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Baird & McGuire Superfund SiteHolbrook, Massachusetts
FINALFIVE-YEAR REVIEW
FOR THE BAIRD & MCGUIRE SUPERFUND SITE
September 1999
Prepared For:U.S. Environmental Protection Agency
Region I, Boston, Massachusetts
Prepared by:Metcalf & Eddy, Inc.WA #034-FRFE-0131
FINAL
EPA Contract No. 68-W6-0042EPA Work Assignment No. 034-FRFE-0131
EPA Project Officer: Diana KingEPA Remedial Project Manager: Melissa Taylor
FIVE YEAR REVIEW FOR THEBAIRD AND McGUIRE SUPERFUND SITE
September 1999
Metcalf& Eddy, Inc.30 Harvard Mill SquareWakefield, MA 01880
TABLE OF CONTENTS
SECTION 1.0 - INTRODUCTION......................................................................................... 1-11.1 BACKGROUND.............................................................................................................. 1-2
1.1.1 Purpose of Report..................................................................................................... 1-21.1.2 Site Background........................................................................................................ 1-31.1.3 Summary of Remedy Stipulated by Records Of Decision............................................ 1-41.1.4 Report Organization.................................................................................................. 1-6
1.2 REMEDIAL OBJECTIVES............................................................................................. 1-6SECTION 2.0 - PRESENT SITE CONDITIONS ................................................................... 2-12.1 GROUNDWATER REMEDY (OU-1)............................................................................. 2-12.1.1 Components of the Remedy........................................................................................... 2-1
2.1.2 System Operation and Equipment Modifications........................................................ 2-32.1.3 System Performance.................................................................................................. 2-52.1.4 Data Evaluation......................................................................................................... 2-7
2.2 SOILS REMEDY (OU-2) ...............................................................................................2-102.2.1 Components of the Remedy ......................................................................................2-112.2.2 DataEvaluation........................................................................................................2-15
2.3 SEDIMENT REMEDY (OU-3) ......................................................................................2-162.3.1 Components of the Remedy......................................................................................2-162.3.2 Performance.............................................................................................................2-172.3.3 Long-Term Monitoring.............................................................................................2-18
2.4 REPLACEMENT OF LOST DEMAND (OU-4).............................................................2-192.4.1 Components of the Remedy......................................................................................2-192.4.2 Performance.............................................................................................................2-19
SECTION 3.0 - SITE VISIT................................................................................................... 3-13.1 REGRADED AND SEEDED PORTIONS OF THE SITE............................................... 3-13.2 RESTORED WETLANDS............................................................................................... 3-13.3 COCHATO RIVER ......................................................................................................... 3-23.4 EXTRACTION WELLS AND RECHARGE BASINS..................................................... 3-23.5 EXTRACTION SYSTEM CONTROL BUILDING (ESCB)............................................ 3-23.6 GROUNDWATER TREATMENT FACILITY (GWTF)................................................. 3-3SECTION 4.0 - ARARS REVIEW......................................................................................... 4-14.1 STANDARDS REVIEW APPROACH............................................................................ 4-14.2 ARARS REVIEW-OPERABLE UNITS 1 & 2.............................................................. 4-24.3 ARARS REVIEW - OPERABLE UNIT 3....................................................................... 4-44.4 ARARS REVIEW-OPERABLE UNIT 4....................................................................... 4-5SECTION 5.0 - COMPLIANCE STATUS ............................................................................. 5-15.1 OU-1 - GROUNDWATER .............................................................................................. 5-15.2 OU-2-SOIL.................................................................................................................... 5-15.3 OU-3-SEDIMENT......................................................................................................... 5-25.4 OU-4 - LOST DEMAND ................................................................................................ 5-2SECTION 6.0-GENERAL DISCUSSION OF RISK............................................................. 6-16.1 GROUNDWATER (OU-1).............................................................................................. 6-1
6.2 SOILS.............................................................................................................................. 6-16.2.1 Backfilled Ash...........................................................................................................6-26.2.2 Outlying Areas........................................................................................................... 6-26.2.3 Soils Below the Bottom Depth of Excavation............................................................ 6-2
6.3 SEDIMENTS (OU-3)......................................................................................................6-36.4 REPLACEMENT OF LOST DEMAND (OU-4)..............................................................6-3SECTION 7.0 - EVALUATION OF INSTITUTIONAL CONTROL...................................... 7-1SECTION 8.0 - RECOMMENDATIONS............................................................................... 8-18.1 TECHNOLOGY RECOMMENDATIONS ...................................................................... 8-1
8.1.1 Groundwater(OU-l)................................................................................................. 8-18.1.2 Soils (OU-2)..............................................................................................................8-38.1.3 Sediments (OU-3)......................................................................................................8-48.1.4 Replacement of Lost Demand (OU-4)........................................................................ 8-4
8.2 STATEMENT ON PROTECTIVENESS......................................................................... 8-58.2.1 OU-1 - Groundwater................................................................................................. 8-58.2.2 OU-2-Soils.............................................................................................................. 8-68.2.3 OU-3 - Sediments..................................................................................................... 8-68.2.4 OU-4 - Lost Demand................................................................................................ 8-6
8.3 NEXT REVIEW............................................................................................................... 8-7REFERENCES.......................................................................................................................R-l
FIGURES
Figure 1-1. Location of Baird & McGuire Superfund Site....................................................... F-lFigure 1-2. Baird & McGuire Site Features ............................................................................ F-2
Figure 2-1. Baird & McGuire Well Locations......................................................................... F-3Figure 2-2. Estimated Extent of LNAPL in Groundwater....................................................... F-4Figure 2-3 Soil Excavation and Backfill Limits....................................................................... F-5Figure 2-4. Cochato River Excavation and Monitoring Area................................................... F-6
TABLES
Table 2-1. Monthly Average Effluent Levels...........................................................................T-lTable 2-2. Summary of Groundwater Treatment Facility Operation and Performance ............. T-3Table 2-3. Total VOCAnd SVOC Concentrations Over Time................................................. T-4
Table 4-1. Potential Chemical-Specific ARARS and Criteria, Advisories, and Guidance.......... T-8Table 4-2. Numerical Standards For Baird & Mcguire Groundwater.....................................T-12Table 4-3. Potential Location-Specific ARARS and Criteria, Advisories, and Guidance........ T-15Table 4-4. Potential Action-Specific ARARS for Operable Units 1 And 2.............................T-21Table 4-5. Potential Chemical-Specific Criteria, Advisories, and Guidance For Ou-3............ T-28Table 4-6. Numerical Chemical-Specific ARARS Criteria, Advisories, and Guidance............ T-32Table 4-7. Potential Action-Specific ARARS For Ou-3 ........................................................ T-34
Appendix A 1997 and 1998 Plume Maps
SECTION 1.0
INTRODUCTION
This document is a comprehensive and interpretive report on the five-year review conducted for the
Baird & McGuire Superfund Site (the Site) in Holbrook, Massachusetts, for U.S. Environmental
Protection Agency (EPA) Region I. This work was conducted by Metcalf & Eddy (M&E) under the
Remedial Action Contract Services (RACS) contract. The U.S. EPA is the lead agency and decision-
maker for the Baird & McGuire Site.
Although not subject to the requirements of the following statutes, EPA Region I conducted this
review in compliance with CERCLA section 121(c), NCP section 300.400(f)(4)(ii), and OSWER
Directives 9355.7-02 (May 23, 1991), and 9355.7-02A (August 1994). Since the remedial action for
this site was selected on September 30, 1986, before the statutory date of October 17, 1986,
compliance with the statute is not required. Other than completing the five-year review within the
statutory timeframe of five years from the initiation of the remedial action, the five-year review was
conducted in accordance with all statutory requirements for remedies selected after October 17, 1986.
The actual first five-year review was due in 1996; all subsequent five-year reviews follow from that
date. The next five-year review will be due by December 2001.
EPA guidance further stipulates that sites subject to five-year reviews with multiple operable unitsshould conduct a five-year review for the entire Site, and not separate five-year reviews for each
remedy or operable unit. The five-year review is triggered by the first operable unit giving rise to afive-year review. This five-year review report for the Baird & McGuire Site incorporates all operable
units, as directed by the guidance (U.S. EPA, 1994).
In order to conduct the first five-year review at this Site, M&E reviewed existing Site documents and
other materials that are the basis for the source control and groundwater treatment, includingdocuments that outline the objectives, cleanup goals, and implementation of the remedial action.
These documents include:
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Record of Decision (ROD) for OU-1 and OU-2, September 30, 1986 (U.S. EPA,1986).
Record of Decision (ROD) for OU-3, October 9, 1989 (U.S. EPA, 1989).
Record of Decision (ROD) for OU-4, September 27, 1990 (U.S. EPA, 1990).
Evaluation of Potential Future Reuse Opportunities for the Baird & McGuire Site(M&E, June 5, 1998).
Nine months of Monthly Operations Reports (April 1998 - December 1998) for thegroundwater treatment system (M&E Services).
Performance evaluations and yearly plume evaluations performed by M&E, Inc.(M&E, July 1998, January 1998, February 1999).
Remedial Action Report for OU-3 (USAGE 1996).
Results of Third Year of Long-Term Monitoring of Sediments and Soils (USAGE1998).
Potential for Advection of Volatile Organic Compounds in Groundwater to theCochato River, Baird & McGuire Superfund Site. USGS Draft Report. March andApril 1998.
1.1 BACKGROUND
The five-year review was undertaken to review remedial actions completed at the Site to date, to
ensure that the remedial actions remain protective of human health and the environment. This reviewis required by federal statute for any Site remedy which results in hazardous substances remaining on-
site above a level that would allow for unlimited, unrestricted use (CERCLA §121(c) and 40 CFR§300.430(f)(4)(ii) of the National Oil and Hazardous Substances Contingency Plan).
1.1.1 Purpose of Report
The purpose of the five-year review is to confirm that the remedy as described in the Records OfDecision (RODs) and/or remedial design remains protective of human health and the environment.This report presents the results of a "Type la" five-year review, as determined by U.S. EPA Region
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I and in accordance with OSWER Directive 9355.7-02A "Structure and Components of Five Year
Reviews." This review includes elements of a Type la review (document reviews, regulatory review,
Site inspection, ARARs review, statement of protectiveness and recommendations). The Type la
review is similar in content to the Level I five-year review described in earlier EPA guidance
(OSWER Directive 9355.7-02).
1.1.2 Site Background
The Baird & McGuire Superfund Site is located on South Street in Holbrook, MA, as show in
Figure 1-1. The ROD defines the Site as the area within the EPA security fence constructed in July
1985. According to the FS, this fence encompasses all known areas of soil contamination related to
Baird & McGuire (GHR, 1986). The Site boundary and coincident fence line are shown onFigure 1-2, based on a Site survey conducted in May 1988. The Site designated on Figure 1-2 has
been determined to consist of approximately 32.5 acres.1 For the purpose of increased security andaccess control measures during remedial actions, additional fencing was constructed in some areas
beyond the Site boundary. This includes fencing around the groundwater treatment plant and
recharge basins, and fencing beyond the southern Site boundary. The approximate location of thisadditional fencing is also shown on Figure 1-2, based on visual observations.
As illustrated on Figure 1-2, the Site is not limited to land within the Baird & McGuire property.
Historically, Lots 130, 130-1 and 130-2 have had Baird & McGuire ownership. These lots consist
of 9.33 acres, of which approximately 8 acres are within the Site boundaries. The remaining 24.5acres of the Site consist of portions of five privately owned lots and two lots jointly owned by the
towns of Holbrook and Randolph. In addition, four privately owned lots located west of the CochatoRiver (Lots 6, 12-2 and 12-3) have restricted access to the river due to the presence of the security
fence.
1 Some paragraphs of the ROD and other project documents have stated that the site consists of approximately 20 acres. The reference to a 20-acre site originated in the RI Report (GHR, 1985) which preceded construction of the security fence that subsequently defined the site limits.
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Figure 1-2 also shows significant ecological Site features, including the Cochato River, the unnamed
brook, the 100-year floodplain, and wetland areas. Based on a wetland boundary delineation
conducted during RI investigations, wetlands occupied approximately 44 percent of the Site. In
addition, 66 percent of the Site was determined to be within the 100-year floodplain (GHR, 1986).2
1.1.3 Summary of Remedy Stipulated by Records Of Decision
Selected remedial actions for the Site were developed in accordance with CERCLA as amended by
the Superfund Amendments and Reauthorization Act (SARA), and, to the extent practicable, in
accordance with the NCP at 40 CFR Part 300.
EPA issued three RODs for the Site, defining four operable units and describing selected remedialalternatives. The first ROD, issued in September 1986, specified groundwater extraction and
treatment at an on-site treatment plant (OU-1) and soil excavation and treatment at an on-site
incinerator (OU-2). The second ROD, issued in September 1989, addressed contamination in theCochato River sediments (OU-3). EPA issued the final ROD in 1990, which called for reopening the
Donna Road well field to replace the lost demand resulting from contamination of the South Street
wellfield (OU-4). The selected remedies being evaluated for protectiveness are:
• OU-1: Groundwater Extraction and Treatment. The RI/FS (GHR, 1985 and GHR,1986)
identified and described the presence of a groundwater contamination plume, originating from the
Baird & McGuire property and extending beyond the Cochato River. The 1986 ROD specifiedgroundwater extraction and on-site treatment to address this contaminatioa The current systemconsists of six extraction wells that pump contaminated groundwater to a groundwater treatmentfacility, and four recharge basins for discharge of treated groundwater back to the aquifer.
• OU-2: Soil Excavation and Treatment Based on the nature and extent of soil contamination
documented in the RI/FS, the 1986 ROD specified the excavation of soil from "hot areas" with
2 The RI Addendum Report (GHR, 1986) predicts a 100-year flood elevation of 126.9 feet, as compared to the 128-foot 100-year floodelevation shown on the Holbrook Flood Insurance Rate Map. For the purpose of this report, the 100-year flood elevation of 128 feet is used, since thiselevation corresponds to the designation of the Flood Plain Protection District on the Town Zoning Map.
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subsequent treatment in an on-site incinerator. The hot areas were delineated in the ROD based
on contamination profiles developed in the RI Addendum (GHR, 1986). The limits of excavation
were established so that contaminant concentrations outside of the hot areas were one to two
orders of magnitude lower than the concentrations inside the hot areas. Also considered in
establishing the limits of excavation was the presence of wetlands and the extent of contamination
in those wetlands, with the intent of minimizing disruption to wetlands. The ROD notes that
although this approach results in residual soil contamination, future health risk for a trespasser
scenario would be within an acceptable range.
• OU-3: Sediment Excavation and Treatment. The Baird & McGuire Site includes a portion
of the Cochato River. This area begins at approximately the center of the Site fence along the
Cochato River and extends north to Union Street. Cochato River sediment contamination was
addressed by the September 1989 ROD for OU-3. The ROD specified excavation and incinerationof approximately 1,500 cubic yards of contaminated sediments for protection of public health and
the environment. Sediments were to be excavated on an average of six inches from approximately
the center of the fenced Site area downstream to Union Street. Sediments were to be transportedto the on-site treatment facility and subsequently placed as backfill on the Site.
The ROD also required erosion control, wetlands restoration, placement of organic fill in the
excavated areas of the river in the vicinity of the groundwater plume and long-term monitoring
of downstream portions of the River where sediments were not excavated.
To minimize the disruption of wetlands, sediments were not to be removed from areas of the river
where contaminant concentrations were low, calculated risks were low, and no impacts were
observed. In accordance with the ROD for OU-3, long term monitoring is to be conducted toevaluate remaining contaminant levels and their behavior over time (USEPA, 1989).
• OU-4: Replacement of Lost Demand from Contamination of South Street Wellfield. The
South Street wellfield, which formerly was part of the municipal water supply for Holbrook, iswithin 1,500 feet of the Baird & McGuire property. The last operating well was shut down in
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1982 due to organic contamination. The ROD for OU-4 was issued to address an alternate water
supply/replacement of lost demand which resulted from the contamination and subsequent
shutdown of the South Street wells. The reactivation of the Donna Road aquifer was selected as
the alternate water supply.
1.1.4 Report Organization
This document is organized for a Level I review in accordance with EPA protocols. Section 1.0
provides an introduction to this five-year review, Site background information, descriptions of the
ROD-specified remedies and remedial objectives. Section 2.0 summarizes present Site conditions and
describe the status of the remedy for each operable unit based on document review and the Site visit.
Observations of the Site visit are described in Section 3.0. Components of each remedy are described
and a review of the performance of each remedy is also presented. Section 4.0 describes the results
of a review of applicable or relevant and appropriate requirements (ARARs). Section 5.0 presents
a discuss of compliance status of site actions based on the ARARs review and the evaluation of
performance. Section 6.0 presents a general discussion of past risk evaluations performed for the Site.Section 7.0 describes non-engineering controls placed on the Site for protectiveness, and discussestheir efficiency. Section 8.0 provides recommendations based on this Five-Year Review. It providesdiscussion of whether current technologies are achieving performance standards and providesrecommendations for continued operation. It also presents a discussion of protectiveness of theremedy based on ARARs review and performance of the remedial actions. Lastly, Section 8.0presents a discussion of the next review.
1.2 REMEDIAL OB JECTIVES
Under its legal authorities, EPA's primary responsibility at Superfund sites is to undertake remedial
actions that are protective of human health and the environment. In addition, Section 121 ofCERCLA establishes several other statutory requirements and preferences, including: a requirement
that EPA's remedial action, when complete, must comply with all federal and more stringent state
environmental standards, requirements, criteria or limitations, unless a waiver is invoked; a
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requirement that EPA select a remedial action that is cost-effective and that utilizes permanent
solutions and alternative treatment technologies or resource recovery technologies to the maximum
extent practicable; and a preference for remedies in which treatment permanently and significantly
reduces the volume, toxicity or mobility of the hazardous substances. Section 121 also provides that
if EPA selects a remedy not compliant with the above preferences, EPA is to publish an explanation
as to why a remedial action involving such reduction was not selected. Response alternatives for the
Baird & McGuire Site were developed to be consistent with these Congressional mandates.
EPA has established a three-tier approach to conducting five-year reviews, the most basic of which
provides a minimum protectiveness evaluation (Level I Review). This report documents a Type la
five-year review for the Baird & McGuire Site in Holbrook, Massachusetts, to confirm that the
remedial action, as presented in the Records of Decision (OU-1 & OU-2, September 30,1986; OU-3,October 9, 1989; OU-4, September 27, 1990) remains protective of human health and the
environment.
This five-year review reassesses ARARs for substances identified as chemicals of concern in the
RODs, and considers whether ARARs for substances not addressed under contaminants of concern
have been changed such that the remedy is no longer protective. The review also considers pendingor actual changes in zoning or land uses that could undermine the remedy. In addition, the review
considers the need for institutional controls at and near the Site. A five-year review is hereinperformed for all operable units, using the information available, in accordance with five-year review
guidance (U.S. EPA, 1994).
Remedial action objectives being evaluated for each operable unit as described in the RODs are as
reiterated below.
1.2.1 OU-1: The remedial action objectives to address groundwater contamination at the Baird &
McGuire Site are as follows:
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• Remediate the contaminated aquifer within a reasonable time to prevent present or futureimpacts to groundwater drinking water supplies;
• Protect surface waters from future contaminant migration; and
• Minimize long-term management and/or maintenance requirements.
