Regulatory
Requirements

RCRA Subtitle C- Hazardous
Waste Identification and Listing
Regulations; Generator and
Handler Requirements (40 CFR
Parts 260-262 and 264)

Applicable

These rules are used to identify, manage,
and dispose of hazardous waste.

Any media generated as part of treatment
activities will be tested for hazardous waste
characteristics. If determined to be
hazardous waste, then they will be stored,
transported, and disposed off site in
accordance with these standards.

Iron Horse Park 3rd OU-FS

Page 68 of 83

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LEL-12. ARARS, CRITERIA, ADVISORIES, AND GUIDANCE FOR THE CONTAMINATED SOILS AREA

ARAR, Media and
Authority

Requirements

Status

Triggering Action & Requirement
Synopsis

Action to be taken to attain ARAR

Massachusetts

Regulatory

Requirements

Management Standards for all
Hazardous Waste Facilities
(310 CMR 30.500); Waste
Analysis (310 CMR 30.513);
Management Standards (310
CMR 510)

Applicable

These rules are used to identify, manage,
and dispose of hazardous waste. Identifies
general operating requirements, and closure
and post-closure care.

Any media generated as part of monitoring
activities will be tested for hazardous waste
characteristics. If determined to be
hazardous waste, then they will be stored,
transported, and disposed off site in
accordance with these standards.

Massachusetts

Regulatory

Requirements

Mass Solid Waste Management
Regulations (310 CMR 19.00)

Applicable for disposal standards; Relevant
and Appropriate for Closure/Post Closure
Standards

These regulations address disposal of non-
hazardous waste and closure, post-closure,
and maintenance of solid waste landfills.

Any media generated as part of treatment
activities that is determined to be non-
hazardous would be managed and disposed
of in accordance with these standards. This
Alternative will meet the closure/post
closure standards to prevent human contact
and migration of contaminants to surface
and groundwater.

Massachusetts

Regulatory

Requirements

Massachusetts Air Pollution
Control Regulations (310 CMR
7.09)

Relevant and Appropriate

This alternative includes excavation and/or
earthwork. Prohibits burning or emissions
of dust which causes or contributes to a
condition of air pollution. Standards for dust
are contained in 310 CMR 7.09.

These standards will be complied with
during any excavation of materials at the
Site.

Iron Horse Park 3rd OU-FS

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TABLE L-13. ARARS, CRITERIA, ADVISORIES, AND GUIDANCE FOR THE ASBESTOS LANDFILL

Alternative

ARAR, Media and
Authority

Requirements

Status

Triggering Action & Requirement
Synopsis

Action to be taken to attain ARAR

No Action













Chemical Specific

YES









Federal Regulatory
Requirements

Clarifying Cleanup Goals and
Identification of New
Assessment Tools for
Evaluating Asbestos at
Superfiind Cleanups

To be Considered

EPA guidance on developing cleanup goals
for asbestos.

The long-term risks from asbestos will not
be addressed since the landfill cap will not
be maintained.



Location Specific

NO









Action Specific

NO







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TABLE L-13. ARARS, CRITERIA, ADVISORIES, AND GUIDANCE FOR THE ASBESTOS LANDFILL

Alternative

ARAR, Media and
Authority

Requirements

Status

Triggering Action & Requirement
Synopsis

Action to be taken to attain ARAR

Limited Action:

Institutional

Controls













Chemical Specific

YES









Federal Regulatory
Requirements

Clarifying Cleanup Goals and
Identification of New
Assessment Tools for
Evaluating Asbestos at
Superfund Cleanups

To be Considered

EPA guidance on developing cleanup goals
for asbestos.

This alternative will meet this standard since
risks from asbestos will be addressed by
maintaining the existing cap and preventing
access to the Site.



Location Specific

YES









Federal Regulatory
Requirements

Clean Water Act (33 U.S.C.
§1251 etseq.); Section
404(b)(1) Guidelines for
Specification of Disposal Sites
for Dredged or Fill Material (40
CFR Part 230, 231 and 33 CFR
Parts 320-323)

40 CFR 230, 231 are Applicable; 33 CFR
320-323 are Relevant and Appropriate

This alternative includes work to be
performed in or near a wetland. Under this
requirement, no activity that adversely
affects a wetland shall be permitted if a
practicable alternative with lesser effects is
available. If activity takes place, impacts
must be minimized to the maximum extent.
Controls discharges of dredged or fill
material to protect aquatic ecosystems.

Given the location of contamination on the
edge of wetlands, this Alternative has been
determined to be the best practical
alternative. Adverse impacts to wetland
resources from cap maintenance, fencing
and well installation activitiy will be
minimized to the maximum extent practical
and mitigation conducted if required.



Federal Regulatory
Requirements

Executive Order 11990;
"Protection of Wetlands" (40
CFR Part 6, Appendix A)

Applicable

This alternative includes work to be
completed in a wetland. Under this
requirement, no activity that adversely
affects a wetland shall be permitted if a
practicable alternative with lesser effects is
available. If activity takes place, impacts
must be minimized to the maximum extent.

Given the location of contamination on the
edge of wetlands, this Alternative has been
determined to be the best practical
alternative. Adverse impacts to wetland
resources from cap maintenance, fencing
and well installation activitiy will be
minimized to the maximum extent practical
and mitigation conducted if required.



Federal Regulatory
Requirements

Fish and Wildlife Coordination
Act(16U.S.C. §661 etseq.);
Fish and wildlife protection (40
CFR §6.302(g))

Applicable

This alternative includes work to be
performed in or near wetland and floodplain
areas. Any modification of a body of water
requires consultation with the U.S. Fish and
Wildlife Service and the appropriate state
wildlife agency to develop measures to
prevent, mitigate or compensate for losses of
fish and wildlife.

EPA will consult with U.S. Fish and
Wildlife Service should Remedial Activities
involve the modification of a body of water.

Iron Horse Park 3rd OU-FS

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TABLE L-13. ARARS, CRITERIA, ADVISORIES, AND GUIDANCE FOR THE ASBESTOS LANDFILL

Alternative

ARAR, Media and
Authority

Requirements

Status

Triggering Action & Requirement
Synopsis

Action to be taken to attain ARAR



Massachusetts

Regulatory

Requirements

Wetlands Protection Act (Mass.
Gen. Laws ch. 131, §40);
Wetlands Protection
Regulations (310 CMR § 10.00)

Applicable

This alternative includes work to be
performed in or near a wetland. Sets
performance standards for dredging, filling,
altering of inland wetlands and within 100
feet of a wetland. The requirement also
defines wetlands based on vegetation type
and requires that effects on wetlands be
mitigated. Resource areas at the site
covered by the regulations include banks,
bordering vegetated wetlands, land under
bodies of water, land subject to flooding,
riverfront, and estimated habitats of rare
wildlife.

If new monitoring wells are needed, and no
practical alternative to locating in wetlands
or regulated buffer zones and/or fencing
needs to be constructed in wetland and/or
regulated buffer zone, then measures will be
taken to minimize impacts.

Iron Horse Park 3rd OU-FS

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TABLE L-13. ARARS, CRITERIA, ADVISORIES, AND GUIDANCE FOR THE ASBESTOS LANDFILL

Alternative

ARAR, Media and
Authority

Requirements

Status

Triggering Action & Requirement
Synopsis

Action to be taken to attain ARAR



Action Specific

YES









Federal Regulatory
Requirements

Clean Air Act - National
Emission Standard for
Asbestos, Subpart M (40 CFR
Part 61.150, 61.151)

Applicable

This alternative includes remedial actions of
areas containing asbestos. Provides
standards for packaging, transport and
disposal of materials that contain asbestos.
Disposal requirements for asbestos disposal
sites are established. Advance EPA
notification of the intended disposal site is
required.

These standards will be complied with for
any asbestos-containing materials
handled/disposed of at the Site.
Furthermore, maintenance and monitoring
of the cap will meet these standards.



