EPA/ROD/RO1-04/694
2004
EPA Superfund
Record of Decision:
SHPACK LANDFILL
EPA ID: MAD980503973
OUOl
NORTON/ATTLEBORO, MA
09/30/2004
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U.S. ENVIRONMENTAL PROTECTION AGENCY
REGION 1
SHPACK LANDFILL SUPERFUND SITE
RECORD OF DECISION SUMMARY
SEPTEMBER 2004
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PART 1: THE DECLARATION
A. SITE NAME AND LOCATION ii
B. STATEMENT OF BASIS AND PURPOSE ii
C. ASSESSMENT OF SITE ii
D. DESCRIPTION OF SELECTED REMEDY ii
E. STATUTORY DETERMINATIONS v
F. SPECIAL FINDINGS v
G. AUTHORIZING SIGNATURES vii
PART 2: THE DECISION SUMMARY
A. SITE NAME, LOCATION AND BRIEF DESCRIPTION 1
B. SITE HISTORY AND ENFORCEMENT ACTIVITIES 1
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 4
D. SCOPE AND ROLE OF OPERABLE UNIT OR RESPONSE ACTION 5
E. SITE CHARACTERISTICS 6
F. CURRENT AND POTENTIAL FUTURE SITE AND RESOURCE USES 29
1. Current Uses
2. Future Uses
G. SUMMARY OF SITE RISKS 30
1. Human Health Risks
2. Ecological Risks
3. Basis for Response Action
H. REMEDIATION OBJECTIVES 73
I. DEVELOPMENT AND SCREENING OF ALTERNATIVES 74
J. DESCRIPTION OF ALTERNATIVES 76
1. Source Control (SC) Alternatives Analyzed
2. Management of Migration (MM) Alternatives Analyzed
K. SUMMARY OF COMPARATIVE ANALYSIS OF ALTERNATIVES 79
L. THE SELECTED REMEDY 85
M. STATUTORY DETERMINATIONS 94
N. DOCUMENTATION OF SIGNIFICANT CHANGES 97
O. STATE ROLE 97
PART 3: THE RESPONSIVENESS SUMMARY 98
APPENDICES
Appendix A: State DEP Letter of Concurrence
Appendix B: ARARs Tables
Appendix C: Administrative Record Index and Guidance Documents
Appendix D: Acronyms and Abbreviations
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DECLARATION FOR THE RECORD OF DECISION
A. SITE NAME AND LOCATION
Shpack Landfill Superfund Site
Norton/Attleboro, MA.
CERCLIS ID #MAD980503973
B. STATEMENT OF BASIS AND PURPOSE
This decision document presents the selected remedial action for the Shpack Landfill Superfund Site, in
Norton/Attleboro, MA, 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 et seq.. 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 Norton Public Library and at the
United States Environmental Protection Agency (EPA) Region 1 OSRR Records Center in Boston,
Massachusetts. The Administrative Record Index (Appendix C) 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. The Commonwealth's letter of
concurrence can be found in Appendix A.
C. 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.
D. DESCRIPTION OF THE SELECTED REMEDY
The selected remedy includes excavation and off-site disposal of material exceeding cleanup levels. This
alternative eliminates the exposure pathways to soil and sediment.
The primary components of this alternative include:
Coordination with local, state and federal agencies for excavating source area materials within a
wetland and associated buffer zone;
Preparation and implementation of a traffic control plan to adequately manage the increased volume
of truck traffic associated with transportation of chemical and radiological impacted source material
from the site;
Preparation and implementation of a transportation and emergency spill contingency plan;
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Relocation of existing power line structures needed to implement the rest of the remedy in
coordination with National Grid.
Connecting two residences to public water. The two residences are identified as Union Road House
1 and Union Road House 2 in the Remedial Investigation;
Mobilization/demobilization of all personnel and equipment to the site for construction activities;
Clearing and grubbing areas of the site requiring excavation;
Establishing a survey grid to conduct sequential consolidation of grid cells to minimize generation of
large quantities of groundwater with one open excavation;
Based on the selected risk scenario for the site (Adjacent Resident without Groundwater
Consumption), excavation and off-site disposal of soil and sediment exceeding radiological and
chemical Cleanup levels including dioxin and PCBs as identified in Tables L-l and L-3, estimated in
the FS as approximately 34,445 yd3;
Excavation and off-site disposal of sediment from the Inner Rung and exceeding the cleanup levels
listed in Table L-2, estimated by the FS to be approximately 1,111 yd3 soil/sediment. The FS
estimated this will take a period of one month;
Dewatering of open areas as needed in each area of the Site;
Transportation of all impacted soils via truck and rail to an approved offsite disposal facility;
All excavated soil and sediments disposed of in accordance with TSCA and the TSCA determination
included as part of this ROD;
Placement of clean fill in open areas to backfill to grade and/or wetlands restoration/replication as
appropriate;
Vernal pools and spotted turtle habitat will be surveyed to focus on the spotted turtle and marbled
salamander and evaluate the habitat for any other rare species or species of special concern that may
be found on the Shpack Site;
Vernal pools and areas containing rare or species of special concern will be protected if possible or
restored/replicated if impacted - an impact minimization and habitat restoration plan prepared and
followed in conjunction with this work;
All work in wetlands areas conducted in accordance with the Wetland Determination included in this
ROD. In addition, work in wetlands, including replication and restoration, must comply with the
Wetlands Protection Act Regulations, 310 CMR 10 as well as all other ARARs identified for this
component of the remedy.
Installation of a temporary chainlink fence surrounding the entire site, with access gates to secure
the site during the design and construction phases of the cleanup;
Preparation and implementation of a surface water, sediment and groundwater monitoring program,
including installation of additional wells around the perimeter of the Site;
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Performance of 5-year reviews to monitor effectiveness of the remedy;
Implementation of institutional controls to restrict future use of property and groundwater.
The selected remedy is based upon a future scenario in which a resident living next to the Site (adjacent
resident) is connected to a public water supply and does not drink the groundwater at the site. The
excavation and off-site disposal of waste materials exceeding cleanup levels addresses the threat of
exposure to human health and environmental receptors. The estimated time for construction is 9-16 months.
This Record of Decision does not address groundwater contamination at and near the site. It addresses the
risk of exposure to contaminated groundwater by installing a public waterline to the two homes adjacent to
the site that are currently on private wells.
The selected response action addresses principal and low-level threat wastes at the site by eliminating
exposure to human and ecological receptors from contaminated groundwater, soil, and sediment. This is
accomplished through excavation and off-site disposal of wastes in soils and sediments exceeding cleanup
levels and installation of a waterline. Long term monitoring and institutional controls will ensure that the
remedy remains protective in the future.
This is intended to be the final Record of Decision for this site. The selected remedy is a comprehensive
approach for this site that addresses all current and potential future risks presented at the site. These
remedial measures will prevent exposure that presents an unacceptable risk to human health and ecological
receptors and meets ARARs.
E. STATUTORY DETERMINATIONS
The selected remedy is protective of human health and the environment, complies with Federal and State
requirements 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 nature and extent of the waste materials at the site, EPA concluded that it was impracticable to
excavate and treat all contaminated material in a cost-effective manner. Thus, the selected remedy does not
satisfy the statutory preference for treatment as a principal element of the remedy.
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
remedial action to ensure that the remedy continues to provide adequate protection of human health and the
environment.
F. SPECIAL FINDINGS
This ROD includes specific determinations made by EPA.
TSCA Determination
Under the Toxic Substances Control Act (TSCA), the Regional Administrator, EPA Region 1, finds that the
remedial action selected meets the standards of 40 CFR 761.50 for remediation and that the selected remedy
for excavation and offsite disposal of polychlorinated biphenyl (PCB) contaminated soil and sediment set
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out in this Record of Decision will not pose an unreasonable risk to human health or the environment
pursuant to 40 CFR 761.61 ©).
Section 404 of the Clean Water Act and Executive Order 11990 Determinations
Under Section 404 of the Clean Water Act and Executive Order 11990 (Protection of Wetlands), EPA finds
that the selected remedy, which involves excavating materials from wetland areas on the site, is appropriate
as there is no practicable alternative to conducting work in the wetlands. The remedial action minimizes
potential harm and avoids adverse effects to the extent practical. Best management practices will be used
throughout the Site to minimize adverse impacts on the wetlands, wildlife, and its habitat. Damage to these
wetlands will be mitigated though erosion control measures and proper re-grading and re-vegetation of the
impacted area with indigenous species. Following excavation activities, wetlands will be restored or
replicated consistent with the requirements of identified Federal and State wetlands protection laws.
This ROD documents the selected remedy for soils and sediments at the Shpack Landfill Superfund Site.
This remedy was selected by EPA with concurrence of the Massachusetts Department of Environmental
Protection.
In approval of the Toxic Substances Control Act finding only:
Robert W. varney
Regional Administrator
EPA-New England
Region 1
In approval of the Record of Decision:
G. AUTHORIZING SIGNATURE
Date: W, Z,oo4-~
Susan E. T. Studlien, Director
Office of Site Remediation and Restoration
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PART 2: THE DECISION SUMMARY
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A. SITE NAME, LOCATION AND BRIEF DESCRIPTION
Shpack Superfund Site, Norton/Attleboro, MA; Union Road/Peckham Street.
National Superfund electronic database identification number, e.g., CERCLIS identification number:
MAD090503973
Lead Agency: U.S. Environmental Protection Agency, Region I
Former site for disposal of industrial and municipal waste.
Site Description
The Shpack Site consists of 9.4 acres on the border between the Town of Norton, Massachusetts and the
City of Attleboro, Massachusetts.; approximately 6.0 acres in Norton were owned by Isadore and Leah
Shpack and operated as a dump. The Town of Norton now owns this portion of the Site. The adjacent 3.4
acres located in Attleboro are a small portion of the landfill currently owned by Attleboro Landfill Inc.
(ALI). ALI's entire facility is approximately 55 acres in total and approximately 110 feet high and operated
most recently as a landfill accepting municipal waste. With the exception of this 3.4-acre parcel that EPA is
addressing, ALI Landfill is being regulated by the Massachusetts DEP's solid waste landfill program. In
1986, the United States Environmental Protection Agency (EPA) placed the Site on the National Priorities
List (NPL). See Figure 1 for Locus Map of the immediate vicinity around the site.
A more complete description of the Site can be found in Section 1 of the RI Report (ERM-New England,
June 2004).
B. SITE HISTORY AND ENFORCEMENT ACTIVITIES
1. History of Site Activities
Between 1946 and the 1970s, the Shpack Site received domestic and industrial wastes, including low-level
radioactive waste. The filled areas where the wastes were dumped are overgrown and entirely enclosed by a
chain link fence. The Site itself is relatively flat with vegetated minor depressions and knolls and was
formerly a flat wetlands area. A powerline transmission corridor divides the Site into two portions. The ALI
Landfill lies directly west of the site. The Site is bounded on two other sides by the Chartley Swamp that
drains under Union Road to Chartley Pond. There are two homes on private drinking water wells within 500
feet of the Site. See Figure 2 for a map of site features, sampling points, and nearby landmarks
In 1980, the Shpack Site was added to the Department of Energy's (DOE) Formerly Utilized Remedial
Action Program (FUSRAP), which dealt with the legacy of the nation's early atomic energy programs. The
uranium discovered at the site in the late 1970's is thought to have originated from local businesses that
constructed reactor cores for the early naval propulsion program from the early 1950's until the mid-sixties.
A more detailed description of the Site History can be found in Section 1.2.2 of the RI Report.
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2. History of Federal and State Investigations and Removal and Remedial Actions
In 1978, a concerned citizen who had detected elevated radiation levels at the site contacted the Nuclear
Regulatory Commission (NRC). The NRC conducted an investigation that confirmed the presence of
radioactivity above background levels. The NRC determined that certain operations associated with
government activities might have resulted in the deposition of radioactive materials within the Shpack
Landfill. The primary constituents of concern found were radium and uranium. It is not known exactly when
these radioactive materials were deposited at the site.
The NRC investigation concluded that the Shpack Landfill was a candidate for the FUSRAP program. On
behalf of the NRC, Oak Ridge National Laboratory (ORNL) conducted a radiological survey in 1980 that
identified metallic wastes containing uranium of various enrichments. The ORNL report confirmed the
NRC preliminary findings and defined general areas of radiological contamination. In 1998, FUSRAP
responsibility was transferred from DOE to the United States Army Corps of Engineers (US ACE) and a
gamma walkover survey was performed to further delineate the radiological contamination.
In October of 1981, a security fence was installed around the site on behalf of DOE to prevent unauthorized
access. With the exception of the area located in the section of the site known as the Tongue Area and an
approximately 1,000-foot section of replacement fence, this fence is the same fence that currently is located
on the Site. Additional studies conducted by DOE between 1982 and 1984 identified chemical
contamination (volatile organic compounds (VOCs) and metals) in groundwater. In 1984, EPA evaluated
the site to determine if it should be listed on the National Priority List (NPL). The site was added to the list
in June 1986.
A summary of preliminary investigations performed at the Site prior to 1990 is included in Table 1 of the
RI. These investigations included sampling of various environmental media and primarily focused on
evaluating radiological impacts at the Site.
In 1990, a group of potential responsible parties formed the Shpack Steering Committee (SSC) and
individual companies comprising the SSC entered into an Administrative Consent Order (AOC) with EPA
(EPA Docket No. 1-90-1113, June 24, 1990) which required them to conduct the Remedial Investigation/
Feasibility Study (RI/FS) for the Site. In November 1991, the SSC prepared and submitted a Site
Characterization Work Plan (SCWP) for the first phase of the RI, known as "Phase IA". Between 1991 and
1992, the SSC implemented Phase IA of the RI, which was a comprehensive investigation of potentially
impacted media at the Site. The Phase IA identified chemical impacts in soil, groundwater, sediment and
surface water at the site. Non-radioactive constituents of concern identified on Site during the Phase IA
include:
Volatile organic compounds (VOCs);
Semi-volatile organic compounds (SVOCs);
Polychlorinated biphenyls (PCBs);
Pesticides;
Dioxins/furans; and,
Inorganics.
The results of the Phase IA RI activities were documented in ERM's 1993 Initial Site Characterization (ISC)
Report. In addition, the Phase IA contains a detailed summary of the previous investigations listed in Table
1 of the RI. With the exception of residential well monitoring activities, no chemical investigation activities
were performed at the Site after the Phase IA ISC Report.
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In 1999, the SSC in conjunction with EPA, the Corps of Engineers FUSRAP program, and DEP began
preparation of work plans to implement Phase IB of the RI. The Phase IB activities included the following:
Monitoring well Installation;
Groundwater sampling;
Surface water and sediment sampling;
Soil sampling;
Tar area delineation;
Well functionality and site survey;
Site fence extension;
Test pit excavation in Tongue Area;
Groundwater gauging;
Residential well sampling;
Surface water drainage characterization
The Phase IB activities were completed in 2003. The Results of the Phase IB investigations, as well as the
prior investigations are documented in the RI Report.
3. History of CERCLA Enforcement Activities
On June 7, 1990, EPA notified approximately 12 parties who either owned or operated the site property,
generated wastes that were disposed of at the Site, arranged for the disposal of wastes at the Site, or
transported wastes to the Site of their potential liability with respect to the Site. As a result of this
notification, a group of PRPs formed a steering committee, called the Shpack Steering Committee (SSC). In
1990, EPA and the SSC entered into an Administrative Order on Consent (Docket No. 1-90-1113) which
required those signing the AOC to conduct the RI/FS for the Site. The RI/FS was completed in June 2004.
On April 2, 2003, EPA notified DOE of its potential liability with regard to the Site. Beginning in 1998, as
part of its FUSRAP responsibilities, USAGE has been conducting investigations of the radiological waste at
the Site. Finally, a number of other parties have received "Potentially Interested Party" letters from EPA.
Additional parties that have potential liability for the Site may be identified in the future.
C. COMMUNITY PARTICIPATION
Throughout the Site's history, community concern and involvement has been high. EPA has kept the
community and other interested parties apprised of Site activities through informational meetings, fact
sheets, press releases, and public meetings. Below is a brief chronology of public outreach efforts.
Local residents formed the Citizen's Advisory Shpack Team (CAST) to monitor Site activities.
CAST has been actively involved in organizing community review of activities conducted at the Site
and providing input to the various government agencies involved at the Site.
On numerous occasions during 2000-2004, EPA and DEP held informational meetings at the
Solmonese School in Norton, Massachusetts to update the community on the results of the Remedial
Investigation and Feasibility Study.
On November 20, 2003, EPA held an informational meeting in Norton, Massachusetts to discuss the
results of the Remedial Investigation.
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On June 18, 2004, EPA published a notice of Proposed Plan in the Attleboro Sun Chronicle. The
plan was made available to the public on June 24, 2004 at the Norton Public Library (25th) and the
EPA office repository.
The Proposed Plan contained a proposed determination with regard to offsite disposal of
PCB-contaminated material pursuant to the Toxic Substances Control Act (TSCA). The Proposed
Plan also contained a draft finding that there is no practical alternative to conducting work in the
wetland areas of the Site under Section 404 of the Clean Water Act and Executive Order No. 11990.
There were no proposed waivers of ARARs included in the Proposed Plan.
On June 23, 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 previously been
involved at the Site. At this meeting, representatives from EPA, MA DEP, and the US Army Corps
of Engineers answered questions from the public.
On June 24, 2004, EPA made the administrative record available for public review at EPA's offices
in Boston and on June 25th at the Norton Public Library. This will be the primary information
repository for local residents and will be kept up to date by EPA.
From June 24, 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 requested and as a
result, the comment period was extended to August 25, 2004.
On July 21, 2004, EPA published a notice of the extension of the comment period as well as a
rescheduled public hearing date (August 4, 2004) in the Attleboro Sun Chronicle.
On August 4, 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 RESPONSE ACTION
The selected remedy was developed by combining components of different source control activities to
obtain a comprehensive approach for Site remediation. In summary, the remedy provides elimination of the
threat posed by exposure to contaminated soil and sediment exceeding cleanup levels through excavation
and disposal off site. Groundwater threats are being addressed by connecting impacted residents to a public
waterline and through the imposition of institutional controls.
The soil and sediment component of the selected remedy is based upon a future exposure scenario that
envisions a resident that lives next to the landfill (adjacent resident) who is connected to a public water
supply and therefore does not use site groundwater for drinking water, etc. EPA believes the adjacent
resident scenario is the most realistic exposure scenario for this site. It is highly unlikely that the Site could
be used for residential development given that most of the Site consists of wetlands and is bisected by high
tension power lines. This cleanup plan is also protective for potential future passive recreation at the site.
The selected remedy does not address Site groundwater. This decision is based upon recent MADEP
correspondence with EPA that indicates the State may revise the "use and value" of this aquifer downward
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from its current designation as "high" to a "low" or "medium" use and value should adjacent residents
abandon their existing wells, connect to the public water supply system, and restrict the installation of future
wells.
In its concurrence letter to EPA, Massachusetts stated that once the remedial action has been implemented
and private drinking water wells eliminated, this portion of the aquifer would no longer be considered a
current or future water supply under the Massachusetts Contingency Plan. At that point, MA DEP will
revise its Groundwater Use and Value Determination to a low use and value provided these wells are
decommissioned and controls placed on these properties that prohibit the future use of groundwater.
EPA understands that once the remedial action has been implemented and private drinking water wells
eliminated as described above, MA DEP will send to EPA its revised use and value determination
documenting this revision.
In these circumstances, given MA DEP's commitment to issue a revised use and value determination once
the remedial action has been implemented, EPA, in selecting the remedy, believes it is appropriate to issue a
low use and value determination for this portion of the aquifer. This determination is consistent with EPA's
"Groundwater Use and Value Determination Guidance."
A "low" use and value determination here means that EPA does not consider this groundwater suitable as a
drinking water source. As a result, the selected remedy does not address groundwater contamination.
E. SITE CHARACTERISTICS
Principal threat wastes are those source materials considered to be highly toxic or highly mobile which
generally cannot be contained in a reliable manner or would present a significant risk to human health or the
environment should exposure occur. The manner in which principal threats are addressed generally will
determine whether the statutory preference for treatment as a principal element is satisfied. Wastes
generally considered to be principal threats are liquid, mobile and/or highly-toxic source material.
Low-level threat wastes are those source materials that generally can be reliably contained and that would
present only a low risk in the event of exposure. Wastes that generally considered to be low-level threat
wastes include non-mobile contaminated source material of low to moderate toxicity, surface soil containing
chemicals of concern that are relatively immobile in air or ground water, low leachability contaminants or
low toxicity source material.
Nature and Extent of Contamination
This section presents the nature and extent of impacts at the Site. The distribution of impacts is presented by
media and class of compounds to document the location of areas of concern at the Shpack Site.
For the purposes of presenting the data in the RI, the Site was divided into two separate areas, as follows:
• Landfill Interior - This area includes all sampling locations inside the chain link fence
surrounding the Site, including the Tongue Area and samples collected between Shpack and
the ALI Landfill. (Now referred to as Site Interior)
• Outside the Fence - This area includes all sampling locations outside the chain link fence
north and east of the Site.
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In general, waste disposal practices at the Site have resulted in a highly variable distribution of constituents
of concern in soil and groundwater across the Site Interior. Although hot spots exist, a discernable pattern of
contaminant distribution was not observed (e.g. a discrete source area with a plume emanating from it).
Although impacts have been identified Outside the Fence, they are generally located immediately adjacent
to the Shpack Site interior. A description of the type and distribution of impacts identified at the Site is
provided below.
Background Environmental Quality
Background reference samples for chemical constituents in soil, groundwater, sediment and surface
water were collected as part of the RI The following samples were collected as part of the Phase IB
field activities and were designated as background for the purposes of evaluating the data:
Soil - SB-22, SB-23, ERM-102D, ERM-104S;
Groundwater - ERM-102D, ERM-102S, ERM-104D, ERM-104S; and
Surface Water and Sediment - SW-4 (D), SW-10 (D), SW-11 (D), SW-22 (D), and SW-23
(D).
In addition, in March 2004, additional background samples were collected in support of the
Screening Level Environmental Risk Assessment or "SLERA" (M&E, 2003) and the Baseline
Environmental Risk Assessment, or "BERA" (M&E, 2004). The following samples collected as part
of this sampling event were identified as background samples:
Soil - SB-32, SB-33, SB-34, SB-35, SB-36, SB-37, SB-38, and SB-39; and
Surface Water and Sediment - SW-24, SW-25, SW-26, SW-27, SW-28, SW-29, and SW-30.
Analytical data for background samples are included in data tables for each media. Sampling
locations are depicted on Figure 3 of the RI. In addition, data included in the 1981 ORNL
Radiological Survey of the Shpack Landfill (ORNL, 1981) provided background data for
radiological compounds detected at the Site.
Soil
Soil samples were collected during the RI from various locations and depths across the Site. The
analytical program was designed to evaluate impacts from waste disposal activities across the entire
Site; therefore, the majority of soil samples collected at the Site were analyzed for a broad suite of
chemical parameters.
The following subsections present the distribution of contaminants of concern in Site soils to give a
site-wide perspective on the occurrence and concentration of contaminants of concern. The soil data
was divided into two segments, as follows:
Shallow Soil - This data set represents soil samples collected from ground surface to a
maximum depth of two feet below ground surface (bgs).
Deep Soil - This data set represents soil samples collected deeper than two feet bgs.
Distribution of Volatile Organic Compounds (VOCs) in Soil
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The distribution of volatile organic compounds (VOCs) in shallow and deep soil samples is
displayed on Figures 11 and 12 of the RI, respectively. Analytical data for VOCs detected in soil are
presented in Table 6A of the RI. VOCs were not detected in shallow or deep background soil
sampling locations (SB-22, SB-23, and ERM-102D).
The type and distribution of VOCs in soil demonstrate the following:
The highest VOC concentrations in shallow soil are located in the north-central portion of the
Site.
The highest VOCs concentrations in deep soil are located southwest of the Site, on the ALI
Landfill.
Chlorinated solvents, including trichloroethene (TCE), tetrachloroethene (PCE),
1,2-dichloroethene and cis-1, 2-dichloroethene (cis-1, 2-DCE) were the primary VOCs
detected. These compounds were detected at one to two orders of magnitude above any other
VOC compound in soil.
A detailed summary of the various classes of compounds detected in soil is provided below.
VOCs in Shallow Soil - Site Interior
A total of 20 samples from shallow soil in the Site Interior were analyzed for VOCs. The highest
concentration of total VOCs detected in shallow soil in the Site Interior was 3,380 micrograms per
kilogram (ug/kg) at location SB-4. The predominant compound detected in SB-4 was TCE, at a
concentration of 3,300 ug/kg. Total VOCs were detected above 1,000 micrograms per kilogram
(ug/kg) at two other locations, SB-6 (1,470 ug/kg) and SB-12 (2,340 ug/kg). The predominant
compound detected in SB-6 was TCE (1,000 ug/kg) and in SB-12 was 1,2-DCE (2,100 ug/kg). All
three sampling locations (SB-4, SB-6 and SB-12) were located in the north-central portion of the
Site Interior, as shown on Figure 11 of the RI. The spatial distribution of these compounds does not
indicate a distinct or localized source area.
VOCs were detected below 100 ug/kg at 14 of the 20 sample locations, and between 100 and 1,000
ug/kg at three locations.
VOCs in Shallow Soil - Outside the Fence
A total of 11 samples from shallow soil Outside the Fence were analyzed for VOCs (Figure 11 of the
RI). VOCs were detected at three of the 11 sampling locations. The highest concentration of total
VOCs detected in shallow soils Outside the Fence was 29 ug/kg at SB-25, located north of the Site
on the Shpack Residence property. Acetone was the only compound detected at SB-25, which is not
consistent with the predominant VOC impacts (e.g. chlorinated solvents) in shallow soil in the Site
interior.
VOCs in Deep Soil - Site Interior
A total of 13 samples from deep soil in the Site Interior were analyzed for VOCs (Figure 12 of the
RI). The highest concentration total VOCs in deep soil was 54,300 ug/kg at ERM-107M (10-12 feet
bgs), located on the ALI Landfill. The predominant compounds detected in this sample included:
PCE = 38,000 ug/kg; and
TCE = 13,000 ug/kg.
7
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As shown on Figures 7 through 9 of the RI, ERM-107M is located upgradient of Shpack. The second
highest concentration of total VOCs detected in deep soil was 11,088 detected in TP-3 (4-6 feet bgs),
located on the Tongue Area, immediately downgradient of ERM-107M. This sample contained cis-1,
2-dichloroethene (cis-1, 2-DCE) at a concentration of 11,000 ug/kg. Cis-1, 2-DCE is a degradation
product of both PCE and TCE.
VOCs in Deep Soil - Outside the Landfill
A total of six deep soil samples were collected from Outside the Fence and analyzed for VOCs.
VOCs were detected at one sampling location, SB-1, at a maximum concentration of 26 ug/kg total
VOCs. SB-1 is located on the Shpack Residence property. PCE is the only compound detected in
this sample, and is consistent with the type of VOCs (i.e. chlorinated solvents) detected in the
Shpack Landfill.
Distribution of SVOCs in Soil
The distribution of semi-volatile organic compounds (SVOCs) in shallow and deep soil samples is
displayed on Figures 11 and 12 of the RI, respectively. Analytical data for SVOCs detected in all
soil samples is presented in Table 6B of the RI. SVOCs were detected in all shallow and two-thirds
of the deep background soil sampling locations (SB-22, SB-23, and ERM-102D).
The type and distribution of SVOCs detected in soil samples collected at the Site demonstrate the
following:
SVOCs were detected in all areas of the Site Interior and the distribution of SVOCs does not
indicate a distinct or localized source of SVOCs.
The predominant type of SVOCs detected in soil at Shpack include both pyrogenic (i.e.
combustion-based) and petrogenic (i.e. petroleum-based) polycyclic aromatic hydrocarbons
(PAHs) and phenols. This is consistent with the nature of waste disposal activities with
variable waste streams.
The highest total SVOC concentration in soil is located on the ALI Landfill at ERM-101B.
Where detected, SVOCs were generally detected at the detection limit or slightly above the
detection limit Outside the Fence.
A detailed summary of the various classes of compounds detected in soil is provided below.
SVOCs in Shallow Soil - Site Interior
A total of 20 shallow soil samples were collected and analyzed for SVOCs in the Site Interior
(Figure 11 of the Rf). SVOCs were detected at all sampling locations in the Site Interior. The highest
total SVOC concentrations detected in shallow soil in the Site Interior are as follows:
SB-4 (710,060 ug/kg) in the north central portion of the Shpack landfill; and
SB-9 (396,860 ug/kg) in the western portion of the Shpack Landfill.
All samples collected from the Site Interior contained SVOC compounds. Co-located samples
collected as part of the Phase IA and Phase IB at both SB-4 and SB-9 soil boring locations indicate
significant variability between the two data sets. The samples collected at SB-4 and SB-9 during the
Phase IA contained total SVOC concentrations two to three orders of magnitude higher than
8
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concentrations detected in the same location during the Phase IB (Figure 11 of the RI). The temporal
heterogeneity displayed between data sets may be attributable to variability of waste materials.
Of the remaining 18 shallow soil samples collected from the Site Interior, seven contained total
SVOC concentrations between 10,000 and 100,000 ug/kg, and the remaining 11 samples contained
total SVOCs below 10,000 ug/kg.
In general, SVOCs were detected in all areas of the Site, with localized areas of elevated
concentrations (e.g. hotspots), and do not display a discernable pattern of distribution, which is
consistent with the waste disposal practices at the Site (e.g. no point source).
SVOCs in Shallow Soil - Outside the Landfill
A total of 12 shallow soil samples were collected and analyzed for SVOCS Outside the Fence.
SVOCs were detected at seven of the 12 locations. Two locations (SB-1, and SB-26) contained total
SVOCs above 100 ug/kg, with the highest concentration (354 ug/kg) detected at SB-1 located on the
former Shpack Residence property.
In general, the concentrations of SVOCs in shallow soils Outside the Fence were highest
immediately adjacent to Shpack and decrease moving east.
SVOCs in Deep Soil - Site Interior
A total of 13 deep soil samples were collected and analyzed for SVOCs. The highest concentration
of total SVOCs was 2,686,000 ug/kg, detected at ERM-101B (6-8 feet bgs) located on the ALI
Landfill (Figure 12 of the RI). Only two other locations in the Site Interior contained total SVOCS at
concentrations exceeding 100,000 ug/kg, including:
SB-4 (193,680 ug/kg) in the north-central portion of Shpack;
SB-9 (167,550 ug/kg) in the western portion of the Shpack;
Two locations contained total SVOCs between 10,000 ug/kg and 100,000 ug/kg, including:
SB-16 (16,834 ug/kg) in the central portion of Shpack; and
TP-3 (83,100 ug/kg) located in the Tongue Area.
All other deep sampling locations in the Site Interior contained total SVOCs below 10,000 ug/kg.
The distribution of SVOCs in deep soil in the Site Interior is varied and does not display a
discernable pattern, although localized areas with elevated concentrations exist.
SVOCs in Deep Soil - Outside the Fence
A total of three deep soil samples from Outside the Fence were analyzed for SVOCs. SVOCs were
detected in one (SB-1) at a concentration of 5 ug/kg. This concentration is below the background
concentration of 185 ug/kg.
Distribution of Pesticides and PCBs in Soil
9
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The distribution of pesticides and polychlorinated biphenyls (PCBs) in shallow and deep soil
samples is displayed on Figures 11 and 12 of the RI, respectively. Analytical data for pesticides and
PCBs detected in all soil samples are presented in Table 6C of the RI. Pesticides and PCBs were not
detected in shallow or deep background soil sampling locations (SB-22, SB-23, and ERM-102D).
The type and distribution of pesticides and PCBs detected in soil samples collected at the Site
demonstrate the following:
PCBs were only detected in the Site Interior and pesticides were detected in both the Site
Interior and Outside the Fence.
A discernable pattern of the lateral or vertical distribution of PCBs and pesticides impacts
was not identified, which is consistent with the nature of waste disposal activities (e.g.
variable waste deposition).
A total of three Aroclors were detected, including Aroclors 1248, 1254 and 1260.
A wide range of pesticides were detected in soil.
A summary of the PCBs and pesticides detected in soil is provided below.
Pesticides and PCBs in Shallow Soil - Site Interior
A total of 20 shallow soil sampling locations in the Site Interior were analyzed for PCBs (Figure 11
of the RI). The highest total PCB concentration detected in the Site Interior was 2,270 ug/kg at soil
sampling location SB-13 (0-2 feet bgs) in the central portion of the Site. Aroclor 1248 was the
primary component, at a concentration of 2,000 ug/kg. PCBs were also detected in a co-located
sample at a concentration of 280 ug/kg, resulting in an average concentration of 1,275 ug/kg total
PCBs at this location. At the remaining 19 sampling locations, total PCBs were detected below 100
ug/kg at nine locations and below 1,000 ug/kg at ten locations. The lateral distribution of PCB
detections is heterogeneous across the Site and does not indicate a discrete source area or "hot spot".
A total of 20 shallow soil samples in the Site Interior were analyzed for pesticides. The highest total
pesticide concentration detected was 1,180 ug/kg at soil sampling location SB-16 in the southern
portion of the Site. Pesticides were detected in a co-located sample at a concentration of 119.9
ug/kg, resulting in an average total pesticide concentration of approximately 650 ug/kg. Total
pesticides were detected below 100 ug/kg at all other sampling locations, except for sampling
location SB-13 (200.78 ug/kg), which was located in the central portion of the Site.
Pesticides and PCBs in Shallow Soil - Outside the Fence
A total of 12 shallow soil samples Outside the Fence were analyzed for PCBs. PCBs were detected
at two locations, SB-18 (15 ug/kg) east of the Site and SB-2 (7.9 ug/kg) north of the Site.
A total of 12 shallow soil samples Outside the Fence were analyzed for pesticides. Total pesticides
were detected at six locations, with the maximum concentration of 10.89 ug/kg detected at SB-25
located on the former Shpack Residence property, north of the Site.
Pesticides and PCBs in Deep Soil - Site Interior
A total of 12 deep soil samples in the Site Interior were analyzed for PCBs (Figure 12 of RI). The
highest concentration was 420 ug/kg, detected at location SB-4 (2-4 feet bgs), located in the north
10
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central portion of the Site. PCBs were not detected at seven of the 12 sampling locations. At the
remaining five locations, PCBs were detected below 100 ug/kg at all locations, except ERM-105D,
located near SB-4 in the north central portion of the Site.
A total of 12 soil samples from the Site 1 interior were analyzed for pesticides. Pesticides were
detected at six of the 12 sampling locations. The highest concentration of pesticides was 74.8 ug/kg,
detected at location SB-13 (2-4 feet bgs) in the center of the Site.
Pesticides and PCBs in Deep Soil - Outside the Fence
A total of three deep soil sampling locations were analyzed for pesticides and PCBs Outside the
Fence. Pesticides and PCBs were not detected in any of the deep samples analyzed from Outside the
Fence
Distribution of Dioxins/Furans in Soil
A total of two sampling locations from the Site Interior were submitted for analysis of
dioxins/furans. Table 6D of the RI contains a summary of dioxins/furans detected in soil samples
collected at the Site. Dioxins/furans were detected at both sampling locations. The highest
concentration of total dioxins/furans was detected at ERM-105D (0-2 feet bgs) at approximately 30
ug/kg. Dioxins/furans were not detected in the deeper sample (22-24 feet bgs) collected at this
location.
Distribution of Inorganics in Soil
A total of 68 soil samples were submitted for laboratory analysis of inorganics (which included
metals and cyanide) during the RI. Table 6E of the RI contains a summary of inorganic constituents
detected in soil samples collected at the Site. In general, the distribution of inorganics in soil
indicated the following:
The highest concentrations were located in the Tongue Area and the north central portion of
the Site Interior, near ERM-105, SB-13, SB-4 and SB-12.
The concentrations Outside the Fence were one to three orders of magnitude lower than the
concentrations in the Site Interior.
The concentration often selected inorganics in shallow and deep soil are plotted on Figures 13 and
14 of the RI, respectively. The plotted data includes only those compounds detected above the
maximum concentration (rounded up) in background samples SB-22, SB-23, ERM-102D or
ERM-104S. A summary of the distribution of inorganics shown on these figures is as follows:
Inorganics in soil exceeding maximum background concentrations were primarily
constrained to the Site Interior.
The distribution of inorganics detected above background on Site was variable across the
Site Interior and is consistent with the nature of waste disposal activities (i.e. heterogeneous
deposition).
The highest concentrations of cadmium, chromium, nickel and zinc in both shallow and deep
soils were in the Tongue Area (with the exception of zinc in shallow soil).
The highest concentrations of arsenic in both shallow and deep soils were located in the
western portion of the Site Interior
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The highest concentrations of lead in both shallow and deep soils were located in the north
central portion of the Site Interior.
The highest concentrations of barium in both shallow and deep soils were located in the
northwestern and central portions of the Site.
The highest concentrations of manganese, vanadium and silver in shallow and deep soils
were located in the central portion of the Site Interior.
The extent of inorganics in soil does not appear to extend outside the Site Interior. The
concentrations of inorganics in surface water and sediment (Section 4.4 and 4.5 of the RI) adjacent
to the Tongue Area are consistent with elevated concentrations of metals observed in soil in the
Tongue Area.
The highest concentrations of mercury were located in the southeastern portion of the Site adjacent
to, and in, the Tongue Area, and at one sampling location in the north central portion of the site as
follows:
All other mercury detections are below 2.0 mg/kg.
Cyanide was detected in soil at five locations, with the maximum concentrations detected at SB-12
(7.1 mg/kg) and SB-10 (3 mg/kg), located in the central and western portions of the Site,
respectively. Cyanide was detected at the remaining three locations below 1.0 mg/kg.
Thallium was detected in soil at five locations, with the maximum concentration detected at SB-9
(0.11 mg/kg) located in the western portion of the Site.
Antimony was detected in soil at 10 locations with the highest concentrations detected at SB-20
(75.4 mg/kg), TP-6 (67.6 mg/kg), ERM-105D (62.3 mg/kg), SB-16 (58 mg/kg), SB-13 (44.7 mg/kg),
SB-4 (36.6 mg/kg), and SB-6 (35.3 mg/kg). These samples were all located on or near the Tongue
Area or in the north central portion of the Site. One soil sample collected Outside the Fence, SB-24,
contained antimony, at a concentration of 0.93 mg/kg. No other sample collected Outside the Fence
contained antimony.
Distribution of Radiological Parameters in Soil
This section summarizes analytical results and interpretations based upon information collected by
the USAGE for radiological parameters in soil. Soil samples were collected at 135 locations for
laboratory analysis of radiological parameters. Table 6F of the RI contains a summary of laboratory
analytical results for radiological parameters analyzed as part of the Focused Site Inspection
performed by Cabrera, the contractor for the USAGE. For the purposes of displaying the nature and
extent of radiological soil impacts, the distributions of uranium (23 5U and 23 8U) and radium
(226Ra and 228Ra), have been plotted on Figure 15 of the RI (provided by Cabrera) as
representative indicator compounds. Due to the variability of concentrations of radiological
ERM-103B
SB-16 =
ERM-105D
TP-1 =
SB-17 =
SB-21 =
41 mg/kg
30.7mg/kg
22.2 mg/kg
8.9 mg/kg
2.2 mg/kg
3.6 mg/kg (north central portion of site)
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parameters detected, the scale of contaminant concentrations is different for each parameter. As
shown on these figures, both radium and uranium were detected across the majority of the Site. The
highest concentrations of radiological parameters are summarized in the following table:
Parameter
Location
Depth
Concentration
(feet bgs)
(PCi/g)
235U
1274
1 -3
730
1278
1 -3
311
1224
1 -3
185
1096
1 -3
174
1286
1 -3
90
1136
1 -3
46.1
238u
1274
1 -3
14,200
1224
1 -3
6,900
226Ra
1281
0-2
1,600
1100
1 -3
730.99
228Ra
1274
1 -3
4.6
1273
1 -3
4.25
As shown on Figure 15 of the RI, elevated concentrations of uranium and radium were detected in
discrete areas of the Site. The highest concentration of 228Ra (4.6 picorcuries per gram (pCi/g)) is
collocated with the highest concentration of 235U and 238U (730 and 14,200 pCi/g, respectively) in the
southeastern portion of the Site, near borings 1273 and 1274. However, the highest concentrations of
226Ra detected at borings 1281 (1,600 pCi/g) and boring 1100 (730.99 pCi/g) in the northern and
eastern edges of Wetland #2 are not collocated with the highest concentrations of either 235U or238U.
Groundwater
Groundwater samples were collected from 25 monitoring wells in 1992 and from 30 monitoring
wells in 2002 as part of the RI. The following subsections present the distribution of contaminants in
groundwater. Figure 16 of the RI displays the distribution of organic compounds detected in
groundwater in the Site Interior and Outside the Fence. Tables 7 A, 7B, and 7C of the RI contain
summaries of VOCs, SVOCS, and inorganics, respectively, detected in groundwater at the Site. In
general, groundwater analytical data indicated the following:
VOCs detected in groundwater were primarily chlorinated solvents and were located in three
discrete areas. The highest concentration of total VOCs are located at well cluster ERM-107,
located upgradient of the Shpack Site on the ALI Landfill.
The distribution of VOCs in samples collected from monitoring wells in the Site Interior and
Outside the Fence relative to concentrations of VOCs in perimeter/off-site monitoring wells
indicate that impacts were limited to areas inside the Site Interior and do not appear to be
migrating Outside the Fence.
The elevated levels of SVOCs detected in soil do not appear to have significantly impacted
groundwater quality.
A summary of the groundwater data is presented below.
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Distribution of VOCs in Groundwater
VOCs were detected at 25 of the 30 groundwater sampling locations at the Site (Figure 16 of the
RI). Concentrations of total VOCs were detected at relatively low levels (below 100 micrograms per
liter (ug/1)) at 20 of the 25 locations where total VOCs were detected. The five detections of total
VOCs greater than 100 ug/1 primarily contain chlorinated solvents (e.g. TCE, 1,2-DCE, cis-1,
2-DCE, etc.) and were located in three discrete areas, as follows:
Tongue Area - One well triplet, ERM-107, located on the ALI Landfill, upgradient of the Tongue
Area, contained three of the five concentrations greater than 100 ug/1 and the highest concentration
detected, 173,000 ug/1 (ERM-107M, Phase IA).
Total VOCs were detected in ERM-107M at a concentration of 11,650 ug/1. Earlier samples
at this location contained primarily TCE (84,000 ug/1) and PCE (70,000 ug/1), whereas, the
more recent sample contained primarily cis-1,2-DCE (9,800 ug/1) and vinyl chloride (1,200
ug/1). The presence of these compounds likely indicates that degradation of TCE and PCE is
occurring.
Monitoring well ERM-107D contained the second highest total VOC concentration (4,150
ug/1). This sample contained PCE at a concentration of 3,400 ug/1 and TCE at a
concentration of 600 ug/1.
Monitoring well ERM-107S contained the fourth highest total VOC concentration (362
ug/1). This sample contained PCE at 180 ug/1 and TCE at 140 ug/1.
Downgradient monitoring well cluster ERM-103 did not contain concentrations of
chlorinated solvents exceeding 100 ug/1.
North Central Interior - The third highest concentration of total VOCs detected in groundwater was
at ERM-105D (5,227 ug/1). This sample contained cis-1, 2-DCE at a concentration of 5,000 ug/1 and
vinyl chloride at a concentration of 200 ug/1. The presence of these compounds likely indicates that
degradation of chlorinated solvents is occurring. Downgradient monitoring well ERM-102D did not
contain detectable concentrations of chlorinated solvents or degradation byproducts.
Eastern Interior - The final concentration of total VOCs exceeding 100 ug/1 was located in the
eastern portion of the Site Interior at DOE-4 (700 ug/1). This sample contained cis-1,2-DCE at a
concentration of 200 ug/1 and vinyl chloride at a concentration of 500 ug/1. The presence of these
compounds likely indicates that degradation of chlorinated solvents is occurring. The nearest
downgradient monitoring wells contain either low levels of chlorinated solvents (ERM-34D-4.72
ug/1) or do not contain detectable concentrations of chlorinated solvents or degradation byproducts.
In summary, total VOCs were detected at low levels across the entire Site Interior and at elevated
levels in three distinct areas.
Distribution of SVOCs in Groundwater
SVOCs were detected in groundwater at eight of the 25 locations analyzed for SVOCs (Figure 16 of
the RI). SVOCs were only detected in monitoring wells located in the Site Interior. In general, the
non-soluble SVOC compounds detected in soil in the Site Interior have not leached to groundwater
Outside the Fence.
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The maximum concentration of total SVOCs detected on Site was at monitoring well ERM-105S at
a concentration of 245 ug/1. (Table 7B of the RI). Total SVOCs were detected in this well at a
concentration of 1.65 ug/1, which is more representative of current Site conditions. The types of
SVOC compounds detected in this sample are consistent with those compounds detected in soil at
this location.
The maximum concentration of total SVOCs detected during the Phase IB was 117.2 ug/1 at
monitoring well ERM-107M, located on the ALI Landfill, upgradient of the Site. The majority of
SVOC compounds detected in this sample are phenolic compounds that are relatively soluble.
Distribution of Pesticides and PCBs in Groundwater
Pesticides and PCBs were not detected in any of the 25 groundwater samples collected in the early
round of sampling. Therefore, none of the groundwater samples collected during the later rounds
were analyzed for PCBs or pesticides.
Distribution of Inorganics in Groundwater
In general, the concentrations of most inorganics detected in groundwater during the 2002-2003
sampling event are one to three orders of magnitude lower than the concentrations detected in
groundwater during the 1992 sampling event. The recent sampling is most representative of current
groundwater conditions at the Site.
The following table summarizes the maximum concentration of metals and cyanide detected in
groundwater, the location of the maximum concentration and the area of the Site where the
maximum value was detected.
Parameter
Maximum
Concentration (ug/1)
Location
Area of Site
Antimony
0.96
ERM-107M
ALI Landfill
Arsenic
69.6
ERM-32D
Power line Access Road
Barium
3760
ERM-105S
Site Interior (north)
Beryllium
75.1
ERM-103D
Tongue Area
Cadmium
70.9
ERM-103S
Tongue Area
Chromium
203
ERM-103D
Tongue Area
Lead
68.1
ERM-107M
ALI Landfill
Manganese
18600
ERM-32D
Power line Access Road
Mercury
0.19*
ERM-109B
ALI portion of the Shpack
Nickel
15300
ERM-103S
Tongue Area
Selenium
4.7*
ERM-107D
ALI Landfill
Silver
4.3
ERM-105D
Site Interior (north)
Vanadium
85.4
ERM-107D
ALI Landfill
Zinc
15800
ERM-103S
Tongue Area
Cyanide
17.3*
DOE-3
Outside the Fence (north)
Notes: * - Compound was only detected at this location during 2002-2003 sampling round
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As shown in the above table, the majority of the maximum concentrations of inorganics detected in
groundwater are isolated to either the Site Interior in Wetland #2, or Outside the Fence, adjacent to
the Tongue Area. The inorganic constituents of concern detected in groundwater are consistent with
those detected in soil.
The concentrations of inorganics detected in background groundwater sampling locations,
ERM-102S, ERM-102D, and ERM-104S were one to three orders of magnitude lower than the
maximum concentration detected on Site.
Distribution of Radiological Parameters in Groundwater
This section summarizes analytical results and interpretations provided by the USAGE for
radiological parameters in groundwater. Table 7D of the RI lists a summary of radiological
parameters detected in groundwater in the Site Interior and Outside the Fence. Radiological
parameters were detected at all groundwater sampling locations. The following table summarizes the
location of the highest detections of Gross Alpha, Gross Beta, Radium, and Uranium detected on
Site.
Parameter
Maximum
Detection
Location
Area of Site
Gross Alpha
90 pCi/1
DOE-7
Eastern Interior
Gross Beta
143pCi/l
ERM-107S
The ALI Landfill
Radium 228
7.5 pCi/1
ERM-107M
The ALI Landfill
Uranium 232
13 pCi/1
ERM-106S
Northern Interior
Uranium 234
118pCi/l
DOE-7
Eastern Interior
Uranium 235
9.4 pCi/1
DOE-7
Eastern Interior
Uranium 238
15pCi/l
DOE-7
Eastern Interior
Gross Alpha was detected at the same order of magnitude as the maximum concentration at four
locations, ERM-103B (22.9 pCi/1), ERM-103D (34 pCi/1), ERM-107M (18 pCi/1), and ERM-32D
(29.2 pCi/1). These detections were located in the Tongue Area (ERM-103), on the ALI Landfill
(ERM-107 and on the power line access road located east of the Shpack Site (ERM-32S). All of
these samples were either located in the eastern/southeastern portion of the Shpack Site, or east of
the Shpack Site.
Radium was detected at 20 locations at the same order of magnitude as the highest concentration
detected during this sampling round. Based on the detections of radium in groundwater, radium was
located in all areas of the site at relatively consistent concentrations. This distribution of radium in
groundwater is consistent with the distribution of radium in soil.
The second highest concentrations of 234U and 238U were detected in the Tongue Area at ERM-103B
(234U = 22.6 pCi/1 and 238U = 9.9 pCi/1) and ERM-103D (234U = 20.6 pCi/1 and 238U = 10.7 pCi/1).
Concentrations of 234U and 238U were not identified in any other sample at this magnitude.
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Surface Water
A total of 21 surface water samples were submitted for analysis of VOCs, SVOCs, PCBs and
pesticides. Surface water at the site was defined as areas of seasonal standing water. Figure 17 of the
RI displays the distribution of organic compounds detected in surface water in the Site Interior and
Outside the Fence. As noted above, surface water located within the Site Interior was essentially
isolated from surface water located Outside the Fence. In addition, surface water transport from the
Site Interior was restricted due to topographical features inhibiting overland flow of surface water
from the Site Interior to surface waters Outside the Fence. Tables 8A, 8B. 8C. and 8D of the RI
contain a summary of VOCs, SVOCS, PCB/pesticides and inorganics, respectively, detected in
surface water at the Site.
In general, surface water analytical data indicate the following:
VOCs were detected at low levels in surface water in the Site Interior and were not detected
Outside the Fence
SVOCs were detected in surface water in the Site Interior in later sampling and were
generally detected at concentrations less than 1.0 ug/1.
Pesticides were detected in surface water in the Site Interior in later sampling and are
consistent with pesticides detected in soil.
PCBs were detected in one surface water sample collected during the early sampling rounds
however, PCBs were not detected in later sampling
The highest concentrations of metals in surface water were located Outside the Fence,
immediately adjacent to the Tongue Area.
A summary of the compounds detected in surface water is presented in the following subsections.
Distribution of VOCs in Surface Water
A total of 21 surface water samples were submitted for analysis of VOCs from both the Site Interior
and Outside the Fence (Figure 17 of the RI). VOCs were detected at nine locations, with the
maximum concentration of 174 ug/1 total VOCs detected at SW-1 (Table 8 A of the RI). The
predominant compound detected in this sample was acetone at a concentration of 170 ug/1, which
was not identified during later sampling.
The most frequently detected compound was cis-1, 2-DCE, at four locations, SW-1 (1.2 ug/1),
SW-15 (5.6 ug/1), SW-18 (0.38 ug/1), and SW-19 (19 ug/1). All of these surface water sampling
locations were in the Site Interior wetlands.
Distribution of SVOCs in Surface Water
SVOCs were detected in surface water at six of the 14 locations sampled (Figure 17 of the RI).
SVOCs were not detected at any of the sampling locations Outside the Fence (SW-4, SW-6, SW-7,
SW-8 and SW-9) with the exception of SW-5, where total SVOCs were detected at 0.5 ug/1. The
maximum concentration of SVOCs detected in the Site Interior is 4.5 ug/1 at SW-1. The total SVOC
concentration of 4.5 ug/1 detected at SW-1 in earlier sampling was not reproduced at SW-1 during
later sampling.
Distribution of Pesticides and PCBs in Surface Water
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Pesticides were detected at three of the 14 sampling surface water locations, SW-15, SW-16 and
SW-18, located in the Site Interior. The maximum concentration of pesticides was 0.02 ug/1 at both
SW-16 and SW-18. Pesticides were not detected in surface water at any sampling location Outside
the Fence.
PCBs were only detected at one surface water sampling location (SW-1) during the early sampling at
a concentration of 0.43 ug/1 (Figure 17 of the RI). This detection was not confirmed in the surface
water sample collected at this location during later sampling rounds. PCBs were not detected in any
surface water sampling location in the Site Interior or Outside the Fence.
Distribution of Inorganics in Surface Water
A total of 23 surface water samples from the Site Interior and Outside the Fence were submitted for
laboratory analysis of total and dissolved inorganics (metals and cyanide [Table 8D of the RI]).
Inorganics were detected at all sampling locations in the Site Interior and Outside the Fence.
Because the analysis of unfiltered samples includes the suspended particles in the water, higher
levels of inorganics are expected in these samples than the filtered samples. Total inorganic
concentrations are generally one to three orders of magnitude greater than dissolved concentrations
(Table 8D of the RI). The remainder of this section presents the results of total inorganics findings
only.
The highest concentrations of inorganics detected in surface water were observed Outside the Fence
adjacent to the Tongue Area at SW-5, and in the Site Interior in Wetlands #1 and #2. A summary of
the various inorganics detected in surface water is provided below.
The highest concentration of nine metals were detected at one sampling location, SW-5, located
Outside the Fence, adjacent to the Tongue Area, as follows:
Beryllium-
1,480 ug/1
Cadmium-
121 ug/1
Chromium -
13,300 ug/1
Lead -
868 ug/1
Mercury-
41.1 ug/1
Nickel -
235,000 ug/1
Silver-
35.9 ug/1
Vanadium -
618 ug/1
Zinc -
49,900 ug/1
The concentration of these nine metals are one to three orders of magnitude lower in all other
samples collected at the Shpack Site. The concentration of inorganics in surface water detected at
SW-5 is consistent with the concentrations detected in soil in the Tongue Area.
The highest concentration of antimony was detected in Wetland #2 in the Site Interior at locations
SW-1 (24.5 ug/1 - Phase IA) and SW-2 (36 ug/1) and Outside the Fence, adjacent to the Tongue
Area at SW-5 (14.9 ug/1). These concentrations are one to two orders of magnitude above the
concentration of antimony detected at any other sampling locations either in the Site Interior or
Outside the Fence.
18
-------
The highest concentration of arsenic in surface water was detected in sampling location SW-4,
located south of the Site, at a concentration of 31.4 ug/1. The next highest concentration of arsenic
was detected adjacent to the Tongue Area at SW-5 at a concentration of 10.8 ug/1.
The highest concentrations of barium in surface water were detected in the Site Interior in Wetlands
#1 and #2 at SW-1 (7,500 ug/1), SW-2 (4,840 ug/1), SW-15 (1,300 ug/1), SW-17 (2,430 ug/1),
SW-18 (2,530 ug/1) and SW-19 (1,690 ug/1). Barium was not detected at any other sampling
location above 1,000 ug/1.
The highest concentration of selenium in surface water was detected at SW-16 (8.6 ug/1), located in
Wetland #2, in the Site Interior. The next highest concentration of selenium was detected in
sampling locations SW-4 (6.2 ug/1) and SW-10 (8.5 ug/1) located south of the Site.
Distribution of Radiological Parameters in Surface Water
This section summarizes analytical results and interpretations for radiological parameters in surface
water. Table 8 of the RI lists a summary of radiological parameters detected in surface water Outside
the Fence. Radiological parameters were detected at all surface water sampling locations. The
following table summarizes the location of the highest detections of Gross Alpha, Gross Beta,
Radium, and Uranium detected Outside the Fence.
Parameter
Maximum
Detection
Location
Sample Location
Gross Alpha
3.6 pCi/1
SW-14
Chartley Swamp (SE)
Gross Beta
12 pCi/1
SW-14
Chartley Swamp (SE)
Radium 226
220 pCi/1
SW-13
Chartley Swamp (SE)
Radium 228
4.33 pCi/1
SW-11
Near the ALI Landfill (SE)
Uranium 232
11.6 pCi/1
SW-12
Adjacent to Tongue (SE)
Uranium 234
3.26 pCi/1
SW-5
Adjacent to Tongue (SE)
Uranium 235
0.29 pCi/1
SW-5
Adjacent to Tongue (SE)
Uranium 238
2.66 pCi/1
SW-5
Adjacent to Tongue (SE)
Gross Alpha was only detected at one location (SW-14). This detection is located in Chartley
Swamp southeast of the Site along the power line access road. Gross Alpha was not detected in any
of the other surface water samples analyzed for radiological parameters.
Radium was detected at all seven locations at the same order of magnitude as the highest
concentration detected in surface water. Radium in surface water outside of the site was detected at
relatively consistent concentrations. The distribution of radium in surface water is consistent with
the distribution of radium in both soil and groundwater.
The highest concentrations of 234U and 238U were detected immediately adjacent to the Tongue Area
at SW-5 (234U = 3.26 pCi/1 and 238U = 2.66 pCi/1). The second highest concentrations 234U and 238U
were detected downgradient of DOE-7 at SW-6 (234U = 1.93 pCi/1 and 238U = 1.92 pCi/1) and
southeast of the site at SW-1 1 (234U =1.18 pCi/1 and 238U = 1.04pCi/l).
19
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Sediment
A total of 14 sediment samples were collected from in the Site Interior and Outside the Fence were
analyzed for VOCs, SVOCs, PCBs and pesticides. In general, organic compounds were detected at
low levels Outside the Fence and at elevated concentrations in the Site Interior. A summary of the
distribution of each class of compounds is provided in the following subsections. Figure 17 of the RI
displays the distribution of organic compounds detected in sediments in the Site Interior and Outside
the Fence. Tables 9A. 9B, 9C, 9D and 9E of the RI contain summaries of VOCs, SVOCS,
PCB/pesticides, inorganics, and general chemistry, respectively, detected in sediments at the Site.
Distribution of Total VOCs in Sediment
Total VOCs were detected at 10 of the 14 sediment sampling locations, with the highest
concentrations detected in the central wetlands in the Site Interior (Figure 17 of the RI) . The two
highest total VOC concentrations in sediment are 13,107 ug/kg and 6,436 ug/kg at SW-18 and
SW-15, respectively (Table 9A of the RI). The predominant compounds detected in these samples
are TCE (13,000 ug/kg) in SW-18 and cis-1, 2-DCE (6,400 ug/kg) in SW-15. The next highest
concentration of total VOCs detected in any sediment sample is 52 ug/kg, detected in SW-8.
Distribution of Total SVOCs in Sediment
Total SVOCs were detected at all 14 sediment sampling locations, with the highest concentration
detected in Wetland 2 in the Site Interior (Figure 17 and Table 9B of the RI). All samples collected
from Wetland 2 contained total SVOCs at concentrations exceeding 10,000 ug/kg, as follows:
SW-15 = 29,230 ug/kg;
SW-16= 18,246 ug/kg;
SW-17= 12,804 ug/kg; and
SW-18 = 200,810 ug/kg;
No other sediment samples collected in the Site Interior or Outside the Fence contained total SVOCs
at concentrations exceeding 1,000 ug/kg except at SW-19 where total SVOCs were detected at a
concentration of 1,211 ug/kg.
Distribution of Pesticides in Sediment
Pesticides were detected at five of the 14 sediment sampling locations analyzed. (Figure 17 and
Table 9C of the RI). Pesticides were not detected in any samples collected from Outside the Fence
(SW-4, SW-5, SW-6, SW-7, SW-8, and SW-9). The highest concentration of total pesticides
detected in sediment in the Site Interior is 1,970 ug/kg at SW-18, located in Wetland 2. The next
highest concentration of total pesticides is two orders of magnitude lower, 92 ug/kg at SW-15, also
located in Wetland 2.
Distribution of PCBs in Sediment
PCBs were detected at seven of the 14 sediment sampling locations collected (Figure 17 and Table
9C of the RI). PCBs were not detected in any samples collected from Outside the Fence (SW-4,
SW-5, SW-6, SW-7, SW-8, and SW-9). The highest concentration of total PCBs detected in the Site
Interior is 91,000 ug/kg at SW-18, in Wetland #2. The next highest concentration of total PCBs is
two orders of magnitude lower, 370 ug/kg at SW-17, also located in Wetland #2.
20
-------
Distribution of Inorganics in Sediment
A total of 23 sediment sampling locations from the Site Interior and Outside the Fence were
submitted for laboratory analysis of total and dissolved inorganics (Table 91) of the RI). Inorganics
were detected at all sediment sampling locations in the Site Interior and Outside the Fence.
The following table summarizes the maximum concentration of metals and cyanide detected in
sediment on site, the location of the maximum concentration and the area of the site where the
maximum was detected.
Parameter
Max. Concentration
(ug/kg)
Location
Area of Site
Antimony
618
SW-18
Wetland #2
Arsenic
38
SW-7
Chartley Swamp
Barium
3,570
SW-18
Wetland #2
Beryllium
98.5
SW-12
Adjacent to Tongue Area
Cadmium
82.1
SW-12
Adjacent to Tongue Area
Chromium
1,380
SW-12
Adjacent to Tongue Area
Lead
2,970
SW-16
Wetland #2
Manganese
1,980
SW-17
Wetland #2
Mercury
4.4
SW-12
Wetland #2
Nickel
26,200
SW-12
Adjacent to Tongue Area
Selenium
3.3
SW-14
Power line Access Road
Silver
454
SW-18
Wetland #2
Thallium
0.15
SW-5
Wetland #l/Tongue Area
Vanadium
127
SW-7
Chartley Swamp
Zinc
20,800
SW-12
Adjacent to Tongue Area
Cyanide
2.1
SW-18
Wetland #2
As shown in the above table, the majority of the maximum inorganic concentrations detected in
sediment were located either in Wetland #2, or Outside the Fence, adjacent to the Tongue Area. The
concentration of inorganics in sediment detected in background sampling locations, SW-10, SW-11,
SW-22 and SW-23 were one to three orders of magnitude lower than the maximum concentration
detected on Site.
Residential Wells
In 2001, 2002, and 2003, samples of drinking water were collected from residential wells near
Shpack as part of Phase IB investigation activities. The analytical program was designed to evaluate
potential impacts to private drinking water supply wells. Figure 3 shows the location of the wells
sampled, as well as the location of the two closest wells, Union Road House 1 and Union Road
House 2. Water samples were collected from wells at following residences:
21
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Town of Attleboro
Well Depth
Town of Norton
Well Depth
Peckham Street, House 1
unknown
Union Road, House 1
unknown
Peckham Street, House 2
unknown
Union Road, House 2
14 feet
Peckham Street, House 3
unknown
N. Worcester Street, House 1
180 feet
Peckham Street, House 4
unknown
Maple Street, House 1
75 feet
Maple Street, House 2
140 feet
Maple Street, House 3
200 feet
Maple Street, House 4
200 feet
Maple Street, House 5
unknown
Maple Street, House 6
unknown
The following subsections present a summary of constituents identified in drinking water near
Shpack. Figure 4 of the RI displays residential well sampling locations with respect to Shpack. Table
10 of the RI summarizes analytical results of residential well samples collected as part of the Phase
IB Investigation. A summary of the residential drinking water data is presented below.
Distribution of VOCs in Residential Wells
A total of six VOCs were detected at six of the 14 residential well sampling locations (Table 10 of
the RI). VOCs were not detected above EPA Maximum Contaminant Limits (MCLs) in any of the
drinking water samples. In general, VOCs were detected at low levels in the residential drinking
water wells. As shown on Table 10 of the RI, five of the six VOCs detected in residential wells were
detected in only one sampling event and have not been repeated in previous or subsequent sampling
events. One VOC, methyl-tert butyl-ether (MTBE) has been detected in four of the six residential
drinking water wells at concentrations ranging from 0.68 ug/1 (Peckham Street, House 3) to 37 ug/1
(Peckham Street, House 2). With the exception of Union Street, House 1, the residential wells where
MTBE has been detected are not associated with the Shpack Site. MTBE was detected in
groundwater at the Shpack site at five locations.
Distribution of Inorganics in Residential Wells
Table 10 of the RI displays inorganic analytical results for residential drinking water samples
collected as part of the RI in 2001, 2002, and 2003. In April 2003, samples collected from four wells
were believed to contain four separate inorganic compounds exceeding EPA MCLs. Based on these
results, re-sampling of these wells was performed in July and August 2003, as summarized in the
following table:
22
-------
Location
Compound
MCL
April 2003
July 2003
August 2003
N Worcester, House 1
Arsenic
0.01
0.0113
0.0136
0.0164
Maple Street, House 5
Cadmium
0.005
0.204
ND
ND
Union Street, House 1
Lead
0.015
0.0008
ND
ND
Union Street, House 2
Antimony
0.006
0
ND
ND
Notes
All compounds reported in milligrams per liter (mg/1)
MCL = Maximum Contaminant Limit
ND = Compound not detected
The detection of arsenic at North Worcester Street, House 1 is not believed to be related to Shpack
as this location is across Chartley Pond and situated topographically and hydrologically upgradient
of Shpack. The residential well sample collected at Maple Street, House 5 was most likely the result
of a laboratory error and was not reproducible
In addition, the MCL exceedences at the other two residential well sampling locations were the
result of data transcription errors, were re-sampled and confirmed to be free of MCL exceedences.
One sample containing manganese was originally reported in the RI at 840 ug/1 at Union Street,
House 2 This was later determined to be a transcription error The maximum level of manganese
detected in this residential well was 170 ug/1. This detected manganese level results in noncancer
hazard quotients of 0.19 and 0.66 for current adult and small child receptors, respectively, which are
both below EPA's noncancer threshold of 1.0. Please refer to the revised Tables 3.10 RME, 7.4
RME, and 7.5 RME for the corrected tables within the "Human Health Risk Assessment-Letter
Addendum", dated September 15, 2004 by Metcalf and Eddy for further detail. 1
1 Water levels in monitoring wells screened in the shallow zone at the Shpack site suggest that groundwater
flow is semi-radially outward toward the northwest, north, northeast, east, and southeast The only direction in which
water levels are higher immediately off the site is to the southwest, beneath the ALI Landfill Although the
groundwater contours for the shallow zone suggest that flow would be toward the private water supply wells north of
the site at Union Road House 1 and Union Road House 2, the shallow groundwater flow is apparently predominantly
downward at the site, into the deeper overburden This concept is supported by both water level and water quality
measurements The positions of these two homes relative to the site (in particular their close proximity to the site) and
to highly contaminated wells make them potentially vulnerable to future contamination if hydrologic conditions
change (e.g , water levels in nearby ponds and wetlands change, drainage characteristics at the Shpack or ALI sites are
altered) Therefore, EPA has determined that a sufficient threat exists at the Site to support installation of a waterline
to these two houses This determination is consistent with EPA's 1988 "Guidance Document for Providing Alternate
Water Supplies"
"In addition, remedial action may be taken based on the threat of future contamination in cases where these
criteria are not yet exceeded ("MCLs") If potable wells are not currently contaminated, it must be determined
they will be threatened with contamination before a final remedy addressing ground water contamination can
be implemented"
23
-------
Distribution of Radiological Parameters in Drinking Water
Table 10 of the RI lists a summary of radiological parameters detected in residential drinking water
in the vicinity of the Shpack Site. Radiological parameters were not detected above EPA MCLs in
any of the residential drinking water samples collected during the RI. Gross Alpha and Beta were
detected at approximately one order of magnitude less than Gross Alpha and Gross Beta in
groundwater at the Shpack Site. Radium was detected in residential drinking water at the same order
of magnitude as Radium detections in groundwater at Shpack. Total Uranium was detected in
residential drinking water at the same order of magnitude or an order of magnitude less than detected
in groundwater at Shpack.
Other Investigation Activities
This section summarizes the results of other field investigation activities performed at Shpack as part
of the RI.
Test Pit Investigation Results
A total of 10 test pits were excavated in the Tongue Area to evaluate the physical and chemical
nature of waste materials in this area. Based on the test pit program, landfill materials in the Tongue
Area are approximately 6 to 8 feet thick and consist of rubber garden hose, concrete, ash (gray,
purple, and yellow in color), metal debris, cinders, wood debris, unidentified burnt debris, and
crushed PVC. The materials were mixed with brown-orange, fine sand, silt, and clay, with some
coarse gravel, and some gray clay lenses. Test pit logs are included in Appendix A of the RI.
As shown on Table 6 of the RI, VOCs, SVOCs, PCBs, pesticides and inorganics were detected in all
soil samples collected from the Tongue Area test pits. In addition, some of the highest
concentrations of inorganic compounds were detected in soil samples collected from test pits in the
Tongue Area. Radiological screening of soils excavated during test pit activities did not indicate
elevated levels of radionuclides in soil in the Tongue Area. This is consistent with radiological
analysis of soil samples collected from soil borings collected in this area by the USAGE (Table 6F
of the RI).
Tar Pit Delineation Results
As part of the RI field activities, the extent of tar material present on the surface of the Site was
evaluated (Figure 3 of the RI). The depth of the tar was evaluated using sections of one-inch
diameter PVC marked with depth measurements. The lateral extent of the tar area was measured
using a tape measure.
Based on the Tar Pit delineation, the tar material measures approximately 0.3 feet to 0.8 feet deep
and extends over an area approximately 12 feet wide by 27 feet long. A graphical representation of
the lateral and vertical extent of the tar pit area is included as Figure 18 of the RI.
24
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F. CURRENT AND POTENTIAL FUTURE SITE AND RESOURCE USES
1. Current Use
The land use surrounding the Site is predominantly rural/low-density residential in nature. The ALI Landfill
is located directly west of the Site. Groundwater is currently used as drinking water by two residents close
to the Site. This is consistent with the State's use and value determination that designates this groundwater
as "high" use and value based primarily upon the fact that this groundwater is currently being used for
drinking water at these two houses.
2. Future Use
As part of the FS, EPA evaluated each alternative based upon four possible future use scenarios. These
scenarios are as follows:
Recreational user
Adj acent resident w/out groundwater exposure
Adj acent resident w/groundwater exposure
On-site resident
Based upon EPA's review of the Site and input from the community and local Town officials, the
reasonably anticipated future use of the site could be either the recreational scenario or the adjacent resident
scenario. A great many comments have been received from the community supporting the recreational
scenario. However, because there is an adjacent resident in existence and the area is zoned to allow that use
to continue, EPA believes this scenario is the most realistic future use scenario. This decision is not contrary
to the wishes expressed by many in the community that the Site be cleaned up to allow recreational use in
the future. The adjacent resident scenario assumes greater exposure to contamination than the recreational
scenario and, therefore, will require greater quantities of waste material to be addressed by the remedy. As a
result, by cleaning up the Site to an adjacent resident scenario and addressing unacceptable ecological risks,
the remedy will be sufficiently protective to allow recreational uses as well.
EPA has also determined that on-site residential use of the site is highly unlikely based upon several factors.
First, a large portion of the Site consists of wetlands which are not conducive to residential development. In
addition, the Site is adjacent to the ALI Landfill. The Site is also bisected by high voltage power lines. All
of these factors make residential development undesirable and therefore not realistic for residential future
use.
The selected remedy does not address Site groundwater (See Section D. SCOPE AND ROLE OF
OPERABLE UNIT OR RESPONSE ACTION for this determination).
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 public 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
25
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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. The ecological risk assessment followed the eight-step process guidance
for Superfund.
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
Sixty-one of the more than 125 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, concentration, frequency of detection, and
mobility and persistence in the environment and can be found in Tables 2.1 through 2.14 of the risk
assessment (M&E, 2004). 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-5 for surface water, sediment, 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 3.1 through 3.14 of the risk assessment (M&E, 2004).
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 consists of a central fenced portion, the more recently-fenced "tongue" area, unfenced areas at the
perimeter of the fencing, the former Shpack residence, and unfenced wetland areas, including Chartley
Swamp. The Site is in a predominantly rural, low density residential area. The ALI Landfill landfill abuts
the site to the west. A utility right-of-way with power lines crosses through the Site. Residences are found to
the north and east of the site and also across Chartley Swamp. There are numerous residential wells within a
3-mile radius of the Site, the closest well being located at the former Shpack residence.
The risk assessment looked at several different exposure pathways consistent with current and future
potential uses at the Site. The following current uses were evaluated in the risk assessment:
Adjacent resident with exposure to groundwater through ingestion;
Former Shpack resident (adult)/worker at adjacent landfill with exposure to surface soil through
ingestion, dermal contact, and external exposure to radionuclides;
Trespasser (adolescent) with exposure to surface soil by ingestion, dermal contact, and external
exposure to radionuclides; to surface water (by dermal contact) and to sediment (by ingestion and
dermal contact) within the wetland areas of the Site.
26
-------
ROD RISK WORKSHEET
Table G-1
Summary of Chemical of Concern and Medium-Specific Exposure Point Concentration
Scenario Timeframe: Future
Medium; Surface Water
Exposure Medium: Surface Water
Exposure Point
Chemical of
Concern
Concentration Detected
Units
Frequency of
Detection
Exposure Point
Concentration
Exposure Point
Concentration
Units
Statistical
Measure
Minimum
Maximum
(1)
Site-wide
Benzo{a;pyrene
0.2
0.4
ug/L
2/14
0.4
ug/L
Max
Benzo(b)fluoranthene
0.2
0.3
ug/L
2/14
0.3
ug/L
Max
Benzo(k)fluoranthene
0.1
0.4
ug/L
2/14
0.4
ug/L
Ma*
Aroclor-1254
0.43
0.43
uglL
1/14
0,41
ug/L
95% UCL - NP
Beryllium
0.785
1480
ug/L
6/21
381
ug/L
95% UCL - NP
Chromium
0.5?
13300
uglL
15/21
3436
ug/L
95% UCL - NP
Nickel
9.5
235000
ug/L
21 / 21
61363
ug/L
95% UCL - NP
Key
(1) Statistics; Maximum Detected Value (Max), 95% UCLof Transformed Data <95% UCt - T); 95% UCLof Normal Data (95% UCL - N); 95% UCl Of Non-parametric Data (95% UCL - NP);
Arithmetic Mean (Mean)
The table represents the chemicals of concern (COCs) and exposure point concentrations (EPCs) for each of the COCs detected in surface water (i.e., the concentrations that wilt be used to estimate the exposure and
risk tar each COC in surface water). 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 inorganic chemicals are the most frequently detected COCs in surface water at the site. The 95% UCL on the arithmetic mean
was used as the EPC for the inorganic compounds beryllium, chromium, and nickel and for Aroclor-1254. However, due to the limited amount of sample data available for benzo(a)pyrene, benzo(b)fluoranthene, and
berizo(k)fluoranthene, the maximum detected concentration was used as the default EPC
Source: A Guide to Preparing Superfund Proposed Plans, Records of Decision, and Other Remedy Selection Decision Documents (U.S. EPA, 1999)
Page 1 of 16
Tables G-1 to G~16.xls
-------
ROD RISK WORKSHEET
Table G-2
Summary of Chemical of Concern and Medium-Specific Exposure Point Concentration
Scenario Timeframe: Future
Medium; Sediment
Exposure Medium: Sediment
Exposure Point
Chemical of
Concern
Concentration
Detected
Minimum
Maximum
Units
Frequency of
Detection
Exposure Point
Concentration
Exposure Point
Concentration
Units
Statistical
Measure
(1)
Site-wide
Aroclor-1254
0.035
84
mg/Kg
8/22
20
HQ/Kg
95% UCL - NP
Key
(1) Statistics: Maximum Detected Value (Max); 95% UCL of Transformed Data (95% UCL-T), 95% UCL of Normal Data (95% UCL - N); 95% UCL of Non-parametric Data {95% UCL - NP);
Arithmetic Mean (Mean)
The table represents the chemical of concern {COC) and exposure point concentration (EPC) for the COC detected in sediment (i.e., the concentrations that will be used to estimate the exposure and risk for the COC
in sediment). The table includes the range of concentrations detected far the 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 Aroclor-1254 is the only COC in sediment at the site. The 95% UCL on the arithmetic mean was used as the EPC for Aroclor-1254.
Source: A Guide to Preparing Superfurtd Proposed Plans, Records of Decision, and Other Remedy Selection Decision Documents (U.S. EPA, 1999)
Page 2 of 16
Tables G-1 to G-16.xls
-------
ROD RISK WORKSHEET
Table <3-3
Summary of Chemical of Concern and Medium-Specific Exposure Point Concentration
Scenario Timeframe: Future
Medium; Soil
Exposure Medium: Surfoce Soil
Exposure Point
Chemical of
Concsm
Concentration Oetecied
Units
Frequency of
Detection
Exposure Point
Concentration
Exposure Point
Cor«C4Kitna(lon
Units
Statistical
M«asurt
(1)
MUnifnum
Maximum
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46
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95%UCL T
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355
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96% UCL- t
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1 2
mjyKg
96% UCL • NP
Dwxin T£Q
0 00003
0Q0GS7
mg/Kg
3'3
000047
Max
Ar*rx
0.1?
?9 3
mg.'Kg
?7 HI
15
mg/Kg
S5% UCl - T
Nick*
5 7
48950
rog-Kg
27 27
1394*1
R6% UCL - NH
Uranium, total
078
43363
71 71
3=02
^0
06* UCL - NP
R*22$
n as
1S0Q
pC^
119' 133
77
pCx-9
9&% UCL - N°
U 234
0 22
5340
pC-9
/I; 7i
bt>f
pCi^g
as% uCl - Nr'
U-23S
0C3
pC»'g
fl9> 133
4n
pC^9
95% UCL • NP
U-23S
0 25
1*^2 OC
PCvg
71 ; 71
1277
pC^g
96% UCi. - NP
On 5«e Rei% UCl v NP
Urarium. lolai
0 7B
42363
mq/Kg
71 71
3902
96% UCL - NP
Rj-228
0 36
1600
eC^S
11©/ 133
77
95% UCL - NP
U-234
0 72
&340
oCJb
71 71
5GT
pGA'jn ^
E.H»Ipce»1 Vaiue ;Max
9h\ !>::i n' Trausfer
-md Eiflfa ^°v. uC.i ¦ !
lk"i r! Sif>rma [
,ila (y'j% - N}
4. s.C,. o'Nuo
¦. Dd'.s J95V 'JCl - NP
"he Obip neE*«oils Dirf corcer-Sr aliens ;EPCa,: d he COCs toU x>>- *av !>»ES"Cwas deved For ail e*posur« pcirts. INs tacie indica'.as thai icx^yarm: •.'nr-H.ais we it* mosl frequently deleciad ZOCi n surtaee sen at ihe site The
95% UC. uf 'IX- a lUirntlK. mean wws u*&i *i> Itw irf "C lor frv inorganic compounds arseriu ar-d tramum IsrHw 'wJiofHJtl-doi FU-22S Lk?34 L1 arw U-?38. arte lor i he organic chcm^ais
be»uc(«i;«3i'•!f jot an< rt-beruria.hunHvaoww!. .irvi nicerx*' l.y J-cdJpvrero! Howevei due lo U« limited sm«jnl of ssmpte dafa avaiiabkr for rl-ocn*, [»-<• m&KnTvutn oeKt'cd
concC'ilfa'ivn ifdi us»eti as '.Ne default O'-V
Source: A Guide lo Preparing Superfund Propowd Plans, Records of Decision, *nd Other R*m*dy Selection Decision Docurrwnts (U.S. EPA, 1999)
Page 3 of 16
1 shifts G-1 toG-?6 xls
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ROD RISK WORKSHEET
Table G-4
Summary of Chemical of Concern and Medium-Specific Exposure Point Concentration
Scenario Timeframe-. Future
Medium: Soil
Exposure Medium: Subsurface Soil
Exposure Point
Chemical of
Concern
Concentration Detected
Units
Frequency of
Detection
Exposure Point
Concentration
Exposure Point
Concentration
Units
Statistical
Measure
Minimum | Maximum
Combined Orv-SHe
Nickel
101
3&7Q0
12 / 12
39700
mg/Kc
Wax
Adjacent Residence
Benzo( a ^anih racene
Q.34
1S0
mg/Kg
7/12
96
mg/Kg
95% UCL-T
Benzo(a)pyrene
0 DOS
140
tiQ/Kg
10/ 12
140
m^Kg
Max
Benzoibjfluo^nt^enc
0 WW
150
fi^Kg
10/12
150
mg/Kg
Max
~ibenz(a,h)anthracene
0 19
1 6
mg/Kg
A / 12
1.6
mg/Kg
Max
Dkwm TEQ
000232
0.00232
mg/Kg
1 1
0 00232
mg/Kg
Max
Arsenic
1 55
1H.2
mg/Kg
11/12
182
mg/Kg
Max
Nicker
101
39700
mg/Kg
12/ 12
39700
mg/Kg
Max
Uranium, total
0.00000013
151
mg/Kg
40/40
28
mg/Kg
95% UCL • NP
Ra-226
0 12?
900
pog
86/123
40
pCi/g
95% UCL - NP
U-234
0 13
39 3
pO'g
39/40
5.?
pCi/g
95% UCL - T
U-235
0 02
3.17
pCi/g
30/123
0 50
pCi/g
95% UCL - NP
U-235
o ns
49 4
pCi/g
39/40
; B
pD/g
95% UCL - T
OfvStfe Residence
Benzo(a>anfhrac»ie
0 34
1&0
mg/Kg
7/12
96
mg/Kg
95% UCL - T
Bert?cKa)pyf©r»
0.003
140
mg/Kg
10/12
140
»*>0*9
Ma*
Berv?o(b>fluorariihene
0 004
150
mg/Kg
10/12
150
(ngXg
Max
Beri?o(k}fli,Kyanthefie
0.022
110
mg/Kg
a! 12
49
tkj/Kq
95% UCL • T
Dvben^a .^anthracene
0^9
mg/Kg
4 ! 12
1 «
mgfl*g
Max
ifideno<1 ,2(3-cdjpyren«
0 071
110
mg/Kg
7/12
43
rng/Kg
95% UCL - T
Dioxin T£Q
0 00232
0 00232
rinj/Ky
1 > 1
0 00232
mg/Kg
Max
Arsenic
1 55
18 2
mg/Kg
11/12
18.2
mg/Kg
Max
Chrorruurti
3.5
2740
m0^9
12/12
2740
mg/K.g
Max
Mercury
0 08
41
mg/Kg
10/12
41
m&Kg
Max
Nickel
101
39700
mqJKq
12/12
39700
mg/Kg
Max
Ra-22G
0 12?
900
pCt/g
36/123
40
$0*8
95% UCL - NP
U-238
0 05
434
pCi.'g
39 f 40
78
pC«g
95% UCL • T
Key
(1} Statistics Maximur
Arrthnnetic Mean CW
n Detecied Value {Max)
can]
95% UCL o? Transform
ed Data (95% UCL - T>
05% UCL of Normal D
%ta ft5% UCL - N); 95%
UCL ol Non-paramet'H
Data (95% UCL - NP],
The tatitfi represents the chemicals ol cnrcem i.COCs) and etposure point concentrations (rPCs] for each ftl tfic COCs detected m subsurface soil 0 e , the ccKicertlrafws thai will be used to ^sinuate IN*
exposure and nsK for each COC subsurface so«lS The table includes Ihe njnge of concentrations yetecteU fix vach COC, tis well as She frequency o? d<«
-------
ROD RISK WORKSHEET
Table G-5
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
Units
Frequency of
Detection
Exposure Point
Concentration
Exposure Point
Concentration
Units
Statistical
Measure
Minimum
Maximum
(1)
Combined
Benzene
0.5
3 J
ug/L
Si 25
37
ug/L
Max
cis-1,2-Dichk3roethene
0.71
5000
ug/L
15/25
5000
ug/L
Max
Triehtoroefhene
056
9.8
ug/L
6/25
9.8
ug/L
Max
Vinyl chloride
0 87
500
ug/L
8/25
500
ug/L
Max
Benzo(b Jfluora nthene
0 13
0.13
ug/L
1/3
0.13
ug/L
Max
Arsenic
0.65
69.6
ug/L
18/25
63 6
ug/L
Max
Barium
7.9
3760
ug/L
25/25
3760
ug/L
Max
Beryllium
0.2
75.1
ug/L
7/25
75.1
ug/L
Max
Cadmium
0.31
70.9
ug/L
9/25
70.8
ug/L
Max
Chromium
03
203
ug/L
21/25
203
ug/L
Max
Manganese
8.7
16600
ug/L
25/25
18600
ug/L
Max
Nickel
1.1
15300
ug/L
25/25
15300
ug/L
Max
Zinc
5.3
15800
ug/L
22/25
15SOO
ug/L
Max
U-234
0.05
118
pCi/L
19/23
118
pGi/L
Max
U-23S
0.06
94
pCi?L
8/23
9.4
pCl/L
Max
U-238
0 03
15
pCi/L
16/23
15
pCW.
Max
Key
!1J Statistics: Maximum Detected Value (Max): 95% UCL of Transformed Data (95% UCL - T), 95% UCL of Normal Data (95% UCl • N), 95% UCL of Non-parametric Data (95% UCL - NP),
Arithmetic Mean (Mean)
The table represents the chemicals of concern (COCs) and exposure point concentrations (EPCs) for each of the COCs detected in groundwater (i.e , the concentrations that will be used to estimate the exposure and
risk for each COC in groundwater). The table includes the range of concentrations detected for each COC. as weW as the frequency of detection (\ 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 thai inorganic chemicals are the most frequently detected COCs in groundwater at the site As prescribed by EPA guidance, the
maximum detected concentration was used as the EPC for all COCs detected in groundwater
Source: A Guide to Preparing Superfund Proposed Plans, Records of Decision, and Other Remedy Selection Decision Documents (U.S. EPA, 1999)
Page 5 of 16
Tables G-1 to G-16.xls
-------
These current exposure pathways and receptors identified may continue in the future.
The following future uses were also evaluated in the risk assessment:
Adjacent resident with exposure to groundwater through ingestion;
Adjacent resident (adult and child)/worker to the site with exposure to surface and subsurface soil
through ingestion, dermal contact, and external exposure to radionuclides;
Former Shpack resident (adult and child) with exposure to surface and subsurface soil through
ingestion, dermal contact, inhalation, and external exposure to radionuclides;
On-site resident (adult and child) with exposure to surface and subsurface soil through ingestion,
dermal contact, external exposure to radionuclides, inhalation of volatile contaminants present in
soil and groundwater following migration to indoor air; and to groundwater through ingestion;
Recreational (adult and child) with exposure to surface and subsurface soil through ingestion, dermal
contact, external exposure to radionuclides; to surface water (by dermal contact) and to sediment (by
ingestion and dermal contact); and,
Construction and utility workers with direct exposure to surface and subsurface soil contaminants,
direct exposure to shallow exposed groundwater and inhalation of volatile contaminants in soil and
groundwater following migration to outdoor air.
In the future, removal of the fencing after completion of the remedial action could allow an increased
intensity and frequency of exposure to on-site soil contaminants for the adjacent resident and for trespassers.
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 or 1E-06 for 1/1,000,000)
and indicate (using this example), that an average individual is not likely to have greater than 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-6.
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 non-carcinogenic effects
32
-------
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 non-carcinogenic effects are unlikely. A
summary of the non-carcinogenic toxicity data relevant to the chemicals of concern is presented in Table
G-7.
The following is a brief summary of the exposure pathways that were found to present significant risks
exceeding EPA's cancer risk range and noncancer threshold. 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 5 and on Tables 9.1 through 9.22 of the risk assessment (M&E, 2004).2
Recreational Use
Tables G-8 and G-12 depict the carcinogenic and non-carcinogenic risk summary for the chemicals of
concern in surface water and surface soil evaluated to reflect potential future recreational exposure
corresponding to the reasonable maximum exposure (RME) scenario. For the future young child and adult
recreational user, carcinogenic and non-carcinogenic risks exceeded the EPA acceptable risk range of 10"4 to
10"6 and a target organ HI of 1. The exceedences were due primarily to the presence of benzo(a) pyrene,
beryllium, chromium, and nickel in surface water, Aroclor-1254 in sediment, and nickel, uranium, Ra-226,
and U-238 in surface soil.
On-Site Resident
Tables G-9 and G-13 depict the carcinogenic and non-carcinogenic risk summary for the chemicals of
concern in groundwater evaluated to reflect potential future RME residential drinking water exposure.
Carcinogenic and non-carcinogenic risks for the future resident drinking water ingestion scenario exceeded
the EPA acceptable risk range primarily due to the presence of the following compounds in groundwater:
cis-1, 2-dichloroethene, trichloroethene, vinyl chloride, arsenic, barium, beryllium, cadmium, chromium,
manganese, nickel, zinc, and U-234. In addition, the following compounds detected in groundwater
exceeded MCLs: cis-1, 2-dichloroethene, trichloroethene, vinyl chloride, arsenic, barium, beryllium,
cadmium, chromium, lead, and uranium.
Tables G-10 and G-14 depict the carcinogenic and non-carcinogenic risk summary for the chemicals of
concern in surface and subsurface soil evaluated to reflect potential future on-site residential exposures for
the RME scenario. For the future on-site resident, carcinogenic and non-carcinogenic risks exceeded the
EPA acceptable risk range for surface and subsurface soil due primarily to the presence of nickel, uranium,
Ra-226, U-235, and U-238 in surface soil and chromium, mercury, nickel, benzo(a) pyrene, benzo(b)
fluoranthene, dioxin, and Ra-226 in subsurface soil.
2 For contaminated groundwater, ingestion of 2 liters/day, 350 days/year for 24 years was presumed for an
adult. For a young child (age 1 to 6), ingestion of 1.5 liters/day, 350 days/year for 6 years was presumed Dermal
contact and incidental ingestion of soils was evaluated for a young child and adult recreational user and on-site
resident who may be exposed 78 or 150 days/year, respectively, for a total of 30 years. Dermal contact and incidental
ingestion of soils was also evaluated for a young child and adult adjacent resident, assumed to be equally exposed to
soil contaminants in both the yard of the former Shpack residence and the site interior (75 days year at each location).
Soil ingestion rates for the young child and adult were presumed to be 200 mg/day and 100 mg day. respectively.
Dermal contact with surface water along with incidental ingestion and dermal contact with sediment was evaluated to
reflect a young child and adult recreational user who may wade in the wetlands 78 days each summer for a total of 30
years. Sediment ingestion rates were the same as those presumed for soils Incidental ingestion of and dermal contact
with subsurface soils were evaluated for the construction worker who was presumed to be exposed 125 days/year. The
soil ingestion rate for the worker was presumed to be 200 mg/day
33
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ROO RISK WORKSHEET
Table G-6
Cancer Toxicity Date Summary
Pathway: Ingestion, Dermal
Chemical of
Oral Cancer
Dermal Cancer
Slope Factor
Weight of
Date
Concern
Slop® factor
Slope Factor
Units
Evid«nceCan^dr
Source
{MWDDfYYYY}
GukcMiiine OMcrlptlon
Benzene
5.5E-02
S5E-Q2
tee*g/MjHjay]
A
IRIS
07/01,-03
©fr^Z-Dicnionoeinei'ie
N>A
M'A
jmg/^g-dHV]
D
JRIS
07-tH^3
IncHtoroelhflne
1 OL-Ol
4 0E 01
iros^a-^f!
C-62
NCEA
07/01^3
Vinyl Chtonde
"I 5E*00
1 5F *00
(m^kg-dgr/J
c
IRIS
07/01^3
BenB5^a)s«firacer«
J.3E.-C1
7 3E-01
img/kg-da*f
B2
IRIS
Q7/!]1iC3
BeruufajpyrfW
? 3F*Q0
1 3E*Qi>
!fiK^-^3Vr'
B2
(RtS
Q7/oim
BeraeNibJfluorafiihene
7 3E-01
7 3E-G1
yj
=2
WS
Q7/0W3
Berizo^kJI^rafit^e^e
7.3E-02
7 3E-02
£2
IRIS
O.'jVI.VZ
n0O
(mQ/kg-dayf
ft?
IRIS
Q7/0iJQ2
lrKleno(1.2,3-al}pyf«rte
7 2E-01
7 3E-01
SmgAg-day)
B2
mis
o?m#3
AjoW-'254
20E+0C
2-9E+00
irngfkg-dayj'
B2
IHIS
IJ I'D', ID'J
Dtoxjr TEO
1 SE'QS
1 SF+QS
S
07,-01/03
C#jrrnu9/kg-
IRIS
07sk'ycaf per pO'g soi
A
HLA&r
amixa
u-?3b
1 141-0/
Lwemal LKposun;
Ri5^y?ar per pGu'g sesi
A
HEAST
o?Xiim
Ra-226
7 3E-10
Sort if^gestton
RtsJg'pCt Mil
A
HEAST
07,til.*03
U 234
1.6E-10
Soil Irtfleston
R>Ski'pCi SO-i
A
tfLASl
U-?3S
1 BF.-IO
Soil ingestion
Rif^'pCi soil
A
HEAST
07,t?«3
L-238
2 1E-10
5*ji< Ingestion
Rt&JpCu sai
A
HEAST
cmim
U 234
71E1!
Wiper logesioo
RiS*/pCi water
A
MLASI
cmi.v.s
U-J35
/ ?L-H
water ingesJKjn
RisWpCi waier
A
HEAST
07,'01,'03
U-23S
8 7E-1!
Water IngastKin
Risfc/pT.i watar
A
'-(EAST
07/01,1}3
Key
EPA Group
N/A Nol apt>licd«e
A - Human <:x".tr *Kj*n
IRiS Imegraieo R'Sl-Inlof-at-on Systerr US EPA
61 • Probatte riuman c
¦•KCirtogen • Indicates limited humarma'a ;r« av.ioncJ|'C'nogeniCiiy
I his i a We presides fie
C^'CinoQenc 'is*- mlofmatio
T W'Kt> i iKteVd'H ?•_» tl* V'Ulrilllin.Ji'Iii j1 MJlCe
rd .ft%jff3C€i waiter, sediineii, SO't ^rx3gojn.Jwjtef Ail'*stime slope
Irx 'f»e ce'rri.ii ro^iB of exposure "hus if>» sK?p<& fado's used m !rrs asspssfdi Ivt/e been R>tiii
XilciltH* ii!_m Gi j. vJIufeS
Ar. adjus'Tie^t 'actor
is semelimes apo^ud aifl isdeoer>dert jpon fiuw
*ell '.he cftem tal is absorbed via tie oral route
Adjuslmenls c.yla-'v i'*'
txif aor 'or chefriicj1^ with less than 5C%
aasorpciun via the ingestion rojie However ad;ys
merit «s let Ir* the ctwrrnr.als- Hv;iUi;«e^ a* ms srfH "fteretare ihe «.
ame valuns pf^^n'^rl above we-e us«d i*ik
dermal ca^mnogorFic slope facers tor "hese ccrvjm
njris
Source: A Gukle to Preparing Superfund Proposed Plans, Records of Decision, and CXher Remedy Selection Decision Documents (U.S. EPA, 1999}
Page 6 o? 16 Tables G-1 to G-16.xls
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ROD RISK WORKSHEET
Table G-7
Non-Cancer Toxicity Data Summary
Pathway: Ingestion, Derma*
Chemical of
Concern
Chronic/
Subchronic
Oral RfD Value
Oral RfD Units
Darmal RfD
Dermai RfD
Units
Primary Target
Organ
Combined
Uncertainty/
Modifying
Factors
Sources of RfD;
Target Organ
Dates of Rfd:
Target Organ
(MM/DOnrYYY}
Benzene
Chronic
4.0E-03
rng/kg-day
4.0E-03
mg/kg^iay
Immune System
300
IRIS
07/01/03
as-1 ^-Dcrtoroethene
Chronic
1 0E-02
mg/k^-day
1 OE-02
rr^/kg-day
Btood
3000
HEAST
07/01/9?
T rieMoroetfiene
Chronic
3 OE-04
mg/kg-day
3 0E-C4
mg/kg-day
Ltvcr
3000
NCEA
07/01/03
Vinyl eMonde
Chronic
3 0E-03
rngykg-d;iy
3.QE-03
n^/kg-day
Liver
30
IRIS
07/01/03
Bern tXa Anthracene
N/A
N/A
N/A
N/A
N/A
N/A
H'A
N/A
NJA
BenzcKa)pyrenc
N/A
N/A
N/A
N/A
N/A
N/A
N/A
N/A
N/A
Ben^oor-*2!>4 afleci the tnimuno system. as-* ^-dichioroet'iunt} and /mc affect ttiu blood sirsentc affects the skin,
barym affucts the candiOvascutar system. cadfmurn and uiartiurn affect Itu: Kittys, beryfliurr and chromium af'ect Jhe gasliointobtma, system, manganese and mf-rnury affect I he nervous system, and rocket causes gtmp.ral toxicity resulting
m growth reduction Reference doses are not available for the carewkogorac poiycyc^c aromatic fsydrocarDnns {benzol a Anthracene, benzcKa}pynene, tienzo( b jft uo r a n I he ne. Be n z o(k )t 1 uor e nihe ne. ait'enz(a.?i)anlhracene and mdenof • ,2.3-
r-djpyrene) or d»oxm Derma3 RfDs are not available tor any of me COCs As was the case for tf>« carcinogenic data riemiaf RfDs can be extrapolated from oral RfDs by appiyiry an adjustment factor as appropriate)
Dermal RfDs have been extrapolated tor the inorganic compounds banum cadmium. cnromiuni, manganese, nickel, and uranium thai have :£s» t?ian 50% sDsQOJlKjn via She ingestion route
Source: A Guide to Preparing Superfund Proposed Plans, Records of Decision, and Other Remedy Selection Decision Documents (U.S. EPA, 1999)
Page ?oM6
Tables G-1 toG-16.xls
-------
Adjacent Resident
Tables G-l 1 and G-15 depict the carcinogenic and non-carcinogenic risk summary for the chemicals of
concern in surface and subsurface soil evaluated to reflect potential future adjacent residential exposures for
the RME scenario. For the future adjacent resident, carcinogenic and non-carcinogenic risks exceeded the
EPA acceptable risk range for surface and subsurface soil due primarily to the presence of nickel, uranium,
Ra-226, and U-238 in surface and subsurface soils.
Tables G-9 and G-13 depict the carcinogenic and non-carcinogenic risk summary for the chemicals of
concern in groundwater evaluated to reflect potential future RME residential drinking water exposure.
Carcinogenic and non-carcinogenic risks for the future resident drinking water ingestion scenario exceeded
the EPA acceptable risk range primarily due to the presence of the following compounds in groundwater:
cis-1, 2-dichloroethene, trichloroethene, vinyl chloride, arsenic, barium, beryllium, cadmium, chromium,
manganese, nickel, zinc, and U-234. In addition, the following compounds detected in groundwater
exceeded MCLs: cis-1,2-dichloroethene, trichloroethene, vinyl chloride, arsenic, barium, beryllium,
cadmium, chromium, lead, and uranium.
Construction Worker
Table G-16 depicts the non-carcinogenic risk summary for the chemicals of concern in subsurface soil
evaluated to reflect potential future construction worker exposure for the RME scenario. For the
construction worker, the non-carcinogenic risk exceeds the EPA acceptable risk range for subsurface soil
exposure due to the presence of nickel.
This ROD is based upon the adjacent resident without groundwater consumption exposure scenario.
Readers are referred to Section 5 and Tables 9.1 through 9.22 of the risk assessment (M&E, 2004) 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.
Risks Associated with Exposure to Lead
The Integrated Exposure and Uptake Biokinetic (IEUBK) model was used to evaluate the hazard potential
posed by exposure of future on-site young child residents as the most sensitive receptor group. The average
time-weighted soil lead concentration was used as the soil concentration in the model. Default values, as
recommended in the model, were used for all other inputs. The outcome of the model revealed that 5.6% of
an exposed population is predicted to have blood lead levels greater than 10 |ig/dl. It is EPA policy to
protect 95% of the sensitive population against blood lead levels in excess of 10 |ig/dl blood. 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 in intake and biokinetics of 1.8 was used in the
model which is typical of populations in small areas dominated by a single source of lead. A typical blood
lead concentration in the absence of site exposures was assumed to be 2.0 |ig/dL, which is a mid-range
default assumption. The outcome of the model revealed that 15.4% of an exposed population is predicted to
have blood lead levels greater than 10 |ig/dl. It is EPA policy to protect 95% of the sensitive population
against blood lead levels in excess of 10 |ig/dl blood. This means that exposures to lead in on-site soil were
estimated to result in an exceedance of the blood lead level goal for a future construction worker and a
future on-site adult and young child resident.
36
-------
ROD RISK WORKSHEET
Table G-8
Risk Characterization Summary - Carcinogens
Scenario Timeframe: Future
Receptor Population: Recreational User
Receptor Age: Young Child/Adult
Medium
Exposure
Medium
Exposure Point
Chemical of
Concern
Carcinogenic Risk
Ingestion
Inhalation
Dermal
External
(Radiation)
Exposure
Routes Total
Surface Water
Surface Water
Site-wide
BenzQ(a5pyrene
BenzQibJfkioranthene
Benzo( k )fluora nthene
Aroclor-1264
-
--
1E-04
1E-0S
4E-06
1E-05
1IE-04
tF-05
4E-06
1E-05
Surface Water Risk Total =
2E-04
Soil
Surface Soil
Combined On-Site
Benzo!a}3nth/acene
Ber\zo|a)pyTene
Benzo{b)fluofantnene
Dibenz(a,h ^anthracene
Dioxin TEQ
Arsenic
Ra-226
U-234
U-235
U-236
3E-06
2E-C5
1E-06
3E-06
2E-05
se-06
2E-05
2E-05
2E-06
SE-05
1E-O6
7E-06
S6-07
1E-06
2E-06
7F.07
1E-04
3E-G8
4E-G6
3E-05
5E4)6
2E-05
26-06
4F-06
3E-Q5
9E-06
1E-04
2E-05
6E-06
1fc-04
Surface Soil Risk Total =
3E-04
Total Risk =
5E-04
Key
- Route of exposure ts not applicable to this medium.
This table provides nsfc estimates tor trie stgnrficant routes of exposure These nsk estimates are based on 3 reasonable maximum exposure and were developed by taking inio account various conservative
assumpiiuns about the frequency and duration of a young child and adult's exposure to surface water arid surface so»l. as well as the toxicity el the COCs (benzo(g iarthracene, bon/r^Opyrene, benzo(b}fiuoranthene,
ben?G(k)fluofi3rithene, dit>eaz(a,h)anthracener dioxm. Arocior-1254, arsenic, Ra-226, Lf-234, U-235, and U-236) The total nsk from direct exposure to contaminated surface water and surface soil at this site to a future
young child/adult recreational user is estimated to be 5 * 10 4. The COCs contributing most to this risk tevei are bervo(a)pyrene in surface water and Ra-226 and U-23fi in surface soil This risk level indicates that if no
clean-up action is taken, an individual would have an increased probabiNty of b in 1 a ,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, 1999)
Page 8 of 16
Tables G-'
¦1
to G-16.xls
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ROD RISK WORKSHEET
Table G-9
Risk Characterization Summary - Carcinogens
Scenario Timeframe: Future
Receptor Population: Resident
Receptor Age: Young Child/Adult
Medium
Exposure
Medium
Exposure Point
Chemical of
Concern
Carcinogenic Risk
Ingestion
Inhalation
Dermal
External
(Radiation)
Exposure
Routes Total
Groundwater
Groundwater
Combined
Benzene
T richloroelhene
Vinyl chloride
Benzo(b)ftuoranthene
Arsenic
U-234
U-235
U-238
4E-Q6
7E-05
1E-C2
2E-06
2E-03
2E-04
1E-05
3E-OS
..
--
..
4 £-06
7E-05
IE -02
21-06
2E-03
2E-04
1E-05
3 £-05
Groundwater Risk Total =
2E-02
Total Risk =
2E-02
Key
- Route of exposure is noi applicable to this medium
This table provides risk estimates for the significant routes of exposure. These risk estimates are based on a reasonable maximum exposure and were developed by taking into account various conservative
assumptions about the frequency and duration of a young child and adult's exposure to groundwater, as well as the toxicity of the COCs (benzsm, trichloroethene, vinyl chonde, benzo(b)fluoranthene, arsenic, U-234,
U-235, and U-238). The total risk Irom direct exposure to contaminated grouridwfer at this site to a future young child.'adult resident is estimated to be 2 x 1 Q"?. The COCs contributing most to this risk level are vinyl
chloride, arsenic, and U-234 in groundwater. This risk level indicates that if no clean-up action is taken, an individual would have an increased probability of 2 in 100 of developing cancer as a result of site-related
exposure to the COCs
Source: A Guide to Preparing Superfund Proposed Plans, Records of Decision, arid Other Remedy Selection Decision Documents (U.S. EPA, 1999)
Page 9 of 16
Tables G-1 to G-16.xls
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ROD RISK WORKSHEET
Table G-10
Risk Characterization Summary - Carcinogens
Scenario Timeframe: Future
Receptor Population: On-SHe Resident
Receptor Age: Young ChiW'Adult
Medium
Exposure
Medium
Exposure Point
Chemical of
Concern
Carcinogenic Risk
Ingestion
Inhalation
Derma)
External
[Radiation)
Exposure
Routes Total
Sal
Surface Soil
On-Siit* Residence
&enzo{a}amhracene
Benzoc
Dioxin TEO
Arsenic
Ra-228
U-234
U-235
u-2m
?E-06
3E-05
2E-06
BE-06
2E-Q6
t>t 05
ifc 06
3E-05
5E-05
3E-06
f£-04
3E-D6
1E-0S
9E-07
2E-06
7E-07
pyf«ne ?E-(H
Be«zo(b)fluorantnea(1,?,3-aJ|pyr^ 2E-0&
Dtoxm TEG 2 £-04
Arsenic 2E-05
Ra-226 2C-05
U-238 <«£-07
--
2E-D5
3E-04
3E-05
1E-06
3E-06
9E-06
2£-m
2tm
1E-03
4F-0G
7E-05
1E-Q3
1E-Q4
3E-Q6
1E-05
3E-C5
3E-04
it us
1E-U3
5E-0G
Subsurface Soil Risk Total *
3E-03
Total Rish =
7E-03
Key
Houie of exposure is not applicable to this medium
T'ii§ idb'»? provides, ns* estimates for the Significant rogi.es of exposure These risk estimate!* a'*? yased or. a reasonable maximum n*p>osure ;wtd wen* developed L-y tekt/tg i-iio account varous
assumptions about Ihft frequency and duration of a young child and adult's exposure to surface and subsurface son. as well as the toxicity o? ihc COCs [b»)tvo(a^nfhfac^n»- bonzo(ajpveoe. bftfi?o{h)Hnoranlhefie.
beazod U-238t The total nsk "on direel exposure lo contaminated surface and subsurface son
-------
ROD RISK WORKSHEET
Table G-11
Risk Characterization Summary - Carcinogens
Scenario Timeframe; Future
Receptor Population: Adjacent Resident
Receptor Age: Young Child/Mult
Medium
Exposure
Medium
Exposure Point
Chemical of
Concern
Carcinogenic Risk
Ingestion
Inhalation
Dermal
External
(Radiation)
Exposure
Routes Total
Sol
Surface Soil
Adjacent ftesktence
Be<<20(a>afTthraceoe
BefiiD(aJp'fTene
Benzo(b )fl uoranthene
Dioeni'iA.h^rithracenc
Dio»n TEQ
Aracrne
Ra-226
U-234
U-235
U-238
3E-06
2E-06
iEoe
3ECC-
2E-05
IE 05
2E-05
2E-0S
2E-06
BE-GS
-
1E-06
7E-06
5E-07
1E-06
?F-06
1E06
te-04
3E-08
4E-06
3E-05
5E-06
2E-0S
2E-06
4E-06
3E-05
1E-05
2E-G4
2E-Q5
6E-06
1E-04
Surface Soil Risk Total *
4E-04
5e
Diosifi TEQ
Arsenic
Ra-226
U-2M
U-2-3S
U-23B
3E-0G
7F-G5
lE-oe
3£«06
2E 05
9E-06
2t 05
2E-05
2E-QR
8E-05
1 E'CKj
7E-0Q
r>F-0T
1E-06
2E-W
aE-07
1E-04
3E-G8
4E-06
3E-05
5E-06
2E-05
2E-06
4E-06
3E-G5
1E05
1E-04
2E-05
SE-06
1E-04
Subsurface Soil Risk Total *
3E04
Tata* Ri*k »
7E-D4
Key
— Route of exposure not applicoMe to this Tieditirr
1 his table provides risk estimates for the significant routes of exposure 1 hese nsk est>ma!es ary based ofi s ryasjU'^Wt manmiim exposure were developed fry taking irilo zcccmrA vanoos ccinscvativfi
assumptions about the frequency and duration of a young chitd and adult's exposure to surface anri Riihsiirt^re soil, as wpM as the: loxioty o! the COCs (honzo^a'^^lhfaccne beni)dfHhracGtw, dioxm. arsenic, Ra-226, U-234, U-235, and U-238) The total ns* from direct exposure lo contaminated surface and subsurface soil al this sUe iu a future yeung child'aduli adjacent resident «
estimated lobe 7 * H?4 The COCs conmoulmg most lo tfus risk leve« are Ra-226 and U-238 ir surtarr ^nd ^ihsur^r.fr soil This risk level .ncir.aiofl thai if no ocia
-------
ROD RISK WORKSHEET
Table G-12
Risk Characterization Summary -
Non-Carcinogens
Scenario Timeframe: Future
Receptor Copulation: Recreational User
Receptor Age: Young Child/Adult
Medium
Exposure
Medium
Exposure Point
Chemical of
Concern
Primary Target
Organ
Non-Carcinogenic Hazard Quotient
Ingestion
Inhalation
Dermal
Exposure
Routes Total
Surface Water
Surface Water
Site-wide
Beryllium
Chromium
Nickel
Gi System
Gl System
General Toxicity
--
IE+00
9E-M30
2E+Q0
3E+00
SE+00
2E+00
Surface Water Hazard Index Total =
!E+01
Sediment!
Sediment
Srte-wide
Arcx;lnf 1254
Immune System
3E-r0O
--
IE+00
4EKX)
Sediment Hazard Index Total =
4E+O0
Soil
Surface Soil
Combined On-Site
Nickel
Genera! Toxicity
2E»00
--
N/A
2E-HX)
Uranium, total
Kidney
4E+Q0
N/A
4E+00
Soil Hazard Index Total -
ee+oo
Receptor Hazard Index =
2E*01
Genera) Toxicity Hazard Index *
4E+00
G! System Hazard Index =
1£*01
Immune System Hazard Index =
4E+00
Kidney Hazard Index =
4E+00
Key
N/A - Toxicity criteria are riot available to quantitatively address this route of exposure
- Route of exposure ts not applicable to this medium.
This table provides hazard quotients (HQs) for each route of exposure and the hazard index (sum of the hazard quotients) for all routes of exposure The Risk Assessment Guidance (RAGS) for Superfund states that,
generally, a hazard index (HI) of greater than i indictes the potential tor adverse noncancer effects The estimated Hi of 4 indicates that the potential for adverse noncancer effects could occur from exposure to
contaminated surface water containing beryllium, chromium, and nickel, sediment containing Aroclor-1254, and surface soil containing nickel and uranium
Source: A Guide to Preparing Superfund Proposed Plans, Records of Decision, and Other Remedy Selection Decision Documents (U.S. EPA, 1999}
Page 12 of 16
Tables G-1 to G-16.xls
-------
ROD RISK WORKSHEET
Table G-13
Risk Characterization Summary
Non-Carcinogens
Scenario Timeframe: Future
Receptor Population: Resident
Receptor Age: Young Child/Adult
Medium
Exposure
Exposure Point
Chemical of
Primary Target
Non-Carcinogenic Hazard Quotient
Medium
Concern
Organ
Ingestion
Inhalation
Dermal
Exposure
Routes Total
Groundwater
Groundwater
Combined
as-1,2-DiChloroeihene
Blood
5E+Q1
SE+Ol
Tnchloroelhene
Liver
3E+Q0
SE+OO
Vinyl chloride
liver
2E+01
-•
2E+01
Arsemc
Skin
2E*Q1
2E+Q1
Barium
Cardiovascular
5E+00
5E+0G
Beryllium
Gl System
4E+00
-•
4E+00
Cadmium
Kidney
1E+01
•-
1E+01
Chromium
Gl System
6E+00
--
6E+00
Manganese
Nervous System
7E+Q1
-
7E+Q1
Nickei
General Toxicity
7E+01
--
7E+01
Zinc
Blood
5E-0Q
5E+00
Groundwater Hazard Index Total *
3E+G2
Receptor Hazard Index *
3E+02
Blood Hazard Index =
5E+-01
Cardiovascular Hazard Index =
5E*0O
General Toxicity Hazard index -
TE+01
Gl System Hazard index =
1E+01
Kidney Hazard index -
1E+01
Liver Hazard index =
2E+01
Nervous System Hazard Index =
Ot
Skin Hazard Index =
2E+01
Kty
N/A - Toxicity cuteria are no! available to Quantitatively address this route of exposure.
- Route erf exposure is noi applicable to this medium.
This table provides hazard quotients- (HQs) for each route of expesye and the hazard rnde* (sum of tne hazard quotients) for all routes of exposure. The Rjsk Assessment Guidance (RAGS] for Superfund states
that, genera«y. a hazaro index (Hi} of greater Ehan I sncictes the potential advene nnnennrrer effects The estimated HI of 30Q indicates that the potential for adverse noncancer ejects could occur from exposure
la corifaminated groundwater containing ci^i ,2-dictvoioethene, ticihloraelhene, vinyf chloride. arsenic, banum, beryllium, cadmium. cHfoinum, manganese. nickel and zinc
Source: A Quids to Preparing Superfund Proposed Plans, Records of Decision, and Other Remedy Selection Decision Documents (U.S. EPA, 1999)
Page 13 of 16 Tables G-1 to G-I6.xls
-------
ROD RISK WORKSHEET
Table G-14
Risk Characterization Summary -
Non-Carcinogens
Scenario Timeframe: Future
Receptor Population: On-Site Resident
Receptor Age: Young Child/Adult
Medium
Exposure
Medium
Exposure Point
Chemical of
Concern
Primary Target
Organ
Non-Carcinogenic Hazard Quotient
Ingestion
Inhalation
Dermal
Exposure
Routes Total
Soil
Surface Soit
On-Site Residence
Nickel
General Toxicity
4E+00
--
N/A
4E*00
Uranium, total
Kidney
7E+Q0
--
N/A
7E+GQ
Surface Soil Hazard Index Total =
1E*01
Soil
Subsurface Soil
On-Site Residence
Chromium
Mercury
Nickel
Gl System
Nervous System
General Toxicity
5E+00
2E+Q0
1E+01
--
N/A
N/A
N/A
BE-i-OO
2E»00
1E*01
Subsurface Soil Hazard Index Total =
2E+01
Receptor Hazard Index =
3E+01
General Toxicity Hazard Index =
1E+01
Gl System Hazard Index =
5E+0Q
Nervous System Hazard Index =
2E+00
Kidney Hazard Index =
7E«-00
Key
N/A - Toxicity criteria are not available to quantitatively address this route of exposure
- Route of exposure is not applicable to this medium.
This table provides hazard quotients (HQs) for each route of exposure and the hazard index (sum of the hazard quotients) for all routes of exposure. The Risk Assessment Guidance (RAGS) lor Superfund states
that, generally, a hazard index (HI) of greater than 1 indictes the potential for adverse noncancer effects The estimated Hi of 30 indicates that !he potential for adverse noncancer effects could occur from exposure
to contaminated surface soil containing nickel and uranium and subsurface soil contarrung chromium, mercury, and nickel
Source: A Guide to Preparing Superfund Proposed Plans, Records of Decision, and Other Remedy Selection Decision Documents (U.S. EPA, 1999}
Page 14 of 16
Tables G-1 to G-16.xls
-------
ROD RISK WORKSHEET
Table G-15
Risk Characterization Summary -
Non-Carcinogens
Scenario Timeframe: Future
Receptor Population: Adjacent Resident
Receptor Age: Young Child/Adult
Medium
Exposure
Medium
Exposure Point
Chemical of
Concern
Primary Target
Organ
Non-Carcinogenic Hazard Quotient
Ingestion
Inhalation
Dermal
Exposure Routes
Total
Soil
Surface Soil
Adjacent Residence
Nickel
General Toxicity
2E+00
--
N/A
2E+00
Uranium, total
Kidney
4E+00
--
N/A
4E+00
Surface Soil Hazard Index Total =
6E+00
Soil
Subsurface Soil
Adjacent Residence
Nickel
General Toxicity
2E+00
--
N/A
2E+00
Uranium, total
Kidney
4E+QQ
--
N/A
4E+00
Subsurface Soil Hazard Index Total =
6E+0Q
Receptor Hazard Index =
1E+01
General Toxicity Hazard Index =
4E+00
Kidney Hazard Index =
7E+00
Key
N/A - Toxicity criteria are not available to quantitatively address this route of exposure
- Route of exposure is not applicable to this medium.
This table provides hazard quotients (HQs) tor each route of exposure and the hazard index (sum of the hazard Quotients) for ail routes of exposure. The Risk Assessment Guidance (RAGS) for Superfund states
that, generally, a hazard index (HI) of greater than 1 indictes the potential for adverse noneancer effects. The estimated Hi of 10 indicates that the potential for adverse noncancer effects could occur from exposure
to contaminated surface and subsurface soil containing nickel and uranium.
Source: A Guide to Preparing Super-fund Proposed Plans, Records of Decision, and Other Remedy Selection Decision Documents (U.S. EPA, 1999)
Page15of16 Tables G-1 to G-16.xis
-------
Uncertainties
Estimation of risks to human health that may result from exposure to chemicals and radionuclides at the Site
is a complex process. Each assumption, whether regarding the toxicity value to use for a particular COPC or
the value of a parameter in an exposure equation, has a degree of variability and uncertainty associated with
it. In each step of the risk assessment process, beginning with the data collection and analysis and
continuing through the toxicity assessment, exposure assessment, and risk characterization, conservative
assumptions are made that are intended to be protective of human health and to ensure that risks are not
underestimated. The following provides a discussion of the key 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. Because of this assumption, historical and
recently collected sampling data were combined allowing for the use of a more robust data set.
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.
However, the natural decay of radionuclides to short-lived decay products was factored into the risk
estimates through the use of toxicity values that include these decay products. COCs currently undergoing
re-evaluation for carcinogenic potency include dioxin and trichloroethene. An interim revised cancer slope
factor for dioxin indicates that the cancer risk associated with dioxin exposure may be as much as 6.2 times
greater than the risks estimated in this risk assessment. Estimates of carcinogenic potency for
trichloroethene range over nearly two orders of magnitude. The high-end of the range of oral slope factors
and unit risk values was used for carcinogenic risk estimation. Therefore, carcinogenic risks for
trichloroethene may have been overestimated.
The bioavailability of COPCs by the oral exposure route through the ingestion of soil and sediment is
uncertain. The animal bioassays on which the toxicity values are based do not involve feeding of chemicals
in a soil/sediment matrix. Oral absorption of chemicals from soil/sediment may be diminished due to the
matrix effect, particularly for inorganics that may be a component of the mineral structure of these media
and, thus, not available for uptake. This may have resulted in an overestimation of inorganic risks.
For dermal exposure pathways, the absence of dermal toxicity criteria necessitated the use of oral toxicity
data. To calculate risk estimates for the dermal pathway, absolute oral bioavailability factors that reflect the
toxicity study conditions were used to modify the oral toxicity criteria. For the chemicals with oral
absorption exceeding 50% (e.g., the PAHs), a default oral absorption factor of 100% was used. The risk
estimates for the dermal pathways may be over- or underestimated depending on how closely these values
reflect the difference between the oral and dermal routes.
Reasonable Maximum Exposure (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., soil ingestion rates) or body
weights. Therefore, exposures and estimated risks are likely to be overestimated.
In a limited number of cases, a small number of environmental samples were collected resulting in the use
of the maximum detected level of a COPC as the RME EPC. Use of the maximum detected result instead of
the 95% UCL value for the RME EPC results in an overestimate of risk.
For groundwater, maximum detected COPC concentrations were used as the RME EPCs, as prescribed by
EPA guidance. This assumption is protective of worst-case groundwater exposures that may occur during
future pumping events. Because the maximum detected groundwater concentrations are not co-located at
45
-------
ROD RISK WORKSHEET
Table G-16
Risk Characterization Summary -
Non-Carcinogens
Scenario Timeframe; Future
Receptor Population: Construction Worker
Receptor Age: Adult
Medium
Exposure
Exposure Point
Chemical of
Primary Target
Non-Carcinogenic Hazard Quotient
Medium
Concern
Organ
Ingestion
Inhalation
Dermal
Exposure
Routes Total
Soil
Subsurface Soil
Combined On-Site
Nickel
General Toxicity
2E+00
N/A
2E+00
Subsurface Soil Hazard index Total =
2E+00
Receptor Hazard Index -
2E+0Q
General Toxicity Hazard Index =
2E*0O
Key
N/A - Toxicity criteria are not available to quantitatively address this route of exposure
- Route of exposure is not applicable to this medium.
This table provides hazard quotients (HQs) lor each route of exposure and the hazard index (sum of the hazard quotients) for all routes of exposure. The Risk Assessment Guidance (RAGS) for Superfund states that.
generally, a hazard index (HI) of greater than 1 irsdictes the potential tor adverse twieancer effects. The estimated HI of 2 indicates that the potential for adverse noncancer effects could occur from exposure to
contaminated subsurface soil containing nickei
Source: A Guide to Preparing Superfund Proposed Plans, Records of Decision, and Other Remedy Selection Decision Documents (U.S. EPA, 1999)
Page 16 of 16
Tables G-1 to G-16.xls
-------
this site, it is unlikely that the installation of a well would result in exposure to maximum detected
concentrations of each groundwater COPC. Therefore, this approach likely results in an overestimate of
risk.
2. Ecological Risk Assessment
An ecological risk assessment (ERA) was completed for the Shpack Landfill Superfund Site to evaluate the
likelihood and magnitude of potential ecological effects associated with historical disposal practices. The
ERA evaluated the potential for contaminants in soil, surface water, and sediment to impact ecological
receptor populations within six distinct exposure areas: the Tongue Area, combined field and shrubland,
onsite seasonal wetlands, hardwood forest, Chartley Swamp, and Chartley Pond. See Figure 4.
In accordance with EPA policy, a screening level ecological risk assessment (SLERA) can be sufficient to
document risk in areas where a known remedy will be implemented when risk is driven by other factors,
such as another risk assessment. Based on the feasibility study, which incorporates the human health risk
assessment for the Shpack site, it was determined that remediation at the Tongue Area and the combined
field and shrubland would require some action to take place, such as capping under the original proposed
plan. As a result, additional evaluation of ecological risk within these two exposure areas was not thought to
be necessary since risk associated with potential exposure to ecological receptors was to have been
eliminated. Therefore, evaluations associated with the Tongue Area and the combined field and shrubland
were not included in the BERA.
Because the selected remedy does not in fact cap the Combined Field and Shrubland habitat, an assessment
of ecological risk posed by soil in the Combined Field and Shrubland habitat (Figure 4) of the site will be
performed utilizing food chain models developed to evaluate receptor risk from soil in other areas of the site
following 1997 EPA Superfund ecological risk assessment guidance. This evaluation will be limited to
those areas which are not being excavated due to human health risk.
Evaluations associated with Chartley Pond are not included in the ROD because no risk was identified in
Chartley Pond in the SLERA. Because radiation standards for human populations will also protect
populations of non-human biota, risk from radiological effects were covered by the human health risk
assessment and were not evaluated in the ERA.
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 each medium and within each
exposure area. Data used to identify COCs are summarized below in Table G-17 (hardwood forest), Table
G-18 and Table G-19 (Chartley Swamp), and Table G-20 and Table G-21 (onsite seasonal wetlands).
Exposure Assessment
The hardwood forest provides habitat for a variety of terrestrial receptors, including small mammals and
terrestrial songbirds. Chartley Swamp provides habitat for aquatic and semi-aquatic mammals, waterfowl,
bottom dwelling fish, and benthic invertebrates. When inundated, the onsite seasonal wetlands provide
habitat for wetland songbirds and benthic invertebrates, and when dry provide habitat for small terrestrial
mammals. The onsite seasonal wetlands also provide habitat for the spotted turtle (Clemmys guttata), a
species of special concern in Massachusetts.
47
-------
Terrestrial receptors may accumulate COCs through consumption of contaminated prey and incidental soil
ingestion. Aquatic and semi-aquatic receptors may be exposed to COCs through ingestion of contaminated
prey, sediment, and surface water. Exposure pathways, assessment endpoints, and measurement endpoints
are summarized below in Table G-22 (hardwood forest). Table G-23 (Chartley Swamp), and Table G-24
(onsite seasonal wetlands).
Potential risk from COCs to assessment populations was estimated using dietary exposure models. Because
site-specific tissue data were not available, doses were modeled from soil, sediment, and surface water
concentrations. To assist in exposure estimation for small terrestrial mammals and songbirds, COC
concentrations in prey (earthworms) were modeled directly from COC concentrations in soil. To assist in
exposure estimation for semi-aquatic mammals, waterfowl, and marsh wren, COC concentrations in prey
(oligocheates) were modeled directly from COC concentrations in sediment. COC concentrations in dietary
vegetation were also modeled to assist exposure estimation for these five indicator species. Risk to bottom
dwelling fish was evaluated by modeling tissue concentrations from measured sediment concentrations.
Risk to benthic invertebrates was evaluated by comparing sediment concentrations to sediment ecological
benchmarks.
Short-tailed shrew (Blarina brevicauda), representing small mammals, and American robin (Turdus
migratorius), representing songbirds, were selected as assessment populations to evaluate risks associated
with exposure to COCs in hardwood forest soil. Muskrat {Ondatra zibethicus), representing semi-aquatic
mammals, and mallards (Anasplatyrhynchos), representing waterfowl, were selected as assessment
populations to evaluate risks associated with exposure to COCs in Chartley Swamp sediment and surface
water. In addition, risk to fish, represented by brown bullhead (Ameiurus nebulosus}, and risk to benthic
invertebrates, were also evaluated in Chartley Swamp. Short-tailed shrew {Blarina brevicauda),
representing small mammals, and marsh wren {Cistothoruspalitstris), representing wetland songbirds were
selected as assessment populations to evaluate risks associated with exposure to COCs in onsite seasonal
wetland sediment and surface water. In addition, risk to benthic invertebrates was also evaluated in the
onsite seasonal wetlands.
For each assessment population, an average exposure case and a maximum exposure case were calculated.
The average case was an exposure model based on (arithmetic) mean COC concentrations. The maximum
exposure case was an exposure model based on the upper confidence limit (UCL) of COC concentrations.
Chartley Swamp was assessed for three exposure scenarios: the inner rung, outer rung, and site-wide
scenario. See Figure 5 for the approximate location of the inner and outer rung of Chartley Swamp. The
distinction was based on apparent geographic differences in contaminant concentrations. The inner rung is
an area of Chartley Swamp which lies adjacent to the highly contaminated Tongue Area, where COC
concentrations were as much as three orders of magnitude higher than the concentrations at sediment
locations in the rest of Chartley Swamp. The area of Chartley Swamp which is not part of the inner rung
comprises the outer rung. The inner rung and outer rung combine to form the site-wide scenario. In the
hardwood forest and the onsite seasonal wetlands, concentrations of COCs in sediments were relatively
uniform, so these exposure areas were not divided into separate sub-areas.
48
-------
TABLE G-17
SOIL CO PC SCREENING
FOREST
Shpack Superfund Site
Norton, Attlehoru, MA
Maximum
Frequency
Noil
Ecological Soil
Source of
of
Concentration
Screening Level
Kcological
Hazard
Analyle
Detection
mg/kg
mg.'kg
Screening Level
cot:?
Reason
Quotient
VOCs (mg/kg)
1,1 -Dichloroelherse
0/ 10
< 0.016
23.5
Mammal
No
Below benchmark
0.0
1,2-Dichloroethene (total)
1 / 6
< 0,016
No SI.
NA
Yes
.No SI.
NA
2-Butartone
o; in
< 0.016
6,487
Mammal
No
Below benchmark
0.0
Acetone
1 10
0.0225
36.6
Mammal
No
Belov, benchmark
0.0
Carbon Disulfide
0/ 1(1
< 0.016
No SI.
NA
Yes
No SL
NA
c is- 1,2-Dich loroctbene
0/4
< 0.008
No SL
NA
Yes
No SI.
NA
Methyl Acetate
0/4
< 0.008
No SL
NA
Yes
No SI.
NA
Tetrachloroethenc
0; 10
< 0.016
2.27
Mammal
No
Below benchmark
0.0
Toluene
0 / 10
< 0.016
51.5
Mammal
¦ No
Below benchmark
0.0
trans-1,2-Uichlorocchene
0/4
< 0.008
No SL
NA
Yes
No SL
NA
Trichloroethctie
0-' 10
< 0.016
1.387
Mammal
No
Below benchmark
0.0
Trichlnroftuoromethane
0/4
< 0.008
No SL
NA
Yes
No SL
NA
Vinyl Chloride
0.' 10
< 0.016
0.0623
Mammal
No
Below benchmark
0.3
SVOCs (mg/kg)
Ll'-Riphenyl
0/4
< 0.37
60
Phyto
No
Below benchmark
0.0
2-MethylnaphlhaIene
0; 10
< 0.52
No SI.
NA
Yes
No SI.
NA
4-Methylphenol
0 / 10
< 0.52
No SL
NA
Yes
No SL
NA
Acenaphthene
0 .< 10
< 0.52
20
Phyto
No
Below benchmark
0.0
Acenaphthylene
1 i 10
0.006
So SI.
NA
Yes
No SL
NA
Anthracene
1 / 10
0.004
No Sl.
NA
Yes
No SL
NA
Benzaldchyde
1 / 4
0.048
No SL
NA
Yes
No SL
NA
Benzo{a)anthracene
0/ 10
< 0 52
So SL
.NA
Yes
No SL
NA
Renzo(a)pyrcne
1 / 10
0.009
1.98
Mammal
No
Below benehnmik
0 0
Renzo(b)fluoraMhene
3/ 10
0.041
No SL
NA
Yes
No SL
NA
Ben g.h, i )pery 1 en e
0/ 10
< 0.52
No St.
NA
Yes
No SL
NA
Benzo(k)fluoranthene
2 / 10
0.037
No SL
NA
Yes
No SL
NA
bis(2-l:thylhexyl)phtha!atc
2 ' 10
0.11
0.91
Avian
No
Below benchmark
0.1
Carbazole
0.' 10
< 0.52
No SL
NA
Y'es
No SL
NA
Chryserie
310
0.047
No SI.
NA
Yes
No SL
NA
Dibenz(a,h)anthracene
o.' 10
< 0.52
No SL
NA
Yes
No SL
NA
Dibenzot'uran
0 10
< 0.52
No SI.
NA
Y'es
No SL
NA
Diethyl phthalate
0.' 10
< 0.52
100
Phyto
No
Below benchmark
0.0
Di-n-butylphthalate
0 ¦ 10
< 0.52
0.09
Avian
Y'es
Exceeds benchmark'
5.S
Di -n-octylphthalate
1 10
0.041
No SL
NA
Y'es
No SL
NA
FJuorantbcne
5/ 10
< 0.52
No SL
NA
Y'es
No SL
NA
Fluorene
0/ 10
< 0.52
30
Earthworm
No
Below benchmark
0 0
]ndeno{ 1,2,3 i.:i)pwenc
0. 10
< 0.52
No SI
NA
Y'es
No SL
NA
Naphthalene
0/ 10
< 0.52
No SL
NA
Yes
No SL
NA
Phenanthreiu"
4/ 10
< 0.52
No SI.
NA
Yes
No SL
NA
Phenol
0/ 10
< 0 52
30
Harthworm
No
Belo« benchmark
0.0
Pyrene
5/ 10
< 0.52
No SL
NA
Yes
No SL
NA
PCBs/Pesticidcs (mg/kg)
4,4'-DDD
0/ 10
< 0.0057
0.002
Avian
Yes
Bioaccumulutes'1
2.9
4,4'-DDE
4/ 10
0.003
0.002
Avian
Y'es
Bioaccumulatcs
1.5
4.4'-DP'l
3 / 10
0.0054
0.002
Avian
Yes
Bioaccumulatcs
l 7
Aldnn
0' 10
< 0.0029
0.733
Mammal
Yes
Bioaccumulutes
D.O
alpha-BHC
o.' 10
< 0.0029
No SI.
