EPA WORK ASSIGNMENT NUMBER: 115-IL54

EPA CONTRACT NUMBER: 68-01-7250

EBASCO SERVICES INCORPORATED

FINAL WORK PLAN PHASE II REMEDIAL INVESTIGATION

AND FEASIBILITY STUDY

SULLIVAN'S LEDGE SITE CITY OF NEW BEDFORD

BRISTOL COUNTY, MASSACHUSETTS

OCTOBER 1987

Prepared by: Approved by: /I

Guy Win. Vaillancourt Russell H. Boyd, J Site Manager Regional Manager Reg E.C. Jordan Co. Ebasco Services Incorp

TABLE OF CONTENTS

Section Title Pacre No.

1.0 INTRODUCTION 1

2.0 SUMMARY OF EXISTING DATA 2

2.1 Phase I RI Report 2 2.1.1 Site History 2 2.1.2 Contamination Summary 3

2.2 Post Phase I RI Data Evaluation 8 2.2.1 Quarry Pit Locations 8 2.2.2 PCS Data Analysis 9 2.2.3 Volatile Organic Compounds

Data Analysis 14 2.2.4 Base/Neutral Extractable

Compounds Data Analysis 22 2.2.5 Lead Data Analysis 25 2.2.6 Separation of Sullivan's Ledge

and the New Bedford Municipal Landfill 31

2.3 Phase I RI Risk Assessment 32

3.0 SCOPING OF THE PHASE II REMEDIAL INVESTIGATION/FEASIBILITY STUDY 37

3.1 Scoping of Remedial Alternatives .... 37 3.1.1 Preliminary Remedial Response

Objectives 37 3.1.2 Preliminary Development of

Remedial Response Actions .... 40 3.2 Identification of Data Requirements. . . 42

3.2.1 Definition and Development of ARARS 42

3.2.2 Consideration of ARARs during the Phase II RI/FS 44

3.2.3 Initial Identification of ARARs 45

3.2.4 Data Quality Objectives (DQO) Determination 45

3.3 Objectives and Scoping of the Phase II Remedial Investigation 57 3.3.1 Objectives of the Phase II RI . . 57 3.3.2 Scope of the Phase II Field

Investigation 58 3.3.2.1 Initial Activities ... 58 3.3.2.2 Bedrock Drilling

Program 58 3.3.2.3 Biota Investigation. . . 59 3.3.2.4 Environmental Sampling . 59

3.3.3 Limitations of the Phase II RI. . 61

-i

TABLE OF CONTENTS (continued)

Section Title Paae No.

4.0 TASK PLAN FOR THE' PHASE II REMEDIAL RI/FS . . 62

4.1 Task 1 - Project Planning 62 4.1.1 Work Acknowledgement Letter . . . 62 4.1.2 62 4.1.3 DQO Session 62 4.1.4 Preparation of Project Plans. . . 63

4.2 Task 2 - Community Relations 63 4.3 Task 3 - Field Investigation 65

4.3.1 Subtask 1 - Initial Activities. . 65 4.3.1.1 Mobilization 65

65 4.3.1.3 Water Level Measurements 66

4.3.2 Subtask 2 - Subsurface Explorations 66

4.3.2.1 Bedrock Wells 66 4.3.2.2 Test Pits 71 4.3.2.3 Piezometers 71 4.3.2.4 Well Packer Assembly . . 71

4.3.3 Subtask 3 - Environmental 72

4.3.3.1 Groundwater Sampling . . 72 4.3.3.2 Surface Water

Sampling 72 4.3.3.3 On-Site Soil Sampling. . 74 4.3.3.4 Sediment Sampling. . . . 76 4.3.3.5 Biota Investigation. .. 76

4.3.4 Subtask 4 - Borehole Geophysics . 78 4.3.5 Subtask 5 - Field Survey 80

4.4 Task 4 - Sample Analysis/Validation. . . 80 4.5 Task 5 - Data Evaluation 82 4.6 Task 6 - Phase II Risk Assessment. . . . 82

4.6.1 Public Health Risk Assessment . . 82 4.6.2 Environmental Risk Assessment . . 82

4.7 Task 7 - Treatability Study/Pilot Testing 83

4.8 Task 8 - RI Report 84 4.9 Task 9 - Remedial Technologies and

Alternatives Screening 85 4.9.1 Development of Response

Objectives and Remedial Action" Target Levels 85

4.9.2 Identification/Screening of 85

4.9.3 Development/Screening of Remedial Alternatives 86

-ii

TABLE OF CONTENTS (continued)

Section_ Title_

4.10 Task 10 - Remedial Alternatives Evaluation

4.10.1 Effectiveness 4.10.1.1 Reliability Assessment 4.10.1.2 Public Health and

Environmental Impacts Evaluation

4.10.1.3 Attainment of ARARs. .

4.10.3 Cost 4.11 Task 11 - Phase II RI/FS Report 4.12 Task 12 - Post RI/FS Support

5.0 PROJECT MANAGEMENT APPROACH

5.1 Organization and Approach 5.2 Quality Assurance and Data

Management 5.3 Project Schedule

REFERENCES .......................

APPENDIX A .......................

Page No.

88 89 89

89 90 90 91 92 92

94

94

94 96

100

102

-iii

LIST OF FIGURES

Figure Title Page No.

2-1 Site Location Map 4 2-2 Site Plan 5 2-3 Site Features Map 6 2-4 Quarry Pit Locations 10 2-5 Interpretation of PCS Data - Soils 0'-3'. . . 11 2-6 Interpretation of PCB Data

Test Pit Soils 3'-6' 12 2-7 Interpretation of PCB Data

Test Pit Soils 6'-9' 13 2-8 PCB Concentrations - Sediment 15 2-9 Interpretation of VOCs - Soils 0'-3' 16 2-10 Interpretation of VOCs

Test Pit Soils 3'-6' 17 2-11 Interpretation of VOCs

Test Pit Soils 6'-9' 18 2-12 Interpretation of VOCs - Overburden Wells . . 20 2-13 Interpretation of VOCs

Bedrock Monitoring Wells 21 2-14 VOCs - Surface Water 23 2-15 VOCs - Sediment 24 2-16 Interpretation of BAP Data - Soils 0'-3'. . . 26 2-17 Interpretation of BAP Data

Test Pit Soils 3'-6' 27 2-18 Interpretation of BAP Data

Test Pit Soils 6'-9' 28 2-19 BAPs - Sediment 29 2-20 Interpretation of Lead Data - Soils 0'-3" . . 30 3-1 RI/FS Remedy Selection Process 38 4-1 Phase II Field Investigation - Anticipated

Subsurface Exploration Locations 67 4-2 Phase II Field Investigation

Surface Water Sampling Locations 72 4-3 Phase II Field Investigation

On-site Soil Sampling 75 4-4 Phase II Field Investigation

Sediment Sampling Locations 77 4-5 Phase II Field Investigation

Sampling Plan 79 5-1 Project Organization 95 5-2 Project Schedule 97

-iv

Table

2-1

3-1

3-2

3-3

4-1

4-2

4-3

4-4

A-l

LIST OF TABLES

Title

Summary of Findings of Phase I Risk

Potential Action— Specific ARARs

Subsurface Exploration Rationale

Phase II RI/FS Report Outline

Exposure Assumptions Made in Phase I RI Risk Assessment

, .

. .

. .

. .

. .

. .

. .

,. .

,. .

Page No.

33

46

49

51

68

70

81

93

103

-v

1.0 INTRODUCTION

E.G. Jordan Co. (Jordan), under contract to Ebasco Services Incorporated (Ebasco), is submitting this Work Plan for the Phase II Remedial Investigation/Feasibility Study (RI/FS) for the Sullivan's Ledge site to the U.S. Environmental Protection Agency (EPA). This submittal is in response to Work Assignment Number 115-IL54 under Contract Number 68-01-7250.

The Sullivan's Ledge site was added to the National Priorities List (NPL) on September 21, 1984, because of the potential hazards associated with chemicals disposed on the site. NUS Corporation (NUS), under the EPA REMFIT Contract, prepared a draft RI report dated August 1986; however, it had not been finalized because the REMFIT contract expired. As a Subcontractor to Ebasco under the EPA REM III Contract, NUS finalized the report, which is referred to as the Phase I RI report because it provides the data necessary for site characterization.

This Work Plan presents Jordan's current understanding of the problem at the site, the rationale for the technical approach, and the technical scope of work for the Phase II RI. In addition, an estimated level of effort and a schedule for conducting the Phase II field investigation and preparing the FS report are included.

The objective of the Phase II field investigation is to collect additional environmental samples to enable the development of remedial alternatives.

