FIVE-YEAR REVIEW REPORT FOR
HATHEWAY & PATTERSON SUPERFUND SITE
BRISTOL COUNTY, MASSACHUSETTS
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Prepared by
U.S. Environmental Protection Agency
Region 1, New England
Boston, Massachusetts
Z.
T. Owens, III, Division Director Date
(Office of Site Remediation and Restoration
U.S. EPA, New England
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TABLE OF CONTENTS
EXECUTIVE SUMMARY ES-1
SECTION 1.0 INTRODUCTION 1-1
SECTION 2.0 SITE CHRONOLOGY 2-1
SECTION 3.0 BACKGROUND 3-1
3.1 PHYSICAL CHARACTERISTICS AND LAND AND RESOURCE USE 3-1
3.2 HISTORY OF CONTAMINATION 3-2
3.3 INITIAL RESPONSE 3-2
3.4 BASIS FOR TAKING ACTION 3-3
SECTION 4.0 REMEDIAL ACTIONS 4-1
4.1 REMEDY SELECTION 4-1
4.2 REMEDY IMPLEMENTATION 4-2
4.3 OPERATION AND MAINTENANCE 4-3
SECTION 5.0 PROGRESS SINCE THE LAST FIVE YEAR REVIEW 5-1
SECTION 6.0 FIVE-YEAR REVIEW PROCESS 6-1
6.1 COMMUNITY NOTIFICATION AND INVOLVEMENT 6-1
6.2 DOCUMENT REVIEW 6-1
6.3 DATA REVIEW 6-1
6.3.1 Hydrogeology 6-1
6.3.2 Groundwater Monitoring Results 6-3
6.3.3 Sediment Monitoring Results 6-4
6.3.4 Fish Survey 6-4
6.4 SITE INSPECTIONS 6-4
6.5 INTERVIEWS 6-5
SECTION 7.0 TECHNICAL ASSESSMENT 7-1
7.1 Question A: Is the remedy functioning as intended by the decision documents? 7-1
7.2 Question B: Are the exposure assumptions, toxicity data, cleanup levels, and remedial action
objectives (RAOs) used at the time of remedy selection still valid? 7-1
7.2.1 Review of Human Health Risk Assessment 7-1
7.2.2 Review of Ecological Risk Assessment 7-6
7.2.3 ARARs Review 7-8
7.3 Question C: Has any other information come to light that could call into question the
protectiveness of the remedy? 7-9
SECTION 8.0 ISSUES 8-1
SECTION 9.0 RECOMMENDATIONS AND FOLLOW-UP ACTIONS 9-1
SECTION 10.0 PROTECTIVENESS STATEMENTS 10-2
SECTION 11.0 NEXT FIVE-YEAR REVIEW 11-1
TABLES
Table 1: Chronology of Site Events
Table 2: Comparison of 2005 and 2014 Oral Reference Doses and Oral Cancer Slope Factors for
Compounds of Potential Concern
Table 3: Soil Cleanup Levels (Commercial/Open Space)
Table 4: Issues
Table 5: Recommendations and Follow-Up Actions
APPENDICES
APPENDIX A: Figures
APPENDIX B: List of Documents Reviewed and References
APPENDIX C: Analytical Data
APPENDIX D: MSR Technical Memorandum
APPENDIX E: Interview Record Forms
APPENDIX F: Risk Calculations
APPENDIX G: ARARs Review Tables
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LIST OF ACRONYMS AND ABBREVIATIONS
ACRONYM
DEFINITION
AAL
Allowable Ambient Air Limits
ACGIH
American Conference of Governmental Industrial Hygienists
ARAR
Applicable or Relevant and Appropriate Requirement
AST
Above Ground Storage Tank
AUL
Activity and Use Limitation
AWQC
Ambient Water Quality Criteria
BERA
Baseline Ecological Risk Assessment
BLM
Biotic Ligand Model
BOH
Board of Health
CCA
Chromated copper arsenate
CERCLA
Comprehensive Environmental Response, Compensation, and Liability Act, 42
USC ง 9601 et seq.
CFR
Code of Federal Regulations
CIC
Community Involvement Coordinator
COC
Contaminant of Concern
COPC
Contaminant of Potential Concern
CWA
Clean Water Act
DA
Domestic Auxiliary
DEQE
Massachusetts Department of Environmental Quality Engineering
EPA
Environmental Protection Agency (U.S. EPA - Region 1)
EPC
Exposure Point Concentration
ESD
Explanation of Significant Differences
FCAP
Fluoro-chrome-arsenate-phenol
FIFRA
Federal Insecticide, Fungicide, and Rodenticide Act of 1947
FS
Feasibility Study
GERE
Grant of Environmental Restrictions and Easements
HHRA
Human Health Risk Assessment
HI
Hazard Index
HQ
Hazard Quotient
ICs
Institutional Controls
ICA
Industrial/Commercial Auxiliary
IRIS
Integrated Risk Information System
LEL
Lowest Effect Level
LI
Limited Industrial
LNAPL
Light Non-Aqueous Phase Liquid
M&E
Metcalf & Eddy
MADEQE
Massachusetts Department of Environmental Quality Engineering
MassDEP
Massachusetts Department of Environmental Protection
MCLs
Maximum Contaminant Levels
MSR
Management System Review
NAWQC
National Ambient Water Quality Criteria
NCP
National Contingency Plan, 40 CFR Part 300
NE
Northeast
NESHAPS
National Emission Standards for Hazardous Air Pollutants
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ACRONYM
DEFINITION
NPL
National Priority List
NW
Northwest
O&M
Operation and Maintenance
OMEE
Ontario Ministry of Environment and Energy
PAHs
Polycyclic Aromatic Hydrocarbons
PA/SI
Preliminary Assessment/Site Investigation
PCP
Pentachlorophenol
PRP
potentially responsible party
RA
Remedial Action
RAC
Response Action Contract
RAFU
Reasonable Anticipated Future Land Use
RAO
Remedial Action Objective
RCRA
Resource Conservation and Recovery Act, 42 U.S.C
RD
Remedial Design
RME
Reasonable Maximum Exposure
RfD
Reference Dose
Rl
Remedial Investigation
ROD
Record of Decision
SDWA
Safe Drinking Water Act
SE
Southeast
SEL
Severe Effect Level
SF
Slope Factor
SVOCs
Semivolatile Organic Compounds
SW
Southwest
TBC
To Be Considered
TEL
Threshold Exposure Limit
TEQ
Toxicity Equivalent
TLV
Threshold Limit Value
TRV
Toxicity Reference Value
UCL
Upper Confidence Limit
USACE
United States Army Corps of Engineers
UST
Underground Storage Tank
VOCs
Volatile Organic Compounds
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EXECUTIVE SUMMARY
This is the first five-year review for the Hatheway & Patterson Superfund Site (the site). This review is
required by statute because the selected remedy will, upon completion, leave hazardous substances,
pollutants, or contaminants on site above levels that allow for unlimited use and unrestricted exposure.
The trigger date for this statutory five-year review is the initiation of the remedial actions at the site on
September 2, 2009.
The site is a former wood treatment facility located at 35 County Street in Mansfield, Massachusetts.
Approximately 36 acres of the 38.17-acre site are located in the Town of Mansfield. The remaining 1.77
acres are located in the Town of Foxborough, also referred to as the Foxborough parcel (see Figure 1.2
in Appendix A). The Mansfield portion of the site is divided into four quadrants by the Rumford River,
which runs north to south, and by a railroad right-of-way, which runs east to west. The northeast and
northwest quadrants are referred to as the "Process Area", the southeast and southwest quadrants
("SE/SW quadrants") cover the area south of the Rumford River, and the "County Street area" lies north
of the site fence in the northeast and northwest quadrants (see Figure 1.2 in Appendix A).
The selected remedy identified in the 2005 Record of Decision (ROD) included demolition of buildings in
and near Hatheway & Patterson's former manufacturing area; excavation of soils with contaminants
exceeding cleanup levels; testing of soils containing pentachlorophenol (PCP), semi-volatile organic
compounds (SVOCs), and arsenic for leachability, stabilization/solidification of the soils, if necessary, and
consolidation of stabilized/solidified soils under a low-permeability cover; off-site disposal of soils
containing dioxin and oily material (LNAPL) at a licensed facility; institutional controls to prohibit the use of
site groundwater and restrict land uses in a manner that ensures the protectiveness of the remedy; and
long-term monitoring of groundwater, surface water, fish tissue, and sediment.
The remedy was modified via an Explanation of Significant Differences (ESD) in 2011. Based on a zoning
change for the Foxborough parcel from residential use to "Limited Industrial" use, and intended reuse of
the parcel as a parking lot, EPA and MassDEP determined that the Foxborough parcel should be
remediated to a Reasonably Anticipated Future Use of commercial/open space and changed the cleanup
level accordingly. It was determined that a consolidation area for soils in Foxborough contaminated with
arsenic could be built on the Foxborough parcel and designed with an asphalt cover in order to facilitate
use as a parking lot. The 2011 ESD also modified the remedy for the management of PCP and arsenic-
contaminated soils from consolidation on the lots in the Mansfield portion of the Site to disposal at an off-
site facility. In addition, the EPA clarified the extent of institutional controls to be placed on the site
properties as called for in the ROD.
Protectiveness Statement
The remedy at the Hatheway & Patterson Superfund Site currently protects human health and the
environment because remediation of the soil (soil removal and on-site consolidation) has been completed
to cleanup levels that are considered protective for the anticipated future use of the property, and there is
no current use of on-site groundwater which is classified as non-potable. However, in order for the
remedy to be protective in the long-term, institutional controls need to be created and recorded to restrict
inappropriate land uses (including use of groundwater) and protect the consolidation area
cover. Operation and maintenance activities have been initiated and will ensure that the consolidation
area and associated components of the remedy (e.g., groundwater monitoring wells) remain in good
condition. In addition, monitoring of groundwater will continue to assess the protectiveness of the
remedy.
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Five-Year Review Summary Form
SITE IDENTIFICATION
Site Name:
Hatheway & Patterson Superfund Site |
EPA ID:
MAD001060805
| Region: 1
State: MA
City/County: Bristol
SITE STATUS
NPL Status: Final
Multiple OUs?
No
REVIEW STATUS
Lead agency: EPA
If "Other Federal Agency" was selected above, enter Agency name: Click here to enter text.
Author name (Federal or State Project Manager): Kimberly White
Author affiliation: U.S. EPA, Region 1 - New England
Review period: February 2014 to August 2014
Date of site inspection: June 3, 2014
Type of review: Statutory
Review number: 1
Triggering action date: September 2, 2009
Due date (five years after triggering action date): September 2, 2014
Has the site achieved construction completion?
Yes
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Five-Year Review Summary Form (continued)
Issues and Recommendations Identified in the Five-Year Review:
OU(s):
Issue Category: Institutional Controls
Issue: Institutional controls restricting land uses that may impact the
protectiveness of the remedy (including preventing the use of groundwater,
protecting the consolidation area cover and other components of the remedy)
need to be established. Also, an updated risk evaluation shows that the railroad
right-of-way will also require institutional controls to protect workers who may
contact soil in that area.
Recommendation: EPA, MassDEP, and the property owners should begin
discussions as soon as possible and establish institutional controls by the next
five-year review.
Affect Current
Protectiveness
Affect Future
Protectiveness
Implementing
Party
Oversight Party
Milestone Date
No
Yes
State
EPA
Aug 2019
OU(s):
Issue Category: Monitoring
Issue: The 2012 sediment sampling event included locations which did not
correspond with the historic sampling locations and the results showed lower
contaminant concentrations than seen previously. As a result, it is uncertain
whether the higher concentrations historically seen remain at the Site. If the
historic concentrations are still present, recent changes to toxicity values and
exposure parameters included in risk evaluation for sediment may result in a
future change to the protectiveness determination with respect to sediment
exposure.
Recommendation: If accessible, collect sediment samples from locations which
correspond to historical sampling locations and assess the new data.
Affect Current
Protectiveness
Affect Future
Protectiveness
Implementing
Party
Oversight Party
Milestone Date
No
Yes
State
EPA
Dec 2018
OU(s):
Issue Category: Monitoring
Issue: The fish tissue collection required by the ROD was not performed due to a
lack offish in the Rumford River. Also, surface water sampling required by the
ROD was not performed due to EPA and MassDEP's agreement to continue
discussions about the future operation and maintenance plan for the site.
Recommendation: Review current site information, determine the need for and,
if necessary, collect any additional data. Update/ document changes in the
monitoring requirements accordingly.
Affect Current
Protectiveness
Affect Future
Protectiveness
Implementing
Party
Oversight Party
Milestone Date
No
Yes
EPA/State
EPA
Dec 2018
ES-3
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OU(s):
Issue Category: Monitoring
Issue: Determine whether a PCP detection above its MCL in a non-potable
private groundwater supply well is site-related.
Recommendation: Perform evaluation which potentially includes the following:
determine if detection is real (potential resampling); review well construction and
any potential hydrogeologic connection to the site; and review nearby potential
sources.
Affect Current
Protectiveness
Affect Future
Protectiveness
Implementing
Party
Oversight Party
Milestone Date
No
Yes
EPA
EPA
Dec 2016
OU(s):
Issue Category: Monitoring
Issue: Active irrigation wells have been identified approximately 300 feet beyond
the compliance boundary. Irrigation wells are not expected to create enough
drawdown to induce groundwater to flow to them from the compliance boundary.
An on-site monitoring well just east (upgradient) of the compliance boundary does
indicate the presence of contamination at concentrations above performance
standards.
Recommendation: Additional investigations should be conducted to confirm
whether groundwater flow directions have been impacted by the irrigation wells.
Affect Current
Protectiveness
Affect Future
Protectiveness
Implementing
Party
Oversight Party
Milestone Date
No
Yes
EPA/State
EPA
Dec 2015
Protectiveness Statement(s)
Sitewide Protectiveness Statement (if applicable)
Protectiveness Determination:
Short-term Protective
Addendum Due Date (if applicable):
Protectiveness Statement:
The remedy at the Hatheway & Patterson Superfund Site currently protects human health and
the environment because remediation of the soil (soil removal and on-site consolidation) has been
completed to cleanup levels that are considered protective for the anticipated future use of the
property, and there is no current use of on-site groundwater which is classified as non-potable.
However, in order for the remedy to be protective in the long-term, institutional controls need to be
created and recorded to restrict inappropriate land uses (including use of groundwater) and protect the
consolidation area cover. Operation and maintenance activities have been initiated and will ensure
that the consolidation area and associated components of the remedy (e.g., groundwater monitoring
wells) remain in good condition. In addition, monitoring of groundwater will continue to assess the
protectiveness of the remedy.
ES-4
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SECTION 1.0
INTRODUCTION
The purpose of this five-year review is to determine whether the remedy for the Hatheway & Patterson
Superfund Site continues to be protective of human health and the environment. The methods, findings,
and conclusions of this review are documented in this five-year review report. In addition, five-year
review reports identify issues found during the review, if any, and present recommendations to address
them.
EPA Region I has conducted this five-year review pursuant to the Comprehensive Environmental
Response, Compensation, and Liability Act (CERCLA) and the National Contingency Plan (NCP).
Section 121(c) of CERCLA 42 USC ง 9621(c) states:
If the President selects a remedial action that results in any hazardous substances, pollutants, or
contaminants remaining at the site, the President shall review such remedial action no less often
than each five years after the initiation of such remedial action to assure that human health and
the environment are being protected by the remedial action being implemented. In addition, if
upon such review it is the judgment of the President that action is appropriate at such site in
accordance with section [ 104] or [ 106], the President shall take or require such action. The
President shall report to the Congress a list of facilities for which such review is required, the
results of all such reviews, and any actions taken as a result of such reviews.
The Agency interpreted this requirement further in the NCP; 40 CFR ง300.430(f)(4)(ii) states:
If a remedial action is selected that results in hazardous substances, pollutants, or contaminants
remaining at the site above levels that allow for unlimited use and unrestricted exposure, the lead
agency shall review such action no less often than every five years after the initiation of the
selected remedial action.
This is the first five-year review for the Hatheway & Patterson Site. This review was performed by EPA
Region I - New England and is required by statute because the selected remedy will, upon completion,
leave hazardous substances, pollutants, or contaminants on site above levels that allow for unlimited use
and unrestricted exposure. The trigger date for this initial five-year review is the initiation of the remedial
actions at the site in September 2009.
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SECTION 2.0
SITE CHRONOLOGY
The chronology of the site, including all significant events and dates is provided below in Table 1.
Table 1: Chronology of Site Events
Event
Date
Discovery of a tar seep on the banks of the Rumford River by
representatives of the Town of Mansfield and Massachusetts
Department of Environmental Quality Engineering (MADEQE) and
subsequent request that Hatheway & Patterson contain the "oily
seepage".
1972
Hatheway & Patterson took steps to control the "oily seepage"
including booms and sorbents, a collection pit and trench, and
other measures including recovery of 2,500 gallons of oil through
groundwater pumping operations.
1973- 1982
Additional report of "oily seepage" in the Rumford River and soil
and groundwater sampling by a prospective property buyer.
1981
MADEQE issued a Notice of Noncompliance letter to Hatheway &
Patterson requiring a Phase I Initial Site Investigation.
May 1987
Phase I site investigations conducted.
1987-1988
MADEQE issued a Notice of Responsibility letter to Hatheway &
Patterson requiring a Phase II Site Investigation, Risk
Assessment, and an alternative evaluation.
August 1988
Phase II site investigations conducted.
late 1988 - early 1989
The Massachusetts Department of Environmental Protection
(MassDEP), formerly MADEQE, issued a Request for Short Term
Measure letter to Hatheway & Patterson to address the imminent
hazard to the Rumford River area based on an additional report of
"oil seepage".
June 1990
Short-term measure investigation conducted and included
"sampling of the worst-case visibly stained soil along the river
bank."
Fall 1990
Hatheway & Patterson constructed a collection trench along the
eastern bank of the Rumford River to intercept groundwater and
oils migrating to the river from oil-contaminated river bank.
September 1991
The collection trench was modified to include groundwater
treatment with activated carbon prior to discharge to the Rumford
River.
February 1992
Two RCRA inspections found that drip pads were not in
compliance with RCRA regulations.
March 1992
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Table 1: Chronology of Site Events
Event
Date
MassDEP inspection and report of petroleum product flowing from
the river bed into the Rumford River, a release of oil into nearby
wetlands, and free-product in the wetlands. MassDEP requested
that Hatheway & Patterson conduct additional assessment and
plans for corrective action.
January 1993
Hatheway & Patterson filed for bankruptcy protection and closed
the manufacturing facility, leaving wood-treatment chemicals and
sludge in ASTs, UST sumps and drums at the abandoned
property.
February - May 1993
EPA and MassDEP initiated a Preliminary Assessment/Site
Investigation (PA/SI).
June 1993
EPA initiated a Removal Action to address the presence of ASTs
and USTs containing hazardous wastes located inside and outside
the buildings. 100,000 gallons of liquid and solid wastes were
removed and disposed off-site. Subsequently, a comprehensive
surface soil investigation was conducted and several areas of the
property received temporary geotextile/gravel and/or asphalt
cover. Also, perimeter fencing was repaired and installed, and
locks to manways of tanks and on-site buildings were installed.
December 1993 - September
1995
Additional on-site reconnaissance and environmental investigation
and sample collection is conducted by MassDEP and EPA.
1998
Town of Mansfield conducted environmental investigation under
an EPA Brownfields Pilot Program grant.
2000
EPA contractors conducted additional groundwater, surface water,
and sediment sampling.
Fall 2001
The site was added to the EPA National Priorities List.
September 5, 2002
Surface soil samples were analyzed from outside of the perimeter
fence on both sides of County Street.
April 2003
EPA initiated a Removal Action to address the arsenic-
contaminated soil located outside the perimeter fence. 376 tons of
contaminated soils were excavated from both sides of county road
and disposed of off-site.
August 2003
Completion of Remedial Investigation/Feasibility Study (RI/FS).
June 2005
EPA issued the Record of Decision.
September 30, 2005
Process buildings are demolished and disposed of off-site.
Spring 2006
Remedial Design is (RD) completed.
September 2008
Start of on-site construction.
September 2009
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Table 1: Chronology of Site Events
Event
Date
EPA issued an Explanation of Significant Differences to document
changes made to the remedy on the Foxborough, Massachusetts
parcel, including changes to the anticipated future land use, design
of the consolidation area, and the tax foreclosure and rezoning of
the property by the Town; to document the shipment of certain
pentachlorophenol and arsenic contaminated soils to an off-site
facility, rather than the on-site consolidation specified in the
Record of Decision (ROD); and to clarify the extent of institutional
controls to be placed on portions of the site.
August 29, 2011
Final Remedial Action Completion Report completed by Sevenson
Environmental Services, Inc. for the U.S. Army Corps of
Engineers.
September 2011
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SECTION 3.0
BACKGROUND
3.1 PHYSICAL CHARACTERISTICS AND LAND AND RESOURCE USE
The Hatheway & Patterson Superfund Site is located at 35 County Street in Mansfield, Massachusetts
(see Figure 1.1 in Appendix A). Approximately 36 acres of the 38.17-acre site are located in the Town of
Mansfield. The remaining 1.77 acres are located in the Town of Foxborough, also referred to as the
Foxborough parcel (see Figure 1.2 in Appendix A). The Mansfield portion of the site is divided into four
quadrants by the Rumford River, which runs north to south, and by a railroad right-of-way, which runs
east to west. The northeast (NE) and northwest (NW) quadrants are referred to as the "Process Area"
and are located north of the active railroad tracks operated by CSX. The southeast (SE) and southwest
(SW) quadrants cover the area south of the railroad tracks. The "County Street area" lies north of the site
fence in the northeast and northwest quadrants (see Figures 1.2 and B-1 in Appendix A).
The site lies within the Taunton River Basin which drains approximately 528 square miles and empties
into the Narragansett Bay at Fall River, Massachusetts. The Rumford River flows north to south and is
primarily fed by the Glue Factory Pond, which is located approximately 1 mile north of the site. The area
to the north of the site is developed with residences and light industry.
Much of the southwestern portion of the site is covered by wetlands, and several potential vernal pool-like
habitats exist in this area. The southerly section of the site is bounded by the Rumford River backwash
channel. Portions of the site are located within areas of the 100-year flood zone (Zone A3) and between
limits of the 100-year flood and 500-year flood zone (Zone B) for the Rumford River. The Rumford River
is a Class B surface water. Class B waters are designated as habitat for fish, other aquatic life and
wildlife, and for primary and secondary contact recreation. They are also designated as suitable for
irrigation and other agricultural uses and for compatible industrial cooling and process uses. The
Rumford River backwash channel (the southern boundary of the site) was the former course of the main
channel of the river until it was redirected further to the south during the 1960's (see Figure 2.1 in
Appendix A). The channel presently runs in a southeasterly direction for about 450 meters until it joins
with the Rumford River.
The majority of the historical operational areas and buildings were located on the northern portion of the
property, north of the railroad tracks, and contained process buildings, drip pads, support buildings, an
office, and a laboratory. With the exception of the office building, which was outside the remediation
area, these structures have been demolished or removed (Sevenson, 2011).
The remedy selected in the ROD for the 1,77-acre Foxborough portion of the site was based on a
residential future use scenario because of the residential zoning in place at the time of the 2005 ROD
signature. At the time of the ROD, the parcel was unused. During Hatheway & Patterson operations, it
may have been used for wood storage. Subsequent to the 2005 ROD, the Town of Foxborough
foreclosed on the approximately 1.7 acres of the site located within the Town, with the intent of
redeveloping the parcel as a parking lot to service the nearby MBTA commuter rail station. The Town
subsequently changed the zoning of the lot from R-40 Residential and Agricultural District to Limited
Industrial (LI) district. Modifications were made to the remedy based on this new information as
documented in an Explanation of Significant Differences (ESD; USEPA, 2011a). .
The 36-acre Mansfield portion of the site is zoned as I-3, which is a flexible mixed-use industrial zone that
allows an array of uses from heavy manufacturing to multi-family dwellings to day care. The Town of
Mansfield utilizes a portion of the site north of the railroad tracks for storage of emergency vehicles and
uses the one remaining building for office space. The site has been used for commercial/industrial
purposes intermittently since 1927. The area of the site south of the railroad tracks has historically been
used for storage, but has not been developed. During ROD development, the Town of Mansfield notified
EPA that the reasonable anticipated future land use (RAFU) of the Mansfield portion of the site will be
commercial use for the front parcel located on County Street (north of the railroad tracks) and Open
Space or Commercial, for the back parcel (south of the railroad tracks) (USEPA, 2005).
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The site and surrounding area are served by municipal drinking water. Groundwater underlying the site is
designated as Class III (non-potable) by the Commonwealth of Massachusetts. The remedy outlined in
the ROD was based on an assumption that groundwater at the site is not available for drinking water by
future users of the site (USEPA, 2005).
3.2 HISTORY OF CONTAMINATION
Initially, the Hatheway & Patterson property consisted only of the land between County Street and the
railroad tracks, and the land from the present eastern property boundary to approximately the Rumford
River. Hatheway & Patterson reportedly began operations at the site in 1927, but did not begin wood
treating until 1953. It is unknown what operations might have been conducted at the site between 1927
and 1953 (USEPA, 2005).
The land west of the Rumford River was owned by the Penn Central Railroad, who used it for bulk
chemical transfer and storage of electric/utility poles and railroad ties, until the land was purchased by
Hatheway & Patterson in 1978. The land south of the railroad tracks was purchased by Hatheway &
Patterson in 1981 and was apparently not used between 1955 and 1971, but was reportedly used for coal
storage prior to 1955 (USEPA, 2005).
Wood treatment was accomplished by a variety of methods that changed over time. From 1953 through
1958, a solution of pentachlorophenol (PCP) in fuel oil, or creosote, was used for dipping lumber. After
dipping, excess chemicals were allowed to drip off of the treated wood onto the ground surface. From
1958 through 1974, solutions of PCP in fuel oil and fluoro-chrome-arsenate-phenol (FCAP) salts in water
were used in a pressure treatment process. From 1960 through 1984, PCP in mineral spirits was also
used to pressure-treat lumber. From 1974 to 1984, operations incorporated PCP in fuel oil and
chromated copper-arsenate (CCA) salts in water. From 1984 until operations ceased in 1993, solutions
of CCA salts in water and PCP in water were utilized at the property. Wood was also infused with fire
retardants, including Dricon (boric acid and anhydrous sodium tetraborate). The various wood-treating
chemicals were stored in aboveground storage tanks (ASTs), underground storage tanks (USTs), and
sumps located inside and outside of the former process buildings (USEPA, 2005).
Contamination was initially discovered in 1972, when a tar seep (approximately 62 feet long and 6 inches
thick) was discovered on the banks of the Rumford River on the southern portion of the property by
representatives of the Town of Mansfield and the MADEQE. Additionally, "oily water and dead fowl were
reported in Fulton Pond, downstream of the property" (USEPA, 2005).
3.3 INITIAL RESPONSE
Following the initial discovery of contamination in 1972, Hatheway & Patterson took steps to control the
"oily seepage" including booms and sorbents, a collection pit and trench, and other measures including
groundwater pumping operations between approximately 1973 and 1982. Under MADEQE requests,
Hatheway & Patterson conducted Phase I and Phase II site investigations between 1987 and early 1989.
In June 1990, MassDEP (formerly MADEQE) issued a Request for Short Term Measure letter to
Hatheway & Patterson to address the imminent hazard to the Rumford River area based on an additional
report of "oil seepage" and in response, soil investigation was conducted along river bank. In September
1991, Hatheway & Patterson constructed a collection trench along the eastern bank of the Rumford River
to intercept groundwater and oils migrating to the river from oil-contaminated river bank. In February
1992, the collection trench was modified to include groundwater treatment with activated carbon prior to
discharge to the Rumford River.
In 1993, Hatheway & Patterson declared bankruptcy, ceased operations, and left the site. In 1993, EPA
conducted a PA/SI at the site and, based on the results, a Removal Action was conducted between
December 1993 and September 1995. The Removal Action addressed the presence of ASTs and USTs
containing hazardous wastes located inside and outside the buildings. Liquid and solid wastes were
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removed and disposed off-site. Subsequently, a comprehensive surface soil investigation was conducted
and several areas of the property received temporary geotextile/gravel and/or asphalt cover. Also,
perimeter fencing was repaired and installed, and locks to manways of tanks and on-site buildings were
installed. Following the Removal Action, MassDEP assumed oversight of the property. EPA conducted
another Removal Action in 2003 to excavate and dispose off-site the arsenic-contaminated surface soil
located outside the perimeter fence. Additional environmental investigations were conducted by
MassDEP, EPA, and the Town of Mansfield between 1998 and 2005, when the ROD was completed.
3.4 BASIS FOR TAKING ACTION
Based on the Remedial Investigation (TRC, 2005), the following summarizes the affected media and
contaminants:
Surface and Subsurface Soil. In general, surface and subsurface soils contaminated with the highest
concentrations of PCP, arsenic, dioxin, and polycyclic aromatic hydrocarbons (PAHs) were located north
of the railroad tracks in the Process Area (NE and NW quadrants).
Groundwater. Groundwater at the Site is impacted primarily by arsenic and PCP. Groundwater plumes
in both overburden and bedrock flow southwesterly from the Process Area and the light non-aqueous
phase liquid (LNAPL) hot spot toward the Rumford River and the Rumford River backwash channel to the
south. It was concluded that the extent of contamination in overburden and bedrock groundwater
appeared to be confined to the site and bounded by the Rumford River and the backwash channel.
LNAPL. A sizable LNAPL hot spot area was located just south of the railroad tracks in the SE/SW
quadrants, near the Process Area. Isolated pockets of free product and LNAPL-saturated subsurface
soils were detected throughout the site.
Surface Water. PCP and two PAHs (benzo(a)anthracene and benzo(a)pyrene) were detected above
surface water screening criteria in on-site Rumford River surface water samples. The highest
concentration of PCP in surface water was detected in an on-site vernal pool sample.
Sediment. Several PAHs were detected in upstream and on-site sediment samples at concentrations
exceeding sediment screening criteria. Other semivolatile organic compounds (SVOCs) (2-methylphenol,
dibenzofuran, diethyl phthalate, and PCP) and dioxin also exceeded sediment screening levels.
Fish. Fish tissue collected from the Rumford River contained concentrations of PCP and dioxin that were
higher in on-site samples than upstream samples.
The baseline human health risk assessment concluded that exposure to surface and subsurface soil in
the Process Area (NE and NW quadrants) containing arsenic, dioxin, and pentachlorophenol was
associated with an unacceptable human health risk outside EPA's acceptable risk range under current
and future exposure scenarios. On-site overburden and bedrock groundwater was also associated with
an unacceptable human health risk based on a conservative assumption that the contaminant plume of
PCP, arsenic, and chromium will migrate to a location outside the current site boundary and will be used
by off-site residents via existing wells on their properties which are currently designated as non-potable.
The baseline ecological risk assessment concluded that benthic invertebrates, water column
invertebrates, fish, piscivorous birds and mammals feeding along the Rumford River are unlikely to be at
a substantial risk from exposure to site-related contaminants.
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SECTION 4.0
REMEDIAL ACTIONS
4.1 REMEDY SELECTION
The EPA ROD for the site was signed on September 30, 2005. Remedial Action Objectives (RAOs) were
developed for various media at the site based on the results of the Rl and risk assessments. The RAOs
were developed to aid in the development and screening of remedial alternatives.
The RAOs for the selected remedy for the site are:
Surface Soil (Process Area) - Prevent current and future trespassers and future on-site residents
(Foxborough parcel), commercial workers, town workers, and utility workers from ingestion of or
dermal contact with Contaminants of Potential Concern (COPCs) (including arsenic, dioxin, and
PCP) which would result in a cumulative excess cancer risk greater than 10"4 to 10"6 or 1-11=1;
Subsurface Soil (Process Area) - Prevent future commercial workers and future on-site residents
(Foxborough parcel) from ingestion of or dermal contact with COPCs (including arsenic, dioxin,
and PCP) which would result in a cumulative risk greater than 10~4 to 10~6 or 1-11=1;
Groundwater - Prevent discharge of pentachlorophenol and other COPCs from soil to
groundwater and from groundwater to surface water at concentrations that would result in an in
stream exceedence of the Ambient Water Quality Criteria (AWQCs) through source control.
Prevent exposure to groundwater by future residents, recreational users, or commercial workers
by monitoring extent of plume (to ensure it is remaining on-site) and implementing institutional
controls to restrict groundwater use within the site boundary;
Inter-Media Transfer - Eliminate or reduce potential for leaching through source control and inter-
media transfer of COPCs from soil to groundwater and surface water;
LNAPL - Minimize further contaminant transfer from LNAPL source material to groundwater by
reducing LNAPL source material in soil excavation/treatment areas. Minimize further migration of
LNAPL free product to groundwater and surface water by removing free product "hotspots" to the
extent feasible.