NA
Yes
Bioaccurnuliites
NA
alpha-Chlordane
0/ 10
< 0.0029
1.8
Avian
Yes
Bioaccumulatcs
u.u
Aroclor-124S
1 / 10
0.064
0.071
Mammal
Yes
Bioaccumulatcs
El. V
Aroclor-1254
0.- 10
< 0.057
0.111
Mammal
Yes
Bioaccumulatcs
0 5
Aroc lor-1260
3 / 10
0.046
40
Phyto
Yes
Bioaccumulaies
U U
Dieldnn
1 ' 10
0.00079
0.064
Avian
Yes
Bioaccumulatcs
U.U
Endosulfan I
0 10
< 0.0029
0.S5
Mammal
Yes
Bioaccumulatcs
0.0
Lndosulfan sulfate
1 / 10
0.0017
0.55
Mammal
Yes
Bioaccumulatcs
0 0
Fndrin
0 / 10
< 0.00S7
0.008
Avian
Yes
Bioaccumulatcs
0.7
Endrin aldehyde
0/ 10
< 0.0057
No SL
NA
Y'es
Bioaccumulatcs
NA
Endrin ketone
0/ 10
< 0.0057
No SI.
NA
Y'es
Rioaccumulates
NA
gamma-C'hlordane
Of 10
< 0.0029
No SL
NA
Y'es
Oioaccumulates
NA
Heptachlor epoxide
0.- 10
< 0.0029
No SI.
NA
Yes
Bioaccumulatcs
NA
Methosvchlor
0,' 10
< 0.029
14.7
Mammal
Y'es
Bioaccumulates
0,0
1 of 10
-------
TABLE G-17
SOIL COPC SCREENING
FORKS!
Shpack Superfund Site
Norton, Attlehoro, MA
Maximum
Frequency
Soil
Ecological Soil
Source of
of
Concentration
Screening Level
Leo logical
Hazard
Aiialyle
Detection
ms/kg
mg/kR
Screening Level
toe?
Reason
Quotient
Metals (mg/kg)
Aluminum
11/11
2231)0
3.X25
Mammal
Yes
Exceeds benchmark
5830.1
Antimony
0/11
< 4.9
0.248
Mammal
Yes
Exceeds benchmark*
19 X
Arsenic
11 / SI
10,2
0.25
Mammal
Yes
Exceeds benchmark
40.8
Barium
11, 11
356
17.2
Avian
Yes
Exceeds benchmark
20.7
Beryllium
10/ 11
CI.48
2.42
Mammal
No
Below benchmark
(1.2
Cadmium
4/11
0.35
1.2
Avian
No
Below benchmark
0.3
Calcium
11/11
2220
NA
Nutrient
No
Nutrient
NA
Chromium
11/11
17
0.4
Earthworm
Yes
Exceeds benchmark
42.5
Cobalt
6/11
6
20
Phyto
No
Below benchmark
0.3
Copper
9/11
26.9
38.9
Avian
No
Below benchmark
0.7
Cyanide
0/11
< 5.4
236.5
Mammal
No
Below, benchmark
0,0
Iron
11/11
20900
No SL
NA
Yes
No SI,
NA
Lead
11/11
73
0.94
Avian
Yes
Exceeds benchmark
'V ?
Magnesium
11/11
2220
NA
Nutrient
No
Nutriem
N'A
Manganese
11 / 11
302
322
Mammal
No
Below benchmark
0.9
Mercury
1/11
0.052
0.1
Earthworm
No
Below benchmark
0.5
Nickel
11/11
37.7
30
Phyto
Yes
Exceeds benchmark
13
Potassium
9/11
< 604
NA
Nutrient
No
Belriw benchmark
NA
Selenium
5/11
2.5
0.331
Avian
Yes
Exceeds benchmark
7.6
Silver
4 / 11
1.3
2
Phyto
No
Below benchmark
0.7
Sodium
7/11
137
NA
Nutrient
No
Nutrient
\A
Thallium
1 / 11
0 087
0.027
Mammal
Yes
Exceeds benchmark
3 2
Uranium, iota!
4/4
2.0
5
Phylo
No
Below benchmark
0,5
Vanadium
11/11
28.7
0.714
Mammal
Yes
Exceeds benchmark
'4)2
Zinc
11/11
68.9
12
Mammal
Yes
Exceeds benchmark
5.7
a. Hazard quotient > 1 but based on maximum detection limit
No SL - No screening level available
"<" - Indicates maximum detection limit.
NA - Not applicable
GOC - Coritmiminl of Concern
Sources;
Mammal - NOACL-based benchmark far food ingestion from Sample el al, 1996
Avian - NOALL-based benchmark for food ingestion from Sample et al, 1996
Earihworm - h'froyrnson ct al, (1997a)
Phyto - Ffroymson et al. (1997b)
2 of 10
-------
TABI.K C-18
SEDIMENT CQPC SCREENING
CHAKII.KV SWAMP
Shpack Superfund Site
Norton, Attleboro, MA
Maximum
Ecological
Freq uenc>
Sediment
Sediment
Source of
of
Concentration
Screening Level1
F.colngical
Ha/.arri
Analvte
Detection
mg/kg
Screening Level
COC?
Keasmi
Quotient
VOCs (m&kg)
1, ]-QicMoroefhene
0 6
< 0.02
No SI.
NA
Yes
No SI.
NA
1,2-Dichloroechene (tola!)
0 > 6
<¦ 0.02
No SI.
NA
Yes
No SL
NA
2-Butanone
0 /O
< 0 02
No SL
NA
Yes
No SL
NA
Acetone
I ' l
1 / 6
0.1)8?
No SL
NA
Yes
No SL
NA
Pyrene
6.' 6
002?
0,66
F.R-L
No
Below benchiruirk
n04
PCBs/Pesikidfs (mg/kg)
W.4-DDD
0/6
< 0.006
0.002
ER-L
Yes
Btoaccwnulates'
3.0
4.4'-DDE
0' 6
< 0,006
0.0022
ER-L
Yes
Bioaccumulates1
2.7
4,4'-DDT
I 6
0.0024
C 00158
ER-L
Yes
Bioaccumulates
1,5
Aldrm
0' 6
< 0,0031
0.016210111
OMOE-Low
Yes
Bioaccumulates
0,2
alpha-BHC
0; 6
< 0.0031
0,048630233
OMOE-Low
Yes
Bioaccumulates
0.1
lalpha-Chlordane
0.' 6
<¦" 0,0031
0.0005
ER-L
Yes
Bioaecumulates
6.2
jAioclor-1248
0/6
< 0,06
0.243 1S1067
OMOE-Low
Yes
Bioaccuniulatcs
0.2
lAroclor-1254
0/6
< 0,06
0.486303333
OMOE-Uw
Yes
Bioaccuniulatcs
0.1
Arodor-1260
0-'6
0,06
0.040525278
OMOE-Low
Yes
Bioaccumulates'
L>
Dieldrin
0/6
< 0,006
0,42146288*
SQC
Yes
Bioaccuniulatcs
0,01
Hiidosiilfan 11
0/6
< 0.006
0.113470778
SQB
Yes
Bioaccumulates
0,1
ibiidttsulfan sulfate
0-' 6
0.006
No SL
NA
Yes
Bioaccumulates
NA
lEjidrin
0/6
<- 0.006
0.162101111
SQC
Yes
Bioaccumulates
0.04
[Ondnn aldehyde
0> 6
C 0.006
NoSL
NA
Yes
Bioaccumulates
NA
SEiidrin ketone
0; 6
<' 0,006
No SI.
NA
Yes
Bioaccumulates
NA
Jgiimnia • ("hlordane
0.' 6
' 0.0031
0.0U03
ER-L
Yes
Bioaccuniulatcs
6,2
IE leptachlgr epoxide
0/ 6
< 0.0031
0.04052527"!
OMOE-Low
Yes
Bioaccumulates
0,1
IMethoxychlnr
0/ 6
< 0,03 J
0.153996056
SQB
Yes
Bioaccumulates
0.2
3 or 10
-------
TABLE CM*
SEDIMENT COPC SCREENING
CHARTLEY SWAMP
Shpack Superfund Site
Norton, Attleboro, MA
Maximum
Ecological
Frequency
Sediment
Sediment
Source of
of
Concentration
Screening Level*
Ecological
Hazard
Analyte
Detection
¦ng/kg
mg/kg
Screening Level
COC?
Reason
Quotient
Metals (mg/kg)
Aluminum
13 / 13
16,800
No SI.
NA
Yes
No SL
NA
Antimony
6:13
< 6.3
2
BR-L
Yci
Exceeds benchmark
3.4
Arsenrc
13 13
38
8.2
BR-L
Yes
Exceeds benchmark
4, If?
Barium
13- 13
61.2
No SL
NA
Yes
No SL
NA
Beryllium
12 - 13
9S.S
No 51.
NA
Yes
No SL
NA
Cadmium
6/13
82.1
1.2
Ek-L
Yes
Exceeds benchmark
5H.4
Calcium
13' 13
6,960
Nutnenl
NA
No
Nument
NA
Chromium
13 ' LI
1.380
81
ER-L
Yes
Exceeds benchmark
17.0
Cobalt
11 / 13
432
No SL
NA
Yes
No SL
NA
Copper
8/13
553
34
ER-L
Yes
Exceeds benchmark
16.3
Cyanide
1 / 13
< 7.5
No SL
NA
Yes
No SL
NA
Iron
13 , 13
48,400
20,000
OMOh-I .mv
Yes
Exceeds benchmark
2 4
Lead
13 13
134
46.7
ER-L
Yes
Exceeds benchmark
2.9
Magnesium
13' 13
2,400
Nutrient
NA
No
Nutrient
NA
Manganese
13 / 13
276
460
(J\10E-Lo'.v
No
Below benchmark
0 0
M ercLtry
4 - 13
4.4
0.15
ER-L
Yes
Exceeds benchmark
29.3
Nickel
13 / H
26.200
20.9
ER-L
YCS
Exceeds benchmark
1253.6
Potassium
12 • 13
659
Nutrient
NA
No
Nulrient
NA
Selenium
8 13
3 3
No SL
NA
Yes
No SL
NA
Silver
6 13
148
1
ER-L
Yes
Exceeds benchmark
14.*
Sodium
(3 ' t .1
173
Nutrient
NA
Nt>
Nulrient
Na
Thal1iu.ni
4/ 13
< 0,7?
No SL
NA
Yes
No SL
NA
Uranium. total
7 / ?
£;,$
No SL
NA
Yes
No SL
NA
Vanadium
13 ^ 13
127
No SL
NA
YCs
No SL
NA
Zinc
13/13
20.800
150
ER-L
Yes
Exceeds benchmark
13d 7
a. SQB. SQC, and OMOb-Lnw benchmark values (organic* only) have been adjusted for a TOO of 8,1%.
b Hazard quotient > I but based on maximum detection limit.
No SI. - No screening level available
" - Indicates maximum detection limit
NA - Nol applicable
COC - Ccntmmant of Concern
Sources in Order of Preference:
SQC - Sediment Quality Criteria. USEPA (1996) ECO Update, Leotoxu Thresholds. Imenniuenl Bulletin Vol 3, No 2.
SQB - Sediment Quality Benchmarks. USEPA (1996) ECO Update, Ecotox Thresholds Intermittent Bulletin Vol 3. No 2
ER-L - NOAA Effects Range-Low, Long el al. | I995S as cited in in J ores, Suiter & Hull (1997)
OMOE-Low - Ontario Ministry of the Environment-Low, Persaud. et al (1993) as cited in Jones, Sutter & Hull (1997)
TEL • Threshold T-iTects Levels. MacDonald < 1994) as cited in Jones. Sutter & Hull (1997)
4 »f 10
-------
TABLE G-19
SURFACE WATER COPC SCREENING
( HARTLEY SWAMP
Shpatk Superfund Sits
Norton, Allliboro, MA
Maximum
Ecological
Frequency
Surface Water
Surfatc Water
Source of
of
CoriceiiEratitm
Screening 1 t-vi-l*
Feological
Hazard
AnaJyte
Detection
(Ug/1.>
(ugflL)
Screening Level
toe?
Reason
Quotient
VOCs (ug/L)
1.1-DichloroechL'ne
0/4
< 10
25
scv
No
Below benchmark
0.4
1,2- Dichloroetht'itt: (lolal)
0 ;4
< 10
590
scv
No
Below benchmark
0.02
2-Bulanonc
0 4
< 10
14,000
scv
No
Below benchmark
0 00 i
Acetone
1 i 4
7
1,500
scv
No
Below benchmark
0.005
Carbon Disulfide
0/4
< 10
0.92
scv
Yes
Exceeds benchmark1'
10-0
Tetrachlorocthene
0'4
< 10
120
F.T-Tior 11
No
Below benchmark
0.:
Toluene
0/4
< 10
130
ET-Tier II
No
Below benchmark
O.l
Iran s -1,2 - Di ch 1 u roe the ne
0:4
10
5fl0
SCV
Nu
Beluw benchmark
0.02
Tnchloroethcnc
0/4
< 10
35!)
FT-Tier II
No
Below benchmark
0.03
Vinyl Chloride
0/4
< 10
No SI.
NA
Yes
No SL
NA
SVOCs (ug/L)
2-Methylnaphthal ene
0/4
< 10
No SJ.
NA
Yes
No SL
NA
4-Melhylphcnol
0/4
< 10
No SI.
NA
Yes
No SL
NA
AccnapMliene
0/4
< 10
Nu SI.
NA
Yes
No SL
NA
Aeenaphthylcne
0/4
< 10
No SI.
NA
Yes
No SL
NA
Anihracene
0/ 4
< 10
0.73
SCV
Yes
Exceeds benchmark
13 7
Bcnzo(a)aruhrai:enc
0/4
< 10
0.027
SCV
Yes
Exceeds benchmark
370.4
BeTi2o(a)pyrcne
0 4
< 10
0 014
ET-Tier 11
Yes
Exceeds benchmark
714.3
Ben/o(b)nuoran(henc
0 4
< 10
NoSL
NA
Yes
No SL
NA
Benzo(g,h,i)pctylenc
0 / 4
< 10
No SI,
NA
Yes
NoSL
NA
Benzo(k) tl uoranthene
0'4
< 10
No SI.
NA
Yes
NoSL
NA
bi s{2 - E thylhex y 1 )ph!halale
0 -4
< 10
32
II ll.T 11
No
Below benchmark
0.3
Carhazole
0 ' 4
< 10
Nci SI.
NA
Yes
NoSL
NA
Chrysene
0-4
< 10
No SI.
NA
Yes
No SL
NA
Dibcnz( a,h)anthraccne
0/4
•• 10
No SJ
NA
Ye>
No SL
NA
Dibenzofuran
0/4
< 10
20
ET-Tier 11
No
Below- benchmark
0.5
Dielhylphthulate
0/4
< 10
220
III i
-------
TABLE G-19
SURFACE WATER COK: SCRFEMM.;
CHAKTLEY SWAMP
Shpack Superfund Site
Norton, Attfcboro, MA
Maximum
Ecological
Frequency
Surface Water
Surface Water
Source of
of
Concentration
Screening Level*
Ecologtcal
Hazard
Analvtc
Detection
(ug/L)
(ug/I.)
Screening Level
coc?
Reason
Quotient
Metals (ug/L)
Aluminum • Dissolved
? - ?
510
75!)
AWQC
No
Beiov. benchmark"
0,7
Aluminum - Total
n mi
33300
750
AWQC*
Yes
Exceeds benchmark
44 4
Antimony - Dissolved
1 i 7
0.9
30
SCV
No
Below benchmark
0.01
Antimony ¦ Total
6/11
< 18
30
SCV
No
Below benchmark
0,6
Arsenic - Dissolved
3/7
< 2
150
AWQC
No
Below benchmark
0.01
Arsenic - Total
SMI
10 S
150
AWQC
No
Below benchmark
0.1
Barium - Dissolved
i 1 7
81.6
3.9
ET-Tier 11
Yes
Exceeds benchmark
20,9
Barium - Total
n/ii
217
3.9
ET-Ticr 11
Yes
Exceeds benchmark
55,6
Beryllium - Dissolved
2/7
21.3
5.1
ET-Tier II
Yes
Exceeds benchmark
4 2
Beryllium - Total
6.-11
1480
5.1
H I -Tier 11
Yes
Exceeds benchmark
290 2
Cadmium - Dissolved
2 / 7
14.9
0.33
AWQC
Yes
Exceeds benchmark
45.3
Cadmium - Total
6.' 11
121
0.37
AWQC
Yes
Exceeds benchmark
327 9
Calcium - Dissolved
in
2S3000
Nutrient
NA
No
Nutrient
NA
Calcium - Total
11 • 11
335000
Nutrient
NA
No
Nutrient
NA
Chromium - Dissolved
ft / 7
193
104
AWQC
Yes
Exceeds benchmark
1.8
Chromium - Total
9/ 11
13300
121
AWQC
Yes
Exceeds benchmark
109.5
Cobalt - Dissolved
7 /7
515
3
ET-Tiei I]
Yes
Exceeds benchmark
171."
Cobalt - Tola!
11/11
1960
3
ET-Tier 11
Yes
Exceeds benchmark
653.3
Copper - Dissolved
4 / 7
55
12 J
AWQC
Yes
Exceeds benchmark
4.3
Copper - Total
8.1)
4220
13.3
AWQC
Yes
Exceeds benchmark
316.3
Cyanide - Dissolved
0/7
< 10
S.2
AWQC
Yes
Exceeds benchmark
1,9
Cyanide - Total
0 / II
« 10
5
AWQC
Yes
Exceeds benchmark'
2.0
Iron - Dissolved
7/7
33100
1,000
AWQC
Yes
Exceeds benchmark
33.1
Iron - Total
11/11
270000
1.000
AWQC
Yes
Exceeds benchmark
270.0
Lead - Dissolved
6' 7
6.2
4.0
AWQC
Yes
Exceeds benchmark
1 6
Lead - Total
9/11
868
5.4
AWQC
Yes
Exceeds benchmark
16U. I
Magnesium - Dissolved
7/7
8730
Nutrient
NA
No
Nutrient
NA
Magnesium - Total
11/11
15800
Nutrient
NA
No
Nutrient
NA
Manganese - Dissolved
7 / 7
5320
80
in.Tier 11
Yes
Exceeds benchmark
66.5
Manganese - Total
11/11
5480
80
ET-Ticr 11
Yes
Exceeds benchmark
68.5
Mercury - Dissolved
i n
0.29
0.77
AWQC*
No
Below benchmark
0.4
Mercury - Total
4/11
41.1
0.91
AWQC
Yes
Exceeds benchmark
45.4
Nickel - Dissolved
7/7
8390
74
AWQC
Yes
Exceeds benchmark
113.2
Nickel - lotal
li/n
235000
74
AWQC
Yes
Exceeds benchmark
.5161.J
Potassium - Dissolved
7/7
5790
Nutrient
NA
No
Nutrient
NA
Potassium - Total
11 11
23350
Nutrient
NA
No
Nutrient
NA
Selenium - Dissolved
2/7
8.6
4.61
AWQC
Yes
Exceeds benchmark
1.9
Selenium - Total
0/11
« 3.8
5
AWQC
No
Below benchmark
0.8
Silver - Dissolved
4/7
1.135
0,36
SCV
Yes
Exceeds benchmark
3.2
Silver - Total
8/11
35.9
0.36
SCV
Yes
Exceeds benchmark
99 7
Sodium - Dissolved
T / 7
18500
Nutrient
NA
No
Nutrient
NA
Sodium - Total
11 M1
78150
Nutrient
NA
No
Nutrient
NA
Thallium - Dissolved
0/7
< 1
12
SCV
No
Be km benchmark
0.1
Thallium - Total
0/ It
< 2
12
SCV
No
Below benchmark
0.2
Uranium • Total
7/11
572,5
2.6
SCV
Yes
Exceeds benchmark
220-2
Vanadium - Dissolved
3-7
1.8
19
ET-Tier 11
No
Below benchmark
0.1
Vanadium - Total
7 n
5.9
19
ET-Tier 11
No
Below benchmark
0.3
Zinc - Dissolved
1 ! 1
3840
168 45
AWQC
Yes
Exceeds benchmark
22 8
Zinc - Total
9/ U
49900
171
AWQC
Yes
Exceeds benchmark
292.1
a. Scrceing values adjusted to a hardness of 152 mg-L CaCO,.
h, Hazard quotient > 1 but based on maximum detection limit.
c. Screening value for aluminium is an acute value for Total-t'nflitered aluminum.
No St. - No screening level available
"<" - Indicates maximum detection limit,
NA - Not applicable
C0C - Contininant of Concern
Sources in Order of Preference:
AWQC - Ambient Water Quality Criteria (USEPA, 2002)
liT-Tier 11 - Ecotox Thresholds (USlfPA. 1996}
SCV- Secondary C'hnrnic Value (Suter & Tsao, 1996)
6 of 10
-------
TABLE €-20
SEDIMENT core SCREENING
ONSITK SEASONAL WETLANDS
Shpack Superfund Site
Norton, Attleboro, MA
Maximum
Ecological
Frequency
Sediment
Sediment
Source of
of
Concentration
Screening Level4
Ecological
EU/yrd
Aimhie
Detection
nig/kg
mg/kg
Screening Level
coc?
Reason
Quotient
VOCs (mg/kg)
1,1-Dichlorocthcne
3 ' 15
-- 0.031
No SL
NA
Yes
NoSL
NA
l,2-l)ich1oroethene (total)
2/8
2 1
No SL
NA
Yes
No SL
NA
2-Butanonc
5 15
< 0-031
No SL
NA
Yes
No SL
NA
Acetone
2 ' 15
0.09
No SI,
NA
Yes
No SI.
NA
Carbon Disulfide
2- 15
< 0.031
No SL
NA
Yes
NoSL
NA
cis-l,2-Dich1oroethene
5/7
6,4
No SI.
NA
Yes
No SL
NA
Methyl Acetate
2/7
0.0142$
No SL
NA
Yes
NoSL
NA
Tetrachloroethene
1 r 15
- 0031
2.1
SQB
No
Below benchmark
n til
Toluene
1 ¦' 15
< 0,031
2.7
SQB
No
Below benchmark
0 01
trans-1,2-Dschloroethene
2 / 7
0-013
No SL
NA
Yes
NoSL
NA
Trichloroethcnc
5 <• 15
10-45
6.5
SQB
Yes
Exceeds benchmark
Lb
Triclilorofluummethane
1 ; 7
•: 0.012
Nu SL
NA
Yes
No SL.
NA
Vinyl Chloride
2 15
0 13
No SL
NA
Yes
NoSL
NA
SVClCsi
U'-BtpHenyl
1 / 7
(1,077
4.5
SQB
No
Below benchmark
0.02
2-Methylnaphllialene
5 ¦' 15
0.275
007
LR-L
Yes
Exceeds benchmark
,Y9
4-Methylphenol
0 ' 14
< ft, 2
\ lene
9/ 14
5.7
0.6885
OMOL-Lou
Yes
Exceeds bcnchntaik
it 3
Ben/o( k jfluDnin ihcuc
12. 15
10
0.972
OMOli-i-ow
Yes
Hxceeds benchmark
Ht.3
bis{2-Hthylhexy1)plithaIate
5/ 15
5-9
0-182
TEL
Yes
Exceeds benchmark
32-4
Carha/ule
4. 14
2.75
Nu SL
NA
Yes
No SI.
NA
Cbrysene
12 • 15
16
0 384
ER-L
Yes
Exceeds benchmark
4L7
Dibenz(a,h}aiu1iraeent:
5." 14
2.55
0.06
HR-L
Yes
Exceeds benchmark
4 IK 1
Dihcmzofurau
3. 14
0 63
S.I
SQB
No
Below benchmark
0 1
Dicthylphthalaie
1 : 15
0,28
2.6
SQB
No
Below benchmark
0 1
Lh-n-bu;ylph:halate
4 15
15
No SL
NA
Yes
NoSL
NA
Di-n-oclytplithalalt"
0/ !4
0
No SL
NA
Yea
No SL
NA
hluoranlht'Tie
14 15
26
I 1.7
SQC
Yes
Eixceeds benchmark
2 2
Fluorcnc
7; 15
Q 84
2187
SQB
No
Bclo^ benchmark
0 4
Ind?no{ 1.2,3-cd)pyrene
9,' 14
5 5
0.081
OMOfi-Lou
Yes
E*Ixc;ceds benchmark
67.9
m-Nttroamlme
0 - 6
< 16
No SL
NA
Yes
No SL
NA
Naphthalene
11 i 15
0 44
0 16
ER-L
Yes
Eixceeds benchmark
2 8
o-Nitroanilinc
0 ' 6
< 16
No SL
NA
Yes
No SL
NA
o-Nitropheriol
0 ft
* 6.2
Ncs SL
NA
Yes
NoSL
NA
Phenamhrene
14 . 15
16 5
3.4
SQC
Yes
Exceeds benchmark
48
Phenol
0; 14
^ 6.2
NoSL
NA
Yes
No SL
NA
Pyrene
15/ 15
31
0 66
ER-L
Yes
Eixceeds benchmark
47 0
PCBs/Pestiddes (rng/kg)
4,4-DDD
4 • 14
0 046
0.002
ER-L
Yes
Bioaccumulatcs
23.0
4,4'DDF.
6-' 14
y.st
0.0022
l'.R-l
Yes
Bioaixumulatei.
231 8
4,4-DDT
5; 14
0-03
0,00158
ER-L
Yes
Bioaccumulatcs
19.0
Aldrin
1 : 14
0.00088
0 0081
OMOh-Um
Yes
Bioaccumulates
0 I
alpha-BHC
(>/ 14
< 0 029
0.0243
OMOE-Low
Yes
Bioaceurn ulates"
1 2
alpha-Chbrdane
3; 14
0-0027
0.0005
ER-L
Yes
Bioaccumulatcs
5 4
Aroclor-1248
4 / 14
1,6
0.1215
OMUL-Uiw
Yes
Ehoaceumulate*
13.2
Aroclor-1254
8' 15
84
0.243
OMOE-Uw
Yes
Bioaccumulaies
345 7
Aroclor-1260
S ' 14
0.28
0.02025
OMOH-l jiv.
Yes
Bioaecuniulatt's
13.H
Dicldnn
1 / 14
0.0065
0.2106
SQC
Yes
Bioaccumulates
0.03
Endosulfan II
1 * 14
0.00098
0.0567
SQB
Yes
Bioaccumulate?,
0.U2
Eridiisiiiran sulfate
3 - 14
0.006
NoSL
NA
V es
Bioaccumulates
NA
Endriri
2- 14
0,047
0,081
SQC
Yes
Bioaccunmlates
0.6
Bndrin aldehyde
4 - 14
0.615
No SI.
NA
Yes
liioaccumuhteji
NA
Endrin ketone
2 ' 14
Q.0066
No SL
NA
Yes
Bioaccumulatcs
NA
gam ma-Cli lordan t;
5 14
0.625
0.0005
HR-L
Yes
Bioaccutnulatcs
12SI1 0
I leplachlor epoxide
2 14
0.00098
0,02025
OMOE-Low
Yes
Bioaccumulates
f> 05
Methnxyclilur
4 ¦ 14
0021
0.07695
SQB
Yes
Bioaccumulates
0.3
7 of 10
-------
TABLE G-20
SEDIMENT COPC SCREENING
OIMSITE SEASONAL WETLANDS
Shpack Superfund Site
Norton, Attlehoro, MA
Maximum
Ecologies!
Frequency
Sediment
Sediment
Source of
of
C oncentrattan
Screening Level"
Kculugical
Hazard
Analvte
Detection
mg/k£
mg/kg
Screening Level
COC?
Reason
Quotient
Metals (mg/kg)
Aluminum
15 15
53,600
No SL
NA
Yes
No SL
NA
Antimony
8/ 15
491
?
ER-L
Yes
Exceeds benchmark
345 5
Arsenic
15/ 15
16.15
8.2
ER-L
Yes
Exceeds benchmark
2.0
Barium
15-' 15
4,060
No SL
NA
Yes
No SI
NA
Beryllium
12/ 15
233
No SL
NA
Yes
No SL
NA
Cadmium
11/13
75 3
1-2
L:R-L
Yes
Exceeds benchmark
62 K
Calcium
15/ 15
167,000
Nutrient
NA
No
Nutrient
NA
Chromium
13 15
2.600
81
ER-L
Yes
Exceeds benchmark
32 ^
Cobalt
24,' 15
422
No SL
NA
Yes
No S L
NA
C opper
15 / IS
17*800
34
I-K-L
Yes
Exceeds benchmark
523.5
Cyanide
4 /15
< 11.1
No SL
NA
Yes
No SL
NA
Iron
15 15
200.000
20,000
OMOE-l-ow
Yes
Exceeds benchmark
10.0
Lead
15. 15
13,200
467
ER-I.
Yes
Exceeds benchmark
282,7
Magnesium
15 15
40,700
Nutrient
NA
No
Nutrient
NA
Manganese
15 15
10,300
460
OMOE-Lo*
Yes
Exceeds benchmark
22 4
Mercury
11/15
30.7
0,15
ER-L
Yus
Exceeds benchmark
204 7
Nickel
15 ' 15
31,800
20.9
ER-L
Yes
Exceeds benchmark
1521.5
Potassium
10 ' 15
959
Nutrient
NA
No
Nutrient
NA
Selenium
5; 15
1 7
No SL
NA
Yes
No SI,
NA
Silver
11 - 15
374
1
ER-L
Yes
Exceeds benchmark
374.O
Sodium
12/ 15
1,470
Nutrient
NA
No
Nutrient
NA
Thallium
4- 15
< 1 1
No St.
NA
Ye*
No SL
NA
Vanadium
14/ 15
108
No SL
NA
"Yes
No SL
NA
Zinc
15/ 15
38,000
150
ER-L
Yes
Exceeds benchmark
253.3
y SQO, SQC, arid OMOH-Uiw benchmark values (organic;, only) have been adjusted for a IOC of 4 [%
b. Hazard quotient > I but based 021 maximum detection limit
Nti SI - No screening level available
- Indicates maximum detection limit.
NA - Not applicable
COC - Comrninant of Concern
Sources in Order of Preference:
SQC - Sedmieru Quality Criteria, USEPA (1996) ECO Update, Hcoloxix Thresholds. Intermittent Bulletin Vol 3, No. 2.
SQB - Sediment Quality Benchmarks, USHPA (1996) IX'O Update, Ecotox Thresholds Intermittent Bulletin Vol 3, No. 2.
ER-L - NOAA Effects Ran^e-Low, Long et al. 11995} as cited in in Jones, SuUcr & Hull (199?)
OMOH-Lo* - Ontario Ministry of the Environment •• I x>\v, Persaud, et al (1993) as cited hi Jones, Sutler & Hull {19971
TEL - Threshold Effects Levels, Mac Donald (1904) as cited in Jones, Sutter & Hull (1997)
8 of 10
-------
TABLE C-21
Hl'RFAt-E WATER COPC SCREENIIVU
ONSJTE SEASONAL WETLANDS
Shpatk Superfund Sile
Nurlun. AHk'buro, MA
Maximum
Ecological
Frequency
Surface Water
Surface Water
Source of
of
Concentration
Screening Level*
Ecological
Hazard
Analyte
Detection
(ug/t)
(ug/L)
Screening Level
coc?
Reason
QuiHk'nt
YOC\ (ug/l.)
Ll-Dichloroethene
0..' 9
<¦ 10
25
scv
No
Below benchmark
0.4
1,2,3 -T richlorobenzene
0 6
< U5
No SI.
NA
V es
N o SL
NA
1.2-Dichloroethene (total)
0" 3
< 10
590
scv
No
Below benchmark
0 i»2
2-Butanone
0 s 9
-• 10
14.000
scv
No
Below benchmark
0 00 I
Acetone
\ !9
170
1,500
scv
No
Below benchmark
(I.I
Carbon Disulfide
0/ 9
<¦ 0.5
0.92
scv
No
Below benchmark
u. 5
cis-1,2 -Dichloroe thene
4/6
19
590
scv
No
Below benchmark
0,03
Methyl Acetate
0/6
< 0.5
No SL
NA
Yes
No SI,
NA
TetrachloToetheue
1 ;9
<- 10
120
BT-Tier 11
No
Below benchmark
0 I
Toluene
2/9
<¦ 10
130
ET-Ticr 11
No
Below benchmark
0 1
trails-1,2-Dichloroetheoe
0/6
< 0.5
590
scv
No
Below beiKlimark
0.001
I'Tichloroethene
2 9
< 10
350
in-Tier il
Ni.i
Below benchmark
0.03
Trichlorofluomnjethane
0/6
< 0.5
No SL
NA
Yes
No SL
N A
Vinyl Chloride
1 / 9
< to
No SL
NA
Yes
No SL
NA
SVOCs (u&'l->
IJ'-Bipheuy]
0 6
< 6.3
14
scv
No
Below benchmark
0.5
1.2,4.5-Tctrachlorobenzcne
0 6
< 6.3
No SI.
NA
Yc»
No SL
NA
2-Methylnaphthalcne
0 9
< JO
No SL
NA
Yes
No SL
NA
4-MefhyIphenoI
2; 9
0.3
No SL
NA
Yes
No Si.
NA
Acenaphthene
1 9
0.!
No SL
NA
Yes
No SL
NA
Acenaphthylene
0; 9
< ID
No SL
NA
Yes
No SI
NA
Anthracene
0/9
0,12
0.73
SC V
No
Below benchmark
!» 2
Benzaldehyde
0 / 6
6.3
No SL
NA
Yes
No SL
NA
Benzo(a)amhracene
0/9
0.4
0.02?
scv
Yes
Belovs benchmark
14.S
Bcnzo(d)p>Tcne
2/9
0.4
0.014
KT-Tier II
Yes
Exceeds benchmark
2H.6
lien/xi(h) lluoraniliene
2/9
< 10
Nil SI.
NA
Yes
No SL
NA
Ben/x)(g.h,i)pcr>lenc
0/9
< 10
Nti SI.
NA
Yes
No SL
NA
I3eii/<,}(k)f1u0ranthene
2 / 9
< 10
N» SI
NA
Yes
No SL
N A
ht!^2-I-Uhylhe*y3)plithalaU:
1 / 9
LI
32
I T Tier Jl
No
Below benchmark
0.03
Carhazole
1 -'9
0)
No SL
NA
Yes
No SI..
NA
Chrysene
2/9
0 5
No SL
NA
Yes
No SL
NA
Dtberiz(a.lOauthrace»e
0/9
-- to
No SL
NA
Yes
No SL
NA
Dibenzofuran
0/9
- 10
20
KT-Tier !l
No
Below benchmark
0 5
Diethylphthalate
0 ' 9
< 10
220
ET Tier II
No
Below benchmark
0 0
Di-n-butylphthalate
0/9
<• 10
23
KT-Tier II
No
Below benchmark
0.3
Di-n-octylphihalaie
0 9
< 10
No SL
NA
Yes
No SL
NA
Fluoranthene
4/ 9
0.8
No SL
NA
Yes
No SI
NA
Ruorene
1 /9
0.1
3-9
KT-Tier II
No
Below benchmark
0,03
IndencK 1,2,3-cd)pyrene
0 / 9
< 10
No SL
NA
Yes
No SL
NA
m-Nitroauilinc
0/6
<• 25
No SL
NA
Yes
No SL
NA
Naphthalene
0 / 9
< 10
24
tT-Ticrll
No
Below benchmark
0.4
o-Nitroamline
0/6
< 25
No SL
NA
Yes
No SL
NA
o-NitropliehC'l
0 6
^ 6.3
No SL
NA
Yes
No SL
NA
Phcnantlirenc
6 / 9
0.8
No SL
NA
Yes
No SL
NA
Phenol
0 ' 9
< 10
No SL
NA
Yes
No SL
NA
Pyrene
2/ 9
0.9
No SL
NA
Yes
No St.
ISA
PCBs/Pestkides (ug-'i.)
4,4-DDD
0/ 9
< 0.1
o.on
scv
Yes
Bioaccumulatcsh
4J 1
4,4'-DDH
I ' 9
0.012
No SL
NA
Yes
Bioaccumulates
NA
4,4-DDT
0/8
* (l. I
0.001
AWQC
Yes
nioaccuniulatKs
100.0
Aldrin
0 ' 9
< 0,05
3
AWQC
Yes
Bioaccunmlates
0 02
alpha-BHC
) 9
0.008125
No SL
NA
Yes
Bioacc umulates
NA
alpha-Chlordane
0 -9
< 0.05
0 0043
AWQC
Yes
Bmaeeumulaies*
S Lfj
Atoclor-1248
0/9
< 1
0.081
SCV
Yes
Bioaccuiiiulaies^
12,3
Aroclor-1 254
1 -9
0.43
0.033
scv
Yes
BioaccumuJates
13.0
Areolar-1260
0/ 9
1
94
scv
Yes
Bioaccumulutes
0,0!
Dieldrm
U/9
O.i
0,056
AWQC
Yes
Btoaccuniulatesh
1.8
Endosulfan 1
0 9
< 0.05
0.056
LLlierll
Yes
Bioaccumulates5'
0.9
Endosulfan sulfate
1 "9
0.0065
No SL
NA
Yes
Bioaccuniulates
NA
Endrin
0 9
0,1
0.036
AWQC
Yes
Bioaccumulates1'
I b
Endrin aldehyde
0/9
< 0J
No SL
NA
Yes
Bioaccuniulates
NA
Endrrn ketone
0/9
< 0,1
No SL
NA
Yes
Bioaccumulalcs
NA
gamnva-Chlordanc
1 / 9
0,0031
0.0043
AWQC
Yes
Bioaccumulates
0/'
Hcptachlor epoxide
0 ¦ 9
<¦ 0.05
0.003 H
AWQC
Yes
Bioaccumulates1"
13.2
Methoxychlor
0/9
< 0.5
0,03
AWQC
Yes
Biuaecumulates0
16.7
9 of 10
-------
TABLE G-2I
SURFACE WATER ( OPC SCREENING
ONS1TE SEASONAL WETLANDS
Shpack Superftmd Site
Norton, Attlcboro, MA
Maximum
Ecological
Freque ncv
Surface Water
Surface Water
Source of
of
Concentration
Screening Level8
Ecological
Hazard
Anahie
Detection
(ug/L)
(u&L)
Screening Level
coc?
Reason
Quotient
Meials (ug,'L)
Aluminum - Dissolved
0.' 6
<: 9
750
AWQC
No
Below benchmark'
0.01
Aluminum - Total
9 .'9
642U
ISO
AWQC
Yes
Exceeds benchmark
K.(j
An(irr*«iv ¦ Dissolved
6/6
0.65
30
.SCV
No
Below benchmark
0 02
Antimony - Total
K *' 9
36
30
SCV
Yes
Exceeds benchmark
1.2
Arsenic - Dissolved
0/6
c 0,5
150
AWQC
No
Below benchmark
0.0
Arsenic - Total
1 >'9
2,3
ISO
AWQC
No
Below benchmark
0.0
Barium - Dissolved
6 * 6
3190
3.9
1'T-Tser II
Yes
Exceeds benchmark
818
| Barium - Total
g/g
7500
3,9
ET-Ticr II
Yes
Exceeds benchmark
1.923
Beryllium - Dissolved
0/6
0 2
5.1
ET-Tier II
No
Below benchmark
0.04
Beryllium - Total
0 o
< 1
5 J
ET-Tter II
No
Below benchmark
0.2
Cadmium - Dissolved
1 ,6
'143
0.48
AWQC
No
Below benchmark
0.9
Cadmium - Total
8 9
39.5
0.55
AWQC
Yes
Exceeds benchmark
71
Calcium - Dissolved
6 * 6
15 WO
Nutrient
NA
No
Nutrient
NA
Calcium - Total
9, q
167000
Nutrient
NA
No
Nutrient
NA
Chromium - Dissolved
5 6
1,4
164
AWQC
No
ilcluw benchmark
0.01
Chromium - Tola!
6/9
< 6.9
190
AWQC"
No
Below benchmark
0 04
Cobalt - Dissolved
2/6
6.4
3
ET-Tier II
Yes
Exceeds benchmark
2 1
Cobalt - Total
5/9
70.4
3
ET-Ticr II
Yes
Exceeds benchmark
23.5
Copper - Dissolved
5 6
14 a
20.5
AWQC
No
Below benchmark
0.7
Copper - Total
8/9
891
21.3
AWQC
Yes
Exceeds benchmark
42
Cyanide - Dissolved
0/ 6
< 5
5,2
AWQC
No
Below benclniiark
0.96
Cyanide - Total
0/9
< 10
5.2
AWQC
Yes
Exceeds benchmark
1.9
Iron - Dissolved
6/ 6
267.5
1,000
AWQC"
No
Below benchmark
0.3
Iron - Total
9; 9
50800
L000
AWQC
Yes
Exceeds benchmark
50. £
Lead - Dissolved
6/6
21 3
7.1
AWQC
Yes
Exceeds benchmark
3 f>
Lead - Total
9/9
160
10.9
AWQC
Yes
Exceeds benchmark
14.7
Magnesium - Dissolved
6; 6
24700
Nutrient
NA
No
Nutrient
NA
Magnesium * Total
0/9
37400
Nutrient
NA
No
Nutrient
NA
Manganese - Dissolved
6/ 6
1000
80
ET-Tier II
Yes
Exceeds benchmark
12.5
Manganese - Total
9/9
2570
ho
HI Txer II
Vcs
Exceeds benchmark
32.)
Mercury - Dissolved
0/6
< 0,14
0.77
AWQC
No
Below benchmark
0.2
Mercury - Total
2/9
1.1
0.77
AWQC
Yes
Below benchmark
1.4
Nickel - Dissolved
6 / 6
135
118
AWQC
Yes
Exceeds benchmark
11
Nickel - Total
9/9
i 780
US
AWQC
Yes
Exceeds benchrnark
15.1
Potassium - Dissolved
6/ 6
24200
Nutrieni
MA
No
Nutrient
NA
Potassium - Total
9/9
59300
Nutrient
NA
No
Nutrient
NA
Selenium - Dissolved
1 / 6
7.6
4,6
AWQC
Yes
Exceeds benchmark
1.7
Selenium - Total
2/9
7,95
5
AWQC
Yes
Exceeds benchmark
1.6
Silver - Dissolved
0/ 6
c. o,s
0.36
SCV
Yes
Exceeds benchmark
Silver - Total
2/9
26 2
0.36
SCV
Yes
Exceeds benchmark
72.8
Sodium - Dissolved
6/ 6
47900
Nutrient
MA
No
Nutrient
NA
Sodium - Total
9/9
125000
Nutrient
NA
No
Numen?
NA
Thallium - Dissolved
0/6
< 0.34
12
scv
Mo
Below benchmark
0.03
Thallium - Total
0/9
< 2
12
SCV
No
Below benchmark
0 2
Vanadium - Dissolved
6/6
6.9
19
ET-Tier 1]
No
Below benchmark
0 4
Vanadium - Total
7/9
148
19
ET-Tier II
Yes
Exceeds benchmark
7 ij
Zinc - Dissolv ed
6/ 6
4Q.9
26*
AWQC
No
Below benchmark
0.2
Zinc - Total
8/9
5470
272
AWQC
Yes
Exceeds benchmark
20.1
a. Screeing values adjusted In a hardness of 263 rug !, CaCO.
b- Hazard quotient > I hut based omiiaximum detection limit,
c. Screening value tor aluminium is an acute value for Total Lnfiltered aluminum.
No SL - No screening level available
- Indicates maximum detection limit.
NA - Not applicable
COC - Confmmant of Concern
AWQC - Ambient WatcTQuality Criteria (USLPA, 2002)
ET-Ticr II - Ecoiox Thresholds (L'SEPA. 1996)
SCV- Secondary Chornii: Value (Suter Si Tsaa. 19%)
lOoflO
-------
Table G-22
Ecological Exposure Pathways of Concern - Hardwood Forest
Exposure
Medium
Sensitive
Environment
Flag
YorN
Receptor
Endangered/
Threatened
Species Flag
Y orN
Exposure
Routes
Assessment
Endpoints
Measurement
Endpoints
Soil
N
Small terrestrial
mammals
N
Ingestion and
direct contact
with chemicals in
soil
Sustainability
{survival, growth,
reproduction) of
local populations of
smalt terrestrial
mammals
Compare modeled
exposures to
published values
which are indicative
of potential
impairment.
Soil
N
Songbirds
N
Ingestion and
direct contact
with chemicals in
soil
Sustainability
(survival, growth,
reproduction) of
local populations of
songbirds
Compare modeled
exposures to
published values
which are indicative
of potential
impairment.
-------
Table G-23
Ecological Exposure Pathways of Concern - Chartley Swamp
Exposure
Medium
Sensitive
Environment
Flag
YorM
Receptor
Endangered/
Threatened
Species Flag
YorN
Exposure
Routes
Assessment
Endpoints
Measurement
Endpoints
Sediment
and Surface
Water
N
Semi-aquatic
mammais
H
Ingestion and
direct contact
with chemicals in
sediment and
surface water.
Sustainability
(survival, growth,
reproduction) of
local populations of
semi-aquatic
mammals
Compare modeled
exposures to
published values
which are indicative
of potential
impairment.
Sediment
and Surface
Water
N
Waterfowt
N
Ingestion and
direct contact
with chemicals in
sediment and
surface water.
Sustainability
(survival, growth,
reproduction} of
local populations of
waterfowl
Compare modeled
exposures to
published values
which are indicative
of potential
impairment.
Sediment
and Surface
Water
N
Bottom dwelling
fish
N
Ingestion and
direct contact
with chemicals in
sediment and
surface water.
Sustainability
(survival, growth,
reproduction! of
local populations of
bottom dwelling
fish
Compare modeled
exposures to
published values
which are indicative
of potential
impairment.
Sediment
and Surface
Water
N
Benthic
invertebrates
N
Ingestion and
direct contact
with chemicals in
sediment and
surface water.
Sustainability
(survival, growth,
reproduction) of
local populations of
benthic
invertebrates
Compare chemical
concentrations in
medium to sediment
toxicity benchmarks.
Indicative of
potential
impairment.
-------
Table G-24
Ecological Exposure Pathways of Concern - Onsite Seasonal Wetland
Exposure
Medium
Sensitive
Environment
Fteg
YorN
Receptor
Endangered/
Threatened
Species Flag
YorN
Exposure
Routes
Assessment
Endpoints
Measurement
Endpoinfs
Soil
N
Small terrestrial
mammals
N
Ingestion and
direct contact
with chemicals in
soil.
Sustainability
(survival, growth,
reproduction) of
iocal populations of
small terrestrial
mammals
Compare modeled
exposures to
published values
which are indicative
of potential
impairment-
Sediment
and Surface
Water
N
Wetland
songbirds
N
Ingestion and
direct contact
with chemicals in
sediment and
surface water.
Sustainability
{survival, growth,
reproduction) of
local populations of
wetland songbirds
Compare modeled
exposures to
published values
which are indicative
of potential
impairment.
Sediment
and Surface
Water
N
Benthic
invertebrates
N
Ingestion and
direct contact
with chemicals in
sediment and
surface water.
Sustainability
(survival, growth,
reproduction) of
local populations of
benthic
invertebrates
Compare chemical
concentrations in
medium to sediment
toxicity benchmarks
indicative of
potential
impairment.
-------
Ecological Effects Assessment
Modeled doses 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. The LOAEL to NOAEL adjustment was
the only calculation in which an uncertainty factor was used. Hazard quotients (HQs) were then calculated
for each COC using the modeled doses and NOAEL TRVs. Risk to shrew, robin, muskrat, mallard, and
marsh wren was based on magnitude of the HQs and an assessment of the uncertainty associated with the
HQs. COCs which showed risk based on these factors in the maximum (UCL) case were identified as
exceeding lower risk thresholds. When COCs exceeded lower risk thresholds, a second set of HQs was
calculated using LOAEL TRVs and the average case. COCs which showed risk based on LOAEL TRVs and
the average case were identified as exceeding upper risk thresholds.
Several COCs lacked avian TRVs (especially VOCs and SVOCs); when avian TRVs were not available,
mammalian TRVs were used as surrogate values to calculate HQs. When mammalian TRVs were not
available for a COC, HQs could not be calculated.
Risk to fish was evaluated by modeling tissue concentrations from measured sediment concentrations.
Hazard quotients were then calculated for each COC using the modeled doses and no-observed-effects-dose
(NOED) and lowest-observed-effects-dose (LOED) TRVs indicative of potential harm. Risk to fish was
based on magnitude of the HQs and an assessment of the uncertainty associated with the estimates. Risk to
benthic invertebrates was evaluated by comparing sediment concentrations to sediment ecological
benchmarks within the context of SEM-AVS data. Whether COCs exceeded lower risk thresholds or upper
risk thresholds for benthic invertebrates was based on exceedences of benchmark values.
Risk Characterization
In the hardwood forest, risk to small mammals and songbirds is not actionable because no COCs exceed
upper risk thresholds. In Chartley Swamp, only the inner rung scenario demonstrated actionable risk to
semi-aquatic mammals, waterfowl, bottom dwelling fish, and benthic macro invertebrates; risk in the inner
rung was associated with concentrations of inorganics. In the onsite seasonal wetlands, risk to small
mammals, wetland songbirds, and benthic invertebrates was associated with concentration of SVOCs,
pesticides/PCBs, and inorganics which exceeded upper risk thresholds.
The goal of the risk description is to identify a threshold concentration (also called threshold effects levels,
or TELs) at which ecological effects are likely to occur. A TEL is a daily dose resulting in a hazard quotient
(HQ) of 1.0. Since food COC concentrations were estimated from soil and sediment concentrations, the
food chain models were used to back-calculate a soil or sediment 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. TELs are summarized below (Table G-25 though Table G-27) for those COCs
which exceed upper risk thresholds. TELs were based on LOAELs and the average case; if LOAELs were
not available then TELs were based on NOAELs and the average case.
TELs for the benthic invertebrate community have not been calculated at this time. Site specific toxicity
testing will be conducted during pre-design efforts to ensure that the selected cleanup standards are
protective of this community. As part of remedial design toxicity testing will be conducted in Chartley
Swamp and the onsite seasonal wetlands to confirm that the selected sediment cleanup levels are protective
of the benthic community.
62
-------
3. Basis for Response Action
Because the baseline human health and ecological risk assessments revealed that ecological and human
receptors potentially exposed to contaminants of concern in soil, sediment and groundwater via ingestion or
direct exposure may present an unacceptable human health risk of 10"4 excess cancer risk and/or a Hazard
Index of HI of 1.0 or greater, or unacceptable ecological risk; 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.
In order to address these risks, the focus of the remedial action is on soil and sediment media in which
COCs are present above the site cleanup levels listed in Tables L-l, L-2, and L-3 of this ROD.
H. REMEDIATION OBJECTIVES
Based on preliminary information relating to types of contaminants, environmental media of concern, and
potential exposure pathways, response 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 human health and the environment. The RAOs for the selected remedy for the
Shpack Landfill Superfund Site are:
Source Control:
Soil
Prevent Ingestion/direct contract with soil having non-carcinogens in excess of a Hazard
Index (HI) of 1 or with soil having carcinogens posing excess cancer risk above 10"4 to 10"6
and meet ARARs.
Prevent inhalation of carcinogens posing excess cancer risk levels above 10"4 to 10"6 or a
hazard index of 1.0 and meet ARARs.
Prevent exposure to contaminants in soil that present an unacceptable risk to the
environment.
Sediment
Prevent exposure to sediment having carcinogens posing excess cancer risk above 10"4 to 10"6
or a hazard index of 1.0.
Prevent exposure to contaminants in sediment that present an unacceptable risk to the
environment.
Surface Water
Prevent migration of contamination from site to surface water to reduce to the extent
practicable the contribution of contamination from the site to surface waters of contamination
that presents an unacceptable risk to human health and the environment.
63
-------
Table G-25
COC Concentrations Expected to Provide Adequate Protection of Ecological
Receptors in the Hardwood Forest
Habitat
Type/ Name
Exposure
Medium
COC
Protectiva
Level
Units
Basis
Assessment
Endpoint
Hardwood
Fores!
Soil
None
NA
NA
Food chain models, LOAEL
Sustainability
(survival, growth,
reproduction) of
local populations
of small terrestrial
mammals
Soil
None
NA
NA
Food chain models, LOAEL
Sustainability
(survival, growth,
reproduction) of
local populations
of small songbirds.
-------
Table G-26
COC Concentrations Expected to Provide Adequate Protection of Ecological
Receptors in Chartley Swamp
Habitat
Type/ Name
Exposure
Medium
COC
Protective
Level
Units
Basis
Assessment
Ertdpoint
Chartley
Swamp
Sediment
Arsenic
6.4
mg/kg
Food chain models, LOED
Sustainability
{survival, growth,
reproduction) of
local populations
Cadmium
62
mg/kg
Food chain models, LOED
Copper
41
mg/kg
Food chain models, LOED
of bottom dwelling
fish
Lead
32
mg/kg
Food chain models, LOED
Mercury
0 89
mg/kg
Food chain models, LOED
Silver
0.89
mg/kg
Food chain models, LOED
Sediment
Beryllium
45
mg/kg
Food chain models, NOAEL
Sustainability
(survival, growth,
reproduction) of
local populations
Cadmium
170
mg/kg
Food chain models, LOAEL
Copper
246
mg/kg
Food chain models, LOAEL
of semi-aquatic
mammals
Mercury
1.9
mg/kg
Food chain models, LOAEL
Nickel
7,805
mg/kg
Food chain models, LOAEL
Zinc
1,591
mg/kg
Food chain models, LOAEL
Sediment
Beryllium
45
mg/kg
Food chain models, NOAEL
Sustainability
(survival, growth,
reproduction) of
local populations
of waterfowl
Cadmium
757
mg/kg
Food chain models, LOAEL
Chromium
2,679
mg/kg
Food chain models, LOAEL
Mercury
18
mg/kg
Food chain models, LOAEL
Zinc
3,114
mg/kg
Food chain models, LOAEL
Sediment
Toxicity testing to be conducted
during predesign studies 1.
Sustainability
(survival, growth,
reproduction) of
local populations
of berrthic
invertebrates
1. A pre-design study will include toxicity testing confirm that selected cleanup goats for sediment concentrations are protective of the benttiic
invertebrate community- See text for a more detailed discussion of toxicity testing.
-------
Table G-27
COC Concentrations Expected to Provide Adequate Protection of Ecological
Receptors in the onsite seasonal Wetlands
Habitat
M
Exposure
Medium
COC
Protective
Level
Units
Basis
Assessment
Endpoint
Onsite
Seasonal
Soil
Benzo(a)anihracefie
1,2
mg/kg
Food chain models, IOAEL
Sustainability
{survival, growth,
reproduction) of
local poputatians of
Wetlands
Benzo(a)pyrene
1.3
mg/kg
Food chain models, LOAEL
Benzo{b)fluoranthene
1.3
mg/kg
Food chain models. LOAEL
small terrestrial
mammats
Senzo(k)fluoranthene
1.3
mg/kg
Food chain models, LOAEL
Chrysene
1.3
mg/kg
Food chain models, LOAEL
Dibenz(a,h)an1hracene
1.3
mg/kg
Food chain models, LOAEL
lndeno(1,2,3)pyrene
1.3
mg/kg
Food chain models, LOAEL
Araclor-1254
0.27
mg/kg
Food chain models, LOAEL
Antimony
49
mg/kg
Food chain models, LOAEL
Arsenic
188
mg/kg
Food chain models, LOAEL
Barium
853
mg/kg
Food chain models, NOAEL
Beryllium
23
mg/kg
Food chain models, NOAEL
Cadmium
136
mg/kg
Food chain models. LOAEL
Copper
5,606
mg/kg
Food chain models, LOAEL
Lead
15.110
mg/kg
Food chain models, LOAEL
Mercury
33
mg/kg
Food chain models, LOAEL
Nickel
31,845
mg/kg
Food chain models, LOAEL
Silver
522
mg/kg
Food chain models, NOAEL
Vanadium
448
mg/kg
Food chain models, LOAEL
Zinc
25,175
mg/kg
Food chain models, LOAEL
Sediment
Benzo(a)anthracene
2.7
mg/kg
Food chain models, LOAEL
Sustainability
(survival, growth,
Benzo(a)pyrene
2.7
mg/kg
Food chain models, LOAEL
reproduction) of
local populations o(
wetland songbirds
Benzo(b)(tuoranthene
2.7
mg/kg
Food chain models, LOAEL
Benzol kjfluorarrthe ne
2.7
mg/kg
Food chain models, LOAEL
Chrysene
27
mg/kg
Food chain models, LOAEL
-------
Ill
Exposure
Medium
coc
Protective
Level
Units
Basis
Assessment
Endpoint
Dibenz(a,h}anthracene
2.3
mg/kg
Food chain models. LOAEL
lndeno{1,2,3)pyrene
2.3
mg/kg
Food chain models, LOAEt
DDT
0.02?
mg/kg
Food chain models. LOAEL
ArocIor-1254
1.6
mg/kg
Food chain models. LOAEL
Antimony
39
mg/kg
Food chain models, LOAEL
Beryllium
5
mg/kg
Food chain models, NOAEL
Cadmium
103
mg/kg
Food chain models, LOAEL
Chromium
42?
mg/kg
Food chain models, LOAEL
Copper
122
mg/kg
Food chain models, LOAEL
Lead
551
mg/kg
Food chain models, LOAEL
Mercury
0.26
mg/kg
Food chain models, LOAEL
Nickel
7.943
mg/kg
Food chain models, LOAEL
Silver
18?
mg/kg
Food chain models, NOAEL
Zinc
437
mg/kg
Food chain models, LOAEL
Sediment
Toxicity testing to be
conducted during predesign
studies.1
Sustainability
(survival, growth,
reproduction) of
local populations of
benthic
invertebrates
1 A pre-design study will include toxicity testing confirm that selected cleanup goals for sediment concentrations are protective of (he benthic
invertebrate community. See text for a more detailed discussion of toxicity testing.
-------
Management of Migration
Prevent Ingestion of groundwater having carcinogens in excess of MCLs, non-zero MCLGs,
and a total excess cancer risk for all contaminants in groundwater greater that 10"4 to 10"6.
Prevent ingestion of groundwater having non-carcinogens in excess of MCLs or non-zero
MCLGs or a hazard index of 1.0.
Prevent exposure to contaminants in groundwater that present an unacceptable risk to the
environment
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) set forth the process by which remedial actions are
evaluated and selected. As discussed in Section 2 of the FS, soil technology options were identified,
assessed and screened based on implementability, effectiveness, and cost. These technologies were
combined into source control (SC) alternatives. Section 3 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. 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. Each
alternative was then evaluated in detail in Section 4 of the FS.
In summary, two source control remedial alternatives screened in Section 2 were retained as possible
options for the cleanup of the Site. As discussed earlier, these alternatives were then developed based upon
four future use scenarios.
With respect to ground water response action, the RI/FS developed a limited number of remedial
alternatives. However, based on site-specific conditions, the FS concluded that groundwater remediation
was infeasible at the time the FS was prepared from a cost, effectiveness and implementability perspective
based on the following:
68
-------
• Proximity to a Significant Offsite Source - As documented in the RI, chemically impacted
landfill materials from the ALI Landfill extend onto the southwestern portion of the Shpack
Site. The highest concentration of VOCs in groundwater detected during the RI were located
upgradient on the ALI Landfill. This indicates that a significant VOC source is located
beneath the ALI Landfill. Because of this, groundwater remediation (i.e., pump and treat)
would be ineffective because a significant source of groundwater contamination remains
unaddressed. Until this offsite, upgradient source is adequately addressed, groundwater
remediation at Shpack would be ineffective.
• High Probability for COPC Partitioning - Due to the high organic carbon contents of
shallow aquifer sediments, the majority of contaminant mass is likely adsorbed onto aquifer
solids, limiting the effectiveness of groundwater restoration The high contaminant sorption
onto soil and sediment inhibit contaminant movement in the aquifer and would increase the
restoration time frame for groundwater remedial activities
In addition, EPA has determined that groundwater will not be used in the future for drinking water, etc See
Section D of the ROD for additional discussion As a result, groundwater cleanup alternatives were not
addressed in the Detailed Analysis of the FS.
J. DESCRIPTION OF ALTERNATIVES
Detailed Analysis of Alternatives
This section presents the detailed analysis of remedial action alternatives that were retained from the
screening performed in Section 2 of the FS. The detailed analysis performed as part of the FS was
conducted in accordance with CERCLA Section 121, the NCP and USEPA RI/FS Guidance. Costs
presented in this section are based on existing site data and will be reevaluated as part of the Remedial
Design/Remedial Action (RD/RA) Phase. In accordance with USEPA RI/FS Guidance, costs presented in
this section are intended to be within the target range of -30% to +50% of the actual cost of the remedial
alternative as described.
Evaluation Criteria
This section presents a summary of the nine criteria used to evaluate the appropriate remedial alternative for
the Site. The nine criteria are broken down into three categories and are summarized as follows:
Threshold Criteria relate directly to statutory findings that must be made in the Record Of Decision. These
criteria include:
Overall protection of human health and the environment; and
• Compliance with ARARs
Balancing Criteria refer to five of the evaluation criteria that represent the primary criteria upon which the
detailed evaluation is performed. These criteria include:
Long-term effectiveness and permanence;
Reduction of toxicity, mobility or volume;
Short-term effectiveness; Implementability; and
Cost.
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Modifying criteria are evaluated following comment on the FS and the proposed plan. These criteria were
not evaluated as part of the FS and include:
State acceptance; and,
Community acceptance.
A description of the major components of each alternative, the costs for each alternative, and comparison to
the nine criteria is provided below.
ALTERNATIVE SC-1: NO ACTION
Under this alternative, no remedial technologies would be implemented at the Site to reduce soil or
sediment concentrations in the source area. As a result, the only decreases in COPC concentrations would
occur from naturally occurring degradation processes.
A comparison of this alternative to the criteria established in the NCP is included as Table 7 of the FS. As
shown in Table X of the FS, there are no costs associated with the No Action alternative.
This alternative does not meet ARAR requirements for radiological and chemical source material.
ALTERNATIVE SC-2: MULTI-BARRIER CAP/EXCAVATION/OFF-SITE DISPOSAL OF PCBs.
DIOXIN, RADIOLOLOGICAL MATERIAL
This alternative includes installing a multi-barrier landfill cap to limit water infiltration and subsequent
migration of contaminants, and excavation and off-site disposal of radiological, PCB and dioxin material
exceeding Cleanup levels. This alternative eliminates the exposure pathways of soil and sediment dermal
contact and ingestion. The capping portion of this alternative was included as part of the FS to comply with
the Federal RCRA ARAR requirements for implementation of an appropriately designed landfill cap at
Superfund sites. The landfill would be designed and installed in accordance with 40 CFR 264 Subpart G
(closure and post-closure); and 40 CFR 264 Subpart N (landfills).
Figure 4 of the FS displays the estimated excavation areas exceeding Cleanup Levels for each of the risk
scenarios evaluated in the FS, and Figure 5 of the FS shows areas with ecological risk. Table 6 displays a
summary of the volumes of impacted material for each risk scenario. Under each risk scenario, the amount
of soil to be excavated varies; however, the general excavation and disposal method is consistent.
A comparison of Alternative SC-2 to seven of the nine NCP criteria is provided on Table 9 of the FS. A
detailed cost estimate for Alternatives SC-2A through SC-2D is provided on Tables 10A through Table 10D
of the FS. The total estimated cost for various risk scenarios under this alternative were estimated as
follows:
SC-2A - Recreational User - $26,057,000
SC-2B - Adjacent Resident without GW consumption - $28,106,000
SC-2C - Adjacent Resident with GW consumption $94,514,000
SC-2D - Onsite Resident - $98,066,000
All costs include 30 years of operation, maintenance and monitoring. The ARARs associated with this
alternative are shown in Table 1C of the FS. The estimated time for construction of the SC-2 alternative
given by the FS is 18-25 months.
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Expected Outcomes
The outcome is dependent upon the risk exposure scenario selected. Restrictions would be placed on the
Site to protect the integrity of the cap in the future. Groundwater restrictions would also be necessary.
ALTERNATIVE SC-3: EXCAVATION AND OFFSITE DISPOSAL
Under this alternative, all source area materials exceeding Cleanup Levels will be excavated and transported
for offsite disposal. As a result, this alternative would provide permanent elimination of contaminants
exceeding Cleanup levels at the Site.
Figure 4 of the FS displays the estimated excavation areas exceeding Cleanup levels for each of the risk
scenarios evaluated in the FS, and Figure 5 of the FS shows areas exceeding ecological risk Cleanup levels.
Table 6 of the FS displays a summary of the volumes of impacted material for each risk scenario. Under
each risk scenario, the amount of soil excavated varies; however, the general excavation and disposal
method is consistent.
A comparison of Alternatives SC-3A through SC-3D to seven of the nine NCP criteria is provided on Table
11 of the FS. A detailed estimate of costs associated with each of the risk scenarios associated with this
alternative is provided as Tables 12A through Table 12B of the FS.
The total estimated costs for each of the risk scenarios associated with this alternative are as follows:
SC-3A - Recreational User - $54,055,000
SC-3B - Adjacent Resident without GW consumption - $55,553,0003
SC-3C - Adjacent Resident with GW consumption - $120,888,000
SC-3D - Onsite Resident - $126,868,000
The ARARs associated with this alternative are shown in Table 1G of the FS. The estimated time for
construction given in the FS is 9-16 months.
Expected Outcomes
The outcome is dependent upon the risk exposure scenario selected. Groundwater restrictions would also be
necessary.
K. SUMMARY OF THE COMPARATIVE ANALYSIS OF ALTERNATIVES
Section 121(b)(1) of CERCLA presents several factors that at a minimum EPA is required to consider in its
assessment of alternatives. Building upon these specific statutory mandates, the NCP articulates nine
evaluation criteria to be used in assessing 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 strength and weakness with
respect to the nine evaluation criteria. These criteria are summarized as follows:
3 This cost was later revised downward to $43,034,000. See Section L for more information.
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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 Balancing 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. Implementability 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.
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 9 and 11 of the FS.
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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 as
compared to these NCP criteria.
OVERALL PROTECTION OF HUMAN HEALTH AND THE ENVIRONMENT
Alternative SC-1, No Action, would be the least protective of human health and the environment because it
would offer no protection to human health and the environment. Because no remedial action would be
performed, both chemical and radiological impacts exceeding site-specific cleanup levels and ARARs
would remain at the Site. Therefore, potential future unacceptable exposure to human health and the
environment would remain at the Site. As a result, this alternative would not meet the threshold criteria in
the NCP that an alternative would be protective of human health and the environment and meet ARARs.
Alternatives SC-2, Multi Barrier Cap/Excavation, and SC-3, Excavation and Off-Site Disposal, both provide
overall protection of human health and the environment. Each of these alternatives would eliminate
exposure to impacted source materials exceeding site-specific Cleanup levels. In addition, Alternatives SC-2
and SC-3 both include requirements for waterlines for adjacent residents to eliminate exposure to
contaminated groundwater. Alternative SC-2, Multi Barrier Cap/Excavation, would remove all radiological,
dioxin and PCB waste that exceeds cleanup requirements from the Site for off-site disposal while the
remaining chemical waste material would be consolidated beneath a RCRA landfill cap which will prevent
exposure to materials that present an unacceptable risk. This alternative also includes requirements for
monitoring to ensure that exposure does not occur in the future. Alternative SC-3, Excavation and Off-Site
Disposal, would eliminate exposure to impacted radiological, dioxin, PCB, and chemical source materials
by removing them from the Site. Because this alternative removes all materials that create an unacceptable
risk from the site, it provides the greatest degree of overall protection.
COMPLIANCE WITH ARARS
Alternative SC-1, No Action, would not comply with chemical-specific ARARs applicable to the Site.
Alternatives SC-2, Multi Barrier Cap/Excavation, and SC-3, Excavation and Off-Site Disposal, would meet
all chemical, location, and action-specific ARARs. See Tables 1A-1I of the FS for additional identification
and discussion of ARARs for each alternative.
LONG-TERM EFFECTIVENESS AND PERMANENCE
Alternative SC-1, No Action, does not provide any long-term effectiveness or permanence. Alternative
SC-2, Multi-Barrier Cap/Excavation, would provide both long-term effectiveness and some permanence
because landfill capping is a proven technology to eliminate exposure to chemical waste material effectively
in the long-term. The cap would be regularly maintained to ensure that it remains effective in the long-term.
In addition, because the radiological, PCB, and dioxin waste is excavated and disposed of off-site. This
component of the alternative is also permanent and effective in the long-term.
Alternative SC-3, Excavation and Off-Site Disposal, provides the greatest degree of long-term effectiveness
and permanence because both chemical and radiological source materials exceeding cleanup levels would
be permanently removed from the site thereby ensuring that this remedy remains effective in the long-term.
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In addition, Alternatives SC-2 and SC-3 both include requirements for waterlines for adjacent residents.
This component of these Alternatives provides additional long-term effectiveness and permanence because
the waterline permanently eliminates the risk to these adjacent residents from using contaminated water.
REDUCTION OF TOXICITY, MOBILITY, OR VOLUME THROUGH TREATMENT
None of the alternatives reduce toxicity, mobility, or volume through treatment (although some materials
shipped off-site may require treatment prior to disposal).
However, Alternative SC-2, Multi Barrier Cap/Excavation, would reduce toxicity, mobility or volume
although not through treatment. This alternative would reduce mobility of the chemical contaminants that
are placed beneath the landfill cap at the Site by preventing water from coming into contact with waste
material thereby preventing this contamination from mobilizing. The toxicity of the radiological, PCB, and
dioxin waste material would be greatly reduced/eliminated because all of this material that exceeds cleanup
levels will be removed from the site. In addition, because all soil and sediment above cleanup levels
established for radiological, PCB, and dioxin waste material will be removed from the property, both the
volume and mobility of this contamination is greatly reduced/eliminated although not through treatment.
Alternative SC-3, Excavation and Off-site Disposal, would reduce/eliminate toxicity by removing both the
radiological, PCB and dioxin contamination as well as all chemical waste material from the Site, thereby
greatly reducing/eliminating the toxicity of what remains at the Site to acceptable levels. In addition,
because all soil and sediment above cleanup levels will be removed from the property, both the volume and
mobility of contamination is greatly reduced/eliminated although not through treatment.
SHORT-TERM EFFECTIVENESS
Because Alternative SC-1, No Action, would not require any activities to be conducted, there would not be
any short-term impacts on the community and on-site workers.
Alternative SC-2, Multi-Barrier Cap/Excavation, would have some short-term impacts to the community
from both the construction activities as well as from shipping materials off-site for disposal. However, these
impacts can be greatly reduced by using standard construction techniques to reduce dust, etc. from the Site
during excavation and construction of the cap. In addition, air monitoring will be conducted to ensure that
adjacent residents are not adversely impacted while this Alternative is being implemented. Appropriate
OSHA/health and safety requirements will be followed to reduce risk to on-site workers. Because this
Alternative requires off-site disposal of radiological, PCB and dioxin waste as well as incoming shipments
of material for construction of the cap, there will be a significant increase in truck traffic through the
community during the 18-25 month time frame the FS estimates it will take to implement this remedy.
Alternative SC-3, Excavation and Off-site Disposal, would have slightly greater short-term effects because
this Alternative would require all chemical and radiological waste material be excavated and shipped
off-site for disposal. However, these impacts can be greatly reduced/eliminated by using standard
construction techniques to reduce dust, etc. from waste material during the excavation and shipping phase.
In addition, air monitoring will be conducted to ensure that adjacent residents are not adversely impacted
while this Alternative is being implemented. Appropriate OSHA/health and safety requirements will be
followed to reduce risk to on-site workers. Because this Alternative requires off-site disposal of both
chemical and radiological waste, there will be a significant increase in truck traffic through the community
during the 9-16 month time frame the FS estimates it will take to implement this remedy.
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IMPLEMENTABILITY
Alternative SC-1 is the easiest to implement because no remedial actions are required.
Alternatives SC-2 and SC-3 are both easily implementable because they both involve reliable waste disposal
technologies with proven histories of success. In addition, the personnel, equipment and materials required
to implement each of these technologies are readily available. The greatest degree of variability in these
alternatives is derived from the time frame required for implementation of these alternatives and the impact
on the community. Alternative SC-3B will take less time to construct than Alternative SC-2B and will
involve some additional truck traffic in comparison to Alternative SC-2B according to Table 9 of the FS.
COST
Alternative SC-1, No Action, would require the least cost. As shown in Table 8 of the FS, there are no costs
associated with the No Action alternative.
Alternative SC-2, Multi-Barrier Cap/Excavation, is generally the second most expensive alternative, with
cost estimates ranging from approximately $26,000,000 to $98,000,000 based upon the risk exposure
scenario.
Alternative SC-2A Recreational Risk Scenario $26,057,000
Alternative SC-2B Adjacent Resident w/out Groundwater $28,106,000
Alternative SC-2C Adjacent Resident w/Groundwater $94,514,000
Alternative SC-2D On-Site Resident $98,066,000
Alternative SC-3, Excavation and Off-Site Disposal, is generally the most expensive alternative, with
estimated costs ranging from approximately $54,000,000 to $127,000,000 based on the risk exposure
scenario.
Alternative SC-3 A Recreational Risk Scenario $54,055,000
Alternative SC-3B Adjacent Resident w/out Groundwater $55,553,0004
Alternative SC-3C Adjacent Resident w/Groundwater $120,888,000
Alternative SC-3D On-Site Resident $126,868,000
COMMUNITY ACCEPTANCE
From June 24th, 2004 to August 25th, 2004, EPA held a public comment period to seek input from the
community regarding remedial cleanup alternatives evaluated for the Site. In addition, comments were
received during a public hearing conducted August 4, 2004.
4 The cost estimate for the selected remedy has been revised. More detail is provided in Section L
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On the basis of comments received, there was overwhelming support in the community for the selected
remedy SC-3B. In addition, while there was some support for Alternative SC-2B, it was significantly less
than support shown for Alternative SC-3B. A summary of the comments received and EPA's response to
comments is included in the Responsiveness Summary portion of this ROD (Part 3).
STATE ACCEPTANCE
The Commonwealth of Massachusetts has indicated its support for the selected remedy by providing its
concurrence in the attached letter (Appendix A).
L. THE SELECTED REMEDY
1. Summary of the Rationale for the Selected Remedy
The Selected Remedy is Alternative SC-3B. The selected remedy is a comprehensive remedy for the Site
based upon EPA's determination that groundwater will not be addressed at this Site for the reasons outlined
in Section D of this ROD. EPA has selected this remedy because it believes this cleanup plan is
cost-effective yet still protective. The selected remedy achieves the best balance among the criteria used by
EPA to evaluate alternatives. The selected remedy provides both short-term and long-term protection of
human health and the environment, attains all Federal and State applicable or relevant and appropriate
environmental requirements, reduces the volume and mobility of contaminated soil and sediment, utilizes
permanent solutions to the maximum extent practicable, by removing contaminated material exceeding site
cleanup levels off-site for disposal.
The vast majority of the comments received during the comment period requested that Alternative SC-3B be
selected as the remedy for the Site based upon numerous concerns including regarding the long term
effectiveness and permanence of the proposed alternative.
The selected remedy does not address Site groundwater. Section D. Scope and Role of Operable Unit or
Response Action discussed this determination.
2. Description of Remedial Components
The selected remedy includes excavation and off-site disposal of material exceeding cleanup levels. This
alternative eliminates the exposure pathways to soil and sediment.
A. The primary components of this alternative include:
Coordination with local, state and federal agencies for excavating source area materials
within a wetland and associated buffer zone;
Preparation and implementation of a traffic control plan to adequately manage the increased
volume of truck traffic associated with transportation of chemical and radiological impacted
source material from the site;
Preparation and implementation of a transportation and emergency spill contingency plan;
Relocation of existing power line structures needed to implement the rest of the remedy in
coordination with National Grid.
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Connecting two residences to public water.5 The two residences are identified as Union Road
House 1 and Union Road House 2 in the Remedial Investigation.
Mobilization/demobilization of all personnel and equipment to the site for construction
activities;
Clearing and grubbing areas of the site requiring excavation;
Establishing a survey grid to conduct sequential consolidation of grid cells to minimize
generation of large quantities of groundwater with one open excavation;
Based on the selected risk scenario for the site (Adjacent Resident without Groundwater
Consumption), excavation and off-site disposal of soil and sediment exceeding radiological
and chemical Cleanup levels including dioxin and PCBs as identified in Tables L-l and L-3,
estimated in the FS as approximately 34,445 yd3;
Excavation and off-site disposal of sediment from the Inner Rung and exceeding the cleanup
levels listed in Table L-2, estimated by the FS to be approximately 1,111 yd3 soil/sediment.
The FS estimated this will take a period of one month;
Dewatering of open areas as needed in each area of the Site needed to complete the rest of
the remedial action;
Transportation of all impacted soils via truck and rail to an approved offsite disposal facility;
All excavated soil and sediments disposed of in accordance with TSCA and the TSCA
determination included as part of this ROD;
Placement of clean fill in open areas to backfill to grade and/or wetlands restoration/
replication as appropriate;
Vernal pools and spotted turtle habitat surveyed to focus on the spotted turtle and marbled
salamander and evaluate the habitat for any other rare species or species of special concern
that may be found on the Shpack Site;6
Vernal pools and areas containing rare or species of special concern will be protected if
possible or restored/replicated if impacted - an impact minimization and habitat restoration
plan prepared and followed in conjunction with this work;
5 Installation of the waterline shall comply with the substantiate requirements of the ARARs relating to
protection of wetlands resources, including the Massachusetts Wetlands Protection Act Design will include detailed
plans of the waterline, elevations and inverts, all wetlands resources which may be impacted by the waterline
extension, de-watering methods and the options for installing the waterline at the railroad crossing on Peckham Street,
if necessary
6 The "Rare Animal Observation Forms" and "Vernal Pool Certification Forms" should be completed and
submitted as part of the substantiative requirements relating to the Massachusetts Natural Heritage and Endangered
Species Program (NHESP)
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All work in wetlands areas conducted in accordance with the Wetland Determination
included in this ROD. In addition, work in wetlands, including replication and restoration,
must comply with the Wetlands Protection Act Regulations, 310 CMR 10 as well as all other
ARARs identified for this component of the remedy.7
Installation of a temporary chainlink fence surrounding the entire site, with access gates to
secure the site during the design and construction phases of the cleanup;8
Preparation and implementation of a surface water, sediment and groundwater monitoring
program, including installation of additional wells around the perimeter of the Site;9
• Performance of 5-year reviews to monitor effectiveness of the remedy; 10
Implementation of institutional controls to restrict future use of property and groundwater.11
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 by the EPA Remedial
Project Manager in a technical memorandum added to the Administrative Record for the Site, an
Explanation of Significant Differences or a Record of Decision Amendment, as appropriate.
7 The wetland replication/restoration must include at a minimum, detailed plans illustrating all existing and
proposed contoui elevations, soil profiles for imported soils, a construction schedule, a planting plan including the
number, size, and species of all plants, groundwater elevations, description of the replicated wetland function and
values, physical features that replicate the vernal pool habitat and rare species habitat functions of the existing
wetlands including coarse woody debris, snags and pit and mound topography, and a 5 year monitoring plan The
wetland replication/restoration plan should commence in the first growing season after the construction activity has
been completed The Conservation Commissions of Norton and Attleboro will be given a reasonable opportunity to
review and comment on deliverables relative to wetlands restoration/replication
8 After construction is completed the community members, municipalities, landowners, and other
stakeholders will be consulted to determine the fence should be permanent or removed as part of demobilization
9 The selected remedy includes a long-term monitoring program to include sampling and analysis of data to
ensure that the remedy continues to be effective This will include sediment and surface water sampling of wetlands
near the site ensure that re-contamination is not occurring
10 EPA will review the Site at least once every five years after the initiation of remedial action at the Site to
assure that the remedial action continues to protect human health and the environment If additional action is required
to ensure protectiveness. it will be taken
11 Restrictions would be placed on the Site to prevent residential use or other uses that present unacceptable
risk in the future Groundwater restrictions would also be necessary on the site and for Union Road House 1 and Union
Road House 2 in the form of deed restrictions These restrictions will be enforced by the appropriate government entity
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B. Pre-design and Design Studies
Pre-design studies sufficient to design the selected remedy will include, but not be limited to, the following:
Performance of pre-design and design studies to prepare for the relocation of existing power line structures
needed to implement the rest of the remedy in coordination with National Grid.
Site specific sediment toxicity testing will be conducted during pre-design efforts to ensure that the selected
cleanup standards are protective of the benthic invertebrate community. As part of remedial design, toxicity
testing will be conducted in Chartley Swamp and the onsite seasonal wetlands to confirm that the selected
sediment cleanup levels in Tables L-2 and L-3 are protective of the benthic community. Toxicity testing
will consist of collecting bulk sediment samples for use in ten day chironomid toxicity tests to assess the
impact of contaminated sediment on growth and survival. Three sampling locations will be selected for each
of the exposure areas (i.e. Chartley Swamp and the onsite seasonal wetlands), two in an area near where
COC concentrations are the highest (near the Tongue Area in Chartley Swamp), and one to represent an
area with lower COC concentrations so as to provide a gradient across which potential effects can be
observed and to provide information useful for targeting potential remediation areas.
Sediment sampling will be performed in the inner rung of Chartley Swamp as necessary to more fully
delineate the extent of sediment exceeding cleanup levels in Table L-2.
An assessment of ecological risk posed by soil in the Combined Field and Shrubland habitat (shown in
Figure 4) of the site will be performed utilizing food chain models developed to evaluate receptor risk from
soil in other areas of the site following "Ecological Risk Assessment Guidance for Superfund, Process for
Designing and Conducting Ecological Risk Assessments (EPA 540-R-97-006)".
A design study will be prepared to determine options for limiting the impact of dewatering on wetlands.
3. Summary of the Estimated Remedy Costs
All cost information reported in the ROD are estimates from the Feasibility Study, with an accuracy
expectation of+50 to -30%. These estimates will be refined as the remedy is designed and implemented. The
original estimated cost of the Selected Remedy (SC-3B) as outlined in Table 12B of the Feasibility Study is
$55,553,000.
EPA gathered additional information that indicates that the transportation and disposal of material
exceeding cleanup standards is considerably lower than the cost figures used in the FS. As a result, EPA has
revised the estimated cost of the selected remedy to $43,034,000. See memorandum dated September 24,
2004 from Ed Conroy of Metcalf and Eddy to David Lederer, Remedial Project Manager entitled
"Shpack-T&D Costs" in the Administrative Record for more information.
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 BSD, or a
ROD amendment. This is an order-of-magnitude engineering cost estimate that is expected to be within +50
to -30 percent of the actual project cost.
The Feasibility Study estimated the time for construction of SC-3B at 9-16 months.
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TABLE L-l SOIL CLEANUP LEVELS, SHPACK SITE
Contaminant
Cleanup Leve
Dioxin (TEQ)
1.0 ppb*
Radium 226
3.1 pCi/gm
Uranium 234
220 pCi/gm
Uranium 235
52 pCi/gm
Uranium 238
110 pCi/gm
Arsenic
12 ppm
Benzo(a)anthracene
28 ppm
Benzo(a)pyrene
2.8 ppm
Benzo(b)fluoranthene
28 ppm
Dibenz(a,h)anthracene
2.8 ppm
Lead
1400 ppm
Nickel
Total Uranium
7000 ppm
1100 ppm
Rationale
EPA Directive 9200.4-26*
10-5 excess cancer risk
Blood Level Modelling for an Adult
Exposure
HI= 1
HI = 1
*In accordance with the April 13th, 1998 OSWER Directive 9200,4-26, "one ppb is to be generally
used as a starting point for setting cleanup levels for setting cleanup levels for CERCLA removal
sites and as a cleanup level for remedial sites for dioxin in surface soil involving a residential
exposure. The "adjacent resident, w/o groundwater exposure" scenario on which the remedy is
based assumes approximately 150 days of exposure to site soils, which is essentially equivalent to
an on-site exposure. Therefore, the cleanup goal for dioxin protective of human health is being set
at 1 ppb TEQ.
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Table L-2: Cleanup Levels, Inner Rung, Chartley Swamp
Contaminant of
Concern
Cleanup Level
(mg/kg)
Basis
Arsenic
8.4
Food Chain
model, LOED
Cadmium
6.2
Copper
41
«
Chromium
2,769
Food Chain,
LOAEL
Lead
32
Food Chain
model, LOED
Mercury
0-89
»
Silver
0.89
«
Beryllium
45
Food Chain
Model,
NOAEL
Zinc
1591
Food Chain
Model,
LOAEL
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Table L-3; Cleanup Levels, Sediments in the On-Site Seasonal Wetlands
Contaminant of Concern
Cleanup Level
(mg kg )
Basis
Benzo( a janthraccnc
1.2
Food Cham Model
(LOAF I.)
Benzo(a)pyrene
1.3
Benzo( b )fluoranthen e
1.3
Benzo(k)fluoranthene
1.3
Chrysene
1.3
Dibenz( a,h)anthracenc
1.3
Indenof 1,2,3)pyrene
1.3
Aroclor(1254)
0.27
Arsenic
188
Barium
853
Food Cham Model,
NOAEL
Vanadium
448
Food Chain Model.
LOAEL
DDT
0.027
-
Antimony
39
••
Beryllium
5
Food Chain Model,
NOAIl.
Cadmium
103
Food Chain Model,
Chromium
427
C opper
122
Lead
551
Mercury
0.26
•*
Nickel
7943
"
Silver
187
Food Chain Model,
NOAF.L
Zinc
437
Food Chain Model.
LOAEL
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4.
Expected Outcomes of the Selected Remedy
The selected remedy is based upon a future exposure scenario that envisions a resident that lives next to the
site (adjacent resident) who is connected to a public water supply and therefore does not use site
groundwater for drinking water, etc. The selected remedy does not address groundwater. Section D. Scope
and Role of operable unit or Response Action of this Decision Summary discussed this determination. The
expected outcome of the selected remedy is that the Shpack Landfill Superfund Site will no longer present
an unacceptable risk to adjacent residents via exposure to contaminated soil and sediment and will be
suitable for passive recreational use. Approximately 9-16 months are estimated as the amount of time
necessary to achieve the cleanup levels for the selected remedy.
The selected remedy will also provide environmental and ecological benefits such as restoration of sensitive
ecosystems, protection of endangered species, protection of wildlife, and wetlands restoration.
a. Cleanup Levels
1. Soil and Sediment Cleanup Levels
The anticipated future use of the site is based upon an adjacent resident that does not consume groundwater.
The site is also suitable for passive recreation. The site will not be suitable for residential use or the use of
groundwater as a drinking water.
Soil cleanup levels for compounds of concern in surface and subsurface soil exhibiting an unacceptable
cancer risk and/or hazard index have been have been established such that they are protective of human
health For the selected remedy, soil cleanup levels for known and suspect carcinogenic chemicals of
concern (Classes A, B, and C compounds) have been set at a 10"5 excess cancer risk level considering
exposures via dermal contact and incidental ingestion
Cleanup levels for chemicals of concern in soils having non-carcinogenic effects (Classes D and E
compounds) were derived for the same exposure pathway(s) and correspond to an acceptable exposure level
to which the human population (including sensitive subgroups) may be exposed without adverse affect
during a lifetime or part of a lifetime, incorporating an adequate margin of safety (hazard quotient =1)
The cleanup values that were selected for the adjacent resident without consumption of groundwater (the
selected remedy) are listed in Table L-l. Table L-l summarizes the cleanup levels for carcinogenic and non-
carcinogenic chemicals of concern in soils protective of direct contact with soils
Cleanup levels based on protection of environmental receptors are as stated in Tables L-2 and L-3 for the
Chartley Swamp and the Interior Wetlands
These sediment cleanup levels must be met at the completion of the remedial action throughout the Site
They are consistent with ARARs for sediment, attain EPA's risk management goals for remedial action, and
are protective of environmental receptors
Site specific toxicity testing will be conducted during pre-design efforts to ensure that the selected cleanup
standards are protective of the benthic invertebrate community As part of remedial design, toxicity testing
will be conducted in Chartley Swamp and the onsite seasonal wetlands to confirm that the selected sediment
cleanup levels are protective of the benthic community Toxicity testing will consist of collecting bulk
sediment samples for use in ten day chironomid toxicity tests to assess the impact of contaminated sediment
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on growth and survival Three sampling locations will be selected for each of the exposure areas (i.e.
Chartley Swamp and the onsite seasonal wetlands), two in an area near where COC concentrations are the
highest (near the Tongue Area in Chartley Swamp), and one to represent an area with lower COC
concentrations so as to provide a gradient across which potential effects can be observed and to provide
information useful for targeting potential remediation areas
M. STATUTORY DETERMINATIONS
The remedial action selected for implementation at the Shpack Landfill Superfund 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 adequately 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, the excavation and off-site disposal of all materials exceeding site
cleanup levels will eliminate exposure to these contaminants.
The selected remedy will reduce potential human health risk levels such that they do not exceed EPA's
acceptable risk range of 10"4 to 10"5 for incremental carcinogenic risk and such that the non-carcinogenic
hazard is below a level of concern, in this case the Hazard Index will not exceed 1. 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. In addition, site sediments will be addressed such that they no longer present an
unacceptable risk to ecological receptors. Implementation of the selected remedy will not pose any
unacceptable short-term risks or cause any cross-media impacts.
2. The Selected Remedy Complies With ARARs
The selected remedy will comply with all federal and any more stringent state ARARs that pertain to the
Site. In particular, this remedy will comply with the federal and state ARARs identified in Table 1G of the
FS (for Alternative SC-3B; attached to this ROD).
3. The Selected Remedy is Cost-Effective
In EPA'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)(l)(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.
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From this evaluation, EPA has determined that Alternative SC-3 is cost effective as it meets both threshold
criteria and is reasonable given the relationship between the overall effectiveness afforded by the other
alternative and cost compared to other available options. In evaluating the differences between Alternatives
SC-2B and SC-3B, the decisive factors were that Alternative SC-3B provides the greatest long-term
effectiveness and permanence when compared to the other source control alternative, SC-2B, and also
provides greater reduction in toxicity, mobility, and volume, although not through treatment.
Although the difference in cost between these two Alternatives is large, EPA believes the additional cost is
justified given the uniqueness of the waste material and the risks it presents to the community. EPA also
believes that the cost differential between Alternatives SC-2B and SC-3B for the chemical waste component
of these alternatives may well end up being significantly smaller than estimated in this ROD. This is based
upon EPA's intention to phase the work at the Site with the radiological waste being addressed first.
Because the different types of contamination present at the site may be co-located, the amount of
non-radiological waste that may be left to be disposed of off-site may be, in fact, less than what is estimated
in the FS. As a result, the cost differential between the 2 alternatives in practice may be smaller than
depicted in the FS.
Finally, while Alternative SC-2 has marginally fewer short term impacts than Alternative SC-3 on the
community, the difference is not significant given that these types of impacts are typical during cleanup
operations and can be minimized or eliminated through routine, standard operating procedures.
Given the importance to the community that the remedy selected have the greatest overall effectiveness, the
additional cost associated with SC-3 is justified.
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. In this case because of the nature of the material at the Site, essentially municipal and industrial
waste combined with PCBs, dioxin and radioactive materials, EPA determined that it was impractical from
a technical standpoint to utilize treatment to address this diverse waste material. As a result, neither
alternative relied upon alternative treatment technologies or resource recovery.
The selected remedy provides the greatest long-term effectiveness and permanence by disposing of all
chemical, radioactive, dioxin and PCB material off-site. The selected remedy also provides the greatest
reduction in toxicity, mobility, and volume although not through treatment. The selected remedy would
reduce/eliminate mobility of chemical, radiological, PCB, and dioxin waste material because all of the
material that exceeds cleanup levels will be removed from the Site. The toxicity of the chemical,
radiological, PCB, and dioxin waste material would be greatly reduced/eliminated because all of the
material that exceeds cleanup levels will be removed from the Site. In addition, because all soil and
sediment above cleanup levels established for chemical, radiological, PCB, and dioxin waste material will
be removed from the site, the volume of this contamination is greatly reduced/eliminated, although not
through treatment. The selected remedy has acceptable short term impacts to the community and workers
that can be minimized or eliminated through routine, standard operating procedures. The selected remedy is
easily implementable and the cost is reasonable given the overall effectiveness of this remedy. The selected
remedy also has significant support from the community and the Commonwealth of Massachusetts.
Alternative SC-2B, on the other hand, was actively opposed by most in the community that provided input
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on remedy selection. This leads to the conclusion that the selected remedy provides the best balance of
trade-offs among the alternatives.
5. The Selected Remedy Does Not Satisfy the Preference for Treatment as a Principal Element
The selected remedy does not satisfy the statutory preference for treatment as a principal element. In this
case because of the nature of the material at the Site, essentially municipal and industrial waste combined
with PCBs, dioxin and radionuclides, EPA determined that it was impractical from a technical standpoint to
utilize treatment to address this diverse waste material.
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 adequate protection of human health and the
environment.
N. DOCUMENTATION OF SIGNIFICANT CHANGES
EPA presented a proposed plan that provided for off-site disposal and consolidation with capping for
remediation of the Site on June 23, 2004. This preferred alternative included off-site disposal of PCB,
dioxin and radioactive waste, consolidation and capping of remaining waste material and construction of a
water line. EPA reviewed all written and verbal comments submitted during the public comment period. It
was determined that Alternative SC-3B would be selected in this Record of Decision, as opposed to SC-2B
as originally identified in the proposed plan.
O. STATE ROLE
The Massachusetts Department of Environmental Protection has reviewed the various alternatives and has
indicated its support for the selected remedy. 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 MA DEP concurs
with the selected remedy for the Shpack Landfill Superfund Site. A copy of the declaration of concurrence
is attached as Appendix A.
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PART 3
RESPONSIVENESS SUMMARY
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TABLE OF CONTENTS
PREFACE
A. OVERVIEW OF PROPOSED PLAN
B. SITE HISTORY AND BACKGROUND ON COMMUNITY INVOLVEMENT AND CONCERNS
C. SUMMARY OF PUBLIC COMMENTS AND AGENCY RESPONSES
ATTACHMENT A: Transcript of public hearing (August 4, 2004)
ATTACHMENT B: Written comments received during comment period (June 24 to August 25, 2004)
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SHPACK LANDFILL SUPERFUND SITE RESPONSIVENESS SUMMARY
PREFACE
The U.S. Environmental Protection Agency (EPA) held a 30-day public comment period from June 24th to
August 25th, 2004, to provide an opportunity for public input on the June 2004 Proposed Plan to address
contamination at the Shpack Landfill Superfund Site (the "Site") in Norton/Attleboro, MA. EPA prepared
the Proposed Plan based on the results of the human-health risk assessment, ecological risk assessment,
remedial investigation data evaluation reports, and the Commonwealth of Massachusetts groundwater use
and value determination. All documents that were used in EPA's selection of the preferred alternative were
placed in the Administrative Record which is available for public review in Norton Public Library, and at
the EPA Records Center in Boston, Massachusetts.
The purpose of this Responsiveness Summary is to document EPA's responses to the questions and
comments raised during the public comment period. EPA considered all the comments summarized in this
document before selecting a final remedy for the Shpack Landfill Superfund Site
This Responsiveness Summary is organized into the following sections:
A. Overview of Proposed Plan. This section briefly outlines the plan proposed to the public in June
2004 for addressing the contamination at the site.
B. Site history and background on community involvement and concerns. This section provides a brief
history of the site and an overview of community interests and concerns regarding the site.
C. Summary of comments received during the public comment period. This section summarizes and
provides EPA's responses to the oral and written comments received from the public during the
public comment period.
A copy of the transcript from the public hearing held on Thursday, August 4, 2004, in Norton,
Massachusetts, is included as Attachment A to this Responsiveness Summary. The written comments
received during the comment period are included in Attachment B.
A. OVERVIEW OF PROPOSED PLAN
On June 23th, 2004, the Proposed Plan for the Shpack Landfill Superfund Site was released. Its main points
included:
Clean up based upon a future scenario in which a resident living next to the Site (adjacent resident)
is connected to a public water supply and does not drink the groundwater at the site
The public waterline will be extended to include two residences adjacent to the landfill that are
currently on private wells.
Approximately 10,500 cubic yards of soil containing radiological contaminants of concern
above the cleanup levels will be excavated and disposed of off-site.
Approximately 2250 cubic yards of dioxin and PCB-contaminated sediment will be
excavated and disposed of off-site.
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Contaminated sediments in wetland areas of the site will be consolidated to an upland area
on-site and the disturbed wetlands will be restored and/or replicated.
The upland area will be capped to prevent exposure to contaminated waste.
The site will be fenced to control access and institutional controls will be put in place to
ensure the remedy remains protective in the long term.
Groundwater will continue to be monitored and the cap maintained in the long term.
Based on the presence of ALI Landfill and other technical issues, the proposed plan did not address
groundwater contamination at and near the site. It addressed the risk of exposure to contaminated
groundwater by installing a public waterline to the two homes adjacent to the site that are currently
on private wells.
B. SITE HISTORY AND BACKGROUND ON COMMUNITY INVOLVEMENT AND
CONCERNS
Site History
Between 1946 and the 1970's, the Shpack Site received domestic and industrial wastes, including low-level
radioactive waste. The filled areas where the wastes were dumped are overgrown and entirely enclosed by a
chain link fence. The Site itself is relatively flat with vegetated minor depressions and knolls and was
formerly a flat wetlands area. A powerline transmission corridor divides the Site into two portions. The Site
is bounded on two other sides by the Chartley Swamp that drains under Union Road to Chartley Pond.
There are two homes on private drinking water wells within 500 feet of the Site.
In 1980, the Shpack Site was added to the Department of Energy's (DOE) Formerly Utilized Remedial
Action Program (FUSRAP), which dealt with the legacy of the nation's early atomic energy programs. The
uranium at the site is thought to have originated from local businesses that constructed reactor cores for the
early naval propulsion program from the early 1950's until the mid-sixties.
A more detailed description of the Site History can be found in Section 1.2.2 of the RI Report.
In 1978, a concerned citizen who had detected elevated radiation levels at the site contacted the Nuclear
Regulatory Commission (NRC). The NRC conducted an investigation that confirmed the presence of
radioactivity above background levels. The NRC determined that certain operations associated with
government activities might have resulted in the deposition of radioactive materials within the Shpack
Landfill. The primary constituents of concern found were radium and uranium. It is not known exactly when
these radioactive materials were deposited at the site.
The NRC investigation concluded that the Shpack Landfill was a candidate for the FUSRAP program. On
behalf of the NRC, Oak Ridge National Laboratory (ORNL) conducted a radiological survey in 1980 that
identified metallic wastes containing uranium of various enrichments. The ORNL report confirmed the
NRC preliminary findings and defined general areas of radiological contamination. In 1998, FUSRAP
responsibility was transferred from DOE to the United States Army Corps of Engineers (US ACE), and a
gamma walkover survey was performed to further delineate the radiological contamination.
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In October of 1981, a security fence was installed around the site on behalf of DOE to prevent unauthorized
access. With the exception of the area located in the section of the site known as the Tongue Area and an
approximately 1,000-foot section of replacement fence, this fence is the same fence that currently is located
on the Site. Additional studies conducted by DOE between 1982 and 1984 identified chemical
contamination (volatile organic compounds (VOCs) and metals) in groundwater. In 1984, EPA evaluated
the site to determine if it should be listed on the National Priority List (NPL). The site was added to the list
in June 1986.
A summary of preliminary investigations performed at the Site prior to 1990 is included in Table 1 of the
RI. These investigations included sampling of various environmental media and primarily focused on
evaluating radiological impacts at the Site.
In 1990, a group of potentially responsible parties formed the Shpack Steering Committee (SSC) and
individual companies comprising the SSC entered into an Administrative Consent Order (ACO) with EPA
(EPA Docket No. 1-90-1113, June 24,1990) which required them to conduct the Remedial Investigation/
Feasibility Study (RI/FS) for the Site. In November 1991, the SSC prepared and submitted a Site
Characterization Work Plan (SCWP) for the first phase of the RI, known as "Phase IA". Between 1991 and
1992, the SSC implemented Phase IA of the RI, which was a comprehensive investigation of potentially
impacted media at the Site. The Phase IA identified chemical impacts in soil, groundwater, sediment and
surface water at the site. Non-radioactive constituents of concern identified on Site during the Phase IA
include:
Volatile organic compounds (VOCs);
Semi-volatile organic compounds (SVOCs);
Polychlorinated biphenyls (PCBs);
Pesticides;
Dioxins/furans; and
Inorganics.
The results of the Phase IA RI activities were documented in ERM's 1993 Initial Site Characterization (ISC)
Report. In addition, the Phase IA contains a detailed summary of the previous investigations listed in Table
1 of the RI. With the exception of residential well monitoring activities, no chemical investigation activities
were performed at the Site after the Phase IA ISC Report.
In 1999, the SSC in conjunction with EPA, the Corps of Engineers FUSRAP program, and DEP began
preparation of work plans to implement Phase IB of the RI. The Phase IB activities included the following:
• Monitoring well Installation
Groundwater sampling
Surface water and sediment sampling
Soil sampling
Tar area delineation
Well functionality and site survey
Site fence extension
Test pit excavation in Tongue Area
Groundwater gauging
Residential well sampling
Surface water drainage characterization
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The Phase IB activities were completed in 2003. The Results of the Phase IB investigations, as well as the
prior investigations are documented in the RI Report.
Community Involvement and Concerns
Throughout the Site's history, community concern and involvement has been high. EPA has kept the
community and other interested parties apprized of Site activities through informational meetings, fact
sheets, press releases, and public meetings. Below is a brief chronology of public outreach efforts.
Local residents formed the Citizen's Advisory Shpack Team (CAST) to monitor Site activities.
CAST has been actively involved in organizing community review of activities conducted at the Site
and providing input to the various government agencies involved at the Site.
On numerous occasions during 2000-2004, EPA and DEP held informational meetings at the
Solmonese School in Norton, Massachusetts to update the community on the results of the Remedial
Investigation and Feasibility Study.
On November 20, 2003, EPA held an informational meeting in Norton, Massachusetts to discuss the
results of the Remedial Investigation.
On June 18, 2004, EPA published a notice of Proposed Plan in the Attleboro Sun Chronicle. The
plan was made available to the public on June 24, 2004 at the Norton Public Library (June 25th) and
the EPA office repository.
The Proposed Plan contained a proposed determination with regard to offsite disposal of
PCB-contaminated material pursuant to the Toxic Substances Control Act (TSCA). The Proposed
Plan also contained a draft finding that there is no practical alternative to conducting work in the
wetland areas of the Site under Section 404 of the Clean Water Act and Executive Order No. 11990.
There were no proposed waivers of ARARs included in the Proposed Plan.
On June 23, 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 previously been
involved at the Site. At this meeting, representatives from EPA, MA DEP, and the US Army Corps
of Engineers answered questions from the public.
On June 24, 2004, EPA made the administrative record available for public review at EPA's offices
in Boston and on June 25th at the Norton Public Library. This will be the primary information
repository for local residents and will be kept up to date by EPA.
From June 24, 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 requested and as a
result, the comment period was extended to August 25, 2004.
On July 21, 2004, EPA published a notice of the extension of the comment period as well as a
rescheduled public hearing date (August 4, 2004) in the Attleboro Sun Chronicle.
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On August 4, 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.
C. SUMMARY OF PUBLIC COMMENTS AND AGENCY RESPONSES
This Responsiveness Summary addresses comments pertaining to the Proposed Plan that were received by
EPA during the public comment period (June 24rd to August 25, 2004). Many individuals submitted written
comments. Six individuals, including Congressman Barney Frank, and Norton Board of Selectman
Chairman Bob Kimball submitted oral comments at the public hearing on August 4, 2004. What follows are
EPA's responses to these comments. Where possible, EPA has grouped similar comments, and prepared a
single response. A copy of the public hearing transcript is included as Attachment A. Copies of the written
comments are included as Attachment B.
A. Comments in Support of Alternative SC-3B
1) The overwhelming majority of the comments supported selection of Alternative SC-3B over EPA's
proposed Alternative SC-2B. In support of these comments, commenters pointed to a number of
factors:
Contamination should be taken off-site and not left on-site
Long-term integrity of the cap under SC-2B is unsure. The permanence of SC-2B is in doubt
over the long term.
Volume and mobility reduction is superior under SC-3B versus SC-2B.
Reliability of fencing and institutional controls will be poor in the long run. Trespassers will
be able to access the site despite fencing and institutional controls. The powerline
transmission right of way through the site presents difficult issues as well in terms of
restricting access. Fencing restricts wildlife movement.
Selection of SC-3B over SC-2B would allow reduction in monitoring and eliminate concern
regarding trespassing thereby saving money.
Mobility of contaminants has been underestimated by EPA. Removal under SC-3B will be
more protective.
Permanent elimination of contamination is the only complete way to address risk of harm
from contaminants
RESPONSE TO COMMENT #1
After review of the comments received and taking into account the wishes of the community and the support
of the Commonwealth of Massachusetts, EPA agrees that Alternative SC-3B should be the selected remedy
for the Site. As outlined in the analysis of the nine selection criteria under CERCLA, SC-3B provides
greater long term protection and permanence and also results in a greater reduction in volume mobility and
toxicity by removing all material that presents an unacceptable risk from the site.
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Although EPA uses institutional controls at sites to prevent exposure, EPA agrees that physical controls
such as fencing are not as effective in the long term to restrict exposure in remote areas where trespassers
are a concern, and are difficult to enforce at a site such as this. It should be noted that although the selected
remedy will no longer require institutional controls to protect the integrity of the cap, it will still require
institutional controls to restrict groundwater use and to make sure that residential housing is not permitted
on the Site in the future. EPA believes these types of institutional controls are more easily enforced in the
long-term than in situations where trespassing is a concern. In addition, EPA agrees that selection of SC-3B
over SC-2B will allow a reduction in monitoring at the Site and will eliminate concern regarding trespassing
thereby providing some slight cost savings.
Although EPA agrees that it is appropriate to remove all waste from the Site in this instance, it should be
noted that EPA has wide regulatory authority in fashioning remedial cleanup plans at Superfund sites under
CERCLA. The definition of "remedial action" under CERCLA is broad and does allow for a variety of
response actions including capping waste in place. In this particular case, given the unusual nature and
variety of materials present at this Site, as well as State and community support, EPA agrees that removal of
this waste material to an off-site location is an appropriate response action. (See also discussion of
presumptive remedy for landfill discussion below)
2) In providing comments supporting selection of Alternative SC-3B over EPA's proposed Alternative
SC-2B, a number of commenters expressed concern with the long-term operation and maintenance
(O&M) costs associated with Alternative SC-2B as they relate to funding, oversight and long term
protectiveness. Included in these comments were the following concerns:
oversight of site O&M is impracticable over the long term under scenario SC-2B
the Town of Norton and or the State could be responsible for O&M and other future costs in
the long term because private Potentially Responsible Parties (PRPs) may not be viable in the
future
the Town of Norton should not bear financial burden for the cleanup
RESPONSE TO COMMENT #2
Cost estimates in the Feasibility Study and Proposed Plan for the SC-2 alternatives did include an estimate
of operation and maintenance costs. Notwithstanding, by selecting Alternative SC-3B, concerns raised by
commenters regarding O&M have been addressed. Because all waste material that presents an unacceptable
risk will be excavated and disposed of off-site, only limited monitoring will be required in the long-term to
ensure that the remedy remains protective. As a result, the cost of this long term obligation is, compared to
this obligation in Alternative SC-2B, quite small.
3) Several comments were received suggesting that it was not appropriate to catagorize the Shpack site
as a "landfill" as it was really an essentially illegal unregulated dump. In addition, commenters noted
that the nature of material disposed of at the Shpack Site was not consistent with materials disposed
of at other landfills.
RESPONSE TO COMMENT #3
After review of the comments presented and information regarding the nature and extent of the
contamination at this Site, EPA agrees that this particular Site presents several unique characteristics that
distinguish it from typical landfills or municipal landfills.
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Typical landfills/municipal landfills do not contain radioactive waste. At this Site approximately one-third
(1/3) of the material that the Feasibility Study estimated must be addressed is radiological in nature. In
addition, because a large portion of the remaining chemical waste material is located in wetland areas,
wetland requirements necessitate that this material also be excavated and moved (placed under a cap as in
SC-2B or taken off-site as required in SC-3B). Municipal landfill closures typically do not require
significant excavation and movement and removal of large quantities of waste material to occur throughout
the landfill prior to putting the cap in place, as is the case here.12 As a results, the major premise of landfill
closure, that all or most waste will be covered in place, does not exist here because of these unique site
specific factors.
In addition, this Site is relatively small in size and the amount of waste material that must be addressed is
also relatively small and near the surface when compared to most landfills. One of the major reasons that
waste is covered in place at municipal landfills is that the size of the landfill and the quantity of waste that
needs to be addressed is so large that it is not cost effective or practicable to remove the waste. In addition,
the waste requiring corrective action at typical landfills is often buried at great depth, below the ground
surface, making removal of the waste impracticable.
This is simply not the case at Shpack where the cap area would extend 2 to 3 acres in size and the waste that
needs to be addressed is approximately 34,000 cu yds (including radiological and non-radiological waste).
Compared to other landfill closures in Region I, the estimated volume of the material required to be
removed in the selected remedy is relatively small. In addition, the material requiring excavation under the
selected remedy is, in general, close to the surface for the "adjacent resident without groundwater
consumption" exposure scenario selected here. These factors make removal of the waste above cleanup
levels practicable.
4) Comments were also received noting that the Attleboro Landfill (ALI) is not properly capped and
the State has not enforced its regulations with regard to that site, and that Alternative SC-2B presents
the same type of uncertainty. For this reason Alternative SC-3B is preferred because it avoids the
issue of effectiveness of capping in the long term.
RESPONSE TO COMMENT #4
By selecting Alternative SC-3B, concerns raised by commenters regarding enforcement of capping
requirements have been addressed. Because all waste material that presents an unacceptable risk will be
excavated and disposed of off-site, capping of the Site will no longer be required. As a result, there should
not be any concern regarding EPA's ability to effectively oversee a capping remedy in the long term.
5) Several commenters also expressed concern that the proposed Alternative SC-2B did not take into
account the community's desire that the Site be used for passive recreation in the future.
RESPONSE TO COMMENT #5
In evaluating alternatives for cleanup of this Site, EPA looked at four different exposure scenarios that
could represent potential future uses of the Site:
12 Some landfill closures might require small limited "hot spot" removals but not excavation and
removal of large portions of landfill material as is necessary here (1/3 of the waste material at Shpack)
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Recreational User
Adj acent resident w/out groundwater exposure
Adj acent resident w/groundwater exposure
On-site resident
Because each exposure scenario was based upon different assumptions regarding activities that would occur
at the site in the future, the result was that different quantities of waste material were addressed under each
scenario. As result, under the Recreational User scenario, the smallest amount of waste would be addressed.
The On-site Resident required the most waste be addressed with the two Adjacent Resident scenarios
requiring amounts in between these other two scenarios be addressed.
By proposing the "adjacent resident w/out groundwater exposure" scenario, EPA believed it was addressing
the community's desire that the Site be safe in the future for passive recreational use because this scenario
required more stringent cleanup levels be met than the "recreational user" scenario thereby ensuring that the
Site was safe as well for passive recreational use.
Based upon the comments received, EPA now understands that what the community meant by expressing its
preference for passive recreation was that not only would the Site be safe for these activities (EPA's view)
but that also the physical nature of the cleanup activities not interfere with or present an impediment to
passive recreational activities. Clearly based upon comments received, constructing a cap would require
some restrictions on recreational activities that would not be acceptable to many in the community. Because
EPA has selected Alternative SC-3B, the remedy will no longer present a physical impediment to the types
of passive recreation envisioned by many in the community.
6) Commenters also expressed concern that installation of the water line will increase the development
of land surrounding the Site thereby exposing an increased population to risks from the Site should
Alternative SC-2B be selected
RESPONSE TO COMMENT #6
By selecting Alternative SC-3B, EPA has addressed this concern. All waste material that presents an
unacceptable risk will be excavated and disposed of off-site. As a result, there should not be any concern
that an increased population will be a risk in the future from the Site.
EPA notes, however, that both Alternatives SC-2B and SC-3B were based upon future use scenarios that
envisioned residents living next to the site and that also visit the site periodically. As a result, EPA believes
it has taken into account in scoping out both of these Alternatives the types of exposure likely to occur to
people who live near the Site. That being said, regardless of how many people ultimately live near the site,
EPA believes that either alternative would be protective of human health.
7) One comment was received that questioned whether Alternative SC-2B would be protective should
an earthquake occur.
RESPONSE TO COMMENT #7
The likelihood of a seismic event large enough to adversely impact a properly designed landfill cover is
considered remote, and in that unlikely occurrence, repairs could be made. In any case, Alternative SC-3B
has been selected.
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8) One comment was received stating that Alternative SC-2B did not take into account the effect future
releases on drinking water that might be used by communities from a proposed water treatment plant
on the Taunton River. Alternative SC-3B does address this concern.
RESPONSE TO COMMENT #8
No impact has been noted within Charley Pond, the closest open water body to the Site. In addition, given
the large number of stream miles to the location in question, it is very unlikely any measurable impact could
be detected at this proposed water treatment plant..
9) Comments were also received from parties concerned with the number of cases of cancer in the
community and, as a result, the commenters believe Alternative SC-3B is the best alternative
because it removes contamination from the community.
RESPONSE TO COMMENT #9
The RI document focused on current and future exposures and risks. The selected remedy is protective of
the community now and in the future.
10) Commenters also expressed their belief that Alternative SC-3B is cost effective.
RESPONSE TO COMMENT #10
In selecting Alternative SC-3B, EPA agrees that the remedy is cost effective.
11) One comment was received that stressed that the concerns of Norton residents were more important
than the concerns of Attleboro and other communities.
RESPONSE TO COMMENT #11
Under the Superfund law, EPA is required to take into account the wishes of the community in making
decisions regarding how to clean up Superfund sites. In this case, EPA has received comments from various
parties including residents or representatives of both communities and has taken all comments into account
in reaching its decision regarding cleanup of the Site.
B. Conduct of the work
1) One commenter asked that completion of ALI capping and the work at Shpack be coordinated.
RESPONSE TO COMMENT #1 - ALI and the Shpack Landfill are being addressed by different
government entities and under different environmental laws. The cleanup at ALI is being overseen by
Massachusetts DEP under state law while the cleanup at Shpack is being overseen by EPA under the federal
Superfund law. However, to the extent there are opportunities to coordinate activities as the clean up occurs,
EPA will attempt to coordinate with appropriate State officials.
2.) Other comments were received asking that EPA coordinate with the local public safety officials
regarding truck routes. A related comment suggested that rail transport should be arranged if
possible to minimize impacts/risks to vehicular traffic.
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RESPONSE TO COMMENT #2 - EPA will work closely with the affected communities regarding short
term impacts from the ongoing cleanup to ensure that impacts are minimized or eliminated and concerns
addressed to the extent possible. As part of the remedial design, rail transport will be evaluated to see if it is
a feasible alternative to transport of waste material by truck.
3) One commenter suggested that there would be significant costs savings if the waterline was
extended from Attleboro rather than from Norton.
RESPONSE TO COMMENT #3 - As part of the remedial design process, location of the waterline will be
reviewed and options regarding location of the waterline evaluated.
4) A number of comments were received that addressed habitat and wetlands issues during the course
of construction. These comments included the following:
Rare Habitat, rare species, vernal pools and wetlands resources should be protected/impacts
to these resources should be minimized during construction activities and these resources
should be restored and/or replicated if impacted.
Options for dewatering wetlands and a transportation and emergency spill contingency plan
should be included in the ROD.
RESPONSE TO COMMENT #4
In response to these comments, additional requirements have been included in the description of the selected
remedy to better address the protection of rare habitats, rare species, vernal pools and wetlands resources
during the construction of the remedy. In addition, more detail has been added to the selected remedy
regarding appropriate restoration and replication in these areas of special concern.
5) In addition, the Norton Conservation Commission has requested that certain activities obtain permits
for work conducted in areas of the Site over which it has jurisdiction. The State National Heritage &
Endangered Species Program (NHESP) has also requested plans be submitted to it for approval.
RESPONSE TO COMMENT #5
CERCLA Section 121(e)(1) reads :
"No Federal, State, or local permit shall be required for the portion of any removal or remedial action
conducted entirely onsite, where such remedial action is selected and carried out in compliance with this
section"
Onsite, under the Superfund law, is defined as: "the area! extent of contamination and all suitable areas in
very close proximity to the contamination necessary for implementation of the response action."
Because the work being conducted at the site is entirely onsite for purposes of the Superfund law, the
permitting and approval requirements noted by the Conservation Commission and NHESP, do not apply. As
a result, permits will not be applied for and documents and plans will not be forwarded for the purposes of
obtaining formal approval.. However, EPA will provide the Conservation Commission and NHESP the
information normally requested by their respective programs and provide them with a reasonable
opportunity to review and comment regarding appropriate activities as cleanup work occurs at the Site.
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6) Comments were also received requesting that Rare Animal Observation Forms and Vernal Pool
Certification Forms be submitted
RESPONSE TO COMMENT #6
The substantiate requirements of the state and local wetlands protection programs, as well as those operated
by the Massachusetts NHESP will be met during the course of the cleanup. The information required by
these forms will be collected and the substantiative requirements of appropriate programs will be met.
7) The Board of Health stated that it may require specific monitoring during cleanup operations.
RESPONSE TO COMMENT #7 - EPA is not required to seek formal approval or permits when
conducting work on-site under the Superfund statue. However EPA will, of course, work closely with the
Board of Health to address their concerns during the construction phase of the remedy and meet the
substantiative requirements of the regulatory requirements normally imposed by the Board of Health.
8) The Board of Health also expressed concern that local roads could not support truck operations.
RESPONSE TO COMMENT #8
One of the items to be considered during the remedial design will be the coordination of truck hauling
routes with local officials to ensure that truck operations are operated in a safe manner. One of the issues to
be considered is the routes taken to the disposal site.
9.) One comment was received asking how residents would be protected during removal of
contaminated soil.
RESPONSE TO COMMENT #9
Standard dust suppression techniques which have been shown to be highly effective will be used during soil
excavation. These could include, but are not limited to, frequent watering down of areas in which work is
being accomplished, the use of foam suppressants, and limiting the size of the open face of excavation at
any one time. In addition, air monitoring both at the work site and the perimeter will be conducted during
construction activities to ensure that the work is conducted safely. Finally, trucks leaving the "hot zone" of
contamination will be decontaminated before they are allowed to leave the contamination reduction zone
and the site itself.
10.) One comment was received asking for clarification of the safety of the water supply around the site.
In a related comment, requests were received for the remedy to include waterline hookups for 2
properties in Attleboro on Peckham street.
RESPONSE TO COMMENT #10
Water levels in monitoring wells screened in the shallow zone at the Shpack site suggest that groundwater
flow is semi-radially outward toward the northwest, north, northeast, east, and southeast. The only direction
in which water levels are higher immediately off the site is to the southwest, beneath the ALI Landfill.
Although the groundwater contours for the shallow zone suggest that flow would be toward the private
water supply wells north of the site at Union Road House 1 and Union Road House 2, the shallow
groundwater flow is apparently predominantly downward at the site, into the deeper overburden. This
concept is supported by both water level and water quality measurements.
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The positions of these two homes relative to the site (in particular their close proximity to the site) and to
highly contaminated wells make them potentially vulnerable to future contamination if hydrologic
conditions change (e.g., water levels in nearby ponds and wetlands change, drainage characteristics at the
Shpack or ALI sites are altered). Therefore, EPA has determined that a sufficient threat exists at the Site to
support installation of a waterline to these two houses. This determination is consistent with EPA's 1988
"Guidance Document for Providing Alternate Water Supplies":
"In addition, remedial action may be taken based on the threat of future contamination in cases where these
criteria are not yet exceeded ("MCLs"). If potable wells are not currently contaminated, it must be
determined they will be threatened with contamination before a final remedy addressing ground water
contamination can be implemented."
While sampling has detected MTBE and arsenic in residential drinking water wells in Attleboro on
Peckham Street, EPA does not believed that these detections are related to the Shpack Site. Because the
contamination in these wells is not related to the Shpack Site, EPA cannot address waterline hookups for
these properties as part of this cleanup action.
11.) One comment was received from the Norton Police Department expressing concern that they would
be required to patrol and have a security presence at the Site.
RESPONSE TO COMMENT #11
During the construction of the selected remedy, requirements will be put in place to ensure that the Site is
secure and that traffic flow is consistent with public safety concerns. The project design will include
planning with municipal officials regarding public safety concerns, including traffic concerns, and
especially routes of trucks and other vehicles on public roads.
C. Comments in Support of Alternative SC-2B
Although the overwhelming number of comments supported selection of Alternative SC-3B, some
comments were received in support of Alternative SC-2B.
1.) One commenter noted that landfills are typically capped in accordance with the presumptive landfill
guidance. In a related comment, it was noted that EPA has effectively capped sites like this one in
the past.
RESPONSE TO COMMENT #1 - EPA's initial thought when scoping out general response actions at the
Site was that this Site might be an appropriate candidate for EPA's presumptive remedy guidance for
municipal landfills. Numerous comments were received from members of the community objecting to this
characterization of the Site. After a review of these comments as well as revisiting the nature and extent of
contamination at the Site, EPA agrees with those commenters who believe that this is not an appropriate site
to use EPA's presumptive remedy guidance.
The Shpack property has always been a privately owned and operated. The Shpack Site is also relatively
small in nature 9.4 acres total in size. In addition, the nature of the waste found at the Site is unique in that it
includes large quantities of radioactive waste, as well as smaller quantities of PCBs and dioxin in addition
to chemical wastes. All alternatives evaluated in the Proposed Plan involved excavation and off-site
disposal of radiological material. In addition, both the dioxin and PCB waste are required to be excavated
under all alternatives except the no action alternative. These contaminants are located through out the site,
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not just limited to small discrete "hot spots", although some "hot spots" are present. Significant amounts of
contamination are also present in wetland areas of the site and must be excavated under any cleanup
scenario consistent with wetlands requirements. As a result, significant excavation and movement of
contaminated soil throughout the Site will be necessary to excavate waste that exceeds cleanup levels for
these contaminants. In addition, much of the material exceeding cleanup levels is located near the ground
surface and can be excavated and removed from the site; whereas in typical much large municipal landfill
sites, the depth and volumes of contaminants make such an effort impracticable. These factors, particularly
when viewed together, clearly indicate that this Site is uniquely different from most municipal landfills.
Given these factors, EPA has decided that the presumptive remedy guidance is not appropriate for use at
this Site.
2.) Another commenter noted that SC-2B is preferable because of the hazards of transportation of waste
off-site, and excavation hazards due to air borne contamination. In a related comment, concerns were
raised regarding short term effects from Alternative SC-3C citing the increase in truck traffic etc.
that would result from this cleanup plan.
RESPONSE TO COMMENT #2
While it is true that the selected remedy will require greater quantities of waste material be excavated and
transported thru the community, EPA believes that the additional risks posed by these activities can be
effectively addressed by proper air monitoring, dust suppression and health and safety requirements. Trucks
leaving the site will be decontaminated. Excavation and off-site transportation of wastes have been safely
conducted at numerous sites and measures to address associated impacts are routine in the waste disposal
arena.
In addition, EPA believes this commenter has over estimated the short term impacts to the community from
hauling off-site the estimated additional 24,000 cubic yards of material required to be shipped off-site under
Alternative SC-3B. First, both Alternatives SC-2B and SC-3B require all radiological waste to travel thru
the community for off-site disposal (approximately 12,000 cubic yards). While EPA agrees that Alternative
SC-3B will have greater transportation needs than Alternative SC-2B, the magnitude of the impact on the
community is not overwhelming. For example, assuming the commenter is correct that Alternative SC-3B
would require 4,000 additional truck trips, these trips would be spread out over the several months estimated
to complete Alternative SC-3B,13 Also as discussed previously, part of remedial design will evaluate the use
of rail transportation to remove contamination from the area to decrease the number of trucks using roads to
carry the material. This could greatly impact the number of truck trips. Finally, although the Town of
Norton and local residents expressed some concern regarding coordination regarding truck traffic there was
little concern shown by the community regarding other short term impacts that would be borne by the
community.
3) One comment was received supporting Alternative SC-2B because the commenter was concerned
that shipping waste off-site would basically just be moving the problems at Shpack to a different
location and the commenter concluded that the risks associated with this do not justify the result.
RESPONSE TO COMMENT #3
Although it is true that off-site disposal does, in some way move the problem from one location to another,
the ultimate disposal location for this waste material is to a location engineered, designed and constructed to
13 Assuming 150 work days, for example, this would amount to <30 additional truck trips spread
out over a typical 10-12 work day.
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dispose of this material safely in the long term and regulated under the appropriate set of environmental
laws and regulations. Any potential exposure that might occur during excavation and transportation can be
addressed through proper engineering and safety practices. In addition, waste that is shipped off-site for
disposal is required to meet stringent requirements for the transport of the material as appropriate.
4) One comment was received supporting Alternative SC-2B noting it will be protective of human
health and the environment, most reliable from an implementation standpoint, has the fewest short
term impacts and can be conducted in the shortest period of time.
RESPONSE TO COMMENT #4
EPA agrees that Alternative SC-2B is protective of human health and the environment. However, EPA does
not agree that there are significant differences between Alternatives SC-2B and SC-3B in terms of
implementability, short term impacts and construction time. EPA has conducted many excavation clean ups
of this magnitude. Excavation does not involve complicated or innovated technologies. Regardless of
whether Alternative SC-2B or SC-3B is selected, significant excavation would be required as both
alternatives require excavation of the radiological, PCB and dioxin contaminated material from the Site,
approximately 1/3 of the waste material which must be addressed. In addition, Alternative SC-2B requires
moving significant amounts of contaminated soil during the consolidation phase. The difference in short
term impacts between the two alternatives is not significant as risks can easily be addressed by sound
engineering and safety practices. Again both alternatives require significant excavation and SC-2B also
requires large amounts of contaminated material to be moved during the consolidation phase and capping
phase. Finally, the estimated difference in construction time between the two Alternatives is negligible -
18-25 months for SC-2B versus 9-16 months for SC-3B (See additional Responses to Comment regarding
reliability and implementation).
5) One comment was also received suggesting that the cap for Alternative SC-2B could be enhanced by
planting a native New England wildflower meadow with additional wild life enhancements. In a
related comment, such a use would ensure that the community has a stake in the future of the Site,
thereby helping to ensure the remedy remains effective in the long term.
RESPONSE TO COMMENT #5
Although Alternative SC-2B has not been selected, the ideas presented are equally applicable to the selected
remedy and will be considered during the remedial design. It is not clear to EPA that the beneficial reuse
suggested significantly impacts either the long term effectiveness or permanence of this alternative.
6) One comment was also received questioning whether the selected remedy was "cost-effective" given
that Alternative SC-2B provides greater net risk reduction . In a related comment, the commenter
questioned whether selection of Alternative SC-3B as the remedy would be consistent with EPA
Guidance.
RESPONSE TO COMMENT #6
After carefully reviewing the EPA guidance cited by the commenter, EPA strongly believes the selection of
Alternative SC-3B is consistent with its guidance. First, as discussed in ROD, the selected remedy is cost-
effective. More than one Alternative can be "cost-effective" when evaluating cleanup alternatives. Short
term impacts under Alternative SC-3B would be controlled through the use of engineering controls such as
dust suppressants, air monitoring and truck decontamination procedures common in the HAZMAT industry.
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As a result, there are negligible differences in short term impacts between SC-2B and SC-3B. In addition,
there are negligible differences in the implementability of either alternative as both involve routine waste
management. EPA disagrees that Alternative SC-2B provides greater net risk reduction because under
alternative SC-3B, waste exceeding cleanup levels is no longer present at the site. The selected remedy has
greater long term effectiveness and permanence. EPA's presumptive remedy guidance is not applicable to
this Site as discussed above, and, as a result, the related guidance regarding reuse of landfills is also not
applicable.
7) A commenter noted that access to the Site under Alternative SC-2B can be achieved in ways other
than locked chain link fencing. SC-2B provides greater net risk reduction. As an alternative a rock
wall or a post and beam fence could be constructed.
RESPONSE TO COMMENT #7
Based upon EPA's experience, fences constructed around Superfund Sites to control access are typically
eight feet high and many times include additional components such as barbed wire. EPA agrees that there
are more aesthetically pleasing ways to restrict site access than chain link fencing. It is debatable however,
whether post and beam fencing, for example, sufficiently restricts site access as it is easily dismantled, and
provides limited deterrence to vehicular traffic, etc.. In addition, while a rock wall with limited openings for
access, could be constructed around the site that could effectively restrict trucks and cars from access to the
Site, it would be difficult to prevent other vehicular traffic (motor bikes and ATVs) while still allowing
pedestrian traffic access to the landfill for passive recreation. In addition, there are components to
Alternative SC-2B that could be subject to vandalism by individuals such as vents included as part of the
landfill design.
EPA has included a temporary chain link fence as a component of the selected remedy to address health and
safety requirements during the time that the remedy is being constructed. EPA has allowed flexibility in the
selected remedy for the fence to remain or be removed once construction is completed.
8) One comment was received expressing concern that Alternative SC-3B does not provide equivalent
or greater reduction in mobility of contaminants than Alternative SC-2B because residual material
with contamination below cleanup levels will mobilize and perhaps result in an unacceptable risk in
the future as our understanding of risk evolves. In a related comment, because residual waste
remains at the Site, the permanence of the remedy is impaired. As a result, Alternative SC-2B
provides greater long term protection than Alternative SC-3B.
RESPONSE TO COMMENT #8
Section 121©) of CERCLA was included in the Superfund law to address the concerns raised by this
comment. This Section provides that remedial actions that result in hazardous substances, pollutants or
contaminants remaining at a Site must be reviewed no less often than every five years to assure that human
health and the environment continue to be protected by the selected remedy. Because both Alternatives
SC-2B and SC-3B allow contamination to remain on site above levels that will allow unrestricted use, this
five year review component was included as a requirement for both Alternatives. As part of this review,
EPA evaluates changes in science that have occurred that would place into question the protectiveness of
the remedy. As a result, action can be taken to address newly discovered risks.
In addition, Alternative SC-3B includes plans for continued monitoring to make sure that Site conditions do
not unexpectedly change over time. Again, monitoring, was also required in Alternative SC-2B because of
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similar concerns. This commenter's theoretical concern that residual material left on site could present a risk
in the future should later scientific assessments determine this contamination poses a risk would appear to
be adequately addressed by both the five year review provision and continued monitoring of site conditions.
EPA notes that the concern regarding residual contamination and mobility raised by the commenter as to
Alternative SC-3B, is also a concern with Alternative SC-2B. Under SC-2B, only a small portion of the 9
acre site will be capped (2-3 acres). Residual material will remain uncapped, capable of mobilizing under
Alternative SC-2B on the majority of the Site.
EPA disagrees with the commenter's statement that leaving residual material below cleanup levels on site
affects the permanence of Alternative SC-3B and that Alternative SC-2B likely provides greater overall
protection. Both Alternative SC-2B and SC-3B leave the same amount of residual material on site.
Alternative SC-3B provides greater overall protection because all waste material that presents an
unacceptable risk will be permanently removed from the Site. Alternative SC-2B does not permanently
remove chemical waste from the site or address it by treatment but rather leaves this contamination beneath
a cap in the long term. Although EPA believes caps are effective from an engineering perspective, they are
subject to deterioration over time and must be continually operated and maintained. Even with the most
effective operation and maintenance, technical problems do occur from time to time and as a result, such
technology is neither as permanent or effective in the long term as permanently removing the waste from the
Site.
9) The same commenter also expressed concern that impacted source materials present at ALI could
recontaminate materials left uncapped at Shpack under Alternative SC-3B.
RESPONSE TO COMMENT #9
This is a concern regardless of which alternative is selected - either this material will recontaminate the cap
that has been put in place under Alternative SC-2B or the clean fill under SC-3B and would need to be
included in the design of either alternative. As a result, this issue will be addressed as part of remedial
design.
10) A comment was also made that EPA selected capping over excavation and off-site disposal in a
similar situation at the Raymark Superfund Site.
RESPONSE TO COMMENT #10
EPA believes it is, at best, very difficult to compare the selected remedy at one site with the selected remedy
at another as each site presents unique issues in terms of appropriate cleanup. That being said, the Raymark
Site involved significantly different contamination, principally asbestos, than that found at Shpack. The
principal risk associated with asbestos (a known carcinogen) is from inhalation of airborne fibers. Unlike
Shpack, Raymark did not have radiological waste. Unlike Shpack, the off-site disposal alternative cited in
the comment was limited in nature because Raymark is a much larger Site, both by volume and size and the
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depth of waste exceeding cleanup standards. As a result, the off-site disposal alternative cited by the
commenter still required that the site be capped (i.e. most waste was left in place)14.