The objectives of the FS are to develop, screen, and evaluate site-specific remedial alternatives for:

• the on-site surface soils; • the surface water in the unnamed stream; • the sediment in the unnamed stream, Middle Marsh, and

if necessary, the adjacent portion of the Apponagansett Swamp;

• the seeps discharging to the surface water; • controlling the release of contaminants to local air;

and • the shallow groundwater contaminated by source

material.

-1

2.0 SUMMARY OF EXISTING DATA

This section summarizes existing data pertaining to site history, site description, and chemical characterization. The Phase I RI report for the Sullivan's Ledge site, prepared by NUS in June 1987, provided the information discussed herein.

This section is divided into three subsections. Subsection 2.1 discusses the Phase I RI report. Subsection 2.2 outlines the evaluation performed by Jordan using data presented in the Phase I RI report. This evaluation was performed to complement the information presented in the Phase I RI report and to determine the scope for the Phase II field investigation. Lastly, Subsection 2.3 summarizes NUS site risk assessment, as determined from the Phase I RI report.

2.1 PHASE I RI REPORT

The Phase I RI report prepared by NUS contains a site history and an evaluation of the environmental data collected at the site. It is not the purpose of this section to repeat the information provided in the Phase I RI report, but rather to give a brief summary to enable the reader to develop a complete understanding of site history and contamination. The Phase I RI report should be consulted for additional information.

2.1.1 Site History

The Sullivan's Ledge site is a former granite quarry which is believed to include four pits. Quarry operations were initiated at the site prior to 1846. Quarry operations at the Sullivan's Ledge site ceased in 1932. In 1935, the City of New Bedford acquired the land through tax title foreclosure. The two pits closest to Hathaway Road were filled with junk automobiles in the mid-193Os. The remaining pits were used for industrial waste disposal from approximately 1940 to 1968.

In the early 1970s, a major fire erupted at the site. The fire was difficult to control and created a dense, black smoke, primarily caused by the large number of tires disposed at the site. To prevent a recurrence of fire, the site was backfilled and regraded.

In 1982, EPA conducted an air monitoring program of the greater New Bedford area. This study included air sampling at the Sullivan's Ledge site. Groundwater monitoring wells were installed around the site in 1983. In September 1984, the Sullivan's Ledge site was added to the NPL.

-2

The Sullivan's Ledge site, an area of approximately 12 acres, is located immediately north of the I-95/State Route 140 interchange (1-95 Interchange No. 19) on the northwestern outskirts of New Bedford, in southeastern Massachusetts. The site entrance is approximately 600 feet southwest of the intersection of Hathaway Road and Route 140. The Site Location Map is presented in Figure 2-1.

The site slopes from west to east, with a change in elevation of approximately 40 feet. Fill material covers the majority of the area. Depths of fill vary from three to ten feet. An overburden groundwater table exists in the surrounding overburden and fill material. A bedrock groundwater table also exists at the site.

Figure 2-2, the Site Plan, is taken from photographic mapping provided by the EPA Environmental Photographic Interpretation Center (EPIC), based on August 1984 and December 1985 aerial photographs. The Sullivan's Ledge site is bounded on the south by the highway interchange, on the east and west by commercial establishments, and on the north by Hathaway Road. Immediately north of Hathaway Road is the Whaling City Country Club, which consists of approximately 250 acres. The country club and the Sullivan's Ledge site comprise the study area because site contamination enters the country club from the unnamed stream and contaminated groundwater discharges through seeps along Hathaway Road.

Figure 2-3, the Site Features Map, was developed from a site visit on June 10, 1987, and illustrates the approximate location of current site features.

2.1.2 Contamination Summary

Information from over 400 environmental samples taken during the Phase I field investigation is included and evaluated in the Phase I report. NUS provided the following environmental contamination summary in the Phase I RI report:

"It is apparent from this review that chemical contaminants from the site have migrated throughout the study area, affecting soils, surface water, sediments, and groundwater. The highest concentrations of contaminants were found in the immediate site vicinity, consistent with characterization of the Sullivan's Ledge site as a primary source area.

"Surface water and groundwater represent the major migration pathways for volatile organic contaminants, while erosion of soils from the site into the adjacent, unnamed stream is the most significant pathway for movement of PCBs and base/neutral organics.

-3

SULLIVAN'S LEDGE AREA

BASE MAP SOURCE•• USGS QUADRANGLE, 7.5 MINUTE SERIES NEW BEDFORD NORTH, MA.

FIGURE 2-1 SITE LOCATION MAP

SULLIVAN'S LEDGE LANDFILL SCALE= I =2083 NEW BEDFORD, MASSACHUSETTS

5180-03

..,. .... •ae• •ua '°"" u,oa,

SCIIL E .,. Hf T FIGU:U: 2-2 SITE PLANr....c--1.oo SULLIVAN'S LEDGE LANOFll

NEW BEDFORD, MASSACHUSETTS

i.HINO........··--·--J> ·-·==~----- .......... ·~· :::: ru.--~ " •TQ oQI

"The following provides a representative listing of the more than 60 HSL contaminants found within the study area.

Contaminant Occurrence (Medium)

Volatile Oraanics

Benzene Groundwater, Surface Water Toluene Groundwater, Surface Water Trichloroethene Groundwater, Surface Water 1,2, trans-dichloroethene Groundwater, Surface Water Chloroform Groundwater

Base/Neutral Organ!cs

Naphthalene Soils, Groundwater, Surface Water

n-Nitrosodiphenylamine Soils, Groundwater Dibenzofuran Soils, Sediments Phenanthrene Soils, Sediments Chrysene Soils, Sediments

PCBs/Pesticidea

PCB-1242, -1248, -1254 Soils, Sediments

Inorganics

Lead Soils, Groundwater, Surface Water, Sediment

Mercury Soils, Surface Water

"In general, a marked pattern of decreasing contamination (both in terms of numbers of contaminants and their respective concentrations) is evident with increasing distance from the site. This pattern is typified by the sharp drop in concentrations of volatile organics in both groundwater and surface water north of the site. Surface soil contamination exhibits a similar pattern with respect to contaminants found in this medium. Streambed sediments, however, exhibit a comparatively undiminished loading of PCBs throughout the golf course area. This is apparently a function of the manner in which PCBs are distributed in the environment; that is, primarily as adsorbed materials to finely divided soils, so that their distribution would mirror that of sediment deposition from the stream." fPhase I Remedial Investigation Report. Sullivan's Ledae Site. NUS Corporation, June 1987.)

Results of the air modeling performed by NUS in the Phase I RI report show that PCB concentrations exceed those measured by EPA in 1982. This finding confirms that air is a potential route of exposure for PCBs attached to airborne soil particles.

-7

2.2 POST PHASE I RI REPORT DATA EVALUATION

As part of Task 5, Data Evaluation, Jordan reviewed the environmental data presented in the Phase I RI report to identify specific contaminant locations in the site soils and to determine the site-specific fate and transport conclusions. This evaluation was necessary to appropriately scope the Phase II field investigation. For each class of compounds (i.e., PCBs, volatile organic compounds, base/neutral compounds, and inorganic compounds), indicator compounds were selected for interpretation, based on the Phase I RI. Jordan prepared contaminant maps for each class of compounds in various media: soils, sediments, surface water, overburden aquifer, and bedrock aquifer.

Figures 2-5, 2-9, and 2-16 are examples of the contaminant maps which were prepared to develop a conceptual model of the site contamination and to determine potential routes of exposure. The contaminant maps were prepared by first plotting the sample point location on the respective well map or sample depth map (for surface soils) and then adding the total contaminant concentration sampled at that point for that depth. Total PCB concentrations were determined by the sum of Aroclors identified for each sample point. In order to have adequate data to perform the mapping, samples with estimated concentrations were used. These samples are flagged with the letter "J" and indicate that the compound was identified, but the concentration is less than the specified detection limit. Estimated sample results cannot be used when evaluating remedial alternatives, but are useful in developing an understanding of the contamination distribution.

To further enhance the data interpretation, order-of-magnitude concentration ranges were established for each map, based on the range of contaminant concentrations for that media. If appropriate, iso-concentration contours were drawn by dividing the distance between sample points of different concentration ranges. For example, if the sample points differed by one range, the contour was drawn halfway between the points; for two ranges, the distance was divided into thirds and the two contours were drawn at these points. The main advantage of this contouring procedure is that it provides a qualitative assessment of contaminant distribution and can aid in the placement of additional sample locations. The disadvantage is that certain sample locations may dominate the resulting distribution and indicate a larger area of contamination.