1.2.2 OU-2: The remedial action objectives for addressing contaminated soils at the Baird &
McGuire Site are as follows:
• Minimize the risk for the human population of direct contact with contaminatedsoils/sediments;
• Protect surface waters from future contaminant migration; and
• Minimize long-term management and/or maintenance requirements.
1.2.3 OU-3: The remedy selected in 1989 was developed to satisfy the following remedial
objectives, which will be used to measure the success of the remedy:
• Reduce human exposure to arsenic, DDT, polycyclic aromatic hydrocarbons (PAHs), andchlordane in sediment by excavating to an average depth of six (6) inches and by achievingthe following levels of contaminants: 250 ppm for arsenic; 19 ppm for DDT; 5 ppm forchlordane; and 22 ppm for total PAHs. These concentrations correspond to a 1 x 10"5 to1 x 10"6 excess cancer risk level; and
• Reduce environmental exposure to the same four contaminants of concern to concentrationscorresponding to the mean sediment quality criteria (SQC) (EPA, 1988) in the river bed, andto the upper bound SQC in the wetland area north of Ice Pond.
Human health target levels for the four contaminants of concern are presented below, and site-specifictarget levels for ecological risk were set at sediment quality criterion for specific target locations (see
Table 5 of the ROD, 1989). An organic layer of soil intended to act as a filter (to attenuate
groundwater discharge) was placed in the vicinity of the groundwater plume where achieving SQCs
would be difficult. Sediment sampling conducted in December of 1998 in the area of the groundwater
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plume where the organic fill material was placed did not reveal any detectable levels of the
contaminants of concern in the sediment.
OU-3 ROD-SPECIFIED HUMAN HEALTH TARGET LEVELS FOR SEDIMENTCONTAMINANTS OF CONCERN
Compound
Arsenic
PAHsDOT
Chlordane
Target Level1(1(T5 Risk) (ppm)
2500
22
190
50
Target Level1CIO'6 Risk) (ppm)
250
2.2
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5.01. These concentrations correspond to the indicated target risk level based on exposure to a single compound and do not
assume concurrent exposure with other contaminants.
While the target levels derived for protection of human health were based on a 1 x 10~5 excess cancer
risk level, the ROD expected remediation to achieve a greater level of protection for three of the four
contaminants of concern. For the contaminants arsenic, DOT and metabolites, and chlordane, a
1 x 10"6 excess cancer risk level was anticipated to be achieved by the remediation. The contaminant
of concern that would achieve only the 1 x 10"5 level is total PAHs, which are found widely
throughout the Cochato River drainage basin. Sediment was remediated to this human health level;the overbank was remediated to 1.5 times this level. It is expected that natural degradative,
depositional, and dispersal processes would gradually reduce contaminant concentrations in theremaining downstream sediment without engineering measures being taken. Full evaluation of this
remedy as part of this five-year review would be premature due to insufficient time for decreases in
sediment and fish contaminant concentrations to occur. Yearly monitoring of sediments downstream
of the Site, along with fish data collected on a five-year basis, will be evaluated when the next five-
year review is due for OU-3 to determine if the selected remedy remains protective of human health
and the environment.
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1.2.4 OU-4: Replacement of Lost Demand from Contamination of South Street Wellfield.
Based on preliminary information such as constraints of the present water system and known available
water sources, a remedial action objective was developed to aid in the development and screening of
alternatives. The response objective for OU-4 is:
To identify a candidate water source that will replace the 0.31 million gallons per day (mgd)Lost Demand in an environmentally sound, cost-effective manner without placing additionalstress on the Great Pond Reservoir system or existing water treatment facilities.
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SECTION 2.0PRESENT SITE CONDITIONS
This section summarizes the remedies and current conditions for each Operable Unit at the Baird and
McGuire Superfund Site in terms of design, implementation and performance. In general, the
groundwater remedy (OU-1) is ongoing. The soil (OU-2) and sediment (OU-3) remedies have been
completed and are being monitored. The remedy for the replacement of lost demand from
contamination of the South Street well field (OU-4) has not been implemented.
2.1 GROUNDWATER REMEDY (OU-1)
The groundwater remedy at the Site is ongoing. A groundwater treatment facility (GWTF) and
extraction/recharge system were built in 1991 and remain in operation, with modifications. The
purpose of the system is to contain and remove the plume of contaminated groundwater. Whitmanand Howard operated the system for one year (under subcontract to Barletta). The O&M contract
was then awarded to M&E Services/PSG who has operated the GWTF since 1993.
2.1.1 Components of the Remedy
The three main components of the groundwater remedy are extraction, treatment, and recharge.
Groundwater Extraction. The groundwater extraction system consists of six extraction welb
(EW-2 through EW-7) each operating at a flow rate of between 10 and 35 gpm. The well locations
are shown on Figure 2-1. The system was originally designed to pump at a maximum total rate of200 gpm. The wells pump the groundwater via separate pipes to an extraction well control building
located south of the extraction system. Within the building, the water converges to a single header
pipe, which conveys the water to the GWTF. All extraction system controls (e.g., valves, flow meters,
electrical switches) are housed within the extraction system control building. The wells are operated
remotely through use of a programmable logic controller (PLC) located at the GWTF.
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Figure 2-1 also shows the locations of the numerous monitoring wells that exist at the Site. At many
of the monitored locations, multiple wells have been constructed. These well clusters allow water
levels and water quality to be determined at different depths in the stratified drift deposits, in the till
deposits and weathered bedrock zone, and in the underlying fractured bedrock. Data gathered from
the monitoring wells are used both to determine the area of capture of the extraction well system and
to monitor the improvements in water quality resulting from groundwater extraction and treatment.
Groundwater Treatment Facility. The GWTF is located off of South Street as shown on
Figure 2-1. It consists of the following unit operations housed within a single building:
• Metals pretreatment consisting of treatment of the influent stream by hydroxideprecipitation and ferric chloride to remove heavy metals and arsenic, and the addition ofpolymer to enhance iron removal.
• Biological treatment by activated sludge process for removing certain volatile andsemivolatile organic compounds from groundwater.
• Granular activated carbon adsorption for removing additional organics not removed in thebiological treatment process.
• Filtration for removing suspended solids carried over from the biological process.
• Sludge dewatering used for decreasing the water content of the metals hydroxide sludge.
• Metals hydroxide sludge disposal in a RCRA hazardous waste landfill.
• Vapor phase carbon adsorption for treating off-gases from various tanks.
The design capacity of the GWTF is 200 gpm. The target range of flow for successful plumecontainment, as determined by groundwater modeling (M&E, 1995) is 150 to 200 gpm. An on-sitelaboratory is located at the Site for analysis of process flow and groundwater monitoring samples. TheGWTF operations is staffed 24-hours a day.
Groundwater Recharge System. Treated water from the GWTF is recharged back to thegroundwater through four infiltration basins, each with dimensions of 100' by 100' (see Figure 2-1).
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Water is discharged to one basin at a time while the other three basins remain inactive. Discharge is
rotated to other basins on a weekly basis, to prevent overuse of any one basin and to allow
maintenance of a particular basin if recharge capacity is diminished.
2.1.2 System Operation and Equipment Modifications
There have been several modifications/refinements made since construction of the groundwater
remedy. Most of the modifications were made to enhance and optimize operations at the GWTF and
to optimize groundwater extraction and plume containment. The major modifications are listed
below:
Additional Extraction Wells. Since construction of the system, one extraction well has beendecommissioned and two extraction wells have been added to the system. EW-1 wasdecommissioned due to its low yield and minimal contaminant removal performance. It was replaced
with EW-8, which was placed on-line in the spring of 1999 and is operating at a rate of between 18gpm and 25 gpm. EW-7 was also added to the system to enhance plume containment efforts near the
Cochato River. EW-7 was placed on line in spring of 1998 and is currently operating at a rate of
approximately 30 gpm. There are currently seven operational extraction wells (EW-2 through EW-8).
Extraction System Control Building (ESCB). This new building was constructed in early 1998 andhouses the extraction well controls. The controls were originally located at the well heads within
concrete vaults; electrical controls were originally within aboveground electrical panels at each well.
All controls, including control valves, flow meters, electrical panels and sample taps are now centrallylocated with the ESCB. Building construction was completed in early 1998.
Extraction Well Piping. The original extraction system was designed so that discharge piping from
each extraction well fed into a common header pipe leading to the GWTF. Individual extraction well
piping was subsequently installed; groundwater is now fed to the extraction system control buildingwhere it is conveyed to the GWTF.
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LNAPL Remediation System. A LNAPL (light non-aqueous phase liquid) remediation system was
designed to remove pure-phase contaminants floating on the water table. From yearly contaminant
plume evaluations, LNAPLs were determined to be a major source of groundwater contamination.
The LNAPL at this site contains a mixture of various chemicals in pure phase (undissolved) that are
lighter than water and therefore float on the water table. The LNAPL chemicals slowly dissolve into
groundwater causing a continuing source of groundwater contaminants. The LNAPL remediation
system was designed to remove pure product floating on the water table by the use of skimmer pumps
and total fluids recovery pumps in two existing extraction wells (EW-3 and EW-6) and one new
extraction well (EW-8). The discharges from these pumps were designed to flow through an oil-
water separator to separate the oil phase from the water phase. The recovered LNAPL will be
disposed of off-site and the water will be recirculated though the wells. A scaled-down version of the
system consisting of LNAPL removal from EW-8 and two nearby monitoring wells (MW-97-1 and
MW-98-1) was constructed. Start-up of this system occurred in the spring of 1999 and is currently
removing LNAPL at a rate of 5 to 8 gallons per day. LNAPL removal equipment at EW-3 and EW-6
may be added in the future, if deemed necessary.
Bioreactors. During the first year of operation, it was discovered that a viable biomass could not besustained within these units due to the lower than expected concentration of contaminants. However,
it was also discovered that removal rates of semivolatile and volatile organic compounds exceeded90% within these units due to aeration. Therefore, although these units are not operating asbioreactors, they remain on-line due to the air stripping that occurs.
Vapor Phase Carbon. Off-gases from the bioreactors and headspaces of process area tanks wereoriginally evacuated and treated by a fume incinerator. Based on a value engineering study, off-gas
treatment was switched to vapor phase carbon in June 1998.
Polymer Addition to Enhance Metals Removal. Existing clarifiers were modified for the addition
of polymer, to assure enhanced floe formation and settlement at higher plant flow rates. Thismodification was implemented in the spring of 1998.
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Internal Modifications. Internal modifications such as piping changeovers, and pump upgrades were
made to increase the capacity of the groundwater treatment plant. The plant is now capable of
treatment at a rate of up to 200 gpm.
Back-up Generator. Electrical circuitry was modified to allow the entire treatment plant to operate
on a back-up generator. Originally, a back-up generator operated only lighting and other bare
essentials.
2.1.3 System Performance
The historic performance of the extraction/recharge system and the GWTF is summarized below.
This summary is based on performance evaluations performed by M&E (M&E 1995, M&E 1997),
recent evaluations of 1998 plume data by M&E, discussions with GWTF personnel and eight monthly
operation reports from the plant (May 1998 to December 1998).
Extraction/Recharge System. With the exception of short-term interruptions (i.e., a few days to a
few weeks), the extraction/recharge system has operated continuously since start-up at varying system
flow rates. The most significant variations in system flow were during source control remediation.During this time, a significant amount of water from the excavation dewatering operations performed
was being pumped to the GWTF and treated. The flow from the extraction wells was decreased tobalance the incoming flow to the plant. Despite this redistribution, the combined effect of dewatering
and extraction well flow still achieved project objectives of contaminant removal. However, full
plume containment was questionable during this two-year period (June, 1995 through July, 1997).After source control remediation was completed in 1997, the extraction systems were brought back
to full operation.
Since the completion of source control, further progress has been made in achieving the target flow
range of 150 gpm to 200 gpm. Technical problems with EW-2, EW-3 and EW-6 (e.g. faulty pumps,low water levels faulty sensors) have sometimes hampered the effort to pump in the target flow range.
The addition of EW-7 and EW-8 allowed the system flow rate to pump over 150 gpm. The operators
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of the GWTF and the extraction system are currently trying to determine optimal flow rates from each
extraction well so that the system flow rate will exceed 150 gpm continuously.
Recent data have shown that contaminant levels have dropped significantly in discharge from
extraction wells EW-2 and EW-4, indicating success in groundwater cleanup. An evaluation is
currently being performed to determine if these wells should remain on-line or if groundwater
pumping can be distributed to other wells to focus pumping on more contaminated portions of the
plume.
The recharge system has performed as designed. The basins are used on a rotational basis to ensure
long-term effectiveness of each basin.
Ground water Treatment Facility. Up until the spring of 1998, the GWTF had difficulty in
accommodating influent pumping rates of greater than 150 gpm due to piping and plumbing problems.
Recent upgrades in the GWTF as discussed above, have resolved these problems.
In general, the GWTF discharge meets the discharge criteria for all compounds (1986 MCLs). There
have been exceedances of iron in the past (i.e., above the secondary MCL of 0.30 mg/L). However,
as discussed above, the iron removal process has been enhanced within the last year, and
consequently, there have been no exceedances since these modifications were completed. Table 2-1
summarizes monthly average discharge levels for the GWTF over the period from May to December1998 and indicates that over that period, discharge criteria have been met. Table 2-2 summarizes total
influent and effluent levels for VOCs, SVOCs, arsenic and lead and lists the percent removal withinthe plant for the last eight months.
Between March and December 1998, high levels of acetone were detected in the plant influent stream.Acetone was also detected in on-site and off-site monitoring wells and surface water. The source of
acetone is not believed to be site-related. The acetone was not removed by the GWTF and therefore,flowed through the system dissolved in water and was discharged back to groundwater via the
infiltration basins. Since there is no MCL for acetone, this was not considered a violation of the
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discharge criteria. Since December 1998, acetone has not been detected in the plant effluent, in Site
monitoring wells, or in adjacent surface water.
2.1.4 Data Evaluation
Plume Evaluations. Evaluations of extraction system performance in regard to contaminated
groundwater remediation and containment have been performed. These evaluations generally involve
creating contour maps ("plume maps") of total VOCs and SVOCs in overburden and bedrock for a
comprehensive round of groundwater sampling performed by the GWTF operator. Four quarterly
sampling rounds, including one comprehensive round of the majority of the Site monitoring wells, are
performed each year. Plume maps were created for the years 1988 (prior to system start-up), 1995
(two years after start-up), 1997 (following source control remediation) and 1998. Plume maps for1988 and 1995 are documented in the report entitled Evaluation of Extraction System Performance
at the Baird & McGuire Site (M&E, 1995). Plume maps for 1997 are documented in a letter to EPA
dated January 29, 1998 (M&E, 1998b). Plume maps for 1998 are documented in a letter to EPA
dated March 3, 1999 (M&E, 1999). Both 1997 and 1998 plume maps are included in Appendix A.
A comparison of these maps indicates that the plumes of VOCs and SVOCs have decreased in size
over time. Comparison of 1997 maps with 1995 maps indicated that the edge of the plume (ie., 5 ppbcontour line) has moved inward toward the source since the 1995 sampling event (M&E, 1998b). This
is further evident when comparing 1998 plume maps with 1997 plume maps. Table 2-3 lists total
VOC and SVOC concentrations over time for most of the Site wells. Concentrations have generallydecreased over time. It should be noted that several site wells were replaced after being destroyed
by source control remediation. The original well name and the replacement well name are listed inTable 2-3 for clarity.
Based on yearly plume comparisons, field observations, and other data, it was concluded that a
continuous source of contamination exists at the center of the plume and that this source is likely
(LNAPL). This led to EPA requesting an LNAPL survey and implementing the LNAPL remediation
system.
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The 1998 plume maps indicate that these LNAPL sources still exist within the plume (as evidenced
by the plume hot-spots), but concentrations have decreased. One possible cause of the decrease is
the combined effect of extraction well upgrades (including the addition of EW-7) and source control
remediation completed in early 1997. Despite the continued decrease in plume size, concentrations
in groundwater are still far above the target cleanup levels (MCLs). EPA plans to continue
evaluations of plume maps on a yearly basis to track progress in remediation.
LNAPL Investigation. EPA requested an investigation of the existence of LNAPL at the Site to
confirm that LNAPLs exist near the center of the plume. This investigation, performed in November
and December 1997 and documented in a report prepared by McCulley, Frick and Oilman, Inc.
(MFC), under subcontract to M&E Services/PSG (MFG, 1998), confirmed that LNAPLs werepresent in Site wells. The results show that a layer of LNAPL floating on the groundwater is present
in the central part of the site only, as shown on Figure 2-2. LNAPL thicknesses in wells ranged from
trace levels to a maximum of 3 feet.
Chemical analyses of one LNAPL sample collected by M&E Services/PSG (near the center part of
the site) indicated that the LNAPL primarily consists of semi-volatiles such as naphthalene (3,000ppm), fluorene (3,600 ppm), phenanthrene (3,800 ppm), acenapthene (8,100 ppm), acenapthalene
(9,700 ppm), fluoranthene (6,300 ppm) and pyrene (500 ppm). The LNAPL also contains significantlevels of volatiles (primarily BTEX) including benzene (33 ppm), ethylebenzene (1,720 ppm), toluene
(522 ppm), total xylenes (8,480 ppm). Several pesticides were also found (e.g., lindane, dieldrin,
endrin, 4,4-DPD and 4,4-DDE). These compounds primarily comprise the dissolved phase plume
leading to the conclusion that LNAPLs are the source of the plume. Although the LNAPL sample
was not analyzed for inorganics, evaluation of dissolved plume concentrations of arsenic indicates thatthe highest dissolved concentrations of arsenic are generally coincident with the locations whereLNAPL was found or suspected. It is assumed that ongoing LNAPL remediation will help reduce
arsenic levels as well as other organic and inorganic compound levels in groundwater.
Based on the findings of the plume studies and LNAPL investigation, EPA moved forward withimplementation of the LNAPL Remediation System. The purpose of this system is to remove
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LNAPLs to accelerate groundwater remediation. The LNAPL remediation system is currently on-
line, removing LNAPL at a rate of 5 to 8 gallons per day.
Discharge to the Cochato River. All plume maps developed to date have indicated that the
contaminant plume extends across the Cochato River. This suggests that contaminated groundwater
could at times discharge to the river. In April 1998 at EPA's request, the USGS performed a study
of the Cochato River to investigate potential discharge to the river (USGS, 1998). The USGS
installed piezometers in the river sediments to investigate vertical gradients, and multi-level vapor-
diffusion samplers to detect the presence of VOCs in sediment pore water. The investigation found
that upward vertical gradients (from the aquifer to the river) existed at the time of the sampling. Also,
VOCs and S VOCs were detected in diffusion samplers. This indicates that some level of contaminants
were migrating into the river at that time. Since this sampling technique does not allow for a direct
correlation to surface water concentrations from the vapor diffusion sample data, surface water
samples were also collected. The surface water sampling conducted during this event and on several
occasions afterward (by EPA), have not detected any contaminants in the river water that are present
in the groundwater plume or in any samples from the vapor diffusion samplers.
