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UNITID ITATII INYIRONIIINTAL PROTICTION AOINCY t9 REGION I

J. F. KENNEDY FEDERAL BUILDING, BOSTON. MASSACHUSmS 02203

December 16, 1985

James F. Murphy, Assistant Vice President Po1yfibron Division w. R. Grace & Company55 Hayden Avenue Lexington, MA 02173

Re: Conditional Approval of Phase Three Plan of Study for Landfill Closure

Dear Mr... Murphy:

The government parties have reviewed the documents and report(&) submitted by w. R. Grace & Company related to the Acton Environ­mental Program, Phase Three Plan of Study for Landfill Closure. This study is approved subject to.the conditions and understandings ~utlined in this letter. The reports included are:

1) The Phase Three Plan of Study for Landfill Closure August 25, 198~· ;

2) The COM report entitled ~ampling and Analysis Report for Industrial Landfill - April, 1984

3) The COM report entitled "Addendum to the Phase Three Plan of Study for Landfill Closure - May, 1984"

4) w. R •. Grace's responses of June 5, 1985 to GCA's comments on the remedial action feasibility studies on the landfill.

These documents were submitted by w. R. Grace & Company in accordance with the provisions of Paragraph Eleven C of the Final Decree between the United States of America and w. R. Grace & Company, and the provisions of Paragraph 5 C of the Administrative Order issued bythe Commonwealth of .Massachusetts, Department of Environmental Quality Engineering and the government parties' letter of July 7, 1983, which called for a revised scope of work for the landfill investigation.

The proposed remedial alternatives for the Industrial Landfill identified by w. R. Grace are as follows:

Capping Encapsulation Off-site Disposal

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These three remedial alternatives were presented in the May, 1984 addendum to the Phase Three Plan of Study for Landfill Closure as the final selected alternatives to be considered in the Phase Four report.

Although we do not believe the Phase Three Plan of Study as submitted completely fulfills the requirements of the Consent Decree or Order, the government parties feel it is in the best interest of all partiesinvolved to resolve any remaining issues as part of the Phase Four study. It is difficult, as part of Phase Three, to address all issues of concern for the various closure options available without causing long delays in the site clean-up process. The government parties are confident that the studies conducted to date providethe necessary foundation for a successful closure if any data gapscurrently exisiting are addressed as part of Phase Four. Defining these.~ata gaps is dependent on what final closure option is recommended. Some of the issues of concern that may need to be addressed during Phase Four are as follows:

1) The treatment/disposal of perched water from the landfill, regardless of option selectedr

2) Improve the characterization of the lateral and vertical extent of the landfill materialr

r 3) Elaborate on the basis for estimating the annual infiltration

rate (currently estimated at 20"/year): in addition, address the impacts of using different infiltration rates rangingfrom 20" - 40" per year:

4) If biodegradation is a part of the Phase Four report, a sampling and analysis program that examines the fate and transport of the constituents of concern will be requiredr

I, ' 5) For the selected alternatives, address potential air II emissions, their release, monitoring and control

technique.,... .and ·..

6) Perfem.···-ddi tional sampling and analysis as may be neceeaary to futher assess the Phase Four optionultiaate,ly selected.

It is the government parties intent, that depending on the closure option selected, these and potential other data gathering issues may need to be resolved prior to approval of Phase Four.

In addition to this Phase Three detet~ination on the Landfill Closure, it is anticipated that the "Other Waste Sites Phase Three" determination can be made shortly. The report on the governmentparties investigation of the Chip Pile will be forwarded to you shortly.

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w. R. Grace should review this report and comment to the government parties on any changes this would dictate in the Grace •other Waste Site Phase Three• report evaluation of the Chip Pile. Upon receipt of Grace's comments the government parties can act on this remaining Phase Three issue.

Yours truly,

ct-/&i~Edmond G. Benoit ChiefJ~J~Y.~ Deputy. Regional Environmental Eng. Superfund Branch Air and Hazardous Waste Program Waste Management Division Department of Environmental JFK Federal Bldg. - Room 1907 Ouali~y Engineering Boston, MA 02203

cc: Bernard J. Murphy, Jr. Acton Larry Dayian, Alfl> Steve Calishman, BoB

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UNITED STATES ENVIRONMENTAL PROTECTION AGENCY

REGION I

CERTI FI EO MAI LJ.F. KENNEDY FEDERAL. BUILDING, BOSTON. MASSACHUSETTS 02203

...,No vembe r 14, __ RE .r·..;;:;- ·

!1986 ......

James F. Murphy Jr. INOUSTclAL. · ·....

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NOV19 ·1~eb-._•• \.n'-'~t"Assistant Vice President Po1yfibron Division W.R. Grace & Co. 55 Hayden Ave Lexington, . MA 02173

RE:

Oea~· Mr. Murphy:.. •.