Federal Regulatory
Requirements

Toxic Substances Control Act -
Transport and Disposal of
Asbestos Waste (40 CFR 763,
Subpart E, Appendix D)

Applicable

This alternative includes remedial actions of
areas containing asbestos. Provides
standards for transport and disposal of
materials that contain asbestos. Requires
proper wetting and containerization.

Disposal involves the isolation of asbestos
material to prevent fiber release. Landfilling
is recommended. Final cover of an area
containing asbestos waste is at least 30
inches of nonasbestos material to provide a
36-inch final cover. Signs warning
"Breathing Asbestos Dust May Cause Lung
Disease and Cancer" should be displayed.

These standards will be complied with for
any asbestos-containing materials
handled/disposed of at the Site.
Furthermore, maintenance and monitoring
of the cap will meet these standards.



Massachusetts

Regulatory

Requirements

Massachusetts Air Pollution
Control Regulations (310 CMR
7.15)

Relevant and Appropriate

This alternative includes excavation and/or
earthwork of asbestos-contaminated areas.
Provides standards for demolition and
renovation of facilities or facility
components that contain asbestos. Requires
notice to the DEP of work to be done.
Specifies procedures to prevent and control
asbestos emissions. Identifies waste
disposal requirements.

These standards will be complied with as
relevant and appropriate to any disturbance
of asbestos-containing materials
handled/disposed of at the Site.

Iron Horse Park 3rd OU-FS

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TABLE L-14. ARARS, CRITERIA, ADVISORIES, AND GUIDANCE FOR THE ASBESTOS LAGOONS

Alternative

ARAR, Media and
Authority

Requirements

Status

Triggering Action & Requirement
Synopsis

Action to be taken to attain ARAR

No Action













Chemical Specific

YES









Federal Regulatory
Requirements

Clarifying Cleanup Goals and
Identification of New
Assessment Tools for
Evaluating Asbestos at
Superfiind Cleanups

To be Considered

EPA guidance on developing cleanup goals
for asbestos.

This alternative will not meet this standard
since risks from asbestos not addressed.



Federal Regulatory
Requirements

Cancer Slope Factors (CSF).

To Be Considered

Guidance used to compute the individual
incremental cancer risk resulting from
exposure to carcinogenic contaminants in
site media.

This alternative will not meet this standard
since potential carcinogenic hazards caused
by exposure to contaminants not addressed.



Federal Regulatory
Requirements

Reference Dose (RfD)

To Be Considered

Guidance used to characterize human health
risks due to non-carcinogens in site media.

This alternative will not meet this standard
since potential non-carcinogenic hazards
caused by exposure to contaminants not
addressed.



Location Specific

NO









Action Specific

NO





Iron Horse Park 3rd OU-FS

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TABLE L-14. ARARS, CRITERIA, ADVISORIES, AND GUIDANCE FOR THE ASBESTOS LAGOONS

Alternative

ARAR, Media and
Authority

Requirements

Status

Triggering Action & Requirement
Synopsis

Action to be taken to attain ARAR

Limited Action:

Institutional

Controls













Chemical Specific

YES









Federal Regulatory
Requirements

Clarifying Cleanup Goals and
Identification of New
Assessment Tools for
Evaluating Asbestos at
Superfund Cleanups

To be Considered

EPA guidance on developing cleanup goals
for asbestos.

This alternative will partially meet this
standard since risks from asbestos will be
reduced by preventing access to the Site.
However, migration of asbestos from the
Site will not be prevented.



Federal Regulatory
Requirements

Cancer Slope Factors (CSF).

To Be Considered

Guidance used to compute the individual
incremental cancer risk resulting from
exposure to carcinogenic contaminants in
site media.

This alternative will not meet this standard
since potential carcinogenic hazards caused
by migration of contaminants into
groundwater will not be addressed through
institutional controls.



Federal Regulatory
Requirements

Reference Dose (RfD)

To Be Considered

Guidance used to characterize human health
risks due to non-carcinogens in site media.

This alternative will not meet this standard
since potential carcinogenic hazards caused
by migration of contaminants into
groundwater will not be addressed through
institutional controls.



Location Specific

YES









Massachusetts

Regulatory

Requirements

Wetlands Protection Act (Mass.
Gen. Laws ch. 131, §40);
Wetlands Protection
Regulations (310 CMR § 10.00)

Applicable

This alternative includes work to be
performed in or near a wetland. Sets
performance standards for dredging, filling,
altering of inland wetlands and within 100
feet of a wetland. The requirement also
defines wetlands based on vegetation type
and requires that effects on wetlands be
mitigated. Resource areas at the site
covered by the regulations include banks,
bordering vegetated wetlands, land under
bodies of water, land subject to flooding,
riverfront, and estimated habitats of rare
wildlife.

If new monitoring wells are needed, and no
practical alternative to locating in wetlands
or regulated buffer zones, then measures will
be taken to minimize impacts.

Iron Horse Park 3rd OU-FS

Page 75 of 83

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TABLE L-14. ARARS, CRITERIA, ADVISORIES, AND GUIDANCE FOR THE ASBESTOS LAGOONS

Alternative

ARAR, Media and
Authority

Requirements

Status

Triggering Action & Requirement
Synapsis

Action to be taken to attain ARAR



Action Specific

YES









Federal Regulatory
Requirements

Clean Air Act - National
Emission Standard for
Asbestos, Subpart M (40 CFR
Part 61.150, 61.151)

Applicable

This alternative includes remedial actions of
areas containing asbestos. Provides
standards for packaging, transport and
disposal of materials that contain asbestos.
Disposal requirements for asbestos disposal
sites are established. Advance EPA
notification of the intended disposal site is
required.

These standards will not be met because
institutional controls alone won't meet
disposal requirements for leaving asbestos in
the lagoons in place.



Federal Regulatory
Requirements

Toxic Substances Control Act -
Transport and Disposal of
Asbestos Waste (40 CFR 763,
Subpart E, Appendix D)

Applicable

This alternative includes remedial actions of
areas containing asbestos. Provides
standards for transport and disposal of
materials that contain asbestos. Requires
proper wetting and containerization.

Disposal involves the isolation of asbestos
material to prevent fiber release. Landfilling
is recommended. Final cover of an area
containing asbestos waste is at least 30
inches of nonasbestos material to provide a
36-inch final cover. Signs warning
"Breathing Asbestos Dust May Cause Lung
Disease and Cancer" should be displayed.

These standards will not be met because
institutional controls alone won't meet
disposal requirements for leaving asbestos in
the lagoons in place.



Federal Regulatory
Requirements

RCRA Subtitle C- Hazardous
Waste Identification and Listing
Regulations; Generator and
Handler Requirements (40 CFR
Parts 260-262 and 264)

Applicable

These rules are used to identify, manage,
and dispose of hazardous waste.

Any media generated as part of monitoring
activities will be tested for hazardous waste
characteristics. If determined to be
hazardous waste, then they will be stored,
transported, and disposed off site in
accordance with these standards.



Massachusetts

Regulatory

Requirements

Management Standards for all
Hazardous Waste Facilities
(310 CMR 30.500); Waste
Analysis (310 CMR 30.513);
Management Standards (310
CMR 510)

Applicable

These rules are used to identify, manage,
and dispose of hazardous waste.

Any media generated as part of monitoring
activities will be tested for hazardous waste
characteristics. If determined to be
hazardous waste, then they will be stored,
transported, and disposed off site in
accordance with these standards.

Iron Horse Park 3rd OU-FS

Page 76 of 83

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TABLE L-14. ARARS, CRITERIA, ADVISORIES, AND GUIDANCE FOR THE ASBESTOS LAGOONS

Alternative

ARAR, Media and
Authority

Requirements

Status

Triggering Action & Requirement
Synopsis

Action to be taken to attain ARAR



Massachusetts

Regulatory

Requirements

Mass Solid Waste Management
Regulations (310 CMR 19.00)

Applicable for disposal standards; Relevant
and Appropriate for Closure/Post Closure
Standards

These regulations address management and
disposal of non-hazardous waste, closure,
post-closure, and maintenance of solid waste
landfills.