The selected remedy for the site consisted of the following components:
Excavation of approximately 31,000 cubic yards of soil exceeding cleanup levels.
Demolition of the buildings in and near Hatheway & Patterson's former manufacturing area to
allow excavation of underlying contaminated soils and replacement of the excavated soil with
clean backfill.
Excavation of soils containing PCP, SVOCs, and arsenic, and testing of soils for leachability and,
if they fail, utilization of a stabilization/solidification agent(s). Consolidation of the
stabilized/solidified soils on-site under a low-permeability cover.
Off-site disposal of soils containing dioxin and oily material (LNAPL) at a licensed facility.
Institutional controls to prohibit the use of site groundwater and restrict land uses in a manner that
ensures the protectiveness of the remedy as described in this ROD, and ensures the integrity of
the on-site low-permeability cover and other remedial components. Evaluation of risks from soil
exposures within the area of the existing railroad right of way during design and implementation
of appropriate action such as deed restrictions or other legal and administrative measures if
necessary.
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Long term monitoring of groundwater, surface water, fish tissue and sediment.
Five-year reviews, and operation and maintenance of remedial components, including the low
permeability cover
An ESD (USEPA, 2011 a) was issued in August 2011 in order to document certain changes and
clarifications to the remedy that was set forth in the ROD. The ESD had three main purposes as
summarized below.
The remedy outlined in the ROD for the Foxborough parcel was based on future residential use of the
parcel, as the property was zoned for residential use in 2005. After the ROD was issued, the Town of
Foxborough took ownership of the parcel through tax foreclosure with the intent of redeveloping the
parcel as a parking lot. In connection with this plan, the town voted at the May 2008 Town Meeting to
adopt a change in zoning of the lot from R-40 Residential and Agricultural District to "Limited Industrial."
The Town notified EPA of its intention to use the parcel as a parking facility for the nearby MBTA
commuter rail station. Based on the change in zoning and intended reuse of the parcel, EPA and
MassDEP determined that the Foxborough parcel should be remediated to a Reasonably Anticipated
Future Use (RAFU) of commercial/open space and changed the cleanup level accordingly from 9.1 ppm
to 16 ppm for arsenic and to 90 ppm for PCP (note that there was no Residential Cleanup Level for PCP
in the ROD). EPA also determined that a consolidation area for soils in Foxborough contaminated with
arsenic could be built on the Foxborough parcel and designed with an asphalt cover in order to facilitate
reuse as a parking facility.
Second, EPA reevaluated the remedy for PCP and arsenic-contaminated soils excavated from the lots in
the Mansfield portion of the site. The remedy chosen in the ROD called for on-site consolidation of these
soils, rather than disposal at an off-site facility. Subsequent to the signing of the ROD, the relative costs
of off-site disposal decreased significantly. EPA reevaluated both options using criteria required under
CERCLA to compare different remedial options. The criteria included overall protection, long-term
effectiveness and permanence, community support, and cost. The remedy was changed since the costs
were similar, but the off-site disposal option offered the greatest overall protection, long-term
protectiveness, and permanence.
Lastly, EPA clarified the extent of institutional controls to be placed on the site properties as called for in
the ROD. Specifically, restrictions on future soil excavation, in the form of institutional controls, will be
needed in the northeast quadrant of the site: 1) below the depth of the vertical extent of excavation
reached during the remedial action (RA); and 2) at depths of two feet and below in a strip of land
bordering the northeast quadrant and County Street to a distance about 5 feet laterally with the fence line.
Institutional controls will also be necessary to protect the cover placed over the consolidated soils in the
Foxborough parcel.
Risks from soil exposures within the area of the existing railroad right of way were evaluated during
design and remedial action as specified by the ROD and institutional controls or other legal and
administrative measures were deemed not to be necessary. The ESD stated that risk from the railroad
right of way would be reevaluated as part of the five-year review process for the site. In addition,
institutional controls to eliminate on-site exposures to groundwater and to prevent residential use will be
necessary on all four quadrants of the site property.
4.2 REMEDY IMPLEMENTATION
Through an Interagency Agreement with EPA Region I, the U.S. Army Corps of Engineers New England
District (USACE) contracted with Sevenson Environmental Services (Sevenson) to perform the remedial
construction in accordance with Construction Specifications developed by Metcalf & Eddy and TRC
Corporation (TRC, 2008). USACE provided construction management technical oversight.
Remedial construction activities commenced in September 2009 and were substantially completed in
September 2010. The work conducted included the following:
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mobilization;
geotechnical investigation;
preparation of all required infrastructure including the construction of two small bridges;
demolition and off-site disposal of one on-site building, including asbestos abatement;
removal and disposal of six underground storage tanks;
removal and disposal of all surficial and subsurface concrete and asphalt within the northeast
and northwest quadrants of the site;
installation of groundwater monitoring wells and groundwater sampling;
pre-excavation soil investigation for waste characterization and to refine excavation limits;
excavation of contaminated soils in the northeast, northwest, and southeast quadrants;
consolidation of arsenic contaminated soils from the Foxborough parcels and installation of an
asphalt cover over the consolidation area; and
site restoration and demobilization.
A total of 34,000 tons of soil was removed from the NE and NW quadrants and 9,500 tons of soil was
removed from the SE quadrant for off-site disposal as non-hazardous waste.
Buffer zone planting was initially completed in the fall of 2010 and then monitored for the first year after
planting. Replanting of some trees was determined to be needed and was conducted in September
2011. Final inspection of the remedy construction occurred in September 2011.
Operation and maintenance of the remedy is currently being performed as described below. Institutional
controls, as required by the ROD and ESD, are being prepared, but have not yet been implemented.
4.3 OPERATION AND MAINTENANCE
Operation and maintenance (O&M) of the remedy for the Hatheway & Patterson Site is being performed
in accordance with the ROD and the O&M Manual (USEPA, 2011 b). MassDEP is the lead agency
performing O&M of the site.
The ROD required long-term monitoring of groundwater, surface water, fish tissue and sediment and
operation and maintenance of the low-permeability cover. The monitoring frequencies and timing were
described in the ROD as follows: 1) annual monitoring of sediment and surface water until completion of
the first five-year review; 2) one round offish tissue sampling in conjunction with the five-year review; and
3) sampling of on-site and off-site groundwater twice a year, every other year, until the first five-year
review and continued monitoring after the five-year review in accordance with the O&M Manual to ensure
that contaminated water is not impacting off-site receptors and to ensure protectiveness of the remedy.
In addition to the monitoring schedule described in the ROD, the O&M Manual specifies annual
monitoring of groundwater following the first five-year review and sampling of sediment, surface water,
and fish tissue once every five years following the first five-year review. Maintenance activities required
by the O&M Manual include inspections and maintenance of the asphalt cover, storm filter, catch basins
and monitoring wells. Surface water sampling required by the ROD was not performed and frequency of
sediment sampling was reduced due to EPA and MassDEP's agreement to continue discussions about
the future operation and maintenance plan requirements for the site, as a result of changes to the
remedy, which were documented in the ESD.
Inspections of the asphalt cover, storm filter, monitoring wells, and site security measures (fence, gates,
locks, and signage) were conducted in May 2012, October 2012, April 2013, and November 2013 in
conjunction with the groundwater monitoring events. No significant issues were noted.
To date, five rounds of groundwater monitoring were conducted since remedy construction: May 2011,
May 2012, and October 2012, April 2013, and October/November 2013. Sediment monitoring was
performed in May 2012 and a fish survey was conducted in June 2013. Monitoring activities were
performed by subcontractors to MassDEP. A discussion of the monitoring results is provided in Section
6.3.
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In addition to the sampling activities, a hydrogeological conditions report was prepared in 2013 (AECOM,
2013) which summarized the groundwater flow and groundwater quality data collected during the RI/FS,
RD, and the RA. The report also presented recommendations for additional investigations and potential
locations for new monitoring wells that may be needed to confirm that contaminated groundwater is not
migrating beyond the site compliance boundary. A summary of the evaluation and resulting
recommendations is provided in Section 6.3.1.
4.4 Institutional Controls
In order for the remedy at the Hatheway & Patterson Site to be protective in the long-term, institutional
controls need to be created and recorded to restrict inappropriate land uses (including use of
groundwater) and protect the consolidation area cover. The remedy is protective in the short-term, as
there is no current use of on-site groundwater, and operation and maintenance activities ensure that the
consolidation area and associated components of the remedy (e.g., groundwater monitoring wells) remain
in good condition.
Implementation of institutional controls (ICs) in Massachusetts, namely the recording of Grants of
Environmental Restrictions and Easements (GEREs), has been a continued challenge for EPA. The
need to complete ICs has often been identified as an issue potentially impacting future protectiveness as
part of five-year reviews at this and other Massachusetts sites. In an effort to address this issue and
improve the process of completing ICs at Massachusetts NPL sites, EPA worked with the MassDEP to
develop a new approach using Notices of Activity and Use Limitations (AUL Notices). This process
involved first working with MassDEP to update and amend their regulations governing AULs (both Notices
and GEREs) embodied in the Massachusetts Contingency Plan (310 CMR 40.0000). The MCP
amendments published in May 2014 included new requirements allowing for use of AUL Notices at NPL
sites. EPA and MassDEP are currently working on model documents and forms that will be used to
implement AUL Notices. Once fully implemented, the overall process for IC implementation will be
streamlined as AUL Notices do not require the signature of the MassDEP Commissioner nor do they
require Subordination Agreements from those holding prior encumbrances on properties. Both of these
requirements served to slow the GERE implementation process at many sites. EPA and MassDEP will
work together to determine whether specific circumstances at sites still require GEREs or whether the
new AUL Notices can be used instead. This new approach to ICs in Massachusetts should allow EPA to
complete these activities more quickly and efficiently and implement ICs at the site within a reasonable
timeframe. Implementation of the necessary Hathaway & Patterson ICs will be follow the above approach.
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SECTION 5.0
PROGRESS SINCE THE LAST FIVE YEAR REVIEW
This is the first five-year review for the Hatheway & Patterson Site.
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SECTION 6.0
FIVE-YEAR REVIEW PROCESS
This section describes the activities performed during the five-year review process and provides a
summary of findings. The Hatheway & Patterson Superfund Site Five-Year Review was led by Kimberly
White of the U.S. EPA, Remedial Project Manager for the Site, and Emily Zimmerman, the Community
Involvement Coordinator (CIC). Gary Waldeck, of the MassDEP, assisted in the review as the
representative for the support agency.
The review, which began in February 2014, consisted of the following components:
Community Involvement;
Document Review;
Data Review;
Site Inspection; and Five-Year Review Report Development and Review.
6.1 COMMUNITY NOTIFICATION AND INVOLVEMENT
On February 13, 2014, EPA issued a press release announcing that EPA was beginning five-year reviews
of 27 Superfund sites across New England, including the Hatheway & Patterson site. A similar press
release will be issued by EPA once the five-year reviews are complete.
6.2 DOCUMENT REVIEW
This five-year review included a review of relevant documents for the site including the ROD, the 2011
ESD, the Remedial Action Completion Report, and site groundwater and sediment monitoring data as
presented in various reports prepared by MassDEP's contractors. See Appendix B for a list of documents
that were reviewed and other references.
6.3 DATA REVIEW
As noted in Section 4.2.3, there have been a number of field monitoring efforts since the remedial action
was completed. These results are summarized in this section. A summary of the site hydrogeology, the
results of three rounds of groundwater monitoring, one round of sediment monitoring, and a fish survey
performed by subcontractors for MassDEP are also provided in this section. Surface water sampling was
not conducted during the five year review period due to EPA's and MassDEP's agreement to continue
discussions about the future operation and maintenance plan requirements for the site following
completion of the ESD in 2011.
In addition to monitoring required in the ROD and O&M Plan, several off-site private wells were sampled.
These wells were identified during a review of information from the Mansfield Board of Health during
preparation of a hydrogeologic conditions report in 2013 (discussed below), and were determined to be
used either for irrigation or for industrial purposes.
6.3.1 Hydrogeology
A hydrogeological conditions report was prepared in 2013 (AECOM, 2013) which summarized the
groundwater flow and groundwater quality data collected during the RI/FS, the RD, and the RA. The
report also presented recommendations for additional investigations and potential locations for new
monitoring wells that may be needed to confirm that contaminated groundwater is not migrating beyond
the site compliance boundary. For reference, the compliance boundary defined in the 2005 ROD is the
property boundary on the south side of the site, the Rumford River backwash channel on the west side of
the site, and the Rumford River on the north side of the site. Figure A-1 in Appendix A presents
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monitoring locations discussed in this section.
Groundwater generally flows to the west-southwest, toward the backwash channel (see Figures 2 and 3
in Appendix A, originally from the Rl report). The piezometric surface map indicates that if site
contaminants were going to migrate beyond the compliance boundary, they would most likely do so along
the backwash channel on the west side of the site. Although migration of contaminated groundwater
beyond the compliance boundaries on the north and south sides of the site is less likely, those
possibilities are also discussed below.
Flow to the North. The compliance boundary to the north of the site is the Rumford River. Groundwater
flow to the north is not indicated by the available piezometric surface data. Furthermore, the Rumford
River is a major discharge feature, and it is reasonable to anticipate that groundwater would not flow
beneath it to the north or northwest unless there were a pumped well or other groundwater "sink" in that
direction. No such "sinks" are known to exist in that direction. Furthermore, the absence of
contamination in MW-107 and MW-107R, which are west of the site but north of the Rumford River,
suggests that plumes are not migrating past the compliance boundary on the north side of the site.
Flow to the West/Southwest. The compliance boundary to the west of the site is the backwash channel.
This stream and wetland area appears to be a groundwater discharge zone, and it is reasonable to
anticipate that groundwater would not flow beneath it and continue flowing to the west or southwest
unless a pumped well or other groundwater "sink" existed in that direction.
The available information suggests that groundwater flow beyond the backwash channel is unlikely under
natural conditions. However, a review of a list of private wells from the Mansfield Board of Health (BOH)
indicated that three of the parcels on Highland Avenue have permits for "domestic auxiliary" (DA) water
wells (see Figure 5 in Appendix A). The existence of two of these wells was confirmed during the site
inspection. The well at 136 Highland Avenue is a driven point and is 12 feet deep, according to the
owner. Although the well at 132 Highland Avenue is completely below ground and therefore not visible, it
is suspected to be of similar construction. Shallow driven well points are probably less likely than bedrock
wells to pull contaminated groundwater beneath the backwash channel since, unlike overburden wells,
bedrock wells could be connected to the groundwater beneath the backwash channel by discrete
fractures that could act as preferential pathways. Nonetheless, with heavy prolonged use during the dry
season, the possibility cannot be discounted that the shallow well points could create gradients that would
cause groundwater to cross beneath the compliance boundary.
The existence of the third possible well on Highland Avenue could not be confirmed. Figure 5 in
Appendix A also shows four DA wells farther to the west, beyond the wells on Highland Avenue. Three of
these wells have been confirmed not to exist, and the owner of the fourth property with a possible well did
not respond to EPA's inquiries. In June 2014, EPA collected groundwater samples from the two wells on
Highland Avenue. The results are discussed in Section 6.3.2.
While movement of groundwater beyond the backwash channel/compliance boundary in response to
groundwater withdrawals from the wells on Highland Avenue is possible, the absence of contamination in
MW-109R suggests that a plume is not migrating past the backwash channel to the north of those wells.
If additional wells are to be installed to investigate possible migration beyond the compliance boundary,
the wells should be located opposite the MW-111 and MW-113 well clusters (see Figure A-1 in Appendix
A), where moderate to high concentrations of PCP have been recently detected and where there are
currently no monitoring wells west of the compliance boundary.
Flow to the South. Prior to the early to mid-1950's, the backwash channel was the course of the
Rumford River as it flowed south and crossed what is now Howe Street, Chauncy Street (Rt. 106), and
the main railroad tracks south of the site. Sometime between 1951 and 1956, at approximately the same
time that wood treatment operations began at the site, the Rumford River was diverted west into a new
channel, and the backwash channel became a backwater and wetland. It is assumed that the former
riverbed between the site and the railroad tracks south of Rt. 106 was filled with soil, and that no
underdrains were placed in the filled channel. As a result, water levels would have risen in the filled area
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between Howe Street and Rt. 106, and the backwash channel would have been forced to drain to the
north into the new Rumford River channel. An aerial photograph of this area from 1977, which shows
ponding of water at the southern end of the backwash channel, supports this conclusion, as does the
observation of northwestward flow in the backwash channel during a site visit in 2010 and during the
recent site inspection. Higher groundwater levels to the south would have prevented movement of
plumes in that direction, so it is unlikely that contaminated groundwater would have flowed south from the
site.
The review of the list of private well records from the Mansfield BOH indicated the possible presence of
non-drinking water industrial/commercial auxiliary (ICA) and domestic auxiliary (DA) supply wells to the
south of the site (see Figure 5 in Appendix A). The four wells that are closest to the site are listed as
follows: 18 Thomas Street, ICA well for a laundry facility; 46 Chauncy Street, DA well for a car wash; 325
N. Main Street, DA well for irrigation; and 17 Pratt Street, no permit and use unknown. During the recent
site inspection, the existence of three of these wells was confirmed. The well at 18 Thomas Street is
reportedly a gravel-packed overburden well about 35 feet deep (used for laundry business); the well at 46
Chauncy Street is reportedly a bedrock well about 800 feet deep (used for car wash, "tracked" to increase
yield); and the well at 325 North Main Street is a driven point (used for lawn irrigation). In addition, it was
learned that permanent dewatering systems exist at the two railroad underpasses at Route 106 and North
Main Street. While the three confirmed wells and the Route 106 underpass are about 1,000 feet from the
site and do not appear to be downgradient, samples were collected by EPA in June 2014 to confirm that
site contaminants are not following an unlikely pathway to the south in response to the combined
pumping. The underpass at North Main Street is also not believed to be downgradient of the site;
furthermore, the water from the dewatering system is discharged to the backwash channel wetland, which
would tend to limit the effect of the dewatering at the site. Sampling results are discussed in Section
6.3.2.
6.3.2 Groundwater Monitoring Results
Groundwater monitoring for remedy compliance has been performed multiple times since completion of
remedy construction: May 2011, May 2012, October 2012, April 2013, and October/November 2013.
Locations both inside and outside the compliance boundary have been selected for this long-term
compliance monitoring. Figure A-1 in Appendix A presents the locations sampled during the events. It
should be noted that an apparent field error resulted in a sample being incorrectly collected from an
interior well (RCA-8) rather than the planned perimeter well (RCA-9) in the two 2012 monitoring rounds.
Analyses included the three analytes which have performance standards established in the ROD: PCP,
arsenic, and chromium. Maximum Contaminant Levels (MCLs) were identified in the ROD as
groundwater performance standards at the site compliance boundary. As dioxins are a known site
contaminant, dioxin congeners (forms of dioxin differing only in the number and location of chlorine
atoms) were also analyzed and compared to the dioxin MCL (following conversion to a dioxin toxicity
equivalency [TEQ]). Appendix C presents results from each monitoring round, as well as a summary
table (Table C-1) compiling the monitoring rounds along with historical results for comparison purposes.
As shown in this table, there have been no exceedances of compliance boundary performance standards
in the wells located beyond the compliance boundary. However, detection limits for PCP in the 2012
monitoring events exceeded the performance standard. Other monitoring rounds did not show detections
of PCP in these wells with lower detection limits. There were detections of the four analytes in interior
wells, but no exceedances of on-site performance standards established for protection of surface water.
As described in the previous section, non-potable DA/private wells were sampled for metals, PCP and
dioxins in June 2014. Figure 6 in Appendix A shows the location of the wells sampled. The monitoring
event summary memorandum and analytical data are presented in Appendix C. The results showed no
exceedances of MCLs for metals or dioxin. There was only one PCP detection (2.7 |jg/L), but this
detection was also above the MCL (1 |jg/L). Based on a brief review of this non-potable well (shallow)
and its location relative to the site, the detection is not likely site-related. In addition, there were no
detections above MCLs in the other wells in the same area. However, further investigation/evaluation will
be performed to confirm this.
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6.3.3 Sediment Monitoring Results
The 2005 ROD included annual sediment monitoring prior to the first five-year review as part of the long-
term monitoring to document conditions at and near the site. Monitoring was performed in May 2012 at
four locations in the Rumford River (see Figure 1 included in Appendix C). These four sampling locations
were different from the sampling locations used prior to the remedial action. Some or all of the previous
locations were inaccessible during the May 2012 sampling event due to modifications of the riverbank
made during the remedial action. Similar to the groundwater monitoring, samples were analyzed for
dioxins, PCP, arsenic, and chromium. Appendix C presents results from the monitoring event, as well as
a summary table (Table C-3). As there were no sediment performance standards in the ROD or ESD, the
table presents historical statistical data (e.g., maximum detections) from the 2004/2005 risk assessments
for comparison purposes. All detections in the 2012 monitoring event were below the historical maximum
detections, except for one dioxin congener (1,2,3,7,8,9-HxCDF). Further discussion of these results as
they relate to the risk assessments can be found in Section 7.2. Only one round of sediment sampling
was conducted before this five year review due to MassDEP's interpretation of the monitoring
requirements described in the Operations and Maintenance Plan. MassDEP and EPA will determine the
locations and frequency of any additional sediment samples to be obtained before the next five year
review.
6.3.4 Fish Survey
The 2005 ROD recommended a round offish tissue sampling to be performed in conjunction with the
five-year review. A fish survey was conducted during June 2013 at three locations along the Rumford
River. The sampling procedures and results are summarized in a report prepared by Environmental
Strategies and Management, Inc., dated October 1, 2013 (ESM, 2013). The report documents that no
fish were collected in Area 1, which was a reference area located upstream of the site. In both Area 1
(reference) and Area 2 (on site between County Street and the railroad tracks), only crayfish were
collected, and no fish were observed. In the downstream area of the river (Area 3, located approximately
400 feet downgradient of the site, immediately upstream of where Henkes Brook flows into the Rumford
River), a few crayfish and fish were observed as part of the survey. Fish samples were not collected at
that time; however, EPA and MassDE P will determine what, if any, samples can be collected before the
next five year review.
6.3.5 Surface Water Monitoring
Surface water sampling has not yet been implemented at the Site. However, on-site groundwater
performance standards established to protect surface water have been monitored and have not been
exceeded. Surface water monitoring is required under the 2005 ROD, and the O&M Manual was based
on the remedy selected in the ROD; however, due to changes in the remedy outlined in the ESD (no on-
site consolidation of PCP and arsenic contaminated soils in the Mansfield portion of the Site), MassDEP
and EPA determined that the requirement to sample surface water would be further discussed. EPA and
MassDEP will evaluate whether surface water sampling is necessary or whether monitoring of the
groundwater performance standards is sufficient to determine impacts to surface water.
6.4 SITE INSPECTION
A site inspection was performed by the EPA Project Manager and AECOM on June 3, 2014. The
MassDEP Project Manager was also present for part of the inspection. The inspection included cursory
examinations of the site fences and gates; the asphalt cover on the Foxborough portion of the site that is
used as a commuter parking lot; a subset of the site monitoring wells; and the Rumford River and its
confluence with the backwash channel. The site inspection checklist and photographs from the site
inspection are included in the Management System Review (MSR) Technical Memorandum in Appendix
D.
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The site was observed to be secure, and no evidence of trespassing or vandalism was noted. The NW
Quadrant of the site is mostly covered with crushed rock except for a vegetated buffer along the Rumford
River and a commuter parking lot for the Town of Foxborough in the extreme northwest corner. As
described in the site inspection checklist, the parking lot is well maintained, and the fencing and gates
that surround the entire NW and NE Quadrants of the site are in good condition (except for very minor
damage to the stockade fence on the northwest side of the commuter lot).
The monitoring wells that were observed were locked and appeared to be in good condition. The
compliance boundary on the southwest side of the site is the backwash channel, which is a vegetated
marshy area and is difficult to traverse. Where observed near its confluence with the Rumford River, the
amount of water in the backwash channel was miniscule, and no flow was observable. However, at the
actual confluence, it was confirmed that the trickle of flow in the channel was moving northwest and
discharging to the river. The wells along the compliance boundary had been sampled several weeks
before the site inspection and were found to be in good condition, and therefore were not inspected.
6.5 INTERVIEWS
Representatives of the Town of Mansfield DPW and the Town of Foxborough, and the MassDEP Project
Manager each responded to a request for an interview by providing written responses to a series of
interview questions. Appendix E includes a detailed summary of the interviews. In general,
representatives from both towns were very pleased with the work conducted at the site. The town
representatives stated that they have been well informed throughout the process and that they have no
concerns. The representative from the Town of Mansfield would like to see the institutional controls
implemented so that the town can move forward with potential reuse of the property. Town of Mansfield
personnel periodically inspect the site. It was noted by the representative from Mansfield that, although
vandalism has generally not been an issue at the site, a few fence cuts in the deep woods have been
found. EPA has followed up with the town and is waiting for an update on the status of the repairs. The
Project Manager for the MassDEP also stated that the project was a success, that he was well informed,
and that he has no concerns.
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SECTION 7.0
TECHNICAL ASSESSMENT
This section discusses the technical assessment of the remedy for the site and provides answers to the
three questions posed in the EPA guidance for five-year reviews (USEPA, 2001).
7.1 Question A: Is the remedy functioning as intended by the decision documents?
Yes. The remedy resulted in the removal of soil to the ROD cleanup levels and/or on-site consolidation
under a protective cover. Site related groundwater contaminants have not been detected beyond the
compliance boundary at concentrations exceeding performance standards, nor on-site at concentrations
exceeding performance standards established to protect surface water. However, institutional controls,
as required under the ROD and ESD, have not been established yet.
The groundwater monitoring program may be modified via recommendations presented in the recent
hydrogeological evaluation report (AECOM, 2013; see Section 6.3.1).
7.2 Question B: Are the exposure assumptions, toxicity data, cleanup levels, and remedial action
objectives (RAOs) used at the time of remedy selection still valid?
No. EPA's dioxin reassessment has been developed and undergone review for many years, with the
participation of scientific experts in EPA and other federal agencies, as well as scientific experts in the
private sector and academia. The Agency followed current guidelines and incorporated the latest data
and physiological/biochemical research into the reassessment. On February 17, 2012, EPA released the
final human health non-cancer dioxin reassessment, publishing an oral non-cancer toxicity value, or
10
reference dose (RfD), of 7x10" mg/kg-day for 2,3,7,8-tetrachlorodibenzo-p-dioxin (TCDD) in EPA's
Integrated Risk Information System (IRIS). The dioxin cancer reassessment will follow thereafter. The
dioxin RfD was approved for immediate use at Superfund sites to ensure protection of human health.
These changes do not affect the current protectiveness of the remedy. However, institutional controls will
now also be required along the railroad right-of-way due to changes in toxicity values (see below).
7.2.1 Review of Human Health Risk Assessment
The baseline human health risk assessment performed in 2005 (M&E, 2005) concluded that there would
be significant risk to human health if groundwater from the site containing VOCs, SVOCs, dioxins, and
metals was used as a potable water supply in the future. The risk assessment further determined that the
following exposures to site soil exceeded EPA risk management guidelines:
Adolescent trespasser, due primarily to arsenic in surface and subsurface soil;
Town worker, due primarily to arsenic in surface soil;
Commercial worker, due primarily to dioxin and arsenic in surface soil, and pentachlorophenol
and arsenic in subsurface soil;
Utility worker, due primarily to arsenic in surface soil; and
On-site resident (Foxborough only), due primarily to dioxin, arsenic, and chromium in surface soil,
and pentachlorophenol and arsenic in subsurface soil.
While there were no exceedances of EPA's risk management guidelines due to exposures of site surface
water and sediment, it was noted in the 2005 ROD that, for the surface water and groundwater dermal
contact pathways, risk associated with dermal absorption could not be quantified for all contaminants
(due to lack of chemical-specific dermal absorption factors). This uncertainty was noted as something
that needed to be periodically reviewed as changes in dermal exposure assessment occurred.
MCLs were selected as compliance boundary groundwater performance standards for
pentachlorophenol, arsenic, and chromium. Additional onsite groundwater performance standards for the
7-1
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protection of surface water were developed based on Massachusetts ambient water quality criteria and
dilution associated with groundwater and river discharge. Risk-based soil cleanup levels were developed
based on site-specific exposure assumptions used in the human health risk assessment.
The 2005 ROD also noted that soil exposures within the area of the existing railroad right of way would be
evaluated during design, with appropriate action being implemented as necessary. This evaluation was
performed by EPA initially in 2007, using existing site data, and then updated in 2011 using data collected
in 2010 during the remedial action (Sevenson, 2011). The results indicated that risks were within the
acceptable risk range in the railroad right of way and that, therefore, deed restrictions were not required.
The 2011 ESD recommended a review of this risk evaluation during the five-year review. EPA completed
this review in June 2014 utilizing updated toxicity information, and determined that the potential estimated
exposure exceeds the acceptable level of 1 for hazard index, but that the exposure scenario is unlikely to
occur at the railroad right-of-way. Details of the review are provided in the June 2014 memo in Appendix
F. The implementation of institutional controls regulating land use in the railroad right-of-way is necessary
to assure that construction and utility worker exposures do not occur in the future.
The 2011 ESD included a change in the anticipated future land use on the Foxborough parcel, from
"residential" to "limited industrial" zoning, with the property being used as a parking facility. This change
resulted in a reevaluation of the arsenic cleanup level designated in the 2005 ROD. It was concluded that
the cleanup level being used for the rest of the site (for commercial/open space areas) was also
protective for the Foxborough parcel.
In this five-year review report, the toxicity values that served as the basis for the soil cleanup levels, as
contained in the 2005 ROD, have been re-evaluated to determine whether any changes in toxicity impact
the protectiveness of the remedy. Changes in toxicity values since the 2005 risk evaluation are also
discussed to determine whether reuse decisions remain valid. Any changes in current or potential future
exposure pathways or exposure assumptions that may impact remedy protectiveness are also noted. In
addition, environmental data, available since the 2005 ROD and implementation of the remedy, have
been qualitatively evaluated to determine whether exposure levels existing at the site present a risk to
current human receptors.
Changes in Toxicity
Table 2 presents a summary of the changes in toxicity values (oral reference doses and oral cancer slope
factors) for compounds selected as COPCs as identified in the 2005 risk assessment. Updated toxicity
information was obtained from the Integrated Risk Information System (USEPA, 2014a) and other current
EPA sources (e.g., the Superfund Health Risk Technical Support Center). Note that an increase in an
oral reference dose will decrease the resulting hazard quotient, while an increase in an oral slope factor
will increase the resulting cancer risk.
For most contaminants, any changes to toxicity information have been minimal and most would not have
any impact on selected site Contaminants of Concern (COCs) or remedy protectiveness. It should be
noted that not all site COCs (i.e., analytes which exceeded EPA's risk criteria) were utilized when
developing performance standards to protect receptors outside of the groundwater compliance boundary.
Therefore, although 1,1 '-biphenyl would have been selected as a COC based solely on changes in
toxicity values, it would likely not have been used to set a performance standard. Furthermore,
groundwater performance standards were developed based either on water quality standards or federal
MCLs, so changes to toxicity values would not impact the performance standards.
With respect to soil, if chromium at the site is evaluated as hexavalent chromium (typical unless
speciation or other justification is available), it would also have been selected as a COC based on the
changes in toxicity values. It was likely co-located with the other soil COCs which were remediated
(either excavated or covered), which would therefore not impact remedy protectiveness.
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A noteworthy change between 2005 and 2014 toxicity values is fordioxin. EPA's dioxin reassessment
has been developed and undergone review for many years, with the participation of scientific experts in
EPA and other federal agencies, as well as experts in the private sector and academia. The Agency
followed current guidelines and incorporated the latest data and physiological/biochemical research into
the reassessment. On February 17, 2012, EPA released the final human health non-cancer dioxin
10
reassessment, publishing an oral non-cancer toxicity value, or RfD, of 7x10" mg/kg-day for TCDD in
EPA's IRIS database. The dioxin cancer reassessment is ongoing. The dioxin RfD was approved for
immediate use at Superfund sites to ensure protection of human health. While dioxin was already a COC
in groundwater and soil (based on cancer risk), the new oral reference dose would have also resulted in a
hazard quotient above 1 for a nearby resident wading in the Rumford River, based on sediment exposure.
The sediment exposure point concentration (EPC) used for dioxin TEQ (toxicity equivalency) in 2005 was
1,641 ng/kg. The maximum dioxin TEQ resulting from sediment detections in 2012 was 173 ng/kg (see
Appendix C), which results in a hazard quotient equal to 1 when applying the site-specific parameters
utilized in the 2005 Human Health Risk Assessment (HHRA). Therefore, the remedy is still considered
protective.