2.2.1 Quarry Pit Locations

Exact locations of the quarry pits were not determined during the Phase I field investigation; rather, they were estimated based on aerial photographs supplied by EPIC. Twenty-six test pits had been excavated within the site boundaries during the

-8

Phase I field investigation. In addition, 24 monitoring wells had been installed on-site. The test pit and monitoring well logs were reviewed to determine if bedrock was intercepted and at what depth. Using this information, the outline of the quarry pits was verified; the results are illustrated in Figure 2-4. It appears that the original locations are fairly accurate for the two pits in the middle of the site. The pits on the north and south sides of the site, however, appear to be located adjacent to and due east of the locations identified in the Phase I RI.

Review of the test pit logs also indicates that waste disposal was not confined to the quarry pits but occurred throughout most of the site. In many of the test pits (e.g., TP-2, TP-15, TP-18), refuse and contamination was found in the fill material above the bedrock. It appears that once industrial wastesdisposed of on the site, dumping then occurred throughoutof the area.

were most

2.2.2 PCS Data Analysis

Jordan developed four maps to depict the distribution of PCS contamination in the near surface soils and the sediments in the unnamed stream and Middle Harsh. Contamination maps were not developed for the site surface water because few samples contained measureable PCB concentrations; similarly, groundwater plume maps were not developed.

Figures 2-5 through 2-7 provide a qualitative interpretation of PCB distribution in the site soils. Figure 2-5 was developed from the test pit data for depths of 0 to 3 feet. Two areas appear to have higher levels of PCB contamination: one at the eastern edge of the site in the vicinity of TP-2, TP-3, and TP-19; and the other in the southwestern portion of the site near TP-12.

Figure 2-6 illustrates the PCB contaminant concentrations for sample depths of 3 to 6 feet. Contamination at this level appears to be greatest near TP-12, with total PCB concentrations around 2,490 parts per million (ppm). TP-3 and TP-20 have elevated PCB concentrations, but they are less than those shown on Figure 2-5.

Figure 2-7 presents the PCB contamination found from 6 to 9 feet. Most test pits were not sampled because of rock or refusal. PCB contamination still exists in the southwestern portion of the site, although it appears greater east of TP-12 to TP-23.

These results are of interest because it appears that the PCB contamination is not spread throughout the site, but is concentrated on the southern and eastern boundaries. The

-9

---------

0

,,' ,, '·'

.Wl!!2.-·-··--.i ::t-·--,-..ua, l!rTD g =~-=·• ...nun~ =·-

Tl'•l4

$ - UST l'IT LIICATIOOI MW·IJ+ -MONl'll»llNi WfLL

FIG~E 2-4 QUARRY PIT LOCATIONS

SULUV AN'S LEDGE LANDFLL NEW BEDFORD, MASSACHUSETTS

---\fM•-__ .,._ -·-·--~ ::...... "DMIIJT-----...,,.== ru,. •ta IOI

~-'111&1. _..,,.,_. =--TP•l4s -TUT 111T UICAT

H- l'CI COIICINTIIAllON,_, -- - .,fUlllO CONClNHt'N

/'-------~

I?

FIGURE 2-6 INTERPRETATION OF PCB DATA (ppm)

SOLS 0-3' SUUJVAN'S L£DGE LANDFU.

NEW BEDFORD, MASSACHUSETTS

-----------..!!!!!!!..-·-··- "'==·na· :::: ~wro.

fl •TU ,:::._..:.-::-- • ""'UTT l'GL.I TP•Z4

-$ -TUT In LOCATION 11 - PCII CONCIIITIIATION,...,

- - 1Nft1111io C()l,jCfNTll°II

"" NS NOT SAMl'U:0

/?~-------'

FIGURE 2-6 INTERPRETATION OF PCB DATA (ppm)

TEST PIT SOLS 3'-6'

SULUVAN'S lEOGE LANOFLL

NEWBEDFORD,MASSACHUSE1TS

----T~~

NS

--..)~n..r-,0 0 100 200 l'&T

,,/? -

~-·-...--:=ir"'L.---11>_,_.·-·· ·:t·==~..." .,a c::.=-'1111&.1 ·~l'IIL.& =·-

TP•l4

$ -TUT PllU>C:ATlll • rca CONCINTIIATl(IN

h••I

NS NOT SAMl'L[O

INf[liltCD ca«:(NJR'N

',, ~·'

Tf'•II

s NS

Tf'•M s

NS

AGlff 2-7 INTERPRETATION OF PCB DATA (ppm)

TEST PIT SOLS 6'-9' SULUVAN'S LEDGE LANDFU

NEW BEDFORD, MASSACHUSETTS

majority of the northern and western portions of the site appear to have PCB concentrations several orders of magnitude lower. It is also of interest that the majority of the contamination appears in the vicinity of, but not over, the southernmost quarry pit.

No explorations were made along the eastern portion of the site between TP-2, TP-3, and TP-21. Additional sampling in this area would be necessary to verify the contamination contouring.

Figure 2-8, which illustrates sediment PCB concentrations, presents information similar to that in the Phase I RI report. Upstream samples (SD-302; so-101, SD-301; SD-613; SD-610; SD-601; SD-614) have PCB concentrations of less than l ppm. Immediately downstream of the site, adjacent to areas with soil samples highest in PCB concentrations (i.e., SD-303 and SD-307), the PCB values in the sediment increase by two orders of magnitude. This supports the conclusion that soil erosion is a pathway for movement of PCBs from the site. Sediment deposition appears to be significant as the stream enters Middle Marsh; this appears to account for the increase in PCB concentrations illustrated by stations SD-611, SD-6llA; SD-103, SD-319; and SD-403.

The unnamed stream follows a well-defined channel throughout Middle Marsh, where it enters a water hazard on the northern edge; here, sedimentation and PCB contamination occur. PCB concentrations to decrease as the unnamed stream travels through the golf course and under the Conrail tracks. Sample SD-322 is upstream of the unnamed stream; the origin of PCBs in this sample is difficult to determine. Similarly, Sample SD-323 is downstream of the site and the New Bedford Municipal Landfill (NBML), making the exact origin of PCBs difficult to determine.

2.2.3 Volatile Organic Compounds Data Analysis

NUS chose fourteen volatile organic compounds (VOCs) as indicator compounds in the Phase I RI: 2-butanone, 4-methyl-2-pentanone, benzene, toluene, xylenes, ethylbenzene, chlorobenzene, 1,2-dichloroethane, trans-1,2- dichloroethene, trichloroethene, vinyl chloride, chloroform, methylene chloride, and styrene. For each sample point, the concentration of these chemicals were summed to determine a total voe concentration. This information was then plotted on maps and analyzed to determine the extent of voe contamination. voe concentrations were mapped in parts per billion (ppb) to provide a sufficient range for interpretation.

Figures 2-9 through 2-ll present an interpretation of voe contamination in the test pit soils. As with the PCB soil maps, contamination appears to be concentrated most heavily near the

-14

i

I

I

I

11'

I

ID IOt .0"ct·oo,~,,.. ----:: ,,..._, ~..o,:=,=:c:------------

NOTl· J•UTIMAJ[OVALUE, NO•NON O[T(CT, C•CONflRM[O

,11001

TP•l4

~ -TUT MUICAT11> - YOUllL f ONGANIC

COMfOUoll> CONCfNTIIATIOH

I •t~I

INffHN(D CONC(Nl'N

FIGlff 2-9 INTERPRETATION OF

VOLATILE ORGANIC COMPOUNDS (VOC) (ppb)

SOLS (Su:IFACE) o!-3'

SUUJV AN'S LEDGE LANOFU.

NEW BEDFORD, MASSACHUSE1TS \

. I

0

'""!..f\-.. ~

//#

I- ~ /,,... .·//~

/ /,/ /

·' /

TP•l4

,S -rmm I~.- IK.

\ I

---y-------n...r-,0 0 100 200 f'EET

.l:Ul!!l---··~---~ .....,1111~-,---•If' :::: 1\!.\AIDI " •tu S::.•hllU:.-:;--• -IU1"f "'3U Tl'-24-s -nsr l'ITLOCATION

1, - ~v~ORCiAIIIC CONC[NTIIATIONC ,_.,

NS NOT 5ANl'LUI

INflllitt;O COHC£NTll°N

FIGURE 2-11 INTERPRETATION OF

VOLATILE ORGANIC COMPOUNDS (VOC) (ppb) TEST PIT SOLS 8'-9'

SUUJVAN'S LEDGE LANDFU. NEW BEDFORD, MASSACHUSETTS

eastern and southern boundaries of the site. Localized "hot spots" appear in the northeastern portion of the site at TP-20 and in the southern portion around TP-17 and TP-23. It is of interest that the two hot spots are in the same general location as the northernmost and southernmost quarry pits, indicating that dumping of voes may have been concentrated in or near these two pits.