Although the USGS findings suggest groundwater could have been discharging to the river at the timeof sampling, it was noted that during the investigation the extraction system was operating at only
65 gpm, with only four of the six extraction wells operating. In addition, extreme precipitationconditions existed during the sampling effort, which caused higher than normal groundwater levels
and gradients. Consequently, while it is likely that full plume containment was not occurring during
the April event, the study was inconclusive with regard to whether there is groundwater discharge tothe river during times when the extraction system is operating within the target extraction range of
150 to 200 gpm.
Natural Attenuation. There is evidence to suggest that biodegradation is occurring within the
plume. In general, suitable conditions exist for biodegradation of chlorinated compounds by reductivedechlorination and biodegradation of other organic compounds such as BTEX and PAHs (e.g.,
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napthalene) by aerobic oxidation and iron reduction. The evidence for bio degradation of organic
compounds is as follows:
• Decreasing concentrations of PCE and TCE in the dissolved plume over time;
• Decreasing BTEX concentrations in the dissolved plume over time;
• Suitable concentrations of electron acceptors and electron donors (required forbio degradation);
• Presence of chloride and chlorinated solvent daughter products such as 1,2 DCE and vinylchloride;
• Low concentrations of nitrate in the plume area; and
• Increased iron concentrations in the plume area.
The process of biodegradation may be helping to attenuate the plume beyond the source areas (e.g.
across the Cochato River and on the north side of the plume) and could be a significant factor in total
plume remediation once the groundwater sources (LNAPLs) are removed. For this reason, future
five-year reviews will consider natural attenuation in the evaluation of the efficacy of attaining cleanup
goals. Future groundwater monitoring should be tailored to collect pertinent data necessary for
evaluation of natural attenuation.
2.2 SOILS REMEDY (OU-2)
The source control remedy (removal and treatment of contaminated soils) commenced in June 1995and was completed in July 1997. Monitoring activities conducted since completion of treatment of
on-site soils. Ongoing O&M activities include annual inspections and maintenance of the soil cover
as well as wetlands monitoring. All soils excavation and treatment facilities have been
decommissioned and removed.
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2.2.1 Components of the Remedy
Major components of the Site source control remedy were erosion control, excavation of soils,
dewatering, backfilling of incinerated material, extraction well piping relocation of the unnamed
stream, incineration, site restoration, wetlands restoration and monitoring.
Erosion Control. Cleared, excavated and backfilled areas were protected from erosion using
temporary drainage ditches, berms silt fences, hay bales, erosion checks and temporary and permanent
vegetation. Wood sheeting was installed along the Cochato River to control erosion and sediment
transport to the river.
Excavation. The Site was cleared and grubbed, and excavation haul roads were built prior to
excavation. Wood sheet piling was installed along the river to facilitate excavation and dewatering
in that area. During the design and implementation of OU-2, the excavation limits were modified to
encompass a slightly larger area than specified in the ROD. The modified excavation limits are shown
on Figure 2-3. Soils were excavated to approximately one foot below the seasonal low water tablewithin the excavation limits, with excavation depths ranging from approximately 3 to 33 feet below
grade. Soils were excavated in 100' by 100' grids. Approximately 248,000 tons of soil and sediment
were excavated and treated by on-site incineration. Soils were stockpiled on site for storage prior to
incineration.
Dewatering. During excavation, dewatering was required to depress the water table to one footbelow the seasonal low water table. A maximum of 100 gpm was pumped for dewatering purposesand conveyed to the GWTF for treatment. Dewatering was accomplished by placing a sump pump
within the excavation. Water was then pumped to a 100,000-gallon holding basin and on to the
GWTF.
Backfilling. Approximately 250,000 tons of the treated soil (i.e., ash) were backfilled into the 12.5-acre excavation area. Approximately 320 tons of ash which failed the leaching criteria were stabilizedwith cement prior to backfilling to reduce the potential for leaching of contaminants by infiltrating
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rainwater. The location where stabilized ash was placed is shown on Figure 2-3. A composite sample
of soils remaining at the base of the excavations was taken prior to backfilling to determine the
magnitude of residual contamination.
Extraction Well Piping Relocation. Extraction well piping was replaced at the end of the
excavation process. Single header pipes were replaced with individual pipes conveying water from
each extraction well to the main extraction well junction chamber. The main chamber was used as
a vault foundation for the Extraction System Control building completed in 1998.
Unnamed Stream Relocation. The unnamed stream was temporarily relocated and a culvert pipe
was installed for its upper portions. The stream was redirected back to its natural course as part of
wetlands restoration.
Incineration and Stabilization (IS) Facility. The IS facility consisted of the following primary
components:
• Materials Handling Unit
• Thermal Destruction Unit (TDU) Feed System
• Rotary Drying Chamber
• Rotary Kiln
• TDU Ash Quench and Removal System
• High Temperature Baghouse
• Scrubber
• Heat Exchanger and Cooling Tower
• Scrubber Blowdown Water Treatment System
• Secondary Combustion Chamber
• TDU Exhaust System.
The primary component of the Thermal Destruction Unit (TDU) was the Rotary Kiln. Materials were
incinerated at a temperature of approximately 1,200 °F. Approximately 248,000 tons of material was
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incinerated. TCLP tests were performed on the ash. Approximately 320 tons of material failed to
meet criteria and was stabilized with cement prior to backfilling.
Site Closure. Upon the completion of soil excavation and treatment, the incineration contractor
initiated Site closure activities as described in the Revised Site Closure Plan (OHM, 1997). These
activities included decontamination, decommissioning and removal of the incinerator building and
equipment; off-site disposal of material generated during demobilization and Site closure, which could
not be treated on-site; utility closeout; final grading, and Site restoration.
Site Restoration. Site restoration involved decommissioning the IS facility, final grading of the
excavation zone, placement of topsoil and seed and wetlands restoration (OHM, 1993). As part of
the decommissioning activities, the former concrete foundation of the incinerator building was crushedand placed within the excavation area along with the backfilled ash. The approximate disposal
location of this foundation material is shown on Figure 2-3. Twelve inches of topsoil were placedover the incinerated soil and the Site was hydroseeded.
Site restoration also included replacement of monitoring wells destroyed during source control
remediation. In general, wells were replaced in the general vicinity of the original well, with some
variations in screened intervals. Existing wells are shown on Figure 1-2.
Wetlands Restoration. Mitigation of unavoidable wetland impacts associated with the remediation
was required to comply with wetlands ARARs. The Final Site Restoration Plan (OHM, 1993),
required the on-site restoration of approximately 7.4 acres of forested and scrub/shrub floodplain
wetlands, including a small peat bog and 1,000 linear feet of the unnamed brook. The plan alsorequired restoring the wetland to the approximate original grades and elevations, backfilling with
organic topsoil (at least 20 percent organic matter by weight) and seeding and planting with
appropriate herbaceous, shrub, and tree species. The relocated stream was to be re-created similarto the original stream in width, depth and bottom characteristics. Once grading and seeding were
completed, the plan required, sequentially, hydrologic monitoring through one full growing season;
adjusting grading as necessary, repeating seeding as needed, and planting of shrubs and trees. The
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plan also required annual monitoring of the wetlands for three years following completion of the
restoration efforts.
The peat bog area was backfilled with organic topsoils as required by the Site Restoration Plan.
Grading, seeding and planting of the restored peat bog was completed in 1998. Grading of the
remainder of the wetland (the majority) was completed in early 1996 and seeding and planting was
completed during the 1996 growing season. The backfilled soils in the majority of the wetland were
less than 20% organic content required by the restoration plan. However, it was anticipated that if
the wetland soils are saturated within the top 12 inches of the ground surface for at least 14 days
during the growing season, the soils would eventually develop sufficient organic and hydric
characteristics.
Hydrologic monitoring is being performed as part of the wetland restoration plan. This plan requires
hydrologic monitoring during the growing season from approximately May 1 through October 1.
Based on the data, EPA and USAGE will evaluate whether sufficient hydrologic conditions are
present to allow the wetland soils to develop naturally with no disruption to existing vegetation.
In September 1997, a USAGE and a M&E wetlands scientist inspected the wetlands. The condition
of many of the new plants was observed to be poor. Physical trauma to the plants and insufficient
hydrology, rather than poor soils, may have been the cause of the poor condition of the vegetation.
Subsequent to the September 1997 inspection, EPA and USAGE required the following measures as
partial remediation for the inadequate soil organic content in the restored wetlands.
• The addition of topographic and habitat diversity to the restored wetland, creation of oneshallow, irregularly shaped pool (approximately 1,500 square feet) and planting the poolwith emergent vegetation.
• Construction of gabion check dams and coconut fiber rolls across the unnamed stream toenhance the hydrology of the restored wetlands.
• Placement of a fiber roll, or similar structure, along the edge of the Cochato River toensure water continues to pond in the wetland.
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EPA & M&E concluded from the site visit conducted for this five-year review that, although the
wetland was not restored with the organic soils recommended in the Final Restoration Plan, the
mitigative measures required by EPA and USAGE after the 1997 wetlands inspection appeared to
have been implemented. The wetland will be monitored annually for three years (until the fall of
2000) in order to assess the success of the wetland restoration effort.
Continued Monitoring. The only remaining activities of the source control remediation are follow-
up inspections and yearly monitoring of the wetlands. This will be performed for a period of three
years after restoration (until 2000).
2.2.2 Data Evaluation
The source control contractor took composite soil samples from the base of the excavations prior to
backfilling. In addition, the backfilled ash was characterized by composite ash samples. In the Site
Reuse Report (M&E, 1998), these data were used in a qualitative evaluation of risk for future Siteuse.
Bottom-Depth Samples. A total of 61 composite bottom-depth soil samples were taken and
analyzed for SVOCs, pesticides, arsenic and lead. These samples were taken from 100' by 100'
excavation grids over the entire excavation zone.
The bottom-depth samples varied in depth from 2.9 to 33.4 feet below grade. Most of the bottom-depth soil samples exhibited residual contamination due in part to the fact that they are below the
existing water table in zones of groundwater contamination. The SVOCs detected consisted primarily
of polycyclic aromatic hydrocarbons (PAHs) whereas the pesticides consisted primarily of DDT,
ODD, DDE, dieldrin and chlordane.
Ash Samples. The source control contractor analyzed incinerated soil (ash) prior to backfilling withinthe 12.5 acre excavation area Samples of each 300 tons of ash were taken prior to backfilling for a
total of 950 routine compliance samples. Analytes for these samples consisted of lead, arsenic and
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up to 11 organic analytes. Sixteen quarterly samples of the ash were taken and analyzed for VOCs,
SVOCs, pesticides, dioxins/furans and 12 metals. Toxicity characteristic leaching procedure (TCLP)
tests were performed on samples of calciner ash. Results of ash sampling can be found in the Site
Reuse Report (M&E, 1998).
2.3 SEDIMENT REMEDY (OU-3)
The remedy for OU-3 involved removal of contaminated sediments from the Cochato River. This
remedy commenced in May 1994 and was completed in June 1995. The results of this remedy are
described in detail in the Remedial Action Report for OU-3 by the New England Division (NED) of
the Army Corps of Engineers (NED, 1997).
2.3.1 Components of the Remedy
Major components of the sediment remedy were Site preparation, sediment dredging, placement of
organic fill and O&M.
Clearing Grubbing, Detention Basin and Haul Roads. The river banks were cleared and grubbed
in preparation for river excavation. A detention basin was built in the river just downstream of the
Union Street Bridge to trap suspended sediments during dredging. The detention basin was
subsequently removed. Temporary haul roads were constructed and then removed after testing
showed no residual contamination.
Dredging. Sediments were dredged from a 2,100-foot reach of river extending from the Baird &McGuire Site to the Union Street bridge (see Figure 2-4). Sediments were dredged to a minimum
depth of six inches and a maximum depth of 24 inches in some areas. Dredged material was pkced
in scalable containers and transported to the Baird & McGuire exclusion zone where it was stored forsubsequent incineration. A total of 4,712 cu. yd. of material was removed from the river. Dredged
material was transported to the IS facility, incinerated and pkced as backfill within the OU-2 soil
excavation area.
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Placement of Organic Fill. The portion of the river where contaminated groundwater underlies the
riverbed was backfilled with approximately 438 cubic yards of clean organic fill. This organic fill acts
as a filter which will attenuate contaminated groundwater that may discharge into the river.
Operation and Maintenance. Work in the dredged areas is complete and requires no future
operation and maintenance (NED, 1996a). EPA developed and is currently implementing a long-term
monitoring plan for the river downstream of the dredged area as part of the OU-3 Operations and
Monitoring plan. This program, which is currently ongoing and is scheduled to last 30 years, includes
analyses of sediment and fish. Sediment samples will be collected annually for the first five years and
fish samples will be collected every 5 years, after which there will be a review of the data and trends.
After the review, sampling frequency may be reduced if the contaminant levels are not increasing
(NED, 1996a). If contaminant levels are increasing, there may be additional sampling in the dredged
reaches of the Cochato River, including an analysis of contaminant accumulations in the organicmaterial backfilled in the river.
Restoration of Wetlands. Wetlands adversely impacted by the dredging and the installation of haulroads were restored under the OU-2 Final Restoration Plan.
2.3.2 Performance
River sediments were remediated to the following human health target cleanup levels:
• Arsenic - 250 ppm• DOT and metabolites (DDD and DDE) - 19 ppm• Chlordane - 5 ppm• Total PAHs - 22 ppm
Cleanup criteria for the riverbanks, as determined by EPA and in consultation with MADEP, is
1.5 times the human health criteria used for sediment (NED, 1996).
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NED inspected work as it proceeded. Samples taken from the river channel and overbank reaches
were analyzed in the USAGE NED Environmental Laboratory for PAHs, chlordane, DDT and
metabolites (DDD and DDT) and arsenic. Sampling results showed that all reaches met target
cleanup levels (NED, 1996).
2.3.3 Long-Term Monitoring
The OU-3 ROD states that no excavation (dredging) would be performed downstream of the Union
Street Bridge due to the potential adverse environmental impacts it would cause. Instead, the ROD
requires long-term monitoring on an annual basis of downstream areas. The ROD also requires that
the monitoring data be evaluated at least once every five years to assure that the remedial actioncontinues to protect human health. Monitoring of surface water quality was not included in the ROD
monitoring plan because the data collected in the Site RI/FS indicated no detectable levels of
contaminants in surface water. Nevertheless, surface water samples have been collected in theCochato River adjacent to the site on a weekly basis; no contaminants above detectable levels have
been found. Fish monitoring is also performed to monitor the impact of sediments on the fish
population.
Long-term sediment sampling is performed by NED and involves taking three random samples from
six locations (strata) for a total of 18 samples annually. The six samples are taken from four general
areas (see Figure 2-4):
A: Upstream of the project area (control)B: Between the Union Street Bridge and Center StreetC: Ice Pond (two areas)D: Mary Lee Wetlands (two areas)
Results are statistically analyzed using the ANOVA (analysis of variance) technique. The results of
the third year of long-term monitoring of sediments performed in September 1998 are documented
in a USAGE monitoring report submitted to EPA (NED, 1998). The results show that all arsenic,
chlordane and total DDT levels were below channel criteria. Total PAHs were below the channel
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criteria, but four overbank samples exceeded channel criteria and one overbank sample exceeded the
overbank criterion of 33 ppm (1.5 x 22 ppm = 33 ppm). However, this only occurs if it is assumed
that the results are equal to the detection limit for the individual PAH; if the results are assumed to
equal half of the detection limit, the total PAH result is below 33 ppm. The results show no
discernable trends in the first three years of sediment sampling.
2.4 REPLACEMENT OF LOST DEMAND (OU-4)
The ROD for OU-4 was issued to address alternate water supply/replacement of lost demand that
resulted from the contamination and subsequent shutdown of the South Street well field (part of the
water supply for Holbrook) in 1982. The wellfield is within 1,500 feet of the Baird & McGuire
property. The reactivation of the Donna Road aquifer was selected in the OU-4 ROD as the alternate
water supply.
2.4.1 Components of the Remedy
The remedy includes the following components:
• Permitting/Predesign Studies
• Ground water Extraction
• Treatment
• Delivery to the Distribution System
2.4.2 Performance
Currently, the system is in the design stages. Future five-year reviews will need to address the
performance of this remedy.
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SECTION 3.0SITE VISIT
A Site visit was conducted on September 30, 1998 to observe Site conditions. The EPA RPM, M&E
project engineer, ARARs specialist, and wetlands scientist attended the Site visit. The Site visit
included a physical inspection of the Site including the regraded and seeded potions of the Site, the
restored wetlands, the Cochato River, the extraction wells and recharge basins, the Extraction System
Control Building and the Groundwater Treatment Facility (GWTF). Observations are listed below.
3.1 REGRADED AND SEEDED PORTIONS OF THE SITE
In general it appeared that there was a significant growth of grass on the regraded portion of the Site.
Some additional grading activities were being performed at the time of the Site visit to create surface
water diversion channels around the extraction system control building.
3.2 RESTORED WETLANDS
A wetlands inspection was performed during the Site visit. One objective of this visit was to check
that the mitigative measures requested by USAGE to compensate for the lack of organic soils in
backfill had been implemented. Although this inspection was conducted after the growing season,
when the plants were senescent, the wetlands plants that were planted by the source control
contractor appeared to be in good condition.
It was observed that one shallow pool had been created by the source control contractor. Three
check dams had been constructed in the unnamed stream and were functioning. As a result, water
was ponding in wetlands near the Cochato River in some locations.
EPA and M&E concluded from this Site visit that, although the wetland was not restored in
accordance with the Final Restoration Plan (with regard to placement of organic soils), the mitigative
measures required by EPA and USAGE after the 1997 wetlands inspection, appeared to have been
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implemented. The wetland will need to be monitored annually for three years, in accordance with the
Final Restoration Plan, to assess the success of the wetland restoration effort. The first monitoring
report was completed in the fall of 1998. USAGE is currently reviewing this report.
3.3 COCHATO RIVER
No extraordinary conditions were noticed with regard to the Cochato River. Piezometers used in the
USGS study of the Cochato River in April 1998 were still existing within the river channel.
3.4 EXTRACTION WELLS AND RECHARGE BASINS
The extraction wells and recharge basins were in operation during the Site visit. Although theextraction/recharge system flow was not determined, a significant amount of water was being
discharged to the northernmost basin during the visit.
It appeared that new monitoring wells and a preliminary boring for extraction well EW-8 had been
recently installed at the time of the visit.
3.5 EXTRACTION SYSTEM CONTROL BUILDING (ESCB)
Electrical contractors were working on the controls within the ESCB at the time of the visit. The
ESCB had been in use for several months prior to this visit and the controls appeared to be in good
working order. Some water had accumulated in the vault of the building due to surface water runoff
and seepage around the foundation. This problem was being addressed at the time of the visit by
installing drainage swales around the building.
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3.6 GROUNDWATER TREATMENT FACILITY (GWTF)
The GWTF was operational at the time of the visit. A walk through was performed under Level D
personal protection conditions. No extraordinary conditions were observed. Several minor leaks
were observed from tanks and pumps. However, these leaks were addressed by secondary
containment and there appeared to be no hazards associated with these leaks. Follow-up discussions
with GWTF personnel indicated that all units were operating properly. Operations are monitored by
the USAGE on-site resident engineers and are reported monthly by GWTF personnel to EPA.