In addition, based on a compilation and review of data on relative bioavailability of arsenic in soil (USEPA,
2012), arsenic was found to be less bioavailable via soil ingestion relative to other analytes. A default
value of relative bioavailability (RBA) of 60% is now applied during soil/sediment ingestion calculations of
risk/cleanup levels. This default RBA value reduces arsenic contribution to risk and/or increases arsenic
cleanup levels. The remedy remains protective with respect to arsenic exposures.
Table 2: Comparison of 2005 and 2014 Oral Reference Doses and Oral Cancer Slope Factors for
Compounds of Potential Concern
Oral Reference
Oral Slope Factor (SF)
Contaminant of
Dose (RfD)
Potential Concern
(mg/kg-day)
(mg/kg-day)"1
2005
2014
2005
2014
1,1,2-Trichloroethane
0.004
0.004
0.057
0.057
1,2-Dichloroethane
0.02
0.006
0.091
0.091
Trichloroethene
0.0003
0.0005
0.4
0.046
Vinyl chloride (a)
0.003
0.003
0.75
0.72
Xylenes (total)
0.2
0.2
N/A
N/A
1,1 '-Biphenyl
0.05
0.5
N/A
0.008
2,3,5,6-Tetrachlorophenol
0.03
0.03
N/A
N/A
2,4,6-T richlorophenol
0.0001
0.001
0.011
0.011
2,4-Dinitrophenol
0.002
0.002
N/A
N/A
2,6-Dinitrotoluene
0.001
0.0003
0.68
1.5
2-Methylnaphthalene
0.004
0.004
N/A
N/A
4,6-Dinitro-2-methylphenol
0.0001
0.00008
N/A
N/A
Acenaphthene
0.06
0.06
N/A
N/A
Acenaphthylene (c)
0.02
0.06
N/A
N/A
Acetophenone
0.1
0.1
N/A
N/A
Atrazine
0.035
0.035
0.22
0.23
Benzo(a)anthracene
N/A
N/A
0.73
0.73
Benzo(a)pyrene
N/A
N/A
7.3
7.3
Benzo(b)fluoranthene
N/A
N/A
0.73
0.73
Benzo(k)fluoranthene
N/A
N/A
0.073
0.073
Bis(2-ethylhexyl)phthalate
0.02
0.02
0.014
0.014
Chrysene
N/A
N/A
0.0073
0.0073
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Oral Reference
Oral Slope Factor (SF)
Contaminant of
Dose (RfD)
Potential Concern
(mg/kg-day)
(mg/kg-day)"1
2005
2014
2005
2014
Dibenz(a,h)anthracene
N/A
N/A
7.3
7.3
Dibenzofuran
0.002
0.001
N/A
N/A
Fluorene
0.04
0.04
N/A
N/A
lndeno(1,2,3-cd)pyrene
N/A
N/A
0.73
0.73
Naphthalene
0.02
0.02
N/A
N/A
Pentachlorophenol
0.03
0.005
0.12
0.4
Phenanthrene (c)
0.02
0.03
N/A
N/A
2,3,7,8-TCDD (Dioxin TEQ)
N/A
7E-10
1.5E+05
1.56E+05
Antimony
0.0004
0.0004
N/A
N/A
Arsenic
0.0003
0.0003
1.5
1.5
Barium
0.07
0.2
N/A
N/A
Cadmium (food)
0.001
0.001
N/A
N/A
Cadmium (water)
N/A
0.0005
N/A
N/A
Chromium
0.003
0.003
N/A
0.5
Lead (b)
N/A
N/A
N/A
N/A
Manganese (drinking water)
0.024
0.024
N/A
N/A
Manganese (diet)
0.07
0.14
N/A
N/A
Mercury
0.0001
0.0001
N/A
N/A
Thallium
0.00008
0.00001
N/A
N/A
Vanadium
0.001
0.005
N/A
N/A
Zinc
0.3
0.3
N/A
N/A
N/A = Not Applicable or Not Available
a. Vinyl chloride has toxicity values for both adult and child to account for mutagenic mode of action (see discussion below).
Toxicity values presented in table are for adult receptors.
b. Lead is currently evaluated through the use of exposure modeling for adults and children.
c. Naphthalene was used as a surrogate in the 2005 HHRA. Based on toxicity changes since that time, it would be considered
more appropriate to use acenaphthene as a surrogate for acenaphthylene and pyrene as a surrogate for phenanthrene due to
structural similarities.
Changes in Exposure Pathways/Assumptions
Since the 2005 HHRA, the Foxborough parcel was rezoned such that residential use is no longer
applicable (it is now a parking facility). The 2011 ESD changed the cleanup levels for this parcel to be
similar to the rest of the site (commercial/open space). No other changes in land use have occurred on or
near the site since the 2005 HHRA. Therefore, the land use assumptions used in the risk assessments
continue to be valid for the site. However, the implementation of institutional controls regulating land use
is necessary to assure that land use changes resulting in more intense human exposures than under
current conditions do not occur in the future.
The consolidation area cover on the Foxborough parcel remains intact, based on recent inspections.
Because contamination is present beneath the cover, prevention of a complete exposure pathway
between human receptors (e.g., commuters) and subsurface contamination is necessary. Continued
maintenance of the cover is required to assure that human exposure to the covered material does not
occur.
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Changes in Risk Assessment Methodology/New Guidance
A new method to evaluate compounds with mutagenic modes of action such as the carcinogenic PAHs
and vinyl chloride, which was not in use in 2005, is now recommended by EPA. The current methodology
calls for the use of age-specific adjustment factors to account for an increased sensitivity during early life.
Vinyl chloride also has a unique set of exposure equations to account for early-life exposures with a
separate set of toxicity values for adult and child. The early-life calculation does not affect the
conclusions of the 2005 evaluation for the commercial scenario (the land use which was utilized to define
cleanup levels), because workers are assumed to be greater than 16 years of age for which the early-life
component is not applicable. The 2005 evaluation showed that the cancer risk for the adolescent
trespasser scenario was less than that for the commercial worker scenario. However, as noted above,
the supplemental early-life calculation for child trespassers was not included as part of the 2005
evaluation. A supplemental calculation that included the early-life component for carcinogens with
mutagenic modes of action, performed as part of this five-year review, confirmed the conclusion that
adolescent trespasser cancer risk is less than the commercial worker risk. Therefore, the conclusions of
the 2005 supplemental risk evaluation continue to be valid. Institutional controls, as required by the ROD
and ESD, should be implemented to assure that future use of the site is consistent with the commercial
land use assumptions used in the 2005 risk evaluation, and that adolescent exposures of greater
frequency and intensity than assumed for trespassing (78 days per year for 10 years) do not occur. The
implementation of comprehensive institutional controls, as required by the ROD and ESD, is on-going,
and when complete, will provide long-term protectiveness for soil and groundwater remedies.
A recent EPA directive (USEPA, 2014b) was published which provides revised default exposure
parameter assumptions for various exposure scenarios. Many of these parameters differ from those
utilized in the 2005 site-specific HHRA. Most are related to residential exposures, which would not impact
the protectiveness of the remedy. There are, however, changes to the worker soil adherence factor
(reduction from 0.2 to 0.12 mg/cm-day), the worker skin surface area (increase from 3,300 cm2 to 3,470
cm2), and the worker body weight (increase from 70 to 80 kg). These changes result in an increase in the
cleanup levels which would provide the same level of Reasonable Maximum Exposure (RME) risk as
defined in the ROD. However, when the new toxicity values (see above) are also incorporated, the
cleanup levels fordioxin (due to non-cancer hazards) and pentachlorophenol would actually be reduced.
The following table shows the residual risk associated with the ROD cleanup levels (which were used
during the remedial action) using the current toxicity values, recommended arsenic RBA of 60%, and
updated exposure parameters:
Table 3. Soil Cleanup Levels (Commercial/Open Space)
Compound
ROD Cleanup
Level
(ppm)
Risk-Level
(established in
the ROD)
Risk-Level (using
current toxicity
values and
exposure
parameters)
Hazard Quotient
(using current
toxicity values and
exposure
parameters)
Benzo(a)pyrene
2.1
1 x 10 s
7 x 10~e
N/A
Dioxin TEQ
0.001
6 x 10~b
5 x 10~b
1*
Arsenic
16
1 x 10"e
5 x 10~e
0.03
Pentachlorophenol
90
1 x 10~b
2 x 10~b
0.03
Residual Risk
9 x 10~5
8 x 10~5
* The HQ value of 1 is rounded down from HQ of 1.4.In addition, after remediation a 6" soil cover was
placed across the site in areas not excavated.
The residual risk remains within EPA's target risk range.
No other changes to dermal exposure assessment have occurred which would change the protectiveness
of the remedy.
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Evaluation of Railroad Right-Of-Way
A review of the railroad right-of-way evaluations performed by EPA in 2007 and 2011 (Sevenson, 2011)
was performed as part of this five-year review, incorporating the toxicity value and exposure parameter
changes listed above. Using the 2010 soil data collected in the railroad right-of-way (see Figure 4.1 in
Appendix F), EPCs were established and used in risk calculations for a utility worker, using the current
toxicity values, arsenic RBA of 60%, and updated exposure parameters described above (see Appendix
F). The utility worker scenario was deemed the most appropriate for the active railroad right-of-way given
the fact that any intrusive work in the area is limited and carefully controlled by the railroad company. The
calculations resulted in a cancer risk of 1E-5, which is within EPA's target risk range. There is currently
no utility work being conducted in the railroad right-of-way so the remedy remains protective in the short
term. However, the non-cancer hazard index of 5 for utility worker (due primarily to applying the new
dioxin RfD) exceeds EPA's target hazard index of 1. The utility worker results show that institutional
controls, as required by the ROD and ESD, should also be applied to this area to protect future utility
workers.
Evaluation of Recent Sampling Data
As noted in Section 6.3.2, there have been no exceedances of groundwater performance standards for
site related contaminants beyond the compliance boundary in site monitoring wells. There is no evidence
at this time showing that the groundwater remedy is not protective. However, as discussed in Section
6.3.1, improvements to the groundwater monitoring network have been recommended. While there was
one private well detection of PCP above its MCL, based on a brief review of this well (shallow) and its
location relative to the site, the detection is not likely site-related. However, further
investigation/evaluation may be necessary to confirm this.
As discussed in Section 6.3.3, 2012 sediment detections were all below the maximum historical
detections of the same analytes, except for one dioxin congener (1,2,3,7,8,9-HxCDF) (see Table C-3 in
Appendix C). While there were two detections of arsenic above the 95% Upper Confidence Limit (UCL)
from the HHRA, which was used as the RME scenario EPC, these concentrations would not have
changed the HHRA conclusions regarding sediment risk. However, as the locations sampled in 2012
may not correspond with the historical locations which provided the maximum concentrations used in the
HHRA, it may be appropriate to include additional monitoring locations in future sampling efforts to
determine if those higher concentrations remain in the river.
While surface water monitoring data was not collected during the five years since remedy construction,
on-site groundwater concentrations have not been detected at levels above performance standards
developed to be protective of surface water.
7.2.2 Review of Ecological Risk Assessment
The baseline ecological risk assessment (BERA) (Lockheed Martin, 2004) performed for the site was
based on data collected during the remedial investigations (Rl). The media of concern were surface
water, sediments, and aquatic biota in the Rumford River. Due to the lack of habitat in contaminated soil
areas, soils were not evaluated in the BERA for risk to terrestrial receptors due to a lack of a complete
exposure pathway. The conclusion of the BERA was that benthic invertebrates, water column
invertebrates, fish, piscivorous birds and mammals feeding along the Rumford River are unlikely to be at
a substantial risk from exposure to site-related contaminants. Based on the results of the risk
assessment, the remedy did not include clean-up in the Rumford River, but recommended long-term
monitoring of groundwater, surface water, sediment, and fish tissue in order to confirm that groundwater
is not migrating off-site or adversely impacting the Rumford River above acceptable levels. Monitoring of
sediment and surface water was to be continued annually to ensure that contaminated groundwater is not
impacting off-site receptors and to ensure the protectiveness of the remedy.
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The BERA was conducted using methodology which would generally comply with current EPA risk
assessment guidance. The minor discrepancies between current guidance and previous guidance exist
in the areas of benchmarks and toxicity values utilized. For most contaminants, changes to toxicity
information have been minimal. There have been minor changes in National Ambient Water Quality
Criteria (NAWQC) since 2005. The NAWQCs were used as screening values (mainly metals and
pentachlorophenol) to select COCs in the BERA for surface water in the Rumford River. The NAWQCs
for metals used in the BERA were not adjusted for hardness in the river and the analytical data for
inorganics represented unfiltered metals which were not corrected to represent the dissolved fraction.
However, the selection of COCs would not have been different in the BERA if these adjustments had
been made, since all of the hardness-dependent inorganics that were likely to be site-related were
selected as COCs during the screening process, with the exception of copper.
The only change in NAWQCs relevant to the site was the change in the basis of the copper standard in
2007 with the adoption of the Biotic Ligand Model (BLM)-based criterion. The BLM is a metal
bioavailability model that uses receiving water body characteristics to develop site-specific freshwater
aquatic life criteria (USEPA, 2007). The BLM requires ten input factors, and these data were not all
collected in the surface water of Rumford River, so the site-specific value could not be calculated from the
data provided in the BERA. However, the selection of copper as a COC in surface water would not have
changed the conclusions of the BERA, or the protectiveness of the remedy. Additional measurement
endpoints, including toxicity testing, were utilized to evaluate surface water toxicity, and were the primary
basis for determination in the BERA that there were not significant risks to aquatic receptors in the river.
The selection of COCs in sediment was based on screening that is generally consistent with methodology
and benchmarks currently used in ecological risk assessments and consistent with guidance.
Dioxins and furans were major COCs of concern evaluated in the BERA. All of the methods used in the
BERA were generally consistent with current guidance (USEPA, 2008). In the BERA, the concentrations
of individual dioxin and furan congeners in surface water, sediments and aquatic biota were measured
and multiplied by published toxic equivalence factors (TEFs) for fish, birds and mammals. The TEFs
were summed to calculate receptor-specific toxic equivalent (TEQ) values for use in the exposure
calculations. The BERA used toxicity reference values (TRVs) and critical body residues that were
conservative. More recent data, particularly for mink (piscivorous mammal), have indicated that the TEQ
method and TRVs used in the BERA are likely to over-estimate reproductive effects (Moore et al., 2012;
Blankenship et al., 2008). Exceedance of the TRVs used in the mink food-chain models would not
necessarily be expected to lead to adverse effects. The BERA concluded that there was no significant
risk to piscivorous mammals (mink) expected based on the conservative analysis and TRVs utilized;
consequently, the remedy is considered protective.
The ROD recommended monitoring of sediment and surface water be continued annually until completion
of the first five-year review after construction of the remedy is completed in order to document conditions
at and near the site. A round offish tissue sampling was to be performed in conjunction with the five-year
review as well. Although a fish survey was performed prior to this five-year review, no additional fish
tissue data were collected, thus it could not be confirmed whether or not the concentrations of
contaminants in fish continue to indicate negligible risk to fish populations.
Sediment monitoring was performed in May 2012 at four locations in the Rumford River. As discussed in
Section 6.3.3, 2012 sediment detections were all below the maximum historical detections of the same
analytes, except for one dioxin congener (1,2,3,7,8,9-HxCDF) (see Table C-3 in Appendix C).
In conclusion, since the BERA was prepared in 2005, there are no newly promulgated standards, relevant
to the site, which bear on the protectiveness of the remedy. The reference values and exposure
assumptions in the BERA were conservative and therefore protective. There are no major changes in
site conditions or exposure assumptions upon which the risk assessment was based that would result in
increased exposure or risk. Recent sediment sampling data from the Rumford River indicate that
sediment COC concentrations detected in 2012, with the exception of one dioxin congener (1,2,3,7,8,9-
HxCDF). Were below measurements evaluated for exposures in the BERA.
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7.2.3 ARARs Review
A review of Applicable or Relevant and Appropriate Requirements (ARARs) was performed to check the
impact on the remedy due to any changes in standards that were identified as ARARs in the ROD, newly
promulgated standards for chemicals of potential concern, and TBCs (to be considered) that may affect
the protectiveness of the remedy. Tables documenting the review of each ARAR, using the regulations
and requirement synopses listed in the ROD as a basis, are presented in Appendix G. The evaluation
included a determination of whether the regulation is currently ARAR orTBC and whether the
requirements have been met. A discussion of the review is summarized below.
The 2005 ROD set forth the following ARARs for the selected remedy:
Location-Specific:
Executive Order 11990 (Protection of Wetlands)
Executive Order 11988 (Floodplain Management)
Fish and Wildlife Coordination Act
Resource Conservation and Recovery Act (RCRA)
Endangered Species Act
310 CMR 10.00 - Massachusetts Wetlands Protection Regulations
321 CMR 10.00 - Massachusetts Endangered Species Act Regulations
Action-Specific:
Clean Water Act (CWA)
Rivers and Harbors Act of 1899
Safe Drinking Water Act (SDWA)
Resource Conservation and Recovery Act (RCRA)
National Emission Standards for Hazardous Air Pollutants (NESHAPs)
314 CMR 4.00 - Massachusetts Surface Water Quality Standards
314 CMR 9.00 - Massachusetts Certification for Dredging, Dredged Material Disposal, and
Filling in Waters
314 CMR 3.00 - Massachusetts Surface Water Discharge Permit Program
314 CMR 6.00 - Massachusetts Groundwater Quality Standards
310 CMR 22.00 - Massachusetts Drinking Water Regulations
310 CMR 6.00 - Massachusetts Ambient Air Quality Standards
310 CMR 7.00 - Massachusetts Air Pollution Control Regulations
310 CMR 30.00 - Massachusetts Hazardous Waste Management Regulations
Additional policies, criteria, and guidance were identified in the ROD as TBC, including:
American Conference of Governmental Industrial Hygienists (ACGIH) Threshold Limit Values
(TLVs)
EPA Risk RfDs, Carcinogen Assessment Group Potency Factors, and Carcinogenicity Slope
Factors
EPA Draft Guidance for Evaluating the Vapor Intrusion to Indoor Air Pathway from
Groundwater and Soils
EPA Guidance: Approach for Addressing Dioxin in Soil at CERCLA and RCRA Sites
Ontario Ministry of Environment and Energy Lowest and Severe Effect Levels (LELs and
SELs) for Freshwater Sediments
EPA Policy on Floodplains and Wetland Assessments for CERCLA Actions
Massachusetts Threshold Effects Exposure Levels (TELs) and Allowable Ambient Air Limits -
Annual (AALs)
EPA Revised Alternative Cap Design Guidance Proposed for Unlined, Hazardous Waste
Landfills in the EPA Region I
EPA Technical Guidance Document: Final Covers on Hazardous Waste Landfills and Surface
Impoundments
7-8
-------
SDWA MCLs were selected as compliance boundary groundwater performance standards for
pentachlorophenol, arsenic, and chromium. MCLs have not changed since the 2005 ROD for these
contaminants. Additional onsite groundwater performance standards for the protection of surface water
were developed for pentachlorophenol, arsenic, and chromium based on Massachusetts ambient water
quality criteria and dilution associated with groundwater and river discharge. The ambient water quality
criteria for these contaminants have not changed since the 2005 ROD. Cleanup levels for soil were risk-
based and EPA's 1998 OSWER Directive Approach for Addressing Dioxin in Soil at CERCLA and RCRA
Sites, which is no longer in effect, was specifically used in setting the soil cleanup level for dioxin.
Section 7.2.1 addresses the potential impacts of changes in EPA toxicity values and addition of an RfD
for dioxin since the 2005 ROD.
Vapor intrusion was evaluated in the baseline human health risk assessment consistent with the EPA's
2002 Draft Guidance for Evaluating the Vapor Intrusion to Indoor Air Pathway from Groundwater and
Soils. Any changes to the vapor intrusion guidance (once finalized) would be considered with respect to
the institutional controls, as required by the ROD and ESD, and future building construction.
The requirements of many of the ARARs identified in the ROD were met during remedy construction.
7.3 Question C: Has any other information come to light that could call into question the
protectiveness of the remedy?
No. There is no other information that calls into question the protectiveness of the remedy.
7-9
-------
SECTION 8.0
ISSUES
Based on the activities conducted during this five-year review, the issues identified in Table 4 have been
noted.
Table 4: Issues
Issue
Affects Protectiveness (YIN)
Current
Future
Institutional controls restricting land uses that may impact the
protectiveness of the remedy (including preventing the use of
groundwater, protecting the consolidation area cover and other
components of the remedy) need to be established. Also, an
updated risk evaluation shows that the railroad right-of-way will
also require institutional controls to protect workers who may
contact soil in that area.
N
Y
The 2012 sediment sampling event included locations which
were not collected at the historic sampling locations and the
results showed lower contaminant concentrations than seen
previously. As a result, it is uncertain whether the higher
concentrations historically seen remain at the Site. If the
historic concentrations are still present, recent changes to
toxicity values and exposure parameters included in risk
evaluation for sediment may result in a future change to the
protectiveness determination with respect to sediment
exposure.
N
Y
The fish tissue collection required by the ROD was not
performed due to a lack of fish in the Rumford River. Also,
surface water sampling required by the ROD was not
performed due to EPA and MassDEP's agreement to continue
discussions about the future operation and maintenance plan
for the site.
N
Y
Determine whether a PCP detection above its MCL in a private
groundwater supply well is site-related.
N
Y
Active irrigation wells have been identified approximately 300
feet beyond the compliance boundary. Irrigation wells are not
expected to create enough drawdown to induce groundwater to
flow to them from the compliance boundary. An on-site
monitoring well just east (upgradient) of the compliance
boundary does indicate the presence of contamination at
concentrations above performance standards.
N
Y
8-1
-------
SECTION 9.0
RECOMMENDATIONS AND FOLLOW-UP ACTIONS
In response to the issues noted in Section 8.0 it is recommended that the actions listed in Table 5 be
taken:
Table 5: Recommendations and Follow-up Actions
Affects
Issue
Recommendations/
Follow-up Actions
Party
Responsible
Oversight
Agency
Milestone
Date
Protectiveness?
(Y/N)
Current
Future
Institutional
controls are not
Prepare
documentation and
EPA/
MassDEP
EPA
Aug 2019
N
Y
in place
record the AULs
Sediment
If accessible, collect
sampling
coverage is
limited
sediment samples
from locations which
correspond to
historical sampling
locations and assess
the new data.
MassDEP
EPA
Dec 2018
N
Y
Surface water
Review current site
and fish tissue
information,
not sampled
determine the need
for and, if necessary,
collect any additional
data. Update/
document changes in
EPA/
MassDEP
EPA
Dec 2018
N
Y
the monitoring
requirements
accordingly.
PCP detection in
Perform evaluation
a private well
which potentially
includes the
following: determine
if detection is real
(potential
resampling); review
well construction and
EPA
EPA
Dec 2016
N
Y
any potential
hydrogeologic
connection to the
site; and review
nearby potential
sources.
Active irrigation
Additional
wells identified
investigations should
near compliance
be conducted to
EPA/
MassDEP
boundary.
confirm whether
groundwater flow
directions have been
impacted by the
irrigation wells.
EPA
Dec 2015
N
Y
10-1
-------
SECTION 10.0
PROTECTIVENESS STATEMENTS
The remedy at the Hatheway & Patterson Superfund Site currently protects human health and the
environment because remediation of soil (soil removal and on-site consolidation) has been completed to
cleanup levels that are considered protective for the anticipated future use of the property, and there is no
current use of on-site groundwater which is classified as non-potable. However, in order for the remedy
to be protective in the long-term, institutional controls need to be created and recorded to restrict
inappropriate land uses (including use of groundwater) and protect the consolidation area
cover. Operation and maintenance activities have been initiated and will ensure that the consolidation
cell and associated components of the remedy (e.g., groundwater monitoring wells) remain in good
condition. In addition, monitoring of groundwater will continue to assess the protectiveness of the
remedy.
10-2
-------
SECTION 11.0
NEXT FIVE-YEAR REVIEW
The next Five-Year Review for the Hatheway & Patterson Superfund Site is due in September 2019, five
years from the signature date of this review.
-------
APPENDIX A
FIGURES
-------
Location of Facility
FIGURE 1.1
Site Location
Q
Feet
0 2,000
amecฎ
AMEC Earth and Environmental, Inc.
2 Robbins Road
Westford, MA 01886
(978) 692-9090
SITE LOCATION MAP
Hatheway and Patterson
Superfund Site
35 County Street
Mansfield, MA
H:\Sevenson\Hath&Pat\Task1\MXD\Site_Locus_Figure_1-1.mxd H:\Sevenson\Hath&Pat\Task1\Export\Site_Locus_Figure_1-1.pdf Sept 25, 2009 DWN: TEH CHKD: Base Map Data from ESRI, 7/1/1989.
-------
no u*F\
ฆMM A -=p=
NORTHEAST QUADRANT
[ i-u 1 i i 1 11_ Tsasi-i-
NORTHWEST QUADRANT
' W/F
Town of Poxborough
Book 11412 "page 403
Gas Line
Apprjf.. Reportecl
Locdtten
N/r
Thomus Vatrochf, Jr.. Trustee
Colony Realty Trust
Book 5S75 page J 76
QUADRANT LINE
FOKBORO PARCEL %
&sa\g&
N/F
MeVi York Central Lineฎ,
Book S579 Page 28
H44"31'
N/F"
Weซ. Yorfc Central Linปg, llC
Book 6279 Pqge 2S
QUADRANT LINE
SOUTHWEST QUADRANT
SOUTHEAST QUADRANT
-Concrete Pedestals
(Typical 9 Places)-?
7awn of ^DKborijugh
'U\V- M76
MซKI06FH
K'v-:
M/r
Faundary, LLC
MW-QIfl-
MYM97R-
QUADRANT LINE
N/F
Winffrart V). 4 Gfcraldirie
Siapben M. & Kathleen f,
Gannon
Swit 3921 page 141 /
MVP
Staph en M. Spile wski
Book B3S4 page 275
H/F
John M. se Oafina M
Harrington
Boot 3146 pago .VJj
N/F
Klmuerly 0. Hnratmann
5: Michael J. Mai I an
Book 133BD page 727
N/F
Francesco 0ryllc
took T50S1 poge 347
LEGEND:
LOCATION OF PRE-DESIGN INVESTIGATION TEST-PlT (WW + NE QUADRANTS); SOILS COVERED WITH NON-REINFORCED
v>35W56'
R= 240.00
The locations and dimensions of the onslte tracks are sppronlmate-
The location of the 4 Inch gae line located along Country Street Is approximate.
Electrical power lines run along the western boundaiy of the Foxboro parcel.
Sewer connection leading to the former location of Building No. 3 was capped within the footprint of
Building No. 3.
Monitoring Wells MW-A through MW-G are sumps and piezometers associated wtth the LNAPL Recovery
System. The recovery eump for the system Is located In the vldnlty of MW-O.
Existing conditions present am taken from drawing entitled "Boundary/Topographic Survey
Land Now or Formerly of HPC Realty Trust" by Conklin & Scroka, Inc. dated August 22,2006.
GRAPHIC SCALE
Sevenson
Environmental
Services, Inc.
SERVICES. INC.
77&9 LOCKPORT ROAO
MAOARA FALLS, NY 14Mป
SOURCE DRAWING FROM CONSTRUCTION SPECIFICATIONS,
HATHEWAY & PATTERSON SUPERFUND SFTE, METCALF & EDDY. IMC
AND TRC ENVIRONMENTAL CORPORATION, 2008.
&
&
A
A
&
&
&
REV
D
M
r
I88UBREVIป0N DESCRIPTION
ENG.
APPR,
US miriy Cbrps.
i.l EngimnsrsSj
Clients;
UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
UNITED STATES ARMY CORPS OF ENGINEERS
AMEC Earth & Environmental
2 ROaaNSRQAD
WEBTFQRD, MASSACHUSETTS 01800
amec
OH1QWL SCALE:
AS SHOWN
PRE-REMEDIATTON SITE FEATURES
HATHEWAY AND PATTERSON SITE
35 COUNTY STREET
MANSFIELD, MASSACHUSETTS
-------
FIGURE B-1
SITE LAYOUT
HATHEWAY AND PATTERSON SITE
15 COUNTY ROAD
MANSFIELD, MASSACHUSETTS
TRC
foot of John ftrwt
LovMI, HA 01852
974-970-3600
Melcalf & Eddy
TRC PROJ. NO.: 021M-0+90-01 *39
CPA CONTRACT NO-: U-M-C041
RAC SU8C0HTRACT0A: 107041
-------
-------
75 150 225 300
SCALE IN FEET
Figure 2
OVERBURDEN GROUND WATER
ELEVATION MAP (APRIL 2004)
HATHEWAY AND PATTERSON SITE
15 COUNTY ROAD
MANSFIELD, MASSACHUSETTS
_ 6osซl Mills South
foot at John Streal
f ML k.O-eซ. UK 0185J
m 9 78-970-5600
mc PROJ. MO.: 021J8-0490-01X39
EPA CONtRACT MO.: 68-W8~0Q42
Me tea If & Eddy
rac subcontract no- io?06i
-------
NOTE:
MS- NOT SURVEYED
0 75 ISO 225 300
Figure 3
BEDROCK GROUND WATER
ELEVATION MAP (APRIL 2004)
HATHEWAY AND PATTERSON SITE
15 COUNTY ROAD
MANSFIELD, MASSACHUSETTS
TRC
Scott Mills South
foot of Joป*n Street
Lowell, MA 01852
978-970-5600
Metealf & Eddy
IRC PROJ MO : 02136-049G-01XJ9
EPA CONTRACT NO,: &8-W6-Q042
ftAC SUBCONTRACT NO.; 107061
-------
Mansfield
Service
Chauncy St
^ o
yyalteh" frve
fctafrnanAsi*
0 Manstteld
North ;
Common
" '''0*"-:S
0 St "t.,
% 2
1 <
-ฃ
V
Caiman,
Cafe
Fulk*
ฆo
ThomPsor' ~
Pratt St
Pleasant St
o
cottafl6 51 =
w ctiurc^ St
Al-Noor i.
Academy w
70
e
3
Hvg*1 st
<5* sanno5el ^'e
Map d&ia ฎ2013 Goofl+
Possible Private Weil To Be Considered For Sampling
Q Possible Private Well
higure 5. Possible Private Wells
-------
132 Highland Ave
Town 1
KINGMAN AVENUE
Town 2
18,Thomas St
[pCeasant street
CHURCH,
Si I E
MB
A
Well
Underpass Dewatering System
FIGURE 6
PRIVATE WELLS AND UNDERPASS
DEWATERING SYSTEMS
AZCOM
-------
APPENDIX B
LIST OF DOCUMENTS REVIEWED AND REFERENCES
AECOM. 2013. Hydrogeologic Conditions Report. Letter report addressed to Mr. David Lederer of EPA-
New England, Region 1. March 29, 2013.
Blankenship, A. L., Kay, D. P., Zwiernik, M. J., Holem, R. R., Newsted, J. L., Hecker, M., & Giesy, J. P.
2008. Toxicity reference values for mink exposed to 2, 3, 7, 8-tetrachlodibenzo-p-dioxin (TCDD)
equivalents (TEQs). Ecotoxicology and Environmental Safety, 69(3), 325-349.
Environmental Strategies & Management (ESM). 2012a. Field Work Reporting Memo - May 2012.
Operations and Maintenance - Hatheway and Patterson, Mansfield, MA. July 25, 2012.
Environmental Strategies & Management (ESM). 2012b. Field Work Reporting Memo - October 2012.
O&M Activities at the Hatheway and Patterson Superfund Site, Mansfield, MA. December 18, 2012.
Environmental Strategies & Management (ESM). 2013. Fish Survey Report. Hatheway and Patterson
Site, Mansfield, MA. October 1, 2013.
Environmental Strategies & Management (ESM). 2014. Field Work Reporting Memo - November 2013.
O&M Activities at the Hatheway and Patterson Superfund Site, Mansfield, MA. January 6, 2014.
Lockheed Martin Information Technologies. 2004. Baseline Ecological Risk Assessment. Hatheway &
Patterson Superfund Site, Mansfield, Massachusetts. July 2004.
Metcalf & Eddy, Inc. (M&E). 2005. Baseline Human Health Risk Assessment. Hatheway & Patterson
Superfund Site, Mansfield, Massachusetts. EPA Contract No. 68-W6-0042, Work Assignment No. 142-
RICO-01X3. January 2005.
Moore, J. N., Zwiernik, M. J., Newsted, J. L., Fitzgerald, S. D., Link, J. E., Bradley, P. W., Kay, D.,
Budinsky, R., Giesy, J. P. and Bursian, S. J. (2012), Effects of dietary exposure of mink (Mustela vison) to
2,3,7,8-tetrachlorodibenzo-p-dioxin, 2,3,4,7,8-pentachlorodibenzofuran, and 2,3,7,8-
tetrachlorodibenzofuran on reproduction and offspring viability and growth. Environmental Toxicology
and Chemistry, 31: 360-369.