Figure 2-12 is a voe contaminant plume map for the overburden aquifer. As in Figures 2-9 through 2-ll, all concentrations are in ppb. Dashed lines on Figure 2-12 indicate that sufficient data did not exist to close the contamination contour; therefore, the contour is approximated in these areas. This figure illustrates that the overburden aquifer is most highly contaminated in the area around the northernmost pit. However, the 100 ppb contour remains open around MW-14, indicating that additional contamination occurred in this area. This observation is supported by Figures 2-9 through 2-11, which outline hot spots in this location.

The overburden groundwater flow maps presented in the Phase I RI report (see Figure 5-9) show the flow in a northeastern to northern direction; that is, the same direction as the contaminant plumes. The leading edge of the contaminant plume appears to be immediately north of WP-land WP-3, just beginning to reach the Middle Marsh area. Contamination also appears in the vicinity of MW-26, MW-27, MW-7, and MW-7A. This contamination appears to be coming from a different source; the New Bedford Municipal Landfill (NBML), located due north of MW-27, is a potential source. A separation of these two sites appears to exist for the overburden groundwater (see Section 2.2.6). It is of interest that the majority of the overburden aquifer under Middle Marsh has voe concentrations less than one ppb. It does not appear that voe contamination in the overburden groundwater has reached this area.

Figure 2-13, a contaminant plume map for the bedrock groundwater, was prepared in a similar fashion as Figure 2-12. The contaminant plume is oriented in the same northeastern to northern direction, with the edge of contamination just reaching the Middle Marsh area.

one important difference between the two maps is that voe concentrations in the bedrock groundwater are an order of magnitude above those found in the overburden wells. This supports the thesis that the majority of voes are likely released into deep groundwater from the pits.

-19

---------

L__,J ~ l I';\MW·H· ··-.. um ~-~ } ~,..·;~,·-- ,~

'0 - 200 .,,, ,,.

I ~ ,o.,. /

/

.,.,

/ 0 " /le> (./ /

I~/ // /

/ I _.. / r MIDllU MAR5N / / /

l // /

/ / /( / /

.,.,·,1/ .....

400 1'££1'

.- ·u111,o-----f(ta' - ., ... -acaMJt: CDitlCUI ·--~--,---,

• )11)1 • UOf (U \•UO. , : .-r111U1 :..,-=..: ..........DaQIIIQ .:., •Ul&IIW fliGLl

• ~a.aft.a LQUtlQIII

COtoefllTIIATIONS

< .... 0 EJ l•IO ,... A IO·IOO• 0 I00-1000 ...

0 )1000,,. )10,000-,•®

ND NON OUECT

CST. VALUE

-- INf[RR[D CONC

Mw·H

0

------,\ \ FIGURE 2-12

INTERPRETATION OF VOLATILE\ ORGANIC COMPOUNDS (VOC) (ppb)\ OVERBlJiOEN WEU.S\ SlUJVAN'S LEDGE L.Ata=U.

\ NEWBEOFORO,MASSACHJSETTS 1110-0J

$1

oo (] o a Ooo •~o

LJ;Jrw-,0 0 200 400 fEET

I I

I I

I

/ (

)

/

IDvoc·o • WVl·lf:J r

// )

~ - ..... c-....A -CC..flCll. ~--·--,1tc2 ~ ..... .,..-fNll COIIGJIII \,s}•lll(llrll)I~-·

.... ,oulllatlillllA ,)lf.)1-ll'CII' IU'tlllO.

.-fMU ~-::.:-~o-... -'. • :~~~I~,UM*I

t0NC(M1Hl10M$

0

Only one well, MW-22, was drilled below the expected depths of the pits. In this well, voe contamination increased with depth. Data from the deepest sampled fracture (263 feet) indicates that voe concentrations approach two orders of magnitude greater than the uppermost sample fracture (45 feet). Based on information from both this well and that presented in Figures 2-12 and 2-13, the existance of voe contamination deeper in the bedrock aquifer is highly likely.

Figure 2-14 shows voe concentrations found in surface water. For each sample station, the voe concentration was included on the map with a symbol indicating the concentration range of the sample. voe concentrations upstream of the site (i.e., SW-302, SW-615; SW-601; SW-614; SW-613; SW-610) all have concentrations below the detection limit. The notable exceptions are sw-101 through SW-301. voe concentrations increase at each of the four seeps along the site. Downstream of the site, the concentrations decrease as dilution and/or volatilization takes place. By the time the unnamed stream exits the golf course area (SW-321), voe concentrations in the surface water approach background concentrations.

An in-depth review of seep and monitoring well data indicates that Seep BS0306 and the seep above BS0107 appear to be fed by the bedrock aquifer. The seep near the car-wash (SW-108, SW-308) and along the southern boundary of the site (SW-425) appears to be fed by the overburden aquifer. This was determined by comparing the contaminants in the seeps with those in the adjacent overburden and bedrock monitoring wells. It appears that groundwater wells near the two bedrock seeps exhibit upward gradients, while the majority of wells on the site exhibit downward gradients. It is hypothesized that bedrock fractures exist in these vicinities, which allows the deeper, more contaminated water to discharge to the surface. The Phase II field investigation has been designed to verify this assumption.

Figure 2-15 illustrates voe concentrations measured in the sediment throughout the study area.voe concentrations increase immediately below the seeps and in Middle Marsh. It appears that the groundwater serves as a source for voes from the seeps and continuous groundwater discharge to the unnamed stream, and that these compounds are sorbed to soil/sediment particles and transported to the Middle Marsh area where deposition occurs. Two samples in the golf course area (SD-317, SD-322) have voes above those anticipated. Because the samples are upstream from the surface water flow of the unnamed stream, it is probable that they represent non-site contamination.

-22

0;·I~. I

) lI

I

..•.... -:·· ._voc_-J_,.~. _ .

--\ ' · so,04

ltlllOL£·\~G>vocc.,.. IIAMtt

·

I (:)°so ·eo,,IOI .. VOC, L:JVOC•7J'" (:;;,·

' >---:,. \ ,..··,., J\· ,_.-:'. v ,:i I ' ._)\ '-..._ ,_.,-' I:,· : 'I

- ~~ ::=~~-~~ :~ !l ..

... SD61qr.,.- 1,:111.••• VOC· 7 0 Jpp. ~-· '. : r • ---~- u . ' ·, ' ; :

0

r:, S1161Z / •, ' I ·-L:J\'OC·62.J11111,tr, C ' · J

(r--...._ \ I { C, \ ,. " )

,'. G .;•--;! ~,

FIGURE 2-16 I VOLATl.£ ORGANIC COMPOlH>S(VOC)(ppb) .

SEDt.l:NT Sll.UVAN'S LEDGE LANDFU

NEW BEDFORD, MASSACHUSETTS II

2.2.4 Base/Neutral Extractable Compounds Data Analysis

It was indicated in the Phase I RI report that only three of the base/neutral extractable compounds were identified as having any potential for public health risks: benzo(a)pyrene (BAP), n-nitrosodimethylamine, and n-nitrosodiphenylamine.

BAP is a potential public health risk for direct contact with site soils and stream sediments. To determine how much site soil was contaminated with BAP, contaminant maps were developed. Figures 2-16 through 2-18 illustrate the BAP concentrations found in the test pit soils. Unlike the other test pit maps, BAP hot spots are located around the site and are not confined to the southern and eastern portions.

Figure 2-19 highlights the BAP concentrations in the study area sediments. The site may contribute BAPs to the sediment, but this is difficult to determine because several background samples have BAP values 'in excess of those found downstream of the site. This is not surprising; BAP is a component of diesel fuel and combustion products and its presence would not be uncommon in the high traffic area surrounding Sullivan's Ledge.

The two other compounds, n-nitrosodimethylamine and n-nitrisodiphenylamine, were found only in the two seeps that enter the unnamed stream along the eastern edge of the property (BS0306 and BS0308). Therefore, any potential risk is confined to these seeps and the aquifer feeding the seeps.

2.2.5 Lead Data Analysis

In the Phase I RI report, lead was determined to be the only inorganic compound posing any potential risk from contact with the surface soils. Figure 2-20, developed to determine if any hot spots occurred on the site surface, highlights a potential lead hot spots near TP-2 and TP-9. Limited data was available for these test pits to determine the exact aerial extent of the hot spots. Additional sampling will be performed in this area to gain more data on PCB and lead distribution (see Section 2.2.2).

Elevated concentrations of lead, found throughout the site surface, are expected because the Sullivan's Ledge site is in a high traffic area and lead is known to be a gasoline additive. An EPA report indicates that lead occurs in all soils with a range of 1 to 200 ppm. Near highways, however, lead concentrations have been found in the range of 150 to 522 ppm (EPA, 1980). All site surface soil data fall within this range, except the two test pits discussed earlier.