As discussed previously, there are negligible differences in short term impacts between SC-2B and SC-3B.
In addition, there are negligible differences in the implementability of either alternative as both involve
routine waste management technologies.
11) One commenter noted that selection of Alternative SC-3B would trigger review by EPA's National
Remedy Review Board (RRB). This would delay implementation of a protective remedy.
RESPONSE TO COMMENT #11
Because of some of the unique circumstances at the Shpack Site, Alternative SC-3B did not need to be
reviewed by the National Remedy Review Board. Therefore, there will not be a delay due to involvement
from the RRB.
12) Another comment was received expressing the belief that Alternative SC-3B poses multiple
implementability challenges. In support of this, the commenter cites potential structural issues
involved in excavating waste next to the ALI Landfill.
RESPONSE TO COMMENT #12
Each Superfund Site presents its own unique technical/engineering issues. The issue of engineering the
excavation near the border with the ALI landfill will be addressed during the design phase of the project.
The depth of excavation in this border region (near ERM 101-B, estimated depth 6-8 feet below ground
surface) is relatively shallow. Excavating this material is neither impracticable nor technically infeasible. If
there are issues with slope stability, they can easily be addressed with engineering controls.
13) A comment was also received concerned that the costs for Alternative SC-3B are disproportionate to
risk reduction achieved. In a related comment, the commenter stated that Alternative SC-3B
achieves less net risk reduction than Alternative SC-2B.
RESPONSE TO COMMENT #13
EPA believes, taking into account all appropriate factors, that the cost is proportional to its overall
effectiveness. (See discussion of Cost-Effectiveness in Section H of the ROD).
In addition, EPA disagrees that Alternative SC-3B achieves less net risk reduction. In fact, risk reduction is
greater because all waste exceeding cleanup levels is removed from the site under Alternative SC-3B. (See
Response to Comments regarding risk reduction).
14 In addition, EPA takes into account changes in science, technology and cost that have occurred when
making remedy decisions at different points in time For example, the Raymark ROD was written almost 10 years ago
and circumstances noted in the Hardage case cited by the commenter occurred over 15 years ago This commenter also
cited to language in the Hardage decision for support that containment remedies are "superior" to excavation
remedies In the Hardage decision, the court rejected EPA's plan to excavate 18,000 barrels and associated waste, a
situation distinct from Shpack, in favor of a containment remedy The differences between the two sites are too
numerous to note However, as pointed out by the commenter, substantial site specific evidence was introduced at trial
to support the different remedial approaches Again, remedy decisions are site specific— each decision based on its
own unique facts including current science and technology
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14) One comment was received noting that once the radiological, dioxin and PCB material is removed
from the Site, Shpack will be just like any other municipal landfill.
RESPONSE TO COMMENT #14
EPA believes, however, proper remedy decisions can only be made at complex sites such as this by viewing
the Site as a whole. To eliminate the excavation of this material from the evaluation of clean up alternatives
is to ignore a major defining characteristic of this Site. The relative shallowness of the excavations of waste
exceeding site cleanup levels, as well as the relatively small volume estimated in the FS to be exceeding
these levels make this site very unique from most municipal landfill sites which have very large quantities
of waste at inaccessible locations making removal of the waste impracticable.
A. The commenter has also included lists of sites from different EPA databases in support of
this comment. The first such list is included in Table 1 of the comment and identifies 149
Sites where landfills have been capped.
RESPONSE TO COMMENT #14.A
EPA agrees that there are many landfills across the country where EPA concluded construction of a cap was
the appropriate remedy. As discussed previously, it is hard to compare remedial responses at different sites
with one another because each site presents unique factors, including community and state acceptance, that
must be taken into account in the selection of the remedy. As a result, it is difficult to agree that EPA has
effectively capped sites like the Shpack Site without taking into account other criteria, based upon the
information in this Table. The relative shallowness of the waste exceeding site cleanup levels, as well as the
relatively small volume estimated in the FS to exceed these levels make this site different from many sites
which have very large quantities of waste at inaccessible locations. In addition, other unique factors may
apply at individual sites.
B. This commenter also included a sample selection of sites in having "similar" contamination
where waste has been left in place under a cap (Table 3 of comment).
RESPONSE TO COMMENT #14.B
Again it is impossible to compare limited features of sites (in this case "similar" contaminants) against one
another without taking into account numerous other site specific factors that go into remedial decision
making. None of these sites cited by the commenter, for example, have radiological waste, a most unique
characteristic. In addition, there are numerous sites with "similar" contaminants where the waste has been
excavated and disposed of off-site. In Region I, there are several NPL sites, including Atlas Tack,
Kearsarge, Salem Acres, Plymouth Harbor, and most recently, Beede in which EPA issued Records of
Decision calling for the off-site disposal of "similar" contaminants. Both Atlas Tack and Beede, more recent
RODs, require significantly more waste material to be excavated and shipped off-site, 50,000 plus cubic
yards at Atlas Tack and 80,000 cubic yards at Beede than that required at Shpack. In addition, there are
numerous removal actions in Region I which have been taken in situations where large quantities of waste
material exceeding cleanup levels have been excavated and removed from communities rather than capping
it in place.
C. This commenter also included what is purported to be a list of sites in Region 1 where
landfill capping remedies have been implemented.
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RESPONSE TO COMMENT #14.C
This is not a correct characterization. Some of these sites are still in the investigation phase and no remedy
has been selected. Some of these sites required waste to be treated on-site unlike the situation here at
Shpack (Stamina Mills, W.R. Grace for example). Some of these sites required waste to be excavated and
disposed of off-site. A defining factor at most of these sites is the size of the area addressed by the Record
of Decision, significantly larger than that considered at Shpack.. None of these sites, with the exception of
the Nuclear Metals Site (no cleanup plan has been selected), have radiological contamination. An area of the
Nuclear Metals site was capped as part of a Superfund Removal Action, but this is considered an interim
measure pending a full Remedial Investigation.
In conclusion, the Shpack Site presents its own unique set of factors, most significantly the presence of
radiological contamination, the relatively small volume of waste that is estimated to exceed cleanup levels,
and the fact that much of the contamination that must be addressed is near the ground surface that make it
unique from many other sites that have been capped in place.
Enforcement
1) Some commenters noted that a significant portion of the Site cleanup costs will be borne by the US
Army Corp of Engineers under the FUSRAP program. Other commenters noted that the Towns of
Attleboro and Norton could end up bearing a significant portion of the costs in the future given their
involvement at the Site as owners or operators. One comment was received saying a trust fund could
be put in place to ensure the continued integrity of the cap, and other long term components of
remedy.
RESPONSE TO COMMENT #1
Comments regarding who is or should be responsible for paying for the cleanup are basically comments
regarding enforcement and are not appropriately addressed as part of this responsiveness summary. In
addition, comments that relate to funding agreed to as part of an enforcement action are also enforcement
issues and are not appropriately addressed as part of this responsiveness summary.
2. One comment was received supporting Alternative SC-3B because by removing the contamination
at Shpack liability for additional contamination will probably belong to ALL
RESPONSE TO COMMENT #2
Comments regarding liability are comments on enforcement and are not appropriately addressed as part of
this responsiveness summary.
Additional Comments
1) Comments were also received asking that ALI be addressed.
RESPONSE TO COMMENT #1
ALI is being addressed under separate regulatory authority administered by the State under its solid waste
landfill program. EPA does not have authority under the Superfund program to address ALI at this time.
Issues relating to ALI are referred to the Massachusetts Department of Environmental Protection.
107
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RESPONSIVENESS SUMMARY
ATTACHMENT A
TRANSCRIPT OF PUBLIC HEARING
AUGUST 4, 2004
108
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UNITED STATES OF AMERICA
ENVIRONMENTAL PROTECTION AGENCY
BOSTON REGION
In the Matter of:
PUBLIC HEARING:
RE: PROPOSED CLEANUP PLAN
SHPACK LANDFILL SUPERFUND SITE
NORTON/ATTLEBORO, MASSACHUSETTS
J.C. Solmonese School
315 West Main Street
Norton, Massachusetts
Wednesday
August 4, 2004
The above entitled matter came on for hearing, pursuant to Notice at 7:10 p.m.
BEFORE:
SUSAN STUDLIEN, Director
Office of Site Remediation & Restoration
DAVE LEDERER, Project Manager
U.S. Environmental Protection Agency
Region 1, New England
Office of Site Remediation & Restoration
One Congress St., Suite 1100
Boston, MA 02114-2023
ORIGINAL
COPY
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INDEX
SPEAKERS PAGE
Barney Frank 8
Joann Sprague 13
Philip Travis 16
Betty Fourier 19
Jennifer Carlino 23
Michael Coppola 26
Robert Kimball 28
Richard Gomes 37
Ronald O'Reilly 39
Gary Covino 43
Jim Mooney 48
Heather Graf 53
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PROCEEDING S
(7:10 p. m.)
MS. STUDLIEN: Thanks to everybody for coming
tonight.
My name is Susan Studlien. I'm the Director of
the Environmental Protection Agency's New England Office of
Site Remediation & Restoration, and I'm going to be the
Hearing Officer for tonight's hearing on the proposed remedy
for Shpack Landfill Superfund Site located on the
Norton/Attleboro border.
The purpose of the hearing tonight is to accept
formally oral comments on the proposed plan that was
released to the public on June 23rd.
The protocol for these hearings is that we do not
respond to comments tonight, but we will respond to them in
writing after August 25th which is the close of the present
comment period. The comment period was extended for 30 days
in order to provide additional time for people to review the
Feasibility Study and the proposed plan.
A public information meeting on the plan was held
on June 23rd of this year, in this very room. At that
meeting, information concerning the plan was presented and
EPA responded to questions about the site.
I want to describe, just briefly, the format for
the hearing. First, Dave Lederer, who is sitting to my
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left, the EPA Project Manager for this site, is going to
give a very brief overview of the proposed Cleanup Plan for
the site, and I know that some of you have already seen
this. On the other hand, we are, we're concerned that some
of the people coming tonight may not have seen it. So,
we're, we're just going to do a brief overview.
Following the presentation, I will then accept
oral comments for the record, and those of you who want to
comment should have indicated your wish to do so by filling
out an index card available from Angela Bonarrigo, who is
waving her hand. If you haven't filled out a card and want
to make a comment, just see Angela.
I'm going to call on people who want to comment in
the order in which you signed up to speak. When you're
called on, if you could come to the front of the room and
sit at this table and use the microphones that are provided
and the microphones that are taped to the table are for our,
our stenographer.
I'm going to give you this microphone that I'm
holding here just for amplification purposes for this room;
so, the people sitting here can, can hear you well. The
reason I am bending over this microphone like this is that,
apparently, you have to come very close to putting it in
your mouth in order for it to work. So, if you can state
your name and address when you come and sit at the table,
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and your affiliation, it would be appreciated.
We are recording these proceedings verbatim; so,
we need to get this information for the record, and, for
that reason, if you could, actually, spell your name and
give the full name of your affiliation, as opposed to, for
example, an acronym or a, or the letters, that would be
appreciated.
In order to, finally, in order to insure that
everybody has a chance to speak, I hope you will limit your
comments to ten minutes. If your comments will take longer
than ten minutes, I would ask that you could summarize your
major points and provide EPA with a copy of the full text of
your comments. The text, in its entirety, will become part
of the hearing's record.
After all the comments have been heard, I'll close
the formal hearing, and if you wish to submit written
comments, you can give them to me tonight, or you can mail
them to our Boston office at the address that's in the prop
— in our proposed plan.
At the conclusion of the hearing, you can see any
of the EPA representatives if you have any questions on how
to submit comments. All of the oral comments that we get
tonight, and the written comments that we receive during the
comment period, will be addressed in a responsive summary
and become part of the administrative record for this site.
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That will be included with the record of decision on the
remedy for the site.
Are there any questions?
(No verbal response.)
MS. STUDLIEN: Okay. We're going to start, then,
with our very brief overview of the plan.
MR. LEDERER: Thank you, Susan.
My name is Dave Lederer. I'm the Remedial Project
Manager for the Shpack Superfund Site, US/EPA.
I'm going to very, very quickly, and I mean
quickly, go through the main points in the proposed plan so
we have a starting point for people's testimony tonight.
This is a map of the layout of the site showing
its features. The site consists of approximately 9.4 acres,
about 3.4 acres are in Attleboro, and about six acres is in
Norton, and is actually owned by the Town of Norton.
The former Shpack residence is located here.
Power lines bisect the site thusly, and you, also, are
surrounded by Chartley Swamp on the south and — I'm sorry.
On the east and the northeast, and by the Attleboro
landfill, of course, on the west.
This slide, basically, just summarizes that same
thing. ALI lies directly west of the site, about 110 feet
higher above grade, above the grade established by Shpack.
There are two holes and private wells within about
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500 feet of the site fence, and the site, itself, is
relatively flat. It was formerly a wetlands area. There is
a small material wetland that remains.
So, under our proposed plan, we are taking the
following measures:
The public water line be extended to include the
two residences adjacent to the landfill that are currently
on private wells; approximately 10,500 cubic yards of soil
contaminated with the radiological contaminants of concern,
above cleanup levels, will be excavated and disposed of off
site, and, under our proposal, approximately 2,250 cubic
yards of dioxin and PCB contaminated sediment will be
excavated and disposed of off site.
Continuing along, contaminated sediments in the
wetland areas of the site will be consolidated to an upland
area on site, and the disturbed wetlands will be restored
and/or replicated to the extent practical.
The landfill will, then, be capped to prevent
exposure to contaminated waste. The site fenced to control
access and legal controls put in place to insure that the
revenue remains protected in the long-term. Groundwater, of
course, will be continued to be monitored and a cap
maintained in the long-term.
That's, basically, an outline of the proposal
before we take testimony. Now, I'll put the microphone
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right up here.
(Pause.)
MR. LEDERER: So, whoever is speaking can just sit
right there in front of the mike.
MS. STUDLIEN: And you're welcomed to pick that
microphone up if it's easier for you as well.
Okay. We'll, now, begin the formal hearing, and
the first speaker is Congressman Barney Frank.
(Pause.)
MR. FRANK: Thank you. I appreciate the
willingness of the EPA to continue to engage, we, also,
continue to have disagreements, but I will say, our
involvement, my office and others, we have found the Federal
Agency, while we are not happy with the current plan, I do
want to acknowledge that it represents significant progress
from when we started, but we think the logic, which got us
from originally here is important.
I guess the point to focus on is, in the summary,
when you pointed out the plan to contain the contamination,
consolidate and contain the contamination — and I think
that's clearly the nub of the disagreement. We believe the
purpose of this should be to get rid of the contamination
and not rearrange it.
Even though you do plan to rearrange it the way
that makes it somewhat less damaging, the thrust of the
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Superfund Program, to us, is to cleanup, and leaving a town
in possession and perpetuity of contamination, even if it is
somewhat more conveniently arranged, is not what we think
should happen.
I want to acknowledge, again, that we've made some
progress, and we've been involved, you know, legislatively
and elsewhere.
The original proposal was to cap even the
radiological material, and thanks to the legislation that
Congressman McGovern I were able to get jointly, and the
progress we've made, we've gotten beyond that.
I, also, want to note that this has been a case
where the lead has been taken by the town, and I want to
acknowledge the Board of Selectmen in the town, Heather Graf
and the Advisory Committee. My office has learned a great
deal from them. They have, at every point when we have
consulted with them, been accurate in their information and
responsible, and that leads me now to enthusiastically
support the initial paper the town has put forward. I've
submitted my own letter.
The nub is this: we believe that there ought to
be a complete removal. We are talking, again, it is a
narrower financial difference than when we started. The
proposal that we are supporting will cost $50 million or
perhaps a little more. The proposal that we are being given
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here, which is removal of the radiological material and
containment of the contamination, would cost 30 million.
We should note 15 million of that comes from the
Core of Engineers, and that is out of the federal budget,
out of the program called FUSRAP, and the rest comes out of
Superfund, but it's legally the responsibility of the PRP,
which is, of course, a nice legal word for the people who
put it there in the first place and having put it there and
having made money putting it there, we think it is only fair
that they now pay the cost of removing it.
So, we are talking about a difference of $25
million over a period of years, and we believe this is a
charge that ultimately should not, and we hope will not be
lodged against the federal government, but will go to the
responsible parties.
Asking the town to continue the perpetuity to have
contamination is, I think, a failure of those of us at the
federal level to meet our responsibilities to these citizens
who have worked so hard and are asking not for any great
boon here, but simply to be left as they otherwise would
have been before the contamination came here.
Now, the, the EPA correctly points out the, the
potential which the groundwater, and you talked about
monitoring to keep the groundwater clean. Well, what we are
saying to the town, if that's what the federal government
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does, is we're going to leave here a potential danger to
groundwater, but don't worry; your federal government is
watching.
Now, I serve in the federal government. I'm not
one to engage in easy denigration of it, but I don't think
we will be reassuring the people here, the parents who are
worried about the long-term effects on their children of
drinking water, etcetera, if we say, "We acknowledge that
there is a problem here," because that's what we're saying
if we say that we're going to monitor the groundwater, we're
acknowledging that we are leaving in situ a potential
contamination. We think we've got it locked up. We think
we've got it detained. I'm not going to challenge your
engineering, but nobody can be sure of this. We're not
dealing here with an area where there is any certainty.
We know there is migration, and the very fact that
we expect to have to monitor it, and I would, also, add, as
we talk about the cost, there is sometimes a problem in the
way we budget, because a true comparison of cost would
factor in, not simply the removal costs if we leave the
contamination, but the monitoring costs, because we are
talking, then, about the federal government having an
ongoing responsibility. So, we believe this ought to be
done outright, and I should add that I'd be talking about my
responsibility, as a federal official, but I'm very pleased,
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because not only have we worked here, my office and others,
with the town, but we've had very good multi-level,
bipartisan cooperation.
The legislative delegation, Senator Sprague is
here, Representative Travis and Representative Fourier. We
have worked very closely together on this, and we, I
believe, have come to an agreement, Representative Coppola
and all the legislators, in the area, and myself agree.
We don't think it is asking too much; indeed, we
think we would be failing our responsibilities to the people
of Norton if we did not clean this site up, and that's what
people expect of the Superfund, and cleaning it up means
cleaning it up.
In no other area of people's lives, you know, if
people's kids spill something at home, they don't tell the
kid, "Okay, here's what you do. You spilled that, and that
was too bad. Put it in a neat pile, and put something over
it."
In fact, let me say, we have a metaphor for not
doing a job. It's called, "Sweeping something under the
rug." In other word for "Sweeping something under the rug,"
is containment. When we have dirt and dust and you sweep it
under the rug, you've contained it.
Again, I don't mean to denigrate the goodwill. I
realize that are not individuals working purely in the
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abstract. I will say that I regret the fact that the budget
for EPA is not greater than it was. I regret the fact that
we've got the tax on oil, which would have generated more
money. That's our job, to find the money, but I don't think
we can ask the citizens to Norton to bear that burden.
So, I ask that we follow the logic of the
radiological issue, and go forward and not just sweep the
contamination under the rug; albeit, it will be a thick rug,
and it will be an attractively landscaped rug, but we'd
still be sweeping it under the rug, and we would still run
the danger of the contamination of the groundwater, and I
believe it is entirely reasonable to ask that we do the
whole job and not part of it.
I thank you for your attention.
(Applause.)
MS. STUDLIEN: Thank you, Congressman.
Our next speaker is State Senator Joann Sprague.
MS. SPRAGUE: Thank you, so much, Hearing Officer
Studlien and Mr. Lederer, and I want to thank you, first of
all, for the privilege of letting me speak to this issue,
which is of great importance to my constituents from Norton
and from Attleboro who are here tonight.
I am State Senator Joann Sprague, and I represent
the people of the Bristol/Norfolk District, and I'd like to
have my letter to Mr. Lederer entered in the record if I
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could, please.
Dear Mr. Lederer, I'm writing on behalf of my
constituents and the Town of Norton, to strongly support the
Town's choice of SC-3B as the best cleanup alternative for
the Shpack Superfund Site.
I am steadfast in my opposition to the EPA's
choice of SC-2B as the best cleanup alternative.
My constituents and I demand that the old Shpack
dump property be returned to a safe enough condition that it
can be used for passive recreation within the Norton
Conservation Commission's Open-Space Plan. This use
conforms to our understanding of what the town's use has
meant during meetings between the ad hoc Shpack Committee,
the Army Corps of Engineers and the United States
Environmental Protection Agency.
The EPA Alternative, SC-2B, will remove only some
elements of the waste and contain the remaining contaminant
under a cap. We know that caps deteriorate, which could
reinitiate the pollution cycle.
Also, SC-2B would not allow my constituents the
kind of use they have been led to expect. The requirement
of fencing and a "No Trespassing" sign is evidence that
SC-2B would not be a full-fledged cleanup; therefore, the
Town and its citizens would be left to bear the burden of
fighting future contamination and policing the problem at
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the site.
The EPA's decision in this case should not be
based on what the remediation costs, but on what is the best
long-term interest for Massachusetts' citizens. All of whom
who are taxpayers with a vested interest in a clean
environment for families or friends and our neighbors.
Through the years, Madam Hearing Officer, my
Norton constituents have paid millions of dollars of their
hard-earned money in taxes to the state and federal
government, and this way, the town's people, for years, have
paid for government actions that benefit, not only
themselves, but actions that provide, also, for the common
good for citizens throughout this great country.
It is now time, Madam Hearing Officer, for the EPA
to stand tall and acknowledge that the common good requires
a permanent and proper cleanup of environmentally unsafe
waste.
There is no better use for our citizen's tax
dollars than to provide for the environmental safety of the
citizens residing in this area now, for the generations to
follow, both of which will ultimately be of benefit not only
to this region but to all the citizens of our great country.
Mr. Lederer, my constituents, their local
officials and I, along with other state and other officials,
demand the government do the right thing for the
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environmental safety of us and future generations by
adopting Choice SC-3B for the cleanup of the Shpack
Superfund Site.
We will be proud to stand by you in this action,
and, in doing so, we will be proud to say, "We won one for
the environmental protection of our land and people."
Thank you, so much, again, for letting me
represent my constituents at this hearing.
(Applause.)
MS. STUDLIEN: Thank you, Senator.
(Applause.)
MS. STUDLIEN: Our next speaker is Representative
Philip Travis.
MR. TRAVIS: Thank you, Madam Director of the EPA.
For the record, my name is State Representative
Philip Travis, T- R- A- V-1- S. I represent the Fourth Bristol
District of the Commonwealth of Massachusetts, in the House
of Representatives, Swansea, Seekonk, Rehoboth and the
Precinct in Norton, Precinct One is where this landfill is
located. It is in my district.
I want to join along with Congressman Barney
Frank; Senator JoAnn Sprague, my Senator; Betty Pourier, the
Representative, who, also, shares Norton with me; Michael
Coppola is to be here this evening, and myself, State
Representative Philip Travis, in saying, unequivocally, we
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do not go along with the citing as CS-2b as has been picked
by the EPA to cleanup my site.
The people of Norton are owed much more.
Contamination, in the form of radiation, going down 15 feet
or more, had been put there during the 50's and 60's by
making nuclear reactors for submarines. In it's time, it
was necessary to protect our United States, but the waste
that came from that work is now sitting in the soil, and we
have a terrorist located in Norton in the form of this
Shpack site. It can contaminate and do harm to the people
of not only the Chartley Section, which I represent, but the
entire area of Attleboro, and that section of Norton.
To remove partially and leave the rest, is a job,
as was said by the Congressman, which is less than half
finished. It makes no sense, in dollars, a $20 million
differential, not to go in and remove the entire site and
bring it back so it can be used by the people of the Town of
Norton for whatever purpose they decide, recreation or
otherwise.
Attleboro has a land site further to the west.
They will be tapping that site to Massachusetts Department
of Environmental Protection. They will be putting a cap on
it, and they will be having trucks come in with materials
from the south shore of Massachusetts to cap it and leave
this town with those same tractor trailers empty and going
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back to a place that is 50 miles away from here.
How, in God's heaven, cannot we coordinator
between a federal agency and a state agency? I know neither
are intertwined in this issue, but Attleboro is working with
EPA and the DEP, and we're working with you folks at the
federal level.
The tractor trailer trucks will leave this
community empty and go all the way down Route 123 and head
back towards the Boston area to, in an empty form.
If we could utilize that and coordinate that
activity to save money, you would have trucks coming in with
fill from Attleboro dumping, coming through Norton to go
back, and with material that is needed to be removed from my
district to make it a cleaner and safer cleanup.
So, uranium and other things that are in the soil
are not left to be, hopefully, not dissipate normally and
not get into the water table and do more harm. It will do
harm to the people of Norton, I'm sure, in the long haul;
perhaps not today, maybe not next year, and maybe not 10
years from now, but I cannot serve in office and represent
the people in that district and say, "I did my best, but I'm
going with the lessor plan."
I go, as strongly as possible, to say to all of
you that the plan you've accepted is not acceptable to me or
my constituents, and I ask that you reconsider your
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alternative and go with SC-2B, which is the plan that is
backed by the Ad Hoc Committee, appointed by the Board of
Selectmen, and which we have worked with, as well as Barney,
and my fellow colleagues at the State House, to have that
plan implemented.
Thank you, very much, and our letter has been
filed with you, but it will be read officially, in a few
minutes, by my colleague, Betty Fourier, of North Attleboro.
Thank you, very much, Ma'am.
(Applause.)
MS. STUDLIEN: Thank you, Representative Travis.
(Applause.)
MS. STUDLIEN: Thank you.
Our next speaker is State Representative Betty
Fourier.
MS. FOURIER: Thank you, very much.
I would like to add my gratitude for having the
opportunity to speak tonight at this Public Hearing. This
is my second Public Hearing as I've only represented Norton
for one term, but I, certainly, had to do a quick study on
what this site means to the community of Norton and all of
the people that have lived with it for many, many decades.
Before I read, read my letter into the record, I
would just like to make a few comments aside from that.
One of the things that disturbs me greatly is that
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the EPA proposed plan does not provide a permanent solution
to this problem. It leaves it here for generations in the
future to concern themselves with and worry about. Perhaps
making it the responsibility, not only of the Town of
Norton, but of the Commonwealth of Massachusetts, and, as a
State Official, I would like, very much, to see that taken
care of this time out, and not to have to address this at
some unforeseen time in the future when it may pose, again,
a problem.
This is not a cleanup of a contaminated area, but
this is a coverup, and, as Congressman Frank, so aptly
stated, this is a rug where contaminants have been swept
under, and, now, we're putting a fence around it, and we're
not going to allow anyone to walk on the rug, which brings
me to my third point.
This is not at all what the community of Norton
has requested. They would like to be able to use that
property for recreational purposes, in combination with
their Open-Space Plan, and this solution — this SC-2B - -
does not allow the community to be able to do that.
So, it, in no way, addresses the concerns that they
mainly have, and that is eliminating the contamination, not
covering it. Eliminating the responsibility for the Town of
Norton, as well as for the Commonwealth of Massachusetts,
and, also, being able to use that property for productive
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use and not fencing it off and keeping people away from the
site.
Now, if you will permit me, I would like to read a
letter that was submitted by myself, State Representative
Betty Fourier — I'm from the 14th Bristol District and
represent all of North Attleboro, one precinct in Attleboro,
one precinct in Norton, and two precincts in Mansfield, and
it is, also, from my colleague, State Representative Michael
Coppolla, who represents two precincts here in Norton, and
Philip Travis, who has the Shpack site right in his own
precinct. The letter reads: Mr. David Lederer - it's to
Mr. Lederer, regarding the Shpack Landfill Superfund Site,
Norton, Mass.
"Dear Mr. Lederer. We write in response to the US
Environmental Protection Agency's proposal to cleanup the
contamination of the Shpack Landfill Superfund Site in the
Town of Norton. After reading information about the various
cleanup alternatives, as well as attending Public Meetings
on this issue, we strongly oppose the EPA's proposal known
as Option SC-2B, at an estimated cost of $30 million.
"We believe that SC-3B is the better, more
permanent solution to rid the landfill and the surrounding
residential area of hazardous pollutants at an estimated
cost of 55 million.
"To spend 30 million on a partial cleanup is money
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poorly spent and requires long-term monitoring and perpetual
restriction on access; however, Option SC-3B is a complete
cleanup of contaminants, and a total and permanent
restoration of the former landfill requiring minimal
monitoring and no access restrictions.
"The wishes of the Town of Norton, for the future
use of the property for passive recreation have been totally
ignored. An additional issue of great concern is the
possibility, at sometime in the future, that the Town of
Norton and the Commonwealth of Massachusetts could be held
responsible for the operation, t he monitoring and the
maintenance of the site. The possibility of these costs at
some point in the future would far surpass the SC-3B option.
"Opposition, as legislators for the Town of
Norton, is clear. We stand united with the Citizens
Advisory Shpack Team in our opposition to EPA's preferred
Alternative, SC-2B.
"We truly hope that you will take the concerns of
the Town and its residents into consideration and choose
Option SC-3B as the preferred Cleanup Plan for this landfill
Superfund site.
"Thank you for your attention to this matter," and
it's signed, "Sincerely, Michael Coppola, State
Representative; Elizabeth Fourier, State Representative; and
Philip Travis, State Representative."
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I very much appreciate the opportunity to be able
to present this to you. Thank you.
MS. STUDLIEN: Thank you, Representative.
(Applause.)
MS. STUDLIEN: Thank you.
Our next speaker is Jennifer Carling (sic).
MR. LEDERER: Carlino.
MS. STUDLIEN: What?
MR. LEDERER: It's Carlino.
MS. STUDLIEN: Oh, Sorry. Carlino. Excuse me.
I'm sorry.
MS. CARLINO: It's all right.
(Pause.)
MS. CARLINO: I'm Jennifer Carlino. I'm Norton's
Conservation Agent, and I would like to speak in support of
Option SC-3B. This option will allow the town to actually
use the property once the cleanup has been concluded. It
improves the wildlife habitat value of the property, would
not require a taking of the spotted turtle habitat and allow
replication of the wetlands on site.
I'm, actually, fairly disappointed with the lack
of information on the six vernal pools that are on the
property and the rare species. There are about two
sentences in the report.
MR. FRANK: This should help.
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MS. CARLINO: All right. Thanks. Sorry.
So, I would like to request that the record of
decision require that the wetland replication, the wetland
replication should improve vernal pool habitat, include rare
species habitat, should provide detailed plans and
narratives for the Conservation Commission to review;
including the soil types, the number, the size and the
specific plants that will be used in the wetland replication
and restoration; include a five year wetland monitoring
program.
The record of decision should, also, require that
the vernal pools and rare species habitat be investigated,
and that all of the vernal pool documentation and the rare
species incident forms should be filled out as requested by
the Mass. Natural Heritage & Endangered Species Program in
their letter of July 30th, 2004.
The record of decision should, also, require
transportation and Emergency Spill Plan; so, that, if there
is a spill anywhere on route, there is some sort of
Contingency Plan for cleaning up those materials. They're
right next to Chartley Swamp. They have to get over that
railroad embankment. They're right next to Chartley Pond,
and the dam that we have just repaired.
So, there should certainly be some type of
requirement for a Contingency Plan and the Conservation
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Commission would like to review that and comment as well.
The Wetland Replication Plan should, also, include
options for dewatering. The Conservation Commission should
be able to review those options and provide comments.
Also, like to see the detailed plans for the
extension of the water line right next to Chartley Swamp,
Chartley Pond, and provide comments on those.
The Conservation Commission should, also, be able
to review the deed restriction language and provide comments
on that.
We do have a couple of concerns about the cap.
The cap, the reports document that the cap will limit
infiltration. It will not stop it. We've seen information
that the Attleboro landfill cap is leaking onto the Shpack
site. The new cap, proposed cap for the Shpack site would
be susceptible, still, to ALI contamination. We, certainly,
don't want the newly replicated wetlands to be filled with
more contaminants.
There is, also, a pretty serious question about
who is responsible for the operation and maintenance and for
the funding if you chose to go that way. We're still in
full support of Option SC-3B.
The information that we have reviewed is not
detailed enough on the operation and maintenance, and is
that the same type of operation and maintenance that the
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Attleboro landfill has been using and what assurance would
Norton have that the Shpack operation and Maintenance Plan
would be better implemented than ALI's?
Thank you.
MS. STUDLIEN: Thank you, very much.
(Applause.)
MS. STUDLIEN: Oh, I'm sorry. Representative - -
thank you.
State Representative Michael Coppola?
MR. COPPOLA: I'm sorry for being late.
MS. STUDLIEN: No problem.
MR. COPPOLA: I feel guilty. I walk in, and I get
to speak. All these people have been sitting all this time.
I, I did want to have an opportunity to express to
you what Representative Fourier has said in our letter, and
without being repetitive, I, I'd like to, certainly, bring
the high points, what I think the high points of our letter
is and of our concern.
As you know, the EPA's proposal is, is just a
containment of the contamination, and it does nothing, as
far as access those, as far as future use, for the area
goes, and there is, certainly, some question on whether we
really have taken care of the problem of contamination and
the, the effects of it for generations to come, and that's
what we're talking here.
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We're not just talking for now. We're talking for
generations to come, and, as you know, when it comes to
landfills, there is a monitoring process of 20, 30 years,
and, also, a, a, a situation where we all have a concern.
There is residents in the area, and we really feel
the only right way of doing this, the only right way of
spending the money appropriately is to do a complete and
total cleanup. It does a number of things.
Besides the obvious, it makes us all feel that
we've done the right thing. That we've really truly taken
care of the environmental concerns of the community and of
the neighborhood in particular, but we've, also, created a
situation where we can now; hopefully, use the land, and use
it for some access, rather than the very limited access that
we'd get with the EPA's proposal.
So, we're talking about a number of things. We're
talking about environment. We're talking about future use.
We're talking about responsibility. We're talking about
what's going to happen in generations to come.
I think it's very clear, among the State
Representatives and among the Town officials and among the
concerned citizens, that the appropriate and the best way of
spending the millions of dollars that we're asking the
government to spend, is to do a total cleanup, and I refer
to the SC-B cleanup.
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I think I said the last time I was here, you know,
you can spend $20 million and do it halfway right, or you
can spend the $50 mill — $55 million and do it right, and
do it right for now, and do it right for the future.
Thank you.
(Applause.)
MS. STUDLIEN: Thank you, Representative.
(Applause.)
MS. STUDLIEN: Thank you.
Our next speaker is Robert Kimball.
(Pause.)
MR. KIMBALL: I'm going to sit down. I believe
it's cooler down here.
First of all, the Town would like to thank the
EPA, members of the EPA representatives, along with
Congressman Barney Frank, Senator Sprague, Representatives
Travis, Fourier and Coppola for coming here tonight to
support our position.
On behalf of its 18,000 residents, the Town of
Norton Board of Selectmen hereby submits its response to the
EPA's Proposed Plan for Cleanup of the Shpack Landfill
Superfund Site, as presented at the June 23rd, 2004 public
meeting.
The position of the Board and the citizens of the
Town is clear. We are united and steadfast in our
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opposition to EPA's preferred Alternative SC-2B, which does
not meet the needs of the community now or in the future.
We are united and steadfast in our declaration that
Alternative SC-3B is the only acceptable alternative for the
Town of Norton.
OWNERSHIP AND LAND USE:
The Shpack property is owned by the Town of Norton,
through its Conservation Commission, "for administration,
control and maintenance as provided in Section 8C of Chapter
40 of the Massachusetts General Laws" (see deed, dated June
1st, 1981, transfer of property from Lea Shpack). As such,
the land is designated as Open Space.
The Ad Hoc Shpack Committee, appointed by the
Board of Selectmen to work with the Army Corps of Engineers
on reuse scenarios for the Shpack Site (July 2002 - January
2003), selected the reuse option of Passive Recreation, with
the Army Corps' approval. Those decisions are consistent
with the Norton Conservation Commission's statutory charge
and underpin the Town's Alternative SC-3B position. The
Environmental Protection Agency's Directive Land Use in the
CERCLA (Superfund) Remedy Selection Process, dated May 25th,
1995, states:
"The EPA believes that early community
involvement, with a particular focus on the community's
future uses of the property should result in a more
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democratic decision-making process; greater community
support for remedies selected as a result of this process,
and more expedited, cost-effective cleanups."
Further, the Environmental Protection Agency's
Reuse Assessment Guide states:
"The scope and level of detail of the reuse
assessment should be site-specific and tailored to the
complexity of the site, the extent of the
contamination... and the density of the development in the
vicinity of the site."
"The Superfund land use Directive states that in
cases where the future land use is relatively certain, the
remedial action objective or objectives generally reflect,
should reflect this land use."
"EPA is responsible for ensuring that reasonable
assumptions regarding land use are considered in the
selection of a response action."
EPA's current plan, which includes fencing off and
securing the site, institutional controls and monitoring,
with health, human health risk potential considered only for
the adjacent residents and trespassers, clearly ignores the
Town's intended reuse of the site; that being Passive
Recreation within the Norton Conservation Commission's Open
Space Plan.
Since December of 1999, when representatives from
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EPA and the US Army Corps of Engineers came to Norton to
discuss the renewed investigations at the site, and at 13
public meetings from February, 2000, to November, 2003, EPA
gave the same presentation. The Army Corps of Engineers
would first excavate and dispose of off-site all the
radiological waste, including uranium and, and radium, and,
then, the EPA, working with the "Possible Responsible Party"
(PRP) Group, under Superfund, would clean up the remaining
chemical and heavy metal contaminants.
We understood "clean up" to mean excavation and
off-site disposal of all contaminated materials from the
site that posed an unacceptable risk, not just the
radiological waste, some dioxin and the PCB contaminated
soil.
The EPA's preferred alternative does not
accomplish this.
After the Army Corps has removed the radiological
waste, the EPA's plan is to excavate only soil and sediment
that is close to the surface in a certain wetland area, even
though the waste extends to 15 feet below the water table in
some wetland portions of the site, to consolidate this
waste, and leave it in an upland area on site. Outside of
the wetland area, EPA plans to remove only the soil that is
contaminated with dioxin or PCBs for off-site disposal. The
majority of the chemical and heavy metal contaminated soil
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(the responsibility of the EPA and PRP Group), and the
aforementioned wetlands excavation would be transferred to
an on-site location and be capped.
The only alternative acceptable to the Town of
Norton, SC-3B would:
"Remove all radiological and chemically
contaminated materials from the site that pose an
unacceptable risk. As a result, Alternative SC-3 provides
the greatest degree of overall protection."
"Both chemical and radiological source materials,
exceeding cleanup levels would be permanently removed from
the site; thereby, ensuring that this remedy remains
effective in the long term."
"SC-3 would greatly reduce the toxicity of the
material that remains at the site to acceptable levels.
Because all site (sic) and sediment above cleanup levels
will be removed from the property, both the volume and
mobility of contamination is greatly eliminated."
EPA maintains that Norton's Preferred Alternative
provides only "slightly greater protection at a
significantly greater cost". We counter that the opposite
is true. The difference in cost is insignificant compared
with the enormous disparity between the two plans. EPA's
strategy is to contain and cover; the community's chosen
remedy is removal.
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EPA's Preferred Alternative cost is approximately
$29 million. The most expensive alternative considered
under their Feasibility Study exceeds $126 million. At $55
million, the plan chosen by the Town of Norton is a
compromise, already meeting EPA and the PRP Group halfway.
It is not an unreasonable demand given the true magnitude of
this problem.
The time frames and impacts on the community,
between the two alternatives being considered for the
EPA/PRP construction phase of the clean up, are not that
different. "Both are easily implementable." "The
personnel, equipment and materials required to implement
each of these technologies are readily available." Impact
to air quality and to the local roads can be managed by good
construction practices and working with the community.
EPA's Preferred Alternative, which requires
long-term monitoring of the still contaminated, capped
parcel by the PRP Group, is unacceptable and could result in
a permanent financial and regulatory burden for the Town of
Norton. While the Town is given assurances that the PRP
companies entering into the Consent Agreement are now
financially stable, there is no guarantee that will hold
true in the future.
Should those parties disappear from the corporate
universe or simply bail out on Shpack, the Town of Norton,
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with the longest standing on the PRP list as owner of the
property, could be left holding the bag. It is also
possible that the State would be left with the
responsibility of operation and maintenance of the site.
It is naive for the Environmental Protection
Agency to believe that the Shpack Site can be secured with
fencing. Over the last decade, neither EPA nor the PRP's
have monitored the site for security, even though they knew
the dangers posed to anyone who entered the property
unprotected. Fences are broken, "No Trespassing" signs are
faded or have fallen, and beer cans, shotgun casings, etc,
provide evidence of trespassers onto the contaminated land;
likely, others curious about an old dump site ventured there
as well, individuals who had no idea what lay beneath them.
Under the EPA's plan, the Human Health Risk was
calculated based on the adjacent residents entering the
property and trespassers. The impact on human health are
dependent on many variables, including age of the person,
which is impossible to determine with the trespassers or the
adjacent resident, as that person, or persons, will
undoubtedly change.
The extension of Norton's water main to the end of
Union Road at the Attleboro city line raises concerns over
new development in the residentially zoned area near the
site, which will expose more residents to EPA's "accepted
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minimum risks" at Shpack. Redevelopment of the 5-acre
parcel of land on which the Shpack residence is situated is
also likely.
In response to the rationalization that
"typically" all landfills are capped, the Shpack site, if it
is anything, is not typical. In fact, although residential
and industrial waste were disposed of there in order to fill
a wetland, the Shpack Superfund Site does not technically
fit in the category of municipal landfills, and the
standards and regulations applied to those licensed
facilities (like the neighboring Attleboro Landfill, Inc.)
should not be assumed the rule for Shpack, which was in fact
a privately owned and operated illegal dump.
Once the Shpack Site is properly cleaned up, we do
expect a cap, that being a cover of clean soil and grass, to
return the land to as near a natural state as possible.
EPA's process, EPA's scheduling of this critical
part of the process (the presentation of its clean up plan,
the public comment period, and the public hearing) from the
end of June through August is unfortunate. Attendance at
the public meeting of June 23rd, 2004, in Norton was very
low compared to past meetings. The low turnout can be
attributed to summertime vacations and other pleasant
distractions which preoccupy much of the public. However,
neither the EPA nor the PRP Group should underestimate
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Norton's resolve. We will exhaust all regulatory, political
and legal means possible to effect the SC-3B solution.
In conclusion, the US Environment Protection
Agency's Proposed Plan For The Cleanup of the Shpack
Superfund Site, 2004, its Preferred Alternative SC-2B (The
Capping Alternative) is unacceptable to the Town of Norton
because:
It does not adequately address the community's
planned reuse of the site, now or in the future. It
appears, in fact, that contrary to the Agency's own stated
policy, this was not a consideration in the selection of its
response action.
EPA's Preferred Alternative is not as effective,
in the long term or the short term, as Norton's Preferred
Alternative.
EPA's Proposed Plan does not provide a permanent
solution to our environmental concerns.
EPA's Preferred Alternative leaves the Town of
Norton with a still contaminated site and a consequentially
unacceptable level of residual risk.
The Town should not have to tolerate the stigma
attached to a toxic waste Superfund Site any longer.
SC-2B results in a permanent financial and
regulatory burden on the Town.
The EPA's Proposed Plan is not considered to be a
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"Remedy".
It is the Board of Selectmen's position that
Norton's Preferred Alternative, SC-3B, is a fair compromise,
at a realistic cost to EPA and the PRP Group, with an
acceptable time frame that provides a reasonable solution to
the decade-old, decades-old problem of the Shpack Superfund
Land Site.
Respectfully submitted by the Norton Board of
Selectmen, Robert W. Kimball, Jr., Chairman. That's
K-1- M - B- A- L- L.
Thank you.
MS. STUDLIEN: Thank you, Selectman.
(Applause.)
MS. STUDLIEN: Thank you.
Our next speaker is Richard Gomes.
(Pause.)
MR. GOMES: Good evening.
My name is Richard Gomes. Last name is spelled
G- O- M - E- S. I'm the Deputy Fire Chief for the Town of
Norton.
I'm just going to go into a little past history.
It's going to be very short, but I will go somewhere with
it.
In the 50's and 60's when the Shpack Site was in
use, and I see it referred to very nicely as a landfill, it
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was a dump. There was no regulation for that type of
operation. The Town was never involved. It was a private
fill, private land use, and there was no regulatory
stipulations at the time. There were no regulations for
that type of use.
Over the years, when the dump was in operation,
the Fire Department responded to many fires there; involving
either rubbish or brush. Many fire fighters either ingested
or absorbed or inhaled contaminants from that site. Over
the years, several of the fire fighters have died of cancer
since that site is closed. Now, we don't know if that had
anything to do with that site.
The point is that, and this is where I'm going,
it's that we don't know. If the site is cleaned up with the
proposal as stated by the EPA, people who visit the site,
trespass the site will not know.
The other thing I'd like to point out is that the,
the people are being referred to "principally responsible
parties". I consider them to be solely responsible parties,
and the Fire Department would like to see you stay with the
plan 3B to completely remove contaminants from the site,
which will alleviate any problems in the future, either
regulatory, financial or any other. It, it will bring the
Town in to a fray if they have no, no business in the
planning or having any party to it.
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Thank you.
MS. STUDLIEN: Thank you, Mr. Gomes.
(Applause.)
MS. STUDLIEN: Thank you.
Our next speaker is Ron O'Reilly.
MR. O'REILLY: Ronald O'Reilly, O, apostrophe,
R- E-1- L- L- Y.
I have lived on Union Road for 32 years. Six
years before the existence of the Shpack Site was
publicized. The 1998 (sic) discovery of nuclear waste at
the Shpack Site, and the following 25 years of failed
cleanup still plagues us to this evening.
In 1978, when a young student with a geiger
counter went to the City Officials, in Attleboro, thinking
that the land was located there, he was ridiculed. He was
referred to in the paper as a lunatic. Each time he tried
to bring attention to the problem, he became the problem.
No one from Texas Instruments stepped forward to
investigate the possible problem. The community did not
know that 1,000 pounds of nuclear material was missing from
TI's Nuclear Processing Plant, but, surely, the people at TI
knew that nuclear material was missing.
We have to assume that both Texas Instrument and
the Department of Energy were aware of the missing 900,
1,000 pounds of enriched uranium pellets.
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In 1980, the Department of Energy quietly removed
in excess of 900 pounds of the enriched uranium pellets from
the Shpack Site; however, no attempt was ever made to locate
any pellets that may have been picked up by kids taking a
shortcut from the dump through the Shpack property.
For those who are too young to remember, in those
days, as was just stated, it was a dump. It was not a
landfill. Many kids used to go there. There were always
interesting things to be picked up. People used to go there
for target practice. A shortcut from the Attleboro dump was
through the Shpack property. The enriched uranium pellets
were probably enticing, and I would imagine some of them
were picked up at various times and taken home.
The Department of Energy erected a fence and
tested the site in the early 80's, and they left the scene
shortly after. After about five years, the brush overgrew
the fence, and, eventually, the fence collapsed. Hunters
were frequent visitors going duck hunting in the swamp, and
ATV's coming along the electric company right of way used it
as a turn around.
The fence on the site today, which was erected
within the last five or six years, is fully over grown and
is barely visible from the street, and it sits on the
street.
These events show that despite the knowledge of
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nuclear hazardous waste, the government was unable to
prevent trespassing at the site. There is no reason to
believe that the future will be any different. Trespassers
on that site will be a perpetual problem.
When we get to talking about capping, the
Attleboro Landfill is a good example of problems with
capping. The plan was approved by the Mass Department of
Environmental Protection. The capping was done and was
inspected as it was progressing by the Department of
Environmental Protection; yet, despite a statutory
requirement, no bond was posted to insure that the site
would be maintained in the future.
Today we know the site needs to be recapped.
Water runs off into the street. During the capping, there
was an explosion and fire. It was not reported. Erosion of
the capping material is evident from the street, and this is
just an example of what's going to happen with capping.
Capping is not a permanent answer.
The steep slope, the plans are in the works to
reopen the cap and try to get it done right in the future.
If it was done right, if they were able to do it right the
first time, it would have been done. There is no reason to
believe the Shpack will be done right the first time.
The Shpack Site is along an electric company right
of way. It runs all the way to Fall River. It's highly
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traveled by ATV's and dirt bikes and motor bikes. The
capping will create an inviting ramp and a jump for these
vehicles. These are recreational vehicles, and they're
always looking for a ramp or a jump. As a result of their
using the ram — the cap as a jump, the cap will deteriorate
very quickly and expose the bikers to hazardous chemicals
and fumes.
EPA has previously advocated Cleanup SC-2B using
the justification that the PRP's will be around in the
future if additional funds are needed. Texas Instruments is
the primary PR — is the PRP with the deepest pockets. Many
of us remember when TI employed over 5,000 people in
Attleboro. Today that number is scheduled to drop to 900.
Who knows if TI will even be in business in the
United States in 20 years if additional funds are required?
The time to cleanup the site is now or the Town of Norton
will be liable in the future.
EPA sought citizen input, and the citizens
advocated the cleanup identified as SC-3B. EPA now faces
the cleanup proposed by the PRP, primarily Texas
Instruments, the same Texas Instruments that stuck its head
in the sand when 900 to 1,000 pounds of nuclear waste was
missing for 25 to 35 years. There is no reason to believe
the PRP's will be anymore responsive to the future problem.
The only cleanup that should be consider is SC-3B.
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Thank you.
(Applause.)
MS. STUDLIEN: Thank you, very much.
(Applause.)
MS. STUDLIEN: Thank you.
Our next speaker is Gary Covino.
MR. COVINO: Good evening. My name is Gary
Covino. I'm the Health Agent for the Town of Norton. The
Town - - sorry about that.
The Town of Norton Board of Health appreciates the
opportunity to comment on the Proposed Cleanup Plan for the
Shpack Landfill Superfund Site.
We cannot support any remediation alternative
which does not provide the overall protection of human
health and the environment. We are in general agreement,
following the public information meeting, that the two
alternatives deserving further consideration are SC-2 and
SC-3 and their variations that provide protection to the
adjacent resident without groundwater consumption.
That is SC-2B and the EPA's preferred alternative
and SC-3B. Both of these alternatives include installation
of a water line to two residences adjacent to the Superfund
Site.
Recent history has shown that installation of a
water line in the area where devel - excuse me. Where
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development could occur has invited residential development.
The Board will not allow residential portable
water wells in the area of Superfund Site; however, we
cannot deny, nor can the Water Department, connection to the
water main installed adjacent to the property.
It has been noted that much of the open land,
along with the water line rouse, is conservation land, but
we believe any developable land will be developed following
the water line installation.
We doubt that the restriction on connections would
be enforceable, and we have to agree with the Water
Department on the policy of sizing pipe installation for
fire protection and future looping; so, any water line
installed will have the capacity for development.
We are concerned with the difference between the
two alternatives and the permanence of the solution and the
effectiveness in protecting the recreational and occasional
user of the site. The least protective of the two
alternatives, SC-2B, consolidates waste as the new landfill
area seals off from normal activities, provides the
monitoring and maintaining of the new landfill.
The Board presently maintains and monitors a close
landfill. It has been subject to trespass, vandalism and
damage from natural causes. This is an ongoing concern
that, at some time in the future, the Board will be required
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to meet some new regulations, deal with some previously
undetected contaminants or spend the sum dealing with the
bad laboratory data. These same ongoing maintenance costs
and concerns would apply to the new landfill on the Shpack
Superfund Site.
While the EPA can argue that the cost of all
future maintenance and monitoring of the Shpack Superfund
Site will be the responsibility of the PRP's, we are
concerned that the Town of Norton is a PRP. The Town is the
PRP with the longest history and we'll be around after all
of the PRP's disappear from the corporate universe.
The Town cannot be sold off to another company and
disburse its liability. Most importantly, should the Board
be left holding the proverbial bag, as the last PRP
somewhere in the distant future or even as, as one of
several PRP's at the same point in time, the Commonwealth
and federal governments have control of funding for the Town
that could be used in simple maintenance required in
compliance with future regulatory requirement.
The lack of permanence in the EPA's preferred
alternative will result in permanent financial and
regulatory burden for the Town of Norton.
The Town of, the Town of Norton Board of Health is
concerned with the EPA's preferred Alternative SC-2B, which
is not as effective as another Alternative SC-3B, in the
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long term or the short term.
While it could be argued that new landfill or
Superfund Site, in Alternative SC-2B, will result in the
better protection from the consolidated waste and less risk
that the existing condition, the alternative will bring more
people to the area when site development occurs along with
the water line.
More residents living closer to the site will
increase the recreational use, number of — excuse me,
number of EPA's accepted minimum risks. The increased
development will, also, increase the number of potential
trespassers and vandals entering the suppose to be secured
land; thereby, increasing exposure, as well as maintenance
costs.
This is not a result that would be particular
Norton, and we would expect that you have seen a similar
result in other locations where landfills have been
consolidated in residential areas.
The Norton Board of Health cannot support the
EPA's preferred alternative and strongly recommends
implementation of a clean cleanup Alternative SC-3B,
installation of a water line and removal of all radiological
and chemically contaminated materials that pose the
unacceptable risks.
The Norton Board of Health understands that there
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are potential impacts in the community from the
implementation of the preferred cleanup plan and possibly
more significant impacts from the alternative we recommend.
The impacts to air quality and to local growers by
truck traffic can be managed by good construction practices
and working with the community. The air quality of the area
surrounding the Shpack Landfill Superfund Site will not be
deteriorated by the cleanup activities in the site.
Standard construction activities and strict monitoring can
be specified and implementing the assuredness.
The Board of Health may require that monitoring
reports be provided to the Board and may require specific
monitoring during cleanup operations. Spillage from the
trucks leaving the site will not be acceptable in the roads
in the area of the Shpack Landfill Site. They are generally
not in accordance to support long-term truck operations.
Again, standard construction activities and strict
monitoring will be specified and implemented to ensure the
materials are not carried off of the site into local roads,
and that transporting materials are not released from the
trucks.
The Board recommends that rail transport, using
the nearby rail lines be considered and implemented if at
all possible. Activities at the Shpack Landfill Superfund
Site and the adjacent Attleboro Landfill will require
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removal of materials and the import cover materials. The
Board recommends that rail transport, using the nearby rail
be considered and implemented if at all possible.
If rail trans — transport can't be implemented an
existing road network must be used. The Board recommends
that all parties involved — PRP, Corps of Engineers,
Attleboro Landfill, Mass DEP, EPA — work to improve
specific roadways to a standard that will support the level
of traffic needed.
The Board of Health will work with the local
public safety officials and other Town Boards to reduce the
impacts of truck traffic in the Town of Norton and its
residents.
Respectfully, the Board of Health.
MS. STUDLIEN: Thank you, very much.
(Applause.)
MS. STUDLIEN: Thank you.
Our next speaker is Jim Mooney.
(Pause.)
MR. MOONEY: Good evening.
I do appreciate the opportunity to come before you
tonight to discuss a little bit about Attleboro's idea of
what should be done over there.
I'm not here to argue with or disagree with
Norton's proposal for the SC-3.1 think once we pass over
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to Norton, I think Norton should be the only one that should
determine ultimately what happens there; however, in the
Attleboro side, we roughly have two and a half acres. Most
of the contamination is not in the Attleboro side. Most of
it is on the Norton side.
Both alternatives, SC-2 and SC-3, will provide
overall protection, health protection to the residents and
to the people of both Attleboro and Norton.
SC-2, SC-2 is a good problem solver. It's done
all over the United States. We have brown fields
everywhere. I have brown fields in Attleboro. I have brown
fields in Attleboro that are currently, now, recreational
sites. I have contaminated sites in Attleboro that, within
the last 27 years, have been covered, capped, and they're
used as athletic fields, that are used as basketball courts,
and they're used as a number of recreational type facilities
for the general public. I believe that, at no time, have
any of these individuals in Attleboro at risk by using these
sites. It is an alternative that the, both state and
federal government, even the City of Attleboro, has had to
address many times in Attleboro.
This is not our first site to deal with. We've
dealt with many sites in Attleboro. We did have a
radioactive ball field years ago. It had Radon.
Fortunately, legislature bailed us out, passed an immediate
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bond to the City of Attleboro and we were able to remove the
radiation, cap the site and now, more than 125 kids play on
that site every night.
I'm not opposed to having something done, and I
want something done that will protect everyone. Whether
you're a citizen of Attleboro or a citizen of Norton, I want
everybody protected. Some things can be done with a lot of
thought, a lot of science, to properly protect.
In Attleboro, the S-2 sites, since we have no
interest, and I don't believe ALI or anybody over there has
any interest in putting a house or a recreational field or
anything on the two and a half acres on the Attleboro site,
the S-2 site seems adequate enough to protect, certainly,
the citizens of Attleboro and, hopefully, the citizens of
Norton.
Norton officials and representatives and
legislatures got up and said, "Hey, the best way to fix
something is to completely remove it." That's true. So,
for Norton, that may be their best proposal, and it may be
the thing that needs to be done, but that two and a half
acre site, I don't know it needs to be completely removed of
all contamination. It's never going to be used.
Both sites, both proposals require that a water
line, a 4,000 foot water line be extended down from Norton,
down Union Road, to the Shpack House and to the house
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adjacent across the street. I think it's a great idea.
Those two wells that have contamination should be protected.
However, I have two wells in Attleboro. I, also,
have a well that was condemned years ago at the ALI site.
So, if you want to be complete, there are actually three
wells that have had some contamination. One no longer being
used.
I reviewed the proposal to extend the water line
4,000 feet from Norton down to these two houses with a
10-inch main. They plan to go underneath the railroad
tracks at a tremendous cost of $125,000.00. I've spoke with
the Mayor or Attleboro. I've spoke with a number of
councilmen. I've spoke with the superintendent of Water.
We do have a. water service on the Peckham side. It's
almost 500 to 700 feet closer to these two homes. We do not
have to go under a railroad line to supply those units with,
with water. There is an immediate savings of over
$125,000.00.
What I propose is that, or have, at least, the EPA
look at allowing the water line to come in from Attleboro.
Attleboro is agreeable to that. We have an eight-inch main
that we can send down there. There is more than enough
water to supply the two houses in, in Norton.
I don't think the water bill is going to be much
different than what it is in Attleboro. We're talking
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pennies. That would save a tremendous cost. I believe
that, that $660,000.00 cost to extend the water line could
be reduced by as much as $250,000.00 if the Town of Norton
and the City of Attleboro and the EPA agree to this.
You've got to remember that we're all part of
this. We're all going to pay the cost of this. We're all
PRP's. As your agent just informed you, whatever the cost
of this, it's not going to be paid by TI. It's going to be
paid equally by all the PRP's. Whether we want to spend,
initially, the cost of $128 million to clean this site,
there isn't that many PRP's out there. It's going to be an
equal cost to all of us, the City of Attleboro, the Town of
Norton.
You have to look at how many PRP's are out there.
There is about a dozen PRP's. If this project goes on, and
we go with 50 or a 100 million dollar cost, it's going to be
divided by all the PRP's. The Town of Norton could be faced
with a five, three to five million dollar cost. So, I'm
just, I just hope that the Town of Norton recognizes that.
The City of Attleboro recognizes that.
The cost is going to be directed through the town
because the citizens of Attleboro and the Town of Norton did
use the Shpack Site, as did the City of Attleboro. When I
say, "The Shpack Site," I mean that little two and a half
acre pie that's considered part of the Shpack Site. It's
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part of Attleboro.
I don't know if the residents are aware of this.
I don't know if the Town officials are aware of this, but
there is a hell of a liability to your town, as there is to
Attleboro. I will not do anymore talking about Norton
because I think you make your own decision, and my thoughts,
privately, I have thoughts about what I'd like to see you
people do, but from may authoritarian point of view, my
jurisdiction ends at the property line.
The first alternative I think is acceptable to
ALL I think what would happen to ALI, the City of
Attleboro, I think what would happen with the capping
probably would happen with ALI, but it would probably be
somewhat corrected by an extension of another two and a half
acres of filling; hopefully, that addressed some of the
problems they have over there, and the rest of it I leave up
to Norton, but I would entertain that the federal government
look at saving some money and look at putting the water line
through the City of Attleboro.
MS. STUDLIEN: Thank you, very much.
(Applause.)
MS. STUDLIEN: Our next speaker is Heather Graf.
MS. GRAF: My name is Heather Graf. I'm the
Coordinator of the Citizen's Advisory Shpack Team. The
spelling is G- R- A- F, as in Frank. One F.
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To Dave Lederer comments. The US Environmental
Protection Agency has always referred to the Shpack Site as
a landfill. We never paid much mind to the use of this
word, but, in hindsight, we should have because, now, the
EPA and the Massachusetts Department of Environmental
Protection Agencies are attempting to justify their cover
and cap proposal for Shpack by saying, "All landfills are
capped."
Well, we would not argue that landfills are
typically capped, but we do counter that the Shpack Site is
not a landfill, and cannot be designated or treated as such,
and while Isadora Shpack accepted any wastes that needed
disposing of in order to fill his wetland property, this
site was, in fact, a privately owned and operated illegal
dump. The Shpack Superfund Site must be classified and
correctly dealt with for what it is, a toxic waste dump, not
a landfill.
The Shpack dump site, also, differs from landfills
in having commingled waste materials; that being a mixed up
mess of both radiological contaminants, uranium and radium,
chemical wastes, some of which are classified as
carcinogenic, volatile inorganic and organic compounds, as
well as high levels of heavy metals; including lead and
arsenic.
The presence of high grade radioactive materials
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had complicated the cleanup process at Shpack. Since 1979,
when the RAD contamination was first detected, numerous
agencies were called upon to investigate the site; including
the Nuclear Regulatory Commission and the US Department of
Energy. The acronym for that is DOE.
In 1980, the DOE removed approximately 800 pounds
of radiological contaminated material from the surface of
the site. Ultimately, the responsibility for dealing with
the uranium and radium fell to the US Army Corps of
Engineers, ACE. Their plan is to excavate, remove and
dispose of, off site, all radiological wastes that exceeds
standard levels for human health and safety.
Considering the fact that these hot spots are not
isolated or centralized, but widely scattered all over the
property, a map identifying the hot spots looks like a bad
case of the measles, and the fact that the radiological
contamination does not lie on the surface but goes to a
depth of up to 20 feet, it is safe to assume that the
activities undertaken by the Army Corps, the first
responders on this site, will greatly decrease the amount of
waste material left for the EPA.
Is it logical even to a layman, just glancing at
the big picture, to see that the lion's share of the waste
material on this site will be taken away by the Army Corps.
In most of the dump, the contaminants are
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commingled. The radiological with the chemicals and heavy
metals. The construction crew working for the Army Corps
must continue digging and removing until they reach the
perimeter where soil tests indicate they are clear of
radiological contamination.
Even in the EPA's current plan, their estimated
volume of RAD material expected to be removed by the ACE is
several thousand yards less than the Corps' estimate, and a
spokesman for the Army Corps admits that their own estimates
always fall short of the actual amount of material they
windup removing.
The excavation, removal and disposal by the Army
Corps of all the radiological contaminates, which cover the
site heterogeneously and go to considerable depth, will also
take out and away much of the chemical and heavy metal waste
leaving less material for the Environmental Protection
Agency to have to deal with.
To those reviewing the Feasibility Study, FS,
intended to support EPA's chosen plan, it does not appear
that this has been given adequate attention.
Also, in the FS, has the draft considered the most
or likely that most, or likely all of the soil with combing
of waste will already have been removed from the site by the
Corps, or did the authors of this report factor in disposal
costs that the contractor working for the possible
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responsible party, PRP Group under EPA, will be charged
factoring it at the highest cost, which is associated with
combing of the waste?
It is apparent that the Feasibility Study is
flawed in overestimating the amount of contaminated material
the PRP's working with EPA will be left to deal with and,
also, overestimating, on top of that, the disposal costs.
In fact, the cleanup alternative preferred by the Town of
Norton would cost considerably less than reports for the EPA
indicate.
It should be noted here that the draft final
Feasibility Study, dated June 17th, 2004, was prepared by
ERM, Environmental Resources Management, "For the Shpack
Steering Committee."
I expect many people reading this testimony
understand that the Shpack Steering Committee is, in fact,
the PRP Group, responsible parties; six companies being held
responsible for the contamination at Shpack and the cost to
cleanup the contamination that is not radiological.
The Shpack, the Shpack Steering Committee should
not be viewed as unbiased. They are a special interest
group whose goal must be to get EPA to accept a cleanup plan
that lets them off the hook as quickly, easily and cheaply
as possible.
It is obvious that EPA has complied choosing the
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alternative that, above all, satisfies the PRP needs, but
still, according to EPA officials, meets the criteria for
their task under Superfund. it would appear a new line time
has been added to the EPA's list of qualifying criteria;
that being PRP satisfaction.
Why would the US Environmental Protection Agency
go in this, go in this direction? Perhaps, because having
the Shpack Site still on their national priority list of
Superfund Sites, after almost 2G years, is an embarrassment.
More embarrassing for EPA and incomprehensible is
the fact that after four and a half years of working with
the Town of Norton, or so we thought; after 13 public
meetings in the Town of Norton, and five smaller meetings
where the Ad Hoc Shpack Technical Committee discussed reuse
scenarios for this site the agency pretends it just doesn't
get it.
At the 11th hour, they pull the rug out from under
us with this stupid plan. Instead of negotiations occurring
between EPA and the PRP Group, which were suppose to start
after the upcoming record of decision and take one to two
years, the Environmental Protection Agency has instead put
the Town of Norton in the extremely difficult position of
having to negotiate for an acceptable cleanup plan.
Although fully engaged in this process for the
entire period, I never saw this coming. Had there been an
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inkling to us during the four and a half year process, that,
in the end, this cover and cap plan would be EPA's preferred
alternative for remedial action at the Shpack Superfund
Site, we would have had an opportunity to fight back and
time to change the course of EPA's decision.
In four and a half years of discussions with EPA,
the project manager, who has been on this Superfund Site
since the beginning, never, ever, in our presence, uttered
the word "cap".
While I would not be here tonight if I thought it
was too late to alter their course, obviously, EPA has put
the Town of Norton at a tremendous disadvantage.
One of the criteria the US Environmental
Protection Agency must consider, must consider in their
record of decision for cleanup of Superfund sites is
community acceptance.
Let us all be perfectly clear here. The Town of
Norton is united and steadfast in our opposition to EPA's
preferred Alternative SC-2B, which does not meet the needs
of the community now or in the future. It does not provide
a remedy, does not allow reuse of a site for passive
recreation, does not have permanence as in a permanent
solution, and places an unfair burden on the Town.
The Town, further, the Town of Norton is united
and steadfast in our declaration that Alternative SC - -
APEX Reporting (617) 426-3077
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SC-3B is not only the preferred alternative of the Town, it
is the only acceptable alternative for the Town.
Any alternative which provides a level of cleanup
lower than the SC-3B will be unacceptable. We do expect
EPA's final chosen plan of action and record of decision to
support Alternative SC-3B for remedial action at the Shpack
Superfund Site.
Finally, if my state tax dollars are going to the
Massachusetts Department of Environmental Protection, DEP,
to support this plan, I'm not going to pay, and if my
federal tax dollars are going to the US Environmental
Protection Agency to propose this dumb plan, I'm not going
to pay.
Thank you.
(Applause.)
MS. STUDLIEN: Angela, are there any other
speakers?
MS. BONARRIGO: No, that's it.
MS. STUDLIEN: Pardon?
MR. LEDERER: No one else has signed -
MS. STUDLIEN: I'm sorry. Is there any other
person that wants to speak?
(No verbal response.)
MS. STUDLIEN: Okay. Thank you, very much, for
participating in the hearing, and, please, remember that the
APEX Reporting (617) 426-3077
-------
public comment period for making written comments doesn't
close until August 25th.
This hearing is now officially closed.
(Whereupon, on August 4th, 2004, at 8:45 p. m.,
above-entitled public hearing is closed.)
APEX Reporting (617) 426-3077
-------
62
CERTIFICATE OF REPORTER AND TRANSCRIBER
This is to certify that the attached proceedings
in the Matter of:
RE: PROPOSED CLEANUP PLAN
SHPACK LANDFILL SUPERFUND SITE
NORTON/ATTLEBORO, MASSACHUSETTS
Place: Norton, Massachusetts
Date: August 4, 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,
Kate Soukonnikov 08/04/04
Reporter Date
Susan Haves 08/12/04
Transcriber Date
APEX Reporting (617) 426-3077
-------
RESPONSIVENESS SUMMARY
ATTACHMENT B
WRITTEN COMMENTS RECEIVED
109
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Comments to The US EPA on the June 2004 Proposed Plan For the Cleanup of
The Shpack Superfund Site, Norton/Attleboro, MA
To Dave Lederer
U.S. EPA :
One Congress St., Suite 1100 (HBO)
Boston, MA 02114
Deadline - Postmarked By Wednesday, August 25,2004
FAX (617) 918 - 1291, No Later Than Wednesday, August 25,2004
August 2004
I am writing to express my firm opposition to the EPA's proposed plan for the 'cleanup'
of the Shpack Superfund Site.
EPA's preferred alternative (SC-2b) is unacceptable for reasons too numerous to detail
here. Most objectionable is the fact this option does not provide "permanence" and is
therefore not a "remedy". It would leave the Town of Norton with a still contaminated
site, and the responsibility & burdens of dealing with it, in the near and distant future.
In the face of the promise the Environmental Protection Agency made to the town,
EPA's chosen course of action, is reprehensible.
If community acceptance, plays any role in the EPA's decision making process for the
cleanup of Shpack, please give serious consideration to these comments, and select
Alternative SC-3b. which will at long last give residents of this community the peace of
-------
SENATOR JO ANN SPBAGUE
BRISTOL AND NORFOLK DISTRICT
ATTLEBORO WARD 3. PRECINCT B. WARD A,
Ward 5. ward 6, Mansfield, Norton, Rehoboth
SEEKONK, DOVER, FOXSOROUGH, M6DRELD,
SHARON, PRECINCTS 1, 4, AND 5, WALP0LE
305 ELM STREET
WALPOLE. MA 02DS1
Tel. (508| 668-8511
Fax <5081 668-5713
August 5, 2004
Mr. David Lederer
US EPA
One Congress Street, Suite 1100 (HBO)
Boston, MA 02114
Room 206, STATE HOUSE
TLl <617v 722- 1222
FAX £617) 722 1Q56
COMMITTEES
WAYS AND MEANS
PUBLIC SAFETY
TAXATfON
EDUCATION. ARTS ft HUMANHIf-S
PUBLIC SERVICE
SCIENCE S 1 (rCHNOLOQ v
LOCAL AFFAfRS
t-Maii JSprngue'-'senate state i
RE: Shpack Superfund Site Cleanup
Dear Mr. Lederer:
1 am writing on behalf of my constituents in the Town of Norton to strongly
support the Town's choice of SC-3b as the best cleanup alternative for the Shpack
Superfund Site. I am steadfast in my opposition to the EPA's choice of SC-2b as the best
cleanup alternative.
My constituents and I demand that the old Shpack Dump property be returned to a
safe enough condition that it can be used for passive recreation within the Norton
Conservation Commission's Open Space Plan. This use conforms to our understanding
of what the term "use" has meant during the meetings between the Adhoc Shpack
Committee, the Army Corps of Engineers and the U.S. EPA.
w
D
The EPA alternative, SC-2b, will remove only some elements of the waste and 5
contain the remaining contaminants under a cap. We knov. that caps deteriorate, which o
could re-initiate the pollution cycle. Also, SC-2b would not allow my constituents the 5
kind of use they had been led to expect. The requirement of fencing and a "No
Trespassing"' sign is evidence that SC-2b would not be a full fledged cleanup, therefore, g
the Town and its citizens would be left to bear the burden of fighting future ^
contamination and policing problems at the site. y
The EPA's decision in this case should not be based on what the remediation
costs, but on what is in the best long term interest for Massachusetts citizens, all of whom
are taxpayers with a vested interest in a clean environment for our families, friends and
neighbors.
©
-------
Through the years, my Norton constituents have paid millions of dollars of their
hard earned money in taxes to the state and federal government. In this way, the
townspeople, for years, have paid for government actions that benefit not only
themselves, but actions that provide, also, for the common good for citizens throughout
this great country.
It is now time for the EPA to stand tall and acknowledge that the common good
requires a permanent and proper clean-up of environmentally unsafe waste. There is no
better use for our citizens' tax dollars than to provide for the environmental safety of the
citizens residing in this area now, for the generations to follow, both of which will
ultimately be of benefit to all the citizens of our country.
Mr. Lederer, my constituents, their local officials and I, along with other state and
federal officials demand that government do the right thing for the environmental safety
of us and future generations by adopting choice SC-3b for the cleanup of the Shpack
Superfund Site.
We will be proud to stand by you in this action, and in doing so we will be proud
to say we won one for the environmental protection of our land and people.
Chr £ommDHturaji^ofiBjt8snrl|iiBptts
MASSACHUSETTS SFNATF
Jo Ann sprague
Bristol 8 Norfolk district
Ways and Means Committee
Room 206, staff house
Boston, ma 02133-1053
TEl {817; 17.-2 1222
305 ELM SrfifcfcT
WALPOLE. MA 02O81
DISTRICT' TEL (BOB) 66fc! £3511
f Mail J Sf) r figure's an pre r.--i \,n
-------
August 4,2004
Heather A. Graf
Citizens Activist, Town of Norton
229 N. Worcester St.
Norton, MA 02766
Ph.(508) 226-0898
FAX (508) 226-2835
To - Dave Lederer
US EPA
One Congress St., Suite 1100 (HBO)
Boston, MA 02114
Comments On the US Environmental Protection Agency's "Proposed Plan For Cleanup Of The Shpack
Landfill Superfund Site, June 2004"
The US Environmental Protection Agency has always referred to the Shpack Site as a "Landfill". We never
paid much mind to the use of the word. In hindsight, we should have. Because now the EPA and the
Massachusetts Department of Environmental Protection Agency are attempting to justify their Cover & Cap
proposal for Shpack, by saying - "all landfills are capped". While we would not argue that landfills are
typically capped, we counter that the Shpack Site is not a landfill, and cannot be designated or treated as
such.
And while Isadore Shpack, accepted any waste that needed disposing of, in order to fill his wetland
property, this site was in fact a privately owned & operated Illegal Dump.
The Shpack Superfund Site must be classified (and correctly dealt with) for what it is - A Toxic Waste
Dump, Not A Landfill!
The Shpack Dump Site also differs from landfills in having "Commingled Waste Materials", that being - a
mixed up mess of both radiological contaminants (uranium& radium), chemical wastes (some of which are
classified as carcinogenic), volatile inorganic & organic compounds, as well as high levels of heavy metals
(including lead & arsenic).
The presence of high-grade radioactive materials has complicated the cleanup process at Shpack. Since
1978, when the rad contamination (including enriched uranium) was first detected, numerous agencies were
called upon to investigate the site, including the Department of Environmental Quality Engineering
(DEQE), the Nuclear Regulatory Commission (NRC), & the US Department of Energy (DOE). In 1980 the
DOE removed approximately 900 pounds of radiological contaminated material from the surface of the site,
which was transported to the Oak Ridge National Laboratories in Tennessee.
Ultimately the responsibility for dealing with the uranium & radium fell to the Us Army Corps of Engineers
(ACE). Their plan is to excavate, remove and dispose of (off site) all radiological waste that exceeds
standard levels for human health & safety.
-------
August 4, 2004
Graf to EPA
Page 2
Considering the fact that these hot spots are not isolated or centralized, but widely scattered all over the
property (a map identifying the hot spots looks like a bad case of the measles), and the fact that the
radiological contamination does not lie on the surface, but goes to a depth of up to 20 feet, it is safe to
assume that the activities undertaken by the Army Corps (first responders on site) will greatly decrease the
amount of waste material left for the EPA. It is logical, even to a layman, just glancing at the big picture, to
see that the lion's share of the waste material on this site, will be taken away by the Army Corps.
In most of the dump, the contaminants are commingled, the radiological with the chemicals and heavy
metals. The construction crew working for the Army Corps must continue digging & removing until they
reach the perimeter where soil tests indicate they are clear of radiological contamination. Even in the EPA's
current plan, their estimated volume of rad material, expected to be removed by the ACE, is several
thousand yards less than the Corps' estimate. And a spokesman for the Army Corps admits that their own
estimates always fall short of the actual amount they wind up removing.
The excavation, removal & disposal (by the Army Corps) of all the radiological contaminants (which cover
the site heterogeneously, and go to considerable depth) will inevitably also take out and away - much of the
volatile organic & inorganic compounds, including chemical & heavy metal waste, leaving far less material
for the Environmental Protection Agency to deal with. To those reviewing the Feasibility Study (FS),
intended to support EPA's chosen plan, it does not appear that this has been given adequate attention, in fact
it has been ignored.
Also in the FS, Question? - Has the draft considered that most (or likely all) of the soil with commingled
waste will have already been removed from the site by the Corps? Or did the authors of this report factor in
disposal fees (that the contractor working for the Possible Responsible Party (PRP) Group, under EPA) -
will be charged, at the high cost associated with commingled waste?
It is apparent that this Feasibility Study is flawed, in over estimating the amount of contaminated material
the PRPs (working with EPA) will be left to deal with, and over estimating (on top of that) the disposal
costs. In feet the cleanup alternative preferred by the Town of Norton would cost considerably less than
reports for the EPA indicate.
It should be noted here that the "Draft Final Feasibility Study" dated June 17,2004 was prepared by ERM
(Environmental Resources Management) "For The Shpack Steering Committee". I expect many people
reading this testimony, understand that the Shpack Steering Committee - is in fact the PRP Group
(responsible parties), six companies being held responsible for the contamination at Shpack and the cost to
clean up the contamination that is not radiological.
-------
August 4,2004
Graf to EPA
Page 3
The Shpack Steering Committee should not be viewed as unbiased. They are a special interest group, whose
goal must be to get EPA to accept a cleanup plan mat lets them off the hook as quickly, easily and cheaply
as possible. It is obvious that EPA has complied - choosing the alternative that above all satisfies the PRPs'
needs, but still (at least according to EPA officials) - meets the criteria for their task under Superfund. It
would appear a new line item has been added to the EPA's list of qualifying criteria - that being PRP
satisfaction!
Why would the US Environmental Protection Agency go in this direction? Perhaps, because having the
Shpack Site still on EPA's "National Priority List (NPL) of Superfund Sites", after almost 20 years is an
embarrassment.
In its haste to de-list the Shpack Site, the Environmental Protection Agency (in a mad dash to the September
30,2004 finish line), is rushing to approve a plan which ignores EPA's stated goals & responsibilities. In
choosing SC-2b as their "Preferred Alternative" the Environmental Protection Agency has given notice that
it is renouncing its commitment to the Town of Norton.
What should be most embarrassing for the EPA, and what I find incomprehensible, is the fact that after 4 &
1/2 years of working with the Town of Norton (or so we thought), after 13 public meetings in the Town of
Norton, and five smaller meetings - where the Ad Hoc Shpack Technical Committee discussed reuse
scenarios for the site, this agency pretends it just didn't get it!
And at the eleventh hour, they pull the rug out from under us with this stupid plan. Instead of negotiations
occurring between EPA & the PRP Group (which were supposed to start after the Record of Decision, and
take 1 to 2 years), the Environmental Protection Agency has put the Town of Norton in the extremely
difficult position of having to be the ones negotiating, just to get an acceptable cleanup plan. Although fully
engaged with this project for the entire 4 and V2 year period, I never saw this coming.
Had there been an inkling among any of us involved with the process, that in the end - this "Cover & Cap
Plan" would be EPA's preferred alternative for remedial action at the Shpack Superfund Site, we would
have had an opportunity to fight back and time to change the coarse of EPA's decision. Since December
1999, in the 4 & V2 year period of discussions with EPA, the Project Manager (who has been on this
Superfund Site since the beginning) never, ever, in our presence (prior to June 2004) uttered the word "cap".
While I would not be here tonight, if I thought it was too late to alter their coarse, obviously EPA has put
the Town of Norton at a tremendous disadvantage.
One of the criteria me US Environmental Protection must consider in their Record of Decision for cleanup
of Superfund sites is - "Community Acceptance". Let us all be perfectly clear on this critical point -
-------
August 4, 2004
Graf to EPA
Page 4 (Final Page)
The Town of Norton is united and steadfast in its opposition to the EPA's Preferred Alternative SC-2b,
which: does not meet the needs of the community now or in the future, does not provide a remedy, does not
allow reuse of the site for the community's intended use - passive recreation, does not have permanence (as
in a permanent solution), and places an unfair burden on the town, now and in the future.
The Town of Norton is united and steadfast in its declaration that alternative SC -3b is not only the
Preferred Alternative OF the town, it is the only acceptable alternative FOR the town.
Any alternative, which provides a level of cleanup lower than SC-3b will be unacceptable to the Town
of Norton.
We do expect EPA's final chosen plan of action, and Record of Decision to support Alternative SC -3b for
"Remedial Action" at the Shpack Superfund Site.
Should the US Environmental Protection Agency choose to ignore our reasonable demand -
Be it resolved - The Town of Norton will have DO reservations about appropriating the necessary
funds to take whatever legal action which may be required to secure the SC-3b REMEDY.
It is our obligation now to ensure that the Shpack Toxic Waste Dump is not left as a legacy to future
generations, and we will not be deterred.
Finally, if my state tax dollars are going to the Massachusetts Department of Environmental Protection,
To Support EPA's Proposed Plan -
I'm Not Going To Pay!
And if my federal tax dollars are going to the US Environmental Protection Agency
To Propose This Dumb Plan -
I'm Not Going To Pay!
Heather A. Graf
-------
July 1, 2004
Heather A. Graf, Coordinator
Citizens Advisory Shpack Team
229 N. Worcester St.
Norton, MA 02766
Ph. (508) 226-0898
FAX (508) 226-2835
Dave Lederer
US EPA, Region
11 Congress St., Suite 1100 (HBO)
Boston, MA 02114
Ph. (617)918-1325
FAX (617) 918-0325
Re: Public Comment Period for EPA's Proposed "Cleanup Plan for the Shpack Landfill Superfund Site"
Please consider this a formal request (in a timely fashion), on behalf of the Town of Norton - for a 30 day
extension of the Public Comment Period, on EPA's "Proposed Plan for the Shpack Landfill Superfund Site,
Norton, MA" dated June 2004.
Thirty days is not nearly enough time to review, digest and discuss: (1) The "Draft Final phase IB Remedial
Investigation Report" (Prepared by ERM, under contract with the "Shpack Steering Committee", AKA -
The PRP Group), dated June 17, 2004, (2) The "Draft Final Feasibility Study for the Shpack Landfill
Superfund Site" (Prepared by ERM, under contract with the "Shpack Steering Committee", AKA - The PRP
Group), dated June 17, 2004, (3) "The Baseline Human Health Risk Assessment" (Prepared by Metcalf &
Eddy, under contract with EPA), dated June 2004, and (4) The "Draft Baseline Ecological Risk
Assessment" (Prepared by Metcalf & Eddy, under contract with EPA), dated June 14, 2004.
Thirty days is certainly not enough time to formulate logical, intelligent, concise & coherent comments on
this plan, or the voluminous documents in support of EPA's Plan.
Assuming the original deadline for public comments was ("postmarked by") July 26, 2004, extending the
period another 30 days (60 day total) - should make the new deadline, as requested here - no earlier than
August 24, 2004.
This request sent by FAX, Thursday, July 1, 2004 at 4: 15 PM. Hard copy to follow.
Heather A. Graf
Cc: CAST Distribution List
-------
Richard Krumm
To', Dave Lederer/R'!/USEPA/US@@,ft]>3rf'4p/! Records Center
07/28/2004 06:01 PM
My dear Mr. Lederer,
Just whose environment are you supposed to be protecting? Certainly not the environment in Norton, where
you propose leaving a site that is badly contaminated for future residents to deal with.
How on earth can you in good conscience propose such a "solution" to this problem after promising for
years that your agency will clean up the site?
The citizens of Norton strongly oppose your proposed plan. Our elected representatives, both at the state
level as well as at the federal government level, also have expresessed their opposition.
You claim that you will take under advisement the will of the citizens in arriving at your decision.
I hope that you are sincere in that promise.
If so, I think you should reconsider your recommended plan and opt instead for your Alternative CS-3b.
Richard L. Krumm
-------
Heather A. Graf,
Coordinator Citizens Advisory Shpack Team
229 N. Worcester St.
Norton, MA 02766
Ph. (508) 226-0898
FAX (508) 226-283 5
To - Dave Lederer
US EPA
One Congress St., Suite 1100 (HBO)
Boston, MA 02114
Position Paper For The Citizens Advisory Shpack Team (CAST) Comments On the US Environmental
Protection Agency's "Proposed Plan For Cleanup Of The Shpack Landfill Superfund Site, June 2004"
Our position is clear. We are united and steadfast in our opposition to EPA's "Preferred Alternative -
SC-2b", which does not meet the needs of the community now, or in the future.
We are united and steadfast in our declaration that Alternative SC-3b is not only the Preferred Alternative
Of The Town of Norton, but the Only Acceptable Alternative For The Town of Norton.
Please make note under EPA's "Modifying Criteria" for approval of the cleanup plan - (that being)
"Community Acceptance", that EPA's Preferred Alternative SC-2b gets an "unsatisfactory rating".
We expect EPA's final chosen plan of action, and Record of Decision to support the modification requested
here - changing to Alternative SC-3b for "Remedial Action".
EPA's Preferred Alternative SC-2b does not provide a remedy, as promised by the Agency. (Ref. Numerous
documents - including meeting handouts etc., EPA's web page- New England Superfund Site, Shpack
Landfill, 8/31/00 - "Cleanup Approach, The site is being addressed in a long-term remedial phase focusing
on cleaning up the entire site." Remedy is understood to mean "the removal of evil, to make right, correct".
It is not intended to be a partial or temporary fix, but a total and permanent restoration of the property to a
safe condition for reuse.
Quote from EPA spokesman John Sebastian "The goal is to return the property to a safe enough condition
so that it can be used again". (Boston Globe, 8/11/91)
-------
CAST Position Paper
Comments to EPA
Page 2
The Shpack property is owned by "The Inhabitants of the Town of Norton, through its Conservation
Commission - for administration, control & maintenance as provided for in Section 8C of Chapter 40 of the
Massachusetts General Laws". (Ref. Deed signed June 1, 1981, transfer of property from Lea Shpack to the
Town of Norton). As such the land is designated as Open Space, intended for Passive Recreation.
The Ad hoc Shpack Committee, appointed by the Board of Selectmen, to work with the Army Corps of
Engineers, on Re-Use Scenarios for the Shpack Site (July 2002-Jan. 2003) selected the reuse option of
Passive Recreation, with the Army Corps' approval.
According to The Environmental Protection Agency's Directive - "Land Use in the CERCLA (Superfund)
Remedy Selection Process" 5/25/95 "The EPA believes that early community involvement, with a particular
focus on the community's future uses of property should result in a more democratic decision-making
process; greater community support for remedies selected as a result of this process; and more expedited,
cost-effective cleanups."
According to The Environmental Protection Agency's - "Reuse Assessment Guide", "The scope and level of
detail of the reuse assessment should be site-specific and tailored to the complexity of the site, the extent of
contamination... and the density of development in the vicinity of the site."
It should be noted here that there has been a tremendous increase in residential development on Maple St.
(at the rear of the Shpack site). And an increase is also anticipated on Union Rd., once the town water main
is extended.
"The Superfund land use Directive states that in cases where the future land use is relatively certain, the
remedial action objective(s) generally should reflect this land use."
"Reuse assessments should have greatest applicability to sites with waste materials on the surface and/or
contaminated soil."
"EPA is responsible for ensuring that reasonable assumptions regarding land use are considered in the
selection of a response action."
Workshops were conducted with the Army Corps, and the committee appointed to represent the Town of
Norton & City of Attleboro, to consider reuse scenarios for the property. The Project Manager for EPA
attended these 5 meetings, and was aware of Norton's intentions for future use of the site. Still, there was no
effort by EPA personnel to discuss with, or involve the community in "assumptions regarding land use" of
the site.
It was only after EPA announced their preferred alternative, June 23, 2004 (at the 14th public meeting, 4+
years after the first public meeting), that Norton officials & citizens realized the Environmental Protection
Agency was not factoring in to the selection of their "cleanup" plan - the community's intent for future use.
EPA's plan - which includes fencing off & securing the site to restrict access, institutional controls &
monitoring, with human health risk potential considered only for an adjacent resident and "trespassers",
made it clear that EPA had totally ignored the Town's intended reuse of the site (that being passive
recreation, within the Norton Conservation Commission's Open Space Plan).
-------
CAST Position Paper
Comments to EPA
Page 3
The Environmental Protection Agency's own standards for - "Selection of a Response Action" had been
absent from the EPA process in the assessment of the Shpack Site. (A process, which in its most recent
running with the public in Norton has taken 4 & 112 years).
Since December 1999, when representatives from EPA and the US Army Corps of Engineers came to
Norton, to discuss renewed investigations at the site, and at 13 public meetings from February 2000 to
November 2003, EPA gave the same presentation: The Army Corps would first excavate and dispose of
(off-site) all the radiological waste (uranium & radium), then the EPA, working with the "Possible
Responsible Party" (PRP) Group, under Superfund, would cleanup the remaining contaminants (chemicals
& heavy ' metals).
We understood cleanup to mean "removal (excavation and off-site disposal) of all contaminated materials
from the site that pose an unacceptable risk", not just the radiological waste, and some dioxin & PCB
contaminated soil. The EPA's preferred alternative does not accomplish this.
EPA's plan (after the Army Corps has removed the radiological waste), is to excavate only soil & sediment
that is close to the surface in a certain wetland area (even though EPA admits "the waste extends to 15 feet
below the water table in some wetland portions of the site"), to consolidate waste from the one wetland and
leave it in an upland area on site. EPA plans to remove only the soil that is contaminated with dioxin or
PCB for off-site disposal. The majority of the chemical & heavy metal contaminated soil (the responsibility
of EPA & PRP Group), in addition to that transferred from the wetlands to a central on-site location, would
be left in place, some portion of which would be covered over with a cap.
The only alternative acceptable to residents of the Town of Norton SC-3b would - "Remove all radiological
and chemically contaminated materials from the site that pose an unacceptable risk. As a result, alternative
SC-3 provides the greatest degree of overall protection." "Both chemical and radiological source materials
exceeding cleanup levels would be permanently removed from the site, thereby ensuring that this remedy
remains effective in the long-term." "SC-3 would greatly reduce the toxicity of the material that remains at
the site to acceptable levels. Because all soil and sediment above cleanup levels will be removed from the
property, both the volume and mobility of contamination is greatly eliminated".
EPA maintains that Norton's preferred alternative provides only "slightly greater protection at a
significantly greater cost". We counter that the opposite is true.
-------
CAST Position Paper
Comments to EPA
Page 4
The difference in cost (EPA's preferred alternative at $30 million & Norton's selected remedy at $50
million) is insignificant compared with the enormous disparity between the two plans. EPA's - "Capping
Alternative" = Contain & Cover.
The community's chosen remedy = Removal.
Considering the most expensive alternative in the Feasibility Study, rings in at $126 million, the plan
chosen by the Town of Norton is a compromise, already meeting EPA & the PRP Group halfway. It is also
not an unreasonable sum of money to expect for this project.
Along the way, we were reminded that the contract between the PRPs & EPA was for the investigative
phase only, no design or construction of remedial measures, and that negotiations for the actual cleanup
could take 1-2 years. Norton officials & citizens accepted this, expecting that the Environmental Protection
Agency's "high standards" would require an extensive cleanup, at a fairly high cost to the responsible
parties. Given the EPA's preferred alternative - actually the least expensive, easiest and quickest action, that
could be reasonably considered, the PRP Group should jump at it. Nowhere in the EPA's list of criteria for
approval of their cleanup plan, is - 'PRP Satisfaction'.
But it does appear that The Environmental Protection Agency is making PRP Satisfaction a top priority, and
placing the Town of Norton in the totally unexpected and extremely difficult position of having to be the
ones negotiating with the EPA, now at the eleventh hour.
The time frames, and impacts on the community, between the two alternatives being considered for the
EPA/PRP construction phase of the cleanup, are not that different. "Both are easily implementable." "The
personnel, equipment and materials required to implement each of these technologies are readily available".
Impacts to air quality and to local roads can be managed by good construction practices and working with
the community.
On this issue, we do request that EPA consult with Town Officials: the Board of Selectmen, Board of
Health, Norton Police Department and Norton Fire & Rescue, with regard to truck routes and times of
transport.
EPA's preferred alternative, which requires long-term monitoring of the still contaminated capped parcel -
by the PRP Group, is unacceptable, and could result in a permanent financial and regulatory burden for the
Town of Norton. While the town is given assurances that the PRP companies, entering into the consent
agreement with EPA, are financially stable at that time, there is no guarantee that will still be the case "long-
term".
Should those parties disappear from the corporate universe, or simply bail out on Shpack, the Town of
Norton (with the longest standing on the PRP list - as owners of the property) could be left holding the bag.
The other scenario, we are told could occur, is for the State to be left with the responsibility of Operation &
Maintenance of the site.
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CAST Position Paper
Comments to EPA
Page 5
It is irresponsible for the Environmental Protection Agency to maintain the Shpack Site can be secured with
fencing. Even though it has been on the EPA's National Priority List of Superfund sites since 1986, the
Consent Order was signed with the PRPs in 1990, and extensive investigative work was done on site by
ERM (under contract with the PRP Group) in 1993, neither EPA nor the PRPs were monitoring the site for
security, even though they knew the dangers posed to anyone who entered the property unprotected.
The old fence (put up in the 1980s) was busted through, the small green "No Trespassing" sign was falling
down (and hardly threatening even in its better days), a small person could slip through the chain-connected
gate, and the property could be entered from the ALI side. The Environmental protection Agency is fully
aware of the unsafe, unsecured state the Shpack Superfund Site was left in, for a period of at least ten year -
while supposedly on EPA's watch.
Beer cans, shot gun casings etc. provided evidence of trespassers onto the contaminated land, likely others
curious about an old dump site ventured there as well, individuals who had no idea what lay beneath them.
Under the EPA's plan, the Human Health Risk was calculated based on the adjacent resident entering the
property, and trespassers. The impacts on human health are dependent on many variables, including age of
the person, which is impossible to determine with "trespassers", or even adjacent resident, as that person, or
persons will undoubtedly change.
The 5-acre parcel of land, on which the Shpack residence sits, not including the house was valued at
$86,700 in the year 2000 (in spite of its location). Even if the house falls down, a family could build a new
home there - not inconceivable down the road, particularly with town water being supplied under EPA's
plan, and land at a premium in Norton.
The extension of the town water main to the end of Union Road, (Attleboro Line), also raises concerns over
increased development in the residentially zoned area near the site, which will expose more residents to
EPA's "accepted minimum risks" at Shpack. It will likely also bring an increased number of trespassers &
vandals, thereby increasing exposures, as well as maintenance and policing costs. The burden of monitoring
& ensuring security at the site will fall on the town. Additionally, and significantly - the Norton Fire
Department could be called upon, should an emergency (fire, explosion, personal injury etc.) occur on the
site.
Capped sites do present additional problems: with the buildup of gases beneath the liner, venting of gases -
which creates air pollution & odors, maintaining the security and efficient operation of the systems, the
noise associated with operations, as well as the threat of an explosion or fire.
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CAST Position Paper
Comments to EPA
Page 6
The residents of this area have already endured the hardships & health hazards associated with the capping
of ALI (Attleboro Landfill Inc.), which abuts the Shpack Site.
There is legitimate concern that flooding (particularly at this location, adjacent to Chartley Pond), erosion or
other natural occurrences, as well as man made factors, will cause deterioration of the cap. Even if we could
trust some entity, outside the town, to guarantee effective monitoring, operation & management of the site
for 30 years, what happens after that? Will Norton still be stuck with a mess that needs to be cleaned up, at
some unbearable cost to the town?
We did not invite or encourage this blight on our community. It is not our responsibility to clean up a mess
we had no part in making. But it is our problem (a problem many of us feel has had serious consequences,
and will continue to have - if not dealt with properly).
In response to the rationalization that "typically" all landfills are capped - The Shpack Site, if it is anything -
It is not typical. In fact, although residential & industrial waste was disposed of there (in order to fill a
wetland), the Shpack Superfund Site does not technically fit in the category of municipal landfills, and the
standards and regulations applied to those licensed facilities (like the neighboring ALI), should not be
assumed the rule for Shpack, which was in fact a privately owned & operated illegal dump.
Once the Shpack Site is properly cleaned up, we do expect a "cap" - that being a cover of clean soil and
grass, to return the land to as near a natural state, as possible.
EPA's scheduling of this critical part of the decision making process (the presentation of their cleanup plan,
the public comment period and the public hearing) - from the end of June through August, is unfortunate. It
was evident at die public meeting held June 23, 2004 in Norton (two days after school recessed), that
attendance and interest had diminished. This can be partially attributed to formerly interested parties - being
sick & tired of all things Shpack, or bored (after four years and thirteen public meetings - rehashing the
same old stuff). The decline in attendance for the end of June meeting can also be attributed to summer
vacations and other pleasant distractions, which occupy much of the public's time.
The Environmental Protection Agency's announcement of their proposed plan - June 23, 2004, and the
timing of the comment period & public hearing, is such that - (intentionally, or not), the EPA & PRP Group
can feel fairly confident that the number of commenters will be significantly lower, than at any other time of
the year.
-------
CAST Position Paper
Comments to EPA
Page 7 (Final Page)
In Conclusion: The US Environmental Protection Agency's Proposed Plan For The Cleanup of the Shpack
Superfund Site, 2004, their "Preferred Alternative SC-2b" (The Capping Alternative) - Is Unacceptable To
The Town Of Norton Because:
It does not adequately address the community's planned reuse of the site. It appears (contrary to the
Environmental Protection Agency's own stated policy), this was not a consideration by EPA in the selection
of their response action.
EPA's preferred alternative is not as effective in the long or the short term, as Norton's preferred alternative.
EPA's proposed plan does not provide a permanent solution.
The contaminants left on site pose an unacceptable level of residual risk.
EPA's preferred alternative leaves the Town of Norton with a still contaminated site.
The Town should not have to tolerate the stigma attached to a toxic waste Superfund Site any longer.
The EPA's proposed plan places an unfair burden on Norton's Police & Fire Departments.
It could also result in a permanent financial & regulatory burden on the Town.
The Norton Board of Health cannot support the EPA's preferred alternative, and strongly recommends
implementation of cleanup alternative SC-3b (Ref. Letter July 8, 2004)
The Norton Board of Selectmen voted to support EPA's alternative SC-3b (July 14, 2004 meeting).
The EPA's Proposed Plan is not considered to be a "Remedy".
It is our position that Norton's Preferred Alternative, SC-3b is a fair compromise, at a realistic cost to EPA
& the PRP Group. This alternative is easily implementable, with an acceptable time frame, to provide a
reasonable and permanent solution - to the decades old problem of the Shpack Superfund Site.
Finally, we hope the US Environmental Protection Agency is sincere when it says "YOUR OPINION
COUNTS!" "If you have comments regarding EPA's proposed cleanup plan for the site, we want to hear
from you before making a final decision."
Heather A. Graf
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Paul FarringUin, PE. Chairman
Frederick J, Watson, RS Clerk
Robert Curry, HealII; Agent
Gary Cuvino, Health Agenl
Phone; (SOS) 285-0263
Fax; " {508} 285-0269
Norma Napoleone, RN, C
Public Health Nurse
Board of Health
70 East Main Street Norton, MA 02 766
July 8, 2004
Re: Comments
Proposed Cleanup Plan
Shpack Landfill Superfund Site
Dave Lederer
U.S. EPA
1 Congress St, Suite 1100 (HBO)
Boston MA 02114
Dear Sir,
The Town of Norton Board of Health appreciates this opportunity to comment of the Proposed Cleanup Plan for the Shpack
Landfill Superfund Site
We cannot support any remediation alternative, which does not provide and overall protection of human health and the
environment. We are in general agreement, following the Public Information Meeting, that the two alternatives deserving further
consideration are SC-2 and SC-3 m their variations that provide protection to the Adjacent Resident without Groundwater
Consumption. That is SC-2B, the EPA s preferred alternative and SC-3B.
Both of these alternatives include installation of a waterline to two residences adjacent to the Superfund Site. Recent history has
shown that installation of a waterline in an area where development could occur has invited residential development. The Board
will not allow residential potable water wells in the area of the Superfund Site. However, we cannot deny, nor can the Water
Department, connection to a water main installed adjacent to a property. It has been noted that much of the open land along the
waterline routes is conservation land. But, we believe any developable land will be developed following the waterline installation.
We doubt that a restriction on connections would be enforceable and we have to agree with the Water Department policy of sizing
pipe installations for fire protection and future looping. So, any waterline installed will have capacity for development
We are concerned with the differences between the two alternatives in permanence of the solution and effectiveness in protecting
the recreational or occasional user of the site. The least protective of the two alternatives, SC-2B, consolidates waste is a new
landfill area, seals if off from normal activities and provides of monitoring and maintaining the new landfill. The Board presently
maintains and monitors a closed landfill It has been subject to trespass, vandalism and damage from natural causes. There is an
ongoing concern that, at some time in the future, the Board will be required to meet some new regulation, deal with some
previously undetected contaminant, or spend an inordinate sum dealing with bad laboratory data. These same ongoing
maintenance costs and concerns would apply to a new landfill on the Shpack Superfund Site.
While EPA can argue that the cost of all future maintenance and monitoring of the Shpack Superfund Site will the responsibility
of the PRPs, we are concerned that the Town of Norton is a PRP. The Town is the PRP with the longest history and will be around
after all the other PRPs disappear from the corporate universe. The Town cannot be sold off to another company and disperse its
liability. Most importantly, should the Town be left holding the proverbial bag as the last PRP somewhere in the distant future or
even as one or several PRPs at some point in time, the Commonwealth and Federal governments have control of funding to the
Town that could be used to coerce simple maintenance requirement or compliance for with some future regulatory requirement.
The lack of permanence in the EPA's preferred alternative will result in a permanent financial and regulatory burden for the Town
of Norton.
Page 1 of 2
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The Town of Norton Board of Health is concerned that the EPA's preferred alternative SC-2B is not as effective as the other
alternative, SC-3B, in the long term or short term. While it could be argued that the new landfill on the Superfund Site in
alternative SC-2B will result in better protection from the consolidated wastes and less risk than the existing condition, the
alternative will bring more people to the area of the site as development occurs along the water line. More residents living closer
to the site will increase the "recreational" use site and number of residents exposed to the EPA accepted minimal risks.
The increased development will also increase the number of potential trespassers and vandals entering what is supposed to be a
secured landfill area thereby increasing exposures as well as maintenance costs. This is not a result that would be peculiar to
Norton and we would expect that you have seen similar results in other locations where landfills have been consolidated in
residential areas.
The Norton Board of Health cannot support the EPA's preferred alternative and strongly recommends implementation of cleanup
alternative SC-3B - installation a water line and removal of all radiological and chemically contaminated materials that pose and
unacceptable risk.
The Norton Board of Health understands that there are potential impacts to the community from the implementation of the
preferred cleanup plan and possibly more significant impacts from the alternative we recommend. The impacts to air quality and
to local roads by truck traffic can be managed by good construction practices and working with the community.
The air quality of the areas surrounding the Shpack Landfill Superfund Site will not be derogated by any cleanup activities on the
site. Standard construction activities and strict monitoring can be specified and implemented to assure this. The Board of Health
may require that monitoring reports be provided to the Board and may require specific monitoring during cleanup operations.
Spillage from trucks leaving the site will not be acceptable and the roads in the area of the Shpack Landfill Superfund Site are
generally not in a condition to support long term truck operations. Again, standard construction activities and strict monitoring can
be specified and implemented to assure that materials are not carried off the site onto local roads and that transported materials are
not released from trucks. The Board recommends that rail transport using the nearby rail lines be considered and implemented if at
all possible.
Activities at the Shpack Landfill Superfund Site and the adjacent Attleboro Landfill will require removal of materials and the
import of cover materials. The Board recommends that rail transport using the nearby rail lines be considered and implemented if
at all possible. If rail transport cannot be implemented and the existing road network must be used, the Board recommends that all
parties involve, PRP, Corps of Engineers, Attleboro Landfill Inc , Mass DEP, EPA work to improve specific roadways to a
standard that will support the level of traffic needed. The Board will work with local public safety officials the other Town boards
to reduce the impacts of truck traffic on the Town of Norton and its residents during construction work at the Shpack Superfund
Site.
Respectfully submitted
Tnwn nf Nnrtnn Rn:irrl nf Ho:illh
Frederick J. Watson, R. S.
Clerk
CC: Town Manager
Board of Selectmen
CAST
Congressman - Barney Frank
Page 2 of 2
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Commonwealth of Massachusetts
Division of
Fisheries & Wildlife
MmssWiMtifc
Wayne F, MacCallum, Director
July 30, 2004
David O. Lederer
Remedial Project Manager
USEPA, Region 1
1 Congress Street, Suite 1100
Boston, MA 02114-2023
RE: Shpack Landfill Superfiind Site Remediation
Norton & Attleboro
NHESP File No. 03-11882
Dear David:
Thank you for providing the Natural Heritage & Endangered Species Program (NHESP) of the MA Division of
Fisheries and Wildlife with the Draft Final Phase IB Remedial Investigation Report for the Shpack Landfill Superfund
Site (dated 6/17/04), The NHESP would like to offer the following comments.
As indicated in the Shpack Landfill Habitat Assessment, the remediation site provides actual habitat for the
SpottedTurtle (Clemmys guttata), a state-protected rare species. In addition, the Marbled Salamander (Amhystoma
opacum) has been documented to occur in the vicinity of the proposed project site, and the site contains potential
habitat for this species. The Habitat Assessment also documents the presence of four vernal pools on the site.
Vernal pools provide important habitat for the Spotted Turtle and Marbled Salamander, and amphibians occurring
within vernal pools are a significant food source for the Spotted Turtle,
We request that any proposed remediation be designed to minimize impacts to the above-listed rare species and their
habitats, including vernal pools. In addition, a plan should be developed to restore rare species habitats once the
remediation is complete. The impact minimization and habitat restoration plan should be submitted to the NHESP
for review and approval prior to start of work. Finally, if they haven't done so already, we also request that
Environmental Resources Management submit Rare Animal Observation Forms and Vernal Pool Certification
Forms to the NHESP, in order to document their observations reported in the Habitat Assessment.
If you have any questions about this letter, please call Jon Regosin, Ph.D. at (508) 792-7270, ext. 316.
u). _
Thomas W, French, Ph.D.
Assistant Director
ce: David Buckley, DEP
Norton Conservation Commission
Attleboro Conservation Comrnisssion
Superi-oqd Hecoicis Center
SITE:
BREAK:
OTHER:
www, masswildlife. org
Division of Fisheries and Wildlife
Field Headquarters, One Rabbit Hill Road, Westborough, MA 01581 (508) 792-7270 Fax (508) 792-7275
An Agency of the Department of Fisheries, Wildlife A Environmental Law Enforcement
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TOWN OF NORTON
BOARD OF SELECTMEN , J „ , _ , „
StroerKmd Records Center
70 EAST MAIN STREET SITE: CK--
MUNICIPAL CENTER, NORTON, MASS. 027^6—
TELEPHONE (508) 285-0210 OTHER:
POSITION PAPER FOR THE TOWN OF NORTON
Comments on the U.S. Environmental Protection Agency's
Proposed Plan For Cleanup Of The Shpack Landfill Superfund Site. June 2004
On behalf ofits 18,000 residents, the Town of Norton Board of Selectmen hereby submits
its response to the EPA's Proposed Plan For Cleanup Of The Shpack Landfill Superfund
Site, as presented at the June 23, 2004, public meeting.
The position of the Board and the citizens of the Town is clear. We are united and
steadfast in our opposition to EPA's Preferred Alternative - SC-2b, which does not meet
the needs of the community now or in the future. We are united and steadfast in our
declaration that Alternative SC-3b is the only acceptable alternative for the Town of
Norton.
OWNERSHIP/LAND USE
The Shpack property is owned by the Town of Norton, through its Conservation
Commission, "for administration, control and maintenance as provided for in Section 8C of
Chapter 40 of the Massachusetts General Laws" (see deed signed June I, 1981, transfer of
property from Lea Shpack). As such, the land is designated as Open Space.
The Ad Hoc Shpack Committee, appointed by the Board of Selectmen to work with the
Army Corps of Engineers on reuse scenarios for the Shpack Site (July 2002 - January
2003), selected the reuse option of Passive Recreation, with the Army Corps' approval.
Those decisions are consistent with the Norton Conservation Commission's statutory
charge and underpin the Town's Alternative SC-3b position. The Environmental
Protection Agency's Directive Land Use in the CERCLA (Superfund) Remedy Selection ^
Process (5/25/95) states: w
3
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"The EPA believes that early community involvement, with a particular focus g»
on the community's future uses of property should result in a more democratic §
decision-making process; greater community support for remedies selected as
a result of this process; and more expedited, cost-effective cleanups." g
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-------
Further, the Environmental Protection Agency's Reuse Assessment Guide states:
"The scope and level of detail of the reuse assessment should be site-
specific and tailored to the complexity of the site, the extent of
contamination .., and the density of development in the vicinity of the
site."
"The Superfund land use Directive states that in cases where the future
land use is relatively certain, the remedial action objective(s) generally
should reflect this land use."
"EPA is responsible for ensuring that reasonable assumptions regarding
land use are considered in the selection of a response action."
EPA's current plan, which includes fencing off and securing the site, institutional controls
and monitoring, with human health risk potential considered only for an adjacent resident
and trespassers, clearly ignores the Town's intended reuse of the site, that being Passive
Recreation within the Norton Conservation Commission's Open Space Plan.
CLEANUP
~ Since December, 1999, when representatives from EPA and the U.S. Army Corps of
Engineers came to Norton to discuss renewed investigations at the site, and at 13 public
meetings from February, 2000, to November, 2003, EPA gave the same presentation. The
Army Corps of Engineers would first excavate and dispose of off-site all the radiological
waste, including uranium and radium, then the EPA, working with the "Possible
Responsible Party" (PRP) Group, under Superfund, would clean up the remaining chemical
and heavy metal contaminants.
We understood "clean up" to mean excavation and off-site disposal of all contaminated
materials from the site that pose an unacceptable risk, not just the radiological waste, some
dioxin and PCB contaminated soil.
The EPA's preferred alternative does not accomplish this.
After the Army Corps has removed the radiological waste, the EPA's plan is to excavate
only soil and sediment that is close to the surface in a certain wetland area, even though the
waste extends to 15 feet below the water table in some wetland portions of the site, to
consolidate this waste, and leave it in an upland area on site. Outside of the wetland area,
EPA plans to remove only the soil that is contaminated with dioxin or PCBs for off-site
disposal. The majority of the chemical and heavy metal contaminated soil (the
responsibility of the EPA and PRP Group), and the aforementioned wetlands excavation
would be transferred to an on-site location and be capped.
-------
The only alternative acceptable to the Town of Norton, SC-3b would:
"Remove all radiological and chemically contaminated materials from the
site that pose an unacceptable risk. As a result, alternative SC-3 provides
the greatest degree of overall protection "
"Both chemical and radiological source materials exceeding cleanup levels
would be permanently removed from the site, thereby ensuring that this
remedy remains effective in the long term "
"SC-3 would greatly reduce the toxicity of the material that remains at the
site to acceptable levels. Because all soil and sediment above cleanup levels
will be removed from the property, both the volume and mobility of
contamination is greatly eliminated."
EPA maintains that Norton's Preferred Alternative provides only "slightly greater
protection at a significantly greater cost". We counter that the opposite is true. The
difference in cost is insignificant compared with the enormous disparity between the two
plans. EPA's strategy is to contain and cover, the community's chosen remedy is removal.
EPA's Preferred Alternative cost is approximately $29 million, The most expensive
alternative considered under their Feasibility Study exceeds $126 million. At $55 million,
the plan chosen by the Town of Norton is a compromise, already meeting EPA and the
PRP Group halfway. It is not an unreasonable demand given the true magnitude of this
problem.
The time frames and impacts on the community, between the two alternatives being
considered for the EPA/PRP construction phase of the clean up, are not that different.
"Both are easily implementable." "The personnel, equipment, and materials required to
implement each of these technologies are readily available," Impacts to air quality and to
local roads can be managed by good construction practices- and working with the
community.
POST CLEANUP
EPA's Preferred Alternative, which requires long-term monitoring of the still
contaminated, capped parcel by the PRP Group, is unacceptable and could result in a
permanent financial and regulatory burden for the Town of Norton. While the Town is
given assurances that the PRP companies entering into the Consent Agreement are now
financially stable, there is no guarantee that will hold true in the future.
-------
Should those parties disappear from the corporate universe or simply bail out on Shpack,
the Town of Norton, with the longest standing on the PRP list as owner of the property,
could be left holding the bag. It is also possible that the State would be left with the
responsibility of operation and maintenance of the site.
It is naive for the Environmental Protection Agency to believe that the Shpack Site can be
secured with fencing. Over the last decade, neither EPA nor the PRPs have monitored the
site for security, even though they knew the dangers posed to anyone who entered the
¦ property unprotected. Fences are broken, "no trespassing" signs are faded or have fallen,
and beer cans, shot gun casings, etc., provide evidence of trespassers onto the contaminated
land, likely others curious about an old dump site ventured there as well, individuals who
had no idea what lay beneath them.
Under the EPA's plan, the Human Health Risk was calculated based on the adjacent
resident entering the property and trespassers. The impacts on human health are dependent
on many variables, including age of the person, which is impossible to determine with
trespassers or the adjacent resident, as that person, or persons, will undoubtedly change.
> The extension of Norton's water main to the end of Union Road at the Attleboro city line
raises concerns over new development in the residentially zoned area near the site, which
will expose more residents to EPA's "accepted minimum risks" at Shpack. Redevelopment
of the 5-acre parcel of land on which the Shpack residence is situated is also likely.
In response to the rationalization that "typically" all landfills are capped, the Shpack site, if
it is anything, is not typical. In fact, although residential and industrial waste were
disposed of there in order to fill a wetland, the Shpack Superfund Site does not technically
fit in the category of municipal landfills, and the standards and regulations applied to those
licensed facilities (like the neighboring Attleboro Landfill, Inc.) should not be assumed the
rule for Shpack, which was in fact a privately owned and operated illegal dump.
Once the Shpack Site is properly cleaned up, we do expect a cap, that being a cover of
clean soil and grass, to return the land to as near a natural state as possible
PROCESS
EPA's scheduling of this critical part of the process (the presentation of its clean up plan,
the public comment period, and the public hearing) from the end of June through August is
unfortunate. Attendance at the public meeting of June 23, 2004, in Norton was very low
compared to past meetings. The low turnout can be attributed to summertime vacations
and other pleasant distractions which preoccupy much of the public. However, neither the
EPA nor the PRP Group should underestimate Norton's resolve: We will exhaust all
regulatory, political, and legal means possible to effect the SC-3b solution.
-------
CONCLUSIONS
The U.S. Environmental Protection Agency's Proposed Plan For The Cleanup of the
Shpack Superfund Site, 2004, its Preferred Alternative SC-2b (The Capping Alternative) is
unacceptable to the Town of Norton because:
It does not adequately address the community's planned reuse of the site, now or in the
fiiture. It appears in fact that, contrary to the Agency's own stated policy, this was not a
consideration in the selection of its response action.
EPA's Preferred Alternative is not as effective, in the long term or the short term, as
Norton's Preferred Alternative.
EPA's proposed plan does not provide a permanent solution to our environmental
concerns.
EPA's Preferred Alternative leaves the Town of Norton with a still contaminated site and a
consequentially unacceptable level of residual risk.
The Town should not have to tolerate the stigma attached to a toxic waste Superfund Site
any longer.
SC-2b results in a permanent financial and regulatory burden on the Town.
The EPA's Proposed Plan is not considered to be a "Remedy",
It is the Board of Selectmen's position that Norton's Preferred Alternative SC-3b is a fair
compromise, at a realistic cost to EPA and the PRP Group, with an acceptable time frame
that provides a reasonable solution to the decades-old problem of the Shpack Superfund
Site.
Respectfully submitted,
NORTON BOARD OF SELECTMEN
Robert W. Kimball, Jr., Chairman
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AAflNgY FRANK
Aw District, Massachusetts
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New Burano, MA 02740
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29 BfiOAOWAV
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Taunton, MA 02780
IS08S 822-4796
August 4, 2004
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Robert W. Vamcy, Regional Administrator
Environmental Protection Agency
One Congress Street
Boston, MA 02114
Dear Mr. Varney:
I would like to submit the following comments conveying my strong support for
the town of Norton and its preferred cleanup idtemative known as SC-3B for the
collection and removal of both chemical and radiological contaminants at the Shpack
Superfund Site. As you are aware, the Shpack landfill has the distinction of being both a
Supcrfund Site under the cleanup authority of the Environmental Protection Agency
(EPA) and a Formerly Utilized Site Remedial Action Program (FUSRAP) site under the
cleanup authority of the Army Corps of Engineers (ACOE). The final decision on a
cleanup alternative has caused an understandable amount of worry for the citizens of
Norton. They are not only concerned about the actual cleanup of Shpack, but the long
term public safety and reuse potential of a fifty year old dump site that has soil
contaminated with radiological, chemical and heavy metal wastes.
The legislation, authorizing the radiological cleanup of Shpack through FUSRAP
was originated by Congressman McGovem and me to ensure that a responsible and
permanent remediation of harmful radioactive waste would occur. This authorizing
legislation was passed by Congress in 2002 and the federal government, through the
ACOE, is now responsible for a significant amount of the final clean up cost outlined in
the EPA's proposed plan.
The ACOE recently agreed to work under the EPA's Record of Decision and is
scheduled to commence work on the collection and removal of more than 13,000 cubic
yards of radiological waste as early as 2005. The town of Norton has asked that the EPA
oversee the removal of collected chemical waste to a level that would provide a true
passive recreational use. However, the EPA's preferred alternative for cleanup, or SC-2B,
provides only a limited removal of chemical material and would cap most contaminants
on site. The subsequent fencing, monitoring, and trespass restrictions resulting from such
an option would require a level of perpetual oversight that is both impractical and
difficult, if not impossible, to enforce over a long period of time. Town officials have
raised legitimate concerns that they might ultimately be responsible for this type of
management.
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August 4,2004
Page 2
Obviously, the EPA has given significant consideration to the cost of each
cleanup option in choosing a preferred alternative. The agency's preferred option is one
of the least expensive. The town's request is not only the safest solution, but a financially
sensible one that is comparatively reasonable when one looks at the variety and level of
contamination on site. It is also far less expensive than other costly alternatives that were
considered.
For more than four years, 1 have hosted and/or participated in many meetings with
r the EPA, ACOE, state officials, and local officials at various times to facilitate the
lengthy process that has brought us to where we are today, i.e., making final decisions on
cleanup proposals for use in a Record of Decision. The town, which has a voice in a final
removal determination through the EPA's Community Acceptance component, should be
protected through the best option under Superfund. No one person or agency can say with
absolute certainty that with the passage of time the integrity of capped materials would
not become compromised through a variety of potential degradations, natural or man
made.
Again, the government is making a significant financial commitment to the
FUSRAP portion of this project under a cleanup that involves the removal of collected
radiological material. Also, the ACOE plans on removing more material than those
options being considered by the EPA which should further reduce the costs associated
with the chemical cleanup as commingled contaminants, chemical and radiological, are
not only collected, but removed by the ACOE.
The citizens of Norton have every right to expect the EPA will oversee the
collection and removal of the chemical and heavy metal wastes at the Shpack site with
the cost shared among those companies already identified with the responsibility of its
cleanup. Therefore, I urge EPA's approval of SC-3B to provide a comprehensive cleanup
arid removal of both chemical and radiological contaminants and afford the greatest level
of protection possible to the people and their surrounding environment.
Sincerely,
BARNEY FRANK
Member of Congress
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MICHAEL J. COPPOLA
FIRST BRISTOL DISTRICT
P.O. BOX 346
FOXBOROUGH MA 02035
(508) 543 3138
0mm£mw€k
HOUSE OF REPRESENTATIVES
STATE HOUSE, BOSTON 02133-1054
Suvve-rfund sificw'jlii Center
SITE: SJ/£^cK
BHM 'f V- C* 4 Committees
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Housing and Urbsn Development
PubNe Salety
STATE HOUSE ROOM 542
(817 ) 722-2488
Rep.MichasiCoopolaahou state ma us
Legislative Aidp
LAUREN BARNES
July 30, 2004
Mr. David Lederer
U.S. Environmental Protection Agency-
One Congress Street, Suite 1100 (HBO)
Boston, MA 02114
RE: Shpack Landfill Superfund Site, Norton, MA
Dear Mr. Lederer:
We write in response to the U.S. Environmental Protection Agency's (EPA)
proposal to clean up the contamination of the Shpack Landfill Superfund site in the
Town of Norton.
After reading information about the various cleanup alternatives, as well as
attending public meetings on this issue, we strongly oppose the EPA's proposal known
as option SC-2B, at an estimated cost of $30 million. We believe option SC-3B is a better,
more permanent solution to rid the landfill, and the surrounding residential area, of
hazardous pollutants, at an estimated cost of $55 million.
To spend $30 million on a partial clean-up (option SC-2B) is money poorly spent
and requires long-term monitoring and a perpetual restriction on access. However,
option SC-3B is a complete clean-up of contaminants and a total and permanent o
restoration of the former landfill, requiring minimal monitoring and no access £
restrictions. a
D
The wishes of the Town of Norton for the future use of the property - passive §
recreation - have been totally ignored. An additional issue of great concern is the §
possibility, at some time in the future, that the Town of Norton and the Commonwealth w
of Massachusetts could be held responsible for the operation, monitoring and A
Printer! an Rnc.yctnct Prtpor
-------
Mr. David Lederer
July 30,2004
Page 2
maintenance of the site. The possibility of these costs, at some point in the future,
would far surpass the SC-3B option.
Our position, as legislators for the Town of Norton, is clear. We stand united
with the Citizens Advisory Shpack Team in our opposition to the EPA's "Preferred
Alternative SC-2B.
We truly hope you will take the concerns of the town and its residents into
consideration and choose option SC-3B as the preferred clean-up plan for the Shpack
Landfill Superfund site.
Thank you for your attention to this important matter.
Very truly yours,
ETH A. POIRIER
State Representative
State Representative
-------
Mr, Dave Lederer e
U.S.E.P.A. ^uperairi-J <•:•¦—v'-i Center
1 Congress St. Suite 1100 (HBO) SITE:
Boston, MA 02114 £ f.; 'J\ J<; yt
CinCrj--
Re: Shpack Landfill Superfund Site - Formal Comment on the proposed-Rl/F-S-
Dear Mr. Lederer,
As a concerned citizen of Attleboro, MA, 1 am writing to support EPA's proposed plan
to remediate the Shpack Landfill Superfund site using the EPA proposed clean up
scenario (SC-2B). I believe this provides the necessary protection for the environment,
the town and the citizens who live there. In fact 1 believe the risk of a total material
removal (option SC-3B, C or D) would in fact result in a higher risk to town citizens
because of the required additional excavation activities and material transport issue
through the town.
Thank you for allowing me the opportunity to provide you with formal comments
regarding the Shpack Landfill RI/FS proposal.
Sincerely,
{X^fLU>-trw KYV"P\
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Superfur.d Records Center
Mr. Dave Lederer
U.S.E.P.A.
1 Congress St. Suite 1100 (HBO)
Boston, MA 02114
BEl:.AK: _
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-------
Leanne & Stevens Cobb
166 Plain Street
Norton, MA 02766
MR, Dave Lederer
U.S.E.P.A.
1 Congress St. Suite 1100 (HBO)
Boston, MA 02114
Re: Shpack Landfill Superfiind Site - Formal Comment on the proposed RI/FS
Dear Mr. Lederer,
"Think globally, act locally". Important words to environmentally concerned
organizations. As a concerned citizen of Norton, MA, I too live by these words but I use
them in a much different context than most other "environmentalists" would. I am writing
in SUPPORT of EPA's proposed plan to remediate the Shpack Landfill Superfiind site
using the proposed SC-2B clean up scenario.
I interpret this saying "think globally, act locally" to mean that: global
environmental problems must be addressed, and to accomplish that goal, they should be
addressed by whatever means are available at a local level. In the case of the Shpack
landfill, removing the radioactive waste and constructing a suitable "engineered landfill
cap" with long term monitoring provisions, meets that need,
It would appear to me that exposure (therefore risk) is at it's lowest by leaving the
material where it is! If it is excavated as proposed by alternative SC-3A, B, C and D there
is a possibility for exposure during excavation activities. It then must be transported
through our town (more exposure possibilities), and transported hundreds (maybe even
thousands) of additional miles, with many opportunities for exposing more citizens of the
country during that activity. Finally, the material would be placed in another landfill
(exposing workers and potentially any community surrounding that landfill) and covered
with an "engineered landfill cap". The additional opportunities for exposure do not make
sense AND the material will be protected exactly the same (and therefore apparently
result in the same risk) at this proposed, remote, final disposal location, as it would be if
it were left in the ground at the Shpack landfill. Again, "think globally, act
locally".
The companies that PAID to have that waste disposed of at Shpack in a completely
lawful manner 30 to 40 years ago, did nothing wrong. The town benefited by having a
local, low cost landfill for disposal of its trash. And in its early life, the landfill was
actually on the tax rolls of the town as a privately owned landfill, which benefited the
town. Times change. Science now tells us this is not the optimum way to dispose of these
types of waste. The total material removal scenario (SC -3A, B, C and D), I suspect,
f -rrfun?? ••¦Sa Center
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BRCAK: _ __
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-------
would encounter opposition at the remote landfill site from a local 'Concerned Citizens'
group near that landfill, BUT that group has no voice in the Shpack clean up process.
They will be concerned about their increased risk from this new waste being brought to
their Town by the removal and again does nothing to support the "think globally, act
locally** philosophy. The other proposed alternatives do nothing to support this
philosophy, either.
Thank you for allowing me the opportunity to provide you with formal comments
regarding die Shpack Landfill RI/FS proposal.
Sincerely,
-------
TEKINIOR APEX COMPANY
July 7, 2004
Superfund Records Center
SITE:
BF:\ '¦ V
\
Mr. Dave Lederer
USE.PA
1 Congress St. Suite 1100 (HBO)
Boston, MA 02114 - 2023
Re: Shpack Landfill Superfund Site - Formal Comment on the proposed RI/FS
Dear Mr Lederer,
As a recipient of a "Potentially Interested Party" letter regarding the Shpack
Landfill clean up proposals, Teknor Apex would like to respond to the recently
published RI/FS. Teknor Apex Company is writing in support of EPA's
proposed plan to remediate the Shpack Landfill using proposed clean up
scenario (SC-2B). This proposal reduces risk to acceptable levels for all
reasonable foreseeable uses. Additionally, given the fact that the proposal to cap
the former landfill site is in agreement with past EPA decisions regarding iandfill
clean ups, continuing that methodology makes sense from all points of view.
Thank you for the opportunity to provide you with formal comments regarding the
Shpack Landfill RI/FS proposal.
Dc
Director ot Keguiatory Affairs
cc: file
505 CENTRAL AVENUE • PAWTUCKET, RHODE ISLAND 02861-1900
TELEPHONE: (401) 725-8000 • FAX: (401) 725-8095 ¦ WWW.teknorapex.com
Sincerely
-------
Mr. Dave Lederer
U.S.E.P.A.
1 Congress St. Suite 1100 (HBO)
Boston, MA 02114
Superfunjj Records v. ¦siuei
SITE:..
BREAi<
OTHER; _
Re: Shpack Landfill Superfund Site - Formal Comment on the proposed RI/FS
Dear Mr. Lederer,
As a concerned citizen of Attleboro, MA, I am writing to support EPA's proposed plan
to remediate the Shpack Landfill Superfund site using the EPA proposed clean up
scenario (SC-2B). I believe this provides the necessary protection for the environment,
the town and the citizens who live there. In fact 1 believe the risk of a total material
removal (option SC-3B, C or D) would in fact result in a higher risk to town citizens
because of the required additional excavation activities and material transport issue
through the town.
Thank you for allowing me the opportunity to provide you with formal comments
regarding the Shpack Landfill RI/FS proposal.
Sincerely,
^9
-------
Superfund Records Center
SITE:
Mr, Dave Lederer
U.S.E.PA
1 Congress St. Suite 1100 (HBO)
BREAK;
OTHER:
Boston, MA 02114
Re: Shpack Landfill Superfund Site - Formal Comment on the proposed RI/FS
Dear Mr, Lederer,
As a concerned citizen of Attleboro, MA, 1 am writing to support EPA's proposed plan
to remediate the Shpack Landfill Superfund site using the EPA proposed clean up
scenario (SC-2B). 1 believe this provides the necessary protection for the environment,
the town and the citizens who live there. In fact 1 believe the risk of a total material
removal (option SC-3B, C or D) would in fact result in a higher risk to town citizens
because of the required additional excavation activities and material transport issue
through the town.
Thank you for allowing me the opportunity to provide you with formal comments
regarding the Shpack Landfill RI/FS proposal,
Sincerely,
-------
michart@onebox.com
08/10/2004 09:41 PM
I live at 13 Shelly Road in Norton and would like to offer my comments about
the Shpack cleanup.
How are area residents protected if you remove the contaminated soils? For
example, in the removal process, how are procedures in place so that disturbed
particles of soil do not get distributed in our area while in transit?
Is the water supply beyond the site affected now, and will it be affected
during the cleanup? How can we feel confident as patrons of the businesses
around the site, ie. the Chartley Store, the Creamery, the Rainbow Kids Day
Care? I have to admit that I am hesitant to shop at those businesses and
decided not to put my daughter into the Rainbow Day Care because I was
concerned about their water.
1 support 23B because of the statement that it is the "most effective".
Michelle
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87/22/2004 10:33 508285B490
HASKINS PHARMACY
PAGE 01
W1
Comments to The US EPA on the June 2004 Proposed Plan For the Cleanup of
The Shpack Superfund Site, Norton/Attleboro, MA
Records Center
To Dave Lederer 'WE* "' /£"r' " ' 7
U.S. epa prfav" "
One Congress St., Suite 1100 (HBO)
Boston, MA 02114 OTHER: , _
Deadline - Postmarked By Wednesday, August 25, 2004
FAX (617) 918 - 129!, No Later Than Wednesday, August 25,2004
August 2004
I am writing to express my firm opposition to the EPA's proposed plan for the 'cleanup'
of the Shpack Superfund Site.
EPA's preferred alternative (SC-2b) is unacceptable for reasons too numerous to detail
here. Most objectionable is the fact this option does not provide "permanence" and is
therefore not a "remedy". It would leave the Town of Norton with a still contaminated
site, and the responsibility ic burdens of dealing with it, in the near and distant future,
In the face of the promise the Environmental Protection Agency made to the town,
EPA's chosen course of action, is reprehensible.
If community acceptance, plays any role in the EPA's decision making process for the
cleanup of Shpack, please give serious consideration to these comments, and select
Alternative SC-3b, which will at long last, give residents of this community the peace of
mind they deserve.
Signature
Print Name
Address
foix. m. s
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JUL-23-04 FRI 08:12 AH ECI-H0LBR00K
FAX NO. 781 607 5792
P, 01/01
Comments to The US EPA on the June 2004 Proposed Plan For the Cleanup of
The Shpack Superfund Site, Norton/Attleboro, MA
Deadline - Postmarked By Wednesday, August 25,2004 OfHUi:
FAX (617)918 - 1291, No Later Than Wednesday, August 25,2004
August 2004
I am writing to express my firm opposition to the EPA's proposed plan for the 'cleanup'
of the Shpack Superfund Site,
EPA's preferred alternative (SC-2b) is unacceptable for reasons too numerous to detail
here. Most objectionable is the fact this option does not provide "permanence" and is
therefore not a "remedy5'. It would leave the Town of Norton with a still contaminated
site, and the responsibility & burdens of dealing with it, in the near and distant future.
In the face of the promise the Environmental Protection Agency made to the town,
IPA's chosen course of action, is reprehensible.
If community acceptance, plays any role in the EPA's decision making process for the
cleanup of Shpack, please give serious consideration to these comments, and select
Alternative SC-3b, which will at long last, give residents of this community the peace of
mind they deserve.
