U.S. ENVIRONMENTAL PROTECTION AGENCY
EPA REGION 1 - NEW ENGLAND
RECORD OF DECISION
OPERABLE UNITS 1, 2, and 3
OLIN CHEMICAL SUPERFUND SITE
WILMINGTON, MASSACHUSETTS
MARCH 2021
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Record of Decision
Table of Contents
PART 1: THE DECLARATION FOR THE RECORD OF DECISION
A.
SITE NAME AND LOCATION
B.
STATEMENT OF BASIS AND PURPOSE
C.
ASSESSMENT OF SITE
D.
DESCRIPTION OF SELECTED REMEDY
E.
STATUTORY DETERMINATIONS
F.
SPECIAL FINDINGS
G.
DATA CERTIFICATION CHECKLIST
H.
AUTHORIZING SIGNATURES
PART 2: THE DECISION SUMMARY
A. SITE NAME, LOCATION, AND BRIEF DESCRIPTION
B. SITE HISTORY AND ENFORCEMENT ACTIVITIES
1. History of Site Activities
2. History of Federal and State Investigations and Removal and Remedial Actions
3. History of CERCLA Enforcement Activities
C. COMMUNITY PARTICIPATION
D. SCOPE AND ROLE OF OPERABLE UNIT OR RESPONSE ACTION
E. SITE CHARACTERISTICS
F. CURRENT AND POTENTIAL FUTURE SITE AND RESOURCE USES
1. Land Uses
2. Groundwater/Surface Water Uses
G. SUMMARY OF SITE RISKS
1. Human Health Risk Assessment
2. Ecological Risk Assessment
3. Basis for Response Action
H. REMEDIAL ACTION OBJECTIVES
I. DEVELOPMENT AND SCREENING OF ALTERNATIVES
J. DESCRIPTION OF ALTERNATIVES
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Wilmington, Massachusetts
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Record of Decision
Table of Contents
K. SUMMARY OF COMPARATIVE ANALYSIS OF ALTERNATIVES
L. THE SELECTED REMEDY
M. STATUTORY DETERMINATIONS
N. DOCUMENTATION OF NO SIGNIFICANT CHANGES
O. STATE ROLE
PART 3: THE RESPONSIVENESS SUMMARY
APPENDICES
Appendix A: MassDEP Letter of Concurrence
Appendix B: Tables
Appendix C: Figures
Appendix D: ARARs Tables
Appendix E: References
Appendix F: Acronyms and Abbreviations
Appendix G: Administrative Record Index and Guidance Documents
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Record of Decision
Part 1: The Declaration
PART 1: THE DECLARATION FOR THE RECORD OF DECISION
A. SITE NAME AND LOCATION
Olin Chemical Superfund Site
Wilmington, Middlesex County, Massachusetts
CERCLIS ID#: MADOO1403104
B. STATEMENT OF BASIS AND PURPOSE
This decision document presents the selected final remedial action for Operable Units (OUs) 1 and 2
(OU1 and OU2, respectively) and an interim remedial action for OU3 for the Olin Chemical Superfund
Site (Site), in Wilmington, Massachusetts, which were chosen in accordance with the Comprehensive
Environmental Response, Compensation, and Liability Act of 1980, as amended (CERCLA, also
commonly referred to as "Superfund"), 42 U.S.C. § 9601 etseq., and, to the extent practicable, the
National Oil and Hazardous Substances Pollution Contingency Plan (NCP), as amended, 40 CFR Part 300
et seq. The Region 1 Director of the Superfund and Emergency Management Division (SEMD) has been
delegated the authority to approve this Record of Decision (ROD).
This decision was based on the Administrative Record for the Site, which has been developed in
accordance with Section 113(k) of CERCLA, 42 U.S.C. § 9613(k), and which is available for review
online at: www.epa.gov/superfund/olin. The Administrative Record Index (Appendix G of this ROD)
identifies each of the items comprising the Administrative Record upon which the selection of the remedy
is based.
The Commonwealth of Massachusetts, Department of Environmental Protection (the Commonwealth), as
the support agency, concurs with the selected remedy (see Appendix A of this ROD for a copy of the
concurrence letter).
C. ASSESSMENT OF SITE
The remedial action selected in this ROD is necessary to protect public health or welfare or the
environment from actual or threatened releases of hazardous substances, pollutants, or contaminants into
the environment. The June 2019 Draft Oil3 Remedial Investigation (RI) Report (Wood, 2019), the July
2015 Final OU1/OU2 RI Report (AM EC, 2015a), and the November 2014 Jewel Drive Dense Aqueous
Phase Liquid (DAPL) Extraction Pilot Report (AMEC, 2014a) summarize the nature and extent of
contamination at OU1, OU2, and OU3 of the Site.' These documents, supplemented by two August 2020
memoranda prepared by EPA entitled Updates to OU1/OU2 RI Report Conclusions (USEPA, 2020a) and
1 The Remedial Investigation (RI) for Operable Unit 3 (OU3) is currently ongoing. A Feasibility Study (FS) report
for the final OU3 remedy addressing Site-wide groundwater will be issued in the future.
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Updates to Draft 2019 OU3 RI Report Conclusions (USEPA, 2020b) were used to prepare a Feasibility
Study (FS) Report that identified all the remedial options considered for final cleanup of OU1 and OU2
and interim cleanup of OU3 of the Site. The FS Report consists of three volumes entitled Volume 1,
Operable Unit 1 & Operable Unit 2 Feasibility Study, Olin Chemical Superfund Site, 51 Eames Street,
Wilmington, Massachusetts (FS Report Volume I, Olin, 2020a), Volume II, Interim Action Feasibility
Study, Olin Chemical Superfund Site, 51 Eames Street, Wilmington, Massachusetts (FS Report Volume II,
Olin, 2020b), and Volume III Comparative Analyses, Feasibility Study Report, Olin Chemical
Superfund Site, Wilmington, Massachusetts (FS Report Volume III, USEPA, 2020c).
D. DESCRIPTION OF SELECTED REMEDY
This ROD sets forth the selected remedy for the Site, which is based on a combination of remedial
alternatives set out in a Proposed Plan issued for public comment in August 2020. The interim OU3
(groundwater) remedy will prevent unacceptable risks from exposure to contaminated groundwater and
remove principal threat waste (source material containing Dense Aqueous Phase Liquid |DAPL|). The
interim remedy will also begin to restore the aquifer while additional information is gathered to support
selection of a final remedy for OU3. The final OU1/OU2 remedy will address all current and potential
future risks caused by contaminated soil, sediments, and surface water, Light Non-Aqueous Phase Liquid
(LNAPL), and the subsurface-to-indoor air vapor intrusion (VI) pathway (OIJ1 and OU2).
The interim and final remedies selected in this ROD include the following:
Interim Action - DA PL and Groundwater Hot Spots (GWHS)
• Construction and operation of new extraction and treatment systems to remove DAPL and hot
spot groundwater targeting 5,000 nanograms/Liter (ng/L) n-nitrosodimethylamine (NDMA)
contour to reduce the mass and further migration of Site contaminants of concern (Site COCs or
COCs) in groundwater and prevent contaminated groundwater from flowing into surface water;
• Pre-design investigations (PDIs) to determine the final number, location, and configuration of
extraction wells and other remedial components; and
• Institutional Controls to 1) prohibit the use of groundwater in the OU3 groundwater study area
unless it can be demonstrated to EPA, in consultation with the Commonwealth, that such use will
not pose an unacceptable risk to human health and the environment, cause further migration of
the groundwater contaminant plume, or interfere with the remedy; and 2) prevent disturbance of
any engineered systems and any other new and existing remedy infrastructure components.
Examples of Institutional Controls include Notice of Activity and Use Limitation (NAUL), Grant
of Env ironmental Restriction and Easement (GERE),2 town ordinance, advisories, building
permit requirements, and other administrative controls.
2 NAULs and GEREs arc approved forms of Massachusetts land use restrictions established under the Massachusetts
Contingency Plan (MCP).
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Final Action - LNAPL and Surface Water (SW)
• Construction and operation of a new multi-phase extraction system to capture LNAPL and
associated contaminated groundwater and soil vapor. Construction and operation of new
treatment systems to treat the recovered LNAPL via oil/water separation, the soil vapor via
granular activated carbon (GAC), and the captured groundwater via the same treatment system(s)
as for hot spot groundwater;
• Construction and operation of a new groundwater extraction and treatment system(s), with
extraction wells sited based on PDIs, to intercept and treat the overburden groundwater
contaminant plume that impacts Site surface water; and
• Institutional Controls to prevent disturbance of any engineered systems and any other new and
existing remedy infrastructure components.
Final Action - Soil and Sediments (SEP)
• Construction and maintenance of caps and cover systems on areas of soil contamination on the
Olin Corporation (Olin) property (Property), including a multi-layer, low-permeability cap over
the Containment Area that meets Resource Conservation and Recovery Act (RCRA) Subtitle D
and Massachusetts solid waste landfill performance standards, the design and footprint of which
will be determined during the Remedial Design (RD) phase;
• Excavation of approximately 4,000 cubic yards (cy) of contaminated wetland soil and sediment
and disposal off-site at an appropriate approved facility; backfilling of excavated areas with clean,
hydric (wetland-type) soil, regrading, and revegetation with native vegetation to control erosion;
and
• Institutional Controls to 1) prevent residential, school, and daycare uses of the Property; 2)
prevent contact with soil beneath caps and cover systems; 3) prevent disturbance of any
engineered systems and any other new and existing remedy infrastructure components; and 4)
prevent future exposure to trimethylpentenes (TMPs) in soil that may pose inhalation risks via the
VI pathway. Institutional Controls will require VI evaluations and/or mitigation measures such as
vapor barriers or sub-slab depressurization systems (SSDSs) for new building construction or
building alterations on the Property.
Included with the three cleanup actions above are the following:
• PDIs and/or treatability studies during the RD process to:
a. determine the final number, location, and configuration of extraction wells and other
remedial components;
b. determine appropriate locations for discharge of treated groundwater to surface water;
and
c. facilitate the implementation of the selected remedial alternatives and map the precise
extent of both excavation limits and the extent of caps and cover systems;
• Minimization of potential harm and avoidance to the extent practicable of adverse impacts to
wetlands and floodplains; restoration and/or replication nearby to address unavoidable impacts
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from remedial activities, including proper regrading. restoration with native vegetation and to
address any diminishment of flood storage capacity, erosion control, monitoring, and
maintenance;
• Long-term operation, maintenance, and monitoring of any new and existing remedy infrastructure
components, including the Calcium Sulfate Landfill (CSL);
• Identification and evaluation of existing wells (e.g., potable, irrigation, and process wells) in the
Site groundwater study area (see Figure 11 in Appendix C of this ROD) to determine whether
their use will pose an unacceptable risk to human health and the environment, cause further
migration of the groundwater contaminant plume, or interfere with the remedy;
• Long-term monitoring of the groundwater plume and surface water, to evaluate remedy
effectiveness; and
• Five Year Reviews to assess protectiveness of the remedy.
In parallel to the selected remedy, the following activities will continue:
• Continued studies as part of the OU3 RI/FS to close remaining data gaps, including to improve
the characterization of bedrock topography and fractures and further delineate the horizontal and
vertical extent of groundwater contamination; and
• Evaluation of long-term groundwater remedial alternatives, leading to the selection of a final
cleanup plan for the Site.
A Baseline Human Health Risk Assessment (BHHRA) for OU1 and OU2 was prepared on July 24, 2015,
as Appendix M to the July 2015 Final OU1/OU2 RIReport (OU1/OU2 BHHRA). A Baseline Ecological
Risk Assessment (BERA) for OU1 and OU2 was also prepared in July 2015, as Appendix N to the July
2015 Final OU1/OU2 RI Report (OU1/OU1 BERA). Appendix K to the June 2019 Draft OU3 RI Report
includes a Revised Draft BHHRA for OU3 (Draft OU3 BHHRA). An evaluation of the potential human
health and ecological risks mitigated by the operations of Plant B was completed on August 27, 2019
(August 27, 2019 Plant B Risk Calculations: Nobis, 2019). A residential human health risk evaluation for
OU1 and OU2 soil was prepared on January 17, 2020 (January 17, 2020 OU1/OU2 Residential Human
Health Risk Evaluation, Bluestone, 2020). A set of risk calculations were prepared on May 15, 2020 to
document the basis for ecological risk-based Preliminary Remediation Goals (PRGs) for soil, sediments,
and surface water (May 15, 2020 Ecological Risk Calculations ', Wood, 2020b). A revised set of human
health risk calculations for the Site was completed on May 21, 2020 for potable use of private residential
well water (May 21, 2020 OU3 Human Health Risk Calculations -, 01 in, 2020c). A set of risk calculations
were prepared on July 1, 2020 (July I, 2020 Risk Calculations) to document the basis for human health
risk-based PRGs for upland soil (including Containment Area soil) and surface water (Wood, 2020c).
E. STATUTORY DETERMINATIONS
The selected interim remedy for OU3 is protective of human health and the environment in the short term
and is intended to provide adequate protection until a final remedy is selected; complies with those federal
and state requirements that are applicable or relevant and appropriate for this limited-scope action; and is
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cost effective. Although this interim action is not intended to address fully the statutory mandate for
permanence and treatment to the maximum extent practicable, this interim action does utilize treatment
and thus supports that statutory mandate. Because this action does not constitute the final remedy for
groundwater, the statutory preference for remedies that employ treatment that reduces toxicity, mobility,
or volume as a principal element, although partially addressed in this remedy, will be addressed by the
final remedial action.
The selected final remedy for OU1 and OU2 is protective of human health and the env ironment; complies
with federal and state requirements that arc applicable or relevant and appropriate to the remedial action;
is cost-effective, and utilizes permanent solutions and alternative treatment technologies to the maximum
extent practicable.
Based on implementability considerations, EPA determined that it was impracticable to excavate and treat
the Site COCs in upland soil, including the Containment Area, and wetland soil and sediments in a cost-
effective manner. However, the final OU1/OU2 remedy includes treatment of the following; recovered
LNAPL and soil vapor; captured groundwater; excavated soil or sediments that exhibit a hazardous waste
characteristic or that are excavated from below the water table to reduce contaminant mobility prior to
off-site disposal; and water generated from dewatcring excavated soil prior to off-site disposal to reduce
toxicity prior to discharge to surface waters. By using treatment as a significant portion of the interim
remedy and partially for the final remedy, the statutory preference for remedies that employ treatment as a
principal element is partially satisfied.
Because this remedy will result in hazardous substances, pollutants, or contaminants remaining on-site
above levels that would allow for unlimited use and unrestricted exposure (and because groundwater and
land use restrictions are necessary), a review will be conducted within five years after initiation of
remedial actions to ensure that the remedy continues to provide adequate protection of human health and
the environment. Five Year Reviews will continue as long as waste remains at the Site and unlimited use
is restricted.
F. SPECIAL FINDINGS
Issuance of this ROD embodies the following specific determinations:
Wetlands Impacts
Pursuant to Section 404 of the Clean Water Act (CWA), 44 CFR Part 9, and Executiv e Order 11990
(Protection of Wetlands), EPA has determined that there is no practicable alternative to conducting work
that will impact wetlands of the United States because significant levels of contamination exist within or
under wetlands of the United States and these areas are included within the Site's cleanup areas.
For those areas impacted by cleanup activities, EPA has also determined that the selected remedy is the
Least Environmentally Damaging Practicable Alternative (LEDPA), as required by the CWA, for
protecting federal jurisdictional wetlands and aquatic ecosystems at the Site under these standards,
because the remedy will permanently remove contaminants that are impairing the wetlands and any
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wetland resources altered by the remediation will be restored to the original grade and with native
vegetation.
EPA will minimize potential harm and avoid adverse impacts to wetlands, to the extent practicable, by
using best management practices to minimize harmful impacts on wetlands, wildlife, or habitat. Any
wetlands affected by remedial work will be restored and/or replicated consistent with the requirements of
federal and state wetlands protection laws with native wetland vegetation, and any restoration efforts will
be monitored. Mitigation measures will be used to protect wildlife and aquatic life during remediation, as
necessary. EPA's selected remedy balances the need to address the contamination that poses an
ecological risk to the wetlands and waterways with the ability to restore any (temporarily or permanently)
altered wetland resources and aquatic habitats impacted by the remediation. EPA's responses to
comments regarding wetland issues are located in the Responsiveness Summary (see Part 3 of this ROD).
Floodplain Impacts
The selected remedy includes activities that result in the occupancy and modification of the 100-year and
500-year floodplains. Pursuant to Federal Emergency Management Agency (FEMA) regulations at 44
CFR Part 9, which set forth the policy, procedure, and responsibilities to implement and enforce
Executive Order 11988 (Floodplain Management), EPA has determined that there is no practicable
alternative to altering floodplain resources.
EPA will avoid or minimize potential harmful temporary or permanent impacts to floodplain resources to
the extent practicable at the areas impacted by remediation. EPA has determined that the selected remedy
will likely result in temporary occupancy of the 100-year and 500-year floodplains in the Maple Meadow
Brook (MMB) wetlands, but after completion of work there will not be any net loss of flood storage
capacity. Additionally, based on the available data, EPA has determined that the selected remedy will not
result in the occupancy and modification of floodplains, specifically, the 500-year floodplain, at the
Property. A stormwatcr study will be undertaken as part of the PDI phase to confirm that this is the case.
If impacts to the 500-year floodplain at the Property are found to be unavoidable, in addition to the likely
temporary impacts to the 100-year and 500-year floodplains in the MMB wetlands while implementing
the remedy, appropriate measures will be incorporated into the RD and subsequently implemented during
the RA phase to ensure that current flood storage capacities and any adjacent wetlands are not diminished
after completion of the remedial actions. Best management practices will be used during construction to
minimize temporary impacts to floodplains, and excavated areas will be returned to original grade to
avoid diminishing flood storage capacity. Restoration and monitoring activities are included in the
remedial actions. As required under applicable federal wetlands regulations, EPA solicited public
comment regarding the remedy's potential impacts on floodplain resources and received no negative
comments (see Part 3 of this ROD).
G. DATA CERTIFICATION CHECKLIST
The following information is included in the Decision Summary section of this ROD. Additional
information can be found in the Administrative Record file for the Site:
1. The Site COCs and their respective concentrations;
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2. Baseline risk represented by the Site COCs;
3. Cleanup levels established for the Site COCs and the basis for the levels;
4. How source materials constituting principal threats will be addressed;
5. Current and future land and groundwater use assumptions used in the baseline risk assessment
and ROD;
6. Land and groundwater use that will be available at the Site as a result of the selected remedy;
7. Estimated capital, annual Operation and Maintenance (O&M), and total present worth costs;
discount rate; and the number of years over which the remedy cost estimates are projected; and
8. Decisive factors that led to the selection of the remedy.
H. AUTHORIZING SIGNATURES
This ROD documents the selected remedy for a final action for soil, sediments, LNAPL, and surface
water and an interim action for groundwater at the 01 in Chemical Superfund Site. This remedy was
selected by EPA with concurrence of the Massachusetts Department of Environmental Protection
(MassDEP). A copy of the Commonwealth's concurrence letter is attached to this ROD in Appendix A.
U.S. Environmental Protection Agency
BRYAN Digitally signed by BRYAN
By: OLSON ^2021.03.30 08:55:34
Bryan Olson, Director
Superfund and Emergency Management Division
Region 1
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Wilmington, Massachusetts
March 2021
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PART 2: THE DECISION SUMMARY
A. SITE NAME, LOCATION, AND BRIEF DESCRIPTION
The 01 in Chemical Superfund Site (CERCL1S ID# MADOO1403104) is located in Wilmington,
Middlesex County, Massachusetts (see Figure 1 in Appendix C of this ROD for Site locus and features).
EPA is the lead agency and MassDEP is the support agency.
The Site is comprised of the Property, an approximately 50-acre parcel located within an industrial park at
51 Eames Street in Wilmington, Massachusetts and adjoining off-Property areas that have been impacted
by releases from manufacturing and waste disposal activities formerly conducted at the Property (see
Figures 2 and 2a in Appendix C of this ROD for current and historical Site features and a historical
photograph, respectively). The Property is located in a general industrial zone, however, the 20-acre
southern portion of the Property remains wooded and has been preserved in a predominately natural,
undeveloped condition by a conservation restriction (Environmental and Open Space Restriction,
recorded with the Middlesex North Registry of Deeds on November 7, 2006, Book 20680, Page 234).
The Property is bounded to the north by Eames Street and to the south by a closed municipal solid waste
landfill (Woburn Sanitary Landfill (WSL|) in the City of Woburn. The Property is bounded to the east by
an active rail line operated by the Massachusetts Bay Transportation Authority (MBTA) and a stream
called "East Ditch Stream" and to the west by an inactive Boston and Main rail line ("PanAM Railways")
and a stream called "Off-Property West Ditch Stream."
Industrial/commercial properties are located to the north and further east and west of the Property,
including a landfill located to the northwest of the Property known as the "Spinazola Landfill."3
Residential properties are located to the west and southwest of the Property along Border Avenue, Butters
Row, Chestnut Street, Cook Avenue, Hillside Way, and Mill Road. The Property is not in active
industrial use. The northern half of the Property is mainly unused and contains a vacated office building,
a small metal butler building, a former guard shack, two vacant warehouses, paved and grassed areas, and
concrete slabs from other former buildings. In 2006, 01in installed a forty-foot office trailer and two
metal storage trailers in the northeast quarter of the Property near Plant B, which houses a groundwater
treatment system.
Portions of the Site arc within the 100-year and 500-year floodplains (see Figure 5 in Appendix C of this
ROD for FEMA flood hazard areas). The Site includes the following wetland areas:
• "Central Wetlands," "Ephemeral Drainage" wetland complex, and "West Ditch Stream
Wetlands" located on the Property;
• Wetland and wooded areas located immediately to the east, south, and west of the Property; and
• A wetland complex called the "MMB wetlands" located approximately a quarter of a mile to the
west of the Property.
3 The Spinazola Landfill accepted municipal solid waste from the 1956 until 1976. On July 24, 2000, MassDEP
ordered that the landfill be closed and capped (MassDEP, 2000).
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To manage investigation and cleanup of the Site, EPA initially divided the Site into three OUs. OU1
consists of the Property, including all media (soil, sediments, and surface water), except for groundwater.
OU1 includes the area in the southern portion of the Property preserved in a predominantly natural,
undeveloped condition by a conservation restriction (see Section B, Site History and Enforcement
Activities, History of Site in Part 2 of this ROD, below), the on-Property stream system (East, South, and
On-Property West Ditch Streams), the Calcium Sulfate Landfill, and the Containment Area (see Figure 2
in Appendix C of this ROD for current and historical Site features). Wastes disposed of on the Property
caused surface water, sediment, and groundwater contamination both on- and off-Property.
OU2 consists of approximately three acres of soil, surface water, and sediment areas off-Property. This
OU includes portions of East and South Ditch Streams, Off-Property West Ditch Stream, portions of the
MMB wetlands, Landfill Brook, and North Pond.
OU3 consists of all groundwater, both on- and off-Property, and includes soil located below the water
table (see Figure 3 in Appendix C of this ROD for the contaminant plume in shallow overburden
groundwater and Figures 4, 4a, and 4b in Appendix C of this ROD for two views of the contaminant
plume in deep overburden groundwater and a transect of the deep overburden plume and DAPL pools,
respectively). This OU includes groundwater beneath the Property, groundwater north, south, and east of
the Property, groundwater west and northwest of the Property, including the MMB aquifer, and private
residential wells in the overburden and bedrock aquifers.
Groundwater is found both in the overburden and bedrock formations; however, area groundwater is
affected by the groundwater divide that crosses the Property and separates the Ipswich River and
Aberjona River Watersheds (see Section B, Site History and Enforcement Activities in Part 2 of this
ROD, below). Shallow groundwater at the Property flows to Site surface waters, which remain consistent
with shallow groundwater flow patterns, as both flow to the south and east.
The Commonwealth has classified portions of the Site to be within a Zone 11 - an area of an aquifer that
contributes water to a well under the most severe pumping and recharge conditions that can be
realistically anticipated (MassDEP, 2010a).4 The Zone II area extends from the Site north and west. In
addition, the Commonwealth identified three MCP classifications at the Site (see 310 CMR 40.0974(2)):
GW-1 (groundwater that is or could be used for drinking water); GW-2 (shallow groundwater near
buildings that could pose a vapor concern to indoor air); and GW-3 (groundwater at all disposal sites is
considered to be a potential source to surface water and shall be categorized, at a minimum, as GW-3).
Because a portion of the Site falls within a GW-1 area (the Zone II to the north), and due to the close
proximity of priv ate drinking water wells and the GW-1 "Potential Drinking Water Source Area" to the
south, and additionally in light of the factors contained in EPA's Final Ground Water Use and Value
Determination Guidance (USEPA, 1996a), the Commonwealth determined that there is a high use and
value for the Site area aquifer (see MassDEP, 2010a).
4 Per the MCP, Current or Potential Drinking Water Source Areas are classified as GW-1. A Current Drinking
Water Source Area includes groundwater within Zone II and within 500 feet of a private water supply well. A
Potential Drinking Water Source Area includes groundwater within a Potentially Productive Aquifer that has not
been excluded as a Non-Potential Drinking Water Source Area.
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A more complete description of the Site can be found in the Site Description sections of the July 2015
Final OU1/OU2 RIReport (AMEC, 2015a) and June 2019 Draft OU3 RIReport (Wood, 2019).
B. SITE HISTORY AND ENFORCEMENT ACTIVITIES
1. History of Site
The Site is comprised of the Property, an approximately 50-acre parcel located within an industrial park at
51 Eames Street in Wilmington, Massachusetts and adjoining off-Property areas that have been impacted
by contaminant releases from manufacturing and waste disposal activities formerly conducted at the
Property (see Figure 2 in Appendix C of this ROD for current and historical Site features). The former
manufacturing facility (Facility) was located within the 30-acre northern portion of the Property, which
manufactured specialty chemicals for the rubber and plastics industries beginning in 1953 until the
Facility ceased operations in 1986. Construction at the Facility began in 1952 by National Polychemicals,
Inc. (NPI), and operations by NPI commenced in 1953, around which time natural drainage features,
streams, and the wetland drainage complex were modified. From 1953 to 1968, the business conducted
by NPI was owned by three different corporations: American Biltrite Rubber Co., Fisons Limited, and
Fisons Corporation, which became known as NOR-AM Agro LLC. In 1968, Stepan Chemical Company
bought the business and continued to operate the Facility until 1980, when the Facility was purchased by
Olin. Olin submitted closure plans for the Facility to MassDEP and EPA in April 1986 and closed the
Facility in the same year. Olin remains the current owner of the Property.
Manufacturing activities were conducted at the Property from 1953 until 1986. From 1953 onward, the
Facility expanded incrementally (additional buildings were constructed) as additional products and
processes were added and as processes were modified.5 Products produced included the following:
• nitrogen blowing agents
o Opex (dinitrosopentamethylenetetramine);
o Kcmpore (azodicarbonamidc);
o Nitropore OT (4,4' oxybisbenzenesulfonylhydrazide or OBSH); and
o Nitropore 5PT (5-phenyltetrazole);
• blowing agent activators;
• polymerization initiators;
• antioxidants stabilizers
o dioctyldiphenylamine or Wytox ADP;
o trosnonylphenyl phosphite or Wytox 312; and
o alkylated phenol or Wytox Pap;
• retarders (N-nitrosodiphenylamine);
• processing aids;
• phthalate plasticizcrs
o di-n-octylphthalate; and
o dibutyl phthalate;
5 See, for example. Smith, 1997, Olin, 2002a, and Olin, 2002b for information on raw materials used, products
manufactured, and chemical wastes disposed of at the Property.
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• chemical intermediates (such as hydrazine); and
• phenolic resins (phenol-formaldehyde resin).
The nitrogen blowing agents - Opex and Kempore - were the largest volume products manufactured at
the Facility; both products were manufactured from the 1950s through 1986.
Raw materials utilized during the operating history of the Property included the following:
• diphenylamine;
• di-n-octylphthalate;
• bis-2-ethylhexylphthalate (BEHP);
• diisobutyleneTMP mixture used at Plant B in the manufacture of Wytox ADP;
• #415 process oil;
• phenol;
• nonylphenol;
• formaldehyde (formalin);
• dimethylformamide;
• dinonylphenol;
• sodium nitrite;
• 2-ethylhexoic acid;
• butanol;
• anhydrous ammonia;
• hydrazine;
• sodium dichromate;
• chlorosulfonic acid;
• diphenyl oxide;
• ammonium hydroxide;
• benzonitrile;
• hydrochloric acid;
• sulfuric acid; and
• sodium dichromate (used as a catalyst in the manufacture of Kempore until 1967, when its use
was discontinued).
Between 1953 and approximately 1970, all liquid wastes generated at the Facility were disposed of in
unlined pits on the northern half of the Property. These pits included Lake Poly, East and West Pits, and
the three Acid Pits. After 1972, liquid wastes were pretreated and sent to the Metropolitan District
Commission (MDC) sewer connection. However, significant disposal of liquid wastes continued due to
leaking lined lagoons until at least 1983.6 On-Property waste disposal practices resulted in soil, sediment.
6 See US I i PA, 2020a, Attachment A. Acidic waste streams were neutralized with lime and discharged to the lined
lagoons, which were located almost entirely within the footprint of the Containment Area.. .According to monitoring
data from the late 1970s, the lined lagoons were leaking at that time. Evaluation of sludge and inspection of the
Lagoon I liner in the fall of 1981 confirmed that the liner was perforated and allowed leakage of fluids from the
lagoon. A 1982 hydrogeologic investigation determined that between 52,900 and 240,000 gallons of
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and groundwater contamination both on- and off-Property. Constituents in liquid waste streams and in
releases to the environment included the following:
• chromium;
• BEHP;
• n-nitrosodiphenylamine (NDPhA);
• n-nitrosodipropylamine (NDPrA);
• diisobutylene (mixture of 2,4,4-trimethyl-l -pentene and 2,4,4-trimethyl-2-pentene);
• formaldehyde;
• dimethylformamide;
• Opex;
• Kcmpore;
• sulfuric acid;
• hydrochloric acid;
• numerous salts of sodium and ammonia (sulfates, chlorides, nitrates, and nitrites);
• calcium sulfate (gypsum), produced and precipitated when wastewaters were neutralized with
lime (calcium hydroxide), after the use of sodium dichromate had been discontinued;
• polychlorinated biphenyls (PCBs), used in electrical transformers at OU1 and released to soil; and
• processing oil, released to soil and the subsurface in the area of the Plant B tank farm, discussed
further below.
NDMA - a semi-volatile organic compound (SVOC) found in DA PL and groundwater - is the primary
Site COC, as it is the most toxic contaminant and most mobile in the aquifer. COCs in DAPL and
groundwater also include other SVOCs and volatile organic compounds (VOCs; associated with chemical
processes used at the Facility) and inorganic compounds.
Inorganic compounds found in DAPL and groundwater generally include the following;
• sodium;
• calcium;
• chloride;
• iron;
• magnesium;
• sulfate;
• ammonia or ammonium ion;
• aluminum; and
• chromium.
wastewater.. .leaked through Lagoon I in approximately one month... Similar volumes of wastewater were
speculated to be leaking from Lagoon II because it was receiving the same sludges and operating in the same fashion
as Lagoon I...A 1979 study determined that sludge had also been dumped in an emergency unlined lagoon located
adjacent to the lined lagoons (and within the Containment Area) when the lined lagoons were filled to
capacity.. .Accordingly, significant disposal of wastes in the Containment Area through leaks in the lined lagoons
and disposal in the emergency lagoon likely occurred until at least 1983.
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Wilmington, Massachusetts
March 2021
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VOCs found in DAPL and groundwater generally include the following:
• acetone;
• bromoform;
• 2-butanone;
• 2-hexanone;
• toluene; and
• TMPs.
SVOCs found in DAPL and groundwater generally include the following:
• benzoic acid;
• BEHP;
• phenols;
• napthalene;
• NDPhA; and
• NDMA; and
• other nitrosamines.
The chemicals identified in the preceding paragraphs arc considered to be COCs, and have been released
to one or more environmental media. Additional COCs, including inorganic compounds, VOCs, and
SVOCs, have been detected in DAPL and groundwater (see Table B-l in Appendix B of this ROD; see
also summary in Table 4-3.1 and full detected results in Appendix E of the June 2019 Draft Oil3 RI
Report). The releases included process waters and liquid wastes, discharged to unlined excavations in the
native soil (lagoons) and later released from leaking lined lagoons. The discharged liquids percolated into
the soil and groundwater or overflowed into the on-Property stream system until at least 1983. The liquid
wastes had high concentrations of dissolved inorganic constituents and fluid densities greater than water,
allowing these dense liquids (as DAPL) to penetrate the underlying overburden water table and migrate
vertically downward to the bedrock surface. Once at the bedrock surface, the DAPL migrated by a
combination of gravity flow and due to the pumping influence from the Town of Wilmington's public
water supply wells (see discussion in Section E, SITE CHARACTERISTICS, Hydrogeology, Pumping
Impacts in Part 2 of this ROD, below) and pooled in a series of cascading bedrock depressions. A
groundwater divide is present west of the Property and DAPL migrated by gravity to the west and
northwest across the groundwater divide, opposite to the easterly direction of overburden groundwater
flow.
The Site, including the Property, is bisected by surface water and groundwater divides which are broadly
co-located (however, the groundwater divide varies significantly both historically and seasonally),
between the Ipswich River Watershed to the north and west, and the Aberjona River Watershed to the
south and east (see Figure 1 in Appendix C of this ROD for watershed delineations). The location of the
divides result in the former source areas, with the exception of Plant B and the currently known areas of
TMP contamination, being generally within the Aberjona River Watershed, while significant groundwater
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Wilmington, Massachusetts
March 2021
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contamination is spread over both the Aberjona and Ipswich River Watersheds.7 RI data collection efforts
for OU3 show that shallow groundwater across the OU1 -portion of the Site is generally level, and that the
location of the watershed divide varies seasonally and has varied historically.
Under natural and pumping-influenced conditions, the DAPL migrated within a sloping bedrock valley -
the Western Bedrock Valley (WBV) - and generally remains as three pools in bedrock depressions
located both on- and off-Property. The DAPL contains constituents that are water soluble and continue to
migrate from the bedrock depressions into the overlying groundwater, acting as a continuing,
uncontrolled source of contamination. The layer of groundwater overlying DAPL, into which
contamination from DAPL continues to migrate, is part of the area of the aquifer termed "groundwater
hot spots" or "hot spot groundwater" (see further discussion below in Part E, SITE
CHARACTERISTICS, Section 2, Conceptual Site Model, Nature and Extent of Contamination, OU3
Groundwater in Part 2 of this ROD ). The full extent of DAPL present in bedrock fractures is unknown
at this time and is currently under investigation.
The Site was listed on the NPL primarily due to the presence of N DM A in groundwater within the MMB
aquifer in proximity to the Town of Wilmington's municipal water supply wells (see discussion in the
History of Federal and State Investigations and Removal and Remedial Actions section, below).
However, NDMA has not been identified as a raw material, a manufactured product, or a waste stream
constituent at the Site. NDMA has been identified in DAPL, groundwater, and surface water. The
precise formation mechanism for NDMA at the Site has not been identified, however, it is believed to
have formed in the aquifer as liquid wastes migrated downwards through the subsurface (see discussion in
the Conceptual Site Model section, below).
Currently, the northern half of the Property is mainly unused and contains a vacated office building, a
small metal butler building, a former guard shack, two vacant warehouses, paved and grassed areas, and
concrete slabs from other former buildings. In 2006, 01 in installed a forty-foot office trailer and two
metal storage trailers in the northeast quarter of the Property near Plant B, which houses a groundwater
treatment system.
The Plant B groundwater recovery/treatment system has been in operation since 1981. The system was
installed to prevent seepage of LNAPL into East Ditch Stream, which was released to soil and the
subsurface in the form of a processing oil in the area of the Plant B tank farm.8 Groundwater extracted by
the system is treated to remove iron and ammonia, as well as dissolved organic compounds. The treated
groundwater is discharged to on-Property surface water in compliance with a Remediation General Permit
(RGP).
7 The June 2019 Draft OU3 RI Report (USEPA, 2020b) provides a more in-depth examination of this issue and
detailed, watershed-specific discussions of the nature and extent of DAPL and groundwater contamination.
8 According to the Comprehensive Site Assessment Phase II Field Investigation Report (CRA, 1993), interviews
with former workers at Plant B indicate that multiple spills occurred in the Plant B area. Materials allegedly spilled
included diisobutylene, diphenylamine, dioctylphthalate, dioctyldiphenylamine, and fuel oil. According to the
Supplemental Phase II Report (Smith, 1997), as early as 1973, MassDEP contacted the Facility about a seep of oily
material in East Ditch Stream, adjacent to the Plant B tank farm. A 1973 analysis of the oil (from well IW-11)
indicated that the oil contained a high percentage of BEHP and lesser amounts of NDPhA, dioctylphthalate, and
TMPs.
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Wilmington, Massachusetts
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The Property contains a slurry wall containment structure with a temporary cap - the "Containment Area"
- that was constructed in 2000/2001 as a Release Abatement Measure (RAM) under the oversight of
MassDEP. This source control action was not ultimately successful; however, its intent was to eliminate
the on-Property DAPL source material as a source of dissolved constituents to groundwater. The
Containment Area structure is comprised of a perimeter slurry wall installed to the bedrock surface and a
temporary cap to minimize infiltration of precipitation. The temporary cap is a scrim-reinforced
polyethylene sheet cover with sewn scams, held in place by sandbags and gravel ballast along the edges.
A water table equalization window within the slurry wall allows the groundwater surface within and
outside the slurry wall to equilibrate.
With the exception of the Calcium Sulfate Landfill (CSL) feature in the southernmost end of the Property,
the 20-acre southern portion of the Property remains wooded. This portion of the Property has been
restricted by a conservation restriction - an Environmental and Open Space Restriction - that, among
other things, preserves this area in its predominantly natural, undeveloped condition.9 The CSL feature is
approximately 2.5 acres in size and was capped in 1988. MassDEP issued a determination on January 7,
2009 that the CSL had been capped in conformance with the landfill design plans and was deemed closed
in accordance with the Massachusetts Solid Waste Management Facility Regulations (310 CMR 19.000),
subject to conditions, including monitoring in accordance with a December 2006 post closure monitoring
plan. On March 3, 2011, MassDEP issued an approval of a modification of the post closure monitoring
plan (MassDEP, 2011).
To facilitate investigation of the Site, EPA subdivided the Site into three OUs, briefly described as
follows:
OU1: On-Property soil, sediments, and surface water;
OU2: Off-Property soil, sediments, and surface water; and
OU3: All on- and ofT-Property groundwater areas that have been affected by contamination from the
Property, including DAPL.
A more detailed description of the Site history can be found in the Site Description and Site History
section of the July 2015 Final OU1/OU2 RIReport (AMEC, 2015a) and the Site Background section of
the June 2019 Draft Oil 3 RI Report (Wood, 2019). For further details on the scope of each OU, see
Section D, SCOPE AND ROLE OF OPERABLE UNIT OR RESPONSE ACTION in Part 2 of this
ROD, below.
2. History of Federal and State Investigations and Removal and Remedial Actions
Table B-2 prov ides a summary of Federal and State Site investigations and response actions.
9 The Environmental and Open Space Restriction, recorded in the Middlesex North Registry of Deeds on November
7, 2006, Book 20680, Page 234, was negotiated by and between Olin, MassDEP, and the Town of Wilmington,
acting by and through its Conservation Commission, in full settlement and satisfaction of the requirements for the
imposition of a land use restriction as provided in MassDEP's 401 Water Quality Certification, dated July 27, 2000,
and Wilmington Conservation Commission's Order of Conditions, dated July 25, 2000.
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Wilmington, Massachusetts
March 2021
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Table B-2
Date
Action
Legal
Authority
Performing
Party
Results
Related Documents
1975 to
1986
Response
Action
PRP
Treatment plant
constructed to treat
liquid wastes;
creation and
operation of the CSL
to receive sediments
from Facility
settling ponds
1980
Site
Assessment
(SA)
CWA and
Resource
Conservation
and Recovery
Act (RCRA)
EPA
Site Inspection (SI)
Report (Ecology,
1980)
1981
Response
Action
PRP
Installation and
operation of Plant B
groundwater
recovery/treatment
for LNAPL to
prevent impacts to
East Ditch Stream
1986
Preiiminarv
Assessment/
Site
Inspection
(PA/SI)
Massachusetts
General Laws
(MGL)
Chapter 2 IE
and MCP, 310
CMR 40.000
Massachu-
setts
Department
of Environ-
mental
Quality
Engineering
(Mass
DEQE)
Phase I SI Report
(Wehran. 1986)
EPA Potential
Hazardous Waste
Site SI Report
(Wehran, 1986)
1987
Response
Action
Massachusetts
Solid Waste
Management
Facility
Regulations,
310 CMR
19.000
PRP
Dismantling of the
lined lagoons and
capping and closure
of CSL
Completion of
Closure (MassDEP,
2009)
1990
Response
Action
MCP, 310
CMR 40.000
PRP
Olin begins to
sample certain Cook
Ave and Border Ave
private residential
wells located near
the Olin property for
VOCs, SVOCs,
pesticides, PCBs,
metals, and general
Comprehensive SA
Phase II Field
Investigation Report
(CRA, 1993)
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Wilmington, Massachusetts
March 2021
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Table B-2
Date
Action
Legal
Authority
Performing
Party
Results
Related Documents
chemistry. After
initial sampling, the
samples were
analyzed for a more
limited suite of
analytes.
1991 to
1993
Site
Investig-
ation
MCP, 310
CM R 40.000
PRP
Olin collects
samples for full-
suite analysis from
Town of
Wilmington public
water supply wells
in the MMB aquifer,
additional residential
wells on Main St,
and monitoring
wells, including
NDMA as part of
the SVOC analysis;
detection limits were
extremely high
(approx. 10,000
ng/L) and NDMA
was not detected.
Comprehensive SA
Phase II Field
Investigation Report
(CRA, 1993)
1992
Notice of
Responsib-
ility
MGL Chapter
21E and MCP,
310 CM R
40.000
MassDEP
Notice of
Responsibility
(MassDEP. 1992)
1994
Response
Action
MCP, 310
CMR 40.000
PRP
Flocculant (floe)
precipitate removed
from Off-Property
West Ditch Stream
via vacuum truck
1997
Site
Investig-
ation and
Risk
Assessments
MCP, 310
CMR 40.000
PRP
Supplemental Phase
II Investigation
Report and Human
Health and
Ecological Risk
Assessments (Smith,
1997)
2000 to
2001
Response
Action
MCP, 310
CMR 40.000
PRP
Construction of
Containment Area
slurry wall and cap;
excavation and off-
site disposal of
contaminated on-
Part I RAM Approval
(June 2000); Part 2
RAM Approval
(August 2000);
Conditional
Approvals of RAM
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Wilmington, Massachusetts
March 2021
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Table B-2
Date
Action
Legal
Authority
Performing
Party
Results
Related Documents
Property soil and
sediments
Modifications
(September and
November 2000);
Status Report No. I,
Part 2 Construction
Related RAM (GEI,
2000b)
2000 to
2004
Response
Action
MCP, 310
CMR 40.000
PRP
Excavation and off-
site disposal of
contaminated soil
from Lake Poly area
Field Activity Report,
Former Lake Poly
Area (GEI, 2004a)
2000 to
2005
Response
Action
MCP, 310
CMR 40.000
PRP
Air Sparging/Soil
Vapor Extraction
(AS/SVE) to remove
more than 2,000
pounds TMPs from
subsurface soils near
Plant B; excavation
and removal of
drums, debris, and
contaminated soil
from Drum Areas A
and B and the
Buried Debris Area
Immediate Response
Action (IRA) Status
Reports (Shaw, 2005)
2002
Response
Action
MCP, 310
CMR 40.000
PRP
First sampling for
NDMA at the Site
with lower detection
limits (approx. 2
ng/L); NDMA first
detected in Town of
Wilmington's
municipal wells in
MMB aquifer; wells
taken off-line and
Town meets water
demand using other
municipal wells
2003 to
2006
Response
Action
MCP, 310
CMR 40.000
PRP
Testing of additional
private wells within
the OU3
groundwater study
area with lower
detection limits for
NDMA (approx. 2
ng/L)
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Wilmington, Massachusetts
March 2021
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Table B-2
Date
Action
Legal
Authority
Performing
Party
Results
Related Documents
2004
MassDEP
Requests that EPA
list Site on the NPL
2006
NPL Listing
CERCLA
EPA
Hazard Ranking
System (HRS)
documentation,
available at:
https JI serosixib. epa. a
ov/work/01/7500101
4.odf
2007 to
2015
Remedial
Investig-
ation
(OU1/OU2)
CERCLA
PRP
July 2015 Final
OU1/OU2 RI Report
(AMEC, 2015a)
Draft Focused RI
Report (MACTEC,
2007); Final R//FS
Work Plan
(MACTEC, 2009);
Preliminary RI
Report GUI
(MACTEC. 2011)
2007 to
Remedial
CERCLA
PRP
Revised June 2019
Draft Focused RI
present
Investig-
ation (OU3)
Draft OU3 RI
Report (Wood,
2019)
Report (MACTEC,
2007); Final RI/FS
Work Plan
(MACTEC, 2009);
OU3 Data Gaps
Work Plan (AMEC,
2014b); Final OU3
Data Gaps Work
Plan (AMEC,
2015b); Focused RI
Report - DAPL
(AMEC, 2017); Data
Gaps Work Plan
(Geomega, 2019);
Approval of Data
Gaps Phase 1A
Seismic Work
(USEPA, 2020d)
2008 to
2009
Response
Action
CERCLA
PRP
EPA requires Olin
sample 11 private
wells near the Olin
property for NDMA;
NDMA detected for
the first time in two
private wells on
Cook Ave at low
concentrations; EPA
requests that Olin
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Wilmington, Massachusetts
March 2021
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Table B-2
Date
Action
Legal
Authority
Performing
Party
Results
Related Documents
repeat and expand
the sampling;
construction of
drinking water line
extension to Town
of Wilmington
public water
distribution system
for residences near
the Olin property
2008 to
Interim
CERCLA
PRP
Design and
Final Interim
2012
Response
Action
construction of the
Jewel Drive DAPL
field pilot extraction
system
Response Steps Work
Plan (MACTEC,
2008)
2008 to
Response
CERCLA
PRP
Quarterly testing of
Residential Water
present
Action
private wells within
the OU3
groundwater study
area
Supply Results
(Nobis, 2020)
2010
Ground-
1998
MassDEP
Determination of
Groundwater Use
water Use
Memorandum
high use and value
and Value
and Value
of Agreement
for the Site area
Determination
Determin-
ation
between EPA
and MassDEP
aquifer
(MassDEP, 2010a)
2010
Interim
Measure
CERCLA
PRP
Provision of bottled
water to two private
well owners on
Cook Ave
NDMA in Private
Wells -
Recommendation to
Discontinue
Consumption
(USEPA, 2010);
Approval to Perform
an EE/CA for a Non-
Time Critical Action
(USEPA, 2011);
Response
Alternatives
Evaluation Report
(AMEC, 2012a)
2012 to
Interim
CERCLA
PRP
Operation of the
Final (MM Plan,
present
Response
Action
DAPL pilot
extraction system
DAPL Extraction
Pilot Test (AMEC,
2012b); Jewel Drive
DAPL Extraction
Pilot Report (AMEC,
2014a)
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Wilmington, Massachusetts
March 2021
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Table B-2
Date
Action
Legal
Authority
Performing
Party
Results
Related Documents
2015
Baseline
Human
Health Risk
Assessment
(OU1/OU2)
CERCLA
PRP
Final Baseline
Human Health Risk
Assessment
OU1/OU2
Appendix M, July
2015 Final
OU1/OU2 RI Report
(AMEC, 2015a)
2015
Baseline
Ecological
Risk
Assessment
(OU1/OU2)
CERCLA
PRP
Baseline Ecological
Risk Assessment
OU1/OU2
Appendix N, July
2015 Final
OU1/OU2 RI Report
(AMEC, 2015a)
2019
Baseline
Human
Health Risk
Assessment
(OU3)
CERCLA
PRP
Revised Draft
Baseline Human
Health Risk
Assessment OU3
Appendix K, Revised
June 2019 Draft OU3
RI Report (Wood,
2019)
2020
Remedial
Investig-
ation
Addendum
(OU1/OU2)
CERCLA
EPA
Updates to
Oil 1/Oil2 RIReport
Conclusions
(USEPA, 2020a)
2020
Remedial
Investig-
ation
Addendum
(OU3)
CERCLA
EPA
Updates to June
2019 Draft OU3 RI
Report Conclusions
(USEPA, 2020b)
2020
Feasibility
Study
Report
CERCLA
EPA/PRP
Evaluation of
Remedial
Alternatives
Volume 1 (Olin,
2020a); Volume 2
(Olin, 2020b);
Volume 3 (USEPA,
2020c)
Plant B/East Ditch
Risk Evaluation
(Nobis, 2019);
Residential Human
Health Risk
Evaluation Olin
OU1/OU2
Soils (Bluestone,
2020); Revised
Human Health Risk
Calculations for
Potable Use of
Private Residential
Wells (Olin, 2020c);
PRCs to Address
Ecological Risks in
Soils, Sediments, and
Surface Water
(Wood, 2020b)
PRCs to Address
Human Health Risks
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Wilmington, Massachusetts
March 2021
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Table B-2
Date
Action
Legal
Authority
Performing
Party
Results
Related Documents
in I)A PL,
Groundwater Hot
Spots, Upland Soil
(Including
Containment Area
Soil), and Surface
Water (Wood, 2020c)
Additional information on prior investigations and response actions can be found in the Study Area
Investigations (OU1/OU2) and Response Actions (OU1/OU2) section of the July 2015 Final OU1/OU2
RIReport (AMEC, 2015a) and the Study Area Investigations section of the June 2019 Draft OU3 RI
Report (Wood, 2019).
3. History of CERCLA Enforcement Activities
EPA has performed a number of PRP search related activities, including sending information requests
pursuant to CERCLA Section 104(e), reviewing files, and performing record searches. As a result of
those PRP search activities, EPA issued notice of potential liability letters to: American Biltrite, Inc.,
Biltrite Corp., Olin Corporation, and Stepan Company on January 12, 2006, and Fisons Limited and
NOR-AM Agro LLC on May 24, 2006. These parties either owned or operated the Facility at a time
when hazardous substances were disposed of there or are a successor to an entity that was the owner or
operator of the Facility at a time when hazardous substances were disposed of there. Olin Corporation is
also the current owner and operator of the Facility.
On June 19, 2006, EPA issued special notice letters pursuant to Section 122(c) of CERCLA requesting
participation in negotiations for performance of an RI/FS to these PRPs. On July 3, 2007, American
Biltrite, Inc., Olin Corporation, and Stepan Company entered into an Administrative Settlement
Agreement and Order on Consent for RI/FS (U.S. EPA Docket No. CERCLA 01-2007-0102) for the Site,
(referred to herein as the "AOC for RI/FS").
On August 12, 2020, EPA issued Potentially Interested Party (PIP) letters to two parties, Bayer
Corporation and Sanofi U.S. Services, Inc.
The AOC RI/FS Respondents (Olin Corporation, American Biltrite, Inc., and Stepan Company) have
been active in the remedy selection process for the Site. The Respondents funded and/or performed the
studies and investigations upon which the FSReport and Proposed Plan were based. One PRP submitted
comments on the Proposed Plan. The PRP comment letter (as well as other comments received during
the comment period) are included in the Administrative Record. The comments are summarized and
responded to in the Responsiveness Summary in Part 3 of this ROD.
C. COMMUNITY PARTICIPATION
Throughout the Site's history, community concern and involvement has been consistent. 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.
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Wilmington, Massachusetts
March 2021
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• In 2006, EPA conducted the first public meeting for the Site. Public meetings were
subsequently conducted in 2007, 2008, 2009, 2010, 2011, 2014.
• On November 12, 2009, EPA initiated consultation with the National Oceanic and Atmospheric
Administration, Coastal Protection and Restoration Division, the Department of Interior, Office
of Environmental Policy and Compliance, and the Commonwealth of Massachusetts, Executive
Office of Energy and Environmental Affairs, Department of Environmental Protection, Natural
Resource Damages Program to provide notification concerning the upcoming RI/FS activities at
the Site.
• In 2010, EPA conducted door-to-door in-person outreach with an official from the Town of
Wilmington's Board of Health to verify the location of private wells (potable and irrigation) and
obtain access for the private well testing program.
• In 2019 and 2020 during the period leading up to the release of the Proposed Plan, EPA
participated in conference calls and meetings with officials from the Town of Wilmington and
MassDEP and members of the Wilmington Environmental Restoration Committee (WERC) to
provide updates on the RI/FS work and discuss and coordinate public outreach for the Proposed
Plan.
• On September 11, 2019, EPA met with officials from the Town of Wilmington and MassDEP to
discuss the ongoing RI/FS at the Site, plan for the upcoming open house and informational
meeting, and discuss next steps including the release of the Proposed Plan.
• On October 22, 2019, EPA held an open house and informational meeting in Wilmington. MA
to update the community about the ongoing RI/FS at the Site, provide information on the Site
background and history, answer questions, and explain next steps. Prior to the meeting, EPA
provided notice to residents in the Town of Wilmington and City of Woburn via a "Save-the-
Date" postcard mailing, and issued a press release and informational fact sheet.
• On August 12, 2020, EPA's Proposed Plan was uploaded to the Site webpage along with
instructions on how community members could participate in the virtual public informational
meeting on August 25, 2020 and virtual formal public hearing on September 22, 2020. An
Eventbrite pre-registration link was also added to track the number of participants and facilitate
the question-and-answer portion of the informational meeting and the prov ision of oral
comments during the formal hearing.
• On August 12, 2020, EPA made the Administrative Record for the Proposed Plan, including the
RI and FS reports, available for public review on the Site webpage. The Administrative Record
is the primary Site information repository for residents and other community members and has
been kept up to date by EPA.
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Wilmington, Massachusetts
March 2021
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• On August 12,2020, EPA issued a press release announcing the availability of the Proposed
Plan and the dates of the virtual public informational meeting and virtual formal public hearing.
Additionally, EPA provided notice to residents in the Town of Wilmington and City of Woburn
via a "Save-the-Date" postcard mailing. EPA also sent notification to the Site e-mail
distribution list. Town officials in the neighboring towns of Woburn, Reading, and Burlington
were also notified.
• On August 12, 2020, EPA published a legal notice in the Wilmington Town Crier announcing
the availability of the Proposed Plan, identifying EPA's proposed remedy for the Site, and
including a link to the Proposed Plan on the Site webpage.
• On August 25, 2020, EPA held a virtual public informational meeting via the Adobe Connect
platform to provide information on the Site background and history, summarize the activities
and findings of the RI/FS, present EPA's proposed remedy for the Site, explain next steps, and
answer questions. The event was held virtually due to the COVID-19 pandemic and state and
local government restrictions on large gatherings. The meeting was recorded and closed
captioning was made available.
• From August 26, 2020 through October 26, 2020, EPA held a 60-day public comment period to
accept public comments on EPA's proposed remedy for the Site, as presented in the Proposed
Plan. EPA accepted comments via mail and e-mail during the comment period, as well as via a
dedicated voice mailbox.
• On September 22, 2020, EPA held a virtual formal public hearing via the Adobe Connect
platform to provide the community with an opportunity to provide oral comments on EPA's
Proposed Plan for the Site for the official record. Oral comments received during the virtual
hearing were transcribed by a stenographer and included as part of the Administrative Record
for the ROD.
• On January 19, 2021, EPA initiated consultation with the Massachusetts Historical Commission
and the Mashpee Wampanoag Tribe, pursuant to EPA's obligations under Section 106 of the
National Historic Preserv ation Act of 1966, as amended, to provide notification concerning
EPA's preparation of the ROD. EPA's correspondence to the Massachusetts Historical
Commission was received on January 27, 2021. In a telephone call with EPA on February 19,
2021, Massachusetts Historical Commission staff identified the Middlesex Canal as a historic
and cultural resource located within the off-Property area of the Site.
D. SCOPE AND ROLE OF OPERABLE UNIT OR RESPONSE ACTION
As with many Superfund sites, the problems at the 01 in Chemical Superfund Site are complex. As a
result, EPA has organized the work into three OUs:
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• 0U1: Includes on-Property soil, sediments, and surface water; vadose-zone soil (soil above the
water table); and VI. Includes the Property, including the Facility and Facility area, the
approximately 20-acre southern area that is restricted by a conservation restriction, on-Property
stream system. CSL, and Containment Area.
• OU2: Includes off-Property soil, sediments, and surface water. Includes East Ditch Stream, a
portion of South Ditch Stream, Off-Property West Ditch Stream, portions of the MMB wetlands,
and North Pond.
• OU3: The OU3 groundwater study area was designed to investigate the nature and extent of
contamination in the Ipswich River and Aberjona River Watersheds. Includes the MMB aquifer,
groundwater beneath the Property, and groundwater to the north, south, east, and west of the
Property that has been affected by contamination associated with the Property.
RI work at the three OUs was conducted pursuant to an AOC signed in July 2007. RI work was
undertaken by Olin on behalf of the Respondents (Olin, American Biltritc Inc., and Stephan Company).
RI work for OU1/OU2 culminated in the submittal to EPA of the July 2015 Final OU1/OU2 RI Report in
2015 (AMEC, 2015a). This report included a BHHRA for OU1/OU2 as Appendix M, and a BERA for
OU1/OU2 as Appendix N. RI work for OU3 was also conducted beginning in 2007 and is still ongoing.
In 2019, Olin submitted the June 2019 Draft OU3 RI Report to EPA (Wood, 2019), which included a
Revised Draft BHHRA for OU3 as Appendix K. Together with a report on the outcome of the Jewel
Drive DAP/, extraction pilot (AMEC, 2014a), the July 2015 Final OU1/OU2 RI Report and the June 2019
Draft OU3 RI Report summarize the nature and extent of contamination at the Site. EPA supplemented
these three documents with RI addenda (USEPA, 2020a and USEPA, 2020b) and additional risk
evaluations (Nobis, 2019, Blucstone, 2020, Olin, 2020c, Wood, 2020b, and Wood, 2020c).
Based on the findings presented in these reports, EPA determined that sufficient information was
available to evaluate alternatives to address soil, sediments, and surface water contamination in OU1 and
OU2 and to evaluate alternatives to initiate source control actions for groundwater (OU3). However,
there were several data gaps regarding the full extent of contamination in groundwater. Therefore, EPA
proceeded with the development of the FS Report for the Site, issued as three volumes (Olin, 2020a, Olin,
2020b, and USEPA, 2020c). The FS Report provides the basis for the selected final remedy for
OU1/OU2 to mitigate risks from soil, sediments, and surface water and an interim remedy for OU3 to
initiate source control for groundwater. Additional investigation activities arc still ongoing for OU3 and a
final remedy will be selected following completion of the OU3 RI/FS.
E. SITE CHARACTERISTICS
The findings of the Final July 2015 OU1/OU2 Report and the June 2019 Dra ft OU3 RI Report arc
summarized below. An overview of the RI activities may also be found in Section I of the FS Report
Volume I and FS Report Volume II.
1. Physical Setting
The Site is in the southern part of Wilmington, Massachusetts and includes the approximately 50-acrc
Property and surrounding areas to the north, south, east, and west where contaminants have migrated by
surface water and/or groundwater transport. The location of the Property and other Site features are
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shown on Figure 1 in Appendix C of this ROD. Features specific to the Property, including former
disposal areas, infrastructure, and remedial features are shown on Figure 2 in Appendix C of this ROD.
The northern portion of the Property, also known as the industrial area, includes the former administration
office building and laboratory, a small butler building, a guard shack, the East and West warehouses, the
Plant B Treatment Building, and an office trailer. These structures, except for Plant B and the office
trailer, are unoccupied with "Do Not Enter" signs posted. Most of the former plant buildings and other
structures have been demolished with only concrete slabs remaining. The Plant B treatment building and
office trailer have electric service and are served by municipal water. The northern industrial area of the
Property and the industrial areas surrounding the Property are partially covered in concrete and pavement.
The southern half of the Property is undeveloped and consists largely of wetlands and mature forest,
except in the southwestern corner where the closed CSL is located. As discussed above in Section B(l),
History of Site in Part 2 of this ROD, approximately 20 acres within this forested area (including the
CSL) is subject to the terms of an Environmental and Open Space Restriction.
On- and off-Property surface water bodies are shown in Figures 1 and 2 in Appendix C of this ROD.
The Property is bounded to the north by Eames Street; to the south by the Woburn/Wilmington town line
and the WSL (currently closed); to the east by the MBTA railroad tracks and East Ditch Stream; and to
the west by the Pan AM Railways railroad spur and Off-Property West Ditch Stream. Intensive industrial
land use occurs on the eastern, northern, and western sides of the Property. Residential properties are
located along Main Street and Cook Avenue to the west of the Property and along Eames Street before it
intersects with Woburn Street.
Site Topography
The dev eloped, northern portion of the Property is essentially flat (see Figure 6 in Appendix C of this
ROD for Site topography); the undev eloped, southern portion of the Property has slightly more
topographic relief. The MBTA rail line creates a topographic low along the eastern side of the Property.
A low ridge runs along the southern boundary of the Property. The WSL is a prominent topographic high
immediately south of the Property; beyond the WSL the land becomes flatter and lower in elevation.
On-Property topographic features include an east-west trending low-lying area that forms South Ditch
Stream and Ephemeral Drainage, and includes Central Pond and a stormwater detention basin located
between the Containment Area and South Ditch Stream. This low-lying area is bounded by East and
West Ditch Streams and railroad tracks on cither side of the Property. Elevations just beyond East and
West Ditch Streams and the railroad tracks are similar and relatively flat. The area immediately west of
the northern portion of the Property is relatively flat. The area immediately west of the southern portion
of the Property features a small hill that includes several residences along Cook Avenue and Border
Avenue. To the northwest of the Property, on the western side of Main Street in Wilmington, the
topography drops to lower elevations near and within the MMB wetlands. The MMB wetlands arc
bordered by upland areas to the west of Chestnut Street, and to the north by a broad ridge that runs
parallel to Butters Row.
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Site Geology
The unconsolidated overburden stratigraphy of the Property includes unconsolidated organic materials
and quaternary glacial deposits (ice contact deposits, outwash deposits, and glacial till). These
unconsolidated deposits arc overlain by fill. The area surrounding the Property is characterized by
bedrock knobs and basins, with generally shallow bedrock that drops off in a series of basins that extend
westward to the MMB wetlands. The MMB wetlands are underlain by a major fracture zone that forms
the WBV. The bedrock surface in the WBV reaches depths of over 120 feet bgs.
The geologic units arc identified as follows (in descending order from the ground surface):
• Fill: Fill was identified over the developed portion of the Property ranging in thickness from 1-12
feet. Fill consists of uniform sand that appears to be a reworked native soil. Unless debris or
foreign materials were present in this material, it was often difficult to distinguish fill from
undisturbed native material.
• Peat/organic silts: Peat deposits were encountered in the formerly industrial portion of the
Property. The organic peat layer is typically encountered at or just below the ground surface. In
some low-lying drainage swales, the peat is encountered at the ground surface but more typically
the peat layer, where present, is overlain by fill material and/or sandy alluvial material and
encountered at depths of 2-11 foot (ft) bgs. Thick layers of peat and silt/clay are also located in
the interior of the MMB wetlands complex.
• Ice contact and outwash deposits: At the Property, these materials are present below the peat and
in some areas directly below the fill. These deposits consist of layers of fine, clean sand
interbedded with sand, gravel, and cobbles ranging from 2-10 feet thick. Thick sand and gravel
deposits are also located within upland areas adjacent to the MMB wetlands complex.
• Glacial till: both basal and ablation till are present; till deposits appear to be thickest in the
deepest incised portions of the WBV.
o Ablation till deposits are generally loose and poorly sorted and consist of well graded
sands and gravels with relatively less silt and clay. The ablation till encountered at the
Property was characterized by the presence of cobbles and silt and was well graded
compared to the relatively uniform ice contact and outwash deposits. The depth to the
top of the ablation till varied from 5-32 ft bgs across the Property .
o The basal till consists of well graded fine to coarse sand and gravel and may contain
appreciable amounts of silt and clay. Basal till is located directly over the bedrock and
may have a lower transmissivity than the ablation till. The interpreted basal till
encountered at the Property was distinguished from the ablation till by the higher fines
content, with enough silt to appear as a cohesive soil. The basal till underlies the ablation
till over much of the Property and was typically encountered in thicknesses of 1-6 feet.
• Bedrock: Generally, bedrock is associated with the Composite Platform of Southeast New
England or more specifically the Milford-Dedham Zone. This zone includes late Proterozoic and
early Paleozoic rocks (also called the Aval on Zone) that lie between the Bloody Bluff Fault and
the Northern Boundary Fault of the Boston Basin. The igneous rocks are predominantly gabbro
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and diorite complexes, with gabbro-diorites that are moderately resistant to weathering and
erosion; cataclastic gabbro-diorites that are more easily weathered, and in turn are found in the
topographically lower terrain with more gentle slopes; and granitic intrusions which are most
competent bedrock and outcrop at the elevated areas near the CSL and near Cook Avenue.
Extensive bedrock fractures are present between the WBV and the Bloody Bluff Fault to the
northwest and along the axis of the WBV. The bedrock at the WBV and closer to the Bloody
Bluff fault within the Burlington Mylonite Zone appears to be more fractured and contains larger
fracture apertures. Bedrock closer to and within the Property may be less fractured, particularly
in the vicinity of bedrock knobs and outcrops. Borings installed in siliceous units such as
quartzite showed limited to sparse fracturing.
Hydrogeology
Groundwater generally flows to the northwest and southeast along a groundwater divide that crosses the
northern portion of the Property and separates the Aberjona and Ipswich River Watersheds. Shallow
overburden groundwater interacts with surface water, while bedrock groundwater does not directly impact
surface water.
Overburden Groundwater Hydrogeology and Hydrology
Figures 7, 8, and 9 in Appendix C of this ROD show the interpreted potentiometric surface across the
Site in shallow overburden, deep overburden, and bedrock groundwater, respectively. These figures also
show the estimated location of the groundwater divide between the two watersheds, which is the
dominant hydrologic feature that separates groundwater flow between the Ipswich River Watershed to the
north and west and the Aberjona River Watershed to the south and east.
The groundwater divide cuts across the northern portion of the Property, slightly south of and parallel to
Eames Street, and continues to the southwest between Main Street and Jewel Drive. The groundwater
divide is influenced by both topography and the location of surface water drainage patterns. Groundwater
elevation changes in the vicinity of the divide are very small and sensitive to seasonal differences in the
groundwater surface; therefore, the location of the divide will shift based on hydrologic conditions.
The hydraulic conductivity (K) of the Site aquifers vary widely depending on location and soil type:
• Glacial tills exhibit K values from less than 1 to 3 feet/day.
• Finer sandy and silty fine sand deposits typical of on-Property areas and areas to the southeast
range from 3-15 feet/day.
• Coarser sand and gravel deposits encountered in the thicker overburden to the west (including ice
contact deposits) range up to 75 feet/day.
• Coarser sand and gravel deposits with cobbles, which predominate in the middle section of the
MMB aquifer, vary widely with K values reported of over 500 feet/day, but probably averaging
140-250 feet/day.
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Groundwater flow rates are estimated to range from 15—45 feet per year (or more) in the MMB aquifer.
Groundwater flow rates are higher in the area of the Property due to steeper gradients despite lower K
values.
Vertical gradients within the Ipswich River Watershed are small (0.0002 to 0.005 feet/feet) and varied,
indicating that the predominant flow component is lateral. Closer to Off-Property West Ditch Stream,
gradients are generally upward. Most wells within the upland portion of the Property typically exhibit
downward vertical gradients between shallow and deep overburden groundwater and generally exhibit
upward gradients within or bordering wetland areas. South Ditch Stream is predominantly a gaining
surface water body that receives shallow groundwater contributions.
Bedrock Groundwater
Bedrock groundwater elevation contours are like those of the overburden groundwater system, and
similarly impacted by the groundwater divide (see Figure 9 in Appendix C of this ROD). Bedrock
hydraulic conductivities measured at the Site range from 0.00032 to 1.3 feet/day, which is typical of New
England metamorphic rock. The K values for bedrock are considered a bulk K value representative of
both solid rock and fractures within the tested zone, and are several orders of magnitude lower than K
values measured in overburden wells. Horizontal gradients within the bedrock groundwater system arc
small and comparable to the deep overburden with values in the range of 0.000057 feet/feet in the Ipswich
River Watershed to 0.0033 feet/feet in the Abeijona River Watershed. Calculated bulk groundwater flow-
rates range from 0.1 feet/year in the Ipswich River Watershed to 8 feet/year in the Aberjona River
Watershed. Vertical gradients in bedrock arc generally small and comparable to those measured in the
overburden.
Pumping Impacts
The Town of Wilmington formerly operated five municipal wells, located in the aquifer underlying the
MMB wetlands approximately three quarters of a mile northwest of the Property in the Ipswich River
Watershed. The municipal wells operated at a rate of approximately 2.5 million gallons per day until they
were shut down in 2003. The former Altron/Sanmina facility, located close to the Property at 1 Jewel
Drive, used two wells for industrial purposes from 1992 to 2004. Pumping of the municipal and
Altron/Sanmina extraction wells may have influenced groundwater flow, resulting in contaminant
transport from the Abeijona River Watershed across the groundwater divide into the Ipswich River
Watershed.
Surface Water Hydrology
The Site contains both on- and off-Property surface water bodies (see Figures 1 and 2 in Appendix C of
this ROD). On-Property surface water includes a stream system of natural drainages that was modified in
the early 1950s, and a natural wetland drainage complex in the southern portion of the Property.
Additional surface water bodies include a stormwater detention basin and pond south of the Containment
Area. The on-Property stream system is connected to two off-Property streams (East and Off-Property
West Ditch Streams). These features are all part of the Aberjona River Watershed. Other surface water
bodies at the Site include MMB and Sawmill Brook (SMB) to the west. MMB and SMB arc located on
the other side of the groundwater/surface water divide, within the Ipswich River Watershed.
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Surface Water Features:
• On-Property West Ditch Stream begins along the northwest border of the Facility and drains to
South Ditch Stream. Sediments in much of On-Property West Ditch Stream and the associated
West Ditch Stream wetlands were remediated and relocated in 2000 and the portion beneath the
Containment Area was reconstructed as a concrete culvert in 2000, which changed the natural
course of the stream channel (MACTEC, 2007).
• The "Ephemeral Drainage" is a low-lying, intermittent surface water feature located just south of
and parallel to South Ditch Stream and represents the floodplain for South Ditch Stream. During
prolonged wet periods and following large precipitation events, flow may develop and join South
Ditch Stream in the vicinity of the eastern boundary of the Property.
• South Ditch Stream (on-Property) begins at the western Property boundary and receives surface
flow from Off-Property and On-Property West Ditch Streams. South Ditch Stream flows east
across the Property and discharges into East Ditch Stream. During high groundwater conditions,
constant base flow within South Ditch Stream indicates that it is a gaining stream that receives
groundwater flow. However, during drier periods, the middle of South Ditch Stream may go dry,
indicating that the water table falls below the stream bottom. South Ditch Stream has an annual
flow of approximately 1.6 million cubic feet per year.
• "Central Pond" is a shallow, 100-foot wide pond with high banks located north of South Ditch
Stream. The pond elevation of Central Pond matches the water table elevation.
• The "Detention Basin" is a shallow, 50-foot wide pond located north of South Ditch Stream that
receives drainage from the Containment Area cap. The Detention Basin was constructed as part
of the 2000 RAM to manage stormwater runoff from the Containment Area cap (GEI, 2000a).
The Detention Basin has an outlet control structure that controls the hydraulic gradient in that
area.
• Off-Property West Ditch Stream is a small, well defined drainage that includes channels
constructed to manage stormwater runoff at the time of the development of Jewel Drive. The
stormwater runoff channels are perpendicular to Jewel Drive at the boundaries of adjacent private
properties. A small culvert under Jewel Drive allows surface water from a small stormwater
sedimentation pond to be conveyed to the channel south of 8 Jewel Drive. Off-Property West
Ditch Stream passes under the Pan AM Railways railroad track in a stone culvert and becomes the
headwaters of South Ditch Stream. Off-Property West Ditch Stream is separated topographically
from the Property and does not receive stormwater runoff from the Property.
• East Ditch Stream lies within the railroad ditch east of the Property. This stream flows to the
southeast from the Eames Street overpass bridge, parallel to the MBTA railroad tracks and the
eastern Property boundary. East Ditch Stream receives stormwater runoff from abutting
developed properties and adjacent wetlands. South of the Property , East Ditch Stream enters and
exits a series of culverts eventually flowing into Halls Brook, which flows to the Halls Brook
Holding Area and eventually to the Aberjona River. East Ditch Stream is owned by or occupies
rights-of-way controlled by the MBTA and is regularly maintained to remove vegetation and
debris from ballast that lines the channel. Access to East Ditch Stream is restricted for public
safety reasons due to railroad operations.
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• MMB and SMB are located within the MMB wetlands complex, which is located approximately
2,000 feet west and north of the Property. These water bodies have not been shown to have been
impacted by the Site.10
• Landfill Brook is located to the south of the Property in Woburn and flows from west to east,
south of the WSL. This brook is approximately 2,600 feet long, ranges from 6-10 feet in width,
and varies from 6 inches-1 foot deep. Landfill Brook has not been shown to have been impacted
by the Site."
Surface water conforms to the groundwater watershed boundaries and flows. Portions of the surface
water bodies described above are located within 100- and 500-year floodplains (see Figure 5 in
Appendix C of this ROD for FEMA flood hazard areas).
2. Conceptual Site Model
The sources of contamination, release mechanisms, exposure pathways to receptors for groundwater,
surface water, soil, sediments, indoor air, as well as other site-specific factors, arc considered while
developing a Conceptual Site Model (CSM). The CSM illustrates contaminant sources, release
mechanisms, exposure pathways, migration routes, and potential human and ecological receptors. It
documents current and potential future site conditions and shows what is known about human and
environmental exposure through contaminant release and migration to potential receptors. The risk
assessment and response actions for all environmental media for the Site are based on this CSM.
The Site has been impacted by SVOCs from past releases (principally phthalates, phenols, and
nitrosamine compounds), VOCs (principally TMPs), and metals (principally chromium, sodium, and
calcium). In addition, the manufacturing processes included use of inorganic constituents including
chloride, sulfate, calcium, and ammonia.
Sections 4 and 5 of both the July 2015 Final OU1/OU2 RI Report and the June 2019 Draft Oil3 RI
Report, Sections 1.4 and 1.5 of the FS Report Volume I, and Section 1.5 of the FS Report Volume II
contain a more detailed discussion of the sources of contamination, nature and extent of contamination,
and contaminant fate and transport. The COCs include, but arc not limited to, the following:
• The DAPL source material is a highly acidic brine that is dark green in color with a specific
gravity greater than or equal to 1.025, with a pH typically around 3.5. DAPL contains chromium
and a high concentration of total dissolved solids. Several constituents are used to define DAPL
empirically in the absence of reliable specific gravity measurements. These constituents include
ammonia, chloride, magnesium, sodium, sulfate, and specific conductance. DAPL also contains
10 See AMEC, 2015a. Executive Summary (p. ES-14). Metals and VOCs detected in surface water samples from the
MMB wetland area are not associated with the Olin Site, and SVOC concentrations are consistent with background
concentrations.
11 See AMEC, 2015a. Section 4.3. The Calcium Sulfate Landfill (CSL), located northwest of the Woburn Sanity
Landfill (WSL), has no measurable impact on Landfill Brook's water quality when compared to that caused by the
WSL and other potential sources (including automotive businesses in proximity to the Landfill Brook headwaters
and the former Merrimac Chemical Company )
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low concentrations of other metals, TMPs, SVOCs (mostly phthalates), and NDMA, with
concentrations of up to 50,000 ng/L (see additional discussion of COCs, below).
• NDMA is the primary COC associated with DAPL, is the most mobile of the groundwater
contaminants, and is the primary COC that drives human health risks. There is no record of
NDMA being used at the Site. NDMA is an SVOC that is thought to have formed in-situ from
precursor chemicals including acetaldehyde, formaldehyde, and hydrazine. NDMA is present in
elevated concentrations in groundwater and in DAPL, at levels of over 20,000 ng/L.
• Ammonia is an inorganic compound, manufactured industrially and also produced naturally from
bacterial processes and the breakdown of organic matter. Ammonia is present in groundwater
and surface water at the Site.
• Metals naturally occur as minerals in soil and rock and arc often present in wastewaters from
industrial activities. Metals in environmental media may also be mobilized by industrial activities
or releases. Metals present in groundwater, soil, and sediments at the Site that contribute to
potential human health and/or ecological risks include arsenic, chromium, cobalt, iron, and
manganese, of which chromium is the most widespread.
• Polycyclic aromatic hydrocarbons (PAHs) are a group of over 100 different chemicals that arc
formed during the incomplete burning of coal, oil and gas, garbage, and other organic substances
like tobacco or charbroiled meat. Several PAHs, including benzo(a)pyrene, are present in soil
and surface water at the Site and contribute to potential human health risks.
• TMPs, which arc a type of VOC, were detected in soil in certain areas and in groundwater and
surface water at the Site. They are also a component of the LNAPL present at the Property.
VOCs are types of chemicals that can easily evaporate and are generally used in products such as
glues, paints, and solvents.
• BEHP is a phthalate chemical detected in on-Property soil and sediments and has been identified
as a component of the LNAPL present at the Property.
• The LNAPL is a mixture of process oil and other raw materials historically stored and used at the
Facility that contains various contaminants, including TMPs and BEHP. LNAPL is present in
soil and groundwater in the Plant B area in the northeastern portion of the Property.
Sources of Contamination
Sources of contamination are related to former manufacturing operations and waste disposal practices.
Groundwater impacts have been identified from former releases of TMP and processing oils at the former
Plant B production area and tank farm, as well as liquid waste disposal practices. The sources of surface
water impacts include impacts from groundwater containing COCs and historical impacts from waste
disposal practices that resulted in sediment contamination within the on-Property stream system. These
sources include specific areas of waste disposal and infrastructure at the Facility (see Figure 2 in
Appendix C of this ROD).
Many contaminant sources were investigated and addressed through response actions under the MCP.
These sources and other potential sources of contamination are identified below:
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• Former Lake Poly. East and West Pits, and the three Acid Pits: Each of these unlined pits
received liquid wastes during Facility operations between 1953 and approximately 1970. The
liquid wastes contained sulfuric acid, sodium chloride, sodium sulfate, ammonium chloride,
ammonium sulfate, chromium sulfate, and other constituents. Sodium dichromate was used in the
Kempore (azodicarbonamide) process and acidic wastes containing chromium were discharged
until 1967.
• Leaks from Lined Lagoons I and II and Emergency Lagoon: In approximately 1972, two lined
lagoons (Lagoons I and II) and an acid treatment and neutralization system were added to the
facility to replace the unlined Acid Pits and Lake Poly for the disposal of acidic wastewaters.
Significant disposal of wastes in the Containment Area through leaks in the Lined Lagoons and
disposal in the Emergency Lagoon likely occurred from 1972 until at least 1983, based on
hydrogeologic evaluations of the lagoons conducted in 1981 and 1982. In 1986, the sludge and
liners from the lagoons were excavated and disposed of in the CSL located in the southern portion
of the Property (USEPA, 2020a).
• Liquid Waste Disposal Practices: Management of liquid wastes on the Property resulted in the
formation of the DAPL pools, located within bedrock depressions. These pools include the Main
Street DAPL pool and the Upper DAPL pool, which is divided into an on-Property portion (the
Containment Area DAPL pool) and an off-Property portion (the Jewel Drive DAPL pool). The
Main Street DAPL pool is further to the northwest of the Containment Area and Jewel Drive
DAPL pools. A soil source for NDMA has not been identified.
• Manufacturing and Wastewater Treatment: Former manufacturing facilities include the
laboratory. Plant A, Plant B, Plants C-l, C-2, and C-3, and Plant D. A wastewater treatment plant
was installed in the early 1970s.
• TMPs: TMPs were released in the vicinity of the Plant B production area and TMP-containing
processing oils were released in the v icinity of the Plant B tank farm.
• Transformers: Five transformers were formerly located across the Facility. The transformers
were evaluated for potential releases of PCBs during the OU1/OU2 RI.
• Former Buried Debris Area: The Buried Debris Area included materials similar to those found in
Lake Poly and was partially excavated in 2000-2001.
• Former Drum Areas: Drum Areas A and B were located near the three Acid Pits and to the
southeast of the Buried Debris Area and were excavated in 2000.
• Calcium Sulfate Landfill: The CSL, which was created to receive sediments from settling ponds
on the Property, was capped in 1988. The CSL received a closure determination from MassDEP
on January 7, 2009, which included requirements for post closure monitoring plan (MassDEP
issued an approv al of a modification of the post closure monitoring plan on March 3, 2011).
• On-Propertv Stream System: The On-Property stream system, consisting of East, South, and On-
Property West Ditch Streams, was used for liquid waste disposal between 1953 until
approximately 1970.
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• Fuel Oil USTs: Former fuel oil USTs were located on the east side of the Facility, beside the
Broiler House.
• Subsurface Utilities/Septic Systems: Subsurface utilities and septic systems may have had leaks
or cracks that released discharges into the subsurface. On-site sewers may have transported
wastes from the Facility to septic leach fields.
Olin conducted a variety of response actions to date, including the following:
• Installation and operation of the groundwater recovery/treatment system at Plant B in 1981 to
address LNAPL and contaminated groundwater that poses a risk to East Ditch Stream;
• The installation of a temporary cap and slurry wall (the "Containment Area" feature) from 2000
to 2001 to address the on-Property portion of the Upper DAPL Pool, the three Acid Pits, and a
portion of the former drum disposal areas;
• Sediment and soil removal from Central Pond, On-Property West Ditch Stream, and South Ditch
Stream from 2000 to 2001;
• Soil removal at the former Lake Poly, the former drum disposal areas, and the former Buried
Debris Area from 2000 to 2004;
• SVE near the former Plant B production area from 2000 to 2005 to address a large area of TMP-
impactcd soils (extractable petroleum hydrocarbons/volatile petroleum hydrocarbons (EPH/VPH |
area); and
• A DAPL extraction pilot test at a well near Jewel Drive between 2012 and 2014 in order to assess
the feasibility of recovering DAPL from the subsurface. The pilot test ended in 2014, however,
the DAPL recovery system has been re-started multiple times (between 2015 and 2016, and in
2017 and continuing through the present). Approximately 20,000 gallons of DAPL were
recovered in 2020; the extraction system has recovered more than one million gallons of DAPL to
date since system start-up.
Nature and Extent of Contamination
The following sections present the nature and extent of contamination - subdivided by OU and media -
based on the following data sets:
• Historical data that arc representative of current Site conditions;
• OU1/OU2 RI data from 2009 to 2013;
• OU3 Rl data from 2010 to 2017; and
• Additional groundwater and soil data from 2019 sampling events.
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Background Samples
Soil samples for the OU1/OU2 RI were collected from six unimpacted locations in the approximately 20-
acre southern area that is restricted by a conservation restriction to characterize background conditions. A
site-specific background concentration (95% Upper Predictive Limit) was developed for
metals/inorganics and PAH compounds based on this data set.
Two background off-Property surface water/sediment locations (upstream of MMB and East Ditch
Stream)12 were sampled to create the background concentrations for surface water and sediment. No OU1
streams were sampled for background conditions since OU1 stream locations all have headwaters either
entirely within the Property or on adjacent property and do not have upstream conditions suitable as a
reference location.
QUI Soil
Parameters detected most frequently in soil samples include SVOCs (BEHP and other phthalates,
NDPhA, and higher molecular weight PAHs), metals and inorganics (chromium, calcium, sodium,
sulfate, chloride, and ammonia), many of which are naturally occurring, and oil constituents or fractions
(primarily CI 1-C22 aromatic hydrocarbons). In general, VOCs were not frequently detected. However,
TMPs, a type of VOC, were detected frequently in soil samples collected in the vicinity of the former
Plant B and the Plant B tank farm.
Site-related contaminants in soil were delineated at the perimeter and in the interior of the Property for
surface soil, shallow subsurface soil (1-10 ft bgs), and deep subsurface soil. Chemicals with maximum
concentrations that exceeded their corresponding EPA Industrial Regional Screening Levels (RSLs;
triggering comparison to background and/or evaluation of risks) include the following:
• Surface soil: BEHP, NDPhA, benzo(a)anthracene, benzo(a)pyrene, benzo(b)fluoranthene,
dibenz(a,h)anthracene, indeno( 1,2,3-cd)pyrene, Aroclor-1260, arsenic, and hexavalent chromium.
EPA Industrial RSLs were not available for several detected parameters including 3&4-
methylphenol, acenaphthylene, benzo(g,h,i)perylene, carbazole, dimethylphthalate, diphenyl
ether, phenanthrene, alpha chlordane, delta-BHC, endosulfan I, endosulfan II, endrin ketone,
calcium, magnesium, potassium, sodium, chloride, sulfate, and ammonia.
• Shallow subsurface soil: TMPs, BEHP, NDPhA, benzo(a)anthracenc, benzo(a)pyrcne,
benzo(b)fluoranthcne, indeno( 1,2,3-cd)pyrene, hydrazine, arsenic, hexavalent chromium, and
CI 1-C22 aromatic hydrocarbons. Industrial RSLs were not available for several detected
parameters, including 4-isopropyl toluene, sec-butylbenzene, 3&4-methylphenol, 4-chlorophenyl
phenyl ether, acenaphthylene, benzo(g,h,i)perylene, carbazole, diphenyl ether, phenanthrene,
calcium, magnesium, potassium, sodium, chloride, ammonia, and sulfate.
• Deep subsurface soil: TMPs, BEHP, arsenic, and hexavalent chromium. Industrial RSLs were
not available for several detected parameters including 4-isopropyl toluene, 4-bromophenyl
phenyl ether, 4-chlorophenyl phenyl ether, benzo(g.h,i)perylene, diphenyl ether,
diphenylmethanone, phenanthrene, calcium, magnesium, potassium, sodium, chloride, ammonia,
and sulfate.
12 See AM lie, 2015a. Figure 2.5-1. Background Surface Water and Sediment Sampling Locations. Remedial
Investigation Report - QU1 and OU2. Olin Chemical Superfund Site. Wilmington. Massachusetts.
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Elevated concentrations of the aforementioned constituents were identified in the vicinity of former
disposal and operations areas that have since been remediated. These areas include the area near former
Lake Poly and the adjacent former Drum Storage Area; the area east of and adjacent to the former Plant B
tank farm; and an area of TMPs in soil under the administrative building parking lot near the former Plant
B production area. The unremediated portion of lower South Ditch Stream both on the Property (OU1)
and just off the Property (OU2) also contain elevated concentrations of certain COCs (see Oil2 Soil,
below).
NDMA was not detected in any soil samples from OU1. The only primary COCs that were detected in
soil, and for which EPA Industrial RSLs (or equivalent risk-based values) are not available, are ammonia,
calcium, sulfate, sodium, and chloride.
Aroclor-1260 was detected in the area of a historical pole-mounted transformer formerly in the northwest
quadrant of the Property. Olin completed a process of staged collection and analysis of PCBs in soil to
determine the areal extent and depth of PCB contamination. The depth of detected concentrations ranged
from surface soil to 4 ft bgs.
Although arsenic was detected in most soil samples at concentrations above the corresponding Industrial
RSL (1.6 milligrams per kilogram [mg/kg]), most of the reported concentrations were less than the Site-
specific background value. Furthermore, concentrations that exceeded the Site-specific background value
were not located in a cluster or clusters. Information from the operational history of the Facility does not
indicate that arsenic was a raw material, waste product, or manufactured product at the Facility; therefore,
the July 2015 Final OU1/OU2 RlReport concluded that arsenic is not a COC.
While soil in the Containment Area has not been identified as RCRA hazardous waste, it is possible that
hazardous waste may be present. Historical disposal practices in this area suggest that unsaturated soil
within the Containment Area contains waste materials. Pre-RI soil samples were primarily collected from
the Containment Area between the surface and 10 feet bgs. During the OU 1/OU2 Rl, characterization of
Containment Area soil was limited to surface samples from beneath the temporary cap, which were
collected by cutting slits in the cap and using a hand-held spatula. Deeper samples were not collected at
that time to avoid potential damage to the temporary cap that may have resulted from the presence of the
drill rig. In 2019, twelve soil samples were collected at a variety of depths from the Containment Area to
determine if Containment Area soil meets the definition of characteristic hazardous waste (Wood, 2020a).
Each boring was drilled through overburden soil and advanced 5 feet into the top of bedrock. Analytical
results from the soil samples collected from these borings showed elevated concentrations of TMPs.
BEHP, and total chromium; none of the samples exceeded the criteria for RCRA hazardous waste
characteristics. However, the sampling data was limited and additional sampling would be necessary to
demonstrate the absence of non-hazardous wastes (i.e., solid wastes) within the Containment Area.
GUI Wetland Soil and Sediments
OU1 sediment samples were collected from South Ditch Stream, the On-Property West Ditch Stream
wetlands, the Detention Basin, and Central Pond.
The most frequently detected parameters in sediment from South Ditch Stream include BEHP, TMPs,
three cxtractable petroleum hydrocarbon (EPH) fractions, 3&4-methylphenol, formaldehyde, metals, and
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inorganics including: aluminum, chromium, iron (that has been associated with floe in South Ditch
Stream), as well as hexavalent chromium, sulfate, and ammonia.
On-Property West Ditch Stream wetland sediment samples had similarly detected constituents as South
Ditch Stream sediment samples, including chromium (and most other metals), BEHP, and TMPs (at low
frequency).
For the Detention Basin, detected analytes in sediment samples include TMPs, BEHP, phenols, NDPhA,
and one PAH, in addition to metals and inorganic constituents; detected analytes appear to be consistent
with potential impacts from groundwater.
For Central Pond, detected analytes in sediment samples include TMPs, phenols, and four PAHs, in
addition to metals and inorganic constituents.
Oil I Surface Water
OU1 surface water samples were collected from South Ditch Stream, the Detention Basin, and Central
Pond.
South Ditch Stream is a gaining stream with very limited headwaters. The most frequently detected
metals and inorganics include aluminum, barium, chloride, chromium, cobalt, copper, iron, magnesium,
manganese, nickel, sodium, potassium, calcium, sulfate, and ammonia. NDMA, NDPhA. NDPrA, and
low concentrations of several SVOCs, including BEHP, 2-nitrophenol, 4-nitrophenol, benzoic acid,
diphenyl ether, bromoform, and diphenylmethanone were also detected in South Ditch Stream surface
water samples. TMPs were detected frequently, but at trace concentrations.
Chromium and ammonia concentrations in South Ditch Stream surface water have declined substantially
over time, with some fluctuations observed that may be related to the changes in the pumping of the
Sanmina industrial water supply wells located across Jewel Drive (see Pumping Impacts in the
Hydrogeology section, above).
The Detention Basin likely receives seasonal groundwater flow depending on the water elevation in the
basin relative to surrounding groundwater elevations. Detected parameters in Detention Basin surface
water include metals and inorganics including aluminum, barium, chloride, chromium, hexavalent
chromium, copper, iron, lead, manganese, magnesium, sodium, vanadium, zinc, potassium, calcium,
chloride, sulfate, and ammonia, at relatively low concentrations. NDPrA was also detected.
Central Pond has no surface water inlet or outlet, and the surface water present is an expression of the
overburden groundwater table. The analytes detected in Central Pond are limited to metals and inorganics
including aluminum, barium, chloride, chromium, iron, lead, magnesium, manganese, sodium, nickel,
potassium, calcium, sulfate, and ammonia at concentrations lower than South Ditch Stream but higher
than the Detention Basin. NDMA was not detected.
OU2 Soil
OU2 soil samples were collected from the area located between the eastern boundary of the Property and
East Ditch Stream from locations north and south of South Ditch Stream. This low-lying area was
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investigated historically to delineate concentrations of chromium in soil. It was postulated that chromium
had been deposited (as floe and sediment particulates) on soil during historical flooding of South Ditch
Stream. OU2 soil samples were also collected from areas immediately to the west of the western
boundary of the Property (the PanAM Railways property).
The most frequently detected VOCs in OU2 soil samples collected from areas immediately to the east of
the Property along South Ditch Stream were acetone, methylene chloride, and toluene. Trimethyl-2-
pentene (TM-2-P) was detected in soil samples, with a detected concentration well below the calculated
Industrial RSL. Among SVOCs, BEHP and several high molecular weight PAHs, NDPrA, diphenyl
ether, and phenol were most frequently detected. Maximum concentrations of BEHP,
benzo(a)anthracene, benzo(a)pyrene, and NDPrA were greater than corresponding Industrial RSLs. The
maximum concentration of CI 1-C22 Aromatics was greater than the MassDEP MCP S-2 soil standard
(relevant for industrial/commercial land use). Among specialty compounds, formaldehyde was the most
frequently detected compound. In addition, maximum concentrations of arsenic and hexavalent
chromium in surface soil samples were also greater than corresponding Industrial RSLs. No specific
sources of arsenic in soils at OU1 have been identified. The large majority of arsenic concentrations are
consistent with background conditions, and arc considered background.
OU2 Wetland Soil and Sediments
Sediment samples were collected from Off-Property West Ditch Stream, East Ditch Stream, Landfill
Brook and the MMB wetlands (including MMB and SMB).
Off-Property West Ditch Stream sediment samples had detections of metals, SVOCs, and VOCs. Metals
detected included aluminum, calcium, chromium, copper, nickel, potassium, sodium, and vanadium.
VOCs detected included TMPs, 1,2,4-trichlorobenzene, and 2-butanone. SVOCs detected included
PAHs, BEHP, NDPhA, diphenyl ether, benzoic acid, and 4-chlorophenyl phenyl ether.
Very little natural sediment is currently present in East Ditch Stream. Metals and inorganic compounds
detected, where present, include aluminum, arsenic, barium, calcium, chromium, cobalt, copper,
hexavalent chromium, iron, lead, manganese, mercury, nickel, v anadium, zinc, and ammonia. VOCs
detected include TM-2-P, 2-butanone, acetone, 1,1,2-trichloro-1,2,2-trifluoroethane, and trichloroethene
(TCE). SVOCs detected include 2-methylnaphthalene, acenaphthylene, anthracene, benzo(a)anthracene,
benzo(a)pyrene, benzo(b)fluoranthene, bcnzo(g,h,i)perylenc, benzoic acid, benzo(k)fluoranthene, BEHP,
chrysene, dibenz(a,h)anthracene, dibenzofuran, diphenyl ether, fluoranthene, fluorene. indeno( 1,2,3-
cd)pyrene, naphthalene, phenanthrene, phenol, and pyrene.
Metals and inorganics were detected in all three sediment samples from Landfill Brook. VOCs detected
in sediment samples from Landfill Brook are associated with the WSL. SVOCs detected included several
chlorinated PAHs, BEHP, and NDPhA, of which BEHP and NDPhA arc associated with the WSL.
For the MMB wetlands, the concentrations and distribution of metals and other inorganics in MMB and
SMB sediment samples arc consistent with naturally occurring concentrations and are not indicativ e of
Site-related impacts.
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0112 Surface Water
Off-Property surface water sampling locations included Off-Property West Ditch Stream, East Ditch
Stream, Landfill Brook, and the MMB wetlands (including MMB and SMB).
For Off-Property West Ditch Stream, metals and inorganics detected in surface water include ammonia,
chromium, hexavalent chromium, calcium, sulfate, and chloride. NDMA was detected in five of six
surface water samples collected. Phenols and benzoic acid were also detected. Several PAH compounds
detected in surface water samples may be from deteriorated railroad ties.
For East Ditch Stream, Site-related inorganics and metals detected in surface water samples include
ammonia, chromium, hexavalent chromium, calcium, sulfate, and chloride. SVOCs including NDMA,
NDPrA, PAHs, BEHP, benzoic acid, and caprolactam were detected, as well as VOCs including TMPs.
NDMA-containing groundwater flows to South Ditch Stream. South Ditch Stream then flows into East
Ditch Stream, and NDMA subsequently attenuates as it flows southward towards the Halls Brook
Holding Area. NDMA detections in surface water are infrequent. Surface water samples collected in
East Ditch Stream immediately downstream from Plant B contained non-detectable and/or low
concentrations of NDMA, ammonia, TMPs, and BEHP.
Landfill Brook is an off-Property wetland/surface water body located south of the WSL. Landfill Brook
was investigated as part of the OU2 RI; the brook was found to be impacted by the WSL and, based on
the data collected, does not show impacts from the Site. Landfill Brook surface water samples contained
fuel-related compounds and 1,1-dichloroethane (1,1-DCA) at low concentrations. Neither NDMA,
NDPrA. or NDPhA were detected in surface water samples from Landfill Brook. An assessment of
hydrologic and geochemical conditions surrounding Landfill Brook is included in the July 2015 Final
OU1/OU2 RI Report, and concludes the surface water quality in Landfill Brook reflects its immediate
proximity to the WSL and adjacent commercial automotive businesses.
For the MMB wetlands (which include MMB and SMB), the concentrations of chromium, hexavalent
chromium, and calcium in surface water are consistent with background sample concentrations and do not
indicate Site-related impacts. MMB and SMB do not appear to be impacted by inorganic compounds or
VOCs associated with the Site. While there was one detection of NDMA in MMB surface water, the
NDMA detection was isolated and the concentration was significantly lower than the ecological screening
benchmark concentration.
0113 Groundwater
The COCs for groundwater include metals, VOCs, and SVOCs.
The primary risk contributors in groundwater related to the Site are NDMA, arsenic, chromium, cobalt,
iron, and manganese. The distribution of cobalt in deep overburden groundwater is similar to the
distribution of NDMA, which is discussed in more detail below. Iron, arsenic, and manganese have a
larger footprint in deep overburden groundwater than NDMA, while chromium has a smaller footprint.
Iron, manganese, and cobalt levels are elevated in DAPL and decrease two or more orders of magnitude
at shallower depths.
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While these metals are highest in DAPL and groundwater in the core of the portion of the plume located
within the Ipswich River watershed, they remain at or above RSLs (for Hazard Index [HI] = 1) in
groundwater downgradient of the DAPL pools. Based on the distribution of COCs in groundwater, the
highest COC concentrations are in the vicinity of the DAPL pools, and metals are co-located with
NDMA; therefore, NDMA is considered an indicator parameter for the purposes of the FS Report Volume
II.
The full extent of groundwater impacts continues to be investigated as part of the ongoing OU3 RI. Some
downgradient migration of NDMA has occurred in the deep overburden groundwater and bedrock
groundwater systems within the Ipswich River watershed since shut-down of the Town of Wilmington's
five municipal wells.
Arsenic concentrations are elevated in groundwater, likely the result of mobilization of naturally-
occurring arsenic bound to iron hydroxides in the aquifer matrix due to the presence of DAPL. The low
pH of DAPL further accentuates the dissolution of iron oxyhydroxide minerals present in the saturated
soil, thereby releasing sorbed arsenic. Arsenic is present at concentrations of up to 260 micrograms per
Liter (|ig/L), which exceeds the Maximum Contaminant Level (MCL) of 10 ng/L in several areas.
Within the Ipswich River watershed, the highest arsenic concentrations are associated with DAPL in the
Main Street DAPL pool and with groundwater at the Spinazola Trust landfill (see Part A, Site Name,
Location, and Brief Description, above). Elevated arsenic also occurs within groundwater in the portion
of the plume core in the Ipswich River watershed and in bedrock underlying that corresponding portion of
the WBV. Slightly downgradient of the portion of the plume in the Ipswich River watershed, arsenic
concentrations are below the MCL.
NDMA in groundwater is the defining contaminant. The extent of other COCs is generally contained
within and co-located with the boundaries of the observed extent of NDMA in overburden and bedrock
groundwater.
The highest NDMA concentrations (greater than 20,000 ng/L) are in deep overburden groundwater in the
vicinity of the Main Street DAPL pool. Overburden shallow groundwater and bedrock groundwater have
similar plume outlines that show increased lateral distribution of NDMA as well depths increase.
The NDMA plumes have primarily spread to the west/northwest of the Property into the Ipswich River
watershed, while the spread to the east/southeast into the Aberjona River watershed is undetermined. An
area of hot spot groundwater under the MMB wetlands in the deep overburden aquifer encompasses the
core of the overburden groundwater plume.
The core of the bedrock plume follows a similar geometry as the core of the overburden plume, extending
from the Main Street DAPL pool under the WBV beneath the MMB aquifer. DAPL migrated beyond the
Main Street DAPL pool along the WBV, but the degree of geologic faulting in the valley may have
precluded the formation of a DAPL pool under the MMB wetlands area. DAPL is observed in one well
in the MMB wetlands that is partially screened in bedrock. Hot spot groundwater is typically co-located
with the DAPL pools and is also present in bedrock underlying the core of the overburden groundwater
plume in the MMB aquifer.
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Chromium is present in deep overburden groundwater at concentrations of up to 1.2 milligrams per Liter
(mg/L) and in shallow overburden groundwater at concentrations of up to 0.021 mg/L. The primary
source of chromium in groundwater is DAPL, specifically, the three DAPL pools located in bedrock
depressions (the Containment Area DAPL pool on the Property, and the Jewel Drive and Main Street
DAPL pools located off the Property). There is flow of low concentration chromium-containing water
from overburden groundwater to South Ditch Stream.
Based on the data collected during the OU3 RI (two rounds of sampling performed in May 2010 and
September 2010) and the May 2019 comprehensive groundwater sampling effort, the extent of
groundwater impacts within the Aberjona River watershed has remained relatively consistent between the
three sampling events. Some downgradient migration of NDMA has occurred in the deep overburden
groundwater and bedrock groundwater systems within the Ipswich River watershed since shutdown of the
Town of Wilmington's municipal water supply wells. The extent of downgradient migration of the plume
will be evaluated more fully during the ongoing OU3 RI.
The terms "groundwater hot spots" or "hot spot groundwater" refer to groundwater containing a large
portion of the overall mass of contaminants relative to the overall plume. Groundwater hot spots are areas
of highly contaminated groundwater containing significantly elevated concentrations of NDMA and other
COCs as compared to downgradient groundwater. This layer of groundwater contamination is formed
under current hydrogeologic conditions primarily via the transfer of COCs from DAPL via chemical
diffusion. The DAPL material acts as an ongoing source; the constituents in DAPL arc water soluble and
continue to migrate from the DAPL pools located in bedrock depressions into the overlying groundwater,
acting as a continuing, uncontrolled source of contamination. COCs in groundwater hot spots may also
be migrating into bedrock. The presence of DAPL, groundwater hot spots, and LNAPL (which is
discussed further below) in the aquifer continue to cause continued downgradient mass transport. The
removal of groundwater hot spots would facilitate remediation of the entire plume by reducing the extent
and further migration of the plume, as groundwater hot spots contain significantly elevated concentrations
of NDMA and other COCs.
The core of the overburden groundwater plume is represented by the extent of hot spot groundwater in
deep overburden wells. Some downgradient migration of NDMA has occurred in the deep overburden
groundwater and bedrock groundwater systems since shutdown of the Town of Wilmington's municipal
wells. The plume core is represented by the region of hot spot groundwater surrounding and
downgradient of the DAPL pools and along the water course of South Ditch Stream.
OU3DAPL
DAPL has been identified in pools residing in bedrock depressions beneath the Property (the On-Property
or Containment Area DAPL pool), immediately west of the Property (the Off-Property or Jewel Drive
DAPL pool), and further to the west near Main Street (the Main Street DAPL pool). The extent of DAPL
in bedrock continues to be evaluated as part of the ongoing OU3 RI. The areal extent of the three DAPL
pools, as is currently understood, is shown on Figure 1 in Appendix C of this ROD.
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DAPL is a highly acidic brine that is dark green in color with a specific gravity greater than or equal to
1.025. DAPL is also defined by an empirically derived set of chemical concentrations in the absence of
specific gravity data:
• Ammonia concentration greater than 1,250 mg/L;
• Chloride concentration greater than 2,800 mg/L;
• Magnesium concentration greater than 270 mg/L;
• Sodium concentration greater than 1,700 mg/L;
• Sulfate concentration greater than 16,000 mg/L; or
• Specific conductance greater than 20,600 microohms per centimeter (fimhos/cm)
The major risk drivers for DAPL include NDMA, arsenic, hexavalent chromium, dibromochloromethanc,
and chloroform (cancer risk), and unsymmetrical dimethylhydrazine (UDMH), cobalt, manganese, and
iron (non-cancer risk). Among these, NDMA stands out as the largest risk contributor.
NDMA has not been identified as a raw material, a manufactured product, or a waste stream constituent
in any of the operational history documentation for the Facility. The generally accepted mechanisms for
NDMA formation occur at low pH via nitrosation, which involves the formation of nitrosyl cation or
similar nitrogen-containing species, during acidification of nitrite. The nitrosyl cation then reacts with an
amine, such as dimethylamine, to form NDMA.
The highest concentrations of NDMA have been detected in DAPL samples. Calculations of NDMA
mass within DAPL are based on the v olume of DAPL present; however, the v olume estimates for DAPL
vary due to the uncertainty of the bedrock geometry/topography and difficulty measuring the exact
elev ation of the DAPL pools. Based on the av ailable data, the range of NDMA mass estimates dev eloped
by EPA and Olin range from 996 to 4,747 grams (g).
Many of the discharged chemicals at the Property were denser than the surrounding groundwater, and
therefore sunk through the aquifer to the top of bedrock to form DAPL. From there, DAPL migrated via
gravity flow into lower depressions, independent of the overlying groundwater. DAPL may have also
migrated into the large fracture network beneath the MMB wetlands.
Although DAPL is no longer being formed, the pooled DAPL serves as a continuing source of
contamination as the DAPL contains constituents that arc water soluble and continue to migrate into
adjacent groundwater and possibly via vertical intrusion into bedrock fractures. NDMA, which is the
primary COC and the most toxic and mobile in the aquifer, is believ ed to have formed in-situ in the waste
liquid lagoons and/or within the aquifer as liquid wastes migrated downwards as DAPL.
OU3LNAPL
A spill in the northeast corner of the Property resulted in a release of LNAPL to East Ditch Stream that
abuts the Property to the east. To address this discharge. Plant B was converted into a groundwater
recovery and treatment system in 1981, tied to three extraction wells, and continues to operate today as an
IRA under the MCP. Operation of the extraction system prevents groundwater containing COCs from
impacting East Ditch Stream. Operation of the extraction system has also resulted in a large smear zone
of LNAPL in soil in this area.
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Currently, only three monitoring wells (GW-23, IW-11, and P5, located on the north side of Plant B; sec
Figure 10 in Appendix C of this ROD) regularly contain a significant amount of LNAPL, ranging from
non-detect to 0.3 feet. Residual LNAPL appears to be limited to an isolated area near the northeast corner
of the Plant B building. The LNAPL consists of a mixture of process oil and dissolved organic
contaminants, including BEHP, TMPs and NDPhA.
Contaminant Fate and Transport
NDMA does not readily undergo biological degradation under natural conditions, is highly soluble, has a
low organic carbon-water partition coefficient, and does not readily absorb to organic carbon or reactive
mineral surfaces in the aquifer. Its primary attenuation mechanisms in groundwater are diffusion,
advection, and dispersion.
NDMA is susceptible to oxidation by ultra-violet (UV) light at wavelengths found in natural sunlight.
The published half-life for NDMA in clear water is on the order of seven minutes; therefore, it will
degrade efficiently in surface water depending on the clarity of the water and its light-transmitting
properties.
TMPs arc highly volatile and have high Henry's Law constants, so TMPs present in subsurface soils
represent potential risks via the VI pathway. TMPs were sporadically detected in surface soils, and
concentrations arc highest in the capillary zone where they volatilize in the vadose zone and may migrate
as vapor in response to changes in atmospheric pressure gradients. TMPs are minimally soluble in water.
Elevated detections of TMPs were found in groundwater and in LNAPL in the area of the former Plant B
tank farm and in a small area west of the Containment Area. Leaching of residual TMPs from subsurface
soil to groundwater is a significant concern. The Plant B groundwater extraction and treatment system
was constructed to control migration of LNAPL to East Ditch Stream. The system is effective in doing
so, and there have been only sporadic, trace concentrations of TMPs detected in East Ditch Stream
surface water.
Chromium is present in soil primarily in the trivalent form. Trivalent chromium in soil is virtually
insoluble in water under typical environmental conditions (precipitation, ambient surface water, and
ambient groundwater). Therefore, trivalent chromium in soil is generally not of concern with respect to
leaching from soil on the banks of or in close proximity to nearby streams. Chromium has been identified
in soil samples from the Containment Area and Lake Poly, where the possibility of the metal leaching to
groundwater cannot be refuted with certainty.
In groundwater, the distribution of chromium attenuates rapidly downgradient from the DAPL pools due
to precipitation with sulfate and with aluminum hydroxides on ferric iron nucleation sites in the aquifer.
Downgradient from the core of the plume, chromium is below detection limits with few exceptions.
One cause of the elevated concentrations of chromium in sediments and streambank soil in South Ditch
Stream is the historical acidic liquid waste discharges to On-Property West Ditch Stream that flowed to
South Ditch Stream, where the chromium partitioned from the surface water to sediments and streambank
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soil during high water conditions. Another potential contributor to sediments and streambank soil
chromium is dissolved-phase chromium in DAPL and groundwater. Chromium in sediments and
streambank soil in South Ditch Stream are not believed to be mobile. The trivalent chromium is not
soluble and is therefore not leaching from either sediments or streambank soil into the channels.
DAPL is acidic and has high concentrations of chromium, sodium, calcium, potassium, sulfate, chloride,
and NDMA. These dissolved constituents (including chromium, which is more soluble at the low pH of
this groundwater) migrate from DAPL into the overlying groundwater and are carried with groundwater
as it migrates away from the DAPL pools.
Groundwater migrates from the DAPL areas toward South Ditch Stream, mixing with other groundwater
and resulting in gradual increases in pH. When the groundwater flows into South Ditch Stream and
mixes with the higher pH surface water of the stream, the surface water pH conditions favor flocculation
of chromium as well as aluminum and iron, and the substantial reduction in concentrations of dissolved
chromium, aluminum, and iron. Likewise, elevated concentrations of metals in groundwater migrating to
the northwest (toward the MMB wetlands) decrease as groundwater migrates to the northwest and away
from the core of the plume.
BEHP from on-Property operational releases impacted soil and sediments, including upland soil in the
area of Plant B and Lake Poly, and wetland soil and sediments in and around South Ditch Stream. BEHP
sorbs strongly to soil and organic sediments and has very low water solubility under typical
environmental conditions, which limits its potential to migrate in groundwater or surface water at
substantial concentrations or to leach to groundwater or surface water. Elevated concentrations of BEHP
in sediments and streambank soil in South Ditch Stream are primarily the result of historical acidic liquid
waste discharges to On-Property West Ditch Stream, which flowed to South Ditch Stream, where the
BEHP partitioned from the surface water to the sediments and streambank soil during high water
conditions. There is no evidence of any substantial input of BEHP to South Ditch Stream under current
conditions.
The principal source of ammonia in groundwater and therefore surface water is believed to be migration
from DAPL to groundwater. Other potential sources of ammonia present in surface water may include
leakage from the Containment Area13 and/or residual contamination in soil outside of the Containment
Area that leaches to groundwater.
Ammonia is soluble in water but is not stable in most env ironments. It is easily transformed to nitrate in
waters that contain oxygen and can be transformed to nitrogen gas in waters that arc low in oxygen. The
most important attenuation mechanism is likely to be sorption to organic substrates and dilution by
surface water downstream.
13 The Containment Area feature, which includes a concrete slurry wall that was installed in a trench excavated into
the top of weathered bedrock, was constructed in an attempt to contain the DAPL pool on the Property. EPA
believes the weathered bedrock underlying the Containment Area DAPL Pool is not competent. Given the
weathered nature of the bedrock surface and based on a preliminary review of hydraulic data collected from inside
and outside the Containment Area that indicates groundwater elevation changes that are regional and unabated by
the slurry wall, leakage through the bedrock/slurry wall interface appears possible, resulting in some degree of
communication between the interior of the Containment Area and the exterior environment.
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Cobalt remains elevated around the plume core within and immediately surrounding the hot spot
groundwater within the MMB aquifer in the WBV. Cobalt, like aluminum, appears to have been
solubilized from clay minerals within the aquifer matrix as the result of acidic conditions in DAPL and
groundwater within the WBV.
Manganese and iron have similar geochemical behaviors, though they have different valence states and
properties. Manganese becomes more soluble with decreasing pH, so in areas of low pH, manganese
concentrations increase. Iron changes from an insoluble (ferric) to a soluble (ferrous) form under
reducing conditions and lower pH. Thus, as pH declines to acidic conditions or when oxygen is
consumed and oxidation-reduction potential becomes negative, dissolved iron concentrations increase.
Metals complexed with ferric iron, notably arsenic, are released when iron is converted to ferrous iron.
Metals also partition to manganese hydroxides, and as manganese dissolves with decreasing pH, those
metals arc also released. Metals released in this manner will typically re-sorb or re-complex as
groundwater moves downgradient and geochemical conditions return to those of ambient groundwater.
Routes of Exposure and Potential Receptors
Human Health
Exposure occurs when humans or other living organisms eat, drink, breathe, or have direct skin contact
with a hazardous substance or waste material. Further, if there is no exposure to a hazardous substance,
there is no risk to human health. Based on existing or reasonably anticipated future land use at a site,
EPA develops different exposure scenarios to determine potential human health risks, appropriate cleanup
levels for contaminants, and potential remedial alternatives.
Environmental media evaluated for OU1 and OU2 include surface soil (and airborne dust), subsurface
soil (and airborne dust if excavated), outdoor air. indoor air, surface water, and sediments. Environmental
media evaluated for OU3 include groundwater and DAPL as drinking water. Additionally, shallow
groundwater was also evaluated for potential indoor air impacts through the VI pathway.
The potential human health routes of exposure for the Site (OU1, OU2, and OU3) include:
• Direct contact (incidental ingestion and dermal contact) with soil, surface water, and sediments;
• Inhalation of airborne soil dust;
• Potable use of groundwater (ingestion, dermal contact, and inhalation of vapors released from
groundwater);
• Non-potable use of groundwater (ingestion, dermal contact, and inhalation of vapors released
from groundwater);
• Inhalation of VOCs from shallow groundwater via the VI pathway; and
• Hypothetical potable use of DAPL (ingestion, dermal contact, and inhalation).
The potential human health receptors for soil, sediments, and surface water (OU1 and OU2) include:
• Current and future on-Propcrty outdoor workers;
• Future off-Property outdoor workers;
• Current and future on-Property trespassers;
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• Current and future off-Property trespassers;
• Future on-Property indoor workers;
• Future on-Property construction workers;
• Future off-Property construction workers; and
• Future on-Property residents.
The potential human health receptors for groundwater and DAPL (OU3) include:
• Current and future off-Property residents;
• Future on-Property residents;
• Current and future off-Property daycare employees and clients;
• Current and future off-Property commercial workers;
• Current and future on-Property commercial workers;
• Future off-Property construction workers; and
• Future on-Property construction workers.
A complete list of exposure pathways evaluated for each OU can be found in Table 1.2-1 for OU1 and
Table 1.2-2 for OU2 in the OU1/OU2 BHHRA (Appendix M of the July 2015 Final OU1/OU2 RIReport
[AMEC, 2015a I), and Table 1.2-1 for OU3 in the Draft OU3 BHHRA (Appendix K of the July 2019
Draft OU3 RI Report [Wood, 2019]).
Ecological
The BERA evaluated potential ecological exposure pathways for OU1 and OU2. No BERA was
performed for OU3 because it is assumed that the current surface water data (evaluated in OU1/OU2)
reflect potential influences from groundwater flowing into surface water.
Chemicals may move from environmental media to ecological receptors through several major biological
exposure mechanisms:
• Uptake of chemicals from soil or sediments through roots (plants);
• Ingestion of chemicals bound to soil (terrestrial invertebrates, birds, and mammals);
• Ingestion of chemicals bound to sediments (benthic invertebrates, amphibians, semi-aquatic birds,
and mammals);
• Ingestion of dissolved and particulate chemicals in surface water (aquatic invertebrates,
amphibians, semi-aquatic birds, and mammals);
• Ingestion of chemicals through consumption of contaminated plants (herbiv ores and omnivores);
and
• Ingestion of chemicals through consumption of contaminated prey (all predators).
Although inhalation and dermal absorption pathways are possibly complete for some receptors, these
pathways arc considered to be minor compared to dietary ingestion and are not ev aluated. A complete list
of exposure pathways evaluated can be found in Table 3.8-1 of the OU1/OU2 BERA, which is included
as Appendix N of the July 2015 Final OU1/OU2 RI Report (AMEC, 2015a).
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3. Principal Threat Waste
The NCP at 40 C.F.R. Section 300.430(a)(l)(iii) states that EPA expects to use "treatment to address the
principal threats posed by a site, wherever practicable" and "engineering controls, such as containment,
for waste that poses a relatively low long-term threat" to achieve protection of human health and the
environment. In general, principal threat wastes are those source materials considered to be highly toxic
or highly mobile that generally cannot be contained in a reliable manner or would pose significant risks to
human health or the environment should exposure occur. Low-level threat wastes are source materials
that generally can be reliably contained and that would present only a low risk in the event of exposure.
The concept of principal threat and low-level threat wastes is applied on a site-specific basis when
characterizing source material. Source material is defined as material that includes or contains hazardous
substances, pollutants, or contaminants that act as a reserv oir for migration of contamination to
groundwater, surface water, air, or acts as a source for direct exposure.
Although EPA has not established a threshold level of toxicity/risk for identifying a principal threat
waste, generally where toxicity and mobility of source material combine to pose a potential risk of 10 ' (1
in 1,000) or greater, the source material is considered to be a "principal threat waste." NDM A-containing
DA PL and groundwater hot spots pose an estimated cancer risk of 10 2 (1 in 100) and act as a continuing
source of contamination to groundwater, and thus arc considered principal threat wastes.
Table E-l prov ides a summary of the principal threat wastes addressed in this ROD.
Table E-l
Principal Threat Wastes
Contaminant
Action to be Taken
DAPL and Groundwater Hot
Spots
NDMA
DAPL and Groundwater
Extraction and Treatment
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 are generally considered to be low-level
threat wastes include non-mobile contaminated source material of low to moderate toxicity, surface soil
containing COCs that are relatively immobile in air or groundwater, low-leachability contaminants, or
low toxicity source material. Low-level threat wastes include soil impacted with chromium and BEHP.
These materials will be addressed by installing a permanent, low-permeability cover over the
Containment Area and installing soil and/or asphalt cover systems for contaminated upland soil.
F. CURRENT AND POTENTIAL FUTURE SITE AND RESOURCE USES
The Property and surrounding properties are used for various purposes. Predominant physical features
include streets, paved areas, commercial and industrial properties, residential properties, open space,
surface water, and wetland areas.
1. Land Uses
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The current and reasonably anticipated future land uses of the Site form the basis for the exposure
assumptions that are used for the risk assessment, are considered in the development of remedial
objectives and remedial alternatives, and are considered in the selection of the appropriate remedial
action.
The Property is currently zoned as industrial/commercial (General Industrial Zone). The Property is not
currently in use, except for activ ities to operate and maintain the Plant B groundwater recovery/treatment
system and the Jewel Drive DAPL extraction program. Industrial/commercial properties are located to
the immediate north of the Property and to the cast and west of the Property. Residential properties are
located along Main Street and Cook Avenue to the west of the Property, and along Earnes Street before it
intersects with Woburn Street.
Based on discussions with Town of Wilmington officials, the reasonably anticipated future use of the
Property is expected to remain industrial/commercial, with the exception of the southern 20 acres of the
Property that are currently restricted by a conserv ation restriction and will remain as such. Future
residential use is unlikely, and the remedy will include Institutional Controls to prohibit future residential
use. Future land use of the areas surrounding Property is expected to remain unchanged.
2. Groundwater/Surface Water Uses
OU3 spans the groundwater divide between the Aberjona and Ipswich River watersheds. Groundwater
movement and associated plume migration varies within each watershed based on differences in
hydrogeology and the locations of historical contaminant releases. Each watershed has different
characteristics based on land use and hydrogeology.
In 2003, the Town of Wilmington ceased use of their five municipal drinking water supply wells in the
MMB aquifer due to contamination from the Site. Olin and the other Respondents funded the
construction of a new pipeline to the MWRA system in 2008. However, groundwater at the Site
continues to be used for drinking water purposes. Site groundwater to the north and west of the Property
is classified as a public drinking water supply. There are 81 private wells (potable and irrigation) on file
with the Town of Wilmington within the Site (see Figure 11 in Appendix C of this ROD for the
currently established boundaries of the Site groundwater study area). Of these 81 wells, 38 are residential
drinking water wells, 40 arc irrigation wells, and three (3) wells are of unknown use. Twenty-eight (28)
of the 38 residential drinking water wells have been sampled at least once, and 20 are monitored on a
quarterly basis to confirm that levels of NDMA do not exceed the upper end of EPA's health-protective
cancer risk range of 0.47 ng/L to 47 ng/L (see also Section G, SUMMARY OF SITE RISKS, Section 1
- Human Health Risk Assessment, Risk Characterization, Future Potable Use of Groundwater and DAPL
in Part 2 of this ROD. below), which would result in unacceptable risk to human health based on cancer
health effects. NDMA detections in 18 of these wells fall within EPA's health-protective range, with
72% of samples (438 out of 608 samples) showing non-detectable levels of NDMA. Two of the 20 wells
have shown consistently higher levels of NDMA over time, with detections in one well ranging from 9.4
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to 24 ng/L and detections in the second well ranging from non-detectable to 56 ng/L.14 Olin has provided
bottled water to these two residences since 2010, and is in the process of working with the Town of
Wilmington to voluntarily extend a waterline to these two households. A third well had an NDMA
detection of 57 ng/L in 2017. but previous and subsequent sampling results for this well were all within
EPA's health-protective range.15
Consistent with EPA's 1996 Final Groundwater Use and Value Determination Guidance and EPA's
endorsement of the Commonwealth's Comprehensive State Groundwater Protection Program
(CSGWPP), MassDEP developed a Groundwater Use and Value Determination"' for the Site in
September 2010. The purpose of the Use and Value Determination was to identify whether the aquifer(s)
beneath the Site are of "high," "medium," or "low" value. The evaluation was performed in accordance
with criteria for groundwater classification promulgated in the MCP. A Current or Potential Drinking
Water Source Area (Zone II) for the five Wilmington municipal water supply wells in the MMB aquifer is
north of the groundwater divide between the Ipswich and Aberjona watersheds; therefore, MassDEP
classifies groundwater in this area as GW-1 (drinking water). Other groundwater designated GW-1
include areas within 500 feet of private water supply wells (including the private wells located on Cook
Avenue) and a Potential Drinking Water Source Area to the south. Other remaining areas were
considered as GW-2 (potential for VI to indoor air) and GW-3 (groundwater flowing to surface water).
Because a portion of the Site falls within a GW-1 designated area, MassDEP concluded that the Site area
aquifer is a "high use and value" aquifer. The selected remedy, which includes an interim action for
groundwater, will be followed by a final remedy for groundwater in the future.
G. SUMMARY OF SITE RISKS
Baseline Risk Assessments (BRAs) for OU1, OU2, and OU3 - consisting of a BHHRA and BERA -
were performed to estimate the probability and magnitude of potential adverse human health and
environmental effects from exposure to C'OCs, assuming no remedial actions were to be taken. These
provide the basis for taking remedial action and identify the contaminants and exposure pathways that
need to be addressed by the remedy.
The BHHRAs were conducted pursuant to EPA Risk Assessment Guidance for Superfund (RAGS) and
followed a four-step process including:
1. Hazard identification, which identified those hazardous substances which (given the specifics of
OU1, OU2, and OU3) were of significant concern;
2. Exposure assessments, which identified actual or potential exposure pathways, characterized the
potentially exposed populations, and determined the extent of possible exposure;
14 Prior to the 2017 sampling event which yielded an NDMA sampling result of 56 ng/L for one of the two
residences on bottled water, sampling data for this well between 2008 and 2016 ranged from non-detectable to 33
ng/L (20 sampling events). Subsequent to the 2017 NDMA result of 56 ng/L, six sampling events were conducted
between 2017 and June 2020. These sampling events yielded NDMA results ranging from 0.34 to 2.9 ng/L.
15 Prior to the 2017 sampling event for this well which yielded an NDMA sampling result of 57 ng/L, sampling data
for this well between 2015 and 2016 ranged from 1.2 to 8.1 ng/L (five sampling events). Subsequent to the 2017
NDMA result of 57 ng/L, three sampling events were conducted between 2018 and June 2020. These sampling
events yielded NDMA results ranging from 0.6 to 7.9 ng/L.
16 MassDEP, 2010a. Groundwater Use and Value Determination, Olin Chemical Superfund Site, September.
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3. Toxicity assessments, which considered the types and magnitude of adverse health effects
associated with exposure to hazardous substances; and
4. Risk characterizations and uncertainty analyses, 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 objective of the BERA was to characterize risk to ecological receptors that are assumed to be
potentially exposed to contaminants associated with historical operations at the Site, in the absence of any
additional remedial measures. The BERA was completed using a process consistent with the framework
for risk assessment described in Ecological Risk Assessment Guidance for Superfund: Process for
Designing and Conducting Ecological Risk Assessments (USEPA, 1997a). The BERA consists of a
problem formulation, exposure and effects assessment, risk characterization, and conclusions.
The complete OU1/OU2 BHHRA and OU1/OU2 BERA are included as Appendix M of the July 2015
Final OU1/OU2 RIReport. Updates to the 2015 BRAs arc presented in technical memoranda to address
PRGs and update OU 1/OU2 RI conclusions (USEPA, 2020a). The Draft OU3 BHHRA is included as
Appendix K to the June 2019 Draft OU3 RI Report. Updates to the OU3 RI arc presented in a technical
memorandum that updates the OU3 RI conclusions (USEPA, 2020b).
The August 27, 2019 Plant B Risk Calculations evaluated the potential human health and ecological risks
mitigated by the operations of Plant B (Nobis, 2019). The January 17, 2020 OU1/OU2 Residential
Human Health Risk Evaluation evaluated residential human health risks for OU1 and OU2 soil
(Bluestone, 2020). The May 15, 2020 Ecological Risk Calculations documented the basis for ecological
risk-based PRGs for soil, sediments, and surface water (Wood, 2020b). The May 21, 2020 Oil3 Human
Health Risk Calculations evaluated the risks associated with the potable use of private residential well
water (Olin, 2020c). The July 1, 2020 Risk Calculations document the basis for human health risk-based
PRGs for upland soil (including Containment Area soil) and surface water (Wood, 2020c).
1. Human Health Risk Assessment
Hazard Identification
QUI andOU2
Sixty-two (62) of the 64 chemicals detected at the Site were selected for evaluation in the BHHRA as
Contaminants of Potential Concern (COPCs) for surface soil, subsurface soil, surface water, and
sediments. The COPCs were selected based on toxicity, concentration, and mobility and persistence in
the environment. The COPCs are summarized in the July 2015 Final OU1/OU2 RI Report, Appendix M,
Tables 2.3-1 through 2.3-6 and, for the Containment Area, in Tables 1 through 3 of the Technical
Memorandum, Documentation of Preliminary Remediation Goals (PRGs) to Address Human Health
Risks in Dense Aqueous Phase Liquid (DAPL), Groundwater Hot Spots, Upland Soil (including
Containment Area Soil), and Surface Water at the Olin Chemical Superfund Site (Wood, 2020c), which
was not evaluated in the OU1/OU2 RI. Tables G-l through G-4 in Appendix B summarize the COPCs
for OU1 and OU2.
COPCs were selected based on the following risk-based selection criteria, which is consistent with the
EPA Region I Risk Update Number 3 (USEPA, 1995a):
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• Selected as a COPC in soil if the maximum detected concentration is greater than the EPA RSL
(adjusted) for industrial soils (USEPA, 2013a).
• Selected as a COPC in surface water if the maximum detected concentration is greater than the
National Recommended Water Quality Criteria (NRWQC) for consumption of organisms only
(USEPA, 2009d) or the EPA RSL (adjusted) for tap water (USEPA, 2013a).
• Selected as a COPC in sediments if the maximum detected concentration is greater than the EPA
RSL (adjusted) for industrial soils (USEPA, 2013a).
• Chemicals for which no screening value is available are retained as COPCs unless they are
essential nutrients.
QU3
Summaries of groundwater analytical results, including frequency of detection and cxccedances of MCLs,
arc presented in Table 4.3-1 of the June 2019 Draft OU3 RI Report. No media of concern have been
identified for current land and groundwater use scenarios (use of private wells for potable or non-potable
use and the Milibrook Country Day School, Inc. public water supply17).
The Draft OU3 BHHRA conducted a screening level evaluation for VI impacts associated with VOCs (in
particular TMPs). The VI evaluation used chemical data from shallow groundwater samples collected
during the RI phase (June 2019 Draft Oil3 RI Report, Appendix G, Table 2.1). The maximum
concentration of 16 chemicals exceeded corresponding Residential Vapor Intrusion Screening Levels
(VISLs): 2,4,4-trimethyl-l -pentene (TM-l-P), TM-2-P, benzene, biphenyl, C5-C8 aliphatics, C9-C12
aliphatics, C9-C10 aromatics, CI 1-C22 aromatics, decane, ethylbenzene, hydrazine, naphthalene,
NDMA, TCE, vinyl chloride, and m & p xylenes (June 2019 Draft OU3 RI Report, Appendix G, Table
2.3 and Table 2.4). Chlorinated VOCs and petroleum-related chemicals exceeded Residential VISLs off-
Property.
COPCs have been selected for each of the components of the groundwater system (overburden and
bedrock, Ipswich and Abcrjona Watersheds, private wells, town wells, Milibrook Country Day School
Inc. water supply, and for DAPL). The procedure used to select COPCs for the Draft OU3 BHHRA is
summarized as follows, and the risk-based selection criteria are consistent with EPA guidance (USEPA,
1989):
• Compound selected as a COPC in groundwater if the maximum detected concentration is greater
than the EPA Tapwater RSL with a target hazard quotient of 0.1 (USEPA, 2018b).
• Chemicals for which no risk-based screening value is available are selected as COPCs.
A list summarizing the selected COPCs by medium and exposure scenario for groundwater can be found
in the June 2019 Draft OU3 RI Report, Appendix K, Table 2.3-9.
Exposure Assessment
17 Milibrook Country Day School Inc. Water Supply is registered in the Commonwealth of Massachusetts as a
transient non-community public water supply system. This school is located approximately 1 mile to the west of the
Site in the Ipswich River watershed. Despite being a public water supply, this facility has been sampled during the
quarterly residential well monitoring program.
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QUI and 0U2
Exposures to COPCs were estimated quantitatively or qualitatively through the development of several
exposure scenarios. Exposure scenarios were developed considering the nature and extent of
contamination, the location of the Exposure Area (EA), current and future potential use of the EA, and
identification of potential receptors and exposure pathways.
The EAs for OU1 include EA-1, EA-2, EA-3, EA-4, EA-6, EA-7, the Containment Area, South Ditch
Stream, On-Property West Ditch Stream, the Stormwater Detention Basin, and Central Pond (see Figure
12 in Appendix C of this ROD for human health EAs). The EAs for OU2 include EA-5, Off-Property
West Ditch Stream, East Ditch Stream, the MMB wetlands, and North Pond. Landfill Brook is not
impacted by COCs released from OU1; therefore. Landfill Brook was evaluated only through the COPC
selection step of the OU1/OU2 BHHRA.
The exposure media evaluated quantitatively in the OU1/OU2 BHHRA include surface and subsurface
soil, surface water, and sediments. The selection of exposure pathways is summarized in Tables 1.2-1
and 1.2-2 of the OU1/OU2 BHHRA. Based on the current and assumed future land uses for the EAs,
receptors evaluated include the following:
• Current Land Use - OU1/OU2
o Outdoor worker - surface soil at EA-1, EA-2, EA-3, EA-5, EA-6, and EA-7; and
o Trespasser - surface soil, surface water, and sediments at EA-1, EA-2, EA-3, EA-4, EA-5,
EA-6, and EA-7; South Ditch Stream; Central Pond and the Stormwater Detention Basin; On-
Property West Ditch Stream; Off-Property West Ditch Stream; East Ditch Stream; the MMB
Wetlands; and North Pond.
• Future Land Use - OU1/OU2
o Indoor worker - surface soil and subsurface soil at EA-1, EA-3, and EA-7;
o Outdoor worker - surface and subsurface soil at EA-1, EA-2, EA-3, EA-5, EA-6, EA-7, and
the Containment Area;
o Construction worker - surface and subsurface soil at EA-1, EA-2, EA-3, EA-5, EA-6, and
EA-7; and
o Trespasser - surface soil, subsurface soil, surface water, and sediments at EA-1, EA-2, EA-3,
EA-4, EA-5, EA-6, EA-7, and the Containment Area; South Ditch Stream; Central Pond and
the Stormwater Detention Basin; On-Property West Ditch Stream; Off-Property West Ditch
Stream; East Ditch Stream; MMB; and North Pond.
OU3
The following current exposure scenarios were evaluated in the Draft OU3 BHHRA {June 2019Draft
Of 13 RIReport, Appendix K):
• Sixteen residential wells within the extent of NDM A groundwater impacts;
• Millbrook Country Day School, Inc. public water supply; and
• One residential well used for non-potable purposes (irrigation);
The following future exposure scenarios were evaluated in the Draft OU3 BHHRA:
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• Future irrigation use of groundwater;
• Future construction worker exposure to shallow groundwater (on-Property and off-Property);
• Future resident potable use of groundwater (including Ipswich River watershed overburden and
bedrock aquifers, and Aberjona River watershed overburden and bedrock aquifers); and
• Future resident - DAPL as a medium of concern for potable use.
Toxicity Assessment
Carcinogenic Effects
EPA has assigned each contaminant a "weight-of-evidence" category that represents the likelihood of the
contaminant being a human carcinogen. Additionally, the cancer potency estimate is a quantitative
measure of a compound's ability to cause cancer and is generally expressed as either a cancer slope factor
(CSF) or an Inhalation Unit Risk (IUR) value.
CSF and IUR values are toxicity estimates developed by EPA based on epidemiological and/or animal
studies, and they reflect a conservative "upper bound" estimate of the potency of the carcinogenic
compound. That is, the true potency is unlikely to be greater than the potency described by EPA. The
July 2015 Final OU1/OU2 RIReport, Appendix M Tables 4.1-1 and 4.1-2 and the June 2019 Draft OU3
RIReport, Appendix K Tables 4.1-1 and 4.1-2 present the cancer toxicity values and cancer
classifications for the COCs used in the BHHRAs. Tables G-5 and G-6 in Appendix B provide cancer
and non-cancer toxicity data summaries. EPA's Cancer Guidelines and Supplemental Guidance (USEPA,
2005a and USEPA, 2005b) have been used as the basis for analysis of carcinogenicity risk assessment.
On January 19, 2017, EPA issued revised cancer toxicity values (less carcinogenic) and new non-cancer
toxicity values for benzo(a)pyrene. The cancer potency of other carcinogenic PAHs is adjusted by the use
of Relative Potency Factors (RPFs), which are expressed relative to the potency of benzo(a)pyrene. The
non-cancer effects of benzo(a)pyrene were not evaluated in the past due to the absence of non-cancer
values. The revised toxicity values for benzo(a)pyrene were used to develop PRGs for Off-Property West
Ditch Stream.
Non-Carcinogenic Effects and Non-Linear Carcinogenic Effects
For addressing non-carcinogenic effects and effects of carcinogenic compounds that exhibit a threshold, it
is EPA's policy to assume that an exposure level exists which is unlikely to result in adverse health
effects. This threshold exposure level is described by the reference dose (RfD) or reference concentration
(RfC). RfDs and RfCs have been developed by EPA as estimates of a daily exposure that is likely to be
without an appreciable risk of an adverse health effect when exposure occurs over the duration of a
lifetime. RfDs and RfCs arc derived from epidemiological and/or animal studies and incorporate
uncertainty factors to help ensure that adverse health effects will not occur. The RfDs and RfCs used in
the BHHRAs are presented in the July 2015 Final OU1/OU2 RI Report, Appendix M Tables 4.2-1 and
4.2-2 and June 2019 Draft OU3 RI Report, Appendix K Tables 4.2-1 and 4.2-2.
The November 2019 RSL Table for Industrial Soil (USEPA, 2019) lists an oral non-cancer RfD of 0.01
milligrams per kilogram per day (mg/kg/day) for 2,4,4-TMP (CAS# 25167-70-8) but the RSL tables do
not list an Inhalation RfC for TMPs. This suggests that sufficient, definitive inhalation toxicity
information is not available for deriving an air concentration that would be without appreciable risk of
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adverse effects for long-term exposure. Instead, route-to-route extrapolation was employed to estimate a
concentration analogous to an Inhalation RfC. The underlying assumption of the approach is that a "safe"
dose for oral exposure, expressed as mg/kg/day, can be assumed to be a "safe" dose for inhalation
exposure. Using this approach, an air concentration was calculated using standard inhalation exposure
assumptions and bodyweights that would yield a dose equal to the Oral RfD (Wood, 2020c).
Risk Characterization
The risk characterization combines the exposure estimate with the toxicity information to estimate the
probability or potential that adverse health effects may occur if no action were to be taken at a site.
Cancer risks are generally expressed as a probability whereas the potential for adverse non-cancer effects
are described in relation to a threshold dose, below which adverse health effects would not be expected to
occur.
Potential cancer risk was calculated by multiplying the estimated lifetime average daily dose (LADD) that
is calculated for a COPC through an exposure route by the CSF or IUR. The LADD is expressed as
intake averaged over a 70-year lifetime as mg-COPC/kg-body weight per day. Typically, cancer 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). EPA
generally views site-related cancer risks in excess of 10^ as unacceptable. Current EPA practice
considers carcinogenic risks to be additive when assessing exposure to a mixture of hazardous substances.
The 2005 Children's Supplemental Cancer Risk Guidelines were used to describe heightened
susceptibility among potentially exposed children where applicable (USEPA, 2005b).
To estimate the potential for adverse non-carcinogenic effects (and carcinogenic effects resulting from
non-linear Mode of Action [MOA] compounds), a hazard quotient (HQ) is calculated, which is the ratio
of the estimated daily intake (averaged over exposure duration) for a given exposure route to the
appropriate reference value (RfD or RfC) for each compound. An HQ < 1 indicates that a receptor's
exposure to a single contaminant is unlikely to result in adverse non-carcinogenic effects. Conversely, an
HQ > 1 indicates that adverse effects as a result of exposure to the contaminant arc possible.
To account for additive effects resulting from exposure to more than one compound, an HI is generated
by adding the HQs for all COPCs that affect the same organ or system (e.g., liver or nervous system). An
HI < 1 indicates that adverse effects arc unlikely whereas an HI > 1 indicates adverse effects are possible.
Generally, EPA views site-related non-canccr risks as unacceptable if HI > 1. It should be noted that the
magnitude of the HQ or HI is not proportional to the likelihood that an adverse effect will be observed.
The following is a summary of the media and exposure pathways that were found to present a significant
risk exceeding EPA's cancer risk range and non-cancer threshold at the Site. Only those exposure
pathways deemed relevant to the remedy being proposed are presented in this ROD. The remedy for
groundwater is an interim action to begin restoration of groundwater and to prevent unacceptable human
health risks from exposure to Site groundwater while gathering additional information to select a final
cleanup plan for groundwater in the future. Readers are referred to Appendix M, Section 5.2, and
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Attachments 11 and 12 of the July 2015 Final OU1/OU2 RI Report and Appendix K of the June 2019
Draft Ol/3 RI Report for a more comprehensive risk summary of all exposure pathways evaluated for all
COPCs, and for estimates of central tendency risk for OU1 and OU2. Table G-7 through Table G-16
present the risk characterization summaries for OU1/OU2 and Table G-17 through Table G-28 present
the risk characterization summaries for OU3 for all receptors with carcinogenic risks greater than 10"6 or
non-carcinogenic Hi greater than 1.
Current/Future Trespasser. Off-Property West Ditch Stream - Surface Water
Tables G-10 and G-ll in Appendix B of this ROD depict the carcinogenic risk and non-cancer hazard
summaries for the current/future trespasser. COCs in surface water were evaluated to reflect potential
current and future adult and adolescent trespasser ingestion and dermal exposure corresponding to the
RME scenario. For the current and future adolescent trespasser, carcinogenic risks exceeded the EPA
acceptable risk range of 10"6 to 10~4. The largest contributor to cancer risk is dermal exposure to surface
water for benzo(a)pyrene (8 x 10 s for the adult trespasser and 2 x 1()~4 for the adolescent trespasser).
Current/Future Potable Use of Groundwater and DAPL
Calculated risks for potential current and future exposure scenarios exceed the EPA cancer risk range and
the calculated non-canccr Hi limit of 1 for the following:
• Three of the current private residential wells had calculated risks at or above 1 x 104. The risks
are primarily attributable to hexavalent chromium The June 2019 Draft OH3 RI Report indicates
that hexavalent chromium detections likely represent anomalous results18. Without including the
risk attributable to hexavalent chromium, all risk results for private potable wells are within the
CERCLA risk range.1''
• Future potable use of groundwater from the Ipswich River watershed overburden aquifer resulted
in risks above the EPA acceptable cancer risk range (10~6 to 10 4) and non-cancer Hi limit of 1.
The predominant cancer risk contributors are NDMA (2 x 10 7 and 86% of the total), vinyl
chloride (2 x 1 0' and 11% of the total), and arsenic (5 x 10 4 and 2.6% of the total ). The
predominant HI contributors (HI>1) arc NDMA (49), manganese (46), cobalt (17), TCE (17),
diphenyl ether (4.9), arsenic (4.4), iron (3.3), cis-1,2-dichloroethene (3.2), antimony (1.9), and
vinyl chloride (1.4).
• Future potable use of groundwater from the Ipswich River watershed bedrock aquifer resulted in
risks above the EPA acceptable cancer risk range (10~6 to 10~4) and non-canccr HI limit of 1. The
predominant cancer risk contributors are NDMA (3 x 10 2 and 98.66% of the total) and TCE (2 x
18 The June 2019 Draft OU3 RI Report concluded that groundwater conditions are not favorable for the presence of
hexavalent chromium, but rather are favorable to the presence of trivalent chromium. Hexavalent chromium can be
a predominant form (high reduction potential) when pi I is high (9-12); however, the pi I of DAPL is typically around
3.5. Therefore, hexavalent chromium is not expected to be stable in the geochemical environment of DAPL, hot
spot groundwater, or other groundwater at the Site.
19 See June 2019 Draft OU3 RI Report. Appendix K. Revised Draft Baseline Human Health Risk Assessment,
Operable Unit 3. Table 5.2-1. Summary of Potential Carcinogenic Risk and Hazard Index: Baseline Scenario.
Baseline Human Health Risk Assessment, Olin OH3, Wilmington, MA.
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10"4 and 0.48% of the total). The predominant HI contributors (HIM) are NDMA (100), cobalt
(85), manganese (67), TCE (23), diphenyl ether (7.7), iron (3.1), and antimony (1.5).
• Future potable use of groundwater from the Aberjona River watershed overburden aquifer
resulted in risks above the EPA acceptable cancer risk range (10~6 to 10"4) and non-cancer HI limit
of 1. The predominant cancer risk contributors arc hydrazine (1 x 10 2 and 56% of the total ),
NDMA (8 x 103 and 41% of the total), and arsenic (5 x 10 4 and 2.7% of the total). The
predominant HI contributors (HI> 1) are hydrazine (33), diphenyl ether (24), UDMH (22), NDMA
(13), cobalt (9.5), manganese (4.9), TMPs (4.8), arsenic (2.6), thallium (2.3), biphenyl (2.0), 4-
chlorophenyl phenyl ether (2.0), and 4-bromophenyl phenyl ether (1.7).
• Future potable use of groundw ater from the Ipswich River watershed bedrock aquifer resulted in
risks above the EPA acceptable cancer risk range (10~6 to 10 4) and non-canccr HI limit of 1. The
predominant cancer risk contributors are NDMA (7 x 10 3 and 94% of the total) and arsenic (2 x
10"4 and 2.7% of the total). The predominant HI contributors (HI>1) arc cobalt (130), manganese
(51), NDMA (21), iron (19), thallium (6.5), aluminum (6.0), silver (5.2), zinc (4.2), nickel (2.1),
diphenyl ether (2.0), TMPs (2.0), and arsenic (1.7).
• Future potable use of DAPL resulted in risks above the EPA acceptable cancer risk range (10~6 to
10 4) and the non-canccr HI limit of 1. The predominant cancer risk contributors are NDMA (3 x
10"2 and 83.75% of the total), arsenic (3 x 10"3 and 9.99% of the total), hexavalent chromium (1 x
103 and 2.88%) of the total), dibromochloromethane (4 x 10~4 and 1.17% of the total), and
chloroform (3 x 10 4 and 0.86% of the total). The predominant HI contributors are UDMH (1,952
adult, 1,195 child), cobalt (955), manganese (391), iron (236), chromium (110), silver (109),
aluminum (95), NDMA (83), tin (73), arsenic (29), thallium (29), TCE (16), nickel (12), diphenyl
ether (8.8), cadmium (7.2), copper (5.9), beryllium (4.1), biphenyl (3.1), vanadium (2.9), and zinc
(1.5).
On-Property Construction Worker
Calculated risks for potential future exposure scenarios exceed the calculated non-canccr HI limit of 1 for
the following:
• The Construction Worker Plant B His are above 1 and are predominantly driven by groundwater
concentrations of diphenyl ether (HI = 9.6), TMPs (HI = 3.1), biphenyl (HI= 1.6), and
naphthalene (HI= 1.5).
• The on-Property Construction Worker (remainder of the Property) HI (10 for both surface and
subsurface soil) is above 1 and is predominantly driven by UDMH (HI=6) and hydrazine (HI =
2.3).
Uncertainties
Numerous raw materials, components of liquid waste streams, and products of the Facility do not have
commercially available and EPA-approved analytical methods. Because there are not analytical methods
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for these specific compounds, environmental media were analyzed for components of these compounds as
per RI procedures and protocols.
Certain contaminants selected as COPCs have no readily available toxicity values from Tier I, II, or III
data sources (US EPA, 2003b). As identified in Table 5.3-1 of the July 2015 OU1/OU2 RI Report, these
COPCs include ammonia, sulfate, bromide (detected in surface water only), chloride, nitrate, lead (COPC
in surface water only), Kempore or azodicarbonamide (detected in surface water only), urea, nonylphenol
(detected in surface water only), diphenylether, dimethylphthalate, delta-hexachlorocyclohexane (delta-
BHC), 4-isopropyltoluene, 4-chlorophenyl phenyl ether, 2-nitrophenol, 3 & 4 methylphenol, 4-
nitrophenol, and diphenylmethanone (detected in surface water and sediment only).
Other compounds without toxicity values that were detected but not selected as COPCs because they are
essential nutrients include calcium, magnesium, potassium, and sodium. Since the lack of toxicity values
prevents calculation of risks, the OU1/OU2 BHHRA and Draft OU3 BHHRA may underestimate risk.
A ratio was used to estimate hexavalent chromium concentrations at EAs with less than three measured
hexavalent chromium samples. The total chromium concentration was used with an OU1 and OU2
media-specific ratio to estimate hexavalent chromium concentrations. Hexavalent chromium was
reported to be present in some groundwater samples collected for OU3. However, the June 2019 Draft
Oil3 RI Report concluded that groundwater conditions are not favorable for the presence of hexavalent
chromium and that the hexavalent chromium detections in groundwater samples represent false positive
results. Nevertheless, the Draft OU3 BHHRA uses a conservative approach and evaluated hexavalent
chromium as it was reported to be detected in the samples.
The screening evaluation of a future VI pathway (future scenarios that cannot be measured under current
conditions), which compared VOC concentrations in groundwater to the appropriate VISLs, has indicated
that there may be potential for a VI pathway. However, the screening evaluation provides a qualitative
evaluation only and does not indicate whether potential risks from VI are acceptable.
The OU1/OU2 BHHRA identified that TMPs in soil and LNAPL could potentially result in unacceptable
VI risks to indoor workers and building occupants in a future scenario if commercial/industrial-type
buildings were to be constructed and occupied on the Property. However, VI risks were only qualitatively
evaluated because currently there are no occupied buildings on the Property.
2. Ecological Risk Assessment
01 in developed the OU1/OU2 BERA as part of the July 2015 Final OU1/OU2 RI Report. The 0U1/0U2
BERA evaluated soil and on-Property surface water and sediments (OU1) including the former Facility
area, the 20-acre southern portion of the Property restricted by a conservation restriction, the on-Property
stream system, the CSL, and the Containment Area, and off-Property surface water and sediments
including off-Property portions of the East Ditch Stream, South Ditch Stream, and West Ditch Stream
(see Figure 13 in Appendix C of this ROD for ecological EAs). The OU1/OU2 BERA also addressed
Landfill Brook, North Pond, and the MMB wetlands which includes MMB, SMB, and surrounding areas.
The August 27, 2019 Plant B Risk Calculations evaluated the ecological risks mitigated by the operations
of Plant B. The May 15, 2020 Ecological Risk Calculations documented the basis for ecological risk-
based PRGs for soil, sediments, and surface water. The OU1/OU2 BERA, as well as the August 27, 2019
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Plant B Risk Calculations and May 15, 2020 Ecological Risk Calculations, were developed in accordance
with EPA ecological risk assessment guidance (USEPA, 1997a).
Identification of Chemicals of Potential Concern
Available data were selected for use in the OU1/OU2 BERA using the criteria established by EPA in
"Guidance for Data Usability in Risk Assessment" (USEPA, 2002). Sample collection and handling,
laboratory analyses, and data Quality Assurance/Quality Control (QA/QC) procedures were performed in
accordance with EPA methods, as described in the project Quality Assurance Project Plan (QAPP).
Samples used in the OU1/OU2 BERA include the following:
• Soil samples from 0-1 ft bgs collected during the OU1/OU2 RI;
• Historical soil samples from 0-2 ft bgs collected from 1991-2012;
• Surface water samples collected from 2009 to 2013; and
• Sediment samples collected from 0-6 inches from 2000 to 2013.
As per EPA guidance, ecological screening benchmarks for chemicals detected in surface water,
sediments, and soil were obtained from published regulatory sources and peer-reviewed scientific
literature using a multi-tiered hierarchy. Contaminants of Potential Ecological Concern (COPECs) were
selected by comparing maximum detected concentrations to screening benchmarks by EA and media.
Constituents with maximum concentrations above their corresponding screening benchmarks were
identified as COPECs. Depending on EA and medium. COPECs identified for further evaluation
consisted of VOCs, SVOCs (including PAHs), EPH, pesticides, metals, other inorganics, and
miscellaneous specialty compounds (e.g., hydrazine). Tables G-Ecol through G-Eco3 in Appendix B of
this ROD provide a summary of COPECs for surface water, sediments, and soil, respectively.
Exposure Assessment
Habitat Description
The northern portion of the Property and properties to the east, north, and west are heavily developed and
industrial. The southern portion of the Property is forested except for the area of the CSL. This southern
portion is south of South Ditch Stream and is preserved in a predominantly natural, undeveloped
condition by a conservation restriction (Environmental and Open Space Restriction, recorded with the
Middlesex North Registry of Deeds on November 7, 2006, Book 20680, Page 234).
Surface water bodies and associated habitats on or potentially impacted by the Property include the
drainage systems and ponds located on-Property (including On-Property West Ditch Stream, South Ditch
Stream, the Ephemeral Drainage, Central Pond, and the Storm Water Detention Basin), adjacent to the
Property (Off-Property West Ditch Stream and East Ditch Stream), to the southeast (Off-Property South
Ditch Stream, Landfill Brook, and North Pond) and to the northwest (MMB and SMB). The MMB
wetlands are a 750-acre wetland complex located west of Main Street and bordered by primarily
residential properties.
Landfill Brook is included in the OU1/OU2 BERA through COPEC selection only as the RI nature and
extent evaluation determined that Landfill Brook is not impacted by the Site.
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Complete Exposure Pathways
The OU1/OU2 BERA evaluated risk to ecological receptors from exposure to COPECs by:
• Comparing concentrations in environmental media to effects benchmarks and reference
concentrations;
• Sediment toxicity tests (Lower South Ditch Stream only); and
• Food chain modeling and Toxicity Reference Value (TRV)-based risk calculations.
Table G-Eco4 in Appendix B of this ROD presents the exposure pathways and receptors evaluated by
EA.
EPCs
The OU1/OU2 BERA evaluated risk to ecological receptors using RME and Central Tendency Exposure
(CTE) EPCs. The RME EPC provides an upper estimate of exposure concentrations. In accordance with
EPA guidance (USEPA, 2002), RME EPCs used in the OU1/OU2 BERA are based on the lesser of the
95% upper confidence limit (UCL) on the arithmetic mean concentration and the maximum detected
concentration.
The CTE represents the concentration to which a population of receptors would most likely be exposed
across an EA and over time. CTE EPCs are average (arithmetic mean) concentrations calculated using
half the sample quantitation limit for non-detects. If the average concentration of a COP EC in an EA is
greater than the maximum concentration, as occurs where the frequency and magnitude of detections is
minimal, the lower of the maximum or RME EPC was used as the CTE EPC.
Ecological Effects Assessment
An HQ approach was used to compare exposure concentrations to benchmarks or TRVs. The HQ
approach simplifies the comparison process and allows for a more standardized interpretation of the
results (i.e., the HQ reflects the magnitude by which the sample concentration exceeds or is less than the
guideline, benchmark, or TRV). In general, if an HQ exceeds 1, some potential for risk is expected
(USEPA, 1993). Although the quotient method does not measure risk in terms of likelihood of effects at
the individual or population level, it does provide a functional benchmark for judging potential risk
(USEPA, 1994).
Benchmark Comparisons
Effects benchmarks represent concentrations at or above which adverse effects are likely to occur.
Effects benchmarks are typically based on toxicity tests and experimental observations published and
summarized in the scientific literature. Effects benchmarks are typically reported based on the degree of
measured response observed. Effects benchmarks differ from screening benchmarks that identify
concentrations below which adverse effects are not expected to occur.
Ecological effects benchmarks for chemicals detected surface water, sediments, and soil (identified for
plant and invertebrate) were obtained from published regulatory sources and peer-reviewed scientific
literature using a multi-tiered hierarchy. In soil, separate effects benchmarks were identified for terrestrial
plant and soil invertebrate receptors.
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HQs were calculated by comparing EPCs to effects benchmarks, as shown:
Hazard Quotient = EPC /Benchmark (Equation 1)
Where:
EPC = RME EPC or CTE EPC
Benchmark = Effects Benchmark
An RME EPC coupled with a screening benchmark provides a conservative estimate of risk; whereas, a
CTE EPC coupled with an effects benchmarks provides a more realistic estimate of risk. Therefore, an
HQ less than 1 based on an RME and an effects screening benchmark indicates that the contaminant alone
is unlikely to cause adverse ecological effects; whereas, an HQ greater than 1 based on a CTE and an
effects benchmark suggests that a COPEC may be present at a concentration at which adverse effects may
occur.
The risk characterization also includes an evaluation of incremental risks that account for the contribution
of reference area concentrations to the overall site risks. Incremental risk was calculated as shown in
Equation 2:
Incremental Risk HQ = Site HQ - Reference HQ (Equation 2)
For the OU1/OU2 BERA, reference area data were available for terrestrial EAs (EA-2, EA-4, and EA-5)
and for the MMB wetlands. No reference data were available for the other aquatic EAs.
Food Chain Modeling Methods
Exposure of terrestrial and semi-aquatic wildlife (i.e., birds and mammals) to COPECs was estimated
using food chain models. Soil, sediments, and surface water EPCs were entered into the food chain
model to calculate an Estimated Daily Intake (EDI) to which the receptor may be exposed. EPCs for prey
items (tissue) were estimated using literature-based Bioaccumulation Factors (BAFs), except for estimates
of chromium concentrations in invertebrate tissue.
Chromium is a frequently detected COC; however, the scientific literature indicates there is no
meaningful positive correlation between soil/sediment concentration and invertebrate tissue
concentrations (Sample et al, 1998; US EPA, 1999). Because no defensible soil- or sediment-to-
invertebrate chromium BAFs are available in the scientific literature, a fixed value of invertebrate tissue
dry is used instead.
EDIs for individual COPECs were compared to wildlife TRVs to evaluate the effect of exposure on
representative species. The comparison was quantified using the HQ approach, as shown:
Hazard Quotient = EDI/ TR V (Equation 3)
Where:
EDI = Estimated daily intake calculated from the food chain model
TR V Toxicity Reference Value
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TRVs were obtained from studies published in primary literature resources or review articles that reported
No Observed Adverse Effect Level (NOAEL) and Lowest Observed Adverse Effect Level (LOAEL) with
survival, growth, or reproductive endpoints. Chronic studies were generally selected over acute or sub-
chronic studies. EPA-derived TRVs established to calculate Ecological Soil Screening Levels (Eco-
SSLs) were used preferentially when available. NOAEL and LOAEL TRVs are roughly analogous to
screening and effects benchmarks used for other media, except that they represent screening and effects
doses, rather than concentrations. Wildlife TRVs used in the food chain model are presented and
discussed in greater detail in Appendix N of the July 2015 OU1/OU2 RI Report, Attachment 5.
The details of food chain models, including exposure assumptions, BAFs, and TRVs, arc provided in
Attachment 5 of the OU1/OU2 BERA. along with the food chain modeling spreadsheets. Results of the
food chain modeling are presented in Appendix N of the July 2015 OU1/OU2 RI Report, Tables 4.5-1
through 4.5-11. Incremental risks (Equation 2) were also calculated for food chain models.
Ecological Risk Characterization
Ecological Risk Presented in the July 2015 OU1/OU2 RI Report
The HQs calculated by comparing RME and CTE EPCs to effects benchmarks are presented in Appendix
N of the July 2015 OU1/OU2 RI Report, Tables 4.3-1 through 4.3-17; results of the food chain modeling
are presented in Tables 4.5-1 through 4.5-11.
The OU1/OU2 BERA found that adverse effects associated with releases at or from OU1 and OU2 to
ecological receptors are unlikely in the following EAs and media:
• EA-2 soil;
• EA-4 soil;
• Central Pond surface water and sediments;
• Storm Water Detention Basin surface water and sediments;
• On-Property West Ditch Stream surface water, wetlands, and sediments;
• Upper South Ditch Stream sediments;
• Off-Property West Ditch Stream surface water and sediments;
• MMB surface water and sediments; and
• North Pond surface water and sediments.
The OU1/OU2 BERA found that adverse effects may be possible in the following EAs and media:
• EA-5 soil, due to chromium and BEHP;
• Upper South Ditch Stream surface water, due to chromium and ammonia;
• Lower South Ditch Stream surface water due to chromium, and ammonia; and
• Lower South Ditch Stream sediments due to chromium and BEHP.
Tables G-Ecol through G-Eco3 in Appendix B of this ROD present the HQs for areas where adverse
effect may be possible. Table G-Eco5 in Appendix B of this ROD presents the target contaminant
concentrations for protection of ecological receptors.
Updates to OU1/OU2 RI Report Conclusions
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The conclusions and findings presented in the OU1/OU2 BERA were updated in the Updates to
OU1/OU2 RIReport Conclusions (USEPA, 2020a). The original BERA indicated that there are no
ecological risk concerns in the portions of the Property available for redevelopment. The OU1/OU2
BERA also found that adverse Site-related effects may be possible for Lower South Ditch Stream
sediments and EA-5 soil due to chromium and BEHP, which is consistent with the findings of the
sediment toxicity test conducted in 2011.
EPA acknowledges that the sediment toxicity test showed toxicity in Lower South Ditch Stream
sediments, documenting mortality of benthic invertebrate population in these sediments. Although the
test did not attribute the cause to any specific chemical(s), ammonia - a primary COC in sediments - was
intentionally stripped from the Hyalella azteca samples prior to toxicity testing because the observed
concentrations were known to cause mortality. This suggests that a COC other than ammonia - likely
chromium - contributed to the observed toxic effects. However, the statement, "the BERA indicates that
there are no ecological risk concerns in the portions of the Property available for redevelopment" is
misleading and contains an inaccuracy. Firstly, the FS Report considers all risks across the Site,
regardless of whether an area is available for redev elopment or not.
Secondly, documented adverse effects to plants and mammals from exposure to chromium and BEHP in
soil and sediments are not confined to Lower South Ditch Stream and the EA-5 soil areas. This is
because these same plant and animal habitats are present beyond these limited EAs in other areas of
OU1/OU2 that contain actionable concentrations of chromium and BEHP in soil and sediments.
In addition to developing remedial alternatives to address contaminated soil and sediments in Lower
South Ditch Stream and EA-5, the development of alternatives in the FS Report for soil and sediments
was expanded to include other areas of OU1/OU2 with similar ecological risk concerns and that have
actionable concentrations of chromium and BEHP. These portions of OU1/OU2 include EA-1, EA-2,
EA-3, EA-4, EA-7, the Containment Area, Off-Property West Ditch Stream, and South Ditch Stream.
Surface water in Upper and Lower South Ditch Streams shows potential adverse effects to ecological
receptors, primarily due to ammonia and chromium. These potential adverse ecological effects were
extended to the East Ditch Stream. EPA has concerns that COCs in groundwater in the area of Plant B
could potentially impact the ecological quality of East Ditch Stream should Plant B cease operation.
Uncertainties
There is uncertainty associated with any BERA result because the risk estimates are based on several
assumptions regarding exposure and toxicity. More specifically, there is inherent variability and
uncertainty associated with the data collected to characterize exposure concentrations and assumptions
about the bioavailability of the selected COPECs (USEPA, 1997a).
Benchmarks used assess potential risk to aquatic, benthic and soil dwelling receptors are not site-specific
and therefore, in general, do not incorporate site-specific environmental conditions that may affect
bioavailability and subsequent toxicity. In addition, benchmarks do not address possible synergistic,
antagonistic, or additive effects of contaminant mixtures; therefore, risk may be over- or under-estimated,
depending on the interactions among the various chemicals present at the study area.
There are also assumptions and limitations inherent in food chain modeling, including selection of
exposure and modeling parameters (e.g., dietary intake, body weight, and age), uptake factors, and
toxicological data (e.g., TRVs). In addition, the food chain models assumed that 100% of the chemicals
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ingested are absorbed. In general, the conservative assumptions incorporated in the food chain models
may result in an overestimate of the risk.
3. Basis for Response Action
The OU1/OU2 BHHRA, OU1/OU2 BERA, Draft OU3 BHHRA, and associated updates determined that
current and future indoor workers or building occupants, current or future trespassers, future residents, or
ecological receptors potentially exposed to Site COCs in soil, groundwater, sediments, or surface water
via direct contact, ingestion, or inhalation may present an unacceptable human health or ecological risk.
Unacceptable human health risk was based on cancer risks exceeding the EPA acceptable risk range of
10 6 to 10~4 and/or non-carcinogenic hazards exceeding the EPA HI of 1. Unacceptable ecological risk
was based on comparison of COC levels in surface water samples to acute and chronic benchmarks and
toxicity testing to compare toxicity of Site surface water and sediment samples to reference locations.
The remedial action selected in this ROD is necessary to protect public health or welfare or the
env ironment from actual or threatened releases of hazardous substances, pollutants, or contaminants into
the environment.
Remedial actions focused on the following media: on-Property soil, upland soil, wetland soil, streambank
soil, sediments, South Ditch Stream surface water. East Ditch Stream surface water, Off-Property West
Ditch Stream surface water. Site-wide groundwater, and DAPL.
Remedial actions focused on the following media/areas:
• Subsurface soil (see Figure 14 in Appendix C of this ROD)
o Plant B;
o Human Health (HH)-EA-7;
o HH-EA-3; and
o Lake Poly (HH-EA-1).
• Upland surface soil (0-1 ft bgs; see Figure 15 in Appendix C of this ROD)
o Former Plant B area within Ecological (E)-EA-1;
o Former Plant C-l area within E-EA-1;
o Two small areas east of the current Plant B treatment building (E-EA-3);
o Former Lake Poly area within E-EA-1;
o An area between the former Lake Poly and the Containment Area;
o Small area immediately east of the East Warehouse (HH-EA-1);
o An area between the Containment Area and the Central Wetlands within E-EA-4; and
o Two single locations east of the former Plant D Tank Farm in E-EA-1 and at the
northwest corner of the Containment Area within E-EA-2.
• Upland shallow subsurface soil (1-10 ft bgs; see Figure 16 in Appendix C of this ROD)
o Former Plant B area and immediately to the north within E-EA-1;
o Former Plant C-l area within E-EA-1;
o Former Boiler House area within E-EA-1;
o An area at and east of the current Plant B treatment building (E-EA-3);
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o Former Lake Poly area within E-EA-1;
o An area immediately east of the East Warehouse and the area of the former Plant D (E-
EA-1);
o A small area between the Containment Area and Central Pond within E-EA-4; and
o Two single locations at the current guard shack within E-EA-1 and beneath the East
Warehouse within E-EA-1.
• Wetland surface soil (0-1 ft bgs; see Figure 17 in Appendix C of this ROD)
o A wetland area in the southern portion of E-EA-2, immediately north of the Containment
Area and adjacent to On-Property West Ditch Stream;
o A wetland area adjacent to both the north and south sides of the lower portion of South
Ditch Stream that spans the eastern boundary of the Property. The upstream portion of
this area is on-Property within E-EA-4 and the downstream portion of the area is off-
Property and is referred to as E-EA-5;
o Three single locations within the Central Wetlands, located within E-EA-4; and
o Three single locations in the wetlands to the south of the upper portion of South Ditch
Stream, located within E-EA-4.
• Wetland shallow subsurface soil (1-10 ft bgs: sec Figure 18 in Appendix C of this ROD)
o A wetland area in the southern portion of E-EA-2, immediately north of the Containment
Area and adjacent to On-Property West Ditch Stream;
o An off-Property wetland area adjacent to both the north and south sides of the lower
portion of South Ditch Stream within E-EA-5; and
o One single location within the Central Wetlands, located within E-EA-4.
• Sediments (sec Figure 17 in Appendix C of this ROD)
o Entire length of South Ditch Stream extending east from immediately downstream of the
concrete weir structure beyond the eastern Property line and to the confluence with East
Ditch Stream. The estimated remediation area includes aquatic sediments as well as soil
located between the top of the north bank and the south bank of South Ditch Stream;
o The northern portion of Off-Property West Ditch Stream; and
o Central Pond.
• Surface water (see Figure 19 in Appendix C of this ROD)
o South Ditch Stream (from the western Property boundary eastward to the confluence with
East Ditch Stream);
o Off-Property West Ditch Stream; and
o East Ditch Stream from the northern Property boundary southward to the confluence with
South Ditch Stream.
• LNAPL in vicinity of Plant B (see Figure 20 in Appendix C of this ROD)
• DAPL (see Figure 21 in Appendix C of this ROD)
o On-Property DAPL pool;
o Off-Property Jewel Drive DAPL pool; and
o Main Street DAPL pool.
• The mass of contaminants within the area of groundwater that targets the 5,000 ng/L NDMA
contour (see Figure 22 in Appendix C of this ROD)
• Containment Area soil (see Figure 23 in Appendix C of this ROD)
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H. REMEDIAL ACTION OBJECTIVES
Remedial Action Objectives (RAOs) are media-specific cleanup goals that define the objective of
remedial actions to protect human health and the env ironment. Based on preliminary information relating
to types of contaminants, environmental media of concern, and potential exposure pathways, RAOs were
developed to aid in the development and screening of alternativ es. These RAOs were dev eloped to
mitigate, restore, and/or prevent existing and future potential threats to human health and the environment
and to attain Applicable or Relevant and Appropriate Requirements (ARARs). The Site COCs are
presented in Table B-l of Appendix B of this ROD and the cleanup levels and performance standards are
presented in Tables L-l and L-2 of Appendix B of this ROD.
EPA determined that proposing an interim remedial action is appropriate at this Site to initiate
groundwater restoration while additional information is collected to better assess the practicability of
aquifer restoration prior to the determination of final cleanup levels and selection of a final remedial
action for groundwater. Accordingly, interim RAOs have been developed for groundwater that prioritize
reduction of exposure risk and reduction of contaminant mass through treatment. The interim RAOs will
not include attainment of specific cleanup levels. The interim RAOs for DAPL and groundwater include:
• DAPL
o Reduce the volume of DAPL and mass of Site COCs in DAPL that represent a source to
groundwater, surface water, and sediments.
o Reduce the horizontal and vertical migration of DAPL acting as a source of Site COCs,
including penetration into bedrock.
o Prevent potential human exposure to DAPL containing Site COCs above levels that arc
protective for residential use.
• Groundwater Hot Spots
o Reduce the mass of Site COCs in groundwater hot spots.
o Reduce the further horizontal and vertical migration of Site COCs in groundwater hot
spots, including penetration into bedrock.
o Prevent potential human exposure to groundwater containing Site COCs above levels that
arc protective for residential use.
The RAOs for the final remedy for LNAPL, surface water, soil, and sediments include:
• LNAPL
o Prevent migration of LNAPL to East Ditch Stream to prevent exposure by current and
future ecological receptors to Site COCs that would result in potential adverse impacts.
o Prevent the migration of Site COCs in LNAPL from the subsurface to groundwater and
that is a source of TMPs to indoor air vapors, via a vapor intrusion pathway, that pose an
unacceptable risk to future indoor workers or building occupants.
• Surface Water
o Prev ent migration of groundwater containing Site COCs to East Ditch Stream, South
Ditch Stream, and Off-Property West Ditch Stream to prevent exposure by current and
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future ecological receptors to surface water containing Site COCs that would result in
potential adverse impacts.
o Prevent migration of groundwater containing Site COCs to Off-Property West Ditch
Stream to prevent potential current and future human exposure to surface water
containing Site COCs above levels that are protective for trespassers.
• OU1/OU2 Soil
o Prevent potential future human exposure to soil containing Site COCs above levels that
are protective for residential use.
• Upland Soil (including the Containment Area)
o Prevent potential human exposure by a future indoor worker or building occupant to
indoor air vapors, via a vapor intrusion pathway, containing COCs at levels that pose an
unacceptable risk.
o Prevent exposure by current and future ecological receptors to upland soil containing
COCs that would result in potential adverse impacts.
o Prevent leaching of COCs associated with the Containment Area into groundwater,
surface water, and sediments at levels that pose unacceptable risks to human health and
the environment.
• Wetland Soil and Sediments
o Prevent exposure by current and future ecological receptors to wetland soil and sediments
containing Site COCs that would result in potential adverse impacts.
o Prevent the further migration of wetland soil and sediments containing Site COCs to
nearby wetlands, surface water, drainage features, and adjoining properties that would
result in potential adverse impacts.
I. DEVELOPMENT AND SCREENING OF ALTERNATIV ES
1. 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: (1) a requirement that EPA's
remedial action, when complete, must comply with all federal environmental and more stringent state
environmental and facility siting standards, requirements, criteria, or limitations, unless a waiver is
invoked; (2) 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 (3) a preference for remedies in which treatment that permanently and
significantly reduces the toxicity, mobility, or volume 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.
2. Technology and Alternative Development and Screening
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CERCLA and the NCP set forth the process by which remedial actions are evaluated and selected. In
accordance with these requirements, a range of alternatives were developed for the Site.
With respect to source control, the RI/FS process developed a range of alternatives for DAPL,
groundwater, LNAPL, surface water, soil, soil vapor, sediments, and indoor air in which treatment that
reduces the toxicity, mobility, or volume of the hazardous substances is a principal element. This range
included alternatives that remove or destroy hazardous substances to the maximum extent feasible,
eliminating or minimizing to the degree possible the need for long-term management. This range also
included: alternatives that treat the principal threats posed by the Site but vary in the degree of treatment
employed and the quantities and characteristics of the treatment residuals and untreated waste that must
be managed; alternatives that involve little or no treatment but provide protection through engineering or
Institutional Controls; and a no action alternative.
As discussed in Section 2.0 of the FS Report Volumes I and II, treatment technology options for DAPL,
groundwater, LNAPL. surface water, soil, soil vapor, sediments, and indoor air were identified, assessed,
and screened based on implcmentability, effectiveness, and cost.
Section 3.0 of the FS Report Volumes I and II presents the remedial alternatives developed by combining
the technologies identified in the previous screening process in the categories identified in Section
300.4301(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 4.0 of the FS Report Volumes I and II.
Of the 34 source control and management of migration remedial alternatives screened in Section 3.0 of
the FS Report Volumes I and II for all impacted media including DAPL, groundwater, LNAPL, surface
water, soil, soil vapor, sediments, and indoor air, 29 were retained as possible options for the cleanup of
the Site. As discussed in detail in the FS Report Volume III, from this initial screening, remedial options
were combined to form four sets of alternatives each to address the consolidated cleanup components of
DAPL/groundwatcr hot spots for OU3, and LNAPL/surface water and soil/sediments for OU1 and OU2.
In addition to a no action alternative, three sets of source control and management of migration
alternatives were developed for the interim remedial action for OU3. Similarly, in addition to two no
action alternatives, six sets of source control and management of migration alternatives were developed
for the final remedial action for OU1 and OU2.
Ultimately, twelve sets of alternatives for the consolidated cleanup components (four for
DAPL/groundwater hot spots in OU3, four for LNAPL/surface water in OU1 and OU2, and four for
soil/sediments in OU1 and OU2) were selected for detailed analysis. Although the alternatives arc media-
specific, the media and alternatives are interrelated such that one alternative for a particular medium may
impact the remedial alternative options for other media. For example, because the surface water in East,
South, and West Ditch Streams is continuously receiving flow of contaminated groundwater, it would not
be practical to directly address surface water. Instead, surface water options, and consequently
exceedances resulting in unacceptable risks, arc addressed through groundwater options, along with
evaluation of surface water to determine achievement of RAOs. Similarly, since the presence of DAPL in
the aquifer results in the migration of COCs to overlying groundwater, any groundwater alternative would
be dependent upon the actions taken to eliminate principal threat wastes associated with DAPL, otherwise
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the efficiency, effectiveness, and timeframe for implementation of the groundwater hot spot remedy could
be compromised.
J. DESCRIPTION OF ALTERNATIVES
This section provides a narrative summary of each remedial alternative retained following screening and
evaluated in the detailed analysis section of the FS Report. These alternatives were developed by
combining response actions and technologies to address the estimated exposure risks to human health and
the environment. The alternatives were also developed, to the extent practicable, to represent a range of
effectiveness, duration of time required to achieve the RAO, and cost to implement.
The descriptions of each remedial alternative are conceptual and arc used for costing purposes. The
specific design details and costs for the selected remedy will be re-evaluated during the RD. The costs
arc intended to be within the target accuracy of -30 to +50% of the actual cost. All present worth costs
associated with O&M and periodic expenditures are based on a 7% discount rate over 30 years.