-25

-----ml!!!.----;.-.=:,::,:_.·--

r.l> ==~...............·:,·== ~nra. ....... 00,~--. • -~OQLI =--

T~·Z4.s -TUT l'lll.OCAT110 -lt:NZO IA) rYN(Nf

CONC(NTll.&TION loo•I

-- INflllRtD CONCTl ,/

~/

FIGlff 2-16 INTERPRETATION OF BENZO (A) PYRENE DATA(ppb)

SOLS 0-3' SUUNAN'S LEDGE LANDFll

NEW BEDFORD, MASSACHUSE1TS

-------·---·-___t ·-"' ~ -IOIDI ,,,....11...wf ·~:::ru,----·--::.: " ---• 1111U • """UT'I OGL.& =·-

'"·14$ -TUT 11T ux:•TU - 8(1110 IAI ..Yll(II(

COHCEHTICATIOH IH-1

115 NOT 5AMl'LlD

INFllllR£0 COHClNTII" N /

,i.___~~~~~-------l

f1GlR: 2-17 INTERPRETATION OF BENZO (A) PYRENE DATA (ppb)

TEST PIT SOLS 3'-ti'

SUUIVAN'S LEDGE LANDF1.1.

NEW BEDFORD, MASSACHUSE1TS

---

,.,.._

--·-'~n..r-,0 0 100 200fEET

WI!!!-·----·---·--~ ==~......-----11..,Y •Jf•:=~...'9 ·TII -::.:_ ·fllll.t=·-·-~

NS NOT SMll'LlO

- - INl£1111£D CONCfll'N /

ii-~~~~~---' I ,

0 /

/ / ~/;

I

I

/ -~· - ---

, -~----....____ __ -,

.wl!!l..-·-·------- .....~ :::r,_----.:t· :::: 11,.~.. 'Ill •'11 IOI,:::.,,_,=·-. """'" ......

T"•Z4 .JO - TUT PIT U>CATICIN ~~ - LUO COHCTll°N 1•11111

J (SllMAllD VALU(

IHfllUl(D COHCIHlll0

N

* DUl'l.lCATE VALUt OUTSIDE Of COIITIIOL UNIT

0

' \

.... ~50J* T

.,,.. 100p,,.,1

s 141J*

,,..,o s

166J

J I FIGURE 2-20

INTERPRETATION OF LEAD DATA (ppm) SOLS 0-3'

SUUJVAN'S LEDGE LANDFI...L NEW BEDFORD.MASSACHUSETTS

Lead concentration mapping was also performed for the data from 3 to 6 feet and 6 to 9 feet. The lead levels

test were

pit not

of concern and, therefore, not included.

The majority of the surface water lead data was rejected during data validation. It is not possible at this time to determine, therefore, what impact lead contamination from the Sullivan's Ledge site has on surface water and biota in the unnamed stream and Middle Marsh. A program for additional surface water samples, proposed to fill this data gap, is outlined in a later section of the report.

2.2.6 Separation of Sullivan's Ledge and the New Bedford Municipal Landfill

The Conrail tracks form the northern boundary of the Sullivan's Ledge study area. Industrial waste disposal at the NBML, located opposite the tracks, has been well documented (NUS, 1986). Based on the data analysis presented in Sections 2.2.2 through 2.2.6, there appears to be a separation between the two sites. PeBs and voes are the two major contaminants that are present and transported from the Sullivan's Ledge site.

PeBs have been documented in site soils and are believed to be transported via erosion and sedimentation into Middle Marsh. The Middle Marsh appears to serve as a sink for a majority of the PeBs. PeBs are still documented in the sediments along the stream length between Middle Marsh and the railroad tracks, but at reduced concentrations (see Figure 2-8). PCB contamination was found downstream of the site in the Apponagansett swamp; however, this was an estimated concentration and not confirmed. Sediment sampling for PeBs will be performed in the Apponagansett Swamp during the Phase II field investigation to verify this assumption.

voes are transported from the Sullivan's Ledge site through the overburden and bedrock aquifers and from the seeps believed to be the prime voe contributor to site surface water. Figure 2-12 shows that the Sullivan's Ledge voe contaminant plume appears to be south of Middle Marsh, indicating that the contamination has not progressed to the NBML. Figure 2-13 shows that the shallow (i.e., less than 100 feet deep) bedrock contaminant plume has just reached the Middle Marsh area. The bedrock wells closest to the NBML (MW-8, MW-9) appear to be free of voe contamination; therefore, a separation appears to exist for the· shallow bedrock aquifer.

Figure 2-14 illustrates the voe concentrations in the study area. voe concentrations are highest at the seeps located adjacent to the site, while they are less than 1 ppb as the surface water leaves the site area at the railroad tracks. A separation of the two sites exists for voes in the surface water at the point where the unnamed stream flows beneath the tracks.

-31

The separation of the two sites will be verified in the FS, based on the information collected in the Phase II RI (e.g., water level measurements, selected well sampling, and PCB sediment sampling).

2.3 PHASE I RI RISK ASSESSMENT

This section provides a summary of the Sullivan's Ledge Risk Assessment conducted by NUS as part of the Phase I RI (NUS, 1986). Table 2-1 contains the major findings of the Risk Assessment. The first column shows the exposure pathways that were identified and evaluated in the Phase I Risk Assessment. Columns 2 through 5 identify the indicator compounds that, in the Phase I RI, presented either noncarcinogenic risks (i.e., a hazard index above one) or incremental carcinogenic risks that f~ll within or ab2ie the s~~erfund total target carcino~enic risk range of 10 to 10 (EPA, 1986). Risks associated with both the most-probable and realistic worst-case exposure conditions (based on average and maximum contaminant concentrations, respectively) are reported in Table 2-1.

The exposure assumptions used to estimate the risks at the Sullivans's Ledge site are summarized in Table A-1 in Appendix A. Jordan will use results from the Phase I Risk Assessment, together with the new risk estimates produced in Task 6, to develop response objectives for the Sullivan's Ledge site.

-32

3tinii.rq - SI2 TABIE 2-1

SlltflARY OF FINDilGS OF EHASE I RISK ASSESSHENI' SULLIVAN'S lIDiE

(page l of 4)

Carcinogenic Ettects (1) NQO::arciJPJeoic Effects (2)

Host Probable Raalistic ttist Prooable Realistic Exposure Q;nlitig,s HQrst O>niitig,s Expoeure Q;lnjitions warst Q::niitions

2) Direct o:intact with surtaoe water

Saepa - '1\'Pical now o:niltiaw - I.aw Fla., Qniltiaw

South of Sita

South ot Hathaway aoait

North ot Hathaway lad

Benzene, Hathylena Chloride, 'ICE, Vinyl Chloride, Chlorofom (6 x

_310 )

Benzene, 1,2-Dichlormat.hana 'ICE, Vinyl Chloride, Chloroform

Same plus DEMP (6 x 10 1)

Trans-1,2-CX:E, Styrene, ~

Same plus 2-aitaoone

Hathylena Chloride, Rl, MJ, lq, Ni Toluene, N-nit.rcsodipienylaaina, -1 Bia-2-chloroathyl ether, .ECBs (1 x 10 )

Chloraienzene, Methylene Chloride

N-ni trcscxUmethylaaina (2 X 10-7)

N-nitrosodipienylaaina_7(4 X 10 )

http:3tinii.rq

TABlE 2-l SlHIARY OF FINDilGS OF RfASE I RISK ASSESSHml'

SULLIVAN'S Im.E (page 2 ot 4)

carciroqenic Ettects Noigrcincqenic Effect§

tbit Pra:iabla Realistic Hc6t Probable Rulistic '£XpOSIJre Cgy;Uti(l)S worst eoroltigw ExposUre o:n:Utions Horst Q:n:1iti9M

Water Hazarda

M,llt Goltera

North of Hathmiey RDlld

Water Hazarda

3) Dinct C'mtlct with SaiiJDents

Seeps .Adjacent to Sita

SQith ot Site

SQith ot Hathaway RDlld PCBs (6 X 10-7)

North of Hathaway Road PCBs (4 X 10-7 )

Water Hazarda PCBs (1 X 10-7)

Hiddle Hanh

Mllt Golfer,

TABlB 2-1

SlHfARY OF f'INDDe OF PliA.SE I RISK ASSESSHENI'

SUILIVNf IS U1XiB

(page J ot 4)

carcimgenic Ettects Honcarcireqenic Effect;t

Realistic tut Pralable Realistic Worn Corditions E>cpo§l.lre CorditiQ')S Worst q;p:iitions