Any media generated as part of monitoring
activities that is determined to be non-
hazardous would be managed and disposed
of in accordance with these standards.
However this Alternative will not meet the
closure/post closure standards because
institutional controls alone will not address
requirements to prevent migration of
contaminants to surface and groundwater.



Massachusetts

Regulatory

Requirements

Massachusetts DEP Landfill
Technical Guidance Manual

To be Considered

Provides a standard reference for and
guidance on landfill design, construction
and QA/QC procedures in accordance with
310 CMR 19.00

These standards will not be met because
institutional controls alone will not address
landfill design requirements.



Massachusetts

Regulatory

Requirements

Massachusetts Air Pollution
Control Regulations (310 CMR
7.15)

Relevant and Appropriate

This alternative includes excavation and/or
earthwork of asbestos-contaminated areas.
Provides standards for demolition and
renovation of facilities or facility
components that contain asbestos. Requires
notice to the DEP of work to be done.
Specifies procedures to prevent and control
asbestos emissions. Identifies waste
disposal requirements.

These standards will not be met because
institutional controls alone won't meet
disposal requirements for leaving asbestos in
the lagoons in place.

Iron Horse Park 3rd OU-FS

Page 77 of 83

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TABLE L-14. ARARS, CRITERIA, ADVISORIES, AND GUIDANCE FOR THE ASBESTOS LAGOONS

Alternative

ARAR, Media and
Authority

Requirements

Status

Triggering Action & Requirement
Synopsis

Action to be taken to attain ARAR

Excavate and
Place Under
Another On-Site
AOC Cap













Chemical Specific

YES









Federal Regulatory
Requirements

Clarifying Cleanup Goals and
Identification of New
Assessment Tools for
Evaluating Asbestos at
Superfund Cleanups

To be Considered

EPA guidance on developing cleanup goals
for asbestos.

This alternative will meet this standard by
removing asbestos and putting it under a cap
at another AOC where it will be properly
managed and monitored.



Federal Regulatory
Requirements

Cancer Slope Factors (CSF).

To Be Considered

Guidance used to compute the individual
incremental cancer risk resulting from
exposure to carcinogenic contaminants in
site media.

This alternative will meet this standard by
removing potential carcinogenic hazards and
putting it under a cap at another AOC where
it will be properly managed and monitored.



Federal Regulatory
Requirements

Reference Dose (RfD)

To Be Considered

Guidance used to characterize human health
risks due to non-carcinogens in site media.

This alternative will meet this standard by
removing potential non-carcinogenic
hazards and putting it under a cap at another
AOC where it will be properly managed and
monitored.



Location Specific

YES









Massachusetts

Regulatory

Requirements

Wetlands Protection Act (Mass.
Gen. Laws ch. 131, §40);
Wetlands Protection
Regulations (310 CMR § 10.00)

Applicable

This alternative includes work to be
performed within 100 feet of a defined
wetland. Sets performance standards for
dredging, filling, altering of inland wetlands
and within 100 feet of a wetland. The
requirement also defines wetlands based on
vegetation type and requires that effects on
wetlands be mitigated. Resource areas at
the site covered by the regulations include
banks, bordering vegetated wetlands, land
under bodies of water, land subject to
flooding, riverfront, and estimated habitats
of rare wildlife.

If excavation activities occur within
regulated buffer zones, then measures will
be taken to minimize impacts.

Iron Horse Park 3rd OU-FS

Page 78 of 83

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TABLE L-14. ARARS, CRITERIA, ADVISORIES, AND GUIDANCE FOR THE ASBESTOS LAGOONS

Alternative

ARAR, Media and
Authority

Requirements

Status

Triggering Action & Requirement
Synopsis

Action to be taken to attain ARAR



Action Specific

YES









Federal Regulatory
Requirements

Clean Air Act - National
Emission Standard for
Asbestos, Subpart M (40 CFR
Part 61.150, 61.151)

Applicable

This alternative includes remedial actions of
areas containing asbestos. Provides
standards for packaging, transport and
disposal of materials that contain asbestos.
Disposal requirements for asbestos disposal
sites are_established. Advance EPA
notification of the intended disposal site is
required.

Excavation of asbestos contaminated
material will be conducted in compliance
with these standards.



Federal Regulatory
Requirements

Toxic Substances Control Act -
Transport and Disposal of
Asbestos Waste (40 CFR 763,
Subpart E, Appendix D)

Applicable

This alternative includes remedial actions of
areas containing asbestos. Provides
standards for transport and disposal of
materials that contain asbestos. Requires
proper wetting and containerization.

Disposal involves the isolation of asbestos
material to prevent fiber release. Landfilling
is recommended. Final cover of an area
containing asbestos waste is at least 30
inches of nonasbestos material to provide a
36-inch final cover. Signs warning
"Breathing Asbestos Dust May Cause Lung
Disease and Cancer" should be displayed.

Excavation of asbestos contaminated
material will be conducted in compliance
with these standards.



Federal Regulatory
Requirements

RCRA Subtitle C- Hazardous
Waste Identification and Listing
Regulations; Generator and
Handler Requirements (40 CFR
Parts 260-262 and 264)

Applicable

These rules are used to identify, manage,
and dispose of hazardous waste.

Any media generated as part of excavation
activities will be tested for hazardous waste
characteristics. If determined to be
hazardous waste, then they will be stored,
transported, and disposed off site in
accordance with these standards.



Massachusetts

Regulatory

Requirements

Management Standards for all
Hazardous Waste Facilities
(310 CMR 30.500); Waste
Analysis (310 CMR 30.513);
Management Standards (310
CMR 510)

Applicable

These rules are used to identify, manage,
and dispose of hazardous waste.

Any media generated as part of excavation
activities will be tested for hazardous waste
characteristics. If determined to be
hazardous waste, then they will be stored,
transported, and disposed off site in
accordance with these standards.

Iron Horse Park 3rd OU-FS

Page 79 of 83

-------
TABLE L-14. ARARS, CRITERIA, ADVISORIES, AND GUIDANCE FOR THE ASBESTOS LAGOONS

Alternative

ARAR, Media and
Authority

Requirements

Status

Triggering Action & Requirement
Synopsis

Action to be taken to attain ARAR



Massachusetts

Regulatory

Requirements

Massachusetts Air Pollution
Control Regulations (310 CMR
7.15)

Relevant and Appropriate

This alternative includes excavation and/or
earthwork of asbestos-contaminated areas.
Provides standards for demolition and
renovation of facilities or facility
components that contain asbestos. Requires
notice to the DEP of work to be done.
Specifies procedures to prevent and control
asbestos emissions. Identifies waste
disposal requirements.

These standards will be complied with as
relevant and appropriate to any disturbance
of asbestos-containing materials handled at
the Site.



Massachusetts

Regulatory

Requirements

Mass Solid Waste Management
Regulations (310 CMR 19.00)

Applicable for disposal standards; Relevant
and Appropriate for Closure/Post Closure
Standards

These regulations address management and
disposal of non-hazardous waste, closure,
post-closure, and maintenance of solid waste
landfills.

Any media generated as part of excavation
activities that is determined to be non-
hazardous would be managed and disposed
of in accordance with these standards. This
Alternative will meet the closure/post
closure standards by removing all non-
hazardous waste from the Site.

Iron Horse Park 3rd OU-FS

Page 80 of 83

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TABLE L-14. ARARS, CRITERIA, ADVISORIES, AND GUIDANCE FOR THE ASBESTOS LAGOONS

Alternative

ARAR, Media and
Authority

Requirements

Status

Triggering Action & Requirement
Synopsis

Action to be taken to attain ARAR

Cap Waste













Chemical Specific

YES









Federal Regulatory
Requirements

Clarifying Cleanup Goals and
Identification of New
Assessment Tools for
Evaluating Asbestos at
Superfund Cleanups

To be Considered

EPA guidance on developing cleanup goals
for asbestos.