To Dave Lederer
U.S. UFA
One Congress St., Suite 1100 (HBO)
Boston, MA 02114
Superfund Records Center
Signature
Print Name
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Address
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-------
JUL-^-04 HUN 12: bl Pfl EC I-HOLBROOK
FAX NO. 781 607 5792
P. 01/01
Comments to The US EPA on the June 2004 Proposed Plan For the Cleanup of
The Shpack Superfimd Site, Norton/Attlcboro, MA
To Dave Lederer e / j r- , 0
U S £Pa bupernmd (vBcoras Center
One Congress St., Suite 1100 (HBO) SITE:
Boston, MA 02114 BREAK:
Deadline - Postmarked By Wednesday, August 25,2004 C^'^'PR'
FAX (617) 918- 1291, No Later Than Wednesday, August 25,2004
August 2004
1 am writing to express my firm opposition to the EPA's proposed plan for the 'cleanup*
of the Shpack Superfund Site.
EPA's preferred alternative (SC-2b) is unacceptable for reasons too numerous to detail
here. Most objectionable is the fact this option does not provide "permanence" and is
therefore not a <4remedy". It would leave the Town of Norton with a still contaminated
site, and the responsibility & burdens of dealing with it, in the near and distant future.
In the face of the promise the Environmental Protection Agency made to the town,
EPA's chosen course of action, is reprehensible.
If community acceptance, plays any role in the EPA's decision making process for the
cleanup of Shpack, please give serious consideration to these comments, and select
Alternative SC-3b, which will at long last, give residents of this community the peace of
mind they deserve.
Signature
Print Name
Sr€xj&>j CT AtLCKj'n
Address
•f
T>°uj b (Lr>
(So St
mA
-------
JUL-27-04 TUE 01:28 PH ELECTRICAL CONTROLS
FAX NO. 781 607 5701
P, 01
Superhind Records Center
SITE; r:fc
Comments to The US liPA on the June 2004 Proposed Plan For of it 7 ~
The Shpack Superftuid Site, Noiton/Attleboro, MA ~
OThiJR:
To Dave Lcdcrcr
U.S. BPA
One Congress St., Suite 1100 (HBO)
Boston, MA 02114
Deadline - Postmarked By Wednesday, August 25, 2004
I AX (63 7) 918 - 1291, No Later Than Wednesday, August 25,2004
August 2004
I nm writing to express my firm opposition to the EPA's proposed plan for the 'cleanup'
of the Shpnck Superfund Site.
EPA's preferred alternative (SC-2b) is unacceptable for reasons too numerous to detail
here. Most objectionable is the fact this option does not provide "permanence" and is
therefore not a "remedy". It would leave the Town of Norton with a still contaminated
site, and the responsibility & burdens of dealing with it, in the near and distant future.
In the fuce of the promise the Environmental Protection Agency made to the town,
HPA's chosen course of action, is reprehensible,
If community acceptance, plays any role in the EPA's decision making process for the
clenriup of Shpack, please give serious consideration to these comments, and select
Alternative SC-3b, which will at long last, give residents of this community the peace of
mind they deserve.
S mixture
Name.
A- flu yVo <0/U ^ /^n
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JUL-28-04 MED 09:20 AM ECI-HQLBRQOK
FAX NO. 78! 60? 5792
P, 01/02
Comments to The US EPA on the June 2004 Proposed Plan Fo&ha3@id»iupiojn e c • > rds Center
The Shpack Supcrfund Site, Norton/Attleboro, MA
CMTI?.
Oil i_;.
BFW.AK:
OTHER:
To Dave Lederer
U.S. EPA
One Congress St., Suite 1100 (HBO)
Boston, MA 02114
Deadline - Postmarked By Wednesday, August 25,2004
FAX (617) 918 - 1291, No Later Than Wednesday, August 25,2004
Mi>l
L
August 2004
I am writing to express my firm opposition to the EPA's proposed plan for the 'cleanup'
of the Shpack Superfund Site.
EPA's preferred alternative (SC-2b) is unacceptable for reasons too numerous to detail
here. Most objectionable is the fact this option does not provide "permanence" and is
therefore not a "remedy''. It would leave the Town of Norton with a still contaminated
site, and the responsibility & burdens of dealing with it, in the near and distant future.
In the face of the promise the Environmental Protection Agency made to the town,
EPA's chosen course of action, is reprehensible,
If community acceptance, plays any role in the EPA's decision making process for the
cleanup of Shpack, please give serious consideration to these comments, and select
Alternative SC-3b, which will at long last, give residents of this community the peace of
mind they deserve.
Signatar^/\A./l$SZX^J, /
7^
Print
I) kit) d .jjdjfbu
Address
(j'1 4-nyf-(ivibt)irt\
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JUL-28-34 WED 09:20 AH ECI-HOLBROOK
FAX NO, 781 607 5792
P, 02/02
Siroerfvmci Records Center
Comments to The US EPA on the June 2004 Proposed Plan For th^T&Mp.M.
Hie Shpack Superfund Site, Norton/Attleboro, MA BREAK: 41,.yL
T ~ f j OTHER;
To Dave Lederer —
U.S. EPA
One Congress St., Suite 1100 (HBO)
Boston, MA 02114
Deadline - Postmarked By Wednesday, August 25,2004
FAX (617)918- 1291, No Later Than Wednesday, August 25,2004
August 2004
I am writing to express my firm opposition to the EPA's proposed plan for the 'cleanup'
of the Shpack Superfuod Site,
EPA's preferred alternative (SC-2b) is unacceptable for reasons too numerous to detail
here. Most objectionable is the fact this option does not provide "permanence" and is
therefore not a "remedy3'. It would leave the Town of Norton with a still contaminated
site, and the responsibility & burdens of dealing with it, in the near and distant future.
In the face of the promise the Environmental Protection Agency made to the town,
EPA's chosen course of action, is reprehensible.
If community acceptance, plays any role in the EPA's decision making process for the
cleanup of Shpack, please give serious consideration to these comments, and select
Alternative SC-3b, which will at long last, give residents of this community the peace of
mind they deserve.
Print Name £oe '
Address GTj -fi )U^'i ^ ~i^i/crl
I^(a QZ/pl
-------
FROM : RMfilnc
PHONE NO. : 14014665408
Jul. 28 2004 06:3?PM PI
Superfund. Iiecords Center
Comments to The US EPA on the June 2004 Proposed Plan For tl^^iianupLof
The Shpack Superfund Site, Norton/Attleboro, MA BREAK; _ -5
OTHER: ~
To Dave Lederer
U.S. EPA
One Congress St., Suite 1100 (HBO)
Boston, MA 02114
Deadline - Postmarked By Wednesday, August 25, 2004
FAX (617) 918 - 1291, No Later Than Wednesday, August 25,2004
r
August 2004
I am writing to express my firm opposition to the EPA's proposed plan for the 'cleanup'
of the Shpack Superfund Site. ,
EPA's preferred alternative (SC-2b) is unacceptable for reasons too numerous to detail
here. Most objectionable is the faci this option does not provide "permanence" and is
therefore not a "remedy". It would leave the Town of Norton with a still contaminated
site, and the responsibility & burdens of dealing with it, in the near and distant future.
In the face of the promise the Environmental Protection Agency made to the town,
EPA's chosen course of action, is reprehensible.
If community acceptance, plays any role in the EPA's decision making process for the
cleanup of Shpack, please give serious consideration to these comments, and select
Alternative SC-3b, which will at long last, give residents of this community the peace of
mind they deserve.
Siena'
£ 0
Print
NametU.IJ G t i A A. gjfe.T.
Address
k. Al QJ-X-ol
-------
JUL-29-04 THU 04:16 Ptl TOWN OF NORTON
FAX HO. 506285029?
Comments to The US EPA on the June 2004 Proposed Plan For Records Center
The Shpack Superfuad Site, Norton/Attleboro, MA SITE: 'Mffji r':J\
To Dave Lederer BREAK: ' J_
U.S. EPA CTHEH:
One Congress St., Suite 1100 (HBO)
Boston, MA 021 ] 4
Deadline - Postmarked By Wednesday, August 25,2004
FAX (617) 918 - 1291, No loiter Than Wednesday, August 25, 2004
August 2004
I am writing to express my firm opposition to the EPA's proposed plan for the 'cleanup'
of the Shpack Superfund Site.
EPA's preferred alternative (SC-2b) is unacceptable for reasons too numerous to detail
here. Most objectionable is the fact this option does not provide "permanence" and is
therefore not a "remedy". It would leave the Town of Norton with a still contaminated
site, and the responsibility & burdens of dealing with it, in the near and distant future.
In the face of the promise the Environmental Protection Agency made to the town,
EPA's chosen course of action, is reprehensible.
If community acceptance, plays any role in the EPA's decision making process for the
cleanup of Shpack, please give serious consideration to these comments, and select
Alternative SC-3b, which will at long last, give residents of this community the peace of
mind they deserve.
Signature
Print Name
-ArJhlt. La&\ S'
Address
-------
AUG-3-2004 07:34P FROMJ
TO:16179181291
P: 1' i
Comments to The US EPA on the June 2004 Proposed Plan For the Cleanup of
The Shpack Supcrfund Site, Norton/Atllcboro, MA Superfund Records Center
SITE:... :::W/he4
To Dave Ledercr p-r „,,
U.S. EPA bK' "iiv
One* Congress St., Suite 1100 (HBO) OTHER:
Boston, MA 02114
Deadline - Postmarked By Wednesday, August 25, 2004
FAX (617) 918 - 1291, No Later Than Wednesday, August 25,2004
August 2004
I am writing to express ray tirrn opposition to the EPA's proposed plan for the 'cleanup'
of the Shpack Supcrfund Site.
EJ'A's preferred alternative (SC-2b) is unacceptable for reasons too numerous to detail
here. Most objectionable is the fact this option does not provide "permanence" and is
therefore not a "remedy". It would leave the Town of Norton with a still contaminated
site, and the responsibility & burdens of dealing with it, in the near and distant future.
In the face of the promise the Environmental Protection Agency made to the town,
EPA's chosen course of action, is reprehensible.
If community acceptance, plays any role in the EPA's decision making process for the
cleanup of Slipaek. please give serious consideration to these comments, and select
Alternative SC-3b, which will at long last, give residents of this community the peace of
mind they deserve.
Signature
Print Name J T~7^"
III iiiiwM* ,,,
Address ST
/O.
o-ft-f CiS
-------
08/08/2004 07:17 5082229128
THOMAS CANNINNG
PAGE 01
Comments to The US EPA on the June 2004 Proposed Plan For the Cleanup of
The Shpack Superfund Site, Norton/Attleboro, MA _ ^
r buperfund necords Center
To Dave Lederer SITE; ^
U.S. EPA BRE/iK;
One Congress St., Suite 1100 (HBO)
Boston, MA 02114 OlHU,:
Deadline - Postmarked By Wednesday, August 25,2004
FAX (617) 918 - 1291, No Later Than Wednesday, August 25,2004
August 2004
I am writing to express my firm opposition to the EPA's proposed plan for the 'cleanup'
of the Shpack Superfund Site.
EPA's preferred alternative (SC-2b) is unacceptable for reasons too numerous to detail
here. Most objectionable is the fact this option does not provide "permanence" and is
therefore not a "remedy". It would leave the Town of Norton with a still contaminated
site, and the responsibility & burdens of dealing with it, in the near and distant future.
In the face of the promise the Environmental Protection Agency made to the town,
EPA's chosen course of action, is reprehensible.
If community acceptance, plays any role in the EPA's decision making process for the
cleanup of Shpack, please give serious consideration to these comments, and select
Alternative SC-3b, which will at long last, give residents of this community the peace of
mind they deserve.
Signature
7}
Print Name I Q»v\ i
a n A , n
Address
Co^-t )4n^e S~f
fl)nr-4ofy Mft.
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Aug. v. 2CG4 5:06PM PAYTM PAYROLL SERVICES, INC
No • 053? P. 1
Comments to The US EPA on the June 2004 Proposed Plan For the Cleanup of
The Shpaek Superfund Site, Norton/Attleboro, MA
Boston, MA 02114
Deadline - Postmarked By Wednesday, August 25,2004
_ FAX (617)918- 1291, No Later Than Wednesday, August 25, 2004
August 2004
1 am writing to express my firm opposition to the EPA's proposed plan for the 'cleanup'
of the Shpaek Superfund Site.
EPA's preferred alternative (SC-2b) is unacceptable for reasons too numerous to detail
here. Most objectionable is the fact this option does not provide "permanence" and is
therefore not a "remedy". It would leave the Town of Norton with a still contaminated
site, and the responsibility & burdens of dealing with it, in the near and distant future.
In the face of the promise the Environmental Protection Agency made to the town,
EPA's chosen course of action, is reprehensible.
If community acceptance, plays any role in the EPA's decision making process for the
cleanup of Shpaek, please give serious consideration to these comments, and select
Alternative SC-3b, which will at long last, give residents of this community the peace of
mind they deserve.
To Dave Lederer
U.S. EPA
One Congress St., Suite 1100 (HBO)
Superfund Records Center
Signature
Print Name
U)
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3
(/l
Address
flidtnOAjoLsOn
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Aug. iijU &: UiHM HAY I KAK FAYKOLL UtKV! Ctb* - INC
No-0535 P. 1
Comments to The US EPA on the June 2004 Proposed Plan For the Cleanup of
The Shpack Superfund Site, Norton/Attleboro, MA
To Dave Lederer Superfund Records Center
U.S. EPA SIT'"' „'/// /£'- f/";"
One Congress St., Suite 1100 (HBO) ^
Boston, MA 02114 EItllAX;_ " ¦
Deadline - Postmarked By Wednesday, August 25, 2004 OTHER:
FAX (617) 918 - 1291, No Later Than Wednesday, August 25,2004
/
August 2004
I am writing to express my firm opposition to the EPA's proposed plan for the 'cleanup'
of the Shpack Superfund Site.
EPA's preferred alternative (SC-2b) is unacceptable for reasons too numerous to detail
here. Most objectionable is the fact this option does not provide "permanence" and is
therefore not a "remedy". It would leave the Town of Norton with a still contaminated
site, and the responsibility & burdens of dealing with it, in the near and distant future.
In the face of the promise the Environmental Protection Agency made to the town,
EPA's chosen course of action, is reprehensible.
If community acceptance, plays any role in the EPA's decision making process for the
cleanup of Shpack, please give serious consideration to these comments, and select
Alternative SC-3b, which will at long last, give residents of this community the peace of
mind they deserve
Signature
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Print Name t~L<£
Address
/vojZ-rt/O &1/3- OX766
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Aus. 10. 2004 3:56AM PAYTRAK PAYROLL SERVICES. [NC
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Comments to The US EPA on the June 2004 Proposed'Plan For
The Shpack Superfund Site, Norton/Attleboro, MA
the Cleanup of
r
To Dave Lederer
U.S. EPA
One Congress St., Suite 1100 (HBO)
Boston, MA 02114
Deadline - Postmarked By Wednesday, August 25, 2004
FAX (617) 918 - 1291, No Later Than Wednesday, August 25,2004
August 2004
I am writing to express my firm opposition to the EPA's proposed plan for the 'cleanup'
of the Shpack Superfund Site,
EPA's preferred alternative (SC-2b) is unacceptable for reasons too numerous to detail
here. Most objectionable is the fact this option does not provide "permanence" and is
therefore not a "remedy". It would leave the Town of Norton with a still contaminated
site, and the responsibility & burdens of dealing with it, in the near and distant future.
In the face of the promise the Environmental Protection Agency made to the town,
EPA's chosen course of action, is reprehensible.
If community acceptance, plays any role in the EPA's decision making process for the
cleanup of Shpack, please give serious consideration to these comments, and select
Alternative SC-3b, which will at long last, give residents of this community the peace of
mind they deserve
Signature
Signature
Print Name Mfc e //¦ PaiZ/e^
Address 7A iS/'
—
A>or-hn, A? A a a
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August 10, 2004
Conservation Commission
70 East Main Street
Norton, ma 02766-2320
(508) 285-0275
Fax (508) 285-0277
David Lederer
US EPA
One Congress Street, Suite 1100 (HBO)
Boston MA 02114
Dear Mr. Lederer,
The Conservation Commission lias reviewed the "Draft Final Feasibility Study, Shpack
Superfund Site, Norton/Attleboro MA" as well as the "Draft Final Phase IB Remedial
Investigation Report" dated June 17, 2004 prepared by ERM, the Shpack Steering
Committee's consultant. The Conservation Commission voted at its regular meeting of
August 9, 2004 to strongly support the option SC-3B for the clean up of the Shpack. Any
option less than SC-3B will not result in an acceptable clean up level. Option SC-3B
allows the Town of Norton to utilize the property for passive recreation after the clean up
while the SC-2 options do not. Option SC-3B also allows for a full restoration of the
spotted turtle (Special Concern on the Massachusetts Endangered Species List) habitat
and vernal pools while the SC-2B options are highly likely to result in a "taking** of rare
species habitat.
During the recent investigations, it has been documented that the Attleboro landfill (ALI)
is not functioning properly and contaminants from ALI are entering the Shpack site. The
Town of Norton is not confident that the proposed capping in the SC-2 option will result
in an acceptable level of dean up. The necessary repairs to the ALI cap must be m
immediately addressed and adequately to cease to pollute the Norton site. The ALI site §
ceased in being a "separate issue" with the acknowledgement of ALFs contamination of £
the Shpack site. The Town of Norton will not accept a capping solution when the |
adjacent cap has failed and there has not been sufficient action to repair it. Option SC-3B °
wBI be the only option for the Town of Norton. a
8
M
The SC-2 options list an Operation and Maintenance (O & M) component. It is unclear g
whom the responsible party for the O & M will be. The feasibility study does not give the 5
Town of Norton any assurances that the Shpack O & M will be better implemented than
the ALI O & M. It is unclear whom will be responsible for funding the O & M. It will be
-------
fiscally irresponsible to approve a plan that requires the Town of Norton to maintain a
parcel of land that cannot be utilized for public uses. Option SC-3B eliminates the need
for future maintenance of a capped site and is the only suitable option for the town.
In reviewing the Feasibility Study it is clear that several items do not include adequate
detailed information. These items must be required in the Record of Decision. The
Conservation Commission respectfully requests that the following items be included as
requirements in the Record of Decision.
1. The venial pool and spotted turtle habitat appear to be grossly overlooked in the
feasibility reports despite conversations regarding the potential negative impacts the
clean up actions could have on the ability of the wetlarid and buffer zone to provide
such habitat The rare species survey should specifically focus on the spotted turtle,
potential for the vernal pools to provide significant wildlife habitat for the spotted
turtle ami marbled salamander and should evaluate the habitat for any other rare
species that may be found on the Shpack site. The Rare Animal Observation Forms
and the Vernal Pool Certification Forms for all vernal pools should be completed and
submitted to the Mass Natural Heritage and Endangered Species Program (NHESP)
as requested by NHESP in their letter of July 30, 2004 (enclosed). The Conservation
Commission should be involved in all evaluations and any Conservation Permit
applications required by NHESP.
2. The wetland replication and restoration must comply with the Wetland Protection Act
Regulations 3t0CMRl0.55 and 310CMR10.59. The wetland replication/restoration
must include at a minimum, detailed plans illustrating all existing and proposed
contour elevations; soil profiles for imported soils; a construction schedule; a planting
plan including the number, size and species of all plants, groundwater elevations;
description of the replicated wetland functions and values; physical features that
replicate the vernal pool habitat and rare species habitat functions of the existing
wetlands including coarse woody debris, snags and pit and mound topography; and a
5-year monitoring plan. The Record of Decision must specifically state that the
wetland replication/restoration should commence in the first growing season of the
construction activity and should not be left as the last aspect of the clean up or the
Town of Norton should receive a cash bond to ensure that the wetland replication/
restoration will actually be accomplished according to the Regulations. The
Conservation Commission should be consulted for the appropriateness of the
proposed replication/restoration projects, have the opportunity to provide comments
on the plans and have the ability to conduct site inspections.
3. Options for dewatering the wetland areas must be evaluated. The Conservation
Commission should be consulted and be able to provide comments for all options of
dewatering.
4. A transportation and emergency spill contingency plan must be required in the
Record of Decision. All materials proposed for removal to off-site facilities will be
transported past Chartley Swamp, Chartley Pond and over the recently renovated
-------
Chartley Pond Dam. The plan, at a minimum, must map the transportation routes,
identify all wetland resource areas along the transportation routes, list the emergency
spill materials to be stored on each truck in the event of a spill, a contact phone list in
the event of a spill, and available funds for the immediate purchase of materials
necessary to deal with a spill. The Conservation Commission should be able to
provide comments on any such plan.
5. Any proposal to extend a water line down Union Road must file the appropriate
permit applications under the Wetland Protection Act and Regulations. The
Conservation Commission feds that the extension of the water line would require a
separate permit under the Wetland Protection Act and the Record of Decision should
specifically require a Notice of Intent be filed with the Conservation Commission for
this portion of the proposed Shpack clean up. The water line extension must include
at a minimum, detailed plans of the water line, elevations and inverts, all wetland
resource areas, dewatering methods and the options for installing the water line at the
railroad crossing.
6. The ALI cap must be repaired.
7. The Conservation Commission manages the Shpack property for passive recreation
and wildlife habitat uses consistent with the Conservation Commission Act, MGL,
Chapter 40, Section 8C. Therefore, the Conservation Commission should be
consulted on the deed restriction language. The Shpack Future Use Committee should
also be consulted and be able to provide comments.
8. A plan should be created to prevent access of motorized vehicles onto the Shpack
site. Motorized vehicle use is not consistent with the Conservation Commission Act
and must be addressed in the future use plan.
The Conservation Commission reiterates their desire for Option SC-3b as the most
appropriate clean up option for the Shpack Superfund site. If you have any questions
please do not hesitate to contact me. Thank you.
Sincerely,
Jennifer Carlino
Conservation Agent
CC; Congressman Barney Frank
Senator Jo Ann Sprague
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Representative Coppola
Representative Poirier
Representative Travis
Heather Graf, CAST
James P. Purcell, Norton Town Manager
Tom French, MA NHESP
Ken Munney, US F& W
David Buckley, MA DEP
Ed Tanner, Attleboro Conservation Commission
Francis Veale, Texas Instruments
-------
Jonathan O'Reilly
29 Union Road
Norton, Massachusetts 02766
1 IJifcC*
August 24, 2004
Dave Lederer
US. EPA
One Congress Street
Suite 1100 (HBO)
Boston, MA 02114
I am writing to express my firm opposition to the EPA's proposed pian for
the 'clean-up' of the Shpack Superfund site.
EPA's preferred alternative (SC-2b) is unacceptable for reasons too
numerous to detail here. Most objectionable is the fact this option does not
provide "permanence" and is therefore not a "remedy." It would leave the
Town of Norton with a still contaminated site, and the responsibility and
burdens of dealing with it, in the near and distant future. In the face of the
promise the Environmental Protection Agency made to the town, EPA's
chosen course of action, is reprehensible.
If community acceptance plays any role in the EPA's decision making process
for the clean-up of Schpack, please give serious consideration to these
comments and select Alternative SC-3b, which will at long last, give
residents of this community the peace of mind they deserve.
Yours truly,
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NORTON FIRE RESCUE
CHIEF
GEORGE F. BURGESS
j it a:
rn.cK
August 24, 2004
U~ o.-
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Mr. David Lederer
United States EPA
One Congress St., Suite 1100 (HBO)
Boston, MA 02114
RE: Comment on Shpaek Superfund Site
The site on Union Road is referred to as a landfill, but it must be remembered that it is
really a dump in that there was no regulatory oversight. It operated as a pre-regulation
dump where known and unknown waste was dumped randomly and obviously
commingled.
Over the years the fire department responded to and extinguished fires of various types
including rubbish and brush. It was not known during those years of operation, or
subsequent years, what was handled there. When our personnel were working fires on the
site (or anywhere else for that matter) they were coming in contact with solid materials,
dust, products of smoke, etc. They have inhaled, ingested, and absorbed the results of this
activity. From the start of the operation of the site until and after its closing, Norton
firefighters have had and/or died from various types of cancer. Obviously we have no
way of knowing for sure what was the cause or contributing factor in those cancers. The
point is we did not know.
The proposed remedy by your agency, alternative SC-2b, is to remove some types of
contaminants and stockpile others. A cap would be installed and monitored. In future
years visitors, trespassers, and the fire department will not be aware of any hazard, and
certainly will not know if the cap has deteriorated, or functioning properly. Ground water
contamination will not, and really cannot, be detected until contamination occurs. Future
generations will not know, just as the fire department did not know of any hazards
The towns preferred plan of action, alternative 3b, would serve the future generations of
residents in a permanent way. I see little benefit short term, and no permanent benefit as
release and/or contamination is possible by "condensing" contaminated material on site.
The fire department officially supports the board of selectmen and the advisory
committee in selecting alternative 3b.
70 E. Main Street • Norton, MA 02766
508-285-0249 * Fax; 508-285-9633
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August 24, 2004
Mr. David Lederer
Page 2 of2
The town had no regulatory authority in the beginning of the use of the site, and is really
involved by taking over the site in response to the contamination found more than twenty
years ago. To now put the town in a position to have to live with contamination on site
and possible future health and financial risks is unnecessary.
Thank you for the opportunity to comment on this issue.
Deputy Fire Chief
Copy: Advisory Committee
File
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NORTON FIRE RESCUE
CHIEF
GEORGE r. BURGESS
Dave Lederer
August 24, 2004
U.S. E.P.AA
One Congress St., Suite 1100 (HBO)
Boston, MA 02114
Dear Mr. Lederer,
I am writing this letter to express my strong opposition to the proposed cleanup plan for the
Shpack super fund site. I have attended many a classroom session as well as many committee meetings
as a representative of the Norton Fire/Rescue Department. While I realize there is a time and place for
"capping" of material, the Shpack site is not one of them. If you are already excavating the material,
there is no legitimate justification for not removing the material from the site. 1 say legitimate, because
the added cost to do this job "right" when factored over future generations is not a justifiable factor.
The E.P.A.'s proposal to use Alternative SC-2b should be abandoned for Alternative SC-3h. This true
"long term" cleanup proposal, will provide the Town with the minimal level of cleanup that will
guarantee that future generations need not "re-visit" the Shpack site.
As a member of the Ad Hoc advisory committee appointed by the Selectman, we discussed
many different "use" scenarios. We discussed at many of the sessions, the scenario referred to as the
"residential farmer scenario". We decided not to push for this scenario because of the huge cost and
logistics in making it happen. It was a "Major" concession on the Town's part. Alternative SC-3b is
the best alternative for all parties involved. It prevents the need for future concerns on the PRP's part
as well as the Town's part.
For the record, I have spent most of my life growing up in Chartley and own a considerable
piece of property in the Chartley section of Town. I want to see my future generations be able to enjoy
the Chartley pond area without fear of health risks associated with contaminants "capped" in place. I
hope you will do what is right for the future generations of this Town and scrap Alternative SC-2b for,
at the minimum, Alternative SC-3h. While this level of cleanup doesn't truly restore the property to
its "pristine" state, or allow the use of water from on site, it does offer a truly permanent solution.
Smcerelv
Paul J. Schleicher
Lieutenant
70 E. Main Street • riorton, MA 02766
508-285-0249 • Fax: 508-285-9633
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Janet O'Reilly
29 Union Road
Norton, Massachusetts 02766
August 24. 2004
Dave Lederer
U.S. EPA
One Congress Street
Suite 1100 (HBO)
Boston, MA 02114
I am writing to express my firm opposition to the EPA's proposed plan for
the 'clean-up' of the Shpack Superfund site.
EPA's preferred alternative (SC-2b) is unacceptable for reasons too
numerous to detail here. Most objectionable is the fact this option does not
provide "permanence" and is therefore not a "remedy." It would leave the
Town of Norton with a still contaminated site, and the responsibility and
burdens of dealing with it, in the near and distant future. In the face of the
promise the Environmental Protection Agency made to the town, EPA's
chosen course of action, is reprehensible.
If community acceptance plays any role in the EPA's decision making process
for the clean-up of Schpack, please give serious consideration to these
comments and select Alternative SC-3b, which will at long last; give
residents of this community the peace of mind they deserve.
Yours truly,
-------
NORTON FIRE RESCUE
CHIEF
GEORGE f. BURGESS
Dave Lederer
U.S. E.P.AA
One Congress St., Suite 1100 (HBO)
Boston, MA 02114
August 24,2004
Dear Mr. Lederer,
1 am writing this letter not just as the Town of Norton's Fire Chief throughout this whole
Shpack affair, but also as a life long resident of Chartley. I am totally opposed to the E.P.A.'s
proposed plan to handle the cleanup of the Shpack property. To think that you, as a government
agency, would even think of just "sweeping the contaminants under the carpet" as a long term solution
to an ongoing nightmare is ludicrous at best. The E.P.A's preferred alternative (SC-2b) is not a
permanent solution to the problems at the Shpack superfund site.
The minimum proposal that should be considered for the site is Alternative SC-3b. which will
give a level of cleanup that the Town can feel comfortable with for generations to come. Even a t this
level of cleanup, the site is still not back to "virgin territory". The Town has made concessions in not
going for the "residential farmer" scenario which would cost over twice what SC-3b will cost. When
you look at the cost difference between the E.P.A's proposed plan and the plan acceptable to the Town,
the cost difference, when amortized over time, is minimal at best.
I want to go on record as being strongly opposed to the plan SC-2b and hope that you will do
what is right and just for the Town of Norton in cleaning the site to the SC-3b alternative.
Sincerely,
~
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70 E. Main Street * Morton, MA 02766
508-285-0249 • Fax: 508-285-9633
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NORTON POLICE DEPARTMENT
82 EAST MAIN STREET
NORTON, MASSACHUSETTS 02766
BRUCE R, FINCH, JR. ADMINISTRATIVE (508) 285-3300
CHIEF OF POLICE ADMINISTRATIVE FAX (508) 285-3337
PATROL FAX (508) 285-3338
DETECTIVE FAX (508) 285-3339
TO: DAVE LEDERER
FROM: LIEUTENANT STANLEY J. WALASAVAGE
DATE: 08/20/2004
RE: SHPACK SUPERFUND SITE
Dear Mr. Lederer.
The Norton Massachusetts Poliee Department recently became aware of clean up work
to be done at the Shpaek Superfund Site located on Union Road in Norton. This clean up
and future security of the property is apparently different than what had been originally
proposed. Please be advised that this agency is small in size, numbering approximately
27 officers. As you can imagine, we are constantly under pressure to stay within budget
restrictions. Officers do routinely patrol the area of the clean up but because of the remote
location and lack of calls into the area, this area may not have the number of officers
patrolling as would other high crime areas. If this department becomes burdened with
having to patrol and maintain a security presence at the site, we would quickly deplete
our budget and in all likelihood not be able to provide officers. I am still unclear on how
the clean up will affect public safety, but assuredly the Police Department would become
over-burdened and under-funded if asked to maintain a police presence.
Respectfully Submitted,
Lt. Stanley J. Walasavage ^
Norton Police Department
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Town of Norton
Emergency Management Agency
22 August 2004
David Lederer,
US EPA ^ U
One Congress Street, Suite i 100 (HBO) " /
Boston, NA 02114
Comments on the US EPA's "Proposed Plan For Cleanup of the Shpack Superfund Site,
June 2004
These comments are to express my firm opposition to EPA's plan for the
'cleanup' of the Shpack Superfund Site,
The Boston College Weston Observatory, analysis of earthquakes that occurred
between 1989 and 1998, there is a "66%" chance that the next earthquake of
magnitude 2.7 or greater will occur in one of the shaded zones shown on the map that
was released after the study, Norton lies within a shaded zone in southeastern
Massachusetts. This area of New England has been classified a "red" zone for possible
serious earthquake for many years. While the fault line may be deep - no one can
predict when one will occur. Thus, in the interest of safety all the mixed up waste of
radiological contaminants and carcinogenic chemical wastes, volatile and inorganic
compounds, as well as the heavy metals must be removal from this illegal dumpsite.
Staying with Alternative SC-3b of the "Feasibility Study" for the Shpack Site will
ensure that when the earthquake does occur Norton will not have to be concerned of
the Impact of an otherwise contaminated site.
EPA's preferred alternative (SC-2b) is unacceptable for other reasons to
numerous to detail here. The fact this option does not provide "permanence" and
cannot be a "remedy" can cause other problems than the earthquake alone. SC-2b
would leave the Town of Norton with a still contaminated site and the financial and
physical burdens and responsibility of dealing with it Remembering the promise the
Environmental Protection Agency made to the Town, EPA's chosen course of action, is
culpable.
If community acceptance, plays any role in the EPA's decision making process for
the cleanup of Shpack, please give serious thought to these comments, and select
Alternative SC-3b, which will finally, give the residents of this community the peace of
mind they merit
Director, NEMA
258 Plain Street
Norton, MA 02766
508.285.4454
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Plan sweeps
it all under
the bed
When I was a kid, my mother would
send my brother and me upstairs to clean
our room. This was not our favorite activ-
ity.
We would go up and perform our own
version of "cleaning." Primarily, this in-
volved shoving as much stuff under our
beds as we could fit.
When we were done, the room looked
pretty good. The floor would be free of
clutter, no dim laundry would be visible,
and unless my mother took the time to ac-
tually bend down and look under the bed
(which unfortunately she often did) it ap-
peared we had done our job and solved the
problem.
Little did the two of us know then that
our actions might wel! be preparing us for
a glorious career in the EPA. (Environ-
AN INSIDE LOOK
BILL GOUVEIA
mental Protection Agency.) Apparently
the people charged with protecting our
environment, and through that our health
and safety, also grew up shoving stuff
under the bed.
How else can you explain the EPA's
proposal for cleaning up Norton's Super-
fund site, the Shpack property near the
Attleboro landfill? The EPA has proposed
to mitigate the problem of hazardous ma-
terial located on the Norton site by pretty
much sweeping the stutf under the bed
and leaving it there. And they propose to
spend about $20 million to do it.
The Shpack property is a parcel of land
adjoining the Attleboro Landfill off Union
Road near the Attleboro border. It was
contaminated with radioactive materials in
the 1950's, dumped diere by a company
that eventually became Texas Instru-
ments.
Norton took ownership of die site in the
early 1980's in hopes of removing obsta-
cles to the cleanup of the property and
getting it on the national Superfund list.
The property was placed on the Super-
fund list in 1986.
Since that time, the wheels of bureau-
cracy have been grinding in agoru zingly
slow motion, There have been studies,
tests, hearings, proposals and reports, |t
has been more than 20 years of slow
progress, federal foot-dragging, and ex-
treme patience by local residents and
abutters, 3
After all that, the EPA has suggested the
life-threatening materials buried on the
property merely be covered up. Greatly
simplified, they want to cap the materials
and throw a nice cover over it. If their pro-
posal is adopted and instituted, the Shpack
property will look beautiful upon comple-
tion. You would never know there was a
problem there.
Sort of like how my room looked clean
when my mother would poke her head in.
But Mom didn't let us get away with that.
She knew that, sooner or later, that stuff
we shoved under the bed would be a prob-
lem. She knew that just because it coukln'-t
be seen and couldn't be smelled today,
after a while things would change.
"You're just making more work for
yourselves when you do this," she would
lecture to us patiently. "You might as well
do it right the first time and save your-
selves a lot of time and trouble."
Mom was right back then, and Norton's
federal, state and local officials — along
with a wonderful group of concerned citi-
zens — are right today. Like Mom, they
don't want the stuff under the bed — or in
this case under the ground — to come
back and cause Norton problems in the
future. They know the only way to solve
the problem is to do the clean up right.
The EPA should immediately abandon
their proposal to simply sweep contami-
nants on the Shpack site under the bed
and lull us into a false sense of security. It
is their job to solve the problem, not
merely cover it up. While the cost m dol-
lars to do this may be double the cost oi
merely hiding it, the cost in quality of life
for Norton citizens could be considerably
higher should they not.
In the meantime, I believe the mothers
of these EPA officials should come testify
at die next public hearing, I want to know
just what it looks like under their beds,
and how comfortably they sleep at night.
Bill Gouveia is a columnist for the Norton
Mirror. lie can be reached at AnlmideLmk®
aal.com.
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August 25, 2004
5 Goldenwood Dr.
Norton, MA 02766
Dave Lederer
U.S. EPA
1 Congress St., Suite 1100 (HBO)
Boston, MA 02114
RE: Shpack Landfill Superfund Site, Norton, MA
Dear Mr. Lederer,
After carefully reviewing the Feasibility Study performed in regards to the Shpack
Landfill, along with the EPA's Proposed Plan and our attendance at the town meeting
held on August 4, 2004, we are writing to express opposition to the EPA's proposed plan
SC-2B. Although this plan does remove the radiological contaminants along with dioxin
and PCB contaminated sediment, the remainder of the chemicals will be left on site under
a cap. While the cap would be impermeable, groundwater may still come into contact
with contaminants, Due to the close proximity of many Norton residents, this is
concerning. The worry about safety may result in a diminished interest to live in the area
which will result in hardship on the town. Additionally, it would not be a permanent long
term fix. Based on the utilization of caps at other landfills, it seems that the longevity of
caps is questionable. We feel that the EPA's plan which includes the ongoing monitoring
of the groundwater proves that this is true.
99 ^
We support the alternative plan SC-3B as it proposes to remove radiological and
chemical waste, thereby providing a permanent solution. A permanent solution is needed
to ensure the safety of current and future residents.
The EPA states in the Proposed Plan that both plans are easily implementable and
technologies for both plans are readily available. Although a cap may be cost beneficial
at this time, a cost will remain for water and site monitoring. In the long run we believe
that the benefits of a complete site clean up under SC-3B greatly outweighs the potential
savings of plan SC-2B.
Respectfully Yours,
Charles and Katie Magri
w
O
3
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Ronald O'Reilly
29 Union Road
Norton, Massachusetts 02766
August 24, 2004
U.S. EPA
Mr. Dave Lederer
1 Congress Street, Suite 1100 (HBO)
Boston, MA 02114
Dear Sirs:
I am writing to express my opposition to the Environmental Protection Agency's (EPA)
"Proposed Plan" (The Plan) for the clean-up of the Shpack Landfill Superfund Site (SLSS) in
Norton, Massachusetts. EPA proposes a limited clean-up and capping of the SLSS identified as
alternative SC-2B.
Judicial Intent:
EPA is using criteria for the SLSS clean-up that apply to landfills. This approach is a procedural
error and is contrary to judicial intent when Title 42, Chapter 82 was passed by Congress. The
Shpack Dump operated for over twenty-five (25) years. The Shpack site was operated as an
unregulated dump and was never in compliance with the regulations promulgated under Title
42, Chapter 82, Sub-chapter IV, Section 6945.
The legislative intent to treat landfills and dumps differently is obvious in the way the legislation
was written. Title 42, Chapter 82, Sub-chapter IV, Section 6944 prescribes the criteria for
sanitary landfills. Section 6945 of the aforementioned promulgates the criteria for closing open
dumps. Section 6945 differentiates dumps from landfills. The judicial intent is that landfills and
dumps are different and requires that they be treated differently,
EPA's approach to the clean-up of SLSS is an erroneous attempt to treat a dump as though it is
a landfill which is contrary to the judicial intent of Title 42, Chapter 82, Sub-chapter IV, Sections
6944 and 6945.
w
DEP's Inability to Enforce Its Regulations: §
tn
EPA's proposed limited clean-up of the site is based on the erroneous assumption that the °
engineering and execution of the work wilt be performed flawlessly. The history of the adjacent 3
Attleboro Landfill, Inc. (ALI) shows these assumptions to be based on fiction. ALI was capped
beginning in 1996. Eight years later, the Massachusetts Department of Environmental 8
Protection (DEP) is attempting to correct the work that has taken place under its supervision. y
The capping of ALI is an example of the inability of regulatory agencies such as DEP and EPA £
to control such a complex engineering feat. ^
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U.S. EPA
Mr. Dave Lederer
August 24, 2004
Page 2
The capping plan for ALI was approved by DEP two years after capping commenced. During
the capping, there was an explosion and fire that burned over an acre of the membrane. DEP,
The Norton and Attleboro Fire Departments were not aware of the explosion and fire until I
notified them a week after it happened. I waited a week to see if DEP would notice the incident
during DEP's scheduled weekly visits. DEP either failed to visit the site weekly or missed a one-
acre hole in the membrane.
After the capping was completed, DEP became aware that the slopes were too steep to prevent
erosion. The slopes were too close to the street to control water run off and the applicant failed
to post the required bond to insure the site would be properly maintained.
All of the aforementioned deficiencies occurred while the capping was being closely monitored
by DEP or were missed in DEP's review of the capping plan. The personnel ranks of DEP have
been drastically reduced over the past five years. DEP is currently staffed to respond to
emergencies only. The department does not have sufficient, qualified and experienced staff to
monitor the capping and continue to inspect the cap in the future. More importantly, the failure
of DEP to enforce its regulations at AL! is proof that the DEP is not competent to perform the
same task at SLSS.
The serious deficiencies of the ALI capping are not a matter of conjecture. Plans are currently
being prepared to reopen the ALI cap to correct the aforementioned deficiencies. DEP is
negotiating with a third party to allow the site to be reopened as a landfill. The revenue from the
reopened ALI would be used to remove the existing cap, reduce the slopes, install a water
collection system, recap the entire site and purchase a bond to finance maintenance of the new
cap and the monitoring wells.
Additional evidence of the inadequate capping of ALI is EPA's acknowledgment that run-off from
ALI is continuing to contaminate SLSS,
There is no reason to assume that the capping of SLSS will be any more successful than the
capping of the adjacent ALI. DEP has less staff now than it did during the ALI capping. To
avoid a recurrence of the debacle at ALI, EPA should select alternative SC-3B as the preferred
clean-up under The Plan.
Fencing of the Site:
The Department of Energy (DOE) erected a fence around SLSS in the early 1980's, When the
Army Corp of Engineers (ACE) began fieldwork in 2000, the fence was broken open in several
places. There was much evidence of trespassing on the site. This was a site known to be a
nuclear and hazardous waste dump.
The fence had been allowed to fall into disrepair despite DOE, EPA and DEP having knowledge
of the nuclear and hazardous waste at the site. The site is relatively small and out of the way.
Much of the site is not visible from the road. Currently, the vegetation has overgrown the fence
to such an extent that a trespasser inside the fence cannot be seen from the street.
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U.S. EPA
Mr. Dave Lederer
August 24, 2004
Page 3
In the future, trespassers will not have to be concerned about the nuclear waste and under
EPA's proposed clean-up; the hazardous waste will be contained under a cap. Trespassers will
be able to enter from the rear by accessing the highly traveled high tension wire right of way.
A fence will restrict wildlife that passes through the area including deer, coyotes, fox, waterfowl,
large snapper turtles and an endangered species, the spotted turtle, which have been observed
around the Chartley Swamp. The failure of the fencing in the past will be repeated. The
present fence is so overgrown it can be easily scaled and the vegetation shields trespassers.
This condition exists after only two years since the last cutting of vegetation from this fence.
The need for a fence would be obviated by EPA selecting alternative 3C-3B under The Plan
Massachusetts Electric Right of Way:
SLSS is bordered on one side by a Massachusetts Electric Right of Way. This right of way is
used like a bike path, but it is used by ATV's, motor bikes, snow mobiles and trail bikes. The
right of way runs for miles in both directions. It is accessible from many area roads in North
Attleboro, Attleboro, Norton, Rehoboth and Seekonk, to name only a few towns. The long
distance that can be traveled along this right of way makes it a popular trail for these vehicles
particularly at night and on weekends.
These vehicles used SLSS as a meeting place when the old fence deteriorated. No warning
signs on the fence were visible because of the over-growth of vegetation. Hunters chased deer
into the opening in the fence. A deer carcass was found at SLSS when ACE began to survey
the site in 2000.
The varied unauthorized uses of this site have been underestimated by EPA. There is no
reason to believe this site will be able to be secured in the future as would be required under the
EPA proposed limited clean-up and capping under alternative SC-2B.
The use of alternative SC-3B under The Plan would eliminate this problem.
Cap/Jump Ramp
As noted above, the site is along a highly traveled right of way for off-road vehicles. The cap
will be the ultimate challenge for these off-road vehicles that are always looking for a new ramp
to jump. The location of the ramp will be posted on Internet chat sites and will be a gathering
point for large numbers of these vehicles because of its easy access.
In time, the cap will be damaged and the material disbursed over SLSS. These vehicles will
easily pull the fence down from the back side and will not be visible from the road due to the
overgrown vegetation.
EPA has failed to consider unauthorized use of the SLSS by off-road vehicles even though the
failure of the fence erected by DOE is well known and documented,
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U.S. EPA
Mr. Dave Lederer
August 24, 2004
Page 4
The use of alternative SC-3B under The Plan would eliminate the reason for these vehicles to
use the site for jumps.
Future Maintenance of the Site:
Under EPA's proposed, limited clean-up, alternative SC-2B, there will be significant future
maintenance costs. The most significant costs in addition to monitoring wells will be
maintenance of the cap and the fence in perpetuity.
The cost of this maintenance cannot be quantified with any reasonable certainty. Experience at
many such sites has shown the estimates of the engineers to be substantially below actual
costs shortly after completion of the capping.
The future maintenance costs can be substantially reduced by eliminating the need for a fence
and cap using alternative SC-3B. This approach would remove much of the uncertainty in
estimating future maintenance costs.
It is unreasonable to believe that the maintenance costs can be estimated for a site in
perpetuity. In the future, it is likely that EPA and DEP will shift these costs to the Town of
Norton. In forty or fifty years, it will be the taxpayers of Norton who will be required to shoulder
this burden. There is no reason for this to happen and it can be avoided by selecting alternative
SC-3B.
Norton Water Supply:
The SLSS is surrounded by the Chartley Swamp which drains to Chartley Pond. The outflow of
Chartley Pond eventually flows to the Taunton River.
The Town of Norton has signed a contract with a firm which proposes to construct a
desalinization plant on the Taunton River to supply water to the Town of Norton and the City of
Brockton. This firm is actively soliciting other communities to purchase drinking water produced
at the proposed water treatment plant on the Taunton River,
EPA's proposed limited clean-up of SLSS has not considered the effect of a future chemical
release into Chartley Swamp on the drinking water of the communities that will be processed
from the Taunton River.
The preferred alternative, SC-3B, would remove SLSS as a potential source of contamination of
the drinking water for a number of communities in southeastern Massachusetts.
Incidents of Cancer:
There are numerous instances of cancer in residents of the immediate area of SLSS which have
not been adequately considered or the causes identified.
-------
U.S. EPA
Mr. Dave lederer
August 24, 2004
Page 5
In the two house nearest SLSS, all four residents died of cancer in the late 1970s to mid-1980.
The brother of one of these families lived further down Union Road. Both that brother and his
wife died of cancer in the late 1970's. Two unrelated residents of Union Road were stricken
with stomach cancer, a statistically unlikely event unless caused by the environment. Both were
long-time residents of Union Road. In 2002, two long-time residents of the area died of
pancreatic cancer within a few months of one another. A physician advised me that this was a
statistical impossibility unless there was an environmental cause.
In June 2003, numerous former residents attended a public meeting to hopefully learn the cause
of their or a relative's cancer. Residents of Sturdy Street in the 1950's to 1970's reported
extremely high incidences of cancer in their families. The same was true of long-time residents
of Maple Street. Two former residents of Maple Street told of multiple incidents of cancer
among their siblings in their 20's and 30's.
Although no definitive cause of these incidences of cancer in the area has yet been identified, it
is unreasonable to deny that a causal relationship exists and the environment appears to be the
cause.
EPA's proposed limited clean-up would leave the hazardous chemicals known to cause cancer
at SLSS. The preferred alternative SC-3B would remove these cancer causing chemicals from
the area and eliminate this potential risk for future generations.
ALI Run-Off:
EPA and ACE acknowledge that currently ALI is a continuing source of contamination at SLSS.
EPA's proposed limited clean-up of SLSS will allow ALI to avoid liability as to the future source
of contamination at SLSS.
In the future, ALI will claim that contamination at SLSS is caused by the material left on site
under EPA's proposed clean-up under SC-2B. Using alternative SC-3B would remove
hazardous chemicals from the site. Future contamination could then be traced back to its likely
source, ALI.
Prospective Responsible Parties:
Texas Instruments (Tl) is the leader of the Steering Committee for the Prospective Responsible
Parties (PRP). This position contrasts with Tl's reluctance to step forward in 1978 when a
young college student discovered the presence of nuclear material in the vicinity of SLSS and
ALI. The student attempted to report his discovery to Attleboro City officials who refused to
investigate his findings. The local newspaper carried articles ridiculing his findings. He became
the problem-not his discovery of a dangerous nuclear waste dump.
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U.S. EPA
Mr, Dave Lederer
August 24, 2004
Page 6
No one from Tl stepped forward to investigate the possible discovery of nuclear material at
SLSS even though Tl had a Nuclear Materials Division that produced such material. Tl must
have known that one thousand (1,000) pounds of enriched uranium pellets used to fuel nuclear
submarines had been missing for more than twenty-five years. DOE was also a party to hiding
the fact that 1,000 pounds of enriched uranium pellets were missing for 25 years in the Attleboro
area,
Tl's silence and inactivity at the time the young student was being ridiculed for making such a
preposterous find indicates that Tl expected the problem to "go away" quietly and at no cost.
Today, as the leader of the PRP Steering Committee, Tl is still trying to minimize the company's
financial exposure, an understandable position for a publicly traded corporation. The financial
difference to Tl would be the cost differential between alternatives SC-2B and SC-3B. The
difference is estimated to be $30,000,000 to be shared by the PRP's in proportion to their
contribution to the problem. Tl earned over $1,100,000,000 in 2003. The total cost differential
to Tl alone is insignificant and even less when allocated among all the PRP's.
EPA has the responsibility to consider input from local officials and residents of the Town of
Norton and the effect on the environment today and in the future. The cost of the proposed
clean-up alternative should not be the determining factor in the selection process.
The preferred clean-up alternative under The Plan is SC-3B,
Citizen Input:
For the past four-and-one-half years, EPA has held a number of public meetings in Norton to
explain the status of the SLSS studies. ACE requested that the Town of Norton form a technical
committee of Norton residents to provide input for the future use of SLSS.
EPA has chosen to ignore all input from the technical committee and every official of the Town
who has expressed an opinion on the preferred clean-up alternative. The Town of Norton
officials and citizens have stated on the record that alternative SC-3B is the preferred alternative
under The Plan. EPA has chosen to ignore the input of residents; officials of the Town of
Norton and the Town's state and federal representatives.
The aforementioned are significant reasons that EPA should consider in selecting the
alternative clean-up method under The Plan. The only logical clean-up for SLSS is the Plan
alternative SC-3B.
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Rug 25 04 02;30p
From-ES8.fi
S08-28S-9957
Taunton River Watershed Alliance, Inc.
PO Box 146 Bridgewater, MA 02324
Telephone (508) 697-5700
Internet; http://lauBtonriver.tripod.com
E-mail; trwa@adelphia.net
August 23, 2004
Mr. Dave Lcdcrer
U.S. E.P.A.
1 Congress Street, Suite 1100 (HBO)
Boston, MA 02114
"e:-
Subject: Comments on Proposed Cleanup Plan
Shpaek Site
Norton, MA
Dear Mr. Lederer:
The Taunton River Watershed Alliance (TRWA) is providing comments on the Proposed Cleanup Plan for the
Shpaek Superfund Site located on the border between the Town of Norton and the City of Attleboro, MA.
The riUVA i« a non-profit alliance of concerned individuals, businesses and organizations who are dedicated to
protecting and restoring the Taunton River watershed-its tributaries, wetlands, floodplains, river and lake corridors
auj wildlife. The Taunton River watershed drains water for all or part of 38 communities in southeastern
Massachusetts, providing the essential sponge for drinking water aquifers, flood storage areas, and habitat for
wildlife m this part of (lie State. The Taunton River is currently being studied for inclusion into the National Park
Swviee, National Wild aacf Scenic Rivers Program (www.'J'auntonRi vcr.orn). If is considered by nuny to be one of
the most ecologically diverse water bodies in the Commonwealth.
Chartley Swamp in the western part of the watershed feeds the Wading River which drains into the Three Mile
River, a primary tributary to the Taunton River. Chartley Swamp his been impacted with dangerous toxic chemicals
and radioactive water from many years of illegal dumping at the Shpaek site, Based upon EPA's own risk
assessments, contaminated sediments ill Chartley Swamp currently present an "unacceptable risk to wildlife" and
contaminants in groundwater present a carcinogenic nsk of exposure to humans via drinking, water consumption. It
is apparent to this organization that the only complete way to prevent fully risk of harm from contaminants at the
site is the permanent elimination of contamination that exceeds cleanup levels at the Shpaek site. That scenario is
provided only in Cleanup Alternative SC-jh.
Therefore TRW a strongly supports Cleanup Plan SC-3B as the only real plan that would lead to the
achievement of a Permanent Solution and provide protection and piescrvation of resources in this portion
of the Taunton River watershed. We thank you for consideration of our concerns.
Sincerely.
£ .X
Joseph Callahan
TRW A Board of Directors
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Robert W. Davis, TRW A Director of Acvoeay
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flue 25 O4 03:45P
K J. Sojkora to EPA; Shpack Glaacvip Altemafivo
Page t of 2
Wednesday, 25-Aug-2004
Mr, Dave Lederer
U.S. Environmental Protection Agency
1 Congress Street, Suite 1100 (HBO)
Boston, MA 02114
Dear Mr. Lederer,
t am writing this letter to express my concern and dismay regarding the EPA's proposal for
applying Alternative SC-28 as the preferred cleanup alternative for the Shpack
FUSRAP/Superfund site in Norton, MA,
As a member of the Ad Hoc Shpack Technical Committee, I was closely involved with the
Committee's endorsement/recommendation for the Passive Recreation, Adjacent Resident without
Groundwater Consumption, most closely mimicked as Alternative SC-3B in the EPA's proposal.
As a Committee, wc worked in good faith given the information provided by Cabrera Engineering
Services, the Army Corps of Engineers, and the EPA. We carefully weighed all of the various
concerns for public safety, worker safety, future community liability, and yes, even cost. We did not
opt for something as restrictive as a resident farmer scenario or neighborhood daycare center. We
concluded it inappropriate to apply the concept of "not a single atom shall remain", and made a
concerted effort to balance costs in terms of monetary expenditure, ecological impact, and worker
safety with the benefits of acceptable dose risk, and felt the resident farmer scenario was not a
practical consideration. I hesitate to use the word, but yes, we "compromised" in our decision
making process. We weighed all of the costs and benefits, and put forth our best and most logical
recommendation for a cleanup alternative that we felt was appropriate and acceptable. Again, we
worked in good faith to arrive at our proposal, and recommended it to the Town of Norton, the
Army Corps of Engineers, and the USEPA, We fee? that anything short of Alternative S03B
violates our "good faith" approach, and negates the diligent efforts of the Ad Hoc Committee.
From a technical standpoint, l feel the SC-2B proposal falls short in the long-term. Several
examples were raised at the 04-Aug-20G4 Town Meeting regarding the responsibility and liability
for future monitoring efforts. By its very nature, the deliberate onsite "disposal" of some of the
material would require greater levels of monitoring effort out into the future. Although Alternative
SC-3B would not be devoid of future monitoring concerns, the fact that less material would remain
onsite would help diminish the need for monitoring. Certainly, the monitoring efforts could be g
scaled back accordingly under the SC-3B Alternative. Ail of these arguments can be also made for jj£
the case of controlling personnel access. Taking on the burden of perimeter fence upkeep and o
trespasser control into the foreseeable future under SC-2B just doesn't make sense in comparison a
to SC-3B, where such controls and upkeep would be unnecessary. The actual monetary cost for
additional monitoring and upkeep under Proposed Alternative SC-2B could actually exceed the 0
total cost associated with Alternative SC-3B. §
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Also from a technical foundation, I would question the rationale for choosing to leave additional 2
contaminants onsite, as proposed in SC-2B. Although the proposed grade and cap barrier pictured w
in the EPA Handout employs all of the sound engineering features designed to isolate wastes, the
presence of teft-behind wastes under this cap raises the potential consequences of any future
failure or breach of this barrier. Although it is widely recognized that radionuclides such as
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p. 2
Bug 25 04 03:45p
K, J. Sejkora to EPA: Shpock Cloanup ARarnativa
Page 2 of 2
uranium, thorium, and radium, and to a certain extent heavy metals, are relatively immobile once
they are bound to soil, adequate consideration has not been given to the other factors that could
impact future isolation of the contaminants. Organic acids resulting from the breakdown of organic
materials may increase the mobility of these contaminants. The RESRAD computer models used
to assess the dose impacts from the various treatment alternatives most likely assumed default soil
transfer coefficients and teachability characteristics. As such, the potential impact for higher-than-
expected contaminant mobility as modified by organic decay products may not have been
addressed. While this argument could be made for both Alternatives SC-2B and SC-3B, the
ramifications of such an oversight are greatly diminished under Alternative SC-3B, because less
material and contaminants will remain onsite.
Again, I wish to express my concern and dismay regarding the EPA's endorsement of cleanup
Alternative SC-2B. Adequate technical justification has not been put forth to elevate it above the
SC-3B Alternative recommended by the Ad Hoc Technical Committee, based on the reasons
stated above. I therefore respectfully request that the U.S. Environmental Protection Agency
reconsider their proposal, and adopt and implement Alternative SC-38.
Kenneth J. sejkora, Ph.D.
Health Physicist/Radiological Environmental Specialist
136 Pine Street
Norton, MA 02766
Cc: Heather Graf, Ad Hoc Shpack Technical Committee
James P. Purcel!, Norton Town Manager
Robert W. Kimball, Jr., Chairman, Norton Board of Selectmen
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BARNIY FRANK
4W DISTRICT, Massachusetts
2252 fUYBURN HOUSE OPHC* BuiUMNU
Washington, DC IS»iS-?1tW
<202) 7J5-5331
29 Chat's Strict
SuTTIE 3>S
IMiwroN. MA 924SI
(fl17i331-3920
Congress at tfje Mmteb States
$ouft of 3&epretfentatibrs
f®arfjingten, 3BC
S58 PleasantSfBtcT
ROOM 309
NE«v Bedfdho, MA 0274O
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29 BflMDWW
Suite 310
Taunton. MA 02780
cum B?2 4?96
August 4,2004
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Robert W. Vamey, Regional Administrator
Environmental Protection Agency
One Congress Street
Boston, MA 02! 14
Dear Mr. Varney;
1 would like to submit the following comments conveying my strong support for
the town of Norton and its preferred cleanup alternative known as SC-3B for the
collection and removal of both chemical and radiological contaminants at the Shpack
Superfund Site, As you are aware, the Shpack landfill has the distinction of being both a
Superftmd Site under the cleanup authority of the Environmental Protection Agency
(IPA) and a Formerly Utilized Site Remedial Action Program (FUSRAP) site under the
cleanup authority of the Array Corps of Engineers (AGO!). The final decision on a
cleanup alternative has caused an understandable amount of wony for the citizens of
Norton. They are not only concerned about the actual cleanup of Shpack, but the long
term public safety and reuse potential of a fifty year old dump site that has soil
contaminated with radiological, chemical and heavy metal wastes.
The legislation authorizing the radiological cleanup of Shpack through FUSRAP
was originated by Congressman McGovern and me to ensure that a responsible and
permanent remediation of harmful radioactive waste would occur. This authorizing
legislation was passed by Congress in 2002 and the federal government, through the
ACOE, is now responsible for a significant amount of the final clean up cost outlined in
the EPA's proposed plan.
The ACOE recently agreed to work under the EPA's Record of Decision and is
scheduled to commence work on the collection mid removal of mow than 13,000 cubic
yards of radiological waste as early as 2005, The town of Norton has asked that the EPA
oversee the removal of collected chemical waste to a level that would provide a true
passive recreational use. However, the EPA's preferred alternative for cleanup, or SC-2B,
provides only a limited removal of chemical material and would cap most contaminants
on site. The subsequent fencing, monitoring, and trespass restrictions resulting from such
an option would require a level of perpetual oversight that is both impractical and
difficult, if not impossible, to enforce over a long period of time. Town officials have
raised legitimate concerns that they might ultimately be responsible for this type of
management.
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August 4,2004
Page 2
Obviously, the EPA has given significant consideration to the cost of each
cleanup option In choosing a preferred alternative. The agency*3 preferred option is one
of the least expensive. The town's request is not only the safest solution, but a financially
sensible one that is comparatively reasonable whea one looks at the variety and level of
contamination on site. It is also fiur less expensive than other costly alternatives that were
considered.
For more than four years, I have hosted and/or participated in many meetings with
' the EPA, ACOE, state officials, and local officials at various times to facilitate the
lengthy process that has brought us to where we are today, i.e., making final decisions on
cleanup proposals for use in a Record of Decision. The town, which has a voice in a final
removal determination through the EPA's Community Acceptance component, should be
protected through the best option under Superfbnd. No one person or agency can say with
absolute certainty that with the passage of time the integrity of capped materials would
not become compromised through a variety of potential degradations, natural or man
made.
Again, the government is making a significant financial commitment to the
FUSRAP portion of this project under a cleanup that involves the removal of collected
radiological material. Also, the ACOE plans on removing more material than those
options being considered by the EPA which should further reduce the costs associated
with the chemical cleanup as commingled contaminants, chemical and radiological, are
not only collected, but removed by the ACOE.
The citizens of Norton have every right to expect the EPA will oversee the
collection and removal of the chemical and heavy metal wastes at (he Shpack site with
the cost shared among those companies already identified with the responsibility of its
cleanup. Therefore, I urge EPA's approval of SC-3B to provide a comprehensive cleanup
and removal of both chemical and radiological contaminants and afford the greatest level
of protection possible to the people and their surrounding environment.
Sincerely,
BARNEYFRANK
Member of Congress
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August 24, 2004
City (Of Aitlehara, jHassaxlmsetts
OFFICE OF THE MUNICIPAL COUNCIL
Government Center, 77 Park Street
Attteboro, Massachusetts 02703
508-223-2222 • Fax 508-222-3046
Certified Mail
Return Receipt Requested
Mr, David O. Lederer
United States EPA - Region 1
One Congress Street
Suite 1100 (HBO)
Boston, MA 02114 - 2023
RE: Shpack Superfund Site Remedial Action Plan Proposal
Dear Mr. Lederer:
As President of the Attleboro Municipal Council. 1 am along with my colleagues.
Councilors Peter Blais, Robert Schoch, Carolyn Tedino, Kate Jackson, Frank Cook, Brian
Kirby, George Ross and Kim Allard writing in support of the EPA Region. We preferred
cleanup alternative (plan SC-2B) for the Shpack Superfund Site as presented by EPA.
Region I, at the public hearing held on 4 August 2004.
After reviewing the overview handout distributed by EPA at the public hearing, and as a
City official concerned with the health and safety of our residents, the environment in
which they live, and the economic well-being of our business community, we concur that
SC- 2B, rather than SC-3B, is the right choice to insure protection of human health,
safety and the environment, and to do so in a cost effective manner. We have come to
this conclusion based upon the following points:
As both SC-2B and SC-3B are protective of human health and the environment and
comply with Applicable or Relevant and Appropriate Requirements (ARARs), and,
As EPA has a long standing precedent for preferring consolidation and capping at
Superfund landfill sites (Presumptive Remedy for CF.RCl.A Municipal Landfill Sites,
EPA Guidance, 1993), including over 50 sites in New England and more than a dozen in
Massachusetts alone, and
As "presumptive remedies" are preferred technologies for common categories of sites
and can be expected to be applied at all appropriate sites unless unusual site-specific
circumstances exist, and
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As, after removal and off-site disposal of approximately 10,500 cubic yards of soil
containing radiological contaminants of concern above the cleanup levels, and
approximately 2250 cubic yards of dioxin and PCB contaminated sediment the Shpack
Superfund Site will not exhibit "unusual site-specific circumstances", and
As EPA guidance notes the CERCLA and NCP requires that a selected remedy must be
cost-effective, and
As both SC-2B and SC-3B are deemed protective, but SC-2B at an estimated cost of
$28.1 Million is also cost-effective, while SC-3B, at a estimated cost of $55.6 Million is
unnecessarily expensive, and
As many of our local businesses, large and small, will likely be brought into the existing
Potentially Responsible Party (PRP) group as new members at a time when many are
struggling economically to compete with off-shore low cost labor, and
As SC-3B will necessitate the trucking of thousands more cubic yards of contaminated
soils over local roads whether in Attleboro or Norton, incurring not only added cost, but
increased heavy truck traffic, wear and tear on roads and potential risk , and
As both the EPA and the MADEP have found SC-2B to be the preferred remedy.
We support the EPA and MADEP preferred choice - SC-2B as the proper remedial
action plan for application at the Shpack Superfund Site.
Very'Vuly yours.
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(Ethr (!}f iMtfeborn, JHassarljusetts
HEALTH DEPARTMENT
Government Center, 77 Park Street
Attleboro, Massachusetts 02703-2355
508-223-2222 * Fax 508-222-3046
¦ /-7
Christopher M. Qutnn, M.D.
Health Officer
James P. Mooney, C.H.O.
Health Agent
Charles E. Flanagan
Deputy Health Agenl
Jacqueline Joyal O'Brien, RN
Public Health Nurse
Nancy Daday
Solid Waste Administrator
Mr. Dave Lederer
US EPA
1 Congress St. Suite 1100 (HBO)
Boston, MA 02114
Re: Written Comment on Proposed Cleanup Plan
Shpack Landfill Super fund Site
Norton, MA 02766
Dear Mr, Lederer:
After reviewing both clean up proposals the Attleboro Health Department supports
proposal SC-2B and acknowledges that the clean up will provide both short-term and
long-term protection of human health and the environment. The proposal does attain all
federal and state applicable environmental requirements by reducing the volume and
morbidity of contaminated soil and sediment while also providing permanent solutions by
removing all radioactive waste, dioxin and PCB-contaminated material from the site.
The acceptable proposal will eliminate exposure from the contaminated materials to the
public by consolidating the remaining material beneath a multilayer cap.
The Department further recognizes the importance of providing public water service to 0
the two identified polluted residential wells at 59 and 68 Union Street, in Norton, a
adjacent to the Shpack dump. However, a review of the proposed water line extension
from Norton to these residents falls short in fully protecting the public health by not o
addressing the two contaminated wells in Attleboro located at 77 and 100 Peckham g
Streets. §
August 23, 2004
in
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The proposed 4000 foot extension of the water line down Union Street (in Norton) under
railroad line at a projected cost of $630,000.00 could be equally accomplished by
extending Attleboro water line 4200 feet down Peckham Street to the residential units on
Union Street, Norton.
By eliminating the $125,000.00 cost of sending Norton's water service under the railroad
line, and allowing for an eight inch service line it is reasonable to assume a savings while
providing relief for the two contaminated residential wells in Attleboro.
Both Mayor Kevin Dumas and acting superintendent Mike Burgess
have indicated their support for the water line extension.
Your review of this proposal is appreciated.
Christopher Quinn, MIX
Health Officer
James Mooney
Health Agent
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City (Of JUtMmrn, JHasMrlntsdis
OFFICE OF THE MUNICIPAL COUNCIL
Government Center, 77 Park Street
Attleboro, Massachusetts 02703
508-223-2222 • Fax 508-222-3046
August 24, 2004
Dave Lederer
U.S. EPA
1 Congress Street
Suite 1100(1 IRO)
Boston, Ma. 02114
Dear Mr. Lederer,
As an Elected Official, representing the entire City of Attleboro as an At-Large City Councilor, 1
implore the acceptance and immediate implantation of EPA proposed plan SC-2B!
Not only is SC-2B protective and cost effective, it is ready to be implemented! This problem
began in 1946, informed as a possible site of buried contamination in 1978, addressed by the
D.O.E. in 1980, and for the last 24 years, more than a generation if interest, study, identification,
and potential Clean up have occurred. What affects have these contaminants had on residents
health for the past 58 years? How many more generations must be put at risk before action is
taken?
Let's not delay Clean Up any longer!
Advocates can still pursue further action, study
contaminates from being removed any longer!
Thank you for your attention of this matter,
"waiter J. Thibodeau
Attleboro City Council
Councilor At-Large
8 Liberty Drive
South Attleboro, Ma.
0270508-399-6549
funding, but lets not delay known
Q
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8
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THE COMMONWEALTH OF MASSACHUSETTS
W
HOUSE OF REPRESENTATIVES
STATE HOUSE, BOSTON 02133-1020
August 23, 2004
Mr. Dave Lederer
U.S. EPA
1 Congress Street, Suite 1100 (HBO)
Boston, MA 02114
Re: Written Comment on Proposed Cleanup Plan
Spack Landfill Supcrfund Site
Norton, MA 02766
Dear Mr. Lederer:
The Shpaek Landfill Superfund Site has been thoroughly studied by the Environmental
Protection Agency over a number of years, I support their conclusion that alternative
solution SC-2B is the most appropriate cleanup plan. The Massachusetts Department of
Environmental Protection also supports this conclusion.
Removing the most harmful substances and capping the remainder is a solution that will
allow for recreational usage for the site. This is a remedy that has been used successfully
in Attleboro both at Finberg Field and more recently at the Balfour River Walk.
Alternative SC-2B avoids the inherent dangers associated with trucking much more
material off site. Capping the site will avoid additional public safety traffic concerns and
public health hazards resulting from airborne contaminants that are associated with
removal of more materials from the site.
The greater cost associated with completely removing all tainted soil and materials are
not insignificant. Undoubtedly, there would be an attempt to apportion the cost among
numerous additional private and public parties including the Town of Norton and the City
of Attleboro. Such an attempt would not go without legal challenge that would further
delay and adequate cleanup process for years to come.
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I also support the Attleboro Health Department's proposal to extend public water service
from Attleboro to homes with polluted wells on Peckham Street in Attleboro and Union
Street in Norton. As a result of extending water line from Attleboro you reach the
polluted wells in both communities rather than just in Norton. You also save SI 25,000
because the water line does not have to be extended under the railroad tracks,
Your time and consideration in this matter is greatly appreciated.
Sincerely,
Representative John A. Lepper
Assistant Minority Whip
Second Bristol District
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August 20,2004
Heather A, Graf
Comments To EPA On Proposed Plan For Cleanup Of The Shpack Superfund Site
From The Ad Hoc Shpack Technical Committee
The Ad Hoc Shpack Technical Committee was appointed in July 2002, by the Norton
Board of Selectmen, to work with the US Army Corps of Engineers on Re Use
Scenarios for the Shpack Superfund Site
Members of the committee:
Jim Brown, Norton Board of Selectmen
Jennifer Carlino, Norton Conservation Director
Lt, Paul Schleicher, Norton Fire & Rescue
Fred Watson, Norton Board of Health
Jeffrey Allen, Norton Resident/Environmental Engineer
Rosemary Dolan, Norton Resident/KN
Heather Graf, Norton Resident (30 years)/ Coordinator Citizens Advisory Shpack Team
Colleen Hussey, Norton Resident/Attorney
Dr Richard Krumm, Norton Resident/Member CAST
Edwin Madera, Attleboro Resident/ Engineer
Ron O'Reilly, Norton Resident (30 years)/ Member Norton Conservation Commission,
Assistant Coordinator CAST
Ken Sejkora, Norton Resident/ Environmental Engineer, Nuclear Power Plant
The committee held meetings between August 27, 2002 and January 27, 2003.
Present for these meetings were: the Project Manager for the Army Corps of Engineers,
representatives from the US ACE consulting group - Cabrera Services, a representative
from the Massachusetts Department of Environmental Protection Agency, and Project
Manager for the United States Environmental Protection Agency - Dave Lederer.
At the first meeting the purpose and goals were outlined for the committee. It was stated
that the future use model scenario(s) chosen by the Corps would dictate the level of
cleanup at the site of the radiological contaminants.
Model scenarios went from the most conservative — Residential Use, to the most liberal -
Passive Recreation III, with two other passive recreation uses in between. It was
emphasized that the committee should consider future uses that would be considered
"Reasonable".
After the committee had met on five occasions, with members having volunteered a
considerable amount of time (away from their jobs), having engaged in a great deal of
discussion and a concerted effort by all to reach agreement, the Reuse Scenario for the
Site was selected. It was Passive Recreation II. This model assumed -
That the site would be maintained by the Norton Conservation Commission, for the Town
of Norton, as Open Space Conservation Land.
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H. Graf for Ad Hoc Shpack Technical Committee to Dave Lederer
Page 2
The Use - Passive Recreation II - Assumes persons on site - hiking & camping (including
digging on site latrines), gathering of plant foods (i.e. - berries, grapes etc.), hunting,
trapping, & harvesting of aquatic foods (including, but not limited to - fish, snails,
mollusks, crustaceans, frogs, eels, turtles & other reptiles). Without an on site well or
community gardens.
Exposure pathways: Inhalation - dust & volatile chemicals, Ingestion - plant (natural),
soil, meat & aquatic foods (as described above), External exposure - dermal absorption
from soil & water contact.
All passive recreation models assume the average amount of time spent on site to be
approximately 250 hours per person, per year.
This Re Use Model chosen by the committee was accepted by the Project Manager for
the Army Corps of Engineers and their consultants (Cabrera Services) - who had
educated the committee and worked with its members in the Reuse Selection Process.
It should be noted here that the Project Manager for the EPA did attend all the joint
meetings between the Corps & Cabrera and the committee. The only input from Dave
Lederer, EPA's PM was a letter to me (as chairperson of the committee) dated November
1, 2002 requesting that I clarify for committee members references made by Cabrera in
their presentation at the October 21, 2002 meeting. (For letter - See Attachment Page 5)
Please explain the rationale for this letter.
At the time, it did not appear to be a bad omen. Especially since Mr. Lederer consistently
maintained that, if anything, EPA's standards were higher/ stricter than the Corps.
Therefore, we could expect a greater level of cleanup would be demanded by the US
Environmental Protection Agency - in their plan for remediation of the Shpack Superfund
Site.
Based on EPA's Proposed Plan, it is now apparent that these statements were not only
misleading, but false.
Having been fully engaged in this process, with EPA & the Corps for 4 & xh years,
working closely with the project managers (and in the case of the ACE - their consultant,
Cabrera), I felt confident I was well informed, as did others who attended the 13 public
meetings in Norton from February 1, 2000 to November 20, 2003.
The presentation from Mr. Lederer was consistent throughout. First the Army Corps
would excavate and dispose of (off site) all the radiological waste. Then the EPA (after
negotiations with the PRP Group) would move to Phase II - that being to clean up the
rest of the mess (volatile, inorganic & organic compounds, carcinogenic chemicals and
heavy metals (including arsenic).
While I do not recall there being any written commitment to off site disposal of the
chemical & heavy metal waste, neither did the EPA PM ever utter the word "CAP",
that is until the 11th hour in June 2004, when the EPA's "consolidate & cover" proposal
(leaving the contaminants on site) came to light for the first time and was announced as
their plan.
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H. Graf for the Ad Hoc Shpack Technical Committee
Page 3
The only time the word "CAP" was used, it was by the Project Manager for the Corps,
and I'm sure Mr, Lederer will recall (if he allows himself to) the reaction that received.
We pounced on the ACE PM for even mentioning the word relative to the Shpack Site,
Was the EPA forthright in its dealings with the community? NO,
In 4 & Vx years time and 13 public meetings, did the EPA Project Manager discuss the
various options that would be considered for their end of the cleanup deal? NO,
Did the Environmental Protection Agency even factor in the intended Re Use of the site,
as the Army Corps had done? NO, Was the EPA folly aware of what the Town of
Norton's intended use was for the Shpack Superfund Site, after cleanup? YES,
According to the Environmental Protection Agency's directive - "Land use in the
CERCLA (Superfund) Remedy Selection Process" 5/25/95 "The EPA believes that early
community involvement, with a particular focus on the community's future uses of the
property should result in a more democratic decision-making process: greater community
support for remedies selected as a result of this process; and more expedited, cost-
effective cleanups."
The Superfund Land Use Directive states that in cases where future land use is relatively
certain, the remedial action objective(s) generally should reflect this land use."
Further - "EPA is responsible for ensuring that reasonable assumptions regarding land
use are considered in the selection of a response action."
With regard to the Shpack Superfund Site, the Environmental Protection Agency has
totally ignored its own stated objectives and directives. Why?
The short answer to what has gone terribly awry here is - We were duped, either
intentionally over a long period of time, or suddenly when it came time to crunch the
numbers and deal with the cost (in both time & money) - to finally rid the EPA of this
decades old embarrassing site, and de-list it in this fiscal year.
It appears that somewhere along the line, or perhaps from the get go, The EPA bailed out
on its commitment to the Town of Norton, in favor of a plan that the Shpack Steering
Committee (PRJP Group) would endorse.
Although "Community Acceptance" is supposed to be at least a part of the modifying
criteria for EPA's selection of a response action, PRP acceptance is not listed as a criteria
item at all.
What led the Environmental Protection Agency in this direction?
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H. Graf for the Ad Hoc Shpack Technical Committee
Page 4
Was the EPA afraid that if they sought a decent (costlier) level of cleanup, that some or
all of the six PRP companies might "Walk", forcing EPA to pursue court action?
Come on... $50 million is not an unreasonable sum to expect these companies (Texaco,
Conoco, Texas Instruments, Waste Management, Swank, and Handy & Harm an) to
"pony up" for remediation of the Shpaek Superfund Site.
So... a little negotiation would be in order. We were always led to believe this would
need to occur, and take perhaps a year or two.
Negotiations? Members of the Shpack Steering Committee must be jumping for joy over
EPA's SC-2b Plan. It is the quickest, easiest, least costly proposal of any, that could be
considered a reasonable option.
Was the $28.1 option also EPA's Preferred Alternative in order to avoid the extra step of
approval from EPA's National Headquarters in Washington DC (necessary for a cleanup
projected to cost over $30 million)? That sounds extremely adolescent. Certainly, having
Congressman Barney Frank, as well as Senators Edward Kennedy & John Kerry in our
court, could (and will) simplify matters there.
Please address these questions/issues and try to make a legitimate case for EPA's
Preferred Alternative SC-2b.
And please do not just repeat the lame excuse that this option will in fact provide
"both short and long term protection of human health and the environment."
Or at the very least - explain in detail how EPA can justify this position.
All things considered, we do not believe the US Environmental Protection Agency can
make an adequate case to defend their choice of the SC-2b Alternative as an acceptable
Response Action or substantiate claims that the SC-3b Cleanup is not warranted for thhe
Shpack Superfund Site.
H
A , imittee
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August 25, 2004
Heather A. Graf, Citizens Activist
229 N, Worcester St,
1
! Onsen
Norton, MA 02766 v~—
Ph. (508) 226 - 0898
FAX (508) 226 - 2835
Dave Lederer
US EPA
One Congress St., Suite 1100 (HBO)
Boston, MA 02114
Comments On EPA's Proposed Plan For The Shpaek Superfund Site -
Personal -
My husband & I have lived in Norton for 30 years. Our home is a little over two miles
from the Shpaek Site, so the term NIMBY is not applicable.
Town of Norton's Resolve -
Cleanup of this site is not a neighborhood issue. This toxic waste dump is a menace that
has plagued the Town of Norton for 26 years, since radioactive waste was discovered
there in 1978.
Residents of the town are united and steadfast in their opposition to the Environmental
Protection Agency's "Preferred Alternative, SC~2b", and adamant in demanding the
SC-3b Alternative be selected in EPA's Record of Decision (ROD), for cleanup of the
Shpaek Superfund Site.
Be assured, as was stated at EPA's Public Hearing on August 4,2004 - when Robert
Kimball (Chairman of the Norton Board of Selectmen) read the "Position Paper For The
Town of Norton" - "Neither the EPA nor the PRP Group should underestimate Norton's
resolve. We will exhaust all regulatory, political, and legal means possible to effect the
SC-3b solution."
Political Support —
On the political level the Town of Norton has the support of Congressman Barney Frank,
State Senator Jo Ann Sprague, State Representatives Mike Coppola, Betty Poirier & Phil
Travis (all of whom testified at the August 4, 2004 Public Hearing and submitted
responses in writing as well).
Legal Aid -
To our advantage, the same attorney who has been on the Shpaek case since the
beginning, is still working for the firm which is under contract as Norton's Town
Counsel.
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August 25,2004
H. Graf to D. Lederer
Page 2
War Chest -
The Town of Norton is adding funds to the Shpack Legal Account to create a war chest,
should we be forced into a legal battle with the EPA, members of the PRP Group, or any
other entity, which would try to deny the Town its right to the SC~3b Remedy of the
Shpack Superfund Site.
We will also be prepared to engage any adversary in a dispute over the Town of Norton's
responsibility to contribute fluids for Phase II - the cleanup of the Shpack Site.
The Town's resolve to effect the SC-3b Solution will not be compromised by threats
from anyone - that ifNorton insists upon the higher level of cleanup, the Town will be
slapped with the burden of sharing the cost of that cleanup.
PRP List -
Contrary to testimony at the August 4,2004 Public Hearing, by Attleboro's Health
Agent, Jim Mooney - The Town of Norton did not ever dump materials/ waste at the
Shpack Dump, Isadore Shpack would accept anything from anyone - in an attempt to fill
his wetland property for use as an apple orchard (which by the way he never achieved,
getting only so far as raising chickens!), and obviously some Norton residents took
advantage of a neighborhood dump to get rid of their trash. That does not make the Town
of Norton culpable, any more than the Town of Rehobeth, if some of its residents took
unwanted materials to the Shpack Dump.
In June 1981, at the urging of the US Department Of Energy (DOE), the Town of Norton
did purchase from Lea Shpack (widow of Isadore, who died Februaiy 1, 1979), the parcel
of land in Norton. The $8,000 for the transfer of the property was provided to the Town
by Texas Instruments (Tl) - the major contributor to contamination at the Shpack Site.
Mrs. Shpack had wisely refused to lease the property to the Department of Energy, she
insisted on selling (unloading) it. DOE convinced the Town that cleanup would be easier
to accomplish if the site were publicly, rather than privately owned. Norton agreed to
accept title to the property in the spirit of cooperation with the Department of Energy, to
facilitate the remediation process. The agreement did include a clause that the Town was
not responsible for the contamination of Shpack.
According to the Environmental Protection Agency's spokesman at the time, and
reiterated by EPA's current Project Manager - Norton was on the PRP list because
Superfiind regulations require the owner of the property be named.
Residents of the Town of Norton have already endured far too much. The citizens of this
community have paid dearly for a highly contaminated toxic waste site - a monster that
they had no part in creating.
The "R" in PRP stands for "Responsible". The Town of Norton, while being perhaps the
only member of the group acting "responsibly"(as in good conscience) clearly was not
and is not - responsible for contamination of the Shpack Site.
Municipal Disputes -
According to Mr. Mooney, Atttleboro (the only person at the Public Hearing to speak in
favor of EPA's Preferred Alternative), the contamination on the 2 & 54 to 3- acre portion
of the Shpack Superfiind Site which lies in Attleboro - is not very contaminated.
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August 25,2004
H. Oraf to D. Lederer
Page 3
Apparently the Attleboro Health Agent has not read reports by Cabrera Services
(Consultant for the US Army Corps of Engineers). The part of the Shpack site in
Attleboro, at the border with Attleboro Landfill Inc. (ALI) is highly contaminated.
Also Mr, Mooney stated that the City of Attleboro does not care if the portion of Shpack
within their city limits — gets cleaned up at all. Just covering it sounds fine, because
Attleboro has no intention of using the land. I'm not sure who Mr. Mooney is speaking
for here. Perhaps, with the Title of Health Agent, dealing with a new mayor and city
councilors - who know little, if anything about Shpack, he has convinced some city
officials to accept this ridiculous position.
While I understand EPA must consider comments from Mr. Mooney, the same as from
the Norton Board of Health, and responses from Attleboro residents, the same as from
those of us in Norton, keep in mind 6 of the 9 acres are in Norton. The majority of
residents affected by Shpack are in Norton. The stigma of the Shpack Superfund Site has
always been Norton's. The burden of protecting the community from the negative
impacts of Shpack has been Norton's. When EPA considers "Community Acceptance"- it
must be weighted to favor the Town of Norton.
Also in a discussion with Garth Patterson (Congressman Barney Frank's Office), we
agreed that a Superfund Site must be treated equally, all together as one. You cannot
draw a line in the sand (or swamp) at the Town/City Line.
Cleanup -
At least verbally, at a preview of the Environmental Protection Agency's Preferred
Alternative, prior to the June 23,2004 Public Meeting, it was stated by a spokesperson for
EPA that a reason for not going with a higher level of cleanup was — because there is
migration from ALI into Shpack. So.If EPA has a barrel filled to the brim with
contaminated material, it should not be emptied, because there will likely be some more
bad stuff leaking into the barrel? Explain the logic in this.
Cleanup Cost -
It should be obvious that the Army Corps of Engineers will be doing the lion's share of
the cleanup at Shpack. "The spot is riddled with red dots, like a bad case of the measles."
(Red dots indicating radioactive waste). In professional terms - The radiological waste is
heterogeneously spread over the site. Also, for most of the site - the materials are not
separated between Rad. and Chemical/Heavy metals. It is all mixed up. When ACE
excavates and disposes of (off site) all the radiological waste, they will be taking with
them much of the contaminated soil that was supposed to be the responsibility of the
EPA/PRP Group to clean up.
Also there will be little, if any, "Commingled Waste" for EPA/PRP Group to deal with.
The estimates by ERM (consultant for the Shpack Steering Committee, AKA - PRP
Group) of the amount of material that will be left for the PRPs to remove are
exaggerated. And so are the estimated cost because it is figured as if the material is
"Commingled Waste". Disposal fees are significantly higher for Commingled Waste.
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August 25,2004 II. Graf to D. Lederer Page 4
Even if the Army Corps could take away only the radiological material, the fact is this
agency of the US Government is assuming the responsibility of removing TI's
contaminants.
Water Main -
EPA's plan is to extend the town water main down Union Road to get the two houses
closest to Shpack off well water, so the level of cleanup can be significantly reduced.
The cost of this water main is minimal, compared with the $70 million it saves between
Norton's Preferred Alternative SC-3b (at approx. $50 million) and the highest level of
cleanup considered (at approx, $116 million).
Representatives for the Town of Norton - Bob Kimball (CH. Norton BOS) and myself, at
the preview of EPA's Propsed Plan in June 2004, agreed upon what we thought was a
very reasonable position: Accept the water main, do not insist on a level of cleanup which
included groundwater, compromise and settle for the $50 million (middle of the road)
alternative, which would dispose of all contaminated soil off site.
In hindsight, perhaps we should not have been so agreeable. By setting our sights and
goal at a lower level, EPA thought they could get away with the SC-2b "Consolidate &
Cap Plan". Be advised we will not be so naive again.
We do see potential problems with the extension of the water mam, that being in
increased development along Union Road near the Shpack Site. While EPA has proposed
"Institutional Controls" under their SC -2b plan, they cannot regulate development
surrounding the site. And while the Town can change zoning, to perhaps Heavy
Industrial, that would not decrease (in fact might increase) the number of individuals
coming to the area. In any case, a zoning change can be reversed at Town Meeting by a
simple 2/3 majority vote.
Contaminants at the Shpack Superfund Site -
According to a 3/20/80 article in the Norton patriot - "Health Inspector Joseph Grimaldi
reported there are 200-300 barrels of PVC buried between two points on the site."
Reportedly, the PYC is residue from the Thompson Chemical fire which destroyed the
company in 1964. An abutter to the property - Louis Tetreault claims that the PVC was
poured on the site and later burned off.
According to a Sun Chronicle article 8/5/80 "While attention has been on the survey for
"hot spots"at the Shpack property recently, (US Rep. .Margaret) Heckler said she has
been told by a US DOE official that any danger from radiation was "one millionth" the
potential hazard from chemical wastes in the dumping areas."
We do know that chemicals have a greater capacity to migrate in groundwater.
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August 25, 2004
H. Graf to D, Lederer
Page 5
Contaminants at Shpaek See Attachment A
Other than some PCBs & Dioxin, which EPA proposes to remove from the site, and the
radiological waste the ACE will take away, given this horror list of toxic substances,
some known carcinogens - (Attachment A), does the EPA still maintain that their SC-2b
(Consolidate & Cover) Plan will in fact provide an acceptable level of protection for
human health and the environment?
EPA's Record of Community Involvement -
The first meeting with EPA, ACE, DEP officials and representatives of the Town of
Norton was held December 20,1999 (five days before Christmas). Could EPA - "The
Lead Agency for the Cleanup of the Shpaek Superfund Site" have chosen a more perfect
time to ensure no one would give a damn about Shpaek? Surprise, some of us did.
Then there was the scheduling of the public meeting, to finally after 4 & !/z years advise
Norton residents of EPA's ill advised Plan - June 23, 2004 (days after school recessed for
summer break). And the setting of the Public Hearing for August 4, 2004 (in a steamy
school cafeteria) - to deflect interest by any other than the very most hardy souls. The
public comment period from June 24 - August 25 couldn't be much worse. Does
anyone, other than Heather Graf, not take at least one weeks vacation during that period?
How many individuals are going to spend any time trying to review EPA's Shpaek Plan,
(such a tedious task) during the summer months? And even for the willing, the material is
so voluminous, almost no one could do more than scan it. Even our expert Conservation
Director - Jennifer Carlino, was hard pressed to respond to even the Feasibility Study.
Forget about reviewing the 229 page text of the "Draft Baseline Ecological Risk
Assessment", prepared by EPA's consultant - Metealf & Eddy, dated June 14, 2004. In
addition to the 229 page text there are Figures, Tables & 3 Appendices - the volume is
5 &1/4 inches thick!
As for the 3 discs provided with the box loads of written material - the table of contents
on the discs is done in CODE.
The designations of alternatives: the EPA's favorite SC-2b and Norton's preferred plan
SC-3b were so similar, as to be totally confusing when trying to separate the two.
The power point presentation at the June 23,2004 public meeting - with miniscule white
letters on black boxes was pathetic. One needed a magnifying glass to read what was
printed on the handouts. Try to copy - and use up an ink cartridge. Don't even think about
FAXING! And the 12 page Proposed Plan handout was the most diseombobulated of any
paper I have ever reviewed.
Whether in their timing or presentations, the US Environmental Protection Agency has
demonstrated an uncanny ability to make the process the least user friendly, the most
difficult & frustrating, and I do believe this was intentional.
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August 25,2004
H. Graf to D. Lederer
Page 6 (Final)
At the introduction to the Public Hearing August 4, 2004, the EPA's Hearing Officer -
Susan Studlien said the hearing was being conducted to receive testimony on The
Proposed REMEDY For the Shpack Superfund Site. The SC-2b Plan is not a REMEDY!
If the US Environmental Protection Agency insists on the SC-2b Plan, it will be apparent
that the name of your agency is an oxymoron.
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i\Yf\
CONTAMINANTS , SHPACK & A LI (ATTLEBORO LANDFILL INC.)
Nuclear Regulatory Commission / November 1978 SHPACK
Principal Radioactive Compounds Above Natural Background Levels:
Uranium - 234, Uranium - 235, Uranium - 238
Radium - 226
Department Of Environmental Quality Engineering / March 1980 SHPACK
Elevated Levels Of Heavy Metals In Soil;
Lead, Arsenic, Chromium, Copper, Cadmium, Nickel, Zinc
Department Of Environmental Quality Engineering / November 1980 SHPACK
Chemicals Detected In Groundwater Above EPA Maximum Contamination Level For
Drinking Water:
1.2.- dichlorethylene, trichlorethylene, tetraehloroethylene
US Environmental Protection Agency / May 1982 SHPACK
Soil & Groundwater - Several Volatile Organic Priority Pollutants Detected
US EPA & Roy F. Weston Technical Assistance Team / August 1989 SHPACK
Presence Of Chemicals In Surface Water Samples At Concentrations Exceeding "EPA
Ambient Water Quality Criteria For Protection Of Human Health":
Vinyl chloride, benzene, 1.2.- dichlorethene, aroctor - 1248
US EPA & Weston / November 1989 SHPACK
Soil Samples Confirmed Presence Of:
Volatile Organic Compounds, Semi-volatile Organic Compounds, Polyehlorinated
Biphenyls (PCBs)
DUMPED ON SITE SHPACK, 1946- 1966:
Waste Oil, Degreasing Solvents, Iron, Cyanide, Heavy Metals, Precious Metal Refining
Waste, Resins, Organics, Depleted Uranium, Vinyl Chloride
GHR ENGINEERS OF NEW BEDFORD / March 25, 1980
SHPACK & ATTLEBORO LANDFILL (ALI)
Samples Collected From 10 Observation Wells On ALI Property On Peckham St.,
Plus 2 Samples Of Contaminated Soil From Older Landfill Northeast Of Present
Landfill (SHPACK):
] 5 Volatile Chemicals Were Detected In One Or MoreObservation Wells. "Eight Of The
Volatile Organics : Vinyl chloride, Chloroform, 1.2 - Dichloroethylene, Methylene
Chloride, Bromodichloromethane, Trichloroethylene, Benzene & Tetraehloroethylene
Exceed Human Health Criteria."
"These Volatile Organic Compounds Are Considered To Be Potential Carcinogens If
Consumed In Drinking Water, Fish Or Shellfish."
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PAGE 2 * '
GHR ENGINEERS / March 25, 1980 (Continued)
"If A Chemical Is Suspected Of Being A Human Carcinogen, There Is No Recognized
Safe Concentration In Drinking Water Or Food Which Will Provide Absolute Protection
Of Human Health Except Zero."
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The Norton Patriot, July 19, 1979 3
a
S.1!f.,A "*?" ^ "» NRC confirmed that Tl dumped
5S.™!,", "" Shrk ""»'»» ""ton RoS
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Q. Urb A >t,\K G j^WO
6 The Sun Chronicle, Friday, June 2?, 1980
Norton and state officials take water samples Iron,
Chartley Pond. Norton, in search for traces of possible
T^c+inn radioactive contamination from the SehpacK dump
Icbiiny property From left are Oavid Opatka. Norton con-
servation director; Robert Fagan (kneeling) of the state
Department of Public Health: Gary Keegar, state
engineer, and Norton Health Agent Joseph Gnmald;
(Photo by Frank Adams'
-------
MA.
. Charles Eradrick oHhe Oak Ridge National Laboratory
At landfill crew uses probe to check for surface radiation on Al-
tleboro Landfill inc. lane Friday.
(Photo by frank Adam
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CiWo^U. »o\n\8o
, |
Taking sample
Workers on the team hired by the U.S. Department of
Energy to determine the extent of radioactive con-
tamination at the Shpack property in Norton Monday
take a ground water sample from the site. Sample was
taken by lowering a water collector into a hollow drill bit
drilled four feet Into the earth. .
(Photo by LeoPeloqum)
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August 24, 2004
Certified Mail
Return Receipt Requested
Mr. David O. Lederer
United States EPA - Region I
One Congress Street,
Boston, MA 02114-2023
RE; Comments on Proposed Remedial Action Plan
Shpack Superfund Site
Norton/Attleboro, Massachusetts
Dear Mr. Lederer,
As the Chairman of the Shpack Steering Committee,1 please accept this letter providing
comments on the United States Environmental Protection Agency ("EPA") Proposed
Plan for the Shpack Landfill Superfund Site in Norton and Attleboro, Massachusetts (the
"Site") dated June 2004. The Shpack Steering Committee endorses EPA's selected
remedy as documented in the Proposed Plan for the Site using Alternative SC-2B (the
"Preferred Alternative") that includes both (1) excavation of PCB, dioxin and
radiological material and (2) consolidation of residual materials that pose little or low-
level risk beneath an onsite multi-barrier landfill cap. The Steering Committee
endorsement is based on the fact that the Preferred Alternative is distinctly superior when
compared to the other alternatives evaluated pursuant to EPA's nine remedy selection
criteria. In this letter, we will set forth in greater detail the analysis supporting this
conclusion.
VISION FOR THE FUTURE
At the outset, we wanted to highlight the community benefits to be derived from the
appropriate implementation at the Shpack Site of the Preferred Alternative.2 These
benefits are substantial and include the following:
• The Site, as remediated, will be protective of both human health and the
environment,
• The Preferred Alternative is the most reliable from an implementability
perspective, has the fewest short-term negative impacts on both the community
and on-site workers and can be accomplished in the shortest period of time.
1 Presently the Shpack Steering Committee consists of Texas Instruments Incorporated, ConocoPhillips,
Keewanee Industries, Inc., and Swank, Inc.. The signatories to the ACQ not included in this response are
Handy & Harman, Inc. and Waste Management, Inc.
2 This remedy could be implemented either by potentially responsible parties under the terms of a Remedial
Design/Remedial Action Consent Decree or by EPA, as the remedial lead.
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Mr. David O. Lederer
Page 2 of 11
August 24, 2004
• As an integral element of the remedy, the Site can be enhanced ecologically
through both careful wetland restoration and the planting of a native New England
wildflower meadow on the soil cap. Such meadows are currently scarce in New
England and provide much needed habitat for birds, butterflies and other
creatures, a number of which are rare or endangered. Combining an upland
meadow habitat with the adjacent wetlands offers even greater wildlife benefits.
• In addition to planting the meadow, there can be wildlife enhancements designed
into the remedy such as bird nesting boxes, turtle nesting areas, perches for
raptors and strategically located brush piles for shelter.
• Such an ecologically enhanced site will offer a community resource that is far
more valuable than a site for housing or agricultural uses. This is the case
because a network of nature trails and boardwalks for the benefit of the
Community can be constructed as part of the remedy implementation, together
with educational and interpretative signage, so that members of the community
may enjoy recreation in a unique natural setting. While housing and agricultural
uses are more readily available, such native meadow/wetland habitat is a scarce
recreational resource,3
• Funding can also be made available to sponsor nature interpretation and
environmental education programming on the Site in conjunction with
environmental organizations (e.g., Massachusetts Audubon) and the local schools.
• The continuing integrity of the cap, the ecological enhancements and the
educational programming can be secured through a funded remedial trust.
The above benefits are not theoretical. Such a native New England wildflower meadow,
together with associated wildlife enhancements, has been successfully implemented at the
ReSolve, Inc. Superfund Site in North Dartmouth, Massachusetts (Exhibit A). Moreover,
the Wildlife Habitat Council (WHC) of Silver Spring, Maryland, a non-profit
organization which encourages and helps to design and integrate ecological/wildlife
enhancements into Superfund remediation projects, has successfully assisted in the
incorporation of such enhancements into several major landfill remediation projects
(Exhibit B).
Thus, not only does the Preferred Alternative best satisfy EPA's own remedy selection
criteria as highlighted in the Proposed Plan and this comment letter, but it offers the
3 This type of recreational resource is becoming ever more important in the face of development "sprawl",
and it is consistent with the salutary planning objective of locating parks in natural settings which are
convenient to user population concentrations such as Attleboro. Also, less desirable uses such as landfills
were historically located near the borders of communities. A recreational and educational resource situated
on the former Shpack Landfill would reverse this unfortunate precedent by instead siting a valuable
community asset at the common boundary of Attleboro and Norton.
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Mr. David O. Lederer
Page 3 of]1
August 24, 2004
community the shortest remedial time frame, with the fewest implementation risks and
very significant accompanying community benefits.
NATIONAL CONTINGENCY PLAN'S NINE REMED Y EVAL UA TION CRITERIA
This section sets forth the nine remedy selection criteria used by EPA pursuant to the
National Contingency Plan ("NCP") to select the remedy for the Shpaek Site and
summarizes the facts that provide compelling support for EPA's selection of Alternative
SC-2B.
/, Overall Protection of Human Health and the Environment
In the Proposed Plan, Alternatives SC-2B and SC-3B are both stated to be protective of
human health and the environment. However, EPA has established a long-standing,
nationwide precedent for preferring consolidation of landfill materials and placement of
landfill caps at Superfund Landfill Sites such as Shpaek. Specifically, EPA's own
regulations at 40 CFR 300.430 (a)(l )(iii)(B) of the NCP state that "EPA expects to use
engineering controls, such as containment, for waste that poses a relatively low long-term
threat..Further EPA's Presumptive Remedy for CERCLA Municipal Landfill Sites
guidance (September 1993, EPA 540-F-93-035)4recommends that containment (i.e.,
capping) be used at landfill sites such as Shpaek that pose 'a relatively low long-term
threat' with 'a heterogeneous mixture of municipal waste frequently co-disposed with
industrial and/or hazardous waste'. Consistent with its regulations and Presumptive
Remedy guidance, for over twenty years, EPA has approved the use of landfill caps at
Superfund Sites throughout the country as evidenced by the following:
• Table 1 includes the results of a search of the EPA Records of Decision (ROD)
database identifying 149 Superfund Landfill Sites around the country where
landfill caps have been implemented as part of the selected remedy.
4 As stated in this Presumptive Remedy guidance document at page 1:
Presumptive remedies are preferred technologies for common categories of sites,
based on historical patterns of remedy selection and EPA's scientific and
engineering evaluation of performance data on technology implementation, The
objective of the presumptive remedy initiative is to use the program's past
experience to streamline site investigation and speed up selection of cleanup
actions. Over time presumptive remedies are expected to ensure consistency in
remedy selection and reduce the cost and time required to clean up similar types of
sites. Presumptive remedies are expected to be used at all appropriate sites
except under unusual site-specific circumstances, (emphasis supplied).
It must be emphasized that, following the excavation of the Principal Threat wastes,
including the PCBs, dioxins and radiological materials, as called for by Alternative SC-2B,
there are no unusual site-specific circumstances affecting the Shpaek Site which would
distinguish it from the other Superfund Landfill Sites at which the presumptive containment
remedies have been implemented.
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Mr, David O Ledcrer
Page 4 of 11
August 24, 2004
• Table 2 includes the results of a search of the EPA ROD Region I Database
identifying 50 Superfund Landfill Sites in New England where caps have been
implemented as part of the selected remedy.
• Table 3 includes a sample selection of Superfund Sites having contaminants
similar to the Shpack Site that have been capped in all areas of the country.
It is important to note that Alternative SC-2B goes beyond capping by including
excavation of Principal Threat wastes (i.e., PCBs, dioxin and radiological material).
Alternative SC-2B thus thoroughly addresses both the health and environmental risks at
the Site.
2. Compliance with ARARs
As the Proposed Plan notes, both Alternatives SC-2B and SC-3B are compliant with
Applicable or Relevant and Appropriate Requirements (ARARs), However, Alternative
SC-2B best comports with published EPA guidance and related documents supporting the
effective implementation of ARARs, including;
• Presumptive Remedy for CERCLA Municipal Landfill Sites (September 1993,
EPA 540-F-93-035) - As discussed above, this guidance establishes capping as
EPA's preferred alternative for Low Level Threat wastes at Superfund Landfill
Sites such as the Shpack Site.
• Reuse of CERCLA Landfill and Containment Sites (September 1999, EPA 54G-F-
99-015) This fact sheet describes the implementation of EPA's Superfund
Redevelopment Initiative at Superfund Landfill Sites. This initiative focuses on
finding productive uses for Superfund Sites following remedy implementation.
As discussed above, once the cap is complete, the Shpack Site may be
beneficially reused consistent with the goals of the Superfund Redevelopment
Initiative. For example, at page 3 of this document, it is observed that:
The historical practice of siting landfills in remote areas often
allows all or part of a landfill site to be used for future ecological
use. Wildlife enhancement areas and wetlands provide green space
and habitat for indigenous species, and often serve as a cost-
effective and design-friendly means of returning landfills to
beneficial use.
• The Role of Cost in the Superfund Remedy Selection Process (September 1996,
EPA 54Q-F-96-018) - This fact sheet outlines the CERCLA and NCP requirement
that every remedy selected "must be cost-effective" (emphasis in the original).
As documented at 40 CFR 300.430(1)0 )(ii)(D), a selected remedy is considered
cost effective if its 'costs are proportional to its overall effectiveness'. Alternative
SC-2B has the distinct advantages of offering greater net risk reduction benefits
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Mr. David O. Lederer
Page 5 of 11
August 24, 2004
(see the discussion below) and comporting with EPA's Presumptive Remedy
guidance, while Alternative SC-3B, lacks these advantages and is
disproportionately (almost twice the cost) expensive. Thus, Alternative SC-2B
must be selected in order to comply with CERCLA, the NCP and applicable
guidance.
3, Long-Term Effectiveness and Permanence
Alternative SC-2B provides long-term effectiveness and permanence. We fully concur
with EPA's statement that landfill capping is a proven technology for effectively
eliminating exposure to chemical waste material over the long-term. Moreover, such
long-term performance can be even further assured through the beneficial site reuse
approach discussed at the outset of these comments. This is the case, because the creation
of a native New England wild flower meadow and wildlife habitat area, which, as
previously noted, can be maintained and supervised by a fully funded remedial Trust, will
help assure that the Shpack Site does not become an unsupervised "orphan". Instead,
institutional and engineering controls would continue to be monitored and enforced by
such a funded entity. Moreover, the communities themselves will have a positive stake in
the future of the Shpack Site since it will be a public recreational and educational asset.
In this connection, the Steering Committee understands that the community is concerned
about the possible installation of a chain-link fence surrounding the property, as it will
limit access for recreational activities such as nature walks, bird watching, etc. Given
the objective of transforming the Site into an attractive and useful recreational and
educational resource for the community, it most certainly will not be fenced off so as to
be inaccessible. Rather, the selected Alternative SC-2B remedy can incorporate the
installation of a rock wall or a post and beam fence (see Exhibit B) that would be
aesthetically appealing and would allow for pedestrian access, while preventing access by
off-road vehicles.
4. Reduction of Toxicity, Mobility or Volume Through Treatment
As stated in the Proposed Plan, both Alternatives SC-2B and SC-3B achieve reduction of
toxicity, mobility or volume, although not through treatment. Specifically Alternative
SC-2B addresses Principal Threat waste at Shpack through excavation of radiological,
PCB and dioxin material. In addition, the placement of a landfill cap under Alternative
SC-2B ensures that any residual Low Level Threat waste is secured safely beneath a cap
so as to eliminate any exposure pathway to community residents. In contrast, Alternative
SC-3B will leave residual impacted material below Preliminary Remediation Goals
(PRGs) in soil at the Shpack Site without the benefit of a cap, As a consequence, such
residual material could be mobilized in the future or accessed by community residents.
Moreover, while the uncapped residual material left under Alternative SC-3B may not in
and of itself at this time be deemed to be a threat to public health or the environment, our
collective understanding of risk changes over time, as do the regulations designed to
protect human health and the environment. Thus, it is possible that contaminant levels
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Mr. David O. Lederer
Page 6 of 11
August 24, 2004
not considered to pose an unacceptable risk today could be deemed too risky in the
future, thus impairing both the protectiveness and permanence of Alternative SC-3B.
Finally, the presence of impacted source material present in the portions of the AL1
Landfill adjacent to the Shpack Site could reeontaminate materials that are left uncapped
under Alternative SC-3B. Thus, the cap provided by Alternative SC-2B is likely to offer
greater long-term protection than that associated with Alternative SC-3B,
5. Short-Term Effectiveness
Alternative SC-2B would be implemented in the shortest time frame and have the least
impact on the community. Specifically, Alternative SC-3B requires excavation and
management of 24,000 cubic yards (yd1) more contaminated soil than Alternative SC-2B.
Therefore, if Alternative SC-3B were to be implemented, it would require approximately
2,000 more truck trips to transport contaminated soil out of the local community, and an
additional 2,000 truck trips to import clean fill to the Site. Due to the potential for cross
contamination, it is not practical to utilize the same truck to bring in clean fill that is used
to transport contaminated material away from the Site. As shown on Figure 1, a likely
truck route along Route 140 to access the Shpack Site will bring these 4,000 trucks,
approximately one-half of which will be hauling contaminated material, past four
schools. In addition, the significantly greater quantities of materials to be excavated as
part of Alternative SC-3B would increase the potential for dust and/or volatile emissions
during remedy implementation, thereby increasing the risks to the community. This
increased risk is unwarranted given the fact that Alternative SC-2B is both protective and
ARAR compliant.5 Indeed, this very issue was addressed in the landmark case of U.S. v.
Hardage, 750 F. Supp. 1460 (D. Okla. 1990) (see discussion below) where a Court
rejected a proposed excavation remedy, in favor of a containment remedy, since the
excavation remedy presented "unacceptable risks to workers, to nearby residents, and to
the environment".
The same concerns with an extensive excavation-based remedy that were expressed by
the Court in the Hardage case were also articulated by EPA New England in evaluating
the short-term effectiveness and implementabililv of the alternative remedies considered
for Operable Unit 1 of the Raymark Industries, Inc. Superfund Site in Stratford,
Connecticut. This was an EPA remedial lead site where, as with the Shpack Site, an
excavation remedy (coincidentally identified as Alternative SC-3) was compared with a
capping remedy (identified as Alternative SC-2). In its Record of Decision for the
Raymark Site, EPA selected the capping remedy stating:
The use of appropriate engineering controls and personal protective
equipment is expected to minimize adverse impacts to the community and
workers, respectively. Earth moving activities (consolidation and
3 These types of "severe effects across environmental media" are cited in applicable guidance as a situation
where containment may be used even to redress Principal Threats, let alone the Low Level Threats for
which containment is proposed by Alternative SC-2B. Rules of Thumb for Superfund Remedy Selection
(August 1997, EPA 540-R-97-013),
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Mr. David O. Ledercr
Page 7 of!1
August 24, 2004
backfilling) associated with Alternative SC-2 are expected to generate
some limited amounts of fugitive dust and vapor-phase VOCs, but would
be easily managed through engineering controls (such as wetting or use of
dust suppressants). Alternative SC-3 [excavation and off-site disposal]
would likely result in greater short-term impacts (e.g., generation of
increased dust and vehicular traffic) than SC-2 because of the excavation,
handling, and off-site transport of 21,000 cubic yards of highly
contaminated material contemplated under SC-3. Alternatives SC-4 and
SC-5 would involve much more excavation and materials handling and
would likely result in much greater fugitive dust and vapor-phase VOCs
generation than Alternatives SC-2 and SC-3, The control of fugitive dust
and/or vapor-phase VOCs for Alternatives SC-3 through SC-5
through common practices such as wetting or use of dust suppressants
becomes increasing more difficult as more contaminated materials are
excavated. This would result in added risks to workers and nearby
residents, (emphasis supplied). Raymark Industries, Inc. Operable Unit 1
Record of Decision, July 13, 1995 at pages 28-29.
Certain Stratford, Connecticut community members urged implementation of the
excavation remedy for the Raymark Site to which EPA responded in its Responsiveness
Summary as follows;
EPA prefers Alternative No. 2, capping, since it offers the best
combination of protecting human health in the short and long-term, can be
completed within a relatively short time period, is economically feasible
and implementable, and would result in less disturbance of highly
contaminated material and possible threats to nearby individuals during
implementation of the remedy. The excavation and off-site disposal may
create more problems than may be solved. Capping is a permanent
solution provided that there is periodic maintenance and it affords a level
of long-term protection appropriate to the future re-use of the property. Id.
Responsiveness Summary at page 22.
Notably, the excavation remedy (SC-3) rejected at the Raymark Site involved the off-site
disposal of only 21,000 cubic yards, whereas the excavation contemplated by Shpaek
Alternative SC-3 would involve the off-site disposal of over 24,000 additional cubic
yards.
Finally, it is also to be noted that the selection of Alternative SC-3B would trigger review
by EPA's National Remedy Review Board. In accordance with EPA policy, this review
is required because Alternative SC-3B is estimated to cost (a) more than $30 million or
(b) more than $10 million and 50% greater than the cost of the least costly, protective.
ARAR-compliant alternative (i.e., Alternative SC-2B), This remedy review process
could further delay the implementation of a protective remedy at the Shpaek Site.
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Mr. David O. Lederer
Page 8 of 11
August 24, 2004
6. Implementability
As described in the Proposed Plan, Alternatives SC-2B and SC-3B are both potentially
implementable at the Shpack Site. However, Alternative SC-3B poses the multiple
implementability challenges and risks detailed above under "Short-Term Effectiveness",
including those risks cited by EPA in its Raymark Industries, Inc. Superfund Site
Operable Unit 1 Record of Decision. In addition, Alternative SC-3B would pose
significant structural engineering challenges in order to manage the excavation of
impacted material adjacent to the towering Attleboro Landfill, Inc. (ALI) landfill which
borders (and forms part of) the Shpack Site. Finally, from an implementability
perspective, Alternative SC-2B is consistent with EPA's nation-wide implementation of
containment remedies at Superfund Landfill Sites.
7. Cost
As described in EPA's Proposed Plan, the cost for Alternative SC-3B is almost twice that
of Alternative SC-2B. This additional $27,000,000 cost associated with Alternative SC-
3B is in fact grossly disproportionate to the risk reduction, if any, achieved by
implementing this far more costly excavation alternative. Indeed, given the short-term
effectiveness and implementability concerns detailed above, it would appear that
Alternative SC-3B in fact will achieve less net risk reduction than Alternative SC-2B.
Furthermore, given the scope of this project, the potential for cost overruns and
implementation delays would be far greater during the implementation of Alternative SC-
3B than it would be during the implementation of Alternative SC-2B, thereby further
increasing the already
disproportionate cost differential between the two remedial alternatives.
8. State Acceptance
As documented in EPA's Proposed Plan, the Massachusetts Department of
Environmental Protection (MA DEP) has reviewed and approved of the preferred cleanup
Alternative SC-2B.
9. Community Acceptance
The PRP Group recognizes that certain members of the community are opposed to the
Preferred Alternative as documented in the Proposed Plan. However, as with the
Raymark Site described above, it appears that such opposition is an inevitable part of the
process. Moreover, the statements made by certain commenters to the effect that
Alternative SC-2B is not protective and will leave the community with a toxic wasteland
are simply not accurate. First, as discussed above, capping is EPA's established
presumptive remedy for Superfund Landfill Sites, and it is both protective and widely
used. Moreover, as is highlighted in these comments, Alternative SC-2B can be
implemented so as to result in the post-remediation Shpack Site being available to the
community as a valuable recreational and educational asset as opposed to a fenced
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Mr. David U. Leuerer
Page 9 of 11
August 24, 2004
wasteland, Indeed, the restoration of the impacted wetlands and the installation of a
native New England wildflower meadow, together with associated wildlife
enhancements, would be fully consistent with the Superfund Redevelopment Initiative's
objective of returning contaminated sites to beneficial reuse.
Special Note Regarding the Waterline
In the Proposed Plan, it is stated that a waterline will be provided to two adjacent
residents. As we have discussed, if the two residences in question continue to use water
supply wells, then such a waterline would be necessary. However, if both of the adjacent
properties were made subject to restrictions prohibiting the use of groundwater, then in
such event the waterline would not be necessary. We respectfully request that EPA
provide appropriate flexibility in its Record of Decision so that such restrictions against
the use of groundwater or other means of eliminating the groundwater exposure pathway,
if duly implemented, could be substituted for the construction of the waterline, since they
would eliminate the very risk that the waterline is designed to address.
CONCLUSIONS
In conclusion, as discussed above, this is not the first time that the benefits of a
"containment" or capping remedy have been demonstrated to outweigh the risks and
shortcomings associated with a large-scale "excavation" remedy such as the one
proposed by Alternative SC-3B. In the seminal CERCLA case in which a court was
forced to evaluate remedial alternatives, U.S. v. Hardaee. 750 F.Supp. 1460 (D.Okla.
1990), the U.S. District Court found that the containment remedy proposed by the
potentially responsible parties was "markedly superior" to the excavation remedy
proposed by EPA. 750 F.Supp. at 1463. The Court rendered this decision after carefully
considering the testimony of 45 trial witnesses, inspecting more than 470 exhibits, and
examining more than 8,000 pages of affidavits and deposition transcripts and 250 pages
of stipulations - all told, a record "totaling more than 150,000 pages." Id. The record
compiled in Hardage led the Court to conclude that the proposed excavation remedy
clearly "would result in more contaminants being released through vapor and dust
emissions than will be released during construction" of the cap which, in turn, meant that
the excavation remedy would present "unacceptable risks to workers, to nearby residents,
and to the environment." Moreover, the Hardage Court found that the proposed landfill
excavation remedy relied on "approaches that are not cost-effective and that are
otherwise inappropriate," and did not satisfy the "standards for remedies that must protect
the public health and welfare and the environment." Id. at 1480-82. The Court further
recognized that all the risk and cost associated with the excavation remedy would be for
naught, because the Hardage site (like the Shpack Site) could "never be returned to its
prewaste disposal condition under any remedy," Id. at 1477.
Fortunately, the lessons learned through the lengthy litigation that led to the Hardaee
decision need not be learned again here, The proposed Shpack remedy selected by EPA,
Alternative SC-2B. like the containment remedy selected by the court in Hardage.
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Mr. David O. Lederer
Page 10 of 11
August 24, 2004
addresses "in a comprehensive way management of the wastes present" at the Shpack
Site. Id. at 1484. It does so by, among other things, removing both the radiological and
chemical waste that poses a high-level threat; consolidating, containing and capping the
low-level threat waste that will remain on-site; and restoring previously impacted
wetlands to their natural state.
Moreover, Alternative SC-2B is even more beneficial to the local community than was
the court-ordered remedy in Hardaee, Unlike the Hardage site remedy, which the Court
admitted would not "make the site suitable for use by animals or humans in the
foreseeable future," Alternative SC-2B promises to create valuable amenities for the
residents of Norton and nearby towns, including a native New England wildflower
meadow and wildlife habitat, footpaths and other passive recreational resources, nature
interpretation and outdoor educational opportunities, and open space.
For all of the foregoing reasons, the Shpack PRP Group fully supports Alternative SC-
2B, the remedial alternative selected by the EPA.
Chairman
Shpack Steering Committee
cc: Shpack Steering Committee Members
References
Proposed Plan Shpack Landfill Superfund Site, Norton, MA United States Environmental
Protection Agency, June 2004;
A Guide to Principal Threat and Low Level Threat Wastes, USEPA November 1991,
Publication No, 93803-06FS;
Presumptive Remedy for CERCLA Municipal Landfill Sites, USEPA, September 1993,
Directive No. 9355.0-49FS (EPA-540-F-93-035);
Reuse of CERCLA Landfill and Containment Sites, USEPA, September 1999, OSWER
9375.3-05P (EPA 540-F-99-015);
Landfill Presumptive Remedy Saves Time and Cost, USEPA, January 1997, Directive No.
9355.0-661 (EPA 540/F-96/017);
Sincerely,
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Mr. David U. Ledcrer
Page 11 of 11
August 24, 2004
The Role of Cost in the Superfund Remedy Selection Process, USEPA, September 1996,
Publication No. 9200.3-23FS (EPA 540-F-96-018);
A Guide To Selecting Superfund Remedial Actions, USEPA, April 1990, Directive No.
9355.0-27FS; and
Rules of Thumb for Superfund Remedy Selection, USEPA, OSWER, August 1997,
Directive No. 9355.0-69 (EPA 540-R-97-Q13).
Figure 1 - Potential Truck Route for Contaminated Material
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Exhibits
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Exhibit B - Bridgestone Superfund Site, Cecil County, MD
Ongmaib \%i
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Table 2 - Summary of Region I (New England) Superfund Landfills
USEPA Superfund Information Systems - Region I
Site Name
Slate Site Type
City
PARKER SANITARY LANDFILL
VI
NPL
Lyndon ville
HAVERHILL MUNICIPAL LANDFILL
MA
NPL
Haverhill
BENNINGTON MUNICIPAL SANITARY LANDFILL
VT
NPL
Bennington
SUTTON BROOK DISPOSAL AREA
MA
NPL
Tewksbury
IRON HORSE PARK
MA
NPL
North BiEterica
TROY MILLS LANDFILL
NH
NPL
Troy
CENTRAL LANDFILL
RI
NPL
Johnston
LAUREL PARK, INC.
CT
NPL
Naugatuck
BEACON HEIGHTS LANDFILL
CT
NPL
Beacon Falls
LANDFILL AND RESOURCE RECOVERY, INC. (L&RR)
RI
NPL
North Smithfield
DAVIS (GSR) LANDFILL
RE
NPL
Glocestei and Smithfield
BFI SANITARY LANDFILL
VT
NPL
Rockingham
SOMERSWORTH SANITARY LANDFILL
NH
NPL
Somerswortti
OLDSOUTHINGTON LANDFILL
CT
NPL
Southington
W1NTHROP LANDFILL
ME
NPL
Winthrop
CHARLFS-GEORGE RECLAMATION TRUST LANDFILL
MA
NPL
Tyngsbo rough
BARKHAMSTED-NEW HARTFORD LANDFILL
CT
NPL
Barkhamsted
ROSH HILL REGIONAL LANDFILL
HI
NPL
South Kingstown
COAKLEY LANDFILL
NH
NPL
Greenland and North Hampton
SACO MUNICIPAL LANDFILL
ME
NPL
Saco
BURGESS BROTHERS LANDFILL
VT
NPL
Woodford and Bennington
NEW LONDON SUBMARINE BASE
CI
NPL
Groton and Ledyard
DOVER MUNICIPAL LANDFILL
NH
NPL
Dover
AUBURN ROAD LANDFILL
NH
NPL
Londonderry
SCOVILL INDUSTRIAL LANDFILL
CT
NPL
Wafcerbury
NEWPORT NAVAL EDUCATION/TRAINING CENTER
RI
NPL
Newport, Middletown, Portsmouth, arid Jamestown
WEST KINGSTON TOWN RUMP/URi DISPOSAL AREA
RI
NPL
South Kingstown
OLD SPRINGFIELD LANDFILL
VT
NPL
Springfield
POWNAL TANNERY
VT
NPL
North Powtxal
PETERSON/PURITAN, INC.
RI
NPL
Cumberland and Lincoln
PORTSMOUTH NAVAL SHIPYARD
ME
NPL
Kittery
BRUNSWICK NAVAL AIR STATION
ME
NPL
Brunswick
DAVISVILLE NAVAL CONSTRUCTION BATTALION CENTER
RI
NPL
North Kingstown
SALEM ACRES
MA
NPL
Salem
SOUTH WEYMOUTH NAVAL AIR STATION
MA
NPL
Weymouth and Abington arid Rockland
PEASE AIR FORCE BASE
NH
NPL
Portsmouth, Newington, and Greenland
LORING AIR FORCE BASE
ME
NPL
Limestone
STAMINA MILLS, INC.
RI
NFL
North Smithfield
FORT DEVENS-SUDBURY TRAINING ANNEX
MA
NPL
Sudbury and Maynard and 1 ludson and Stow
OTIS AIR NATIONAL GUARD BASE/CAMP EDWARDS
MA
NPL
Falmouth and Bourne arid Sandwich and Mashpee
FORT DEVENS
MA
NPL
Shirley, Ayer, Lancaster, 1 larvard
W. R- GRACE & CO., INC,(ACTON PLANT)
MA
NPL
Acton, Concord
HOCOMONCO POND
MA
NPL
Wi'stborough
SULLIVAN'S LEDGE
MA
NPL
New Bedford
HANSCOM F1ELD/HANSCOM AIR FORCE BASE
MA
NPL
Bedford, and Concord and Lexington and Lincoln
NYANZA CHEMICAL WASTE DUMP
MA
NPL
Ashland
NUCLEAR METALS
MA
NPL
Concord
FLETCHERS PAINT WORKS ii STORAGE
NH
NPL
Milford
MILTONJA MANAGEMENT INC.(GKEENIi TANNERY)
Nil
BF
Mitten
RAYMARK INDUSTRIES
cr
NPL
Stratford
Page 1 rsf 1
-------
Table 3 - Summary of Nationwide Superfund Landfills with Similar Contaminants
Site name
Town
State
Acres
Comtaminants
Selected ROD Remedy
Volnev Municipal Landfill
Volney
NY
85
VOCs, metals
Supplemental landfill cap construction
Old Springfield Landfill
Springfield
VT
10
vex;, PCB. PAH
Capping, Institutional controls
Osborne Landfill
Pine
PA
15
VOC, PCB, metals
Clay cap, public watcrline
Skinner Landfill
West Chester
OH
78
VOC, PCB, pest, metals, dioxins
Consolidation, RCRA Cap
Fresno Municipal Sanitary Landfill
Fresno
CA
145
VOC
Capping, gas and leachate collection
Algoma Landfill
Algoma
W1
13
VOC, metals
New landfill cap
Hunts Disposal Landfill
Racine
WI
35
VOC, PCB, metals
Multi-layer cap, fencing, gas collection
Nineteenth Avenue Landfill
Phoenix
AZ
213
VOC, PCB, pescticide
Clay cap
Purity Oil Sales
Fresno
CA
7
VOC, PCB, metals
RCRA cap
Schmalz Dump
Harrison
WI
0.75
PCB
Low-permeability cap
Tenth Street Dump
Oklahoma City
OK
3.5
PCB, VOC, TPH
Capping (as part of ROD amendment)
Global Sanitary Landfill
Old Bridge
N]
60
VOC
Landfill cap
Buckeye Reclamation
St. Clairsville
OH
50
Metals, VOC, PAH
Landfill cap
Colesville Municipal Landfill
Colesville
NY
30
VOCs
Landfill cap, public water
Burgess Brothers
Bennington
VT
3
VOC, metals
Landfill cap, SVE
Old Southington Landfill
Southington
CT
11
VOC
Consolidation, Capping
Kohler Company
Kohler
WI
82
VOC, PAH, PCB, metals
Multi-layer cap
Master Disposal Seervice Landfill
BrookfieJd
WI
26
VOC, metals
Clay cap
Red Oak City Landfill
Ret! Oak
IA
20
VOC, metals
Landfill cap
Northside Landfill
Spokane
WA
345
VOC
Public Water, landfill cap
Tomah Municipal Sanitary Landfill
Tomah
WI
18
VOC, metals
Multi-barrier cap (under presumptive remedy)
Central Landfill
Johnson
RI
121
VOC, metals
Landfill cap, institutional controls, gas collection
Kentucky Caliber Landfill
Maceo
KY
14
Landfill cap, leachate collection
Coakley Landfill
Greenland
NH
92
VOC, metals
Consolidation, Landfill cap, gas collection
Modem Sanitation
York
PA
72
VOC
Landfill cap, fencing
1 looker-102nd Street
Niagra Falls
NY
22
VOC, metals, pest, dioxins
Slurry wall, synthetic cap, fencing
Enviro-chem Corporation
Indianapolis
IN
6
VOC, metals
Landfill cap, SVE, GW extraction
Tri-County Landfill
South Elgin
IL
66
VOC, PCB, pest, metals
Impermeable cap, gas collection
Richardson Hill Road Landfill
Sidney Center
NY
8
VOC, PCB
Consolidation, landfill cap, GW treatment
Outboard Marine Corp
Waukegan
IL
PCB
Consolidation, dredging, capping
Oak Grove Sanitary Landfill
Oak Grove
MN
104
VOC, metals
Fencing, mulit-layer cap, deed restrictions
Rosen Brothers Scrap Yard
Cortland
NY
20
VOC, metals
Consolidation, capping
Page 1 of 1
-------
Tables
-------
Table 1 - Summary of Supetfuttd Landfills Nationwide
USEPA Superfund Information Systems - Records of Decision
Site Name
City
State
ABERDEEN PROVING GROUND (EDGEWOOD AREA)
EDGEWOOD
MD
ABERDEEN PROVING GROUND (EDGEWOOD AREA)
EDGEWOOD
MD
ADAK NAVAL AIR STATION
ADAK
AK
A1RCO
CALVERT CITY
KY
ALLIED PAPER, INC/PORTAGE CREEK/KALAMAZOO RIVER
KALAMAZOO
MI
ALLIED PAPER, INC/PORTAGE CREEK/KALAMAZOO RIVER
KALAMAZOO
Mt
AMOCO CHEMICALS (JOLIET LANDFILL)
JOLIET
IL
ARMY CREEK LANDFILL
NEWCASTLE
DE
AUBURN ROAD LANDFILL
LONDONDERRY
NH
B.F. GOODRICH
CALVERT CITY
KY
BARKHAMSTED-NEW HARTFORD LANDFILL
BARKHAMSTED
CT
BATAVtA LANDFILL
BATAVIA
NY
BEACON HEIGHTS LANDFILL
BEACON FALLS
CT
BERKLEY PRODUCTS CO. DUMP
DENVER
PA
BERKS LANDFILl.
SPRING TOWNSHIP
PA
BRANTLEY LANDFILL
ISLAND
KY
BROOKHAVEN NATIONAL LABORATORY (USDOE)
UPTON
NY
CALDWELL TRUCKING CO.
FAIRFIELD
NJ
CAMP PENDLETON MARINE CORPS BASF.
CAMP PENDLETON
CA
CASTLE AIR FORCE BASE (6 AREAS)
MERCED
CA
CENTRAL LANDFILL
JOHNSTON
RI
CHARLES-GEORGE RECLAMATION TRUST LANDFILL
TYNGSBOROUGH
MA
Cm' DISPOSAL CORP. LANDFILL
DUNN
Wt
COAKLEY LANDFILL
NORTH HAMPTON
Nil
COAL CREEK AKA ROSS ELECTRIC
CHEHALIS
WA
COMBE FILL SOUTH LANDFILL
CHESTER TOWNSHIP
NJ
COSHOCTON LANDFILL
FRANKLIN TOWNSHIP
OH
DAVISVILLE NAVAL CONSTRUCTION BATTALION CENTER
NORTH KINGSTOWN
Rl
DOUGLASS ROAD/UNtROYAI, 1NC„ LANDFILL
MISHAWAKA
IN
DOUGLASS KOAD/UNIROYA1, JNC„ LANDFILL
MISHAWAKA
IN
OUBLL k GARDNER LANDFILL
DALTON TOWNS! IIP
Ml
E.L DU PONT DE NEMOURS k CO., INC. (NEWPORT PIGMENT PLANT LANDFILL)
NEWPORT
DE
EASTERN DIVERSIFIED META1S
HOMETOWN
PA
F.L TORO MARINE CORPS AIR STATION
ELTORO
CA
ENDICOTl VILLAGE WELL FIELD
VILLAGE OF ENDICOTl'
NY
ENV1ROCHEM CORP.
ZlONSVILLE
IN
FA1RCHILD AIR FORCE BASE (4 WASTE AREAS)
SPOKANE
WA
FEED MATERIALS PRODUCTION CENTER (USDOE)
FERNALD
OH
FORT DEVENS
FORT DEVENS
MA
FORT DEVENS
FORT DEVENS
MA
FORT DEVENS-SUDBURY TRAINING ANNEX
SUDBURY
MA
FORT DIX (LANDFILL SITE)
PEMBERTON TOWNSHIP
NJ
FORT WA1NWRJGHT
FORT WA1NWRIGHT
AK
GLOBAL SANITARY LANDFILL
OLD BRIDGE TOWNSHIP
NJ
GLOBAL SANITARY LANDFILL
OLD BRIDGE TOWNSHIP
NJ
GOULD, INC.
PORTLAND
OR
GREEN RIVER DISPOSAL, INC.
MACEO
KY
GRIFFISS AIR FORCE BASE {11 AREAS)
ROME
NY
GR1FFJSS AIR FORCE BASE (11 AREAS)
ROME
NY-
GRIFFISS AIR FORCE BASE (11 AREAS)
ROME
NY
H.O.D. LANDFILL
ANTIOCH
IL
HANSCOM FIELD/HANSCOM AIR FORCE BASE
BEDFORD
MA
HIPPS ROAD LANDFILL
DUVALCOUNTY
FL
1IOCOMONCO POND
WESTBOROUGH
MA
HOOKER (102ND STREET)
NIAGARA FALLS
NY
IDAHO NATIONAL ENGINEERING LABORATORY (USDOE)
IDAHO FALLS
ID
INDUSTRIAL EXCESS LANDFILL
UNIONTOWN
OH
ISLIF MUNICIPAL SANITARY LANDFILL
ISLIP
NY
JACKSONVILLE NAVAL AIR STATION
JACKSONVILLE
FL
JANESVILLE ASH BEDS
JANESVILLE
W1
JANESVILLE OLD LANDFILL
JANESVILLE
WJ
JOLIET ARMY AMMUNITION PLANT (LOAD-ASSEMBLY-PACKING AREA)
JOLIET
IL
]'age 1 of 3
-------
Table 1 - Summary of Superfund Landfills Nationwide
USEPA Superfund Information Systems - Records of Decision
Site Name
City
State
JOL1ET ARMY AMMUNITION PLANT (MANUFACTURING AREA)
JOL1GT
IL
JUNCOS LANDFILL
JUNCOS
PR
KM. AVENUE LANDFILL
OSHTEMO TOWNSHIP
Ml
K&L AVENUE LANDFILL
OSHTEMO TOWNSHIP
MI
KOHLER CO. LANDFILL
KOHLER
W1
LAKE SANDY JO (M&M LANDFILL)
GARY
IN
LAUREL PARK, INC.