1. Source Control Alternatives Analyzed
The OU1/OU2 source control alternatives analyzed for a final remedial action for soil and sediments
include the following:
Final Action - Soil/Sediments
• SOIL/SED-1: No action
• SOIL/SED-2: Containment Area cap, upland soil covers, excavation with off-site disposal and
restoration of wetland soil and sediments, limited action for TMPs (Institutional Controls,
including vapor intrusion evaluation or vapor barriers/sub-slab depressurization systems)
• SOIL/SED-3: Containment Area cap, excavation with off-site disposal and clean soil cover for
upland soil, excavation with off-site disposal and restoration of wetland soil and sediments, air
sparging and SVE for TMPs
• SOIL/SED-4: Excavation (0-10 ft) with off-site disposal and clean soil cover for Containment
Area and upland soil, excavation with off-site disposal and restoration of wetland soil and
sediments, excavation and off-site disposal for TMPs
Each of the source control alternatives for soil and sediments is summarized below. With the exception
of the No Action alternative (SOIL/SED-1), each of the alternatives for soil and sediments includes the
following: (1) a PDI to further define the horizontal and vertical extent of soil contamination and refine
the design and footprint of caps and cover systems; (2) post-excavation confirmatory sampling to
document limits of soil and sediment impacts and confirm achievement of RAOs and PRGs: (3)
dewatering and stabilization, as necessary, of excavated soil and sediments prior to shipment off-site; (4)
restoration of excavated areas with clean, imported backfill to grade and re-vegetation with native
vegetation to control erosion; (5) restoration of any wetland/floodplain habitat altered by the remedial
action such that current flood storage capacities and wetlands arc not diminished after completion of
remedial actions; (6) all appropriate plans and specifications (e.g., air monitoring plan,
transportation/trucking plan, dust and odor control plan, soil management plan, restoration plan,
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demolition plan for existing structures, as appropriate, erosion and sedimentation control plan, and health
and safety plan); and (7) all necessary preparation and mobilization activities (e.g., removal of vegetation
and debris, as appropriate, installation of temporary fencing, decontamination facilities, soil
stockpile/management areas, trailer, and sanitation facilities). A more complete, detailed presentation of
each soil and sediment alternative may be found in Section 4.0 of the FS Report Volume I and Section IX
of the FS Report Volume III.
Alternative SOIL/SED-1: No Action
As required by CERCLA and the NCP, Alternative SOIL/SED-1 was developed as a baseline for
comparing the effectiveness of the other remedial alternatives for soil and sediments. No further action
would be taken to address contamination in the Containment Area, upland soil, wetland soil and
sediments, and to address the presence of TMPs in soil. The No Action Alternative does not include
active remediation or Institutional Controls and the current levels of contaminants in soil and sediments
are assumed to remain unchanged. No construction would take place, and RAOs would not be achieved.
As required by CERCLA, Five Year Reviews would still be performed as part of the No Action
Alternative. Except for the cost of statutorily-required Five Year Reviews, there is no cost associated
with this alternative - the capital cost for this alternative is SO, the annual O&M cost is $0, and the net
present value is $0.
Alternative SOIL/SED-2: Containment Area cap, upland soil covers, excavation with off-site
disposal and restoration of wetland soil and sediments, limited action for TMPs (Institutional
Controls, including vapor intrusion evaluation or vapor barriers/sub-slab depressurization
systems) (This is EPA '.v Selected Alternative.)
Alternative SOIL/SED-2 is shown on Figure 24 in Appendix C of this ROD. Alternative SOIL/SED-2
includes placement of a permanent, low-permeability cap over the Containment Area that meets RCRA
Subtitle D and Massachusetts solid waste landfill performance standards. The existing equalization
window would be closed by grouting in place. Soil or asphalt cover systems would be placed over areas
of shallow (0-1 ft) upland soil with concentrations of COCs in excess of the PRGs. The caps and cover
systems would be designed to prevent direct contact with impacted soil, to prevent soil from being carried
to nearby areas, including streams and wetlands, during rain events via erosion, and to prevent soil
contaminants from leaching to groundwater. The caps and cover systems would be adequately designed
with long-term integrity for seasonal conditions, severe storms (up to a 500-year storm event), and
freeze/thaw conditions; to satisfy ARAR requirements; and to prevent contaminants leaching to
groundwater (i.e., meet impermeability requirements). Mitigation measures would be required to address
any unavoidable short- or long-term floodplain impairment within the 500-year floodplain on the
Property. Based on the available wetland soil and sediment data, PRG exceedanccs for the COCs arc
generally limited to approximately 1 ft bgs. A PDI will be conducted to further refine the extent of
material to be excavated. Under this alternative, wetland soil and sediments with concentrations of COCs
in excess of the PRGs would be excavated (estimated to be approximately 6,000 tons) and disposed of
off-site at an appropriate permitted facility.
This alternative also includes long-term monitoring and maintenance of capped/covered areas, as well as
Institutional Controls to ensure that caps and cover systems are maintained and prevent contact with the
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underlying soil, prohibit residential, school, and daycare use of the Property, and guard against the future
vapor intrusion pathway. TMPs would be addressed via Institutional Controls that require vapor intrusion
evaluations and/or vapor barriers/sub-slab depressurization systems. Five Year Reviews would be
required since contamination would be left in place. The estimated construction time for this alternative
is two years; the time to achieve RAOs is also estimated to be on the order of two years. The estimated
capital cost for this alternative is $5.6 million, the annual O&M cost is $1.1 million, and the net present
value is $6.1 million.
Alternative SOIL/SED-3: Containment Area cap, excavation (0-1 ft) with off-site disposal and clean
soil cover for upland soil, excav ation with off-site disposal and restoration of wetland soil and
sediments, air sparging and SVE for TMPs
Alternative SOIL/SED-3 is shown on Figure 25 in Appendix C of this ROD. Alternative SOIL/SED-3
includes placement of a permanent cap over the Containment Area. The existing equalization window
would be closed by grouting in place. Upland soil (0-1 ft) and wetland soil and sediments with
concentrations of COCs in excess of the PRGs would be excav ated (estimated to be approximately 10,000
tons) and disposed of off-site at an appropriate permitted facility. A PDI would be conducted to refine the
extent of upland soil and wetland soil and sediments to be excavated. Excavated soil and sediments
would be dewatered and stabilized, as necessary, prior to shipment off-site. Excavated upland soil areas
would be backfilled with either a 1-ft soil layer cover system or a combination 9-inch (in) soil layer and
3-in asphalt layer cover system. Soil cover systems would be re-vegetated with native vegetation to
control erosion. The caps and cover systems would be designed to prevent direct contact with impacted
soil, to prevent soil from being carried to nearby areas, including streams and wetlands, during rain events
via erosion, and to prevent soil contaminants from leaching to groundwater. The caps and cover systems
would be adequately designed with long-term integrity for seasonal conditions, severe storms (up to a
500-year storm event), and freeze/thaw conditions; to satisfy ARAR requirements; and to prevent
contaminants leaching to groundwater {i.e., meet impermeability requirements). Mitigation measures
would be required to address any unavoidable short- or long-term floodplain impairment within the 500-
year floodplain on the Property. Based on the available wetland soil and sediment data, PRG exceedances
for the COCs are generally limited to approximately 1 ft bgs. A PDI will be conducted to further refine
the extent of material to be excavated. Under this alternative, wetland soil and sediments with
concentrations of COCs in excess of the PRGs would be excavated and disposed of off-site at an
appropriate permitted facility.
This alternative also includes long-term monitoring and maintenance of capped/covered areas, as well as
Institutional Controls to ensure that caps and cover systems are maintained and prevent contact with the
underlying soil, prohibit residential, school, and daycare use of the Property, and guard against the future
vapor intrusion pathway. TMPs would be removed and treated via installation and operation of an air
sparging/SVE system. Five Year Reviews would be required since contamination would be left in place.
The estimated construction time for this alternative is two years; the time to achieve RAOs is also
estimated to be on the order of two years. The estimated capital cost for this alternative is $6.7 million,
the annual O&M cost is $1.5 million, and the net present value is $7.5 million.
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Alternative SOIL/SED-4: Excavation (0-10 ft) with off-site disposal and clean soil cover for
Containment Area and upland soil, excavation with off-site disposal and restoration of wetland soil
and sediments, excavation and off-site disposal for TMPs
Alternative SOIL/SED-4 is shown on Figure 26 in Appendix C of this ROD. Alternative SOIL/SED-4
includes excavation of areas within the Containment Area with concentrations of COCs in excess of the
PRGs. Sheet piling would be installed, as necessary, to maintain the structural integrity of the slurry wall
during excavation. Upland soil (0-10 ft), wetland soil and sediments, and TMP-containing soil with
concentrations of COCs in excess of the PRGs would be excavated (estimated to be approximately
130,000 tons) and disposed of off-site at an appropriate permitted facility. Based on the available upland
soil data, which is very limited,20 the majority of PRG exceedances for the COCs appear to be located
between 0 and approximately 8 ft bgs. A PDI will be conducted to further refine the extent of soil and
sediments to be excavated. Excavated soil and sediments would be dewatered and stabilized, as
necessary, prior to shipment off-site. Excavated areas would be backfilled with clean soil to grade and re-
vegetated with native vegetation to control erosion; to withstand seasonal conditions (up to a 500-year
storm event), and freeze/thaw conditions; and to satisfy ARAR requirements. Mitigation measures would
be required to address any unavoidable short- or long-term floodplain impairment within the 500-year
floodplain on the Property.
This alternative also includes long-term monitoring and maintenance of restored areas, as well as
Institutional Controls to ensure the long-term integrity of restored areas, and prohibit residential, school,
and daycare use of the Property. Five Year Reviews would be required since contamination would be left
in place. The estimated construction time for this alternative is two years; the time to achieve RAOs is
also estimated to be on the order of two years. The estimated capital cost for this alternative is $34.0
million, the annual O&M cost is $330,000, and the net present value is $34.2 million.
2. Combined Source Control and Management of Migration Alternatives Analyzed
Elements of source control were combined with management of migration to develop alternatives for a
final remedial action for LNAPL and surface water and an interim remedial action for DAPL and
groundwater hot spots. Management of migration alternatives address contaminants that have migrated
into and with groundwater from the original source of contamination. At the Site, contaminants have
migrated from surface and subsurface releases at the Property into Site-wide groundwater, and surface
water at the Site continuously receives flow of contaminated groundwater. The action alternatives to
address surface water consist of remedies to intercept and treat the overburden groundwater plume to
prevent continued impacts to surface water. The OU1/OU2 combined source control and management of
migration alternatives analyzed for a final action for LNAPL and surface water include the following:
• Source control options to remove LNAPL that represents a source of COCs to groundwater and a
source of TMPs to indoor air v apors; and
• Management of migration options to prevent the migration of LNAPL to East Ditch Stream and
prev ent the migration of groundwater containing COCs to East Ditch Stream, South Ditch
Stream, and Off-Property West Ditch Stream.
20 The collection of upland soil samples on the Property has been limited by the presence of concrete slabs that
remained following the demolition of former plant buildings and other structures.
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The 0U3 combined source control and management of migration alternatives analyzed for an interim
action for DAPL and groundwater hot spots include the following:
• Source control options to reduce the volume of DAPL and mass of COCs in DAPL and
groundwater hot spots that represent a source of contamination to groundwater, surface water,
and sediments; and
• Management of migration options to reduce the horizontal and vertical migration of (1) DAPL
acting as a source of COCs; and (2) groundwater hot spots, including penetration into bedrock.
The OU1/OU2 source control and management of migration alternatives analyzed for a final remedial
action for LNAPL and surface water include the following:
Final Action - LNAPL/Surface Water
• LNAPL/SW-1: No action
• LNAPL/SW-2: MPE for LNAPL with treatment at Plant B, groundwater extraction to prevent
impacts to surface water, treatment at new treatment systcm(s)
• LNAPL/SW-3: Demolition of Plant B, expanded MPE for LNAPL, targeted groundwater extraction
to prevent impacts to surface water, treatment at new treatment system(s)
• LNAPL/SW-4: Excavation of LNAPL with off-site disposal, targeted Permeable Reactive Barriers
(PRBs) to treat groundwater before flow into surface water
Each of the alternatives for LNAPL and surface water is summarized below. With the exception of the
No Action alternative (LNAPL/SW-1), each of the alternatives for LNAPL and surface water includes
PDIs to: (1) determine the final number, location, and configuration of extraction wells and other
remedial components; (2) determine appropriate locations for discharge of treated groundwater to surface
water; and (3) map the precise extent of LNAPL remediation limits. Additionally, each of the action
alternatives for LNAPL and surface water include the following: (I) restoration of any wetland/floodplain
habitat altered by the remedial action such that current flood storage capacities and wetlands arc not
diminished after completion of remedial actions; (2) all appropriate plans and specifications (e.g., air
monitoring plan, transportation/trucking plan, dust and odor control plan, soil management plan,
restoration plan, demolition plan for existing structures, as appropriate, erosion and sedimentation control
plan, and health and safety plan); (3) all necessary preparation and mobilization activities (e.g., removal
of vegetation and debris, as appropriate, installation of temporary fencing, decontamination facilities, soil
stockpile/management areas, trailer, and sanitation facilities); (4) long-term maintenance and monitoring
of new and existing remedy infrastructure components; and (5) long-term monitoring of the groundwater
plume and surface water, to evaluate remedy effectiveness. A more complete, detailed presentation of
each LNAPL alternative may be found in Section 4.0 of the FSReport Volume II. More detailed
presentations of each surface water alternative may be found in Section 4.0 of the FS Report Volume I.
Additional details may also be found in Section VIII of the FS Report Volume III.
Alternative LNAPL/SW-1: No Action
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As required by CERCLA and the NCP, Alternative LNAPL/SW-1 was developed as a baseline for
comparing the effectiveness of the other remedial alternatives to address LNAPL and surface water. No
further action would be taken to address LNAPL or surface water contamination. The No Action
Alternative does not include active remediation or Institutional Controls and the current level of LNAPL
contamination and level of contaminants in surface water are assumed to remain unchanged. No
construction would take place, and RAOs would not be achieved. As required by CERCLA, Five Year
Reviews would still be performed as part of the No Action Alternative. Except for the cost of statutorily-
required Five Year Reviews, there is no cost associated with this alternative - the capital cost for this
alternative is $0, the annual O&M cost is $0, and the net present value is $0.
Alternative LNAPL/SW-2: MPE for LNAPL with treatment at Plant B, groundwater extraction to
prevent impacts to surface water, treatment at new treatment svstem(s)
Alternative LNAPL/SW-2 is shown on Figure 27 in Appendix C of this ROD. Alternative LNAPL/SW-
2 includes construction and operation of approximately one MPE well, located just outside the northeast
corner of the Plant B building near monitoring well GW-23, where the thickest LNAPL accumulation is
observed. PDIs during the PD phase will determine the final number, location, and configuration of MPE
wells and other remedial components under this alternative. A skid-mounted system would likely be
employed to treat the extracted materials, conceptually consisting of an extraction blower, knockout tank
to separate the streams, oil/water separator to remove LNAPL, and GAC to treat vapors. Extracted
groundwater would be conveyed to the existing Plant B for additional treatment. Extracted LNAPL
would be stored on-site, with off-site disposal at an appropriate off-site permitted facility.
This alternative also includes the installation of a groundwater extraction and treatment system, with
extraction wells sited based on PDIs, to prevent contaminant concentrations in groundwater from
impacting surface water. Extracted groundwater would be treated at a newly constructed, groundwater
treatment system or systems (potentially the same system(s) as for the groundwater hot spots, see below)
and discharged to surface water. The treatment system(s) design would be refined during the RD phase,
and would include components such as an influent equalization task, hypochlorite flash mixer for
oxidation and removal of metals, breakpoint chlorination for ammonia treatment, slow mix flocculation
and lamella clarifier to remove solids, filter press for solids dewatering, GAC to ensure clarity, UV
transmittance, and remove VOCs, and UV photo-oxidation for NDMA destruction. O&M would include
monitoring to assure that the extraction pumps are operating properly, the treatment components are in
proper operation, the activated carbon is changed as needed, and compliance monitoring for air emissions
and treated water are being performed. Mitigation may be required for any alteration of the 500-year
floodplain and/or wetlands from the installation, operation, and maintenance of the groundwater treatment
system(s). Well and piping locations, as well as the location of the treatment system or systems, would
need to be designed so as to not interfere with the remedial infrastructure required for the soil and
sediment components (see above) and DAPL and groundwater hot spot components (see below) of the
selected remedy.
This alternative includes Institutional Controls to prohibit residential, school, and daycare use of the
Property, prevent disturbance of any engineered systems and any new and existing remedy infrastructure
components, and prohibit the use of contaminated groundwater unless it can be demonstrated to EPA, in
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consultation with the Commonwealth, that such use will not pose an unacceptable risk to human health
and the environment, cause further migration of the groundwater contaminant plume, or interfere with the
remedy. Five Year Reviews would be required since contamination would be left in place. The estimated
construction time for this alternative is two to three years. A 30-year timeframe was used for O&M,
monitoring, and cost estimation purposes. The estimated capital cost for this alternative is $4.6 million,
the annual O&M cost is $6.5 million, and the net present value is $9.0 million.
Alternative LNAPL/SW-3: Demolition of Plant B, expanded MPE for LNAPL, targeted
groundwater extraction to prevent impacts to surface water, treatment at new treatment svstem(s)
(This is EPA's Selected Alternative.)
Alternative LNAPL/SW-3 is shown on Figure 28 in Appendix C of this ROD. Alternativ e LNAPL/SW-
3 includes the installation of a groundwater extraction and treatment system to prevent contaminant
concentrations in groundwater from impacting surface water. Extraction wells would be installed along
Off-Property West Ditch Stream and South Ditch Stream to intercept and treat the ov erburden
groundwater contaminant plume that impacts these streams. Extraction wells would be sited and
configured based upon PDls. Extracted groundwater would be treated at a newly constructed
groundwater treatment system or systems (potentially the same system(s) as for the groundwater hot
spots, see below) and discharged to surface water. The treatment system(s) design would be refined
during the RD phase, and would include components such as an influent equalization task, hypochlorite
flash mixer for oxidation and removal of metals, breakpoint chlorination for ammonia treatment, slow
mix flocculation and lamella clarifier to remov e solids, filter press for solids dewatering, GAC to ensure
clarity, UV transmittance, and remove VOCs, and UV photo-oxidation for NDMA destruction.
Additionally, groundwater currently treated by Plant B would be re-routed to the new groundwater
treatment system(s). Following this, the Plant B groundwater treatment system would be
decommissioned and demolished. An estimated three to five MPE wells, the exact number and location
of which will be determined by the PDIs, would be installed within the LNAPL footprint, including
beneath the Plant B building foundation following Plant B's demolition, to remediate LNAPL, the smear
zone, and dissolved-phase COCs that would otherwise impact East Ditch Stream. A skid-mounted
system would likely be employed to treat the extracted materials, conceptually consisting of an extraction
blower, knockout tank to separate the streams, oil/water separator to remove LNAPL, and GAC to treat
vapors. Extracted LNAPL would be stored on-site, with off-site disposal at an appropriate off-site
permitted facility. Extracted groundwater would be conveyed to the new groundwater treatment
system(s) for treatment. O&M would include monitoring to assure that the extraction pumps are
operating properly, the treatment components are in proper operation, the activated carbon is changed as
needed, and compliance monitoring for air emissions and treated water are being performed. Mitigation
may be required for any alteration of the 500-year floodplain and/or wetlands from the installation,
operation, and maintenance of the groundwater treatment system(s). Well and piping locations, as well as
the location of the treatment system(s), would need to be designed so as to not interfere with the remedial
infrastructure required for the soil and sediment components (see above) and DAPL and groundwater hot
spot components (see below) of the selected remedy.
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This alternative includes Institutional Controls to prohibit residential, school, and daycare use of the
Property, prevent disturbance of any engineered systems and any new and existing remedy infrastructure
components, and prohibit the use of contaminated groundwater unless it can be demonstrated to EPA, in
consultation with the Commonwealth, that such use will not pose an unacceptable risk to human health
and the environment, cause further migration of the groundwater contaminant plume, or interfere with the
remedy. Five Year Reviews would be required since contamination would be left in place. The estimated
construction time for this alternative is two to three years. A 30-year timeframe was used for O&M,
monitoring, and cost estimation purposes. The estimated capital cost for this alternative is $2.3 million,
the annual O&M cost is $7.4 million, and the net present value is $6.6 million.
Alternative LNAPL/SW-4: Excavation of LNAPL with off-site disposal, targeted PRBs to treat
groundwater before flow into surface water
Alternative LNAPL/SW-4 is shown on Figure 29 in Appendix C of this ROD. Under Alternative
LNAPL/SW-4, Plant B would continue to operate until the new groundwater hot spot treatment system(s)
has been constructed and is fully operational (see below). Current Plant B extraction wells would then be
re-routed to the new treatment system(s), and Plant B would be decommissioned and demolished.
LNAPL-impacted soil would be excav ated to the bottom of the smear zone. The v olume of soil to be
excavated under this alternative is estimated to be 830 cy, with an additional 520 cy remov ed (for a total
of 1,350 cy) if the initial excav ation reveals additional LNAPL-impacted soil requiring remov al. Post-
excavation confirmatory sampling would be conducted to document limits of LNAPL impacts and
confirm achievement of RAOs and PRGs. Excav ated soil would be dewatered and stabilized, as
necessary, prior to shipment off-site. The excavated area would be backfilled with clean soil to grade and
re-vegetated with native vegetation to control erosion; to withstand seasonal conditions (up to a 500-year
storm event), and freeze/thaw conditions; and to satisfy ARAR requirements.
This alternative also includes construction and installation of PRBs along portions of South Ditch Stream,
where the majority of concentrations of COCs above PRBs arc found. A grouted sheet-pile wall would be
constructed to direct groundwater through the PRBs. The PRB would be constructed perpendicular to the
direction of groundwater flow in the vicinity of the weir and upstream portion of South Ditch Stream
where contaminated groundwater flows laterally to and into the stream. The design of the PRBs would
be based on additional data obtained during the PD1 phase, and might include additional segments of
PRBs in other areas to address East and West Ditch Streams if PDI data indicates that groundwater
impacted by COCs is resulting in unacceptable impacts to these surface waters. Reactive materials for the
PRBs would consist of a mixture of zeolites to treat ammonia and activated carbon to treat chromium.
The PRBs would be installed from just below ground surface to the weathered bedrock surface.
Finally, this alternative includes construction of a groundwater extraction and treatment system or
systems (potentially the same system(s) as for the groundwater hot spots, see below), to which
groundwater currently treated by the existing Plant B would be re-routed. The treatment system(s) design
would be refined during the RD phase, and would include components such as an influent equalization
task, hypochlorite flash mixer for oxidation and removal of metals, breakpoint chlorination for ammonia
treatment, slow mix flocculation and lamella clarifier to remove solids, filter press for solids dewatering,
GAC to ensure clarity, UV transmittance, and remove VOCs, and UV photo-oxidation for NDMA
destruction. O&M for Alternative LNAPL/SW-4 would include monitoring to assure that the extraction
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pumps and PRB segments are operating properly, periodic replacement/regeneration of the reactive media
in the PRB, and for the groundwater treatment system(s), monitoring to assure that components are in
proper operation, the activated carbon is changed as needed, and compliance monitoring for air emissions
and treated water are being performed. Mitigation may be required for any alteration of the 500-year
floodplain and/or wetlands from the installation, operation, and maintenance of the groundwater treatment
system(s). Well, piping, and PRB segment locations, as well as the location of the treatment system(s),
would need to be designed so as to not interfere with the remedial infrastructure required for the soil and
sediment components (see above) and DAPL and groundwater hot spot components (see below) of the
selected remedy.
This alternative includes Institutional Controls to prohibit residential, school, and daycare use of the
Property, prevent disturbance of any engineered systems and any new and existing remedy infrastructure
components, including the PRB segments, and prohibit the use of contaminated groundwater unless it can
be demonstrated to EPA, in consultation with the Commonwealth, that such use will not pose an
unacceptable risk to human health and the env ironment, cause further migration of the groundwater
contaminant plume, or interfere with the remedy. Long-term monitoring and maintenance would be
conducted of areas that have been restored following remediation-related disturbances. Five Year
Reviews would be required since contamination would be left in place. The estimated construction time
for this alternative is one year. A 30-year timeframe was used for O&M, monitoring, and cost estimation
purposes. The estimated capital cost for this alternative is $5.3 million, the annual O&M cost is $6.7
million, and the net present value is $9.0 million.
The OU3 source control and management of migration alternatives analyzed for an interim remedial
action for DAPL and groundwater hot spots include the following:
Interim Action — DAPL/Groundwater Hot Spots
• DAPL/GWHS-1: No action
• DAPL/GWHS-2: DAPL extraction (approx. 5 wells), groundwater hot spot extraction targeting
11,000 ng/L NDMA contour (approx. 2-3 wells), and treatment at new treatment system(s)
• DAPL/GWHS-3: DAPL extraction (approx. 20 wells), groundwater hot spot extraction targeting
5,000 ng/L NDMA contour (approx. 6 wells), and treatment at new treatment system(s)
• DAPL/GWHS-4: DAPL extraction (approx. 20 wells), groundwater hot spot extraction targeting
1,100 ng/L NDMA contour (approx. 12 wells), and treatment at new treatment system(s)
Each of the alternatives for DAPL and groundwater hot spots is summarized below. With the exception
of the No Action alternative (DAPL/GWHS-1), each of the alternatives for DAPL and groundwater hot
spots includes PDIs to: (1) determine the final number, location, and configuration of extraction wells and
other remedial components; (2) determine appropriate locations for discharge of treated groundwater to
surface water; and (3) facilitate the implementation of the chosen cleanup alternatives. Additionally, each
of the action alternatives for DAPL and groundwater include the following: (1) restoration of any
wetland/floodplain habitat altered by the remedial action such that current flood storage capacities and
wetlands are not diminished after completion of remedial actions; (2) all appropriate plans and
specifications (e.g., air monitoring plan, transportation/trucking plan, dust and odor control plan, soil
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management plan, restoration plan, demolition plan for existing structures, as appropriate, erosion and
sedimentation control plan, and health and safety plan); (3) all necessary preparation and mobilization
activ ities (e.g., removal of vegetation and debris, as appropriate, installation of temporary fencing,
decontamination facilities, soil stockpile/management areas, trailer, and sanitation facilities); (4) long-
term maintenance and monitoring of new and existing remedy infrastructure components; (5)
identification and evaluation of existing wells (e.g., potable, irrigation, and process wells) in the Site
groundwater study area (see Figure 11 in Appendix C of this ROD) to determine whether their use will
pose an unacceptable risk to human health and the env ironment, cause further migration of the
groundwater contaminant plume, or interfere with the remedy; and (6) long-term monitoring of the
groundwater plume and surface water, to evaluate remedy effectiveness.
In parallel to the implementation of each action alternative for DAPL and groundwater, OU3 RI/FS
activities will continue, which include the following: (1) continued studies to close remaining data gaps,
including to improv e the characterization of bedrock topography and fractures and further delineate the
horizontal and v ertical extent of groundwater contamination; and (2) evaluation of long-term groundwater
remedial alternativ es, leading to the selection of a final cleanup plan for the Site.
Under each of the action alternatives discussed below, DAPL would be pumped to a storage tank(s)
where it would be stored prior to treatment. Performance monitoring schedules would be evaluated as
part of the RD phase, and would generally occur on a monthly basis. Monitoring would be performed to
assess remedy progress, evaluate the response of the DAPL and ov erlying groundwater during pumping,
assess trends of monitored parameters in DAPL and groundwater, and assess the specific chemical
characteristics of the extracted DAPL.
The DAPL and groundwater hot spot treatment system(s) design would be refined during the RD phase.
Conceptually, it is assumed that such treatment will generally include the following components:
treatment for DAPL consisting of lime precipitation to remove metals, devvatering and off-site disposal of
liquids and sludge materials, stripping of VOCs and ammonia. UV photo-oxidation of NDMA, and
evaporation of remaining water and off-site disposal of residual solids; and additional treatment for hot
spot groundwater consisting of an influent equalization task, hypochlorite flash mixer for oxidation and
remov al of metals, breakpoint chlorination for ammonia treatment, slow mix flocculation and lamella
clarifier to remove solids, filter press for solids devvatering, off-site disposal of residual solids and sludge
materials, GAC to ensure clarity, UV transmittance, and remove VOCs, and UV photo-oxidation for
NDMA destruction. The waste liquids and residual solids/sludges generated during DAPL treatment are
assumed to be non-hazardous waste, but would be further characterized prior to off-site disposal. DAPL
would be removed to the extent practicable based on measured concentrations meeting the definition of
DAPL. DAPL has been defined as having specific gravity greater than 1.025; other parameters including
metals, anions, and geochemistry are also indicative of DAPL (see Section E, Conceptual Site Model,
Nature and Extent of Contamination, OU3 DAPL in Part 2 of this ROD, above). This definition will be
re-evaluated as part of the RD phase.
O&M would include monitoring to assure that the extraction pumps arc operating properly, the treatment
components arc in proper operation, the activated carbon, pumps, tubing, and other consumable
components arc changed/replaced as needed, and compliance monitoring for air emissions and treated
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water are being performed. O&M would also include routine inspections of extraction system
components, including pumps, pump enclosure vaults, system controls, communication equipment,
piping, storage tank(s), and tanker truck loading station(s), and periodic evaluation and adjustment of
pumping rates. Mitigation would be required for any alteration of the 1 (K)-year and 500-year floodplains
and/or wetlands from the installation, operation, and maintenance of the DAPL and groundwater
extraction and treatment system(s). Well and piping locations, as well as the location of the treatment
system(s), would need to be designed so as to not interfere with the remedial infrastructure required for
the soil, sediment, LNAPL, and surface water components (see above) of the selected remedy.
The three action alternatives also include Institutional Controls to prohibit residential, school, and daycare
use of the Property, prevent disturbance of any engineered systems and any new and existing remedy
infrastructure components, and prohibit the use of contaminated groundwater within the OU3
groundwater study area unless it can be demonstrated to EPA, in consultation with the Commonwealth,
that such use will not pose an unacceptable risk to human health and the environment, cause further
migration of the groundwater contaminant plume, or interfere with the remedy. Five Year Reviews
would be required since contamination would be left in place.
A more complete, detailed presentation of each DAPL and groundwater hot spot alternative may be found
in Section 4.0 of the FS Report Volume II and Section VII of the FS Report Volume III.
Alternative DAPL/GYVHS-1: No Action
As required by CERCLA and the NCP, Alternative DAPL/GWHS-1 was developed as a baseline for
comparing the effectiveness of the other remedial alternatives to address DAPL and groundwater hot
spots. No further action would be taken to address DAPL or groundwater contamination. The No Action
Alternative does not include active remediation or Institutional Controls and the current level of DAPL
contamination and level of contaminants in groundwater are assumed to remain unchanged. No
construction would take place, and RAOs would not be achieved. As required by CERCLA, Five Year
Rev iews would still be performed as part of the No Action Alternative. Except for the cost of statutorily-
required Five Year Reviews, there is no cost associated with this alternative - the capital cost for this
alternative is SO, the annual O&M cost is SO, and the net present value is $0.
Alternative DAPL/GWHS-2: DAPL extraction (approx. 5 wells), groundwater hot spot extraction
targeting 11,000 ng/L NDMA contour (approx. 2-3 wells), and treatment at new treatment
system(s)
Alternative DAPL/GWHS-2 is shown on Figure 30 in Appendix C of this ROD. Alternative
DAPL/GWHS-2 includes the construction and operation of a DAPL extraction system, with
approximately one well in the Off-Property Jewel Drive DAPL pool, approximately one well in the
Containment Area DAPL pool, and approximately three wells in the Main Street DAPL pool, the exact
number, location, and configuration of which would be based on PDIs. For the Main Street DAPL pool,
multiple extraction wells would be used to target bedrock low points and to prov ide adequate coverage
across the entire DAPL pool area. It is assumed that 5% of the accessible DAPL volume would not be
captured by the extraction system; to address 95% of the DAPL, the Off-Property Jewel Drive well is
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estimated to require on the order of 12 years of operation, the Containment Area well is estimated to
require on the order of three years of operation, and the Main Street wells are estimated to require on the
order of 20 years of operation. In total. Alternative DAPL/GWHS-2 is estimated to operate for 20 years,
would remove 14.1 million gallons of DA PL from the aquifer, and would generate approximately 15,705
tons of sludge and soil residuals for off-site disposal as a result of DAPL treatment.
This alternative also includes construction and operation of a groundwater extraction system, with
approximately two-three new, deep overburden wells targeting the 11,000 ng/L NDMA contour (the exact
number, location, and configuration of which would be based on PDIs), to remove and treat the mass of
contaminants in groundwater hot spots in the areas downgradient of the Main Street DAPL pool. Under
this alternative, it is expected that the new wells would be installed in the general vicinity of existing
wells GW-58D, GW-83D, and GW-84D. Extracted DAPL and groundwater would be treated at a newly
constructed treatment system or systems (potentially the same system(s) as for Alternatives LNAPL/SW-
2, -3, and -4, see above) and discharged to surface water. In order to implement this alternative, it is
expected that a new access road would be constructed in the MMB wetlands to the area around GW-83D
and GW-84D, and the marshy area around GW-58D. Based on a constant combined extraction rate of 20-
30 gpm, Alternative DAPL/GWHS-2 is estimated to operate for approximately 1.5-2.5 years and would
remove approximately 17.1 million gallons of contaminated hot spot groundwater.
In all. Alternative DAPL/GWHS-2 is estimated to remove 4,159 grams (g) of NDMA from overburden
groundwater and the DAPL pools. The estimated construction time for this alternative is two to three
years: the time to achieve RAOs is estimated to be on the order of 20 years. The estimated capital cost for
this alternative is $10.3 million, the annual O&M cost is $21.7 million, and the net present value is $22.5
million.
DAPL/GWHS-3: DAPL extraction (approx. 20 wells), groundwater hot spot extraction targeting
5,000 ng/L NDMA contour (approx. 6 wells), and treatment at new treatment system(s) (This is
EPA '.v Selected Alternative.)
Alternativ e DAPL/GWHS-3 is shown on Figures 31 and 32 in Appendix C of this ROD. Alternative
DAPL/GWHS-3 (EPA's Selected Alternative for DAPL and groundwater hot spots) includes the
construction and operation of a DAPL extraction system, with approximately four wells in the Off-
Property Jewel Drive DAPL pool, approximately four wells in the Containment Area DAPL pool, and
approximately 12 wells in the Main Street DAPL pool, the exact number, location, and configuration of
which would be based on PDIs. Multiple extraction wells in each DAPL pool would serve to minimize
drawdown, provide flexibility with pumping rates, and target bedrock low points identified during the
PDI activities of the RD phase. It is assumed that 5% of the accessible DAPL volume would not be
captured by the extraction system; to address 95% of the DAPL, the Off-Property Jewel Drive wells arc
estimated to require on the order of 3.5 years of operation, the Containment Area wells are estimated to
require on the order of one year of operation, and the Main Street wells are estimated to require on the
order of six years of operation. In total, EPA's Selected Alternative for DAPL and groundwater hot spots
is estimated to operate for six years, is expected to remove 14.8 million gallons of DAPL from the
aquifer, and generate approximately 16,531 tons of sludge and soil residuals for off-site disposal as a
result of DAPL treatment.
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This alternative also includes construction and operation of a groundwater extraction system, with
approximately six new, deep overburden extraction wells to remove and treat the mass of contaminants
within the area of groundwater that targets the 5,000 ng/L contour. The exact number, location, and
configuration of the extraction wells would be based on PDIs. Under this alternative, it is expected that
the new wells would include approximately three new extraction wells near existing wells GW-58D, GW-
83D, and GW-84D; approximately one new extraction well in the general vicinity of well GW-85D; and
approximately two new extraction wells in the Main Street DAPL area, screened in the hot spot
groundwater layer over the DAPL surface.
Extracted DAPL and groundwater would be treated at a newly constructed treatment system or systems
(potentially the same system(s) as for Alternatives LNAPL/SW-2, -3, and -4, see above) and discharged
to surface water. In order to implement this alternative, it is expected that a new access road would be
constructed in the MMB wetlands to the areas around wells GW-83D, GW-84D, and GW-85D, and the
marshy area around well GW-58D. Based on a constant combined extraction rate from the six wells of 60
gpm (10 gpm each). Alternative DAPL/GWHS-3 is estimated to operate for approximately 6.5 years and
would remove approximately 68.4 million gallons of contaminated hot spot groundwater.
In all, EPA's Selected Alternative for DAPL and groundwater hot spots is estimated to remove 7,013 g of
NDMA from overburden groundwater and the DAPL pools. The estimated construction time for this
alternative is two to three years; the time to achieve RAOs is estimated to be on the order of 8 years. The
estimated capital cost for this alternative is $15.6 million, the annual O&M cost is $24.6 million, and the
net present value is $35.5 million.
DAPL/GWHS-4: DAPL extraction (approx. 20 wells), groundwater hot spot extraction targeting
1,100 ng/L NDMA contour (approx. 12 wells), and treatment at new treatment system(s)
Alternative DAPL/GWHS-4 is shown on Figure 33 in Appendix C of this ROD. Similar to EPA's
Selected Alternative for DAPL and groundwater hot spots. Alternative DAPL/GWHS-4 includes the
construction and operation of a DAPL extraction system, with approximately four wells in the Off-
Property Jewel Drive DAPL pool, approximately four wells in the Containment Area DAPL pool, and
approximately 12 wells in the Main Street DAPL pool, the exact number, location, and configuration of
which will be based on PDIs. Multiple extraction wells in each DAPL pool would serve to minimize
drawdown, provide flexibility with pumping rates, and target bedrock low points identified during the
PDI activities of the RD phase. It is assumed that 5% of the accessible DAPL volume would not be
captured by the extraction system; to address 95% of the DAPL, the Off-Property Jewel Drive wells are
estimated to require on the order of 3.5 years of operation, the Containment Area wells are estimated to
require on the order of one year of operation, and the Main Street wells are estimated to require on the
order of six years of operation. In total, Alternative DAPL/GWHS-4 is estimated to operate for six years,
is expected to remove 14.8 million gallons of DAPL from the aquifer, and generate approximately 16,531
tons of sludge and soil residuals for off-site disposal as a result of DAPL treatment.
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This alternative also includes construction and operation of a groundwater extraction system, with
approximately 12 new, deep overburden extraction wells (the exact number, location, and configuration
of which will be based on PDIs) to remove and treat the mass of contaminants in groundwater containing
NDMA within the 1,100 ng/L contour interval. Under this alternative, it is expected that the new wells
would include approximately three new extraction wells in the general vicinity of existing wells GW-
58D, GW-83D, and GW-84D; approximately one new extraction well in the general vicinity of well GW-
85D; approximately four new extraction wells in the Main Street DAPL area, screened in the hot spot
groundwater layer over the DAPL surface; approximately two new extraction wells between the Off-
Property Jewel Drive and Main Street DAPL pools; approximately one well in the general area around
monitoring well GW-413D; and approximately one on-Property well in the general vicinity of well GW-
55D.
Extracted DAPL and groundwater would be treated at a newly constructed treatment system or systems
(potentially the same system(s) as for Alternatives LNAPL/SW-2, -3, and -4, see above) and discharged
to surface water. In order to implement this alternative, it is expected that a new access road would be
constructed in the MMB wetlands to the areas around wells GW-83D, GW-84D, and GW-85D, the
wetland area around well GW-55D, and the marshy area around well GW-58D. Based on a constant
combined extraction rate from the 12 wells of 120 gpm (10 gpm each). Alternative DAPL/GWHS-4 is
estimated to operate for approximately 8 years and would remove approximately 110.3 million gallons of
contaminated hot spot groundwater.
In all. Alternative DAPL/GWHS-4 is estimated to remove 7,320 g of NDMA from overburden
groundwater and the DAPL pools. The estimated construction time for this alternative is two to three
years; the time to achiev e RAOs is estimated to be on the order of 8 years. The estimated capital cost for
this alternative is $19.3 million, the annual O&M cost is $26.5 million, and the net present value is $40.5
million.
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 remedial alternatives. Building upon these specific statutory mandates, the NCP
articulates nine ev aluation criteria to be used in assessing the individual remedial alternatives.
A detailed analysis was performed on the DAPL, groundwater hot spots, LNAPL, surface water, soil and
sediment alternatives using the nine evaluation criteria in order to select an interim site remedy for DAPL
and groundwater hot spots and a final site remedy for LNAPL, surface water, soil, and sediments. The
comparative analysis of alternatives was presented in the FS Report Volume III. The following is a
summary of the comparison of each alternativ e's strength and weakness with respect to the nine
evaluation criteria. These criteria are summarized as follows;
Threshold Criteria
The two threshold criteria described below must be met in order for the alternatives to be eligible for
selection in accordance with the NCP.
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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 arc 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 O&M costs, as well as present-worth costs.
Modifying Criteria
The two 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 described in the Proposed Plan and RI/FS, 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.
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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 the FSReport Volume III, and attached to this ROD as Table K-l in Appendix
B
This 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. A summary of the
modifying criteria for Alternatives DAPL/GWHS-3, LNAPL/SW-3, and S01L/SED-2 can be found at the
end of this section.
Comparative Analysis of Alternatives for an Interim Action for DAPL and Groundwater Hot Spots
Overall Protection of Human Health and the Environment
The No Action Alternative (DAPL/GWHS-1) provides no protection of human health or the environment.
This alternative would not reduce the potential for human exposure to DAPL or contaminated Site
groundwater. No controls would be put in place to prevent human exposure to groundwater containing
COCs above levels that pose an unacceptable risk. No controls would be put in place on DAPL or
groundwater migration; remaining DAPL would be a continuing source of contamination to the aquifer,
and hot spot groundwater would continue to migrate, causing potential plume expansion and impacts to
downgradient groundwater and surface water.
Alternatives DAPL/GWHS-2 through -4 are protective of human health and the environment. These
alternativ es remove uncontrolled DAPL sources, a major source of contamination to downgradient
groundwater, and prohibit the use of groundwater in the OU3 groundwater study area unless it can be
demonstrated to EPA, in consultation with the Commonwealth. that such use will not pose an
unacceptable risk to human health and the env ironment, cause further migration of the groundwater
contaminant plume, or interfere with the remedy via Institutional Controls. Groundwater hot spot
extraction and treatment is included in these alternatives, which reduces risk to potential downgradient
receptors by capturing hot spot groundwater that would otherwise migrate uncontrolled and that acts as a
source of contamination.
Alternatives DAPL/GWHS-2 through -4 will require Five Year Reviews since each will leave
contamination in place that exceeds unrestricted use risk standards. The time to achieve RAOs for
Alternatives DAPL/GWHS-2 through -4, ranked from longest to shortest time frames are DAPL/GWHS-
2 (approximately 20 years), and DAPL/GWHS-3 and -4 (both approximately 8 years). Groundwater
restrictions arc expected to be in place until final groundwater cleanup levels are identified and achieved
in a future, final groundwater remedy for the Site.
Compliance with ARARs
The remedial action alternatives for DAPL and groundwater hot spots arc interim actions that will be
evaluated against the RAOs specified in Part 2, Section H of this ROD, above. As interim actions, these
alternatives are not expected to attain chemical-specific ARARs, and thus cleanup levels have not been
set for these groundwater actions based on chemical-specific ARARs. The achievement of chemical-
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specific ARARs in groundwater within the aquifer will be addressed in a future, final remedial action that
addresses the restoration of groundwater. The proposed interim remedial actions for groundwater will
support the final groundwater remedial action.
No activities would be performed under the No Action Alternative (DAPL/GWH S-1), therefore, action-
and location-specific ARARs do not apply. With proper implementation, it is anticipated that
Alternatives DAPL/GWHS-2 through -4 would meet action- and location-specific ARARs. Alternatives
DAPL/GWHS-2, -3, and -4 would all meet ARAR requirements for minimization of impacts, mitigation
of any alteration of 1 (K)-year and 500-year floodplains and/or wetlands from the installation and
maintenance of extraction and monitoring wells, piping systems, access roads, and staging areas, and
restoration of flood storage capacities, if necessary, following completion of remedial activities. Action-
specific ARARs would be met under Alternatives DAPL/GWHS-2 through -4 for the treatment and
disposal/discharge of extracted DAPL and groundwater.
Long-Term Effectiveness and Permanence
The No Action Alternative (DAPL/GWHS-1) would not decrease the risks to human health and the
environment. This alternative will have the highest risk due to the lack of Institutional Controls or plume
containment.
Alternatives DAPL/GWHS-2 through -4 rely on Institutional Controls to prevent exposure to
contaminated groundwater and use groundwater hot spot and DAPL extraction to intercept the plume and
remove source material, thus reducing contaminant toxicity and mobility. Of these three alternatives.
Alternatives DAPL/GWHS-3 and -4 are expected to have good long-term effectiveness and permanence
and would be more effective in the long-term than Alternative DAPL/GWHS-2, as the former will
achieve the removal of an estimated 5% more DAPL (an estimated 14.8 million gallons of DAPL for
Alternatives DAPL/GWHS-3 or -4 as compared to an estimated 14.1 million gallons of DAPL for
Alternative DAPL/GWHS-2) by using more extraction wells to reduce the number of isolated low points
within the DAPL pools, which further reduces residual risk.
Alternative DAPL GWHS-4 would be somewhat more effective in the long-term than EPA's Selected
Alternative for DAPL and groundwater hot spots, which would be more effective than Alternative
DAPL/GWHS-2, as Alternative DAPL/GWHS-4 targets the lowest groundwater NDMA concentrations
(the 1,100 ng/L NDMA contour, versus the 5,000 ng/L NDMA contour targeted by EPA's Selected
Alternative and the 11,000 ng/L NDMA contour targeted by Alternative DAPL/GWHS-2) and thus leaves
the smallest mass of contamination unaddressed and provides the most control over groundw ater
contaminant sources and migration. All three action alternatives would provide a high degree of
resilience to the long-term effects of extreme weather events, as the sources are well below ground
surface and therefore insulated and it is presumed the treatment system will not be constructed within an
area at risk of flooding during an extreme weather event. Treatment residuals formed under the
DAPL/GWHS-2, -3, and -4 alternatives can be properly managed and pose minimal risk.
Reduction in Contaminant Toxicity, Mobility, or Volume through Treatment
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The No Action Alternative (DAPL/GWHS-1) does not include any treatment, and thus provides no
reduction in toxicity, mobility, or volume through treatment. All of the remaining alternatives provide for
treatment of DA PL and groundwater contamination.
Alternatives DAPL/GWHS-2 through -4 provide for DAPL extraction from the subsurface, reducing its
mobility and v olume. DAPL treatment would remove Site COCs and reduce the volume of DAPL to a
sufficient volume that it is a solid suitable for off-site transportation/disposal. The DAPL and
groundwater hot spot treatment design would be refined during the RD phase. Conceptually, it is
assumed that such treatment will generally include the following components: treatment for DAPL
consisting of lime precipitation to remove metals, devvatering of sludges, stripping of VOCs and
ammonia, UV photo-oxidation for NDMA destruction, and evaporation of remaining water and off-site
disposal of the resulting residual solids; and additional treatment for hot spot groundwater (see below).
Of the three action alternatives. Alternatives DAPL/GWHS-3 and -4 provide for a greater reduction of
COC toxicity, mobility, or volume through treatment as compared to Alternative DAPL/GWHS-2
because more DAPL would be removed (an estimated 14.8 million gallons under Alternatives
DAPL/GWHS-3 or -4 versus an estimated 14.1 million gallons under Alternative DAPL/GWHS-2),
resulting in a smaller amount of DAPL remaining in the subsurface following extraction.
Alternatives DAPL/GWHS-2 through -4 also provide for extraction of hot spot groundwater, which
would be treated with a hypochlorite flash mixer for oxidation and removal of metals, breakpoint
chlorination for ammonia treatment, sediment removal and consolidation, GAC, UV photo-oxidation,
dewatering of solids, and off-site disposal of residual solids and sludge materials. Of the three action
alternatives, Alternatives DAPL/GWHS-3 and -4 provide for the best reduction of COC toxicity,
mobility, or volume through treatment as compared to Alternative DAPL/GWHS-2 because a greater
v olume of contaminated groundwater will be removed and treated (an estimated 68.4 million gallons
under EPA's Selected Alternative and an estimated 110.3 million gallons under Alternative
DAPL/GWHS-4 versus an estimated 17.1 million gallons under Alternative DAPL/GWHS-2).
Alternatives DAPL/GWHS-3 and -4 will remove a greater mass of NDMA (an estimated 7,320 g for
Alternative DAPL/GWHS-4 and an estimated 7,013 g for EPA's Selected Alternative) than Alternative
DAPL/GWHS-2 (an estimated 4,159 g) from overburden groundwater and the DAPL pools. These two
alternatives address the largest volumes of groundwater, resulting in the most control over groundwater
migration of all the alternativ es considered, however, extraction and treatment of the largest v olume of
groundwater will result in the largest v olume of treatment residuals requiring disposal, as compared to
Alternative DAPL/GWHS-2.
Generally, the treatment technologies associated with DAPL and hot spot groundwater arc well-proven
and irreversible, however, for DAPL, additional design work and treatability studies will take place
during the PDI stage to finalize the design of the treatment process. Overall. Alternatives DAPL/GWHS-
3 and -4 prov ide for the highest reductions of COC toxicity, mobility, or volume through treatment, and
Alternative DAPL GWHS-2 provides for a lower reduction.
Short-Term Effectiveness
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While the No Action Alternative (DAPL/GWHS-1) will not be effective in the short-term in protecting
human health or the environment, because no remedial activities will occur, there will be no adverse
impacts to the public or workers performing the cleanup, or the env ironment.
Of the three action alternatives. Alternative DAPL'GWHS-2 would be somewhat more effective in the
short-term than EPA's Selected Alternative for DAPL and groundwater hot spots, which would be more
effective than Alternative DAPL/GWHS-4, as the number of extraction wells increases under succeeding
alternatives, with increasing impacts to the environment from well drilling and associated construction
activities and piping installations (an estimated 7-8 wells, 26 wells, and 32 wells under Alternatives
DAPL-GWHS-2, -3, and -4, respectively).
All of these alternatives are expected to pose minimal risk to the community from well drilling and
associated general construction activities, treatment of DAPL and hot spot groundwater, and transport and
disposal of residual wastes. Limited short-term impacts to the community would include an increase in
traffic during construction activities, but these would be minimized as much as possible via use of best
management practices. These alternatives also pose low risk to workers from exposure to collected
DAPL, hot spot groundwater, and treatment residuals. While construction time for the action alternativ es
is estimated to be 2-3 years, generally, risks to workers and the community would be minimized via use
of best management practices.
The estimated timeframe to remove DAPL under Alternative DAPL/GWHS-2 is approximately 20 years;
under this alternative an estimated two to three years would be required to address the target NDMA
groundwater concentration of 11,000 ng/L. The estimated timeframe to remove DAPL under Alternatives
DAPL/GWHS-3 or -4 is approximately six years; under EPA's Selected Alternative an estimated 6.5
years would be required to address the target groundwater NDMA concentrations of 5,000 ng/L and under
Alternative DAPL/GWHS-4 an estimated eight years would be required to address the target groundwater
NDMA concentration of 1,100 ng/L. However, for the three action alternatives, the risk of human
exposure to DAPL and contaminated groundwater is expected to be addressed upon implementation of
Institutional Controls. Additionally, risks from exposure to treatment residuals can be readily controlled.
Construction of the DAPL and groundwater hot spot extraction and treatment system(s) is expected to
have low impacts to the community and workers, as the work will be conducted on the Property and/or
within the bounds of secured property nearby and best management practices will be used to mitigate any
issues. Installation of new wells and infrastructure is expected to have minor, short-term impacts to the
environment; no environmentally sensitive areas have been identified in the likely areas of intrusive work
for DAPL, however, all of the action alternatives include one or more extraction wells and piping in
MMB wetlands to collect hot spot groundwater. All of the action alternatives include piping systems in
MMB wetlands, with the MMB wetlands piping systems under Alternativ es DAPL/GWHS-3 and -4 the
most extensive. However, for these three action alternatives, wells and piping would be installed in a
manner so as to minimize impacts, and use of best management practices during the work would also
serve to minimize environmental impacts in this sensitive area.
Iniplementability
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The No Action Alternative (DAPL/GWHS-1) is the easiest to implement because it does not involve the
construction, operation, or maintenance of remedial systems or enforcement of Institutional Controls.
The remaining alternatives all use standard construction equipment and there are no infrastructure issues;
no issues are anticipated regarding the availability of treatment, storage, and disposal facilities (TSDFs)
for waste solids and other treatment residuals. Alternatives DAPL/GWHS-2, 3, and 4 would all require
access to private property to install extraction wells and conveyance pipes. DA PL and groundwater
extraction is a reliable technology and allows for optimization, increasing the reliability. Groundwater
extraction, treatment, and discharge are relatively routine tasks and the equipment and services required
for implementation are readily available.
Implementation of Alternatives DAPL/GWHS-3 and -4 would be more challenging because these
alternatives require the placement of groundwater extraction wells directly above the DAPL pools to
extract hot spot groundwater. Extraction strategies and well designs would be explored during the PDI
phase and incorporated into the RD to optimize the performance of groundwater hot spot extraction.
DAPL extraction has been implemented at the Site and prov en effective and sustainable at a pumping rate
of 0.25 gpm, however, the feasibility of DAPL treatment will require treatability (bench-scale) testing as
part of a PDI. The DAPL treatment train may be less reliable than treatment of hot spot groundwater.
Planned monitoring of the treatment system(s) and nature and extent of DAPL and groundwater hot spots
will assess remedy effectiveness; however, the ability to monitor remedy effectiveness for Alternative
DAPL/GWHS-4 is slightly more difficult, as there are fewer monitoring wells available north of the
Property (due to barriers limiting access such as railroad corridors) which would be necessary to gauge
the effectiveness of this alternative in targeting the groundwater 1,100 ng/L NDMA contour.
Institutional Controls under all three action alternatives can be administratively challenging, however,
they can be implemented and completed quickly with adequate planning.
The additional extraction wells under Alternative DAPL/GWHS-4 (an estimated 32 wells total, as
compared to an estimated 26 wells under EPA's Selected Alternative for DAPL and groundwater hot
spots) may pose installation challenges. Overall, of the three action alternatives. Alternatives
DAPL/GWHS-2 and -3 have high implementability and the implementability of Alternative
DAPL/GWHS-4 is somewhat lower.
Costs
The costs for all alternatives arc presented in Table K-l in Appendix B of this ROD. The range in
estimated cost for all four alternatives is from $0 for Alternative DAPL/GWHS-1 to $40.5 million for
Alternative DAPL/GWHS-4. Specifically, the overall costs for Alternatives DAPL/GWHS-2, -3, and -4
arc $22.5 million, $35.5 million, and $40.5 million, respectively.
Alternative DAPL GWHS-2 has the lowest capital costs ($10.3 million, as compared to $15.6 million for
EPA's Selected Alternative and $19.3 million for Alternative DAPL/GWHS-4) but O&M costs of over
$20 million, which is comparable to the O&M costs of Alternatives DAPL/GWHS-3 and -4. Of
Alternatives DAPL/GWHS-2 and -3, Alternative DAPL/GWHS-2 has the lower capital costs, O&M
costs, and overall costs.
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Comparative Analysis of Alternatives for a Final Action for LNAPL and Surface Water
Overall Protection of Human Health and the Environment
The No Action Alternative (LNAPL/SW-1) provides no protection of human health and the environment.
No action would be taken to address LNAPL, which would result in ongoing releases to East Ditch
Stream. In addition, no actions would be taken to stop the overburden groundwater contaminant plume
from continuing to impact East, South, and Off-Property West Ditch Streams. These releases would
result in ongoing adverse impacts to the ecological habitat in and adjacent to these streams.
Alternatives LNAPL/SW-2 and -3 arc protective of human health and the environment. Both utilize MPE
wells to extract LNAPL and contaminated groundwater, preventing the release of LNAPL into East Ditch
Stream, as well as using groundwater extraction wells to prevent the overburden groundwater plume from
impacting Site surface water. Both alternatives would include treatment to remove the LNAPL material
and Site COCs from groundwater to levels protective of the streams prior to discharge of extracted
groundwater to surface drainage.
Alternative LNAPL/SW-4 is also protective of human health and the environment. This alternative
includes excavation and off-site disposal to completely remove the LNAPL, along with continued
operation of the three extraction wells along East Ditch Stream, preventing releases to East Ditch Stream.
This alternative also includes the use of targeted PRBs to treat groundwater in-situ to protective levels
prior to the groundwater flowing into South and Off-Property West Ditch Streams. This alternative is
protective of human health and the environment. Alternative LNAPL/SW-4 would prevent exposure of
current and future ecological receptors to surface water containing Site COCs that would result in
potential adv erse impacts. Short-term continued operation of Plant B is assumed for this alternative until
the new groundwater hot spot treatment system or systems (the same as for the DAPL and groundwater
hot spots, see above) is constructed and operational. At this point, groundwater extracted from the three
wells along East Ditch Stream would be re-routed to the new groundwater treatment system(s). If Plant B
were to be shut down prior to construction of the new treatment system(s), an evaluation of Site
hydrogeology would be performed first to ensure continued protection of human health and the
environment, which might result in the identification of a need for additional extraction wells and/or PRB
segments along East Ditch Stream.
Alternativ es LNAPL/SW-2 through -4 will require Five Year Rev iews since each will leave
contamination in place that exceeds unrestricted use risk standards. A 30-year timeframe was used for
O&M, monitoring, and cost estimation purposes for the LNAPL and surface water final action.
Compliance with ARARs
The remedial action alternatives for LNAPL and surface water are final actions that will be evaluated
against the RAOs specified in Part 2, Section H of this ROD, above. All of the alternatives, except for
the No Action Alternative (LNAPL/SW-1), have been developed to comply with ARARs. There are no
chemical-specific ARARs for the LNAPL/SW alternatives. Alternative LNAPL/SW-1 would not meet
action- and location-specific ARARs since no removal or containment would occur to address LNAPL
and Site COCs in groundwater that impact surface water. With proper implementation, it is anticipated
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that Alternatives LNAPL/SW-2 and -3 would meet action- and location-specific ARARs. Under these
two alternatives, LNAPL would be removed to the extent practicable, and proposed site-specific surface
water performance standards derived from NRWQC (to address ecological risks) and To-Be-Considercd
(TBC) guidance (to address human health risks) will be used to monitor surface water to ensure that the
groundwater extraction and treatment are successful in reducing COC levels in surface water to be
protective of sensitiv e receptors (benthic invertebrates). Both alternatives include treatment to remove the
LNAPL material and Site COCs from groundwater. Under these alternatives, the effluent from the
treatment system(s) will be treated prior to any discharges to the streams. Action-specific ARARs would
be met under Alternatives LNAPL/SW-2 and -3 for the treatment and disposal/discharge of extracted
LNAPL and surface water. In addition, any impacts to wetlands from the construction of the remediation
systems would be mitigated, thus meeting location-specific ARARs.
With proper implementation, it is anticipated that Alternative LNAPL/SW-4 would also meet action- and
location-specific ARARs. This alternative includes excavation and off-site disposal to completely
remove the LNAPL. along with continued operation of the three extraction wells along East Ditch
Stream, preventing releases to East Ditch Stream. Proposed site-specific ecological surface water
performance standards derived from NRWQC would be used to monitor surface water to ensure that the
PRBs and extraction wells are successful in reducing COC levels in surface water to be protective of
ecological receptors. In addition, any impacts to wetlands from the construction of these systems would
be mitigated (thus achieving location-specific ARARs).
Alternatives LN APL/SW-2, -3, and -4 would all meet ARAR requirements for minimization of impacts,
mitigation of any alteration of 100-year and 500-year floodplains and/or wetlands from the installation
and maintenance of extraction and/or monitoring wells, piping systems, access roads, and staging areas,
and restoration of flood storage capacities, if necessary, following completion of remedial activities.
Long-Term Effectiveness and Permanence
The No Action Alternative (LNAPL/SW-1) would not decrease the risks to human health and the
env ironment. This alternative will have the highest risk due to the lack of Institutional Controls or
removal or treatment of LNAPL and contaminated groundwater.
Alternatives LNAPL/SW-2 and -3 would be effective in the long-term as they both would utilize MPE to
remove free-phase LNAPL and reduce COC levels in the smear zone. Under these alternatives,
groundwater containing Site COCs that would otherwise enter the streams would be permanently
removed and treated. Both alternatives would result in some residual risk as neither can remove all
LNAPL from soil pores and LNAPL sorbed to soil particles. However, Alternative LNAPL/SW-3 would
be more effective in the long-term than Alternative LNAPL/SW-2, with an estimated three to five MPE
wells versus an estimated one well under Alternative LNAPL/SW-2, as the expanded MPE system under
Alternative LNAPL/SW-3 would remove more of the LNAPL (LNAPL that is located under the Plant B
building) and thus result in less residual risk. Under Alternative LNAPL/SW-3, approximately 90% of an
estimated 12 gallons of mobile (floating) LNAPL would be removed. By contrast, under Alternative
LNAPL/SW-2, an estimated 65% of the mobile LNAPL would be removed. The LNAPL remediation
areas under the three action alternatives for LNAPL and surface water are located outside of the 100-year
and 500-year floodplains - thus an evaluation of these remedial alternatives' degree of resiliency to
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extreme weather events is not expected to be relevant. With respect to the surface water alternatives, the
groundwater extraction under Alternative LNAPL/SW-2 and EPA's Selected Alternative (LNAPL/LW-3)
would have a higher degree of resilience to the effects of extreme flood events as the majority of the
remedial infrastructure is located below the ground surface. Alternative LNAPL/SW-4 would also be
more resilient to the effects of extreme weather events because it involves a passive system (PRBs) with
minimal aboveground infrastructure. Alternative LNAPL/SW-4 would be the most effective in the long-
term, as nearly all residual LNAPL would be removed by excavation.
The MPE and groundwater extraction and treatment systems under Alternatives LNAPL/SW-2, -3, and -4
would permanently remove and treat groundwater containing Site COCs that would otherwise enter the
streams. However, in order to have long-term effectiveness, continuous efforts to operate the systems are
required. Treatment residuals formed under the LNAPL/SW-2 and -3 alternatives can be properly
managed and pose minimal risk. For Alternative LNAPL/SW-4, the PRBs would convert the COCs to
less toxic contaminants. The PRBs would not require any day-to-day operation and maintenance;
however, over time the reactive media within the barrier may become spent and require replacement.
Except for the No Action Alternative (LNAPL/SW-1), all of the alternatives include Institutional Controls
to prevent exposure while the remedy is implemented.
Reduction of Contaminant Toxicity, Mobility, or Volume through Treatment
The No Action Alternative (LNAPL/SW-1) does not include any treatment, and thus provides no
reduction in toxicity, mobility, or volume through treatment. All of the remaining alternatives provide for
treatment and/or removal of LNAPL and groundwater contamination that affects surface water quality.
Alternatives LNAPL/SW-2 and -3 provide for a permanent removal of Site COCs in groundwater through
treatment. The groundwater treatment design (the same as for the groundwater hot spots, see above)
would be refined during the RD phase, and would generally consist of a hypochlorite flash mixer for
oxidation and removal of metals, breakpoint chlorination for ammonia treatment, sediment removal and
consolidation, GAC, UV photo-oxidation, and dewatcring of solids. Alternative LNAPL/SW-2, utilizing
one MPE well, is estimated to capture eight gallons of mobile LNAPL (65% of the estimated 12 gallons
of mobile LNAPL), which would be sent off-site for disposal. This alternative also includes collection
and treatment of soil vapor and groundwater from the MPE well. Generally, groundwater treatment is
well-proven and irreversible, however, there are waste materials from the treatment systcm(s) including
solids from the filter press and used activated carbon. Treatment would achieve both water and air
discharge standards. Alternative LNAPL/SW-3 provides for more reduction of toxicity, mobility, or
volume, as it utilizes five MPE wells to capture and treat soil vapor and groundwater. This alternative is
estimated to capture 11 gallons of mobile LNAPL (90% of the estimated 12 gallons of mobile LNAPL),
including material under Plant B, which will be taken off-site for disposal. Metrics to govern the
termination of MPE will be determined during the PDI phase. Again, groundwater treatment is
irreversible and similar waste materials would be generated.
Alternative LNAPL/SW-4 includes the excavation of 390 tons of soil. This soil will not be treated and
may require disposal as hazardous waste. However, there may be some reduction of pollutant mobility
through the addition of bulking agents to facilitate off-site disposal of the excavated material. This
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alternative also utilizes PRBs and the three existing extraction wells along East Ditch Stream to treat
groundwater, reducing its toxicity, prior to it flowing into streams. If Plant B were to be shut down prior
to construction of the new groundwater treatment system(s), an evaluation of Site hydrogeology might
result in the identification of a need for additional extraction wells and/or PRE segments along East Ditch
Stream. After the PRBs have reached the end of their useful life, the material (activated carbon and
zeolite) would need to be removed and replaced. Overall, Alterative LNAPL/SW-3 provides for the
greatest reduction of contaminant toxicity, mobility, or v olume through treatment.
Short-Term Effectiveness
While the No Action Alternative (LNAPL/SW-1) will not be effective in the short-term in protecting
human health or the environment, because no remedial activities will occur, there will be no adverse
impacts to the public or workers performing the cleanup, or the environment.
Alternatives LNAPL/SW-2 and -3 are expected to pose minimal risk to the community from well drilling
and associated general construction activities, treatment of groundwater, O&M, and transport and
disposal of collected LNAPL and residual wastes from groundwater treatment. These alternatives also
pose very low risk to workers and risks from collected LNAPL and treatment residuals can be minimized
by the use of best management practices. The risk of human exposure to contaminated groundwater is
expected to be addressed upon implementation of Institutional Controls. An estimated one year is the
timeframe for remediating LNAPL under Alternatives LNAPL/SW-2 through -4. Construction of the
groundwater extraction and treatment system(s) is expected to have low impacts to the community and
workers, as the work will be conducted on the Property and/or within the bounds of secured property
nearby and best management practices will be used to mitigate any issues. Installation of new wells and
infrastructure is expected to have minor, short-term impacts to the environment, and use of best
management practices during the work would serve to minimize environmental impacts in sensitive areas.
Groundwater extraction and treatment for Alternatives LNAPL/SW-2 through -4 will require resources
and material handling for an extended length of time. A 30-year timeframe was used for O&M,
monitoring, and cost estimation purposes for the surface water component.
Alternative LNAPL/SW-4 (soil excavation/stabilization and off-site disposal and PRBs and extraction
wells to treat groundwater) poses potential risks to the community from releases of vapor as well as
structural stability issues in excavating close to the MBTA railroad tracks. Best management practices
and technical controls (such as sheet piling) would mitigate these issues. Excavated soil and backfill
material would be transported through the community, posing a potential risk. Soil excavation also poses
the highest risks to workers from direct contact and inhalation of fugitive soil dusts. These issues can be
mitigated by the use of best management practices. Overall, this alternative has the greatest possible
short-term impacts, though is estimated to be constructed in less than one year. Construction of the PRBs
would require material to be transported off-site, but since this alternative is estimated to be for a short
duration, the overall impacts to the community arc low. Risks to workers during construction of the
PRBs are also low and could be minimized using best management practices. However, construction of
the PRBs would have significant short-term impacts to the environment as trenching (heavy construction)
will occur in sensitive areas. OveralI, Alterative LNAPL/SW-3 provides the best short-term
effectiveness.
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Implementabilitv
The No Action Alternative (LNAPL/SW-1) is the easiest to implement because it does not involve the
construction, operation, or maintenance of remedial systems or enforcement of Institutional Controls.
The remaining alternatives all use standard construction equipment and there are no infrastructure issues;
no issues are anticipated regarding the availability of TSDFs for waste solids and other treatment
residuals.
Groundwater extraction and treatment under Alternatives LNAPL/SW-2 and -3 is a reliable technology
and allows for optimization, increasing the reliability. Groundwater extraction, treatment, and discharge
are relatively routine tasks and the equipment and services required for implementation are readily
av ailable. Well designs and placement would be explored during the PDI phase and incorporated into the
RD to optimize the performance of groundwater extraction. Planned monitoring of the treatment
system(s) and nature and extent of COCs in surface water will assess remedy effectiveness.
The PRBs under Alternative LNAPL/SW-4 would require a PDI and bench-scale testing. Once
constructed, there is little post-construction flexibility and therefore less reliability compared to
groundwater extraction. Large quantities of reactive material are needed for the PRBs, requiring extra
lead time to ensure adequate supply during implementation.
Institutional Controls under all three action alternatives can be administratively challenging, however,
they can be implemented and completed quickly with adequate planning. Overall, of the three action
alternatives, Alternative LNAPL SW-3 is the most reliable and easiest to implement.
Costs
The costs for all alternatives are presented in Table K-l in Appendix B of this ROD. The range in
estimated cost for all four alternatives is from $0 for Alternative LNAPL/SW-1 to $9 million for
Alternatives LNAPL/SW-2 and -4. Specifically, the overall costs for Alternatives LNAPL/SW-2, -3, and
-4 are $9 million, $6.6 million, and $9 million, respectively.
Alternative LNAPL/SW-3 has the lowest capital costs ($2.3 million, as compared to $4.6 million for
Alternative LNAPL/SW-2 and $5.3 million for Alternative LNAPL/SW-4) and the highest O&M costs
($7.4 million, as compared to $6.5 million for Alternative LNAPL/SW-2 and $6.7 million for Alternative
LNAPL/SW-4). However, this alternative has the lowest overall costs.
Comparative Analysis of Alternatives for a Final Action for Soil and Sediments
Overall Protection of Human Health and the Environment
Under the No Action Alternative (SOIL/SED-1), no action would be taken to address exposure to soils
and leaching of Site COCs from soil to groundwater in the Containment Area. No action would be taken
to address contaminated upland soil; soil with concentrations of Site COCs above those allowed for
unrestricted use/unrestricted exposure would not be addressed. No active remediation would occur for
any type of soil, and RAOs would not be achieved. Additionally, no action would be taken to address
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exposure to wetland soil and sediments with concentrations of Site COCs above cleanup levels. No
active remediation would occur, and RAOs would not be achieved. Finally, no action would be taken to
address TMPs in soil. No controls would be put in place to prevent human exposure to TMPs. TMPs
would remain in place, and no controls would be put in place to prevent migration of TMP vapors.
Alternativ e SOIL SED-1 offers no protection of human health and the environment, and risks to current
and future users from direct exposure to contaminated soil or soil vapors, as well as ecological receptors,
including the American Robin, Marsh Wren, and other insect-eating birds, Short-Tailed Shrew, and
bcnthic invertebrate community, would remain.
Alternatives SOIL/SED-2 through -4 arc expected to provide protection of human health and the
environment by eliminating risks to human health from direct exposure to and inhalation of Site COCs,
and eliminating risks to ecological receptors from direct exposure and ingestion. Site Management Plans
(SMPs) and Institutional Controls would be incorporated into each of these alternativ es to address soil
remaining with concentrations above those allowed for unrestricted use/unrestricted exposure, prevent
disturbance of remedial measures, and restrict use to commercial/industrial.
Alternative SOIL/SED-2 includes a low-permeability cap that meets RCRA Subtitle D and Massachusetts
solid waste landfill performance standards above the contaminated soil in and near the Containment Area
to prev ent exposure and minimize leaching of soil COCs to groundwater. Although the alternative does
not inv olve remov al of soil from the Containment Area, the low-permeability cover coupled with the
slurry wall and closure of the equalization window would serve to minimize leaching.
Alternativ e SOIL/SED-2 also includes covering all upland soil areas containing elevated levels of Site
COCs above cleanup levels with clean soil, eliminating the exposure pathway for ecological receptors.
The soil covers would include long-term maintenance and repair and would be protected by Institutional
Controls to prevent disturbance of these soil covers. Under this alternative, all wetland soil and sediments
containing elevated levels of Site COCs above cleanup levels would be excavated and disposed of off-
site, eliminating future exposures for ecological receptors. The restoration of the excavated wetland soil
and sediment to existing grades would prevent the need for further wetland or flood storage mitigation
(other than restoring the surface to native wetland/aquatic habitat and restoring any access ways to the
excav ation areas). Finally, the Alternative SOIL/SED-2 includes additional vapor intrusion evaluations to
assess risks and/or the use of vapor barriers and/or sub-slab depressurization systems if buildings are
constructed or altered in areas containing soil contaminated with TMPs at levels that may pose a vapor
intrusion risk. Any engineered systems preemptively installed or otherwise determined to be necessary as
a result of the vapor intrusion evaluations would prevent the migration of soil vapors into buildings,
eliminating future exposures to indoor workers.
Alternativ e SOIL/SED-3 contains many of the same components as Alternative SOIL/SED-2, except it
would handle the upland soil contaminated with Site COCs above cleanup levels differently. With the
exception of TMPs, soil containing Site COCs above cleanup levels would be excav ated down to 1 ft,
backfilled, and then covered with either clean soil or asphalt, depending on the location. Soil containing
TMPs would be treated with air sparging and SVE. These technologies would eliminate exposure
pathways for ecological receptors and remove contaminants causing potential vapor intrusion issues.
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Alternative S01L/SED-4 applies excavation to all media. Containment Area and other upland soil
containing COCs above cleanup levels would be excavated down to 10 ft, then covered with clean soil.
This alternative would include treatment of water generated from excavations or dewatered soils, as
necessary, and discharge of treated water to surface water. All wetland soil and sediments containing
elevated levels of Site COCs above cleanup levels would be excavated and disposed of off-site,
eliminating future exposures for ecological receptors. This alternative includes backfilling and restoration
of the excavated areas, environmental monitoring, and implementation of Institutional Controls to
prohibit excavation or disturbance of these soils and restrict use to commercial/industrial.
Alternatives SOIL/SED-2 through -4 will require Five Year Reviews since each will leave contaminated
soil and/or sediments in place that exceeds unrestricted use risk standards. The time to achieve RAOs for
each of the three action alternatives is approximately two years.
Compliance with ARARs
The remedial action alternatives for soil and sediments are final actions that will be evaluated against the
RAOs specified in Part 2, Section H of this ROD, above. All of the alternatives, except for the No
Action Alternative (SOlL/SED-1), have been developed to comply with ARARs. Alternative SOIL/SED-
1 would not meet chemical-specific ARARs since it does not prevent exposure to contaminated soil, soil
vapors, or sediment. No activities would be performed under Alternative SOIL/SED-1, thus action-
specific and location-specific ARARs do not apply to this alternative. With proper implementation, it is
anticipated that Alternatives SOIL/SED-2, -3 and -4 would meet action-specific, location-specific, and
chemical-specific ARARs. Any impacts to wetlands from remedial work under the three action
alternatives would be mitigated, thus meeting location-specific ARARs. Alternatives SOIL/SED-2, -3,
and -4 would all meet ARAR requirements for minimization of impacts, mitigation of any alteration of
floodplains and/or wetlands that is unavoidable to implement the remedial measures, and restoration of
flood storage capacities, if necessary, following completion of remedial activities.
Alternative SOIL/SED-2 includes a low-permeability cap that meets RCRA Subtitle D and Massachusetts
solid waste landfill performance standards above the Containment Area, covering contaminated upland
soil areas with clean soil, excavating contaminated wetland soil and sediments, and conducting vapor
intrusion evaluations and/or using vapor barriers and/or sub-slab depressurization systems in new
construction in areas with soil containing TMPs at levels that may pose a vapor intrusion risk. The cap
for the Containment Area would comply with RCRA Subtitle D regulations and Massachusetts Solid
Waste Management Facility Regulations and meet impermeability requirements with an effective
permeability that is equivalent to the permeability of the existing slurry wall (approximately lxl0"8
centimeters per second (cm/sec)) or a permeability of no greater than lxlO7 cm/sec, whichever is less.
Excavated contaminated wetland soil and sediments determined to contain hazardous waste would be
managed in accordance with RCRA hazardous waste regulations.
Permanent or temporary wetlands loss and/or impacts to the 500-year floodplain due to construction of
the Containment Area cap, installation of covers in upland soil areas, excavation of wetland soil and
sediments, and construction of engineered vapor intrusion mitigation systems would comply with
location-specific ARARs through appropriate avoidance and minimization of impacts, and mitigation and
restoration activities. Impacted wetlands would be re-established following completion of remedial
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activities. Upon completion of excavation work in wetlands, erosion blankets would be installed, where
applicable, and wetland grass varieties would be seeded. Temporary erosion control best management
practices would be instituted until such time as natural systems recover. Plants and visible ground
surfaces would be inspected and maintained until plantings are fully established.
Through its analysis of alternatives, EPA has determined that construction of the Containment Area cap,
installation of covers in upland soil areas, excavation of wetland soil and sediments, and construction of
engineered vapor intrusion mitigation systems may, but is not likely to, result in temporary occupancy of
the 500-year floodplain, but after completion of work there will not be any net loss of flood storage
capacity. Additionally, based on the available data, EPA has determined that implementation of these
remedial alternatives will not result in the permanent occupancy and modification of the 500-year
floodplain. A stormwater study would be undertaken as part of these alternatives to confirm that this is
the case. If temporary impacts to the 500-year floodplain are found to be unavoidable while
implementing the alternatives, additional mitigation measures would be incorporated to address
temporary alteration of floodplains during remedial construction and any additional floodplain
impairment within the 500-year floodplain. Excavated materials would be managed so as to not
temporarily impair resources within the 500-year floodplain or adjacent wetlands, to the extent
practicable. Upon completion of work in floodplains and wetlands, the impacted areas would be
backfilled to original grade with clean soil (i.e., soil that meets appropriate screening levels) and restored
with native vegetation.
Alternative SOIL/SED-3 differs from Alternative SOIL SED-2 only in how the upland soil contaminated
with BEHP, chromium, and TMPs is handled (excavation for soils containing BEHP and chromium; and
air sparging and SVE to treat TMPs). Soil with concentrations of Site COCs above cleanup levels would
be removed and managed on-site in compliance with ARARs until disposed of at a permitted, off-site
facility. Chemical-specific ARARs were considered in the development of the cleanup levels for soils
and sediments.
Alternative S01L/SED-4, which applies excavation to all media, will also comply with all ARARs. Soil
and sediments with concentrations of Site COCs above cleanup levels would be removed and managed
on-site in compliance with ARARs until disposed of at a licensed off-site facility. Under this alternative,
soil exceeding cleanup levels (i.e., chromium exceeding 1,000 mg/kg and BEHP exceeding 3 mg/kg)
within the Containment Area (estimated to be approximately 44,608 cy) would be excavated and disposed
of at an approved off-site facility after dewatering and stabilization, as necessary. Based on the available
upland soil data, the majority of cleanup level exceedances for the Site COCs arc generally limited to
approximately 8 ft bgs. Excavated areas would then be backfilled with clean soils, which would serve as
a cap over areas of remaining subsurface contamination. Due to the depth of the excavation and
proximity of excavation areas to the slurry wall, a sheet pile wall would be installed to protect the
structural integrity of the slurry wall and the equalization window when excavation occurs near the wall.
Although not expected based on available data, any excavated soil that contains hazardous waste because
it fails the toxicity characteristic leaching procedure (TCLP), and any excavated soil from below the water
table would be treated and stabilized on-site in accordance with ARARs prior to transportation and off-
site disposal. Water and any associated air discharges generated from dewatering activities during
excav ations and the management of excavated soil would meet applicable ARARs for discharge.
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In summary, any wastes generated by remedial activities for Alternatives SOIL/S ED-2 through -4 would
be managed on-site in compliance with ARARs until disposed of at a permitted, off-site disposal facility.
Any water generated during soil and sediment excavation and de-watering activities would be
characterized and treated appropriately, then discharged to surface water. All work within wetlands and
streams would meet action-specific ARARs for protecting water quality.
Long-Term Effectiveness and Permanence
The No Action Alternative (SOIL/SED-1) is the least effective alternative for long-term effectiveness and
permanence because risks from Site COCs in soil and sediments are not addressed. COC concentrations
exceeding cleanup levels would remain, human health and ecological risks would not be addressed, and
the process whereby Site COCs above cleanup levels leach to groundwater would remain unchanged.
This alternative will have the highest remaining risk due to the lack of Institutional Controls or removal or
treatment of contamination in soil and sediments. Alternatives SOIL/SED-2 through -4 have some degree
of residual risk due to contamination that will remain on-site and will require Five Year Reviews to assess
the ongoing protectiveness of the remedy and Institutional Controls to prevent exposure to the remaining
contamination. Except for the No Action Alternative (SOIL/SED-1), all of the alternatives include
Institutional Controls to prevent exposure to any remaining contamination, prohibit future residential use
of the Property, prevent disturbance of any engineered systems and any other new and existing remedy
infrastructure components, prevent contact with soil beneath cover systems, and require either a vapor
intrusion evaluation or vapor mitigation systems be installed if a new building is constructed or altered on
the Property.
Alternatives SOIL/SED-2 and -3 are comparably effective in the long-term, while Alternative SOIL/SED-
4 would be the most effectiv e in the long-term, as this alternative provides for removal of the greatest
quantities of contaminated soil and contamination that is furthest from the surface than either Alternatives
SOIL/SED-2 or -3. Alternative SOIL'SED-4 would also have the highest degree of resiliency to extreme
weather events because the smallest volume of impacted material would remain in the subsurface,
followed by Alternative SOIL/SED-3 (shallow upland soil excavation and treatment of TMP-impacted
soils), followed by Alternative SOIL/SED-2, which leaves the largest volume of impacted soil close to the
surface, where it may be impacted by flooding and more extreme freeze/thaw cycling.
Alternatives SOIL/SED-2 through -4 include the same approach to remediating wetland soil and
sediments: excavation to a depth of one ft, followed by backfilling with clean wetland soil and sediment,
as appropriate and in accordance with a wetland restoration plan, and restoration to original grades, which
will be protective of human and ecological receptors. Long-term effectiveness is dependent on the
adequacy of the hydric soil (soil that is sufficiently wet to create anaerobic conditions, as is found in
wetlands), the success of the wetland plantings, environmental monitoring, and Institutional Controls.
Alternatives SOIL/SED-2 and -3 include a permanent, low-permeability cap that meets RCRA Subtitle D
and Massachusetts solid waste landfill performance standards over the Containment Area and closure of
the equalization window. These actions would help to hydraulically isolate the impacted soils, reduce the
potential for COCs to leach and migrate, and therefore control the exposure to COCs remaining in place.
Some residual risk would remain for the soil remaining in place beneath the permanent cap, which would
be addressed via Institutional Controls. Installation of the cap will help to minimize leaching from
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impacted soil remaining in place and reduce the potential for disturbance from extreme weather events.
Institutional Controls would protect the cap, prevent exposure to Site COCs in soil and soil vapor, and
prevent use other than commercial/industrial.
Under Alternative SOIL/SED-2, contaminated upland soil would be covered to eliminate the exposure
pathway for ecological receptors, and engineering controls for TMPs would be required for new
construction to address potential vapor intrusion risks. COCs would remain in place, causing potential
future risk if they were to be exposed and a higher potential for disturbance from extreme weather events.
Institutional Controls would mitigate these risks, provided that the controls are maintained. The long-
term effectiveness of the soil cover and Institutional Controls to prevent disturbance and require
engineering controls to address vapor intrusion would be contingent on maintenance and monitoring of
the controls chosen during remedy design.
Treatment of TMPs under Alternative SOIL/SED-3 - via air sparging/SVE - would be less effective in
the long-term than the approach taken under Alternative SOIL/SED-2. While vapor capture would
effectively control TMPs during treatment and residual risk would be low and mitigated through
Institutional Controls, some TMPs would likely remain sorbed to soil and not fully removed. Any
remaining soil containing TMPs may be subject to disturbance from extreme weather effects.
Under Alternative S01L/SED-4, which would be most effective in the long-term, excavation would be
applied to all media. Excavation and replacement with clean soil would reliably reduce the potential for
human health and ecological risk. Some residual risk would remain for the soil that remains (e.g., any
contaminated soil remaining in the Containment Area that is more than 10 feet deep), but Institutional
Controls would prevent exposure to this soil and prevent use other than commercial/industrial. The depth
of the remaining soil would minimize potential impacts from extreme weather events. While soil
excavation in TMP-impacted areas would have the potential to release vapors and might require
additional water handling, these risks would be mitigated via an SMP during implementation.
Reduction of Contaminant Toxicity, Mobility, or Volume through Treatment
The No Action Alternative (SOIL/SED-1) does not include any treatment, and thus provides no reduction
in toxicity, mobility, or volume through treatment. While Alternatives SOIL/SED-2 and -4 provide
comparable reductions in contaminant toxicity, mobility, or volume through treatment. Alternative
SOIL/SED-3 provides the highest degree of reduction in contaminant toxicity, mobility, or volume
through treatment.
All of the alternatives, with the exception of the No Action Alternative, reduce the mobility of COCs
throughout the Site by providing for their on-site containment, off-site disposal, and/or treatment.
However, active treatment is a component of only one alternative - SOIL/SED-3 - via air sparging/SVE.
With the exception of this active-treatment approach under Alternative SOIL/SED-3, the components of
all of the other alternatives require either caps/covers or excavation and clean soil covers, as opposed to
primary treatment, to reduce the toxicity, mobility, or volume of contaminated soil and sediment.
Alternatives SOIL/SED-2 and -4, in addition to the non-TMP components of Alternative SOIL/SED-3,
include limited treatment as a component of the alternatives, in that excavated soil or sediment that
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exhibits a hazardous waste characteristic or soil/sediments that are excavated from below the water table
would be treated (stabilized) by adding Portland cement, lime, or another suitable stabilizing agent to
reduce contaminant mobility prior to off-site disposal. Additionally, water generated from
excavation/dewatering soil prior to off-site disposal would be treated to reduce toxicity prior to discharge
to surface waters.
Alternative SOIL/SED-2 includes vapor intrusion evaluations and/or engineering controls, including
vapor mitigation features, to prevent human exposure to TMPs in soil. For engineered systems, regular
inspections and maintenance would be required to ensure a completed vapor intrusion pathway does not
develop. The removal and diversion of soil vapors through natural degradation processes would be
considered irreversible, however, TMP mass would remain in place and would not be actively treated by a
vapor barrier or sub-slab depressurization system, which are considered passive/'semi-passive systems.
To achieve protection of human health, this alternative relies on the implementation and enforcement of
engineering controls and Institutional Controls.
Short-Term Effectiveness
While the No Action Alternative (SOIL/SED-1) will not be effective in the short-term in protecting
human health or the environment, because no remedial activities will occur, there will be no adverse
impacts to the public or workers performing the cleanup, or short-term impacts to natural habitats.
The remaining alternatives (SOIL/SED-2 through -4) all include excavation and consolidation of
contaminated soil and sediments, to varying degrees, which will have some short-term impacts or risks
that will be mitigated via use of best management practices requiring appropriate Personal Protective
Equipment (PPE) during remedial activities, dust control, and proper handling and management of
contaminated media and other waste materials. Of these three alternatives. Alternative SOIL/SED-2
would be the most effective in the short-term. Alternative SOlL/SED-3 would be somewhat less effective
in the short-term, and Alternative SOIL/SED-4 would be the least effective in the short-term.
Alternative SOIL/SED-2 will require approximately 6,000 tons of contaminated soil and sediments to be
transported off-site; Alternative SOIL/SED-3 will require approximately 10,000 tons of material to be
transported off-site; and Alternative SOIL/SED-4 will require the transportation of approximately
130,000 tons of material off-site. In terms of risks for the community and on-site workers during
implementation. Alternative SOIL/SED-2 incorporates the least amount of contaminated soil and
sediment excavation, temporary stockpiling, on-site consolidation, loading, and transportation, while
Alternative SOIL/SED-4 incorporates the most amount. These remedial action alternatives provide a
means of potential exposure to the nearby community, on-site workers (via fugitive dust or the active
work environment), and the nearby environment to contaminated media.
The least amount of soil and sediments is handled by Alternative SOIL/SED-2, which means it creates the
least risk to the community, workers, and the environment, while the most amount of material is handled
by Alternative SOIL/SED-4, which would create the most risk from these perspectives. Excavation of
deeper upland soil under Alternative SOIL/SED-4 may also require excavation support to protect the
railroad, which would entail greater risks to workers. Alternative SOIL/SED-4 also includes deep soil
excavation, and soil and water management, which pose a high potential for direct contact and vapor
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exposure compared to the other alternatives. Risks to the community include those from increased
transportation of hazardous materials and increased traffic to bring in backfill material, and some of the
excavated soil may have contaminated soil vapor, however, best management practices would reduce
these risks to the community. Excavation, stabilization, and restoration will require a larger temporary
footprint than capping alone, as more space will be needed for staging materials. However, efforts will be
made to avoid and, where unavoidable, minimize impacts to ecologically sensitive areas.
Short-term impacts to the environment include emissions from on-site equipment, trucks delivering clean
soil cover and/or capping materials, and potential transport of excavated material to the on-site
consolidation area(s). Every effort will be made to minimize the areas of upland and wetland habitat
impacted to access contaminated surface and subsurface soil and sediment for excavation and
consolidation, regardless of which alternative is selected, and mitigation measures will be taken to reduce
impacts wherever possible. Following excavation, upland and wetland areas will be restored to match
original conditions to the greatest degree possible. Short-term environmental impacts are considerable
under Alternatives SOIL/SED-3 and -4, but less so under Alternative SOIL/SED-2. The engineering
controls and Institutional Controls for TMPs under Alternative SOIL/SED-2 would not pose a risk to the
community, construction personnel, or the environment during installation activities. Accomplishing
vapor mitigation with an SSDS would require low levels of electrical power, and air/soil gas monitoring
would require relatively minimal resources to complete. Installation and operation of air sparging/SVE
equipment to treat TMPs under Alternative SOIL/SED-3 has some potential for vapors to escape and
poses lower-level risks to workers, which would be addressed via best management practices.
Alternatives SOIL/SED-2 through -4 will all meet the established RAOs for soil and sediments in the
same general timeframe, and all will require generally the same amount of time to construct
(approximately two years).
Implementability
The No Action Alternative (SOIL/SED-1) would not require any actions to be taken at the Site and
therefore does not present any implementability issues. This alternative is the easiest to implement
because it does not involve the construction, operation, or maintenance of remedial systems or
enforcement of Institutional Controls. All of the remaining alternatives are relatively comparable given
that they involve routine construction work (conventional and available technology), available trained
personnel and materials, and, in the case of air sparging/SVE for TMPs under Alternative SOIL/SED-3, a
technology that was previously implemented at the Site without any issues related to construction or
operation. Overall, of the three action alternatives. Alternative SOIL/SED-2 is the most reliable and
easiest to implement.
Excavation and capping/covering arc not considered highly complex and have been frequently and readily
implemented at similar environmental restoration sites. Of the three action alternatives, Alternative
SOIL/SED-2 is comparatively the easiest to implement because of the higher implementability of
caps/covers over excavation, as well as the various attributes of the engineering controls which would be
used to address risks from TMPs. These include the relative ease of conducting vapor intrusion
evaluations and incorporating vapor barriers and SSDSs into new building construction, and the reliability
and minimal maintenance associated with engineered systems. Permits arc not required to implement the
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remedy for TMPs under Alternative SOIL/SED-2; however, the construction and operation of vapor
mitigation systems is highly reliant on Institutional Controls to prevent human contact with hazardous
wastes. Coordination with the Town of Wilmington and MassDEP will be necessary to ensure that new
construction within zones of TMP impacts properly account for residual risks from TMP vapors.
No difficulties or uncertainties are anticipated with construction of the permanent cap and sealing the
equalization window for the Containment Area under Alternatives SOIL/SED -2 and -3. The proposed
cap will be reliable if regularly inspected and maintained. Migration of COCs via leaching is possible, as
is also the case for the excavation remedy for the Containment Area under Alternative SOIL/SED-4,
under which remaining contamination that is more than 10 ft deep may be a source for groundwater,
surface water, and sediment contamination. This concern may be mitigated, however, via the use of
monitoring wells both inside and outside the Containment Area to monitor groundwater contaminant
concentrations.
Alternatives SOIL/SED-3 and -4 are comparatively more difficult to implement than Alternative
SOIL/SED-2 because the former require managing and consolidating the greatest amount of waste and, in
the case of Alternativ e SOIL/SED-4, a possible need for sheet piling for soil structural support in an area
near the MBTA railroad tracks where the structural stability of soil may be a concern. All three of these
alternatives will result in impacts to wetlands during excavation activities (and for some, placement of
caps or covers); such impacts will be minimized to the extent possible and mitigation for unavoidable
impacts will be required. Actions will be taken to ensure that current flood storage capacities are not
diminished after completion of the proposed remedial activities. For Alternatives SOIL/SED-2 through -
4, coordination with other agencies, as well as monitoring to determine the effectiveness of the remedy, is
equally implementable. PDI sampling would be used to map the extents of soil and sediment
contamination, ensure that caps/covers are adequately protective, and that excavations are complete.
Costs
The costs for all alternatives are presented in Table K-l in Appendix B of this ROD. The range in
estimated cost for all four alternatives is from $0 for Alternative SOIL/SED-1 to $34.2 million for
Alternative SOIL/SED-4. Specifically, the overall costs for Alternatives SOIL/SED-2, -3, and -4 are $6
million, $7.5 million, and $34.2 million, respectively.
Alternative SOIL/SED-2 has the lowest capital costs ($5.6 million, as compared to $6.7 million for
Alternative SOIL/SED-3 and $34 million for Alternative SOIL/SED-4) and O&M costs comparable to
those of Alternative SOIL/SED-3. but higher than the O&M costs associated with Alternative SOIL/SED-
4 ($1.1 million, as compared to $ 1.5 million for Alternative SOIL/SED-3 and $330,000 for Alternative
SOIL/SED-4). However, due to the high capital costs associated with Alternative SOIL/SED-4 (which
raises the overall costs for this alternative significantly over the other alternatives). Alternative
SOIL/SED-2 has the lowest overall costs.
Modifying Criteria with Respect to Alternatives DAPL/GWHS-3. LNAPL/SW-3, and SO//./SED-2
State Acceptance
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The Commonwealth of Massachusetts, through its lead agency, MassDEP, has expressed its support for
EPA's preferred alternatives presented in the August 2020 Proposed Plan and concurs with the selected
remedy outlined in this ROD (see Appendix A of this ROD for the State concurrence letter).
Community Acceptance
EPA's extensive community engagement efforts at the Site included the publication of a Proposed Plan in
August 2020, and the occurrence of multiple public meetings which are described in further detail above
in Section C of this ROD. An in-person public informational meeting was held at the Wilmington High
School in Wilmington, MA on October 22, 2019 to provide information on the site history and R!
findings and update the community on the progress towards a ROD, which was followed by a question-
and-answer session. A virtual public informational meeting on the Proposed Plan was held on August 25,
2020, which included a question-and-answer session. A virtual formal public hearing on the Proposed
Plan was held on September 22, 2020. A transcript was created for this hearing and has been made part
of the Administrative Record for this ROD. in addition to the oral comments received at the hearing, 25
sets of written comments were also provided. A summary of the comments specific to the proposed
alternatives for the Site and EPA's responses to the comments are included in the Responsiveness
Summary, Part 3 of this ROD.
In general, the comments received from the community were supportive of the remedial alternatives
selected in the ROD. There were concerns related to making sure the interim action for groundwater
remains a priority and that the final action for groundwater results in restoration of the aquifer as a
drinking water aquifer. There were also concerns raised regarding future development of the Property,
noting that cleanup should occur before redevelopment is allowed. Responses to these concerns are
included in the Responsiveness Summary.
L. THE SELECTED REMEDY
1. Summary of the Rationale for the Selected Remedy
The selected remedy for the Site is a comprehensive final remedy for LNAPL, surface water, soil, and
sediments and an interim remedy for DAPL and groundwater hot spots. The final and interim remedies
both utilize source control and management of migration components to address unacceptable risk from
exposure to Site COCs and/or exceedances of ARARs. The final remedy utilizes source control measures
to address the following: COCs in soil and sediments that present unacceptable risks to human health
and/or env ironmental receptors; and LNAPL that represents a source of COCs to groundwater and a
source of TMPs to indoor air vapors. The interim remedy utilizes source control measures to address
DAPL and COCs in groundwater hot spots that represent an ongoing source of COCs to groundwater,
surface water, and sediments.
Additionally, the final remedy utilizes management of migration components to prevent the migration of
LNAPL to East Ditch Stream and prevent groundwater containing COCs from flowing into surface water
features. The interim remedy utilizes management of migration components to reduce the horizontal and
v ertical migration of DAPL and groundwater hot spots. Of all the alternativ es, the selected interim
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remedy for DAPL and groundwater hot spots and final remedy for LNAPL, surface water, soil, and
sediments best satisfy the statutory criteria for remedy selection.
The remedy is estimated to cost approximately $48 million. The cost analyses include an estimation of
the capital costs and annual O&M costs. In addition, the cost estimate is based on a present worth
analysis by discounting to a base year or current year using a 7 percent discount rate. The selected
remedy is anticipated to take two to three years to construct. Groundwater restrictions are expected to be
in place for over 100 years, until final cleanup levels are identified in a future remedy decision for
groundwater and achieved.
2. Description of Remedial Components
The following is a detailed description of the components of the selected remedy. The final selected
source control and management of migration remedy for the Site is consistent with EPA's preferred
alternatives outlined in the August 2020 Proposed Plan.
Components of the Remedy Specific to DAPL and Groundwater Hot Spots (Interim Action - Alternative
DAPL/G WHS-3)
The selected remedy for the interim action for DAPL and groundwater hot spots - Alternative
DAPL/GWHS-3: DAPL extraction (approx. 20 wells), groundwater hot spot extraction targeting 5,000
ng/L NDMA contour (approx. 6 wells), and treatment at new treatment system(s) - includes the following
components:
• Construction and operation of a DAPL extraction system, conceptualized with approximately four
wells in the Off-Property Jewel Drive DAPL pool, approximately four wells in the Containment
Area DAPL pool, and approximately 12 wells in the Main Street DAPL pool (see Figures 34, 35,
and 36 in Appendix C of this ROD, respectively), the final number, location, and configuration
of which will be determined based on the PDIs;
• Construction and operation of a groundwater extraction and treatment system, conceptualized
with approximately six wells targeting the 5,000 ng/L NDMA contour, the final number, location,
and configuration of which will be determined based on the PDIs, to remove and treat the mass of
contaminants in groundwater hot spots; and
• Treatment of extracted DAPL and hot spot groundwater in a new treatment system(s).
Conceptually, it is assumed that such treatment will generally include the following
methodologies:
o Treatment for DAPL:
¦ Lime precipitation to remove metals, with subsequent dewatcring and off-site
disposal of the liquids and sludge materials;
¦ Air stripping to remove VOCs and ammonia;
¦ UV photo-oxidation to remove NDMA; and
¦ Evaporation of the remaining water and off-site disposal of the residual solids;
o Treatment for hot spot groundwater:
¦ Influent equalization tank;
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¦ Hypochlorite flash mixer (a rapid mixer that uniformly distributes a treatment
chemical) for oxidation and removal of metals (iron and manganese );
¦ Breakpoint chlorination to treat ammonia;
¦ Slow mix flocculation (a process by which fine particulates arc caused to clump
together) and lamella clarifier (a scries of inclined plates on which particulates
can settle) to remove solids;
¦ Filter press for solids dewatering;
¦ Off-site disposal of residual solids and sludge materials;
¦ GAC to ensure clarity and ultra-violet (IJV) transmittance. as well as remove
volatile organic compounds (VOCs);
¦ UV photo-oxidation for NDMA destruction; and
¦ Discharge of treated water.
Overview of the DAPL and Groundwater Hot Spots Remedy
Figure 31 in Appendix C of this ROD provides a conceptual layout of the DAPL and groundwater hot
spot remedy, and Figure 32 in Appendix C of this ROD provides a cross-section of the conceptual plan
for this alternative. Alternative DAPL GWHS-3 is expected to remove approximately 14.8 million
gallons of DAPL and 68.4 million gallons of hot spot groundwater from the aquifer, and generate
approximately 16,531 tons of sludge residuals for off-site disposal as a result of DAPL treatment. These
sludge residuals are assumed to be non-hazardous waste, but will be further characterized prior to
shipment off-site. If solids meet hazardous waste criteria, further dewatering will be conducted, where
possible, as necessary to minimize moisture content/water weight before disposal off-site at an approved
disposal facility licensed to accept the contaminated media. Studies will be conducted to evaluate and
optimize the on-site treatment of DAPL. The goal will be to pre-treat the extracted DAPL to reduce its
volume, thus reducing the volume of residuals requiring off-site disposal. If it is not feasible to treat
DAPL on-site, extracted DAPL will be disposed of off-site at a permitted facility licensed to receive such
wastes.
DAPL Remedy
This alternative includes the construction and operation of a DAPL extraction system, with approximately
four wells in the Off-Property Jewel Drive DAPL pool, approximately four wells in the Containment Area
DAPL pool, and approximately 12 wells in the Main Street DAPL pool (see Figures 34, 35, and 36 in
Appendix C of this ROD, respectively), the final number, location, and configuration of which will be
determined based on the PDIs. Multiple extraction wells in each DAPL pool will serve to minimize
drawdown, provide flexibility with pumping rates, and target bedrock low points identified during the
PDI activities of the RD phase.
Groundwater Hot Spots Remedy
Alternative DAPL/GWHS-3 also includes construction and operation of a groundwater extraction system,
with approximately six new, deep overburden extraction wells, the final number, location, and
configuration of which will be based on the PDIs, to remove and treat the mass of contaminants within
the area of groundwater that targets the 5,000 ng/L NDMA contour. Figure 31 in Appendix C of this
ROD shows proposed locations of extraction wells and conveyance lines, and a hypothetical location for
the groundwater treatment plant. An estimated three new extraction wells will be sited in the general
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vicinity of existing wells GW-58D, GW-83D, and GW-84D; approximately one new extraction well will
be located in the general vicinity of well GW-85D, and approximately two new extraction wells will be
sited in the Main Street DAPL area, screened in the hot spot groundwater layer over the DAPL surface.
Other Components of the DAPL and Groundwater Hot Spots Remedy
Extracted DAPL and groundwater will be treated at a newly constructed treatment system or systems
(potentially the same system(s) as for Alternative LNAPL/SW-3, see below) and discharged to surface
water. The groundwater hot spot extraction wells are estimated to pump at 10 gpm each, for a constant
combined extraction rate of 60 gpm. The Off-Property Jewel Drive and Containment Area wells will be
pumped at an estimated 0.25 gpm. Based on the deeper bedrock and steeper sides of the Main Street
DAPL pool, the Main Street wells will be pumped initially at 0.5 gpm, but it may become necessary to
progressively reduce the rate of DAPL extraction with time as DAPL pool volumes diminish. The waste
liquids and residual solids/sludges generated during DAPL treatment are assumed to be non-hazardous
waste, but will be further characterized prior to off-site disposal. The goal will be to evaporate a
sufficient volume of DAPL such that it is a solid suitable for off-site transportation/disposal. DAPL
would be removed to the extent practicable based on measured concentrations meeting the definition of
DAPL.
Alternative DAPL/GWHS-3 includes all appropriate plans and specifications relevant to this component
of the remedy (e.g., air monitoring plan, transportation/trucking plan, dust and odor control plan, site
management plan, restoration plan, and health and safety plan) and all necessary preparation and
mobilization activities to implement this remedy component (e.g., removal of vegetation and debris, as
appropriate, installation of temporary fencing, decontamination facilities, solids/sludges/waste liquids
management areas, trailer, and sanitation facilities). Details regarding these plans and other measures will
be developed during the RD phase.
O&M for Alternative DAPL GWHS-3 will include monitoring to assure that the extraction pumps are
operating properly, the treatment components are in proper operation, the activated carbon, pumps,
tubing, and other consumable components are changed/replaced as needed, and compliance monitoring
for air emissions and treated water are being performed. O&M will also include routine inspections of
extraction system components, including pumps, pump enclosure vaults, system controls, communication
equipment, piping, storage tank(s), and tanker truck loading station(s), and periodic evaluation and
ad justment of pumping rates.
Existing wells (e.g., potable, irrigation, and process wells) in the Site groundwater study area (see Figure
11 in Appendix C of this ROD) will be identified and evaluated to determine whether their use will pose
an unacceptable risk to human health and the environment, cause further migration of the groundwater
contaminant plume, or interfere with the remedy. Monitoring of groundwater and surface water will be
performed to assess remedy progress and effects on surface water features, evaluate the response of the
DAPL and overlying groundwater during pumping, assess trends of monitored parameters in DAPL and
groundwater, and assess the specific chemical characteristics of the extracted DAPL. Long-term
monitoring and maintenance will be conducted for any new and existing remedy infrastructure
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components and to maintain any required wetland'floodplain mitigation and/or stormwater controls. Five
Year Reviews will be required since contamination will be left in place.
Components of the Remedy Specific to LNAPL and Surface Water (Final Action - Alternative
LNAPL/SW-3)
The selected remedy for the final action for LNAPL and Surface Water - Alternative LNAPL/Surface
Water-3: Demolition of Plant B, MPE for LNAPL, Targeted Groundwater Extraction to Prevent Impacts
to Surface Water, Treatment at New Treatment Systcm(s) - conceptually includes the following
components:
• An estimated three to five MPE wells installed within the LNAPL footprint, including beneath
the Plant B building foundation (the exact number, location, and configuration of which will be
based on the PDIs), to remediate LNAPL, the smear zone, and dissolved-phase COCs that would
otherwise impact East Ditch Stream;
• Treatment of recovered LNAPL and soil vapor via a treatment system that conceptually includes
an oil/water separator to remove the LNAPL and vapor-phase GAC to treat the soil vapor;
• Off-site disposal of recovered LNAPL at an appropriate off-site permitted facility;
• Construction and operation of a new groundwater extraction and treatment system or systems,
with extraction wells sited based on PDIs to intercept and treat the overburden groundwater
contaminant plume that impacts Site surface water;
• Re-routing of groundwater currently treated by Plant B to the new groundwater treatment system
or systems (potentially the same system(s) as for the hot spot groundwater, see above); and
• Decommissioning and demolition of the Plant B groundwater treatment system.
Overview of the LNAPL and Surface Water Remedy
Figure 28 in Appendix C of this ROD provides a conceptual layout of the LNAPL and surface water
remedy. Extraction wells will be installed to intercept and treat the overburden groundwater contaminant
plume that impacts Site surface water. Extracted groundwater will be treated at a newly constructed
groundwater treatment system (potentially the same system as for the groundwater hot spots, see above)
and discharged to surface water, the design of which will be refined during the RD phase. Additionally,
groundwater currently treated by Plant B will be re-routed to the new groundwater treatment system.
Following this, the Plant B groundwater treatment system will be decommissioned and demolished. An
estimated three to five MPE wells (the exact number, location, and configuration of which will be based
on the PDIs) will then be installed within the LNAPL footprint, including beneath the Plant B building
foundation following Plant B's demolition, to remediate LNAPL, the smear zone, and dissolved-phase
COCs that would otherwise impact East Ditch Stream.
LNAPL Remedy
Plant B will continue to operate until the new groundwater hot spot treatment system (see above) is
operational. Once the new treatment system becomes operational, the extracted groundwater currently
being treated at Plant B will be re-routed to the new treatment system. After the reconfiguration, the Plant
B building, tanks, and associated infrastructure will be decommissioned and demolished to grade,
removing obstructions prior to investigation and treatment. Data collected during the PDIs will be used to
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confirm the limit of LNAPL in soil and groundwater that requires remediation (see Figure 20 in
Appendix C of this ROD).
Following the PDI phase, the MPE system will be constructed, which will likely employ a skid-mounted
system to treat the extracted materials. Conceptually, the skid-mounted system will consist of an
extraction blower, knockout tank to separate the streams, oil/water separator to remove LNAPL, and
GAC to treat vapors. Extracted LNAPL will be stored on-site, with off-site disposal at an appropriate off-
site facility licensed to receive the contaminated media. A post-remediation verification program will be
conducted to confirm achievement of RAOs. The sampling will include collection of soil boring samples
from the smear zone as well as groundwater samples with analysis for BEHP and VPH. The currently
operating extraction wells at Plant B will continue to operate, at a minimum, through the first Five Year
Review following the LNAPL remedial action. Groundwater monitoring, including product thickness
measurements, will be performed as LNAPL is being removed and following the cessation of LNAPL
removal, until a Five Year Review determines that further monitoring is no longer necessary.
Surface Water Remedy
Groundwater extraction wells will be installed, based on data collected during PDIs, to intercept and treat
the overburden groundwater contaminant plume that impacts Site surface water (see conceptual layout in
Figure 37 in Appendix C of this ROD). Continued short-term operation of Plant B is assumed.
Following the shut-down and demolition of Plant B, an evaluation of Site hydrogeology would be
performed first and the necessity of additional extraction wells to prevent groundwater impacts to surface
water would be evaluated, followed by their design and installation. Extracted groundwater will be
conveyed to the new treatment plant for the DAPL and groundwater hot spot remediation (see above).
The treated groundwater will be discharged to surface drainage, the precise location(s) of which will be
determined during the PDI phase. Remedy optimization, such as modifying the number of extraction
wells, adjusting the extraction pumping rates, and/or changes to the monitoring program, will be
evaluated as part of the monitoring program and the Five Year Review process.
Other Components of the LNAPL and Surface Water Remedy
All appropriate plans and specifications relevant to this component of the remedy will be developed and
implemented (e.g., air monitoring plan, transportation/trucking plan, dust and odor control plan, site
management plan, restoration plan, demolition plan for existing structures, erosion and sedimentation
control plan, and health and safety plan), as well as all necessary preparation and mobilization activities to
implement this remedy component (e.g., removal of vegetation and debris, as appropriate, installation of
temporary fencing, decontamination facilities, wastes/waste liquids management areas, trailer, and
sanitation facilities). Details regarding these plans and other measures will be developed during the RD
phase.
O&M for Alternative LNAPL/SW-3 will include monitoring to assure that the extraction pumps are
operating properly, the treatment components are in proper operation, the activated carbon, pumps,
tubing, and other consumable components are changed/replaced as needed, and compliance monitoring
for air emissions and treated water are being performed. O&M will also include routine inspections of
extraction system components, including pumps, pump enclosure vaults, system controls, communication
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equipment, piping, storage tank(s), and tanker truck loading station(s), and periodic evaluation and
adjustment of pumping rates.
Performance monitoring schedules will be evaluated as part of the RD phase. Monitoring of groundwater
and surface water will be performed to assess remedy progress and effects on surface water features.
Long-term monitoring and maintenance will be conducted for any new and existing remedy infrastructure
components and to maintain any required wetland/floodplain mitigation and/or stormwatcr controls. Five
Year Reviews will be required since contamination will be left in place.
Components of the Remedy Specific to Soil and Sediments (Final Action - Alternative SOIL/SED-2)
The selected remedy for the final action for soil and sediments - Alternative SOIL/SED-2: Containment
Area cap, upland soil covers, excavation with off-site disposal and restoration of wetland soil and
sediments, limited action for TMPs (Institutional Controls, including vapor intrusion evaluations or vapor
barriers/SSDSs) - includes the following components:
• Placement of a permanent, low-permeability cap that meets RCRA Subtitle D and Massachusetts
solid waste landfill performance standards over the Containment Area, the design and footprint of
which will be determined during the RD phase;21
• Closure of the existing slurry wall equalization window by grouting in place;
• Placement of a soil or asphalt cover system over areas of shallow (0-1 ft) upland soil with
concentrations of COCs in excess of the cleanup levels;
• Excavation of approximately 4,000 cy of wetland soil and sediment with concentrations of COCs
in excess of the cleanup levels;
• Post-excavation confirmatory sampling to document limits of impacts and confirm achievement
of the RAOs and cleanup levels;
21 While soil in the Containment Area has not been identified as RCRA hazardous waste, it is possible that
hazardous waste may be present. Historical disposal practices in this area suggest that unsaturated soil within the
Containment Area contains waste materials. Pre-RI soil samples were primarily collected from the Containment
Area between the surface and 10 feet bgs. During the OU1/OU2 RI, characterization of Containment Area soil was
limited to surface samples from beneath the temporary cap, which were collected bv cutting slits in the cap and
using a hand-held spatula. Deeper samples were not collected at that time to avoid potential damage to the
temporary cap that may have resulted from the presence of the drill rig. In 2019, twelve soil samples were collected
at a variety of depths from the Containment Area to determine if Containment Area soil meets the definition of
characteristic hazardous waste (Wood, 2020a). Each boring was drilled through overburden soil and advanced 5
feet into the top of bedrock. Analytical results from the soil samples collected from these borings showed elevated
concentrations of TMPs, BEHP, and total chromium; none of the samples exceeded the criteria for RCRA hazardous
waste characteristics. However, the sampling data was limited, and additional sampling would be necessary to
demonstrate the absence of non-hazardous wastes (i.e., solid wastes) within the Containment Area. Accordingly, the
solid wastes in the Containment Area will need to be contained, a remedial action that would include the prevention
of leaching of chemicals or constituents from such wastes, in accordance with RCRA Subtitle D regulations and
Massachusetts Solid Waste Management Facility Regulations.
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• Minimization of potential harm and avoidance to the extent practicable of adverse impacts to
wetlands and floodplains; restoration and/or replication nearby to address unavoidable impacts
from remedial activities, including proper regrading, restoration with native vegetation and to
address any diminishment of flood storage capacity, erosion control, monitoring, and
maintenance;
• Off-site disposal of all excavated material at an appropriate off-site permitted facility;
• Prevention of future exposure to TMPs that may pose inhalation risks via vapor intrusion by
requirements to conduct additional evaluations and/or implement mitigation measures such as
vapor barriers or SSDSs for new building construction or building alterations on the Property; and
• Long-term monitoring and maintenance of any new and existing remedy infrastructure, including
the cap for the CSL
Overview of the Soil and Sediments Remedy
Figure 24 in Appendix C of this ROD provides a conceptual layout of the soil and sediments remedy,
including the areas expected to be excavated and the areas to be addressed via caps and cover systems. A
permanent, low-permeability cap that meets RCRA Subtitle D and Massachusetts solid waste landfill
performance standards will be placed over the Containment Area. The existing equalization window will
be closed by grouting in place. Soil or asphalt cover systems will be placed over areas of shallow (0-1 ft)
upland soil with concentrations of COCs in excess of the cleanup levels as verified with additional
sampling during the PDI. Wetland soil and sediment with concentrations of COCs in excess of the
cleanup levels will be excavated and disposed of off-site at an approved, permitted facility. A PDI will be
conducted to further refine the extent of soil and sediments to be excavated. Excavated contaminated
wetland soil and sediments determined to contain hazardous waste will be managed in accordance with
RCRA hazardous waste regulations. The caps and cover systems will be designed to prevent direct
contact with impacted soil, to prevent soil from being carried to nearby areas (including streams and
wetlands) via erosion during rain events, and to prevent soil contaminants from leaching to groundwater.
The caps and cover systems will be adequately designed with long-term integrity for seasonal conditions,
severe storms (up to a 500-year storm event), and freeze/thaw conditions; to satisfy ARAR requirements;
and to prevent contaminants leaching to groundwater (i.e., meet impermeability requirements). As
appropriate, alternative cap/cover system designs such as new building foundations, pavement, or
landscaping may be evaluated and assessed during the RD phase for adequacy of satisfying the RAOs and
ARARs low-permeability cap standards. Five Year Reviews will be required since contamination will be
left in place.
Containment Area Remedy
A permanent cap meeting ARARs' low-permeability cap standards will be designed and constructed, the
objective of which is to permanently minimize infiltration of rainwater. The cap will comply with RCRA
Subtitle D regulations and Massachusetts Solid Waste Management Facility Regulations and meet low-
permeability requirements with an effective permeability of the existing slurry wall (approximately lxlO-8
centimeters/second (cm/s)) or a permeability of no greater than 1x10 7 cm/'s, whichever is less). The
footprint of the cap will extend approximately 30-50 ft beyond the boundary of the Containment Area,
except where the detention basin is ad jacent to the southern end of the Containment Area. PDIs will
include a program to obtain geotechnical information in support of the RD and will determine if the
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existing temporary cap should be removed or if the new permanent cap can be placed on top of the
existing temporary cap. The geotechnical data, along with settlement and slope stability evaluations, will
be used to design the cap. The approximate limits of the proposed cap as shown on Figure 38 of
Appendix C of this ROD are based on a maximum of 7.5 ft of subgrade soil (average depth of
approximately 2.5 ft) to achieve a 3% minimum slope prior to construction of the approximately 2-ft thick
composite cap. A general cross-section of the cap is shown on Figure 39 of Appendix C of this ROD,
and will be refined further during the RD phase. Conceptually, the components of the cap from depth to
surface will generally be as follows:
• Compacted sub-grade fill;
• 12 in of soil;
• Geosynthetic clay liner;
• Linear low-density polyethylene geomembrane;
• Geocomposite drainage layer;
• 18 in of soil cover; and
• Vegetative layer with 6 in of topsoil.
As noted above, alternative cap/cover system designs such as new building foundations, pavement, or
landscaping may also be evaluated and assessed during the RD. Prior to construction of the cap for the
Containment Area, the existing equalization window will be closed by grouting in place. The
equalization window is an approximately 10-ft by 40-ft opening in the west side of the Containment
Area's 3-ft wide slurry wall, filled with crushed stone. The window will be sealed and grouted in place to
eliminate the flow of groundwater through the slurry wall.
PDIs for the Containment Area will include a storm water study to verify the current understanding that
the Containment Area (85 ft above mean sea level [msl]) is above the 500-year flood elevation (82 ft
above msl), which would mean that the remedy will not result in the occupancy and modification of the
500-year floodplain at the Property. If additional site preparation is needed to allow for adequate
drainage and storage within the 500-year floodplain, this will be evaluated as part of the design activities
and implemented during the remedial action phase. Institutional Controls will be implemented to limit
and restrict future activities within the confines of the slurry wall/Containment Area that would negatively
impact the integrity of the permanent cap.
Upland Soil Remedy
Figure 40 in Appendix C of this ROD shows the estimated remediation areas consisting of caps and
cover systems for the upland soil remedy. The extents of remediation areas will be further refined during
the PDIs. Contamination in upland soil exceeding the cleanup levels will be addressed by placement of
cover systems to prevent unacceptable ecological exposures. The cover systems will consist of either 1 -ft
soil layers or 3-in layers of asphalt pavement over areas of shallow (0-1 ft) contamination. As
appropriate, alternative cover system designs such as new building foundations or parking lots may be
evaluated and assessed during the RD phase for adequacy of satisfying the RAOs and meeting ARARs.
Areas that are already inaccessible because they are under buildings or are covered with competent
concrete or asphalt will be maintained without additional cover, and included within the set of
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Institutional Controls to ensure their long-term integrity. If existing buildings, foundations, or pavement
are removed, the soil beneath these areas shall be evaluated to determine if cover systems are needed to
prevent exposure.
PDIs for upland soil will be conducted to confirm the extent of COCs in the upper foot of soil and
facilitate the design of adequately protective caps and cover systems. Institutional Controls will include a
Soil Management Plan to ensure the integrity of the caps and cover systems over areas of remediated
upland soil and provide requirements to minimize future excavation of soil in these areas. In the event
that future excavation is necessary, the Soil Management Plan will provide requirements for notifying and
obtaining agency approvals, and requirements to prohibit subsurface soil with COCs above cleanup levels
from being placed at the ground surface and specify appropriate material handling and waste management
practices. Periodic inspections of all caps/cover systems will be conducted to verify that the integrity has
not been compromised. If soil erosion is identified in the areas with soil covers or if deterioration or
damage is identified in the areas with asphalt pavement covers, the damages will be repaired and
monitored to ensure long-term integrity.
Wetland Soil and Sediments Remedy
Figure 41 in Appendix C of this ROD shows the wetland soil and sediment areas to be addressed via
excavation and off-site disposal under this remedy. Excavation will occur for sediments in the northern
half of Off-Property West Ditch Stream, along the entire length of the on-Property portion of South Ditch
Stream (both Upper and Lower South Ditch Streams), and in Central Pond. For wetland soil, remediation
areas will include Lower South Ditch Stream (the off-Property portion) and E-EA-5, E-EA-4 and E-EA-6,
and the eastern portion of E-EA-2 within the On-Property West Ditch Stream wetlands. Wetland soil and
sediment analytical data indicates that the majority of cleanup level exceedances for COCs are limited to
approximately 1 -ft bgs; remediation areas estimated to total 106,500 square feet will generally be
excavated to a depth of approximately 1 -ft bgs, yielding approximately 5,000 loose cy of excavated soil
and sediments. In total, approximately 4,000 in-pi ace cy arc estimated to be excavated and stabilized on-
site (if needed) prior to shipping off-site for disposal, weighing 6,200 tons. The actual excavation depths
and extents will be determined during the RD phase and will be based on additional wetlands delineation
confirmed through site reconnaissance and evaluation by a qualified wetlands soil scientist and data
collected during the PDI. PDIs will include sample analysis to confirm the limits in wetland soil that
require remediation.
A detailed Stormwater Pollution Prevention Plan (SWPPP) will be included in the design package to
protect areas surrounding the remediation areas during wetland soil/sediments excavation. Temporary
stormwater controls may be required during remedy implementation to minimize the amount of soil that
requires stabilization and to facilitate excavation. Depending on the season, temporary stormwater
diversions may be needed to facilitate excavation in streams. In relatively dry conditions, stream water
may be temporarily diverted to facilitate soil and sediment removal. Existing roads will be utilized
wherever possible to access areas requiring remediation. In certain areas, new access routes may need to
be constructed.
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Central Pond will require dewatering before excavating the sediments from this area. An estimated
640,000 gallons of recovered water will be treated locally through the treatment system(s), the same as for
the DA PL and groundwater hot spots remedy.
Sediment excavation areas will be backfilled with off-site borrow material that is verified to meet
appropriate guidelines. Excavation areas will be backfilled to generally match pre-excavation conditions,
using granular soil material within the stream channel and dressed with an organic top soil in adjacent
forested wetland areas. Upon completion of excavation, erosion blankets will be installed on channel
banks where applicable and wetland grass varieties will be seeded. Temporary erosion controls best
management practices will be instituted until such time as natural systems recover.
Excavated wetland areas will be backfilled and re-vegetated in accordance with wetland restoration plans.
Wetland soil excavation areas will be backfilled with off-site borrow material that is verified to meet
appropriate guidelines. Wetland soil areas will be backfilled to match pre-excavation conditions
generally, using granular soil material and dressed with an organic top soil. Best management practices to
control erosion and sedimentation will be maintained until vegetation is re-established.
TMPs Remedy
Under this component of the remedy. Institutional Controls will address potential vapor intrusion
concerns associated with future buildings or building alterations on the Property in areas where elevated
concentrations of TMPs have been detected in soil. Figure 42 in Appendix C of this ROD shows
currently known areas of TMP-impacted soil. The Institutional Controls will require vapor intrusion
evaluations and/or engineering controls, such as vapor barriers and/or SSDSs, for future building
construction on the Property, or building alteration or modification. SSDS designs may be passive
systems with an option to upgrade to an active system based on post-construction/post-renovation
monitoring results.
As part of the Institutional Controls, engineering controls in the form of vapor barriers and/or SSDSs
would be required to be incorporated into the design and construction of future building foundations in
the v icinity of HH-EA-1, HH-EA-3, and HH-EA-7 where elev ated levels of TMPs in soil have been
detected. Final design requirements will depend on the size and type of the building to be constructed,
but are expected to generally consist of collection piping or a collection geotextile laid into a layer of
gravel, connected to header pipes that vent the vapors to outdoor air outside the building footprint.
Periodic monitoring will be required for buildings with mitigation systems in order to determine whether
the systems are functioning properly and to document negative pressures beneath floor slabs for active
systems. System fans, piping, and other components will be monitored for signs of wear. Periodic
sampling and monitoring will be recommended for buildings with elev ated measurements of TMPs in soil
but where no active mitigation system was installed because indoor air sampling indicated that the passive
system was adequate to prevent unacceptable indoor air risks. Periodic inspections will also be required
for all buildings with mitigation systems to evaluate whether building conditions may have changed in a
manner that could cause an increased potential for vapor intrusion and thus necessitate a
modification/addition to the existing engineered mitigation system.
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Calcium Sulfate Landfill Maintenance and Monitoring
Long-term maintenance and monitoring (post-construction monitoring) in accordance with Massachusetts
Solid Waste Management Facility Regulations (310 CMR 19.000) will be implemented for the CSL cap
and associated infrastructure, as well as Institutional Controls, to ensure the integrity, maintenance, and
repair (as necessary) of the cap to ensure its protectiveness and prevent contact with the underlying soil.
On January 7, 2009, MassDEP issued a determination that the CSL had been capped in conformance with
the landfill design plans and was deemed closed, subject to conditions including monitoring in accordance
with a December 2006 post closure monitoring plan (MassDEP, 2009). On March 3, 2011, MassDEP
issued an approval of a modification of the post closure monitoring plan (MassDEP, 2011). The post
closure monitoring plan approved by MassDEP may be modified by EPA as needed for the overall
remedy at the Site.
Other Components of the Soil and Sediments Remedy
Potential harmful temporary or permanent impacts to wetlands and/or floodplain resources will be
minimized to the extent practicable and mitigated as necessary. Mitigation measures will be required to
address any unavoidable short- or long-term floodplain impairment within the 500-year floodplain on the
Property and within the 1 (X)-year and 500-year floodplains off-Property in the MMB wetlands. Caps and
cover systems within the 500-year floodplain on the Property will be designed, constructed, and
maintained to prev ent any releases in the event of flooding (up to a 500-year flood event). Figure 5 in
Appendix C of this ROD shows the Site FEMA flood zone designations.
A sequencing plan will be developed for implementing the soil and sediments remedy to coordinate work
with the remedial actions for the DAPL and groundwater hot spots and LNAPL and surface water and
ensure that remedial activities taken to address COCs in soil and sediments are not undermined by
recontamination from LNAPL and contamination in groundwater and surface water. The soil and
sediments remedy will be implemented after it is established that flow from contaminated groundwater is
not serving as on ongoing source which could negatively impact the quality of wetland soil and
sediments. Based on the available wetland soil and sediment data, cleanup level exceedances for the Site
COCs are generally limited to approximately 1 ft bgs. A PD1 will be conducted to further refine the
extent of material to be excavated. Temporary roads may need to be installed to support excavation and
other remedial activities. Prior to excavation, erosion control measures will be installed around the
excavation areas. During the excav ation, dust control and air monitoring will be performed, as well as
monitoring of adjacent wetlands/waterways, as necessary, to ensure that no contaminant releases
adversely impact human health and/or the environment during the cleanup activities. Wetland soil and
sediments with concentrations of Site COCs in excess of the cleanup levels will be excav ated (estimated
to be approximately 6,000 tons) and disposed of off-site at an appropriate permitted facility. Excavated
soil and sediments will be stockpiled at an approved location. Excavated soil and sediments will be
devvatered and stabilized, as necessary, prior to shipment off-site to an approved, permitted facility. The
dewatering water is expected to be treated to appropriate levels prior to either appropriate off-site disposal
at a permitted facility or discharge at an appropriate approved surface water discharge location.
Construction of a dewatering pad may be necessary to handle saturated soil and sediments. Prior to
disposal, waste characterization samples will be collected from the stockpiled soil.
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A land survey will be conducted of all cleanup infrastructure to be left in place (e.g., impermeable caps,
soil and pavement covers, monitoring wells, etc.). Excavated areas will be restored with clean, imported
backfill to achieve pre-existing elevations and grades and re-vegetated with native vegetation to control
erosion and conform with pre-remedial conditions, to the extent practicable. Restoration will include
returning disturbed areas to pre-existing conditions, and applying seed (native species to the extent
practicable), mulch and/or soil amendments to restore the disturbed areas. Any wetland/floodplain habitat
altered by the remedial action will be restored such that current flood storage capacities and wetlands arc
not diminished after completion of remedial actions. All appropriate plans and specifications (e.g., air
monitoring plan, transportation/trucking plan, dust and odor control plan, soil management plan,
restoration plan, demolition plan for existing structures, as appropriate, erosion and sedimentation control
plan, and health and safety plan) will be prepared to implement this component of the remedy. Necessary
preparation and mobilization activities to implement this remedy component (e.g., removal of vegetation
and debris, as appropriate, installation of temporary fencing, decontamination facilities, soil
stockpile/management areas, trailer, and sanitation facilities) will be developed during the design phase
and implemented during the remedial action.
Long-term monitoring and maintenance will be implemented for capped/covered areas, as well as
Institutional Controls, to ensure the integrity, maintenance, and repair (as necessary ) of caps and cover
systems and prevent contact with the underlying soil, prohibit residential, school, and daycare use of the
Property, and guard against the future vapor intrusion pathway. Long-term monitoring and maintenance
will be conducted for any new and existing remedy infrastructure components and to maintain any
required wetland/ floodplain mitigation and/or stormwater controls. Long-term monitoring of other
environmental media (e.g., groundwater and surface water) will also be conducted to evaluate the
effectiveness of the remedy for soil and sediments. Five Year Reviews will be required since
contamination will be left in place.
Common Components of the Remedy for All Media
Pre-Design Investigations
PDIs will be conducted for all components of the remedy during the RD process to:
• Determine the final number, location, and configuration of extraction wells and other remedial
components; and
• Facilitate the implementation of the chosen cleanup alternatives and map the precise extent of
remediation limits, including the extent of excavation limits and the extent of caps and cover
systems.
Well and piping locations under the DAPL and groundwater hot spots component of the selected remedy,
as well as the location of the treatment system(s), will be designed so as to not interfere with the remedial
infrastructure required for the soil, sediment, LNAPL, and surface water components of the selected
remedy. Similarly, well and piping locations, as well as the location of the LNAPL and groundwater
treatment systems under the LNAPL and surface water component of the selected remedy, will be
designed so as not to interfere with the remedial infrastructure required for the soil and sediment
components and DAPL and groundwater hot spot components of the selected remedy. The exact number.
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location, and configuration of DA PL and groundwater extraction wells, as well as groundwater extraction
wells for the surface water component of the LN A PL/surface water remedy, may be modified based on
the additional information obtained during implementation of the data gaps studies and during the PDI
phase. PDI activities will also focus on extraction well design. The PDIs will evaluate hydraulic data to
revise, update, and support calibration of the existing groundwater flow model. This model will be
updated and used to evaluate optimal placement for the extraction wells and optimal pumping rates for
groundwater and DAPL capture. Such modeling will also provide quantitative insight on methods to
prevent the vertical capture of underlying bedrock groundwater through pumping of deep overburden
groundwater.
Additionally, the precise location of the groundwater treatment systems will be determined as part of the
PDI activities. A sequencing plan will be developed for implementing the soil and sediments remediation
to coordinate work with the remedial actions for DAPL, groundwater hot spots, LNAPL, and surface
water to ensure that remedial activities taken to address contamination in soil and sediments are not
undermined by recontamination from LNAPL and contamination in groundwater and surface water. The
remedial work to address contaminated soil and sediments will be conducted after it is established that
flow from contaminated groundwater is not serving as on ongoing source which could negatively impact
the quality of wetland soil and sediments.
Under both the DAPL/GWHS-3 and LNAPL/SW-3 alternatives, PDIs will be conducted to determine
appropriate locations for discharge of treated groundwater to surface water and refine the
DAPL/groundwater treatment system(s) design, including specific treatment technology unit operations
and components. For the SOIL/SED-2 alternative and the LNAPL-component of the LNAPL/SW-3
alternative, sampling will be conducted to further refine the horizontal and vertical extents of soil and
sediment contamination to be addressed by MPE, excavation, capping, and/or cover systems. Waste
characterization sampling will be conducted, where necessary, to facilitate the proper handling of
remediation wastes for off-site disposal.
Restoration
Restoration of wetlands and aquatic ecosystems affected by remedial activities will be conducted under
all of the remedy components. Any wetlands affected by remedial work will be restored and/or replicated
consistent with the requirements of federal and state wetlands protection laws with native wetland
vegetation and any restoration efforts will be monitored. Mitigation measures will be used to protect
wildlife and aquatic life during remediation, as necessary. Floodplain resources affected by
implementation of the remedy will be addressed via the implementation of measures refined during the
RD phase to ensure that flood storage capacities are not diminished following completion of remedial
actions. Best management practices will be used during construction to minimize temporary impacts to
floodplains and excavated areas will be returned to original grade to avoid diminishing flood storage
capacity. Long-term monitoring of restored areas will be conducted as part of the response actions.
Institutional Controls
In order to protect human health by controlling potential exposures to contaminated soil, sediments,
groundwater, and surface water, and LNAPL and DAPL, the selected remedy relies on the use of
Institutional Controls, including limitations on land and groundwater uses and activities. Institutional
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Controls arc also necessary for the protection of the selected remedy, including limitations on uses and
activities that interfere with or disturb components of the remedy. Institutional Controls will be required
to prev ent residential, school, and daycare uses of the Property. Institutional Controls will also be
necessary to: 1) prohibit the use of groundwater in the OU3 groundwater study area unless it can be
demonstrated to EPA, in consultation with the Commonwealth, that such use will not pose an
unacceptable risk to human health and the environment, cause further migration of the groundwater
contaminant plume, or interfere with the remedy; 2) prevent disturbance of any engineered systems such
as caps and cover systems, and any other new and existing remedy infrastructure components; 3) prevent
contact with soil beneath caps and cover systems; and 4) require a vapor intrusion evaluation and/or vapor
mitigation systems such as vapor barriers or SSDSs be installed if a new building is constructed or altered
on the Property (examples of Institutional Controls include NAULs, GEREs, town ordinance, advisories,
building permit requirements, and other administrative controls). Should someone wish to demonstrate
that there are no unacceptable risks from vapor intrusion and therefore mitigation systems are not
required, an evaluation of vapor intrusion risks (following EPA-approved procedures and subject to EPA
approval) must be performed prior to the building of structures or a change in building structure or usage
on the Property to demonstrate that vapor intrusion risks are within or below EPA's target risk levels (risk
range of 10~4to 106 and/or a target organ HI of 1).
To facilitate future use and redevelopment of the Property consistent with the cleanup. Institutional
Controls will be established to preserve the remedy, and appropriately manage impacted soil and
groundwater encountered during future intrusive activities (e.g., installing subsurface utilities, building
foundations/slabs, etc.) to protect human health and the environment. A groundwater restriction zone or
other mechanism will be established as part of the Institutional Controls for the OU3 groundwater study
area to prevent contact with contaminated groundwater, prevent further migration of the groundwater
contaminant plume, and prevent interference with the remedy until final groundwater cleanup levels arc
selected and achieved in the final remedy for the Site (see Figure 11 in Appendix C of this ROD).
Twenty-eight (28) residential drinking water wells have been sampled at least once, and 20 are monitored
on a quarterly basis to confirm that levels of NDMA do not exceed the upper end of EPA's health-
protective cancer risk range of 0.47 ng/L to 47 ng/'L (see also Section G, SUMMARY OF SITE RISKS,
Section 1 - Human Health Risk Assessment, Risk Characterization, Future Potable Use of Groundwater
and DA PL in Part 2 of this ROD. below), which would result in unacceptable risk to human health based
on cancer health effects. As part of the selected remedy, all current potable and irrigation wells, including
those not currently or previously sampled, will be evaluated to determine whether their use will pose an
unacceptable risk to human health and the environment, cause further migration of the groundwater
contaminant plume, or interfere with the remedy. The extent of groundwater Institutional Controls may
be expanded or reduced, as appropriate, based on new data or information. The details of the Institutional
Controls will be resolved during the pre-design and RD phase in coordination with the parties performing
the remedial action, impacted landowners, local officials, and MassDEP.
Monitoring and Studies
The selected remedy includes long-term monitoring of groundwater and surface water to evaluate remedy
effectiveness.
Five Year Reviews
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At the conclusion of remedy construction, hazardous substances, pollutants, or contaminants will remain
at the Site. Therefore, as required by law, EPA will review the Site remedy to ensure that the remedial
action continues to protect human health and the environment at least once every five years. These Five
Year Reviews will evaluate the components of the remedy for as long as hazardous substances remain on-
site above levels that permit unlimited use and unrestricted exposure. The purpose of the Five Year
Review is to evaluate the implementation and performance of the remedy in order to determine if the
remedy is or will be protective of human health and the environment. The Five Year Review will
document recommendations and follow-up actions as necessary to ensure the long-term protectiveness of
the remedy or bring about protectiveness of a remedy that is not protective. These recommendations
could include providing additional response actions, improving O&M activities, optimizing the remedy,
enforcing access controls and Institutional Controls, and conducting additional studies and investigations.
Remedy Modifications
The selected remedy may change somewhat as a result of the RD and construction processes. Different
numbers and configurations of extraction wells under the DAPL, groundwater, and surface water
alternatives and MPE wells under the LNAPL alternative may be determined based on PDI results and/or
observations during remedy implementation, and their locations and configurations may change. For the
surface water remedy. Plant B will continue to be operated in the short-term until its replacement.
Following the shut-down and demolition of Plant B, an evaluation of Site hydrogeology would be
performed and the necessity of additional extraction wells to prevent groundwater impacts to surface
water would be evaluated, followed by their design and installation. DAPL and groundwater treatment
system components, design, and configuration will all be determined during RD and may differ from the
specific components outlined above.
PDIs will include survey, sampling, and evaluation work to determine the final configuration of remedial
components, further map the extent of remediation limits, and facilitate the implementation of the chosen
remedies. Investigations at the Property will include additional sampling to refine the extent of soil and
sediment contamination to implement the LNAPL and soil and sediments remedies and determine the
volume of hazardous waste to be disposed of off-site at a permitted facility.
Changes to the remedy described in this ROD will be documented in a technical memorandum in the
Administrative Record for the Site, an Explanation of Significant Differences (ESD), or a ROD
Amendment, as appropriate.
3. Summary of the Estimated Remedy Costs
The total estimated total cost of the selected remedy is approximately $48 million. A summary table of
the major capital and annual O&M cost elements for each component of the selected remedy are shown
below and in Table K-l in Appendix B of this ROD. The discount rate used for calculating total present
worth costs was 7%. The timeframe estimated in the FS Report over which cost expenditures arc
calculated is 30 years.
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Component of
Remedy
Capital Cost
O&M - Present Value
(30 years)22
Total Cost - Present
Value23
DAPL GWHS-3
$15,625,318
$24,620,268
$35,497,565
LNAPL/SW-3
$2,278,032
$7,356,000
$6,644,452
SOIL/SED-2
$5,614,205
$1,127,600
$6,072,515
2021 ROD Totals
$23,517,555
$33,103,868
$48,214,532
The information in the cost estimate summary table is based on the best available information regarding
the anticipated scope of the remedial alternatives. 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 alternatives.
Major changes may be documented in the form of a memorandum in the Administrative Record file, an
ESD, or a ROD Amendment. This is an order-of-magnitude engineering cost estimate that is expected to
be within +50 to -30 percent of the actual project cost.
4. Expected Outcomes of the Selected Remedy
The primary expected outcome of the selected interim remedy for DAPL and groundwater hot spots is
that uncontrolled DAPL sources - a major source of contamination to the aquifer and highly toxic - will
be removed and treated. Groundwater hot spots will be removed and treated, thereby limiting the further
spread of hot spot groundwater which acts as source of contamination to the aquifer. The v olume of
DAPL and mass of Site COCs in DAPL and groundwater hot spots that represent an ongoing source to
groundwater, surface water, and sediments will be reduced. Institutional Controls will prevent
unacceptable human exposure to DAPL and contaminated groundwater via ingestion, dermal contact, and
inhalation by showering.
For the selected final remedy for LNAPL and surface water, following completion of the remedial action,
groundwater will no longer serve as a source of continuing impacts to surface water resulting in levels of
Site COCs in Off-Property West Ditch Stream that no longer pose unacceptable human health risks to
current or future trespassers via ingestion and dermal contact. LNAPL that represents a source of Site
COCs to groundwater and a source of TMPs to indoor air, via the subsurface-to-indoor air vapor intrusion
pathway, and that poses unacceptable human health risks to future indoor workers or building occupants
on the Property, will be removed. The migration of LNAPL to East Ditch Stream and the migration of
groundwater containing Site COCs to surface waters including East, South, and Off-Property West Ditch
Streams, which presents adverse ecological impacts, will be prevented.
The expected outcomes of the selected final remedy for soil and sediments include the prevention of
unacceptable human health risks from exposure by a future resident of the Property via ingestion, dermal
contact, or inhalation of airborne dusts. Unacceptable human health risks via the vapor intrusion pathway
by a future indoor worker or building occupant on the Property will be prevented. The leaching of Site
22 Annual O&M costs presented is total present value and includes annual O&M for 30 years.
23 Total Cost - Present Value presented is the sum of capital cost, net present value of periodic cost (separate from
O&M) for 30 years, and net present value of annual O&M for 30 years.
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COCs associated with the Containment Area into groundwater, surface water, and sediments at levels that
pose unacceptable risks to human health and the environment will be prevented. Adverse ecological
impacts associated with exposures to contaminated upland soil and wetland soil and sediments will be
prevented by covering and/or removing and disposing contaminated soil and sediments. Finally, the
further migration of contaminated wetland soil and sediments to nearby wetlands, surface water, drainage
features, and adjoining properties that would result in potential adverse impacts will be prevented.
Groundwater restrictions arc expected to be in place until final cleanup levels are identified in a future
remedy decision for groundwater and achieved. It is anticipated that the selected remedy will also
provide socio-economic and community revitalization impacts such as increased property values,
increased tax revenues due to redevelopment, and enhanced human uses of ecological resources.
The effectiveness of the components of the final remedy for LNAPL, surface water, soil, and sediments
will be determined based upon attainment of the cleanup levels and performance standards outlined in
Tables L-l and L-2 in Appendix B of this ROD. A monitoring program will be implemented in order to
evaluate remedy performance and progress towards attainment of RAOs and cleanup levels. The details
of the monitoring program will be established during the RD phase and will include preparation of a long-
term monitoring plan. Monitoring scope and frequency could change over time based on technical
analysis of the remedy, optimization studies, revised CSM, or other information, as determined by EPA.
To evaluate the interim measures for DAPL and groundwater, monitoring of DAPL, groundwater, and
surface water will be conducted which will, together with the information and data gathered as a result of
the data gaps studies, form the basis for the evaluation of long-term groundwater remedial alternatives,
leading to the selection of a final remedy for groundwater.
Cleanup Levels and Performance Standards
Cleanup levels and performance standards for the final remedy addressing soil, surface water, and
sediments were developed for the Site COCs identified in the human health and ecological risk
assessments. The cleanup levels and performance standards were selected by considering the ARARs,
risk-based PRGs, quantitation limits, and reference/background data. Cleanup levels and performance
standards were identified for Site COCs that posed any of the following:
• An excess lifetime cancer risk (ELCR) in excess of 10 4;
• A Hi greater than 1; or
• A significant ecological risk.
The human health and ecological risk-based cleanup levels and performance standards for soil, sediments,
and surface water arc identified in Tables L-l and L-2 in Appendix B of this ROD (created from Table
2.1-12 of the FS Report Volume 1 and the PRG summary table from Upland Soil (including Containment
Area Soil) and Surface Water at the Olin Chemical Superfund Site (Wood, 2020c). The detailed
documentation of the technical basis and the derivation of the PRGs are included in the May 15, 2020
Ecological Risk Calculations (Wood, 2020b) and the July 1, 2020 Risk Calculations (Wood, 2020c).
Interim Action DAPL and Groundwater Hot Spot Cleanup Levels
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Cleanup levels were not established for DAPL and groundwater hots spots because the interim remedial
actions developed for the Site are focused on removing contaminant mass from the groundwater and
minimizing further impacts to the aquifer rather than risk-based endpoints. DAPL will be addressed by
the selected interim remedy and will target the DAPL pools through increased extraction, thereby
reducing the mass of NDMA24 - the primary COC that drives human health risks - in the DAPL and its
further migration in groundwater. Remediation goals and cleanup levels for groundwater will be
established by EPA in the final ROD for groundwater (OU3).
EPA evaluated several options for where to target initial mass removal actions. Because there is no MCL
for NDMA, EPA established contours at orders of magnitude above the RSL for NDMA in groundwater,
11 ng/'L, and calculated NDMA mass within such contours. NDMA concentration contours of 1,1 (X) ng/L
and 11,000 ng/L were used. Based on the broad NDMA mass difference between the 1,100 and 11,000
ng/L contours (more than 3,000 g),25 a third mass estimate was calculated based on the 5,000 ng/L median
contour.26 Based on the available data, estimates of the mass of NDMA within the three concentration
contours are as follows:27
• Within the 11,000 ng/L NDMA contour = 1,715 g NDMA
• Within the 5,000 ng/L NDMA contour = 4,440 g NDMA
• Within the 1,100 ng/L NDMA contour = 4,747 g NDMA
These estimates show significant NDMA mass in groundwater that exceeds the combined NDMA mass
of 2,573 g within the three DAPL pools. The calculations of NDMA mass show a significant increase in
NDMA mass removal if remediation were targeted to the 5,000 ng/L contour as compared to the 11,000
ng/L contour, but only a modest increase in NDMA mass removal if remediation were targeted to the
1,100 ng/L contour. The 5,000 ng/L contour, which contains an estimated 4,440 g of NDMA, would
require the treatment of approximately 68.4 million gallons of water to remove this mass. The 1,100 ng/L
contour, which contains an estimated 4,747 g of NDMA, would require the treatment of approximately
110.0 million gallons of water, almost twice the volume of water for an additional 307 g of NDMA
removal. Since the goal of the interim action for groundwater is mass remov al, the selected interim
remedy appropriately targets the 5,000 ng/L contour based on mass of NDMA removed and the volume
of groundwater requiring treatment.
24 Based on the available data, the range of NDMA mass estimates for DAPL developed by EPA and Olin range
from 996 to 2,573 grams (g). See further discussion in Updates to Draft 2019 Oil3 RI Report Conclusions (USEPA,
2020b).
25 The figure of 3,000 g represents Olin's estimate of the NDMA mass difference between the 1,100 and 11,000
ng/L contours. EPA's estimate of the NDMA mass difference between these two contours is approximately 2,200 g.
Differences between EPA's and Olin's NDMA mass calculations within the various NDMA concentration contours
were not significant enough to change the general approach to conceptualizing alternatives in the FS Report Volume
II to address DAPL and groundwater hot spots.
26 See Figure 3, N-nitrosodimethylamine (NDMA) Concentrations in Shallow Overburden Groundwater and Figure
4, N-nitrosodimethylamine (NDMA) Concentrations in Deep Overburden Groundwater in Appendix C of this
ROD.
27 These figures represent Olin's estimates of the mass of NDMA within these three concentration contours. EPA's
NDMA mass estimates are 1,361 g, 3,129 g, and 3,599 g for the 11,000 ng/L, 5,000 ng/L, and 1,100 ng/L NDMA
contours, respectively. Differences between EPA's and Olin's NDMA mass calculations within the various NDMA
concentration contours were not significant enough to change the general approach to conceptualizing alternatives in
the FS Report Volume II to address DAPL and groundwater hot spots.
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Included with the interim remedy are a set of Institutional Controls that will prohibit the use of
groundwater in the OU3 groundwater study area unless it can be demonstrated to EPA, in consultation
with the Commonwealth, that such use will not pose an unacceptable risk to human health and the
environment, cause further migration of the groundwater contaminant plume, or interfere with the
remedy. In parallel to the interim remedy, groundwater studies will continue as part of the OU3 RI/FS to
close remaining data gaps and evaluate long-term groundwater remedial alternatives. At the conclusion
of the data gaps investigation for groundwater, EPA will prepare an FS that will evaluate additional
alternatives targeted at restoration of the aquifer. These alternatives will include options for addressing
contamination beyond the 5,000 ng/L contour.
Final Action LNAPL Cleanup Levels
The removal of LNAPL is not based on attainment of media-specific concentrations of specific
contaminants or a chemical-specific ARAR. The selected final action alternative includes LNAPL
recovery that will remove floating LNAPL and will address LNAPL in the smear zone to the extent that
natural fluctuations in the water table reach the extent of the smear zone. Some residual risk will remain,
as this alternative will not remove all LNAPL from soil pores and LNAPL sorbed to soil particles.
Mobile LNAPL will be greatly reduced; removed LNAPL will no longer act as a source of contaminants
to groundwater. Free-phase LNAPL that would otherwise migrate towards and impact surface water will
be removed by the MPE wells, therefore terminating the pathway that poses an unacceptable risk.
Final Action - Surface Water Performance Standards
The OU1/OU2 BHHRA (AMEC, 2015d) concluded that the cancer risk for the trespasser exposed to
COCs in sediments and surface water in Off-Property West Ditch Stream is above the CERCLA
acceptable risk range. The main risk contributor for the receptor is from the combined ingestion and
dermal exposure to surface water for benzo(a)pyrene. The combined ingestion and dermal cancer risk for
benzo(a)pyrene in surface water for the trespasser is 2.51 x 10~4. The benzo(a)pyrene EPC in Off-
Property West Ditch Stream surface water is 2.3 jig/L. The cumulative surface water His for the
adolescent trespasser and for the adult trespasser are both below 1. Therefore, a risk-based surface water
performance standard has been established for benzo(a)pyrene based on a target cancer risk of 1 x 10 4 -
0.9 |iig/L - which will be used to assess the progress of Alternative LNAPL/SW-3 in groundwater
treatment and this alternative's effects on surface water quality. This target cancer risk level was selected
because benzo(a)pyrene was the sole risk driver for exposure to surface water and sediment in Off-
Property West Ditch Stream. In addition, there may be other sources of benzo(a)pyrene not related to the
Site.
The July 2015 Final OU1/OU2 RIReport (AMEC, 2015a) and OU1/OU2 BHHRA (AMEC, 2015d)
indicate potential off-Property sources of benzo(a)pyrcne and other PAHs in Off-Property West Ditch
Stream surface water, including stormwater runoff from parking lots, nearby creosote-treated railroad ties,
and stormwater runoff from roadways. The July 1, 2020 Risk Calculations summarize health risks and
document the basis for human health risk-based PRGs for surface water (Wood, 2020c).
The ecological risk-based COCs for surface water were identified as the Site-related contaminants in
South Ditch Stream surface water with concentrations above screening benchmarks and site-specific
chronic NRWQC. For each medium and exposure scenario, chemicals with HI values above 1 for RME
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scenarios were identified as COC candidates. Ecological risk-based surface water performance standards
have been established for chromium (0.1 mg/'L) and ammonia (9 mg/L), which will be used to assess the
progress of Alternative LNAPL/SW-3 in groundwater treatment and this alternative's effects on surface
water quality.
Final Action - Soil and Sediment Cleanup Levels and Performance Standards
Soil cleanup levels have been established to address human health and ecological risks, and sediment
cleanup levels have been established to address ecological risks.
The OU1/OU2 BHHRA concluded that calculated RME cancer risk and non-cancer HI values were below
10 4 and 1, respectively, for soil exposure (incidental ingestion, dermal contact, and inhalation of soil-
derived dust), and sediments (incidental ingestion and dermal contact) (AMEC, 2015d). However, the
2020 Residential Human Health Risk Evaluation Memo calculated a RME cancer risk of 4.1 x 10 ' and
non-cancer HI = 31 for a future resident based on metals and benzo(a)pyrene for upland soil exposure
(ingestion, dermal contact, and inhalation of airborne dust) (Bluestone, 2020). Because these risks will be
addressed by Institutional Controls, human health-based cleanup levels were not established for upland
soil.
The OU1/OU2 BERA included evaluation of multiple assessment endpoints and measurement endpoints.
Each of the assessment endpoint/measurement endpoint combinations were assigned an Inference Weight
(Low, Medium, and High) used in interpreting the results for the various assessment
endpoint/measurement endpoint combinations. The OU1/OU2 BERA evaluated risks to ecological
receptors based on multiple assessment endpoints and measurement endpoints using a Four-Way
Interpretive Risk Matrix and a Two-Way Interpretive Matrix that had previously been developed for EPA
(pages 5-1 and 5-2 of the OU1/OU2 BERA).
Based on the OLM/OU2 BERA conclusions, ecological risk-based cleanup levels were derived for
chromium and BEHP in soil (upland soil, wetland soil, and streambank soil), chromium and BEHP in
sediments, and chromium and ammonia in surface water. The cleanup levels for upland soil, wetland soil,
streambank soil, and sediments were derived using the risk calculations for food chain exposure modeling
which were identified as having medium or high inference weight in the ecological risk characterization.
For each medium (i.e. upland soil, wetland soil, streambank soil, sediments) and exposure scenario,
chemicals with HI values above 1 for RME scenarios were identified as Site COC candidates. The
cleanup levels for soil and sediments represent concentrations associated with target HI values of 1 or
above.
Final Action Indoor Air Performance Standard
Soil cleanup levels (source medium cleanup levels) that address VI were not established for TMPs due to
the uncertainty with predicting indoor air impacts caused by soil contamination (Wood, 2020b). Based on
information presented in the July 2015 Final OU1/OU2 RI Report (AMEC, 2015a) and the associated
OU1/OU2 BHHRA (AMEC, 2015d), there are no occupied buildings in contact with the ground surface
at the Property in locations where TMPs have been identified in soil,28 and therefore, a complete VI
pathway does not exist under current conditions.
28 An office trailer is currently maintained on the Property, from which Olin staff operate and maintain the Plant B
groundwater remediation system. However, there is open airspace between the trailer floor and the ground surface.
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TMP concentrations in soil within HH-EA-1, HH-EA-3, and HH-EA-7 indicate a potential concern for
subsurface-to-indoor air VI in future occupied buildings. In the OU1/OU2 BHHRA, it was not possible
to estimate Vl-related potential indoor air concentrations and associated industrial/commercial employee
risks for future buildings without significant uncertainty; however, potential VI risks may be addressed by
preventing VI into a building via engineering controls or by removing and/or treating soil with elevated
TMP concentrations.
TMPs are not classified as carcinogens by EPA; therefore, an indoor air performance standard has been
established based on toxicity information for non-cancer effects. The performance standard was set for a
commercial/ industrial indoor worker being on the Property 8 hours per day for 250 days per year. The
calculated indoor air performance standard for TMPs based on a target HQ of 1 is 0.175 mg/m3. Details
supporting the development of this performance standard are included in Section 2.1.3.1 of the FS Report
Volume I.
M. STATUTORY DETERMINATIONS
The remedial action selected for implementation at the Site, which includes an interim action to address
current and potential future risks caused by groundwater contamination and a final action to address all
current and potential future risks caused by LNAPL, surface water, soil, and sediment contamination, is
consistent with CERCLA and, to the extent practicable, the NCP. The selected remedy is protective of
human health and the environment, will comply will ARARs, and is cost-etYective. In addition, the
selected remedy utilizes permanent solutions and alternate treatment technologies or resource recovery
technologies to the maximum extent practicable, and partially satisfies the statutory preference for
treatment that permanently and significantly reduces the mobility, toxicity, or volume of hazardous
substances as a principal element to the maximum extent practicable.
1. The Selected Remedy is Protective of Human Health and the Environment
The selected interim remedy for OU3 for DAPL and groundwater will protect human health and the
environment in the short term, until a final ROD is implemented. The selected remedy will remove and
treat uncontrolled DAPL sources, a major source of contamination to downgradient groundwater, and
extract and treat hot spot groundwater that would otherwise migrate uncontrolled. By removing DAPL
and extracting hot spot groundwater, the timeframe for groundwater restoration may also be decreased.
The selected interim remedy for OU3 will use Institutional Controls to prevent future exposures to
groundwater contaminants.
COCs in groundwater hot spots to be addressed by the selected remedy arc currently above acceptable
levels and pose future unacceptable risks. Available treatment technologies are technically feasible and
have been proven to be effective at other sites to degrade or destroy the groundwater contaminants.
Implementation of the selected interim remedy will not pose unacceptable short-term risks. While
potential adverse cross-media impacts may occur due to the civil site work associated with interim
remedy implementation, the design and implementation of the remedy, and associated treatment and
monitoring efforts will be conducted to minimize impacts to nearby streams and wetlands, including
surface water that receives discharges from the DAPL and groundwater treatment system(s).
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The selected final remedy for 0U1 and OU2 will adequately protect human health and the environment
by eliminating, reducing, or controlling exposures to human and environmental receptors through caps
and cover systems, excavation, treatment, engineering controls, long-term monitoring, and Institutional
Controls.
The selected remedy will reduce potential human health risk levels such that they do not exceed EPA's
target risk range of a total ELCR of 10"6 to 10 4 and/or a non-cancer HI greater than 1.0. It will reduce
potential human health risk levels to protective ARARs levels (i.e., the remedy will comply with ARARs
and risk-based standards derived using TBC criteria). In addition, unacceptable ecological risks
associated with exposure to wetland sediment/soil will be eliminated by permanent removal of impacted
wetland sediment/soil and wetland restoration.
More specifically, the selected remedy for OU1/OU2 includes the following components: a low-
permeability cap that meets RCRA Subtitle D and Massachusetts solid waste landfill performance
standards above the contaminated soil in and near the Containment Area along with closure of the
equalization window, covering all upland soil areas containing elevated levels of Site COCs above
cleanup lev els with clean soil or pav ement, excav ation and off-site disposal of all wetland soil and
sediments containing elevated levels of Site COCs above cleanup levels, and additional vapor intrusion
evaluations to assess risks and/or the use of vapor barriers and/or sub-slab depressurization systems if
buildings are constructed or altered in areas containing soil contaminated with TMPs at levels that may
pose a vapor intrusion risk. The selected remedy for OU2 includes the following components: MPE wells
to extract LNAPL and contaminated groundwater, and groundwater extraction wells to prevent the
overburden groundwater plume from contaminating surface water.
The components of the OU1/OU2 remedy will be protective of human health and the environment by
preventing exposure to and minimize leaching of soil COCs in the Containment Area to groundwater,
eliminating the exposure pathways from upland and wetland soil for ecological receptors, and preventing
the migration of soil vapor into buildings, eliminating future exposures to indoor workers. The
components of the OU2 remedy will be protective of human health and the environment by preventing the
release of LNAPL into East Ditch Stream, as well as using groundwater extraction wells to prevent the
overburden groundwater plume from impacting Site surface water.
Long-term monitoring of groundwater, surface water, and the vapor intrusion pathway will ensure the
remedy remains protective until cleanup levels and performance standards are met. The selected final
remedy for OU1 and OU2 will use Institutional Controls to accomplish the following: prohibit future
residential, school, and daycare use at the Property; maintain the integrity of caps, cover systems, and
other remedial components and prevent the disturbance of any engineered systems and any other new and
existing remedy infrastructure components; prevent contact with soil beneath caps and cover systems; and
require either a vapor intrusion ev aluation or vapor mitigation system be installed if a new building is
constructed or modified on the Property. Implementation of the selected remedy will not pose any
unacceptable short-term risks or cause cross-media impacts.
2. The Selected Remedy Complies with ARARs
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Because the selected remedy for OU3 DAPL and groundwater hot spots is an interim action, compliance
with chemical-specific ARARs is not expected to be achieved at this time. Chemical-specific ARARs
have therefore not been identified. The selected interim remedy for DAPL and groundwater hot spots is a
limited scope action and will comply with location-specific and action-specific ARARs and TBCs
described in Appendix D of this ROD.
The selected final remedy for OU1 and OU2 will comply will all federal and any more stringent state
ARARs identified for the Site. The selected remedy will also incorporate procedures and processes
identified by a number of policies, adv isories, criteria, and guidance documents (To Be Considered). A
detailed list of ARARs/To Be Considered requirements for the selected final remedy for OU1 and OU2 is
included in Appendix D of this ROD. A discussion of the more significant ARAR issues is include
below.
Wetlands Impacts
Issuance of the ROD embodies specific ARARs determinations made by EPA, pursuant to federal
regulatory standards. More specifically, as defined by Section 404(b) of the Clean Water Act and
regulations promulgated under the Act at 40 CFR Parts 230, 231, and 33 CFR Parts 320-323, EPA has
determined, with issuance of this ROD. that the selected remedial action is the Least Environmentally
Damaging Practicable Alternative (LEDPA) for protecting federal jurisdictional wetlands and aquatic
ecosystems at the Site under these standards. The selected remedy includes activities that will impact
wetlands. Extraction wells, piping, and temporary (but possibly permanent) access roads will need to be
installed in the MMB wetlands to address contaminated groundwater beneath the wetlands. In addition,
the excav ation of contaminated sediment will occur in portions of wetlands and surface water bodies.
EPA has determined that because significant levels of contamination exist in sediment and wetland soil
and within OU3 groundwater beneath the MMB wetlands, there is no practicable alternative to
permanently removing the contaminants from these wetlands and from installing the necessary remedial
infrastructure to implement the OU3 interim remedy. EPA has determined that the cleanup activities that
impact wetlands are the LEDPA because they arc necessary for the interim OU3 remedy and will
permanently remove contaminants that are impairing sediments and wetland soil, and that any wetland
resources altered by the cleanup will be restored to original grades and with native vegetation. The
selected remedy provides the best balance of achieving the RAOs with minimizing both temporary and
permanent alteration of wetlands. EPA will minimize potential harm and avoid adverse impacts to
wetlands, to the extent practicable, by using best management practices during excavation and
construction activ ities to minimize harmful impacts on the wetlands, wildlife, or habitat, and by restoring
these areas consistent with federal and state wetlands protections laws. Any wetlands affected by
remedial work will be restored to their original condition as a wetland area if practicable, or a new
wetland area will be created within the same vicinity and any restoration or replacement efforts will be
monitored until the wetland vegetation becomes re-established. Mitigation measures will be used to
protect wildlife and aquatic life during remediation, as necessary.
In compliance with relev ant and appropriate Wetland Protection and Floodplain Management regulations
(44 CFR Part 9), EPA solicited public comment through the Proposed Plan on the proposed cleanup's
impacts on wetland resources within the Proposed Plan. EPA's responses to general comments regarding
wetland issues arc located in Part 3, The Responsiveness Summary, of this ROD.
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Floodplain Impacts
Further, EPA solicited public comment, under 44 CFR Part 9, through the Proposed Plan, on its
determination that there is no practicable alternative to temporarily occupy and/or temporarily modify
portions of the 1 (M)-year and 500-year floodplains within the Site in the MMB wetlands (see Figure 5 in
Appendix C of this ROD) in order to implement the proposed cleanup plan, but after completion of work
there will not be any net loss of flood storage capacity. EPA also solicited public comment on its
determination that the proposed cleanup plan will not result in occupancy and modification of the 500-
year floodplain within the Property (see also Figure 5 in Appendix C of this ROD), that a stormwater
study will be undertaken as part of the PDI phase to confirm that this is the case, and that if impacts are
found to be unavoidable while implementing the cleanup actions, appropriate measures will be
incorporated into the cleanup design and subsequently implemented during the RA phase to ensure that
current flood storage capacities and any adjacent wetlands are not diminished after completion of the
proposed remedial actions. To address remedial measures that may affect floodplain resources, any
excavation will be backfilled with clean fill and then restored to its original grade, to the extent
practicable, so that the current flood storage capacity of these areas and any adjacent wetlands will not be
diminished after completion of the proposed remedial actions. Moreover, EPA will avoid or minimize
potential harmful temporary and permanent impacts on floodplain resources, to the extent practicable,
within the Containment Area and MMB wetlands. Best management practices will be used during
construction, which include erosion control measures, proper re-grading, and restoration and monitoring
of impacted areas. EPA's responses to general comments regarding floodplain issues are located in Part
3, The Responsiveness Summary, of this ROD.
National Historic Preservation Act, Section 106
The National Historic Preservation Act, and the state equivalent law, require that prior to work taking
place, a federal agency consider the effects of its undertaking on historic properties. EPA must consult
with the state historic preservation officer (SHPO) as well as any interested tribal historic preservation
officers (THPO) in making determinations and findings concerning the effects of its undertakings on
historic property.
EPA initiated consultation with the Massachusetts Historical Commission (SHPO) and the Mashpee
Wampanoag Tribe (THPO) in January 2021. At that time, EPA identified the Middlesex Canal
(Middlesex Canal Historic and Archaeological District), located in the off-Property area of the Site and in
close proximity to Maple Meadow Brook, as having historic significance. EPA does not anticipate any
impacts to the Middlesex Canal from the construction or operation of the groundwater remedy. No
remedial infrastructure is planned for the Middlesex Canal or its environs. The Town of Wilmington has
designated an area within the Town - Wilmington Centre Village - from Middlesex Drive and Church
Street, from Adams Street to Wildwood Cemetery, as a historic district. Other places and landmarks
within the Town are also listed on the National Register of Historic Places, but such places and structures
are not within the bounds of the Property, nor within off-Property areas where remedial equipment may
be located for the purposes of implementing the remedy.
EPA will continue to consult with the SHPO and THPO during the RD to determine whether
implementation of the remedy will adversely impact historic, archaeological, or cultural resources eligible
for, or already listed on, the National Register of Historic Places. If any such adverse impacts cannot be
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avoided, EPA will work with the SHPO and THPO to develop a set of activities to mitigate those impacts,
which will be memorialized in a Memorandum of Agreement between the parties.
3. The Selected Remedy is Cost-Effective
In EPA's judgment, the selected remedy is cost-effective because the remedy 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 state 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, or volume through
treatment; and short-term effectiveness, in combination. The overall effectiveness of each alternative was
then compared to the alternative's cost to determine cost-effectiveness. The relationship of the overall
effectiveness of the remedial alternatives was determined to be proportional to their costs and hence
represents a reasonable value for the money to be spent.
The combined DAPL and groundwater hot spots, LNAPL and surface water, and soil and sediment
alternatives range in cost from $0 to $83.7 million. The range in estimated cost for the four
DAPL/GWHS alternatives is $0 (DAPL/GWHS-1: No-Action) to $40.5 million (DAPL/GWHS-4). The
range in estimated cost for the four LNAPL/SW alternatives is $0 (LNAPL/SW-1: No Action) to $9
million (LNAPL/SW-2 and 4). The range in estimated cost for the four SOIL/SED alternatives is $0
(SOIL/SED-1; No Action) to $34.2 million (SOIL/SED-4).
The selected interim remedy for DAPL and groundwater hot spots. Alternative DAPL/GWHS-3, is
comparable to Alternative DAPL/GWHS-4 in terms of long-term effectiveness, reduction of toxicity,
mobility, or volume through treatment, and short-term effectiveness. Both alternatives would achieve the
removal and treatment of an estimated 14.8 million gallons of DAPL in an estimated 6 years, which is
approximately 5% more DAPL than would be removed and treated under Alternative DAPL/GWHS-2 in
an estimated 20 years. Alternative DAPL/GWHS-4 would remove and treat an estimated 110.3 million
gallons of hot spot groundwater in an estimated 8 years, which is 41.9 million gallons more than would be
removed and treated under Alternative DAPL/GWH S-3 in an estimated 6.5 years. Howev er, Alternative
DAPL/GWHS-4 would remove only an additional 307 g of N DM A (approximately 4%) from hot spot
groundwater and DAPL compared to Alternative DAPL/GWHS-3 (7,320 g of N DM A for DAPL/GWHS-
4 and 7,013 g of N DM A for DAPL/GWHS-3). In contrast. Alternative DAPL/GWHS-2 would only
remove and treat 17.1 million gallons of hot spot groundwater in an estimated two to three years, resulting
in removal and treatment of 4,159 g of NDMA.
As the number of extraction wells increases from Alternative DAPL/GWHS-2 to Alternative
DAPL/GWHS-4, there are increasing short-term impacts to the community, workers, and the environment
from well drilling and associated construction activities and piping installations (an estimated 7-8 wells,
26 wells, and 32 wells under Alternatives DAPL-GWHS-2, -3, and -4, respectively). The total net present
value of the active alternatives is as follows; DAPL/GWHS-2 - $22.5 million; DAPL/GWHS-3 - $35.5
million; and DAPL/GWHS-4 - $40.5 million. Alternative DAPL/GWHS-3 would achieve approximately
4% less of a reduction of NDMA mass in overburden groundwater, but is nearly $5 million less expensive
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than Alternative DAPL/GW-4, and has slightly higher short-term effectiveness. Alternative
DAPL/GWHS-3's costs are proportional to its overall effectiveness and it is therefore cost-effective.
The selected final remedy for LNAPL and surface water, Alternative LNAPL/SW-3, would remove an
estimated 90% of the LNAPL for treatment, compared with an estimated 65% removal of LNAPL for
Alternative LNAPL/SW-2. Although LNAPL/SW-4 would excavate all of the LNAPL, it would achieve
less overall reduction in toxicity, mobility, or volume through treatment because the LNAPL-
contaminated soil to be excavated will only be treated to a limited degree to facilitate off-site disposal of
the material. Under all of the LNAPL/SW alternatives, groundwater containing COCs that would
otherwise enter the streams would be permanently removed and treated, with the time to construct the
PRBs in Alternative LNAPL/SW-4 being approximately two months and the time to construct the
groundwater extraction and treatment system(s) under Alternatives LNAPL/SW-2 and -3 being two to
three years. An estimated one year is the timeframe for remediating LNAPL under Alternatives
LNAPL/SW-2 through -4.
Alternative LNAPL/SW-4 has the highest short-term impacts due to potential risks to the community
from releases of vapor and transport of materials through the community, as well as structural stability
issues in excavating close to the MBTA railroad tracks, and trenching for the PRBs occuring in sensitive
environmental areas. Alternatives LNAPL/SW-2 and -3 are expected to pose minimal short-term risk to
the community, workers, and the environment. The total net present value of the active alternatives is as
follows: LNAPL/SW-2 - $9 million; LNAPL/SW-3 - $6.6 million; and LNAPL/SW-4 - $9 million.
Alternative LNAPL/SW-3's costs are proportional to its overall effectiveness and it is therefore cost-
effective.
The selected final remedy for soil and sediments. Alternative SOIL/SED-2, would be comparably
effective in the long term to Alternative SOIL/SED-3. Both alternatives would leave some contaminants
in place but would nonetheless be protective of human health and the environment. Under Alternative
SOIL/SED-2, upland soil contaminants would be covered in place, which may pose potential future
ecological risk if contaminants were to be exposed. Under Alternative SOIL/SED-3, upland soil
contaminants would remain below one foot, which also could pose potential future ecological risk if
contaminants were to be exposed. Both of these alternatives include long-term maintenance and would be
protected by Institutional Controls to prevent disturbance of the soil covers. Additionally, under
Alternative SOIL/SED-3, some TMPs would likely remain sorbed to soil and not be fully removed but
vapor capture would effectively control TMPs during treatment and residual risk would be low.
Alternative SOIL/SED-4 would be the most effective in the long-term, as this alternative provides for
removal of greater quantities of contaminated soil and contamination that is furthest from the surface than
cither Alternative SOIL/SED-2 or -3.
All of the SOIL/SED alternatives would excavate and disposal off-site wetland soil and sediments with
contaminants above cleanup levels. Alternatives SOIL/SED-2 and -4 provide comparably low reductions
in contaminant toxicity, mobility, or volume through treatment because the components of these
alternatives require cither caps/covers or excavation and clean soil covers, as opposed to primary
treatment. Alternative SOIL/SED-3 provides a slightly higher degree of reduction in contaminant
toxicity, mobility, or volume through treatment because it contains the only active treatment component -
air sparging SVE for TMPs. Alternative SOIL/SED-2 would be the most effective in the short-term
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because it requires the smallest volume of contaminated soil and sediments (approximately 6,000 tons,
compared with 10,000 tons for Alternative SOIL/SED-3 and 130,000 tons for SOIL/SED-4) to be
transported off site, and all of the SOIL'S ED alternatives would be constructed in approximately two
years.
Additionally, the required deep soil excavation and soil and water management for Alternative SOIL-
SED-4 would pose a high potential for direct contact and vapor exposure compared to the other
alternatives, and this alternative may also require excavation support to protect the railroad, which would
entail greater risks to workers. Short-term environmental impacts are considerable under Alternatives
SOIL/SED-3 and -4, but less so under Alternative SOIL/SED-2 due to the smaller area of excavation.
The total net present value of the active alternatives is as follows: SOIL/SED-2 - $6 million; SOIL/SED-3
- $7.5 million; and SOIL/SED-4 - $34.2 million. Alternative SOIL SED-2's costs are proportional to its
overall effectiveness and it is therefore cost-effective.
Table K-l in Appendix B helps demonstrate the cost-effectiveness of the selected remedies.
4. The Selected Remedy Utilizes Permanent Solutions and Alternative Treatment or Resource
Recovery Technologies to the Maximum Extent Practicable
EPA has determined that the selected remedy for DAPL and groundwater hot spots, as an interim
remedial action, represents the maximum extent to which permanent solutions and treatment technologies
can be utilized in a practicable manner at the Site. EPA also determined that the selected remedy for
DAPL and groundwater hot spots provides the best balance of tradeoffs in terms of the five balancing
criteria, while also considering the statutory preference for treatment as a principal element and
considering state and community acceptance.
The selected remedy for DAPL and groundwater hot spots satisfies the long-term effectiveness criterion
by removing DAPL and hot spot groundwater. The treatment of DAPL and hot spot groundwater is
expected to effectively decrease contaminant mobility and volume and may also decrease the potential for
exposure to Site-related contaminants. The selected remedy for DAPL and groundwater hot spots does
not present any short-term risks that cannot be readily mitigated. The interim remedial action can be
implemented using available technology and resources.
Once the Agency identified those final alternatives for LNAPL and surface water, and soil and sediments
that attain or, as appropriate, waive ARARs and that are protective of human health and the environment,
EPA identified which alternatives utilize permanent solutions and alternative treatment technologies or
resource recovery technologies to the maximum extent practicable. This determination was made by
deciding which one of the identified alternatives provides the best balance of trade-offs among
alternatives in terms of: 1) long-term effectiveness and permanence; 2) reduction of toxicity, mobility, or
volume through treatment; 3) short-term effectiveness; 4) implementability; and 5) cost. The balancing
test emphasized long-term effectiveness and permanence and the reduction of toxicity, mobility, or
volume through treatment; and considered the preference for treatment as a principal element, the bias
against off-site land disposal of untreated waste, and community and state acceptance. The selected final
remedies for LNAPL and surface water, and soil and sediments provide the best balance of trade-offs
among the alternatives.
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The selected final remedy for LNAPL, surface water, soil, and sediments is protective of human health
and the environment, uses proven cleanup technologies such as caps and cover systems, excavation, off-
site disposal, treatment, engineering controls and Institutional Controls, and is cost-effective, while
achieving the Site-specific cleanup objectives in a reasonable timeframe. This cleanup approach provides
both short- and long-term protection of human health and the environment; attains all applicable or
relevant and appropriate federal and state environmental laws and regulations; reduces the toxicity,
mobility, or volume of contaminated soil, sediments, and groundwater impacting surface water through
treatment, to the maximum extent practicable; utilizes permanent solutions and uses land use restrictions
to prevent unacceptable exposures in the future to the contaminants that will remain at the Site.
5. The Selected Remedy Partially Satisfies the Preference for Treatment Which Permanently and
Significantly Reduces the Toxicity, Mobility, or Volume of the Hazardous Substances as a
Principal Element
As indicated in Section E, STATUTORY DETERMINATIONS of Part 1 of this ROD, as an interim
solution, the limited scope of the interim remedy for DAPL and groundwater hot spots is not intended to
address the statutory mandate to utilize permanent solutions and alternative treatment technologies to the
maximum extent practicable. Because the interim remedy does not constitute the final remedy for
groundwater at the Site, the statutory preference in CERCLA Section 121(b)(1) for remedies that employ
treatment that reduces toxicity, mobility, or volume as a principal clement will be addressed by the final
response action. Nonetheless, the interim remedy does employ active treatment components, including
the methodologies described above in Section L, THE SELECTED REMEDY of Part 2 of this ROD,
to address the principal threat waste of NDMA-containing DAPL and groundwater hot spots, with off-site
disposal of the residual solids resulting from DAPL treatment.
The principal elements of the selected final remedy for OU1 and OU2 addressing LNAPL, surface water,
soil, and sediments are source control and management migration. The final remedy includes treatment
of the recovered LNAPL via oil/water separation, the soil vapor via GAC, and the captured groundwater
via the same treatment system(s) as for hot spot groundwater before discharge to surface water.
Additionally, excavated soil or sediments that exhibit a hazardous waste characteristic or soil/sediments
that are excavated from below the water table would be treated (stabilized) by adding Portland cement,
lime, or another suitable stabilizing agent to reduce contaminant mobility prior to off-site disposal. Water
generated from excavation/dcwatering soil prior to off-site disposal would also be treated to reduce
toxicity prior to discharge to surface waters. With the exception of these treatment elements, the selected
final remedy for OU1 and OU2 soil and sediments includes either caps/covers or excavation and clean
soil covers, as opposed to primary treatment, to reduce the toxicity, mobility, and volume of contaminated
soil and sediments. By using treatment as a significant portion of the interim remedy for DAPL and
groundwater hot spots and partially for the final remedy for LNAPL, surface water, soil, and sediments,
the statutory preference for remedies that employ treatment as a principal element is partially satisfied.
