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EPA Contract No. 68-W9-0036 H k H \ K: ;7 EPA Work Assignment No. 36-lL5$ *{ !{ R ._^Pl21^_
EPA Project Officer: Diane Kelley EPA Remedial Project Manager: Donald McElroy
FINAL WORK PLAN AMENDMENT
FOR REMEDIAL INVESTIGATION
Iron Horse Park Superfund Site 3rd Operable Unit
Billerica, Massachusetts
September 1994
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iflJBMetcalf&Eddy o oAn Air & Water Technologies Company o N)
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EPA CONTRACT NO. 68-W9-0036 EPA WORK ASSIGNMENT NO. 36-1L57
EPA Project Officer: Diane Kelley EPA Remedial Project Manager: Donald McElroy
FINAL
WORK PLAN AMENDMENT FOR
REMEDIAL INVESTIGATION
IRON HORSE PARK SUPERFUND SITE 3rd OPERABLE UNIT
NORTH BELLERICA, MASSACHUSETTS
September 1994
Prepared By:
METCALF & EDDY, INC. 30 Harvard Mill Square Wakefield, MA 01880
WORK PLAN AMENDMENT
TABLE OF CONTENTS
1.0 INTRODUCTION 1-1
1.1 SITE DESCRIPTION 1-5
1.2 GEOLOGY 1-6
1.2.1 Surficial Geology 1-6 1.2.2 Bedrock Geology 1-6
1.3 HYDROGEOLOGY 1-7
1.3.1 Groundwater Occurrence and Movement 1-7 1.3.2 Surface Water Drainage 1-8 1.3.3 Water Use and Receptors 1-8
1.4 SITE HISTORY 1-9
1.5 PREVIOUS STUDIES AND REPORTS 1-16
1.6 CURRENT STUDIES AND REPORTS 1-16
2.0 PRESENTATION OF EXISTING DATA AND RI OBJECTIVES 2-1
2.1 SUMMARY OF HISTORICAL DATA 2-1
2.1.1 Contaminant Investigation 2-1
2.1.1.1 B&M Railroad Landfill and Locomotive Shop Disposal Areas 2-2
2.1.1.2 RSI Landfill 2-3 2.1.1.3 Old B&M Oil/Sludge Recycling Area 2-4 2.1.1.4 Contaminated Soil Area 2-5 2.1.1.5 Asbestos Contamination 2-8 2.1.1.6 PCB Contamination 2-9 2.1.1.7 Groundwater 2-11 2.1.1.8 Surface Water 2-11 2.1.1.9 Sediment 2-11
WORK PLAN AMENDMENT
TABLE OF CONTENTS (Continued)
2.1.2 Hydrogeological Investigation 2-12
2.2 IDENTIFICATION OF RI DATA NEEDS 2-13
2.2.1 Nature and Extent 2-13 2.2.2 Data for Prediction of Contaminant Migration 2-16 2.2.3 Public Health Risk Assessment 2-16 2.2.4 Ecological Risk Assessment 2-16
2.3 RI OBJECTIVES 2-16
3.0 TECHNICAL APPROACH 3-1
3.1 PROJECT PLANNING (TASK 1) 3-1
3.1.1 RI Work Plan Amendment 3-1 3.1.2 Sampling and Analysis Plan Addendum 3-1 3.1.3 Site Safety and Health Plan Addendum 3-2 3.1.4 Project Management 3-2 3.1.5 Meeting Attendance 3-3 3.1.6 Subcontractor Procurement 3-3 3.1.7 Delivery of Analytical Services (DAS) 3-5
3.2 COMMUNITY RELATIONS (Task 2) 3-5
3.3 FIELD INVESTIGATIONS (Task 3) 3-6
3.3.1 Surface Geophysical Surveys 3-9 3.3.2 Hydrogeological Assessment 3-9
3.3.2.1 Decontamination Pad Construction/Site Clearing 3-9 3.3.2.2 Piezometer Installation 3-12 3.3.2.3 Monitoring Well Installation 3-15 3.3.2.4 Seepage Meter Installation 3-18 3.3.2.5 Staff Gauge Installation 3-19 3.3.2.6 Water Level Measurements 3-19 3.3.2.7 Aquifer Testing 3-21
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WORK PLAN AMENDMENT
TABLE OF CONTENTS (Continued)
3.3.3 Environmental Sampling 3-22
3.3.3.1 Soil Borings 3-22 3.3.3.2 Groundwater 3-22
3.3.4 Site Survey/Mapping 3-25 3.3.5 Field Generated Waste Disposal 3-25 3.3.6 Fieldwork Support 3-27
3.3.6.1 Site Setup, Mobilization and Demobilization 3-27 3.3.6.2 Audits 3-28 3.3.6.3 Preparation and Post Field Work 3-28
3.3.7 Meetings 3-30 3.3.8 Duration of Field Activities 3-30
3.4 SAMPLE ANALYSIS/VALIDATION (TASK 4) 3-31
3.5 DATA EVALUATION (TASK 5) 3-33
3.5.1 Databases 3-33 3.5.2 Data Evaluation/Preliminary Report Preparation 3-34
3.6 ASSESSMENT OF RISKS (TASK 6) 3-35
3.6.1 Scope of the Investigation 3-35 3.6.2 Grouping of Data 3-36 3.6.3 Selection of Chemicals of Potential Concern 3-36 3.6.4 Exposure Assessment 3-37 3.6.5 Toxicity Evaluation 3-38 3.6.6 Risk Characterization 3-39 3.6.7 Uncertainty Evaluation 3-39
3.7 TREATABILITY STUDY/PILOT TESTING (TASK 7) 3-40
3.8 REMEDIAL INVESTIGATION REPORTS (TASK 8) 3-40
3.9 DEVELOPMENT AND SCREENING OF ALTERNATIVES (TASK 9) . 3-41
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WORK PLAN AMENDMENT
TABLE OF CONTENTS (Continued)
3.10 DETAILED ANALYSIS OF ALTERNATIVES (TASK 10) 3-41
3.11 FEASIBILITY STUDY REPORT (TASK 11) 3-41
3.12 POST RI/FS SUPPORT (Task 12) 3-41
3.13 ENFORCEMENT SUPPORT (TASK 13) 3-41
3.14 MISCELLANEOUS SUPPORT (TASK 14) 3-41
3.15 ERA PLANNING (TASK 15) 3-41
3.16 ADMINISTRATIVE RECORD (TASK 16) 3-42
4.0 DOCUMENT PRODUCTION AND DISTRIBUTION 4-1
5.0 ASSUMPTIONS AND SCHEDULE 5-1
6.0 CASH FLOW SCHEDULE 6-1
7.0 SUBCONTRACTING PLAN 7-1
8.0 EQUIPMENT AND SUPPLIES 8-1
9.0 REFERENCES 9-1
IV
WORK PLAN AMENDMENT
LIST OF FIGURES
1-1 Geographical Location of the Iron Horse Park Superfund site 1-2
1-2 Site Base Map 1-4
1-3 Property Boundaries 1-12
3-1 Existing and Proposed Monitoring Wells, Piezometers, Staff Gauges, and Seepage Meters 3-11
5-1 Schedule 5-2
6-1 Cash Flow Schedule 6-2
WORK PLAN AMENDMENT
LIST OF TABLES
1-1 Chronology: Iron Horse Park site, 3rd Operable Unit 1-10
2-1 Summary of Soil Samples from the Old B&M Oil/Sludge Recycling Area on the Perm Culvert Property 2-6
2-2 Lead Levels in Site Soils that Exceed Typical Background Levels Found in New England Soils 2-7
2-3 Summary of Phase 1 RI Conclusions and Recommendations 2-14
2-4 Summary of 3rd Operable Unit RI Activities 2-15
3-1 Project Meeting Summary 3-4
3-2 Field Investigation Activity Summary 3-7
3-3 Hydrogeologic Groupings of Monitoring Well and Piezometer Locations for Areas of Concern 3-10
3-4 Estimated Depths of Proposed Piezometers, Monitoring Wells, and Seepage Meters 3-13
3-5 Summary of Environmental Samples and Analyses 3-23
8-1 Projected Logistic Field Station Supplies 8-2
8-2 Projected Field Support Supplies 8-3
8-3 Projected Health and Safety Supplies 8-4
8-4 Projected Task Equipment Needs 8-5
8-5 Projected Bottle Requirements 8-7
VI
1.0 INTRODUCTION
The U.S. Environmental Protection Agency (EPA), Region I, is currently conducting a remedial
investigation (RI) at the 3rd operable unit of the Iron Horse Park Superfund site in North
Billerica, Massachusetts (Figure 1-1). The RI will document the nature and extent of
contamination observed in the 3rd operable unit so that remedial alternatives can be developed
and an appropriate response action or actions can be implemented. This work plan amendment
to the Final Work Plan (M&E, 1993a) is intended to describe the RI activities that will be
conducted at the Iron Horse Park site, 3rd operable unit to evaluate potential groundwater
contamination. The other two operable units at the site, the Boston & Maine (B&M) Railroad
wastewater lagoons (operable unit 1) and the Shaffer landfill (operable unit 2), are not addressed
in this work plan amendment.
A statement of work (SOW) was prepared by EPA in September 1992 to summarize the EPA's
current understanding of the nature and extent of contamination at the site, and to identify the
general and site-specific requirements for the investigations under the Comprehensive
Environmental Response, Compensation and Liability Act (CERCLA), 42 U.S.C. §§ 9601
et. seq. and the National Oil and Hazardous Substances Pollution Contingency Plan (NCP) 40
CFR Part 300. The September 1992 SOW incorporates the Shaffer landfill Record of Decision
(U.S. EPA, 1991a), the Phase 1A RI report (CDM, 1987), the Phase IB RI report
(CDM, 1988), the Phase 1C RI report (CDM, 1989a), the Phase 1C feasibility study
(CDM, 1991), and the memorandum report (CDM, 1989b). The site history and scope of work
for this work plan amendment were prepared using excerpts from the above mentioned
documents as well as the SOW for the 3rd operable at Iron Horse Park Superfund site
(U.S. EPA, 1992a).
The first investigation, the Phase 1A RI, was conducted in 1985 by Camp Dresser &
McKee, Inc. (CDM), under contract to the EPA (CDM, 1987). This RI undertook a broad
study of the site to delineate potential problem areas. As a result of the Phase 1A RI, the site
was then divided into three operable units: the B&M wastewater lagoons (operable unit 1), the
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Site Boundary for Iron Horse Park Supertund Site
SOURCE USGS Topographic Map Blllenca, MA N4230-W7115/75(1979) Wilmington, MA N4230-W7107 5/7 5 (1979)
SCALE IN FEET
FIGURE 1-1. GEOGRAPHICAL LOCATION OF THE IRON HORSE PARK SUPERFUND SITE
METC A L F » E D D Y 1-2
Shaffer landfill (operable unit 2) and the remaining nine areas of concern defined as operable
unit 3 (these included: asbestos landfill, asbestos lagoons, old B&M oil/sludge recycling area,
contaminated soil area, PCB contamination, B&M Railroad landfill and locomotive shop disposal
areas, RSI landfill, site-wide groundwater contamination, and site-wide surface water and
sediment contamination), which were addressed in this investigation (Figure 1-2). The Phase
IB RI report (CDM, 1988) concentrated on the area surrounding the B&M wastewater lagoons.
The Phase 1C RI report (CDM, 1989a) concentrated on the Shaffer landfill at the Iron Horse
Park site.
The objectives of the RI are to complete a field program for collecting data to quantify the
nature and extent of contamination, delineate potential source areas, and to evaluate the public
health and ecological risks associated with contaminants found at each of the following areas:
• asbestos lagoons • old B&M oil/sludge recycling area • contaminated soil area • B&M Railroad landfill • B&M locomotive shop disposal areas • RSI landfill • site-wide surface water and sediment
In addition, the historical PCB contamination in Middlesex Canal, the integrity of the asbestos
landfill cap, site-wide groundwater, and hydrogeological characteristics were evaluated in the
summer and fall of 1993 and the winter of 1993/94.
In February 1994, M&E submitted to EPA a Hydrogeological Assessment Report
(M&E, 1994a). The purpose of this report was to present a conceptual model of the site
hydrogeology and to characterize groundwater contamination at the 3rd operable unit. Following
submittal of this report, EPA prepared a scope of work to further evaluate potential groundwater
contamination for five areas of concern including: the B&M Railroad landfill, the RSI landfill,
the B&M locomotive and shop disposal area, the asbestos lagoons, and the old B&M oil/sludge
recycling area (Work Assignment #36-lL57, Revision 12). The scope of work and the
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technical approach to address each of these areas of concern are described in this work plan
amendment. The purpose of this work plan amendment is:
• to present the scope of work, including a site description, the objectives of the RI, and the work planned by task for evaluation of groundwater contamination in each of the five source areas.
• to provide a basis for changes in scope, if field investigations indicate such a need, by including detailed descriptions and assumptions about the work to be performed.
Subsections of section 1 of the work plan amendment summarize the site description, geology,
hydrogeology, history, and previous studies conducted at the Iron Horse Park site. In section 2,
existing data are evaluated, and data gaps and RI objectives are identified. Section 3 details the
technical approach to the scope of work to be implemented in performing the RI. Section 4
outlines document production and distribution. The work schedule and budget assumptions are
described in section 5. Section 6 outlines the cash flow schedule. Section 7 presents the
subcontracting plan. Equipment and supplies are detailed in section 8.
1.1 SITE DESCRIPTION
The Iron Horse Park site occupies approximately 553 acres of land hi North Billerica,
Massachusetts, near the Tewksbury town line, approximately 20 miles northwest of Boston
(Figure 1-1).
The Iron Horse Park site is an active industrial complex and railyard with a long history of
activities which have resulted hi contamination of soils, groundwater, surface water, and air at
the site. This large site includes numerous manufacturing operations, open storage areas,
landfills and lagoons, some of which began operating hi the early 1900's. Contaminants known
to have been disposed of at the site include asbestos, PCBs, solvents, waste oils, and other
chemicals (CDM, 1987). Changes hi physical characteristics of the site have occurred during
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the years of operation, due to the creation and eventual expansion of several landfills, open
storage areas, and lagoons.
The site is bounded on the north by the B&M railroad tracks, on the west side by High Street
and an auto salvage yard, on the east side by Gray Street and on the south side by a wetland,
Pond Street and the Middlesex Canal (Figure 1-2). The Middlesex Canal flows through the site
to the east where it joins Content Brook at the southeastern edge of the Shaffer landfill. This
area is also an abundant wetland area. Residential property borders the north and south
boundaries of the Shaffer landfill.