Seeps kljaoant to Sita

- South of Sita

South ot Hathllway Rcad

North of Hathaway Read

Water Hazuds

Kiddle Marsh

5) Direct cmtact with SUrtaoe Soil

Ott-site Golf Ccurse

Golt 9!1IM Wcrkor CQtt-sitel

Kl!.s (9 X 10-7)

-6l'CBs (5 X l0-7) PCBs, B(a)p (J X 10 )

l'CBs (4 X 10-7) PCBs (9 X 10-7 )

l'CBs (5 X 10-7) PCBs (2 X 10-6)

Pees, B(a)P (4 X 10-6)

TABLE 2-1

SlfflARl{ OF FnIDD«iS OF AIASE I RISK ASSESSHENl'

SUILIVAN'S UIXiE

(page 4 ot 4)

Carcinogenic Ettects Hro;;,arcinogenic ECfects

1bit: Probable Realistic Realistic f'lT9rpJre Corditioos Worst c:bn;Utia,s Worst Cgditigm

6) Accidental lnjastion ot surt11CB Soila

layae NA NA

8) InhAl.atj.cm ot Partiauat:es

NA K:&i (5 X 10-6) HA

NA K:&i (2 X 10-6) NA

(1) 'Iha estimated litet.u. in::remental CAr£~~ri.sks associated with tha 8lCPJSUI"& pathway are lihown in parentheses; only risks within or above tha SUperturd target rarga ot 10 to 10 a.re shown.

(2) 'Iha hazard !max tor the exposure patn.tay is shl:Ml in parentheses1 only hazard imioes above l are shanl. (3) Ciuihaa imicate that either the hazard iMex was l or below, or that tha incremental. carcinogenic risk was below 10-7

NA

http:InhAl.atj.cm

3.0 SCOPING OF THE PHASE II REMEDIAL INVESTIGATION/FEASIBILITY STUDY

The· site characterization work performed by NUS is considered the Phase I RI. To refine the general site characterization and obtain information necessary to evaluate remedial alternatives, Jordan will perform additional work which is considered the Phase II field investigation. Jordan will develop response objectives for the site based on the information from the Phase I RI and modified with information from the Phase II field investigation. Figure 3-1 illustrates the phased approach to the RI/FS selection process.

The scope of the Sullivan's Ledge RI/FS, developed in meetings with EPA, promotes this phased approach by:

• Providing a comprehensive rationale for the Phase II field investigation based on a thorough review and evaluation of existing data.

• Defining specific data requirements by reviewing the Phase I RI and scoping potential remedial alternatives. These data requirements aid in the definition of Applicable or Relevant and Appropriate Requirements (ARARs) and Data Quality Objectives (DQOs).

• Incorporating previous considerations into the development of Project Plans. The Work Plan was developed concurrently with the Field Operations Plan (FOP). The FOP contains the Site Management Plan (SMP), the Field Sampling and Analysis Plan (FSAP), and the Health and Safety Plan (HASP).

3.1 SCOPING OF REMEDIAL ALTERNATIVES

Based on the information presented in the Phase I RI and the requirements of Section 121 of the Superfund Amendments and Reauthorization Act (SARA) and the current National Contingency Plan (NCP), a scoping of remedial alternatives can be performed for the site. This is accomplished by developing preliminary remedial response objectives and preliminary remedial response actions.

3.1.l Preliminary Remedial Response Objectives

Response objectives will be developed based on l) the requirements of SARA, 2) the NCP (to the extent practical), and 3) the site-specific contamination. Response objectives will be developed that:

-37

Remedial lnveellgallon

f'hHe I Sile ( : .........., ......m

r---------· ·- ---··· -... S••lf*'I

ot Ille 111'1 S

lden1,1, polenllal l•e•llh ............ lc1t1t,un 111ecilic 1111e1f ede1.a AIIAll1. del••-ne 111111.i action lev1l1

1 htane,1, lfllll.a data q,11lil' ullfeCIIVH flHlOal 1111 1e1ne,li1I........,.,.._

l ........., ........ pt11fell•u11e1i1llle 10,ot. li~••v ,e,,.....,. '' .......11

---~

I llelme 11•l111e 111., e•leul ol u111l•111111t1hon C••••• 1,11•1. COlllellllilllUIII. dl1l11l,ulio1111

1 ll•lme 111101

l Auen nee,I Im 11eel•btl1li, lltodlel. NllkllJlllif m•lelllll h111dllnv

I

I '

+........

liewelupmenl ul AlleU1•hve1

I lilttnhlw 1u1lenh•I 1111,1111111111 l•1 l11111lug111. lUlll•1111111111ll1h~p11li1I •••111111m1111l1 1111 ••" ....... flt ............-·~··................

AIIAla. Ce It . 1•1111 h•nl

1 A11111nbl• l1e11lm11111 1h1po1•I ,omh11••l111111 111111 •h111nehw111

l llevek,p • , ange ol ............... ..........11

v,11111111 l1v1l1 ul 1111•11111111 1111lt11m•m;e

feHlbllll1 .... I Sludv

PIIHeH i.,11111 Sc,eenlng

Sueen 1ll1m1llv11 lu n•11uw lhe 1111d lo be ....., .... Ill .....ii

SOURCE: U.S.EPA, OFFICE Of SOLID WASTE AND EMERGENCY RESPONSE, DIRECTIVE No. 8366.0-18, "INTERIM GUIDANCE ON SUPERFUND

r~_... • Pu•I Sc:1e•111ng

f 1e1J IIIVHli9.tl1011

I Pe1lo1m ••••l•bllo•, IHII II nece1111w

2 Collecl 1c1J1ll1H11l l1eld dale. 11 11ecea111w lo 1111111 g111e11I 1lle ch111cl11 I, IIIUII

•

Selecllon ot ll11m•"t

I &ele,1 I ........f 11111 ii pu,l•LIIVI &II human ll••llh and 11,e a11111tonm111I

l Selecl a ,u,I· atlecllve ,emellw

l s..., ...........,

lhal ..... ·····"S11111t etJe1 •I

AIIAR1 ""°'' ,onlfllehun

• Sel•cl • ,e1111,lw 1h11 UHi pa,111••••111 1ol11leon1 •ntJ allemallv• lul111uluyl11 lo Iha ma•lmu,n e•lenl p1uhcabl1

6 Co1111"•• u•e ol loleum •••vu111e1

, I

Pll111 HI Uel1ll1d A1111,111

ol All1m111vu

I Develop 91ne11I pe,lounence c,ile11• lo 11,h 1llem111v1

1 Anel,11 1el1llv1 co111 . long ••"' 1ho1I 111111 1ll1cllv111H1.

I~lmplem111leblt1tw

J va,11,,cOffltl••• p,01ecllv1n111, p,011clion ol public heallh and envltonmenl. compll1t1Ce with AnAR1. 11d11cllon of IIIOblMlwt loa1cltw C•H•lnm•nt ol p,el11~nc1 101 pe1m111111I 1olullon1 lm,olvina 1te11menll.•,.., olhe, 1111ulu1w l11t.11111 1co1111tJ1, w111ve11. ill IUtCIUillWI

FIGURE 3-1

SELECTION OF REMEDY", DECEMBER 24, 1986. RI/FS REMEDY SELECTION PROCESS

SULLIVAN'S LEDGE RI/FS WORK PLAN . ..._-------------------~---------- - ·-·---------- ------------·-------·

• prevent or mitigate further releases of contaminants to surrounding environmental media;

• eliminate or minimize the threat posed to public health or welfare or the environment;

• reduce the volume, toxicity, or mobility of hazardous waste through the use of treatment technologies; and

• utilize permanent solutions and alternative treatment technologies or resource recovery technologies to the maximum extent practicable.

Preliminary response objectives have been developed by Jordan and EPA. The final response objectives will be determined with EPA following the evaluation of data collected in the Phase II field investigation. The preliminary response objectives for source control measures are as follows:

• Prevent or mitigate the continued release of hazardous substances, pollutants, and contaminants to the unnamed stream and Middle Marsh.

• Reduce risks to human health associated with direct contact with contaminants in surface and sub-surface soils and sediments.

• Reduce risks to freshwater aquatic life associated with contact with PCB contaminated sediments and subsequent bioaccumulation. Freshwater aquatic life include both sediment dwelling organisms and those at higher trophic levels.

• Reduce the volume, toxicity, or mobility of hazardous substances, pollutants, and contaminants.

Preliminary response objectives for the management of migration measures include:

• Reduce risks to human health associated with dermal contact and subsequent absorption from the seeps, ingestion of groundwater, and inhalation of volatiles released from the seeps.

• Eliminate or minimize the threat posed to public health and the environment from the current and potential future extent of contaminant migration in groundwater and surface water.