6. Five Year Reviews of the Selected Remedy are Required
At the conclusion of the remedy construction, hazardous substances, pollutants, or contaminants will
remain at the Site. Therefore, as required by law, EPA will review the Site remedy to ensure that the
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remedial action continues to protect human health and the environment at least once every five years as
part of the Agency's Five Year Reviews for the entire Site. These Five Year Reviews will evaluate the
components of the Site remedy for as long as contaminated media above CERCLA risk levels remain in
place.
N. DOCUMENTATION OF NO SIGNIFICANT CHANGES
EPA presented the Olin Chemical Proposed Plan for remediation of the Site to the public for review and
comment on August 10, 2020. The Proposed Plan described the alternatives considered and EPA's
preferred alternatives for the selected remedy.
EPA rev iewed all verbal comments submitted during the formal public hearing on September 22, 2020
and reviewed all written comments submitted during the public comment period, which began on August
26, 2020, and ended on October 26,2020. Based upon a review of the comments, EPA determined that
one change to the August 2020 Proposed Plan is necessary based on a comment that the PRG for
ammonia in surface water is too high.
In response to this comment, EPA re-evaluated the surface water performance standards for ammonia (sec
Nobis, 2021). The surface water PRGs for ammonia were calculated using procedures described in the
Aquatic Life Ambient Water Quality Criterion for Ammonia - Freshwater (USEPA, 2013a). The
Criterion Continuous Concentration (CCC) is a value below which adverse effects would not be expected
for the majority of aquatic receptors. For ammonia, the CCC is based in part on the temperature and pH
of the water body or stream. EPA believes that the site-specific assumptions used for pH are appropriate,
and pH has been, overall, less variable over time in both the South Ditch Stream and East Ditch Stream.
However, EPA believes that a slight adjustment in the PRG is needed based on the assumptions used for
temperature. The PRG for ammonia presented in the Proposed Plan was based on an average spring
instream temperature of 7.13 °C for East Ditch Stream and 6.92°C for South Ditch Stream. While EPA
agrees that generally spring temperatures should be utilized as the basis, EPA believ es that it is more
appropriate to use an average of the in-stream temperatures in late spring (between May - June, not
January - March as was utilized in the Proposed Plan). Late spring temperatures reflect a period when
aquatic receptors will be more active, and epi-benthic organisms that are exposed to ambient water will be
present in the water column. Also, the BERA assumes that the Marsh Wren and Green Heron may forage
on-site. Adjusting to late spring temperatures would account for the time when both species would be
present and breeding in New England. Therefore, EPA believes that the performance standard should be
adjusted to 9 mg/L from 15 mg/L in the Proposed Plan, based on an in-strcam temperature of 18 °C and
pH of 6.6 (see Table L-2 in Appendix B of this ROD). The in-stream temperature is the 95% upper
confidence level (UCL) of the temperature values from mid-May through June for the East Ditch Stream.
Additionally, EPA is clarifying that the proposed indoor air cleanup level for TMPs in upland soil
included in Table 2 of the August 2020 Proposed Plan has been reclassified as a "performance standard."
EPA has decided that the term "performance standard" is appropriate with regards to TMPs because the
TMPs component of the selected remedy does not include activ e treatment of TMPs in soil. Rather,
buildings constructed on the Property in the future will be required to meet the specified performance
standard for indoor air.
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O. STATE ROLE
The Commonwealth of Massachusetts, through MassDEP concurs with the selected remedy for the Site.
A copy of the declaration of MassDEP's concurrence is attached as Appendix A of this ROD.
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Record of Decision
Part 3: Responsiveness Summary
PART 3: THE RESPONSIVENESS SUMMARY
A. PUBLIC COMMENTS AND EPA RESPONSES
EPA published the notice of availability of the Proposed Plan and Administrative Record for the Olin
Chemical Superfund Site (Site) in the Wilmington Town Crier on August 12,2020 and released the
Proposed Plan to the public by posting a publicly accessible link on EPA's website.
From August 26, 2020 through September 25, 2020, EPA held a thirty-day public comment period to
accept public comments on the alternatives presented in the Feasibility Study (FS) and Proposed Plan,
and on any other documents previously released to the public. In response to a request from a community
member, EPA extended the public comment period an additional thirty days - through October 26, 2020
- for a total of sixty days. On August 25, 2020, EPA held a public informational meeting to prov ide an
overview of the Site history and investigation findings, describe EPA's Proposed Plan, and answer
questions. On September 22,2020, EPA held a Public Hearing to accept oral comments.
In order to adhere to guidance from the Centers for Disease Control (CDC) and state and local restrictions
on large gatherings due to the Covid-19 pandemic, both the August 25, 2020 and September 22, 2020
events were conducted virtually via the Adobe Connect platform with closed captioning, including an
option to connect to the conference audio via telephone. Both events were simulcast on the local cable
access television station - WCTV. Prior to the informational meeting, a copy of EPA's presentation,
including the audio recording of EPA's remarks, was available on EPA's webpage for the Site.
During the Public Hearing, three comments were received from local elected officials, one comment was
received from a state elected official, four comments were received from members of the local
Community Advisory Group (CAG), and two comments were received from Wilmington residents.
Additionally, 22 sets of written comments were received from Wilmington residents, the Town of
Wilmington Board of Selectmen and the Town's consultant, the Wilmington Environmental Restoration
Committee (WERC), Olin Corporation (Olin), Wilmington Woburn Intermodal LLC (WWI) and
members of the Massachusetts Institute of Technology (MIT) community during the public comment
period. Outlined below is a summary of comments receiv ed from the public and other interested parties
during the public comment period and EPA's response to those comments. The full text of both the
written and oral comments received during the comment period has been included in the Administrative
Record for the Site.
B. SUMMARY OF COMMENTS RECEIV ED AT THE SEPTEMBER 22, 2020 PUBLIC
HEARING
Comment #1 (Jeffrey Hull, Town Manager; Jonathan Eaton, Chairman, Wilmington Board of
Selectmen; and Stephanie Baima, WERC)
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The goal of the groundwater remediation should be the restoration of the Town of Wilmington's drinking
water.
EPA Response:
The National Oil and Hazardous Substances Pollution Contingency Plan (NCP). the regulations
governing the assessment and cleanup of sites under Superfund, describes EPA's expectations for
groundwater restoration and states that EPA expects to return usable ground waters to their
beneficial uses wherever practicable, within a timeframe that is reasonable given the particular
circumstances of the site. When restoration of ground water to beneficial uses is not practicable,
EPA expects to prev ent further migration of the plume, prev ent exposure to the contaminated
ground water, and evaluate further risk reduction. 40 C.F.R. § 300.430(a)(l)(iii)(F). Portions of
the aquifer at the Site are classified as drinking water sources. Furthermore, the Massachusetts
Department of Environmental Protection (MassDEP) has assigned a high use and value for the
Site area aquifer in its Groundwater Use and Value Determination (MassDEP, 2010a). As such,
the goal for the groundwater would be to restore this aquifer to its beneficial use, unless it is
determined not to be practicable. There is insufficient data at this time to make this
determination. Further work is underway to finish characterizing the nature and extent of
contamination in the aquifer and to develop and ev aluate a set of alternatives to address the
groundwater contamination. Once this investigation is completed, EPA will issue a final Record
of Decision (ROD) for groundwater identifying the final cleanup goals for groundwater at the
Site.
Comment #2
(Jeffrey Hull, Town Manager) Site redevelopment must wait for the completion of remedial activities or
work around any remedial activities.
(Suzanne Sullivan, WERC) Any remaining data gaps should be filled prior to redevelopment and
closeout of Operable Unit 1 (OU1) and Operable Unit 2 (OU2). Operable Unit 3 (OU3 ) should not be
separated from OU 1 and OU2.
EPA Response:
While EPA does not dictate the terms of redevelopment, if redevelopment occurs, EPA will
ensure that such redevelopment does not adversely impact the selected remedy for the Site and
EPA's efforts to collect more data as needed to select and implement a final remedy for
groundwater (OU3). EPA will also ensure that the developer refrains from using the Olin
property (Property) in any manner that would interfere with or adversely affect the
implementation, integrity, or protectiveness of any past or future response actions.
EPA has divided the cleanup of the Site into Operable Units (OUs) in order to expedite the
remediation for those source areas considered to be sufficiently characterized to move forward
with remedy selection. While the primary sources of impacts to groundwater (OU3) are
addressed as interim actions in this selected remedy, significant data gaps remain regarding the
extent of groundwater impacts, particularly in bedrock. The OU3 Remedial Investigation (RI) is
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ongoing and will incorporate the additional chemical, geological, and hydrogeological data
collected. EPA is working closely with Olin to ensure that the OU3 RI, including the ongoing
data gaps investigation, is comprehensive and will result in data of sufficient quality and quantity
to support development of an FS and final remedy for Site groundwater.
Comment #3
(Jeffrey Hull, Town Manager) The remediation goal for the groundwater hot spot should be lowered
below 5,000 nanograms per Liter (ng/L) as soon as practicable.
(Gary Mercer and Suzanne Sullivan, WERC) The groundwater hot spot should use 1,100 ng/L as the
remedial goal.
EPA Response:
Remediation goals and cleanup levels for groundwater will be established by EPA in the final
remedy for groundwater (OU3). The 5,000 ng/L and 1,100 ng/L n-nitrosodimethylamine
(NDMA) concentration contours are not remediation goals. The 5,000 ng/L contour is the
approximate area that EPA is targeting to begin mass removal of contaminants from the aquifer
as an interim action. EPA evaluated several options for where to target the initial mass removal
actions, including targeting the areas defined by the 1,100 ng/L, 5,000 ng/L, and 11,000 ng/L
NDMA contours. According to Olin's calculations, the 5,000 ng/L contour contains an estimated
4,440 grams (g) of NDMA and would require the treatment of approximately 68.4 million gallons
of water to remove this mass. The 1,100 ng/L contour contains an estimated 4,747 g of NDMA
and would require the treatment of approximately 110.3 million gallons of water, almost twice the
volume of water for an additional 307 g of NDMA removal. Since the goal of the interim action
for groundwater is mass removal, the selected remedy appropriately targets the 5,000 ng/L
contour based on mass of NDMA removed and the volume of groundwater requiring treatment.
At the conclusion of the data gaps investigation for groundwater, EPA will prepare an FS that
will ev aluate additional alternatives targeted at restoration of the aquifer. These alternatives will
include options for addressing the contamination beyond the 5,000 ng/L contour. The final ROD
for OU3 will specify the final cleanup goals and the approach for achieving those goals.
Comment #4 (Jeffrey Hull, Town Manager)
Discharge of treated groundwater should minimize the transfer of groundwater from one watershed to the
other.
EPA Response:
EPA agrees that in general, treated groundwater should be returned to the originating watershed
to the extent feasible. However, years of data demonstrate that the water table across the
impacted area is very flat with frequent mixing. Also, Dense Aqueous Phase Liquid (DAPL) and
impacted groundwater within the bedrock fractures move independently from the watershed
divide. Regardless, EPA considers the Site area aquifer (that is, groundwater from both
watersheds) to be of high value, and the selected remedy includes extraction of groundwater,
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treatment at a newly constructed groundwater treatment system(s), and discharge to surface
water. While the precise discharge location will be determined during the pre-design
investigations (PDIs) of the Remedial Design (RD) phase, groundwater is not likely to be
recharged under the selected remedy. However, long-term groundwater and surface water
monitoring will be conducted, which will include evaluation of the impacts of extraction and
discharge.
Comment #5 (Jeffrey Hull, Town Manager)
A permanent cap should be installed over the Containment Area.
EPA Response:
EPA agrees with the comment. The cap over the Containment Area will be a permanent feature.
The remedial alternative including the cap also includes provisions for long-term monitoring and
maintenance to ensure the cap's continued integrity and effectiveness. The cap will be subject to
Five Year Reviews by EPA for as long as contamination remains in place above criteria allowing
for unrestricted use (residential criteria).
Comment #6 (Jeffrey Hull, Town Manager and Jonathan Eaton, Chairman, Wilmington Board of
Selectmen)
The Town of Wilmington is concerned about the imposition of restrictions of wells in the area and would
like to receive examples of regulations or bylaws that EPA has developed for other communities.
EPA Response:
Comment noted. EPA will share examples of regulations developed by and for other
communities. Institutional Controls on groundwater use are frequently implemented as part of
remedies for Superfund sites. EPA's primary objective is the protection of public health;
however, EPA understands the unintended consequences of overly restrictiv e controls. EPA will
work closely and cooperatively with the Town of Wilmington to develop restrictions which
provide for as much flexibility as possible with the goal of ensuring that members of the
community are not exposed to contamination associated with the Site. EPA's general goals for
the Institutional Controls include making sure that residents and other community members are
not extracting water that is unsafe to use, and ensuring that groundwater extraction that may
interfere with the implementation of EPA's remedy does not occur. One example of Institutional
Controls is the Groundwater Management Zone created by the Town of Durham, Connecticut for
the Durham Meadows Superfund Site (available at: https://ecode360.com/30752082).
Comment #7 (Jomarie O'Mahonv)
The remedy selection should not consider cost.
EPA Response:
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EPA is required by statute and regulation to consider cost in the Superfund remedy selection
process. See e.g., 42 U.S.C. § 9621(a)-(b); 40 C.F.R. §§ 300.430(e)(7)(iii) and430(f)(l)(ii)(D).
In addition, cost is included in EPA guidance (Guidance for Conducting Remedial Investigations
and Feasibility Studies under CERCLA. Interim Final October 1988. EPA/540/H-89/004) as a
primary balancing criterion, along with long-term effectiveness and permanence, reduction of
toxicity, mobility, and volume through treatment, short-term effectiveness, and implementability.
The threshold criteria that must be met for remedy selection are overall protection of human
health and the environment and compliance with Applicable and Relevant and Appropriate
Requirements (ARARs). The preamble to the 1990 NCP (page 55 FR 8728 available at:
https://semspub.epa.gov/work/HQ/174999.pdf and beginning on page 161 of the 376-page pdf)
states in part (emphasis added):
...EPA notes that many alternatives will be protective but will achieve that protection
through different methods or combinations of methods ...alternatives may emerge from
the detailed analysis as comparably "effective," in terms of the three effectiveness
criteria of long-term effectiveness and permanence, reduction of toxicity, mobility or
volume through treatment and short-term effectiveness: in that event, the least costly of
the comparably effective alternatives would be identified as cost-effective while the
others would not. However, because the remedy selection process usually involves
consideration of a range of distinct alternatives that generally vary in their effectiveness
and cost, most often a comparative analysis of the relationship between the overall
effectiveness of the alternatives and their costs will be required to determine which
alternatives are cost-effective (i.e., provide overall effectiveness proportional to their
costs)...
The preamble to the 1985 NCP (see 55 FR 8727 available at
https://semspub.epa.gov/work/HO/174999.pdf and beginning on page 158 of the 376-page pdf,
referencing 50 FR 47921) also explains the role of cost and states in part (emphasis added):
...The approach embodied in today's rule is to select a cost-effective alternative from a
range of remedies that protects the public health and welfare and the environment. First,
it is clear that if all the remedies examined are equally feasible, reliable, and provide the
same level of protection, the lead asencv will select the least expensive remedy. Second,
where all factors are not equal, the lead agency must evaluate the cost, level of
protection, and reliability of each alternative. In evaluating the cost of remedial
alternatives, the lead agency must consider not only immediate capital costs, but also the
costs of operating and maintaining the remedy for the period required to protect public
health and welfare and the environment. For example, the lead agency might select a
treatment or destruction technology with a higher capital cost than long-term
containment because treatment or destruction might offer a permanent solution to the
problem...
* * *
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...Finally, the lead agency would not always select the most protective option, regardless
of cost. The lead agency would instead consider costs, technology, reliability,
administrative and other concerns, and their effects on public health and welfare and the
environment. This allows selection of an alternative that is the most appropriate for the
specific site in question...
The preamble to the 1990 NCP states that it continues the approach outlined in the preamble to
the 1985 NCP. The preamble (page 55 FR 8727) states in part:
...Today's rule continues the approach embodied in the 1985 NCP, although some of the
terminology has changed. First, the approach promulgated today requires that
alternatives are determined to be adequately protective and ARAR-compliant before cost-
effectiveness is considered in remedy selection (see § 3Q0.430(f)(l)(ii)(D)). Second,
today's rule recognizes that a range of alternatives can be protective and ARAR-
compliant, and that cost is a legitimate factor for choosing among such alternatives...
Comment #8 (Gary Mercer, WERC)
An alternative should be developed for the removal of all impacted soils from within the Containment
Area.
EPA Response:
EPA tasked Olin with developing an excavation and disposal alternative for Containment Area
soil. This was developed in the Interim Action Feasibility Study (FSReport Volume II; Olin,
2020b) as "Alternative CA-3: Targeted Soil Removal." EPA's intent in developing this remedial
option for the Containment Area was to establish an excavation alternative for all areas within the
Containment Area where concentrations of Site contaminants exceed the Preliminary
Remediation Goals (PRGs) for the Site. To conceptualize the alternative, excavation areas were
assumed based on existing soil data where PRGs of 3 milligrams per kilogram (mg/kg) for bis-2-
ethylhexylphthalate (BEHP) or 1,000 mg/kg for chromium were exceeded. The water table
within the Containment Area is generally around 8 feet (ft) below ground surface (bgs).
Assuming an excavation depth of 10 ft bgs yielded an in-situ volume of approximately 45,000
cubic yards of material to be excavated. However, given the limited sampling data from the
Containment Area, EPA believes the actual volume would likely be significantly larger upon
execution of the alternative. The limits of the excavation areas would be determined based on
PDIs during the RD phase.
Significant implementability and worker safety concerns are associated with Alternative CA-3
with regard to shoring up 10-foot plus excavations across the Containment Area feature to
address structural stability concerns, handling and transporting the large v olume of waste
materials off-site, and impacts to the community from increased transportation of hazardous
materials, backfill, and other remedy-related equipment. The capping alternative selected for the
Containment Area eliminates risks to human health and ecological receptors from direct exposure
to Site contaminants, and prevents leaching of Site contaminants into groundwater, surface water,
and sediments at levels that would pose unacceptable risks to human health and the environment.
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while creating the least risk and impacts to the community by handling the least amount of
contaminated materials.
Comment #9 (Gary Mercer, WERC)
An alternative should be developed to consolidate impacted soils such as upland soils and
trimethylpentene (TMP)-impacted soils within the Containment Area.
EPA Response:
EPA did consider an alternative that involved consolidation of impacted soil on the Property
within the Containment Area. However, the alternative was screened out from consideration for
two reasons. First, upland soil poses an ecological risk to birds that may feed in the area. These
soils do not pose a significant risk of leaching to groundwater; therefore, an impermeable or low-
permeability cap is not needed to eliminate the threat. Second, the volume of upland soil posing a
threat to ecological receptors and TMP-containing soil posing a potential human health threat as
presented in the FS was thought to significantly underestimate the actual volume. Although the
FS depicts these areas to be finite based on the sampling conducted during the RI, the sampling
data used to estimate these volumes of impacted soil are limited; the impacted areas requiring
remediation are likely to be much larger, resulting in significantly larger volumes to manage.
EPA anticipated that the contamination posing unacceptable ecological and human health threats
was likely to be more w idespread and would require extensive excavation of large volumes of
soil which were not likely to fit within the footprint of the Containment Area.
According to the FS Report Volume I (Olm, 2020a), the total volume of soil that could be
consolidated under the cap is 12,808 cubic yards (cy) or approximately 345,800 cubic feet (cf).
This total was found by adding the volume of TMP-containing soil (5,648 cy), upland soil from 0
to 1 foot (ft) bgs (2,400 cy) minus an estimated 240 cy that would need to be transported off-site
as hazardous waste for 2,160 cy total, and wetland soil and sediments from 0-1 ft bgs (roughly
5,000 cv). The area of the cap is approximately 200,000 square feet (sq. ft) or roughly 4.6 acres.
Assuming that the slurry wall is fairly close to the edge of the cap, placing excavated soil within
the Containment Area in a 1 ft-thick layer would use 1,613 cy per acre-ft. Taking the total volume
of impacted soil of 12,808 cy and dividing by 1,613 cy per acre-ft yields 7.9 acre-ft. Assuming
the entire cap area is used, 7.9 acre-ft divided by 4.6 acres yields a 1.12 ft elevation increase
across the entire cap area. Assuming only half the cap is used would result in 7.9 acre-ft being
divided by 2.3 acres, which yields a 3.4 ft elevation increase across half the cap area.
While these estimates may suggest that the volume of impacted upland and TMP-containing soil
on the Property may be reasonably consolidated within the Containment Area, these volumes
very likely underestimate the actual volume of impacted soil that would be determined during the
PDI component of the RD phase. Since capping these soils in place with clean soil or pavement
provided an effective alternative to address the risk, this capping alternative was carried through
the detailed evaluation process in the FS.
Comment #10 (Gary Mercer, WERC)
The preliminary remediation goal for ammonia in surface water is too high.
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EPA Response:
In response to this comment, EPA has re-evaluated the surface water performance standards for
ammonia (see Nobis, 2021). The surface water performance standard for ammonia in the
Proposed Plan was calculated using procedures described in the Aquatic Life Ambient Water
Quality Criterion for Ammonia - Freshwater (USEPA, 2013a) to establish the Criterion
Continuous Concentration (CCC). The CCC is a value below which adverse effects would not be
expected for the majority of aquatic receptors. For ammonia, the CCC is dependent on the
temperature and pH of the water body or stream. We believe that the site-specific assumptions
used for pH are appropriate, and pH has been, overall, less variable over time in both the South
Ditch Stream and East Ditch Stream.
EPA believes that a slight adjustment in the performance standard is needed based on the
assumptions used for temperature. The proposed performance standard for ammonia was based
on an average spring instrcam temperature of 7.13 °C for East Ditch Stream and 6.92°C for South
Ditch Stream. While EPA agrees that generally spring temperatures should be utilized as the
basis, EPA believes that it is more appropriate to use an average of the in-stream temperatures in
late spring (between May - June, not January - March). Late spring temperatures reflect a period
when aquatic receptors will be more active, and epi-benthic organisms that are exposed to
ambient water will be present in the water column. Also, the Baseline Ecological Risk
Assessment (BERA) assumes that the Marsh Wren and Green Heron may forage on-site.
Adjusting to late spring temperatures would account for the time when both species would be
present and breeding in New England. Therefore, EPA believes that the performance standard
should be adjusted to 9 milligrams per Liter (mg/L), based on an in-stream temperature of 18 °C
and pH of 6.6. The in-stream temperature is the 95% Upper Confidence Limit (LJCL) of the
temperature values from mid-May through June. The revised performance standard of 9 mg/L
has been added to the ROD.
Comment #11 (Gary Mercer, WERC)
There is insufficient analysis to show that groundwater extraction wells would be adequate to intercept
ammonia and chromium and sufficiently reduce their concentrations in surface water.
EPA Response:
A PDI is included in the selected remedy for surface water. As described in the Volume 1,
Operable Unit 1 Operable Unit 2 Feasibility Study, Olin Chemical Supeifund Site, 51 Fames
Street, Wilmington, Massachusetts (FSReport Volume /, Olin, 2020a), the PDI may include
additional surface water sampling, evaluation of potential groundwater seepage locations, as well
as a shallow groundwater hydrology evaluation to site the extraction wells to intercept ammonia
and chromium. The surface water alternative also includes monitoring provisions to ensure that
the surface water concentrations are reduced below applicable criteria. If monitoring indicates
that the groundwater interception system is inadequate, EPA may require modifications to the
system to address its deficiencies.
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Comment #12 (Martha Stevenson and Suzanne Sullivan, WERC)
The virtual meeting format is not as effective as the in-person format for public meetings.
EPA Response:
Comment noted. EPA is balancing the need to continue progress towards selecting a cleanup
remedy for the Site with the need to protect public health during the COVID-19 pandemic. For
this public hearing, EPA followed the April 16, 2020 Memorandum regarding virtual public
hearings and meetings (USEPA, 2020c), which states in part:
Virtual public hearings and meetings are a permissible tool under the federal
environmental statutes that EPA administers to provide for public participation in
permitting, rulemaking, and similar regulatory actions in lieu of in-person public
hearings and meetings. Virtual public meetings are also permissible when conducting
public engagement at Superfund sites.
Comment #13 (Suzanne Sullivan, WERC)
The potential truck traffic impact of removing soil is not a significant impact and should not be weighted
during alternative development and selection.
EPA Response:
Evaluation of potential impacts to the community from transport of waste materials off-site is
included in EPA guidance (Guidance for Conducting Remedial Investigations and Feasibility
Studies under CERCLA. Interim Final. October 1988. EPA/540/H-89/004). Section 6.2.3.5 -
Short-Term Effectiveness - requires remedial alternatives to be evaluated with respect to their
effects on human health and the environment during implementation of the remedial action and
states in part (emphasis added):
The following factors should be addressed as appropriate for each alternative:
• Protection of the community during remedial actions - This aspect of short-term
effectiveness addresses any risk that results from implementation of the proposed
remedial action, such as dust from excavation, transportation of hazardous
materials, or air-quality impacts from a stripping tower operation that may affect
human health.
Table 6-3 - Short-Term Effectiveness - provides this list of questions to consider in analyzing the
short-term effectiveness of the remedial alternative in protecting the community during remedial
actions:
• What are the risks to the community during remedial actions that must be
addressed?
• How will the risks to the community be addressed and mitigated?
• What risks remain to the community that cannot be readily controlled?
The potential impacts of excavating and removing soil were considered in evaluating the short-
term effectiveness of the soil cleanup alternatives, all of which, except for the No Action
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Alternative, included removal of contaminated material to varying degrees. The potential short-
term impacts considered by EPA included fugitive air emissions during excavation and from
trucks transporting wastes, and the potential for accidents and spills. These impacts can be
mitigated by best management practices, as noted in the Proposed Plan. It is EPA's experience
that truck traffic and its associated impacts to a neighborhood, and in particular, the hazardous
contents of trucks transporting wastes from a site, is frequently cited by community members as a
concern for alternatives involving excavation and transport of material from Superfund sites.
However, short-term effectiveness is one of the five balancing criteria that EPA is required by
statute to consider in selecting a remedy and is secondary to the criteria of overall protection of
human health and the environment and compliance with ARARs.
Comment #14 (Suzanne Sullivan, WERC)
The Zone 2 delineation performed by MassDEP pre-dates installation of the Containment Area and
should be revisited.
EPA Response:
EPA presumes that the commenter believes the Zone 2 boundary should be expanded to include
more of the Site. EPA also presumes that the commenter believes that expanding the Zone 2 will
result in different cleanup goals for the Property. It is true that MassDEP developed the Zone 2
many years ago and some of the facts which form the basis for the Zone 2 designation may have
changed. However, moving the Zone 2 or expanding it to include the Containment Area will not
alter the remedial action objectives for the selected remedy.
The NCP - the regulations governing the assessment and cleanup of sites under Superfund -
describes EPA's expectations for groundwater restoration and states that EPA expects to return
usable ground waters to their beneficial uses wherever practicable, within a timeframe that is
reasonable given the particular circumstances of the site. When restoration of ground water to
beneficial uses is not practicable, EPA expects to prevent further migration of the plume, prevent
exposure to the contaminated ground water, and evaluate further risk reduction. 40 C.F.R. §
300.430(a)(l)(iii)(F). Since portions of the aquifer at the Site are classified as drinking water
sources and since MassDEP has assigned a high use and value for the Site area aquifer in its
Groundwater Use and Value Determination (MassDEP, 2010a), the goal for the groundwater
would be to restore this aquifer to its beneficial use, unless it is determined not to be practicable.
Since there is insufficient data at this time to determine whether full restoration is practicable,
EPA's remedial action objectives for this portion of the remedy focused on removing the source,
minimizing further migration of contaminants, and preventing exposure.
Further work is underway to finish characterizing the nature and extent of contamination in the
aquifer and to develop and evaluate a set of alternatives to restore the groundwater to its
beneficial use as a drinking water aquifer. Once this investigation is completed, EPA will issue a
final ROD for groundwater identifying the final cleanup goals for groundwater at the Site.
Expanding the Zone 2 to include the Containment Area will not result in a different outcome as
the goals remains the same - restore the aquifer to its beneficial use (as a drinking water source),
unless it is determined not to be practicable.
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Comment #15 (Liz Harriman, WERC)
The interim action should not be approved before more design studies are performed to determine the rate
of source removal.
EPA Response:
EPA's issuance of this selected remedy is not an "approval" of the conceptual design presented in
the FS. EPA also agrees that the rate of source removal is a critical performance criterion that
needs further evaluation during the design phase. However, EPA believes that sufficient data
exists to issue a ROD that includes source removal actions for DAPL and groundwater hot spots
as a key component of the initial remedy for OU3 (groundwater).
With regards to DAPL, a formal field scale pilot study - the Jewel Drive DAPL extraction pilot -
was conducted between 2012 and 2015 to evaluate the feasibility of extracting DAPL. The pilot
confirmed the feasibility of extracting DAPL from the aquifer. EPA has not yet determined the
final extraction rates for each well or the final number of wells that will be needed to optimize the
overall rate of removal of DAPL from the aquifer. The design phase for the DAPL and
groundwater hot spot interim remedy will include an ev aluation of other extraction methods (such
as larger well screens) and different well configurations to expedite DAPL removal.
With regards to groundwater hot spots, the design will include an evaluation of how best to
optimize source removal from groundwater while not interfering with DAPL removal. The final
design of the extraction systems and identification of remov al rates must be reviewed and
approved by EPA before the remedy is fully implemented.
Comment #16 (Liz Harriman, WERC)
The design and installation of extraction wells should take place as soon as possible.
EPA Response:
EPA agrees that strong efforts should be made to hasten the pace of remedy design and
implementation, while meeting EPA's obligations under the Comprehensive Environmental
Response, Compensation, and Liability Act (CERCLA) and the NCP. EPA also agrees that
source removal is a critical next step and will be a priority moving forward.
Comment #17 (Ethan Sawyer)
The speaker was concerned that the Olin property will be used for transmodal (truck to rail) storage and
transportation of chemicals such as chlorine.
EPA Response:
Property use will be determined by local planning authorities and the property owner. EPA does
not have the authority under CERCLA to dictate the future use of the Property. However, if
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redevelopment occurs, EPA will review any redevelopment plans to ensure that such
redevelopment does not adversely impact the selected remedy for the Site and that the Site is safe
for its intended use. A goal of the current interim remedy to address the major sources of
contamination in groundwater and the final remedy for contaminated soil, sediments, and surface
water is to remediate the Property to a level that is safe for a commercial/industrial use based on
the current zoning. Please see also EPA's response to Comment #2 in Section B, above.
Comment #18 (Ethan Sawyer)
Wants to see stronger land use restrictions on the Olin property in addition to groundwater use
restrictions.
EPA Response:
Land use restrictions for the Property, together with other Institutional Controls, will be
developed in consultation with the Town of Wilmington and MassDEP, based on current zoning,
known areas of contamination, and receptors at risk. EPA's general goals for land use restrictions
include ensuring that members of the community are not exposed to contamination associated
with the Site and that use of the Property does not interfere with the implementation of EPA's
remedy. See also EPA's response to Comment #6 in Section B, above.
Comment #19 (Stephanie Baima, WERC)
Olin's preferences for remediation should not be taken into consideration for remedy selection.
EPA Response:
EPA's proposed cleanup remedy for the Site, as presented in the Proposed Plan, is based on
EPA's review of the nine statutory criteria presented in the Superfund law and regulations for
remedy selection. According to the Superfund law and regulations, EPA must also consider and
respond to all comments received during the 60-day public comment period on the proposed
remedy, including those provided by Olin.
Comment #20 (Multiple community members and representatives)
Multiple commenters expressed dissatisfaction with the pace of the cleanup.
EPA Response:
EPA acknowledges that the pace of the investigation has been slower than desired. The Site is
among the more complex CERCLA sites in New England, which has posed challenges in
determining the extent of contamination and how the contamination has migrated within the
environment. The presence of DAPL at a Superfund site is rare and the chemical and physical
properties of the DAPL present at the Site arc largely unique to this Site. The hydraulic setting is
complicated by the location of a major groundwater divide and the complex bedrock geology of
the groundwater study area. EPA is also required by statute to rely on Potentially Responsible
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Party (PRP) participation, where a viable PRP is present, to lead site investigations and cleanups
under EPA oversight. The issuance of the ROD is a major milestone in the Superfund process,
and EPA is hopeful that this accomplishment will help facilitate more expeditious cleanup work.
C. COMMENTS RECEIV ED IN WRITING DURING THE PUBLIC COMMENT
PERIOD
I. Written comments submitted by Olin on October 2, 2020
Comment #1
Specific design details for several remedial alternatives will depend on the planned pre-design
investigations: location and number of groundwater and DAPL extraction wells, equipment for
groundwater and DAPL treatment systems, and delineation of soil and sediment that exceeds PRCs and
requires remediation.
EPA Response:
EPA agrees that PDIs are needed to refine the details of the selected remedy, including the
location and number of groundwater and DAPL extraction wells, the configuration of the
equipment for the groundwater and DAPL treatment systems, and the further delineation of
contamination in soil and sediments. These studies will also include evaluating and optimizing
the on-site treatment of DAPL prior to off-site disposal of the residuals, with the goal of pre-
treating the extracted DAPL to reduce its volume as much as possible - thus reducing the volume
of residuals requiring off-site disposal, if it is not feasible to treat DAPL on-site, extracted DAPL
will be disposed of off-site at a permitted facility licensed to receive such wastes. However, it is
important to note that EPA expects these investigations to be focused and implemented
expeditiously such that active cleanup is initiated as soon as possible. The investigations at the
Site have been ongoing for a very long time, with little progress in the actual cleanup. The
dynamic of work at the Site must shift such that the PDIs do not become another long-term phase
of the investigation. In order to facilitate the rapid implementation of DAPL extraction and
treatment, the PDIs may need to incorporate treatability studies and additional field investigations
(either pilot-scale or full-scale). For example, piloting extraction of DAPL in known bedrock low-
spots, even while the bedrock topography continues to be fully investigated, may be appropriate.
Comment #2
The currently operating groundwater and Light Non-Aqueous Phase Liquid (LNAPL) treatment and
extraction system adjacent to East Ditch Stream (the Plant B treatment system) is operating as intended
and LNAPL is not currently flowing into any surface water bodies. LNAPL (or other non-aqueous phase
liquids) have not been observed in the vicinity of South Ditch, On-Property West Ditch, or Off-Property
West Ditch Streams.
EPA Response:
Clarification noted.
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Comment #3
The cap planned for the Containment Area should be a low-permeability cap, as specified in the
OU1/OU2 FS, and not an impermeable cap as indicated in the Proposed Plan. The final details of the cap
will be determined during the RD phase.
EPA Response:
The selected remedy includes the construction and maintenance of caps and cover systems on
areas of soil contamination on the Property, including a multi-layer, low-permeability cap that
meets Resource Conservation and Recovery Act (RCRA) Subtitle D and Massachusetts solid
waste landfill performance standards over the Containment Area. The term impermeable cap in
the Proposed Plan is fundamentally not different than a low-permeability cap required to meet
ARARs. Volume III Comparative Analyses, Feasibility Study Report, Olin Chemical Superfund
Site, Wilmington, Massachusetts {FSReport Volume III, USEPA, 2020c) states:
Alternative SOIL/SED-2 includes an impermeable cap above the contaminated soil in and
near the Containment Area... The cap for the Containment Area would comply with
Resource Conservation and Recovery Act (RCRA) Subtitle D regulations and
Massachusetts solid waste management regulations and meet impermeability
requirements with an effective permeability that is equivalent to the permeability of the
existing slurry wall (approximately lxl0~8 centimeters per second (cm/sec)) or a
permeability of no greater than IxlO7 cm/sec, whichever is less...
Comment #4
Previous investigations have shown that there is no reasonable likelihood of contaminants leaching at
unacceptable levels from the Containment Area, as demonstrated through analysis of samples collected
for the 2019 Containment Area soil investigation and supported by historical data. In addition, human
health evaluation has not identified unacceptable health risk for future land uses (which will be restricted
or prohibited by Institutional Controls). While Olin does not disagree with the need for a cap, the
leaching concerns are not supported by the available data.
EPA Response:
EPA disagrees with the comment, as insufficient data exists to conclude that there is no
reasonable likelihood of contaminants leaching from soil to groundwater at unacceptable levels
from the Containment Area. During the OU1/OU2 RI, characterization of Containment Area soil
was limited to surface samples from beneath the temporary cap. Deeper samples were not
collected at that time to avoid potential damage to the temporary cap that may have resulted from
the presence of a drill rig.
The November 2019 Containment Area soil investigation referenced above was generally
conducted in locations that targeted previously excavated areas, former disposal pits and lagoons,
and other potential former disposal areas. The majority of samples collected during this event
were from shallow sample intervals; a total of 103 discrete soil samples were collected, 76 of
which (74%) were from depths shallower than 10 ft bgs. Additionally, the spatial resolution of
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the soil boring locations cannot be considered comprehensive, as a total 12 soil borings were used
to assess a study area nearly five acres in size. The degree of interpolation required between
sampling locations from the November 2019 soil investigation combined with the limitations of
the surficial soil sample data set from the OU1/OU2 RI would, in the opinion of EPA, preclude a
definitive conclusion regarding contaminant leaching from Containment Area soil.
Major findings from EPA's Memorandum entitled Updates to Oil I/O (12 RI Report Conclusions
(USEPA, 2020a) include the following:
• Significant volumes of acidic wastewaters and other wastes, including
containerized and laboratory wastes from various facility production operations,
were disposed of within the Containment Area from approximately 1965 until at
least 1983;
• Specific areas within the Containment Area - primarily the drum and buried
debris areas - have been remediated, but these areas represent a fraction of the
total extent of the Containment Area. Therefore, unsaturated soil within the
Containment Area likely contains waste materials; and
• The solid wastes in the Containment Area will need to be contained, a remedial
action that would include the prevention of leaching of chemicals or constituents
from such wastes, in accordance with RCRA Subtitle D regulations and
Massachusetts Solid Waste Management Facility Regulations is appropriate.
The selected remedial actions for the Containment Area, which include closure of the
equalization window, installation of a permanent, low-permeability cap, and DAPL extraction,
will significantly reduce the potential for adverse groundwater impacts from the Containment
Area.
Comment #5
The September 21, 2010 Use and Value Determination identified only portions of the groundwater
impacted by the Site as current or potential future drinking water source areas that meet the criteria for
Category GW-1 groundwater, and classified the remainder of the Site groundwater as GW-2/GW-3 (not
current or potential future drinking water source areas).
EPA Response:
Comment noted, however, the September 21, 2010 Groundwater Use and Value Determination
(MassDEP, 2010a) identified a high use and value for the Site area groundwater aquifer:
Because a portion of the Site falls within a GW-1 area, (the Zone II to the north) and the
close proximity to private drinking water wells to the southeast and the GW-1 Potential
Drinking Water Source Area to the south, and in light of the factors contained in EPA's
Final Ground Water Use and Value Determination Guidance, the Department supports a
high use and value for the Site area aquifer (See Attached Table: Groundwater Use and
Value Factors)...
Comment #6
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The Proposed Plan indicates a potential need to extract "hot spot" groundwater from immediately above
the DA PL pools. Current data is limited to a single well point but does not support the presence of a
significant NDMA hot spot above the DAPL pool. The data gap investigation will verify current
conditions. In addition, Olin believes that extraction of groundwater immediately above the DAPL pools
will exacerbate conditions by causing convection and dilution of DAPL. The DAPL pilot test results
suggest that the gravimetric DAPL recovery from the bottom of the DAPL pool will result in progressive
drawdown of the DAPL diffuse layer interface, stranding any extraction wells set above the DAPL pool.
EPA Response:
EPA agrees that additional evaluation is required to determine the thickness and extent of the
groundwater hot spot above each of the DAPL pools, as well as the aquifer response to removal
of DAPL. There may be advantages to phasing the work, with initial remediation focused on
DAPL pool removal and subsequent groundwater extraction after the DAPL pool has been
partially drawn down. These evaluations and exploration of phasing will be included in the PDIs
and RD phase.
Comment #7
The Proposed Plan reflects the initial assumptions related to the operations required to successfully treat
DAPL and impacted groundwater; these assumptions will require verification through treatability and
potentially pilot-scale studies. The PDIs and RD will identify the location for the new treatment system
and alignment of associated piping and appurtenances.
EPA Response:
EPA agrees with the comment. The selected remedy explains that the treatment system details
for both DAPL and impacted groundwater will be determined based on PDIs and refined in the
RD.
Comment #8
The available information indicates that the LNAPL in the subsurface is the result of a release of rubber
process oil #425 from storage tank #6 (a raw material for chemical manufacturing) and not a fuel oil spill.
The LNAPL has been contaminated by historical, co-located releases of bis-2-ethylhexylphthalate
(BEHP), n-nitrosodiphenylamine (NDPhA), and TMPs. The process oil itself did not contain these
constituents. This information is included in Figure 1.3-2, Table 1.4-1, and text of Section 1.4.2.2 of the
2015 OU1/OU2 RI Report.
EPA Response:
Part 2, Section B, SITE HISTORY AND ENFORCEMENT ACTIVITIES, History of Site,
above, of this ROD explains that #415 process oil was a raw material utilized during the
operating history of the Property. This section further explains that the LNAPL was released to
soil and the subsurface in the area of the Plant B tank farm in the form of a processing oil.
According to the Comprehensive Site Assessment Phase II Field Investigation Report (CRA,
1993), interviews with former workers at Plant B indicate that multiple spills occurred in the
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Plant B area. Materials allegedly spilled included diisobutylcne, diphenylamine, dioctylphthalate,
dioctyldiphenylamine, and fuel oil. According to the Supplemental Phase IIReport (Smith,
1997), as early as 1973, MassDEP contacted the Facility about a seep of oily material in East
Ditch Stream, adjacent to the Plant B tank farm. A 1973 analysis of the oil (from well IW-11)
indicated that the oil contained a high percentage of BEHP and lesser amounts of NDPhA,
dioctylphthalate, and TMPs. Part 2, Section E, SITE CHARACTERISTICS, Conceptual
Site Model explains that the LNAPL is a mixture of process oil and other raw materials
historically stored and used at the former manufacturing facility (Facility) that contains various
contaminants, including TMPs and BEHP.
Comment #9
The Proposed Plan noted that benzo(a)pyrene in surface water in Off-Property West Ditch Stream could
result in unacceptable risk to trespassers. The available benzo(a)pyrene analytical data for shallow
groundwater in the vicinity of this stream do not contain substantial concentrations of benzo(a)pyrene or
other high molecular weight polycyclic aromatic hydrocarbon (PAH) compounds that were detected in
the stream; likewise, low molecular weight PAHs (more soluble in water) were also not detected in the
stream or nearby groundwater. The detection of only less-soluble PAH compounds in the stream suggest
that the PAHs are associated with suspended particulate matter. The topography of the 01 in property and
area to the west do not support runoff toward the stream: on-property flow is toward On-Property West
Ditch Stream, and immediately west of the property boundary, the ground surface elevation increases
with the elevated PanAm Railway tracks. Finally, the risk calculated in the 0U1/0U2 Baseline Human
Health Risk Assessment (BHHRA) was based on a single sample result. Other potential PAH sources
may include the railroad ties from the rail line and local stormwater runoff from the west. Additional
sampling and analysis of surface water for benzo(a)pyrene and other PAHs would be beneficial in
determining with more confidence what the representative concentrations are in surface water of Off-
Property West Ditch Stream.
EPA Response:
EPA acknowledges that other sources may contribute to the benzo(a)pyrene concentrations in
surface water; however, Olin's role as a potential contributor to the contamination has not been
ruled out at this time, given the limited surface water and nearby groundwater sampling
conducted. Benzo(a)pyrene and other PAHs were detected in surface and subsurface soil on the
Property, with the highest concentrations occurring in the v icinity of the former Plant C Boiler
and the former Laboratory Building Boiler near the Guard Shack (USEPA, 2020a). EPA's goal is
to reduce, to the extent practicable, any sources of PAHs, including benzo(a)pyrene. In the
absence of additional data that conclusively rules out the contributions of potential source areas
on the Property to surface water in Off-Property West Ditch Stream, surface water impacts in
Off-Property West Ditch Stream from Site contaminants are addressed by the selected remedy.
Additional sampling is planned to clarify the current contaminant concentrations and trends in
Off-Property West Ditch Stream. This sampling will help to determine if source areas on the
Property are contributing to benzo(a)pyrene concentrations in Off-Property West Ditch Stream
and will be taken into consideration during the RD phase and subsequent remedy implementation
phases.
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Comment #10
Olin provided suggested wording regarding the discussion of the residential well NDMA results, noting
that samples from two wells have consistently had higher concentrations of NDMA than the other wells
and that Olin is working with the Town of Wilmington to voluntarily extend a waterline to these two
residences. Olin also prov ided suggested wording regarding the NDMA results from 2017 that were
above the risk criterion of 47 ng/L.
EPA Response:
EPA acknowledges that the section in the Proposed Plan that summarizes the private well
sampling results could have been clearer. Part 2, Section F, CURRENT AND POTENTIAL
FUTURE SITE AND RESOURCE USES, Groundwater/Surface Water Uses of this ROD
explains the following (excerpt in part):
... There are 81 private wells (potable and irrigation) on file with the Town of Wilmington
within the Site...Of these, 26 residential drinking water wells have been sampled at least
once, and 18 are monitored on a quarterly basis to confirm that levels of NDMA do not
exceed the upper end of EPA's health-protective cancer risk range of 47 ng/L...NDMA
detections in 16 of these wells fall within EPA's health-protective range, with 72% of
samples (438 out of608 samples) showing non-detectable levels of NDMA...Two of the
18 wells have shown consistently higher levels of NDMA over time, with detections in one
well ranging from 9.4 to 24 ng/L and detections in the second well ranging from non-
detectable to 56 ng/L.15 Olin has provided bottled water to these two residences since
2010, and is in the process of working with the Town of Wilmington to voluntarily extend
a waterline to these two households. A third well had an NDMA detection of 57 ng/L in
2017, but previous and subsequent sampling results for this well were all within EPA's
health-protective range.16
Footnote 15 adds:
Prior to the 2017 sampling event which yielded an NDMA sampling result of 56 ng/L for
one of the two residences on bottled water, sampling data for this well between 2008 and
2016 ranged from non-detectable to 33 ng/L (20 sampling events). Subsequent to the
2017 NDMA result of 56 ng/L, six sampling events were conducted between 2017 and
June 2020. These sampling events yielded NDMA results ranging from 0.34 to 2.9 ng/L.
Footnote 16 adds:
Prior to the 2017 sampling event for this well which yielded an NDMA sampling result of
57 ng/L, sampling data for this well between 2015 and 2015 ranged from 1.2 to 8.1 ng/L
(five sampling events). Subsequent to the 2017 NDMA result of 57 ng/L, three sampling
events were conducted between 2018 and June 2020. These sampling events yielded
NDMA results ranging from 0.6 to 7.9 ng/L.
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II.
Written general and technical comments submitted by WERC on October 26, 2020
Comment #1
It has been challenging to fully evaluate the more than 1,100 pages of technical documentation released
by EPA and 01 in in August 2020.
EPA Response:
EPA acknowledges that there has been a significant volume of information to digest. EPA has
shared many documents during the course of the investigation with WERC, as well as the Town
of Wilmington and their consultant. These documents included correspondence to and from Olin,
sampling data, draft reports, and technical memoranda. EPA solicited written comments from
WERC and the Town and incorporated such comments where appropriate. EPA met with WERC
members on a regular basis to explain results, apprise the group of progress towards remedy
selection, and discuss concerns. EPA is open to suggestions for how communications and the
sharing of technical information can be improved. Nonetheless, EPA has strived to involve
WERC and local officials as active stakeholders in the site investigation and will continue to do
so in the next phase of the CERCLA remedial lifecycle for the Site. Please see also EPA's
response to Comment #1 in Section C, III, below.
Comment #2
The use of a virtual hearing severely limited the participation of residents in both Wilmington and
Woburn; in addition, concerns over C"ovid-19 limited WERC's internal interactions and ability to meet.
EPA Response:
Comment noted. EPA acknowledges these concerns. Please sec EPA's response to Comment
#12 in Section B, above.
Comment #3
WERC continues to be frustrated over the lack of progress at the Site over the preceding decades. EPA
should require maximum effort to begin cleanup.
EPA Response:
EPA acknowledges that the pace of the investigation has been slower than desired. EPA agrees
that strong efforts should be made to hasten the pace of remedy design and implementation, while
meeting EPA's obligations under CERCLA and the NCP. Please see EPA's response to
Comments #16 and #20 in Section B, above.
Comment #4
The commenter stated that groundwater contamination (OU3) is the sole reason the Olin Site was
elevated to the National Priorities List in 2006 and questioned why groundwater has consistently been left
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to last in being addressed behind soil and sediment on Olin's parcel of property. EPA's focus always
should have been and must now be determining the full extent and severity of the groundwater
contamination throughout the entire Site. The proposed Interim Action to remove the worst of the worst
groundwater is a good first step, but it is only a half-measure.
EPA Response:
EPA agrees that the groundwater contamination at the Site poses a significant threat to the
environment. The issues posed by the unique material present - namely DA PL - have been a
challenge to fully understand through the studies completed to date. Over the last few years, EPA
has gained a much better understanding of the Conceptual Site Model (CSM) for the Site but
there is still insufficient data to select a comprehensive remedy for groundwater. However, given
the threats, EPA determined that an interim remedial action is appropriate at the Site to initiate
source control while additional information is collected to better assess the practicability of
aquifer restoration prior to the determination of final cleanup levels and selection of a final
remedial action for groundwater. Accordingly, the cleanup objectives for the interim action were
developed to prioritize reduction of exposure risk and reduction of contaminant mass through
treatment. The selected interim remedy for groundwater includes the critical outcome of reducing
the mass of NDMA in the aquifer by extracting and treating DAPL and groundwater hot spots.
Additionally, Part 2, Section L, THE SELECTED REMEDY, Description of Remedial
Components. Common Components of the Remedy for All Media, Pre-Design Investigations of
this ROD explains that a sequencing plan will be developed for implementing the soil and
sediments remediation to coordinate work with the remedial actions for DAPL, groundwater hot
spots, LNAPL. and surface water to ensure that remedial activities taken to address contamination
in soil and sediments are not undermined by rccontamination from LNAPL and contamination in
groundwater and surface water. The remedial work to address contaminated soil and sediments
will be conducted after it is established that discharge from impacted groundwater is not serving
as on ongoing source which could negatively impact the quality of wetland soil and sediments.
Please see also EPA's responses to Comment #1 in Section B and Comment #1 in Section C, I,
above.
Comment #5
WERC continues its steadfast opposition to any redevelopment at the 01 in property before all 0U3
investigations are completed and the 0U3 Feasibility Study has been approved.
EPA Response:
EPA is not taking a position on whether the Property should be redeveloped and when such
redevelopment should occur. However, a redeveloper must cooperate fully with EPA's
environmental investigation and response actions at the Site; protect and maintain remedial
systems and containment infrastructure; and refrain from using the Property in any manner that
would interfere with or adversely affect the implementation, integrity, or protectiveness of any
past or future action. Please sec also EPA's responses to Comment #2 and #17 in Section B,
above.
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Comment #6
EPA has fallen short in failing to require that Olin identify the source of NDMA once and for all. Recent
studies have identified additional nitrosamines that pose a danger to human health. Aside from one
sampling event done several years ago, WERC is not aware of any other investigations to identify other
nitrogen compounds related to the manufacturing processes through the decades, or which may have
resulted from Olin's various attempts to reduce hydrazine and ammonia levels, which are both present in
the Plant B area, as well as widespread across the Site.
EPA Response:
EPA included information about the source of NDMA in the Hazard Ranking System (HRS)
documentation record for the Site's listing on the National Priorities List (NPL; see page 19 of the
55-page pdf, available at: https://semspiib.epa.gov/work/01/75001Q14.pdf). which states the
following:
Although evidence indicates that NDMA was not directly used, produced, purchased, or
disposed of at the Olin Chemical facility, there is evidence that the historical disposal of
chemical wastes in the unlined pits may have resulted in conditions favorable for NDMA
formation in the waste stream, waste disposal structures (unlinedpits), DAPL ground
water, or diffuse layer ground water (Ref 8, pp. 24, 25). In particular, the processes for
the manufacture of Opex, Kempore, Hydrazine, OBSC/OBSH, Wiltrol-N, Nitropore 5PT,
and Nitropore OTproduced wastes that when combined may have had the potential to
result in NDMA formation (Ref 8, p. 30). Details of these and other possible NDMA
formation mechanisms are discussed in Section 3.1.1 of this HRS documentation record.
Extensive time has been spent seeking to identify precisely how NDMA formed, without yielding
a conclusive finding. At this point, the lack of a full understanding of how NDMA formed does
not prevent EPA from making remedial decisions concerning groundwater at the Site. Regardless
of how NDMA formed, the interim remedy focuses on removal of NMDA, thus preventing
further contamination of the aquifer.
EPA acknowledges a number of data gaps with respect to the distribution of NDMA in the
subsurface; however, EPA believes sufficient data exists to issue a ROD that includes source
removal actions for DAPL and groundwater hot spots as a key component of the initial remedy
for OU3 (groundwater). Continued studies to close remaining data gaps, including additional
nitrosamine-precursor and nitrosamine-related compound sampling, will be further evaluated in
the RD phase of the selected interim remedy, and in the OU3 Remedial Investigation/'Feasibi 1 ity
Study (Rl/FS).
Comment #7
The Zone II contribution area to Wilmington's municipal wells should be revised. The Zone II delineation
was from a 1990 aquifer study, and the area's hydrological and hydraulic conditions have changed since
then, including cessation of pumping of the Town of Wilmington municipal wells and Altron/Sanmina
wells, Containment Area construction, and installation of the weir in the South Ditch Stream. Each of
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these developments affects the groundwater flows, and a new delineation is important in understanding
future impacts of remedial activities and siting of any redevelopment.
We also have concerns regarding the outfall of the NPDES discharges and placement of proposed
remedial structures. Over the years Olin has presented various scenarios showing how the groundwater
and surface water divides between the Ipswich and Aberjona watersheds vary seasonally and under
various pumping demands. Regardless of Olin's attempts to show that very little of their property lies
within Wilmington's 1990 Zone II, contamination from Olin reached our town's wells, and has migrated
off-property in all directions. If the Zone II delineation is not modified, EPA should remediate all water
related to the Site to drinking water standards.
EPA Response:
Comment noted. Please sec EPA's response to Comment #14 in Section B, above.
Comment #8
Over the years, many interim attempts to remediate various areas on the property were reviewed by local,
state, and federal regulators prior to the Site's listing on the NPL, who in turn granted approvals with
restrictions and conditions. These limitations on the property must be borne in mind when designing and
siting future remedial and/or redevelopment structures. For example, Wilmington Conservation
Commission's Order of Conditions and the United States Army Corps of Engineers' (USACE's) Water
Quality Certification, which was incorporated into Massachusetts Environmental Policy Act (MEPA)
approval of permitting work performed in 2000, prohibits any further alteration or removal of wetlands on
the property- While temporary alteration is allowed for essential remedial activities and facilities, no net
loss of wetlands is allowed. EPA must require that these restrictions on future activ ities be enforced.
The protective covenant on the southern portion of the Olin property was negotiated between Olin and the
Town to prevent further disturbance to that area. EPA should not allow the siting of any remedial activity
in the Conservation Restriction area to facilitate redevelopment. Only actions essential to the cleanup that
cannot be located anywhere else should be permitted, and those should be temporary.
EPA Response:
EPA is aware of the conservation restriction, which has preserved the southern portion of the
Property (the "Conservation Area") in a predominantly natural, undeveloped condition
(Environmental and Open Space Restriction, recorded with the Middlesex North Registry of
Deeds on November 7, 2006, Book 20680, Page 234). Currently, EPA is not planning any work
within this area other than any remediation that is necessary to address areas with contamination
exceeding cleanup levels, which is expressly permitted under the restriction. Wetland areas on
the Property requiring remediation are generally located in the immediate environs of South Ditch
Stream and areas to the north, though do appear to extend to a limited degree into the
Conservation Area.
The selected remedies for LNAPL, surface water, soil, and sediments will comply with all
wetland and floodplain ARARs and minimize impacts to wetlands and floodplains. Part 1,
Section F, SPECIAL FINDINGS, above, of this ROD explains that pursuant to Section 404 of
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the Clean Water Act (CWA), 44 CFR Part 9, and Executive Order 11990 (Protection of
Wetlands), EPA has determined that there is no practicable alternative to conducting work that
will impact wetlands of the United States because significant levels of contamination exist within
or under wetlands of the United States and these areas are included within the Site's cleanup
areas.
For those areas impacted by cleanup activities, EPA has also determined that the selected remedy
is the Least Environmentally Damaging Practicable Alternative (LEDPA), as required by the
CWA, for protecting federal jurisdictional wetlands and aquatic ecosystems at the Site under
these standards, because the remedy will permanently remove contaminants that are impairing the
wetlands and any wetland resources altered by the cleanup will be restored to the original grade
and with native v egetation.
EPA will minimize potential harm and avoid adverse impacts to wetlands, including in the
Conservation Area, to the extent practicable, by using best management practices to minimize
harmful impacts on wetlands, wildlife, or habitat. Any wetlands affected by remedial work will
be restored and/or replicated consistent with the requirements of federal and state wetlands
protection laws with native wetland vegetation, and any restoration efforts will be monitored.
Mitigation measures will be used to protect wildlife and aquatic life during remediation, as
necessary.
The conceptual plans for the selected interim and final remedies do not include remedial
infrastructure such as staging areas, extraction wells, conveyance piping, and treatment
buildings/systems in the southern portion of the Property, including the Conservation Area. The
final location of these and other components of the remedy will be designed to minimize impacts
to the Conservation Area. Regarding future development, it will be up to the local conservation
commission, which is the grantee under the conservation restriction, to enforce the restriction in
this area.
Comment #9
EPA is aware that WERC continues to have serious concerns about the Containment Area. What does it
contain? We are not convinced that the soils, sediments, and waste products Olin placed in the
Containment Area have been adequately characterized. We suggest that if EPA finds that the
Containment Area is not functioning as designed, serious consideration should be given to 'daylighting'
the On-Property West Stream, which was culverted at the time the Containment Area was constructed in
2000.
EPA Response:
Significant volumes of acidic wastewaters and other wastes, including containerized and
laboratory wastes from various facility production operations, were disposed of within
the Containment Area from approximately 1965 until at least 1983 (AMEC, 2015,
Section 1.4.2.3). Specific areas within the Containment Area - primarily the drum and
buried debris areas - have been remediated, but these areas represent a fraction of the
total extent of the Containment Area. Therefore, unsaturated soil within the Containment
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Area likely contains waste materials. EPA agrees with the commenter that insufficient
data exists to fully characterize the Containment Area. However, the selected remedial
actions for the Containment Area, which include closure of the equalization window,
installation of a permanent, low-permeability cap, and DAPL extraction, will address the
human health risks posed by the Containment Area, and significantly reduce the potential
for adverse groundwater impacts from the Containment Area and associated impacts to
surface water and sediments. Please see also EPA's response to Comment #4 in Section
C, I, above.
Regarding the comment concerning the culvcrted portion of On-Property West Ditch
Stream, the culvert is constructed of 30-inch (in) diameter reinforced concrete and was
installed between September and October 2000 (GEI, 2004b). The culverted portion of
On-Property West Ditch Stream discharges to South Ditch Stream, which is monitored by
surface water location PZ-18R at the discharge point and surface water locations SD-17
and PZ-17RRR approximately 150 ft downgradient of the discharge point (see Figure 27
in Appendix C of this ROD). These locations are sampled quarterly (if surface water is
available to sample) and the selected remedy for surface water includes long-term
monitoring of these and other locations. Based on most recent data available and
previous surface water trends, the Site contaminant concentrations at surface water
location PZ-18R are comparable to the closest upgradient surface water sample location
(ISCOl) and generally lower than downgradient locations SD-17 and PZ-17RRR,
suggesting that the culvert is not the source of these surface water impacts. A review of
the available monitoring data does not suggest that surface water in the culvert has been
impacted by surrounding soil.
Comment #10
Will the working documents during the design phase of remedial work be available for comment? WERC
will have additional comments for the design phase. We hope to continue our working relationship as
you move forward towards implementing the Action Alternatives adopted in your forthcoming Record of
Decision.
EPA Response:
The RD plans and other documents submitted by Olin will be made available for WERC, Town
officials, and other stakeholders to comment, similar to previous practice. Please see also EPA's
responses to Comment #6 in Section B and Comment #1 in Section C, II, above. Comment #15
in Section C, II, below, and Comment #1 in Section C, III, below.
Comment #11
WERC requests an opportunity to discuss technical points with EPA in more detail prior to the issuance
of the ROD.
EPA Response:
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The NCP establishes the process that EPA must follow for the release of the Proposed Plan, the
public comment period, and issuance of the ROD. Responses to oral and written comments
received during the comment period are provided in the Responsiveness Summary of the ROD.
These comments and responses become a part of the Administrative Record for the ROD in the
event that the selected remedy is challenged. Once the ROD is issued, EPA will continue to
discuss the technical points of its decision with interested parties during the design phase.
Comment #12
The premise and promise of the Superfund Program is the "Polluter Pays" principle. Olin has had 40
years to clean up the property at 51 Eames Street, and they have failed. Their only motivation now to
implement additional clean-up activities is the anticipated sale of the property; their newfound
cooperation to expedite certain aspects of additional groundwater investigations is driven by their desire
to claim exemption from decontaminating our aquifer because they waited so long that the cost to do so
will likely be astronomical. EPA should make the responsible parties pay all costs that were squandered
by their failure to remediate OU3 (groundwater) upon confirming the presence of NDMA in 1990.
EPA Response:
EPA has a longstanding policy to pursue "enforcement first" throughout the Superfund cleanup
process. This policy promotes the "polluter pays" principle and helps to conserve resources for
the cleanup of sites where viable responsible parties do not exist. EPA guidance emphasizes that
a major component of the "enforcement first" policy is that PRPs should conduct remedial actions
whenever possible. See EPA's Memorandum, Enforcement First for Remedial Action at
Superfund Sites, dated September 20,2002 (available at:
https://www.epa.gov/sites/production/files/documents/enffirst-mem.pdf). Following the issuance
of the ROD, EPA will negotiate with the PRPs to enter into an agreement for the PRPs to perform
the required response actions in accordance with Section 122 of CERCLA, 42 U.S.C. § 9622. If
the parties are unable to reach agreement, EPA will consider other enforcement options. Please
see also EPA's response to Comment #7 in Section B, above and Comment #2 in Section C, IV,
below.
Comment #13
It's time for EPA to do everything possible now to require that all contamination be eliminated wherever
possible, and that the concentrations are lowered to the largest degree possible where complete clean-up is
not achievable. No half-measures - clean-up, not cover-up.
EPA Response:
EPA agrees that cleanup works needs to be initiated as soon as possible. The investigations at the
Site have been ongoing for a very long time, with little progress in the actual cleanup. Strong
efforts need to be made to hasten the pace of remedy design and implementation. Please see also
EPA's responses to Comments #1, #3, and #16 in Section B and EPA's response to Comment #1
in Section C, I, above.
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Comment #14
EPA should remove all contamination remaining at the Property and either consolidate within the
Containment Area if the Containment Area is actually viable or treat it to safe standards. Contaminants of
concern should not be left in place to "naturally attenuate" another 40-50 years. We don't want decades
of additional monitoring, rather, a clean environment.
EPA Response:
During the FS, EPA considered several alternatives for remediation of the Site. For the soil
contamination, EPA did consider removal and off-site disposal or consolidation within the
Containment Area. These alternatives were not carried through the detailed analysis as they
posed serious implementation issues. Please see EPA's responses to Comments #8 and #9 in
Section B, above.
Comment #15
WERC is concerned that the group has not been included enough during development of the FS, Proposed
Plan, and supporting documents.
EPA Response:
EPA has tried to keep WERC and other interested members of the public informed on the
development of the FS, Proposed Plan, and supporting documents. Leading up to the issuance of
the Proposed Plan, EPA met several times with representatives from WERC and discussed openly
the status of work, the range of alternatives under development, the technical challenges posed by
the Site, and many other issues. EPA provided the public an extended opportunity (10 days) for
review of the Proposed Plan before the start of the comment period and conducted an extended
formal comment period (60 days) for all parties to review the record. EPA remains committed to
facilitating additional public input into the implementation of the remedy and will continue to
discuss WERC's concerns as we move forward. Please sec also EPA's response to Comment #1
in Section C, II, above and Comment #1 in Section C, III, below.
Comment #16
The Remedial Action Objectives (RAOs) for DAPL and groundwater hot spots are interim and fail to
recognize the value of the aquifer as a public and private water supply. A long-term RAO must be
included for the aquifer.
EPA Response:
The interim RAOs for DAPL and groundwater hot spots are intended to support the initiation of
cleanup of the aquifer, designated as having a high use and value by MassDEP. EPA agrees that
long-term RAOs are needed; EPA plans to develop and issue such RAOs as part of the final
ROD, following completion of the data gaps work and final FS for groundwater (OU3). Please
see also EPA's responses to Comment #1 and #14 in Section B, above.
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Comment #17
The second RAO for surface water should be revised to remove the phrase "by a current or future
trespasser."
EPA Response:
The second RAO for surface water states, "Prevent migration of groundwater containing Site
contaminants to Off-Property West Ditch Stream to prevent potential human exposure by a
current or future trespasser to surface water containing Site contaminants at levels that pose an
unacceptable risk." EPA Guidance for drafting RAOs suggests that the RAO identify the risk
posed and the receptor at risk. In the case of Off-Property West Ditch Stream, the risk is to
current and future trespassers. It is unclear why the commenter requests that the wording, "by a
current or future trespasser," be deleted, as removal of this language will make the RAO vague
and incomplete. As such, the language remains in the ROD.
Comment #18
Compliance with the surface water RAOs will be achieved by monitoring the water quality in surface
water, not groundwater. Therefore, the RAO should include surface water objectives and not
groundwater objectives. The following RAO should be added: "Restore surface water to ambient water
quality criteria for the contaminants of concern."
EPA Response:
The first RAO for surface water states, "Prevent migration of groundwater containing Site
contaminants to East Ditch Stream, South Ditch Stream, and Off-Property West Ditch Stream to
prevent exposure by current and future ecological receptors to surface water containing Site
contaminants that would result in potential adverse impacts. " EPA notes that this ROD
establishes National Recommended Water Quality Criteria (NRWQC) as the performance
standards for surface water as these levels are protective of ecological receptors. EPA also notes
that the selected remedy includes monitoring of the water quality in surface water to demonstrate
that these standards have been achieved. However, EPA does not agree that an additional RAO
- "Restore surface water to ambient water quality criteria for the contaminants of concern" is
needed. The selected remedy achieves the objective of preventing the migration of contaminated
groundwater to East, South, and Off-Property West Ditch Streams that would result in potential
adverse impacts by preventing contaminated groundwater from impacting surface water, not by
actively restoring the surface water. Therefore, EPA believes the RAOs in the Proposed Plan and
ROD are sufficient.
Comment #19
The following RAO should be added for sediments: "Restore sediments to pre-release/background
conditions to the extent feasible, at a minimum to levels that will result in self-sustaining benthic
communities with diversity and structure."
EPA Response:
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EPA acknowledges the commenter's intention and notes that the selected remedy will restore
sediments to levels that are protective of the benthic community by removal and off-site disposal.
The RAOs in this ROD for wetland soil and sediments are as follows:
o Prevent exposure by current and future ecological receptors to wetland soil and
sediments containing Site contaminants that would result in potential adverse impacts,
o Prevent the further migration of wetland soil and sediments containing Site contaminants
to nearby wetlands, surface water, drainage features, and adjoining properties that
would result in potential adverse impacts.
This ROD also establishes cleanup levels for sediments that will result in the re-establishment of
the benthic community. Therefore, EPA does not agree that revisions to the RAOs for sediments
arc needed.
Comment #20
WERC has little trust in the future owner/operator adhering to Institutional Control requirements, so
contamination should be cleaned up rather than covered or left in place with monitoring.
EPA Response:
Part 2, Section E.3, SITE CHARACTERISTICS, Principal Threat Waste, above, of this ROD
explains that the soil impacted with chromium and BEHP on the Property is considered to be low-
level threat waste that will be addressed under the selected remedy by installing a permanent,
low-permeability cap over the Containment Area and installing soil and/or asphalt cover systems
over contaminated upland soil. The Containment Area cap and upland soil cover systems will
prev ent unacceptable exposure by ecological receptors and unacceptable leaching of Site
contaminants in the Containment Area. Institutional Controls and long-term maintenance of
covers and caps will be used to address these materials over the long-term. Further, under the
selected final remedy for soil and sediments, additional evaluations and/or implementation of
engineering controls such as vapor barriers or sub-slab depressurization systems (SSDSs) will be
required for new building construction or building alterations on the Property to address potential
vapor intrusion risks to indoor workers from TMPs.
Institutional Controls are non-engineered instruments such as administrative and legal controls in
the form of land use restrictions that help minimize the potential for human or ecological
exposure to contamination and/or protect the integrity of the remedy. The details of the
Institutional Controls required by this ROD will be resolved during the pre-design and RD phase
in coordination with the parties performing the remedial action, impacted landowners, local
officials, and MassDEP. Institutional Controls may be implemented through measures that may
include, but are not limited to. Notice of Activity and Use Limitation (NAUL), Grant of
Environmental Restriction and Easement (GERE), town ordinance, advisories, building permit
requirements, and other administrative controls.
Institutional Controls for, and long-term maintenance of, upland soil covers, the Containment
Area cap, and any implemented vapor barriers or SSDSs will ensure the protectivcncss of these
remedial activities over the long term. In addition, EPA will continue to evaluate Site conditions
and the effectiveness of implemented Institutional Controls through its Five Year Reviews to
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ensure the remedy remains protective of human health and the environment. To facilitate future
use and redevelopment of the Property consistent with the cleanup. Institutional Controls will also
be established to appropriately manage impacted soil, soil vapor, and groundwater encountered
during future intrusive activities (e.g., installing subsurface utilities, building foundations/slabs,
etc.) to protect human health and the environment. In the event that a future land owner or
developer fails to comply with the Institutional Controls, EPA and the state can take enforcement
actions requiring compliance.
Comment #21
Consolidation of the cleanup components does not promote public understanding of the interrelationships
between the various cleanup components and does not allow for optimization. The alternatives should be
decoupled for case in evaluation.
EPA Response:
EPA considered several methods to develop remedial alternatives, but ultimately selected
bundling alternatives because some of the alternatives arc interrelated and needed to be combined
to be appropriately protective. Additionally, due to the large number (34) and complexity of the
remedial alternatives considered in Volumes I and II of the FS report for the eight cleanup
components - DAPL, groundwater hot spots, LNAPL, surface water. Containment Area soil,
upland soil, wetland soil and sediments, and TMPs in soil - EPA sought to simplify and
consolidate the cleanup components to promote public understanding of the interrelationship
between the various cleanup components and to reduce the number and extent of comparative
analyses required. See FS Report Volume III (USEPA, 2020c) for further discussion on the
rationale for consolidating the cleanup components.
The eight original cleanup components were grouped by media, which resulted in the linking of
DAPL with groundwater hot spots for the development of a set of alternatives for an interim
action to address the major sources of contamination in OU3. For the final action for OU1 and
OU2, LNAPL was coupled with surface water, because of the inherent potential impacts to East
Ditch Stream surface water from LNAPL contamination and the prudence of developing a
consistent approach to addressing all surface water contamination at the Site. Further, all of the
soil and sediment alternatives (Containment Area soil, upland soil, wetland soil and sediments,
and TMPs in soil) were bundled together in consideration of their interrelated nature and to
facilitate the development of a set of alternatives to address contamination on and in the
immediate environs of the Property.
Comment #22
WERC prefers Alternative GWHS-4 - DAPL extraction (approx. 20 wells), groundwater hot spot
extraction targeting 1,10® ng/L NDMA (approx. 12 wells), on-site treatment at new treatment system -
rather than Alternative GWHS-3 - DAPL extraction (approx. 20 wells), groundwater hot spot extraction
targeting 5,000 ng/L NDMA (approx. 6 wells), on-site treatment at new treatment system - which was
listed as the preferred alternative component in the Proposed Plan, for the following reasons: it includes
more mass removal; does more to prevent further NDMA migration into the aquifer and bedrock, making
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final cleanup more feasible; similar implementation to the selected alternative (Alternative GWHS-3);
target concentration is still two orders of magnitude above the target cleanup level for NDMA; marginal
cost increase of 14% present worth; construction time and time to achieve RAOs is the same as
Alternative GWHS-3; and better achieves RAOs.
EPA Response:
Understood. Please see EPA's response to Comment #3 in Section B, above.
Comment #23
The groundwater hot spot alternatives GWHS-2 through GWHS-4 include new prohibitions on the use of
groundwater in the OU3 study area unless demonstrated that it will not pose an unacceptable risk, cause
further plume migration, or interfere with the remedy. Given these prohibitions, will residents and
property owners be provided with water to replace their well water?
EPA Response:
Residential well water within the OU3 study area is tested quarterly to evaluate the potential risk
posed. If residents and property owners within the study area are not already in the quarterly
sampling program, they are welcome to reach out to EPA to discuss their potential risk and
whether sampling of their well is warranted. If sampling indicates a potential unacceptable risk,
residents and other users may be connected to existing or planned water lines. At this time, Olin
is providing bottled water and water coolers to two residences and working cooperatively with the
Town of Wilmington to extend a water line to these residences. Other properties in the area
already have a water line nearby for connection. If a new well is planned, EPA will work with the
Town of Wilmington to ensure that the well docs not have the potential to cause adverse impacts
to health or to the groundwater remedy.
Comment #24
WERC considers Alternative DAPL/GWHS-4 - DAPL extraction (approx. 20 wells), groundwater hot
spot extraction targeting 1,100 ng/L NDMA (approx. 12 wells), on-site treatment at new treatment system
- to be more effective than the selected alternative (Alternative DAPL/GWHS-3 - targeting 5,000 ng/L
NDMA) because it will remove more source material sooner. Each delay in removal of source material
results in more contamination migrating to bedrock, where it is much more difficult to remove or treat.
EPA Response:
Understood. Please sec EPA's response to Comment #3 in Section B, above.
Comment #25
WERC disagrees with EPA's rating of Alternative DAPL/GWHS-4 - DAPL extraction (approx. 20
wells), groundwater hot spot extraction targeting 1,100 ng/L NDMA (approx. 12 wells), on-site treatment
at new treatment system - as "fair" and Alternative DAPL/GWHS-3 - DAPL extraction (approx. 20
wells), groundwater hot spot extraction targeting 5,000 ng/L NDMA (approx. 6 wells), on-site treatment
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at new treatment system - as "good" for short-term effectiveness given that risks to the community are
modest and can be minimized with best management practices. The groundwater extraction well
placements for Alternatives DAPL/GWHS-4 and -3 are similar.
EPA Response:
While the location of the groundwater extraction wells are generally similar for the two
alternatives, Alternative DAPL/GWHS-4 incorporates one extraction well approximately 400 ft
further into the MMB wetlands. This may have significant temporary impacts on the wetland
during construction of the extraction well and associated pipeline. Furthermore, two additional
extraction wells arc located on commercial properties and have some additional administrative
and potentially operational impacts. Finally, while best management practices will be used to
minimize impacts, the potential for impacts is larger in general for alternatives with more
infrastructure. Therefore, EPA still supports the original ratings for short-term effectiveness of
"good" for Alternative DAPL/GWHS-3 and "fair" for Alternative DAPL/GWHS-4.
Comment #26
WERC disagrees with EPA's rating of Alternative DAPL/GWHS-4 - DAPL extraction (approx. 20
wells), groundwater hot spot extraction targeting 1,100 ng/L NDMA (approx. 12 wells), on-site treatment
at new treatment system - as "fair" and Alternative DAPL/GWHS-3 - DAPL extraction (approx. 20
wells), groundwater hot spot extraction targeting 5,000 ng/L NDMA (approx. 6 wells), on-site treatment
at new treatment system - as "good" for implementability, and considers the alternatives to be the same,
with the exception that the ease of implementing future remedial actions is considered to be better for
Alternative DAPL/GWHS-4.
EPA Response:
The installation of an additional extraction well and associated infrastructure much further into
the MMB wetlands as part of Alternative DAPL/GWHS-4 poses significant logistical challenges:
all construction and maintenance would need to be tailored to minimize environmental impacts to
a significant wetland resource, but at the same time, physical access to this area is challenging
because of the soft ground and shallow water (that prevents use of water craft such as a barge).
The additional wells outside of the MMB wetlands under Alternative DAPL/GWHS-4 also add
some complexity to the design and operation of the extraction system. EPA acknowledges that a
more aggressive approach earlier in the process may assist with later groundwater remediation,
but considers that overall. Alternative DAPL/GWHS-4 is somewhat less implcmentable than
Alternative DAPL/GWHS-3.
Comment #27
For LNAPL and surface water, WERC agrees with the selection of Individual Cleanup Component
LNAPL-5 - continued operation of Plant B to capture and treat LNAPL, followed by Plant B demo! ition
and expanded Multi-Phase Extraction (MPE) - but would prefer to pair this with surface water Individual
Cleanup Component SW-3 - groundwater extraction and treatment - which has more extensive
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groundwater extraction because this combination of alternatives for LNAPL and surface water would
better achieve RAOs. The cost of this alternative is unknown.
EPA Response:
Individual Cleanup Component SW-4 - targeted groundwater extraction and treatment - was
included in the selected remedy because it included groundwater extraction and treatment at the
identified source areas for potential groundwater impacts to surface water: the Plant B area,
groundwater that may have been impacted by the Jewel Drive and Containment Area DAPL
pools, and areas of elevated groundwater contamination that may be migrating from the industrial
area in the northern portion of the Property. At the same time, this Individual Cleanup
Component minimized the potential impacts on wetland areas to the south and southeast of the
Containment Area. As provided in Section 4.5.2.7 (Individual Cleanup Component SW-3) and
Section 4.5.3.7 (Individual Cleanup Component SW-4) of the FS Report Volume I (Olin, 2020a),
the net present worth (NPW) of Individual Cleanup Component SW-3 was estimated to be
approximately $8.8 million compared to approximately $5.0 million for Individual Cleanup
Component SW-4. Given the other factors listed above and the cost difference, EPA retained
Individual Cleanup Component SW-4. Note that the final configuration of groundwater
extraction wells will be determined based on PDI results, subject to EPA's review and approval.
Comment #28
A new alternative for the Containment Area should be developed that includes excavation of all soil
above PRGs.
EPA Response:
Please see EPA's response to Comment #8 in Section B, above.
Comment #29
WERC disagrees with EPA's selection of Individual Cleanup Component SOIL-2 - soil covers - for
upland soil and does not consider Institutional Controls to be sufficient to address soil, given that
compliance would be left to future property owners/operators. Following the National Institute for
Occupational Safety and Health (NIOSH) and EPA's waste management hierarchy. Institutional Controls
should be a solution of last resort.
EPA Response:
EPA has considered the reasonably anticipated future land use of the Property—in light of its
industrial history and its location in a commercial/industrial area—in selecting Institutional
Controls as a component of the remedy to ensure the prohibition of residential use. Soil covers
will restrict access for ecological receptors. Please see also EPA's responses to Comment #6 in
Section B and Comment #20 in Section C, II, above.
Comment #30
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WERC disagrees with EPA's selection of Individual Component TMP-2 - limited action (Institutional
Controls, including vapor intrusion evaluations or vapor barriers and/or SSDSs - for TMPs in Soil and
prefers to see treatment or excavation of TMP-impacted soil.
EPA Response:
TMPs pose potential human health risks on the Property via the subsurface-to-indoor vapor
intrusion pathway in future occupied buildings. Vapor intrusion risks are commonly and reliably
mitigated in new construction by including vapor barriers and sub-slab ventilation systems, which
can be readily incorporated into new building designs.
Comment #31
Soil data for the Containment Area have not been presented in a timely fashion to make an informed
decision about this area, and the monitoring results were not compared to the upland soil PRGs.
EPA Response:
EPA does not consider the assessment of Containment Area soil to date to be comprehensive
(please see EPA's response to Comment #4 in Section C, I, above) and acknowledges the time
constraints for analyzing the data produced by the November 2019 Containment Area soil
investigation prior to drafting RAOs for Site media. Results from the November 2019
Containment Area soil investigation were transmitted from Olin to EPA on March 20, 2020 and
shared with WERC on March 23, 2020. The principal purpose of the 2019 investigation was to
better define the requirements of the remedial action selected by EPA, specifically the
requirements under RCRA by which the wastes within the Containment Area would need to be
remediated, contained, and monitored for the foreseeable future. The 2019 investigation did not
indicate that soil within the Containment Area exhibited toxicity characteristics as defined by
RCRA (40 C.F.R. § 261.24(a)).
The PRGs established in the feasibility study for TMPs, BEHP, and chromium for upland soil and
Containment Area soil assume that a complete risk pathway is present, meaning birds were
feeding in the area and thus in direct contact with the contaminated soil. At the time of the
issuance of this ROD, Containment Area soil is ov erlain by a temporary cover that theoretically
prevents water infiltration and also disrupts the primary risk pathway for ecological receptors.
Considering the results of the 2019 investigation, historical disposal practices, and analytical data
produced by the RIs for the Site, EPA determined that a multi-layer, low-permeability cap
compliant with RCRA Subtitle D and Massachusetts solid waste landfill performance standards
would be necessary to address the risks posed by Containment Area soil. Specifically, the low-
permeability cap preferred by EPA would further prevent leaching of Site contaminants
associated with the Containment Area into groundwater, surface water, and sediments at levels
that pose unacceptable risks to human health and the environment. Although soil results from the
Containment Area were not compared to the upland soil PRGs - which were established based on
ecological exposures and risks - the low-permeability cap in the Containment Area would also
address these risks, should they exist, by eliminating the exposure pathway.
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Comment #32
The Containment Area does not adequately control groundwater. While the proposed cap would prevent
contact with soil, it would not prevent the continued migration of groundwater into the Containment Area
from the north and the migration of groundwater out of the Containment Area to the south. Because the
OU3 (groundwater) FS will be completed in the future, any decision regarding the Containment Area is
premature at this time.
EPA Response:
EPA agrees that the current temporary cap is inadequate, that shallow groundwater migrates out
of the Containment Area via the equalization window, and that there appears to be some degree
of groundwater leakage elsewhere from the Containment Area at the interface between the slurry
wall and bedrock surface. As discussed in EPA's response to Comment #4 in Section C, I,
above, it is important to note that the Containment Area contains both solid waste material that
poses a threat of leaching contaminants into groundwater, and DAPL, a liquid that can flow and
similarly leaches contaminants into groundwater. The selected remedy includes the installation
of a low-permeability cap over the Containment Area and closure of the equalization w indow to
reduce the infiltration of water into this area and minimize leaching of contaminants from the
solid waste and soil into groundwater. The selected remedy also includes the extraction of DAPL
within the Containment Area to remove this material as a source of contaminants to groundwater.
Collectively, these activ ities are intended to control the sources of groundwater contamination in
this area; they are not intended to result in restoration of the aquifer. Further inv estigations and
an FS are needed to understand the full nature and extent of groundwater contamination and to
evaluate alternatives for restoration of the aquifer. It is common practice in the Superfund
cleanup process to start cleanup of a site by first selecting remedies that control the sources of
contamination, followed by selecting remedies that achieve all the cleanup goals for the site.
Therefore, EPA does not agree that selection of the source control activities for the Containment
Area is premature. Once again, further alternatives will be evaluated as part of OU3
(groundwater) to further address groundwater contamination migrating from this area.
Comment #33
EPA needs to decide if the Containment Area truly restricts groundwater flow. If it does, then
contaminated soils and sediments from elsewhere at the Site should be added before installing a cap. If
not, then the contaminated soils above PRGs should be removed and clean fill added, without adding a
cap.
EPA Response:
As noted previously in EPA's responses to Comment #5 in Section B, Comment #4 in Section C,
I, and Comment #31 in Section C, II, above. EPA does not believe that the Containment Area,
with its current temporary cap and slurry wall, is protective enough for the issues posed by this
area of the Site. The Containment Area contains solid wastes that can leach contaminants and act
as on ongoing source of contaminants to the aquifer. The area also contains DAPL that can
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migrate into bedrock fractures and act as on ongoing source of contamination to the aquifer.
EPA's remedy involves closing the equalization window, capping the solid waste with a low-
permeability cover to minimize infiltration, and extracting DAPL. These actions serve as source
control measures to minimize ongoing impacts to groundwater.
The upland soil located outside of the Containment Area poses a different kind of risk. These
upland soils pose ecological risks to birds feeding in the area. As such, these risks can be
managed with different types of cover systems, such as clean soil or pavement. The upland soil
does not pose a threat of leaching contaminants to the aquifer and as such does not require
management via a low-permeability cover. Consolidation of contaminated upland soil within the
Containment Area and under the low-permeability cap was considered by EPA (please see EPA's
response to Comment #9 in Section B, above); howev er, the volume of soil requiring excavation
and consolidation would likely cause capacity issues within the Containment Area.
III. Written comments submitted by the Town of Wilmington (Board of Selectmen and
Geolnsight. Inc.) on October 22, 2020
Comment #1
Wilmington residents and their Town government did not cause or contribute to the contamination of the
Property, private residential and commercial properties, a major aquifer and five of the Town's nine
drinking water wells. Nor were they in a position to manage or mitigate that contamination, other than
commenting on technical reports and work plans. Therefore, the Town of Wilmington should be afforded
ample opportunity to contribute to decision-making concerning the selection and scope of plans to
remediate that contamination.
EPA Response:
Part 2, Section C, COMMUNITY PARTICIPATION, above, of this ROD explains that EPA
made significant efforts to keep Town of Wilmington officials, WERC, and other interested
members of the public informed with regards to the development of the FS, Proposed Plan, and
supporting documents leading up to the issuance of the Proposed Plan. EPA provided the public
an extended opportunity (10 days) for review of the Proposed Plan before the start of the formal
comment period, and also conducted an extended formal comment period (60 days) for all parties
to review the record and provide comments. Please see also EPA's response to Comments #1,
#10, and #15 in Section C, II, above.
EPA is required by statute to hold a formal public comment period to receive comment on its
identified range of proposed cleanup approaches and its preferred alternative published in the
Proposed Plan. EPA considers and uses these comments to improve the cleanup approach
ultimately selected. In the Superfund process, the formal comment period on cleanup alternatives
is concluded and a cleanup plan is selected and documented in the ROD before the engineering
design phase can start. Although a formal public comment period is not held during any portion
of the engineering design phase, EPA incorporates opportunities for public involvement as it
proceeds with the implementation of the cleanup plan. EPA will seek the input of Town officials
and WERC in design planning such as addressing soil and sediment erosion controls; flood.
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wetland, and stormwater management; traffic and construction management; and health and
safety. As design progresses, EPA will issue several design documents (such as a 30% design,
60% design, and 100% design), outlining construction and monitoring plans in detail. These
design documents will be shared with Town officials, WERC, the public, and other interested
parties. Likely mechanisms for sharing engineering design information include posting design
documents on the Site webpage and the EPA contractor's fileshare webpagc, making them
available at the information repositories, distributing e-mail updates, a Site fact sheet, and
community mailers highlighting the design information, and holding public informational
meetings. In addition, EPA will coordinate closely with residents who reside on potentially
impacted properties. EPA remains committed to facilitating additional public input into the
implementation of the remedy and will continue to discuss the Town's and public's concerns as
we move forward.
Comment #2
Remediation should make good on the original goal of restoring the Ipswich Watershed and Aberjona
Watershed and the Town of Wilmington's drinking water resources.
EPA Response:
Please see EPA's responses to Comments #1 and #3 in Section B, above.
Comment #3
Remedial measures should be sufficient to withstand any potential redevelopment and not be
compromised by cost concerns.
EPA Response:
EPA will continue to prov ide oversight to ensure that redevelopment does not adversely impact
the construction and operation of the selected remedy for the Site and EPA's efforts to collect
more data as needed to select and implement a final remedy for groundwater (OU3). If
redev elopment occurs, EPA will review any redev elopment plans to ensure that the portion of the
Site under consideration for redevelopment is safe for the intended use. Please see also EPA's
response to Comments #2 and #17 in Section B, above.
EPA is required by statute and regulation to consider cost in the Supcrfund remedy selection
process. Please see EPA's response to Comment #7 in Section B and Comment #12 in Section
C, II, above.
Comment #4
The Town is concerned that the Containment Area slurry wall may not have been installed properly, that
the slurry wall's integrity is suspect, and that it has allowed the migration of DAPL contaminants to
surrounding media and off-site. While the Town's preference would be complete cleanup and full
remediation, the Town recognizes that a substantial and secure cap could be a valid method. The Town
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urges EPA to rigorously re-evaluate the cap and extraction measures at the Containment Area at each Five
Year Review, or more frequently, once installed.
EPA Response:
The original intent of the slurry wall was to cut off the migration of contamination and contain
the DAPL within the boundaries of the 01 in Property (Property ). However, this effort was not
successful. The DAPL pooled beneath the Property (the On-Property DAPL Pool) migrated via
gravity flow over time into a lower depression to the west and formed the Jewel Drive DAPL
Pool. When the second depression filled, DAPL migrated into a third depression creating the
Main Street DAPL Pool. The extent of DAPL beyond these pools is currently unknown and will
be investigated further during the 0U3 RI.
EPA agrees with the commenter that the current temporary cap is inadequate for the purposes of
reducing or eliminating the movement of Site contaminants. EPA's selected remedy for the
Containment Area addresses the issue of the open equalization window within the slurry wall,
which may contribute to the inability of the current Containment Area design to adequately
contain Site contaminants. EPA is also of the opinion that there appears to be some degree of
groundwater leakage elsewhere from the Containment Area at the interface between the slurry
wall and bedrock surface (see EPA's response to Comment #32 in Section C, II, above).
Irrespective of the root cause of the observed leakage through the slurry wall, EPA's selected
remedy of a permanent cap for the Containment Area addresses the threat of leaching of Site
contaminants associated with the Containment Area into groundwater, surface water, and
sediments at levels that pose unacceptable risks to human health and the environment. More
importantly, EPA's selected interim remedy for DAPL and hot spot groundwater includes
extraction wells both inside and outside of the Containment Area slurry wall. The extraction
network is the primary mechanism to address the liquid waste (e.g. DAPL and contaminated
groundwater) in this area which is acting as a continuous source. The use of this extraction
network minimizes the issues associated with the possible leakage occuring through the slurry
wall.
At the conclusion of the remedy construction, hazardous substances, pollutants, or contaminants
will remain at the Site. Therefore, as required by law, EPA will review the Site remedy to ensure
that the remedial action continues to protect human health and the environment at least once
every five years as part of the Agency's Five Year Reviews for the entire Site. These Five Year
Reviews will evaluate all of the components of the Site remedy for as long as contaminated media
above CERCLA risk levels remain in place.
Comment #5
The Town recognizes that the proposed 5,000 ng/L NOMA target for groundwater hot spot extraction is
associated with an interim action and that a lower concentration target is expected to be adopted in the
future. EPA should re-evaluate the need for a far lower target level as it develops final remedial plans.
EPA Response:
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Please see EPA's response to Comment #3 in Section B, above.
Comment #6
The proposed cleanup plan may result in a net loss of water from the Ipswich Watershed and depletion of
groundwater in the MMB aquifer, which is mostly located in the Ipswich Watershed. The treatment
system design should therefore include mechanisms to mitigate or minimize potential groundwater
depletion in the MMB aquifer. EPA should require that the extraction, treatment, and discharge of treated
groundwater should be designed and implemented, as much as practicable, in order to minimize the
transfer of groundwater between the Ipswich and Aberjona watersheds.
EPA Response:
Generally, treated groundwater should be returned to the watershed from which it was withdrawn
to the extent feasible. Years of data collected from the Site demonstrate that the water table
across the impacted area is typically flat, with frequent groundwater mixing between the Ipswich
and Aberjona River watersheds. This Site-specific hydrologic information indicated that the
impacts of groundwater withdrawal will likely not have a significant effect on the MMB aquifer.
However, the impacts of extraction and discharge of groundwater will be evaluated further during
design and the design will be based on an approach that minimizes adverse impacts. In addition,
once the remedy is operational, continued monitoring will occur to demonstrate that the system is
not resulting in adverse impacts to either watershed. Please see also EPA's response to Comment
#4 in Section B, above.
Comment #7
Wilmington is prepared to cooperate with EPA to develop and implement appropriate restrictions on use
of private wells in areas specifically impacted by Site contamination. However, EPA should more
specifically identify the nature, scope, and geographic areas for bylaws or other locally-imposed
restrictions or conditions on residential or industrial water usage and/or construction of wells. Details
regarding these restrictions should be included in the ROD.
EPA Response:
EPA will work closely with the Town of Wilmington on the development of Institutional
Controls for limiting the use of groundwater either through the passage of an ordinance, an
amendment to local bylaws, or the establishment of procedures. This ROD contains information
on the nature, scope, and geographic area where the restrictions should apply (see Figure 11 in
Appendix C of this ROD). EPA will periodically review the Institutional Controls for the
groundwater, at a minimum every five years, to make sure that they are effective and cover the
appropriate area as more information about the extent of contamination is developed. Please see
also EPA's response to Comment #6 in Section B, above.
Comment #8
The interim target groundwater concentration that was developed (5,000 ng/L) is several orders of
magnitude above concentrations that are protective of human health and the environment. The final
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cleanup plan for groundwater should include a target cleanup goal for NDMA that is significantly lower
than the interim action goal of 5,000 ng/L; expansion of the groundwater extraction system to remediate
areas where NDMA concentrations arc below 5,000 ng/L; remediation of groundwater to concentrations
that do not present a risk to human health or the environment for unrestricted uses; and restoration of the
MMB aquifer to meet drinking water standards.
EPA Response:
Please see EPA's responses to Comments #1 and #3 in Section B, above.
Comment #9
The interim groundwater extraction and treatment system should be designed so that it can be readily
expanded to receive additional DAPL and/or contaminated groundwater. The system design should
include: oversized liquid conveyance piping diameter to accommodate potential increases in liquid flow;
installation of spare piping in trenches for potential future use; adding valves or appurtenances to the
piping so that additional extraction wells can be installed in the future; and designing a treatment system
with sufficient excess capacity to accommodate potential increases in flow rate.
EPA Response:
EPA agrees with the comment. The potential for capacity expansion will be considered during
rev iew of the PDI and RD documents.
Comment #10
EPA's preferred alternative for LNAPL and surface water in the Proposed Plan is LNAPL/SW-3 -
Demolition of Plant B, MPE for LNAPL, Targeted Groundwater Extraction to Prevent Impacts to Surface
Water, Treatment at New Treatment System(s). This approach is not expected to be effective in
achieving cleanup goals and a different remedial alternative should be considered for LNAPL. The
LNAPL has been described as "#415 Process Oil" and process oil that contains BEHP, NDPhA, and
TMPs. This LNAPL is considered to be a highly viscous oil that is relatively immobile. LNAPL
mobility tests have not been conducted, but the LNAPL appears to have remained in the same
approximate area where it was originally identified and does not appear to be migrating. LNAPL
recovery rates have been very low and LNAPL remains despite nearly 40 years of active remediation.
This indicates that the LNAPL is not sufficiently mobile to be recovered by MPE. EPA should consider
an alternative approach that combines Individual Cleanup Component LNAPL-6 (excavation and off-site
disposal) with Individual Cleanup Component SW-3 (groundwater extraction and treatment). This
approach would remove the LNAPL directly and allow groundwater extraction wells to be installed
directly in the excavation prior to backfill.
EPA Response:
EPA's preferred alternative for LNAPL and surface water - Alternative LNAPL SW-3 - includes
MPE for the treatment of LNAPL. MPE and excavation were among a set of alternatives
evaluated to address LNAPL contamination near Plant B in the Interim Action Feasibility Study
(FSReport Volume II; Olin, 2020b) and Volume III - Comparative Analyses, Feasibility Study
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Report, Olin Chemical Superfund Site, Wilmington, Massachusetts (FS Report Volume III,
USEPA, 2020c). Please see also EPA's response to Comment #8 in Section C, I, above.
EPA disagrees with the commenter's position that MPE will not be effective in achieving the
cleanup goals, and that LNAPL is not sufficiently mobile to be recovered by MPE. LNAPL
remediation over the history of the Site has been passive - limited to removal by hand via
skimmers or absorbent bailers - and while current recovery volumes are low, they demonstrate
some degree of mobility. LNAPL was first detected as oily seepage into East Ditch Stream, and
has remained in the same general area since its release because of the lack of a significant
hydraulic gradient due to groundwater extraction by Plant B. LNAPL that is inherently mobile is
not expected to migrate when a negligible groundwater gradient is present. Additionally,
remediation efforts were limited in the past by the presence of the Plant B building, which will be
demolished under the selected remedy to facilitate access to the entire LNAPL-contamination
area. MPE is a more robust remedy than passive removal of LNAPL, and its implementation will
include PDIs and testing. Under the selected remedy, the geographical extent of LNAPL will be
further delineated via additional sampling and the LNAPL will be further characterized, including
evaluations of LNAPL mobility. PDI data will be used to develop operating parameters and to
calibrate the MPE system.
As the MPE remedy becomes operational, EPA will closely monitor its progress to ensure that the
system is functioning as intended and working to meet the RAOs of preventing migration of
LNAPL to East Ditch Stream and removing LNAPL that represents a source of Site contaminants
to groundwater and a source of TMPs to indoor air in future building construction. EPA's
selected remedy also includes groundwater extraction and treatment to prevent impacts to surface
water.
For the reasons described above, excavation of LNAPL-impacted soil would only be slightly
more effective in the long term than MPE. However, MPE provides for more reduction of
contaminant toxicity, mobility, or volume than excavation, as EPA's Selected Alternative
LNAPL SW-3 will utilize an estimated three to five MPE wells to capture and treat soil vapor and
groundwater, and only limited reduction of pollutant mobility would occur during excavation
through the addition of bulking agents to facilitate off-site disposal. Both alternatives would be
protective of human health and the environment and would meet ARARs. Both alternatives
would remediate LNAPL in approximately one year, but excavation has greater short-term
impacts in terms of worker and community health and safety issues due to risks associated
LNAPL volatilization during excavation and trucking LNAPL-contaminated soil through the
community for off-site disposal. Moreover, MPE is easier to implement than excavation because
excavation would interfere with existing extraction and/or monitoring wells on the Property, and
if additional LNAPL-impacted soil is encountered during excavation activities, removing those
impacts would be difficult due to potential encroachment on the active Massachusetts Bay
Transportation Authority (MBTA) railroad line and sheet piling along the bank of East Ditch
Stream may also be necessary. The costs of MPE are proportional to its overall effectiveness, and
it is therefore cost effective.
Additionally, as required bv law, EPA will review the Site remedy, including the MPE remedy
for LNAPL, to ensure that the remedial action continues to protect human health and the
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environment at least once every five years as part of the Agency's Five Year Reviews for the
entire Site as long as hazardous substances, pollutants, or contaminants remain at the Site above
levels that allow for unrestricted use. These Five Year Reviews will evaluate all of the
components of the Site remedy for as long as contaminated media above CERCLA risk levels
remain in place.
Comment #11
EPA's proposed alternative to install a permanent cap over the Containment Area is expected to
adequately address residual impacts and achieve RAOs. However, Olin's investigations in the
Containment Area were limited and may be insufficient to adequately assess remaining impacts.
EPA Response:
EPA agrees that the investigations within the Containment Area were limited and may not
completely characterize all Containment Area soil. This area has been reworked several times
during the history of the Site and during previous response actions. As such, the area would need
a more robust sampling program to demonstrate that the soils in this area do not pose a leaching
threat to groundwater. Please see also EPA's response to Comment #4 in Section C, I, above.
Comment #12
A significant amount of information will be collected regarding DAPL and groundwater impacts from the
ongoing data gaps investigation. The Town and its contractor expect a final cleanup plan for OU3 after
the data gaps work is completed and expect to review and comment on that document.
EPA Response:
Comment noted. Please see also EPA's response to Comment #10 in Section C, II, above.
IV. Written comments submitted by residents on October 26 & 27, 2020
Comment #1 (C. Baima, J. Baima)
The plan for the remedial action should involve cleaning rather than covering contamination.
EPA Response:
Portions of the selected remedy do consist of removal of contamination (the interim remedies for
DAPL and groundwater hot spots; and the final remedy for wetland soil and sediments) based on
a full evaluation that includes feasibility, cost, as well as effectiveness. Removal of all other
impacted soil has a high degree of permanency relative to the other alternatives evaluated,
however, EPA considered other factors as outlined in Superfund guidance. Excavation of all
impacted soil requires significant effort to manage, consolidate, dewater, and transport material,
and also results in more potential short-term impacts to workers and neighboring areas from this
work. In addition, excavation near the eastern boundary of the Olin property (Property) may
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require additional structural support close to the MBTA railroad tracks, which poses significant
structural, logistical, and safety challenges given that this is an active commuter rail line.
The engineering controls for the soils remaining in place under the selected remedy - capping and
cover systems, installation of soil vapor barriers and other vapor mitigation systems for potential
future buildings - are reliable and widely-accepted technologies. Given that the Property is zoned
for industrial use and that soil impacts are generally limited to the Property or immediately
adjacent to the Property boundary, EPA considers engineering controls and Institutional Controls
to be adequately reliable for the soil contamination remaining in place under the selected remedy.
As part of the selected remedy, Five Year Reviews will be required for as long as contamination
remains in place at concentrations above residential criteria, and these reviews will evaluate the
engineering controls and Institutional Controls in place to ensure their adequacy. Please see also
EPA's responses to Comment #8 in Section B and Comments #14 and #20 in Section C, 11,
above.
Comment #2 (C. Baima, J. Baima)
What is the possible impact on the planned interim or final activities in the case of bankruptcy or change
in ownership for Olin or other prior or future owners? The various owners of the Olin Site should not be
excused from their environmental, social and fiscal responsibilities.
EPA Response:
Under CERCLA, the classes of liable parties include current owners and operators of a facility
and past owners and operators of a facility at the time of disposal of hazardous substances. Part
2, Section B.3, SITE HISTORY AND ENFORCEMENT ACTIVITIES, History of CERCLA
Enforcement Activities, above, of this ROD explains that as a result of Site PRP search activities,
EPA issued notices of potential liability to several PRPs, including American Biltrite, Inc.,
Biltrite Corp., Olin, Stepan Company, Fisons Limited, and NOR-AM Agro LLC. These parties
cither owned or operated the Facility at a time when hazardous substances were disposed or are a
successor to an entity that was the owner or operator of the Facility at a time of disposal of
hazardous substances. Olin is the current owner and operator of the Facility. Pursuant to an
Administrative Settlement Agreement and Order on Consent (AOC), Olin, American Biltrite,
Inc., and Stepan Company have been performing the RI/FS with EPA oversight, which is still on-
going for Site-wide groundwater. Therefore, EPA has identified a number of parties that it
believes are responsible for the contamination at the Site and expects that these parties will pay
for/perform the cleanup.
CERCLA liability is joint and several, which means that any one PRP may be held liable for the
entire cleanup of a site. Therefore, if Olin or any of the other PRPs are unable to fulfill their
cleanup obligations at the Site, the other PRPs would be required to satisfy the obligations.
Additionally, EPA negotiates financial assurance requirements in its Superfund settlements and
imposes financial requirements on PRPs through orders. In general, financial assurance
provisions in settlements and orders require PRPs to demonstrate that adequate financial
resources are available to complete required cleanup work.
CERCLA was amended in 2002 to allow certain parties who purchase contaminated properties to
buy such properties and avoid potential CERCLA liability if they qualify as a "bona fide
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prospective purchaser" ("BFPP"). The BFPP provision provides that a person meeting the
criteria ofCERCLA Sections 101(40) and 107(r)(l) and who purchases after January 11, 2002 is
protected from CERCLA liability and will not be liable as an owner or operator under CERCLA.
To meet the statutory criteria for a BFPP, a landowner must satisfy certain threshold criteria and
continuing obligations. Among other continuing obligations, a BFPP must do the following: (!)
provide full cooperation, assistance, and access to persons that are authorized to conduct response
actions at the site; (ii) take reasonable steps to stop any continuing release; prevent any threatened
future release; and prevent or limit human, environmental, or natural resource exposure to any
previously released hazardous substance; and (iii) establish that it is in compliance with any land
use restrictions established or relied on in connection with the cleanup, and it does not impede the
effectiveness or integrity of any Institutional Control employed in connection with the cleanup.
Landowners must comply with land use restrictions and implement Institutional Controls even if
the restrictions or Institutional Controls were not in place at the time the person purchased the
property. Therefore, any future owners of the Olin property will be required to meet these
requirements in order to maintain BFPP status. Please see also EPA's response to Comment #20
in Section C, II, above.
Comment #3 (C. Baima)
If the Containment Area is working as intended, contaminated material should be consolidated within it
prior to capping. If not, it should be fixed prior to capping or the soils should be removed. If the status of
the cap is unknown, a remedy should not be selected at this time.
EPA Response:
Please see EPA's responses to Comments #8 and #9 in Section B, above. Comment #4 in Section
C, I, above, and Comments #14 and #32 in Section C, II, above.
Comment #4 (C. Baima)
Cost should not be a criterion for the selection of alternatives.
EPA Response:
Please see EPA's response to Comment #7 in Section B, above.
Comment #5 (C. Baima)
Remedial alternatives should be selected based on the expectation of restoration of soil and water to pre-
contamination conditions and in the shortest possible timeframe. The goal for groundwater is to restore
the aquifer to drinking water conditions.
EPA Response:
EPA's May 25, 1995 directive entitled. Land Use in the CERCLA Remedy Selection Process
(available at: https://www.epa.gov/sites/production/files/documents/landuse.pdf) provides
information for considering land use in remedy selection decisions. Major points of this directive
include the following:
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• Discussions with local land use planning authorities, appropriate officials, and
the public, as appropriate, should be conducted as early as possible in the
scoping phase of the Remedial Investigation/Feasibility Study (RI/FS). This will
assist EPA in understanding the reasonably anticipated future uses of the land on
which the Superfimd site is located;
• Remedial action objectives developed during the RI/FS should reflect the
reasonably anticipated future land use or uses; and
• Future land use assumptions allow the baseline risk assessment and the
feasibility study to be focused on developing practicable and cost effective
remedial alternatives. These alternatives should lead to site activities which are
consistent with the reasonably anticipated future land use.
The Olin property (Property) is zoned for commercial/industrial use; EPA's understanding from
discussions with Town of Wilmington officials is that the reasonably anticipated future uses of
the Property continues to be commercial/industrial. Therefore, EPA developed the set of cleanup
objectives for the Property during the remedy selection process with this anticipated future land
use in mind. The RAOs developed to address soil contamination resulted in a set of remedial
alternatives to address the ecological and human health risks posed by the Site, including the
human health risks posed by the contamination on the Property that would need to be addressed
to make the Property ready for commercial/industrial re-use.
Section 121(b)(1) of CERCLA presents the factors that, at a minimum. EPA is required to
consider in its assessment of remedial alternatives. The selected remedies for soil (cap or cover
systems for soil across the Property to prevent exposure and potential leaching; removal of
contaminated soil and sediments from w etland areas and wetland restoration; treatment of
LNAPL-contaminated soil via MPE; and vapor intrusion evaluations and/or mitigation systems
for TM P-contaminated soil) meet the five principal requirements for the selection of remedies in
CERCLA Section 121 and the nine criteria (see further discussion in PART 2, Section K,
SUMMARY OF THE COMPARATIVE ANALYSIS OF ALTERNATIVES of this ROD.
above).
Low-level threat wastes arc source materials that generally can be reliably contained and that
would present only a low risk in the event of exposure. The NCP, which governs EPA cleanups,
at 40 CFR § 300.430(a)(l)(iii), states that EPA expects to use "treatment to address the principal
threats posed by a site, wherever practicable" and "engineering controls, such as containment, for
waste that poses a relatively low long-term threat" to achieve protection of human health and the
environment. Wastes that are generally considered to be low-level threat wastes include non-
mobile contaminated source material of low to moderate toxicity, surface soil containing Site
contaminants that are relatively immobile in air or groundwater, low-leachability contaminants,
or low toxicity source material. Low-level threat wastes on the Olin property include soil
impacted with chromium and BEHP. These materials will be addressed by installing a
permanent, low-permeability cover over the Containment Area and installing soil and/or asphalt
cover systems for contaminated upland soil. Institutional Controls and long-term maintenance of
covers and caps will be used to address these materials over the long term.
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The NCP describes EPA's expectations for groundwater restoration and states that EPA expects
to return usable ground waters to their beneficial uses wherever practicable, within a timeframe
that is reasonable given the particular circumstances of the site. When restoration of ground
water to beneficial uses is not practicable, EPA expects to prevent further migration of the plume,
prevent exposure to the contaminated ground water, and evaluate further risk reduction. Since
portions of the aquifer at the Site are classified as drinking water sources and since MassDEP has
assigned a high use and value for the Site area aquifer, the goal for the groundwater would be to
restore this aquifer to its beneficial use, unless it is determined not to be practicable. Since there
is insufficient data at this time to determine whether full restoration is practicable, EPA's
objectives for this interim remedy are focused on removing the source, minimizing further
migration of contaminants, and preventing exposure.
Further work is underway to finish characterizing the nature and extent of contamination in the
aquifer and to develop and evaluate a set of alternatives to restore the groundwater to its
beneficial use as a drinking water aquifer. Once this investigation is completed. EPA will issue a
final ROD for groundwater identifying the final cleanup goals for groundwater at the Site.
EPA agrees that strong efforts should be made to hasten the pace of remedy design and
implementation, while meeting EPA's obligations under CERCLA and the NCP. The
investigations at the Site have been ongoing for a very long time, with little progress in the actual
cleanup. While PDIs are needed to refine the details of the selected remedy, EPA expects these
investigations to be focused and implemented expeditiously such that active cleanup is initiated
as soon as possible. The dynamic of work at the Site must shift such that the PDIs do not become
another long-term phase of the investigation.
Please see also EPA's responses to Comments #1, #14, and #16 in Section B, above, and
Comment #1 in Section C, I, above.
Comment #6 (C. Baima, S. Baima)
Institutional Controls should not be relied upon (such as for TMPs) when remediation is an option.
EPA Response:
Please see EPA's responses to Comments #20 and #30 in Section C, II, above.
Comment #7 (C. Baima, J. Baima, S. Baima)
The goal for groundwater should be to restore the aquifer to drinking water conditions.
EPA Response:
Please see EPA's responses to Comments #1 and #14 in Section B, above.
Comment #8 (L. Brooks)
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Will Transrail be allowed on Olin's property to begin construction for operation? If land is disrupted
before cleanup is complete, contamination may spread further.
EPA Response:
Please see EPA's responses to Comments #2 and #17 in Section B, above and Comment #2 in
Section C, IV, above.
Comment #9 (S. Baima)
The PRPs should have no influence over the selection of a final remedy.
EPA Response:
Please see EPA's response to Comment #19 in Section B, above.
Comment #10 (S. Baima)
Alternative DAPL/GWHS-4 is preferable to DAPL/GWHS-3 because it removes more surface material.
The temporary environmental impact of the installation of more wells is an acceptable price to pay for
additional wells.
EPA Response:
Please see EPA's responses to Comment #3 in Section B, above and Comments #22, #24, #25,
and #26 in Section C, II, above.
Comment #11 (S. Baima)
The PRGs for LNAPL and surface water appear to be using a mix of averages and "not to exceed" limits
for ammonia and chromium. How is it appropriate to compare an average value to a "not to exceed" limit
when you could fail the limit with high individual readings?
EPA Response:
The Proposed Plan contained performance standards for chromium and ammonia in surface water
developed in accordance with EPA Guidance for Aquatic Life Ambient Water Quality Criterion -
Freshwater (USEPA, 2013) to establish the Criterion Continuous Concentration (CCC). The
CCC is a value below which adverse effects would not be expected for the majority of aquatic
receptors. The site-specific chromium CCC of 0.10 mg/L was documented in Table 3.12-3 of the
BERA. This concentration, for dissolved chromium, was calculated using EPA equations for
deriving hardness-dependent criteria using the arithmetic mean of surface water hardness for the
South Ditch Stream (177 mg/L Calcium Carbonate [CaCO3]). Using an arithmetic mean for
determining hardness is an appropriate approach for addressing the variability in this parameter
and consistent with guidance.
The site-specific ammonia CCC was calculated based on site-specific surface water temperature
and pH data consistent with Table N-l in Appendix N of Aquatic Life Ambient Water Quality
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Criteria for Ammonia -Freshwater (USEPA, 2013). The Proposed Plan contained a performance
standard for ammonia in surface water of 15 mg/L based on an average temperature of 9.2°C and
a pH of 7.13. As noted in EPA's response to Comment #10 in Section B, above, EPA has re-
evaluated the performance standard for ammonia in surface water and believes that the
performance standard should be based on the 95% Upper Confidence Limit (UCL) of temperature
data from mid-May through June (18°C ) and has revised the performance standard in the ROD to
9 mg/L. Using the 95% UCL for temperature is an appropriate approach for addressing the
variability in this parameter and consistent with guidance.
It is important to note that the surface water performance standards arc instream levels, protective
of organisms over the long term (e.g., chronic conditions). To evaluate whether the remedy is
functioning as designed, surface water samples will be taken at different locations within the
stream and compared to these performance standards to evaluate the effectiveness of the remedy.
Exceedances of the performance standards at a particular location may result in modifications to
the remedy or may result in further evaluations including toxicity testing. In summary, the use of
statistical methods such as UCLs, averages, and arithmetic means for characterizing the
conditions of the stream (i.e., hardness, temperature, and pH) is an appropriate means to
determine the performance standards. Long term monitoring results will be compared to these
performance standards to determine if the remedy is functioning as designed and sufficiently-
protective.
Comment #12 (S. Baima)
The USACE water quality certification allows for wetland intrusion only if that intrusion is temporary
and for remediation activities. While remediation activities will impact wetland areas, some impacts may
be necessary to remove contaminants. The wetlands should be restored to the greatest extent possible.
EPA Response:
EPA agrees with the substance of this comment. Restoration of wetlands impacted by remedial
activities is included in the selected remedy. EPA will minimize potential harm and avoid
adverse impacts to wetlands, to the extent practicable, by using best management practices to
minimize harmful impacts on wetlands, wildlife, or habitat. Any wetlands affected by remedial
work will be restored and/or replicated consistent with the requirements of federal and state
wetlands protection laws with native wetland vegetation, and any restoration efforts will be
monitored. Mitigation measures will be used to protect wildlife and aquatic life during
remediation, as necessary. Please see also EPA's response to Comment #8 in Section C, II,
above.
V. Written comments submitted by WWI LLC on October 26. 2020
Comment #1
How does the fact that additional sampling is anticipated affect the proposed cap for the Containment
Area? Does EPA anticipate that additional investigation and remediation will affect the design and
installation of the permanent cap? Will the cap be installed after the data gap investigation is complete?
EPA Response:
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Additional investigation and remediation arc not expected to significantly change the plan for the
cap. The data gap investigation in the area of the Containment Area is anticipated to be
completed prior to final cap design and installation.
Comment #2
The removal of DA PL and highly contaminated groundwater is expected to take 8 years. Docs EPA
anticipate that the permanent cap would be installed after DAPL removal, or can DAPL removal proceed
with the permanent cap in place?
EPA Response:
The implementation sequence for the remedy will be defined during the design. However, EPA
anticipates that DAPL and hot spot groundwater extraction wells within the area of the
Containment Area cap will be installed before the permanent cap is constructed.
Comment #3
The cap over the Containment Area has not yet been designed. Would EPA consider a building, designed
to address potential vapor intrusion, as a component of that cap? If the building is not designed as part of
the cap, could the cap be designed and constructed to allow for a building to be installed in the future?
Note that this has occurred at other NPL sites. We can work with Olin on the specifics of integrating a
building into cap design but request clarification that such an approach would be acceptable.
EPA Response:
The cap over the Containment Area must be designed and constructed to meet ARARs,
specifically the performance requirements of RCRA Subtitle D criteria for solid waste landfills
and Massachusetts solid waste landfill regulations to minimize infiltration. It is possible that a
building could be designed and constructed to meet these requirements. It is also possible that the
permanent cap could be designed and constructed to allow the installation of a building above the
cap. If a building is constructed in this area, it must be constructed to ensure that vapor intrusion
issues are mitigated and that the structure does not interfere with all other aspects of the remedy,
including the extraction and monitoring of DAPL and groundwater.
Comment #4
The remedial plan for on-Site soil also includes some soil excavation and capping with either asphalt or
soil cover. It appears to that the selection of asphalt or soil is consistent with existing conditions, e.g.
replacing soil with soil, and asphalt with asphalt. The proposed redevelopment involves the construction
of a large warehouse building. Is EPA amenable to a "cap" consisting of a building, rather than asphalt or
soil?
EPA Response:
The upland soil on the Olin property (Property) pose an ecological risk to various species. To
mitigate these risks, EPA's remedy includes covering these soils with either clean soil or
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pavement to eliminate the exposure pathway for these species. Construction of a building over
those soils that pose a risk can also achieve the RAOs. However, the building would then
become a component of the remedy and as such, the design, construction, and long-term
maintenance would necessarily be conducted under the oversight and approval of EPA.
Comment #5
The Proposed Plan includes the collection and treatment of highly contaminated groundwater and product
and the construction of a new treatment building, shown as being located near Plant B. WWI suggests
that EPA consider locating the treatment building off-Property for the following reasons: the location
depicted in the Proposed Plan would require installation of piping through much of the developable area
of the Site and complicate future redevelopment, would require an increase distance to pipe contaminants
(increasing potential for release) and would cross at least one wetland. Instead, WWI suggests that the
treatment plant be located on 1 Jewel Drive.
EPA Response:
The location of the treatment plant in the Proposed Plan is conceptual and may be rev ised during
the design phase. EPA is amenable to an alternate treatment plant location as long as it meets
location-specific ARARs.
VI. Written comments submitted by MIT community/MIT Superfund Research
Program (J. Kav. K. Vandiver. J. Beard. B. Engelward, T. Swager) October 22-26.
2020
Comment #1 (MIT SRP)
We agree that continued quarterly monitoring of the 18 currently tested residential wells for nitrosamine
contamination is appropriate, but should be expanded to include other nitrosamines and contaminants
beyond NDMA only.
EPA Response:
It has been concluded over many years of collecting groundwater samples at the Site that NDMA
is both the most toxic and most mobile of all the target analytes and this chemical has been used
to define the extent of groundwater impacts at the Site. The available data shows NDMA to be
more widespread than any other nitrosamines that have been analyzed for at the Site; addressing
the major sources of NDMA to the aquifer - DAPL and groundwater hot spots - will result in
addressing other nitrosamines that are present in environmental media. NDMA concentrations in
the currently tested private residential wells are orders of magnitude lower than concentrations in
DAPL and groundwater hot spots, and EPA expect these levels in residential wells to decline
even further upon implementation of the interim remedy for OU3.
The sampling effort for private wells under the Superfund program was initiated in October 2009
and has evolved over time. Initial samples were analyzed quarterly for the target analytical list as
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required by the Final RI/FS Work Plan (MACTEC, 2009).29 The initial analyte list included 74
semi-volatile organic compounds (SVOCs), inorganics (ammonia, sulfate, chloride, nitrate, and
nitrite), metals (sodium, chromium, and hexavalent chromium), NDMA, and n-
nitrosodipropylamine (NDPrA). NDPrA detections were reported with NDMA as per EPA
drinking water Method 521. Over time, the list of target analytes was narrowed based on ongoing
results. SVOC analyses were discontinued for multiple wells due to a lack of detections.
Other nitrosamine compounds besides NDMA were sampled in known impacted wells GW-10S
and GW-10D and there were no detections above EPA Regional Screening Levels (RSLs), which
are conservative risk-based values. These wells are located on the Olin property (Property) in
close proximity to the Jewel Drive DAPL pool. Given their location near an area of elev ated
NDMA concentrations in groundwater, these wells would be likely to exhibit concentrations of
other nitrosamines, if present. Samples from these wells were analyzed for n-nitrosodi-n-
butylamine (NDBA), NDPrA, n-nitrosodiethylamine (NDEA), NDMA, n-
nitrosomethylcythylamine (NMEA), n-nitrosopiperidine (NP1P), and n-nitrosopyrrolidine
(NPYR). For GW-10S, based on reporting limits ranging from 1.9 ng/L to 4.8 ng/L, the
laboratory did not report any positive detections of these compounds. For GW-10D, the
laboratory reported low, estimated (J-flagged) detections of NDBA (4.9 ng/L (J)) and NMEA (0.5
ng/L (J)), along with an NDMA concentration of 220 ng/L (J). A comparison of the estimated
detections of NDBA and NMEA to the EPA RSLs did not indicate unacceptable human health
risks.
In summary, the results support the conclusion that NDMA is the predominant compound of
concern among the Method 521 analyte list as it was detected at the highest concentration and has
the lowest tapwater RSL. Based on the results, EPA did not require Olin to conduct further
groundwater sampling and analysis in the residential monitoring program for NDPrA, NDEA,
NMEA, NPYR, NPIP, or NDBA. In addition, during design of the remedy and implementation
of the data gaps work, EPA will continue to evaluate the nature and extent of all nitrosamines at
the Site. For example, it will be important to evaluate and confirm that treatment systems arc
adequately addressing the full list of nitrosamines. Confirmation sampling from certain select
wells and the influent and effluent from the treatment systems will be implemented to confirm
our conclusions thus far.
Comment #2 (MIT SRP)
It is extremely important to characterize the full chemical composition of DAPL in order to understand
health risks to the community.
EPA Response:
EPA believes that sufficient characterization of DAPL has occurred to understand the health risks
to the community. While conductiv ity is often used as a primary indicator or screening tool,
DAPL has been analyzed for a broad spectrum of contaminants and characteristics as listed in
Table 3.1-1 of the Final RI/FS Work Plan (MACTEC, 2009), including VOCs, SVOCs including
29 See MACTEC, 2009. Field Sampling Plan, Volume III-A, Table 3.1-1.
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the nitrosamines NOMA, NDPrA, and NDPhA, total and dissolved metals, alkalinity, anions,
ammonia, phthalic acid/phthalic anhydride, specific conductance, specific gravity, total organic
carbon, and specialty compounds including 1,1 -dimethylhydrazine, acetaldehyde, formaldehyde,
Kempore, methylhydrazine, Opex, and perchlorate. The most recent RI report summarizing these
results is the June 2019 Draft OU3 RI Report (Wood, 2019). Please see also EPA's response to
Comment #1 in Section C, VI, above.
In addition, DAPL chemistry has been evaluated in technical bulletins and articles, including the
following:
• Eary, L. E. and Davis, A., 2007. Geochemistry of an acidic chromium sulfate plume.
Applied Geochemistry 22, 357-369.
• Gcomega, 1999. Technical Series 3: Results of August 1998 multilevel piezometer
samping event and DAPL/diffuse layer discrimination analysis. January 8.
• Geomega, 2004. Technical Series 37: Conclusion of the laboratory column test
simulating aquifer pumping for DAPL removal. December 28.
Table 1.1 of the Focused RI Report DAPL (AMEC, 2017) identifies the 33 monitoring wells
and multi-port piezometers screened in DAPL; Table 4.1 summarizes all the chemical analyses
that were conducted for each of those groundwater monitoring wells and multi-level piezometer
ports. Tables 4.2-1,4.2-2, and 4.2-3 include all of the analytical data for organics (including
NDMA and NDPhA), inorganics, and non-standard analytes (including hydrazine, unsymmetrical
dimethylhydrazine (UDMH), monomethylhydrazine (MMH), formaldehyde, dimethylformamide,
acetaldehyde, Opex, and Kempore). Table 2.3-8 of the Draft Baseline Human Health Risk
Assessment for OU3 (Draft 2019 OU3 BHHRA) - Attachment K of the June 2019 Draft OU3 RI
Report (Wood, 2019) - summarizes analytical data for compounds detected at least once among
samples collected from DAPL monitoring wells sampled between May 2010 and June 2016; the
table includes full-suite analyses of DAPL samples including organics (VOCs and SVOCs,
including NDMA, NDPrA, and NDPhA), volatile petroleum hydrocarbons (VPH), metals,
inorganics, and specialty compounds (including hydrazine, UDMH, MMH, formaldehyde,
dimethylformamide, acetaldehyde, Opex, and Kempore). The current data set indicates that
NDMA is the predominant nitrosamine compound in DAPL. In addition, as noted in the previous
response, during design of the remedy and implementation of the data gaps work, EPA will
continue to evaluate the nature and extent of all nitrosamines at the Site.
Comment #3 (MIT SRP)
MIT is concerned regarding the proposed method of "pump and treat" for DAPL. Historically, pump-
and-treat is ineffective because the entire mass cannot be treated simultaneously and turnover rates are
extremely slow relative to the size and dynamics of the plume. Even if treated effectively, upon
reinjection it returns to the plume and facilitates plume migration, and may still contain precursors that
may re-form hazardous materials. For example, pump and treat of trichloroethenc (TCE) on Cape Cod
has not reduced contamination.
EPA Response:
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The extraction and treatment method planned for DAPL has several major differences with
traditional groundwater pump-and-treat, as described below.
• The DAPL targeted by the selected remedy has collected in bedrock depressions over
time and is isolated from most groundwater advective flow. While EPA remains
concerned that some of the DAPL has migrated over time via bedrock fractures, the
targeted DAPL mass is not migrating measurably.
• There are no plans to reinject treated DAPL directly to the source area. If reinjection is
contemplated in the future, further studies will be conducted to evaluate the feasibility of
this action. Studies will be conducted to evaluate and optimize the on-site treatment of
DAPL prior to off-site disposal of the residuals. The goal will be to pre-treat the
extracted DAPL to reduce its volume as much as possible, thus reducing the volume of
residuals requiring off-site disposal. There will be two waste streams from the treatment,
a solid waste stream which will be containerized and then disposed of off-site and a
liquid waste stream which will be evaporated. If it is not feasible to treat DAPL on-site,
extracted DAPL will be disposed of off-site at a permitted facility licensed to receive
such wastes.
• The planned extraction is designed to minimize mixing of DAPL and overlying
groundwater. The proposed DAPL extraction rates are very low to match the rate of
gravity flow, and the extraction screens will be placed at the top of bedrock to capture as
much DAPL as possible and minimize cntrainment of overlying groundwater. EPA has
also selected a remedy for DAPL that includes a larger number of extraction wells in
order to reduce the pumping rate at any given extraction point but still allow for
extraction to proceed at a reasonable pace.
It is also important to note that Olin conducted a pilot test to evaluate extraction rates for DAPL
that allow for removal of DAPL while minimizing the mixing of the overlying groundwater.
Approximately one million gallons of DAPL have been successfully removed from the Jewel
Drive DAPL pool to date.
With respect to the use of pump-and-treat technologies utilized to address TCE contamination on
Cape Cod, EPA disagrees with the commenteds conclusion. Significant plume reduction and
aquifer restoration has been achieved on Cape Cod using pump-and-treat technologies.
Reinjection of the treated groundwater also helped contain the plumes as the reinjection was
designed to create hydrologic highs that served to funnel the contaminated groundwater towards
the extraction wells. A review of the historical extent of contamination compared to current
extent showed dramatic decreases in the nature and extent.
Comment #4 (MIT SRP)
The proposed final actions for LNAPL and soil/sediment are not satisfactory. MIT is concerned about the
efficacy of pumping and treatment for LNAPL. Considering the history of chemical disposal, NDMA
precursors and other chemicals are likely present in the LNAPL and soil/sediment, and more aggressive
assessment and response is needed. Olin manufactured nitrosamine products, such as NDPhA (Wiltrol N)
and Opex, which may be less mobile in the environment than NDMA due to soil sorption, necessitating
more aggressive soil remediation. The acidity of the Site's waste, combined with these nitrosamines, may
create conditions favoring ongoing formation of more mobile nitrosamines such as NDMA that could
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continue to leach to groundwater. In addition, numerous nitrosamine precursors or materials known to
create nitrosamine-forming conditions are known or highly likely to be present in LNAPL and
soil/sediment, including hydrazines, raw material for Nitropore 5PT, and aqueous ammonia and chlorine.
EPA Response:
EPA believes that adequate site characterization has occurred to develop sets of alternatives to
address LNAPL contamination and contamination in soil and sediments, and believes that the
selected remedies for LNAPL and soil and sediment contamination are appropriate. EPA
acknowledges that the LNAPL process oil was known to contain NDPhA as well as other
constituents, however, NDPhA was not detected in surface soil or shallow subsurface soil at Plant
A/C-l or the Plant D Tank Farm where most of the hydrazine detections in soil were located; the
hydrazine and NDPhA detections in soil are not co-located and therefore would not have the
opportunity to react together. In addition, EPA is not of the opinion that there are currently acidic
conditions in soil (a requisite for nitrosation) where the hydrazine has been detected (see below
for further discussion of acidic conditions). Given the relatively small volume of LNAPL and its
limited aerial extent, EPA does not believe the LNAPL is a significant source of groundwater
contamination as compared to DAPL.
EPA notes that more than 400 soil samples were collected for nitrosamines (MDMA, NDPrA, and
NDPhA), ammonia, chloride, and sulfate analysis. In addition, approximately 200 soil samples
were collected and analyzed for 1,1 -dimethylhydrazine, acetaldehyde, dimethylformamide,
formaldehyde, hydrazine, and methylhydrazine. The LNAPL, soil, and sediment data indicate
that NDMA precursors arc not present at most sample locations, and where present, arc at low
concentrations and without the acidic conditions that would be needed to sustain reactions and
create additional nitrosamines.
The acidic waste on the Olin property (Property) was in the liquid waste streams that were
discharged to unlined lagoons and pits (including the one referred to as "Lake Poly") from 1953
to around 1970. These disposal areas are distinct from the LNAPL/Plant B area and range from
more than 300 feet to more than 1,000 feet to the southwest. That waste stream ultimately
resulted in the formation of DAPL. Lake Poly soil was excavated to bedrock and disposed of off-
site. There is no corollary acidic waste distributed within soils on the Property where NDPhA is
found. EPA does not believe that the conditions that previously existed in the chemical
manufacturing processes and the discharges of associated liquid wastes currently exist in soil,
sediments, or the LNAPL area at the Property.
Please see also EPA's response to Comment #10 in Section C, III above for a discussion of
LNAPL excavation and EPA's responses to Comment #8 in Section B, Comment #14 in Section
C, II, and Comment #1 in Section C, IV, above, for a discussion of removal of impacted soils.
Comment #5 (MIT SRP/recommendation letter)
Because the slurry wall was not installed to bedrock and leaves opportunity for fluid transport, ongoing
NDMA production will continue to contaminate the groundwater of Wilmington unless chemical sources
(hydrazines, aqueous ammonia and chlorine) are removed and an effective barrier constructed.
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Containment walls should be installed that extend to bedrock and a permanent, secure, impermeable cap
should be installed.
EPA Response:
The slurry wall of the Containment Area feature was constructed to bedrock; however, EPA
believes there may be some degree of groundwater leakage at the interface between the slurry
wall and bedrock surface because the slurry wall was not keyed or grouted into the bedrock
during construction. The open equalization window may also contribute to the inability of the
current Containment Area design to adequately contain Site contaminants. EPA's selected
interim remedy for DAPL and hot spot groundwater includes extraction wells both inside and
outside of the slurry wall to remove these liquid sources of contamination and reduce the
potential for ongoing NOMA production instead of trying to contain them with physical barriers.
The addition of a permanent, low-permeability cap and closure of the equalization window will
also address the threat of future leaching of Site contaminants associated with the soils and solid
waste within the Containment Area. EPA has concluded that these two components of the
remedy in this area (extraction for liquid waste and capping for solid waste) will provide adequate
source control for the Containment Area. Please sec also EPA's responses to Comment #5 in
Section B, Comment #32 in Section C, II, and Comment #4 in Section C, III, above.
Comment #6 (MIT SRP/J.Beard/N. Owiti/S. Kaushal)
N-nitrosamines, a class comprising hundreds of chemicals, are among the most potent carcinogens
known. Over 70 n-nitrosamines have been documented to cause cancer in animals, and most are not
currently tested for at the Olin Site. For example, n-nitrosodiethylamine (NDEA) is even more toxic and
carcinogenic than NDMA, and given its structural similarity, it is almost certainly present, but does not
appear to have been routinely measured.
Given the known contamination of the Site with additional nitrosamines and potential for even more toxic
nitrosamines, it is important to take measures to identify, monitor and remediate other nitrosamines and
potential carcinogens in DAPL, LNAPL, and groundwater.
EPA Response:
It has been concluded over many years of collecting groundwater samples at the Site that NDMA
is both the most toxic and most mobile of all the target analytes and this chemical has been used
to define the extent of groundwater impacts at the Site. As noted previously, prior investigations
carefully evaluated whether other nitrosamines were present at levels that posed a risk.
Specifically, two key monitoring wells known to be representative of known source areas were
sampled in 2012 and analyzed for the nitrosamines NDBA, NDPrA, NDEA, NDMA, NMEA,
NPIP, and NPYR (see discussion in Comment #1 in Section C, VI, above). NDEA was not
detected in either of the wells at a reporting limit of 1.9 ng/L while NDMA concentrations ranged
up to 4,600 ng/L in these two wells from 2011 to 2019. Based on these evaluations, EPA has
concluded that NDEA is not a contaminant of concern at the Site. However, EPA will continue
to evaluate this issue as part of the remedial design for the remedy to ensure that the groundwater
treatment is sufficient to address all nitrosamines. For example, during pre-design activities key
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monitoring wells can be sampled for verification of key contaminants. In addition, the treatment
system influent and effluent will be analyzed for a full suite of contaminants including all
nitrosamines to confirm sufficient treatment prior to discharge to surface water. Please see also
EPA's response to Comment #3 in Section C, VI, above.
Comment #7 (MIT SRP)
N-nitrosodiphenylamine (NDPhA), which was manufactured at the Site and has been found in Olin
LNAPL and groundwater, is a substantial concern. NDPhA is an EPA class B2 probable carcinogen and
is a precursor for NDMA. Given the relative thermal instability and low volatility of NDPhA, gas
chromatography/mass spectrometry (GC/MS) analysis of this chemical is problematic and thus results of
analysis likely underestimates the true level of contamination. Even so, NDPhA has been detected at
unacceptably high levels.
EPA Response:
EPA believes that the range of possible nitrosamines has been adequately characterized. NDMA
has been identified as the predominant nitrosamine compound in env ironmental media at the Site,
and the data from the Site investigation and monitoring efforts demonstrates that NDMA is the
most significant human health risk contributor. Please see also EPA's responses to Comments #1
and #6 in Section C, VI, above. NDPhA has exceeded the tapwater RSL of 12 ug/L on the Olin
Property in shallow overburden groundwater near Plant B and in deep overburden groundwater
north of the on-property DAPL pool, with a maximum concentration of 400 ug/L (GW-16R,
November 2009). These exceedances are limited to small areas on the Olin Property.
Although EPA believes that adequate characterization for nitrosamines has occurred, EPA will
evaluate the use of other analytical methods such as liquid chromatography with tandem mass
spectrometry (LC/MS) for analysis of groundwater samples collected as part of the planned
remedial design and data gap investigation to eliminate potential degradation concerns from
GC/MS. Limited sampling is planned during design to ensure that the treatment components
adequately address all possible contaminants.
Comment #8 (MIT recommendation letter)
Ongoing nitrosamine formation and nitrosamine levels over time should be monitored. The MIT SRP
team is developing a rapid NDMA sensor and offers to test NDMA concentrations in and around the Olin
Site, and also request access to water samples. Likewise, the MIT SRP team is developing analytical
approaches to detect and identify multiple nitrosamines and requests surface water and groundwater
samples for analysis.
EPA Response:
The Site is routinely monitored for NDMA concentrations using EPA-approved methods. The
data collected does not show evidence of ongoing nitrosamine formation. EPA is aware that MIT
is developing an NDMA rapid sensor and has suggested that MIT work with Olin on a proposal
to test this sensor using samples collected at the Site and validated by other approved methods.
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Comment #9 (MIT recommendation letter)
EPA should communicate the intended fate of treated, excavated or otherwise removed contamination.
Note that contaminants should not be transferred to another site that risks human exposure.
EPA Response:
The selected remedy involves extracting and treating the groundwater. Currently, the plan is to
discharge the treated groundwater to surface water. Prior to discharge, the water must meet
performance standards that are safe for human health and the environment. In the event it is
determined that it is beneficial to reinject the groundwater. EPA will establish injection standards
protective of this discharge option. The selected remedy also includes extracting and treating
DAPL. The proposed treatment process for DAPL will result in a solid waste that must be
disposed of off-site. The treatment also involves evaporation of any wastewater. Any solid or
sludge generated from the treatment of DAPL and groundwater and any contaminated sediments
excavated from the wetlands will be taken off-site to a disposal facility that has been approved to
accept CERCLA waste. EPA will review and approve all disposal facilities used for wastes from
the Site to ensure that they are in compliance with the regulations governing their continued
operation.
Comment #10 (MIT recommendation letter)
A critical evaluation should be performed for pump and treat of LNAPL to ensure that evidence of
efficacy is established and treated waste is tested for remaining contaminants and nitrosamine precursors
before re-release to the environment. Treated water should also be treated for nitrosamines other than
NDMA and NDPhA prior to discharge.
EPA Response:
MPE is a proven technology for the extraction and treatment of LNAPL. The selected remedy-
also requires monitoring of the discharge from the treatment system to demonstrate it achieves
levels protective of surface water and sediments prior to discharge. Please see also EPA's
response to Comment #3 in Section C, VI, above.
Comment #11 (MIT recommendation letter)
If nitrosamine concentrations do not decrease significantly, alternative remediation methods should be
identified and applied.
EPA Response:
The selected remedy includes long-term monitoring of contaminants in the aquifer to demonstrate
that the remedy is functioning as it was designed. As part of this monitoring, contaminant trends
will be evaluated and if progress is not demonstrated, other actions will be evaluated and
implemented as part of the final remedy selected for groundwater (OU3). Furthermore, as part of
the selected remedy. Five Year Reviews will be required for as long as contamination remains in
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place at concentrations above unrestricted use, and these reviews will evaluate how well the
remedy is performing.
Comment #12 (A. Moise)
Longitudinal studies should be conducted to track changes in concentration of NDMA. NDMA
precursors, and other chemicals in LNAPL, DAPL, and soil as remediation progresses.
EPA Response:
The selected remedy includes monitoring of all aspects of the remedy, including groundwater,
surface water, soil, and sediments to demonstrate remediation progress and whether the cleanup
levels and performance standards have been achieved. Pre-design studies will evaluate the
presence and impact of NDMA precursors on the remedy and if further monitoring is needed over
time. Please see also EPA's response to Comment #11 in Section C, VI, above.
Comment #13 (H. Feng)
Further investigations should be conducted to understand the impact of contaminant migration via
bedrock fractures, especially since prior activities have not involved removal of contamination from
fractures.
EPA Response:
EPA agrees. Contaminant migration in bedrock has been identified as a data gap for the Site, and
additional characterization activities to identify bedrock fractures and the potential impact of
contaminated groundwater and DAPL in bedrock fractures and within the bedrock matrix arc
planned as part of the ongoing data gap work, which will lead to the final ROD for groundwater
(OU3).
Comment #14 (H. Feng)
Did the DAPL pilot program include studies on how the act of extraction may impact contaminant
migration in the surrounding areas? When the municipal wells were in operation, they resulted in upward
migration of contaminants.
EPA Response:
The DAPL pilot program was intended to determine the feasibility of DAPL extraction and a
sustainable extraction rate for DAPL, and associated monitoring evaluated the potential for
entrainment of groundwater into the DAPL pool. The pilot test demonstrated that extraction rates
around 0.25 gallons per minute (gpm) were sustainable in the Jewel Drive DAPL pool and would
not result in excessive mixing of groundwater and DAPL and fouling in the extraction wells. The
total combined extraction rate from all 20 DAPL extraction wells is estimated at 8 gpm or 11,520
gallons per day. Given the low extraction rates determined to be sustainable to prevent mixing,
minimal impact is expected on groundwater flow above the DAPL pools. In contrast, the
municipal wells were located on the far side of the MMB wetlands and pumped a significant
Record of Decision
Olin Chemical Superfund Site
Wilmington, Massachusetts
March 2021
Page 191 of 193
-------
volume of groundwater (combined flow rate of more than 5 million gallons per day when all six
Town wells were in operation). The CSM for the Site suggests that Town wells had a strong
influence on the migration of contamination from the Site, pulling the contamination plume in
from both below the wells and from across the aquifer.
Comment #15 (J. Beard)
The Proposed Plan states that NDMA will be destroyed with "ultra-violet (UV) photo-oxidation" and it is
unclear if this is UV irradiation or if the intent is to pair UV light with the addition of an oxidant. If the
latter is correct, it has been shown that UV/'O? can reduce the formation of the secondary amine during
photolysis, somewhat mitigating re-formation of nitrosamines.
EPA Response:
The selected remedy includes the use of UV photo-oxidation to treat NDMA in groundwater and
DAPL. The details of the technology will be developed further during design to ensure that the
performance goals can be achieved, and the suggestion in the comment will be taken into
consideration.
Comment #16 (J. Kelly)
The transport of contaminants through different media is highly uncertain and difficult to predict,
therefore, contaminants have the potential to migrate into the air both outside and in peoples" homes.
Both indoor and outdoor air should be monitored for contaminants as well as their degradation products.
EPA Response:
Most of the contaminants found at the Site do not have the potential to migrate into air under
ambient conditions at levels that pose an unacceptable risk. TMPs were detected on the 01 in
property-portion of the Site and the selected remedy for this area includes further evaluation of
vapor intrusion impacts or the use of vapor mitigation systems if buildings were to be constructed
in this area. Beyond this area, no other air impacts are anticipated. In addition, routine air
sampling is conducted as part of the normal health and safety procedures during implementation
of the remedy when there is a risk (usually due to the nature of the contaminants ) that a release to
the ambient air is possible. Such routine monitoring will be implemented when work proceeds at
the Site.
Comment #17 (J. Kelly)
Environmental monitoring of contaminants should be expanded to also include degradation products.
EPA Response:
The investigations at the Site have included monitoring and analysis of numerous contaminants,
and where appropriate, degradation products have been included in the analysis. The commenter
did not provide further information on which contaminants and degradation products they believe
have been omitted from our analysis and why further analysis of these contaminants arc needed.
Record of Decision
Olin Chemical Superfund Site
Wilmington, Massachusetts
March 2021
Page 192 of 193
-------
Therefore, further response cannot be provided. Please see also EPA's responses to Comments
#1 and #6 in Section C, VI, above.
Comment #18 (S. Kaushal)
Genetic variability profoundly impacts the biological consequences of N DM A exposure. The in vivo
studies that form the basis for federal NDMA health hazard assessment were performed in wild type
animals, but humans are known to vary widely in their capacity for repairing N DMA-induced DNA
damage, so existing risk assessments do not account for highly susceptible populations.
EPA Response:
The EPA human health risk assessment process does account for sensitive subpopulations in both
the development of toxicity values and through exposure assessment, which characterizes the
magnitude of exposure to a receptor. The toxicity values for NDMA have undergone an
extensive review process and arc suitable for risk assessment purposes. Additionally, the
methodologies for developing the toxicity values do take into account uncertainty from
extrapolating from animal models to humans. Another way the risk assessment process accounts
for sensitive populations is in the exposure assessment phase. Sensitive receptors including
children were evaluated as part of the risk assessment. Exposure parameters were selected to
represent what is considered the reasonable maximum exposure, or the maximum exposure that is
reasonably expected to occur at a site. This approach follows the EPA Risk Assessment
Guidance for Superfund'0 and ensures that potential impacts to sensitive populations are captured
by the human health risk assessment.
30 EPA Risk Assessment Guidance for Superfund, Part A.
Record of Decision
Olin Chemical Superfund Site
Wilmington, Massachusetts
March 2021
Page 193 of 193
-------
Appendices
Appendix A: MassDEP Letter of Concurrence
Appendix B: Tables
Appendix C: Figures
Appendix D: ARARs Tables
Appendix E: References
Appendix F: Acronyms and Abbreviations
Appendix G: Administrative Record Index and Guidance Documents
Record of Decision
Olin Chemical Superfund Site
Wilmington, Massachusetts
Appendices
March 2021
-------
Appendix A
Massachusetts Department of Environmental Protection
Letter of Concurrence
Record of Decision
Olin Chemical Superfund Site
Wilmington, Massachusetts
Appendix A
March 2021
-------
Commonwealth of Massachusetts
Executive Office of Energy & Environmental Affairs
Department of Environmental Protection
One Winter Street Boston, MA 02108 »B17-292-5500
Charles D. Baker Kathleen A. Theoharides
Governor Secretary
Karyn E. Polito Martin Suuberg
Lieutenant Governor Commissioner
March 25, 2021
Mr. Robert Cianciarulo
Office of Site Remediation and Restoration
U.S. Environmental Protection Agency, Region 1
5 Post Office Square
Boston, MA 02109
Re: State Concurrence Determination
Record of Decision OU1, OU2, Interim OU3- Olin Chemical Superfund Site
Wilmington, Massachusetts
Dear Mr. Cianciarulo:
The Department of Environmental Protection ("the Department") has reviewed the Operable
Unit ("OU')l, OU2, and Interim OU3 Record of Decision ("ROD") for Olin Chemical
Superfund Site ("Site") in Wilmington, Massachusetts dated March 2021. OU1 consists of soil,
sediments, and surface water on the Olin Property ("Property"); OU2 consists of soil, surface
water, and sediment areas on and off Property. OU3 consists of all groundwater, both on- and
off-Property, and soil located below the water table. See attached figures for details. For the
reasons described below, MassDEP concurs with the remedy selected in the ROD ("Selected
Remedy").
The Selected Remedy includes;
• an interim action to begin restoration of groundwater and to prevent unacceptable risks
from exposure to Site groundwater while gathering additional information to select a final
cleanup plan for groundwater (OU3); and
• a final action to address all current and potential future risks caused by contaminated soil,
sediments, and surface water, Light Non-Aqueous Phase Liquid (LNAPL), and the
subsurface-to-indoor air vapor intrusion (VI) pathway (OU1 and OU2).
The major components of the Selected Remedy include;
• groundwater extraction and treatment;
• multi-phase extraction (MPE) to remove LNAPL;
This information is available in alternate format. Contact Michelle Waters-Ekanem, Director of Diversity/Civil Rights at 617-292-5751.
TTY# MassRelay Service 1-800-439-2370
MassDEP Website: www.mass.gov/dep
Printed on Recycled Paper
-------
MassDEP Concurrence Letter- OU1, OI.J2 & Interim OU3 ROD - Olin Chemical Superfund Site
• oil/water separation;
• treatment of soil vapor using granular activated carbon (GAC);
• installation of caps and cover systems;
• soil excavation and off-site disposal;
• continued groundwater studies to close remaining data gaps and evaluate long-term
groundwater cleanup options;
• long-term operation and maintenance of new and existing remedy infrastructure
components;
• long-term groundwater and surface water monitoring;
• removal of Dense Aqueous Phase Liquid ("DAPL") from the aquifer;
• removal of contaminated soil and sediments from on- and off-Property wetlands and
restoration of the wetland areas;
• removal of LNAPL and associated contaminated soil vapor from the Property;
• prevention of indoor air exposures via the VI pathway; and
• restoration of the Property to allow for beneficial re-use.
The Selected Remedy includes Institutional Controls ("ICs"). ICs will require VI evaluations
and/or mitigation measures such as vapor barriers or sub-slab depressurization systems (SSDSs),
which are intended to preserve the remedy and ensure that any impacted soil and groundwater
encountered during future intrusive activities (e.g., installing subsurface utilities and/or building
foundations/slabs) are appropriately managed to protect human health. ICs have been selected to
maintain caps and cover systems, prevent residential, school, and daycare use of the Property,
and prohibit use of groundwater in the OU3 groundwater study area unless it can be
demonstrated to EPA, in consultation with the Department, that such use will not pose an
unacceptable risk to human health and the environment, cause further migration of the
groundwater contaminant plume, or interfere with the remedy. Periodic Five-Year Reviews by
EPA are also required to assess protectiveness.
The specific remedial measures selected in this ROD are described in detail in Attachment A to
this letter.
If you have any questions regarding this letter, please contact Mr. Garry Waldeck, Project
Manager at (617) 348-4017.
Assistant Commissioner
Bureau of Waste Site Cleanup
Department of Environmental Protection
Copies to:
Lynne Jennings, USEPA
2
-------
MassDEP Concurrence Letter- OU1, OI.J2 & Interim OU3 ROD - Olin Chemical Superfund Site
ATTACHMENT A
Remedial Measures selected in March 2021 Olin Chemical ROD
Interim Action OU3 - DAPL and Groundwater Hot Spots (GWHS)
EPA's selected remedy for the interim action for DAPL and Groundwater Hot Spots is DAPL
extraction (approx. 20 wells), groundwater hot spot extraction targeting the 5,000
nanograms/Liter (ng/L) n-nitrosodimethylamine (NDMA) contour (approx. 6 wells), and
treatment at a new treatment system or systems, which include the following components:
• Construction and operation of a DAPL extraction system (conceptualized with
approximately four wells in the Off-Property Jewel Drive DAPL pool, approximately
four wells in the Containment Area DAPL pool, and approximately 12 wells in the Main
Street DAPL pool), with the final number and location of wells based on pre-design
investigations (PDIs);
• Construction and operation of a groundwater extraction and treatment system
(conceptualized with approximately six wells targeting the 5,000 ng/L NDMA contour),
the final number and location of which will be based on PDIs, to remove and treat the
mass of contaminants in groundwater hot spots; and
• Treatment of extracted DAPL and hot spot groundwater in a new treatment system or
systems generally consisting of the following methodologies:
o Treatment for DAPL:
¦ Lime precipitation to remove metals, with subsequent dewatering and off-
site disposal of the liquids and sludge materials;
¦ Evaporation of the remaining water and off-site disposal of the residual
solids; and
¦ Additional treatment as described for hot spot groundwater, below;
o Treatment for hot spot groundwater:
¦ Influent equalization tank;
¦ Hypochlorite flash mixer (a rapid mixer that uniformly distributes a
treatment chemical) for oxidation and removal of metals (iron and
manganese);
¦ Breakpoint chlorination to treat ammonia;
¦ Slow mix flocculation (a process by which fine particulates are caused to
clump together ) and lamella clarifier (a series of inclined plates on which
particulates can settle) to remove solids;
Attachment A - 1
-------
MassDEP Concurrence Letter- OU1, OI.J2 & Interim OU3 ROD - Olin Chemical Superfund Site
¦ Filter press for solids dewatering;
¦ Off-site disposal of residual solids and sludge materials;
¦ GAC to ensure clarity and ultra-violet (UV) transmittance, as well as
remove volatile organic compounds (VOCs);
¦ UV photo-oxidation for NDMA destruction; and
¦ Discharge of treated water.
Final Action QUI and OU2- LNAPL and Surface Water:
EPA's selected remedy for LNAPL and Surface Water is Demolition of Plant B, MPE for
LNAPL, targeted groundwater extraction to prevent impacts to surface water, and treatment at
new treatment system or systems, which include the following components:
• An estimated three to five MPE wells installed within the LNAPL footprint, including
beneath the Plant B building foundation, to remediate LNAPL, the smear zone, and
dissolved-phase Site contaminants that would otherwise impact East Ditch Stream;
• PDIs to determine the final number and location of MPE wells;
• Treatment of recovered LNAPL and soil vapor via a skid-mounted treatment system that
includes an oil/water separator to remove the LNAPL and vapor-phase GAC to treat the
soil vapor;
• Off-site disposal of recovered LNAPL at an appropriate off-site permitted facility;
• Construction and operation of a new groundwater extraction and treatment system(s),
with extraction wells sited based on PDIs to intercept and treat the overburden
groundwater contaminant plume that impacts Site surface water;
• Re-routing of groundwater currently treated by Plant B to the new groundwater treatment
system(s) (the same system(s) as for the hot spot groundwater); and
• Decommissioning and demolition of the Plant B groundwater treatment system.
Final Action QUI and OU2 - Soil and Sediments:
EPA's selected remedy for Soil and Sediments is Containment Area cap, upland soil covers,
excavation with off-site disposal and restoration of wetland soil and sediments, and limited
action for trimethylpentenes (TMPs) - Institutional Controls, including vapor intrusion
evaluations or vapor barriers/SSDSs, which include the following components:
• Placement of a permanent, low-permeability cap that meets Resource Conservation and
Recovery Act (RCRA) Subtitle D and Massachusetts solid waste management
performance standards over the Containment Area, the design and footprint of which will
be determined during the Remedial Design (RD) phase;
• Closure of the existing slurry wall equalization window by grouting in place;
• Placement of a soil or asphalt cover system over areas of shallow (0-1 foot [ft]) upland
soil with concentrations of Site contaminants in excess of the cleanup levels;
Attachment A - 2
-------
MassDEP Concurrence letter- Olil, OIJ2 & Interim OU3 ROD - Olin Chemical Superfund Site
• Excavation of wetland soil and sediments with concentrations of Site contaminants in
excess of the cleanup levels;
• Post-excavation confirmatory sampling to document limits of impacts and confirm
achievement of the Remedial Action Objectives (RAOs) and cleanup levels; and
• Off-site disposal of all excavated material at an appropriate off-site permitted facility.
Included with the three cleanup actions above are the following:
• PDIs and/or treatability studies during the RD process to:
o determine the final number, location, and configuration of extraction wells and
other remedial components;
o determine appropriate locations for discharge of treated groundwater to surface
water; and
o facilitate the implementation of the chosen cleanup alternatives and map the
precise extent of both excavation limits and the extent of caps and cover systems;
• Restoration with hydric (wetland-type) soil and native vegetation, as needed, of any
wetland habitat or floodplains altered by the remedial action, as well as restoration of any
excavated or otherwise altered areas with clean, imported backfill to grade and
revegetation with native vegetation to control erosion;
• Long-term maintenance and monitoring of any new and existing remedy infrastructure
components, including the Calcium Sulfate Landfill (CSL);
• Long-term monitoring of the groundwater plume and surface water, to evaluate remedy
effectiveness;
• Institutional Controls to 1) prohibit future residential use at the Property; 2) prohibit the
use of groundwater in the OU3 groundwater study area (for example, for potable,
irrigation, or industrial purposes) unless it can be demonstrated to EPA, in consultation
with the Commonwealth, that such use will not pose an unacceptable risk to human
health and the environment, cause further migration of the groundwater contaminant
plume, or interfere with the remedy; 3) prevent disturbance of any engineered systems
and any other new and existing remedy infrastructure components; 4) prevent contact
with soil beneath cover systems; and 5) require either a VI evaluation or vapor mitigation
system be installed if a new building is constructed or altered on the Property (examples
of Institutional Controls include Notice of Activity and Use Limitation (NAUL), Grant of
Environmental Restriction and Easement (GERE), 1 town ordinance, advisories, building
permit requirements, and other administrative controls); and
• Periodic Five Year Reviews to ensure the remedy remains protective.
1 NAULs and GEREs are approved forms of Massachusetts land use restrictions established under the
Massachusetts Contingency Plan (MCP).
Attachment A - 3
-------
MassDEP Concurrence Letter- OU1, OI.J2 & Interim OU3 ROD - Olin Chemical Superfund Site
In parallel to the selected remedy, the following activities will continue as part of the OU3
Rl/FS:
• Continued studies to close remaining data gaps, including an improved characterization
of bedrock topography and fractures and further delineation of the horizontal and vertical
extent of groundwater contamination; and
• Evaluation of long term groundwater cleanup options, leading to a selection of a final
cleanup plan for OU3
Attachment A - 4
-------
MassDEP Concurrence Letter- OU1, OU2 & Interim OU3 ROD - Olin Chemical Superfund Site
Butters Row.
Butters Row
Treatment Plant
Butters Row #2-
& TowrvPark
^ Butters Row #1,
Chestnut St #1A/2 &
Chestnut St #1
Maple Meadow
Brook Wetland
PanAM Railways
Main St
DAPL Pool
Plant.B.
MBTA'
Rail Line
^ Plant B]J
; Discharge'
jSanminaJ
' Property*
On:FJWD.^- -.
Off-Property I
West Ditch |
DAPL Pool
'^TfCcntai nment
I'// S^Area
On-Property I \
|pAPL Pool I \s9uth Ditch
/Y l^jonaervation
f Area"
CaTciumj
Sulfate]
Landfill '
Off;Property^
South^DitcK1
Town of VWmtngton
"City.of Woburn*
Wbburn
Landfill
North Pond
New Boston Street
Drainway
[South Pond
Legend
I I Aberjona River Watershed
I I Ipswich River Watershed ¦
^^Approximate DAPL Pool
¦ Operable Unit 1
^^51 Eames St.
Property Boundary
^ Town Wfrils
Town Line
Paved Road
Unpaved Road
Structures
Surface Water
—— Vtooded Areas
Wetland Boundary
*¦ Culvert
Area map. Shown are the major features of the Olin Site, watersheds, nearby surface waters, and the pools of Dense Aqueous-Phase Liquid
(DAPL). Site straddles two watersheds - the Ipswich River Watershed to the north (in blue) and the Aberjona River Watershed to the south
(in green).
Visible are the subsurface pools of DAPL (shown in green outline), located in depressions on the top of bedrock.
Figure - 1
-------
MassDEP Concurrence Letter- OU1, OU2 & Interim OU3 ROD - Olin Chemical Superfund Site
[EPH/VPH
\ vA
-------
MassDEP Concurrence Letter- OU1, OU2 & Interim OU3 ROD - Olin Chemical Superfund Site
Legsnd
|'AM* „ DAPL
Eamfts St Property Boundary
NOMA m Groundwater Approximate DAPL Pool Boundary
(RSL: 0.11 ng/1_>
¦ Dashed whew Intarad
J® Non-Detac*
N-Nitrosodimethylamine Concentrations
in Deep Overburden Groundwater
Figure - 3
-------
MassDEP Concurrence Letter- OU1, OU2 & Interim OU3 ROD - Olin Chemical Superfund Site
Letfeml
NDMA in Graunrtwator ConUi«nn»f>l Area
•{RSL.: 0 11 ogfl.) it si Earnes St Property Boundary
Oasfiod wtww tnt#tr«d Appro* DAPL Pool Boundary
N Mitrosodimethylamine Concentrations
in Shallow Overburden Groundwater
Figure - 4
-------
MassDEP Concurrence Letter- OU1, OU2 & Interim OU3 ROD - Olin Chemical Superfund Site
DA PL extraction (approx. 20 wells).
GW Hot Spot extraction targeting
5.000 ng/L NOMA (approx. 6 wells)
Olin Chemical Superfund Site
Wilmington, Massachusetts
Provide*# 6RP O~242o| Cl»cli*40al* 8KH 04-24-70
DAPL/GWHS Alternatives
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Aft 4: DAHeJcr/wtun (aoow. 20«m*i). GW Hot.Sgot wtfact»n targeting
>, 100 ng/l-MDMA (apptan. Uot'HI
CftRL&fflaM.
Potential Extractor!
Well Location
Legend
J Ccrlainrnent Area
¦ 51 Games St Property Boundary
• Exfsting DAPL
Extraction Well
Proposed DAPL
m'm conveyance piping
Existing DAPL
conveys rrce piping
Approximate DAPL
Pool Boundary
GW Hot Soot
Proposed Extraction Well
Proposed Treatment Ptant
» Proposed GW conveyance piping
NOMA in Groundwater (in ng/L)
DAPL - dense aqueous phase iqutd
GW - groundwater
NDMA - N-Nltrosodimethylamrne
"11.GOO ng/L" identifies NOMA
concentrations in nanograms per Liter
Notes:
1 I imits of ndma taocontouni am
based on historically observed
MDMA concentrations.
2. The limits of Institutional Controls
and extents of remedies, including
the final number and location of
extraction wells, will be based on
pre-design investigations and
subsequent data evaluation.
Figure
-------
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WAJN STREET DAPL POOL
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MassDEP Concurrence Letter- OU1, OU2 & Interim OU3 ROD - Olin Chemical Superfund Site
LNAPl/SW Alternatives
Ah 11 No Anion
Aft 2: MPE for LNAPL with treatment at Plant B, GW extraction to prevent discharge
to surface water
Ait 3 : Demotion of Plant B. expanded MP£ for LNAPL targeted GW extraction to
prevent di scharge to surface water
Alt 4: Excavation of LNAPL with off-site disposal, PRB to treat GW before discharge
to surface water
Proposed Extraction Well
Legend
Interpreted Extent of
LNAPL (March 2018)
Groundwater Sampling Location
. ~ Surface VWiter Sampling Location
Proposed Treatment Plant £^3 Containment Area
m Conveyance Piping ^—51 Eames St Property Boundary
LNAPL Alternative
O *»""« MPE Wril Location SAC - sjraniil,. carton
GW - groundvrater
¦ Conveyance Piping
LNAPL - light non-aqueous phase liquid
MPE - multi-phase extraction
Note:
The limits of Institutional Controls
and extents of remedies, including PRB - permeable reactive barrier
the final number and location of sw-surface water
extraction wells, will be based on
pre-deslgn investigations and
subsequent data evaluation.
Figure - 7
-------
MassDEP Concurrence Letter- OU1, OU2 & Interim OU3 ROD - Olin Chemical Superfund Site
2
Figure - 8
l Proposed
W J Containment Area Cap
O Potential TMP
\fepor Bamer/SSOS
a Existing Conta*>merit Area«
3 Estimated Sediment
Excavation Area
~ Estimated Wetland
Excavation Area
CD Sediment Areas
~ Wetland Soil
Legend
mUpland Sal Area
Proposed for Asphalt Cover
m Upland Soil Area
Proposed for Soil Cover
51 Eames St Property Boundary
AS/SVE - Air Sparge/Soil Vapor Extraction
CA - Containnent Area
S3DS - Sub-sab duptessumuburi
TMP - trimethyl pentenes
Note:
The limits of institutional controls and
extents of remedies including capping,
excavation, and/or vapor
barriers/depressurization systems
will be based on pre-design investigation
and subsequent data evaluation.
AitMnativ* soiL'SED-2: Goniainmor* Aria cap.
upland soil covers, excavation vxith off-site
disposal and reiteration of wetland soil and
sediments, limited action for TRIPs
{Institutional Control*, Including vapor Intrusion
evaluation
-------
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VSMminqton. Massachusetts
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Scale 1 17,000
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MARION STREET
Area: 1,450 Acres
2,520
Legend
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Groundwater Study Area
Groundwater Study Area (VWmngton Parcels)
Groundwater Study Area (Wotxjm Paroeis)
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Appendix B
Tables
Record of Decision Appendix B
Olin Chemical Superfund Site March 2021
Wilmington, Massachusetts
-------
Table B-1
Contaminants of Concern
OU1-OU2
OU3 (Interim)
Contaminant of Concern
Surface
Soil
Subsurface
Soil
Surface
Water
Sediment
Overburden
Groundwater
Bedrock
Groundwater
DAPL
Volatile Organic Compounds
1,2,4-T richloro benzene
X
X
1,2-Dichloroethane
X
X
X
1,3-Dichlorobenzene
X
1,4-Dichlorobenzene
X
X
2.4.4-T ri methyl-1 -Pentene
X
X
X
2,4,4-T rimethyl-2-Pentene
X
X
X
4-lsopropyltoluene
X
X
Benzene
X
X
X
Bromodichloro methane
X
X
X
X
Bromoform
X
X
X
Carbon tetrachloride
X
Chlorodibromomethane
X
Chloroform
X
X
X
X
Cis-1,2-Dichloroethene
X
X
X
Dibromochloro methane
X
X
X
Dibro mo methane
X
X
X
X
Ethylbenzene
X
Methyl tert-butyl ether
X
Methylene chloride
X
Naphthalene
X
X
Trichloroethene
X
X
X
X
Vinyl Chloride
X
X
X
X
Page 1 of 4
-------
Table B-1
Contaminants of Concern
Contaminant of Concern
OU1-OU2
OU3 (Interim)
Surface
Soil
Subsurface
Soil
Surface
Water
Sediment
Overburden
Groundwater
Bedrock
Groundwater
DAPL
Semivolatile Organic Compounds
1,1 -Biphenyl
X
X
2-Nitrophenol
X
3 & 4 Methylphenol
X
4-Bromophenyl-phenylether
X
4-Chloroaniline
X
4-Chloropheriyl-phenylether
X
X
X
4-Nitrophenol
Azobenzene
X
X
Benzo(a)anthracene
X
X
X
X
Benzo(a)pyrene
X
X
X
X
X
X
X
Benzo(b)fluoranthene
X
X
X
X
X
Benzo(k)fluoranthene
X
X
Bis(2-ethylhexyl)phthalate
X
X
X
X
X
Garbazole
X
X
X
Chrysene
X
Dibenz(a,h)anthracene
X
X
X
X
X
X
Dimethylphthalate
X
Diphenyl Ether
X
X
X
X
X
X
X
Diphenylmethanone
X
N-N
trosodimethylamine (NOMA)
X
X
X
X
N-N
trosodiphenylamine (NDPhA)
X
X
N-N
troso-di-n-propylamine (NDPrA)
X
X
Pentachlorophenol
X
Phenanthrene
X
X
Pyrene
X
Page 2 of 4
-------
Table B-1
Contaminants of Concern
Contaminant of Concern
OU1-OU2
OU3 (Interim)
Surface
Soil
Subsurface
Soil
Surface
Water
Sediment
Overburden
Groundwater
Bedrock
Groundwater
DAPL
Pesticides/PC Bs
Aroclor-1260
X
X
Delta-BHC
X
Metals
Aluminum
X
X
X
X
Antimony
X
X
X
X
X
Arsenic
X
X
X
X
X
X
X
Beryllium
X
X
Cadmium
X
X
Chromium
X
X
X
Chromium, Hexavalent
X
X
X
X
X
X
Cobalt
X
X
X
X
X
X
Copper
X
X
X
Iron
X
X
X
Lead
X
Manganese
X
X
X
X
X
Mercury
X
Nickel
X
X
X
X
Silver
X
X
X
X
Thallium
X
X
X
X
X
Tin
X
X
Vanadium
X
X
X
X
Zinc
X
Page 3 of 4
-------
Table B-1
Contaminants of Concern
Contaminant of Concern
OU1-OU2
OU3 (Interim)
Surface
Soil
Subsurface
Soil
Surface
Water
Sediment
Overburden
Groundwater
Bedrock
Groundwater
DAPL
Inorganics
Bromide
X
Chloride
X
X
X
X
X
Nitrate as N
X
Nitrogen, as Ammonia
X
X
X
X
Sulfate
X
X
X
X
Urea
X
Petroleum Hydrocarbons
C5-C8 Aliphatics
X
C9-C10 Aromatics
X
C9-C12 Aliphatics
X
C11-C22 Aromatics
X
X
X
X
C19-C22 Aliphatics
X
Specialty Compounds
1,1-Dimethylhydrazine (UDMH)
X
X
4-Nonylphenol
X
Acetaldehyde
X
Formaldehyde
X
Hydrazine
X
X
X
X
X
Kempore (Azodicarbonamide)
X
Monomethylhydrazine (MMH)
X
Perchlorate
X
X
Key
X = Contaminant of Concern or potential Contaminant of Concern DAPL = Dense Aqeous Phase Liquid
Site = Olin Chemical Superfund Site BHHRA = Baseline Human Health Risk Assessment
Property = Olin Property at 51 Eames Street, Wilmington, MA PCBs = Polychlorinated Biphenyls
OU = Operable Unit
Note:
1.Surface soil, subsurface soil, surface water, and sediment contaminants of concern based on OU1/OU2 Remedial Investigation Report Table 6.2-1.
Groundwater contaminants of concern based on Draft OU3 BHHRA Tables 5.3-1 through 5.3-4. DAPL contaminants of concern based on Draft OU3 BHHRA
Table E-28; all analytes with cancer risk above 1x10-6 or Hazard Index above 1 assumed to be contaminants of concern.
2. The list of overburden groundwater Contaminants of Concern includes both on-Property (Plant B) and off-Property impacts.