1.2 GEOLOGY
The surficial and bedrock geology in the vicinity of the site are described briefly in the following
sections.
1.2.1 Surficial Geology
According to previous investigations conducted at the Iron Horse Park site (CDM, 1987; 1988;
1989a) the overburden in the site consists of a sandy ablation till overlain by glacial outwash
deposits. The till is reportedly discontinuous and where present reaches a thickness of up to
5 feet. The outwash deposits range from 0 to approximately 60 feet in thickness. The thickest
overburden deposits occur in the vicinity of Shaffer landfill, where the glacial outwash thickness
was found to range from 10 to 58 feet.
1.2.2 Bedrock Geology
The site is situated geologically within the Nashoba Zone, a northeast-trending structural
geologic province, which is bounded by the Clinton-Newbury fault system to the north and the
Bloody Bluff fault system to the south. The Nashoba Zone consists of high-grade
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metasedimentary and metavolcanic rocks which have been intruded by intermediate composition
and granitic plutons.
The site is situated near the contact between two rock formations in the Nashoba Zone, the
Nashoba Formation, which consists primarily of schists and gneisses, and the Andover Granite,
which is one of the intrusive rocks of the Nashoba Zone. The Andover consists of
peraluminous, garnet bearing muscovite-biotite foliated and non-foliated granite with pegmatites
common (Hepburn and Munn, 1984).
In some areas the contact occurs and has been mapped as a migmatite, or "mixed rock," which
formed when the Nashoba Formation was intruded by the Andover Granite. The contact trends
northeast across the site with the Nashoba Formation occurring northwest of the Andover
Granite. Rock cores obtained from the site suggest that the contact is irregular but trends
northeast across the mid portion of Shaffer landfill. The bedrock surface at the site is reportedly
irregular and in some areas highly weathered causing variation in the depth to bedrock.
1.3 HYDROGEOLOGY
The site hydrogeology and surface water drainage patterns are described briefly in the following
sections.
1.3.1 Groundwater Occurrence and Movement
Groundwater at the Iron Horse Park site exists under water table conditions in the glacial
outwash and till deposits that overlie the site. Groundwater also occurs in the fractured bedrock
that underlies the site.
Groundwater in the vicinity of the B&M wastewater lagoons flows radially away from the
lagoons in all directions except to the south (CDM, 1988). In the vicinity of Shaffer landfill,
groundwater in both the overburden and bedrock generally flows from west to east. Previous
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work conducted in this area suggest that flow directions and hydraulic gradients in the
overburden and bedrock are similar (CDM, 1989a).
Along the west end of the Shaffer landfill, groundwater flow is to the northeast in the direction
of Richardson Pond. In the central portion of the landfill, hydraulic gradients decrease due to
an increased saturated thickness and bedrock low, and flow occurs both to the northeast towards
Richardson Pond and to the southeast towards the wetlands surrounding the Middlesex Canal.
Groundwater in the east portion of the landfill flows to the southeast. East of the Shaffer
landfill, the regional groundwater flow direction is to the southeast.
1.3.2 Surface Water Drainage
Surface water at the site drains to the east along the Middlesex Canal, which drains to the
Shawsheen River and ultimately to the Merrimack River to the north. The topographic high in
the site vicinity lies just to the south of the site; the topographic low in the area lies to the
northeast of the site at Richardson Pond and Long Pond.
1.3.3 Water Use and Receptors
The primary water supply source for the town of Billerica is the Concord River which serves
approximately 95% of the town's water needs. The town's water supply intake is located
approximately one mile upstream of the Middlesex Canal's entry point to the river. At least four
residential wells, which are located approximately 0.2 miles east of the Shaffer landfill, have not
been used since the Shaffer landfill ceased operations.
The town of Tewksbury, located northeast of the Iron Horse Park site, currently uses the
Merrimack River as its primary drinking water supply. Four municipal wells were used until
approximately 1991 to provide 30 to 40% of the Tewksbury drinking water supply. Located
approximately 4,000 feet northeast of the Shaffer landfill, these wells currently are used only
as an emergency source.
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1.4 SITE HISTORY
The 553 acres of land which now makes up the Iron Horse Park site was first purchased by the
B&M Railroad (now known as B&M Corporation) in 1911. Since then, a variety of industrial
disposal practices have resulted in the creation of numerous lagoons, landfills, and open storage
areas, that complicate the process of delineating the origin and nature of the contamination
problems that currently exist at the site. Table 1-1 provides a chronology of site activities at the
Iron Horse Park site.
The B&M Railroad, which began operations at Iron Horse Park site in 1913, has owned and
operated the locomotive/railroad car maintenance facility ever since. The B&M Railroad has
also owned and operated the present combined sewage/drainage system for Iron Horse Park
since approximately 1924. Beginning sometime prior to 1938, the B&M Railroad also operated
an "oil and sludge" recycling area on their property for a number of years. In addition, at
different times over the years, the B&M Corporation has sold and leased several parcels of their
land and some of the buildings to various companies. The property boundaries of companies
currently located within the Iron Horse Park site are presented in Figure 1-3.
At the present time, the B&M Corporation's on-site operations include administrative offices,
a locomotive/railroad car maintenance and repair facility, track panel fabrication, rail welding,
and operation of the sewage collection system which includes subsurface sewer lines, a
dismantled pumphouse, two unlined filter lagoons (approximately 104 foot by 200 foot by
4 foot), and one overflow lagoon. These lagoons received septic waste from B&M facilities and
other manufacturing facilities throughout the park. Presently, the sewage collection system no
longer discharges to the lagoons, but has been tied into the Billerica system. In addition to
septic wastes, the lagoons also received industrial/hazardous wastes such as solvents, waste oils
and other chemicals from various floor and yard drams found throughout the industrial park.
Sludge from the bottom of these lagoons was periodically dredged during the past 60 years of
operation and deposited in piles adjacent to the lagoons. Prior to 1981, much larger quantities
of hazardous wastes were discharged directly to these lagoons. After 1981, much of the
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TABLE 1-1. CHRONOLOGY: IRON HORSE PARK SITE, 3rd OPERABLE UNIT (1)
Year Activities within the Site Boundaries
1911 Boston & Maine (B&M) Railroad purchased 553 acres of land that now makes up the Iron Horse Park site.
1913 B&M Railroad began operations at the Iron Horse Industrial Park.
1924 B&M Railroad began operating a combined sewage/drainage system for the Iron Horse Industrial Park.
1938 Oil and sludge recycling activities began in the area that is currently owned by Penn Culvert.
1944 B&M Corporation sold approximately 70 acres of land to Johns-Manville Products Corporation which manufactures structural insulating board. Two unlined lagoons, located on the newly purchased land were used to dispose of asbestos sludge waste. In addition, approximately 15 acres of land was leased from B&M for use as a landfill for asbestos waste.
1961 Johns-Manville sold the western portion of land to General Latex and Chemical Corporation.
1961 Aerial photographs indicate that wetland areas east of the railyard, on the north side of the Middlesex Canal, were being filled by B&M Railroad.
1961 B&M Railroad sold a 23-acre parcel of land on which oil and sludge recycling took place to Omega Trust.
1962 B&M Railroad sold approximately 1.2 acres of land and an existing building to Wood Fabricators, Inc.
1966 B&M Corporation sold an additional 0.67 acres of land to Wood Fabricators, Inc.
1966 B&M Corporation sold approximately 106 acres of land to Phillip Shaffer as Trustee of Gray Pond Realty Trust. Prior to 1966, this land was used for open burning.
1-10
TABLE 1-1 (Cont'd). CHRONOLOGY: IRON HORSE PARK SITE
Year Activities within the Site Boundaries
1968 Billerica Board of Health ordered that open burning practices cease on the land owned by Phillip Shaffer. The land was then used as a landfill, accepting both commercial and residential waste materials. This area is known as the Shaffer or Pond Street Landfill.
1969 Aerial photographs indicate significant expansion of existing landfills areas located in the eastern portion of Iron Horse Park. These areas include B&M land being used by Johns-Manville for disposal of asbestos waste, the B&M landfill north of the canal and the Shaffer Landfill.
1973 Omega Trust sold the oil and sludge recycling area to Penn Culvert Company
1976 Aerial photographs indicate that the expansion of the existing landfills has slowed down or even halted. Vegetation has returned to parts of each landfill.
1976 B&M Corporation sold approximately 150 acres of primarily developed land to the Massachusetts Bay Transportation Authority (MBTA) to operate passenger rail service including land along the northern portion of the Shaffer landfill.
1979 Aerial photographs indicate that the old B&M oil & sludge recycling area has been cleared, leveled and filled. The area is currently a partially paved lot used as a storage area.
1984 Iron Horse Park site was placed on the National Priorities List as a result of DEP investigations and a Site Investigation Report.
1984 A lawsuit was filed against Phillip Shaffer by the DEP for environmental violations.
1984 The Johns-Manville asbestos landfill was capped during an Immediate Removal Action under CERCLA performed by the EPA.
1986 In compliance with the state Court Order, the Shaffer Landfill ceased operations hi April 1986.
(1) Source: CDM, 1989a
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hazardous waste generated at the site was disposed of offsite at RCRA permitted treatment,
storage, and disposal (TSD) facilities, in compliance with state and federal hazardous waste
regulations. However, wastes from various cleaning and repair operations may have been
discharged directly to the lagoons through floor and yard drains.
In 1944, the B&M Railroad sold approximately 70 acres of land located in the western portion
of the site to Johns-Manville Products Corporation, who at that time began to manufacture
structural insulating board which contained asbestos. Two unlined lagoons were built to dispose
of the resulting asbestos sludge waste. At approximately the same time, the B&M Railroad
leased approximately 15 acres of land located in the eastern portion of the site to the
Johns-Manville Products Corporation to be used as a landfill for asbestos sludge and other
asbestos mill wastes generated by Johns-Manville manufacturing operations. EPA capped this
landfill in 1984 as part of an "Immediate Removal Action" under CERCLA.
In 1961, the Johns-Manville Products Corporation sold the western portion of their land to the
General Latex and Chemical Corporation who manufactured acrylic and vinyl acetate polymers
and copolymers which are used hi fabrics, paper and insulation. Latex and polymerization
wastes were treated onsite using flocculation, coagulation, and sand filters which produced a
filter cake that was disposed of offsite at a sanitary landfill. The liquid filtrate was discharged
to the ground through sand filters. This practice was discontinued in May 1982, when General
Latex was connected to the Billerica wastewater treatment system.
Aerial photographs indicate that B&M Railroad began to fill hi the wetland area located just east
of the railyard, on the north side of the Middlesex Canal (west of Pond Street) in 1961
(CDM, 1989a). The photographs show that another wetland area owned by the B&M Railroad,
located on the east side of Pond Street, was also being filled in. Also in 1961, the B&M
Railroad sold a 23-acre parcel of land containing the "sludge-oil" area to Omega Trust. In 1962,
the B&M Railroad sold approximately 1.2 acres of land and an existing building to Wood
Fabricators, Inc. In 1966, the B&M Corporation sold Wood Fabricators an additional 0.67 acres
of land.
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In 1966, the B&M Corporation sold 106 acres of land to Phillip Shaffer as the Trustee of Gray
Pond Realty Trust. Prior to 1966, this parcel of land had been used as an open burning dump
operation with approval from the Billerica Board of Health. The area was originally a flat
wetlands area which was mostly filled in by 1966. From 1966 until 1968, burning practices
continued until the Billerica Board of Health issued regulations in 1968 stating that no further
burning would take place. The regulations also stated that all refuse would be placed above the
water table and that daily cover should be applied. Since that time the area had been used as
a landfill (referred to as the Shaffer or Pond Street landfill) operated by Middlesex Disposal
Services, Inc., and received commercial and residential waste materials from private clients,
wastewater treatment sludge from the Town of Billerica, and domestic waste from Billerica
residents.
The Shaffer landfill has been cited for many violations of federal and state regulations under the
Clean Water Act and the Solid Waste Regulations (CDM, 1987). At the present time, the
Shaffer landfill owners are conducting closure activities under a Consent Order with the
Massachusetts Department of Environmental Protection (DEP) following a lawsuit filed in 1984
against the owner of the landfill for these violations. In compliance with the State Court Order,
the landfill stopped receiving waste of any kind in April 1986.
Aerial photographs taken in 1969 indicate that significant expansion of existing landfill areas
located in the eastern portion of the Iron Horse Park site was taking place. These areas included
the B&M land being used by Johns-Manville for disposal of asbestos waste, the B&M landfill
area north of the Middlesex Canal (west of Pond Street) being used by B&M to dump various
kinds of materials, and the Shaffer landfill, north of the Middlesex Canal (east of Pond Street).
In addition, the B&M Railroad was using a parcel of land located just east of the railyard on the
south side of the Middlesex Canal as a borrow pit for sand and gravel. This borrow pit area
was leased by B&M for a three month period to Reclamation Services, Inc., (RSI) for use as
a landfill to dispose of municipal and light industrial waste. Aerial photographs taken in 1976
indicate that the expansion of the existing landfill areas had slowed down or stopped and that
1-14
vegetative cover had returned to portions of each landfill, including the asbestos landfill, the
B&M landfill, the former RSI landfill, and the Shaffer landfill.
In 1973, the land containing the "oil and sludge" recycling area, previously owned by the B&M
Railroad, was sold by Omega Trust to the Perm Culvert Company. An aerial photograph taken
in 1979 shows that the old B&M oil and sludge recycling area, now located on Penn Culvert
property, had been cleared, leveled, and filled. The area is currently a partially paved lot and
is used as a storage area by Penn Culvert.
In 1976, the B&M Corporation sold approximately 150 acres of primarily developed land to the
Massachusetts Bay Transportation Authority (MBTA), who has since used the land to operate
passenger rail service. The B&M Corporation now leases much of this land from the MBTA.
B&M Corporation presently owns approximately 100 acres of the Iron Horse Park site.
Current landowners and operating companies on the Iron Horse Industrial Park Site include:
General Latex, B&M Corporation, Penn Culvert, Spincraft, Wood Fabricators, Johns-Manville,
and George McQuesten Lumber.
The Iron Horse Park site was placed on the National Priorities List (NPL) in September 1984
as a result of DEP investigations and a site investigation report prepared for EPA (NUS, 1983).
Due to the large size of the Iron Horse Park site and the number of potential source areas, a
phased operable unit approach was undertaken to select remedies for each identified source area.