NAUGATUCK BOROUGH
cr
LEE'S LANE LANDFILL
LOUISVILLE
KY
LORING AIR FORCE BASE
LIMESTONE
ME
LORING AIR FORCE BASE
LIMESTONE
ME
LOWRY LANDFILL
AURORA
CO
MARION (BRAGG) DUMP
MARION
IN
MASTER DISPOSAL SERVICE LANDFILL
BROOKFIELD
WI
MATHER AIR FORCE BASE (AC&W DISPOSAL SITE)
MATHER
CA
MITAMORA LANDFILL
METAMORA
MI
METAMORA LANDFILL
METAMORA
MI
MICHIGAN DISPOSAL SERVICE (CORK STREEF LANDFILL)
KALAMAZOO
Ml
MID-SOUT1I WOOD PRODUCTS
MENA
AR
MIG/DEWANK LANDFILL
BELVIDERE
IL
MINOT LANDFILL
MINOT
ND
MODERN SANITATION LANDFILL
LOWER WINDSOR TWF
PA
MOFFETT NAVAL AIR STATION
MOFFETT FIELD
CA
MOFFETT NAVAL AIR STATION
MOFFETT FIELD
CA
MOSLEY ROAD SANITARY LANDFILL
OKLAHOMA CITY
OK
N.W. MAUTHE CO., INC.
AITUTON
WI
NAVAL AIR STATION, WHIDBEY 1SIAND (AULT FIELD)
WHJDBEY ISLAND
WA
NAVAL AIR STATION, WHIDBEY ISLAND (AULT FIELD)
WHIDBEY ISLAND
WA
NAVAL TRAINING CENTER BAfNBRlDCE
CAMBRIDGE
MD
NAVAL WEAPONS STATION EARLE (SITE A)
COLTS NECK
N1
MEALS LANDFILL (BLOOMINGTON)
BLOOMINGTON
IN
NEWPORT NAVAL EDUCATION & TRAINING CENTER
NEWPORT
RI
NIAGARA COUNTY REFUSE
WHEATFIELD
NY
NORFOLK NAVAL BASE (SEWELLS POINT NAVAL COMPLEX)
NORFOLK
VA
NORTH SEA MUNICIPAL LANDFILL
NORTH SEA
NY
NORTHS!DE LANDFILL
SPOKANE
WA
OLD BETHPAGE LANDFILL
OYSTER BAY
NY
OLD NAVY DUMP/MANCHESTER LABORATORY (USEPA/NOAA)
MANCHESTER
WA
OLD SOUTHINGTON LANDFILL
SOUTHINGTON
cr
ORDNANCE WORKS DISPOSAL AREAS
MORGANTOWN
wv
ORDNANCE WORKS DISPOSAL AREAS
MORGANTOWN
wv
ORDNANCE WORKS DISPOSAL ARIAS
MORGANTOWN
WV
ORDOT LANDFILL
AGANA
GU
OTT/STORY/CORDOVA CHEMICAL CO.
DALTON TOWNSHIP
Ml
PAGEL'S PIT
ROCKFORD
IL
PEASE AIR FORCE BASE
PORTSMOUTH/NEWINGTON
NH
PLATTSBURGH AIR FORCE BASE
PLATTSBURGH
NY
PLATTSBURGH AIR FORCE BASE
PLATTSBURGH
NY
PLATTSBURGH AIR FORCE BASE
PLATTSBURGH
NY
PLATTSBURGH AIR FORCE BASE
PLATTSBURGH
NY
PORT HADLOCK DETACHMENT (USNAVY)
INDIAN ISLAND
WA
PORT WASHINGTON LANDFILL
PORT WASHINGTON
NY
RED OAK CITY LANDFILL
RED OAK
IA
RED PENN SANITATION CO. LANDFILL
PEEWEE VALLEY
KY
REFUSE HIDEAWAY LANDFILL
M3DDLETON
WI
RESIN DISPOSAL
JEFFERSON BOROUGH
PA
RIPGN CITY LANDFILL
FOND DU LAC COUNTY
WI
ROCKWELL INTERNATIONAL CORP. (ALLEGAN PLANT)
ALLEGAN
MI
ROSE HILL REGIONAL LANDFILL
SOUTH KINGSTOWN
RI
RSR CORPORATION
DALLAS
TX
SANGAMO ELECTRIC DUMP/CRAB ORCHARD NATIONAL WILDLIFE REFUGE
CARTERVILLE
IL
SAUK COUNTY' LANDFILL
EXCELSIOR
WI
SINCLAIR REFINERY
WF.LLSVILLE
NY
Page 2 of 3
-------
Table 1 - Summary of Superfund Landfills Nationwide
USEPA Superfund Information Systems - Records of Decision
Site Name
City
State
SMITHS FARM
BROOKS
KY
SMUGGLER MOUNTAIN
ASPEN
CO
SOUTH BRUNSWICK LANDFILL
SOUTH BRUNSWICK
NJ
SPARTA LANDFILL
SPARTA TOWNSHIP
MI
SPICKLEK LANDFILL
SPENCER
WI
SfRASBURG LANDFILL
NEWLIN TOWNSHIP
PA
SYOSSET LANDFILL
OYSTER BAY
NY
TEX-TIN CORP.
TEXAS CITY
TX
TOMAH MUNICIPAL SANITARY LANDFILL
TOMAH
WI
TULALIP LANDFILL
MARYSVILLE
WA
UNITED SCRAP LEAD CO., INC.
TROY
OH
WALSH LANDFILL
HONEYBROOK TOWNSHIP
PA
WARWICK LANDFILL
WARWICK
NY
WASTE, INC., LANDFILL
MICHIGAN CITY
IN
WAUCONDA SAND k GRAVEL
WAUCONDA
II.
WAYNE WASTE OIL
COLUMBIA CITY
IN
WHITEHOUSE OIL PITS
WHITE HOUSE
FL
WILDCAT LANDFILL
DOVER
DE
WINDOW DUMP
WINDOM
MN
WOODSTOCK MUNICIPAL LANDFILL
WOODSTOCK
IL
WOODSTOCK MUNICIPAL LANDFILL
WOODSTOCK
IL
WRIGHT-PATTERSON AIR FORCE BASE
DAYTON
OH
WRIGHT-PATTERSON AIR FORCE BASE
DAYTON
Oil
hfctp://cfpub,epa,gov/superrods/srch.cftri?keys=Iandfi]!%20k:appLrigiScftrstTime=Yes^cCFlD-l5360485^CFTOkEN-S7469l54
Page 3 of 3
-------
Comments to The US EPA on the June 2004 Proposed Plan For the Cleanup of
The Shpack Superfund Site. Norton/Attleboro, MA
To Dave Lederer
U.S. EPA
One Congress St., Suite 1100 (HBO)
Boston, MA 02114
Deadline - Postmarked By Wednesday, August 25, 2004
FAX (617) 918 - 1291, No Later Than Wednesday, August 25, 2004
August 2004
1 am writing to express my firm opposition to the EPA's proposed plan for the 'cleanup5
of the Shpaek Superfund Site.
EPA's preferred alternative (SC-2b) is unacceptable for reasons too numerous to detail
here. Most objectionable is the fact this option does not provide "permanence" and is
therefore not a "remedy". It would leave the Town of Norton with a still contaminated
site, and the responsibility & burdens of dealing with it, in the near and distant future.
In the face of the promise the Environmental Protection Agency made to the town,
EPA's chosen course of action, is reprehensible.
If community acceptance, plays any role in the EPA's decision making process for the
cleanup of Shpack, please give serious consideration to these comments, and select
Alternative SC-3b, which will at long last, give residents of this community the peace of
mind they deserve.
Prim Name f/lo H/~
Address
-------
Comments to The US EPA on the June 2004 Proposed Plan For the Cleanup of
The Shpack Superfund Site, Norton/Attleboro, MA
To Dave Lederer
U.S. EPA
One Congress St, Suite 1100 (HBO)
Boston, MA 02114
Deadline - Postmarked By Wednesday, August 25, 2004
FAX (617) 918 - 1291, No Later Than Wednesday, August 25, 2004
August 2004
I am writing to express my firm opposition to the EPA's proposed plan for the 'cleanup'
of the Shpack Superfund Site.
EPA's preferred alternative (SC-2b) is unacceptable for reasons too numerous to detail
here. Most objectionable is the fact this option does not provide "permanence" and is
therefore not a "remedy". It would leave the Town of Norton with a still contaminated
site, and the responsibility & burdens of dealing with it, in the near and distant future.
In the face of the promise the Environmental Protection Agency made to the town,
EPA's chosen course of action, is reprehensible.
If community acceptance, plays any role in the EPA's decision making process for the
cleanup of Shpack, please give serious consideration to these comments, and select
Alternative SC-3b, which will at long last, give residents of this community the peace of
mind they deserve.
Signature
Print Name
Address [ f cA
-------
Comments to The US EPA on the June 2004 Proposed Plan For the Cleanup of
The Shpack Superfund Site, Norton/Attleboro, MA
To Dave Lederer
U.S. EPA
One Congress St., Suite 1100 (HBO)
Boston, MA 02114
Deadline - Postmarked By Wednesday, August 25, 2004
FAX (617) 918 - 1291, No Later Than Wednesday, August 25,2004
August 2004
I am writing to express my firm opposition to the EPA's proposed plan for the 'cleanup'
of the Shpaek Superfund Site.
EPA's preferred alternative (SC-2b) is unacceptable for reasons too numerous to detail
here. Most objectionable is the fact this option does not provide "permanence" and is
therefore not a "remedy". It would leave the Town of Norton with a still contaminated
site, and the responsibility & burdens of dealing with it, in the near and distant future.
In the face of the promise the Environmental Protection Agency made to the town,
EPA's chosen course of action, is reprehensible.
If community acceptance, plays any role in the EPA's decision making process for the
cleanup of Shpack. please give serious consideration to these comments, and select
Alternative SC-3b, which will at long last, give residents of this community the peace of
mind they deserve.
Print Name
Signature
Address
P
-------
Comments to The US EPA on the June 2004 Proposed Plan For the Cleanup of
The Shpack Superfund Site. Norton/Attleboro, MA
To Dave Lederer
U.S. EPA
One Congress St., Suite 1100 (HBO)
Boston, MA 02114
Deadline - Postmarked By Wednesday, August 25, 2004
FAX (617)918- 1291, No Later Than Wednesday, August 25,2004
August 2004
I am writing to express my firm opposition to the EPA's proposed plan for the 'cleanup*
of the Shpack Superfund Site,
EPA's preferred alternative (SC-2b) is unacceptable for reasons too numerous to detail
here. Most objectionable is the fact this option does not provide "permanence" and is
therefore not a "remedy". It would leave the Town of Norton with a still contaminated
site, and the responsibility & burdens of dealing with it, in the near and distant future.
In the face of the promise the Environmental Protection Agency made to the town,
EPA's chosen course of action, is reprehensible.
If community acceptance, plays any role in the EPA's decision making process for the
cleanup of Shpack, please give serious consideration to these comments, and select
Alternative SC-3b, which will at long last, give residents of this community the peace of
mind they deserve.
Print Name HC^Oe
Address
\(X V,ston f, C)LST)H
-------
Comments to The US EPA on the June 2004 Proposed Plan For the Cleanup of
The Shpack Superfund Site, Norton/Attleboro, MA
To Dave Lederer
U.S. EPA
One Congress St., Suite 1100 (HBO)
Boston, MA 02114
Deadline - Postmarked By Wednesday, August 25, 2004
FAX (617) 918 - 1291, No later Than Wednesday, August 25,2004
August 2004
I am writing to express my firm opposition to the EPA's proposed plan for the 'cleanup'
of the Shpack Superfund Site,
EPA's preferred alternative (SC-2b) is unacceptable for reasons too numerous to detail
here. Most objectionable is the fact this option does not provide "permanence" and is
therefore not a "remedy". It would leave the Town of Norton with a still contaminated
site, and the responsibility & burdens of dealing with it, in the near and distant future.
In the face of the promise the Environmental Protection Agency made to the town,
EPA's chosen course of action, is reprehensible.
If community acceptance, plays any role in the EPA's decision making process for the
cleanup of Shpack, please give serious consideration to these comments, and select
Alternative SC-3b, which will at long last, give residents of this community the peace of
mind they deserve.
Signature
Print Name
Address \\7
-------
Comments to The US EPA on the June 2004 Proposed Plan For the Cleanup of
The Shpaek Superfund Site, Norton/Attleboro, MA
To Dave Lederer
U.S. EPA
One Congress St., Suite 1100 (HBO)
Boston, MA 02114
Deadline - Postmarked By Wednesday, August 25, 2004
FAX (617) 918 - 1291, No Later Than Wednesday, August 25, 2004
August 2004
I am writing to express my firm opposition to the EPA's proposed plan for the 'cleanup'
of the Shpaek Superfund Site.
EPA's preferred alternative (SC-2b) is unacceptable for reasons too numerous to detail
here. Most objectionable is the fact this option does not provide "permanence" and is
therefore not a "remedy". It would leave the Town of Norton with a still contaminated
site, and the responsibility & burdens of dealing with it, in the near and distant future.
In the face of the promise the Environmental Protection Agency made to the town,
EPA's chosen course of action, is reprehensible.
If community acceptance, plays any role in the EPA's decision making process for the
cleanup of Shpaek, please give serious consideration to these comments, and select
Alternative SC-3b, which will at long last, give residents of this community the peace of
mind they deserve.
Print Name r
y/^ts-y
-------
»
Comments to The US EPA on the June 2004 Proposed Plan For the Cleanup of
The Shpack Superfund Site, Norton/Attieboro, MA
To Dave Lederer
U.S. EPA
One Congress St., Suite 1100 (HBO)
Boston, MA 02114
Deadline - Postmarked By Wednesday, August 25, 2004
FAX (61?) 918 - 1291, No Later Than Wednesday, August 25, 2004
August 2004
I am writing to express my firm opposition to the EPA's proposed plan for the 'cleanup*'
of the Shpack Superfund Site.
EPA's preferred alternative (SC-2b) is unacceptable for reasons too numerous to detail
here. Most objectionable is the fact this option does not provide "permanence" and is
therefore not a "remedy". It would leave the Town of Norton with a still contaminated
site, and the responsibility & burdens of dealing with it, in the near and distant future.
In the face of the promise the Environmental Protection Agency made to the town,
EPA's chosen course of action, is reprehensible.
If community acceptance, plays any role in the EPA's decision making process for the
cleanup of Shpack, please give serious consideration to these comments, and select
Alternative SC-3b, which will at long last, give residents of this community the peace of
mind they deserve.
Signature
Print Name
Address
-------
Comments to The US EPA on the June 2004 Proposed Plan For the Cleanup of
The Shpack Superfund Site, Norton/Attleboro, MA
To Dave Lederer
U.S. EPA
One Congress St., Suite 1100 (HBO)
Boston, MA 02114
Deadline - Postmarked By Wednesday, August 25, 2004
FAX (617) 918 - 1291, No Later Than Wednesday, August 25, 2004
August 2004
i am writing to express my firm opposition to the EPA's proposed plan for the 'cleanup'
of the Shpack Superfund Site.
EPA's preferred alternative (SC-2b) is unacceptable for reasons too numerous to detail
here. Most objectionable is the fact this option does not provide "permanence" and is
therefore not a "remedy". It would leave the Town of Norton with a still contaminated
site, and the responsibility & burdens of dealing with it, in the near and distant future.
In the face of the promise the Environmental Protection Agency made to the town,
EPA's chosen course of action, is reprehensible.
If community acceptance, plays any role in the EPA's decision making process for the
cleanup of Shpack, please give serious consideration to these comments, and select
Alternative SC-3b, which will at long last, give residents of this community the peace of
mind they deserve.
Signature
Print Name
Address
' \oh ££
1fffl^aaaaaaa^iaaaaaaaijyaaaaaaaaaaaaaaaaaaaaaaaatj^^^
-------
Comments to The US EPA on the June 2004 Proposed Plan For the Cleanup of
The Shpack Superfund Site, Norton/Attleboro, MA
To Dave Lederer
U.S. EPA
One Congress St., Suite 1100 (HBO)
Boston, MA 02114
Deadline - Postmarked By Wednesday, August 25, 2004
FAX (617) 918 - 1291, No Later Than Wednesday, August 25, 2004
August 2004
I am writing to express my firm opposition to the EPA's proposed plan for the 'cleanup'
of the Shpack Superfund Site.
EPA's preferred alternative (SC-2b) is unacceptable for reasons too numerous to detail
here. Most objectionable is the fact this option does not provide "permanence" and is
therefore not a "remedy". It would leave the Town of Norton with a still contaminated
site, and the responsibility & burdens of dealing with it, in the near and distant future.
In the face of the promise the Environmental Protection Agency made to the town,
EPA's chosen course of action, is reprehensible.
if community acceptance, plays any role in the EPA's decision making process for the
cleanup of Shpack, please give serious consideration to these comments, and select
Alternative SC-3b, which will at long last, give residents of this community the peace of
mind they deserve.
Print Name
Address
nft, Mfl.A shfp.-f
-------
Comments to The US EPA on the June 2004 Proposed Plan For the Cleanup of
The Shpack Superftmd Site, Norton/Attleboro, MA
To Dave Lederer
U.S. EPA
One Congress St., Suite 1100 (HBO)
Boston, MA 02114
Deadline - Postmarked By Wednesday, August 25, 2004
FAX (617) 918 - 1291, No Later Than Wednesday, August 25, 2004
August 2004
I am writing to express ray firm opposition to the EPA's proposed plan for the 'cleanup'
of the Shpack Superftmd Site.
EPA's preferred alternative (SC-2b) is unacceptable for reasons too numerous to detail
here. Most objectionable is the fact this option does not provide "permanence" and is
therefore not a "remedy". It would leave the Town of Norton with a still contaminated
site, and the responsibility & burdens of dealing with it, in the near and distant future.
In the face of the promise the Environmental Protection Agency made to the town,
EPA's chosen course of action, is reprehensible.
If community acceptance, plays any role in the EPA's decision making process for the
cleanup of Shpack, please give serious consideration to these comments, and select
Alternative SC-3b, which will at long last, give residents of this community the peace of
mind they deserve.
Stem, S?
Print Name M, rA*** / sf X
Address O Robe- f is Tf
j/y/rtonsock rh
-------
Comments to The US EPA on the June 2004 Proposed Plan For the Cleanup of
The Shpack Superfund Site, Norton/Attleboro, MA
To Dave Lederer
U.S. EPA
One Congress St,, Suite 1100 (HBO)
Boston, MA 02114
Deadline - Postmarked By Wednesday, August 25,2004
FAX (617) 918 - 1291, Ho Later Than Wednesday, August 25, 2004
August 2004
I am writing to express my firm opposition to the EPA's proposed plan for the 'cleanup'
of the Shpack Superfund Site.
EPA's preferred alternative (SC-2b) is unacceptable for reasons too numerous to detail
here. Most objectionable is the fact this option does not provide "permanence" and is
therefore not a "remedy". It would leave the Town of Norton with a still contaminated
site, and the responsibility & burdens of dealing with it, in the near and distant future.
Jn the face of the promise the Environmental Protection Agency made to the town,
EPA's chosen course of action, is reprehensible.
If community acceptance, plays any role in the EPA's decision making process for the
cleanup of Shpack, please give serious consideration to these comments, and select
Alternative SC-3b, which will at long last, give residents of this community the peace of
mind they deserve.
ddress
-------
Comments to The US EPA on the June 2004 Proposed Plan For the Cleanup of
The Shpack Superfund Site, Norton/Attleboro, MA
To Dave Lederer
U.S. EPA
One Congress St., Suite 1100 (HBO)
Boston, MA 02114
Deadline - Postmarked By Wednesday, August 25, 2004
PAX (617) 918 - 1291, No Later Than Wednesday, August 25, 2004
August 2004
I am writing to express my firm opposition to the EPA's proposed plan for the 'cleanup'
of the Shpack Superfund Site.
EPA's preferred alternative (SC-2b) is unacceptable for reasons too numerous to detail
here. Most objectionable is the fact this option does not provide "permanence" and is
therefore not a "remedy". It would leave the Town of Norton with a still contaminated
site, and the responsibility & burdens of dealing with it, in the near and distant future.
In the face of the promise the Environmental Protection Agency made to the town,
EPA's chosen course of action, is reprehensible.
If community acceptance, plays any role in the EPA's decision making process for the
cleanup of Shpack, please give serious consideration to these comments, and select
Alternative SC-3b, which will at long last, give residents of this community the peace of
mind they deserve.
Address / *) M&de Q uC
0 oOofocK
-------
Comments to The US EPA on the June 2004 Proposed Plan For the Cleanup of
The Shpack Superfund Site, Norton/Attleboro, MA
To Dave Lederer
U.S. EPA
One Congress St,, Suite 1100 (HBO)
Boston, MA 02114
Deadline - Postmarked By Wednesday, August 25, 2004
_ FAX (617) 918 - 1291, No Later Than Wednesday, August 25, 2004
August 2004
I am writing to express my firm opposition to the EPA's proposed plan for the 'cleanup'
of the Shpack Superfund Site.
EPA's preferred alternative (SC-2b) is unacceptable for reasons too numerous to detail
here. Most objectionable is the fact this option does not provide "permanence" and is
therefore not a "remedy". It would leave the Town of Norton with a still contaminated
site, and the responsibility & burdens of dealing with it, in the near and distant future.
In the face of the promise the Environmental Protection Agency made to the town,
EPA's chosen course of action, is reprehensible.
If community acceptance, plays any role in the EPA's decision making process for the
cleanup of Shpack, please give serious consideration to these comments, and select
Alternative SC-3b, which will at long last, give residents of this community the peace of
mind they deserve.
Signature
'Jhyyiunet-
Print Name
Address
e. Linda- Pl^rAiiyct
a-
4D a)- alrimJMfH
-------
Comments to The US EPA on the June 2004 Proposed Plan For the Cleanup of
The Shpaek Superfund Site, Norton/Attleboro, MA
To Dave Lederer
U.S. EPA
One Congress St., Suite 1100 (HBO)
Boston, MA 02114
Deadline - Postmarked By Wednesday, August 25,2004
FAX (617) 918 - 1291, No Later Than Wednesday, August 25, 2004
August 2004
I am writing to express my firm opposition to the EPA's proposed plan for the 'cleanup'
of the Shpaek Superfund Site.
EPA's preferred alternative (SC-2b) is unacceptable for reasons too numerous to detail
here. Most objectionable is the fact this option does not provide "permanence" and is
therefore not a "remedy". It would leave the Town of Norton with a still contaminated
site, and the responsibility & burdens of dealing with it, in the near and distant future.
In the face of the promise the Environmental Protection Agency made to the town,
EPA's chosen course of action, is reprehensible.
If community acceptance, plays any role in the EPA's decision making process for the
cleanup of Shpaek, please give serious consideration to these comments, and select
Alternative SC-3b, which will at long last, give residents of this community the peace of
mind they deserve.
Signatur
cr
Address
Mh OclQ3t
-------
Comments to The US EPA on the June 2004 Proposed Plan For the Cleanup of
'File Shpack Superfund Site, Norton/Attleboro, MA
To Dave Ledcrer
U.S. EPA
One Congress St., Suite 1 100 (HBO)
Boston, MA 02114
Deadline - Postmarked By Wednesday, August 25, 2004
/AX (617)918- 1291, No Later Than Wednesday, August 25,2004
August 2004
I am writing to express my firm opposition to the EPA's proposed plan for the 'cleanup5
of the Shpack Superfund Site,
EPA's preferred alternative (SC-2b) is unacceptable for reasons too numerous to detail
here. Most objectionable is the fact this option does not provide "permanence" and is
therefore not a "remedy". It would leave the Town of Norton with a still contaminated
site, and the responsibility & burdens of dealing with it, in the near and distant future.
In the face of the promise the Environmental Protection Agency made to the town,
EPA's chosen course of action, is reprehensible.
If community acceptance, plays any role in the EPA's decision making process for the
cleanup of Shpack, please give serious consideration to these comments, and select
Alternative SC-3b, which will at long last, give residents of this community the peace of
mind they deserve.
Print Name
Address
-------
Comments to The US EPA on the June 2004 Proposed Plan For the Cleanup of
The Shpack Superfund Site, Norton/Attleboro, MA
To Dave I.ederer
U.S. EPA
One Congress St., Suite 1100 (HBO)
Boston, MA 02114
Deadline - Postmarked By Wednesday, August 25, 2004
FAX (617) 918 - 1291, No Later Than Wednesday, August 25, 2004
August 2004
I am writing to express my firm opposition to the EPA's proposed plan for the 'cleanup'
of the Shpack Superfund Site.
EPA's preferred alternative (SC-2b) is unacceptable for reasons too numerous to detail
here. Most objectionable is the fact this option does not provide "permanence" and is
therefore not a "remedy". It would leave the Town of Norton with a still contaminated
site, and the responsibility & burdens of dealing with it, in the near and distant future.
In the face of the promise the Environmental Protection Agency made to the town,
EPA's chosen course of action, is reprehensible.
If community acceptance, plays any role in the EPA's decision making process for the
cleanup of Shpack, please give serious consideration to these comments, and select
Alternative SC-3b, which will at long last, give residents of this community the peace of
mind they deserve.
Signature
Print Name
Address
jA-iuatJm mfi Qdo3a
-------
Comments to The US EPA on the June 2004 Proposed Plan For the Cleanup of
The Shpack Superfund Site, Norton/Attleboro, MA
To Dave Lederer
U.S. EPA
One Congress St., Suite 1100 (HBO)
Boston, MA 02114
Deadline - Postmarked By Wednesday, August 25, 2004
FAX (617) 918 - 1291, No Later Than Wednesday, August 25,2004
August 2004
I am writing to express my firm opposition to the EPA's proposed plan for the 'cleanup'
of the Shpack Superfund Site.
EPA's preferred alternative (SC-2b) is unacceptable for reasons too numerous to detail
here. Most objectionable is the fact this option does not provide "permanence" and is
therefore not a "remedy". It would leave the Town of Norton with a still contaminated
site, and the responsibility & burdens of dealing with it, in the near and distant future.
In the face of the promise the Environmental Protection Agency made to the town,
EPA's chosen course of action, is reprehensible.
If community acceptance, plays any role in the EPA's decision making process for the
cleanup of Shpack, please give serious consideration to these comments, and select
Alternative SC-3b, which will at long last, give residents of this community the peace of
mind they deserve.
Signature
Print Name DlMraJO l)cLf)fM
Address PUMP
fmAMJ in PDA c&CtiR
-------
Comments to The US EPA on the June 2004 Proposed Plan For the Cleanup of
The Shpack Superfund Site, Norton/Attleboro, MA
To Dave Lederer
U.S. EPA
One Congress St., Suite 1100 (HBO)
Boston, MA 02114
Deadline - Postmarked By Wednesday, August 25, 2004
FAX (617) 918 - 1291, No Later Than Wednesday, August 25,2004
August 2004
I am writing to express my firm opposition to the EPA's proposed plan for the 'cleanup'
of the Shpack Superfund Site.
EPA's preferred alternative (SC-2b) is unacceptable for reasons too numerous to detail
here. Most objectionable is the fact this option does not provide "permanence" and is
therefore not a "remedy". It would leave the Town of Norton with a still contaminated
site, and the responsibility & burdens of dealing with it, in the near and distant future.
In the face of the promise the Environmental Protection Agency made to the town,
EPA's chosen course of action, is reprehensible.
If community acceptance, plays any role in the EPA's decision making process for the
cleanup of Shpack, please give serious consideration to these comments, and select
Alternative SC-3b, which will at long last, give residents of this community the peace of
mind they deserve.
Signature
Print Name
HZjtbe-i bllnliln
Address
16 btbOiXi Dfa'-o
frani/lm mW
-------
Comments to The US EPA on the June 2004 Proposed Plan For the Cleanup of
The Shpack Superfirod Site, Norton/Attleboro, MA
To Dave Lederer
U.S. EPA
One Congress St., Suite 1100 (11130)
Boston, MA 02114
Deadline - Postmarked By Wednesday, August 25, 2004
FAX (617)918- 1291, No Later Than Wednesday, August 25,2004
August 2004
I am writing to express my firm opposition to the EPA's proposed plan for the 'cleanup'
of the Shpack Superfund Site.
EPA's preferred alternative (SC-2b) is unacceptable for reasons too numerous to detail
here. Most objectionable is the fact this option does not provide "permanence" and is
therefore not a "remedy". It would leave the Town of Norton with a still contaminated
site, and the responsibility & burdens of dealing with it, in the near and distant future.
In the face of the promise the Environmental Protection Agency made to the town,
EPA's chosen course of action, is reprehensible.
If community acceptance, plays any role in the EPA's decision making process for the
cleanup of Shpack, please give serious consideration to these comments, and select
Alternative SC-3b, which will at long last, give residents of this community the peace of
mind they deserve.
Signature
Print Name
Si—-
ftShW. Wnrllo
Address
15 OxbQiQ bf
\Uta\ it Jin it^i
I
-------
Comments to The US EPA on the June 2004 Proposed Plan For the Cleanup of
The Shpack Superfund Site, Norton/Attleboro, MA
To Dave Lederer
U.S. EPA
One Congress St., Suite 1100 (HBO)
Boston, MA 02114
Deadline - Postmarked By Wednesday, August 25, 2004
FAX (6)7) 918 - 1291, No Later Than Wednesday, August 25, 2004
August 2004
I am writing to express my firm opposition to the EPA's proposed plan for the 'cleanup1
of the Shpaek Superfund Site.
EPA's preferred alternative (SC-2b) is unacceptable for reasons too numerous to detail
here. Most objectionable is the fact this option does not provide "permanence" and is
therefore not a "remedy". It would leave the Town of Norton with a still contaminated
site, and the responsibility & burdens of dealing with it, in the near and distant future,
in the face of the promise the Environmental Protection Agency made to the town,
EPA's chosen course of action, is reprehensible.
If community acceptance, plays any role in the EPA's decision making process for the
cleanup of Shpack, please give serious consideration to these comments, and select
Alternative SC-3b, which will at long last, give residents of this community the peace of
mind they deserve.
Signature
Print Name
Uui Pa-o-^HQ
Address
QxjppcO DoVe.
frajg x i i n mft
MMkBBBBBBBBiaa|||MH|aaaMlaiaiaia^£aaiaaaaagggiaHaHai^
-------
Comments to The US EPA on the June 2004 Proposed Plan For the Cleanup of
The Shpack Superfund Site, Norton'Attleboro, MA
To Dave Lederer
U.S. EPA
One Congress St,, Suite 1100 (HBO)
Boston, MA 02114
Deadline - Postmarked By Wednesday, August 25, 2004
FAX (617)918- 1291, No Later Than Wednesday, August 25, 2004
August 2004
I am writing to express my firm opposition to the EPA's proposed plan for the 'cleanup'
of the Shpack Superfund Site,
EPA's preferred alternative (SC-2b) is unacceptable for reasons too numerous to detail
here. Most objectionable is the fact this option does not provide "permanence" and is
therefore not a "remedy". It would leave the Town of Norton with a still contaminated
site, and the responsibility & burdens of dealing with it, in the near and distant future,
In the face of the promise the Environmental Protection Agency made to the town,
EPA's chosen course of action, is reprehensible.
if community acceptance, plays any role in the EPA's decision making process for the
cleanup of Shpack, please give serious consideration to these comments, and select
Alternative SC-3b, which will at long last, give residents of this community the peace of
mind they deserve.
Print Name /Ss? b / / S A P^9 / 2. !/
Address l\t#E Sr krM 3h ~fl(TV \
\p£fy^orte ii Od^ST
-------
Comments to The US EPA on the June 2004 Proposed Plan For the Cleanup of
The Shpack Superfund Site, Norton/Attleboro, MA
To Dave Lederer
U.S. EPA
One Congress St., Suite 1100 (HBO)
Boston. MA 02114
Deadline - Postmarked By Wednesday, August 25, 2004
FAX (617) 918 - 1291, No Later Than Wednesday, August 25, 2004
August 2004
I am writing to express my firm opposition to the EPA's proposed plan for the 'cleanup'
of the Shpack Superfund Site.
EPA's preferred alternative (SC-2b) is unacceptable for reasons too numerous to detail
here. Most objectionable is the fact this option does not provide "permanence" and is
therefore not a "remedy". It would leave the Town of Norton with a still contaminated
site, and the responsibility & burdens of dealing with it, in the near and distant future.
In the face of the promise the Environmental Protection Agency made to the town,
EPA's chosen course of action, is reprehensible.
If community acceptance, plays any role in the EPA's decision making process for the
cleanup of Shpack, please give serious consideration to these comments, and select
Alternative SC-3b, which will at long last, give residents of this community the peace of
mind they deserve.
Signature ^
Print Name Pf£M^ £>& /?&&&-/#-
Address / ^ j/O& £ ? S »
-------
Comments to The US EPA on the June 2004 Proposed Plan For the Cleanup of
The Shpack Superfund Site, Norton/Attleboro, MA
To Dave Lederer
U.S. EPA
One Congress St., Suite 1100 (HBO)
Boston, MA 02114
Deadline - Postmarked By Wednesday, August 25, 2004
FAX (617) 918— 1291, No Later Than Wednesday, August 25, 2004
August 2004
I am writing to express my firm opposition to the EPA's proposed plan for the 'cleanup'
of the Shpack Superfund Site.
EPA's preferred alternative (SC-2b) is unacceptable for reasons too numerous to detail
here. Most objectionable is the fact this option does not provide "permanence" and is
therefore not a "remedy". It would leave the Town of Norton with a still contaminated
site, and the responsibility & burdens of dealing with it, in the near and distant future.
In the face of the promise the Environmental Protection Agency made to the town,
EPA's chosen course of action, is reprehensible.
If community acceptance, plays any role in the EPA's decision making process for the
cleanup of Shpack, please give serious consideration to these comments, and select
Alternative SC-3b, which will at long last, give residents of this community the peace of
mind they deserve.
Signature
PrintName
~x
Address
-------
Comments to The US EPA on the June 2004 Proposed Plan For the Cleanup of
The Shpack Super-fund Site, Norton/Attleboro, MA
To Dave Lederer
U.S. EPA
One Congress St., Suite 1100 (HBO)
Boston, MA 02114
Deadline - Postmarked By Wednesday, August 25, 2004
> FAX (617) 918 - 1291, No Later Than Wednesday, August 25, 2004
August 2004
I am writing to express my firm opposition to the EPA's proposed plan for the 'cleanup'
of the Shpack Superfund Site.
EPA's preferred alternative (SC-2b) is unacceptable for reasons too numerous to detail
here. Most objectionable is the fact this option does not provide "permanence" and is
therefore not a "remedy". It would leave the Town of Norton with a still contaminated
site, and the responsibility & burdens of dealing with it, in the near and distant future.
In the face of the promise the Environmental Protection Agency made to the town,
EPA's chosen course of action, is reprehensible.
If community acceptance, plays any role in the EPA's decision making process for the
cleanup of Shpack, please give serious consideration to these comments, and select
Alternative SC-3b, which will at long last, give residents of this community the peace of
mind they deserve.
Signature
rf- ar-""
Print Name
D/P&fcl
Address ^o i J I ^ VV Of S>f~
A/or-hy^ /Yl/I Q31UC,
-------
Comments to The US EPA on the June 2004 Proposed Plan For the Cleanup of
The Shpack Superfund Site, Norton/Attleboro, MA
To Dave Lederer
U.S. EPA
One Congress St., Suite 1100 (HBO)
Boston, MA 02114
Deadline - Postmarked By Wednesday, August 25,2004
FAX (617)918 - 1291, No Later Than Wednesday, August 25,2004
August 2004
I am writing to express my firm opposition to the EPA's proposed plan for the 'cleanup'
of the Shpack Superfund Site.
EPA's preferred alternative (SC-2b) is unacceptable for reasons too numerous to detail
here. Most objectionable is the fact this option does not provide "permanence" and is
therefore not a "remedy". It would leave the Town of Norton with a still contaminated
site, and the responsibility & burdens of dealing with it, in the near and distant future.
In the face of the promise the Environmental Protection Agency made to the town,
EPA's chosen course of action, is reprehensible.
If community acceptance, plays any role in the EPA's decision making process for the
cleanup of Shpack, please give serious consideration to these comments, and select
Alternative SC-3b, which will at long last, give residents of this community the peace of
mind they deserve.
Print Name
Signature f
7
Address
-------
Comments to The US EPA on the June 2004 Proposed Plan For the Cleanup of
Hie Shpack Superfiznd Site, Norton/A ttleboro, MA
To Dave Lederer
U.S. EPA
One Congress St., Suite 1100 (HBO)
Boston, MA 02114
Deadline - Postmarked By Wednesday, August 25, 2004
FAX (617) 918 - 1291, No Later Than Wednesday, August 25,2004
August 2004
I am writing to express my firm opposition to the EPA's proposed plan for the 'cleanup'
of the Shpack Superfund Site.
EPA's preferred alternative (SC-2b) is unacceptable for reasons too numerous to detail
here. Most objectionable is the fact this option does not provide "permanence" and is
therefore not a "remedy". It would leave the Town of Norton with a still contaminated
site, and the responsibility & burdens of dealing with it, in the near and distant furore,
In the face of the promise the Environmental Protection Agency made to the town,
EPA's chosen course of action, is reprehensible,
If community acceptance, plays any role in the EPA's decision making process for the
cleanup of Shpack, please give serious consideration to these comments, and select
Alternative SC-3b, which will at long last, give residents of this community the peace of
mind they deserve.
/
Signature
cUi
Print Name
Address
q R iChdAcl -S O A A
(V^OD/O , 0X1LU
-------
Comments to The US EPA on the June 2004 Proposed Plan For the Cleanup of
The Shpaek Superfund Site, Norton/Attleboro, MA
To Dave Lederer
U.S. EPA
One Congress St., Suite 1100 (HBO)
Boston, MA 02114
Deadline - Postmarked By Wednesday, August 25, 2004
FAX (617) 918 - 1291, No Later Than Wednesday, August 25,2004
August 2004
I am writing to express my firm opposition to the EPA's proposed plan for the 'cleanup*
of the Shpaek Superfund Site.
EPA's preferred alternative (SC-2b) is unacceptable for reasons too numerous to detail
here. Most objectionable is the fact this option does not provide "permanence" and is
therefore not a "remedy". It would leave the Town of Norton with a still contaminated
site, and the responsibility & burdens of dealing with it, in the near and distant future,
in the face of the promise the Environmental Protection Agency made to the town,
EPA's chosen course of action, is reprehensible.
If community acceptance, plays any role in the EPA's decision making process for the
cleanup of Shpaek, please give serious consideration to these comments, and select
Alternative SC-3b, which will at long last, give residents of this community the peace of
mind they deserve.
Print Name fow -l-b fJlioH-
Address 13 folJIUjf)Of.i Cm if.
fxlliryLno nv)lcl
-------
Comments to The US EPA on the June 2004 Proposed Plan For the Cleanup of
The Shpack Superfund Site, Norton/Attleboro, MA
To Dave I.ederer
U.S. EPA
One Congress St., Suite 1100 (HBO)
Boston, MA 02114
Deadline - Postmarked By Wednesday, August 25, 2004
FAX (617) 918 - 1291, Ho Later Than Wednesday, August 25,2004
August 2004
I am writing to express my firm opposition to the EPA's proposed plan for the 'cleanup'
of the Shpack Superfund Site,
EPA's preferred alternative (SC-2b) is unacceptable for reasons too numerous to detail
here. Most objectionable is the fact this option does not provide "permanence" and is
therefore not a "remedy". It would leave the Town of Norton with a still contaminated
site, and the responsibility & burdens of dealing with it, in the near and distant future.
In the face of the promise the Environmental Protection Agency made to the town,
EPA's chosen course of action, is reprehensible.
If community acceptance, plays any role in the EPA's decision making process for the
cleanup of Shpack, please give serious consideration to these comments, and select
Alternative SC-3b, which will at long last, give residents of this community the peace of
mind they deserve.
0
Signature \ U J.£AaaJ\ /vyvyui^
* 1 Hflg^j^^H^flfl^ll^HWflflflfl|^HaaaaflflaHaaaaaa^^flri^aflflafl|thiiaflflflflflflHaaaMi^IMHHiiiiiiii^^
Print Name ^
Address
RT /)^iC
-------
Comments to The US EPA on the June 2004 Proposed Plan For the Cleanup of
The Shpack Superfund Site, Norton/Attleboro, MA
To Dave Lederer
U.S. EPA
One Congress St., Suite 1100 (HBO)
Boston, MA 02114
Deadline - Postmarked By Wednesday, August 25, 2004
FAX (617) 918 - 1291, No Later Than Wednesday, August 25, 2004
August 2004
I am writing to express my firm opposition to the EPA's proposed plan for the 'cleanup'
of the Shpack Superfund Site.
EPA's preferred alternative (SC-2b) is unacceptable for reasons too numerous to detail
here. Most objectionable is the fact this option does not provide "permanence" and is
therefore not a "remedy". It would leave the Town of Norton with a still contaminated
site, and the responsibility & burdens of dealing with it, in the near and distant future.
In the face of the promise the Environmental Protection Agency made to the town,
EPA's chosen course of action, is reprehensible.
If community acceptance, plays any role in the EPA's decision making process for the
cleanup of Shpack, please give serious consideration to these comments, and select
Alternative SC-3b, which will at long last, give residents of this community the peace of
mind they deserve.
Signature
Print Name S P 5 p~ fi) A/\J [P
Ires 7 9 wa/us F(£ld AUe
-------
Comments to The US EPA on the June 2004 Proposed Plan For the Cleanup of
The Shpack Superfund Site, Norton/Attleboro, MA
To Dave Lederer
U.S. EPA
One Congress St., Suite 1100 (HBO)
Boston, MA 02114
Deadline - Postmarked By Wednesday, August 25,2004
FAX (617) 918 - 1291, No Later Than Wednesday, August 25, 2004
August 2004
I am writing to express my firm opposition to the EPA's proposed plan for the 'cleanup'
of the Shpack Superfujid Site.
EPA's preferred alternative (SC-2b) is unacceptable for reasons too numerous to detail
here. Most objectionable is the fact this option does not provide "permanence" and is
therefore not a "remedy". It would leave the Town of Norton with a still contaminated
site, and the responsibility & burdens of dealing with it, in the near and distant future.
In the face of the promise the Environmental Protection Agency made to the town,
EPA's chosen course of action, is reprehensible.
If community acceptance, plays any role in the EPA's decision making process for the
cleanup of Shpaek, please give serious consideration to these comments, and select
Alternative SC-3b, which will at long last, give residents of this community the peace of
mind they deserve.
¦A-
Print Name fiA&etffiUA P, /-'GPaJA/'JD
Signature fJ /J
Address /^1
fl)f/trc J OA
-------
Comments to The US EPA on the June 2004 Proposed Plan For the Cleanup of
The Shpack Superfund Site, Norton/Attleboro, MA
To Dave Lederer
U.S. EPA
One Congress St., Suite 1100 (HBO)
Boston, MA 02114
Deadline - Postmarked By Wednesday, August 25,2004
FAX (617) 918 - 1291, No Later Than Wednesday, August 25, 2004
August 2004
I am writing to express my firm opposition to the EPA's proposed plan for the 'cleanup'
of the Shpack Superfund Site.
EPA's preferred alternative (SC-2b) is unacceptable for reasons too numerous to detail
here. Most objectionable is the fact this option does not provide "permanence" and is
therefore not a "remedy". It would leave the Town of Norton with a still contaminated
site, and the responsibility & burdens of dealing with it, in the near and distant future.
In the face of the promise the Environmental Protection Agency made to the town,
EPA's chosen course of action, is reprehensible.
If community acceptance, plays any role in the EPA's decision making process for the
cleanup of Shpack. please give serious consideration to these comments, and select
Alternative SC-3b, which will at long last, give residents of this community the peace of
mind they deserve.
/ "jjLfina.
Signature mu.L. A ^JUi//UZ7U7^c?
CT£>U/ 'J: L
Print Name
V
Address
ntf P\/f
m/q-
-------
08/21/2034 23:15 15086228133
E F FOWLER AND ASSOC
PAGE 0S
Comments to The US EPA on the June 2004 Proposed Plan For the Cleanup of
The Shpack Superfund Site, Norton/Attleboro, MA
To Dave Lederer
U.S. EPA
One Congress St., Suite 1100 (HBO)
Boston, MA 02114
Deadline * Postmarked By Wednesday, August 25, 2004
FAX (617) 918 - 1291, No Later Than Wednesday, August 25,2004
August 2004
I am writing to express my firm opposition to the EPA's proposed plan for the 'cleanup'
of the Shpack Superfund Site.
EPA's preferred alternative (SC-2b) is unacceptable for reasons too numerous to detail
here. Most objectionable is the fact this option does not provide "permanence" and is
therefore not a "remedy". It would leave the Town of Norton with a still contaminated
site, and the responsibility & burdens of dealing with it, in the near and distant future.
In the face of the promise the Environmental Protection Agency made to the town,
EPA's chosen course of action, is reprehensible.
If community acceptance, plays any role in the EPA's decision making process for the
cleanup of Shpack, please give serious consideration to these comments, and select
Alternative SC-3b, which will at long last, give residents of this co mm unity the peace of
mind they deserve.
Signature A, 7^ s
Print Name P \ \ OcA (~Q 1 {) ( P )T
Address IQfN J") "S »
. OX7lR
-------
08/21/2004 23:15 15088229193
E F FOWLER AND ASSOC
PAGE
05
Comments to The US EPA on the June 2004 Proposed Plan For the Cleanup of
Hie Shpack Superfund Site, Norton/Attleboro, MA
To Dave Lederer
U.S. EPA
One Congress St., Suite 1100 (HBO)
Boston, MA 02114
Deadline - Postmarked By Wednesday, August 25,2004
FAX (617) 918 - 1291, No Later Than Wednesday, August 25, 2004
August 2004
I am writing to express my firm opposition to the EPA's proposed plan for the 'cleanup*
of the Shpack Superfund Site.
EPA's preferred alternative (SC-2b) is unacceptable for reasons too numerous to detail
here. Most objectionable is the fact this option does not provide "permanence" and is
therefore not a "remedy". It would leave the Town of Norton with a still contaminated
site, and the responsibility & burdens of dealing with it, in the near and distant future.
In the face of the promise the Environmental Protection Agency made to the town,
EPA's chosen course of action, is reprehensible.
If community acceptance, plays any role in the EPA's decision making process for the
cleanup of Shpack, please give serious consideration to these comments, and select
Alternative SC-3b, which will at long last, give residents of this community the peace of
mind they deserve.
Signature
Address
fao u mA SfczT
Htor /(Ml/tic* M OJM-/V0
¦¦¦ IIM^ ¦
-------
08/21/2004 23:15 15088228193
E F FOWLER AND ASSOC
PAGE 04
Comments to The US EPA on the June 2004 Proposed Plan For the Cleanup of
The Shpaek Superfund Site, Norton/Attleboro, MA
To Dave Lederer
U.S. EPA
One Congress St., Suite 1100 (HBO)
Boston, MA 02114
Deadline - Postmarked By Wednesday, August 25, 2004
FAX (617) 918 - 1291, No Later Than Wednesday, August 25, 2004
August 2004
I am writing to express my firm opposition to the EPA's proposed plan for the 'cleanup'
of the Shpaek Superfund Site.
EPA's preferred alternative (SC-2b) is unacceptable for reasons too numerous to detail
here. Most objectionable is the fact this option does not provide "permanence" and is
therefore not a "remedy". It would leave the Town of Norton with a still contaminated
site, and the responsibility & burdens of dealing with it, in the near and distant future.
In the face of the promise the Environmental Protection Agency made to the town,
EPA's chosen course of action, is reprehensible.
If community acceptance, plays any role in the EPA's decision making process for the
cleanup of Shpaek, please give serious consideration to these comments, and select
Alternative SC-3b, which will at long last, give residents of this community the peace of
mind they deserve.
Address /Q° k/tVQJw&J
01/1SJ Q2- vjS
-------
08/21/2004 23:15 15088226133
E F FOWLER AND ASSOC
PAGE 01
Comments to The US EPA on the June 2004 Proposed Plan For the Cleanup of
The Shpack Superfund Site, Norton/Attleboro, MA
To Dave Lederer
U.S. EPA
One Congress St., Suite 1100 (HBO)
Boston, MA 02114
Deadline - Postmarked By Wednesday, August 25, 2004
FAX (617) 918 - 1291, No Later Than Wednesday, August 25, 2004
August 2004
1 am writing to express my firm opposition to the EPA's proposed plan for the 'cleanup'
of the Shpack Superfund Site.
EPA's preferred alternative (SC-2b) is unacceptable for reasons too numerous to detail
here. Most objectionable is the fact this option docs not provide "permanence" and is
therefore not a "remedy". It would leave the Town of Norton with a still contaminated
site, and the responsibility & burdens of dealing with it, in the near and distant future.
In the face of the promise the Environmental Protection Agency made to the town,
EPA's chosen course of action, is reprehensible.
If community acceptance, plays any role in the EPA's decision making process for the
cleanup of Shpack, please give serious consideration to these comments, and select
Alternative SC-3b, which will at long last, give residents of this community the peace of
mind they deserve.
Signature
Print Name
Address
-------
go/ ii / ZUUH 4.3 . L X-^JKJOO/L /LO X D J
c. r ruwLLr hmu hdouu
rnac. rn.
Comments to The US EPA on the June 2004 Proposed Plan For the Cleanup of
The Shpack Superfund Site, Norton/Attleboro, MA
To Dave Lederer
U.S. EPA
One Congress St., Suite 1100 (HBO)
Boston, MA 02114
Deadline - Postmarked By Wednesday, August 25, 2004
FAX (617) 918 - 1291, No Later Than Wednesday, August 25, 2004
August 2004
I am writing to express my firm opposition to the EPA's proposed plan for the 'cleanup1
of the Shpack. Superfund Site.
EPA's preferred alternative (SC-2b) is unacceptable for reasons too numerous to detail
here. Most objectionable is the fact this option does not provide "permanence" and is
therefore not a "remedy". It would leave the Town of Norton with a still contaminated
site, and the responsibility & burdens of dealing with it, in the near and distant future.
In the face of the promise the Environmental Protection Agency made to the town,
EPA's chosen course of action, is reprehensible.
If community acceptance, plays any role in the EPA's decision making process for the
cleanup of Shpack, please give serious consideration to these comments, and select
Alternative SC~3b, which will at long last, give residents of this community the peace of
mind they deserve.
Signature 0 X )¦
Print Name
knmffg L Kn.Ugg-
(00 Kirv^ Sim
Address
Taunton .
—'— imnT—" ilffn fciiiiiininiiiiiii " i> i» 1 ———
-------
Comments to The US EPA on the June 2004 Proposed Plan For the Cleanup of
The Shpack Superfund Site, Norton/Attieboro, MA
To Dave Lederer
U.S. EPA
One Congress St., Suite 1100 (HBO)
Boston, MA 02114
Deadline - Postmarked By Wednesday, August 25, 2004
FAX (617) 918 - 1291, No Later Than Wednesday, August 25, 2004
August 2004
I am writing to express my firm opposition to the EPA's proposed plan for the 'cleanup'
of the Shpack Superfund Site,
EPA's preferred alternative (SC-2b) is unacceptable for reasons too numerous to detail
here. Most objectionable is the fact this option does not provide "permanence" and is
therefore not a "remedy". It would leave the Town of Norton with a still contaminated
site, and the responsibility & burdens of dealing with it, in the near and distant future.
In the face of the promise the Environmental Protection Agency made to the town,
EPA's chosen course of action, is reprehensible.
If community acceptance, plays any role in the EPA's decision making process for the
cleanup of Shpack, please give serious consideration to these comments, and select
Alternative SC-3b, which will at long last, give residents of this community the peace of
mind they deserve.
Print Name
P o 3dQ>
-------
Comments to The US EPA on the June 2004 Proposed Plan For the Cleanup of
The Shpack Superfimd Site, Norton/Attleboro, MA
To Dave Lederer
U.S. EPA
One Congress St., Suite 1100 (HBO)
Boston, MA 02114
Deadline - Postmarked By Wednesday, August 25, 2004
FAX (617) 918 - 1291, No Later Than Wednesday, August 25, 2004
August 2004
I am writing to express my firm opposition to the EPA's proposed plan for the 'cleanup'
of the Shpack Superfimd Site,
EPA's preferred alternative (SC-2b) is unacceptable for reasons too numerous to detail
here. Most objectionable is the fact this option does not provide "permanence" and is
therefore not a "remedy". It would leave the Town of Norton with a still contaminated
site, and the responsibility & burdens of dealing with it, in the near and distant future.
In the face of the promise the Environmental Protection Agency made to the town,
EPA's chosen course of action, is reprehensible.
If community acceptance, plays any role in the EPA's decision making process for the
cleanup of Shpack, please give serious consideration to these comments, and select
Alternative SC-3b, which will at Jong last, give residents of this community the peace of
mind they deserve.
Print Name ~{\ \~\ \W
Address I 3 tOC
mft QZQ3P>
-------
Comments to The US EPA on the June 2004 Proposed Plan For the Cleanup of
The Shpack Superfund Site, Norton/Attleboro, MA
To Dave Lederer
U.S. EPA
One Congress St., Suite 1100 (HBO)
Boston, MA 02114
Deadline - Postmarked By Wednesday, August 25, 2004
FAX (617) 918 - 1291, No Later Than Wednesday, August 25, 2004
August 2004
I am writing to express my firm opposition to the EPA's proposed plan for the 'cleanup'
of the Shpack Superfund Site.
EPA's preferred alternative (SC-2b) is unacceptable for reasons too numerous to detail
here. Most objectionable is the fact this option does not provide "permanence" and is
therefore not a "remedy". It would leave the Town of Norton with a still contaminated
site, and the responsibility & burdens of dealing with it, in the near and distant future.
In the face of the promise the Environmental Protection Agency made to the town,
EPA's chosen course of action, is reprehensible.
If community acceptance, plays any role in the EPA's decision making process for the
cleanup of Shpack, please give serious consideration to these comments, and select
Alternative SC-3b, which will at long last, give residents of this community the peace of
mind they deserve.
Signature
Print Name
Jo A i-Ho fb
Address S in )-f 1 *3 K (
-------
Comments to The US EPA on the June 2004 Proposed Plan For the Cleanup of
The Shpack Superfund Site, Norton/Attleboro, MA
To Dave Lederer
U.S. EPA
One Congress St., Suite 1100 (HBO)
Boston, MA 02114
Deadline - Postmarked By Wednesday, August 25, 2004
FAX (617) 918 - 1291, No Later Than Wednesday, August 25, 2004
August 2004
I am writing to express my firm opposition to the EPA's proposed plan for the 'cleanup'
of the Shpack Superfund Site.
EPA's preferred alternative (SC-2b) is unacceptable for reasons too numerous to detail
here. Most objectionable is the fact this option does not provide "permanence" and is
therefore not a "remedy". It would leave the Town of Norton with a still contaminated
site, and the responsibility & burdens of dealing with it, in the near and distant future.
In the face of the promise the Environmental Protection Agency made to the town,
EPA's chosen course of action, is reprehensible.
If community acceptance, plays any role in the EPA's decision making process for the
cleanup of Shpack, please give serious consideration to these comments, and select
Alternative SC-3b, which will at long last, give residents of this community the peace of
mind they deserve.
Signature (^jyfTh/s
Print Name
Carol a.
Address
-------
Comments to The US EPA on the June 2004 Proposed Plan For the Cleanup of
The Shpack Superfund Site, Norton/Attleboro, MA
To Dave Lederer
U.S. EPA
One Congress St., Suite 1100 (HBO)
Boston, MA 02114
Deadline - Postmarked By Wednesday, August 25,2004
FAX (617) 918 - 1291, No Later Than Wednesday, August 25, 2004
August 2004
1 am writing to express my firm opposition to the EPA's proposed plan for the 'cleanup'
of the Shpack Superfund Site.
EPA's preferred alternative (SC-2b) is unacceptable for reasons too numerous to detail
here. Most objectionable is the fact this option does not provide "permanence" and is
therefore not a "remedy". It would leave the Town of Norton with a still contaminated
site, and the responsibility & burdens of dealing with it, in the near and distant future.
In the face of the promise the Environmental Protection Agency made to the town,
EPA's chosen course of action, is reprehensible.
If community acceptance, plays any role in the EPA's decision making process for the
cleanup of Shpack, please give serious consideration to these comments, and select
Alternative SC-3b, which will at long last, give residents of this community the peace of
mind they deserve.
Signature
Print Name
Address r-0^
, Ua Oli
-------
Comments to The US EPA on the June 2004 Proposed Plan For the Cleanup of
The Shpack Superfund Site, Norton/Attleboro, MA
To Dave Lederer
U.S. EPA
One Congress St., Suite 1100 (HBO)
Boston, MA 02114
Deadline - Postmarked By Wednesday, August 25,2004
FAX (617) 918 ~ 1291, No Later Than Wednesday, August 25, 2004
August 2004
I am writing to express my firm opposition to the EPA's proposed plan for the 'cleanup'
of the Shpack Superfund Site.
EPA's preferred alternative (SC-2b) is unacceptable for reasons too numerous to detail
here. Most objectionable is the fact this option does not provide "permanence" and is
therefore not a "remedy". It would leave the Town of Norton with a still contaminated
site, and the responsibility & burdens of dealing with it, in the near and distant future.
In the face of the promise the Environmental Protection Agency made to the town,
EPA's chosen course of action, is reprehensible.
If community acceptance, plays any role in the EPA's decision making process for the
cleanup of Shpack, please give serious consideration to these comments, and select
Alternative SC-3b, which will at long last, give residents of this community the peace of
mind they deserve.
-------
Comments to The US EPA on the June 2004 Proposed Plan For the Cleanup of
The Shpack Superfund Site, Norton/Attleboro, MA
To Dave Lederer
U.S. EPA
One Congress St., Suite 1100 (HBO)
Boston, MA 02114
Deadline - Postmarked By Wednesday, August 25, 2004
_ FAX (617) 918 - 1291, No Later Than Wednesday, August 25, 2004
August 2004
1 am writing to express my firm opposition to the EPA's proposed plan for the 'cleanup'
of the Shpack Superfund Site.
EPA's preferred alternative (SC-2b) is unacceptable for reasons too numerous to detail
here. Most objectionable is the fact this option does not provide "permanence" and is
therefore not a "remedy", it would leave the Town of Norton with a still contaminated
site, and the responsibility & burdens of dealing with it, in the near and distant future.
In the face of the promise the Environmental Protection Agency made to the town,
EPA's chosen course of action, is reprehensible.
If community acceptance, plays any role in the EPA's decision making process for the
cleanup of Shpack, please give serious consideration to these comments, and select
Alternative SC-3b, which will at long last, give residents of this community the peace of
mind they deserve.
.
Print Name uXtnttcj
Address (H* 5^1 Qj f
liryjtodfYi, c&OlQ
-------
Comments to The US EPA on the June 2004 Proposed Plan For the Cleanup of
The Shpack Superfund Site, Norton'Attleboro, MA
To Dave Lederer
U.S. EPA
One Congress St., Suite 1100 (HBO)
Boston, MA 02114
Deadline - Postmarked By Wednesday, August 25, 2004
FAX (617) 918 - 1291, No Later Than Wednesday, August 25, 2004
August 2004
I am writing to express my firm opposition to the EPA's proposed plan for the 'cleanup'
of the Shpack Superfund Site.
EPA's preferred alternative (SC-2b) is unacceptable for reasons too numerous to detail
here. Most objectionable is the fact this option does not provide "permanence" and is
therefore not a "remedy". It would leave the Town of Norton with a still contaminated
site, and the responsibility & burdens of dealing with it, in the near and distant future.
In the face of the promise the Environmental Protection Agency made to the town.
EPA's chosen course of action, is reprehensible.
If community acceptance, plays any role in the EPA's decision making process for the
cleanup of Shpack, please give serious consideration to these comments, and select
Alternative SC-3b, which will at long last, give residents of this community the peace of
mind they deserve.
Signature
Print Name
Address
UMtiftW koffinLu>
M* Vwihilood Qfxlo
am PAft OTtO )Q
-------
Comments to The US EPA on the June 2004 Proposed Plan For the Cleanup of
The Shpack Superfund Site, Norton/Attleboro, MA
To Dave Lederer
U.S. EPA
One Congress St., Suite 1100 (HBO)
Boston, MA 02114
Deadline - Postmarked By Wednesday, August 25, 2004
FAX (617) 918 - 1291, No Later Than Wednesday, August 25, 2004
August 2004
I am writing to express my firm opposition to the EPA's proposed plan for the 'cleanup'
of the Shpack Superfund Site.
EPA's preferred alternative (SC-2b) is unacceptable for reasons too numerous to detail
here. Most objectionable is the fact this option does not provide "permanence" and is
therefore not a "remedy". It would leave the Town of Norton with a still contaminated
site, and the responsibility & burdens of dealing with it, in the near and distant future.
In the face of the promise the Environmental Protection Agency made to the town,
EPA's chosen course of action, is reprehensible.
If community acceptance, plays any role in the EPA's decision making process for the
cleanup of Shpack, please give serious consideration to these comments, and select
Alternative SC-3b, which will at long last, give residents of this community the peace of
mind they deserve.
Signature
Print Name
Address |5I7 ThliffiWl $
We^&VaM. MA £2#?3
-------
Comments to The US EPA on the June 2004 Proposed Plan For the Cleanup of
llie Shpack Superfund Site, Norton/Attleboro, MA
To Dave Lederer
U.S. EPA
One Congress St., Suite 1100 (HBO)
Boston, MA 02114
Deadline - Postmarked By Wednesday, August 25, 2004
FAX (617) 918 - 1291, No Later Than Wednesday, August 25, 2004
August 2004
I am writing to express my firm opposition to the EPA's proposed plan for the 'cleanup'
of the Shpack Superfund Site,
EPA's preferred alternative (SC-2b) is unacceptable for reasons too numerous to detail
here. Most objectionable is the fact this option does not provide "permanence" and is
therefore not a "remedy", it would leave the Town of Norton with a still contaminated
site, and the responsibility & burdens of dealing with it, in the near and distant future.
In the face of the promise the Environmental Protection Agency made to the town.
EPA's chosen course of action, is reprehensible.
If community acceptance, plays any role in the EPA's decision making process for the
cleanup of Shpack, please give serious consideration to these comments, and select
Alternative SC-3b, which will at long last, give residents of this community the peace of
mind they deserve.
Signature
Print Name
Address
urn s w & ¦
fM 0.3705
-------
Comments to The US EPA on the J line 2004 Proposed Plan lor the Cleanup of
The Shpack Superfund Site, Norton/Attleboro, MA
To Dave Lederer
U.S. EPA
One Congress St., Suite 1100 (HBO)
Boston, MA 02114
Deadline - Postmarked By Wednesday, August 25, 2004
FAX (617) 918 - 1291, No Later Than Wednesday, August 25, 2004
August 2004
I am writing to express my firm opposition to the EPA's proposed plan for the 'cleanup'
of the Shpack Superfund Site,
EPA's preferred alternative (SC-2b) is unacceptable for reasons loo numerous to detail
here. Most objectionable is the fact this option does not provide "permanence" and is
therefore not a "remedy". It would leave the Town of Norton with a still contaminated
site, and the responsibility & burdens of dealing with it, in the near and distant future.
In the face of the promise the Environmental Protection Agency made to the town,
EPA's chosen course of action, is reprehensible.
If community acceptance, plays any role in the EPA's decision making process for the
cleanup of Shpack, please give serious consideration to these comments, and select
Alternative SC-3b, which will at long last, give residents of this community the peace of
mind they deserve.
Print Name —lj/. L 4 Q S [f lld. Q |
Address ZP ^)bH 4 s ^r(^4Ar
— ^
-------
Comments to The US EPA on the June 2004 Proposed Plan For the Cleanup of
The Shpack Supetfund Site, Norton/Attleboro, MA
To Dave Lederer
U.S. EPA
One Congress St., Suite 1100 (HBO)
Boston, MA 02114
Deadline - Postmarked By Wednesday, August 25,2004
FAX (617) 918 - 1291, No Later Than Wednesday, August 25, 2004
August 2004
I am writing to express my firm opposition to the EPA's proposed plan for the 'cleanup*
of the Shpack Superfund Site.
EPA's preferred alternative (SC-2b) is unacceptable for reasons too numerous to detail
here. Most objectionable is the fact this option does not provide "permanence" and is
therefore not a "remedy". It would leave the Town of Norton with a still contaminated
site, and the responsibility & burdens of dealing with it, in the near and distant future,
In the face of the promise the Environmental Protection Agency made to the town,
EPA's chosen course of action, is reprehensible.
If community acceptance, plays any role in the EPA's decision making process for the
cleanup of Shpack, please give serious consideration to these comments, and select
Alternative SC-3b, which will at long last, give residents of this community the peace of
mind they deserve.
S i mature,,
s
Print Name
I fz- Z-ec ' j r
Address
5 5* "fT" 'pt Y ^/
MA J J. c-r*
-------
Comments to The US EPA on the June 2004 Proposed Plan For the Cleanup of
The Shpaek Superfund Site, Norton/Attleboro, MA
To Dave Lederer
U.S. EPA
One Congress St., Suite 1100 (HBO)
Boston, MA 02114
Deadline - Postmarked By Wednesday, August 25, 2004
FAX (617) 918 ~ 1291, No Later Than Wednesday, August 25, 2004
August 2004
I am writing to express my firm opposition to the EPA's proposed plan for the 'cleanup'
of the Shpaek Superfund Site,
EPA's preferred alternative (SC-2b) is unacceptable for reasons too numerous to detail
here. Most objectionable is the fact this option does not provide "permanence" and is
therefore not a "remedy". It would leave the Town of Norton with a still contaminated
site, and the responsibility & burdens of dealing with it, in the near and distant future.
In the face of the promise the Environmental Protection Agency made to the town,
EPA's chosen course of action, is reprehensible.
If community acceptance, plays any role in the EPA's decision making process for the
cleanup of Shpaek, please give serious consideration to these comments, and select
Alternative SC-3b, which will at long last, give residents of this community the peace of
mind they deserve.
Signature QH\Q
Print Name i ^
Address ss.'mfN? '~-^V
toft
-------
Comments to The US EPA on the June 2004 Proposed Plan For the Cleanup of
The Shpack Superfimd Site, Norton/ Attleboro, MA
To Dave Lederer
U.S. EPA
One Congress St., Suite 1100 (HBO)
Boston, MA 02! 14
Deadline - Postmarked By Wednesday, August 25,2004
FAX (617) 918 - 1291, No Later Than Wednesday, August 25, 2004
August 2004
I am writing to express my fum opposition to the EPA's proposed plan for the 'cleanup'
of the Shpack Superfimd Site.
EPA's preferred alternative (SC-2b) is unacceptable for reasons too numerous to detail
here. Most objectionable is the fact this option does not provide "permanence" and is
therefore not a "remedy". It would leave the Town of Norton with a still contaminated
site, and the responsibility & burdens of dealing with it, in the near and distant future.
In the face of the promise the Environmental Protection Agency made to the town,
EPA's chosen course of action, is reprehensible.
If community acceptance, plays any role in the EPA's decision making process for the
cleanup of Shpack, please give serious consideration to these comments, and select
Alternative SC-3b, which will at long last, give residents of this community the peace of
mind they deserve.
Address
-------
Comments to The US EPA on the June 2004 Proposed Plan For the Cleanup of
The Shpaek Superfund Site, Norton/Attleboro, MA
To Dave Lederer
U.S. EPA
One Congress St., Suite 1100 (HBO)
Boston, MA 02114
Deadline - Postmarked By Wednesday, August 25, 2004
FAX (617) 918 - 1291, No Later Than Wednesday, August 25,2004
August 2004
I am writing to express my firm opposition to the EPA's proposed plan for the 'cleanup'
of the Shpaek Superfund Site.
EPA's preferred alternative (SC-2b) is unacceptable for reasons too numerous to detail
here. Most objectionable is the fact this option does not provide "permanence" and is
therefore not a "remedy". It would leave the Town of Norton with a still contaminated
site, and the responsibility & burdens of dealing with it, in the near and distant future.
In the face of the promise the Environmental Protection Agency made to the town,
EPA's chosen course of action, is reprehensible.
If community acceptance, plays any role in the EPA's decision making process for the
cleanup of Shpaek, please give serious consideration to these comments, and select
Alternative SC-3b, which will at long last, give residents of this community the peace of
mind they deserve.
Signature
Print Name
(Wlcs.
Address
lit! jfrvK td-iL ftu C *5?
-------
Comments to The US EPA on the June 2004 Proposed Plan For the Cleanup of
The Shpaek Superfund Site, Norton/Attleboro, MA
To Dave Lederer
US. EPA
One Congress St., Suite 1100 (HBO)
Boston, MA 02114
Deadline - Postmarked By Wednesday, August 25, 2004
FAX (617) 918 - 1291, No Later Than Wednesday, August 25, 2004
August 2004
I am writing to express my firm opposition to the EPA's proposed plan for the 'cleanup"'
of the Shpaek Superfiind Site.
EPA's preferred alternative (SC-2b) is unacceptable for reasons too numerous to detail
here. Most objectionable is the fact this option does not provide "permanence" and is
therefore not a "remedy". It would leave the Town of Norton with a still contaminated
site, and the responsibility & burdens of dealing with it, in the near and distant future.
In the face of the promise the Environmental Protection Agency made to the town,
EPA's chosen course of action, is reprehensible.
If community acceptance, plays any role in the EPA's decision making process for the
cleanup of Shpaek, please give serious consideration to these comments, and select
Alternative SC-3b, which will at long last, give residents of this community the peace of
mind they deserve.
Signature
Print Name
//f-AStyk. STT
Aj(yfyy\ M*
-------
Comments to The US EPA on the June 2004 Proposed Plan For the Cleanup of
The Shpack Superfimd Site, Norton/Attleboro, MA
To Dave l.ederer
U.S. EPA
One Congress St., Suite 1100 (HBO)
Boston, MA 02114
Deadline - Postmarked By Wednesday, August 25, 2004
FAX (617) 918 - 1291, No Later Than Wednesday, August 25, 2004
August 2004
I am writing to express my firm opposition to the EPA's proposed plan for the "cleanup'
of the Shpack Superfund Site.
EPA's preferred alternative (SC-2b) is unacceptable for reasons too numerous to detail
here. Most objectionable is the fact this option does not provide "permanence" and is
therefore not a "remedy". It would leave the Town of Norton with a still contaminated
site, and the responsibility & burdens of dealing with it, in the near and distant future.
In the face of the promise the Environmental Protection Agency made to the town,
EPA's chosen course of action, is reprehensible.
If community acceptance, plays any role in the EPA's decision making process for the
cleanup of Shpack, please give serious consideration to these comments, and select
Alternative SC-3b, which will at long last, give residents of this community the peace of
mind they deser
Signature
Print Name
Address
Klo/teA rnfl
Print Name
-------
Comments to The US EPA on the June 2004 Proposed Plan For the Cleanup of
The Shpack Superfund Site, Norton/Attleboro, MA
To Dave Lederer
U.S. EPA
One Congress St., Suite 1100 (HBO)
Boston, MA 02114
Deadline - Postmarked By Wednesday, August 25, 2004
FAX (617) 918 - 1291, No Later Than Wednesday, August 25,2004
August 2004
I am writing to express my firm opposition to the EPA's proposed plan for the 'cleanup'
of the Shpaek Superfund Site.
EPA's preferred alternative (SC-2b) is unacceptable for reasons too numerous to detail
here. Most objectionable is the fact this option does not provide "permanence" and is
therefore not a "remedy". It would leave the Town of Norton with a still contaminated
site, and the responsibility & burdens of dealing with it, in the near and distant future.
In the face of the promise the Environmental Protection Agency made to the town,
EPA's chosen course of action, is reprehensible.
If community acceptance, plays any role in the EPA's decision making process for the
cleanup of Shpack, please give serious consideration to these comments, and select
Alternative SC-3b, which will at long last, give residents of this community the peace of
mind they deserve.
Signature
Print Name (M
Address f(Xf If 1,(1^ St
-------
Comments to The US EPA on the June 2004 Proposed Plan For the Cleanup of
The Shpack Superfund Site, Norton/Attleboro, MA
To Dave Lederer
U.S. EPA
One Congress St., Suite 1100 (HBO)
Boston, MA 02114
Deadline - Postmarked By Wednesday, August 25, 2004
FAX (617) 918 - 1291, No Later Than Wednesday, August 25, 2004
August 2004
I am writing to express my firm opposition to the EPA's proposed plan for the 'cleanup'
of the Shpack Superfund Site.
EPA's preferred alternative (SC-2b) is unacceptable for reasons too numerous to detail
here. Most objectionable is the fact this option does not provide "permanence" and is
therefore not a "remedy". It would leave the Town of Norton with a still contaminated
site, and the responsibility & burdens of dealing with it, in the near and distant future.
In the face of the promise the Environmental Protection Agency made to the town,
EPA's chosen course of action, is reprehensible.
If community acceptance, plays any role in the EPA's decision making process for the
cleanup of Shpack, please give serious consideration to these comments, and select
Alternative SC-3b, which will at long last, give residents of this community the peace of
mind they deserve.
Print Name lUl (ltd AL
Address A&3 fitUi.UicLai •S'i-UeJ'
fan A/tin Mfi
-------
Comments to The US EPA on the June 2004 Proposed Plan For the Cleanup of
The Shpaek Superfund Site, Norton/Attleboro, MA
To Dave Lederer
U.S. EPA
One Congress St., Suite 1100 (HBO)
Boston, MA 02114
Deadline - Postmarked By Wednesday, August 25, 2004
FAX (617) 918 - 1291, No Later Than Wednesday, August 25,2004
August 2004
I am writing to express my firm opposition to the EPA's proposed plan for the 'cleanup'
of the Shpaek Superfund Site.
EPA's preferred alternative (SC-2b) is unacceptable for reasons too numerous to detail
here. Most objectionable is the fact this option does not provide "permanence" and is
therefore not a "remedy". It would leave the Town of Norton with a still contaminated
site, and the responsibility & burdens of dealing with it, in the near and distant future.
In the face of the promise the Environmental Protection Agency made to the town,
EPA's chosen course of action, is reprehensible.
If community acceptance, plays any role in the EPA's decision making process for the
cleanup of Shpaek, please give serious consideration to these comments, and select
Alternative SC-3b, which will at long last, give residents of this community the peace of
mind they deserve.
PnhfijT\aJ\A } iZ) D'A
-------
Comments to The US EPA on the June 2004 Proposed Plan For the Cleanup of
The Shpack Superfund Site, Norton/Attleboro, MA
To Dave Lederer
U.S. EPA
One Congress St., Suite 1100 (HBO)
Boston, MA 02114
Deadline - Postmarked By Wednesday, August 25, 2004
FAX (617) 918 - 1291, No Later Than Wednesday, August 25, 2004
August 2004
I am writing to express my firm opposition to the EPA's proposed plan for the 'cleanup'
of the Shpack Superfund Site.
EPA's preferred alternative (SC-2b) is unacceptable for reasons too numerous to detail
here. Most objectionable is the fact this option does not provide "permanence" and is
therefore not a "remedy". It would leave the Town of Norton with a still contaminated
site, and the responsibility & burdens of dealing with it, in the near and distant future.
In the face of the promise the Environmental Protection Agency made to the town,
EPA's chosen course of action, is reprehensible.
If community acceptance, plays any role in the EPA's decision making process for the
cleanup of Shpack, please give serious consideration to these comments, and select
Alternative SC-3b, which will at long last, give residents of this community the peace of
mind they deserve.
Signature jQst/n
Print Name
Address ^ fVf -5^ f V
S^OCfrUClC
-------
Comments to The US EPA on the June 2004 Proposed Plan For the Cleanup of
The Shpack Superfund Site, Norton/Attleboro, MA
To Dave Lederer
U.S. EPA
One Congress St., Suite 1100 (HBO)
Boston, MA 02114
Deadline - Postmarked By Wednesday, August 25,2004
FAX (617) 918 - 1291, No Later Than Wednesday, August 25,2004
August 2004
I am writing to express my firm opposition to the EPA's proposed plan for the "cleanup'
of the Shpack Superfund Site.
EPA's preferred alternative (SC-2b) is unacceptable for reasons too numerous to detail
here. Most objectionable is the fact this option does not provide "permanence" and is
therefore not a "remedy". It would leave the Town of Norton with a still contaminated
site, and the responsibility & burdens of dealing with it, in the near and distant future.
In the face of the promise the Environmental Protection Agency made to the town,
EPA's chosen course of action, is reprehensible.
If community acceptance, plays any role in the EPA's decision making process for the
cleanup of Shpack, please give serious consideration to these comments, and select
Alternative SC-3b, which will at long last, give residents of this community the peace of
mind they deserve.
Signature
Print Name
¦ u -
Cjor-ejti '~R/rd_
Address
fhtituJoort. fjrtJe.
-------
Comments to The US EPA on the June 2004 Proposed Plan For the Cleanup of
The Shpack Superfund Site, Norton/Attleboro, MA
To Dave Lederer
U.S. EPA
One Congress St, Suite 1100 (HBO)
Boston, MA 02114
Deadline - Postmarked By Wednesday, August 25, 2004
FAX (617) 918 - 1291, No Later Than Wednesday, August 25, 2004
August 2004
I am writing to express my firm opposition to the EPA's proposed plan for the 'cleanup'
of the Shpack Superfund Site.
EPA's preferred alternative (SC-2b) is unacceptable for reasons too numerous to detail
here. Most objectionable is the fact this option does not provide "permanence" and is
therefore not a "remedy". It would leave the Town of Norton with a still contaminated
site, and the responsibility & burdens of dealing with it, in the near and distant future,
In the face of the promise the Environmental Protection Agency made to the town,
EPA's chosen course of action, is reprehensible.
If community acceptance, plays any role in the EPA's decision making process for the
cleanup of Shpack, please give serious consideration to these comments, and select
Alternative SC-3b, which will at long last, give residents of this community the peace of
mind they deserve.
Signature
Print Name
Address
fc (frntwAKk
-------
Comments to The US EPA on the June 2004 Proposed Plan For the Cleanup of
The Shpack Superfund Site, Norton/Attleboro, MA
To Dave Lederer
U.S. EPA
One Conpess St., Suite 1100 (HBO)
Boston, MA 02114
Deadline - Postmarked By Wednesday, August 25,2004
FAX (617) 918 - 1291, No Later Than Wednesday, August 25, 2004
August 2004
I am writing to express my firm opposition to the EPA's proposed plan for the 'cleanup'
of the Shpack Superfund Site.
EPA's preferred alternative (SC-2b) is unacceptable for reasons too numerous to detail
here. Most objectionable is the fact this option does not provide "permanence" and is
therefore not a "remedy". It would leave the Town of Norton with a still contaminated
site, and the responsibility & burdens of dealing with it, in the near and distant future.
In the face of the promise the Environmental Protection Agency made to the town,
EPA's chosen course of action, is reprehensible.
If community acceptance, plays any role in the EPA's decision making process for the
cleanup of Shpack, please give serious consideration to these comments, and select
Alternative SC-3b, which will at long last, give residents of this community the peace of
mind they deserve.
Signature
Print Name
Address
U-AJAtiOlCiL C>29-?J>
-------
Comments to The US EPA on the June 2004 Proposed Plan For the Cleanup of
The Shpaek Superfund Site, Norton/Attleboro, MA
To Dave Lederer
U.S. EPA
One Congress St., Suite 1100 (HBO)
Boston, MA 02114
Deadline - Postmarked By Wednesday, August 25,2004
FAX (617) 9 ] 8 - 1291, No Later Than Wednesday, August 25, 2004
August 2004
I am writing to express my Firm opposition to the EPA's proposed plan for the 'cleanup'
of the Shpaek Superftmd Site,
EPA's preferred alternative (SC-2b) is unacceptable for reasons too numerous to detail
here. Most objectionable is the fact this option does not provide "permanence" and is
therefore not a "remedy". It would leave the Town of Norton with a still contaminated
site, and the responsibility & burdens of dealing with it, in the near and distant future.
In the face of the promise the Environmental Protection Agency made to the town,
EPA's chosen course of action, is reprehensible.
If community acceptance, plays any role in the EPA's decision making process for the
cleanup of Shpaek, please give serious consideration to these comments, and select
Alternative SC-3b, which will at long last, give residents of this community the peace of
mind they deserve.
Print Name
Address
fOeuJto/ng
/l)vt &^^6 &
-------
Comments to The US EPA on the June 2004 Proposed Plan For the Cleanup of
The Shpack Superfund Site, Norton/Attleboro, MA
To Dave Led ere r
U.S. EPA
One Congress St., Suite 1100 (HBO)
Boston, MA 02114
Deadline - Postmarked By Wednesday, August 25, 2004
FAX (617) 918 - 1291, No Later Than Wednesday, August 25,2004
August 2004
1 am writing to express my firm opposition to the EPA's proposed plan for the 'cleanup'
of the Shpack Superfund Site.
EPA's preferred alternative (SC-2b) is unacceptable for reasons too numerous to detail
here. Most objectionable is the fact this option does not provide "permanence" and is
therefore not a "remedy". It would leave the Town of Norton with a still contaminated
site, and the responsibility & burdens of dealing with it, in the near and distant future.
In the face of the promise the Environmental Protection Agency made to the town,
EPA's chosen course of action, is reprehensible.
If community acceptance, plays any role in the EPA's decision making process for the
cleanup of Shpack, please give serious consideration to these comments, and select
Alternative SC-3b, which will at long last, give residents of this community the peace of
mind they deserve.
SignaturgTlP f
/ /X
Print Name & v / / $ C% v c.
Address 2 ^ CVTSfn J ¥ St. Aft *
M M-U-eboia, (lift n»7UO
-------
Comments to The US EPA on the June 2004 Proposed Plan For the Cleanup of
The Shpack Superfund Site, Norton/Attleboro, MA
To Dave Lederer
U.S. EPA
One Congress St., Suite 1100 (HBO)
Boston, MA 02114
Deadline - Postmarked By Wednesday, August 25, 2004
FAX (617) 918 - 1291, No Later Than Wednesday, August 25,2004
August 2004
1 am writing to express my firm opposition to the EPA's proposed plan for the 'cleanup'
of the Shpack Superfund Site.
EPA's preferred alternative (SC-2b) is unacceptable for reasons too numerous to detail
here. Most objectionable is the fact this option does not provide "permanence" and is
therefore not a "remedy". It would leave the Town of Norton with a still contaminated
site, and the responsibility & burdens of dealing with it, in the near and distant future.
In the face of the promise the Environmental Protection Agency made to the town,
EPA's chosen course of action, is reprehensible,
If community acceptance, plays any role in the EPA's decision making process for the
cleanup of Shpack, please give serious consideration to these comments, and select
Alternative SC-3b, which will at long last, give residents of this community the peace of
mind they deserve.
Print Name Susan t/V\. [AjtkniV SC-oH
Address <^10 ( vXftxfel R"f. ( i $
P\a.\one. 1^53
-------
Comments to The US EPA on the June 2004 Proposed Plan For the Cleanup of
The Shpack Superfund Site, Norton/Attleboro, MA
To Dave Lederer
U.S. EPA
One Congress St., Suite 1100 (HBO)
Boston, MA 02114
Deadline - Postmarked By Wednesday, August 25, 2004
FAX (617) 918 - 1291, No Later Than. Wednesday, August 25, 2004
August 2004
I am writing to express my firm opposition to the EPA's proposed plan for the 'cleanup'
of the Shpack Superfund Site.
EPA's preferred alternative (SC-2b) is unacceptable for reasons too numerous to detail
here. Most objectionable is the fact this option does not provide "permanence" and is
therefore not a "remedy". It would leave the Town of Norton with a still contaminated
site, and the responsibility & burdens of dealing with it, in the near and distant future.
In the face of the promise the Environmental Protection Agency made to the town,
EPA's chosen course of action, is reprehensible.
If community acceptance, plays any role in the EPA's decision making process for the
cleanup of Shpack, please give serious consideration to these comments, and select
Alternative SC-3b, which will at long last, give residents of this community the peace of
mind they deserve.
Ad
-------
Comments to The US EPA on the June 2004 Proposed Plan For the Cleanup of
The Shpack Superfund Site, Norton/Attleboro, MA
To Dave Lederer
U.S. EPA
One Congress St., Suite 1100 (HBO)
Boston, MA 02114
Deadline - Postmarked By Wednesday, August 25, 2004
FAX (617)918- 1291, No Later Than Wednesday, August 25,2004
August 2004
I am writing to express my firm opposition to the EPA's proposed plan for the "cleanup'
of the Shpack Superfund Site.
EPA's preferred alternative (SC-2b) is unacceptable for reasons too numerous to detail
here. Most objectionable is the fact this option does not provide "permanence" and is
therefore not a "remedy". It would leave the Town of Norton with a still contaminated
site, and the responsibility & burdens of dealing with it, in the near and distant future.
In the face of the promise the Environmental Protection Agency made to the town,
EPA's chosen course of action, is reprehensible.
If community acceptance, plays any role in the EPA's decision making process for the
cleanup of Shpack, please give serious consideration to these comments, and select
Alternative SC-3b, which will at long last, give residents of this community the peace of
mind they deserve.
Signature
Print Name
SctrcxK 5ikjcIo.iV
Address (ff -Turiij Cir^*- Fran KM m ozx>35
-------
Comments to The US EPA on the June 2004 Proposed Plan For the Cleanup of
The Shpack Superfund Site, Norton/Attleboro, MA
To Dave Lederer
U.S. EPA
One Congress St., Suite 1100 (HBO)
Boston, MA 02114
Deadline - Postmarked By Wednesday, August 25, 2004
FAX (617) 918 - 1291, No Later Than Wednesday, August 25, 2004
August 2004
I am writing to express my firm opposition to the EPA's proposed plan for the 'cleanup''
of the Shpack Superfund Site.
EPA's preferred alternative (SC-2b) is unacceptable for reasons too numerous to detail
here. Most objectionable is the fact this option does not provide "permanence" and is
therefore not a "remedy". It would leave the Town ofNorton with a still contaminated
site, and the responsibility & burdens of dealing with it, in the near and distant future.
In the face of the promise the Environmental Protection Agency made to the town,
EPA's chosen course of action, is reprehensible.
If community acceptance, plays any role in the EPA's decision making process for the
cleanup of Shpack, please give serious consideration to these comments, and select
Alternative SC-3b, which will at long last, give residents of this community the peace of
mind they deserve.
Signature
Print Name f\c\ /•?• *S/s\Q/i
-------
Comments to The US EPA on the June 2004 Proposed Plan For the Cleanup of
The Shpack Superfund Site, Norton/Attleboro, MA
To Dave Lederer
U.S. EPA
One Congress St., Suite 1100 (HBO)
Boston, MA 02114
Deadline - Postmarked By Wednesday, August 25, 2004
FAX (617) 918 - 1291, No Later Than Wednesday, August 25, 2004
August 2004
I am writing to express my firm opposition to the EPA's proposed plan for the 'cleanup'
of the Shpack Superfund Site.
EPA's preferred alternative (SC-2b) is unacceptable for reasons too numerous to detail
here. Most objectionable is the fact this option does not provide "permanence" and is
therefore not a "remedy". It would leave the Town of Norton with a still contaminated
site, and the responsibility & burdens of dealing with it, in the near and distant future.
In the face of the promise the Environmental Protection Agency made to the town,
EPA's chosen course of action, is reprehensible.
If community acceptance, plays any role in the EPA's decision making process for the
cleanup of Shpack, please give serious consideration to these comments, and select
Alternative SC-3b, which will at long last, give residents of this community the peace of
mind they deserve.
Signature
/
3b ftick
Print Name
Address
fc
-------
Comments to The US EPA on the June 2004 Proposed Plan For the Cleanup of
The Shpack Super-fund Site, Norton/Attleboro, MA
To Dave Lederer
U.S. EPA
One Congress St., Suite 1100 (HBO)
Boston, MA 02114
Deadline - Postmarked By Wednesday, August 25,2004
FAX (617) 918 - 1291, No Later Than Wednesday, August 25, 2004
August 2004
I am writing to express my firm opposition to the EPA's proposed plan for the ¦"cleanup1
of the Shpack Superfund Site.
EPA's preferred alternative (SC-2b) is unacceptable for reasons too numerous to detail
here. Most objectionable is the fact this option does not provide "permanence" and is
therefore not a "remedy". It would leave the Town of Norton with a still contaminated
site, and the responsibility & burdens of dealing with it, in the near and distant future.
In the face of the promise the Environmental Protection Agency made to the town,
EPA's chosen course of action, is reprehensible.
If community acceptance, plays any role in the EPA's decision making process for the
cleanup of Shpack, please give serious consideration to these comments, and select
Alternative SC-3b, which will at long last, give residents of this community the peace of
mind they deserve.
Signature
Print Name filt* fynckif
Address 1%Li /Yleit'n
0, 4/1
-------
Comments to The US EPA on the June 2004 Proposed Plan For the Cleanup of
The Shpack Superfund Site, Norton/Attleboro, MA
To Dave Lederer
U.S. EPA
One Congress St., Suite 1100 (HBO)
Boston, MA 02114
Deadline - Postmarked By Wednesday, August 25, 2004
_ FAX (617) 918-1291, No Later Than Wednesday, August 25, 2004
August 2004
I am writing to express my firm opposition to the EPA's proposed plan for the 'cleanup'
of the Shpack Superfund Site.
EPA's preferred alternative (SC-2b) is unacceptable for reasons too numerous to detail
here. Most objectionable is the fact this option does not provide "permanence" and is
therefore not a "remedy". It would leave the Town of Norton with a still contaminated
site, and the responsibility & burdens of dealing with it, in the near and distant future.
In the face of the promise the Environmental Protection Agency made to the town,
EPA's chosen course of action, is reprehensible.
If community acceptance, plays any role in the EPA's decision making process for the
cleanup of Shpack, please give serious consideration to these comments, and select
Alternative SC-3b, which will at long last, give residents of this community the peace of
mind they deserve.
Signature
Print Name L.U\(X (Sl^cJCUf
Address
-------
Comments to The US EPA on the June 2004 Proposed Plan For the Cleanup of
The Shpack Superfund Site, Norton/Attleboro, MA
To Dave Lederer
U.S. EPA
One Congress St., Suite 1100 (HBO)
Boston, MA 02114
Deadline - Postmarked By Wednesday, August 25, 2004
_ FAX (617) 918-1291, No Later Than Wednesday, August 25, 2004
August 2004
I am writing to express my firm opposition to the EPA's proposed plan for the 'cleanup'
of the Shpack Superfund Site.
EPA's preferred alternative (SC-2b) is unacceptable for reasons too numerous to detail
here. Most objectionable is the fact this option does not provide "permanence" and is
therefore not a "remedy". It would leave the Town of Norton with a still contaminated
site, and the responsibility & burdens of dealing with it, in the near and distant future.
In the face of the promise the Environmental Protection Agency made to the town,
EPA's chosen course of action, is reprehensible.
If community acceptance, plays any role in the EPA's decision making process for the
cleanup of Shpack, please give serious consideration to these comments, and select
Alternative SC-3b, which will at long last, give residents of this community the peace of
mind they deserve.
Print Name
Plkfticjg W- AmrMr
Address fzO ri"J>t ftVt NCtflCA 0J~7(kC>
-------
Comments to The US EPA on the June 2004 Proposed Plan For the Cleanup of
The Shpack Superfund Site. Norton/Attleboro, MA
To Dave I.ederer
U.S. EPA
One Congress St., Suite 1100 (HBO)
Boston, MA 02114
Deadline - Postmarked By Wednesday, August 25, 2004
FAX (617) 918 - 1291, No Later Than Wednesday, August 25, 2004
August 2004
I am writing to express my firm opposition to the EPA's proposed plan for the 'cleanup'
of the Shpack Superfund Site,
EPA's preferred alternative (SC-2b) is unacceptable for reasons too numerous to detail
here. Most objectionable is the fact this option does not provide "permanence" and is
therefore not a "remedy", it would leave the Town of Norton with a still contaminated
site, and the responsibility & burdens of dealing with it, in the near and distant future.
In the face of the promise the Environmental Protection Agency made to the town,
EPA's chosen course of action, is reprehensible.
If community acceptance, plays any role in the EPA's decision making process for the
cleanup of Shpack, please give serious consideration to these comments, and select
Alternative SC-3b, which will at long last, give residents of this community the peace of
mind they deserve.
Print Name
Address ^ J ^ dy C.i roI
/
U>n /vl4 OJloZ £
-------
Comments to The US EPA on the June 2004 Proposed Plan For the Cleanup of
The Shpack Superfund Site. Norton/Attleboro, MA
To Dave Lederer
U.S. EPA
One Congress St., Suite 1100 (HBO)
Boston, MA 02114
Deadline - Postmarked By Wednesday, August 25, 2004
_ FAX (617) 918 - 1291, No Later Than Wednesday, August 2 5, 2004
August 2004
I am writing to express my firm opposition to the EPA's proposed plan for the 'cleanup'
of the Shpack Superfund Site.
EPA's preferred alternative (SC-2b) is unacceptable for reasons too numerous to detail
here. Most objectionable is the fact this option does not provide "permanence" and is
therefore not a "remedy". It would leave the Town of Norton with a still contaminated
site, and the responsibility & burdens of dealing with it, in the near and distant future,
In the face of the promise the Environmental Protection Agency made to the town,
EPA's chosen course of action, is reprehensible.
If community acceptance, plays any role in the EPA's decision making process for the
cleanup of Shpack, please give serious consideration to these comments, and select
Alternative SC-3b, which will at long last, give residents of this community the peace of
mind they deserve.
Signature
Print Name
CJr\ €xJ S a c I ctvT
Address *3 I-] & \ ^ \ 1
AAA .
-------
Comments to The US EPA on the June 2004 Proposed Plan For the Cleanup of
The Shpack Superfund Site, Norton/Attleboro, MA
To Dave Lederer
U.S. EPA
One Congress St., Suite 1100 (HBO)
Boston, MA 02114
Deadline - Postmarked By Wednesday, August 25, 2004
FAX (617) 918 - 1291, No Later Than Wednesday, August 25, 2004
August 2004
I am writing to express my firm opposition to the EPA's proposed plan for the 'cleanup'
of the Shpack Superfund Site,
EPA's preferred alternative (SC-2b) is unacceptable for reasons too numerous to detail
here. Most objectionable is the fact this option does not provide "permanence" and is
therefore not a "remedy". It would leave the Town of Norton with a still contaminated
site, and the responsibility & burdens of dealing with it, in the near and distant future.
In the face of the promise the Environmental Protection Agency made to the town,
EPA's chosen course of action, is reprehensible.
If community acceptance, plays any role in the EPA's decision making process for the
cleanup of Shpack, please give serious consideration to these comments, and select
Alternative SC-3b, which will at long last, give residents of this community the peace of
mind they deserve.
Signature
Address F M- 5 t
fJoJr i ok , A4 /* o If 66 - ST" 33
I ¦
-------
Comments to The US EPA on the June 2004 Proposed Plan For the Cleanup of
The Shpack Super-fund Site, Norton/Attleboro, MA
To Dave Lederer
U.S. EPA
One Congress St., Suite 1100 (HBO)
Boston, MA 02114
Deadline - Postmarked By Wednesday, August 25, 2004
FAX (617) 918- 1291, No Later Than Wednesday, August 25, 2004
August 2004
I am writing to express my firm opposition to the EPA's proposed plan for the 'cleanup'
of the Shpack Superfund Site,
EPA's preferred alternative (SC-2b) is unacceptable for reasons too numerous to detail
here. Most objectionable is the fact this option does not provide "permanence" and is
therefore not a "remedy". It would leave the Town of Norton with a still contaminated
site, and the responsibility 8c burdens of dealing with it, in the near and distant future.
In the face of the promise the Environmental Protection Agency made to the town,
EPA's chosen course of action, is reprehensible.
If community acceptance, plays any role in the EPA's decision making process for the
cleanup of Shpack, please give serious consideration to these comments, and select
Alternative SC-3b, which will at long last, give residents of this community the peace of
mind they deserve.
Address /7ls?
-------
Comments to The US EPA on the June 2004 Proposed Plan For the Cleanup of
The Shpack Superfund Site. Norton/Attleboro, MA
To Dave Lederer
U.S. EPA
One Congress St., Suite 1100 (HBO)
Boston, MA 02114
Deadline - Postmarked By Wednesday, August 25, 2004
FAX (617) 918 - 1291, No Later Than Wednesday, August 25, 2004
August 2004
1 am writing to express my firm opposition to the EPA's proposed plan for the 'cleanup'
of the Shpack Superfund Site.
EPA's preferred alternative (SC-2b) is unacceptable for reasons too numerous to detail
here. Most objectionable is the fact this option does not provide "permanence" and is
therefore not a "remedy". It would leave the Town of Norton with a still contaminated
site, and the responsibility & burdens of dealing with it, in the near and distant future.
In the face of the promise the Environmental Protection Agency made to the town,
EPA's chosen course of action, is reprehensible.
If community acceptance, plays any role in the EPA's decision making process for the
cleanup of Shpack, please give serious consideration to these comments, and select
Alternative SC-3b, which will at long last, give residents of this community the peace of
mind they deserve.
Signature
PrintName A"
Address / is tc/z *Sg#
Qj&$TtJcrVc/ QXO^O
-------
Comments to The US EPA on the June 2004 Proposed Plan For the Cleanup of
The Shpack Superfimd Site, Norton'Attleboro, MA
To Dave Lederer
U.S. EPA
One Congress St., Suite 1100 (HBO)
Boston, MA 02114
Deadline - Postmarked By Wednesday, August 25, 2004
FAX (617) 918 - 1291, No Later Than Wednesday, August 25, 2004
August 2004
I am writing to express my firm opposition to the EPA's proposed plan for the 'cleanup'
of the Shpack Superfund Site.
EPA's preferred alternative (SC-2b) is unacceptable for reasons too numerous to detail
here. Most objectionable is the fact this option does not provide "permanence" and is
therefore not a "remedy". It would leave the Town of Norton with a still contaminated
site, and the responsibility & burdens of dealing with it, in the near and distant future.
In the face of the promise the Environmental Protection Agency made to the town,
EPA's chosen course of action, is reprehensible.
If community acceptance, plays any role in the EPA's decision making process for the
cleanup of Shpack, please give serious consideration to these comments, and select
Alternative SC-3b, which will at long last, give residents of this community the peace of
mind they deserve.
Print Name
Address 3 ^ '
Q/76Q
-------
Comments to The US EPA on the June 2004 Proposed Plan For the Cleanup of
The Shpack Superfund Site, Norton/Attleboro, MA
To Dave Lederer
U.S. EPA
One Congress St., Suite 1100 (HBO)
Boston, MA 02114
Deadline - Postmarked By Wednesday, August 25,2004
FAX (617) 918 - 1291, No Later Than Wednesday, August 25, 2004
August 2004
I am writing to express ray firm opposition to the EPA's proposed plan for the 'cleanup5
of the Shpack Superfund Site.
EPA's preferred alternative (SC-2b) is unacceptable for reasons too numerous to detail
here. Most objectionable is the fact this option does not provide "permanence" and is
therefore not a "remedy". It would leave the Town of Norton with a still contaminated
site, and the responsibility & burdens of dealing with it, in the near and distant future,
In the face of the promise the Environmental Protection Agency made to the town,
EPA's chosen course of action, is reprehensible.
If community acceptance, plays any role in the EPA's decision making process for the
cleanup of Shpack, please give serious consideration to these comments, and select
Alternative SC-3b, which will at long last, give residents of this community the peace of
mind they deserve.
-------
Comments to The US EPA on the June 2004 Proposed Plan For the Cleanup of
The Shpack Superfimd Site, Norton/Attleboro, MA
To Dave Lederer
U.S. EPA
One Congress St., Suite 1100 (HBO)
Boston, MA 02114
Deadline - Postmarked By Wednesday, August 25, 2004
FAX (617) 918 - 1291, No Later Than Wednesday, August 25, 2004
August 2004
I am writing to express my firm opposition to the EPA's proposed plan for the 'cleanup'
of the Shpack Superfimd Site.
EPA's preferred alternative (SC-2b) is unacceptable for reasons too numerous to detail
here. Most objectionable is the fact this option does not provide "permanence" and is
therefore not a "remedy". It would leave the Town of Norton with a still contaminated
site, and the responsibility & burdens of dealing with it, in the near and distant future.
In the face of the promise the Environmental Protection Agency made to the town,
EPA's chosen course of action, is reprehensible.
If community acceptance, plays any role in the EPA's decision making process for the
cleanup of Shpack, please give serious consideration to these comments, and select
Alternative SC-3b, which will at long last, give residents of this community the peace of
mind they deserve.
Signature
plaid
HU* f~\ ,
a . Q> i n a ^
¦#
c4s> feyxd-fifljcJLj
Print Name
Address
fYlft CQjS 1Q
-------
Comments to The US EPA on the June 2004 Proposed Plan For the Cleanup of
The Shpack Superfund Site, Norton/Attleboro, MA
To Dave I.ederer
U.S. EPA
One Congress St., Suite 1100 (HBO)
Boston, MA 02114
Deadline - Postmarked By Wednesday, August 25, 2004
FAX (617) 918 - 1291, No Later Than Wednesday, August 25, 2004
August 2004
I am writing to express my firm opposition to the EPA's proposed plan for the 'cleanup'
of the Shpack Superfund Site.
EPA's preferred alternative (SC-2b) is unacceptable for reasons too numerous to detail
here. Most objectionable is the fact this option does not provide "permanence" and is
therefore not a "remedy". It would leave the Town of Norton with a still contaminated
site, and the responsibility & burdens of dealing with it, in the near and distant future.
In the face of the promise the Environmental Protection Agency made to the town.
EPA's chosen course of action, is reprehensible.
If community acceptance, plays any role in the EPA's decision making process for the
cleanup of Shpack, please give serious consideration to these comments, and select
Alternative SC-3b, which will at long last, give residents of this community the peace of
mind they deserve.
Signature
'al^/OAU.
7
Print Name
^ fyncJa / if
Address
Qu'mtu, Afo 02J(„ q
-------
Comments to The US EPA on the June 2004 Proposed Plan For the Cleanup of
The Shpack Superfund Site. Norton/Attleboro, MA
To Dave Lederer
U.S. EPA
One Congress St., Suite 1100 (HBO)
Boston, MA 02114
Deadline - Postmarked By Wednesday, August 25, 2004
FAX (617) 918 - 1291, No Later Than Wednesday, August 25, 2004
August 2004
I am writing to express my firm opposition to the EPA's proposed plan for the 'cleanup'
of the Shpack Superfund Site.
EPA's preferred alternative (SC-2b) is unacceptable for reasons too numerous to detail
here. Most objectionable is the fact this option does not provide "permanence" and is
therefore not a "remedy". It would leave the Town of Norton with a still contaminated
site, and the responsibility & burdens of dealing with it, in the near and distant future.
In the face of the promise the Environmental Protection Agency made to the town,
EPA's chosen course of action, is reprehensible.
If community acceptance, plays any role in the EPA's decision making process for the
cleanup of Shpack, please give serious consideration to these comments, and select
Alternative SC-3b, which will at long last, give residents of this community the peace of
mind they deserve.
Print Name
Address --2 /'.j/z/e&TJ' (jy
m*?.
-------
Comments to The US EPA on the June 2004 Proposed Plan For the Cleanup of
The Shpack Superfund Site, Norton/Attleboro, MA
To Dave Lederer
U.S. EPA
One Congress St., Suite 1100 (HBO)
Boston, MA 02114
Deadline - Postmarked By Wednesday, August 25, 2004
FAX (617) 918 - 1291, No Later Than Wednesday, August 25, 2004
August 2004
1 am writing to express my firm opposition to the EPA's proposed plan for the 'cleanup'
of the Shpack Superfund Site.
EPA's preferred alternative (SC-2b) is unacceptable for reasons too numerous to detail
here. Most objectionable is the fact this option does not provide "permanence" and is
therefore not a "remedy". It would leave the Town of Norton with a still contaminated
site, and the responsibility & burdens of dealing with it, in the near and distant future.
In the face of the promise the Environmental Protection Agency made to the town,
EPA's chosen course of action, is reprehensible.
If community acceptance, plays any role in the EPA's decision making process for the
cleanup of Shpack, please give serious consideration to these comments, and select
Alternative SC-3b, which will at long last, give residents of this community the peace of
mind they deserve.
Signatur
Print Name
Address
-------
Comments to The US EPA on the June 2004 Proposed Plan For the Cleanup of
The Shpaek Superfund Site, Norton/Attleboro, MA
To Dave Lederer
U.S. EPA
One Congress St., Suite 1100 (HBO)
Boston, MA 02114
Deadline - Postmarked By Wednesday, August 25, 2004
FAX (617)918- 1291, No Later Than Wednesday, August 25,2004
August 2004
I am writing to express my firm opposition to the EPA's proposed plan for the 'cleanup'
of the Shpaek Superfund Site,
EPA's preferred alternative (SC-2b) is unacceptable for reasons too numerous to detail
here. Most objectionable is the fact this option does not provide "permanence" and is
therefore not a "remedy". It would leave the Town of Norton with a still contaminated
site, and the responsibility & burdens of dealing with it, in the near and distant future.
In the face of the promise the Environmental Protection Agency made to the town,
EPA's chosen course of action, is reprehensible.
If community acceptance, plays any role in the EPA's decision making process for the
cleanup of Shpaek, please give serious consideration to these comments, and select
Alternative SC-3b, which will at long last, give residents of this community the peace of
mind they deserve.
Signature Mr
7) TT
Print Name
Address
f p\s . Uc ! OS^D
-------
Comments to The US EPA on the June 2004 Proposed Plan For the Cleanup of
The Shpack Superfund Site, Norton/Attleboro, MA
To Dave Lederer
U.S. EPA
One Congress St., Suite 1100 (HBO)
Boston, MA 02114
Deadline - Postmarked By Wednesday, August 25, 2004
FAX (617) 918 - 1291, No Later Than Wednesday, August 25, 2004
August 2004
I am writing to express my firm opposition to the EPA's proposed plan for the 'cleanup'
of the Shpack Superfund Site,
EPA's preferred alternative (SC-2b) is unacceptable for reasons too numerous to detail
here. Most objectionable is the fact this option does not provide "permanence" and is
therefore not a "remedy". It would leave the Town of Norton with a still contaminated
site, and the responsibility & burdens of dealing with it, in the near and distant future.
In the face of the promise the Environmental Protection Agency made to the town,
EPA's chosen course of action, is reprehensible.
If community acceptance, plays any role in the EPA's decision making process for the
cleanup of Shpack, please give serious consideration to these comments, and select
Alternative SC-3b, which will at long last, give residents of this community the peace of
mind they deserve,
Signature
Print Name
Address
-------
Comments to The US EPA on the June 2004 Proposed Plan For the Cleanup of
The Shpack Super-fund Site, Norton/Attleboro, MA
To Dave Lederer
U.S. EPA
One Congress St., Suite 1100 (HBO)
Boston, MA 02114
Deadline - Postmarked By Wednesday, August 25, 2004
FAX (617) 918 - 1291, No Later Than Wednesday, August 25, 2004
August 2004
I am writing to express my firm opposition to the EPA's proposed plan for the 'cleanup'
of the Shpack Superfund Site.
EPA's preferred alternative (SC-2b) is unacceptable for reasons too numerous to detail
here. Most objectionable is the fact this option does not provide "permanence1'1 and is
therefore not a "remedy". It would leave the Town of Norton with a still contaminated
site, and the responsibility & burdens of dealing with it, in the near and distant future.
In the face of the promise the Environmental Protection Agency made to the town,
EPA's chosen course of action, is reprehensible.
If community acceptance, plays any role in the EPA's decision making process for the
cleanup of Shpack, please give serious consideration to these comments, and select
Alternative SC-3b, which will at long last, give residents of this community the peace of
mind they deserve.
Print Name
Address
Attlep,6£$ MA- teva?
-------
Comments to 'l'he US EPA on the June 2004 Proposed Plan For the Cleanup of
The Shpack Superfund Site, Norton/Attleboro, MA
To Dave Lederer
U.S. EPA
One Congress St., Suite 1100 (HBO)
Boston, MA 02114
Deadline - Postmarked By Wednesday, August 25, 2004
_ FAX (617) 918 - 1291, No Later Than Wednesday, August 25, 2004
August 2004
I am writing to express my firm opposition to the EPA's proposed plan for the 'cleanup'
of the Shpack Superfund Site.
EPA's preferred alternative (SC-2b) is unacceptable for reasons too numerous to detail
here. Most objectionable is the fact this option does not provide "permanence" and is
therefore not a "remedy". It would leave the Town of Norton with a still contaminated
site, and the responsibility & burdens of dealing with it, in the near and distant future.
In the face of the promise the Environmental Protection Agency made to the town,
EPA's chosen course of action, is reprehensible.
if community acceptance, plays any role in the EPA's decision making process for the
cleanup of Shpack, please give serious consideration to these comments, and select
Alternative SC-3b, which will at long last, give residents of this community the peace of
mind they deserve.
Print Name Stq /"£
Address S ® H//£• H/*!-'-/
^ — i ¦ in.
-------
Comments to The US EPA on the June 2004 Proposed Plan For the Cleanup of
The Shpack Superfund Site, Norton/Attleboro, MA
To Dave Lederer
U.S. EPA
One Congress St., Suite 1100 (HBO)
Boston, MA 02 U 4
Deadline - Postmarked By Wednesday, August 25, 2004
FAX (617) 918 - 1291, No Later Than Wednesday, August 25, 2004
August 2004
I am writing to express my firm opposition to the EPA's proposed plan for the 'cleanup'
of the Shpack Superfund Site,
EPA's preferred alternative (SC-2b) is unacceptable for reasons too numerous to detail
here. Most objectionable is the fact this option does not provide "permanence" and is
therefore not a "remedy". It would leave the Town of Norton with a still contaminated
site, and the responsibility & burdens of dealing with it, in the near and distant future.
In the face of the promise the Environmental Protection Agency made to the town,
EPA's chosen course of action, is reprehensible.
If community acceptance, plays any role in the EPA's decision making process for the
cleanup of Shpack, please give serious consideration to these comments, and select
Alternative SC-3b, which will at long last, give residents of this community the peace of
mind they deserve.
Signature^ ^ ^^
Print Name Ch f \ MfrjW",Sap
a€ i
Address ?|| -/W
- Wl-ft
-------
Comments to The US EPA on the June 2004 Proposed Plan For the Cleanup of
The Shpack Super fund Site, Norton/ Attleboro, MA
To Dave Lederer
U.S. EPA
One Congress St., Suite 1100 (HBO)
Boston, MA 02114
Deadline - Postmarked By Wednesday, August 25, 2004
FAX (617)918-1291 , No Later Than Wednesday, August 25, 2004
August 2004
I am writing to express my firm opposition to the EPA's proposed plan for the 'cleanup'
of the Shpack Superfund Site.
EPA's preferred alternative (SC-2b) is unacceptable for reasons too numerous to detail
here. Most objectionable is the fact this option does not provide "permanence" and is
therefore not a "remedy". It would leave the Town of Norton with a still contaminated
site, and the responsibility & burdens of dealing with it, in the near and distant future.
In the face of the promise the Environmental Protection Agency made to the town,
EPA's chosen course of action, is reprehensible.
If community acceptance, plays any role in the EPA's decision making process for the
cleanup of Shpack, please give serious consideration to these comments, and select
Alternative SC-3b, which will at long last, give residents of this community the peace of
mind they deserve,
Signature
Print Name &-Yl \j(X ,S
Address 15 ^iU.oraJ Cm if.
Ot
1
-------
Comments to The US EPA on the June 2004 Proposed Plan For the Cleanup of
The Shpack Super-fund Site, Norton/Attleboro, MA
To Dave Lederer
U.S. EPA
One Congress St., Suite 1100 (HBO)
Boston, MA 02114
Deadline - Postmarked By Wednesday, August 25, 2004
FAX (617) 918 - 1291, No Later Than Wednesday, August 25, 2004
August 2004
I am writing to express my firm opposition to the EPA's proposed plan for the 'cleanup'
of the Shpack Superfund Site.
EPA's preferred alternative (SC-2b) is unacceptable for reasons too numerous to detail
here. Most objectionable is the fact this option does not provide "permanence" and is
therefore not a "remedy". It would leave the Town of Norton with a still contaminated
site, and the responsibility & burdens of dealing with it, in the near and distant future,
In the face of the promise the Environmental Protection Agency made to the town,
EPA's chosen course of action, is reprehensible.
If community acceptance, plays any role in the EPA's decision making process for the
cleanup of Shpack, please give serious consideration to these comments, and select
Alternative SC-3b, which will at long last, give residents of this community the peace of
mind they deserve.
Signature
Print Name l/Vi
Add]
-------
Comments to The US EPA on the June 2004 Proposed Plan For the Cleanup of
The Shpack Superfund Site, Norton/Attleboro, MA
To Dave Lederer
U.S. EPA
One Congress St., Suite 1100 (HBO)
Boston, MA 02114
Deadline - Postmarked By Wednesday, August 25, 2004
FAX (617) 918 - 1291, No Later Than Wednesday, August 25, 2004
August 2004
I am writing to express my firm opposition to the EPA's proposed plan for the 'cleanup'
of the Shpack Superfund Site.
EPA's preferred alternative (SC-2b) is unacceptable for reasons too numerous to detail
here. Most objectionable is the fact this option does not provide "permanence" and is
therefore not a "remedy". It would leave the Town of Norton with a still contaminated
site, and the responsibility & burdens of dealing with it, in the near and distant future.
In the face of the promise the Environmental Protection Agency made to the town,
EPA's chosen course of action, is reprehensible.
If community acceptance, plays any role in the EPA's decision making process for the
cleanup of Shpack, please give serious consideration to these comments, and select
Alternative SC-3b, which will at long last, give residents of this community the peace of
mind they deserve.
Print Name
21 ft 1 >4
Address / rK 4~ / / Sr. Sr.
I——MM——
L-
-------
Comments to The US EPA on the June 2004 Proposed Plan For the Cleanup of
The Shpack Superfund Site, Norton/Attleboro, MA
To Dave Lederer
U.S. EPA
One Congress St., Suite 1100 (HBO)
Boston, MA 02114
Deadline - Postmarked By Wednesday, August 25,2004
FAX {617)918- 1291, No Later Than Wednesday, August 25, 2004
August 2004
I am writing to express my firm opposition to the EPA's proposed plan for the 'cleanup'
of the Shpack Superfund Site.
EPA's preferred alternative (SC-2b) is unacceptable for reasons too numerous to detail
here. Most objectionable is the fact this option does not provide "permanence" and is
therefore not a "remedy". It would leave the Town of Norton with a still contaminated
site, and the responsibility & burdens of dealing with it, in the near and distant future.
In the face of the promise the Environmental Protection Agency made to the town,
EPA's chosen course of action, is reprehensible.
If community acceptance, plays any role in the EPA's decision making process for the
cleanup of Shpack, please give serious consideration to these comments, and select
Alternative SC-3b, which will at long last, give residents of this community the peace of
mind they deserve.
Signature PAM AAJ
iM
IAJ,
-------
Comments to The US EPA on the June 2004 Proposed Plan For the Cleanup of
The Shpack Superfund Site, Norton/Attleboro, MA
To Dave Lederer
U.S. EPA
One Congress St., Suite 1100 (HBO)
Boston, MA 02114
Deadline - Postmarked By Wednesday, August 25, 2004
FAX (617) 918 - 1291» No Later Than Wednesday, August 25,2004
August 2004
I am writing to express my firm opposition to the EPA's proposed plan for the "cleanup1
of the Shpack Superlund Site.
EPA's preferred alternative (SC-2b) is unacceptable for reasons too numerous to detail
here. Most objectionable is the fact this option does not provide "permanence" and is
therefore not a "remedy". It would leave the Town of Norton with a still contaminated
site, and the responsibility & burdens of dealing with it, in the near and distant future.
In the face of the promise the Environmental Protection Agency made to the town,
EPA's chosen course of action, is reprehensible.
If community acceptance, plays any role in the EPA's decision making process for the
cleanup of Shpack, please give serious consideration to these comments, and select
Alternative SC-3b, which will at long last, give residents of this community the peace of
mind they deserve.
Signature
Print Name (\hS!katov \^o\( y-
Address **73 ^PCCO
i naimjp
(\/\ A- O{S0H
-------
Comments to The US EPA on the June 2004 Proposed Plan For the Cleanup of
The Shpack Superfund Site, Norton/Attleboro, MA
To Dave Lederer
U.S. EPA
One Congress St., Suite 1100 (HBO)
Boston, MA 02114
Deadline - Postmarked By Wednesday, August 25, 2004
FAX (617) 918 - 1291, No Later Than Wednesday, August 25, 2004
August 2004
I am writing to express my firm opposition to the EPA's proposed plan for the "cleanup'
of the Shpack Superfund Site.
EPA's preferred alternative (SC-2b) is unacceptable for reasons too numerous to detail
here. Most objectionable is the fact this option does not provide "permanence" and is
therefore not a "remedy". It would leave the Town of Norton with a still contaminated
site, and the responsibility & burdens of dealing with it, in the near and distant future,
In the face of the promise the Environmental Protection Agency made to the town,
EPA's chosen course of action, is reprehensible.
If community acceptance, plays any role in the EPA's decision making process for the
cleanup of Shpack. please give serious consideration to these comments, and select
Alternative SC-3b, which will at long last, give residents of this community the peace of
mind they deserve.
Signature A
Print Name
Address
Qi AOJl t
-------
Comments to The US EPA on the June 2004 Proposed Plan For the Cleanup of
The Shpack Superfund Site, Norton/Attleboro, MA
To Dave Lederer
U.S. EPA
One Congress St., Suite 1100 (HBO)
Boston, MA 02114
Deadline - Postmarked By Wednesday, August 25, 2004
FAX (617) 918 - 1291, No Later Than Wednesday, August 25, 2004
August 2004
I am writing to express my firm opposition to the EPA's proposed plan for the 'cleanup'
of the Shpack Superfimd Site.
EPA's preferred alternative (SC-2b) is unacceptable for reasons too numerous to detail
here. Most objectionable is the fact this option does not provide "permanence" and is
therefore not a "remedy". It would leave the Town of Norton with a still contaminated
site, and the responsibility & burdens of dealing with it, in the near and distant future.
In the face of the promise the Environmental Protection Agency made to the town,
EPA's chosen course of action, is reprehensible.
If community acceptance, plays any role in the EPA's decision making process for the
cleanup of Shpack, please give serious consideration to these comments, and select
Alternative SC-3b, which will at long last, give residents of this community the peace of
mind they deserve.
Signature
LQmtljls
(X,. [AjOAyCJuU^.
Print Name
Address
AIdtLWN 6 a
-------
Comments to The US EPA on the June 2004 Proposed Plan For the Cleanup of
The Shpack Superfimd Site, Norton/Attleboro, MA
To Dave Lederer
U.S. EPA
One Congress St., Suite 1100 (HBO)
Boston, MA 02114
Deadline - Postmarked By Wednesday, August 25,2004
FAX (617) 918 - 1291, No Later Than Wednesday, August 25,2004
August 2004
I am writing to express my firm opposition to the EPA's proposed plan for the 'cleanup'
of the Shpack. Superfimd Site.
EPA's preferred alternative (SC-2b) is unacceptable for reasons too numerous to detait
here. Most objectionable is the fact this option does not provide "permanence" and is
therefore not a "remedy". It would leave the Town of Norton with a still contaminated
site, and the responsibility & burdens of dealing with it, in the near and distant future.
In the face of the promise the Environmental Protection Agency made to the town,
EPA's chosen course of action, is reprehensible.
If community acceptance, plays any role in the EPA's decision making process for the
cleanup of Shpack, please give serious consideration to these comments, and select
Alternative SC-3b, which will at long last, give residents of this community the peace of
mind they deserve.
Signature
Print Name K*fA f-M j
Address dip % IdjjJ. (~^X
^ ^
miP (B93&
-------
Comments to The US EPA on the June 2004 Proposed Plan For the Cleanup of
The Shpack Superfund Site, Norton/Attleboro, MA
To Dave Lederer
U.S. EPA
One Congress St., Suite 1100 (HBO)
Boston, MA 02114
Deadline - Postmarked By Wednesday, August 25, 2004
FAX (617) 918 - 1291, No Later Than Wednesday, August 25, 2004
August 2004
1 am writing to express ray firm opposition to the EPA's proposed plan for the 'cleanup'
of the Shpack Superfund Site,
EPA's preferred alternative (SC-2b) is unacceptable for reasons too numerous to detail
here. Most objectionable is the fact this option does not provide "permanence" and is
therefore not a "remedy". It would leave the Town of Norton with a still contaminated
site, and the responsibility & burdens of dealing with it, in the near and distant future.
In the face of the promise the Environmental Protection Agency made to the town,
EPA's chosen course of action, is reprehensible.
If community acceptance, plays any role in the EPA's decision making process for the
cleanup of Shpack, please give serious consideration to these comments, and select
Alternative SC-3b, which will at long last, give residents of this community the peace of
mind they deserve.
Signature
Print Name D/XtCO L0-LLbij
Address
Pitf in (LA/ St
-------
Comments to The m pcm
Shpack ^Pofund SkcNwoTf 2°°4 ProP°s«' Plan F ,h
T tC'^"^AWeboro, MA For Cleanup of
U.S. EM rCT
B2°LaMAeS02T,4SUite " °° (HB°)
^ Wednesday, Augus,25 20C4
August 2004
Shpi); SuJSdSite™ 0pposi"'°n to the EPA's „
^ is ra EPA S~P'» for the "cleanup'
& respr?"'',S' ^Ie^v7tte0/d^n°'VrnT™"' '° "**"
the face on? b,'ily & b"rdens nfH , ^ of N°rton with^?,?"**" and «
EPA'c , the promise the /•„ • fdea}«g with it in th IJ Comaminaterf
couree w:ardistam ^
»miuiu(y acceptarirp „r rePrenensjbJe ^ y ma^e to the taum
A&lsc 3?'"H^""SS'con"'d"EPA'5«-*'*<» maid™
.Hey de Jeb' "» «' W
COmmun^ the peace of
Signatu
-------
Comments to The US EPA on the June 2004 Proposed Plan For the Cleanup of
The Shpack Superfund Site, Norton/Attleboro, MA
To Dave Lederer
U.S. EPA
One Congress St., Suite 1100 (HBO)
Boston, MA 02114
Deadline - Postmarked By Wednesday, August 25, 2004
FAX (617) 918 - 1291, No Later Than Wednesday, August 25, 2004
August 2004
I am writing to express my firm opposition to the EPA's proposed plan for the 'cleanup'
of the Shpack Superfund Site.
EPA's preferred alternative (SC-2b) is unacceptable for reasons too numerous to detail
here. Most objectionable is the fact this option does not provide "permanence" and is
therefore not a "remedy". It would leave the Town of Norton with a still contaminated
site, and the responsibility & burdens of dealing with it, in the near and distant future.
In the face of the promise the Environmental Protection Agency made to the town,
EPA's chosen course of action, is reprehensible.
If community acceptance, plays any role in the EPA's decision making process for the
cleanup of Shpack, please give serious consideration to these comments, and select
Alternative SC-3b, which will at long last, give residents of this community the peace of
mind they deserve.
Signature
Print Name
Address /-/y BU'l-iciel/ Dr / 13 M Qn/r.
WonJJ !\/ii (Motionj llt a Oj.74,6
-------
Comments to The US EPA on the June 2004 Proposed Plan For the Cleanup of
The Shpack Super!und Site, Norton/Attleboro, MA
To Dave Lederer
U.S. EPA
One Congress St., Suite 1100 (HBO)
Boston, MA 02114
Deadline - Postmarked By Wednesday, August 25,2004
FAX (617) 918 - 1291, No Later Than Wednesday, August 25, 2004
August 2004
I arn writing to express my firm opposition to the EPA's proposed plan for the 'cleanup'
of the Shpaek Superfund Site.
EPA's preferred alternative (SC-2b) is unacceptable for reasons too numerous to detail
here. Most objectionable is the fact this option does not provide "permanence" and is
therefore not a "remedy". It would leave the Town of Norton with a still contaminated
site, and the responsibility & burdens of dealing with it, in the near and distant future.
In the face of the promise the Environmental Protection Agency made to the town,
EPA's chosen course of action, is reprehensible.
If community acceptance, plays any role in the EPA's decision making process for the
cleanup of Shpack, please give serious consideration to these comments, and select
Alternative SC-3b, which will at long last, give residents of this community the peace of
mind they deserve.
Signature ^
Print Name
L^An/e L. WHY4/0 7~~
Address
[\iefi-TtN MA . 0 2-1 £6
-------
Comments to The US EPA on the June 2004 Proposed Plan For the Cleanup of
The Shpack Superfund Site, Norton/Attleboro, MA
To Dave Lederer
U.S. EPA
One Congress St., Suite 1100 (HBO)
Boston, MA 02114
Deadline - Postmarked By Wednesday, August 25,2004
FAX (617) 918 - 1291, No Later Than Wednesday, August 25, 2004
August 2004
I am writing to express my firm opposition to the EPA's proposed plan for the 'cleanup'
of the Shpack Superfund Site,
EPA's preferred alternative (SC-2b) is unacceptable for reasons too numerous to detail
here. Most objectionable is the fact this option does not provide "permanence" and is
therefore not a "remedy". It would leave the Town of Norton with a still contaminated
site, and the responsibility & burdens of dealing with it, in the near and distant future,
in the face of the promise the Environmental Protection Agency made to the town,
EPA's chosen course of action, is reprehensible.
If community acceptance, plays any role in the EPA's decision making process for the
cleanup of Shpack, please give serious consideration to these comments, and select
Alternative SC-3b, which will at long last, give residents of this community the peace of
mind they deserve.
/I
/ ' y
Signature
Print Name
Address
l/ /Vf? o ^7/
-------
Comments to The US EPA on the June 2004 Proposed Plan For the Cleanup of
The Shpack Superftmd Site, Norton/Attleboro, MA
To Dave Lederer
U.S. EPA
One Congress St., Suite 1100 (HBO)
Boston, MA 02114
Deadline - Postmarked By Wednesday, August 25, 2004
FAX (617) 918 - 1291, No Later Than Wednesday, August 25,2004
August 2004
I am writing to express my firm opposition to the EPA's proposed plan for the 'cleanup'
of the Shpaek Superftmd Site.
EPA's preferred alternative (SC-2b) is unacceptable for reasons too numerous to detail
here. Most objectionable is the fact this option does not provide "permanence" and is
therefore not a "remedy". It would leave the Town of Norton with a still contaminated
site, and the responsibility & burdens of dealing with it, in the near and distant future.
In the face of the promise the Environmental Protection Agency made to the town,
EPA's chosen course of action, is reprehensible.
If community acceptance, plays any role in the EPA's decision making process for the
cleanup of Shpack, please give serious consideration to these comments, and select
Alternative SC-3b, which will at long last, give residents of this community the peace of
mind they deserve.
Signature
Print Name
-------
Comments to The US EPA on the June 2004 Proposed Plan For the Cleanup of
The Shpack Superfimd Site, Norton/Attleboro, MA
To Dave Lederer
U.S. EPA
One Congress St., Suite 1100 (HBO)
Boston, MA 02114
Deadline - Postmarked By Wednesday, August 25, 2004
FAX (617) 918 - 1291, No Later Than Wednesday. August 25,2004
August 2004
I am writing to express my firm opposition to the EPA's proposed plan for the 'cleanup'
of the Shpack Superfund Site.
EPA's preferred alternative (SC-2b) is unacceptable for reasons too numerous to detail
here. Most objectionable is the fact this option does not provide "permanence" and is
therefore not a "remedy". It would leave the Town of Norton with a still contaminated
site, and the responsibility & burdens of dealing with it, in the near and distant future.
In the face of the promise the Environmental Protection Agency made to the town,
EPA's chosen course of action, is reprehensible.
If community acceptance, plays any role in the EPA's decision making process for the
cleanup of Shpack, please give serious consideration to these comments, and select
Alternative SC-3b, which will at long last, give residents of this community the peace of
mind they deserve.
Signature
Print Name
/ A, UJtbhi-f
Address
^ QX7t*(o
d 1395 'O^
'5U1 '-S3IAJJ5 ! !&!*?- '1 e J1A E ^ 7J0C "5
-------
Comments to The US EPA on the June 2004 Proposed Plan For the Cleanup of
The Shpack Superfuiul Site, Norton/Attleboro, MA
To Dave Lederer
U.S. EPA
One Congress St, Suite 1100 (HBO)
Boston, MA 02114
Deadline - Postmarked By Wednesday, August 25, 2004
FAX (617) 918 - 1291, No Later Than Wednesday, August 25,2004
August 2004
I am writing to express my firm opposition to the EPA's proposed plan for the 'cleanup'
of the Shpack Superfund Site.
EPA's preferred alternative (SC-2b) is unacceptable for reasons too numerous to detail
here. Most objectionable is the fact this option does not provide "permanence" and is
therefore not a "remedy". It would leave the Town of Norton with a still contaminated
site, and the responsibility & burdens of dealing with it, in the near and distant future.
In the face of the promise the Environmental Protection Agency made to the town,
EPA's chosen course of action, is reprehensible.
If community acceptance, plays any role in the EPA's decision making process for the
cleanup of Shpack, please give serious consideration to these comments, and select
Alternative SC-3b, which will at long last, give residents of this community the peace of
mind they deserve.
/
Signature
Print Name
Address
'1\ 6-q Jetty 'ST
-------
Comments to The US EPA on the June 2004 Proposed Plan For the Cleanup of
The Shpack Superfund Site, Norton/Attleboro, MA
To Dave Lederer
U.S. EPA
One Congress St., Suite 1100 (HBO)
Boston, MA 02114
Deadline - Postmarked By Wednesday, August 25, 2004
FAX (617) 918- 1291, No Later Than Wednesday, August 25,2004
August 2004
f arh writing to express my firm opposition to the EPA's proposed plan for the -cleanup- - -
of the Shpack Superfund Site. , -
EPA's preferred alternative (SC-2b) is unacceptable for reasons too numerous to detail
here. Most objectionable is the fact this option does not provide "permanence" and is
therefore not a "remedy*". It would leave the Town of Norton with a still contaminated
site, and the responsibility & burdens of dealing with it, in the near and distant future.
In the face of the promise the Environmental Protection Agency made to the town,
EPA's chosen course of action, is reprehensible.
If community acceptance, plays any role in the EPA's decision making process for the
cleanup of Shpack, please give serious consideration to these comments, and select
Alternative SC*3b, which will at long last, give residents of this community the peace of
mind they deserve.
Signature 7lamu mul&Ad
Print Name Nicm/ WtUakd
Address 3 S-atz Ldnc
0>S Cob, C.T (iisHJl
-------
Comments to The US EPA on the June 2004 Proposed Plan For the Cleanup of
The Shpack Superfund Site, Norton/Attleboro, MA
To Dave Lederer
U.S. EPA
One Congress St., Suite 1100 (HBO)
Boston, MA 02114
Deadline - Postmarked By Wednesday, August 25,2004
FAX (617) 918 - 1291, No Later Than Wednesday, August 25, 2004
August 2004
1 am writing to express my firm opposition to the EPA's proposed plan for the 'cleanup'
of the Shpack Superfund Site.
EPA's preferred alternative (SC-2b) is unacceptable for reasons too numerous to detail
here. Most objectionable is the fact this option does not provide "permanence" and is
therefore not a "remedy". It would leave the Town of Norton with a still contaminated
site, and the responsibility & burdens of dealing with it, in the near and distant future.
In the face of the promise the Environmental Protection Agency made to the town,
EPA's chosen course of action, is reprehensible.
If community acceptance, plays any role in the EPA's decision making process for the
cleanup of Shpack, please give serious consideration to these comments, and select
Alternative SC-3b, which will at long last, give residents of this community the peace of
mind they deserve.
Signature
Print Name
jL/j.fi/ //e Mi bf /
Address
J M-
T
-------
PHONE NO. ; 15082262835
Aug. 05 2004 11;53PM PI
HEATHER A. GRAF, COORDINATOR , S.