Page 4 of 4
-------
ROD RISK WORKSHEET
Table G-1
OU1/2 Summary of Contaminants of Concern and Medium-Specific Exposure Point Concentration
Scenario Timeframe: Future
Medium: Soil
Exposure Medium: Surface Soil
Exposure Point
Chemical of
Concern
Concentration
Units
Exposure Point
Concentration
Exposure Point
Concentration
Units
Statistical
Measure
Mean
Maximum
95% UCL
(1)
EA1 -OU1
Semivolatite Organics
Benzo(a)anthracene
0.91
28
4.2
NP [a]
mg/Kg
4.2
mg/Kg
UCL-NP[a]
Benzo(a)pyrene
0.70
21
3.0
NP [a]
mg/Kg
3.0
mg/Kg
UCL - NP [a]
Benzo(b)fluoranthene
0.86
29
4.0
NP [a]
mg/Kg
4.0
mg/Kg
UCL - NP [a]
B is(2-Ethylhexyl )phtha late
6.3
375
39
NP [a]
mg/Kg
39
mg/Kg
UCL - NP [a]
C11-C22 Aromatics
171
1900
437
NP [b]
mg/Kg
437
mg/Kg
UCL - NP [b]
Carbazole
0.19
5.4
0.34
NP [c]
mg/Kg
0.34
mg/Kg
UCL - NP [c]
D
benz(a, h)anthracene
0.24
4.8
0.23
G [h]
mg/Kg
0.23
mg/Kg
UCL - G [h]
D
methylphthalate
0.34
0.11
0.040
NP [c]
mg/Kg
0.040
mg/Kg
UCL - NP [c]
D
phenyl ether
0.10
1.7
0.086
Gfh]
mg/Kg
0.086
mg/Kg
UCL - G [h]
indeno(1,2,3-cd)pyrene
0.45
14
1.9
NP [a]
mg/Kg
1.9
mg/Kg
UCL - NP [a]
PCBs
Aroclor-1260
0.89
13
1.8
NP [c]
mg/Kg
1.8
mg/Kg
UCL - NP [c]
Metals
Antimony
0.66
0.92
0.48
NP [c]
mg/Kg
0.48
mg/Kg
UCL - NP [c]
Arsenic
7.0
56
10.9
NP [d]
mg/Kg
10.9
mg/Kg
UCL - NP [d]
Chromium, Hexavaient
2.8
11
7.4
NP [a]
mg/Kg
7.4
mg/Kg
UCL - NP [a]
Cobalt
3.5
12
4.8
NP [e]
mg/Kg
4.8
mg/Kg
UCL - NP [e]
Silver
0.73
15
1.2
NP [b]
mg/Kg
1.2
mg/Kg
UCL - NP [b]
Thallium
0.63
2.2
0.50
NP [c]
mg/Kg
0.50
mg/Kg
UCL - NP [c]
Inorganics
Chloride
16
95
26
NP [c]
mg/Kg
26
mg/Kg
UCL - NP [c]
Nitrogen, as Ammonia
34
170
53
NP [d]
mg/Kg
53
mg/Kg
UCL - NP [d]
Sulfate
432
19400
1821
NP [d]
mg/Kg
1821
mg/Kg
UCL - NP [d]
Page 1 of 7
-------
Table G-1
OU1/2 Summary of Contaminants of Concern and Medium-Specific Exposure Point Concentration
Scenario Timeframe: Future
Medium: Soil
Exposure Medium: Surface Soil
Exposure Point
Chemical of
Concern
Concentration
Units
Exposure Point
Concentration
Exposure Point
Concentration
Units
Statistical
Measure
Mean
Maximum
95% UCL
(1)
EA2-OU1
Semivolatile Organics
Benzo(a)anthracene
1.0
0.36
0.19
NP [c]
mg/Kg
0.19
mg/Kg
UCL - NP [c]
Benzo(a)pyrene
0.25
0.24
0.15
NP [f]
mg/Kg
0.15
mg/Kg
UCL - NP [f]
Benzo(b)fluoranthene
1.1
0.56
0.20
GO]
mg/Kg
0.20
mg/Kg
UCL - G [i]
Bis(2-Ethylhexyl)phthalate
22
340
91
G[i]
mg/Kg
91
mg/Kg
UCL - G [i]
Dibenz(a,h)anthracene
0.28
0.31
0.21
NP [c]
mg/Kg
0.21
mg/Kg
UCL - NP [c]
Diphenyl ether
2.1
0.12
NC
mg/Kg
0.12
mg/Kg
Maximum
lndeno(1,2,3-cd)pyrene
1.0
0.2
0.13
NP [f]
mg/Kg
0.13
mg/Kg
UCL - NP [f]
Metals
Arsenic
6.7
15
8.5
NP [f]
mg/Kg
8.5
mg/Kg
UCL - NP [f]
Cobalt
3.0
5.9
3.7
N [II
mg/Kg
3.7
mg/Kg
UCL - N [I]
Silver
0.73
1.3
0.70
NP [c]
mg/Kg
0.70
mg/Kg
UCL - NP [c]
Inorganics
Chloride
79
550
173
NP [c]
mg/Kg
173
mg/Kg
UCL - NP [c]
Nitrogen, as Ammonia
439
1200
625
N[l]
mg/Kg
625
mg/Kg
UCL - N [I]
Sulfate
41
37
35
NPfc]
mg/Kg
35
mg/Kg
UCL - NP [c]
EA3 - OU1
Semivolatile Organics
Benzo(a)anthracene
0.09
0.12
0.083
NP [c]
mg/Kg
0.083
mg/Kg
UCL - NP [c]
Benzo(a)pyrene
0.08
0.17
0.093
NP [c]
mg/Kg
0.093
mg/Kg
UCL - NP [c]
Benzo(b)fluoranthene
0.10
0.24
0.13
NP [f]
mg/Kg
0.13
mg/Kg
UCL - NP [f]
Bis(2-Ethylhexyl )phtha late
3.0
13
4.6
NP [b]
mg/Kg
4.6
mg/Kg
UCL - NP [b]
C11-G22 Aromatics
27
100
75
NP [e]
mg/Kg
75
mg/Kg
UCL - NP [e]
Dibenz(a,h)anthracene
0.087
0.21
NC
mg/Kg
0.21
mg/Kg
Maximum
Diphenyl ether
0.091
0.19
0.10
NP [c]
mg/Kg
0.10
mg/Kg
UCL - NP [c]
lndeno(1,2,3-cd)pyrene
0.087
0.14
0.097
NP [c]
mg/Kg
0.097
mg/Kg
UCL - NP [c]
PCBs
Aroclor-1260
0.095
0.14
NC
mg/Kg
0.14
mg/Kg
Maximum
Metals
Arsenic
5.8
8.2
7.1
N [I]
mg/Kg
7.1
mg/Kg
UCL - N [I]
Cobalt
4.6
7.9
5.9
N[l]
mg/Kg
5.9
mg/Kg
UCL - N [I]
Chromium, Hexavalent
1.2
1.7
1.8
N[l]
mg/Kg
1.7
mg/Kg
Maximum
Silver
0.32
0.11
NC
mg/Kg
0.11
mg/Kg
Maximum
Inorganics
Nitrogen, as Ammonia
285
2100
2892
NP [g]
mg/Kg
2100
mg/Kg
Maximum
Page 2 of 7
-------
Table G-1
OU1/2 Summary of Contaminants of Concern and Medium-Specific Exposure Point Concentration
Scenario Timeframe: Future
Medium: Soil
Exposure Medium: Surface Soil
Exposure Point
Chemical of
Concern
Concentration
Units
Exposure Point
Concentration
Exposure Point
Concentration
Units
Statistical
Measure
Mean
Maximum
95% UCL
(1)
EA4-OU1
Semivolatile Organics
Benzo(a)anthracene
0.51
0.4
0.23
NP [f]
mg/Kg
0.23
mg/Kg
UCL - NP [f]
Benzo(a)pyrene
0.24
0.62
0.24
NP [c]
mg/Kg
0.24
mg/Kg
UCL - NP [c]
Benzo(b)fluoranthene
0.54
1.065
0.23
G [i]
mg/Kg
0.23
mg/Kg
UCL - G [i]
Bis(2-Ethylhexyl)phthalate
14
200
33
NP [b]
mg/Kg
33
mg/Kg
UCL - NP [b]
Dibenz(a,h)anthracene
0.20
0.25
0.43
NP [a]
mg/Kg
0.25
mg/Kg
Maximum
lndeno(1,2,3-cd)pyrene
0.53
0.725
0.28
NP [c]
mg/Kg
0.28
mg/Kg
UCL - NP [c]
Metals
Antimony
5.9
79
NC
mg/Kg
79
mg/Kg
Maximum
Arsenic
9.8
32
13.1
NP [f]
mg/Kg
13.1
mg/Kg
UCL - NP [f]
Chromium, Hexavalent
21
95
NC
mg/Kg
95
mg/Kg
Maximum
Cobalt
7.9
45.5
31
NP [a]
mg/Kg
31
mg/Kg
UCL - NP [a]
Silver
0.61
0.99
NC
mg/Kg
0.99
mg/Kg
Maximum
Inorganics
Chloride
81
560
185
NP [c]
mg/Kg
185
mg/Kg
UCL - NP [c]
Nitrogen, as Ammonia
193
460
254
N [I]
mg/Kg
254
mg/Kg
UCL - N [I]
Sulfate
273
2400
638
NP [c]
mg/Kg
638
mg/Kg
UCL - NP [c]
Page 3 of 7
-------
Table G-1
OU1/2 Summary of Contaminants of Concern and Medium-Specific Exposure Point Concentration
Scenario Timeframe: Future
Medium: Soil
Exposure Medium: Surface Soil
Exposure Point
Chemical of
Concern
Concentration
Units
Exposure Point
Concentration
Exposure Point
Concentration
Units
Statistical
Measure
Mean
Maximum
95% UCL
a)
EA5 - OU2
Semivolatile Organics
Benzo(a)arrthracene
0.42
2.3
2.999
NP [g]
mg/Kg
2.3
mg/Kg
Maximum
Benzo(a)pyrene
0.072
0.44
0.15
NP [c]
mg/Kg
0.15
mg/Kg
UCL - NP [c]
Benzo(b)fluoranthene
0.27
0.6
0.21
NP [c]
mg/Kg
0.21
mg/Kg
UCL - NP [c]
Bis(2-Ethylhexyl)phthalate
31
216
103
NP [d]
mg/Kg
103
mg/Kg
UCL - NP [d]
C11-C22 Aromatics
4,450
7500
NC
mg/Kg
7500
mg/Kg
Maximum
Carbazole
0.036
0.086
0.055
NP [c]
mg/Kg
0.055
mg/Kg
UCL - NP [c]
Diphenyl ether
0.37
1.9
0.95
NP [c]
mg/Kg
0.95
mg/Kg
UCL - NP [c]
lndeno(1,2,3-cd)pyrerte
1.3
13
17.0
NP [g]
mg/Kg
13.0
mg/Kg
Maximum
N-Nitrosodi-n-propylamine
2.5
0.26
NC
mg/Kg
0.26
mg/Kg
Maximum
Metals
Antimony
0.88
0.34
0.36
NP [c]
mg/Kg
0.34
mg/Kg
Maximum
Arsenic
19
42
23
NP [f]
mg/Kg
23
mg/Kg
UCL - NP [f]
Chromium, Hexavalent
79
1100
240
NP [c]
mg/Kg
240
mg/Kg
UCL - NP [c]
Cobalt
3.2
10
4.988
N [I]
mg/Kg
4.988
mg/Kg
UCL - N [I]
Silver
103
1100
1441
NP [g]
mg/Kg
1100
mg/Kg
Maximum
Thallium
1.9
7.4
NC
mg/Kg
7.4
mg/Kg
Maximum
Inorganics
Nitrogen, as Ammonia
406
1100
749
LN [m]
mg/Kg
749
mg/Kg
UCL - LN [m]
Sulfate
74
230
143
NP [c]
mg/Kg
143
mg/Kg
UCL - NP [c]
Page 4 of 7
-------
Table G-1
OU1/2 Summary of Contaminants of Concern and Medium-Specific Exposure Point Concentration
Scenario Timeframe: Future
Medium: Soil
Exposure Medium: Surface Soil
Exposure Point
Chemical of
Concern
Concentration
Units
Exposure Point
Concentration
Exposure Point
Concentration
Units
Statistical
Measure
Mean
Maximum
95% UCL
(1)
EA6-OU1
Semivolatile organics
Benzo(a)anthracene
0.47
1.1
0.19
NP [c]
mg/Kg
0.19
mg/Kg
UCL - NP [c]
Benzo(a)pyrene
0.36
3.4
0.36
G [h]
mg/Kg
0.36
mg/Kg
UCL - G [h]
Benzo(b)fluoranthene
0.48
0.71
0.17
NP [f]
mg/Kg
0.17
mg/Kg
UCL - NP [f]
Bis(2-Ethylhexyl)phthalate
7.4
110
36
NP [g]
mg/Kg
36
mg/Kg
UCL - NP [g]
C11-C22 Aromatics
32
130
54
NP [f]
mg/Kg
54
mg/Kg
UCL - NP [f]
Carbazole
0.091
0.02
NC
mg/Kg
0.020
mg/Kg
Maximum
Dibenz(a,h)anthracene
0.23
0.14
0.080
NP [c]
mg/Kg
0.080
mg/Kg
UCL - NP [c]
lndeno{1,2,3-cd)pyrene
0.46
0.43
0.19
NP [c]
mg/Kg
0.19
mg/Kg
UCL - NP [c]
PCBs
Delta-BHG
0.016
0.031
0.027
NP [g]
mg/Kg
0.027
mg/Kg
UCL - NP [g]
Metals
Arsenic
6.7
31
8.0
NP [f]
mg/Kg
8.0
mg/Kg
UCL - NP [f]
Chromium, Hexavalent
7.9
8.9
NC
mg/Kg
8.9
mg/Kg
Maximum
Cobalt
2.4
7.3
3.9
GO]
mg/Kg
3.9
mg/Kg
UCL - G 0]
Silver
1.9
0.98
NC
mg/Kg
0.98
mg/Kg
Maximum
Thallium
1.1
0.8
NC
mg/Kg
0.80
mg/Kg
Maximum
inorganics
Chloride
16
56
NC
mg/Kg
56
mg/Kg
Maximum
Nitrogen, as Ammonia
309
1800
748
NP [e]
mg/Kg
748
mg/Kg
UCL - NP [e]
Sulfate
1752
23900
17890
NP [g]
mg/Kg
17890
mg/Kg
UCL - NP [g]
Page 5 of 7
-------
Table G-1
OU1/2 Summary of Contaminants of Concern and Medium-Specific Exposure Point Concentration
Scenario Timeframe: Future
Medium: Soil
Exposure Medium: Surface Soil
Exposure Point
Chemical of
Concern
Concentration
Units
Exposure Point
Concentration
Exposure Point
Concentration
Units
Statistical
Measure
Mean
Maximum
95% UCL
(1)
EA7-OU1
Semivolatile Organics
Benzo(a)arrthracene
0.056
0.22
0.062
NP [c]
mg/Kg
0.062
mg/Kg
UCL - NP [c]
Benzo(a)pyrene
0.058
0.22
0.071
NP [c]
mg/Kg
0.071
mg/Kg
UCL - NP [c]
Benzo(b)fluoranthene
0.061
0.31
0.082
NP [c]
mg/Kg
0.082
mg/Kg
UCL - NP [c]
Bis(2-Ethylhexyl)phthalate
1.8
21
3.9
NP [b]
mg/Kg
3.9
mg/Kg
UCL - NP [b]
C11-C22 Aromatics
43
390
113
NP [b]
mg/Kg
113
mg/Kg
UCL - NP [b]
Diphenyl ether
0.16
1.7
0.34
NP [c]
mg/Kg
0.34
mg/Kg
UCL - NP [c]
lndeno(1,2,3-cd)pyrene
0.05
0.13
NC
mg/Kg
0.13
mg/Kg
Maximum
Metals
Arsenic
6.9
15
13.6
NP [e]
mg/Kg
13.6
mg/Kg
UCL - NP [e]
Chromium, Hexavalent
0.86
2.0
1.2
N [II
mg/Kg
1.2
mg/Kg
UCL - N [I]
Cobalt
3.2
7.4
4.5
G[k]
mg/Kg
4.5
mg/Kg
UCL - G [k]
Silver
0.28
0.42
0.32
NP [c]
mg/Kg
0.32
mg/Kg
UCL - NP [c]
Thallium
0.49
0.11
NC
mg/Kg
0.11
mg/Kg
Maximum
Inorganics
Chloride
13
25
NC
mg/Kg
25
mg/Kg
Maximum
Nitrogen, as Ammonia
21
45
29
NP [f]
mg/Kg
29
mg/Kg
UCL - NP [f]
Sulfate
40
140
65
NP [c]
mg/Kg
65
mg/Kg
UCL - NP [c]
Page 6 of 7
-------
Table G-1
0U1/2 Summary of Contaminants of Concern and Medium-Specific Exposure Point Concentration
Scenario Timeframe: Future
Medium: Soil
Exposure Medium: Surface Soil
Exposure Point
Chemical of
Concern
Concentration
Units
Exposure Point
Concentration
Exposure Point
Concentration
Units
Statistical
Measure
Mean
Maximum
95% UCL
(1)
Containment Area -
OU1
Sem{volatile Organics
Benzo(a )a nthracene
0.019
0.019
0.020
NP [c]
mg/Kg
0.019
mg/Kg
Max
mum
Benzo(a)pyrene
0.018
0.017
0.017
NP [o]
mg/Kg
0.017
mg/Kg
Max
mum
Benzo(b)fluoranthene
0.020
0.027
0.028
NP [o]
mg/Kg
0.027
mg/Kg
Max
mum
Bis(2-Ethylhexyl)phthalate
0.69
1.6
1.1
G[k]
mg/Kg
1.1
mg/Kg
UCL - G [k]
Diphenyi ether
0.019
0.015 J
NC
mg/Kg
0.015
mg/Kg
Maximum
Metals
Arsenic
9.5
23
13.6
G [k]
mg/Kg
13.6
mg/Kg
UCL - G [k]
Cobalt
4.2
5.6
4.7
N [II
mg/Kg
4.7
mg/Kg
UCL - N [I]
Chromium, Hexavalent
3.3
5.1
3.9
N [II
mg/Kg
3.9
mg/Kg
UCL - N [I]
Silver
0.65
1.2
0.83
N [II
mg/Kg
0.83
mg/Kg
UCL - N [I]
Inorganics
Chloride
13.4
44
NC
mg/Kg
44
mg/Kg
Maximum
Nitrogen, as Ammonia
12.4
39
21
NP [c]
mg/Kg
21
mg/Kg
UCL - NP [c]
Sulfate
3460
13000
9225
G[k]
mg/Kg
9225
mg/Kg
UCL - G [k]
Key
(1) Statistics: Maximum Detected Value (maximum); 95% UCL; Arithmetic Mean (Mean)
NC - Not Calculated
UCL - Upper Confidence Limit
J - estimated value
PCB - polychlorinated biphenyls
mg/kg - milligrams per kilogram
NP - Nonparametric distribution
[a] 97.5% KM (Chebyshev) UCL
[b] 95% KM (BCA) UCL
[c] 95% KM (t) UCL
[d] 95% KM (Chebyshev) UCL
[e] 95% Chebyshev (Mean, Sd) UCL
[f] 95% KM (Percentile Bootstrap) UCL
[g] 99% KM (Chebyshev) UCL
G - Gamma Distribution
[h] 95% GROS Approximate Gamma
[i] 95% GROS Adjusted Gamma
0] 95% Adjusted Gamma KM-UCL
[k] 95% Adjusted Gamma UCL
N - Normal distribution
[I] 95% Student's-t
LN - Lognormal distribution
[m] 95% H- UCL
The table represents the current/future chemical of concern (COC) and exposure point concentration (EPC) for the COCs in surface soil (i.e., the concentration that will be used to estimate the exposure and risk
for the COC in surface soil). The table includes the range of concentrations detected for the COCs, the EPC, and how the EPC was derived. Frequency of Detection was not used for evaluation given the size of
the areas, number of samples, and potential for varied chemical impacts. The 95% UCL on the arithmetic mean was used as the EPC for all COCs except for the following: dipheny! ether (EA2);
dibenz(a,h)anthracene, Aroclor-1260, hexavalent chromium, silver, and ammonia (EA3); dibenz(a)anthracene, antimony, hexavalent chromium, and silver (EA4); benzo(a)anthracene, C11-C22 aromatics,
ndeno(1,2,3-cd)pyrene, n-nitrosodi-n-propyiamine, antimony, silver, and thallium (EA5); carbazoie, hexavalent chromium, silver, thallium, and chloride (EA6); lndeno(1,2,3-cd)pyrene, thallium, and chloride (EA7);
and benzo(a)anthracene, benzo(a)pyrene, benzo(b)fluoranthene, diphenyi ether, and chloride (Containment Area). For these COCs, the maximum concentration was used because it is lower than the calculated
95% UCL, or no 95% UCL could be calculated.
Source: A Guide to Preparing Superfund Proposed Plans, Records of Decision, and Other Remedy Selection Decision Documents (U.S. EPA, 1999)
Page 7 of 7
-------
ROD RISK WORKSHEET
Table G-2
OU1/2 Summary of Contaminants of Concern and Medium-Specific Exposure Point Concentration
Scenario Timeframe: Future
Medium: Soil
Exposure Medium: Subsurface Soil
Exposure Point
Chemical of Concern
Concentration
Units
Exposure Point
Concentration
Exposure Point
Concentration
Units
Statistical
Measure
Mean
Maximum
95% UCL
(1)
EA1 - 0U1
Volatile Organics
2,4,4-Trimethyl-1-pentene
2.2
103
9.5
NP [h]
mg/Kg
9.5
mg/Kg
UCL - NP [h]
2,4,4-Trimethyl-2-pentene
1.0
45
1.4
G[i]
mg/Kg
1.4
mg/Kg
UCL - G |0
4-iso-Propyltoiuene
0.14
5.2
0.26
NP [c]
mg/Kg
0.26
mg/Kg
UCL - NP [c]
4-Chlorophenyl phenyl ether
3.4
0.17
NC
mg/Kg
0.17
mg/Kg
Maximum
Semivoiatile Organics
Benzo(a)anthracene
0.28
0.088
0.029
NP [c]
mg/Kg
0.029
mg/Kg
UCL - NP [c]
Benzo(a)pyrene
0.17
0.34
0.038
NP [c]
mg/Kg
0.038
mg/Kg
UCL - NP [c]
Benzo{b)fluoranthene
0.28
0.49
0.048
NP [c]
mg/Kg
0.048
mg/Kg
UCL - NP [c]
Benzo(k)fluoranthene
0.46
0.22
0.027
NP [c]
mg/Kg
0.027
mg/Kg
UCL - NP [c]
Bis(2-Ethylhexyl)phthalate
51
1218
159
NP [h]
mg/Kg
159
mg/Kg
UCL - NP fh]
Carbazoie
4.3
0.017
NC
mg/Kg
0.017
mg/Kg
Maximum
Diphenyl ether
0.12
3.8
0.24
NP Ic]
mg/Kg
0.24
mg/Kg
UCL - NP [c]
lndeno(1,2,3-cd)pyrene
0.36
10
0.12
G[i]
mg/Kg
0.12
mg/Kg
UCL - G [i]
N-Nitrosodiphenylamine
57
3400
266
NP[h]
mg/Kg
266
mg/Kg
UCL - NP [h]
PCBs
Aroclor-1260
0.55
10
1.0
NP [c]
mg/Kg
1.0
mg/Kg
UCL - NP [c]
Metals
Antimony
2.5
41
2,7
NP [b]
mg/Kg
2.7
mg/Kg
UCL - NP [b]
Arsenic
3.7
16
4.1
NP [e]
mg/Kg
4.1
mg/Kg
UCL - NP [e]
Chromium, Hexavalent
3.2
19.9
4.7
NP[e]
mg/Kg
4.7
mg/Kg
UCL - NP [e]
Inorganics
Chloride
23
170
26
NP(c]
mg/Kg
26
mg/Kg
UCL - NP [c]
Nitrogen, as Ammonia
1B1
4700
449
NP[b]
mg/Kg
449
mg/Kg
UCL - NP [b]
Sulfate
5469
285000
27406
NP [h]
mg/Kg
27406
mg/Kg
UCL - NP [h]
Petroleum Hydrocarbons
C11-C22 Aromatics
372
4700
693
NP [e]
mg/Kg
693
mg/Kg
UCL - NP [e]
Specialty Compounds
Hydrazine
0.11
1.9
0.41
NP [d]
mg/Kg
0.41
mg/Kg
UCL - NP [d]
Page 1 of 3
-------
Table G-2
OU1/2 Summary of Contaminants of Concern and Medium-Specific Exposure Point Concentration
Scenario Timeframe: Future
Medium: Soil
Exposure Medium: Subsurface Soil
Exposure Point
Chemical of Concern
Concentration
Units
Exposure Point
Concentration
Exposure Point
Concentration
Units
Statistical
Measure
Mean
Maximum
95% UCL
(1)
EA3 - 0U1
Volatile Organics
2,4,4-Trimethyl-1 -pentene
32
230
66
NP [a]
mg/Kg
66
mg/Kg
UCL - NP[a]
2,4,4-Trimethyi-2-pentene
3.7
27
7.3
NP [a]
mg/Kg
7.3
mg/Kg
UCL - NP[a]
Semivolatile Organics
Bis(2-Ethy!hexyl)phthalate
901
8600
3522
NP [b]
mg/Kg
3522
mg/Kg
UCL - NP[b]
N-Nitrosodiphenylamine
2.0
0.41
0.24
NP [c]
mg/Kg
0.24
mg/Kg
UCL - NP [c]
Metals
Antimony
4.2
0.67
0.61
NP [c]
mg/Kg
0.61
mg/Kg
UCL - NP [c]
Arsenic
3.6
5.2
4.1
N [f]
mg/Kg
4.1
mg/Kg
UCL - N [f]
Chromium, Hexavalent
0.44
1.1
0.59
N[f]
mg/Kg
0.59
mg/Kg
UCL - N [f]
Inorganics
Chloride
22
56
37
NP jc]
mg/Kg
37
mg/Kg
UCL - NP [c]
Nitrogen, as Ammonia
5.9
11.3
8.7
NP [c]
mg/Kg
8.7
mg/Kg
UCL - NP [c]
Sulfate
31
120
54
NP [c]
mg/Kg
54
mg/Kg
UCL - NP [c]
Petroleum Hydrocarbons
C11-C22 Aromatics
1,006
450Q
1904
N[f]
mg/Kg
1904
mg/Kg
UCL - N [f]
Specialty Compounds
Hydrazine
0.0025
0.0039
NC
mg/Kg
0.0039
mg/Kg
Maximum
Page 2 of 3
-------
Table G-2
OU1/2 Summary of Contaminants of Concern and Medium-Specific Exposure Point Concentration
Scenario Timeframe: Future
Medium: Soil
Exposure Medium: Subsurface Soil
Exposure Point
Chemical of Concern
Concentration
Units
Exposure Point
Concentration
Exposure Point
Concentration
Statistical
Measure
Mean
Maximum
95% UCL
Units
(1)
EA7 - 0U1
Volatile Organics
2,4,4-TrimethyM -pentene
72
1200
133
NP [c]
mg/Kg
133
mg/Kg
UCL - NP [c]
2,4,4-Trimethyl-2-pentene
22
310
40
NP [c]
mg/Kg
40
mg/Kg
UCL - NP [c]
Semivolatile Organics
Benzo(a)anthracene
0.78
18
1.5
NP [c]
mg/Kg
1.5
mg/Kg
UCL - NP [c]
Benzo(a)pyrene
0.70
23
1.7
NP [c]
mg/Kg
1.7
mg/Kg
UCL - NP [c]
Benzo(b)fluoranthene
0.53
17
NC
mg/Kg
17
mg/Kg
Maximum
Bis(2-Ethyihexyl)phthaiate
36
580
225
NP [d]
mg/Kg
225
mg/Kg
UCL - NP [d]
Diphenyl ether
0.22
3.1
0.52
NP [c]
mg/Kg
0.52
mg/Kg
UCL - NP [c]
lndeno(1,2,3-cd)pyrene
0.40
10
0.78
NP[c]
mg/Kg
0.78
mg/Kg
UCL - NP [c]
N-Nitrosodiphenylamine
1.4
38
2.9
Q[g]
mg/Kg
2.9
mg/Kg
UCL - G [g]
Metals
Antimony
3.0
0.35
0.38
NP [c]
mg/Kg
0.35
mg/Kg
Maximum
Arsenic
4.4
7.5
5.3
N[13
mg/Kg
5.3
mg/Kg
UCL - N [f]
Chromium, Hexavalent
0.77
1.9
0.95
N[fl
mg/Kg
0.95
mg/Kg
UCL - N [f]
Inorganics
Nitrogen, as Ammonia
5.6
11
8.0
NP [c]
mg/Kg
8.0
mg/Kg
UCL - NP [c]
Sulfate
32
80
46
NP [c]
mg/Kg
46
mg/Kg
UCL - NP [c]
Urea
120
350
310
NP [c]
mg/Kg
310
mg/Kg
UCL - NP [c]
Petroleum Hydrocarbons
C11-C22 Aromatics
237
1700
374
NP [e]
mg/Kg
374
mg/Kg
UCL - NP [e]
Specialty Compounds
Hydrazine
0.00085
0.0007
0.00078
NP [c]
mg/Kg
0.0007
mg/Kg
Maximum
Key
(1) Statistics: Maximum Detected Value (maximum); 95% UCL; Arithmetic Mean (Mean)
NC - Not Calculated
UCL - Upper Confidence Limit
J - estimated value
PCB - polychlorinated biphenyls
mg/kg - milligrams per kilogram
NP - Nonparametric distribution
N - Normal distribution
[a] 95% KM (Percentile Bootstrap) UCL
[f] 95% Student's-t
[b] 95% KM (Chebyshev) UCL
[c] 95% KM (t) UCL
[d] 99% KM (Chebyshev) UCL
G - Gamma Distribution
[e] 95% KM (BCA) UCL
[g] 95% GROS Adjusted Gamma
[h] 97.5% KM (Chebyshev) UCL
[i] 95% GROS Approximate Gamma UCL
The table represents the current/future chemical of concern (COC) and exposure point concentration (EPC) for the COCs in subsurface soil (i.e., the concentration that will be used to estimate the exposure and risk for the
COC in subsurface soil). The table includes the range of concentrations detected for the COCs, the EPC, and how the EPC was derived. Frequency of Detection was not used for evaluation given the size of the areas,
number of samples, and potential for varied chemical Impacts. The 95% UCL on the arithmetic mean was used as the EPC for ail COCs except for the following; 4-chlorophenyi phenyl ether and carbazole (EA1); hydrazine
(EA3); and benzo(b)fluoranthene, antimony, and hydrazine (EA7). For these COCs, the maximum concentration was used because it is lower than the calculated 95% UCL, or no 95% UCL could be calculated.
Source: A Guide to Preparing Superfuncf Proposed Plans, Records of Decision, and Other Remedy Selection Decision Documents (U.S. EPA, 1999)
Page 3 of 3
-------
ROD RISK WORKSHEET
Table G-3
OU1/2 Summary of Contaminants of Concern and Medium-Specific Exposure Point Concentration
Scenario Timeframe: Current/Future
Medium: Surface Water
Exposure Medium: Surface Water
Exposure Point
Chemical of Concern
Concentration
Units
Exposure Point
Concentration
Exposure Point
Concentration
Units
Statistical
Measure
Mean
Maximum
95% UCL
(1)
Upper South Ditch
Stream
Volatile Organics
1,3-Dichlorobenzene
0.00049
0.00057
0.00068
NP [a]
mg/L
0.00057
mg/L
Maximum
Bromodichloromethane
0.00036
0.00051
0.00044
NP [a]
mg/L
0.00044
mg/L
UCL - NP [a]
Chlorodibromomethane
0.0014
0.0038
0.0022
NP[c]
mg/L
0.0022
mg/L
UCL - NP [c]
Chloroform
0.00060
0.0012
0.00086
NP [c]
mg/L
0.00086
mg/L
UCL - NP [c]
Dibromomethane
0.00061
0.0011
0.00076
NP [c]
mg/L
0.00076
mg/L
UCL - NP [c]
Semivolatile Organics
2-Nitrophenol
0.0013
0.0018
0.0013
NP [c]
mg/L
0.0013
mg/L
UCL - NP [c]
4-Nitrophenol
0.0020
0.0021
0.0021
NP [a]
mg/L
0.0021
mg/L
Maximum
Azobenzene
0.0016
0.00053
0.00056
NP [a]
mg/L
0.00053
mg/L
Maximum
B
s(2-Ethylhexyi)phthalate
0.0019
0.0018
NC
mg/L
0.0018
mg/L
Maximum
D
phenyl ether
0.0013
0.0011
0.00089
NP [a]
mg/L
0.00089
mg/L
UCL - NP [a]
D
phenylmethanone
0.0015
0.0012
0.0010
NP [a]
mg/L
0.0010
mg/L
UCL - NP [a]
N-Nitrosodimethylamine
0.00013
0.0003
0.00019
Nig]
mg/L
0.00019
mg/L
UCL - N [g]
N-Nitrosodi-n-propyiamine
0.0000040
0.0000093
0.0000060
NP [a]
mg/L
0.0000060
mg/L
UCL - NP [a]
Metals, Total
Aluminum
5.5
280
2.6
NP [f]
mg/L
2.6
mg/L
UCL - NP [f]
Antimony
0.0031
0.0037
NC
mg/L
0.0037
mg/L
Maximum
Arsenic
0.0049
0.0035
NC
mg/L
0.0035
mg/L
Maximum
Chromium
1.2
64
0.61
NP [e]
mg/L
0.61
mg/L
UCL - NP [e]
Chromium, Hexavalent
0.074
3.8
0.23
N(e]
mg/L
0.23
mg/L
UCL - N[e]
Cobalt
0.028
0.05
0.038
N[g]
mg/L
0.038
mg/L
UCL - N [g]
Lead
0.00049
0.0012
0.00066
NP (c]
mg/L
0.00066
mg/L
UCL - NP [c]
Manganese
1.5
2.2
1.8
N [g]
mg/L
1.8
mg/L
UCL - N[g]
Mercury
0.00012
0.00029
NC
mg/L
0.00029
mg/L
Maximum
Nickel
0.031
0.057
0.042
N[g]
mg/L
0.042
mg/L
UCL - N [g]
Thallium
0.0048
0.0031
NC
mg/L
0.0031
mg/L
Maximum
Vanadium
0.0047
0.0022
NC
mg/L
0.0022
mg/L
Maximum
Inorganics
Bromide
0.30
0.48
0.39
NP [c]
mg/L
0.39
mg/L
UCL - NP [c]
Chloride
165
320
175
G[l]
mg/L
175
mg/L
UCL - G [I]
Nitrate as N
1.2
6
1.8
hp in
mg/L
1.8
mg/L
UCL - NP [f]
Nitrogen, as Ammonia
52
180
70
HP [e]
mg/L
70
mg/L
UCL - NP [e]
Sulfate
320
1300
439
NP[e]
mg/L
439
mg/L
UCL - NP [e]
Specialty Compounds
Hydrazine
0.000053
0.000076
NC
mg/L
0.000076
mg/L
Maximum
4-Nonylphenol (Tech.)
0.011
0.018
0.015
NP [c]
mg/L
0.015
mg/L
UCL - NP [c]
Kempore (Azodicarbonamide)
0.69
1.4
1.19
NP [a]
mg/L
1.2
mg/L
UCL - NP [a]
Page 1 of 7
-------
Table G-3
OU1/2 Summary of Contaminants of Concern and Medium-Specific Exposure Point Concentration
Scenario Timeframe: Current/Future
Medium: Surface Water
Exposure Medium: Surface Water
Exposure Point
Chemical of Concern
Concentration
Units
Exposure Point
Concentration
Exposure Point
Concentration
Units
Statistical
Measure
Mean
Maximum
95% UCL
«i)
Detention Basin
Semivolatile Organics
N-Nitrosodimethylamine
0.0000032
0.0000032 J
NC
mg/L
0.0000032
mg/L
Maximum
N-Nitrosodi-n-propylamine
0.0000074
0.0000032
NC
mg/L
0.0000074
mg/L
Maximum
Metals, TotaJ
Aluminum
0.90
0.9
NC
mg/L
0.90
mg/L
Maximum
Chromium
0.0068
0.0068
NC
mg/L
0.0068
mg/L
Maximum
Chromium, Hexavalent
0.010
0.01
NC
mg/L
0.010
mg/L
Maximum
Lead
0.0030
0.003
NC
mg/L
0.0030
mg/L
Maximum
Manganese
0.12
0.12
NC
mg/L
0.12
mg/L
Maximum
Nickel
0.0014
0.0014
NC
mg/L
0.0014
mg/L
Maximum
Vanadium
0.0020
0.002
NC
mg/L
0.0020
mg/L
Maximum
inorganics
Chloride
9.0
9
NC
mg/L
9.0
mg/L
Maximum
Nitrate as N
0.084
0.084
NC
mg/L
0.084
mg/L
Maximum
Nitrogen, as Ammonia
7.5
7.5
NC
mg/L
7.5
mg/L
Maximum
Sulfate
@6
96
NC
mg/L
96
mg/L
Maximum
Central Pond
Metals, Total
Aluminum
0.21
0.21
NC
mg/L
0.21
mg/L
Maximum
Chromium
0.0085
0.0085
NC
mg/L
0.0085
mg/L
Maximum
Cobalt
0.0012
0.0012
NC
mg/L
0.0012
mg/L
Maximum
Lead
0.00090
0.0009
NC
mg/L
0.00090
mg/L
Maximum
Manganese
0.70
0.70
NC
mg/L
0.70
mg/L
Maximum
Nickel
0.0053
0.0053
NC
mg/L
0.0053
mg/L
Maximum
inorganics
Bromide
0.13
0.13
NC
mg/L
0.13
mg/L
Maximum
Chloride
52
52
NC
mg/L
52
mg/L
Maximum
Nitrate as N
3.6
3.6
NC
mg/L
3.6
mg/L
Maximum
Nitrogen, as Ammonia
28
28
NC
mg/L
28
mg/L
Maximum
Sulfate
460
460
NC
mg/L
460
mg/L
Maximum
Page 2 of 7
-------
Table G-3
OU1/2 Summary of Contaminants of Concern and Medium-Specific Exposure Point Concentration
Scenario Timeframe: Current/Future
Medium: Surface Water
Exposure Medium: Surface Water
Exposure Point
Chemical of Concern
Concentration
Units
Exposure Point
Concentration
Exposure Point
Concentration
Units
Statistical
Measure
Mean
Maximum
95% UCL
(1)
Lower South Ditch
Stream
Volatile Organics
Chlorodibromomethane
0.0018
0.0034
NC
mg/L
0.0034
mg/L
Maximum
Chloroform
0.00039
0.00027
NC
mg/L
0.00027
mg/L
Maximum
Dibromomethane
0.00041
0.00032
NC
mg/L
0.00032
mg/L
Maximum
Semivolatile Organics
2-Nitrophenol
0.00074
0.00091
NC
mg/L
0.00091
mg/L
Maximum
Benzo(a)pyrene
0.00012
0.00015
NC
mg/L
0.00015
mg/L
Maximum
Bis{2-Ethylhexyl)phthalate
0.0047
0.0061
NC
mg/L
0.0061
mg/L
Maximum
Diphenylmethanone
0.0015
0.00067
NC
mg/L
0.00067
mg/L
Maximum
N-Nitrosodimethylamine
0.000099
0.00012
NC
mg/L
0.00012
mg/L
Maximum
Metals, Total
Aluminum
1.7
9.6
1.6
G[i]
mg/L
1.6
mg/L
UCL - G [i]
Arsenic
0.0041
0.0031
NC
mg/L
0.0031
mg/L
Maximum
Chromium
0.35
2.2
0.32
G[k]
mg/L
0.32
mg/L
UCL - G [k]
Chromium, Hexavalent
0.016
0.12
0.027
G [k]
mg/L
0.027
mg/L
UCL - G [k]
Cobalt
0.029
0.032
NC
mg/L
0.032
mg/L
Maximum
Lead
0.0013
0.0021
NC
mg/L
0.0021
mg/L
Maximum
Manganese
1.6
1.7
NC
mg/L
1.7
mg/L
Maximum
Nickel
0.030
0.034
NC
mg/L
0.034
mg/L
Maximum
Inorganics
Bromide
0.38
0.43
NC
mg/L
0.43
mg/L
Maximum
Chloride
155
220
171
N[g]
mg/L
171
mg/L
UCL - N[g]
Nitrate as N
1.4
3.9
1.8
G[k]
mg/L
1.8
mg/L
UCL-G fk]
Nitrogen, as Ammonia
74
250
93
N[g]
mg/L
93
mg/L
UCL - Nig]
Sulfate
447
1200
546
Nig]
mg/L
546
mg/L
UCL-Nig]
Specialty Compounds
Hydrazine
0.000065
0.00008
NC
mg/L
0.000080
mg/L
Maximum
4-Nonylpheno! (Tech.)
0.0059
0.0062
NC
mg/L
0.0062
mg/L
Maximum
Kempore (Azodicarbonamide)
0.85
1.2
NC
mg/L
1.2
mg/L
Maximum
Page 3 of 7
-------
Table G-3
OU1/2 Summary of Contaminants of Concern and Medium-Specific Exposure Point Concentration
Scenario Timeframe: Current/Future
Medium: Surface Water
Exposure Medium: Surface Water
Exposure Point
Chemical of Concern
Concentration
Units
Exposure Point
Concentration
Exposure Point
Concentration
Units
Statistical
Measure
Mean
Maximum
95% UCL
(1)
Off-Property West Ditch
Stream
Semivolatile Organics
3 & 4 Methyiphenol
0.0018
0.00076
0.00078
NP [a]
mg/L
0.00076
mg/L
Maximum
4-Nitrophenol
0.0020
0.00075
NC
mg/L
0.00075
mg/L
Maximum
Benzo(a)anthracene
0.00047
0.002
NC
mg/L
0.0020
mg/L
Maximum
Benzo(a)pyrene
0.00089
0.0042
0.0023
NP [a]
mg/L
0.0023
mg/L
UCL - NP [a]
Benzo(b)fluoranthene
0.0016
0.0077
0.0042
NP [a]
mg/L
0.0042
mg/L
UCL - NP [a]
Benzo(k)fluorarithene
0.00061
0.0026
NC
mg/L
0.0026
mg/L
Maximum
Chrysene
0.0012
0.0053
0.0029
NP [a]
mg/L
0.0029
mg/L
UCL - NP [a]
Dibenz{a,h)anthracene
0.00039
0.0012
NC
mg/L
0.0012
mg/L
Maximum
lndeno{1,2,3-cd)pyrene
0.00088
0.004
0.0023
NP [a]
mg/L
0.0023
mg/L
UCL - NP [a]
N-Nitrosodimethylamine
0.000049
0.00011
0.000076
NP(c]
mg/L
0.000076
mg/L
UCL - NP [c]
Pyrene
0.0031
0.012
0.0065
HP [a]
mg/L
0.0065
mg/L
UCL - NP [a]
Metals, Total
Aluminum
0.82
1.6
1.3
N[0]
mg/L
1.3
mg/L
UCL - N[g]
Arsenic
0.0060
0.012
0.0087
NP [a]
mg/L
0.0087
mg/L
UCL - NP [a]
Chromium
0.050
0.13
0.093
N|g]
mg/L
0.093
mg/L
UCL - N[g]
Chromium, Hexavalent
0.0024
0.0071
0.0078
N[e]
mg/L
0.0071
mg/L
Maximum
Cobalt
0.0097
0.018
0.015
N[g]
mg/L
0.015
mg/L
UCL - N[g]
Lead
0.0027
0.0058
0.0043
N[g]
mg/L
0.0043
mg/L
UCL - N [g]
Manganese
0.85
1.5
1.3
N[g]
mg/L
1.3
mg/L
UCL - N[g]
Nickel
0.0090
0.018
0.013
N[g]
mg/L
0.013
mg/L
UCL - N[g]
Vanadium
0.0057
0.012
0.0087
NP [a]
mg/L
0.0087
mg/L
UCL - NP [a]
inorganics
Bromide
0.15
0.21
0.19
NP [c]
mg/L
0.19
mg/L
UCL - NP [c]
Chloride
139
180
176
N[g]
mg/L
176
mg/L
UCL - N [g]
Nitrate as N
0.032
0.069
NC
mg/L
0.069
mg/L
Maximum
Nitrogen, as Ammonia
45
66
60
N[g]
mg/L
60
mg/L
UCL - N [g]
Sulfate
211
360
318
N [g]
mg/L
318
mg/L
UCL - N[g]
Page 4 of 7
-------
Table G-3
OU1/2 Summary of Contaminants of Concern and Medium-Specific Exposure Point Concentration
Scenario Timeframe: Current/Future
Medium: Surface Water
Exposure Medium: Surface Water
Exposure Point
Chemical of Concern
Concentration
Units
Exposure Point
Concentration
Exposure Point
Concentration
Units
Statistical
Measure
Mean
Maximum
95% UCL
(1)
East Ditch Stream
Volatile Organics
Cis-1,2-Dichloroethene
0.0015
0.0061
0.0029
NP (a]
mg/L
0.0029
mg/L
UCL - NP [a]
Trichloroethene
0.0011
0.0034
0.0017
NP [a]
mg/L
0.0017
mg/L
UCL - NP [a]
Vinyl chloride
0.00028
0.00052
NC
mg/L
0.00052
mg/L
Maximum
Xylenes (m&p)
0.0010
0.00052
NC
mg/L
0.00052
mg/L
Maximum
Semivolatile Organics
Bis(2-Ethylhexyl)phthalate
0.0010
0.0015
0.0016
NP [a]
mg/L
0.0015
mg/L
Maximum
Dibenz{a,h)anthracene
0.00020
0.00018
0.00017
NP [a]
mg/L
0.00017
mg/L
UCL - NP [a]
lndeno(1,2,3-cd)pyrene
0.00020
0.00017
0.00017
NP [a]
mg/L
0.00017
mg/L
Maximum
N-Nitrosodimethylamine
0.0000045
0.000012
0.0000069
NP [a]
mg/L
0.0000069
mg/L
UCL - NP [a]
N-Nitrosodi-n-propylamine
0.0000021
0.0000033
NC
mg/L
0.0000033
mg/L
Maximum
Metals, Total
Aluminum
0.16
0.77
0.19
G [i]
mg/L
0.19
mg/L
UCL - G [i]
Arsenic
0.0053
0.0078
0.0090
NP [a]
mg/L
0.0078
mg/L
Maximum
Chromium
0.0055
0.065
0.011
NP [b]
mg/L
0.011
mg/L
UCL - NP [b]
Chromium, Hexavalent
0.00028
0.00086
0.00047
NP [e]
mg/L
0.00047
mg/L
UCL - NP [e]
Cobalt
0.0036
0.0024
0.0024
NP la]
mg/L
0.0024
mg/L
UCL - NP [a]
Lead
0.00051
0.0015
0.00075
NP [c]
mg/L
0.00075
mg/L
UCL - NP [c]
Manganese
0.41
0.91
0.59
N[g]
mg/L
0.59
mg/L
UCL - N [g]
Nickel
0.0040
0.0039
0.0036
NP [c]
mg/L
0.0036
mg/L
UCL - NP [c]
Thallium
0.0050
0.0052
NC
mg/L
0.0052
mg/L
Maximum
Vanadium
0.0048
0.0025
NC
mg/L
0.0025
mg/L
Maximum
inorganics
Bromide
0.069
0.18
0.13
NP [a]
mg/L
0.13
mg/L
UCL - NP [a]
Chloride
170
360
192
N[g]
mg/L
192
mg/L
UCL - N [g]
Nitrate as N
1.0
2.6
1.2
N [g]
mg/L
1.2
mg/L
UCL - N[g]
Nitrogen, as Ammonia
2.7
10
4.5
G ID
mg/L
4.5
mg/L
UCL - G 0]
Sulfate
36
99
46
LN [h]
mg/L
46
mg/L
UCL - LN [h]
Specialty Compounds
Kempore (Azodicarbonamide)
1.0
4.1
2.1
NP [a]
mg/L
2.1
mg/L
UCL - NP [a]
Page 5 of 7
-------
Table G-3
OU1/2 Summary of Contaminants of Concern and Medium-Specific Exposure Point Concentration
Scenario Timeframe: Current/Future
Medium: Surface Water
Exposure Medium: Surface Water
Exposure Point
Chemical of Concern
Concentration
Units
Exposure Point
Concentration
Exposure Point
Concentration
Units
Statistical
Measure
Mean
Maximum
95% UCL
(1)
Maple Meadow Brook
Volatile Organics
Cis-1,2-Dichloroethene
0.00049
0.00062
0.00077
NP[a]
mg/L
0.00062
mg/L
Maximum
Trichloroethene
0.00050
0.0004
NC
mg/L
0.00040
mg/L
Maximum
Semivolatile Organics
3 &4 Methyiphenol
0.0022
0.00074
NC
mg/L
0.00074
mg/L
Maximum
Benzo(a)pyrene
0.000094
0.00013
0.00014
NP [a]
mg/L
0.00013
mg/L
Maximum
Benzo(b)fluoranthene
0.QQ014
0.00013
NC
mg/L
0.00013
mg/L
Maximum
lndeno(1,2,3-cd)pyrene
0.Q0023
0.0002
NC
mg/L
0.00020
mg/L
Maximum
N-Nitrosodimethylamine
0.0000041
0.00000047
NC
mg/L
0.00000047
mg/L
Maximum
N-Nitrosodi-n-propylamine
0.0000041
0.00000078
0.00000080
NP [a]
mg/L
0.00000078
mg/L
Maximum
Metals, Total
Aluminum
0.17
1.8
0.68
NP [d]
mg/L
0.68
mg/L
UCL - NP [d]
Arsenic
0.0050
0.0048
0.0049
NP [a]
mg/L
0.0048
mg/L
Maximum
Chromium
0.0024
0.00098
NC
mg/L
0.00098
mg/L
Maximum
Chromium, Hexavalent
0.00026
0.000275
0.00028
N[g]
mg/L
0.00028
mg/L
Maximum
Cobalt
0.0046
0.0077
0.0051
NP [a]
mg/L
0.0051
mg/L
UCL - NP [a]
Lead
0.0065
0.11
0.038
NP [d]
mg/L
0.038
mg/L
UCL - NP [d]
Manganese
0.91
9.3
2.7
NP [e]
mg/L
2.7
mg/L
UCL - NP [e]
Nickel
0.0046
0.0072
0.0052
NP [c]
mg/L
0.0052
mg/L
UCL - NP [c]
Thallium
0.0051
0.0066
NC
mg/L
0.0066
mg/L
Maximum
Vanadium
0.0048
0.0037
0.0045
NP [a]
mg/L
0.0037
mg/L
Maximum
Inorganics
Bromide
0.055
0.12
0.10
NP [a]
mg/L
0.10
mg/L
UCL - NP [a]
Chloride
121
220
138
N [g]
mg/L
138
mg/L
UCL - N[g]
Nitrate as N
0.19
0.6
0.26
NP [c]
mg/L
0.26
mg/L
UCL - NP [c]
Nitrogen, as Ammonia
0.30
2.5
0.56
NP [b]
mg/L
0.56
mg/L
UCL - NP [b]
Sulfate
15.1
39
18.3
N[g]
mg/L
18.3
mg/L
UCL - N [g]
Specialty Compounds
Hydrazine
0.000050
0.00006
NC
mg/L
0.000060
mg/L
Maximum
Kempore (Azodicarbonamide)
0.55
0.71
NC
mg/L
0.71
mg/L
Maximum
Page 6 of 7
-------
Table G-3
OU1/2 Summary of Contaminants of Concern and Medium-Specific Exposure Point Concentration
Scenario Timeframe:
Current/Future
Medium: Surface Water
Exposure Medium: Surface Water
Exposure Point
Chemical of Concern
Concentration
Units
Exposure Point
Concentration
Exposure Point
Concentration
Statistical
Measure
Mean
Maximum
95% UCL
Units
(1)
North Pond
Semivolatile Organics
Benzo(a)anthracene
0.00012
0.00012
0.00015
NP la]
mg/L
0.00012
mg/L
Maximum
Benzo(a)pyrene
0.00012
0.00017
0.00020
NP la]
mg/L
0.00017
mg/L
Maximum
Benzo(b)fluoranthene
0.00019
0.00027
0.00031
NP [a]
mg/L
0.00027
mg/L
Maximum
Benzo(k)fluoranthene
0.00013
0.00015
0.00020
NP [a]
mg/L
0.00015
mg/L
Maximum
Bis(2-Ethylhexyl)phthalate
0.0010
0.0026
0.0023
N[g]
mg/L
0.0023
mg/L
UCL - N [g]
Chrysene
0.00036
0.00029
0.00035
NP [a]
mg/L
0.00029
mg/L
Maximum
Pyrene
0.00080
0.00039
0.00051
NP [a]
mg/L
0.00039
mg/L
Maximum
Metals, Total
Aluminum
0.15
0.22
0.24
NP [a]
mg/L
0.22
mg/L
Maximum
Chromium
0.0025
0.0043
0.0041
Nig]
mg/L
0.0041
mg/L
UCL - N lg]
Lead
0.00093
0.0013
0.0015
Nig]
mg/L
0.0013
mg/L
Maximum
Manganese
0.39
0.49
0.48
Nig]
mg/L
0.48
mg/L
UCL - N[g]
Nickel
0.0026
0.0025
0.0026
NP la]
mg/L
0.0025
mg/L
Maximum
Inorganics
Bromide
0.28
0.65
0.64
NP [a]
mg/L
0.64
mg/L
UCL - NP [a]
Chloride
190
320
301
Nig]
mg/L
301
mg/L
UCL - Nig]
Nitrate as N
0.11
0.24
0.22
NP (a]
mg/L
0.22
mg/L
UCL - NP [a]
Nitrogen, as Ammonia
0.077
0.10
0.13
NP (a]
mg/L
0.10
mg/L
Maximum
Sulfate
8.4
15
14.5
N[g]
mg/L
14.5
mg/L
UCL - N[g]
Key
(1) Statistics: Maximum Detected Value (maximum); 95% UCL; Arithmetic Mean (Mean)
NC - Not Calculated
UCL - Upper Confidence Limit
J - estimated value
mg/L - milligrams per liter
NP - Nonparametric distribution
N - Normal distribution
G - Gamma Distribution
[a] 95% KM (t) UCL
[g] 95% Student
s-t UCL
li] 95% GROS Adjusted Gamma UCL
[b] 95% KM (BCA) UCL
0] 95% Adjusted Gamma KM-UCL
[c] 95% KM (Percentile Bootstrap) UCL
LN - Lognormai distribution
[k] 95% Adjusted Gamma UCL
[d] 97.5% KM (Chebyshev) UCL
[h] 95% H-UCL
[I] 95% Approximate Gamma UCL
[a] 95% Chebyshev (Mean, Sd) UCL
[f] 95% KM (Chebyshev) UCL
The table represents the current/future chemical of concern (COC) and exposure point concentration (EPC) for the COCs in surface water (i.e., the concentration that will be used to estimate the exposure and risk for
the COC in surface water). The table includes the range of concentrations detected for the COCs, the EPC, and how the EPC was derived. Frequency of Detection was not used for evaluation given the size of the
areas, number of samples, and potential for varied chemical impacts. The 95% UCL on the arithmetic mean was used as the EPC for all COCs except for the following: 1,3-dichlorobenzene, 4-nitrophenol. azobenzene,
bis(2-ethylhexyl)phthalate, antimony, arsenic, mercury, thallium, vanadium, and hydrazine (Upper South Ditch Stream): 3 & 4 methylphenol, nitrophenol, benzo(a)anthracene, benzo(k)fluoranthene,
dibenz(a,h)anthracene, hexavalent chromium, and nitrate (Off-Property West Ditch Stream); vinyl chloride, m&p xylenes, bis(2-ethylhexyl)phthalate, indeno(1,2,3-cd)pyrene, n-nitrosodi-n-propylamine, arsenic, thallium,
and vanadium (East Ditch Stream); cis-1,2-dichloroethene, trichloroethene, 3&4 methylphenol, benzo(a)pyrene, benzo(b)fluoranthene, indeno(1,2,3-cd)pyrene, n-nitrosodimethylamine, n-nitrosodi-n-propylamine,
arsenic, chromium, hexavalent chromium, thallium, vanadium, hydrazine, and kempore (Maple Meadow Brook); benzo(a)anthracene, benzo(a)pyrene, benzo(b)fluoranthene, benzo(k)fiuoranthene, chrysene, pyrene,
aluminum, lead, nickel, and ammonia (North Pond) and ail COCs at the Detention Basin, Central Pond, and Lower South Ditch Stream. For these COCs, the maximum concentration was used because it is lower than
the calculated 95% UCL, or no 95% UCL could be calculated.
Source: A Guide to Preparing Superfund Proposed Plans, Records of Decision, and Other Remedy Selection Decision Documents (U.S. EPA, 1999)
Page 7 of 7
-------
ROD RISK WORKSHEET
Table G-4
OU1/2 Summary of Contaminants of Concern and Medium-Specific Exposure Point Concentration
Scenario Timeframe: Current/Future
Medium: Sediment
Exposure Medium: Sediment
Exposure Point
Chemical of Concern
Concentration
Units
Exposure Point
Concentration
Exposure Point
Concentration
Units
Statistical
Measure
Mean
Maximum
95% UCL
(1)
On Property West Ditch
Stream
Semivoiatile Organics
Benzo(b)fluoranthene
2.1
3
NC
mg/Kg
3
mg/Kg
Maximum
Bis(2-Ethylhexyl)phthalate
4.2
14
5.7
NP [a]
mg/Kg
5.7
mg/Kg
UCL - NP[a]
Metals
Arsenic
3.3
7.77
NC
mg/Kg
7.8
mg/Kg
Maximum
Chromium, Hexavalent
4.1
11.0
4.7
G if]
mg/Kg
4.7
mg/Kg
UCL - G [f]
Manganese
13.0
22
NC
mg/Kg
22
mg/Kg
Maximum
Upper South Ditch
Stream
Volatile Organics
4-iso-Propyltoluene
0.0018
0.0026 J
NC
mg/Kg
0.0026
mg/Kg
Maximum
Semivolatile Organics
Benzo{a)anthracene
0.21
0.51
0.35
NP [a]
mg/Kg
0.35
mg/Kg
UCL - NP[a]
Benzo{a)pyrene
0.095
0.13
0.11
NP [b]
mg/Kg
0.11
mg/Kg
UCL - NP [b]
Benzo{b)fluoranthene
0.099
0.16
0.12
NP [b]
mg/Kg
0.12
mg/Kg
UCL - NP[b]
B
s(2-Ethylhexyl)phthalate
42
210
707
G[f]
mg/Kg
210
mg/Kg
Maximum
D
benz(a,h)anthracene
0.078
0.048
0.048
NP [a]
mg/Kg
0.048
mg/Kg
Maximum
D
phenyl ether
0.15
0.22
0.22
NP [a]
mg/Kg
0.22
mg/Kg
UCL - NP[a]
D
phenylmethanone
0.098
0.0305
NC
mg/Kg
0.031
mg/Kg
Maximum
Metals
Arsenic
5.3
13
8.6
N [e]
mg/Kg
8.6
mg/Kg
UCL - N [e]
Chromium, Hexavalent
7.0
25
15.5
NP [a]
mg/Kg
15.5
mg/Kg
UCL - NP [a]
Cobalt
4.5
5.5
5.2
N [e]
mg/Kg
5.2
mg/Kg
UCL ~ N [e]
Manganese
121
270
211
N [e]
mg/Kg
211
mg/Kg
UCL - N [e]
Inorganics
Chloride
74
140
127
N [e]
mg/Kg
127
mg/Kg
UCL - N [e]
Nitrogen, as Ammonia
148
240
215
N [e]
rug/Kg
215
mg/Kg
UCL - N [e]
Sulfate
454
640
695
N [e]
mg/Kg
640
mg/Kg
Maximum
Petroleum Hydrocarbons
C11-C22 Aromatics
288
1100
925
N [e]
mg/Kg
925
mg/Kg
UCL - N [e]
C19-C36 Aliphatics
194
690
583
N [e]
mg/Kg
583
mg/Kg
UCL - N [e]
Page 1 of 5
-------
Table G-4
OU1/2 Summary of Contaminants of Concern and Medium-Specific Exposure Point Concentration
Scenario Timeframe: Current/Future
Medium: Sediment
Exposure Medium: Sediment
Exposure Point
Chemical of Concern
Concentration
Units
Exposure Point
Concentration
Exposure Point
Concentration
Units
Statistical
Measure
Mean
Maximum
95% UCL
a)
Detention Basin
Semivolatile Organics
Benzo(a)pyrene
0.24
0.22
NC
mg/Kg
0.22
mg/Kg
Maximum
Bis{2-Ethylhexyl)phthalate
2.3
3.1
NC
mg/Kg
3.1
mg/Kg
Maximum
Metals
Arsenic
10.7
12
NC
mg/Kg
12.0
mg/Kg
Maximum
Cobalt
4.7
4.8
NC
mg/Kg
4.8
mg/Kg
Maximum
Manganese
420
440
NC
mg/Kg
440
mg/Kg
Maximum
Inorganics
Chloride
9.7
13
NC
mg/Kg
13.0
mg/Kg
Maximum
Nitrogen, as Ammonia
18.0
22
NC
mg/Kg
22
mg/Kg
Maximum
Sulfate
1400
1900
NC
mg/Kg
1900
mg/Kg
Maximum
Central Pond
Semivolatile Organics
Benzo{b)fluoranthene
0.19
0.14
NC
mg/Kg
0.14
mg/Kg
Maximum
Metals
Arsenic
7.2
8.1
NC
mg/Kg
8.1
mg/Kg
Maximum
Chromium, Hexavalent
5.1
22.4
12.6
0 [f]
mg/Kg
12.6
mg/Kg
UCL - G [f]
Cobalt
4.0
4
NC
mg/Kg
4.0
mg/Kg
Maximum
Manganese
515
590
NC
mg/Kg
590
mg/Kg
Maximum
Inorganics
Chloride
21
24
NC
mg/Kg
24
mg/Kg
Maximum
Nitrogen, as Ammonia
26
35
NC
mg/Kg
35
mg/Kg
Maximum
Sulfate
855
1200
NC
mg/Kg
1200
mg/Kg
Maximum
Page 2 of 5
-------
Table G-4
OU1/2 Summary of Contaminants of Concern and Medium-Specific Exposure Point Concentration
Scenario Timeframe: Current/Future
Medium: Sediment
Exposure Medium: Sediment
Exposure Point
Chemical of Concern
Concentration
Units
Exposure Point
Concentration
Exposure Point
Concentration
Units
Statistical
Measure
Mean
Maximum
95% UCL
(1)
Lower South Ditch
Stream
Semivolatile Organics
Benzo(a)anthracene
2.0
3.1
NC
mg/Kg
3.1
mg/Kg
Maximum
Benzo(a)pyrene
0.98
0.099
NC
mg/Kg
0.099
mg/Kg
Maximum
B
s(2-Ethylhexyl)phthalate
560
920
1112
N [e]
mg/Kg
920
mg/Kg
Maximum
D
benz(a,h)anthracene
1.0
0.26 J
NC
mg/Kg
0.26
mg/Kg
Maximum
D
phenyl ether
2.7
2.6
NC
mg/Kg
2.6
mg/Kg
Maximum
Metals
Arsenic
6.4
6.7
6.8
N [e]
mg/Kg
6.7
mg/Kg
Maximum
Chromium, Hexavalent
172
480
622
N [e]
mg/Kg
480
mg/Kg
Maximum
Cobait
15.6
21
26
N[e]
mg/Kg
21
mg/Kg
Maximum
Manganese
68
87
100
N [e]
mg/Kg
87
mg/Kg
Maximum
Inorganics
Chloride
130
130
NC
mg/Kg
130
mg/Kg
Maximum
Nitrogen, as Ammonia
227
290 J
328
N [e]
mg/Kg
290
mg/Kg
Maximum
Sulfate
715
830
NC
mg/Kg
830
mg/Kg
Maximum
Petroleum Hydrocarbons
C11-C22 Aromatics
9,400
9400
NC
mg/Kg
9400
mg/Kg
Maximum
C19-C36 Aliphatics
6,400
6400
NC
mg/Kg
6400
mg/Kg
Maximum
Off-Property West Ditch
Stream
Semivolatile Organics
4-Chlorophenyl phenyl ether
0.044
0.061 J
NC
mg/Kg
0.061
mg/Kg
Maximum
Benzo(a)anthracene
0.14
0.17
0.20
N [e]
mg/Kg
0.17
mg/Kg
Maximum
Benzo(a)pyrene
0.17
0.2
0.23
N [e]
mg/Kg
0.20
mg/Kg
Maximum
Benzo(b)fluoranthene
0.31
0.31
NC
mg/Kg
0.31
mg/Kg
Maximum
Bis(2-Ethylhexyl)phthalate
0.092
0.12 J
0.16
N [e]
mg/Kg
0.12
mg/Kg
Maximum
Carbazole
0.045
0.051 J
0.055
N [e]
mg/Kg
0.051
mg/Kg
Maximum
Dibenz(a,h)anthracene
0.048
0.061 J
NC
mg/Kg
0.061
mg/Kg
Maximum
Diphenyl ether
0.33
0.86 J
3.3
NP [c]
mg/Kg
0.86
mg/Kg
Maximum
Diphenylmethanone
0.091
0.2 J
0.50
NP[d]
mg/Kg
0.20
mg/Kg
Maximum
Metals
Arsenic
10.0
14
16.2
N [e]
mg/Kg
14
mg/Kg
Maximum
Chromium, Hexavalent
89
224
288
N [e]
mg/Kg
224
mg/Kg
Maximum
Cobalt
7.5
15 J
18.5
NW
mg/Kg
15
mg/Kg
Maximum
Manganese
85
160 J
195
N [e]
mg/Kg
160
mg/Kg
Maximum
Inorganics
Chloride
147
240
284
N [e]
mg/Kg
240
mg/Kg
Maximum
Nitrogen, as Ammonia
254
540 J
673
N[e)
mg/Kg
540
mg/Kg
Maximum
Sulfate
697
1500
1870
N [e]
mg/Kg
1500
mg/Kg
Maximum
Page 3 of 5
-------
Table G-4
OU1/2 Summary of Contaminants of Concern and Medium-Specific Exposure Point Concentration
Scenario Timeframe: Current/Future
Medium: Sediment
Exposure Medium: Sediment
Exposure Point
Chemical of Concern
Concentration
Units
Exposure Point
Concentration
Exposure Point
Concentration
Units
Statistical
Measure
Mean
Maximum
95% UCL
(1)
East Ditch Stream
Semivolatile Organics
Benzo(a)anthracene
0.55
0.77 J
1.0
N[e]
mg/Kg
0.77
mg/Kg
Maximum
Benzo(a)pyrene
0.62
0.94 J
1.2
N [e]
mg/Kg
0.94
mg/Kg
Maximum
Benzo(b)fluoranthene
1.0
1.6 J
2.0
N [e]
mg/Kg
1.60
mg/Kg
Maximum
Bis(2-Ethylhexyl)phthalate
4.2
10 J
12.7
N[e]
mg/Kg
10
mg/Kg
Maximum
Carbazole
0.20
0.24 J
NC
mg/Kg
0.24
mg/Kg
Maximum
Dibenz(a,h)anthracene
0.15
0.037 J
NC
mg/Kg
0.037
mg/Kg
Maximum
Dipheny! ether
0.20
0.28 J
NC
mg/Kg
0.28
mg/Kg
Maximum
Metals
Arsenic
178
450 J
576
N[e]
mg/Kg
450
mg/Kg
Maximum
Chromium, Hexavalent
7.9
12.5
14.7
N [e]
mg/Kg
12.5
mg/Kg
Maximum
Cobalt
16.7
30 J
37
N [e]
mg/Kg
30
mg/Kg
Maximum
Manganese
1,343
3200 J
4072
N[e]
mg/Kg
3200
mg/Kg
Maximum
Inorganics
Chloride
257
690
890
N [e]
mg/Kg
690
mg/Kg
Maximum
Nitrogen, as Ammonia
50
130
167
N [e]
mg/Kg
130
mg/Kg
Maximum
Sulfate
58
71
NC
mg/Kg
71
mg/Kg
Maximum
Maple Meadow Brook
Semivolatile Organics
4-Nitrophenol
0.43
0.091 J
NC
mg/Kg
0.091
mg/Kg
Maximum
Benzo{a)anthracene
0.13
0.4 J
0.17
NP [a]
mg/Kg
0.17
mg/Kg
UCL - NP [a]
Benzo(a)pyrene
0.13
0.4 J
0.17
NP [b]
mg/Kg
0.17
mg/Kg
UCL - NP[b]
Benzo(b)fluoranthene
0.16
0.56 J
0.23
NP [b]
mg/Kg
0.23
mg/Kg
UCL - NP[b]
Bis(2-Ethylhexyl)phthalate
0.15
0.35 J
0.20
NP [b]
mg/Kg
0.20
mg/Kg
UCL - NP[b]
Carbazole
0.093
0.097 J
0.082
NP [a]
mg/Kg
0.082
mg/Kg
UCL - NP[a]
Dibenz(a,h)anthracene
0.094
0.15 J
0.10
NP [a]
mg/Kg
0.10
mg/Kg
UCL - NP[a]
Metals
Arsenic
17.2
52 J
23.8
N [e]
mg/Kg
24
mg/Kg
UCL - N [e]
Chromium, Hexavalent
3.5
6.4
4.5
N[e]
mg/Kg
4.5
mg/Kg
UCL - N [e]
Cobalt
12.7
34 J
18.1
N[e]
mg/Kg
18.1
mg/Kg
UCL - N [e]
Manganese
788.46
2100 J
1358
G[f]
mg/Kg
1358
mg/Kg
UCL - G [f]
Thallium
2.6
1.4 J
NC
mg/Kg
1.4
mg/Kg
Maximum
Inorganics
Chloride
485
1000
658
N [e]
mg/Kg
658
mg/Kg
UCL - N [e]
Nitrogen, as Ammonia
567
1500 J
771
N [e]
mg/Kg
771
mg/Kg
UCL-N [e]
Sulfate
600
1400 J
800
NP [b]
mg/Kg
800
mg/Kg
UCL - NP[b]
Page 4 of 5
-------
Table G-4
OU1/2 Summary of Contaminants of Concern and Medium-Specific Exposure Point Concentration
Scenario Timeframe: Current/Future
Medium: Sediment
Exposure Medium: Sediment
Exposure Point
Chemical of Concern
Concentration
Units
Exposure Point
Concentration
Exposure Point
Concentration
Statistical
Measure
Mean
Maximum
95% UCL
Units
(1)
North Pond
Semivolatile Organics
Benzo(a)anthracene
0.46
0.66
0.79
NP [a]
mg/Kg
0.66
mg/Kg
Maximum
Benzo(a)pyrene
0.44
0.7
0.75
NP [a]
mg/Kg
0.70
mg/Kg
Maximum
Benzo(b)fluoranthene
0.70
1.1
1.2
NP [a]
mg/Kg
1.1
mg/Kg
Maximum
Bis(2~Ethylhexyl)phthalate
1.8
3.7 J
NC
mg/Kg
3.7
mg/Kg
Maximum
Carbazole
0.34
0.16 J
NC
mg/Kg
0.16
mg/Kg
Maximum
Metals
Arsenic
8.3
13
13.6
NP [a]
mg/Kg
13.0
mg/Kg
Maximum
Chromium, Hexavalent
0.59
0.9
0.99
N [e]
mg/Kg
0.90
mg/Kg
Maximum
Cobait
6.7
9
9.1
N[e]
mg/Kg
9.0
mg/Kg
Maximum
Manganese
420
1250
1071
N [e]
mg/Kg
1071
mg/Kg
UCL - N [e]
Thallium
0.76
0.82 J
NC
mg/Kg
0.82
mg/Kg
Maximum
Inorganics
Chloride
184
320
333
N[e]
mg/Kg
320
mg/Kg
Maximum
Nitrogen, as Ammonia
12.2
23
24
N [e]
mg/Kg
23
mg/Kg
Maximum
Sulfate
183
270
327
NP [a]
mg/Kg
270
mg/Kg
Maximum
Key
(1) Statistics: Maximum Detected Value (maximum); 95% UCL; Arithmetic Mean (Mean)
NC - Not Calculated
J - estimated value
UCL - Upper Confidence Limit
mg/kg - milligrams per kilogram
NP - Nonparametric distribution
N - Normal distribution
[a] 95% KM (t) UCL
[e] 95% Student's-t UCL
[b] 95% KM (Percentile Bootstrap) UCL
[c] 99% KM (Chebyshev) UCL
G - Gamma Distribution
[d] 97.5% KM (Chebyshev) UCL
[f] 95% Adjusted Gamma UCL
The table represents the current/future chemical of concern (COC) and exposure point concentration (EPC) for the COCs in sediment (i.e., the concentration that will be used to estimate the exposure and risk for the
COC in sediment). The table includes the range of concentrations detected for the COCs, the EPC, and how the EPC was derived. Frequency of Detection was not used for evaluation given the size of the areas,
number of samples, and potential for varied chemical impacts. The 95% UCL on the arithmetic mean was used as the EPC for ail COCs except for the following: benzo(b)f!uoranthene, arsenic, and manganese (On-
Property West Ditch Stream); 4-iso-propyltoluene, bis(2-ethylhexyl)phthalate, dibenz(a,h)anthracene, diphenylmethanone. and sulfate (Upper South Ditch Stream); benzo(b)fluoranthene, arsenic, cobalt, manganese,
chloride, ammonia, and sulfate (Central Pond); 4-nitrophenol and thallium (Maple Meadow Brook); benzo(a)anthracene, benzo(a)pyrene, benzo(b)f!uoranthene, bis(2-ethylhexyl)phthalate, carbazole, arsenic,
hexavalent chromium, cobalt, thallium, chloride, ammonia, and sulfate (North Pond) and all COCs at the Detention Basin, Lower South Ditch Stream, Off-Property West Ditch Stram, and East Ditch Stream. For these
COCs, the maximum concentration was used because it is lower than the calculated 95% UCL, or no 95% UCL could be calculated.
Source: A Guide to Preparing Superfund Proposed Plans, Records of Decision, and Other Remedy Selection Decision Documents (U.S. EPA, 1999)
Page 5 of 5
-------
ROD RISK WORKSHEET
Table G-5
OU1/2 Cancer Toxicity Data Summary
Pathway: Ingestion, Dermal
Chemical of
Oral Cancer
Dermal Cancer
Slope Factor
Weight of
Concern
Slope Factor
Slope Factor
Units
Evidence/Cancer
Source
Date
Guideline Description
VOLATILES
1,2-Dichloroethene (cis)
ND
ND
Inadequate evidence
IRIS
July-13
2,4,4-Trimethyl-1-pentene
NA
NA
ND
July-13
2,4,4-T rimethyl-2-pentene
NA
NA
ND
July-13
4-iso-Propyltoluene
NA
ND
ND
July-13
Bromodichloromethane
6.2E-02
6.2E-02
(mg/kg-day)"1
B2
IRIS
July-13
Chlorodibrornomethane
8.4E-02
8.4E-02
(mg/kg-day)'1
C
IRIS
July-13
Chloroform
3.1E-02
3.1E-02
(mg/kg-day)"1
B2 [a]
CALEPA
July-13
Dibromomethane
ND
ND
Inadequate evidence
PPRTV
July-13
Trichioroethene
4.6E-02
4.6E-02
(mg/kg-day)"1
Carcinogenic to humans
IRIS
July-13
v/fnyl Chloride (child and adult)
1.4E+00
1.4E+00
(mg/kg-day)"1
Known carcinogen
IRIS
July-13
Xylenes (total)
NA
NA
Inadequate evidence
IRIS
NP
SEMIVOLATILES
1,3-Dichlorobenzene
ND
ND
D
IRIS
September-11
2-Nitrophenol
ND
ND
Inadequate evidence
PPRTV
July-13
4-Bromophenyl-phenylether
NA
NA
D
IRIS
NP
4-Methylphenot (p-Creso!)
NA
NA
C
IRIS
NP
4-Nitrophenol
ND
ND
July-13
<\zobenzene
1.1E-01
1.1E-01
(mg/kg-day)"
B2
IRIS
July-13
Benzo(a)anthracene
7.3E-01
7.3E-01
(mg/kg-day)"1
B2
NCEA
Juiy-13
Benzo(a)pyrene
7.3E+00
7.3E+00
(mg/kg-day)"1
B2
IRIS
July-13
Benzo(b)fluoranthene
7.3E-01
7.3E-01
(mg/kg-day)'1
B2
NCEA
July-13
Benzo(k)fluoranthene
7.3E-02
7.3E-02
(mg/kg-day)"1
B2
NCEA
July-13
Bis(2-ethylhexyl)phthalate (BEHP)
1.4E-02
1.4E-02
(mg/kg-day)"
B2
IRIS
July-13
Carb azote
2.0E-02
2.0E-02
(mg/kg-day)"
B2
HEAST
July-13
Qhrysene
7.3E-03
7.3E-03
(mg/kg-day)"
B2
NCEA
July-13
Diberizo{a,h)anthracene
7.3E+00
7.3E+00
(mg/kg-day)"
B2
NCEA
July-13
Dimethylphthalate
NA
ND
D
IRIS
July-13
Diphenyi ether
NA
NA
July-13
Diphenylmethanone
NA
NA
July-13
Hydrazine
3.0E+00
3.0E+00
(mg/kg-day)"1
B2
IRIS
July-13
lndeno(1,2,3-cd)pyrene
7.3E-01
7.3E-01
(mg/kg-day)"
B2
NCEA
July-13
n-Nitrosodimethylamine
5.1E+01
5.1E+01
(mg/kg-day)"1
B2
IRIS
July-13
n-Nitrosodi-n-propylamine
7.0E+00
7.0E+00
(mg/kg-day)"1
B2
IRIS
July-13
n-Nitrosodiphenyiamine
4.9E-03
4.9E-Q3
(mg/kg-day)"
B2
IRIS
July-13
Phenanthrene
NA
NA
D
IRIS
July-13
Pyrene
ND
NA
D
IRIS
July-13
Page 1 of 4
-------
Table G-5
OU1/2 Cancer Toxicity Data Summary
Pathway: Ingestion, Dermal
Chemical of
Oral Cancer
Dermal Cancer
Slope Factor
Weight of
Concern
Slope Factor
Slope Factor
Units
Evidence/Cancer
Source
Date111
Guideline Description
PESTIClDES/PCBs
delta-BHC
NA
ND
D
IRIS
July-13
Arocfor 1260
2.0E+00
2.0E+00
{mg/kg-dayj1
See PCBs
IRIS
July-13
INORGANICS/METALS
Aluminum
ND
ND
Inadequate evidence
PPRTV
July-13
Antimony
ND
ND
ND
IRIS
July-13
Arsenic
1.5E+00
1.5E+00
(mg/kg-day)"1
A
IRIS
July-13
Bromide
NA
NA
July-13
Cadmium
ND
ND
ND
IRIS
NP
Cadmium
ND
ND
Inadequate evidence
IRIS
NP
Calcium
ND
ND
ND
Chloride
NA
NA
July-13
Chromium III
ND
ND
D
IRIS
July-13
Chromium Vi
ND
ND
D
IRIS
July-13
Cobalt
ND
ND
July-13
Lead
ND
ND
B2
IRIS
July-13
Manganese
ND
ND
D
IRIS
July-13
Mercury (as mercuric chloride)
ND
NA
C
IRIS
July-13
Nickel
ND
ND
ND
IRIS
July-13
Nitrate
ND
ND
ND
IRIS
July-13
Nitrogen, Ammonia
ND
ND
July-13
Silver
ND
ND
D
IRIS
July-13
Sulfates as S04
NA
NA
July-13
Thallium
ND
ND
Inadequate evidence
IRIS
July-13
Urea
ND
ND
Inadequate evidence
July-13
Vanadium
ND
ND
ND
July-13
PETROLEUM HYDROCARBONS
C19-C36 Atiphatics
NA
NA
July-13
C11-C22 Aromatics
NA
NA
July-13
SPECIALTY COMPOUNDS
July-13
4-Nony!phenol
NA
NA
July-13
Kempore
NA
NA
July-13
Page 2 of 4
-------
Table G-5
OU1/2 Cancer Toxicity Data Summary
Pathway: Ingestion, Dermal
Chemical of
Oral Cancer
Dermal Cancer
Slope Factor
Weight of
Concern
Slope Factor
Slope Factor
Units
Evidence/Cancer
Source
Date|1)
Guideline Description
Pathway: Inhalation
Chemical of
inhalation
Weight of
Concern
Unit Risk
Units
Cancer Slope
Units
Evidence/Cancer
Source
Date"1
Factor
Guideline Description
VOLATILES
1,2-Dichtoroethene (cis)
ND
ND
Inadequate data
IRIS
July-13
2,4,4-Trimethy(-1-pentene
ND
ND
ND
JuSy-13
2,4,4-Trimethyl-2-peniene
ND
ND
ND
July-13
4-iso-Propy!toiuene
ND
ND
Inadequate data
PPRTV
July-13
Bromodichioromethane
3.7E-05
(ug/m3)"1
1.3E-01
(mg/kg-day)"1
B2
CALEPA
July-13
^hlorodibromomethane
2.7E-Q5
(uglmY
9.4E-02
(mg/kg-day)"1
C
CALEPA
July-13
Dhioroform
2.3E-05
(ug/m3)"1
8.1E-02
(mg/kg-day)"1
82
IRIS
July-13
}ibromomethane
ND
ND
Inadequate data
PPRTV
July-13
Trichioroethene
4.1QE-Q6
(ug/m3)"1
7.00E-03
(mg/kg-day)"1
Carcinogenic to humans
IRIS
July-13
/rnyi Chloride (adult and child)
8.80E-06
(ug/m3)-1
3.1GE-G2
(mg/kg-day)"1
Known human carcinogen
IRIS
July-13
is(2-ethylhexyl)phtha!ate (BEHP)
2.4E-06
(ug/m3)"1
8.4E-03
(mg/kg-day)"1
B2
CALEPA
July-13
iarbazoie
ND
ND
Inadequate data
PPRTV
July-13
Shrysene
1.10E-05
(ug/m3)"1
3.9E-02
(mg/kg-day)"1
B2
CALEPA
July-13
}ibenzo(a,h)anthracene
1.2E-03
(ug/m3)"1
4.1E+00
(mg/kg-day)"1
B2
CALEPA
July-13
Dimethyl phthalate
NA
ND
D
IRIS
July-13
Diphenyl ether
NA
NA
July-13
Diphenylmethanone
NA
NA
July-13
Hydrazine
4.90E-03
(ug/m3)"1
1.7E+01
(mg/kg-day)"1
B2
IRIS
July-13
ndeno(1,2,3-cd)pyrene
1.1E-04
(ug/m3)"1
3.9E-01
(mg/kg-day)"1
B2
CALEPA
July-13
v|-Nitrosodimethylamine
1.4E-02
(ug/m 3)"1
5.0E+01
(mg/kg-day)"1
B2
IRIS
July-13
l-Nitrosodi-n-propyiamine
2.0E-03
(ug/m3)"1
7.0E+00
(mg/kg-day)"1
B2
CALEPA
July-13
i-Nitrosodiphenylamine
2.6E-06
(ug/m3)"1
9.0E-03
(mg/kg-day)"1
B2
CALEPA
July-13
3henanthrene
NA
NA
D
IRIS
July-13
3yrene
NA
NA
D
IRIS
July-13
'ESTlCIDES/PCBs
JeSta-BHC
NA
NA
D
IRIS
July-13
\roclor 1260
5.7E-04
(ug/m3)"1
2.0E+Q0
(mg/kg-day)"1
B2
IRIS
July-13
Page 3 of 4
-------
Table G-5
OU1/2 Cancer Toxicity Data Summary
Pathway: ingestion, Dermal
Chemical of
Oral Cancer
Dermal Cancer
Slope Factor
Weight of
Concern
Slope Factor
Slope Factor
Units
Evidence/Cancer
Source
Date|1)
Guideline Description
INORGAN!CS/METALS
Aluminum
ND
ND
July-13
Antimony
ND
ND
July-13
Arsenic
4.3E-03
(ug/m3)"1
1.5E+01
(mg/kg-day)'1
A
IRIS
July-13
Bromide
NA
NA
July-13
Chloride
NA
NA
July-13
Chromium III
ND
ND
D
IRIS
July-13
Chromium Vf
1.2E-02
(ug/m3)'1
4.3E+01
(mg/kg-day)"1
A
IRIS
July-13
-obait
9.0E-03
(ug/m3)"1
3.2E+01
(mg/kg-day)"1
Likely carcinogenic in humans
PPRTV
July-13
.ead
ND
ND
B2
IRIS
July-13
Manganese
ND
ND
D
IRIS
July-13
Mercury (as mercuric chloride)
ND
ND
C
IRIS
July-13
vlickei
2.6E-04
(ug/m3)'1
9.1E-01
(mg/kg-day)'1
A
CALEPA
July-13
titrate
ND
ND
ND
IRIS
July-13
Nitrogen, Ammonia
ND
ND
IRIS
July-13
Silver
ND
ND
D
IRIS
July-13
Sulfates as S04
NA
NA
July-13
Thallium
ND
ND
July-13
Jrea
ND
ND
Inadequate evidence
IRIS
July-13
/anadium
ND
ND
ND
July-13
tph
D19-C36 Aliphatics
NA
NA
July-13
S11-C22 Aromatics
NA
NA
July-13
SPECIALTY COMPOUNDS
l-Nonylphenol
NA
NA
July-13
-------
ROD RISK WORKSHEET
Table G-6
OU1/2 Non-Cancer Toxicity Data Summary
Chemical of Concern
Chronic/
Subchronic
Oral RfD
Value
Oral RfD
Units
Dermal
RfD
Dermal
RfD
Units
Primary Target Organ
Combined
Uncertainty/
Modifying
Factors
Sources of
RfD:
Target
Organ
Dates of
RfD:
Target
Organ(1)
Pathway: Ingestion, Dermal
VOLATILES
1,2-Dichloroethene (cis)
chronic
2.0E-03
mg/kg/day
2.0E-03
mg/kg/day
Hematological
3,000
IRIS
July-13
subchronic
3.0E-01
mg/kg/day
3.0E-01
mg/kg/day
Hematological
100/1
MRL
July-13
2,4,4-Trimethyl-1-pentene
chronic
2.1E-02
mg/kg/day
2.1E-02
mg/kg/day
Liver/LOAEL
10,000
AMEC
July-13
subchronic
2.1E-01
mg/kg/day
2.1E-01
mg/kg/day
Liver/LOAEL
1,000
AMEC
July-13
2,4,4-Trimethyi-2-pentene
chronic
2.1E-02
mg/kg/day
2.1E-02
mg/kg/day
Liver/LOAEL
10,000
AMEC
July-13
subchronic
2.1E-01
mg/kg/day
2.1E-01
mg/kg/day
Liver/LOAEL
1,000
AMEC
July-13
4-iso-Propyltoluene
chronic
NA
NA
July-13
subchronic
NA
NA
July-13
Bromodichloromethane
chronic
2.0E-02
mg/kg/day
2.QE-02
mg/kg/day
Kidney; renal cytomegaly
1,000/1
IRIS
July-13
subchronic
8.0E-03
mg/kg/day
8.0E-03
mg/kg/day
Reproductive
100
PPRTV
July-13
Chlorodibromomethane
chronic
2.0E-02
mg/kg/day
2.0E-02
mg/kg/day
Hepatic lesions
1,000/1
IRIS
July-13
subchronic
7.0E-02
mg/kg/day
7.0E-02
mg/kg/day
NOAEL / Liver lesions
300
PPRTV
July-13
Chloroform
chronic
1.0E-02
mg/kg/day
1.0E-02
mg/kg/day
Liver; fatty cyst formation in liver
100/1
IRIS
July-13
subchronic
1.0E-01
mg/kg/day
1.0E-01
mg/kg/day
Hepatic
100
MRL
July-13
Chloromethane (Methyl chloride)
chronic
ND
ND
July-13
subchronic
ND
ND
July-13
Dibromomethane
chronic
1.0E-02
mg/kg/day
1.0E-02
mg/kg/day
increased carboxyhemoglobin
1,000
HEAST
July-13
subchronic
9.0E-03
mg/kg/day
9.0E-03
mg/kg/day
Kidney, liver, thyroid
1,000
PPRTV
July-13
Trichloroethene
chronic
5.0E-04
mg/kg/day
5.0E-04
mg/kg/day
Immune System, heart malformations
1,000
IRIS
July-13
subchronic
5.0E-04
mg/kg/day
5.0E-04
mg/kg/day
Immune System, heart malformations
1,000
Chronic
July-13
Vinyl Chloride
chronic
3.0E-03
mg/kg/day
3.0E-03
mg/kg/day
Liver; liver cell polymorphism
30/1
IRIS
July-13
subchronic
3.0E-03
mg/kg/day
3.0E-03
mg/kg/day
Liver; liver cell polymorphism
30/1
Chronic
July-13
Xylenes (total)
chronic
2.0E-01
mg/kg/day
2.0E-01
mg/kg/day
General toxicity; increased mortality
1,000/1
IRIS
December-10
subchronic
4.0E-01
mg/kg/day
4.QE-01
mg/kg/day
decreased body weight
1,000
PPRTV
February-11
SEMIVOLATILES
1,3-Dichlorobenzene
chronic
3.0E-03
mg/kg/day
3.0E-03
mg/kg/day
Liver
NCEA
December-10
subchronic
2.0E-02
mg/kg/day
2.0E-02
mg/kg/day
Endocrine
100
MRL
September-11
2-Nitrophenol
chronic
NA
NA
July-13
subchronic
NA
NA
July-13
4-Chlorophenyl-phenylether
chronic
NA
NA
July-13
subchronic
NA
NA
July-13
4-Methylphenol (p-Cresol)
chronic
5.0E-03
mg/kg/day
5.0E-03
mg/kg/day
Reproductive; maternal death
1,000/1
HEAST
subchronic
1.0E-01
mg/kg/day
1.0E-Q1
mg/kg/day
Respiratory system
100/1
MRL
4-Nitrophenol
chronic
NA
NA
July-13
subchronic
NA
NA
July-13
Azobenzene
chronic
ND
ND
July-13
subchronic
ND
ND
July-13
Benzo(a)anthracene
chronic
3.0E-02
mg/kg/day
3.0E-02
mg/kg/day
Kidney; renal tubular pathology
3,000/1
Surrogate (1)
July-13
subchronic
3.0E-01
mg/kg/day
3.0E-01
mg/kg/day
Kidney; renai tubular pathology
300/1
Surrogate (1)
July-13
Benzo(a)pyrene
chronic
3.0E-02
mg/kg/day
3.0E-02
mg/kg/day
Kidney; renai tubular pathology
3,000/1
Surrogate (1)
July-13
subchronic
3.0E-01
mg/kg/day
3.0E-01
mg/kg/day
Kidney; renai tubular pathology
300/1
Surrogate (1)
July-13
Benzo(b)fluoranihene
chronic
3.0E-02
mg/kg/day
3.0E-02
mg/kg/day
Kidney; renai tubular pathology
3,000/1
Surrogate (1)
July-13
subchronic
3.0E-01
mg/kg/day
3.0E-01
mg/kg/day
Kidney; renal tubular pathology
300/1
Surrogate (1)
July-13
Benzo(k)fluoranthene
chronic
3.0E-02
mg/kg/day
3.0E-02
mg/kg/day
Kidney; renai tubular pathology
3,000/1
Surrogate (1)
July-13
subchronic
3.0E-01
mg/kg/day
3.0E-01
mg/kg/day
Kidney; renal tubular pathology
300/1
Surrogate (1)
July-13
Bis(2-ethylhexyl)phthaiate (BEHP)
chronic
2.0E-02
mg/kg/day
2.0E-02
mg/kg/day
Liver; increased liver weight
1,000/1
IRIS
July-13
subchronic
1.0E-01
mg/kg/day
1.0E-01
mg/kg/day
Reproductive
100
MRL
July-13
Carbazole
chronic
ND
ND
PPRTV
July-13
subchronic
ND
ND
PPRTV
July-13
Chrysene
chronic
3.0E-02
mg/kg/day
3.0E-Q2
mg/kg/day
K
dney
renal tubular pathology
3,000/1
Surrogate (1)
July-13
subchronic
3.0E-01
mg/kg/day
3.0E-01
mg/kg/day
K
dney
renal tubular pathology
300/1
Surrogate (1)
July-13
Dibenzo(a,h)anthracene
chronic
3.0E-02
mg/kg/day
3.0E-02
mg/kg/day
K
dney
renal tubular pathology
3,000/1
Surrogate (1)
July-13
subchronic
3.0E-01
mg/kg/day
3.0E-01
mg/kg/day
K
dney
renal tubular pathology
300/1
Surrogate (1)
July-13
Dimethylphthalate
chronic
ND
ND
July-13
subchronic
ND
ND
July-13
Diphenyi ether (diphenyl oxide)
chronic
NA
NA
July-13
subchronic
NA
NA
July-13
Diphenylmethanone
chronic
NA
NA
July-13
subchronic
NA
NA
July-13
Hydrazine
chronic
NA
NA
July-13
subchronic
NA
NA
July-13
lndeno(1,2,3-cd)pyrene
chronic
3.0E-02
mg/kg/day
3.0E-02
mg/kg/day
Kidney; renal tubular pathology
3,000/1
Surrogate (1)
July-13
subchronic
3.0E-01
mg/kg/day
3.0E-01
mg/kg/day
Kidney; renai tubular pathology
300/1
Surrogate (1)
July-13
n-Nitrosodimethylamine
chronic
8.0E-06
mg/kg/day
8.0E-06
mg/kg/day
Developmental effects
3,000
PPRTV
July-13
subchronic
8.0E-06
mg/kg/day
8.0E-06
mg/kg/day
Developmental effects
3,000
PPRTV
July-13
n-Nitrosodi-n-propylamine
chronic
ND
ND
July-13
subchronic
ND
ND
July-13
n-Nitrosodiphenylamine
chronic
ND
ND
July-13
subchronic
ND
ND
July-13
Phenanthrene
chronic
3.0E-02
mg/kg/day
3.0E-02
mg/kg/day
K
dney
renal tubular pathology
3,000/1
Surrogate (1)
July-13
subchronic
3.0E-01
mg/kg/day
3.0E-01
mg/kg/day
K
dney
renal tubular pathology
300/1
Surrogate (1)
July-13
Pyrene
chronic
3.0E-02
mg/kg/day
3.0E-02
mg/kg/day
K
dney
renal tubular pathology
3,000/1
IRIS
July-13
subchronic
3.0E-01
mg/kg/day
3.0E-01
mg/kg/day
K
dney
renai tubular pathology
300
PPRTV
July-13
Page 1 of 5
-------
Table G-6
OU1/2 Non-Cancer Toxicity Data Summary
Chemical of Concern
Chronic/
Subchronic
Oral RfD
Value
Oral RfD
Units
Dermal
RfD
Dermal
RfD
Units
Primary Target Organ
Combined
Uncertainty/
Modifying
Factors
Sources of
RfD:
Target
Organ
Dates of
RfD:
Target
Organ*1*
PESTICIDES/PCBs
deita-BHC
chronic
ND
ND
July-13
subchronic
ND
ND
July-13
Aroclor 1260
chronic
2.0E-05
mg/kg/day
2.0E-05
mg/kg/day
Immune system; immunotoxicity; Eye
300/1
Surrogate (2)
July-13
subchronic
3.0E-Q5
mg/kg/day
3.0E-05
mg/kg/day
Immune system; immunotoxicity; Eye
1,000
Surrogate (2)
July-13
iNORGANICS/METALS
Aluminum
chronic
1.0E+00
mg/kg/day
1.0E+00
mg/kg/day
LOAEL/CNS
100
PPRTV
July-13
subchronic
1.0E+00
mg/kg/day
1.0E+00
mg/kg/day
CNS
30
MRL
July-13
Antimony
chronic
4.0E-04
mg/kg/day
6.0E-05
mg/kg/day
Reduced lifespan; hematological; blood glucose and cholesterol
1,000/1
IRIS
July-13
subchronic
4.0E-04
mg/kg/day
6.0E-05
mg/kg/day
Reduced lifespan; hematological; blood glucose and cholesterol
PPRTV
July-13
Arsenic
chronic
3.0E-04
mg/kg/day
3.0E-04
mg/kg/day
Skin; keratosis, hyperpigmentation and vascular complications
3/1
IRIS
July-13
subchronic
3.0E-04
mg/kg/day
3.0E-04
mg/kg/day
Skin; keratosis and hyperpigmentation
3/1
HEAST
July-13
Bromide
chronic
NA
NA
July-13
subchronic
NA
NA
July-13
Chloride
chronic
NA
NA
July-13
subchronic
NA
NA
July-13
Chromium III
chronic
1.5E+00
mg/kg/day
2.0E-02
mg/kg/day
No effects observed
100/10
IRIS
July-13
subchronic
1.5E+00
mg/kg/day
2.0E-02
mg/kg/day
No effects observed
1,000/1
HEAST
July-13
Chromium VI
chronic
3.0E-03
mg/kg/day
7.5E-05
mg/kg/day
No effects reported
300/3
IRIS
July-13
subchronic
2.0E-02
mg/kg/day
5.0E-04
mg/kg/day
No effects reported
100/1
HEAST
July-13
Cobalt
chronic
3.0E-04
mg/kg/day
3.0E-Q4
mg/kg/day
LOAEL / Thyroid
3,000
PPRTV
July-13
subchronic
3.0E-03
mg/kg/day
3.GE-03
mg/kg/day
LOAEL / Thyroid
300
PPRTV
July-13
Lead
chronic
ND
ND
July-13
subchronic
ND
ND
July-13
Manganese (soil)
chronic
2.4E-02
mg/kg/day
9.6E-04
mg/kg/day
CNS; impairment of neurobehavioral function
3/1
IRIS
July-13
subchronic
2.4E-02
mg/kg/day
9.6E-04
mg/kg/day
CNS; Impairment of neurobehavioral function
3/1
chronic
July-13
Mercury (as mercuric chloride)
chronic
3.0E-04
mg/kg/day
2.1E-05
mg/kg/day
Immune system; autoimmune effects
1,000/1
IRIS
July-13
subchronic
2.0E-03
mg/kg/day
1.4E-04
mg/kg/day
Renal
100
MRL
July-13
Nickel
chronic
2.0E-02
mg/kg/day
8.0E-04
mg/kg/day
Decreased body and organ weights
300/1
IRIS
July-13
subchronic
2.0E-02
mg/kg/day
8.0E-04
mg/kg/day
Decreased body and organ weights
300/1
Chronic
July-13
Nitrate
chronic
1.6E+00
mg/kg/day
1.6E+00
mg/kg/day
Hematological; early clinical signs of methemoglobinemia
1/1
IRIS
July-13
subchronic
1.6E+00
mg/kg/day
1.6E+00
mg/kg/day
Hematological; early clinical signs of methemoglobinemia
1/1
chronic
July-13
Nitrogen, Ammonia
chronic
ND
ND
July-13
subchronic
ND
ND
July-13
Silver
chronic
5.0E-03
mg/kg/day
2.0E-04
mg/kg/day
Skin, eye, and respiratory tract; argyria
3/1
IRIS
July-13
subchronic
5.0E-03
mg/kg/day
2.0E-04
mg/kg/day
Skin; argyria
3/1
HEAST
July-13
Sulfates as S04
chronic
NA
NA
July-13
subchronic
NA
NA
July-13
Thallium
chronic
1 .OE-05
mg/kg/day
1 .0E-05
mg/kg/day
No effects observed
3,000
PPRTV SL
July-13
subchronic
8.0E-04
mg/kg/day
8.QE-04
mg/kg/day
No effects observed
300/1
HEAST
July-13
Urea
chronic
ND
ND
July-13
subchronic
ND
ND
July-13
Vanadium - Region 1
chronic
4.9E-03
mg/kg/day
1.3E-04
mg/kg/day
Kidney
100/1
IRIS
July-13
subchronic
1.0E-02
mg/kg/day
2.6E-04
mg/kg/day
Hematological
10/1
MRL
July-13
EPH
C19-C36 Aliphatics
chronic
2.0E+00
mg/kg/day
2.0E+00
mg/kg/day
MassDEP
July-13
subchronic
6.0E+00
mg/kg/day
6.QE+00
mg/kg/day
MassDEP
July-13
C11-C22 Aromatics
chronic
3.0E-02
mg/kg/day
3.0E-02
mg/kg/day
MassDEP
July-13
subchronic
3.0E-01
mg/kg/day
3.0E-01
mg/kg/day
MassDEP
July-13
SPECIALTY COMPOUNDS
4-Nonyiphenol
chronic
NA
NA
July-13
subchronic
NA
NA
July-13
Kempore
chronic
NA
NA
July-13
subchronic
NA
NA
July-13
Page 2 of 5
-------
Table G-6
OU1/2 Non-Cancer Toxicity Data Summary
Chemical of Concern
Chronic/
Subchronic
Oral RfD
Value
Oral RfD
Units
Dermal
RfD
Dermal
RfD
Units
Primary Target Organ
Combined
Uncertainty/
Modifying
Factors
Sources of
RfD:
Target
Organ
Dates of
RfD:
Target
Organ*1*
Pathway: Inhalation
VOLATiLES
1,2-Dichloroethene (cis)
chronic
ND
ND
July-13
subchronic
ND
ND
July-13
2,4,4-Trimethyl-1-pentene
chronic
7.2E-02
mg/m3
2.1E-02
mg/kg/day
Liver / NOAEL
10,000
AMEC
July-13
subchronic
7.2E-01
mg/m3
2.1E-01
mg/kg/day
Liver / NOAEL
1,000
AMEC
July-13
2,4,4-Trimethy!-2-pentene
chronic
7.2E-02
mg/m3
2.1E-02
mg/kg/day
Liver / NOAEL
10,000
AMEC
July-13
subchronic
7.2E-01
mg/m3
2.1E-01
mg/kg/day
Liver / NOAEL
1,000
AMEC
July-13
4-iso-Propyltoluene
chronic
NA
NA
July-13
subchronic
NA
NA
July-13
Bromodichloromethane
chronic
ND
ND
July-13
subchronic
2.0E-02
mg/m3
5.7E-03
mg/kg/day
NOAEL / kidney degeneration
300
PPRTV
July-13
Chlorodibromomethane
chronic
ND
ND
July-13
subchronic
ND
ND
July-13
Chloroform
chronic
9.8E-02
mg/m3
2.8E-02
mg/kg/day
Hepatic
100
MRL
July-13
subchronic
2.4E-01
mg/m3
6.9E-02
mg/kg/day
Hepatic
300
MRL
July-13
Dibromomethane
chronic
4.0E-03
mg/m3
1.1E-03
mg/kg/day
3,000
PPRTV
July-13
subchronic
4.0E-02
mg/m3
1.1E-02
mg/kg/day
300
PPRTV
July-13
Trichloroethene
chronic
2.0E-03
mg/m3
5.7E-04
mg/kg/day
Immune system; heart malformations
100
IRIS
July-13
subchronic
2.0E-03
mg/m3
5.7E-04
mg/kg/day
Immune system; heart malformations
100
Chronic
July-13
Vinyf Chloride
chronic
1.0E-01
mg/m3
2.9E-02
mg/kg/day
Liver; liver cell polymorphism
30/1
IRIS
July-13
subchronic
1.0E-01
mg/m3
2.9E-Q2
mg/kg/day
Liver; liver cell polymorphism
30/1
Chronic
July-13
Xylenes (total)
chronic
1.0E-01
mg/m3
2.9E-02
mg/kg/day
CNS; impaired motor coordination
300/1
IRIS
January-00
subchronic
4.0E-01
mg/m3
1.1E-01
mg/kg/day
CNS; impaired motor coordination
100
PPRTV
January-GQ
SEMIVOLATILES
1,3-Dichlorobenzene
chronic
ND
ND
IRIS
subchronic
ND
ND
2-Nitrophenol
chronic
ND
ND
July-13
subchronic
5.0GE-04
mg/m3
1.4E-Q4
mg/kg/day
Squamous metaplasia of nasal epithelium
300
PPRTV
July-13
4-Chlorophenyl-phenyiether
chronic
NA
NA
July-13
subchronic
NA
NA
July-13
4-Methylphenol (p-Cresol)
chronic
6.0E-01
mg/m3
1.7E-01
mg/kg/day
CNS
REL
January-00
subchronic
6.0E-01
mg/m3
1.7E-01
mg/kg/day
CNS
Chronic
4-Nitrophenol
chronic
NA
NA
July-13
subchronic
NA
NA
July-13
Azobenzerie
chronic
ND
ND
July-13
subchronic
ND
ND
July-13
Benzo{a)anthracene
chronic
ND
ND
July-13
subchronic
ND
ND
July-13
Benzo(a)pyrene
chronic
ND
ND
July-13
subchronic
ND
ND
July-13
Benzo{b)fiuoranthene
chronic
ND
ND
July-13
subchronic
ND
ND
July-13
Benzo{k)fluoranthene
chronic
ND
ND
July-13
subchronic
ND
ND
July-13
Bis(2-ethylhexyl)phthalate (BEHP)
chronic
ND
ND
July-13
subchronic
ND
ND
July-13
Carbazole
chronic
NA
NA
July-13
subchronic
NA
NA
July-13
Chrysene
chronic
ND
ND
July-13
subchronic
ND
ND
July-13
Dibenzo(a,h}anthracene
chronic
ND
ND
July-13
subchronic
ND
ND
July-13
Dimethyiphthaiate
chronic
NA
NA
July-13
subchronic
NA
NA
July-13
Diphenyl ether
chronic
NA
NA
July-13
subchronic
NA
NA
July-13
Diphenyimethanone
chronic
NA
NA
July-13
subchronic
NA
NA
July-13
Hydrazine
chronic
3.0E-05
mg/m3
8.6E-06
mg/kg/day
Liver
1,000
PPRTV
July-13
subchronic
9.0E-05
mg/m3
2.6E-05
mg/kg/day
Liver
300
PPRTV
July-13
lndeno(1,2,3-cd)pyrene
chronic
ND
ND
July-13
subchronic
ND
ND
July-13
Page 3 of 5
-------
Table G-6
OU1/2 Non-Cancer Toxicity Data Summary
Chemical of Concern
Chronic/
Subchronic
Oral RfD
Value
Oral RfD
Units
Dermal
RfD
Dermal
RfD
Units
Primary Target Organ
Combined
Uncertainty/
Modifying
Factors
Sources of
RfD:
Target
Organ
Dates of
RfD:
Target
Organ*1*
SEMIVOLATILES (cont.)
n-Nitrosodimethylamine
chronic
4.0E-05
mg/m3
1.1E-05
mg/kg/day
LOAEL / Reduced body weight
3,000
PPRTV SL
July-13
subchronic
4.0E-05
mg/m3
1.1E-05
mg/kg/day
LOAEL / Reduced body weight
3,000
chronic
July-13
n-Nitrosodi-n-propylamine
chronic
ND
ND
July-13
subchronic
ND
ND
July-13
n-Nitrosodiphenyiamine
chronic
ND
ND
July-13
subchronic
ND
ND
July-13
Phenanthrene
chronic
NA
NA
July-13
subchronic
NA
NA
July-13
Pyrene
chronic
ND
ND
July-13
subchronic
ND
ND
July-13
PESTICIDES/PCBs
delta-BHC
chronic
NA
NA
July-13
subchronic
NA
NA
July-13
Aroclor 1260
chronic
ND
ND
July-13
subchronic
ND
ND
July-13
INORGANICS/METALS
Aluminum
chronic
5.0E-03
mg/m3
1.4E-Q3
mg/kg/day
LOAEL/CNS
300
PPRTV
July-13
subchronic
5.0E-03
mg/m3
1.4E-03
mg/kg/day
LOAEL/CNS
300
chronic
july-13
Antimony
chronic
ND
ND
July-13
subchronic
ND
ND
July-13
Arsenic
chronic
1.5E-05
mg/m3
4.3E-06
mg/kg/day
Developmental; cardiovascular: CNS
CalEPA
July-13
subchronic
1.5E-05
mg/m3
4.3E-06
mg/kg/day
Developmental; cardiovascular; CNS
chronic
July-13
Bromide
chronic
NA
NA
July-13
subchronic
NA
NA
July-13
Chloride
chronic
NA
NA
July-13
subchronic
NA
NA
July-13
Chromium III
chronic
ND
ND
July-13
subchronic
5.0E-03
mg/m3
1.4E-Q3
mg/kg/day
Respiratory system
90
MRL
July-13
Chromium VI
chronic
1.0E-04
mg/m3
2.9E-05
mg/kg/day
Lung; enzyme alterations
300/1
IRIS
July-13
subchronic
3.0E-04
mg/m3
8.6E-05
mg/kg/day
Respiratory system
100
MRL
July-13
Cobalt
chronic
6.QE-06
mg/m3
1.7E-06
mg/kg/day
Respiratory tract / Lung INOAEL
300
PPRTV
July-13
subchronic
2.0E-05
mg/m3
5.7E-06
mg/kg/day
Respiratory tract / Lung / NOAEL
100
PPRTV
July-13
Lead
chronic
ND
ND
July-13
subchronic
ND
ND
July-13
Manganese
chronic
5.0E-05
mg/m3
1.4E-05
mg/kg/day
CNS; impairment of neurobehavioral function
1,000/1
IRIS
July-13
subchronic
5.QE-05
mg/m3
1.4E-05
mg/kg/day
CNS; impairment of neurobehavioral function
1,000/1
Chronic
July-13
Mercury (as mercuric chloride)
chronic
3.0E-05
mg/m3
8.6E-06
mg/kg/day
REL
July-13
subchronic
3.0E-05
mg/m3
8.6E-06
mg/kg/day
Chronic
July-13
Mercury (as elemental mercury)
chronic
3.0E-04
mg/m3
8.6E-05
mg/kg/day
CNS; tremors, memory; autonomic dysfunction
30/1
IRIS
July-13
subchronic
3.0E-04
mg/m3
8.6E-05
mg/kg/day
CNS; neurotoxicity
30/1
HEAST97
July-13
Mercury (as methyl mercury)
chronic
ND
ND
July-13
subchronic
ND
ND
July-13
Nickel
chronic
9.0E-05
mg/m3
2.6E-05
mg/kg/day
Respiratory system
30
MRL
July-13
subchronic
2.0E-04
mg/m3
5.7E-05
mg/kg/day
Respiratory system
30
MRL
July-13
Nitrate
chronic
ND
ND
July-13
subchronic
ND
ND
July-13
Nitrogen, Ammonia
chronic
1.QE-01
mg/m3
2.9E-02
mg/kg/day
Respiratory system; chemical pneumonia
30/1
IRIS
July-13
subchronic
1.0E-01
mg/m3
2.9E-02
mg/kg/day
NOAEL / Pulmonary
30
PPRTV
July-13
Silver
chronic
ND
ND
July-13
subchronic
ND
ND
July-13
Sulfates as S04
chronic
NA
NA
July-13
subchronic
NA
NA
July-13
Thallium
chronic
ND
ND
July-13
subchronic
ND
ND
July-13
Urea
chronic
ND
ND
July-13
subchronic
ND
ND
July-13
Vanadium
chronic
1.0E-Q4
mg/m3
2.9E-05
mg/kg/day
Respiratory
30
MRL
July-13
subchronic
1.QE-Q4
mg/m3
2.9E-05
mg/kg/day
Respiratory
30
Chronic
July-13
EPH
C19-C36 Aliphatics
chronic
ND
ND
July-13
subchronic
ND
ND
July-13
C11-C22 Aromatics
chronic
5.0E-02
mg/m3
1.4E-02
mg/kg/day
MassDEP
July-13
subchronic
5.0E-01
mg/m3
1.4E-01
mg/kg/day
MassDEP
July-13
Page 4 of 5
-------
Table G-6
OU1/2 Non-Cancer Toxicity Data Summary
Dermal
RfD
Units
Combined
Sources of
Dates of
Chemical of Concern
Chronic/
Subchronic
Oral RfD
Value
Oral RfD
Units
Dermal
RfD
Primary Target Organ
Uncertainty/
Modifying
Factors
RfD:
Target
Organ
RfD:
Target
Organ(1)
SPECIALTY COMPOUNDS
4-Nonylphenol
chronic
NA
NA
July-13
subchronic
NA
NA
July-13
Kempore
chronic
NA
NA
July-13
subchronic
NA
NA
July-13
Key
mg = milligram
NA - not liste
d in heirarchy sources
kg = kilogram
ND - no data
available
m3 = cubic meter
CNS - central nervous system
LOAEL - lowest observed adverse effect level
NOAEL - no observed adverse effect level
PCBs - polychlorinated biphenyts
RfD - reference dose
(1) Date indicates when source was last reviewed.
NA - No information available
IRIS: integrated Risk Information System, EPA
PPRTV = Provisional Peer Reviewed Toxicity Value developed by Superfund Technical Support Center (STSC)
HEAST = Health Effects Assessment Summary Tables
MRL = Minimum Risk Level (Agency for Toxic Substances and Dis
sase Registry)
CalEPA = California Environmental Protection Agency, Office of Environmental Health Hazard Assessment
MassDEP = Massachusetts Department of Environmental Protection
PPRTV SL = Preliminary Peer-Reviewed Toxicity Value Screening Level
(1) Date indicates when source was last reviewed.
This table provides non-carcinogenic risk information which is relevant to the chemicals of concern (COCs) in soil, sediment, and surface water. Thirty nine COCs have oral toxicity data (or surrogate toxicity data) indicating
their potential for adverse non-carcinogenic health effects in humans. Chronic toxicity data available for the COCs for oral exposures have been used to develop chronic oral reference doses (RfDs), provided in this table.
The available chronic toxicity data indicate that trichloroethene, Aroclor 1260 and mercury affect the immune system, 2.4,4-trimethyl-1-pentene, 2,4,4-trimethyl-2-pentene, chlorodibromomethane, chloroform,
dibromomethane, vinyl chloride, 1,3-dichforobenzene, bis(2-ethylhexyl)phthalate, and hydrazine affect the liver, bromodichloromethane, dibromomethane, benzo{a)anthracene, benzo(b)pyrene, benzo(b)fluoranthene,
benzo(k)fluoranthene, chrysene, dibenzo{a,h)anthracene, indeno(1,2,3-cd)pyrene, phenanthrene, pyrene, mercury, and vanadium affect the kidney; 4-methylphenol, aluminum, arsenic, and manganese affect the central
nervous system; n-nitrosodimethylamine and arsenic are developmental toxicants; xylenes, n-nitrosodimethylamine, xylenes, antimony, and nickel affect the whole body; 4-methyiphenol, chromium, nickel, silver, vanadium,
and ammonia affect the respiratory system; trichloroethene, antimony, and arsenic affect the cardiovascular system, 1,2-dichloroethene, dibromomethane, antimony, vanadium and nitrate affect the blood;
bromodichloromethane, 4-methylphenol, and bis(2-ethylhexyl)phthalate affect the reproductive system; dibromomethane, 1,3-dichlorobenzene and cobalt affect the endocrine system; Aroclor 1260 and silver affect the eyes;
and arsenic and silver affect the skin. As was the case for the carcinogenic data, dermal RfDs can be extrapotated from oral RfDs by applying an adjustment factor as appropriate. Oral RfDs were adjusted for COCs with
less than 50% absorption via the ingestion route to derive dermal RfDs for these COCs. inhalation reference concentrations (RfCs) are available for twenty three COCs evaluated for the inhalation pathway.
Toxicity values shown are those developed for the OU1/OU2 BHHRA (Amec, 2015).
Source: A Guide to Preparing Superfund Proposed Plans, Records of Decision, and Other Remedy Selection Decision Documents (U.S. EPA, 1999)
Page 5 of 5
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ROD RISK WORKSHEET
Table G-7
OU1/2 Risk Characterization Summary - Carcinogens
Scenario Timeframe: Current/Future
Receptor Population; Outdoor Worker
Receptor Age: Adult
Medium
Exposure
Exposure Point
Chemical of Concern
Carcinogenic Risk
Medium
Ingestion
Inhalation
Dermal
External
(Radiation)
Exposure
Routes Total
Soil
Surface Soil /
EA1 OU1
Benzo(a)anthracene
1E-06
3E-11
8E-07
NA
1.8E-06
Dust (inhalation)
Benzo(a)pyrene
7E-06
2E-10
6E-06
NA
1.3E-05
Benzo(b)fluoranthene
9E-07
2E-11
8E-07
NA
1.7E-06
Bis(2-Ethylhexyl)phthalate
2E-07
5E-12
1E-07
NA
2.8E-07
Carbazole
2E-09
NC
1E-09
NA
3.6E-09
Dibenz(a,h)anthracene
5E-07
2E-11
5E-07
NA
9.9E-07
lndeno(1,2,3-cd)pyrene
4E-07
1E-11
4E-07
NA
7.9E-07
Aroclor-1260
1E-06
6E-11
1E-06
NA
2.2E-06
Arsenic
3E-06
3E-09
1E-06
NA
4.1E-06
Chromium, Hexavalent
NC
5E-09
NC
NA
4.8E-09
Cobalt
NC
2E-09
NC
NA
2.3E-09
Exposure Risk Total =
2E-05
Soil
Surface Soil /
EA2 OU1
Benzo(a)anthracene
4E-08
1E-12
4E-08
NA
8.0E-08
Dust (inhalation)
Benzo(a)pyrene
3E-07
9E-12
3E-07
NA
6.3E-07
Benzo(b)fluoranthene
5E-08
1E-12
4E-08
NA
8.7E-08
Bis(2-Ethylhexyl)phthalate
4E-07
1E-11
3E-07
NA
6.6E-07
Dibenz(a,h)anthracene
5E-07
1E-11
4E-07
NA
9.1E-07
lndeno(1,2,3-cd)pyrene
3E-08
8E-13
3E-08
NA
5.7E-08
Arsenic
2E-06
2E-09
8E-07
NA
3.2E-06
Cobalt
NC
2E-09
NC
NA
1.8E-09
Exposure Risk Total =
6E-06
Soil
Surface Soil /
EA3 OU1
Benzo(a)anthracene
2E-08
5E-13
2E-08
NA
3.5E-08
Dust (inhalation)
Benzo(a)pyrene
2E-07
6E-12
2E-07
NA
3.9E-07
Benzo(b)fluoranthene
3E-08
8E-13
3E-08
NA
5.6E-08
Bis(2-Ethylhexyl)phthalate
2E-08
6E-13
1E-08
NA
3.3E-08
Dibenz(a,h)anthracene
5E-07
1E-11
4E-07
NA
8.9E-07
lndeno(1,2,3-cd)pyrene
2E-08
6E-13
2E-08
NA
4.1E-08
Aroclor-1260
9E-08
4E-12
8E-08
NA
1.7E-07
Arsenic
2E-06
2E-09
7E-07
NA
2.7E-06
Cobalt
NC
3E-09
NC
NA
2.9E-09
Chromium, Hexavalent
NC
1E-09
NC
NA
1.1E-09
Exposure Risk Total -
3E-06
Page 1 of 2
-------
Table G-7
OU1/2 Risk Characterization Summary - Carcinogens
Scenario Timeframe: Current/Future
Receptor Population: Outdoor Worker
Receptor Age: Adult
Medium
Exposure
Exposure Point
Chemical of Concern
Carcinogenic Risk
Medium
Ingestion
Inhalation
Dermal
External
(Radiation)
Exposure
Routes Total
Soil
Surface Soil
EA6 OU1
Benzo(a)anthracene
4E-08
NA
4E-08
NA
8.0E-08
Benzo(a)pyrene
8E-07
NA
7E-07
NA
1.5E-06
Benzo(b)fluoranthene
4E-08
NA
3E-08
NA
7.4E-08
Bis(2-Ethylhexyl)phthalate
2E-07
NA
1E-07
NA
2.6E-07
Carbazole
1E-1Q
NA
8E-11
NA
2.1E-10
Dibenz(a,h)anthracene
2E-07
NA
2E-07
NA
3.4E-07
!ndeno(1,2,3-cd)pyrene
4E-08
NA
4E-08
NA
8.1E-08
Arsenic
2E-06
NA
8E-07
NA
3.0E-06
Exposure Risk Total =
5E-06
Soil
Surface Soil /
EAT
Benzo(a)anthracene
1E-08
4E-13
1E-08
NA
2.6E-08
Dust (inhalation)
Benzo(a)pyrene
2E-07
4E-12
1E-07
NA
3.0E-07
Benzo(b)fluoranthene
2E-08
5E-13
2E-08
NA
3.5E-08
Bis(2-Ethylbexyl)phthalate
2E-08
5E-13
1E-08
NA
2.8E-08
lndeno(1,2,3-cd)pyrene
3E-08
8E-13
3E-08
NA
5.6E-08
Arsenic
4E-06
3E-09
1E-06
NA
5.1E-06
Chromium. Hexavalent
NC
8E-10
NC
NA
7.5E-10
Cobalt
NC
2E-09
NC
NA
2.2E-09
Exposure Risk Total =
6E-06
Key
EA - Exposure Area
NA - Exposure route not applicable for this chemical/exposure medium.
NC - Not carcinogenic by this exposure route.
OU - Operable Unit
~ - Not calculated; dose-response data and/or dermal absorption values not available.
This table provides risk estimates for the significant routes of exposure for the current/future outdoor worker exposed to soils. 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 adult outdoor workers' exposure to soil and dust, as well as the toxicity of the chemicals of concern.
Source: A Guide to Preparing Superfund Proposed Plans, Records of Decision, and Other Remedy Selection Decision Documents (U.S. EPA, 1999)
Page 2 of 2
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ROD RISK WORKSHEET
Table G-8
OU1/2 Risk Characterization Summary - Carcinogens
Scenario Timeframe: Future
Receptor Population: Construction Worker
Receptor Age: Adult
Medium
Exposure Point
Chemical of Concern
Carcinogenic Risk
External
Medium
Inhalation
Dermal
Exposure
(Radiation)
Routes Total
Soil
Surface Soil /
EA1 OU1
Benzo(a)anihracene
1E-07
1E-11
6E-Q8
NA
2E-07
Dust (inhalation)
Benzo(a)pyrene
1E-06
7E-11
4E-07
NA
1E-06
Benzo(b)fluoranthene
1E-07
9E-12
5E-08
NA
2E-07
Bis(2-Ethy!hexyl)phthalate
3E-08
2E-12
8E-09
NA
3E-Q8
Carbazole
3E-1G
NA
1E-10
NA
4E-10
Dibenz(a,h)anthracene
8E-08
6E-12
3E-08
NA
1E-07
lndeno(1,2,3-cd)pyrene
6E-08
4E-12
2E-08
NA
9E-08
Aroclor-1260
2E-Q7
2E-11
7E-08
NA
2E-07
Arsenic
5E-07
1E-Q9
7E-08
NA
5E-07
Chromium, Hexavalent
NC
2E-Q9
NC
NA
2E-09
Cobalt
NC
9E-10
NC
NA
9E-10
Exposure Risk TotaS =
3E-Q6
Soil
Subsurface Soil /
EA3 OU1
Bis(2-Ethylhexyl)phthalate
2E-06
2E-1Q
7E-07
NA
3E-06
Dust (inhalation)
N-Nitrosodiphenylamine
5E-11
1E-14
«
NA
5E-11
Arsenic
2E-07
4E-10
3E-08
NA
2E-07
Chromium, Hexavalent
NC
2E-10
NC
NA
2E-10
Hydrazine
5E-10
4E-13
NA
5E-10
Exposure Risk TotaS =
3E-06
Soil
Surface Soil
EA5
Benzo(a)anthracene
8E-08
NA
3E-08
NA
1E-07
Benzo(a)pyrene
5E-08
NA
2E-08
NA
7E-08
Benzo(b)fluoranthene
7E-09
NA
3E-09
NA
1E-08
Bis(2-Ethythexyl)phthatate
7E-08
NA
2E-08
NA
9E-08
Carbazole
5E-11
NA
2E-11
NA
7E-11
lndeno(1,2,3-cd)pyrene
4E-Q7
NA
2E-07
NA
6E-07
N-Nitrosodi-n-propylamine
8E-08
NA
-
NA
8E-08
Arsenic
9E-07
NA
-
NA
1E-06
Exposure Risk Total =
2E-06
Soil
Subsurface Soil /
EA7 OU1
Benzo(a)anthracene
5E-08
4E-12
2E-08
NA
7E-08
Dust (inhalation)
Benzo(a)pyrene
6E-07
4E-11
2E-07
NA
8E-07
Benzo(b)fluoranthene
6E-07
4E-11
2E-07
NA
8E-07
Bis(2-Ethy!hexy!)phtha!ate
2E-G7
1E-11
4E-08
NA
2E-07
lndeno(1,2,3-cd)pyrene
3E-08
2E-12
1E-08
NA
4E-08
N-Nitrosodiphenylamine
7E-1Q
2E-13
NA
7E-1Q
Arsenic
2E-Q7
5E-10
3E-Q8
NA
3E-07
Chromium, Hexavalent
NC
2E-10
NC
NA
2E-10
Hydrazine
1E-1Q
7E-14
-
NA
1E-10
Exposure Risk Total =
2E-06
Key
EA - Exposure Area
NA - Exposure route not applicable for this chemical/exposure medium.
NC - Not carcinogenic by this exposure route.
OU - Operable Unit
- - Not calculated; dose-response data and/or dermal absorption values not available.
This table provides risk estimates for the significant routes of exposure for the future construction worker exposed to soil on the Olin property. 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 construction workers' exposure to soil and dust, as well as the toxicity of the chemicals of concern. Risks for
the future construction worker exposed to subsurface soil/dust at EA1, surface soil at EA2, surface soil at EA3, surface soil at EA8, and surface soil at EA7 were below the risk screening threshold of 1x10-6.
Source: A Guide to Preparing Superfund Proposed Plans, Records of Decision, and Other Remedy Selection Decision Documents (U.S. EPA, 1999)
Page 1 of 1
-------
ROD RISK WORKSHEET
Table G-9
OU1/2 Risk Characterization Summary - Non-Carcinogens
Scenario Timeframe: Future
Receptor Population; Construction Worker
Receptor Age: Adult
Medium
Exposure
Exposure Point
Chemical of Concern
Primary Target Organ
Non-Carcinogenic Hazard Quotient
Medium
ingestion
inhalation
Dermal
Exposure
Routes Total
Soil
Surface Soil /
EA1 OU1
Benzo(a)anthracene
K
dney
5E-05
NA
2E-05
6E-05
Dust (inhalation)
Benzo(a)pyrene
K
dney
3E-05
NA
1E-05
5E-05
Benzo(b)fluoranthene
K
dney
4E-05
NA
2E-05
6E-05
Bis(2-Ethylhexy1)phthalate
Reproductive
1E-03
NA
4E-04
2E-03
C11-C22 Aromatics
5E-03
1E-06
1E-03
6E-03
Dibenz(a,h)anthracene
Kidney
3E-06
NA
1E-06
3E-06
lndeno(1,2,3-cd)pyrene
Kidney
2E-05
NA
8E-06
3E-05
Aroclor-1260
Immune system / Eye
2E-01
NA
8E-02
3E-01
Antimony
General Toxicity / Hematological
4E-03
NA
__
4E-03
Arsenic
Skin/Developmental/Cardiovascular/Nervous System
7E-02
1E-03
1E-02
8E-02
Chromium, Hexavalent
NOAEL / Respiratory
1E-03
4E-05
1E-03
Cobalt
Endocrine / Respiratory
5E-03
4E-04
-
6E-03
Silver
Skin / Eye / Respiratory
8E-04
NA
-
8E-04
Thallium
NOAEL
2E-03
NA
2E-03
Nitrogen, as Ammonia
Respiratory
8E-07
8E-07
Exposure Point Total =
4E-01
Soil
Subsurface Soil /
EA1 OU1
2,4,4-T rimethyl-1 -pentene
Liver
2E-04
2E-08
__
2E-Q4
Dust (inhalation)
2,4,4-T rimethyl-2-pentene
Liver
2E-05
3E-09
-
2E-05
Benzo(a)anthracene
K
dney
3E-07
NA
1E-07
4E-07
Benzo{a)pyrene
K
dney
4E-07
NA
2E-07
6E-07
Benzo(b)fluoranthene
K
dney
5E-07
NA
2E-07
7E-07
Benzo(k)fluoranthene
K
dney
3E-07
NA
1E-07
4E-07
Bis(2-Ethylhexyl)phthalate
Reproductive
5E-03
NA
2E-03
7E-03
lndeno(1,2,3-cd)pyrene
Kidney
1E-06
NA
5E-07
2E-06
Aroclor-1260
Immune system / Eye
1E-01
NA
5E-02
2E-01
Antimony
General Toxicity / Hematological
2E-02
NA
2E-02
Arsenic
Developmental / Cardiovascular/ Nervous System / Skir
3E-02
4E-04
4E-03
3E-02
Chromium, Hexavalent
NOAEL / Respiratory
8E-04
2E-05
8E-04
Nitrogen, as Ammonia
Respiratory
-
7E-06
_
7E-06
Exposure Point Total =
2E-01
Soil
Subsurface Soil /
EA3 OU1
2,4,4-T rimethyl-1 -pentene
Liver
1E-03
1E-07
1E-03
Dust (inhalation)
2,4,4-T rimethyl-2-pentene
Liver
1E-04
2E-08
1E-04
Bis(2-Ethylhexyl)phthalate
Reproductive
1E-01
_
3E-02
1E-01
C11-C22 Aromatics
2E-02
6E-06
6E-03
3E-02
Antimony
General Toxicity / Skin
5E-03
-
5E-03
Arsenic
Developmental / Cardiovascular / Nervous System
3E-02
4E-04
4E-03
3E-02
Chromium, Hexavalent
Respiratory
1E-04
3E-06
1E-04
Nitrogen, as Ammonia
Respiratory
1E-07
1E-Q7
Hydrazine
-
6E-08
6E-08
Exposure Point Total =
2E-01
Page 1 of 2
-------
Table G-9
OU1/2 Risk Characterization Summary - Non-Carcinogens
Scenario Timeframe: Future
Receptor Population: Construction Worker
Receptor Age: Adult
Medium
Exposure
Exposure Point
Chemical of Concern
Primary Target Organ
Non-Carcinogenic Hazard Quotient
Medium
Ingestion
Inhalation
Dermal
Exposure
Routes Total
Soil
Surface Soil
EA5
Benzo(a)anthracene
Kidney
3E-05
NA
1E-05
3E-05
Benzo(a)pyrene
Kidney
2E-06
NA
6E-07
2E-06
Benzo(b)fluoranthene
Kidney
2E-06
NA
9E-07
3E-06
Bis(2-Ethylhexyl)phthalate
Reproductive
3E-03
NA
1E-03
4E-03
C11-C22 Aromatics
8E-02
NA
2E-02
1E-01
lndeno(1,2,3-cd)pyrene
Kidney
1E-04
NA
6E-05
2E-04
Antimony
General Toxicity/
3E-03
NA
3E-03
Arsenic
Skin
2E-01
NA
2E-02
2E-01
Chromium, Hexavalent
NOAEL
4E-02
NA
4E-02
Cobalt
Endocrine
5E-03
NA
5E-03
Silver
Skin / Eye I Respiratory
7E-01
NA
~~
7E-01
Thallium
NOAEL
3E-02
NA
3E-02
Exposure Point Total =
1E+00
Key
EA - Exposure Area
NA - Toxicity criteria are not available to quantitatively address this route of exposure.
NOAEL - No Observed Adverse Effects Level
OU - Operable Unit
- 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 for future construction workers exposed to soil and dust. The Risk Assessment
Guidance for Superfund (RAGS) states that, generally, a hazard index (HI) of greater than 1 indicates the potential for adverse noncancer effects. Results presented use toxicity values and site-specific exposure parameters from
the baseline HHRA. Soils and dust at EA2, EA6, EA7 and the Containment Area were at or below a HI of 0.1.
Source: A Guide to Preparing Superfund Proposed Plans, Records of Decision, and Other Remedy Selection Decision Documents (U.S. EPA, 1999)
Page 2 of 2
-------
ROD RISK WORKSHEET
Table G-10
OU1/2 Risk Characterization Summary - Carcinogens
Scenario Timeframe: Current/Future
Receptor Population: Trespasser
Receptor Age: Adult
Medium
Exposure
Medium
Exposure Point
Chemical of Concern
Carcinogenic Risk
Ingestion
Inhalation
Dermal
External
(Radiation)
Exposure
Routes Total
Soil
Surface Soil
EA1 OU1
Benzo(a)anthracene
1.9E-07
NA
9E-08
NA
3E-07
Benzo(a)pyrene
1.4E-06
NA
6E-07
NA
2E-06
Benzo{b)fIuoranthene
1.8E-07
NA
8E-08
NA
3E-07
Bis(2-Ethylhexyl)phthalate
3.3E-08
NA
1E-08
NA
5E-08
Carbazole
4.2E-10
NA
2E-10
NA
6E-10
Dibenz(a,h)anthracene
1.0E-07
NA
5E-08
NA
2E-07
!ndeno(1,2,3-cd)pyrene
8.3E-08
NA
4E-08
NA
1E-07
Aroclor-1260
2.2E-07
NA
1E-07
NA
3E-07
Arsenic
6.0E-07
NA
1E-07
NA
7E-07
Exposure Risk Total =
4E-06
Soil
Surface Soil
EA5
Benzo{a)anthracene
1.0E-07
NA
5E-08
NA
2E-07
Benzo{a)pyrene
6.8E-08
NA
3E-08
NA
1E-07
Benzo{b)fluoranthene
9.3E-09
NA
4E-09
NA
1E-08
Bis(2-Ethylhexyl)phthalate
8.8E-08
NA
3E-08
NA
1E-07
Carbazole
6.8E-11
NA
3E-11
NA
9E-11
!ndeno{1,2,3-cd)pyrene
5.8E-07
NA
3E-07
NA
9E-07
N-Nitrosodi-n-propyl amine
1.1E-07
NA
NA
1E-07
Arsenic
1.2E-06
NA
2E-07
NA
2E-06
Exposure Risk Total =
3E-06
Sediment
Sediment
Lower South Ditch
Benzo(a)anthracene
5E-08
NA
3E-08
NA
7E-08
Stream
Benzo(a)pyrene
2E-08
NA
8E-09
NA
2E-08
Bis(2-Ethylhexyl)phthalate
3E-07
NA
1E-07
NA
4E-07
Dibenz(a,h)anthracene
4E-08
NA
2E-08
NA
6E-08
Arsenic
2E-07
NA
3E-08
NA
2E-07
Surface Water
Surface Water
Lower South Ditch
Chloroform
1.7E-10
NA
2E-10
NA
4E-10
Stream
Benzo(a)pyrene
2.2E-08
NA
5E-06
NA
5E-06
Bis(2-Ethylhexyl)phthalate
1.7E-09
NA
3E-08
NA
3E-08
N-Nitrosodimethylamine
1.2E-07
NA
4E-09
NA
1E-07
Arsenic
9.5E-08
NA
1E-08
NA
1E-07
Hydrazine
4.9E-09
NA
3E-11
NA
5E-09
Exposure Risk Total =
6E-06
Page 1 of 3
-------
Table 6-10
OU1/2 Risk Characterization Summary - Carcinogens
Scenario Timeframe: Current/Future
Receptor Population: Trespasser
Receptor Age: Adult
Medium
Exposure Point
Chemical of Concern
Carcinogenic Risk
Medium
Ingestion
Inhalation
Dermal
External
Exposure
.. .{Radiation}..
Routes Total
Sediment
Sediment
Off-Property West
Benzo(a)anthracene
3E-09
NA
1E-09
NA
4E-09
Ditch Stream
Benzo(a)pyrene
3E-08
NA
2E-08
NA
5E-08
Benzo(b)fluoranthene
5E-09
NA
3E-09
NA
7E-09
Bis(2-Ethylhexyl)phthalate
3E-11
NA
1E-11
NA
5E-11
Carbazole
2E-11
NA
9E-12
NA
3E-11
Dibenz(a,h)anthracene
9E-09
NA
5E-09
NA
1E-08
Arsenic
4E-07
NA
5E-08
NA
5E-07
Surface Water
Surface Water
Off-Property West
Benzo(a)anthracene
3E-08
NA
4E-06
NA
4E-06
Ditch Stream
Benzo(a)pyrene
3E-07
NA
8E-05
NA
8E-05
Benzo(b)fiuoranthene
6E-08
NA
2E-05
NA
2E-05
Benzo(k)fluoranthene
4E-09
NA
_
NA
4E-09
Chrysene
4E-10
NA
6E-08
NA
6E-08
Dibenz(a,h)anthracene
2E-07
NA
7E-05
NA
7E-05
lndeno(1,2,3-cd)pyrene
3E-08
NA
8E-06
NA
8E-06
N-Nitrosodimethylamine
8E-08
NA
3E-09
NA
8E-08
Arsenic
3E-07
NA
3E-08
NA
3E-07
Exposure Risk Total =
2E-04
Sediment
Sediment
East Ditch Stream
Benzo(a)anthracene
1E-08
NA
6E-09
NA
2E-08
Benzo(a)pyrene
1E-07
NA
8E-08
NA
2E-07
Benzo(b)fiuoranthene
2E-08
NA
1E-08
NA
4E-08
Bis(2-Ethylhexyl)phthalate
3E-09
NA
1E-09
NA
4E-09
Carbazole
1E-10
NA
4E-11
NA
1E-10
Dibenz(a,h)anthracene
6E-09
NA
3E-09
NA
9E-09
Arsenic
1E-05
NA
2E-06
NA
2E-05
Surface Water
Surface Water
East Ditch Stream
Trichloroethene
2E-09
NA
3E-09
NA
5E-09
Vinyl chloride
2E-08
NA
1E-08
NA
3E-08
Bis(2-Ethylhexyl)phthalate
4E-10
NA
7E-09
NA
8E-09
Dibenz(a,h)anthracene
3E-08
NA
9E-06
NA
9E-06
lndeno(1,2,3-cd)pyrene
3E-09
NA
6E-07
NA
6E-07
N-Nitrosodimethylamine
7E-09
NA
2E-10
NA
7E-09
N-Nitrosodi-n-propylamine
5E-10
NA
2E-10
NA
7E-10
Arsenic
2E-07
NA
3E-08
NA
3E-07
Exposure Risk Total =
3E-05
Page 2 of 3
-------
Table 6-10
OU1/2 Risk Characterization Summary - Carcinogens
Scenario Timeframe: Current/Future
Receptor Population: Trespasser
Receptor Age: Adult
Medium
Exposure Point
Chemical of Concern
Carcinogenic Risk
Medium
Ingestion
Inhalation
Dermal
External
Exposure
.. (Radiation!
Routes Total
Sediment
Sediment
Maple Meadow
Benzo(a)anthracene
3E-09
NA
1E-09
NA
4E-09
Brook
Benzo(a)pyrene
3E-08
NA
1E-08
NA
4E-08
Benzo(b)fluoranthene
3E-09
NA
2E-09
NA
5E-09
Bis(2-Ethylhexyl)phthalate
6E-11
NA
2E-11
NA
8E-11
Carbazole
3E-11
NA
1E-11
NA
5E-11
Dibenz(a,h)anthracene
2E-08
NA
8E-09
NA
2E-08
Arsenic
7E-G7
NA
9E-08
NA
8E-07
Surface Water
Surface Water
Maple Meadow
Trichloroethene
4E-10
NA
7E-10
NA
1E-09
Brook
Benzo(a)pyrene
2E-08
NA
5E-06
NA
5E-G8
Benzo(b)fluoranthene
2E-09
NA
5E-G7
NA
5E-07
lndeno(1,2,3-cd)pyrene
3E-09
NA
7E-07
NA
7E-07
N-Nitrosodimethylamine
5E-10
NA
2E-11
NA
5E-10
N - N it ros od i-n -propyl am i n e
1E-10
NA
4E-11
NA
2E-10
Arsenic
2E-07
NA
2E-08
NA
2E-07
Hydrazine
4E-09
NA
2E-11
NA
4E-09
Exposure Risk Total =
7E-06
Sediment
Sediment
North Pond
Benzo(a)anthracene
1E-08
NA
5E-09
NA
2E-08
Benzo(a)pyrene
1E-07
NA
6E-08
NA
2E-07
Benzo(b)fluoranthene
2E-08
NA
9E-09
NA
3E-08
Bis(2-Ethylhexyl)phthalate
1E-09
NA
4E-10
NA
2E-09
Carbazole
7E-11
NA
3E-11
NA
9E-11
Arsenic
4E-07
NA
5E-08
NA
5E-07
Surface Water
Surface Water
North Pond
Benzo(a)anthracene
1.8E-09
NA
2E-G7
NA
3E-07
Benzo(a)pyrene
2.5E-08
NA
8E-06
NA
8E-08
Benzo(b)fluoranthene
4.0E-09
NA
1E-06
NA
1E-06
Benzo(k)fluoranthene
2.2E-10
NA
NA
2E-10
Bis(2-Ethylhexyl)phthalate
6.5E-10
NA
1E-08
NA
1E-08
Chrysene
4.3E-11
NA
6E-09
NA
6E-09
Exposure Risk Total =
8E-Q8
Key
EA - Exposure Area
NA - Esfiosure route not applicable for this chemical/exposure medium.
NC - Not carcinogenic by this exposure route.
OU - Operable Unit
- - Not calculated; dose-response data and/or dermal absorption values not available.
This table provides risk estimates for the significant routes of exposure for the current/future trespasser esfiosed to soil, s<
aliment and surface water, 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 adult trespassers' exposure to Site media, as well as the toxicity of the chemicals of concern. Risks for
IIHf current/future adult trespasser exposed to surface soil at EA2, surface soil at EA3, surface soil at EA4, surface soil at EA6, surface soil at EA7, sediment at the On-Property West Ditch Stream, sediment and
surface water at Upper South Ditch Stream, surface water and sediment at the Detention Basin, surface water and sediment at Central Pond, were at or below the risk screening threshold of 1x10-6.
Source: A Guide to Preparing Superfund Proposed Plans, Records of Decision, and Other Remedy Selection Decision Documents (U.S. EPA, 1999)
Page 3 of 3
-------
ROD RISK WORKSHEET
Table G-11
OU1/2 Risk Characterization Summary - Carcinogens
Scenario Timeframe: Current/Future
Receptor Population: Trespasser
Receptor Age: Adolescent
Medium
Exposure
Medium
Exposure Point
Chemical of Concern
Carcinogenic Risk
Ingestion
Inhalation
Dermal
External
(Radiation)
Exposure
Routes Total
Soil
Surface Soil
EA1 OU1
Benzo(a)anthracene
6E-07
NA
6E-07
NA
1E-06
Benzo(a)pyrene
5E-06
NA
4E-06
NA
9E-06
Benzo{b)fIuoranthene
6E-07
NA
5E-07
NA
1E-06
Bis(2-Ethylhexyl)phthalate
4E-08
NA
3E-08
NA
6E-08
Carbazole
5E-10
NA
3E-10
NA
8E-10
Dibenz(a,h)anthracene
4E-07
NA
3E-07
NA
7E-07
!ndeno(1,2,3-cd)pyrene
3E-07
NA
2E-07
NA
5E-07
Aroclor-1260
3E-07
NA
2E-07
NA
5E-07
Arsenic
7E-07
NA
2E-07
NA
9E-07
Exposure Risk Total =
1E-05
Soil
Surface Soil
EA2 OU1
Benzo{a)anthracene
3E-08
NA
2E-08
NA
5E-08
Benzo{a)pyrene
2E-07
NA
2E-07
NA
4E-07
Benzo{b)fluoranthene
3E-08
NA
3E-08
NA
6E-08
Bis(2»Ethylhexyl)phthalate
9E-08
NA
6E-08
NA
2E-07
Dibenz(a,h)anthracene
3E-07
NA
3E-07
NA
6E-07
!ndeno{1,2,3-cd)pyrene
2E-08
NA
2E-08
NA
4E-08
Arsenic
5E-07
NA
2E-07
NA
7E-07
Exposure Risk Total =
2E-06
Soii
Surface Soil
EA3 OU1
Benzo(a)anthracene
1E-08
NA
1E-08
NA
2E-08
Benzo(a)pyrene
1E-07
NA
1E-07
NA
3E-07
Benzo(b)fluoranthene
2E-08
NA
2E-08
NA
4E-08
Bis(2-Ethylhexyl)phthalate
5E-09
NA
3E-09
NA
7E-09
Dibenz(a,h)anthracene
3E-07
NA
3E-07
NA
6E-07
lndeno{1,2,3-cd)pyrene
2E-08
NA
1E-08
NA
3E-08
Aroclor-1260
2E-08
NA
2E-08
NA
4E-08
Arsenic
4E-07
NA
2E-07
NA
6E-07
Surface Soil Risk Total =
2E-06
Soil
Surface Soil
EA4 OU1
Benzo(a)anthracene
4E-08
NA
3E-08
NA
7E-08
Benzo(a)pyrene
4E-07
NA
3E-07
NA
7E-07
Benzo{b)fluoranthene
3E-08
NA
3E-08
NA
6E-08
Bis(2-Ethylhexyl)phthalate
3E-08
NA
2E-08
NA
5E-08
Dibenz(a, h)anthracene
4E-07
NA
3E-07
NA
7E-07
Indeno(1,2,3-cd)pyrene
4E-08
NA
4E-08
NA
8E-08
Arsenic
8E-07
NA
3E-07
NA
1E-06
Exposure Risk Total =
3E-06
Page 1 of 5
-------
Table G-11
OU1/2 Risk Characterization Summary - Carcinogens
Scenario Timeframe: Current/Future
Receptor Population: Trespasser
Receptor Age: Adolescent
Soil
Surface Soil
EA5
Benzo(a)anthracene
4E-07
NA
3E-07
NA
7E-07
Benzo{a)pyrene
2E-07
NA
2E-07
NA
4E-07
Benzo(b)fluoranthene
3E-08
NA
3E-08
NA
6E-08
Bis{2-Ethylhexyl)phthalate
1E-07
NA
7E-08
NA
2E-07
Carbazole
8E-11
NA
5E-11
NA
1E-10
!ndeno(1,2,3-cd)pyrene
2E-06
NA
2E-06
NA
4E-06
N-Nitrosodi-n-propylamine
1E-07
NA
NA
1E-07
Arsenic
1E-06
NA
5E-07
NA
2E-06
Exposure Risk Total =
7E-06
Soil
Surface Soil
EA6 OU1
Benzo(a)anthracene
3E-08
NA
2E-08
NA
5E-08
Benzo(a)pyrene
6E-07
NA
5E-07
NA
1E-06
Benzo(b)fluoranthene
3E-08
NA
2E-08
NA
5E-08
Bis(2~Ethylhexyl)phthalate
4E-08
NA
2E-08
NA
6E-08
Carbazole
3E-11
NA
2E-11
NA
5E-11
Dibenz(a,h)anthracene
1E-07
NA
1E-07
NA
2E-07
!ndeno(1,2,3-cd)pyrene
3E-08
NA
3E-08
NA
5E-08
Arsenic
5E-07
NA
2E-07
NA
7E-07
Exposure Risk Total =
2E-06
Sediment
Sediment
Upper South Ditch
Bromodichloromethane
6E-10
NA
4E-10
NA
1E-09
Stream
Chloroform
6E-10
NA
4E-10
NA
1E-09
Azobenzene
1E-09
NA
NA
1E-09
Bis(2-Ethylhexyl)phthalate
6E-10
NA
6E-09
NA
7E-09
N-Nitrosodimethylamine
7E-07
NA
1E-08
NA
7E-07
N-Nitrosodi-n-propylamine
1E-09
NA
2E-10
NA
1E-09
Arsenic
1E-07
NA
8E-09
NA
1E-07
Hydrazine
5E-09
NA
2E-11
NA
5E-09
Surface Water
Surface Water
Upper South Ditch
Bromodichloromethane
6E-10
NA
4E-10
NA
1E-09
Stream
Chloroform
6E-10
NA
4E-10
NA
1E-09
Azobenzene
1E-09
NA
-
NA
1E-09
Bis(2-Ethylhexyl)phthalate
6E-10
NA
6E-09
NA
7E-09
N-Nitrosodimethylamine
7E-07
NA
1E-08
NA
7E-07
N-Nitrosodi-n-propylamine
1E-09
NA
2E-10
NA
1E-09
Arsenic
1E-07
NA
8E-09
NA
1E-07
Hydrazine
5E-09
NA
2E-11
NA
5E-09
Exposure Risk Total =
2E-06
Page 2 of 5
-------
Table G-11
OU1/2 Risk Characterization Summary - Carcinogens
Scenario Timeframe: Current/Future
Receptor Population: Trespasser
Receptor Age: Adolescent
Sediment
Sediment
Lower South Ditch
Benzo{a)anthracene
2E-07
NA
2E-07
NA
4E-07
Stream
Benzo(a)pyrene
5E-08
NA
6E-08
NA
1E-07
Bis(2-Ethylhexyl)phthalate
3E-07
NA
3E-07
NA
6E-07
Dibenz{a,h)anthracene
1E-07
NA
2E-07
NA
3E-07
Arsenic
2E-07
NA
7E-08
NA
3E-07
Surface Water
Surface Water
Lower South Ditch
Chloroform
2E-10
NA
1E-10
NA
3E-10
Stream
Benzo(a)pyrene
8E-08
NA
1E-05
NA
1E-05
Bis(2-Ethylhexyi)phthaiate
2E-09
NA
2E-08
NA
2E-08
N-Nitrosodimethyiamine
4E-07
NA
9E-09
NA
4E-07
Arsenic
1E-07
NA
7E-09
NA
1E-07
Hydrazine
6E-09
NA
2E-11
NA
6E-09
Exposure Risk Total =
1E-05
Sediment
Sediment
Off-Property West
Benzo(a)anthracene
8.6E-09
NA
1.1E-08
NA
1.9E-08
Ditch Stream
Benzo(a)pyrene
1.0E-07
NA
1.3E-07
NA
2.3E-07
Benzo(b)fiuoranthene
1.6E-08
NA
1.9E-08
NA
3.5E-08
Bis(2-Ethylhexyi)phthaiate
3.9E-11
NA
3.7E-11
NA
7.6E-11
Carbazoie
2.4E-11
NA
2.2E-11
NA
4.6E-11
Dibenz(a, h)anthracene
3.1E-08
NA
3.8E-08
NA
6.9E-08
Arsenic
4.9E-07
NA
1.4E-07
NA
6.2E-07
Surface Water
Surface Water
Off-Property West
Benzo(a)anthracene
1E-07
NA
9E-06
NA
9E-06
Ditch Stream
Benzo(a)pyrene
1E-06
NA
2E-04
NA
2E-04
Benzo(b)fiuoranthene
2E-07
NA
3E-05
NA
3E-05
Benzo(k)fiuoranthene
1E-08
NA
NA
1E-08
Chrysene
2E-09
NA
1E-07
NA
1E-07
Dibenz(a,h)anthracene
6E-07
NA
1E-04
NA
1E-04
lndeno(1,2,3-cd)pyrene
1E-07
NA
2E-05
NA
2E-05
N-Nitrosodimethyiamine
3E-07
NA
6E-09
NA
3E-07
Arsenic
3E-07
NA
2E-08
NA
3E-07
Exposure Risk Iota! =
4E-04
Page 3 of 5
-------
Table G-11
OU1/2 Risk Characterization Summary - Carcinogens
Scenario Timeframe: Current/Future
Receptor Population: Trespasser
Receptor Age: Adolescent
Sediment
Sediment
East Ditch Stream
Benzo{a)anthracene
4E-08
NA
5E-08
NA
9E-08
Benzo{a)pyrene
5E-07
NA
6E-07
NA
1E-06
Benzo(b)fluoranthene
8E-08
NA
1E-07
NA
2E-07
Bis(2-Ethylhexyi)phthalate
3E-09
NA
3E-09
NA
6E-09
Carbazole
1E-10
NA
1E-10
NA
2E-10
Dibenz(a,h)anthracene
2E-08
NA
2E-08
NA
4E-08
Arsenic
2E-05
NA
5E-06
NA
2E-05
Surface Water
Surface Water
East Ditch Stream
Trichloroethene
2E-09
NA
2E-09
NA
4E-09
Vinyl chloride
2E-08
NA
8E-09
NA
2E-08
Bis(2-Ethylhexyl)phthalate
5E-10
NA
5E-09
NA
6E-09
Dibenz(a,h)anthracene
9E-08
NA
2E-05
NA
2E-05
!ndeno(1,2,3-cd)pyrene
9E-09
NA
1E-06
NA
1E-06
N-Nitrosodimethylamine
2E-08
NA
5E-10
NA
3E-08
N-Nitrosodi-n-propylamine
5E-10
NA
1E-10
NA
7E-10
Arsenic
3E-07
NA
2E-08
NA
3E-07
Exposure Risk Total =
4E-05
Sediment
Sediment
Maple Meadow
Benzo{a)anthracene
9E-09
NA
1E-08
NA
2E-08
Brook
Benzo(a)pyrene
9E-08
NA
1E-07
NA
2E-07
Benzo(b)fluoranthene
1E-08
NA
1E-08
NA
3E-08
Bis(2-Ethylhexyl)phthalate
6E-11
NA
6E-11
NA
1E-10
Carbazole
4E-11
NA
4E-11
NA
7E-11
Dibenz(a,h)anthracene
5E-08
NA
6E-08
NA
1E-07
Arsenic
8E-07
NA
2E-07
NA
1E-06
Surface Water
Surface Water
Maple Meadow
Trichloroethene
4E-10
NA
5E-10
NA
9E-10
Brook
Benzo(a)pyrene
7E-08
NA
1E-05
NA
1E-05
Benzo(b)fluoranthene
7E-09
NA
1E-06
NA
1E-06
!ndeno(1,2,3-cd)pyrene
1E-08
NA
2E-06
NA
2E-06
N-Nitrosodimethylamine
2E-09
NA
4E-11
NA
2E-09
N-Nitrosodi-n-propylamine
1E-10
NA
3E-11
NA
2E-10
Arsenic
2E-07
NA
1E-08
NA
2E-07
Hydrazine
4E-09
NA
1E-11
NA
4E-09
Exposure Risk Total =
1E-05
Page 4 of 5
-------
Table G-11
OU1/2 Risk Characterization Summary - Carcinogens
Scenario Timeframe: Current/Future
Receptor Population: Trespasser
Receptor Age: Adolescent
Sediment
Sediment
North Pond
Benzo{a)anthracene
3E-08
NA
4E-08
NA
8E-08
Benzo{a)pyrene
4E-07
NA
4E-07
NA
8E-07
Benzo(b)fluoranthene
6E-08
NA
7E-08
NA
1E-07
Bis(2-Ethylhexyl)phthalate
1E-09
NA
1E-09
NA
2E-09
Carbazole
7E-11
NA
7E-11
NA
1E-10
Arsenic
5E-07
NA
1E-Q7
NA
6E-07
Surface Water
Surface Water
North Pond
Benzo{a)anthracene
6E-09
NA
5E-07
NA
5E-07
Benzo(a)pyrene
9E-08
NA
1E-05
NA
1E-05
Benzo{b)fluoranthene
1E-08
NA
2E-06
NA
2E-06
Benzo{k)fluoranthene
8E-10
NA
NA
8E-10
Bis(2-Ethylhexyl)phthalate
7E-10
NA
8E-09
NA
8E-09
Chrysene
2E-10
NA
1E-08
NA
1E-08
Exposure Risk Total =
2E-05
Key
EA - Exposure Area
NA - Exposure route not applicable for this chemical/exposure medium.
NC - Not carcinogenic by this exposure route.
OU - Operable Unit
- - Not calculated; dose-response data and/or dermal absorption values not available.
This table provides risk estimates for the significant routes of exposure for the current/future adolescent trespasser exposed to Site media. 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 adolescent trespasser exposure to soil and dust, as well as the toxicity of the chemicals of concern. Risks for the
current/future adult trespasser exposed to surface soil at EA7, sediment at the On-Property West Ditch Stream, surface water and sediment at the Detention Basin, surface water and sediment at Central Pond were at
or below the risk screening threshold of 1x10-6.
Source: A Guide to Preparing Superfund Proposed Plans, Records of Decision, and Other Remedy Selection Decision Documents (U.S. EPA, 1999)
Page 5 of 5
-------
ROD RISK WORKSHEET
Table G-12
OU1/2 Risk Characterization Summary - Carcinogens
Scenario Timeframe: Future
Receptor Population: Outdoor Worker
Receptor Age: Adult
Medium
Exposure
Medium
Exposure Point
Chemical of Concern
Carcinogenic Risk
Ingestion
Inhalation
Dermal
External
(Radiation)
Exposure
Routes Total
Soil
Subsurface Soil /
EA1 OU1
Benzo(a)anthracene
7E-09
2E-13
6E-09
NA
1E-08
dust (inhalation)
Benzo(a)pyrene
9E-08
2E-12
8E-08
NA
2E-07
Benzo(b)fluoranthene
1E-08
3E-13
1E-08
NA
2E-08
Benzo(k)fluoranthene
6E-10
2E-13
5E-10
NA
1E-09
Bis(2-Ethylhexyl)phthalate
7E-07
2E-11
5E-07
NA
1E-06
Carbazole
1E-10
NC
7E-11
NA
2E-10
indeno(1,2,3-cd)pyrene
3E-08
7E-13
2E-08
NA
5E-08
N-Nitrosodiphenylamine
4E-07
4E-11
NA
4E-07
Aroclor-1260
7E-07
3E-11
6E-07
NA
1E-06
Arsenic
1E-06
1E-09
4E-07
NA
2E-06
Chromium, Hexavalent
NC
3E-09
NC
NA
3E-09
Exposure Risk Total =
5E-06
Soil
Subsurface Soil /
EA3 OU1
Bis(2-Ethylhexyl)phthalate
2E-05
5E-10
1E-05
NA
3E-05
dust (inhalation)
N-Nitrosodiphenylamine
4E-10
3E-14
-
NA
4E-10
Arsenic
1E-06
1E-09
4E-07
NA
2E-06
Chromium, Hexavalent
NC
4E-10
NC
NA
4E-10
Hydrazine
4E-09
1E-12
NC
NA
4E-09
Exposure Risk Total =
3E-05
Soii
Surface Soil
EA5
Benzo(a)anthracene
5E-07
NA
5E-07
NA
1E-06
Benzo(a)pyrene
4E-07
NA
3E-07
NA
7E-07
Benzo(b)fluoranthene
5E-08
NA
4E-08
NA
9E-08
Bis(2-Ethylhexyl)phthalate
5E-07
NA
3E-07
NA
8E-07
Carbazole
4E-10
NA
2E-10
NA
6E-10
!ndeno(1,2,3-cd)pyrene
3E-06
NA
3E-06
NA
6E-06
N-Nitrosodi-n-propylamine
6E-07
NA
NA
6E-07
Arsenic
6E-06
NA
2E-06
NA
9E-06
Exposure Risk Total =
2E-05
Soil
Subsurface Soil /
EA7 OU1
Benzo(a)anthracene
4E-07
9E-12
3E-07
NA
7E-07
dust (inhalation)
Benzo(a)pyrene
4E-06
1E-10
3E-06
NA
7E-06
Benzo(b)fluoranthene
4E-06
1E-10
3E-06
NA
7E-06
Bis(2-Ethylhexyl)phthalate
1E-06
3E-11
7E-07
NA
2E-06
lndeno(1,2,3-cd)pyrene
2E-07
5E-12
2E-07
NA
3E-07
N-Nitrosodiphenylamine
4E-09
4E-13
NA
4E-09
Arsenic
2E-06
1E-09
5E-07
NA
2E-06
Chromium, Hexavalent
NC
6E-10
NC
NA
6E-10
Hydrazine
7E-1G
2E-13
NC
NA
7E-10
Exposure Risk Total =
2E-05
Page 1 of 2
-------
Table G-12
OU1/2 Risk Characterization Summary - Carcinogens
Scenario Timeframe: Future
Receptor Population: Outdoor Worker
Receptor Age: Adult
Medium
Exposure Point
Chemical of Concern
Carcinogenic Risk
Medium
Ingestion
Inhalation
Dermal
External
Exposure
.. .(Radiation}..
Routes Total
Soil
Surface Soil /
Containment Area
Benzo{a)anthracene
4E-09
1E-13
4E-09
NA
8E-09
dust (inhalation)
OU1
Benzo(a)pyrene
4E-08
1E-12
3E-08
NA
7E-08
Benzo(b)fluoranthene
6E-09
2E-13
5E-09
NA
1E-08
Bis(2-Ethylhexyl)phthalate
5E-09
1E-13
3E-09
NA
8E-09
Arsenic
4E-06
3E-09
1E-06
NA
5E-06
Cobalt
NC
2E-09
NC
NA
2E-09
Chromium, Hexavaient
NC
3E-09
NC
NA
3E-09
Exposure Risk Total =
5E-06
Key
EA - Exposure Area
NA - Exposure route not applicable for this chemical/exposure medium,
NC - Not carcinogenic by this exposure route.
OU - Operable Unit
- - Not calculated; dose-response data and/or dermal absorption values not available.
This table provides risk estimates for the significant routes of exposure for the future outdoor worker exposed to soil and dust. Future (non-current) exposures include subsurface sol as well as surface sol at the
Containment Area {currently capped) and EA5 {not currently accessible to outdoor workers). 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 adult outdoor workers' exposure to soil and dust, as well as the tenacity of the chemicals of concern.
Source: A Guide to Preparing Superfund Proposed Plans, Records of Decision, and Other Remedy Selection Decision Documents (U.S. EPA, 1999)
Page 2 of 2
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ROD RISK WORKSHEET
Table G-13
OU1/2 Risk Characterization Summary - Non-Carcinogens
Scenario Timeframe: Future
Receptor Population: Outdoor Worker
Receptor Age: Adult
Medium
Exposure
Exposure Point
Chemical of Concern
Primary Target Organ
Non-Carcinogenic Hazard Quotient
Medium
Ingestion
Inhalation
Dermal
Exposure
Routes Total
Soil
Subsurface Soil /
EA3
2,4,4-Trimethyl-1-pentene
Liver
3E-03
1E-07
_
3E-03
dust (inhalation)
2,4,4-T rimethyl-2-pentene
Liver
3E-04
2E-08
3E-04
Bis(2-Ethylhexyl)phthalate
Liver
2E-01
6E-06
1E-01
3E-01
C11-C22 Aromatics
6E-02
_
3E-02
9E-02
Antimony
General Toxicity /
1E-03
_
_
1E-03
Arsenic
Skin / Hematologics
7E-03
4E-05
2E-03
1E-02
Chromium, Hexavalent
NOAEL
2E-Q4
9E-07
-
2E-04
Nitrogen, as Ammonia
Respiratory
_
1E-08
_
1E-08
Hydrazi ne
-
2E-08
2E-08
Exposure Point Total -
4E-01
Soil
Surface Soil
EA5
Benzo(a)anthracene
Kidney
7E-05
NA
6E-05
1E-04
Benzo(a)pyrene
Kidney
5E-06
NA
4E-06
8E-06
Benzo(b)fluoranthene
Kidney
6E-06
NA
5E-06
1E-05
Bis(2-Ethylhexyl)phtha!ate
Liver
5E-03
NA
3E-03
8E-03
C11-C22 Aromatics
2E-01
NA
1E-01
4E-01
lndeno(1,2,3-cd)pyrene
Kidney
4E-04
NA
3E-04
7E-04
Antimony
General Toxicity I
8E-04
NA
_
8E-04
Arsenic
Skin / Hematologica
4E-02
NA
1E-02
5E-02
Chromium, Hexavalent
NOAEL
7E-02
NA
7E-02
Cobalt
Endocrine
2E-02
NA
_
2E-02
Silver
Skin 1 Eye / Respiratory
2E-01
NA
_
2E-01
Thallium
NOAEL
7E-01
NA
_
7E-01
Exposure Point Total =
1E+00
Key
EA - Ejpwire Area
NA - Toxicity criteria are riot available to quantitatively address this route of exposure.
NOAEL - No Observed Adverse Effects Level
OU - Operable Unit
—- Not calculated; dose-response data and/or dermal absorption values not available.
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 for future outdoor workers exposed to soil and dust. The Risk Assessment Guidance for
Superfund (RAGS) states that, generally,
hazard index (HI) of greater than 1 indicates the potential for adverse noncancer effects. Results presented use toxicity values and site-specific exposure parameters from the baseline HHRA,
Soils and dust at EA1, EA2, EA3 (surface
soil only), EA6, EAT and the Containment Area were at or below a Hi of 0.1.
Source: A Guide to Preparing Superfund Proposed Plans, Records of Decision, and Other Remedy Selection Decision Documents (U.S. EPA, 1999)
Page 1 of 1
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ROD RISK WORKSHEET
Table G-14
OU1/2 Risk Characterization Summary - Carcinogens
Scenario Timeframe: Future
Receptor Population: Indoor Worker
Receptor Age: Adult
Medium
Exposure
Exposure Point
Chemical of Concern
Carcinogenic Risk
Medium
Ingestion
Inhalation
Dermal
External
(Radiation)
Exposure
Routes Total
Soil
Surface Soil
EA3 OU1
Benzo(a)anthracene
1E-08
NA
6E-09
NA
2E-08
Benzo(a)pyrene
1E-07
NA
7E-08
NA
2E-07
Benzo(b)fluoranthene
2E-08
NA
1E-08
NA
3E-08
Bis(2-Ethylhexyl)phthalate
1E-08
NA
5E-09
NA
2E-08
Dibenz(a,h)anthracene
3E-07
NA
2E-07
NA
4E-07
!ndeno(1,2,3-cd)pyrene
1E-08
NA
7E-09
NA
2E-08
Aroclor-1260
5E-08
NA
3E-08
NA
8E-08
Arsenic
1E-06
NA
3E-07
NA
1E-06
Surface Soil Risk Total =
2E-06
Soil
Subsurface Soil
EA3 OU1
Bis(2-Ethylhexyl)phthalate
9E-06
NA
4E-06
NA
1E-05
N-Nitrosodiphenylamine
2E-10
NA
NA
2E-10
Arsenic
6E-07
NA
2E-07
NA
8E-07
Hydrazine
2E-09
NA
-
NA
2E-09
Surface Soil Risk Total =
1E-05
Soil
Surface Soil
EA7 OU1
Benzo{a)anthracene
8E-09
NA
5E-09
NA
1E-08
Benzo(a)pyrene
9E-08
NA
5E-08
NA
2E-07
Benzo{b)fluoranthene
1E-08
NA
6E-09
NA
2E-08
Bis(2-Ethylhexyl)phthaiate
1E-08
NA
4E-09
NA
1E-08
lndeno{1,2,3-cd)pyrene
2E-08
NA
1E-08
NA
3E-08
Arsenic
2E-06
NA
5E-07
NA
3E-06
Surface Soil Risk Total =
3E-06
Soil
Subsurface Soil
EA7 OU1
Benzo(a)anthracene
2E-13
NA
0E+00
NA
2E-13
Benzo(a)pyrene
2E-12
NA
0E+00
NA
2E-12
Benzo(b)fluoranthene
2E-12
NA
OE+OQ
NA
2E-12
Bis(2-Ethylhexyl)phthalate
6E-07
NA
3E-07
NA
8E-07
lndeno(1,2,3-cd)pyrene
1E-13
NA
0E+00
NA
1E-13
N-Nitrosodiphenylamine
3E-09
NA
NA
3E-09
Arsenic
8E-07
NA
2E-07
NA
1E-06
Hydrazine
4E-10
NA
-
NA
4E-10
Surface Soil Risk Total =
2E-06
Page 1 of 2
-------
Table G-14
OU1/2 Risk Characterization Summary - Carcinogens
Scenario Timeframe: Future
Receptor Population: Indoor Worker
Receptor Age: Adult
Medium
Exposure
Exposure Point
Chemical of Concern
Carcinogenic Risk
Medium
Ingestion
Inhalation
Dermal
External
Exposure
(Radiation)
Routes Total
Soil
Surface Soil
Containment Area
Benzo(a)anthracene
2E-09
NA
2E-09
NA
4E-09
Benzo(a)pyrene
2E-08
NA
1E-08
NA
4E-08
Benzo(b)fluoranthene
3E-09
NA
2E-09
NA
6E-09
Bis(2-Ethylhexyt)phthalate
3E-09
NA
1E-09
NA
4E-09
Arsenic
2E-06
NA
5E-07
NA
3E-06
Surface Soil Risk Total =
3E-06
Key
EA - Exposure Area
NA - E^osure route not applicable for this chemical/exposure medium.
OU - Operable Unit
-- - Not calculated; dose-response data and/or dermal absorption values not available.
This table provides risk estimates for the significant routes of exposure for the future indoor worker exposed to soil. These risk estimates are base
d on a reasonable maximum exposure and were developed by taking
into account various conservative assumptions about the frequency and duration of adult indoor workers' exposure to soil
as well as the toxicity of the chemicals of concern.
Source: A Guide to Preparing Superfund Proposed Plans, Records of Decision, and Other Remedy Selection Decision Documents (U.S. EPA, 1999)
Page 2 of 2
-------
ROD RISK WORKSHEET
Table G 15
OU1/2 Risk Characterization Summary - Carcinogens
Scenario Timeframe: Future
Receptor Population: Trespasser
Receptor Age: Adult
Medium
Exposure
Exposure Point
Chemical of Concern
Carcinogenic Risk
Medium
Ingestion
Inhalation
Dermal
External
(Radiation)
Exposure
Routes Total
Soil
Subsurface Soil
EA3 OU1
Bis(2-Ethylhexyl)phthalate
3E-06
NA
1E-06
NA
4E-06
N-Nitrosodiphenylamine
7E-11
NA
-
NA
7E-11
Arsenic
2E-07
NA
4E-08
NA
3E-07
Hydrazine
7E-10
NA
..
NA
7E-10
Surface Soil Risk Total =
4E-06
Soil
Subsurface Soil
EA7 OU1
Benzo(a)anthracene
7E-08
NA
3E-08
NA
1E-07
Benzo(a)pyrene
8E-07
NA
4E-07
NA
1E-06
Benzo(b)fluoranthene
8E-07
NA
4E-07
NA
1E-06
Bis(2-Ethylhexyl)phthalate
2E-07
NA
7E-08
NA
3E-07
lndeno(1,2,3-cd)pyrene
4E-08
NA
2E-08
NA
5E-08
N-Nitrosodiphenylamine
9E-10
NA
-
NA
9E-10
Arsenic
3E-07
NA
5E-08
NA
3E-07
Hydrazine
1E-10
NA
..
NA
1E-10
Surface Soil Risk Total =
3E-06
Key
EA - Exposure Area
NA - Exposure route not applicable for this chemical/exposure medium.
OU - Operable Unit
- - - Not calculated; dose-response data and/or dermal absorption values not available.
This table provides risk estimates for the significant routes of exposure for the future adult trespasser exposed to soil. 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 adult trespasser exposure to soil as well as the toxicity of the chemicals of concern. Risks for the future adult trespasser
exposed to subsurface soil/dust at EA1 and were below the risk screening threshold of 1x10-6.
Source: A Guide to Preparing Superfund Proposed Plans, Records of Decision, and Other Remedy Selection Decision Documents (U.S. EPA, 1999)
Page 1 of 1
-------
ROD RISK WORKSHEET
Table G 16
OU1/2 Risk Characterization Summary - Carcinogens
Scenario Timeframe: Future
Receptor Population: Trespasser
Receptor Age: Adolescent
Medium
Exposure
Exposure Point
Chemical of Concern
Carcinogenic Risk
Medium
Ingestion
Inhalation
Dermal
External
(Radiation)
Exposure
Routes Total
Soil
Subsurface Soil
EA3 OU1
Bis(2-Ethylhexyl)phthalate
3E-06
NA
2E-06
NA
6E-06
N-Nitrosodiphenylamine
8E-11
NA
-
NA
8E-11
Arsenic
3E-07
NA
8E-08
NA
3E-07
Hydrazine
8E-10
NA
_
NA
8E-10
Exposure Risk Total -
6E-06
Soil
Subsurface Soil
EA7 0U1
Benzo(a)anthracene
2E-07
NA
2E-Q7
NA
4E-07
Benzo(a)pyrene
3E-06
NA
2E-06
NA
5E-06
Benzo(b)fluoranthene
3E-06
NA
2E-06
NA
5E-06
Bis(2-Ethylhexyl)phthalate
2E-07
NA
1E-07
NA
4E-07
I ndeno( 1,2,3-cd)pyrene
1E-07
NA
1E-Q7
NA
2E-07
Arsenic
3E-07
NA
1E-07
NA
4E-07
Hydrazine
2E-10
NA
_
NA
2E-10
Exposure Risk Total =
1E-05
Key
EA - Exposure Area
NA - Exposure route not applicable for this chemical/exposure medium.
OU - Operable Unit
- - Not calculated; dose-response data and/or dermal absorption values not available.
This table provides risk estimates for the significant routes of exposure for the future adolescent trespasser exposed to soil. 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 adolescent trespasser exposure to soil, as well as the toxicity of the chemicals of concern. Risks for the
future adolescent trespasser exposed to subsurface soil at EA1 and the Containment Area were at or below the risk screening threshold of 1x10-6.
Source: A Guide to Preparing Superfund Proposed Plans, Records of Decision, and Other Remedy Selection Decision Documents (U.S. EPA, 1999)
Page 1 of 1
-------
ROD RISK WORKSHEET
Table G-17
OU3 Risk Characterization Summary - Carcinogens
Scenario Timeframe: Future
Receptor Population: Resident
Receptor Age: Adult
Medium
Exposure Point
Chemical of Concern
Carcinogenic Risk
Medium
Ingestion
Inhalation
Dermal
External
Exposure
(Radiation)
Routes Total
Groundwater
Overburden
Ipswich Aquifer
Volatile Organic Compounds
Groundwater/
Plume Core -
1,1-Dichloroethane
5.4E-08
3.7E-07
4.1E-09
NA
4.3E-07
Shower Air
Overburden
1,2,4-T richlorobenzene
2.7E-07
NC
3.7E-07
NA
6.4E-07
1,2-Dichloroethane
4.3E-06
2.7E-05
2.0E-07
NA
3.2E-05
1,4-Dichlorobenzene
1.6E-08
6.7E-07
1.1E-08
NA
7 0E-07
Benzene
3.4E-07
4.8E-06
5.2E-08
NA
5.2E-06
Chloroform
1.1E-07
1 9E-06
9.8E-09
NA
2.0E-06
Methyl Tertbutyl Ether
4.1E-07
1.2E-06
9.2E-09
NA
1.6E-06
Naphthalene
7.3E-07
3.3E-06
4.6E-07
NA
4.5E-06
Trichloroethene
2.6E-05
5.4E-05
4.2E-06
NA
8.4E-05
Vinyl chloride
7.6E-04
1.4E-04
5.9E-05
NA
9.6E-04
Semi-Volatile Organic Compounds
4-Chlorophenyl phenyl ether
8.9E-09
NC
1.3E-08
NA
2.2E-08
Biphenyl
8.2E-08
NC
1.2E-07
NA
2.0E-07
N-Nitrosodimethylamine
6.8E-03
5.3E-04
1.7E-05
NA
7.3E-03
Metals
Arsenic
3.4E-04
NC
1 9E-06
NA
3.4E-04
Specialty Compounds
Formaldehyde
NC
1.1E-07
NC
NA
1.1E-07
Exposure Risk Total =
9E-03
Page 1 of 2
-------
Table G-17
OU3 Risk Characterization Summary - Carcinogens
Scenario Timeframe: Future
Receptor Population: Resident
Receptor Age: Adult
Medium
Exposure Point
Chemical of Concern
Carcinogenic Risk
Medium
Ingestion
Inhalation
Dermal
External
Exposure
(Radiation)
Routes Total
Groundwater
Bedrock
Ipswich Aquifer
Volatile Organic Compounds
Groundwater/
Plume Core -
1,2,4-T richlorobenzene
1.8E-07
NC
2.5E-07
NA
4.3E-07
Shower Air
Bedrock
1,2-Dichloroethane
6.1E-06
3.8E-05
2 9E-07
NA
4.4E-05
1,4-Dichlorobenzene
1.9E-08
8.1E-07
1 3E-08
NA
8.4E-07
Benzene
2.0E-07
2 9E-06
3.1E-08
NA
3.1E-06
Bromodichloromethane
1.2E-07
1.3E-06
8.0E-09
NA
1.4E-06
Chloroform
1.3E-06
2.2E-05
1.1E-07
NA
2.3E-05
Methylene chloride
5.8E-08
7.4E-09
2.1E-09
NA
6.8E-08
Trichloroethene
3.5E-05
7.2E-05
5.6E-06
NA
1.1E-04
Vinyl chloride
1 5E-05
2.7E-06
1.1E-06
NA
1.9E-05
Semi-Volatile Organic Compounds
Benzo(a)anthracene
3.1E-07
1 9E-07
NC
NA
5.0E-07
Benzo(a)pyrene
2.4E-06
NC
NC
NA
2.4E-06
Dibenz(a,h)anthracene
3.1 E-Q6
NC
NC
NA
3 1E-06
N-Nitrosodimethylamine
1.4E-02
1.1E-03
3.5E-05
NA
1.5E-02
Pentachlorophenol
3.2E-06
NC
1 4E-05
NA
1.7E-05
Metals
Arsenic
7.2E-05
NC
4.0E-07
NA
7.2E-05
Chromium, Hexavalent
6.1E-06
NC
2.3E-06
NA
8.4E-06
Specialty
Formaldehyde
NC
1 2E-07
NC
NA
1.2E-07
Hydrazine
1.7E-06
4.1E-07
6.1E-10
NA
2.1E-06
Exposure Risk Total =
2E-02
Key
NA - Exposure route not applicable for this chemical/exposure medium.
NC - Not carcinogenic by this expsoure route.
This table provides risk estimates for the significant routes of exposure for the future adult residents exposed to groundwater in the Ipswich Watershed. 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 adult resident exposure to groundwater, as well as the toxicity of the
COCs.
Source: A Guide to Preparing Superfund Proposed Plans, Records of Decision, and Other Remedy Selection Decision Documents (U.S. EPA, 1999)
Page 2 of 2
-------
ROD RISK WORKSHEET
Table G-18
OU3 Risk Characterization Summary - Non-Carcinogens
Scenario Timeframe: Future
Receptor Population: Resident
Receptor Age: Adult
Medium
Exposure
Exposure
Chemical of Concern
Primary Target Organ
Non-Carcinogenic Hazard Quotient
Medium
Point
Ingestion
Inhalation
Dermal
Exposure
Routes Total
Groundwater
Overburden
Ipswich Aquifer
Volatile Organic Compounds
Groundwater/
Plume Core -
1,1-Dichloroethane
Kidney
0.00016
NA
0.000013
0.00017
Shower Air
Overburden
1,2,4-Trichlorobenzene
Endocrine f Urinary
0.0033
0.29
0.0044
0.30
1,2-DichIoroethane
Undetermined / Nervous System
0.028
0.53
0.0013
0.56
1,4-Dichlorobenzene
Liver
0.00015
0.00027
0.00010
0.00052
2,4,4-T rimethyl-1-pentene
Liver
0.0078
0.047
0.018
0.073
2,4,4-Trimethyl-2-pentene
Liver
0.0023
0.014
0.0054
0.022
Benzene
Immune System
0.020
0.072
0.0030
0.10
Chloroform
Liver
0.0013
0.0029
0.00011
0.0043
Cis-1,2-Dichloroethene
Kidney/ General Toxicity / Liver
1.6
0.39
0.19
2.18
Methyl Tertbutyi Ether
Liver / Kidney
NC
0.0055
NC
0.006
Naphthalene
General Toxicity / Nervous System / Respiratory
0.0011
0.11
0.00067
0.11
Trichloroethene
Developmental / Immune System / Cardiovascular / Kidney
3.3
19
0.53
23
Vinyl chloride
Liver
0.61
0.55
0.048
1.2
Semi-Volatile Organic Compounds
4-Chlorophenyl phenyl ether
Respiratory / Liver / Kidney
0.0000078
0.15
0.000012
0.15
Biphenyl
Respiratory / Liver / Kidney
0.000072
1.2
0.00011
1.2
Diphenyl ether
Eye / Respiratory
8.1
8.1
N-Nitrosodimethylamine
Developmental
29
NC
0.072
29
Petroleum Hydrocarbons
C9-C10 Aromatics
Respiratory
0.082
1.8
0.081
2.0
C9-C12 Aliphatics
Liver / Kidney / Endocrine
0.020
0.047
NC
0.067
Metals
Aluminum
Nervous System
0.0022
NC
0.000012
0.0022
Antimony
Hematological / General Toxicity
1.1
NC
0.042
1.1
Arsenic
Skin / Cardiovascular
2.6
NC
0.015
2.6
Cadmium
Kidney
0.036
NC
0.0040
0.040
Cobalt
Endocrine
10
NC
0.023
10
Iron
Gl System
2.0
NC
0.011
2.0
Manganese
Nervous System
25
NC
3.5
29
Nickel
General Toxicity
0.18
NC
0.0050
0.19
Vanadium
Skin
0.060
NC
0.013
0.073
Zinc
Immune System / Hematological
0.0039
NC
0.000013
0.0039
Inorganics, Total
Nitrate as N
Hematological
0.00060
NC
0.0000033
0.00060
Nitrite as N
Hematological
0.0063
NC
0.000035
0.0063
Specialty Compounds
Formaldehyde
Kidney / Gl System / General Toxicity / Eye / Respiratory
0.0018
0.0030
0.000026
0.0048
Exposure Point Total =
113
Page 1 of 2
-------
Table G-18
OU3 Risk Characterization Summary - Non-Carcinogens
Scenario Timeframe: Future
Receptor Population: Resident
Receptor Age: Adult
Medium
Exposure
Exposure
Chemical of Concern
Primary Target Organ
Non-Carcinogenic Hazard Quotient
Medium
Point
Ingestion
Inhalation
Dermal
Exposure
Routes Total
Groundwater
Bedrock
Ipswich Aquifer
Volatile Organic Compounds
Groundwater
Plume Core -
1,2,4-T richlorobenzene
Endocrine / Urinary
0.0022
0.20
0.0030
0.21
Bedrock
1,2-Dichioroethane
Undetermined / Nervous System
0.039
0.74
0.0018
0.78
1,4-Dichlorobenzene
Liver
0.00018
0.00032
0.00012
0.00062
2 4 4-Trimethyt-1-pentene
Liver
0.025
0.15
0.058
0.23
Benzene
Immune System
0.012
0.043
0.0018
0.057
Bromodich'nromethane
Kidney
0.00033
NC
0.000023
0.00035
Chloroform
Liver
0.015
0.034
0.0013
0.050
Cis-1,2-Dichloroethene
Kidney / General Toxicity / Liver
0.22
0.055
0.027
0.30
Methylene chloride
Liver
0.0085
0.0022
0.00031
0.011
Trichloroethene
Developmental / Immune System /Cardiovascular/ Kidney
4.4
25
0.71
30.11
Vinyl chloride
Liver
0.012
0.011
0.00093
0.024
Semi-Volatile Organic Compounds
Bcn/niaipyrene
Developmental
0.014
NC
NC
0.014
Diphenyi ether
Eye / Respiratory
NC
13
NC
13
N-Nitrosod*methylamine
Developmental
60
NC
0.15
60
Pt-nla^Mnwiphenol
Liver
0.0056
NC
0.024
0.030
Metdls
Antmonv
Hematological / General Toxicity
0.90
NC
0.033
0.93
Ar^pnic
Skin / Cardiovascular
0.56
NC
0.0031
0.56
Chromium Hexavalent
Undetermined
0.0071
NC
0.0032
0.010
Cobalt
Endocrine
51
NC
0.11
51
Iron
Gl System
1.8
NC
0.010
1.8
Nervous System
36
NC
5.1
41
MicKe?