The· government parties have reviewed the documents and reports submitted by W.R. Grace & Co. (•The Company•) relative to the Acton Environmental Program, Phase Three Plan of Study for Other Waste- Sites. The •other Waste Sites• are defined as: the North Lagoon, the Boiler Lagoon, the Battery Separator Lagoon, th~ Tank Car Area, and the

..,../ Blowdown Pit. These documents were submitted by W.R. urace in accordance with the provisions of ?ara~raph

Eleven C of the Final Decree between the United States of America and W.R. Grace, dated October 21, 1980, and the provisions of Paragraph Five C of the Administrative Order issued by the Commonwealth of Massachusetts Department of Environmental Quality Engineering also dated October 21, 1980. The Phase Three Plan·is approved subject to the conditions and und~rst~ndings outlined in this letter.

Based upon a review of the above-mentioned reports and II documents, the government parties are of the opinion

that the information provided is sufficient to proceed with the Phase Four Study if the noted deficiencies are addressed prior to government action on the Phase Four Report.

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We acknowledge that requiring you to address all issues for the various closure options available as part of Phase Three would cause long delays in the site remediation process. It is in the best interest of all parties involved to resolve any remaining issues as part of the Phase Four Study.

Therefore the government parties conditionally approve the data collection conducted at the Company's Acton facility · and the reports submitted to complete Phase Three of the Consent Decree and Administrative Order. Approval is given on the condition that the following data gaps be addressed prior to or as part of the Phase Four Study:

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1. Determine the boundaries of the contaminated soils underlying the North Lagoon.

2. Conduct sampling and analysis -of soil from the trench leading from the Tank Car Area to the North Lagoon.

3. Utilize the data from the aquifer restoration program to determine the extent of contamination ·from the Blowdown Pit. To date, only one sample has been analyzed and may not be representative of actual contamination levels.

4 • . Conduct tests, including but not limited to prio~ity pollutant analysis and toxic compound leaching procedure (TLCP), on the contaminated sediments from

. . •· the Battery Separator Lagoons (BSL) to assess their impact on groundwater.

5. Conduct additional sampling and analysis of soil and groundwater for volatile organic compounds in the Tank Car Area.

6. With regard to the Battery Separator Chip Pile, perform additional sampling and analysis of the groundwater at BSL-l and BL-l to conclusively determine whether or not formaldehyde is present downgradient of the piles. Until this sampling is conducted and evaluated, the government parties cannot take a position on final closure of the BatterySeparator Chip Pile.

The government parties believe that it is prudent to conditionally .approve Phase Three and move on to the Phase Four activities without additional delay. However, the government parties reserve the right to require any additional data and/or inform.tion deemed necessary under Phase Four including, but not limited to, the information noted above.

Sincerely, , (. ~ . - · ·-_____,~. . ;;;::::..., .. , v .. o/I

/I: . )/'..'I..: II. l.t. I )I, '"' .~.:.. ,._ · ,.,.,.,~ .. ' ~.,Fogel, E~ •, Merrill s. Hoh~an, ~irector ,. ....j~.} Waste Management Division Interim Regional

U.S. EPA Environmental Engineer Mass. DEOE

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N.J. Pollfter. Vice Prftidettt PofyfiMrt DiYiaien

W.R. Groce & Co. 55 Hoyden~ Leaington, Mou. 02173

(617) 861-6600

1/ August 19, 1983

Mr. John R. Moebes Waste Response & Compliance Branch u. S. EnVironmental Protection Aaency John F. Kennedy Federal BuUdins Boston, MA 02203

.. Mr. Edmond G. Benoit .. .. Deputy Regional Environmental Engineer Air and Hazardous Waste Proaram Department of EnVironmental Quality Ensmeertna One Winter Street Boston, MA 02108

) Dear Messrs. Moebes and Benoit:

We are ill receipt of your letter of Auaust a, 1983, in which you discuss your consideration of the various alternative remedial actions for closure of the pnmary, seoondary and emersency la&QODI under the Phue Three Plan of Study of the Cont~t Decree.

To be sure that we have correctly interpreted your letter, the foDoWina is .our understanding:

1. Both Grace and the Government parties are agreed that the followtna alternative actions should not be investigated in Phue Pour EngineerinlAnalysis: ·

a. No action.

b. Encapsulation.

c. Containment structure.

2. Both Grace and the Government parties aaree that off-lite disposal should be investigated in detail in Phase Pour.

3. Grace considers capping and soil/waste 10licW!cat1on to be practical . options and, therefore, plans to indude these in the Phue Four prosram.

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Messrs. Moebes and Benoit August 19, 1983 Page Two

4. While we do not agree with the Govern.QJent parties' opinJon that in­cineration is likely to be a viable remedial action, given several years probable permitting delays, we are willing to also include it in the Phase Four program.