This alternative will meet this standard by
capping the asbestos and maintaining and
monitoring the cap



Federal Regulatory
Requirements

Cancer Slope Factors (CSF).

To Be Considered

Guidance used to compute the individual
incremental cancer risk resulting from
exposure to carcinogenic contaminants in
site media.

This alternative will meet this standard by
capping potential carcinogenic hazards and
maintaining and monitoring the cap.



Federal Regulatory
Requirements

Reference Dose (RfD)

To Be Considered

Guidance used to characterize human health
risks due to non-carcinogens in site media.

This alternative will meet this standard by
capping potential non-carcinogenic hazards
and maintaining and monitoring the cap.



Location Specific

YES









Massachusetts

Regulatory

Requirements

Wetlands Protection Act (Mass.
Gen. Laws ch. 131, §40);
Wetlands Protection
Regulations (310 CMR § 10.00)

Applicable

This alternative includes work to be
performed within 100 feet of a defined
wetland. Sets performance standards for
dredging, filling, altering of inland wetlands
and within 100 feet of a wetland. The
requirement also defines wetlands based on
vegetation type and requires that effects on
wetlands be mitigated. Resource areas at
the site covered by the regulations include
banks, bordering vegetated wetlands, land
under bodies of water, land subject to
flooding, riverfront, and estimated habitats
of rare wildlife.

If excavation and capping activities occur
within regulated buffer zones, then measures
will be taken to minimize impacts.

Iron Horse Park 3rd OU-FS

Page 81 of 83

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TABLE L-14. ARARS, CRITERIA, ADVISORIES, AND GUIDANCE FOR THE ASBESTOS LAGOONS

Alternative

ARAR, Media and
Authority

Requirements

Status

Triggering Action & Requirement
Synopsis

Action to be taken to attain ARAR



Action Specific

YES









Federal Regulatory
Requirements

Clean Air Act - National
Emission Standard for
Asbestos, Subpart M (40 CFR
Part 61.150, 61.151)

Applicable

This alternative includes remedial actions of
areas containing asbestos. Provides
standards for packaging, transport and
disposal of materials that contain asbestos.
Disposal requirements for asbestos disposal
sites are established. Advance EPA
notification of the intended disposal site is
required.

These standards for managing asbestos and
capping the area will be met.



Federal Regulatory
Requirements

Toxic Substances Control Act -
Transport and Disposal of
Asbestos Waste (40 CFR 763,
Subpart E, Appendix D)

Applicable

This alternative includes remedial actions of
areas containing asbestos. Provides
standards for transport and disposal of
materials that contain asbestos. Requires
proper wetting and containerization.

Disposal involves the isolation of asbestos
material to prevent fiber release. Landfilling
is recommended. Final cover of an area
containing asbestos waste is at least 30
inches of nonasbestos material to provide a
36-inch final cover. Signs warning
"Breathing Asbestos Dust May Cause Lung
Disease and Cancer" should be displayed.

These standards for managing asbestos and
capping the area will be met.



Federal Regulatory
Requirements

RCRA Subtitle C- Hazardous
Waste Identification and Listing
Regulations; Generator and
Handler Requirements (40 CFR
Parts 260-262 and 264)

Applicable

These rules are used to identify, manage,
and dispose of hazardous waste.

Any media generated as part of monitoring
activities will be tested for hazardous waste
characteristics. If determined to be
hazardous waste, then they will be stored,
transported, and disposed off site in
accordance with these standards.



Massachusetts

Regulatory

Requirements

Management Standards for all
Hazardous Waste Facilities
(310 CMR 30.500), Waste
Analysis (310 CMR 30.513);
Management Standards (310
CMR 510)

Applicable

These rules are used to identify, manage,
and dispose of hazardous waste.

Any media generated as part of monitoring
activities will be tested for hazardous waste
characteristics. If determined to be
hazardous waste, then they will be stored,
transported, and disposed off site in
accordance with these standards.

Iron Horse Park 3rd OU-FS

Page 82 of 83

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TABLE L-14. ARARS, CRITERIA, ADVISORIES, AND GUIDANCE FOR THE ASBESTOS LAGOONS

Alternative

ARAR, Media and
Authority

Requirements

Status

Triggering Action & Requirement
Synopsis

Action to be taken to attain ARAR



Massachusetts

Regulatory

Requirements

Mass Solid Waste Management
Regulations (310 CMR 19.00)

Applicable for disposal standards; Relevant
and Appropriate for Closure/Post Closure
Standards

These regulations address management and
disposal of non-hazardous waste, closure,
post-closure, and maintenance of solid waste
landfills.

Any media generated as part of monitoring
activities that is determined to be non-
hazardous would be managed and disposed
off site in accordance with these standards.
This Alternative will be meet the
closure/post closure standards to prevent
human contact and migration of
contaminants to surface and groundwater.



Massachusetts

Regulatory

Requirements

Massachusetts DEP Landfill
Technical Guidance Manual

To be Considered

Provides a standard reference for and
guidance on landfill design, construction
and QA/QC procedures in accordance with
310 CMR 19.00

This Alternative will be meet the landfill
design standards to prevent human contact
and migration of contaminants to surface
and groundwater.



Massachusetts

Regulatory

Requirements

Massachusetts Air Pollution
Control Regulations (310 CMR
7.15)

Relevant and Appropriate

This alternative includes excavation and/or
earthwork of asbestos-contaminated areas.
Provides standards for demolition and
renovation of facilities or facility
components that contain asbestos. Requires
notice to the DEP of work to be done.
Specifies procedures to prevent and control
asbestos emissions. Identifies waste
disposal requirements.

These standards will be complied with as
relevant and appropriate to any disturbance
of asbestos-containing materials handled at
the Site.

Iron Horse Park 3rd OU-FS

Page 83 of 83

-------
APPENDIX D: Glossary of Terms and Acronyms

-------


LIST OF ACRONYMS AND ABBREVIATIONS

Acronym/



Abbreviation

Definition

ACO

Administrative Consent Order

AOC

Administrative Order on Consent

ARAR

Applicable or Relevant and Appropriate Requirement

AT SDR

Agency for Toxic Substances and Disease Registry

AWQC

Ambient Water Quality Criteria

BRA

Baseline Risk Assessment

BTEX

Benzene, toluene, ethylbenzene and xylene

CAA

Clean Air Act

CD

Consent Decree

CERCLA

Comprehensive Environmental Response, Compensation, and Liability Act

CERCLIS

CERCLA Information System Database

CFR

Code of Federal Regulations

COC

Contaminant of Concern

COPC

Contaminants of Potential Concern

CWA

Clean Water Act

EO

Executive Order

ERA

Environmental Risk Assessment

ESD

Explanation of Significant Difference

EPA

United States Environmental Protection Agency

EPC

Exposure Point Concentration

FS

Feasibility Study

HQ

Hazard Quotient

HRS

Hazard Ranking System

IEUBK

Integrated Exposure and Uptake Biokinetic model

LNAPL

Light Non-Aqueous Phase Liquid

LOAEL

Lowest Observed Adverse Effects Level

LTM

Long Term Monitoring

MADEP

Massachusetts Department of Environmental Protection

MCL

Maximum Contaminant Level

MCP

Massachusetts Contingency Plan

M&E

Metcalf & Eddy, Inc.