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SECTION 4.0
ARARS REVIEW
A review of ARARs was conducted to evaluate whether the remedial actions are protective of
human health and the environment. The review accounted for updated regulatory standards
promulgated since the RODs were issued.
4.1 STANDARDS REVIEW APPROACH
Chemical-specific ARARs, including criteria to be considered (TBC), used during development of the
RODs were updated and any changes evaluated to determine the effects of the changes on the chosen
remedial action and action effectiveness. The standards review was based on review of EPA-provided
documents as well as published federal, state and local rules and regulations.
An analysis of newly promulgated or modified requirements of state or federal environmental
regulations was conducted to determine if these ARARs call into question the protectiveness of the
remedy. Within this report, chemical-, location-, and action-specific requirements are tabulated.Changes to the requirements since the RODs were signed are highlighted.
The standards review also includes examination of analytical data collected from the Site and the
groundwater treatment plant, including quarterly monitoring data in comparison to federal and state
standards. Recommendations are made as to whether any changes to the list of constituents of
concern need to be made.
The basis for the Site RODs for OU-1, OU-2 and OU-3 was developed prior to promulgation of therevised National Contingency Plan (40 CFR Part 300, March 1990) and prior to publication of the
CERCLA Compliance With Other Laws Manual: Parts I and n, (OSWER Directives 9234.1-01 and
9234.1-02, respectively), although existing Draft ARAR procedures were followed in the ROD for
OU-3. Many changes to the ARARs have occurred since the three RODs were developed. Thesechanges are presented in the subsequent subsections.
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4.2 ARARS REVIEW - OPERABLE UNITS 1 & 2
The 1986 ROD for OU-1 and OU-2, Groundwater Extraction and Treatment plus Soil Excavation
and Treatment (U.S. EPA, 1986) set forth the following ARARs for the selected source control and
management of migration remedy:
• Resource Conservation and Recovery Act (RCRA)
• Clean Water Act, and associated state regulations
• Safe Drinking Water Act
• Clean Air Act, and associated state regulations
• Executive Order 11990 (Protection of Wetlands)
• Executive Order 11988 (Floodplain Management)
Since this ROD was completed prior to promulgation of the revised National Contingency Plan (40
CFR Part 300, March 1990) and prior to publication of the CERCLA Compliance With Other Laws
Manual: Parts I and II, (OSWER Directives 9234.1-01 and 9234.1-02, respectively), the ROD doesnot provide detailed analysis of the applicability or relevance and appropriateness of each regulation.For the purposes of this review and compliance with current requirements, the following tables have
been prepared:
Table 4-1: Potential chemical-specific ARARs and guidance for OU-1 and OU-2 are
evaluated in this table, using the regulations listed in the ROD as a basis. The evaluation
includes a determination of whether the rule is currently ARAR or TBC and whether the
remediation is in compliance with the ARAR.
Table 4-2: This numerical, chemical-specific ARARs table presents drinking water and
groundwater protection standards for OU-1 groundwater chemicals of concern. The
contaminants of concern listed at the top were identified as critical contaminants in the 1986
ROD for OUs I and II; "other compounds detected," at the bottom of the table, identifiescriteria for compounds detected at levels exceeding SDWA MCLs during 1997 groundwater
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monitoring. The 1989 Site Maintenance Plan (M&E, 1989) specified that the regulatory
criteria for closure of the GWTP/extraction system be the attainment of MCLs for all
contaminants.
Table 4-3: Potential location-specific ARARs and guidance for the entire Site are presented.
Table 4-4: Potential action-specific ARARs and guidance for the OU-1 and OU-2 remedies
are evaluated, using the regulations listed in the ROD as a basis. The evaluation includes a
determination of whether the rule is currently ARAR or TBC.
Overall, many of the ARARs have changed since the 1986 ROD was signed. The referenced tables
provide a summary of current state and federal ARARs. In addition, criteria to-be-considered are also
modified from the previous ROD presentations. Massachusetts Drinking Water Health Advisories
have been replaced by Massachusetts Office of Research and Standards Guidelines (ORSGs). Federalacceptable intake chronic and subchronic values are no longer used, having been replaced by Risk
Reference Doses (RfDs). In addition, RfDs and Carcinogen Assessment Group (CAG) slope factors
are two of several factors that may be used to calculate risk at a Site. These criteria do not need to
be identified in the ARAR section as they are usually covered under the RI/FS risk assessment
discussion of a five-year review. This five-year review does not include recalculation of risk.
Therefore, RfDs and CAG slope factors are not updated on the numerical groundwater criteria tables
and are not discussed in the chemical-specific ARARs table.
Revisions to the chemical-specific requirements can affect treatment plant operation and maintenance.
Environmental monitoring programs are frequently under review to address the chemical-specific
ARARs, particularly the groundwater protection programs under RCRA and the Commonwealth of
Massachusetts.
The wetlands ARARs identified in the Site RODs still apply today. A Wetland Restoration Plan was
implemented to restore wetlands impacted by remedial measures. Wetlands monitoring is currently
ongoing. The status of wetlands restoration was assessed during the Site visit (see Section 3.0).
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Action-specific requirements were identified in previous RODs, although the regulatory
considerations were not clearly distinguished for OU-1 or OU-2. An attempt has been made to clarify
the requirements. The requirement status identified in the accompanying tables is accurate for on-
going remedial actions.
4.3 ARARS REVIEW - OPERABLE UNIT 3
The 1989 ROD for OU-3, Sediment Excavation and Treatment (U.S. EPA, 1989) set forth the
following ARARs for the selected source control and management of migration remedy:
• Resource Conservation and Recovery Act (RCRA)
• Clean Water Act (CWA)
• Executive Order 11990 (Protection of Wetlands)
• Executive Order 11988 (Floodplain Management)
• Clean Air Act (CAA)
• Occupational Safety and Health Act (OSHA)
• 310 CMR 30.00 - Hazardous Waste Management Requirements
• 310 CMR 6.00 - Ambient Air Quality Standards for the Commonwealth of
Massachusetts
• 310 CMR 7.00 - Air Pollution Control Regulations
• 310 CMR 10.00 - Wetlands Protection Requirements
• 310 CMR 33.00 - Employee and Community Right-to-Know Requirements
• 314 CMR 4.00 - Surface Water Quality Standards
• 314 CMR 9.00 - Certification for Dredging and Filling
• 302 CMR 6.00 - Inland Wetland Orders
For the purposes of this review and compliance with current requirements, the following tables havebeen developed to revisit ROD specified ARARs.
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Table 4-5: Potential chemical-specific ARARs and guidance identified in the ROD for OU-3
are re-evaluated in this table. The re-evaluation includes a determination of whether the rule
is currently ARAR or TBC and if the requirement has been met.
Tables 4-6: This numerical, chemical-specific ARARs table presents a comparison of the
ROD-specified standards (1989) to current (1998) standards for surface water quality for OU-
3 chemicals of concern.
Tables 4-7: Potential action-specific ARARs and guidance identified in the OU-3 ROD are
re-evaluated in this table. The re-evaluation includes a determination of whether the rule is
currently ARAR or TBC, and if the requirement has been met.
Location-specific ARARs apply uniformly to the Site (OU-1, OU-2 and OU-3) and were presented
in Table 4-3.
4.4 ARARS REVIEW - OPERABLE UNIT 4
The 1990 ROD for OU-4, Replacement of Lost Demand (U.S. EPA, 1990) set forth the following
ARARs:
Chemical-specific:
• Safe Drinking Water Act• Massachusetts Drinking Water Regulations
Location-specific:
• Executive Order 11990 (Wetlands Protection)• Fish and Wildlife Coordination Act• Clean Water Act• Rivers and Harbors Act of 1899• Resource Conservation and Recovery Act• Massachusetts Wetlands Protection Act
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• Massachusetts Waterways Act• Massachusetts Surface Water Quality Standards• Massachusetts Groundwater Quality Standards• Massachusetts Water Quality Certification and Certification of Dredging• Massachusetts Water Management Act• Massachusetts Supervision of Inland Waters
Action-specific:
• Occupational Safety and Health Act• Massachusetts Guidelines and Policies for Public Water Systems
Many of the ARARs identified would be applicable regulations at the off-site property. For example,the reopening of a Donna Road Well public drinking water supply facility would be required to meet
all state and federal regulations. A discussion of "relevance and appropriateness" of requirements at
off-site properties is not appropriate. ARARs for the Baird & McGuire Superfund Site have been
discussed in sections 4.1 through 4.3. Standards for the Donna Road Well reopening are detailed in
specification documents developed for that work being conducted under state authority, and are
available from the Commonwealth of Massachusetts.
The Occupational Safety and Health Administration (OSHA) standards (Le., 29 CFR 1910, 1904, and
1926) apply to worker safety, and require employers to communicate risks at the workplace to
employees. OSHA standards are worker requirements, not environmental rules, and must be
complied with during all Site work; they are no longer discussed as ARARs.
The DEP DWS published a document, called the Massachusetts Guidelines & Policies for Public
Water Systems, that provides guidance for the exploration, evaluation, treatment, storage/distribution, and protection of new public water supply sources (DEP, 1990). For all
groundwater withdrawals, the document specifies an exploration phase, Site exam, five-day pump
test, requirements for delineating three affected zones, and a final report. Compliance with this
guidance would be provided in specification documents for the Donna Road Well.
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SECTION 5.0
COMPLIANCE STATUS
5.1 OU-1 - GROUNDWATER
On-going remedial actions for groundwater are generally being conducted in compliance with state
and federal environmental regulations. This includes the groundwater treatment plant which operates
in compliance with state and federal RCRA hazardous waste generator rules. The treated
groundwater discharge complies with MCLs.
Underlying groundwater contamination remains, however, and continued treatment is required to
achieve state and federal drinking water standards, RCRA groundwater protection standards, and
other federal and state groundwater protection standards. Constituents in Site groundwater still
exceed criteria for arsenic, dieldrin, VOCs, and SVOCs. Identified as applicable or relevant and
appropriate, the requirements under the Safe Drinking Water Act, RCRA Subpart F, MassachusettsGroundwater Quality Standards, and Massachusetts Drinking Water Requirements remain to be met.
Groundwater requires continued remediation under these rules.
5.2 OU-2 - SOIL
Soil remediation activities have been completed and compliance with the ROD achieved. The only
remaining soil remedial action is monitoring of wetland restoration. Material left on-site consists of
incinerated soil (ash residue). The ash is covered with a soil layer, as specified by the ROD.Groundwater, surface water and sediment monitoring are in pkce at the Site, along with the
groundwater treatment system. Monitoring has shown that the contaminant plume is shrinking.
The only remaining soil and sediment compliance issue is that of wetland remediation. As discussed
in Section 2.2, the wetland was not restored in accordance with requirements regarding organic
content of the soils. However, steps are being taken to correct this. Wetland restoration is in the
implementation phase, and is following state and federal wetlands protection acts including
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Massachusetts wetlands protection rules.. Remedial action for OU-3 was initiated later than remedialactions for OU-1 and OU-2. A three-year monitoring program is being implemented to evaluate
compliance with wetlands restoration requirements. One monitoring event has been performed thus
far. A full assessment of compliance with wetlands restoration requirements will be made after thethird year of monitoring (year 2000), as required by the site restoration plan.
5.3 OU-3 - SEDIMENT
Sediment removal and treatment has been completed, consistent with the ROD, in areas ROD-specified for excavation. The site was regraded according to plan and according to floodplain
delineation. Downstream sediment quality, however, requires continued monitoring and evaluation.The ROD established annual monitoring of sediments downstream in areas not excavated, to evaluatethe success of natural degradative, depositional, and dispersal processes in reducing contaminant
concentrations. Annual monitoring of river sediments has been conducted since completion of thesediment removal and treatment action (NED, 1998). As required in the ROD for this operable unit,compliance with the ROD remedy (no action in the downstream locations) will be fully evaluated afterfive years of annual sediment monitoring data has been collected. Currently, three years of monitoring
have been completed. Wetland compliance issues for OU-3 are the same as discussed for OU-2, Soil,in Section 5.2 above.
5.4 OU-4 - LOST DEMAND
As this remedy is only in the design stage, it is too early to discuss compliance issues associated with
the remedy.
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SECTION 6.0GENERAL DISCUSSION OF RISK
No additional assessment of risk was performed under this five-year review. This following summary
of risk is based on prior risk assessments performed for the Site.
6.1 GROUNDWATER (OU-1)
A risk assessment performed under the 1986 Feasibility Study Report (FS) concluded that there
would be significant risk to human health if the "no action" alternative was implemented and
groundwater from the Site was ingested (GHR, 1986). The FS also indicated that there were no
public or private drinking water wells located within one mile of the Site, and thus, there were no
current exposures to groundwater. The ROD stated that the aquifer at the Baird & McGuire Site is
classified as a Class II aquifer (current or potential usage) and required restoration of the aquifer to
groundwater standards that are protective of human health and the environment. The objective of the
groundwater remediation system is to remediate the groundwater to the target cleanup levelsestablished during design (M&E, 1989). Continued operation of the groundwater extraction and
treatment facility and the restrictions on groundwater use are still required to address risks.
6.2 SOILS
The risk assessment performed in the FS addressed exposure to Site soils and outlying areas. Basedon the results of the FS risk assessment, the required lateral extent and depth of soil excavation weredetermined to reduce the risk to human health and the environment to acceptable levels within theSite. As stated above, soil excavation was completed in 1997. Risks in soils outside the excavationarea were estimated as between 1 x 10"7 and 1 x 10 . These estimated risks were consideredacceptable by EPA for certain exposure scenarios and thus, no remedial measures were required.
Future reuse of the Site may be limited by risk associated with potential exposure to remaining Site
contaminants in soil. In 1997, qualitative risk assessments as part of the Site Reuse Study (M&E,
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1998) were performed to evaluate the potential for Site reuse. The risk evaluation was performed
for the construction scenario and child trespasser scenario only. Risks were evaluated separately for
backfilled ash within the excavation area, the outlying Site areas where residual contamination exists
(based on results of the RI), and in the deep soils below the bottom depth of excavation.
6.2.1 Backfilled Ash
Residual contaminants are present in the backfilled ash at concentrations greater than the risk-based
concentrations for residential soils established by EPA, which suggests that the area should not be
used for residential purposes (M&E, 1998). However, the report concludes that the calculated risk
associated with incidental ingestion of backfilled ash suggests that the 12.5-acre area could be
developed for commercial or industrial use.
6.2.2 Outlying Areas
The Site Reuse Study includes a qualitative risk-based evaluation of the 20 acres of Site soils outlying
the excavation area. The study was based on data from the Rl and RI addendum (GHR, May 1985
and June 1986). The study concluded that the risks for worker and trespasser scenarios were withinacceptable levels and thus would not pose harm to future commercial/industrial workers or child
trespassers.
6.2.3 Soils Below the Bottom Depth of Excavation
A qualitative risk-based evaluation of soils below the bottom depth of excavation was also performed
as part of the Site reuse study. The evaluation was based on bottom-of-excavation soil data, and onsoil data from the RI at depths corresponding to or greater than the bottom-depth soils. The
evaluation only considered soils less than a depth of 15 feet, because it was assumed that contact with
deeper soils by workers would be unlikely. The study concluded that these soils would not be of harm
to future industrial or commercial workers, or to neighborhood children trespassing onto the Site.
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6.3 SEDIMENTS (OU-3)
An analysis of risk was performed in the Focused Feasibility Study and summarized in the ROD. The
analysis focused on direct exposure contact to arsenic, DDT, PAHs and chlordane in sediments.
Target cleanup levels were developed based on the analysis. The OU-3 remedial action has been
implemented consistent with the requirements of the ROD. Although contaminated sediments may
remain in areas downstream from the site, it is expected that natural degradative, depositional and
dispersal processes will gradually reduce contaminant concentrations. Long-term monitoring is being
performed in downstream areas on an annual basis to monitor sediment levels. In general, sediment
levels have remained below target public health cleanup levels. Ecological risks have been minimized
by placing organic fill in the stream bed where the contaminated groundwater runs under the river.
As a result of fish not being considered safe for consumption at this time, the Department of Public
Health has posted a health advisory for the Cochato River, Sylvan Lake and Ice Pond. The intent of
this advisory is to control any exposure through the consumption offish. Based on the need to collect
a sufficient amount of sediment and fish data from the river, a further evaluation will be performedfor the next five-year review of the long-term monitoring program to demonstrate the effectiveness
of the natural attenuation assumption in the ROD.
6.4 REPLACEMENT OF LOST DEMAND (OU-4)
The issue of risk for this operable unit is summarized in the following ROD statement (EPA, 1990):
"As this operable unit does not address contamination from the Baird & McGuire Site, there
were no Site risks associated with this fourth operable unit. Therefore, no risk assessment
was performed in connection with this study."
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SECTION 7.0
EVALUATION OF INSTITUTIONAL CONTROLS
Human health protection is further attained through the use of institutional controls that prevent or
reduce exposures to remaining contaminants. Primarily this involves the use of zoning, deed use
restrictions and fencing to protect and control access to the groundwater extraction and treatment
system and to subsurface materials. Currently there are no institutional controls at the site as a result
of the majority of the land not being available for re-use; however, EPA is in the process of
developing institutional controls at the site and expects to have them implemented in the near future.
The Baird & McGuire Superfund Site is largely within an Industrial I District, although some outlying
portions of the Site are zoned residential. Industrial zoning by-laws prohibit some uses, namely
residential uses, hospitals, day cares, and kindergartens. Allowable industrial-zoning uses that are
possibly consistent with other Site reuse limitations may include, but are not necessarily limited to:
governmental buildings; adult education centers; laboratory or research facilities; automobile repairshops; drive-in banks; and various industrial, wholesale and transportation uses. Local zoning
regulations are enforceable as long as they remain in effect.
A portion of the Site is also within a floodplain protection district and a substantial portion of the Site
has been delineated as wetlands. In accordance with the zoning bylaws, any use of a lot in anindustrial district that is overlaid in part or whole by the floodplain protection district requires a
special permit by the Board of Appeals. A large part of the Site is not suitable for industrialdevelopment due to the presence of these ecological resources (e.g., the river, the wetlands, and the
floodplain). Ecological protection from contact with contaminants can not, by character, be attainedthrough the use of institutional controls.
In order to allow for the ongoing operation of the groundwater extraction and treatment system andthe planned LNAPL recovery system, the following areas of the Site should not be relinquished for
potential reuse until groundwater remedial actions are complete: the entire area within the existing
fence surrounding the groundwater treatment plant; the area in the immediate vicinity of the
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groundwater recharge basins; and the area in the vicinity of the extraction wells and the extraction
well control building. In addition, groundwater within the Site boundary and the surrounding area
should not be used for any purpose. Also, activities near the monitoring and extraction wells must
be controlled to ensure compatibility with on-going remedial actions. Development in the vicinity of
the wells must not prevent access to, or compromise the integrity of, the wells. Should existing
fencing be removed, new fencing should be installed around areas where it is necessary to restrict
access.