5. We assume the Government parties did not intend their letter of August 3, 1983, to be a final determination on these points , since the Consent Decree and Order require that the final determination be made on the basis of the Phase Four report. Thus, for example, while we agree with the Government parties' atated view that other applicable regulation& must be taken into account in any final determination, it would be premature to decide upon removal or incineration at thia time.

:lased on your August 3rd letter, we understand that you have approved . .9ur Phase Three Plan of Study with the oondition that we include incinen­·Uon in the Phase Four Engineering Analysts.

We will plan to begin work on Phase Four by August 26, 1983, unless we have heard from you to the contrary. We also assume that the Phase Four 9D-day period will &tart on that date.

Sincer,,

17~ Nigel I. Palmer Vice President, Technical Services Polyflbron Divildon

NIP:ead

cc: Ms. Nancy Banks

bee: W. J. Cheeseman 0. M. Favorite · J. C. Johnson :, . F. Murphy, Jr.

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C. tONWEALTH OF MASSACHUSETTf If Department of Environmental Quality Engineering

One Winter Street NOV 0 8 R£C'DBoston, Massachusetts 02108

UNITED STATES ENVIRONMENTAL PROTECTION AGENCY John F. Kennedy Federal Building

Boston, Massachusetts 02203

November 7, 1983

Mr. Nigel I. Palmer Vice President w.R. Grace and CompanyTechnical Services-Polyfibron Division 55 Hayden Avenue Lexiqgton, Massachusetts 02173

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:: Re: Acton Environmental Program Phase Three Plan of StudyPrimary, Secondary and Emergency Lagoon Closure

Dear Mr. Palmer:

The governmental partles have reviewed your response of August 19, 1983 to our comments of August 3, 1983 on the •Acton Environmental Program Phase Three Plan of Study-Primary, Secondary and Emergency Lagoon Closure,• dated May 9, 1983.

We believe it is appropriate to clarify the position taken and still held by the government parties in our letter of August 3, 1983. Off-site disposal does not limit W.R. Grace and Company to disposal only at an out of state hazardous waste disposal site. However, it is our strongly held opinion that any effort to leave the sludge/contaminated soil in their present locations over a known drinking water aquifer is not consistent with the intent of the Federal Final Decree or the State Order. Off-site could mean other acceptable locations, including locations at Grace's Acton facility not on or within the influence of the aquifer, meeting appropriate Federal and State requirements for such disposal.

Futhermore, any proposal for an unlined site would not be favorably considered by the government parties. Chemical treatment technologies are in such infancy that it would be difficult if not impossible to demonstrate that the release of contaminants from an unlined site would not occur over time. With that as background, we have the following remarks regarding items in your letter:

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Concerning items la, lc, 2, 4, and 5, the governmental parties are generally in agreement with your understanding. Concerning items lb and 3 we have the following comments:

lb. Excluding encapsulation in th~ Phase IV Engineering Analysis­

If the definition of encapsulation is meant to be untreated insitu disposal, then we would agree with your decision. However, if encapsulation is meant to include off-site (as defined in this letter), with treatment, then it should

.. not be rejected as a remedial measure. In fact, encapsulatior. . •. . as such, could mean the equivalent of proper land disposal •

Furthermore, it is difficult to understand why W.R. Grace and Company would believe encapsulation is not practical

' tf capping was considered practical since encapsulation provides a higher degree of environmental protection than capping alone. In fact, Table 4-1 in your report of May 9, 1983 included encapsulation as an acceptable andi applicable remedial option.

3.. Capping as. acceptable. 11nd applicable

Although you may wish to continue pursuit of this option, it must he recognized that there · ts little likelihood of acceptance by the governmental parties for reasons stated above and in our earlier communications.

Your understanding that we have conditionally approved the Phase Three Plan of Study is correct, recognizing that concerns or deficiencies noted in the governmental parties comments on the Phase Three Plan of Study attached to our letter of August 1983 will need to be addressed, at least in part, during the Phase Four Engineering Analysis.

Since this clarifying letter should not significantly alter your present work on Phase Four, we also concur that August 26, 1983 commenced the 90-day period for Phase Four.

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During this critical phase, we encourage the company and its consultants to work closely with the governmental parties in the development of the Engineering Analysis. It is suggested that a technical meeting be held as soon as possible to assure thdt all parties are clear on the Phase Four issues and to establish communication links during the study period Ithat will reduce the likelihood of lengthy delays in reviewing· and approving the final document. It is in everyone's best J interest to pursue final lagoon closures as early in 1984 as jpossible. We trust completion of the Phase Four Analysis will be the last step towards that goal.

Branch Protection

cca Nancy Banks, Town of Acton Jay Johnson, CDM James Murphy, W.R. Grace John Macleod, Acton Water District

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Deputy Regional Environmental Engineer

Massachusetts Department of Environmental Quality Engineering

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