MNA

Monitored Natural Attenuation

NAPL

Non-Aqueous Phase Liquid

NCP

National Contingency Plan

ND

Not Detected

NHESP

Natural Heritage and Endangered Species Act

NOAEL

No Observed Adverse Effects Level

NOED

No Observed Effects Dose

NPL

National Priorities List

O&M

Operation and Maintenance

OSHA

Occupational Safety and Health Administration

OSWER

EPA Office of Solid Waste and Emergency Response

OU

Operable Unit

PAH

Polycyclic aromatic hydrocarbon

PCB

Polychlorinated biphenyl

PPb

parts per billion

ppm

parts per million

PRG

Preliminary Remediation Goal

PRP

Potentially Responsible Party

RA

Remedial Action

RCRA

Resource Conservation and Recovery Act

RD

Remedial Design

RfD

Reference Dose

RI

Remedial Investigation

-------
RI/FS

Remedial Investigation/Feasibility Study

RME

Reasonable Maximum Exposure

ROD

Record of Decision

RPM

Remedial Project Manager

SDWA

Safe Drinking Water Act

SC

Source Control

SVOC

Semi-Volatile Organic Compound

TBCs

To Be Considered

TCE

Trichloroethene

TEL

Threshold Effects Level

TRV

Toxicity Reference Value

TSCA

Toxic Substances Control Act

UCL

Upper Confidence Limit

VOC

Volatile Organic Compound

-------
APPENDIX E:

Administrative Record Index and Guidance Documents

-------
IRON HORSE PARK
NPL Site Administrative Record
Record of Decision (ROD)
Operable Unit 3

Index

Record of Decision Signed
September 2004

Administrative Record Released
February 2006

Prepared by
EPA New England
Office of Site Remediation & Restoration

-------
Introduction to the Collection

This is the Administrative Record file for the Iron Horse Park Superfund site, North
Billerica, MA, OU 3, Rest of Site, Record of Decision (ROD) Proposed Plan, released June
2004. The file contains site-specific documents and a list of guidance documents used by EPA
staff in selecting a response action at the site.

This file includes, by reference, the administrative record file for the Iron Horse Park, OU
1 Record of Decision, issued September 15, 1988 and the administrative record file for the
Iron Horse Park, OU 2 Record of Decision, issued June 27, 1991.

PLEASE NOTE: The best available copies were used to create this collection.

The administrative record file is available for review at:

Billerica Public Library
15 Concord Road
Billerica, MA 01821
978-671-0948 (phone)
www.billericalibrarv.org

EPA New England Superfund Records & Information Center

1 Congress Street, Suite 1100 (HSC)

Boston, MA 02114 (by appointment)

617-918-1440 (phone)

617-918-1223 (fax)

www.epa.goviregionOl/superfund/resource/records.htm

Questions about this administrative record file should be directed to the EPA New England
site manager.

An administrative record file is reguired by the Comprehensive Environmental Response,
Compensation, and Liability Act (CERCLA), as amended by the Superfund Amendments and
Reauthorization Act (SARA).

-------
IRON HORSE PARK
REST OF SITE
ADMINISTRATIVE RECORD FILE
IRON HORSE ROD PROPOSED PLAN

3. REMEDIAL INVESTIGATION (RI)

1. LETTER: EPA'S COMMENTS ON DRAFT HEALTH ASSESSMENT FOR IRON HORSE PARK
TO: MARILYN DISIRIO, AGENCY FOR TOXIC SUBSTANCES AND DISEASE REGISTRY
AUTHOR: JOHN GALLAGHER, US EPA REGION 1
DOC ID: 209745 01/20/1989 3 PAGES

2.	MEMO: REVIEW OF HEALTH ASSESSMENT FOR IRON HORSE PARK AS AMENDED APRIL 4, 1990

TO: LOUISE A HOUSE, US PUBLIC HEALTH SERVICE/ATSDR
AUTHOR: DON MCELROY, US EPA
DOC ID: 209746 08/20/1990 5 PAGES

3.	LETTER: REVIEW OF PROPOSAL FOR TRENCH EXCAVATION AT BNZ MATERIALS INC.

TO: ROGER P THIBAULT, GZA GEOENVIRONMENTAL INC
AUTHOR: DALE YOUNG, MA DEPT OF ENVIRONMENTAL PROTECTION
DOC ID: 209731 11/06/1990 2 PAGES

4.	LETTER: SCOPING MEETING SUMMARY, IRON HORSE REMEDIAL INVESTIGATION/FEASIBILITY STUDY

(RI/FS)

TO: DON MCELROY, US EPA

AUTHOR: DEBORAH M SIMONE, METCALF & EDDY INC
DOC ID: 209733 10/29/1992 7 PAGES

5.	MEMO: IRON HORSE PARK, OU3 REMEDIAL INVESTIGATION (RI) - SCOPE

TO: NANCY BARMAKIAN, US EPA REGION 1
AUTHOR: DON MCELROY, US EPA
DOC ID: 209734 11/16/1992 2 PAGES

6.	LETTER: COMMENTS ON "DRAFT WORK PLAN FOR REMEDIAL INVESTIGATION (RI)"

TO: DON MCELROY, US EPA

AUTHOR: HELEN WALDORF, MA DEPT OF ENVIRONMENTAL PROTECTION
DOC ID: 209739 01/05/1993 5 PAGES

7.	MEMO: COMMENTS ON IRON HORSE DRAFT WORKPLAN FOR OU3

TO: DON MCELROY, US EPA

AUTHOR: MARGARET MCDONOUGH, US EPA REGION 1
DOC ID: 209740 01/07/1993 5 PAGES

8.	MEMO: COMMENTS ON DRAFT WORK PLAN FOR REMEDIAL INVESTIGATION (RI)

TO: DON MCELROY, US EPA

AUTHOR: PATTI LYNNE TYLER, US EPA REGION 1
DOC ID: 209741 01/10/1993 6 PAGES

9.	REPORT: SCOPE OF WORK SUMMARY FOR THE FIELD ACTIVITIES FOR THE REMEDIAL INVESTIGATION

(RI)

AUTHOR: METCALF & EDDY INC

DOC ID: 209735 02/01/1993 24 PAGES

10.

REPORT
AUTHOR
DOC ID

FINAL WORK PLAN FOR REMEDIAL INVESTIGATION (RI)

METCALF R EDDY INC

209742 06/01/1993 131 PAGES

-------
IRON HORSE PARK
REST OF SITE
ADMINISTRATIVE RECORD FILE
IRON HORSE ROD PROPOSED PLAN

3.REMEDIAL INVESTIGATION (RI) (cont)

11. REPORT: HYDROGEOLOGICAL ASSESSMENT REPORT
TO: US EPA REGION 1
AUTHOR: METCALF K EDDY
DOC ID: 65002 02/01/1994 226 PAGES

12. MEMO: REVIEW OF THE "BENTHIC INVERTEBRATE RECONNAISSANCE SURVEY, IRON HORSE PARK,
BILLERICA, MA"

TO: DON MCELROY, US EPA

AUTHOR: PATTI LYNNE TYLER, US EPA REGION 1
DOC ID: 209747 04/01/1994 2 PAGES

13.

REPORT
AUTHOR
DOC ID

FINAL WORK PLAN AMENDMENT FOR REMEDIAL INVESTIGATION (RI)

METCALF & EDDY INC

209743 09/01/1994 106 PAGES

14. LETTER: COMMENTS ON "DRAFT WORK PLAN AMENDMENT FOR REMEDIAL INVESTIGATION (RI)"
TO: DEBORAH M SIMONE, METCALF & EDDY INC
AUTHOR: DON MCELROY, US EPA
DOC ID: 209744 09/16/1994 6PAGES

15. MEMO: COMMENTS ON REMEDIAL INVESTIGATION (RI) DRAFT REPORT
TO: DON MCELROY, US EPA

AUTHOR: PATTI LYNNE TYLER, US EPA REGION 1
DOC ID: 209736 10/08/1996 10 PAGES

16. LETTER: REVIEW OF "REMEDIAL INVESTIGATION (RI) DRAFT REPORT" FOR THE THIRD OPERABLE
UNIT

TO: DON MCELROY, US EPA

AUTHOR: JAY NAPARSTEK, MA DEPT OF ENVIRONMENTAL PROTECTION
DOC ID: 209732 12/10/1996 4 PAGES

17. MEMO: COMMENTS ON REMEDIAL INVESTIGATION (RI) DRAFT REPORT
TO: DON MCELROY, US EPA

AUTHOR: MARGARET MCDONOUGH, US EPA REGION 1
DOC ID: 209737 02/28/1997 2 PAGES

18. LETTER: DRAFT REMEDIAL INVESTIGATION (RI) COMMENTS
TO: DEBORAH M SIMONE, METCALF & EDDY INC
AUTHOR: DON MCELROY, US EPA
DOC ID: 209738 07/14/1997 53 PAGES