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SECTION 8.0RECOMMENDATIONS
8.1 TECHNOLOGY RECOMMENDATIONS
Recommendations for continued operation, monitoring, evaluation and remediation of the operable
units are provided below.
8.1.1 Groundwater (OU-1)
The groundwater extraction/recharge system and GWTF is functioning so as to achieve the desired
goal of restoring the aquifer to levels that are protective of public health and the environment.
Documented decreases in plume size, significant contaminant mass removal from the plume area and
recharge of treated water at or below MCLs are indicators of such performance. EPA and USAGE
are attempting to address the sources of groundwater contamination by removing pools of LNAPL
existing at the Site. If successful, this effort could significantly decrease the time required to achieve
clean-up goals. EPA will continue to evaluate the performance of the LNAPL recovery system;
however, if total LNAPL removal cannot be achieved with the current system, many technologies that
are rapidly evolving may prove to be viable forms of treatment in the future. Applicability of evolving
technologies will be evaluated in the next five year review.
With strong evidence of natural biodegradation occurring, natural attenuation should also beconsidered as a viable approach for attenuating the plume and achieving cleanup goals. It is
recommended that future groundwater monitoring be tailored to collect data necessary for the
evaluation of natural attenuation. Recommended groundwater sampling parameters in addition to
data currently analyzed for includes:
• Dissolved Oxygen
• Methane• Sulfide
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• Oxidation/reduction potential (ORP)
• Iron (II) and Iron (III) in addition to total iron.
This data can be used in conjunction with data currently collected such as VOCs, SVOCs, chloride,
nitrate and sulfate concentrations to determine the efficacy of natural attenuation in restoring
groundwater to protective levels in an adequate time frame. Natural attenuation modeling and
contaminant transport modeling will likely be necessary to perform this evaluation.
The OU-1 ROD (EPA, 1986) recommends the following:
"After five (5) years of operation and evaluation, the Agency will prepare a supplemental
decision document to determine how long the groundwater extraction and treatment system
will remain operational and to document that the target levels are achievable."
The evaluation referenced in this ROD statement is premature at this time for the following reasons:
the incineration project significantly reduced the ability to pump groundwater at treatment capacity
for two years and enhancements to the groundwater treatment system are currently being implemented
(i.e., the LNAPL remediation system). Consequently, the ROD-specified evaluation of thegroundwater extraction and treatment system will be postponed until the next five-year review to
allow the LNAPL remediation system to operate for a period of time, and to determine how much
of the contaminant sources the LNAPL system can feasibly remove.
In summary, the following recommendations are made for OU-1:
1. Continue operation of the groundwater extraction and treatment system. Continue toevaluate extraction well performance and modify operation as necessary to maximize flowrate and optimize groundwater recovery.
2. Continue to operate the LNAPL remediation system and optimize LNAPL recovery. Thesuccess of the LNAPL remediation system in removing a significant source ofgroundwater contamination should be assessed. Depending on the success of remediation,
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the use of other technologies for removing LNAPL sources or enhancing groundwaterremediation may be necessary.
3. The ROD specified evaluation of the groundwater extraction and treatment system willbe postponed until after the LNAPL remediation system is operational in order todetermine how much of the contaminant sources the LNAPL system can feasibly remove.
4. Continue groundwater monitoring and yearly comprehensive evaluation of plumeconfiguration to track progress in plume remediation. The performance of the systemshould be evaluated in terms of plume size and containment by comparing plume mapsand observing trends in Site contaminants.
5. Natural Attenuation. Evaluate the extent to which natural attenuation is occurring ingroundwater and predict impact on plume restoration. Future groundwater monitoringshould be tailored to collect pertinent data necessary for evaluation of natural attenuation.The process of biodegradation may be a significant factor in total plume remediation onceLNAPLs are removed from the groundwater.
6. Restrict future land and water use consistent with the recommendations of the Site ReuseStudy.
8.1.2 Soils (OU-2)
The OU-2 remedy specified in the ROD has been completed. Qualitative risk analyses of residual
contamination have been performed and the Site has been deemed potentially suitable for commercialor industrial use provided that trespasser scenarios are limited. The vegetative soil layer will be
maintained and replaced as necessary to maintain cover over ash residue and prevent erosion.Continued monitoring and evaluation of restored wetlands wiH be performed to ensure that wetlandsremain viable. Recommendations for future evaluations are as follows:
1. Wetlands Restoration. Trends in wetlands restoration should be evaluated to determineif a viable wetlands has developed or will develop in a reasonable time frame. Evaluatecompliance with restoration requirements based on three years of monitoring data.
2. Site use. Assess the adequacy of legally-binding institutional controls. Evaluate Site useto confirm that only commercial and industrial activities have been performed at the Site,consistent with recommendations of the Site Reuse Report (M&E, 1998).
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8.1.3 Sediments (OU-3)
The OU-3 remedy specified in the ROD has been substantially completed. Contaminated sediments
have been treated and placed onsite as backfill. Long-term monitoring continues to be performed in
downstream areas as required by the ROD. Trends of contaminant levels cannot be determined at this
time due to lack of a statistically significant number of samples. As specified in the ROD, continued
monitoring and evaluation is required, specifically:
• Annual monitoring downstream of Union Street;
• Annual monitoring in the Mary Lee wetland;
• Annual monitoring of Ice Pond;
• Annual evaluation of monitoring results; and
• A five-year review of the annual evaluations and an assessment of the protectiveness of bothpublic health and the environment.
In addition, the following recommendations are made for future evaluations:
• Natural Attenuation. Evaluate the success of natural degrading, depositional, and dispersiveprocesses in reducing contaminant concentrations in sediment. The long-term monitoringprogram will be supplemented to provide all necessary information needed to demonstrate theeffectiveness of the natural attenuation assumption in the ROD. An evaluation will be performedafter the site remedies have stabilized and a sufficient amount of sediment and fish data have beencollected. It is expected that this evaluation will be performed for the next five-year review.
• Use of Cochato River Water. The ROD assumed that the Cochato River would not be used fora public water supply. There has been a recommendation by the town of Holbrook to considerusing the Cochato River as input to a public water supply. The risks associated with use of thiswater should be evaluated carefully before implementation of this proposal. Sampling of CochatoRiver Water will be required to check that levels are protective of human health.
8.1.4 Replacement of Lost Demand (OU-4)
An evaluation of this remedy will be performed after its implementation.
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8.2 STATEMENT ON PROTECTFVENESS
The remedies are protective of human health and the environment as long as use controls, as discussed
in the Site Reuse Report (M&E, 1998), remain in effect. The following sections describe
protectiveness of each separate remedy (operable unit) based upon its current status.
8.2.1 OU-1 - Groundwater
The current pathway for human health exposures has been eliminated as the contaminated aquifer is
no longer being used as a drinking water source. The aquifer is being remediated to mitigate a future
human health exposure pathway and data indicates that the plume of contamination is shrinking.
There is, however, a continuing hot spot of contamination and high concentrations continue to be
observed in overburden. For this reason, groundwater remedial actions need to continue. Residual
contaminants present in groundwater are not expected to affect protectiveness as long as limitations
on public use of groundwater are in place.
For continued protection, the groundwater treatment plant, recharge basins, monitoring wells,
extraction wells, LNAPL recovery system, and piping network must remain undisturbed.
Groundwater should not be used for any purpose, due to its contamination and to the negative impact
pumping could have on the effectiveness of the extraction and treatment system.
It is believed that groundwater discharges to the Cochato River do not occur during periods of fullplume containment. Actions have been taken to increase control of the plume. Placement of an
organic filter layer in the area where there is potential discharge of contaminated groundwater
provides further protection to the environment. Continued monitoring remains to be conducted to
determine protectiveness of the surface water and sediment from recontamination by groundwater.
Surface water sampling conducted in 1998 showed no detectable levels of site contaminants.
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8.2.2 OU-2- Soils
The ROD limited the excavation and treatment of soils to hot areas, and limited the depth of the
excavation due to complications of excavation into the water table. Residual soil contamination is
present on site, in terms of both areas beyond and below the excavation limits and in terms of the
backfilled ash. Protectiveness to human health is attained through controls of potential on-site use
activities. As long as the Site is not used for residential purposes and the appropriate fencing is
maintained to prohibit trespassing by children, human health protectiveness will be within the risk-
based concentrations established by EPA.
Protectiveness is achieved for future workers in a commercial or industrial use scenario.
Contaminants present at depths greater than 15 feet below grade are considered unlikely to be
contacted directly by individuals during future Site development activities, including construction and
utility work. Continued monitoring of wetlands is needed to confirm that the wetlands remain viable,
and therefore protected.
8.2.3 OU-3 - Sediments
Sediment with a high degree of contaminants was excavated and treated, and clean fill used to replace
materials excavated. To minimize disruption to wetlands, sediments were not removed from areas
of the river where contaminant concentrations were low. Although contaminated sediments mayremain, it is expected that natural degradative, depositional, and dispersal processes will gradually
reduce remaining concentrations in the sediment. Long-term monitoring will be conducted to evaluatecontaminant levels and their behavior over time.
8.2.4 OU-4 - Lost Demand
There are no protectiveness issues associated with this operable unit, because it does not address acontaminated media. Rather, this operable unit addresses a lost resource.
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8.3 NEXT REVIEW
Five-year reviews are done every five years at sites where contaminant levels remain at concentrations
that prevent unlimited, unrestricted use of the Site. Since remedial actions have not been completed
for all operable units, and since the remedy does not allow for unrestricted use of the Site, a follow-up
five-year review will be required. Five-year reviews are triggered by the date remedial actions are
initiated at any operable unit. When a five-year review is conducted at a time other than when it is
due, the next five-year review is due within five years of the time when it was originally required (U.S.
EPA, 1994). Each five-year review is to cover all operable units, whether or not remediation at that
unit is complete (EPA, 1994). The next five-year review for the Baird & McGuire Site should be
conducted in 2001. This will be a statutory review triggered by the implementation of remedialactions at OU-3.
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REFERENCES
GHR Engineering Associates, Remedial Investigation Report. Baird & McGuire Site. Preparedfor U.S. EPA, May 22, 1985.
GHR Engineering Associates, Feasibility Study Report, Baird and McGuire Site. Prepared forU.S. EP A, July 18, 1986.
Jones, D.S., G.W. Suter, II, and R.N. Hull, 1997. Toxicological Benchmarks for ScreeningContaminants of Potential Concern for Effects on Sediment-Associated Biota, 1997 Revision.Prepared by Environmental Sciences Division, Oak Ridge National Laboratory. ES/ER/TM-95/R4.
Long, E.R., D.D. McDonald, S.L. Smith, and F.D. Calder, 1995. Incidence of AdverseBiological Effects Within Ranges of Chemical Concentrations in Marine and EstuarineSediments. Environmental Management. Vol. 19., No. 1, pp. 81-97.
Long, E.R. and L.G. Morgan, 1990. The Potential for Biological Effects of Sediment-SorbedContaminants Tested in the National Status and Trends Program. NOAA TechnicalMemorandum NOS OMA 52. March 1990.
Massachusetts Department of Environmental Protection (MA DEP), 1995. The MassachusettsContingency Plan. 310 CMR 40.0000. Bureau of Waste Site Cleanup. December 15, 1995 andOctober 31, 1997 update.
McCulley, Frick & Oilman, Inc. (MFG), 1998. Light Non-Aqueous Phase Liquid FieldInvestigation Summary Report for the Baird & McGuire Superfund Site. Prepared for Metcalf &Eddy Services/PSG, January 30, 1998.
Metcalf & Eddy, Inc. (M&E), 1995. Evaluation of Extraction System Performance at theBaird & McGuire Site. Prepared by Metcalf & Eddy, Inc. for M&E Services, April, 1995.
Metcalf & Eddy, Inc. (M&E), 1989. Site Maintenance Plan for the Baird & McGuireGroundwater Treatment Plant and Extraction/Recharge System. Prepared by Metcalf & Eddy,Inc. for the U.S. Army Corps of Engineers, April 25, 1989.
Metcalf & Eddy, Inc. (M&E), 1998a. Evaluation of Potential Future Reuse Opportunities forthe Baird & McGuire Superfund Site. Prepared by Metcalf & Eddy, Inc., June 5, 1998.
Metcalf & Eddy, Inc. (M&E), 1998b. Letter to EPA regarding Plume Evaluation for 1997.Prepared by M&E, Inc., January 29, 1998.
Metcalf & Eddy, Inc. (M&E), 1999. Letter to EPA regarding Plume Evaluation for 1998.Prepared by M&E, Inc., March 3, 1999.
R-l
Metcalf & Eddy/Professional Services Group (M&E/PSG). Monthly process summary reportsfor the Baird &McGuire Groundwater Treatment Facility, April 1998 to December 1998.
New England Division of the Army, Corps of Engineers (NED), 1996. Baird &McGuireSuperfund Site Operating Unit #3 Monitoring Results. Prepared by the EnvironmentalEngineering and Hydraulics Branch, Water Control Division, Department of the Army, NewEngland Division, Corps of Engineers, Waltham, Massachusetts. September 1996.
New England Division of the Army Corps of Engineers (NED), 1997. Remedial Action Report.Baird & McGuire Superfund Site - Operable Unit 3, 1997.
New England Division of the Army Corps of Engineers (NED), 1998. Results of Third Year ofLong-Term Monitoring of Sediments and Soils at Baird & McGuire, 1998.
OHM Remediation Services Corporation (OHM), 1997. Site Closure Plan. Baird & McGuireSuperfund Site On-Site Incineration Project, November, 1993.
OHM Remediation Services Corporation, (OHM), Final Site Restoration Plan. Baird &McGuire Superfund Site On-Site Incineration Project, November, 1993.
Persaud, D., R. Jaagumagi, and A. Hayton, 1993. Guidelines for the Protection andManagement of Aquatic Sediment Quality in Ontario. Ontario Ministry of Environment andEnergy. August 1993.
Sample, B.E., D.M. Opresko, and G.W. Suter, II, 1996. Toxicological Benchmarks for Wildlife:1996 Revision. Prepared by Environmental Sciences Division, Oak Ridge National Laboratory.ES/ERATM-96/R3.
Suter, G.W., II. and C.L. Tsao, 1996. Toxicological Benchmarks for Screening PotentialContaminants of Concern for Effects on Aquatic Biota: 1996 Revision. Prepared byEnvironmental Sciences Division, Oak Ridge National Laboratory. ES/ER/TM-96/R2.
U. S. Environmental Protection Agency (USEPA), 1986. Record of Decision (ROD) for the Baird &McGuire Superfund Site, OU1 and OU2, Groundwater Extraction and Treatment plus SoilExcavation and Treatment, September 30, 1986.
U. S. Environmental Protection Agency (USEPA), 1989. Record of Decision (ROD) for the Baird &McGuire Superfund Site, OU3, Sediment Excavation and Treatment, October 9, 1989.
U. S. Environmental Protection Agency (USEPA), 1990. Record of Decision (ROD) for the Baird &McGuire Superfund Site, OU4, Donna Road Well Field, September 27, 1990.
U. S. Environmental Protection Agency (U.S. EPA), 1991. Structure and Components of Five -Year Reviews. OSWER Directive 9355.7-02. May 23, 1991.
R-2
U. S. Environmental Protection Agency (U.S. EPA), 1994. Supplemental Five-Year ReviewGuidance. OSWER Directive 9355.7-.02A, EPA/540/F-94/004. August 1994.
U. S. Environmental Protection Agency (USEPA), 1996. Ecotox Thresholds. U.S. EPA Officeof Emergency and Remedial Response, ECO Update, Publication 9345.0-12FSI. January 1996.
U. S. Environmental Protection Agency (U.S. EPA), 1998. Scope of Work for Baird & McGuireSuperfund Site - First Five-Year Review. June 1998.
U.S. Geological Survey (USGS), 1998. Potential for Advection of Volatile Organic Compoundsin Groundwater to the Cochato River, Baird & McGuire Superfund Site, Holbrook,Massachusetts. March and April 1998.
R-3
FIGURES
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TABLE 2-3 HISTORICAL CONCENTRATIONS AT SITE WELLS
OverburdenWells
BM-32BBM34ABM-34BBM-35BM-2BM-4ABM-7BM-8BM-10BM-13BBM-14BM-17BM-I8RBM-20RBM-21BM-23RBM-30BM-31BBM-37BM-38901A902B902A903B904B908909A910A910B91IB912B912A913A914C914B914A91 5A91SB919M-lM-2M-3M-5M-6M-7M-7M-8
ReplacementWell
MW-97-20MW-97-21MW-97-22MW-97-23MW-97-17
MW-97-18
MW-97-19
MW-97-24MW-97-25
MW-97-3
MW-97-4
MW-97-9MW-97-8
MW-97-12MW-97-1 1MW-97-10MW-97-1 3MW-97-1 4
MW-97-1 5
MW-97-27
WellType
SDSDSDSDSDSDSDSDSDSDSDSDSDSD
SDSDSDSDSDSDSDSDSDSDB
SDT
SDSDSDSDSDSDSDTT
SDSD
T/WBSDSDSD
T/WBSD
T/WBSD
8/88,9/88TotalVOCs(Ppb)
13490
14590
13.7
787355.974202293
1.4
660140.2
124.9
731911540
ND49020
ISO
2838
9.4
101697860
4/94TotalVOCs(PPb)
ND
ND116
ND5
5
10/94TotaJVOCs(PPb)
1224
2.4
1.45
5.4
5
3/95TotalVOCs(PPb)
4/95TotalVOCs(PPb)
5630
23.924.9736
ND
ND11.41.6
ND
ND18.3
1814.9
42
904511725
148.6
11.9
18.5
8/97,9/97,10/97TotalVOCs(PPb)
392514763317
655.0
1.618.0ND
44.912.328.2
8.70.1
10.30.9
1.80.4
34.07.7
10120ND
15.610.81.41.69.5
50051245
8.47609.47.4
15.0630NDND1.83.9
11.6
8/98,9/98,10/98TotalVOCs(PPb)
0.52303
6.16470.0
238.0
ND4.1ND6.71.9
NDNDNDND7.5
1.5ND4.52.5
487CND
1.11.42.2
NDND1.8
1918.C8.2
1938.C4.00.63.89.45.5
935NDNDND0.8ND
Tab2 198 6/14/99
TABLE 2-3 HISTORICAL CONCENTRATIONS AT SITE WELLS
OverburdenWells
M-8M-9M-10M-llM-12EW-1EW-2EW-3EW-4EW-5EW-6EW-7
BedrockWells
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ReplacementWell
WellType
T/WBT
T/WBSDSD
T/WBSDSD
T/WBSDSDSD
8/88.9/88TotalVOCs(ppb)
4/94TotalVOCs(Ppb)
7
38146
4467377653
2829
10/94TotalVOCs(ppb)
0.8
48.962.5
4260375780
4683
3/95TotalVOCs(ppb)
49.210
2785229575
2767
4/95TotalVOCs(ppb)
NDND
27.619
11870435
726.83061.5
8/97,9/97,10/97TotalVOCs(ppb)
10.45.71.