General Toxicity
0.21
NC
0.0059
0.22
Vanadium
Skin
0.059
NC
0.013
0.072
Specialty Compounds
Dimethy\formamide
Liver
0.0060
0.00023
0.0000077
0.0062
Fu rnairJehyde
Kidney / Gl System / General Toxicity / Eye / Respiratory
0.0019
0.0033
0.000028
0.0052
Hydrazine
Liver
NC
0.0097
NC
0.0097
Exposure Point Total ~
201
Key
Gl - Gastrointestinal
NA - Toxicity criteria are not available to quantitatively address this route of exposure.
NC - Not Calculated
Tnis Iwd'd fjuot nntfe. (HOi for h.k, i *oJtH uf exposure and *wza" J index is*jrri nf the naz^rd qjotit-nM fcr b.g-nf cant rojtPs nf exposure for a flirt residents exposed to h Acju fer groundwater Tne R'Sk
Assessment Guidance for Superfund (RAGS) states that, generally, a hazard index (HI) of greater than 1 indicates the potential for adverse noncancer effects. Results presented use toxicity values and site-specific exposure
parameters from the baseline HHRA.
Source: A Guide to Preparing Superfund Proposed Plans, Records of Decision, and Other Remedy Selection Decision Documents (U.S. EPA, 1999)
Page 2 of 2
-------
ROD RISK WORKSHEET
Table G-19
OU3 Risk Characterization Summary - Carcinogens
Scenario Timeframe: Future
Receptor Population; Resident
Receptor Age: Child
Medium
Exposure
Medium
Exposure Point
Chemical of Concern
Carcinogenic Risk
ingestion
inhalation
Dermal
External
(Radiation)
Exposure
Routes Total
Groundwater
Overburden
Groundwater /
Shower Air
Ipswich Aquifer
Plume Core -
Overburden
Volatile Organic Compounds
1.1-Dichloroethane
1,2,4-T richlorobenzene
1.2-Dichloroethane
1,4-Dichlorobenzene
Benzene
Chloroform
Methyl Tertbutyl Ether
Naphthalene
Trichloroethene
Vinyl chloride
Semi-Volatile Organic Compounds
4-Chlorophenyl phenyl ether
Biphenyl
N-Nitrosodimethylamine
Metals
Arsenic
Specialty Compounds
Formaldehyde
2.7E-08
1.4E-07
2.2E-06
8.1E-09
1.7E-07
5.6E-08
2.1E-07
3.6E-07
2.0E-05
1.0E-03
4.4E-09
4.1E-08
9.0E-03
1.7E-04
NC
6.7E-08
NC
5.0E-06
1.2E-07
8.7E-07
3.4E-07
2.2E-07
6.0E-07
1.6E-05
6.6E-05
NC
NC
2.5E-04
NC
2.0E-08
1.8E-09
1.7E-07
9.3E-08
5.1E-09
2.3E-08
4.4E-09
4.1E-09
2.1E-07
3.0E-06
6.8E-05
6.1E-09
5.6E-08
2.0E-05
7.4E-07
NC
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
9.6E-08
3.1E-07
7.3E-06
1.3E-07
1.1E-06
4.0E-07
4.3E-07
1.2E-06
3.9E-05
1.1E-03
1.1E-08
9.7E-08
9.3E-03
1.7E-04
0.0E+00
2.0E-08
Exposure Risk Total =
1E-02
Page 1 of 2
-------
Table G-19
OU3 Risk Characterization Summary - Carcinogens
Scenario Timeframe: Future
Receptor Population: Resident
Receptor Age: Child
Medium
Exposure
Medium
Exposure Point
Chemical of Concern
Carcinogenic Risk
Ingestion
Inhalation
Dermal
External
(Radiation)
Exposure
Routes Total
Groundwater
Bedrock
Groundwater /
Shower Air
Ipswich Aquifer
Plume Core -
Bedrock
Volatile Organic Compounds
1,2,4-T richlorobenzene
1,2-Dichloroethane
1,4-Dichlorobenzene
Benzene
Bromodichlorom ethane
Chloroform
Methylene chloride
Trichloroethene
Vinyl chloride
Semi-Volatile Organic Compounds
Benzo(a)anthracene
Benzo(a)pyrene
Dibenz(a,h)anthracene
N-Nitrosodimethylamine
Pentachlorophenol
Metals
Arsenic
Chromium, Hexavalent
Specialty Compounds
Formaldehyde
Hydrazine
9.2E-08
3.0E-06
9.7E-09
1.0E-07
5.8E-Q8
6.5E-07
7.7E-08
2.7E-05
2.0E-05
4.1E-07
3.2E-06
4.1E-06
1.8E-02
1.6E-06
3.6E-05
8.0E-06
NC
8.6E-07
NC
6.9E-06
1.5E-07
5.2E-07
2.4E-07
4.0E-06
3.6E-09
2.2E-05
1.3E-06
9.0E-08
NC
NC
5.2E-04
NC
NC
NC
2.2E-08
7.4E-08
1.1E-07
1.3E-07
6.1E-09
1.4E-08
3.6E-09
5.1E-08
2.5E-09
3.9E-06
1.3E-06
NC
NC
NC
4.0E-05
6.1E-06
1.6E-07
2.4E-06
NC
2.6E-10
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
2.0E-07
1.0E-05
1.7E-07
6.3E-07
3.0E-07
4.7E-06
8.3E-08
5.3E-05
2.3E-05
5.0E-07
3.2E-06
4.1E-06
1.9E-02
7.7E-06
3.6E-05
1.0E-05
2.2E-08
9.3E-07
Exposure Risk Total =
2E-02
Key
NA - Exposure route not applicable for this chemical/exposure medium.
NC - Not carcinogenic by this expsoure route.
This table provides risk estimates for the significant routes of exposure for the future child residents exposed to groundwater in the Ipswich Watershed. 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 child resident exposure to groundwater, as well as the toxicity of the COCs.
Source: A Guide to Preparing Superfund Proposed Plans, Records of Decision, and Other Remedy Selection Decision Documents (U.S. EPA, 1999)
Page 2 of 2
-------
ROD RISK WORKSHEET
Table G-20
OU3 Risk Characterization Summary - Non-Carcinogens
Scenario Timeframe: Future
Receptor Population: Resident
Receptor Age: Child
Medium
Exposure
Exposure
Chemical of Concern
Primary Target Organ
Non-Carcinogenic Hazard Quotient
Medium
Point
Ingestion
Inhalation
Dermal
Exposure
Routes Total
Groundwater
Overburden
Ipswich Aquifer
Volatile Organic Compounds
Groundwater /
Plume Core -
1,1-Dichloroethane
Kidney
0.00027
NC
0.000019
0.00029
Shower Air
Overburden
1,2,4-Trichlorobenzene
Endocrine / Urinary
0.0055
0.18
0.0067
0.19
1,2-Dichloroethane
Nervous System
0.046
0.32
0.0020
0.37
1,4-Dichlorobenzene
Liver
0.00025
0.00016
0.00016
0.00057
2,4,4-Trimethyl-1 -pentene
Liver
0.013
0.029
0.027
0.069
2,4,4-Trimethyl-2-pentene
Liver
0.0039
0.0086
0.0081
0.021
Benzene
Immune System
0.033
0.043
0.0044
0.080
Chloroform
Liver
0.0021
0.0018
0.00017
0.0041
Cis-1,2-Dichloroethene
Kidney / General Toxicity / Liver
2.6
0.23
0.29
3.1
Methyl Tertbutyl Ether
Liver / Kidney
NA
0.0033
NA
0.0033
Naphthalene
General Toxicity / Nervous System / Respiratory
0.0018
0.069
0.0010
0.072
Trichloroethene
Developmental / Immune System / Cardiovascular / Kidney
5.5
11
0.80
17
Vinyl chloride
Liver
1.0
0.33
0.069
1.4
Semi-Volatile Organic Compounds
4-Chlorophenyl phenyl ether
Respiratory / Liver / Kidney
0.000013
0.091
0.000018
0.091
Biphenyl
Respiratory / Liver / Kidney
0.00012
0.71
0.00016
0.71
Diphenyl ether
Eye / Respiratory
NA
4.9
NA
4.9
N-Nitrosodimethylamine
Developmental
49
NC
0.11
49
Petroleum Hydrocarbons
C9-C10 Aromatics
Respiratory
0.14
1.1
0.12
1.4
C9-C12 Atiphatics
Liver / Kidney / Endocrine
0.033
0.028
NC
0.061
Metals
Aluminum
Nervous System
0.0036
NC
0.000016
0.0036
Antimony
Hematological / General Toxicity
1.9
NC
0.055
2.0
Arsenic
Skin / Cardiovascular
4.4
NC
0.019
4.4
Cadmium
Kidney
0.060
NC
0.0053
0.065
Cobalt
Endocrine
17
NC
0.031
17
Iron
Gi System
3.3
NC
0.015
3.3
Manganese
Nervous System
41
NC
4.6
46
Nickel
General Toxicity
0.30
NC
0.0066
0.31
Vanadium
Skin
0.10
NC
0.017
0.12
Zinc
Immune System / Hematological
0.0065
NC
0.000017
0.0065
Inorganics, Total
Nitrate as N
Hematological
0.0010
NC
0.0000044
0.0010
Nitrite as N
Hematological
0.010
NC
0.000046
0.010
Specialty Compounds
Formaldehyde
Kidney / Gi System / General Toxicity / Eye / Respiratory
0.0030
0.0018
0.000038
0.0048
Exposure Point Total =
152
Page 1 of 2
-------
Table G-20
OU3 Risk Characterization Summary - Non-Carcinogens
Scenario Timeframe: Future
Receptor Population: Resident
Receptor Age: Child
Medium
Exposure
Exposure
Chemical of Concern
Primary Target Organ
Non-Carcinogenic Hazard Quotient
Medium
Point
Ingestion
Inhalation
Dermal
Exposure
Routes Total
Groundwater
Bedrock
Ipswich Aquifer
Volatile Organic Compounds
Groundwater/
Plume Core -
1,2,4-T rich lorobenzene
Endocrine / Urinary
0.0037
0.12
0.0045
0.13
Shower Air
Bedrock
1,2-Dichloroethane
Nervous System
0.065
0.44
0.0028
0.51
1,4-Dichlorobenzene
Liver
0.00030
0.00019
0.00019
0.00068
2,4,4-T rimethyl-1 -pentene
Liver
0.042
0.092
0.088
0.22
Benzene
Immune System
0.020
0.026
0.0026
0.049
RrpmnrJirviloromethane
Kidney
0.00055
NC
0.000034
0.00058
Cnloroforn
Liver
0.024
0.021
0.0019
0.047
Os-1 2-Uichloroethene
Kidney / General Toxicity / Liver
0.37
0.033
0.041
0.444
Mr thylfrir chloride
Liver
0.014
0.0013
0.00046
0.016
Irch ofoethene
Cardiovascular / Kidney
7.3
15
1.1
23
Vinyl chloride
Liver
0.020
0.0065
0.0013
0.028
Semi-Volatile Organic Compounds
Rcnnnaipyrr'nc
Developmental
0.023
NC
NC
0.023
D^ihs-nvl ether
Eye / Respiratory
NC
7.7
NC
7.7
N-Nitrosodimethylamine
Developmental
100
NC
0.22
100
Pt roph^ntjl
Liver
0.0094
NC
0.036
0.045
Metals
Antimony
Hematological / General Toxicity
1.5
NC
0.044
1.5
Arsen c
Skin / Cardiovascular
0.93
NC
0.0041
0.93
C*iromiur. Hexavalent
Undetermined
0.012
NC
0.0042
0.016
Cnbalt
Endocrine
85
NC
0.15
85
Iron
Gl System
3.1
NC
0.014
3.1
Manganese
Nervous System
60
NC
6.6
67
M CK&I
General Toxicity
0.35
NC
0.0078
0.36
Van.idtum
Skin
0.098
NC
0.017
0.12
Specialty Compounds
D metny fo'mamide
Liver
0.010
0.00014
0.000011
0.010
Fo ma.dphyde
Kidney / Gl System / General Toxicity / Eye / Respiratory
0.0032
0.0020
0.000041
0.0052
Hydrazine
Liver
NC
0.0058
NC
0.0058
Exposure Point Total =
291
Key
Gl - Gastrointestinal
NA - Toxicity criteria are not available to quantitatively address this route of exposure.
NC - Not Calculated
Tfu& table p hazard qjot nnts }HQs) fu« route of exposure and the hazard nde-s ,surn of the wa'd ijuol fcr ^ign f^-ant routes of exposure for f jl-jr^ i h d *es
-------
ROD RISK WORKSHEET
Table G-21
OU3 Risk Characterization Summary - Carcinogens
Scenario Timeframe: Hypothetical Future
Receptor Population: Resident
Receptor Age: Adult
Medium
Exposure
Medium
Exposure Point
Chemical of Concern
Carcinogenic Risk
Ingestion
Inhalation
Dermal
External
(Radiation)
Exposure
Routes Total
Groundwater
Overburden
Aberjona Aquifer
Volatile Organic Compounds
Groundwater/
Plume Core-
1,1-Dichtoroethane
7.8E-08
5.4E-07
5.9E-09
NA
6.2E-07
Shower Air
Overburden
1,2,4-Trichlorobenzene
5.0E-07
NC
6.7E-07
NA
1.2E-06
1,2-Dichloroethane
2.4E-06
1.5E-05
1.1E-07
NA
1.8E-05
1,4-Dichlorobenzene
2.4E-08
1.0E-06
1.7E-08
NA
1.0E-06
Benzene
8.0E-08
1.1E-06
1.2E-08
NA
1.2E-06
Bromodichloromethane
9.6E-07
1.1E-05
6.6E-08
NA
1.2E-05
Bromoform
5.7E-07
1.0E-06
4.0E-08
NA
1.6E-06
Carbon tetrachloride
1.9E-06
3.4E-06
4.8E-07
NA
5.8E-06
Chloroform
6.1E-07
1.0E-05
5.3E-08
NA
1.1E-05
Dibromochloromethane
3.2E-06
1.3E-05
2.1E-07
NA
1.6E-05
Ethyl benzene
2.1E-08
1.1E-07
1.2E-08
NA
1.4E-07
Naphthalene
3.6E-07
1.6E-06
2.3E-07
NA
2.2E-06
Trichloroethene
3.2E-07
6.7E-07
5.2E-08
NA
1.0E-06
Semi-Volatile Organic Compounds
4-Bromophenyl phenyl ether
2.4E-07
NC
3.6E-07
NA
6.0E-07
4-Chiorophenyl phenyl ether
1.2E-07
NC
1.8E-07
NA
3.0E-07
Benzo(a)pyrene
2.2E-06
NC
NC
NA
2.2E-06
Benzo(b)fluoranthene
2.6E-07
NC
NC
NA
2.6E-07
Biphenyl
1.4E-07
NC
2.1E-07
NA
3.5E-07
Bis(2-Ethylhexyl)phthalate
2.0E-07
NC
NC
NA
2.0E-07
Dibenz(a,h)anthracene
1.7E-06
NC
NC
NA
1.7E-06
N-Nitrosodimethylamine
3.1E-03
2.4E-04
7.7E-06
NA
3.3E-03
N-Nitrosodiphenylamine
1.1E-06
NC
3.4E-07
NA
1.4E-06
Metals
Arsenic
3.3E-04
NC
1.9E-06
NA
3.3E-04
Chromium, Hexavalent
5.3E-06
NC
2.0E-06
NA
7.3E-06
Specialty Compounds
Formaldehyde
NC
1.6E-07
NC
NA
1.6E-07
Hydrazine
5.9E-03
1.4E-03
2.1E-06
NA
7.3E-03
Monomethylhydrazine (MMH)
NC
1.6E-06
NC
NA
1.6E-06
Exposure Risk Total »
1E-02
Page 1 of 3
-------
Table G-21
0U3 Risk Characterization Summary - Carcinogens
Scenario Timeframe: Hypothetical Future
Receptor Population: Resident
Receptor Age: Adult
Medium
Exposure
Medium
Exposure Point
Chemical of Concern
Carcinogenic Risk
Ingestion
Inhalation
Dermal
External
(Radiation)
Exposure
Routes Total
Groundwater
Bedrock
Groundwater /
Shower Air
Aberjona Aquifer
Plume Core -
Bedrock
Volatile Organic Compounds
1.1-Dichloroethane
1.2-Dichloroethane
Benzene
Bromodichloromethane
Bromoform
Chloroform
Dibromochloromethane
Ethyl benzene
Methylene chloride
Trichloroethene
Semi-Volatile Organic Compounds
Azobenzene
Bis(2-Ethylhexyl)phthalate
N-Nitrosodimethylamine
Metals
Arsenic
Specialty Compounds
Formaldehyde
Hydrazine
1.9E-08
2.6E-06
3.0E-07
3.5E-06
1.1E-06
6.6E-06
4.6E-06
7.3E-08
8.9E-08
2.8E-07
5.4E-07
9.2E-07
2.9E-03
1.3E-04
NC
1.9E-06
1.3E-07
1.6E-05
4.1E-06
4.0E-05
2.0E-06
1.1E-04
1.9E-05
4.1E-07
1.1E-08
5.8E-07
1.9E-07
NC
2.3E-04
NC
5.2E-07
4.6E-07
1.4E-09
1.2E-07
4.4E-08
2.4E-07
8.2E-08
5.8E-07
3.0E-07
4.3E-08
3.2E-09
4.5E-08
5.3E-07
NC
7.2E-06
7.5E-07
NC
6.8E-10
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
1.5E-07
1.9E-05
4.4E-06
4.4E-05
3.2E-06
1.2E-04
2.4E-05
5.3E-07
1.0E-07
9.1E-07
1.3E-06
9.2E-07
3.1E-03
1.3E-04
5.2E-07
2.4E-06
Exposure Risk Total =
4E-03
DAPL
DAPL/
Shower Air
Site-Wide
Volatile Organic Compounds
1,2-Dichloroethane
1,4-Dichlorobenzene
Benzene
Bromodichloromethane
Bromoform
Chloroform
Dibromochloromethane
Ethyl benzene
Methylene chloride
Naphthalene
Trichloroethene
Vinyl chloride
Semi-Volatile Organic Compounds
4-Bromophenyl phenyl ether
4-Chloroaniline
Benzo(a)pyrene
Benzo(b)fluoranthene
Bi phenyl
Dibenz(a,h)anthracene
lndeno(1,2,3-cd)pyrene
N-Nitrosodimethylamine
1.3E-05
3.5E-08
1.1E-06
1.4E-06
1.3E-06
1.4E-05
6.1E-05
3.3E-07
6.0E-07
1.3E-05
2.4E-05
4.6E-06
5.8E-08
1.5E-06
5.1E-06
8.7E-07
3.6E-07
1.5E-06
4.5E-07
1.2E-02
8.3E-05
1.4E-06
1.6E-05
1.6E-05
2.3E-06
2.3E-04
2.5E-04
1.8E-06
7.7E-08
6.1E-05
4.9E-05
8.3E-07
NC
NC
NC
NC
NC
NC
NC
9.0E-04
6.2E-07
2.4E-08
1.7E-07
9.6E-08
9.1E-08
1.2E-06
4.0E-06
1.9E-07
2.2E-08
8.4E-06
3.8E-06
3.5E-07
8.7E-08
9.8E-08
NC
NC
5.4E-07
NC
NC
2.9E-05
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
9.7E-05
1.5E-06
1.7E-05
1.7E-05
3.7E-06
2.5E-04
3.2E-04
2.3E-06
7.0E-07
8.2E-05
7.7E-05
5.8E-06
1.5E-07
1.6E-06
5.1E-06
8.7E-07
9.0E-07
1.5E-06
4.5E-07
1.3E-02
Page 2 of 3
-------
Table G-21
0U3 Risk Characterization Summary - Carcinogens
Scenario Timeframe: Hypothetical Future
Receptor Population; Resident
Receptor Age: Adult
Medium
Exposure
Medium
Exposure Point
Chemical of Concern
Carcinogenic Risk
Ingestion
Inhalation
Dermal
External
(Radiation)
Exposure
Routes Total
M@lais
Arsenic
Ghramiim Hexavalent
Specialty Compounds
A' ~ Ultif mydn
Fomria dehvde
H>rird'in*
2.2E-03
3.2E-04
NC
NC
4.4E-06
NC
NC
8.0E-06
1.1E-05
1.1E-06
1.3E-05
1.2E-04
NC
NC
1.6E-09
NA
NA
NA
NA
NA
2.2E-03
4.4E-04
8.0E-06
1.1E-05
5.5E-06
Exposure Risk Total
2E-02
Key
DAPL - Dense aqueous phase liquid
NA - Exposure route not applicable for this chemical/exposure medium.
NC - Not carcinogenic by this expsoure route.
This tciti'C provides risk estimates for the significant routes of exposure for the hypothetical future adult resident exposure to groundwater or DAPL, 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 adult resident exposure to groundwater, as well as the toxicity of the COCs.
Source: A Guide to Preparing Superfund Proposed Plans, Records of Decision, and Other Remedy Selection Decision Documents (U.S. EPA, 1999)
Page 3 of 3
-------
ROD RISK WORKSHEET
Table G-22
OU3 Risk Characterization Summary - Non-Carcinogens
Scenario Timeframe: Future
Receptor Population: Resident
Receptor Age: Adult
Medium
Exposure
Exposure
Chemical of Concern
Primary Target Organ
Non-Carcinogenic Hazard Quotient
Medium
Point
Ingestion
Inhalation
Dermal
Exposure
Routes Total
Groundwater
Overburden
Aberjona Aquifer
Volatile Organic Compounds
Groundwater /
Plume Core -
1,1-Dichloroethane
Kidney
0.00024
NC
0.000018
0.00026
Shower Air
Overburden
1,2,4-Trichlorobenzene
Endocrine / Urinary
0.0060
0.53
0.0081
0.54
1,2,4-Trimethyi benzene
Nervous System
0.0010
0.004Q
0.0012
0.0062
1,2-Oichloroeihane
Undetermined / Nervous System
0.015
0.29
0.00073
0.31
1,4-DichSorobenzene
Liver
0.00022
0.00040
0.00015
0.00077
2,4,4-Trimethyl-1-pentene
Liver
0.39
2.4
0.90
3.7
2,4,4-Trimethyl-2-pentene
Liver
0.12
0.73
0.28
1.1
Benzene
Immune System
0.0046
0.017
0.00070
0.022
Bromodichioromethane
Kidney
0.0027
NC
0.00019
0.0029
Bromoform
Liver
0.013
NC
0.00090
0.014
Carbon tetrachloride
Liver
0.023
0.020
0.0061
0.049
Chloroform
Liver
0.0069
0.016
0.00060
0.024
Dibromochloromethane
Liver
0.0066
0.02
0.00043
0.027
Dsbromomethane
Hematological
NC
0.53
NC
0.53
Ethyibenzene
Liver / Kidney J Developmental
Q.000066
0.00016
0.000038
0.00026
Naphthalene
General Toxicity / Nervous System / Respiratory
0.00052
0.057
0.00033
0.058
Toluene
KidneyI Nervous System
0.0014
0.00057
0.00046
0.0024
Trichloroethene
0.041
0.23
0.0065
0.28
Xylene, o-
General Toxicity I Nervous System
0.000037
0.0018
0.000021
0.0019
Semi-Volatile Organic Compounds
4-Bromophenyl phenyl ether
Respiratory / Liver / Kidney
0.00021
1.7
0.00032
1.7
4-ChIoropheny! phenyl ether
Respiratory / Liver / Kidney
0.00010
2.0
0.00015
2.0
Benzo{a)pyrene
Developmental
0.013
NC
NC
0.013
Biphenyl
Respiratory / Liver / Kidney
0.00012
2.0
0.00018
2.0
Bis(2-Ethy!hexyl)phtha!ate
Liver
0.0025
NC
NC
0.0025
Diphenyl ether
Eye / Respiratory
NC
24
NC
24
vi-Nitrosodimethyiamine
Vletals
Developmental
13
NC
0.033
13
Aluminum
Nervous System
0.24
NC
0.0013
0.24
Arsenic
Skin/Cardiovascular
2.6
NC
0.014
2.6
Beryllium
Gl System
0.031
NC
0.025
0.056
Cadmium
Kidney
0.15
NC
0.017
0.17
Chromium
Undetermined
0.022
NC
0.012
0.034
Chromium, Hexavalent
Undetermined
0.0062
NC
0.0028
0.0090
Cobalt
Endocrine
9.5
NC
0.021
9.5
Copper
Gl System
0.13
NC
0.00071
0.13
ron
Gl System
1.3
NC
0.0074
1.3
Manganese
Nervous System
4.3
NC
0.61
4.9
Mickel
General Toxicity
0.13
NC
0.0038
0.13
Silver
Skin
0.22
NC
0.018
0.24
Thallium
Skin
2.3
NC
0.013
2.3
fin
Liver / Kidney
0.10
NC
0.00056
0.10
Vanadium
Skin
0.40
NC
0.085
0.49
Zinc
Immune System / Hematological
0.015
NC
0.000051
0.015
norgantcs
Mitrate as N
Hematological
0.018
NC
0.00010
0.018
3erchiorate
Endocrine
0.24
NC
0.0013
0.24
Specialty Compounds
Dimethylform amide
Liver
0.01
0.00029
0.00
0.0078
"ormaidehyde
Kidney / Gi System / General Toxicity / Eye / Respiratory
0.003
0.0043
0.000037
0.0068
Hydrazine
Liver
NC
33
NC
33
Monomethylhydrazine (MMH)
Developmental / Hematological / Liver
0.0093
0.28
0.000014
0.29
JDMH
Eye / Reproductive
0.2
22
0.000
22
Exposure Point Total =
127
Page 1 of 4
ROD Section G Tables-HH OU3R1
-------
Table G-22
OU3 Risk Characterization Summary - Non-Carcinogens
Scenario Timeframe: Future
Receptor Population: Resident
Receptor Age: Adult
Medium
Exposure
Exposure
Chemical of Concern
Primary Target Organ
Non-Carcinogenic Hazard Quotient
Medium
Point
Ingestion
Inhalation
Dermal
Exposure
Routes Total
Groundwater
Bedrock
Aberjona Aquifer
Volatile Organic Compounds
Groundwater /
Plume Core -
1,1-Dichloroethane
Kidney
0.000057
NC
0.0000043
0.000061
Shower Air
Bedrock
1,2-DichIoroethane
Undetermined / Nervous System
0.016
0.31
0.00078
0.33
2,4,4-TrimethyM-pentene
Liver
0.18
1.1
0.41
1.7
2,4,4-Trimethyt-2-pentene
Liver
0.054
0.33
0.12
0.50
Benzene
Immune System
0.017
0.062
0.0026
0.082
Bromodichloromethane
Kidney
0.0099
NC
0.00068
0.011
Bromoform
Liver
0.025
NC
0.0018
0.027
Chloroform
Liver
0.075
0.17
0.0066
0.25
Dibromochloromethane
Liver
0.0096
0.030
0.00063
0.040
Dsbromomethane
Hematological
NC
1,1
NC
1.1
Ethylbenzene
Liver 1 Kidney / Developmental
0.00023
0.00057
0.00014
0.00094
Methylene chloride
Liver
0.013
0.0033
0.00047
0.017
Toluene
Kidney / Nervous System
0.0024
0.00096
0.00079
0.0042
Trichloroethene
Developmental / Immune System/ Cardiovascular I Kidney
0.035
0.20
0.0057
0.24
Xylene, o
General Toxicity / Nervous System
0.000030
0.0014
0.000017
0.0014
Semi-Volatile Organic Compounds
3is(2-Ethylhexyl)phthalate
Liver
0.012
NC
NC
0.012
Diphenyl ether
Eye / Respiratory
NC
3.3
NC
3.3
N-Nitrosodimethylamine
Developmental
13
NC
0.031
13
Metals
Muminum
Nervous System
3.6
NC
0.020
3,6
Vttimony
Hematological / General Toxicity
0.38
NC
0.014
0.39
Arsenic
Skin/Cardiovascular
1.0
NC
0.0058
1.0
Beryllium
Gl System
0.21
NC
0.17
0.38
Cadmium
Kidney
0.72
NC
0.080
0.80
Chromium
Undetermined
0.56
NC
0.31
0.87
Cobalt
Endocrine
78
NC
0.17
78
Copper
Gl System
0.17
NC
0.00096
0.17
ron
Gl System
12
NC
0.065
12
Manganese
Nervous System
27
NC
3.8
31
Nickel
General Toxicity
1.2
NC
0.034
1.2
Silver
Skin
2.9
NC
0.25
3.2
Thallium
Skin
3.9
NC
0.022
3.9
Zinc
Immune System / Hematological
2.5
NC
0.0084
2.5
norganics
3erchlorate
Endocrine
0.43
NC
0.0024
0.43
Specialty Compounds
Dimethylform amide
Liver
0.0099
0.00038
0.000013
0.010
Formaldehyde
Kidney / Gl System / General Toxicity
0.0084
0.014
0.00012
0.023
^drazine
Liver
NA
0.011
NA
0.011
Exposure Point Total =
160
Page 2 of 4
ROD Section G Tab!es-HH OU3R1
-------
Table G-22
OU3 Risk Characterization Summary - Non-Carcinogens
Scenario Timeframe: Future
Receptor Population: Resident
Receptor Age: Adult
Medium
Exposure
Exposure
Chemical of Concern
Primary Target Organ
Non-Carcinogenic Hazard Quotient
Medium
Point
Ingestion
Inhalation
Dermal
Exposure
Routes Total
DAPL
DAPL/
Site-Wide
Volatile Organic Compounds
Shower Air
1,2,4-Trimethylbenzene
Nervous System
0.010
0.040
0.011
0.061
1,2-Dichloroethane
Undetermined / Nervous System
0.085
1.6
0.0040
1.7
1,4-Dschlorobenzene
Liver
0.00032
0.00057
0.00022
0.0011
2,4,4-TrimethyM-pentene
Liver
0.050
0.30
0.12
0.47
2,4,4-Trimethyt-2-pentene
Liver
0.039
0.24
0.090
0.37
Benzene
immune System
0.067
0.24
0.010
0.32
Bromodichloromethane
Kidney
0.0039
NC
0.00027
0.0042
Bromoform
Liver
0.028
NC
0.0020
0.030
Chloroform
Liver
0.15
0.36
0.013
0.52
Cis-1,2-Dichloroethene
Kidney / General Toxicity / Liver
0.10
0.025
0.013
0.14
Dibromochloromethane
Liver
0.13
0.39
0.0083
0.53
Dibromomethane
Hematological
NC
1.1
NC
1.1
Ethylbenzene
Liver / Kidney / Developments!
0.0010
0.0025
0.00060
0.0041
Methylene chloride
Liver
0.087
0.022
0.0032
0.11
Naphthalene
General Toxicity / Nervous System / Respiratory
0.019
2.1
0.012
2.1
Toluene
Kidney / Nervous System
0.033
0.013
0.011
0.057
T richioroethene
Developmental / immune System /Cardiovascular / Kidney
3.0
17
0.48
20
\/inyl chloride
Liver
0.0037
0.0033
0.00029
0.0073
Semi-Volatile Organic Compounds
4-Bromophenyl phenyl ether
Respiratory / Liver / Kidney
0.000050
0.41
0.000076
0.41
4-Chloroaniiine
Immune System
0.0064
NC
0.00043
0.0068
3enzo(a)pyrene
Developmental
0.030
NC
NC
0.030
Biphenyi
Respiratory / Liver / Kidney
0.00031
5.2
0.00048
5.2
Diphenyl ether
Eye / Respiratory
Developmental
NC
50
15
NC
NC
0.12
15
50
=hthaiic acid
Urinary
0.072
NC
0.0049
0.077
Petroleum Hydrocarbons
39-C10 Aromatic®
Respiratory
0.011
0.24
0.011
0.3
Metals
Aluminum
Nervous System
57
NC
0.32
57
Vsenic
Skin / Cardiovascular
17
NC
0.098
17
3arium
Urinary
0.16
NC
0.013
0.17
Beryllium
Gl System
1.5
NC
1.2
2.7
Cadmium
Kidney
4.0
NC
0.44
4.4
Chromium
Undetermined
46
NC
26
72
Chromium. Hexavalent
Undetermined
0.37
NC
0.17
0.54
Cobalt
Endocrine
573
NC
1.3
574
Copper
Gl System
3.5
NC
0.020
3.5
ron
Gl System
141
NC
0.79
142
Manganese
Nervous System
212
NC
30
242
Vlercury
Immune System / Urinary
0.31
NC
0.025
0.34
Mickel
General Toxicity
7.3
NC
0.20
7.5
Silver
Skin
61
NC
5.1
66
Thallium
Skin
17
NC
0.10
17
Hn
Liver / Kidney
44
NC
0.25
44
Vanadium
Skin
1.5
NC
0.32
1.8
Zinc
Immune System / Hematological
0.88
NC
0.0029
0.88
norganics, Total
Nitrate as N
Hematological
0.23
NC
0.0013
0.23
Write as N
Hematological
0.30
NC
0.0017
0.30
Perchlorate
Endocrine
0.60
NC
0.0033
0.60
Specialty Compounds
^cetafdehyde
Nervous System / Respiratory
NC
1.4
NC
1.4
Dimethylform amide
Liver
0.075
0.0029
0.000096
0.078
rorm aldehyde
Kidney / Gl System / Genera! Toxicity / Eye / Respiratory
0.19
0.31
0.0027
0.50
Hydrazine
Liver
NC
0.025
NC
0.025
UDMH
Eye / Reproductive
18
1933
0.012
1951
Exposure Point Total =
3307
Page 3 of 4 ROD Section G Tables-HH OU3R1
-------
Table G-22
0U3 Risk Characterization Summary - Non-Carcinogens
Scenario Timeframe: Future
Receptor Population: Resident
Receptor Age: Adutt
Medium
Exposure
Medium
Exposure
Point
Chemical of Concern
Primary Target Organ
Non-Carcinogenic Hazard Quotient
Ingestion
Inhalation
Dermal
Exposure
Routes Total
Key
DAPL - Dense aqueous phase liquid
Gastrointestinal
NA - Toxicity criteria are not available to quantitatively address this route of exposure.
NC - Not Calculated
This table provides hazard quotients (HQs) for each route of exposure and the hazard index (sum of the hazard quotients) for significant routes of exposure for
The Risk Assessment Guidance for Superfund (RAGS) states that, generally, a hazard index (HI) of greater than 1 indicates the potential for adverse noncance
exposure parameters from the baseline HHRA.
future adult residents exposed to groundwater or DAPL.
Results presented use toxicity values and site-specific
Source: A Guide to Preparing Superfund Proposed Plans, Records of Decision, and Other Remedy Selection Decision Documents (U.S. EPA, 1999)
Page 4 of 4
ROD Section G Tab!es-HH OU3R1
-------
ROD RISK WORKSHEET
Table G-23
OU3 Risk Characterization Summary - Carcinogens
Scenario Timeframe: Hypothetical Future
Receptor Population: Resident
Receptor Age: Child
Medium
Exposure
Medium
Exposure Point
Chemical of Concern
Carcinogenic Risk
Ingestion
Inhalation
Dermal
External
(Radiation)
Exposure
Routes Total
Groundwater
Overburden
Aberjona Aquifer
Volatile Organic Compounds
Groundwater/
Plume Core-
1,1-Dichtoroethane
3.9E-08
9.8E-08
2.7E-09
NA
1.4E-07
Shower Air
Overburden
1,2,4-Trichlorobenzene
2.5E-07
NC
3.0E-07
NA
5.5E-07
1,2-Dichloroethane
1.2E-06
2.8E-06
5.2E-08
NA
4.1E-06
1,4-Dichlorobenzene
1.2E-08
1.8E-07
7.5E-09
NA
2.0E-07
Benzene
4.0E-08
2.0E-07
5.3E-09
NA
2.5E-07
Bromodichloromethane
4.8E-07
2.0E-06
3.0E-08
NA
2.5E-06
Bromoform
2.8E-07
1.8E-07
1.8E-08
NA
4.8E-07
Carbon tetrachloride
9.3E-07
6.2E-07
2.2E-07
NA
1.8E-06
Chloroform
3.0E-07
1.9E-06
2.4E-08
NA
2.2E-06
Dibromochloromethane
1.6E-06
2.4E-06
9.4E-08
NA
4.1E-06
Ethyl benzene
1.0E-08
2.1E-08
5.4E-09
NA
3.6E-08
Naphthalene
1.8E-07
3.QE-07
1.0E-07
NA
5.8E-07
Trichloroethene
2.5E-07
2.0E-07
3.6E-08
NA
4.9E-07
Semi-Volatile Organic Compounds
4-Bromophenyl phenyl ether
1.2E-07
NC
1.6E-07
NA
2.8E-07
4-ChIorophenyl phenyl ether
5.8E-08
NC
8.0E-08
NA
1.4E-Q7
Benzo(a)pyrene
2.9E-06
NC
NC
NA
2.9E-06
Benzo(b)fluoranthene
3.4E-07
NC
NC
NA
3.4E-07
Biphenyl
6.9E-08
NC
9.5E-08
NA
1.6E-07
Bis(2-Ethylhexyl)phthalate
1.0E-07
NC
NC
NA
1.0E-07
Dibenz(a,h)anthracene
2.3E-06
NC
NC
NA
2.3E-06
N-Nitrosodimethylamine
4.1E-03
1.2E-04
8.9E-06
NA
4.2E-03
N-Nitrosodiphenylamine
5.4E-07
NC
1.5E-07
NA
6.9E-07
Metals
Arsenic
1.7E-04
NC
7.3E-07
NA
1.7E-04
Chromium, Hexavalent
7.0E-06
NC
2.1E-06
NA
9.1E-06
Specialty Compounds
Formaldehyde
NC
2.8E-08
NC
NA
2.8E-08
Hydrazine
2.9E-03
2.5E-04
9.0E-07
NA
3.2E-03
Monomethylhydrazine (MMH)
NC
2.8E-07
NC
NA
2.8E-07
Exposure Risk Total =
8E-03
Page 1 of 3
-------
Table G-23
0U3 Risk Characterization Summary - Carcinogens
Scenario Timeframe: Hypothetical Future
Receptor Population; Resident
Receptor Age: Child
Medium
Exposure
Medium
Exposure Point
Chemical of Goncern
Carcinogenic Risk
Ingestion
Inhalation
Dermal
External
(Radiation)
Exposure
Routes Total
Groundwater
Bedrock
Groundwater /
Shower Air
Aberjona Aquifer
Plume Core -
Bedrock
Volatile Organic Compounds
1.1-Dichloroethane
1.2-Dichloroethane
Benzene
Bromodichloromethane
Bromoform
Chloroform
Dibromochloromethane
Ethyl benzene
Methylene chloride
Trichloroethene
Semi-Volatile Organic Compounds
Azobenzene
Bis(2-Ethylhexyl)phthalate
N-Nitrosodimethylamine
Metals
Arsenic
Specialty Compounds
Formaldehyde
Hydrazine
9.3E-09
1.3E-06
1.5E-07
1.7E-06
5.7E-07
3.3E-06
2.3E-06
3.7E-08
1.2E-07
2.2E-07
2.7E-07
4.6E-07
3.9E-03
6.7E-05
NC
9.6E-07
2.3E-08
2.9E-06
7.5E-07
7.3E-06
3.7E-07
2.0E-05
3.5E-06
7.3E-08
5.5E-09
1.7E-07
3.5E-08
NC
1.1E-04
NC
9.3E-08
8.2E-08
6.4E-10
5.5E-08
2.0E-08
1.1E-07
3.7E-08
2.6E-07
1.4E-07
1.9E-08
3.9E-09
3.2E-08
2.4E-07
NC
8.4E-06
3.0E-07
NC
2.9E-10
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
3.3E-08
4.3E-06
9.2E-07
9.1E-06
9.8E-07
2.4E-05
5.9E-06
1.3E-07
1.3E-07
4.2E-07
5.5E-07
4.6E-07
4.0E-03
6.7E-05
9.3E-08
1.0E-06
Exposure Risk Total =
4E-03
DAPL
DAPL/
Shower Air
Site-Wide
Volatile Organic Compounds
1,2-Dichloroethane
1,4-Dichlorobenzene
Benzene
Bromodichloromethane
Bromoform
Chloroform
Dibromochloromethane
Ethyl benzene
Methylene chloride
Naphthalene
Trichloroethene
Vinyl chloride
Semi-Volatile Organic Compounds
4-Bromophenyl phenyl ether
4-Chloroaniline
Benzo(a)pyrene
Benzo(b)fluoranthene
Bi phenyl
Dibenz(a,h)anthracene
lndeno(1,2,3-cd)pyrene
N-Nitrosodi methyla mine
6.6E-06
1.7E-08
5.7E-07
7.0E-07
6.4E-07
6.8E-06
3.0E-05
1.6E-07
7.9E-07
6.7E-06
1.9E-05
6.0E-06
2.9E-08
7.3E-07
6.8E-06
1.2E-06
1.8E-07
1.9E-06
5.9E-07
1.5E-02
1.5E-05
2.6E-07
2.9E-06
2.9E-06
4.1E-07
4.1E-05
4.6E-05
3.3E-07
3.7E-08
1.1E-05
1.5E-05
4.0E-07
NC
NC
NC
NC
NC
NC
NC
4.3E-04
2.8E-07
1.1E-08
7.6E-08
4.3E-08
4.1E-08
5.4E-07
1.8E-06
8.6E-08
2.6E-08
3.8E-06
2.7E-06
4.1E-07
3.9E-08
4.4E-08
NC
NC
2.5E-07
NC
NC
3.3E-05
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
2.2E-05
2.9E-07
3.5E-06
3.6E-06
1.1E-06
4.8E-05
7.8E-05
5.8E-07
8.5E-07
2.2E-05
3.7E-05
6.8E-06
6.8E-08
7.7E-07
6.8E-06
1.2E-06
4.3E-07
1.9E-06
5.9E-07
1.5E-02
Page 2 of 3
-------
Table 6-23
0U3 Risk Characterization Summary - Carcinogens
Scenario Timeframe: Hypothetical Future
Receptor Population: Resident
Receptor Age: Child
Medium
Exposure
Medium
Exposure Point
Chemical of Concern
Carcinogenic Risk
Ingestion
Inhalation
Dermal
External
(Radiation)
Exposure
Routes Total
M@lais
Arsenic
Ghramiim Hexavalent
Specialty Compounds
A' ~ Ultif mydn
F o<-m a dehvde
H>rird'iru
1.1E-03
4.2E-04
NC
NC
2.2E-06
NC
NC
1.4E-06
2.1E-06
1.9E-07
4.9E-06
1.2E-04
NC
NC
6.8E-10
NA
NA
NA
NA
NA
1.1E-03
5.4E-04
1.4E-06
2.1E-06
2.4E-06
Exposure Risk Total
2E-02
Key
DAPL - Dense aqueous phase liquid
NA - Exposure route not applicable for this chemical/exposure medium.
NC - Not carcinogenic by this expsoure route.
This table provides risk estimates for the significant routes of exposure for the hypothetical child resident exposed to groundwater or DAPL, These risk estimates are based on a reasonable maximum exposure
nd were developed by taking into account various conservative assumptions about the frequency and duration of child resident exposure, as well as the toxicity of the COCs.
Source: A Guide to Preparing Superfund Proposed Plans, Records of Decision, and Other Remedy Selection Decision Documents (U.S. EPA, 1999)
Page 3 of 3
-------
ROD RISK WORKSHEET
Table G-24
OU3 Risk Characterization Summary - Non-Carcinogens
Scenario Timeframe: Future
Receptor Population: Resident
Receptor Age: Child
Medium
Exposure
Exposure
Chemical of Concern
Primary Target Organ
Non-Carcinogenic Hazard Quotient
Medium
Point
Ingestion
Inhalation
Dermal
Exposure
Routes Total
Groundwater
Overburden
Aberjona Aquifer
Volatile Organic Compounds
Groundwater /
Plume Core -
1,1-Dichloroethane
Kidney
0.00040
NC
0.000027
0.00043
Shower Air
Overburden
1,2,4-Trich!orobenzene
Endocrine / Urinary
0.010
0.32
0.012
0.34
1,2,4-Trimethylbenzene
Nervous System
0.0017
0.0024
0.0017
0.0058
1,2-Dichloroethane
Undetermined / Nervous System
0.026
0.18
0.0011
0.21
1,4-Dichlorobenzene
Liver
0.00037
0.00024
0.00023
0.00084
2,4,4-Trimethyi-1-pentene
Liver
0.65
1.4
1.4
3.5
2,4,4-Trimethy!-2-pentene
Liver
0.20
0.44
0.42
1.1
Benzene
Immune System
0.0077
0.010
0.0010
0,019
Bromodichioromethane
Kidney
0.0045
NC
0.00028
0.0048
Bromoform
Liver
0.021
NC
0.0013
0.022
Carbon tetrachloride
Liver
0.039
0.012
0.0091
0.060
Chloroform
Liver
0.011
0.0096
0.00091
0.022
Dibrom ochSoromethane
Liver
0.011
0.01
0.00065
0.022
Dibromom ethane
Hematological
NC
0.32
NC
0.32
Ethylbenzene
Liver / Kidney / Developments!
0.00011
0.000097
0.000058
0.00027
Naphthalene
General Toxicity / Nervous System / Respiratory
0.00087
0.034
0.00050
0.035
Toluene
Kidney / Nervous System
0.0023
0.00034
0.00070
0.0033
Trichioroethene
Developmental / Immune System /Cardiovascular / Kidney
0.068
0.14
0.0099
0.218
Xylene, o-
General Toxicity
0.000062
0.0011
0.000031
0.0012
Semi-Volatile Organic Compounds
4-Bromophenyl phenyl ether
Respiratory / Liver / Kidney
0.00035
1.0
0.00048
1.0
4-Ch!orophenyi phenyl ether
Respiratory! Liver / Kidney
0.00017
1.2
0.00023
1.2
Benzo(a)pyrene
Developmental
0.022
NC
NC
0.022
Biphenyl
Respiratory / Liver / Kidney
0.00020
1.2
0.00028
1.2
Bis(2-Ethy!hexyi)phthaiate
Liver
0.0042
NC
NC
0.0042
Dipheny! ether
Eye / Respiratory
NC
14
NC
14
N-Niirosodimethylamine
Developmental
22
NC
0.048
22
Metals
Aluminum
Nervous System
0.40
NC
0.0018
0.40
Arsenic
Skin / Cardiovascular
4.3
NC
0.019
4.3
Beryllium
Gl System
0.052
NC
0.032
0.084
Cadmium
Kidney
0.25
NC
0.022
0.27
Chromium
Undetermined
0.036
NC
0.016
0.052
Chromium, Hexavalent
Undetermined
0.010
NC
0.0036
0.014
Cobalt
Endocrine
16
NC
0.028
16
Copper
Gl System
0.21
NC
0.00093
0.21
Iron
Gl System
2.2
NC
0.0097
2.2
Manganese
Nervous System
7.2
NC
0.80
8.0
Nickel
General Toxicity
0.22
NC
0.0049
0.22
Silver
Skin
0.36
NC
0.024
0.38
Thallium
Skin
3.8
NC
0.017
3.8
Tin
Liver / Kidney
0.17
NC
0.00073
0.17
Vanadium
Skin
0.66
NC
0.11
0.77
Zinc
Immune System / Hematological
0.025
NC
0.000067
0.025
Inorganics
Nitrate as N
Hematological
0.030
NC
0.00013
0.030
Perchlorate
Endocrine
0.39
NC
0.0017
0.39
Specialty Compounds
Dimethylformamide
Liver
0.012
0.00018
0.000014
0.012
Formaldehyde
Kidney / Gl System / General Toxicity / Eye / Respiratory
0.0042
0.0026
0.000053
0.0069
Hydrazine
Liver
NA
20
NA
20
Monomethylhydrazine (MMH)
Developmental I Hematological / Liver
0.015
0.17
0.000020
0.19
UDMH
Eye / Reproductive
0.34
13
0.00020
13
Exposure PointTotal =
117
Page 1 of 4
-------
Table G-24
OU3 Risk Characterization Summary - Non-Carcinogens
Scenario Timeframe: Future
Receptor Population: Resident
Receptor Age: Child
Medium
Exposure
Exposure
Chemical of Concern
Prima ry Ta rget Orga n
Non-Carcinogenic Hazard Quotient
Medium
Point
ingestion
Inhalation
Dermal
Exposure
Routes Total
Groundwater
Bedrock
Aberjona Aquifer
Volatile Organic Compounds
Groundwater /
Plume Core -
1,1-Dichloroethane
Kidney
0.000095
NC
0.0000065
0.00010
Shower Air
Bedrock
1,2-DichSoroeihane
Undetermined / Nervous System
0.027
0.19
0.0012
0.218
2,4,4-Trimethyi-1-pentene
Liver
0.29
0.65
0.62
1.56
2,4,4-Trimethy!-2-pentene
Liver
0.090
0.20
0.19
0.48
Benzene
Immune System
0.029
0.037
0.0038
0.070
Bromodichloromethane
Kidney
0.016
NC
0.0010
0.017
Bromoform
Liver
0.042
NC
0.0027
0.045
Chloroform
Liver
0.12
0.10
0.0099
0.23
Dibromochloromethane
Liver
0.016
0.018
0.00095
0.035
Dibromom ethane
Hematological
NC
0.64
NC
0.640
Ethyibenzene
Liver / Kidney / Developmental
0.00039
0.00034
0.00020
0.00093
Methylene chloride
Liver
0.022
0.0020
0.00071
0.025
Toluene
Kidney / Nervous System
0.0039
0.00058
0.0012
0.0057
Trichioroethene
Developmental / Immune System! Cardiovascular / Kidne}
0.059
0,12
0.0086
0.188
Xylene, o
General Toxicity / Nervous System
0.000050
0.00087
0.000025
0.000945
Semi-Volatile Organic Compounds
0
Bis(2-Ethy!hexyi)phtha!ate
Liver
0.019
NC
NC
0.019
Diphenyl ether
Eye / Respiratory
NC
2.0
NC
2.000
N-Nitrosodimethylamine
Developmental
21
NC
0.045
21
Metals
0
Aluminum
Nervous System
6.0
NC
0.026
6.0
Antimony
Hematological / General Toxicity
0.64
NC
0.019
0.66
Arsenic
Skin / Cardiovascular
1.7
NC
0.0077
1.7
Beryllium
Gl System
0.35
NC
0.22
0.57
Cadmium
Kidney
1.2
NC
0.11
1.3
Chromium
Undetermined
0.93
NC
0.41
1.3
Cobalt
Endocrine
130
NC
0.23
130
Copper
Gl System
0.29
NC
0.0013
0.29
Iron
Gl System
19
NC
0.085
19
Manganese
Nervous System
46
NC
5.0
51
Nickel
General Toxicity
2.0
NC
0.044
20
Silver
Skin
4.9
NC
0.32
5.2
Thallium
Skin
6.5
NC
0.029
6.5
Zinc
Immune System / Hematological
4.2
NC
0.011
4.2
inorganics
0
Perchiorate
Endocrine
0.71
NC
0.0031
0.71
Specialty Compounds
0
Dimeth ylf orm am id e
Liver
0.016
0.00023
0.000018
0.016
Formaldehyde
Kidney / Gl System / General Toxicity / Eye / Respiratory
0.014
0.0085
0.00018
0.023
Hydrazine
Liver
NC
0.0065
NC
0.007
Exposure Point Total =
257
Page 2 of 4
-------
Table G-24
OU3 Risk Characterization Summary - Non-Carcinogens
Scenario Timeframe: Future
Receptor Population: Resident
Receptor Age: Child
Medium
Exposure
Exposure
Chemical of Concern
Primary Target Organ
Non-Carcinogenic Hazard Quotient
Medium
Point
ingestion
Inhalation
Dermal
Exposure
Routes Total
DAPL
DAPL/
Site-Wide
Volatile Organic Compounds
Shower Air
1,2,4-Trimethyibenzene
Nervous System
0.017
0.024
0.017
0.058
1,2-Dichioroethane
Undetermined / Nervous System
0.14
0.97
0.0060
1.12
1,4-Dichiorobenzene
Uver
0.00053
0.00034
0.00034
0.0012
2,4,4-TrimethyM-pentene
Liver
0.083
0.18
0.17
0.43
2,4,4-Trimethyl-2-pentene
Liver
0.065
0.14
0.14
0.35
Srom^dtchloromeihane
Immune System
Kidney
0.11
0.0065
0.14
NC
0.015
0.00041
0.27
0.0069
Bromoform
Liver
0.047
NC
0.0031
0.050
Chloroform
Liver
0.26
0.21
0.020
0.49
Cis-1,2-Dichloroethene
Kidney / General Toxicity i Liver
0.17
0.015
0.019
0.20
Dibromochlorom ethane
Liver
0.21
0.24
0.013
0.46
Dibromomethane
Liver / Hematological
NC
0.64
NC
0.64
Ethylbenzene
Liver / Kidney / Developmental
0.0017
0.0015
0.00091
0.0041
Methylene chloride
Liver
0.15
0.013
0.0048
0.17
Naphthalene
General Toxicity / Nervous System / Respiratory
0.032
1.3
0.019
1.4
Toluene
Kidney / Nervous System
0.055
0.0081
0.017
0.080
Trichioroethene
Developmental / immune System /Cardiovascular / Kidney
5.0
10
0.73
16
Vinyl chloride
Liver
0.0061
0.0020
0.00041
0.0085
Semi-Volatile Organic Compounds
4-Bromophenyl phenyl ether
Respiratory / Liver / Kidney
0.000084
0.25
0.00011
0.25
4-Ch!oroaniline
Immune System
0.011
NC
0.00064
0.012
Benzo(a)pyrene
Developmental
0.050
NC
NC
0.050
Biphenyl
Respiratory / Liver / Kidney
0.00052
3.1
0.00072
3.1
Diphenyl ether
Eye / Respiratory
NC
8.8
NC
8.8
Developmental
83
NC
0.18
83
Phthaiic acid
Urinary
0.12
NC
0.0073
0.13
Petroleum Hydrocarbons
C9-C10 Aromatics
Respiratory
0.019
0.15
0.017
0.19
Metals
Aluminum
Nervous System
95
NC
0.42
95
Arsenic
Skin / Cardiovascular
29
NC
0.13
29
Barium
Urinary
0.27
NC
0.017
0.29
Beryllium
Gl System
2.5
NC
1.6
4.1
Cadmium
Kidney
6.6
NC
0.58
7.2
Chromium
Undetermined
76
NC
34
110
Chromium, Hexavalent
Undetermined
0.61
NC
0.22
0.83
Cobalt
Endocrine
953
NC
1.7
955
Copper
Gl System
5.9
NC
0.026
5.9
Iron
Gl System
235
NC
1.0
236
Manganese
Nervous System
352
NC
39
391
Mercury
Immune System / Urinary
0.52
NC
0.032
0.55
Nickel
General Toxicity
12
NC
0.27
12
Silver
Skin
102
NC
6.7
109
Thallium
Skin
28
NC
0.13
28
Tin
Liver / Kidney
73
NC
0.32
73
Vanadium
Skin
2.5
NC
0.42
2.9
Zinc
Immune System / Hematological
1.5
NC
0.0039
15
Inorganics
Nitrate as N
Hematological
0.39
NC
0.0017
0.39
Nitrite as N
Hematological
0.50
NC
0.0022
0.50
Perchlorate
Endocrine
1.0
NC
0.0044
1.0
Specialty Compounds
Acetaldehyde
Nervous System / Respiratory
NC
0.85
NC
0.85
Dimethylformamide
Liver
0.12
0.0018
0.00014
0.12
Formaldehyde
Kidney / Gl System / General Toxicity / Eye / Respiratory
0.31
0.19
0.0039
0.50
Hydrazine
Liver
NC
0.015
NC
0.02
UDMH
Eye / Reproductive
31
1164
0.018
1195
Exposure PosntTotal»
3379
Page 3 of 4
-------
Table G-24
Key
DAPL - Dense aqueous phase liquid
Gl - Gastrointestinal
NA-Toxicity criteria are not available to quantitatively address this route of exposure.
NC - NotCafculatecl
This table provides hazard quotients (HQs) for each route of exposure and the hazard index (sum of the hazard quotients) for significant routes of exposure for hypothetical future child residents exposed to groundwater or DAPL.
The Risk Assessment Guidance for Superfund (RAGS) states that, generally, a hazard index (HI) of greater than 1 indicates the potential for adverse noncancer effects. Results presented use toxicity values and site-specific
exposure parameters from the baseline HHRA.
Source: A Guide to Preparing Superfund Proposed Plans, Records of Decision, and Other Remedy Selection Decision Documents (U.S. EPA, 1999)
Page 4 of 4
ROD Section G Tabies-HH_OU3R1
-------
ROD RISK WORKSHEET
Table G-25
OU3 Risk Characterization Summary - Carcinogens
Scenario Timeframe: Future
Receptor Population: Construction Worker
Receptor Age: Adult
Medium
Exposure
Medium
Exposure Point
Chemical of Concern
Carcinogenic Risk
Ingestion
Inhalation
Dermal
External
(Radiation)
Exposure
Routes Total
Groundwater
Groundwater /
Shallow Overburden
Volatile Organic Compounds
Excavation
Groundwater -
1,4-Dichlorobenzene
3.3E-12
5.4E-08
3.5E-10
NA
5.4E-08
Air
Plant B
Benzene
2.3E-11
1.9E-07
6.0E-10
NA
1.9E-07
Ethylbenzene
8.7E-11
2.3E-07
8.1E-09
NA
2.4E-07
Methyl Tertbutyl Ether
4.3E-11
7.0E-08
NC
NA
7.0E-08
Naphthalene
1.0E-09
2.1E-06
1.0E-07
NA
2.2E-06
Semi-Volatile Organic Compounds
2,6-Dinitrotoluene
8.7E-09
NC
9.3E-08
NA
1.0E-07
Biphenyl
1.3E-1Q
NC
3.1E-08
NA
3.1E-08
Bis(2-Ethylhexyl)phthalate
2.3E-10
NC
NC
NA
2.3E-10
N-Nitrosodimethylamine
9.3E-1Q
5.1E-08
4.2E-10
NA
5.2E-08
N-Nitrosodiphenylamine
2.0E-10
NC
NC
NA
2.0E-10
Metals
Arsenic
6.6E-09
NC
8.9E-09
NA
1.6E-08
Chromium, Hexavalent
2.2E-10
NC
1.8E-11
NA
2.4E-10
Exposure Risk Total =
3E-06
Groundwater
Groundwater /
Shallow
Volatile Organic Compounds
Excavation
Overburden -
1,2,4-T richlorobenzene
1.2E-11
NC
2.5E-09
NA
2.5E-09
Air
On-Property
1,2-Dichloroethane
5.5E-11
1.8E-07
4.5E-10
NA
1.8E-07
Bromodichloromethane
6.8E-11
2.9E-07
7.1E-10
NA
2.9E-07
Bromoform
4.1E-11
2.2E-08
4.3E-10
NA
2.2E-08
Dibromochloromethane
2.3E-10
3.1E-07
2.2E-09
NA
3.1E-07
Methylene chloride
2.3E-11
1.6E-09
1.5E-10
NA
1.8E-09
Naphthalene
2.6E-11
5.3E-08
2.5E-09
NA
5.6E-08
Trichloroethene
1.5E-11
1.3E-08
3.9E-10
NA
1.3E-08
Semi-Volatile Organic Compounds
2,6-Dinitrotoluene
5.8E-10
NC
6.2E-09
NA
6.8E-09
4-Bromophenyl phenyl ether
1.0E-11
NC
2.4E-09
NA
2.4E-09
Benzo(a)pyrene
9.2E-11
NC
NC
NA
9.2E-11
Benzo(b)fluoranthene
1.8E-11
NC
NC
NA
1.8E-11
Biphenyl
7.3E-12
NC
1.7E-09
NA
1.7E-09
Dibenz(a,h)anthracene
1.7E-10
NC
NC
NA
1.7E-10
lndeno(1,2,3-cd)pyrene
1.8E-11
NC
NC
NA
1.8E-11
N-Nitrosodimethylamine
1.9E-08
1.1E-G6
8.7E-09
NA
1.1E-06
N-Nitrosodiphenylamine
8.5E-12
NC
NC
NA
8.5E-12
Metals
0.0E+00
Arsenic
6.7E-09
NC
9.0E-09
NA
1.6E-08
Chromium, Hexavalent
2.5E-10
NC
2.1E-11
NA
2.7E-10
Specialty Compounds
Formaldehyde
NC
1.2E-08
NC
NA
1.2E-08
Hydrazine
5.8E-08
1.5E-05
NC
NA
1.5E-05
Monomethylhydrazine (MMH)
NC
1.0E-07
NC
NA
1.0E-07
Exposure Risk Total =
2E-05
Page 1 of 2
-------
Table G-25
OU3 Risk Characterization Summary - Carcinogens
Scenario Timeframe: Future
Receptor Population: Construction Worker
Receptor Age: Adult
Medium
Exposure
Medium
Exposure Point
Chemical of Concern
Carcinogenic Risk
Ingestion
Inhalation
Dermal
External
(Radiation)
Exposure
Routes Total
Groundwater
Groundwater /
Shallow
Volatile Organic Compounds
Excavation
Overburden -
1,1-Dichloroethane
3.3E-12
1.1E-08
4.3E-11
NA
1.1 E-08
Air
Off-Property
1,4-Dichlorobenzene
1.7E-11
2.8E-07
1.8E-09
NA
2.8E-07
1,4-Dioxane
5.2E-09
1.1E-07
3.2E-09
NA
1.2E-07
Benzene
5.1E-10
4.2E-06
1.4E-08
NA
4.2E-06
Chloroform
1.1E-11
7.9E-08
1.5E-10
NA
7.9E-08
Ethylbenzene
4.2E-10
1.1E-06
3.9E-08
NA
1.1E-06
Methylene chloride
1.7E-11
1.2E-09
1.1E-10
NA
1.3E-09
Naphthalene
2.1E-10
4.2E-07
2.0E-08
NA
4.4E-07
Trichloroethene
2.3E-11
2.0E-08
5.9E-10
NA
2.1 E-08
Vinyl chloride
3.3E-10
4.1 E-08
4.8E-09
NA
4.6E-08
Semi-Volatile Organic Compounds
Atrazine
1.3E-10
NC
2.5E-09
NA
2.6E-09
Benzo(a)anthracene
1.5E-11
3.6E-09
1.5E-11
NA
3.6E-09
Benzo{a)pyrene
1.1E-10
NC
1.1E-10
NA
2.2E-10
Benzo(b)fluoranthene
1.7E-11
NC
1.7E-11
NA
3.4E-11
Bis(2-Ethylhexyl)phthalate
6.7E-12
NC
6.7E-12
NA
1.3E-11
Dibenz(a,h)anthracene
1.2E-10
NC
1.2E-10
NA
2.4E-10
lndeno(1,2,3-cd)pyrene
1.5E-11
NC
1.5E-11
NA
3.0E-11
N-Nitrosodimethylamine
3.3E-10
1.8E-08
4.8E-10
NA
1.9E-08
Metals
Arsenic
1.4E-08
NC
1.8E-08
NA
3.2E-08
Chromium, Hexavalent
3.4E-10
NC
2.8E-11
NA
3.7E-10
Specialty Compounds
Formaldehyde
NC
1.2E-Q8
NC
NA
1.2E-08
Hydrazine
9.9E-11
2.5E-08
9.9E-11
NA
2.5E-08
Exposure Risk Total =
6E-06
Key
NA - Exposure route not applicable for this chemical/exposure medium.
NC - Not carcinogenic by this expsoure route.
This table provides risk estimates for the significant routes of exposure for the hypothetical future adult construction worker exposure to groundwater. 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 construction worker exposure to groundwater, as well as the toxicity of the COCs.
Source: A Guide to Preparing Superfund Proposed Plans, Records of Decision, and Other Remedy Selection Decision Documents (U.S. EPA, 1999)
Page 2 of 2
-------
ROD RISK WORKSHEET
Table G-26
OU3 Risk Characterization Summary - Non-Carcinogens
Scenario Timeframe: Future
Receptor Population: Construction Worker
Receptor Age: Aduit
Medium
Exposure
Exposure
Chemical of Concern
Primary Target Organ
Non-Carcinogenic Hazard Quotient
Medium
Point
Ingestion
Inhalation
Dermal
Exposure
Routes Total
Groundwater
Groundwater/
Shallow
Volatile Organic Compounds
Excavation
Overburden -
1,4-Dichforobenzene
Liver
0.00000061
0.00029
0.000065
0.00036
Air
Plant B
2,4.4-Trimethyi-1-pentene
Liver
0.00037
1,0
1.3
2.3
2,4,4-Trimethyl-2-pentene
Liver
0.00013
0.36
0.44
0.80
Benzene
Hematological
0.000011
0.021
0.00071
0.022
Ethylbenzene
Liver / Nervous System
0.000011
0.00072
0.00051
0.0012
Naphthalene
Developmental / Nervous System / Respiratory
0.0000010
1.5
0.0029
1.5
Xylene, o
General Toxicity / Nervous System
0.0000032
0.037
0.00057
0.038
Semi-Volatile Organic Compounds
2,6-Dinitrotoiuene
Endocrine
0.00014
NA
0.015
0.015
Bipheny!
Developmental / Respiratory / Liver! Kidney
0.000012
1.6
0.00054
1,6
Bis{2-Ethy!hexy!)phthalate
Liver
0.000057
NA
NC
0.000057
Diphenyl ether
Eye / Respiratory
NC
9.6
NC
9.6
N-Nitrosodimethylamine
Developmental / General Toxicity
0.00016
0.0063
0.000072
0.0065
Petroleum Hydrocarbons
C11-C22 Aromatics Adjusted
Respiratory / Reproductive
0.0046
0.13
0.69
0 82
C5-C8 Aliphatics
Nervous System
0.00013
0.29
NC
0.29
C9-C12 Aliphatics
Liver I Kidney / Respiratory
0.000026
0.25
NC
0.25
Metals
Aluminum
Nervous System
0.000095
NC
Q.00013
0.00023
Antimony
General Toxicity
0.00028
NC
0.0026
0.0029
Arsenic
Gl System
0.000062
NC
0.0014
0.0015
Cadmium
Kidney
0.000097
NC
0.0027
0.0028
Chromium, Hexavalent
Undetermined
0.000010
NC
0.0011
0.0011
Cobalt
Endocrine
0.000074
NC
0.00042
0.00049
Iron
Gl System
0.00022
NC
0.00031
0.00053
Manganese
Nervous System
0.00084
NC
0.029
0.030
Vanadium
Kidney
0.0014
NC
0.011
0.012
Inorganics, Total
Nitrate as N
Hematological
0.000021
NC
0.000075
0.000096
Nitrite as N
Hematological
0.00013
NC
0.00019
0.00032
Exposure Point Total *
17
Page 1 of 3
-------
Table G-26
OU3 Risk Characterization Summary - Non-Carcinogens
Scenario Timeframe: Future
Receptor Population: Construction Worker
Receptor Age: Adult
Medium
Exposure
Exposure
Chemical of Concern
Primary Target Organ
Non-Carcinogenic Hazard Quotient
Medium
Point
Ingestion
Inhalation
Dermal
Exposure
Routes Total
Groundwater
Groundwater/
Shallow
Volatile Organic Compounds
Excavation
Overburden -
1,2,4-Trichlorobenzene
Urinary / Liver
0.00000033
0.0094
0.00061
0.010
Air
On-Property
1,2-DichSoroethane
Nervous System / Kidney
0.Q000021
0.0068
0.000057
0.0069
2,4,4-Trimethyl-1-pentene
Liver
0.000011
0.030
0.036
0.066
2,4.4-Trimethyi-2-pentene
Liver
0.0000038
0.011
0.013
0.024
Bromodichlorom ethane
Kidney I Reproductive
0.0000096
0.028
0.000040
0.028
Bromoform
Liver
0.000012
0.00019
Q.00020
Dibromochlorom ethane
Liver
0.0000027
0.004
0.000093
0.0041
Dibromomethane
Hematological
0.000020
0.027
NC
0.027
Methylene chloride
Nervous System
0.0000041
0.011
0.00088
0.012
Naphthalene
Nervous System / Respiratory / Developmental
0.000000025
0.036
0.000073
0.036
Trichloroethene
Developmental/ Immune System /Cardiovascular / Kidney
0.000047
0.11
0.0012
0.11
Semi-Volatile Organic Compounds
2,6-Dinitrotoiuene
Endocrine
0.0000090
0.00096
0.00097
4-Bromophenyl phenyl ether
Respiratory / Liver / Kidney I Developmental
0.00000090
0.050
0.000042
0.050
Benzo(a)pyrene
Developmental
0.000021
NC
NC
0.000021
Biphenyl
Respiratory / Liver / Kidney / Developmental
0.00000064
0.087
0.000030
0.087
Diphenyl ether
Eye / Respiratory
NC
0.22
NC
0.22
N-Nrtrosodimethylamine
General Toxicity / Developmental
0.0033
0.13
0.0015
0.13
Metals
Aluminum
Nervous System
0.000049
NC
0.000069
0.00012
Antimony
General Toxicity
0.00020
NC
0.0019
0.0021
Arsenic
Gl System
0.000063
NC
0.0015
0.0016
Beryllium
G! System
0.000011
NC
0.0022
0.0022
Cadmium
Kidney
0.000083
NC
0.0023
0.0024
Chromium, Hexavalent
Undetermined
0.000012
NC
0.0013
0.0013
Cobalt
Endocrine
0.00027
NC
0.0015
0.0018
Copper
G! System
0.00012
NC
0.000042
0.00016
Iron
Gl System
0.00073
NC
0.0010
0.0017
Manganese
Nervous System
0.0044
NC
0.16
0.16
Nickel
General Toxicity
0.000018
NC
0.00012
0.0001
Silver
Skin
0.00015
NC
0.0033
0.0035
Thallium
Skin
0.00033
NC
0.0019
0.0022
Vanadium
Kidney
0.0016
NC
0.012
0.014
Zinc
Immune System / Hematological
0.000032
NC
0000027
0.000059
Inorganics, Total
Nitrate as N
Hematological
0.000032
NC
0.00011
0 00014
Nitrite as N
Hematological
0.0000086
NC
0.000012
0.000021
Perchlorate
Endocrine
0.000042
NC
0.000059
0.00
Specialty Compounds
Dimethylfbrmamide
Liver/Reproductive
0.0000036
0.00013
0.0000025
0.00014
Formaldehyde
Eye t Respiratory / Kidney / Gl System / General Toxicity
0.0000036
0.0018
0.000011
0.0018
Hydrazine
Liver
NC
2.3
NC
2.3
Kempore (Azodicarbonamide)
Reproductive
0.00022
0.000012
0.00023
MonomethyShydrazine (MMH)
Hematological / Liver / Developmental
0.000013
0.024
0.0000039
0.024
UDMH
Reproductive / Eye
0.00030
6.0
0.000037
6.0
Exposure Point Total =
9.0
Page 2 of 3
-------
Table G-26
OU3 Risk Characterization Summary - Non-Carcinogens
Scenario Timeframe: Future
Receptor Population: Construction Worker
Receptor Age: Adult
Medium
Exposure
Exposure
Chemical of Concern
Primary Target Organ
Non-Carcinogenic Hazard Quotient
Medium
Point
Ingestion
Inhalation
Dermal
Exposure
Routes Total
Groundwater
Groundwater/
Shallow
Volatile Organic Compounds
Excavation
Overburden -
1,1-Dichloroethane
Kidney
0.000000020
NC
0.0000026
0.0000026
Air
Off-Property
1,2,4-Trimethylbenzene
Nervous System
0.000064
0.11
0.011
0.12
1,4-Dichloro benzene
Liver
0.0000031
0.0015
0.00033
0.0018
1,4-Dioxane
Eye
0.0000073
0.0022
0.000075
0.0023
2,4,4-Trimethyl-1-pentene
Liver
0.000047
0.13
0.16
0.29
2,4,4-Trimethyl-2-pentene
Liver
0.000012
0.032
0.040
0.072
Benzene
Hematological
0.00024
0.47
0.016
0.49
Chlorobenzene
Liver / Kidney
0.000053
0.079
0.010
0.089
Chloroform
Liver
0.00000024
0.0010
0.000034
0.0010
Cts-1,2-Dichloroethene
Liver / Hematological
0.000000051
0.0032
0.00054
0.0037
Ethylbenzene
Nervous System / Liver
0.000054
0.0035
0.0025
0.0061
Methylene chloride
Nervous System
0.0000030
0.0082
0.00065
0.0089
Naphthalene
Nervous System / Respiratory / Developmental
0.00000020
0.29
0.00059
0.29
Tetrahydrofuran
Liver / Nervous System / Developmental
0.00017
0.42
0.00038
0.42
Toluene
Nervous System / Kidney
0.0000096
0.021
0.0054
0.026
Trichloroethene
Developmental / Immune System /Cardiovascular / Kidney
0.000071
0.17
0.0018
0.17
Vinyl chloride
Respiratory / Liver
0.000011
0.0085
0.00016
0.0087
Xylene, o
Nervous System / General Toxicity
0.0000021
0.025
0.00038
0.025
Xylenes (m&p)
Nervous System / General Toxicity
0.000020
0.24
0.0040
0.24
Semi-Volatile Organic Compounds
4,6-Dinitro-2-methylphenoi
Developmental / Eye
0.000059
NC
0.0059
0.0060
Atrazine
Reproductive
0.000013
NC
0.000022
0.000035
Benzo(a)pyrene
Developmental
0.000026
NC
NC
0.000026
Bis(2-Ethy!hexyi)phthalate
Liver
0.0000017
NC
NC
0.0000017
Diphenyl ether
Eye / Respiratory
NC
0.12
NC
0.12
N-Nitrosodimethylamine
General Toxicity / Developmental
0.000057
0.0022
0.000026
0.0023
Metais
Aluminum
Nervous System
0.0000092
NC
0 000013
0.000022
Antimony
General Toxicity
0.00062
NC
0.0058
0.0064
Arsenic
Gl System
0.00013
NC
0.0030
0.0031
Cadmium
Kidney
0.000058
NC
0.0016
0.0017
Chromium, Hexavalent
Undetermined
0.000016
NC
0.0018
0.0018
Cobalt
Endocrine
0.00012
NC
0.00070
0.00082
Iron
Gl System
0.0012
NC
0.0017
0.0029
Manganese
Nervous System
0.0023
NC
0.081
0.083
Thallium
Skin
0.00043
NC
0.0024
0.0028
Vanadium
Kidney
0.00038
NC
0.0029
0.0033
inorganics
Nitrate as N
Hematological
0.000012
NC
0.000043
0.000055
Specialty Compounds
Formaldehyde
Eye I Respiratory / Kidney / Gl System / General Toxicity
0.0000036
0.0018
0.000011
0.0018
Hydrazine
Liver
NC
0.0040
NC
0.0040
Exposure Point Totai =
2.5
Key
Gl - Gastrointestinal
NA - Toxicity criteria are not availabl
i to quantitatively address this route of exposure.
NC - Not Calculated
This table provides hazard quotients (HQs) for each route of exposure and the hazard index (sum of the hazard quotients) for significant routes of exposure for future construction workers exposed to groundwater. The Risk
Assessment Guidance for Superfund (RAGS) states that, generally, a hazard index (Hi) of greater than 1 indicates the potential for adverse noncancer effects. Results presented use toxicity
values and site-specific exposure
parameters from the baseline HHRA
Source: A Guide to Preparing Superfund Proposed Plans, Records of Decision, and Other Remedy Selection Decision Documents (U.S. EPA, 1999)
Page 3 of 3
-------
ROD RISK WORKSHEET
Table G-27
OU3 Risk Characterization Summary
Carcinogens
Scenario Timeframe: Current
Receptor Population: Resident
Receptor Age: Adult
Medium
Exposure
Medium
Exposure Point
Chemical of Concern
Carcinogenic Risk
Ingestion
Inhalation
Dermal
External
(Radiation)
Exposure
Routes Total
Groundwater
Groundwater /
Residential Well -
Semi-Volatiie Organic Compounds
Shower Air
Maximum
Benzo(a)anthracene
1.9E-07
1.1E-07
NC
NA
3.0E-07
Concentration
N-Nitrosodimethylamine
Metals
2.2E-05
1.7E-06
5.4E-08
NA
2.4E-05
Chromium, Hexavalent
8.1E-05
NC
3.0E-05
NA
1.1E-04
Exposure Risk Total =
1E-04
Key
NA - Exposure route not applicable for this chemical/exposure medium.
NIC - Not carcinogenic by this expsoure route.
This table provides risk estimates for the significant routes of exposure for the current adult resident exposure to groundwater. Risks from irrigation were below 1x1 Cf6 and not included. Risks were
originally calculated on a per-residence basis; maximum risks are shown. 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 residential exposure to groundwater, as well as the toxicity of the COCs.
Source: A Guide to Preparing Superfund Proposed Plans, Records of Decision, and Other Remedy Selection Decision Documents (U.S. EPA, 1999)
Page 1 of 1
-------
ROD RISK WORKSHEET
Table G-28
OU3 Risk Characterization Summary - Carcinogens
Scenario Timeframe: Current
Receptor Population: Resident
Receptor Age: Child
Medium
Exposure
Medium
Exposure Point
Chemical of Concern
Carcinogenic Risk
Ingestion
Inhalation
Dermal
External
(Radiation)
Exposure
Routes Total
Groundwater
Groundwater /
Residential Well -
Semi-Volatile Organic Compounds
Shower Air
Maximum
Benzo(a)anthracene
2.5E-07
5.5E-08
NC
NA
3.1E-07
Concentration
N-Nitrosodimethylamine
Metals
2.9E-05
8.2E-07
6.3E-08
NA
3.0E-05
Chromium, Hexavaient
1.1E-04
NC
3.2E-05
NA
1.4E-04
Exposure Risk Total =
2E-04
Groundwater
Irrigation/
Residential Well -
Metals
Recreation
Maximum
Concentration
Chromium, Hexavaient
9.4E-08
NC
2.4E-06
NA
2.5E-06
Exposure Risk Total =
3E-06
Key
NA - Exposure route not applicable for this chemical/exposure medium.
NC - Not carcinogenic by this expsoure route.
This table provides risk estimates for the significant routes of exposure for the current child resident exposure to groundwater. Risks were originally calculated on a per-residence basis; maximum risks are
shown. 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 residential
exposure to groundwater, as well as the toxicity of the COCs.
Source: A Guide to Preparing Superfund Proposed Plans, Records of Decision, and Other Remedy Selection Decision Documents (U.S. EPA, 1999)
Page 1 of 1
-------
ROD RISK WORKSHEET
Table G-Eco1
Occurrence, Distribution, and Selection of Surface Water Contaminants of Concern
Exposure Medium: Surface Water
Exposure Area
Chemical of
Concern
Concentration
Detected (mg/kg)
Mean
(mg/kg)
95% UCL2
(rng/L)
Reference
(mg/L)
Screening
Toxicity Value
(mg/L)
Screening
Toxicity Value
Source3
HQ Value4
Minimum
Maximum
Maximum
Average
RME
CTE
South Ditch Stream
Semivolatile Organics
Azobenzene
0.00046
0.00053
0.0017
0.00056
NA
NA
NA
NA
NA
NA
Benzo(a)pyrene
0.00015
0.00015
0.00016
NC
NA
NA
0.000014
ORNL-SCV
0.63
0.63
Bis(2-Ethylhexyl)phthalate
0.0018
0.0061
0.0024
0.0034
NA
NA
0.003
ORNL-SCV
0.13
0.090
N-Nitrosodi-n-propylamine
0.0000049
0.0000093
0.0000035
0.0000066
NA
NA
NA
NA
NA
NA
Metals, Total
Aluminum
0.076
280
4.9
19
NA
NA
0.087
AWQC-CCC
25
6.5
Barium
0.013
0.032
0.024
0.027
NA
NA
0.004
ORNL-SCV
0.24
0.22
Beryllium
0.0003
0.0011
0.00061
0.00084
NA
NA
0.00066
ORNL-SCV
0.024
0.017
Chromium [d]
0.0085
64
1.1
3.3
NA
NA
0.12
AWQC-CCC
2.2
0.73
Cobait
0.0053
0.05
0.028
0.037
NA
NA
0.023
ORNL-SCV
0.024
0.019
Copper [d]
0.00021
0.026
0.0090
0.017
NA
NA
0.019
AWQC-CCC
0.63
0.35
Iron
1.5
13
5.9
7.9
NA
NA
1
AWQC-CCC
NA
NA
Lead [d]
0.00028
0.0021
0.00063
0.00094
NA
NA
0.0018
AWQC - CCC
0.0086
0.0057
Manganese
0.5
2.2
1.5
1.8
NA
NA
0.12
ORNL-SCV
0.78
0.65
Silver
0.0Q0017
0.000017
0.00027
NC
NA
NA
0.000012
EPA Region 4 - Chronic
0.014
0.014
Metals, Filtered
Aluminum
0.02
22
0.69
1.5
NA
NA
0.087
AWQC - CCC
25
6.5
Chromium
0.004
5
0.20
0.40
NA
NA
0.10
AWQC-CCC
7.2
2.4
Inorganics
Bromide
0.14
0.48
0.32
0.40
NA
NA
NA
NA
NA
NA
Chloride
60
300
164
172
NA
NA
230
AWQC-CCC
0.20
0.19
Nitrite as N
0.01
0.043
0.031
0.021
NA
NA
NA
NA
NA
NA
Nitrogen, as Ammonia [e]
14
250
56
73
NA
NA
3.0
AWQC - CCC
2.0
1.6
Central Pond
Metals, Total
Aluminum
0.21
0.21
0.21
NC
NA
NA
0.087
AWQC-CCC
0.28
0.28
Barium
0.049
0.049
0.049
NC
NA
NA
0.004
ORNL-SCV
0.45
0.45
Manganese
0.7
0.7
0.70
NC
NA
NA
0.12
ORNL-SCV
0.30
0.30
Silver
0.000015
0.000015
0.000015
NC
NA
NA
0.000012
EPA Region 4 - Chronic
0.012
0.012
inorganics
Bromide
0.13
0.13
0.13
NC
NA
NA
NA
NA
NA
NA
Nitrite as N
0.075
0.075
0.075
NC
NA
NA
NA
NA
NA
NA
Nitrogen, as Ammonia fe]
28
28
28
NC
NA
NA
3.0
AWQC-CCC
0.78
0.78
Page 1 of 4
-------
Table G-Eco1
Occurrence, Distribution, and Selection of Surface Water Contaminants of Concern
Exposure Medium: Surface Water
Exposure Area
Chemical of
Concern
Concentration
Detected (mg/kg)
Mean
(mg/kg)
95% UCL2
(rng/L)
Reference
(mg/L)
Screening
Toxicity Value
(mg/L)
Screening
Toxicity Value
Source3
HQ Value4
Minimum
Maximum
Maximum
Average
RME
CTE
Storm Water Detention
Basin
Semivolatile Organics
N-Nitrosodiphenylamine
0.0000074
0.0000074
0.0000074
NC
NA
NA
NA
EPA Region 3
0.0000019
0.0000019
Metals, Total
Aluminum
0.9
0.9
0.90
NC
NA
NA
0.087
AWQC-CCC
1.2
1.2
Barium
0.026
0.026
0.026
NC
NA
NA
0.004
ORNL-SCV
0.24
0.24
Iron
1.5
1.5
1.5
NC
NA
NA
1
AWQC-CCC
NA
NA
Lead [dj
0.003
0.003
0.0030
NC
NA
NA
0.0014
AWQC-CCC
0.035
0.035
Silver
0.000056
0.000056
0.000056
NC
NA
NA
0.000012
EPA Region 4 - Chronic
0.046
0.046
Inorganics
Nitrite as N
0.026
0.026
0.026
NC
NA
NA
NA
NA
NA
NA
Nitrogen, as Ammonia [e]
7.5
7.5
7.5
NC
NA
NA
3.0
AWQC-CCC
0.21
0.21
Off-PWD Stream
Volatile Organics
Carbon disulfide
0.001
0.0025
0.0033
0.0025
NA
NA
0.00092
ORNL-SCV
0.15
0.15
Semivolatile Organics
3 & 4 Methylphenol
0.00073
0.00076
0.0018
0.00078
NA
NA
NA
NA
NA
NA
Benzo(a)anthracene
0.00024
0.002
0.00047
NC
NA
NA
0.000027
ORNL-SCV
4.1
0.95
Benzo(a)pyrene
0.00012
0.0042
0.00089
0.0023
NA
NA
0.000014
ORNL-SCV
9.5
3.7
Benzo(b)f!uoranthene
0.00019
0.0077
0.0016
0.0040
NA
NA
0.0006
ECOSAR- CSV
0.67
0.27
Benzo(ghi)perylene
0.00011
0.0046
0.00099
0.0026
NA
NA
0.0002
ECOSAR- CSV
1.3
0.50
Benzo(k)fluoranthene
0.0005
0.0026
0.00061
0.0026
NA
NA
0.0006
ECOSAR-CSV
0.43
0.10
Ghrysene
0.00018
0.0053
0.0012
0.0027
NA
NA
0.0019
ECOSAR-CSV
0.14
0.064
Dibenz(a,h)anthracene
0.0012
0.0012
0.00039
NC
NA
NA
0.0002
ECOSAR-CSV
0.60
0.20
lndeno(1,2,3-cd)pyrene
0.000098
0.004
0.00088
0.0040
NA
NA
0.0002
ECOSAR-CSV
2.0
0.44
Phenanthrene
0.000081
0.0025
0.00053
0.0013
NA
NA
0.0004
EPA Region 3
3.3
1.3
Pyrene
0.00022
0.012
0.0031
0.0063
NA
NA
0.000025
EPA Region 3
253
122
Metals, Total
Aluminum
0.1
1.6
0.82
1.3
NA
NA
0.087
AWQC-CCC
1.7
1.1
Barium
0.026
0.046
0.035
0.041
NA
NA
0.004
ORNL-SCV
0.37
0.31
Chromium [d]
0.0061
0.13
0.050
0.093
NA
NA
0.051
AWQC-CCC
0.15
0.081
Iron
5
30
16.4
25
NA
NA
1
AWQC-CCC
NA
NA
Lead fdl
0.00082
0.0058
0.0027
0.0043
NA
NA
0.00047
AWQC-CCC
0.15
0.092
Manganese
0.27
1.5
0.85
1.3
NA
NA
0.12
ORNL-SCV
0.55
0.37
Zinc [d]
0.009
0.12
0.038
0.095
NA
NA
0.069
AWQC-CCC
1.4
0.54
Inorganics
Bromide
0.1
0.21
0.15
0.20
NA
NA
NA
NA
NA
NA
Nitrite as N
0.02
0.02
0.023
NC
NA
NA
NA
NA
NA
NA
Nitrogen, as Ammonia fe|
17
66
45
60
NA
NA
3.0
AWQC-CCC
1.7
1.2
Page 2 of 4
-------
Table G-Eco1
Occurrence, Distribution, and Selection of Surface Water Contaminants of Concern
Exposure Medium: Surface Water
Exposure Area
Chemical of
Concern
Concentration
Detected (mg/kg)
Mean
(mg/kg)
95% UCL2
(rng/L)
Reference
(mg/L)
Screening
Toxicity Value
(mg/L)
Screening
Toxicity Value
Source3
HQ Value4
Minimum
Maximum
Maximum
Average
RME
CTE
MMB Wetland
Semivotatite Organics
Benzo(a)pyrene
0.000096
0.00013
0.000094
0.00014
ND
ND
0.000014
ORNL-SCV
0.54
0.39
Caprolactam
0.00066
0.00066
0.0021
NC
0.00056
0.001405
NA
NA
NA
NA
N-Nitrosodi-n-propylamine
0.00000044
0.00000078
0.0000041
0.00000080
ND
ND
NA
NA
NA
NA
Metals, Total
Aluminum
0.012
1.8
0.17
0.68
0.44
0.24
0.087
AWQC-CCC
0.90
0.23
Barium
0.015
0.15
0.037
0.046
0.05
0.038
0.004
ORNL-SCV
0.41
0.33
Copper [d]
0.00077
0.054
0.0048
0.015
0.0039
0.0026
0.009
AWQC-CCC
1.4
0.44
Iron
0.39
29
3.4
9.9
2.0
1.1
1
AWQC-CCC
NA
NA
Lead [d]
0.00016
0.11
0.0065
0.038
0.0013
0.0011
0.00058
AWQC-CCC
1.0
0.18
Manganese
0.03
9.3
0.91
2.7
0.59
0.31
0.12
ORNL-SCV
1.2
0.39
Inorganics
Bromide
0.1
0.12
0.055
0.10
ND
ND
NA
NA
NA
NA
North Pond
Semivolatile Organics
Benzo(a)anthracene
0.000076
0.00012
0.00012
NC
NA
NA
0.000027
ORNL-SCV
0.24
0.24
Benzo(a)pyrene
0.00013
0.00017
0.00012
NC
NA
NA
0.000014
ORNL-SCV
0.71
0.51
Caprolactam
0.00033
0.00033
0.0019
NC
NA
NA
NA
NA
NA
NA
Pyrene
0.000094
0.00039
0.00080
NC
NA
NA
0.000025
EPA Region 3
16
16
Metals, Total
Aluminum
0.11
0.22
0.15
NC
NA
NA
0.087
AWQC-CCC
0.29
0.20
Barium
0.026
0.041
0.034
NC
NA
NA
0.004
ORNL-SCV
0.37
0.31
Iron
0.57
2.9
1.9
NC
NA
NA
1
AWQC-CCC
NA
NA
Lead [d]
0.00022
0.0013
0.00093
NC
NA
NA
0.00097
AWQC-CCC
0.02
0.02
Manganese
0.32
0.49
0.39
NC
NA
NA
0.12
ORNL-SCV
0.21
0.17
Silver
0.000022
0.000022
0.00038
NC
NA
NA
0.000012
EPA Region 4 - Chronic
0.018
0.018
Inorganics
Bromide
0.27
0.65
0.28
NC
NA
NA
NA
NA
NA
NA
Chloride
120
320
190
NC
NA
NA
230
AWQC-CCC
0.37
0.22
Page 3 of 4
-------
Table G-Eco1
Occurrence, Distribution, and Selection of Surface Water Contaminants of Concern
Exposure Medium: Surface Water
Exposure Area
Chemical of
Concern
Concentration
Detected (mg/kg)
Minimum Maximum
Mean
(mg/kg)
95% UCL2
(mg/L)
Reference
(mg/L)
Maximum Average
Screening
Toxicity Value
(mg/L)
Screening
Toxicity Value
Source3
HQ Value
RME
CTE
Key
ng/L - microgram per liter
NA - Not Applicable
ND - Not Detected
PWD - Property West Ditch
1 Minimum/maximum/mean detected concentration above the sample quantitation limit
The 95% Upper Confidence Limit (UCL) represents the RME concentration
[b] AWQC-CCC for aluminum is for waters with pH between 6.5 and 9.0.
[c] AWQC-CCC is for the dissolved fraction of the metal.
[d] Hardness dependent criteria. AWQC-CCC are calculated for exposure area specific average hardness using the equations presented in USEPA (2013).
[e] WQC-CCC for ammonia in freshwater are pH, temperature, and receptor and receptor life-stage dependent and are calculated using the equations presented in EPA, 2013
Surface Water Screening benchmark sources in order of preference:
1. AWQC - CCC - EPA, Freshwater Ambient Water Quality Criteria (AWQC) Chronic Continuous Concentration (CCC) (EPA, 2013).
2. ORNL - SCV - Oak Ridge National Laboratory (ORNL) Tier II Secondary Chronic Values (SCVs) from Suter and Tsao, 1996 as cited in Buchman, 2008, Screening Quick Reference Tables
(SQuiRTs from NOAA).
3. EPA Region 4 - Chronic-(EPA, 2001)
4. EPA Region 3 (EPA, 2006)
5. Estimated benchmarks using EPA, 2012 Ecological Structure Activity Relationships (ECOSTAR) Database v. 1,11 chronic toxicity value equal to a LC50+10 were restored to LC50s and factors of 10
for non-persistent chemicals, 20 for persistnent non-bioaccumulating chemicals, and 100 for persistent and bioaccumulating chemicals were applied to convert to NOAELs. Methodology derived from the
Texas Surface Water Quality Standards(30 TAC §307.6(c).(7), as amended TNRCC, 2000b).
HQ (Hazard Quotient) calculated by dividing the exposure point concentration by the effects benchmark.
Surface water chemicals of concern based on initial screening in Table 3.13-4 through 3.13-10 of Baseline Ecological Risk Assessment, OU1-OU2 Rl. Average [arithmetic mean] calclated using one-half the detection limit for
non-detects. 95% UCL from Table 4.1-4 through 4.1-9. Landfill brook was not fully evaluated because the Rl determined that it was not impacted by contamination from the Site. Reference and HQ values from Table 4.3-4
through 4.3-9. HQ values above 1 are bold.
Source: A Guide to Preparing Superfund Proposed Plans, Records of Decision, and Other Remedy Selection Decision Documents (U.S. EPA, 1999)
Page 4 of 4
-------
ROD RISK WORKSHEET
Table G-Eco2
Occurrence, Distribution, and Selection of Sediment Contaminants of Concern
Exposure Medium: Sediment
Exposure Area
Chemical of Concern
Concentration Detected
(mg/kg)
Mean
(mg/kg)
95% UCL2
(mg/L)
Reference
(mg/kg)
Screening
Toxicity
Value
(mg/kg)
Screening
Toxicity Value
Source3
HQ Value4
Minimum
Maximum
Maximum
Average
RME
CTE
Upper South Ditch
Volatile Organics
Stream
2,4,4-Trimethyl-1-pentene
0.03
0.03
0.010
NC
NA
NA
NA
NA
NA
NA
2,4,4-T rimethyl-2-pentene
0.003
0.003
0.0031
NC
NA
NA
NA
NA
NA
NA
4-iso-Propyltoluene
0.0026
0.0026
0.0018
NC
NA
NA
NA
NA
NA
NA
Acetaldehyde
0.052
0.083
0.11
NC
NA
NA
NA
NA
NA
NA
Formaldehyde
0.27
1.09
0.57
NC
NA
NA
NA
NA
NA
NA
Semivolatile Organics
3 & 4 Methyl phenol
0,61
3
1.3
3.0
NA
NA
NA
NA
NA
NA
Acetophenone
0.09
0.09
0.43
NC
NA
NA
NA
NA
NA
NA
Benzaldehyde
0.2
0.62
0.35
NC
NA
NA
NA
NA
NA
NA
Caprolactam
0.053
0.053
0.10
NC
NA
NA
NA
NA
NA
NA
D
phenyl ether
0.17
0.22
0.15
NC
NA
NA
NA
NA
NA
NA
D
-n-octylphthalate
0.15
0.15
0.42
NC
NA
NA
NA
NA
D
phenylmethanone
0.0305
0.0305
0.098
NC
NA
NA
NA
NA
NA
NA
Phenol
0.22
0.96
0.72
0.96
NA
NA
0.42
EPA Region 3
2.3
1.7
Metals
Arsenic
2.1
13
5.3
10
NA
NA
9.79
TEC
0.30
0.16
Barium
7
86
27
70
NA
NA
NA
NA
NA
NA
Beryllium
0.21
1
0.44
0.71
NA
NA
NA
NA
NA
NA
Chromium
20
1,800
405
926
NA
NA
43,4
TEC
8.3
3.6
Chromium, Hexavalent
2.6
25
7.0
25
NA
NA
NA
NA
NA
NA
Iron
4,200
23,000
12,445
13,895
NA
NA
20,000
OMEE - LEL
0.35
0.31
Silver
1.6
35
7.5
19
NA
NA
2
EPA Region 4
9.5
3.7
Vanadium
5.4
18
10
15
NA
NA
NA
NA
NA
NA
inorganics
Chloride
41.5
140
74
NC
NA
NA
NA
NA
NA
NA
Nitrogen, as Ammonia
54
240
148
215
NA
NA
NA
NA
NA
NA
Sulfate
210
640
454
NC
NA
NA
NA
NA
NA
NA
Specialty Compounds
Hydrazine
0.00091
0.0013
0.0013
NC
NA
NA
NA
NA
NA
NA
Dimethylformamide
0.3
0.3
0.13
NC
NA
NA
NA
NA
NA
NA
Petroleum Hydrocarbons
C11-C22 Aromatics
11
1,100
288
NC
NA
NA
0,09
MassDEP
287
190
C19-C36 Aliphatics
14
690
194
NC
NA
NA
9,88
MassDEP
4.4
2.9
C9-C18 Aliphatics
96
96
26
NC
NA
NA
3,17
MassDEP
30
3.2
Page 1 of 7
-------
Table G-Eco2
Occurrence, Distribution, and Selection of Sediment Contaminants of Concern
Exposure Medium: Sediment
Exposure Area
Chemical of Concern
Concentration Detected
(mg/kg)
Mean
(mg/kg)
95% UCL2
(mg/L)
Reference
(mg/kg)
Screening
Toxicity
Value
(mg/kg)
Screening
Toxicity Value
Source3
HQ Value*
Minimum
Maximum
Maximum
Average
RIME
CTE
lower South Ditch
Volatile Organics
Stream
2.4,4-Trimethyl-1-pentene
0.0096
0.02
0.011
NC
NA
NA
NA
NA
NA
NA
2,4,4-T rimethyi-2-pentene
0.0035
0.0035
0.0037
NC
NA
NA
NA
NA
NA
NA
Acetaidehyde
0.063
0.063
0.11
NC
NA
NA
NA
NA
NA
NA
Acetone
0.12
0.12
0.168
NC
NA
NA
0.0091
ORNL-LCV
13.2
13.2
Formaldehyde
0.27
0.6
0.44
NC
NA
NA
NA
NA
NA
NA
Semivoiafile Organics
Aniline
0.23
0.23
3.7
NC
NA
NA
NA
NA
NA
NA
Benzaldehyde
0.12
0.12
0.99
NC
NA
NA
NA
NA
NA
NA
Bis(2-Ethylhexyl)phthalate
11
920
322
602
NA
NA
433
434
0.14
0.074
Di-n-octylphthalate
0.15
0.15
1.1
NC
NA
NA
NA
NA
NA
NA
Diphenyl ether
0.22
2.6
1.8
NC
NA
NA
NA
NA
NA
NA
Diphenylamine
0.095
0.095
0.062
NC
NA
NA
NA
NA
NA
NA
Pesticides
4,4-DDT
0,062
0.062
0,025
NC
NA
NA
0.00416
TEC
0.99
0.39
Hexachlorobenzene
0.037
0,037
0.016
NC
NA
NA
0.02
OMEE - LEI
0.15
0,07
Metals
Barium
7
23
12.8
17.4
NA
NA
NA
NA
NA
NA
Beryllium
0.64
1.9
0.96
1.5
NA
NA
NA
NA
NA
NA
Cadmium
0.32
1.2
0.56
1.0
NA
NA
0.99
TEC
0.21
0,11
Chromium
570
3,000
1,922
2,764
NA
NA
43.4
TEC
25
17.3
Chromium, Hexavalent
7.9
28
14.5
26
NA
NA
NA
NA
NA
NA
Mercury
0,045
0.39
0.18
0.29
NA
NA
0.18
TEC
0.27
0.17
Nickel
7.3
24
14.1
19.6
NA
NA
22.7
TEC
0.40
0.29
Silver
35
62
25
62
NA
NA
2
EPA Region 4
31
12.6
Tin
1.6
1.6
3.7
NC
NA
NA
NA
NA
NA
NA
Vanadium
5.4
14
8.7
11.1
NA
NA
NA
NA
NA
NA
Inorganics
Chloride
130
140
133
NC
NA
NA
NA
NA
NA
NA
Nitrogen, as Ammonia
54
290
172
252
NA
NA
NA
NA
NA
NA
Sulfate
600
830
690
NC
NA
NA
NA
NA
NA
NA
Petroleum Hydrocarbons
C11-C22 Aromatics
1100
9,400
5,250
NC
NA
NA
0.09
MassDEP
104,444
58,333
C19-C36 Aliphatics
690
6,400
3,545
NC
NA
NA
9.88
MassDEP
648
359
C9-C18 Aliphatics
96
770
433
NC
NA
NA
3.17
MassDEP
243
137
Specialty Compounds
Hydrazine
0.0013
0.0024
0.0019
NC
NA
NA
NA
NA
NA
NA
On-PWD
Volatile Organics
Stream/West Ditch
Acetone
0.095
0.34
7.6
0.45
NA
NA
0.0091
ORNL-LCV
37
37
Wetland
Benzene
4.4
4.4
0.93
NC
NA
NA
16
EPA NIO ESBs
0.037
0.0077
Metals
Barium
3.4
37.6
18.0
NC
NA
NA
NA
NA
NA
NA
Beryllium
0.61
0.61
0.25
NC
NA
NA
NA
NA
NA
NA
Cadmium
0.229
1.2
0.57
0.94
NA
NA
0.99
TEC
0.19
0.12
Chromium
4.5
69
24
30
NA
NA
43.4
TEC
0.27
0.22
Lead
4.6
110
50
76
NA
NA
35.8
TEC
0.59
0.39
Mercury
0.23
0.44
0.23
0.34
NA
NA
0.18
TEC
0,32
0.22
Vanadium
3
27
15.7
NC
NA
NA
NA
NA
NA
NA
Page 2 of 7
-------
Table G-Eco2
Occurrence, Distribution, and Selection of Sediment Contaminants of Concern
Exposure Medium: Sediment
Exposure Area
Chemical of Concern
Concentration Detected
(mg/kg)
Mean
(mg/kg)
95% UCL2
(mg/L)
Reference
(mg/kg)
Screening
Toxicity
Value
(mg/kg)
Screening
Toxicity Value
Source3
HQ Value*
Minimum
Maximum
Maximum
Average
RIME
CTE
Central Pond
Volatile Organics
2,4,4-Trimethyl-1-pentene
0.011
0.011
0.0068
NC
NA
NA
NA
NA
NA
NA
2,4,4-T rimethyl-2-pentene
0.0088
0.0088
0.0057
NC
NA
NA
NA
NA
NA
NA
Acetone
0.11
0.12
0.12
NC
NA
NA
0.0091
ORNL-LCV
13.2
12.6
Methyl Tertbutyl Ether
0.0017
0.0017
0.0016
NC
NA
NA
NA
NA
NA
NA
Semivolatile Organics
3&4 Methyl phenol
4.3
6.1
5.2
NC
NA
NA
NA
NA
NA
NA
Acetophenone
0.15
0.26
0.21
NC
NA
NA
NA
NA
NA
NA
Benzaldehyde
1.4
1.9
1.7
NC
NA
NA
NA
NA
NA
NA
Phenol
1.7
2.2
2.0
NC
NA
NA
0.42
EPA Region 3
5.2
4.6
PoSyaromatic Hydrocarbons
Benzo(b)fluoranthene
0.14
0.14
0.19
NC
NA
NA
979
EPA PAH ESBs
NA
NA
Fluoranthene
0.21
0.29
0.25
NC
NA
NA
707
EPA PAH ESBs
0.13
0.11
Phenanthrene
0.21
0.21
0.22
NC
NA
NA
596
EPA PAH ESBs
0.18
0.18
Pyrene
0.18
0,23
0.21
NC
NA
NA
697
EPA PAH ESBs
0,15
0.13
Metals
Barium
45
46
46
NC
NA
NA
NA
NA
NA
NA
Beryllium
0.09
0.094
0.092
NC
NA
NA
NA
NA
NA
NA
Chromium
18
140
36
95
NA
NA
43,4
TEC
1.3
0.35
Chromium, Hexavalent
0.21
0.27
0,24
NC
NA
NA
NA
NA
NA
NA
Lead
50
51
51
NC
NA
NA
35,8
TEC
0,40
0.39
Manganese
440
590
515
NC
NA
NA
460
OMEE - LEL
0,54
0.47
Tin
2.1
2,2
2,2
NC
NA
NA
NA
NA
NA
NA
Vanadium
16
17
16.5
NC
NA
NA
NA
NA
NA
NA
inorganics
Chloride
18
24
21
NC
NA
NA
NA
NA
NA
NA
Nitrogen, as Ammonia
17
35
26
NC
NA
NA
NA
NA
NA
NA
Sulfate
510
1,200
855
NC
NA
NA
NA
NA
NA
NA
Page 3 of 7
-------
Table G-Eco2
Occurrence, Distribution, and Selection of Sediment Contaminants of Concern
Exposure Medium: Sediment
Exposure Area
Chemical of Concern
Concentration Detected
(mg/kg)
Mean
(mg/kg)
95% UCL2
(mg/L)
Reference
(mg/kg)
Screening
Toxicity
Value
(mg/kg)
Screening
Toxicity Value
Source3
HQ Value*
Minimum
Maximum
Maximum
Average
RIME
CTE
Storm Water
Volatile Organics
Detention Basin
2,4,4-T rimethy!-1-pentene
0.0024
0.0078
0.0051
NC
NA
NA
NA
NA
NA
NA
2,4,4-T rimethyl-2-pentene
0.0014
0.0039
0.0027
NC
NA
NA
NA
NA
NA
NA
Acetone
0.13
0.15
0.14
NC
NA
NA
0.0091
ORNL-LCV
16.5
15.4
Semivolatile Organics
3 &4 Methyl phenol
1.8
4
2.9
NC
NA
NA
NA
NA
NA
NA
Acetophenone
0.16
0.16
0.23
NC
NA
NA
NA
NA
NA
NA
Benzaldehyde
0.62
1.3
0.96
NC
NA
NA
NA
NA
NA
NA
Phenol
1.4
1.9
1.7
NC
NA
NA
0.42
EPA Region 3
4.5
3.9
Polyaromatic Hydrocarbons
Benzo(a)pyrene
0.22
0.22
0.24
NC
NA
NA
965
EPA PAH ESBs
0.15
0.15
Metals
Arsenic
9.4
12
10.7
NC
NA
NA
9.79
TEC
0.36
0.32
Barium
48
51
50
NC
NA
NA
NA
NA
NA
NA
Beryllium
0.089
0.12
0.10
NC
NA
NA
NA
NA
NA
NA
Chromium
33
50
42
NC
NA
NA
43.4
TEC
0,45
0.37
Tin
2.2
2.3
2.3
NC
NA
NA
NA
NA
NA
NA
Vanadium
19
22
21
NC
NA
NA
NA
NA
NA
NA
Inorganics
Chloride
6.3
13
9.7
NC
NA
NA
NA
NA
NA
NA
Nitrogen, as Ammonia
14
22
18.0
NC
NA
NA
NA
NA
NA
NA
Sulfate
900
1,900
1,400
NC
NA
NA
NA
NA
NA
NA
Off-PWD Stream
Volatile Organics
2,4,4-T rimethyl-1-pentene
0.06
0.06
0.023
NC
NA
NA
NA
NA
NA
NA
2,4,4-T rimethyl-2-pentene
0.008
0.008
0.0060
NC
NA
NA
NA
NA
NA
NA
Formaldehyde
0.4
0.61
0.51
NC
NA
NA
NA
NA
NA
NA
Semivolatile Organics
4-Chlorophenyl phenyl ether
0.061
0.061
0.044
NC
NA
NA
NA
NA
NA
NA
Carbazole
0.039
0.051
0.045
NC
NA
NA
NA
NA
NA
NA
Diphenyl ether
Q.094
0.86
0.33
NC
NA
NA
NA
NA
NA
NA
Diphenylmethanone
0.028
0.2
0.091
NC
NA
NA
NA
NA
NA
NA
Metals
Arsenic
6.7
14
10.0
NC
NA
NA
9.79
TEC
0.42
0.30
Barium
9.1
16
11.7
NC
NA
NA
NA
NA
NA
NA
Beryllium
1.1
1,4
1.2
NC
NA
NA
NA
NA
NA
NA
Chromium
250
2,400
1,350
NC
NA
NA
43.4
TEC
22
12.2
Copper
16
39
25
NC
NA
NA
31.6
TEC
0.26
0.17
Silver
3.7
41
23.6
NC
NA
NA
2
EPA Region 4
20.5
11.8
Vanadium
9.2
15
11.7
NC
NA
NA
NA
NA
NA
NA
Inorganics
Chloride
91
240
147
NC
NA
NA
NA
NA
NA
NA
Nitrogen, as Ammonia
93
540
254
NC
NA
NA
NA
NA
NA
NA
Sulfate
280
1500
697
NC
NA
NA
NA
NA
NA
NA
Specialty Compounds
Hydrazine
0.0013
0.0013
0.0017
NC
NA
NA
NA
NA
NA
NA
Page 4 of 7
-------
Table G-Eco2
Occurrence, Distribution, and Selection of Sediment Contaminants of Concern
Exposure Medium: Sediment
Exposure Area
Chemical of Concern
Concentration Detected
(mg/kg)
Mean
(mg/kg)
95% UCL2
(mg/L)
Reference
(mg/kg)
Screening
Toxicity
Value
(mg/kg)
Screening
Toxicity Value
Source3
HQ Value*
Minimum
Maximum
Maximum
Average
RIME
CTE
MMB Wetland
Volatile Organics
Acetaldehyde
0.22
0.42
0.35
0.33
ND
ND
NA
NA
NA
NA
Acetone
0.035
1.7
0.72
0.96
2.0
2.0
0.0091
ORNL-LCV
106
79
Formaldehyde
0.31
4
2.2
2.8
ND
ND
NA
NA
NA
NA
Semivolatile Organics
3 &4 Methyl phenol
0.2
0.32
0.12
0.32
ND
0.12
NA
NA
NA
NA
4-Nitrophenol
0.091
0.091
0.43
NC
ND
0.55
NA
NA
NA
NA
Benzaldehyde
0.056
0.3
0.12
0.20
0.33
0.33
NA
NA
NA
NA
Benzoic Acid
0.21
1.4
0.59
0.76
0.54
0.54
0.65
EPA Region 3
1.2
0.90
Benzyl alcohoi
0.35
0.35
0.20
NC
ND
0.23
0.073
ORNL - LCV
4.8
2.7
Caprolactam
0.088
0.088
0.068
0.20
ND
ND
NA
NA
NA
NA
Carbazole
0.025
0.097
0.093
0.097
ND
0.12
NA
NA
NA
NA
Metals
Aluminum
5,400
28,000
12,969
17,498
5,500
5,500
25,500
ARCS-TEC
0.30
0.22
Arsenic
3.5
52
17.2
26
6.6
6.6
9,79
EPA Region 4
0.79
0.52
Barium
22
190
103
131
84
84
NA
NA
NA
NA
Beryllium
0.17
2.6
0.98
1.4
0.7
0,7
NA
NA
NA
NA
Cadmium
0.082
4.8
2.1
2.9
0.9
0.9
0.99
TEC
0.59
0.41
Copper
7.4
90
39
53
15
15
31.6
TEC
0.36
0.26
Iron
6,400
95,000
25,508
38,554
7,500
7,500
20,000
OMEE - LEL
0.96
0,64
Lead
7.2
415
138
204
46
46
35.8
TEC
1.6
1.1
Manganese
110
2,100
788
1,267
500
500
460
OMEE - LEL
1.2
0,72
Mercury
0.22
0.51
0.26
0.41
ND
ND
0.18
TEC
0.39
0.24
Nickel
5.4
44
18.6
25
6.1
6.1
22.7
TEC
0.51
0.38
Thallium
1.4
1.4
2.6
NC
ND
ND
NA
NA
NA
NA
Tin
7-1
16
8.6
10.1
7.3
7.3
NA
NA
NA
NA
Vanadium
8.9
58
32
41
11
11
NA
NA
NA
NA
Zinc
22
500
207
288
73
73
121
TEC
0.63
0.45
inorganics
Chloride
34
1,000
485
658
420
420
NA
NA
NA
NA
Nitrogen, as Ammonia
62
1,500
567
771
830
830
NA
NA
NA
NA
Sulfate
120
1,400
600
834
420
420
NA
NA
NA
NA
Page 5 of 7
-------
Table G-Eco2
Occurrence, Distribution, and Selection of Sediment Contaminants of Concern
Exposure Medium: Sediment
Exposure Area
Chemical of Concern
Concentration Detected
(mg/kg)
Mean
(mg/kg)
95% UCL2
(mg/L)
Reference
(mg/kg)
Screening
Toxicity
Value
(mg/kg)
Screening
Toxicity Value
Source3
HQ Value*
Minimum
Maximum
Maximum
Average
RIME
CTE
North Pond
Volatile Organics
2,4,4-T rimethy!-1-pentene
0.002
0.002
0.0038
NC
NA
NA
NA
NA
NA
NA
Acetone
0.12
0.33
0.21
NC
NA
NA
0.0091
ORNL-LCV
36
23
Carbon disulfide
0.0073
0.0073
0.0036
NC
NA
NA
0.001
EPA Region 3
NA
NA
Semivolatile Organics
Carbazole
0.16
0.16
0.34
NC
NA
NA
NA
NA
NA
NA
Metals
Arsenic
5.05
13
8.3
NC
NA
NA
9.79
EPA Region 4
0.39
0.25
Barium
28
62
41
NC
NA
NA
NA
NA
NA
NA
Beryllium
0.37
0.53
0.48
NC
NA
NA
NA
NA
NA
NA
Cadmium
0.25
2.2
1.4
NC
NA
NA
0.99
TEC
0.44
0.28
Chromium
20
780
278
NC
NA
NA
43.4
TEC
7.0
2.5
Chromium, Hexavalent
0.285
0.9
0.59
NC
NA
NA
NA
NA
NA
NA
Copper
11.55
68
45
NC
NA
NA
31.6
TEC
0.46
0.30
Iron
9,000
23,000
15,500
NC
NA
NA
20,000
OMEE - LEI
0.58
0.39
Lead
31
110
69
NC
NA
NA
35.8
TEC
0.86
0.54
Manganese
120
1250
420
NC
NA
NA
460
OMEE - LEL
1.1
0.38
Thallium
0.82
0,82
0.76
NC
NA
NA
NA
NA
NA
NA
Tin
0.7
11
5.9
NC
NA
NA
NA
NA
NA
NA
Vanadium
17
26
23
NC
NA
NA
NA
NA
NA
NA
Zinc
110
360
288
NC
NA
NA
121
TEC
0,78
0.63
Inorganics
Chloride
55.5
320
184
NC
NA
NA
NA
NA
NA
NA
Nitrogen, as Ammonia
3.2
23
12
NC
NA
NA
NA
NA
NA
NA
Sulfate
200
270
183
NC
NA
NA
NA
NA
NA
NA
Page 6 of 7
-------
Table G-Eco2
Occurrence, Distribution, and Selection of Sediment Contaminants of Concern
Exposure Medium: Sediment
Exposure Area
Chemical of Concern
Concentration Detected
(mg/kg)
Minimum Maximum
Mean
(mg/kg)
95% liCL2
(mg/L)
Reference
(mg/kg)
Maximum Average
Screening
Toxicity
Value
(mg/kg)
Screening
Toxicity Value
Source3
HQ Value
RME
CTE
Key
Mg/L - microgram per titer
NA-Not Applicable
NC - Not Calculated - dataset too small to calculate or only one detection
ND - Not Detected
PWD - Property West Ditch
Minimum/maximum/mean detected concentration above the sample quantitation limit
The 95% Upper Confidence Limit (UCl) represents the RME concentration
Sediment Screening benchmark sources in order of preference:
1. EPA PAH ESBs - Equilibrium Sediment Partitioning Benchmarks for PAHs (COC,PAHi,FCVi) (EPA, 2003)
2. EPA NiO ESBs - Equilibrium Sediment Partitioning Benchmarks for Nonionic Organics Freshwater Conventional ESBs (EPA, 2008)
3. TECs - Threshold Effects Concentrations (MacDonald, et al., 2000).
4. EPA Region 4 (EPA, 2001)
5. OEMEE LELEs - Ontario Ministry of Energy and Environment Low-Effect Levels (Persaud et al., 1993)
6. ARCs TECs - Assessment and Remediation of Contaminated Sediments Program Threshold Effects Concentrations (EPA, 1996).
7. EPA Region 3 (EPA, 2006)
8. ORNL - LCVs - Oak Ridge National Laboratory Lowest Chronic Values (Jones, Suter, and Hull, 1997).
9. MassDEP - Sediment Benchmarks for Current MassDEP Petroleum Hydrocarbon Fractions (MassDEP, 2007).
10. REACH (Registration, Evaluation, Authorisation and Restriction of Chemicals) database. Values selected are No Observed Effects Concentrations for aquatic invertebrates
HQ (Hazard Quotient) calculated by dividing the exposure point concentration by the effects benchmark.
[b] Value is for 1,2-Dichloroethene.
[c] Calcium, magnesium, potassium, and sodium are considered essential nutrients; therefore benchmarks are not applicable.
Sediment chemicals of concern based on initial screening in Table 3.13-11 through 3.13-19 of Baseline Ecological Risk Assessment, OU1-OU2 Rl. Average [arithmetic mean] calculated using one-half the detection limit for non-
detects. 95% UCL from Table 4.1-10 through 4.1-17. Landfill brook was not fully evaluated because the Rl determined that it was not impacted by contamination from the Site. Reference and HQ vaiuesfrom Table 4.3-10
through 4.3-17. HQ values above 1 are bold.
Source: A Guide to Preparing Superfund Proposed Plans, Records of Decision, and Other Remedy Selection Decision Documents (U.S. EPA, 1999)
Page 7 of 7
-------
ROD RISK WORKSHEET
Table G-Eco3
Occurrence, Distribution, and Selection of Soil Contaminants of Concern
Exposure Medium: Soil
Exposure Area
Chemical of Potential
Ecological Concern
Concentration Detected
(mg/kg)1
Mean
(mg/kg)
95% UCL
(mg/L)
Background
(mg/kg)
Screening
Toxicity Value
(mg/kg)
Screening
Toxicity Value
Source3
HQ Value4
Minimum
Maximum
RME
CTE
RME
CTE
EA2
Volatile Organics
Acetaldehyde
0.044
0.2
0.26
NC
ND
ND
NA
NA
NA
NA
Semivolatile Organics
Benzaidehyde
0.086
1.9
2.2
0.79
0.098
0.063
NA
NA
NA
NA
Benzo{a)pyrene
0.021
0.24
0.25
0.15
0.022
0.019
0.1
EPA Region 4
0.009
0.015
Bis(2-Ethylhexyl)phthalate
0.022
340
22
110
0.031
0.019
0.925
REACH
0.85
0.17
Diphenyl ether
0.12
0.12
2.1
NC
ND
ND
NA
NA
NA
NA
Fluoranthene
0.037
0.94
1.7
0.40
0.043
0.026
0.1
EPA Region 4
0.023
0.054
Phenanthrene
0.026
0.68
1.8
0.27
0.035
0.022
0.1
EPA Region 4
0.015
0.038
Pyrene
0.042
0.66
1.7
0.31
0.049
0.028
0.1
EPA Region 4
0.018
0.038
Pesticides
4,4'-DDD
0.039
0.039
0.056
NC
NA
NA
0.0025
EPA Region 4
0.002
0.002
4,4'-DDE
0.049
0.049
0.059
NC
NA
NA
0.0025
EPA Region 4
0.002
0.002
4,4'-DDT
0.68
0.68
0.27
NC
NA
NA
0.021
Eco-SSL - Mammals
0.035
0.014
Metals
Aluminum
1,200
24,000
8,715
13,090
13,000
7,378
50
ORNL - Plants
1.8
27
Arsenic
1.7
15
6.7
8.8
10
5.0
10
ORNL - Plants
0.49
0.37
Cadmium
0.14
1.1
0.51
0.69
0.26
0.15
0.36
Eco-SSL - Mammals
0.022
0.016
Chromium
10
275
39
116
10
6.2
0.4
ORNL - Invertebrates
0.37
0.13
Copper
5.2
35
17.9
22
5.8
4.1
28
Eco-SSL-Mammals
0.32
0.26
Iron
710
36,000
10,908
22,493
12,000
6,314
200
EPA Region 4
NA
NA
Lead
3.85
80
40
53
26
15.6
11
Eco-SSL - Birds
0.44
0.33
Mercury
0.01
0.35
0.15
0.16
0.11
0.077
0.1
ORNL - Invertebrates
1.6
1.5
Selenium
0.93
3.6
1.1
2.4
0.60
0.41
0.52
Eco-SSL - Plants
4.6
2.1
Vanadium
14
44
24
29
21
11.9
2
ORNL - Plants
14.7
11.8
Zinc
6.7
140
49
70
18
8.5
46
Eco-SSL - Birds
0.58
0.41
Inorganics
Chloride
25.85
550
79
242
ND
ND
8.7
ECOSAR-CSV
2.8
0.90
Nitrogen, as Ammonia
23
1,200
439
625
200
128
NA
NA
NA
NA
Page 1 of 4
-------
Table G-Eco3
Occurrence, Distribution, and Selection of Soil Contaminants of Concern
Exposure Medium: Soil
Exposure Area
Chemical of Potential
Ecological Concern
Concentration Detected
(mg/kg)1
Mean
(mg/kg)
95% UCL
(mg/L)
Background
(mg/kg)
Screening
Toxicity Value
(mg/kg)
Screening
Toxicity Value
Source3
HQ Value4
Minimum
Maximum
RME
CTE
RME
CTE
EA4
Volatile Organics
Acetaldehyde
0.046
0.046
0.12
NC
ND
ND
NA
NA
NA
NA
Semivolatile Organics
Benzaldehyde
0.012
1.2
0.24
0.61
0.098
0.063
NA
NA
NA
NA
Benzo(a)pyrene
0.011
3.4
0.33
0.35
0.022
0.019
0.1
EPA Region 4
0.021
0.020
Bis{2-Ethylhexyl)phthalate
0.014
200
9.0
30
0.031
0.019
0.925
REACH
0.23
0.069
Fluoranthene
0.011
1.9
0.85
0.41
0.043
0.026
0.1
EPA Region 4
0.023
0.049
Naphthalene
0.008
0.21
0.82
0.065
ND
ND
0.0994
EPA Region 5
0.004
0.012
Phenanthrene
0.012
0.69
0.78
0.14
0.035
0.022
0.1
EPA Region 4
0.008
0.039
Pyrene
0.013
1.3
0.82
0.22
0.049
0.028
0.1
EPA Region 4
0.013
0.047
Pesticides
4,4'-DDD
0.00012
0.16
0.021
0.016
NA
NA
0.0025
EPA Region 4
0.0008
0.0011
4,4'~DDE
0.00053
0.011
0.017
0.0038
NA
NA
0.0025
EPA Region 4
0.0002
0.0005
4,4'-DDT
0.0014
0.15
0.025
0.068
NA
NA
0.021
Eco-SSL - Mammals
0.0035
0.0013
Alpha-BHC
0.0002
0.0058
0.015
0.0020
NA
NA
0.0025
EPA Region 4
0.00007
0.0002
Gamma-BHC/Lindane
0.00011
0.13
0.019
0.012
NA
NA
0.00005
EPA Region 4
2.5
3.9
Metals
Aluminum
640
59,000
7,016
8,804
13,000
7,378
50
ORNL - Plants
176
140
Arsenic
2
32
7.6
9.1
10.0
5.0
10
ORNL - Plants
0.51
0.42
Cadmium
0.026
5.8
0.42
0.48
0.26
0.15
0.36
Eco-SSL - Mammals
0.015
0.013
Chromium
1.1
5,000
272
583
10.0
6.2
0.4
ORNL - Invertebrates
1.9
0.88
Chromium, Hexavalent
8.9
95
11
38
NA
NA
81
Eco-SSL - Mammals
NA
NA
Cobalt
0.16
45.5
5.0
16.2
2.9
1.6
13
Eco-SSL - Plants
1.2
0.39
Copper
0.94
79.5
14
27
5.8
4.1
28
Eco-SSL - Birds
0.39
0.20
Iron
81
100,000
8,973
19,245
12,000
6,314
200
EPA Region 4
NA
NA
Lead
1.5
210
24
43
26
15.6
11
Eco-SSL - Birds
0.36
0.20
Manganese
2.8
1035
84
171
69
28
220
ECO-SSL- Plants
0.78
0.38
Mercury
0.034
0.49
0.12
0.14
0.11
0.077
0.1
ORNL - Invertebrates
1.4
1.2
Nickei
0.66
67
10
25
7.3
4.0
30
ORNL ~ Plants
0.66
0.27
Vanadium
4.1
54
17
20
21
11.9
2
ORNL - Plants
10.2
8.4
Zinc
1.2
180
23
48
18
8.5
46
Eco-SSL - Birds
0.40
0.19
Inorganics
Chloride
26.3
560
54
119
NA
NA
8.7
ECOSAR-CSV
1.4
0.62
Cyanide, Total
3.7
9.05
5.8
7.9
NA
NA
0.9
EPA Region 4
0.088
0.065
Nitrogen, as Ammonia
27
1,800
262
356
200
128
NA
NA
NA
NA
Sulfate
13.4
23,900
1,095
10,004
63
28
46
ECOSAR-CSV
22
2.4
Petroleum Hydrocarbons
C11-C22 Aromatics
6.8
130
32
56
NA
NA
NA
NA
NA
NA
C19-C36 Aliphatics
5.9
190
42
81
NA
NA
NA
NA
NA
NA
C9-C18 Aliphatics
6.7
17
6.5
16.3
NA
NA
NA
NA
NA
NA
Page 2 of 4
-------
Table G-Eco3
Occurrence, Distribution, and Selection of Soil Contaminants of Concern
Exposure Medium: Soil
Exposure Area
Chemical of Potential
Ecological Concern
Concentration Detected
(mg/kg)1
Mean
(mg/kg)
95% UCL
(mg/L)
Background
(mg/kg)
Screening
Toxicity Value
(mg/kg)
Screening
Toxicity Value
Source3
HQ Value4
Minimum
Maximum
RUE
CTE
RME
CTE
EA5
Volatile Organics
Acetaldehyde
0.048
0.13
0.082
NC
NA
NA
NA
NA
NA
NA
Semivolatile Organics
Aniline
0.12
0.12
12.7
NC
NA
NA
NA
NA
NA
NA
Benzaldehyde
0.029
0.33
0.12
0.21
NA
NA
NA
NA
NA
NA
Benzo{a)pyrene
0.014
0.44
0.072
0.15
NA
16.4
0.1
EPA Region 4
0.0092
0.004399407
Bis(2-Ethylhexyl)phthalate
0.026
216
31
103
130
130
0.925
REACH
0.80
0.24
Diphenyl ether
1.6
1.9
0.37
1.9
NA
NA
NA
NA
NA
NA
Fluoranthene
0.018
2.6
0.44
2.5
NA
17.5
0.1
EPA Region 4
0.14
0.025
N-Nitrosodi-n-propylamine
0.26
0.26
2.5
NC
NA
NA
NA
NA
NA
NA
Phenanthrene
0.023
0.41
0.26
0.15
NA
17.7
0.1
EPA Region 4
0.0082
0.015
Pyrene
0.024
0.79
0.28
0.56
NA
17.5
0.1
EPA Region 4
0.032
0.016
Pesticides
4,4'-DDT
0.045
0.045
0.045
NC
NA
19.6
0.021
Eco-SSL - Mammals
0.0023
0.0023
Hexachlorobenzene
0.029
0.029
0.029
NC
NA
19.7
0.0025
EPA Region 4
0.0015
0.0015
Metals
Aluminum
2,500
43,000
10,789
20,005
50
NA
50
ORNL - Plants
400
216
Antimony
0.29
0.34
0.88
0.36
5.0
78
0.27
Eco-SSL - Mammals
0.068
0.068
Arsenic
4.5
42
19.4
27
18
60
10
ORNL - Plants
1.5
1.1
Cadmium
0.093
0.52
0.65
0.42
32
140
0.36
Eco-SSL - Mammals
0.013
0.016
Chromium
7.2
62,000
6,648
26,344
310
310
0.4
ORNL - Invertebrates
85
21
Chromium, Hexavalent
19
1,100
79
559
NA
NA
81
Eco-SSL - Mammals
NA
NA
Copper
3.8
190
38
97
70
80
28
Eco-SSL - Birds
1.4
0.55
Iron
3,700
31,000
14,067
20,139
NA
NA
200
USEPA Region 4
NA
NA
Lead
27
150
71
93
120
1,700
11
Eco-SSL - Birds
0.78
0.59
Mercury
0.047
3.1
0.64
1.9
0.3
0.1
0.1
ORNL - Invertebrates
19.3
6.4
Silver
10
1,100
103
1,439
560
NA
2
ORNL - Plants
2.0
0.18
Thallium
7.4
7.4
1.9
NC
1.0
NA
1
ORNL - Plants
7.4
1.9
Tin
4.5
26,000
2924
31,853
50
NA
50
ORNL ~ Plants
520
58
Vanadium
12
150
39
69
2.0
NA
2
ORNL - Plants
35
19.5
Zinc
3.4
47
17.0
31
160
120
46
Eco-SSL - Birds
0.26
0.14
Inorganics
Cyanide, Total
6.5
6.5
6.5
NC
NA
89
0.9
USEPA Region 4
0.073
0.073
Nitrogen, as Ammonia
150
1,100
406
749
NA
NA
NA
NA
NA
NA
Sulfate
120
230
74
230
NA
465
46
ECOSAR-CSV
0.49
0.16
Petroleum Hydrocarbons
C11-C22 Aromatics
1,400
7,500
4450
NC
NA
11.616
NA
NA
646
383
C19-C36 Aliphatics
1,800
4,900
3350
NC
NA
NA
NA
NA
NA
NA
C9-C18 Aliphatics
200
780
490
NC
NA
NA
NA
NA
NA
NA
Page 3 of 4
-------
Table G-Eco3
Occurrence, Distribution, and Selection of Soil Contaminants of Concern
Exposure Medium: Soil
Exposure Area
Chemical of Potential
Ecological Concern
Concentration Detected
(mg/kg)1
Minimum Maximum
Mean
(mg/kg)
95% UCL
(mg/L)
Background
(mg/kg)
RME
CTE
Screening
Toxicity Value
(mg/kg)
Screening
Toxicity Value
Source3
HQ Value4
RME
CTE
Key
CTE = central tendency exposure
EA = exposure area
Mg/L - microgram per liter
NA = Not Applicable
NC = Not Calculated - dataset too small to calculate or only one detection
RME = reasonable maximum exposure
Minimum/maximum/mean detected concentration above the sample quantitation limit
Soil Screening benchmark sources in order of preference:
1. Lowest value in these sources
Eco-SSLs - Ecological Soil Screening Levels, EPA, 2013
ORNL - Invertebrates - Oak Ridge National Laboratory (Efroymson, Will, & Suter, 1997)
ORNL - Plants (Efroymson, et al., 1897)
2. Lowest value in these sources
EPA Region 4 (from EPA, 2001)
EPA Region 5 (EPA, 2003)
3. Estimated benchmarks using EPA, 2012 Ecological Structure Activity Relationships (ECOSTAR) Database v. 1.11 using 14 day LC50s for earthworms and factors of 10 for non-persistent chemicals, 20 for
persistnent non-bioaccumulating chemicals, and 100 for persistent and bioaccumuiating chemicals to convert to NOAELs.
4. In lieu of other benchmarks, the benchmark for formaldehyde was selected from Sample et al., 1996 value for shrew.
5. REACH (Registration, Evaluation, Authorisation and Restriction of Chemicals) database. Values selected are No Observed Effects Concentrations for invertebrates
6. Chlordane (technical) used as a surrogagte for alpha-chlordane
7. Calcium, magnesium, potassium and sodium considered essential nutrients; benchmarks are not applicable
HQ (Hazard Quotient) calculated by dividing the exposure point concentration by the effects benchmark.
Soil chemicals of concern based on initial screening in Table 3.13-1 through 3.13-3 of Baseline Ecological Risk Assessment, OU1-OU2 Rl. 95% UCL from Table 4.1-1 through 4.1-3. Screening benchmarks from table 3.12-1.
Background and HQ values from Table 4.3-1 through 4.3-3. HQ based on largest value for plants and invertebrates; HQ values above 1 are bold.
Source: A Guide to Preparing Superfund Proposed Plans, Records of Decision, and Other Remedy Selection Decision Documents (U.S. EPA, 1999)
Page 4 of 4
-------
ROD RISK WORKSHEET
Table G-Eco4
Ecological Exposure Pathways and End points
Exposure
Media
Sensitive
Environment
Flag
(Yor N)
Receptor
Exposure Routes
Assessment
Endpoints
Measurement Endpoints
Terrestrial
Exposure Areas:
EA2, EA4 and EA5
(Soil)
N
Terrestrial Plants
Soil
Sustainability of terrestrial
plant community
Compare bulk soil concentrations to soil effects benchmarks and
reference area conditions
N
Soil Invertebrates
Soil
Sustainability of soil
invertebrate community
Compare bulk soil concentrations to soil effects benchmarks and
reference area conditions
N
Terrestrial Birds - American
Robin
Soil, Plants, Prey
Sustainability of invertivorous
bird populations
Compare estimated daily does based on prey and soil ingestion to
published avian TRVs and reference area conditions
N
Terrestrial Birds - Red-Tailed
Hawk
Soil, Prey
Sustainability of bird of prey
populations
Compare estimated daily does based on prey and soil ingestion to
published avian TRVs and reference area conditions
N
Terrestrial Mammals - Short-
Tailed Shrew
Soil, Plants, Prey
Sustainability of ominvorous
small mammal populations
Compare estimated daily does based on prey and soil ingestion to
published mammalian TRVs and reference area conditions
N
Terrestrial Mammals - Red
Fox
Soil, Prey
Sustainability of carnivorous
mammal populations
Compare estimated daily does based on prey and soil ingestion to
published mammalian TRVs and reference area conditions
Aquatic Exposure
Areas: Central
Pond, Storm Water
Detention Basin,
On-PWD Stream/
Wetland, Off-PWD
Stream, MMB
Wetland, Lanfill
Brook, North Pond
Y
Benthic Macroinvertebrates
Surface Water,
Sediment
Sustainability of benthic
invertebrate community
Compare sediment/surface water concentrations to effects
benchmarks. Compare sediment toxicity test results for South Ditch
to reference samples.
Y
Amphibians
Surface Water,
Sediment
Sustainability of amphibian
populations
Compare sediment/surface water concentrations to effects
benchmarks.
Y
Semi-Aquatic Birds - Marsh
Wren
Surface Water,
Sediment, Prey
Sustainability of semi-aquatic
bird populations
Compare estimated daily doses based on ingestion of prey,
sediment and surface water to published avian TRVs.
Y
Semi-Aquatic Birds - Green
Heron
Surface Water,
Sediment, Prey
Sustainability of semi-aquatic
bird populations
Compare estimated daily doses based on ingestion of prey,
sediment and surface water to published avian TRVs.
Y
Semi-Aquatic Mammals -
Muskrat
Surface Water,
Sediment, Plants
Sustainability of semi-aquatic
mamma! populations
Compare estimated daily doses based on ingestion of plants,
sediment and surface water to published mammalian TRVs.
Y
Semi-Aquatic Mammals -
Raccoon
Surface Water,
Sediment, Prey
Sustainability of semi-aquatic
mamma! populations
Compare estimated daily doses based on ingestion of prey,
sediment and surface water to published mammalian TRVs.
Key
NA = Not Applicable
MMB - Maple Meadow Brook
PWD = Property West Ditch
TRV = Toxicity Reference Value
Note: no endangered or threatened species have been identified at the Site. Assessment endpoints described on page 3-13 and 3-14 of OU1/OU2 BERA.
Source: A Guide to Preparing Superfund Proposed Plans, Records of Decision, and Other Remedy Selection Decision Documents (U.S. EPA, 1999)
Page 1 of 1
-------
ROD RISK WORKSHEET
Table G-Eco5
Target Contaminant of Concern Concentrations for Protection of Ecological Receptors
Habitat Type/
Name
Exposure
Medium
coc
Protective Level
Units
Basis
Assessment
Endpoint
Upland
(Terrestrial)
Upland Soil
Bis(2-ethylhexyl)phthalate
3
mg/kg
A
invertivorous birds and
omnivorous small
mammals
Chromium
1,000
mg/kg
B
Wetland
Wetland Soil
Bis(2-ethylhexyl)phthalate
20
mg/kg
C
Sustainability of semi-
aquatic birds
Chromium
600
mg/kg
D
Surface Water
Bodies
Streambank Soil and
Bis(2-ethylhexyl)phthalate
100
mg/kg
E
Sustainability of semi-
aquatic birds
Aquatic Sediment
Chromium
100
mg/kg
F
Surface Water
Chromium
0.1
mg/L
G
Sustainability of aquatic life
based on ambient water
quality criteria
Ammonia
15
mg/L
H
K
cc
Ct
m
kg
L
N
P
A
B
C
D
E
F
G
H
ey
c - criterion continuous concentration
X - chemical of concern
g-milligram
- kilogram
liter
DAEL - lowest adverse effects level
OAEL - no observed adverse effects level
RG - preliminary remediation goal
Geometric mean of NOAEL-PRG & LOAEL-PRG for American robin (most sensitive receptor) at EA-5.
Geometric mean of NOAEL-PRG & LOAEL-PRG for American robin (most sensitive receptor) at EA-5, rounded down to 1000 mg/kg
Geometric mean of NOAEL-PRG & LOAEL-PRG for marsh wren at Lower South Ditch (21 mg/kg rounded to 20 mg/kg); applicable to all wetland soil
Geometric mean of NOAEL-PRG & LOAEL-PRG for marsh wren at Off-Property West Ditch Stream (641 mg/kg rounded to 600 mg/kg); applicable to all wetland soil
Conclusion from REACH dossier (https://echa.europa.eu/registration-dossier/-/registered dossier/15358/6/1)
Probable Effect Concentration (110 mg/kg) and conclusion from REACH dossier (100 mg/kg) rounded to 100 mg/kg
Arithmetic mean of hardness-adjusted CCC at seven water bodies at Site (Table 3.12-3 of BERA [AMEC, 2015c]), rounded to 0.1
CCC for Site-specific pH and temperature during Spring months at East Ditch, applied to all surface water at Site
Source: A Guide to Preparing Superfund Proposed Plans, Records of Decision, and Other Remedy Selection Decision Documents (U.S. EPA, 1
Page 1 of 1
-------
Table K-1
Comparative Analysis of Remedial Alternatives
ALTERNATIVES BY MEDIUM
Overall Protection
of Human Health
and the
Environment
Compliance with
ARARs
Long-Term
Effectiveness and
Permanence
Reduction of
Toxicity, Mobility,
or Volume Through
Treatment
Short-Term
Effectiveness
Implementability
Costs'
Capital Cost
O&M Cost
Total (Net
Present Value)
OAPL/Groundwater Interim Action
Alternative DAPL/GWHS-1: No action
X
X
N/A
N/A
SO
SO
so
Alternative DAPL/GWHS-2: DAPL extraction (approx. Swells), groundwater hot spot extraction
targeting 11,000 ng/L (approx. 2-3 wells), on-site treatment at new treatment system
v'
V
.
+
+
+
$10,253,755
$21,701,568
$22,518,229
Alternative DAPL/GWHS-3: DAPL extraction (approx. 20 wells), groundwater hot spot extraction
targeting 5,000 ng/L (approx 6 wells), on-site treatment at new treatment system
v-"
+
+ +
+
+
$15,625,318
$24,620,268
$35,497,565
Alternative DAPL/GWHS-4: DAPL extraction (approx. 20 wells), groundwater hot spot extraction
targeting 1,100 ng/L (approx. 12 wells), on-site treatment at new treatment system
V
v'
+ +
+ +
.
.
$19,289,931
$26,519,632
$40,464,350
LNAPL/Surface Water Final Action
Alternative LNAPL-SW-1: No action
N/A
N/A
vQ
SO
SO
Alternative LNAPL/SW-2; MPE for LNAPl with treatment at Plant B, groundwater extraction to
prevent discharge to surface water, on-site treatment at new treatment system
v"
V
-
+
-
+
$4,638,520
$6,534,000
$9,005,134
Alternative LNAPL/SW-3: Demolition of Plant B, MPE for LNAPL, targeted groundwater extraction to
prevent discharge to surface water, on-site treatment at new treatment system
V*
V
+
+ +
+
+ +
$2,278,032
$7,356,000
S6.644.452
Alternative LNAPL/SW-4: Excavation of LNAPL with off- site disposal, PRBs to treat groundwater
before discharge into surface water
V
v"
+ +
+
..
-
$5,313,855
$6,726,091
$8,976,238
Soil/Sediment Final Action
Alternative SOIL/SED-1: No action alternative
X
X
N/A
N/A
-
+ +
$0
$0
$0
Alternative SOIL/SED-2: Containment Area cap, upland soil covers, excavation with off-site disposal
and restoration of wetland soil and sediments, limited action for TMPs (Institutional Controls, including
vapor intrusion evaluations or vapor barriers/sub-siab depressurization systems)
V"
+
-
+
+ +
$5,614,205
$1,127,600
$6,072,515
Alternative SOIL/SED-3: Containment Area cap, excavation (0-1 ft) with off-site disposal and dean
soil cover for upland soil, excavation with off-site disposal and restoration of wetland soil and
sediments, air sparging and SVE for TMPs
V
+
+
-
+
$6,686,227
$1,522,200
$7,470,417
Alternative SOIL/SED-4: Excavation (0-10 ft) with off-site disposal and clean soil cover for
Containment Area and upland soil, excavation with off-site disposal and restoration of wetland soil
and sediments, excavation and off-site disposal for TMPs
V*
+ +
.
..
+
$34,045,584
$330,400
$34,174,675
Key:
x Fails - - Poor + Good DAPL = Dense Aqueous Phase Liquid MPE = multi-phase extraction SVE = soil vapor extraction ARARs = Applicable or Relevant and Appropriate Requirements
v Passes - Fair ++ Very Good LNAPL = Light Non-Aqueous Phase Liquid PRB <* permeable reactive barrier TMPs = trimethylpentenes ng/L = nanograms per liter SW = Surface Water
SED = Sediment GWHS = Groundwater Hot Spot N/A - Not Applicable ft = feet O&M = Operations and Maintenance
Note: (1) "Present Value" is the amount of money set aside today to ensure that enough money is available over the expected life of the project, assuming certain conditions (e.g., inflation). Cost information was presumed over a 30-year period, using a 7% discount rate.
Page I of 1
-------
Table L-1
OU1-OU2 Performance Standards:
Protection of Human Health
Chemical of Concern
Performance Standard
Units
Basis
Upland Soil (indoor air impacts)
Trimethylpentenes
0.175
mg/m3
A
Surface Water
Benzo(a)pyrene
0.0009
mg/L
B
Key:
A: Vapor intrusion risks were only qualitatively evaluated due to uncertainty in future use scenario; instead, the OU1/OU2 FS
derived a target level from lexicological calculations.
B: CR = 5 x 10"4 and HI = 0.2 for Trespasser Off-Property West Ditch (Ingestion & Dermal Contact)
mg/m = Milligrams per meter cubed
mg/L = Milligrams per liter
DAPL = Dense Aqueous Phase Liquid
CR = Cancer Risk
HI = Hazard Index
NOMA = n-nitrosodimethylamine
OU = Operable Unit
FS = Feasibility Study
Note: DAPL (excess lifetime cancer risk = 3x10 and hazard index = 3,379) and groundwater hot spots (excess lifetime cancer risk =
hazard index = 291) are addressed as an interim remedy focused on mass removal. The key risk driver for exposure to these sources is NOMA.
Upland soil risks posed by metals and benzo(a)pyrene will be addressed by Institutional Controls to restrict residential use; cleanup levels have
therefore not been established for upland soil.
Page 1 of 1
-------
Table L-2
0U1-0U2 Cleanup Levels and Performance Standards;
Protection of Ecological Receptors
Exposure Medium
Chemical of Concern
Cleanup Level
Units
Basis
Upland Soil
Bis(2-ethylhexyl)phthalate
3
mg/kg
A
Chromium
1,000
mg/kg
B
Wetland Soil
Bis(2-ethylhexyl)phthalate
20
mg/kg
C
Chromium
600
mg/kg
D
Streambank Soil and Aquatic Sediment
Bis(2-ethylhexyl)phthalate
100
mg/kg
E
Chromium
100
mg/kg
F
Exposure Medium
Chemical of Concern
Performance Standard
Units
Basis
Surface Water
Chromium
0.1
mg/L
G
Ammonia
9
mg/L
H
Key;
A Geometric mean of NOAEL-PRG & LOAEL-PRG for American robin (most sensitive receptor) at EA-5.
B: Geometric mean of NOAEL-PRG & LOAEL-PRG for American robin (most sensitive receptor) at EA-5, rounded down to 1000 mg/kg
C: Geometric mean of NOAEL-PRG & LOAEL-PRG for marsh wren at Lower South Ditch Stream (21 mg/kg rounded to 20 mg/kg); applicable to all
wetland soil
D: Geometric mean of NOAEL-PRG & LOAEL-PRG for marsh wren at Off-PWD (641 mg/kg rounded to 600 mg/kg); applicable to all wetland soil
E: Conclusion from REACH dossier (https://echa.europa.eu/registration-dossier/-/registered dossier/15358/6/1)
Fi Probable Effect Concentration (110 mg/kg) and conclusion from REACH dossier (100 mg/kg) rounded to 100 mg/kg
G: Arithmetic mean of hardness-adjusted CCC at seven water bodies at Site (Table 3.12-3 of BERA [AMEC, 2015c]), rounded to 0.1
H: CCC for Site-specific pH and temperature during Spring months (mid-May to June) at East Ditch Stream, applied to all surface water at Site
mg/kg = Milligrams per kilogram
EA = Exposure Area
mg/L = Milligrams per liter
Off-PWD = Off-Property West Ditch Stream
NOAEL = No Observed Adverse Effect Level
Site = Olin Property
LOAEL = Lowest Observed Adverse Effect Level
CCC = Criterion Continuous Concentration
BERA = Baseline Ecological Risk Assessment
REACH = Registration, Evaluation, Authorisation and restriction of Chemicals
-------
Appendix C
Figures
Record of Decision Appendix C
Olin Chemical Superfund Site March 2021
Wilmington, Massachusetts
-------
I I Aberjona River Watershed
i I Ipswich River Watershed
Approximate DAPL Pool
Operable Unit 1
51 Eames St.
Property Boundary
Town Wells
¦ ¦ Town Line
Culvert
700
I Feet
DAPL - Dense Aqueous Phase Liquid
EA- Exposure Area
PWD - Property West Ditch
Notes:
1. Off-Property Jewel Drive DAPL Pool
and On-Property DAPL Pool formerly
referred to as Upper DAPL Pool
2. Watersheds obtained from MassGIS:
https://docs.digital.mass.gov/dataset/
massgis-data-major-drainage-basins
-------
Building No.
Building Name
1
Building #1
2
Building #2
3
Building #3
4
Office/Lab
4A
Office Building
5
General Purpose Building
6
Plant A
6A
Plant A Extension
7
Plant B
8
Plant C-1
8A
Plant C-1
8B
Plant C-1 Shed (C-1 Extension)
9
Plant C-2
9A
Plant C-3
10
Maintenance/Boiler Room
10A
Stock Room
11
Pump House
12
Butter Building
14
Electrical Sub Station
15
West Warehouse
15A
West Warehouse (south)
16
East Warehouse
17
Plant D (D-1, D-2, D-3)
GS
Guard Shack
PB
Plant B Treatment Building
Legend
»51 Eames St Property Boundary =¦=¦ Town Line Railroad
LY3 Conservation Easement ~ Existing Structure — Structure
Containment Area E23 Former Structure »—* Fence
1—1 Aboveground Conveyance Piping 1 ' Lined Lagoons Drain/Sewer Line
- - Underground Conveyance Piping — Paved Road Surface Water
11) Former Disposal Feature — Unpaved Road — Wetland Boundary
DAPL- Dense Aqueous Phase Liquid
EPH/VPH - Extractable Petroleum Hydrocarbons/
Volatile Petroleum Hydrocarbons
Figure 2
Site Features
(Current and Historic)
-------
nobis
Nobis Group* - 585 Middlesex Street
Lowell, MA 01851 -{978)683-0891
www.n obis-grou p. com
FIGURE 2a
OUN AERIAL OVERVIEW
OLIN CHEMICAL SUPERFUND SITE
WILMINGTON, MASSACHUSETTS
PREPARED BY: CA
CHECKED BY: JB
PROJECT NO. D0001
DATE: March 2021
Notes:
1. Olin property circa 1967, looking south.
-------
Legend
9 Public Water Supply Well
N-Nitrosodimethylamine (NDMA) (ng/L):
• 0.42 <=31
O 32 <= 110
O 111 <=230
O 231 <=440
' 441 <= 780
NDMA in Groundwater
~^(R5L: 0.11 ng/L)
~ - Dashed where inferred
O Non-Detect
3 Containment Area
^=51 Eames St. Property Boundary
^^Approximate DAPL Pool Boundary
¦=• Wilmington/Wobum Town Line
450
i Feet
DAPL - Dense Aqueous Phase Liquid
ng/L - Nanograms per Liter
RSL- Regional Screening Levels
Figure 3
N-Nitrosodimethylamine Concentrations
in Shallow Overburden Groundwater
-------
Legend
Public Water Supply Well ~ Well is screened in DAPL
N-Nitrosodimethylamine (NDMA) (ng/L):
O 0.43 <=420
O 421 <= 1700
1701 <= 5700
5701 <= 13000
! 13001 <=24000
450
i Feet
NDMA in Groundwater
(RSL: 0.111 ng/L)
™ ¦ Dashed where inferred
O Non-Detect
1_J Containment Area
™—51 Eames St. Property Boundary
i^™>Approximate DAPL Pool Boundary
=¦=¦ Wilmington/Woburn Town Line
DAPL - Dense Aqueous Phase Liquid
ng/L - Nanograms per Liter
RSL - Regional Screening Levels
Figure 4
N-Nitrosodimethylamine Concentrations
in Deep Overburden Groundwater
-------
FIGURE 4a
EXTENT OF N-NITROSODIMETHYLAMINE
(NDMA) IN DEEP OVERBURDEN
GROUNDWATER
OLIN CHEMICAL SUPERFUND SITE
WILMINGTON, MASSACHUSETTS
PREPARED BY: CA
CHECKED BY: JB
PROJECT NO. D0001
DATE: March 2021
Notes:
1. Maximum result from 2010-2017 sampling events is
labeled. If data are not available from 2010-2017, the
most recent detection from 2003-2017 is included and
labeled with an asterisk.
2. All concentrations shown are in nanograms per liter
(ng/L).
3. Locations of site features depicted hereon are
approximate and given for illustrative purposes only.
4. EPA10^ risk level is 47 ng/L
5. Former Public Supply Wells are shown in pink.
Legend
> 1.1 ng/L
> 11 ng/L
>110 ng/L
>1100 ng/L
> 5000 ng/L
> 11000 ng/L
Feet
1 inch = 600 feet
CHESTNUT
ft
0
ST 1A/2
2.51
GW-63D
34
nobis
Nobis Group® - 535 Middlesex Street
Lowel. MA 01851 -(978) 683-0891
wwvtnobis-group.com
-------
Main Street
DAPL Pool
Jewel Drive
DAPL Pool
On-Property
DAPL Pool
H 1 1 1 1 1 1 1 1 1 1—
1000 1300 1400 1800 1690 2C00
DO
75
70
S5
SO
--
-¦ 50
4$
- - 40
-- 35
30
+ 2®
20
+ 15
10
5
-- 0
- - -5
+ .to
-IS
-- -®
- - -26
-36
•35
4000
Legend:
>1.1 ng/L
>11 ng/L
>110 ng/L
>1,100 ng/L
>5,00 ng/L
>11,0 00 ng/L
Notes:
1. Cross section transect location
shown on Figure 4a.
2. EPA10-4 risk level is 47 ng/L.
nobis
Nobis Group* - 585 Middlesex Street
Lowell, MA 01851 -(978)683-0891
www.nobis-group.com
FIGURE 4b
DAPL POOLS - CONCEPTUAL SITE MODEL
OLIN CHEMICAL SUPERFUND SITE
WILMINGTON, MASSACHUSETTS
PREPARED BY: CA
PROJECT NO. D0001
CHECKED BY: JB
DATE: March 2021
Dense Aqueous Phase Liquid (DAPL) Pools
100
ss
so
85
go
75
70
m
eo
ss
so
£ 45
Z 40
S 35
i 30
30
15
10
5
0
-5
40
•15
¦25
-30
-35 -I
Point A
Point B
MMS SIVtCCT D*«. WXX
JEWEL DftfW CWW*«MT
-------
Legend
Areas of 1% Annual Chance Flood
(formerly referred to as 100 year flood):
EUD Zone A (No Base Flood
Elevations Determined)
Zone AE (Base Flood
Elevations Determined)
Floodway Areas in Zone AE
Areas of 0.2% Annual Chance Flood
(formerly referred to as 500 year flood):
onno ZoneX
Notes:
1. National Flood Hazard Layers obtained from FEMA:
https://www.fema.gov/national-flood-hazard-layer-nfhl
2. Watershed obtained from MassGIS:
https://docs.digital.mass.gov/dataset/ 0
massgis-data-major-drainage-basins
3. DAPL — Dense Aqueous Phase Liquid
51 Eames St.
Property Boundary
Ipswich and Aberjona
Watershed Boundary
Approximate DAPL
Pool Boundary
Containment Area
Paved Road
Unpaved Road
Railroad
Structures
Surface Water
Wetland Boundary
Figure 5
FEMA Flood Zones
-------
-------
-------
-------
-------
-------
-------
[Map lei M eadow,
IB r ook jWet I ana I
WlQrjSwD]
*->>
MMStream
ysm^jp
"^Stream
[e^Jtainmentj
i^mi
jgetention rpnt^iatftd
V Basin ^|pon9]|^^H
¦¦SojJBj|
IBackgroun'dl
.Calcium!
IsuifaTtef
.Landfill
'North
iRonal
Legend
Exposure Area — Paved Road
Culvert — Unpaved Road
51 Eames St. Property Boundary -™ Railroad
— Surface Water
— Wetland Boundary
EA- Exposure Area
o 125250 HHRA-Human Health Risk Assessment
EH&Sfoet PWD - Property West Ditch
Figure 12
Human Health Risk Assessment
Exposure Areas
-------
3 ~ -—| >a '
-------
-------
Legend
Upland Soils 0-1 ft: tZ2 Containment Area Soil — Water
o Below Both Performance Standards IZZl Upland Soil 1 Railroad
• Above BEHP Performance Standard ~~ Wetland Soil — Paved Road
• Above Chromium Performance Standard ~~ Considered to be Sediment Unpaved Road
• Above Both Performance Standards 51 Eames St. — Wetland Boundary
C3 Estimated Remediation Areas Property Boundary
Performance Standards: BEHP Chromium
Soils: 3 mg/kg 1000mg/kg
0 45 90
Feet
BEHP - Bis 2-Ethylhexyl Phthalate
mg/kg - Milligrams per Kilogram
Figure 15
Estimated Remediation Areas
Chromium and BEHP
in Upiand Surface Soil (0-1 ft)
-------
Upland Soils 1-10 ft:
o Below Both Performance Standards
• Above BEHP Performance Standard
• Above Chromium Performance Standard ~~ Considered to be Sediment Unpaved Road
• Above Both Performance Standards 51 Eames St. — Wetland Boundary
C3 Estimated Remediation Areas Property Boundary
Performance Standards: BEHP Chromium
Soils: 3 mg/kg 1000mg/kg
0 45 90
Feet
BEHP - Bis 2-Ethylhexyl Phthalate
mg/kg - Milligrams per Kilogram
Figure 16
Estimated Remediation Areas
Chromium and BEHP
in Upiand Shallow Subsurface Soil (1-10 ft)
-------
-------
Wetland Soils 1-10 ft:
o Below Both Performance Standards
® Above BEHP Performance Standard
• Above Chromium Performance Standard ~~ Considered to be Sediment Unpaved Road
• Above Both Performance Standards 51 Eames St. — Wetland Boundary
C3 Estimated Remediation Areas Property Boundary
Performance Standards: BEHP
Wetland Soils: 20 mg/kg
A, Sediment: 100 mg/kg
jd 0 45 90 BEHP - Bis 2-Ethylhexyl Phthalate
1 1^5jmmi Feet mg/kg - Milligrams per Kilogram
Chromium
600 mg/kg
100 mg/kg
Figure 18
Estimated Remediation Areas
Chromium and BEHP
in Wetland Soil (1-10 ft) and Sediment
-------
Legend
Stream
ll I Slurry Wall
=¦=¦ Wilmington/Woburn Town Line
^—51 Eames St. Property Boundary
Water
— Railroad
Paved Road
IJnpaved Road
Wetland Boundary
Figure 19
South Ditch Stream and East Ditch Stream
Surface Water Areas to be
Addressed by Remedial Alternatives
-------
GW-14
Interpreted Extent of LNAPL -
thickness in feet (March 2019)
~ Recovery Well
^ Monitoring Well
Site Boundary
Fence
¦ Railroad
0 10 20
I Feel LNAPL - Light Non-Aqueous Phase Liquid
Figure 20
Estimated Remediation Area
of LNAPL
-------
Legend
Well is screened in DAPL — Paved Road — Structure
at the time of installation Unpaved Road — Water
• Approximate DAPL Pool Boundary „ Railroad — Wetland Boundary
51 Eames St. Property Boundary
Wilmington/Woburn Town Line
0 125 250
Feet
DAPL - Dense Aqueous Phase Liquid
Formerly the Off-Property Jewel Drive DAPL Pool
and On-Property DAPL Pool were collectively
referred to as the Upper DAPL Pool
-------
Legend
O Public W&ter Supply Well » 2019 - Non-Detect or Not Sampled —Water
Units in ng/L — Wetland Boundary
J - Estimated —^ Railroad
N - Presumptively present — Paved Road
R - Rejected during data validation Unpaved Road
^~Containment Area Wilmington/Woburn
— 51 Eames St. Property Boundary " Town Line
^Approximate DAPL Pool Boundary
2019 NDMA (ng/L):
o 0.38-1.1
o 1.1-11
o 11-110
O 110-1,100
• 1,100- 11,000
• 11,000-20,000
• 20,000 - 42,000
¦ Well is screened in DAPL
2019 NDMA in Groundwater
(RSL. 0.11 ng/L) DAPL - Dense Aqueous Phase Liquid
- Dashed where inferred NDMA _ N-Nitrosodimethylamine . . . . „„
n m__ >¦ ., ... Monitoring well symbol is based on
• Non-Detect ng/L - Nanograms per Liter highest detection at locations with
RSL - Regional Screening Levels multiple sample rounds.
0 125 250
Figure 22
Estimated Remediation Area
Groundwater Hot Spot Extraction
Targeting 5,000 Nanograms per Liter (ng/L)
N-Nitrosodimethyiamine
-------
Plant B
Discharge
' West
Warehouse
East
Warehouse
Former
Wastewater
^Treatment
¦> Plant
GW-CA3D
Containment
Area O
Detention
Basin
Central
Pond
Legend
nn Estimated Remediation Areas 0-10 Feet Containment Area Soi! Paved Road
G3 Estimated Remediation Areas 0-1 Feet
Monitoring Well
Upland Soils:
Below Both
Performance Standards
Above BEHP Performance
Standard (3 mg/kg)
Above Chromium Performance
Standard (1000 mg/kg)
Above Both
* Performance Standards BEHP
= Slurry Wall
1 Equalization Window
Aboveground
Conveyance Piping
Underground
Conveyance Piping
51 Eames St,
Property Boundary
Drain/Sewer Line
Unpaved Road
Structure
h— Railroad
*—*- Fence
Trail
Surface Water
Wetland Boundary
Bis 2-Ethylhexyl Phthalate
Figure 23
Estimated Remediation Areas
Containment Area
-------
__ Proposed
t J Containment Area Cap
i i Proposed Staging Area
Potential TMP
Vapor Barrier/SSDS
Q Existing Containment Area
Estimated Sediment
Excavation Area
Estimated Wetland
1—1 Excavation Area
Note:
The limits of Institutional Controls and
extents of remedies including capping,
excavation, and/or vapor
barriers/depressurization systems
will be based on pre-design investigation
and subsequent data evaluation.
» i Sediment Areas
> " Wetland Soil
__ Upland Soil Area
UW Proposed for Asphalt Cover
Upland Soil Area
Proposed for Soil Cover
^~51 Eames St. Property Boundary
CA- Containment Area
SSDS - Sub-Slab Depressurization
System
TMP - Trimethylpentenes
Figure 24
Conceptual Plan for Alternative SOIL/SED-2 -
Containment Area Cap, Upland Soil Covers,
Excavation with Off-Site Disposal and Restoration of
Wetland Soil and Sediments, and Limited Action for
Trimethylpentenes (TMPs)- Institutional Controls,
Including Vapor Intrusion Evaluations or Vapor
Barriers/Sub-Slab Depressurization Systems
-------
__ Proposed
C J Containment Area Cap
i i Proposed Staging Area
. Existing
J Containment Area
® Air Sparge Well
SVE Well
- Conveyance Piping
C2D TMP Remedial Areas
Estimated Sediment
'—J Excavation Area
Estimated Wetland
S=J Excavation Area
Note:
The limits of Institutional Controls and
extents of remedies including capping,
excavation, and/or vapor
barriers/depressurization systems
will be based on pre-design investigation
and subsequent data evaluation.
AS/SVE - Air Sparge/Soil Vapor Extraction
CA- Containment Area
TMP - Trimethylpentenes
140
I Feet
Figure 25
Conceptual Plan for Alternative SOIL/SED-3 -
Containment Area Cap, Excavation (0-1 Feet)
with Off-Site Disposal and Clean Soil Cover for
Upland Soil, Excavation with Off-Site Disposal
and Restoration of Wetland Soil and Sediments,
Air Sparging and SVE for TMP Impacts
-------
Legend
, Estimated CA
Excavation Areas 0-10 Feet
Estimated CA
—1 Excavation Areas 0-1 Feet
= Proposed Sheet Pile Wall
i i Proposed Staging Area
— Slurry Wall
¦ ¦ ¦ Equalization Window
Containment Area Soil
Upland Soil
Wetland Soil
Sediment Areas
__ Estimated Wetland
I—I Excavation Area
__ Estimated Sediment
I—I Excavation Area
O TMP Remedial Areas
__ Estimated Upland Soil
Excavation Areas 0-10 Feet
—>51 Eames St. Property Boundary
Note:
The limits of Institutional Controls and
extents of remedies including capping,
excavation, and/or vapor
barriers/depressurization systems
will be based on pre-design investigation
and subsequent data evaluation.
CA - Containment Area
EA- Exposure Area
GAC - Granular Activated Carbon
TMP - Trimethylpentenes
140
I Feet
Figure 26
Conceptual Plan for Alternative SOIL/SED-4 -
Excavation (0-10 Feet) with Off-Site Disposal
and Clean Soil Cover for Containment Area and
Upland Soil, Excavation with Off-Site Disposal
and Restoration of Wetland Soil and Sediments,
Excavation and Off-Site Disposal for TMP Impacts
-------
vs. Conceptual Location
™ of Treatment Plant
™ Conveyance Piping
LNAPL Alternative:
O Estimated MPE Well Location
¦ Conveyance Piping
Note:
The limits of Institutional Controls
and extents of remedies, including
the final number and location of
extraction wells, will be based on
pre-design investigations and
subsequent data evaluation.
GAC - Granular Activated Carbon
GW - Groundwater
LNAPL - Light Non-Aqueous Phase Liquid
MPE - Multi-Phase Extraction
SW - Surface Water
140
3 Feet
Ar
Figure 27
Conceptual Plan for
Alternative LNAPL/SW-2 -
MPE for LNAPL with Treatment at Plant B,
GW Extraction to Prevent
mpacts to Surface Water
-------
SW Alternative:
Proposed Extraction Well
vv Conceptual Location
™ of Treatment Plant
™ Conveyance Piping
LNAPL Alternative:
O Estimated MPE Well Location
™ Conveyance Piping
Note:
The limits of Institutional Controls
and extents of remedies, including
the final number and location of
extraction wells, will be based on
pre-design investigations and
subsequent data evaluation.
Interpreted Extent of
— LNAPL (March 2019)
¦V Groundwater Sampling Location
V Surface Water Sampling Location
[ I Containment Area
^"51 Eames St. Property Boundary
GAC - Granular Activated Carbon
GW-Groundwater
LNAPL - Light Non-Aqueous Phase Liquid
MPE - Multi-Phase Extraction
SW - Surface Water
130
3 Feet
A'
Figure 28
Conceptual Plan for Alternative LNAPL/SW-3 -
(EPA'a Selected Final Remedy for
LNAPL and Surface Water)
Demolition of Plant B, Expanded Multi-Phase
Extraction (MPE) for Light Non-Aqueous Phase
Liquid (LNAPL), Targeted Groundwater Extraction
to Prevent Impacts to Surface Water, and On-Site
Treatment at a New Treatment System
-------
Conceptual Location of|
Groundwater Hot Spot
Treatment System |
GW-3S^
PZ-17RR
GW-4^
PZ-16RR
ISC03
Proposed Soil Staging
and Stabilization Area
Legend
SW Alternative:
Grouted Sheet Pile Wall
Permeable Reactive Barrier
LNAPL Alternative:
Assumed
Excavation Area
r_. Contingency
— — Excavation Area
Sheeting for Contingency
~" Excavation Stabilization
Note:
The limits of Institutional Controls
and extents of remedies, including
excavation and placement of
remedy infrastructure components,
will be based on pre-design
investigations and subsequent
data evaluation.
Interpreted Extent of
LNAPL (March 2019)
Groundwater Sampling Location
V Surface Water Sampling Location
^3 Containment Area
^=>51 Eames St. Property Boundary
GW - Groundwater
LNAPL - Light Non-Aqueous Phase Liquid
PRB - Permeable Reactive Barrier
SW - Surface Water
Figure 29
Conceptual Plan for Alternative LNAPL/SW-4 -
Excavation of LNAPL
with Off-Site Disposal,
PRB to Treat GW Before
Flow into Surface Water
-------
DAPL Extraction:
/-K Potential Extraction
r Weil Location
Existing DAPL
Extraction Well
Proposed DAPL
conveyance piping
Existing DAPL
conveyance piping
.Approximate DAPL
E—Ipool Boundary
GW Hot Spot:
"0" Proposed Extraction Weil
>s. Conceptual Location
™ of Treatment Plant
— Proposed GW conveyance piping
NDMA in Groundwater (in ng/L)
DAPL - Dense Aqueous Phase Liquid
GW - Groundwater
NDMA - N-Nitrosodimethylamine
"11,000 ng/L" Identifies NDMA
Concentrations in Nanograms per Liter
ng/L - Nanograms per Liter
Notes:
1. Limits of NDMA isocontours are
based on historically observed
NDMA concentrations.
2. The limits of Institutional Controls
and extents of remedies, including
the final number and location of
extraction wells, will be based on
pre-design investigations and
subsequent data evaluation.
Figure 30
Conceptual Plan for Alternative DAPL/GWHS-2 -
Dense Aqueous Phase Liquid (DAPL) Extraction
(Approximately 5 Wells), Groundwater Hot Spot
Extraction Targeting 11,000 Nanograms per Liter
(ng/L) N-Nitrosodimethylamine (NDMA;
Approximately 2-3 Wells)
-------
DAPL Extraction:
/¦K Potential Extraction
t Well Location
Existing DAPL
Extraction Well
Proposed DAPL
conveyance piping
Existing DAPL
conveyance piping
-Approximate DAPL
1 j Pool Boundary
GW Hot Spot:
Proposed Extraction Well
xn. Conceptual Location
™ of Treatment Plant
- Proposed GW conveyance piping
NDMA in Groundwater (in ng/L)
DAPL - Dense Aqueous Phase Liquid
GW - Groundwater
NDMA - N-Nitrosodimethylamine
"11,000 ng/L" Identifies NDMA
Concentrations in Nanograms per Liter
ng/L - Nanograms per Liter
Notes:
1. Limits of NDMA isocontours are
based on historically observed
NDMA concentrations.
2. The limits of Institutional Controls
and extents of remedies, including
the final number and location of
extraction wells, will be based on
pre-design investigations and
subsequent data evaluation.
Figure 31
Conceptual Plan for Alternative DAPL/GWHS-3 -
(EPA's Selected interim Remedy for
DAPL and Groundwater Hot Spots)
Dense Aqueous Phase Liquid (DAPL) Extraction
(Approximately 20 Wells), Groundwater Hot Spot
Extraction Targeting 5,000 Nanograms per Liter
(ng/L) N-Nitrosodimethylamine (NDMA;
Approximately 6 Wells); and On-Site Treatment
at a New Treatment System
-------
WEST
MAIN STREET DAPL POOL OFF PROPERTY JEWEL DRIVE DAPL POOL CONTAINMENT AREA DAPL POOL
g
LU
m
5
o
z
EXPLORATION LEGEND
EXPLORATION DESIGNATION
APPROXIMATE EXISTING
GROUND SURFACE
TOP OF SCREEN
OBSERVED WATER LEVEL
NDMA CONCENTRATION IN ng/L
BOTTOM OF SCREEN
END OF BORING HOLE
N-NITROSODIMETHYLAMINE
(NDMA) CONCENTRATIONS
150 300
60
1.1-11 ng/L
11 -110 ng/L
110-1,100 ng/L
1,100 - 5,000 ng/L
5,000 ng/L -11,000 ng/L
> 11,000 ng/L
GROUNDWATER
EXTRACTION
WELL
DENSE AQUEOUS
PHASE LIQUID (DAPL)
EXTRACTION WELL
VERTICAL SCALE: 1" = 15'
HORIZONTAL SCALE: 1" = 300'
HORIZONTAL SCALE IN FEETg
Prepared/Date: BRT 03/19/20
Checked/Date: BH 03/05/21
STRATA LEGEND
|^Ml BEDROCK
DAPL POOL
NOTES:
DAPL - Dense Aqueous Phase Liquid
NDMA - N-Nitrosodimethylamine
EXT - Extraction
ng/L - Nanograms per Liter
The limits of Institutional Controls and extents of remedies, including
the final number and location of extraction wells, will be based on pre-
design investigations and subsequent data evaluation.
Figure 32
Cross-Section of the Conceptual Plan for Alternative DAPL/
GWHS-3 (EPA's Selected Interim Remedy for DAPL and
Groundwater Hot Spots)Dense Aqueous Phase Liquid
(DAPL) Extraction (Approximately 20 Wells), Groundwater
Hot Spot Extraction Targeting 5,000 Nanograms per Liter
(ng/L) N-Nitrosodimethylamine (NDMA; Approximately 6
Wells); and On-Site Treatment at a New Treatment System
-------
DAPL Extraction:
Potential Extraction
t Well Location
Existing DAPL
Extraction Well
Proposed DAPL
conveyance piping
Existing DAPL
conveyance piping
- .Approximate DAPL
t^lPool Boundary
GW Hot Spot:
Proposed Extraction Well
/v Conceptual Location
" of Treatment Plant
¦ Proposed GW conveyance piping
— NDMA in Groundwater (in ng/L)
DAPL - Dense Aqueous Phase Liquid
GW - Groundwater
NDMA- N-Nitrosodimethylamine
"11,000 ng/L" Identifies NDMA
Concentrations in Nanograms per Liter
Notes:
1. Limits of NDMA isocontours are
based on historically observed
NDMA concentrations.
2. The limits of Institutional Controls
and extents of remedies, including
the final number and location of
extraction wells, will be based on
pre-design investigations and
subsequent data evaluation.
Figure 33
Conceptual Plan for Alternative DAPL/GWHS-4 -
Dense Aqueous Phase Liquid (DAPL) Extraction
(Approximately 20 Wells), Groundwater Hot Spot
Extraction Targeting 1,100 Nanograms per Liter
(ng/L) N-Nitrosodimethylamine (NDMA;
Approximately 12 Wells)
-------
A
Conventional Screened Well
Most recent bedrock
•
Bedrock Confirmation Location
contours supplied by Oiin
Multi-Port Well
Nobis/EPA Bedrock Contour
~
Induction Logging Well
Maximum estimated DAPL extent
Existing Extraction Well
Paved Road
Proposed Extraction Wells
Unpaved Road
~
DPT Locations
Rail
Site Boundary
Water Features
Buildings
Notes: Wetlands
1. Bedrock contours from AMEC, 2015.
DAPL Extraction Pilot Study Performance 5. Locations of site features depicted
Evaluation Report Supplemental Water hereon are approximate and given for
Level and Hydraulic Analysis. February 5. illustrative purposes only.
2. This site sketch was developed from 6. Extent of DAPL to be confirmed
elevation data from Mactec, Amec Foster during data gaps and pre-design
Wheeler, Wood, and observations made investigations,
by Nobis. N
3. DAPL - Dense Aqueous Phase Liquid
4. DPT - Direct Push Technology
\ *
Figure 34
Conceptual Plan for Off-Property Jewel Drive
DAPL Pool Component of DAPIJGroundwater
Hot Spots Interim Remedy - DAPL Extraction
-------
Legend
Conventional Screened Wells Nobis/EPA Bedrock Contour
Bedrock Confirmation Location Maximum estimated DAPL extent
Multi-Port Well
Existing Extraction Well
Proposed Extraction Wells
Most recent bedrock
contours supplied by Olin
[ 1 Containment Area
Paved Road
Unpaved Road
Rail
— Site Boundary
Water Features
Buildings
Wetlands
Notes:
1. Bedrock contours from Olin, 2018.
Results of Containment Area Bedrock
Borings Olin Chemical Superfund Site,
(OCSS), Wilmington, MA. May 10.
2. This site sketch was developed from
elevation data from Mactec, Amec Foster
Wheeler, Wood, and observations made
by Nobis.
3. DAPL - Dense Aqueous Phase Liquid
4. DPT - Direct Push Technology
5. Locations of site features depicted
hereon are approximate and given for
illustrative purposes only.
6. Extent of DAPL to be confirmed
during data gaps and pre-design
investigations.
Figure 35
Conceptual Plan for Containment Area
DAPL Pool Component of DAPL/Groundwater
Hot Spots Interim Remedy - DAPL Extraction
-------
Legend
9 Bedrock Confirmation Location Most recent bedrock
® Multi-Port Well contours supplied by Olin
a Conventional Screened Well Nobis/EPA Bedrock Contour
~ DPT Locations Paved Road
¦0- Proposed Extraction Wells Unpaved Road
I I Maximum estimated DAPL extent ^a''
Site Boundary
Water Features
Buildings
Notes: Wetlands
1. Bedrock contours fromi Olin 2018. 5 Locations of site features depicted
Slides to support December 10 2018 hereon are approximate and given for
team meeting Provided December 11. N|ustrative pu onl
2. This site sketch was developed from
elevation data from Mactec, Amec Foster
Wheeler, Wood, and observations made
by Nobis.
3. DAPL - Dense Aqueous Phase Liquid
4. DPT - Direct Push Technology
6. Extent of DAPL to be confirmed
during data gaps and pre-design
investigations.
Figure 36
Conceptual Plan for Main Street
DAPL Pool Component of DAPL/Groundwater
Hot Spots Interim Remedy - DAPL Extraction
-------
GW-308
;><• c?°
PZ-16RR
PZ-17RR'
GW-50S
ISC03
Figure 37
Conceptual Plan for Surface Water
Component of LNAPL/Surface Water
Final Remedy - Targeted Groundwater
Extraction and Treatment
Legend
Proposed Extraction Well
/v Conceptual Location
™ of Treatment Plant
The limits of Institutional Controls and
extents of remedies, including the final
number and location of extraction wells,
will be based on pre-design investigations
and subsequent data evaluation.