CASI *¦' Y'/
CITIZENS ADVISORY SHPACK TEAM _
229 N. Worcester St.
Norton, MA 02766
FAX (SOS) 226 - 2835
Phone (508) 226-0898
FAX
mi iK,
(is
fax: (*1*1 - 9/
-------
A toxic legacy leaves
Norton demanding
Waste not
By MIKE STUCKA
Gazette Staff Writer
NORTON — Ghosts of Norton's past lie
just under the surface of the Attleboro/Norton
line. A mix of uranium, PCBs, VOCa and
other hazardous chemicals are again bring-
ing controversy decades into the planning of
a clean-up.
The Shpack Site on Union Road still holds
thousands of cubic yards of radioactive scrap,
debris from a chemical plant fire and* whatev-
er else that a landfill operator put in his back
10 acres. State and federal agencies are sup-
porting a plan to clean up uranium,- PCBs
and dioxin by digging it up and taking it out
of the state.
City residents are angry because concen-
trations of heavy metals, volatile organic
compounds and other pollutants would be
bulldozed, piled and capped to remain near
wetlands and Chartley Pond,
"We have [an] obligation to future genera-
tions to make certain that type of materials
are not in the ground," said Robert Kimball,
chairman of Norton's Board of Selectmen,
The U.S. Environmental
Protection Agency is accept-
ing comments through Aug.
25 on the proposal, and will
hold a hearing Aug. 4.
The difference between
what the Environmental
Protection Agency supports
and some city residents
want is stark; The site has a
price tag estimated at $28.1
million for the EPA's propos-
al, half of the $55.6 million
for the town-supported plan.
-------
U*"
r*
vT
-------
C
Galeae phoia by MIKE STUCK A
Documents on the Shpack Superfund site are as old as 1981 and as recent as several
weeks. The documents could fill up nearly two shelves and several CDs,* another shelf-
load is expected.
-------
F.S. Phones
Zing after
Dump Ad
By John Watson and Alex Kuzma
In the last edition of the Citizen
Advocate, Fair Share researchers issued an
appeal to readers for information leading
to potentially hazardous dump sites in
local communities. Because the
Department of Environmental Quality
Engineering's (DEQEJ refused to release
data on suspected toxic dumps in various
communities, Fair Share was forced to rely
on ordinary citizens to report sites that
could pose a serious threat to town
drinking supplies and the public health in
general. TJie following is a report on
response to the Fair Share "Hunt the
Dump" Appeal.
Concerned citizens from Haverhill,
Gardner, Attleboro, Tewksbury, Milford,
and other towns responsed to the Fair
Share appeal with phone calls, letters, arid
even photographs documenting
widespread anxiety over potentially
dangerous and illegal activity on the par! of
chemical companies and trucking firms.
DRILLING FOR HAZARDS; State and federal investigators drill for cam sample of dump site near Norton.Attleboro town line.
By Ron B
In one case, Mr. Ron Baptists of
Attleboro, Mass., forward disturbing
photos of slate DEQE officials and federal
investigators at a drill site in Norton, where
hazardous (possibly radioactive) wastes
had been found. The federal inspectors
in work suits bearing the
the U.S. Atomic Energy
and Oak Ridge National
of Erwin, Tennessee. The
presence of AEC and Oak Ridge personnel
might indicate that nuclear materials were
suspected to be stored in Norton.
were dressed
insignias of
Commission,
Laboratories
¦-irk. j
(Wss Ye
-------
i-HUNt= nu. : lsatfc^b^ojb
Hug. ^i> <3dm HI
HEATHER A. GRAF, COORDINATOR
CAST ¦
CITIZENS ADVISORY SHPACK TEAM , o
229 N. Worcester St. ¦" ' ^ '
Norton, MA 02766 : ' " 7• /
FAX (508) 226 - 2835
Phone (508) 226-0898
FAX
TO: itfi ^e£*S&JGSX
<> + i * *. *
, f.
(If
rr. °l IS - 6 3c»,»/y\
W', is>0 -h^, /M/
iY«-Vs \
Heather A. Graf
-------
FROM : GRAF PHONE Id. : 15082262835
Aug. 25 2004 03:53AM P2
August 25,2004
Heather A- Graf, Citizens Activist
229 N. Worcester St.
Morion, MA 02766
Ph. (SOS) 226-0898
FAX (508) 226 - 2835
Dave Lederer
US EPA
One Congress St., Suite 1100 (HBO)
Boston, MA 02114
Comments On EPA's Proposed Plan For The Shpack Superfund Site -
Personal-
My husband & 1 have lived in Norton for 30 years. Our home is a little over two miles
from the Shpack Site, so the term NIMBY is not applicable.
Town of Norton's Resolve -
Cleanup of this site is not a neighborhood issue. This toxic waste dump is a menace that
has plagued the Town of Norton for 26 years, since radioactive waste was discovered
therein 1978.
Residents of the town are united and steadfast in their opposition to the Environmental
Protection Agency's "Preferred Alternative, SC-2b", and adamant in demanding the
SC-3b Alternative be selected in EPA's Record of Decision (ROD), for cleanup of the
Shpack Superfund Site.
Be assured, as was stated at EPA's Public Hearing on August 4, 2004 - when Robert
Kimball (Chairman of the Norton Board of Selectmen) read the "Position Paper For The
Town of Norton™ - "Neither fee EPA nor the PRP Group should underestimate Norton's
resolve. We will exhaust all regulatory, political, and legal means possible to effect the
SC-3b solution."
Political Support -
On the political level fee Town of Norton has the support of Congressman Barney Frank,
State Senator JoAnn Sprague, State Representatives Mike Coppola, Betty Poirier & Phil
Travis (all of whom, testified at the August 4,2004 Public Hearing and submitted
responses in writing as well).
Legal Aid-
To our advantage, fee same attorney who has been on the Shpack case since the
beginning, is still working for the firm which is under contract as Norton's Town
Counsel.
-------
t-MJM : UKftt- HHUNfc NU. : l^kJUddbeiiib Hug. <£) cM«4 (£U:5JHD KJ
August 25,2004 H. Graf to D, Lcderer Page 2
War Chest -
The Town of Norton is adding funds to the Shpaek Legal Acco unt to create a war chest,
should we be forced into a legal battle with the EPA, members of the PR? Group, or any
other entity, which would try to deny the Town its right to the SC-3b Remedy of the
Shpaek Superfund Site.
We will also be prepared to engage any adversary in a dispute over the Town of Norton's
responsibility to contribute funds for Phase II - the cleanup of the Shpaek Site.
The Town's resolve to effect the SC-3b Solution will not be compromised by threats
from anyone - that if Norton insists upon the higher level of cleanup, the Town will be
slapped with the burden of sharing the cost of that cleanup.
PRP List -
Contrary to testimony at the August 4,2004 Public Hearing, by Attleboro's Health
Agent, Jim Mooney - The Town of Norton did not ever dump materials/ waste at the
Shpaek Dump. Isadore Shpaek would accept anything from anyone - in an attempt to fill
his wetland property for use as an apple orchard (which by the way he never achieved,
getting only so far as raising chickens!), and obviously some Norton residents took
advantage of a neighborhood dump to get rid of their trash. That does not make the Town
of Norton culpable, any more than the Town of Rehobeth, if some of its residents took
unwanted materials to the Shpaek Dump.
In June 1981, at the urging of the US Department Of Energy (DOE), the Town of Norton
did purchase from Lea Shpaek (widow of Isadore, who died February 1,1979), the parcel
of land in Norton. The $8,000 for the transfer of the property was provided to the Town
by Texas Instruments (TI) - the major contributor to contamination at the Shpaek Site.
Mrs. Shpaek had wisely refused to lease the property to the Department of Energy, she
insisted on selling (unloading) it DOE convinced the Town that cleanup would be easier
to accomplish if the site were publicly, rather than privately owned. Norton agreed to
accept title to the property in the spirit of cooperation with the Department of Energy, to
facilitate the remediation process. The agreement did include a clause that the Town was
not responsible for the contamination of Shpaek.
According to the Environmental Protection Agency's spokesman at the time, and
reiterated by EPA's current Project Manager — Norton was on the PRP list because
Superfund regulations require the owner of the property be named.
Residents of the Town of Norton have already endured far too much. The citizens of this
community have paid dearly for a highly contaminated toxic waste site - a monster that
they had no part in creating.
The "R" in PRP stands for "Responsible". The Town of Morton, while being perhaps the
only member of die group acting "responsibly"(as in good conscience) clearly was not
and is not - responsible for contamination of the Shpaek Site.
Municipal Disputes -
According to Mr. Mooney, Atttleboro (the only person at the Public Hearing to speak in
favor of EPA's Preferred Alternative), the contamination on the 2 & lA to 3- acre portion
of the Shpaek Superfund Site which lies in Attleboro - is not very contaminated.
-------
t-rcuri . ukmt mUNfc NU. ; IDUO^bcfOJS Hug, cO 4HM P4
August 25,2004 H. Graf to D. Lederer Page 3
Apparently the Attleboro Health Agent has not read reports by Cabrera Services
(Consultant for the US Army Corps of Engineers). The part of the Shpack site in
Attleboro, at the border with Attleboro Landfill Inc. (ALI) is highly contaminated.
Also Mr, Mooney stated that the City of Attleboro does not care if the portion of Shpack
within their city limits - gets cleaned up at all. Just covering it sounds fine, because
Attleboro has no intention of using the land. I'm not sure who Mr. Mooney is speaking
for here. PeAaps, with the Title of Health Agent, dealing with a new mayor and city
councilors - who know little, if anything about Shpack, he has con vinced some city
officials to accept this ridiculous position.
While I understand EPA must consider comments from Mr. Mooney, the same as from
the Norton Boaid of Health, and responses from Attleboro residents, the same as from
those of m in Norton, keep in mind 6 of the 9 acres are in Norton. The majority of
residents affected by Shpack are in Norton. The stigma of the Shpack Superfund Site has
always been Norton's. The burden of protecting the community from the negative
impacts of Shpack has been Norton's. When EPA considers "Community Acceptance"- it
must be weighted to fevor the Town of Norton.
Also in a discussion with Garth Patterson (Congressman Barney Frank's Office), we
agreed that a Superfund Site must be treated equally, all together as one. You cannot
draw a line in the sand (or swamp) at the Town/City Line.
Cleanup -
At least verbally, at a preview of the Environmental Protection Agency's Preferred
Alternative, prior to the June 23,2004 Public Meeting, it was stated by a spokesperson for
EPA that a reason for not going with a higher level of cleanup was - because there is
migration from ALI into Shpack. So... If EPA has a barrel filled to the brim with
contaminated material, it should not be emptied, because there will likely be some more
bad stuff leaking into the barrel? Explain the logic in this.
Cleanup Cost -
It should be obvious that the Army Corps of Engineers will be doing the lion's share of
the cleanup at Shpack. "The spot is riddled with red dots, like a bad case of the measles."
(Red dots indicating radioactive waste). In professional terms — The radiological waste is
heterogeneously spread over the site. Also, for most of the site - the materials are not
separated between Rad. and Chemical/Heavy metals. It is all mixed up. When ACE
excavates and disposes of (off site) all the radiological waste, they will be taking with
them much of the contaminated soil that was supposed to be the responsibility of the
EPA/PRP Group to clean up.
Also there will be little, if any, "Commingled Waste" for EPA/PRP Group to deal with.
The estimates by ERM (consultant for the Shpack Steering Committee, AKA - PRP
Group) of the amount of material that will be left for the PRPs to remove are
exaggerated. And so are the estimated cost because it is figured as if the material is
"Commingled Waste". Disposal fees are significantly higher for Commingled Waste.
-------
} WUI i » -Ji\nr
rnufNt nu. . iD^d^o^dOD
Hug. ^:d Mm f-o
August 25, 2004 H, Graf to D, Ledcrer Page 4
Even if the Arrov Corns could take away only the radiological material, the fact is this
aeencv of the US Government is assuming the responsibility of removing TI's
contaminants.
Water Main -
EPA's plan is to extend the town water main down Union Road to get the two houses
closest to Shpack off well water, so the level of cleanup can be significantly reduced.
The cost of this water main is minimal, compared with the $70 million it saves between
Norton's Preferred Alternative SC*3b (at approx. $50 million) and the highest level of
cleanup considered (at approx. $116 million).
Representatives for the Town of Norton ~ Bob Kimball (CH. Norton BOS) and myself, at
the preview of EPA's Propsed Plan in June 2004, agreed upon what we thought was a
very reasonable position: Accept the water main, do not insist on a level of cleanup which
included groundwater, compromise and settle for the $50 million (middle of the road)
alternative, which would dispose of all contaminated soil off site.
In hindsight, perhaps we should not have been so agreeable. By setting our sights and
goal at a lower level, EPA thought they could get away with the SC-2b "Consolidate &
Cap Plan". Be advised we will not be so naive again.
We do see potential problems with the extension of the water main, thai being in
increased development along Union Road near the Shpack Site. While EPA has proposed
"Institutional Controls" under their SC -2b plan, they cannot regulate development
surrounding the site. And while the Town can change zoning, to perhaps Heavy
Industrial, that would not decrease (in fact might increase) the number of individuals
coining to the area. In any case, a zoning change can be reversed at Town Meeting by a
simple 2/3 majority vote.
Contaminants at the Shpack Superfund Site ~
According to a 3/20/80 article in the Norton patriot - "Health Inspector Joseph Grimaldi
reported there are 200-300 barrels of PVC buried between two points on the site."
Reportedly, the PVC is residue from the Thompson Chemical fire which destroyed the
company in 1964, An abutter to the property — Louis Tetrcault claims that the PVC was
poured on the site and later burned off.
According to a Sun Chronicle article 8/5/80 "While attention has been on the survey for
"hot spots"at the Shpack property recently, (US Rep..Margaret) Heckler said she has
been told by a US DOE official that any danger from radiation was "one millionth" the
potential hazard from chemical wastes in the dumping areas."
We do know that chemicals have a greater capacity to migrate in groundwater.
-------
FROM : GRAF PHONE NO. : 15082262835 Rug. 25 2004 03:55RM PS
August 25,2004 H. Graf to D. Lederer Page 5
Contaminants at Shpack See Attachment A
Other than some PCBs & Dioxin, which EPA proposes to remove from the site, and the
radiological waste the ACE will take away, given this horror list of toxic substances,
some Mown carcinogens - (Attachment A), does the EPA still maintain that their SC-2b
(Consolidate & Cover) Plan will in fact provide an acceptable level of protection for
human health and the environment?
EPA's Record of Community Involvement -
The first meeting with EPA, ACE, MP officials and representatives of the Town of
Norton was held December 20,1999 (five days before Christmas). Could EPA - "The
Lead Agency for the Cleanup of the Shpack Superfund Site" have chosen a more perfect
time to ensure no one would give a damn about Shpack? Surprise, some of us did.
Then there was the scheduling of the public meeting, to finally after 4 & 14 years advise
Norton residents of EPA's ill advised Plan - June 23,2004 (days after school recessed for
summer break). And the setting of the Public Hearing for August 4,2004 (in a steamy
school cafeteria) - to deflect interest by any other than the very most hardy souls. The
public comment period from June 24 - August 25 couldn't be much worse. Does
anyone, other than Heather Graf, not take at least one weeks vacation during that period?
How many individuals are going to spend any time trying to review EPA's Shpack Plan,
(such a tedious task) during the summer months? And even for the willing, the material is
so voluminous, almost no one could do mote than scan it. Even our expert Conservation
Director - Jennifer Carlino, was hard pressed to respond to even the Feasibility Study.
Forget about reviewing the 229 page text of the "Draft Baseline Ecological Risk
Assessment", prepared by EPA's consultant - Metealf & Eddy, dated June 14,2004. In
addition to the 229 page text there are Figures, Tables & 3 Appendices — the volume is
5 &I/4 inches thick!
As for the 3 discs provided with the box loads of written material - the table of contents
on the discs is done in CODE.
The designations of alternatives: the EPA's favorite SC-2b and Norton's preferred plan
SC-3b were so similar, as to be totally confusing when trying to separate the two.
The power point presentation at the June 23,2004 public meeting - with miniscule white
letters on black boxes was pathetic. One needed a magnifying glass to read what was
printed on the handouts. Try to copy - and use up an ink cartridge. Don't even think about
FAXING! And the 12 page Proposed Plan handout was the most discombobulated of any
paper 1 have ever reviewed.
Whether in their timing or presentations, the US Environmental Protection Agency has
demonstrated an uncanny ability to make the process the least user friendly, the most
difficult & frustrating, and I do believe this was intentional.
-------
rrojn - r
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August 25,2004 H. Graf to D. Ledercr Page 6 (Final)
At the introduction to the Public Hearing August 4, 2004, the EPA's Hearing Officer -
Susan Studlien said the hearing was being conducted to receive testimony on The
Proposed RF.MFDY For the Shoack Smxsrflmd Site. The SC-2b Plan is not a REMEDY!
If the US Environmental Protection Agency insists on the SC-2b Plan, it will be apparent
that the name of your agency is m oxymoron,
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-------
CONTAMINANTS , SHPACK & ALI (ATTLEBORO LANDFILL INC.)
/ ,
Nuclear Regulatory Commission / November 1978 SHPACK
Principal Radioactive Compounds Above Natural Background Levels;
Uranium - 234, Uranium - 235, Uranium - 238
Radium - 226
Department Of Environmental Quality Engineering / March 1980 SHPACK
Elevated Levels Of Heavy Metals In Soil:
Lead, Arsenic, Chromium, Copper, Cadmium, Nickel, Zinc
Department Of Environmental Quality Engineering / November 1980 SHPACK
Chemicals Detected In Groundwater Above EPA Maximum Contamination Level For
Drinking Water:
1.2,- dichlorethylene, trichlorethylene, tetrachloroethylene
US Environmental Protection Agency / May 1982 SHPACK
Soil & Groundwater — Several Volatile Organic Priority Pollutants Detected
US EPA & Roy F. Weston Technical Assistance Team / August 1989 SHPACK
Presence Of Chemicals In Surface Water Samples At Concentrations Exceeding "EPA
Ambient Water Quality Criteria For Protection Of Human Health":
Vinyl chloride, benzene, 1.2.- dichlorethene, aroetor- 1248
US EPA & Weston / November 1989 SHPACK
Soil Samples Confirmed Presence Of:
Volatile Organic Compounds, Semi-volatile Organic Compounds, Polychlorinated
Biphenyls (PCBs)
DUMPED ON SITE SHPACK, 1946-1966:
Waste Oil, Degreasing Solvents, Iron, Cyanide, Heavy Metals, Precious Metal Refining
Waste, Resins, Organics, Depleted Uranium, Vinyl Chloride
GHR ENGINEERS OF NEW BEDFORD / March 25,1980
SHPACK & ATTLEBORO LANDFILL (ALI)
Samples Collected From 10 Observation Wells On ALI Property On Peckham St.,
Plus 2 Samples Of Contaminated Soil From Older Landfill Northeast Of Present
Landfill (SHPACK):
15 Volatile Chemicals Were Detected In One Or MoreObservation Wells. "Eight Of The
Volatile Organics : Vinyl chloride, Chloroform, 1.2 - Dichloroethylene, Methylene
Chloride, Bromodichioromethane, Trichloroethylene, Benzene & Tetrachloroethylene
Exceed Human Health Criteria."
"These Volatile Organic Compounds Are Considered To Be Potential Carcinogens If
Consumed In Drinking Water, Fish Or Shellfish.'*
-------
PAGE 2
GHR ENGINEERS / March 25,1980 (Continued)
"If A Chemical Is Suspected Of Being A Human Carcinogen, There is No Recognized
Safe Concentration In Drinking Water Or Food Which Will Provide Absolute Protection
Of Human Health Except Zero."
-------
Comments to The US EPA on the June 2004 Proposed Plan For the Cleanup of
The Shpack Superfund Site, Norton/Attleboro, MA
To Dave Lederer Superfund Records Center
U.S. EPA SITE:
One Congress St., Suite 1100 (HBO) BREAK*
Boston, MA 02114 _
Deadline - Postmarked By Wednesday, August 25,2004 ' ¦ *
FAX (617) 918 - 1291, No Later Than Wednesday, August 25,2004
August 2004
I am writing to express my firm opposition to the EPA's proposed plan for the 'cleanup'
of the Shpaek Superfund Site.
EPA's preferred alternative (SC-2b) is unacceptable for reasons too numerous to detail
here. Most objectionable is the fact this option does not provide "permanence" and is
therefore not a "remedy". It would leave the Town of Norton with a still contaminated
site, and the responsibility & burdens of dealing with it, in the near and distant future.
In the face of the promise the Environmental Protection Agency made to the town,
EPA's chosen course of action, is reprehensible.
If community acceptance, plays any role in the EPA's decision making process for the
cleanup of Shpack, please give serious consideration to these comments, and select
Alternative SC-3b, which will at long last, give residents of this community the peace of
mind they deserve.
Signature
Print Name /5st?3//p. ff\.
Address & R jYx rrUrV) Auk.
Mopffln, n,M- c$-i(o (p
-------
Comments to The US EPA on the June 2004 Proposed Plan For the Cleanup of
The Shpack Superfiind Site, Norton/Attleboro, MA
To Dave Lederer
U.S. EPA
One Congress St., Suite 1100 (HBO)
Boston, MA 02114
Deadline - Postmarked By Wednesday, August 25, 2004
FAX (61?) 918 — 1291, No Later Than Wednesday, August 25,2004
August 2004
I am writing to express my firm opposition to the EPA's proposed plan for the 'cleanup*
of the Shpack Superfund Site.
EPA's preferred alternative (SC-2b) is unacceptable for reasons too numerous to detail
here, Most objectionable is the fact this option does not provide "permanence" and is
therefore not a "remedy". It would leave the Town of Norton with a still contaminated
site, and the responsibility & burdens of dealing with it, in the near and distant future.
In the face of the promise the Environmental Protection Agency made to the town,
EPA's chosen course of action, is reprehensible.
If community acceptance, plays any role in the EPA's decision making process for the
cleanup of Shpack, please give serious consideration to these comments, and select
Alternative SC-3b, which will at long last, give residents of this community the peace of
mind they deserve.
Signature f\ M
, y
Print Name /fWH ^ N & 9 u i
Address Z H ft M fit */>/ Jp
pocfc H A HA/aN_ U/ u.
-------
Comments to The US EPA on the June 2004 Proposed Plan For the Cleanup of
The Shpack Supeifund Site, Norton/Attleboro, MA
To Dave Lederer
US. EPA
One Congress St., Suite 1100 (HBO)
Boston, MA 02114
Deadline - Postmarked By Wednesday, August 25,2004
FAX (617) 918 - 1291, No Later Than Wednesday, August 25,2004
l
August 2004
I am writing to express my firm opposition to the EPA's proposed plan for the 'cleanup'
of the Shpack Superfund Site.
EPA's preferred alternative (SC-2b) is unacceptable for reasons too numerous to detail
here. Most objectionable is the fact this option does not provide "permanence" and is
therefore not a "remedy". It would leave the Town of Norton with a still contaminated
site, and the responsibility & burdens of dealing with it, in the near and distant future.
In the face of the promise the Environmental Protection Agency made to the town,
EPA's chosen course of action, is reprehensible.
If community acceptance, plays any role in the EPA's decision making process for the
cleanup of Shpack, please give serious consideration to these comments, and select
Alternative SC-3b, which will at long last, give residents of this community the peace of
mind they deserve.
Signature
Print Name
/
Address A+k STtEfT'
jftKTJd t firtf d*-~! UL
-------
Comments to The US EPA on the June 2004 Proposed Plan For the Cleanup of
The Shpack Superfund Site, Norton/Attleboro, MA
To Dave Lederer
U.S. EPA
One Congress St., Suite 1100 (HBO)
Boston, MA 02114
Deadline - Postmarked By Wednesday, August 25,2004
FAX (617) 918 - 1291, No Later Than Wednesday, August 25,2004
August 2004
I am writing to express my firm opposition to the EPA's proposed plan for the 'cleanup'
of the Shpack Superfund Site.
EPA's preferred alternative (SC-2b) is unacceptable for reasons too numerous to detail
here. Most objectionable is the fact this option does not provide "permanence" and is
therefore not a "remedy". It would leave the Town of Norton with a still contaminated
site, and the responsibility & burdens of dealing with it, in the near and distant future.
In the face of the promise the Environmental Protection Agency made to the town,
EPA's chosen course of action, is reprehensible.
If community acceptance, plays any role in the EPA's decision making process for the
cleanup of Shpack, please give serious consideration to these comments, and select
Alternative SC-3b, which will at long last, give residents of this community the peace of
mind they deserve.
Print Name . T> U>AT£ri/J
Address PJa, a/
-------
Comments to The US EPA on the June 2004 Proposed Plan For the Cleanup of
The Shpaek Superfund Site, Norton/Attleboro, MA
To Dave Lederer
U.S. EPA
One Congress St., Suite 1100 (HBO)
Boston, MA 02114
Deadline - Postmarked By Wednesday, August 25, 2004
FAX (617) 918 - 1291, No Later Than Wednesday, August 25, 2004
August 2004
I am writing to express my firm opposition to the EPA's proposed plan for the 'cleanup'
of the Shpaek Superfund Site,
EPA's preferred alternative (SC-2b) is unacceptable for reasons too numerous to detail
here. Most objectionable is the fact this option does not provide "permanence" and is
therefore not a "remedy". It would leave the Town of Norton with a still contaminated
site, and the responsibility & burdens of dealing with it, in the near and distant future.
In the face of the promise the Environmental Protection Agency made to the town,
EPA's chosen course of action, is reprehensible.
If community acceptance, plays any role in the EPA's decision making process for the
cleanup of Shpaek, please give serious consideration to these comments, and select
Alternative SC-3b, which will at long last, give residents of this community the peace of
mind they deserve.
Signature -RaXTAv
Print Name *73, E? . 6 €>r> id
Address / *Tf £?• H Aits S-V •
iQp-r-f-g n. Ha.- r>9S7k&
-------
Comments to The US EPA on the June 2004 Proposed Plan For the Cleanup of
The Shpack Superfund Site, Norton/Attleboro, MA
To Dave Lederer
U.S. EPA
One Congress St., Suite 1100 (HBO)
Boston, MA 02114
Deadline - Postmarked By Wednesday, August 25, 2004
FAX (617) 918 - 1291, No Later Than Wednesday, August 25, 2004
August 2004
I am writing to express my firm opposition to the EPA's proposed plan for the 'cleanup'
of the Shpaek Superfund Site.
EPA's preferred alternative (SC-2b) is unacceptable for reasons too numerous to detail
here. Most objectionable is the fact this option does not provide "permanence" and is
therefore not a "remedy". It would leave the Town of Norton with a still contaminated
site, and the responsibility & burdens of dealing with it, in the near and distant future.
In the face of the promise the Environmental Protection Agency made to the town,
EPA's chosen course of action, is reprehensible.
If community acceptance, plays any role in the EPA's decision making process for the
cleanup of Shpack, please give serious consideration to these comments, and select
Alternative SC-3b, which will at long last, give residents of this community the peace of
mind they deserve.
Signature
Print Name
Address
-------
Comments to The US EPA on the June 2004 Proposed Plan For the Cleanup of
The Shpack Superfimd Site, Norton/Attleboro, MA
To Dave Lederer
U.S. EPA
One Congress St., Suite 1100 (HBO)
Boston, MA 02114
Deadline - Postmarked By Wednesday, August 25, 2004
FAX (617) 918 - 1291, No Later Than Wednesday, August 25,2004
August 2004
I am writing to express my firm opposition to the EPA's proposed plan for the 'cleanup'
of the Shpack Superfimd Site.
EPA's preferred alternative (SC-2b) is unacceptable for reasons too numerous to detail
here. Most objectionable is the fact this option does not provide "permanence" and is
therefore not a "remedy". It would leave the Town of Norton with a still contaminated
site, and the responsibility & burdens of dealing with it, in the near and distant future.
In the face of the promise the Environmental Protection Agency made to the town,
EPA's chosen course of action, is reprehensible.
If community acceptance, plays any role in the EPA's decision making process for the
cleanup of Shpack, please give serious consideration to these comments, and select
Alternative SC-3b, which will at long last, give residents of this community the peace of
mind they deserve.
Print Name
Address
-------
Comments to The US EPA on the June 2004 Proposed Plan. For the Cleanup of
The Shpack Superfund Site, Norton/Atxleboro, MA
To Dave Lederer
U.S. EPA
One Congress St., Suite 1100 (HBO)
Boston, MA 02114
Deadline - Postmarked By Wednesday, August 25,2004
FAX (61?) 918 - 1291, No Later Than Wednesday, August 25,2004
August 2004
I arn writing to express nay firm opposition to the EPA's proposed plan for the 'cleanup'
of the Shpack Superfund Site.
EPA's preferred alternative (SC-2b) is unacceptable for reasons too numerous to detail
here. Most objectionable is the fact this option does not provide "permanence" and is
therefore not a "remedy". It would leave the Town of Norton with a still contaminated
site, and the responsibility & burdens of dealing with it, in the near and distant future,
in the face of the promise the Environmental Protection Agency made to the town,
EPA's chosen course of action, is reprehensible.
If community acceptance, plays any role in the EPA's decision making process for the
cleanup of Shpack, please give serious consideration to these comments, and select
Alternative SC-3b, which will at long last, give residents of this community the peace of
mind they deserve.
Print Name
Address
3^6
SH390a
B/.2.8S8S80S 81 'II
-------
Comments to The US EPA on the June 2004 Proposed Plan For the Cleanup of
The Shpack Superfund Site, Norton/Attleboro, MA
To Dave Lederer
U.S. EPA
One Congress St., Suite 1100 (HBO)
Boston, MA 02114
Deadline - Postmarked By Wednesday, August 25, 2004
FAX (617) 918 - 1291, No Later Than Wednesday, August 25,2004
August 2004
I am writing to express my firm opposition to the EPA's proposed plan for the 'cleanup'
of the Shpack Superfund Site.
EPA's preferred alternative (SC-2b) is unacceptable for reasons too numerous to detail
here. Most objectionable is the fact this option does not provide "permanence" and is
therefore not a "remedy". It would leave the Town of Norton with a still contaminated
site, and the responsibility & burdens of dealing with it, in the near and distant future.
In the face of the promise the Environmental Protection Agency made to the town,
EPA's chosen course of action, is reprehensible.
If community acceptance, plays any role in the EPA's decision making process for the
cleanup of Shpack, please give serious consideration to these comments, and select
Alternative SC~3b, which will at long last, give residents of this community the peace of
mind they deserve.
Signature
Print Name
y-cyC
Address
ff /% M*-*— —
-------
Comments to The US EPA on the Jurxe 2004 Proposed Plan For the Cleanup of
The Shpack Superfund Site, Norton/Attleboro, MA
To Dave Lederer
U.S. EPA
One Congress St., Suite 1100 (HBO)
Boston, MA 02114
Deadline ¦ Postmarked By Wednesday, August 25,2004
FAX (617) 918 - 1291, No Later Than Wednesday, August 25,2004
August 2004
I am writing to express my firm opposition to the EPA's proposed plan for the 'cleanup'
of the Shpack Superfund Site.
EPA's preferred alternative (SC-2b) is unacceptable for reasons too numerous to detail
here. Most objectionable is the fact this option does not provide "permanence" and is
therefore not a "remedy". It would leave the Town of Norton with a still contaminated
site, and the responsibility & burdens of dealing with it, in the near and distant future.
In the face of the promise the Environmental Protection Agency made to the town,
EPA's chosen course of action, is reprehensible.
If community acceptance, plays any role in the EPA's decision making process for the
cleanup of Shpack, please give serious consideration to these comments, and select
Alternative SC-3b, which will at long last, give residents of this community the peace of
mind they deserve.
Print Nam*.
Signature
Address
-------
Comments to The US EPA on the June 2004 Proposed Plan For the Cleanup of
The Shpack Superfund Site, Norton/Attleboro, MA
To Dave Lederer
U.S. EPA
One Congress St., Suite 1100 (HBO)
Boston, MA 02114
Deadline - Postmarked By Wednesday, August 25,2004
FAX (617) 918- 1291, No Later Than Wednesday, August 25, 2004
August 2004
I am writing to express my firm opposition to the EPA's proposed plan for the 'cleanup*
of the Shpack Superfund Site.
EPA's preferred alternative (SC-2b) is unacceptable for reasons too numerous to detail
here. Most objectionable is the fact this option does not provide "permanence" and is
therefore not a "remedy". It would leave the Town of Norton with a still contaminated
site, and the responsibility & burdens of dealing with it, in the near and distant future.
In the face of the promise the Environmental Protection Agency made to the town,
EPA's chosen course of action, is reprehensible.
If community acceptance, plays any role in the EPA's decision making process for the
cleanup of Shpack, please give serious consideration to these comments, and select
Alternative SC-3b, which will at long last, give residents of this community the peace of
mind they deserve.
Signature
Print Name ^ lAs .S fJ tY"^ 1 rO 6
If ST-
AfoftTan , qZ-7-lL
-------
Comments to The US EPA on the June 2004 Proposed Plan For the Cleanup of
The Shpack Super-fund Site, Norton/Attleboro, MA
To Dave Lederer
U.S. EPA
One Congress St., Suite 1100 (HBO)
Boston, MA 02114
Deadline - Postmarked By Wednesday, August 25,2004
_ FAX (617) 918 - 1291, No Later Than Wednesday, August 25, 2004
"t
August 2004
I am writing to express my firm opposition to the EPA's proposed plan for the 'cleanup'
of the Shpack Superfund Site.
EPA's preferred alternative (SC-2b) is unacceptable for reasons too numerous to detail
here. Most objectionable is the fact this option does not provide "permanence" and is
therefore not a "remedy". It would leave the Town of Norton with a still contaminated
site, and the responsibility & burdens of dealing with it, in the near and distant future.
In the face of the promise the Environmental Protection Agency made to the town,
EPA's chosen course of action, is reprehensible.
If community acceptance, plays any role in the EPA's decision making process for the
cleanup of Shpack, please give serious consideration to these comments, and select
Alternative SC-3b, which will at long last, give residents of this community the peace of
mind they deserve.
Signature
Print Name
Address
-------
Comments to The US EPA on the June 2004 Proposed Plan For the Cleanup of
The Shpack Superfund Site, Norton/Attleboro, MA
To Dave Lederer
U.S. EPA
One Congress St., Suite 1100 (HBO)
Boston, MA 02114
Deadline - Postmarked By Wednesday, August 25, 2004
FAX (617) 918 -1291, No Later Than Wednesday, August 25,2004
August 2004
I am writing to express my firm opposition to the EPA's proposed plan for the 'cleanup'
of the Shpack Superfund Site,
EPA's preferred alternative (SC-2b) is unacceptable for reasons too numerous to detail
here. Most objectionable is the fact this option does not provide "permanence" and is
therefore not a "remedy". It would leave the Town of Norton with a still contaminated
site, and the responsibility & burdens of dealing with it, in the near and distant future.
In the face of the promise the Environmental Protection Agency made to the town,
EPA's chosen course of action, is reprehensible.
If community acceptance, plays any role in the EPA's decision making process for the
cleanup of Shpack, please give serious consideration to these comments, and select
Alternative SC-3b, which will at long last, give residents of this community the peace of
rninH fhf»v Hpspt-vp
Print Name
Address l^£jrr\TOa} Af
-------
Comments to The US EPA on the June 2004 Proposed Plan For the Cleanup of
The Shpack Superfund Site, Norton/Attleboro, MA
To Dave Lederer ...
u.s.epa ,\
One Congress St,, Suite 1100 (HBO)
Boston, MA 02114
Deadline - Postmarked By Wednesday, August 25,2004
FAX (617) 918 - 1291, No Later Than Wednesday, August 25,2004
August 2004
I am writing to express my firm opposition to the EPA's proposed plan for the 'cleanup'
of the Shpack Superfund Site.
EPA's preferred alternative (SC-2b) is unacceptable for reasons too numerous to detail
here. Most objectionable is the fact this option does not provide "permanence" and is
therefore not a "remedy". It would leave the Town of Norton with a still contaminated
site, and the responsibility & burdens of dealing with it, in the near and distant future.
In the face of the promise the Environmental Protection Agency made to the town,
EPA's chosen course of action, is reprehensible.
If community acceptance, plays any role in the EPA's decision making process for the
cleanup of Shpack, please give serious consideration to these comments, and select
Alternative SC-3b, which will at long last, give residents of this community the peace of
mind they deserve. . ... . ., ..
Signature
Print Name
Address
% fWife VftWfc
-------
Comments to The US EPA on the June 2004 Proposed Plan For the Cleanup of
The Shpack Superfund Site, Norton/Attleboro, MA
To Dave Lederer
U.S. EPA
One Congress St,, Suite 1100 (HBO)
Boston, MA 02114
Deadline - Postmarked By Wednesday, August 25,2004
FAX (617) 918- 1291,No Later Than Wednesday, August 25, 2004
August 2004
I am writing to express my firm opposition to the EPA's proposed plan for the 'cleanup'
of the Shpack Superfund Site.
EPA's preferred alternative (SC-2b) is unacceptable for reasons too numerous to detail
here. Most objectionable is the fact this option does not provide "permanence" and is
therefore not a "remedy". It would leave the Town ofNorton with a still contaminated
site, and the responsibility & burdens of dealing with it, in the near and distant future.
In the face of the promise the Environmental Protection Agency made to the town,
EPA's chosen course of action, is reprehensible.
If community acceptance, plays any role in the EPA's decision making process for the
cleanup of Shpack, please give serious consideration to these comments, and select
Alternative SC-3b, which will at long last, give residents of this community the peace of
mind they deserve.
Signature
Address
(?. ^ Ms9- ^yj ^
-------
Comments to The US EPA on the June 2004 Proposed Plan For the Cleanup of
The Shpack Superfund Site, Norton/Attleboro, MA
To Dave Lederer
U.S. EPA
One Congress St., Suite 1100 (HBO)
Boston, MA 02114
Deadline - Postmarked By Wednesday, August 25,2004
FAX (617) 918 - 1291, No Later Than Wednesday, August 25, 2004
August 2004
I am writing to express my firm opposition to the EPA's proposed plan for the 'cleanup'
of the Shpack Superfund Site.
EPA's preferred alternative (SC-2b) is unacceptable for reasons too numerous to detail
here. Most objectionable is the fact this option does not provide "permanence" and is
therefore not a "remedy". It would leave the Town of Norton with a still contaminated
site, and the responsibility & burdens of dealing with it, in the near and distant future.
In the face of the promise the Environmental Protection Agency made to the town,
EPA's chosen course of action, is reprehensible.
If community acceptance, plays any role in the EPA's decision making process for the
cleanup of Shpack, please give serious consideration to these comments, and select
Alternative SC-3b, which will at long last, give residents of this community the peace of
mind they deserve.
Signature < ^
2V~ [7Am. e f^ouiy
^' f $lJ4/ ^ fK A r ~7T |p ^
-------
Comments to The US EPA on the June 2004 Proposed Plan For the Cleanup of
The Shpack Superfuiid Site, Norton/Attleboro, MA
To Dave Lederer
U.S. EPA
One Congress St., Suite 1100 (HBO)
Boston, MA 02114
Deadline - Postmarked By Wednesday, August 25,2004
^ FAX (617)918 - 1291, No Later Than Wednesday, August 25,2004
August 2004
I am writing to express my firm opposition to the EPA's proposed plan for the 'cleanup'
of the Shpack Superfund Site,
EPA's preferred alternative (SC-2b) is unacceptable for reasons too numerous to detail
here. Most objectionable is the fact this option does not provide "permanence" and is
therefore not a "remedy'-'. It would leave the Town of Norton with a still contaminated
site, and the responsibility & burdens of dealing with it, in the near and distant future.
In the face of the promise the Environmental Protection Agency made to the town,
EPA's chosen course of action, is reprehensible.
If community acceptance, plays any role in the EPA's decision making process for the
cleanup of Shpack, please give serious consideration to these comments, and select
Alternative SC-3b, which will at long last, give residents of this community the peace of
mind they deserve.
Signature IslxJlJlfi
— * '¦ ' * '¦ - «¦
Print Name
#£///?/ /) \j£LLE
Address
*7 f £Ut4j,ltryi ? /
Tlo-'t h)?i, ft t> 2*7-66
-------
Comments to The US EPA on the June 2004 Proposed Plan For the Cleanup of
The Shpack Superfund Site, Norton/Attleboro, MA
To Dave Lcderer
U S EPA
One Congress St., Suite 1100 (HBO)
Boston, MA 02114
Deadline - Postmarked By Wednesday, August 25,2004
FAX (617) 918- 1291, No Later Than Wednesday, August 25,2004
August 2004
I am writing to express my firm opposition to the EPA's proposed plan for the cleanup
of the Shpack Superfund Site.
EPA's preferred alternative (SC-2b) is unacceptable for reasons too numerous to detail
here. Most objectionable is the fact this option does not provide "permanence" and is
therefore not a "remedy". It would leave the Town of Norton with a still contaminated
site, and the responsibility & burdens of dealing with it, in the near and distant future.
In the face of the promise the Environmental Protection Agency made to the town,
EPA's chosen course of action, is reprehensible.
If community acceptance, plays any role in the EPA's decision making process for the
cleanup of Shpack, please give serious consideration to these comments, and select
Alternative SC-3b, which will at long last, gjve residents of this community the peace of
mind they deserve.
Signature
Address
-------
Comments to The US EPA on the June 2004 Proposed Plan For the Cleanup of
The Shpack Superfiind Site, Norton/Attleboro, MA
To Dave Lederer
U.S. EPA
One Congress St., Suite 1100 (HBO)
Boston, MA 02114
Deadline - Postmarked By Wednesday, August 25, 2004
^ FAX (617)918- 1291,No Later Than Wednesday, August 25,2004
August 2004
1 am writing to express my firm opposition to the EPA's proposed plan for the 'cleanup'
of the Shpaek Superfund Site.
EPA's preferred alternative (SC-2b) is unacceptable for reasons too numerous to detail
here. Most objectionable is the fact this option does not provide "permanence" and is
therefore not a "remedy". It would leave the Town of Norton with a still contaminated
site, and the responsibility & burdens of dealing with it, in the near and distant future.
In the face of the promise the Environmental Protection Agency made to the town,
EPA's chosen course of action, is reprehensible.
If community acceptance, plays any role in the EPA's decision making process for the
cleanup of Shpack, please give serious consideration to these comments, and select
Alternative SC-3b, which will at long last, give residents of this community the peace of
mind they deserve.
Signature
Print Name
Address
W-
).n Mftr
-------
Comments to The US EPA on the June 2004 Proposed Plan For the Cleanup of
The Shpack Superftmd Site, Norton/Attleboro, MA
To Dave Lederer
U.S. EPA
One Congress St., Suite 1100 (HBO)
Boston, MA 02114
Deadline - Postmarked By Wednesday, August 25, 2004
FAX (617) 918 - 1291, No Later Than Wednesday, August 25,2004
August 2004
I am writing to express my firm opposition to the EPA's proposed plan for the 'cleanup'
of the Shpaek Superfund Site.
EPA's preferred alternative (SC-2b) is unacceptable for reasons too numerous to detail
here. Most objectionable is the fact this option does not provide "permanence" and is
therefore not a "remedy". It would leave the Town of Norton with a still contaminated
site, and the responsibility & burdens of dealing with it, in the near and distant future.
In the face of the promise the Environmental Protection Agency made to the town,
EPA's chosen course of action, is reprehensible.
If community acceptance, plays any role in the EPA's decision making process for the
cleanup of Shpack, please give serious consideration to these comments, and select
Alternative SC-3b, which will at long last, give residents of this community the peace of
mind they deserve.
Signature
ik
Print Name
Address ^3^? jO . 109^0%
-------
Comments to The US EPA on the June 2004 Proposed Plan For the Cleanup of
The Shpack Superfund Site, Norton/Attleboro, MA
To Dave Lederer
U.S. EPA
One Congress St., Suite 1100 (HBO)
Boston, MA 02114
Deadline - Postmarked By Wednesday, August 25, 2004
FAX (617) 918 - 1291, No Later Than Wednesday, August 25,2004
r
August 2004
I am writing to express my firm opposition to the EPA's proposed plan for the 'cleanup'
of the Shpack Superfund Site.
EPA's preferred alternative (SC-2b) is unacceptable for reasons too numerous to detail
here. Most objectionable is the fact this option does not provide "permanence" and is
therefore not a "remedy". It would leave the Town of Norton with a still contaminated
site, and the responsibility & burdens of dealing with it, in the near and distant future.
In the face of the promise the Environmental Protection Agency made to the town,
EPA's chosen course of action, is reprehensible.
If community acceptance, plays any role in the EPA's decision making process for the
cleanup of Shpack, please give serious consideration to these comments, and select
Alternative SC-3b, which will at long last, give residents of this community the peace of
mind they deserve.
Signature
Print Name
M A&ih U ££.
Address t-QVUL-J
,tj~ /Tier- 03 ~>r> <3
-------
Comments to The US EPA on the June 2004 Proposed Plan For the Cleanup of
The Shpack Superfund Site, Norton/Attleboro, MA
To Dave Lederer
U.S. EPA
One Congress St., Suite 1100 (HBO)
Boston, MA 02114
Deadline - Postmarked By Wednesday, August 25, 2004
FAX (617) 918 - 1291, No Later Than Wednesday, August 25,2004
August 2004
I am writing to express my firm opposition to the EPA's proposed plan for the 'cleanup'
of the Shpack Superfund Site,
EPA's preferred alternative (SC-2b) is unacceptable for reasons too numerous to detail
here. Most objectionable is the fact this option does not provide "permanence" and is
therefore not a "remedy". It would leave the Town of Norton with a still contaminated
site, and the responsibility & burdens of dealing with it, in the near and distant future.
In the face of the promise the Environmental Protection Agency made to the town,
EPA's chosen course of action, is reprehensible.
If community acceptance, plays any role in the EPA's decision making process for the
cleanup of Shpack, please give serious consideration to these comments, and select
Alternative SC-3b, which will at long last, give residents of this community the peace of
mind they deserve.
Print Name
Address
-------
Comments to The US EPA on-the June 2004 Proposed Plan For the Cleanup of
The Shpack Superftmd Site, Norton/Attleboro, MA
To Dave Lederer
U.S. EPA
One Congress St., Suite 1100 (HBO)
Boston, MA 02114
Deadline - Postmarked By Wednesday, August 25, 2004
FAX (617) 918 - 1291, No Later Than Wednesday, August 25,2004
August 2004
I am writing to express my firm opposition to the EPA's proposed plan for the 'cleanup'
of the Shpack Superfund Site.
EPA's preferred alternative (SC-2b) is unacceptable for reasons too numerous to detail
here. Most objectionable is the fact this option does not provide "permanence" and is
therefore not a "remedy". It would leave the Town of Norton with a still contaminated
site, and the responsibility & burdens of dealing with it, in the near and distant future.
In the face of the promise the Environmental Protection Agency made to the town,
HPA's chosen course of action, is reprehensible,
If community acceptance, plays any role in the EPA's decision making process for the
cleanup of Shpack, please give serious consideration to these comments, and select
Alternative SC-3b, which will at long last, give residents of this community the peace of
mind they deserve.
Signature/piuIau%4-~'
Print Name jj-Oi<±£id A* o^tz^S-
Address ~7
t* M ft 6 £
-------
Comments to The US EPA on the June 2004 Proposed Plan For the Cleanup of
The Shpaek Superfund Site, Norton/Attleboro, MA
To Dave Lederer
U.S. EPA
One Congress St., Suite 1100 (HBO)
Boston, MA 02114
Deadline - Postmarked By Wednesday, August 25, 2004
FAX (617)918- 1291, No Later Than Wednesday, August 25, 2004
August 2004
I am writing to express my firm opposition to the EPA's proposed plan for the 'cleanup'
of the Shpaek Superfund Site.
EPA's preferred alternative (SC-2b) is unacceptable for reasons too numerous to detail
here. Most objectionable is the fact this option does not provide "permanence" and is
therefore not a "remedy". It would leave the Town of Norton with a still contaminated
site, and the responsibility & burdens of dealing with it, in the near and distant future,
In the face of the promise the Environmental Protection Agency made to the town,
EPA's chosen course of action, is reprehensible.
If community acceptance, plays any role in the EPA's decision making process for the
cleanup of Shpaek, please give serious consideration to these comments, and select
Alternative SC-3b, which will at long last, give residents of this community the peace of
mind they deserve.
Print Name
t- ro L- {
Address
%Do c 4 n W A P) Co (o
Uas ^ ^
- Gl^cJ cio IV • —
\ tx/ t. \y\ €L CL < V CV V—i U al ol a Vvi
Co^ Q. 5" WJi oX. . C • -
-------
Comments to The US EPA on the June 2004 Proposed Plan For the Cleanup of
The Shpack Superfuxid Site, Norton/Attleboro, MA
To Dave Lederer
U.S. EPA
One Congress St., Suite 1100 (HBO)
Boston, MA 02114
Deadline - Postmarked By Wednesday, August 25, 2004
FAX (617) 918 - 1291, No Later Than Wednesday, August 25, 2004
August 2004
I am writing to express my firm opposition to the EPA's proposed plan for the 'cleanup'
of the Shpack Superfund Site.
EPA's preferred alternative (SC-2b) is unacceptable for reasons too numerous to detail
here. Most objectionable is the fact this option does not provide "permanence" and is
therefore not a "remedy". It would leave the Town of Norton with a still contaminated
site, and the responsibility & burdens of dealing with it, in the near and distant future.
In the face of the promise the Environmental Protection Agency made to the town,
EPA's chosen course of action, is reprehensible.
If community acceptance, plays any role in the EPA's decision making process for the
cleanup of Shpack, please give serious consideration to these comments, and select
Alternative SC-3b, which will at long last, give residents of this community the peace of
mind they deserve.
Signature
Print Name
Address (/ /U /ft rt/c JtV .
VP' ti A MA 03-76^
-------
Comments to The US EPA on the June 2004 Proposed Plan For the Cleanup of
The Shpack Superfund Site, Norton/Attleboro, MA
To Dave Lederer
U.S. EPA
One Congress St., Suite 1100 (HBO)
Boston, MA 02114
Deadline - Postmarked By Wednesday, August 25, 2004
FAX (617) 918-1291, No Later Than Wednesday, August 25, 2004
August 2004
I am writing to express my firm opposition to the EPA's proposed plan for the 'cleanup'
of the Shpack Superfund Site.
EPA's preferred alternative (SC-2b) is unacceptable for reasons too numerous to detail
here. Most objectionable is the fact this option does not provide "permanence" and is
therefore not a "remedy". It would leave the Town of Norton with a still contaminated
site, and the responsibility & burdens of dealing with it, in the near and distant future.
In the face of the promise the Environmental Protection Agency made to the town,
EPA's chosen course of action, is reprehensible.
If community acceptance, plays any role in the EPA's decision making process for the
cleanup of Shpack, please give serious consideration to these comments, and select
Alternative SC-3b, which will at long last, give residents of this community the peace of
mind they deserve.
Print Name
Address 2^-3 /)¦ •
-------
Comments to The US EPA on the June 2004 Proposed Plan For the Cleanup of
The Shpack Superfund Site, Norton/Attleboro, MA
To Dave Lederer
U.S. EPA
One Congress St., Suite 1100 (HBO)
Boston, MA 02114
Deadline - Postmarked By Wednesday, August 25,2004
FAX (617) 918 - 1291, No Later Than Wednesday, August 25,2004
August 2004
I am writing to express my firm opposition to the EPA's proposed plan for the 'cleanup'
of the Shpack Superfund Site.
EPA's preferred alternative (SC-2b) is unacceptable for reasons too numerous to detail
here. Most objectionable is the fact this option does not provide "permanence" and is
therefore not a "remedy". It would leave the Town of Norton with a still contaminated
site, and the responsibility & burdens of dealing with it, in the near and distant future,
In the face of the promise the Environmental Protection Agency made to the town,
EPA's chosen course of action, is reprehensible.
If community acceptance, plays any role in the EPA's decision making process for the
cleanup of Shpack, please give serious consideration to these comments, and select
Alternative SC-3b, which will at long last, give residents of this community the peace of
mind they deserve.
Address
-------
Comments to The US EPA on the June 2004 Proposed Plan For the Cleanup of
The Shpack Superfund Site, Norton/Attleboro, MA
To Dave Lederer
U.S. EPA
One Congress St., Suite 1100 (HBO)
Boston, MA 02114
Deadline - Postmarked By Wednesday, August 25,2004
FAX (617) 918 - 1291, Ho Later Than Wednesday, August 25,2004
August 2004
I am writing to express my firm opposition to the EPA's proposed plan for the 'cleanup'
of the Shpack Superfund Site.
EPA's preferred alternative (SC-2b) is unacceptable for reasons too numerous to detail
here. Most objectionable is the fact this option does not provide "permanence" and is
therefore not a "remedy". It would leave the Town of Norton with a still contaminated
site, and the responsibility & burdens of dealing with it, in the near and distant future.
In the face of the promise the Environmental Protection Agency made to the town,
EPA's chosen course of action, is reprehensible.
If community acceptance, plays any role in the EPA's decision making process for the
cleanup of Shpack, please give serious consideration to these comments, and select
Alternative SC-3b, which will at long last, give residents of this community the peace of
mind they deserve.
Signature
Print Name
~
Address jJV No. tUorg
-------
Comments to The US EPA on the June 2004 Proposed Plan For the Cleanup of
The Shpack Superfund Site, Norton/Attleboro, MA
To Dave Lederer
U.S. EPA
One Congress St., Suite 1100 (HBO)
Boston, MA 02114
Deadline - Postmarked By Wednesday, August 25, 2004
FAX (617) 918 - 1291, No Later Than Wednesday, August 25, 2004
August 2004
I am writing to express my firm opposition to the EPA's proposed plan for the 'cleanup'
of the Shpack Superfund Site.
EPA's preferred alternative (SC-2b) is unacceptable for reasons too numerous to detail
here. Most objectionable is the fact this option does not provide "permanence" and is
therefore not a "remedy". It would leave the Town of Norton with a still contaminated
site, and the responsibility & burdens of dealing with it, in the near and distant future.
In the face of the promise the Environmental Protection Agency made to the town,
EPA's chosen course of action, is reprehensible.
If community acceptance, plays any role in the EPA's decision making process for the
cleanup of Shpack, please give serious consideration to these comments, and select
Alternative SC-3b, which will at long last, give residents of this community the peace of
mind they deserve
Signature
/c/7 cSr
-------
Comments to The US EPA on the June 2004 Proposed Plan For the Cleanup of
The Shpack Supcrfund Site, Norton/Attleboro, MA
To Dave Lederer
U.S. EPA
One Congress St., Suite 1100 (HBO)
Boston, MA 02114
Deadline - Postmarked By Wednesday, August 25, 2004
FAX (617) 918 - 1291, No Later Than Wednesday, August 25, 2004
August 2004
I am writing to express my firm opposition to the EPA's proposed plan for the 'cleanup'
of the Shpack Superfund Site.
EPA's preferred alternative (SC-2b) is unacceptable for reasons too numerous to detail
here. Most objectionable is the fact this option does not provide "permanence" and is
therefore not a "remedy". It would leave the Town of Norton with a still contaminated
site, and the responsibility & burdens of dealing with it, in the near and distant future.
In the face of the promise the Environmental Protection Agency made to the town,
EPA's chosen course of action, is reprehensible.
If community acceptance, plays any role in the EPA's decision making process for the
cleanup of Shpack, please give serious consideration to these comments, and select
Alternative SC-3b, which will at long last, give residents of this community the peace of
mind they deserve.
Signature
Print Name
rr
j {JVi-
\~y\- H uJn
Q(\
Address
i. I? 6
-------
Comments to The US EPA on the June 2004 Proposed Plan For the Cleanup of
The Shpack Superfund Site, Norton/Attleboro, MA
To Dave Lederer
U.S. EPA
One Congress St., Suite 1100 (HBO)
Boston, MA 02114
Deadline - Postmarked By Wednesday, August 25,2004
FAX (617) 918 - 1291, No Later Than Wednesday, August 25,2004
r
August 2004
I am writing to express my firm opposition to the EPA's proposed plan for the •cleanup'
of the Shpack Superfund Site.
EPA's preferred alternative (SC-2b) is unacceptable for reasons too numerous to detail
here. Most objectionable is the fact this option does not provide "permanence" and is
therefore not a "remedy". It would leave the Town of Norton with a still contaminated
site, and the responsibility & burdens of dealing with it, in the near and distant future.
In the face of the promise the Environmental Protection Agency made to the town,
EPA's chosen course of action, is reprehensible.
If community acceptance, plays any role in the EPA's decision making process for the
cleanup of Shpack, please give serious consideration to these comments, and select
Alternative SC-3b, which will at long last, give residents of this community the peace of
mind they deserve.
Print Name
Address I ® ^
-------
Comments to The US EPA on the June 2004 Proposed Plan For the Cleanup of
The Shpack Superfund Site, Norton/Attleboro, MA
To Dave Lederer
U.S. EPA
One Congress St., Suite 1100 (HBO)
Boston, MA 02114
Deadline - Postmarked By Wednesday, August 25, 2004
FAX (617)918- 1291, No Later Than Wednesday, August 25, 2004
August 2004
I am writing to express my firm opposition to the EPA's proposed plan for the 'cleanup'
of the Shpack Superfund Site.
EPA's preferred alternative (SC-2b) is unacceptable for reasons too numerous to detail
here. Most objectionable is the fact this option does not provide "permanence" and is
therefore not a "remedy". It would leave the Town of Norton with a still contaminated
site, and the responsibility & burdens of dealing with it, in the near and distant future.
In the face of the promise the Environmental Protection Agency made to the town,
EPA's chosen course of action, is reprehensible.
If community acceptance, plays any role in the EPA's decision making process for the
cleanup of Shpack, please give serious consideration to these comments, and select
Alternative SC-3b, which will at long last, give residents of this community the peace of
mind they deserve.
Signature
Print Name i \lo-Ct I
Address
"5* t
-------
Comments to The US EPA on the June 2004 Proposed Plan For the Cleanup of
The Shpack Superfund Site, Norton/Attleboro, MA
To Dave Lederer
U.S. EPA
One Congress St., Suite 1100 (HBO)
Boston, MA 02114
Deadline - Postmarked By Wednesday, August 25, 2004
FAX (617) 9!8 - 1291,No Later Than Wednesday, August 25, 2004
August 2004
I am writing to express my firm opposition to the EPA's proposed plan for the 'cleanup'
of the Shpack Superfund Site.
EPA's preferred alternative (SC-2b) is unacceptable for reasons too numerous to detail
here. Most objectionable is the fact this option does not provide "permanence" and is
therefore not a "remedy". It would leave the Town of Norton with a still contaminated
site, and the responsibility & burdens of dealing with it, in the near and distant future.
In the face of the promise the Environmental Protection Agency made to the town,
EPA's chosen course of action, is reprehensible.
If community acceptance, plays any role in the EPA's decision making process for the
cleanup of Shpack, please give serious consideration to these comments, and select
Alternative SC-3b, which will at long last, give residents of this community the peace of
mind they deserve.
Print Name
Address 9S Sf
/\)c>
-------
Comments to The US EPA on the June 2004 Proposed Plan For the Cleanup of
The Shpack Superfiind Site, Norton/Attleboro, MA
To Dave Lederer
U.S. EPA
One Congress St., Suite 1100 (HBO)
Boston, MA 02114
Deadline - Postmarked By Wednesday, August 25, 2004
FAX (617) 918 - 1291, No Later Than Wednesday, August 25, 2004
r
August 2004
I am writing to express my firm opposition to the EPA's proposed plan for the 'cleanup'
of the Shpack Superfond Site.
EPA's preferred alternative (SC-2b) is unacceptable for reasons too numerous to detail
here. Most objectionable is the fact this option does not provide "permanence" and is
therefore not a "remedy". It would leave the Town of Norton with a still contaminated
site, and the responsibility & burdens of dealing with it, in the near and distant future.
In the face of the promise the Environmental Protection Agency made to the town,
EPA's chosen course of action, is reprehensible.
If community acceptance, plays any role in the EPA's decision making process for the
cleanup of Shpack, please give serious consideration to these comments, and select
Alternative SC-3b, which will at long last, give residents of this community the peace of
mind they deserve.
Address /57 H DLbgtJ
Le7$c£o, MftSs
-------
Comments to The US EPA on the June 2004 Proposed Plan For the Cleanup of
The Shpack Superfund Site. Norton/Attleboro, MA
To Dave Lederer
U.S. EPA
One Congress St., Suite 1100 (HBO)
Boston, MA 02114
Deadline - Postmarked By Wednesday, August 25, 2004
FAX (617) 918 - 1291, No Later Than Wednesday, August 25, 2004
August 2004
I am writing to express my firm opposition to the EPA's proposed plan for the 'cleanup'
of the Shpack Superfund Site.
EPA's preferred alternative (SC-2b) is unacceptable for reasons too numerous to detail
here. Most objectionable is the fact this option does not provide "permanence" and is
therefore not a "remedy" It would leave the Town of Norton with a still contaminated
site, and the responsibility & burdens of dealing with it, in the near and distant future.
In the face of the promise the Environmental Protection Agency made to the town,
EPA's chosen course of action, is reprehensible.
If community acceptance, plays any role in the EPA's decision making process for the
cleanup of Shpack, please give serious consideration to these comments, and select
Alternative SC-3b, which will at long last, give residents of this community the peace of
mind they deserve.
Address KOrffl V. K , CfolWO
I III — m I * |^WT»
-------
» iHhcr* .._ -— /
Comments to The US EPA on the June 2004 Proposed Plan For the Cleanup of
The Shpack Superfund Site, Norton/Attleboro, MA.
To Dave Lederer
U.S. EPA
One Congress St., Suite 1100 (HBO)
Boston, MA 02114
Deadline - Postmarked By Wednesday, August 25,2004
FAX (61 ?) 918 - 1291, No Later Than Wednesday, August 25,2004
August 2004
I am writing to express my firm opposition to the EPA's proposed plan for the 'cleanup*
of the Shpack Superfund Site.
EPA's preferred alternative (SC-2b) is unacceptable for reasons too numerous to detail
here. Most objectionable is the feet this option does not provide "permanence" and is
therefore not a "remedy". It would leave the Town of Norton with a still contaminated
site, and the responsibility & burdens of dealing with it, in the near and distant future.
In the face of the promise the Environmental Protection Agency made to the town,
EPA's chosen course of action, is reprehensible.
If community acceptance, plays any role in the EPA's decision making process for the
cleanup of Shpack, please give serious consideration to these comments, and select
Alternative SC-3b, which will at long last, give residents of Ms community the peace of
mind they deserve.
Address, XS(q \&xaA,C>v-^ A-V/f .
VjnrW... f .§ys*l£pCg..
-------
Comments to The US EPA on the June 2004 Proposed Plan For the Cleanup of
The Shpack Superfund Site, Norton/Attleboro, MA
To Dave Lederer
U.S. EPA
One Congress St., Suite 1100 (HBO)
Boston, MA 02114
Deadline - Postmarked By Wednesday, August 25,2004
FAX (617) 918 - 1291, No Later Than Wednesday, August 25,2004
August 2004
I am writing to express my firm opposition to the EPA's proposed plan for the 'cleanup'
of the Shpack Superfund Site.
EPA's preferred alternative (SC-2b) is unacceptable for reasons too numerous to detail
here. Most objectionable is the fact this option does not provide "permanence" and is
therefore not a "remedy". It would leave the Town of Norton with a still contaminated
site, and the responsibility & burdens of dealing with it, in the near and distant future,
In the face of the promise the Environmental Protection Agency made to the town,
EPA's chosen course of action, is reprehensible.
If community acceptance, plays any role in the EPA's decision making process for the
cleanup of Shpack, please give serious consideration to these comments, and select
Alternative SC-3b, which will at long last, give residents of this community the peace of
mind they deserve.
Signature
Prim Name DOTtMV/
Addre.fi /# 'TlU/iHtfl
-------
Comments to The US EPA on the June 2004 Proposed Plan For the Cleanup of
The Shpack Superfund Site, Norton/Attleboro, MA
To Dave Lederer
U.S. EPA
One Congress St., Suite 1100 (HBO)
Boston, MA 02114
Deadline - Postmarked By Wednesday, August 25, 2004
FAX (617)918- 1291, No Later Than Wednesday, August 25, 2004
August 2004
I am writing to express my firm opposition to the EPA's proposed plan for the 'cleanup'
of the Shpack Superfund Site.
EPA's preferred alternative (SC~2b) is unacceptable for reasons too numerous to detail
here. Most objectionable is the fact this option does not provide "permanence" and is
therefore not a "remedy". It would leave the Town of Norton with a still contaminated
site, and the responsibility & burdens of dealing with it, in the near and distant future.
In the face of the promise the Environmental Protection Agency made to the town,
EPA's chosen course of action, is reprehensible.
If community acceptance, plays any role in the EPA's decision making process for the
cleanup of Shpack, please give serious consideration to these comments, and select
Alternative SC-3b, which will at long last, give residents of this community the peace of
mind they deserve.
Address
-------
Comments to The US EPA on the June 2004 Proposed Plan For the Cleanup of
The Shpack Superfund Site, Norton/Attleboro, MA
To Dave Lederer
U.S. EPA
One Congress St., Suite 1100 (HBO)
Boston, MA 02114
Deadline - Postmarked By Wednesday, August 25, 2004
FAX {617) 918 - 1291, No Later Than Wednesday, August 25,2004
August 2004
1 am writing to express my firm opposition to the EPA's proposed plan for the 'cleanup'
of the Shpack Superfund Site.
EPA's preferred alternative (SC-2b) is unacceptable for reasons too numerous to detail
here. Most objectionable is the fact this option does not provide "permanence" and is
therefore not a "remedy". It would leave the Town of Norton with a still contaminated
site, and the responsibility & burdens of dealing with it, in the near and distant future.
In the face of the promise the Environmental Protection Agency made to the town,
EPA's chosen course of action, is reprehensible.
If community acceptance, plays any role in the EPA's decision making process for the
cleanup of Shpack, please give serious consideration to these comments, and select
Alternative SC-3b, which will at long last, give residents of this community the peace of
mind they deserve.
Signature
Print Name V\v>l f? ^ Liff b
Address \ L I
Ok I 9 tnj t'/Ll
-------
Comments to The US EPA on the June 2004 Proposed Plan For the Cleanup of
The Shpack Superfund Site, Norton/Attleboro, MA
To Dave Lederer
U.S. EPA
One Congress St., Suite 1100 (HBO)
Boston, MA 02114
Deadline - Postmarked By Wednesday, August 25,2004
FAX (617) 918 - 1291, No Later Than Wednesday, August 25, 2004
August 2004
I am writing to express my firm opposition to the EPA's proposed plan for the 'cleanup'
of the Shpaek Superfund Site.
EPA's preferred alternative (SC-2b) is unacceptable for reasons too numerous to detail
here. Most objectionable is the faet this option does not provide "permanence" and is
therefore not a "remedy". It would leave the Town of Norton with a still contaminated
site, and the responsibility & burdens of dealing with it, in the near and distant future.
In the face of the promise the Environmental Protection Agency made to the town,
EPA's chosen course of action, is reprehensible.
If community acceptance, plays any role in the EPA's decision making process for the
cleanup of Shpack, please give serious consideration to these comments, and select
Alternative SC-3b, which will at long last, give residents of this community the peace of
mind they deserve.
Signature
Print Name
Address
-------
«-i§. . 23';4 S P*v':PaVRO._ S£3V!CES. '.SC.
Comments 10 The US EPA on the June 2004 Proposed Plan For the Cleanup of
The Shpack Superfund Site, Norton/Attleboro, MA
To Dave Lederer
U.S. EPA
One Congress St., Suite 1100 (HBO)
Boston, MA 02114
Deadline - Postmarked By Wednesday, August 25,2004
FAX (617) 918 - 1291, No Later Than Wednesday, August 25,2004
August 2004
I am writing to express my firm opposition to the EPA's proposed plan for the 'cleanup'
of the Shpack Superfund Site,
EPA's preferred alternative (SC-2b) is unacceptable for reasons too numerous to detail
here. Most objectionable is the fact this option does not provide "permanence" and is
therefore not a "remedy". It would leave the Town of Norton with a still contaminated
site, and the responsibility & burdens of dealing with it, in the near and distant future
In the face of the promise the Environmental Protection Agency made to the town,
EPA's chosen course of action, is reprehensible.
If community acceptance, plays any role in the EPA's decision making process for the
cleanup of Shpack, please give serious consideration to these comments, and select
Alternative SC-3b, which will at long last, give residents of this community the peace of
mind they deserve
Address
-------
Aug-13-04 I: 1Qam FroarSTATE STREET SLOSAL ADVISORS
6!f-6 S4-2 S 57
T-;5i POCI/O:' F-ci3
Comments to The US EPA on the June 2004 Proposed Plan For the Cleanup of
The Shpack Superfund Site, Norton/Attleboro, MA
To Dave Lederer
U.S. EPA
One Congress St, Suite 1100 (HBO)
Boston, MA 02114
Deadline - Postmarked By Wednesday, August 25,2G04
FAX (617) 918- 1291, No Later Than Wednesday, August 25,2004
August 2004
I am writing to express my firm opposition to the EPA's proposed plan for the 'cleanup'
of the Shpack Superfund Site.
EPA's preferred alternative (SC-2b) is unacceptable for reasons too numerous to detail
here. Most objectionable is the fact this option does not provide "permanence" and is
therefore not a "remedy" It would leave the Town of Norton with a still contaminated
site, and the responsibility & burdens of dealing with it, in the near and distant future.
In the face of the promise the Environmental Protection Agency made to the town,
EPA's chosen course of action, is reprehensible.
If community acceptance, plays any role in the EPA's decision making process for the
cleanup of Shpack, please give serious consideration to these comments, and select
Alternative SC-3b, which will at long last, give residents of this community the peace of
mind they deserve.
Signature
Print Name vu ^
Address ^ o^W. VWu.s4r<" -S'Wcc.V
eh* \pfy_ 6 6
-------
Comments to The US EPA on the June 2004 Proposed Plan For the Cleanup of
The Shpack Superfund Site, Norton/Attieboro, MA
To Dave Lederer
U.S. EPA
One Congress St., Suite 1100 (HBO)
Boston, MA 02114
Deadline - Postmarked By Wednesday, August 25, 2004
FAX (617) 918 - 1291, No Later Than Wednesday, August 25,2004
August 2004
I am writing to express my firm opposition to the EPA's proposed plan for the 'cleanup'
of the Shpaek Superfund Site,
EPA's preferred alternative (SC-2b) is unacceptable for reasons too numerous to detail
here. Most objectionable is the fact this option does not provide "permanence" and is
therefore not a "remedy". It would leave the Town of Norton with a still contaminated
site, and the responsibility & burdens of dealing with it, in the near and distant future.
In the face of the promise the Environmental Protection Agency made to the town,
EPA's chosen course of action, is reprehensible.
If community acceptance, plays any role in the EPA's decision making process for the
cleanup of Shpack, please give serious consideration to these comments, and select
Alternative SC-3b, which will at long last, give residents of this community the peace of
mind they deserve.
/
Print Name p ^77\cwvii
Address
n rftkL* o
^~
hjcrJjiTt f)/l$ OX^U
-------
Comments to The US EPA on the June 2004 Proposed Plan For the Cleanup of
The Shpack Superfund Site, Norton/Attleboro, MA
To Dave Lederer
U.S. EPA
One Congress St., Suite 1100 (HBO)
Boston, MA 02114
Deadline - Postmarked By Wednesday, August 25, 2004
FAX (617) 918 - 1291, No Later Than Wednesday, August 25, 2004
August 2004
I am writing to express my firm opposition to the EP A's proposed plan for the 'cleanup'
of the Shpack Superfund Site.
EPA's preferred alternative (SC-2b) is unacceptable for reasons too numerous to detail
here. Most objectionable is the fact this option does not provide "permanence" and is
therefore not a "remedy". It would leave the Town of Norton with a still contaminated
site, and the responsibility & burdens of dealing with it, in the near and distant future,
in the face of the promise the Environmental Protection Agency made to the town,
EPA's chosen course of action, is reprehensible.
If community acceptance, plays any role in the EPA's decision making process for the
cleanup of Shpack, please give serious consideration to these comments, and select
Alternative SC-3b, which will at long last, give residents of this community the peace of
mind they deserve.
Signatw
^OS/tfaJ x/t £¦/i>//i/&
3/ ^
Print Name
Address
-------
Comments to The US EPA on the June 2004 Proposed Plan For the Cleanup of
The Shpack Superfund Site, Norton/Attleboro, MA
To Dave Lederer
U.S. EPA
One Congress St., Suite 1100 (HBO)
Boston, MA 02114
Deadline - Postmarked By Wednesday, August 25,2004
FAX (617) 918 - 1291, No Later Than Wednesday»August 25,2004
August 2004
I am writing to express my firm opposition to the EPA's proposed plan for the 'cleanup'
of the Shpack Superfund Site.
EPA's preferred alternative (SC-2b) is unacceptable for reasons too numerous to detail
here. Most objectionable is the fact this option does not provide "permanence" and is
therefore not a "remedy". It would leave the Town of Norton with a still contaminated
site, and the responsibility & burdens of dealing with it, in the near and distant future.
In the face of the promise the Environmental Protection Agency made to the town,
EPA's chosen course of action, is reprehensible.
If community acceptance, plays any role in the EPA's decision making process for the
cleanup of Shpack, please give serious consideration to these comments, and select
Alternative SC-3b, which will at long last, give residents of this community the peace of
mind they deserve.
Signature
Print Name
Address
f\Jcn L [.yj 2-T £ 'jo
-------
Comments to The US EPA on the June 2004 Proposed Plan For the Cleanup of
The Shpaek Superfund Site, Norton/Attleboro, MA
To Dave Lederer
U.S. EPA
One Congress St., Suite 1100 (HBO)
Boston, MA 02114
Deadline - Postmarked By Wednesday, August 25,2004
FAX (617) 918 - 1291, No Later Than Wednesday, August 25, 2004
August 2004
I am writing to express my firm opposition to the EPA's proposed plan for the 'cleanup'
of the Shpaek Superfund Site.
EPA's preferred alternative (SC-2b) is unacceptable for reasons too numerous to detail
here. Most objectionable is the fact this option does not provide "permanence" and is
therefore not a "remedy". It would leave the Town of Norton with a still contaminated
site, and the responsibility & burdens of dealing with it, in the near and distant future.
In the face of the promise the Environmental Protection Agency made to the town,
EPA's chosen course of action, is reprehensible.
If community acceptance, plays any role in the EPA's decision making process for the
cleanup of Shpaek, please give serious consideration to these comments, and select
Alternative SC-3b, which will at long last, give residents of this community the peace of
mind they deserve.
Signature
Print Name
Address
/yl/j O 3-~7C C
(
-------
Comments to The US EPA on the June 2004 Proposed Plan For the Cleanup of
The Shpack Superfund Site, Norton/Attleboro, MA
To Dave Lederer
U.S. EPA
One Congress St., Suite 1100 (HBO)
Boston, MA 02114
Deadline - Postmarked By Wednesday, August 25,2004
FAX (617) 918 - 1291, No Later Than Wednesday, August 25,2004
August 2004
I am writing to express my firm opposition to the EPA's proposed plan for the 'cleanup'
of the Shpack Superfund Site.
EPA's preferred alternative (SC-2b) is unacceptable for reasons too numerous to detail
here. Most objectionable is the fact this option does not provide "permanence" and is
therefore not a "remedy". It would leave the Town of Norton with a still contaminated
site, and the responsibility & burdens of dealing with it, in the near and distant future.
In the face of the promise the Environmental Protection Agency made to the town,
EPA's chosen course of action, is reprehensible.
If community acceptance, plays any role in the EPA's decision making process for the
cleanup of Shpack, please give serious consideration to these comments, and select
Alternative SC-3b, which will at long last, give residents of this community the peace of
mind they deserve.
Print Name
Signature
Address
/U^> /2TT, yV A & 2-YC L
-------
Comments to The US EPA on the June 2004 Proposed Plan For the Cleanup of
The Shpack Superfund Site, Norton/Attleboro, MA
To Dave Lederer
U.S. EPA
One Congress St,, Suite 1100 (HBO)
Boston, MA 02114
Deadline - Postmarked By Wednesday, August 25,2004
FAX (617) 918 - 1291, No Later Than Wednesday, August 25,2004
August 2004
I am writing to express my Firm opposition to the EPA's proposed plan for the 'cleanup'
of the Shpack Superfund Site,
EPA's preferred alternative (SC-2b) is unacceptable for reasons too numerous to detail
here. Most objectionable is the fact this option does not provide "permanence" and is
therefore not a "remedy". It would leave the Town of Norton with a still contaminated
site, and the responsibility & burdens of dealing with it, in the near and distant future.
In the face of the promise the Environmental Protection Agency made to the town,
EPA's chosen course of action, is reprehensible.
If community acceptance, plays any role in the EPA's decision making process for the
cleanup of Shpack, please give serious consideration to these comments, and select
Alternative SC-3b, which will at long last, give residents of this community the peace of
mind they deserve.
Signature
Print Name
Address
/V yL~yr3 /u /-
-------
Comments to The US EPA on the June 2004 Proposed Plan For the Cleanup of
The Shpack Superfund Site, Norton/Attleboro, MA
To Dave Lederer
U.S. EPA
One Congress St., Suite 1100 (HBO)
Boston, MA 02114
Deadline - Postmarked By Wednesday, August 25,2004
FAX (617) 918 - 1291, No Later Than Wednesday, August 25,2004
August 2004
I am writing to express my firm opposition to the EPA's proposed plan for the 'cleanup'
of the Shpack Superfund Site.
EPA's preferred alternative (SC-2b) is unacceptable for reasons too numerous to detail
here. Most objectionable is the fact this option does not provide "permanence" and is
therefore not a "remedy". It would leave the Town of Norton with a still contaminated
site, and the responsibility & burdens of dealing with it, in the near and distant future.
In the face of the promise the Environmental Protection Agency made to the town,
EPA's chosen course of action, is reprehensible.
If community acceptance, plays my role in the EPA's decision making process for the
cleanup of Shpack, please give serious consideration to these comments, and select
Alternative SC-3b, which will at long last, give residents of this community the peace of
mind they deserve.
Print Name
WffLTF^/Z ~ZJASCt4LA-ls
AdA™ _ Q-2-D PilC-S J-fHcbtxj
-------
Comments to The US EPA on the June 2004 Proposed Plan For the Cleanup of
The Shpack Supeifund Site, Norton/Attleboro, MA
To Dave Lederer
U.S. EPA
One Congress St., Suite 1100 (HBO)
Boston, MA 02114
Deadline - Postmarked By Wednesday, August 25,2004
FAX (617)918- 1291, No Later Than Wednesday, August 25, 2004
August 2004
I am writing to express my firm opposition to the EPA's proposed plan for the 'cleanup'
of the Shpack Superfund Site.
EPA's preferred alternative (SC-2b) is unacceptable for reasons too numerous to detail
here. Most objectionable is the fact this option does not provide "permanence" and is
therefore not a "remedy". It would leave the Town of Norton with a still contaminated
site, and the responsibility & burdens of dealing with it, in the near and distant future.
In the face of the promise the Environmental Protection Agency made to the town,
EPA's chosen course of action, is reprehensible.
If community acceptance, plays any role in the EPA's decision making process for the
cleanup of Shpack, please give serious consideration to these comments, and select
Alternative SC-3b, which will at long last, give residents of this community the peace of
mind they deserve.
Print Name
Address
-------
Comments to The US EPA on the June 2004 Proposed Plan For the Cleanup of
The Shpack Superfund Site. Norton/Attleboro, MA
To Dave Lederer
U.S. EPA
One Congress St., Suite 1100 (HBO)
Boston, MA 02114
Deadline - Postmarked By Wednesday, August 25, 2004
FAX (617) 918 - 1291, No Later Than Wednesday, August 25, 2004
August 2004
I am writing to express my firm opposition to the EPA's proposed plan for the 'cleanup'
of the Shpack Superfund Site.
EPA's preferred alternative (SC-2b) is unacceptable for reasons too numerous to detail
here. Most objectionable is the fact this option does not provide "permanence" and is
therefore not a "remedy". It would leave the Town of Norton with a still contaminated
site, and the responsibility & burdens of dealing with it, in the near and distant future.
In the face of the promise the Environmental Protection Agency made to the town,
EPA's chosen course of action, is reprehensible.
If community acceptance, plays any role in the EPA's decision making process for the
cleanup of Shpack, please give serious consideration to these comments, and select
Alternative SC-3b, which will at long last, give residents of this community the peace of
mind they deserve.
Signature
Print Name
Address XWdX
k/^r-hn, a G
-------
Comments to The US EPA on the June 2004 Proposed Plan For the Cleanup of
The Shpack Superfund Site. Norton/Attieboro, MA
To Dave Lederer
U.S. EPA
One Congress St., Suite 1100 (HBO)
Boston, MA 02114
Deadline - Postmarked By Wednesday, August 25, 2004
FAX (617)918- 1291, No Later Than Wednesday, August 25, 2004
August 2004
I am writing to express my firm opposition to the EPA's proposed plan for the "cleanup'
of the Shpack Superfund Site.
EPA's preferred alternative (SC-2b) is unacceptable for reasons too numerous to detail
here. Most objectionable is the fact this option does not provide "permanence" and is
therefore not a "remedy*'. It would leave the Town of Norton with a still contaminated
site, and the responsibility & burdens of dealing with it, in the near and distant future.
In the face of the promise the Environmental Protection Agency made to the town,
EPA's chosen course of action, is reprehensible.
If community acceptance, plays any role in the EPA's decision making process for the
cleanup of Shpack, please give serious consideration to these comments, and select
Alternative SC-3b, which will at long last, give residents of this community the peace of
mind they deserve.
Signature
Print Name
Address
-------
Comments to The US EPA on the June 2004 Proposed Pian For the Cleanup of
The Shpack Superior,d Site, Norton/Attlcboro, MA
To Dave Ledercr
U.S. EPA
Out Congress St. Suite [ 3 00 (HBO)
Boston. MA 02114
Deadline - Postmarked By Wednesday, August 25,2004
FAX (617) 918 - 1291, No Later Than Wednesday, August 25,2004
August 2004
I am writing to express my £rm opposition to the EPA'a proposed plan for the 'cleanup*
of the Shpack Superftmd Site,
EPA's preferred alternative (SC-2b) Is unacceptable for reasons too numerous to detail
here. Most objectionable is the fact this option does not provide "pennanence" and is
therefore not a "remedy". It would lave the Town of Norton with a still contaminated
site, and the responsibility & burdens of dealing with it, in the sear and distant future.
In the face of the promise the Environmental Protection Agency made to the lown.
EPA's chosen course of action, is reprehensible.
If community acceptance, plays my role in tic EPA's decision making process for the
cleanup of Shpack. pieasc give jerious consideration to diew XQinments, and select
Alternative SC-3b, which will at long last, give residents of thiscornmunity1^TS«cc erf
mind they deserve.
Signature
Pnm Name Pa irs f? aJrr I i -f^C
Address ~2.QU ~~ThCJ A,(/^&
Signature
lYsrfo/l ha. Q% 1U4,
-------
Comments to The US EPA on the June 2004 Proposed Plan For the Cleanup of
The Shpack Superfimd Site, Norton/Attleboro, MA
To Dave Lederer
U.S. EPA
One Congress St. Suite i 100 (HBO)
Boston, MA 02114
Deadline - Postmarked By Wednesday, August 23,2004
FAX (617)918-1291, No Later Than Wednesday, August 25,2004
August 2004
I am writing to express my firm opposition to the EPA's proposed plan for the 'cleanup'
of the Shpack Superftmd Site.
EPA's preferred alternative (SC-2b) is unacceptable for reasons too numerous to detail
here. Most objectionable is the fact this option doea not provide "permanence" and is
therefore not a "remedy". It would leave the Town of Norton with a still contaminated
site, and the responsibility A burdens of dealing with it, in the near and distant ftiture.
to the face of the promise the Environmental Protection Agency made to the town,
EPA's chosen course of action, is reprehensible.
If community acceptance, plays any role in the EPA*s decision making process for the
cleanup of Shpack, please give serious consideration to ;he^a«TMent§, md select
Alternative SC-3b, which will at long last, give residents of this of
mind they deserve.
Signature
Prim Mum fi/b?"- T 0
Addieas 2 Tfit/A/7~#A/
& a/ />/#
-------
Comments to The US EPA on the June 2004 Proposed Plan For the Cleanup of
The Shpack Superfund Site, Norton/Attleboro, MA
To Dave Lederer
U.S. EPA
One Congress St., Suite 1100 (HBO)
Boston, MA 02114
Deadline - Postmarked By Wednesday, August 25, 2004
FAX (617) 918 - 1291, No Later Than Wednesday, August 25, 2004
August 2004
I am writing to express my firm opposition to the EPA's proposed plan for the 'cleanup*
of the Shpack Superfund Site.
EPA's preferred alternative (SC-2b) is unacceptable for reasons too numerous to detail
here. Most objectionable is the fact this option does not provide "permanence" and is
therefore not a "remedy". It would leave the Town of Norton with a still contaminated
site, and the responsibility & burdens of dealing with it, in the near and distant future.
In the face of the promise the Environmental Protection Agency made to the town,
EPA's chosen course of action, is reprehensible.
If community acceptance, plays any role in the EPA's decision making process for the
cleanup of Shpack, please give serious consideration to these comments, and select
Alternative SC-3b, which will at long last, give residents of this community the peace of
mind they deserve.
Signature
Print Name
Address
2-oCe CJlsL Ax*
oZTqCb
-------
Comments to The US EPA on the June 2004 Proposed Plan For the Cleanup of
The Shpack Superfimd Site, NortoitfAtlteboto, MA
To Dave Ledertr
U.S. EPA
Or,e Conarcss St. Suits ! 100 (HBO)
Bos'cc. NLA 021 H
Deadline - Posmariccd By Wednesday, August 25,2004
FAX (6! 1} 918 - 125J, No Later !Mn Wednesday, August 25, 200-5
Augu.il 2004
1 am wriibg to express my firm opposition to the EPA's proposed plan for the 'cleanup'
c: Lie Shpacfc Superfind Site.
HPA's preferred alternative (SC-2b) is unacceptable fcr reasons tew numerous to detail
here. Most objectionable is the fact this option does not provide "pcnr.arxnce" end is
therefore no; a "remedy". It would leave die Town otNottott \viih a still contaminated
ji'.e, and the rcsponsibiliiy & burdens of dealing with it in the near and distant future.
In the face of the promise the Environmental Protection Agency mace to the town,
HPA's chosen course of action, is reptchensible.
lf community acceptance, plays any role in the EPA's decision making process for the
Cieaimp of Shpacic. please give serious consic station tc ±es£X«npnent»? and select
Alterative SC»3b, which will at long last, give residents of this coatmwi}t5'the'whscc of
nind they deserve.
-------
Comments to The US EPA on the June 2004 Proposed Plan For the Cleanup of
The Shpack Superfund Site, Norton/Attleboro, MA
To Dave Lederer
U.S. EPA
One Congress St., Suite 1100 (HBO)
Boston, MA 02114
Deadline - Postmarked By Wednesday, August 25,2004
FAX (617) 918 - 1291, No Later Than Wednesday, August 25,2004
August 2004
I am writing to express my firm opposition to the EPA's proposed plan for the 'cleanup*
of the Shpack Superfund Site.
EPA's preferred alternative (SC-2b) is unacceptable for reasons too numerous to detail
here. Most objectionable is the fact this option does not provide "permanence" and is
therefore not a "remedy". It would leave the Town of Norton with a still contaminated
site, and the responsibility & burdens of dealing with it, in the near and distant future.
In the face of the promise the Environmental Protection Agency made to the town,
EPA's chosen course of action, is reprehensible.
If community acceptance, plays any role in the EPA's decision making process for the
cleanup of Shpack, please give serious consideration to these comments, and select
Alternative SC-3b, which will at long last, give residents of this community the peace of
mind they deserve.
Signature
Print Name f a tout h¦ Lees
Address
I Boy i
-------
Comments to The US EPA on the June 2004 Proposed Plan For the Cleanup of
The Shpaek Superfund Site, Norton/Attleboro, MA
To Dave Lcderer
U.S. EPA
One Congress St,, Suite 1100 (HBO)
Boston, MA 02114
Deadline - Postmarked By Wednesday, August 25,2004
FAX (617) 918 - 1291, No Later Than Wednesday, August 25,2004
August 2004
1 am writing to express my firm opposition to the EPA's proposed plan for the 'cleanup'
of the Shpaek Superfund Site.
EPA's preferred alternative (SC-2b) is unacceptable for reasons too numerous to detail
here. Most objectionable is the fact this option does not provide "permanence" and is
therefore not a "remedy". It would leave the Town of Norton with a still contaminated
site, and the responsibility & burdens of dealing with it, in the near and distant future.
In the face of the promise the Environmental Protection Agency made to the town,
EPA's chosen course of action, is reprehensible.
If community acceptance, plays any role in the EPA's decision making process for the
cleanup of Shpaek, please give serious consideration to these comments, and select
Alternative SC-3b, which will at long last, give residents of this community the peace of
mind they deserve,
Signature
Print Name M- f-f/YL L AHAtJ
i Willi I— —
Address U6 South UofLe&Srtnt !>r
(slca-ny^. tAA Q3-7 fcfc
-------
Comments to The US EPA on the June 2004 Proposed Plan For the Cleanup of
The Shpack Superfiind Site, Norton/Attleboro, MA
To Dave Lederer
U.S. EPA
One Congress St., Suite ! 100 (HBO)
Boston, MA 02114
Deadline - Postmarked By Wednesday, August 25,2004
FAX (617) 918 - 1291, No Later Than Wednesday, August 25,2004
August 2004
I am writing to express my firm opposition to the EPA's proposed plan for the 'cleanup*
of the Shpack Superfiind Site.
EPA's preferred alternative (SC-2b) is unacceptable for reasons too numerous to detail
here. Most objectionable is the faet this option does not provide "permanence" and is
therefore not a "remedy". It would leave the Town of Norton with a still contaminated
site, and the responsibility & burdens of dealing with it, in the near and distant future.
In the face of the promise the Environmental Protection Agency made to the town,
EPA's chosen course of action, is reprehensible.
If community acceptance, plays any role in the EPA's decision making process for the ,
cleanup of Shpack, please give serious consideration to these comments, and select
Alternative SC-3b, which will at long last, give residents of this community the peace of
mind they deserve.
Prim Name /.erfSO- I. /sCCL,
f/er-fvn, /D& a
-------
Appendix A: State Concurrence Letter
-------
Commonwealth of Massachusetts
Executive Office of Environmental Affairs
Department of Environmental Protection
ONE WINTER STREET. BOSTON, MA 0210R 617-292-5500
MITT EOMNEY
Governor
KLLhlN iiOY mClJZKIiL!l|-;it
Secretary
KERRY HEA1EY
Lieutenant Governor
KOJIEHT W GOLI,FDGK: Jr.
Comnu^ioiter
September 29, 2004
Ms. Susan Studlien, Director
Office of Site Remediation and Restoration
U.S. EPA
One Congress St., Suite 1100
Boston, MA 02114-2023
Re: State Concurrence Letter
Dear Ms. Studlien:
The Massachusetts Department of Environmental Protection (DEP) has reviewed the remedial action
alternative ("Option 3b") selected by EPA for the remediation of the Shpack Superfund Site in Norton and
Attleboro, Massachusetts. Based upon an evaluation of available information and data, as well as public
comments received in this matter, DEP concurs with the selected remedy for this site.
DEP has evaluated the EPA's selected remedy for consistency with applicable, relevant and appropriate
state requirements. The selected remedy addresses a continuing source of contamination to surface water,
sediment, and to the private drinking water supplies of nearby residents, and includes the following
components:
1) Excavation and off-site disposal of all wastes and contaminated media exceeding site cleanup goals, 2)
Backfilling to the original grade, 3) Restoration of impacted wetland resources, 4) Extension of a waterline
to replace private water supplies, 5) Implementation of land use restrictions, and 6) Long term monitoring
DEP believes that the selected remedy for this site will be protective of human health and the environment.
Once the remedial actions are implemented at the site and the private water supplies are eliminated,
groundwater at and in the vicinity of the site would no longer be considered a current or future drinking
water source (GW-1 Classification) under the Massachusetts Contingency Plan. At that point, DEP will
This information is available in alternate format. Call Donald M. Gomes, ADA Coordinator at 617-56-1057. TDD Service - 1-800-298-2207
Shpack Superfund Site, Norton/Attleboro
DEP on the World Wide Web http //www mass gov/dep
Printed on Recycled Paper
-------
Page 2 DEP
Concurrence Letter
September 29, 2004
revise the Groundwater Use and Value determination to reflect a low use and value, provided that the wells
are decommissioned and controls placed on the future use of groundwater at these properties. The
Department looks forwarded to working with you on implementing the preferred alternative. If you have
any questions, please contact David Buckley at 617-556-1184.
Sincerely,
Robert W. Golleclge, Jr.
Commissioner
cc: Dave Buckley, DEP
e-file: Shpack ROD Concurrence LETTER 040924
-------
Appendix B: ARAR's Tables
-------
Alternative SC-3B - Excavation/Ojf-Site Disposal (Adjacent Resident Without Groundwater Consumption)
Potential Chemical-Specific ARARs
Shpack Landfill Supetfuml Site
Norton/Atlleboro, Massachusetts
Medium l^ireme«s Synopsis of Require
STATE REGULA1
Soil/
Groundwater
ORY REQUIREMENTS
Massachusetts Regulations for Control of Radiation (105 CMR
120)
Relevant and
Appropriate
Ivsbahlishes standards for radiation related activities.
*
FEDERAL RF.RUt
Non-
Environmental
Materials
.ATORY REQUIREMENTS
Department ot the Army, USACK hM~3B5-l-60, lable 6-4
To be Considered
This USAOR Radiation Protection Manual table sets acceptable surface contamination
levels for U-nat, U-235, U-238 and associated decay products lor release of equipment
3nd non-environmental materials (e.g., old kitchen appliances).
*
Soil
Domestic Licensing of Source Material (30 CT'R 40, Appendix A,
Relevant and
Appropriate
Establishes benchmark approach for setting clean-up levels for radionuclides
*
Health and Environmental Protection Standards for Uranium
Relevant and
Appropriate
Establishes concentration limits for clean-up of Ra-226, Ra-228 and thorium m soil
*
Use of StuI Clean-up Criteria in 40 CFR Fart 192 as Remediation
Goals forCHKCl-A Sites, Directive No. 9200,4-25, February 12,
To be Considered
Addresses use of soil clean-up criteria in 40 OR 1^2 in setting remediation levels for
subsurface soil at CI-RCI .A sites with radioactive contamination.
*
Remediation Goals for Radioactively-Contarriinated CHRCLA
Site Using the Benchmark Dose Oean-Up Criteria m 10 CTR 40,
Appendix A, I, Criterion 6(6), Directive No. 9200-4-351', April
11,2000.
To be Considered
Addresses the use of the soil and structure clean-up criteria m 10 CJ-R 40, Appendix A,
I, Criterion b(h) with setting remediation goals at CKRCI -A sites with radioactive
contamination
ic
Sediment
Ontario Ministry of the Environment Sediment Quality
Guidelines
To be Considered
The Sediment Quality Guidelines present scientific data and guidance on the
environmental effects of pollutants. The criteria can contribute to establishing
*
\otev
Applu'abk* ¦ AJdrvsm-S A hdzdntous Ktdiuv. pollutant, contaminant. ri'rmilial artwn. If* anon or other * itrums>Wn>m% bul ddtiro^es Miualums simsl.tr t-iiough to ho relevant and appropriate
n, h, ier,,i - '«"™> » <*«•< «* AKAK s,„lus, they mav N* . 4^ (fen* W> F'""""" « P"W" h«'""h «r lh" W
* Will N* rmi through ev jv
-------
Alternative SC-3B - ixcaration/Off-Site Disposal (Adjacent Resident Without Groundwater Consumption)
Potential Location-Specific ARARs
Shpack Landfill Supetfund Site
NartottfAitteboro, Massachusetts
Meet or Attain
Medium Requirements Status Synopsis of Requirements ARAR
STATE REGULATORY REQUIREMENTS
Wetland
Sediment
Massachusetts Wetlands Protection Act Regulations (310 CMR
1000)
Applicable
These regulations are promulgated under Wetlands Protection l^ws, which regulate
dredging, filling altering or polluting inland wethmds. This requirement regulates
work within the wetlands buffer zone,, and defines wetlands based on vegetation type
and mitigation requirements.
***
401 Water Quality Certificalion for I >ischarg,e of Dredged or Fill
Material (314 CMR 9.00)
Applicable
ARAR if discharge of dredged or fill material occurs.
***
Massachusetts Rmlangered Species Act {321 CMR 10.00)
Applicable
Requires that site activities be conducted in a manner that minimizes impact to
Massachusetts-listed rare, threatened, or endangered species, and species listed by the
Massachusetts Natural 1 lentage Program.
**
FEDERAL REGULATORY REQUIREMENTS
Weti and
Sediment
Federal Executive Order on Protection of Wetlands (E.G. 11940,
40 CFR Part 6, Appendix A)
Applicable
Requires federal agencies to avoid impacts aswaiated with the destruction or loss of
wetlands, minimis* potential harm, preserve and enhance wetlands, and avoid support
tif new construction m wetlands if a practicable alternative exists.
*
federal Fish and Wildlife Cixirdinatum Act (16 U5C 661 et seq„
40 OR Part 6)
Applicable
Establishes requirements for a consultation with U.S. Fish and Wildlife Service and state
wildlife agencies to mitigate losses of fish and wildlife thai result from modification of a
water body
****
Federal Clean Water Act (33 USC 1344), US Army Corps of
Hngineers Nationwide Permit Program (33 CFR Part 330),
"Federal Guidehnes for Specification of Disposal Sites" {40 CFR
Part 210), Clean Water Act Sections 401 and 404 (33 CFR 26)
Applicable
Under this requirement, no activity that adversely atfects a wetland shall be permitted if
a practicable alternative that has less effect is available. The requirements also describe
actions to minimize adverse impacts. Fstahhsbes regulations for filling and dredging
within wetlands
*
Endangered Species Act (50 CFK Parts 1 ?. 11-12)
Applicable
Requires site action be conducted in a manner thai a voids harming threatened or
endangered species or their habitat.
**
\oxey.
Applh-ablc - Addri-ssos <* fvi/^fdoLK -sutKtanav pt'lIuUmJ, cmuamifum, remcdt^l ji tion, f rnnsidcrtxJ - V>n-promul£tdtc cplena, Advisories or pjiiidamv dsi mil have AN AH however, thev nuv het"otwdfT<\j in determining lU-anup levels prultxiive v htf,h of s-ontiiimnMOs) t"*>;i ;fl wetlands are.t !h-iv rv.i praciu-a; altetrwme to ev ui. .ill Mih^umtivo rviimrervu'nts ef ihe«-e n-guliHums will be nvt.
"""" -J-. mid this .ilvni.im"' f^unf in> idili.MfJon i-: j w.ivr IhhIv lius i .fi'sN-i.mon reouuvriieH: will [te tendu, ted
Cage 2 of 5
-------
Alternative SC-3B - Excavation/Off-Site Disposal (Adjacent Resident Without Groundwater Consumption)
Potential Action-Specific ARARs
Shpack Landfill Superfund Site
Norton/Attleboro, Massachusetts
Medium
Requirements
Status
Synopsis of Requirements
Meet or Attain
AKAR
STATE REGULATORY REQUIREMENTS
Air
Massachusetts DBF Air Pollution Control Regulations (310
CME 7,00)
Applicable
These regulations set requirements for fugitive emissions, dust, and particulates.
*
Non-
EnviionmentaJ
Materials
Department of the Army, USACE EM-385-1-80, Table 6-4
To be Considered
This USACE Radiation Protection Manual table yets acceptable surface contamination
levels for U-nat U-235, U-238 and associated decay products for release of equipment
and non-environmental materials (e.g., old kitchen appliances).
t
Soil
Domestic Licencing of Source Material (10 CFR 40, Appendix A,
I Criterion 6(6))
Relevant and
Appropriate
Establishes benchmark approach for setting clcan-up levels for radionuclides.
t
Health and Environmental Protection Standards for Uranium
and Thorium Mill Tailings (40 CFR Part 192)
Relevant and
Apprvpriati'
Establishes concentration limits for clean-up of Ra-226, Ra-22H and thorium in soil.
t
Use of Soil Clean-up Criteria in 40 CFR fart 192 as Remediation
Goals for CERCLA Sites, Directive Ho ¥200.4-25, February 12,
1998.
To be Considered
Address<*s use of soil clean-up criteria in 40 CFR 192 in setting remediation levels for
subsurface soil at CERCLA sites with radioactive contamination.
t
Remediation Coals for Radioactively-Contaminated CERCLA
Site Using the Benchmark Dose Clean-Up Criteria in 10 CFR 40,
Appendix A, I, Criterion 6(6), Directive No 9200-4-35P, April
li, 2000.
To be Considered
Addresses the use of the soil and structure clean-up criteria in 10 CFR 40, Appendix A,
1, Criterion 6(6} with setting remediation goals at CERCLA sites with radioactive
contamination.
t
Massachusetts DEP Hazardous Waste Regulations (310 CMR
30,000)
Relevant and
Appropriate
These regulations describe the requirements for treatment, storage, and disposal of
hazardous waste
**
Water
Massachusetts Surface Water Quality Standards (314 CMR 4.00)
Applicable
Establishes criteria to be met if dcwatcring activities require surface water discharge
t
Certification of Operators of Wastewater Treatment Facilities
(25? CMR 2.0)
Applicable
Addresses certification of wastewater treatment operators to be met if dewatering
activities require water treatment
t
Operation and Maintenance and Pretreatment Standards for
Wastewater Treatment Works and Indirect Discharges (M4
CMR 12-00)
Applicable
Addresses operations and maintenance and pretreatment standards for wastewater
treatment to be met if dewatering activities require water treatment
t
"Votes
Af>pin-dfi!o - Addrr^ics ;i Iw^rdous •.obsMtHV. polfuiant, t'onfrtininant, remedial actum iixafiim ur teller orcumMrfik*1 found .n iho sift-
Kt-|E'VHHl .ind Appropriate - N.4U Jirwtly df plwrtWt' if tho mK\ but dddryb**.'*, situations Mrruldr enough to [*• rHfv• - \on-j-»rorTuil^rtlt\1 h'di-Tal or Srtlr i fiferui. advisor)*'* or guiddnu" di> not have ARAR status K'wtnnr, tii^y m«iy U' »'t>nsi«1i-rin1 in deU'rinin.fi^ « V.inup Irvfh pmttvlno of publu UtviUh .>r lh«-on\ .ror.nlfni.
' l-\i av, h vim-* v* ill lv cond titled In flitvl tin: n-quirofivriK nt rv£uidUon«»
*" Sutisjcipilivt1 !,trull ill < iosim- roquironu'n'.s U»«rt ^ddrrs1* i kuin < losutv wiil tv met hv this .ilterrumo
~ ! \v.5!v,Ui<»i', and utlsiU1 disposal ^ ill U^nrKku K'd if; AVCf,UfU'O wUb roquir'.'nvnls
Page 3 oS 5
-------
Alternative SC-3B - Excapation/Ojf-Site Disposal (Adjacent Resident Without Groundwater Consumption)
Potential Action-Specific ARARs
Shpack Landfill Supetfund Site
Nor to it/A ttleboro, Massachusetts
Medium
Requirements
Status
Synopsis of Requirements
Meet or Attain
ARAR
FEDERAL REGULATORY REQUIREMENTS
Air
National I-mission Standards for I iazardous Air Pollutants
(NES1 lAI's) and Clean Air Act (40 CFR til, Subparts 11 and i)
Relevant and
Appropriate
Regulates air emissions of VC Ks and radionuclides
*ik*
Soil
Federal RCRA Subtitle G {40 CFR Fart 264 Subpart G - Closure
and Post Closure, Sections 264.111, 264.114, and 264,117) Clean
Closure Requirements 40 CFK 264.25S
Relevant and
Appropriate
Establishes performance standards for closure of hazardous waste piles, disposal
facilities, and groundwater monitoring.
*
Water
Clean Water Act {Section 402; NPDHS)
Applicable
Establishes criteria to be met if dewatering activities require surface water discharge
t
Groundwater
Federal Ambient Water Quality Criteria {AWyQ (CWA 303)
Relevant and
Applicable
Federal AW(_K are hea^b-baved criteria which hut-e lieen developed for certain
carcinogenic and noncaremogenie compounds.
JeHe
Federal RCRA Subtitle C Regulations, 40 CFR Part 264 Subpart
V - Releases from Solid Waste Management Units, Sections
264.i)5, 264.96(a) and (c). 264.97, 264,98 and 264 99)
Relevant and
Appropriate
Groundwater monitoring requirements and compliance points for determining the need
for additional monitoring and corrective action.
-k
**
Notes
Applicable - Addressee a hazardous substance, pollutant, conuminar.t, remedial .Ktjon, kvation or other nnumslarve found al tfw site
KeU-vani and Appropriate - Not directly applicable to the <,1 but addr^ses Mluattom similar enough to he relevant and appropriate
lo be kOn-iidrrtHi Mon-promulgated Fedora! or Stale criteria, advr.onfs or guidance dr> not have ARAR staius; however, they nwy be considered in determining«leanup levels pruhMive ol public health or t!w environment,
* Siifrsiamn'e lamifril rknurv requirements that atJdnss clean closure will be met by this alternative
** i hese criteria will be used hi determine if other acltvitit* rvnnimi?f I bo contribution ol contaminants from (be Mte 10 surface water.
**"* hiravatmn activoies will 1*-1 I'mducieri tn mu,n the reusiuvmenK ot these regulations
f Dew>sit>nn)> w ill he coruiu? led n\ accordance with these n*nuft nvnls
Page 4 of 5
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Alternative SC-3B - Excavatit>n/Off-Sile Disposal (Adjacent Resident Without Groundwater Consumption)
Potential Radiological-Specific ARARs
Shpack Landfill Superfund Site
Norton/Attleboro, Massachusetts
Medium
Requirements
Status
Synopsis of Requirements
STATE REGULATORY REQUIREMENTS
Soil/
Groundwater
Massachusetts Regulations for Control of Radiation (11)5 C M K
120)
Relevant and
Appropriate
Establishes .standards for radiation related activities-
FEDERAL REGULATORY REQUIREMENTS
Air
National Emission Standards for Hazardous Air Pollutants
(NT.Sf iAFs) and Clean Air Act (40 CFR 61, Subparts I I arid I)
Relevant and
Appropriate
Provides guidance on air emissions of radionuclides during cleanup of Federal Facilities
and licensed NKC facilities with radioactive contamination.
Groundwater
Ore Mining and Dressing Point Source Category (40 CFR 440,
Subpart C)
Relevant and
Appropriate
Regulates effluent limits from facilities that extract/process uranium, radium and
vanadium ores. Mav be applicable to discharges of radioactive waste to surface waters
Federal Water Quality Criteria (FVVQC) ami Stale Water Quality
Standard* (Water Quality Criteria, Report of the National
Technical Advisory Committee to the Secretary of the Interior,
April 1, 1«*86}
To be considered
FWQC are criteria/standards for the protection of aquatic life and/or human health.
Health and Environmental Protection for Uranium and
Thorium Tailings (40 CFR 192, Subpart A, Table 1}
Relevant and
Appropriate
Standards have l>een developed under the Uranium Mill Failings Radiation Control Act
(UMTKCA) for sites that are exempt from CFRCTA for radium/thorium m soil.
Federal Safe 1 "linking Water Act - Maximum Contaminant
Levels (MCLs) for Radiological Constituents (40 CFR 141
Subparts R, CI and 1)
Applicable, if non-
zero
MCLs have been promulgated for a number of radiological constituents. These levels
regulate the concentration of contaminants in public drinking water supplies, but may
also be considered appropriate for groundwater aquifers potentially used for drinking
•water.
Sail
Health and Environmental Protection for Uranium and
Thorium Tailings (40 Cf:R 192.12, 192 32,192.41)
Relevant and
Appropriate
Standards have been developed under the Uranium Mill Failings Radiation Control Act
(UMTRCAJ for sites that are exempt from CTRCLA for radium/thorium in soil.
Licensing Requirements for Land Disposal of Radioactive Waste
(10 CFR 61,41)
Relevant and
Appropriate
Provides performance objectives for licensed disposal sites containing low level
radioactive waste if the waste will be left permanently on site.
Notre
Applti dhk* - Addrirsscfi J tw^rdous ^ut^tdrvcf, pollutant, tunldmmjnt, rrmoiial v/mi and appropriate.
I o K> * onsidfrvd - Norvpnwuilj'Aled K-Jerdl i-r Slate-rniiTi.t, ,tdvi vines nr omd^medo noi fuivr ARAR sluus, hum-vcr, the'. mav ho forKuh-red hi determining; irleanup h-veh prottvmv ol putiu" iu.sitli or ih>j environment
sk'turn-, iinci UVcHn'ri-^HH irk AR A R tahlvs [ur a Ui^'uviKm o.t ho*. us* ^yw.i'.r K AK> me addressed, il sn .ill, by this ditorrwiiv*,'
Page 5 of
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Appendix C: Administrative Record Index
and Guidance Documents
-------
SHPACK LANDFILL
ENTIRE SITE
ADMINISTRATIVE RECORD FILE
SHPACK OU1 ROD AR
1. SITE ASSESSMENT
1. FORM : NATIONAL PRIORITIES LIST CHECKLIST OF DATA REQUIREMENTS
AUTHOR: DAVID K COOK, ECOLOGY & ENVIRONMENT INC
DOC ID: 209593 2 PAGES
2. REPORT: A BACKGROUND REPORT FOR THE FORMERLY UTILIZED
MANHATTAN ENGINEER DISTRICT/ATOMIC ENERGY COMMISSION SITES
PROGRAM [COVER PAGE AND PAGES 67-74 ONLY]
AUTHOR: US DEPT OF ENERGY
DOC ID: 205017 09/01/1980 10 PAGES
3. FORM : POTENTIAL HAZARDOUS WASTE SITE INVESTIGATION AND
PRELIMINARY ASSESSMENT
AUTHOR: DAVID K COOK, ECOLOGY & ENVIRONMENT INC
DOC ID: 205019 04/09/1982 4 PAGES
4. MEMO : POTENTIAL HAZARDOUS WASTE SITE INVESTIGATION AND
PRELIMINARY ASSESSMENT AND NATIONAL PRIORITIES CHECKLIST TO: JOHN
F HACKLER, US EPA REGION 1
AUTHOR: DAVID K COOK, ECOLOGY & ENVIRONMENT INC
DOC ID: 205018 04/20/1982 7 PAGES
5. REPORT: CHEMICAL CONTAMINATION AT THE SHPACK LANDFILL,
NORTON/ATTLEBORO, MASSACHUSETTS
AUTHOR: DAVID K COOK, ECOLOGY & ENVIRONMENT INC
DOC ID: 209596 12/06/1982 235 PAGES
6. MEMO : TRIP REPORT OF INVENTORY OF SURFACE DEBRIS
AUTHOR: GREGORY A ROSCOE, NUS/TETRA TECH INC
DOC ID: 209595 09/25/1984 4 PAGES
7. REPORT: FINAL SITE RESPONSE ASSESSMENT REPORT (SRA), SHPACK/
ATTLEBORO LANDFILL INCORPORATED, NORTON/ATTLEBORO,
MASSACHUSETTS TO: US EPA REGION 1
AUTHOR: GREGORY A ROSCOE, NUS/TETRA TECH INC
DOC ID: 209594 11/21/1985 143 PAGES
2. REMOVAL RESPONSE
1. REPORT: REPORT NO. 78-154-A, RADIOACTIVE MATERIAL IN UNCONTROLLED
LOCATION, NORTON, MA
AUTHOR: J W DEVLIN, US NUCLEAR REGULATORY COMMISSION
DOC ID: 201267 03/13/1979 1 PAGE
-------
SHPACK LANDFILL
ENTIRE SITE
ADMINISTRATIVE RECORD FILE
SHPACK OU1 ROD AR
2. REMOVAL RESPONSE (con't)
2. LETTER: TRANSMITTAL OF REGION 1 INVESTIGATION REPORT NO. 78-154-A
TO: GERALD PARKER S, MA DEPT OF PUBLIC HEALTH
AUTHOR: GEORGE SMITH, US NUCLEAR REGULATORY COMMISSION
DOC ID: 201268 06/26/1979 64 PAGES
3. REPORT: ADDITIONAL DEPARTMENT OF ENERGY (DOE) SURVEYS AND
ANALYSIS - SHPACK/ATTLEBORO FUSRAP SITE TO: BARBARA IKALAINEN, US
EPA REGION 1
AUTHOR: JAMES K ALEXANDER, US DEPT OF ENERGY
DOC ID: 209597 04/14/1982 24 PAGES
4. REPORT: RADIOLOGICAL SURVEY OF THE FORMER SHPACK LANDFILL, WITH
TRANSMITTAL TO: US DEPT OF ENERGY
AUTHOR: BECHTEL NATIONAL INC
DOC ID: 201269 03/01/1984 164 PAGES
5. REPORT: ANALYTICAL DATA PACKAGE, VOLUME 1 OF 6: VOLATILE ORGANIC
COMPOUNDS
AUTHOR: ROY F WESTON
DOC ID: 209587 09/08/1989 380 PAGES
6. REPORT: ANALYTICAL DATA PACKAGE, VOLUME 2 OF 6: SEMI-VOLATILE
ORGANIC COMPOUNDS, PART 1 OF 2
AUTHOR: ROY F WESTON
DOC ID: 209588 09/08/1989 433 PAGES
7. REPORT: ANALYTICAL DATA PACKAGE, VOLUME 3 OF 6: SEMI-VOLATILE
ORGANIC COMPOUNDS, PART 2 OF 2
AUTHOR: ROY F WESTON
DOC ID: 209589 09/08/1989 240 PAGES
8. REPORT: ANALYTICAL DATA PACKAGE, VOLUME 4 OF 6: METALS, PART 1 OF 2
AUTHOR: ROY F WESTON
DOC ID: 209590 09/08/1989 235 PAGES
9. REPORT: ANALYTICAL DATA PACKAGE, VOLUME 5 OF 6: METALS, PART 2 OF 2
AUTHOR: ROY F WESTON
DOC ID: 209591 09/08/1989 300 PAGES
10. REPORT: ANALYTICAL DATA PACKAGE, VOLUME 6 OF 6: PESTICIDES/PCBS
AND RADIOLOGICALS
AUTHOR: ROY F WESTON
DOC ID: 209592 09/08/1989 298 PAGES
-------
SHPACK LANDFILL
ENTIRE SITE
ADMINISTRATIVE RECORD FILE
SHPACK OU1 ROD AR
2. REMOVAL RESPONSE (con't)
11. REPORT: DATA VALIDATION FOR SHPACK LANDFILL DATA, TDD# 01 -8909-L1,
PCS# 0711
AUTHOR: MARTHA POIRIER, ROY F WESTON
DOC ID: 209602 11/06/1989 33 PAGES
12. MEMO : MEMORANDUM OF UNDERSTANDING (MOU) BETWEEN THE US
DEPARTMENT OF ENERGY (DOE) AND THE US ARMY CORPS OF ENGINEERS
REGARDING PROGRAM ADMINISTRATION AND EXECUTION OF THE
FORMERLY UTILIZED SITES REMEDIAL ACTION PROGRAM (FUSRAP)
AUTHOR: JAMES M OWENDOFF, US DEPT OF ENERGY
RUSSELL L FUHRMAN, US ARMY CORPS OF ENGINEERS
DOC ID: 209610 03/17/1999 12 PAGES
13. REPORT: DRAFT QUALITY ASSURANCE PROJECT PLAN, SHPACK LANDFILL
SUPERFUND SITE, GAMMA AND CIVIL SURVEYS TO: US ARMY CORPS OF
ENGINEERS - NEW ENGLAND DIVISION
AUTHOR: CABRERA SERVICES INC
DOC ID: 209601 09/08/1999 18 PAGES
14. REPORT: DRAFT SITE SAFETY AND HEALTH PLAN, SHPACK LANDFILL
SUPERFUND SITE, GAMMA AND CIVIL SURVEYS TO: US ARMY CORPS OF
ENGINEERS - NEW ENGLAND DIVISION
AUTHOR: CABRERA SERVICES INC
DOC ID: 209609 09/08/1999 158 PAGES
15. LETTER: TRANSMITTAL OF THREE DRAFT PLANS APPLICABLE TO THE SHPACK
LANDFILL SUPERFUND SITE TO: DAVID O LEDERER, US EPA REGION 1
AUTHOR: CHRISTINE WAITERS, CABRERA SERVICES INC
DOC ID: 209600 09/13/1999 1 PAGE
16. REPORT: GAMMA WALKOVER AND CIVIL SURVEY WORK PLAN TO: US ARMY
CORPS OF ENGINEERS - NEW ENGLAND DIVISION
AUTHOR: CABRERA SERVICES INC
DOC ID: 209607 12/30/1999 25 PAGES
17. REPORT: QUALITY ASSURANCE PROJECT PLAN, SHPACK LANDFILL
SUPERFUND SITE, GAMMA AND CIVIL SURVEYS TO: US ARMY CORPS OF
ENGINEERS - NEW ENGLAND DIVISION
AUTHOR: CABRERA SERVICES INC
DOC ID: 209608 12/30/1999 18 PAGES
-------
SHPACK LANDFILL
ENTIRE SITE
ADMINISTRATIVE RECORD FILE
SHPACK OU1 ROD AR
2. REMOVAL RESPONSE (con't)
18. REPORT: DRAFT SITE- SPECIFIC RADIOLOGICAL SURVEY PLAN
AUTHOR: METCALF & EDDY
DOC ID: 209622 01/01/2000 31 PAGES
19. REPORT: DRAFT GAMMA WALKOVER AND CIVIL SURVEY REPORT TO: US
ARMY CORPS OF ENGINEERS - NEW ENGLAND DIVISION
AUTHOR: CABRERA SERVICES INC
DOC ID: 201276 07/13/2000 62 PAGES
20. LETTER: REVIEW COMMENTS ON GAMMA WALKOVER AND CIVIL SURVEY
REPORT TO: DAVID O LEDERER, US EPA REGION 1
AUTHOR: EDWARD A CONROY, METCALF & EDDY
DOC ID: 209614 10/19/2000 4 PAGES
21. LETTER: COMMENTS ON GAMMA WALKOVER AND CIVIL SURVEY REPORT
DATE JULY 13,2000 TO: DAVID O LEDERER, US EPA REGION 1
AUTHOR: JAY NAPARSTEK, MA DEPT OF ENVIRONMENTAL PROTECTION
DOC ID: 209615 10/24/2000 3 PAGES
22. LETTER: TRANSMIT! AL OF COMMENTS ON SHPACK GAMMA WALKOVER AND
CIVIL SURVEY REPORT FROM BOTH METCALF AND EDDY AND
MASSACHUSETTS DEPARTMENT OF ENVIRONMENTAL PROTECTION TO:
WILLIAM TAYLOR, US ARMY CORPS OF ENGINEERS - NEW ENGLAND DIVISION
AUTHOR: DAVID O LEDERER, US EPA REGION 1
DOC ID: 209613 10/24/2000 1 PAGE
23. LETTER: COMMENTS ON THE GAMMA WALKOVER AND CIVIL SURVEY
REPORT TO: WILLIAM TAYLOR, US ARMY CORPS OF ENGINEERS - NEW
ENGLAND DIVISION
AUTHOR: HEATHER GRAF, SHPACK AD HOC COMMITTEE
DOC ID: 209611 10/26/2000 11 PAGES
24. LETTER: DRAFT GAMMA WALKOVER AND CIVIL SURVEY REPORT - RESPONSE
TO COMMENTS TO: DAVID O LEDERER, US EPA REGION 1
AUTHOR: SCOTT E ACONE, US ARMY CORPS OF ENGINEERS
DOC ID: 209616 01/19/2001 24 PAGES
25. REPORT: FINAL REPORT, GAMMA WALKOVER AND CIVIL SURVEY REPORT TO:
US ARMY CORPS OF ENGINEERS - NEW ENGLAND DIVISION
AUTHOR: CABRERA SERVICES INC
DOC ID: 201277 01/23/2001 61 PAGES
-------
SHPACK LANDFILL
ENTIRE SITE
ADMINISTRATIVE RECORD FILE
SHPACK OU1 ROD AR
2. REMOVAL RESPONSE (con't)
26. LETTER: REVIEW OF RESPONSE COMMENTS ON GAMMA WALKOVER SURVEY
TO: SCOTT E ACONE, US ARMY CORPS OF ENGINEERS
AUTHOR: DAVID O LEDERER, US EPA REGION 1
DOC ID: 209612 03/01/2001 4 PAGES
27. REPORT: FINAL QUALITY ASSURANCE PROJECT PLAN, FOCUSED SITE
INSPECTION: CHARACTERIZATION SURVEYS FOR RADIOLOGICAL
CONTAMINANTS OF CONCERN TO: US ARMY CORPS OF ENGINEERS - NEW
ENGLAND DIVISION
AUTHOR: CABRERA SERVICES INC
DOC ID: 209605 02/22/2002 284 PAGES
28. REPORT: FINAL SAMPLING AND ANALYSIS PLAN, FOCUSED SITE INSPECTION:
CHARACTERIZATION SURVEYS FOR RADIOLOGICAL CONTAMINANTS OF
CONCERN [PART 2 OF 2]
AUTHOR: CABRERA SERVICES INC
DOC ID: 201564 02/22/2002 455 PAGES
29. REPORT: FINAL SAMPLING AND ANALYSIS PLAN, FOCUSED SITE INSPECTION:
CHARACTERIZATION SURVEYS FOR RADIOLOGICAL CONTAMINANTS OF
CONCERN [PART 1 OF 2] TO: US ARMY CORPS OF ENGINEERS - NEW ENGLAND
DIVISION
AUTHOR: CABRERA SERVICES INC
DOC ID: 209604 02/22/2002 759 PAGES
30. MAP : WETLANDS DELINEATION SUMMER 2002 TO: US ARMY CORPS OF
ENGINEERS - NEW ENGLAND DIVISION
AUTHOR: CABRERA SERVICES INC
DOC ID: 209603 01/06/2003
31. REPORT: FINAL LETTER REPORT, FOCUSED SITE INSPECTION:
CHARACTERIZATION SURVEYS FOR RADIOLOGICAL CONTAMINANTS OF
CONCERN TO: US ARMY CORPS OF ENGINEERS - NEW ENGLAND DIVISION
AUTHOR: CABRERA SERVICES INC
DOC ID: 205015 04/01/2003 42 PAGES
32. REPORT: FINAL LETTER REPORT, FOCUSED SITE INSPECTION:
CHARACTERIZATION SURVEYS FOR RADIOLOGICAL CONTAMINANTS OF
CONCERN, APPENDICES TO: US ARMY CORPS OF ENGINEERS - NEW ENGLAND
DIVISION
AUTHOR: CABRERA SERVICES INC
DOC ID: 205016 04/01/2003 496 PAGES
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SHPACK LANDFILL
ENTIRE SITE
ADMINISTRATIVE RECORD FILE
SHPACK OU1 ROD AR
2. REMOVAL RESPONSE (con't)
33. REPORT: DRAFT ENGINEERING EVALUATION AND COST ANALYSIS (EE/CA),
SHPACK FUSRAP SUPERFUND LANDFILL TO: US ARMY CORPS OF ENGINEERS
AUTHOR: ERM-NEW ENGLAND
DOC ID: 65214 02/01/2004 1 PAGE
3. REMEDIAL INVESTIGATION (RI)
1. FORM : REGIONAL REVIEW OF UNCONTROLLED HAZARDOUS WASTE SITE
CONTRACT LABORATORY DATA PACKAGE
AUTHOR: US EPA REGION 1
DOC ID: 209647 22 PAGES
2. REPORT: INTERPRETIVE REPORT OF RESULTS OF GROUNDWATER SURVEY OF
THE ATTLEBORO LANDFILL CONDUCTED 04/07/86, 04/08/86 & 04/10/86.