• Maintain air quality at protective levels for on-site workers and the public during site remediation.

-39

3.1.2 Preliminary Development of Remedial Response Actions

To meet preliminary and potential response objectives discussed in Section 3.1.1, two categories of general response actions were identified: l) source control actions; and 2) management of migration actions. The no-action alternative is also being considered.

These general response actions, together with potential remedial alternatives addressing them, are discussed in the following paragraphs.

No-action. The no-action alternative will be evaluated during the development of remedial alternatives (see Section 4.9.1). The purpose of the no-action alternative is to serve as a baseline risk assessment to which the other alternatives will be compared.

Source Control Alternatives. Source control remedies, which treat, prevent, or minimize migration of hazardous substances from the source material, may assist in the attainment of response objectives by minimizing the inhalation of contaminants, preventing direct contact with contaminated soil, surface water, and sediments.

At the Sullivan's Ledge site, the source area consists of the quarry pits, which were filled with hazardous wastes, the site soils, which are predominantly fill material used to cover the pits and the contaminated sediments in the unnamed stream and Middle Marsh. Source characterization of the site surface soils and stream sediment was performed in the Phase I RI. Several additional soil samples will be taken during the Phase II program to further define soil contamination along the site's eastern boundary (see Section 4.3.3.3) and to determine the distribution of the PCBs in the sediment.

Although adequate source characterization is necessary for effective source control, it was not performed for the quarry pits during the Phase I field investigation, and is not proposed for the Phase II program. The REM III team and EPA have indicated three reasons why source characterization of the quarry pits is not recommended at the Sullivan's Ledge site:

(1) Operational Considerations. The Sullivan's Ledge quarry pits, believed to be 150 to 300 feet deep, were used for the disposal of transformers, cars, tires, refuse, and timber. To provide comprehensive characterization, any borings in the pits will need to be drilled at least to the bottom of the pit. Although drilling through this type of material is technically feasible, it would be difficult.

-40

Drill bits or casing intercepting a car, timber, or refrigerator can deflect and shift the boring off center. When this occurs, the boring has to be abandoned and repeated.

(2) Technical Considerations. The material disposed in the Sullivan's Ledge quarry was varied, ranging from industrial solvents to junk cars. Because no records were kept of the location of disposed items, it must be assumed that hazardous waste may be present in any or all of the four pits. To address source characterization, a sufficient number of borings (i.e., four to five borings per pit) would be required to develop an understanding of the heterogeneity and characteristics of the waste material.

(3) Health and Safety Considerations. A significant concern is the health and safety of site workers performing the drilling in the pits. Based on characteristics of wastes known to be present at the site, drilling would most likely be performed with Level B protection (i.e., full dermal protection and artificially supplied air). Ammunition and cyanide, reported to be disposed of in the pits, present potential significant hazards. Also, transformers and other contained units may be in the pits. If these items are pressurized, punctures during drilling would result in other hazards.

For these three reasons, source characterization of the pits is not recommended by EPA and the REM III team.

Source control alternatives potentially applicable to the site include the following:

• alternatives that reduce the mobility, toxicity, and volume of the waste material;

• alternatives that prevent the continued erosion of contaminated soils into the air and unnamed stream; and

• alternatives that remove and/or treat contaminated sediments located along the unnamed stream and within Middle Marsh.

Source control alternatives that may be appropriate for the on-site soils include capping, removal and treatment, and in situ treatment. Source control alternatives that may be appropriate in removing or treating the contaminated sediments include excavation/treatment, in situ biodegradation, and solidification.

-41

Management of Migration Alternatives. Remedial actions designed to manage contaminant migration must be evaluated when hazardous substances migrate from the original contaminant source. At Sullivan's Ledge, off-site migration of VOCs is known to occur through the seeps, surface water, and groundwater. Management of migration could be accomplished by:

(1) preventing the migration of groundwater flow to the seeps and stream;

(2) containing the groundwater plume in its current location, or reversing the flow direction to maintain the plume within site boundaries;

(3) extracting and/or treating the contaminated groundwater; and

(4) treating the surface water prior to leaving the site boundaries.

Management of migration alternatives that may be effective include a groundwater extraction/treatment system, physical containment barriers, and in situ biodegradation. Groundwater extraction/treatment systems include either an extraction well system or a passive collection system (e.g., subsurface trenches). Potential treatment technologies include a physical/chemical step to remove inorganics, and a VOC treatment step (e.g., carbon absorption, biodegradation in a reactor, air stripping, or UV/ozonation).

Potential physical containment barriers include slurry walls to prevent the overburden groundwater discharge, and barrier walls.

3.2 IDENTIFICATION OF DATA REQUIREMENTS

3.2.1 Definition and Development of ARARs

The National Contingency Plan (NCP) defines ARARs as "applicable or relevant and appropriate requirements," and identifies two categories for consideration during the RI/FS and remedial action design: (1) ARARs, and (2) additional guidance to be considered. In addition, the NCP further defines two components of ARARs:

(1) Applicable Requirements. Applicable requirements are those federal requirements that would be legally applicable to the response action if that action were not taken pursuant to Section 104 or 106 of the Comprehensive Environmental Response, Compensation, and Liability Act (CERCLA).

Requirements that are applicable to and have jurisdiction over given situations are considered "applicable requirements." An example would be Maximum Contaminant

-42

Levels (MCLs) for a site exhibiting groundwater contamination when the groundwater supplies water to the public via a central distribution system.

(2) Relevant and Appropriate Requirements. Relevant and Appropriate Requirements are those federal requirements, although not "applicable," designed for problems sufficiently similar to those encountered at CERCLA sites to make their application appropriate.

Relevant and Appropriate Requirements are intended to have the same weight and consideration as Applicable Requirements. Therefore, once a requirement is identified as relevant and appropriate, it is applied in the same manner as an Applicable Requirement. The term "relevant" was included so that a requirement initially screened as nonapplicable because of jurisdictional restrictions would be recondsidered and, if appropriate, included as an ARAR for the site. For example, MCLs would be a suitable, nonapplicable requirement for a site exhibiting contamination of groundwater that is not a public water supply.

According to these NCP definitions, only federal regulatory requirements are considered ARARs. SARA further expanded this definition of ARARs to include state regulatory requirements, as well as certain federal nonregulatory requirements. Prior to the enactment of SARA, state regulatory requirements were considered but given less weight than federal requirements. As a result of SARA, state requirements that are more stringent than federal requirements, and are duly promulgated and consistently applied, must generally be attained. SARA also requires that certain specific federal nonregulatory guidance and criteria be attained, including Ambient Water Quality Criteria (AWQC).

ARARs are used as a guide in evaluating the appropriate extent of site cleanup, scoping and formulating remedial action alternatives, and governing the implementation and operation of the selected action. ARARs are identified and considered so that CERCLA responses are consistent with pertinent state and federal environmental laws. In the absence of ARARs that address a particular site problem, federal or state guidance and criteria other than those specified herein may be considered and used, as appropriate.

Under the description of ARARs set forth in SARA, many state and federal environmental requirements must be considered. These ARARs fall into three general categories:

• chemical-specific (i.e., govern the extent of site remediation)

-43

• location-specific (i.e., pertain to existing site features)

• action-specific (i.e., pertain to proposed site remedies and govern the implementation of the selected site remedy

Chemical-specific ARARs are usually health- or risk-based values limiting the concentration of a chemical that can be found in or discharged to the environment. They govern the extent of site remediation by providing either actual clean-up levels or the basis for calculating such levels. For instance, groundwater standards may provide the necessary clean-up goals for the Sullivan's Ledge site. Chemical-specific ARARs will be used to refine remedial response objectives, modify potential alternatives, and formulate new alternatives, as necessary.

Location-specific ARARs are requirements that must be considered due to the site location and features. Site features governed by location-specific ARARs may include natural features, such as wetlands, floodplains, and sensitive ecosystems. Also, places with historical or archeological significance may be governed by special requirements. Location-specific ARARs may also include requirements that govern site landfills or disposal areas. These ARARs provide a basis for assessing existing site conditions, and subsequently aid in assessing potential remedies.

Action-specific ARARs are based on the limitations or features of remedial technologies and site activities. These ARARs are used during the evaluation, selection, and design of site remedial alternatives. For example, if groundwater or leachate is treated and discharged on the Sullivan's Ledge site, national and state pollution discharge elimination system requirements must be considered.

3.2.2 Consideration of ARARs during the Phase II RI/FS

ARARs will be considered at four decision points during the Phase II RI/FS. Specifically:

(1) Task 3 - Field Investigation. Location-specific ARARs will be considered when determining data to be collected in the Phase II field investigation.