The intent of this approach is to remediate the site more effectively by establishing priorities for
potential source areas and then conducting a separate but overlapping RI on each designated
source area or "operable unit", rather than attempting to remediate all source areas
simultaneously (NUS, 1983).
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1.5 PREVIOUS STUDIES AND REPORTS
Several studies have been conducted concerning the Iron Horse Park site. These include:
Final Report for Iron Horse Park Site Inspection Report, North Billerica, MA, (NUS, 1975)
Final Environmental Impact Report Pond Street Sanitary Landfill, Billerica, Massachusetts, (GHR Engineering Corporation, 1984)
Supplemental Final Environmental Impact Report, Pond Street Sanitary Landfill, Billerica, Massachusetts, (GHR Engineering Corporation, 1985)
Preliminary Site Assessment of the Iron Horse Park Facility, North Billerica, Massachusetts, (NUS, 1983)
Field Investigations of Uncontrolled Hazardous Waste Sites (FIT Project): Scope of Work for Site Inspection and Investigation, Iron Horse Park, Billerica, MA, (Ecology and Environment, 1982)
Draft Phase 1A Remedial Investigation for the Iron Horse Site, Billerica, MA, (COM, 1987)
Draft Phase IB Remedial Investigation for the Boston and Maine Wastewater Lagoon Area, Iron Horse Site, Billerica, MA, (COM, 1988)
Draft Phase 1C Remedial Investigation for the Shaffer Landfill, Iron Horse Park Site, Billerica, MA, (CDM, 1989a)
Wetlands Characterization and Biological Investigations, Iron Horse Park Site, Billerica, Massachusetts (Weston, 1989).
1.6 CURRENT STUDIES AND REPORTS
The following reports have been prepared as part of the current remedial investigation:
• Hydrogeological Assessment Report, Iron Horse Park Superfund site, North Billerica, Massachusetts (M&E, 1994a).
1-16
• Asbestos Landfill Cap Evaluation Report, Iron Horse Park SuperfundBillerica, Massachusetts (M&E, 1994b).
site, North
• PCS Contamination Evaluation Report, Iron Horse Park SuperfundBillerica, Massachusetts (M&E, 1994c).
site, North
1-17
2.0 PRESENTATION OF EXISTING DATA AND RI OBJECTIVES
This section summarizes the findings from the previous site evaluations and details the objectives
for the RI at the Iron Horse Park site. The intent of this section is to provide a clear focus for
the RI scope of work for the areas in the 3rd operable unit of the site.
2.1 SUMMARY OF HISTORICAL DATA
A summary of historic contaminant and hydrogeologic information is detailed below.
2.1.1 Contaminant Investigation
A technical memorandum was prepared (CDM, 1989b) to summarize the current understanding
of the site and to address concerns associated with the different operable units that were
identified in the Phase 1A RI report (CDM, 1987). As described in section 1, the 3rd operable
unit consists of nine areas that will be studied during this RI investigation. This section
summarizes seven of the nine areas, identified as part of the 3rd operable unit at the site
(Figure 1-2), using sections and excerpts from the memorandum (CDM, 1989b) and from the
SOW for this assignment (U.S. EPA, 1992a). The areas described include: the B&M Railroad
landfill and locomotive shop disposal areas, the RSI landfill, the old B&M oil/sludge recycling
area, the contaminated soil area, PCB contamination, and asbestos contamination (includes
asbestos landfill and asbestos lagoons). In addition, site-wide groundwater, surface water, and
sediment contamination has been identified by previous investigations (CDM, 1987).
Following the review of the Hydrogeological Assessment Report (M&E, 1994a) by EPA, it was
decided that potential groundwater contamination in five areas of concern (the B&M Railroad
landfill and locomotive shop disposal areas, the RSI landfill, the old B&M oil/sludge recycling
area, and the asbestos lagoons) would be further evaluated as part of Work Assignment
#36-lL57, Revision 12. Results and conclusions presented in the Hydrogeological Assessment
Report (M&E, 1994a) have also been included in this section.
2-1
2.1.1.1 B&M Railroad Landfill and Locomotive Shop Disposal Areas. The B&M Railroad
historically used two distinct areas, B&M Railroad landfill and locomotive shop disposal areas,
at the site.
B&M Railroad Landfill. The B&M Railroad landfill is approximately 14 acres in size, and
is located in a wetland area, to the north of the Middlesex Canal and east of the railyard. The
wetland was filled in by the B&M Railroad prior to 1938 and used to dispose of various kinds
of debris until about 1976. CDM (1987) observed that this area contains partially buried drums
and creosoted railroad ties. Soil samples from this area were not collected during the Phase 1A
RI. Surface water and sediment samples from two locations in the Middlesex Canal (which
borders the area) were analyzed and the results indicated no detectable levels of contaminants.
However, a cluster of groundwater monitoring wells (OW 49-51) was also placed on the eastern
edge of this wetland. Samples of groundwater collected from these wells revealed detectable
levels of volatile organics in the bedrock well (90 ppb) and the deep overburden well (6 ppb).
During the recent field investigation performed in the fall of 1993, geophysical data suggested
that buried metal was more concentrated in certain subareas within the landfill. The boring logs
also suggest that landfilled materials may be below the water table, which was noted at
approximate depths of 4 to 15 feet below the ground surface. 1,1-Dichloroethene (1,1-DCE)
was detected during groundwater screening on the easternmost side of the landfill. In addition,
high conductivities (greater than 1,000 ^mhos/cm), indicative of elevated concentrations of
inorganics were reported. Preliminary analytical data from the soil borings and test pits installed
during the fall investigation indicate that a range of organic compounds including PAHS,
PCB aroclors, long-chain alkanes, BTEX compounds, and ketones are present hi subsurface soils
in contact with groundwater.
B&M Locomotive Shop Disposal Areas. The B&M locomotive shop disposal areas consist of
two disposal areas separated by a manmade channel which flows into the unnamed brook. The
first area located on the south side of the channel, is approximately 3 acres in size. Prior to
1938 and until about 1979, the area was used to dispose of various kinds of "light and
2-2
dark-toned materials". CDM observed that the area contains various kinds of debris, including
deteriorated drums. The soils in this area were not sampled.
The second area, located on the north side of the channel and approximately 1 acre in size, was
investigated by CDM during the Phase 1A RI. Various kinds of partially buried debris were
observed in this area. Two soil borings drilled in this area revealed that subsurface soils were
visibly contaminated with oily wastes. Chemical analysis for hazardous substance list (HSL)
contaminants revealed elevated levels of lead and polynuclear aromatic hydrocarbon (PAH)
compounds (3,000 ppm and 4 ppm, respectively). Trace levels (5 ppb) of volatile organics were
also detected. In addition, analysis of surface soils for asbestos revealed levels greater than 1 %.
Recent geophysical surveys (fall 1993; M&E, 1994a) suggest that nonmetallic fill was
predominant in the small disposal area. The larger disposal area revealed geophysical anomalies
which are attributable to the presence of surface metals. Preliminary subsurface data from the
fall investigation indicate the presence of a variety of organics such as tetrachloroethene (PCE),
PAHs, long-chained alkanes, ketones, various pesticides, and PCBs. Groundwater screening
directly downgradient of the disposal areas indicated the presence of 1,1 -DCE, vinyl chloride,
and elevated specific conductance.
2.1.1.2 RSI Landfill. The RSI landfill is located east of the B&M railyard near the
Johns-Manville asbestos landfill. It is bounded on the south side by an unnamed brook and the
east side by a wetland, which is drained by the Middlesex Canal. This area was used by B&M
as a borrow pit for sand and gravel sometime between 1961 and 1969.
This 6-acre parcel of land was once leased by the B&M Corporation to Reclamation Services
Incorporated (RSI) for a period of three months (from June of 1971 until August of 1971),
because of a fire at the RSI Cambridge Plant. During the fire, some compacted refuse bales
were broken apart in order to extinguish the fire. The Massachusetts Division of Environmental
Health granted RSI permission to use the B&M land to dispose of their loose, burnt refuse. This
area was not used for disposal by RSI after August 1971. The waste disposed of by RSI on
2-3
B&M land was classified as municipal and light industrial solid wastes from the cities of
Cambridge and Somerville. There were no records kept on specific waste characteristics. By
1976, the area was no longer being used and vegetative cover was returning.
Although soil samples from this area were not analyzed during the Phase 1A RI, samples of
surface water and sediment were collected and analyzed from the unnamed brook, at the point
where it discharges to an adjacent wetland area. In addition, groundwater samples were
collected from a cluster of monitoring wells installed in the adjacent wetland area. Detectable
levels of contaminants were not found in nearby surface waters, but detectable levels of volatile
organics were found hi the bedrock well (27 ppb) and the shallow overburden well (6 ppb).
A sediment sample collected from the adjacent wetland area contained PAHs (9 ppm) and
elevated levels of arsenic (81 ppm) and lead (1,000 ppm).
Geophysical data from the fall of 1993 suggests that the landfill contains abundant metal objects.
Boring logs confirmed the geophysical findings and suggest that the fill is as much as 15 feet
thick in the central portion of the landfill and that groundwater may be in contact with the fill
materials. Chlorinated volatiles (1,1-DCE, ds-l,2-DCE, and vinyl chloride) and benzene were
detected during groundwater screening. In addition, preliminary analytical data from the soil
boring and test pit activities indicated that a substantial number of long-chained alkanes, BTEX
compounds, PAHs, creosols, phthalates, ketones, various pesticides, and PCB aroclors are
present in subsurface soils from this landfill.
2.1.1.3 Old B&M Oil/Sludge Recycling Area. The 6-acre old B&M oil/sludge recycling area
was established sometime prior to 1938 for the purpose of recycling oil. A B&M Railroad site
plan dated 1972, shows two adjacent areas designated as "sludge" and "oil", which appear to
be pooled areas located about 300 feet west of the B&M locomotive repair facility
(CDM, 1989b). These two areas have a combined dimension of 600 by 200 feet. In 1973, the
Penn Culvert Company purchased the parcel of land containing these two disposal areas, and
sometime later filled in these areas.
2-4
During the NUS site inspection (NUS, 1975) and the CDM Phase 1A RI, subsurface soil
samples were collected from these areas. A summary of the analytical results is presented in
Table 2-1. The results from both sampling rounds revealed that the soils are contaminated with
lead (up to 27,000 ppm) and PAHs (0.5 ppm to 10 ppm) at depths ranging from the surface to
6 feet. In addition, both NUS and CDM observed that these soils were visibly contaminated
with oil.
Geophysical anomalies defined during the fall 1993 field investigation (M&E, 1994a) were
interpreted to represent the contrast in electrical conductivity between the buried oil and sludge
and other subsurface materials. This suggests that the horizontal extent of the waste is beyond
the limits of the study area. Detectable quantities of chlorinated volatiles (DCE and
vinyl chloride) were reported in groundwater-screening data. In the southern portion of this
area, the presence of oil and sludge was confirmed by borings, test pits, and the observation of
free product in piezometer P-12. In addition, alkanes, PAHs, and pesticides were reported in
preliminary subsurface soil data from this area.
2.1.1.4 Contaminated Soil Area. The emphasis for identifying contaminated soil was based
upon the results of a random soil boring program conducted across the site that indicated
elevated levels of lead (310 to 76,600 ppm) at nine out of forty locations. The results for
locations where lead levels exceeded expected background levels (300 ppm; CDM, 1987; 1989a)
are presented in Table 2-2. In particular, there are two locations on B&M property where lead
concentrations were present at percent levels (in the contaminated soil area).
Other than these two locations, the highest lead levels occurred on the Penn Culvert property
in the old B&M oil/sludge recycling area. Groundwater samples collected in the vicinity of
these areas did not contain detectable levels of lead.
As part of the recent field investigation (summer and fall 1993), surface soils were collected
from this area. The final results of the analytical sampling will be incorporated into the RI
report.
2-5
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2-6
TABLE 2-2. LEAD LEVELS IN SITE SOILS THAT EXCEED TYPICAL BACKGROUND LEVELS FOUND IN NEW ENGLAND SOILS(1)
Sample Location
NUS Samples Collected 12/83
Penn Culvert
Penn Culvert
Penn Culvert
CDM Samples Collected 11/85 and 3/86
Johns-Manville
Johns-Manville
B&M
B&M
B&M
B&M
B&M
B&M
B&M
Penn Culvert
Penn Culvert
Penn Culvert
Penn Culvert
1. Source: CDM, 1989b
Sample Identification
IHP-S67
IHP-S68
IHP-S69
SB-22-030
SB-26-039
SB-28-054
SB-28-055
SB-30-043
PZ-08-017
PZ-09-020
PZ-09A-021
PZ-18-042
PZ-11A-026
PZ-12-027
PZ-12A-028
PZ-12A-029
Sample Depth (feet)
2
2
2
0-1
0-1
0-1
3-4
0-1
0-2
0-2
4.5-6.5
0-2
5-7
0-2
4-6
4-6
Lead Concentration (ppm)
23,900
26,900
19,900
315
310
76,600
527
539
2,890
59,200
4,610
2,940
362
4,760
2,220
2,930
2-7
2.1.1.5 Asbestos Contamination. Asbestos contamination associated with the asbestos landfill
and asbestos lagoons are described in the following sections.
Asbestos Landfill. The Iron Horse Industrial Park has historically been identified with asbestos
contamination due to asbestos landfilling operations conducted by Johns-Manville over a 32-year
period. Despite the fact that EPA capped the asbestos landfill hi 1984, "asbestos contamination"
was identified by CDM (1987) as a potential operable unit because the cap is not currently
maintained. Asbestos materials have been found outside the limits of the cap, and the entire
western boundary of the cap is not fenced. In 1985, during Phase 1A RI (CDM, 1987), surficial
soils (0 to 3 inches) from 40 random boring locations were also analyzed for the presence of
asbestos. Asbestos was detected at 28 of the locations sampled and 8 out of these 28 locations
located on Johns-Manville, Perm Culvert, and B&M properties, asbestos was present at greater
than 1% (Figure 1-3).
This suggested that windblown deposition of asbestos (CDM, 1989) had occurred in portions of
the site on B&M property adjacent to the landfill, as well as Johns-Manville property where the
asbestos waste originated.
An off-site soil sampling program (CDM, 1988) was also conducted to determine the extent to
which, if any, windblown deposition of asbestos had occurred in residential areas bordering the
Iron Horse Industrial Park.
The results of the off-site soil sampling indicated that, with one exception, there were no
detectable levels of asbestos in residential areas bordering the site. Therefore, CDM (1989)
concluded that wind-blown deposition of asbestos from the site to off-site areas most likely did
not occur. The integrity of the asbestos landfill cap were evaluated as part of the RI.