DOC ID: 11774 5 PAGES
3. REPORT: INTERPRETIVE REPORT OF RESULTS OF GROUNDWATER SURVEY OF
THE ATTLEBORO LANDFILL CONDUCTED 12/10/85 & 12/11/85 [A 02/11/86 COVER
LETTER AND A 04/02/86 COVER SHEET ARE ATTACHED]
DOC ID: 11773 42 PAGES
4. REPORT: INTERPRETIVE REPORT OF RESULTS OF THE 03/24/87 GROUNDWATER
SURVEY [A 05/22/87 REPORT IS ATTACHED]
DOC ID: 11739 58 PAGES
5. REPORT: REPORT ON RESULTS OF ANALYSIS OF TEST WELL WATER AT
ATTLEBORO LANDFILL SITE
DOC ID: 209618 12 PAGES
6. SAMPLING & ANALYSIS DATA: WASTE WATER ANALYSIS AUTHOR: MA DEPT
OF ENVIRONMENTAL QUALITY ENGINEERING
DOC ID: 209621 11/20/1978 25 PAGES
7. REPORT: REPORT ON RADIATION SURVEY ON PREMISES OF ATTLEBORO
LANDFILL COMPANY AUTHOR: DOUGLAS R SHEARER
DOC ID: 209619 02/05/1980 6 PAGES
8. REPORT: REPORT - EVALUATION OF ATTLEBORO LANDFILL MONITORING TO:
ATTLEBORO LANDFILL INC
AUTHOR: GHR ENGINEERING CORP
DOC ID: 209649 03/25/1980 87 PAGES
-------
SHPACK LANDFILL
ENTIRE SITE
ADMINISTRATIVE RECORD FILE
SHPACK OU1 ROD AR
3. REMEDIAL INVESTIGATION (RI) (cont)
9. REPORT: RADIOLOGICAL CHARACTERIZATION OF THE SHPACK LANDFILL.
NORTON, MA, SURVEY PLAN
DOC ID: 209617 04/01/1982 21 PAGES
10. SAMPLING & ANALYSIS DATA: SHPACK DUMP, CASE#01260, JTC
ENVIRONMENTAL CONSULTANTS, SAMPLING DATES: 09/20/82 - 09/20/82
AUTHOR: JTC ENVIRONMENTAL CONSULTANTS
DOC ID: 209688 09/20/1982 143 PAGES
11. SAMPLING & ANALYSIS DATA: SHPACK DUMP, CASE# 01318, COMPUCHEM
LABS, SAMPLING DATES: 09/20/82 - 09/20/82
AUTHOR: ED TAYLOR, NUS CORP SUPERFUND DIVISION
DOC ID: 209687 09/20/1982 61 PAGES
12. SAMPLING & ANALYSIS DATA: SHPACK DUMP, CASE#01318, JTC
ENVIRONMENTAL CONSULTANTS, SAMPLING DATES: 09/20/82 - 09/20/82
AUTHOR: JTC ENVIRONMENTAL CONSULTANTS
DOC ID: 209689 09/20/1982 235 PAGES
13. LETTER: SUMMARY OF PRE-1990 RESIDENTIAL WELL SAMPLING
TO: DOROTHY FREEMAN, NORTON (MA) TOWN OF
AUTHOR: JOHN F HACKLER, US EPA REGION 1
DOC ID: 209663 11/18/1982 10PAGES
14. REPORT: REMEDIAL ACTION MASTER PLAN SECTION 1, DATA COMPILATION
AND EVALUATION
TO: US EPA REGION 1
AUTHOR: CAMP DRESSER & MCKEE INC
DOC ID: 200408 02/08/1983 19 PAGES
15. SAMPLING & ANALYSIS DATA: GROUNDWATER MONITORING ANALYTICAL
RESULTS
TO: GREG HUNT, DEQE SOUTHEAST REGION JAMES MOONEY, ATTLEBORO
BOARD OF HEALTH
AUTHOR: ROBERT S CUMMINGS, GHR ENGINEERING CORP
DOC ID: 11766 03/23/1984 39 PAGES
16. SAMPLING & ANALYSIS DATA: SET OF ANALYTICAL RESULTS
TO: GREG HUNT, DEQE SOUTHEAST REGION JAMES MOONEY, ATTLEBORO
BOARD OF HEALTH
AUTHOR: ROBERT S CUMMINGS, GHR ENGINEERING CORP
DOC ID: 209620 03/23/1984 39 PAGES
-------
SHPACK LANDFILL
ENTIRE SITE
ADMINISTRATIVE RECORD FILE
SHPACK OU1 ROD AR
3. REMEDIAL INVESTIGATION (RI) (cont)
17. MEMO : SHPACK INORGANIC DATA VALIDATION
TO: ED TAYLOR, NUS CORP SUPERFUND DIVISION
AUTHOR: HANS-PETER KRAHN, NUS CORP SUPERFUND DIVISION
DOC ID: 209677 07/27/1984 34 PAGES
18. MEMO : SHPACK ORGANIC DATA VALIDATION
TO: ED TAYLOR, NUS CORP SUPERFUND DIVISION
AUTHOR: HANS-PETER KRAHN, NUS CORP SUPERFUND DIVISION
DOC ID: 209646 07/30/1984 34 PAGES
19. REPORT: RESULTS ON GROUNDWATER QUALITY IN THE VICINITY OF THE
ATTLEBORO SANITARY LANDFILL TO: GHR ENGINEERING CORP
AUTHOR: GHR ANALYTICAL INC
DOC ID: 11768 05/17/1985 50 PAGES
20. REPORT: GHR LABORATORY REPORTS ON GROUNDWATER MONITORING AT
ATTLEBORO LANDFILL
TO: DIANE DRUYETIS, MA DEPT OF ENVIRONMENTAL PROTECTION
AUTHOR: LEANNE E S COBB, GHR ANALYTICAL INC
DOC ID: 200410 02/11/1986 42 PAGES
21. REPORT: REVIEW OF ATTLEBORO LANDFILL FINAL ENVIRONMENTAL IMPACT
REPORT
TO: MA DEPT OF ENVIRONMENTAL PROTECTION
AUTHOR: JOE HARTLEY
DOC ID: 200413 03/19/1986 3 PAGES
22. REPORT: INTERPRETIVE REPORT OF 04/86, GROUNDWATER SAMPLING ROUND
[A 07/17/86 COVER SHEET IS ATTACHED]
AUTHOR: GHR ANALYTICAL INC
DOC ID: 11736 05/16/1986 58 PAGES
23. REPORT: INTERPRETIVE REPORT OF OCTOBER 21,1986 GROUND WATER
SAMPLING ROUND
TO: MA DEPT OF ENVIRONMENTAL PROTECTION
AUTHOR: LEANNE E S COBB, GHR ANALYTICAL INC
DOC ID: 200412 12/16/1986 46 PAGES
24. REPORT: LETTER REPORT, SHPACK RESIDENTIAL WELL SAMPLING PROGRAM,
1st SAMPLING ROUND
TO: MA DEPT OF ENVIRONMENTAL QUALITY ENGINEERING
AUTHOR: WEHRAN ENGINEERING CORP
DOC ID: 209645 03/01/1987 66 PAGES
-------
SHPACK LANDFILL
ENTIRE SITE
ADMINISTRATIVE RECORD FILE
SHPACK OU1 ROD AR
3. REMEDIAL INVESTIGATION (RI) (cont)
25. LETTER: RESIDENTIAL WELL STUDY RESULTS
AUTHOR: CHRISTOPHER TILDEN, MA DEPT OF ENVIRONMENTAL PROTECTION
DOC ID: 200415 04/21/1987 9 PAGES
26. LETTER: RESIDENTIAL WELL STUDY RESULTS
TO: NORTON (MA) RESIDENT AUTHOR: CHRISTOPHER TILDEN, MA DEPT OF
ENVIRONMENTAL PROTECTION
DOC ID: 200414 04/22/1987 7 PAGES
27. REPORT: ANALYSIS OF WATER SAMPLES FROM SHPACK LANDFILL
TO: PETER CROTEAU, WEHRAN ENGINEERING CORP
AUTHOR. ERT
DOC ID: 209643 04/28/1987 69 PAGES
28. LETTER: ANALYSIS OF RESIDENTIAL WELL SAMPLING PROGRAM SECOND
SAMPLING EVENT [RELATED DOCUMENTS ARE ATTACHED]
TO: HELEN WALDORF, MA DEPT OF ENVIRONMENTAL PROTECTION
AUTHOR: KEVIN M BURGER, WEHRAN ENGINEERING CORP
PETER CROTEAU, WEHRAN ENGINEERING CORP
DOC ID: 11747 05/20/1987 10 PAGES
29. REPORT: INTERPRETIVE REPORT OF THE MARCH 24, 1987 GROUNDWATER
SURVEY OF THE ATTLEBORO LANDFILL
DOC ID: 209644 07/22/1987 58 PAGES
30. LETTER: SHPACK RESIDENTIAL WELL SAMPLING PROGRAM, FOURTH SAMPLE
EVENT - ANALYTICAL RESULTS
TO: HELEN WALDORF, MA DEPT OF ENVIRONMENTAL PROTECTION
AUTHOR: KEVIN M BURGER, WEHRAN ENGINEERING CORP
PETER CROTEAU, WEHRAN ENGINEERING CORP
DOC ID: 209641 11/23/1987 48 PAGES
31. REPORT: PRELIMINARY HEALTH ASSESSMENT FOR SHPACK LANDFILL
AUTHOR: AGENCY FOR TOXIC SUBSTANCES AND DISEASE REGISTRY (ATSDR)
DOC ID: 201271 04/18/1989 7 PAGES
32. REPORT: SHPACK LANDFILL SITE RESIDENTIAL WELL ANALYSIS
DOC ID: 209675 10/01/1989 92 PAGES
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SHPACK LANDFILL
ENTIRE SITE
ADMINISTRATIVE RECORD FILE
SHPACK OU1 ROD AR
3. REMEDIAL INVESTIGATION (RI) (cont)
33. SAMPLING & ANALYSIS DATA: DRINKING WATER PURGEABLE ORGANIC
ANALYSIS
TO: CAROL B GOLDSBERRY, US EPA REGION 1
AUTHOR: MARY JANE CUZZUPE, US EPA REGION 1
SCOTT CLIFFORD, US EPA REGION 1
DOC ID: 11754 10/24/1989 27 PAGES
34. MEMO : ANALYSIS OF PESTICIDES AND PCB'S IN WATER - SHPACK LANDFILL
TO: CAROL B GOLDSBERRY, US EPA REGION 1
AUTHOR: DELON MA AS, US EPA REGION 1
HUI WANG, US EPA REGION 1
RICHARD SISCANAW, US EPA REGION 1
DOC ID: 209638 11/01/1989
35. SAMPLING & ANALYSIS DATA: ANALYSIS OF PESTICIDES AND PCBS IN WATER
TO: CAROL B GOLDSBERRY, US EPA REGION 1
AUTHOR: DELON MAAS, US EPA REGION 1
HUI WANG, US EPA REGION 1
RICHARD SISCANAW, US EPA REGION 1
DOC ID: 11756 11/01/1989 13 PAGES
36. SAMPLING & ANALYSIS DATA: GAS CHROMOTOGRAPHY- MASS
SPECTROMETRY ANALYSIS OF EXTRACTABLE ORGANICS IN MUNICIPAL AND
INDUSTRIAL DISCHARGES
TO: CAROL B GOLDSBERRY, US EPA REGION I
AUTHOR: JOSEPH MONTANARO, US EPA REGION 1
NATHAN RAINES, US EPA REGION 1
RICHARD SISCANAW, US EPA REGION 1
SURESH SRIVASTAVA, US EPA REGION 1
DOC ID: 11758 11/22/1989 39 PAGES
37. MEMO : EVALUATION OF RESIDENTIAL WELL SAMPLES, SHPACK LANDFILL
TO: CAROL B GOLDSBERRY, US EPA REGION 1
AUTHOR: LOUISE A HOUSE, US PUBLIC HEALTH SERVICE/AT SDR
DOC ID: 201272 02/07/1990 2 PAGES
38. LETTER: REQUEST FOR EXTENSION OF WORK PLAN SUBMISSION DATE
TO: RICHARD T LEIGHTON, US EPA REGION 1
AUTHOR: PETER SPAWN, ALLIANCE TECHNOLOGIES CORP
DOC ID: 209632 12/11/990 3 PAGES
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3. REMEDIAL INVESTIGATION (RI) (cont)
39. LETTER: TRANSMITTAL OF REMEDIAL INVESTIGATION/FEASIBILITY STUDY
(RI/FS) OVERSIGHT WORKPLAN
TO: RICHARD T LEIGHTON, US EPA REGION 1
AUTHOR: PETER SPAWN, ALLIANCE TECHNOLOGIES CORP
DOC ID: 209631 01/04/1991 2 PAGES
40. REPORT: REMEDIAL INVESTIGATION AND FEASIBILITY STUDY, VOLUME 1 OF
3
TO: SHPACK STEERING COMMITTEE
AUTHOR: ERM-NEW ENGLAND INC
DOC ID: 200474 01/28/1991 405 PAGES
41. REPORT: REMEDIAL INVESTIGATION AND FEASIBILITY STUDY, VOLUME 2 OF
3
TO: SHPACK STEERING COMMITTEE
AUTHOR: ERM-NEW ENGLAND INC
DOC ID: 200475 01/28/1991 212 PAGES
42. REPORT: REMEDIAL INVESTIGATION AND FEASIBILITY STUDY, VOLUME 3 OF
3
TO: SHPACK STEERING COMMITTEE
AUTHOR: ERM-NEW ENGLAND INC
DOC ID: 200476 01/28/1991 491 PAGES
43. MEMO : COMMENTS REGARDING REVIEW OF THE WORK PLAN FOR REMEDIAL
INVESTIGATION/FEASIBILITY STUDY (RI/FS) OVERSIGHT
TO: NADINE RANIERE, US EPA REGION 1
AUTHOR: PAMELA SHIELDS, US EPA REGION 1
DOC ID: 11619 01/29/1991 2 PAGES
44. MEMO : SHPACK WORK PLAN SCOPING MEETING - DECEMBER 10, 1990 AND
JANUARY 4, 1991
AUTHOR: PAMELA SHIELDS, US EPA REGION 1
DOC ID: 209628 02/03/1991 6 PAGES
45. LETTER: REVIEW OF WORK PLAN FOR SHPACK LANDFILL
TO: PAMELA SHIELDS, US EPA REGION 1
AUTHOR: STEVEN E MIERZYKOWSKI, US DOI/US FISH & WILDLIFE SERVICE
DOC ID: 200439 02/21/1991 2 PAGES
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3. REMEDIAL INVESTIGATION (RI) (cont)
46. LETTER: RESPONSE TO COMMENTS ON DRAFT WORK PLAN FOR THE
REMEDIAL INVESTIGATION/FEASIBILITY STUDY (RI/FS)
TO: TERESA REC, MA DEPT OF ENVIRONMENTAL PROTECTION
AUTHOR: PAMELA SHIELDS, US EPA REGION 1
DOC ID: 209625 04/24/1991 7 PAGES
47. LETTER: SHPACK DRAFT HEALTH AND ENDANGERMENT ASSESSMENT WORK
PLAN - CONDITIONAL APPROVAL
TO: JOANNA HALL, ALLIANCE TECHNOLOGIES CORP
AUTHOR: PAMELA SHIELDS, US EPA REGION 1
DOC ID: 209626 05/14/1991 3 PAGES
48. LETTER: CONDITIONAL APPROVAL OF TASKS 8-11 OF REVISED WORK PLAN
FOR THE REMEDIAL INVESTIGATION/FEASIBILITY STUDY (RI/FS)
TO: FRANCIS J VEALE, SHPACK STEERING COMMITTEE
AUTHOR: RICHARD A CAVAGNERO, US EPA REGION I
DOC ID: 209624 07/11/1991 2 PAGES
49. MEMO : TRANSMITTAL OF SITE HEALTH AND SAFETY PLAN FOR SHPACK
LANDFILL TO: PAMELA SHIELDS, US EPA REGION 1
AUTHOR: EILEEN HAHNEN, US EPA REGION 1
DOC ID: 209630 08/01/1991 1 PAGE
50. REPORT: WORK PLAN SUPPLEMENT FOR REMEDIAL INVESTIGATION TO:
SHPACK STEERING COMMITTEE
AUTHOR: ERM-NEW ENGLAND INC
DOC ID: 209623 09/03/1991 240 PAGES
51. LETTER: COMMENTS ON REVISED REMEDIAL INVESTIGATION/FEASIBILITY
STUDY (RI/FS) WORK PLAN
TO: FRANCIS J VEALE, SHPACK STEERING COMMITTEE
AUTHOR: US EPA REGION 1
DOC ID: 209629 09/30/1991 23 PAGES
52. LETTER: ERM'S RESPONSE TO SPECIFIC EPA COMMENTS FROM EPA'S
SEPTEMBER 30, 1991 CORRESPONDENCE
TO: DAVID O LEDERER, US EPA REGION 1
AUTHOR: DUANE A WANTY, ERM NEW ENGLAND INC
ROBERT J FOXEN, ERM NEW ENGLAND INC
DOC ID: 200404 11/15/1991 44 PAGES
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3. REMEDIAL INVESTIGATION (RI) (cont)
53. WORK PLAN: WORK PLAN FOR THE REMEDIAL INVESTIGATION AND
FEASIBILITY STUDY (RI/FS), VOLUME 1
TO: SHPACK STEERING COMMITTEE
AUTHOR: ERM NEW ENGLAND INC
DOC ID: 200407 11/15/1991 632 PAGES
54. REPORT: OVERSIGHT TRIP REPORT FOR THE PERIOD JULY 31 TO AUGUST 22,
1991
TO: US EPA REGION I
AUTHOR: ALLIANCE TECHNOLOGIES CORP
DOC ID: 201278 11/25/1991 72 PAGES
55. REPORT: SHPACK LANDFILL SUPERFUND SITE, LABORATORY QUALITY
ASSURANCE PROJECT PLANS (QAPPS) - VOLUME 1 OF 2
AUTHOR. ERM-NEW ENGLAND INC
DOC ID: 209685 02/28/1992 324 PAGES
56. REPORT: SHPACK LANDFILL SUPERFUND SITE, LABORATORY QUALITY
ASSURANCE PROJECT PLANS (QAPPS) - VOLUME 2 OF 2
AUTHOR: ERM-NEW ENGLAND INC
DOC ID: 209686 02/28/1992 525 PAGES
57. WORK PLAN: INITIAL SITE CHARACTERIZATION WORK PLAN
TO: SHPACK STEERING COMMITTEE
AUTHOR: ERM NEW ENGLAND INC
DOC ID: 201279 06/29/1992 51 PAGES
58. REPORT: RESIDENTIAL WELL SAMPLING PLAN, ADDENDUM TO 15 NOVEMBER
1991 SHPACK LANDFILL WORK PLANS
AUTHOR: ERM-NEW ENGLAND INC
DOC ID: 209637 07/31/1992 22 PAGES
59. WORK PLAN: REMEDIAL INVESTIGATION/FEASABILITY STUDY (RI/FS)
OVERSIGHT WORK PLAN/QUALITY ASSURANCE PROJECT PLAN (QAPP)
COMPLIANCE OVERSIGHT
TO: US EPA REGION 1
AUTHOR: TRC ENVIRONMENTAL CORP
DOC ID: 201283 09/30/1992 174 PAGES
60. REPORT: CONDITION OF DOE MONITORING WELLS AT SHPACK LANDFILL
TO: DAVID O LEDERER, US EPA REGION 1
AUTHOR: ANN MARIE PETRICCA, ERM NEW ENGLAND INC
DUANE A WANTY, ERM NEW ENGLAND INC
DOC ID: 200409 10/20/1992 31 PAGES
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3. REMEDIAL INVESTIGATION (RI) (cont)
61. REPORT: FIELD ACTIVITY REPORT NO. 1
TO: US EPA REGION 1
AUTHOR: TRC ENVIRONMENTAL CORP
DOC ID: 201284 11/17/1992 70 PAGES
62. REPORT: FIELD ACTIVITY REPORT NO. 2
TO: US EPA REGION 1
AUTHOR: TRC ENVIRONMENTAL CORP
DOC ID: 201285 11/18/1992 23 PAGES
63. REPORT: FIELD ACTIVITY REPORT NO. 3
TO: US EPA REGION 1
AUTHOR: TRC ENVIRONMENTAL CORP
DOC ID: 201286 11/18/1992 36 PAGES
64. REPORT: FIELD ACTIVITY REPORT NO. 4
TO: US EPA REGION 1
AUTHOR: TRC ENVIRONMENTAL CORP
DOC ID: 201287 11/25/1992 16 PAGES
65. LETTER: DATA VALIDATION REPORT, SHPACK LANDFILL REMEDIAL
INVESTIGATION/FEASIBILITY STUDY (RI/FS) COMPLIANCE OVERSIGHT,
VOLATILES: 3 WATER; 1 SOIL, SEMIVOLATILES: 2 WATER; 1 SOIL, PESTICIDE/
PCB: 2 WATER; 1 SOIL
TO: MARGARET LESHEN, US EPA REGION 1
AUTHOR: WILLIAM J FARING, TRC COMPANIES INC
DOC ID: 209679 12/21/1992 48 PAGES
66. LETTER: DATA VALIDATION REPORT, SHPACK LANDFILL REMEDIAL
INVESTIGATION/FEASIBILITY STUDY (RI/FS) COMPLIANCE OVERSIGHT,
METALS AND CYANIDE: 1 SOIL
TO: MARGARET LESHEN, US EPA REGION 1
AUTHOR: WILLIAM J FARINO, TRC COMPANIES INC
DOC ID: 209680 01/05/1993 36 PAGES
67. LETTER: DATA VALIDATION REPORT, SHPACK LANDFILL REMEDIAL
INVESTIGATION/FEASIBILITY STUDY (RI/FS) COMPLIANCE OVERSIGHT,
METALS AND CYANIDE: 1 SOIL; 1 AQUEOUS
TO: MARGARET LESHEN, US EPA REGION 1
AUTHOR: WILLIAM J FARING, TRC COMPANIES INC
DOC ID: 209682 01/05/1993 45 PAGES
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3. REMEDIAL INVESTIGATION (RI) (cont)
68. LETTER: DATA VALIDATION REPORT, SHPACK LANDFILL REMEDIAL
INVESTIGATION/FEASIBILITY STUDY (RI/FS) COMPLIANCE OVERSIGHT,
METALS AND CYANIDE: 2 AQUEOUS
TO: MARGARET LESHEN, US EPA REGION 1
AUTHOR: WILLIAM J FARING, TRC COMPANIES INC
DOC ID: 209681 01/05/1993 36 PAGES
69. LETTER: DATA VALIDATION REPORT, SHPACK LANDFILL REMEDIAL
INVESTIGATION/FEASIBILITY STUDY (RI/FS) COMPLIANCE OVERSIGHT,
VOLATILES: 1 WATER/1 SOIL, SEMIVOLATILES: 1 WATER/1 SOIL, PESTICIDE: 1
WATER/1 SOIL
TO: MARGARET LESHEN, US EPA REGION 1
AUTHOR: WILLIAM J FARING, TRC COMPANIES INC
DOC ID: 209683 01/05/1993 43 PAGES
70. LETTER: DATA VALIDATION REPORT, SHPACK LANDFILL REMEDIAL
INVESTIGATION/FEASIBILITY STUDY (RI/FS) COMPLIANCE OVERSIGHT,
VOLATILES: 2 WATER, SEMIVOLATILES: I WATER, PESTICIDE/PCB: 1 WATER
TO: MARGARET LESHEN, US EPA REGION 1
AUTHOR: WILLIAM J FARING, TRC COMPANIES INC
DOC ID: 209684 01/13/1993 71 PAGES
71. REPORT: INITIAL SITE CHARACTERIZATION REPORT, VOLUME 1 OF 3, [PART 1
OF 2, TEXT AND TABLES]
TO: SHPACK STEERING COMMITTEE
AUTHOR: ENVIRONMENTAL RESOURCES MANAGEMENT
DOC ID: 200425 03/17/1993 303 PAGES
72. REPORT: INITIAL SITE CHARACTERIZATION REPORT, VOLUME 1 OF 3, [PART 2
OF 2, FIGURES] AND VOLUME 2 OF 3, [PART 1 OF 2, APPENDICES A-E]
TO: SHPACK STEERING COMMITTEE
AUTHOR: ERM-NEW ENGLAND INC
DOC ID: 200481 03/17/1993 351 PAGES
73. REPORT: INITIAL SITE CHARACTERIZATION REPORT, VOLUME 2 OF 3, [PART 2
OF 2, APPENDICES F & G]
AUTHOR: ERM-NEW ENGLAND INC
DOC ID: 200482 03/17/1993 257 PAGES
74. REPORT: INITIAL SITE CHARACTERIZATION REPORT, VOLUME 3 OF 3 [PART 1
OF 2, APPENDICES H & I]
AUTHOR: ERM-NEW ENGLAND INC
DOC ID: 200483 03/17/1993 278 PAGES
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3. REMEDIAL INVESTIGATION (RI) (cont)
75. REPORT: INITIAL SITE CHARACTERIZATION REPORT, VOLUME 3 OF 3 [PART 2
OF 2, APPENDICES I (CONTINUED), J & K]
AUTHOR: ERM-NEW ENGLAND INC
DOC ID: 200484 03/17/1993 237 PAGES
76. MEMO : REVIEW OF INITIAL SITE CHARACTERIZATION REPORT
TO: ANDREW RAUBVOGEL, US EPA REGION 1
JAMES CHERNIACK, US EPA REGION 1
JUI YU HSIEH, US EPA REGION 1
ROSE TOSCANO, US EPA REGION 1
SUSAN SVIRSKY, US EPA REGION 1
AUTHOR: DAVID O LEDERER, US EPA REGION 1
DOC ID: 201280 03/19/1993 1 PAGE
77. LETTER: CORRECTION OF VOLATILE ORGANIC ANALYSIS RESULTS
TO: DAVID O LEDERER, US EPA REGION 1
AUTHOR: DUANE A WANTY, ERM NEW ENGLAND INC
PHILIP J DOHERTY, ERM NEW ENGLAND INC
DOC ID: 201282 03/25/1993 8 PAGES
78. MEMO : REVIEW OF INITIAL SITE CHARACTERIZATION REPORT,
CLARIFICATION LETTER FROM PRPS
TO: ANDREW RAUBVOGEL, US EPA REGION 1
DANIEL P FENNO, TRC COMPANIES INC
DAVID BUCKLEY, MA DEPT OF ENVIRONMENTAL PROTECTION
JAMES CHERNIACK, US EPA REGION 1
JUI YU HSIEH, US EPA REGION 1
ROSE TOSCANO, US EPA REGION 1
SUSAN SVIRSKY, US EPA REGION 1
AUTHOR: DAVID O LEDERER, US EPA REGION 1
DOC ID: 201281 03/26/1993 1 PAGE
79. REPORT: SUBMITTAL OF PHASE IB WORK PLANS FOR THE SHPACK LANDFILL
TO: US EPA REGION 1
AUTHOR: ANN MARIE PETRICCA, ERM NEW ENGLAND INC
DUANE A WANTY, ERM NEW ENGLAND INC
ROBERT J FOXEN, ERM NEW ENGLAND INC
DOC ID: 201288 10/08/1993 12 PAGES
80. WORK PLAN: PHASE IB WORK PLAN INSERTS FOR REMEDIAL INVESTIGATION
AND FEASIBILITY STUDIES
AUTHOR: ERM NEW ENGLAND INC
DOC ID: 201289 10/08/1993 56 PAGES
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3. REMEDIAL INVESTIGATION (RI) (cont)
81. WORK PLAN: ARCS WORK PLAN FOR REMEDIAL INVESTIGATION/FEASIBILITY
STUDY (RI/FS)
TO: US EPA REGION 1
AUTHOR: TRC ENVIRONMENTAL CORP
DOC ID: 201290 01/05/1994 16 PAGES
82. LETTER: SUMMARY OF ANALYTICAL RESULTS AT RESIDENTIAL PROPERTIES
TO: FRANCIS J VEALE, SHPACK STEERING COMMITTEE
AUTHOR: JOE SZLACHCIUK, TEXAS INSTRUMENTS INC
DOC ID: 209678 04/15/1997 39 PAGES
83. LETTER: REQUEST FOR LIST OF PROPOSED HOMES FOR RESIDENTIAL WELL
SAMPLING
TO: FRANCIS J VEALE JR, TEXAS INSTRUMENTS INC
AUTHOR: DAVID O LEDERER, US EPA REGION 1
DOC ID: 209669 01/13/2000 1 PAGE
84. LETTER: RESIDENTIAL WELL SAMPLING
TO: FRANCIS J VEALE JR, TEXAS INSTRUMENTS INC
AUTHOR: STEVEN P SACCO, ENVIRONMENTAL RESOURCES MANAGEMENT
DOC ID: 209667 01/26/2000 6 PAGES
85. LETTER: LIST OF ALL BUILDINGS WITHIN 1 MILE OF SHPACK LANDFILL
WITHOUT MUNICIPAL WATER
TO: JOE SZLACHCIUK, TEXAS INSTRUMENTS INC
AUTHOR: ROBERT A CURRY, NORTON (MA) TOWN OF
DOC ID: 209668 02/14/2000 1 PAGE
86. MEMO : REVIEW COMMENTS ON: FIELD SAMPLING WORK PLAN- RESIDENTIAL
WELLS, REVISION 5
DOC ID: 209670 02/24/2000 1 PAGE
87. WORK PLAN: QUALITY MANUAL, RADIOCHEMISTRY AND URANIUM
LABORATORIES, WITH TRANSMITTAL
TO: DAVE LEDERERE, EPA REGION 1
AUTHOR: HAZEN RESEARCH, INC
DOC ID: 200418 03/08/2000 87 PAGES
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3. REMEDIAL INVESTIGATION (RI) (cont)
88. MEMO : PROPOSED RESIDENTIAL WELL SAMPLING
TO: BOB CURRY, NORTON (MA) TOWN OF
FRANCIS J VEALE, TEXAS INSTRUMENTS INC
JAMES MOONEY, ATTLEBORO BOARD OF HEALTH
JOE SZLACHCIUK, TEXAS INSTRUMENTS INC
PETER F KUDARAUSKAS, US EPA REGION 1
AUTHOR: DAVID O LEDERER, US EPA REGION 1
DOC ID: 209665 04/27/2000 4 PAGES
89. LETTER: RESULTS OF GROSS ALPHA AND GROSS BETA TESTING ON WATER
SAMPLES
TO: WILLIAM J ANDRADE, US EPA REGION 1
AUTHOR: CHERYL BAKER, ME DEPT OF HUMAN SERVICES
DOC ID: 209673 06/02/2000 71 PAGES
90. LETTER: ANALYTICAL RESULTS FROM MAY 2 AND 3, 2000 RESIDENTIAL WELL
SAMPLING IN THE VICINITY OF THE SHPACK LANDFILL SUPERFUND SITE
TO: DAVID O LEDERER, US EPA REGION 1
AUTHOR: PETER F KUDARAUSKAS, US EPA REGION 1
DOC ID: 209674 06/06/2000 22 PAGES
91. MEMO : ANALYTICAL RESULTS FROM MAY 2 AND 3, 2000 RESIDENTIAL WELL
SAMPLING IN THE VICINITY OF THE SHPACK LANDFILL SUPERFUND SITE
[WITH TRANSMITTAL AND MARGINALIA]
TO: DAVID O LEDERER, US EPA REGION 1
AUTHOR: PETER F KUDARAUSKAS, US EPA REGION 1
DOC ID: 209664 06/06/2000 23 PAGES
92. LETTER: RESULTS OF RESIDENTIAL WELL SAMPLING
AUTHOR: DAVID O LEDERER, US EPA REGION 1
DOC ID: 209672 06/12/2000 52 PAGES
93. MAP : MAPS RELATED TO RESIDENTIAL WELL SAMPLING
AUTHOR: TEXAS INSTRUMENTS INC
DOC ID: 209671 10/10/2000 8 PAGES
94. MAP : PROPOSED WELL SAMPLING 2001
AUTHOR: JOE SZLACHCIUK, TEXAS INSTRUMENTS INC
MIKE MILLER, TEXAS INSTRUMENTS INC
DOC ID: 209666 12/18/2000 1 PAGE
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3. REMEDIAL INVESTIGATION (RI) (cont)
95. LETTER: RESIDENTIAL WELL SAMPLING PLAN FOR REVIEW
TO: DAVID O LEDERER, US EPA REGION 1
AUTHOR: STEVEN P SACCO, ENVIRONMENTAL RESOURCES MANAGEMENT
DOC ID: 200416 02/28/2001 1 PAGE
96. WORK PLAN: RESIDENTIAL WELL SAMPLING PLAN
AUTHOR: ENVIRONMENTAL RESOURCES MANAGEMENT
DOC ID: 200417 02/28/2001 210 PAGES
97. LETTER: DISCUSSION OF RESIDENTIAL WELL SAMPLING FOR 2001
TO: BOB CURRY, NORTON (MA) TOWN OF
AUTHOR: DAVID O LEDERER, US EPA REGION 1
DOC ID: 209662 03/16/2001 2 PAGES
98. LETTER: REQUIREMENT OF THE RESIDENTIAL WELL SAMPLING PLAN
TO: JAMES OCCHIALINI, ALPHA ANALYTICAL LABS
AUTHOR: STEVEN P SACCO, ENVIRONMENTAL RESOURCES MANAGEMENT
DOC ID: 200419 04/17/2001 2 PAGES
99. SAMPLING & ANALYSIS DATA: SHPACK - SURFACE WATER, COPY OF DATA
SENT TO LEO GILLIS AT NATIONAL GRID
TO: DAVID O LEDERER, US EPA REGION 1
AUTHOR: EDWARD A CONROY, METCALF & EDDY
DOC ID: 209635 05/03/2001 10 PAGES
100. MEMO : DATA GAPS RELATING TO ECOLOGICAL RISK ASSESSMENT
AUTHOR: ANTHONY M RODOLAKIS, METCALF & EDDY
DOC ID: 201274 05/11 /2001 2 PAGES
101. WORK PLAN: QUALITY ASSURANCE PROJECT PLAN, VOLUME 1 OF 2. TEXT,
TABLES, FIGURES, APPENDICES A & B
TO: SHPACK STEERING COMMITTEE
AUTHOR: ENVIRONMENTAL RESOURCES MANAGEMENT
DOC ID: 200468 08/01/2001 477 PAGES
102. WORK PLAN: QUALITY ASSURANCE PROJECT PLAN, VOLUME 2 OF 2,
APPENDICES C & D [PART 1 OF 2]
TO: SHPACK STEERING COMMITTEE AUTHOR: ENVIRONMENTAL RESOURCES
MANAGEMENT
DOC ID: 200469 08/01/2001 423 PAGES
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3. REMEDIAL INVESTIGATION (RI) (cont)
103. WORK PLAN: DRAFT QUALITY ASSURANCE PROJECT PLAN SUPPLEMENTAL
LABORATORY INFORMATION
TO: DAVID O LEDERER, US EPA REGION 1
AUTHOR: STEVEN P SACCO, ENVIRONMENTAL RESOURCES MANAGEMENT
DOC ID: 200470 08/13/2001 126 PAGES
104. LETTER: FEBRUARY 2002 STATUS REPORT
TO: FRANCIS J VEALE, SHPACK STEERING COMMITTEE SHPACK STEERING
COMMITTEE
AUTHOR: STEVEN P SACCO, ENVIRONMENTAL RESOURCES MANAGEMENT
DOC ID: 200459 03/20/2002 2 PAGES
105. REPORT: QUALITY ASSURANCE PROJECT PLAN, REVISION 2 INSERT SHEETS
TO: SHPACK STEERING COMMITTEE
AUTHOR: ENVIRONMENTAL RESOURCES MANAGEMENT
DOC ID: 200458 05/01/2002 115 PAGES
106. WORK PLAN: SELECTED APPENDICES, ON COMPACT DISK, FOR FINAL
SAMPLING ANALYSIS PLAN, FOCUSED SITE INSPECTION; CHARACTERIZATION
SURVEYS FOR RADIOLOGICAL CONTAMINATES OF CONCERN, WITH
TRANSMITTAL
TO: DAVID LEDERER, EPA REGION 1 ON 5/17/2002
TO: US ARMY CORPS OF ENGINEERS - NEW ENGLAND DIVISION
AUTHOR: CABRERA SERVICES INC
DOC ID: 200473 05/09/2002 1 PAGE
107. LETTER: EXPLANATION OF QUALITY ASSURANCE PROJECT PLAN, REVISION 2
INSERT SHEETS
TO: DAVID O LEDERER, US EPA REGION 1
AUTHOR: STEVEN P SACCO, ENVIRONMENTAL RESOURCES MANAGEMENT
DOC ID: 200471 05/16/2002 2 PAGES
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3. REMEDIAL INVESTIGATION (RI) (cont)
108. LETTER: TRANSMITTAL FOR QUALITY ASSURANCE PROJECT PLAN, REVISION
2 INSERT SHEETS
TO: ANDREW COENEN, ERM WOODBURY
CONNIE FAUSTINI, ERM ANNAPOLIS
DAVID BUCKLEY, MA DEPT OF ENVIRONMENTAL PROTECTION
EDWARD A CONROY, METCALF & EDDY
ELLEN HEATH, DUKE ENGINEERING & SERVICES
FRANCIS J VEALE, TEXAS INSTRUMENTS INC
HEATHER GRAF, SHPACK AD HOC COMMITTEE
JENNIFER CARLINO, NORTON CONSERVATION COMMISSION
KATHLEEN HIBBETT, ATTLEBORO (MA) PUBLIC LIBRARY
MICHAEL ELLIOTT, TEXAS INSTRUMENTS INC NORTON (MA) PUBLIC
LIBRARY
PAUL SENCAL, MITIKEM
ROBERT CUMMINGS, EAST COAST ENGINEERING
ROBERT M BERNSTEIN, CABRERA SERVICES INC
SCOTT E ACONE, US ARMY CORPS OF ENGINEERS
AUTHOR: STEVEN P SACCO, ENVIRONMENTAL RESOURCES MANAGEMENT
DOC ID: 200472 05/16/2002 2 PAGES
109. LETTER: CONDITIONAL APPROVAL OF PHASE IB REMEDIAL INVESTIGATION
QUALITY ASSURANCE PROJECT PLAN, REVISION 2
TO: FRANCIS J VEALE, SHPACK STEERING COMMITTEE
AUTHOR: DAVID O LEDERER, US EPA REGION 1
DOC ID: 200441 06/06/2002 3 PAGES
110. LETTER: RESPONSE TO CONDITIONAL APPROVAL, PHASE IB WORK PLAN
TO: DAVID O LEDERER, US EPA REGION 1
AUTHOR: JOHN C DROBINSKI, ENVIRONMENTAL RESOURCES MANAGEMENT
JOHN R D'AGOSTINO, ENVIRONMENTAL RESOURCES MANAGEMENT
DOC ID: 200420 07/29/2002 30 PAGES
111. REPORT: MONITORING WELL REPLACEMENT, PHASE IB FIELD ACTIVITIES
TO: DAVID O LEDERER, US EPA REGION 1
AUTHOR: JOHN C DROBINSKI, ENVIRONMENTAL RESOURCES MANAGEMENT
JOHN R DAGOSTINO, ENVIRONMENTAL RESOURCES MANAGEMENT
DOC ID: 209636 11/07/2002 18 PAGES
112. LETTER: COMMENTS ON DRAFT HUMAN HEALTH ASSESSMENT INTAKE
VALUES REASONABLE MAXIMUM EXPOSURE (RME) AND CENTRAL
TENDENCY (CT)
TO: DAVID O LEDERER, US EPA REGION 1
AUTHOR: JOHN R D'AGOSTINO, ENVIRONMENTAL RESOURCES MANAGEMENT
DOC ID: 201275 03/04/2003 5 PAGES
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3. REMEDIAL INVESTIGATION (RI) (cont)
113. LETTER: LABORATORY REPORT, TOTAL RECOVERABLE METALS IN WATER
TO: DAVID O LEDERER, US EPA REGION 1
AUTHOR: WILLIAM J ANDRADE, US EPA REGION 1
DOC ID: 209634 05/15/2003 8 PAGES
114. LETTER: CONTINUATION PHASE 1-B FIELD SAMPLING AND REPLACEMENT
WELL INSTALLATION, OVERSIGHT REPORT, APRIL 24-MAY 2,2003
TO: DAVID O LEDERER, US EPA REGION 1
AUTHOR: EDWARD A CONROY, METCALF & EDDY
DOC ID: 209633 05/28/2003 9 PAGES
115. REPORT: HABITAT ASSESSMENT AND BIOLOGICAL SURVEY
TO: CAROL B GOLDSBERRY, US EPA REGION 1
AUTHOR: ENVIRONMENTAL RESOURCES MANAGEMENT
DOC ID: 201273 07/01/2003 46 PAGES
116. LETTER: NOVEMBER 2003 STATUS REPORT
TO: FRANCIS J VEALE, SHPACK STEERING COMMITTEE
SHPACK STEERING COMMITTEE
AUTHOR: JOHN R D'AGOSTINO, ENVIRONMENTAL RESOURCES MANAGEMENT
DOC ID: 200460 12/05/2003 2 PAGES
117. LETTER: JANUARY 2004 STATUS REPORT
TO: FRANCIS J VEALE, SHPACK STEERING COMMITTEE
SHPACK STEERING COMMITTEE
AUTHOR: JOHN R D'AGOSTINO, ENVIRONMENTAL RESOURCES MANAGEMENT
DOC ID: 200461 02/13/2004 2 PAGES
118. LETTER: FEBRUARY 2004 STATUS REPORT
TO: FRANCIS J VEALE, SHPACK STEERING COMMITTEE
SHPACK STEERING COMMITTEE
AUTHOR: JOHN R D'AGOSTINO, ENVIRONMENTAL RESOURCES MANAGEMENT
DOC ID: 200462 03/05/2004 2 PAGES
119. WORK PLAN: BACKGROUND SAMPLING WORK PLAN
TO: DAVID O LEDERER, US EPA REGION 1
AUTHOR: JOHN C DROBINSKI, ENVIRONMENTAL RESOURCES MANAGEMENT
JOHN R D'AGOSTINO, ENVIRONMENTAL RESOURCES MANAGEMENT
DOC ID: 200466 03/18/2004 12 PAGES
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120. LETTER: MARCH 2004 STATUS REPORT
TO: FRANCIS J VEALE, SHPACK STEERING COMMITTEE
SHPACK STEERING COMMITTEE
AUTHOR: JOHN R D'AGOSTINO, ENVIRONMENTAL RESOURCES MANAGEMENT
DOC ID: 200463 04/16/2004 2 PAGES
121. REPORT: BASELINE HUMAN HEALTH RISK ASSESSMENT
AUTHOR: METCALF & EDDY
DOC ID: 210480 06/01/2004 1 PAGE
122. REPORT: DRAFT BASELINE ECOLOGICAL RISK ASSESSMENT
AUTHOR: METCALF & EDDY
DOC ID: 210481 06/14/2004 1 PAGE
123. REPORT: DRAFT FINAL PHASE IB REMEDIAL INVESTIGATION (RI) REPORT,
VOLUME 1 OF 2
TO: SHPACK STEERING COMMITTEE
AUTHOR: ERM-NEW ENGLAND INC
DOC ID: 210484 06/17/2004 1 PAGE
124. REPORT: DRAFT FINAL PHASE IB REMEDIAL INVESTIGATION (RI) REPORT,
VOLUME 2 OF 2
TO: SHPACK STEERING COMMITTEE
AUTHOR: ERM-NEW ENGLAND INC
DOC ID: 210485 06/17/2004 1 PAGE
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4. FEASIBILITY STUDY (FS)
1. FORM : COMMENTS ON THE PROPOSED PLAN (24 FORM LETTERS)
TO: DAVID O LEDERER, US EPA REGION 1
AUTHOR: BRIAN RATCLIFFE, NORTON (MA) RESIDENT
BRYAN O'ROURKE, NORTON (MA) RESIDENT
CAROLE A LEES, NORTON (MA) RESIDENT
DENNIS M O'KEEFE, NORTON (MA) RESIDENT
DOROTHY LEE DESMARAIS, NORTON (MA) RESIDENT
DOROTHY RATCLIFFE, NORTON (MA) RESIDENT
DWAYNE HANCOCK, NORTON (MA) RESIDENT
EDWARD M HALLAHAN, NORTON (MA) RESIDENT
JANET MARIE O'KEEFE, NORTON (MA) RESIDENT
JANETTE FRANKE JOEL THOMSON, NORTON (MA) RESIDENT
KAREN O'ROURKE, NORTON (MA) RESIDENT
KELLIE ROE, NORTON (MA) RESIDENT
MATTHEW DESMARAIS, NORTON (MA) RESIDENT
MOLLIE L O'KEEFE, NORTON (MA) RESIDENT
NICOLINA ZUSCHLAG, ATTLEBORO (MA) RESIDENT
PATRICIA A CLIFFORD, NORTON (MA) RESIDENT
PAUL W RATCLIFFE, NORTON (MA) RESIDENT
SHEILA GRAY, NORTON (MA) RESIDENT
STEVEN J PAILLE, NORTON (MA) RESIDENT
SUSAN J WEILDING, NORTON (MA) RESIDENT
TERESA L TOCCI, NORTON (MA) RESIDENT
VIVIAN LAMBRECHT WALTER RATCLIFFE, NORTON (MA) RESIDENT
WALTER ZUSCHLAG, ATTLEBORO (MA) RESIDENT
DOC ID: 212008 24 PAGES
2. LETTER: COMMENTS ON THE PROPOSED PLAN
TO: DAVID O LEDERER, US EPA REGION 1
AUTHOR: MARK BRUHAN, NORTON (MA) RESIDENT
DOC ID: 211336 1 PAGE
3. LETTER: COMMENTS ON THE PROPOSED PLAN
TO: DAVID O LEDERER, US EPA REGION I
AUTHOR: LEANNE COBB, NORTON (MA) RESIDENT
STEVENS COBB, NORTON (MA) RESIDENT
DOC ID: 211337 2 PAGES
4. LETTER: COMMENTS ON THE PROPOSED PLAN
TO: DAVID O LEDERER, US EPA REGION 1
AUTHOR: DONALD G QUILLEN, ATTLEBORO (MA) RESIDENT
DOC ID: 211339 1 PAGE
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4. FEASIBILITY STUDY (FS) (cont)
5. LETTER: COMMENTS ON THE PROPOSED PLAN
TO: DAVID O LEDERER, US EPA REGION 1
AUTHOR: JOSEPH SURETTE, ATTLEBORO (MA) RESIDENT
DOC ID: 211340 1 PAGE
6. MEMO : POSITION PAPER FOR THE TOWN OF NORTON, COMMENTS ON THE
PROPOSED PLAN
AUTHOR: ROBERT W KIMBALL, NORTON BOARD OF SELECTMEN
DOC ID: 211332 5 PAGES
7. LETTER: RELEASE CRITERIA FOR DECOMMISSIONING RADIOLOGICALLY
CONTAMINATED FACILITIES FOR UNRESTRICTED USE IN MASSACHUSETTS
TO: DAVID BUCKLEY, MA DEPT OF ENVIRONMENTAL PROTECTION
AUTHOR: ROBERT M HALLISEY, MA DEPT OF PUBLIC HEALTH
DOC ID: 200467 07/20/2001 2 PAGES
8. LETTER: POTENTIAL ARAR RELATIVE TO THE SHPACK SUPERFUND SITE
RADIONUCLIDE CONTAINING WASTES, WITH TRANSMITTAL TO SCOTT
ACONE, US ACE ON 8/24/2001
TO: DAVID O LEDERER, US EPA REGION 1
AUTHOR: PAUL CRAFFEY, US EPA REGION 1
DOC ID: 200465 08/13/2001 3 PAGES
9. FACT SHEET: PROPOSED PLAN FOR SELECTED REMEDIAL ACTION AT SHPACK
LANDFILL SITE AUTHOR: US EPA REGION 1
DOC ID: 210633 06/01/2004 12 PAGES
10. REPORT: DRAFT FINAL FEASIBILITY STUDY (FS)
TO: SHPACK STEERING COMMITTEE
AUTHOR: ERM-NEW ENGLAND INC
DOC ID: 210483 06/17/2004 1 PAGE
11. LETTER: TRANSMITTAL OF PROPOSED PLAN, REMEDIAL INVESTIGATION,
FEASIBILITY STUDY, HUMAN HEALTH RISK ASSESSMENT, AND BASELINE
RISK ASSESSMENT
AUTHOR: DAVID O LEDERER, US EPA REGION 1
DOC ID: 213639 06/22/2004 1 PAGE
12. LETTER: REQUEST FOR A THIRTY (30) DAY EXTENSION OF PUBLIC COMMENT
PERIOD ON THE PROPOSED PLAN
TO: DAVID O LEDERER, US EPA REGION 1
AUTHOR: HEATHER GRAF, SHPACK AD HOC COMMITTEE
DOC ID: 211327 07/01/2004 1 PAGE
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4. FEASIBILITY STUDY (FS) (cont)
13. LETTER: COMMENTS ON THE PROPOSED PLAN
TO: DAVID O LEDERER, US EPA REGION 1
AUTHOR: DAVID F YOPAK, TEKNOR APEX COMPANY
DOC ID: 2113 3 8 07/07/2004 1 PAGE
14. LETTER: COMMENTS ON THE PROPOSED PLAN
TO: DAVID O LEDERER, US EPA REGION 1
AUTHOR: FREDERICK J WATSON, NORTON (MA) BOARD OF HEALTH
DOC ID: 211330 07/08/2004 2 PAGES
15. MEMO : COMMENTS ON THE PROPOSED PLAN
TO: DAVID O LEDERER, US EPA REGION 1
AUTHOR: CITIZENS ADVISORY SHPACK TEAM (CAST)
HEATHER GRAF, SHPACK AD HOC COMMITTEE
DOC ID: 211329 07/14/2004 7 PAGES
16. FORM : COMMENTS ON THE PROPOSED PLAN
TO: DAVID O LEDERER, US EPA REGION 1
AUTHOR: ROSEMARIE HOYLE, NORTON (MA) RESIDENT
DOC ID: 211342 07/22/2004 1 PAGE
17. FORM : COMMENTS ON THE PROPOSED PLAN
TO: DAVID O LEDERER, US EPA REGION 1
AUTHOR: WAYNE A GRAF, NORTON (MA) RESIDENT
DOC ID: 211343 07/23/2004 1 PAGE
18. FORM : COMMENTS ON THE PROPOSED PLAN
TO: DAVID O LEDERER, US EPA REGION 1
AUTHOR: STEVEN J ARCANTI
DOC ID: 211344 07/23/2004 1 PAGE
19. FORM : COMMENTS ON THE PROPOSED PLAN
TO: DAVID O LEDERER, US EPA REGION 1
AUTHOR: JAMES A HARROD
DOC ID: 211345 07/27/2004 1 PAGE
20. MEMO : COMMENTS ON THE PROPOSED PLAN
TO: DAVID O LEDERER, US EPA REGION 1
AUTHOR: CLARENCE P RICH, NORTON BOARD OF SELECTMEN
DOC ID: 211324 07/27/2004 2 PAGES
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4. FEASIBILITY STUDY (FS) (cont)
21. FORM : COMMENTS ON THE PROPOSED PLAN
TO: DAVID O LEDERER, US EPA REGION 1
AUTHOR: KATHLEEN A RODRIGUES
DOC ID: 211346 07/28/2004 1 PAGE
22. FORM : COMMENTS ON THE PROPOSED PLAN
TO: DAVID O LEDERER, US EPA REGION 1
AUTHOR: JOHN M RODRIGUES
DOC ID: 211347 07/28/2004 1 PAGE
23. FORM : COMMENTS ON THE PROPOSED PLAN
TO: DAVID O LEDERER, US EPA REGION 1
AUTHOR: DONALD G RAFFETY
JUDITH A RAFFETY
DOC ID: 211348 07/28/2004 1 PAGE
24. MEMO : COMMENTS ON THE PROPOSED PLAN
TO: DAVID O LEDERER, US EPA REGION 1
AUTHOR: RICHARD KRUMM, NORTON (MA) RESIDENT
DOC ID: 211328 07/28/2004 1 PAGE
25. FORM : COMMENTS ON THE PROPOSED PLAN
TO: DAVID O LEDERER, US EPA REGION 1
AUTHOR: ANNE RODRIGUES, NORTON (MA) RESIDENT
DOC ID: 211349 07/29/2004 1 PAGE
26. LETTER: COMMENTS ON THE PROPOSED PLAN
TO: DAVID O LEDERER, US EPA REGION 1
AUTHOR: THOMAS W FRENCH, MA DIVISION OF FISHERIES
DOC ID: 2113 31 07/3 0/2004 1 PAGE
27. LETTER: COMMENTS ON THE PROPOSED PLAN
TO: ROBERT W VARNEY, US EPA REGION 1
AUTHOR: ELIZABETH A POIRIER, MA HOUSE OF REPRESENTATIVES
MICHAEL COPPOLA, MA HOUSE OF REPRESENTATIVES
PHILIP TRAVIS, MA HOUSE OF REPRESENTATIVES
DOC ID: 211334 07/30/2004 2 PAGES
28. LETTER: COMMENTS ON THE PROPOSED PLAN
TO: DAVID O LEDERER, US EPA REGION 1
AUTHOR: LISA M TOMMASELLO, NORTON (MA) RESIDENT
DOC ID: 2113 3 5 07/3 0/2004 1 PAGE
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29. FORM : COMMENTS ON THE PROPOSED PLAN (35 FORM LETTERS)
TO: DAVID O LEDERER, US EPA REGION I
AUTHOR: CHRISTIANE DENKEL, NORTON (MA) RESIDENT
CHRISTINE WILLCUTT, NORTON (MA) RESIDENT
DEBORAH A SALLEY, NORTON (MA) RESIDENT
ELIZABETH D SEACORD, NORTON (MA) RESIDENT
ELIZABETH POLK, NORTON (MA) RESIDENT
ELIZABETH S DEXTER
ESTELLE M FLETT, NORTON (MA) RESIDENT
ESTHER JARUGA
FREDERICK J WATSON, NORTON (MA) RESIDENT
HAROLD ROGERS, E. TAUNTON (MA) RESIDENT
HENRI A YELLE, NORTON (MA) RESIDENT
HOLLY INTASI, NORTON (MA) RESIDENT
JACQUELINE CANTO, NORTON (MA) RESIDENT
JOHN J WILLCUTT, NORTON (MA) RESIDENT
KARLEEN SALLEY, NORTON (MA) RESIDENT
KIMBERLY SALLEY, NORTON (MA) RESIDENT
KRISTINA SALLEY, NORTON (MA) RESIDENT
LISA M MCINTOSH, NORTON (MA) RESIDENT
LORRAINE N ORNELLA, NORTON (MA) RESIDENT
LYDIA A LOVING, NORTON (MA) RESIDENT
LYDIA J FALES-TATRO, NORTON (MA) RESIDENT
MARCIMACKEY, ATTLEBORO (MA) RESIDENT
MARIE E WEISS MARIE T LEE, ATTLEBORO (MA) RESIDENT
MILDRED L ANDREWS, NORTON (MA) RESIDENT
PETER B ROBB
ROGER A BOGOSH, NORTON (MA) RESIDENT
RUTH E GOOLD, NORTON (MA) RESIDENT
RUTH YOUNGQUIST
STEPHEN WEBBER, E. TAUNTON (MA) RESIDENT
SUSAN MIMS, NORTON (MA) RESIDENT
THERESA A ROGERS, E. TAUNTON (MA) RESIDENT
THOMAS E BURKE, NORTON (MA) RESIDENT
VICTORIA MAY, NORTON (MA) RESIDENT
WILLIAM J JR CROWLEY, ATTLEBORO (MA) RESIDENT
DOC ID: 211355 08/01/2004 35 PAGES
30. FORM : COMMENTS ON THE PROPOSED PLAN
TO: DAVID O LEDERER, US EPA REGION 1
AUTHOR: JOHN J WILLCUTT, NORTON (MA) RESIDENT
DOC ID: 211350 08/03/2004 1 PAGE
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4. FEASIBILITY STUDY (FS) (cont)
31. LETTER: COMMENTS ON THE PROPOSED PLAN
TO: DAVID O LEDERER, US EPA REGION 1
AUTHOR: HEATHER GRAF, SHPACK AD HOC COMMITTEE
DOC ID: 211326 08/04/2004 4 PAGES
32. LETTER: COMMENTS ON THE PROPOSED PLAN
TO: ROBERT W VARNEY, US EPA REGION 1
AUTHOR: BARNEY FRANK, US HOUSE OF REPRESENTATIVES
DOC ID: 211333 08/04/2004 2 PAGES
33. LETTER: COMMENTS ON THE PROPOSED PLAN ON BEHALF OF CONSTITUENTS
TO: DAVID O LEDERER, US EPA REGION 1
AUTHOR: JO ANN SPRAGUE, MA SENATE
DOC ID: 211325 08/05/2004 2 PAGES
34. FORM : COMMENTS ON THE PROPOSED PLAN
TO: DAVID O LEDERER, US EPA REGION 1
AUTHOR: KARI CANNING, NORTON (MA) RESIDENT
THOMAS CANNING, NORTON (MA) RESIDENT
DOC ID: 211351 08/06/2004 1 PAGE
35. FORM : COMMENTS ON THE PROPOSED PLAN
TO: DAVID O LEDERER, US EPA REGION 1
AUTHOR: NANCY M WEBBER, NORTON (MA) RESIDENT
DOC ID: 211352 08/09/2004 1 PAGE
36. FORM : COMMENTS ON THE PROPOSED PLAN
TO: DAVID O LEDERER, US EPA REGION 1
AUTHOR: JAMES R PAILLE, NORTON (MA) RESIDENT
DOC ID: 211353 08/09/2004 1 PAGE
37. FORM : COMMENTS ON THE PROPOSED PLAN
TO: DAVID O LEDERER, US EPA REGION 1
AUTHOR: ALICE H PAILLE, NORTON (MA) RESIDENT
DOC ID: 211354 08/10/2004 1 PAGE
3 8. LETTER: COMMENTS ON THE PROPO SED PLAN
TO: DAVID O LEDERER, US EPA REGION 1
AUTHOR: MICHELE MICHART@ ONEBOX.COM, NORTON (MA) RESIDENT
DOC ID: 211341 08/10/2004 1 PAGE
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4. FEASIBILITY STUDY (FS) (cont)
39. LETTER: THE CONSERVATION COMMISSION HAS VOTED TO STRONGLY
SUPPORT THE OPTION SC-3B FOR THE CLEANUP OF SHPACK LANDFILL
TO: BARNEY FRANK, US HOUSE OF REPRESENTATIVES
DAVID BUCKLEY, MA DEPT OF ENVIRONMENTAL PROTECTION
DAVID O LEDERER, US EPA REGION 1
ED TANNER, ATTLEBORO CONSERVATION COMMISSION
ELIZABETH A POIRIER, MA HOUSE OF REPRESENTATIVES
FRANCIS J VEALE, TEXAS INSTRUMENTS INC
HEATHER GRAF, SHPACK AD HOC COMMITTEE
JAMES P PURCELL, NORTON (MA) TOWN OF
JO ANN SPRAGUE, MA SENATE
KENNETH MUNNEY, US DOI/US FISH & WILDLIFE SERVICE
MICHAEL COPPOLA, MA HOUSE OF REPRESENTATIVES
PHILIP TRAVIS, MA HOUSE OF REPRESENTATIVES
AUTHOR: JENNIFER CARLINO, NORTON CONSERVATION COMMISSION
DOC ID: 212007 08/10/2004 5 PAGES
40. LETTER: COMMENTS ON THE PROPOSED CLEANUP PLAN FOR THE SHPACK
SUPERFUND SITE
TO: DAVID O LEDERER, US EPA REGION 1
AUTHOR: STANLEY J WALASAVAGE, NORTON POLICE DEPARTMENT
DOC ID: 213807 08/20/2004 1 PAGE
41. MEMO : COMMENTS ON THE PROPOSED PLAN FOR THE SHPACK SUPERFUND
SITE
AUTHOR: HEATHER GRAF, SHPACK AD HOC COMMITTEE
DOC ID: 213820 08/20/2004 4 PAGES
42. LETTER: COMMENTS ON THE PROPOSED CLEANUP PLAN FOR THE SHPACK
SUPERFUND SITE
TO: DAVID O LEDERER, US EPA REGION 1
AUTHOR: HOWARD B BAKER, NORTON (MA) EMERGENCY MANAGEMENT
AGENCY
DOC ID: 213808 08/22/2004 1 PAGE
43. NEWS CLIPPING: COMMENTS ON THE PROPOSED CLEANUP PLAN FOR THE
SHPACK SUPERFUND SITE
TO: DAVID O LEDERER, US EPA REGION 1
AUTHOR: JOSEPH CALLAHAN, TAUNTON RIVER WATERSHED ALLIANCE INC
DOC ID: 213812 08/23/2004 1 PAGE
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4. FEASIBILITY STUDY (FS) (cont)
44. LETTER: COMMENTS ON THE PROPOSED CLEANUP PLAN FOR THE SHPACK
SUPERFUND SITE
TO: DAVID O LEDERER, US EPA REGION 1
AUTHOR: JONATHAN O'REILLY, NORTON (MA) RESIDENT
DOC ID: 213802 08/24/2004 1 PAGE
45. LETTER: COMMENTS ON THE PROPOSED CLEANUP PLAN FOR THE SHPACK
SUPERFUND SITE
TO: DAVID O LEDERER, US EPA REGION 1
AUTHOR: RICHARD J GOMES, NORTON FIRE RESCUE
DOC ID: 213803 08/24/2004 2 PAGES
46. LETTER: COMMENTS ON THE PROPOSED CLEANUP PLAN FOR THE SHPACK
SUPERFUND SITE
TO: DAVID O LEDERER, US EPA REGION 1
AUTHOR: PAUL J SCHLEICHER, NORTON FIRE RESCUE
DOC ID: 213804 08/24/2004 1 PAGE
47. LETTER: COMMENTS ON THE PROPOSED CLEANUP PLAN FOR THE SHPACK
SUPERFUND SITE
TO: DAVID O LEDERER, US EPA REGION 1
AUTHOR: JANET O'REILLY, NORTON (MA) RESIDENT
DOC ID: 213805 08/24/2004 1 PAGE
48. LETTER: COMMENTS ON THE PROPOSED CLEANUP PLAN FOR THE SHPACK
SUPERFUND SITE
TO: DAVID O LEDERER, US EPA REGION 1
AUTHOR: GEORGE F BURGESS, NORTON FIRE RESCUE
DOC ID: 213806 08/24/2004 1 PAGE
49. NEWS CLIPPING: COMMENTS ON THE PROPOSED CLEANUP PLAN FOR THE
SHPACK SUPERFUND SITE
TO: DAVID O LEDERER, US EPA REGION 1
AUTHOR: RONALD O'REILLY, NORTON (MA) RESIDENT
DOC ID: 213811 08/24/2004 7 PAGES
50. LETTER: COMMENTS ON THE PROPOSED CLEANUP PLAN FOR THE SHPACK
SUPERFUND SITE
TO: DAVID O LEDERER, US EPA REGION 1
AUTHOR: KEWNNETH SEJKORA, AD HOC SHPACK TECHNICAL COMMITTEE
DOC ID: 213813 08/25/2004 2 PAGES
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4. FEASIBILITY STUDY (FS) (cont)
51. NEWS CLIPPING: COMMENTS ON THE PROPOSED CLEANUP PLAN FOR THE
SHPACK SUPERFUND SITE
TO: DAVID O LEDERER, US EPA REGION 1
AUTHOR: CHARLES MAORI, NORTON (MA) RESIDENT
KATIE MAORI, NORTON (MA) TOWN OF
DOC ID: 213810 08/25/2004 1 PAGE
52. LETTER: WASTE DISPOSAL ALTERNATIVES REVIEW FOR THE SHPACK SITE
TO: EDWARD A CONROY, METCALF & EDDY
AUTHOR: KENNETH M KASPER, SCIENTECH
DOC ID: 214124 09/22/2004 7 PAGES
53. MEMO : TRANSMITAL FOR SHPACK TRANSPORT AND DISPOSAL COSTS
TO: DAVID O LEDERER, US EPA REGION 1
AUTHOR: EDWARD A CONROY, METCALF & EDDY
DOC ID: 214123 09/24/2004 1 PAGE
5. RECORD OF DECISION (ROD)
1. LETTER: STATE APPLICABLE, AND RELEVANT AND APPROPRIATE
REQUIREMENTS FOR THE SHPACK LANDFILL
TO: DAVID O LEDERER, US EPA REGION 1
AUTHOR: DAVID BUCKLEY, MA DEPT OF ENVIRONMENTAL PROTECTION
DOC ID: 200406 01/15/2004 4 PAGES
2. LETTER: MA DEP COMMENTS ON THE DRAFT RECORD OF DECISION
TO: DAVID O LEDERER, US EPA REGION 1
AUTHOR: DAVID BUCKLEY, MA DEPT OF ENVIRONMENTAL PROTECTION
DOC ID: 214125 09/22/2004 3 PAGES
3. RECORD OF DECISION: RECORD OF DECISION (ROD)
AUTHOR: US EPA REGION 1
DOC ID: 214530 09/30/2004
9. STATE COORDINATION
1. LETTER: REQUEST FOR ASSISTANCE IN COORDINATING THE SITE
INVESTIGATION
TO: MERRILL S HOHMAN, US EPA REGION 1
AUTHOR: WILLIAM F CASS, MA DEPT OF ENVIRONMENTAL PROTECTION
DOC ID: 200405 12/28/1981 1 PAGE
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9. STATE COORDINATION (cont)
2. LETTER: ISSUES REGARDING ATTLEBORO LANDFILL INC WHICH MAY IMPACT
CLEANUP AT THE SHPACK LANDFILL SITE
TO: JAY NAPARSTEK, MA DEPT OF ENVIRONMENTAL PROTECTION
AUTHOR: CAROL TUCKER, US EPA REGION 1
DOC ID: 200438 02/18/2004 6 PAGES
3. LETTER: GROUNDWATER USE AND VALUE DETERMINATION
TO: CAROL TUCKER, US EPA REGION I
AUTHOR: JAY NAPARSTEK, MA DEPT OF ENVIRONMENTAL PROTECTION
DOC ID: 200436 04/12/2004 6 PAGES
10. ENFORCEMENT/NEGOTIATION
1. LITIGATION: ADMINISTRATIVE ORDER BY CONSENT FOR REMEDIAL
INVESTIGATION/FEASIBILITY STUDY (RI/FS), US EPA DOCKET NO. 1-90-1113
AUTHOR: US EPA REGION 1
DOC ID: 41851 09/24/1990 102 PAGES
2. LITIGATION: COST RECOVERY ADMINISTRATIVE AGREEMENT, CERCLA
DOCKET NO. 1-90-1114
AUTHOR: US EPA REGION 1
DOC ID: 200402 06/18/1991 19 PAGES
3. LETTER: NO COMMENTS RECEIVED ON COST RECOVERY ADMINISTRATIVE
AGREEMENT, CERCLA DOCKET NO. 1-90-1114
TO: PATRICIA L TRUSCELLI, PARKER CHAPIN FLATTAU & KLIMPL
RICK JOOSTEN, TEXAS INSTRUMENTS INC
AUTHOR: ANDREW RAUBVOGEL, US EPA REGION 1
DOC ID: 200403 08/14/1991 2 PAGES
11. POTENTIALLY RESPONSIBLE PARTY
1. LETTER: REQUEST FOR REIMBURSEMENT OF COSTS ARISING OUT OF THE
DECONTAMINATION AND DECOMMISSIONING OF THE TEXAS INSTRUMENTS
INCORPORATED FACILITY IN ATTLEBORO, MASSACHUSETTS [PART 1 OF 17]
TO: HAZEL R OLEARY, US DEPT OF ENERGY
ROBERT R NORDHAUS, US DEPT OF ENERGY
AUTHOR: WERNER H SCHUELE, TEXAS INSTRUMENTS INC
DOC ID: 209706 12/20/1996 205 PAGES
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11. POTENTIALLY RESPONSIBLE PARTY (cont)
2. LETTER: REQUEST FOR REIMBURSEMENT OF COSTS ARISING OUT OF THE
DECONTAMINATION AND DECOMMISSIONING OF THE TEXAS INSTRUMENTS
INCORPORATED FACILITY IN ATTLEBORO, MASSACHUSETTS [PART 10 OF 17]
TO: HAZEL R OLEARY, US DEPT OF ENERGY
ROBERT R NORDHAUS, US DEPT OF ENERGY
AUTHOR: WERNER H SCHUELE, TEXAS INSTRUMENTS INC
DOC ID: 209715 12/20/1996 302 PAGES
3. LETTER: REQUEST FOR REIMBURSEMENT OF COSTS ARISING OUT OF THE
DECONTAMINATION AND DECOMMISSIONING OF THE TEXAS INSTRUMENTS
INCORPORATED FACILITY IN ATTLEBORO, MASSACHUSETTS [PART 11 OF 17]
TO: HAZEL R OLEARY, US DEPT OF ENERGY
ROBERT R NORDHAUS, US DEPT OF ENERGY
AUTHOR: WERNER H SCHUELE, TEXAS INSTRUMENTS INC
DOC ID: 209716 12/20/1996 295 PAGES
4. LETTER: REQUEST FOR REIMBURSEMENT OF COSTS ARISING OUT OF THE
DECONTAMINATION AND DECOMMISSIONING OF THE TEXAS INSTRUMENTS
INCORPORATED FACILITY IN ATTLEBORO, MASSACHUSETTS [ PART 12 OF 17]
TO: HAZEL R OLEARY, US DEPT OF ENERGY
ROBERT R NORDHAUS, US DEPT OF ENERGY
AUTHOR: WERNER H SCHUELE, TEXAS INSTRUMENTS INC
DOC ID: 209717 12/20/1996 171 PAGES
5. LETTER: REQUEST FOR REIMBURSEMENT OF COSTS ARISING OUT OF THE
DECONTAMINATION AND DECOMMISSIONING OF THE TEXAS INSTRUMENTS
INCORPORATED FACILITY IN ATTLEBORO, MASSACHUSETTS [PART 13 OF 17]
TO: HAZEL R OLEARY, US DEPT OF ENERGY
ROBERT R NORDHAUS, US DEPT OF ENERGY
AUTHOR: WERNER H SCHUELE, TEXAS INSTRUMENTS INC
DOC ID: 209718 12/20/1996 318 PAGES
6. LETTER: REQUEST FOR REIMBURSEMENT OF COSTS ARISING OUT OF THE
DECONTAMINATION AND DECOMMISSIONING OF THE TEXAS INSTRUMENTS
INCORPORATED FACILITY IN ATTLEBORO, MASSACHUSETTS [PART 14 OF 17]
TO: HAZEL R OLEARY, US DEPT OF ENERGY
ROBERT R NORDHAUS, US DEPT OF ENERGY
AUTHOR: WERNER H SCHUELE, TEXAS INSTRUMENTS INC
DOC ID: 209719 12/20/1996 213 PAGES
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11. POTENTIALLY RESPONSIBLE PARTY (cont)
7. LETTER: REQUEST FOR REIMBURSEMENT OF COSTS ARISING OUT OF THE
DECONTAMINATION AND DECOMMISSIONING OF THE TEXAS INSTRUMENTS
INCORPORATED FACILITY IN ATTLEBORO, MASSACHUSETTS [PART 15 OF 17]
TO: HAZEL R OLEARY, US DEPT OF ENERGY
ROBERT R NORDHAUS, US DEPT OF ENERGY
AUTHOR: WERNER H SCHUELE, TEXAS INSTRUMENTS INC
DOC ID: 209720 12/20/1996 205 PAGES
8. LETTER: REQUEST FOR REIMBURSEMENT OF COSTS ARISING OUT OF THE
DECONTAMINATION AND DECOMMISSIONING OF THE TEXAS INSTRUMENTS
INCORPORATED FACILITY IN ATTLEBORO, MASSACHUSETTS [PART 16 OF 17]
TO: HAZEL R OLEARY, US DEPT OF ENERGY
ROBERT R NORDHAUS, US DEPT OF ENERGY
AUTHOR: WERNER H SCHUELE, TEXAS INSTRUMENTS INC
DOC ID: 209721 12/20/1996 172 PAGES
9. LETTER: REQUEST FOR REIMBURSEMENT OF COSTS ARISING OUT OF THE
DECONTAMINATION AND DECOMMISSIONING OF THE TEXAS INSTRUMENTS
INCORPORATED FACILITY IN ATTLEBORO, MASSACHUSETTS [PART 17 OF 17]
TO: HAZEL R OLEARY, US DEPT OF ENERGY
ROBERT R NORDHAUS, US DEPT OF ENERGY
AUTHOR: WERNER H SCHUELE, TEXAS INSTRUMENTS INC
DOC ID: 209722 12/20/1996 137 PAGES
10. LETTER: REQUEST FOR REIMBURSEMENT OF COSTS ARISING OUT OF THE
DECONTAMINATION AND DECOMMISSIONING OF THE TEXAS INSTRUMENTS
INCORPORATED FACILITY IN ATTLEBORO, MASSACHUSETTS [PART 2 OF 17]
TO: HAZEL R OLEARY, US DEPT OF ENERGY
ROBERT R NORDHAUS, US DEPT OF ENERGY
AUTHOR: WERNER H SCHUELE, TEXAS INSTRUMENTS INC
DOC ID: 209707 12/20/1996 207 PAGES
11. LETTER: REQUEST FOR REIMBURSEMENT OF COSTS ARISING OUT OF THE
DECONTAMINATION AND DECOMMISSIONING OF THE TEXAS INSTRUMENTS
INCORPORATED FACILITY IN ATTLEBORO, MASSACHUSETTS [PART 3 OF 17]
TO: HAZEL R OLEARY, US DEPT OF ENERGY
ROBERT R NORDHAUS, US DEPT OF ENERGY
AUTHOR: WERNER H SCHUELE, TEXAS INSTRUMENTS INC
DOC ID: 209708 12/20/1996 279 PAGES
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SHPACK LANDFILL
ENTIRE SITE
ADMINISTRATIVE RECORD FILE
SHPACK OU1 ROD AR
11. POTENTIALLY RESPONSIBLE PARTY (cont)
12. LETTER: REQUEST FOR REIMBURSEMENT OF COSTS ARISING OUT OF THE
DECONTAMINATION AND DECOMMISSIONING OF THE TEXAS INSTRUMENTS
INCORPORATED FACILITY IN ATTLEBORO, MASSACHUSETTS [PART 4 OF 17]
TO: HAZEL R OLEARY, US DEPT OF ENERGY
ROBERT R NORDHAUS, US DEPT OF ENERGY
AUTHOR: WERNER H SCHUELE, TEXAS INSTRUMENTS INC
DOC ID: 209709 12/20/1996 287 PAGES
13. LETTER: REQUEST FOR REIMBURSEMENT OF COSTS ARISING OUT OF THE
DECONTAMINATION AND DECOMMISSIONING OF THE TEXAS INSTRUMENTS
INCORPORATED FACILITY IN ATTLEBORO, MASSACHUSETTS [PART 5 OF 17]
TO: HAZEL R OLEARY, US DEPT OF ENERGY
ROBERT R NORDHAUS, US DEPT OF ENERGY
AUTHOR: WERNER H SCHUELE, TEXAS INSTRUMENTS INC
DOC ID: 209710 12/20/1996 236 PAGES
14. LETTER: REQUEST FOR REIMBURSEMENT OF COSTS ARISING OUT OF THE
DECONTAMINATION AND DECOMMISSIONING OF THE TEXAS INSTRUMENTS
INCORPORATED FACILITY IN ATTLEBORO, MASSACHUSETTS [PART 6 OF 17]
TO: HAZEL R OLEARY, US DEPT OF ENERGY
ROBERT R NORDHAUS, US DEPT OF ENERGY
AUTHOR: WERNER H SCHUELE, TEXAS INSTRUMENTS INC
DOC ID: 209711 12/20/1996 163 PAGES
15. LETTER: REQUEST FOR REIMBURSEMENT OF COSTS ARISING OUT OF THE
DECONTAMINATION AND DECOMMISSIONING OF THE TEXAS INSTRUMENTS
INCORPORATED FACILITY IN ATTLEBORO, MASSACHUSETTS [PART 7 OF 17]
TO: HAZEL R OLEARY, US DEPT OF ENERGY
ROBERT R NORDHAUS, US DEPT OF ENERGY
AUTHOR: WERNER H SCHUELE, TEXAS INSTRUMENTS INC
DOC ID: 209712 12/20/1996 206 PAGES
16. LETTER: REQUEST FOR REIMBURSEMENT OF COSTS ARISING OUT OF THE
DECONTAMINATION AND DECOMMISSIONING OF THE TEXAS INSTRUMENTS
INCORPORATED FACILITY IN ATTLEBORO, MASSACHUSETTS [PART 8 OF 17]
TO: HAZEL R OLEARY, US DEPT OF ENERGY
ROBERT R NORDHAUS, US DEPT OF ENERGY
AUTHOR: WERNER H SCHUELE, TEXAS INSTRUMENTS INC
DOC ID: 209713 12/20/1996 211 PAGES
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SHPACK LANDFILL
ENTIRE SITE
ADMINISTRATIVE RECORD FILE
SHPACK OU1 ROD AR
11. POTENTIALLY RESPONSIBLE PARTY (cont)
17. LETTER: REQUEST FOR REIMBURSEMENT OF COSTS ARISING OUT OF THE
DECONTAMINATION AND DECOMMISSIONING OF THE TEXAS INSTRUMENTS
INCORPORATED FACILITY IN ATTLEBORO, MASSACHUSETTS [PART 9 OF 17]
TO: HAZEL R OLEARY, US DEPT OF ENERGY
ROBERT R NORDHAUS, US DEPT OF ENERGY
AUTHOR: WERNER H SCHUELE, TEXAS INSTRUMENTS INC
DOC ID: 209714 12/20/1996 182 PAGES
18. LETTER: RETRACTION OF PROPRIETARY INFORMATION CLAIM ON "REQUEST
FOR REIMBURSEMENT OF COSTS ARISING OUT OF THE DECONTAMINATION
AND DECOMMISSIONING OF THE TEXAS INSTRUMENTS INCORPORATED
FACILITY IN ATTLEBORO, MASSACHUSETTS"
TO: GRETCHEN MUENCH, US EPA REGION 1
AUTHOR: FRANCIS J VEALE JR, TEXAS INSTRUMENTS INC
DOC ID: 209757 06/09/2004 2 PAGES
13. COMMUNITY RELATIONS
1. LETTER: DISPOSAL OF RADIOACTIVE WASTES IN NORTON AND ATTLEBORO.
MA
TO: JOHN SULLIVAN, ATTLEBORO (MA) RESIDENT
AUTHOR: RONNIE SHORENSTEIN ALKIRE
DOC ID: 201266 04/18/1980 2 PAGES
2. PRESS RELEASE: INVESTIGATION BEGINS AT SHPACK SUPERFUND SITE
AUTHOR: US EPA REGION 1
DOC ID: 201263 07/29/1991 2 PAGES
3. REPORT: COMMUNITY RELATIONS PLAN TO: US EPA REGION 1
AUTHOR: ALLIANCE TECHNOLOGIES CORP
DOC ID: 201257 08/06/1991 31 PAGES
4. REPORT: COMMUNITY RELATIONS SUPPORT PLAN
TO: US EPA REGION 1
AUTHOR: ERM NEW ENGLAND INC
DOC ID: 201258 05/12/1992 37 PAGES
5. LETTER: DOE EVALUATION OF RADIOLOGICAL CHARACTERIZATION EFFORTS
TO: FRANCIS J VEALE, SHPACK STEERING COMMITTEE
AUTHOR: LESTER K PRICE, US DEPT OF ENERGY
DOC ID: 201260 10/04/1993 2 PAGES
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SHPACK LANDFILL
ENTIRE SITE
ADMINISTRATIVE RECORD FILE
SHPACK OU1 ROD AR
COMMUNITY RELATIONS (cont)
6. FACT SHEET: FUSRAP FACT SHEET
AUTHOR: US ARMY CORPS OF ENGINEERS - NEW ENGLAND DIVISION
DOC ID: 201261 12/01/1999 3 PAGES
7. PUBLIC MEETING RECORD: INVITATION TO A PUBLIC INFORMATION MEETING
FOR AN UPDATE ON THE REMEDIAL INVESTIGATION AT THE SHPACK
LANDFILL SITE
AUTHOR: US EPA REGION 1
DOC ID: 200434 09/18/2000 1 PAGE
8. FACT SHEET: SHPACK LANDFILL SITE UPDATE
AUTHOR: US ARMY CORPS OF ENGINEERS - NEW ENGLAND DIVISION
DOC ID: 201262 01/01/2001 2 PAGES
9. PUBLIC MEETING RECORD: INVITATION TO A PUBLIC INFORMATION MEETING
ON THE SHPACK LANDFILL SITE
AUTHOR: US EPA REGION 1
DOC ID: 200433 03/06/2001 1 PAGE
10. PUBLIC MEETING RECORD: PUBLIC INFORMATION MEETING ON THE SHPACK
LANDFILL SITE TO BE POSTPONED
AUTHOR: US EPA REGION 1
DOC ID: 200432 07/25/2001 1 PAGE
11. PUBLIC MEETING RECORD: INVITATION TO ATTEND A PUBLIC INFORMATION
MEETING ON THE SHPACK LANDFILL SITE
AUTHOR: US EPA REGION 1
DOC ID: 200431 07/31/2001 1 PAGE
12. PUBLIC MEETING RECORD: INVITATION TO ATTEND A PUBLIC INFORMATION
MEETING ON THE SHPACK LANDFILL SITE
AUTHOR: US EPA REGION 1
DOC ID: 200430 09/11/2001 1 PAGE
13. PUBLIC MEETING RECORD: INVITATION TO ATTEND A PUBLIC INFORMATION
MEETING ON THE SHPACK LANDFILL SITE
AUTHOR: US EPA REGION 1
DOC ID: 200429 10/23/2001 1 PAGE
14. REPORT: COMMUNITY RELATIONS SUPPORT PLAN TO: SHPACK STEERING
COMMITTEE
AUTHOR: ENVIRONMENTAL RESOURCES MANAGEMENT
DOC ID: 201259 12/21/2001 12 PAGES
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SHPACK LANDFILL
ENTIRE SITE
ADMINISTRATIVE RECORD FILE
SHPACK OU1 ROD AR
COMMUNITY RELATIONS (cont)
15. PUBLIC MEETING RECORD: AGENDA AND HANDOUTS FOR THE LEGISLATIVE
BRIEFING FOR THE SHPACK LANDFILL SITE
AUTHOR: MA DEPT OF PUBLIC HEALTH
DOC ID: 200435 05/22/2002 8 PAGES
16. PUBLIC MEETING RECORD: AGENDA FOR A PUBLIC INFORMATION MEETING
ON CANCER INCIDENCE IN NORTON AND ATTLEBORO, MA
TO: SHPACK STEERING COMMITTEE
AUTHOR: MA DEPT OF PUBLIC HEALTH
DOC ID: 200428 06/11/2002 1 PAGE
17. PUBLIC MEETING RECORD: INVITATION TO AN OPEN HOUSE FOR THE SHPACK
LANDFILL
TO: SHPACK STEERING COMMITTEE
AUTHOR: US EPA REGION 1
DOC ID: 200427 07/16/2002 2 PAGES
18. LETTER: CLARIFICATION OF SLIDES PREPARED AND PRESENTED BY CABRERA
SERVICES
TO: HEATHER GRAF, SHPACK AD HOC COMMITTEE
AUTHOR: DAVID O LEDERER, US EPA REGION 1
DOC ID: 201265 11/01/2002 1 PAGE
19. PUBLIC MEETING RECORD: INVITATION TO A PUBLIC INFORMATIONAL
MEETING ON THE SHPACK LANDFILL
TO: SHPACK STEERING COMMITTEE
AUTHOR: US EPA REGION 1
DOC ID: 200426 11/12/2002 1 PAGE
20. LETTER: SUMMARY OF SAMPLING RESULTS FOR RESIDENTIAL PROPERTIES
AUTHOR: DAVID O LEDERER, US EPA REGION 1
DOC ID: 209661 05/15/2003 26 PAGES
21. SAMPLING & ANALYSIS DATA: VOAS IN DRINKING WATER, TRIP VOA BLANK
AUTHOR: US EPA REGION 1
DOC ID: 209660 08/27/2003 30 PAGES
22. SAMPLING & ANALYSIS DATA: LABORATORY REPORT, VOAS IN DRINKING
WATER
TO: DAVID O LEDERER, US EPA REGION 1
AUTHOR: WILLIAM J ANDRADE, US EPA REGION I
DOC ID: 209658 08/28/2003 41 PAGES
-------
SHPACK LANDFILL
ENTIRE SITE
ADMINISTRATIVE RECORD FILE
SHPACK OU1 ROD AR
COMMUNITY RELATIONS (cont)
23. SAMPLING & ANALYSIS DATA: TOTAL RECOVERABLE METALS IN WATER, 59
AND 68 UNION STREET, 70, 77, 100 AND 106 PECKHAM STREET, 14 NORTH
WORCESTER STREET, 35, 36, 82, 83, 94 AND 95 MAPLE STREET
AUTHOR: US EPA REGION 1
DOC ID: 209659 09/17/2003 14 PAGES
24. SAMPLING & ANALYSIS DATA: LABORATORY REPORT, TOTAL RECOVERABLE
METALS IN WATER
TO: DAVID O LEDERER, US EPA REGION 1
AUTHOR: WILLIAM J ANDRADE, US EPA REGION 1
DOC ID: 209657 09/18/2003 19 PAGES
25. SAMPLING & ANALYSIS DATA: TOTAL RECOVERABLE METALS IN WATER, 120
PECKHAM
AUTHOR: US EPA REGION 1
DOC ID: 209650 09/20/2003 1 PAGE
26. MEMO : SHPACK LANDFILL SITE PRIVATE WELL SAMPLING DATA
TO: DAVID O LEDERER, US EPA REGION 1
AUTHOR: DANIEL S GRANZ, US EPA REGION 1
DOC ID: 209656 09/24/2003 2 PAGES
27. LETTER: SUMMARY OF WELL MONITORING RESULTS FOR 59 AND 68 UNION
ROAD, 14 NORTH WORCESTER, 35, 36, 82, 83, 94, AND 95 MAPLE STREET, 70, 77,
100, AND 106 PECKHAM STREET
AUTHOR: DAVID O LEDERER, US EPA REGION 1
DOC ID: 209655 11/04/2003 17 PAGES
28. SAMPLING & ANALYSIS DATA: LABORATORY REPORT, VOAS IN DRINKING
WATER TO: DANIEL S GRANZ, US EPA REGION 1
AUTHOR: WILLIAM J ANDRADE, US EPA REGION 1
DOC ID: 209654 02/04/2004 17 PAGES
29. SAMPLING & ANALYSIS DATA: LABORATORY REPORT, TOTAL RECOVERABLE
METALS IN WATER
TO: DANIEL S GRANZ, US EPA REGION 1
AUTHOR: WILLIAM J ANDRADE, US EPA REGION 1
DOC ID: 209653 02/17/2004 8 PAGES
30. LETTER: SUMMARY OF WELL MONITORING RESULTS FOR 77 PECKHAM
STREET
AUTHOR: DAVID O LEDERER, US EPA REGION 1
DOC ID: 209652 02/23/2004 10 PAGES
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SHPACK LANDFILL
ENTIRE SITE
ADMINISTRATIVE RECORD FILE
SHPACK OU1 ROD AR
13. COMMUNITY RELATIONS (cont)
31. MEMO : SHPACK LANDFILL SITE PRIVATE WELL SAMPLING DATA TO: DAVID O
LEDERER, US EPA REGION 1
AUTHOR: DANIEL S GRANZ, US EPA REGION 1
DOC ID: 209651 02/23/2004 10 PAGES
32. PRESS RELEASE: THE UNITED STATES ENVIRONMENTAL PROTECTION
AGENCY ANNOUNCES THE AVAILABILITY OF THE ADMINISTRATIVE RECORD,
AND THE RESCHEDULING OF A PUBLIC MEETING, HEARING, AND PUBLIC
COMMENT PERIOD ON THE PROPOSED CLEANUP PLAN FOR THE SHPACK
LANDFILL SUPERFUND SITE
AUTHOR: US EPA REGION 1
DOC ID: 213581 06/18/2004 1 PAGE
33. FACT SHEET: INVITATION TO PUBLIC INFORMATION MEETING AND PUBLIC
HEARING ON THE PROPOSED CLEANUP PLAN
AUTHOR: US EPA REGION 1
DOC ID: 210474 06/23/2004 1 PAGE
34. PRESS RELEASE: THE UNITED STATES ENVIRONMENTAL PROTECTION
AGENCY ANNOUNCES THE EXTENSION TO THE PUBLIC COMMENT PERIOD
AND RESCHEDULING OF THE PUBLIC HEARING ON THE PROPOSED CLEANUP
PLAN FOR THE SHPACK LANDFILL SUPERFUND SITE
AUTHOR: US EPA REGION 1
DOC ID: 213582 07/21/2004 1 PAGE
35. PUBLIC MEETING RECORD: PUBLIC HEARING FOR THE PROPOSED CLEANUP
PLAN
DOC ID: 213801 08/04/2004 62 PAGES
36. NEWS CLIPPING: EDITORIAL COMMENTING ON THE PROPOSED CLEANUP PLAN
FOR THE SHPACK SUPERFUND SITE, WITH HANDWRITTEN NOTE ATTACHED
TO: DAVID O LEDERER, US EPA REGION 1
AUTHOR: WILLIAM GOUVEIA, NORTON MIRROR
DOC ID: 213809 08/13/2004 2 PAGES
14. CONGRESSIONAL RELATIONS
1. LETTER: COMMENTS ON THE PROPOSED CLEANUP PLAN FOR THE SHPACK
SUPERFUND SITE
TO: ROBERT W VARNEY, US EPA REGION 1
AUTHOR: BARNEY FRANK, US HOUSE OF REPRESENTATIVES
DOC ID: 213814 08/04/2004 2 PAGES
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SHPACK LANDFILL
ENTIRE SITE
ADMINISTRATIVE RECORD FILE
SHPACK OU1 ROD AR
14. CONGRESSIONAL RELATIONS (cont)
2. LETTER: COMMENTS ON THE PROPOSED CLEANUP PLAN FOR THE SHPACK
SUPERFUND SITE
TO: DAVID O LEDERER, US EPA REGION 1
AUTHOR: CHRISTOPHER QUINN, ATTLEBORO (MA) CITY OF
JAMES MOONEY, ATTLEBORO BOARD OF HEALTH
DOC ID: 213817 08/23/2004 2 PAGES
3. LETTER: COMMENTS ON THE PROPOSED CLEANUP PLAN FOR THE SHPACK
SUPERFUND SITE
TO: DAVID O LEDERER, US EPA REGION 1
AUTHOR: JOHN A LEPPER, MA HOUSE OF REPRESENTATIVES
DOC ID: 213819 08/23/2004 2 PAGES
4. LETTER: COMMENTS ON THE PROPOSED CLEANUP PLAN FOR THE SHPACK
SUPERFUND SITE
TO: DAVID O LEDERER, US EPA REGION 1
AUTHOR: FRANCIS J VEALE, SHPACK STEERING COMMITTEE
DOC ID: 213815 08/24/2004 20 PAGES
5. LETTER: COMMENTS ON THE PROPOSED CLEANUP PLAN FOR THE SHPACK
SUPERFUND SITE
TO: DAVID O LEDERER, US EPA REGION 1
AUTHOR: BARRY K LACASSE, ATTLEBORO (MA) CITY OF
DOC ID: 213816 08/24/2004 2 PAGES
6. LETTER: COMMENTS ON THE PROPOSED CLEANUP PLAN FOR THE SHPACK
SUPERFUND SITE
TO: WALTER J THIBODEAU, ATTLEBORO (MA) CITY OF
AUTHOR: WALTER J THIBODEAU, ATTLEBORO (MA) CITY OF
DOC ID: 213818 08/24/2004 1 PAGE
16. NATURAL RESOURCE TRUSTEE
1. LETTER: NO ENDANGERED SPECIES OCCUR IN PROJECT AREA
TO: CHRISTINE BLUNDELL, ENVIRONMENTAL RESOURCES MANAGEMENT
AUTHOR: GORDON E BECKETT, US DOI/US FISH & WILDLIFE SERVICE
DOC ID: 200423 10/15/1992 1 PAGE
2. LETTER: TRANSMITTAL OF REMEDIAL INVESTIGATION DOCUMENTS
TO: DALE YOUNG, MA DEPT OF ENVIRONMENTAL PROTECTION
KENNETH C CARR, US DOI/US FISH & WILDLIFE SERVICE
AUTHOR: DAVED O LEDERER, US EPA REGION 1
DOC ID: 200440 09/23/2002 1 PAGE
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SHPACK LANDFILL
ENTIRE SITE
ADMINISTRATIVE RECORD FILE
SHPACK OU1 ROD AR
SITE MANAGEMENT RECORDS
1. LETTER: NORTON ABANDONED INDUSTRIAL WASTE DISPOSAL AREA OFF
UNION ROAD
TO: JOHN SULLIVAN, ATTLEBORO (MA) RESIDENT
AUTHOR: JEFFREY GOULD E, DIVISION OF WATER POLLUTION CONTROL
DOC ID: 200444 09/13/1978 1 PAGE
2. LETTER: NORTON - SOLID WASTE DISPOSAL, ABANDONED INDUSTRIAL
WASTE LOCATED ON UNION ROAD ADJACENT TO ATTLEBORO LANDFILL
TO: NORTON (MA) BOARD OF HEALTH
AUTHOR: ROBERT P FAGAN, MA EXECUTIVE OFFICE OF ENVIRONMENTAL
AFFAIRS
DOC ID: 200442 09/29/1978 1 PAGE
3. MEMO : RADIATION INCIDENT - ATTLEBORO/NORTON
TO: GERALD PARKER S, MA DEPT OF PUBLIC HEALTH
AUTHOR: GEORGE SWIBLE, MA DEPT OF ENVIRONMENTAL PROTECTION
DOC ID: 200443 06/07/1979 4 PAGES
4. LETTER: PRELIMINARY REPORT OF EG&G AERIAL RADIOLOGICAL SURVEY OF
THE FORMER SHPACK LANDFILL
TO: RAYMOND PATENAUDE, NORTON BOARD OF SELECTMEN
AUTHOR: WILLIAM E MOTT, US DEPT OF ENERGY
DOC ID: 201270 01/07/1980 9 PAGES
5. REPORT: REPORT ON RESULTS OF ANALYSIS OF TEST WELL WATER AT
ATTLEBORO LANDFILL SITE
AUTHOR: DOUGLAS R SHEARER
DOC ID: 200457 03/10/1980 12 PAGES
6. LETTER: SHPACK/ATTLEBORO WASTE DISPOSAL SITES
TO: DAVID K HILL, NORTON CONSERVATION COMMISSION
AUTHOR: WILLIAM F CASS, MA DEPT OF ENVIRONMENTAL PROTECTION
DOC ID: 200445 04/03/1980 1 PAGE
7. LETTER: ATTLEBORO - SOLID WASTES - GROUNDWATER MONITORING
PROGRAM FOR ATTLEBORO LANDFILL INC, PECKHAM STREET
TO: GERALD J KEANE, ATTLEBORO (MA) TOWN OF
AUTHOR: MA DEPT OF ENVIRONMENTAL PROTECTION
DOC ID: 200446 12/09/1980 2 PAGES
-------
SHPACK LANDFILL
ENTIRE SITE
ADMINISTRATIVE RECORD FILE
SHPACK OU1 ROD AR
17. SITE MANAGEMENT RECORDS (cont)
8. LETTER: EXECUTED ACCESS AGREEMENT; FORMER SHPACK LANDFILL
FUSRAP SITE
TO: LEO G YELLE, NORTON CONSERVATION COMMISSION
AUTHOR: E L KELLER, US DEPT OF ENERGY
DOC ID: 200421 07/07/1981 5 PAGES
9. REPORT: GUIDANCE DOCUMENT FOR PROVIDING ALTERNATE WATER
SUPPLIES
AUTHOR: US EPA - OFFICE OF SOLID WASTE & EMERGENCY RESPONSE
DOC ID: 200424 02/01/1988 66 PAGES
10. LETTER: REQUEST FOR ADDITIONAL INFORMATION ON THE ATTLEBORO
LANDFILL CLOSURE PLAN TO: ALBERT DUMONT, ATTLEBORO LANDFILL INC
AUTHOR: DAVID B ELLIS, MA DEPT OF ENVIRONMENTAL PROTECTION
DOC ID: 200448 10/11/1994 7 PAGES
11. LETTER: COMMENTS ON THE ATTLEBORO LANDFILL INC (ALI) CLOSURE PLAN
TO: ROBERT JOHNSON, MA DEPT OF ENVIRONMENTAL PROTECTION
AUTHOR: FRANCIS J VEALE, SHPACK STEERING COMMITTEE
DOC ID: 200447 10/13/1994 6 PAGES
12. PHOTOGRAPH: SIX PHOTOS OF THE ATTLEBORO LANDFILL PERIMETER ROAD
TEST PITS, ALONG THE SHPACK BORDER
DOC ID: 200450 11/17/1994 2 PAGES
13. MISC : MEETING NOTES ON THE ATTLEBORO LANDFILL
AUTHOR: MA DEPT OF ENVIRONMENTAL PROTECTION
DOC ID: 200451 11/21/1994 6 PAGES
14. LETTER: REVIEW OF ERM'S COMMENTS ON THE ATTLEBORO LANDFILL INC
(ALI) CLOSURE PLAN
TO: VICKIE BLETSO, WRIGHT & MOEHRKE
AUTHOR: NEIL S SHIFRIN, GRADIENT CORPORATION
DOC ID: 200452 01/10/1995 6 PAGES
15. LETTER: RESPONSES TO ERM'S COMMENTS ON THE ATTLEBORO LANDFILL
INC (ALI) CLOSURE PLAN
TO: DAVID O LEDERER, US EPA REGION 1
ROBERT JOHNSON, MA DEPT OF ENVIRONMENTAL PROTECTION
AUTHOR: VICKIE BLETSO, WRIGHT & MOEHRKE
DOC ID: 200453 02/07/1995 2 PAGES
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SHPACK LANDFILL
ENTIRE SITE
ADMINISTRATIVE RECORD FILE
SHPACK OU1 ROD AR
17. SITE MANAGEMENT RECORDS (cont)
16. LETTER: RESPONSES TO WRIGHT & MOEHRKE'S CORRESPONDENCE TO EPA
AND DEP REGARDING THE ALI AND SHPACK LANDFILL
TO: FRANCIS J VEALE, SHPACK STEERING COMMITTEE
AUTHOR: DUANE A WANTY, ERM NEW ENGLAND INC
ROBERT J FOXEN, ERM NEW ENGLAND INC
DOC ID: 200454 02/27/1995 5 PAGES
17. LETTER: RESULTS OF ADDITIONAL FILE REVIEW OF ATTLEBORO LANDFILL
INC (ALI), DISCUSSION WITH DEP PROJECT MANAGER AND SITE VISIT
[PORTIONS BARELY LEGIBLE]
TO: FRANCIS J VEALE, SHPACK STEERING COMMITTEE
AUTHOR: DUANE A WANTY, ERM NEW ENGLAND INC
ROBERT J FOXEN, ERM NEW ENGLAND INC
DOC ID: 200455 07/02/1996 5 PAGES
18. LETTER: SHPACK STEERING COMMITTEE COMMENTS ON THE ATTLEBORO
LANDFILL CLOSURE DEFICIENCIES
TO: CATHY DORS, MA DEPT OF ENVIRONMENTAL PROTECTION
AUTHOR: DUANE A WANTY, ERM NEW ENGLAND INC
ROBERT J FOXEN, ERM NEW ENGLAND INC
DOC ID: 200456 09/30/1996 3 PAGES
19. WORK PLAN: SITE MANAGEMENT PLAN TO: SHPACK STEERING COMMITTEE
AUTHOR: ENVIRONMENTAL RESOURCES MANAGEMENT
DOC ID: 200422 12/01/2001 29 PAGES
20. REPORT: HISTORICAL AERIAL PHOTOGRAPHS (16) OF SHPACK LANDFILL,
WITH TRANSMITTAL LETTERS TO DAVID LEDERER, EPA REGION 1 ON 4/1/04
AND 4/15/04
AUTHOR: US EPA - ENVIRONMENTAL PHOTOGRAPHIC INTERPRETATION CTR
(EPIC)
DOC ID: 200478 04/01/2004 18 PAGES
21. REPORT: INTERIM HISTORICAL AERIAL PHOTOGRAPHIC ANALYSIS REPORT,
WITH TRANSMITTAL TO DAVID LEDERER, EPA REGION 1 ON 4/19/04
AUTHOR: US EPA - ENVIRONMENTAL PHOTOGRAPHIC INTERPRETATION CTR
(EPIC)
DOC ID: 200477 04/01/2004 12 PAGES
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SHPACK LANDFILL
ENTIRE SITE
ADMINISTRATIVE RECORD FILE
SHPACK OU1 ROD AR
RECORDS MANAGEMENT
1. INDEX : LIST OF GUIDANCE DOCUMENTS FOR SHPACK LANDFILL RECORD OF
DECISION (ROD) PROPOSED PLAN ADMINISTRATIVE RECORD
AUTHOR: US EPA REGION 1
DOC ID: 210631 05/05/2004 61 PAGES
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Supcii'und Records Center
GUIDANCE DOCUMENTS
OilihK: 2
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GUIDANCE DOCUMENTS
TITLE
GUIDELINES FOR HEALTH ASSESSMENT OF SUSPECT DEVELOPMENTAL TOXICANTS (FEDERAL
REGISTER, SEPTEMBER 24,1986, p. 34028)
DOC DATE OSWER/EPA ID DOC NUMBER
9/24/1986 5005
TITLE
GUIDELINES FOR MUTAGENICITY RISK ASSESSMENT (FEDERAL REGISTER, SEPTEMBER 24, p. 34000
DOC DATE OSWER/EPA ID DOC NUMBER
9/24/1986 5006
TITLE
PROTOCOL FOR GROUND-WATER EVALUATIONS
DOC DATE OSWER/EPA ID DOC NUMBER
9/1/1986 OSWER #9080.0-1 2406
TITLE
RCRA GROUND-WATER MONITORING TECHNICAL ENFORCEMENT GUIDANCE DOCUMENT(TEGD)
DOC DATE OSWER/EPA ID DOC NUMBER
9/1/1986 OSWER #99501 2407
TITLE
MANAGEMENT OF INVESTIGATION-DERIVED WASTES DURING SITE INSPECTIONS.
DOC DATE OSWER/EPA ID DOC NUMBER
5/1/1991 EPA/540/G-91/009 C189
TITLE
OPERATION AND MAINTENANCE INSPECTION GUIDE (RCRA GROUND-WATER MONITORING
SYSTEMS)
DOC DATE OSWER/EPA ID DOC NUMBER
3/30/1988 OSWER #9950-3 2405
TITLE
TECHNICAL GUIDANCE DOCUMENT: CONSTRUCTION QUALITY ASSURANCE FOR HAZARDOUS
WASTE LAND DISPOSAL FACILITIES
DOC DATE OSWER/EPA ID DOC NUMBER
10/1/1986 OSWER #9472.003 2211
TITLE
RCRA GUIDANCE DOCUMENT: LANDFILL DESIGN LINER SYSTEMS AND FINAL COVER (DRAFT)
DOC DATE OSWER/EPA ID DOC NUMBER
7/1/1982 2208
TITLE
LINING OF WASTE CONTAINMENT AND OTHER IMPOUNDMENT FACILITIES
DOC DATE OSWER/EPA ID DOC NUMBER
9/1/1988 EPA/600/2-88/052 2205
TITLE
COMPENDIUM OF SUPERFUND FIELD OPERATIONS METHODS
DOC DATE OSWER/EPA ID DOC NUMBER
12/1/1987 OSWER #9355.0-14 2100
Wednesday, May 05, 2004 Page 2
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GUIDANCE DOCUMENTS
TITLE
FIELD SCREENING METHODS CATALOG: USER'S GUIDE
DOC DATE OSWER/EPA ID DOC NUMBER
9/1/1988 EPA/540/2-88/005 2105
TITLE
HEALTH EFFECTS ASSESSMENT DOCUMENTS (58 CHEMICAL PROFILES)
DOC DATE OSWER/EPA ID DOC NUMBER
9/1/1984 EPA/540/1-86/001-058 5008
TITLE
INTEGRATED RISK INFORMATION SYSTEM (IRIS) [A COMPUTER-BASED HEALTH RISK
INFORMATION SYSTEM AVAILABLE THROUGI E-MAIL-BROCHURE ON ACCESS IS INCLUDED]
DOC DATE OSWER/EPA ID DOC NUMBER
5009
TITLE
PUBLIC HEALTH RISK EVALUATION DATABASE (PHRED) [USER'S MANUAL AND TWO DISKETTES
CONTAINING THE DBASE III PLUS SYSTEM ARE INCLUDED]
DOC DATE OSWER/EPA ID DOC NUMBER
9/16/1988 5011
TITLE
LABORATORY DATA VALIDATION FUNCTIONAL GUIDELINES FOR EVALUATING ORGANICS
ANALYSES (DRAFT)
DOC DATE OSWER/EPA ID DOC NUMBER
2/1/1988 2114
TITLE
LABORATORY DATA VALIDATION FUNCTIONAL GUIDELINES FOR EVALUATING INORGANICS
ANALYSES (DRAFT)
DOC DATE OSWER/EPA ID DOC NUMBER
7/1/1988 2113
TITLE
USER'S GUIDE TO THE CONTRACT LABORATORY PROGRAM
DOC DATE OSWER/EPA ID DOC NUMBER
12/1/1988 OSWER #9240.0-1 2119
TITLE
GUIDANCE MANUAL ON THE RCRA REGULATION OF RECYCLED HAZARDOUS WASTES
DOC DATE OSWER/EPA ID DOC NUMBER
3/1/1986 OSWER #9441.00-2 3004
TITLE
INTERIM RCRA/CERCLA GUIDANCE ON NON-CONTIGUOUS SITES AND ON-SITE MANAGEMENT OF
WASTE AND TREATMENT RESIDUE
DOC DATE OSWER/EPA ID DOC NUMBER
3/27/1986 OSWER #9347.0-1 3005
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Page 3
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GUIDANCE DOCUMENTS
TITLE
EXPANDED SITE INSPECTION (ESI) TRANSITIONAL GUIDANCE FOR FY-88
DOC DATE OSWER/EPA ID DOC NUMBER
10/1/1987 OSWER #9345.1-02 0001
TITLE
PRELIMINARY ASSESSMENT (PA) GUIDANCE FISCAL YEAR 1988
DOC DATE OSWER/EPA ID DOC NUMBER
1/1/1988 OSWER #9345.0-01 0002
TITLE
FIELD SCREENING FOR ORGANIC CONTAMINANTS IN SAMPLES FROM HAZARDOUS WASTE SITES
DOC DATE OSWER/EPA ID DOC NUMBER
4/2/1986 2104
TITLE
EPA GUIDE FOR MINIMIZING ADVERSE ENVIRONMENTAL EFFECTS OF CLEANUP OF
UNCONTROLLED HAZARDOUS-WASTE SITES
DOC DATE OSWER/EPA ID DOC NUMBER
6/1/1985 EPA/600/8-85/008 2001
TITLE
CERCLA REMOVAL ACTIONS AT METHANE RELEASE SITES
DOC DATE OSWER/EPA ID DOC NUMBER
!/23/1986 OSWER #9360.0-8 1000
TITLE
REMOVAL COST MANAGEMENT MANUAL
DOC DATE OSWER/EPA ID DOC NUMBER
4/1/1988 OSWER #9360.0-026 6001
TITLE
SUPERFUND REMOVAL PROCEDURES, REVISION # 3
DOC DATE OSWER/EPA ID DOC NUMBER
2/1/1988 OSWER #9360.0-036 1006
TITLE
EMERGENCY RESPONSE PROCEDURES FOR CONTROL OF HAZARDOUS SUBSTANCE RELEASES
DOC DATE OSWER/EPA ID DOC NUMBER
1/1/1983 EPA-600/D-84-023 1002
TITLE
ROLE OF EXPEDITED RESPONSE ACTIONS (EPA) UNDER SARA
DOC DATE OSWER/EPA ID DOC NUMBER
4/21/1987 OSWER #9360.0-15 1007
TITLE
INTERIM FINAL GUIDANCE ON REMOVAL ACTION LEVELS AT CONTAMINATED DRINKING WATER
SITES
DOC DATE OSWER/EPA ID DOC NUMBER
10/6/1987 OSWER #9360.1-01 4002
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Page 4
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GUIDANCE DOCUMENTS
TITLE
ENVIRONMENTAL REVIEW REQUIREMENTS FOR REMOVAL ACTIONS
DOC DATE OSWER/EPA ID DOC NUMBER
4/13/1987 OSWER #9318.0-05 1003
TITLE
INTERIM GUIDANCE ON SUPERFUND SELECTION OF REMEDY
DOC DATE OSWER/EPA ID DOC NUMBER
12/24/1986 OSWER #9355.0-19 9000
TITLE
GUIDANCE ON IMPLEMENTATION OF THE "CONTRIBUTE TO EFFICIENT REMEDIAL PERFORMANCE"
PROVISION
DOC DATE OSWER/EPA ID DOC NUMBER
4/6/1987 OSWER #9360.0-13 1004
TITLE
RCRA/CERCLA DECISIONS MADE ON REMEDY SELECTION
DOC DATE OSWER/EPA ID DOC NUMBER
6/24/1985 9001
TITLE
COMPENDIUM OF TECHNOLOGIES USED IN THE TREATMENT OF HAZARDOUS WASTES
DOC DATE OSWER/EPA ID DOC NUMBER
9/1/1987 EPA/625/8-87/014 2300
TITLE
ALTERNATE CONCENTRATION LIMIT GUIDANCE PART 1, ACL POLICY AND INFORMATION
REQUIREMENTS
DOC DATE OSWER/EPA ID DOC NUMBER
7/1/1987 OSWER #9481.00-6C 4000
TITLE
APPLICABILITY OF THE HSWA MINIMUM TECHNICAL REQUIREMENTS RESPECTING LINERS AND
LEACHATE COLLECTION SYSTEMS
DOC DATE OSWER/EPA ID DOC NUMBER
4/1/1985 OSWER #9480.01 (85) 3000
TITLE
CARBON ABSORPTION ISOTHERMS FOR TOXIC ORGANICS
DOC DATE OSWER/EPA ID DOC NUMBER
4/1/1980 EPA/600/8-80-023 2301
TITLE
COVERS FOR UNCONTROLLED HAZARDOUS WASTE SITES
DOC DATE OSWER/EPA ID DOC NUMBER
9/1/1985 EPA/540/2-85/002 2200
TITLE
DATA QUALITY OBJECTIVES FOR REMEDIAL RESPONSE ACTIVITIES: DEVELOPMENT PROCESS
DOC DATE OSWER/EPA ID DOC NUMBER
3/1/1987 EPA/540/G-87/003 2101
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GUIDANCE DOCUMENTS
TITLE
DATA QUALITY OBJECTIVES FOR REMEDIAL RESPONSE ACTIVITIES: EXAMPLE SCENARIO: RI/FS
ACTIVITIES AT A SITE W/CONTAMINATED SOILS AND GROUNDWATER
DOC DATE OSWER/EPA ID DOC NUMBER
3/1/1987 EPA/540/G-87/004 2102
TITLE
DESIGN AND DEVELOPMENT OF A HAZARDOUS WASTE REACTIVITY TESTING PROTOCOL
DOC DATE OSWER/EPA ID DOC NUMBER
2/1/1984 EPA-600/2-84-057 2103
TITLE
ENGINEERING HANDBOOK FOR HAZARDOUS WASTE INCINERATION
DOC DATE OSWER/EPA ID DOC NUMBER
9/1/1981 OSWER 09488.00-5 2302
TITLE
EPA GUIDE FOR INFECTIOUS WASTE MANAGEMENT
DOC DATE OSWER/EPA ID DOC NUMBER
5/1/1986 OSWER #9410.00-2 2304
TITLE
EVALUATING COVER SYSTEMS FOR SOLID AND HAZARDOUS WASTE
DOC DATE OSWER/EPA ID DOC NUMBER
9/1/1982 OSWER #9476.00-1 2202
TITLE
FIELD STANDARD OPERATING PROCEDURES MANUAL # 4-SITE ENTRY
DOC DATE OSWER/EPA ID DOC NUMBER
1/1/1985 OSWER 09285.2-01 2106
TITLE
FIELD STANDARD OPERATING PROCEDURES MANUAL # 6- WORK ZONES
DOC DATE OSWER/EPA ID DOC NUMBER
4/1/1985 OSWER #9285.2-04 2107
TITLE
FIELD STANDARD OPERATING PROCEDURES MANUAL # 8 AIR SURVEILLANCE
DOC DATE OSWER/EPA ID DOC NUMBER
1/1/1985 OSWER #9285.2-03 2108
TITLE
FIELD STANDARD OPERATING PROCEDURES MANUAL # 9- SITE SAFETY PLAN
DOC DATE OSWER/EPA ID DOC NUMBER
4/1/1985 OSWER #9285.2-05 2109
TITLE
GEOPHYSICAL METHODS FOR LOCATING ABANDONED WELLS
DOC DATE OSWER/EPA ID DOC NUMBER
7/1/1984 EPA-600/4-84-065 2110
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Page 6
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GUIDANCE DOCUMENTS
TITLE
GEOPHYSICAL TECHNIQUES FOR SENSING BURIED WASTES AND WASTE MIGRATION
DOC DATE OSWER/EPA ID DOC NUMBER
6/1/1984 EPA-600/7-84/064 2111
TITLE
GUIDANCE DOCUMENT FOR CLEANUP OF SURFACE IMPOUNDMENT SITES
DOC DATE OSWER/EPA ID DOC NUMBER
6/1/1986 OSWER #9380.0-06 2305
TITLE
GUIDANCE DOCUMENT FOR CLEANUP OF SURFACE TANK AND DRUM SITES
DOC DATE OSWER/EPA ID DOC NUMBER
5/28/1985 OSWER #9380.0-03 2306
TITLE
INTERIM FINAL GUIDANCE FOR CONDUCTING REMEDIAL INVESTIGATIONS AND FEASIBILITY
STUDIES UNDER CERCLA
DOC DATE OSWER/EPA ID DOC NUMBER
10/1/1988 OSWER #9355.3-01 2002
TITLE
GUIDANCE MANUAL FOR MINIMIZING POLLUTION FROM WASTE DISPOSAL SITES
DOC DATE OSWER/EPA ID DOC NUMBER
8/1/1978 EPA-600/2-78-142 2203
TITLE
GUIDELINES AND SPECIFICATIONS FOR PREPARING QUALITY ASSURANCE PROGRAM
DOCUMENTATION
DOC DATE OSWER/EPA ID DOC NUMBER
6/1/1987 2112
TITLE
HANDBOOK FOR EVALUATING REMEDIAL ACTION TECHNOLOGY PLANS
DOC DATE OSWER/EPA ID DOC NUMBER
8/1/1983 EPA-600/2-83-076 2307
TITLE
HANDBOOK FOR STABILIZATION/SOLIDIFICATION OF HAZARDOUS WASTE
DOC DATE OSWER/EPA ID DOC NUMBER
6/1/1986 EPA/540/2-86-001 2308
TITLE
LEACHATE PLUME MANAGEMENT
DOC DATE OSWER/EPA ID DOC NUMBER
11/1/1985 EPA/540/2-85/004 2310
TITLE
LINING OF WASTE IMPOUNDMENT AND DISPOSAL FACILITIES
DOC DATE OSWER/EPA ID DOC NUMBER
3/1/1983 OSWER #9480.00-4 2206
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GUIDANCE DOCUMENTS
TITLE
MOBILE TREATMENT TECHNOLOGIES FOR SUPERFUND WASTES
DOC DATE OSWER/EPA ID DOC NUMBER
9/1/1986 EPA/540/2-86-003F 2311
TITLE
PRACTICAL GUIDE- TRIAL BURNS FOR HAZARDOUS WASTE INCINERATORS
DOC DATE OSWER/EPA ID DOC NUMBER
4/1/1986 EPA/600/2-86/050 2312
TITLE
PRACTICAL GUIDE- TRIAL BURNS FOR HAZARDOUS WASTE INCINERATORS, PROJECT SUMMARY
DOC DATE OSWER/EPA ID DOC NUMBER
7/1/1986 EPA/600/S2-86/05C 2313
TITLE
PROCEDURES FOR MODELING FLOW THROUGH CLAY LINERS TO DETERMINE REQUIRED LINER
THICKNESS (DRAFT)
DOC DATE OSWER/EPA ID DOC NUMBER
1/1/1984 OSWER #9480.00-90 2207
TITLE
PROHIBITION ON THE PLACEMENT OF BULK LIQUID HAZARDOUS WASTE IN LANDFILLS-
STATUTORY INTERPRETIVE GUIDANCE
DOC DATE OSWER/EPA ID DOC NUMBER
6/11/1986 OSWER #9487.00-2A 2314
TITLE
REVIEW OF IN-PLACE TREATMENT TECHNIQUES FOR CONTAMINATED SURFACE SOILS- VOL. 1:
TECHNICAL EVALUATION
DOC DATE OSWER/EPA ID
9/19/1984 EPA/540/2-84-003a
TITLE
RI/FS IMPROVEMENTS
DOC DATE OSWER/EPA ID
7/23/1987 OSWER #9355.0-20
TITLE
RI/FS IMPROVEMENTS FOLLOW-UP
DOC DATE OSWER/EPA ID DOC NUMBER
4/25/1988 OSWER #9355.3-05 2009
TITLE
SEDIMENT SAMPLING QUALITY ASSURANCE USER'S GUIDE
DOC DATE OSWER/EPA ID DOC NUMBER
7/1/1985 EPA/600/4-85/046 2116
TITLE
SETTLEMENT AND COVER SUBSIDENCE OF HAZARDOUS WASTE LANDFILLS
DOC DATE OSWER/EPA ID DOC NUMBER
5/1/1985 EPA-600/S2-85-035 2209
Wednesday, May 05, 2004
DOC NUMBER
2316
DOC NUMBER
2008
: PROJECT SUMMARY
Page 7
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GUIDANCE DOCUMENTS
TITLE
SLURRY TRENCH CONSTRUCTION FOR POLLUTION MIGRATION CONTROL
DOC DATE OSWER/EPA ID DOC NUMBER
2/1/1984 EPA/540/2-84-001 2317
TITLE
SOIL SAMPLING QUALITY ASSURANCE USER'S GUIDE SUPERSEDED BY C091 IN REGIONAL
COMPENDIUM
DOC DATE OSWER/EPA ID DOC NUMBER
5/1/1984 EPA 600/4-B4/043 2117
TITLE
SUPPLEMENTARY GUIDANCE ON DETERMINING LINER/LEACHATE COLLECTION SYSTEM
COMPATIBILITY
DOC DATE OSWER/EPA ID DOC NUMBER
8/7/1986 OSWER #9480.00-13 2210
TITLE
SYSTEMS TO ACCELERATE IN SITU STABILIZATION OF WASTE DEPOSITS
DOC DATE OSWER/EPA ID DOC NUMBER
9/1/1986 EPA 540/2-86/002 2318
TITLE
TEST METHODS FOR EVALUATING SOLID WASTE, LABORATORY MANUAL PHYSICAL/CHEMICAL
METHODS, THIRD EDITION (VOLUMES IA, IB, 1C, AND II)
DOC DATE OSWER/EPA ID DOC NUMBER
11/1/1986 2118
TITLE
TREATMENT OF REACTIVE WASTES AT HAZARDOUS WASTE LANDFILLS PROJECT SUMMARY
DOC DATE OSWER/EPA ID DOC NUMBER
1/1/1984 EPA/600/S2-83/118 2212
TITLE
TREATMENT TECHNOLOGY BRIEFS: ALTERNATIVES TO HAZARDOUS WASTE LANDFILLS
DOC DATE OSWER/EPA ID DOC NUMBER
7/1/1986 EPA/600/8-86/017 2320
TITLE
TECHNOLOGY SCREENING GUIDE FOR TREATMENT OF CERCLA SOILS AND SLUDGES
DOC DATE OSWER/EPA ID DOC NUMBER
9/1/1988 EPA 540/2-88/004 2319
TITLE
COSTS OF REMEDIAL RESPONSE ACTIONS AT UNCONTROLLED HAZARDOUS WASTE SITES
DOC DATE OSWER/EPA ID DOC NUMBER
1/1/1981 1001
TITLE
REMEDIAL ACTION COSTING PROCEDURES MANUAL
DOC DATE OSWER/EPA ID DOC NUMBER
10/1/1987 6000
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GUIDANCE DOCUMENTS
TITLE
GUIDANCE DOCUMENT FOR PROVIDING ALTERNATE WATER SUPPLIES
DOC DATE OSWER/EPA ID DOC NUMBER
2/1/1988 OSWER #9355.3-03 4001
TITLE
INFORMATION ON DRINKING WATER ACTION LEVELS
DOC DATE OSWER/EPA ID DOC NUMBER
4/19/1988 1005
TITLE
PRACTICAL GUIDE FOR GROUND-WATER SAMPLING
DOC DATE OSWER/EPA ID DOC NUMBER
9/1/1985 EPA/600/2-85/104 2115
TITLE
CRITERIA FOR IDENTIFYING AREAS OF VULNERABLE HYDROGEOLOGY UNDER RCRA: STATUTORY
INTERPRETIVE GUIDANCE
DOC DATE OSWER/EPA ID DOC NUMBER
7/1/1986 OSWER #9472.00-2A 2400
TITLE
FINAL RCRA COMPREHENSIVE GROUND-WATER MONITORING EVALUATION (CME) GUIDANCE
DOCUMENT
DOC DATE OSWER/EPA ID DOC NUMBER
12/19/1986 OSWER #9950.2 2401
TITLE
GROUND-WATER MONITORING AT CLEAN-CLOSING SURFACE IMPOUNDMENT AND WASTE PILE
UNITS
DOC DATE OSWER/EPA ID DOC NUMBER
3/31/1988 OSWER #9476.00-14 2402
TITLE
RCRA GROUND-WATER MONITORING TECHNICAL ENFORCEMENT GUIDANCE DOCUMENT, TEGD:
EXECUTIVE SUMMARY
DOC DATE OSWER/EPA ID DOC NUMBER
7/1/1987 OSWER #9950.1-a 2408
TITLE
SUPERFUND FEDERAL-LEAD REMEDIAL PROJECT MANAGEMENT HANDBOOK (DRAFT)
DOC DATE OSWER/EPA ID DOC NUMBER
12/1/1986 OSWER 09355.1-1 2010
TITLE
HANDBOOK REMEDIAL ACTION AT WASTE DISPOSAL SITES (REVISED)
DOC DATE OSWER/EPA ID DOC NUMBER
10/1/1985 EPA/625/6-85/006 2309
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GUIDANCE DOCUMENTS
TITLE
LAND DISPOSAL RESTRICTIONS
DOC DATE OSWER/EPA ID DOC NUMBER
8/11/1987 2204
TITLE
MODELING REMEDIAL ACTIONS AT UNCONTROLLED HAZARDOUS WASTE SITES (VOL. I-IV)
DOC DATE OSWER/EPA ID DOC NUMBER
4/1/1985 OSWER #9355.0-08 2004
TITLE
REVIEW OF IN-PLACE TREATMENT TECHNIQUES FOR CONTAMINATED SURFACE SOILS- VOL 2:
BACKGROUND INFORMATION FOR IN-SITU TREATMENT
DOC DATE OSWER/EPA ID DOC NUMBER
11/1/1984 EPA-540/2-84-0035 2315
TITLE
SUPERFUND REMEDIAL DESIGN AND REMEDIAL ACTION GUIDANCE
DOC DATE OSWER/EPA ID DOC NUMBER
6/1/1986 OSWER #9355.0-4A 2011
TITLE
CASE STUDIES 1-23: REMEDIAL RESPONSE AT HAZARDOUS WASTE SITES
DOC DATE OSWER/EPA ID DOC NUMBER
3/1/1984 EPA 540/2-84/002B 2000
TITLE
REMEDIAL RESPONSE AT HAZARDOUS WASTE SITES: SUMMARY REPORT
DOC DATE OSWER/EPA ID DOC NUMBER
3/1/1984 EPA 540/2-84/002A 2006
TITLE
REVISED PROCEDURES FOR IMPLEMENTING OFF-SITE RESPONSE ACTION?
DOC DATE OSWER/EPA ID DOC NUMBER
11/13/1987 OSWER #9834.11 2007
TITLE
SUPERFUND STATE-LEAD REMEDIAL PROJECT MANAGEMENT HANDBOOK
DOC DATE OSWER/EPA ID DOC NUMBER
12/1/1986 OSWER #9355.2-1 2012
TITLE
ATSDR HEALTH ASSESSMENTS ONNPL SITES (DRAFT)
DOC DATE OSWER/EPA ID DOC NUMBER
6/16/1986 5000
TITLE
FINAL GUIDANCE FOR THE COORDINATION OF ATSDR HEALTH ASSESSMENT ACTIVITIES WITH THE
SUPERFUND REMEDIAL PROCESS
DOC DATE OSWER/EPA ID DOC NUMBER
5/14/1987 OSWER #9285.4-02 5002
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GUIDANCE DOCUMENTS
TITLE
JOINT CORPS/EPA GUIDANCE
DOC DATE OSWER/EPA ID DOC NUMBER
6/24/1983 OSWER #9295.2-02 2003
TITLE
POLICY ON FLOOD PLAINS AND WETLAND ASSESSMENTS FOR CERCLA ACTIONS
DOC DATE OSWER/EPA ID DOC NUMBER
8/1/1985 OSWER #9280.0-02 2005
TITLE
EPA'S IMPLEMENTATION OF THE SUPERFUND AMENDMENTS AND REAUTHORIZATION ACT OF 1981
DOC DATE OSWER/EPA ID DOC NUMBER
5/21/1987 3003
TITLE
CERCLA COMPLIANCE WITH OTHER ENVIRONMENTAL STATUTES
DOC DATE OSWER/EPA ID DOC NUMBER
10/2/1985 OSWER #9234.0-2 3001
TITLE
CERCLA COMPLIANCE WITH OTHER LAWS MANUAL (DRAFT)
DOC DATE OSWER/EPA ID DOC NUMBER
8/8/1988 OSWER #9234.1-01 3002
TITLE
INTERIM GUIDANCE ON POTENTIALLY RESPONSIBLE PARTY PARTICIPATION IN REMEDIAL
INVESTIGATIONS AND FEASIBILITY STUDIES
DOC DATE OSWER/EPA ID DOC NUMBER
5/16/1988 OSWER #9835.la 8001
TITLE
COMMUNITY RELATIONS IN SUPERFUND: A HANDBOOK (INTERIM VERSION). INCLUDES CHAPTER
6, DATED 11/03/88.
DOC DATE OSWER/EPA ID DOC NUMBER
6/1/1988 OSWER #9230.0-038 7000
TITLE
ENDANGERMENT ASSESSMENT GUIDANCE
DOC DATE OSWER/EPA ID DOC NUMBER
11/22/1986 OSWER #9850.0-1 8000
TITLE
SUPERFUND EXPOSURE ASSESSMENT MANUAL
DOC DATE OSWER/EPA ID DOC NUMBER
4/1/1988 OSWER #9285.5-1 5013
TITLE
SUPERFUND PUBLIC HEALTH EVALUATION MANUAL
DOC DATE OSWER/EPA ID DOC NUMBER
10/1/1986 OSWER #9285.4-1 5014
Wednesday, May 05, 2004
Page 9
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GUIDANCE DOCUMENTS
TITLE
CHEMICAL. PHYSICAL & BIOLOGICAL PROPERTIES OF COMPOUNDS PRESENT AT HAZARDOUS
WASTE SITES
DOC DATE OSWER/EPA ID DOC NUMBER
9/27/1985 OSWER #9850.3 5001
TITLE
TOXICOLOGY HANDBOOK
DOC DATE OSWER/EPA ID DOC NUMBER
8/1/1985 OSWER #9850.2 5015
TITLE
INTERIM POLICY FOR ASSESSING RISKS OF "DIOXINS" OTHER THAN 2.3,7,8-TCDD
DOC DATE OSWER/EPA ID DOC NUMBER
1/7/1987 5010
TITLE
INDEX TO COMPENDIUM OF CERCLA RESPONSE SELECTION GUIDANCE DOCUMENTS
DOC DATE OSWER/EPA ID DOC NUMBER
5/1/1989 0000
TITLE
GUIDANCE ON NON-NPL REMOVAL ACTIONS INVOLVING NATIONALLY SIGNIFICANT OR
PRECEDENT SETTING ISSUES
DOC DATE OSWER/EPA ID DOC NUMBER
4/3/1989 OSWER #9360.0-19 1008
TITLE
ADVANCING THE USE OF TREATMENT TECHNOLOGIES FOR SUPERFUND REMEDIES
DOC DATE OSWER/EPA ID DOC NUMBER
2/21/1989 OSWER #9355.0-26 2321
TITLE
RI/FS IMPROVEMENTS PHASE II, STREAMLINING RECOMMENDATIONS
DOC DATE OSWER/EPA ID DOC NUMBER
1/1/1989 OSWER #9355.3-06 2017
TITLE
CERCLA COMPLIANCE WITH OTHER LAWS MANUAL PART II: CLEAN AIR ACT AND OTHER
ENVIRONMENTAL STATUTES AND STATE REQUIREMENTS
DOC DATE OSWER/EPA ID DOC NUMBER
8/1/1989 OSWER #9234.1-02 3013
TITLE
INTERIM GUIDANCE ON ESTABLISHING SOIL LEAD CLEANUP LEVELS AT SUPERFUND SITES
DOC DATE OSWER/EPA ID DOC NUMBER
9/1/1989 OSWER #9355.4-02 3015
Wednesday, May 05, 2004
Page
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GUIDANCE DOCUMENTS
TITLE
RISK ASSESSMENT GUIDANCE FOR SUPERFUND, VOLUME I, HUMAN HEALTH EVALUATION
MANUAL
DOC DATE OSWER/EPA ID DOC NUMBER
9/29/1989 OSWER #9285.7-01a 5023
TITLE
RISK ASSESSMENT GUIDANCE FOR SUPERFUND, VOLUME II. ENVIRONMENTAL EVALUATION
MANUAL
DOC DATE OSWER/EPA ID DOC NUMBER
3/1/1989 EPA/540/1-69/001 5024
TITLE
TECHNOLOGICAL APPROACHES TO THE CLEANUP OF RADIOLOGICALLY CONTAMINATED
SUPERFUND SITES
DOC DATE OSWER/EPA ID DOC NUMBER
8/1/1988 EPA/540/2-88/002 2328
TITLE
TREATMENT STANDARDS AND MINIMUM TECHNOLOGY REQUIREMENTS UNDER LAND DISPOSAL
RESTRICTIONS (LDR)
DOC DATE OSWER/EPA ID DOC NUMBER
7/1/1989 OSWER #9347.3-03FS 3018
TITLE
TOXICOLOGICAL PROFILE FOR 2, 3, 7, 8 -TETRACHLORO-DIBENZO-P-DIOXIN
DOC DATE OSWER/EPA ID DOC NUMBER
6/1/1989 5027
TITLE
GUIDANCE ON REMEDIAL ACTIONS FOR CONTAMINATED GROUND WATER AT SUPERFUND SITES
DOC DATE OSWER/EPA ID DOC NUMBER
12/1/1986 OSWER #9283.1-2 2413
TITLE
GUIDE TO TREATMENT TECHNOLOGIES FOR HAZARDOUS WASTES AT SUPERFUND SITES
DOC DATE OSWER/EPA ID DOC NUMBER
3/1/1989 EPA/540/2-89/052 2322
TITLE
LAND DISPOSAL RESTRICTIONS AS RELEVANT AND APPROPRIATE REQUIREMENTS FOR CERCLA
CONTAMINATED SOIL AND DEBRIS
DOC DATE OSWER/EPA ID DOC NUMBER
6/5/1989 OSWER 09347.2-01 3016
TITLE
OPTIONS FOR INTERIM POLICY FOR SOIL INGESTION ASSUMPTIONS
DOC DATE OSWER/EPA ID DOC NUMBER
10/4/1988 5022
Wednesday, May 05, 2004
Page 11
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GUIDANCE DOCUMENTS
TITLE
CONSIDERATIONS IN GROUND WATER REMEDIATION AT SUPERFUND SITES
DOC DATE OSWER/EPA ID DOC NUMBER
10/18/1989 OSWER #9355.4-03 2410
TITLE
MODEL STATEMENT OF WORK FOR A REMEDIAL INVESTIGATION AND FEASIBILITY STUDY
CONDUCTED BY POTENTIALLY RESPONSIBLE PARTIES
DOC DATE OSWER/EPA ID DOC NUMBER
6/2/1989 OSWER #9835.8 2016
TITLE
GUIDANCE FOR SOIL INGESTION RATES
DOC DATE OSWER/EPA ID DOC NUMBER
!/27/1989 OSWER #9850.4 5021
TITLE
EXPOSURE FACTORS HANDBOOK
DOC DATE OSWER/EPA ID DOC NUMBER
7/1/1989 EPA/600/8-89/043 5020
TITLE
TOXICOLOGICAL PROFILE FOR BENZENE
DOC DATE OSWER/EPA ID DOC NUMBER
5/1/1989 5029
TITLE
TOXICOLOGICAL PROFILE FOR HEPTACHLOR/HEPTACHLOR EPOXIDE
DOC DATE OSWER/EPA ID DOC NUMBER
4/1/1989 5035
TITLE
TOXICOLOGICAL PROFILE FOR 1,4-DICHLOROBENZENE
DOC DATE OSWER/EPA ID DOC NUMBER
1/1/1989 5026
TITLE
TOXICOLOGICAL PROFILE FOR DI(2-ETHYLHEXYL) PHTHALATE
DOC DATE OSWER/EPA ID DOC NUMBER
4/1/1989 5034
TITLE
TOXICOLOGICAL PROFILE FOR CHLOROFORM
DOC DATE OSWER/EPA ID DOC NUMBER
1/1/1989 5032
TITLE
TOXICOLOGICAL PROFILE FOR CADMIUM
DOC DATE OSWER/EPA ID DOC NUMBER
3/1/1989 5031
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GUIDANCE DOCUMENTS
TITLE
TOXICOLOGICAL PROFILE FOR CHROMIUM
DOC DATE OSWER/EPA ID DOC NUMBER
7/1/1989 5033
TITLE
TOXICOLOGICAL PROFILE FOR N-NITRO SODIPHENYLAMINE
DOC DATE OSWER/EPA ID DOC NUMBER
12/1/1988 5037
TITLE
TOXICOLOGICAL PROFILE FOR SELECTED PCBs (AROCLOR-1260, -1254, -1248, -1242, -1232, -1221, AND
-1010
DOC DATE OSWER/EPA ID DOC NUMBER
6/1/1989 5039
TITLE
TOXICOLOGICAL PROFILE FOR METHYLENE CHLORIDE
DOC DATE OSWER/EPA ID DOC NUMBER
4/1/1989 5036
TITLE
TOXICOLOGICAL PROFILE FOR TRICHLOROETHYLENE
DOC DATE OSWER/EPA ID DOC NUMBER
10/1/1989 5040
TITLE
TOXICOLOGICAL PROFILE FOR NICKEL
DOC DATE OSWER/EPA ID DOC NUMBER
12/1/1988 5038
TITLE
TOXICOLOGICAL PROFILE FOR VINYL CHLORIDE
DOC DATE OSWER/EPA ID DOC NUMBER
8/1/1989 5041
TITLE
TOXICOLOGICAL PROFILE FOR BERYLLIUM
DOC DATE OSWER/EPA ID DOC NUMBER
12/1/1988 5030
TITLE
TOXICOLOGICAL PROFILE FOR ARSENIC
DOC DATE OSWER/EPA ID DOC NUMBER
3/1/1989 5028
TITLE
EVALUATION OF GROUND-WATER EXTRACTION REMEDIES- VOLUME 1 SUMMARY REPORT
DOC DATE OSWER/EPA ID DOC NUMBER
9/1/1989 EPA/540/2-89/054 2412
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GUIDANCE DOCUMENTS
TITLE
DETERMINING SOIL RESPONSE ACTION LEVELS BASED ON POTENTIAL CONTAMINANT MIGRATION
TO GROUNDWATER A COMPENDIUM OF EXAMPLES
DOC DATE OSWER/EPA ID DOC NUMBER
10/1/1989 EPA/540/2-89/057 2411
TITLE
GUIDE FOR CONDUCTING TREATABILITY STUDIES UNDER CERCLA, INTERIM FINAL,
DOC DATE OSWER/EPA ID DOC NUMBER
12/1/1989 EPA/540/2-89/058 2015
TITLE
GUIDE TO SELECTING SUPERFUND REMEDIAL ACTIONS
DOC DATE OSWER/EPA ID DOC NUMBER
4/1/1990 OSWER 09355.0-27FS 9002
TITLE
SUPERFUND LDR GUIDE #1 OVERVIEW OF RCRA LAND DISPOSAL RESTRICTIONS (LDRs)
DOC DATE OSWER/EPA ID DOC NUMBER
7/1/1989 OSWER #9347.3-01FS 2214
TITLE
SUPERFUND LDR GUIDE #2 COMPLYING WITH THE CALIFORNIA LIST RESTRICTIONS UNDER LAND
DISPOSAL RESTRICTIONS (LDRs)
DOC DATE OSWER/EPA ID DOC NUMBER
7/1/1989 OSWER 39347.3-02FS 2215
TITLE
RESTRICTIONS (LDRs)
DOC DATE OSWER/EPA ID DOC NUMBER
7/1/1989 OSWER 09347.3-03FS 2216
TITLE
SUPERFUND LDR GUIDE #4 COMPLYING WITH THE HAMMER RESTRICTIONS UNDER LAND
DISPOSAL RESTRICTIONS (LDRs)
DOC DATE OSWER/EPA ID DOC NUMBER
7/1/1989 OSWER S9347.3-04FS 2217
TITLE
SUPERFUND LDR GUIDE #5 DETERMINING WHEN LAND DISPOSAL RESTRICTIONS (LDRs) ARE
APPLICABLE TO CERCLA RESPONSE ACTIONS
DOC DATE OSWER/EPA ID DOC NUMBER
7/1/1989 OSWER #9347.3-05FS 2218
TITLE
SUPERFUND LDR GUIDE #6A OBTAINING A SOIL AND DEBRIS TREATABILITY VARIANCE FOR
REMEDIAL ACTIONS
DOC DATE OSWER/EPA ID DOC NUMBER
7/1/1969 OSWER #9347.3-06FS 2219
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GUIDANCE DOCUMENTS
TITLE
SUPER RESPONSE ACTIONS
DOC DATE OSWER/EPA ID DOC NUMBER
12/1/1986 OSWER #9347.3-08FS 2220
TITLE
MANAGEMENT REVIEW: RECOMMENDATION NO.26
DOC DATE OSWER/EPA ID DOC NUMBER
12/27/1989 OSWER #9234.1-06 2213
TITLE
INNOVATIVE TECHNOLOGY - SOIL WASHING [QUICK REFERENCE FACT SHEET]
DOC DATE OSWER/EPA ID DOC NUMBER
11/1/1989 OSWER #9200.5-250FS 2327
TITLE
INNOVATIVE TECHNOLOGY - IN-SITU VITRIFICATION [QUICK REFERENCE FACT SHEET]
DOC DATE OSWER/EPA ID DOC NUMBER
11/1/1989 OSWER #9200.5-251FS 2325
TITLE
INNOVATIVE TECHNOLOGY - SLURRY-PHASE BIODEGRADATION [QUICK REFERENCE FACT SHEET]
DOC DATE OSWER/EPA ID DOC NUMBER
11/1/1989 OSWER #200.5-252FS 2326
TITLE
INNOVATIVE TECHNOLOGY - GLYCOLATE DEHALOGENATION [QUICK REFERENCE FACT SHEET]
DOC DATE OSWER/EPA ID DOC NUMBER
11/1/1989 OSWER #9200.5-254FS 2324
TITLE
INNOVATIVE TECHNOLOGY - BEST SOLVENT EXTRACTION PROCESS [QUICK REFERENCE FACT
SHEET]
DOC DATE OSWER/EPA ID DOC NUMBER
11/1/1989 OSWER #9200.5-253FS 2323
TITLE
GUIDE ON REMEDIAL ACTIONS FOR CONTAMINATED GROUND WATER [QUICK REFERENCE FACT
SHEET]
DOC DATE OSWER/EPA ID DOC NUMBER
4/1/1989 OSWER #92831-2FS 2409
TITLE
CERCLA COMPLIANCE WITH OTHER LAWS MANUAL - SUMMARY OF PART II - CAA, TSCA, AND
OTHER STATUTES [QUICK REFERENCE FACT SHEET]
DOC DATE OSWER/EPA ID DOC NUMBER
4/1/1990 OSWER #9234.2-07FS 3012
TITLE
ARARs SHORT GUIDANCE QUARTERLY REPORT [QUICK REFERENCE FACT SHEET)
DOC DATE OSWER/EPA ID DOC NUMBER
12/1/1989 OSWER #9234.3-001 3007
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GUIDANCE DOCUMENTS
TITLE
ARARs SHORT GUIDANCE QUARTERLY REPORT [QUICK REFERENCE FACT SHEET]
DOC DATE OSWER/EPA ID DOC NUMBER
3/1/1990 OSWER #9234.3-001 3008
TITLE
CERCLA COMPLIANCE WITH OTHER LAWS MANUAL RCRA ARARS FOCUS ON CLOSURE
REQUIREMENTS
DOC DATE OSWER/EPA ID DOC NUMBER
10/1/1986 OSWER #9234.2-04FS 3017
TITLE
ARARs Q'S & A'S [QUICK REFERENCE FACT SHEET]
DOC DATE OSWER/EPA ID DOC NUMBER
5/1/1989 OSWER #9234.2-01 FS 3006
TITLE
CERCLA COMPLIANCE WITH OTHER LAWS MANUAL - CERCLA COMPLIANCE WITH STATE
REQUIREMENTS [QUICK REFERENCE FACT SHEET]
DOC DATE OSWER/EPA ID DOC NUMBER
12/1/1969 OSWER #9234.2-05FS 3009
TITLE
CERCLA COMPLIANCE WITH OTHER LAWS MANUAL - OVERVIEW OF ARARs - FOCUS ON ARAR
WAIVERS [QUICK REFERENCE FACT SHEET)
DOC DATE OSWER/EPA ID DOC NUMBER
12/1/1989 OSWER #9234.2-03FS 3011
TITLE
CERCLA COMPLIANCE WITH OTHER LAWS MANUAL - CERCLA COMPLIANCE WITH THE CWA AND
SDWA [QUICK REFERENCE FACT SHEET]
DOC DATE OSWER/EPA ID DOC NUMBER
2/1/1990 OSWER #9234.2-06FS 3010
TITLE
CONTROL OF AIR EMISSIONS FROM SUPERFUND AIR STRIPPERS AT SUPERFUND GROUNDWATER
SITES
DOC DATE OSWER/EPA ID DOC NUMBER
6/15/1989 OSWER #9533.0-28 3014
TITLE
GETTING READY - SCOPING THE RI/FS [QUICK REFERENCE FACT SHEET]
DOC DATE OSWER/EPA ID DOC NUMBER
11/1/1989 OSWER #9355.3-01FSl 2013
TITLE
REMEDIAL INVESTIGATION - SITE CHARACTERIZATION AND TREATABILITY STUDIES [QUICK
REFERENCE FACT SHEET]
DOC DATE OSWER/EPA ID DOC NUMBER
11/1/1989 OSWER #9355.3-01FS2 5025
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Page 16
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GUIDANCE DOCUMENTS
TITLE
FEASIBILITY STUDY - DEVELOPMENT AND SCREENING OF REMEDIAL ACTION ALTERNATIVES
[QUICK REFERENCE FACT SHEET]
DOC DATE OSWER/EPA ID DOC NUMBER
11/1/1989 OSWER #9355.3-01FS3 2018
TITLE
FEASIBILITY STUDY DETAILED ANALYSIS OF REMEDIAL ACTION ALTERNATIVES [QUICK
REFERENCE FACT SHEET]
DOC DATE OSWER/EPA ID DOC NUMBER
3/1/1990 OSWER #9355.3-01FS4 2019
TITLE
TREATABILITY STUDIES UNDER CERCLA AN OVERVIEW [QUICK REFERENCE FACT SHEET]
DOC DATE OSWER/EPA ID DOC NUMBER
12/1/1989 OSWER #9380.3-02FS 2020
TITLE
GUIDANCE ON REMEDIAL ACTIONS FOR SUPERFUND SITES WITH PCB CONTAMINATION
DOC DATE OSWER/EPA ID DOC NUMBER
8/1/1990 OSWER #9355.4-01 2014
TITLE
AIR/SUPERFUND NATIONAL TECHNICAL GUIDANCE STUDY SERIES VOLUME I - APPLICATION OF
AIR PATHWAY ANALYSES FOR SUPERFUND ACTIVITIES
DOC DATE OSWER/EPA ID DOC NUMBER
12/1/1988 5016
TITLE
AIR/SUPERFUND NATIONAL TECHNICAL GUIDANCE STUDY SERIES VOLUME II - ESTIMATION OF
BASELINE AIR EMISSIONS AT SUPERFUND SITES
DOC DATE OSWER/EPA ID DOC NUMBER
1/1/1989 EPA/450/1-89/002 5017
TITLE
AIR/SUPERFUND NATIONAL TECHNICAL GUIDANCE STUDY SERIES VOLUME III - ESTIMATION OF
AIR EMISSIONS FROM CLEANUP ACTIVITIES AT SUPERFUND SITES
DOC DATE OSWER/EPA ID DOC NUMBER
1/1/1989 EPA/450/1-89/003 5018
TITLE
AIR/SUPERFUND NAT'L TECHNICAL GUIDANCE STUDY SERIES - VOLUME IV PROCEDURES FOR
DISPERSION MODELING AND AIR MONITORING FOR AIR PATHWAY ANALYSES (DRAFT)
DOC DATE OSWER/EPA ID DOC NUMBER
12/1/1988 5019
TITLE
ADDITIONAL INTERIM GUIDANCE FOR FISCAL YEAR 1987 RECORDS OF DECISION. FINAL
DOC DATE OSWER/EPA ID DOC NUMBER
7/24/1987 OSWER #9355.0-21 C001
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GUIDANCE DOCUMENTS
TITLE
ANALYSIS OF RCRA CLOSURE OPTIONS FOR SUPERFUND SITES IN SUPERFUND 1987: PROCEEDINGS
OF THE 8TH NATIONAL CONFERENCE.