LNAPL - Light Non-Aqueous Phase Liquid
~ Slurry Wall
Wilmington/Woburn
" " Town Line
51 Eames St.
Property Boundary
Water
— Railroad
Paved Road
Unpaved Road
Wetland Boundary
V
Proposed Underground Piping
Groundwater Sampling Location
Surface Water Sampling Location
Shallow Monitoring Well Location
Interpreted Groundwater Contour
(Dashed where inferred)
-------
Legend
^^Approximate Limits of Proposed Cap Unpaved Road
[ I Proposed Staging Area
^—Slurry Wall
Containment Structure
™» Aboveground Conveyance Piping
- - Underground Conveyance Piping
Eames St, Property Boundary
Paved Road
Structure
H— Railroad
¦—*- Fence
Trail
Drain/Sewer Line
Surface Water
Wetland Boundary
Note: The actual limits of the proposed cap
will be established during the remedial design.
Figure 38
Conceptual Plan for Containment Area Component
of Soil/Sediments Final Remedy - Permanent Cap
-------
Compacted Subgrade Fill (thickness depth varies)
GCL = Geosynthetic Clay Liner
LLDPE = Linear low-density polyethylene
OLIN CHEMICAL
SUPERFUND SITE
WILMINGTON, MA
Note:
Final design of the cap will be determined
during the remedial design phase.
Figure 39
Cross Section of Soil/Sediment - 2
Containment Area Cap
-------
Legend
Upland Soils 0-1 ft:
O Below Both Performance Standards
© Above BEHP Performance Standard
• Above Chromium Performance Standard
• Above Both Performance Standards
__ Upland Soil Area
dl Proposed for Asphalt Cover
Upland Soil Area
Proposed for Soil Cover
^™51 Eames St. Property Boundary
Note:
The limits of Institutional Controls and extents
of remedies including cover systems will be
based on pre-design investigation and
subsequent data evaluation.
~ Containment Area Soil
~ Upland Soil
~ Wetland Soil
¦ i Considered to be Sediment
Water
-1— Railroad
Paved Road
Unpaved Road
Wetland Boundary
Performance Standards: BEHP Chromium
Soils: 3 mg/kg 1000 rng/kg
BEHP - Bis 2-Ethylhexyl Phthalate
mg/kg - Milligrams per Kilogram
Figure 40
Conceptual Plan for Upland Soil
Component of Soil/Sediments
Final Remedy - Cover Systems
-------
Legend
Sediment & Wetland Soils: I 1 Containment Area Soil
O Below Both Performance Standards I I Upland Soil
• Above BEHP Performance Standard Wetland Soil
• Above Chromium Performance Standard ¦ i Considered to be Sediment
• Above Both Performance Standards
C3 Estimated Wetland Excavation Area
C3 Estimated Sediment Excavation Area
Eames St. Property Boundary
Wetland Boundary
Water
¦ Railroad
Paved Road
lln paved Road
Note:
The limits of Institutional Controls
and extents of remedies including
excavation will be based on
pre-design investigation and
subsequent data evaluation.
Performance Standards: BEHP
Wetland Soils: 20 mg/kg
Sediment: 100 mg/kg
BEHP - Bis 2-Ethylhexyl Phthalate
mg/kg - Milligrams per Kilogram
Chromium
600 mg/kg
100 mg/kg
200
I Feet
Figure 41
Conceptual Plan for Wetland Soil
and Sediments Component of
Soil/Sediments Final Remedy -
Excavation with Off-Site Disposal
and Restoration
-------
Legend
o Currently known IMP Remedial Areas
<^™51 Eames St, Property Boundary
Railroad
Paved Road
Note:
The limits of Institutional Controls and
extents of remedies including vapor
barriers/depressurization systems
will be based on pre-design investigation
and subsequent data evaluation.
Unpaved Road
Structure
Water
Wooded Area
Wetland Boundary
EA- Exposure Area
TMP - Trimethylpentene
Figure 42
Conceptual Plan for TMPs Component
of Soil/Sediments Final Remedy -
Limited Action for TMPs - Institutional Controls,
Including Vapor Intrusion Evaluations or Vapor
Barriers/Sub-Slab Depressurization Systems
-------
Appendix D
ARARs Tables
Record of Decision Appendix D
Olin Chemical Superfund Site March 2021
Wilmington, Massachusetts
-------
Table D-1
Action-Specific ARARs, Criteria, Advisories, and Guidance for DAPL/GWHS-3
Record of Decision
Olin Chemical Superfund Site
Wilmington, Massachusetts
Action/T rigger
Requirement
Citation
Status
Requirement Synopsis
Action To Be Taken To Attain Requirement
Federal Standards
Hazardous Waste
Treatment,
Storage, Disposal
Resource Conservation and
Recovery Act (RCRA) Subtitle
C; Hazardous Waste
Identification; Generator
Requirements; Tracking
Requirements; Treatment,
Storage, and Disposal
Requirements; Groundwater
Monitoring Requirements;
Closure and Post Closure
Requirements
42 USC § 6901 et seq.;
40 CFR Parts 260-262, Part
264
Applicable, if hazardous waste
is generated
Federal standards used to identify, manage, and dispose
of hazardous waste. Massachusetts has been delegated
the authority to administer these RCRA standards through
its state hazardous waste management regulations.
Any wastes generated during the interim action will be analyzed
under these standards to determine whether they are listed or
characteristic hazardous waste. Any generation, treatment, or
storage of hazardous waste will be managed in accordance
with these regulations. N on-hazardous wastes will be disposed
of appropriately.
Hazardous Waste -
Air Emissions
RCRA, Air Emission
Standards for Process Vents;
Equipment Leaks; Tanks,
Surface Impoundments, and
Containers
40 CFR Part 264, Subparts
AA, BB, and CC
Applicable, if hazardous
wastes: will be managed by
process vents with volatile
organic concentrations of at
least 10 parts per million by
weight (ppmw) (Subpart AA);
will be managed by equipment
with organic concentrations of
at least 10% by weight
(Subpart BB); or will be
managed in tanks, surface
impoundments, or containers,
and thresholds are met
(Subpart CC)
Relevant and Appropriate, if
organics less than thresholds
or for non-hazardous waste
RCRA emissions standards not delegated to the State.
Standards for process vents for systems that manage
hazardous wastes that have organic concentrations of at
least 10 ppmw.
Standards for air equipment leaks for systems that
manage hazardous wastes with organic concentrations of
at least 10% by weight.
Standards for tanks, surface impoundments, and
containers that manage hazardous wastes with average
VOC concentrations of 500 ppm or greater
No hazardous waste generated by the interim action is
expected to have concentrations over the applicability
threshold. Any generation, treatment, or storage of hazardous
waste will comply with these regulations. Management of VOCs
in DAPL and highly contaminated groundwater will be in
accordance with these air emission regulations.
Discharges to
Surface Water;
Storm Water
Controls
Clean Water Act; National
Pollutant Discharge
Elimination System (NPDES)
40 CFR Parts 122 and 125
Applicable
These requirements include storm water standards for
construction activities disturbing more than one acre and
requirements for stormwater discharges from hazardous
waste treatment, storage, and disposal facilities. These
requirements also specify the permissible concentration or
level of contaminants in the discharge from any point
source to waters of the United States.
Best management practices will be used to control and manage
stormwater runoff during construction and operation of the
DAPL and groundwater hot spot extraction and treatment
systems. The discharge of treated effluent from the treatment of
DAPL and highly contaminated groundwater to a surface water
will meet the substantive discharge standards (the
Massachusetts Surface Water Discharge Permit Program [314
CMR 3.001 has similar requirements).
Discharge to a
Publicly Owned
Treatment Works
(POTW)
General Pretreatment
Regulations for Existing and
New Sources of Pollution
40 CFR Part 403
Applicable, if discharge to a
POTW occurs
Standards for discharge into a Publicly
Owned Treatment Works (POTW).
The specifications for the most appropriate discharge method
for the DAPL and groundwater hot spot treatment systems will
be developed during remedial design. If the interim action
results in discharges to a POTW, the discharge will be
monitored and treated, if necessary, to comply with requlations.
Underground
Injection
SDWA Underground Injection
Control (UIC) Program
40 CFR Parts 144. 146, and
147 (including Subpart W)
Applicable, if treated effluent is
injected underground
These regulations outline minimum program and
performance standards for the UIC program. Technical
criteria and standards for siting, operating, closure, and
post-closure are set forth in Part 146.
The specifications for the most appropriate discharge method
for the DAPL and groundwater hot spot treatment systems will
be developed during remedial design. If re-injection or
infiltration of treated water were to occur, construction and
operation of such re-injection or infiltration would comply with
these requlations.
Air Emissions
Clean Air Act (CAA),
Hazardous Air Pollutants;
National Emission Standards
for Hazardous Air Pollutants
(NESHAP)
42 USC § 112(b)(1);
40 CFR Part 61
Applicable
These regulations establish emissions standards for 189
hazardous air pollutants.
No air emissions from the interim action, such as soil
excavation, will cause air quality standards to be exceeded.
Dust standards will be complied with during the interim action.
Emissions from well drilling activities, DAPL and groundwater
hot spot extraction and treatment system operation, and O&M
will be implemented in accordance with these regulations.
Page 1 of 5
-------
Table D-1
Action-Specific ARARs, Criteria, Advisories, and Guidance for DAPL/GWHS-3
Record of Decision
Olin Chemical Superfund Site
Wilmington, Massachusetts
Action/Trigger
Requirement
Citation
Status
Requirement Synopsis
Action To Be Taken To Attain Requirement
Institutional
Controls
Safe Drinking Water Act
(SDWA) National Primary
Drinking Water Regulations,
Maximum Contaminant Levels
(MCLs)
42 USC § 30Gf et seq.;
40 CFR Part 141, Subparts B
and G
Relevant and Appropriate
These regulations establish MCLs for common organic and
inorganic contaminants applicable to public drinking water
supplies. MCLs are federally enforceable standards based
in part on the availability and cost of treatment techniques.
MCLs were used to determine the extent of required
institutional controls to be established for the interim action.
Institutional
Controls
Safe Drinking Water Act
(SDWA) National Primary
Drinking Water Regulations,
Maximum Contaminant Level
Goals (MCLGs)
42 USC § 300f et seq.;
40 CFR Part 141, Subpart F
Relevant and Appropriate for
non-zero MCLGs only;
MCLGs set as zero are To Be
Con sidered
These regulations establish MCLGs for several organic
and inorganic contaminants in public drinking water
supplies. MCLGs specify the maximum concentration at
which no known or anticipated adverse effect on humans
will occur. MCLGs are non-enforceable health-based goals
set equal to or lower than MCLs.
MCLGs were used to determine the extent of required
institutional controls to be established for the interim action.
Institutional
Controls
EPA Risk Reference Doses
(RfDs)
To Be Considered
RfDs are considered to be the levels unlikely to cause
significant adverse n on-cancer health effects associated
with a threshold mechanism of action in human exposure
for a lifetime. Used in developing risk-based cleanup
standards by computing human health hazard resulting
from exposure to non-carcinogens at the Site.
RfDs were considered in determining the extent of required
institutional controls to be established for the interim action.
Institutional
Controls
Human Health Assessment
Cancer Slope Factors (CSFs)
To Be Considered
CSFs are estimates of the upper-bound probability on the
increased cancer risk from a lifetime exposure to
contaminants. Used in developing risk-based cleanup
standards by computing the incremental cancer risk from
exposure to contaminants at the Site.
CSFs were considered in determining the extent of required
institutional controls to be established for the interim action.
Institutional
Controls
EPA, Office of Water, Drinking
Water Health Advisories
To Be Considered
Health Advisories (HAs) are estimates of acceptable
drinking water levels for chemical substances based on
health effects information; a HA is not a legaRy enforceable
federal standard, but serves as technical guidance to
assist federal, state, and local officials.
HAs were considered in determining the extent of required
institutional controls to be established for the interim action.
Institutional
Controls
Guidelines for Carcinogenic
Risk Assessment
EPA/630/P-Q3/001F, March
2005
To Be Considered
These guidance values are to be used to evaluate the
potential carcinogenic hazard caused by exposure to
contaminants.
These guidance values were considered in determining the
extent of required institutional controls to be established for the
interim action.
Institutional
Controls
Supplemental Guidance for
Assessing Susceptibility from
Early-Life Exposure to
Carcinoqens
EPA/630/R-03/003F, March
2005
To Be Considered
These guidance values are to be used to evaluate the
potential carcinogenic hazard to children caused by
exposure to contaminants.
These guidance values were considered in determining tine
extent of required institutional controls to be established for the
interim action.
Institutional
Controls
Regional Screening Levels for
Chemical Contaminants at
Superfund Sites
USEPA Regional Screening
Levels for Chemical
Contaminants at Superfund
Sites
To Be Considered
Regional Screening Levels (RSLs) are risk-based tools for
screening contaminants at Superfund sites. RSLs are not
intended to be cleanup standards.
These screening levels were considered in determining the
extent of required institutional controls to be established for the
interim action.
Investigation-
Derived Waste
-------
Table D-1
Action-Specific ARARs, Criteria, Advisories, and Guidance for DAPL/GWHS-3
Record of Decision
Olin Chemical Superfund Site
Wilmington, Massachusetts
Action/Trigger
Requirement
Citation
Status
Requirement Synopsis
Action To Be Taken To Attain Requirement
Hazardous Waste -
Management
Facility Standards
Massachusetts Hazardous
Waste Rules - Management
Standards for All Hazardous
Waste Facilities
310 CMR 30.500
Applicable, if hazardous waste
is generated
General facility requirements for waste analysis, security
measures, inspections, and training requirements. Section
30.580 addresses closure. Section 30.590 addresses post-
closure of hazardous waste facilities. Section 30.513
requires a general waste analysis of any hazardous waste.
Any hazardous waste generated during the interim action will
be managed in accordance with these regulations.
Hazardous Waste -
Technical Facility
Standards
Massachusetts Hazardous
Waste Rules - Technical
Standards for All Hazardous
Waste Facilities
310 CMR 30.600
Applicable, if hazardous waste
is managed
Standards for the design, performance, operation,
maintenance, and monitoring of hazardous waste facilities,
including miscellaneous units.
Any hazardous waste generated during the interim action will
be managed in accordance with these regulations.
Hazardous Waste -
Wastewater
Treatment
Massachusetts Hazardous
Waste Rules - Special
Requirements for Wastewater
Treatment Units
310 CMR 30.605
Applicable, if hazardous waste
is managed in a WWTU
This regulation establishes standards for wastewater
treatment units (WWTUs) for the treatment of hazardous
waste
If the interim action generates hazardous waste that is
managed in a WWTU, the WWTU will comply with these
regulations.
Hazardous Waste -
Groundwater
Massachusetts Hazardous
Waste Rules - Groundwater
Protection
310 CMR 30.660
Applicable, if hazardous waste
is managed in a regulated unit
310 CMR 30.661 through 30.673 prescribe requirements
for regulated units that receive hazardous waste, except
for certain waste piles, to protect qroundwater.
Any hazardous waste generated during the interim action will
be managed to prevent contaminant migration to groundwater.
Hazardous Waste -
Containers
Massachusetts Hazardous
Waste Rules - Use and
Management of Containers
310 CMR 30.680
Applicable, if hazardous waste
is containerized
310 CMR 30.681 through 30.689 prescribe requirements
for the use of containers, such as drums, to store
hazardous waste. Provides specifications for inter alia
labelling and marking, management of containers,
inspections, and closure.
Any hazardous waste generated during the interim action that is
managed in containers will comply with these regulations.
Hazardous Waste -
Tanks
Massachusetts Hazardous
Waste Rules - Storage and
Treatment in Tanks
310 CMR 30.690
Applicable, if hazardous waste
is stored and/or treated in
tanks
310 CMR 30.691 through 30.699 prescribe requirements
for the use of tanks to store and treat hazardous waste.
Provides specifications for inter alia design and installation,
containment and detection of leaks, general operating
requirements, inspections, and closure and post-closure
care.
Any hazardous waste generated during the interim action that is
managed in tanks will comply with these regulations.
Discharges to
Surface Waters
Massachusetts Clean Water
Act; Surface Water Discharge
Permit Regulations
MGL c. 21, §§ 26-53;
314 CMR 3.00
Applicable
These regulations require that discharges to waters of the
Commonwealth shall not result in exceedances of
Massachusetts Surface Water Quality Standards
{MSWQS) {314 CMR 4.00).
Any water discharged to surface waters from the treatment of
DAPL and highly contaminated groundwater will be treated to
meet the substantive discharge standards.
Discharges to
Surface Water
Massachusetts Clean Water
Act; MA Surface Water Quality
Standards (MSWQS)
MGL c. 21, §§ 26-53;
314 CMR 4.00
Applicable
These standards designate the most sensitive uses for
which the various waters of the Commonwealth shall be
enhanced, maintained, or protected. Minimum water
quality criteria required to sustain the designated uses are
established.
Any water discharged to surface waters from the treatment of
DAPL and highly contaminated groundwater will be treated to
meet the substantive discharge standards
Hazardous Waste -
Facility Discharge
Standards
Massachusetts Supplemental
Requirements for Hazardous
Waste Management Facilities
MGL c. 21, §§ 26-53;
314 CMR 8.00
Applicable, if hazardous waste
is generated and surface
water discharge occurs
This regulation establishes additional requirements that
must be satisfied for a RCRA facility (a wastewater
treatment works which manages hazardous waste) that
has a wastewater discharqe permit.
interim action activities that involve management of hazardous
waste prior to discharge to surface waters will comply with
these regulations.
Discharge to
Publicly Owned
Treatment Works
(POTW)
Massachusetts Operation,
Maintenance and
Pretreatment Standards for
Wastewater Treatment Works
and Indirect Discharqers
314 CMR 12.00
Applicable, if discharges to a
POTW occur
Standards for pretreatment requirements for sources to a
POTW.
The specifications for the most appropriate discharge method
for the DAPL and groundwater hot spot treatment systems will
be developed during remedial design. If interim action activities
result in discharges to a POTW, the discharge will be monitored
and treated, if necessary, to comply with these requlations.
Underground
Injection
Massachusetts Underground
Injection Control Regulations
310 CMR 27.00
Applicable, if treated effluent is
injected underground
These regulations protect underground sources of drinking
water by regulating the underground injection of hazardous
wastes, fluids used for extraction of minerals, oil, and
energy, and any other fluids having potential to
contaminate groundwater.
The specifications for the most appropriate discharge method
for the DAPL and groundwater hot spot treatment systems will
be developed during remedial design. If re-injection or
infiltration of treated water were to occur, construction and
operation of such re-injection or infiltration would comply with
these regulations.
Page 3 of 5
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Table D-1
Action-Specific ARARs, Criteria, Advisories, and Guidance for DAPL/GWHS-3
Record of Decision
Olin Chemical Superfund Site
Wilmington, Massachusetts
Action/Trigger
Requirement
Citation
Status
Requirement Synopsis
Action To Be Taken To Attain Requirement
Discharge of
treated
groundwater to
groundwater
Massachusetts Groundwater
Discharge Permit Program
314 CMR 5.10 and 5.11
Relevant and Appropriate, if
treated effluent is injected
underground
These regulations require MassDEP to control the
discharge of pollutants to groundwaters of the
Commonwealth to assure that groundwaters are protected
for their actual and potential use as a source of potable
water and surface waters are protected for their existing
and designated uses.
The specifications for the most appropriate discharge method
for the DAPL and groundwater hot spot treatment systems will
be developed during remedial design. If treated effluent is
discharged to groundwater, the discharge will be controlled so
that groundwaters are protected for their actual and potential
use as a source of potable water and surface waters are
protected for their existing and designated uses in accordance
with the substantive discharqe standards.
Air Emissions
Massachusetts Ambient Air
Quality Standards
310 CMR 6.00
Applicable
These regulations establish primary and secondary
standards for emissions of sulfur dioxide, particulate
matter, carbon monoxide, ozone, nitrogen dioxide, and
lead.
The interim action will be implemented in accordance with these
regulations. Emission standards, including for dust, will be
complied with during DAPL and groundwater hot spot extraction
and treatment.
Air Emissions
Massachusetts Air Pollution
Control Regulations
310 CMR 7.00
Applicable
These regulations set emission limits necessary to attain
ambient air quality standards including standards for
visible emissions (7.06); dust, odor, construction and
demolition (7.09); noise (7.10); and asbestos (7.15).
The interim action will be implemented in accordance with these
regulations. Emission standards, including for dust, will be
complied with during DAPL and groundwater hot spot extraction
and treatment.
Institutional
Controls
Massachusetts Drinking Water
Regulations
310 CMR 22.00
Relevant and Appropriate
These regulations establish MCLs that apply to public
drinking water supplies. Massachusetts MCLs and
MCLGs are specified for numerous contaminants,
including inorganic and organic chemicals. For the most
part, the numerical criteria are identical to Federal SDWA
MCLs and MCLGs, although there are several additional
chemicals that have criteria.
Massachusetts MCLs and MCLGs were used to determine the
extent of required institutional controls to be established for the
interim action.
Institutional
Controls
Massachusetts Drinking Water
Guidelines
Drinking Water Guidelines
To Be Considered
Massachusetts DEP's Office of Research and Standards
issues guidance for chemicals other than those with
Massachusetts MCLs in drinking water.
These Guidelines were considered in determining the extent of
required institutional controls to be established for the interim
action.
Monitoring Wells
Massachusetts Standard
References for Monitoring
Wells
WSC-310-91
To Be Considered
Guidance on locating, drilling, installing, sampling and
decommissioning monitoring wells
Monitoring wells that are required as part of the interim action
will be installed, maintained, or decommissioned in accordance
with this guidance.
Sediment/Erosion
Control;
Stormwater
Management
Massachusetts Erosion and
Sediment Control Guidelines
for Urban and Suburban Areas
Prepared for Massachusetts
Executive Office of
Environmental Affairs (original
print March 1997; reprint May
2003)
To Be Considered
Guidance on preventing erosion and sedimentation.
Design, construction, and operation of the interim action will be
implemented in accordance with this guidance.
Air Quality
Division of Air Quality Control
(DAQC)
DAQC Policy 90-001, re:
Noise Regulation
To Be Considered
Guidance on sound emissions.
The interim action will comply with this guidance to assess
whether any remedial measures exceed State noise guidance
levels, and will follow the suggested noise limit to the extent
possible in accordance with this guidance. Construction will be
scheduled durinq dayliqht hours.
Page 4 of 5
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Table D-1
Action-Specific ARARs, Criteria, Advisories, and Guidance for DAPL/GWHS-3
Record of Decision
Olin Chemical Superfund Site
Wilmington, Massachusetts
Notes:
ARAR = Applicable or Relevant and Appropriate Requirement
CAA = Clean Air Act
CERCLA = Comprehensive Environmental Response, Compensation, and Liability Act
CFR = Code of Federal Regulations
CMR = Code of Massachusetts Regulations
CSF = cancer slope factor
DEP = Department of Environmental Protection
IDW = Investigation Derived Waste
MCLGs = Maximum Contaminant Level Goals
MCLs ~ Maximum Contaminant Levels
MGL = Massachusetts General Law
MSWQS = Massachusetts Surface Water Quality Standards
NESHAP = National Emission Standards for Hazardous Air Pollutants
NPDES = National Pollutant Discharge Elimination System
OSWER = Office of Solid Waste and Emergency Response
POTW = Publicly Owned Treatment Works
ppmw = parts per million by weight
RfD = reference dose
RCRA = Resource Conservation and Recovery Act
SDWA = Safe Drinking Water Act
UIC = Underground Injection Control
USC = United States Code
USEPA - United States Environmental Protection Agency
WSC = Waste Site Cleanup
Page 5 of 5
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Table D-2
Location-Specific ARARs, Criteria, Advisories, and Guidance for DAPL/GWHS-3
Record of Decision
Olin Chemical Superfund Site
Wilmington, Massachusetts
Location Characteristic
Requirement
Citation
Status
Requirement Synopsis
Action To Be Taken To Attain Requirement
Federal Standards
Floodplains and Wetlands
Floodplain Management
and Protection of
Wetlands
44 CFR Part 9 (implementing
Executive Orders 11988 and
11990)
Relevant and Appropriate
Federal Emergency Management Agency (FEMA) regulations
set forth the policy, procedure, and responsibilities to
implement and enforce Executive Order 11988 (Floodplain
Management) and Executive Order 11990 (Protection of
Wetlands). These regulations prohibit activities that adversely
affect a federally-regulated wetland unless there is no
practicable alternative and the proposed action includes ail
practicable measures to minimize harm to wetlands that may
result from such use. These regulations require the avoidance
of impacts associated with the occupancy and modification of
federally-designated 100-year and 500-year floodplains and
require the avoidance of development within a floodplain
wherever there is a practicable alternative. An assessment of
impacts to the 500-year floodplain is required for critical
actions, which includes siting waste facilities in a floodplain.
These regulations require public notice when proposing any
action in or affecting floodplains or wetlands.
if there is no practicable alternative method to work in federal
jurisdictional wetlands, or 100-year or 500-year floodplains, then all
practicable measures will be taken to minimize and mitigate any
adverse impacts. Erosion and sedimentation control measures will be
adopted during remedial activities to protect these wetlands and
fbodplains. The interim action, including the use of extraction wells,
access roads, conveyance piping, and associated infrastructure
constructed in/adjacent to wetlands and floodplains, will comply with
this ARAR through appropriate avoidance, minimization, mitigation
and/or restoration. After completion of work within the regulated 100-
year and 500-year floodplains, there will be no significant net loss of
flood storage capacity and no significant net increase in flood stage or
velocities. Floodplain habitat will be restored to the extent practicable.
Wetlands, Aquatic
Ecosystem
Clean Water Act (CWA)
Section 404(b)(1)
Guidelines for
Specification of Disposal
Sites for Dredged or Fill
Material
33 USC § 1344(b)(1);
40 CFR Parts 230 & 231:
33 CFR Parts 320-323
Applicable
For discharge of dredged or fill material into water bodies or
wetlands, there must be no practicable alternative with less
adverse impact on aquatic ecosystem; discharge cannot
cause or contribute to violation of state water quality standards
or toxic effluent standards or jeopardize threatened or
endangered species; discharge cannot significantly degrade
waters of U.S.; practicable steps must be taken to minimize
and mitigate adverse impacts; and impacts on flood level,
flood velocity, and flood storage capacity must be evaluated.
Sets standards for restoration and mitigation required as a
result of unavoidable impacts to aquatic resources. EPA must
determine which alternative is the least environmentally
damaging practicable alterative to protect wetland and aquatic
resources.
The interim action, including the use of extraction wells, access roads,
conveyance piping, and associated infrastructure constructed
in/adjacent to wetlands, will comply with this ARAR through
appropriate avoidance, minimization, mitigation and/or restoration.
EPA has determined that the selected remedial alternative is the least
environmentally damaging practicable alternative because (a) there is
no practicable alternative method that will achieve cleanup objectives
with less adverse impact and (b) all practicable measures would be
taken to minimize and mitigate any adverse impacts from the work.
Floodplains
RCRA Floodplain
Restrictions for Hazardous
Waste Facilities
42 USC § 6901 etseq.;
40 CFR §264.18(b)
Applicable, if hazardous
waste is managed within the
100-year floodplain
A hazardous waste treatment, storage, or disposal facility
located in a 100-year floodplain must be designed,
constructed, operated, and maintained to prevent washout or
to result in no adverse effects on human health or the
environment if washout were to occur.
To the extent any hazardous waste is generated during the interim
action, including the installation and operation of extraction wells,
conveyance piping, and treatment systems, the waste will be managed
so that it will not impact floodplain resources.
Floodplains
RCRA Floodplain
Restrictions for Solid
Waste Disposal Facilities
and Practices
40 CFR §257.3-1
Applicable, if solid waste is
managed within the 100-
year floodplain
Solid waste practices must not restrict the flow of a 100-year
flood, reduce the temporary water storage capacity of the
floodplain, or result in washout of solid waste, so as to pose a
hazard to human life, wildlife, or land or water resources.
Any solid waste generated during the interim action, including the
installation and operation of extraction wells, conveyance piping, and
treatment systems, will be managed so that it will not impact floodplain
resources.
Wetlands
U.S. Army Corps of
Engineers, New England
District Compensatory
Mitigation Guidance (09-
07-2016)
To Be Considered
This guidance is to be considered when compensatory
mitigation to address impacts to federal jurisdictional wetlands
is appropriate for a particular remedial activity.
The interim action, including the installation and operation of extraction
wells, conveyance piping, and treatment systems, may impact federal
jurisdictional wetlands. Activities affecting federal jurisdictional
wetlands will be conducted in accordance with these guidance
standards for mitiqation and restoration.
Endangered Species
Endangered Species Act
16 U.S.C. §§ 1531 etseq.;
50 CFR §§17.11-17.12;
50 CFR Part 402
Applicable, if endangered
species are encountered
This act requires action to avoid jeopardizing the continued
existence of listed endangered or threatened species or
modification of their habitat.
No known endangered or threatened species or their habitats have
been identified in the vicinity of the Site. If such species or habitats in
the interim action area are identified, interim action activities would be
designed and implemented to avoid effects to endangered or
threatened species or their habitats.
Page 1 of 3
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Table D-2
Location-Specific ARARs, Criteria, Advisories, and Guidance for DAPL/GWHS-3
Record of Decision
Olin Chemical Superfund Site
Wilmington, Massachusetts
Location Characteristic
Requirement
Citation
Status
Requirement Synopsis
Action To Be Taken To Attain Requirement
Historical/ Archeological
Resources
National Historic
Preservation Act
54 USC §§ 300101 etseq.;
36 CFR Part 800
Applicable, if subject
historical resources are
present
Pursuant to Section 106 of the NHPA, CERCLA response
actions are required to take into account the effects of the
response activities on any historic property (any prehistoric or
historic district, site, building, structure, or object included in, or
eligible for inclusion in, the National Register of Historic
Places, which would be significant in American history,
architecture, archeology, engineering, and culture) and to
resolve any adverse effects, including avoidance,
minimization, or mitiqation of the adverse effects.
No protected resources are known to exist in the area impacted by the
interim action; however, the Middlesex Canal (Middlesex Canal
Historic and Archaeological District) is located in close proximity to
Maple Meadow Brook, where extraction wells will be potentially
installed. If protected resources are identified in the interim action
area, federal and state preservation officials would be consulted to
address measures to avoid, minimize and/or mitigate any impacts to
these protected resources.
Surface Waters,
Wetland/Waterway
Habitat for Endangered
Species, Migratory
Species
Fish and Wildlife
Coordination Act
16 USC§661 etseq.;
40 CFR § 6.302(g)
Applicable
Requires that any federal agency proposing to modify a body
of water must consult with the U.S. Fish and Wildlife Service,
National Marine Fisheries Service, and other related state
agencies to prevent, mitigate, or compensate for project-
related losses of or damage to endangered species, fish and
wildlife resources.
Interim action activities will be designed and implemented to prevent
and mitigate project related impacts to fish and wildlife. Consultation
with appropriate agencies will be maintained during planning and
implementation of interim action activities that may alter protected
resource area to ensure that losses of or damage to habitat and
wildlife will be prevented, mitiqated, or compensated.
Atlantic Flyway
Migratory Bird Treaty Act
16 USC §703 etseq.
Applicable, if subject
protected species are
present
Protects migratory birds, their nests and eggs. A depredation
permit issued by the U.S. Fish and Wildlife Service is required
to take, possess, or transport migratory birds or disturb their
nests, eggs, or young.
Interim action activities will be evaluated to protect migratory birds,
their nests and eggs. If migratory bird protected areas are identified in
the interim action area, measures to avoid, minimize and/or mitigate
any impacts to protected resource areas will be implemented in
consultation with appropriate agencies.
State Standards
Floodplains, Wetlands,
Surface Waters
Massachusetts Wetland
Protection Act and
Regulations
MGL c. 131, §40;
310 CMR 10.00
Applicable if alternative
alters wetlands or
floodplains
These regulations restrict dredging, filling, altering, or polluting
inland wetland resource areas (defined as areas within the
100-year floodpiain) and buffer zones (100 feet of a vegetated
wetland or 200 feet from a perennial stream), and impose
performance standards for work in such areas. Protected
resource areas include: 10.54 (Bank); 10.55 (Bordering
Vegetated Wetlands); 10.56 (Land under Water Bodies and
Waterways); 10.57 (Land Subject to Flooding); and 10.58
(Riverfront Area).
If the interim action, including the use of extraction wells, access
roads, conveyance piping, and associated infrastructure constructed
in/adjacent to wetlands and floodplains, would alter state regulated
wetlands or floodplains, it would comply with this ARAR through
appropriate avoidance, minimization, mitigation, and restoration. Any
interim action activity conducted within 100 feet of a state regulated
wetland resource area or 200 feet from a perennial stream will comply
with the substantive requirements of these regulations. Mitigation of
impacts on state wetland resource areas will be addressed. All interim
action work within any regulated floodpiain will result in no net loss of
flood storage capacity and no net increase in flood stage or velocities.
Floodpiain habitat will be restored, to the extent practicable.
Area of Critical
Environmental Concern
Massachusetts Areas of
Critical Environmental
Concern (ACECs)
Regulations
301 CMR 12.00
Applicable, if AC EC is
identified
An ACEC is of regional, state, or national importance or
contains significant ecological systems with critical
interrelationships among a number of components. An eligible
area must contain features from four or more of the following
groups: (1) fisheries, (2) coastal features, (3) estuarine
wetlands, (4) inland wetlands, (5) inland surface waters, (6)
water supply areas (e.g., aquifer recharge area); (7) natural
hazard areas (e.g., floodpiain); (8) agricultural areas; (9)
historical/archeological resources; (10) habitat resources (e.g.,
for endangered wildlife); or (11) special use areas. After an
area is designated as an ACEC, the aim is to preserve and
restore these areas.
No known ACEC has been identified at the Site. If an ACEC is
identified in the interim action area, interim action activities will be
controlled to minimize impacts to affected species or resources.
Floodplains
Massachusetts Hazardous
Waste Regulations,
Location Standards for
Land Subject to Flooding
310 CMR 30.701
Applicable, if hazardous
waste is managed within a
floodpiain
This regulation sets forth criteria for siting hazardous waste
facilities within land subject to flooding (as defined under the
Massachusetts Wetland Protection Act standards). Any new or
expanded hazardous waste storage or treatment facility (which
only receives hazardous waste from on-site sources), the
active portion of which is located within the boundary of land
subject to flooding from the statistical 100-year frequency
storm, shall be flood-proofed. Flood-proofing shall be
designed, constructed, operated and maintained to prevent
floodwaters from coming into contact with hazardous waste.
To the extent any hazardous waste is generated during the interim
action, including the installation and operation of extraction wells,
conveyance piping, and treatment systems, the waste will be managed
so that it will not impact floodpiain resources.
Page 2 of 3
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Table D-2
Location-Specific ARARs, Criteria, Advisories, and Guidance for DAPL/GWHS-3
Record of Decision
Olin Chemical Superfund Site
Wilmington, Massachusetts
Location Characteristic
Requirement
Citation
Status
Requirement Synopsis
Action To Be Taken To Attain Requirement
Endangered Species
Massachusetts
Endangered Species
Regulations
321 CMR 10.00
Applicable, if endangered
species are encountered
Requires action to regulate the impact to state listed
endangered or threatened species or their habitats. Actions
must be conducted in a manner that minimizes the impact to
Massachusetts-listed rare, threatened, or endangered species,
and species listed by the Massachusetts Natural Heritage
Proqram.
No known endangered or threatened species or their habitats have
been identified in the vicinity of the Site. If such species or their
habitats in the interim action area are identified, interim action
activities would be designed and implemented to avoid adverse effects
to endangered or threatened species or their habitats.
Historical/ Archeological
Resources
Massachusetts Antiquities
Act; Massachusetts
Historical Commission
Regulations; Protection of
Properties Included in the
State Register of Historic
Places
MGL c. 9, §§ 26-27C;
950 CMR 70.00 and 71.00
Applicable, if subject
historical resources are
present.
Projects must eliminate, limit, or mitigate adverse effects to
properties listed in the State Register of Historic Places
(historic and archaeological properties). Establishes
coordination with the National Historic Preservation Act.
No protected resources are known to exist in the area impacted by the
interim action; however, the Middlesex Ganal (Middlesex Canal
Historic and Archaeological District) is located in close proximity to
Maple Meadow Brook, where extraction wells will be potentially
installed, if protected resources are identified in the interim action
area, federal and state preservation officials would be consulted to
address measures to avoid, minimize and/or mitigate any impacts to
these protected resources.
Notes:
ACEC = Area of Critical Environmental Concern
ARAR = Applicable or Relevant and Appropriate Requirement
CFR = Code of Federal Regulations
CMR = Code of Massachusetts Regulations
CWA = Clean Water Act
DAPL = Dense Aqueous Phase Liquid
EPA = United States Environmental Protection Agency
FEMA = Federal Emergency Management Agency
MGL = Massachusetts General Law
RCRA = Resource Conservation and Recovery Act
USC = United States Code
USFWS = United States Fish and Wildlife Service
Page 3 of 3
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Table D-3
Action-Specific ARARs, Criteria, Advisories, and Guidance for LNAPL/SW-3
Record of Decision
Olin Chemical Superfund Site
Wilmington, Massachusetts
Action/Trigger
Requirement
Citation
Status
Requirement Synopsis
Action To Be Taken To Attain Requirement
Federal Standards
Hazardous Waste
Treatment, Storage,
Disposal
Resource Conservation and
Recovery Act (RCRA) Subtitle C;
Hazardous Waste Identification;
Generator Requirements;
Tracking Requirements;
Treatment Storage, and Disposal
Requirements; Groundwater
Monitoring Requirements;
Closure and Post Closure
Requirements
42 USC § 6901 etseq.;
40 CFR Parts 260-262, Part 264
Applicable, if hazardous waste is
generated.
Federal standards used to identify, manage, and
dispose of hazardous waste. Massachusetts has
been delegated the authority to administer these
RCRA standards through its state hazardous waste
management regulations.
Any wastes generated during remedial activities
will be analyzed under these standards to
determine whether they are listed or characteristic
hazardous waste. Any generation, treatment, or
storage of hazardous waste will be managed in
accordance with these regulations. Non-hazardous
wastes will be disposed of appropriately.
Hazardous Waste - Air
Emissions
RCRA, Air Emission Standards
for Process Vents; Equipment
Leaks; Tanks, Surface
Impoundments, and Containers
40 CFR Part 264, Subparts AA,
BB, and CC
Applicable, if hazardous wastes:
will be managed by process
vents with volatile organic
concentrations of at least 10
parts per million by weight
(ppmw) (Subpart AA); will be
managed by equipment with
organic concentrations of at least
10% by weight (Subpart BB); or
will be managed in tanks, surface
impoundments, or containers,
and thresholds are met (Subpart
CC).
Relevant and Appropriate, if
organics less than thresholds or
for non-hazardous waste.
RCRA emissions standards not delegated to the
State.
Standards for process vents for systems that
manage hazardous wastes that have organic
concentrations of at least 10 ppmw.
Standards for air equipment leaks for systems that
manage hazardous wastes with organic
concentrations of at least 10% by weight.
Standards for tanks, surface impoundments, and
containers that manage hazardous wastes with
average VOC concentrations of 500 ppm or
greater.
No hazardous waste generated by remedial
activities is expected to have concentrations over
the applicability threshold. Any generation,
treatment, or storage of hazardous waste above
applicability thresholds will comply with these
regulations. Management of VOCs in LNAPL will
be in accordance with these air emission
regulations.
Discharges to Surface
Water; Storm Water
Controls
Clean Water Act; National
Pollutant Discharge Elimination
System (NPDES)
40 CFR Parts 122 and 125
Applicable
These requirements include storm water standards
for construction activities disturbing more than one
acre and requirements for stormwater discharges
from hazardous waste treatment, storage, and
disposal facilities. These requirements also specify
the permissible concentration or level of
contaminants in the discharge from any point
source to waters of the United States.
Best management practices will be used to control
and manage stormwater runoff during construction
and operation. Alternatives that incorporate
discharges to surface waters will need to have the
discharges meet the substantive discharge
standards (the Massachusetts Surface Water
Discharge Permit Program [314 CMR 3.00] has
similar requirements).
Discharge to a Publicly
Owned Treatment
Works (POTW)
General Pretreatment
Regulations for Existing and
New Sources of Pollution
40 CFR Part 403
Applicable, if discharge to a
POTW occurs
Standards for discharge into a Publicly
Owned Treatment Works (POTW).
The specifications for the most appropriate
discharge method for effluent from remedial
activities will be developed during remedial design.
If remedial activities result in discharges to a
POTW, the discharge will be monitored and
treated, if necessary, to comply with these
regulations.
Air Emissions
Clean Air Act (CAA), Hazardous
Air Pollutants; National Emission
Standards for Asbestos
42 USC § 112(b)(1);
40 CFR Part 61, Subpart M
Applicable, if asbestos containing
waste material is present in Plant
B
Provides regulations for emission of particular air
pollutants from specific sources, including
standards for demolition of asbestos-containing
materials, and regulations for transport and
disposal of asbestos waste
If these regulations apply due to asbestos in Plant
B, demolition of Plant B will comply with the work
practice standards as well as the standards for
collection, processing, packaging, and
transportation.
Air Emissions
Clean Air Act (CAA), Hazardous
Air Pollutants; National Emission
Standards for Hazardous Air
Pollutants (NESHAP)
42 USC § 112(b)(1);
40 CFR Part 61
Applicable
These regulations establish emissions standards
for 189 hazardous air pollutants.
No air emissions from the remedial activities will
cause air quality standards to be exceeded. Dust
standards will be complied with during the remedial
activities. Emissions from remedial activities will be
implemented in accordance with these regulations.
Page 1 of 5
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Table D-3
Action-Specific ARARs, Criteria, Advisories, and Guidance for LNAPL/SW-3
Record of Decision
Olin Chemical Superfund Site
Wilmington, Massachusetts
Action/Trigger
Requirement
Citation
Status
Requirement Synopsis
Action To Be Taken To Attain Requirement
Underground Injection
SDWA Underground Injection
Control (UIC) Program
40 CFR Parts 144, 146. and 147
(including Subpart W)
Applicable, if treated effluent is
injected underground
These regulations outline minimum program and
performance standards for the UIC program.
Technical criteria and standards for siting,
operating, closure, and post-closure are set forth in
Part 146.
The specifications for the most appropriate
discharge method will be developed during
remedial design. If re-injection or infiltration of
treated water were to occur, construction and
operation of such re-injection or infiltration would
comply with these requlations.
Monitoring Surface
Water
Clean Water Act (CWA) National
Recommended Water Quality
Criteria (NRWQC); Aquatic Life
Criteria
To Be Considered
NRWQC are health-based criteria developed for
chemical constituents in surface water. They have
been developed to protect aquatic life and human
health from harmful effects due to exposure to
chemically impacted surface water. Performance
standards to be used for monitoring surface water
during remedial activities.
NRWQC were used to derive ecological surface
water performance standards that would be
protective of ecological receptors in surface water,
which will be used to monitor surface water during
remedial action to ensure that the alternatives are
successful in reducing contaminant levels in
surface water to be protective of ecological
receptors.
Investigation-Derived
Waste (IDW)
Guide to Management of
Investigation-Derived Wastes
USEPA OSWER Publication
9345.3-03FS, January 1992
To Be Considered
Guidance on management of IDW in a manner that
ensures protection of human health and the
environment.
IDW generated during remedial activities will be
managed in accordance with guidance from this
publication.
Groundwater
Remediation
Summary of Key Existing EPA
CERCLA Policies for
Groundwater Restoration
OSWER 9283.1- 33 (June 26,
2009)
To Be Considered
Guidance on developing groundwater remedies at
CERCLA sites.
The remedial activities were developed in
consideration of this guidance.
Institutional Controls
EPA Risk Reference Doses
(RfDs)
To Be Considered
RfDs are considered to be the levels unlikely to
cause significant adverse non-cancer health effects
associated with a threshold mechanism of action in
human exposure for a lifetime. Used in developing
risk-based cleanup standards by computing human
health hazard resulting from exposure to non-
carcinoqens at the Site.
RfDs were considered to derive human health
surface water performance standards that would be
protective of human receptors in surface water,
which will be used to monitor surface water during
remedial action to ensure that the alternatives are
successful in reducing contaminant levels in
surface water to be protective of human receptors.
Institutional Controls
Human Health Assessment
Cancer Slope Factors (CSFs)
To Be Considered
CSFs are estimates of the upper-bound probability
on the increased cancer risk from a lifetime
exposure to contaminants. Used in developing risk-
based cleanup standards by computing the
incremental cancer risk from exposure to
contaminants at the Site.
CSFs were considered to derive human health
surface water performance standards that would be
protective of human receptors in surface water,
which will be used to monitor surface water during
remedial action to ensure that the alternatives are
successful in reducing contaminant levels in
surface water to be protective of human receptors.
Institutional Controls
EPA, Office of Water, Drinking
Water Health Advisories
To Be Considered
Health Advisories (HAs) are estimates of
acceptable drinking water levels for chemical
substances based on health effects information; a
HA is not a legally enforceable federal standard,
but serves as technical guidance to assist federal,
state, and local officials.
HAs were considered to derive human health
surface water performance standards that would be
protective of human receptors in surface water,
which will be used to monitor surface water during
remedial action to ensure that the alternatives are
successful in reducing contaminant levels in
surface water to be protective of human receptors.
Institutional Controls
Guidelines for Carcinogenic Risk
Assessment
EPA/630/P-03/001F, March 2005
To Be Considered
These guidance values are to be used to evaluate
the potential carcinogenic hazard caused by
exposure to contaminants.
These guidance values were considered to derive
human health surface water performance
standards that would be protective of human
receptors in surface water, which will be used to
monitor surface water during remedial action to
ensure that the alternatives are successful in
reducing contaminant levels in surface water to be
protective of human receptors.
Page 2 of 5
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Table D-3
Action-Specific ARARs, Criteria, Advisories, and Guidance for LNAPL/SW-3
Record of Decision
Olin Chemical Superfund Site
Wilmington, Massachusetts
Action/Trigger
Requirement
Citation
Status
Requirement Synopsis
Action To Be Taken To Attain Requirement
Institutional Controls
Supplemental Guidance for
Assessing Susceptibility from
Early-Life Exposure to
Carcinogens
EPA/63O/R-O3/O03F, March 2005
To Be Considered
These guidance values are to be used to evaluate
the potential carcinogenic hazard to children
caused by exposure to contaminants.
These guidance values were considered to derive
human health surface water performance
standards that would be protective of human
receptors in surface water, which will be used to
monitor surface water during remedial action to
ensure that the alternatives are successful in
reducing contaminant levels in surface water to be
protective of human receptors.
Institutional Controls
Regional Screening Levels for
Chemical Contaminants at
Superfund Sites
USEPA Regional Screening
Levels for Chemical
Contaminants at Superfund Sites
To Be Considered
Regional Screening Levels (RSLs) are risk-based
tools for screening contaminants at Superfund
sites. RSLs are not intended to be cleanup
standards.
These screening levels were considered to derive
human health surface water performance
standards that would be protective of human
receptors in surface water, which will be used to
monitor surface water during remedial action to
ensure that the alternatives are successful in
reducing contaminant levels in surface water to be
protective of human receptors.
State Standards
Hazardous Waste
Identification
Massachusetts Hazardous
Waste Management Rules for
Identification and Listing of
Hazardous Wastes
310 CMR 30.100
Applicable, if hazardous waste is
generated
Massachusetts is delegated to administer RCRA
through its state regulations. These regulations
establish requirements for determining whether
wastes are either listed or characteristic hazardous
waste.
Any wastes generated during remedial activities
will be analyzed under these standards to
determine whether they are listed or characteristic
hazardous wastes. Hazardous and nonhazardous
wastes will be managed and disposed of
appropriately.
Hazardous Waste -
Generator Standards
Massachusetts Hazardous
Waste Rules - Requirements for
Generators
310CMR 30.300
Applicable, if hazardous waste is
generated
These regulations contain requirements for
hazardous waste generators. The regulations
apply to generators of sampling waste and also
apply to the accumulation of waste prior to off-site
disposal.
Any hazardous waste generated during remedial
activities will be managed in accordance with these
regulations.
Hazardous Waste -
Management Facility
Standards
Massachusetts Hazardous
Waste Rules - Management
Standards for All Hazardous
Waste Facilities
310 CMR 30.500
Applicable, if hazardous waste is
generated
General facility requirements for waste analysis,
security measures, inspections, and training
requirements. Section 30.580 addresses closure.
Section 30.590 addresses post-closure of
hazardous waste facilities. Section 30.513 requires
a qeneral waste analysis of any hazardous waste.
Any hazardous waste generated during remedial
activities will be managed in accordance with these
regulations.
Hazardous Waste -
Technical Facility
otanoams
Massachusetts Hazardous
Waste Rules - Technical
Standards for All Hazardous
Waste Facilities
310 CMR 30.600
Applicable, if hazardous waste is
managed
Standards for the design, performance, operation,
maintenance, and monitoring of hazardous waste
facilities, including miscellaneous units.
Any hazardous waste generated during remedial
activities will be managed in accordance with these
regulations.
Hazardous Waste -
Wastewater Treatment
Massachusetts Hazardous
Waste Rules - Special
Requirements for Wastewater
Treatment Units
310 CMR 30.605
Applicable, if hazardous waste is
managed in a WWTU
This regulation establishes standards for
wastewater treatment units (WWTUs) for the
treatment of hazardous waste
Any hazardous waste generated during remedial
activities will be managed in accordance with these
regulations. If remedial activities generate
hazardous waste that is managed in a WWTU, the
WWTU will comply with these requlations.
Hazardous Waste -
Groundwater
Massachusetts Hazardous
Waste Rules - Groundwater
Protection
310 CMR 30.660
Applicable, if hazardous waste is
managed in a regulated unit
310 CMR 30.661 through 30.673 prescribe
requirements for regulated units that receive
hazardous waste, except for certain waste piles, to
protect groundwater.
Any hazardous waste generated during remedial
activities will be managed to prevent contaminant
migration to groundwater. Any management of
hazardous waste in subject waste piles will comply
with these requlations.
Hazardous Waste -
Containers
Massachusetts Hazardous
Waste Rules - Use and
Management of Containers
310 CMR 30.680
Applicable, if hazardous waste is
containerized
310 CMR 30.681 through 30.689 prescribe
requirements for the use of containers, such as
drums, to store hazardous waste. Provides
specifications for inter alia labelling and marking,
management of containers, inspections, and
closure.
Any hazardous waste generated during remedial
activities that is managed in containers will comply
with these regulations.
Page 3 of 5
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Table D-3
Action-Specific ARARs, Criteria, Advisories, and Guidance for LNAPL/SW-3
Record of Decision
Olin Chemical Superfund Site
Wilmington, Massachusetts
Action/Trigger
Requirement
Citation
Status
Requirement Synopsis
Action To Be Taken To Attain Requirement
Hazardous Waste -
Tanks
Massachusetts Hazardous
Waste Rules - Storage and
Treatment in Tanks
310CMR 30.690
Applicable, if hazardous waste is
stored and/or treated in tanks
310 CMR 30.691 through 30.699 prescribe
requirements for the use of tanks to store and treat
hazardous waste. Provides specifications for inter
alia design and installation, containment and
detection of leaks, general operating requirements,
inspections, and closure and post-closure care.
Any hazardous waste generated during remedial
activities that is managed in tanks will comply with
these regulations.
Hazardous Waste -
Waste Piles
Massachusetts Hazardous
Waste Rules - Waste Piles
31OCMR 30.640
Applicable, if hazardous waste is
managed in waste piles
310 CMR 30.641 through 30.649 prescribe
requirements for storage and treatment of
hazardous waste in waste piles. Provides
specifications for inter alia design and operations,
monitoring and inspection, and closure and post-
closure care.
Any hazardous waste generated during remedial
activities that is managed in waste piles will comply
with these regulations.
Discharges to Surface
Waters
Massachusetts Clean Water Act;
Surface Water Discharge Permit
Regulations
MGL c. 21, §§ 26-53;
314 CMR 3.00
Applicable
These regulations require that discharges to waters
of the Commonwealth shall not result in
exceed an ces of Massachusetts Surface Water
Quality Standards (MSWQS) (314 CMR 4.00).
Any water discharged to surface waters related to
excavation and dewatering activities will be treated
to meet the substantive discharge standards.
Discharges to Surface
Water
Massachusetts Clean Water Act;
MA Surface Water Quality
Standards (MSWQS)
MGL c.21, §§ 26-53;
314 CMR 4.00
Applicable
These standards designate the most sensitive uses
for which the various waters of the Commonwealth
shall be enhanced, maintained, or protected.
Minimum water quality criteria required to sustain
the desiqnated uses are established.
Any water discharged to surface waters related to
excavation and dewatering activities will be treated
to meet the substantive discharge standards.
Discharge to Publicly
Owned Treatment
Works (POTW)
Massachusetts Operation,
Maintenance and Pretreatment
Standards for Wastewater
Treatment Works and Indirect
Dischargers
314 CMR 12.00
Applicable, if discharges to a
POTW occur
Standards for pretreatment requirements for
sources to a POTW.
The specifications for the most appropriate
discharge method for effluent from remedial
activities will be developed during remedial design.
If remedial activities result in discharges to a
POTW, the discharge will be monitored and
treated, if necessary, to comply with these
regulations.
Hazardous Waste -
Facility Discharge
Standards
Massachusetts Supplemental
Requirements for Hazardous
Waste Management Facilities
MGL c. 21, §§ 26-53;
314 CMR 8.00
Applicable, if hazardous waste is
generated and surface water
discharge occurs
This regulation establishes additional requirements
that must be satisfied for a RCRA facility (a
wastewater treatment works which manages
hazardous waste) that has a wastewater discharge
permit.
Remedial activities that involve management of
hazardous waste prior to discharge to surface
waters will comply with these regulations.
Air Emissions
Massachusetts Ambient Air
Quality Standards
310 CMR 6.00
Applicable
These regulations establish primary and secondary
standards for emissions of sulfur dioxide,
particulate matter, carbon monoxide, ozone,
nitroqen dioxide, and lead.
Remedial activities will be implemented in
accordance with these regulations. Emission
standards, including for dust, will be complied with
durinq remedial activities.
Air Quality
Division of Air Quality Control
(DAQC)
DAQC Policy 90-001, re: Noise
Regulation,
To Be Considered
Guidance on sound emissions.
Remedial activities will comply with this guidance to
assess whether any remedial measures exceed
State noise guidance levels, and will follow the
suggested noise limit to the extent possible in
accordance with this guidance. Construction will be
scheduled during daylight hours.
Solid Waste
Massachusetts Solid Waste
Management Regulations
310 CMR 19.000
Applicable, if solid waste is
generated
This regulation establishes requirements for the
storage, transfer, processing, treatment, disposal,
use and reuse of solid waste (including asbestos),
including contracting for disposal or transport of
solid waste.
Any wastes generated by remedial activities that
are determined to not be hazardous wastes will be
managed in accordance with these regulations.
Air Emissions
Massachusetts Air Pollution
Control Regulations
310 CMR 7.00
Applicable
These regulations set emission limits necessary to
attain ambient air quality standards including
standards for visible emissions (7.06); dust, odor,
construction and demolition (7.09); noise (7.10);
and asbestos (7.15).
Remedial activities will be implemented in
accordance with these regulations. Emission
standards, including for dust, will be complied with
during these remedial activities.
Monitoring Wells
Massachusetts Standard
References for Monitoring Wells
WSC-310-91
To Be Considered
Guidance on locating, drilling, installing, sampling
and decommissioning monitoring wells
Monitoring wells that are required as part of
remedial activities will be installed, maintained, or
decommissioned in accordance with this guidance.
Page 4 of 5
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Table D-3
Action-Specific ARARs, Criteria, Advisories, and Guidance for LNAPL/SW-3
Record of Decision
Olin Chemical Superfund Site
Wilmington, Massachusetts
Action/Trigger
Requirement
Citation
Status
Requirement Synopsis
Action To Be Taken To Attain Requirement
Sediment/Erosion
Control; Stormwater
Management
Massachusetts Erosion and
Sediment Control Guidelines for
Urban and Suburban Areas
Prepared for Massachusetts
Executive Office of
Environmental Affairs (original
print March 1997; reprint May
2003)
To Be Considered
Guidance on preventing erosion and
sedimentation.
Design, construction, and operation of remedial
activities will be implemented in accordance with
this guidance.
Underground Injection
Massachusetts Underground
Injection Control Regulations
310 CMR 27.00
Applicable, if treated effluent is
injected underground
These regulations protect underground sources of
drinking water by regulating the underground
injection of hazardous wastes, fluids used for
extraction of minerals, oil, and energy, and any
other fluids having potential to contaminate
groundwater.
The specifications for the most appropriate
discharge method will be developed during
remedial design. If re-injection or infiltration of
treated water were to occur, construction and
operation of such re-injection or infiltration would
comply with these regulations.
Discharge of treated
groundwater to
groundwater
Massachusetts Groundwater
Discharge Permit Program
314 CMR 5.10 and 5.11
Relevant and Appropriate, if
treated effluent is injected
underground
These regulations require MassDEP to control the
discharge of pollutants to groundwaters of the
Commonwealth to assure that groundwaters are
protected for their actual and potential use as a
source of potable water and surface waters are
protected for their existing and designated uses.
The specifications for the most appropriate
discharge method will be developed during
remedial design. If treated effluent is discharged to
groundwater, the discharge will be controlled so
that groundwaters are protected for their actual and
potential use as a source of potable water and
surface waters are protected for their existing and
designated uses in accordance with the
substantive discharge standards.
Notes:
ARAR = Applicable or Relevant and Appropriate Requirement
CAA = Glean Air Act
CERCLA = Comprehensive Environmental Response, Compensation, and Liability Act
CFR = Code of Federal Regulations
CMR = Code of Massachusetts Regulations
DAPL = Dense Aqueous Phase Liquid
IDW = Investigation Derived Waste
MGL = Massachusetts General Law
MSWQS = Massachusetts Surface Water Quality Standards
NAPL = Non-Aqueous Phase Liquid
NESHAP = National Emission Standards for Hazardous Air Pollutant
NPDES = National Pollutant Discharge Elimination System
OSWER = Office of Solid Waste and Emergency Response
POTW = Publicly Owned Treatment Works
ppmw = parts per million by weight
RfD = reference dose
RCRA = Resource Conservation and Recovery Act
USC = United States Code
USEPA = United States Environmental Protection Agency
Page 5 of 5
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Table D-4
Location-Specific ARARs, Criteria, Advisories, and Guidance for LNAPL/SW-3
Record of Decision
Olin Chemical Superfund Site
Wilmington, Massachusetts
Location Characteristic
Requirement
Citation
Status
Requirement Synopsis
Action To Be Taken To Attain Requirement
Federal Standards
Fioodplains and Wetlands
Floodplain Management and
Protection of Wetlands
44 CFR Part 9 (implementing
Executive Orders 11988 and
11990)
Relevant and Appropriate
Federal Emergency Management Agency (FEMA)
regulations set forth the policy, procedure, and
responsibilities to implement and enforce Executive
Order 11988 (Floodplain Management) and Executive
Order 11990 (Protection of Wetlands). These
regulations prohibit activities that adversely affect a
federally-regulated wetland unless there is no
practicable alternative and the proposed action includes
all practicable measures to minimize harm to wetlands
that may result from such use. These regulations
require the avoidance of impacts associated with the
occupancy and modification of federally-designated
100-year and 500-year fioodplains and require the
avoidance of development within a floodplain wherever
there is a practicable alternative. An assessment of
impacts to the 500-year floodplain is required for critical
actions, which includes siting waste facilities in a
floodplain. These regulations require public notice when
proposing any action in or affecting fioodplains or
wetlands.
If there is no practicable alternative method to work in
federal jurisdictional wetlands, or 100-year or 500-year
floodplains, then all practicable measures will be taken
to minimize and mitigate any adverse impacts. Erosion
and sedimentation control measures will be adopted
during remedial activities to protect these wetlands and
floodplains. Remedial activities will comply with this
ARAR through appropriate avoidance, minimization,
mitigation and/or restoration. After completion of work
within the regulated 100-year and 500-year floodplains,
there will be no significant net loss of flood storage
capacity and no significant net increase in flood stage
or velocities. Floodplain habitat will be restored to the
extent practicable. Federal jurisdictional wetlands
altered by wetland soil and sediment excavation and
soil covers installed adjacent to such wetlands will be
restored in place.
Floodplains
RCRA Floodplain
Restrictions for
Hazardous
Waste Facilities
42 USC § 6901 etseq.;
40 CFR § 264.18(b)
Applicable, if hazardous waste
is managed within the 100-year
floodplain
A hazardous waste treatment, storage, or disposal
facility located in a 100-year floodplain must be
designed, constructed, operated, and maintained to
prevent washout or to result in no adverse effects on
human health or the environment if washout were to
occur.
To the extent any hazardous waste is generated during
the remedial activities, the waste will be managed so
that it will not impact floodplain resources.
Fioodplains
RCRA Floodplain
Restrictions for
Solid Waste Disposal Facilities
and Practices
40 CFR §257.3-1
Applicable, if solid waste is
managed within the 100-year
floodplain
Solid waste practices must not restrict the flow of a 100-
year flood, reduce the temporary water storage capacity
of the floodplain, or result in washout of solid waste, so
as to pose a hazard to human life, wildlife, or land or
water resources.
Any solid waste generated from during the remedial
action will be managed so that it will not impact
floodplain resources.
Wetlands, Aquatic Ecosystem
Clean Water Act (CWA) Section
404(b)(1) Guidelines for
Specification of Disposal Sites
for Dredged or Fill Material
33 USC § 1344(b)(1);
40 CFR Parts 230 & 231;
33 CFR Parts 320-323
Applicable
For discharge of dredged or fill material into water
bodies or wetlands, there must be no practicable
alternative with less adverse impact on aquatic
ecosystem; discharge cannot cause or contribute to
violation of state water quality standards or toxic effluent
standards or jeopardize threatened or endangered
species; discharge cannot significantly degrade waters
of U.S.; practicable steps must be taken to minimize and
mitigate adverse impacts; and impacts on flood level,
flood velocity, and flood storage capacity must be
evaluated. Sets standards for restoration and mitigation
required as a result of unavoidable impacts to aquatic
resources. EPA must determine which alternative is the
least environmentally damaging practicable alternative
to protect wetland and aquatic resources.
Remedial activities will comply with this ARAR through
appropriate avoidance, minimization, mitigation and/or
restoration. Under these alternatives, groundwater
extraction wells and conveyance piping will impact
federal jurisdictional wetlands. The remedial activities
will be conducted in accordance with these
requirements including, but not limited to, appropriate
avoidance, minimization, mitigation, and/or restoration.
EPA has determined that the selected remedial
alternative is the least environmentally damaging
practicable alternative because (a) there is no
practicable alternative method that will achieve cleanup
objectives with less adverse impact and (b) all
practicable measures would be taken to minimize and
mitigate any adverse impacts from the work.
Wetlands
U.S. Army Corps of Engineers,
New England
District Compensatory Mitigation
Guidance (09-07-2016)
To Be Considered
This guidance is to be considered when compensatory
mitigation to address impacts to federal jurisdictional
wetlands is appropriate for a particular remedial activity.
Remedial activities may impact federal jurisdictional
wetlands. Activities affecting federal jurisdictional
wetlands will be conducted in accordance with these
guidance standards for mitigation and restoration.
Page 1 of 3
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Table D-4
Location-Specific ARARs, Criteria, Advisories, and Guidance for LNAPL/SW-3
Record of Decision
Olin Chemical Superfund Site
Wilmington, Massachusetts
Location Characteristic
Requirement
Citation
Status
Requirement Synopsis
Action To Be Taken To Attain Requirement
Surface Waters,
Wetland/Waterway Habitat for
Endangered Species, Migratory
Species
Fish and Wildlife Coordination
Act
16 USC §661 etseq.;
40 CFR § 6.302(g)
Applicable
Requires that any federal agency proposing to modify a
body of water must consult with the U.S. Fish and
Wildlife Service, National Marine Fisheries Service, and
other related state agencies to prevent, mitigate, or
compensate for project-related losses of or damage to
endangered species, fish and wildlife resources.
Remedial activities will be designed and implemented
to prevent and mitigate project related impacts to fish
and wildlife. Consultation with appropriate agencies will
be maintained during planning and implementation of
remedial activities that may alter protected resource
area to ensure that losses of or damage to habitat and
wildlife will be prevented, mitiqated, or compensated.
Endangered Species
Endangered Species Act
16 U.S.C. §§1531 etseq.;
60 CFR §§ 17.11-17.12;
50 CFR Part 402
Applicable, if endangered
species are encountered
This act requires action to avoid jeopardizing the
continued existence of listed endangered or threatened
species or modification of their habitat.
No known endangered or threatened species have
been identified in the vicinity of the Site. If such species
or habitats in the remedial areas are identified,
remedial activities would be designed and implemented
to avoid effects endangered or threatened species or
their habitats.
Historical/ Archeological
Resources
National Historic Preservation
Act
54 USC §§ 300101 etseq.;
36 CFR Part 800
Applicable, if subject historical
resources are present
Pursuant to Section 106 of the NHPA, CERCLA
response actions are required to take into account the
effects of the response activities on any historic property
(any prehistoric or historic district, site, building,
structure, or object included in, or eligible for inclusion
in, the National Register of Historic Places, which would
be significant in American history, architecture,
archeology, engineering, and culture) and to resolve any
adverse effects, including avoidance, minimization, or
mitiqation of the adverse effects.
No protected resources are known to exist in the East
and South Ditch Stream areas and LNAPL area. If
protected resources are identified in the remedial area,
federal and state preservation officials would be
consulted to address measures to avoid, minimize
and/or mitigate any impacts to these protected
resources.
Atlantic Flyway
Migratory Bird Treaty Act
16 USC §703 etseq.
Applicable, if subject protected
species are present
Protects migratory birds, their nests and eggs. A
depredation permit issued by the U.S. Fish and Wildlife
Service is required to take, possess, or transport
migratory birds or disturb their nests, eggs, or young.
Remedial activities will be evaluated to protect
migratory birds, their nests, and eggs. If migratory bird
protected areas are identified within the remedial area,
measures to avoid, minimize and/or mitigate any
impacts to protected resource areas will be
implemented in consultation with appropriate agencies.
State Standards
Floodplains, Wetlands, Surface
Waters
Massachusetts Wetland
Protection Act and Regulations
MGLc. 131, §40;
310 CMR 10.00
Applicable if alternative alters
wetlands or floodplains
These regulations restrict dredging, filling, altering, or
polluting inlaid wetland resource areas (defined as
areas within the 100-year floodplain) and buffer zones
(100 feet of a vegetated wetland or 200 feet from a
perennial stream), and impose performance standards
for work in such areas. Protected resource areas
include: 10.54 (Bank); 10.55 (Bordering Vegetated
Wetlands); 10.56 (Land under Water Bodies and
Waterways); 10.57 (Land Subject to Flooding); and
10.58 (Riverfront Area).
Remedial activities will occur in/adjacent to wetlands
and floodplains, and, if state regulated wetlands or
floodplains will be altered, the remedial activities will
comply with this ARAR through appropriate avoidance,
minimization, mitigation, and restoration. Any remedial
activity conducted within 100 feet of a state regulated
wetland resource area or 200 feet from a perennial
stream will comply with the substantive requirements of
these regulations. Mitigation of impacts on state
wetland resource areas will be addressed. All remedial
work within any regulated floodplain will result in no net
loss of flood storage capacity and no net increase in
flood stage or velocities. Floodplain habitat will be
restored, to the extent practicable.
Floodplains
Massachusetts Hazardous
Waste Regulations, Location
Standards for Land Subject to
Flooding
310CMR 30.701
Applicable, if hazardous waste
is managed within a flood plain
This regulation sets forth criteria for siting hazardous
waste facilities within land subject to flooding (as
defined under the Massachusetts Wetland Protection
Act standards). Any new or expanded hazardous waste
storage or treatment facility (which only receives
hazardous waste from on-site sources), the active
portion of which is located within the boundary of land
subject to flooding from the statistical 100-year
frequency storm, shall be flood-proofed. Flood-proofing
shall be designed, constructed, operated, and
maintained to prevent floodwaters from coming into
contact with hazardous waste.
To the extent any hazardous waste is generated during
the remedial activities, the waste will be managed so
that it will not impact floodplain resources.
Page 2 of 3
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Table D-4
Location-Specific ARARs, Criteria, Advisories, and Guidance for LNAPL/SW-3
Record of Decision
Olin Chemical Superfund Site
Wilmington, Massachusetts
Location Characteristic
Requirement
Citation
Status
Requirement Synopsis
Action To Be Taken To Attain Requirement
Wetlands, Aquatic Ecosystem
Massachusetts Clean Water Act;
Massachusetts Water Quality
Certification for Discharge of
Dredged or Fill Material
MGL c. 21, §§ 26-53;
314 CMR 9.00
Applicable, if alternative
involves filling of wetlands
For discharges of dredged or fill material, there must be
no practicable alternative with less adverse impact on
the aquatic ecosystem; appropriate and practicable
steps must be taken to avoid and minimize potential
adverse impacts to wetlands and land under water;
stormwater discharges must be controlled with BMPs;
and there must not be substantial adverse impacts to
the physical, chemical, or biological integrity of surface
waters. For dredging and dredged material
management, there must be no practicable alternative
with less adverse impact on the aquatic ecosystem; and
if avoidance is not possible, then minimize, or if neither
avoidance nor minimization are possible, then mitigate
potential adverse impacts
The effects of remedial activities on the aquatic
ecosystem will be evaluated and avoided, and/or
minimized. Compensatory mitigation will need to be
performed as necessary to comply with this ARAR
through appropriate avoidance, minimization, mitigation
and/or restoration. EPA has determined that the
selected final LNAPL-SW action is the least
environmentally damaging practicable alternative
because (a) there is no practicable alternative method
that will achieve cleanup objectives with less adverse
impact and (b) all practicable measures would be taken
to minimize and mitigate any adverse impacts from the
work.
Endangered Species
Massachusetts Endangered
Species Regulations
321 CMR 10.00
Applicable, if endangered
species are encountered
Requires action to regulate the impact to state listed
endangered or threatened species or their habitats.
Actions must be conducted in a manner that minimizes
the impact to M assa chu setts -I isted rare, threatened, or
endangered species, and species listed by the
Massachusetts Natural Heritaqe Proqram.
No known endangered or threatened species or their
habitats have been identified in the vicinity of the Site.
If such species or habitats in the remedial areas are
identified, remedial activities would be designed and
implemented to avoid affects endangered or threatened
species or their habitats.
Historical/
ArcheologicalResources
Massachusetts Antiquities Act;
Massachusetts Historical
Commission Regulations;
Protection of Properties Included
in the State Register of Historic
Places
MGL c. 9, §§ 26-27C;
950 CMR 70.00 and 71.00
Applicable, if subject historical
resources are present.
Projects must eliminate, limit, or mitigate adverse effects
to properties listed in the State Register of Historic
Places (historic and archaeological properties).
Establishes coordination with the National Historic
Preservation Act.
No protected resources are known to exist in the East
and South Ditch Stream areas and LNAPL area. If
protected resources are identified in the remedial area,
federal and state preservation officials would be
consulted to address measures to avoid, minimize
and/or mitigate any impacts to these protected
resources.
Area of Critical Environmental
Concern
Massachusetts Areas of Critical
Environmental Concern (ACECs)
Regulations
301 CMR 12.00
Applicable, if ACEC is identified
An ACEC is of regional, state, or national importance or
contains significant ecological systems with critical
interrelationships among a number of components. An
eligible area must contain features from four or more of
the following groups: (1) fisheries, (2) coastal features,
(3) estuarine wetlands, (4) inland wetlands, (5) inland
surface waters, (6) water supply areas (e.g., aquifer
recharge area); (7) natural hazard areas (e.g.,
floodplain); (8) agricultural areas; (9)
historical/archeological resources; (10) habitat
resources (e.g., for endangered wildlife); or (11) special
use areas. After an area is designated as an ACEC, the
aim is to preserve and restore these areas.
No known ACEC has been identified at the Site, if an
ACEC is identified in the remediation area, remedial
activities will be controlled to minimize impacts to
affected species or resources.
Notes:
ACEC = Area of Critical Environmental Concern
ARAR = Applicable or Relevant and Appropriate Requirement
BMP = Best Management Practice
CFR = Code of Federal Regulations
CMR = Code of Massachusetts Regulations
CWA = Clean Water Act
EPA = United States Environmental Protection Agency
FEMA = Federal Emergency Management Agency
MGL = Massachusetts General Law
PRB = Permeable Reactive Barrier
RCRA = Resource Conservation and Recovery Act
USC = United States Code
USFWS = United States Fish and Wildlife Service
Page 3 of 3
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Table D-5
Action-Specific ARARs, Criteria, Advisories, and Guidance for Soil/Sed-2
Record of Decision
Olin Chemical Superfund Site
Wilmington, Massachusetts
Action/Trigger | Requirement j Citation | Status | Requirement Synopsis | Action To Be Taken To Attain Requirement
Federal Standards
Municipal Solid
Waste Landfills
RCRA Subtitle D; Criteria for
Municipal Solid Waste Landfills
40CFR Part 258, Subpart F
Relevant and Appropriate
Federal standards for non-hazardous solid waste
landfills. Subpart F provides closure (including
design requirements for a final cover system) and
post-closure care requirements.
The Containment Area will be capped and closed in
accordance with these requirements.
Hazardous Waste
Treatment,
Storage, Disposal
Resource Conservation and
Recovery Act (RCRA) Subtitle C;
Hazardous Waste Identification;
Generator Requirements;
Tracking Requirements;
Treatment, Storage and Disposal
Requirements; Groundwater
Monitoring Requirements;
Closure and Post Closure
Requirements
42 USC § 6901 et seq.;
40 CFR Parts 260-262, Part 264
Applicable, if hazardous waste is
generated
Federal standards used to identify, manage, and
dispose of hazardous waste. Massachusetts has
been delegated the authority to administer these
RCRA standards through its state hazardous waste
management regulations.
Any wastes generated during remedial activities, including
excavation of wetland soil and sediment, dewatering and
any related treatment, closure of the Containment Area
equalization window, construction and O&M of the
Containment Area cap and soil cover systems, any
implementation of building vapor mitigation measures, pre-
design investigation, and monitoring activity, will be
analyzed under these standards to determine whether they
are listed or characteristic hazardous waste. Non-hazardous
wastes will be disposed of appropriately. Any generation,
treatment, or storage of hazardous waste will comply with
these requlations.
Hazardous Waste
- Landfills
RCRA Subtitle C; Hazardous
Waste Landfill Standards
40 CFR Part 264, Subpart N
Relevant and Appropriate, if
hazardous waste is determined
to have been disposed of in the
Containment Area
Federal standards for hazardous waste landfills.
Subpart N provides closure (including design
requirements for a final cover system) and post-
closure care requirements.
Based on available data, hazardous waste is not expected
to be present in the Containment Area. If hazardous waste
is determined to have been disposed of in the Containment
Area, it will be capped and closed in accordance with these
requlations.
Hazardous Waste
- Surface
Impoundments
RCRA Subtitle C; Hazardous
Waste Surface Impoundment
Standards
40 CFR Part 264, Subpart K
Relevant and Appropriate, if
hazardous waste is determined
to have been disposed of in the
Containment Area
Federal standards for hazardous waste surface
impoundments. Subpart K provides closure
(including design requirements for a final cover
system) and post-closure care requirements.
Based on available data, hazardous waste is not expected
to be present in the Containment Area. If hazardous waste
is determined to have been disposed of in the Containment
Area, it will be capped and closed in accordance with these
requlations.
Hazardous Waste
- Air Emissions
RCRA, Air Emission Standards
for Process Vents; Equipment
Leaks; Tanks, Surface
Impoundments, and Containers
40 CFR Part 264, Subparts AA,
BB, and CC
Applicable, if hazardous wastes:
with volatile organic
concentrations of at least 10
parts per million by weight
(ppmw) will be managed by
process vents (Subpart AA); with
organic concentrations of at least
10% by weight will be managed
by equipment (Subpart BB); or
with average VOC
concentrations of 500 ppm or
greater will be managed in tanks,
surface impoundments, or
containers, (Subpart CC).
Relevant and Appropriate, if
organics less than thresholds or
for non-hazardous waste.
RCRA emissions standards not delegated to the
State. Standards for process vents for systems that
manage hazardous wastes that have organic
concentrations of at least 10 ppmw. Standards for
air equipment leaks for systems that manage
hazardous wastes with organic concentrations of at
least 10% by weight. Standards for tanks, surface
impoundments, and containers that manage
hazardous wastes with average VOC
concentrations of 500 ppm or greater.
No hazardous waste generated by remedial activities,
including excavation of wetland soil and sediment,
dewatering and any related treatment, closure of the
Containment Area equalization window, construction and
O&M of the Containment Area cap and soil cover systems,
any implementation of building vapor mitigation measures,
pre-design investigation, and monitoring activity, is expected
to have concentrations over the applicability thresholds.
Management of VOCs in excavated soil and sediment and
in any implemented building vapor mitigation measures will
be in accordance with these air emission regulations.
Air Emissions
Clean Air Act (CAA), Hazardous
Air Pollutants; National Emission
Standards for Hazardous Air
Pollutants (NESHAP)
42 USC§ 112(b)(1);
40 CFR Part 61
Applicable
These regulations establish emissions standards
for 189 hazardous air pollutants.
Remedial activities, including excavation of wetland soil and
sediment, dewatering and any related treatment, closure of
the Containment Area equalization window, construction
and O&M of the Containment Area cap and soil cover
systems, any implementation of building vapor mitigation
measures, pre-design investigation, and monitoring activity,
will be implemented in accordance with these rules. No air
emissions from remedial activities will cause air quality
standards to be exceeded. Dust standards will be complied
with during remedial activities.
Page 1 of 6
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Table D-5
Action-Specific ARARs, Criteria, Advisories, and Guidance for Soil/Sed-2
Record of Decision
Olin Chemical Superfund Site
Wilmington, Massachusetts
Action/Trigger
Requirement
Citation
Status
Requirement Synopsis
Action To Be Taken To Attain Requirement
Discharges to
Surface Water;
Storm Water
Controls
Clean Water Act; National
Pollutant Discharge Elimination
System (NPDES)
40CFR Parts 122 and 125
Applicable (and if surface water
discharge occurs, discharge
standards are also applicable)
These requirements include storm water standards
for construction activities disturbing more than one
acre and requirements for stormwater discharges
from hazardous waste treatment, storage, and
disposal facilities. These requirements also specify
the permissible concentration or level of
contaminants in the discharge from any point
source to waters of the United States.
Best management practices will be used to control and
manage stormwater runoff during remedial activities,
including excavation of wetland soil and sediment,
dewatering and any related treatment, closure of the
Containment Area equalization window, construction and
O&M of the Containment Area cap and soil cover systems,
any implementation of building vapor mitigation measures,
pre-design investigation, and monitoring activity. The
discharge of treated effluent from remedial activities,
including from dewatering, to a surface water will meet the
substantive discharge standards (the Massachusetts
Surface Water Discharge Permit Program [314 CMR 3.00]
has similar requirements).
Discharge to a
Publicly Owned
Treatment Works
(POTW)
Genera! Pretreatment
Regulations for Existing and New
Sources of Pollution
40 CFR Part 403
Applicable, if discharge to a
POTW occurs
Standards for discharge into a Publicly
Owned Treatment Works (POTW).
The specifications for the most appropriate discharge
method for effluent from remedial activities, including from
dewatering, will be developed during remedial design. If
effluent from remedial activities, including from dewatering,
is discharged to a POTW, the discharge will be monitored
and treated, if necessary, to comply with these regulations.
Underground
Injection
SDWA Underground Injection
Control (UIC) Program
40 CFR Parts 144,146, and 147
(including Subpart W)
Applicable, if treated effluent is
injected underground
These regulations outline minimum program and
performance standards for the UIC program.
Technical criteria and standards for siting,
operating, closure, and post-closure are set forth in
Part 146.
The specifications for the most appropriate discharge
method for effluent from remedial activities, including from
dewatering, will be developed during remedial design. If
effluent from remedial activities, including from dewatering,
is injected underground, the underground injection will be
monitored and treated, if necessary, to comply with these
regulations.
Sediment
Remediation
Contaminated Sediment
Remediation Guidance for
Hazardous Waste Sites
EPA-540-R-05-012; OSWER
9355.0-85 (December 2005)
To Be Considered
Guidance for making remedy decisions for
contaminated sediment sites. Some of the relevant
sections of the guidance address Remedial
Investigations (Ch. 2), FS Considerations (Ch. 3),
Monitored Natural Recovery (Ch. 4), In-Situ
Capping (Ch. 5), and Dredging and Excavation
(Ch. 6).
Chromium- and/or BEHP-impacted wetland soil and
sediments will be excavated in accordance with this
guidance to a depth of approximately one foot below ground
surface and disposed of off-site. Pre-design investigations
will include sample analysis to confirm the limits in wetiand
soil and sediments that require remediation.
Investigation-
Derived Waste
(IDW)
Guide to Management of
Investigation-Derived Wastes
USEPA OSWER Publication
9345.3-03FS, January 1992
To Be Considered
Guidance on management of IDW in a manner that
ensures protection of human health and the
environment.
IDW generated as part of remedial activities, including
excavation of wetland soil and sediment, closure of the
Containment Area equalization window, construction of the
Containment Area cap and soil cover systems, any
implementation of building vapor mitigation measures, and
pre-design investigation, will be managed in accordance
with quidance from this publication.
Vapor Intrusion
OSWER Technical Guide for
Assessing and Mitigating the
Vapor Intrusion Pathway from
Subsurface Vapor Sources to
Indoor Air
OSWER Publication 9200.2-154
(June 2015)
To Be Considered
This EPA guidance establishes a methodology for
assessing potential indoor air risks to human health
that may result from volatilization of contaminants
from groundwater and soil vapor into an overlying
building, using multiple lines of evidence.
Site-specific vapor intrusion performance standards derived
considering this guidance will be used to ensure that the
remedial activities, including any implementation of building
vapor mitigation measures, prevent unacceptable risks due
to vapor intrusion. Any implemented mitigation measures
such as vapor barriers or SSDSs for new building
construction or building alterations on the Property will be
monitored to ensure their protectiveness. Institutional
controls pertaining to vapor intrusion will be implemented
and maintained utilizing these guidance standards until such
time as it is determined they are no longer needed.
Vapor Intrusion
EPA Vapor Intrusion Screening
Level (VISL) Calculator
To Be Considered
EPA developed the VISLs as numerical screening
levels to identify areas or buildings that may
warrant further investigation of the vapor intrusion
pathway.
VISLs were compared to shallow groundwater data as
screening tool for evaluating vapor intrusion risk.
Page 2 of 6
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Table D-5
Action-Specific ARARs, Criteria, Advisories, and Guidance for Soil/Sed-2
Record of Decision
Olin Chemical Superfund Site
Wilmington, Massachusetts
Action/Trigger | Requirement j Citation j Status | Requirement Synopsis | Action To Be Taken To Attain Requirement
State Standards
Hazardous Waste
identification
Massachusetts Hazardous
Waste Management Rules for
Identification and Listing of
Hazardous Wastes
310 CMR 30.100
Applicable, if hazardous waste is
generated
Massachusetts is delegated to administer RCRA
through its state regulations. These regulations
establish requirements for determining whether
wastes are either listed or characteristic hazardous
waste.
These Massachusetts regulations supplement federal RCRA
requirements. Any wastes generated during remedial
activities, including excavation of wetland soil and sediment,
dewatering and any related treatment, closure of the
Containment Area equalization window, construction and
O&M of the Containment Area cap and soil cover systems,
any implementation of building vapor mitigation measures,
pre-design investigation, and monitoring activity, will be
analyzed under these regulations to determine whether they
are listed or characteristic hazardous wastes. Hazardous
and nonhazardous wastes will be managed and disposed of
appropriately.
Hazardous Waste
- Generator
Standards
Massachusetts Hazardous
Waste Rules - Requirements for
Generators
310 CMR 30.300
Applicable, if hazardous waste is
generated
These regulations contain requirements for
hazardous waste generators. The regulations apply
to generators of sampling waste and also apply to
the accumulation of waste prior to off-site disposal.
Any hazardous waste generated by remedial activities,
including excavation of wetland soil and sediment,
dewatering and any related treatment, closure of the
Containment Area equalization window, construction and
O&M of the Containment Area cap and soil cover systems,
any implementation of building vapor mitigation measures,
pre-design investigation, and monitoring activity, will be
manaqed in accordance with these requiations.
Hazardous Waste
- Management
Facility Standards
Massachusetts Hazardous
Waste Rules - Management
Standards for All Hazardous
Waste Facilities
310 CMR 30.500
Applicable, if hazardous waste is
generated
General facility requirements for waste analysis,
security measures, inspections, and training
requirements. Section 30.580 addresses closure.
Section 30.590 addresses post-closure of
hazardous waste facilities. Section 30.513 requires
a general waste analysis of any hazardous waste.
Any hazardous waste generated by remedial activities,
including excavation of wetland soil and sediment,
dewatering and any related treatment, closure of the
Containment Area equalization window, construction and
O&M of the Containment Area cap and soil cover systems,
any implementation of building vapor mitigation measures,
pre-design investigation, and monitoring activity, will be
manaqed in accordance with these requiations.
Hazardous Waste
-Technical
Facility Standards
Massachusetts Hazardous
Waste Rules - Technical
Standards for All Hazardous
Waste Facilities
310 CMR 30.600
Applicable, if hazardous waste is
managed
Standards for the design, performance, operation,
maintenance, and monitoring of hazardous waste
facilities, including miscellaneous units.
Any hazardous waste generated by remedial activities,
including excavation of wetland soil and sediment,
dewatering and any related treatment, closure of the
Containment Area equalization window, construction and
O&M of the Containment Area cap and soil cover systems,
any implementation of building vapor mitigation measures,
pre-design investigation, and monitoring activity, will be
manaqed in accordance with these requiations.
Hazardous Waste
- Wastewater
Treatment
Massachusetts Hazardous
Waste Rules - Special
Requirements for Wastewater
Treatment Units
310 CMR 30.605
Applicable, if hazardous waste is
managed in a WWTU
This regulation establishes standards for
wastewater treatment units WWTUs) for the
treatment of hazardous waste
If remedial activities, including excavation of wetland soil
and sediment, dewatering and any related treatment,
closure of the Containment Area equalization window,
construction and O&M of the Containment Area cap and soil
cover systems, any implementation of building vapor
mitigation measures, pre-design investigation, and
monitoring activity, generate hazardous waste that is
managed in a WWTU, the WWTU will comply with these
requiations.
Hazardous Waste
- Surface
Impoundments
Massachusetts Hazardous
Waste Rules - Surface
Impoundments
310 CMR 30.610
Relevant and Appropriate, if
hazardous waste is determined
to have been disposed of in the
Containment Area
310 CMR 30.611 through 30.618 prescribe
requirements for storage, treatment, and disposal
of hazardous waste in surface impoundments.
Provides specifications for inter alia design and
operations, testing, monitoring and inspection, and
closure and post-closure care.
Based on available data, hazardous waste is not expected
to be present in the Containment Area. If hazardous waste
is determined to have been disposed of in the Containment
Area, it will be capped and closed in accordance with these
regulations.
Page 3 of 6
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Table D-5
Action-Specific ARARs, Criteria, Advisories, and Guidance for Soil/Sed-2
Record of Decision
Olin Chemical Superfund Site
Wilmington, Massachusetts
Action/Trigger
Requirement
Citation
Status
Requirement Synopsis
Action To Be Taken To Attain Requirement
Hazardous Waste
- Landfills
Massachusetts Hazardous
Waste Rules - Landfills
310 CMR 30.620
Relevant and Appropriate, if
hazardous waste is determined
to have been disposed of in the
Containment Area
310 CMR 30.621 through 30.633 prescribe
requirements for disposal of hazardous waste in
landfills. Provides specifications for inter alia design
and operations, monitoring and inspection, and
closure and post-closure care.
Based on available data, hazardous waste is not expected
to be present in the Containment Area. If hazardous waste
is present in the Containment Area, it will be capped and
closed in accordance with these regulations.
Hazardous Waste
- Waste Piles
Massachusetts Hazardous
Waste Rules - Waste Piles
310 CMR 30.640
Applicable, if hazardous waste is
managed in waste piles
310 CMR 30.641 through 30.649 prescribe
requirements for storage and treatment of
hazardous waste in waste piles. Provides
specifications for inter alia design and operations,
monitoring and inspection, and closure and post-
closure care.
Any hazardous waste generated by remedial activities,
including excavation of wetland soil and sediment, closure of
the Containment Area equalization window, construction
and O&M of the Containment Area cap and soil cover
systems, and any implementation of building vapor
mitigation measures, that is managed in a waste pile will
comply with these requlations.
Hazardous Waste
- Groundwater
Massachusetts Hazardous
Waste Rules - Groundwater
Protection
310 CMR 30.660
Applicable, if hazardous waste is
managed in a regulated unit
310 CMR 30.661 through 30.673 prescribe
requirements for regulated units that receive
hazardous waste, except for certain waste piles, to
protect groundwater.
Any hazardous waste generated by remedial activities,
including excavation of wetland soil and sediment, closure of
the Containment Area equalization window, construction
and O&M of the Containment Area cap and soil cover
systems, and any implementation of building vapor
mitigation measures, will be managed to prevent
contaminant migration to groundwater. Any management of
hazardous waste in a subject waste pile will comply with
these regulations.
Hazardous Waste
- Containers
Massachusetts Hazardous
Waste Rules - Use and
Management of Containers
310 CMR 30.680
Applicable, if hazardous waste is
containerized
310 CMR 30.681 through 30.689 prescribe
requirements for the use of containers, such as
drums, to store hazardous waste. Provides
specifications for inter alia labelling and marking,
management of containers, inspections, and
closure.
Any hazardous waste generated by remedial activities,
including excavation of wetland soil and sediment,
dewatering and any related treatment, closure of the
Containment Area equalization window, construction and
O&M of the Containment Area cap and soil cover systems,
any implementation of building vapor mitigation measures,
pre-design investigation, and monitoring activity, that is
managed in containers will comply with these regulations.
Hazardous Waste
- Tanks
Massachusetts Hazardous
Waste Rules - Storage and
T"reatrnent in Tanks
310 CMR 30.690
Applicable, if hazardous waste is
stored and/or transported in
tanks
310 CMR 30.691 through 30.699 prescribe
requirements for the use of tanks to store and treat
hazardous waste. Provides specifications for inter
alia design and installation, containment and
detection of leaks, general operating requirements,
inspections, and closure and post-closure care.
Any hazardous waste generated by remedial activities,
including excavation of wetland soil and sediment,
dewatering and any related treatment, closure of the
Containment Area equalization window, construction and
O&M of the Containment Area cap and soil cover systems,
any implementation of building vapor mitigation measures,
pre-design investigation, and monitoring activity, that is
manaqed in tanks will comply with these requlations.
Discharges to
Surface Waters
Massachusetts Clean Water Act;
Surface Water Discharge Permit
Regulations
MGL c. 21, §§ 26-53;
314 CMR 3.00
Applicable, if surface water
discharge occurs
These regulations require that discharges to waters
of the Commonwealth shall not result in
exceedances of Massachusetts Surface Water
Quality Standards (MSWQS) (314 CMR 4.00).
Any water discharged to surface waters from remedial
activities, including from dewatering, will be treated to meet
the substantive discharge standards.
Discharges to
Surface Water
Massachusetts Clean Water Act;
MA Surface Water Quality
Standards (MSWQS)
MGL c. 21, §§ 26-53;
314 CMR 4.00
Applicable, if surface water
discharge occurs
These standards designate the most sensitive uses
for which the various waters of the Commonwealth
shall be enhanced, maintained, or protected.
Minimum water quality criteria required to sustain
the desiqnated uses are established.
Any water discharged to surface waters from remedial
activities, including from dewatering, will be treated to meet
the substantive discharge standards.
Hazardous Waste
Discharge
Standards
Massachusetts Supplemental
Requirements for Hazardous
Waste Management Facilities
MGL c. 21, §§ 26-53;
314 CMR 8.00
Applicable, if hazardous waste is
generated and surface water
discharge occurs
This regulation establishes additional requirements
that must be satisfied for a RCRA facility (a
wastewater treatment works which manages
hazardous waste) that has a wastewater discharge
permit.
Remedial activities, including excavation of wetland soil and
sediment, closure of the Containment Area equalization
window, construction and O&M of the Containment Area cap
and soil cover systems, any implementation of building
vapor mitigation measures, pre-design investigation, and
monitoring activity, that involve management of hazardous
waste prior to discharge will comply with these requlations.
Page 4 of 6
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Table D-5
Action-Specific ARARs, Criteria, Advisories, and Guidance for Soil/Sed-2
Record of Decision
Olin Chemical Superfund Site
Wilmington, Massachusetts
Action/Trigger
Requirement
Citation
Status
Requirement Synopsis
Action To Be Taken To Attain Requirement
Discharge to
Publicly Owned
Treatment Works
(POTW)
Massachusetts Operation,
Maintenance and Pretreatment
Standards for Wastewater
Treatment Works and Indirect
Dischargers
314 CMR 12.00
Applicable, if discharges to a
POTW occur
Standards for pretreatment requirements for
sources to a POTW.
The most appropriate discharge method for the treated
effluent from remedial activities, including from dewatering,
will be developed during remedial design. If effluent from
remedial activities, including from dewatering, is discharged
to a POTW, the discharge will be monitored and treated, if
necessary, to comply with these requlations.
Discharge of
treated
groundwater to
groundwater
Massachusetts Groundwater
Discharge Permit Program
314 CMR 5.10 and 5.11
Relevant and Appropriate, if
treated effluent is injected
underground
These regulations require MassDEP to control the
discharge of polutants to groundwaters of the
Commonwealth to assure that groundwaters are
protected for their actual and potential use as a
source of potable water and surface waters are
protected for their existing and designated uses.
The most appropriate discharge method for the treated
effluent from remedial activities, including from dewatering,
will be developed during remedial design. If effluent from
remedial activities, including from dewatering, is discharged
to groundwater, the discharge will be controlled so that
groundwaters are protected for their actual and potential use
as a source of potable water and surface waters are
protected for their existing and designated uses in
accordance with the substantive discharqe standards.
Underground
Injection
Massachusetts Underground
Injection Control Regulations
310 CMR 27.00
Applicable, if treated effluent is
injected underground
These regulations protect underground sources of
drinking water by regulating the underground
injection of hazardous wastes, fluids used for
extraction of minerals, oil, and energy, and any
other fluids having potential to contaminate
groundwater.
The most appropriate discharge method for the treated
effluent from remedial activities, including from dewatering,
will be developed during remedial design. If effluent from
remedial activities, including from dewatering, is injected
underground or infiltrated, construction and operation of
such re-injection or infiltration would comply with these
requlations.
Solid Waste
Massachusetts Solid Waste
Management Regulations
310 CMR 19.000
Applicable, if solid waste is
generated
This regulation establishes requirements for the
storage, transfer, processing, treatment, disposal,
use and reuse of solid waste (including asbestos),
including contracting for disposal or transport of
solid waste.
Any wastes generated by remedial activities, including
excavation of wetland soil and sediment, dewatering and
any related treatment, closure of the Containment Area
equalization window, construction and O&M of the
Containment Area cap and soil cover systems, any
implementation of building vapor mitigation measures, pre-
design investigation, and monitoring activity, that are
determined to not be hazardous wastes will be managed in
accordance with these requlations.
Solid Waste
Massachusetts Solid Waste
Management Regulations,
Landfill design and operational
standards
310 CMR 19.100
Relevant and Appropriate
Regulations establishing minimum performance
and design standards; operation and maintenance
standards; and closure/post-closure requirements
for solid waste landfills.
The Containment Area will be capped and closed in
accordance with these requirements.
Air Emissions
Massachusetts Ambient Air
Quality Standards
310 CMR 6.00
Applicable
These regulations establish primary and secondary
standards for emissions of sulfur dioxide,
particulate matter, carbon monoxide, ozone,
nitrogen dioxide, and lead.
Remedial activities, including excavation of wetland soil and
sediment, dewatering and any related treatment, closure of
the Containment Area equalization window, construction
and O&M of the Containment Area cap and soil cover
systems, and any building vapor mitigation measures, will
be implemented in accordance with these regulations.
Emission standards, including for dust, will be complied with
durinq remedial activities
Air Emissions
Massachusetts Air Pollution
Control Regulations
310 CMR 7.00
Applicable
These regulations set emission limits necessary to
attain ambient air quality standards including
standards for visible emissions (7.06); dust, odor,
construction and demolition (7.09); noise (7.10);
and asbestos (7.15).
Remedial activities, including excavation of wetland soil and
sediment, dewatering and any related treatment, closure of
the Containment Area equalization window, construction
and O&M of the Containment Area cap and soil cover
systems, and any building vapor mitigation measures, will
be implemented in accordance with these regulations.
Emission standards, including for dust, wili be complied with
during these remedial activities.
Page 5 of 6
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Table D-5
Action-Specific ARARs, Criteria, Advisories, and Guidance for Soil/Sed-2
Record of Decision
Olin Chemical Superfund Site
Wilmington, Massachusetts
Action/Trigger
Requirement
Citation
Status
Requirement Synopsis
Action To Be Taken To Attain Requirement
Sediment/Erosion
Control;
Stormwater
Management
Massachusetts Erosion and
Sediment Control Guidelines for
Urban and Suburban Areas
Prepared for Massachusetts
Executive Office of
Environmental Affairs (original
print March 1997; reprint May
2003)
To Be Considered
Guidance on preventing erosion and
sedimentation.
Design, construction, and operation of remedial activities,
including excavation of wetland soil and sediment,
dewatering and any related treatment, closure of the
Containment Area equalization window, construction and
Q&M of the Containment Area cap and soil cover systems,
and any building vapor mitigation measures, will be
implemented in accordance with this guidance.
Monitoring Wells
Massachusetts Standard
References for Monitoring Wells
WSC-310-91
To Be Considered
Guidance on locating, drilling, installing, sampling
and decommissioning monitoring wells
Monitoring wells that are required as part of remedial
activities will be installed, maintained, or decommissioned in
accordance with this quidance.
Air Quality
Division of Air Quality Control
(DAQC)
DAQC Policy 90-001, re: Noise
Regulation,
To Be Considered
Guidance on sound emissions.
Remedial activities, including the excavation of wetland soil
and sediment, dewatering and any related treatment,
closure of the Containment Area equalization window,
construction and O&M of the Containment Area cap and soil
cover systems, and any implemented building vapor
mitigation measures, will comply with this guidance to
assess whether any remedial measures exceed State noise
guidance levels, and will follow the suggested noise limit to
the extent possible in accordance with this guidance.
Construction will be scheduled during daylight hours.
Notes:
ARAR = Applicable or Relevant and Appropriate Requirement
CERCLA = Comprehensive Environmental Response, Compensation, and Liability Act
CFR = Code of Federal Regulations
CMR = Code of Massachusetts Regulations
DEP = Department of Environmental Protection
IDW = Investigation Derived Waste
MGL = Massachusetts General Law
NPDES = National Pollutant Discharge Elimination System
OSWER = Office of Solid Waste and Emergency Response
POTW = Publicly Owned Treatment Works
ppmw = parts per million by weight
RCRA = Resource Conservation and Recovery Act
USC = United States Code
EPA = United States Environmental Protection Agency
Page 6 of 6
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Table D-6
Location-Specific ARARs, Criteria, Advisories, and Guidance for Soil/Sed-2
Record of Decision
Olin Chemical Superfund Site
Wilmington, Massachusetts
Location Characteristic [ Requirement [ Citation Status | Requirement Synopsis | Action To Be Taken To Attain Requirement
Federal Standards
Fioodplains and Wetlands
Floodplain Management and
Protection of Wetlands
44 CFR Part 9 {implementing
Executive Orders 11988 and 11990)
Relevant and
Appropriate
Federal Emergency Management Agency (FEMA)
regulations set forth the policy, procedure, and
responsibilities to implement and enforce Executive
Order 11988 (Floodplain Management) and Executive
Order 11990 (Protection of Wetlands). These
regulations prohibit activities that adversely affect a
federally-regulated wetland unless there is no
practicable alternative and the proposed action
includes all practicable measures to minimize harm to
wetlands that may result from such use. These
regulations require the avoidance of impacts
associated with the occupancy and modification of
federally-designated 100-year and 500-year
floodplains and require the avoidance of development
within a floodplain wherever there is a practicable
alternative. An assessment of impacts to the 500-year
floodplain is required for critical actions, which includes
siting waste facilities in a floodplain. These regulations
require public notice when proposing any action in or
affecting floodplains or wetlands.
If there is no practicable alternative method to work in federal
jurisdictional wetlands, or 100-year or 500-year floodplains, then all
practicable measures will be taken to minimize and mitigate any
adverse impacts. Erosion and sedimentation control measures will
be adopted during remedial activities to protect these wetlands and
floodplains. Remedial activities, including excavation of wetland
soil and sediment, dewatering and any related treatment, closure of
the Containment Area equalization window, construction and O&M
of the Containment Area cap and soil cover systems, any
implementation of building vapor mitigation measures, pre-design
investigation, and monitoring activity, will comply with this ARAR
through appropriate avoidance, minimization, mitigation and/or
restoration. The Containment Area elevation (85 ft msl) is above
the 500-year flood elevation (82 ft msl), which means that the
infrastructure for the Containment Area cap would not result in the
occupancy and modification of the 500-year floodplain on the Olin
Property. If additional site preparation work is required to provide
for adequate drainage and storage within the 100- or 500-year
floodplain, this will be evaluated as part of design activities and
implemented during the Remedial Action (RA) phase. After
completion of work within the regulated 100- or 500-year floodplain,
there will be no significant net loss of flood storage capacity and no
significant net increase in flood stage or velocities. Floodplain
habitat will be restored to the extent practicable. Federal
jurisdictional wetlands altered by wetland soil and sediment
excavation and soil covers installed adjacent to such wetlands wili
be restored in place.
Floodplains
RCRA Floodplain Restrictions
for Hazardous Waste Facilities
42 USC § 6901 et seq.;
40 CFR § 264.18(b)
Applicable, if
hazardous waste is
managed within the
100-year floodplain
A hazardous waste treatment, storage, or disposal
facility located in a 100-year floodplain must be
designed, constructed, operated, and maintained to
prevent washout or to result in no adverse effects on
human health or the environment if washout were to
occur.
To the extent any hazardous waste is generated during remedial
activities, including the excavation of wetland soil and sediment,
dewatering and any related treatment, closure of the Containment
Area equalization window, construction and O&M of the
Containment Area cap and soil cover systems, implementation of
any building vapor mitigation measures, pre-design investigation,
and monitoring activity, the waste will be managed so that it will not
impact floodplain resources.
Fioodplains
RCRA Floodplain Restrictions
for Solid Waste Disposal
Facilities and Practices
40 CFR §257.3-1
Applicable, if solid
waste is managed
within the 100-year
floodplain
Solid waste practices must not restrict the flow of a
100-year flood, reduce the temporary water storage
capacity of the floodplain, or result in washout of solid
waste, so as to pose a hazard to human life, wildlife, or
land or water resources.
Any solid waste generated during remedial activities, including the
excavation of wetland soil and sediment, dewatering and any
related treatment, closure of the Containment Area equalization
window, construction and O&M of the Containment Area cap and
soil cover systems, implementation of any building vapor mitigation
measures, pre-design investigation, and monitoring activity, will be
managed so that it will not impact floodplain resources.
Page 1 of 4
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Table D-6
Location-Specific ARARs, Criteria, Advisories, and Guidance for Soil/Sed-2
Record of Decision
Olin Chemical Superfund Site
Wilmington, Massachusetts
Location Characteristic
Requirement
Citation
Status
Requirement Synopsis
Action To Be Taken To Attain Requirement
Wetlands, Aquatic Ecosystem
Clean Water Act (CWA) Section
404{bX1) Guidelines for
Specification of Disposal Sites
for Dredged or Fill Material
33 USC § 1344(bX1);
40 CFR Parts 230 & 231; and
33 CFR Parts 320-323
Applicable
For discharge of dredged or fill material into water
bodies or wetlands, there must be no practicable
alternative with less adverse impact on aquatic
ecosystem; discharge cannot cause or contribute to
violation of state water quality standards or toxic
effluent standards or jeopardize threatened or
endangered species; discharge cannot significantly
degrade waters of U.S.; practicable steps must be
taken to minimize and mitigate adverse impacts; and
impacts on flood level, flood velocity, and flood storage
capacity must be evaluated. Sets standards for
restoration and mitigation required as a result of
unavoidable impacts to aquatic resources. EPA must
determine which alternative is the least
environmentally damaging practicable alternative to
protect wetland and aquatic resources.
Remedial activities, including excavation of wetland soil and
sediment, dewatering and any related treatment, closure of the
Containment Area equalization window, construction and O&M of
the Containment Area cap and soil cover systems, implementation
of any building vapor mitigation measures, pre-design
investigation, and monitoring activity, will comply with this ARAR
through appropriate avoidance, minimization, mitigation and/or
restoration. EPA has determined that the selected remedial
alternative is the least environmentally damaging practicable
alternative because (a) there is no practicable alternative method
that will achieve cleanup objectives with less adverse impact and
(b) all practicable measures would be taken to minimize and
mitigate any adverse impacts from the work.
Wetlands
U.S. Army Corps of Engineers,
New England District
Compensatory Mitigation
Guidance (09-07-2016)
To Be Considered
This guidance is to be considered when compensatory
mitigation to address impacts to federal jurisdictional
wetlands is appropriate for a particular remedial
activity.
Remedial activities, including excavation of wetland soil and
sediment, dewatering and any related treatment, closure of the
Containment Area equalization window, construction and O&M of
the Containment Area cap and soil cover systems, implementation
of any building vapor mitigation measures, pre-design
investigation, and monitoring activity, may impact federal
jurisdictional wetlands. Activities affecting federal jurisdictional
wetlands will be conducted in accordance with these guidance
standards for mitigation and restoration.
Surface Waters,
Wetland/Waterway Habitat for
Endangered Species,
Migratory Species
Fish and Wildlife Coordination
Act
16 USC §661 etseq.;
40 CFR § 6.302(g)
Applicable
Requires that any federal agency proposing to modify
a body of water must consult with the U.S. Fish and
Wildlife Service, National Marine Fisheries Service,
and other related state agencies to prevent, mitigate,
or compensate for project-related losses of or damage
to endangered species, fish, and wildlife resources.
Consultation with appropriate federal and state agencies will be
maintained during planning and implementation of remedial
activities, including excavation of wetland soil and sediment,
dewatering and any related treatment, construction and O&M of the
Containment Area cap and soil cover systems, implementation of
any building vapor mitigation measures, pre-design investigation,
and monitoring activity to ensure that losses of or damage to
habitat and wildlife will be prevented, mitiqated, or compensated.
Endangered Species
Endangered Species Act
16 USC. §§1531 etseq.;
50 CFR §§ 17.11-17.12;
50 CFR Part 402
Applicable, if
endangered species
are encountered
This act requires action to avoid jeopardizing the
continued existence of listed endangered or
threatened species or modification of their habitat.
No known endangered or threatend species have been identified in
the vicinity of the Site. If such species or habitats in the remedial
areas are identified, remedial activities will be designed and
implemented to avoid effects to endangered or threatened species
or their habitats.
Historical/
ArcheologicalResources
National Historic Preservation
Act
54 USC §§ 300101 etseq.;
36 CFR Part 800
Applicable, if subject
historical resources
are present
Pursuant to Section 106 of the NHPA, CERCLA
response actions are required to take into account the
effects of the response activities on any historic
property (any prehistoric or historic district, site,
building, structure, or object included in, or eligible for
inclusion in, the National Register of Historic Places,
which would be significant in American history,
architecture, archeology, engineering, and culture) and
to resolve any adverse effects, including avoidance,
minimization, or mitigation of the adverse effects.
No protected resources are known to exist in the area impacted by
remedial activities, including excavation of wetland soil and
sediment, dewatering and any related treatment, closure of the
Containment Area equalization window, construction and O&M of
the Containment Area cap and soil cover systems, implementation
of any building vapor mitigation measures, pre-design
investigation, and monitoring activity. If protected resource areas
are identified, federal and state preservation officials will be
consulted to address measures to avoid, minimize and/or mitigate
any impacts to these protected resource areas.
Page 2 of 4
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Table D-6
Location-Specific ARARs, Criteria, Advisories, and Guidance for Soil/Sed-2
Record of Decision
Olin Chemical Superfund Site
Wilmington, Massachusetts
Location Characteristic
Requirement
Citation
Status
Requirement Synopsis
Action To Be Taken To Attain Requirement
Atlantic Flyway
Migratory Bird Treaty Act
16 USC § 703 et seq.
Applicable, if subject
protected species are
present
Protects migratory birds, their nests, and eggs. A
depredation permit issued by the U.S. Fish and
Wildlife Service is required to take, possess, or
transport migratory birds or disturb their nests, eggs,
or young.
Remedial activities, including excavation of wetland soil and
sediment, dewatering and any related treatment, closure of the
Containment Area equalization window, construction and O&M of
the Containment Area cap and soil cover systems, implementation
of any building vapor mitigation measures, pre-design
investigation, and monitoring activity, will be evaluated to protect
migratory birds, their nests, and eggs. If migratory bird protected
areas are identified in the area of remedial activities, measures to
avoid, minimize and/or mitigate any impacts to protected resource
areas will be implemented in consultation with appropriate agency
officials.
State Standards
Fioodplains
Massachusetts Hazardous
Waste Regulations, Location
Standards for Land Subject to
Flooding
310CMR 30.701
Applicable, if
hazardous waste is
managed within a
floodplain
This regulation sets forth criteria for siting hazardous
waste facilities within land subject to flooding (as
defined under the Massachusetts Wetland Protection
Act standards). Any new or expanded hazardous
waste storage or treatment facility (which only receives
hazardous waste from on-site sources), the active
portion of which is located within the boundary of land
subject to flooding from the statistical 100-year
frequency storm, shall be flood-proofed. Flood-
proofing shall be designed, constructed, operated, and
maintained to prevent floodwaters from coming into
contact with hazardous waste.
To the extent any hazardous waste is generated during remedial
activities, including the excavation of wetland soil and sediment,
dewatering and any related treatment, closure of the Containment
Area equalization window, construction and O&M of the
Containment Area cap and soil cover systems, implementation of
any building vapor mitigation measures, pre-design investigation,
and monitoring activity, the waste will be managed so that it will not
impact floodplain resources.
Floodplains, Wetlands,
Surface Waters
Massachusetts Wetland
Protection Act and Regulations
MGLc. 131, §40;
310 CMR 10.00
Applicable if
alternative alters
wetlands or floodplains
These regulations restrict dredging, filling, altering, or
polluting inland wetland resource areas (defined as
areas within the 100-year floodplain) and buffer zones
(100 feet of a vegetated wetland or 200 feet from a
perennial stream), and impose performance standards
for work in such areas. Protected resource areas
include: 10.54 (Bank); 10.55 (Bordering Vegetated
Wetlands); 10.56 (Land under Water Bodies and
Waterways); 10.57 (Land Subject to Flooding); and
10.58 (Riverfront Area).
Remedial activities, including the excavation of wetland soil and
sediment, dewatering and any related treatment, closure of the
Containment Area equalization window, construction and O&M of
the Containment Area cap and soil cover systems, implementation
of any building vapor mitigation measures, pre-design
investigation, and/or monitoring activity, will occur in/adjacent to
wetlands and floodplains, and, if state regulated wetlands or
floodplains will be altered, the remedial activities will comply with
this ARAR through appropriate avoidance, minimization, mitigation
and restoration. Any remedial activity described above conducted
within 100 feet of a state regulated wetland resource area or 200
feet from a perennial stream will comply with the substantive
requirements of these regulations. Mitigation of impacts on state
wetland resource areas will be addressed. Ail remedial work within
any regulated floodplain will result in no net loss of flood storage
capacity and no net increase in flood stage or velocities. Floodplain
habitat will be restored, to the extent practicable.
Wetlands, Aquatic Ecosystem
Massachusetts Clean Water
Act; Massachusetts Water
Quality Certification for
Discharge of Dredged or Fiil
Material
MGL c. 21, §§ 26-53;
314 CMR 9.00
Applicable, if
alternative involves
filling of wetlands
For discharges of dredged or fill material, there must
be no practicable alternative with less adverse impact
on the aquatic ecosystem: appropriate and practicable
steps must be taken to avoid and minimize potential
adverse impacts to wetlands and land under water;
stormwater discharges must be controlled with BMPs;
and there must not be substantial adverse impacts to
the physical, chemical, or biological integrity of surface
waters. For dredging and dredged material
management, there must be no practicable alternative
with less adverse impact on the aquatic ecosystem;
and if avoidance is not possible, then minimize, or if
neither avoidance nor minimization are possible, then
mitigate potential adverse impacts
Remedial activities, including excavation of wetland soil and
sediment, dewatering and any related treatment, closure of the
Containment Area equalization window, construction and O&M of
the Containment Area cap and soil cover systems, implementation
of any building vapor mitigation measures, pre-design
investigation, and monitoring activity, will comply with this ARAR
through appropriate avoidance, minimization, mitigation and/or
restoration. EPA has determined that the selected final soil-
sediment action is the least environmentally damaging practicable
alternative because (a) there is no practicable alternative method
that will achieve cleanup objectives with less adverse impact and
(b) all practicable measures would be taken to minimize and
mitigate any adverse impacts from the work.
Page 3 of 4
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Table D-6
Location-Specific ARARs, Criteria, Advisories, and Guidance for Soil/Sed-2
Record of Decision
Olin Chemical Superfund Site
Wilmington, Massachusetts
Location Characteristic
Requirement
Citation
Status
Requirement Synopsis
Action To Be Taken To Attain Requirement
Endangered Species
Massachusetts Endangered
Species Regulations
321 CMR 10.00
Applicable, if
endangered species
are encountered
Requires action to regulate the impact to state listed
endangered or threatened species or their habitats.
Actions must be conducted in a manner that minimizes
the impact to Massachusetts-listed rare, threatened, or
endangered species, and species listed by the
Massachusetts Natural Heritage Program.
No known endangered or threatened species have been identified
in the vicinity of the remedial activities, including excavation of
wetland soil and sediment, dewatering and any related treatment,
closure of the Containment Area equalization window, construction
and O&M of the Containment Area cap and soil cover systems,
implementation of any building vapor mitigation measures, pre-
design investigation, and monitoring activity. However, if state
listed endangered or threatened species or their habitats in the
area of remedial activities are identified, the remedial activities will
be designed and implemented to avoid adverse effects to
endanqered or threatened species or their habitats.
Historical/
ArcheoiogicalResources
Massachusetts Antiquities Act;
Massachusetts Historical
Commission Regulations;
Protection of Properties
Included in the State Register of
Historic Places
MGL c. 9, §§ 26-27C;
950 CMR 70.00 and 71.00
Applicable, if subject
historical resources
are present.
Projects must eliminate, limit, or mitigate adverse
effects to properties listed in the State Register of
Historic Places (historic and archaeological
properties). Establishes coordination with the National
Historic Preservation Act.
No protected resources are known to exist in the area impacted by
remedial activities, including excavation of wetland soil and
sediment, dewatering and any related treatment, closure of the
Containment Area equalization window, construction and O&M of
the Containment Area cap and soil cover systems, implementation
of any building vapor mitigation measures, pre-design
investigation, and monitoring activity. If protected resource areas
are identified in the area of remedial activities, federal and state
preservation officials will be consulted to address measures to
avoid, minimize and/or mitigate any impacts to these protected
resources.
Area of Critical Environmental
Concern
Massachusetts Areas of Critical
Environmental Concern
(ACECs) Regulations
301 CMR 12.00
Applicable, if ACEC is
identified
An ACEC is of regional, state, or national importance
or contains significant ecological systems with critical
interrelationships among a number of components. An
eligible area must contain features from four or more
of the following groups: (1) fisheries, (2) coastal
features, (3) estuarine wetlands, (4) inland wetlands,
(5) inland surface waters, (6) water supply areas (e.g.,
aquifer recharge area); (7) natural hazard areas (e.g.,
floodplain); (8) agricultural areas; (9)
historical/archeological resources; (10) habitat
resources (e.g., for endangered wildlife); or (11)
special use areas. After an area is designated as an
ACEC, the aim is to preserve and restore these areas.
No known ACEC has been identified at the Site. If an ACEC is
identified in the area of remedial activities, including excavation of
wetland soil and sediment, dewatering and any related treatment,
closure of the Containment Area equalization window, construction
and O&M of the Containment Area cap and soil cover systems,
implementation of any building vapor mitigation measures, pre-
design investigation, and monitoring activity, activities will be
controlled to minimize impacts to effected species or resources.
Notes:
ACEC = Area of Critical Environmental Concern
ARAR = Applicable or Relevant and Appropriate Requirement
BMP = Best Management Practice
CFR = Code of Federal Regulations
CMR = Code of Massachusetts Regulations
CWA = Clean Water Act
FEMA = Federal Emergency Management Agency
MGL = Massachusetts General Law
RCRA = Resource Conservation and Recovery Act
USC = United States Code
EPA = United States Environmental Protection Agency
USFWS = United States Fish and Wildlife Service
Page 4 of 4
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Table D-7
Chemical-Specific ARARs, Criteria, Advisories, and Guidance for Soil/Sed-2
Record of Decision
Olin Chemical Superfund Site
Wilmington, Massachusetts
Requirement
Citation
Status
Requirement Synopsis
Action To Be Taken To Attain Requirement
Federal Standards
USEPA Risk Reference Doses (RfDs)
USEPA RfDs
To Be Considered
RfDs are considered to be the levels unlikely to cause significant
adverse non-cancer health effects associated with a threshold
mechanism of action in human exposure for a lifetime. Used in
developing risk-based cleanup standards by computing human
health hazard resulting from exposure to non-carcinogens at the
Site.
Institutional controls (ICs) will prevent exposure to soil and sediment contaminants
that contribute to a calculated non-carcinogenic risk, developed in consideration of
this guidance. Long term monitoring and ICs will prevent residential development.
USEPA Carcinogenic Assessment
Group, Cancer Slope Factors (CSFs)
USEPA CSFs
To Be Considered
CSFs are estimates of the upper-bound probability on the
increased cancer risk from a lifetime exposure to contaminants.
Used in developing risk-based cleanup standards by computing
the incremental cancer risk from exposure to contaminants at the
Site.
ICs will prevent exposure to soil and sediment contaminants that contribute to a
calculated carcinogenic risk, developed in consideration of this guidance. Long
term monitoring and ICs will prevent residential development.
Guidelines for Carcinogenic Risk
Assessment
EPA/63G/P-03/001F, March 2005
To Be Considered
These guidance values are to be used to evaluate the potential
carcinogenic hazard caused by exposure to contaminants.
ICs will prevent exposure to soil and sediment contaminants that contribute to a
calculated carcinogenic risk, developed in consideration of this guidance. Long
term monitorinq and ICs will prevent residential development.
Supplemental Guidance for Assessing
Susceptibility from Early-Life Exposure
to Carcinogens
EPA/630/R-03/003F, March 2005
To Be Considered
These guidance values are to be used to evaluate the potential
carcinogenic hazard to children caused by exposure to
contaminants.
ICs will prevent exposure to soil and sediment contaminants that contribute to a
calculated carcinogenic risk, developed in consideration of this guidance. Long
term monitorinq and ICs will prevent residential development.
Regional Screening Levels for
Chemical Contaminants at Superfund
Sites
USEPA Regional Screening Levels for
Chemical Contaminants at Superfund
Sites
To Be Considered
Regional Screening Levels (RSLs) are risk based tools for
screening contaminants at Superfund sites. RSLs are not
intended to be cleanup standards.
ICs will prevent exposure to soil and sediment contaminants that contribute to a
calculated residential risk based on standards developed in consideration of this
quidance.
Supplemental Guidance for
Developing Soil Screening Levels for
Superfund Sites
OSWER 9355.4-24 (2002)
To Be Considered
EPA guidance for evaluating soil contamination. Used to develop
risk-based cleanup standards, including based on the leaching of
soil contaminants to qroundwater.
ICs will prevent exposure to soil and sediment contaminants that contribute to a
calculated residential risk based on standards developed in consideration of this
quidance.
Soil Screening Guidance: Technical
Background Document
EPA/540/R95/128 (1996)
To Be Considered
EPA guidance for evaluating soil contamination. Used to develop
risk-based cleanup standards.
ICs will prevent exposure to soil and sediment contaminants that contribute to a
calculated residential risk based on standards developed in consideration of this
quidance.
Ecological Risk Assessment Guidance
for Superfund
EPA/540/R97/006
To Be Considered
EPA guidance used to develop site-specific ecological risk-based
cleanup standards.
The remedial alternatives, including excavation of wetland soil and sediment and
soil cover systems, will prevent ecological exposure to soil and sediment
contaminants that contribute to a calculated risk developed in consideration of this
guidance, by removing all contaminated wetland soil and sediment and covering or
cappinq all upland soil that exceeds cleanup levels.
Ecological Soil Screening
Levels (Eco-SSLs)
EPA,
https://www.epa.gov/risk/ecological-soil-
screening-level-eco-ssl-guidance-and-
documents
To Be Considered
Provides nonregulatory soil screening criteria and toxicity
reference values for the protection of ecological receptors.
The remedial alternatives, including excavation of wetland soil and sediment and
soil cover systems, will prevent ecological exposure to soil contaminants that
contribute to a calculated risk developed in consideration of this guidance, by
removing all contaminated wetland soil and sediment and covering or capping ail
upland soil that exceeds cleanup levels.
Ontario Ministry of Environment and
Energy (OMEE) Severe Effect Levels
(SELs) for Freshwater Sediments
Persaud etal., 1993
To Be Considered
The SEL value is the concentration at which the majority of the
sediment-dwelling organisms are affected. Used to develop risk-
based cleanup standards.
The remedial alternatives, including excavation of wetland soil and sediment, will
prevent ecological exposure to sediment contaminants that contribute to a
calculated risk developed in consideration of this guidance, by removing all
contaminated sediment that exceeds cleanup levels.
Development and Evaluation of
Consensus-Based Sediment Quality
Guidelines for Freshwater
Ecosystems. Probable Effects
Concentrations (PECs)
MacDonald et al., 2000
To Be Considered
The PEC value is the concentration above which the adverse
effects on sediment-dwelling organisms are likely to occur. Used
to develop risk-based cleanup standards.
The remedial alternatives, including excavation of wetland soil and sediment, will
prevent ecological exposure to sediment contaminants that contribute to a
calculated risk developed in consideration of this guidance, by removing ail
contaminated sediment that exceeds cleanup levels.
European Regulation on Registration,
Evaluation, Authorisation, and
Restriction of Chemicals (REACH)
Dossier
https://echa.europa.eu/regulations/reac
h/substance-registration/the-
registration-dossier
To Be Considered
Source of ecological soil screening benchmarks used to develop
site-specific ecological risk-based cleanup standards.
The remedial alternatives, including excavation of wetland soil and sediment and
soil cover systems, will prevent ecological exposure to soil and sediment
contaminants that contribute to a calculated ecological risk, by removing all
contaminated wetland soil and sediment and covering and capping all upland
contaminated soil that exceeds cleanup levels.
Page 1 of 2
-------
Table D-7
Chemical-Specific ARARs, Criteria, Advisories, and Guidance for Soil/Sed-2
Record of Decision
Olin Chemical Superfund Site
Wilmington, Massachusetts
Requirement
Citation
Status
Requirement Synopsis
Action To Be Taken To Attain Requirement
Toxicological Benchmarks for
Contaminants of Potential Concern for
Effects on Soil and Litter Invertebrates
and Heterotrophic Process: 1997
Revision. Oak Ridge National
Laboratory, Oak Ridge, TN.
ES/ER/TM-126/R2.)
Efroymson, Will & Suter,
1997http://www.hsrd.oml.gov/ecorisk/tm
126r21.pdf
To Be Considered
Source of ecological soil screening benchmarks used to develop
site-specific ecological risk-based cleanup standards.
The remedial alternatives, including excavation of wetland soil and sediment and
soil cover systems, will prevent ecological exposure to soil and sediment
contaminants that contribute to a calculated risk, by removing all contaminated
wetland soil and sediment and covering and capping all upland contaminated soil
that exceeds cleanup levels.
Ontario Ministry of the Environment.
2011. Rationale for the Development
of Generic Soil and Ground Water
Standards for Use at Contaminated
Sites in Ontario.
https://www.ontario.ca/page/soil-
ground-water-and-sediment-standards-
use-under-part-xv1-environmental-
protection-act
To Be Considered
Source of ecological soil screening benchmarks used to develop
site-specific ecological risk-based cleanup standards.
The remedial alternatives, including excavation of wetland soil and sediment and
soil cover systems, will prevent ecological exposure to soil and sediment
contaminants that contribute to a calculated risk, by removing ail contaminated
wetland soil and sediment and covering and capping ail upland contaminated soil
that exceeds cleanup levels.
Notes:
ARAR = Applicable or Relevant and Appropriate Requirement
CFR = Code of Federal Regulations
CMR = Code of Massachusetts Regulations
CSF = cancer slope factor
MCLGs = Maximum Contaminant Level Goals
MCLs = Maximum Contaminant Levels
RfD = reference dose
Page 2 of 2
-------
Appendix E
References
Record of Decision Appendix E
Olin Chemical Superfund Site March 2021
Wilmington, Massachusetts
-------
References
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Olin Chemical Superfund Site
Wilmington, Massachusetts
Appendix E
March 2021
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Based Sediment Quality Guidelines for Freshwater Ecosystems. Archives of Environmental
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ERB-N91-1628 Jewell Drive. Issued to: Olin Chemicals, P.O. Box 248, Lower River Road, Charlestow,
TN 37310, Attn. Steve Morrow. Commonwealth of Massachusetts, Executive Office of Environmental
Affairs, Department of Environmental Protection, Metro Boston/Northeast Regional Office. May 28.
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of Closure, FMF #131605. Commonwealth of Massachusetts, Executive Office of Environmental Affairs,
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Record of Decision Appendix E
Olin Chemical Superfund Site March 2021
Wilmington, Massachusetts Page 3 of 7
-------
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Operable Unit 1 & Operable Unit 2, Feasibility Study. Olin Corporation. July 31.
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Interim Action Feasibility Study. Olin Corporation. August.
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Record of Decision
Olin Chemical Superfund Site
Wilmington, Massachusetts
Appendix E
March 2021
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Director, Emergency and Remedial Response Division, Region II, Director, Hazardous Waste
Management Division, Regions III, VI, VIII, IX, Director, Hazardous Waste Division, Region X,
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25.
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and Evaluation of Sediment Effect Concentrations for the Amphipod Hyalella Azteca and the Midge
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Conducting Ecological Risk Assessments, Interim Final. EPA 540-R-97-006 / OSWER 9285.7-25. June.
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July.
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Waste Sites. OSWER 9285.6-10. December.
Record of Decision
Olin Chemical Superfund Site
Wilmington, Massachusetts
Appendix E
March 2021
Page 5 of7
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USEPA, 2003a. Procedures for the Derivation of Equilibrium Partitioning Sediment Benchmarks (ESBs)
for the Protection of Benthic Organisms: PAH Mixtures. EPA/600/R-02/013. November.
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Technology Innovation. To: Superfund National Policy Managers, Regions 1 - 10. Subject: Human
Health Toxicity Values in Superfund Risk Assessments. OSWER Directive 9285.7-53. December 5.
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03/00IF, Washington, D.C. March.
USEPA, 2005b. Supplemental Guidance for Assessing Susceptibility from Early-Life Exposure to
Carcinogens, Risk Assessment Forum, EPA/630/R-03/003F, Washington, D.C. March.
USEPA, 2006. EPA Region 111 BTAG Freshwater Screening Benchmarks. July.
USEPA, 2008. Procedures for the Derivation of Equilibrium Partitioning Sediment Benchmarks (ESBs)
for the Protection of Benthic Organisms: PAH Mixtures. EPA/600/R-02/013. November.
USEPA, 2009a. Correspondence. From: James M. DiLorenzo, USEPA Region 1 - New England. To:
Ken Finkelstein, NOAA/NOS/OR&R, Coastal Protection and Restoration Division. Subject: Transmittal
of Final RI/FS Work Plan, Olin Chemical Superfund Site, Wilmington, Mass. November 12.
USEPA, 2009b. From: James M. DiLorenzo, USEPA Region 1 - New England. To: Andrew L. Raddant,
Department of Interior, Office of Environmental Policy and Compliance. Subject: Transmittal of Final
RI/FS Work Plan, Olin Chemical Superfund Site, Wilmington, Mass. November 12.
USEPA, 2009c. From: James M. DiLorenzo, USEPA Region 1 - New England. To: Ian A. Bowles,
Secretary, Executive Office of Energy and Environmental Affairs, NRD Coordinator. Subject:
Transmittal of Final RI/FS Work Plan, Olin Chemical Superfund Site, Wilmington, Mass. November 12.
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Olin Chemical Superfund Site, Wilmington, Mass. November 1.
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Evaluation/Cost Analysis for a Non-Time Critical Approval Action. May 25.
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March.
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R-18-002. April.
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Office of Superfund. November.
USEPA, 2015. From: Nancy Barmakian, Acting Director, Office of Site Remediation and Restoration,
USEPA Region 1 - New England. To: Robert W. Jones, III, Managing Principal, New England Transrail,
LLC. Subject: Comfort/Status and Reasonable Steps Letter, 51 Eames Street, Wilmington, Massachusetts,
Olin Chemical Superfund Site. May 13.
Record of Decision
Olin Chemical Superfund Site
Wilmington, Massachusetts
Appendix E
March 2021
Page 6 of7
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USEPA, 2018a. Integrated Risk Information System on-line database search: www,epa.gov/iris
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Conclusions. August 5.
USEPA, 2020b. Memorandum. Olin Chemical Superfund Site, Updates to Draft 2019 OU3 RI Report
Conclusions. August 5.
USEPA, 2020c. Memorandum. Volume III - Comparative Analyses, Feasibility Study Report, Olin
Chemical Superfund Site, Wilmington, Massachusetts. August 5.
USEPA, 2020d. E-mail Correspondence. From: Melanie Morash, USEPA. To: Chinny Esakkiperumal,
Olin Corporation. Subject: EPA Approval - Olin Chemical Superfund Site - Wilmington, MA - Data
Gaps Work Plan - Phase 1A Proposal - Seismic Work. March 12.
USEPA, 2020e. Memorandum. From: Matthew Z. Leopold, General Counsel. To: Associate Deputy
Administrator, Assistant Administrators, Regional Administrators. Subject: Virtual Public Hearings and
Meetings. April 16.
Wehran, 1986. Phase I Site Inspection Report for the Olin Chemical Group, Wilmington, Massachusetts,
Middlesex County, Massachusetts FIT Contract, MDEQE Project Number 86-01-086-093, WE Project
Number 50086.10. Wehran Engineering Corp. September.
Wood, 2018. Revised Draft Baseline Human Health Risk Assessment, Operable Unit 3. Olin Chemical
Superfund Site, Wilmington, MA. December 18.
Wood, 2019. Revised Draft Remedial Investigation Report, Operable Unit 3, Olin Chemical Superfund
Site, Wilmington, Massachusetts. Wood Environment & Infrastructure Solutions. June.
Wood, 2020a. Memorandum, Supplemental Characterization of Containment Area Soil, November 2019,
Olin Chemical Superfund Site, 51 Eames Street, Wilmington, MA. March 20.
Wood, 2020b. Technical Memorandum. Documentation of Preliminary Remediation Goals (PRGs) for
Soils, Sediments, and Surface Water at the Olin Chemical Superfund Site. Wood Environment &
Infrastructure Solutions, Inc. May 15.
Wood, 2020c. Technical Memorandum. Documentation of Preliminary Remediation Goals (PRGs) to
Address Human Health Risks in Dense Aqueous-Phase Liquid (DAPL), Groundwater Hot Spots, Upland
Soil (including Containment Area soil), and Surface Water at the Olin Chemical Superfund Site. Wood
Environment & Infrastructure Solutions, Inc. July 1.
Record of Decision
Olin Chemical Superfund Site
Wilmington, Massachusetts
Appendix E
March 2021
Page 7 of7
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Appendix F
Acronyms and Abbreviations
Record of Decision Appendix F
Olin Chemical Superfund Site March 2021
Wilmington, Massachusetts
-------
Acronyms and Abbreviations
1,1-DC A
5PT
AOC
ARAR
AS
BAF
BEHP
BERA
BFPP
bgs
BHHRA
BRA
ccc
CERCLA
CERCLIS
cf
CFR
CMR
COC
COPC
COPEC
CSF
CSGWPP
CSL
CSM
CTE
CWA
cy
DAPL
delta-BHC
E-EA
EA
Eco-SSL
EDI
EE/CA
ELCR
EPA
EPC
EPH
EPH/VPH
ESD
FEMA
FS
ft
1,1 -dichloroethane
5-phenyltetrazole
Administrative Settlement Agreement and Order on Consent
Applicable or Relevant and Appropriate Requirement
Air Sparging
Bioaccumulation Factor
bis-2-ethylhexylphthalate
Baseline Ecological Risk Assessment
bona fide prospective purchaser
below ground surface
Baseline Human Health Risk Assessment
Baseline Risk Assessment
Criterion Continuous Concentration
Comprehensive Environmental Response, Compensation, and Liability Act
Comprehensive Environmental Response, Compensation, and Liability Information
System
cubic feet
Code of Federal Regulation
Code of Massachusetts Regulations
Contaminant of Concern
Contaminants of Potential Concern
Contaminants of Potential Ecological Concern
cancer slope factor
Comprehensive State Groundwater Protection Program
Calcium Sulfate Landfill
Conceptual Site Model
Central Tendency Exposure
Clean Water Act
cubic yard
Dense Aqueous Phase Liquid
de lta-hexach lorocyc lohexane
Ecological Exposure Area
Exposure Area
Ecological Soil Screening Level
Estimated Daily Intake
Engineering Evaluation/Cost Analysis
excess lifetime cancer risk
United States Environmental Protection Agency
Exposure Point Concentration
extractable petroleum hydrocarbons
extractable petroleum hydrocarbon/volatile petroleum hydrocarbon
Explanation of Significant Difference
Federal Emergency Management Agency
Feasibility Study
foot
Record of Decision
Olin Chemical Superfund Site
Wilmington, Massachusetts
Appendix F
March 2021
Page 1 of 4
-------
GAC
GC/MS
GERE
gpm
GWHS
g
HDPE
HH-EA
HHRA
HI
HQ
HRS
in
IRA
IUR
K
kg
LADD
LC/MS
LEDPA
LIF
LNAPL
LOAEL
M-g/L
MassDEP
MassDEQE
MBTA
MCL
MCP
MDC
MEPA
mg/kg
mg/kg/day
mg/L
Jig/L
MGL
MMB
MMH
|imhos/cm
MOA
MPE
msl
MWRA
NAUL
NCP
NDBA
NDEA
granular activated carbon
gas chromatography/mass spectrometry
Grant of Environmental Restriction and Easement
gallons per minute
Groundwater Hot Spots
grams
high density polyethylene
Human Health Exposure Area
Human Health Risk Assessment
Hazard Index
Hazard Quotient
Hazard Ranking System
inch
Immediate Response Action
Inhalation Unit Risk
hydraulic conductivity
Kilogram
lifetime average daily dose
liquid chromatography/mass spectrometry
Least Environmentally Damaging Practicable Alternative
Laser-Induced Fluorescence
Light Non-Aqueous Phase Liquid
Lowest Observed Adverse Effect Level
micrograms per Liter
Massachusetts Department of Environmental Protection
Massachusetts Department of Environmental Quality Engineering
Massachusetts Bay Transportation Authority
Maximum Contaminant Level
Massachusetts Contingency Plan
Metropolitan District Commission
Massachusetts Environmental Policy Act
milligrams per kilogram
milligrams per kilogram per day
milligrams per Liter
micrograms per Liter
Massachusetts General Laws
Maple Meadow Brook
monomethylhydrazine
microohms per centimeter
Mode of Action
multi-phase extraction
mean sea level
Massachusetts Water Resources Authority
Notice of Activity and Use Limitation
National Oil and Hazardous Substances Pollution Contingency Plan
n-nitrosodi-n-butylamine
n-nitrosodiethylamine
Record of Decision
Olin Chemical Superfund Site
Wilmington, Massachusetts
Appendix F
March 2021
Page 2 of 4
-------
NDMA
NDPhA
NDPrA
ng/L
NIOSH
NMEA
NOAEL
NPI
NPIP
NPL
NPYR
NRWQC
O&M
OBSC
OBSH
ou
PA
PA/SI
PAH
PCBs
PDI
PIP
PPE
PRB
PRG
PPvP
PVC
QA/QC
QAPP
RAGS
RAM
RAO
RCRA
RD
RfC
RED
RGP
RI
RI/FS
RME
ROD
RPF
RSL
s
SA
SED
SEMD
n-nitrosodimethylamine
n-nitrosodiphenylamine
n-nitrosodipropylamine
nanograms per Liter
National Institute for Occupational Safety and Health
n-nitrosomethylethylamine
No Observed Adverse Effect Level
National Polychem icals. Inc.
n-nitrosopiperidine
National Priorities List
n-n itrosopyrrol idine
National Recommended Water Quality Criteria
Operation and Maintenance
4,4' oxybisbenzenesulfonylchloride
4,4' oxybisbenzenesulfonylhydrazide
Operable Unit
Preliminary Assessment
Preliminary Assessment/Site Inspection
Polycyclic Aromatic Hydrocarbon
polychlorinated biphenyls
Pre-design investigation
Potentially Interested Party
Personal Protective Equipment
Permeable Reactive Barrier
Preliminary Remediation Goal
Potentially Responsible Party
polyvinyl chloride
Quality Assurance/Quality Control
Quality Assurance Project Plan
EPA Risk Assessment Guidance for Superfund
Release Abatement Measure
Remedial Action Objective
Resource Conservation and Recovery Act
Remedial Design
Reference Concentration
Reference Dose
Remediation General Permit
Remedial Investigation
Remedial Investigation/Feasibility Study
Reasonable Maximum Exposure
Record of Decision
Relative Potency Factor
Regional Screening Level
second
Site Assessment
sediments
Superfund and Emergency Management Division
Record of Decision
Olin Chemical Superfund Site
Wilmington, Massachusetts
Appendix F
March 2021
Page 3 of 4
-------
sq. ft
square feet
SHPO
State Historic Preservation Officer
SI
Site Inspection
SMB
Sawmill Brook
SMP
Site Management Plan
SSDS
Sub-Slab Depressurization System
SVE
Soil Vapor Extraction
SVOC
Semi-Volatile Organic Compound
sw
surface water
SWPPP
Storm water Pollution Prevention Plan
TBC
T o-be-Considered
TCE
trichloroethene
TCLP
Toxicity Characteristic Leaching Procedure
THPO
Tribal Historic Preservation Officer
TM-l-P
2,4,4-trimethyl-1 -pentene
TM-2-P
2,4,4-trimethyl-2-pentene
TMPs
trimethylpentenes
TSDF
treatment, storage, and disposal facility
TRY
Toxicity Reference Value
UCL
Upper Confidence Limit
UDMH
unsymmetrical dimethylhydrazine
USAGE
United States Army Corps of Engineers
USEPA
United States Environmental Protection Agency
uv
ultra-violet
UVOST
ultra-violet optical screening tool
VI
Vapor Intrusion
VISL
Vapor Intrusion Screening Level
voc
Volatile Organic Compound
VPH
volatile petroleum hydrocarbons
WBV
Western Bedrock Valley
WERC
Wilmington Environmental Restoration Committee
WSL
Woburn Sanitary Landfill
Record of Decision
Olin Chemical Superfund Site
Wilmington, Massachusetts
Appendix F
March 2021
Page 4 of 4
-------
Appendix G
Administrative Record Index and Guidance Documents
Record of Decision Appendix G
Olin Chemical Superfund Site March 2021
Wilmington, Massachusetts
-------
Olin Chemical
NPL Site Administrative Record
Record of Decision (ROD)
Final Action (Operable Units 1 & 2)
Interim Action (Operable Unit 3)
Index
ROD Dated: March 2021
Released: March 2021
Prepared by
EPA New England
Superfund & Emergency Management Division
-------
Introduction to the Collection
This is the administrative record for the Olin Chemical Superfund Site, Wilmington, MA, Record
of Decision (ROD), dated March 2021. The Record of Decision consists of a final remedial
action for Operable Units (OUs) 1 & 2, and an interim remedial action for OU 3. The file
contains site-specific documents and a list of guidance documents used by EPA staff in selecting
a response action at the site.
This record replaces the administrative record file for the Olin Chemical Superfund Site,
Wilmington, MA, Record of Decision (ROD) Proposed Plan, dated August 2020. Documents
listed as bibliographic sources in individual reports might not be listed separately in the index.
The administrative record file is available for review at:
Online: https://go.usa.gov/xGb7a
Additional information about the site is also available at www.epa.gov/superfund/olin.
The EPA is temporarily suspending its Regional Records Centers for public visitors to reduce the
risk of transmitting COVID-19. In addition, many site information repositories are closed and
information in these repositories, including the administrative record file, has not been updated.
The EPA continues to carefully and continuously monitor information from the Centers for
Disease Control and Prevention (CDC), local area health departments, and our Federal partners
so that we can respond rapidly as conditions change regarding COVID-19.
For assistance with access or for questions, contact (note that because of government COVID-19
restrictions EPA's Offices may not be open to the public):
SEMS Records & Information Center
U.S. EPA Region 1 - New England
5 Post Office Square, Suite 100 (mail code: 02-3)
Boston, MA 02109-3912
(617)918-1440 (phone)
R1 ,Records-SEMS@epa. gov (email)
An administrative record is required by the Comprehensive Environmental Response,
Compensation, and Liability Act (CERCLA), as amended by the Superfund Amendments and
Reauthorization Act (SARA).
Questions about this administrative record should be directed to the EPA New England site
manager, Melanie Morash (617) 918-1292, morash.melanie@epa.gov.