The Asbestos Landfill Evaluation Report (M&E, 1994b) was submitted to EPA in February
1994. This report documents recent finding of current surficial conditions of the landfill.
2-8
Recommendations of corrective actions to be implemented to protect public health and comply
with state and federal regulations were provided.
Asbestos Lagoons. In addition to the asbestos landfill, there are three unlined asbestos lagoons
on Johns-Manville property. One of these lagoons has been filled and covered. When the
lagoons were operated by Johns-Manville they received an asbestos slurry pumped from the
adjacent manufacturing operations. Asbestos from these lagoons was disposed of in the asbestos
landfill; however, the lagoons still contain some asbestos. The lagoons continued to receive
wastewater from Johns-Manville operations after asbestos manufacturing operations closed.
While this discharge did not contain asbestos, it may have had some hazardous substances in it
(CDM, 1989b). This area will be sampled as part of the RI.
Volatile organics, including benzene, xylene, PCE, and DCE were detected in groundwater
screened during the recent field investigation (fall 1993). Samples collected from the uncovered
asbestos lagoons reported detectable levels of aromatic volatile organics (toluene and xylenes)
and pesticides.
As part of the recent field investigation (summer/fall 1993), sediment samples were collected
from the asbestos lagoons. The final results of the analytical sampling will be incorporated into
the RI report.
2.1.1.6 PCB Contamination. As a result of PCBs found in sediments and soils associated with
a separate storm drain system on the Johns-Manville property, PCB contamination was identified
as an area of concern. PCBs were not detected in any other sediments or soils located
throughout the Iron Horse Industrial Park or hi the vicinity of the Shaffer landfill.
In 1985, during the CDM Phase 1A RI, PCBs were discovered hi the Johns-Manville storm
drain system which discharges to the Middlesex Canal. Sediments from two of the catch basins
in that system as well as sediments from the Middlesex Canal were contaminated with
concentrations of PCBs ranging from 10 to 270 ppm. Following this discovery, Johns-Manville
2-9
hired GZA as a consultant and initiated an independent investigation of their storm drain system.
GZA conducted three separate sampling events, in which CDM split samples with them. These
sampling events involved collecting sediments from six catch basins/manholes and from eight
locations along the Middlesex Canal as well as soils adjacent to those six catch basin/manhole
locations. The samples from the catch basins/manholes were actually obtained during a dredging
operation conducted by a hazardous waste contractor through GZA. All sampling locations are
presented in Figure 4-4 of the Phase 1A RI report (CDM, 1987).
The results of the additional sampling done by GZA confirmed the presence of PCBs in
Middlesex Canal sediments found near the discharge pipe, and also confirmed the presence of
PCBs in two additional manholes that were part of the system. The results of soil sampling done
adjacent to the old catch basins revealed PCB concentrations in soils ranging from 1.5 to
20 ppm. It is noted that in July and September 1986, GZA performed two additional sampling
rounds on the Johns-Manville storm drain system in which neither EPA nor CDM personnel
were present. A few months later, Johns-Manville informed EPA that 20 feet of the storm drain
discharge pipe to the Middlesex Canal was dug up and removed. Johns-Manville stated that the
end of the pipe was sealed with a concrete plug and that the discharge system was no longer in
service.
The Middlesex Canal was sampled by CDM in six locations both upgradient and downgradient
from this discharge pipe, and no detectable levels of PCBs were found. It appeared that no
migration of PCBs occurred from this discharge point. These PCB data from previous
investigations were evaluated as part of the RI.
During February 1994, the PCB Contamination Evaluation Report (M&E, 1994c) was submitted
to EPA. This report compiled and evaluated all available data and subsequent remedial
recommendations presented in the Phase 1A report (CDM, 1987) and the PCB Investigation
Report (GZA, 1987) to develop a full understanding of the potential contamination that may exist
in the area of the site. Recommendations of corrective actions to be implemented to protect
public health were provided.
2-10
2.1.1.7 Groundwater. Elevated concentrations of volatile organics have been detected in
groundwater east of the Shaffer landfill, and were also measured at lower concentrations in
groundwater north, west, and northwest of the landfill. Semivolatile compounds were found in
groundwater downgradient and southeast of the landfill along Gray Street. In areas north and
upgradient of the landfill, metals were found in groundwater at elevated concentrations
(CDM, 1991).
During the recent field investigation (fall 1993), shallow groundwater was screened for volatile
organics using a field gas chromatograph. 1,1-DCE, cw-l,2-DCE, vinyl chloride, and benzene
were detected at the site in the vicinity of the areas of concern.
2.1.1.8 Surface Water. During the Phase 1A RI, surface water was collected from 19
locations. The highest volatile organic concentrations were found north of the Shaffer landfill
on the southern edge of Richardson's Pond, and along Content Brook. The Ambient Water
Quality Criteria were exceeded for arsenic in all samples (CDM, 1991).
Two rounds (high and low flow) of surface water samples were collected during the summer/fall
of 1993. The final analytical results will be incorporated into the RI report.
2.1.1.9 Sediment. During the Phase 1A RI, sediment samples were collected at 33 locations.
Volatile organics concentrations were highest along the northern edge of the Shaffer landfill and
the southern edge of Richardson's Pond. Semivolatile compounds were found both upstream and
downstream of the landfill. Low levels of pesticides were also detected in the vicinity of the
landfill (CDM, 1991).
Two rounds of sediment samples were collected concurrently with the surface water samples
described in section 2.1.1.8. The final analytical results will be incorporated into the RI report.
2-11
2.1.2 Hydrogeological Investigation
To date, hydrogeological investigations have been included in each of the three Phase 1 RIs
conducted at the Iron Horse Park site and the current RI.
The Phase 1A hydrogeological investigation (CDM, 1987) included the installation of 53
monitoring wells and 19 piezometers in an effort to characterize the groundwater flow system
at the site. The monitoring wells were installed in the shallow and deep overburden and in the
bedrock. Falling head tests were performed on all of the wells to estimate aquifer
transmissivities. Three rounds of groundwater elevation measurements were made. The Phase
IB hydrogeological investigation (CDM, 1988) concentrated on groundwater in the vicinity of
the B&M wastewater lagoons. No additional monitoring wells were installed. Thirteen selected
monitoring wells from the Phase 1A investigation were used in the Phase IB study.
The Phase 1C hydrogeological investigation (CDM, 1989a) focused on the Shaffer landfill area
and included the installation of 21 mini-piezometers to identify groundwater discharge and
recharge areas and four monitoring well clusters of three wells each. The Phase 1C
investigation also used 37 previously installed monitoring wells for groundwater elevation data.
Water level elevations were measured once and permeability testing was performed in the newly
installed monitoring wells.
Geophysical surveys were conducted during the Phase 1A and Phase 1C investigations. Seismic
refraction was conducted to determine depth to water and depth to bedrock during both Phase 1A
(CDM, 1987) and Phase 1C (CDM, 1989a). Ground penetrating radar was performed during
the Phase 1A to identify potential drilling obstructions. Electromagnetic conductivity was
measured during Phase 1C to determine the thickness of fill at the Shaffer landfill and to identify
potential areas of leachate migration.
During the recent field investigation (summer/fall 1993), geophysical surveys (EM and GPR)
and water level measurements were conducted. Results of the geophysical surveys and a
2-12
preliminary hydrogeological investigation conducted as part of the current RI are presented in
the Hydrogeological Assessment Report (M&E, 1994a).
2.2 IDENTIFICATION OF RI DATA NEEDS
Following the Phase 1 RIs, CDM identified data needs for future work in areas of the 3rd
operable unit (CDM, 1989a). These are summarized in Table 2-3. Based upon CDM
recommendations and further EPA review, an SOW was developed. The SOW was further
defined during a scoping meeting held on October 22, 1992, and subsequent discussions between
M&E and EPA. In addition to the areas identified hi Table 2-3, it was decided that the asbestos
lagoons, site-wide groundwater and surface water and sediment, and ecological characterization
would also be evaluated as part of the 3rd operable unit RI. Most recently, as part of
WA#36-IL57, Revision 12, groundwater will be evaluated in the B&M Railroad landfill, B&M
locomotive shop disposal area, the RSI landfill, the old B&M oil/sludge recycling area, and the
asbestos lagoons. A summary of the RI activities for the 3rd operable unit is presented in
Table 2-4.
The RI activities for the 3rd operable unit are designed to generate data necessary to help fulfill
specific needs. These data needs are described hi the following section.
2.2.1 Nature and Extent
Contaminants hi the 3rd operable unit are likely to have been distributed throughout several
phases. Other than their presence hi the original fill material, these compounds are likely to be
detected hi groundwater, hi adjacent surface waters, and in soil and sediment. The RI will
evaluate presence or absence of contaminants as related to present and historical activities at the
site as well as the extent to which contaminants have either vertically or laterally migrated from
the original source material.
2-13
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2.2.2 Data for Prediction of Contaminant Migration
In addition to describing the current nature and extent of contamination in relation to the source
areas, the RI should develop information needed to predict future contaminant migration.
Information to predict migration of contaminants hi groundwater typically include soil
permeability, groundwater flow direction, and the organic content of soils.
2.2.3 Public Health Risk Assessment
Data needed for the public health risk assessment includes information regarding the nature and
extent of contamination, with emphasis on contaminants detected in surface soil, sediment,
surface water, and groundwater in the vicinity of the site. Also needed are a demographic
characterization of the surrounding community, population distribution surrounding the site, and
consideration of present and future land uses, including frequency of recreation use at the site
and groundwater usage.
2.2.4 Ecological Risk Assessment
Data needed for the ecological risk assessment includes information pertaining to the ecological
resources present as well as the nature and extent of contamination, with emphasis on
contaminant concentrations hi surface water, sediment and soil, and migration to potential
off-site areas. The ecological resources information that is needed includes identification of
potential food webs and energy pathways and likely mechanisms for potential biomagnification
and trophic magnification.
2.3 RI OBJECTIVES
The primary objective of the RI will be to assess site conditions at the 3rd operable unit and
evaluate the nature and extent of contamination at the site hi order to reflect the intent of the
EPA's developing policies for RI studies as described hi Guidance for Conducting Remedial
2-16
Investigation and Feasibility Studies Under CERCLA (U.S. EPA, 1988a) and the
NCP (40 CFR Part 300).
The overall objectives of the RI activities described in this work plan amendment are to:
• Complete a field program for collecting data to quantify the nature and extent of contamination in the groundwater.
• Assess the public health risk associated with any existing groundwater contamination.
The data collected during the current RI activities will be used for site characterization and risk
assessment. In order to achieve the RI data quality objectives (DQOs), a combination of
laboratory services and field testing will be used and are discussed below:
• Field screening (Level I) will provide the lowest data quality, but the fastest results, and will be used at the site for health and safety monitoring and preliminary screening of samples to identify those requiring confirmation sampling (Level IV). A FID and/or a PID will be used for Level I analysis. Other Level I analyses includepH, Eh, conductivity, dissolved oxygen (DO), and turbidity. These data provide presence-absence of certain constituents and will be generally qualitative rather than quantitative.
• Geotechnical analysis of selected soil samples, to determine soil characteristics is considered as Level III. Geotechnical analysis which include total combustible organics, moisture content, grain size, porosity, and permeability will be conducted by a subcontracted geotechnical laboratory.
• Confirmational analysis (Level IV), which provides the highest level of data quality, will be used for risk assessment and cost recovery documentation. Included at this level are standard CLP-RAS methods. All analytical samples analyzed as RAS will be collected and validated to provide Level IV data quality. In addition, DAS analysis of low-level pesticides and PCBs in groundwater will have report deliverables that meet Level IV data requirements.
• Non CLP method (Level V) will be used for the DAS analysis of alkalinity, total organic carbon (TOC), total petroleum hydrocarbons (TPH), biological oxygen demand (BOD), chemical oxygen demand (COD), total dissolved solids (TDS),
2-17
total suspended solids (TSS), sulfate, phosphorous, nitrate/nitrite, and chloride. The DAS analyses will require laboratory deliverables that will be specified in the DAS analytical specifications.
All DAS analytical specifications will be submitted to EPA for approval. All RAS analytical
data (Level IV) and DAS pesticide/PCB data will be validated to Tier III as specified in the EPA
Region I Memorandum (U.S. EPA, 1993) and hi accordance with EPA Region I Laboratory Data
Validation Functional Guidelines for Evaluating Organics Analysis (U.S. EPA, 1988b) and EPA
Region I Laboratory Data Validation Functional Guidelines for Evaluating Inorganics Analysis
(U.S. EPA, 1989a); modified to meet criteria in the current SOWs for RAS organic and
inorganic analyses (U.S. EPA, 1991a; 1991b). All DAS analytical data (Level V) will be
reviewed and validated to ensure that it meets the data requirements in the DAS analytical
specifications. Geotechnical analyses will be reviewed, but not validated. Level I field
screening data will be reviewed only.
2-18
3.0 TECHNICAL APPROACH
This section of the work plan amendment presents the technical approach to the remedial
investigation activities that will be conducted during the hydrogeological and groundwater
sampling investigation.
3.1 PROJECT PLANNING (TASK 1)
Included in this task are development of the work plan amendment to the Final Work Plan
(M&E, 1993a); obtaining appropriate approvals for the work plan amendment budget, and
schedule; preparation of the Sampling and Analysis Plan (SAP) Addendum, which consists of
the modification of the Field Sampling Plan (FSP; M&E, 1993b) and Quality Assurance Project
Plan (QAPP; M&E, 1993c); and modification of the Site Safety and Health Plan (SSHP;
M&E, 1993d) for the field activities; project management; a meeting with EPA and the DEP;
and subcontractor procurement.
3.1.1 RI Work Plan Amendment
This subtask includes a description of RI tasks associated with the hydrogeological investigation
and groundwater sampling as well as preparation of the work plan amendment, budgets, and
schedules for implementing the proposed RI tasks. Activities in this subtask include preparation
of the draft work plan amendment; internal review of the draft before submission for EPA
review; incorporation of EPA review comments; and submittal of the final work plan
amendment.
3.1.2 Sampling and Analysis Plan Addendum
Included in this subtask will be modifications to the existing FSP (M&E, 1993b) and QAPP
(M&E, 1993c) for the proposed RI field activities. Modifications to the FSP and QAPP will be
presented in separate sections as part of a SAP Addendum. The SAP addendum will follow the
3-1
same format as the existing plans. Modifications or new material will be described in detail
in the SAP Addendum, with references to the FSP and QAPP, as appropriate. As part of the
SAP Addendum, the QAPP section will describe the analytical procedures and quality assurance
and quality control (QA/QC) protocols necessary to achieve DQOs. The QAPP section will
incorporate any modifications, which are related to the delivery of analytical services (DAS)
program.