19. MEMO: SURFACE SOIL HOT SPOTS AT IRON HORSE PARK, MEMO TO FILE
AUTHOR: JOHN YOUNG, METCALF k EDDY INC
DOC ID: 209748 08/15/1997 5 PAGES

20. REPORT: REMEDIAL INVESTIGATION (RI) FINAL REPORT, VOLUME 1 OF 5, TEXT
AUTHOR: METCALF & EDDY
US EPA REGION 1

DOC ID: 204924 09/01/1997 489 PAGES

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IRON HORSE PARK
REST OF SITE
ADMINISTRATIVE RECORD FILE
IRON HORSE ROD PROPOSED PLAN

3.REMEDIAL	INVESTIGATION (RI) (cont)

21.	REPORT: REMEDIAL INVESTIGATION (RI) FINAL REPORT, VOLUME 2 OF 5, TABLES
AUTHOR: METCALF 8 6 EDDY

US EPA REGION 1

DOC ID: 204925 09/01/1997 410 PAGES

22.	REPORT: REMEDIAL INVESTIGATION (RI) FINAL REPORT, VOLUME 3 OF 5, FIGURES
AUTHOR: METCALF % EDDY

US EPA REGION 1

DOC ID: 204926 09/01/1997 95 PAGES

23.	REPORT: REMEDIAL INVESTIGATION (RI) FINAL REPORT, VOLUME 4 OF 5, APPENDICES A-E
AUTHOR: METCALF K EDDY

US EPA REGION 1

DOC ID: 204927 09/01/1997 702 PAGES

24.	REPORT: REMEDIAL INVESTIGATION (RI) FINAL REPORT, VOLUME 5 OF 5, APPENDICES F-I
AUTHOR: METCALF & EDDY

US EPA REGION 1

DOC ID: 204928 09/01/1997 1798 PAGES

25.	MEMO: COMMENTS ON THE BASELINE HUMAN HEALTH RISK ADDENDUM, OLD B&M OIL/SLUDGE RECYCLING
AREA

TO: DON MCELROY, US EPA

AUTHOR: MARGARET MCDONOUGH, US EPA REGION 1
DOC ID: 65003 12/04/2001 2 PAGES

4.	FEASIBILITY STUDY (FS)

1.	LETTER: TRANSMITTAL OF DRAFT FEASIBILITY STUDY WORK PLAN

TO: JANET WALDRON, MA DEPT OF ENVIRONMENTAL QUALITY ENGINEERING
AUTHOR: DON MCELROY, US EPA
DOC ID: 64996 05/19/1998 1 PAGE

2.	LETTER: MADEP COMMENTS ON THE FEASIBILITY STUDY DRAFT REPORT
TO: DON MCELROY, US EPA

AUTHOR: JAY NAPARSTEK, MA DEPT OF ENVIRONMENTAL PROTECTION
DOC ID: 65004 05/08/2000 11 PAGES

3.	MEMO: COMMENTS ON THE DRAFT FEASIBILITY STUDY
TO: DON MCELROY, US EPA

AUTHOR: MARGARET MCDONOUGH, US EPA REGION 1
DOC ID: 65005 08/01/2000 2 PAGES

4.	MEMO: REVIEW OF THE DRAFT FEASLBILITY STUDY REPORT
TO: DON MCELROY, US EPA

AUTHOR: PATTI LYNNE TYLER, US EPA REGION 1
DOC ID: 65006 08/16/2000 6 PAGES

5.	MEMO: REVIEW OF IRON HORSE PARK SAMPLING DATA
TO: DON MCELROY, US EPA

AUTHOR: DARRYL LUCE, US EPA REGION 1
DOC ID: 64998 03/21/2001 2 PAGES

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IRON HORSE PARK
REST OF SITE
ADMINISTRATIVE RECORD FILE
IRON HORSE ROD PROPOSED PLAN

4.FEASIBILITY STUDY (FS) (cont)

6.	MEMO: CONFERENCE CALL ON ISSUES WITH RESPECT TO A POTENTIAL GROUND WATER REMEDY
TO: DON MCELROY, US EPA

AUTHOR: DARRYL LUCE, US EPA REGION 1
DOC ID: 64999 05/08/2001 1 PAGE

7.	MEMO: REVIEW OF GROUND WATER MODEL AND INFORMATION RELEVANT TO A GROUND WATER REMEDY
TO: DON MCELROY, US EPA

AUTHOR: DARRYL LUCE, US EPA REGION 1
DOC ID: 65000 06/06/2001 1 PAGE

8.	LIST: RESPONSE TO REVIEW COMMENTS ON THE DRAFT FEASIBILITY STUDY REPORT
AUTHOR: METCALF & EDDY INC

DOC ID: 65007 09/06/2001 28 PAGES

9.	LETTER: MADEP COMMENTS ON METCALF & EDDY RESPONSE TO REVIEW COMMENTS ON THE DRAFT
FEASIBILITY STUDY REPORT

TO: DON MCELROY, US EPA

AUTHOR: JANET WALDRON, MA DEPT OF ENVIRONMENTAL QUALITY ENGINEERING
DOC ID: 65008 10/31/2001 3 PAGES

10.	MEMO: MADEP COMMENTS ON SUPPLEMENTAL ANALYSIS OF ECOLOGICAL RISK IN EAST & WEST
MIDDLESEX CANAL

TO: JANET WALDRON, MA DEPT OF ENVIRONMENTAL QUALITY ENGINEERING
AUTHOR: NANCY BETTINGER, MA DEPT OF ENVIRONMENTAL PROTECTION
DOC ID: 65009 12/03/2001 8 PAGES

11.	LETTER: MADEP REVIEW OF "COMPARATIVE ANALYSIS OF THE REMEDIAL TECHNOLOGIES BY AOC"
TO: DON MCELROY, US EPA

AUTHOR: JANET WALDRON, MA DEPT OF ENVIRONMENTAL QUALITY ENGINEERING
DOC ID: 65010 03/11/2002 4 PAGES

12.	MEMO: MEETING MINUTES ON COMMENTS TO SECTION 7 OF THE DRAFT FEASIBILITY STUDY REPORT
TO: D ROBERTS, ROBERTS ENVIRONMENTAL

D SILVERMAN, METCALF & EDDY INC
DEBORAH M SIMONE, METCALF & EDDY INC
DON MCELROY, US EPA

JANET WALDRON, MA DEPT OF ENVIRONMENTAL QUALITY ENGINEERING
S CZARNIECKI, METCALF & EDDY INC
AUTHOR: LAURIE OSOWSKI, METCALF & EDDY INC
DOC ID: 65011 10/29/2002 4PAGES

13.	LETTER: RESPONSE TO REVIEW COMMENTS ON THE DRAFT FEASIBILITY STUDY REPORT
TO: DON MCELROY, US EPA

AUTHOR: JANET WALDRON, MA DEPT OF ENVIRONMENTAL QUALITY ENGINEERING
DOC ID: 65012 11/07/2002 2 PAGES

14.