21.21104.0
11.019.9
2254.0
8/98,9/98,10/98TotalVOCs(ppb)
ND
ND
4.3785.0
2.56.3
1956.0142.7
ReplacementWell
MW-97-4MW-97-5
MW-96-6MW-97-7
BRBRBRBRBRBRBRBRBRBRBRBRBRBRBRBRBRBRBR
198.8
1811590
012001360
ND180
24.9768.2
13.125.1
NDND
10
ND
4ND
10
3.8
5.418
2.72.7
50.73.7
ND
ND15.410.52.519
25.7ND
8.316.70.8
13.1
ND
2.91.6
14.9
4.27.0
10.12.2
ND
1.21.7
ND7.73.60.6
Notes: SD: stratified driftT: tillBR: bedrock
T/WB: till and weathered bedrockND: non-detectBlank Space: not sampled
Tab2 198 6/14/99
TABLE 2-3 HISTORICAL CONCENTRATIONS AT SITE WELLS
OverburdenWells
BM-32BBM34ABM-34BBM-35BM-2BM-4ABM-7BM-8BM-10BM-13BBM-14BM-17BM-18RBM-20RBM-21BM-23RBM-30BM-31BBM-37BM-38901A902B902A903B904B908909A910A910B911B912B912A913A914C914B914A915A91SB919M-lM-2M-3M-5M-6M-7M-7M-8
ReplacementWell
MW-97-20MW-97-21MW-97-22MW-97-23MW-97-17
MW-97-18
MW-97-19
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MW-97-3
MW-97-4
MW-97-9MW-97-8
MW-97-12MW-97-11MW-97-10MW-97-13MW-97-14
MW-97-15
MW-97-27
WellType
SDSDSDSDSDSDSDSDSDSDSDSDSDSD
SDSDSDSDSDSDSDSDSDSDB
SDT
SDSDSDSDSDSDSDTT
SDSD
T/WBSDSDSD
T/WBSD
T/WBSD
8/88,9/88Total
SVOCs(ppb)
22320
15440
ND
ND250
6570840
13
6527
94
852049200
NDNDNDND
34ND27
1150010440
4/94Total
SVOCs(ppb)
ND
NDND
2
NDND
4
10/94Total
SVOCs(ppb)
1938
ND
NDND
ND
ND
3/95Total
SVOCs(ppb)
4/95Total
SVOCs(PPb)
9098
ND6297
110
NDNDND
6
NDNDNDNDNDND
734855
132
ND
ND
8/97,9/97,10/97Total
SVOCs(PPb)
72843482
6869006452.0
16.2NDND3.0ND
31.7NDND
23.4ND
ND573.3
74.65.2
4578ND
NDNDNDNDND
71412937
2.83115NDND5.4
30305.05.5NDNDND
8/98,9/98,10/98Total
SVOCs(PPb)
5.76113.0
46.9426202652.0
4.3NDND4.2ND14.6NDND2.7
ND
ND66.0
6.7ND
2049ND
NDND3.6
123.1NDND
6032.046.7
5286.03.0
9NDNDND
259310.1NDNDNDND
Tab2 198 6/14/99
TABLE 2-3 HISTORICAL CONCENTRATIONS AT SITE WELLS
OverburdenWells
M-8M-9M-IOM-llM-12EW-1EW-2EW-3EW-4EW-5EW-6EW-7
BedrockWells
BM-13901902-1902-2903904905908909910911912913M-4M-6M-7M-8M-10M-12
ReplacementWell
WellType
T/WBT
T/WBSDSD
T/WBSDSD
T/WBSDSDSD
8/88,9/88Total
SVOCs(ppb)
4/94Total
SVOCs(ppb)
7
7891
12127111925164073
10/94Total
SVOCs(ppb)
ND
628870581
19154884
ND
3/95Total
SVOCs(ppb)
34ND
10230681
18594400
4/95Total
SVOCs(ppb)
NDND4679
7967267531
4511
ReplacementWell
MW-97-4MW-97-5
MW-%-6MW-97-7
BRBRBRBRBRBRBRBRBRBRBRBRBRBRBRBRBRBRBR
122
6180590
00
3320NDND
1593275
103
ND
ND
ND1
ND
ND
ND2
67ND
923
ND
NDNDNDNDNDNDNDNDND
22
8/97,9/97,10/97Total
SVOCs(ppb)
ND8.32.7
775166
26328
4800
ND
15.0NDND
4.2NDNDND
8/98,9/98,10/98Total
SVOCs(ppb)
ND
ND3455.0
6.4178.9
2885.0471.8
ND
2.8NDND
3.3NDNDND
Notes:
Tab2 198 6/14/99
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'rt1^fo\Scs
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•O
1<u
•s00
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'§Q
disc
harg
ed b
ack
to g
roun
dwat
er a
nd m
eets
the s
tand
ards
for t
his r
ule.
Grou
ndwa
ter
ub*iSfl
1_oo00 .!a 3*" ^SC T32 M11») gD O«- C^ °i-sv a>% w(« JDe "PS 8r* ^6 O
S §"•3 fe.
cont
amin
atio
n re
mai
ns, h
owev
er, a
ndtre
atm
ent i
s exp
ecte
d to
con
tinue
for s
ever
alye
ars.
Grou
ndwa
ter s
till r
equi
res
rem
ediat
ion
unde
r thi
s rul
e. |
The
Site
is lo
cated
in a
des
igna
ted
Mas
s.W
ellh
ead
Prot
ectio
n A
rea.
Drin
king
wat
ersta
ndar
ds a
re a
pplic
able
to g
roun
dwat
ersu
pplie
s sur
roun
ding
the B
aird
& M
cGui
reSi
te.
MM
CLs
lbrO
U-1
are
pro
vide
d in
Tabl
e 4-
2. C
onsti
tuen
ts in
Site
gro
undw
ater
still
exce
ed c
riter
ia fo
r ars
enic
, diel
drin
,V
OCs
, and
Sem
i-VO
Cs.
Grou
ndwa
ter
treat
men
t is
curr
ently
bei
ng c
ondu
cted
. Th
etre
ated
gro
undw
ater
is b
eing
disc
harg
edba
ck to
gro
undw
ater
and
mee
ts th
e sta
ndar
dsfo
r thi
s rul
e. G
roun
dwat
er c
onta
min
atio
nre
mai
ns, h
owev
er, a
nd tr
eatm
ent i
s exp
ecte
d
c >< °SS (3 •£•g .s * >,
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to c
ontin
ue fo
r sev
eral
year
s. Si
tegr
ound
wat
er re
quire
s co
ntin
ued
rem
edia
tion
to p
rote
ct ou
tlyin
g gr
ound
wate
r sup
plie
s.
Five
-Yea
r Rev
iew
B
RO
D re
quire
men
ts sy
nops
is a
nd c
onsi
dera
tion
RW
S
i4-t
2CD
§»
«•»S19S?a
bh.£'§53<•s
Med
ia ai
u ^
MCL
s an
d no
n-ze
ro M
CLG
s ha
ve th
e sta
tuof
ARA
Rs fo
r are
as o
utsid
e of
the
Baird
&M
cGui
re S
ite b
ound
arie
s. Ze
ro M
CLG
s ar
crite
ria to
be
cons
ider
ed.
Man
y of
the
MCI
and
MCL
Gs h
ave
chan
ged
since
RO
Dco
mpl
etio
n. M
CLs/M
CLG
s Ib
rOU
-l ar
epr
ovid
ed in
Tab
le 4
-2.
The
mos
t stri
ngen
tnu
mer
ical
sta
ndar
ds a
nd c
riter
ia ar
ehi
ghlig
hted
. G
roun
dwat
er re
quire
sco
ntin
ued
rem
edia
tion
unde
r thi
s rul
e to
prot
ect o
utly
ing
reso
urce
s.
Max
imum
cont
amin
ant l
evel
goa
ls (M
CLG
s) a
rehe
alth
-bas
ed cr
iteria
that
are
to b
e con
sider
ed fo
rdr
inki
ng w
ater s
ourc
es a
s a r
esul
t of S
ARA
. Th
ese
goals
are
ava
ilabl
e fo
r a n
umbe
r of o
rgan
ic a
ndin
orga
nic
cont
amin
ants.
Proj
ecte
d gr
ound
wat
er c
once
ntra
tions
wer
e co
mpa
red
to th
eir M
CLG
s in
doc
umen
ts su
ppor
ting
the
ROD.
o•o *5 "§S a J5ra TO j"£ C *Ki e-g5 &u"o a. oai < co
CO
S —II!£ Si*5 cd
i C -"""'3 ^
lls8"SCO
•o<rf'S u« O
51Ii•o -a5 c£ «
! « . , . ; ) ^ x
Thes
e re
gula
tions
cla
ssify
the
surfa
ce w
ater
of th
e Com
mon
wea
lth a
ccor
ding
to th
e us
e;of
thos
e w
ater
s. Th
e w
etla
nd h
as a
Clas
s A
wat
erw
ay cl
assif
icat
ion.
Cla
ss A
wate
rs ar
tde
signa
ted
as h
abita
t for
fish
, oth
er a
quat
ican
d wi
ldlif
e, an
d fo
r prim
ary
and
seco
ndar
yco
ntac
t rec
reat
ion.
The
stat
e su
rface
wate
rm
inim
um c
riter
ia fo
r Cla
ss A
wat
ers
are
cons
isten
t with
fede
ral A
WQ
C. T
hese
rule
are
appl
icab
le to
the
Coch
ato
Rive
r and
unna
med
bro
ok.
•a .. .a "s
DEP
Sur
face
Wat
er Q
ualit
y St
anda
rds
are g
iven
for
diss
olve
d ox
ygen
, tem
pera
ture
incr
ease
, pH
, and
tot
colif
orm
and
ther
e is
a na
rrativ
e req
uire
men
t for
toxi
cant
s in
toxi
c am
ount
s. In
the
abse
nce
of a
state
stand
ard
for a
com
poun
d, fe
dera
l AW
QC
woul
d be
appr
opria
te.
Requ
irem
ents
wer
e co
nsid
ered
; how
ever
, no
num
ersta
ndar
ds e
xist
for c
onta
min
ants
foun
d in
Site
grou
ndw
ater
whi
ch w
ould
be
disc
harg
ed to
surfa
cew
ater
. Fe
dera
l AW
QC
will
be u
sed
in th
e ab
senc
e i
narra
tive s
tanda
rds.
u•irou1<,
«1y «<s "Sb 3wa 55 >oS £>3o a ^slei1aort H W
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8•S3 as *^0 C
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S;
V06
vi
V
.5
ROD
requ
irem
ents
syno
psis
and
cons
ider
atio
lR
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Cfl
ic«QO06
•*SSLd
1f^06
1
9
1
1
CERC
LA S
ec. 1
21 (
d)(2
)(A
) Sp
ecifi
cally
state
s th
at re
med
ial a
ctio
ns s
hall
at le
ast
atta
in fe
dera
l AW
QC
esta
blish
ed u
nder
the
Clea
n W
ater A
ct if
they
are r
elev
ant a
ndap
prop
riate
. AW
QC
for b
oth
prot
ectio
n of
hum
an h
ealth
from
inge
stion
of w
ater
and
aqua
tic o
rgan
isms a
re re
leva
nt a
ndap
prop
riate
. Cu
rrent
AW
QC
are l
isted
inTa
ble 4
-7.
•S"3
Fede
ral A
WQ
C ar
e hea
lth-b
ased
and
eco
logi
cally
base
d cr
iteria
whi
ch h
ave
been
dev
elope
d fo
r 95
carc
inog
enic
and
non
-car
cino
geni
c co
mpo
unds
.
AW
QC
wer
e co
nsid
ered
in c
hara
cter
izin
g pu
blic
hi
risks
to a
quat
ic o
rgan
isms d
ue to
con
tam
inan
tco
ncen
tratio
ns in
surfa
ce w
ater a
t Coc
hato
Riv
er.
Beca
use t
his
water
is n
ot u
sed
as a
drin
king
wate
rso
urce
, the
crite
ria d
evelo
ped
for
aqua
tic o
rgan
ismpr
otec
tion
and
inge
stion
of c
ontam
inate
d aq
uatic
orga
nism
s w
ere
cons
ider
ed.
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ide
ambi
ent a
ir qu
ality
stand
ards
for t
he C
omm
onw
ealth
, sta
ndar
dsfo
r dus
t are
cont
aine
d in
310
CM
R 7.0
9, an
310
CMR
7.08
prov
ides
inci
nera
tor
stand
ards
. Th
ese
stand
ards
wer
e us
ed in
esta
blish
ing
disc
harg
e lim
its fr
om th
ein
cine
rato
r. Th
e in
cine
rato
r has
bee
ndi
sman
tled
and
thes
e req
uire
men
ts ar
e no
long
er a
pplic
able
, rel
evan
t or a
ppro
pria
te.
Shou
ld ex
cava
tion
occu
r in
the
futu
re, d
ust
cont
rol s
tand
ards
wou
ld n
eed
to b
ere
cons
ider
ed.
i>r*4
Thes
e sta
ndar
ds w
ere p
rimar
ily de
velo
ped
to re
gul;
stack
and
auto
mob
ile em
issio
ns.
oB
jo pej•c"§ |itsa, < 2
. s S.Sa o o<: 3 OO
1 *-^ 'CQ f^ O
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ncin
erat
or h
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een
dism
antle
d an
dth
ese r
equi
rem
ents
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no lo
nger
app
licab
lere
leva
nt o
r app
ropr
iate
. Sh
ould
exc
avat
ion
be c
onsid
ered
in th
e fu
ture
, the
se v
alue
swo
uld
need
to b
e rec
onsid
ered
.
g<y, ,O
Thes
e sta
ndar
ds w
ere
issue
d as
con
sens
us s
tanda
rdco
ntro
lling
air
qual
ity in
wor
kpla
ce e
nviro
nmen
ts.
TLVs
coul
d be
use
d to
asse
ss S
ite in
halat
ion
risks
1so
il re
mov
al o
pera
tions
.
u £CQ oo e
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inci
nera
tor h
as b
een
dism
antle
d an
dth
ese
requ
irem
ents
are
no lo
nger
app
licab
lere
leva
nt o
r app
ropr
iate
.
o*£
AALs
wer
e co
nsid
ered
whe
n as
sess
ing
the
signi
fies
of m
onito
red
and
mod
eled
resid
entia
l con
tamin
atiol
from
ak e
miss
ions
.
pa oo e
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uke
Site,
Tab
le 1
, Rec
ord
of D
ecisi
orcte
d cr
itica
l con
tamin
ants
at th
e Bair
d &
McO
"3co
b•§,3
s -<4- O
tS .£•i &G U, _ , o> '>r U-U O
*~* C/5
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. *^-
p] ^32 SX — '&S•s 1C O M«J B--Iy> u 2
sll
of 15
ppb
(0.01
5 m
g/L)
at t
he ta
p, O
.Cn t
o inf
orm
cons
umer
s abo
ut ho
w to
nW
A M
CLs d
urin
g 19
97 g
roun
dwat
er
MCL
for l
ead
was r
eplac
ed by
an ac
tion
level
<m
ent;
b) u
nder
take a
publ
ic ed
ucati
on pr
ogra
n3-
com
poun
ds d
etecte
d at
levels
exce
edin
g SD
1
o "c5 jcF to O
Ur-pcscs
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H?'i'5o
!3og,
i•c
orga
nic
and
orga
nic
chem
ical
s" re
qui
se co
mpo
unds
are i
dent
ified
as "u
nreg
ulate
d in
sF
&S.c0ueccIU
1351cu
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Ul
Sta?•aG3
6U(«1os
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efin
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Site
Main
tenam
for th
e U.S
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r Dist
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(om
poun
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re co
ntam
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dica
tor c
ompo
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pril
25, 1
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D ?.
1 of D
ecisi
on:
2-m
ethy
lnap
thal
ene,
ac•en
e, na
ptha
lene,
phen
anth
rene
, and
p:o
mpo
unds
liste
d in
Tab
le 2
of 9
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86 R
ecor
da,h
)ant
hrac
ene,
fluor
ene,
inde
no(l,
2, 3
-cd)
pyr
" "X*Hr< Oi-H N< c
"frH
a FIV
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The
Fish
and
Wild
life C
oord
inat
ion
Act
(16
USC
661
et. se
q.) re
quire
s th
at, b
efor
e iss
uing
a fe
dera
l
0
3u"o.•3*
<H ui cs .§•2 SC -^CO T3
tE U
perm
it or
und
erta
king
any
fede
ral a
ction
that
caus
esth
e im
poun
dmen
t (wi
th c
erta
in e
xem
ptio
ns),
dive
rsio
n, o
r oth
er co
ntro
l or m
odifi
catio
n of
any
-,VO
[Jc/i
,
body
of w
ater
, the
app
licab
le fe
dera
l age
ncy
mus
tco
nsul
t with
(1) t
he a
ppro
pria
te st
ate
agen
cyex
erci
sing
juris
dict
ions
ove
r wild
life r
esou
rces
; (2)
the
U.S.
Fish
and
Wild
life S
ervi
ce (U
SFW
S) a
nd| t
he N
atio
nal M
arin
e Fish
erie
s Se
rvice
, with
in th
eD
epar
tmen
t of I
nter
ior;
and
(3) t
he N
atio
nal M
arin
eFi
sher
ies S
ervi
ce, w
ithin
the
Dep
artm
ent o
fCo
mm
erce
. Th
e Ba
ird &
McG
uire
Site
inclu
des
signi
fican
t wet
land
s. Th
is re
quire
men
t is
addr
esse
dun
der C
WA
Sec
tion
404.
0 C
*3 *-" *?J'3-2E D O
if .1 "3 "3U CX $3 ^D, u «> "-
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Thes
e req
uire
men
ts ar
e pro
mul
gate
d un
der
Wetl
ands
Pro
tect
ion
Law
s, wh
ich re
gula
te d
redg
ing,
fillin
g, a
lterin
g, o
r pol
lutin
g w
etla
nds.
Wor
k wi
thin
100
feet
of a
wet
land
is a
lso re
gula
ted
unde
r thi
s
u30
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requ
irem
ent.
The r
equi
rem
ent d
efin
es w
etla
nds
base
d on
veg
etatio
n ty
pe a
nd re
quire
s th
at eff
ects
onwe
tland
s be m
itiga
ted.
u_.•f
cc
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Lc ^^>
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If al
tern
ativ
es re
quire
that
wor
k be
com
plet
ed w
ithin
100
feet
of a
defin
ed w
etla
nd, t
hese
regu
latio
ns a
reto
be
cons
ider
ed.
Miti
gatio
n of
impa
cts
on w
etla
nds
are
addr
esse
d un
der C
WA
404
.
u<Q
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The C
ERCL
A p
roce
ss g
ener
ates
eva
luati
repo
rts th
at ar
e equ
ivale
nt to
thos
e req
uii
To e
limin
ate
redu
ndan
cy, t
hese
rule
s ar
e
CO
1 -aS cu 1
Thes
e re
gula
tions
requ
ire th
at all
acti
ons
spec
ified
thre
shol
d es
tablis
hed
unde
r MI
requ
iring
fund
ing,
or re
quiri
ng a
majo
r p
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111£ < z
u O< m^ ^^^•-^ ££ ^i
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cons
ider
ed A
RAR.
.1 o0 ^
prep
are
and
file a
n En
viro
nmen
tal N
otif
Form
(EN
F).