The FSP section of the SAP addendum will provide guidance for all proposed field work
including the sampling and subsurface investigative methods to be used. The proposed sampling
locations, investigative techniques, collection and handling procedures, and the equipment
necessary for sampling and testing will be described. The procedures outlined in the
Compendium of Superfund Field Operation Methods (U.S. EPA, 1987) and other EPA guidance
will be used as appropriate, to modify the FSP. Modifications to the sample custody procedures,
including those related to chain-of custody, in relation to the DAS program will be delineated
hi the FSP.
For the cost estimate, it is assumed that the SAP addendum will be submitted for EPA review
and that no changes will be necessary. Quality control for all documents submitted to EPA will
be provided.
3.1.3 Site Safety and Health Plan Addendum
The SSHP (M&E, 1993d) previously prepared for the site will be modified to include the
proposed field activities, as well as, incorporate new data that was obtained as part of the 1993
field investigations. Quality control of the SSHP Addendum will be provided.
3.1.4 Project Management
Day-to-day management of the RI will be handled within this subtask, which will include
telephone discussions with the RPM, actions as a result of telecons, meetings with the RPM,
3-2
preparing/editing correspondence to RPM, monitoring and controlling level of effort (LOE)/costs
and actions, subcontractor management and invoice review/approval, schedule maintenance and
analysis, staff scheduling, monthly report preparations, Summary Evaluation Report preparation,
project management staff meetings, meetings with DPM, and problem resolution. It is estimated
that the project planning period for this work assignment will continue through April 1996,
although project management costs have only been included through January 1996. It is assumed
that the budget for project management will be sufficient through April 1996, however, EPA will
be notified if additional funding is needed.
3.1.5 Meeting Attendance
During the additional fieldwork, project personnel will hold meetings with personnel from the
EPA Region I and Massachusetts DEP. Table 3-1 summarizes the subject, frequency,
participants, and locations of proposed meetings for Tasks 1 and Task 3 related to this work plan
amendment. For Tasks 1, it is assumed that one 4-hour meeting to discuss the work plan
amendment and 2 hours for preparation and travel will be required. Two meetings are planned
for Task 3 and costs have been included in that task.
3.1.6 Subcontractor Procurement
Some field investigation activities that will be conducted during the RI will require the services
of outside contractors. Technical and support services to be subcontracted are:
• Geophysical surveying
• Drilling
• Surveying
• Air sampling laboratory
• Data validation
3-3
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• Geotechnical laboratory analyses
• Removal of Rl-derived waste
M&E has established a Basic Ordering Agreement (BOA) for data validation (discussed in
section 3.4) and will issue a work order for site specific activities. Procurement for the other
service areas listed above will be managed under Task 1. It is anticipated that existing
subcontracts for geophysical and site surveying will be modified for new procurement, while
new subcontracts will be prepared and procured for drilling, geotechnical analyses, and air
sampling (for lead). Analytical costs and equipment rental and supplies for the air sampling
have been included in the Task 3 costs. The subcontract for removal of Rl-derived waste will
be developed following completion of the field activities. Based on the sampling results from
soil samples collected in the summer/fall of 1993, air sampling for lead during drilling
operations is necessary to comply with OSHA regulations.
3.1.7 Delivery of Analytical Services (DAS)
Analytical specifications for DAS methods will be developed under the Analytical Services work
assignment (WA#46-1HZZ) for the analysis of low-level pesticides/PCBs, TPH and water
quality parameters: alkalinity, BOD, chloride, COD, nitrate/nitrite, phosphorus, sulfate, TDS,
TSS, and TOC. It is anticipated that all LOE and costs associated with the development of the
DAS analytical specifications will be handled as part of WA#46-1HZZ.
3.2 COMMUNITY RELATIONS (Task 2)
Community relations activities for the project will occur throughout the RI activities. It is not
anticipated that the Task 2 budget will be impacted by the hydrogeological and groundwater
sampling activities. Therefore, no costs have been included for Task 2.
3-5
3.3 FIELD INVESTIGATIONS (Task 3)
The field investigation program for the Iron Horse Park site has been designed to collect data
that will facilitate meeting the RI objectives outlined in section 2.
The following RI field activities will be conducted:
• Surface Geophysical Surveys
• Hydrogeological Assessment Decontamination pad installation/clearing Piezometer installation and development Monitoring well installation and development Seepage meter installation Staff gauge installation Water level measurements Aquifer testing
• Environmental Sampling Soil boring sampling Groundwater sampling
• Site survey/mapping
• Field-generated waste disposal
• Field work support
• Meetings
Table 3-2 generally summarizes the field activities to be conducted during the RI. However,
if data gaps arise during RI activities, additional activities may be conducted. The scope and
costs for additional activities will be developed as needed during the RI.
3-6
TABLE 3-2. FIELD INVESTIGATION ACTIVITY SUMMARY
Activity
Surface Geophysical Surveys
Electromagnetic (EM)
Hydrogeological Assessment
Groundwater Elevation Measurements
Seepage Meter Measurements
Surface Water Elevation Measurements
Aquifer Testing
Monitoring Well Soil Borings
Purpose
Determine horizontal extent of oil/sludge in the old B&M oil/sludge recycling area.
Establish site-wide synoptic groundwater levels
Assess the relationship between shallow groundwater and surface water
Determine the head differential between groundwater and surface water near potential source areas
Determine the rate of groundwater flow and evaluate the feasibility of groundwater extraction
Assess the potential ability of contaminants to migrate through the overburden soils
Action
Conduct surveys in designated areas using 25-foot-grid spacing
Measure water levels in all monitoring wells and piezometers within a single 24-hour period
Collect stream-bed hydraulic conductivity data during same period groundwater levels are measured
Install staff gauges in surface water bodies at the site and measure water levels during same period groundwater levels are measured at the new and existing staff gauges
Perform hydraulic conductivity tests in select monitoring wells
Collect and analyze selected soils for total combustible organics (TCO), grain size, permeability, and porosity
3-7
TABLE 3-2 (Continued). FIELD INVESTIGATION ACTIVITY SUMMARY
Activity
Environmental Sampling
Groundwater Sampling
Purpose
Determine background concentrations of groundwater
Evaluate the type and extent of contamination in groundwater to evaluate human health risks
Assess potential seasonal fluctuations in contaminant concentrations
Action
Collect and analyze groundwater samples upgradient of the site
Collect and analyze groundwater upgradient and downgradient from the source areas and compare results to background levels
Collect two rounds of groundwater samples
3-8
3.3.1 Surface Geophysical Surveys
Electromagnetic (EM) or terrain conductivity surveys will be conducted in the vicinity of the old
B&M oil/sludge recycling area to delineate the horizontal extent of buried oil sludge. Previous
EM surveys in this area were successful in determining several concentrated areas of oil sludge
within the Penn Culvert compound, which defined the limits of the original survey area. The
additional EM-31 surveys will be conducted to the northwest and southeast of the original survey
area. The EM-31 data will be collected in the same manner as previous data was obtained, with
data for both quadrature-phase (apparent terrain conductivity) and in-phase data being recorded
at 10-foot intervals along grid lines spaced 25 feet apart.
It is assumed that 1-1/2 field days (10 hours) will be required to complete the additional
geophysical surveys. An M&E geologist will oversee the geophysical subcontractor. It is
assumed that the clearing of vegetation will be conducted by the survey subcontractor with
1/2 day of M&E oversight.
3.3.2 Hydrogeological Assessment
The hydrogeological assessment will consist of piezometer, monitoring well, seepage meter, and
staff gauge installation, measurement of water levels, and aquifer testing. The hydrogeological
groupings of monitoring wells and piezometers for the areas of concern are listed in Table 3-3.
The existing monitoring wells and piezometers and the proposed locations of the new monitoring
wells and piezometers are shown in Figure 3-1.
3.3.2.1 Decontamination Pad Construction/Site Clearing. Prior to the installation of
piezometers, decontamination pads will be installed in each of the five areas of concern. The
decontamination pads will each consist of a polyethylene-lined bed where drilling rigs and
drilling equipment will be steam cleaned. The area will be sloped such that decontamination
water can be collected in an adjacent polyethylene-lined pit. After each decontamination, a
sample of water from the pit will be collected and the sample headspace screened with a PID.
3-9
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TARGET SHEET
THE MATERIAL DESCRIBED BELOW WAS NOT SCANNED BECAUSE:
(X) OVERSIZED MAP
() NON-PAPER MEDIA
() OTHER:
DOC ED: 209743 DATE: September 1994 TITLE: FINAL WORK PLAN AMENDMENT FOR REMEDIAL
INVESTIGATION (RI) DESCRIPTION: FIGURE 3-1: EXISTING AND PROPOSED
LOCATIONS FOR MONITORING WELLS, PIEZOMETERS, STAFF GAUGES, AND SEEPAGE METERS
THE OMITTED MATERIAL IS AVAILABLE FOR REVIEW BY APPOINTMENT
AT THE EPA NEW ENGLAND SUPERFUND RECORDS CENTER, BOSTON, MA
Decontamination water that produces a reading higher than 10 ppm will be drummed, otherwise
decontamination water will be pumped out of the pit and allowed to infiltrate at that location.
It is assumed that the decon pads can be constructed by the drilling subcontractor in 2 days with
M&E oversight and it will not be necessary to collect and drum decontamination water. It is
also assumed that 3 days of site clearing by a 2-person team may be needed to provide drilling
rig access to some drilling locations.
3.3.2.2 Piezometer Installation. A total of 18 piezometers will be installed in five separate
areas on the site (Table 3-3; Figure 3-1) at depths specified in Table 3-4. The piezometers will
be installed in order to determine local shallow groundwater flow directions in each of the areas.
Piezometers will be installed in groupings of three at each of the following areas: B&M
Railroad landfill, RSI landfill, both of the B&M locomotive shop disposal areas (A & B), the
B&M oil/sludge recycling area, and the asbestos lagoons.
The 18 piezometers will be drilled using 2 1/2-inch hollow stem augers and will be constructed
of 2-inch-diameter schedule 40 PVC well screen and riser. Using water level data collected by
M&E in the fall of 1993, the depth to the water table at each piezometer location will be
estimated prior to the field effort. The estimated depth will be confirmed by taking a split-spoon
sample just above the depth at which the water table is expected to occur and continuously
thereafter until the water table is encountered. Each piezometer will have a 5-foot screen which
will be placed just below the water table. Using soil cuttings, the piezometers will be backfilled
to a minimum depth of 2 feet below the surface where a minimum 6-inch bentonite seal will be
placed. A 3-foot-long locking protective casing will then be installed with 1-1/2 feet below
ground with a grout seal. If the water table is less than 2 feet below the ground surface, the
dimensions of the piezometer completion will be adjusted accordingly.
Each of the piezometers will be developed using a bailer or pump. Water will be removed from
the piezometers until turbidity, pH, specific conductance, and temperature readings on successive
samples are within 10% of each other or until development efforts have continued for a
maximum of 2 hours per piezometer. It is assumed that it will not be necessary to drum well
3-12
Table 3-4. Estimated Depths of Proposed Piezometers, Monitoring Wells, and Seepage Meters
AREA/ MAT. SCREENED (1)WELLID
BACKGROUND Monitoring Wells
MW-200S SOB MW-200D DOB MW-200B BED
B&M RAILROAD LANDFILL Piezometers
PZ-101 SOB PZ-102 SOB PZ-103 SOB
Monitoring Wells MW-201S SOB MW-201D DOB MW-201B BED MW-202S SOB MW-202D DOB MW-202B BED MW-203S SOB MW-203D DOB MW-203B BED
Seepage Meters SM-1 SM-2
RSI LANDFILL Piezometers
PZ-104 SOB PZ-105 SOB PZ-106 SOB
Monitoring Wells MW-204S SOB MW-204D DOB MW-204B BED MW-205S SOB MW-205D DOB MW-205B BED MW-206S SOB MW-206D DOB MW-206B BED MW-215B BED
Seepage Meters SM-3 SM-4
B&M LOCOMOTIVE SHOP DISPOSAL AREAS AREAA Piezometers
PZ-107A SOB PZ-108A SOB PZ-109A SOB
Monitoring Wells MW-207S SOB MW-207D DOB MW-207B BED
ESTIMATED DEPTH(FT)
20 40 80
15 15 15
20 40 80 20 40 80 20 40 80
15 15 15
20 40 70 20 40 70 20 40 70 100
15 15 15
20 40 70
SCREENED INTERVAL (FT)
10-20 30-40 60-80
10-15 10-15 10-15
10-20 30-40 60-80 10-20 30-40 60-80 10-20 30-40 60-80
10-15 10-15 10-15
10-20 30-40 50-70 10-20 30-40 50-70 10-20 30-40 50-70 80-100
10-15 10-15 10-15
10-20 30-40 50-70
SCREEN LENGTH
10 10 20
5 5 5
10 10 20 10 10 20 10 10 20
5 5 5
10 10 20 10 10 20 10 10 20 20
5 5 5
10 10 20
3-13
B&M LOCOMOTIVE SHOP DISPOSAL AREAS AREAB Piezometers
PZ-107B PZ-108B PZ-109B
Monitoring Wells MW-208S MW-208D MW-208B MW-209S MW-209D MW-209B
Seepage Meters SM-5 SM-6
OLD B&M OIL/SLUDGE Piezometers
PZ-110 PZ-111 PZ-112
Monitoring Wells MW-210S MW-210D MW-210B MW-211S MW-211D MW-211B MW-212S MW-212D MW-212B
Seepage Meters SM-7 SM-8
ASBESTOS LAGOONS Piezometers
PZ-113 PZ-114 PZ-115
Monitoring Wells MW-213S MW-213D MW-213B MW-214B
Seepage Meters SM-9 SM-10
NOTES: 1. Defines material that monitoring well is screened in. SOB - Shallow Overburden DOB - Deep Overburden BED - Bedrock
Table 3-4. Estimated Depths of Proposed Piezometers, Monitoring Wells, and Seepage Meters
AREA/ MAT. SCREENED (1) ESTIMATED SCREENED SCREEN WELL ID DEPTH (FT) INTERVAL (FT) LENGTH
SOB 15 SOB 15 SOB 15
SOB 20 DOB 40 BED 70 SOB 20 DOB 40 BED 70
RECYCLING AREA
SOB 15 SOB 15 SOB 15
SOB 20 DOB 40 BED 70 SOB 20 DOB 40 BED 70 SOB 20 DOB 40 BED 70
SOB 15 SOB 15 SOB 15
SOB 20 DOB 40 BED 70 BED 100
10-15 10-15 10-15
10-20 30-40 50-70 10-20 30-40 50-70
10-15 10-15 10-15
10-20 30-40 50-70 10-20 30-40 50-70 10-20 30-40 50-70
10-15 10-15 10-15
10-20 30-40 50-70 80-100
5 5 5
10 10 20 10 10 20
5 5 5
10 10 20 10 10 20 10 10 20
5 5 5
10 10 20 20
3-14
development water.