MEMO: ATTACHMENT TO MA DEP MEMO ON OU #3 ISSUES
AUTHOR: MA DEPT OF ENVIRONMENTAL PROTECTION
DOC ID: 65013 12/10/2002 4 PAGES

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IRON HORSE PARK
REST OF SITE
ADMINISTRATIVE RECORD FILE
IRON HORSE ROD PROPOSED PLAN

4.FEASIBILITY STUDY (FS) (cont)

15. REPORT: FEASIBILITY STUDY (FS) FINAL REPORT, VOLUME 1 OF 3, TEXT
AUTHOR: METCALF &, EDDY
US EPA REGION 1

DOC ID: 204929 03/01/2003 769 PAGES

16.	REPORT: FEASIBILITY STUDY (FS) FINAL REPORT, VOLUME 2 OF 3, TABLES AND FIGURES
AUTHOR: METCALF &, EDDY

US EPA REGION 1

DOC ID: 204930 03/01/2003 499 PAGES

17.	REPORT: FEASIBILITY STUDY (FS) FINAL REPORT, VOLUME 3 OF 3, APPENDICES
AUTHOR: METCALF 8 6 EDDY

US EPA REGION 1

DOC ID: 204931 03/01/2003 1087 PAGES

18. MISC: OU #3 ISSUES

AUTHOR: MA DEP/BUREAU OF WASTE SITE CLEANUP WESTERN REG OFFICE
DOC ID: 64995 04/01/2003 5 PAGES

19. LETTER: MADEP COMMENTS ON THE FINAL FEASIBILITY STUDY
TO: DON MCELROY, US EPA

AUTHOR: JANET WALDRON, MA DEPT OF ENVIRONMENTAL QUALITY ENGINEERING
DOC ID: 64997 04/04/2003 2 PAGES

20. MEMO: CLEANUP GOALS AT IRON HORSE PARK
TO: DON MCELROY, US EPA

AUTHOR: MARGARET MCDONOUGH, US EPA REGION 1
DOC ID: 65017 04/25/2003 1 PAGE

21. MEMO: REVIEW OF ECO PRGS

TO: CHESTER L JANOWSKI, US EPA REGION 1
DON MCELROY, US EPA

AUTHOR: RICHARD SUGATT, US EPA REGION 1
DOC ID: 65016 04/25/2003 1 PAGE

22. LETTER: REVIEW OF THE FEASIBILITY STUDY FINAL REPORT
TO: DON MCELROY, US EPA

AUTHOR: JANET WALDRON, MA DEPT OF ENVIRONMENTAL QUALITY ENGINEERING
DOC ID: 65019 03/04/2004 2 PAGES

23. LETTER:	REVIEW OF THE DRAFT PROPOSED PLAN
TO: DON MCELROY, US EPA

AUTHOR:	JANET WALDRON, MA DEPT OF ENVIRONMENTAL QUALITY ENGINEERING

DOC ID:	65015 04/22/2004 3 PAGES

24.

FACT SHEET: PROPOSED PLAN, IRON HORSE PARK SUPERFUND SITE

AUTHOR: US EPA REGION 1

DOC ID: 209725 06/01/2004 25 PAGES

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IRON HORSE PARK
REST OF SITE
ADMINISTRATIVE RECORD FILE
IRON HORSE ROD PROPOSED PLAN

9. STATE COORDINATION

1.	MAP: PRELIMINARY ASSESSMENT MAP: 1, H, & 1/4 MILE RADII
AUTHOR: MA DEPT OF ENVIRONMENTAL PROTECTION

DOC ID: 209749 04/23/1998 I PAGE

2.	MEMO: GROUNDWATER USE AND VALUE DETERMINATION, IRON HORSE PARK
AUTHOR: MA DEPT OF ENVIRONMENTAL PROTECTION

DOC ID: 209750 06/01/1998 3 PAGES

3.	LIST: MADEP ITEMS THAT NEED TO BE ADDRESSES FOR OU 3
AUTHOR: MA DEPT OF ENVIRONMENTAL PROTECTION

DOC ID: 65021 09/04/2002 6 PAGES

16.	NATURAL RESOURCE TRUSTEE

1.	LETTER: REVIEW OF THE IRON HORSE PARK 3RD OPERABLE UNIT SCOPE OF SERVICES FOR SURFACE
WATER AND SEDIMENT SAMPLING

TO: DON MCELROY, US EPA

AUTHOR: STEVEN E MIERZYKOWSKI, US DOI/US FISH k WILDLIFE SERVICE
DOC ID: 209751 06/03/1992 3 PAGES

2.	LETTER: REVIEW OF THE DRAFT REMEDIAL INVESTIGATION (RI) WORKPLAN FOR IRON HORSE PARK,
OPERABLE UNIT 3

TO: DON MCELROY, US EPA

AUTHOR: KENNETH FINKLESTEIN, NATIONAL OCEANIC AND ATMOSPHERIC ADMINISTRATION
DOC ID: 209752 02/24/1993 1 PAGE

17.	SITE MANAGEMENT RECORDS

1.	PHOTOGRAPH: SITE ANALYSIS AND WETLANDS ASSESSMENT: IRON HORSE PARK, BILLERICA,

MASSACHUSETTS, VOLUME 2, EPIC BOOK
TO: US EPA REGION 1

AUTHOR: US EPA - ENVIRONMENTAL PHOTOGRAPHIC INTERPRETATION CTR (EPIC)

DOC ID: 209724 03/01/1987 1 PAGE

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GUIDANCE DOCUMENTS

EPA guidance documents may be reviewed at the EPA Region I Superfund Records Center in
Boston, Massachusetts.

TITIiE

INTERIM FINAL GUIDANCE FOR CONDUCTING REMEDIAL INVESTIGATIONS AND FEASIBILITY STUDIES UNDER CERCLA.
DOCDATE	OSWER/EPA ID	DOCNUMBER

10/1/1988 OSWER #9355.3-01	2002

TITIiE

GEOPHYSICAL	TECHNIQUES FOR SENSING

DOCDATE	OSWER/EPA ID

6/1/1984	EPA-600/7-84/064

BURIED WASTES AND WASTE MIGRATION
DOCNUMBER

2111

TITIiE

TEST METHODS FOR EVALUATING SOLID WASTE, LABORATORY MANUAL PHYSICAL/CHEMICAL METHODS, THIRD EDITION
(VOLUMES IA, IB, IC, AND II)

DOCDATE	OSWER/EPA ID	DOCNUMBER

11/1/1986	2118

TITIiE

CHEMICAL, PHYSICAL 8 BIOLOGICAL	PROPERTIES OF COMPOUNDS PRESENT AT HAZARDOUS WASTE SITES

DOCDATE OSWER/EPA ID	DOCNUMBER

9/27/1985 OSWER 09850.3	5001

TITIiE

GUIDELINES FOR CARCINOGEN RISK ASSESSMENT (FEDERAL REGISTER, SEPTEMBER 24, 1986, p. 33992

DOCDATE OSWER/EPA ID	DOCNUMBER

9/24/1986	5003

TITIiE

GUIDELINES FOR EXPOSURE ASSESSMENT	(FEDERAL REGISTER, SEPTEMBER 24, 1986, p. 34042)

DOCDATE OSWER/EPA ID	DOCNUMBER

9/24/1986	5004

TITIiE

GUIDELINES FOR THE HEALTH RISK ASSESSMENT OF CHEMICAL MIXTURES (FEDERAL REGISTER, SEPTEMBER 24, 1986,
34014)

DOCDATE OSWER/EPA ID	DOCNUMBER

9/24/1986	5007

TITIiE

HEALTH EFFECTS ASSESSMENT DOCUMENTS	(58 CHEMICAL PROFILES)