MEP
A h
as d
eterm
ined
tha
0-••<05<
8— iiu
H
repo
rts g
ener
ated
durin
g Ba
ird &
McG
uiin
vesti
gatio
ns e
ssen
tially
cons
titut
e an
Envi
ronm
ental
Impa
ct Re
port.
o
u
Dur
ing
deve
lopm
ent o
f alte
rnati
ves i
mpa
wetl
ands
and
floo
dplai
ns w
as e
valu
ated.
o
•a ^C 3
« ""f S
To m
itiga
te un
avoi
dabl
e wetl
and
impa
ct;
Resto
ratio
n Pl
an w
as d
evelo
ped.
The
pi;
o
'C i— -o c3 O
Pursu
ant t
o th
ese r
egul
ation
s, DE
M ha
s ;ad
opt o
rder
s res
trict
ing
activ
ities
or u
ses
<aca0
"5.<
BeU
Ss
llllQ CQ
crt
c.gC cp -^
the r
esto
ratio
n of
fore
sted
and
scru
b/sh
ruwe
tland
s, in
clud
ing
a sm
all p
eat b
og, a
nc3 "SS* "
wetl
ands
in o
rder
to p
rese
rve
and
prom
olsa
fety
, pro
perty
, wild
life a
nd w
ater r
esou
li 8T3
^ ^IgM ^
w •§B- o
^0
« ^"g •—-5 ^
inter
mitt
ent s
tream
impa
cted
by th
e rem
eTh
e pla
n als
o re
quire
s ann
ual m
onito
ring
flood
plain
area
s.
o•5 _"P 5.2^3 e^
wet
land
s for
thre
e ye
ars
follo
wing
com
plre
stora
tion
effo
rts.
This
annu
al m
onito
ril
><
o1DE
M w
as a
ppra
ised
of re
med
ial a
ction
sim
pact
inlan
d w
etia
nds.
"85b
<s> >5 u•^ ^
!l
11*%P 0tuS Qg O« *ll1^^> «^3a, -ao ^o !2 in
the
next
five
-yea
r rev
iew
.
oo
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uz<QSOQZ
o
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ERA
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<!•§2 S£ £
RCRA
-def
ined
liste
d or
cha
ract
erist
ic h
azar
dous
was
te (4
0 CF
R 26
1) fa
cility
mus
t be
desig
ned,
cons
tructe
d, o
pera
ted, a
nd m
aintai
ned
to p
reve
ntwa
shou
t by
1 00-
year
floo
d.
aG Q_
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as §
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Fede
ral a
genc
ies sh
all ta
ke a
ction
to re
duce
the
risk
of fl
ood
loss
, min
imize
the
impa
ct o
f flo
ods o
nhu
man
safet
y, he
alth
and
welfa
re, a
nd re
store
and
pres
erve
the n
atura
l and
bene
ficial
valu
es o
fflo
odpl
ains.
Fede
ral a
genc
ies sh
all al
so ev
aluate
pote
ntia
l effe
cts o
f acti
ons i
n flo
odpl
ains a
nd en
sure
cons
ider
ation
of f
lood h
azar
ds an
d flo
odpla
inm
anag
emen
t. If
actio
n is
taken
in fl
oodp
lains
,alt
erna
tives
to av
oid a
dver
se ef
fects,
and
min
imize
poten
tial h
arm
mus
t be t
aken
.
J3u"Sf*
<
X&
!-§5 ~ O 4> y
CL, 12 , — ,x O C <I'a > •> a
HillE ^ ^^ • ^?[T) f_) vp <r
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ll2 *oOS O
*"" |_,
it su £
'E cy 00
u"ic ™O C^ CS
^ c
5 "^< -1 cpi oo o
-11le ®P c^-0
Act
ions
in "b
orde
ring
land
subj
ect t
o flo
odin
g" sh
allpr
ovid
e co
mpe
nsat
ory
stora
ge fo
r flo
od st
orag
evo
lum
e los
t as a
resu
lt of
the p
rojec
t, sh
all no
tre
stric
t flo
ws so
as t
o ca
use
an in
crea
se in
floo
dsta
ge o
r velo
city,
and
shall
not
impa
ir its
cap
acity
topr
ovid
e im
porta
nt w
ildlif
e hab
itat f
uncti
ons o
r alte
rve
rnal
poo
l hab
itat.
Act
ions
in "
isolat
ed la
ndsu
bjec
t to
flood
ing"
shall
not
resu
lt in
floo
d da
mag
ebe
caus
e of l
atera
l disp
lacem
ent o
f wate
r tha
t wou
ldot
herw
ise b
e co
nfin
ed w
ithin
the
area
, adv
erse
effe
cts o
n wa
ter su
pply
, adv
erse
effe
cts o
n th
eca
paci
ty o
f the
area
to p
reve
nt g
roun
dwat
erpo
llutio
n, o
r adv
erse
effe
cts o
n ve
rnal
poo
l hab
itat.
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U
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5 J2 B* — ce0 f fc
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No n
ew fa
cility
may
be lo
cated
in a
n ar
ea su
bjec
flood
ing,
with
in th
e w
ater
shed
of c
lass A
or
claSA
segm
ent o
f a su
rface
wate
r bod
y (u
nles
s DE
Ba
1 '&5 « s.S li J£o! § <
(* *f3 Ji0 3
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111<_> C/3 *po> JB -S^3 -S X!
•o "S§ S x
dete
rmin
es th
ese
is no
feas
ible
alter
nativ
e), o
n 1;
over
lyin
g an
actu
al pl
anne
d, o
r pot
entia
l pub
licpr
ivat
e drin
king
wate
r sou
rce,
or i
n th
e flo
w pa
t
txUo*3? f^C-o« ^S 0-i <?cfl o
U^^^
1c•acoO
grou
ndw
ater
supp
lyin
g w
ater t
o an
exist
ing
well
Varia
nces
and
exce
ptio
ns a
re n
oted
in th
ere
gula
tions
.
§
The i
mpa
ct of
the c
onstr
uctio
n an
d op
erati
on o
f
SuSPb00
U'C
iuien
•§
JSB' V*
§ disp
osal
facil
ity o
n th
e flo
odpl
ain m
ust b
eco
nsid
ered
dur
ing
the
deve
lopm
ent o
f rem
edial
alte
rnat
ives
.
Bc/5 -o -a c u_ u J2 § 5 o _5 -b £• -s S ^ c SS 3 « O O C — u Ur T C T ' O c d ^ _ ~ o £" " C o _ , ^ S > J: TI* S= S-l o-S M"? |Bf = -sl ^t-P-2S . S - - § § | - C E S ^ gf £!§?»! s i i g• o . S ^ - S g w g j j KJ l l S ^ l l g S fS §* 1 &-8 1 - = • "« ^ l i l §s s§ >• ^ o o E S ^ ^ ^ S ' - s- £ T 3 t ? » & BJ blS0"1 C1 11 s,|-i 8,^11^ ^ i s i i r " " ^ ' ?= « s ^ - 3 S s H t : o Sg ^ c ^ b ^ 5 < S - S o= C L o u ' « o t i r ; ' - c ;o c - ^ c — ^ b ° -S s»M.§ grf §1^ g - 8 - 8 .: | g t s p g - a ^ ' g a S 5 ' 8g o j 5 J a b Q , : f l f e Q < Q . cP S S ' S S S ' S l f l lH ^ ^ ^ . S f S l j i g g . s
<OH rtco m . ™
A wa
ter q
ualit
y ce
rtific
ation
is re
quire
d fo
r any
activ
ity th
at in
volv
es d
redg
ing
in a
wate
rway
or
wed
and
in M
assa
chus
etts
that
is als
o su
bjec
t to
U.S.
Arm
y Co
rps
of E
ngin
eers
CW
A Pe
rmit,
a ]
NPD
ES p
erm
it, o
r a M
assa
chus
etts
Wed
ands
01
Wate
rway
s Ord
er o
f Con
ditio
ns o
r Lice
nse.
App
licat
ion
mus
t be
mad
e to
DEP
to ce
rtify
thai
prop
osed
pro
ject
will
atta
in o
r main
tain
the
Mas
sach
uset
ts W
ater
Qua
lity
Stan
dard
s and
min
imize
adve
rse
impa
cts to
wate
r qua
lity.
u•SCOo"5.3-<.BO
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Thes
e re
quire
men
ts ar
e re
leva
nt a
ndap
prop
riate
to o
pera
tions
at t
he g
roun
dwat
etre
atmen
t fac
ility
. Al
thou
gh th
e GW
TP d
oeno
t tre
at RC
RA-d
esig
nate
d ha
zard
ous
was
te, i
t doe
s ge
nera
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idua
lth
at ma
y, at
times
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t the
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te.
Gen
erat
orre
quire
men
ts ar
e th
eref
ore b
eing
com
pile
dwi
th a
t the
facil
ity.
A co
ntin
genc
y pla
n is
avai
labl
e at
the
Site
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tline
s the
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ker
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genc
y pro
cedu
res
to b
e use
d fix
expl
osio
ns, f
ires,
etc.
Thi
s reg
ulati
ore
quire
s tha
t thr
eats
to p
ublic
hea
lthen
viro
nmen
t be
min
imize
d -
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tus:
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r Sta
tus:
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ve ac
tion
rule
s hav
ech
ange
d sig
nific
antly
sinc
e th
e RO
D w
asiss
ued.
A g
roun
dwat
er m
onito
ring
prog
ram
has b
een
impl
emen
ted at
the
Site
. M
onth
lywa
ter le
vel m
onito
ring
and
quar
terly
grou
ndw
ater
sam
plin
g is
perfo
rmed
und
erth
is pl
an.
Thes
e re
quke
men
ts ar
e rel
evan
tan
d ap
prop
riate
to th
e Site
due
to it
s for
mer
use.
Subs
tant
ive r
ules
are
bei
ng co
mpl
iedwi
th.
o ao^S §X! C g- ,_,
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n de
tails
requ
kem
ents
grou
ndw
ater m
onito
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prog
ram
toin
stalle
d at
the S
ite.
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tus:
ARA
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r Sta
tus:
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Thes
e req
uire
men
ts w
ere r
elev
ant a
ndap
prop
riate
to th
e inc
iner
ator
. Th
ein
cine
rato
r has
bee
n di
sman
tled.
The
grou
ndwa
ter t
reatm
ent f
acili
ty do
es n
ot tr
eal
haza
rdou
s wa
ste a
nd d
oes
not m
eet t
hesta
ndar
ds fo
r bei
ng su
fficie
ntly
simila
r to
aha
zard
ous
waste
trea
tmen
t fac
ility
. Th
ese
rule
s are
no
long
er c
onsid
ered
app
licab
le,
rele
vant
or a
ppro
pria
te.
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n de
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spec
ific r
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for cl
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e and
post-
closu
re o
f haz
aiw
aste
facil
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ecifi
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n, o
per
and
clos
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ents
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urfa
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losu
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men
ts fo
r haz
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us w
aste
lan
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n de
tails
spec
ific r
equk
for t
he d
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pera
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clos
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<ha
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ous
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te in
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If gr
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treate
dsit
e tre
atmen
t pro
cess
es is
disc
harg
esu
rface
wate
rs on
-site,
trea
ted g
roun
mus
t be i
n co
mpl
ianc
e with
app
licab
quali
ty st
anda
rds.
In a
dditi
on, a
disc
mon
itorin
g pr
ogra
m m
ust b
e im
plen
Rout
ine d
ischa
rge m
onito
ring
reco
rdbe
com
plete
d.
Any p
oint
sour
ce d
ischa
rges
mus
t mee
tN
PDES
per
mitt
ing
requ
irem
ents,
whi
chin
clude
com
plian
ce w
ith a
pplic
able
wate
rqu
ality
stan
dard
s; es
tablis
hmen
t of a
disc
harg
e mon
itorin
g sy
stem
; and
rout
ine
com
pleti
on o
f disc
harg
e mon
itorin
g re
cord
s.RO
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pplic
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urin
g th
e ide
ntifi
catio
n, sc
reen
ing,
evalu
ation
of a
ltern
ative
s, die
effec
tswe
tland
s mus
t be e
valu
ated.
This
regu
latio
n ou
dine
s req
uire
men
ts fo
rdi
scha
rges
of d
redge
d or
fill
mate
rial.
Unde
r this
requ
irem
ent n
o ac
tivity
that
impa
cts a
wetl
and
will
be pe
rmitt
ed if
apr
actic
able
alter
nativ
e tha
t has
less
impa
cton
die w
edan
d is
avail
able.
If t
here
is n
ooth
er p
racti
cabl
e alte
rnati
ve, i
mpa
cts m
ust
be m
itiga
tedRO
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pplic
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Fugi
tive d
ust e
miss
ions
from
Site
exac
tiviti
es w
ill b
e main
taine
d be
low
1Hg
/m3 (p
rimar
y sta
ndar
d) b
y du
stsu
ppre
ssan
ts, if
nece
ssar
y.
This
regu
latio
n sp
ecifi
es m
axim
um pr
imar
yan
d se
cond
ary 2
4-ho
ur co
ncen
tratio
ns fo
rpa
rticu
late m
atter
ROD
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tus:
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r Sta
tus:
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I fe
Cont
amin
ated
mate
rials
ship
ped
off-
be p
acka
ged,
man
ifeste
d, a
nd tr
ansp
a lice
nsed
off-
site d
ispos
al fa
cility
inco
mpl
iance
with
thes
e reg
ulat
ions
.
This
regu
latio
n ou
dine
s pro
cedu
res
for t
hepa
ckag
ing,
labe
ling,
man
ifesti
ng, a
ndtra
nspo
rtatio
n of
haza
rdou
s mate
rials
ROD
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tus:
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r Sta
tus:
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T SY
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ct po
int-s
ourc
e di
scha
rgwa
ter a
re o
ccur
ring.
B« « £! § < §>- S ^S.l.fe
Pollu
tant
disc
harg
es to
surfa
ce w
com
ply
with
NPD
ES p
erm
it re
quPe
rmit
cond
ition
s an
d sta
ndar
ds i
class
es o
f wate
r are
spec
ified
.
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To m
itiga
te un
avoi
dabl
e we
tlan
Fina
l Site
Res
tora
tion
Plan
was
The p
lan
requ
ired
the
resto
ratio
and
scru
b/sh
rub
flood
plain
wetl
incl
udin
g a
small
pea
t bog
, and
inte
rmitt
ent s
tream
impa
cted
b>ac
tion.
The
pla
n als
o re
quire
s a
mon
itorin
g of
the w
etla
nds
for t
follo
wing
com
plet
ion
of th
e res
ief
forts
. Th
is an
nual
mon
itorin
gco
mpl
eted
in th
e ye
ar 2
000.
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E-Y
EAR
REV
IEW
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REQ
UIR
EMEN
T SY
NO
PSIS
AN
D CO
NSI
DER
ATI
ON
IN T
HE
FFS
3HJ
Hc«Q0•*(
H
W
iat5ou«
ii
MED
IAAU
THO1
C 1) 73'*. ra H _
CERC
LASe
c. 1
21 (
d)(2
)(A)
Spec
ifica
llysta
tes
that
rem
edia
l act
ions
sha
ll at
leas
t atti
fede
ral A
WQC
esta
blish
ed u
nder
the C
lean
Wate
r Act
if th
ey ar
e rel
evan
t and
app
ropr
i;Th
ere
is a
rece
nt p
ropo
sal t
o re
open
the
Coch
ato
Rive
r to
the p
ublic
wat
er s
uppl
y.Th
ese
crite
ria a
re n
ot c
urre
ntly
ARA
R;ho
wev
er, t
hey
may
bec
ome
rele
vant
and
appr
opria
te if
the
Coch
ato
Rive
r is
cons
idei
for a
pot
entia
l pub
lic w
ater s
uppl
y. C
urre
nA
WQ
C ar
e lis
ted in
Tab
le 4
-1.
Rem
edial
acti
ons i
nvol
ving
cont
amin
ated
surfa
ce w
ater o
r gro
undw
ater
mus
t con
sider
the u
ses
of th
e wa
ter a
nd th
e circ
umsta
nces
of th
e rel
ease
or t
hrea
tened
rele
ase;
this
dete
rmin
es th
e rel
evan
ce a
ndap
prop
riate
ness
.
This
requ
irem
ent w
ill b
e co
nsid
ered
whe
nde
term
inin
g cle
an-u
p lev
els o
r pot
entia
ldi
scha
rge
limits
.
"° UG -«_^«i a
J5 o.13 p.oi <
^ r"
S3 g:% 3<^ ^^B <-> 0o O' •<H > S•a ^2 || §lS U U
«j
The
Site
is lo
cated
in a
des
igna
ted M
ass.
Wel
lhea
d Pr
otec
tion
Are
a. D
rinki
ng w
ater
stand
ards
are
app
licab
le to
drin
king
wate
rso
urce
s su
rroun
ding
the B
aird
& M
cGui
re !
MM
CLs
for O
U-3
are
pro
vide
d in
Tab
le 1
-Co
ntam
inat
ed se
dim
ents
have
bee
n re
mov
ean
d ar
e no
long
er ex
pecte
d to
leac
hco
ntam
inati
on to
the C
ocha
to R
iver
. Th
isre
quire
men
t has
bee
n at
tain
ed fo
r OU
-3.
Itdo
es, h
owev
er, r
emai
n re
leva
nt a
ndap
prop
riate
.
Mas
sach
usett
s ad
opted
the
fede
ral S
DW
AM
axim
um C
ontam
inan
t Lev
els (M
CLs)
asits
drin
king
wate
r stan
dard
s. M
CLs r
egul
ate
the c
once
ntra
tion
of co
ntam
inan
ts in
pub
licdr
inki
ng w
ater s
uppl
ies.
Whe
n ris
ks to
pub
lic h
ealth
due
toco
nsum
ptio
n of
surfa
ce w
ater w
ere
asse
ssed
,co
ncen
tratio
ns o
f con
tam
inan
ts of
conc
ern
were
com
pare
d to
Mas
sach
usett
s MCL
s.
"S aO (0-1 "CI IO fl,
~M\ C^
(A <
If
c "^
•5 §Q2 2« Q||5 73
S CO
•f §U o
Di .£•
CO Di
"B "i u „ „S ^3 C -^ ^3c r t . _ . « \ c d w C _ ^ ~ ^
Thes
e re
gula
dons
clas
sify
the
surfa
ce w
ater
the
Com
mon
wea
lth a
ccor
ding
to th
e us
es o
lth
ose
water
s. Th
e we
tland
has
a C
lass
Awa
terw
ay cl
assif
icatio
n. C
lass
A w
aters
are
desig
nated
as h
abita
t for
fish
, oth
er a
quat
icwi
ldlif
e, an
d fo
r prim
ary
and
seco
ndar
y co
nre
crea
don.
The
stat
e su
rface
wate
r min
imu
crite
ria fo
r Cla
ss A
wat
ers
are
cons
isten
t wi
fede
ral A
WQ
C. T
hese
rule
s are
app
licab
leth
e Co
chat
o Ri
ver a
nd u
nnam
ed b
rook
.
Surfa
ce w
ater q
ualit
y sta
ndar
ds a
re sp
ecifi
edfor
the m
ajor s
urfa
ce w
ater b
odies
of t
heCo
mm
onwe
alth.