The drilling rigs and all associated downhole equipment will be steam cleaned prior to the
installation of each piezometer and after the last piezometer is completed.
It is assumed that the piezometers will be drilled to a maximum depth of 15 feet and that
3 piezometers can be installed in one day per drilling rig. Piezometers will be installed using
two drilling rigs, each under the supervision of an M&E geologist. It is assumed that all
locations will be selected and staked in one 10-hour day by two persons. It is estimated that the
drilling and installation operations will be completed in three days. Two half days (6 hours)
have been estimated per geologist for mobilization and demobilization. Development will be
conducted following piezometer installation. For the purpose of this work plan amendment, it
is estimated that development will be conducted by the drilling subcontractor with oversight of
two M&E geologists and be completed in 1-1/2 days (2 hours per piezometer).
3.3.2.3 Monitoring Well Installation. A total of 14 monitoring well clusters and two bedrock
wells that will be added to existing clusters will be installed in this field effort (Table 3-3;
Figure 3-1) at depths specified in Table 3-4. Monitoring well clusters will be installed in the
vicinity of the B&M Railroad landfill, the RSI landfill, the B&M locomotive shop disposal area,
the B&M oil/sludge recycling area and the asbestos lagoons. In addition, one background
monitoring well cluster will be installed upgradient of the site. Each of the monitoring well
clusters will consist of a shallow overburden well, a deep overburden well, and a bedrock well.
Bedrock monitoring wells will be installed at existing overburden monitoring well clusters
OW-20/OW-21 and OW-25/OW-26/OW-27.
It is assumed that the locations for the proposed monitoring wells will be selected and staked in
two 10-hour days by a two person team. It is estimated that the monitoring wells will be
installed during a single field effort during which 3 drilling rigs will be mobilized. All drilling
and well installation activities will be supervised by M&E geologists. Geologic boring logs and
well installation specifications will be recorded by the geologist for each drilling location. For
3-15
cost estimating purposes, two half days (6 hours) has been estimated for mobilization and
demobilization per geologist.
Overburden Monitoring Wells. Because of the vertical distribution of overburden groundwater
contamination previously determined at the site, monitoring wells to be installed in the
overburden will target shallow and deep screened intervals to further characterize groundwater
quality hi the vicinity of each of the five areas. Overburden monitoring wells will be installed
similarly to the OW series wells.
Shallow overburden OW series wells were screened below the water table and without a strict
criteria for the position of the top of the screen with respect to the water table. Deep
overburden OW series wells were screened such that the base of the screen was set at the top
of glacial till, if present, or at the top of bedrock. Shallow and deep overburden wells in the
OW series were screened such that the distance between the bottom of the shallow well and the
top of the deep well was no more than 10 to 15 feet, which is the reason some of the OW series
monitoring well clusters have two shallow wells.
Shallow overburden wells installed during this field effort will be placed with the top of the
screen being set a maximum of 5 feet below the water table. Deep overburden wells will be
install such that the bottom of the screen is set at the top of the glacial till, if present, or at the
base of the overburden if the till is not present.
Overburden monitoring wells will be drilled using 4 1/4-inch diameter hollow stem augers. At
each monitoring well cluster location, the deep overburden well will be drilled prior to the
shallow well and the overburden stratigraphy determined by the collection of split-spoon
samples, taken continuously to the water table and every five feet thereafter. With the possible
exception of geotechnical samples, no samples will be taken during the installation of the shallow
monitoring wells.
3-16
All overburden monitoring wells will have 10-foot screens and be constructed of 2-inch-diameter
schedule 40 PVC well screen and riser. Once the screen and riser have been centered in the
borehole at the proper depth, a sand pack will be placed around the well screen to a depth of
2 feet above the top of the screen. A minimum 2-foot-thick bentonite seal will be placed above
the sand pack and the borehole will be grouted to the surface. A locking steel protective casing
will be installed over the riser pipe with a sloping concrete pad. Each well will be locked with
keyed-alike locks.
The overburden monitoring wells will be developed using a pump or bailer, depending on the
expected recovery capacity of the well and the volume of water to be removed. The wells will
be developed until measurements of turbidity, pH, specific conductance, and temperature
readings have stabilized to within 10% of each other or until development efforts have continued
for a maximum of 3 hours per well. One M&E geologist will oversee the drilling subcontractor.
It is also estimated that 6 existing overburden wells will be developed for a maximum of 3 hours
per well by a two-person team.
Prior to beginning the installation of each monitoring well and after the last monitoring well, the
drill rigs and associated downhole equipment will be steam cleaned.
It is assumed a shallow overburden well will be installed in 1/2 day and a deep overburden well
will be installed in 1-1/2 days.
Bedrock Monitoring Wells. Drilling methods and construction details for bedrock wells to be
installed in this field effort will be similar to the OW series bedrock wells. Bedrock monitoring
wells will be drilled by spinning or driving 5-inch diameter steel casing into the top of the
bedrock surface. A nominal 4 1/2-inch borehole will then be drilled a maximum of 30 feet into
the rock using rotary drilling methods. Drill cuttings will be collected and described by the
M&E geologist in a rock drilling log which will be maintained for each bedrock borehole.
Drilling tunes (feet/minute) will also be noted as well as depths at which indications of possible
3-17
fracture zones occur during drilling, such as losses in circulation of drilling fluids or water
entering the borehole.
Bedrock monitoring wells will be screened across intervals which are most likely to contain
water bearing fractures, as determined by the geologist. Bedrock wells will be screened using
10- or 20-foot screens, depending on the conditions encountered in the borehole.
Bedrock well screens and risers will be constructed using 2-inch-diameter schedule 40 PVC pipe.
After the screen and riser pipe have been placed in the hole at the appropriate depth, a sand pack
will be placed around the well screen to a minimum height of 2 feet above the top of the screen.
A minimum 2-foot-thick bentonite seal will then be placed above the sand pack and the borehole
grouted to the surface using a neat cement grout.
Bedrock wells will be completed with the installation of a locking steel protective casing and a
sloping concrete pad. The bedrock wells will be locked with keyed alike locks. Bedrock wells
will be developed in the same manner as overburden monitoring wells. The drilling rig and all
associated equipment will be steam cleaned prior to drilling each bedrock well and after the
completion of the last well.
It is assumed that no coring of bedrock will be performed and that each bedrock well installation
will require 2 days. It is estimated that each bedrock well will be developed a maximum of
3 hours. One M&E geologist will oversee the drilling subcontractor. In addition, 6 existing
wells will be developed by a two-person team for a maximum of 3 hours per well. The existing
bedrock wells will be developed with the existing overburden wells.
3.3.2.4 Seepage Meter Installation. A total of ten seepage meters will be installed in surface
water bodies associated with each of the five areas to be investigated during this field effort (see
Figure 3-1; Table 3-4). The seepage meters will be installed in order to verify and quantify the
interaction between groundwater and surface water in the vicinity of each of the five areas so
that the potential for the discharge of contaminated groundwater can be evaluated. It is planned
3-18
that two seepage meters will be installed near each area. The hydraulic conductivity of the
stream-bed, lake, or canal bottom and a seepage rate will be determined at each seepage meter
location.
The seepage meters will be constructed using end-sections of 55-gallon drums, with the drums
being placed open-end down approximately 6 niches into the bottom of the surface water body.
A plastic bag equipped with a valve will be attached to Tygon tubing which will be connected
to the drum with a water-tight seal.
The valve, which is closed during the underwater attachment process, will be opened once the
seepage meter is in place. The volume of water entering the bag will be measured and recorded
using a graduated cylinder. Hydraulic conductivity values will be calculated using the volume
of water collected in the bag.
It is assumed that the 10 seepage meters can be installed by a two-person team in two days.
3.3.2.5 Staff Gauge Installation. In addition to the existing 9 staff gauge locations installed
during the hydrogeological assessment, up to 5 additional locations will be installed to determine
the relationship between groundwater and surface water (see Figure 3-1; Table 3-4). Staff
gauges will consist of steel stakes with steel graduated rulers attached.
For costing purposes, it is assumed that the 5 staff gauges can be installed by a two-person team
in one 8-hour day.
3.3.2.6 Water Level Measurements. Three rounds of water level measurements will be
conducted. A preliminary round will be measured following piezometer installation and prior
to new monitoring well, staff gauge, and seepage meter installation. Two additional rounds of
groundwater measurements will be conducted following each groundwater sampling round.
3-19
Preliminary Round. Water levels will be measured in all newly installed piezometers and at
selected existing monitoring well, piezometer, and staff gauge locations which are adjacent to
the areas hi which the piezometers are installed. Water level elevations measured in the new
piezometers and adjacent measuring points will be used to determine local shallow groundwater
flow directions in each of the five areas.
For purposes of cost estimating, it is assumed that, in addition to the 18 newly installed
piezometers, up to 50 additional locations will be measured during this preliminary round. It
is estimated that water level measurements will be collected by three two-person teams in a
single 12-hour period.
Round 1. Water level measurement Round 1 will be conducted within one week following
groundwater sampling Round 1. Water levels in all newly installed piezometers and monitoring
wells, existing piezometers and monitoring wells, and existing staff gauges will be measured
within a single 10-hour period by five 2-person teams. In addition, the newly installed seepage
meters will be measured hi two 10-hour days by a 2-person team.
For purposes of cost estimating, it is assumed that the following data points will be measured
during Round 1:
• 53 existing monitoring wells
• 10 existing piezometers
• 9 existing staff gauge locations
• 44 new monitoring wells
• 18 new piezometers
• 10 new seepage meter locations
• 5 new staff gauge locations
3-20
Round 2. Water level measurement Round 2 will be conducted within one week following
ground water sampling Round 2. Water level measurements in Round 2 will be the same in
scope and will be conducted hi the same manner as Round 1.
3.3.2.7 Aquifer Testing. Estimates of hydraulic conductivity (K) will be determined for each
of the 44 newly installed monitoring wells. Slug tests will be performed after the first round
of groundwater samples have been collected.
The slug tests will be conducted in the following manner:
1. Using a decontaminated water level indicator, the static water level hi the well will
be measured and recorded.
2. A decontaminated 10 or 20 psi pressure transducer will be lowered into the well and
secured at a minimum predetermined depth of approximately 10-15 feet below the water
table. The well will then be allowed to recover to static level.
3. The feet of head being read by the transducer will then be checked using the data
logger readout. If any discrepancy exists, the transducer will be replaced and rechecked.
4. A decontaminated solid slug of known volume will be instantaneously introduced into
the well and the response will be recorded with the data logger.
5. After the well has recovered to static level, the slug will be instantaneously removed
from the well and the response will be recorded with the data logger.
Well response data will be analyzed using both the Hvorslev (1951) and Bouwer and Rice
(Bouwer, 1989) methods. It is assumed that slug testing at each well will be conducted in
3 hours by a 2-person team and data analysis (Task 5) for each well will require 2 hours/well.
3-21
3.3.3 Environmental Sampling
Soil boring and groundwater samples will be collected for laboratory analysis. The parameters,
analytical methods, quantities of samples, and associated QA/QC samples are summarized in
Table 3-5. Details of sampling methods, collection of blanks and field duplicates, preservation
of samples, and sample handling and shipping are presented in the SAP.
Existing and proposed sampling locations for monitoring wells are presented in Figure 3-1.
Actual locations for the new monitoring wells will be determined based on field conditions.
3.3.3.1 Soil Borings. Twenty subsurface soil samples will be collected by the geologists from
selected soil borings drilled for monitoring well installation based on field observations. Twenty
of the samples will be submitted to a subcontracted geotechnical laboratory for the analysis of
total combustible organics (TCO), moisture content, grain size, permeability, and porosity.
Table 3-5 summarizes the parameters, analytical methods, and sample quantities. It is estimated
that an additional person will be onsite 1/2 day per week (6 hours) during monitoring well
installation activities to package and ship the selected samples to the laboratory.
3.3.3.2 Groundwater. Groundwater will be collected during two rounds to evaluate seasonal
variations. A total of 44 new monitoring wells and 27 existing monitoring wells will be
sampled. The new and existing wells are listed by area in Table 3-3. Samples will be collected
using the low-flow purge and sampling method. It is expected that three wells per day can be
sampled, packaged, and shipped by a two-person team. This assumes that shallow and deep
overburden wells can be purged and sampled within 3 hours each, and that bedrock wells will
take no longer than 8 hours to purge. Peristaltic pumps with dedicated Teflon-coated
polyethylene or rigid Teflon tubing will be used to purge and sample new and existing wells.
Submersible pumps will be used at wells where the peristaltic pumps are not feasible (i.e., depth
to water exceeds 20 feet). During purging field parameters (temperature, pH, specific
conductance, dissolved oxygen, Eh, and turbidity) will be measured at specified intervals.
Purging will continue until pH and specific conductance readings have stabilized (i.e., are within
3-22
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3-24
10% for three consecutive readings). If these field parameters have not stabilized after the
above-mentioned periods of time, technical judgement will be used to determine whether the well
has been sufficiently purged. It is assumed that one person can monitor the purging process
once the equipment has been setup and that purging will continue without problems. Therefore,
it is anticipated that the second person will be available on a part-tune basis to package samples
and assist with other field duties.
Samples will be analyzed for target compound list (TCL) volatile organics, TCL semivolatile
organics, low-level pesticides/PCBs, target analyte list (TAL) metals, cyanide, TPH, and water
quality parameters (alkalinity, BOD, chloride, COD, nitrate/nitrite, phosphorous, sulfate, TDS,
TSS, and TOC). Field parameters will also be measured at sample collection. Field QC
samples will also be collected during both rounds as shown in Table 3-5.
For cost estimating purposes, it is assumed that three 2-person teams can sample 71 wells hi
8 days and mobilization/demobilization can be conducted by 3 persons in two 6-hour days.