DOCDATE	OSWER/EPA ID	DOCNUMBER

9/1/1984	EPA/540/1-86/001-058	5008

TITIiE

EXPOSURE FACTORS HANDBOOK

DOCDATE	OSWER/EPA ID	DOCNUMBER

7/1/1989	EPA/600/8-89/043	5020

TITIiE

RISK ASSESSMENT GUIDANCE FOR SUPERFUND, VOLUME I, HUMAN HEALTH EVALUATION MANUAL
DOCDATE	OSWER/EPA ID	DOCNUMBER

9/29/1989 OSWER #9285.7-01a	5023

TITIiE

RISK ASSESSMENT GUIDANCE FOR SUPERFUND, VOLUME II, ENVIRONMENTAL EVALUATION MANUAL
DOCDATE	OSWERTEPA ID	DOCNUMBER

3/1/1989	EPA/540/1-89/001	5024

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TITIiE

TOXICOLOGICAL PROFILE FOR ARSENIC

DOCDATE	OSWER/EPA ID	DOCNUMBER

3/1/1989	5028

TITIiE

TOXICOLOGICAL PROFILE FOR BENZENE

DOCDATE	OSWER/EPA ID	DOCNUMBER

5/1/1989	5029

TITLE

TOXICOLOGICAL PROFILE FOR BERYLLIUM

DOCDATE	OSWER/EPA ID	DOCNUMBER

12/1/1988	5030

TITIiE

TOXICOLOGICAL PROFILE FOR CADMIUM

DOCDATE	OSWER/EPA ID	DOCNUMBER

3/1/1989	5031

TITIiE

TOXICOLOGICAL PROFILE FOR CHROMIUM

DOCDATE	OSWER/EPA ID	DOCNUMBER

7/1/1989	5033

TITLE

TOXICOLOGICAL PROFILE FOR D1(2-ETHYLHEXYL)PHTHALATE
DOCDATE	OSWER/EPA ID	DOCNUMBER

4/1/1989	5034

TITIiE

TOXICOLOGICAL PROFILE FOR HEPTACHLOR/HEPTACHLOR EPOXIDE
DOCDATE	OSWER/EPA ID	DOCNUMBER

4/1/1989	5035

TITIiE

TOXICOLOGICAL PROFILE FOR METHYLENE	CHLORIDE

DOCDATE OSWER/EPA ID	DOCNUMBER

4/1/1989	5036

TITIiE

TOXICOLOGICAL PROFILE FOR N-NITRO	SODIPHENYLAMINE

DOCDATE OSWER/EPA ID	DOCNUMBER

12/1/1988	5037

TITIiE

TOXICOLOGICAL PROFILE FOR NICKEL

DOCDATE	OSWER/EPA ID	DOCNUMBER

12/1/1988	5038

TITIiE

TOXICOLOGICAL PROFILE FOR SELECTED	PCBs (AROCLOR-1260, -1254, -1248, -1242, -1232, -1221, AND -1016)

DOCDATE OSWER/EPA ID	DOCNUMBER

6/1/1989	5039

TITIiE

TOXICOLOGICAL PROFILE FOR TRICHLOROETHYLENE
DOCDATE	OSWER/EPA ID	DOCNUMBER

10/1/1989	5040

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TITIiE

TOXICOLOGICAL PROFILE FOR VINYL CHLORIDE
DOCDATE	OSWER/EPA ID	DOCNUMBER

8/1/1989	5041

TITIiE

DEVELOPMENT OF STATISTICAL DISTRIBUTION OR RANGES
DOCDATE	OSWER/EPA ID	DOCNUMBER

3/1/1985	EPA OHEA-E-16	C020

STANDARD FACTORS USED IN EXPOSURE ASSESSMENTS

TITIiE

NATIONAL OIL AND HAZARDOUS SUBSTANCES POLLUTION CONTINGENCY PLAN.
DOCDATE	OSWER/EPA ID	DOCNUMBER

C063

TITIiE

SUPPLEMENTAL RISK ASSESSMENT GUIDANCE FOR THE SUPERFUND PROGRAM. DRAFT FINAL
DOCDATE	OSWER/EPA ID	DOCNUMBER

6/1/1989	EPA 901/5-89-001	C104

TITIiE

GUIDANCE FOR EVALUATING THE TECHNICAL IMPRACTICABILITY OF GROUND WATER RESTORATION.
DOCDATE	OSWER/EPA ID	DOCNUMBER

10/4/1993 OSWER 9234.2-25	C158

TITIiE

ESTIMATING POTENTIAL FOR OCCURRENCE	OF DNAPL AT SUPERFUND SITES.

DOCDATE OSWER/EPA ID	DOCNUMBER

1/1/1992 9355.4-07FS	C218

TITIiE

DERMAL EXPOSURE ASSESSMENT: PRINCIPLES AND APPLICATIONS. INTERIM REPORT.
DOCDATE	OSWER/EPA ID	DOCNUMBER

1/1/1992	EPA/600/8-91/011B	C227

TITIiE

CLASSIFICATION OF WETLANDS AND DEEPWATER HABITATS OF THE UNITED STATES.
DOCDATE	OSWER/EPA ID	DOCNUMBER

12/1/1979 FWS/OBS-79/31	C233

TITIiE

ECOLOGICAL ASSESSMENT OF HAZARDOUS WASTE SITES: A FIELD AND LABORATORY REFERENCE.
DOCDATE	OSWER/EPA ID	DOCNUMBER

3/1/1989	EPA/600/3-89/013	C251

TITIiE

ROLE OF THE BASELINE RISK ASSESSMENT
DOCDATE	OSWER/EPA ID

4/22/1991 OSWER #9355.0-30

IN SUPERFUND REMEDY SELECTION DECISIONS
DOCNUMBER

C276

TITIiE

RISK-BASED CONCENTRATION TABLE, THIRD QUARTER 1994

DOCDATE OSWER/EPA ID	DOCNUMBER

7/11/1994	C277

TITIiE

RISK UPDATE ISSUE NO. 2

DOCDATE	OSWER/EPA ID	DOCNUMBER

8/1/1994	C288

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TITIiE

ECOLOGICAL RISK ASSESSMENT GUIDANCE FOR SUPERFUND PROCESS FOR DESIGNING AND CONDUCTING ECOLOGICAL RISK
ASSESSMENTS (EPA 540-R-97-006)

DOCDATE	OSWER/EPA ID	DOCNUMBER

6/2/1997	C361

TITIiE

FRAMEWORK FOR ECOLOGICAL RISK ASSESSMENT (EPA/630/R-92/001)
DOCDATE	OSWER/EPA ID	DOCNUMBER

2/1/1992	C364

TITIiE

TOXICOLOGICAL BENCHMARKS FOR WILDLIFE: 1996 REVISION
DOCDATE	OSWER/EPA ID	DOCNUMBER

6/1/1996	C368

TITIiE

ECOLOGICAL RISK ASSESSMENT	ISSUE PAPERS (EPA/630/R-94/009)

DOCDATE OSWER/EPA ID	DOCNUMBER

11/1/1994	C369

TITIiE

TOXICOLOGICAL BENCHMARKS FOR SCREENING POTENTIAL CONTAMINANTS OF CONCERN FOR EFFECTS ON AQUATIC BIOTA:
1994 REVISION

DOCDATE	OSWER/EPA ID	DOCNUMBER

7/1/1994	C376

TITIiE

GUIDELINES FOR THE PROTECTION AND MANAGEMENT OF AQUATIC SEDIMENT QUALITY IN ONTARIO
DOCDATE	OSWER/EPA ID	DOCNUMBER

1/1/1996	C390

TITIiE

GREAT LAKES WATER QUALITY INITIATIVE CRITERIA DOCUMENTS FOR THE PROTECTION OF WILDLIFE (PROPOSED) DDT
MERCURY 2,3,7,8 - TCDD PCBS

DOCDATE	OSWER/EPA ID	DOCNUMBER

4/1/1983	C400

TITIiE

GUIDELINES FOR DERIVING NUMERICAL NATIONAL WATER QUALITY FOR THE PROTECTION OF AQUATIC ORGANISMS AND
THEIR USES

DOCDATE	OSWER/EPA ID	DOCNUMBER

1/1/1985	C447

TITIiE

RECOMMENDATIONS OF THE TECHNICAL	REVIEW WORK GROUP FOR LEAD FOR AN INTERIM APPROACH

DOCDATE OSWER/EPA ID	DOCNUMBER

12/1/1996	C511

TITIiE

RISK ASSESSMENT GUIDANCE FOR SUPERFUND, VOLUME 1, HUMAN HEALTH EVALUATION MANUAL, INTERIM

DOCDATE OSWER/EPA ID	DOCNUMBER

1/1/1998	C530

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