Sur
face
wate
rs we
recla
ssifi
ed w
ith re
spec
t to
desig
nated
use
s.Ea
ch c
lass
of su
rface
wate
r has
a c
riter
iaas
socia
ted w
ith it
(e.g
., di
ssol
ved
oxyg
en,
tem
pera
ture
, pH,
total
col
iform
).
The C
ocha
to R
iver
is d
esig
nated
as
a Cl
ass
B Ri
ver.
Actio
ns w
ill ta
ke in
to a
ccou
nt th
ede
signa
ted u
se(s
) and
will
com
ply
with
spec
ified
wate
r qua
lity s
tand
ards
.
_uo0
"5.<
j£ Uo •*o ~^
<S C3 «a1X3 "§2 -81 I!£lit2 CXrJ-
ON<N
OU
CO
£U>aXatu
iNM
ROD
REQ
UIR
EMEN
T SY
NO
PSIS
AN
D C
ON
SID
ERA
TIO
N IN
TH
E FF
S
3
f-«c^QOCC
REQ
UIR
EMEN
T
Q ^|7 fN
< 2< oIE**
•-So § 5 ^>>^ ^. o = £.ti S — i tn oo y u 7t """ ._f •! ! "§ •! £ S "g|2" | g 1 -| f e ^ S =^'^ >-" r~ S 3 * § ^ o 3
g ^ o : fe 8 1 "B ^'i 1'? ^ ^ ^ ^" 'tJ "^ TO $1 ^
i l o ^ l « l § ) H i3 1 <£ .5 o l ^ ^ l s|il|ij|lji .
Mas
sach
uset
ts ha
s pro
mul
gate
d am
bien
t air
qual
ity st
anda
rds f
or si
x po
lluta
nts
(e.g
.,su
lfur o
xide
s, pa
rticu
late
mat
ter,
carb
on,
ozon
e, ni
troge
n, a
nd le
ad).
Dur
ing
exca
vatio
n ac
tiviti
es th
ese
stand
ards
will
be co
mpl
ied w
ith.
•a 0c3 S
i'l5 oI I)V{ ^
04|J |
O ^
" CO
SjJ
1 2JJ?^ U \o
nrt ^^ fli
5o E
u 3-<l 1/3 ai
_oiBV.
C.Q§o
Eotfcalei° <|° °3CO ^
•« (fl
§*££
This
guid
ance
man
ual g
ives
tran
spor
t and
fate
info
rmati
on fo
r 129
prio
rity
pollu
tant
s.
Thes
e crit
eria
wer
e con
sider
ed d
urin
g th
eris
k as
sess
men
t.
"S1BOUu
CO
^*UB
EPA
Offic
e of W
ater G
uida
Wate
r-Rela
ted F
ate of
129
Prio
rity P
ollu
tants
( 1 97
9) .
.8'§1«'S 85113 rj
ll
O
0 {S
S3 - .g>!;3o ^>
illu h 2S3 cL-3ce ° CB .2 8c -S -°C . Crts . £ ^
Thes
e re
qui
cons
ider
ed :
inci
nera
tor !
This
guid
ance
evalu
ates
acut
e an
d ch
roni
cto
xicit
y an
d se
ts dr
aft A
ALs
for
1 06
chem
ical
s. Fi
nal A
ALs
will
be is
sued
in
•8T3
'aoUU
CQ
E2
Mas
sach
usett
s Gui
danc
e on
Allo
wab
le A
mbi
ent L
evels
(AA
Ls).
cited
in C
hem
ical
.8&0
•a*C.2f 8£3 ^.ti *rt
S3s -gon S
00ON
Hea
lth E
ffects
Ass
essm
ent
PHOJ
1 Met
hodo
locv
and M
ethod
ol
c
1 to
Der
ive
Allo
wab
le A
mbi
eTh
ese
levels
will
be
cons
ider
ed w
hen
eval
uatin
g ex
cava
tion
and
treat
men
ttec
hnol
ogies
that
have
pot
entia
l haz
ardo
usair
emiss
ions
.i
*ooOs
aUQ
Q
oBI)S3•ac
"SB
>UBU
1X
'u^O
*u«O
1
H K -3" oc 2 -2 "a •S ttj Si ^* 7^O ^-« ^ ^ *^
£ 0- I g"3 v •* "5 "o^ ^ Q ^ c
"o. ^* ^^ ^J ^3
1 I % 1 -gO -g -3 O oJ5 a ^ ^ -EB^ J 2*0.— O ^ ? <"^ .i "§ 1 £•*: & * * p"S 2 * §" .0 -dSl l l l l|g s|sl1 1 g 1 .s 8
Thes
e cr
iteria
hav
e be
en re
cent
ly d
evelo
ped
by E
PA fo
r 16
org
anic
com
poun
ds.
Thes
ecr
iteria
repr
esen
t lev
els p
rote
ctiv
e of
aqua
ticlif
e.
Thes
e cr
iteria
wer
e use
d to
gen
erat
ese
dim
ent q
ualit
y crit
eria
valu
es d
urin
g th
eris
k as
sess
men
t.
•811uu
CO
^
B
| EP
A F
utur
e In
terim
Sed
ime
^«
1
1
M ».
Crite
ria V
alue
s for
Non
pola
Hydr
opho
bic O
rgan
icCo
ntam
inan
ts (S
CO
No.
17
May
198
8)
COSCfl
'£T3
.2S U
U ^is11
cCOi
O06Ou.WUZ<Q5oQ
O Btt U> <£ <»53a o& Oa; «u BQ^0'± EH wS HCU — iOJ C0j w< *
T3<->OUui
BQ<H
£>•d3COS<a>
1
>X
t/i
RO
D R
EQU
IREM
ENT
SYN
OPS
ISA
ND
CO
NSI
DER
ATI
ON
IN
TH
E FF
i
C/23•<1/3a0mjSfl
H§SUasSautf
g£< 2•< oS£5^S •<
a ••*b si «0 * 0
8 :: J5-c — c,u c a..& d f"3 •* oi- •— ' Cu K t«
!~ ^ 0
8 «•§Q. *S Cuw J r )« u 5n & *:•8 H ^3 U •»« Id 13
-S c -5
The
MCP
rem
edia
tioit
is sta
ted
•oc
The
MCP
esta
blish
es re
quire
men
ts an
dpr
oced
ures
for t
he d
iscov
ery,
not
ifica
tion,
asse
ssm
ent o
f, an
d res
pons
es to
, rele
ases
a
—X:ao"S.C.<
OenenOO Ij1
^g<a >n"2 <~-S a•o P£ o2 -t«o cd"^ «'o *tn U
>,
laJ2 e3 «00 £•s!u =2 ff
OD Qi
-3u•o'>Ou«cxiUa:Uul_lu
T3c3
"§J2300Ob«
_>.'uM
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1
1fe
'S"ou
1o2
•S
o.td13 Q5 .I i^ ^Q|siu o
•S u
•3 15'5 S11c •«S T3-r re
that
DEP
cC
ERC
LA ;
C«
mat
eria
ls. P
ursu
ant t
o M
CL c2
1 E
and
the
MCP
t the
Com
mon
wea
lth o
f Mas
sach
uset
t
i>v:<S)
'•si*,_oQOoiu
•S'i
conc
urre
d
ts;3O
1
1
fe
'S
1CBOu
Ih*Ooa
a
ISc.
"3lik.U"2'£QOk.u00B
CulaV5
_U~3UiU•s:U•S
Ther
efor
e,m
ateria
l to
be in
vesti
gate
d. B
ecau
se th
eA
RARS
.Ba
ird &
McG
uire
Site
is a
conf
irmed
stat
eha
zard
ous m
ateria
l Site
and
listed
on
the
Nat
iona
l Prio
ritie
s List
, joi
nt fe
dera
l and
state
juris
dict
ion
exist
s. Co
oper
ativ
eag
reem
ents
and
cont
racts
with
the f
eder
al
t**
gove
rnm
ent s
hall
inco
rpor
ate,
to th
e ex
tent
poss
ible
, the
dea
dlin
es a
nd sp
ecifi
catio
ns c
MCL
c2 IE
and
the M
CP.
UZ• i.Q
OQZ•<j
Wv
^^^^
2 HO H22 W
Q 3 2
^ O !»
U *y
H l *^
9-4 &
u w S o®3 u g<C 0 QU c« 536 z w
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u z o53 O (j
1*2U 2 QJ ai^ ^•- BQ
^Zvo
_3
_4—C
i1en
u"es
u€sen
X*O ^5*^ "^ 'ftf
ft. £ ^W H
r,
fli >> v •> — •
1 1 1 I|a-5§^ c
wc aP a0 £3
0 0
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u ||•<! ^_
ioCJtt.0Juiu
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i
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to
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en
Od
rf04
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lo
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thyl
hex;
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men
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uOuu.O
u
Su .8
1
(Noc
XC
ON
Oen
1
r-
S
a
!
COen
IOz
f>•— i ^o tfifi! tdo <*Li, -i
\RA
Rsl
SSA
CH
alB^"y oSoCA OS^so 5
TAB
LE 4
-7.
POTE
NTI
AL
AC
TBA
IRD
& M
CG
UIR
E SI
TE, H
^H>sPU^*
paE
5<t t^^QH2
BET
AK
EA
RAR
|
OP<;
ROD
REQ
UIR
EMEN
T SY
NO
PIS
AN
D S
TATU
S
QiQi
XS
§
'335
PC
biI•M
61
:/: ^C ^• i an*o ;= ?-sj l
S 3 oa & <=u ,_• a
"to 2 SH b "c
°» E —C qj • ^-
>-H *•* qj'S U u"a4 tf cS -r- 4>WM ^ V4J O* "^W3 U- diu a, >£ &.S
23u. .5 1O T3 CO
> ° "5S o ^2 ^ Sg o 5
uals
from
\e
disp
osed
:ont
ainer
s
3 -0 o§1 is |^fli CrS rtiS a <™ 2 o^e S uE- i as
!3
If co
ntam
inate
d su
bstan
ces m
eet t
he d
efin
ition
of R
CRA-
haza
rdou
s und
er 4
0 CF
R 26
1, RC
RA re
quke
men
ts ar
eap
plica
ble.
If co
ntam
inate
d su
bstan
ces a
t CER
CLA
sites
i
VI
1 ^f 1 3 o c-i55 t< VO1/3 — cs5 10 Ie« ^O ob°l-:C ^^ C*^1> VQ \O
O <N <N1 fy! i"
^ u ^u ° !2OS S<N
^•S s.2 b 2b .-2 -g1 g e-E o c«: « C.§ b §•
•0 g> ^TO O ^
•a § >« O <L>
"8 s "SV- Xu o o
• — 3 _C£ "- 13§ u .y r<u £ & s
^0£U
"5
5O^
cicm
COc
•oa
deter
min
ed to
be s
uffic
iently
sim
ilar t
o RC
RA h
azar
dous
waste
s, tec
hnica
l asp
ects
of R
CRA
requ
kem
ents
are
cons
ider
ed re
levan
t and
app
ropr
iate.
•i35
S3u
If re
mov
ed fr
om th
ek ex
istin
g lo
catio
n, h
azar
dous
subs
tani
shou
ld be
hand
led, t
rans
porte
d, a
nd tr
eated
as R
CRA
haza
rdou
s was
te.
Gene
ral g
ener
ator r
equk
emen
ts ou
tline
was
tech
arac
teriz
atio
n, m
anag
emen
t of c
onta
iner
s, pa
ckag
ing,
labe
ling
and
man
ifesti
ng.
ROD
Sta
tus:
App
licab
le5-
Yea
r Sta
tus:
Not
AR
AR
1 £"^ f* P* T3§ ' —
"o ^ ^o | i! 1 1G 'u Sli _C f^
| s||1 2k» ^ 2ti O* O
^ OH Tt
fS s-.sS uc ^
"§ "S 1u oa o 2•t1 a bi/3 ?g K>c c tSc • ^* o"S
^ T3 §i|i1 1 »'o -a ig
s! c !§^ <ii S
- s^ fli '2f E -53O Q _>,
•§ C 'c>. <S .H
— • R is1 "S 1g 1 .1°S ^ -oc^ $ ^
|||111•rt ^ ^"c -^ ^S cd
&S 5
o— ,"1 - v.u- O 4JU en 5« .a ^> ,S2
'^ c2W5 -^ 4iO O t«o « 2£ 5a o1|||
* "8 I"b * "°° sDN S X3
If a f
acili
ty o
pera
ted p
ursu
ant t
o RC
RA re
gula
tions
, RCR
Are
quire
men
ts ar
e ap
plic
able
. If
cont
amin
ated
subs
tanc
es a
CERC
LA si
tes a
re d
eterm
ined
to b
e su
fficie
ntly
sim
ilar t
oRC
RA h
azar
dous
was
tes, t
echn
ical a
spec
ts of
RCR
Are
quke
men
ts ar
e con
sider
ed re
levan
t and
app
ropr
iate.
t, . CO
° 1>*-i OC E>
Y\ C^ O
1 ° ^
1 ^
g|lftS O (X
10•<*
iUS
CO
•a °o~o ^fcd \ott. (N
^>
= "S 2
§ b "<i- -a .2S % o.a o £
g b I^ c1 o^S "o S.? ^ 5
1^11 1 :§N t— i -^2 4i ^J nc3 4J p, *-O ' & ^*•ta- r^ ro \.
6 ' o£ ^
'"^ ^nM O13 o.3 .23•a T3l5 Oi!^ i^1 1 i§ E
§ oc^
Sf 1
If re
mov
ed fr
om th
eir e
xisti
ng lo
catio
n, h
azar
dous
subs
tani
shou
ld be
han
dled
, tra
nspo
rted,
and
trea
ted as
RCR
Aha
zard
ous w
aste.
ni)D
Gen
eral
gen
erat
or re
quke
men
ts ou
tline
gen
eral
was
tean
alysis
, sec
urity
mea
sure
s, in
spec
tions
, and
trai
ning
requ
kem
ents.
ROD
Sta
tus:
App
licab
le5-
Yea
r Sta
tus:
Not
AR
AR
KE
req
^ We-e
§
21
-3CIB
I 5ll^"' 't' h"a. rt cC^ V3 O
O -3 ou -5 c
j= ^ U GO fl-> '-3 5 O «
S"- IE C t: >"*• ifc -^
Q. c c "o ffiE -S .2 -° •§illiis § 11|
•B s
Site
retre
atmen
pollu
tant
_O -^
2 Jj*
§ S* Oo ^
=« '3•Z E=g gE ^
= S§••5< =
2 -S£*'11o FO -C
f I* 1Qi «< -5
a|2 o
"§1u C
8 83 co"- 'C
ls-1
f — 2^Ti CO CO3 ~; - O -=ic J> < p -1
•S »: C OtJ g ^
" § T O : i S - 2 = j ES ' z : c i : c « 1 - ' ^ : : c o
5 o —
lt|C/3 2i CO
"S853
OO 03 'COU 3 C•^ O O1) T3 U
U 4=3 <
3 I" g 8 H Si S S * i - 83 « -3 | g Ra^ f lS , ,» ri *< "3 5J >; i s S «« coIS a UsJ 2 * < £ I?^*eil
i S l S - a 8
|?!S5°3 -a <; ^ o o
ilsil!3 ^ 2 d^-51.1111135 b "H, ° ^S o 3 o. o -9CX O. W £> £
mi
« s a g ©MillCA « !> S- en
FIV
E-Y
EAR
REV
IEW
S1<,
R23*tn SUJ <
CO0HZO
6<,
on5
ROD
REQ
UIR
EMEN
T SY
NO
PIS
AN
D S
TA
<j<
« S ° 1 „
The
MCP
inclu
des
a sp
ecifi
c rc
fere
nre
med
iatio
n at
CERC
LA si
tes (4
0.01
whe
re it
is st
ated
that
the M
CP d
oes
appl
y to
sites
ade
quat
ely
regu
late
d u
CER
CLA
, pro
vide
d th
at D
EP c
oncu
with
the
ROD
and
that
CERC
LAad
dres
ses
all c
onta
min
ants.
DEP
conc
urre
d wi
th th
e RO
D fo
r thi
s site
ther
efor
e, th
ese
rule
s are
no
long
erco
nsid
ered
ARA
Rs.
c/i•o oo -ab T3 rt T3
111 1 g Is"5 u5 •->- ^ E ~ ^l i l l i i 11^ ^ . k - s c - t s j a p|;-g 1 1. o = ,| c^ • S S O -o O E
S E O . B « e? g>-«CU &< u J= ."73 ^ '•$ •*"
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The M
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tabl
ishes
requ
irem
ents
and
proc
edur
es f
disc
over
y, n
otifi
catio
n, a
sses
smen
t of,
and
resp
onse
tre
leas
es a
nd th
reats
of r
elea
se o
f oil
or h
azar
dous
ma
Purs
uant
to M
CL c.
2 IE
and
the M
CP,
the C
omm
on'
Mas
sach
usett
s pub
lishe
s a li
st of
conf
irmed
oil
or ha
mate
rial t
o be
inve
stiga
ted.
Beca
use t
he B
aird
& M
eSi
te is
a con
firme
d sta
te ha
zard
ous m
ateria
l Site
and
the N
atio
nal P
riorit
ies
List,
join
t fed
eral
and
state
jur
exist
s. Co
oper
ativ
e ag
reem
ents
and
cont
ract
s wi
th tl
gove
rnm
ent s
hall
inco
rpor
ate,
to th
e ext
ent p
ossib
le,
dead
lines
and
spec
ifica
tions
of M
GL c2
1E a
nd th
e VRO
D S
tatu
s: A
pplic
able
5-Y
ear S
tatu
s: N
otA
RA
R
uc
luu 22 C-V3 &.
« 11
5 S 2H, CM -t
2 £ i g
Thes
e re
quire
men
ts w
ere
appl
icab
leth
e exc
avati
on a
nd in
cine
ratio
n of
deTh
ese
activ
ities
are
com
plet
ed, a
ndfu
rther
land
dist
urbi
ng a
ctiv
ities
are
plan
ned.
The
re a
re n
o ai
r em
issio
nso
urce
s on
site
. Th
ese r
ules
are
no
IA
RAR.
>> 2S £ ^S-2l|^ fl "2 ts^ "c3 T3 0 "
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fe S*S w o *5w o -S *- £ ^5 l« 1^1
Thes
e reg
ulati
ons o
utlin
e the
stan
dard
s and
requ
irem
air po
llutio
n co
ntro
l in
Mas
sach
usett
s. Sp
ecifi
c reg
uge
nera
lly co
nsid
ered
ARA
Rs at
CER
CLA
sites
inclu
parti
culat
e matt
er st
anda
rd (f
or ex
cava
tion
and t
reatr
activ
ities
), an
d pl
an a
ppro
val a
nd em
issio
n lim
itatio
rtre
atm
ent a
ctivi
ties,
such
as i
ncin
erat
ion,
gen
erati
ngem
issio
ns).
ROD
Sta
tus:
App
licab
le5-
Yea
r Sta
tus:
Not
AR
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c0•a o ^-v3 — . O=5 en, pa, ^ °°u. c -C
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mH
APPENDIX A
1997 AND 1998 PLUME MAPS
TOTAL SVOCS AND VOCS
1998 PLUME MAPS
1997 PLUME MAPS