Sevenson Environmental Services, Inc. 2011. Final Remedial Action Completion Report. Hatheway and
Patterson Superfund Site. Mansfield, Massachusetts. September 2011.
TRC Environmental Corporation (TRC), 2005. Interim Final Remedial Investigation Report, Hatheway &
Patterson Superfund Site, Mansfield, Massachusetts. April 2005.
TRC Environmental Corporation (TRC), 2008. Construction Specifications, Hatheway & Patterson
Superfund Site, Mansfield, Massachusetts. September 2008.
U.S. Environmental Protection Agency (USEPA). 2001. Comprehensive Five-Year Review
Guidance. June 2001.
U.S. Environmental Protection Agency (USEPA). 2005. Record of Decision. Hatheway & Patterson
Superfund Site, Mansfield-Foxborough, Massachusetts. September 30, 2005.
U.S. Environmental Protection Agency (USEPA). 2007. Aquatic Life Ambient Freshwater Quality Criteria
-Copper. 2007 Revision. Office of Water. EPA-822-R-07-001. February 2007.
U.S. Environmental Protection Agency (USEPA). 2008. Framework for Application of the Toxicity
Equivalence Methodology for Polychlorinated Dioxins, Furans, and Biphenyls in Ecological Risk
Assessment. EPA/100/R-08/004.
U.S. Environmental Protection Agency (USEPA). 2011a. Declaration for the Explanation of Significant
Differences. Hatheway & Patterson Superfund Site, Mansfield/Foxborough, Massachusetts. August 2011.
-------
U.S. Environmental Protection Agency (USEPA). 2011b. Operations and Maintenance Manual.
Hatheway and Patterson Superfund Site, Mansfield, Massachusetts. Version 1.0. September 2011.
U.S. Environmental Protection Agency (USEPA). 2012. Compilation and Review of Data on Relative
Bioavailability of Arsenic in Soil and Recommendations for Default Value for Relative Bioavailability of
Arsenic in Soil Documents. OSWER Directive 9200.1-113. December 31, 2012.
U.S. Environmental Protection Agency (USEPA). 2014a. Integrated Risk Information System. Available
at http://www.epa.gov/iris/. May 2014.
U.S. Environmental Protection Agency (USEPA). 2014b. Human Health Evaluation Manual,
Supplemental Guidance: Update of Standard Default Exposure Factors. OSWER Directive 9200.1-120.
February 6, 2014.
-------
APPENDIX C
ANALYTICAL RESULTS
-------
GROUNDWATER ANALYTICAL RESULTS
-------
TABLE C-1. PENTACHLOROPHENOL (PCP), DIOXIN TEQ, ARSENIC, AND CHROMIUM CONCENTRATIONS
IN SELECT WELLS AT HATHEWAY & PATTERSON, 2001 TO 2012
Dec 2002 (unless footnoted)
May 2011
May 2012
Oct 2012
Apr 2013
Oct/Nov/Dec 2013
Well No.
Notes
PCP
Dioxin TEQ
As
Cr
PCP
Dioxin TEQ
As
Cr
PCP
Dioxin TEQ
As
Cr
PCP
Dioxin TEQ
As
Cr
PCP
Dioxin TEQ
As
Cr
PCP
Dioxin TEQ
As
Cr
ug/L
pg/L
ug/L
ug/L
ug/L
pg/L
ug/L
ug/L
ug/L
pg/L
ug/L
ug/L
ug/L
pg/L
ug/L
ug/L
ug/L
pg/L
ug/L
ug/L
ug/L
pg/L
ug/L
ug/L
MW-011
O
BK
LT
NA
NA
0.55(1)
<2.5(1)
<0.5
0.186
ND
ND
<11(2)
0.0126131
<8(2)
<50(2)
<11(2)
NCD(2)
<8(2)
<50(2)
<1<2)
0.013131
<8(2)
<50(2)
<1<2)
0.38(3)
<8(2)
<50(2)
MW-111
O
ICB
LT
I
NCD
4.4
ND
<10
0.00336
<8
<50
<10
0.21
<8
<50
3
0.023
<8
<50
2
0.25
<8
<50
MW-113
O
ICB
LT
86.4
NCD
3.2
. .
51
0.00269
<50
130
NCD
<50
110
NCD
<50
110
0.16
<50
1.1
RCA-9
O
ICB
LT
2.1w
NA
0.14 B(4)
<2.5141
<0.5(2)
0 171O)
ND
0.7(3)
<1
NCD
<8
<50
<1
0.59
<8
<50
MW-111R
B
ICB
LT
4 (5)
NA
3.6(5)
<2.5|5>
1270
0.0938
3.5
2.4
350
0.00399
<8
<50
1400
NCD
<8
<50
1200
0.081
15
<50
1200
0.38
<8
<50
MW-113R
B
ICB
LT
1 >
0.00363
1.6
2.3
70
0.003
<8
<50
200
7.66
<8
<50
140
NCD
<8
<50
<1
0.26
<8
<50
MW-107
O
BOB
LT
| <0,
0.00115
9
1.2
<11
NCD
10
<50
<10
NCD
8
<50
<1
NCD
<8
<50
<1
0.17
<8
<50
MW-107R
B
BOB
LT
<0.2(5)
NA
42 (5)
<2.5(51
<0.5
NCD
ND
0.6
<10
0.00579
<8
<50
<10
NCD
<8
<50
<1
NCD
<8
<50
<1
0.18
<8
<50
MW-109R
B
BOB
LT
<0.2(5)
NA
2.5(5)
<2.5(51
<0.5
1.31
3.5
ND
<10
0.00513
<8
<50
<10
1.32
<8
<50
<1
0.011
<8
<50
<1
0.52
<8
<50
RCA-8
O
ICB
18(4>
NA
1.2(4)
NA
11
34.6
<8
<50
13
44.66
<8
<50
Compliance Boundary
Performance Standard
1
30
10
100
1
30
10
100
1
30
10
100
1
30
10
100
1
30
10
100
1
30
10
100
On-Site Performance
Standard (Surface Water
Protection)
1,792
None
Established
17,924
1,314
1,792
None
Established
17,924
1,314
1,792
None
Established
17,924
1,314
1,792
None
Established
17,924
1,314
1,792
None
Established
17,924
1,314
1,792
None
Established
17,924
1,314
1. Nov 2001
2. Sample and duplicate sample were analyzed. For non-detects, value reflects higher reporting limit (RL) if RLs were different.
3. Value is average of two (sample and duplicate) analyses
4. Dec 2003
5. Oct 2004
Column 2 Notes: O = Overburden Well; B = Bedrock Well; BK = Background Location; BOB = Beyond Compliance Boundary; ICB = Inside Compliance Boundary;
LT = Long-Term Monitoring Location, per Groundwater, Surface Water, and Sediment Sampling and Analysis Plan (SES, 2011)
Dioxin TEQ calculated using WHO 2005 TEFs (ND=0) except for Oct/Nov/Dec 2013, calculated using MassDEP 1995 TEFs (ND=0). Results using WHO TEFs would be less conservative and therefore still not exceed the performance standard.
ND = Not detected (reporting limit unknown)
NCD = No congeners detected, and no dioxin TEQ calculated
NA = Not analyzed
TEQ - Toxicity Equivalence
TEF - Toxicity Equivalence Factor
WHO - World Health Organization
Values in bold italic exceed performance criteria
"Less than" i = j values in bold = reporting limit is higher than performance standard
Light gray shading = well was not sampled
Sources: May 2011 results taken from Analytical Data Report prepared by Waste Stream Technology Inc, 06/09/11 (Note that concentrations are incorrectly reported in
Remedial Action Completion Report (SES, Sep 2011). May 2012 through Dec 2013 results taken from reports prepared by Environmental Strategies & Mgmt (Jul and
Dec 2012; Jan 2014). Pre-2011 results taken from Interim Final Rl Report, Hatheway & Patterson Superfund Site (M&E/TRC, Apr 2005)
-------
2014 PRIVATE WELL MONITORING
-------
Table C-2. Hathewav & Patterson Private Well Sampling - June 2014
18 Thomas Street
136 Highland Ave
46 Chauncy Street
325 N Main Street
Town 1
Town 2
132 Highland ave
132 Highland
ave(FD)
Max Detect
MCL
6/18/2014
6/18/2014
6/18/2014
6/18/2014
6/18/2014
6/18/2014
6/18/2014
6/18/2014
Cone.
RL
Cone.
RL
Cone.
RL
Cone.
RL
Cone.
RL
Cone.
RL
Cone.
RL
Cone.
RL
Beryllium
ug/L
ND
0.2
0.2
0.2
ND
0.2
ND
0.2
ND
0.2
ND
0.2
ND
0.2
ND
0.2
0.2
4
Aluminum
ug/L
ND
5
59
5
ND
5
ND
5
ND
5
10
5
36
5
49
5
59
Vanadium
ug/L
ND
0.2
ND
0.2
ND
0.2
ND
0.2
0.28
0.2
ND
0.2
ND
0.2
0.22
0.2
0.28
Chromium
ug/L
1
0.5
ND
0.5
ND
0.5
ND
0.5
ND
0.5
ND
0.5
0.5
0.5
0.56
0.5
1
100
Manganese
ug/L
27
0.2
20
0.2
1600
0.2
2600
2
1.5
0.2
1400
0.2
11
0.2
11
0.2
2600
Cobalt
ug/L
ND
0.2
ND
0.2
2.2
0.2
8.1
0.2
ND
0.2
5
0.2
ND
0.2
ND
0.2
8.1
Nickel
ug/L
3.2
0.2
1.3
0.2
3.3
0.2
3.4
0.2
1.8
0.2
6.7
0.2
2.1
0.2
2.2
0.2
6.7
Copper
ug/L
22
0.5
1.2
0.5
7.4
0.5
3.7
0.5
1.9
0.5
7.2
0.5
46
0.5
78
0.5
78
1300
Zinc
ug/L
13
5
88
5
590
5
18
5
19
5
39
5
17
5
24
5
590
Arsenic
ug/L
ND
1
ND
1
4.1
1
ND
1
ND
1
ND
1
ND
1
ND
1
4.1
10
Selenium
ug/L
ND
1
ND
1
ND
1
ND
1
ND
1
ND
1
ND
1
ND
1
ND
50
Silver
ug/L
ND
0.2
ND
0.2
ND
0.2
ND
0.2
ND
0.2
ND
0.2
ND
0.2
ND
0.2
ND
Cadmium
ug/L
ND
0.2
ND
0.2
ND
0.2
ND
0.2
ND
0.2
ND
0.2
ND
0.2
ND
0.2
ND
5
Molybdenum
ug/L
ND
1
ND
1
ND
1
ND
1
ND
1
ND
1
ND
1
ND
1
ND
Antimony
ug/L
ND
0.5
ND
0.5
ND
0.5
ND
0.5
ND
0.5
ND
0.5
ND
0.5
ND
0.5
ND
6
Barium
ug/L
92
0.2
42
0.2
41
0.2
60
0.2
32
0.2
300
0.2
60
0.2
61
0.2
300
2000
Thallium
ug/L
ND
0.5
ND
0.5
ND
0.5
ND
0.5
ND
0.5
ND
0.5
ND
0.5
ND
0.5
ND
2
Lead
ug/L
1.3
0.2
ND
0.2
0.58
0.2
0.46
0.2
ND
0.2
0.74
0.2
3.5
0.2
7.6
0.2
7.6
15
Magnesium (mg/L)
mg/L
7.2
0.1
1.6
0.1
3.8
0.1
4.2
0.1
1.7
0.1
6.9
0.1
2.1
0.1
2.1
0.1
7.2
Calcium (mg/L)
mg/L
67
0.2
15
0.2
59
0.2
33
0.2
18
0.2
57
2
24
0.2
24
0.2
67
Iron
ug/L
ND
50
ND
50
3200
50
3100
50
ND
50
3500
50
340
50
940
50
3500
Uranium
ug/L
ND
1
ND
1
ND
1
ND
1
ND
1
ND
1
ND
1
ND
1
ND
30
Pentachlorophenol
ug/L
ND
0.2
ND
0.2
ND
0.2
2.7
DB
ND
0.2
ND
0.2
ND
0.2
ND
0.2
2.7
1
Dioxin TEQ
Pg/L
0.281
0.196
0.375
1.58
0.197
0.28
0.646
0.255
1.58
ug/L
2.81E-07
1.96E-07
3.75E-07
1.58E-06
1.97E-07
2.80E-07
6.46E-07
2.55E-07
1.58E-06
3.00E-05
Notes:
RL - Reporting Limit
ND - Not Detected
DB - Value reported is from a diluted sample and there was contamination associated with a laboratory blank
FD - Field Duplicate
TEQ - Toxicity Equivalency - based on WHO 2005 values
-------
Hatheway & Patterson Well Sampling
June 18, 2014
UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
REGION I
DATE: July 22, 2014
SUB J: Hatheway and Patterson Ground water Sampling and Analysis - June 2014
FROM: Jerry Keefe, EIA Team Leader
TO: Kimberly White, RPM OSRR
I. Background Information
A. Date of Sampling:
B. Weather Conditions:
C. USEPA Representatives:
D. Samples Requested by:
E. Address:
II. Purpose of Sampling
The sampling event was being done as part of a 5-year review to obtain additional information on potential
contaminant migration in the site aquifer. The objective of the sampling event was to collect representative
groundwater samples from private irrigation wells; all the properties are connected to a public water supply system
for drinking water. Samples will be analyzed for dioxin/furans, PCP (pentachlorophenol), and metals. NERL will be
analyzing samples for metals. The Dioxin and PCP samples will be analyzed at a CLP laboratory and is not discussed
in this summary report.
Wednesday, June 18
Mostly sunny, approximately 85 degrees F
Jerry Keefe
Mike Looney
Kim White, RPM OSRR
Various locations within the town of Mansfield, Massachusetts
III. Description of Sampling Locations
Sample locations and descriptions are shown in table 1.
-------
Hatheway & Patterson Well Sampling
June 18, 2014
Table 1
Sample
Location/
Address
Owner/phone#
Map/Lot
#
Time
Comments
Mansfield
Fabric Care
Center/18
Thomas St,
Mansfield, MA
Billings Realty Trust
Fontanini & Kennedy Trs
508-339-9057
Map 021,
Lot 182
0935
Sampled at Spigot before filters. (Picture 1)
Temperature -14.0 C
Conductivity - 1618 uS/cm
pH - 6.19
Private
Residence/ 136
Highland Ave,
Mansfield, MA
John & Donna Harrington
508-339-8731
Map 018,
Lot 460
1038
Sampled at pump head. (Picture 2)
Temperature - 11.2 C
Conductivity - 363.6 uS/cm
pH - 5.53
Car Wash / 46
Chauncy St,
Mansfield, MA
Nicks Realty Trust
Nicholas & Steven Anagnos
508-339-9556
Map 022,
Lot 008
1130
Sampled at top of system not thru hose. (Picture 3)
Readings are grabs, flow was to high from system.
Flushed system for 30 minutes.
Temperature - 13.9 C
Conductivity - 501 uS/cm
pH - 7.14
Multi-tenant
Residence/ 325
N Main Street,
Mansfield, MA
Nicks Realty Trust
Nicholas & Steven Anagnos
508-339-9556
Map 022,
Lot 003
1215
Sampled at outside spigot - before treatment (Picture 4)
Temperature - 13.1 C
Conductivity - 886 uS/cm
pH - 6.29
Town
1/ Underpass
on N. Main St
at Mansfield
Ave,
Mansfield, MA
Mark Cook
508-922-8388
Underpass
1419
Sample taken from seep in road. Mansfield Ave overpass
on North Main Street. (Picture 5)
Start purge at 1400 using peristaltic pump
Temperature - 18 C
Conductivity - 513.2 uS/cm
pH - 6.53
Town
2/ Underpass
on Chauncy St
at Mansfield
Ave,
Mansfield, MA
Mark Cook
508-922-8388
Underpass
1500
Sample taken from storm sewer manhole on sidewalk.
Overpass Route 106 and Chauncy Street. (Picture 6)
Sample from 5 gallon pail dropped into manhole. No
readings taken.
Private
Residence/ 132
Highland Ave,
Mansfield, MA
Kimberly Horstmann &
Michael Mallon
774-406-1559
Map 018,
Lot 459
1610
Sample taken from just after pump head. (Picture 7)
Temperature - 15.6 C
Conductivity - 98.6 uS/cm
pH - 6.01
IV. Sampling Summary
On Wednesday, June 18, 2014, EPA investigators Jerry Keefe and Mike Looney conducted a Sampling Project at
seven locations within the town of Mansfield, MA. Pre and post calibrations of field instruments were within
acceptable limits. All locations sampled were completed according to sampling and analysis plan except for the
Town 1 and Town 2 locations. These locations are stormwater and groundwater collections tanks for 2 town
underpasses. Both holding tanks contain extensive debris (plastic cup/bottles, cigarette butts, etc) and were therefore
not appropriate groundwater sample locations (Picture 8). Pipes with flowing groundwater were observed in the tanks
but could not be sampled directly because of difficulty and safety concerns. The Town 1 location had breakouts of
groundwater up-flowing into the street and then to the storm sewer. These groundwater up-flows appeared to be
representative groundwater sampling locations. Picture 5 shows the sample location and the sample tubing. The
peristaltic pump was pumping at approximately 400 ml/min with no draw down. Due to safety concerns the purging
-------
Hatheway & Patterson Well Sampling
June 18, 2014
was only for 20 minutes and the samples were collected along with field parameters. The Town 2 location was
sampled from a manhole using a clean 5 gallon bucket from a 10" pipe flowing groundwater (according to Mark
Cook) to the holding tank. The route 106 underpass is shown in Picture 6.
To ensure that data quality objectives were met and acceptable for decision making purposes the following was
reviewed.
1) SAP - Hatheway and Patterson Well Sampling for Analysis of Dioxins, PCP, and metals.
2) Chain of Custody (COC)
3) Field duplicate comparison
Sampling and Analysis Plan
The SAP objectives were achieved and all locations were sampled accordingly. As stated above two sample locations
Town 1 and Town 2 were sampled based upon the investigators' professional judgment and safety considerations.
Although these sampling locations appeared representative and satisfactory, the locations have potential of being
affected by other conditions that are not representative of actual ground water (stormwater, road debris).
Chain of Custody
All COC information as compared to field notes showed no issues. Sample delivery, preservation, and signage were
acceptable.
Field Duplicate Comparison
A field duplicate is a collection of two or more samples collected at the same location side by side or one immediately
after the other. This duplicate represents the precision of the whole method, site heterogeneity, field sampling and the
laboratory analysis. Relative Percent Difference (RPD) was calculated for metals. The USEPA nationally has not set
control criteria for field duplicates but the site SAP used 30 percent as a standard. Site contaminant of concern
(chromium and arsenic) are within acceptable limits. Aluminum, copper, zinc, lead, and iron are above the 30 percent
limit. In general water samples that are not filtered and/or collected at high flow rates may tend to have fluctuations
in sample results due to the solubility of such compounds. The results show good correlation and field precision.
Overall Assessment
None of the data were qualified or rejected based upon this review and the quality of the data is acceptable. All data
can be used for decision making purposes.
-------
Hatheway & Patterson Well Sampling
June 18, 2014
Table 2
132 Highland
Ave
132(d)
Highland
RPD
Beryllium
ND
ND
0.0
Aluminum
36
49
30.6
Vanadium
ND
0.22
9.5
Chromium
0.5
0.56
11.3
Manganese
11
11
0.0
Cobalt
ND
ND
0.0
Nickel
2.1
2.2
4.7
Copper
46
78
51.6
Zinc
17
24
34.1
Arsenic
ND
ND
0.0
Selenium
ND
ND
0.0
Silver
ND
ND
0.0
Cadmium
ND
ND
0.0
Molybdenum
ND
ND
0.0
Antimony
ND
ND
0.0
Barium
60
61
1.7
Thallium
ND
ND
0.0
Lead
3.5
7.6
73.9
Magnesium (mg/L)
2.1
2.1
0.0
Calcium (mg/L)
24
24
0.0
Iron
340
940
93.8
Uranium
ND
ND
0.0
-------
Patterson Well Sampling
June 18, 2014
Picture 1-18 Thomas Street
1 |
It
,im |
Picture 2-136 Highland Ave
-------
Patterson Well Sampling
June 18, 2014
Picture 3-46 Chauncy Street
Picture 4 - 325 North Main Street
-------
Patterson Well Sampling
June 18, 2014
Hatheway &
Picture 5 - Town 1
Picture 6 - Town 2
-------
Patterson Well Sampling
June 18, 2014
Hatheway &
Picture 7
Picture 8 - Town 1 Debris in Holding Tank
V
e
f
*
-------
United States Environmental Protection Agency
Office of Environmental Measurement & Evaluation
11 Technology Drive
North Chelmsford, MA 01863-2431
Page 1 of 15
Laboratory Report
July 17, 2014
Jerry Keefe - EIA / OEME
Kimberly White - Mail Code OSRR07-1
US EPA New England, Region 1
Kimberly White - Mail Code OSRR07-1
Project Number: 14060018
Project: Hatheway & Patterson Co - Mansfield, MA
Analysis: Total Recoverable Metals in Water
EPA Chemist: Michael Dowling
Date Samples Received by the Laboratory: 06/19/2014
Analytical Procedure:
All samples were received and logged in by the laboratory according to the USEPA New England
Laboratory SOP for Sample Log-in.
Sample preparation and analysis was done following the EPA Region I SOP, EIASOP-INGICPMS5.
Samples were prepared following USEPA New England Sample Prep SOP: EIA-INGPREP8.SOP.
Samples were analyzed using a Perkin Elmer Elan 6000 inductively coupled plasma mass spectrometer.
Preparation and analysis SOP's are based on Methods 200.2 and 200.8, respectively, as stated in "Methods
for the Determination of Metals in Environmental Samples, Supplement I (EPA/600/R-94/111), Rev. 5.4,
May 1994."
Data were reviewed in accordance with the internal verification procedures described in the EPA New England Quality
Manual for NERL.
Results relate only to the items tested or to the samples as received by the Laboratory. This analytical report shall not be
reproduced except in full, without written approval of the laboratory.
If you have any questions please call me at 617-918-8340 .
Sincerely,
14060018$MTMSW
-------
Qualifiers:
Page 2 of 15
RL Reporting limit
ND Not Detected above reporting limit
NA Not Applicable
NC Not calculated since analyte concentration is ND
J1 Estimated value due to MS recovery outside accceptance criteria
J2 Estimated value due to LFB result outside acceptance criteria
J3 Estimated value due to RPD result outside acceptance criteria
J4 Estimated value due to LCS result outside acceptance criteria
B Analyte is associated with the lab blank or trip blank contamination. Values are
qualified when the observed concentration of the contamination in the sample
extract is less than 10 times the concentration in the blank.
R No recovery was calculated since the analyte concentration is greater than four times
the spike level.
Comments: The pH values of all samples were approximately 1.9.
14060018$MTMSW
-------
US ENVIRONMENTAL PROTECTION AGENCY
NEW ENGLAND LABORATORY
Page -3 of lb
Hatheway & Patterson Co - Mansfield, MA
Total Recoverable Metals in Water
Client Sample ID:
18 Thomas Street
Lab Sample ID:
AB48954
Date of Collection:
6/18/2014
Matrix:
Water
Date of Preparation:
7/14/2014
Amount Prepared: 25 mL
Date of Analysis:
7/15/2014
Percent Solids:
N/A
Dry Weight Prepared:
N/A
Extract Dilution:
1.01
Wet Weight Prepared:
N/A
pH:
<2
Concentration
RL
CAS Number
Compound
ug/L
us/L
Qualifier
7440-41-7
Beryllium
ND
0.20
7429-90-5
Aluminum
ND
5.0
7440-62-2
Vanadium
ND
0.20
7440-47-3
Chromium
1.0
0.50
7439-96-5
Manganese
27
0.20
7440-48-4
Cobalt
ND
0.20
7440-02-0
Nickel
3.2
0.20
7440-50-8
Copper
22
0.50
7440-66-6
Zinc
13
5.0
7440-38-2
Arsenic
ND
1.0
7782-49-2
Selenium
ND
1.0
7440-22-4
Silver
ND
0.20
7440-43-9
Cadmium
ND
0.20
7439-98-7
Molybdenum
ND
1.0
7440-36-0
Antimony
ND
0.50
7440-39-3
Barium
92
0.20
7440-28-0
Thallium
ND
0.50
7439-92-1
Lead
1.3
0.20
7439-95-4
Magnesium (mg/L)
7.2
0.10
7440-70-2
Calcium (mg/L)
67
0.20
7439-89-6
Iron
ND
50
7440-61-1
Uranium
ND
1.0
Comments:
14060018$MTMSW
-------
US ENVIRONMENTAL PROTECTION AGENCY
NEW ENGLAND LABORATORY
Page 4 of lb
Hatheway & Patterson Co - Mansfield, MA
Total Recoverable Metals in Water
Client Sample ID:
136 Highland Ave
Lab Sample ID:
AB48955
Date of Collection:
6/18/2014
Matrix:
Water
Date of Preparation:
7/14/2014
Amount Prepared: 25 mL
Date of Analysis:
7/15/2014
Percent Solids:
N/A
Dry Weight Prepared:
N/A
Extract Dilution:
1.01
Wet Weight Prepared:
N/A
pH:
<2
Concentration
RL
CAS Number
Compound
ug/L
us/L
Qualifier
7440-41-7
Beryllium
0.20
0.20
7429-90-5
Aluminum
59
5.0
7440-62-2
Vanadium
ND
0.20
7440-47-3
Chromium
ND
0.50
7439-96-5
Manganese
20
0.20
7440-48-4
Cobalt
ND
0.20
7440-02-0
Nickel
1.3
0.20
7440-50-8
Copper
1.2
0.50
7440-66-6
Zinc
88
5.0
7440-38-2
Arsenic
ND
1.0
7782-49-2
Selenium
ND
1.0
7440-22-4
Silver
ND
0.20
7440-43-9
Cadmium
ND
0.20
7439-98-7
Molybdenum
ND
1.0
7440-36-0
Antimony
ND
0.50
7440-39-3
Barium
42
0.20
7440-28-0
Thallium
ND
0.50
7439-92-1
Lead
ND
0.20
7439-95-4
Magnesium (mg/L)
1.6
0.10
7440-70-2
Calcium (mg/L)
15
0.20
7439-89-6
Iron
ND
50
7440-61-1
Uranium
ND
1.0
Comments:
14060018$MTMSW
-------
US ENVIRONMENTAL PROTECTION AGENCY
NEW ENGLAND LABORATORY
Page b of lb
Hatheway & Patterson Co - Mansfield, MA
Total Recoverable Metals in Water
Client Sample ID:
46 Chauncy Street
Lab Sample ID:
AB48956
Date of Collection:
6/18/2014
Matrix:
Water
Date of Preparation:
7/14/2014
Amount Prepared: 25 mL
Date of Analysis:
7/15/2014
Percent Solids:
N/A
Dry Weight Prepared:
N/A
Extract Dilution:
1.01
Wet Weight Prepared:
N/A
pH:
<2
Concentration
RL
CAS Number
Compound
ug/L
us/L
Qualifier
7440-41-7
Beryllium
ND
0.20
7429-90-5
Aluminum
ND
5.0
7440-62-2
Vanadium
ND
0.20
7440-47-3
Chromium
ND
0.50
7439-96-5
Manganese
1600
0.20
7440-48-4
Cobalt
2.2
0.20
7440-02-0
Nickel
3.3
0.20
7440-50-8
Copper
7.4
0.50
7440-66-6
Zinc
590
5.0
7440-38-2
Arsenic
4.1
1.0
7782-49-2
Selenium
ND
1.0
7440-22-4
Silver
ND
0.20
7440-43-9
Cadmium
ND
0.20
7439-98-7
Molybdenum
ND
1.0
7440-36-0
Antimony
ND
0.50
7440-39-3
Barium
41
0.20
7440-28-0
Thallium
ND
0.50
7439-92-1
Lead
0.58
0.20
7439-95-4
Magnesium (mg/L)
3.8
0.10
7440-70-2
Calcium (mg/L)
59
0.20
7439-89-6
Iron
3200
50
7440-61-1
Uranium
ND
1.0
Comments:
14060018$MTMSW
-------
US ENVIRONMENTAL PROTECTION AGENCY
NEW ENGLAND LABORATORY
Page b of lb
Hatheway & Patterson Co - Mansfield, MA
Total Recoverable Metals in Water
Client Sample ID:
325 N Main Street
Lab Sample ID:
AB48957
Date of Collection:
6/18/2014
Matrix:
Water
Date of Preparation:
7/14/2014
Amount Prepared: 25 mL
Date of Analysis:
7/15/2014
Percent Solids:
N/A
Dry Weight Prepared:
N/A
Extract Dilution:
1.01
Wet Weight Prepared:
N/A
pH:
<2
Concentration
RL
CAS Number
Compound
ug/L
us/L
Qualifier
7440-41-7
Beryllium
ND
0.20
7429-90-5
Aluminum
ND
5.0
7440-62-2
Vanadium
ND
0.20
7440-47-3
Chromium
ND
0.50
7439-96-5
Manganese
2600
2.0
7440-48-4
Cobalt
8.1
0.20
7440-02-0
Nickel
3.4
0.20
7440-50-8
Copper
3.7
0.50
7440-66-6
Zinc
18
5.0
7440-38-2
Arsenic
ND
1.0
7782-49-2
Selenium
ND
1.0
7440-22-4
Silver
ND
0.20
7440-43-9
Cadmium
ND
0.20
7439-98-7
Molybdenum
ND
1.0
7440-36-0
Antimony
ND
0.50
7440-39-3
Barium
60
0.20
7440-28-0
Thallium
ND
0.50
7439-92-1
Lead
0.46
0.20
7439-95-4
Magnesium (mg/L)
4.2
0.10
7440-70-2
Calcium (mg/L)
33
0.20
7439-89-6
Iron
3100
50
7440-61-1
Uranium
ND
1.0
Comments: The manganese result is reported from a lOx dilution.
14060018$MTMSW
-------
US ENVIRONMENTAL PROTECTION AGENCY
NEW ENGLAND LABORATORY
Hatheway & Patterson Co - Mansfield, MA
Page 7 of 15
Total Recoverable Metals in Water
Client Sample ID:
Town 1
Lab Sample ID:
Date of Collection:
6/18/2014
Matrix:
Date of Preparation:
7/14/2014
Amount Prepared:
Date of Analysis:
7/15/2014
Percent Solids:
Dry Weight Prepared:
N/A
Extract Dilution:
Wet Weight Prepared:
N/A
pH:
Concentration
RL
CAS Number
Compound
ug/L
us/L
7440-41-7
Beryllium
ND
0.20
7429-90-5
Aluminum
ND
5.0
7440-62-2
Vanadium
0.28
0.20
7440-47-3
Chromium
ND
0.50
7439-96-5
Manganese
1.5
0.20
7440-48-4
Cobalt
ND
0.20
7440-02-0
Nickel
1.8
0.20
7440-50-8
Copper
1.9
0.50
7440-66-6
Zinc
19
5.0
7440-38-2
Arsenic
ND
1.0
7782-49-2
Selenium
ND
1.0
7440-22-4
Silver
ND
0.20
7440-43-9
Cadmium
ND
0.20
7439-98-7
Molybdenum
ND
1.0
7440-36-0
Antimony
ND
0.50
7440-39-3
Barium
32
0.20
7440-28-0
Thallium
ND
0.50
7439-92-1
Lead
ND
0.20
7439-95-4
Magnesium (mg/L)
1.7
0.10
7440-70-2
Calcium (mg/L)
18
0.20
7439-89-6
Iron
ND
50
7440-61-1
Uranium
ND
1.0
AB48958
Water
25 mL
N/A
1.01
<2
Qualifier
Comments:
14060018$MTMSW
-------
US ENVIRONMENTAL PROTECTION AGENCY
NEW ENGLAND LABORATORY
Hatheway & Patterson Co - Mansfield, MA
Page 8 of 15
Total Recoverable Metals in Water
Client Sample ID:
Town 2
Lab Sample ID:
Date of Collection:
6/18/2014
Matrix:
Date of Preparation:
7/14/2014
Amount Prepared:
Date of Analysis:
7/15/2014
Percent Solids:
Dry Weight Prepared:
N/A
Extract Dilution:
Wet Weight Prepared:
N/A
pH:
Concentration
RL
CAS Number
Compound
ug/L
us/L
7440-41-7
Beryllium
ND
0.20
7429-90-5
Aluminum
10
5.0
7440-62-2
Vanadium
ND
0.20
7440-47-3
Chromium
ND
0.50
7439-96-5
Manganese
1400
0.20
7440-48-4
Cobalt
5.0
0.20
7440-02-0
Nickel
6.7
0.20
7440-50-8
Copper
7.2
0.50
7440-66-6
Zinc
39
5.0
7440-38-2
Arsenic
ND
1.0
7782-49-2
Selenium
ND
1.0
7440-22-4
Silver
ND
0.20
7440-43-9
Cadmium
ND
0.20
7439-98-7
Molybdenum
ND
1.0
7440-36-0
Antimony
ND
0.50
7440-39-3
Barium
300
0.20
7440-28-0
Thallium
ND
0.50
7439-92-1
Lead
0.74
0.20
7439-95-4
Magnesium (mg/L)
6.9
0.10
7440-70-2
Calcium (mg/L)
57
2.0
7439-89-6
Iron
3500
50
7440-61-1
Uranium
ND
1.0
AB48959
Water
25 mL
N/A
1.01
<2
Qualifier
Comments: The calcium result is reported from a lOx dilution.