-------
AR66515 & Interim Record of Decision (ROD) - Operable March
AR66514 Units (OU) 1,2, & 3 2021
Document ID
Title
Document
Date
Page
Author
Addressee
Resource Type
Program Information
Access Control
Region
URL
653925
RECORD OF DECISION (ROD)
3/30/2021
444
Rl: (US EPA REGION 1)
RPT/ Report
053 KLMLDIAL/U!)31 lf.jni.jdy
Characterizat ion/05.04-RECORD OF
DECISION (ROD)
UCTL( Uncontrolled)
1
htt Ds://semsoub.epa.gov/src/document/Ql/653925
653926
RESPONSIVENESS SUMMARY
3/30/2021
59
Rl: (US EPA REGION 1)
RPT/ Report
053-REMEDIAL/0531-Remedy
Characterizat ion/05.03-
RESPONSIVENESS SUMMARIES
UCTL( Uncontrolled)
1
htt Ds://semsoub.epa.gov/src/document/Ql/653926
653927
LETTER REGARDING CONCURRENCE WITH RECORD OF
DECISION (ROD)
3/25/2021
15
R01; Locke, Paul W (MA DEPT OF
ENVIRONMENTAL PROTECTION)
R01: Cianciarub, Robert G (US EPA REGION 1)
LTR/Letter
053-REMEDIAL/0531-Remedy
Characterizat ion/05.01-
CORRESPONDENCE
UCTL( Uncontrolled)
1
htt os://semspub.epa.gov/src/document/01/653927
653900
MEMO REGARDING CLEANUP LEVEL FORAMMONIA IN
SURFACE WATER
3/10/2021
10
R01: Brunelle, Jeffrey (NOBIS ENGINEERING),
R01: Delong,T (NOBIS GROUP), R01: Lambert, J
(NOBIS GROUP)
MEMO/Memorandum
053-REMEDIAL/0531-Remedy
Characterizat ion/04.04-INTERIM
DELIVERABLES(FS)
UCTL( Uncontrolled)
1
httBs://semspub.epa.gov/src/document/01/6539QQ
100016500
LETTER REGARDING INITIATION OF SECTION 106
CONSULTATION WITH CONCURRENCE STAMP
2/22/2021
6
R01: Morash, Melanie (US EPA REGION 1)
R01: Simon, Brona (MA HISTORICAL
COMMISSION), R01: Weeden, David (MASHPEE
WAMPANOAG TRIBE)
LTR/Letter
053-REMEDIAL/0531-Remedy
Characterizat ion/16.01-
CORRESPONDENCE(NATURAL
RESOURCE TRUSTEE)
UCTL( Uncontrolled)
1
httos://semspub.epa,gov/src/document/01/100016500
100016176
LETTER REGARDING INITIATION OF SECTION 106
CONSULTATION (CERTIFIED MAIL RECEIPTS ATTACHED)
1/19/2021
18
R01: Morash, Melanie (US EPA REGION 1)
R01: Simon, Brona (MA HISTORICAL
COMMISSION), R01: Weeden, David (MASHPEE
WAMPANOAG TRIBE)
LTR/Letter
053-REMEDIAL/0531-Remedy
Characterizat ion/16.01-
CORRESPONDENCE(NATURAL
RESOURCE TRUSTEE)
UCTL( Uncontrolled)
1
htt Ds://semsou b.epa.gov/src/docu ment/01/100016176
100002726
News Release: EPA Releases Tenth Update to the
Administrator's Emphasis List, Continuing to Accelerate
Progress in Cleaning Up the Nation's Land by Achieving
Significant Milestones at 8 Sites Across the Country
1/15/2021
4
Rll: (U.S. EPA)
PUB/Publication
051-COMMUNITY
INVOLVEMENT/0511-Community
Involvement Activities/A4.6-
Community Involvement Plan
UCTL( Uncontrolled)
11
htt Ds://semsou b.epa.gov/src/docu ment/11/100002726
652694
OEHHATOXICrTY CRITERIA DATABASE
12/9/2020
1
R01: (STATE OF CA OFFICE OF HEALTH HAZARD
ASSESSMENT)
CHT / Chart/Table
056-SITE SUPPORT/0561-
Administrative Support/17.07-
REFERENCE DOCUMENTS
UCTL( Uncontrolled)
1
htt Ds://semspub.epa.gov/src/document/01/652694
649997
NEWS RELEASE: EPA TO CONDUCT AERIAL SURVEY OF
OLIN CHEMIAL SUPERFUND SITE IN WILMINGTON, MA
WEEKOF 11/09/2020 OR 11/16/2020
11/9/2020
3
R01: (US EPA REGION 1)
PUB/Publication
051-COMMUNITY
INVOLVEMENT/0511-Community
Involvement Activities/13.03-NEWS
CUPPINGS/PRESS RELEASES
UCTL( Uncontrolled)
1
htt Ds://semspub.epa.gov/src/document/01/649997
649954
EMAIL REGARDING COMMENTS ON PROPOSED PLAN
10/26/2020
1
R01: Pribyl, Lee (MASSACHUSETTS INSTITUTE
OF TECHNOLOGY (MrT))
R01: Morash, Melanie (US EPA REGION 1)
EML/Email
053-REMEDIAL/0531-Remedy
Characterizat ion/05.03-
RESPONSIVENESS SUMMARIES
UCTL( Uncontrolled)
1
htt Ds://semsoub.epa.gov/src/document/Ql/649954
649957
EMAIL REGARDING COMMENTS ON PROPOSED PLAN
10/26/2020
1
R01: Feng, Haosheng (MASSACHUSETTS
INSTITUTE OF TECHNOLOGY (MIT))
R01: Morash, Melanie (US EPA REGION 1)
EML/Email
053-REMEDIAL/0531-Remedy
Characterizat ion/05.03-
RESPONSIVENESS SUMMARIES
UCTL( Uncontrolled)
1
htt Ds://semsoub.epa.gov/src/document/Ql/649957
649960
EMAIL REGARDING COMMENTS ON PROPOSED PLAN
(10/20/2020 COMMENT LETTERATTACHED)
10/26/2020
4
R01: Beard, Jessica C (MASSACHUSETTS
INSTITUTE OF TECHNOLOGY (MIT))
R01: Morash, Melanie (US EPA REGION 1)
EML/Email
053-REMEDIAL/0531-Remedy
Characterizat ion/05.03-
RESPONSIVENESS SUMMARIES
UCTL( Uncontrolled)
1
htt Ds://semsoub.epa.gov/src/document/Ql/64996Q
649962
EMAIL REGARDING COMMENTS ON PROPOSED PLAN
10/26/2020
1
R01: Brooks, Lee
R01: Morash, Melanie (US EPA REGION 1)
EML/Email
053-REMEDIAL/0531-Remedy
Characterizat ion/05.03-
RESPONSIVENESS SUMMARIES
UCTL( Uncontrolled)
1
htt Ds://semsoub.epa.gov/src/document/Ql/649962
649964
EMAIL REGARDING COMMENTS ON PROPOSED PLAN
10/26/2020
1
R01: Riedinger, Kristen (MASSACHUSETTS
INSTITUTE OF TECHNOLOGY (MIT))
R01: Morash, Melanie (US EPA REGION 1)
EML/Email
053-REMEDIAL/0531-Remedy
Characterizat ion/05.03-
RESPONSIVENESS SUMMARIES
UCTL( Uncontrolled)
1
htt Ds://semsoub.epa.gov/src/document/Ql/649964
649965
LETTER REGARDING COMMENTS ON PROPOSED PLAN
10/26/2020
3
R01: Poitras, Brian A (WILMINGTON WOBURN
INTERMODAL LLC)
R01: Morash, Melanie (US EPA REGION 1)
LTR/Letter
053-REMEDIAL/0531-Remedy
Characterizat ion/05.03-
RESPONSIVENESS SUMMARIES
UCTL( Uncontrolled)
1
htt Ds://semsoub.epa.gov/src/document/Ql/649965
649966
LETTER REGARDING COMMENTS ON PROPOSED PLAN
10/26/2020
5
R01: Stevenson, Martha (WERC)
R01: Jennings, Lynne (US EPA REGION 1)
LTR/Letter
053-REMEDIAL/0531-Remedy
Characterizat ion/05.03-
RESPONSIVENESS SUMMARIES
UCTL( Uncontrolled)
1
htt Ds://semsoub.epa.gov/src/document/Ql/649966
649968
EMAIL REGARDING COMMENTS ON PROPOSED PLAN
10/26/2020
2
R01: Baima, Stephanie (WILMINGTON (MA)
RESIDENT OF)
R01: Morash, Melanie (US EPA REGION 1)
EML/Email
053-REMEDIAL/0531-Remedy
Characterizat ion/05.03-
RESPONSIVENESS SUMMARIES
UCTL( Uncontrolled)
1
htt Ds://semsoub.epa.gov/src/document/Ql/649968
649969
MEMO REGARDING TECHNICAL COMMENTS ON
UPDATES TO OPERABLE UNrT (OU) 1 AND 2 REPORT,
FEASIBILITY STUDY (FS) VOL1, INTERIM ACTION FS
VOL 2, COMPRATIVE ANALYSIS VOL. 3, AND PROPOSED
PLAN
10/26/2020
18
R01: (WILMINGTON ENVIRONMENTAL
RESTORATION COMMITTEE)
R01: Jennings, Lynne (US EPA REGION 1), R01:
Morash, Melanie (US EPA REGION 1), R01:
Waldeck, Garry (MA DEPT OF ENVIRONMENTAL
PROTECTION)
MEMO/Memorandum
053-REMEDIAL/0531-Remedy
Characterizat ion/05.03-
RESPONSIVENESS SUMMARIES
UCTL( Uncontrolled)
1
htt Ds://semsoub.epa.gov/src/document/Ql/649969
649972
EMAIL REGARDING COMMENTS ON PROPOSED PLAN
10/26/2020
1
R01: Baima, Jennifer (WILMINGTON (MA)
RESIDENT OF)
R01: Morash, Melanie (US EPA REGION 1)
EML/Email
053-REMEDIAL/0531-Remedy
Characterizat ion/05.03-
RESPONSIVENESS SUMMARIES
UCTL( Uncontrolled)
1
htt Ds://semsoub.epa.gov/src/document/Ql/649972
649974
EMAIL REGARDING COMMENTS ON PROPOSED PLAN
10/26/2020
1
R01: Baima, Charles (WILMINGTON (MA)
RESIDENT OF)
R01: Morash, Melanie (US EPA REGION 1)
EML/Email
053-REMEDIAL/0531-Remedy
Characterizat ion/05.03-
RESPONSIVENESS SUMMARIES
UCTL( Uncontrolled)
1
htt Ds://semsoub.epa.gov/src/document/Ql/649974
-------
649975
SPECIFIC RECOMMENDATIONS AND PROPOSAL TO
COLLABORATE FROM THE MIT SUPERFUND RESEARCH
PROGRAM
10/26/2020
2
kOi: Kay, Jennifer (MAiiALHUiLNi
INSTITUTE OF TECHNOLOGY (MIT)), R01: Beard,
Jessica C (MASSACHUSETTS INSTITUTE OF
TECHNOLOGY(MIT)), R01: Vandiver, Kathy
(MASSACHUSETTS INSTITUTE OF TECHNOLOGY
(MIT)), R01: Swager, Timothy
(MASSACHUSETTS INSTITUTE OF TECHNOLOGY
(MIT)), R01: Engelward, Bevin
(MASSACHUSETTS INSTITUTE OF TECHNOLOGY
(MIT))
R01: (US EPA REGION 1)
RPT/ Report
053-REMEDIAL/0531-Remedy
Characterizat ion/05.03-
RESPONSIVENESS SUMMARIES
UCTL( Uncontrolled)
1
httDs://semspub.epa.gov/src/document/01/649975
649976
COMMENTS ON PROPOSED PLAN
10/26/2020
3
KOI: Kay, Jennifer (MASSACHUStl IS
INSTITUTE OF TECHNOLOGY (MIT)), R01: Beard,
Jessica C (MASSACHUSETTS INSTITUTE OF
TECHNOLOGY(MIT)), R01: Vandiver, Kathy
(MASSACHUSETTS INSTITUTE OF TECHNOLOGY
(MIT)), R01: Swager, Timothy
(MASSACHUSETTS INSTITUTE OF TECHNOLOGY
(MIT)), R01: Engelward, Bevin
(MASSACHUSETTS INSTITUTE OF TECHNOLOGY
(MIT))
R01: (US EPA REGION 1)
RPT/ Report
053-REMEDIAL/0531-Remedy
Characterizat ion/05.03-
RESPONSIVENESS SUMMARIES
UCTL( Uncontrolled)
httDs://semspub.epa.gov/src/document/01/649976
649978
EMAIL REGARDING COMMENTS ON PROPOSED PLAN
10/26/2020
1
R01: Armijo, Amanda (MASSACHUSETTS
INSTITUTE OF TECHNOLOGY (MIT))
R01: Morash, Melanie (US EPA REGION 1)
EML/Email
053-REMEDIAL/0531-Remedy
Characterizat ion/05.03-
RESPONSIVENESS SUMMARIES
UCTL( Uncontrolled)
httos://semspub. epa.gov/src/document/01/649978
649980
EMAIL REGARDING COMMENTS ON PROPOSED PLAN
10/26/2020
1
R01: Hrdina, Amy (MASSACHUSETTS INSTITUTE
OF TECHNOLOGY (MrT))
R01: Morash, Melanie (US EPA REGION 1)
EML/Email
053-REMEDIAL/0531-Remedy
Characterizat ion/05.03-
RESPONSIVENESS SUMMARIES
UCTL( Uncontrolled)
htt Ds://semsou b.epa.gov/src/docu ment/01/649980
649982
EMAIL REGARDING COMMENTS ON PROPOSED PLAN
10/26/2020
1
R01: Owiti, Norah A (MASSACHUSETTS
INSTITUTE OF TECHNOLOGY (MIT))
R01: Morash, Melanie (US EPA REGION 1)
EML/Email
053-REMEDIAL/0531-Remedy
Characterizat ion/05.03-
RESPONSIVENESS SUMMARIES
UCTL( Uncontrolled)
httos://semspub. epa.gov/src/document/01/649982
649984
EMAIL REGARDING COMMENTS ON PROPOSED PLAN
10/26/2020
1
R01: Moise, Aimee (MASSACHUSETTS
INSTITUTE OF TECHNOLOGY (MIT))
R01: Morash, Melanie (US EPA REGION 1)
EML/Email
053-REMEDIAL/0531-Remedy
Characterizat ion/05.03-
RESPONSIVENESS SUMMARIES
UCTL( Uncontrolled)
htt Ds://semsoub.epa.gov/src/document/01/649984
649985
COMMENTS ON PROPOSED PLAN
10/26/2020
1
R01: Kelly, Jaime M (MASSACHUSETTS
INSTITUTE OF TECHNOLOGY (MIT))
R01: (US EPA REGION 1)
RPT/ Report
053-REMEDIAL/0531-Remedy
Characterizat ion/05.03-
RESPONSIVENESS SUMMARIES
UCTL( Uncontrolled)
httBs://semspub.epa.gov/src/document/01/649985
649931
EMAIL REGARDING COMMENTS ON PROPOSED PLAN
10/23/2020
2
R01: Waldeck, Garry (MA DEPT OF
ENVIRONMENTAL PROTECTION)
R01: Morash, Melanie (US EPA REGION 1)
EML/Email
053-REMEDIAL/0531-Remedy
Characterizat ion/05.03-
RESPONSIVENESS SUMMARIES
UCTL( Uncontrolled)
httos://semspub.epa,gov/src/document/01/S49931
649914
LETTER REGARDING COMMENTS ON PROPOSED PLAN
10/22/2020
3
R01: Eaton, Jonathan R (WILMINGTON (MA)
TOWN OF)
R01: Morash, Melanie (US EPA REGION 1)
LTR/Letter
053-REMEDIAL/0531-Remedy
Characterizat ion/05.03-
RESPONSIVENESS SUMMARIES
UCTL( Uncontrolled)
httos://semspub.epa,gov/src/document/01/S49914
649915
LETTER REGARDING COMMENTS ON PROPOSED PLAN
10/22/2020
5
R01: Reynolds, Robert C (GEOINSIGHT INC),
R01: Trainer, Kevin D (GEOINSIGHT INC)
R01: Morash, Melanie (US EPA REGION 1)
LTR/Letter
053-REMEDIAL/0531-Remedy
Characterizat ion/05.03-
RESPONSIVENESS SUMMARIES
UCTL( Uncontrolled)
httos://semspub.epa,gov/src/document/01/S49915
649917
EMAIL REGARDING COMMENTS ON PROPOSED PLAN
10/22/2020
1
R01: Corless, Elliot (MASSACHUSETTS
INSTITUTE OF TECHNOLOGY (MIT))
R01: Morash, Melanie (US EPA REGION 1)
EML/Email
053-REMEDIAL/0531-Remedy
Characterizat ion/05.03-
RESPONSIVENESS SUMMARIES
UCTL( Uncontrolled)
httos://semspub.epa,gov/src/document/01/S49917
100015886
PRESENTATION - AERIAL ELECTROMAGNETIC (AEM)
SURVEY
10/22/2020
3
R01: (OLIN CORP)
MTG / Meeting Document
051-COMMUNITY
INVOLVEMENT/0511-Community
Involvement Activities/13.04-PUBLIC
MEETINGS/HEARINGS
UCTL( Uncontrolled)
httos://semspub.epa,gov/src/document/01/10001588S
100015887
TALKING POINTS FOR 10/22/2020 PRESENTATION TO
THE TOWN OF WILLMINGTON'S BOARD OF SELECTMEN
10/22/2020
1
R01: Cashwell, James M (OLIN CORP)
R01: (WILMINGTON (MA) BOARD OF
SELECTMEN)
MTG / Meeting Document
051-COMMUNITY
INVOLVEMENT/0511-Community
Involvement Activities/13.04-PUBLIC
MEETINGS/HEARINGS
UCTL( Uncontrolled)
httos://semspub.epa,gov/src/document/01/100015887
649910
EMAIL REGARDING COMMENTS ON PROPOSED PLAN
10/21/2020
3
R01: Kaushal, Simran (MASSACHUSETTS
INSTITUTE OF TECHNOLOGY (MIT))
R01: Morash, Melanie (US EPA REGION 1)
EML/Email
053-REMEDIAL/0531-Remedy
Characterizat ion/05.03-
RESPONSIVENESS SUMMARIES
UCTL( Uncontrolled)
httos://semspub.epa,gov/src/document/01/S49910
649599
LETTER REGARDING COMMENTS ON PROPOSED PLAN
(TRANSMITTAL EMAILATTACHED)
10/20/2020
4
R01: Kay, Jennifer (MASSACHUSETTS INSTITUTE
OF TECHNOLOGY (MrT))
R01: Morash, Melanie (US EPA REGION 1)
LTR/Letter
053-REMEDIAL/0531-Remedy
Characterizat ion/05.03-
RESPONSIVENESS SUMMARIES
UCTL( Uncontrolled)
httDs://semspub.epa.gov/src/document/01/649599
100015763
LETTER REGARDING UPCOMING AERIAL
ELECTROMAGNETIC (AEM) SURVEY (FACT SHEET
ATTACHED)
10/19/2020
4
R01: Cashwell, James M (OLIN CORP)
R01: Hull, Jeffrey M (WILMINGTON (MA)
TOWN OF)
LTR/Letter
051-COMMUNITY
INVOLVEMENT/0511-Community
Involvement Activities/13.01-
CORRESPONDENCE (COMMUNITY
RELATIONS)
UCTL( Uncontrolled)
httos://semspub.epa,gov/src/document/01/100015763
100015428
LETTER REGARDING COMMENTS ON PROPOSED PLAN
(COMMENTS ATTACHED)
10/2/2020
11
R01: Cashwell, James M (OLIN CORP)
R01: Morash, Melanie (US EPA REGION 1)
LTR/Letter
053-REMEDIAL/0531-Remedy
Characterizat ion/05.03-
RESPONSIVENESS SUMMARIES
UCTL( Uncontrolled)
httos://semspub.epa,gov/src/document/01/100015428
649561
VIRTUAL PUBLIC HEARING CONFERENCE CALL
TRANSCRIPT
9/22/2020
30
R01: Jennings, Lynne(US EPA REGION 1)
MTG / Meeting Document
051-COMMUNITY
INVOLVEMENT/0511-Community
Involvement Activities/13.04-PUBLIC
MEETINGS/HEARINGS
UCTL( Uncontrolled)
httos://semspub.epa,gov/src/document/01/649561
-------
649224
NEWS RELEASE: EPA EXTENDS PUBLIC COMMENT
PERIOD FOR PROPOSED CLEANUP PLAN FOR OLIN
CHEMICALSUPERFUNDSITE IN WILMINGTON, MA
9/15/2020
2
R01: (US EPA REGION 1)
PUB/Publication
051-COMMUNITY
INVOLVEMENT/0511-Community
Involvement Activities/13.03-NEWS
CUPPINGS/PRESS RELEASES
UCTL( Uncontrolled)
1
httDs://semspub.epa.gov/src/document/Gl/649224
100015427
EMAIL REGARDING PRE-REGISTRATION FOR PROVIDING
ORAL COMMENTS DURING 09/22/2020 PUBLIC
HEARING
9/10/2020
2
R01: White, Sarah (US EPA REGION 1)
EML/Email
051-COMMUNITY
INVOLVEMENT/0511-Community
Involvement Activities/13.04-PUBLIC
MEETINGS/HEARINGS
UCTL( Uncontrolled)
1
httos://semspub.epa,gov/src/document/Gl/10GG15427
648692
EMAIL REPLYING TO REQUEST FOR EXTENSION OF 30-
DAY COMMENT PERIOD (EMAIL HISTORY ATTACHED)
[REDACTED]
9/9/2020
2
R01: Morash, Melanie (US EPA REGION 1)
R01: Dilorenzo, James M (US EPA REGION 1),
R01: Pechulis, Kevin P (US EPA REGION 1), R01:
Jennings, Lynne (US EPA REGION 1), R01:
Shewack, Robert (US EPA REGION 1), R01:
Stevenson, Martha (WERC)
EML/Email
051-COMMUNITY
INVOLVEMENT/0511-Community
Involvement Activities/13.01-
CORRESPONDENCE (COMMUNITY
RELATIONS)
UCTL( Uncontrolled)
1
httos://semspub. 8pa.gov/sir/document/01/648692
648686
EMAIL REQUESTING EXTENSION OF 30-DAY COMMENT
PERIOD [REDACTED]
9/8/2020
1
R01: Stevenson, Martha (WERC)
R01: Dilorenzo, James M (US EPA REGION 1),
R01: Pechulis, Kevin P (US EPA REGION 1), R01:
Jennings, Lynne (US EPA REGION 1), R01:
Morash, Melanie (US EPA REGION 1), R01:
Shewack, Robert (US EPA REGION 1)
EML/Email
051-COMMUNITY
INVOLVEMENT/0511-Community
Involvement Activities/13.01-
CORRESPONDENCE (COMMUNITY
RELATIONS)
UCTL( Uncontrolled)
1
httDs://semspub.epa.gov/src/document/Gl/648686
100014400
PUBLIC MEETING PRESENTATION (PDF VERSION)
8/25/2020
33
R01: (US EPA REGION 1)
MTG / Meeting Document
051-COMMUNITY
INVOLVEMENT/0511-Community
Involvement Activities/13.04-PUBLIC
MEETINGS/HEARINGS
UCTL( Uncontrolled)
1
httDs://semspub.epa,gov/src/document/01/100014400
647840
PUBLIC NOTICE: EPA ANNOUNCES PROPOSED PLAN TO
CLEAN UP THE OLIN CHEMICAL SUPERFUND SITE IN
WILMINGTON, MA
8/12/2020
1
R01: (US EPA REGION 1)
PUB/Publication
051-COMMUNITY
INVOLVEMENT/0511-Community
Involvement Activities/13.03-NEWS
CUPPINGS/PRESS RELEASES
UCTL( Uncontrolled)
1
httDs://semspub.epa.gov/srt/document/01/64784Q
100014355
PRESS RELEASE: EPA ANNOUNCES PROPOSED PLAN TO
BEGIN CLEAN UP OFTHE OLIN CHEMICAL SUPERFUND
SITE IN WILMINGTON, MA
8/12/2020
3
R01: (US EPA REGION 1)
PUB/Publication
051-COMMUNITY
INVOLVEMENT/0511-Community
Involvement Activities/13.03-NEWS
CUPPINGS/PRESS RELEASES
UCTL( Uncontrolled)
1
httDs://semspub.epa,gov/src/document/01/10QQ14355
100014373
NOTIFICATION TO POTENTIALLY INTERESTED PARTY
(PIP) OF FORTHCOMING PROPOSED CLEANUP PLAN -
BAYER CORP
8/12/2020
12
R01: Jennings, Lynne (US EPA REGION 1)
R01: Partridge, Scott (BAYER CORP)
LTR/Letter
052-ENFORCEMENT/0522-
Negotiat ions/10.01-
CORRESPONDENCE
(ENFORCEMENT/NEGOTIATION)
UCTL( Uncontrolled)
1
httDs://semspub.epa,gov/src/document/01/10QQ14373
100014374
NOTIFICATION TO POTENTIALLY INTERESTED PARTY
(PIP) OF FORTHCOMING PROPOSED CLEANUP PLAN -
SANOFI US SERVICES INC
8/12/2020
12
R01: Jennings, Lynne (US EPA REGION 1)
R01: Lee, Chan (SANOFI US SERVICES INC)
LTR/Letter
052-ENFORCEMENT/0522-
Negotiat ions/10.01-
CORRESPONDENCE
(ENFORCEMENT/NEGOTIATION)
UCTL( Uncontrolled)
1
httDs://semspub.epa,gov/src/document/01/10QQ14374
100014426
PUBLIC NOTICE AS APPEARING IN WILMINGTON TOWN
CRIER: EPA ANNOUNCES PROPOSED PLAN TO CLEAN UP
THE OLIN CHEMICAL SUPERFUND SITE IN
WILMINGTON, MA
8/12/2020
1
R01: (US EPA REGION 1), R01: (WILMINGTON
TOWN CRIER)
PUB/Publication
051-COMMUNITY
INVOLVEMENT/0511-Community
Involvement Activities/13.03-NEWS
CUPPINGS/PRESS RELEASES
UCTL( Uncontrolled)
1
httDs://semspub.epa,gov/src/document/01/10QQ14426
100014368
EMAIL REGARDING UPCOMING PUBLIC
INFORMATIONAL MEETING (PROPOSED PLAN AND
SAVETHE DATE POSTCARD ATTACHED)
8/11/2020
55
R01: Pechulis, Kevin (US EPA REGION 1)
R01: Cashwell, James M (OLIN CORP), R01:
Funderberg, Lisa A (OLIN CORP), R01: Share,
David M (OLIN CORPORATION)
EML/Email
051-COMMUNITY
INVOLVEMENT/0511-Community
Involvement Activities/13.01-
CORRESPONDENCE (COMMUNITY
RELATIONS)
UCTL( Uncontrolled)
1
httDs://semspub.epa,gov/src/document/01/10QQ14368
100014369
EMAIL REGARDING UPCOMING PUBLIC
INFORMATIONAL MEETING (PROPOSED PLAN AND
SAVETHE DATE POSTCARD ATTACHED)
8/11/2020
55
R01: Pechulis, Kevin (US EPA REGION 1)
R01: Feist, S
EML/Email
051-COMMUNITY
INVOLVEMENT/0511-Community
Involvement Activities/13.01-
CORRESPONDENCE (COMMUNITY
RELATIONS)
UCTL( Uncontrolled)
1
httDs://semspub.epa,gov/src/document/01/10QQ14369
100014370
EMAIL REGARDING UPCOMING PUBLIC
INFORMATIONAL MEETING (PROPOSED PLAN AND
SAVETHE DATE POSTCARD ATTACHED)
8/11/2020
55
R01: Pechulis, Kevin (US EPA REGION 1)
R01: Guilliani, V
EML/Email
051-COMMUNITY
INVOLVEMENT/0511-Community
Involvement Activities/13.01-
CORRESPONDENCE (COMMUNITY
RELATIONS)
UCTL( Uncontrolled)
1
httDs://semspub.epa,gov/src/document/01/10QQ1437Q
100014371
EMAIL REGARDING UPCOMING PUBLIC
INFORMATIONAL MEETING (PROPOSED PLAN AND
SAVETHE DATE POSTCARD ATTACHED)
8/11/2020
55
R01: Pechulis, Kevin (US EPA REGION 1)
R01: Amidon, David M (BURNS & LEVINSON
LLP)
EML/Email
051-COMMUNITY
INVOLVEMENT/0511-Community
Involvement Activities/13.01-
CORRESPONDENCE (COMMUNITY
RELATIONS)
UCTL( Uncontrolled)
1
httDs://semspub.epa.gov/srt/document/Gl/10GG14371
647859
MEMO REGARDING UPDATESTO REMEDIAL
INVESTIGATION (Rl) REPORT CONCLUSIONS
8/5/2020
20
R01: Dilorenzo, James (US EPA REGION 1)
MEMO/Memorandum
053-REMEDIAL/0531-Remedy
Characterization/03.06-REMEDIAL
INVESTIGATION REPORTS
UCTL( Uncontrolled)
1
httDs://semspub.epa.gov/src/document/Gl/647859
647860
MEMO REGARDING FEASIBILITYSTUDY(FS) REPORT,
VOLUME 3 OF 3 - COMPARATIVE ANALYSES
8/5/2020
48
R01: Jennings, Lynne (US EPA REGION 1)
MEMO/Memorandum
053-REMEDIAL/0531-Remedy
Characterization/04.06-FEASIBILITY
STUDY REPORTS
UCTL( Uncontrolled)
1
httDs://semspub.epa.gov/src/document/Gl/64786G
647882
MEMO REGARDING UPDATESTO DRAFT2019
REMEDIAL INVESTIGATION (Rl) REPORT CONCLUSIONS
8/5/2020
25
R01: Dilorenzo, James (US EPA REGION 1)
MEMO/Memorandum
053-REMEDIAL/0531-Remedy
Characterization/03.06-REMEDIAL
INVESTIGATION REPORTS
UCTL( Uncontrolled)
1
httDs://semspub.epa.gov/src/document/Gl/647882
647851
MEMO REGARDING PROPOSED PLAN PUBLIC
COMMENT PERIOD - VIRTUAL PUBLIC MEETING
MEASURES
8/3/2020
2
R01: Pechulis, Kevin (US EPA REGION 1)
MEMO/Memorandum
051-COMMUNITY
INVOLVEMENT/0511-Community
Involvement Activities/13.01-
CORRESPONDENCE (COMMUNITY
RELATIONS)
UCTL( Uncontrolled)
1
httos://semspub.epa,gov/src/document/Gl/647851
-------
647828
SAVETHE DATE POSTCARD, VIRTUAL MEETING AND
HEARING 08/25/2020 AND 09/22/2020
8/1/2020
2
R01: (US EPA REGION 1)
MTG / Meeting Document
051-COMMUNITY
INVOLVEMENT/0511-Community
Involvement Activities/13.04-PUBLIC
MEETINGS/HEARINGS
UCTLJUn
ontrolled)
1
httos:
/semsoub.eD3.gov/src/document/01/647828
647858
INTERIM ACTION FEASIBILITY STUDY (FS), VOLUME 2
OF 3 (08/03/2020 TRANSMITTAL LETTERATTACHED)
8/1/2020
864
R01: (OLIN CORPORATION)
R01: (US EPA REGION 1)
RPT/ Report
053-REMEDIAL/0531-Remedy
Characterization/04.06-FEASIBILITY
STUDY REPORTS
UCTLJUn
ontrolled)
1
httos:
/semsoub.eD3.gov/src/document/01/647858
647883
PROPOSED PLAN
8/1/2020
52
R01: (US EPA REGION 1)
RPT/ Report
053-REMEDIAL/0531-Remedy
Characterization/04.09-PRO POSED
PLANS FOR SELECTED REMEDIAL
ACTION
UCTLJUn
ontrolled)
1
httos:
/semsoub.eDa.gov/src/document/01/647883
647850
FEASIBILITY STUDY (FS), VOLUME 1 OF 3 (TRANSMITTAL
LETTERATTACHED)
7/31/2020
276
R01: (OLIN CORPORATION)
R01: (US EPA REGION 1)
RPT/ Report
053-REMEDIAL/0531-Remedy
Characterization/04.06-FEASIBILITY
STUDY REPORTS
UCTLJUn
ontrolled)
1
httos:
/semsoub.eDa.gov/src/document/01/647850
647843
ADDRESS LISTS FOR SAVE THE DATE POSTCARD,
VIRTUAL MEETING AND HEARING 08/25/2020 AND
09/22/2020
7/30/2020
1
R01: (US EPA REGION 1)
LST/ List/Index
051-COMMUNITY
INVOLVEMENT/0511-Community
Involvement Activities/13.06-
MAILING LISTS
PRVY /
Controlled/Privacy
1
N/A
647583
MEMO REGARDING BENZO(A)PYRENE DISTRIBUTION
AND SURFACE WATER IMPACTS
7/20/2020
8
R01: Brunelle, Jeffrey (NOBIS ENGINEERING
INC), R01: Lambert, J (NOBISGROUP)
R01: Morash, Melanie (US EPA REGION 1)
MEMO/Mem
randum
053-REMEDIAL/0531-Remedy
Characterization/04.02-SAMPLING &
ANALYSIS DATA (FS)
UCTLJUn
ontrolled)
1
httos:
/semsoub.eDa.gov/src/document/01/647583
647282
TECHNICAL MEMORANDUM REGARDING
DOCUMENTATION OF PRELIMINARY REMEDIATION
GOALS (PRGS) TO ADDRESS HUMAN HEALTH RISKS IN
DENSE AQUEOUS-PHASE LIQUID (DAPL),
GROUNDWATER HOT SPOTS, UPLAND SOIL (INCLUDING
CONTAINMENT AREA SOIL), AND SURFACE WATER
7/1/2020
102
R01: Murphy, Michael, J (WOOD)
R01: Esakkiperumal, Chinny (OLIN
CORPORATION)
MEMO/Mem
053-REMEDIAL/0531-Remedy
Characterization/03.09-HEALTH
ASSESSMENTS
UCTLJUn
ontrolled)
1
httos:
/semsoub.eD3.gov/src/document/01/647282
647201
REDACTED EMAIL REGARDING QUESTION ON
PRELIMINARY REMEDIATION GOAL(PRG) FOR
AMMONIA IN SURFACE WATER (EMAIL HISTORY
ATTACHED)
6/17/2020
3
R01: Mercer, Gary (WILMINGTON
ENVIRONMENTAL RESTORATION COMMITTEE)
R01: Morash, Melanie (US EPA REGION 1)
EML/Email
053-REMEDIAL/0531-Remedy
Characterization/03.10-
ENDANGERMENT/BASELINE RISK
ASSESSMENTS
UCTLJUn
ontrolled)
1
httos:
/semsoub.eD3.gov/src/document/01/647201
647006
TECHNICAL MEMO REGARDING PRELIMINARY
EVALUATION OF FLOODPLAIN IMPACTS (TRANSMITTAL
LETTERATTACHED)
6/4/2020
5
R01: Walter, Nelson (WOOD ENVIRONMENT &
INFRASTRUCTURE SOLUTIONS INC)
R01: Cashwell, James M (OLIN CORP), R01:
Esakkiperumal, Chinny (OLIN CORPORATION)
MEMO/Mem
randum
053-REMEDIAL/0531-Remedy
Characterization/04.04-INTERIM
DELIVERABLES(FS)
UCTLJUn
ontrolled)
1
httos:
/semsoub.eD3.gov/src/document/01/647QQ6
646183
REVISED MEMO REGARDING REVISED HUMAN HEALTH
RISK CALCULATIONS FOR POTABLE USE OF PRIVATE
RESIDENTIAL WELLS AT PROPERTY 1 AND PROPERTY 2
(TRANSMITTAL LETTERATTACHED)
5/21/2020
164
R01: Thompson, Peter (OLIN CORP), R01:
Murphy, Michael (OLIN CORP)
R01: Cashwell, James M (OLIN CORP)
MEMO/Mem
053-REMEDIAL/0531-Remedy
Characterization/03.09-HEALTH
ASSESSMENTS
UCTLJUn
ontrolled)
1
httos:
/semsDub.eD3,gov/src/document/01/646183
646169
MEMO REGARDING DOCUMENTATION OF
PRELIMINARY REMEDIATION GOALS (PRGS) FOR SOILS,
SEDIMENTS, AND SURFACE WATER (TRANSMITTAL
LETTERATTACHED)
5/15/2020
55
R01: Murphy, Michael, J (WOOD)
R01: Esakkiperumal, Chinny (OLIN
CORPORATION)
MEMO/Mem
053-REMEDIAL/0531-Remedy
Characterization/04.04-INTERIM
DELIVERABLES(FS)
UCTLJUn
ontrolled)
1
httos:
/semsDub.eD3,gov/src/document/01/646169
100002469
For Regional Superfund Site Teams: CERCLA Interim
Guidance on Public Engagement During COVID-19
4/28/2020
2
Rll: (U.S. EPA)
LAWS/
Laws/Regu latio
ns/Gu idanc
058-PROGRAM SUPPORT/0583-
Regulatory Development/B8.4-
Directives and Policy Guidance
Documents
UCTLJUn
ontrolled)
11
httos:
/semsoub.eD3.gov/src/document/ll/100Q02469
100002476
Memorandum on Virtual Public Hearings and Meetings
4/16/2020
2
Rll: (Office of General Counsel)
LAWS/
Laws/Regu latio
ns/Gu idanc
058-PROGRAM SUPPORT/0583-
Regulatory Development/B8.4-
Directives and Policy Guidance
Documents
UCTLJUn
ontrolled)
11
httos:
/semsoub.eD3.gov/src/document/ll/10QQQ2476
646107
EMAILAPPROVING PROPOSAL TO APPEND THE
ONGOING QUARTERLY MONrTORING PROGRAM
(EMAIL HISTORY ATTACHED)
4/10/2020
7
R01: Morash, Melanie (US EPA REGION 1)
R01: Esakkiperumal, Chinny (OLIN
CORPORATION)
EML/Email
053-REMEDIAL/0534-Post
Construction/0801-
CORRESPONDENCE (POST REMEDIAL
ACTION)
UCTLJUn
ontrolled)
1
httos:
/semsDub.eD3,gov/src/document/01/646107
644595
MEMO REGARDING HEXAVALENT CHROMIUM IN
GROUNDWATER, SURFACE WATER, SEDIMENT, AND
SOIL (TRANSMITTAL LETTERATTACHED)
4/2/2020
128
R01: Murphy, Michael, J (WOOD), R01:
Kullman, Jane (WOOD ENVIRONMENT &
INFRASTRUCTURE SOLUTIONS INC)
R01: Esakkiperumal, Chinny (OLIN
CORPORATION)
MEMO/Mem
randum
053-REMEDIAL/0531-Remedy
Characterization/04.02-SAMPLING &
ANALYSIS DATA (FS)
UCTLJUn
ontrolled)
1
httos:
/semsoub.eD3.gov/src/document/01/644595
644569
MEMO REGARDING SUPPLEMENTAL
CHARACTERIZATION OF CONTAINMENT AREA SOIL
(TRANSMITTAL LETTERATTACHED)
3/20/2020
445
R01: Bowen, Elizabeth T (WOOD
ENVIRONMENT & INFRASTRUCTURE
SOLUTIONS INC), R01: Tull, Kerry (WOOD
ENVIRONMENT & INFRASTRUCTURE
SOLUTIONS INC)
R01: Cashwell, James M (OLIN CORP), R01:
Esakkiperumal, Chinny (OLIN CORPORATION)
MEMO/Mem
053-REMEDIAL/0531-Remedy
Characterizat ion/03.01-
CORRESPONDENCE (Rl)
UCTLJUn
ontrolled)
1
httos:
/semsoub.eD3.gov/src/document/01/644569
644544
EMAIL REGARDING EPA APPROVAL OF DATA GAPS
WORK PLAN - PHASE 1A PROPOSAL - SEISMIC WORK
(EMAIL HISTORY ATTACHED)
3/12/2020
6
R01: Morash, Melanie (US EPA REGION 1)
R01: Esakkiperumal, Chinny (OLIN
CORPORATION)
EML/Email
053-REMEDIAL/0531-Remedy
Characterizat ion/04.07-WORK
PLANS & PROGRESS REPORTS (FS)
UCTLJUn
ontrolled)
1
httos:
/semsoub.eD3.gov/src/document/01/644544
644516
LETTER REGARDING PROPOSALTO APPENDTHE
ONGOING QUARTERLY MONrTORING PROGRAM
3/6/2020
4
R01: Cashwell, James M (OLIN CORP)
R01: Morash, Melanie (US EPA REGION 1)
LTR/Letter
053-REMEDIAL/0534-Post
Construction/0801-
CORRESPONDENCE (POST REMEDIAL
ACTION)
UCTLJUn
ontrolled)
1
httos:
/semsDub.eD3,gov/src/document/01/644516
644517
MEMO RESPONDING TO COMMENTS AND
CONDITIONAL APPROVAL OF COMPREHENSIVE DATA
GAPS WORK PLAN - PHASE 1
3/6/2020
7
R01: Cashwell, James M (OLIN CORP)
R01: Jennings, Lynne (US EPA REGION 1), R01:
Morash, Melanie (US EPA REGION 1)
LTR/Letter
053-REMEDIAL/0531-Remedy
Characterizat ion/04.07-WORK
PLANS & PROGRESS REPORTS (FS)
UCTLJUn
ontrolled)
1
httos:
/semsDub.eD3,gov/src/document/01/644517
-------
644066
EMAIL RESUBMITTING CSM TRANSECT FIGURES
(FIGURESATTACHED)
2/28/2020
5
R01: Lambert, Jennifer (NOBIS GROUP)
kOi: Dilorenzo, James (Ui LPA ktGION 1), kOi:
Pechulis, Kevin P (US EPA REGION 1), R01:
Jennings, Lynne (US EPA REGION 1), R01: Ng,
Manchak (US EPA REGION 1), R01: Morash,
Melanie (US EPA REGION 1), R01: Brandon,
William C (US EPA REGION 1), R01: Waldeck,
Garry(MA DEPTOF ENVIRONMENTAL
PROTECTION), R01: Carroll, Courtney (US EPA
REGION 1), R01: Kelly, Christopher, J (US EPA
REGION 1)
EML/Email
053-REMEDIAL/0531-Remedy
Characterization/04.06-FEASIBILITY
STUDY REPORTS
UCTL( Uncontrolled)
1
htt Ds://semsoub.epa.gov/src/document/Gl/644G6S
644082
EMAIL REGARDING CONTAINMENT SOIL DATA
(RESULTS MEMO AND DATA SHEETS ATTACHED)
2/28/2020
175
R01: Lambert, Jennifer (NOBIS GROUP)
kOi: Dilorenzo, James (U*> LPA kLGION 1), kOi:
Pechulis, Kevin P (US EPA REGION 1), R01:
Jennings, Lynne (US EPA REGION 1), R01: Ng,
Manchak (US EPA REGION 1), R01: Morash,
Melanie (US EPA REGION 1), R01: Brandon,
William C (US EPA REGION 1), R01: Waldeck,
Garry(MA DEPTOF ENVIRONMENTAL
PROTECTION), R01: Carroll, Courtney (US EPA
REGION 1), R01: Kelly, Christopher, J (US EPA
REGION 1)
EML/Email
053-REMEDIAL/0531-Remedy
Characterization/04.06-FEASIBILITY
STUDY REPORTS
UCTL( Uncontrolled)
1
htt Ds://semsoub.epa.gov/src/document/Gl/644G82
644084
LETTER TRANSMITTING RESIDENTIAL WATER SUPPLY
RESULTS
2/24/2020
41
R01: Lambert, Jennifer (NOBIS GROUP)
R01: Morash, Melanie (US EPA REGION 1)
ADD/Analytical Data
Document
053-REMEDIAL/0531-Remedy
Characterization/04.02-SAMPLING &
ANALYSIS DATA (FS)
UCTL( Uncontrolled)
1
htt Ds://semsoub.epa.gov/src/document/Gl/644G84
644086
EMAIL REGARDING EPA COMMENTS ON PROPOSAL TO
AMEND THE QUARTERLY GROUNDWATER
MONITORING PROGRAM (EMAIL HISTORY AND
FIGURES OF MONITORING WELLS PROPOSED FOR
REMOVALATTACHED)
2/24/2020
10
R01: Lambert, Jennifer (NOBIS GROUP)
R01: Dilorenzo, James (US tPA REGION 1), R01:
Pechulis, Kevin P (US EPA REGION 1), R01:
Jennings, Lynne (US EPA REGION 1), R01: Ng,
Manchak (US EPA REGION 1), R01: Morash,
Melanie (US EPA REGION 1), R01: Brandon,
William C (US EPA REGION 1), R01: Waldeck,
Garry(MA DEPTOF ENVIRONMENTAL
PROTECTION), R01: Carroll, Courtney (US EPA
REGION 1), R01: Kelly, Christopher, J (US EPA
REGION 1)
EML/Email
053-REMEDIAL/0531-Remedy
Characterizat ion/04.01-
CORRESPONDENCE (FS)
UCTL( Uncontrolled)
htt Ds://semsoub.epa.gov/src/document/Gl/644G86
644089
MEMO REGARDING DENSE AQUEOUS PHASE LIQUID
(DAPL) ALTERNATIVE DETAILED ANALYSIS R6
2/21/2020
117
R01: Brunelle, Jeffrey (NOBIS ENGINEERING
INC), R01: Lambert,Jennifer(NOBISGROUP)
R01: (US EPA REGION 1)
MEMO/Memorandum
053-REMEDIAL/0531-Remedy
Characterization/04.06-FEASIBILITY
STUDY REPORTS
UCTL( Uncontrolled)
httBs://semspub.epa.gov/src/document/01/644Q89
647261
EMAIL REGARDING DATA GAPS WORK PLAN - PHASE 1A
PROPOSAL - SEISMIC WORK (EMAIL HISTORY
ATTACHED)
2/18/2020
4
R01: Morash, Melanie (US EPA REGION 1)
R01: Cashwell, James M (OLIN CORP)
EML/Email
053-REMEDIAL/0531-Remedy
Characterizat ion/04.01-
CORRESPONDENCE (FS)
UCTL( Uncontrolled)
httos://semspub.epa,gov/src/document/01/S4?2Sl
643525
EMAIL REGARDING EPA COMMENTS ON DATA GAPS
WORK PLAN - PHASE 1 (REVIEW MEMOS AND EMAIL
HISTORY ATTACHED)
1/31/2020
30
R01: Morash, Melanie (US EPA REGION 1)
R01: Cashwell, James M (OLIN CORP)
EML/Email
053-REMEDIAL/0531-Remedy
Characterizat ion/04.01-
CORRESPONDENCE (FS)
UCTL( Uncontrolled)
htt Ds://semsoub.epa.gov/src/document/Gl/643525
643505
MEMO REGARDING RESIDENTIAL HUMAN HEALTH RISK
EVALUATION-OPERABLE UNIT(OU) 1 AND 2 SOILS
1/17/2020
16
R01: Woods, C (BLUESTONE ENVIRONMENTAL
GROUP)
R01: Dilorenzo, James (US EPA REGION 1)
MEMO/Memorandum
053-REMEDIAL/0531-Remedy
Characterization/03.10-
ENDANGERMENT/BASELINE RISK
ASSESSMENTS
UCTL( Uncontrolled)
htt Ds://semsoub.epa.gov/src/document/Gl/6435G5
643161
EMAIL REGARDING COMMENTS ON PROPOSAL TO
AMEND THE QUARTERLY GROUNDWATER
MONITORING PROGRAM (EMAIL HISTORY ATTACHED)
1/4/2020
4
R01: Morash, Melanie (US EPA REGION 1)
R01: Esakkiperumal, Chinny (OLIN
CORPORATION)
EML/Email
053-REMEDIAL/0531-Remedy
Characterizat ion/04.01-
CORRESPONDENCE (FS)
UCTL( Uncontrolled)
httDs://semspub.epa.gov/src/document/Ql/S431Sl
644083
MEMO REGARDING DENSE AQUEOUS PHASE LIQUID
(DAPL) VOLUME AND NDMA MASS CALCULATIONS
(01/15/2020 TRANSMITTAL LETTERATTACHED)
1/3/2020
68
R01: Davis, Andy (GEOMEGA INC), R01:
Humphrey, S (GEOMEGA INC)
R01: Cashwell, James (OLIN CORP), R01:
Esakkiperumal, Chinny (OLIN CORPORATION)
MEMO/Memorandum
053-REMEDIAL/0531-Remedy
Characterization/04.06-FEASIBILITY
STUDY REPORTS
UCTL( Uncontrolled)
httDs://semspub.epa.gov/src/document/Ql/S44Q83
650490
SEMI-ANNUAL STATUS REPORT NO. 25
12/18/2019
262
R01: (WOOD)
R01: (OLIN CORPORATION)
RPT/ Report
053-REMEDIAL/0531-Remedy
Characterizat ion/03.07-WORK
PLANS & PROGRESS REPORTS (Rl)
UCTL( Uncontrolled)
httDs://semspub.epa.gov/src/document/Ql/S5Q49Q
646123
MEMO RESPONDING TO PLANT B / EAST DITCH RISK
EVALUATION V2 (TRANSMITTAL LETTERATTACHED)
12/13/2019
12
R01: Murphy, Michael, J (WOOD)
R01: Esakkiperumal, Chinny (OLIN
CORPORATION)
MEMO/Memorandum
053-REMEDIAL/0531-Remedy
Characterization/03.10-
ENDANGERMENT/BASELINE RISK
ASSESSMENTS
UCTL( Uncontrolled)
httos://semspub.epa,gov/src/document/0i/S4S123
642199
MEMO REGARDING SITE-SPECIFIC AMBIENT WATER
QUALITY CRITERION (AWQC) FOR AMMONIA
(11/26/2019 TRANSMITTAL LETTERATTACHED)
11/25/2019
14
R01: Murphy, Michael, J (WOOD)
R01: Esakkiperumal, Chinny (OLIN
CORPORATION)
MEMO/Memorandum
053-REMEDIAL/0531-Remedy
Characterization/03.02-SAMPLING &
ANALYSIS DATA (Rl)
UCTL( Uncontrolled)
httos://semspub.epa,gov/src/document/0i/S42199
641674
MEMO REGARDING RECOMMENDATION OF
LOCATIONS FOR MULTI-PORT WELL INSTALLATIONS,
CONTAINMENT AREA
11/5/2019
3
R01: Brandon, William C (US EPA REGION 1)
R01: Morash, Melanie (US EPA REGION 1)
MEMO/Memorandum
053-REMEDIAL/0531-Remedy
Characterizat ion/03.01-
CORRESPONDENCE (Rl)
UCTL( Uncontrolled)
httos://semspub.epa,gov/src/document/0i/S41S?4
646113
MEMO REGARDING OPERABLE UNIT(OU) 1/OU2
REMEDIAL INVESTIGATION (Rl) APPENDIX J REVIEW
11/5/2019
5
R01: Brunelle, Jeffrey (NOBIS ENGINEERING
INC), R01: Lambert, J (NOBISGROUP)
R01: (US EPA REGION 1)
MEMO/Memorandum
053-REMEDIAL/0531-Remedy
Characterization/03.06-REMEDIAL
INVESTIGATION REPORTS
UCTL( Uncontrolled)
htt Ds://semspu b.epa.gov/src/docu ment/Ql/646113
652662
REGIONAL SCREENING LEVELS (RSL) FOR CHEMICAL
CONTAMINANTSAT SUPERFUND SITES, THQ 0.1
11/1/2019
1
R01: (US EPA REGION 1)
CHT / Chart/Table
056-SITE SUPPORT/0561-
Administrative Support/17.07-
REFERENCE DOCUMENTS
UCTL( Uncontrolled)
httDs://semspub.epa.gov/src/document/Ql/S52SS2
652663
REGIONAL SCREENING LEVELS (RSL) FOR CHEMICAL
CONTAMINANTS AT SUPERFUND SITES, THQ 1.0
11/1/2019
1
R01: (US EPA REGION 1)
CHT / Chart/Table
056-SITE SUPPORT/0561-
Administrative Support/17.07-
REFERENCE DOCUMENTS
UCTL( Uncontrolled)
htt Ds://semsoub.epa.gov/src/document/Ql/S52SS3
-------
643135
LETTER REGARDING PROPOSALTO APPENDTHE
ONGOING QUARTERLY MONrTORING PROGRAM
10/23/2019
4
R01: Cashwell, James M (OLIN CORP)
R01: Morash, Melanie (US EPA REGION 1)
LTR/Letter
053-REMEDIAL/0534-Post
Construction/0801-
CORRESPONDENCE (POST REMEDIAL
ACTION)
UCTL( Uncontrolled)
1
httDs://semspub.epa,gov/srt/document/01/643135
643155
MEMO REGARDING EVALUATION OF POTENTIAL
CONTAMINANTS OF CONCERN: EAST DITCH SURFACE
WATER, SOUTH DITCH SURFACE WATER, AND
GROUNDWATER
10/23/2019
561
R01: Brunelle, Jeffrey (NOBIS ENGINEERING
INC), R01: Lambert, J (NOBISGROUP)
R01: (US EPA)
MEMO/Memorandum
053-REMEDIAL/0531-Remedy
Characterization/04.02-SAMPLING &
ANALYSIS DATA (FS)
UCTL( Uncontrolled)
1
httDs://semspub.epa,gov/srt/document/01/643155
641683
PRESENTATION: COMMUNITY MEETING
10/22/2019
49
R01: (US EPA REGION 1)
MTG / Meeting Document
051-COMMUNITY
INVOLVEMENT/0511-Community
Involvement Activities/13.04-PUBLIC
MEETINGS/HEARINGS
UCTL( Uncontrolled)
1
httDs://semspub.epa,gov/srt/document/01/641683
642182
SAVETHE DATE POSTCARD ANNOUNCING OPEN HOUSE
/PUBLIC MEETING
10/22/2019
2
R01: (US EPA REGION 1)
MTG / Meeting Document
051-COMMUNITY
INVOLVEMENT/0511-Community
Involvement Activities/13.04-PUBLIC
MEETINGS/HEARINGS
UCTL( Uncontrolled)
1
httos://semspub.epa,gov/srt/document/01/S42182
199603
Overview ofthe Olin Chemical Superfund Site Fact
Sheet
10/21/2019
7
PUB/Publication
051-COMMUNITY
INVOLVEMENT/0511-Community
Involvement Activities/A4.6-
Community Involvement Plan
UCTL( Uncontrolled)
11
htt Ds://semspub.epa.gov/srt/document/ll/199603
641673
MEDIA ADVISORY: INFORMATIONAL MEETING TO BE
HELD ON THE OLIN CHEMICAL SUPERFUND SITE IN
WILMINGTON, MA
10/16/2019
2
R01: (US EPA REGION 1)
PUB/Publication
051-COMMUNITY
INVOLVEMENT/0511-Community
Involvement Activities/13.03-NEWS
CUPPINGS/PRESS RELEASES
UCTL( Uncontrolled)
1
httDs://semspub.epa,gov/srt/document/01/641673
643156
MEMO REGARDING GROUNDWATER TREND
EVALUATION FOR WELLS ASSOCIATED WITH EAST
DITCH AND SOUTH DITCH
10/1/2019
70
R01: Brunelle, Jeffrey (NOBIS ENGINEERING
INC), R01: Lambert, J (NOBISGROUP)
R01: (US EPA)
MEMO/Memorandum
053-REMEDIAL/0531-Remedy
Characterization/04.02-SAMPLING &
ANALYSIS DATA (FS)
UCTL( Uncontrolled)
1
httDs://semspub.epa,gov/srt/document/01/643156
100012999
FACT SHEET-TECHNICAL ASSISTANCE SERVICES FOR
COMMUNITIES (TASC) - 2019
10/1/2019
7
R01: (US EPA REGION 1)
PUB/Publication
051-COMMUNITY
INVOLVEMENT/0511-Community
Involvement Activities/13.05-FACT
SHEETS/INFORMATION UPDATES
UCTL( Uncontrolled)
1
httDs://semspub.epa,gov/srt/document/01/10QQ12999
643158
LETTER REGARDING PER- AND POLYFLUOROALKYL
SUBSTANCES (PFAS) SAMPLING RESULTS
9/27/2019
93
R01: Bowen, Elizabeth T (WOOD
ENVIRONMENT & INFRASTRUCTURE
SOLUTIONS INC), R01: Andolsek, Hank (WOOD
ENVIRONMENT & INFRASTRUCTURE
SOLUTIONS INC)
R01: Esakkiperumal, Chinny (OLIN
CORPORATION)
LTR/Letter
053-REMEDIAL/0531-Remedy
Characterization/04.02-SAMPLING &
ANALYSIS DATA (FS)
UCTL( Uncontrolled)
1
httDs://semspub.epa,gov/srt/document/01/643158
100002231
Superfund Task Force Final Report
9/9/2019
80
Rll: (SUPERFUNDTASK FORCE), Rll: (Office Of
Land & Emergency Management (OLEM))
RPT/ Report
058-PROGRAM SUPPORT/0587-
Public Affairs/B7.2-Public
Information & Outreach
UCTL( Uncontrolled)
11
httos://semspub.epa,gov/srt/document/ll/100002231
640101
MEMO REGARDING PLANT B / EAST DITCH RISK
EVALUATION V2
8/27/2019
51
R01: Brunelle, Jeffrey (NOBIS ENGINEERING
INC), R01: Lambert, J (NOBISGROUP), R01:
Woods, C (NOBIS GROUP), R01: Delong,T
(NOBIS GROUP)
R01: (US EPA REGION 1)
MEMO/Memorandum
053-REMEDIAL/0531-Remedy
Characterization/03.10-
ENDANGERMENT/BASELINE RISK
ASSESSMENTS
UCTL( Uncontrolled)
1
httos://semspub. 8pa.gov/sir/document/01/640101
640109
EMAIL TRANSMITTING MEMOS REGARDING DENSE
AQUEOUS PHASE LIQUID (DAPL) TREATMENT OPTIONS
AND REVIEW FAILURE OF DAPL EXTRACTION PILOT
TEST AND ALTERNATIVE WELL DESIGN FOR DAPL
E>CTRACTION (EMAIL HISTORY ATTACHED)
8/15/2019
2
R01: Morash, Melanie (US EPA REGION 1)
R01: Jennings, Lynne (US EPA REGION 1), R01:
Cashwell, James M (OLIN CORP)
EML/Email
053-REMEDIAL/0531-Remedy
Characterizat ion/04.01-
CORRESPONDENCE (FS)
UCTL( Uncontrolled)
1
httos://semspub.epa,gov/srt/document/01/S40109
640104
MEMO REGARDING DENSE AQUEOUS PHASE LIQUID
(DAPL) TREATMENT OPTIONS
8/12/2019
7
R01: Huling, Scott G (US EPA)
R01: Dilorenzo, James M (US EPA REGION 1),
R01: Morash, Melanie (US EPA REGION 1), R01:
Smith, Christopher (US EPA REGION 1)
MEMO/Memorandum
053-REMEDIAL/0531-Remedy
Characterizat ion/04.01-
CORRESPONDENCE (FS)
UCTL( Uncontrolled)
1
httos://semspub.epa,gov/srt/document/01/640104
640111
EMAIL REGARDING EPA COMMENTS ON 07/25/2019
PROPOSED STREAM GAUGE LOCATIONS (08/06/2019
REVIEW MEMO AND EMAIL HISTORY ATTACHED)
8/12/2019
7
R01: Morash, Melanie (US EPA REGION 1)
R01: Cashwell, James M (OLIN CORP)
EML/Email
053-REMEDIAL/0531-Remedy
Characterizat ion/04.01-
CORRESPONDENCE (FS)
UCTL( Uncontrolled)
1
httBs://semspub.epa.gov/sir/document/01/640111
640113
EMAIL REGARDING EPA / NOBIS REVIEW OF
CONTAINMENT AREA SOIL PROPOSAL (08/06/2019
REVIEW MEMO ATTACHED)
8/8/2019
5
R01: Dilorenzo, James (US EPA REGION 1)
R01: Esakkiperumal, Chinny (OLIN
CORPORATION)
EML/Email
053-REMEDIAL/0531-Remedy
Characterizat ion/04.01-
CORRESPONDENCE (FS)
UCTL( Uncontrolled)
1
htt Ds://semspu b.epa.gov/srt/docu ment/01/640113
640137
MEMO REVIEWING SUPPLEMENTAL
CHARACTERIZATION OF SOIL WITHIN THE
CONTAINMENT AREA V3
8/6/2019
4
R01: Brunelle, Jeffrey (NOBIS ENGINEERING
INC), R01: Lambert, J (NOBISGROUP)
R01: (US EPA REGION 1)
MEMO/Memorandum
053-REMEDIAL/0531-Remedy
Characterizat ion/04.04-INTERIM
DELIVERABLES(FS)
UCTL( Uncontrolled)
1
httDs://semspub.epa,gov/src/document/01/S40137
643129
DATA GAPS WORK PLAN (TRANSMITTAL LETTER
ATTACHED)
8/2/2019
74
R01: (GEOMEGA INC)
R01: (OLIN CORPORATION)
WP/Work Plan
053-REMEDIAL/0531-Remedy
Characterizat ion/04.07-WORK
PLANS & PROGRESS REPORTS (FS)
UCTL( Uncontrolled)
1
httDs://semspub.epa,gov/src/document/Ql/643129
640115
EMAIL TRANSMITTING MEMOS REGARDING
COMMENTS ON SEISMIC REFRACTION INFORMATION
AND SURFACE WATER STREAM GAUGES (07/29/2019
STREAM GAUGE LOCATION COMMENT MEMO,
07/30/2019 GEOPHYSICAL ALIGNMENTS MEMO, AND
EMAIL HISTORY ATTACHED)
7/31/2019
5
R01: Jennings, Lynne (US EPA REGION 1)
R01: Cashwell, James M (OLIN CORP)
EML/Email
053-REMEDIAL/0531-Remedy
Characterizat ion/04.01-
CORRESPONDENCE (FS)
UCTL( Uncontrolled)
1
htt Ds://semspu b.epa.gov/srt/docu ment/01/640115
640117
EMAIL REGARDING ADDITIONAL FEEDBACK ON SEISMIC
LINES (FIGURE OF PROPOSED LINES EAST OF OLIN AND
EMAIL HISTORY ATTACHED)
7/31/2019
3
R01: Jennings, Lynne (US EPA REGION 1)
R01: Cashwell, James M (OLIN CORP)
EML/Email
053-REMEDIAL/0531-Remedy
Characterizat ion/04.01-
CORRESPONDENCE (FS)
UCTL( Uncontrolled)
1
htt Ds://semspu b.epa.gov/srt/docu ment/01/640117
-------
647039
MEMO REGARDING REVISED REMEDIAL
INVESTIGATION (Rl) REPORT REVIEW COMMENTS
7/31/2019
12
R01: Brunelle, Jeffrey (NOBIS ENGINEERING
INC), R01: Lambert, J (NOBISGROUP)
MEMO/Memorandum
053-REMEDIAL/0531-Remedy
Characterization/03.06-REMEDIAL
INVESTIGATION REPORTS
UCTL( Uncontrolled)
1
httDs://semspub.epa.gov/src/document/Gl/647Q39
640136
MEMO REGARDING PROPOSED STREAM GAUGE
LOCATION REVIEW COMMENTS
7/29/2019
2
R01: Brunelle, Jeffrey (NOBIS ENGINEERING
INC), R01: Lambert, J (NOBISGROUP)
R01: (US EPA REGION 1)
MEMO/Memorandum
053-REMEDIAL/0531-Remedy
Characterization/04.04-INTERIM
DELIVERABLES(FS)
UCTL( Uncontrolled)
1
httDs://semspub.epa,gov/src/document/Ql/64Q136
647040
MEMO REGARDING SUPPLEMENTAL
CHARACTERIZATION OF SOIL WITHIN THE
CONTAINMENT AREA (07/26/2019 TRANSMITTAL
LETTER ATTACH ED)
7/25/2019
7
R01: Bowen, Libby (WOOD), R01: Andolsek,
Hank(WOOD ENVIRONMENT &
INFRASTRUCTURE SOLUTIONS INC), R01:
Thompson, Peter (WOOD ENVIRONMENT &
INFRASTRUCTURE SOLUTIONS INC)
R01: Cashwell, James M (OLIN CORP), R01:
Esakkiperumal, Chinny (OLIN CORPORATION)
MEMO/Memorandum
053-REMEDIAL/0531-Remedy
Characterizat ion/03.03-SCOPES OF
WORK(RI)
UCTL( Uncontrolled)
1
httDs://semspub.epa.gov/src/document/Gl/647G4Q
640135
MEMO REVIEW COMMENTS REGARDING REVISED
DRAFTOPERABLE UNIT(OU) 1ANDOU2 FEASIBILITY
STUDY (FS)
7/24/2019
9
R01: Brunelle, Jeffrey (NOBIS ENGINEERING
INC), R01: Lambert, J (NOBISGROUP)
R01: (US EPA REGION 1)
MEMO/Memorandum
053-REMEDIAL/0531-Remedy
Characterization/04.06-FEASIBILITY
STUDY REPORTS
UCTL( Uncontrolled)
1
httos://semspub.epa,gov/src/document/01/64G135
647014
MEMO REGARDING CONTAINMENT AREA SOIL
EVALUATION
7/22/2019
128
R01: Brunelle, Jeffrey (NOBIS ENGINEERING
INC), R01: Lambert, J (NOBISGROUP)
MEMO/Memorandum
053-REMEDIAL/0531-Remedy
Characterization/04.02-SAMPLING &
ANALYSIS DATA (FS)
UCTL( Uncontrolled)
1
httos://semspub.epa,gov/src/document/01/64?014
640102
MEMO REGARDING REVISED EVALUATION OF DENSE
AQUEOUS PHASE LIQUID (DAPL) AND NDMA TO
SUPPORT FEASIBILITY STUDY (FS) REVIEW AND
DEVELOPMENT OF DAPLAND GROUNDWATER
ALTERNATIVES V5
7/19/2019
60
R01: Brunelle, Jeffrey (NOBIS ENGINEERING
INC), R01: Lambert, J (NOBISGROUP)
R01: (US EPA REGION 1)
MEMO/Memorandum
053-REMEDIAL/0531-Remedy
Characterizat ion/04.04-INTERIM
DELIVERABLES(FS)
UCTL( Uncontrolled)
1
httos://semspub.epa,gov/src/document/01/S40102
640103
MEMO REGARDING DENSE AQUEOUS PHASE LIQUID
(DAPL) EXTRACTION ALTERNATIVES V2.2
7/19/2019
29
R01: Brunelle, Jeffrey (NOBIS ENGINEERING
INC), R01: Lambert, J (NOBISGROUP)
R01: (US EPA REGION 1)
MEMO/Memorandum
053-REMEDIAL/0531-Remedy
Characterizat ion/04.04-INTERIM
DELIVERABLES(FS)
UCTL( Uncontrolled)
1
httos://semspub.epa,gov/src/document/Gl/64G103
640134
MEMO REGARDING GROUNDWATER HOTSPOT/
DOWNGRADIENT CONTROL CONCEPTUAL MODEL
MEMORANDUM
7/19/2019
7
R01: Brunelle, Jeffrey (NOBIS ENGINEERING
INC), R01: Lambert, J (NOBISGROUP)
R01: (US EPA REGION 1)
MEMO/Memorandum
053-REMEDIAL/0531-Remedy
Characterizat ion/04.04-INTERIM
DELIVERABLES(FS)
UCTL( Uncontrolled)
1
httos://semspub.epa,gov/src/document/01/S40134
100012144
PRESENTATION: OLIN'S RECOMMENDED
MODIFICATIONS TO PROPOSED OCSS SEISMIC LINES
FOLLOWING 07/12/2019 CONFERENCE CALL
7/19/2019
18
R01: (OLIN CORP)
R01: (US EPA REGION 1)
MTG / Meeting Document
053-REMEDIAL/0531-Remedy
Characterizat ion/04.01-
CORRESPONDENCE (FS)
UCTL( Uncontrolled)
1
htt Ds://semspu b.epa.gov/src/docu ment/01/100012144
100012145
MEMO REGARDING MODIFICATION TO SEISMIC LINES
TO ACCOMMODATE USEPA'S PROPOSALAND THE
EXISTING DATA IN THE EAST-OF-OLIN AREA
7/18/2019
4
R01: Davis, Andy (GEOMEGA INC)
R01: Cashwell, James M (OLIN CORP), R01:
Esakkiperumal, Chinny (OLIN CORPORATION)
MEMO/Memorandum
053-REMEDIAL/0531-Remedy
Characterizat ion/03.01-
CORRESPONDENCE (Rl)
UCTL( Uncontrolled)
1
htt Ds://semspu b.epa.gov/src/docu ment/01/100012145
647205
SEMI-ANNUAL STATUS REPORT NO. 24 (TRANSMITTAL
LETTER ATTACH ED)
7/3/2019
2005
R01: (WOOD ENVIRONMENT &
INFRASTRUCTURE SOLUTIONS INC)
R01: (OLIN CORPORATION)
RPT/ Report
053-REMEDIAL/0531-Remedy
Characterizat ion/03.07-WORK
PLANS & PROGRESS REPORTS (Rl)
UCTL( Uncontrolled)
1
httDs://semspub.epa.gov/src/document/Gl/6472Q5
640133
DRAFT MEMO REGARDING GROUNDWATER
EXTRACTION ALTERNATIVES - FEASIBILITY, EXTRACTION
OF NDMA-CONTAINING GROUNDWATER WITHIN
MAPLE MEADOW BROOKWETLANDS USING SWAMP
MAT APPROACH
6/27/2019
25
R01: Brunelle, Jeffrey (NOBIS ENGINEERING
INC), R01: Lambert, J (NOBISGROUP)
R01: (US EPA REGION 1)
MEMO/Memorandum
053-REMEDIAL/0531-Remedy
Characterizat ion/04.04-INTERIM
DELIVERABLES(FS)
UCTL( Uncontrolled)
1
httos://semspub.epa,gov/src/document/01/S40133
642184
LETTER REGARDING NOTICE OF DISAPPROVAL, FINAL
INTERIM RESPONSE STEPS WORK PLAN (IRSWP)
ADDENDUM - PLANT B CONTINUED OPERATIONS
MAINTENANCE AND MONITORING (OM&M) PLAN
6/12/2019
2
R01: Dilorenzo, James M (US EPA REGION 1)
R01: Esakkiperumal, Chinny (OLIN
CORPORATION)
LTR/Letter
053-REMEDIAL/0531-Remedy
Characterizat ion/04.01-
CORRESPONDENCE (FS)
UCTL( Uncontrolled)
1
httos://semspub.epa,gov/src/document/01/S42184
647016
REVISED REMEDIAL INVESTIGATION (Rl) REPORT
6/1/2019
6056
R01: (WOOD ENVIRONMENT &
INFRASTRUCTURE SOLUTIONS INC)
R01: (OLIN CORPORATION)
RPT/ Report
053-REMEDIAL/0531-Remedy
Characterization/03.06-REMEDIAL
INVESTIGATION REPORTS
UCTL( Uncontrolled)
1
httos://semspub.epa,gov/src/document/01/64?01S
640854
FEASIBILITY STUDY (FS) REPORT, OPERABLE UNIT(OU) 1
AND OU2, REVISED DRAFT
5/1/2019
276
R01: (WOOD ENVIRONMENT &
INFRASTRUCTURE SOLUTIONS INC)
R01: (OLIN CORPORATION)
RPT/ Report
053-REMEDIAL/0531-Remedy
Characterization/04.06-FEASIBILITY
STUDY REPORTS
UCTL( Uncontrolled)
1
httBs://semspub.epa.gov/src/document/01/64Q854
640853
FEASIBILITY STUDY (FS) REPORT, INTERIM ACTION,
DRAFT
4/1/2019
138
R01: (WOOD ENVIRONMENT &
INFRASTRUCTURE SOLUTIONS INC)
R01: (OLIN CORPORATION)
RPT/ Report
053-REMEDIAL/0531-Remedy
Characterization/04.06-FEASIBILITY
STUDY REPORTS
UCTL( Uncontrolled)
1
httDs://semspub.epa.gov/src/document/Ql/S4Q853
652637
NEWS RELEASE: ADMINISTRATOR WHEELER
RECOGNIZES ACCOMPLISHMENTS ATTWO SUPERFUND
SITES MOVING OFF THE ADMINISTRATOR'S EMPHASIS
LIST
4/1/2019
3
R01: (US EPA REGION 10
PUB/Publication
051-COMMUNITY
INVOLVEMENT/0511-Community
Involvement Activities/13.03-NEWS
CUPPINGS/PRESS RELEASES
UCTL( Uncontrolled)
1
httDs://semspub.epa.gov/src/document/Ql/S52637
647258
PRESENTATION: WILMINGTON MEETING
3/26/2019
24
R01: (OLIN CORPORATION)
MTG / Meeting Document
051-COMMUNITY
INVOLVEMENT/0511-Community
Involvement Activities/13.04-PUBLIC
MEETINGS/HEARINGS
UCTL( Uncontrolled)
1
httDs://semspub.epa.gov/src/document/Ql/S47258
642120
LETTER REGARDING EPA RESPONSES TO 01/02/2019
RESPONSE TO EPA'S COMMENTS ON DRAFT REMEDIAL
INVESTIGATION (Rl) AND FEASIBILITY STUDY (FS)
REPORTS
3/8/2019
172
R01: Dilorenzo, James M (US EPA REGION 1)
R01: Esakkiperumal, Chinny (OLIN
CORPORATION)
LTR/Letter
053-REMEDIAL/0531-Remedy
Characterization/03.06-REMEDIAL
INVESTIGATION REPORTS
UCTL( Uncontrolled)
1
httos://semspub.epa,gov/src/document/01/S4212Q
653915
CALCIUM SULFATE LANDFILL BIENNIAL REPORT (2017-
2018)
2/22/2019
193
R01: (WOOD ENVIRONMENT &
INFRASTRUCTURE SOLUTIONS INC)
R01: (OLIN CORPORATION)
RPT/ Report
056-SITE SUPPORT/0563-
State/Tribal Involvement/09.10-
STATE TECHNICAL AND HISTORICAL
RECORDS
UCTL( Uncontrolled)
1
httos://semspub.epa,gov/src/document/01/S53915
650489
SEMI-ANNUAL STATUS REPORT NO. 23
1/3/2019
241
R01: (WOOD)
R01: (OLIN CORPORATION)
RPT/ Report
053-REMEDIAL/0531-Remedy
Characterizat ion/03.07-WORK
PLANS & PROGRESS REPORTS (Rl)
UCTL( Uncontrolled)
1
httDs://semspub.epa.gov/src/document/Ql/S5Q489
-------
647262
MEMO RESPONDINGTO 11/29/2019 MEMO -
RESOLUTION OF CONCEPTUALSITE MODEL(CSM)
12/21/2018
36
R01: (US EPA REGION 1)
R01: (OLIN CORPORATION)
MEMO/Memorandum
053-REMEDIAL/0531-Remedy
Characterizat ion/04.01-
CORRESPONDENCE (FS)
UCTL( Uncontrolled)
1
httDs://semspub.epa.gov/src/document/Ql/647262
647842
MEMO REGARDING IMPROVING RESOLUTION AND
TECHNICAL BASIS FOR CONCEPTUALSITE MODEL(CSM)
RELATIVE TO MAIN STREET AND JEWEL DRIVE DENSE
AQUEOUS PHASE LIQUID (DAPL) POOLS
11/29/2018
21
R01: Brandon, Bill (US EPA REGION 1)
R01: Dilorenzo, James M (US EPA REGION 1),
R01: Jennings, Lynne (US EPA REGION 1), R01:
Lambert, Jennifer (NOBIS GROUP), R01: Smith,
Christopher(US EPA REGION 1)
MEMO/Memorandum
053-REMEDIAL/0531-Remedy
Characterizat ion/03.01-
CORRESPONDENCE (Rl)
UCTL( Uncontrolled)
1
httDs://semspub.epa.gov/src/document/Ql/647842
640105
MEMO REGARDING REVIEW FAILURE OF DENSE
AQUEOUS PHASE LIQUID (DAPL) EXTRACTION PILOT
TEST AND ALTERNATIVE WELL DESIGN FOR DAPL
EXTRACTION
11/16/2018
4
R01: Huling, Scott G (US EPA)
R01: Dilorenzo, James M (US EPA REGION 1),
R01: Smith, Christopher (US EPA REGION 1)
MEMO/Memorandum
053-REMEDIAL/0531-Remedy
Characterizat ion/04.01-
CORRESPONDENCE (FS)
UCTL( Uncontrolled)
1
httos://semspub.epa,gov/src/document/01/S40105
641688
LETTER RESPONDINGTO NOTIFICATIONS REGARDING
PLANT B
11/15/2018
3
R01: Dilorenzo, James (US EPA REGION 1)
R01: Esakkiperumal, Chinny (OLIN
CORPORATION)
LTR/Letter
053-REMEDIAL/0531-Remedy
Characterizat ion/03.01-
CORRESPONDENCE (Rl)
UCTL( Uncontrolled)
1
httos://semspub.epa,gov/src/document/01/641688
643157
LETTER RESPONDINGTO 5 SUBMITTALS FROM OLIN: 2
IRSWP MONITORING PROGRAM OPTIMIZATION
PROPOSALS, GROUNDWATER OPTIMIZATION
PROPOSAL, REQUEST FOR APPROVALOF ADDITIONAL
INVESTIGATION TASK, AND VERIFICATION OF DNAPL AT
SELECT MONITORING LOCATIONS
11/15/2018
23
R01: Smith, Christopher (US EPA REGION 1)
R01: Esakkiperumal, Chinny (OLIN
CORPORATION)
LTR/Letter
053-REMEDIAL/0531-Remedy
Characterizat ion/04.01-
CORRESPONDENCE (FS)
UCTL( Uncontrolled)
1
httos://semspub.epa,gov/src/document/01/643157
647841
MEMO REGARDING FOLLOW-UPTO MEETING OF
10/25/2018: REEVALUATION OF TECHNICAL BASIS FOR
MAIN STREET SADDLE AND RELATED CONCEPTUAL SITE
MODEL (CSM) ELEMENTS, INITIAL RESPONSE
11/15/2018
3
R01: Brandon, Bill (US EPA REGION 1)
R01: Dilorenzo, James M (US EPA REGION 1),
R01: Jennings, Lynne (US EPA REGION 1), R01:
Lambert, Jennifer (NOBIS GROUP), R01: Smith,
Christopher(US EPA REGION 1)
MEMO/Memorandum
053-REMEDIAL/0531-Remedy
Characterizat ion/03.01-
CORRESPONDENCE (Rl)
UCTL( Uncontrolled)
1
httos://semspub.epa,gov/src/document/01/647841
100010328
LETTER REGARDING DISAPPROVAL OF MARCH 2018
REMEDIAL INVESTIGATION / FEASIBILITY STUDY (RI/FS)
DELIVERABLES
9/25/2018
275
R01: Dilorenzo, James M (US EPA REGION 1)
R01: Esakkiperumal, Chinny (OLIN
CORPORATION)
LTR/Letter
053-REMEDIAL/0531-Remedy
Characterization/03.06-REMEDIAL
INVESTIGATION REPORTS
UCTL( Uncontrolled)
1
httos://semspub.epa,gov/src/document/Gl/lGGG10328
647015
MEMO REGARDING REVIEW COMMENTS ON REVISED
ROCK MATRIX SAMPLING WORK PLAN
8/3/2018
3
R01: Lambert, J (NOBIS GROUP)
MEMO/Memorandum
053-REMEDIAL/0531-Remedy
Characterization/04.02-SAMPLING &
ANALYSIS DATA (FS)
UCTL( Uncontrolled)
1
httos://semspub.epa,gov/src/document/01/S4?015
650715
SEMI-ANNUAL STATUS REPORT NO. 22
7/26/2018
2069
R01: (WOOD)
R01: (OLIN CORPORATION)
RPT/ Report
053-REMEDIAL/0531-Remedy
Characterizat ion/03.07-WORK
PLANS & PROGRESS REPORTS (Rl)
UCTL( Uncontrolled)
1
httos://semspub.epa,gov/src/document/01/S50?15
647041
ROCK MATRIX SAMPLING WORK PLAN (TRANSMITTAL
LETTER ATTACH ED)
7/6/2018
82
R01: (WOOD ENVIRONMENT &
INFRASTRUCTURE SOLUTIONS INC)
R01: (OLIN CORPORATION)
WP/Work Plan
053-REMEDIAL/0531-Remedy
Characterizat ion/03.07-WORK
PLANS & PROGRESS REPORTS (Rl)
UCTL( Uncontrolled)
1
httos://semspub.epa,gov/src/document/01/64?041
647209
TECHNICAL REVIEW MEMO - DRAFT REMEDIAL
INVESTIGATION (Rl)
5/16/2018
27
R01: Brunelle, Jeffrey (NOBIS ENGINEERING
INC)
R01: Dilorenzo, James M (US EPA REGION 1)
MEMO/Memorandum
053-REMEDIAL/0531-Remedy
Characterization/03.06-REMEDIAL
INVESTIGATION REPORTS
UCTL( Uncontrolled)
1
httos://semspub.epa.gov/src/document/Gl/6472G9
647259
TECHNICAL MEMO - CONTAINMENT AREA BEDROCK
BORING RESULTS (TRANSMITTAL LETTER ATTACHED)
5/10/2018
44
R01: Murphy, Michael, J (WOOD), R01:
Thompson, Peter (WOOD ENVIRONMENT &
INFRASTRUCTURE SOLUTIONS INC)
R01: Cashwell, James M (OLIN CORP), R01:
Esakkiperumal, Chinny (OLIN CORPORATION)
MEMO/Memorandum
053-REMEDIAL/0531-Remedy
Characterization/03.02-SAMPLING &
ANALYSIS DATA (Rl)
UCTL( Uncontrolled)
1
httBs://semspub.epa.gov/src/document/01/647259
642599
LETTER REGARDING EPA REVIEW AND PARTIAL
CONDITIONAL APPROVAL OF GW-413 AREA
SUPPLEMENTAL INVESTIGATION
3/29/2018
4
R01: Dilorenzo, James M (US EPA REGION 1)
R01: Cashwell, James M (OLIN CORP)
LTR/Letter
053-REMEDIAL/0531-Remedy
Characterizat ion/04.04-INTERIM
DELIVERABLES(FS)
UCTL( Uncontrolled)
1
httDs://semspub.epa.gov/src/document/01/642599
650714
SEMI-ANNUAL STATUS REPORT NO. 21 (TRANSMITTAL
LETTER ATTACH ED)
1/11/2018
3025
R01: (AMEC FOSTER WHEELER ENVIRONMENT
AND INFRASTRUCTURE INC), R01: (OLIN CORP)
R01: (US EPA REGION 1)
RPT/ Report
053-REMEDIAL/0531-Remedy
Characterizat ion/03.07-WORK
PLANS & PROGRESS REPORTS (Rl)
UCTL( Uncontrolled)
1
httos://semspub.epa,gov/src/document/01/650714
647235
MEMO REGARDING COMMENTS ON DENSEAQUEOUS
PHASE LIQUID (DAPL) FOCUSED FEASIBILITY STUDY (FS)
11/27/2017
2
R01: (WILMINGTON ENVIRONMENTAL
RESTORATION COMMnTEE)
R01: Dilorenzo, James (US EPA REGION 1), R01:
Waldeck, Garry (MA DEPT OF ENVIRONMENTAL
PROTECTION)
MEMO/Memorandum
053-REMEDIAL/0531-Remedy
Characterization/04.06-FEASIBILITY
STUDY REPORTS
UCTL( Uncontrolled)
1
httDs://semspub.epa.gov/src/document/01/647235
647237
MEMO REGARDING COMMENTS ON FOCUSED
REMEDIAL INVESTIGATION (Rl) REPORT, DENSE
AQUEOUS PHASE LIQUID (DAPL)
11/27/2017
3
R01: (WILMINGTON ENVIRONMENTAL
RESTORATION COMMnTEE)
R01: Dilorenzo, James (US EPA REGION 1), R01:
Waldeck, Garry (MA DEPT OF ENVIRONMENTAL
PROTECTION)
MEMO/Memorandum
053-REMEDIAL/0531-Remedy
Characterization/03.06-REMEDIAL
INVESTIGATION REPORTS
UCTL( Uncontrolled)
1
httDs://semspub.epa.gov/src/document/Ql/647237
647236
DRAFT FOCUSED REMEDIAL INVESTIGATION (Rl)
REPORT, DENSEAQUEOUS PHASE LIQUID (DAPL)
(TRANSMITTAL LETTERATTACHED)
10/5/2017
235
R01: (AMEC FOSTER WHEELER ENVIRONMENT
& INFRASTRUCTURE, INC.)
R01: (OLIN CORPORATION)
RPT/ Report
053-REMEDIAL/0531-Remedy
Characterization/03.06-REMEDIAL
INVESTIGATION REPORTS
UCTL( Uncontrolled)
1
httDs://semspub.epa.gov/src/document/01/647236
650713
SEMI-ANNUAL STATUS REPORT NO. 20
7/13/2017
2723
R01: (AMEC FOSTER WHEELER ENVIRONMENT
AND INFRASTRUCTURE INC), R01: (OLIN CORP)
R01: (US EPA REGION 1)
RPT/ Report
053-REMEDIAL/0531-Remedy
Characterizat ion/03.07-WORK
PLANS & PROGRESS REPORTS (Rl)
UCTL( Uncontrolled)
1
httos://semspub.epa,gov/src/document/0i/650713
647255
LETTER REGARDING EVALUATION OF EARLY ACTION TO
ADDRESS PRINCIPAL THREATS IN GROUNDWATER
2/24/2017
24
R01: Dilorenzo, James M (US EPA REGION 1)
R01: Cashwell, James M (OLIN CORP)
LTR/Letter
053-REMEDIAL/0531-Remedy
Characterizat ion/03.01-
CORRESPONDENCE (Rl)
UCTL( Uncontrolled)
1
httDs://semspub.epa.gov/src/document/01/647255
650712
SEMI-ANNUALSTATUS REPORT NO. 19
1/3/2017
2477
R01: (AMEC FOSTER WHEELER ENVIRONMENT
AND INFRASTRUCTURE INC), R01: (OLIN CORP)
R01: (US EPA REGION 1)
RPT/ Report
053-REMEDIAL/0531-Remedy
Characterizat ion/03.07-WORK
PLANS & PROGRESS REPORTS (Rl)
UCTL( Uncontrolled)
1
httos://semspub.epa,gov/src/document/0i/650712
647830
LETTER REGARDING REVIEWAND CONDITIONAL
APPROVALOF GW-413 AREA SUPPLEMENTAL
INVESTIGATION PROPOSAL
8/4/2016
2
R01: Dilorenzo, James M (US EPA REGION 1)
R01: Cashwell, James M (OLIN CORP)
LTR/Letter
053-REMEDIAL/0531-Remedy
Characterizat ion/04.04-INTERIM
DELIVERABLES(FS)
UCTL( Uncontrolled)
1
httDs://semspub.epa.gov/src/document/Ql/64783Q
650711
SEMI-ANNUALSTATUS REPORT NO. 18(06/29/2016
TRANSMITTAL LETTERATTACHED)
7/1/2016
2498
R01: (AMEC FOSTER WHEELER ENVIRONMENT
AND INFRASTRUCTURE INC), R01: (OLIN CORP)
R01: (US EPA REGION 1)
RPT/ Report
053-REMEDIAL/0531-Remedy
Characterizat ion/03.07-WORK
PLANS & PROGRESS REPORTS (Rl)
UCTL( Uncontrolled)
1
httDs://semspub.epa.gov/src/document/Ql/65Q711
-------
642597
LETTER REGARDING GW-413 AREA SUPPLEMENTAL
INVESTIGATION PROPOSAL
6/14/2016
35
R01: Murphy, Michael (AMEC FOSTER
WHEELER), R01: Thompson, Peter (AMEC
ENVIRONMENT AND INFRASTRUCTURE INC)
R01: Dilorenzo, James M (US EPA REGION 1)
LTR/Letter
053-REMEDIAL/0531-Remedy
Characterization/04.04-INTERIM
DELIVERABLES(FS)
UCTL( Uncontrolled)
htt os://semspub.epa.gov/src/document/01/642597
650710
SEMI-ANNUALSTATUS REPORT NO. 17
1/7/2016
1947
R01: (AMEC FOSTER WHEELER ENVIRONMENT
AND INFRASTRUCTURE INC), R01: (OLIN CORP)
R01: (US EPA REGION 1)
RPT/ Report
053-REMEDIAL/0531-Remedy
Characterization/03.07-WORK
PLANS & PROGRESS REPORTS (Rl)
UCTL( Uncontrolled)
httDs://semspub.epa,gov/src/document/Ql/65Q710
627393
FINAL REMEDIAL INVESTIGATION (Rl) REPORT -
APPENDIXA - D
7/24/2015
1242
R01: (AMEC ENVIRONMENT AND
INFRASTRUCTURE INC)
R01: (OLIN CORPORATION)
RPT/ Report
053-REMEDIAL/0531-Remedy
Characterization/03.06-REMEDIAL
INVESTIGATION REPORTS
UCTL( Uncontrolled)
htt os://semspub. 8Da.gov/sir/document/01/627393
627394
FINAL REMEDIAL INVESTIGATION (Rl) REPORT -
APPENDIX E
7/24/2015
25503
R01: (AMEC ENVIRONMENT AND
INFRASTRUCTURE INC)
R01: (OLIN CORPORATION)
RPT/ Report
053-REMEDIAL/0531-Remedy
Characterization/03.06-REMEDIAL
INVESTIGATION REPORTS
UCTL( Uncontrolled)
htt Ds://semsoub.epa.gov/src/document/Gl/627394
627395
FINAL REMEDIAL INVESTIGATION (Rl) REPORT -
APPENDIX F-J
7/24/2015
978
R01: (AMEC ENVIRONMENT AND
INFRASTRUCTURE INC)
R01: (OLIN CORPORATION)
RPT/ Report
053-REMEDIAL/0531-Remedy
Characterization/03.06-REMEDIAL
INVESTIGATION REPORTS
UCTL( Uncontrolled)
htt Ds://semsDub.epa.gov/src/document/01/627395
627396
FINAL REMEDIAL INVESTIGATION (Rl) REPORT -
APPENDIX K- L
7/24/2015
682
R01: (AMEC ENVIRONMENT AND
INFRASTRUCTURE INC)
R01: (OLIN CORPORATION)
RPT/ Report
053-REMEDIAL/0531-Remedy
Characterization/03.06-REMEDIAL
INVESTIGATION REPORTS
UCTL( Uncontrolled)
htt Ds://semsoub.epa.gov/src/document/Ql/627396
627397
FINAL REMEDIAL INVESTIGATION (Rl) REPORT -
APPENDIX M
7/24/2015
11970
R01: (AMEC ENVIRONMENT AND
INFRASTRUCTURE INC)
R01: (OLIN CORPORATION)
RPT/ Report
053-REMEDIAL/0531-Remedy
Characterization/03.06-REMEDIAL
INVESTIGATION REPORTS
UCTL( Uncontrolled)
htt Ds://semsoub.epa.gov/src/document/Ql/627397
627398
FINAL REMEDIAL INVESTIGATION (Rl) REPORT -
APPENDIX N
7/24/2015
1640
R01: (AMEC ENVIRONMENT AND
INFRASTRUCTURE INC)
R01: (OLIN CORPORATION)
RPT/ Report
053-REMEDIAL/0531-Remedy
Characterization/03.06-REMEDIAL
INVESTIGATION REPORTS
UCTL( Uncontrolled)
htt Ds://semsoub.epa.gov/src/document/Ql/627398
627399
FINAL REMEDIAL INVESTIGATION (Rl) REPORT -
APPENDIX O
7/24/2015
11432
R01: (AMEC ENVIRONMENT AND
INFRASTRUCTURE INC)
R01: (OLIN CORPORATION)
RPT/ Report
053-REMEDIAL/0531-Remedy
Characterization/03.06-REMEDIAL
INVESTIGATION REPORTS
UCTL( Uncontrolled)
htt Ds://semsoub.epa.gov/src/document/Ql/627399
641414
FINAL REMEDIAL INVESTIGATION (Rl) REPORT
7/24/2015
517
R01: (AMEC ENVIRONMENT AND
INFRASTRUCTURE INC)
R01: (OLIN CORPORATION)
RPT/ Report
053-REMEDIAL/0531-Remedy
Characterization/03.06-REMEDIAL
INVESTIGATION REPORTS
UCTL( Uncontrolled)
htt Ds://semsoub.epa.gov/src/document/Ql/641414
642000
FINAL REMEDIAL INVESTIGATION (Rl) REPORT -
ATTACHMENTSA-E
7/24/2015
500
R01: (AMEC ENVIRONMENT AND
INFRASTRUCTURE INC)
R01: (OLIN CORPORATION)
RPT/ Report
053-REMEDIAL/0531-Remedy
Characterization/03.06-REMEDIAL
INVESTIGATION REPORTS
UCTL( Uncontrolled)
htt Ds://semsoub.epa.gov/src/document/Ql/642QQQ
650709
SEMI-ANNUALSTATUS REPORT NO. 16 (TRANSMITTAL
LETTER ATTACH ED)
7/7/2015
1703
R01: (AMEC FOSTER WHEELER ENVIRONMENT
AND INFRASTRUCTURE INC), R01: (OLIN CORP)
R01: (US EPA REGION 1)
RPT/ Report
053-REMEDIAL/0531-Remedy
Characterization/03.07-WORK
PLANS & PROGRESS REPORTS (Rl)
UCTL( Uncontrolled)
htt Ds://semsoub.epa.gov/src/document/Ql/65Q7Q9
647208
FINAL DATA GAP ANALYSIS AND ADDITIONAL FIELD
STUDIES WORK PLAN
7/3/2015
464
R01: (AMEC FOSTER WHEELER ENVIRONMENT
& INFRASTRUCTURE, INC.)
R01: (OLIN CORPORATION)
WP/Work Plan
053-REMEDIAL/0531-Remedy
Characterization/03.07-WORK
PLANS & PROGRESS REPORTS (Rl)
UCTL( Uncontrolled)
htt Ds://semsoub.epa.gov/src/document/Ql/6472Q8
640862
LETTER REGARDING REVIEWAND CONDITIONAL
APPROVAL, DRAFT FINAL REMEDIAL INVESTIGATION
(Rl) AND RISKASSESSMENT REPORT AND RELATED
DOCUMENTS
7/2/2015
2
R01: Dilorenzo, James M (US EPA REGION 1)
R01: Cashwell, James M (OLIN CORP)
LTR/Letter
053-REMEDIAL/0531-Remedy
Characterization/03.06-REMEDIAL
INVESTIGATION REPORTS
UCTL( Uncontrolled)
htt Ds://semsoub.epa.gov/src/document/Ql/64Q862
576599
COMFORT/STATUS LETTER - 51 EAMES STREET,
WILMINGTON, MA
5/13/2015
8
R01: Barmakian, Nancy(US EPA REGION 1)
R01: Jones, Robert (NEW ENGLAND TRANSRAIL
LLC)
LTR/Letter
052-ENFORCEMENT/0521-PRP
Search/11.09-PRP-SPECIFIC
DOCUMENTS
UCTL( Uncontrolled)
htt Ds://semsoub.epa.gov/src/document/Ql/576599
642595
LETTER REGARDING CONDITIONAL APPROVALOF
REVISED OPERABLE UNIT (OU) 3 DATA GAP ANALYSIS
AND ADDITIONAL FIELD STUDIES WORK PLAN
5/13/2015
7
R01: Dilorenzo, James M (US EPA REGION 1)
R01: Cashwell, James M (OLIN CORP)
LTR/Letter
053-REMEDIAL/0531-Remedy
Characterization/04.07-WORK
PLANS & PROGRESS REPORTS (FS)
UCTL( Uncontrolled)
htt Ds://semsoub.epa.gov/src/document/Ql/642595
644093
LETTER REGARDING COMMENTS ON DATA GAP
ANALYSIS AND ADDITIONAL FIELD STUDIES WORK PLAN
4/3/2015
4
R01: Trifilo, Joel J (GEOINSIGHT INC), R01:
Trainer, Kevin D (GEOINSIGHT INC), R01:
Webster, Michael J (GEOINSIGHT INC)
R01: Dilorenzo, James (US EPA REGION 1)
LTR/Letter
053-REMEDIAL/0531-Remedy
Characterization/03.07-WORK
PLANS & PROGRESS REPORTS (Rl)
UCTL( Uncontrolled)
htt Ds://semsoub.epa.gov/src/document/Ql/644Q93
644091
COMMENTSON DATA GAP ANALYSIS AND
SUPPLEMENTAL WORK PLAN REVISED (12/16/2014)
3/17/2015
5
R01: (WILMINGTON ENVIRONMENTAL
RESTORATION COMMITTEE)
R01: Dilorenzo, James (US EPA REGION 1)
MEMO/Memorandum
053-REMEDIAL/0531-Remedy
Characterization/03.07-WORK
PLANS & PROGRESS REPORTS (Rl)
UCTL( Uncontrolled)
httos://semspub.epa,gov/src/document/01/644G91
643159
MEMO REGARDING SUPPLEMENTAL WATER LEVEL AND
HYDRAULIC ANALYSIS, DENSE NON-AQUEOUS PHASE
LIQUID (DNAPL) EXTRACTION PILOT STUDY
PERFORMANCE EVALUATION REPORT
2/5/2015
19
R01: Rand, John B (AMEC ENVIRONMENT AND
INFRASTRUCTURE INC), R01: Thompson, Peter
(AMEC ENVIRONMENT AND INFRASTRUCTURE
INC)
R01: Cashwell, James M (OLIN CORP)
MEMO/Memorandum
053-REMEDIAL/0531-Remedy
Characterization/04.02-SAMPLING &
ANALYSIS DATA (FS)
UCTL( Uncontrolled)
httos://semspub.epa,gov/src/document/01/643159
644092
REVIEW OF DATA GAP ANALYSIS AND ADDITIONAL
FIELD STUDIES WORK PLAN (TRANSMITTAL LETTER
ATTACHED)
1/23/2015
6
R01: Ford, Heather M (NOBIS ENGINEERING
INC)
R01: Dilorenzo, James (US EPA REGION 1)
MEMO/Memorandum
053-REMEDIAL/0531-Remedy
Characterization/03.07-WORK
PLANS & PROGRESS REPORTS (Rl)
UCTL( Uncontrolled)
htt Ds://semsoub.epa.gov/src/document/Ql/644Q92
650708
SEMI-ANNUALSTATUS REPORT NO. 15 (TRANSMITTAL
LETTER ATTACH ED)
12/31/2014
1972
R01: (AMEC ENVIRONMENT AND
INFRASTRUCTURE INC), R01: (OLIN CORP)
R01: (US EPA REGION 1)
RPT/ Report
053-REMEDIAL/0531-Remedy
Characterization/03.07-WORK
PLANS & PROGRESS REPORTS (Rl)
UCTL( Uncontrolled)
htt Ds://semsoub.epa.gov/src/document/Ql/65Q7Q8
647263
DATA GAP ANALYSIS AND ADDITIONAL FIELD STUDIES
WORK PLAN
12/16/2014
429
R01: (AMEC ENVIRONMENT AND
INFRASTRUCTURE INC)
R01: (OLIN CORPORATION)
WP/Work Plan
053-REMEDIAL/0531-Remedy
Characterization/03.07-WORK
PLANS & PROGRESS REPORTS (Rl)
UCTL( Uncontrolled)
htt Ds://semsoub.epa.gov/src/document/Ql/647263
576492
DENSE AQUEOUS PHASE LIQUID (DAPL) EXTRACTION
PILOT STUDY PERFORMANCE EVALUATION REPORT
11/7/2014
101
R01: (AMEC ENVIRONMENT AND
INFRASTRUCTURE INC)
R01: (US EPA REGION 1)
RPT/ Report
053-REMEDIAL/0531-Remedy
Characterization/03.07-WORK
PLANS & PROGRESS REPORTS (Rl)
UCTL( Uncontrolled)
htt Ds://semsoub.epa.gov/src/document/Ql/576492
650707
SEMI-ANNUALSTATUS REPORT NO. 14 (TRANSMITTAL
LETTER ATTACH ED)
7/2/2014
2212
R01: (AMEC ENVIRONMENT AND
INFRASTRUCTURE INC), R01: (OLIN CORP)
R01: (US EPA REGION 1)
RPT/ Report
053-REMEDIAL/0531-Remedy
Characterization/03.07-WORK
PLANS & PROGRESS REPORTS (Rl)
UCTL( Uncontrolled)
htt Ds://semsoub.epa.gov/src/document/Ql/65Q7Q7
-------
644090
REVIEW OF DRAFT FINAL REMEDIAL INVESTIGATION
(Rl) REPORT (TRANSMITTAL LETTER ATTACHED)
5/19/2014
78
R01: Ford, Heather M (NOBIS ENGINEERING
INC)
R01: Dilorenzo, James (US EPA REGION 1)
MEMO/Memorandum
053-REMEDIAL/0531-Remedy
Characterization/03.06-REMEDIAL
INVESTIGATION REPORTS
UCTL( Uncontrolled)
htt os://semspu b.epa.gov/src/docu ment/Gl/S44G9G
640859
LETTER REGARDING RESPONSE TO COMMENTS
CONCERNING SECOND INTERIM DELIVERABLE -
BASELINE ECOLOGICAL RISK ASSESSMENT (ERA)
3/21/2014
27
R01: Murphy, Michael (AMEC ENVIRONMENT
AND INFRASTRUCTURE INC), R01: Thompson,
Peter (AMEC ENVIRONMENT AND
INFRASTRUCTURE INC)
R01: Dilorenzo, James M (US EPA REGION 1)
LTR/Letter
053-REMEDIAL/0531-Remedy
Characterization/03.10-
ENDANGERMENT/BASELINE RISK
ASSESSMENTS
UCTL( Uncontrolled)
htt Ds://semsoub.epa.gov/src/document/Gl/64Q859
640860
RESPONSE TO COMMENTS CONCERNING REMEDIAL
INVESTIGATION (Rl) SECTION 1-5 INCLUDING
STAKEHOLDER COMMENTS (TRANSMITTAL LETTER
ATTACHED)
3/21/2014
70
R01: Murphy, Michael (AMEC ENVIRONMENT
AND INFRASTRUCTURE INC), R01: Thompson,
Peter (AMEC ENVIRONMENT AND
INFRASTRUCTURE INC)
R01: Dilorenzo, James M (US EPA REGION 1)
RPT/ Report
053-REMEDIAL/0531-Remedy
Characterization/03.06-REMEDIAL
INVESTIGATION REPORTS
UCTL( Uncontrolled)
htt Ds://semsou b.epa.gov/src/docu ment/Gl/64G8SG
650499
SEMI-ANNUALSTATUS REPORT NO. 13
1/29/2014
7291
R01: (AMEC ENVIRONMENT AND
INFRASTRUCTURE INC), R01: (OLIN CORP)
R01: (US EPA REGION 1)
RPT/ Report
053-REMEDIAL/0531-Remedy
Characterization/03.07-WORK
PLANS & PROGRESS REPORTS (Rl)
UCTL( Uncontrolled)
htt Bs://semspub.epa.gov/src/document/Ql/65Q499
652661
REGIONAL SCREENING LEVELS (RSL) FOR CHEMICAL
CONTAMINANTS AT SUPERFUND SITES
11/1/2013
17
R01: (US EPA REGION 1)
CHT / Chart/Table
056-SITE SUPPORT/0561-
Administrative Support/17.07-
REFERENCE DOCUMENTS
UCTL( Uncontrolled)
httos://semspub.epa,gov/src/document/01/S52S61
650498
SEMI-ANNUALSTATUS REPORT NO. 12
7/1/2013
9598
R01: (AMEC ENVIRONMENT AND
INFRASTRUCTURE INC), R01: (OLIN CORP)
R01: (US EPA REGION 1)
RPT/ Report
053-REMEDIAL/0531-Remedy
Characterization/03.07-WORK
PLANS & PROGRESS REPORTS (Rl)
UCTL( Uncontrolled)
htt Ds://semsoub.epa.gov/src/document/01/S5Q498
100002732
Aquatic Life Ambient Water Quality Criteria for
Ammonia - Freshwater - 2013 - EPA 822-R-18-002
4/1/2013
255
Rll: (US ENVIRONMENTAL PROTECTION
AGENCY)
LAWS /
Laws/Regu lat ions/Gu ida nc
058-PROGRAM SUPPORT/0583-
Regulatory Development/B8.4-
Directives and Policy Guidance
Documents
UCTL( Uncontrolled)
httos://semspub.epa,gov/src/document/ll/100001?32
640861
REVIEW OF PRELIMINARY REMEDIAL INVESTIGATION
(Rl) REPORT, REMAINING ISSUES (TRANSMITTAL LETTER
ATTACHED)
1/31/2013
13
R01: Ford, Heather M (NOBIS ENGINEERING
INC)
R01: Dilorenzo, James M (US EPA REGION 1)
RPT/ Report
053-REMEDIAL/0531-Remedy
Characterization/03.06-REMEDIAL
INVESTIGATION REPORTS
UCTL( Uncontrolled)
httos://semspub.epa,gov/src/document/01/S4Q8Sl
650497
SEMI-ANNUALSTATUS REPORT NO. 11
1/2/2013
23905
R01: (AMEC ENVIRONMENT AND
INFRASTRUCTURE INC), R01: (OLIN CORP)
R01: (US EPA REGION 1)
RPT/ Report
053-REMEDIAL/0531-Remedy
Characterization/03.07-WORK
PLANS & PROGRESS REPORTS (Rl)
UCTL( Uncontrolled)
htt Ds://semsoub.epa.gov/src/document/01/S5Q497
647004
FINAL OPERATIONS, MAINTENANCE AND
PERFORMANCE MONITORING (O&M) PLAN, DENSE
NON-AQUEOUS PHASE LIQUID (DNAPL) EXTRACTION
PILOTTEST
10/1/2012
688
R01: (AMEC ENVIRONMENT AND
INFRASTRUCTURE INC), R01: (OLIN
CORPORATION)
R01: (US EPA REGION 1)
WP/Work Plan
053-REMEDIAL/0534-Post
Construction/0805-WORK PLANS &
PROGRESS REPORTS(POST
REMEDIAL)
UCTL( Uncontrolled)
htt Ds://semsoub.epa.gov/src/document/Ql/S47QQ4
643123
RESPONSE ALTERNATIVES EVALUATION REPORT
8/3/2012
104
R01: (AMEC ENVIRONMENT AND
INFRASTRUCTURE INC), R01: (OLIN
CORPORATION)
R01: (US EPA REGION 1)
RPT/ Report
053-REMEDIAL/0531-Remedy
Characterization/04.04-INTERIM
DELIVERABLES(FS)
UCTL( Uncontrolled)
httos://semspub.epa,gov/src/document/01/S43123
650496
SEMI-ANNUALSTATUS REPORT NO. 10
7/2/2012
1375
R01: (AMEC ENVIRONMENT AND
INFRASTRUCTURE INC), R01: (OLIN CORP)
R01: (US EPA REGION 1)
RPT/ Report
053-REMEDIAL/0531-Remedy
Characterization/03.07-WORK
PLANS & PROGRESS REPORTS (Rl)
UCTL( Uncontrolled)
htt Ds://semsoub.epa.gov/src/document/Ql/S5Q49S
650495
SEMI-ANNUALSTATUS REPORT NO. 9
12/30/2011
4822
R01:(MACTEC ENGINEERING AND
CONSULTING INC), R01: (OLIN CORP)
R01: (US EPA REGION 1)
RPT/ Report
053-REMEDIAL/0531-Remedy
Characterization/03.07-WORK
PLANS & PROGRESS REPORTS (Rl)
UCTL( Uncontrolled)
htt Ds://semsoub.epa.gov/src/document/Ql/S5Q495
647590
PRELIMINARY REMEDIAL INVESTIGATION (Rl) REPORT
8/22/2011
8527
R01: (MACTEC)
R01: (OLIN CORPORATION)
RPT/ Report
053-REMEDIAL/0531-Remedy
Characterization/03.06-REMEDIAL
INVESTIGATION REPORTS
UCTL( Uncontrolled)
htt Ds://semsoub.epa.gov/src/document/Ql/S4759Q
174480
FACT SHEET: GROUNDWATER ROAD MAP DETAILING
THE RECOMMENDED PROCESS FOR RESTORING
CONTAMINATED GROUNDWATER AT SUPERFUND SITES
OSWER 9283.1-34
7/1/2011
31
LAWS /
Laws/Regu lat ions/Gu ida nc
058-PROGRAM SUPPORT/0583-
Regulatory Development/B8.1-
Regulations, Standards & Guidelines
UCTL( Uncontrolled)
11
htt Ds://semsoub.epa.gov/src/document/ll/17448Q
650494
SEMI-ANNUALSTATUS REPORT NO. 8
7/1/2011
5037
R01:(MACTEC ENGINEERING AND
CONSULTING INC), R01: OLIN CORP)
R01: (US EPA REGION 1)
RPT/ Report
053-REMEDIAL/0531-Remedy
Characterization/03.07-WORK
PLANS & PROGRESS REPORTS (Rl)
UCTL( Uncontrolled)
htt Ds://semsoub.epa.gov/src/document/Ql/S5Q4 94
485654
[REDACTED] ENGINEERING EVALUATION / COST
ANALYSIS (EE/CA) APPROVAL MEMORANDUM FOR
NON-TIME CRITICAL REMOVAL ACTION (NTCRA),
OPERABLE UNIT3 (OU3)
5/26/2011
25
R01: Owens lii, James T (US EPA REGION 1)
MEMO/Memorandum
054-REMOVAL/0541-Removal
Responses/02.02-REMOVAL
RESPONSE REPORTS
UCTL( Uncontrolled)
htt Ds://semsoub.epa.gov/src/document/Ql/485S54
484768
REVIEW OF GROUNDWATER FROM WELL (MAP 24/LOT
54) REGARDING N-NITROSODIMETHYLAMINE (NDMA)
5/12/2011
2
R01: Dilorenzo, James (US EPA REGION 1)
R01: Stanley, Lisa (WILMINGTON (MA)
RESIDENT OF)
LTR/Letter
054-REMOVAL/0541-Removal
Responses/02.03-SAMPLING &
ANALYSIS DATA (REMOVAL
RESPONSE)
UCTL( Uncontrolled)
htt Ds://semsoub.epa.gov/src/document/Ql/4847S8
484771
[REDACTED] REVIEW OF GROUNDWATER FROM WELL
(MAP 27/LOT 14C) REGARDING N-
NITROSODIMETHYLAMINE(NDMA)
5/12/2011
2
R01: Dilorenzo, James (US EPA REGION 1)
R01: (WILMINGTON (MA) - RESIDENT OF)
LTR/Letter
054-REMOVAL/0541-Removal
Responses/02.03-SAMPLING &
ANALYSIS DATA (REMOVAL
RESPONSE)
UCTL( Uncontrolled)
httos://semspub.epa,gov/src/document/01/48477i
484772
[REDACTED] REVIEW OF GROUNDWATER FROM WELL
(MAP 24/LOT 63) REGARDING N-
NITROSODIMETHYLAMINE(NDMA)
5/12/2011
2
R01: Dilorenzo, James (US EPA REGION 1)
R01: (WILMINGTON (MA) - RESIDENT OF)
LTR/Letter
054-REMOVAL/0541-Removal
Responses/02.03-SAMPLING &
ANALYSIS DATA (REMOVAL
RESPONSE)
UCTL( Uncontrolled)
htt Ds://semsoub.epa.gov/src/document/Ql/484772
484773
[REDACTED] REVIEW OF GROUNDWATER FROM WELL
(MAP 24/LOT 94) REGARDING N-
NITROSODIMETHYLAMINE(NDMA)
5/12/2011
2
R01: Dilorenzo, James (US EPA REGION 1)
R01: (WILMINGTON (MA) - RESIDENT OF)
LTR/Letter
054-REMOVAL/0541-Removal
Responses/02.03-SAMPLING &
ANALYSIS DATA (REMOVAL
RESPONSE)
UCTL( Uncontrolled)
htt Ds://semsoub.epa.gov/src/document/Ql/484773
-------
484774
[REDACTED] REVIEW OF GROUNDWATER FROM WELL
(MAP 02/LOT07E) REGARDING N-
NITROSODIMETHYLAMINE(NDMA)
5/12/2011
2
R01: Dilorenzo, James (US EPA REGION 1)
R01: (WILMINGTON (MA) - RESIDENT OF)
LTR/Letter
054-REMOVAL/0541-Removal
Responses/02.03-SAMPLING &
ANALYSIS DATA (REMOVAL
RESPONSE)
UCTL( Uncontrolled)
1
httDs://semspub.epa.gov/src/document/Gl/484774
484775
[REDACTED] REVIEW OF GROUNDWATER FROM WELL
(MAP 15/LOT2C) REGARDING N-
NITROSODIMETHYLAMINE(NDMA)
5/12/2011
2
R01: Dilorenzo, James (US EPA REGION 1)
R01: (WILMINGTON (MA) - RESIDENT OF)
LTR/Letter
054-REMOVAL/0541-Removal
Responses/02.03-SAMPLING &
ANALYSIS DATA (REMOVAL
RESPONSE)
UCTL( Uncontrolled)
1
httDs://semspub.epa.gov/src/document/Gl/484775
484776
[REDACTED] REVIEW OF GROUNDWATER FROM WELL
(MAP 24/LOT 54) REGARDING N-
NITROSODIMETHYLAMINE(NDMA)
5/12/2011
2
R01: Dilorenzo, James (US EPA REGION 1)
R01: (WILMINGTON (MA) - RESIDENT OF)
LTR/Letter
054-REMOVAL/0541-Removal
Responses/02.03-SAMPLING &
ANALYSIS DATA (REMOVAL
RESPONSE)
UCTL( Uncontrolled)
1
httos://semspub. epa.gov/sir/document/01/484776
484777
[REDACTED] REVIEW OF GROUNDWATER FROM WELL
(MAP 24/LOT 64) REGARDING N-
NITROSODIMETHYLAMINE(NDMA)
5/12/2011
2
R01: Dilorenzo, James (US EPA REGION 1)
R01: (WILMINGTON (MA) - RESIDENT OF)
LTR/Letter
054-REMOVAL/0541-Removal
Responses/02.03-SAMPLING &
ANALYSIS DATA (REMOVAL
RESPONSE)
UCTL( Uncontrolled)
1
httDs://semspub.epa.gov/src/document/01/484777
485558
[REDACTED] LETTER REGARDING RESIDENCE WELL
SAMPLING
4/29/2011
2
R01: Murphy, Michael (MACTEC ENGINEERING
AND CONSULTING INC), R01: Thompson, Peter
H (MACTEC ENGINEERING AND CONSULTING
INC)
R01: Morrow, Steve (OLIN CORP)
LTR/Letter
054-REMOVAL/0541-Removal
Responses/02.01-
CORRESPONDENCE (REMOVAL
RESPONSE)
UCTL( Uncontrolled)
1
httDs://semspub.epa.gov/src/document/01/485558
485561
[REDACTED] LETTER REGARDING RESIDENCE WELL
SAMPLING
4/29/2011
2
R01: Murphy, Michael (MACTEC ENGINEERING
AND CONSULTING INC), R01: Thompson, Peter
(MACTEC ENGINEERING AND CONSULTING INC)
R01: Morrow, Steve (OLIN CORP)
LTR/Letter
054-REMOVAL/0541-Removal
Responses/02.01-
CORRESPONDENCE (REMOVAL
RESPONSE)
UCTL( Uncontrolled)
1
httos://semspub.epa,gov/src/document/01/4855Sl
483572
[REDACTED] EMAIL REGARDING UPDATE ON
POTENTIAL WATER SOLUTION OPTION (WITH EMAIL
HISTORY)
4/25/2011
2
R01: (WILMINGTON (MA) - RESIDENT OF)
R01: Dilorenzo, James (US EPA REGION 1)
EML/Email
054-REMOVAL/0541-Removal
Responses/02.01-
CORRESPONDENCE (REMOVAL
RESPONSE)
UCTL( Uncontrolled)
1
httDs://semspub.epa.gov/src/document/01/483572
70001450
EMAIL REGARDING SCHEDULING OF BRIEFING FOR
WILMINGTON TOWN OFFICIALS ON OLIN PRIVATE
WELL SAMPLING (EMAIL HISTORY ATTACHED)
4/25/2011
3
R01: (WILMINGTON (MA) TOWN OF)
R01: White, Sarah (US EPA REGION 1)
EML/Email
054-REMOVAL/0541-Removal
Responses/02.01-
CORRESPONDENCE (REMOVAL
RESPONSE)
UCTL( Uncontrolled)
1
httos://semspub.epa,gov/src/document/01/70001450
483571
[REDACTED] EMAIL REGARDING UPDATE OF WATER
SOLUTION
4/21/2011
1
R01: (WILMINGTON (MA) - RESIDENT OF)
R01: Dilorenzo, James (US EPA REGION 1)
EML/Email
054-REMOVAL/0541-Removal
Responses/02.01-
CORRESPONDENCE (REMOVAL
RESPONSE)
UCTL( Uncontrolled)
1
httos://semspub.epa,gov/src/document/01/483571
70001449
EMAIL REGARDING OLIN LETTER OF SUPPORT FOR NON
TIME CRITICAL REMOVAL ACTION (NTCRA)
4/21/2011
1
R01: Coyne, Joseph (MA DEP)
R01: Dilorenzo, James (US EPA REGION 1), R01:
Brill, Larry(US EPA REGION 1)
EML/Email
054-REMOVAL/0541-Removal
Responses/02.01-
CORRESPONDENCE (REMOVAL
RESPONSE)
UCTL( Uncontrolled)
1
httos://semspub.epa,gov/src/document/01/70001449
483576
[REDACTED] EMAIL REGARDING PRIVATE WELL UPDATE
4/20/2011
2
R01: Dilorenzo, James (US EPA REGION 1)
R01: (WILMINGTON (MA) - RESIDENT OF)
EML/Email
054-REMOVAL/0541-Removal
Responses/02.03-SAMPLING &
ANALYSIS DATA (REMOVAL
RESPONSE)
UCTL( Uncontrolled)
1
httDs://semspub.epa.gov/src/document/01/483576
485613
MADEP SUPPORT LETTER FOR NON-TIME CRITICAL
REMOVAL ACTION (NTCRA) ACTION MEMORANDUM
4/20/2011
2
R01: Naparstek, Jay (MA DEPTOF
ENVIRONMENTAL PROTECTION)
R01: Brill, Larry (US EPA REGION 1)
LTR/Letter
054-REMOVAL/0541-Removal
Responses/02.01-
CORRESPONDENCE (REMOVAL
RESPONSE)
UCTL( Uncontrolled)
1
httos://semspub.epa,gov/src/document/01/485S13
70001484
MA DEP SUPPORT LETTER FOR NON-TIME CRITICAL
REMOVAL ACTION (NTCRA)
4/20/2011
2
R01: Naparstek, Jay (MA DEPTOF
ENVIRONMENTAL PROTECTION)
R01: Brill, Larry (US EPA REGION 1)
LTR/Letter
054-REMOVAL/0541-Removal
Responses/02.01-
CORRESPONDENCE (REMOVAL
RESPONSE)
UCTL( Uncontrolled)
1
httos://semspub.epa,gov/src/document/01/70001484
70001447
EMAIL REGARDING RECENT PRIVATE WELL RESULTS
4/12/2011
2
R01: Webster, Michael J (GEOINSIGHT INC)
R01: Dilorenzo, James (US EPA REGION 1)
EML/Email
054-REMOVAL/0541-Removal
Responses/02.01-
CORRESPONDENCE (REMOVAL
RESPONSE)
UCTL( Uncontrolled)
1
httos://semspub.epa,gov/src/document/01/70001447
483570
[REDACTED] EMAIL REGARDING RESIDENTIALWELL
SAMPLING CONDUCTED ON 03/30/2011 AND
03/31/2011
4/11/2011
2
R01: Brunelle, Jeffrey (NOBIS ENGINEERING
INC)
R01: Dilorenzo, James (US EPA REGION 1)
EML/Email
054-REMOVAL/0541-Removal
Responses/02.01-
CORRESPONDENCE (REMOVAL
RESPONSE)
UCTL( Uncontrolled)
1
httDs://semspub.epa.gov/src/document/01/48357Q
483575
[REDACTED] EMAIL REGARDING N-
NITROSODIMETHYLAMINE (NDMA) IN PRIVATE WELLS
DATA CONFIRMATION
4/11/2011
2
R01: Dilorenzo, James (US EPA REGION 1)
R01: (WILMINGTON (MA) TOWN OF)
EML/Email
054-REMOVAL/0541-Removal
Responses/02.01-
CORRESPONDENCE (REMOVAL
RESPONSE)
UCTL( Uncontrolled)
1
httDs://semspub.epa.gov/src/document/Ql/483575
484735
[REDACTED] EMAIL REGARDING OLIN
CORRESPONDENCE DATED 04/07/2011
4/11/2011
1
R01: (WILMINGTON (MA) - RESIDENT OF)
R01: Dilorenzo, James (US EPA REGION 1)
EML/Email
054-REMOVAL/0541-Removal
Responses/02.01-
CORRESPONDENCE (REMOVAL
RESPONSE)
UCTL( Uncontrolled)
1
httDs://semspub.epa.gov/src/document/01/484735
70001442
EMAIL REGARDING HOME OWNER LETTERS
4/8/2011
1
R01: Morrow, Stephen (OLIN CORP)
R01: Dilorenzo, James (US EPA REGION 1)
EML/Email
054-REMOVAL/0541-Removal
Responses/02.01-
CORRESPONDENCE (REMOVAL
RESPONSE)
UCTL( Uncontrolled)
1
httos://semspub.epa,gov/src/document/0i/70001442
484789
MAP: FIGURE 1 N-NrTROSODIMETHYLAMINE (NDMA)
CONCENTRATIONS IN RESIDENTIAL WELLS, REVISION
03-2010
4/6/2011
1
R01: (NOBIS ENGINEERING INC)
FIG / Figure/Map/ Drawing
056-SITE SUPPORT/0561-
Administrative Support/17.04-NON-
PRINT MATERIALS
UCTL( Uncontrolled)
1
httDs://semspub.epa.gov/src/document/01/484789
-------
70001473
MAP: N-NITROSODIMETHYLAMINE (NDMA)
CONCENTRATIONS IN RESIDENTIAL WELLS - 2010
4/6/2011
1
R01: (NOBIS ENGINEERING INC)
FIG / Figure/Map/ Drawing
056-SITE SUPPORT/0561-
Administrative Support/17.04-NON-
PRINT MATERIALS
UCTL( Uncontrolled)
1
httos://semspub.epa,gov/src/document/Gl/7GGG1473
483568
[REDACTED] EMAIL REGARDING COMMENTS ON
REVISED PRIVATE WELL FIGURE (EMAIL HISTORY
ATTACHED)
4/5/2011
7
R01: Morrow, Stephen (OLIN CORP)
R01: Dilorenzo, James (US EPA REGION 1)
EML/Email
054-REMOVAL/0541-Removal
Responses/02.01-
CORRESPONDENCE (REMOVAL
RESPONSE)
UCTL( Uncontrolled)
1
httDs://semspub.epa.gov/src/document/01/483568
70001452
SUMMARY OF 2010 PRIVATE WELL DATA M-14/L-02B
4/5/2011
11
ADD/Analytical Data
Document
054-REMOVAL/0541-Removal
Responses/02.03-SAMPLING &
ANALYSIS DATA (REMOVAL
RESPONSE)
UCTL( Uncontrolled)
1
httos://semspub.epa,gov/src/document/Gl/7GGG1452
70001454
SUMMARY OF 2010 PRIVATE WELL DATA M-27M-27/L-
14C
4/5/2011
1
ADD/Analytical Data
Document
054-REMOVAL/0541-Removal
Responses/02.03-SAMPLING &
ANALYSIS DATA (REMOVAL
RESPONSE)
UCTL( Uncontrolled)
1
httDs://semspub.epa.gov/src/document/Gl/7GGG14 54
483567
[REDACTED] EMAIL REGARDING COMMENTS ON
REVISED PRIVATE WELL FIGURE
4/4/2011
4
R01: Morrow, Stephen (OLIN CORP)
R01: Dilorenzo, James (US EPA REGION 1)
EML/Email
054-REMOVAL/0541-Removal
Responses/02.01-
CORRESPONDENCE (REMOVAL
RESPONSE)
UCTL( Uncontrolled)
1
httos://semspub.epa.gov/src/document/Gl/483567
70001444
EMAIL REGARDING FIGURE 1 - N-
NITROSODIMETHYLAMINE (NDMA) CONCENTRATION
IN RESIDENTIAL WELLS - 2010 (EMAIL HISTORY
ATTACHED)
4/1/2011
2
R01: Bouvier, Marc (NOBIS ENGINEERING INC)
R01: Dilorenzo, James (US EPA REGION 1)
EML/Email
054-REMOVAL/0541-Removal
Responses/02.01-
CORRESPONDENCE (REMOVAL
RESPONSE)
UCTL( Uncontrolled)
1
httDs://semspub.epa,gov/src/document/01/70001444
70001470
EMAIL TRANSMITTING REVISED PRIVATE WELL FIGURE
4/1/2011
1
R01: Dilorenzo, James (US EPA REGION 1)
R01: Morrow, Stephen (OLIN CORP)
EML/Email
054-REMOVAL/0541-Removal
Responses/02.01-
CORRESPONDENCE (REMOVAL
RESPONSE)
UCTL( Uncontrolled)
1
httDs://semspub.epa,gov/src/document/01/70001470
485564
[REDACTED] MAP: FIGURE 1 N-
NITROSODIMETHYLAMINE (NDMA) CONCENTRATIONS
IN RESIDENTIAL WELLS - 2010
3/31/2011
1
R01: (NOBIS ENGINEERING INC)
FIG / Figure/Map/ Drawing
056-SITE SUPPORT/0561-
Administrative Support/17.04-NON-
PRINT MATERIALS
UCTL( Uncontrolled)
1
httDs://semspub.epa.gov/src/document/Ql/485564
70001475
FIGURE 1: N-NITROSODIMETHYLAMINE (NDMA)
CONCENTRATIONS IN RESIDENTIAL WELLS - 2010
3/31/2011
1
R01: (NOBIS ENGINEERING INC)
FIG / Figure/Map/ Drawing
056-SITE SUPPORT/0561-
Administrative Support/17.04-NON-
PRINT MATERIALS
UCTL( Uncontrolled)
1
httos://semspub.epa,gov/src/document/01/?00014?5
485658
[REDACTED] RESIDENTIAL WELLS FOR SAMPLING 2011
3/30/2011
2
LST/ List/Index
054-REMOVAL/0541-Removal
Responses/02.01-
CORRESPONDENCE (REMOVAL
RESPONSE)
UCTL( Uncontrolled)
1
httDs://semspub.epa.gov/src/document/01/485658
70001439
EMAIL REGARDING UPDATED RESIDENTIALSCHEDULE
3/30/2011
2
R01: Morrow, Stephen (OLIN CORP)
R01: Dilorenzo, James (US EPA REGION 1)
EML/Email
054-REMOVAL/0541-Removal
Responses/02.01-
CORRESPONDENCE (REMOVAL
RESPONSE)
UCTL( Uncontrolled)
1
httos://semspub.epa,gov/src/document/01/?0001439
483574
[REDACTED] EMAIL REGARDING PRIVATE WELL LETTERS
3/29/2011
1
R01: Dilorenzo, James (US EPA REGION 1)
R01: Morrow, Stephen (OLIN CORP)
EML/Email
054-REMOVAL/0541-Removal
Responses/02.01-
CORRESPONDENCE (REMOVAL
RESPONSE)
UCTL( Uncontrolled)
1
httDs://semspub.epa.gov/src/document/01/483574
483565
[REDACTED] EMAIL REGARDING DRAFT REVIEW FOR
PRIVATE WELL RESULTS QUARTER 3 AND 4
3/28/2011
2
R01: Morrow, Stephen (OLIN CORP)
R01: Dilorenzo, James (US EPA REGION 1)
EML/Email
054-REMOVAL/0541-Removal
Responses/02.01-
CORRESPONDENCE (REMOVAL
RESPONSE)
UCTL( Uncontrolled)
1
httDs://semspub.epa.gov/src/document/01/483565
483566
[REDACTED] EMAIL REGARDING PRIVATE WELL
QUARTER 3 AND 4, INTERNAL DRAFT
3/28/2011
2
R01: Morrow, Stephen (OLIN CORP)
R01: Dilorenzo, James (US EPA REGION 1)
EML/Email
054-REMOVAL/0541-Removal
Responses/02.01-
CORRESPONDENCE (REMOVAL
RESPONSE)
UCTL( Uncontrolled)
1
httDs://semspub.epa.gov/src/document/Ql/483566
483569
[REDACTED] EMAIL REGARDING PRIVATE WELL
SAMPLING 2011,1ST QUARTER (EMAIL HISTORY
ATTACHED)
3/28/2011
3
R01: Ford, Heather M (NOBIS ENGINEERING
INC)
R01: Dilorenzo, James (US EPA REGION 1)
EML/Email
054-REMOVAL/0541-Removal
Responses/02.01-
CORRESPONDENCE (REMOVAL
RESPONSE)
UCTL( Uncontrolled)
1
httDs://semspub.epa.gov/src/document/Ql/483569
483494
[REDACTED] SUMMARY OF PRIVATE WELL RESIDENCE
WELL MONITORING DATA AND COMPARISON TO
FEDERAL AND MASSACHUSETTS DRINKING WATER
STANDARDS/GUIDELINES
3/25/2011
1
ADD/Analytical Data
Document
054-REMOVAL/0541-Removal
Responses/02.03-SAMPLING &
ANALYSIS DATA (REMOVAL
RESPONSE)
UCTL( Uncontrolled)
1
httDs://semspub.epa.gov/src/document/Ql/483494
483495
[REDACTED] LETTER REGARDING RESIDENTIAL WELL
SAMPLING
3/25/2011
2
R01: Murphy, MichaelJ (MACTEC
ENGINEERING AND CONSULTING INC), R01:
Thompson, Peter(MACTEC ENGINEERING AND
CONSULTING INC)
R01: Morrow, Stephen (OLIN CORP)
LTR/Letter
054-REMOVAL/0541-Removal
Responses/02.01-
CORRESPONDENCE (REMOVAL
RESPONSE)
UCTL( Uncontrolled)
1
httDs://semspub.epa.gov/src/document/Ql/483495
483496
[REDACTED] LETTER REGARDING RESIDENTIAL WELL
SAMPLING
3/25/2011
2
R01: Morrow, Stephen (OLIN CORP)
R01: (WILMINGTON (MA) - RESIDENT OF)
LTR/Letter
054-REMOVAL/0541-Removal
Responses/02.01-
CORRESPONDENCE (REMOVAL
RESPONSE)
UCTL( Uncontrolled)
1
httDs://semspub.epa.gov/src/document/Ql/483496
483497
[REDACTED] SUMMARY OF PRIVATE WELL RESIDENCE
WELL MONITORING DATA AND COMPARISON TO
FEDERAL AND MASSACHUSETTS DRINKING WATER
STANDARDS/GUIDELINES
3/25/2011
1
ADD/Analytical Data
Document
054-REMOVAL/0541-Removal
Responses/02.03-SAMPLING &
ANALYSIS DATA (REMOVAL
RESPONSE)
UCTL( Uncontrolled)
1
httDs://semspub.epa.gov/src/document/Ql/483497
-------
483498
[REDACTED] LETTER REGARDING RESIDENTIAL WELL
SAMPLING
3/25/2011
2
R01: Murphy, MichaelJ (MACTEC
ENGINEERING AND CONSULTING INC), R01:
Thompson, Peter H (MACTEC ENGINEERING
AND CONSULTING INC)
R01: Morrow, Steve (OLIN CORP)
LTR/Letter
054-REMOVAL/0541-Removal
Responses/02.01-
CORRESPONDENCE (REMOVAL
RESPONSE)
UCTL( Uncontrolled)
1
htt Ds://semsoub.epa.gov/src/document/Ql/483498
483499
[REDACTED] LETTER REGARDING RESIDENTIAL WELL
SAMPLING
3/25/2011
1
R01: Morrow, Steve (OLIN CORP)
R01: (WILMINGTON (MA) - RESIDENT OF)
LTR/Letter
054-REMOVAL/0541-Removal
Responses/02.01-
CORRESPONDENCE (REMOVAL
RESPONSE)
UCTL( Uncontrolled)
1
htt Ds://semsoub.epa.gov/src/document/Ql/483499
483564
[REDACTED] EMAIL REGARDING PRIVATE WELL
SAMPLING 2011 - 1ST QUARTER
3/24/2011
2
R01: Morrow, Stephen (OLIN CORP)
R01: Dilorenzo, James (US EPA REGION 1)
EML/Email
054-REMOVAL/0541-Removal
Responses/02.01-
CORRESPONDENCE (REMOVAL
RESPONSE)
UCTL( Uncontrolled)
1
httos://semspub. epa.gov/sir/document/01/483564
485000
[REDACTED] ADDITIONAL PRIVATE WELLS LOCATION -
MARCH 2011
3/24/2011
2
LST/ List/Index
054-REMOVAL/0541-Removal
Responses/02.03-SAMPLING &
ANALYSIS DATA (REMOVAL
RESPONSE)
UCTL( Uncontrolled)
1
httBs://semspub.epa.gov/src/document/Ql/485QQQ
485657
[REDACTED] 2011 QUARTER 1 PRIVATE WELL DATA
3/24/2011
2
ADD/Analytical Data
Document
054-REMOVAL/0541-Removal
Responses/02.03-SAMPLING &
ANALYSIS DATA (REMOVAL
RESPONSE)
UCTL( Uncontrolled)
1
httDs://semspub.epa.gov/src/document/Ql/485S57
70001468
EMAIL TRANSMITTING ADDITIONAL PRIVATE WELL
LOCATIONS
3/24/2011
1
R01: Dilorenzo, James (US EPA REGION 1)
R01: Morrow, Stephen (OLIN CORP)
EML/Email
054-REMOVAL/0541-Removal
Responses/02.01-
CORRESPONDENCE (REMOVAL
RESPONSE)
UCTL( Uncontrolled)
1
httos://semspub.epa,gov/src/document/01/?00014S8
70001478
ADDmONALWELL LOCATIONS FIGURE
3/24/2011
1
R01: (GOOGLE)
FIG / Figure/Map/ Drawing
056-SITE SUPPORT/0561-
Administrative Support/17.04-NON-
PRINT MATERIALS
UCTL( Uncontrolled)
1
httos://semspub.epa,gov/src/document/01/?00014?8
483573
[REDACTED] EMAIL REGARDING LATEST PRIVATE WELL
RESULTS
3/21/2011
1
R01: Dilorenzo, James (US EPA REGION 1)
R01: Morrow, Stephen (OLIN CORP)
EML/Email
054-REMOVAL/0541-Removal
Responses/02.03-SAMPLING &
ANALYSIS DATA (REMOVAL
RESPONSE)
UCTL( Uncontrolled)
1
httDs://semspub.epa.gov/src/document/01/483573
70001435
EMAIL REGARDING WILMINGTON RESIDENTIAL WELLS
2010 DATA
3/21/2011
2
R01: Morrow, Stephen (OLIN CORP)
R01: Dilorenzo, James (US EPA REGION 1)
EML/Email
054-REMOVAL/0541-Removal
Responses/02.01-
CORRESPONDENCE (REMOVAL
RESPONSE)
UCTL( Uncontrolled)
1
httos://semspub.epa,gov/src/document/01/?00Q1435
70001461
SUMMARY OF 2010 PRIVATE WELL DATA M-14/L-02B
3/21/2011
11
ADD/Analytical Data
Document
054-REMOVAL/0541-Removal
Responses/02.03-SAMPLING &
ANALYSIS DATA (REMOVAL
RESPONSE)
UCTL( Uncontrolled)
1
httDs://semspub.epa.gov/src/document/Ql/7QQQ1461
70001482
SUMMARY OF 2010 PRIVATE WELL DATA
3/18/2011
11
ADD/Analytical Data
Document
054-REMOVAL/0541-Removal
Responses/02.03-SAMPLING &
ANALYSIS DATA (REMOVAL
RESPONSE)
UCTL( Uncontrolled)
1
httos://semspub.epa,gov/src/document/0i/?0001482
70001463
EMAIL REGRADING OLIN DRINKING WATER RISKS
(EMAIL HISTORY ATTACHED)
3/10/2011
2
R01: Dilorenzo, James (US EPA REGION 1)
R01: Woods, Cynthia (AVATAR
ENVIRONMENTAL)
EML/Email
054-REMOVAL/0541-Removal
Responses/02.01-
CORRESPONDENCE (REMOVAL
RESPONSE)
UCTL( Uncontrolled)
1
httos://semspub.epa,gov/src/document/0i/?0001463
70001515
EMAIL REGARDING OLIN DRINKING WATER RISKS
3/10/2011
1
R01: Woods, Cynthia (AVATAR
ENVIRONMENTAL)
R01: Dilorenzo, James (US EPA REGION 1)
EML/Email
054-REMOVAL/0541-Removal
Responses/02.01-
CORRESPONDENCE (REMOVAL
RESPONSE)
UCTL( Uncontrolled)
1
htt Ds://semsou b.epa.gov/src/docu ment/01/70001515
70001525
RESIDENTIAL DRINKING WATER INGESTION CANCER
RISK70 YEAR EXPOSURE
3/10/2011
1
ADD/Analytical Data
Document
054-REMOVAL/0541-Removal
Responses/02.03-SAMPLING &
ANALYSIS DATA (REMOVAL
RESPONSE)
UCTL( Uncontrolled)
1
httos://semspub.epa,gov/src/document/01/?0001525
653797
LETTER REGARDING APPROVAL OF MODIFICATION OF
POST CLOSURE MONITORING PLAN, OLIN GYPSUM
LANDFILL, 51 EAMES STREET
3/3/2011
2
R01: Adams, David C (MA DEPTOF
ENVIRONMENTAL PROTECTION), R01: Carrigan,
John A (MA DEPT OF ENVIRONMENTAL
PROTECTION)
R01: Morrow, Steve (OLIN CORP)
LTR/Letter
056-SITE SUPPORT/0563-
State/Tribal Involvement/09.10-
STATE TECHNICAL AND HISTORICAL
RECORDS
UCTL( Uncontrolled)
1
htt Ds://semspub.epa.gov/src/document/01/653797
485603
EMAIL REGARDING OLIN PRIVATE WELL INFORMATION
2/15/2011
1
R01: Newhouse, Shelly (WILMINGTON (MA)
BOARD OF HEALTH)
R01: Dilorenzo, James (US EPA REGION 1)
EML/Email
054-REMOVAL/0541-Removal
Responses/02.01-
CORRESPONDENCE (REMOVAL
RESPONSE)
UCTL( Uncontrolled)
1
htt Ds://semspub.epa.gov/src/document/01/4856Q3
70001521
EMAIL REGARDING OLIN PRIVATE WELL INFORMATION
2/15/2011
1
R01: Dilorenzo, James (US EPA REGION 1)
R01: Newhouse, Shelly (WILMINGTON (MA)
BOARD OF HEALTH)
EML/Email
054-REMOVAL/0541-Removal
Responses/02.01-
CORRESPONDENCE (REMOVAL
RESPONSE)
UCTL( Uncontrolled)
1
htt Ds://semsoub.epa.gov/src/document/Ql/7QQQ1521
485535
[REDACTED] LIST OF WELLS SORTED BY ADDRESSES
(MAPS ATTACHED) [HARD COPY IMAGE SKEWED]
2/11/2011
9
LST/ List/Index
054-REMOVAL/0541-Removal
Responses/02.01-
CORRESPONDENCE (REMOVAL
RESPONSE)
UCTL( Uncontrolled)
1
htt Ds://semsoub.epa.gov/src/document/Ql/485535
483590
[REDACTED] EMAIL REGARDING UNVALIDATED N-
NITROSODIMETHYLAMINE(NDMA) DATA FOR
DECEMBER SAMPLING (EMAIL HISTORY ATTACHED)
2/7/2011
3
R01: Ford, Heather M (NOBIS ENGINEERING
INC)
R01: Dilorenzo, James (US EPA REGION 1)
EML/Email
054-REMOVAL/0541-Removal
Responses/02.03-SAMPLING &
ANALYSIS DATA (REMOVAL
RESPONSE)
UCTL( Uncontrolled)
1
htt Ds://semsoub.epa.gov/src/document/Ql/48359Q
-------
484770
[REDACTED] FIGURE 1 N-NITROSODIMETHYLAMINE
(NDMA) CONCENTRATIONS IN RESIDENTIALWELLS-
DECEMBER2010
2/7/2011
1
R01: (NOBIS ENGINEERING INC)
FIG / Figure/Map/ Drawing
056-SITE SUPPORT/0561-
Administrative Support/17.04-NON-
PRINT MATERIALS
UCTL( Uncontrolled)
1
htt Ds://semsoub.epa.gov/src/document/Ql/48477Q
70001514
EMAIL REGARDING OLIN N-NITROSODIMETHYLAMINE
(NDMA) RESIDENTIALFIGURE
2/7/2011
1
R01: Bouvier, Marc (NOBIS ENGINEERING INC)
R01: Dilorenzo, James (US EPA REGION 1)
EML/Email
054-REMOVAL/0541-Removal
Responses/02.01-
CORRESPONDENCE (REMOVAL
RESPONSE)
UCTL( Uncontrolled)
1
htt os://semspu b.epa.gov/src/docu ment/Gl/7GGG1514
483589
[REDACTED] EMAIL REGARDING RESIDENTIALWELLS
SUMMARY RE PORT (EMAIL HISTORY ATTACHED)
2/4/2011
7
R01: Ford, Heather M (NOBIS ENGINEERING
INC)
R01: Dilorenzo, James (US EPA REGION 1)
EML/Email
054-REMOVAL/0541-Removal
Responses/02.01-
CORRESPONDENCE (REMOVAL
RESPONSE)
UCTL( Uncontrolled)
1
httos://semspub. epa.gov/sir/document/01/483589
483580
[REDACTED] EMAIL REGARDING WELL RESULTS
1/31/2011
2
R01: Morrow, Stephen (OLIN CORP)
R01: Dilorenzo, James (US EPA REGION 1)
EML/Email
054-REMOVAL/0541-Removal
Responses/02.03-SAMPLING &
ANALYSIS DATA (REMOVAL
RESPONSE)
UCTL( Uncontrolled)
1
htt Ds://semsou b.epa.gov/src/docu ment/01/483580
483588
[REDACTED] EMAIL REGARDING LOW-LEVEL PAHS
DETECTED IN PRIVATE WELLS (EMAIL HISTORY
ATTACHED)
1/26/2011
3
R01: Sugatt, Richard (US EPA REGION 1)
R01: Dilorenzo, James (US EPA REGION 1)
EML/Email
054-REMOVAL/0541-Removal
Responses/02.01-
CORRESPONDENCE (REMOVAL
RESPONSE)
UCTL( Uncontrolled)
1
htt Ds://semspub.epa.gov/src/document/Ql/483588
483586
[REDACTED] EMAIL REGARDING LOW-LEVEL PAHS
DETECTED IN PRIVATE WELLS (EMAIL HISTORY
ATTACHED)
1/25/2011
2
R01: Sugatt, Richard (US EPA REGION 1)
R01: Dilorenzo, James (US EPA REGION 1)
EML/Email
054-REMOVAL/0541-Removal
Responses/02.03-SAMPLING &
ANALYSIS DATA (REMOVAL
RESPONSE)
UCTL( Uncontrolled)
1
htt Ds://semspub.epa.gov/src/document/01/483586
483587
[REDACTED] EMAIL REGARDING LOW-LEVEL PAHS
DETECTED IN PRIVATE WELLS (EMAIL HISTORY
ATTACHED)
1/25/2011
4
R01: Ford, Heather M (NOBIS ENGINEERING
INC)
R01: Dilorenzo, James (US EPA REGION 1)
EML/Email
054-REMOVAL/0541-Removal
Responses/02.01-
CORRESPONDENCE (REMOVAL
RESPONSE)
UCTL( Uncontrolled)
1
htt Ds://semsoub.epa.gov/src/document/Ql/483587
483594
[REDACTED] EMAIL REGARDING OLIN SUMMER 2010
DRINKING WATER WELLS - PAHS
1/25/2011
2
R01: Dilorenzo, James (US EPA REGION 1)
R01: Woods, Cynthia (AVATAR
ENVIRONMENTAL)
EML/Email
054-REMOVAL/0541-Removal
Responses/02.03-SAMPLING &
ANALYSIS DATA (REMOVAL
RESPONSE)
UCTL( Uncontrolled)
1
htt Ds://semsoub.epa.gov/src/document/Ql/483594
484739
LETTER REGARDING TRITES RESIDENCE WELL
SAMPLING
1/24/2011
2
R01: Murphy, MichaelJ (MACTEC
ENGINEERING AND CONSULTING INC), R01:
Thompson, Peter(MACTEC ENGINEERING AND
CONSULTING INC)
R01: Morrow, Steve (OLIN CORP)
LTR/Letter
054-REMOVAL/0541-Removal
Responses/02.01-
CORRESPONDENCE (REMOVAL
RESPONSE)
UCTL( Uncontrolled)
1
htt Ds://semsoub.epa.gov/src/document/Ql/484739
485043
[REDACTED] LETTER REGARDING RESIDENTIAL WELL
SAMPLING
1/24/2011
2
R01: Murphy, MichaelJ (MACTEC
ENGINEERING AND CONSULTING INC), R01:
Thompson, Peter(MACTEC ENGINEERING AND
CONSULTING INC)
R01: Morrow, Steve (OLIN CORP)
LTR/Letter
054-REMOVAL/0541-Removal
Responses/02.01-
CORRESPONDENCE (REMOVAL
RESPONSE)
UCTL( Uncontrolled)
1
htt Ds://semsoub.epa.gov/src/document/Ql/485Q43
485504
[REDACTED] LETTER REGARDING RESIDENTIAL WELL
SAMPLING CONDUCTED IN AUGUST 2010
1/24/2011
2
R01: Murphy, MichaelJ (MACTEC
ENGINEERING AND CONSULTING INC), R01:
Thompson, Peter(MACTEC ENGINEERING AND
CONSULTING INC)
R01: Morrow, Steve (OLIN CORP)
LTR/Letter
054-REMOVAL/0541-Removal
Responses/02.01-
CORRESPONDENCE (REMOVAL
RESPONSE)
UCTL( Uncontrolled)
1
htt Ds://semsoub.epa.gov/src/document/Ql/4855Q4
485507
[REDACTED] LETTER REGARDING RESIDENTIAL WELL
SAMPLING CONDUCTED IN AUGUST 2010
1/24/2011
2
R01: Murphy, MichaelJ (MACTEC
ENGINEERING AND CONSULTING INC), R01:
Thompson, Peter(MACTEC ENGINEERING AND
CONSULTING INC)
R01: Morrow, Steve (OLIN CORP)
LTR/Letter
054-REMOVAL/0541-Removal
Responses/02.01-
CORRESPONDENCE (REMOVAL
RESPONSE)
UCTL( Uncontrolled)
1
htt Ds://semsoub.epa.gov/src/document/Ql/4855Q7
485676
[REDACTED] LETTER REGARDING RESIDENTIAL WELL
SAMPLING
1/24/2011
2
R01: Murphy, MichaelJ (MACTEC
ENGINEERING AND CONSULTING INC), R01:
Thompson, Peter(MACTEC ENGINEERING AND
CONSULTING INC)
R01: Morrow, Steve (OLIN CORP)
LTR/Letter
054-REMOVAL/0541-Removal
Responses/02.01-
CORRESPONDENCE (REMOVAL
RESPONSE)
UCTL( Uncontrolled)
1
htt Ds://semsoub.epa.gov/src/document/Ql/485S7S
484738
[REDACTED] EMAIL REGARDING WELL WATER
APPOINTMENT CANCELLATION (EMAIL HISTORY
ATTACHED)
1/18/2011
2
R01: Dilorenzo, James (US EPA REGION 1)
R01: (WILMINGTON (MA) - RESIDENT OF)
EML/Email
054-REMOVAL/0541-Removal
Responses/02.01-
CORRESPONDENCE (REMOVAL
RESPONSE)
UCTL( Uncontrolled)
1
htt Ds://semsoub.epa.gov/src/document/Ql/484738
485508
[REDACTED] LETTER REGARDING RESIDENTIAL WELL
SAMPLING CONDUCTED IN AUGUST 2010
1/18/2011
1
R01: Murphy, MichaelJ (MACTEC
ENGINEERING AND CONSULTING INC), R01:
Thompson, Peter(MACTEC ENGINEERING AND
CONSULTING INC)
R01: Morrow, Steve (OLIN CORP)
LTR/Letter
054-REMOVAL/0541-Removal
Responses/02.01-
CORRESPONDENCE (REMOVAL
RESPONSE)
UCTL( Uncontrolled)
1
htt Ds://semsoub.epa.gov/src/document/Ql/4855Q8
485512
[REDACTED] LETTER REGARDING RESIDENTIAL WELL
SAMPLING CONDUCTED IN AUGUST 2010
1/18/2011
1
R01: Murphy, MichaelJ (MACTEC
ENGINEERING AND CONSULTING INC), R01:
Thompson, Peter(MACTEC ENGINEERING AND
CONSULTING INC)
R01: Morrow, Steve (OLIN CORP)
LTR/Letter
054-REMOVAL/0541-Removal
Responses/02.01-
CORRESPONDENCE (REMOVAL
RESPONSE)
UCTL( Uncontrolled)
1
httos://semspub.epa,gov/src/document/01/485512
485520
[REDACTED] LETTER REGARDING RESIDENTIAL WELL
SAMPLING CONDUCTED IN AUGUST 2010
1/18/2011
1
R01: Murphy, MichaelJ (MACTEC
ENGINEERING AND CONSULTING INC), R01:
Thompson, Peter(MACTEC ENGINEERING AND
CONSULTING INC)
R01: Morrow, Steve (OLIN CORP)
LTR/Letter
054-REMOVAL/0541-Removal
Responses/02.01-
CORRESPONDENCE (REMOVAL
RESPONSE)
UCTL( Uncontrolled)
1
htt Ds://semsoub.epa.gov/src/document/Ql/48552Q
485538
[REDACTED] LETTER TRANSMITTING RESULTS OF
RESIDENTIAL WELL SAMPLING CONDUCTED IN AUGUST
2010
1/18/2011
1
R01: Morrow, Steve (OLIN CORP)
R01: (WILMINGTON (MA) - RESIDENT OF)
LTR/Letter
054-REMOVAL/0541-Removal
Responses/02.01-
CORRESPONDENCE (REMOVAL
RESPONSE)
UCTL( Uncontrolled)
1
htt Ds://semsoub.epa.gov/src/document/Ql/485538
485539
[REDACTED] LETTER TRANSMITTING RESULTS OF
RESIDENTIAL WELL SAMPLING CONDUCTED IN AUGUST
2010
1/18/2011
1
R01: Morrow, Steve (OLIN CORP)
R01: (WILMINGTON (MA) - RESIDENT OF)
LTR/Letter
054-REMOVAL/0541-Removal
Responses/02.01-
CORRESPONDENCE (REMOVAL
RESPONSE)
UCTL( Uncontrolled)
1
htt Ds://semsoub.epa.gov/src/document/Ql/485539
-------
485540
[REDACTED] LETTER TRANSMITTING RESULTS OF
RESIDENTIAL WELL SAMPLING CONDUCTED IN AUGUST
2010
1/18/2011
1
R01: Morrow, Steve (OLIN CORP)
R01: (WILMINGTON (MA) - RESIDENT OF)
LTR/Letter
054-REMOVAL/0541-Removal
Responses/02.01-
CORRESPONDENCE (REMOVAL
RESPONSE)
UCTL( Uncontrolled)
1
httDs://semspub.epa.gov/src/document/Ql/48554Q
483585
[REDACTED] EMAIL REGARDING WELL WATER
APPOINTMENT CANCELLATION
1/17/2011
1
R01: (WILMINGTON (MA) - RESIDENT OF)
R01: Dilorenzo, James (US EPA REGION 1)
EML/Email
054-REMOVAL/0541-Removal
Responses/02.01-
CORRESPONDENCE (REMOVAL
RESPONSE)
UCTL( Uncontrolled)
1
httDs://semspub.epa.gov/src/document/Ql/483585
485042
[REDACTED] LEI ILR 1RANSMITTING RESULTS OF
RESIDENTIAL WELL SAMPLING CONDUCTED IN JULY
AND AUGUST 2010 (CERTIFIED MAIL RECEIPTS AND
SUPPORTING DOCUMENTATION ATTACHED)
1/17/2011
46
R01: Morrow, Steve (OLIN CORP)
R01: (WILMINGTON (MA) - RESIDENT OF)
LTR/Letter
054-REMOVAL/0541-Removal
Responses/02.01-
CORRESPONDENCE (REMOVAL
RESPONSE)
UCTL( Uncontrolled)
1
httDs://semspub.epa.gov/src/document/Ql/485Q42
650493
SEMI-ANNUAL STATUS REPORT NO. 7
1/14/2011
27759
R01:(MACTEC ENGINEERING AND
CONSULTING INC), R01: OLIN CORP)
R01: (US EPA REGION 1)
RPT/ Report
053-REMEDIAL/0531-Remedy
Characterization/03.07-WORK
PLANS & PROGRESS REPORTS (Rl)
UCTL( Uncontrolled)
1
httDs://semspub.epa.gov/src/document/Gl/65Q493
483577
[REDACTED] EMAIL REGARDING QUARTERS 1 AND 2
RESULT LETTERS (EMAIL HISTORY ATTACHED)
1/13/2011
2
R01: Morrow, Stephen (OLIN CORP)
R01: Dilorenzo, James (US EPA REGION 1)
EML/Email
054-REMOVAL/0541-Removal
Responses/02.01-
CORRESPONDENCE (REMOVAL
RESPONSE)
UCTL( Uncontrolled)
1
httBs://semspub.epa.gov/src/document/01/483577
483578
[REDACTED] EMAIL REGARDING QUARTER 2 RESULT
LETTERS (EMAIL HISTORY ATTACHED)
1/13/2011
2
R01: Morrow, Stephen (OLIN CORP)
R01: Dilorenzo, James (US EPA REGION 1)
EML/Email
054-REMOVAL/0541-Removal
Responses/02.01-
CORRESPONDENCE (REMOVAL
RESPONSE)
UCTL( Uncontrolled)
1
httDs://semspub.epa.gov/src/document/01/483578
483579
[REDACTED] EMAIL REGARDING QUARTER 2 RESULTS
LETTERS (EMAIL HISTORY ATTACHED)
1/13/2011
2
R01: Morrow, Stephen (OLIN CORP)
R01: Dilorenzo, James (US EPA REGION 1)
EML/Email
054-REMOVAL/0541-Removal
Responses/02.01-
CORRESPONDENCE (REMOVAL
RESPONSE)
UCTL( Uncontrolled)
1
httDs://semspub.epa.gov/src/document/Ql/483579
483584
[REDACTED] EMAIL REGARDING WELL WATER
APPOINTMENT (EMAIL HISTORY ATTACHED)
1/13/2011
8
R01: (WILMINGTON (MA) - RESIDENT OF)
R01: Dilorenzo, James (US EPA REGION 1)
EML/Email
054-REMOVAL/0541-Removal
Responses/02.01-
CORRESPONDENCE (REMOVAL
RESPONSE)
UCTL( Uncontrolled)
1
httDs://semspub.epa.gov/src/document/Ql/483584
485659
[REDACTED] TRANSMITTAL LETTER FOR DATA
VALIDATION SUMMARY AND LABORATORY
ANALYTICAL DATA
1/13/2011
1
R01: Morrow, Stephen (OLIN CORP)
R01: (WILMINGTON (MA) - RESIDENT OF)
LTR/Letter
054-REMOVAL/0541-Removal
Responses/02.01-
CORRESPONDENCE (REMOVAL
RESPONSE)
UCTL( Uncontrolled)
1
httDs://semspub.epa.gov/src/document/Ql/485S59
485667
[REDACTED] LETTER REGARDING RESIDENTIAL WELL
SAMPLING
1/13/2011
1
R01: Morrow, Stephen (OLIN CORP)
R01: (WILMINGTON (MA) - RESIDENT OF)
LTR/Letter
054-REMOVAL/0541-Removal
Responses/02.03-SAMPLING &
ANALYSIS DATA (REMOVAL
RESPONSE)
UCTL( Uncontrolled)
1
httDs://semspub.epa.gov/src/document/Ql/485S67
485001
[REDACTED] LETTER REGARDING RESIDENTIAL WELL
SAMPLING
1/11/2011
1
R01: Murphy, MichaelJ (MACTEC
ENGINEERING AND CONSULTING INC), R01:
Thompson, Peter(MACTEC ENGINEERING AND
CONSULTING INC)
R01: Morrow, Steve (OLIN CORP)
LTR/Letter
054-REMOVAL/0541-Removal
Responses/02.03-SAMPLING &
ANALYSIS DATA (REMOVAL
RESPONSE)
UCTL( Uncontrolled)
1
httos://semspub.epa,gov/src/document/01/48500i
485002
[REDACTED] TRANSMITTAL LETTER FOR DATA
VALIDATION SUMMARY AND LABORATORY
ANALYTICAL DATA
1/11/2011
1
R01: Morrow, Stephen (OLIN CORP)
R01: (WILMINGTON (MA) - RESIDENT OF)
LTR/Letter
054-REMOVAL/0541-Removal
Responses/02.01-
CORRESPONDENCE (REMOVAL
RESPONSE)
UCTL( Uncontrolled)
1
httDs://semspub.epa.gov/src/document/Ql/485QQ2
485004
[REDACTED] LETTER REGARDING RESIDENTIAL WELL
SAMPLING
1/11/2011
1
R01: Murphy, MichaelJ (MACTEC
ENGINEERING AND CONSULTING INC), R01:
Thompson, Peter(MACTEC ENGINEERING AND
CONSULTING INC)
R01: Morrow, Steve (OLIN CORP)
LTR/Letter
054-REMOVAL/0541-Removal
Responses/02.01-
CORRESPONDENCE (REMOVAL
RESPONSE)
UCTL( Uncontrolled)
1
httDs://semspub.epa.gov/src/document/Ql/485QQ4
485549
[REDACTED] LETTER REGARDING RESIDENTIAL WELL
SAMPLING
1/11/2011
1
R01: Murphy, MichaelJ (MACTEC
ENGINEERING AND CONSULTING INC), R01:
Thompson, Peter(MACTEC ENGINEERING AND
CONSULTING INC)
R01: Morrow, Steve (OLIN CORP)
LTR/Letter
054-REMOVAL/0541-Removal
Responses/02.01-
CORRESPONDENCE (REMOVAL
RESPONSE)
UCTL( Uncontrolled)
1
httDs://semspub.epa.gov/src/document/Ql/485549
483582
[REDACTED] EMAIL CORRESPONDENCE REGARDING
WELL WATER (EMAIL HISTORY ATTACH ED)
1/5/2011
3
R01: (WILMINGTON (MA) - RESIDENT OF)
R01: Dilorenzo, James (US EPA REGION 1)
EML/Email
054-REMOVAL/0541-Removal
Responses/02.01-
CORRESPONDENCE (REMOVAL
RESPONSE)
UCTL( Uncontrolled)
1
httDs://semspub.epa.gov/src/document/Ql/483582
483583
[REDACTED] EMAIL REGARDING WELL WATER
APPOINTMENT (EMAIL HISTORY ATTACHED)
1/5/2011
5
R01: (WILMINGTON (MA) - RESIDENT OF)
R01: Dilorenzo, James (US EPA REGION 1)
EML/Email
054-REMOVAL/0541-Removal
Responses/02.01-
CORRESPONDENCE (REMOVAL
RESPONSE)
UCTL( Uncontrolled)
1
httDs://semspub.epa.gov/src/document/Ql/483583
483592
[REDACTED] EMAIL REGARDING WELL WATER
APPOINTMENT (EMAIL HISTORY ATTACHED)
1/5/2011
4
R01: Dilorenzo, James (US EPA REGION 1)
R01: (WILMINGTON (MA) - RESIDENT OF)
EML/Email
054-REMOVAL/0541-Removal
Responses/02.01-
CORRESPONDENCE (REMOVAL
RESPONSE)
UCTL( Uncontrolled)
1
httDs://semspub.epa.gov/src/document/Ql/483592
483593
[REDACTED] EMAIL REGARDING WELL WATER
APPOINTMENT (EMAIL HISTORY ATTACHED)
1/5/2011
6
R01: Dilorenzo, James (US EPA REGION 1)
R01: (WILMINGTON (MA) - RESIDENT OF)
EML/Email
054-REMOVAL/0541-Removal
Responses/02.01-
CORRESPONDENCE (REMOVAL
RESPONSE)
UCTL( Uncontrolled)
1
httDs://semspub.epa.gov/src/document/Ql/483593
483581
[REDACTED] EMAIL REGARDING BOTTLED WATER
12/27/2010
2
R01: Morrow, Steven G (OLIN CHEMICAL CORP)
R01: Guichard, Brian (OLIN CHEMICAL)
EML/Email
054-REMOVAL/0541-Removal
Responses/02.01-
CORRESPONDENCE (REMOVAL
RESPONSE)
UCTL( Uncontrolled)
1
httos://semspub.epa,gov/src/document/01/483581
-------
483591
[REDACTED] EMAIL REGARDING WELL WATER (EMAIL
HISTORY ATTACHED)
12/27/2010
3
R01: Dilorenzo, James (US EPA REGION 1)
R01: (WILMINGTON (MA) - RESIDENT OF)
EML/Email
054-REMOVAL/0541-Removal
Responses/02.01-
CORRESPONDENCE (REMOVAL
RESPONSE)
UCTL( Uncontrolled)
1
httDs://semspub.epa,gov/src/document/Ql/483591
484736
[REDACTED] EMAIL CORRESPONDENCE REGARDING
WELL WATER
12/24/2010
2
R01: (WILMINGTON (MA) - RESIDENT OF)
R01: Dilorenzo, James (US EPA REGION 1)
EML/Email
054-REMOVAL/0541-Removal
Responses/02.01-
CORRESPONDENCE (REMOVAL
RESPONSE)
UCTL( Uncontrolled)
1
httDs://semspub.epa.gov/src/document/Ql/484736
485668
[REDACTED] PRIVATE RESIDENTIALWELLS SAMPLED
12/15/2010
2
RPT/ Report
054-REMOVAL/0541-Removal
Responses/02.03-SAMPLING &
ANALYSIS DATA (REMOVAL
RESPONSE)
UCTL( Uncontrolled)
1
httDs://semspub.epa.gov/src/document/Ql/485668
70001491
EMAIL REGARDING FOURTH QUARTER PRIVATE WELL
SAMPLING
12/15/2010
2
R01: Morrow, Stephen (OLIN CORP)
R01: Dilorenzo, James (US EPA REGION 1)
EML/Email
054-REMOVAL/0541-Removal
Responses/02.01-
CORRESPONDENCE (REMOVAL
RESPONSE)
UCTL( Uncontrolled)
1
httDs://semspub.epa.gov/src/document/Gl/7GGQ1491
653930
LETTER REGARDING MODIFICATION OF POSTCLOSURE
MONITORING PLAN, REQUIREMENT FORAPPLIATION,
OLIN GYPSUM LANDFILL
12/14/2010
2
R01: Adams, David C (MA DEPTOF
ENVIRONMENTAL PROTECTION), R01: Carrigan,
John A (MA DEPT OF ENVIRONMENTAL
PROTECTION)
R01: Morrow, Stephen (OLIN CORP)
LTR/Letter
056-SITE SUPPORT/0563-
State/Tribal Involvement/09.10-
STATE TECHNICAL AND HISTORICAL
RECORDS
UCTL( Uncontrolled)
1
httDs://semspub.epa.gov/src/document/Gl/65393G
484758
[REDACTED] PRIVATE RESIDENTIALWELLS SAMPLED
DECEMBER 2010
12/1/2010
2
ADD/Analytical Data
Document
054-REMOVAL/0541-Removal
Responses/02.03-SAMPLING &
ANALYSIS DATA (REMOVAL
RESPONSE)
UCTL( Uncontrolled)
1
httBs://semspub.epa.gov/src/document/01/484758
485038
[REDACTED] LEI ILR 1RANSMITTING RESULTS OF
RESIDENTIAL WELL SAMPLING CONDUCTED IN JULY,
AUGUST AND SEPTEMBER 2010 (SUPPORTING
DOCUMENTATION ATTACHED) [MARGINALIA]
11/29/2010
36
R01: Morrow, Steve (OLIN CORP)
R01: (WILMINGTON (MA) - RESIDENT OF)
LTR/Letter
054-REMOVAL/0541-Removal
Responses/02.01-
CORRESPONDENCE (REMOVAL
RESPONSE)
UCTL( Uncontrolled)
1
httDs://semspub.epa.gov/src/document/01/485Q38
484706
[REDACTED] EMAIL REGARDING N-
NITROSODIMETHYLAMINE (NDMA) WELLS
11/12/2010
2
R01: (TOWN OF WILMINGTON)
R01: Dilorenzo, James (US EPA REGION 1)
EML/Email
054-REMOVAL/0541-Removal
Responses/02.01-
CORRESPONDENCE (REMOVAL
RESPONSE)
UCTL( Uncontrolled)
1
httDs://semspub.epa.gov/src/document/Ql/4847QS
484712
[REDACTED] EMAIL REGARDING N-
NITROSODIMETHYLAMINE (NDMA) IN WELLS
11/12/2010
1
R01: Dilorenzo, James (US EPA REGION 1)
R01: (TOWN OF WILMINGTON)
EML/Email
054-REMOVAL/0541-Removal
Responses/02.01-
CORRESPONDENCE (REMOVAL
RESPONSE)
UCTL( Uncontrolled)
1
httos://semspub.epa,gov/src/document/01/484712
484713
[REDACTED] EMAIL REGARDING N-
NITROSODIMETHYLAMINE (NDMA) IN WELLS AND
ASKING FOR POSIBILITYTO GET IN TOUCH WITH
OWNERS (EMAIL HISTORY ATTACH ED)
11/12/2010
2
R01: Dilorenzo, James (US EPA REGION 1)
R01: (TOWN OF WILMINGTON)
EML/Email
054-REMOVAL/0541-Removal
Responses/02.01-
CORRESPONDENCE (REMOVAL
RESPONSE)
UCTL( Uncontrolled)
1
httos://semspub.epa,gov/src/document/01/484713
484714
[REDACTED] EMAIL REGARDING RECOMMENDATION
THAT WELL WATER NO LONGER BE USED FOR
DRINKING OR COOKING PURPOSES DUE TO
CONTINUED DETECTION OF NDMA
11/12/2010
1
R01: Dilorenzo, James (US EPA REGION 1)
R01: (WILMINGTON (MA) - RESIDENT OF)
EML/Email
054-REMOVAL/0541-Removal
Responses/02.01-
CORRESPONDENCE (REMOVAL
RESPONSE)
UCTL( Uncontrolled)
1
httos://semspub.epa,gov/src/document/01/484714
485003
[REDACTED] SUMMARY OF PRIVATE RESIDENCE WELL
MONITORING DATA AND COMPARISON TO FEDERAL
AND MASSACHUSETTS DRINKING WATER
STANDARDS/GUIDELINES (12/03/2010 DATA
VALIDATION SUMMARY ATTACHED)
11/12/2010
44
ADD/Analytical Data
Document
054-REMOVAL/0541-Removal
Responses/02.03-SAMPLING &
ANALYSIS DATA (REMOVAL
RESPONSE)
UCTL( Uncontrolled)
1
httDs://semspub.epa.gov/src/document/Ql/485QQ3
485006
[REDACTED] SUMMARY OF PRIVATE RESIDENCE WELL
MONITORING DATA AND COMPARISON TO FEDERAL
AND MASSACHUSETTS DRINKING WATER
STANDARDS/GUIDELINES (12/03/2010 DATA
VALIDATION SUMMARY ATTACHED)
11/12/2010
50
ADD/Analytical Data
Document
054-REMOVAL/0541-Removal
Responses/02.03-SAMPLING &
ANALYSIS DATA (REMOVAL
RESPONSE)
UCTL( Uncontrolled)
1
httDs://semspub.epa.gov/src/document/Ql/485QQS
485505
[REDACTED] SUMMARY OF PRIVATE RESIDENCE WELL
MONITORING DATA AND COMPARISON TO FEDERAL
AND MASSACHUSETTS DRINKING WATER
STANDARDS/GUIDELINES (12/03/2010 DATA
VALIDATION SUMMARY ATTACHED)
11/12/2010
60
ADD/Analytical Data
Document
054-REMOVAL/0541-Removal
Responses/02.03-SAMPLING &
ANALYSIS DATA (REMOVAL
RESPONSE)
UCTL( Uncontrolled)
1
httDs://semspub.epa.gov/src/document/Ql/4855Q5
485506
[REDACTED] SUMMARY OF PRIVATE RESIDENCE WELL
MONITORING DATA AND COMPARISON TO FEDERAL
AND MASSACHUSETTS DRINKING WATER
STANDARDS/GUIDELINES (12/03/2010 DATA
VALIDATION SUMMARY ATTACHED) [MARGINALIA]
11/12/2010
60
ADD/Analytical Data
Document
054-REMOVAL/0541-Removal
Responses/02.03-SAMPLING &
ANALYSIS DATA (REMOVAL
RESPONSE)
UCTL( Uncontrolled)
1
httDs://semspub.epa.gov/src/document/Ql/4855QS
485509
[REDACTED] SUMMARY OF PRIVATE RESIDENCE WELL
MONITORING DATA AND COMPARISON TO FEDERAL
AND MASSACHUSETTS DRINKING WATER
STANDARDS/GUIDELINES (12/03/2010 DATA
VALIDATION SUMMARY ATTACHED)
11/12/2010
60
ADD/Analytical Data
Document
054-REMOVAL/0541-Removal
Responses/02.03-SAMPLING &
ANALYSIS DATA (REMOVAL
RESPONSE)
UCTL( Uncontrolled)
1
httDs://semspub.epa.gov/src/document/Ql/4855Q9
485513
[REDACTED] SUMMARY OF PRIVATE RESIDENCE WELL
MONITORING DATA AND COMPARISON TO FEDERAL
AND MASSACHUSETTS DRINKING WATER
STANDARDS/GUIDELINES (12/03/2010 DATA
VALIDATION SUMMARY ATTACHED) [MARGINALIA]
11/12/2010
60
ADD/Analytical Data
Document
054-REMOVAL/0541-Removal
Responses/02.03-SAMPLING &
ANALYSIS DATA (REMOVAL
RESPONSE)
UCTL( Uncontrolled)
1
httos://semspub.epa,gov/src/document/01/485513
-------
485521
[REDACTED] SUMMARY OF PRIVATE RESIDENCE WELL
MONITORING DATA AND COMPARISON TO FEDERAL
AND MASSACHUSETTS DRINKING WATER
STANDARDS/GUIDELINES (12/03/2010 DATA
VALIDATION SUMMARY ATTACHED) [MARGINALIA]
11/12/2010
60
ADD/Analytical Data
Document
054-REMOVAL/0541-Removal
Responses/02.03-SAMPLING &
ANALYSIS DATA (REMOVAL
RESPONSE)
UCTL( Uncontrolled)
1
httos://semspub.epa,gov/src/document/01/485521
485522
[REDACTED] SUMMARY OF PRIVATE RESIDENCE WELL
MONITORING DATA AND COMPARISON TO FEDERAL
AND MASSACHUSETTS DRINKING WATER
STANDARDS/GUIDELINES (12/03/2010 DATA
VALIDATION SUMMARY ATTACHED) [MARGINALIA]
11/12/2010
76
ADD/Analytical Data
Document
054-REMOVAL/0541-Removal
Responses/02.03-SAMPLING &
ANALYSIS DATA (REMOVAL
RESPONSE)
UCTL( Uncontrolled)
1
htt Ds://semsoub.epa.gov/src/document/Ql/485522
485005
[REDACTED] SUMMARY OF PRIVATE RESIDENCE WELL
MONITORING DATA AND COMPARISON TO FEDERAL
AND MASSACHUSETTS DRINKING WATER
STANDARDS/GUIDELINES (12/03/2010 DATA
VALIDATION SUMMARY ATTACHED)
11/11/2010
60
ADD/Analytical Data
Document
054-REMOVAL/0541-Removal
Responses/02.03-SAMPLING &
ANALYSIS DATA (REMOVAL
RESPONSE)
UCTL( Uncontrolled)
1
htt os://semspu b.epa.gov/src/docu ment/Gl/485GG5
485516
[REDACTED] LETTER REGARDING US EPA REQUESTTO
PROVIDE BOTTLED WATER (SUPPORTING
DOCUMENTATION ATTACHED)
11/8/2010
83
R01: Hilliard, Garland (OLIN CORP)
R01: Owens, James T (US EPA REGION 1)
LTR/Letter
054-REMOVAL/0541-Removal
Responses/02.01-
CORRESPONDENCE (REMOVAL
RESPONSE)
UCTL( Uncontrolled)
1
httos://semspub.epa,gov/src/document/01/485516
484701
[REDACTED] EMAIL TRANSMITTING RISK
CALCULATIONS FOR ALL DETECTED COMPOUNDS
(EMAIL HISTORY ATTACHED)
11/1/2010
3
R01: Morrow, Steven G (OLIN CHEMICAL CORP)
R01: Dilorenzo, James (US EPA REGION 1)
EML/Email
054-REMOVAL/0541-Removal
Responses/02.01-
CORRESPONDENCE (REMOVAL
RESPONSE)
UCTL( Uncontrolled)
1
httos://semspub.epa,gov/src/document/01/484701
485082
MEMO CONCERNING NDMA IN PRIVATE WELLSAND
RECOMMENDATION TO DISCONTINUE CONSUMPTION
11/1/2010
1
R01: Dilorenzo, James (US EPA REGION 1)
R01: Owens, James T (US EPA REGION 1)
MEMO/Memorandum
054-REMOVAL/0541-Removal
Responses/02.01-
CORRESPONDENCE (REMOVAL
RESPONSE)
UCTL( Uncontrolled)
1
htt Ds://semsoub.epa.gov/src/document/Gl/485G82
485502
[REDACTED] REQUESTTO REDUCE EXPOSURE TO
NDMA (ROUTING ANDTRANSMITTAL SLIP ATTACHED)
(WrTH CONCURRENCES)
11/1/2010
4
R01: Owens, James T (US EPA REGION 1)
R01: Hilliard, Garland (OLIN CORP)
LTR/Letter
054-REMOVAL/0541-Removal
Responses/02.01-
CORRESPONDENCE (REMOVAL
RESPONSE)
UCTL( Uncontrolled)
1
htt Ds://semspub.epa.gov/srt/document/Ql/4855Q2
485666
[REDACTED] REQUESTTO REDUCE EXPOSURE TO
NDMA [UNSIGNED]
11/1/2010
3
R01: Owens, James T (US EPA REGION 1)
R01: Hilliard, Garland (OLIN CORP)
LTR/Letter
054-REMOVAL/0541-Removal
Responses/02.01-
CORRESPONDENCE (REMOVAL
RESPONSE)
UCTL( Uncontrolled)
1
htt Ds://semsoub.epa.gov/src/document/01/485S66
70001543
EMAIL TRANSMITTING N-NITROSODIMETHYLAMINE
(NDMA) 1E-04 RISK SPREADSHEET
10/28/2010
1
R01: Sugatt, Richard (US EPA REGION 1)
R01: Dilorenzo, James (US EPA REGION 1)
EML/Email
054-REMOVAL/0541-Removal
Responses/02.01-
CORRESPONDENCE (REMOVAL
RESPONSE)
UCTL( Uncontrolled)
1
httDs://semspub.epa,gov/src/document/01/7QQQ1543
484711
[REDACTED] EMAIL REGARDING JEFF AVAILABILITY OF
PRIVATE WELL SAMPLING
10/25/2010
2
R01: Dilorenzo, James (US EPA REGION 1)
R01: Ford, Heather M (NOBIS ENGINEERING
INC)
EML/Email
054-REMOVAL/0541-Removal
Responses/02.01-
CORRESPONDENCE (REMOVAL
RESPONSE)
UCTL( Uncontrolled)
1
htt Ds://semsou b.epa.gov/src/docu ment/Ql/484711
484700
[REDACTED] EMAIL REGARDING OLIN WELL WATER
SAMPLING SCHEDULE
10/22/2010
2
R01: Morrow, Steven G (OLIN CHEMICAL CORP)
R01: Dilorenzo, James (US EPA REGION 1)
EML/Email
054-REMOVAL/0541-Removal
Responses/02.01-
CORRESPONDENCE (REMOVAL
RESPONSE)
UCTL( Uncontrolled)
1
htt Ds://semsoub.epa.gov/src/document/Ql/4847QQ
485009
[REDACTED] SUMMARY OFALLAVAILABLE DATA FOR
PRIVATE WELL M-24/L-94 - DETECTED PARAMETERS
ONLY (SUPPORTING DOCUMENTATION ATTACHED)
10/22/2010
21
ADD/Analytical Data
Document
054-REMOVAL/0541-Removal
Responses/02.03-SAMPLING &
ANALYSIS DATA (REMOVAL
RESPONSE)
UCTL( Uncontrolled)
1
htt Ds://semsoub.epa.gov/src/document/Ql/485QQ9
485526
[REDACTED] LETTER REGARDING DETECTION OF NDMA
IN PRIVATE WELLSAND DISCONTINUATION OF THEIR
USE AS SOURCE OF DRINKING WATER (ENVELOPE
ATTACHED)
10/22/2010
2
R01: Caira, Michael (WILMINGTON (MA) TOWN
OF)
R01: Dilorenzo, James (US EPA REGION 1)
LTR/Letter
054-REMOVAL/0541-Removal
Responses/02.01-
CORRESPONDENCE (REMOVAL
RESPONSE)
UCTL( Uncontrolled)
1
htt Ds://semsoub.epa.gov/src/document/Ql/485526
484710
[REDACTED] EMAIL TRANSMITTING PRIVATE WELL
FACTORS
10/21/2010
1
R01: Dilorenzo, James (US EPA REGION 1)
R01: Ford, Heather M (NOBIS ENGINEERING
INC)
EML/Email
054-REMOVAL/0541-Removal
Responses/02.01-
CORRESPONDENCE (REMOVAL
RESPONSE)
UCTL( Uncontrolled)
1
httos://semspub.epa,gov/src/document/01/48471Q
484705
[REDACTED] EMAIL REGARDING LETTER TO RESIDENT
TRANSMITTING SUGGESTED REVISIONS
10/19/2010
2
R01: Sugatt, Richard (US EPA REGION 1)
R01: Dilorenzo, James (US EPA REGION 1)
EML/Email
054-REMOVAL/0541-Removal
Responses/02.01-
CORRESPONDENCE (REMOVAL
RESPONSE)
UCTL( Uncontrolled)
1
htt Ds://semsoub.epa.gov/src/document/Ql/4847Q5
485015
[REDACTED] LETTER PROVIDING EXPLANATION OF
GROUNDWATER RESULTS FOR RESIDENTIAL WELL
10/19/2010
2
R01: Dilorenzo, James (US EPA REGION 1)
R01: (WILMINGTON (MA) - RESIDENT OF)
LTR/Letter
054-REMOVAL/0541-Removal
Responses/02.01-
CORRESPONDENCE (REMOVAL
RESPONSE)
UCTL( Uncontrolled)
1
httos://semspub.epa,gov/src/document/0i/485015
485542
[REDACTED] LETTER PROVIDING FURTHER
EXPLANATION OF GROUNDWATER RESULTS FOR
RESIDENTIALWELL
10/19/2010
2
R01: Dilorenzo, James (US EPA REGION 1)
R01: (WILMINGTON (MA) - RESIDENT OF)
LTR/Letter
054-REMOVAL/0541-Removal
Responses/02.01-
CORRESPONDENCE (REMOVAL
RESPONSE)
UCTL( Uncontrolled)
1
htt Ds://semsoub.epa.gov/src/document/Ql/485542
483599
[REDACTED] EMAIL TRANSMITTING WELL ANALYTICAL
RESULTS
10/18/2010
2
R01: Morrow, Steven G (OLIN CHEMICAL CORP)
R01: Dilorenzo, James (US EPA REGION 1)
EML/Email
054-REMOVAL/0541-Removal
Responses/02.01-
CORRESPONDENCE (REMOVAL
RESPONSE)
UCTL( Uncontrolled)
1
htt Ds://semsoub.epa.gov/src/document/Ql/483599
-------
484704
[REDACTED] EMAIL REGARDING APPOINTMENT FOR
OLIN SAMPLING (EMAIL HISTORY ATTACH ED)
10/18/2010
3
R01: Newhouse, Shelly (METCALF & EDDY)
R01: Webster, Michael J (GEOINSIGHT INC),
R01: Woods, Michael (WILMINGTON (MA)
WATER & SEWER DIVISION), R01: (TOWN OF
WILMINGTON)
EML/Email
054-REMOVAL/0541-Removal
Responses/02.01-
CORRESPONDENCE (REMOVAL
RESPONSE)
UCTL( Uncontrolled)
1
httDs://semspub.epa.gov/src/document/Ql/4847Q4
70001569
ANALYTICAL REPORT, SDG NO. 360-30382-1
10/18/2010
302
R01: Mason, Becky C (TEST AMERICA), R01:
Wickham, James T(TESTAMERICA)
R01: (OLIN CORP)
RPT/ Report
054-REMOVAL/0541-Removal
Responses/02.03-SAMPLING &
ANALYSIS DATA (REMOVAL
RESPONSE)
UCTL( Uncontrolled)
1
httDs://semspub.epa,gov/src/document/Ql/7GGQ1569
485031
[REDACTED] LEI ILR 1RANSMITTING RESULTS OF
RESIDENTIAL WELL SAMPLING CONDUCTED IN MARCH
AND JULY 2010 (10/15/2010 LETTER AND 07/08/2008
DATA VALIDATION SUMMARYTESTAMERICA DATA
SETS 360-27496-1 AND 360-27496-2 ATTACH ED)
[MARGINALIA]
10/15/2010
84
R01: Morrow, Steve (OLIN CORP)
R01: (WILMINGTON (MA) - RESIDENT OF)
LTR/Letter
054-REMOVAL/0541-Removal
Responses/02.01-
CORRESPONDENCE (REMOVAL
RESPONSE)
UCTL( Uncontrolled)
1
httos://semspub.epa,gov/src/document/Gl/485G31
484702
[REDACTED] EMAIL REGARDING PRIVATE WELLS
10/7/2010
2
R01: Sugatt, Richard (US EPA REGION 1)
R01: Dilorenzo, James (US EPA REGION 1)
EML/Email
054-REMOVAL/0541-Removal
Responses/02.01-
CORRESPONDENCE (REMOVAL
RESPONSE)
UCTL( Uncontrolled)
1
httDs://semspub.epa.gov/src/document/Gl/4847G2
484703
[REDACTED] EMAIL REGARDING COMMENTS ON DATA
PACKAGE OF PRIVATE WELL
10/7/2010
5
R01: Ford, Heather M (NOBIS ENGINEERING
INC)
R01: Dilorenzo, James (US EPA REGION 1)
EML/Email
054-REMOVAL/0541-Removal
Responses/02.03-SAMPLING &
ANALYSIS DATA (REMOVAL
RESPONSE)
UCTL( Uncontrolled)
1
httDs://semspub.epa.gov/src/document/Gl/4847G3
483596
[REDACTED] EMAIL TRANSMITTING RISK CALCULATION
SPREADSHEETS REGARDING WELL
10/5/2010
2
R01: Morrow, Steven G (OLIN CHEMICAL CORP)
R01: Dilorenzo, James (US EPA REGION 1)
EML/Email
054-REMOVAL/0541-Removal
Responses/02.01-
CORRESPONDENCE (REMOVAL
RESPONSE)
UCTL( Uncontrolled)
1
httos://semspub. epa.gov/src/document/Gl/48359S
483597
[REDACTED] EMAIL TRANSMITTING DATA VALIDATION
PACKAGE
10/5/2010
1
R01: Morrow, Steven G (OLIN CHEMICAL CORP)
R01: Dilorenzo, James (US EPA REGION 1)
EML/Email
054-REMOVAL/0541-Removal
Responses/02.01-
CORRESPONDENCE (REMOVAL
RESPONSE)
UCTL( Uncontrolled)
1
httDs://semspub.epa.gov/src/document/Gl/483597
483598
[REDACTED] EMAILTRANSMITTING JULY AND AUGUST
2010 RESIDENTIALWELLDATA VALIDATION REPORT
10/5/2010
1
R01: Morrow, Steven G (OLIN CHEMICAL CORP)
R01: Dilorenzo, James (US EPA REGION 1)
EML/Email
054-REMOVAL/0541-Removal
Responses/02.01-
CORRESPONDENCE (REMOVAL
RESPONSE)
UCTL( Uncontrolled)
1
htt Ds://semsou b.epa.gov/src/docu ment/01/483598
484709
[REDACTED] EMAIL REGARDING PRIVATE WELLS
10/5/2010
1
R01: Dilorenzo, James (US EPA REGION 1)
R01: Sugatt, Richard (US EPA REGION 1), R01:
Ford, Heather M (NOBIS ENGINEERING INC)
EML/Email
054-REMOVAL/0541-Removal
Responses/02.01-
CORRESPONDENCE (REMOVAL
RESPONSE)
UCTL( Uncontrolled)
1
httDs://semspub.epa.gov/src/document/Ql/4847Q9
70001531
EMAILTRANSMITTING DATA VALIDATION PACKAGE
10/5/2010
1
R01: Morrow, Steven G (OLIN CHEMICAL CORP)
R01: Dilorenzo, James (US EPA REGION 1)
EML/Email
054-REMOVAL/0541-Removal
Responses/02.01-
CORRESPONDENCE (REMOVAL
RESPONSE)
UCTL( Uncontrolled)
1
httDs://semspub.epa.gov/src/document/Ql/7QQQ1531
483595
[REDACTED] EMAIL REGARDING EVALUATION OF WELL
RESULTS (EMAIL HISTORY ATTACHED)
10/4/2010
3
R01: Morrow, Steven G (OLIN CHEMICAL CORP)
R01: Dilorenzo, James (US EPA REGION 1)
EML/Email
054-REMOVAL/0541-Removal
Responses/02.03-SAMPLING &
ANALYSIS DATA (REMOVAL
RESPONSE)
UCTL( Uncontrolled)
1
httDs://semspub.epa.gov/src/document/Ql/483595
484734
[REDACTED] EMAIL REGARDING DRAFT LETTER
10/4/2010
1
R01: Morrow, Steven G (OLIN CHEMICAL CORP)
R01: Dilorenzo, James (US EPA REGION 1)
EML/Email
054-REMOVAL/0541-Removal
Responses/02.01-
CORRESPONDENCE (REMOVAL
RESPONSE)
UCTL( Uncontrolled)
1
httDs://semspub.epa.gov/src/document/Ql/484734
485008
[REDACTED] CALCULATIONS OF EXCESS LIFETIME
CANCER RISKS BASED ON CHILDHOOD AND ADULT
EXPOSURE FOR AVERAGE AND MOST RECENT
GROUNDWATER CONCENTRATION
10/1/2010
4
ADD/Analytical Data
Document
054-REMOVAL/0541-Removal
Responses/02.03-SAMPLING &
ANALYSIS DATA (REMOVAL
RESPONSE)
UCTL( Uncontrolled)
1
httDs://semspub.epa.gov/src/document/Ql/485QQ8
485098
[REDACTED] TABLES 1THROUGH 4: CALCULATION OF
EXCESS LIFE CANCER RISK BASED ON CHILDHOOD AND
ADULT EXPOSURE BASED ON MOST RECENT
GROUNDWATER CONCENTRATION
10/1/2010
4
ADD/Analytical Data
Document
054-REMOVAL/0541-Removal
Responses/02.03-SAMPLING &
ANALYSIS DATA (REMOVAL
RESPONSE)
UCTL( Uncontrolled)
1
httDs://semspub.epa.gov/src/document/Ql/485Q98
70001548
RESIDENTIAL DRINKING WATER INGESTION CANCER
RISK
10/1/2010
1
ADD/Analytical Data
Document
054-REMOVAL/0541-Removal
Responses/02.03-SAMPLING &
ANALYSIS DATA (REMOVAL
RESPONSE)
UCTL( Uncontrolled)
1
httos://semspub.epa,gov/src/document/Gl/7GGG1548
485013
{REDACTED] DATA VALIDATION SUMMARY, TEST
AMERICA DATA SETS 360-29118 AND 360-29259
9/30/2010
17
R01: Ricardi, Chris (MACTEC ENGINEERINGAND
CONSULTING INC), R01: Murphy, Michael
(MACTEC ENGINEERING AND CONSULTING INC)
R01: Morrow, Steve (OLIN CORP)
ADD/Analytical Data
Document
054-REMOVAL/0541-Removal
Responses/02.03-SAMPLING &
ANALYSIS DATA (REMOVAL
RESPONSE)
UCTL( Uncontrolled)
1
httos://semspub.epa,gov/src/document/01/485013
485007
[REDACTED] LETTER CONCERNING RESULTS OF
RESIDENTIAL WELL SAMPLING PERFORMED IN MARCH
AND JULY 2010 (SUPPORTING DOCUMENTATION
ATTACHED)
9/23/2010
4
R01: Morrow, Steve (OLIN CORP)
R01: (WILMINGTON (MA) - RESIDENT OF)
LTR/Letter
054-REMOVAL/0541-Removal
Responses/02.01-
CORRESPONDENCE (REMOVAL
RESPONSE)
UCTL( Uncontrolled)
1
httDs://semspub.epa.gov/src/document/Ql/485QQ7
485636
[REDACTED] RESIDENTIAL WELL SAMPLING PROGRAM
(VALIDATION SUMMARY ANDANALYTICAL DATA
ATTACHED)
9/23/2010
4
R01: Morrow, Stephen (OLIN CORP)
R01: (WILMINGTON (MA) - RESIDENT OF)
ADD/Analytical Data
Document
054-REMOVAL/0541-Removal
Responses/02.03-SAMPLING &
ANALYSIS DATA (REMOVAL
RESPONSE)
UCTL( Uncontrolled)
1
httDs://semspub.epa.gov/src/document/Ql/485S3S
-------
485637
[REDACTED] EMAIL REGARDING OLIN-REVIEW OF
PRIVATE WELL DATA [MARGINALIA]
9/23/2010
1
R01: Sugatt, Richard (US EPA REGION 1)
R01: Dilorenzo,Jim(US EPA)
CORR / Correspondence
054-REMOVAL/0541-Removal
Responses/02.01-
CORRESPONDENCE (REMOVAL
RESPONSE)
UCTL( Uncontrolled)
1
htt os://semspub.epa.gov/srt/document/01/485637
485638
[REDACTED] EMAIL REGARDING SCANNED EPA FILES
FOR WHITNEY BARREL (EMAIL HISTORY AND SAMPLING
RESULTSATTACHED) [MARGINALIA]
9/23/2010
12
R01: Dilorenzo,Jim(US EPA)
CORR / Correspondence
054-REMOVAL/0541-Removal
Responses/02.01-
CORRESPONDENCE (REMOVAL
RESPONSE)
UCTL( Uncontrolled)
1
htt Ds://semsoub.epa.gov/srt/document/Ql/485638
485648
[REDACTED] UPDATE ON PRIVATE WELL SAMPLING
EFFORT
9/23/2010
7
R01: Dilorenzo, James (US EPA REGION 1)
ADD/Analytical Data
Document
054-REMOVAL/0541-Removal
Responses/02.03-SAMPLING &
ANALYSIS DATA (REMOVAL
RESPONSE)
UCTL( Uncontrolled)
1
htt Ds://semsoub.epa.gov/srt/document/Ql/485648
484708
[REDACTED] EMAIL REGARDING OLIN RESIDENTIAL
WELLS SUMMARY
9/16/2010
4
R01: Dilorenzo, James (US EPA REGION 1)
R01: Cosio, Julie (MA DEPT OF PUBLIC HEALTH)
EML/Email
054-REMOVAL/0541-Removal
Responses/02.01-
CORRESPONDENCE (REMOVAL
RESPONSE)
UCTL( Uncontrolled)
1
htt Ds://semspub.epa.gov/srt/document/01/4847Q8
484707
[REDACTED] EMAIL REGARDING SAMPLING OF AREA
RESIDENTIAL WELLS AT SITE (EMAIL HISTORY
ATTACHED)
9/3/2010
3
R01: Dilorenzo, James (US EPA REGION 1)
R01: Trifilo, Joel J (GEOINSIGHT INC)
EML/Email
054-REMOVAL/0541-Removal
Responses/02.01-
CORRESPONDENCE (REMOVAL
RESPONSE)
UCTL( Uncontrolled)
1
htt Ds://semsoub.epa.gov/srt/document/Ql/4847Q7
526084
GROUNDWATER USE AND VALUE DETERMINATION
(09/21/2010 COVER LETTERATTACHED)
9/1/2010
6
R01: (MA DEPARTMENT OF ENVIRONMENTAL
PROTECTION - COMMISSIONER)
EML/Email
053-REMEDIAL/0531-Remedy
Characterization/03.01-
CORRESPONDENCE (Rl)
UCTL( Uncontrolled)
1
htt Ds://semsoub.epa.gov/srt/document/Ql/526Q84
70001527
EMAILTRANSMITING PRIVATE WELLS SAMPLES
8/30/2010
1
R01: Morrow, Steven G (OLIN CHEMICAL CORP)
R01: Dilorenzo, James (US EPA REGION 1)
EML/Email
054-REMOVAL/0541-Removal
Responses/02.01-
CORRESPONDENCE (REMOVAL
RESPONSE)
UCTL( Uncontrolled)
1
httos://semspub.epa,gov/srt/document/01/700Q1527
484716
[REDACTED] EMAIL TRANSMITTING SUMMARY DATA
TABLE REGARDING RESIDENTIAL WELL SAMPLING
8/20/2010
1
R01: Ford, Heather M (NOBIS ENGINEERING
INC)
R01: Dilorenzo, James (US EPA REGION 1)
EML/Email
054-REMOVAL/0541-Removal
Responses/02.01-
CORRESPONDENCE (REMOVAL
RESPONSE)
UCTL( Uncontrolled)
1
httDs://semspub.epa,gov/srt/document/Ql/484716
484737
[REDACTED] EMAIL SUMMARIZING PRIVATE WELL
SAMPLING EFFORT
8/20/2010
2
R01: Dilorenzo, James (US EPA REGION 1)
R01: Cosio, Julie (MA DEPT OF PUBLIC HEALTH)
EML/Email
054-REMOVAL/0541-Removal
Responses/02.01-
CORRESPONDENCE (REMOVAL
RESPONSE)
UCTL( Uncontrolled)
1
htt Ds://semsoub.epa.gov/srt/document/Ql/484737
70001576
EMAIL REQUESTING LOCATION AND DATA FOR
RESIDENTIALWELLS
8/18/2010
1
R01: Cosio, Julie (MA DEPT OF PUBLIC HEALTH)
R01: Dilorenzo, James (US EPA REGION 1)
EML/Email
054-REMOVAL/0541-Removal
Responses/02.01-
CORRESPONDENCE (REMOVAL
RESPONSE)
UCTL( Uncontrolled)
1
httos://semspub.epa,gov/srt/document/01/7000157S
70001575
EMAIL REGARDING RISK CALCULATION FOR
RESIDENTIAL DRINKING WATER SAMPLE WITH BEHP
DATA HIT
8/17/2010
3
R01: Ford, Heather M (NOBIS ENGINEERING
INC)
R01: Dilorenzo, James (US EPA REGION 1)
EML/Email
054-REMOVAL/0541-Removal
Responses/02.03-SAMPLING &
ANALYSIS DATA (REMOVAL
RESPONSE)
UCTL( Uncontrolled)
1
httos://semspub.epa,gov/srt/document/01/70001575
70001578
EMAILASKING CONCURRENCE OR POSITION
REGARDING RISK CALCULATION FOR RESIDENTIAL
DRINKING WATER SAMPLE WITH BEHP DATA
8/17/2010
2
R01: Dilorenzo, James (US EPA REGION 1)
R01: Sugatt, Richard (US EPA REGION 1)
EML/Email
054-REMOVAL/0541-Removal
Responses/02.01-
CORRESPONDENCE (REMOVAL
RESPONSE)
UCTL( Uncontrolled)
1
httos://semspub.epa,gov/srt/document/01/70001578
485645
[REDACTED] HYDRAZINE DETECTED AT RESIDENTIAL
WELL
8/10/2010
2
R01: Sugatt, Richard (US EPA REGION 1)
R01: Dilorenzo, James (US EPA REGION 1)
LTR/Letter
054-REMOVAL/0541-Removal
Responses/02.03-SAMPLING &
ANALYSIS DATA (REMOVAL
RESPONSE)
UCTL( Uncontrolled)
1
htt Ds://semspub.epa.gov/srt/document/01/485645
485646
[REDACTED] EMAIL REGARDING MARCH 2010 RISK
CALCULATION (WITH ATTACHMENTS)
8/10/2010
4
R01: Sugatt, Richard (US EPA REGION 1)
R01: Dilorenzo, James (US EPA REGION 1)
LTR/Letter
054-REMOVAL/0541-Removal
Responses/02.03-SAMPLING &
ANALYSIS DATA (REMOVAL
RESPONSE)
UCTL( Uncontrolled)
1
htt Ds://semsoub.epa.gov/srt/document/01/485646
485022
[REDACTED] LETTER TRANSMITTING RESULTS OF
RESIDENTIAL WELL SAMPLING CONDUCTED IN MARCH
2010(07/23/2010 LETTERAND07/08/2008 DATA
VALIDATION SUMMARY TEST AMERICA DATA SETS 360-
27496-1 AND 360-27496-2 ATTACHED) [MARGINALIA]
8/4/2010
58
R01: Morrow, Steve (OLIN CORP)
R01: (WILMINGTON (MA) - RESIDENT OF)
LTR/Letter
054-REMOVAL/0541-Removal
Responses/02.01-
CORRESPONDENCE (REMOVAL
RESPONSE)
UCTL( Uncontrolled)
1
htt Ds://semsoub.epa.gov/srt/document/Ql/485Q22
485023
[REDACTED] LETTER TRANSMITTING RESULTS OF
RESIDENTIAL WELL SAMPLING CONDUCTED IN MARCH
2010(07/23/2010 LETTERAND07/08/2008 DATA
VALIDATION SUMMARY, TEST AMERICA DATA SETS 360
27496-1 AND 360-27496-2 ATTACH ED)
8/4/2010
58
R01: Morrow, Steve (OLIN CORP)
R01: (WILMINGTON (MA) - RESIDENT OF)
LTR/Letter
054-REMOVAL/0541-Removal
Responses/02.01-
CORRESPONDENCE (REMOVAL
RESPONSE)
UCTL( Uncontrolled)
1
htt Ds://semsoub.epa.gov/srt/document/Ql/485Q23
485024
[REDACTED] LETTER TRANSMITTING RESULTS OF
RESIDENTIAL WELL SAMPLING CONDUCTED IN MARCH
2010(07/23/2010 LETTERAND07/08/2008 DATA
VALIDATION SUMMARY TEST AMERICA DATA SETS 360-
27496-1 AND 360-27496-2 ATTACHED) [MARGINALIA]
8/4/2010
58
R01: Morrow, Steve (OLIN CORP)
R01: (WILMINGTON (MA) - RESIDENT OF)
LTR/Letter
054-REMOVAL/0541-Removal
Responses/02.01-
CORRESPONDENCE (REMOVAL
RESPONSE)
UCTL( Uncontrolled)
1
htt Ds://semsoub.epa.gov/srt/document/Ql/485Q24
-------
485025
[REDACTED] LETTER TRANSMITTING RESULTS OF
RESIDENTIAL WELL SAMPLING CONDUCTED IN MARCH
2010(07/23/2010 LETTERAND07/08/2008 DATA
VALIDATION SUMMARY TEST AMERICA DATA SETS 360-
27496-1 AND 360-27496-2 ATTACHED) [MARGINALIA]
8/4/2010
58
R01: Morrow, Steve (OLIN CORP)
R01: (WILMINGTON (MA) - RESIDENT OF)
LTR/Letter
054-REMOVAL/0541-Removal
Responses/02.01-
CORRESPONDENCE (REMOVAL
RESPONSE)
UCTLJUn
ontrolled)
1
htt Ds://semsoub.epa.gov/src/document/Ql/485Q25
485026
[REDACTED] LETTER TRANSMITTING RESULTS OF
RESIDENTIAL WELL SAMPLING CONDUCTED IN MARCH
2010(07/23/2010 LETTERAND07/08/2008 DATA
VALIDATION SUMMARY TEST AMERICA DATA SETS 360-
27496-1 AND 360-27496-2 ATTACHED) [MARGINALIA]
8/4/2010
58
R01: Morrow, Steve (OLIN CORP)
R01: (WILMINGTON (MA) - RESIDENT OF)
LTR/Letter
054-REMOVAL/0541-Removal
Responses/02.01-
CORRESPONDENCE (REMOVAL
RESPONSE)
UCTLJUn
ontrolled)
1
htt Ds://semsoub.epa.gov/src/document/Gl/485Q26
485027
[REDACTED] LETTER TRANSMITTING RESULTS OF
RESIDENTIAL WELL SAMPLING CONDUCTED IN MARCH
2010(07/23/2010 LETTERAND07/08/2008 DATA
VALIDATION SUMMARY TEST AMERICA DATA SETS 360-
27496-1 AND 360-27496-2 ATTACHED) [MARGINALIA]
8/4/2010
58
R01: Morrow, Steve (OLIN CORP)
R01: (WILMINGTON (MA) - RESIDENT OF)
LTR/Letter
054-REMOVAL/0541-Removal
Responses/02.01-
CORRESPONDENCE (REMOVAL
RESPONSE)
UCTLJUn
ontrolled)
1
htt Ds://semsoub.epa.gov/src/document/Ql/485Q27
485028
[REDACTED] LETTER TRANSMITTING RESULTS OF
RESIDENTIAL WELL SAMPLING CONDUCTED IN MARCH
2010(07/23/2010 LETTERAND07/08/2008 DATA
VALIDATION SUMMARY TEST AMERICA DATA SETS 360-
27496-1 AND 360-27496-2 ATTACHED) [MARGINALIA]
8/3/2010
46
R01: Morrow, Steve (OLIN CORP)
R01: (WILMINGTON (MA) - RESIDENT OF)
LTR/Letter
054-REMOVAL/0541-Removal
Responses/02.01-
CORRESPONDENCE (REMOVAL
RESPONSE)
UCTLJUn
ontrolled)
1
htt Ds://semsoub.epa.gov/src/document/Ql/485Q28
484780
TABLE 3: CALCULATION OF EXCESS LIFE CANCER RISK
BASED ON CHILDHOOD AND ADULT EXPOSURE BASED
ON MOST RECENT GROUNDWATER CONCENTRATION
8/1/2010
5
ADD/Analytical Data
Document
054-REMOVAL/0541-Removal
Responses/02.03-SAMPLING &
ANALYSIS DATA (REMOVAL
RESPONSE)
UCTLJUn
ontrolled)
1
htt Ds://semsou b.epa.gov/src/docu ment/01/484780
485097
[REDACTED] TABLE 4: CALCULATION OF EXCESS LIFE
CANCER RISK BASED ON CHILDHOOD AND ADULT
EXPOSURE BASED ON MOST RECENT GROUNDWATER
CONCENTRATION
8/1/2010
1
ADD/Analytical Data
Document
054-REMOVAL/0541-Removal
Responses/02.03-SAMPLING &
ANALYSIS DATA (REMOVAL
RESPONSE)
UCTLJUn
ontrolled)
1
httBs://semspub.epa.gov/src/document/Ql/485Q97
485010
[REDACTED] DATA VALIDATION SUMMARY, TEST
AMERICA DATA SETS360-27496-1AND 360-27496-2
(09/30/2010 DATA VALIDATION SUMMARY, TEST
AMERICA DATA SET 360-29439 ATTACHED)
[MARGINALIA]
7/8/2010
80
R01: Smith, Deborah L (KESTREL
ENVIRONMENTALTECHNOLOGIES INC)
R01: Ricardi, Christian (MACTEC ENGINEERING
AND CONSULTING INC), R01: Thompson, Peter
(MACTEC ENGINEERING AND CONSULTING INC)
ADD/Analytical Data
Document
054-REMOVAL/0541-Removal
Responses/02.03-SAMPLING &
ANALYSIS DATA (REMOVAL
RESPONSE)
UCTLJUn
ontrolled)
1
httos://semspub.epa,gov/src/document/01/485010
650488
SEMI-ANNUAL STATUS REPORT NO. 6
7/2/2010
1125
R01:(MACTEC ENGINEERING AND
CONSULTING INC), R01: OLIN CORP)
R01: (US EPA REGION 1)
RPT/ Report
053-REMEDIAL/0531-Remedy
Characterization/03.07-WORK
PLANS & PROGRESS REPORTS (Rl)
UCTLJUn
ontrolled)
1
htt Bs://semspub.epa.gov/src/document/01/65Q488
485019
[REDACTED] MARCH 2010 SAMPLING (SUPPORTING
DOCUMENTATION ATTACHED) [MARGINALIA]
5/25/2010
4
ADD/Analytical Data
Document
054-REMOVAL/0541-Removal
Responses/02.03-SAMPLING &
ANALYSIS DATA (REMOVAL
RESPONSE)
UCTLJUn
ontrolled)
1
httos://semspub.epa,gov/src/document/01/485Q19
485500
[REDACTED] SPREADSHEET WITH MARCH 2010
SAMPLING, RESIDENTIAL DRINKING WATER INGESTION
CANCER RISKOF 24 NG/L OF N-
NITROSODIPROPYLAMINE, ASSUMING MUTAGENIC
MODE OF CARCINOGENESIS
3/1/2010
4
ADD/Analytical Data
Document
054-REMOVAL/0541-Removal
Responses/02.03-SAMPLING &
ANALYSIS DATA (REMOVAL
RESPONSE)
UCTLJUn
ontrolled)
1
htt Ds://semsoub.epa.gov/src/document/Ql/4855QQ
485551
[REDACTED] ANALYTICAL RESULTS FOR PRIVATE WELLS
OCTOBER 2008 - MARCH 2010
3/1/2010
8
ADD/Analytical Data
Document
054-REMOVAL/0541-Removal
Responses/02.03-SAMPLING &
ANALYSIS DATA (REMOVAL
RESPONSE)
UCTLJUn
ontrolled)
1
httos://semspub.epa,gov/src/document/01/485551
485565
[REDACTED] ANALYTICAL RESULTS FOR PRIVATE WELLS
OCTOBER 2008 - MARCH 2010
3/1/2010
2
ADD/Analytical Data
Document
054-REMOVAL/0541-Removal
Responses/02.03-SAMPLING &
ANALYSIS DATA (REMOVAL
RESPONSE)
UCTLJUn
ontrolled)
1
htt Ds://semsoub.epa.gov/src/document/Ql/4855S5
70001616
EMAIL TRANSMITTING OLIN DRINKING WATER WELL
DATA TABLE (EMAIL HISTORY ATTACHED)
3/1/2010
2
R01: Ford, Heather M (NOBIS ENGINEERING
INC)
R01: Dilorenzo, James (US EPA REGION 1)
EML/Email
054-REMOVAL/0541-Removal
Responses/02.01-
CORRESPONDENCE (REMOVAL
RESPONSE)
UCTLJUn
ontrolled)
1
htt Ds://semsou b.epa.gov/src/docu ment/Ql/7QQQ1616
484731
[REDACTED] EMAIL REGARDING WILMINGTON HOME
OWNER SAMPLING PROGRAM (EMAIL HISTORY
ATTACHED)
2/23/2010
3
R01: Ford, Heather M (NOBIS ENGINEERING
INC)
R01: Dilorenzo, James (US EPA REGION 1)
EML/Email
054-REMOVAL/0541-Removal
Responses/02.01-
CORRESPONDENCE (REMOVAL
RESPONSE)
UCTLJUn
ontrolled)
1
httos://semspub.epa,gov/src/document/01/484731
485545
[REDACTED] LETTER REGARDING ANALYSIS OF
GROUNDWATER FROM RESIDENTIAL WELL
2/18/2010
4
R01: Dilorenzo, James (US EPA REGION 1)
R01: (WILMINGTON (MA) - RESIDENT OF)
LTR/Letter
054-REMOVAL/0541-Removal
Responses/02.01-
CORRESPONDENCE (REMOVAL
RESPONSE)
UCTLJUn
ontrolled)
1
htt Ds://semsoub.epa.gov/src/document/Ql/485545
485548
[REDACTED] LETTER REGARDING ANALYSIS OF
GROUNDWATER FROM RESIDENTIAL WELL
2/18/2010
4
R01: Dilorenzo, James (US EPA REGION 1)
R01: (WILMINGTON (MA) - RESIDENT OF)
LTR/Letter
054-REMOVAL/0541-Removal
Responses/02.01-
CORRESPONDENCE (REMOVAL
RESPONSE)
UCTLJUn
ontrolled)
1
htt Ds://semsoub.epa.gov/src/document/Ql/485548
70001607
EMAIL TRANSMITTING OLIN RESIDENTIAL SAMPLING
SUMMARYTABLE
2/18/2010
2
R01: Ford, Heather M (NOBIS ENGINEERING
INC)
R01: Dilorenzo, James (US EPA REGION 1)
EML/Email
054-REMOVAL/0541-Removal
Responses/02.01-
CORRESPONDENCE (REMOVAL
RESPONSE)
UCTLJUn
ontrolled)
1
httos://semspub.epa,gov/src/document/01/7000iS07
-------
485035
[REDACTED] LEI IEK 1KANSMITTING RESULTS OF
RESIDENTIAL WELL SAMPLING CONDUCTED IN
NOVEMBER 2009 (02/08/2010 LETTERAND
12/22/2009 DATA VALIDATION SUMMARY TEST
AMERICA DATA SETS 360-25526-1 AND 360-25526-2
ATTACHED) [MARGINALIA]
2/10/2010
44
R01: Morrow, Steve (OLIN CORP)
R01: (WILMINGTON (MA) - RESIDENT OF)
LTR/Letter
054-REMOVAL/0541-Removal
Responses/02.01-
CORRESPONDENCE (REMOVAL
RESPONSE)
UCTL( Uncontrolled)
1
htt Ds://semsoub.epa.gov/src/document/Ql/485Q35
485037
[REDACTED] LEI ILR 1 KANSMITTING RESULTS OF
RESIDENTIAL WELL SAMPLING CONDUCTED IN
NOVEMBER 2009 (02/08/2010 LETTERAND
12/22/2009 DATA VALIDATION SUMMARY TEST
AMERICA DATA SETS 360-25526-1 AND 360-25526-2
ATTACHED) [MARGINALIA]
2/10/2010
33
R01: Morrow, Steve (OLIN CORP)
R01: (WILMINGTON (MA) - RESIDENT OF)
LTR/Letter
054-REMOVAL/0541-Removal
Responses/02.01-
CORRESPONDENCE (REMOVAL
RESPONSE)
UCTL( Uncontrolled)
1
htt os://semspub.epa.gov/src/document/Gl/485G37
483561
PROPOSED DRINKING WATERANALYTES, REVISION 2
2/8/2010
1
ADD/Analytical Data
Document
054-REMOVAL/0541-Removal
Responses/02.03-SAMPLING &
ANALYSIS DATA (REMOVAL
RESPONSE)
UCTL( Uncontrolled)
1
httos://semspub.epa,gov/src/document/01/4835Sl
484730
[REDACTED] EMAIL TRANSMITTING SUPPORTING
SPREADSHEETS FOR DRINKING WATER WELL RISK
BASED ON NOVEMBER 2009 SAMPLING (EMAIL
HISTORY ATTACHED)
2/1/2010
2
R01: Woods, Cynthia (AVATAR
ENVIRONMENTAL)
R01: Sugatt, Richard (US EPA REGION 1)
EML/Email
054-REMOVAL/0541-Removal
Responses/02.01-
CORRESPONDENCE (REMOVAL
RESPONSE)
UCTL( Uncontrolled)
1
htt Ds://semsoub.epa.gov/src/document/Ql/48473Q
100016232
LETTER REGARDING APPROVAL OF CLOSURE OF
SPINAZOLA LANDFILL AKA MAPLE MEADOW LANDFILL
NEAR SITE PROPERTY
1/21/2010
6
R01: Lipman, Steven G (MA DEPTOF
ENVIRONMENTAL PROTECTION)
R01: Spinazola, Clarence (ESTATE OF CLARENCE
SPINAZOLA), R01: Toomey, Michael (BOSTON
ENVIRONMENTALANDTRUCKING), R01:
(RIEMER& BRAUNSTEIN LLP)
LTR/Letter
056-SITE SUPPORT/0563-
State/Tribal Involvement/09.10-
STATE TECHNICAL AND HISTORICAL
RECORDS
UCTL( Uncontrolled)
1
httDs://semspub.epa,gov/src/document/01/100016232
485039
[REDACTED] LETTER TRANSMITTING RESULTS OF
RESIDENTIAL WELL SAMPLING CONDUCTED IN
NOVEMBER 2009 (SUPPORTING DOCUMENTATION
ATTACHED) [MARGINALIA]
1/14/2010
34
R01: Morrow, Steve (OLIN CORP)
R01: (WILMINGTON (MA) - RESIDENT OF)
LTR/Letter
054-REMOVAL/0541-Removal
Responses/02.01-
CORRESPONDENCE (REMOVAL
RESPONSE)
UCTL( Uncontrolled)
1
htt Ds://semspub.epa.gov/srt/document/Ql/485Q39
485040
[RLUAULUJ LEI ILK IKANSMII IING KLSULISOF
RESIDENTIAL WELL SAMPLING CONDUCTED IN
NOVEMBER 2009 (SUPPORTING DOCUMENTATION
ATTACHED) [MARGINALIA]
1/14/2010
45
R01: Morrow, Steve (OLIN CORP)
R01: (WILMINGTON (MA) - RESIDENT OF)
LTR/Letter
054-REMOVAL/0541-Removal
Responses/02.01-
CORRESPONDENCE (REMOVAL
RESPONSE)
UCTL( Uncontrolled)
1
htt Ds://semsoub.epa.gov/src/document/Ql/485Q4Q
484715
[REDACTED] EMAIL TRANSMITTING OLIN RISK
ASSESSMENT OF PRIVATE WELLS (EMAIL HISTORY
ATTACHED)
1/12/2010
2
R01: Ford, Heather M (NOBIS ENGINEERING
INC)
R01: Dilorenzo, James (US EPA REGION 1)
EML/Email
054-REMOVAL/0541-Removal
Responses/02.01-
CORRESPONDENCE (REMOVAL
RESPONSE)
UCTL( Uncontrolled)
1
httDs://semspub.epa,gov/src/document/Ql/484715
484759
[REDACTED] PROPOSED DRINKING WATERANALYTES
1/1/2010
1
ADD/Analytical Data
Document
054-REMOVAL/0541-Removal
Responses/02.03-SAMPLING &
ANALYSIS DATA (REMOVAL
RESPONSE)
UCTL( Uncontrolled)
1
htt Ds://semsoub.epa.gov/src/document/Ql/484759
650492
SEMI-ANNUAL STATUS REPORT NO. 5
12/22/2009
1736
R01:(MACTEC ENGINEERING AND
CONSULTING INC), R01: OLIN CORP)
R01: (US EPA REGION 1)
RPT/ Report
053-REMEDIAL/0531-Remedy
Characterization/03.07-WORK
PLANS & PROGRESS REPORTS (Rl)
UCTL( Uncontrolled)
1
htt Ds://semsoub.epa.gov/src/document/Ql/S5Q492
484756
[REDACTED] TIER 2 DATA VALIDATION REPORT, SDG
NO. D00273
12/15/2009
68
R01: Quigley, Diane (WESTON SOLUTIONS INC),
R01: Deruzzo, Gail (NOBIS ENGINEERING INC)
R01: Clark, Christine (US EPA REGION 1)
ADD/Analytical Data
Document
054-REMOVAL/0541-Removal
Responses/02.03-SAMPLING &
ANALYSIS DATA (REMOVAL
RESPONSE)
UCTL( Uncontrolled)
1
htt Ds://semsoub.epa.gov/src/document/Ql/48475S
484752
[REDACTED] TOTAL RECOVERABLE METALS IN WATER
(CHAIN OF CUSTODY ATTACHED)
12/11/2009
10
R01: Boudreau, Daniel N (US EPA REGION 1)
R01: Dilorenzo, James (US EPA REGION 1)
ADD/Analytical Data
Document
054-REMOVAL/0541-Removal
Responses/02.03-SAMPLING &
ANALYSIS DATA (REMOVAL
RESPONSE)
UCTL( Uncontrolled)
1
htt Ds://semsoub.epa.gov/src/document/Ql/484752
484746
[REDACTED] SPLIT ANALYSIS AMMONIA (CHAIN OF
CUSTODY ATTACH ED)
11/17/2009
17
R01: (ALPHA ANALYTICAL LABORATORIES)
ADD/Analytical Data
Document
054-REMOVAL/0541-Removal
Responses/02.03-SAMPLING &
ANALYSIS DATA (REMOVAL
RESPONSE)
UCTL( Uncontrolled)
1
htt Ds://semsoub.epa.gov/src/document/Ql/48474S
484748
[REDACTED] SPLIT ANALYSIS BNAS IN WATER (CHAIN
OF CUSTODY ATTACHED)
11/17/2009
19
R01: Boudreau, Daniel N (US EPA REGION 1)
R01: Dilorenzo, James (US EPA REGION 1)
ADD/Analytical Data
Document
054-REMOVAL/0541-Removal
Responses/02.03-SAMPLING &
ANALYSIS DATA (REMOVAL
RESPONSE)
UCTL( Uncontrolled)
1
htt Ds://semsoub.epa.gov/src/document/Ql/484748
484754
[REDACTED] SPLITANALYSIS VOAS IN DRINKING WATER
(CHAIN OF CUSTODY ATTACHED)
11/13/2009
21
R01: Boudreau, Daniel N (US EPA REGION 1)
R01: Dilorenzo, James (US EPA REGION 1)
ADD/Analytical Data
Document
054-REMOVAL/0541-Removal
Responses/02.03-SAMPLING &
ANALYSIS DATA (REMOVAL
RESPONSE)
UCTL( Uncontrolled)
1
htt Ds://semsoub.epa.gov/src/document/Ql/484754
650437
LETTER TRANSMITTING FINAL REMEDIAL
INVESTIGATION / FEASBILITY STUDY (RI/FS) WORK
PLAN
11/12/2009
2
R01: Finkelstein, Kenneth (US NATIONAL
OCEANIC AND ATMOSPHERIC
ADMINISTRATION)
R01: Dilorenzo, James (US EPA REGION 1)
LTR/Letter
053-REMEDIAL/0531-Remedy
Characterizat ion/16.01-
CORRESPONDENCE(NATURAL
RESOURCE TRUSTEE)
UCTL( Uncontrolled)
1
htt Ds://semsoub.epa.gov/src/document/Ql/S5Q437
650438
LETTER TRANSMITTING FINAL REMEDIAL
INVESTIGATION / FEASBILITY STUDY (RI/FS) WORK
PLAN
11/12/2009
2
R01: Raddant, Andrew (US DEPT OF INTERIOR)
R01: Dilorenzo, James (US EPA REGION 1)
LTR/Letter
053-REMEDIAL/0531-Remedy
Characterizat ion/16.01-
CORRESPONDENCE(NATURAL
RESOURCE TRUSTEE)
UCTL( Uncontrolled)
1
htt Ds://semsoub.epa.gov/src/document/Ql/S5Q438
650439
LETTER TRANSMITTING FINAL REMEDIAL
INVESTIGATION / FEASBILITY STUDY (RI/FS) WORK
PLAN
11/12/2009
2
R01: Bowles, Ian (MA EXECUTIVE OFFICE OF
ENERGY AND ENVIRONMENTALAFFAIRS)
R01: Dilorenzo, James (US EPA REGION 1)
LTR/Letter
053-REMEDIAL/0531-Remedy
Characterizat ion/16.01-
CORRESPONDENCE(NATURAL
RESOURCE TRUSTEE)
UCTL( Uncontrolled)
1
htt Ds://semsoub.epa.gov/src/document/Ql/S5Q439
-------
653702
REVISIONS TO SECTION 307 - TEXAS SURFACE WATER
QUALITY STANDARDS
11/12/2009
144
R01: (TX NATURAL RESOURCE CONSERVATION
COMMISSION)
LAWS/
Laws/Regu lat ions/Gu ida nc
056-SITE SUPPORT/0561-
Administrative Support/17.07-
REFERENCE DOCUMENTS
UCTL( Uncontrolled)
1
httDs://semspub.epa.gov/src/document/Ql/6537Q2
485625
[REDACTED] EPA SPLITS SPECIALTYCHEMS DAS0043S-
403099 VALIDATED
11/10/2009
2
ADD/Analytical Data
Document
054-REMOVAL/0541-Removal
Responses/02.03-SAMPLING &
ANALYSIS DATA (REMOVAL
RESPONSE)
UCTL( Uncontrolled)
1
httDs://semspub.epa.gov/src/document/Ql/485625
484729
[REDACTED] EMAIL REGARDING OLIN DRIKING WATER
SAMPLING SCHEDULE (EMAIL HISTORY ATTACHED)
11/9/2009
2
R01: Morrow, Steven G (OLIN CHEMICAL CORP)
R01: Dilorenzo, James (US EPA REGION 1)
EML/Email
054-REMOVAL/0541-Removal
Responses/02.01-
CORRESPONDENCE (REMOVAL
RESPONSE)
UCTL( Uncontrolled)
1
httDs://semspub.epa.gov/src/document/Ql/484729
484786
SAMPLE RECEIPT MEMORANDUM
11/9/2009
1
R01: Boudreau, Dan (US EPA REGION 1)
R01: Dilorenzo, James (US EPA REGION 1)
MEMO/Memorandum
054-REMOVAL/0541-Removal
Responses/02.01-
CORRESPONDENCE (REMOVAL
RESPONSE)
UCTL( Uncontrolled)
1
httDs://semspub.epa.gov/src/document/Ql/484786
484785
PROPOSED DRINKING WATER ANALYTES ROUND 3,
REVISED 11/02/2009
11/3/2009
2
ADD/Analytical Data
Document
054-REMOVAL/0541-Removal
Responses/02.03-SAMPLING &
ANALYSIS DATA (REMOVAL
RESPONSE)
UCTL( Uncontrolled)
1
httDs://semspub.epa.gov/src/document/01/484785
70001604
EMAIL REGARDING WILMINGTON FINAL RESIDENTIAL
WELL PROGRAM TABLE
11/3/2009
2
R01: Morrow, Steven G (OLIN CHEMICAL CORP)
R01: Dilorenzo, James (US EPA REGION 1)
EML/Email
054-REMOVAL/0541-Removal
Responses/02.01-
CORRESPONDENCE (REMOVAL
RESPONSE)
UCTL( Uncontrolled)
1
httos://semspub.epa,gov/src/document/01/70001S04
484728
[REDACTED] EMAIL REGARDING OLIN DRINKING WATER
SAMPLING SCHEDULE
11/2/2009
2
R01: Morrow, Steven G (OLIN CHEMICAL CORP)
R01: Dilorenzo, James (US EPA REGION 1)
EML/Email
054-REMOVAL/0541-Removal
Responses/02.01-
CORRESPONDENCE (REMOVAL
RESPONSE)
UCTL( Uncontrolled)
1
httDs://semspub.epa.gov/src/document/01/484728
485553
[REDACTED] ANALYTICAL RESULTS FOR PRIVATE WELLS
OCTOBER 2008 - NOVEMBER 2009
11/1/2009
8
ADD/Analytical Data
Document
054-REMOVAL/0541-Removal
Responses/02.03-SAMPLING &
ANALYSIS DATA (REMOVAL
RESPONSE)
UCTL( Uncontrolled)
1
httDs://semspub.epa.gov/src/document/01/485553
485554
[REDACTED] ANALYTICAL RESULTS FOR PRIVATE WELLS
OCTOBER 2008 - NOVEMBER 2009
11/1/2009
8
ADD/Analytical Data
Document
054-REMOVAL/0541-Removal
Responses/02.03-SAMPLING &
ANALYSIS DATA (REMOVAL
RESPONSE)
UCTL( Uncontrolled)
1
httDs://semspub.epa.gov/src/document/01/485554
70001602
EMAIL REGARDING RESIDENTIAL WELL TABLE
10/22/2009
2
R01: Morrow, Steven G (OLIN CHEMICAL CORP)
R01: Dilorenzo, James (US EPA REGION 1)
EML/Email
054-REMOVAL/0541-Removal
Responses/02.01-
CORRESPONDENCE (REMOVAL
RESPONSE)
UCTL( Uncontrolled)
1
httos://semspub.epa,gov/src/document/01/70001S02
485541
[REDACTED] REQUESTTO SAMPLE RESIDENTIAL WELL
WATER
10/5/2009
1
R01: Dilorenzo, James (US EPA REGION 1)
R01: (WILMINGTON (MA) - RESIDENT OF)
LTR/Letter
054-REMOVAL/0541-Removal
Responses/02.01-
CORRESPONDENCE (REMOVAL
RESPONSE)
UCTL( Uncontrolled)
1
httos://semspub.epa,gov/src/document/01/485541
485544
[REDACTED] LETTER REGARDING ANALYSIS OF
GROUNDWATER FROM RESIDENTIAL WELL
(SUPPORTING DOCUMENTATION ATTACHED)
[MARGINALIA]
10/5/2009
36
R01: Dilorenzo, James (US EPA REGION 1)
R01: (WILMINGTON (MA) - RESIDENT OF)
LTR/Letter
054-REMOVAL/0541-Removal
Responses/02.01-
CORRESPONDENCE (REMOVAL
RESPONSE)
UCTL( Uncontrolled)
1
httDs://semspub.epa.gov/src/document/01/485544
485547
[REDACTED] LETTER REGARDING ANALYSIS OF
GROUNDWATER FROM RESIDENTIAL WELL
(SUPPORTING DOCUMENTATION ATTACHED)
[MARGINALIA]
10/5/2009
34
R01: Dilorenzo, James (US EPA REGION 1)
R01: (WILMINGTON (MA) - RESIDENT OF)
LTR/Letter
054-REMOVAL/0541-Removal
Responses/02.01-
CORRESPONDENCE (REMOVAL
RESPONSE)
UCTL( Uncontrolled)
1
httDs://semspub.epa.gov/src/document/01/485547
484727
[REDACTED] EMAIL REGARDING WILMINGTON HOME
OWNER WELL LETTERS
9/22/2009
1
R01: Morrow, Steven G (OLIN CHEMICAL CORP)
R01: Dilorenzo, James (US EPA REGION 1)
EML/Email
054-REMOVAL/0541-Removal
Responses/02.01-
CORRESPONDENCE (REMOVAL
RESPONSE)
UCTL( Uncontrolled)
1
httDs://semspub.epa.gov/src/document/Ql/484727
485033
[REDACTED] LETTER TRANSMITTING RESULTS OF
RESIDENTIAL WELL SAMPLING CONDUCTED IN MARCH
2009
9/22/2009
1
R01: Morrow, Steve (OLIN CORP)
R01: (WILMINGTON (MA) - RESIDENT OF)
LTR/Letter
054-REMOVAL/0541-Removal
Responses/02.01-
CORRESPONDENCE (REMOVAL
RESPONSE)
UCTL( Uncontrolled)
1
httDs://semspub.epa.gov/src/document/Ql/485Q33
485036
[REDACTED] LEI ILR 1RANSMITTING RESULTS OF
RESIDENTIAL WELL SAMPLING CONDUCTED IN MARCH
2009(09/21/2009 LETTERAND06/02/2009 DATA
VALIDATION SUMMARY TEST AMERICA DATA SET 360-
21622 ATTACHED) [MARGINALIA]
9/22/2009
16
R01: Morrow, Steve (OLIN CORP)
R01: (WILMINGTON (MA) - RESIDENT OF)
LTR/Letter
054-REMOVAL/0541-Removal
Responses/02.01-
CORRESPONDENCE (REMOVAL
RESPONSE)
UCTL( Uncontrolled)
1
httDs://semspub.epa.gov/src/document/Ql/485Q3S
485034
[RLDACILDJ LEI ILR IRANSMII IING RLSULISOF
RESIDENTIAL WELL SAMPLING CONDUCTED IN MARCH
2009 (06/02/2009 DATA VALIDATION SUMMARY TEST
AMERICA DATA SET 360-21622 ATTACHED)
[MARGINALIA]
9/21/2009
15
R01: Murphy, MichaelJ (MACTEC
ENGINEERING AND CONSULTING INC), R01:
Thompson, Peter(MACTEC ENGINEERING AND
CONSULTING INC)
R01: Morrow, Steve (OLIN CORP)
LTR/Letter
054-REMOVAL/0541-Removal
Responses/02.01-
CORRESPONDENCE (REMOVAL
RESPONSE)
UCTL( Uncontrolled)
1
httDs://semspub.epa.gov/src/document/Ql/485Q34
483523
FACT SHEET: EMERGING CONTAMINENT N-
NITROSODIMETHYLAMINE(NDMA)
9/1/2009
4
R01: (US EPA REGION 1)
PUB/Publication
051-COMMUNITY
INVOLVEMENT/0511-Community
Involvement Activities/13.05-FACT
SHEETS/INFORMATION UPDATES
UCTL( Uncontrolled)
1
httDs://semspub.epa.gov/src/document/Ql/483523
-------
640138
HISTORICALAERIAL PHOTOGRAPHICANALYSIS, LAND
USE/LAND COVER ANALYSIS, SITE DISCOVERY
INVENTORY ANALYSIS, WETLANDS/DRAINAGE
ANALYSIS, AND FRACTURE TRACE ANALYSIS, VOLUME 1
OF 2
9/1/2009
49
R01: (US EPA - ENVIRONMENTAL
PHOTOGRAPHIC INTERPRETATION CTR (EPIC))
PHT/ Photograph
056-SITE SUPPORT/0561-
Administrative Support/17.04-NON-
PRINT MATERIALS
UCTL( Uncontrolled)
1
httDs://semspub.epa,gov/src/document/Gl/64G138
640139
HISTORICALAERIAL PHOTOGRAPH ICANALYSIS, LAND
USE/LAND COVER ANALYSIS, SITE DISCOVERY
INVENTORY ANALYSIS, WETLANDS/DRAINAGE
ANALYSIS, AND FRACTURE TRACE ANALYSIS, VOLUME 2
OF 2
9/1/2009
49
R01: (US EPA - ENVIRONMENTAL
PHOTOGRAPHIC INTERPRETATION CTR (EPIC))
PHT/ Photograph
056-SITE SUPPORT/0561-
Administrative Support/17.04-NON-
PRINT MATERIALS
UCTL( Uncontrolled)
1
httos://semspub.epa,gov/src/document/01/64G139
485623
[REDACTED] RESPONSE TO OLIN REGARDING
EVALUATION OF FORMALDEHYDE DATA (CHRONOLOGY
OF FORMALDEHYDE ATTACHED)
8/27/2009
3
R01: Dilorenzo, James (US EPA REGION 1)
R01: Morrow, Steven G (OLIN CHEMICAL CORP)
LTR/Letter
054-REMOVAL/0541-Removal
Responses/02.01-
CORRESPONDENCE (REMOVAL
RESPONSE)
UCTL( Uncontrolled)
1
htt Ds://semsoub.epa.gov/src/document/01/485623
485639
[REDACTED] RESPONSE TO OLIN REGARDING
EVALUATION OF FORMALDEHYDE DATA (CHRONOLOGY
OF FORMALDEHYDE ATTACHED)
8/27/2009
3
R01: Dilorenzo, James (US EPA REGION 1)
R01: Morrow, Steven G (OLIN CHEMICAL CORP)
LTR/Letter
054-REMOVAL/0541-Removal
Responses/02.01-
CORRESPONDENCE (REMOVAL
RESPONSE)
UCTL( Uncontrolled)
1
httos://semspub. 8pa.gov/sir/document/01/485639
458068
FINAL REMEDIAL INVESTIGATION / FEASIBILITY STUDY
(RI/FS) WORK PLAN, VOLUME 1 OF 4, PROJECT
OVERVIEW (TRANSMITTAL, RESPONSE TO EPA
CONDITIONAL APPROVAL AND COMMENTS, AND
ADDENDUM 1 - NORTH POND INVESTIGATION
ATTACHED)
8/14/2009
180
R01: (OLIN CORP), R01: (MACTEC
ENGINEERING AND CONSULTING INC)
R01: (US EPA REGION 1)
WP/Work Plan
053-REMEDIAL/0531-Remedy
Characterization/03.06-REMEDIAL
INVESTIGATION REPORTS
UCTL( Uncontrolled)
1
htt Ds://semsoub.epa.gov/src/document/Gl/458G68
458069
FINAL REMEDIAL INVESTIGATION / FEASIBILITY STUDY
(RI/FS) WORK PLAN, VOLUME 2 OF 4, PROJECT
OPERATIONS PLAN, SITE MANAGEMENT PLAN AND
COMMUNITY RELATIONS SUPPORT PLAN
8/14/2009
51
R01: (OLIN CORP), R01: (MACTEC
ENGINEERING AND CONSULTING INC)
R01: (US EPA REGION 1)
WP/Work Plan
053-REMEDIAL/0531-Remedy
Characterization/03.06-REMEDIAL
INVESTIGATION REPORTS
UCTL( Uncontrolled)
1
htt Ds://semsoub.epa.gov/src/document/Gl/458G69
458070
FINAL REMEDIAL INVESTIGATION / FEASIBILITY STUDY
(RI/FS) WORK PLAN, VOLUME 3-A OF 4, PROJECT
OPERATIONS PLAN, FIELD SAMPLING PLAN
8/14/2009
449
R01: (OLIN CORP), R01: (MACTEC
ENGINEERING AND CONSULTING INC)
R01: (US EPA REGION 1)
WP/Work Plan
053-REMEDIAL/0531-Remedy
Characterization/03.06-REMEDIAL
INVESTIGATION REPORTS
UCTL( Uncontrolled)
1
htt Ds://semsou b.epa.gov/src/docu ment/01/458070
458071
FINAL REMEDIAL INVESTIGATION / FEASIBILITY STUDY
(RI/FS) WORK PLAN, VOLUME 3-B OF 4, PROJECT
OPERATIONS PLAN, QUALITY ASSURANCE PROJECT
PLAN (QAPP)
8/14/2009
2552
R01: (OLIN CORP), R01: (MACTEC
ENGINEERING AND CONSULTING INC)
R01: (US EPA REGION 1)
WP/Work Plan
053-REMEDIAL/0531-Remedy
Characterization/03.06-REMEDIAL
INVESTIGATION REPORTS
UCTL( Uncontrolled)
1
httos://semspub.epa,gov/src/document/01/4580?l
458072
FINAL REMEDIAL INVESTIGATION / FEASIBILITY STUDY
(RI/FS) WORK PLAN, VOLUME 4 OF 4, PROJECT
OPERATIONS PLAN, HEALTH AND SAFETY PLAN
8/14/2009
323
R01: (OLIN CORP), R01: (MACTEC
ENGINEERING AND CONSULTING INC)
R01: (US EPA REGION 1)
WP/Work Plan
053-REMEDIAL/0531-Remedy
Characterization/03.06-REMEDIAL
INVESTIGATION REPORTS
UCTL( Uncontrolled)
1
htt Ds://semsou b.epa.gov/src/docu ment/01/458072
485621
[REDACTED] EVALUATION OF FORMALDEHYDE DATA
7/29/2009
4
R01: Morrow, Steve (OLIN CORP)
R01: Dilorenzo, James (US EPA REGION 1)
LTR/Letter
054-REMOVAL/0541-Removal
Responses/02.03-SAMPLING &
ANALYSIS DATA (REMOVAL
RESPONSE)
UCTL( Uncontrolled)
1
httos://semspub.epa,gov/src/document/01/485621
485622
[REDACTED] RESPONSE TO MACTEC'S DATA
VALIDATION COMMENTS ON FORMALDEHYDE DATED
JUNE 24, 2009 (WITH ATTACHMENT)
7/10/2009
15
R01: Deruzzo, Gail (NOBIS ENGINEERING INC)
R01: Dilorenzo, James (US EPA REGION 1)
LTR/Letter
054-REMOVAL/0541-Removal
Responses/02.03-SAMPLING &
ANALYSIS DATA (REMOVAL
RESPONSE)
UCTL( Uncontrolled)
1
htt Ds://semspub.epa.gov/src/document/01/485622
650487
SEMI-ANNUAL STATUS REPORT NO. 4
6/29/2009
853
R01: (MACTEC ENGINEERING AND
CONSULTING INC), R01: OLIN CORP)
R01: (US EPA REGION 1)
RPT/ Report
053-REMEDIAL/0531-Remedy
Characterization/03.07-WORK
PLANS & PROGRESS REPORTS (Rl)
UCTL( Uncontrolled)
1
htt Ds://semsoub.epa.gov/src/document/Ql/65Q487
175202
MEMO REGARDING SUMMARY OF KEY EXISTING EPA
CERCLA POLICIES FOR GROUNDWATER RESTORATION
6/26/2009
12
CORR / Correspondence
058-PROGRAM SUPPORT/0583-
Regulatory Development/B8.1-
Regulations, Standards & Guidelines
UCTL( Uncontrolled)
11
htt Ds://semsoub.epa.gov/src/document/ll/1752Q2
483519
REVIEW OF NOBIS ENGINEERING DATA VALIDATION
REPORT AND METHOD 8315 FORMALDEHYDE DATA
REPORTED BY SOUTHWEST RESEARCH INSTITUTE
6/24/2009
4
R01: Ricardi, Christian (MACTEC ENGINEERING
AND CONSULTING INC), R01: Murphy, Michael
(MACTEC ENGINEERING AND CONSULTING
INC), R01:Thompson, Peter(MACTEC
ENGINEERING AND CONSULTING INC)
R01: Morrow, Steve (OLIN CORP)
LTR/Letter
054-REMOVAL/0541-Removal
Responses/02.03-SAMPLING &
ANALYSIS DATA (REMOVAL
RESPONSE)
UCTL( Uncontrolled)
1
httos://semspub.epa,gov/src/document/01/483519
483522
LETTER REGARDING DATA REVIEW OF FORMALDEHYDE
DATA FROM MARCH 2009 RESIDENTIAL SAMPLING
EVENT (SUPPORTING DOCUMENTATION ATTACHED)
[MARGINALIA]
6/22/2009
5
R01: Deruzzo, Gail (NOBIS ENGINEERING INC)
R01: Dilorenzo, James (US EPA REGION 1)
LTR/Letter
054-REMOVAL/0541-Removal
Responses/02.03-SAMPLING &
ANALYSIS DATA (REMOVAL
RESPONSE)
UCTL( Uncontrolled)
1
htt Ds://semsoub.epa.gov/src/document/01/483522
70001600
EMAIL REGARDING N-NITROSODIMETHYLAMINE
(NDMA)
6/18/2009
1
R01: Dilorenzo, James (US EPA REGION 1)
EML/Email
054-REMOVAL/0541-Removal
Responses/02.01-
CORRESPONDENCE (REMOVAL
RESPONSE)
UCTL( Uncontrolled)
1
httos://semspub.epa,gov/src/document/0i/70001600
484726
[REDACTED] EMAIL REGARDING WILMINGTON HOME
OWNER SAMPLING PROGRAM
6/10/2009
2
R01: Morrow, Steven G (OLIN CHEMICAL CORP)
R01: Dilorenzo, James (US EPA REGION 1)
EML/Email
054-REMOVAL/0541-Removal
Responses/02.01-
CORRESPONDENCE (REMOVAL
RESPONSE)
UCTL( Uncontrolled)
1
htt Ds://semsoub.epa.gov/src/document/01/484726
485518
[REDACTED] RESIDENTIAL WELL SAMPLING UPDATE
6/10/2009
2
R01: (NOBIS ENGINEERING INC)
LST/ List/Index
054-REMOVAL/0541-Removal
Responses/02.01-
CORRESPONDENCE (REMOVAL
RESPONSE)
UCTL( Uncontrolled)
1
httos://semspub.epa,gov/src/document/01/485518
-------
484725
[REDACTED] EMAIL REQUESTING COMPLETE
LABORATORY DATA PACKAGE
6/8/2009
3
R01: Morrow, Steven G(OLIN CHEMICAL CORP)
R01: Dilorenzo, James (US EPA REGION 1)
EML/Email
054-REMOVAL/0541-Removal
Responses/02.01-
CORRESPONDENCE (REMOVAL
RESPONSE)
UCTL( Uncontrolled)
1
htt Ds://semsoub.epa.gov/src/document/Ql/484725
485080
DATA VALIDATION SUMMARY, TEST AMERICA DATA
SET 360-21622 (06/05/2009 TRANSMITTAL LETTER
ATTACHED) [MARGINALIA]
6/2/2009
483
R01: Ricardi, Chris (MACTEC ENGINEERINGAND
CONSULTING INC), R01: Murphy, Michael
(MACTEC ENGINEERING AND CONSULTING INC)
R01: Morrow, Steve (OLIN CORP)
ADD/Analytical Data
Document
054-REMOVAL/0541-Removal
Responses/02.03-SAMPLING &
ANALYSIS DATA (REMOVAL
RESPONSE)
UCTL( Uncontrolled)
1
htt os://semspu b.epa.gov/src/docu ment/Gl/485G8G
484724
[REDACTED] EMAIL TRANSMITTING LATEST
CALCULATIONS OF CANCER RISKOF DRINKING WATER
OF PRIVATE WELLS (EMAIL HISTORY ATTACHED)
5/14/2009
5
R01: Woods, Cynthia (AVATAR
ENVIRONMENTAL)
R01: Sugatt, Richard (US EPA REGION 1)
EML/Email
054-REMOVAL/0541-Removal
Responses/02.01-
CORRESPONDENCE (REMOVAL
RESPONSE)
UCTL( Uncontrolled)
1
htt Ds://semsoub.epa.gov/src/document/Ql/484724
484755
[REDACTED] TIER 2 DATA VALIDATION REPORT, SDG
NO. D00232
5/11/2009
7
R01: Quigley, Diane (WESTON SOLUTIONS INC),
R01: Deruzzo, Gail (NOBIS ENGINEERING INC)
R01: Clark, Christine (US EPA REGION 1)
ADD/Analytical Data
Document
054-REMOVAL/0541-Removal
Responses/02.03-SAMPLING &
ANALYSIS DATA (REMOVAL
RESPONSE)
UCTL( Uncontrolled)
1
htt Bs://semspub.epa.gov/srt/document/01/484755
484757
[REDACTED] TIER 2 DATA VALIDATION REPORT, SDG
NO. D00083
5/11/2009
7
R01: Deruzzo, Gail (NOBIS ENGINEERING INC)
R01: Clark, Christine (US EPA REGION 1)
ADD/Analytical Data
Document
054-REMOVAL/0541-Removal
Responses/02.03-SAMPLING &
ANALYSIS DATA (REMOVAL
RESPONSE)
UCTL( Uncontrolled)
1
htt Ds://semspub.epa.gov/src/document/Ql/484757
485032
[REDACTED] LETTER TRANSMITTING RESULTS OF
RESIDENTIAL WELL SAMPLING CONDUCTED IN
JANUARY2009 (04/16/2009 LETTERAND LABORATORY
ANALYSIS REPORT ATTACHED) [MARGINALIA]
4/21/2009
24
R01: Morrow, Steve (OLIN CORP)
R01: (WILMINGTON (MA) - RESIDENT OF)
LTR/Letter
054-REMOVAL/0541-Removal
Responses/02.01-
CORRESPONDENCE (REMOVAL
RESPONSE)
UCTL( Uncontrolled)
1
htt Ds://semsoub.epa.gov/src/document/Ql/485Q32
484744
[REDACTED] TOTAL RECOVERABLE METALS IN WATER
(CHAIN OF CUSTODY ATTACHED)
4/14/2009
9
R01: Boudreau, Daniel N (US EPA REGION 1)
R01: Dilorenzo, James (US EPA REGION 1)
ADD/Analytical Data
Document
054-REMOVAL/0541-Removal
Responses/02.03-SAMPLING &
ANALYSIS DATA (REMOVAL
RESPONSE)
UCTL( Uncontrolled)
1
htt Ds://semsoub.epa.gov/src/document/Ql/484744
484742
[REDACTED] SPLIT ANALYSIS BNAS IN WATER (CHAIN
OF CUSTODY ATTACHED)
4/2/2009
18
R01: Boudreau, Daniel N (US EPA REGION 1)
R01: Dilorenzo, James (US EPA REGION 1)
ADD/Analytical Data
Document
054-REMOVAL/0541-Removal
Responses/02.03-SAMPLING &
ANALYSIS DATA (REMOVAL
RESPONSE)
UCTL( Uncontrolled)
1
htt Ds://semsoub.epa.gov/src/document/Ql/484742
484743
[REDACTED] SPLITANALYSIS ION CHROMATOGRAPHY
ANION (CHAIN OF CUSTODY ATTACHED)
3/30/2009
11
R01: Boudreau, Daniel N (US EPA REGION 1)
R01: Dilorenzo, James (US EPA REGION 1)
ADD/Analytical Data
Document
054-REMOVAL/0541-Removal
Responses/02.03-SAMPLING &
ANALYSIS DATA (REMOVAL
RESPONSE)
UCTL( Uncontrolled)
1
htt Ds://semsoub.epa.gov/src/document/Ql/484743
483552
HRGC/HRMSAND N-NITROSODIMETHYLAMINE
(NDMA) ANALYSIS DATA SHEET
3/28/2009
6
R01: (SOUTHWEST RESEARCH INSTITUTE)
RPT/ Report
054-REMOVAL/0541-Removal
Responses/02.03-SAMPLING &
ANALYSIS DATA (REMOVAL
RESPONSE)
UCTL( Uncontrolled)
1
htt Ds://semsoub.epa.gov/src/document/Ql/483552
485624
[REDACTED] DATA SUMMARYTABLE TIER 2 VALIDATED
DATA AQUEOUS ANALYSES DAS NO. 0022S, SDG NO.