3.3.4 Site Survey/Mapping
A Massachusetts licensed surveyor will survey all new piezometers (18), monitoring wells (44),
seepage meters (10), and staff gauges (5). The surveyed elevations and coordinates based on
the Massachusetts State Plane Coordinate System will be plotted on the base map. It is planned
that one M&E personnel will accompany the surveyors for one day.
3.3.5 Field Generated Waste Disposal
Wastes derived from the RI field tasks will include: soil cuttings from soil borings and test pits,
water produced from equipment decontamination, and field clothes and assorted trash. Wastes
generated during the RI will be disposed of in accordance Guide to Management of Investigation
- Derived Wastes (U.S. EPA, 1992). If hazardous wastes are sent off site, both administrative
3-25
and substantive elements of the RCRA generator requirements of 40 CFR Part 262 and land
disposal restrictions and certification requirements of Part 268 will be complied with.
Soil cuttings. Soil cuttings generated from soil borings from piezometers and monitoring wells
will be screened for total organic vapors using a PID, FID, or other appropriate detection
equipment. If organic vapors are detected above 10 ppm, the drilling at that location will be
stopped and the EPA RPM will be notified to authorize the drumming of the waste. Once the
EPA RPM has been notified, contaminated drill cuttings will be drummed. If organic vapors
are below 10 ppm the cuttings will be disposed of at the drilling or test pit location. The drill
cuttings will be spread at the boring site.
Personal Protective Equipment. All solid wastes such as general trash and personal protective
equipment will be handled and disposed of as "non-hazardous" solid waste in an on-site
dumpster. However, air monitoring scans for organic vapors will be performed on all solid
wastes using a PID, FID, or other appropriate detection equipment. If the scans indicate that
organic vapors are detected above 10 ppm in the solid waste, the wastes will be packed in DOT
approved drums, the EPA RPM contacted and temporary storage arranged. It is assumed that
it will not be necessary to drum PPE.
Decontamination Water. The liquid waste generated onsite during the decontamination of
drilling and sampling equipment will be screened and if deemed non-hazardous will be allowed
to drain back onsite. However, decontamination liquids containing solvents or acids, will be
drummed, and temporary storage arranged prior to transport to a treatment/disposal unit. Low
contamination organic fluids will be evaporated, if possible.
Well Development or Sampling Purge Water. Water generated from development or purging
of piezometers and monitoring wells will be screened for total organic vapors using a PID, FID,
or other appropriate detection equipment. If organic vapors are detected above 10 ppm, the
EPA RPM will be notified to authorize the drumming of the waste. Once the EPA RPM has
been notified, contaminated drill development or sampling purge water will be drummed.
3-26
If organic vapors are below 10 ppm, it is anticipated that the development or purge water will
be disposed of in the vicinity of the piezometer or monitoring well and allowed to infiltrate into
the ground. For the purposes of this cost estimate, it is assumed that it will not be necessary
to collect, drum, and dispose of well development or sampling purge water.
It is estimated that a total of no more than 10 drums of hazardous solid or liquid waste will
require storage and disposal for all RI field activities and waste disposal will require no more
than two 8-hour field days.
3.3.6 Fieldwork Support
Fieldwork support includes those activities that are necessary prior to and during field activities.
The following section describes these activities and includes those associated with equipment
procurement, mobilization, site setup, and demobilization.
3.3.6.1 Site Setup, Mobilization and Demobilization. This pre-field work activity involves
securing and shipping field and health and safety equipment and materials to the site; setting up
the on-site office trailer in the decontamination and support area; procuring electrical and
telephone services to the office trailer; and providing for portable toilets and trash pickup;
equipment calibration and maintenance; troubleshooting; procurement of equipment and supplies;
and cooler tracking.
One mobile trailer will be rented for use as an on-site office (48 feet). In addition, the two
storage boxes will be kept onsite for the field activities: one for storing equipment (20 feet) and
one for sample bottles (20 feet). It is assumed that the EPA-owned decontamination trailer
(16 feet) will be available for the entire field effort. The office and decontamination trailers will
be equipped with heat, telephone, water, and electricity. In addition, the office trailer will be
equipped with a telefax and answering machine. Lists of projected equipment needs and bottle
requirements are presented hi section 8.
3-27
The 30-foot-square fenced storage area for storage of Rl-derived hazardous waste such as drill
cuttings (55-gallon drums) from contaminated soils, will be used if necessary.
It is assumed that mobilization and demobilization will be completed in five 8-hour days.
3.3.6.2 Audits. It is assumed that two 8-hour audits will be conducted by one M&E person
during the field effort (one during monitoring well installation and one during groundwater
sampling) to ensure that the drilling specifications and the procedures outlined in the SAP
followed.
3.3.6.3 Pre- and Post-Field Work Activities. Field team preparation includes review of the
SAP and SSHP Addendums, attendance of internal pre-field meetings, preparation of paperwork
prior to and following each field activity, and equipment management. Since the cost estimate
was developed with lower level geologists in the field, office hours for daily interaction of the
project geologist with the field geologists during field work have been included. These activities
are described in more detail below.
Documentation preparation:
• Preparation of paperwork for each field activity includes:
Preparation of logbooks for each field activity Preparing sample labels for sample bottles Pre-field meeting preparation for all field personnel Set up tracking system for samples (to be used for data validation, reduction, etc.) Coordinating required health and safety information Pre-field paperwork which includes the typing and preparation of the following:
RAS/DAS traffic reports for samples M&E chain-of-custodies for geotechnical samples M&E sample labels for coolers airbills for Federal Express
3-28
Additional informational labels (quantity and nature of materials being shipped) required when using hazardous goods airbills on coolers Miscellaneous information for field team
preparing final equipment lists and interaction with equipment manager
Pre-field meetings and preparation include:
Time for field personnel to read the SSHP and SAP Addendums for each field activity
Meetings between the project manager, project engineer, and field leader prior to each field activity and preparation and attendance for pre-field meetings
Meeting and conversations with Federal Express to coordinate sample shipment and tracking
Pre-field meeting attendance for all field team members
Coordination of laboratory solicitation with SMO/EPA for RAS samples
Annual asbestos/lead meeting
Equipment Management:
• Procurement, coordination, and tracking of equipment
• Tracking of equipment inventory
• Restocking of expendable items
• Maintenance and repair of instruments
• Coordination of equipment needs
• Rental equipment pick-up and returns
Geologist Interaction:
• Daily update of work completed
• Interaction with drilling subcontractor
• Discussion and resolution of any field problems
3-29
• Coordination of field work for piezometer and monitoring well installation and development
3.3.7 Meetings
It is planned that two meetings will be held during the fieldwork as listed in Table 3-1. One will
be held following piezometer installation and the preliminary round of groundwater
measurements to discuss placement of monitoring wells. A second meeting will be held
following Round 1 of groundwater sampling to discuss analytical data and potential modifications
to the analytical parameters for Round 2 groundwater sampling. It is anticipated that each
meeting will last 3 hours hi duration, will require a total of 4 additional hours for preparation
and travel, and will be attended by three M&E personnel.
3.3.8 Duration of Field Activities
For the purposes of this work plan amendment cost estimate, the duration of each of the field
activities are detailed below.
• Surface Geophysical Surveys (1.5 days)
• Hydrogeological Assessment
Decon pad construction/clearing (2 days & 3 days) Piezometer installation & development (3 days & 1.5 days) Monitoring well installation & development (20 days & 4 days) Seepage meter installation (2 days) Staff gauge installation (1 8-hour day) Water level measurements 1 day per round (2 days for seepage meters) Aquifer testing (7.5 days)
• Environmental Sampling
Soil boring sampling (4 6-hour days) Groundwater sampling (9 days per round)
• Site survey/mapping (1 day for M&E and 10 days for surveyors)
3-30
• Field-generated waste disposal (2 days)
• Field work support (mobilization - 5 days & demobilization - 5 days)
The LOE estimate assumes no delays related railroad or site access issues, weather or equipment
problems, or other unplanned circumstances.
3.4 SAMPLE ANALYSIS/VALIDATION (TASK 4)
The M&E team will validate analytical data from environmental samples. It is estimated that
142 samples and 50 associated field QC samples will be collected during two rounds of
groundwater sampling and 21 soil samples will be collected for geotechnical analyses.
As part of the CLP system, sample analyses performed with RAS methods will receive Level
IV data deliverables and sample analyses performed through DAS will receive Level V data
deliverables. All RAS data and DAS pesticide/PCB data will be validated to Tier III as specified
in the EPA Region I Memorandum (EPA, 1993) and in accordance with the EPA Region I
Laboratory Data Validation Functional Guidelines for Evaluating Organic Analysis (EPA, 1988b)
and Inorganic Analysis (EPA, 1989a); modified to meet criteria in the current SOWs for RAS
organic and inorganic analyses (EPA, 1991a; 1991b). Validation of the water quality parameters
will be limited to normal field and laboratory QA/QC checks. Data from samples analyzed or
screened in the field or analyzed by a geotechnical laboratory subcontractor will be reviewed,
but will not be validated.
The EPA Region I (1993) specifies the generation of several memorandum reports for both
inorganic and organic analysis as well as a prescribed number of worksheets and a final table
of qualified data. All of these required deliverables will be generated by a data validation
subcontractor for RAS data packages and by M&E for the DAS pesticide/PCB data packages.
3-31
Any data generated by DAS will have modified package of deliverables depending upon the
analysis performed. The DAS data packages will be validated in-house by M&E. Costs and
LOE to perform the validation of DAS data packages are included in the cost estimate; however,
it is assumed that any costs and LOE associated with laboratory problems related to the
validation will be incurred under the Analytical Services Work Assignment WA#46-1HZZ.
As part of Task 4, M&E will also conduct the following tasks associated with validation and
sample management:
• Arrange for CLP Laboratories with EPA
• Log the RAS and DAS packages on an appropriate tracking sheet; all other associated DAS sample tracking and DAS issues will be conducted as part of DAS WA#46-1HZZ
• Complete the inorganic/organic file inventory sheet as required by EPA
• Check for accuracy and completeness of sample log-in sheet (Form CD-I) on all RAS and DAS data packages
• Complete inorganic/organic complete file inventory checklist (Form DC-2), as required by EPA, on all RAS and DAS data packages
• Perform an evidence audit on all RAS and DAS data packages
• Mail the original and one copy of inorganic/organic file inventory sheet to contract evidence audit team on all RAS and DAS data packages
• Keep a copy of the EPA Form 1 and send RAS data packages to validation subcontractor with cover letter
• Keep hi telephone contact with validation subcontractor
• Review validated data; itemized in a validation review memorandum any problems noted and coordinate with validators such that corrective action can be taken
3-32
Send the validation memos and summary tables, validation worksheets, and ORDA/IRDA sheets and summary form, and DC-2 form to the Region I sample control coordinator, the Region I deputy project officer, and the EPA region where the laboratory is located
Record all telephone conversations with the laboratory, EPA, or data validation subcontractor on a telephone contract log or telecon memorandum
Data validation deliverables will be distributed in accordance with the EPA Region I guidelines
(U.S. EPA 1993).
3.5 DATA EVALUATION (TASK 5)
This task includes compilation of analytical data and water-level measurements onto databases
and data evaluation (including geological, hydrogeological, and chemical data) and preliminary
preparation of draft text for the RI report, which is described in more detail in section 3.8.
3.5.1 Databases
During this subtask all chemical and geotechnical data will be compiled into the existing database
that has been developed for this project. It is assumed that all of the chemical data will be
compiled from LOTUS files that will be created as part of the Tier III data validation reports.
In addition, field parameters measured during groundwater sampling (pH, specific conductance,
temperature, turbidity, DO, and Eh) will be input from field logbooks onto the database.
Water-level data from three rounds of measurements will also be entered into a database.
The following assumptions were used to derive the cost estimate for creating the analytical
database:
• Input of field and analytical data for each round of sampling (~ 79,000 data points)
• Revision of LOTUS 123 analyses tables provided by validators
3-33
• Conversion of validation data tables to a data base format
• Creation of relational data base files
3.5.2 Data Evaluation/Preliminary Report Preparation
During this task, information will be compiled to describe the field investigation, ecological
effects, geology, hydrogeology, nature and extent, and fate and transport processes for the draft
RI report. In addition, data will be transferred to the ARC/INFO system to be used in
preparation of the RI report maps and figures. It is estimated that only a small amount of effort
is needed to summarize the proposed field work and any actual field modifications, and no
additional ecological evaluations are expected based on the proposed field work.
For cost estimating purposes, it is assumed that geologic and hydrogeologic data from the
44 proposed monitoring wells and 18 proposed piezometers will be compiled and presented as
follows:
• 62 GINT boring logs
• 62 graphic well logs
• 9 geologic cross-sections (2 site-wide and 7 by area)
• 13 groundwater Contour Maps (3 site-wide and 10 by area)
• RI geologic write-up
• RI hydrogeologic write-up
• conceptual model of hydrogeologic characteristics
• aquifer testing data analysis (44 proposed wells)
• geotechnical data analysis
3-34
The nature and extent section will provide a comprehensive discussion of contaminant
distribution based on the data collected during M&E investigations and the previous RIs
(CDM, 1987; 1988; 1989a). Evaluation of the nature and extent of contamination will be
facilitated through the use of the analytical database and preliminary statistical summaries. It
is expected that data will be presented in the following formats:
• data tables showing all of the analytical results
• data summary tables
• figures representing contaminant concentrations and trends, if apparent
Since information will be presented primarily in tabular and graphical forms, contaminant
concentrations will not generally be presented in the text.
3.6 ASSESSMENT OF RISKS (TASK 6)
This section of the work plan amendment presents an addition to the scope of work as stated in
Section 3.6 - Assessment of Risks (Task 6) of the Final Work Plan for the Remedial
Investigation of the Iron Horse Park Superfund Site, Operable Unit 3, (M&E 1993a).
Specifically, this section presents the addition of a quantitative evaluation of potential risks to
human health from groundwater exposure pathways at the site to potential future on-site
residents. Ecological risks from direct exposure to groundwater are not expected and will not
be evaluated. This addendum supersedes the discussion of groundwater risk evaluation presented
in the previous work plan.
3.6.1 Scope of the Investigation
The areas of concern to be evaluated are as follows:
B&M Railroad landfill
RSI landfill
3-35
B&M locomotive shop disposal areas
old B&M oil/sludge recycling area
asbestos lagoons
The evaluation will include the data from two rounds of sampling of 27 existing monitoring as
well as 13 newly installed monitoring well clusters in these areas, (one well in each of the
shallow overburden, deep overburden, and bedrock aquifers at each well cluster location, one
additional bedrock well upgradient of the asbestos lagoons, one bedrock well upgradient of the
RSI landfill, and one cluster of background wells (totalling 44 new monitoring wells).