14060018$MTMSW
-------
US ENVIRONMENTAL PROTECTION AGENCY
NEW ENGLAND LABORATORY
Page 9 of lb
Hatheway & Patterson Co - Mansfield, MA
Total Recoverable Metals in Water
Client Sample ID:
132 Highland ave
Lab Sample ID:
AB48960
Date of Collection:
6/18/2014
Matrix:
Water
Date of Preparation:
7/14/2014
Amount Prepared: 25 mL
Date of Analysis:
7/15/2014
Percent Solids:
N/A
Dry Weight Prepared:
N/A
Extract Dilution:
1.01
Wet Weight Prepared:
N/A
pH:
<2
Concentration
RL
CAS Number
Compound
ug/L
us/L
Qualifier
7440-41-7
Beryllium
ND
0.20
7429-90-5
Aluminum
36
5.0
7440-62-2
Vanadium
ND
0.20
7440-47-3
Chromium
0.50
0.50
7439-96-5
Manganese
11
0.20
7440-48-4
Cobalt
ND
0.20
7440-02-0
Nickel
2.1
0.20
7440-50-8
Copper
46
0.50
7440-66-6
Zinc
17
5.0
7440-38-2
Arsenic
ND
1.0
7782-49-2
Selenium
ND
1.0
7440-22-4
Silver
ND
0.20
7440-43-9
Cadmium
ND
0.20
7439-98-7
Molybdenum
ND
1.0
7440-36-0
Antimony
ND
0.50
7440-39-3
Barium
60
0.20
7440-28-0
Thallium
ND
0.50
7439-92-1
Lead
3.5
0.20
7439-95-4
Magnesium (mg/L)
2.1
0.10
7440-70-2
Calcium (mg/L)
24
0.20
7439-89-6
Iron
340
50
7440-61-1
Uranium
ND
1.0
Comments:
14060018$MTMSW
-------
US ENVIRONMENTAL PROTECTION AGENCY
NEW ENGLAND LABORATORY
Hatheway & Patterson Co - Mansfield, MA
Page 10 of 15
Total Recoverable Metals in Water
Client Sample ID:
132 (d) Highland ave
Lab Sample ID:
Date of Collection:
6/18/2014
Matrix:
Date of Preparation:
7/14/2014
Amount Prepared:
Date of Analysis:
7/15/2014
Percent Solids:
Dry Weight Prepared:
N/A
Extract Dilution:
Wet Weight Prepared:
N/A
pH:
Concentration
RL
CAS Number
Compound
ug/L
us/L
7440-41-7
Beryllium
ND
0.20
7429-90-5
Aluminum
49
5.0
7440-62-2
Vanadium
0.22
0.20
7440-47-3
Chromium
0.56
0.50
7439-96-5
Manganese
11
0.20
7440-48-4
Cobalt
ND
0.20
7440-02-0
Nickel
2.2
0.20
7440-50-8
Copper
78
0.50
7440-66-6
Zinc
24
5.0
7440-38-2
Arsenic
ND
1.0
7782-49-2
Selenium
ND
1.0
7440-22-4
Silver
ND
0.20
7440-43-9
Cadmium
ND
0.20
7439-98-7
Molybdenum
ND
1.0
7440-36-0
Antimony
ND
0.50
7440-39-3
Barium
61
0.20
7440-28-0
Thallium
ND
0.50
7439-92-1
Lead
7.6
0.20
7439-95-4
Magnesium (mg/L)
2.1
0.10
7440-70-2
Calcium (mg/L)
24
0.20
7439-89-6
Iron
940
50
7440-61-1
Uranium
ND
1.0
AB48961
Water
25 mL
N/A
1.01
<2
Qualifier
Comments:
14060018$MTMSW
-------
US ENVIRONMENTAL PROTECTION AGENCY
NEW ENGLAND LABORATORY
Hatheway & Patterson Co - Mansfield, MA
Page 11 of 15
Laboratory Reagent Blank Result (ug/L)
Client Sample ID:
N/A
Lab Sample ID:
Date of Collection:
N/A
Matrix:
Date of Preparation:
7/14/2014
Amount Prepared:
Date of Analysis:
7/15/2014
Percent Solids:
Dry Weight Prepared:
N/A
Extract Dilution:
Wet Weight Prepared:
N/A
pH:
Concentration
RL
CAS Number
Compound
ug/L
us/L
7440-41-7
Beryllium
ND
0.20
7429-90-5
Aluminum
ND
5.0
7440-62-2
Vanadium
ND
0.20
7440-47-3
Chromium
ND
0.50
7439-96-5
Manganese
ND
0.20
7440-48-4
Cobalt
ND
0.20
7440-02-0
Nickel
ND
0.20
7440-50-8
Copper
ND
0.50
7440-66-6
Zinc
ND
5.0
7440-38-2
Arsenic
ND
1.0
7782-49-2
Selenium
ND
1.0
7440-22-4
Silver
ND
0.20
7440-43-9
Cadmium
ND
0.20
7439-98-7
Molybdenum
ND
1.0
7440-36-0
Antimony
ND
0.50
7440-39-3
Barium
ND
0.20
7440-28-0
Thallium
ND
0.50
7439-92-1
Lead
ND
0.20
7439-95-4
Magnesium (mg/L)
ND
0.10
7440-70-2
Calcium (mg/L)
ND
0.20
7439-89-6
Iron
ND
50
7440-61-1
Uranium
ND
1.0
N/A
Water
25 mL
N/A
1.01
N/A
Qualifier
Comments:
14060018$MTMSW
-------
US ENVIRONMENTAL PROTECTION AGENCY
NEW ENGLAND LABORATORY
Hatheway & Patterson Co - Mansfield, MA
MATRIX SPIKE (MS) RECOVERY
Sample ID: AB48957
SPIKE
SAMPLE
MS
MS
QC
ADDED
CONCENTRATION
CONCENTRATION
%
LIMITS
PARAMETER
ug/L
ug/L
ug/L
REC
(% REC)
Aluminum
40
ND
37.9
95
70 -
130
Antimony
40
ND
42.2
106
70 -
130
Arsenic
40
ND
44.2
110
70 -
130
Barium
40
60
97.2
93
70 -
130
Beryllium
40
ND
39.7
99
70 -
130
Cadmium
40
ND
39.5
99
70 -
130
Chromium
40
ND
38.6
97
70 -
130
Cobalt
40
8.1
47.1
98
70 -
130
Copper
40
3.7
40.9
93
70 -
130
Iron
440
3100
3480
R
70 -
130
Lead
40
0.46
42.1
104
70 -
130
Manganese
40
2600
2440
R
70 -
130
Molybdenum
40
ND
43.2
108
70 -
130
Nickel
40
3.4
40.6
93
70 -
130
Selenium
40
ND
40.3
101
70 -
130
Silver
40
ND
38.3
96
70 -
130
Thallium
40
ND
42.0
105
70 -
130
Uranium
40
ND
43.4
108
70 -
130
Vanadium
40
ND
41.2
103
70 -
130
Zinc
40
18
58.1
100
70 -
130
14060018$MTMSW
-------
US ENVIRONMENTAL PROTECTION AGENCY
NEW ENGLAND LABORATORY
Hatheway & Patterson Co - Mansfield, MA
Laboratory Duplicate Results
Sample ID: AB48955
PARAMETER
SAMPLE
RESULT
ug/L
SAMPLE DUPLICATE
RESULT
ug/L
PRECISION
RPD
%
QC
LIMITS
Aluminum
59
62
5.0
20
Antimony
ND
ND
NC
20
Arsenic
ND
ND
NC
20
Barium
42
42
0.0
20
Beryllium
0.20
ND
NC
20
Cadmium
ND
ND
NC
20
Calcium (mg/L)
15
15
0.0
20
Chromium
ND
ND
NC
20
Cobalt
ND
ND
NC
20
Copper
1.2
1.3
8.0
20
Iron
ND
ND
NC
20
Lead
ND
ND
NC
20
Magnesium (mg/L)
1.6
1.7
6.1
20
Manganese
20
21
4.9
20
Molybdenum
ND
ND
NC
20
Nickel
1.3
1.4
7.4
20
Selenium
ND
ND
NC
20
Silver
ND
ND
NC
20
Thallium
ND
ND
NC
20
Uranium
ND
ND
NC
20
Vanadium
ND
ND
NC
20
Zinc
88
92
4.4
20
14060018$MTMSW
-------
US ENVIRONMENTAL PROTECTION AGENCY
NEW ENGLAND LABORATORY
Hatheway & Patterson Co - Mansfield, MA
Laboratory Fortified Blank (LFB) Results
LFB AMOUNT
LFB
LFB
QC
SPIKED
RESULT
RECOVERY
LIMITS
PARAMETER
ug/L
ug/L
%
%
Aluminum
40.0
39.2
98
85 - 115
Antimony
40.0
39.9
100
85 - 115
Arsenic
40.0
41.8
104
85 - 115
Barium
40.0
39.7
99
85 - 115
Beryllium
40.0
40.0
100
85 - 115
Cadmium
40.0
40.0
100
85 - 115
Calcium (mg/L)
8.00
7.58
95
85 - 115
Chromium
40.0
40.1
100
85 - 115
Cobalt
40.0
41.9
105
85 - 115
Copper
40.0
40.7
102
85 - 115
Iron
440
441
100
85 - 115
Lead
40.0
40.2
100
85 - 115
Magnesium (mg/L)
4.00
4.14
104
85 - 115
Manganese
40.0
40.0
100
85 - 115
Molybdenum
40.0
40.4
101
85 - 115
Nickel
40.0
40.7
102
85 - 115
Selenium
40.0
40.2
100
85 - 115
Silver
40.0
41.4
104
85 - 115
Thallium
40.0
41.1
103
85 - 115
Uranium
40.0
41.2
103
85 - 115
Vanadium
40.0
40.1
100
85 - 115
Zinc
40.0
42.8
107
85 - 115
Comments:
Samples in Batch: AB48954, AB48955, AB48956, AB48957, AB48958, AB48959, AB48960, AB48961
14060018$MTMSW
-------
\ ENVIRONMENTAL PROTECTION AGENCY
?
REGION 1
CHAIN OF CUSTODY RECORD
PROJ. NO.
PROJECT NAME
NO.
OF
CON-
TAINERS
REMARKS
SAMPLERS: (Signature)
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(Signature)
Dittribuiion; Orijintl Aecompaniei Shipment; Copv to Coordinator R*ld Filปi
Date /Time
/d.'3S
Remarks
1- 1947F.
-------
EPA Sample No.
1DFA - FORM 1-HR CDp-J
CDD/CDF SAMPLE DATA SUMMARY
HIGH RESOLUTION
AO A AO
Lab Name; A.GAT LABORATORIES Contract: EP10W00106V
tab Code; AGATAB Cose Bo.; 4iซ2 TO Mo.: 2134.2 S DG No,: AOAAO
Matrix.: Water Lab Sample ID: 5496756
Sample wt/vol: 910 ml Lab File ID: 14M35456&_54967S6
Water Sample Prep: SEFF Date Received: 0 6-2:3-2014
Concentrated Extract Volume: 20 uL Date Extracted: 05-26-2014
rnjsctior: Volumes: 1.0 uL % Soiids/Lipids; Date Analysed: 07-02-2014
CC ro j i,im, : ; j R - :-> ID: 0.2SQ mm Dilution factor: 1.0
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HI61" RESOLUTION
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Lab Name: AGA7 LABORATORIES Contract: fc;P [ OWUQ 1 ti tป
Lab Code; AGATAT1 Case No.: 44423 TO No.: 2134,2 SDG No.: M) A AO-
Ma I rix: Water Lob Samp to ID: 54 96760
Sample wt/voi: 990 mL Lab filo ID; 1 'lM8545fc.8_h4:i II
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IDFA - FORM 1 -aft CDD-1
CDD/Cpf SAMPLE DATA SUMMARY
HIGH P F-SOlXiT I ON
Lab Name: AGAT LABOIWTOPIES Contract: EP.i PWOO1 067
Ub Code: AGATAB Case No,: <14423 T7i No,: 2134.2 SDG No.: AOAAO
Matrix: Water Lab Sample ID: 5496761
Sample w L / vc 1: 9?0 ml. Lab ftii: ID: MMB54SC8 Jt496?61
M-iter Sample Prep: SBPP Date Received: 06-23-2014
Concentrated Extract Volume: 20 uL Data Extracted: 06-26-2014
In lection Volume: 1.0 ut, t Sal ids/Lipicis; Data Analyzed: 07-02-2014
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IDFA - CORK I-MR CCD-I
CDD/CDF SAMPLE OATS SUMMARY
s: I Gil RESOLIJT I OS
EPA Sample No.
A0AA6
Lrfb Name; AG AT I.ABORATOKf FIS
r.ab Code; AGATAB Case No,: 4<|42J
Matrix: Water
Hrlinple wt/voi; 990 IB J
Water Sample Prep: SEFF
Concentrated Ex.rrae.t Volume: 20 uiป
In 1 ect j on Volume: f.O uS, v. So I ids / la p i. ds :
CC Column; DB-5 fO: 0.250 rum
Conc.ontra t.ion Uri
Contract; EP10w00 lซt> i
T3 Mo.: 2134.2 SDG Mo.: ftOAAO
Lab Sample ID: 5496763
Lab file ID: HMBM5S8 5 4 96"J6'.<
Date Received; 06-23-2014
Da te Ext tat: ied: 06- 26-C01
Da t e fai a 1 y 2 e d: 07-0 3 - 2 0 i -I
D i 1 u t ,i o n factor: 1. 0
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EPA Sample Nc
1 UFA - fc'ORH I-lift CDD-1
CDD/CDF SAMPLE DATA SUMMARY
HIGH RESOLUTION
Lab Nana: A GAT 1', A B 0 RA'l" 0 R1E S
Cfih C,:.L
Cab File ID
14.M8 5 4 5 6 8 _ _ 5 4 9 67 6 4
Water Sample l?rep;
3EPF
Date Received; 06-
23-CG2 4
Concentrated Extract Volume;
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Date Extracted: 06
-2 6-201-1
injection Volume: 1
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Date Analyzed: 07-
04-.2 014
GC Column; DB-5
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COD/CDF SAMPLE DATA SUMMAHY
HIGH RESOLUTION
Lab Name: AGAT LABQRATOfUF,S Contract.: EP10W001067
Lab Code: AGATA8 Case No.: 4-1'123 TO Wo. ; 2134.2 S DC Mo.: ADA AO
Matrix: Water T.ab Sample 111: 5.196768
Sample wt/vol: 655 pi) {Sec cas'e narrative! hah Pile ID: HMB.b4S6S_549C.7bS
Water Sample Preps 5EPF Data Received: 06-?3-2014
Concentrated Extract Vol time: 20 >:L tote Ejtt.ract.ecl: O6-26-:*014
injection Volume: .1.. 0 nil x Solids/Li pids: Dace Analyzed: 07-03-20H
GC Column: DB-3 TP: 0.250' mm Dilation Factor: 1.0
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Lab Sample II): 5496756
He ID: 14M854066- 549b756
Rate Received: 06-23-201 '1
Date Extracted: 06-/6-20], >1
Date analysed; 07~O2~2O1<1
Dilution Factor; 1.0
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v 0 .1
(i 0
|J . 0
0 . 1 =
0 . 1
12 J i r t< - H x1 ' P ;
I . U P
x 0 . '1
o. \ ct z>
i.... m ' -iipoor
0 . i7Z
x 0 . (j 1 =
v .oil r.M
I ''a. > i-llp:Ll"'
0 , ! >
'j . T 1 =
rซ ;
i; "'7r<-Hi.":c.r
p 7 F< 1
'ฆ>. 0 ]
0 . i 1 i i i l< ฆ'
olppp
1 07
.< P' . 0 j 'J 7
U . ' L'0ljr:l
'J!" L'L-
1 . 0 u
;< i j . i j 'j ;) J =
fi linn / f y
7 a7: a =
0 . b 4 b
* TEP - Toxicity L'iuฑvaleiit Fa .-for.
?Q05.
>'jni t he Ko"l'i H':=ii>h Organ! za t l,.
! W;iO !
Pi I,HO
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1DFB FORM I-HR CCD-2
CDD/CDF TOXICITY EQUIVALENCE SUMMARY
HTtjH RESOLUTION
i.aln Hurts'? r AG AT I .Ail ORATOR tES
Lab Cซise fe,: 44 4^
Mar rix: Viปr e r
Samp 1 e w t / voi : 100 0 mi.,
Water Satnpl e Prep: SEPF
C o n ce n teste d E x t c a c t Vo I umซ*: 2 0 u L
Inject ton Volume: 1.0 uf, Sol ids/L ipi as :
GC ron.mn: d&-5 ID: 0.250 ป
Concert I ft! L i on Units : pg/L
Contract: EP10W00 1 Of*. 7
Nc>. ; 7134.2 S[}G No. : AOAAO
Lab Samp i.,i ID; 5496758
Lab File ID: 1M854568 _S496"?Se
Date Received: 06-23-2014
Da t e E x i t; a c t e ci: 0 6 - 2 6 - 2 01 4
Date Analysed: 0?-02~20H
Dilution fYiCtnr: 1,0
_! .!ฆ . d-TCDF
; ,J ; /rl-roCDF
Hi,
I) I
ฆ i. ti ;i j
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'ti :'-:;yi:L'.n
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0. L
0 . 1,1"; 11 i
I2 I '1 lb
J II. ,-1
PLM02.? ()?/0W)
FORM r-HR CDD-2
IS
-------
1DFB - A)RM L-HR CUD-2
CDP/CDF TOXICITY EQU1VALENCE SUMMARY
HIGH RKPOUAAON
;-un[>ic Mo
A'Vw\J
A,ป< Name: AG AT LABORATORIES
Lab .Ante; AG AT AH Case No.: M -.:5_-L"
; ; f " C
, .., 0
:
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1
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i h
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:r
, riFP - FC'PM i- iip :dj-j
rl r"i cqlcvclilCcl cu.tia
rfIG.fi BKSOr^r'T'JN
Am A A
Lab Name: ARAT LABORAT0M1fc.5
LftLi Code. AOATAB Case Mo.:
MaO'ix; Wal pr
S amp L e w t/Vo1 - 9 5 0 m [,
Water Sample! Ftap: SEPf
Concentrated Extract Volume: 20 ul
In led ion Volume?: 1-0
GC Column: DB-5
Sol i ds/i,ipxci
ID: 0.250 mm
Cm- reel : c-fc ! 1 ซ'111 1 1' '
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A)PB - FORK I -Hft CDD-7
CDLAiJbf TOXICITY EQUIVALENCE SUMM/'.f?'(
HIGH RESOLUTION
Lab Mnme: lUVV] LAbOHATOR IES
A']
Lab Code: CSpปe So,: 4 4 4 At
i\,1 vv."!, !
Sample wt/vo.A 970 ml,
Water Sample Prep: SEPF
Concentrated Extract Volume: 20 uL
! tntict ton Volume: 1.0 nL 7 Solicis/Lipuls;
GC Column: DB-O ID: 0,25 0 ions
Contract,; EI'llWO0106 *
TO No, : 2 i. 3-1, 2 SDG No. : A0AA0
Aab Sample ID; 5496161
i.afc File 10: 1 4M854 568_54ป676 1
Date Received: 06-23-21114
Date Extracted: 06-26-2014
Date Analyzed: 07-02-2014
Dilution Factor: 1.0
J'.>7-i,n]y,
C'M il"= 111 i .-i I mi1
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7 OCA,
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FORM 1 -lift CDI1-A
-------
lore - FORM I-HR CDD-*
CDD/CflF TOXICITY EQUIVALENCE SUMMARY"
HIGH RESOLUTION
CPA tifsKpiii Mo,
Cab Name: ACAC LABORATORIES
Lab rcitk:: AGATAB Cdflo Ho.: 4 44 23
Matrix: Water
Sample wi/voi : 1000 niL
Water SampJซ Prep: SEPF
Concent rated Extract Volume: 20 uL
Inytotian Volume: 1,0 til, Sol ids/Lipids:
GC Column: DE-5 t C: 6ป?S0 mm
Contract: EH0WOO106?
TO No.: ZlS'l,? SDG No.: A0M.0
si' : :
Lab File ID: 14MB 54568_S496/62
Date Received: 06-23-2014
Date Extracted: 06-26-2014
Date Analysed: 07-03-2014
Dilution Factor: 1.0
Concentration Units: pg/I,
fa i ฆ 1' J' nil ฆ ] i. V'
1 V,r. ฆ; nl ;:at- mi | TEF 1
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FORM i-llR
IS'
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_ ut.1 f.juu1 : AFAA Liu'irii j"j LL
Lcil- L-r.a-i : ArA- TAB Sm, 1 4 4 F ฆ<
T la rtFiiu-
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L- CDF I.X'.m'TTY r:v"TVA:.EN>-s" SUMMAU'f'
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2005.
FORM r-ilR T'DtJ-F
?0
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(..!<ป H-.,AC/a LABORATORIES
Cat" Cttiie: A&CJMt Case Cc, :
B,i i r is: W,ปf >:r
Cifnf.Cp w/vci: 960 rol,
Wafซr iCwtpue Prep: SEPF
Concern r.ned Extract Volume:
1 njc:f;t ion Volume; 1,0 ซ!. i Solids,
IX Column: DB-5 IE: 1
1DFB - FORM 1.-HB CDD-C
CDC/CDF TOXICITY EOCI VM.EHCIE SUMMARY
iw,:
:C\ C'
<1442 i TI rii4lS:
CDC No.;. A0AA0
I,dt: Saniple ID: C49676-I
Lab Cite ID; J 4 M8 5 4 5 6 8 _ฃ> 4 9 fi ? 6 4
Dart: Received: 06-23-2014
Date Extracted: 06-26-2014
Date Analyzed: 07-04-2014
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A OA BO
-nil i I
ILIPB mm 1-HR CDD-3
CDD/CiJf TOXICITY EQUIVALENCE SUMMARY
HIGH RESOLUTION
I,at) Name : 7\GAT LABOKRTOR IES Contract; EPIOMOOlObT
Lab Code: AGA.TAB Case No,; 44423 TO No. : 2134,2 SDG No.-: AOAAO
Matrix; Water Lab Sample ID: 5496168
Sample wt/vol: 855 ml (See case narrative) Lab File ID: 1 i|MBS4S68_ 5496768
Water Sample Prep; 3EPF Dace Received: 06-23-2014
Concentrated Extract Volume; 20 uL Date Extracted: 06-26-2014
infection Volume: 1.0 uL 3 Sollds/Lipids*. Date Analysed: 07-03-2014
GC Column: DB-5 ID; 0,250 mix, Diiution Factor: 1.0
Concentration Units; pg/1,
Ta cqot An a L ytC'
C'"iii reii Li a. L l nn
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,
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FORM ISIR Cbb-2
-------
IF" - FORM I SV-KJ.M
SEMI VOLATILE SIM ORGAMICS ANALYSIS DATA SIIEE*]
11 ; Sweaty Environmental Services, Inc
; SHEAlV
- 4442'-
Water
! 000
mL
CONT
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|J J
'.r.; <0
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"110 4
AOAAO
PF20Q38-001
. 120708810
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i -06/24/2014
07/08/2014
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-------
IF - FORM I SV-SIM r
3EMIVOLATILE SIM ORGANICS ANALYSIS DATA SHEET
ILL.
A0AA1
La a Kปme: Shealy Environmental Services, Inc.
Lab ;!ocle: SHEALY Case- Uo, ; 44423
'"ontract.; EP-W-11-03S
Mod. Bซฃ l*lo
21*04 .3DG No. ; AOAAQ
KazziXi : 501 L/SE3/mTER. Wafer
Saispiซ >ปt/voi; TOO ig/wt) mL_
Lab Sanspla rr>: PF20038-002
Lac ?Li* ID: 120706811
Extraction: <;Type
"i Moisture:
CONT
Liecan-ed; f i/ N}
Date Received: 06/2CV2014
Concentrar ad Extract Volume; IjQQO _ uit>
Injection Volume-; 10 fuLj GPC Factor 1.0
IF" -i r ! i r i/ T! 1
E x t. r a. c t eci ;06/24/2014
Date .Ana I vzed: 07/0872014
N
pH:
Dilution Factor; UL
>.;v: iH i. | ^ .*v.'L'Tin
CONCENTRATION UNITS:
lua/L or: ua/Kqlua/L
C
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SHEAlY i; , . ; 444Z3 ; ,, |s.L 21104 .>_ \ : A0AA0
son : .? E iJAVhF-.: Water r ;,b ;, - - , PF20038-004
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SEDIMENT ANALYTICAL RESULTS
-------
oi^^oV
MW-
MW-
MONITORING WELL LOCATION
^ SEDIMENT SAMPLE LOCATION
APPROXIMATE PROPERTY LINE
llllllllllll RAILROAD TRACK
GENERAL TREE LINE
BASE MAP SOURCE: FIGURE 2, PREPARED BY
TRC, SEPTEMBER 2010
I
200
SCALE
400
FEET
Environmental
Strategies
& Management
273 West Main Street
Norton, MA 02766
(508) 226-1800
(508) 226-1811 fax
esmznc. com
GAUGING DATE:
DRAWING Djffris
* 11/11/15
mfi>w Ffifit
WSSMStSKt-.
MONITORING WELLS AND SEDIMENT SAMPLES
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-------
Table C-3. Hathewav & Patterson Superfund Site Sediment Sampling Results
SED-1
5/16/2012
SED-2
5/16/2012
SED-3
5/16/2012
SED-4
5/16/2012
SED-4-FD
5/16/2012
Maximum
Detection
Maximum
Historical
Detections
HHRA
95% UCL
HHRA
Maximum
Historical
Detections
BERA
Geomean
BERA
2,3,7,8-TCDD
mg/kg
7.02E-07
< 1.24E-06
< 1.13E-06
2.64E-06
1.37E-06
2.64E-06
NA
NA
3.29E-06
6.76E-07
1,2,3,7,8-PeCDD
mg/kg
6.05E-06
2.39E-06
3.11E-06
1.72E-05
3.64E-06
1.72E-05
NA
NA
4.91E-05
3.03E-06
1,2,3,4,7,8-HxCDD
mg/kg
2.34E-05
7.41E-06
7.59E-06
4.45E-05
5.73E-06
4.45E-05
NA
NA
2.15E-04
8.45E-06
1,2,3,6,7,8-HxCDD
mg/kg
2.31E-04
3.87E-05
4.60E-05
2.17E-04
2.99E-05
2.31E-04
NA
NA
1.82E-03
3.50E-05
1,2,3,7,8,9-HxCDD
mg/kg
7.04E-05
1.84E-05
1.80E-05
1.14E-04
1.91E-05
1.14E-04
NA
NA
6.15E-04
2.25E-05
1,2,3,4,6,7,8-HpCDD
mg/kg
8.72E-03
1.03E-03
1.44E-03
5.27E-03
8.17E-04
8.72E-03
NA
NA
5.90E-02
1.05E-03
OCDD
mg/kg
6.61E-02
6.57E-03
1.14E-02
3.66E-02
7.27E-03
6.61E-02
NA
NA
5.24E-01
7.09E-03
2,3,7,8-TCDF
mg/kg
< 1.24E-06
< 1.24E-06
< 1.13E-06
4.83E-06
2.46E-06
4.83E-06
NA
NA
2.81E-05
1.38E-06
1,2,3,7,8-PeCDF
mg/kg
1.84E-06
< 3.1E-06
7.10E-07
7.83E-06
1.62E-06
7.83E-06
NA
NA
3.60E-05
1.29E-06
2,3,4,7,8-PeCDF
mg/kg
1.72E-06
< 3.1E-06
5.87E-07
5.20E-06
1.56E-06
5.20E-06
NA
NA
2.89E-05
1.43E-06
1,2,3,4,7,8-HxCDF
mg/kg
3.16E-05
6.15E-06
7.39E-06
5.15E-05
7.87E-06
5.15E-05
NA
NA
2.79E-04
1.15E-05
1,2,3,6,7,8-HxCDF
mg/kg
1.24E-05
3.91E-06
5.27E-06
4.16E-05
6.44E-06
4.16E-05
NA
NA
1.37E-04
9.87E-06
2,3,4,6,7,8-HxCDF
mg/kg
< 3.1E-06
< 3.1E-06
1.73E-06
< 4.25E-06
< 3.57E-06
1.73E-06
NA
NA
1.38E-04
3.08E-06
1,2,3,7,8,9-HxCDF
mg/kg
2.51E-05
7.19E-06
1.03E-05
7.93E-05
1.16E-05
7.93E-05
NA
NA
3.31E-05
5.81E-07
1,2,3,4,6,7,8-HpCDF
mg/kg
1.50E-03
2.14E-04
2.89E-04
1.39E-03
2.02E-04
1.50E-03
NA
NA
9.12E-03
2.06E-04
1,2,3,4,7,8,9-HpCDF
mg/kg
9.86E-05
1.51E-05
2.78E-05
1.44E-04
1.97E-05
1.44E-04
NA
NA
8.15E-04
1.77E-05
OCDF
mg/kg
1.06E-02
7.58E-04
1.34E-03
4.32E-03
5.65E-04
1.06E-02
NA
NA
5.38E-02
6.28E-04
Dioxin TEQ1
mg/kg
1.73E-04
2.67E-05
3.49E-05
1.57E-04
2.68E-05
1.73E-04
2.27E-03
1.60E-03
NA
NA
Arsenic
mg/kg
26
1.7
4.8
20
6.2
26
65
18
65
2.77
Chromium
mg/kg
7
5
9
26
17
26
330
240
330
15.6
Pentachlorophenol
mg/kg
< 1
< 1
< 1
< 8
< 7
ND
690
81
24
0.438
Notes
1. Using 2005 WHO TEFs and non-detects equal to the 1/2 reporting limit.
NA - Not Applicable
ND - Not Detected
< - Not detected at the value reported
HHRA - 2005 Human Health Risk Assessment
BERA - 2004 Baseline Ecological Risk Assessment
UCL - Upper Confidence Limit
-------
TABLE 2A
SUMMARY OF ANALYTICAL RESULTS IN SEDIMENT SAMPLES
DIOXINS
Hatheway Patterson Site RTN 4-571
15 County Street
Mansfield MA
(results in ng/kg)
Lab ID
Sample
Sample Type
Sample
Date
o
o
o
o
o
o
o
o
o
o
o
o
o
O
o
o
^ Q
co O
O
O
O
O
O
O
O
O
O
O
O
O
O
O
O
O
24087-13 (SED-1) |SED-1 |Sample | 5/16/2012 | 0.702 J | 6.05 | 23.4 | 231 | 70.4 | 8720 E 166100 B,E|0.76 C,j| 1.84 J | 1.72 J | 31.6 | 12.4 K | <3.1 | 25.1
24087-13 (SED-1)
SED-1
Re-analyzed TCDF
5/16/2012
<1.24
24087-13 (SED-1)
SED-1
Diluted
5/16/2012
<24.8
<62.1
24.1 J,K
226
71.6
7620
68100 B
<24.8
<62.1
<62.1
23.5 J
<62.1
<62.1
<62.1
24087-13 (SED-1)
SED-1
Matrix Spike
5/16/2012
24.1
70.1
91.9
155
12900 E
94900 E
25.8
66.2
55.5
98.8
75.3
56.6
85.3
24087-13 (SED-1)
SED-1
Dup Matrix Spike
5/16/2012
25.6
67.5
92.3
347
173
10500 E
79600 E
26.3
66.7
52.6
90.4
74.6
58.5
84
24087-14 (SED-2)
SED-2
Sample
5/16/2012
<1.24
2.39 J
7.41
38.7
18.4
1030
6570 B,E
<1.24
<3.1
<3.1
6.15
3.91
<3.1
7.19
24087-15 (SED-3)
SED-3
Sample
5/16/2012
<1.13
3.11
7.59
46
18
1440
11400 B,E
<1.13
0.71 J
0.587 J
7.39
5.27
1.73 J,K
10.3
24087-16 (SED-4)
SED-4
Sample
5/16/2012
2.64
17.2
44.5
217
114
5270 E
36600 B,E
6.82 C
7.83
5.2 K
51.5
41.6
<4.25
79.3
24087-16 (SED-4)
SED-4
Re-analyzed TCDF
5/16/2012
4.83
24087-16 (SED-4)
SED-4
Diluted
5/16/2012
<17
15.4 J
40.3 J,K
248
132
5190
39500 B
<17
<42.5
<42.5
46.8 K
42.1 J,K
<42.5
71.9
24087-17 (SED-4 Dup)
(SED-4 Dup)
Sample
5/16/2012
1.37 J
3.64
5.73 K
29.9
19.1
817
7270 B,E
3.69 C
1.62 J
1.56 J
7.87
6.44
<3.57
11.6
24087-17 (SED-4 Dup)
(SED-4 Dup)
Re-analyzed TCDF
5/16/2012
2.46
Lab Control Sample
LCS
Sample
5/16/2012
17.8
45.4
45.6
48.3
48
43.9
78.1
18.5
49.3
45.8
42
45.8
43.3
44
Method Blank
MB
Method Blank
5/16/2012
<0.937
<2.34
<2.34
<2.34
<2.34
<2.34
1.55 J
<0.937
<2.34
<2.34
<2.34
<2.34
<2.34
<2.34
Notes:
List of flags and qualifiers is attached.