DOO232/368405
3/28/2009
2
ADD/Analytical Data
Document
054-REMOVAL/0541-Removal
Responses/02.03-SAMPLING &
ANALYSIS DATA (REMOVAL
RESPONSE)
UCTL( Uncontrolled)
1
htt Ds://semsoub.epa.gov/src/document/Ql/485S24
484741
[REDACTED] SPLIT ANALYSIS AMMONIA (CHAIN OF
CUSTODY ATTACH ED)
3/25/2009
12
R01: (ALPHA ANALYTICAL LABORATORIES)
R01: Boudreau, Dan (US EPA REGION 1)
ADD/Analytical Data
Document
054-REMOVAL/0541-Removal
Responses/02.03-SAMPLING &
ANALYSIS DATA (REMOVAL
RESPONSE)
UCTL( Uncontrolled)
1
httos://semspub.epa,gov/src/document/01/48474i
484745
[REDACTED] SPLITANALYSIS VOAS IN DRINKING WATER
(CHAIN OF CUSTODY ATTACHED)
3/19/2009
21
R01: Boudreau, Daniel N (US EPA REGION 1)
R01: Dilorenzo, James (US EPA REGION 1)
ADD/Analytical Data
Document
054-REMOVAL/0541-Removal
Responses/02.03-SAMPLING &
ANALYSIS DATA (REMOVAL
RESPONSE)
UCTL( Uncontrolled)
1
htt Ds://semsoub.epa.gov/src/document/Ql/484745
484723
[REDACTED] EMAIL REGARDING DRAFT RESPONSE TO
RESIDENTIAL WELL LETTER (EMAIL HISTORY ATTACHED)
3/4/2009
2
R01: Morrow, Steven G (OLIN CHEMICAL CORP)
R01: Dilorenzo, James (US EPA REGION 1)
EML/Email
054-REMOVAL/0541-Removal
Responses/02.01-
CORRESPONDENCE (REMOVAL
RESPONSE)
UCTL( Uncontrolled)
1
htt Ds://semsoub.epa.gov/src/document/Ql/484723
485029
[REDACTED] LETTER TRANSMITTING RESULTS OF
RESIDENTIAL WELL SAMPLING CONDUCTED IN
DECEMBER2008(03/04/2009 LETTERAND
LABORATORY ANALYSIS REPORT ATTACHED)
3/4/2009
21
R01: Morrow, Steve (OLIN CORP)
R01: (WILMINGTON (MA) - RESIDENT OF)
LTR/Letter
054-REMOVAL/0541-Removal
Responses/02.01-
CORRESPONDENCE (REMOVAL
RESPONSE)
UCTL( Uncontrolled)
1
htt Ds://semsoub.epa.gov/src/document/Ql/485Q29
485030
[REDACTED] LETTER TRANSMITTING RESULTS OF
RESIDENTIAL WELL SAMPLING CONDUCTED IN
DECEMBER2008(03/04/2009 LETTERAND
LABORATORY ANALYSIS REPORT ATTACHED)
3/4/2009
21
R01: Morrow, Steve (OLIN CORP)
R01: (WILMINGTON (MA) - RESIDENT OF)
LTR/Letter
054-REMOVAL/0541-Removal
Responses/02.01-
CORRESPONDENCE (REMOVAL
RESPONSE)
UCTL( Uncontrolled)
1
htt Ds://semsoub.epa.gov/src/document/Ql/485Q3Q
485546
[REDACTED] LETTER REGARDING DETECTION OF NDMA
IN RESIDENTIAL WELL WATER
3/4/2009
2
R01: Dilorenzo, James (US EPA REGION 1)
R01: (WILMINGTON (MA) - RESIDENT OF)
LTR/Letter
054-REMOVAL/0541-Removal
Responses/02.01-
CORRESPONDENCE (REMOVAL
RESPONSE)
UCTL( Uncontrolled)
1
htt Ds://semsoub.epa.gov/src/document/Ql/48554S
484722
[REDACTED] EMAIL TRANSMITTING PRIVATE WELL
SAMPLE RESULT COMMUNICATIONS
3/2/2009
1
R01: Morrow, Steven G (OLIN CHEMICAL CORP)
R01: Dilorenzo, James (US EPA REGION 1)
EML/Email
054-REMOVAL/0541-Removal
Responses/02.01-
CORRESPONDENCE (REMOVAL
RESPONSE)
UCTL( Uncontrolled)
1
htt Ds://semsoub.epa.gov/src/document/Ql/484722
-------
485525
[REDACTED] LETTER REGARDING RESIDENTIAL WELL
SAMPLING (SUPPORTING DOCUMENTATION
ATTACHED)
3/2/2009
21
R01: Morrow, Steve (OLIN CORP)
R01: (WILMINGTON (MA) - RESIDENT OF)
LTR/Letter
054-REMOVAL/0541-Removal
Responses/02.03-SAMPLING &
ANALYSIS DATA (REMOVAL
RESPONSE)
UCTL( Uncontrolled)
1
httDs://semspub.epa.gov/src/document/Ql/485525
484796
SAMPLE DISPOSITION DOCUMENT- PROJECT NUMBER
07110022
3/1/2009
1
R01: Germansderfer, Inna (US EPA REGION 1),
R01: Dilorenzo, James (US EPA REGION 1)
ADD/Analytical Data
Document
054-REMOVAL/0541-Removal
Responses/02.03-SAMPLING &
ANALYSIS DATA (REMOVAL
RESPONSE)
UCTL( Uncontrolled)
1
httDs://semspub.epa.gov/src/document/Ql/484796
484719
[REDACTED] EMAIL REGARDING RESPONSETO WATER
TEST
2/27/2009
4
R01: (WILMINGTON (MA) - RESIDENT OF)
R01: Dilorenzo, James (US EPA REGION 1)
EML/Email
054-REMOVAL/0541-Removal
Responses/02.01-
CORRESPONDENCE (REMOVAL
RESPONSE)
UCTL( Uncontrolled)
1
httos://semspub.epa,gov/src/document/01/484?19
484720
[REDACTED] EMAIL REGARDING WILMINGTON
SAMPLING (EMAIL HISTORY ATTACH ED)
2/27/2009
2
R01: Morrow, Steven G (OLIN CHEMICAL CORP)
R01: Dilorenzo, James (US EPA REGION 1)
EML/Email
054-REMOVAL/0541-Removal
Responses/02.01-
CORRESPONDENCE (REMOVAL
RESPONSE)
UCTL( Uncontrolled)
1
httDs://semspub.epa.gov/src/document/Ql/48472Q
484721
[REDACTED] EMAIL REGARDING WATER TEST (EMAIL
HISTORY ATTACHED)
2/27/2009
5
R01: (WILMINGTON (MA) - RESIDENT OF)
R01: Dilorenzo, James (US EPA REGION 1)
EML/Email
054-REMOVAL/0541-Removal
Responses/02.01-
CORRESPONDENCE (REMOVAL
RESPONSE)
UCTL( Uncontrolled)
1
httos://semspub.epa,gov/src/document/01/484?21
485628
[REDACTED] ANALYSIS OF GROUNDWATER (MAP
24/LOT 63) SPLIT RESULTS
2/27/2009
2
R01: Dilorenzo, James (US EPA REGION 1)
R01: (WILMINGTON (MA) - RESIDENT OF)
LTR/Letter
054-REMOVAL/0541-Removal
Responses/02.03-SAMPLING &
ANALYSIS DATA (REMOVAL
RESPONSE)
UCTL( Uncontrolled)
1
httos://semspub. epa.gov/src/document/01/485628
484718
[REDACTED] EMAILCONCERNING WATER TEST RESULTS
2/23/2009
2
R01: (WILMINGTON (MA) - RESIDENT OF)
R01: Dilorenzo, James (US EPA REGION 1)
EML/Email
054-REMOVAL/0541-Removal
Responses/02.01-
CORRESPONDENCE (REMOVAL
RESPONSE)
UCTL( Uncontrolled)
1
httos://semspub.epa,gov/src/document/01/484?18
485020
[REDACTED] LETTER REGARDING RESULTS OF WELL
SAMPLING CONDUCTED IN DECEMBER 2008
(SUPPORTING DOCUMENTATION ATTACHED)
2/20/2009
21
R01: Morrow, Steve (OLIN CORP)
R01: (WILMINGTON (MA) - RESIDENT OF)
LTR/Letter
054-REMOVAL/0541-Removal
Responses/02.01-
CORRESPONDENCE (REMOVAL
RESPONSE)
UCTL( Uncontrolled)
1
htt Ds://semsou b.epa.gov/src/docu ment/01/485020
484717
[REDACTED] EMAIL REGARDING RESAMPLE OF HOME
OWNER WELL MAP 24 LOT 54
2/19/2009
1
R01: Morrow, Steven G (OLIN CHEMICAL CORP)
R01: Dilorenzo, James (US EPA REGION 1)
EML/Email
054-REMOVAL/0541-Removal
Responses/02.01-
CORRESPONDENCE (REMOVAL
RESPONSE)
UCTL( Uncontrolled)
1
httos://semspub.epa,gov/src/document/01/484?l?
485543
[REDACTED] LETTER REGARDING DETECTION OF NDMA
IN RESIDENTIAL WELL WATER (07/1999 FACT SHEET
ATTACHED)
2/19/2009
4
R01: Dilorenzo, James (US EPA REGION 1)
R01: (WILMINGTON (MA) - RESIDENT OF)
LTR/Letter
054-REMOVAL/0541-Removal
Responses/02.01-
CORRESPONDENCE (REMOVAL
RESPONSE)
UCTL( Uncontrolled)
1
httBs://semspub.epa.gov/src/document/01/485543
485626
[REDACTED] ANALYSIS OF GROUNDWATER (MAP
27/LOT 14C) SPLIT RESULTS
2/19/2009
2
R01: Dilorenzo, James (US EPA REGION 1)
R01: (WILMINGTON (MA) - RESIDENT OF)
LTR/Letter
054-REMOVAL/0541-Removal
Responses/02.03-SAMPLING &
ANALYSIS DATA (REMOVAL
RESPONSE)
UCTL( Uncontrolled)
1
httDs://semspub.epa.gov/src/document/01/485626
485627
[REDACTED] ANALYSIS OF GROUNDWATER (MAP
24/LOT 87) SPLIT RESULTS
2/19/2009
2
R01: Dilorenzo, James (US EPA REGION 1)
R01: (WILMINGTON (MA) - RESIDENT OF)
LTR/Letter
054-REMOVAL/0541-Removal
Responses/02.03-SAMPLING &
ANALYSIS DATA (REMOVAL
RESPONSE)
UCTL( Uncontrolled)
1
httDs://semspub.epa.gov/src/document/Ql/485627
485629
[REDACTED] ANALYSIS OF GROUNDWATER (MAP
15/LOT 2C) SPLIT RESULTS
2/19/2009
2
R01: Dilorenzo, James (US EPA REGION 1)
R01: (WILMINGTON (MA) - RESIDENT OF)
LTR/Letter
054-REMOVAL/0541-Removal
Responses/02.03-SAMPLING &
ANALYSIS DATA (REMOVAL
RESPONSE)
UCTL( Uncontrolled)
1
httDs://semspub.epa.gov/src/document/Ql/485629
485630
[REDACTED] ANALYSIS OF GROUNDWATER (MAP
14/LOT2B) SPLIT RESULTS
2/19/2009
2
R01: Dilorenzo, James (US EPA REGION 1)
R01: (WILMINGTON (MA) - RESIDENT OF)
LTR/Letter
054-REMOVAL/0541-Removal
Responses/02.03-SAMPLING &
ANALYSIS DATA (REMOVAL
RESPONSE)
UCTL( Uncontrolled)
1
httDs://semspub.epa.gov/src/document/Ql/48563Q
485041
[REDACTED] LEI ILR 1RANSMITTING RESULTS OF
RESIDENTIAL WELL SAMPLING CONDUCTED IN
OCTOBER 2008 (SUPPORTING DOCUMENTATION
ATTACHED) [MARGINALIA]
2/18/2009
23
R01: Morrow, Steve (OLIN CORP)
R01: (WILMINGTON (MA) - RESIDENT OF)
LTR/Letter
054-REMOVAL/0541-Removal
Responses/02.01-
CORRESPONDENCE (REMOVAL
RESPONSE)
UCTL( Uncontrolled)
1
httos://semspub.epa,gov/src/document/01/485Q41
485528
[REDACTED] LETTER REGARDING RESIDENTIAL WELL
SAMPLING (SUPPORTING DOCUMENTATION
ATTACHED)
2/18/2009
26
R01: Morrow, Steve (OLIN CORP)
R01: (WILMINGTON (MA) - RESIDENT OF)
LTR/Letter
054-REMOVAL/0541-Removal
Responses/02.03-SAMPLING &
ANALYSIS DATA (REMOVAL
RESPONSE)
UCTL( Uncontrolled)
1
httDs://semspub.epa.gov/src/document/Ql/485528
485530
[REDACTED] LETTER REGARDING RESIDENTIAL WELL
SAMPLING (SUPPORTING DOCUMENTATION
ATTACHED)
2/18/2009
23
R01: Morrow, Steve (OLIN CORP)
R01: (WILMINGTON (MA) - RESIDENT OF)
LTR/Letter
054-REMOVAL/0541-Removal
Responses/02.03-SAMPLING &
ANALYSIS DATA (REMOVAL
RESPONSE)
UCTL( Uncontrolled)
1
httDs://semspub.epa.gov/src/document/Ql/48553Q
485531
[REDACTED] LETTER REGARDING RESIDENTIAL WELL
SAMPLING (SUPPORTING DOCUMENTATION
ATTACHED)
2/18/2009
23
R01: Morrow, Steve (OLIN CORP)
R01: (WILMINGTON (MA) - RESIDENT OF)
LTR/Letter
054-REMOVAL/0541-Removal
Responses/02.03-SAMPLING &
ANALYSIS DATA (REMOVAL
RESPONSE)
UCTL( Uncontrolled)
1
httDs://semspub.epa,gov/src/document/Ql/485531
485532
[REDACTED] LETTER REGARDING RESIDENTIAL WELL
SAMPLING (SUPPORTING DOCUMENTATION
ATTACHED)
2/18/2009
23
R01: Morrow, Steve (OLIN CORP)
R01: (WILMINGTON (MA) - RESIDENT OF)
LTR/Letter
054-REMOVAL/0541-Removal
Responses/02.03-SAMPLING &
ANALYSIS DATA (REMOVAL
RESPONSE)
UCTL( Uncontrolled)
1
httDs://semspub.epa.gov/src/document/Ql/485532
-------
485533
[REDACTED] LETTER REGARDING RESIDENTIAL WELL
SAMPLING (SUPPORTING DOCUMENTATION
ATTACHED)
2/18/2009
23
R01: Morrow, Steve (OLIN CORP)
R01: (WILMINGTON (MA) - RESIDENT OF)
LTR/Letter
054-REMOVAL/0541-Removal
Responses/02.03-SAMPLING &
ANALYSIS DATA (REMOVAL
RESPONSE)
UCTLJUn
ontrolled)
1
httos:
/semspub.epa.gov/srt/document/01/485533
485534
[REDACTED] LETTER REGARDING RESIDENTIAL WELL
SAMPLING (SUPPORTING DOCUMENTATION
ATTACHED)
2/18/2009
23
R01: Morrow, Steve (OLIN CORP)
R01: (WILMINGTON (MA) - RESIDENT OF)
LTR/Letter
054-REMOVAL/0541-Removal
Responses/02.03-SAMPLING &
ANALYSIS DATA (REMOVAL
RESPONSE)
UCTLJUn
ontrolled)
1
httos:
/semsou b.epa.gov/src/docu ment/01/485534
485021
[REDACTED] DRAFT, LETTER REGARDING DETECTION OF
NDMA IN WELL WATER
2/13/2009
2
R01: Dilorenzo, James (US EPA REGION 1)
R01: (WILMINGTON (MA) - RESIDENT OF)
LTR/Letter
054-REMOVAL/0541-Removal
Responses/02.01-
CORRESPONDENCE (REMOVAL
RESPONSE)
UCTLJUn
ontrolled)
1
httos:
/semsoub. eDa.gov/sir/document/01/485021
485673
[REDACTED] HOME OWNER WELL SAMPLING
PROGRAM
2/13/2009
2
R01: Morrow, Steve (OLIN CORP)
R01: Dilorenzo, James (US EPA REGION 1)
LST/ List/Index
054-REMOVAL/0541-Removal
Responses/02.01-
CORRESPONDENCE (REMOVAL
RESPONSE)
UCTLJUn
ontrolled)
1
httos:
/semsDub.epa.gov/srt/document/01/485673
484733
[REDACTED] EMAIL REGARDING PRIVATE WELL
COMMUNICATIONS
2/10/2009
2
R01: Morrow, Steven G (OLIN CHEMICAL CORP)
R01: Dilorenzo, James (US EPA REGION 1)
EML/Email
054-REMOVAL/0541-Removal
Responses/02.01-
CORRESPONDENCE (REMOVAL
RESPONSE)
UCTLJUn
ontrolled)
1
httos:
/semsoub.epa.gov/srt/document/01/484733
485503
[REDACTED] DETECTED CONCENTRATIONS 2008TO
2009 PRIVATE WELL RESULTS
2/1/2009
2
R01: Owens, James T (US EPA REGION 1)
RPT/ Report
054-REMOVAL/0541-Removal
Responses/02.01-
CORRESPONDENCE (REMOVAL
RESPONSE)
UCTLJUn
ontrolled)
1
httos:
/semspub.epa.gov/srt/document/Ql/4855Q3
485559
[REDACTED] LETTER TRANSMITTING RESULTS OF
RESIDENCE WELL SAMPLING
2/1/2009
1
R01: Morrow, Steve (OLIN CORP)
R01: (WILMINGTON (MA) - RESIDENT OF)
LTR/Letter
054-REMOVAL/0541-Removal
Responses/02.01-
CORRESPONDENCE (REMOVAL
RESPONSE)
UCTLJUn
ontrolled)
1
httos:
/semspub.epa.gov/srt/document/Ql/485559
485562
[REDACTED] LETTER TRANSMITTING RESULTS OF WELL
SAMPLING
2/1/2009
2
R01: Morrow, Steve (OLIN CORP)
R01: (WILMINGTON (MA) - RESIDENT OF)
LTR/Letter
054-REMOVAL/0541-Removal
Responses/02.01-
CORRESPONDENCE (REMOVAL
RESPONSE)
UCTLJUn
ontrolled)
1
httos:
/semspub.epa.gov/srt/document/Ql/4855S2
70001640
EMAIL TRANSMITTING OLIN PROPOSED ADDITIONAL
DRINKING WELLANALYTES
1/30/2009
2
R01: Deruzzo, Gail (NOBIS ENGINEERING INC)
R01: Boudreau, Dan (US EPA REGION 1)
EML/Email
054-REMOVAL/0541-Removal
Responses/02.01-
CORRESPONDENCE (REMOVAL
RESPONSE)
UCTLJUn
ontrolled)
1
httos:
/semspu b.epa.gov/srt/docu ment/Ql/7QQQ164Q
485557
[REDACTED] SUMMARY OF RESIDENCE WELL
MONITORING DATA AND COMPARISON TO FEDERAL
DRINKING WATER STANDARDS/GUIDELINES
1/29/2009
2
R01: Morrow, Steve (OLIN CORP)
ADD/Analytical Data
Document
054-REMOVAL/0541-Removal
Responses/02.03-SAMPLING &
ANALYSIS DATA (REMOVAL
RESPONSE)
UCTLJUn
ontrolled)
1
httos:
/semspub.epa.gov/sir/document/01/485557
485096
EMAIL REGARDING ADDITIONAL CONTAMINANTS LIST
(EMAIL HISTORY ANDTABLE OF PROPOSED
ADDITIONAL DRINKING WELLANALYTES ATTACHED)
[MARGINALIA]
1/26/2009
3
R01: Sugatt, Richard (US EPA REGION 1)
R01: Dilorenzo, James (US EPA REGION 1)
EML/Email
054-REMOVAL/0541-Removal
Responses/02.01-
CORRESPONDENCE (REMOVAL
RESPONSE)
UCTLJUn
ontrolled)
1
httos:
/semspub.epa.gov/sir/document/01/485Q96
483553
ATSDR TECHNICAL ASSISTANCE FORM
1/21/2009
3
R01: Sweet, William (US AGENCY FORTOXIC
SUBSTANCES AND DISEASE REGISTRY (ATSDR))
R01: Dilorenzo, James (US EPA REGION 1)
ADD/Analytical Data
Document
054-REMOVAL/0541-Removal
Responses/02.03-SAMPLING &
ANALYSIS DATA (REMOVAL
RESPONSE)
UCTLJUn
ontrolled)
1
httos:
/semspub.epa.gov/sir/document/01/483553
70001639
EMAIL REGARDING N-NITROSODIMETHYLAMINE
(NDMA) GROUNDWATER RISK
1/20/2009
1
R01: Woods, Cynthia (AVATAR
ENVIRONMENTAL)
R01: Dilorenzo, James (US EPA REGION 1), R01:
Sugatt, Richard (US EPA REGION 1)
EML/Email
054-REMOVAL/0541-Removal
Responses/02.01-
CORRESPONDENCE (REMOVAL
RESPONSE)
UCTLJUn
ontrolled)
1
httos:
/semspub.epa.gov/srt/document/Ql/7QQQ1639
653914
LETTER REGARDING COMPLETION OF CLOSURE, OLIN
GYPSUM LANDFILL, 51 EAMES STREET
1/17/2009
10
R01: Adams, David C (MA DEPTOF
ENVIRONMENTAL PROTECTION), R01: Carrigan,
John A (MA DEPT OF ENVIRONMENTAL
PROTECTION)
R01: Morrow, Steve (OLIN CORP)
LTR/Letter
056-SITE SUPPORT/0563-
State/Tribal Involvement/09.10-
STATE TECHNICAL AND HISTORICAL
RECORDS
UCTLJUn
ontrolled)
1
httos:
/semspub.epa,gov/sir/document/01/653914
485560
[REDACTED] SUMMARY OF RESIDENCE WELL
MONITORING DATA AND COMPARISON TO FEDERAL
DRINKING WATER STANDARDS/GUIDELINES
1/8/2009
2
R01: Morrow, Steve (OLIN CORP)
ADD/Analytical Data
Document
054-REMOVAL/0541-Removal
Responses/02.03-SAMPLING &
ANALYSIS DATA (REMOVAL
RESPONSE)
UCTLJUn
ontrolled)
1
httos:
/semspub.epa.gov/sir/document/01/48556Q
646184
LETTER REGARDING COMPLETION OF CLOSURE, OLIN
GYPSUM LANDFILL
1/7/2009
5
R01: Adams, David C (MA DEPTOF
ENVIRONMENTAL PROTECTION), R01: Carrigan,
John A (MA DEPT OF ENVIRONMENTAL
PROTECTION)
R01: Morrow, Steve (OLIN CORP)
LTR/Letter
056-SITE SUPPORT/0563-
State/Tribal Involvement/09.10-
STATE TECHNICAL AND HISTORICAL
RECORDS
UCTLJUn
ontrolled)
1
httos:
/semspub.epa,gov/srt/document/Ql/646184
646186
FACT SHEET: OLIN GYPSUM LANDFILLCLOSURE
CERTIFICATION
1/6/2009
5
R01: (MA DEPT OF ENVIRONMENTAL
PROTECTION)
RPT/ Report
056-SITE SUPPORT/0563-
State/Tribal Involvement/09.10-
STATE TECHNICAL AND HISTORICAL
RECORDS
UCTLJUn
ontrolled)
1
httos:
/semspub.epa,gov/srt/document/Ql/646186
485563
[REDACTED] DRAFT, LETTER REGARDING DETECTION OF
N-NITROSODIMETHYLAMINE (NDMA) IN WELL WATER,
MAP 24/LOT 54
1/2/2009
2
R01: Dilorenzo, James (US EPA REGION 1)
R01: (WILMINGTON (MA) - RESIDENT OF)
LTR/Letter
054-REMOVAL/0541-Removal
Responses/02.01-
CORRESPONDENCE (REMOVAL
RESPONSE)
UCTLJUn
ontrolled)
1
httos:
/semspub.epa.gov/sir/document/01/485563
196796
National Recommended Water Quality Criteria
1/1/2009
22
Rll: (US ENVIRONMENTAL PROTECTION
AGENCY)
PUB/Publication
058-PROGRAM SUPPORT/0583-
Regulatory Development/B8.1-
Regulations, Standards & Guidelines
UCTLJUn
ontrolled)
11
httos:
/semspub.epa.gov/sir/document/ll/196796
-------
458077
SEMI-ANNUAL STATUS REPORT NO. 3 (12/31/2008
TRANSMITTAL LETTERATTACHED)
12/29/2008
595
R01:(MACTEC ENGINEERING AND
CONSULTING INC), R01: (OLIN CORP)
R01: (US EPA REGION 1)
RPT/ Report
053-REMEDIAL/0532-Re medial
Design/03.07-WORK PLANS &
PROGRESS REPORTS(RI)
UCTL( Uncontrolled)
1
htt os://semspub.epa.gov/src/document/Gl/458G77
483556
DATA VALIDATION SUMMARY, TEST AMERICA DATA
SETS 360-19275-1 AND 360-19248-1
12/19/2008
75
R01: Ricardi, Chris (MACTEC ENGINEERINGAND
CONSULTING INC), R01: Murphy, Michael
(MACTEC ENGINEERING AND CONSULTING INC)
R01: Morrow, Steve (OLIN CORP)
ADD/Analytical Data
Document
054-REMOVAL/0541-Removal
Responses/02.03-SAMPLING &
ANALYSIS DATA (REMOVAL
RESPONSE)
UCTL( Uncontrolled)
1
htt Ds://semsoub.epa.gov/src/document/Ql/483556
484790
RESIDENTIAL WELL SAMPLING RESULTS (FINAL RESULTS
SUMMARY ATTACHED)
12/19/2008
7
R01: Morrow, Steve (OLIN CORP)
R01: Dilorenzo, James (US EPA REGION 1)
LTR/Letter
054-REMOVAL/0541-Removal
Responses/02.03-SAMPLING &
ANALYSIS DATA (REMOVAL
RESPONSE)
UCTL( Uncontrolled)
1
htt Ds://semsoub.epa.gov/src/document/Ql/48479Q
485656
[REDACTED] RESIDENTIAL WELL SAMPLING RESULTS
(FINAL RESULTS SUMMARY ATTACHED) [MARGINALIA]
12/19/2008
7
R01: Morrow, Steve (OLIN CORP)
R01: Dilorenzo, James (US EPA REGION 1)
LTR/Letter
054-REMOVAL/0541-Removal
Responses/02.03-SAMPLING &
ANALYSIS DATA (REMOVAL
RESPONSE)
UCTL( Uncontrolled)
1
htt Ds://semspub.epa.gov/src/document/01/485656
485556
[REDACTED] HOME OWNER WELL SAMPLING
PROGRAM
12/12/2008
2
R01: Morrow, Steve (OLIN CORP)
R01: Dilorenzo, James (US EPA REGION 1)
LST/ List/Index
054-REMOVAL/0541-Removal
Responses/02.01-
CORRESPONDENCE (REMOVAL
RESPONSE)
UCTL( Uncontrolled)
1
htt Ds://semspub.epa.gov/src/document/01/485556
70001638
EMAIL REGARDING HOME OWNERS SAMPLING UPDATE
12/12/2008
1
R01: Morrow, Steven G (OLIN CHEMICAL CORP)
R01: Dilorenzo, James (US EPA REGION 1)
EML/Email
054-REMOVAL/0541-Removal
Responses/02.01-
CORRESPONDENCE (REMOVAL
RESPONSE)
UCTL( Uncontrolled)
1
httos://semspub.epa,gov/src/document/01/?000138
484751
[REDACTED] TOTAL RECOVERABLE METALS IN WATER
(CHAIN OF CUSTODY ATTACHED), DRAFT RESULTS
12/3/2008
9
R01: Boudreau, Daniel N (US EPA REGION 1)
R01: Dilorenzo, James (US EPA REGION 1)
ADD/Analytical Data
Document
054-REMOVAL/0541-Removal
Responses/02.03-SAMPLING &
ANALYSIS DATA (REMOVAL
RESPONSE)
UCTL( Uncontrolled)
1
httos://semspub.epa,gov/src/document/01/484?51
485642
[REDACTED] TECHNICAL OVERSIGHT REPORT,
POTENTIALLY RESPONSIBLE PARTY(PRP) SAMPLING OF
RESIDENTIAL WELLS (12/16/2008 TRANSMITTAL LETTER
ATTACHED)
12/1/2008
14
R01: (NOBIS ENGINEERING INC)
ADD/Analytical Data
Document
054-REMOVAL/0541-Removal
Responses/02.03-SAMPLING &
ANALYSIS DATA (REMOVAL
RESPONSE)
UCTL( Uncontrolled)
1
htt Ds://semspub.epa.gov/src/document/01/485642
485640
[REDACTED] ANALYTICAL SCREENING DATA REPORT
WATER SAMPLES (11/17/2008 AND 01/10/2000
TRANSMITTALS ATTACHED)
11/17/2008
8
R01: (MA DEP)
ADD/Analytical Data
Document
054-REMOVAL/0541-Removal
Responses/02.03-SAMPLING &
ANALYSIS DATA (REMOVAL
RESPONSE)
UCTL( Uncontrolled)
1
htt Ds://semspub.epa.gov/src/document/Ql/48564Q
484791
SAMPLE RECEIPT MEMORANDUM
11/12/2008
2
R01: Boudreau, Dan (US EPA REGION 1)
R01: Dilorenzo, James (US EPA REGION 1)
MEMO/Memorandum
054-REMOVAL/0541-Removal
Responses/02.01-
CORRESPONDENCE (REMOVAL
RESPONSE)
UCTL( Uncontrolled)
1
httos://semspub.epa,gov/src/document/01/484?91
70001637
EMAIL REGARDING HOME WELL OWNER UPDATE
11/4/2008
1
R01: Morrow, Steven G (OLIN CHEMICAL CORP)
R01: Dilorenzo, James (US EPA REGION 1)
EML/Email
054-REMOVAL/0541-Removal
Responses/02.01-
CORRESPONDENCE (REMOVAL
RESPONSE)
UCTL( Uncontrolled)
1
httos://semspub.epa,gov/src/document/01/?000163?
485675
[REDACTED] HOME OWNER WELL SAMPLING
PROGRAM
10/31/2008
3
R01: Morrow, Steve (OLIN CORP)
R01: Dilorenzo, James (US EPA REGION 1)
LST/ List/Index
054-REMOVAL/0541-Removal
Responses/02.01-
CORRESPONDENCE (REMOVAL
RESPONSE)
UCTL( Uncontrolled)
1
htt Ds://semspub.epa.gov/src/document/01/485675
484732
[REDACTED] EMAIL REGARDING PENDING PRIVATE
WELL SAMPLES
10/29/2008
2
R01: (WILMINGTON (MA) - RESIDENT OF)
R01: Dilorenzo, James (US EPA REGION 1)
EML/Email
054-REMOVAL/0541-Removal
Responses/02.01-
CORRESPONDENCE (REMOVAL
RESPONSE)
UCTL( Uncontrolled)
1
htt Ds://semsoub.epa.gov/src/document/01/484732
484747
[REDACTED] SPLIT ANALYSIS BNAS IN WATER (CHAIN
OF CUSTODY ATTACHED)
10/24/2008
29
R01: Boudreau, Daniel N (US EPA REGION 1)
R01: Dilorenzo, James (US EPA REGION 1)
ADD/Analytical Data
Document
054-REMOVAL/0541-Removal
Responses/02.03-SAMPLING &
ANALYSIS DATA (REMOVAL
RESPONSE)
UCTL( Uncontrolled)
1
htt Ds://semsoub.epa.gov/src/document/Ql/484747
485510
[REDACTED] HOME OWNER WELL SAMPLING
PROGRAM (MAP ATTACH ED) [MARGINALIA]
10/24/2008
2
LST/ List/Index
054-REMOVAL/0541-Removal
Responses/02.01-
CORRESPONDENCE (REMOVAL
RESPONSE)
UCTL( Uncontrolled)
1
httos://semspub.epa,gov/src/document/01/485510
485519
[REDACTED] HOME OWNER WELL SAMPLING
PROGRAM
10/24/2008
2
LST/ List/Index
054-REMOVAL/0541-Removal
Responses/02.01-
CORRESPONDENCE (REMOVAL
RESPONSE)
UCTL( Uncontrolled)
1
httDs://semspub.epa,gov/src/document/Ql/485519
483542
SPLIT ANALYSIS AMMONIA (CHAIN OF CUSTODY
ATTACHED)
10/15/2008
12
R01: (ALPHA ANALYTICAL LABORATORIES)
ADD/Analytical Data
Document
054-REMOVAL/0541-Removal
Responses/02.03-SAMPLING &
ANALYSIS DATA (REMOVAL
RESPONSE)
UCTL( Uncontrolled)
1
htt Ds://semsoub.epa.gov/src/document/Ql/483542
484750
[REDACTED] SPLITANALYSIS ION CHROMATOGRAPHY
ANION (CHAIN OF CUSTODY ATTACHED)
10/15/2008
12
R01: Boudreau, Daniel N (US EPA REGION 1)
R01: Dilorenzo, James (US EPA REGION 1)
ADD/Analytical Data
Document
054-REMOVAL/0541-Removal
Responses/02.03-SAMPLING &
ANALYSIS DATA (REMOVAL
RESPONSE)
UCTL( Uncontrolled)
1
htt Ds://semsoub.epa.gov/src/document/Ql/48475Q
484753
[REDACTED] SPLITANALYSIS VOAS IN DRINKING WATER
(CHAIN OF CUSTODY ATTACHED)
10/14/2008
27
R01: Boudreau, Daniel N (US EPA REGION 1)
R01: Dilorenzo, James (US EPA REGION 1)
ADD/Analytical Data
Document
054-REMOVAL/0541-Removal
Responses/02.03-SAMPLING &
ANALYSIS DATA (REMOVAL
RESPONSE)
UCTL( Uncontrolled)
1
htt Ds://semsoub.epa.gov/src/document/Ql/484753
-------
484749
[REDACTED] SPLITS CHAIN OF CUSTODY RECORD
10/8/2008
1
R01: (US EPA REGION 1)
ADD/Analytical Data
Document
054-REMOVAL/0541-Removal
Responses/02.03-SAMPLING &
ANALYSIS DATA (REMOVAL
RESPONSE)
UCTLJUn
ontrolled)
1
httos:
/semsou b.epa.gov/src/docu ment/01/484749
485631
[REDACTED] SPLIT COMPARISON OF PRIVATE WELL
RESULTS 2008
10/1/2008
2
ADD/Analytical Data
Document
054-REMOVAL/0541-Removal
Responses/02.03-SAMPLING &
ANALYSIS DATA (REMOVAL
RESPONSE)
UCTLJUn
ontrolled)
1
httos:
/semspub.epa.gov/src/document/Ql/485631
647003
DENSE NON-AQUEOUS PHASE LIQUID (DNAPL) PILOT
DESIGN REPORT
9/9/2008
16
R01: Thompson, Peter H (MACTEC
ENGINEERING AND CONSULTING INC), R01:
Oulton, Ralph E(MACTEC ENGINEERINGAND
CONSULTING INC)
R01: Dilorenzo, James M (US EPA REGION 1)
RPT/ Report
053-REMEDIAL/0532-Re medial
Design/06.04-REMEDIAL DESIGN
REPORTS
UCTLJUn
ontrolled)
1
httos:
/semspub.epa.gov/six/document/Gl/647GQ3
485045
RESIDENTIAL WELL SAMPLING
8/27/2008
5
ADD/Analytical Data
Document
054-REMOVAL/0541-Removal
Responses/02.03-SAMPLING &
ANALYSIS DATA (REMOVAL
RESPONSE)
UCTLJUn
ontrolled)
1
httos:
/semspub.epa.gov/src/document/Ql/485Q45
485650
[REDACTED] EMAIL REGARDING WELL SAMPLING FOR
METHYLTERTIARY BUTYL ETHER (MTBE) (EMAIL
HISTORY ATTACHED)
8/27/2008
3
R01: Dilorenzo, James (US EPA REGION 1)
R01: Coyne, Joseph (MA DEP)
LTR/Letter
054-REMOVAL/0541-Removal
Responses/02.01-
CORRESPONDENCE (REMOVAL
RESPONSE)
UCTLJUn
ontrolled)
1
httos:
/semspub.epa.gov/src/document/Ql/485S5Q
70001635
EMAIL REGARDING PRIVATE WELL ANALYTICAL LIST
8/18/2008
3
R01: Ford, Heather M (NOBIS ENGINEERING
INC)
R01: Dilorenzo, James (US EPA REGION 1)
EML/Email
054-REMOVAL/0541-Removal
Responses/02.01-
CORRESPONDENCE (REMOVAL
RESPONSE)
UCTLJUn
ontrolled)
1
httos:
/semspub.epa.gov/src/document/Ql/7QQQ1635
293559
FINAL INTERIM RESPONSE STEPS WORK PLAN
8/8/2008
433
R01: Murphy, MichaelJ (MACTEC
ENGINEERING AND CONSULTING INC), R01:
Thompson, Peter(MACTEC ENGINEERINGAND
CONSULTING INC)
R01: (US EPA REGION 1)
WP/Work Plan
054-REMOVAL/0541-Removal
Responses/02.06-WORK PLANS &
PROGRESS REPORTS (REMOVAL
RESPONSE)
UCTLJUn
ontrolled)
1
httos:
/semspub.epa.gov/sir/document/01/293559
485514
[REDACTED] ADDITIONAL COMMENTS ON PRIVATE
WELL SUMMARY
8/6/2008
2
R01: Ford, Heather M (NOBIS ENGINEERING
INC)
R01: Dilorenzo, James (US EPA REGION 1)
LTR/Letter
054-REMOVAL/0541-Removal
Responses/02.01-
CORRESPONDENCE (REMOVAL
RESPONSE)
UCTLJUn
ontrolled)
1
httos:
/semspub.epa.gov/src/document/Ql/485514
485641
[REDACTED] ADDITIONAL COMMENTS ON PRIVATE
WELL SUMMARY [MARGINALIA]
8/6/2008
2
R01: Ford, Heather M (NOBIS ENGINEERING
INC)
R01: Dilorenzo, James (US EPA REGION 1)
LTR/Letter
054-REMOVAL/0541-Removal
Responses/02.01-
CORRESPONDENCE (REMOVAL
RESPONSE)
UCTLJUn
ontrolled)
1
httos:
/semspub.epa.gov/sir/document/01/485641
485644
[REDACTED] EMAIL REGARDING OLIN'S PROPOSED
PRIVATE WELL LIST
8/1/2008
2
R01: Dilorenzo, James (US EPA REGION 1)
R01: Ford, Heather M (NOBIS ENGINEERING
INC)
EML/Email
054-REMOVAL/0541-Removal
Responses/02.01-
CORRESPONDENCE (REMOVAL
RESPONSE)
UCTLJUn
ontrolled)
1
httos:
/semspub.epa.gov/sir/document/01/485644
293558
SEMI-ANNUAL STATUS REPORT NO. 2 (06/27/2008
COVER LETTER ATTACH ED)
6/27/2008
970
R01: (MACTEC ENGINEERING AND
CONSULTING INC), R01: (OLIN CORP)
R01: (US EPA REGION 1)
RPT/ Report
053-REMEDIAL/0532-Re medial
Design/03.07-WORK PLANS &
PROGRESS REPORTS(RI)
UCTLJUn
ontrolled)
1
httos:
/semspub.epa.gov/src/document/01/293558
484760
[REDACTED] REVIEW SUMMARY OF PRIVATE WELL
INVENTORY AND SAMPLING ACTIVITIES DURING
IMMEDIATE RESPONSE ACTIONS 2003/2004
6/1/2008
8
R01: (NOBIS ENGINEERING INC)
ADD/Analytical Data
Document
054-REMOVAL/0541-Removal
Responses/02.03-SAMPLING &
ANALYSIS DATA (REMOVAL
RESPONSE)
UCTLJUn
ontrolled)
1
httos:
/semspub.epa.gov/src/document/Ql/48476Q
485643
[REDACTED] GROUNDWATER USE AND VALUE
DETERMINATION (05/30/2008 MAPATTACHED)
[MARGINALIA]
6/1/2008
3
RPT/ Report
056-SITE SUPPORT/0561-
Administrative Support/17.07-
REFERENCE DOCUMENTS
UCTLJUn
ontrolled)
1
httos:
/semspub.epa.gov/src/document/Ql/485643
485647
[REDACTED] REVIEW SUMMARY OF PRIVATE WELL
INVENTORY AND SAMPLING ACTIVITIES DURING
IMMEDIATE RESPONSE ACTIONS 2003/2004
(06/18/2008 TRANSMITTAL LETTER AND TABLES
ATTACHED) [MARGINALIA]
6/1/2008
13
R01: (NOBIS ENGINEERING INC)
ADD/Analytical Data
Document
054-REMOVAL/0541-Removal
Responses/02.03-SAMPLING &
ANALYSIS DATA (REMOVAL
RESPONSE)
UCTLJUn
ontrolled)
1
httos:
/semspub.epa.gov/six/document/01/485647
485651
[REDACTED] REVIEW SUMMARY OF PRIVATE WELL
INVENTORY AND SAMPLING ACTIVITIES DURING
IMMEDIATE RESPONSE ACTIONS 2003/2004
(06/09/2008 TRANSMITTAL LETTER AND TABLES
ATTACHED) [MARGINALIA]
6/1/2008
11
R01: (NOBIS ENGINEERING INC)
ADD/Analytical Data
Document
054-REMOVAL/0541-Removal
Responses/02.03-SAMPLING &
ANALYSIS DATA (REMOVAL
RESPONSE)
UCTLJUn
ontrolled)
1
httos:
/semspub.epa.gov/six/document/01/485651
484793
FACT SHEET: EMERGING CONTAMINANT N-
NITROSODIMETHYLAMINE(NDMA)
4/1/2008
4
R01: (US EPA REGION 1)
PUB/Publication
051-COMMUNITY
INVOLVEMENT/0511-Community
Involvement Activities/13.05-FACT
SHEETS/INFORMATION UPDATES
UCTLJUn
ontrolled)
1
httos:
/semspub.epa.gov/six/document/01/484793
135714
Procedures forthe Derivation of Equilibrium
Partitioning Sediments Benchmarks (ESBs) forthe
Protection of Bent hie Organisms: Compendium of Tier
2 Values for Nonionic Organics, EPA/600/R-02/016
3/1/2008
75
LAWS /
Laws/Regu lat ions/Gu ida nc
053-REMEDIAL/053-
REMEDIAL/0531-Remedy
Characterization/A4.2-Record of
Decision/Remedy Selection
UCTLJUn
ontrolled)
11
httos:
/semspub.epa,gov/six/document/ll/135714
484798
DRINKING WATER CONTAMINANTS
2/15/2008
13
R01: (US EPA)
RPT/ Report
056-SITE SUPPORT/0561-
Administrative Support/17.07-
REFERENCE DOCUMENTS
UCTLJUn
ontrolled)
1
httos:
/semspub.epa.gov/six/document/01/484798
484799
2008 STANDARDS AND GUIDELINES FOR
CONTAMINANTS IN MASSACHUSETTS DRINKING
WATER
2/15/2008
7
R01: (MA DEP)
RPT/ Report
056-SITE SUPPORT/0561-
Administrative Support/17.07-
REFERENCE DOCUMENTS
UCTLJUn
ontrolled)
1
httos:
/semspub.epa.gov/six/document/01/484799
-------
485600
CURRENT REGULATORY LIMIT: N
NITROSODIMETHYLAMINE(NDMA)
2/15/2008
3
R01: (MA DEP)
RPT/ Report
056-SITE SUPPORT/0561-
Administrative Support/17.07-
REFERENCE DOCUMENTS
UCTL( Uncontrolled)
htt os://semspub.epa.gov/src/document/Gl/4856GG
485601
FACT SHEET: CURRENT REGULATORY LIMIT - N
NITROSODIMETHYLAMINE(NDMA)
2/15/2008
20
R01: (AGENCY FORTOXIC SUBSTANCES AND
DISEASE REGISTRY (ATSDR))
PUB/Publication
051-COMMUNITY
INVOLVEMENT/0511-Community
Involvement Activities/13.05-FACT
SHEETS/INFORMATION UPDATES
UCTL( Uncontrolled)
httDs://semspub.epa,gov/src/document/Gl/4856Gl
280865
REVIEW OF DRAFT FOCUSED REMEDIAL INVESTIGATION
(Rl) REPORT [MARGINALIA]
1/15/2008
22
R01: Dilorenzo, James M (US EPA REGION 1)
R01: Morrow, Stephen (OLIN CORP)
LTR/Letter
053-REMEDIAL/0531-Remedy
Characterization/03.06-REMEDIAL
INVESTIGATION REPORTS
UCTL( Uncontrolled)
htt Ds://semsoub.epa.gov/src/document/Gl/28Q865
280857
SPLIT DATA FOR GROUNDWATER LETTER REPORT
1/10/2008
1
R01: Dilorenzo, James M (US EPA REGION 1)
R01: Morrow, Stephen (OLIN CORP)
RPT/ Report
053-REMEDIAL/0531-Remedy
Characterization/03.02-SAMPLING &
ANALYSIS DATA (Rl)
UCTL( Uncontrolled)
htt Ds://semsoub.epa.gov/src/document/Gl/28Q857
650486
SEMI-ANNUALSTATUS REPORT NO. 1
1/2/2008
1082
R01: Murphy, MichaelJ (MACTEC
ENGINEERING AND CONSULTING INC), R01:
Thompson, Peter(MACTEC ENGINEERING AND
CONSULTING INC)
R01: (US EPA REGION 1)
RPT/ Report
054-REMOVAL/0541-Removal
Responses/02.06-WORK PLANS &
PROGRESS REPORTS (REMOVAL
RESPONSE)
UCTL( Uncontrolled)
htt Ds://semspub.epa.gov/src/document/Ql/65Q486
484740
[REDACTED] DATA SUMMARYTABLE: TIER 2 DATA
VALIDATION N-NITROSODIMETHYLAMINE (NDMA)
ANALYSIS
1/1/2008
7
R01: (NOBIS ENGINEERING INC)
ADD/Analytical Data
Document
054-REMOVAL/0541-Removal
Responses/02.03-SAMPLING &
ANALYSIS DATA (REMOVAL
RESPONSE)
UCTL( Uncontrolled)
htt Ds://semspub.epa.gov/src/document/Ql/48474Q
280845
LETTER REGARDING POSTPONEMENT OF REMEDIAL
INVESTIGATION / FEASIBILITY STUDY (RI/FS) WORK
PLAN
12/17/2007
1
R01: Dilorenzo, James (US EPA REGION 1)
R01: Morrow, Stephen (OLIN CORP)
LTR/Letter
053-REMEDIAL/0531-Remedy
Characterizat ion/03.01-
CORRESPONDENCE (Rl)
UCTL( Uncontrolled)
htt Ds://semsoub.epa.gov/src/document/Ql/28Q245
280859
SAMPLE RECEIPT MEMORANDUM
12/12/2007
1
R01: Boudreau, Dan (US EPA REGION 1)
R01: Dilorenzo, James M (US EPA REGION 1)
MEMO/Memorandum
053-REMEDIAL/0531-Remedy
Characterizat ion/03.01-
CORRESPONDENCE (Rl)
UCTL( Uncontrolled)
htt Ds://semsoub.epa.gov/src/document/Ql/28Q859
280860
SPLIT DATA FOR GROUNDWATER LETTER REPORT
[MARGINALIA]
12/4/2007
11
R01: Boudreau, Daniel N (US EPA REGION 1)
R01: Dilorenzo, James M (US EPA REGION 1)
RPT/ Report
053-REMEDIAL/0531-Remedy
Characterization/03.02-SAMPLING &
ANALYSIS DATA (Rl)
UCTL( Uncontrolled)
htt Ds://semsoub.epa.gov/src/document/Ql/28Q86Q
280864
SPLIT DATA FOR GROUNDWATER LETTER REPORT
[MARGINALIA]
12/4/2007
11
R01: Boudreau, Daniel N (US EPA REGION 1)
R01: Dilorenzo, James M (US EPA REGION 1)
RPT/ Report
053-REMEDIAL/0531-Remedy
Characterization/03.02-SAMPLING &
ANALYSIS DATA (Rl)
UCTL( Uncontrolled)
htt Ds://semsoub.epa.gov/src/document/Ql/28Q864
280862
SPLIT DATA FOR GROUNDWATER LETTER REPORT
[MARGINALIA]
11/29/2007
26
R01: Boudreau, Daniel N (US EPA REGION 1)
R01: Dilorenzo, James M (US EPA REGION 1)
RPT/ Report
053-REMEDIAL/0531-Remedy
Characterization/03.02-SAMPLING &
ANALYSIS DATA (Rl)
UCTL( Uncontrolled)
htt Ds://semsoub.epa.gov/src/document/Ql/28Q862
280861
SPLIT DATA FOR GROUNDWATER LETTER REPORT
[MARGINALIA]
11/28/2007
26
R01: Boudreau, Daniel N (US EPA REGION 1)
R01: Dilorenzo, James M (US EPA REGION 1)
RPT/ Report
053-REMEDIAL/0531-Remedy
Characterization/03.02-SAMPLING &
ANALYSIS DATA (Rl)
UCTL( Uncontrolled)
httos://semspub.epa,gov/src/document/01/28086i
280863
SAMPLING & ANALYSIS SPLIT DATA FOR
GROUNDWATER REPORT [MARGINALIA]
11/20/2007
12
R01: (ALPHA ANALYTICAL LABORATORIES)
R01: Boudreau, Daniel N (US EPA REGION 1)
ADD/Analytical Data
Document
053-REMEDIAL/0531-Remedy
Characterization/03.02-SAMPLING &
ANALYSIS DATA (Rl)
UCTL( Uncontrolled)
htt Ds://semsoub.epa.gov/src/document/Ql/28Q863
647012
REDACTED EMAIL REGARDING REVIEW OF INTERIM
RESPONSE STEPS WORK PLAN (11/02/2007-11/09/2007
SUPPORTING EMAILSATTACHED)
11/19/2007
2
R01: Duggan, Deborah L(WILMINGTON (MA)
TOWN OF)
R01: Dilorenzo, James (US EPA REGION 1)
EML/Email
054-REMOVAL/0541-Removal
Responses/02.01-
CORRESPONDENCE (REMOVAL
RESPONSE)
UCTL( Uncontrolled)
httos://semspub.epa,gov/src/document/01/64?G12
484795
SAMPLE DISPOSITION DOCUMENT- PROJECT NUMBER
07110022
11/14/2007
4
R01: Dilorenzo, James (US EPA REGION 1), R01:
Montanaro, Joseph (US EPA REGION 1)
ADD/Analytical Data
Document
054-REMOVAL/0541-Removal
Responses/02.03-SAMPLING &
ANALYSIS DATA (REMOVAL
RESPONSE)
UCTL( Uncontrolled)
htt Ds://semsoub.epa.gov/src/document/Ql/484795
280858
EMAIL REGARDING PLANNED SPLIT SAMPLING (WITH
11/08/2007 EMAILATTACHED)
11/9/2007
6
R01: Thompson, Peter H (MACTEC
ENGINEERING AND CONSULTING INC)
R01: Dilorenzo, James M (US EPA REGION 1)
MEMO/Memorandum
053-REMEDIAL/0531-Remedy
Characterizat ion/03.01-
CORRESPONDENCE (Rl)
UCTL( Uncontrolled)
htt Ds://semsoub.epa.gov/src/document/Ql/28Q858
280821
REVIEW OF DRAFT INTERIM RESPONSE STEPS WORK
PLAN
11/2/2007
12
R01: Dilorenzo, James (US EPA REGION 1)
R01: Morrow, Stephen (OLIN CORP)
LTR/Letter
054-REMOVAL/0541-Removal
Responses/02.06-WORK PLANS &
PROGRESS REPORTS (REMOVAL
RESPONSE)
UCTL( Uncontrolled)
httos://semspub.epa,gov/src/document/01/28Q821
280409
COMMENTS ON THE INTERIM RESPONSE STEPS WORK
PLAN (IRSWP)
10/16/2007
2
R01: Ford, Heather M (US EPA REGION 1)
R01: Bouvier, Marc (NOBIS ENGINEERING INC)
EML/Email
053-REMEDIAL/0531-Remedy
Characterizat ion/03.01-
CORRESPONDENCE (Rl)
UCTL( Uncontrolled)
htt Ds://semsoub.epa.gov/src/document/Ql/28Q4Q9
275079
REFERENCES, PART 2, FOR DRAFT, FOCUSED REMEDIAL
INVESTIGATION (Rl)
10/10/2007
6765
R01: (US EPA REGION 1), R01: (MACTEC)
RPT/ Report
053-REMEDIAL/0531-Remedy
Characterization/03.06-REMEDIAL
INVESTIGATION REPORTS
UCTL( Uncontrolled)
htt Ds://semsoub.epa.gov/src/document/Ql/275Q79
280397
MEETING ATTENDANCE LIST: FOCUSED REMEDIAL
INVESTIGATION (Rl) REPORT
10/10/2007
1
R01: (US EPA REGION 1)
MTG / Meeting Document
051-COMMUNITY
INVOLVEMENT/0511-Community
Involvement Activities/13.04-PUBLIC
MEETINGS/HEARINGS
UCTL( Uncontrolled)
htt Ds://semsoub.epa.gov/src/document/Ql/28Q397
280401
OVERVIEW MEETING PRESENTATION: DRAFT FOCUSED
REMEDIAL INVESTIGATION (Rl) REPORT
10/10/2007
29
R01: (MACTEC)
MTG / Meeting Document
053-REMEDIAL/0531-Remedy
Characterizat ion/03.01-
CORRESPONDENCE (Rl)
UCTL( Uncontrolled)
httos://semspub.epa,gov/src/document/Gl/280401
280425
MEETING AGENDA FOR FOCUSED REMEDIAL
INVESTIGATION (Rl) REPORT
10/10/2007
1
R01: (US EPA REGION 1)
MTG / Meeting Document
053-REMEDIAL/0531-Remedy
Characterizat ion/03.01-
CORRESPONDENCE (Rl)
UCTL( Uncontrolled)
htt Ds://semsoub.epa.gov/src/document/01/28Q425
-------
280419
MEMO ON DRAFT FOCUSED REMEDIAL INVESTIGATION
(Rl) REPORT
10/5/2007
1
R01: Dilorenzo, James (US EPA REGION 1)
MEMO/Memorandum
053-REMEDIAL/0531-Remedy
Characterizat ion/03.01-
CORRESPONDENCE (Rl)
UCTL( Uncontrolled)
httos://semspub.epa,gov/src/document/01/28G419
485529
[REDACTED] LETTER REGARDING PRIVATE WELL
SAMPLING RESULTS (SUPPORTING DOCUMENTATION
ATTACHED)
10/4/2007
18
R01: Pyott, Christopher (MA DEPT OF
ENVIRONMENTAL PROTECTION), R01: Fagan,
Joanne (MA DEPTOF ENVIRONMENTAL
PROTECTION)
R01: (WILMINGTON (MA) - RESIDENT OF)
LTR/Letter
054-REMOVAL/0541-Removal
Responses/02.01-
CORRESPONDENCE (REMOVAL
RESPONSE)
UCTL( Uncontrolled)
htt Ds://semsoub.epa.gov/src/document/Gl/485529
275077
DRAFT, FOCUSED REMEDIAL INVESTIGATION (Rl)
10/1/2007
9661
R01: (US EPA REGION 1), R01: (MACTEC)
RPT/ Report
053-REMEDIAL/0531-Remedy
Characterization/03.06-REMEDIAL
INVESTIGATION REPORTS
UCTL( Uncontrolled)
htt os://semspub.epa.gov/src/document/Gl/275G77
280434
MEMO WITH COMMENTS ON THE DRAFT INTERIM
RESPONSE STEPS WORKPLAN ADDITIONAL
INFORMATION
9/21/2007
2
R01: Sullivan, Suzanne M (METCALF & EDDY)
R01: Dilorenzo, James (US EPA REGION 1)
MEMO/Memorandum
053-REMEDIAL/0531-Remedy
Characterizat ion/03.01-
CORRESPONDENCE (Rl)
UCTL( Uncontrolled)
htt Ds://semsoub.epa.gov/src/document/Gl/28G4 34
280839
LETTER REGARDING COMMENTS ON DRAFT INTERIM
RESPONSE STEPS WORK PLAN
9/21/2007
2
R01: Sullivan, Suzanne M (METCALF & EDDY)
R01: Dilorenzo, James (US EPA REGION 1)
LTR/Letter
054-REMOVAL/0541-Removal
Responses/02.06-WORK PLANS &
PROGRESS REPORTS (REMOVAL
RESPONSE)
UCTL( Uncontrolled)
htt Ds://semsoub.epa.gov/src/document/Gl/28G239
647008
REDACTED EMAIL REGARDING ADDITIONAL COMMENT
ON DRAFT INTERIM RESPONSE STEPS WORK PLAN
(IRSWP) ADDITIONAL INFORMATION
9/21/2007
1
R01: Duggan, Deborah L(WILMINGTON (MA)
TOWN OF)
R01: Dilorenzo, James (US EPA REGION 1)
EML/Email
053-REMEDIAL/0531-Remedy
Characterizat ion/03.01-
CORRESPONDENCE (Rl)
UCTL( Uncontrolled)
htt Ds://semsoub.epa.gov/src/document/Gl/647GG8
647009
REDACTED EMAIL REGARDING WERC'S COMMENTS ON
REVIEW PROCESS
9/21/2007
1
R01: Dilorenzo, James (US EPA REGION 1)
R01: Coyne, Joseph (MA DEP)
EML/Email
053-REMEDIAL/0531-Remedy
Characterizat ion/03.01-
CORRESPONDENCE (Rl)
UCTL( Uncontrolled)
htt Ds://semsoub.epa.gov/src/document/Gl/647GG9
647010
REDACTED EMAIL COMMENTS ON PROCESS (RESPONSE
ATTACHED)
9/21/2007
4
R01: Dilorenzo, James (US EPA REGION 1)
R01: Coyne, Joseph (MA DEP)
EML/Email
053-REMEDIAL/0531-Remedy
Characterizat ion/03.01-
CORRESPONDENCE (Rl)
UCTL( Uncontrolled)
httos://semspub.epa,gov/src/document/01/S47010
647011
REDACTED EMAIL WITH THE COMMENTS ON THE
DRAFT INTERIM RESPONSE STEPS WORK PLAN AND
SUPPLEMENTAL MATERIALS
9/21/2007
3
R01: Mercer, Gary (METCALF & EDDY)
R01: Dilorenzo, James (US EPA REGION 1)
MEMO/Memorandum
053-REMEDIAL/0531-Remedy
Characterizat ion/03.01-
CORRESPONDENCE (Rl)
UCTL( Uncontrolled)
htt Ds://semsoub.epa.gov/src/document/Gl/647Gll
280408
EMAIL REGARDING COMMENT PERIOD AND NEW
MATERIAL (EMAIL HISTORY ATTACH ED)
9/10/2007
2
R01: Dilorenzo, James (US EPA REGION 1)
EML/Email
053-REMEDIAL/0531-Remedy
Characterizat ion/03.01-
CORRESPONDENCE (Rl)
UCTL( Uncontrolled)
htt Ds://semspu b.epa.gov/src/docu ment/01/280408
280395
ANNOUNCEMENT OF A PUBLIC INFORMATION
MEETING ON 09/05/2007
9/5/2007
2
R01: (US EPA REGION 1)
MTG / Meeting Document
051-COMMUNITY
INVOLVEMENT/0511-Community
Involvement Activities/13.04-PUBLIC
MEETINGS/HEARINGS
UCTL( Uncontrolled)
htt Ds://semspu b.epa.gov/src/docu ment/01/280395
653700
SEDIMENTTOXICITYOF PETROLEUM HYDROCARBON
FRACTIONS
9/1/2007
89
R01: (BATTELLE)
R01: (MA DEPT OF ENVIRONMENTAL
PROTECTION)
RPT/ Report
056-SITE SUPPORT/0561-
Administrative Support/17.07-
REFERENCE DOCUMENTS
UCTL( Uncontrolled)
htt Ds://semsoub.epa.gov/src/document/Gl/6537GG
280433
MEMO WITH COMMENTS ON THE DRAFT INTERIM
RESPONSE STEPS WORK PLAN
8/28/2007
4
R01: Sullivan, Suzanne M (WILMINGTON (MA)
RESIDENT OF)
R01: Dilorenzo, James (US EPA REGION 1)
MEMO/Memorandum
053-REMEDIAL/0531-Remedy
Characterizat ion/03.01-
CORRESPONDENCE (Rl)
UCTL( Uncontrolled)
htt Ds://semspu b.epa.gov/src/docu ment/01/280433
280828
LETTER REGARDING COMMENTS ON DRAFT INTERIM
RESPONSE STEPS WORK PLAN [MARGINALIA]
8/28/2007
7
R01: Trifilo, Joel J (GEOINSIGHT INC), R01:
Gilbert, John (GEOINSIGHT INC)
R01: Dilorenzo, James (US EPA REGION 1)
LTR/Letter
054-REMOVAL/0541-Removal
Responses/02.06-WORK PLANS &
PROGRESS REPORTS (REMOVAL
RESPONSE)
UCTL( Uncontrolled)
htt Ds://semspu b.epa.gov/src/docu ment/01/280828
485536
[REDACTED] MAP: SITE LOCATION [MARGINALIA]
8/28/2007
1
R01: (MACTEC ENGINEERING AND
CONSULTING INC)
FIG / Figure/Map/ Drawing
056-SITE SUPPORT/0561-
Administrative Support/17.04-NON-
PRINT MATERIALS
UCTL( Uncontrolled)
htt Ds://semspub.epa.gov/src/document/01/485536
280431
MEMO ON THE REVIEW OF THE 07/25/2007 DRAFT
INTERIM RESPONSE STEPS WORK PLAN
8/27/2007
1
R01: Sugatt, Richard (US EPA REGION 1)
R01: Dilorenzo, James (US EPA REGION 1)
MEMO/Memorandum
053-REMEDIAL/0531-Remedy
Characterizat ion/03.01-
CORRESPONDENCE (Rl)
UCTL( Uncontrolled)
httos://semspub.epa,gov/src/document/01/280431
485511
[REDACTED] TABLE 2.1-18: RESIDENTIAL WELL SAMPLE
LOCATIONS
8/24/2007
1
R01: (MACTEC ENGINEERING AND
CONSULTING INC)
FIG / Figure/Map/ Drawing
056-SITE SUPPORT/0561-
Administrative Support/17.04-NON-
PRINT MATERIALS
UCTL( Uncontrolled)
htt Ds://semspu b.epa.gov/src/docu ment/01/485511
485523
[REDACTED] TABLE C.2-1: GROUNDWATER ANALYTICAL
RESULTS DRAFT REMEDIAL INVESTIGATION (Rl) REPORT
8/14/2007
4
ADD/Analytical Data
Document
054-REMOVAL/0541-Removal
Responses/02.03-SAMPLING &
ANALYSIS DATA (REMOVAL
RESPONSE)
UCTL( Uncontrolled)
htt Ds://semspub.epa.gov/src/document/01/485523
280418
MEMO ON DRAFT INTERIM RESPONSE STEPS WORK
PLAN
8/8/2007
1
R01: Dilorenzo, James (US EPA REGION 1)
MEMO/Memorandum
053-REMEDIAL/0531-Remedy
Characterizat ion/03.01-
CORRESPONDENCE (Rl)
UCTL( Uncontrolled)
httos://semspub.epa,gov/src/document/01/280418
274545
DRAFT INTERIM RESPONSE STEPS WORK PLAN
(07/30/2007 TRANSMITTAL LETTERATTACHED)
7/25/2007
332
R01: Murphy, MichaelJ (MACTEC
ENGINEERING AND CONSULTING INC), R01:
Thompson, Peter(MACTEC ENGINEERING AND
CONSULTING INC)
R01: (US EPA REGION 1)
WP/Work Plan
053-REMEDIAL/0531-Remedy
Characterizat ion/03.07-WORK
PLANS & PROGRESS REPORTS (Rl)
UCTL( Uncontrolled)
htt Ds://semspub.epa.gov/src/document/01/274545
280396
NEWS RELEASE: THE US EPA ANNOUNCES THE
AVAILABILITY OF ATECHNICAL ASSISTANCE GRANT
(TAG) FOR THE OLIN CHEMICAL SUPERFUND SITE
7/1/2007
1
R01: Shewack, Robert (US EPA REGION 1)
PUB/Publication
051-COMMUNITY
INVOLVEMENT/0511-Community
Involvement Activities/13.07-
TECHNICAL ASSISTANCE GRANTS
(TAGS)
UCTL( Uncontrolled)
htt Ds://semspu b.epa.gov/src/docu ment/01/280396
273456
ADMINISTRATIVE SETTLEMENT AGREEMENT AND
ORDER ON CONSENT (AOC) WITH STATEMENT OF
WORK (SOW) FOR RI/FS
6/28/2007
115
R01: Owens lii, James T (US EPA REGION 1)
LGL/ Legal Instrument
052-ENFORCEMENT/0522-
Negotiat ions/10.07-EPA
ADMINISTRATIVE ORDERS
UCTL( Uncontrolled)
htt Ds://semsoub.epa.gov/src/document/01/27345S
-------
280402
NEWS RELEASE: US EPAANNOUNCESA SETTLEMENT
AGREEMENT FOR INVESTIGATION OF THE OLIN
CHEMICALSUPERFUNDSITE
6/1/2007
3
R01: (US EPA REGION 1)
PUB/Publication
051-COMMUNITY
INVOLVEMENT/0511-Community
Involvement Activities/13.03-NEWS
CUPPINGS/PRESS RELEASES
UCTL( Uncontrolled)
1
htt Ds://semsoub.epa.gov/src/document/Gl/2804G2
280393
LETTER ON WILMINGTON ENVIRONMENTAL
RESTORATION COMMrTTEE APPLYING FOR A
TECHNICAL ASSISTANCE GRANT (TAG)
5/9/2007
1
R01: Brazell, Maiy (WILMINGTON
ENVIRONMENTAL RESTORATION COMMITTEE)
R01: Shewack, Robert (US EPA REGION 1)
LTR/Letter
051-COMMUNITY
INVOLVEMENT/0511-Community
Involvement Activities/13.07-
TECHNICAL ASSISTANCE GRANTS
(TAGS)
UCTL( Uncontrolled)
1
htt Ds://semsoub.epa.gov/src/document/Gl/28G393
280435
MEETING NOTES REGARDING SUPERFUND PROCESS
3/13/2007
2
R01: (US EPA REGION 1), R01: (WILMINGTON
(MA) TOWN OF)
MTG / Meeting Document
053-REMEDIAL/0531-Remedy
Characterizat ion/03.01-
CORRESPONDENCE (Rl)
UCTL( Uncontrolled)
1
htt Ds://semsoub.epa.gov/src/document/Gl/280435
653912
CLOSURE CERTIFIATION LETTER, CALCIUM SULFATE
LANDFILL, 51 EAMES STREET
12/13/2006
40
R01: Peters, Mark(MACTEC ENGINEERING AND
CONSULTING INC), R01: Thompson, Peter
(MACTEC ENGINEERING AND CONSUTING INC)
R01: Adams, David C (MA DEPTOF
ENVIRONMENTAL PROTCTION)
LTR/Letter
056-SITE SUPPORT/0563-
State/Tribal Involvement/09.10-
STATE TECHNICAL AND HISTORICAL
RECORDS
UCTL( Uncontrolled)
1
httos://semspub.epa,gov/src/document/Gl/S53912
653913
DRAFT CALCIUM SULFATE LANDFILL POST CLOSURE
MONITORING PLAN, 51 EAMES STREET (12/15/2006
TRANSMITTAL LETTERATTACHED)
12/1/2006
48
R01:(MACTEC ENGINEERING AND
CONSULTING INC)
WP/Work Plan
056-SITE SUPPORT/0563-
State/Tribal Involvement/09.10-
STATE TECHNICAL AND HISTORICAL
RECORDS
UCTL( Uncontrolled)
1
httos://semspub.epa,gov/src/document/01/S53913
652698
FRESHWATER SCREENING BENCHMARKS, EPA REGION
3 BIOLOGICAL TECHNICAL ASSISTANCE GROUP (BTAG)
7/1/2006
8
R01: (US EPA REGION 3)
CHT / Chart/Table
056-SITE SUPPORT/0561-
Administrative Support/17.07-
REFERENCE DOCUMENTS
UCTL( Uncontrolled)
1
httos://semspub. epa.gov/src/document/Gl/S52S98
251674
SPECIAL NOTICE LETTER (SNL) - AMERICAN BILTRITE INC
6/19/2006
6
R01: Studlien, Susan (US EPA REGION 1 -
OFFICE OF SITE REMEDIATION &
RESTORATION)
R01: Winkleman, Henry W (AMERICAN
BILTRITE INC)
LTR/Letter
052-ENFORCEMENT/0521-PRP
Search/11.09-PRP-SPECIFIC
DOCUMENTS
UCTL( Uncontrolled)
1
htt Ds://semsoub.epa.gov/src/document/Gl/25674
251675
SPECIAL NOTICE LETTER (SNL) - STEPAN COMPANY
6/19/2006
6
R01: Studlien, Susan (US EPA REGION 1 -
OFFICE OF SITE REMEDIATION &
RESTORATION)
R01: Olian, Robert M (SIDLEY & AUSTIN), R01:
(STEPAN COMPANY)
LTR/Letter
052-ENFORCEMENT/0521-PRP
Search/11.09-PRP-SPECIFIC
DOCUMENTS
UCTL( Uncontrolled)
1
httos://semspub.epa,gov/src/document/01/251S?5
251676
SPECIAL NOTICE LETTER (SNL) - NOR-AM AGRO LLC
6/19/2006
6
R01: Studlien, Susan (US EPA REGION 1 -
OFFICE OF SITE REMEDIATION &
RESTORATION)
R01: Threadgold, Eric (NOR-AM AGRO LLC)
LTR/Letter
052-ENFORCEMENT/0521-PRP
Search/11.09-PRP-SPECIFIC
DOCUMENTS
UCTL( Uncontrolled)
1
httos://semspub.epa,gov/src/document/01/251S?S
251677
SPECIAL NOTICE LETTER (SNL) - FISONS LIMITED
6/19/2006
6
R01: Studlien, Susan (US EPA REGION 1 -
OFFICE OF SITE REMEDIATION &
RESTORATION)
R01: Polinsky, Laurie H (FISONS LIMITED)
LTR/Letter
052-ENFORCEMENT/0521-PRP
Search/11.09-PRP-SPECIFIC
DOCUMENTS
UCTL( Uncontrolled)
1
httos://semspub.epa,gov/src/document/01/251S??
251678
SPECIAL NOTICE LETTER (SNL) - BILTRITE CORP
6/19/2006
6
R01: Studlien, Susan (US EPA REGION 1 -
OFFICE OF SITE REMEDIATION &
RESTORATION)
R01: Amidon, David M (BURNS & LEVINSON
LLP), R01: (BILTRITE CORP)
LTR/Letter
052-ENFORCEMENT/0521-PRP
Search/11.09-PRP-SPECIFIC
DOCUMENTS
UCTL( Uncontrolled)
1
httos://semspub.epa,gov/src/document/01/251S?8
251679
SPECIAL NOTICE LETTER (SNL) - OLIN CORP
6/19/2006
5
R01: Studlien, Susan (US EPA REGION 1 -
OFFICE OF SITE REMEDIATION &
RESTORATION)
R01: Hilliard, Garland (OLIN CORP), R01:
Morrow, Stephen (OLIN CORP)
LTR/Letter
052-ENFORCEMENT/0521-PRP
Search/11.09-PRP-SPECIFIC
DOCUMENTS
UCTL( Uncontrolled)
1
httos://semspub.epa,gov/src/document/01/251S?9
252319
GENERAL NOTICE LETTER (GNL) - NOR-AM AGRO LLC
(INFORMATION SHEET ATTACH ED)
5/24/2006
8
R01: Studlien, Susan (US EPA REGION 1)
R01: Threadgold, Eric (NOR-AM AGRO LLC)
LTR/Letter
052-ENFORCEMENT/0521-PRP
Search/11.09-PRP-SPECIFIC
DOCUMENTS
UCTL( Uncontrolled)
1
httos://semspub.epa,gov/src/document/01/252319
252320
GENERAL NOTICE LETTER (GNL) - FISONS LIMITED
(INFORMATION SHEET ATTACH ED)
5/24/2006
8
R01: Studlien, Susan (US EPA REGION 1)
R01: Polinsky, Laurie H (FISONS LIMITED)
LTR/Letter
052-ENFORCEMENT/0521-PRP
Search/11.09-PRP-SPECIFIC
DOCUMENTS
UCTL( Uncontrolled)
1
htt Ds://semspu b.epa.gov/src/docu ment/01/252320
280394
NEWS RELEASE: OLIN CHEMICAL SITE ADDED TO
NATIONAL SUPERFUND LIST
4/18/2006
2
R01: (US EPA REGION 1)
PUB/Publication
051-COMMUNITY
INVOLVEMENT/0511-Community
Involvement Activities/13.03-NEWS
CUPPINGS/PRESS RELEASES
UCTL( Uncontrolled)
1
htt Ds://semspu b.epa.gov/src/docu ment/01/280394
280430
LETTER ABOUT PROPOSED DENSE AQUEOUS PHASE
LIQUID (DAPL) E>CTRACTION WELL LOCATION
3/9/2006
2
R01: Johnson, Stephen (US EPA), R01: Pyott,
Christopher (MA DEPT OF ENVIRONMENTAL
PROTECTION)
R01: Dilorenzo, James (US EPA REGION 1)
LTR/Letter
053-REMEDIAL/0531-Remedy
Characterizat ion/03.01-
CORRESPONDENCE (Rl)
UCTL( Uncontrolled)
1
htt Ds://semspu b.epa.gov/src/docu ment/01/280430
275083
LETTER REGARDING TRUCKS-TO-RAIL WASTE TRANSFER
FACILITY
3/1/2006
2
R01: Varney, Robert W (US EPA REGION 1)
R01: Kerry, John F (US SENATE)
LTR/Letter
051-COMMUNITY
INVOLVEMENT/0511-Community
Involvement Activities/14.01-
CORRESPONDENCE
(CONGRESSIONAL RELATIONS)
UCTL( Uncontrolled)
1
htt Ds://semspub.epa.gov/src/document/01/275Q83
280400
AGENDA AND NOTES FROM A MEETING ON
02/08/2006 [MARGINALIA]
2/8/2006
14
R01: (MA DEPT OF ENVIRONMENTAL
PROTECTION)
MTG / Meeting Document
053-REMEDIAL/0531-Remedy
Characterizat ion/03.01-
CORRESPONDENCE (Rl)
UCTL( Uncontrolled)
1
htt Ds://semsoub.epa.gov/src/document/Gl/28G4GG
485609
ASSESSMENT GUIDANCE FOR PERCHLORATE
1/26/2006
3
R01: Bodine, Susan Parker (US EPA)
R01: (REGIONAL ADMINISTRATORS-REGIONS 1-
X)
RPT/ Report
056-SITE SUPPORT/0561-
Administrative Support/17.07-
REFERENCE DOCUMENTS
UCTL( Uncontrolled)
1
htt Ds://semspub.epa.gov/src/document/Ql/485SQ9
241252
GENERAL NOTICE LETTER (GNL) - OLIN CORPORATION
1/12/2006
8
R01: Studlien, Susan (US EPA REGION 1)
R01: Pain, George H (OLIN CORP)
LTR/Letter
052-ENFORCEMENT/0521-PRP
Search/11.09-PRP-SPECIFIC
DOCUMENTS
UCTL( Uncontrolled)
1
httos://semspub.epa,gov/src/document/01/241252
241253
GENERAL NOTICE LETTER (GNL) - BILTRITE
CORPORATION
1/12/2006
8
R01: Studlien, Susan (US EPA REGION 1)
R01: Fine, Stephen A (BILTRITE CORP)
LTR/Letter
052-ENFORCEMENT/0521-PRP
Search/11.09-PRP-SPECIFIC
DOCUMENTS
UCTL( Uncontrolled)
1
httos://semspub.epa,gov/src/document/01/241253
241254
GENERAL NOTICE LETTER (GNL) - AMERICAN BILTRITE
INC
1/12/2006
8
R01: Studlien, Susan (US EPA REGION 1)
R01: Winkelman, Henry W (AMERICAN
BILTRITE INC)
LTR/Letter
052-ENFORCEMENT/0521-PRP
Search/11.09-PRP-SPECIFIC
DOCUMENTS
UCTL( Uncontrolled)
1
httos://semspub.epa,gov/src/document/01/241254
-------
241255
GENERAL NOTICE LETTER (GNL) - STEPAN COMPANY
1/12/2006
8
R01: Studlien, Susan (US EPA REGION 1)
R01: Brennan, Richard S (STEPAN COMPANY)
LTR/Letter
052-ENFORCEMENT/0521-PRP
Search/11.09-PRP-SPECIFIC
DOCUMENTS
UCTL( Uncontrolled)
1
httos://semspub.epa,gov/src/document/Gl/241255
647586
IMMEDIATE RESPONSE ACTION (IRA) STATUS REPORT
FOR PLANT B AREA REMEDIATION SYSTEMS
(08/30/2005 TRANSMITTAL MEMO ATTACHED)
8/1/2005
414
R01: (SHAW ENVIRONMENTAL INC)
R01: (OLIN CORPORATION)
RPT/ Report
053-REMEDIAL/0531-Remedy
Characterization/03.07-WORK
PLANS & PROGRESS REPORTS (Rl)
UCTL( Uncontrolled)
1
htt Ds://semsoub.epa.gov/src/document/Gl/647586
280429
LETTER ABOUT DENSE AQUEOUS PHASE LIQUID (DAPL)
RECOVERY PILOT TEST OFF-PROPERTY WEST DITCH
STUDY AREA LAB COLUMN TEST AND PERFORMANCE
MONITORING PROGRAM
3/21/2005
5
R01: Pyott, Christopher (MA DEPT OF
ENVIRONMENTAL PROTECTION), R01: Johnson,
Stephen M (MA DEPT OF ENVIRONMENTAL
PROTECTION)
R01: Morrow, Stephen (OLIN CORP)
LTR/Letter
053-REMEDIAL/0531-Remedy
Characterizat ion/03.01-
CORRESPONDENCE (Rl)
UCTL( Uncontrolled)
1
htt Ds://semsoub.epa.gov/src/document/Gl/28G429
190690
GUIDELINES FOR CARCINOGEN RISK ASSESSMENT
3/1/2005
166
LAWS /
Laws/Regu lat ions/Gu ida nc
058-PROGRAM SUPPORT/0583-
Regulatory Development/B8.1-
Regulations, Standards & Guidelines
UCTL( Uncontrolled)
11
htt Ds://semsoub.epa.gov/src/document/ll/19G69G
100002728
Supplemental Guidance for Assessing Susceptibility
from Early-Life Exposure to Carcinogens - EPA/630/R-
03-003F
3/1/2005
126
LAWS /
Laws/Regu lat ions/Gu ida nc
058-PROGRAM SUPPORT/0583-
Regulatory Development/B8.4-
Directives and Policy Guidance
Documents
UCTL( Uncontrolled)
11
htt Ds://semsoub.epa.gov/src/document/ll/10GGG2728
280428
LETTER ABOUT OLIN PROPERTY WEST DITCH DAPL
RECOVERY PROVE-OUT
2/1/2005
6
R01: Pyott, Christopher (MA DEPT OF
ENVIRONMENTAL PROTECTION), R01: Johnson,
Stephen M (MA DEPT OF ENVIRONMENTAL
PROTECTION)
R01: Morrow, Stephen (OLIN CORP)
LTR/Letter
053-REMEDIAL/0531-Remedy
Characterizat ion/03.01-
CORRESPONDENCE (Rl)
UCTL( Uncontrolled)
1
htt Ds://semspu b.epa.gov/src/docu ment/01/280428
248296
PART 2 CONSTRUCTION RELATED RELEASE ABATEMENT
MEASURE - STATUS REPORT#8 (RELEASE ABATEMENT
MEASURE (RAM) TRANSMITTAL FORM AND
TRANSMITTAL LETTERATTACHED)
9/7/2004
344
R01: Hanley, Margret (GEI CONSULTANTS INC)
R01: Pyott, Christopher (MA DEPT OF
ENVIRONMENTAL PROTECTION), R01: (OLIN
CORP)
RPT/ Report
053-REMEDIAL/0531-Remedy
Characterizat ion/03.04-INTERIM
DELIVERABLES (Rl)
UCTL( Uncontrolled)
1
httDs://semspub.epa.gov/src/document/01/248296
485524
[REDACTED] TABLE 1: ANALYTICAL DATA FOR PRIVATE
WELL SAMPLING
8/5/2004
6
ADD/Analytical Data
Document
054-REMOVAL/0541-Removal
Responses/02.03-SAMPLING &
ANALYSIS DATA (REMOVAL
RESPONSE)
UCTL( Uncontrolled)
1
htt Ds://semspub.epa.gov/src/document/01/485524
247370
FIELD ACTIVITY REPORT - FORMER LAKE POLY AREA
(COMPREHENSIVE RESPONSE ACTION TRANSMITTAL
FORM AND 02/10/2004 TRANSMITTAL LETTER
ATTACHED)
2/9/2004
156
R01: Hanley, Margret (GEI CONSULTANTS INC),
R01: Axelrod, Eric M (MACTEC ENGINEERING
AND CONSULTING INC), R01: Murphy, Michael
J (MACTEC ENGINEERING AND CONSULTING
INC)
R01: Pyott, Christopher (MA DEPT OF
ENVIRONMENTAL PROTECTION), R01: Morrow,
Stephen (OLIN CORP)
RPT/ Report
056-SITE SUPPORT/0563-
State/Tribal Involvement/09.10-
STATE TECHNICAL AND HISTORICAL
RECORDS
UCTL( Uncontrolled)
1
htt Ds://semsoub.epa.gov/src/document/Ql/24737Q
485649
[REDACTED] MAP: FIGURE 1 PRIVATE WELL
INVESTIGATION SURVEY
1/20/2004
1
R01: (MACTEC)
FIG / Figure/Map/ Drawing
056-SITE SUPPORT/0561-
Administrative Support/17.04-NON-
PRINT MATERIALS
UCTL( Uncontrolled)
1
htt Ds://semsoub.epa.gov/src/document/Ql/485S49
485537
[REDACTED] UPDATE ON INVENTORYANDTESTING OF
PRIVATE WELLS (TABLES AND MAPS ATTACHED)
[MARGINALIA AND HIGHLIGHTS]
1/8/2004
18
R01: Axelrod, Eric M (MACTEC ENGINEERING
AND CONSULTING INC), R01: Murphy, Michael
J (MACTEC ENGINEERING AND CONSULTING
INC)
R01: Pyott, Christopher (MA DEPT OF
ENVIRONMENTAL PROTECTION)
LTR/Letter
054-REMOVAL/0541-Removal
Responses/02.02-REMOVAL
RESPONSE REPORTS
UCTL( Uncontrolled)
1
htt Ds://semsoub.epa.gov/src/document/Ql/485537
136
MEMO REGARDING REVISIONS TO HUMAN HEALTH
TOXICITY VALUES IN SUPERFUND RISKASSESSMENTS
12/5/2003
4
Rll: (US ENVIRONMENTAL PROTECTION
AGENCY)
LAWS /
Laws/Regu lat ions/Gu ida nc
058-PROGRAM SUPPORT/0583-
Regulatory Development/B8.1-
Regulations, Standards & Guidelines,
058-PROGRAM SUPPORT/0583-
Regulatory Development/B8.4-
Directives and Policy Guidance
Documents
UCTL( Uncontrolled)
11
htt Ds://semsoub.epa.gov/src/document/ll/13S
100002731
Procedures forthe Derivation of Equilibrium
Partitioning Sediment Benchmarks (ESBs) forthe
Protection of Bent hie Organisms: PAH Mixtures - EPA-
600-R-02-013
11/1/2003
175
Rll: (US ENVIRONMENTAL PROTECTION
AGENCY)
LAWS /
Laws/Regu lat ions/Gu ida nc
058-PROGRAM SUPPORT/0583-
Regulatory Development/B8.4-
Directives and Policy Guidance
Documents
UCTL( Uncontrolled)
11
httos://semspub.epa,gov/src/document/ll/10GGG2731
100016398
SUPPLEMENTALSTATE INFORMATION REQUEST
RESPONSE-OLIN CORP
12/18/2002
20
R01: Morrow, Steve (OLIN CORP)
R01: Johnson, Stephen M (MA DEPT OF
ENVIRONMENAL PROTECTION)
LTR/Letter
052-ENFORCEMENT/0521-PRP
Search/11.09-PRP-SPECIFIC
DOCUMENTS
UCTL( Uncontrolled)
1
httos://semspub.epa,gov/src/document/Gl/10G01S398
190669
CALCULATING UPPER CONFIDENCE LIMITS FOR
EXPOSURE POINT CONCENTRATIONS AT HAZARDOUS
WASTE SITES
12/1/2002
32
LAWS /
Laws/Regu lat ions/Gu ida nc
058-PROGRAM SUPPORT/0583-
Regulatory Development/B8.1-
Regulations, Standards & Guidelines
UCTL( Uncontrolled)
11
htt Ds://semsoub.epa.gov/src/document/ll/19GS69
247317
STATE INFORMATION REQUEST RESPONSE - OLIN CORP
11/27/2002
91
R01: Obrien, Thomas P (OLIN CORP)
R01: Johnson, Stephen M (MA DEPT OF
ENVIRONMENAL PROTECTION)
LTR/Letter
052-ENFORCEMENT/0521-PRP
Search/11.09-PRP-SPECIFIC
DOCUMENTS
UCTL( Uncontrolled)
1
httos://semspub.epa,gov/src/document/Gl/247317
248308
PART 2 CONSTRUCTION RELATED RELEASE ABATEMENT
MEASURE STATUS REPORT NO 1 (RELEASE AND UTILITY
RELATED ABATEMENT MEASURE (RAM) TRANSMITTAL
FORM ANDTRANSMITTAL LETTERATTACHED)
12/27/2000
291
R01: Hanley, Margret (GEI CONSULTANTS INC)
R01: Pyott, Christopher (MA DEPT OF
ENVIRONMENTAL PROTECTION), R01: (OLIN
CORP)
RPT/ Report
053-REMEDIAL/0531-Remedy
Characterizat ion/03.04-INTERIM
DELIVERABLES (Rl)
UCTL( Uncontrolled)
1
htt Ds://semsoub.epa.gov/src/document/01/248308
100015929
ADMINISTRATIVE CONSENT ORDER FOR CLOSURE OF
SPINAZOLA LANDFILL - MA DEP DOCKET NO. ACOP NO.
NE-9009-4673
7/24/2000
13
R01: (MA DEPT OF ENVIRONMENTAL
PROTECTION)
LGL/ Legal Instrument
052-ENFORCEMENT/0522-
Negotiat ions/10.03-STATE AND
LOCAL ENFORCEMENT RECORDS
UCTL( Uncontrolled)
1
httos://semspub.epa,gov/src/document/0i/iG0G15929
-------
652699
ARTICLE IN ARCHIVES OF ENVIRONMENTAL
CONTAMINATION AND TOXICOLOGY: DEVELOPMENT
AND EVALUATION OF CONSENSUS-BASED SEDIMENT
QUALITY GUIDELINES FOR FRESHWATER ECOSYSTEMS
1/13/2000
13
R01: Berger, T A, R01: Ingersoll, C G
(COLUMBIA ENVIRONMENTAL RESEARCH
CENTER), R01: Macdonald, Donald D
(MACDONALD ENVIRONMENTAL SCIENCES
LTD)
PUB/Publication
056-SITE SUPPORT/0561-
Administrative Support/17.07-
REFERENCE DOCUMENTS
COPY( Controlled/Co
pyright)
1
DOI: 10.1007/s002440010075
190616
PEER REVIEW DRAFT- SCREENING LEVEL ECOLOGICAL
RISKASSESSMENT PROTOCOL FOR HAZARDOUS WASTE
COMBUSTION FACILITIES, VOLUME ONE
8/1/1999
1362
LAWS /
Laws/Regu lat ions/Gu ida nc
058-PROGRAM SUPPORT/0583-
Regulatory Development/B8.1-
Regulations, Standards & Guidelines
UCTL( Uncontrolled)
11
httDs://semspub.epa,gov/src/document/ll/19Q616
70001483
ATSDR FACT SHEET: N-NITROSODIMETHYLAMINE
(NDMA)
7/1/1999
2
R01: (AGENCY FORTOXIC SUBSTANCES AND
DISEASE REGISTRY (ATSDR))
PUB/Publication
051-COMMUNITY
INVOLVEMENT/0511-Community
Involvement Activities/13.05-FACT
SHEETS/INFORMATION UPDATES
UCTL( Uncontrolled)
1
httos://semspub.epa,gov/src/document/Gl/7GGG1483
70001618
FACT SHEET: N-NITROSO-DIMETHYLAMINE (NDMA)
CAS #62-75-9
7/1/1999
2
R01: (AGENCY FORTOXIC SUBSTANCES AND
DISEASE REGISTRY (ATSDR))
PUB/Publication
051-COMMUNITY
INVOLVEMENT/0511-Community
Involvement Activities/13.05-FACT
SHEETS/INFORMATION UPDATES
UCTL( Uncontrolled)
1
htt Ds://semsou b.epa.gov/src/docu ment/01/7GGG1618
247373
IRANSMIIIAL LEI 1LR FOR SUPPLLMLNIAL PHASE 2
COMPREHENSIVE SITE ASSESSMENT (CSA) -
GEOCHEMICAL DISCRIMINATION BETWEEN
GROUNDWATER EMANATING FROM CALCIUM SULFATE
AND WOBURN LANDFILL (COMPREHENSIVE RESPONSE
ACTION TRANSMITTAL FORM ATTACHED)
2/16/1999
4
R01: Hanley, Margret (GEI CONSULTANTS INC)
R01: Pyott, Christopher (MA DEPT OF
ENVIRONMENTAL PROTECTION)
LTR/Letter
056-SITE SUPPORT/0563-
State/Tribal Involvement/09.10-
STATE TECHNICAL AND HISTORICAL
RECORDS
UCTL( Uncontrolled)
1
htt Ds://semsoub.epa.gov/src/document/01/247373
247379
TECHNICAL SERIES 4 - GEOCHEMICAL DISCRIMINATION
BETWEEN GROUNDWATER EMANATING FROM THE
CALCIUM SULFATE ADN WOBURN SANITARY LANDFILLS
2/10/1999
58
R01: (GEOMEGA INC)
R01: (OLIN CORP)
RPT/ Report
056-SITE SUPPORT/0563-
State/Tribal Involvement/09.10-
STATE TECHNICAL AND HISTORICAL
RECORDS
UCTL( Uncontrolled)
1
httos://semspub. epa.gov/sir/document/01/247379
247328
TECHNICAL SERIES 3 - RESULTS OF AUGUST 1998
MULTILEVEL PIEZOMENTER SAMPLING EVENT AND
DAPL/DIFFUSE LAYER DISCRIMINATION ANALYSIS
(COMPREHENSIVE RESPONSE ACTION TRANSMITTAL
FORM AND 01/22/99 TRANSMITTAL LETTER
ATTACHED)
1/8/1999
48
R01: (GEOMEGA INC)
R01: Pyott, Christopher (MA DEPT OF
ENVIRONMENTAL PROTECTION)
RPT/ Report
056-SITE SUPPORT/0563-
State/Tribal Involvement/09.10-
STATE TECHNICAL AND HISTORICAL
RECORDS
UCTL( Uncontrolled)
1
httDs://semspub.epa.gov/src/document/01/247328
247374
REPORT OF GROUNDWATER SAMPLING AND ANALYSIS
IN THE VICINITY OFTHE CALCIUM SULFATE LANDFILL
(COMPREHENSIVE RESPONSE ACTION TRANSMITTAL
FORM AND 07/31/98 TRANSMITTAL LETTER
ATTACHED)
7/30/1998
23
R01: Hanley, Margret (GEI CONSULTANTS INC),
R01: (LAW ENGINEERING AND
ENVIRONMENTALSERVICES)
R01: Pyott, Christopher (MA DEPT OF
ENVIRONMENTAL PROTECTION), R01: (OLIN
CORP)
RPT/ Report
056-SITE SUPPORT/0563-
State/Tribal Involvement/09.10-
STATE TECHNICAL AND HISTORICAL
RECORDS
UCTL( Uncontrolled)
1
httDs://semspub.epa.gov/src/document/01/247374
652695
TOXICOLOGICAL BENCHMARKS FOR SCREENING
CONTAMINANTS OF POTENTIAL CONCERN FOR
EFFECTS ON TERRESTRIAL PLANTS: 1997 REVISION
11/1/1997
123
R01: Etroymson, R A (LOCKHEED MARTIN
ENERGY SYSEMS INC), R01: Suterll,G W
(LOCKHEED MARTIN ENERGY SYSEMS INC),
R01: Will, M E (LOCKHEED MARTIN ENERGY
SYSEMS INC), R01: Wooten, A C (LOCKHEED
MARTIN ENERGY SYSEMS INC)
R01: (US DEPT OF ENERGY)
RPT/ Report
056-SITE SUPPORT/0561-
Administrative Support/17.07-
REFERENCE DOCUMENTS
UCTL( Uncontrolled)
1
httDs://semspub.epa.gov/src/document/Ql/S52695
652696
TOXICOLOGICAL BENCHMARKS FOR CONTAMINANTS
OF POTENTIALCONCERN FOR EFFECTS ON SOILAND
LITTER, INVERTEBRATESAND HETEROTROPHIC
PROCESS: 1997 REVISION
11/1/1997
151
R01: Efroymson, R A (LOCKHEED MARTIN
ENERGY SYSEMS INC), R01: Suterll,G W
(LOCKHEED MARTIN ENERGY SYSEMS INC),
R01: Will, M E (LOCKHEED MARTIN ENERGY
SYSEMS INC)
R01: (US DEPT OF ENERGY)
RPT/ Report
056-SITE SUPPORT/0561-
Administrative Support/17.07-
REFERENCE DOCUMENTS
UCTL( Uncontrolled)
1
httDs://semspub.epa.gov/src/document/Ql/S5269S
157968
EPA RULES OFTHUMB FORSUPERFUND REMEDY
SELECTION
8/1/1997
26
053-REMEDIAL/0531-Remedy
Characterization/A4.2-Record of
Decision/Remedy Selection
UCTL( Uncontrolled)
11
httDs://semspub.epa.gov/src/document/ll/1579S8
158350
EPA Health Effects Assessment Summary Tables FY
1997 Update
7/1/1997
403
053-REMEDIAL/053-
REMEDIAL/0531-Remedy
Characterization/A4.2-Record of
Decision/Remedy Selection
UCTL( Uncontrolled)
11
httDs://semspub.epa.gov/src/document/ll/15835Q
157941
ECOLOGICAL RISKASSESSMENT GUIDANCE FOR
SUPERFUND: PROCESS FOR DESIGNING AND
CONDUCTING ECOLOGICAL RISKASSESSMENTS -
INTERIM FINAL
6/1/1997
239
LAWS /
Laws/Regu lat ions/Gu ida nc
053-REMEDIAL/053-
REMEDIAL/0531-Remedy
Characterization/A4.2-Record of
Decision/Remedy Selection, 058-
PROGRAM SUPPORT/0583-
Regulatory Development/B8.1-
Regulations, Standards & Guidelines
UCTL( Uncontrolled)
1
httos://semspub.epa,gov/src/document/ii/15794i
248913
SUPPLEMENTAL PHASE 2 REPORT [PART 1 OF 2]
(COMPREHENSIVE RESPONSE ACTION TRANSMITTAL
FORM AND PHASE 1 COMPLETION STATEMENT
ATTACHED) [MARGINALIA]
6/1/1997
387
R01: (ABB ENVIRONMENTALSERVICES INC),
R01: (GEOMEGA INC), R01: (PTI
ENVIRONMENTALSERVICES), R01: (SMITH
TECHNOLOGY CORP)
RPT/ Report
055-SITE EVALUATION/O551-Pre-
Remedial Site Evaluation/01.03-SITE
INSPECTION/INVESTIGATION
UCTL( Uncontrolled)
1
httos://semspub.epa,gov/src/document/0i/248913
248914
SUPPLEMENTAL PHASE 2 REPORT-TABLES AND
FIGURES [PART 2 OF 2]
6/1/1997
690
R01: (ABB ENVIRONMENTALSERVICES INC),
R01: (GEOMEGA INC), R01: (PTI
ENVIRONMENTALSERVICES), R01: (SMITH
TECHNOLOGY CORP)
RPT/ Report
055-SITE EVALUATION/O551-Pre-
Remedial Site Evaluation/01.03-SITE
INSPECTION/INVESTIGATION
UCTL( Uncontrolled)
1
httos://semspub.epa,gov/src/document/0i/248914
-------
173
Presumptive Response Strategy and Ex-Situ Treatment
Technologies for Contaminated Groundwater at
CERCLA Sites [EPA # 540/R-96/023; OSWER# 9283.1-
12]
10/1/1996
86
LAWS /
Laws/Regu lat ions/Gu ida nc
058-PROGRAM SUPPORT/0583-
Regulatory Development/B8.4-
Directives and Policy Guidance
Documents
UCTL( Uncontrolled)
11
httDs://semspub.epa.gov/src/document/ll/173
652697
TOXICOLOGICAL BENCHMARKS FOR SCREENING
CONTAMINANTS OF POTENTIAL CONCERN FOR
EFFECTS ON SEDIMENT-ASSOCIATED BIOTA: 1996
REVISION
6/1/1996
52
R01: Hull, R N (LOCKHEED MARTIN ENERGY
SYSEMSINC), R01: Jones, DS(LOCKHEED
MARTIN ENERGY SYSEMS INC), R01: Suterll,G
W (LOCKHEED MARTIN ENERGY SYSEMS INC)
R01: (US DEPTOF ENERGY)
RPT/ Report
056-SITE SUPPORT/0561-
Administrative Support/17.07-
REFERENCE DOCUMENTS
UCTL( Uncontrolled)
1
httDs://semspub.epa.gov/src/document/Ql/652697
66493
FINAL DRAFT GROUNDWATER USE AND VALUE
DETERMINATION GUIDANCE
4/3/1996
28
R01: (US EPA REGION 1)
RPT/ Report
056-SITE SUPPORT/0561-
Administrative Support/17.07-
REFERENCE DOCUMENTS
UCTL( Uncontrolled)
1
httos://semspub. epa.gov/sir/document/01/66493
652660
RISK UPDATES, NUMBER 3
8/1/1995
6
R01: (US EPA REGION 1)
PUB/Publication
053-REMEDIAL/0531-Remedy
Characterization/03.10-
ENDANGERMENT/BASELINE RISK
ASSESSMENTS
UCTL( Uncontrolled)
1
httDs://semspub.epa.gov/src/document/01/65266Q
147
Land Use in the CERCLA remedy Selection Process
5/25/1995
11
LAWS /
Laws/Regu lat ions/Gu ida nc
058-PROGRAM SUPPORT/0583-
Regulatory Development/B8.4-
Directives and Policy Guidance
Documents
UCTL( Uncontrolled)
11
httDs://semspub.epa.gov/src/document/ll/147
50978
RISK UPDATES, NUMBER 2
8/1/1994
23
R01: (US EPA REGION 1)
PUB/Publication
053-REMEDIAL/0531-Remedy
Characterization/03.10-
ENDANGERMENT/BASELINE RISK
ASSESSMENTS
UCTL( Uncontrolled)
1
httDs://semspub.epa.gov/src/document/Ql/5Q978
190664
WILDLIFE EXPOSURE FACTORS HANDBOOK, APPENDIX:
LITERATURE REVIEW DATABASE, VOLUME li OF II
12/1/1993
481
PUB/Publication
058-PROGRAM SUPPORT/0583-
Regulatory Development/B8.1-
Regulations, Standards & Guidelines
UCTL( Uncontrolled)
11
httDs://semspub.epa.gov/src/document/ll/19Q664
190663
WILDLIFE EXPOSURE FACTORS HANDBOOK, VOLUME 1
OF II
12/1/1993
84
PUB/Publication
058-PROGRAM SUPPORT/0583-
Regulatory Development/B8.1-
Regulations, Standards & Guidelines
UCTL( Uncontrolled)
11
httDs://semspub.epa.gov/src/document/ll/19Q663
653701
GUIDELINES FORTHE PROTECTION AND MANAGEMENT
OF AQUATIC SEDIMENT QUALITY IN ONTARIO
8/1/1993
39
R01: (ONTARIO MINISTRY OF ENVIRONMENT
AND ENERGY)
RPT/ Report
056-SITE SUPPORT/0561-
Administrative Suport/17.07-
REFERENCE DOCUMENTS
UCTL( Uncontrolled)
1
httos://semspub.epa,gov/src/document/0i/653701
248902
COMPREHENSIVE SITE ASSESSMENT (SI) - PHASE 2
FIELD INVESTIGATION REPORT, VOLUME 1 OF 3
6/1/1993
302
R01: (CONESTOGA-ROVERS & ASSOCIATES)
R01: (OLIN CORPORATION)
RPT/ Report
055-SITE EVALUATION/O551-Pre-
Remedial Site Evaluation/01.03-SITE
INSPECTION/INVESTIGATION
UCTL( Uncontrolled)
1
httDs://semspub.epa.gov/src/document/Ql/2489Q2
248903
COMPREHENSIVE SITE ASSESSMENT (SI) - PHASE 2
FIELD INVESTIGATION REPORT, VOLUME 2 OF 3
6/1/1993
672
R01: (CONESTOGA-ROVERS & ASSOCIATES)
R01: (OLIN CORPORATION)
RPT/ Report
055-SITE EVALUATION/O551-Pre-
Remedial Site Evaluation/01.03-SITE
INSPECTION/INVESTIGATION
UCTL( Uncontrolled)
1
httDs://semspub.epa.gov/src/document/Ql/2489Q3
248904
COMPREHENSIVE SITE ASSESSMENT (SI) - PHASE 2
FIELD INVESTIGATION REPORT, VOLUME 3 OF 3
6/1/1993
666
R01: (CONESTOGA-ROVERS & ASSOCIATES)
R01: (OLIN CORPORATION)
RPT/ Report
055-SITE EVALUATION/O551-Pre-
Remedial Site Evaluation/01.03-SITE
INSPECTION/INVESTIGATION
UCTL( Uncontrolled)
1
httDs://semspub.epa.gov/src/document/Ql/2489Q4
249005
NO 1 ILL OF RLSPONSIBIILIY LEI ILR REGARDING
02/04/92 INVESTIGATION OF RELEASE OF ALUMINUM
HYDROXIDE AND CHROMIUM (CERTIFIED MAIL RECEIPT
ATTACHED)
5/28/1992
5
R01: Boyle, Timothy J (MA DEPTOF
ENVIRONMENTAL PROTECTION)
R01: Morrow, Stephen (OLIN CORP)
LTR/Letter
052-ENFORCEMENT/0522-
Negotiat ions/10.03-STATE AND
LOCAL ENFORCEMENT RECORDS
UCTL( Uncontrolled)
1
httDs://semspub.epa.gov/src/document/Ql/249QQ5
174509
MEMO REGARDING CONSIDERATIONS IN GROUND-
WATER REMEDIATION AT SUPERFUND SITES AND RCRA
FACILITIES - UPDATE OSWER No. 9283.1-06
5/27/1992
13
MEMO/Memorandum
058-PROGRAM SUPPORT/0583-
Regulatory Development/B8.1-
Regulations, Standards & Guidelines
UCTL( Uncontrolled)
11
httDs://semspub.epa.gov/src/document/ll/1745Q9
156748
A Guide to Principal Threat and Low Level Threat
Wastes Office
11/1/1991
4
053-REMEDIAL/0531-Remedy
Characterization/A4.2-Record of
Decision/Remedy Selection
UCTL( Uncontrolled)
11
httDs://semspub.epa.gov/src/document/ll/156748
191
RISKASSESSMENT GUIDANCE FOR SUPERFUND (RAGS),
VOLUME l-HUMAN HEALTH EVALUATION MANUAL,
PART A
12/1/1989
288
LAWS /
Laws/Regu lat ions/Gu ida nc
058-PROGRAM SUPPORT/0583-
Regulatory Development/B8.1-
Regulations, Standards & Guidelines,
058-PROGRAM SUPPORT/0583-
Regulatory Development/B8.4-
Directives and Policy Guidance
Documents
UCTL( Uncontrolled)
11
httos://semspub.epa,gov/src/document/ll/191
653911
LETTER REGARDING COMPLETION OF CLOSURE,
GYPSUM LANDFILL (STATEMENT OF COMPLIANCE
ATTACHED)
2/1/1988
16
R01: Cameron, Donald (OLIN CORP)
R01: Chalpin, Richard J (MA DEPTOF
ENVIRONMENTAL QUALITY ENGINEERING)
LTR/Letter
056-SITE SUPPORT/0563-
State/Tribal Involvement/09.10-
STATE TECHNICAL AND HISTORICAL
RECORDS
UCTL( Uncontrolled)
1
htt Ds://semsou b.epa.gov/src/docu ment/Ql/653911
646185
LETTER REGARDING TELEPHONE CONVERSATION
ABOUT SAMPLING PARAMETERS
12/30/1987
1
R01: Mcmahon, Thomas C (MA DEPT OF
ENVIRONMENTAL QUALITY ENGINEERING)
R01: Bellotti, Michael J (OLIN CORP)
LTR/Letter
056-SITE SUPPORT/0563-
State/Tribal Involvement/09.10-
STATE TECHNICAL AND HISTORICAL
RECORDS
UCTL( Uncontrolled)
1
httos://semspub.epa,gov/src/document/01/646185
653910
LETTER REGARDING SULFATE SETTLING PONDS
CLOSURE
6/18/1987
1
R01: Norwood, Verrill M (OLIN CORP)
R01: Dore, Peter (MA DIVISION OF ATER
POLLUTION CONTROL)
LTR/Letter
056-SITE SUPPORT/0563-
State/Tribal Involvement/09.10-
STATE TECHNICAL AND HISTORICAL
RECORDS
UCTL( Uncontrolled)
1
httos://semspub.epa,gov/src/document/01/653910
-------
100012146
NATIONAL POLLUTANT DISCHARGE ELIMINATION
SYSTEM (NPDES) PERMIT NO. MA0005304
3/9/1987
7
R01: (MA DEPT OF ENVIRONMENTAL QUALITY
ENGINEERING), R01: (US EPA REGION 1)
LGL/ Legal Instrument
052-ENFORCEMENT/0522-
Negotiat ions/10.03-STATE AND
LOCAL ENFORCEMENT RECORDS
UCTL( Uncontrolled)
1
htt Ds://semsou b.epa.gov/src/docu ment/Ql/10GQ12146
100012147
DRAFT NATIONAL POLLUTANT DISCHARGE
ELIMINATION SYSTEM (NPDES) PERMIT NO.
MA0005304 FACT SHEET
10/8/1986
13
R01: (US EPA REGION 1)
PUB/Publication
052-ENFORCEMENT/0522-
Negotiations/10.03-STATE AND
LOCAL ENFORCEMENT RECORDS
UCTL( Uncontrolled)
1
htt Ds://semsou b.epa.gov/src/docu ment/Ql/10GQ12147
653909
LETTER REGARDING GYPSUM WASTE LANDFILL,
SUMMARY OF WORK FOR PLACEMENT OF CALCIUM
SULFATE
10/7/1986
6
R01: Mcbrien, Ronald J (OLIN CORP)
R01: Adams, David (MA DEPTOF
ENVIRONMENTAL QUALITY ENGINEERING)
LTR/Letter
056-SITE SUPPORT/0563-
State/Tribal Involvement/09.10-
STATE TECHNICAL AND HISTORICAL
RECORDS
UCTL( Uncontrolled)
1
htt Ds://semsoub.epa.gov/src/document/Gl/6539G9
248870
PHASE 1 SITE INSPECTION (SI) REPORT [MARGINALIA
AND HIGHLIGHTS]
9/1/1986
321
R01: (WEHRAN ENGINEERING CORP)
RPT/ Report
055-SITE EVALUATION/O551-Pre-
Remedial Site Evaluation/01.03-SITE
INSPECTION/INVESTIGATION
UCTL( Uncontrolled)
1
htt Ds://semsoub.epa.gov/src/document/Gl/24887G
646153
HYDROGEOLOGIC INVESTIGATION (02/25/1982
TRANSMITTAL LETTERATTACHED)
2/1/1982
149
R01: (MALCOM PIRNIE INC)
R01: (OLIN CHEMICAL CORP)
RPT/ Report
053-REMEDIAL/0531-Remedy
Characterization/03.04-INTERIM
DELIVERABLES (Rl)
UCTL( Uncontrolled)
1
httos://semspub.epa,gov/src/document/01/S4S153
476282
SITE INSPECTION (SI) REPORT
12/5/1980
72
R01: Cook, David K(ECOLOGY&
ENVIRONMENT INC)
R01: Hackler, John F (US EPA REGION 1 -
OFFICE OF UNCONTROLLED WASTE SITES)
RPT/ Report
055-SITE EVALUATION/O551-Pre-
Remedial Site Evaluation/01.03-SITE
INSPECTION/INVESTIGATION
UCTL( Uncontrolled)
1
htt Ds://semsoub.epa.gov/src/document/Gl/476282
653908
SITE PLAN, PROPOSED DEWATERED CAKE LANDFILL,
NATIONAL POLYCHEMICALS INC
8/31/1973
6
R01: (DANA PERKINS AND SONS
INCORPORATED)
FIG / Figure/Map/Drawing
056-SITE SUPPORT/0563-
State/Tribal Involvement/09.10-
STATE TECHNICAL AND HISTORICAL
RECORDS
UCTL( Uncontrolled)
1
htt Ds://semsoub.epa.gov/src/document/Gl/6539G8
646187
POLLUTION CONTROL STUDY FOR NATIONAL
POLYCHEMICALS INC
8/21/1969
19
R01: (BADGERCO)
RPT/ Report
056-SITE SUPPORT/0563-
State/Tribal Involvement/09.10-
STATE TECHNICAL AND HISTORICAL
RECORDS
UCTL( Uncontrolled)
1
httos://semspub.epa,gov/src/document/01/646187
475926
SCREENING QUICK REFERENCE TABLES (SQUIRTS)
Undated
34
R01: (NATIONAL OCEANIC AND ATMOSPHERIC
ADMINISTRATION (NOAA))
NOTE / Notes
055-SITE EVALUATION/O551-Pre-
Remedial Site Evaluation/01.18-SITE
ASSESSMENT SUPPORT
DOCUMENTATION
UCTL( Uncontrolled)
1
httDs://semspub.epa.gov/src/document/Ql/475926
483478
[REDACTED] SPREADSHEET WITH RESIDENTIAL
DRINKING WATER/HOUSEHOLD WATER USE CANCER
RISK 30 YEAR EXPOSURE BASED ON 11/2009 EPA
SAMPLING RESULTS
Undated
3
R01: Ford, Heather M (NOBIS ENGINEERING
INC)
R01: Dilorenzo, James (US EPA REGION 1)
ADD/Analytical Data
Document
054-REMOVAL/0541-Removal
Responses/02.03-SAMPLING &
ANALYSIS DATA (REMOVAL
RESPONSE)
UCTL( Uncontrolled)
1
httDs://semspub.epa.gov/src/document/Ql/483478
483479
[REDACTED] SPREADSHEET WITH RESIDENTIAL
DRINKING WATER/HOUSEHOLD WATER USE CANCER
RISK 30 YEAR EXPOSURE BASED ON 11/2009 EPA
SAMPLING RESULTS
Undated
3
R01: Ford, Heather M (NOBIS ENGINEERING
INC)
R01: Dilorenzo, James (US EPA REGION 1)
ADD/Analytical Data
Document
054-REMOVAL/0541-Removal
Responses/02.03-SAMPLING &
ANALYSIS DATA (REMOVAL
RESPONSE)
UCTL( Uncontrolled)
1
httDs://semspub.epa.gov/src/document/Ql/483479
483480
[REDACTED] SPREADSHEET FOR RESIDENTIAL DRINKING
WATER/HOUSEHOLD WATER USE CANCER RISK 70
YEAR EXPOSURE BASED ON 11/2009 EPA SAMPLING
RESULTS
Undated
3
R01: Ford, Heather M (NOBIS ENGINEERING
INC)
R01: Dilorenzo, James (US EPA REGION 1)
ADD/Analytical Data
Document
054-REMOVAL/0541-Removal
Responses/02.03-SAMPLING &
ANALYSIS DATA (REMOVAL
RESPONSE)
UCTL( Uncontrolled)
1
httDs://semspub.epa.gov/src/document/Ql/48348Q
483481
[REDACTED] SPREADSHEET WITH RESIDENTIAL
DRINKING WATER/HOUSEHOLD WATER USE CANCER
RISK 70 YEAR EXPOSURE BASED ON 11/2009 EPA
SAMPLING RESULTS
Undated
3
R01: Ford, Heather M (NOBIS ENGINEERING
INC)
R01: Dilorenzo, James (US EPA REGION 1)
ADD/Analytical Data
Document
054-REMOVAL/0541-Removal
Responses/02.03-SAMPLING &
ANALYSIS DATA (REMOVAL
RESPONSE)
UCTL( Uncontrolled)
1
httos://semspub.epa,gov/src/document/01/48348i
483482
[REDACTED] SPREADSHEET WITH RESIDENTIAL
DRINKING WATER/HOUSEHOLD WATER USE CANCER
RISK30 YEAR EXPOSURE
Undated
6
R01: Woods, Cynthia (AVATAR
ENVIRONMENTAL)
R01: Sugatt, Richard (US EPA REGION 1)
ADD/Analytical Data
Document
054-REMOVAL/0541-Removal
Responses/02.03-SAMPLING &
ANALYSIS DATA (REMOVAL
RESPONSE)
UCTL( Uncontrolled)
1
httDs://semspub.epa.gov/src/document/Ql/483482
483483
[REDACTED] SPREADSHEET WITH RESIDENTIAL
DRINKING WATER/HOUSEHOLD WATER USE CANCER
RISK30 YEAR EXPOSURE
Undated
3
R01: Woods, Cynthia (AVATAR
ENVIRONMENTAL)
R01: Sugatt, Richard (US EPA REGION 1)
ADD/Analytical Data
Document
054-REMOVAL/0541-Removal
Responses/02.03-SAMPLING &
ANALYSIS DATA (REMOVAL
RESPONSE)
UCTL( Uncontrolled)
1
httDs://semspub.epa.gov/src/document/Ql/483483
483484
[REDACTED] SPREADSHEET WITH RESIDENTIAL
DRINKING WATER/HOUSEHOLD WATER USE CANCER
RISK70 YEAR EXPOSURE
Undated
6
R01: Woods, Cynthia (AVATAR
ENVIRONMENTAL)
R01: Sugatt, Richard (US EPA REGION 1)
ADD/Analytical Data
Document
054-REMOVAL/0541-Removal
Responses/02.03-SAMPLING &
ANALYSIS DATA (REMOVAL
RESPONSE)
UCTL( Uncontrolled)
1
httDs://semspub.epa.gov/src/document/Ql/483484
483485
[REDACTED] SPREADSHEET WITH RESIDENTIAL
DRINKING WATER/HOUSEHOLD WATER USE CANCER
RISK70 YEAR EXPOSURE
Undated
3
R01: Woods, Cynthia (AVATAR
ENVIRONMENTAL)
R01: Sugatt, Richard (US EPA REGION 1)
ADD/Analytical Data
Document
054-REMOVAL/0541-Removal
Responses/02.03-SAMPLING &
ANALYSIS DATA (REMOVAL
RESPONSE)
UCTL( Uncontrolled)
1
httDs://semspub.epa.gov/src/document/Ql/483485
483486
[REDACTED] SPREADSHEET WITH RESIDENTIAL
DRINKING WATER/HOUSEHOLD WATER USE CANCER
RISK 30 YEAR EXPOSURE BASED ON EPA SAMPLING
RESULTS
Undated
3
R01: Woods, Cynthia (AVATAR
ENVIRONMENTAL)
R01: Sugatt, Richard (US EPA REGION 1)
ADD/Analytical Data
Document
054-REMOVAL/0541-Removal
Responses/02.03-SAMPLING &
ANALYSIS DATA (REMOVAL
RESPONSE)
UCTL( Uncontrolled)
1
httDs://semspub.epa.gov/src/document/Ql/483486
483487
[REDACTED] SPREADSHEET WITH RESIDENTIAL
DRINKING WATER/HOUSEHOLD WATER USE CANCER
RISK 30 YEAR EXPOSURE BASED ON OLIN COPR
SAMPLING RESULTS
Undated
3
R01: Woods, Cynthia (AVATAR
ENVIRONMENTAL)
R01: Sugatt, Richard (US EPA REGION 1)
ADD/Analytical Data
Document
054-REMOVAL/0541-Removal
Responses/02.03-SAMPLING &
ANALYSIS DATA (REMOVAL
RESPONSE)
UCTL( Uncontrolled)
1
httDs://semspub.epa.gov/src/document/Ql/483487
483488
[REDACTED] SPREADSHEET WITH RESIDENTIAL
DRINKING WATER/HOUSEHOLD WATER USE CANCER
RISK 30 YEAR EXPOSURE BASED ON OLIN COPR
SAMPLING RESULTS
Undated
3
R01: Woods, Cynthia (AVATAR
ENVIRONMENTAL)
R01: Sugatt, Richard (US EPA REGION 1)
ADD/Analytical Data
Document
054-REMOVAL/0541-Removal
Responses/02.03-SAMPLING &
ANALYSIS DATA (REMOVAL
RESPONSE)
UCTL( Uncontrolled)
1
httDs://semspub.epa.gov/src/document/Ql/483488
-------
483489
[REDACTED] SPREADSHEET WITH RESIDENTIAL
DRINKING WATER/HOUSEHOLD WATER USE CANCER
RISK 30 YEAR EXPOSURE BASED ON EPA SAMPLING
RESULTS
Undated
3
R01: Woods, Cynthia (AVATAR
ENVIRONMENTAL)
R01: Sugatt, Richard (US EPA REGION 1)
ADD/Analytical Data
Document
054-REMOVAL/0541-Removal
Responses/02.03-SAMPLING &
ANALYSIS DATA (REMOVAL
RESPONSE)
UCTL( Uncontrolled)
1
httDs://semspub.epa.gov/src/document/Gl/483489
483490
[REDACTED] SPREADSHEET WITH RESIDENTIAL
DRINKING WATER/HOUSEHOLD WATER USE CANCER
RISK 70 YEAR EXPOSURE BASED ON EPA SAMPLING
RESULTS
Undated
3
R01: Woods, Cynthia (AVATAR
ENVIRONMENTAL)
R01: Sugatt, Richard (US EPA REGION 1)
ADD/Analytical Data
Document
054-REMOVAL/0541-Removal
Responses/02.03-SAMPLING &
ANALYSIS DATA (REMOVAL
RESPONSE)
UCTL( Uncontrolled)
1
httDs://semspub.epa.gov/src/document/Gl/48349G
483491
[REDACTED] SPREADSHEET WITH RESIDENTIAL
DRINKING WATER/HOUSEHOLD WATER USE CANCER
RISK 70 YEAR EXPOSURE BASED ON OLIN CORP
SAMPLING RESULTS
Undated
3
R01: Woods, Cynthia (AVATAR
ENVIRONMENTAL)
R01: Sugatt, Richard (US EPA REGION 1)
ADD/Analytical Data
Document
054-REMOVAL/0541-Removal
Responses/02.03-SAMPLING &
ANALYSIS DATA (REMOVAL
RESPONSE)
UCTL( Uncontrolled)
1
httos://semspub.epa,gov/src/document/Gl/483491
483492
[REDACTED] SPREADSHEET WITH RESIDENTIAL
DRINKING WATER/HOUSEHOLD WATER USE CANCER
RISK 70 YEAR EXPOSURE BASED ON OLIN CORP
SAMPLING RESULTS
Undated
3
R01: Woods, Cynthia (AVATAR
ENVIRONMENTAL)
R01: Sugatt, Richard (US EPA REGION 1)
ADD/Analytical Data
Document
054-REMOVAL/0541-Removal
Responses/02.03-SAMPLING &
ANALYSIS DATA (REMOVAL
RESPONSE)
UCTL( Uncontrolled)
1
httDs://semspub.epa.gov/src/document/Gl/483492
483493
[REDACTED] SPREADSHEET WITH RESIDENTIAL
DRINKING WATER/HOUSEHOLD WATER USE CANCER
RISK 70 YEAR EXPOSURE BASED ON EPA SAMPLING
RESULTS
Undated
3
R01: Woods, Cynthia (AVATAR
ENVIRONMENTAL)
R01: Sugatt, Richard (US EPA REGION 1)
ADD/Analytical Data
Document
054-REMOVAL/0541-Removal
Responses/02.03-SAMPLING &
ANALYSIS DATA (REMOVAL
RESPONSE)
UCTL( Uncontrolled)
1
htt Ds://semsou b.epa.gov/src/docu ment/01/483493
483524
HEALTH EFFECTS REGARDING N-
NITROSODIMETHYLAMINE(NDMA)
Undated
50
RPT/ Report
054-REMOVAL/0541-Removal
Responses/02.02-REMOVAL
RESPONSE REPORTS
UCTL( Uncontrolled)
1
httBs://semspub.epa.gov/src/document/01/483524
483525
POTENTIAL HUMAN EXPOSURE REGARDING N-
NITROSODIMETHYLAMINE(NDMA)
Undated
12
RPT/ Report
054-REMOVAL/0541-Removal
Responses/02.02-REMOVAL
RESPONSE REPORTS
UCTL( Uncontrolled)
1
httDs://semspub.epa.gov/src/document/01/483525
483526
PUBLIC HEALTH STATEMENT REGARDING N-
NITROSODIMETHYLAMINE(NDMA)
Undated
7
RPT/ Report
054-REMOVAL/0541-Removal
Responses/02.02-REMOVAL
RESPONSE REPORTS
UCTL( Uncontrolled)
1
httDs://semspub.epa.gov/src/document/Ql/483526
483527
REGULATIONS ANDADVISORIES REGARDING N-
NITROSODIMETHYLAMINE(NDMA)
Undated
3
RPT/ Report
054-REMOVAL/0541-Removal
Responses/02.02-REMOVAL
RESPONSE REPORTS
UCTL( Uncontrolled)
1
httDs://semspub.epa.gov/src/document/Ql/483527
483558
RESIDENTIAL DRINKING WATER INGESTION CANCER
RISK BASED CONCENTRATION FOR 1E-04 CANCER RISK
AND 70 YEAR EXPOSURE
Undated
1
ADD/Analytical Data
Document
054-REMOVAL/0541-Removal
Responses/02.03-SAMPLING &
ANALYSIS DATA (REMOVAL
RESPONSE)
UCTL( Uncontrolled)
1
httDs://semspub.epa.gov/src/document/Ql/483558
483559
RESIDENTIAL DERMALCONTACT NON CANCER RISK
CHILD EXPOSURE
Undated
10
ADD/Analytical Data
Document
054-REMOVAL/0541-Removal
Responses/02.03-SAMPLING &
ANALYSIS DATA (REMOVAL
RESPONSE)
UCTL( Uncontrolled)
1
httDs://semspub.epa.gov/src/document/Ql/483559
484778
RESIDENTIAL DRINKING WATER INGESTION CANCER
RISKOF 9.4 NG/L OF N-NITROSODIMETHYLAMINE
(NDMA) ASSUMING MUTAGENIC MODE OF
CARCINOGENESIS 70 YEAR EXPOSURE
Undated
3
ADD/Analytical Data
Document
054-REMOVAL/0541-Removal
Responses/02.03-SAMPLING &
ANALYSIS DATA (REMOVAL
RESPONSE)
UCTL( Uncontrolled)
1
httDs://semspub.epa.gov/src/document/Ql/484778
484782
RESIDENTIAL DRINKING WATER INGESTION CANCER
RISKOF 14 NG/L OF N-NITROSODIMETHYLAMINE
(NDMA) ASSUMING MUTAGENIC MODE OF
CARCINOGENESIS 70 YEAR EXPOSURE
Undated
2
ADD/Analytical Data
Document
054-REMOVAL/0541-Removal
Responses/02.03-SAMPLING &
ANALYSIS DATA (REMOVAL
RESPONSE)
UCTL( Uncontrolled)
1
httDs://semspub.epa.gov/src/document/Ql/484782
484783
PROPOSED DRINKING WATERANALYTES [HIGHLIGHTS]
Undated
3
ADD/Analytical Data
Document
054-REMOVAL/0541-Removal
Responses/02.03-SAMPLING &
ANALYSIS DATA (REMOVAL
RESPONSE)
UCTL( Uncontrolled)
1
httDs://semspub.epa.gov/src/document/Ql/484783
484784
PROPOSED DRINKING WATERANALYTES [HIGHLIGHTS]
Undated
2
ADD/Analytical Data
Document
054-REMOVAL/0541-Removal
Responses/02.03-SAMPLING &
ANALYSIS DATA (REMOVAL
RESPONSE)
UCTL( Uncontrolled)
1
httDs://semspub.epa.gov/src/document/Ql/484784
484787
TAP SAMPLING OF RESIDENTIAL WELLS PROCEDURE
Undated
1
ADD/Analytical Data
Document
054-REMOVAL/0541-Removal
Responses/02.03-SAMPLING &
ANALYSIS DATA (REMOVAL
RESPONSE)
UCTL( Uncontrolled)
1
httDs://semspub.epa.gov/src/document/Ql/484787
485014
[REDACTED] EXCERPT REGARDING SAMPLING OF
PRIVATE WELLS
Undated
1
RPT/ Report
054-REMOVAL/0541-Removal
Responses/02.01-
CORRESPONDENCE (REMOVAL
RESPONSE)
UCTL( Uncontrolled)
1
httos://semspub.epa,gov/src/document/01/485G14
485016
[REDACTED] RESIDENTIAL PROPERTIES WITH PRIVATE
WELLS PROPOSED FOR SAMPLING (SUPPORTING
DOCUMENTATION ATTACHED)
Undated
4
LST/ List/Index
054-REMOVAL/0541-Removal
Responses/02.03-SAMPLING &
ANALYSIS DATA (REMOVAL
RESPONSE)
UCTL( Uncontrolled)
1
httos://semspub.epa,gov/src/document/Gl/48501S
485017
[REDACTED] TABLE C-20: USABLE EXISTING
GROUNDWATER DATA SUMMARY - PRIVATE WELLS
[MARGINALIA]
Undated
10
ADD/Analytical Data
Document
054-REMOVAL/0541-Removal
Responses/02.03-SAMPLING &
ANALYSIS DATA (REMOVAL
RESPONSE)
UCTL( Uncontrolled)
1
httos://semspub.epa,gov/src/document/01/485017
485018
[REDACTED] TABLE C-20: USABLE EXISTING
GROUNDWATER DATA SUMMARY - PRIVATE WELLS
Undated
70
ADD/Analytical Data
Document
054-REMOVAL/0541-Removal
Responses/02.03-SAMPLING &
ANALYSIS DATA (REMOVAL
RESPONSE)
UCTL( Uncontrolled)
1
httos://semspub.epa,gov/src/document/Gi/485018
-------
485046
PROPOSED DRINKING WELLANALYTES
Undated
1
ADD/Analytical Data
Document
054-REMOVAL/0541-Removal
Responses/02.03-SAMPLING &
ANALYSIS DATA (REMOVAL
RESPONSE)
UCTL( Uncontrolled)
1
htt Ds://semsoub.epa.gov/src/document/Gl/485G4S
485048
LETTER REGARDING PRIVATE DRINKING WATER WELL
[BEST AVAILABLE COPY]
Undated
1
R01: Newhouse, Shelly (WILMINGTON (MA)
BOARD OF HEALTH)
LTR/Letter
054-REMOVAL/0541-Removal
Responses/02.01-
CORRESPONDENCE (REMOVAL
RESPONSE)
UCTL( Uncontrolled)
1
htt os://semspub.epa.gov/src/document/Gl/485G48
485064
PROPOSED ADDITIONAL DRINKING WELLANALYTES
[REVISED]
Undated
2
ADD/Analytical Data
Document
054-REMOVAL/0541-Removal
Responses/02.03-SAMPLING &
ANALYSIS DATA (REMOVAL
RESPONSE)
UCTL( Uncontrolled)
1
htt Ds://semsoub.epa.gov/src/document/Gl/485GS4
485067
PROPOSED ADDITIONAL DRINKING WELLANALYTES
Undated
2
ADD/Analytical Data
Document
054-REMOVAL/0541-Removal
Responses/02.03-SAMPLING &
ANALYSIS DATA (REMOVAL
RESPONSE)
UCTL( Uncontrolled)
1
htt Ds://semsoub.epa.gov/src/document/Gl/485GS7
485075
PRIVATE WELL SURVEY QUESTIONS
Undated
2
R01: (US EPA REGION 1)
FRM / Form
054-REMOVAL/0541-Removal
Responses/02.01-
CORRESPONDENCE (REMOVAL
RESPONSE)
UCTL( Uncontrolled)
1
htt Ds://semspub.epa.gov/src/document/Ql/485Q75
485093
PROPOSED ADDITIONAL DRINKING WELLANALYTES
[MARGINALIA]
Undated
1
ADD/Analytical Data
Document
054-REMOVAL/0541-Removal
Responses/02.03-SAMPLING &
ANALYSIS DATA (REMOVAL
RESPONSE)
UCTL( Uncontrolled)
1
htt Ds://semsoub.epa.gov/src/document/Ql/485Q93
485095
MAP: EXTENT OF GROUNDWATER IMPACT
[MARGINALIA]
Undated
1
R01:(MACTEC ENGINEERING AND
CONSULTING INC)
FIG / Figure/Map/ Drawing
056-SITE SUPPORT/0561-
Administrative Support/17.04-NON-
PRINT MATERIALS
UCTL( Uncontrolled)
1
htt Ds://semsoub.epa.gov/src/document/Ql/485Q95
485099
[REDACTED] RESIDENTIAL PROPERTIES WITH PRIVATE
WELLS PROPOSED FOR SAMPLING [MARGINALIA]
Undated
1
LST/ List/Index
054-REMOVAL/0541-Removal
Responses/02.03-SAMPLING &
ANALYSIS DATA (REMOVAL
RESPONSE)
UCTL( Uncontrolled)
1
htt Ds://semsoub.epa.gov/src/document/Ql/485Q99
485501
[REDACTED] PROPOSED DRINKING WELLANALYTES
[MARGINALIA]
Undated
2
ADD/Analytical Data
Document
054-REMOVAL/0541-Removal
Responses/02.03-SAMPLING &
ANALYSIS DATA (REMOVAL
RESPONSE)
UCTL( Uncontrolled)
1
httos://semspub.epa,gov/src/document/01/485501
485515
[REDACTED] RESIDENTIAL DRINKING
WATER/HOUSEHOLD WATER USE CANCER RISKS
Undated
2
ADD/Analytical Data
Document
054-REMOVAL/0541-Removal
Responses/02.03-SAMPLING &
ANALYSIS DATA (REMOVAL
RESPONSE)
UCTL( Uncontrolled)
1
httos://semspub.epa,gov/src/document/01/485515
485517
[REDACTED] TABLE 3: SUMMARY OF RECOMMENDED
PRIVATE WELL SAMPLING
Undated
4
ADD/Analytical Data
Document
054-REMOVAL/0541-Removal
Responses/02.03-SAMPLING &
ANALYSIS DATA (REMOVAL
RESPONSE)
UCTL( Uncontrolled)
1
httos://semspub.epa,gov/src/document/01/48551?
485527
[REDACTED] RESIDENTIAL DRINKING
WATER/HOUSEHOLD WATER USE CANCER RISKS
[HIGHLIGHTS]
Undated
1
ADD/Analytical Data
Document
054-REMOVAL/0541-Removal
Responses/02.03-SAMPLING &
ANALYSIS DATA (REMOVAL
RESPONSE)
UCTL( Uncontrolled)
1
htt Ds://semsoub.epa.gov/src/document/Ql/485527
485550
[REDACTED] SPREADSHEET WITH COMPARISON OF
WELL MONITORING DATA (AUGUST 2010) WITH EPA
REGIONAL SCREENING LEVELS OFTAPWATER
Undated
3
ADD/Analytical Data
Document
054-REMOVAL/0541-Removal
Responses/02.03-SAMPLING &
ANALYSIS DATA (REMOVAL
RESPONSE)
UCTL( Uncontrolled)
1
htt Ds://semsoub.epa.gov/src/document/Ql/48555Q
485632
[REDACTED] GIS PRIVATE WELLS
Undated
2
LST/ List/Index
054-REMOVAL/0541-Removal
Responses/02.01-
CORRESPONDENCE (REMOVAL
RESPONSE)
UCTL( Uncontrolled)
1
htt Ds://semsoub.epa.gov/src/document/Ql/485S32
485669
[REDACTED] SECOND SAMPLING EVENT OF
WILMINGTON RESIDENTIAL WELLS - 07/29/2010 -
08/23/2010
Undated
2
ADD/Analytical Data
Document
054-REMOVAL/0541-Removal
Responses/02.03-SAMPLING &
ANALYSIS DATA (REMOVAL
RESPONSE)
UCTL( Uncontrolled)
1
htt Ds://semsoub.epa.gov/src/document/Ql/485S69
485670
[REDACTED] SPREADSHEET WITH RESIDENTIAL
DRINKING WATER/HOUSEHOLD WATER USE CANCER
RISK 30 YEAR EXPOSURE BASED ON 11/2009 EPA
SAMPLING RESULTS
Undated
3
R01: Ford, Heather M (NOBIS ENGINEERING
INC)
R01: Dilorenzo, James (US EPA REGION 1)
ADD/Analytical Data
Document
054-REMOVAL/0541-Removal
Responses/02.03-SAMPLING &
ANALYSIS DATA (REMOVAL
RESPONSE)
UCTL( Uncontrolled)
1
htt Ds://semsoub.epa.gov/src/document/Ql/485S7Q
485671
[REDACTED] SPREADSHEET WITH RESIDENTIAL
DRINKING WATER/HOUSEHOLD WATER USE CANCER
RISKS
Undated
2
R01: Ford, Heather M (NOBIS ENGINEERING
INC)
R01: Dilorenzo, James (US EPA REGION 1)
ADD/Analytical Data
Document
054-REMOVAL/0541-Removal
Responses/02.03-SAMPLING &
ANALYSIS DATA (REMOVAL
RESPONSE)
UCTL( Uncontrolled)
1
httDs://semspub.epa,gov/src/document/Ql/485S71
485672
[REDACTED] LIST OF PROPERTIES WITH RESIDENTIAL
WELLS
Undated
2
LST/ List/Index
054-REMOVAL/0541-Removal
Responses/02.01-
CORRESPONDENCE (REMOVAL
RESPONSE)
UCTL( Uncontrolled)
1
htt Ds://semsoub.epa.gov/src/document/Ql/485S72
485674
[REDACTED] RESIDENTIAL DRINKING
WATER/HOUSEHOLD WATER USE CANCER RISKS
Undated
2
R01: Woods, Cynthia (AVATAR
ENVIRONMENTAL)
R01: Sugatt, Richard (US EPA REGION 1)
ADD/Analytical Data
Document
054-REMOVAL/0541-Removal
Responses/02.03-SAMPLING &
ANALYSIS DATA (REMOVAL
RESPONSE)
UCTL( Uncontrolled)
1
htt Ds://semsoub.epa.gov/src/document/Ql/485S74
-------
646166
NOTES ON HISTORIC WASTE DISPOSAL AT SITE
Undated
30
R01: (MA DEPT OF ENVIRONMENTAL
PROTECTION)
RPT/ Report
056-SITE SUPPORT/0563-
State/Tribal Involvement/09.10-
STATE TECHNICAL AND HISTORICAL
RECORDS
UCTL( Uncontrolled)
1
httDs://semsDub.epa,aov/src/document/01/S4S166
70001573
RESIDENTIAL DRINKING WATER INGESTION CANCER
RISK-BASED CONCENTRATION FOR IE-04 CANCER RISK
AND 70 YEAR EXPOSURE
Undated
1
ADD/Analytical Data
Document
054-REMOVAL/0541-Removal
Responses/02.03-SAMPLING &
ANALYSIS DATA (REMOVAL
RESPONSE)
UCTL( Uncontrolled)
1
httos://semsDub.epa,gov/srt/document/01/?00015?3
70001583
RESIDENTIAL DERMALCONTACT NON-CANCER RISK
RESIDENTIAL CHILD EXPOSURE (NATIVE FILE
ATTACHED)
Undated
1
R01: Ford, Heather M (NOBIS ENGINEERING
INC)
R01: Dilorenzo, James (US EPA REGION 1)
ADD/Analytical Data
Document
054-REMOVAL/0541-Removal
Responses/02.03-SAMPLING &
ANALYSIS DATA (REMOVAL
RESPONSE)
UCTL( Uncontrolled)
1
httos://semsDub.epa,gov/srt/document/01/?0001583
70001585
RESIDENTIAL INGESTION NON-CANCER RISK
RESIDENTIAL CHILD EXPOSURE (NATIVE FILE
ATTACHED)
Undated
1
ADD/Analytical Data
Document
054-REMOVAL/0541-Removal
Responses/02.03-SAMPLING &
ANALYSIS DATA (REMOVAL
RESPONSE)
UCTL( Uncontrolled)
1
httos://semsDub.epa,gov/srt/document/01/?0001585
70001620
PROPOSED DRINKING WELL ANALYTES (NATIVE FILE
ATTACHED)
Undated
1
ADD/Analytical Data
Document
054-REMOVAL/0541-Removal
Responses/02.03-SAMPLING &
ANALYSIS DATA (REMOVAL
RESPONSE)
UCTL( Uncontrolled)
1
httos://semsDub.epa,gov/srt/document/01/?0001S20
70001633
PROPOSED DRINKING WELL ANALYTES (NATIVE FILE
ATTACHED)
Undated
1
ADD/Analytical Data
Document
054-REMOVAL/0541-Removal
Responses/02.03-SAMPLING &
ANALYSIS DATA (REMOVAL
RESPONSE)
UCTL( Uncontrolled)
1
httos://semsDub.epa,gov/srt/document/01/?0001S33
70001652
PROPOSED ADDITIONAL DRINKING WELL ANALYTES
(NATIVE FILEATTACHED)
Undated
1
ADD/Analytical Data
Document
054-REMOVAL/0541-Removal
Responses/02.03-SAMPLING &
ANALYSIS DATA (REMOVAL
RESPONSE)
UCTL( Uncontrolled)
1
httos://semsDub.epa,gov/srt/document/01/?0001S52
70001653
FIELD AND QUALITY CONTROL SAMPLE SUMMARY
(TABLE ON SAMPLE CONTAINERS, PRESERVATION AND
HOLDING TIME ATTACHED)
Undated
2
R01: (NOBIS ENGINEERING INC)
ADD/Analytical Data
Document
054-REMOVAL/0541-Removal
Responses/02.03-SAMPLING &
ANALYSIS DATA (REMOVAL
RESPONSE)
UCTL( Uncontrolled)
1
httos://semsDub.epa,gov/srt/document/01/?0001S53
------- |