3.6.2 Grouping of Data
After all the analytical data is obtained from both rounds of sampling in the monitoring wells,
the data from each area will be evaluated to determine if either the grouping of strata (e.g.,
shallow overburden and deep overburden aquifers) or the grouping of adjacent areas (e.g., the
B&M Railroad landfill and the RSI landfill) would facilitate the evaluation of the Operable Unit
risks by combining areas with similar contamination. The M&E Team will work with EPA
Region I to determine the appropriate criteria for evaluating whether data grouping will facilitate
this site assessment. It is assumed that the data will be separated by stratum and by area, for
a total of 15 data groups.
3.6.3 Selection of Chemicals of Potential Concern
Prior to selecting chemicals of potential concern (COCs), the existing data will be summarized
by strata and area as detailed in the Final Work Plan (M&E, 1993a). The sampling data will
be summarized using the appropriate statistical methods as stated in RAGS to generate the
central tendency estimates and associated confidence limits. The mean concentrations in
groundwater will be calculated using the detected values in addition to one-half the detection
limit for the non-detected values (excluding high detection limits in accordance with EPA
guidance (U.S. EPA, 1989b; 1991b). Based on the current understanding of site
3-36
geology/hydrology, and of the lack of any adequate background sampling locations, it is assumed
that all organic and inorganic analytes, with the possible exception of the five human nutrients
listed on the TAL and any blank related analytes, detected in the groundwater from these on-site
wells will be selected as chemicals of potential concern. If a large number of COCs result from
this, an approach to background comparison will be developed in consultation with EPA
Region I. For purposes of this scope, it is assumed that the primary chemicals of potential
concern in groundwater are likely to be chlorinated volatile organics and metals.
3.6.4 Exposure Assessment
The exposure pathways associated with groundwater will be reviewed after the collection of
monitoring well data to ensure that all complete exposure pathways are evaluated in the risk
assessment. However, the only complete exposure pathway is assumed to be the ingestion of
groundwater by potential future on-site residents (both adults and children) in each grouping
area. It is assumed that risks via inhalation of volatiles and dermal absorption of contaminants
while showering will be qualitatively estimated.
Exposures for each receptor population will be quantified by calculating average daily doses
(ADDs) in accordance with EPA Region I guidance (U.S. EPA, 1989b). The ADDs will be
based on the exposure point concentrations and assumption regarding the frequency and duration
of exposures and the rate of daily water intake.
Two exposure cases will be examined: the Reasonable Maximum Exposure (RME) exposure
concentrations will be estimated, as per Region I guidance, by combining the maximum detected
concentrations with exposure parameters specified by Region I; the average case will be
estimated using the arithmetic mean concentrations with a different set of exposure parameters
values selected for the RME case, as specified by EPA Region I, providing an indication of the
uncertainty associated with the exposure concentration estimates.
3-37
3.6.5 Toxicity Evaluation
The chemicals of potential concern will be characterized with respect to their toxic effects in
humans. Where possible, relevant critical toxicity criteria will be identified for each chemical.
Two types of dose-response toxicity criteria are used for the human health assessment:
EPA-derived cancer slope factors for potentially carcinogenic chemicals, and reference doses
(RfDs) for chemicals exhibiting noncarcinogenic effects. For carcinogens, cancer slope factors
and the chemicals' weight-of-evidence classifications for human carcinogenicity will be provided
and discussed. For noncarcinogens, RfDs and the uncertainty factors used in deriving them will
be provided. The primary source of cancer slope factors and RfDs will be EPA's Integrated
Risk Information System (IRIS) and Health Effects Assessment Summary Table (HEAST).
Although not included in the SOW's budget, the EPA Regional Toxicologist and Environmental
Criteria and Assessment Office (ECAO) may also be contacted for toxicological information,
as well as for guidance on the evaluation of chemicals that do not have EPA-published toxicity
values.
Because no dose-response toxicity criteria exist for lead, the risk assessment cannot evaluate
quantitative lead doses for potential receptors. Instead, an alternative methodology will be used
for determining impacts associated with potential lead exposures. Instead of quantifying
potential doses and associated risks, the risk assessment will present comparisons of the data
groupings to established EPA guidance lead levels that are considered protective of children.
This approach is conservative since children are some of the most sensitive members of the
population with respect to lead exposures. EPA has provided a clean-up level for lead in
groundwater of 15 fig/L; this concentration is considered to provide substantial health protection
for the majority of young children. These values will be used in the risk assessment for
comparative purposes, and will be discussed in terms of health protectiveness.
The concentrations of lead in groundwater will also be examined from the perspective of
alternative methodologies that exist for evaluating potential impacts associated with lead
exposure, namely the Uptake Biokinetic (UBK) Model. The UBK Model, which can incorporate
3-38
many site-specific inputs and which EPA has developed for assessment of residential sites, will
be used to conduct a multi-media evaluation of the blood lead levels in potential future child
residents from exposure to all media, including groundwater, at the Iron Horse Park Site.
3.6.6 Risk Characterization
Potential human health impacts will be characterized by combining estimated exposures (doses)
with appropriate EPA dose-response criteria. The results of the risk characterization will include
estimates of the RME and average individual cancer risks for potential carcinogens and hazard
indices for noncarcinogens. The individual lifetime excess cancer risk for a chemical exhibiting
carcinogenic effects will be calculated by multiplying the upper-bound cancer slope factor by the
estimated lifetime average daily dose (LADD) averaged over 70 years. For noncarcinogens, a
hazard quotient will be calculated by dividing the estimated lifetime average daily dose (LADD)
averaged over 30 years by the RfD for each individual chemical. A hazard index for all
non-carcinogenic effects for each area grouping will be calculated by summing all the hazard
quotients for the area. A hazard index for any area greater than a threshold level of 1.0 will
trigger a more detailed evaluation, in which the hazard indices for groups of chemicals affecting
similar target organs will be calculated. If a target organ-specific hazard index exceeds 1.0,
there may be concern for potential health effects (U.S. EPA, 1989b).
As noted above, a multi-media evaluation of lead exposures via the EPA UBK model will be
presented, as well as a table in which summary statistics for the groundwater strata and area
groupings will be compared to the 15 pg/L clean-up goal.
3.6.7 Uncertainty Evaluation
As in any risk assessment, these exists a degree of uncertainty with regard to the analytical
results, exposure parameters and other assumptions, and toxicity criteria. A qualitative
discussion of the uncertainty associated with these will be provided in the risk assessment. A
3-39
table will also be presented providing an "order of magnitude" indication of the effect of
uncertainties in specific parameters on the risk estimates.
3.7 TREATABILITY STUDY/PILOT TESTING (TASK 7)
For the purpose of this work plan, no level of effort or costs for this task have been budgeted.
3.8 REMEDIAL INVESTIGATION REPORTS (TASK 8)
After Tasks 3 through 6 are completed, the M&E team will prepare the draft and final RI report
as described in the Final Work Plan (M&E, 1993a). Additional Task 8 activities associated with
the hydrogeological investigation and groundwater sampling include:
• Description of the field investigation program including methodologies and locations.
• Summary of geological data from piezometer and monitoring wells.
• Summary of analytical sampling results.
• Results and significance of findings, including hydrogeologic assessment, nature and extent of contamination, assessment of risks, fate and transport, and comparisons with ARARs.
Costs for this task are based on the following assumptions:
• An internal documentation review or TAT meeting will not be held
• Internal comment to the document will be minimal and require no major revisions to tasks, text, figures, or appendices
• EPA and state comments will also be minimal requiring minor revision to tables, text, figures, and appendices
3-40
3.9 DEVELOPMENT AND SCREENING OF ALTERNATIVES (TASK 9)
As directed by EPA, no level of effort or costs for this task have been budgeted.
3.10 DETAILED ANALYSIS OF ALTERNATIVES (TASK 10)
As directed by EPA, no level of effort or costs for this task have been budgeted.
3.11 FEASIBILITY STUDY REPORT (TASK 11)
As directed by EPA, no level of effort or costs for this task have been budgeted.
3.12 POST RI/FS SUPPORT (Task 12)
As directed by EPA, no level of effort or costs have been budgeted for this task.
3.13 ENFORCEMENT SUPPORT (TASK 13)
As directed by EPA, no level of effort or costs for this task have been budgeted.
3.14 MISCELLANEOUS SUPPORT (TASK 14)
As directed by EPA, no level of effort or costs for this task have been budgeted.
3.15 ERA PLANNING (TASK 15)
As directed by EPA, no level of effort or costs have been budgeted for this task.
3-41
3.16 ADMINISTRATIVE RECORD (TASK 16)
As directed by EPA, no level of effort or costs have been budgeted for this task.
3-42
4.0 DOCUMENT PRODUCTION AND DISTRIBUTION
The M&E project team will produce six copies of each of the following documents as required
by EPA in the scope of work (except where noted). Due dates for some of these deliverables
have not yet been determined.
Draft Work Plan for RI (8 copies)
Final Work Plan for RI (8 copies)
Draft Work Plan Cost Estimate for RI
Final Work Plan Cost Estimate for RI
Draft Site Safety and Health Plan
Final Site Safety and Health Plan
Draft Quality Assurance Project Plan
Final Quality Assurance Project Plan
Draft Field Sampling Plan
Final Field Sampling Plan
Draft Work Plan Amendment for RI
Final Work Plan Amendment for RI
Draft Work Plan Amendment Cost Estimate for RI
Final Work Plan Amendment Cost Estimate for RI
Site Safety and Health Plan Addendum
Sampling and Analysis Plan Addendum
Draft Community Relations Plan
Final Community Relations Plan
(Task 1)
(Task 1)
(Task 1)
(Task 1)
(Task 1)
(Task 1)
(Task 1)
(Task 1)
(Task 1)
(Task 1)
(Task 1)
(Task 1)
(Task 1)
(Task 1)
(Task 1)
(Task 1)
(Task 2)
(Task 2)
12/22/92
06/25/93
12/22/93
06/25/93
02/24/93
06/02/93
02/02/93
06/02/93
02/02/93
06/02/93
08/05/94
4-1
Draft RI Meeting Summaries (2)
Final RI Meeting Summaries (2)
Draft RI Fact Sheets (2)
Final RI Fact Sheets (2)
Ecological Characterization Report
Asbestos Contamination Letter
PCB Contamination Report
Hydrogeological Letter Report
Draft RI Report (15 copies)
Final RI Report (15 Copies)
The M&E team will also prepare monthly progress reports
assignment.
(Task 2)
(Task 2)
(Task 2)
(Task 2)
(Task 5)
(Task 5) 02/06/94
(Task 5) 02/06/94
(Task 5) 02/28/94
(Task 8)
(Task 8)
for the duration of the work
M&E will furnish the following people with the specified number of documents both in the draft
and final form. All documents will be submitted in hard copy as well as with one computer
diskette containing the document in Word Perfect Version 5.1.
Person
Ms. Susan Walter Ms. Diane Kelley Mr. Donald McElroy
Position
Contracting Officer Project Officer Remedial Project Manager
Number of Copies
(letter only) 1 5 (1 unbound) & (1 diskette)
4-2
5.0 ASSUMPTIONS AND SCHEDULE
The schedule for this work assignment is shown in Figure 5-1. In addition to assumptions stated
in sections 3 and 4, the schedule and budget has been developed based on the following
assumptions:
• EPA will arrange for all access to drilling and sampling locations.
• No delays related to railroad or site access issues, weather, equipment problems, or unforeseen circumstances will be incurred.
• Costs for expendable supplies will be covered by program management. Non-Expendable equipment will be provided, if available from program management. Site-specific rentals will not be covered by program management.
• All drilling locations will be accessible with an ATV rig.
• It is assumed that all fieldwork will be conducted in Level D.
• Railroad operations will not result hi delays in field activities.
• A flagman will be contracted for activities conducted by M&E or its subcontractors involving crossing active railroad tracks.
• The grid that was established during the summer/fall 1993 field activities is intact.
• With the exception of the three days for clearing of vegetation (as described in section 3), no additional LOE for clearing of vegetation has been included in this cost estimate.
• Standard laboratory turnaround tunes of 5 weeks were assumed.
• Standard data validation turnaround times of 3 weeks were assumed.
• 12-hour days with 1-hour travel time per day and 8-hour office days were assumed, unless otherwise noted.
• Receipt of EPA comments 2 weeks following submittal of risk assessment interim deliverables.
5-1
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5-3
The schedule for completion of all tasks and subtasks has not been specified by EPA. M&E has
assumed task duration and deliverable dates for the purpose of cost estimation. Should EPA
require a different schedule or revise deliverable dates, adjustments in the estimated LOE may
be necessary.
Should delays in field work or other components of the RI be encountered, M&E will identify
those delays to the RPM and will submit a revised schedule as warranted and/or is requested by
EPA.
5-4
6.0 CASH FLOW SCHEDULE
M&E has prepared a cash flow schedule based on work plan amendment schedule and budget
information. Cash flow estimations for all tasks have been based on the approximate schedule
anticipated by M&E. The cash flow schedule is shown hi Figure 6-1.
6-1
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7.0 SUBCONTRACTING PLAN
The M&E team anticipates using the following subcontractors for hydrogeological and
groundwater sampling investigation.
Work Item Subcontractor
Drilling/Excavation To be selected
Surveying To be selected
Geophysical Surveys To be selected
Geotechnical Laboratory Analysis To be selected
Data Validation Weston & Viar
Waste Disposal To be selected
Air Laboratory To be selected
7-1
8.0 EQUIPMENT AND SUPPLIES
Projected logistic field station supplies are shown in Table 8-1. Projected field support supplies
are shown in Table 8-2. Table 8-3 lists the projected health and safety supplies. Projected task
equipment needs are listed hi Table 8-4. Table 8-5 lists the projected bottle requirements for
the entire field effort.
8-1
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9.0 REFERENCES
Adamas, P.R., E.J. Clairain, Jr., R.D. Smith, and R.E. Young. 1987. Wetland Evaluation Technique Volume II: Methodology. Wetlands Research Program, U.S. Army Corps of Engineers, Environmental Laboratory, Operational Draft. USACOE/USDOT, Washington, DC.
APHA-AWWA-WPCF. 1992. Standard Methods for the Examination of Water and Wastewater, 18th Edition. Port City Press, Maryland, pp. 4-103 to 4-105, 2-36.
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