NA - not applicable
Results for non-detected comounds shown as less than (<) the laboratory reporting limit.
* EPA Fresh Water Screening Criterion
S:\Customers\S A R S S\Projects\Hathaway Mansfield\Analytical\revised tables
7/25/2012
1 of 2
Environmental
Strategies
& Management
-------
TABLE 2A
SUMMARY OF ANALYTICAL RESULTS IN SEDIMENT SAMPLES
DIOXINS
Hatheway Patterson Site RTN 4-571
15 County Street
Mansfield MA
(results in ng/kg)
Lab ID
Sample
Sample Type
Sample
Date
LL
O
O
Q_
in
c
CO
o
N
C
CD
_Q
T3
O
O
o
03
Q.
CD
in
co
K
CD
CO
OJ
LL
O
O
Q_
in
c
CO
o
N
C
CD
_Q
T3
O
O
0
03
Q.
CD
1
CD
co"
r-{
CO
OJ
Octachlorodibenzofuran (OCDF)
Tetrachlorodibenzo-p-dioxins (TCDD), Total
Pentachlorodibenzo-p-dioxin (PeCDD), Total
Hexachlorodibenzo-p-dioxins (HxCDD), Total
Heptachlorodibenzo-p-dioxins (HpCDD), Total
Tetrachlorodibenzofurans (TCDF), Total
Pentachlorodibenzofurans (PeCDF), Total
Hexachlorodibenzofurans (HxCDF), Total
Heptachlorodibenzofurans (HpCDF), Total
Total TCDD TEQ - 2005 WHO (ND = MRL)
24087-13 (SED-1)
SED-1
Sample
5/16/2012
1500 P
98.6
10600 E,P
12.2
55.7
839
13500
2.07
88.3
1090
1600
162
24087-13 (SED-1)
SED-1
Re-analyzed TCDF
5/16/2012
162
24087-13 (SED-1)
SED-1
Diluted
5/16/2012
1200
<62.1
9480
162
24087-13 (SED-1)
SED-1
Matrix Spike
5/16/2012
2220
193
14300 E
28.8
138
1380
20100
31.1
234
1780
10900
24087-13 (SED-1)
SED-1
Dup Matrix Spike
5/16/2012
1860
166
12200 E
25.6
123
1270
16300
30.5
225
1540
8490
24087-14 (SED-2)
SED-2
Sample
5/16/2012
214
15.1
758
<1.24
4.8
152
1600
<1.24
21.1
202
858
25.4
24087-15 (SED-3)
SED-3
Sample
5/16/2012
289
27.8
1340
<1.13
7.09
161
2190
<1.13
37.1
232
1260
34.3
24087-16 (SED-4)
SED-4
Sample
5/16/2012
1390
144
4320
22.4
81.7
1270
8850
64.7
298
1540
5050
157
24087-16 (SED-4)
SED-4
Re-analyzed TCDF
5/16/2012
157
24087-16 (SED-4)
SED-4
Diluted
5/16/2012
1250
117
4420
157
24087-17 (SED-4 Dup)
(SED-4 Dup)
Sample
5/16/2012
202
19.7
565
5.11
42.1
458
1740
25.1
55.5
210
706
26.6
24087-17 (SED-4 Dup)
(SED-4 Dup)
Re-analyzed TCDF
5/16/2012
26.6
Lab Control Sample
LCS
Sample
5/16/2012
46.4
48.9
75.5
Method Blank
MB
Method Blank
5/16/2012
<2.34
<2.34
<4.68
<0.937
<2.34
<2.34
<2.34
<0.937
<2.34
<2.34
<2.34
Notes:
List of flags and qualifiers is attached.
NA - not applicable
Results for non-detected comounds shown as less than (<) the laborato
* EPA Fresh Water Screening Criterion
S:\Customers\S A R S S\Projects\Hathaway Mansfield\Analytical\revised tables
7/25/2012
2 of 2
Environmental
Strategies
& Management
-------
TABLE 2B
SUMMARY OF ANALYTICAL RESULTS IN SEDIMENT SAMPLES
As, Cr, and PCP
Hatheway Patterson Site RTN 4-571
15 County Street
Mansfield MA
(results in mg/kg)
Sampled Date
Arsenic
Chromium
Pentachlorophenol
Field Samples
SED-1
5/16/2012
26
7
< 1
SED-2
5/16/2012
1.7
5
< 1
SED-3
5/16/2012
4.8
9
SED-4
5/16/2012
20 ""
26
<8
SED-4 Duplicate
5/16/2012
6.2
17
< 7
Notes:
List of flags and qualifiers is attached.
NA - not applicable
Results for non-detected comounds shown as less than (<) the laboratory reporting limit.
* EPA Fresh Water Screening Criterion
S:\Customers\S A R S S\Projects\Hathaway Mansfield\Analytical\revised tables
7/25/2012
1 of 1
-------
Data Qualifier Flags - Dioxin/Furans
o B Indicates the associated analyte is found in the method blank, as well as in the sample.
o C Confirmation of the TCDF compound: When 2378-TCDF is detected on the DB-5 column,
confirmation analyses are performed on a second column (DB-225). The results from both the
DB-5 column and the DB-225 column are included in this data package. The results from the
DB-225 analyses should be used to evaluate the 2378-TCDF in the samples. The confirmed
result should be used in determining the TEQ value for TCDF.
o E Indicates an estimated value - used when the analyte concentration exceeds the upper end of
the linear calibration range.
o J Indicates an estimated value - used when the analyte concentration is below the method
reporting limit (MRL) and above the estimated detection limit (EDL).
o K EMPC - When the ion abundance ratios associated with a particular compound are outside the
QC limits, samples are flagged with a 'K' flag. A 'K' flag indicates an estimated maximum
possible concentration for the associated compound.
o U Indicates the compound was analyzed and not detected.
o Y Samples that had recoveries of labeled standards outside the acceptance limits are flagged
with T. In all cases, the signal-to-noise ratios are greater than 10:1, making these data
acceptable.
o ND Indicates concentration is reported as 'Not Detected.'
o S Peak is saturated; data not reportable.
o P Indicates chlorodiphenyl ether interference present at the retention time of the target
compound.
o Q Lock-mass interference by chlorodiphenyl ether compounds.
E1200610 10 of 1117
-------
APPENDIX D
MANAGEMENT SYSTEM REVIEW
-------
TECHNICAL MEMORANDUM
MANAGEMENT SYSTEM REVIEW AND TECHNICAL COMPLIANCE EVALUATION
HATHEWAY AND PATTERSON SUPERFUND SITE
MANSFIELD, MASSACHUSETTS
JULY 2014
As part of the Five-Year Review for the Hatheway and Patterson Superfund Site in Mansfield, MA, a
Management System Review (MSR) has been performed which includes performance of a site
inspection, review of the remedy, and a technical compliance evaluation in order to evaluate whether
each element of the remedy is being maintained and operated in accordance with its intended function.
This technical memorandum includes the completed inspection checklist from the site inspection
performed on June 3, 2014, as well as annotated photographs of various site features taken on that date,
and a technical assessment of physical features of the remedy. The portion of the review associated with
risk standards was submitted under separate cover on June 9, 2014, in a memorandum entitled
Assessment of Changes in Standards Memorandum.
Background
The Hatheway & Patterson Superfund Site is located at 35 County Street in Mansfield, Massachusetts
(see Figure 1.1). Approximately 36 acres of the 38.17-acre site are located in the Town of Mansfield.
The remaining 1.77 acres are located in the Town of Foxborough. The site is divided into four quadrants
by the Rumford River, which runs north to south, and by a railroad right-of-way, which runs east to west.
The northeast (NE) and northwest (NW) quadrants are referred to as the "Process Area" and are located
north of the railroad tracks operated by CSX (see Figure 1.2). The southeast (SE) and southwest (SW)
quadrants cover the area south of the railroad tracks. The "County Street area" lies north of the site fence
in the northeast and northwest quadrants.
The majority of the historical operational areas and buildings were located on the northern portion of the
property, north of the railroad tracks, and contained process buildings, drip pads, support buildings, an
office, and a laboratory. With the exception of the office building, which was outside the remediation
area, these structures have been demolished or removed (Sevenson, 2011).
The site and surrounding area are served by municipal drinking water. Groundwater underlying the site is
designated as Class III (non-potable) by the Commonwealth of Massachusetts. The remedy outlined in
the ROD was based on an assumption that groundwater at the site is not available for drinking water by
future users of the site (USEPA, 2005).
History of Contamination
The land west of the Rumford River was owned by the Penn Central Railroad, who used it for bulk
chemical transfer and storage of electric/utility poles and railroad ties, until the land was purchased by
Hatheway & Patterson in 1978. The land south of the railroad tracks was purchased by Hatheway &
Patterson in 1981 and was apparently not used between 1955 and 1971, but was reportedly used for coal
storage prior to 1955 (USEPA, 2005).
1
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Hatheway & Patterson reportedly began operations at the site in 1927, but did not begin wood treating
until 1953. It is unknown what operations might have been conducted at the site between 1927 and 1953
(USEPA, 2005).
Wood treatment was accomplished by a variety of methods that changed over time. From 1953 through
1958, a solution of pentachlorophenol (PCP) in fuel oil, or creosote, was used for dipping lumber. After
dipping, excess chemicals were allowed to drip off of the treated wood onto the ground surface. From
1958 through 1974, solutions of PCP in fuel oil and fluoro-chrome-arsenate-phenol (FCAP) salts in water
were used in a pressure treatment process. From 1960 through 1984, PCP in mineral spirits was also
used to pressure-treat lumber. From 1974 to 1984, operations incorporated PCP in fuel oil and
chromated copper-arsenate (CCA) salts in water. From 1984 until operations ceased in 1993, solutions
of CCA salts in water and PCP in water were utilized at the property. Wood was also infused with fire
retardants, including Dricon (boric acid and anhydrous sodium tetraborate). The various wood-treating
chemicals were stored in aboveground storage tanks (ASTs), underground storage tanks (USTs), and
sumps located inside and outside of the former process buildings (USEPA, 2005). More detail on site
history is provided in the Five Year Review Report.
Remedial Action Objectives
The EPA ROD for the site was signed on September 30, 2005. Remedial Action Objectives (RAOs) were
developed for various media at the site based on the results of the Rl and risk assessments. The RAOs
were developed to aid in the development and screening of remedial alternatives.
The RAOs for the selected remedy for the site are:
Surface Soil (Process Area) - Prevent current and future trespassers and future on-site
residents (Foxborough parcel), commercial workers, town workers, and utility workers
from ingestion of or dermal contact with Contaminants of Potential Concern (COPCs)
(including arsenic, dioxin, and PCP) which would result in a cumulative excess cancer
risk greater than 10"4 to 10"6 or 1-11=1;
Subsurface Soil (Process Area) - Prevent future commercial workers and future on-site
residents (Foxborough parcel) from ingestion of or dermal contact with COPCs (including
arsenic, dioxin, and PCP) which would result in a cumulative risk greater than 10~4 to 10"
or 1-11=1;
Groundwater - Prevent discharge of pentachlorophenol and other COPCs from soil to
groundwater and from groundwater to surface water at concentrations that would result in
an in stream exceedence of the Ambient Water Quality Criteria (AWQCs) through source
control. Prevent exposure to groundwater by future residents, recreational users, or
commercial workers by monitoring extent of plume (to ensure it is remaining on-site) and
implementing institutional controls to restrict groundwater use within the site boundary;
Inter-Media Transfer - Eliminate or reduce potential for leaching through source control
and inter-media transfer of COPCs from soil to groundwater and surface water;
LNAPL - Minimize further contaminant transfer from LNAPL source material to
groundwater by reducing LNAPL source material in soil excavation/treatment areas.
2
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Minimize further migration of LNAPL free product to groundwater and surface water by
removing free product "hotspots" to the extent feasible.
The primary components of the ROD included:
Excavation of approximately 31,000 cubic yards of soil exceeding cleanup levels.
Demolition of the buildings in and near Hatheway & Patterson's former manufacturing
area to allow excavation of underlying contaminated soils and replacement of the
excavated soil with clean backfill.
Excavation of soils containing PCP, SVOCs, and arsenic, testing for leachability and, if
they fail, utilization of a stabilization/solidification agent(s). Consolidation of the
stabilized/solidified soils on-site under a low-permeability cover.
Off-site disposal of soils containing dioxin and oily material (LNAPL) at a licensed facility.
Institutional controls to prohibit the use of site groundwater and restrict land uses in a
manner that ensures the protectiveness of the remedy as described in this ROD, and
ensures the integrity of the on-site low-permeability cover and other remedial
components. Evaluation of risks from soil exposures within the area of the existing
railroad right of way during design and implementation of appropriate action such as
deed restrictions or other legal and administrative measures if necessary.
Long term monitoring of groundwater, surface water, fish tissue and sediment.
Five-year reviews, and operation and maintenance of remedial components, including the
low permeability cover.
An ESD (USEPA, 2011), issued in August 2011, had three main purposes as summarized below.
The remedy outlined in the ROD for the Foxborough parcel was based on future residential
use of the parcel as the property was zoned for residential use in 2005. After the ROD was
issued, the Town of Foxborough took ownership of the parcel through tax foreclosure with the
intent of redeveloping the parcel as a parking lot. In connection with this plan, the town voted
at the May 2008 Town Meeting to adopt a change in zoning of the lot from R-40 Residential
and Agricultural District to "Limited Industrial." The Town notified EPA of its intention to use
the parcel as a parking facility for the nearby MBTA commuter rail station. Based on the
change in zoning and intended reuse of the parcel, EPA and MassDEP determined that the
Foxborough parcel should be remediated to a Reasonably Anticipated Future Use (RAMU) of
commercial/open space and changed the cleanup level accordingly. EPA also determined
that a consolidation area for soils in Foxborough contaminated with arsenic could be built on
the Foxborough parcel and designed with an asphalt cover in order to facilitate reuse as a
parking facility.
EPA reevaluated the remedy for PCP and arsenic-contaminated soils excavated from the lots
in the Mansfield portion of the site. The remedy chosen in the ROD called for on-site
3
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consolidation of these soils, rather than disposal at an off-site facility. Subsequent to the
signing of the ROD, the relative costs of off-site disposal decreased significantly. EPA
reevaluated both options using criteria required under CERCLA to compare different remedial
options. The criteria included overall protection, long-term effectiveness and permanence,
community support, and cost. The remedy was changed since the costs were similar but the
off-site disposal option offered the greatest overall protection, long-term protectiveness, and
permanence.
EPA clarified the extent of institutional controls to be placed on the site properties as called
for in the ROD. Specifically, restrictions on future soil excavation, in the form of institutional
controls, will be needed in the northeast quadrant of the site: 1) below the depth of the
vertical extent of excavation reached during the remedial action (RA); and 2) at depths of two
feet and below in a strip of land bordering the northeast quadrant and County Street to a
distance about 5 feet laterally with the fence line. Institutional controls will also be necessary
to protect the cover placed over the consolidated soils in the Foxborough parcel. In addition,
institutional controls to eliminate on-site exposures to groundwater and to prevent residential
use will be necessary on all four quadrants of the site property.
Site Inspection
On June 3, 2014, Kimberly White of the US EPA and Warren Diesl of AECOM performed an inspection of
the Hatheway and Patterson site. Also present for part of the inspection was Garry Waldeck of
MassDEP. The site inspection checklist and photos are included as Attachments 1 and 2, respectively.
As described above, the site is divided into four quadrants by two features: a wide (100 +/- feet) active
railroad right-of-way, which is oriented NW-SE and divides the site into northern and southern sections,
and by the Rumford River, which flows southwest (after entering the site in the NW Quadrant and flowing
a short distance along County Road) and divides the site into eastern and western sections. The NE
quadrant is a vegetated field except for the extreme eastern end, where the Town of Mansfield has its
Emergency Management Agency building and a large storage building. The vegetation in the NE
Quadrant is reportedly cut twice per year and was due to be cut shortly after the site inspection. The NW
Quadrant is mostly covered with crushed rock except for a vegetated buffer along the Rumford River and
a commuter parking lot for the Town of Foxborough in the extreme northwest corner. As described in the
Site Inspection Checklist, the parking lot is well maintained, and the fencing and gates that surround the
entire NW and NE Quadrants of the site are in good condition (except for very minor damage to the
stockade fence on the northwest side of the commuter lot).
The monitoring wells that were observed were locked and appeared to be in good condition. The
compliance boundary on the southwest side of the site is the backwash channel, which is in a vegetated
marshy area which is difficult to traverse. Where observed near its confluence with the Rumford River,
the amount of water in the backwash channel was miniscule, and no flow was observable. However, at
the actual confluence, it was confirmed that the trickle of flow in the channel was moving northwest and
discharging to the river. The wells along the compliance boundary had been sampled several weeks
before the site inspection and were therefore not inspected.
Interviews
Representatives of the Town of Mansfield DPW and the Town of Foxborough, and the MassDEP Project
Manager each responded to a request for an interview by providing written responses to a series of
4
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interview questions. Attachment 3 includes a detailed summary of the interviews. In general,
representatives from both towns were very pleased with the work conducted at the Site. The town
representatives stated that they have been well informed throughout the process and that they have no
concerns. The representative from the Town of Mansfield would like to see the institutional controls
implemented so that the town can move forward with potential reuse of the property. Town of Mansfield
personnel periodically inspect the Site. It was noted by the representative from Mansfield that, although
vandalism has generally not been an issue at the Site, a few fence cuts in the deep woods have been
found. The Project Manager for the MassDEP also stated that the project was a success, that he was well
informed, and that he has no concerns.
Technical Compliance Evaluation of Remedy Components
The technical compliance evaluation is conducted to determine whether the individual components of the
remedy are being maintained and operated in accordance with their intended functions.
Evaluation of Intended Function:
The RAOs of preventing ingestion and dermal contact with surface and subsurface soils that
would result in unacceptable risks have been achieved as a result of the remedial action.
Institutional controls restricting inappropriate land uses and protecting the consolidation cell
cover and other components of the remedy, as required by the 2011 ESD, need to be
established to better ensure future protectiveness.
The RAO of preventing discharge of pentachlorophenol and other COPCs from soil to
groundwater and from groundwater to surface water at concentrations that would result in an
in-stream exceedance of the Ambient Water Quality Criteria (AWQCs) was addressed via
source control. The ROD and O&M Manual require annual surface water monitoring; however
no surface water sampling has been conducted since the remedy was completed. Surface
water sampling, in accordance with the ROD, is recommended in order to confirm that there
are no in-stream exceedances of the AWQCs..
The RAO of preventing exposure to groundwater by future residents, recreational users, or
commercial workers by monitoring extent of plume (to ensure it is remaining on-site) is being
addressed via the ongoing groundwater monitoring at existing monitoring wells. Institutional
controls restricting the use of groundwater within the site boundary, as required by the 2011
ESD, need to be established to better ensure future protectiveness. Also, as recommended in
the Hydrogeologic Conditions Report prepared by AECOM (2013), an expanded groundwater
monitoring effort at private wells beyond the compliance boundary is also being implemented
by EPA in response to the detection of contamination in monitoring wells at the boundary.
Although not expected, if off-site plume migration is detected during monitoring of private
wells, additional measures may be necessary to maintain protectiveness.
The exposure pathways that were stated in the ROD and ESD are still valid. More detail is
provided in the Assessment of Changes in Standards Memorandum.
The zoning of the Foxborough Parcel was changed from Future Residential to "Limited
Industrial". This changed was addressed in the ESD, issued in 2011, and does not affect the
protectiveness of the remedy.
5
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References
AECOM. 2013. Hydrogeologic Conditions Report. Letter report addressed to Mr. David Lederer of EPA-
New England, Region 1. March 29, 2013.
Sevenson Environmental Services, Inc. 2011. Final Remedial Action Completion Report. Hatheway and
Patterson Superfund Site. Mansfield, Massachusetts. September 2011.
U.S. Environmental Protection Agency (USEPA). 2005. Record of Decision. Hatheway & Patterson
Superfund Site, Mansfield-Foxborough, Massachusetts. September 30, 2005.
U.S. Environmental Protection Agency (USEPA). 2011. Declaration for the Explanation of Significant
Differences. Hatheway & Patterson Superfund Site, Mansfield/Foxborough, Massachusetts. August 2011.
6
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FIGURES
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Location of Facility
SITE LOCATION MAP
Hatheway and Patterson
Superfund Site
35 County Street
Mansfield, MA
FIGURE 1.1
Site Location
Q
ii Feet
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amec
AM EC Earth and Environmental, Inc.
2 Robbins Road
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-------
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LEGEND:
LOCATION OF PRE-DESIGN INVESTIGATION TEST-PlT (WW + NE QUADRANTS); SOILS COVERED WITH NON-REINFORCED
v>35W56'
R= 240.00
The locations and dimensions of the onslte tracks are sppronlmate-
The location of the 4 Inch gae line located along Country Street Is approximate.
Electrical power lines run along the western boundaiy of the Foxboro parcel.
Sewer connection leading to the former location of Building No. 3 was capped within the footprint of
Building No. 3.
Monitoring Wells MW-A through MW-G are sumps and piezometers associated wtth the LNAPL Recovery
System. The recovery eump for the system Is located In the vldnlty of MW-O.
Existing conditions present am taken from drawing entitled "Boundary/Topographic Survey
Land Now or Formerly of HPC Realty Trust" by Conklin & Scroka, Inc. dated August 22,2006.
GRAPHIC SCALE
Sevenson
Environmental
Services, Inc.
SERVICES. INC.
77&9 LOCKPORT ROAO
MAOARA FALLS, NY 14Mป
SOURCE DRAWING FROM CONSTRUCTION SPECIFICATIONS,
HATHEWAY & PATTERSON SUPERFUND SFTE, METCALF & EDDY. IMC
AND TRC ENVIRONMENTAL CORPORATION, 2008.
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UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
UNITED STATES ARMY CORPS OF ENGINEERS
AMEC Earth & Environmental
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OH1QWL SCALE:
AS SHOWN
PRE-REMEDIATTON SITE FEATURES
HATHEWAY AND PATTERSON SITE
35 COUNTY STREET
MANSFIELD, MASSACHUSETTS
-------
ATTACHMENT 1
SITE INSPECTION CHECKLIST
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Five-Year Review Site Inspection Checklist
("N/A" refers to "not applicable.")
I. SITE INFORMATION
Site name: Hatheway & Patterson) Superfund Site Date of inspection: June 3,2014
Location and Region: Mansfield, MA; Region I EPA ID: MAD001060805
Agency, office, or company leading the five-year Weather/temperature: Clear/80ฐF
review: USEPA/AECOM
Remedy Includes: (Check all that apply)
~ Landfill cover/containment ~ Monitored natural attenuation
X Access controls ~ Groundwater containment
X Institutional controls ~ Vertical barrier walls
~ Groundwater pump and treatment
~ Surface water collection and treatment
X Other Monitoring of groundwater, surface water, sediment and fish; asphalt-paved parking lot on
Foxborough portion of NW Quadrant of site
Attachments: ~ Inspection team roster attached ~ Site map attached
II. INTERVIEWS
Interviews were performed by USEPA/AECOM and are included separately.
1
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III. ON-SITE DOCUMENTS & RECORDS VERIFIED (Check all that apply)
1.
O&M Documents
X O&M manual
X As-built drawings
X Maintenance logs
X Readily available
X Readily available
~ Readily available
~ Up to date
~ Up to date
X Up to date
~ N/A
~ N/A
~ N/A
Remarks: O&M manual was included RA Report, along with as-built drawings.
2.
Site-Specific Health and Safety Plan ~ Readily available
~ Contingency plan/emergency response plan ~ Readily available
~ Up to date
~ Up to date
~ N/A
~ N/A
Remarks: Not seen or reviewed - presumably available at office of contractor who performs monitoring
and inspection.
3.
O&M and OSHA Training Records
~ Readily available
~ Up to date
~ N/A
Remarks: Not seen or reviewed - presumably available at office of contractor who performs monitoring
and inspection.
4.
Permits and Service Agreements
~ Air discharge permit
~ Effluent discharge
~ Waste disposal, POTW
~ Other permits
Remarks:
~ Readily available
~ Readily available
~ Readily available
~ Readily available
~ Up to date
~ Up to date
~ Up to date
~ Up to date
XN/A
XN/A
XN/A
XN/A
5.
Gas Generation Records
Remarks:
~ Readily available
~ Up to date
XN/A
6.
Settlement Monument Records
Remarks:
~ Readily available
~ Up to date
XN/A
7.
Groundwater Monitoring Records
Remarks:
X Readily available
X Up to date
~ N/A
8.
Leachate Extraction Records
~ Readily available
~ Up to date
XN/A
Remarks:
9.
Discharge Compliance Records
~ Air
~ Water (effluent)
~ Readily available
~ Readily available
~ Up to date
~ Up to date
XN/A
XN/A
10.
Daily Access/Security Logs
Remarks:
~ Readily available
~ Up to date
XN/A
2
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IV. O&M COSTS
1.
O&M Organization
~ State in-house
~ PRP in-house
~ Federal Facility in-house
~ Other
X Contractor for State
~ Contractor for PRP
~ Contractor for Federal Facility
2.
O&M Cost Records
Not Reviewed
3.
Unanticipated or Unusually High O&M Costs During Review Period
Describe costs and reasons:
V. ACCESS AND INSTITUTIONAL CONTROLS X Applicable ~ N/A
A.
Fencing
1.
Fencing damaged ~ Location shown on site map X Gates secured ~ N/A
Remarks: The cvclone fencing that surrounds most of the site aooears to be in good condition. The two
vehicle gates that provide access to the site off Countv Street are locked and in good condition, as are the
two vehicle gates that isolate the site from the (active) railroad tracks that bisect the site and the vehicle
gate that separates the Foxborough commuter narking lot from the rest of the NW Quadrant.
B.
Other Access Restrictions
1.
Signs and other security measures ~ Location shown on site map X N/A
Remarks
3
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c.
Institutional Controls (ICs)
1.
Implementation and enforcement
Site conditions imply ICs not properly implemented ~ Yes ~ No
Site conditions imply ICs not being fully enforced ~ Yes ~ No
Type of monitoring (e.#., self-reporting, drive by)
~ N/A
~ N/A
Frequency
Responsible party/agency
Contact
Name Title Date
Phone no.
Reporting is up-to-date ~ Yes ~ No
Reports are verified by the lead agency ~ Yes ~ No
~ N/A
~ N/A
Specific requirements in deed or decision documents have been met ~ Yes ~ No
Violations have been reported ~ Yes ~ No
Other problems or suggestions: ~ Report attached
~ N/A
~ N/A
Remarks ICs are not vet in place.
2.
Adequacy ~ ICs are adequate ~ ICs are inadequate
Remarks ICs are not vet in place.
~ N/A
D.
General
1.
Vandalism/trespassing ~ Location shown on site map X No vandalism evident
Remarks
2.
Land use changes on site X N/A
Remarks
3.
Land use changes off site X N/A
Remarks
VI. GENERAL SITE CONDITIONS
A.
Roads X Applicable ~ N/A
1.
Roads damaged ~ Location shown on site map X Roads adequate
Remarks
~ N/A
4
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B.
Other Site Conditions
Remarks The NE Ouadrant of the site is a vegetated field except for a small paved area at its eastern
end, where the Town of Mansfield has its Emergency Management Building and a large storage facility.
Vegetation is reportedly cut twice ocr vear and was due to be cut shortly after the site inspection.
The NW Ouadrant of the site is covered with crushed rock, except for the buffer strip along the Rumford
River and the commuter parking lot in the northwestern corner. The fencing that completely surrounds
the NE and NW Ouadrants of the site is in good condition, as are the two gates on County Street, the two
gates at the railroad crossing, and the gate that isolates the commuter parking lot.
VII. LANDFILL COVERS ~ Applicable XN/A
A.
Landfill Surface
1.
Settlement (Low spots) ~ Location shown on site map ~ Settlement not evident
Areal extent Depth
Remarks
2.
Cracks ~ Location shown on site map ~ Cracking not evident
Lengths Widths Depths
Remarks
3.
Erosion ~ Location shown on site map ~ Erosion not evident
Areal extent Depth
Remarks
4.
Holes ~ Location shown on site map ~ Holes not evident
Areal extent Depth
Remarks
5.
Vegetative Cover ~ Grass ~ Cover properly established ~ No signs of stress
~ Trees/Shrubs (indicate size and locations on a diagram)
Remarks
6.
Alternative Cover (armored rock, concrete, etc.) ~ N/A
Remarks
7.
Bulges ~ Location shown on site map ~ Bulges not evident
Areal extent Height
Remarks
5
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8.
Wet Areas/Water Damage
~ Wet areas
~ Ponding
~ Seeps
~ Soft subgrade
Remarks
~ Wet areas/water damage not evident
~ Location shown on site map Areal extent
~ Location shown on site map Areal extent
~ Location shown on site map Areal extent
~ Location shown on site map Areal extent
9.
Slope Instability ~ Slides
Areal extent
Remarks
~ Location shown on site map ~ No evidence of slope instability
B.
Benches ~ Applicable ~ N/A
(Horizontally constructed mounds of earth placed across a steep landfill side slope to interrupt the slope
in order to slow down the velocity of surface runoff and intercept and convey the runoff to a lined
channel.)
1.
Flows Bypass Bench
Remarks
~ Location shown on site map ~ N/A or okay
2.
Bench Breached
Remarks
~ Location shown on site map ~ N/A or okay
3.
Bench Overtopped
Remarks
~ Location shown on site map ~ N/A or okay
C.
Letdown Channels ~ Applicable ~ N/A
(Channel lined with erosion control mats, riprap, grout bags, or gabions that descend down the steep side
slope of the cover and will allow the runoff water collected by the benches to move off of the landfill
cover without creating erosion gullies.)
1.
Settlement ~ Location shown on site map ~ No evidence of settlement
Areal extent Depth
Remarks
2.
Material Degradation ~ Location shown on site map ~ No evidence of degradation
Material type Areal extent
Remarks
3.
Erosion ~ Location shown on site map ~ No evidence of erosion
Areal extent Depth
Remarks
6
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4.
Undercutting ~ Location shown on site map ~ No evidence of undercutting
Areal extent Depth
Remarks
5.
Obstructions Type ~ No obstructions
~ Location shown on site map Areal extent
Size
Remarks
6.
Excessive Vegetative Growth Type
~ No evidence of excessive growth
~ Vegetation in channels does not obstruct flow
~ Location shown on site map Areal extent
Remarks:
D.
Cover Penetrations ~ Applicable ~ N/A
1.
Gas Vents ~ Active ~ Passive
~ Properly secured/locked ~ Functioning ~ Routinely sampled
~ Evidence of leakage at penetration ~ Needs Maintenance
~ N/A
X Good condition
Remarks:
2.
Gas Monitoring Probes
~ Properly secured/locked ~ Functioning
~ Evidence of leakage at penetration
Remarks:
~ Routinely sampled
~ Needs Maintenance
~ Good condition
~ N/A
3.
Monitoring Wells (within surface area of landfill)
~ Properly secured/locked ~ Functioning
~ Evidence of leakage at penetration
Remarks
~ Routinely sampled
~ Needs Maintenance
~ Good condition
~ N/A
4.
Leachate Extraction Wells
~ Properly secured/locked ~ Functioning
~ Evidence of leakage at penetration
Remarks
~ Routinely sampled
~ Needs Maintenance
~ Good condition
~ N/A
5.
Settlement Monuments ~ Located
Remarks
~ Routinely surveyed
~ N/A
7
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E.
Gas Collection and Treatment
~ Applicable
~ N/A
1.
Gas Treatment Facilities
~ Flaring ~ Thermal destruction ~ Collection for reuse
~ Good condition ~ Needs Maintenance
Remarks:
2.
Gas Collection Wells, Manifolds and Piping
~ Good condition ~ Needs Maintenance
Remarks:
3.