DOC DATE OSWER/EPA ID DOC NUMBER
C002
TITLE
PROTECTION OF WETLANDS: EXECUTIVE ORDER 11990. 42 FED. REG. 26961 (1977).
DOC DATE OSWER/EPA ID DOC NUMBER
5/24/1977 C003
TITLE
BIODEGRADATION AND TREATABILITY OF SPECIFIC POLLUTANTS.
DOC DATE OSWER/EPA ID DOC NUMBER
10/1/1979 EPA 600/9-79-034 C007
TITLE
CERCLA COMPLIANCE WITH OTHER LAWS MANUAL DRAFT GUIDANCE. SUPERSEDED BY 3002.
DOC DATE OSWER/EPA ID DOC NUMBER
5/6/1988 OSWER #9234.1-01 C009
TITLE
COMMUNITY RELATIONS IN SUPERFUND: A HANDBOOK. INTERIM VERSION. SUPERSEDED BY 7000.
DOC DATE OSWER/EPA ID DOC NUMBER
9/1/1983 HW-6 C017
TITLE
COMPREHENSIVE ENVIRONMENTAL RESPONSE. COMPENSATION. AND LIABILITY ACT OF 1980.
AMENDED BY PL 99-499. 10/17/86
DOC DATE OSWER/EPA ID DOC NUMBER
10/17/1986 CO 18
TITLE
DEVELOPMENT OF ADVISORY LEVELS FOR POLY CHLORINATED BIPHENYLS (PCBS) CLEANUP.
DOC DATE OSWER/EPA ID DOC NUMBER
5/1/1986 EPA 600/6-86/002 C019
TITLE
DEVELOPMENT OF STATISTICAL DISTRIBUTION OR RANGES STANDARD FACTORS USED IN
EXPOSURE ASSESSMENTS.
DOC DATE OSWER/EPA ID DOC NUMBER
3/1/1985 EPA OHEA-E-16 C020
TITLE
DRAFT GUIDANCE FOR CONDUCTING REMEDIAL INVESTIGATIONS AND FEASIBILITY STUDIES
UNDER CERCLA SUPERSEDED BY 2002
DOC DATE OSWER/EPA ID DOC NUMBER
3/1/1988 OSWER #9335.3-01 C021
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GUIDANCE DOCUMENTS
TITLE
DRAFT GUIDANCE ON REMEDIAL ACTIONS FOR CONTAMINATED GROUND WATER AT SUPERFUND
SITES.
DOC DATE OSWER/EPA ID DOC NUMBER
10/1/1986 OSWER #9283.1-2 C022
TITLE
DRINKING WATER CRITERIA DOCUMENT FOR POLY CHLORINATED BIPHENYLS (PCBS).
SUPERSEDED BY CI07
DOC DATE OSWER/EPA ID DOC NUMBER
5/1/1987 EPA ECAO-CIN-414 C024
TITLE
ENDANGERMENT ASSESSMENT HANDBOOK.
DOC DATE OSWER/EPA ID DOC NUMBER
8/1/1985 C025
TITLE
ESTIMATED SOIL INGESTION RATES FOR USE IN RISK ASSESSMENT. TAKEN FROM RISK ANALYSIS,
VOL. 7, NO. 3. 1987.
DOC DATE OSWER/EPA ID DOC NUMBER
1/8/1987 C026
TITLE
GUIDANCE ON FEASIBILITY STUDIES UNDER CERCLA.
DOC DATE OSWER/EPA ID DOC NUMBER
6/1/1985 EPA 540/G-85-003 C034
TITLE
GUIDANCE ON REMEDIAL INVESTIGATIONS UNDER CERCLA
DOC DATE OSWER/EPA ID DOC NUMBER
6/1/1985 EPA 540/G-85/002 C035
TITLE
GUIDELINES ESTABLISHING TEST PROCEDURES FOR THE ANALYSIS OF POLLUTANTS UNDER THE
CLEAN WATER ACT; FINAL. INTERIM FINAL & PROPOSED RULE.
DOC DATE OSWER/EPA ID DOC NUMBER
10/26/1984 C036
TITLE
GUIDELINES FOR PCB LEVELS IN THE ENVIRONMENT
DOC DATE OSWER/EPA ID DOC NUMBER
1/1/1988 C037
TITLE
IMPACT OF THE RCRA LAND DISPOSAL RESTRICTIONS ON SUPERFUND RESPONSE ACTIONS IN
SUPERFUND.
DOC DATE OSWER/EPA ID DOC NUMBER
C039
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GUIDANCE DOCUMENTS
TITLE
EPA IMPLEMENTATION OF THE SUPERFUND AMENDMENTS AND REAUTHORIZATION ACT OF 1986
(SARA). DUPLICATE OF 3003
DOC DATE OSWER/EPA ID DOC NUMBER
5/21/1987 C044
TITLE
APPLICATION OF INTERIM SEDIMENT CRITERIA VALUES AT SULLIVAN'S LEDGE SUPERFUND SITE
DOC DATE OSWER/EPA ID DOC NUMBER
4/11/1988 C049
TITLE
COMMENTS ON THE PCB CONTAMINATION- REGULATORY AND POLICY BACKGROUND MEMO.
DOC DATE OSWER/EPA ID DOC NUMBER
10/14/1987 C050
TITLE
STATUS OF ALTERNATE CONCENTRATION (ACL) LIMIT FACT SHEET.
DOC DATE OSWER/EPA ID DOC NUMBER
6/24/1981 C051
TITLE
SCOPE OF CERCLA PETROLEUM EXCLUSION UNDER SECTIONS 101(14) AND 104(a)(2).
DOC DATE OSWER/EPA ID DOC NUMBER
7/31/1987 C052
TITLE
COMMUNITY RELATIONS ACTIVITIES AT SUPERFUND ENFORCEMENT SITES.
DOC DATE OSWER/EPA ID DOC NUMBER
6/28/1985 C053
TITLE
INTERIM GUIDANCE ON COMPLIANCE WITH APPLICABLE OR RELEVANT AND APPROPRIATE
REQUIREMENTS
DOC DATE OSWER/EPA ID DOC NUMBER
7/9/1987 OSWER #9234.0-05 C055
TITLE
17TH REMEDY DELEGATION REPORT, PART 1.
DOC DATE OSWER/EPA ID DOC NUMBER
5/13/1988 C056
TITLE
APPLICABILITY OF PCB REGULATIONS TO SPILLS WHICH OCCURRED PRIOR TO THE EFFECTIVE
DATE OF THE 1978 REGULATION.
DOC DATE OSWER/EPA ID DOC NUMBER
8/3/1979 C057
TITLE
PROCEDURES FOR IMPLEMENTING CERCLA DELEGATIONS FOR OFF-SITE RESPONSE ACTIONS
DOC DATE OSWER/EPA ID DOC NUMBER
C059
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GUIDANCE DOCUMENTS
TITLE
EVALUATION OF TSCA REQUIREMENTS AS ARARS FOR THE RE-SOLVE. INC. SUPERFUND SITE.
DOC DATE OSWER/EPA ID DOC NUMBER
7/24/1987 C061
TITLE
NATIONAL OIL AND HAZARDOUS SUBSTANCES POLLUTION CONTINGENCY PLAN.
DOC DATE OSWER/EPA ID DOC NUMBER
C063
TITLE
OCCUPATIONAL SAFETY AND HEALTH GUIDANCE MANUAL FOR HAZARDOUS WASTE SITE
ACTIVITIES
DOC DATE OSWER/EPA ID
10/1/1985
TITLE
PCB SPILL CLEANUP POLICY.
DOC DATE OSWER/EPA ID
4/2/1987
TITLE
PERSONNEL PROTECTION AND SAFETY.
DOC DATE OSWER/EPA ID DOC NUMBER
C071
TITLE
PROPOSED AMENDMENTS FOR LANDFILL, SURFACE IMPOUNDMENT AND WASTE PILE CLOSURES.
PROPOSED AMENDMENT TO RULE.
DOC DATE OSWER/EPA ID DOC NUMBER
3/19/1987 C079
TITLE
REMEDIAL ACTION AT WASTE DISPOSAL SITES (REVISED). HANDBOOK. DUPLICATE OF 2309.
DOC DATE OSWER/EPA ID DOC NUMBER
10/1/1985 EPA/625/6-85/006 C080
TITLE
RISK ANALYSIS OF TCDD CONTAMINATED SOIL.
DOC DATE OSWER/EPA ID DOC NUMBER
EPA 600/8-84-031 C081
TITLE
STANDARD OPERATING SAFETY GUIDES
DOC DATE OSWER/EPA ID DOC NUMBER
11/1/1984 C082
TITLE
SUMMARY OF THE REQUIREMENTS: LAND DISPOSAL RESTRICTIONS RULE
DOC DATE OSWER/EPA ID DOC NUMBER
C084
DOC NUMBER
C065
DOC NUMBER
C069
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GUIDANCE DOCUMENTS
TITLE
SUPERFUND REMEDIAL DESIGN AND REMEDIAL ACTION GUIDANCE. DUPLICATE OF 2011
DOC DATE OSWER/EPA ID DOC NUMBER
6/1/1986 OSWER#9355.04A C087
TITLE
SUPERFUND INNOVATIVE TECHNOLOGY EVALUATION PROGRAM. PROGRESS AND
ACCOMPLISHMENTS. A REPORT TO CONGRESS.
DOC DATE OSWER/EPA ID DOC NUMBER
2/1/1988 EPA/540/5-88/001 C085
TITLE
TECHNOLOGY BRIEFS: DATA REQUIREMENTS FOR SELECTING REMEDIAL ACTION TECHNOLOGY.
DOC DATE OSWER/EPA ID DOC NUMBER
1/1/1987 EPA/606/2-87/001 C088
TITLE
TECHNOLOGY SCREENING GUIDE FOR TREATMENT OF CERCLA SOILS AND SLUDGES. DUPLICATE
OF 2319.
DOC DATE OSWER/EPA ID DOC NUMBER
9/1/1988 EPA/540/2-88/004 C090
TITLE
CATALOG OF SUPERFUND PROGRAM DIRECTIVES, INTERIM EDITION
DOC DATE OSWER/EPA ID DOC NUMBER
7/1/1988 OSWER #9200.7-01 C012
TITLE
UPDATE PCB CLEANUP-LEVEL DOCUMENT
DOC DATE OSWER/EPA ID DOC NUMBER
12/6/1988 C060
TITLE
FEASIBILITY TESTING OF IN SITU VITRIFICATION OF NEW BEDFORD HARBOR SEDIMENTS.
DOC DATE OSWER/EPA ID DOC NUMBER
12/1/1988 C028
TITLE
B. E. S. T. IS CURRENTLY TECHNICALLY UNACCEPTABLE FOR USE AT BROS.
DOC DATE OSWER/EPA ID DOC NUMBER
9/20/1988 C004
TITLE
ORGANIC EXTRACTION UTILIZING SOLVENTS. DEMONSTRATION BULLETIN SUPERFUND
INNOVATIVE TECHNOLOGY EVALUATION
DOC DATE OSWER/EPA ID DOC NUMBER
4/1/1989 EPA/540/M5-89/006 C066
TITLE
FINAL REPORT: LABORATORY TESTING RESULTS: KPEG TREATMENT OF NEW BEDFORD SOIL.
DOC DATE OSWER/EPA ID DOC NUMBER
12/20/1988 C030
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GUIDANCE DOCUMENTS
TITLE
BRIDGEPORT BID PROTEST.
DOC DATE OSWER/EPA ID DOC NUMBER
C008
TITLE
MATERIAL SAFETY DATA SHEET: TRIETHYLAMINE
DOC DATE OSWER/EPA ID DOC NUMBER
3/1/1986 C092
TITLE
GUIDANCE MANUAL FOR WRITERS OF PCB DISPOSAL PERMITS FOR ALTERNATE TECHNOLOGIES.
DRAFT REPORT.
DOC DATE OSWER/EPA ID DOC NUMBER
6/30/1988 C033
TITLE
STATIONARY SOURCE SAMPLING REPORT. EEI REF. NO 5448. BENZENE, MERCURY, TOLUENE,
TRIETHYLAMINE AND XYLENE EMISSIONS TESTING.
DOC DATE OSWER/EPA ID DOC NUMBER
2/26/1987 C006
TITLE
INCINERATION OF A CHEMICALLY CONTAMINATED SYNTHETIC SOIL MATRIX (SSM) USING A
PILOT-SCALE ROTARY KILN SYSTEM.
DOC DATE OSWER/EPA ID DOC NUMBER
C041
TITLE
NCR WORKGROUP MEETINGS.
DOC DATE OSWER/EPA ID DOC NUMBER
6/9/1989 C062
TITLE
POLICY FOR SUPERFUND COMPLIANCE WITH THE RCRA LAND DISPOSAL RESTRICTIONS
DOC DATE OSWER/EPA ID DOC NUMBER
4/17/1989 OSWER #9347.1-0 C058
TITLE
LAND DISPOSAL RESTRICTIONS AS RELEVANT AND APPROPRIATE REQUIREMENTS FOR CERCLA
CONTAMINATED SOIL AND DEBRIS DUPLICATE OF 3016.
DOC DATE OSWER/EPA ID DOC NUMBER
6/5/1989 OSWER #9347.2-01 C054
TITLE
PCB CONTAMINATION AT SUPERFUND SITES.
DOC DATE OSWER/EPA ID DOC NUMBER
4/7/1989 C048
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Page 23
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GUIDANCE DOCUMENTS
TITLE
LABORATORY SCALE TESTING REPORT: KPEG PROCESSING OF WIDE BEACH DEVELOPMENT SITE
SOILS.
DOC DATE OSWER/EPA ID DOC NUMBER
9/30/1968 C042
TITLE
HIGH TEMPERATURE THERMAL TREATMENT FOR CERCLA WASTE. EVALUATION AND SELECTION
OF ONSITE AND OFF SITE SYSTEMS
DOC DATE OSWER/EPA ID DOC NUMBER
12/1/1988 EPA/640/X-8 8/006 C038
TITLE
TECHNOLOGY EVALUATION REPORT SITE PROGRAM DEMONSTRATION TEST, HAZCON
SOLIDIFICATION, DOUGLASSVILLE, PENNSYLVANIA. VOLUME 1.
DOC DATE OSWER/EPA ID DOC NUMBER
2/1/1989 EPA/540/5-89/001A C089
TITLE
NEW BEDFORD HARBOR. ACUSHN6T RIVER ESTUARY ENGINEERING FEASIBILITY STUDY OF
DREDGING. RPT 9: LABORATORY-SCALE APPLICATION OF SOLIDIFICATION.
DOC DATE OSWER/EPA ID DOC NUMBER
1/1/1989 C064
TITLE
CLASSIFICATION OF SURFACE WATERS
DOC DATE OSWER/EPA ID DOC NUMBER
9/1/1979 C016
TITLE
FEASIBILITY OF APEG DETOXIFICATION OF DIOXIN-CONTAMINATED SOILS. PROJECT SUMMARY
DOC DATE OSWER/EPA ID DOC NUMBER
4/1/1984 EPA-600/S2-84-071 C078
TITLE
DESTRUCTION OF PCBS: ENVIRONMENTAL APPLICATIONS OF ALKALI METAL POLYETHYLENE
GLYCOLATE COMPLEXES. PROJECT SUMMARY.
DOC DATE OSWER/EPA ID DOC NUMBER
12/1/1985 EPA/600/S2-85/108 C076
TITLE
CHEMICAL REACTION OF POLY CHLORINATED BIPHENYLS ON SOILS WITH POLY (ETHYLENE
GLYCOL)/KOH. TAKEN FROM "CHEMOSPHERE" VOL. 14. NO. 2, 1985.
DOC DATE OSWER/EPA ID DOC NUMBER
C015
TITLE
PCB DESTRUCTION: A NOVEL DEHALOGENATION REAGENT (TAKEN FROM JOURNAL OF
HAZARDOUS MATERIALS, 12 (1985) 161-176
DOC DATE OSWER/EPA ID DOC NUMBER
1/1/1985 C067
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Page 24
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GUIDANCE DOCUMENTS
TITLE
GROUNDWATER CLASSIFICATION SYSTEM.
DOC DATE OSWER/EPA ID DOC NUMBER
5/1/1986 C031
TITLE
IN SITU VITRIFICATION OF PCB-CONTAMINATED SOILS. FINAL REPORT.
DOC DATE OSWER/EPA ID DOC NUMBER
10/1/1986 C040
TITLE
CHEMICAL DESTRUCTION OF CHLORINATED DIOXINS AND FURANS.
DOC DATE OSWER/EPA ID DOC NUMBER
C013
TITLE
PCB SEDIMENT DECONTAMINATION - TECHNICAL/ECONOMIC ASSESSMENT OF SELECTED
ALTERNATIVE TREATMENTS. PROJECT SUMMARY.
DOC DATE OSWER/EPA ID DOC NUMBER
3/1/1987 EPA/600/S2-86/112 C077
TITLE
CATALYTIC DEHYDROHALOGENATION: A CHEMICAL DESTRUCTION METHOD FOR HALOGENATED
ORGANICS. PROJECT SUMMARY.
DOC DATE OSWER/EPA ID DOC NUMBER
3/1/1987 EPA/600/S2-86/113 C075
TITLE
CHEMICAL DESTRUCTION OF HALOGENATED ALIPHATIC HYDROCARBONS
DOC DATE OSWER/EPA ID DOC NUMBER
6/23/1987 C014
TITLE
SUPERFUND RECORD OF DECISION: LIQUID DISPOSAL, MI.
DOC DATE OSWER/EPA ID DOC NUMBER
9/1/1987 EPA/ROD/R05-87/051 C086
TITLE
ANALYSIS OF KPEG/GUAM SOIL PCB DETOXIFICATION FROM THE GUAM FIELD TEST
DOC DATE OSWER/EPA ID DOC NUMBER
6/24/1988 C046
TITLE
IN SITU VITRIFICATION TECHNOLOGY INFORMATION
DOC DATE OSWER/EPA ID DOC NUMBER
7/13/1988 C043
TITLE
GUAM II. RETREATMENT OF GUAM SOILS AND THE CONTINUATION OF APEG FOR PCB
DETOXIFICATION
DOC DATE OSWER/EPA ID DOC NUMBER
10/13/1988 C045
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GUIDANCE DOCUMENTS
TITLE
BASIC EXTRACTIVE SLUDGE TREATMENT (B E S T.) DEMONSTRATED AVAILABLE TECHNOLOGY
DOC DATE OSWER/EPA ID DOC NUMBER
12/16/1986 C005
TITLE
PCB SEDIMENT DECONTAMINATION PROCESSES SELECTION FOR TEST AND EVALUATION (TAKEN
FROM HAZARDOUS WASTE & HAZARDOUS MATERIALS. VOL 5, NUMBER, 3. 1988)
DOC DATE OSWER/EPA ID DOC NUMBER
1/1/1988 C068
TITLE
EVALUATION OF THE B E S T. SOLVENT EXTRACTION SLUDGE TREATMENT TECHNOLOGY
TWENTY-FOUR HOUR TEST
DOC DATE OSWER/EPA ID DOC NUMBER
EPA 600/2-88/051 C027
TITLE
DISTRIBUTION OF DRAFT CLEAN WATER ACT/SAFE DRINKING WATER ACT (CWA/SWDA) VOLUME
OF THE SUPERFUND COMPLIANCE MANUAL
DOC DATE OSWER/EPA ID DOC NUMBER
C047
TITLE
DRAFT STANDARD REVIEW PLAN INFORMATION REQUIREMENTS
DOC DATE OSWER/EPA ID DOC NUMBER
C023
TITLE
SUMMARY OF BIOASSAY TESTS ON APEG BYPRODUCTS
DOC DATE OSWER/EPA ID DOC NUMBER
C083
TITLE
FIELD EXPERIENCE WITH THE KPEG REAGENT
DOC DATE OSWER/EPA ID DOC NUMBER
C029
TITLE
POLY CHLORINATED BIPHENYLS (PCBS) MANUFACTURING. PROCESSING, DISTRIBUTION IN
COMMERCE, AND USE PROHIBITIONS
DOC DATE OSWER/EPA ID DOC NUMBER
7/1/1987 C074
TITLE
POLY CHLORINATED BIPHENYLS, CRITERIA MODIFICATION, HEARINGS.
DOC DATE OSWER/EPA ID DOC NUMBER
5/31/1979 C072
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GUIDANCE DOCUMENTS
TITLE
POLY CHLORINATED BIPHENYLS (PCBS): FINAL RULES AND NOTICE OF REQUEST FOR ADDITIONAL
COMMENTS ON CERTAIN INDIVIDUAL AND CLASS PETITIONS FOR EXEMPTION.
DOC DATE OSWER/EPA ID DOC NUMBER
7/10/1984 C073
TITLE
GUIDANCE MANUAL FOR HAZARDOUS WASTE INCINERATOR PERMITS.
DOC DATE OSWER/EPA ID DOC NUMBER
7/1/1983 EPA SW-966 C032
TITLE
PERMIT WRITER'S GUIDE TO TEST BURN DATA. HAZARDOUS WASTE INCINERATION. HANDBOOK.
DOC DATE OSWER/EPA ID DOC NUMBER
9/1/1986 EPA/625/6-86/012; C070
TITLE
APPLICATION OF LOW-TEMPERATURE THERMAL TREATMENT TECHNOLOGY TO CERCLA SOILS.
DOC DATE OSWER/EPA ID DOC NUMBER
C093
TITLE
DISCHARGE OF WASTEWATER FROM CERCLA SITES INTO POTWS.
DOC DATE OSWER/EPA ID DOC NUMBER
4/15/1966 C094
TITLE
SEDIMENT QUALITY VALUES REFINEMENT: 1988 UPDATE AND EVALUATION OF PUGET SOUND AET.
DOC DATE OSWER/EPA ID DOC NUMBER
9/1/1988 C095
TITLE
EVALUATION OF THE APPARENT EFFECTS THRESHOLD (AET) APPROACH FOR ASSESSING SEDIMENT
QUALITY. REPORT OF THE SEDIMENT CRITERIA SUBCOMMITTEE.
DOC DATE OSWER/EPA ID DOC NUMBER
7/1/1989 SAB-EETFC-69-027 C096
TITLE
NBH SUPERFUND PROJECT, ACUSHNET RIVER ESTUARY ENG. FS OF DREDGED MATERIAL DISPOSAL
ALTERNATIVES. RPT. 10. EVALUATION OF DREDGING CONTROL TECHNOLOGIES.
DOC DATE OSWER/EPA ID DOC NUMBER
11/1/1988 EL-88-15 C097
TITLE
HOT SPOT FEASIBILITY STUDY. NEW BEDFORD HARBOR. DRAFT FINAL
DOC DATE OSWER/EPA ID DOC NUMBER
7/1/1989 C098
TITLE
INTERIM FINAL GUIDANCE ON SOIL INGESTION RATES.
DOC DATE OSWER/EPA ID DOC NUMBER
2/9/1989 OSWER #9650.4 C099
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GUIDANCE DOCUMENTS
TITLE
PCB SEDIMENT DECONTAMINATION-TECHNICAL/ECONOMIC ASSESSMENT OF SELECTED
ALTERNATIVE TREATMENTS.
DOC DATE OSWER/EPA ID DOC NUMBER
9/15/1986 C100
TITLE
B E S T. PROCESS-EFFECTIVE TREATMENT OF SLUDGES, SOILS. AND SEDIMENTS CONTAMINATED
WITH PCBS, SEMI-VOLATILE ORGANICS (PAHS). VOCS. PCP, CREOSOTES
DOC DATE OSWER/EPA ID DOC NUMBER
2/24/1989 C101
TITLE
B E S T. PROCESS-EFFECTIVE TREATMENT OF SLUDGES, SEDIMENTS AND SOILS CONTAMINATED WITH
PCBS, POLYNUCLEAR AROMATICS (PNAS). VOCS, PCP, CREOSOTE
DOC DATE OSWER/EPA ID DOC NUMBER
8/14/1989 C102
TITLE
HAZARDOUS WASTE MANAGEMENT SYSTEM, LAND DISPOSAL RESTRICTIONS, FINAL RULE
DOC DATE OSWER/EPA ID DOC NUMBER
11/7/1986 C103
TITLE
SUPPLEMENTAL RISK ASSESSMENT GUIDANCE FOR THE SUPERFUND PROGRAM. DRAFT FINAL.
DOC DATE OSWER/EPA ID DOC NUMBER
6/1/1989 EPA 901/5-89-001 C104
TITLE
LAND DISPOSAL RESTRICTIONS FOR CERTAIN "CALIFORNIA LIST' HAZARDOUS WASTES AND
MODIFICATIONS TO THE FRAMEWORK FINAL RULE.
DOC DATE OSWER/EPA ID DOC NUMBER
7/8/1987 C105
TITLE
GUIDANCE ON REMEDIAL ACTIONS FOR CONTAMINATED GROUND WATER AT SUPERFUND SITES.
INTERIM FINAL. DUPLICATE OF 2413.
DOC DATE OSWER/EPA ID DOC NUMBER
12/1/1988 OSWER #9283.1-2 C106
TITLE
DRINKING WATER CRITERIA FOR POLY CHLORINATED BIPHENYLS (PCBS). FINAL. RESEARCH AND
DEVELOPMENT
DOC DATE OSWER/EPA ID DOC NUMBER
4/1/1968 ECAO-CIN-414 C107
TITLE
CERCLA COMPLIANCE WITH OTHER LAWS MANUAL: DRAFT GUIDANCE. DUPLICATE OF 3002.
DOC DATE OSWER/EPA ID DOC NUMBER
8/8/1988 EPA/540/G-89/006 C108
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Page 27
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GUIDANCE DOCUMENTS
TITLE
CERCLA COMPLIANCE WITH OTHER LAWS MANUAL: PART II. CLEAN AIR ACT AND OTHER
ENVIRONMENTAL STATUTES AND STATE REQUIREMENTS. INTERIM FINAL. DUP. OF 3013.
DOC DATE OSWER/EPA ID DOC NUMBER
8/1/1989 EPA/540/G-89/009 C109
TITLE
AIR STRIPPER CONTROL GUIDANCE.
DOC DATE OSWER/EPA ID DOC NUMBER
7/12/1989 OSWER #9355.0-28 CI 10
TITLE
IN SITU TREATMENT OF HAZARDOUS WASTE-CONTAMINATED SOILS HANDBOOK.
DOC DATE OSWER/EPA ID DOC NUMBER
1/1/1990 EPA/540/2-90/002 CI 11
TITLE
SUPERFUND GLOSSARY, WINTER 1986.
DOC DATE OSWER/EPA ID DOC NUMBER
WH/FS-86-007 CI 12
TITLE
PUBLIC INVOLVEMENT IN THE SUPERFUND PROGRAM, FALL 1987.
DOC DATE OSWER/EPA ID DOC NUMBER
WH/FS-67-004R CI 13
TITLE
SUPERFUND, FALL 1987
DOC DATE OSWER/EPA ID DOC NUMBER
WH/FS-87-001R CI 14
TITLE
SUPERFUND REMEDIAL PROGRAM, FALL 1987.
DOC DATE OSWER/EPA ID DOC NUMBER
WH/FS-87-002R CI 15
TITLE
INTERIM SEDIMENT CRITERIA VALUES FOR NONPOLAR HYDROPHOBIC ORGANIC CONTAMINANTS.
DOC DATE OSWER/EPA ID DOC NUMBER
5/1/1988 SCDHM7 CI 16
TITLE
APPLICABILITY OF LDRS TO RCRA AND CERCLA GROUND WATER TREATMENT REINJECTION
SUPERFUND MANAGEMENT REVIEW: RECOMMENDATION NO. 26. DUPLICATE OF 2213.
DOC DATE OSWER/EPA ID DOC NUMBER
12/27/1989 OSWER#9234.1-06 CI 19
TITLE
FEDERAL MANUAL FOR IDENTIFYING AND DELINEATING JURISDICTIONAL WETLANDS.
DOC DATE OSWER/EPA ID DOC NUMBER
1/10/1989 CI 18
Wednesday, May 05, 2004
Page
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GUIDANCE DOCUMENTS
TITLE
GUIDE ON REMEDIAL ACTIONS FOR CONTAMINATED GROUND WATER. DUPLICATE OF 2409.
DOC DATE OSWER/EPA ID DOC NUMBER
4/1/1989 9283.1-2FS C120
TITLE
TECHNOLOGY EVALUATION REPORT: SITE PROGRAM DEMONSTRATION TEST TERRA VAC IN SITU
VACUUM EXTRACTION SYSTEM VOLUME 1.
DOC DATE OSWER/EPA ID DOC NUMBER
4/1/1989 EPA/540/5-89/003a C121
TITLE
ARARS Q'S & A'S. GENERAL POLICY: RCRA. CWA & SDWA. SUPERFUND FACT SHEET. DUPLICATE OF
3006.
DOC DATE OSWER/EPA ID DOC NUMBER
5/1/1989 OERR 9234.2-01 FS C122
TITLE
LAND DISPOSAL RESTRICTIONS. SUMMARY OF REQUIREMENTS.
DOC DATE OSWER/EPA ID DOC NUMBER
6/1/1989 OS-520 C123
TITLE
SUPERFUND LDR GUIDE #1. OVERVIEW OF RCRA LAND DISPOSAL RESTRICTIONS (LDRS). DUPLICATE
OF 2214.
DOC DATE OSWER/EPA ID DOC NUMBER
7/1/1989 9347.3-01 FS C124
TITLE
SUPERFUND CDR GUIDE #2. COMPLYING WITH THE CALIFORNIA LIST RESTRICTIONS UNDER LAND
DISPOSAL RESTRICTIONS (LDRS). DUPLICATE OF 2215.
DOC DATE OSWER/EPA ID DOC NUMBER
7/1/1989 9347.3-02 FS C125
TITLE
SUPERFUND LDR GUIDE #3. TREATMENT STANDARDS AND MINIMUM TECHNOLOGY REQUIREMENTS
UNDER LAND DISPOSA RESTRICTIONS (LDRS). DUPLICATE OF 3018.
DOC DATE OSWER/EPA ID DOC NUMBER
7/1/1989 9347.3-03FS C126
TITLE
SUPERFUND LDR GUIDE #5. DETERMINING WHEN LAND DISPOSAL RESTRICTIONS (LDRS) ARE
APPLICABLE TO CERCLA RESPONSE ACTIONS. DUPLICATE OF 2218.
DOC DATE OSWER/EPA ID DOC NUMBER
7/1/1989 9347.3-05 FS C127
TITLE
SUPERFUND LDR GUIDE #8A. OBTAINING A SOIL AND DEBRIS TREATABILITY VARIANCE FOR
REMEDIAL ACTIONS DUPLICATE OF 2219.
DOC DATE OSWER/EPA ID DOC NUMBER
7/1/1989 9347.3-06 FS C128
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GUIDANCE DOCUMENTS
TITLE
CODE OF FEDERAL REGULATIONS. TITLE 40. PARTS 190 TO 299. PROTECTION OF ENVIRONMENT.
REVISED AS OF JULY 1, 1989.
DOC DATE OSWER/EPA ID DOC NUMBER
7/1/1989 C129
TITLE
STATE AND LOCAL INVOLVEMENT IN THE SUPERFUND PROGRAM. FALL 1989.
DOC DATE OSWER/EPA ID DOC NUMBER
9375.5-01/FS C130
TITLE
EVALUATION OF GROUND-WATER EXTRACTION REMEDIES. VOLUME 1. SUMMARY REPORT.
DUPLICATE OF 2412.
DOC DATE OSWER/EPA ID DOC NUMBER
9/1/1989 EPA/540/2-89/054 C131
TITLE
DETERMINING SOIL RESPONSE ACTION LEVELS BASED ON POTENTIAL CONTAMINANT MIGRATION TO
GROUND WATER: A COMPENDIUM OF EXAMPLES. DUPLICATE OF #2411.
DOC DATE OSWER/EPA ID DOC NUMBER
10/1/1989 EPA/540/2-89/057 C133
TITLE
GROUND WATER ISSUE. PERFORMANCE EVALUATIONS OF PUMP-AND-TREAT REMEDIATIONS.
DOC DATE OSWER/EPA ID DOC NUMBER
10/1/1989 EPA/540/4-89/005 C134
TITLE
SUPERFUND LDR GUIDE #4 COMPLYING WITH THE HAMMER RESTRICTIONS UNDER LAND DISPOSAL
RESTRICTIONS (LDRS) DUPLICATE OF 2217
DOC DATE OSWER/EPA ID DOC NUMBER
7/1/1989 9347.3-04FS C135
TITLE
CONSIDERATIONS IN GROUND WATER REMEDIATION AT SUPERFUND SITES DUPLICATE OF 2410
DOC DATE OSWER/EPA ID DOC NUMBER
10/18/1989 93554-03 C136
TITLE
SUPERFUND INNOVATIVE TECHNOLOGY EVALUATION PROGRAM TECHNOLOGY PROFILES
DOC DATE OSWER/EPA ID DOC NUMBER
11/1/1989 EPA/540/5-89/013 C137
TITLE
ANALYSIS OF TREATABILITY DATA FOR SOIL & DEBRIS EVALUATION OF LAND BAN IMPACT ON USE
OF SUPERFUND TREATMENT TECHNOLOGIES SF MGMT REVIEW REC 34A
DOC DATE OSWER/EPA ID DOC NUMBER
11/30/1989 93803-04 C138
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GUIDANCE DOCUMENTS
TITLE
SUPERFUND LDR GUIDE #7 DETERMINING WHEN LAND DISPOSAL RESTRICTIONS (LDRS) ARE
RELEVANT AND APPROPRIATE TO CERCLA RESPONSE ACTIONS DUPLICATE OF 2220
DOC DATE OSWER/EPA ID DOC NUMBER
12/1/1989 9347.3-08FS C139
TITLE
CERCLA COMPLIANCE WITH OTHER LAWS MANUAL CERCLA COMPLIANCE WITH STATE
REQUIREMENTS DUPLICATE OF 3009
DOC DATE OSWER/EPA ID DOC NUMBER
12/1/1989 9234.2-05/FS C140
TITLE
CERCLA COMPLIANCE WITH OTHER LAWS MANUAL OVERVIEW OF ARARS FOCUS ON ARAR WAIVERS
DUPLICATE OF 3011
DOC DATE OSWER/EPA ID DOC NUMBER
12/1/1989 92342-03/FS C141
TITLE
TECHNOLOGY EVALUATION REPORT SITE PROGRAM DEMONSTRATION OF THE ULTROX
INTERNATIONAL ULTRAVIOLET RADIATION/OXIDATION TECHNOLOGY
DOC DATE OSWER/EPA ID DOC NUMBER
1/1/1990 EPA/540/5-89/012 C142
TITLE
PRESUMPTIVE REMEDIES POLICY AND PROCEDURES
DOC DATE OSWER/EPA ID DOC NUMBER
9/1/1993 93550-47FS C143
TITLE
STATE OF TECHNOLOGY REVIEW SOIL VAPOR EXTRACTION SYSTEMS PROJECT SUMMARY
DOC DATE OSWER/EPA ID DOC NUMBER
1/1/1990 EPA/600/S2-089/024 C144
TITLE
CERCLA COMPLIANCE WITH OTHER LAWS MANUAL CERCLA COMPLIANCE WITH THE CWA AND SDWA
DUPLICATE OF 3010
DOC DATE OSWER/EPA ID DOC NUMBER
2/1/1990 92342-06/FS C145
TITLE
FIELD EVALUATION OF THE UV/OXIDATION TECHNOLOGY TO TREAT CONTAMINATED
GROUNDWATER. MARCH/APRIL 1990.
DOC DATE OSWER/EPA ID DOC NUMBER
C146
TITLE
CERCLA COMPLIANCE WITH OTHER LAWS MANUAL. SUMMARY OF PART II CAA, TSCA, AND OTHER
STATUTES. DUPLICATE OF 3012.
DOC DATE OSWER/EPA ID DOC NUMBER
4/1/1990 9234.2-07/FS C147
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Page 31
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GUIDANCE DOCUMENTS
TITLE
FIELD DEMONSTRATION OF THE UV/OXIDATION TECHNOLOGY TO TREAT GROUND WATER
CONTAMINATED WITH VOCS.
DOC DATE OSWER/EPA ID DOC NUMBER
4/1/1990 C148
TITLE
FEASIBILITY STUDY ANALYSIS. UNION CHEMICAL
DOC DATE OSWER/EPA ID DOC NUMBER
5/8/1990 C149
TITLE
ATSDR FACT SHEET.
DOC DATE OSWER/EPA ID DOC NUMBER
C150
TITLE
TECHNOLOGY EVALUATION REPORT: CF SYSTEMS ORGANICS EXTRACTION SYSTEM. VOLUME I.
DOC DATE OSWER/EPA ID DOC NUMBER
1/1/1990 EPA/540/5-90/002 C151
TITLE
TECHNOLOGY EVALUATION REPORT: SITE PROGRAM DEMONSTRATION TEST. SOLIDITECH, INC.
SOLIDIFICATION/STABILIZATION PROCESS. VOLUME 1.
DOC DATE OSWER/EPA ID DOC NUMBER
2/1/1990 EPA/540/5-B9/005a C152
TITLE
ROD ANNUAL REPORT: FY 1989.
DOC DATE OSWER/EPA ID DOC NUMBER
4/1/1990 EPA/540/8-90/006 C153
TITLE
FINAL METHODOLOGY FOR EARLY DE MINIMIS WASTE CONTRIBUTOR SETTLEMENTS UNDER CERCLA
SECTION 122(g)(1)(A).
DOC DATE OSWER/EPA ID DOC NUMBER
6/2/1992 OSWER 9834.7-1C C154
TITLE
FINAL METHODOLOGIES FOR IMPLEMENTATION OF CERCLA SECTION 122(g)(lXA) DE MINIMIS WASTE
CONTRIBUTOR SETTLEMENT PROPOSALS AND AGREEMENTS.
DOC DATE OSWER/EPA ID DOC NUMBER
12/20/1988 OSWER 9634.7-1B C155
TITLE
FINAL GUIDANCE ON PREMIUM PAYMENTS IN CERCLA SETTLEMENTS.
DOC DATE OSWER/EPA ID DOC NUMBER
11/17/1988 OSWER 9835.6 C156
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GUIDANCE DOCUMENTS
TITLE
PRESUMPTIVE REMEDY FOR CERCLA MUNICIPAL LANDFILL SITES.
DOC DATE OSWER/EPA ID DOC NUMBER
9/1/1993 OSWER 9355.0-49FS C157
TITLE
GUIDANCE FOR EVALUATING THE TECHNICAL IMPRACTICABILITY OF GROUND WATER
RESTORATION.
DOC DATE OSWER/EPA ID DOC NUMBER
10/4/1993 OSWER 9234.2-25 C158
TITLE
FINAL GUIDANCE ON PREPARING AND RELEASING WASTE- IN LISTS AND VOLUMETRIC RANKINGS TO
PRPS UNDER CERCLA.
DOC DATE OSWER/EPA ID DOC NUMBER
2/22/1991 OSWER 9835.16 C159
TITLE
FINAL INTERIM GUIDANCE ON SETTLEMENTS WITH DE MINIMIS WASTE CONTRIBUTORS UNDER
SECTION 122 (g) OF SARA
DOC DATE OSWER/EPA ID DOC NUMBER
6/19/1987 OSWER 9834.7 C160
TITLE
INTERIM CERCLA SETTLEMENT POLICY.
DOC DATE OSWER/EPA ID DOC NUMBER
5/30/7986 OSWER 9835.0 C161
TITLE
OFF-SITE RULE IMPLEMENTATION.
DOC DATE OSWER/EPA ID DOC NUMBER
9/27/1993 EPA 9834.1 lFSa C162
TITLE
SEWAGE SLUDGE, USE AND DISPOSAL RULE (40 CFR PART 503} - FACT SHEET.
DOC DATE OSWER/EPA ID DOC NUMBER
11/1/1992 EPA-822-F-92-002 C163
TITLE
SUMMARY OF THE STANDARDS FOR THE USE OR DISPOSAL OF SEWAGE SLUDGE. 40 CFR PART 503 (58
FR 32: 9248-9415).
DOC DATE OSWER/EPA ID DOC NUMBER
9/30/1993 CI 64
TITLE
RCRA REGULATORY STATUS OF CONTAMINATED GROUNDWATER.
DOC DATE OSWER/EPA ID DOC NUMBER
12/1/1984 C165
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Page 33
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GUIDANCE DOCUMENTS
TITLE
RCRA REGULATORY STATUS OF CONTAMINATED GROUND WATER.
DOC DATE OSWER/EPA ID DOC NUMBER
11/13/1986 9441.1986(83: C166
TITLE
CERCLA SITE DISCHARGES TO POTWS GUIDANCE MANUAL.
DOC DATE OSWER/EPA ID DOC NUMBER
8/1/1990 EPA/540/G-90/005 C167
TITLE
QUALITY ASSURANCE AND QUALITY CONTROL FOR WASTE CONTAINMENT FACILITIES. TECHNICAL
GUIDANCE DOCUMENT
DOC DATE OSWER/EPA ID DOC NUMBER
9/1/1993 EPA/600/R-93/182 C168
TITLE
DRAFT GUIDANCE ON CERCLA COMPLIANCE WITH OTHER LAWS MANUAL. DUPLICATE OF CI08.
DOC DATE OSWER/EPA ID DOC NUMBER
8/8/1988 OSWER 9234.1-01 C169
TITLE
INTERIM FINAL GUIDANCE FOR CONDUCTING REMEDIAL INVESTIGATIONS AND FEASIBILITY STUDIES
UNDER CERCLA. DUPLICATE OF 2002.
DOC DATE OSWER/EPA ID DOC NUMBER
10/1/1988 OSWER #9355.3-01 C170
TITLE
REQUIREMENTS FOR HAZARDOUS WASTE LANDFILL DESIGN, CONSTRUCTION, AND CLOSURE
DOC DATE OSWER/EPA ID DOC NUMBER
4/1/1989 EPA/625/4-89/02; C171
TITLE
FINAL COVERS ON HAZARDOUS WASTE LANDFILLS AND SURFACE IMPOUNDMENTS. TECHNICAL
GUIDANCE DOCUMENT.
DOC DATE OSWER/EPA ID DOC NUMBER
7/1/1989 EPA/530-SW-89-047 C172
TITLE
CERCLA COMPLIANCE WITH OTHER LAWS MANUAL. RCRA ARARS: FOCUS ON CLOSURE
REQUIREMENTS. DUPLICATE OF 3017.
DOC DATE OSWER/EPA ID DOC NUMBER
10/1/1989 OSWER #9234.2-04FS C173
TITLE
RISK ASSESSMENT GUIDANCE FOR SUPERFUND. VOLUME I. HUMAN HEALTH EVALUATION MANUAL
(PART A). INTERIM FINAL.
DOC DATE OSWER/EPA ID DOC NUMBER
12/1/1989 EPA/540/1-89/002 C174
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GUIDANCE DOCUMENTS
TITLE
HYDROLOGIC EVALUATION OF LANDFILL PERFORMANCE MODEL - VERSION 2.05.
DOC DATE OSWER/EPA ID DOC NUMBER
1/1/1988 C175
TITLE
STREAMLINING THE RI/FS FOR CERCLA MUNICIPAL LANDFILL SITES.
DOC DATE OSWER/EPA ID DOC NUMBER
9/1/1990 OSWER #9355.3-11FS C176
TITLE
CONDUCTING REMEDIAL INVESTIGATIONS/FEASIBILITY STUDIES FOR CERCLA MUNICIPAL LANDFILL
SITES
DOC DATE OSWER/EPA ID DOC NUMBER
2/1/1991 OSWER 09355.3-11 C177
TITLE
DRAFT GUIDANCE ON CERCLA COMPLIANCE WITH OTHER LAWS MANUAL.
DOC DATE OSWER/EPA ID DOC NUMBER
11/25/1987 OSWER 9234.1-01 C178
TITLE
GUIDANCE ON PREPARING SUPERFUND DECISION DOCUMENTS: THE PROPOSED PLAN, THE RECORD
OF DECISION, E S.D.' S, ROD. AMENDMENT. INTERIM FINAL.
DOC DATE OSWER/EPA ID DOC NUMBER
7/1/1969 OSWER 9355.3-02 C179
TITLE
RISK ASSESSMENT GUIDANCE FOR SUPERFUND. HUMAN HEALTH EVALUATION MANUAL PART A.
DOC DATE OSWER/EPA ID DOC NUMBER
7/1/1989 C180
TITLE
FINAL COVERS ON HAZARDOUS WASTE LANDFILLS AND SURFACE IMPOUNDMENTS. TECHNICAL
GUIDANCE DOCUMENT. DUPLICATE OF CI72.
DOC DATE OSWER/EPA ID DOC NUMBER
7/1/1989 EPA/530-SW-89-047 C181
TITLE
DRAFT ENGINEERING EVALUATION/COST ANALYSIS GUIDANCE FOR NON-TIME-CRITICAL REMOVAL
ACTIONS
DOC DATE OSWER/EPA ID DOC NUMBER
3/1/1988 CI 82
TITLE
SUPERFUND REMOVAL PROCEDURES: GUIDANCE ON THE CONSIDERATION OF ARARS DURING
REMOVAL ACTIONS
DOC DATE OSWER/EPA ID DOC NUMBER
9/1/1991 EPA 540/P-91/011 C183
Wednesday, May 05, 2004 Page 35
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GUIDANCE DOCUMENTS
TITLE
RAYOX: A SECOND GENERATION ENHANCED OXIDATION PROCESS FOR DESTROYING WATERBORNE
TOXIC CONTAMINANTS.
DOC DATE OSWER/EPA ID DOC NUMBER
2/15/1989 C010
TITLE
CERCLA COMPLIANCE WITH OTHER LAWS MANUAL. RCRA ARARS: FOCUS ON CLOSURE
REQUIREMENTS. DUPLICATE OF 3017.
DOC DATE OSWER/EPA ID DOC NUMBER
10/1/1989 OSWER #9234.2-04FS C011
TITLE
SOIL SAMPLING QUALITY ASSURANCE USER'S GUIDE. SECOND EDITION.
DOC DATE OSWER/EPA ID DOC NUMBER
3/1/1989 EPA/600/B-89/046 C091
TITLE
APPLICABILITY OF LDRS TO RCRA AND CERCLA GROUND WATER TREATMENT REINJECTION
SUPERFUND MANAGEMENT REVIEW: RECOMMENDATION NO. 26. DUPLICATE OF CI 19.
DOC DATE OSWER/EPA ID DOC NUMBER
12/27/1989 OSWER #9234.1-06 CI 17
TITLE
AMBIENT WATER QUALITY CRITERIA FOR POLY CHLORINATED BIPHENYLS
DOC DATE OSWER/EPA ID DOC NUMBER
10/1/1989 EPA 440/5-80-066 C132
TITLE
FINAL GUIDANCE ON OVERSITE OF POTENTIALLY RESPONSIBLE PARTY REMEDIAL INVESTIGATIONS
AND FEASIBILITY STUDIES. VOLUMES 1 & 2.
DOC DATE OSWER/EPA ID DOC NUMBER
7/1/1991 9835.1(d) C184
TITLE
EARLY ACTION AND LONG-TERM ACTION UNDER SACM (SUPERFUND ACCELERATED CLEANUP
MODEL). INTERIM GUIDANCE
DOC DATE OSWER/EPA ID DOC NUMBER
12/1/1992 OSWER #9203.1-051 C185
TITLE
GUIDANCE ON CONDUCTING NON-TIME-CRITICAL REMOVAL ACTIONS UNDER CERCLA.
DOC DATE OSWER/EPA ID DOC NUMBER
8/1/1993 EPA 540-R-93-057 C186
TITLE
SUPERFUND ACCELERATED CLEANUP MODEL (SACM) COORDINATION STRATEGY.
DOC DATE OSWER/EPA ID DOC NUMBER
9/14/1993 OSWER 09203.1-11 C187
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GUIDANCE DOCUMENTS
TITLE
CONDUCTING NON-TIME-CRITICAL REMOVAL ACTIONS UNDER CERCLA
DOC DATE OSWER/EPA ID DOC NUMBER
12/1/1993 OSWER#9360 0-32FS C188
TITLE
DESIGN. CONSTRUCTION, AND EVALUATION OF CLAY LINERS FOR WASTE MANAGEMENT FACILITIES.
DOC DATE OSWER/EPA ID DOC NUMBER
11/1/1988 EPA/530/SW-86/007F 2201
TITLE
ARARs Q's & A's: STATE GROUND-WATER ANTIDEGRADATION ISSUES.
DOC DATE OSWER/EPA ID DOC NUMBER
7/1/1990 9234.2-11FS C191
TITLE
CERCLA COMPLIANCE WITH THE RCRA TOXICITY CHARACTERISTICS (TC) RULE: PART II.
DOC DATE OSWER/EPA ID DOC NUMBER
10/1/1990 9347.3-11FS C190
TITLE
ARARs Q's & A's: COMPLIANCE WITH FEDERAL WATER QUALITY CRITERIA.
DOC DATE OSWER/EPA ID DOC NUMBER
6/1/1990 9234.2-09/FS C192
TITLE
ARARs Q's & A's. COMPLIANCE WITH THE TOXICITY CHARACTERISTICS RULE: PART I.
DOC DATE OSWER/EPA ID DOC NUMBER
5/1/1990 9234.2-08/FS C193
TITLE
BASICS OF PUMP-AND-TREAT GROUND-WATER REMEDIATION TECHNOLOGY
DOC DATE OSWER/EPA ID DOC NUMBER
3/1/1990 EPA/600/8-90/003 C194
TITLE
FINAL GUIDANCE FOR COORDINATING ATSDR HEALTH ASSESSMENT ACTIVITIES WITH THE
SUPERFUND REMEDIAL PROCESS.
DOC DATE OSWER/EPA ID DOC NUMBER
3/11/1987 9285.4-02 C195
TITLE
ALTERNATE CONCENTRATION LIMIT GUIDANCE BASED ON S264.94(b) CRITERIA. PART I. INFORMATION
REQUIRED IN ACL DEMONSTRATIONS. DRAFT
DOC DATE OSWER/EPA ID DOC NUMBER
6/1/1985 C196
TITLE
FATE OF POLY CHLORINATED BIPHENYLS (PCBs) IN SOIL FOLLOWING STABILIZATION WITH
QUICKLIME
DOC DATE OSWER/EPA ID DOC NUMBER
9/1/1991 EPA/600/2-91/052 C197
Wednesday, May 05, 2004 Page 37
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GUIDANCE DOCUMENTS
TITLE
STABILIZATION/SOLIDIFICATION OF CERCLA AND RCRA WASTES. PHYSICAL TESTS, CHEMICAL
TESTING PROCEDURES, TECHNOLOGY SCREENING, AND FIELD ACTIVITIES.
DOC DATE OSWER/EPA ID DOC NUMBER
5/1/1989 EPA/625/6-89/022 C198
TITLE
HEALTH CONSULTATION, DENNY FARM INCINERATOR CLOSURE PLAN
DOC DATE OSWER/EPA ID DOC NUMBER
7/14/1968 C199
TITLE
GUIDANCE ON KEY TERMS USED IN SUPERFUND.
DOC DATE OSWER/EPA ID DOC NUMBER
9200.5-220 C200
TITLE
INNOVATIVE TREATMENT TECHNOLOGIES. DRAFT.
DOC DATE OSWER/EPA ID DOC NUMBER
2/1/1991 9380.3-OSFS C201
TITLE
IMMOBILIZATION AS TREATMENT. DRAFT.
DOC DATE OSWER/EPA ID DOC NUMBER
2/1/1991 9380.3-07FS C202
TITLE
SUPERFUND INNOVATIVE TECHNOLOGY EVALUATION. INTERNATIONAL WASTE TECHNOLOGIES/
GEO-CON IN SITU STABILIZATION/SOLIDIFICATION. APPLICATIONS ANALYSIS.
DOC DATE OSWER/EPA ID DOC NUMBER
8/1/1990 EPA/540/A5-89/004 C203
TITLE
TOXICOLOGICAL PROFILE FOR POLYCYCLIC AROMATIC HYDROCARBONS.
DOC DATE OSWER/EPA ID DOC NUMBER
12/1/1990 ATSPR/TP-90-20 C204
TITLE
SUPERFUND RESPONSIVENESS SUMMARIES. (SUPERFUND MANAGEMENT REVIEW:
RECOMMENDATION # 43E)
DOC DATE OSWER/EPA ID DOC NUMBER
6/7/1990 9203.0-06 C205
TITLE
SUGGESTED ROD LANGUAGE FOR VARIOUS GROUND WATER REMEDIATION OPTIONS.
DOC DATE OSWER/EPA ID DOC NUMBER
10/10/1990 9283.1-03 C206
Wednesday, May 05, 2004
Page
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GUIDANCE DOCUMENTS
TITLE
NATIONAL PRIMARY DRINKING WATER REGULATIONS, SYNTHETIC ORGANIC CHEMICALS;
MONITORING FOR UNREGULATED CONTAMINANTS; FINAL RULE. 40 CFR PARTS 141 & 142.
DOC DATE OSWER/EPA ID DOC NUMBER
7/8/1987 C207
TITLE
NATIONAL PRIMARY DRINKING WATER REGULATIONS; VOLATILE SYNTHETIC ORGANIC CHEMICALS;
FINAL RULE AND PROPOSED RULE. 40 CFR PARTS 141 & 142.
DOC DATE OSWER/EPA ID DOC NUMBER
11/13/1965 C208
TITLE
DRINKING WATER REGULATIONS; MAXIMUM CONTAMINANT LEVEL GOALS AND NATIONAL PRIMARY
DRINKING WATER REGULATIONS FOR LEAD AND COPPER; PROPOSED RULE.
DOC DATE OSWER/EPA ID DOC NUMBER
8/18/1988 C209
TITLE
NATIONAL PRIMARY AND SECONDARY DRINKING WATER REGULATIONS; SYNTHETIC ORGANIC
CHEMICALS AND INORGANIC CHEMICALS PROPOSED RULE. 40 CFR PART 141 et at.
DOC DATE OSWER/EPA ID DOC NUMBER
7/25/1990 C210
TITLE
NATIONAL PRIMARY AND SECONDARY DRINKING WATER REGULATIONS; PROPOSED RULE. 40 CFR
PARTS 141, 142 & 143.
DOC DATE OSWER/EPA ID DOC NUMBER
5/22/1969 C211
TITLE
REMEDIAL ACTION AT WASTE DISPOSAL SITES. HANDBOOK
DOC DATE OSWER/EPA ID DOC NUMBER
6/1/1982 EPA-625/6-82-006 C212
TITLE
CONSISTENT IMPLEMENTATION OF THE FY 1993 GUIDANCE ON TECHNICAL IMPRACTICABILITY OF
GROUND-WATER RESTORATION AT SUPERFUND SITES
DOC DATE OSWER/EPA ID DOC NUMBER
1/19/1995 9200.4-14 C213
TITLE
FINAL REVISIONS TO OMB CIRCULAR A-94 ON GUIDELINES AND DISCOUNT RATES FOR BENEFIT-COST
ANALYSIS.
DOC DATE OSWER/EPA ID DOC NUMBER
6/25/1993 9355.3-20 C214
TITLE
DENSE NONAQUEOUS PHASE LIQUIDS. A WORKSHOP SUMMARY. DALLAS, TX APRIL 16-18, 1991.
DOC DATE OSWER/EPA ID DOC NUMBER
2/1/1992 EPA/600/R-92/030 C215
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GUIDANCE DOCUMENTS
TITLE
CONSIDERATIONS IN GROUND-WATER REMEDIATION AT SUPERFUND SITES AND RCRA FACILITIES.
UPDATE
DOC DATE OSWER/EPA ID DOC NUMBER
5/27/1992 9283.1-06 C216
TITLE
AIR/SUPERFUND NATIONAL TECHNICAL GUIDANCE STUDY SERIES. ASSESSING POTENTIAL INDOOR
AIR IMPACTS FOR SUPERFUND SITES.
DOC DATE OSWER/EPA ID DOC NUMBER
9/1/1992 EPA-45 l/R-92-002 C217
TITLE
ESTIMATING POTENTIAL FOR OCCURRENCE OF DNAPL AT SUPERFUND SITES.
DOC DATE OSWER/EPA ID DOC NUMBER
1/1/1992 9355.4-07FS C218
TITLE
RISK ASSESSMENT GUIDANCE FOR SUPERFUND. VOL 1. HUMAN HEALTH EVALUATION MANUAL
SUPPLEMENTAL GUIDANCE. STANDARD DEFAULT EXPOSURE FACTORS. INTERIM FINAL.
DOC DATE OSWER/EPA ID DOC NUMBER
3/25/1991 9265.6-03 C219
TITLE
FINAL GUIDELINES FOR EXPOSURE ASSESSMENT. PCS. 22888-22938
DOC DATE OSWER/EPA ID DOC NUMBER
5/29/1992 C220
TITLE
REDUCING RISK: SETTING PRIORITIES AND STRATEGIES FOR ENVIRONMENTAL PROTECTION
DOC DATE OSWER/EPA ID DOC NUMBER
9/1/1990 SAB-EC-90-021 C221
TITLE
SUPERFUND INNOVATIVE TECHNOLOGY EVALUATION. CF SYSTEMS ORGANICS EXTRACTION
PROCESS. NEW BEDFORD HARBOR. MA. APPLICATIONS ANALYSIS REPORT.
DOC DATE OSWER/EPA ID DOC NUMBER
8/1/1990 EPA/540/A5-90/002 C222
TITLE
PROCEEDINGS OF THE SYMPOSIUM ON SOIL VENTING. APRIL 29 - MAY 1, 1991. HOUSTON, TX.
DOC DATE OSWER/EPA ID DOC NUMBER
9/1/1992 EPA/600/R-92/174 C223
TITLE
SITE CHARACTERIZATION FOR SUBSURFACE REMEDIATION. SEMINAR PUBLICATION.
DOC DATE OSWER/EPA ID DOC NUMBER
11/1/1991 EPA/625/4-91/026 C224
Wednesday, May 05, 2004 Page 40
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GUIDANCE DOCUMENTS
TITLE
COMPENDIUM OF METHODS FOR THE DETERMINATION OF TOXIC ORGANIC COMPOUNDS IN AMBIENT
AIR. INCLUDES SEPT. 1986 SUPPLEMENT EPA/600/4-87/006.
DOC DATE OSWER/EPA ID DOC NUMBER
4/1/1984 EPA-600/4-84-041 C225
TITLE
SUPERFUND AUTOMATED RECORDS OF DECISION SYSTEM (RODS) USERS MANUAL.
DOC DATE OSWER/EPA ID DOC NUMBER
8/1/1988 EPA/540/G-89/005 C226
TITLE
DERMAL EXPOSURE ASSESSMENT: PRINCIPLES AND APPLICATIONS. INTERIM REPORT
DOC DATE OSWER/EPA ID DOC NUMBER
1/1/1992 EPA/600/8-91/0116 C227
TITLE
HEALTH EFFECTS ASSESSMENT SUMMARY TABLES (HEAST). FY-1994 ANNUAL.
DOC DATE OSWER/EPA ID DOC NUMBER
3/1/1994 EPA/540/R-94/020 C228
TITLE
PINETTES FEASIBILITY STUDY (FS) SCOPING MEETING HANDOUT.
DOC DATE OSWER/EPA ID DOC NUMBER
8/18/1967 C229
TITLE
PROPOSAL FOR THE CONNECTICUT CLEAN-UP STANDARD REGULATIONS.
DOC DATE OSWER/EPA ID DOC NUMBER
12/1/1994 C230
TITLE
STREAMLINED APPROACH FOR SETTLEMENTS WITH DE MINIMIS WASTE CONTRIBUTORS UNDER
CERCLA SECTION 122 (g)(1)(A)
DOC DATE OSWER/EPA ID DOC NUMBER
7/30/1993 OSWER #9834.7-10 C231
TITLE
INTERIM CASHOUT SETTLEMENT PROCEDURES.
DOC DATE OSWER/EPA ID DOC NUMBER
1/7/1992 C232
TITLE
CLASSIFICATION OF WETLANDS AND DEEPWATER HABITATS OF THE UNITED STATES.
DOC DATE OSWER/EPA ID DOC NUMBER
12/1/1979 FWS/OBS-79/31 C233
TITLE
INTERIM GUIDELINES AND SPECIFICATIONS FOR PREPARING QUALITY ASSURANCE PROJECT PLANS.
DOC DATE OSWER/EPA ID DOC NUMBER
12/29/1980 QAMS-005/80 C234
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GUIDANCE DOCUMENTS
TITLE
RISK ASSESSMENT IN SUPERFUND: A PRIMER. FIRST EDITION. SEPTEMBER 1990.
DOC DATE OSWER/EPA ID DOC NUMBER
4/1/1991 EPA/540/X-91/002 C235
TITLE
INNOVATIVE TREATMENT TECHNOLOGIES: OVERVIEW AND GUIDE TO INFORMATION SOURCES.
DOC DATE OSWER/EPA ID DOC NUMBER
10/1/1991 EPA/540/9-91/002 C236
TITLE
SUPERFUND INNOVATIVE TECHNOLOGY EVALUATION. TERRA VAC IN SITU VACUUM EXTRACTION
SYSTEM. APPLICATIONS ANALYSIS REPORT.
DOC DATE OSWER/EPA ID DOC NUMBER
7/1/1989 EPA/540/A5-89/D03 C237
TITLE
ASBESTOS-CONTAINING MATERIALS IN SCHOOL BUILDINGS: A GUIDANCE DOCUMENT. PART I
DOC DATE OSWER/EPA ID DOC NUMBER
3/1/1979 C00090 C238
TITLE
GUIDANCE ON LANDOWNER LIABILITY UNDER SECTION 107(a)(1) OF CERCLA, DE MINIMIS
SETTLEMENTS UNDER SECTION 122(g)(1)(B) OF CERCLA.
DOC DATE OSWER/EPA ID DOC NUMBER
6/6/1989 9835.9 C239
TITLE
SUMMARY OF GUIDANCE ON LANDOWNER LIABILITY UNDER SECTION 107(a) 1 OF CERCLA, DE
MINIMIS SETTLEMENTS UNDER SECTION 122(g)(1)(b) OF CERCLA. FACT SHEET
DOC DATE OSWER/EPA ID DOC NUMBER
5/1/1991 9835.9FS C240
TITLE
BRODHEAD CREEK, STROUDSBURG, PA. EPA REGION III. RECORD OF DECISION. MAY BE VIEWED AT
THE EPA NEW ENGLAND LIBRARY
DOC DATE OSWER/EPA ID DOC NUMBER
3/29/1991 C241
TITLE
FAIRFIELD COAL GASIFICATION, FAIRFIELD, IA. EPA REGION VII. RECORD OF DECISION. MAY BE
VIEWED AT EPA NEW ENGLAND LIBRARY.
DOC DATE OSWER/EPA ID DOC NUMBER
9/1/1990 C242
TITLE
LIQUID DISPOSAL, INC., UTICA, MI. EPA REGION V. RECORD OF DECISION. MAY BE VIEWED AT EPA
NEW ENGLAND LIBRARY
DOC DATE OSWER/EPA ID DOC NUMBER
9/30/1987 C243
Wednesday, May 05, 2004
Page 42
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GUIDANCE DOCUMENTS
TITLE
PEOPLES NATURAL GAS COAL GASIFICATION, DUBUQUE, IA. EPA REGION VII RECORD OF DECISION.
MAY BE VIEWED AT EPA NEW ENGLAND LIBRARY.
DOC DATE OSWER/EPA ID DOC NUMBER
9/1/1991 C244
TITLE
PEPPER STEEL. FLORIDA. EPA REGION IV. ENFORCEMENT DECISION DOCUMENT. MAY BE VIEWED AT
EPA NEW ENGLAND LIBRARY.
DOC DATE OSWER/EPA ID DOC NUMBER
3/19/1986 C24S
TITLE
WIDE BEACH. NEW YORK. EPA REGION II. RECORD OF DECISION. MAY BE VIEWED AT EPA NEW
ENGLAND LIBRARY.
DOC DATE OSWER/EPA ID DOC NUMBER
9/30/1965 C246
TITLE
DESIGN AND CONSTRUCTION OF RCRA/CERCLA FINAL COVERS.
DOC DATE OSWER/EPA ID DOC NUMBER
5/1/1991 EPA/625/4-91/025 C247
TITLE
GUIDE FOR CONDUCTING TREATABILITY STUDIES UNDER CERCLA: SOIL VAPOR EXTRACTION.
INTERIM GUIDANCE
DOC DATE OSWER/EPA ID DOC NUMBER
9/1/1991 EPA/540/2-91/019A C24B
TITLE
INTERIM FINAL GUIDANCE ON PREPARING SUPERFUND DECISION DOCUMENTS: PROPOSED PLAN,
RECORD OF DECISION, ESD, RECORD OF DECISION AMENDMENT
DOC DATE OSWER/EPA ID DOC NUMBER
6/1/1989 OSWER #9355.3-02 C249
TITLE
FURTHERING THE USE OF INNOVATIVE TREATMENT TECHNOLOGIES IN OSWER PROGRAMS. MISSING
PCS. 15 & i
DOC DATE OSWER/EPA ID DOC NUMBER
6/10/1991 OSWER #9380.0-17 C250
TITLE
ECOLOGICAL ASSESSMENT OF HAZARDOUS WASTE SITES: A FIELD AND LABORATORY REFERENCE
DOC DATE OSWER/EPA ID DOC NUMBER
3/1/1969 EPA/600/3-69/013 C251
TITLE
TRANSPORT AND FATE OF CONTAMINANTS IN THE SUBSURFACE. SEMINAR PUBLICATION.
DOC DATE OSWER/EPA ID DOC NUMBER
9/1/1989 EPA/625/4-89/019 C252
Wednesday, May 05, 2004 Page 43
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GUIDANCE DOCUMENTS
TITLE
RAPID BIOASSESSMENT PROTOCOLS FOR USE IN STREAMS AND RIVERS. BENTHIC
MACROINVERTEBRATES AND FISH.
DOC DATE OSWER/EPA ID DOC NUMBER
5/1/1989 EPA/444/4-89-001 C253
TITLE
GUIDE ON REMEDIAL ACTIONS AT SUPERFUND SITES WITH PCB CONTAMINATION. QUICK REFERENCE
FACT SHEET
DOC DATE OSWER/EPA ID DOC NUMBER
8/1/1990 OSWER #9355.4-01 FS C254
TITLE
STRUCTURE AND COMPONENTS OF FIVE YEAR REVIEWS.
DOC DATE OSWER/EPA ID DOC NUMBER
5/23/1991 OSWER #9355.7-02 C255
TITLE
COMPLIANCE WITH THE CLEAN AIR ACT AND ASSOCIATED AIR QUALITY REQUIREMENTS. ARARS
FACT SHEET.
DOC DATE OSWER/EPA ID DOC NUMBER
9/1/1992 OSWER 09234.2-22FS C256
TITLE
CONTAMINANTS AND REMEDIAL OPTIONS AT SELECTED METAL-CONTAMINATED SITES.
DOC DATE OSWER/EPA ID DOC NUMBER
7/1/1995 EPA/540/R-95/512 C257
TITLE
GROUND-WATER TREATMENT TECHNOLOGY RESOURCE GUIDE.
DOC DATE OSWER/EPA ID DOC NUMBER
9/1/1994 EPA/542-B-94-009 C258
TITLE
GUIDE TO ADDRESSING PRE-ROD AND POST-ROD CHANGES.
DOC DATE OSWER/EPA ID DOC NUMBER
4/1/1991 OSWER #9355.02FS-4 C259
TITLE
COMMUNITY RELATIONS IN SUPERFUND: A HANDBOOK
DOC DATE OSWER/EPA ID DOC NUMBER
3/1/1986 OSWER #9230.0-3A C260
TITLE
SUPERFUND REFORMS: UPDATING REMEDY DECISIONS MEMORANDUM
DOC DATE OSWER/EPA ID DOC NUMBER
9/27/1996 EPA 540/F-96/026 C261
TITLE
AMBIENT WATER QUALITY CRITERIA FOR ARSENIC - 1984
DOC DATE OSWER/EPA ID DOC NUMBER
1/1/1985 EPA 440/5-84-033 C262
Wednesday, May 05, 2004 Page 44
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GUIDANCE DOCUMENTS
TITLE
SUPERFUND REMOVAL PROCEDURES ACTION MEMORANDUM GUIDANCE
DOC DATE OSWER/EPA ID DOC NUMBER
9/1/1990 OSWER #9380.3-01 C263
TITLE
USER'S GUIDE TO THE VOCS IN SOILS PRESUMPTIVE REMEDY
DOC DATE OSWER/EPA ID DOC NUMBER
7/1/1996 OSWER #9355.063FS C264
TITLE
RESIDENTS GUIDE TO TEMPORARY RELOCATION RALPH GRAY TRUCKING COMPANY SUPERFUND
SITE, WESTMINSTER, CA. (REVISED)
DOC DATE OSWER/EPA ID DOC NUMBER
3/1/1995 C265
TITLE
EFFECT OF SUPERFUND ON INVOLUNTARY ACQUISITIONS OF CONTAMINATED PROPERTY BY
GOVERNMENT ENTITIES QUICK REFERENCE FACT SHEET
DOC DATE OSWER/EPA ID DOC NUMBER
12/1/1995 C266
TITLE
ENGINEERING FORUM ISSUE PAPER: SOIL VAPOR EXTRACTION IMPLEMENTATION EXPERIENCES
DOC DATE OSWER/EPA ID DOC NUMBER
4/1/1996 OSWER #9200.5-223FS C267
TITLE
ECO UPDATE. ECOLOGICAL SIGNIFICANCE AND SELECTION OF CANDIDATE ASSESSMENT ENDPOINTS
INTERMITTENT BULLETIN VOLUME 3, NUMBER 1
DOC DATE OSWER/EPA ID DOC NUMBER
1/1/1996 OSWER #9345.0-11 FSI C26B
TITLE
ECO UPDATE. ECOTOX THRESHOLDS. INTERMITTENT BULLETIN VOLUME 3. NUMBER 2
DOC DATE OSWER/EPA ID DOC NUMBER
1/1/1996 OSWER 89345.0-12FSI C269
TITLE
INITIATIVES TO PROMOTE INNOVATIVE TECHNOLOGY IN WASTE MANAGEMENT PROGRAMS
DOC DATE OSWER/EPA ID DOC NUMBER
4/29/1996 OSWER #9380.0-25 C270
TITLE
FINAL POLICY TOWARD OWNERS OF PROPERTY CONTAINING CONTAMINATED AQUIFERS
DOC DATE OSWER/EPA ID DOC NUMBER
5/24/1995 C271
TITLE
GUIDANCE ON AGREEMENTS WITH PROSPECTIVE PURCHASERS OF CONTAMINATED PROPERTY
DOC DATE OSWER/EPA ID DOC NUMBER
5/24/1995 C272
Wednesday, May 05, 2004 Page 45
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GUIDANCE DOCUMENTS
TITLE
GROUNDWATER USE AND VALUE DETERMINATION GUIDANCE. A RESOURCE-BASED APPROACH TO
DECISION MAKING. FINAL DRAFT.
DOC DATE OSWER/EPA ID DOC NUMBER
4/3/1996 C273
TITLE
INNOVATIVE TREATMENT TECHNOLOGIES: ANNUAL STATUS REPORT (FIFTH EDITION)
DOC DATE OSIER/EPA ID DOC NUMBER
9/1/1993 EPA 542-R-93-003 C274
TITLE
GUIDE TO DEVELOPING SUPERFUND NO ACTION. INTERIM ACTION, AND CONTINGENCY REMEDY
RODS
DOC DATE OSWER/EPA ID DOC NUMBER
4/1/1991 OSWER 89355.3-02FS-3 C275
TITLE
ROLE OF THE BASELINE RISK ASSESSMENT IN SUPERFUND REMEDY SELECTION DECISION:
DOC DATE OSWER/EPA ID DOC NUMBER
4/22/1991 OSWER 09355.0-30 C276
TITLE
RISK-BASED CONCENTRATION TABLE. THIRD QUARTER 1994
DOC DATE OSWER/EPA ID DOC NUMBER
7/11/1994 C277
TITLE
FINAL GROUND WATER USE AND VALUE DETERMINATION GUIDANCE
DOC DATE OSWER/EPA ID DOC NUMBER
4/4/1996 C278
TITLE
DOCUMENTATION OF CLOSE OUT REQUIREMENTS AT SITES WHERE THERE IS NO ACTION RECORD OF
DECISION (DOCUMENT MISSING)
DOC DATE OSWER/EPA ID DOC NUMBER
2/2/1993 C279
TITLE
ARAR'S FACT SHEET: COMPLIANCE WITH CLEAN THE CLEAN AIR ACT AND ASSOCIATED AIR QUALITY
REQUIREMENTS
DOC DATE OSWER/EPA ID DOC NUMBER
9/1/1992 C281
TITLE
SUPERFUND AMENDMENTS AND REAUTHORIZATION ACT OF 1986
DOC DATE OSWER/EPA ID DOC NUMBER
C282
TITLE
DETERMINATION OF IMMINENT AND SUBSTANTIAL ENDANGERMENT FOR REMOVAL ACTIONS
DOC DATE OSWER/EPA ID DOC NUMBER
8/19/1993 OSWER #360.0-34 C2B3
Wednesday, May 05, 2004 Page 46
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GUIDANCE DOCUMENTS
TITLE
TRANSMITTAL OF SUPERFUND REMOVAL PROCEDURES- REMOVAL ENFORCEMENT GUIDANCE FOR
ON-SCENE COORDINATORS
DOC DATE OSWER/EPA ID DOC NUMBER
8/6/1992 OSIER #9360.3-06 C284
TITLE
TRANSMITTAL OF SUPERFUND REMOVAL PROCEDURES- PUBLIC PARTICIPATION GUIDANCE FOR
ON-SCENE COORDINATORS COMMUNITY RELATIONS AND THE ADMINISTRATIVE RECORD
DOC DATE OSWER/EPA ID DOC NUMBER
6/23/1992 OSIER #9360.3-05 C265
TITLE
TOXICOLOGICAL PROFILE FOR POLY CHLORINATED BIPHENYLS (UPDATE)
DOC DATE OSWER/EPA ID DOC NUMBER
9/1/1997 C286
TITLE
REGULATION FILING AND PUBLICATION- REGULATION CHAPTER NUMBER AND HEADING 310 CMR
40.000
DOC DATE OSWER/EPA ID DOC NUMBER
11/19/1993 C287
TITLE
RISK UPDATE ISSUE NO. 2
DOC DATE OSWER/EPA ID DOC NUMBER
8/1/1994 C288
TITLE
POLY CHLORINATED BIPHENYLS (PCBS): DERMAL ABSORPTION, SYSTEMIC ELIMINATION, AND
DERMAL WASH EFFICIENCY
DOC DATE OSWER/EPA ID DOC NUMBER
1/1/1963 C289
TITLE
EFFECT OF INTRAUTERINE PCB EXPOSURE ON VISUAL RECOGNITION MEMORY
DOC DATE OSWER/EPA ID DOC NUMBER
1/1/1985 C290
TITLE
STUDY OF HUMAN LACTATION FOR EFFECTS OF ENVIRONMENTAL CONTAMINANTS: THE NORTH
CAROLINA BREAST MILK AND FORMULA PROJECT AND SOME OTHER IDEAS
DOC DATE OSWER/EPA ID DOC NUMBER
1/1/1985 C291
TITLE
POTENTIAL REPRODUCTIVE AND POSTNATAL MORBIDITY FROM EXPOSURE TO POLY CHLORINATED
BIPHENYLS: EPIDEMIOLOGIC CONSIDERATIONS
DOC DATE OSWER/EPA ID DOC NUMBER
1/1/1985 C292
Wednesday, May 05, 2004
Page 47
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GUIDANCE DOCUMENTS
TITLE
IN VIVO IN VITRO ABSORPTION AND BINDING TO POWDERED STRATUM CORNEUM AS METHODS TO
EVALUATE SKIN ABSORPTION OF ENVIRONMENTAL CHEMICAL CONTAMINANTS
DOC DATE OSWER/EPA ID DOC NUMBER
1/1/1987 C293
TITLE
STATISTICAL METHODS FOR ENVIRONMENTAL POLLUTION MONITORING
DOC DATE OSWER/EPA ID DOC NUMBER
1/1/1987 C294
TITLE
SUPERFUND REMOVAL PROCEDURES: ACTION MEMORANDUM GUIDANCE (EPA/540/P-90/004)
DOC DATE OSWER/EPA ID DOC NUMBER
12/1/1990 C295
TITLE
CONGENITAL POISONING BY POLY CHLORINATED BIPHENYLS AND THEIR CONTAMINANTS IN TAIWAN
DOC DATE OSWER/EPA ID DOC NUMBER
1/1/1988 C296
TITLE
POTENTIAL FOR BIOLOGICAL EFFECTS OF SEDIMENT-SORB ED CONTAMINANTS TESTED IN THE
NATIONAL STATUS AND TRENDS PROGRAM
DOC DATE OSWER/EPA ID DOC NUMBER
8/1/1991 C510
TITLE
PERCUTANEOUS ABSORPTION AND SKIN DECONTAMINATION OF PCBS: IN VITRO STUDIES WITH
HUMAN SKIN AND IN VIVO STUDIES IN THE RHESUS MONKEY
DOC DATE OSWER/EPA ID DOC NUMBER
1/1/1990 C299
TITLE
EFFECTS OF EXPOSURE OF TO PCBS AND RELATED COMPOUNDS ON GROWTH AND ACTIVITY IN
CHILDREN
DOC DATE OSWER/EPA ID DOC NUMBER
1/1/1990 C300
TITLE
POLY CHLORINATED BIPHENYLS AND THE DEVELOPING NERVOUS SYSTEM: CROSS-SPECIES
COMPARISONS
DOC DATE OSWER/EPA ID DOC NUMBER
1/1/1990 C301
TITLE
EFFECTS OF IN UTERO EXPOSURE TO POLY CHLORINATED BIPHENYLS AND RELATED CONTAMINANTS
ON COGNITIVE FUNCTIONING IN YOUNG CHILDREN
DOC DATE OSWER/EPA ID DOC NUMBER
1/1/1990 C302
Wednesday, May 05, 2004
Page 48
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GUIDANCE DOCUMENTS
TITLE
PERCUTANEOUS ABSORPTION OF PCBS FROM SOIL: IN VIVO RHESUS MONKEY. IN VITRO HUMAN SKIN,
AND BINDING TO POWDERED HUMAN STRATUM CORNEUM
DOC DATE OSWER/EPA ID DOC NUMBER
1/1/1993 C303
TITLE
ESTIMATING CONSUMPTION OF FRESHWATER FISH AMONG MAINE ANGLERS
DOC DATE OSWER/EPA ID DOC NUMBER
1/1/1993 C308
TITLE
NEUROTOXCITY OF LEAD, METHYLMERCURY, AND PCBS IN RELATION TO THE GREAT LAKES
DOC DATE OSWER/EPA ID DOC NUMBER
1/1/1995 C309
TITLE
EFFECT OF POSTNATAL EXPOSURE TO A PCB MIXTURE IN MONKEYS ON MULTIPLE FIXED INTERVAL-
FIXED RATIO PERFORMANCE
DOC DATE OSWER/EPA ID DOC NUMBER
1/1/1997 C310
TITLE
WORKSHOP REPORT ON DEVELOPMENTAL NEUROTOXIC EFFECTS ASSOCIATED WITH EXPOSURE TO
PCBS-SEPTEMBER 14-15, 1992
DOC DATE OSWER/EPA ID DOC NUMBER
5/1/1993 C312
TITLE
LAND USE IN THE CERCLA REMEDY SELECTION PROCESS
DOC DATE OSWER/EPA ID DOC NUMBER
1/1/1995 OSIER #9355.704 C317
TITLE
TOXICOLOGICAL CONSEQUENCES OF AROCLOR 1254 INGESTION BY FEMALE RHESUS (MACACA
MULATTA) MONKEYS. PART 2 REPRODUCTION AND INFANT FINDINGS
DOC DATE OSWER/EPA ID DOC NUMBER
1/1/1995 C318
TITLE
WATER QUALITY GUIDANCE FOR THE GREAT LAKES SYSTEM: SUPPLEMENTARY INFORMATION
DOCUMENT (SID) (EPA-820-B95-001)
DOC DATE OSWER/EPA ID DOC NUMBER
3/1/1995 C324
TITLE
PUBLIC HEALTH IMPLICATIONS OF PCB EXPOSURES
DOC DATE OSWER/EPA ID DOC NUMBER
12/1/1996 C329
Wednesday, May 05, 2004 Page 49
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GUIDANCE DOCUMENTS
TITLE
LESSONS FORNEUROTOXICOLOGY FROM SELECTED MODEL COMPOUNDS: SGOMSEC JOINT REPORT
DOC DATE OSWER/EPA ID DOC NUMBER
4/1/1996 C330
TITLE
PCBS: CANCER DOSE-RESPONSE ASSESSMENT AND APPLICATION TO ENVIRONMENTAL MIXTURES
DOC DATE OSWER/EPA ID DOC NUMBER
9/1/1996 C340
TITLE
HEALTH ADVISORIES FOR CONSUMERS OF GREAT LAKES SPORT FISH: IS THE MESSAGE BEING
RECEIVED?
DOC DATE OSWER/EPA ID DOC NUMBER
12/1/1997 C347
TITLE
DERMAL WORKGROUP RESPONSE TO GE'S CHALLENGE TO THE SOIL DERMAL ABSORPTION VALUE
FOR PCBS OF 14%
DOC DATE OSWER/EPA ID DOC NUMBER
!/27/1998 C350
TITLE
EXPOSURE FACTORS HANDBOOK; GENERAL FACTORS, VOLUME I
DOC DATE OSWER/EPA ID DOC NUMBER
8/1/1997 EPA/600/P-95/002FA C356
TITLE
ECOLOGICAL RISK ASSESSMENT GUIDANCE FOR SUPERFUND PROCESS FOR DESIGNING AND
CONDUCTING ECOLOGICAL RISK ASSESSMENTS (EPA 540-R-97-006)
DOC DATE OSWER/EPA ID DOC NUMBER
6/2/1997 C361
TITLE
REVIEW OF ECOLOGICAL ASSESSMENT CASE STUDIES FROM A RISK ASSESSMENT PERSPECTIVE
DOC DATE OSWER/EPA ID DOC NUMBER
5/1/1993 C363
TITLE
SPECIAL REPORT ON ENVIRONMENTAL ENDOCRINE DISRUPTION. AN EFFECTS ASSESSMENT AND
ANALYSIS
DOC DATE OSWER/EPA ID DOC NUMBER
6/29/1997 C362
TITLE
FRAMEWORK FOR ECOLOGICAL RISK ASSESSMENT (EPA/630/R-92/001)
DOC DATE OSWER/EPA ID DOC NUMBER
2/1/1992 C364
Wednesday, May 05, 2004
Page 50
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GUIDANCE DOCUMENTS
TITLE
REPORT FROM THE WORKSHOP ON THE APPLICATION OF 2,3 .7,8 - TCDD TOXICITY EQUIVALENCY
FACTORS TO FISH AND WILDLIFE
DOC DATE OSWER/EPA ID DOC NUMBER
3/31/1998 C365
TITLE
DRAFT FINAL GUIDELINES FOR ECOLOGICAL RISK ASSESSMENT
DOC DATE OSWER/EPA ID DOC NUMBER
7/18/1997 C366
TITLE
REVIEW OF ECOLOGICAL ASSESSMENT CASE STUDIES FROM A RISK ASSESSMENT PERSPECTIVE -
VOLUME II (EPA/630/R-94/003)
DOC DATE OSWER/EPA ID DOC NUMBER
1/1/1994 C367
TITLE
TOXICOLOGICAL BENCHMARKS FOR WILDLIFE: 1996 REVISION
DOC DATE OSWER/EPA ID DOC NUMBER
6/1/1996 C36B
TITLE
ECOLOGICAL RISK ASSESSMENT ISSUE PAPERS (EPA/630/R-94/009)
DOC DATE OSWER/EPA ID DOC NUMBER
11/1/1994 C369
TITLE
ENFORCEMENT UNDER SACM - INTERIM GUIDANCE (VOL. 1, NO. 3)
DOC DATE OSWER/EPA ID DOC NUMBER
!/20/1992 OSIER #9203.1 -051 C370
TITLE
SACM REGIONAL DECISION TEAMS - INTERIM GUIDANCE (VOLUME I, NO. 5)
DOC DATE OSWER/EPA ID DOC NUMBER
12/1/1992 OSIER #9203.1-051 C371
TITLE
SAB REPORT: REVIEW OF SEDIMENT CRITERIA DEVELOPMENT METHODOLOGY FOR NON-IONIC
ORGANIC CONTAMINANTS (EPA-SAB-EPEC-92-002)
DOC DATE OSWER/EPA ID DOC NUMBER
11/1/1992 C372
TITLE
TOXICOLOGICAL BENCHMARKS FOR SCREENING POTENTIAL CONTAMINANTS OF CONCERN FOR
EFFECTS ON AQUATIC BIOTA: 1994 REVISION
DOC DATE OSWER/EPA ID DOC NUMBER
7/1/1994 C376
Wednesday, May 05, 2004
Page
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GUIDANCE DOCUMENTS
TITLE
EVALUATION OF BIOMARKERS IN BROWN BULLHEAD
DOC DATE OSWER/EPA ID DOC NUMBER
3/22/1996 C377
TITLE
UPTAKE OF PLANAR POLYCHLORINATED BIPHENYLS AND 2,3,7,8 - SUBSTITUTED POLY CHLORINATED
DIBENZOFURANS BY BIRDS NESTING IN THE LOWER FOX RIVER
DOC DATE OSWER/EPA ID DOC NUMBER
1/1/1993 C378
TITLE
CURRENT STATUS OF PCB TOXICITY TO MINK, AND EFFECT ON THEIR REPRODUCTION
DOC DATE OSWER/EPA ID DOC NUMBER
1/1/1977 C379
TITLE
POLYCHLORINATED BIPHENYLS (AROCLORS 1016 AND 1242): EFFECTS ON SURVIVAL AND
REPRODUCTION IN MINK AND FERRET
DOC DATE OSWER/EPA ID DOC NUMBER
1/1/1980 C380
TITLE
MONO-ORTHO-CHLORINATED CHLORBIPHENYLS: TOXICITY AND INDUCTION OF 7-ETHOYRESPRUFIN
0-DEETHYLASE (EROD) ACTIVITY IN CHICK EMBRYOS
DOC DATE OSWER/EPA ID DOC NUMBER
1/1/1990 C381
TITLE
EPA'S CONTAMINATED SEDIMENT MANAGEMENT STRATEGY
DOC DATE OSWER/EPA ID DOC NUMBER
11/1/1997 C382
TITLE
ESTIMATING EXPOSURE OF TERRESTIAL WILDLIFE TO CONTAMINANTS
DOC DATE OSWER/EPA ID DOC NUMBER
9/1/1994 C383
TITLE
POLYCHLORINATED BIPHENYL HAZARDS TO FISH, INVERTEBRATES: A SYNOPTIC REVIEW
DOC DATE OSWER/EPA ID DOC NUMBER
4/1/1986 C386
TITLE
EFFECT OF PCB INGESTION ON SLEEPING TIMES, ORGAN WEIGHTS. FOOD CONSUMPTION, SERUM
CORTICOSTERONE, AND SURVIVAL OF ALBINO MICE
DOC DATE OSWER/EPA ID DOC NUMBER
1/1/1974 C388
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GUIDANCE DOCUMENTS
TITLE
BIOACCUMULATION OF TOXICANTS. ELEMENT AND NUTRIENT COMPOSITION, AND SOFT TISSUE
HISTOLOGY OF ZEBRA MUSSELS (DREISSENA POLYMORPHA) FROM NEW YORK STATE
DOC DATE OSWER/EPA ID DOC NUMBER
1/1/1993 C389
TITLE
GUIDELINES FOR THE PROTECTION AND MANAGEMENT OF AQUATIC SEDIMENT QUALITY IN ONTARIO
DOC DATE OSWER/EPA ID DOC NUMBER
1/1/1996 C390
TITLE
ASSESSMENT OF THE REPRODUCTIVE TOXIC POTENTIAL AROCLOR 1254 IN FEMALE
SPRAGUE-DAWLEY RATS
DOC DATE OSWER/EPA ID DOC NUMBER
1/1/1982 C391
TITLE
MICROBIAL DEGRADATION OF POLY CHLORINATED BIPHENYLS IN AQUATIC ENVIRONMENTS
DOC DATE OSWER/EPA ID DOC NUMBER
1/1/1992 C392
TITLE
WATER-RELATED ENVIRONMENTAL FATE OF 129 PRIORITY POLLUTANTS (VOLUME I)
(EPA-440/4-79-029A)
DOC DATE OSWER/EPA ID DOC NUMBER
12/1/1979 C393
TITLE
ENVIRONMENTAL CONTAMINANTS AND REPRODUCTIVE SUCCESS OF GREAT BLUE LAKE HERONS
ARDEA HERODIAS IN BRITISH COLUMBIA, 1986-87
DOC DATE OSWER/EPA ID DOC NUMBER
1/1/1989 C394
TITLE
TECHNICAL BASIS FOR ESTABLISHING SEDIMENT QUALITY CRITERIA FORNONIONIC ORGANIC
CHEMICALS USING EQUILIBRIUM PARTITIONING
DOC DATE OSWER/EPA ID DOC NUMBER
1/1/1991 C395
TITLE
SUPERFUND REMOVAL PROCEDURES SPECIAL CIRCUMSTANCES AND FACT SHEET
DOC DATE OSWER/EPA ID DOC NUMBER
!/22/1998 OSIER #9360.3-09FS C280
TITLE
GUIDANCE ON THE CONSIDERATION OF ARARS DURING REMOVAL ACTIONS
DOC DATE OSWER/EPA ID DOC NUMBER
8/23/1991 OSIER #9360.3-02 C297
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GUIDANCE DOCUMENTS
TITLE
FRAMEWORK FOR ECOLOGICAL RISK ASSESSMENT AT THE EPA
DOC DATE OSWER/EPA ID DOC NUMBER
1/1/1992 C396
TITLE
ONTARIO ECOSYSTEM
DOC DATE OSWER/EPA ID DOC NUMBER
1/1/1988 C397
TITLE
GUIDELINES FOR DERIVING SITE-SPECIFIC SEDIMENT QUALITY CRITERIA FOR THE PROTECTION OF
BENTHIC ORGANISMS (EPA-822-R-93-017)
DOC DATE OSWER/EPA ID DOC NUMBER
9/1/1993 C398
TITLE
TECHNICAL BASIS FOR DERIVING SEDIMENT QUALITY CRITERIA FORNONIONIC ORGANIC
CONTAMINANTS FOR THE PROTECTION OF BENTHIC ORGANISMS BY (EPA-822-R-93-011)
DOC DATE OSWER/EPA ID DOC NUMBER
9/1/1993 C399
TITLE
GREAT LAKES WATER QUALITY INITIATIVE CRITERIA DOCUMENTS FOR THE PROTECTION OF
WILDLIFE (PROPOSED) DDT MERCURY 2,3.7.8 - TCDD PCBS
DOC DATE OSWER/EPA ID DOC NUMBER
4/1/1983 C400
TITLE
AROCLOR 1254 RESIDUES IN BIRDS' LETHAL LEVELS AND LOSS RATES
DOC DATE OSWER/EPA ID DOC NUMBER
1/1/1984 C401
TITLE
CHARACTERIZATION OF COMMERCIAL AROCLORS BY AUTOMATED MASS SPECTROMETRY
DETERMINATION OF POLY CHLORINATED BIPHENYLS BY LEVEL OF CHLORINATION
DOC DATE OSWER/EPA ID DOC NUMBER
1/1/1986 C402
TITLE
MICROCONTAMINANTS AND REPRODUCTIVE IMPAIRMENT OF THE FORSTER'S TERN ON GREEN BAY.
MICHIGAN - 198
DOC DATE OSWER/EPA ID DOC NUMBER
1/1/1989 C403
TITLE
MORPHOLOGICAL CHANGES IN LIVERS OF RATS FED POLY CHLORINATED BIPHENYLS
DOC DATE OSWER/EPA ID DOC NUMBER
11/1/1972 C404
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GUIDANCE DOCUMENTS
TITLE
LETHAL DIETARY TOXICITIES OF ENVIRONMENTAL CONTAMINANTS AND PESTICIDES TO COTURNIX-
FISH AND WILDLIFE TECHNICAL REPORT 2
DOC DATE OSWER/EPA ID DOC NUMBER
1/1/1986 C405
TITLE
ENDPOINTS FOR RESPONSES OF FISH TO CHRONIC TOXIC EXPOSURES - (HAZARD ASSESSMENT)
DOC DATE OSWER/EPA ID DOC NUMBER
1/1/1987 C406
TITLE
DIETARY ACCUMULATION OF PCBS FROM A CONTAMINATED SEDIMENT SOURCE BY A DERMERSAL
FISH (LEIOSTOMUS XANTHURUS)
DOC DATE OSWER/EPA ID DOC NUMBER
1/1/1984 C407
TITLE
SUBLETHAL RESPONSES OF PLATICHTHYS STELLATUS TO ORGANIC CONTAMINATION IN SAN
FRANCISCO BAY WITH EMPHASIS ON REPRODUCTION
DOC DATE OSWER/EPA ID DOC NUMBER
1/1/1990 C408
TITLE
HEPATIC MICROSOMAL MONOOXYGENASES OF SEA BIRDS
DOC DATE OSWER/EPA ID DOC NUMBER
1/1/1984 C409
TITLE
PCBS: STRUCTURE-FUNCTION RELATIONSHIPS AND MECHANISM OF ACTION
DOC DATE OSWER/EPA ID DOC NUMBER
1/1/1985 C410
TITLE
PERINATAL PCB EXPOSURE AND ITS EFFECT ON THE IMMUNE SYSTEM OF YOUNG RABBITS
DOC DATE OSWER/EPA ID DOC NUMBER
1/1/1980 C411
TITLE
DIETARY EFFECTS OF POLY CHLORINATED BIPHENYLS ON MINK
DOC DATE OSWER/EPA ID DOC NUMBER
10/1/1973 C412
TITLE
DETERMINATION OF CRITICAL POLLUTANT LEVELS IN WILD POPULATIONS, WITH EXAMPLES FROM
ORGANOCHLORINE INSECTICIDES IN BIRDS OF PREY
DOC DATE OSWER/EPA ID DOC NUMBER
1/1/1988 C413
Wednesday, May 05, 2004
Page 55
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GUIDANCE DOCUMENTS
TITLE
EFFECT OF POLY CHLORINATED BIPHENYLS ON RAT REPRODUCTION
DOC DATE OSWER/EPA ID DOC NUMBER
1/1/1974 C415
TITLE
ROLE OF STAG'S IN ECOLOGICAL ASSESSMENT - ECO UPDATE - VOL. 1, NO. 1
DOC DATE OSWER/EPA ID DOC NUMBER
9/1/1991 OSIER #9345.0-051 C416
TITLE
EFFECT OF POLY CHLORINATED BIPHENYLS (AROCLOR 1260) ON HISTOLOGY OF ADRENAL OF RATS
DOC DATE OSWER/EPA ID DOC NUMBER
1/1/1993 C417
TITLE
INCIDENCE OF ADVERSE BIOLOGICAL EFFECTS WITHIN RANGES OF CHEMICAL CONCENTRATIONS IN
MARINE AND ESTUARINE SEDIMENTS
DOC DATE OSWER/EPA ID DOC NUMBER
1/1/1995 C418
TITLE
BIOACCUMULATION OF POLY CHLORINATED ORGANIC CONTAMINANTS FROM SEDIMENT BY THREE
MENTHIC MARINE SPECIES
DOC DATE OSWER/EPA ID DOC NUMBER
1/1/1993 C420
TITLE
BIOACCUMULATION PATTERNS OF HYDROCARBONS AND POLY CHLORINATED BIPHENYLS IN
BIVALVES, CRUSTACEANS AND FISHES
DOC DATE OSWER/EPA ID DOC NUMBER
1/1/1993 C420
TITLE
ENDOCRINE BIOMARKERS, ORGANOCHLORINE AND CONGENER SPECIFIC POLY CHLORINATED
BIPHENYLS (PCBS) IN LARGEMOUTH BAS (MICROPTERUS SALMOIDES) FROM WOODS POND
DOC DATE OSWER/EPA ID DOC NUMBER
9/1/1994 C424
TITLE
BIOLOGICAL AND TOXICOLOGICAL EFFECTS OF ENVIRONMENTAL CONTAMINANTS IN FISH AND
THEIR EGGS
DOC DATE OSWER/EPA ID DOC NUMBER
1/1/1983 C428
TITLE
POSSIBLE EFFECTS OF POLY CHLORINATED BIPHENYLS ON SEX DETERMINATION IN RAINBOW TROUT
DOC DATE OSWER/EPA ID DOC NUMBER
1/1/1998 C429
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GUIDANCE DOCUMENTS
TITLE
PATTERNS OF PCB ACCUMULATION BY FRY OF LAKE TROUT
DOC DATE OSWER/EPA ID DOC NUMBER
1/1/1981 C430
TITLE
EFFECTS OF POSTNATAL EXPOSURE TO A PCB MIXTURE IN MONKEYS ON NONSPATIAL REVERSAL
AND DELAYED ALTERNATION PERFORMANCE
DOC DATE OSWER/EPA ID DOC NUMBER
1/1/1997 C434
TITLE
PCB LITERATURE SEARCH (VARIOUS ARTICLES)
DOC DATE OSWER/EPA ID DOC NUMBER
1/1/1997 C433
TITLE
ORGANOCHLORINE AND HEAVY METAL RESIDUES IN STANDARD FILLETS OF COHO AND CHINOOK
SALMON OF THE GREAT LAKES- 1980
DOC DATE OSWER/EPA ID DOC NUMBER
1/1/1982 C435
TITLE
FOOD OF VERTEBRATE PREDATORS ON TROUT WATERS IN NORTH CENTRAL LOWER MICHIGAN
DOC DATE OSWER/EPA ID DOC NUMBER
1/1/1977 C436
TITLE
PATTERNS OF ACCUMULATION BY FRY OF LAKE TROUT
DOC DATE OSWER/EPA ID DOC NUMBER
1/1/1981 C437
TITLE
BIOLOGICAL AND TOXICOLOGICAL EFFECTS OF ENVIRONMENTAL CONTAMINANTS IN FISH AND
THEIR EGGS
DOC DATE OSWER/EPA ID DOC NUMBER
1/1/1963 C438
TITLE
STUDY OF THE HEPATIC MONOOXYGENASE OF SEA BIRDS AND ITS RELATIONSHIP TO
ORGAN CHLORINE POLLUTANTS
DOC DATE OSWER/EPA ID DOC NUMBER
1/1/1982 C439
TITLE
PCBS AS AHH INDUCERS
DOC DATE OSWER/EPA ID DOC NUMBER
1/1/1982 C440
Wednesday, May 05, 2004
Page
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GUIDANCE DOCUMENTS
TITLE
2,3,7,8 TETRACHLORODIBENZO-P-DIOXIN AND RELATED HALOGENATED AROMATIC HYDROCARBONS:
EXAMINATION OF THE MECHANISM OF TOXICITY
DOC DATE OSWER/EPA ID DOC NUMBER
1/1/1982 C441
TITLE
INFLUENCE OF SYMMETRICAL POLY CHLORINATED BIPHENYL ISOMERS ON EMBRYO AND FETAL
DEVELOPMENT IN MICE
DOC DATE OSWER/EPA ID DOC NUMBER
1/1/1989 C442
TITLE
POLY CHLORINATED BIPHENYLS (PCBS). ENVIRONMENTAL IMPACT, BIOCHEMICAL AND TOXIC
RESPONSES, AND IMPLICATIONS FOR RISK ASSESSMENT
DOC DATE OSWER/EPA ID DOC NUMBER
1/1/1994 C443
TITLE
BELTED KINGFISHERS AS ECOLOGICAL MONITORS OF CONTAMINATION: A REVIEW
DOC DATE OSWER/EPA ID DOC NUMBER
1/1/1993 C444
TITLE
FIELD METABOLIC RATE AND FOOD REQUIREMENT SCALING IN MAMMALS AND BIRDS
DOC DATE OSWER/EPA ID DOC NUMBER
1/1/1987 C445
TITLE
GUIDELINES FOR DERIVING NUMERICAL NATIONAL WATER QUALITY FOR THE PROTECTION OF
AQUATIC ORGANISMS AND THEIR USES
DOC DATE OSWER/EPA ID DOC NUMBER
1/1/1985 C447
TITLE
POLY CHLORINATED BIPHENYLS (PCBS) AND POLYBROMINATED BIPHENYLS (PBBS): BIOCHEMISTRY,
TOXICOLOGY, AND MECHANISM IN ACTION
DOC DATE OSWER/EPA ID DOC NUMBER
1/1/1985 C446
TITLE
ENVIRONMENT AND DISEASE: ASSOCIATION OR CAUSATION
DOC DATE OSWER/EPA ID DOC NUMBER
1/1/1965 C448
TITLE
SUMMARY OF EPA SEDIMENT POLICY GOALS
DOC DATE OSWER/EPA ID DOC NUMBER
11/9/1997 C449
Wednesday, May 05, 2004
Page 58
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GUIDANCE DOCUMENTS
TITLE
INITIATION OF FINAL AGENCY REVIEW FOR CONTAMINATED SEDIMENT MANAGEMENT STRATEGY
DOC DATE OSWER/EPA ID DOC NUMBER
11/26/1997 C450
TITLE
TRANSFER OF THE CHLORINATED HYDROCARBON PCB IN A LABORATORY MARINE FOOD CHAIN
DOC DATE OSWER/EPA ID DOC NUMBER
1/1/1977 C456
TITLE
RESIDUE LEVELS OF ORGANOCHLORINE AND MERCURY COMPOUNDS IN UNHATCHED EGGS AND THE
RELATIONSHIPS TO BREEDING SUCCESS IN WHITE-TAILED SEA EAGLES
DOC DATE OSWER/EPA ID DOC NUMBER
1/1/1982 C457
TITLE
DEVELOPMENT OF A RAPID. SENSITIVE, AND QUANTITATIVE TEST FOR THE ASSESSMENT OF THE
EFFECTS OF XENOBIOTICS ON REPRODUCTION IN FISH
DOC DATE OSWER/EPA ID DOC NUMBER
1/1/1984 C458
TITLE
REPRODUCTION DECLINE OF HARBOUR SEALS: PCBS IN THE FOOD AND THEIR EFFECT ON MINK
DOC DATE OSWER/EPA ID DOC NUMBER
1/1/1983 C459
TITLE
HEPATIC MONOOXYGENASE INDUCTION AND PROMUTAGEN ACTIVATION IN CHANNEL CATFISH
FROM A CONTAMINATED RIVER BASIN
DOC DATE OSWER/EPA ID DOC NUMBER
1/1/1988 C460
TITLE
MODELING THE LONG-TERM BEHAVIOR OF AN ORGANIC CONTAMINANT IN A LARGE LAKE:
APPLICATION TO PCBS IN LAKE ONTARIO
DOC DATE OSWER/EPA ID DOC NUMBER
1/1/1989 C461
TITLE
EPA'S CONTAMINATED SEDIMENT MANAGEMENT STRATEGY
DOC DATE OSWER/EPA ID DOC NUMBER
4/1/1998 C462
TITLE
POSSIBLE EFFECTS OF POLY CHLORINATED BIPHENYLS ON SEX DETERMINATION IN RAINBOW TROUT
DOC DATE OSWER/EPA ID DOC NUMBER
1/1/1998 C463
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GUIDANCE DOCUMENTS
TITLE
ENVIRONMENTAL TRANSPORT AND TRANSFORMATION OF POLY CHLORINATED BIPHENYLS
DOC DATE OSWER/EPA ID DOC NUMBER
1/1/1983 C464
TITLE
POLY CHLORINATED BIPHENYLS:
DOC DATE OSWER/EPA ID
4/1/1972
EFFECTS ON PENNED PHEASANTS
DOC NUMBER
C465
TITLE
CANADIAN WATER QUALITY GUIDELINES FOR POLY CHLORINATED BIPHENYLS IN COASTAL AND
ESTUARINE WATERS
DOC DATE OSWER/EPA ID DOC NUMBER
1/1/1991 C466
TITLE
IRIS SUBSTANCE FILE: POLY CHLORINATED BIPHENYLS (PCBS)
DOC DATE OSWER/EPA ID DOC NUMBER
6/1/1997 C467
TITLE
HEALTH EFFECTS ASSESSMENT SUMMARY TABLES - FY 1997 UPDATE (EPA -540-R-97-036)
DOC DATE OSWER/EPA ID DOC NUMBER
7/1/1997 C468
TITLE
DERMAL EXPOSURE ASSESSMENT PRINCIPLES AND APPLICATIONS
DOC DATE OSWER/EPA ID DOC NUMBER
1/1/1992 C469
TITLE
DOCUMENTATION FOR THE RISK ASSESSMENT SHORTFORM RESIDENTIAL SCENARIO(POLICY
8WCS/ORS-142-92)
DOC DATE OSWER/EPA ID DOC NUMBER
10/1/1992 C470
TITLE
DRAFT INTERIM FINAL OSIER MONITORED NATURAL ATTENUATION POLICY
DOC DATE OSWER/EPA ID DOC NUMBER
12/1/1997 OSIER #9200.4-17 C474
TITLE
EXECUTIVE ORDER 119B8 - FLOODPLAIN MANAGEMENT
DOC DATE OSWER/EPA ID DOC NUMBER
5/24/1977 C471
TITLE
EXECUTIVE ORDER 11990 - PROTECTION OF WETLANDS
DOC DATE OSWER/EPA ID DOC NUMBER
5/24/1977 C472
Wednesday, May 05, 2004
Page
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GUIDANCE DOCUMENTS
TITLE
RULES OF THUMB FOR SUPERFUND REMEDY SELECTION (EPA 540-R-97-013)
DOC DATE OSWER/EPA ID DOC NUMBER
8/1/1997 OSIER #9355.0-69 C473
TITLE
USE OF MONITORED NATURAL ATTENUATION AT SUPERFUND, RCRA CORRECTIVE ACTION. AND
UNDERGROUND STORAGE TANK SITES
DOC DATE OSWER/EPA ID DOC NUMBER
11/1/1997 OSIER #9200.4-17 C475
TITLE
TRANSMITTAL OF OSIER DIRECTIVE ON COMPREHENSIVE STATE GROUND WATER PROTECTION
PROGRAMS (CSGWPPS)
DOC DATE OSWER/EPA ID DOC NUMBER
4/14/1997 OSIER #9283.1-09 C476
TITLE
LETTER AND ATTACHED MEMORANDUM OF AGREEMENT BETWEEN U.S. EPA AND MASS DEP FOR
IMPLEMENTATION OF GROUND WATER USE AND VALUE DETERMINATION GUIDANCE
DOC DATE OSWER/EPA ID DOC NUMBER
3/23/1998 C477
TITLE
INNOVATIVE SITE REMEDIATION TECHNOLOGY: CHEMICAL TREATMENT, VOL. 2
DOC DATE OSWER/EPA ID DOC NUMBER
9/1/1994 EPA 542-B-94-004 C478
TITLE
INNOVATIVE SITE REMEDIATION TECHNOLOGY, SOIL WASHING/SOIL FLUSHING, VOL. 3
DOC DATE OSWER/EPA ID DOC NUMBER
11/1/1993 542-B-93-012 C479
TITLE
INNOVATIVE REMEDIATION TECHNOLOGY: SOLIDIFICATION/STABILIZATION VOLUME 4
DOC DATE OSWER/EPA ID DOC NUMBER
6/1/1994 542-B-94-001 C480
TITLE
INNOVATIVE SITE REMEDIATION TECHNOLOGY-SOLVENT CHEMICAL EXTRACTION VOLUME 5
DOC DATE OSWER/EPA ID DOC NUMBER
6/1/1995 542-B-94-005 C481
TITLE
INNOVATIVE SITE REMEDIATION TECHNOLOGY: THERMAL DESORPTION, VOL 6
DOC DATE OSWER/EPA ID DOC NUMBER
11/1/1993 542-B-93-011 C482
TITLE
INNOVATIVE SITE REMEDIATION TECHNOLOGY: THERMAL DESTRUCTION, VOL 7
DOC DATE OSWER/EPA ID DOC NUMBER
10/1/1994 542-B-94-003 C483
Wednesday, May 05, 2004 Page
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GUIDANCE DOCUMENTS
TITLE
ENGINEERING BULLETIN. SOLIDIFICATION/STABILIZATION OF ORGANICS AND INORGANICS
DOC DATE OSWER/EPA ID DOC NUMBER
5/1/1993 EPA/540/S -92/015 C484
TITLE
CITIZEN'S GUIDE TO PHYTOREMEDIATION
DOC DATE OSWER/EPA ID DOC NUMBER
8/1/1998 EPA 542-F-98-011 C485
TITLE
MANAGEMENT OF REMEDIATION WASTE UNDER RCRA
DOC DATE OSWER/EPA ID DOC NUMBER
10/14/1998 EPA530-F-98-026 C486
TITLE
USE OF THE AREA OF CONTAMINATION (AOC) CONCEPT DURING RCRA CLEANUPS
DOC DATE OSWER/EPA ID DOC NUMBER
3/13/1996 C4B7
TITLE
COMMUNITY RELATIONS IN SUPERFUND: A HANDBOOK
DOC DATE OSWER/EPA ID DOC NUMBER
1/1/1992 EPA/5 0/R-92/009 C488
TITLE
TOXICOLOGICAL PROFILE FOR CHLOROBENZENE
DOC DATE OSWER/EPA ID DOC NUMBER
12/1/1990 TP-90-06 C489
TITLE
TOXICOLOGICAL PROFILE FOR 1,4-DICHLOROBENZENE (UPDATE)
DOC DATE OSWER/EPA ID DOC NUMBER
12/1/1998 C490
TITLE
PRESUMPTIVE REMEDIES: SITE CHARACTERIZATION AND TECHNOLOGY SELECTION FOR CERCLA
SITES WITH VOLATILE ORGANIC COMPOUNDS IN SOILS
DOC DATE OSWER/EPA ID DOC NUMBER
9/1/1993 9355.0-48FS C491
TITLE
GASTROINTESTINAL ABSORPTION OF SELECTED CHEMICALS: REVIEW OF EVIDENCE FOR DERIVING
RELATIVE ABSORPTION FACTORS
DOC DATE OSWER/EPA ID DOC NUMBER
7/1/1993 CONTRACT 68-WO-0032 C492
TITLE
INVESTIGATION OF DERMAL CONTACT WITH SOIL IN CONTROLLED TRIALS
DOC DATE OSWER/EPA ID DOC NUMBER
1/1/1998 C493
Wednesday, May 05, 2004
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GUIDANCE DOCUMENTS
TITLE
SOIL REMEDIATION GOALS FOR SPRAGUE ELECTRIC BROWN SITE, NORTH ADAMS, MI
DOC DATE OSWER/EPA ID DOC NUMBER
6/3/1992 C494
TITLE
ALTERNATIVE CAP DESIGN GUIDANCE PROPOSED FOR UNLINED, HAZARDOUS WASTE LANDFILLS IN
EPA REGION I
DOC DATE OSWER/EPA ID DOC NUMBER
9/30/1997 C495
TITLE
FEDERAL REGISTER. PART II. 40 CFR PART 300 NATIONAL OIL AND HAZARDOUS SUBSTANCES
CONTINGENCY PLAN, FINAL RULE. VOL. 55, NO. 46
DOC DATE OSWER/EPA ID DOC NUMBER
3/8/1990 C496
TITLE
DISPOSAL OF POLY CHLORINATED BIPHENYLS (PCBS); FINAL RULE, FEDERAL REGISTER. VOL. 63,
NO. 124
DOC DATE OSWER/EPA ID DOC NUMBER
6/29/1998 C497
TITLE
TOXICOLOGICAL PROFILE FOR CHLORINATED DIBENZO-P-DIOXINS, DRAFT FOR PUBLIC COMMENT
DOC DATE OSWER/EPA ID DOC NUMBER
1/1/1997 C498
TITLE
TOXICOLOGICAL PROFILE FOR LEAD, DRAFT FOR PUBLIC COMMENT
DOC DATE OSWER/EPA ID DOC NUMBER
8/1/1997 C499
TITLE
MASSACHUSETTS CONTINGENCY PLAN; CODE OF MASSACHUSETTS REGULATIONS, 310 CMR 40.000
DOC DATE OSWER/EPA ID DOC NUMBER
5/29/1998 C500
TITLE
EXPOSURE FACTORS HANDBOOK; FOOD INGESTION FACTORS. VOLUME II
DOC DATE OSWER/EPA ID DOC NUMBER
8/1/1997 EPA/600/P-95/002FB C501
TITLE
EXPOSURE FACTORS HANDBOOK; ACTIVITY FACTORS, VOLUME III
DOC DATE OSWER/EPA ID DOC NUMBER
8/1/1997 EPA/600/P-95/002FC C502
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GUIDANCE DOCUMENTS
TITLE
NATIONAL OIL AND HAZARDOUS SUBSTANCES POLLUTION CONTINGENCY PLAN; CODE OF FEDERAL
REGULATIONS (TITLE 40, PART 300)
DOC DATE OSWER/EPA ID DOC NUMBER
7/1/1998 C503
TITLE
APPROACH FOR ADDRESSING DIOXIN IN SOIL AT CERCLA AND RCRA SITES
DOC DATE OSWER/EPA ID DOC NUMBER
4/13/1998 OSIER 9200.4-26 C504
TITLE
REUSE AND DISPOSAL OF CONTAMINATED SOIL AT MASS. LANDFILLS, DEPARTMENT OF
ENVIRONMENTAL PROTECTION POLICY #COMM-97-001 (SUPERSEDES POLICY #BWP-94-037)
DOC DATE OSWER/EPA ID DOC NUMBER
C506
TITLE
USERS GUIDE FOR THE JOHN AND ETTINGER (1991) MODEL FOR SUBSURFACE VAPOR INTRUSION INTO
BUILDINGS, CONTRACT NO, 68-D30035. WORK ASSIGNMENT NO. 111-106
DOC DATE OSWER/EPA ID DOC NUMBER
9/1/1997 C508
TITLE
SEDIMENTS. ENVIRONMENTAL MANAGEMENT. V. 19,1
DOC DATE OSWER/EPA ID DOC NUMBER
1/1/1995 C509
TITLE
FINAL OSIER DIRECTIVE "USE OF MONITORED NATURAL ATTENUATION AT SUPERFUND, RCRA
CORRECTIVE ACTION, AND UNDERGROUND STORAGE TANK SITES"
DOC DATE OSWER/EPA ID DOC NUMBER
4/21/1999 OSIER #9200.4-17P C512
TITLE
INTERIM POLICY ON THE USE OF PERMANENT RELOCATIONS AS PART OF SUPERFUND REMEDIAL
ACTIONS
DOC DATE OSWER/EPA ID DOC NUMBER
OSIER 9355.0-71 P C505
TITLE
TOXICOLOGICAL BENCHMARKS FOR SCREENING POTENTIAL CONTAMINANTS OF CONCERN FOR
EFFECTS ON AQUATIC BIOTA: 1996 REVISION, ES/ER/TMN-96/R2
DOC DATE OSWER/EPA ID DOC NUMBER
6/1/1996 C513
TITLE
CONDUCTING NON-TIME-CRITICAL REMOVAL ACTIONS UNDER CERCLA. (EPA/540-R-93-057)
DOC DATE OSWER/EPA ID DOC NUMBER
8/6/1993 OSIER #9360.0-32 C514
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GUIDANCE DOCUMENTS
TITLE
USE OF MONITORED NATURAL ATTENUATION AT SUPERFUND, RCRA CORRECTIVE ACTION, AND
UNDERGROUND STORAGE TANK SITES
DOC DATE OSWER/EPA ID DOC NUMBER
4/21/1999 OSIER #9200.4-17P C515
TITLE
GROUND WATER ISSUE: MICROBIAL PROCESSES AFFECTING MONITORED NATURAL ATTENUATION OF
CONTAMINANTS IN THE SUBSURFACE
DOC DATE OSWER/EPA ID DOC NUMBER
9/1/1999 EPA/540/S-99/001 C516
TITLE
ANALYSIS OF GROUND-WATER REMEDIAL ALTERNATIVES AT A SUPERFUND SITE, GROUNDWATER,
VOL. 29. NO 6
DOC DATE OSWER/EPA ID DOC NUMBER
11/1/1991 C517
TITLE
USE OF NON-TIME-CRITICAL REMOVAL AUTHORITY IN SUPERFUND RESPONSE ACTIONS,
(REGIONS I-X)
DOC DATE OSWER/EPA ID DOC NUMBER
2/14/2000 C518
TITLE
NATIONAL PRIMARY DRINKING WATER REGULATIONS: ARSENIC AND CLARIFICATIONS TO
COMPLIANCE AND NEW SOURCE CONTAMINANTS MONITORING. (CFR, VOL. 65. NO. 121)
DOC DATE OSWER/EPA ID DOC NUMBER
6/22/2000 C519
TITLE
PROPOSED REVISION TO ARSENIC DRINKING WATER STANDARD (815-F-00-012)
DOC DATE OSWER/EPA ID DOC NUMBER
5/1/2000 C520
TITLE
IMPLEMENTING FY2000 APPROPRIATIONS REPORT LANGUAGE ON SEDIMENT DREDGING
DOC DATE OSWER/EPA ID DOC NUMBER
1/19/2000 C521
TITLE
GUIDANCE ON EXERCISING CERCLA ENFORCEMENT DISCRETION IN ANTICIPATION OF FULL COST
ACCOUNTING CONSISTENT WITH THE STATEMENT OF FEDERAL FINANCIAL ACCOUNTING
STANDARDS NO. 4
DOC DATE OSWER/EPA ID DOC NUMBER
5/26/2000 C522
TITLE
SUPERFUND INDIRECT COST RATES FOR FISCAL YEARS (FY) 1990-2001
DOC DATE OSWER/EPA ID DOC NUMBER
C523
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GUIDANCE DOCUMENTS
TITLE
REVISED ALTERNATIVE CAP DESIGN GUIDANCE PROPOSED FOR UNLINED HAZARDOUS WASTE
LANDFILLS IN THE EPA REGION I
DOC DATE OSWER/EPA ID DOC NUMBER
2/5/2001 C524
TITLE
GUIDE TO PREPARING SUPERFUND PROPOSED PLANS RECORDS OF DECISION AND OTHER REMEDY
SELECTION DECISION DOCUMENT:
DOC DATE OSWER/EPA ID DOC NUMBER
7/1/1999 OSIER #9200.1-23P C525
TITLE
ABANDONED MINE SITE CHARACTERIA2TION & CLEANUP HANDBOOK (available on cd-rom)
DOC DATE OSWER/EPA ID DOC NUMBER
8/1/2000 EPA 910-B-00-001 C526
TITLE
INTRODUCTION TO HARD ROCK MINING A CD-ROM APPLICATION (available on cd-rom)
DOC DATE OSWER/EPA ID DOC NUMBER
9/1/1997 EPA 530-C-97-005 C527
TITLE
MINING WASTE SCIENTIST TO SCIENTIST MEETING (available on cd-rom)
DOC DATE OSWER/EPA ID DOC NUMBER
6/15/2000 C528
TITLE
FISCAL YEAR 2001 APPROPRIATIONS CONFERENCE REPORT LANGUAGE ON CONTAMINATED
SEDIMENTS
DOC DATE OSWER/EPA ID DOC NUMBER
3/22/2001 OSIER #9200.0-36 C529
TITLE
RISK ASSESSMENT GUIDANCE FOR SUPERFUND, VOLUME 1, HUMAN HEALTH EVALUATION MANUAL,
INTERIM
DOC DATE OSWER/EPA ID DOC NUMBER
1/1/1998 C530
TITLE
INSTITUTIONAL CONTROL A SITE MANAGER'S GUIDE TO IDENTIFYING, EVALUATING AND SELECTING
INSTITUTIONAL CONTROLS AT SUPERFUND AND RCRA CORRECTIVE ACTION CLEANUPS
DOC DATE OSWER/EPA ID DOC NUMBER
9/1/2000 C531
TITLE
GUIDANCE FOR EVALUATING THE TECHNICAL IMPRACTICABILITY OF GROUND-WATER RESTORATION
DOC DATE OSWER/EPA ID DOC NUMBER
9/1/1993 540-R-93-080 C532
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GUIDANCE DOCUMENTS
TITLE
RECOMMENDATIONS OF THE TECHNICAL REVIEW WORK GROUP FOR LEAD FOR AN INTERIM
APPROACH
DOC DATE OSWER/EPA ID DOC NUMBER
12/1/1996 C511
TITLE
FIELD APPLICATIONS OF IN SITU REMEDIATION TECHNOLOGIES CHEMICAL OXIDATION
DOC DATE OSWER/EPA ID DOC NUMBER
9/1/1998 EPA 542-R-9B-008 C533
TITLE
Dioxin and Dioxin-Like Compounds in Soil. Part 1 ATSDR Interim Policy Guideline
DOC DATE OSWER/EPA ID DOC NUMBER
1/1/1997 C534
TITLE
TOXIC EQUIVALENCY FACTORS (TEFs) FOR PCBs, PCDDs, PSDFs FOR HUMANS AND WILDLIFE
DOC DATE OSWER/EPA ID DOC NUMBER
12/1/1998 C535
TITLE
WITHDRAWAL OF CYANIDE AND SULFIDE REACTIVITY GUIDANCE
DOC DATE OSWER/EPA ID DOC NUMBER
4/21/1992 C536
TITLE
ELEMENTS FOR EFFECTIVE MANAGEMENT OF OPERATING PUMP AND TREAT SYSTEMS
DOC DATE OSWER/EPA ID DOC NUMBER
OSIER 9355.4-27FS-A C537
TITLE
TRANSFER OF LONG-TERM RESPONSE ACTION (LTRA) PROJECTS TO STATES
DOC DATE OSWER/EPA ID DOC NUMBER
7/2/2003 OSIER 9355.0-81 FS-A C536
TITLE
COMPREHENSIVE FIVE-YEAR REVIEW GUIDANCE
DOC DATE OSWER/EPA ID DOC NUMBER
6/1/2003 OSIER 9355.7-03B-P C539
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Appendix D: List of Acronyms and Abbreviations
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LIST OF ACRONYMS AND ABBREVIATIONS
Acronym/
Abbreviation
Definition
ALI
Attleboro Landfill, Inc.
AGO
Administrative Consent Order
AOC
Administrative Order on Consent
ARAR
Applicable or Relevant and Appropriate Requirement
ATSDR
Agency for Toxic Substances and Disease Registry
AWQC
Ambient Water Quality Criteria
BERA
Baseline Environmental Risk Assessment
BTEX
Benzene, toluene, ethylbenzene and xylene
CAA
Clean Air Act
CAST
Citizens Advisory Shpack Team
CD
Consent Decree
CERCLA
Comprehensive Environmental Response, Compensation, and Liability Act
CERCLIS
CERCLA Information System Database
CFR
Code of Federal Regulations
cis-1, 2-DCE
cis-1,2-Dichloroethene
coc
Contaminant of Concern
COPC
Contaminants of Potential Concern
CWA
Clean Water Act
DCE
1,2-Dichloroethene
DDT
dichloro-diphenyl-trichloroethane
DEQE
Department of Environmental Quality Engineering (now the MADEP)
DNAPL
Dense Non-Aqueous Phase Liquid
DOE
United States Department of Energy
EO
Executive Order
ERA
Environmental Risk Assessment
ERM
Environmental Resources Management, Inc.
ESD
Explanation of Significant Difference
EPA
United States Environmental Protection Agency
EPC
Exposure Point Concentration
FS
Feasibility Study
FUSRAP
Formerly Utilized Sites Remedial Action Program
gpm
gallons per minute
HQ
Hazard Quotient
HRS
Hazard Ranking System
IEUBK
Integrated Exposure and Uptake Biokinetic model
ISC
Initial Site Characterization
LDR
RCRA Land Disposal Restrictions
LNAPL
Light Non-Aqueous Phase Liquid
LOAEL
Lowest Observed Adverse Effects Level
LOED
Lowest Observed Effects Dose
LTM
Long Term Monitoring
MADEP
Massachusetts Department of Environmental Protection
MCL
Maximum Contaminant Level
MCLG
Maximum Contaminant Level Goal
MCP
Massachusetts Contingency Plan
M&E
Metcalf & Eddy, Inc.
MNA
Monitored Natural Attenuation
MTBE
methyl-ter butyl ether
NAPL
Non-Aqueous Phase Liquid
NCP
National Contingency Plan
ND
Not Detected
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Acronym/
Abbreviation Definition
NHESP
Natural Heritage and Endangered Species Act
NOAEL
No Observed Adverse Effects Level
NOED
No Observed Effects Dose
NPL
National Priorities List
NRC
United States Nuclear Regulatory Commission
O&M
Operation and Maintenance
ORNL
Oak Ridge National Laboratory
OSHA
Occupational Safety and Health Administration
OSIER
EPA Office of Solid Waste and Emergency Response
OU
Operable Unit
PAH
Polycyclic aromatic hydrocarbon
PCB
Polychlorinated biphenyl
PCE
T etrachloroethene
ppb
parts per billion
ppm
parts per million
PRO
Preliminary Remediation Goal
PRP
Potentially Responsible Party
psi
Pounds per square inch
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
SE
southeast
SLERA
Screening Level Environmental Risk Assessment
ssc
Shpack Steering Committee
svoc
Semi-Volatile Organic Compound
TBCs
To Be Considered
TCE
Trichloroethene
TCLP
Toxicity Characteristic Leaching Procedure
1,1,1-TCA
1,1,1 -Trichloroethane
TEL
Threshold Effects Level
TEQ
Toxicity Equivalent
trans-1,2-DCE
trans-1,2-Dichloroethene
TRY
Toxicity Reference Value
TSCA
Toxic Substances Control Act
UCL
Upper Confidence Limit
USACE
United States Army Corps of Engineers
VOC
Volatile Organic Compound
USFWS
United States Fish and Wildlife Service
USGS
United States Geological Survey
VLDPE
Very Low Density Polyethylene
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