Gas Monitoring Facilities (e.g., gas monitoring of adjacent homes or buildings)
~ Good condition ~ Needs Maintenance ~ N/A
Remarks
F.
Cover Drainage Layer
~ Applicable
~ N/A
1.
Outlet Pipes Inspected
Remarks:
~ Functioning
~ N/A
2.
Outlet Rock Inspected
Remarks:
~ Functioning
~ N/A
G.
Detention/Sedimentation Ponds
~ Applicable
~ N/A
1.
Siltation Areal extent
Depth ~ N/A
~ Siltation not evident
Remarks:
2.
Erosion Areal extent
Depth
~ Erosion not evident
Remarks
3.
Outlet Works ~ Functioning ~ N/A
Remarks
4.
Dam ~ Functioning ~ N/A
Remarks
8
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H. Retaining Walls
~ Applicable ~ N/A
1.
Deformations
Horizontal displacement
~ Location shown on site map ~ Deformation not evident
Vertical displacement
Rotational displacement
Remarks
2.
Degradation
Remarks
~ Location shown on site map ~ Degradation not evident
I. Perimeter Ditches/Off-Site Discharge ~ Applicable ~ N/A
1.
Siltation ~ Location shown on site map X Siltation not evident
Areal extent Depth
Remarks
2.
Vegetative Growth ~ Location shown on site map ~ N/A
~ Vegetation does not impede flow
Areal extent Type
Remarks:
3.
Erosion
Areal extent
~ Location shown on site map ~ Erosion not evident
Depth
Remarks
4.
Discharge Structure
Remarks:
~ Functioning ~ N/A
VIII. VERTICAL BARRIER WALLS ~ Applicable X N/A
1.
Settlement
Areal extent
~ Location shown on site map ~ Settlement not evident
Depth
Remarks
2.
Performance Monitoring Type of monitoring
~ Performance not monitored
Frequency ~ Evidence of breaching
Head differential
Remarks
9
-------
IX. GROUNDWATER/SURFACE WATER REMEDIES ~ Applicable XN/A
A.
Groundwater Extraction Wells, Pumps, and Pipelines ~ Applicable ~ N/A
1.
Pumps, Wellhead Plumbing, and Electrical
~ Good condition ~ All required wells properly operating ~ Needs Maintenance ~ N/A
Remarks:
2.
Extraction System Pipelines, Valves, Valve Boxes, and Other Appurtenances
~ Good condition ~ Needs Maintenance
Remarks:
3.
Spare Parts and Equipment
~ Readily available ~ Good condition ~ Requires upgrade ~ Needs to be provided
Remarks:
B. Surface Water Collection Structures, Pumps, and Pipelines ~ Applicable ~ N/A
1.
Collection Structures, Pumps, and Electrical
~ Good condition ~ Needs Maintenance
Remarks
2.
Surface Water Collection System Pipelines, Valves, Valve Boxes, and Other Appurtenances
~ Good condition ~ Needs Maintenance
Remarks
3.
Spare Parts and Equipment
~ Readily available ~ Good condition ~ Requires upgrade ~ Needs to be provided
Remarks
10
-------
c.
Treatment System ~ Applicable L N/A
1.
Treatment Train (Check components that apply)
~ Metals removal ~ Oil/water separation ~ Bioremediation
~ Air stripping ~ Carbon adsorbers
~ Filters: microfiltration and filter presses
~ Additive (e.g., chelation agent, flocculent)
~ Others
~ Good condition ~ Needs Maintenance
~ Sampling ports properly marked and functional
~ Sampling/maintenance log displayed and up to date
~ Equipment properly identified
~ Quantity of groundwater treated annually
~ Quantity of surface water treated annually
Remarks
2.
Electrical Enclosures and Panels (properly rated and functional)
~ N/A ~ Good condition ~ Needs Maintenance
Remarks
3.
Tanks, Vaults, Storage Vessels
~ N/A ~ Good conditionL Proper secondary containment ~ Needs Maintenance
Remarks
4.
Discharge Structure and Appurtenances
~ N/A ~ Good condition ~ Needs Maintenance
Remarks
5.
Treatment Building(s)
~ N/A ~ Good condition (esp. roof and doorways) ~ Needs repair
~ Chemicals and equipment properly stored
Remarks
6.
Monitoring Wells (pump and treatment remedy)
~ Properly secured/locked ~ Functioning X Routinely sampled ~ Good condition
~ All required wells located ~ Needs Maintenance ~ N/A
Remarks:
D. Monitoring Data:
1.
Monitoring Data
~ Is routinely submitted on time ~ Is of acceptable quality
2.
Monitoring data suggests:
~ Groundwater plume is effectively contained ~ Contaminant concentrations are declining
11
-------
D.
Monitored Natural Attenuation
1.
Monitoring Wells (natural attenuation remedy)
~ Properly secured/locked ~ Functioning ~ Routinely sampled ~ Good condition
~ All required wells located ~ Needs Maintenance ~ N/A
Remarks:
X. OTHER REMEDIES
Bituminous Asphalt Cover. The oortion of the NW Ouadrant of the site that is within the Town of
Foxborough was paved to create a commuter parking lot. The pavement appears to be in very good
condition, with only minor cracks along joints in the pavement and near the southern corner of the lot. No
settlement was observed. Silt fence at the outlet of the storm drainage system (possibly a relic from
construction) is breached, and minor repairs are needed at two locations along the stockade fence that
borders the northwest side of the lot. However, the overall condition of the lot is very good.
Monitoring Wells. The monitoring wells that were observed were locked and appeared to be in good
condition. None were marked, but the markings may be under the protective covers. A monitoring round
had been conducted a few weeks prior to the site inspection, and no deficiencies in the well network had
been reported.
XL OVERALL OBSERVATIONS
A.
Implementation of the Remedy
The remedy is effective and functioning as designed. Access to the site is restricted. Institutional
controls are not yet in place, but the site is inaccessible (except for along the railroad tracks) for activities
that would involve excavation or drilling. Monitoring of groundwater, surface water, sediment, and fish
are ongoing.
B.
Adequacy of O&M
Other than maintenance of the fencing that surrounds most of the site, little O&M is required. The
vegetation at the site is cut twice per year, and the portion of the site that is a commuter parking lot is in
good condition.
C. Early Indicators of Potential Remedy Problems
Describe issues and observations such as unexpected changes in the cost or scope of O&M or a high
frequency of unscheduled repairs that suggest that the protectiveness of the remedy may be compromised
in the future.
None
12
-------
D. Opportunities for Optimization
Describe possible opportunities for optimization in monitoring tasks or the operation of the remedy.
None
13
-------
ATTACHMENT 2
SITE PHOTOS
-------
HATHEWAY AND PATTERSON SUPERFUND SITE
June 3, 2014 - SITE INSPECTION PHOTOGRAPHS
Photo #1. Easternmost Gate to Site off County Road
Photo #2. Looking Southeast across NE Quadrant of Site
T00066-HATH RATI SITE INSP-Q60314-5.00 1
-------
Photo #3. Looking Southeast Across NW Quadrant of Site (NE Quadrant in distance)
T00066-HATH PATT SITE INSP-060314-500
2
-------
Photo #5. Gates at RR Crossing Between Northern and Southern Quadrants of Site
Photo #6. Rumford River Flowing Southwest in Channel Between NW and NE Quadrants of Site
(Railroad Bridges Across River in Background)
3
-------
Photo #7. Rumford River Downstream of Railroad Bridges and Upstream of Confluence with
Backwash Channel
Photo #8. Backwash Channel Flowing (ซ1 gpm, from left to right, in rivulet that crosses mud-filled
channel) into Rumford River
4
-------
Photo #9. Commuter Parking Lot on Foxborough Portion of Site (Note minor crack in pavement in
foreground along painted line)
Photo #10. Gate Separating Commuter Lot from NW Quadrant of Site (note flush-mount monitoring
well along fence, with road box painted white)
T00066-HATH PATT SITE INSP-060314-500
5
-------
ATTACHMENT 3
INTERVIEW RECORDS
-------
INTERVIEW RECORD
Site Name: Hatheway and Patterson Superfund Site (Mansfield,
MA)
EPA ID No.: MAD001060805
Subject: Five Year Review
Time:
Date:
Type: ~ Telephone
Location of Visit:
~ Visit
~ Other
~ Incoming ~ Outgoing
Contact Made By:
Name:
Title:
Organization: AECOM
Individual Contacted:
Name: Mike Ahern
Title: Department of
Public Works
Organization: Town of Mansfield
Telephone No: (508) 261-7335
Fax No:(508)261-7452
E-Mail: mahern@mansfieldma.com
Street Address: 6 Park Row,
Mansfield, MA 02048
1. What is your overall impression of the project? (general sentiment)
Project went very well. Town was very happy.
2. Do you feel well informed about site activities and progress?
Yes, the Town was kept very well informed throughout the process and was
invited to attend various project meetings to stay current with job progress.
3. What are the current uses of the property?
Presently part of the property is used for Mansfield Emergency Management
Agency and the rest is presently grassed areas and gravel parking.
4. What are the planned future uses of the property (if different from current
uses)?
Town is looking at the property for future uses including business development
and other potential uses.
5. Is there evidence or sightings of trespassers on the property? If yes, how
often and what type of activities do they engage in?
Generally no, although there has been a few, mainly hunters only. Whereas the
site has Emergency Management on site they constantly look at the site.
6. Have there been any events of vandalism at the property?
Generally no, except for few fence cuts in deep woods.
Page 1 of 3
-------
7. Have there been any unusual or unexpected activities or events at the site
(e.g., flooding)? If so, what if anything was done to address these issues?
In existing parking area there has been small ponding, but it is being addressed
by the Town. (No issue)
8. Have any problems been encountered or changes in the site conditions that
affect the current operations at the site?
No.
9. Has the site been the subject of any community complaints (e.g., odor,
noise, health, etc.)?
No.
10. Are you aware of any community concerns regarding the site or remedial
actions performed? If so, please provide details.
No.
11. Have there been routine communications or activities (site visits,
inspections, reporting activities, etc.) conducted by your office regarding the
site? If so, please give purpose and results.
We do general inspections and as stated in question 5, Mansfield Emergency
Management watches the site.
12. Do you have any comments, suggestions, or recommendations regarding
site management or operation?
Generally no, everything is going well. The only thing would be the completion of
the site specific activity use limitations so we can move forward with the
potential uses of the property.
13. Is there any other information that you wish to share that might be of use?
Overall, the project went very well. It was great working with the staff of the EPA
and the Army Corps of Engineers. Dave Lenderer from the EPA, Chris Turek
of the Army Corps of Engineers and Gary Waldeck from Mass DEP were all
exceptional to work with.
Page 2 of 3
-------
INTERVIEW RECORD
Site Name: Hatheway and Patterson Superfund Site (Mansfield,
MA)
EPA ID No.: MAD001060805
Subject: Five Year Review
Time: 2:40pm Date: 6/25/2014
Type: ~ Telephone
Location of Visit:
~ Visit
X Other
~ Incoming X Outgoing
Contact Made By:
Name:
Title:
Organization: AECOM
Individual Contacted:
Name: William R. Scollins,
Title: Finance
Director
Organization: Town of
Foxborough
Telephone No: 508-543-1218
Fax No: 508-543-6278
E-Mail: rscollins@town.foxborough.ma.us
Street Address: 40 South Street,
Foxborough, MA 02035
1. What is your overall impression of the project? (general sentiment)
We are very pleased with the result. To have a long standing hazardous waste site
cleaned up in a residential neighborhood and then repurposed for the benefit of the
Foxborough residents is incredibly positive for all.
2. Do you feel well informed about site activities and progress?
Yes. During the cleanup and reconstruction of the property, the project managers
maintained a website that was kept updated with all activities and progress. When
there were critical decisions to be made appropriate meetings were held with Town
officials.
3. What are the current uses of the property?
A dedicated free commuter parking lot for Foxborough residents only who take the
commuter rail from Mansfield, as per the site conditions.
4. What are the planned future uses of the property (if different from current
uses)?
The Town is prohibited from changing the use from a parking lot to anything else, as
per the conditions of the funding award.
5. Is there evidence or sightings of trespassers on the property? If yes, how
often and what type of activities do they engage in?
Page 1 of 2
-------
The local police patrol all areas of the Town including this parking lot. No trespassers
have been reported. The property is well lit and signed.
6. Have there been any events of vandalism at the property?
None have been reported.
7. Have there been any unusual or unexpected activities or events at the site
(e.g., flooding)? If so, what if anything was done to address these issues?
None have been reported.
8. Have any problems been encountered or changes in the site conditions that
affect the current operations at the site?
None.
9. Has the site been the subject of any community complaints (e.g., odor,
noise, health, etc.)?
None.
10. Are you aware of any community concerns regarding the site or remedial
actions performed? If so, please provide details.
No concerns, other than a preference for a dedicated pathway from the parking lot to
the Mansfield commuter rail station, which is a half mile away. This would require a
level of funding that Foxborough would find quite difficult to absorb. Further, the
pathway would be primarily on property in the Town of Mansfield.
11. Have there been routine communications or activities (site visits,
inspections, reporting activities, etc.) conducted by your office regarding the
site? If so, please give purpose and results.
We have actively promoted the site to residents at the Foxborough Town Hall &
website, as well as the Mansfield train station. The police dept patrols the site routinely
as part of their rounds. The highway dept maintains the light fixtures, signage, fencing,
and grounds, including plowing and striping.
12. Do you have any comments, suggestions, or recommendations regarding
site management or operation?
None at this time.
13. Is there any other information that you wish to share that might be of use?
We are grateful that this site was chosen to be remediated. The neighbors are pleased
and the commuters are also pleased to have this lot as an option.
Page 2 of 2
-------
INTERVIEW RECORD
Site Name: Hatheway and Patterson Superfund Site (Mansfield,
MA)
EPA ID No.: MAD001060805
Subject: Five Year Review
Time:
Date:
Type: ~ Telephone
Location of Visit:
~ Visit
~ Other
~ Incoming ~ Outgoing
Contact Made By:
Name:
Title:
Organization: AECOM
Individual Contacted:
Name: Garry Waldeck
Title: State
Remedial
Project manager
Organization: MassDEP
Telephone No: (617) 348-4017
Fax No:
E-Mail Address:
gairv.waldeck@state.ma.us
Street Address:
1 Winter Street
Boston, MA 02108
1. What is your overall impression of the project? (general sentiment)
The construction of the remedy is complete and the project was a success.
2. Have there been routine communications or activities (site visits,
inspections, reporting, etc.) conducted by your office at the site? If so, please
give purpose and results.
Yes, MassDEP has been performing the O and M for the site, including
groundwater and sediment sampling.
3. Have there been any complaints, violations, or other incidents related to the
site requiring response by your office? If so, please give details of the events
and results of the responses.
No.
4. Do you feel well informed about site activities and progress?
Yes
Page 1 of 2
-------
5. Do you have any comments, suggestions, or recommendations regarding
the site's management or operation?
No
6. Are you aware of any problems or issues that will affect the progress or
implementability of the proposed institutional controls?
No
7. Is there evidence or sightings of trespassers on the property, or evidence of
vandalism? If yes, how often and what type of activities do they engage in?
No
8. Have there been any unusual or unexpected activities or events at the site
(e.g., flooding)? If so, has this resulted in any damage or had an impact on
operations at the site?
No
9. Has the site been the subject of any community complaints (e.g., odor,
noise, health, etc.)?
No
10. Is there any other information that you wish to share that might be of use?
No
11. What are the annual system operation/O&M costs for OU-1 since the RA was
completed? Please provide in the following format:
Dates
Total Cost (rounded to nearest $1,000)
From
To
4/1/12
6/6/14
$111,000
Page 2 of 2
-------
APPENDIX E
INTERVIEW RECORD FORMS
-------
INTERVIEW RECORD
Site Name: Hatheway and Patterson Superfund Site (Mansfield,
MA)
EPA ID No.: MAD001060805
Subject: Five Year Review
Time:
Date:
Type: ~ Telephone
Location of Visit: by email
~ Visit
X Other
~ Incoming ~ Outgoing
Contact Made By:
Name: Cinthia McLane
Title: Project Manager
Organization: AECOM
Individual Contacted:
Name: Garry Waldeck
Title: State
Remedial
Project manager
Organization: MassDEP
Telephone No: (617) 348-4017
Fax No:
E-Mail Address:
garrv.waldeck@state.ma.us
Street Address:
1 Winter Street
Boston, MA 02108
1. What is your overall impression of the project? (general sentiment)
The construction of the remedy is complete and the project was a success.
2. Have there been routine communications or activities (site visits,
inspections, reporting, etc.) conducted by your office at the site? If so, please
give purpose and results.
Yes, MassDEP has been performing the O and M for the site, including
groundwater and sediment sampling.
3. Have there been any complaints, violations, or other incidents related to the
site requiring response by your office? If so, please give details of the events
and results of the responses.
No.
4. Do you feel well informed about site activities and progress?
Yes
Page 1 of 2
-------
5. Do you have any comments, suggestions, or recommendations regarding
the site's management or operation?
No
6. Are you aware of any problems or issues that will affect the progress or
implementability of the proposed institutional controls?
No
7. Is there evidence or sightings of trespassers on the property, or evidence of
vandalism? If yes, how often and what type of activities do they engage in?
No
8. Have there been any unusual or unexpected activities or events at the site
(e.g., flooding)? If so, has this resulted in any damage or had an impact on
operations at the site?
No
9. Has the site been the subject of any community complaints (e.g., odor,
noise, health, etc.)?
No
10. Is there any other information that you wish to share that might be of use?
No
11. What are the annual system operation/O&M costs for OU-1 since the RA was
completed? Please provide in the following format:
Dates
Total Cost (rounded to nearest $1,000)
From
To
4/1/12
6/6/14
$111,000
Page 2 of 2
-------
INTERVIEW RECORD
Site Name: Hatheway and Patterson Superfund Site (Mansfield,
MA)
EPA ID No.: MAD001060805
Subject: Five Year Review
Time: 2:40pm Date: 6/25/2014
Type: ~ Telephone
Location of Visit:
~ Visit
X Other
~ Incoming X Outgoing
Contact Made By:
Name: Cinthia McLane
Title: Project Manager
Organization: AECOM
Individual Contacted:
Name: William R. Scollins,
Title: Finance
Director
Organization: Town of
Foxborough
Telephone No: 508-543-1218
Fax No: 508-543-6278
E-Mail: rscollins@town.foxborough.ma.us
Street Address: 40 South Street,
Foxborough, MA 02035
1. What is your overall impression of the project? (general sentiment)
We are very pleased with the result. To have a long standing hazardous waste site
cleaned up in a residential neighborhood and then repurposed for the benefit of the
Foxborough residents is incredibly positive for all.
2. Do you feel well informed about site activities and progress?
Yes. During the cleanup and reconstruction of the property, the project managers
maintained a website that was kept updated with all activities and progress. When
there were critical decisions to be made appropriate meetings were held with Town
officials.
3. What are the current uses of the property?
A dedicated free commuter parking lot for Foxborough residents only who take the
commuter rail from Mansfield, as per the site conditions.
4. What are the planned future uses of the property (if different from current
uses)?
The Town is prohibited from changing the use from a parking lot to anything else, as
per the conditions of the funding award.
5. Is there evidence or sightings of trespassers on the property? If yes, how
often and what type of activities do they engage in?
Page 1 of 2
-------
The local police patrol all areas of the Town including this parking lot. No trespassers
have been reported. The property is well lit and signed.
6. Have there been any events of vandalism at the property?
None have been reported.
7. Have there been any unusual or unexpected activities or events at the site
(e.g., flooding)? If so, what if anything was done to address these issues?
None have been reported.
8. Have any problems been encountered or changes in the site conditions that
affect the current operations at the site?
None.
9. Has the site been the subject of any community complaints (e.g., odor,
noise, health, etc.)?
None.
10. Are you aware of any community concerns regarding the site or remedial
actions performed? If so, please provide details.
No concerns, other than a preference for a dedicated pathway from the parking lot to
the Mansfield commuter rail station, which is a half mile away. This would require a
level of funding that Foxborough would find quite difficult to absorb. Further, the
pathway would be primarily on property in the Town of Mansfield.
11. Have there been routine communications or activities (site visits,
inspections, reporting activities, etc.) conducted by your office regarding the
site? If so, please give purpose and results.
We have actively promoted the site to residents at the Foxborough Town Hall &
website, as well as the Mansfield train station. The police dept patrols the site routinely
as part of their rounds. The highway dept maintains the light fixtures, signage, fencing,
and grounds, including plowing and striping.
12. Do you have any comments, suggestions, or recommendations regarding
site management or operation?
None at this time.
13. Is there any other information that you wish to share that might be of use?
We are grateful that this site was chosen to be remediated. The neighbors are pleased
and the commuters are also pleased to have this lot as an option.
Page 2 of 2
-------
INTERVIEW RECORD
Site Name: Hatheway and Patterson Superfund Site (Mansfield,
MA)
EPA ID No.: MAD001060805
Subject: Five Year Review
Time:
Date:
Type: ~ Telephone
Location of Visit:
~ Visit
~ Other
~ Incoming ~ Outgoing
Contact Made By:
Name:
Title:
Organization: AECOM
Individual Contacted:
Name: Mike Ahern
Title: Department of
Public Works
Organization: Town of Mansfield
Telephone No: (508) 261-7335
Fax No:(508)261-7452
E-Mail: mahern@mansfieldma.com
Street Address: 6 Park Row,
Mansfield, MA 02048
1. What is your overall impression of the project? (general sentiment)
Project went very well. Town was very happy.
2. Do you feel well informed about site activities and progress?
Yes, the Town was kept very well informed throughout the process and was
invited to attend various project meetings to stay current with job progress.
3. What are the current uses of the property?
Presently part of the property is used for Mansfield Emergency Management
Agency and the rest is presently grassed areas and gravel parking.
4. What are the planned future uses of the property (if different from current
uses)?
Town is looking at the property for future uses including business development
and other potential uses.
5. Is there evidence or sightings of trespassers on the property? If yes, how
often and what type of activities do they engage in?
Generally no, although there has been a few, mainly hunters only. Whereas the
site has Emergency Management on site they constantly look at the site.
6. Have there been any events of vandalism at the property?
Generally no, except for few fence cuts in deep woods.
Page 1 of 3
-------
7. Have there been any unusual or unexpected activities or events at the site
(e.g., flooding)? If so, what if anything was done to address these issues?
In existing parking area there has been small ponding, but it is being addressed
by the Town. (No issue)
8. Have any problems been encountered or changes in the site conditions that
affect the current operations at the site?
No.
9. Has the site been the subject of any community complaints (e.g., odor,
noise, health, etc.)?
No.
10. Are you aware of any community concerns regarding the site or remedial
actions performed? If so, please provide details.
No.
11. Have there been routine communications or activities (site visits,
inspections, reporting activities, etc.) conducted by your office regarding the
site? If so, please give purpose and results.
We do general inspections and as stated in question 5, Mansfield Emergency
Management watches the site.
12. Do you have any comments, suggestions, or recommendations regarding
site management or operation?
Generally no, everything is going well. The only thing would be the completion of
the site specific activity use limitations so we can move forward with the
potential uses of the property.
13. Is there any other information that you wish to share that might be of use?
Overall, the project went very well. It was great working with the staff of the EPA
and the Army Corps of Engineers. Dave Lenderer from the EPA, Chris Turek
of the Army Corps of Engineers and Gary Waldeck from Mass DEP were all
exceptional to work with.
Page 2 of 3
-------
APPENDIX F
RISK CALCULATIONS
-------
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Post-Excavation
Soil Sample Locations
Hatheway and Patterson
Superfund Site
35 County Street
Mansfield, MA
FIGURE 4.1
115
Feet
ame
cฎ
AMEC Environment & Infrastructure, Inc.
2 Robbins Road
NV Westford, MA 01886
(978) 692-9090
Legend
Confirmatory Soil Sample Location
(Hatheway-Patterson Site)
Post Excavation Soil Sample Location
(CSX Right of Way)
Limit of Excavation
Location of Facility
H: Sovonson'.Hath&Pat'Task6 MXD'Fig_4-1 .mxd August23, 2011 DWN: JDP APC CHKD: AKN
Aerial Imagery Source: MassGIS, 2008
-------
UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
I I Regi0n 1
^ 5 Post Office Square, Suite 100
^ BOSTON, MA 02109-3912
pRCrtfc '
Date: June 18, 2014
From: Chau Vu, Human Health Risk Assessor, Technical & Enforcement Support
Section
To: Kimberly White, RPM, MA Superfund Section
Subject: Update on Risks from Railroad Right-of-Way Exposures, Hatheway and Patterson
Superfund Site
The purpose of this memorandum is to update Margaret McDonough's May 24, 2007 and March
31, 2011 memoranda on risk evaluation for the railroad right-of-way exposures at the Hatheway
and Patterson Superfund Site (Appendix L of the September 2011 Final Remedial Action
Completion Report for the Hatheway and Patterson Superfund Site). This update is performed to
reflect the new release of the OSWER Directive 9200.1-120 dated February 6, 2014 on the
Update of Standard Default Exposure Factors and the finalization of dioxin non-cancer oral
reference dose (RfD) in February 2012 on EPA Integrated Risk Information System (IRIS).
Prior to the final dioxin RfD value on IRIS, non-cancer health effects from exposures to dioxin
were not usually evaluated due to the lack of a non-cancer toxicity value. This memorandum
also includes the use of the default relative bioavailability value of 60% or 0.6 of arsenic in soil
according to the December 2012 OSWER Directive 9200.1-113 Recommendations for Default
Value for Relative Bioavailability of Arsenic in Soil. Due to the changes of standard default
exposure factors, relative bioavailability for arsenic, and new dioxin RfD value, risk estimates
for receptors exposed to contaminated subsurface soils at the railroad right-of-way on the Site
have changed.
Similar to the 2007 and 2011 memos, risk screening and risk evaluation are performed in this
memorandum using the maximum detected concentrations of pentachlorophenol (PCP), dioxin,
and arsenic presented in the September 2011 Final Remedial Action Completion Report. The
maximum detected concentrations are used from the 2010 dataset for post-excavation soil from
the Report because these are soils closest to the railroad tracks and there are no samples collected
from the railroad tracks themselves. Although there are five samples, including a duplicate
sample, from the adjacent Northeast quadrant, and four samples from the Northwest quadrant,
there are not sufficient samples to calculate a statistically significant 95th upper confidence limit
(95% UCL) value for exposure point concentration. In this situation, it is EPA's practice to use
the maximum detected concentration in the dataset to be conservative.
Risks are calculated for utility workers who are assumed to conduct repairs and maintenance at
the railroad right-of-way area and exposed to contaminated subsurface soils via incidental
1
-------
ingestion and dermal contact pathways. Table 1 below presents the default exposure factors for
utility worker previously used in the 2007 and 2011 memos along with the currently
recommended values from the 2012 and 2014 OSWER Directives and the 2012 dioxin IRIS
update. For those exposure values not currently recommended, the values are kept the same as
those used in previous memos.
Table 1 - Utility Worker Exposure Factors and Toxicity Values
Exposure Factors and Toxicity Values
(units)
Symbol
Previous Default
Value
Currently
Recommended
Value
Soil/sediment ingestion rate - intense
contact (mg/day)
IRworker
200
200
Default relative bioavailability for arsenic
(%)
RBAarSenic
100
60
Exposure frequency (days/year)
EF
66
66
Body weight (kg)
BWWorker
70
80
Skin surface area (cm2)
S Aworker
3300
3470
Adherence factor (mg/cm ) - utility
worker
AF
0.2
0.12
Absorption factor for PCP (unitless)
ABSpcp
0.13
0.25
Absorption factor for dioxin (unitless)
ABS dioxin
0.13
0.03
Absorption factor for arsenic (unitless)
ABSarsenic
0.13
0.03
Cancer slope factor for PCP (mg/kg-day)"1
CSFpcp
0.4
0.4
Reference dose for PCP (mg/kg-day)
RfDpcp
5E-03
5E-03
Cancer slope factor for dioxin (mg/kg-
day)"1
C SF dioxin
1.5E+05
1.5E+05
Reference dose for dioxin (mg/kg-day)
RfDdioxin
Not Available
7E-10
Cancer slope factor for arsenic (mg/kg-
day)"1
C SF arsenic
1.5
1.5
Reference dose for arsenic (mg/kg-day)
RfDarsenic
3E-04
3E-04
Averaging time for cancer risk (year)
AT cancer
70
70
Averaging time for non-cancer risk -
utility worker (year)
ATnoncancer
1
1
Bold text represents the exposure values changed since 2011.
Risk screening for 2010 subsurface soil data
Following EPA's risk assessment practice, the maximum detected concentrations of the 2010
dataset for post-excavation soil from the 2011 Final Remedial Action Completion Report are
used to screen against the risk-based screening levels. Table 2 below presents the maximum
concentrations and screening levels.
2
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Table 2 - Maximum Concentrations near Railroad Right-of-Way Compared to EPA Risk-
Based Screening Levels
Maximum
Detected
PCP
(mg/kg)
EPA PCP
Screening
Level
(mg/kg)
Maximum
Detected
Dioxin
(mg/kg)
EPA Dioxin
Screening
Level (mg/kg)
Maximum
Detected
Arsenic
(mg/kg)
EPA Arsenic
Screening
Level
(mg/kg)
152
4
(1E-06 risk)
6.76E-03
2.2E-05
(1E-06 risk)
309
3
(1E-06 risk)
The EPA screening levels are developed based on a target cancer risk level of 1E-06 or an HI of
0.1 for each contaminant for commercial/industrial exposure scenario, using the standard EPA
risk methodology. These chemical-specific values are selected from the May 2014 EPA
Regional Screening Levels (RSLs) available at http://www.epa.gov/reg3hwmd/risk/human/rb-
concentration table/. Since the maximum detected concentrations of PCP, dioxin, and arsenic in
subsurface soils near the railroad right-of-way exceed their respective screening levels, further
risk evaluation is performed for these detected subsurface soil levels for utility worker and
construction worker.
Risk evaluation for utility worker
The following equations are used to estimate cancer risks and non-cancer hazards for utility
worker exposed to PCP, dioxin, and arsenic in subsurface soils at the railroad right-of-way area.
Please refer to Table 1 above for more detailed descriptions of the values used in the equations.
Ingestion Pathway
Equation 1
Cancer Risk =
CSF x RBA xCxlO"6 kg/mg x IR x ED x EF
BW x ATcancer x 365 days/year
Where:
CSF = cancer slope factor
RBA = default relative bioavailability for arsenic
C = maximum detected concentration
IR = ingestion rate
ED = exposure duration
EF = exposure frequency
BW = body weight
AT cancer = averaging time for cancer
Equation 2
Hazard Index =
C x RBA x 10"6 kg/mg x IR x ED x EF
RfD x BW x AT,
noncancer
x 365 days/year
3
-------
Where:
C
maximum detected concentration
RBA
default relative bioavailability for arsenic
IR
ingestion rate
ED
exposure duration
EF
exposure frequency
RfD
reference dose
BW
body weight
ATnonCancer
averaging time for non-cancer
Dermal Pathway
Equation 3
Cancer risk =
CSF x RBA x C x 10"6kg/mg x ED x EF x ABS x AF x SA
BW x ATcancer x 365 days/year
Where:
CSF
= cancer slope factor
RBA
= default relative bioavailability for arsenic
C
= maximum detected concentration
ED
= exposure duration
EF
= exposure frequency
ABS
= absorption factor
AF
= adherence factor
SA
= skin surface area
BW
= body weight
AT cancer
= averaging time for cancer
Equation 4
C x RBA x 10"6 kg/mg x ED x EF x ABS x AF x SA
Hazard Index =
RfD x BW x ATnoncancer x 365 days/year
Where:
C
= maximum detected concentration
RBA
= default relative bioavailability for arsenic
ED
= exposure duration
EF
= exposure frequency
ABS
= absorption factor
AF
= adherence factor
SA
= skin surface area
RfD
= reference dose
4
-------
BW = body weight
ATnoncanCer = averaging time for non-cancer
Similar to the 2007 and 2011 memos, utility workers are assumed to be exposed to contaminated
subsurface soils at the railroad right-of-way area via incidental ingestion and dermal exposure
pathways. Inhalation of subsurface soils is not considered an exposure pathway for this receptor.
Equation 5
Total Cancer Risk = Ingestion Risk + Dermal Risk
Equation 6
Total Hazard Index = Ingestion HI + Dermal HI
Applying the values from Tables 1 and 2 to these equations, the risk and hazard estimates for
utility worker exposed to pentachlorophenol, dioxin, and arsenic in subsurface soils at the
railroad right-of-way area are presented in Table 3 below.
Table 3 - Utility Worker Estimated Cancer Risk and Hazard Index
Subsurface Soil
Maximum Concentration
Cancer Risk for
Hazard Index for
Contaminant
in Subsurface Soil (mg/kg)
Utility Worker
Utility Worker
Pentachlorophenol
152
5E-07
0.02
Dioxin
6.76E-03
7E-06
4.7
Arsenic
309
2E-06
0.3
Total
1E-05
5.0
Table 3 shows that by using the updated exposure values and toxicity values with the 2010
subsurface soil data, total cancer risk estimate for utility workers from exposures to maximum
detected concentrations of PCP, dioxin, and arsenic in subsurface soil is similar to the total
cancer risk of 1E-05 calculated in the previous memo and is within EPA's acceptable risk range
of 10-4 to 10-6. However, the non-cancer total hazard index of 5.0 would exceed the acceptable
hazard index level of 1, mainly due to dioxin in soil.
Risk evaluation for construction worker
The 2007 memo stated that a construction worker scenario is unlikely because it is based on the
assumption that the railroad tracks will be removed in the future. However, risks are still
estimated for a construction worker. Similar to the 2007 memo, a construction worker is
assumed to be exposed to contaminated soil on the railroad right-of-way for aboutl80 days or 6
months, approximately 3 times longer than assumed for the utility worker. Thus, the total risks
for construction worker would be 3 times greater than those estimated for utility worker
presented in Table 3 above. These risk estimates are shown in Table 4 below.
5
-------
Table 4 - Construction Worker Estimated Cancer Risk and I
azard Index
Subsurface Soil
Contaminant
Maximum Concentration
in Subsurface Soil (mg/kg)
Cancer Risk for
Construction
Worker
Hazard Index for
Construction
Worker
Pentachlorophenol
152
2E-06
0.06
Dioxin
6.76E-03
2E-05
14.1
Arsenic
309
6E-06
0.9
Total
3E-05
15.0
Table 4 shows that the total cancer risk estimate of 3E-05 for construction worker scenario is
within EPA's acceptable risk range of 10-4 to 10-6. However, the non-cancer total hazard index
of 15.0 would exceed the acceptable hazard index level of 1, mainly due to dioxin in soil.
Conclusion
The potential estimated non-cancer hazard to a utility worker, the most likely scenario in the
railroad right-of-way, exceeds the acceptable level of 1 for hazard index based on the assumption
that concentrations bordering the tracks are representative of this exposure. The potential
estimated non-cancer hazard to a construction worker is higher, but the construction worker
scenario is considered unlikely to occur at the railroad right-of-way.
6
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APPENDIX G
ARARs REVIEW TABLES
-------
Chemical-Specific ARARs
Media/Authority
Requirements and Status
Requirement Synopsis
Action to Attain ARAR
Five Year Review
All Media
Federal Criteria,
Advisories, and
Guidance
American Conference of
Governmental Industrial
Hygienists Threshold
Limit Values (TLVs)
ROD Status: To Be
Considered (TBC)
5-Yr Status: Not ARAR
Health-based guidelines for
exposure limit represented in
terms of exposure over a
workday (8 hours) or a work
week (40 hours). These
standards were issued as
consensus standards for
controlling air quality in work
place environments.
TLVs will be used for
assessing site inhalation risks
for site remediation workers.
These guidelines were To Be Considered (TBC) for air
monitoring during active phases of the remedial construction.
No further land disturbing activities are anticipated, thus these
guidelines are no longer ARAR unless further land disturbing
activities are conducted. This ARAR is more appropriate as
an Action-Specific ARAR.
EPA Risk Reference Dose
(RfDs) and EPA
Carcinogen Assessment
Group Potency Factors
ROD Status: TBC
5-Yr Status: TBC
Reference dose is an estimate of
a daily oral exposure to human
populations that is likely to be
without an appreciable risk of
non-cancer effects. The Cancer
Group Potency factors are used
as qualitative weight-of-evidence
judgment as to the likelihood of a
chemical being a carcinogen.
Risks due to carcinogens and
noncarcinogens with EPA
RfDs and carcinogens with
Cancer Potency factors were
used to develop target
cleanup levels and evaluate
remedial alternatives.
These values were used in the risk assessment and
development of soil cleanup levels and any future risk
calculations are expected to use these values.
EPA Carcinogenicity
Slope Factors
ROD Status: TBC
5-Yr Status: TBC
Slope factors are developed by
EPA from health effects
assessments. Carcinogenic
effects present the most up-to-
date information on cancer risk.
Risks due to carcinogens as
assessed with slope factors
were used to develop target
cleanup levels and evaluate
remedial alternatives.
These values were used in the risk assessment and
development of soil cleanup levels and any future risk
calculations are expected to use these values.
OSWER Draft Guidance
for Evaluating the Vapor
Intrusion to Indoor Air
Pathway from
Groundwater and Soils
This draft guidance establishes a
methodology for assessing
indoor air risks to human health.
Risks associated with future
residential exposure to indoor
air were evaluated consistent
with this guidance.
Vapor intrusion was evaluated in the risk assessment
consistent with the draft guidance. This guidance has not yet
been finalized. Once finalized, potential impacts related to
the institutional controls (not yet implemented) should be
evaluated.
ROD Status: TBC
5-Yr Status: TBC
US EPA Guidance:
Approach for Addressing
Dioxin in Soil at CERCLA
and RCRA Sites
ROD Status: TBC
5-Yr Status: Not ARAR
Recommends PRG's or points of
departure for cleanup levels for
dioxin in soils and sediments at
CERCLA sites. Recommended
cleanup levels are based on direct
exposure pathway.
This guidance was used in
setting cleanup levels for
dioxin-contaminated soils.
The cleanup level for dioxin in soil was based on the
recommended level in this 1998 EPA guidance. Since the
2005 ROD, an RfD was developed for dioxin and is now the
recommended toxicity value "to be considered" in developing
dioxin cleanup levels under CERCLA. Refer to the response
to "Question B" in the five-year review text for the discussion
of the potential impacts of the change.
-------
Chemical-Specific ARARs
Media/Authority
Requirements and Status
Requirement Synopsis
Action to Attain ARAR
Five Year Review
Other Guidance
Ontario Ministry of
Environment and Energy
(OMEE) Lowest and
Severe Effect Levels
(LELs and SELs) for
Freshwater Sediments
(Persaud et al.. 1993)
ROD Status: TBC
5-Yr Status: TBC
The LEL value is the
concentration at which the
majority of the sediment-
dwelling organisms are not
affected.
The LEL value was used for
selecting Chemicals of
Potential Concern and for
characterizing ecological
effects for all alternatives and
to assist in setting
soil/sediment cleanup levels.
These values were used as screening values for the baseline
ecological risk assessment and any future risk calculations are
expected to use these values. Note that no cleanup levels
were developed for sediment and these sediment criteria were
not used in setting soil cleanup levels.
-------
Location-Specific ARARs
Media/Authority
Requirements
Requirement Synopsis
Action to Attain ARAR
Five-Year Review
All Media
Federal Regulatory
Requirements
Executive Order 11990;
"Protection of Wetlands"
(40 CFR Part 6, Appendix
A)
ROD Status: Applicable
5-Yr Status: Applicable
Under this requirement, no
activity that adversely affects a
wetland shall be permitted if a
practicable alternative with lesser
effects is available. Action to
avoid, whenever possible, the
long-and short-term impacts on
wetlands and to preserve and
enhance wetlands. If activity
takes place, impacts must be
minimized to the maximum
extent.
Wetlands have been identified on the
site and excavation, consolidation and
installation of monitoring wells occur
in or around wetlands. Because high
levels of contamination exist in or
near wetlands areas, there is no
practicable alternative to excavating
or consolidating in these areas. All
practicable means will be used to
minimize harm to the wetlands.
Wetlands disturbed by remedial
activities will be mitigated, restored,
or preserved. The Proposed Plan will
solicit specific comments on this
work.
Buffer zone adjacent to the Rumford River was
impacted by the remedial construction and
subsequently restored by grading and replanting with
native species, followed by a one-year monitoring
period that resulted in some additional replanting in
2011. This requirement remains applicable to any
future activities, such as installation of monitoring
wells, if determined to be needed in or around
wetlands.
Fish and Wildlife Co-
ordination Act (16 U.S.C.
ง661 et seq.); Fish and
wildlife protection (40
CFR ง6.302(g))
ROD Status: Applicable
5-Yr Status: Not ARAR
Any modification of a body of
water requires consultation with
the U.S. Fish and Wildlife
Services and the appropriate state
wildlife agency to develop
measures to prevent, mitigate or
compensate for losses of fish and
wildlife.
The Site includes streams and rivers.
These alternatives may require
discharge of treated water into
Rumford River resulting from
dewatering activities. Consultation
will be undertaken with appropriate
agencies in this case.
During remedial construction, no discharge of treated
water occurred into the Rumford River. Some
treated water was discharged to the ground on-site.
Executive Order 11988;
"Floodplain Management"
(40 CFR Part 6, Appendix
A)
ROD Status: Applicable
5-Yr Status: Applicable
Actions will avoid, whenever
possible, the long- and short-term
impacts associated with the
occupancy and modifications of
floodplains development,
wherever there is a practical
alternative. Promotes the
preservation and restoration of
floodplains so that their natural
and beneficial value can be
realized.
The Site includes areas defined to be
within the 100-year floodplain. These
alternatives all involve installation of
monitoring wells, some include
excavation, and/or consolidation and
cap construction possibly in the
floodplain areas. All practicable
means will be followed to minimize
harm and avoid adverse effects as
much as possible. Actions will be
taken to restore and preserve the
natural and beneficial values of the
floodplain.
This requirement would be applicable to any future
activities, such as installation of monitoring wells, if
determined to be needed within the 100-year
floodplain.
-------
Location-Specific ARARs
Media/Authority
Requirements
Requirement Synopsis
Action to Attain ARAR
Five-Year Review
Federal Regulatory
Requirements
(continued)
Standards for Owners and
Operators Of RCRA
Hazardous Waste
Treatment, Storage, and
Disposal Facilities, 40
C.F.R. Part 264.18(b)k
General Facility Standards,
Subpart B
ROD Status: Applicable
5-Yr Status: NotARAR
Requires that hazardous waste
treatment, storage, or disposal
facilities within a 100-year
floodplain must be designed,
constructed, operated, and
maintained to prevent washout
unless an alternative
demonstration is made to the
Regional Administrator.
The Site includes areas defined to be
within the 100-year floodplain.
Consolidation and capping will be
designed, constructed and maintained
to prevent washout by a 100-year
flood.
The on-site consolidation area that was originally
envisioned in the 2005 ROD for arsenic and
pentachlorophenol contaminated soils from the
Mansfield parcel was not constructed and these soils
were disposed olf-site. A low permeability asphalt
cover was placed across the majority of the Foxboro
parcel.
Endangered Species Act,
16 U.S.C. 1531 etseq.; 50
C.F.R. Parts 17.11-12
ROD Status: Applicable
5-Yr Status: Applicable
Requires site action to be
conducted in a manner that
avoids harming threatened or
endangered species or their
habitat.
Transient bald eagles have been sited.
Work will be conducted to avoid
harming the bald eagle or its habitat.
The requirement remains applicable.
State Regulatory
Requirements
Wetlands Protection Act
(Mass. Gen. Laws ch. 131,
ง40); Wetlands Protection
Regulations (310 CMR
ง10.00)
ROD Status: Applicable
5-Yr Status: Applicable
Sets performance standards for
dredging, filling, altering of
inland wetlands and within 100
feet of a wetland. The
requirement also defines
wetlands based on vegetation
type and requires that effects on
wetlands be mitigated. Resource
areas at the site covered by the
regulations include banks,
bordering vegetated wetlands,
land under bodies of water, land
subject to flooding, riverfront,
and estimated habitats of rare
wildlife. Under this requirement
available alternatives must be
considered that minimize the
extent of adverse impacts and
mitigation including restoration
and/or replication are required.
Wetlands have been identified on the
site and excavation, consolidation and
installation of monitoring wells occur
in or around wetlands and the 100 foot
buffer zone. Because high levels of
contamination exist in or near
wetlands areas, there is no practicable
alternative to excavating or
consolidating in these areas. All
practicable means will be used to
minimize harm to the wetlands
including erosion and sedimentations
controls and stormwater management.
Wetlands disturbed by remedial
activities will be mitigated, restored,
or preserved.
Buffer zone adjacent to the Rumford River was
impacted by the remedial construction and
subsequently restored by grading and replanting with
native species, followed by a one-year monitoring
period that resulted in some additional replanting in
2011. This requirement remains applicable to any
future activities, such as installation of monitoring
wells, if determined to be needed in or around
wetlands.
-------
Location-Specific ARARs
Media/Authority
Requirements
Requirement Synopsis
Action to Attain ARAR
Five-Year Review
Massachusetts Endangered
Species Act (Mass. Gen.
Lawsch. 131 ง40);
Massachusetts Endangered
Species Act Regulations,
Part III: Alteration of
Significant Habitat (321
CMR งง10.30-10.43
ROD Status: Applicable
5-Yr Status: Applicable
The MESA establishes State's
list of threatened and endangered
species and species of special
concern. Habitat of such species
is protected by the regulations
promulgated under the MA
Wetlands Protection Act.
The Site is noted as being near the
habitat of "species of special concern"
(see letter in Appendix B); further
review will be conducted to determine
applicability of this requirement.
Should endangered or threatened
species or species of special concern
be determined to be present at the site,
the substantive requirements of this
regulation will be met.
The requirement remains applicable.
Federal Criteria,
Advisories and
Guidance
Policy on Floodplains and
Wetland Assessments for
CERCLA Actions (EPA
OSWER, 8/8/1985)
ROD Status: TBC
5-Yr Status: TBC
Floodplain and wetlands
assessments must be
incorporated into analysis
conducted during planning of
remedial action; public
participation requirements must
also be met.
Restates requirement that
remedial action may only be
located in wetlands if no
practicable alternative exists.
Potential harm or adverse effects
to wetlands or floodplains must
be minimized and/or mitigated as
required by law/regulation
Floodplain and wetlands assessments
and associated considerations were
incorporated into RI/FS process.
Public participation requirements
were met through Proposed Plan.
Substantive requirements for decision-
making will be met when selecting
and designing remedy.
The substantive requirements of this policy were met.
-------
Action-
Specific ARARs
Media/Authority
Requirements
Requirement Synopsis
Action to be Taken to Attain ARAR
Five-Year Review
Surface Water,
Wetlands
Federal Regulatory
Requirements
Clean Water Act (33
U.S.C. ง1251 etseq.%
Section 404(b)(1)
Guidelines for
Specification of Disposal
Sites for Dredged or Fill
Material (40 CFR Part 230,
231 and 33 CFR Parts 320-
323)
ROD Status: Applicable
5-Yr Status: Applicable
Under this requirement, no
activity that adversely affects a
wetland shall be permitted if a
practicable alternative with lesser
effects is available. If activity
takes place, impacts must be
minimized to the maximum
extent. Controls discharges of
dredged or fill material to protect
aquatic ecosystems.
Wetlands have been identified on the
site coincident with contamination.
Excavation, consolidation, and
installation of monitoring wells will
occur in and around the site wetlands.
These actions will be designed to
minimize adverse effects and to
preserve, mitigate, and restore
disturbed areas.
Buffer zone adjacent to the Rumford River was
impacted by the remedial construction and
subsequently restored by grading and replanting with
native species, followed by a one-year monitoring
period that resulted in some additional replanting in
2011. This requirement remains applicable to any
future activities, such as installation of monitoring
wells, if determined to be needed in or around
wetlands.
Rivers and Harbors Act of
1899 (33 U.S.C. ง401 et
seq.y, (33 CFR Part 320)
ROD Status: Applicable
5-Yr Status: Not ARAR
Protects navigable rivers from
unauthorized discharges or from
unauthorized obstruction or
alteration.
Discharges to the Rumford River
resulting from dewatering activities, if
any, will occur via a piping system
that will not obstruction or alter the
River.
During remedial construction, no discharge of treated
water occurred into the Rumford River. Some
treated water was discharged to the ground on-site.
Clean Water Act, Section
402, National Pollutant
Discharge Elimination
System (NPDES), 33 USC
1342 (4- CFR 122-125,
131)
These standards govern
discharge of water into surface
waters.
Groundwater resulting from
dewatering activities, if any, will be
treated to the required standards
before discharge to the Rumford
River.
During remedial construction, no discharge of treated
water occurred into the Rumford River. Some
treated water was discharged to the ground on-site.
ROD Status: Applicable
5-Yr Status: Not ARAR
State Regulatory
Requirements
Massachusetts Surface
Water Quality Standards -
Vernal Pools, 314 CMR
ง4.06(l)(d)(ll) and 314
CMR 9.08 (variance)
ROD Status: Relevant
and Appropriate
5-Yr Status: Relevant
and Appropriate
Prohibits discharge of dredged or
fill material to a vernal pool
certified by the Massachusetts of
Division of Fisheries and
Wildlife, unless a variance is
granted under 314 CMR
M8.)(ll)-Vernal Pools
Wetland features exist, which,
although not officially classified, may
be characteristic of vernal pools. If
further studies indicate an ecological
risk exists, it will be considered an
overriding public interest to address
the risk. Dredging and/or filling
activities will be conducted to avoid,
minimize and mitigate adverse effects
and restoration/replication will be
conducted.
Vernal pools were not filled as part of the remedial
construction. This requirement remains relevant and
appropriate to any future activities, such as
installation of monitoring wells, if determined to be
needed in or around vernal pools.
-------
Action-Specific ARARs
Media/Authority
Requirements
Requirement Synopsis
Action to be Taken to Attain ARAR
Five-Year Review
Surface Water Quality
Standards (314CMR4.00)
ROD Status: Applicable
5-Yr Status: Applicable
Surface water in the vicinity of
the Site are classified as Class B
and designated as habitat for fish,
other aquatic and wildlife, and
for primary and secondary
contact recreation. The state
surface water minimum criteria
for Class B waters are consistent
with federal AWQC.
Surface water standards will be used
as performance criteria to measure the
effectiveness of the Site remedy at
preventing degradation of surface
water below these standards.
AWQC for pentachlorophenol, arsenic, and
chromium were used in calculating onsite
groundwater performance standards for protection of
surface water. The AWQC for these compounds
have not changed since the ROD. Groundwater
monitoring results are compared to these
performance standards.
401 Water Quality
Certification for Discharge
of Dredged or Fill
Material, 314 CMR 9.00
ROD Status: Applicable
5-Yr Status: Applicable
Under this requirement, no
activity that adversely affects a
wetland shall be permitted if a
practicable alternative with lesser
effects is available. If activity
takes place, adverse impacts
must be minimized. Controls
discharges of dredged or fill
material to protect aquatic
ecosystems.
Wetlands have been identified on the
site coincident with contamination.
Excavation, consolidation, and
installation of monitoring wells will
occur in and around site wetlands.
These actions will be designed to
minimize adverse effects and to
preserve, mitigate, and restore
disturbed areas.
Buffer zone adjacent to the Rumford River was
impacted by the remedial construction and
subsequently restored by grading and replanting with
native species, followed by a one-year monitoring
period that resulted in some additional replanting in
2011. This requirement remains applicable to any
future activities, such as installation of monitoring
wells, if determined to be needed in or around
wetlands.
Massachusetts DEP
Surface Water Discharge
Permit Program (314 CMR
3)
ROD Status: Applicable
5-Yr Status: Not ARAR
These standards govern
discharge of water into surface
waters.
Groundwater resulting from
dewatering activities, if any, will be
treated to the required standards
before discharge to the Rumford
River.
During remedial construction, no discharge of treated
water occurred into the Rumford River. Some
treated water was discharged to the ground on-site.
Groundwater
Federal Regulatory
Requirements
Federal Safe Drinking
Water Act - Maximum
Contaminant Levels
(MCLs) and non-zero
MCLs 40CFR141
ROD Status: Relevant
and Appropriate
5-Yr Status: Relevant
and Appropriate
These levels regulate the
concentration of contaminants in
public drinking water supplies
but may also be considered
appropriate for groundwater
aquifers potentially used for
drinking water.
These standards will be used during
groundwater monitoring to measure
the performance of the remedy to
ensure that groundwater migrating off
the Site does not exceed MCLs and
non-zero MCLs.
These standards remain relevant and appropriate.
The MCLs for pentachlorophenol, arsenic, and
chromium are used as performance standards for
long-term monitoring of groundwater beyond the
compliance boundary.
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Action-Specific ARARs
Media/Authority
Requirements
Requirement Synopsis
Action to be Taken to Attain ARAR
Five-Year Review
Resource Conservation and
Recovery Act (42 U.S.C.
ง6901 etseq.)l40 CFR
264.94 and 95) Subpart F
ROD Status: Relevant
and Appropriate
5-Yr Status: Relevant
and Appropriate
Establishes maximum
concentration limits for RCRA
groundwater monitoring and
response requirements for solid
waste management units.
Standards for 14 toxic
compounds have been adopted as
part of RCRA groundwater
protection standards.
These standards will be used during
groundwater monitoring to measure
the performance of the remedy to
ensure that groundwater migrating off
the Site does not exceed RCRA
groundwater concentration levels for
Site contaminants. Compliance
boundary is south of the Rumford
River and will be established more
specifically during remedial design.
These requirements remain relevant and appropriate.
Arsenic and chromium groundwater monitoring
results for wells located beyond the compliance
boundary should be compared to these standards.
Note that the limit for arsenic (0.05 mg/1) is higher
than the MCL (0.01 mg/1); however, the limit from
chromium (0.05 mg/1) is lower than the MCL (0.1
mg/1). Long-term monitoring results for 2011, 2012,
and 2013 met these standards.
Resource Conservation and
Recovery Act (42 U.S.C.
ง6901 etseq.)l40 CFR
264.100) Subpart F
ROD Status: Relevant
and Appropriate
5-Yr Status: Relevant
and Appropriate
Requires that corrective action be
taken in the event groundwater is
migrating offsite in excess of
RCRA groundwater
concentration levels set out in 40
CFR 264.94.
Corrective action will be taken should
offsite monitoring wells demonstrate
that groundwater is migrating offsite
in excess of RCRA groundwater
concentration levels.
These requirements remain relevant and appropriate.
State Regulatory
Requirements
Massachusetts Ground
Water Quality Standards
(314 CMR ง6.00)
ROD Status: Applicable
5-Yr Status: Not ARAR
Establishes groundwater quality
criteria necessary to sustain the
designated uses, and regulations
necessary to achieve the
designated uses or maintain the
existing groundwater quality.
Groundwater at the site is
classified as Class II and III, non-
potable uses.
These standards will be used during
groundwater monitoring to measure
the performance of the remedy to
ensure that groundwater migrating off
the Site does not exceed MCLs and
non-zero MCLs that are more
stringent that federal standards for
Site contaminants.
These regulations were rescinded after the 2005 ROD
and are no longer applicable. Federal SDWA MCLs
for pentachlorophenol, arsenic, and chromium are
used as performance standards for long-term
monitoring of groundwater beyond the compliance
boundary.
Air
Federal Regulatory
Requirements
National Emission
Standards for Hazardous
Air Pollutants (NESHAPs)
40 CFR Part 61 Subparts
H&I
ROD Status: Relevant
and Appropriate
5-Yr Status: Not ARAR
Regulates air emissions of VOCs
from regulated source categories.
VOC emission levels will be met
during soil treatment processes
through carbon filtering and/or other
engineering controls.
No soil treatment was performed during remedial
construction and no activities are anticipated that
would trigger this requirement.
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Action-Specific ARARs
Media/Authority
Requirements
Requirement Synopsis
Action to be Taken to Attain ARAR
Five-Year Review
RCRA Air Emissions
Standards for Process
Vents (40 CFR Part 264,
Subpart AA)
ROD Status: Relevant
and Appropriate if
threshold concentrations
are met
5-Yr Status: Not ARAR
Contains air pollutant emission
standards applying to solvent
extraction and air stripping
facilities that treat RCRA wastes
with total organics
concentrations of 10 parts per
million by weight or greater.
Treatment components treating wastes
with regulated levels of organic
constituents will be designed to meet
the criteria set forth in this subpart if
threshold levels are met.
No treatment was performed during remedial
construction and no activities are anticipated that
would trigger this requirement.
RCRA Air Emissions
Standards for Equipment
Leaks (40 CFR Part 264,
Subpart BB)
ROD Status: Relevant
and Appropriate if
treatment involves
groundwater with
organics at
concentrations of at least
10% by weight
5-Yr Status: Not ARAR
Sets emission standards for
equipment that contains or
contacts RCRA wastes with
organic concentrations of at least
10% by weight.
Treatment components treating wastes
with regulated levels of VOCs will be
designed to meet the criteria set forth
in this subpart if threshold levels are
met.
No treatment was performed during remedial
construction and no activities are anticipated that
would trigger this requirement.
RCRA Air Emissions
Standards for Tanks and
containers (40 CFR Part
264, Subpart CC)
ROD Status: Relevant
and Appropriate if
threshold levels are met
5-Yr Status: Not ARAR
Requires specific organic
emissions controls on tanks and
containers having VOC
concentrations equal to or greater
than 500 parts per million by
weight.
Treatment facility components
treating wastes with regulated levels
of VOCs will be designed to meet the
criteria set forth in this subpart if
threshold levels are met.
No treatment was performed during remedial
construction and no activities are anticipated that
would trigger this requirement.
State Regulatory
Requirements
Ambient Air Quality
Standards (310 CMR 6.00)
ROD Status: Applicable
5-Yr Status: Not ARAR
Sets primary and secondary
standards for emissions of Sulfur
Oxides, particulate matter, CO,
ozone, Nitrogen Dioxide, and
Lead.
Remedies will be designed,
constructed, and operated in
accordance with these rules. No air
emissions from remedial treatment
will cause ambient air quality
standards to be exceeded. Dust
standards will be complied with
during any and all excavation of
materials at the Site.
No treatment was performed during remedial
construction. A Perimeter Air Monitoring and
Emissions Control Plan was developed and air
monitoring for fugitive dust, VOCs, and hydrogen
sulfide was performed during active phases of the
remedial construction. No further land disturbing
activities are anticipated, thus these requirements are
no longer ARAR unless further land disturbing
activities are conducted.
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Action-Specific ARARs
Media/Authority
Requirements
Requirement Synopsis
Action to be Taken to Attain ARAR
Five-Year Review
Massachusetts DEP Air
Pollution Control
Regulations (310 CMR
7.00)
ROD Status: Applicable
5-Yr Status: Not ARAR
Regulates dust, particulates and
fugitive emissions. Establishes
emissions limitations for various
processes and regions within the
state.
Excavation and treatment processes
will be designed, constructed, and
operated in accordance with these
rules. Air monitoring will be
conducted to ensure levels are met.
No treatment was performed during remedial
construction. A Perimeter Air Monitoring and
Emissions Control Plan was developed and air
monitoring for fugitive dust, VOCs, and hydrogen
sulfide was performed during active phases of the
remedial construction. No further land disturbing
activities are anticipated, thus these requirements are
no longer ARAR unless further land disturbing
activities are conducted.
Massachusetts
Criteria, Advisories,
and Guidance
Massachusetts Threshold
Effects Exposure Levels
(TELs) and Allowable
Ambient Limits (AALs)
for Air (December 1995)
ROD Status: To Be
Considered
5-Yr Status: Not ARAR
Establishes exposure
concentrations for air
contaminants developed and
recommended by the Office of
Research and Standards to
protect public health.
Evaluation of air emissions will
consider AALs and TELs.
A Perimeter Air Monitoring and Emissions Control
Plan was developed and air monitoring for fugitive
dust, VOCs, and hydrogen sulfide was performed
during active phases of the remedial construction.
No further land disturbing activities are anticipated,
thus these guidelines are no longer ARAR unless
further land disturbing activities are conducted.
Soil
Federal Regulatory
Requirements
RCRA program has
been delegated to
Massachusetts;
therefore, only State
references appear as
ARARs unless
particular provision
not contained in
State program.
State Regulatory
Requirements
RCRA Hazardous Waste
Management -
Identification and Listing
of Hazardous Waste (310
CMR 30.100)
ROD Status: Applicable
5-Yr Status: Not ARAR
Establishes standards for
identifying and listing hazardous
waste.
Testing as appropriate will assess
whether hazardous wastes are present
in excavated soil, sediments (if any)
and groundwater generated during
remedial activities.
This ARAR has been met. Pre-excavation waste
characterization was performed on the contaminated
soils to be disposed off-site and the soil was
determined to be non-characteristic under RCRA.
Some wastes generated during remedial construction,
including liquid and solid contents of certain USTs,
were characterized and disposed as RCRA
characteristic waste.
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Action-Specific ARARs
Media/Authority
Requirements
Requirement Synopsis
Action to be Taken to Attain ARAR
Five-Year Review
Hazardous Waste
Management -
Requirements for
Generators of Hazardous
Waste (310 CMR 30.300)
ROD Status: Applicable
to any action that
generates hazardous
waste
5-Yr Status: Not ARAR
Generator requirements outline
waste characterization,
management of containers,
packaging, labeling, and
manifesting. Generator
requirements apply to
contaminated substances meeting
the definition of hazardous under
310 CMR 100.
Waste generated during excavation,
treatment processes and well drilling
that are characteristic waste will be
managed in accordance with the
substantive requirements of this
regulation.
This ARAR has been met. RCRA characteristic
wastes generated during remedial construction were
characterized and managed in accordance with these
requirements.
Hazardous Waste
Management - Landfill
Closure and Post Closure
Care (310 CMR,
30.633(1 Xa-d), 2(a), (d),
(e))
ROD Status: Relevant
and Appropriate
5-Yr Status: Relevant
and Appropriate
Establishes performance
standards for low permeability
covers and for post closure care
and for groundwater monitoring.
Consolidated waste will be covered
on-site with a low permeability cover
that meets these standards. Post-
closure care of cover will meet these
standards.
This ARAR remains relevant and appropriate and is
being complied with. An asphalt parking lot was
constructed on the Foxboro parcel to provide a low
permeability cover over contaminated soils. Long-
term inspection and maintenance of the asphalt cover
as well as long-term groundwater monitoring are
being conducted in accordance with the O&M
Manual (EPA Region 1, September 2011).
Hazardous Waste
Management - Closure
and Post Closure (310
CMR 30.582, 30.585,
30.592)
ROD Status: Relevant
and Appropriate
5-Yr Status: Relevant
and Appropriate
Establishes performance
standards for closure and post
closure care and groundwater
monitoring
All equipment, structures, and soil
will be properly decontaminated and
disposed of during the remedial
action. Post closure care will meet
substantive standards as determined
by EPA.
This ARAR remains relevant and appropriate. Long-
term inspection and maintenance of the asphalt cover
as well as long-term groundwater monitoring are
being conducted in accordance with the O&M
Manual (EPA Region 1, September 2011).
Hazardous Waste
Management - General
Requirements for ignitable,
reactive, or incompatible
waste (310 CMR 30.560)
ROD Status: Applicable
5-Yr Status: Not ARAR
General requirement for handling
hazardous waste
Hazardous wastes will be handled in
accordance with these requirements.
No ignitable, reactive, or incompatible wastes were
encountered during remedial construction.
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Action-Specific ARARs
Media/Authority
Requirements
Requirement Synopsis
Action to be Taken to Attain ARAR
Five-Year Review
Hazardous Waste
Management - Tanks (310
CMR 30.343)
ROD Status: Applicable
5-Yr Status: Not ARAR
Establishes management
procedures tanks uses to store
hazardous waste.
Any hazardous waste stored in
containers will meet substantive
requirements of this subpart, including
condition and management of
containers.
Hazardous wastes were not stored in tanks during
remedial construction.
Hazardous Waste
Management - Containers
(310 CMR 30.342)
ROD Status: Applicable
5-Yr Status: Not ARAR
Specifies conditions under which
hazardous waste may be stored in
containers.
Any hazardous waste stored in
containers will meet substantive
requirements of this subpart, including
condition and management of
containers.
Hazardous wastes were not stored in containers
during remedial construction.
Federal Criteria,
Advisories and
Guidance
Revised Alternative Cap
Design Guidance Proposed
for Unlined, Hazardous
Waste Landfills in the EPA
Region 1 (EPA OSRR
2/5/01).
ROD Status: TBC
5-Yr Status: Not TBC
USEPA Technical
Guidance Document:
Final Covers on Hazardous
Waste Landfills and
Surface Impoundments
(EPA/530-SW-89-047)
ROD Status: TBC
5-Yr Status: Not TBC
Provides guidance for landfill
cap design for unlined, hazardous
waste landfills at Superfund
landfill sites in EPA Region 1.
Presents technical specifications
for the design of multi-barrier
covers for landfills at which
hazardous wastes were disposed.
Guidance will be considered when
designing low permeability cover for
consolidated material on-site.
Technical specifications in guidance
will be considered when designing
low permeability cover for
consolidated material on-site.
These guidance documents would have been
considered during design the asphalt cover on the
Foxboro parcel, but are no longer to be considered
for the on-going operation, maintenance, and
monitoring activities.
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