(2) Task 6 - Phase II RI Risk Assessment. Chemical-specific ARARs will be considered during the analysis of risk to public health and the environment.

(3) Task 9 - Remedial Alternatives Screening. Action-specific ARARs will be considered during the identification and screening of remedial technologies/ alternatives.

-44

(4) Task 10 - Remedial Alternatives Evaluation. Each of the ARAR categories will be revisited during the detailed analysis of alternatives. In this section, attainment of ARARs will be evaluated for each alternative. If needed, specific design parameters will be outlined for each alternative to ensure that the alternative will attain ARARs if selected for remedial design and implementation.

3.2.3 Initial Identification of ARARs

Tables 3-1 through 3-3 outline ARARs considered relevant to the Sullivan's Ledge site. Table 3-1, which was developed based on data presented in the Phase I RI report, lists the chemical-specific ARARs. Table 3-2 illustrates the location-specific ARARs considered pertinent. Table 3-3 highlights potential action-specific ARARs. These ARARs were identified based on potential remedial alternatives discussed earlier. They will be refined and revised through the RI/FS process as discussed in Section 3.2.2. Additional ARARs provided as guidance by EPA will be incorporated as available.

3.2.4 DQOs Determination

DQOs are based on the concept that different data uses may require different data quality, which is the degree of uncertainty with respect to precision, accuracy, reproducibility, completeness, and comparability (PARCC) of a data base. DQOs are qualitative and quantitative statements describing the data required to support Phase II RI/FS activities (including site screening, characterization, and risk assessment), and to support engineering alternative evaluation and selection decisions and enforcement. Four broad categories of data quality are used in the Phase II RI/FS process:

Level I - Field Screening. This level of data quality is the lowest; however, it provides the most rapid results and assists in the optimization of sampling locations and health and safety support. Generated data provide presence/absence of certain constituents, and are generally qualitative rather than quantitative.

Level II - Field Analysis. This level of data quality is characterized by the use of both analytical instruments carried in the field and mobile laboratories. Depending on factors such as instrumentation and environmental matrix, data may either be qualitative or quantitative.

Level III - Laboratory Analysis. This quality level represents data generated under laboratory conditions using EPA-approved procedures other than Contract Laboratory Program - Routine Analytical Services (CLP-RAS) protocols. This level is used for certain types of source, extent, or

-45

TABLE 3-1

POTENTIAL CONTAMINANT-SPECIFIC ARARS

SULLIVAN'S LEDGE SITE

FEDERAL REQUIREMENTS

Does this Apply?

REQUIREMENT RS 00 COHMENTS

1. SOWA - HAXIHUH CONTAMINANT LEVELS (HCLs) (40 CFR 141.11 - 141.16) X Relevant and appropriate. Final or proposed MCLs exist for most of the groundwater contaminants at the site.

2. CAA - NATIONAL AMBIENT AIR QUALITY STANDARDS (NAAQS) (40 CFR SO) X NAQS for particulate matter may be considered during assessment of soil removal options .

..• MASSACHUSETTS STATE REQUIREMENTS

REQUIREMENT

Does this Apply?

RS 00 COMMENTS

1. DEQE - AIR QUALITY, AIR POLLUTION (310 CHR 6.00 - 8.00) X Relevant and appropriate - standards for particulate matter will be considered during assessment of soil removal options.

2. DEQE - DRINKING WATER REQUIREMENTS (310 CMR 22.00) X Requirements apply only to public water not applicable to the site.

system;

3. D.I.S. - SUBSTANCES HAZARDOUS TO HEALTH (441 CMR 1.00 - 9.00) X Refers to various not applicable.

industrial safety standards;

4. HDWPC - GROUND WATER QUALITY STANDARDS (314 CMR 6.00) X Relevant and appropriate - Ground Water Quality Standards exist for most of the contaminants at the site.

S. HDWPC - SURFACE WATER QUALITY STANDARDS (314 CMR 4.00) X Surface Water Quality Standards do contaminants at the site.

not exist for

6.87.157 0001.0.0

TABLE 3-1 (cont.)

POTENTIAL CONTAHINANT-SPECIFIC ARARS

SULLIVAN'S LEDGE SITE

FEDERAL CRITERIA, ADVISORIES, AND GUIDANCE (FCAG)

Do these FCAG5 Apply?

FCAG YES NO COttttENTS

1. FEDERAL AHBIENT WATER QUALITY CRITERIA (AWQC) Relevant and appropriate - AWQC exi5t for grouudwater and surface water coutaaioanta.

2. HAXIHUH CONTAHINANT LEVEL GOALS (HCLGS) X Relevant and appropriate groundwater contaminants

- HCLGa exist for at the site.

3. TSCA SECTION 80 IIEALTII AND SAFETY DATA X Hot applicable.

4. HEALTII ADVISORIES (EPA OFFICE or DRINICIHG WATER) _!_ Relevant only to drinking water exposures. 5. TSCA CHIHICAL ADVISORIES/FACT SHEETS -· X Provide qualitative toxicological information on chemicals; not applicable here. 6. EPA RIS( REFERENCE DOSES (RfD) _!_ Appropriate for use in quantitative public healtb

evaluation of remedial alternatives, if adequate data exilit.

7. EPA CARCINOGEN ASSESSMENT GROUP POTENCY FACTORS _!_ Relevant and appropriate - potency factors aay be used to develop target soil cleanup levels.

8. ACCEPTABLE INTAJCE - CHRONIC ASSESSMENT DOCUMENTS

(AIC) AND SUBCHROHIC (AIS) - EPA HEALTH X

Appropriate for use in quantitative public health evaluation of remedial alternatives, adequate data exist.

if

9. PESTICIDE REGISTRATION DATA X Not applicable.

10. EPA OFFICE OF WATER GUIDANCE - WATER-RELA'{ED ENVIROHHENTAL FATE OF 129 PRIORITY POLLUTANTS (1979) X Relevant - transport and

assessed. fate of pollutants were

11. TSCA - POLYClll.ORINATED BIPHEHYLS SPILL CLEANUP (40 CFR 761, SUBPART G; 761.120 - 761.135)

POLICY X Not applicable to CERCLA sites, but standards are relevant and appropriate and aay be used as guideline for the site.

6.87.157 0002.0.0

TAbL£ l·I (cont.)

l'O'l't:N'flAL CONTAHINAH'f-Sl'l!:ClflC AkAkS

SULU VAN'S l.£0t.i£ SIn:

•

ttASSACIIUSHfS CRITEIIIA, ADVISORIU, ANll tiUIIUNC.:J:: (tlCAl.i)

Do tlac:;c tlCAGs Avply't

----~-----------------NC--'A-G____________~--~--------------~-~Y!S NO ______ -----Clltltlt:N'l'S ______ -·

I. ttASSACUUStns GUIPAHC£ 011 ACC£1''fA8L£ Mllllt:NT AIR Lt:VUS (AALs) X H•Y be •l'l'l·ovd.ilc to 11rou11Jw.alcr ll·c•l111cnl wh.:n voes ... y be c111illcJ.

z. NASSACNUS£ns PRINICING "AT[ll 11£ALTH ADVISOlllES llc•lth •Jviliocic:; c:xht foe coul.t111i11.a11lM •t llaa: II it C,

..•

6.117. IH 000 ).0. o

TABLE 3-2

POTENTIAL LOCATION-SPECIFIC ARARS

SULLIVAN'S LEDGE SITE

FEDERAL REQUIREMENTS

Does this Apply?

REQUIREMENT YES NO COHHENTS

1. CWA - 40 CFR PART 404 X Relevant and appropriate to alternatives that affect the Hiddle Harsh area.

2. NEPA - 40 CFR PART 6 X Preparation of RI/FS precludes preparation of EIS.

3. ENDANGERED SPECIES ACT (16 U.S.C. 1531, 50 CFR PARTS 81, 225, 402) X Threatened or endangered species are not present at the :.ite.

4. WILD AND SCENIC RIVERS ACT (16 U.S.C. 1271) X Not applicable.

...5. FISH AND WILDLIFE COORDINATION ACT (16 U.S.C. 661 NOTE) X Requirements addressed in CWA Section 404. 6. FISH AND WILDLIFE CONSERVATION ACT (16 U.S.C. 2901, 50 CFR PART 83) X Requirements addressed in CWA Section 404.

7. COASTAL ZONE ttAHAGIHENT ACT (16 U.S.C. 1451, 15 CFR PART 930, 923.45)· X Not applicable.

8. HISTORIC SITES, BUILDINGS, AND ANTIQUITIES ACT (16 U.S.C. 461) X Not applicable.

9. NATIONAL HISTORIC PRESERVATION ACT (16 U.S.C. 470) X Not applicable.

10. PROTECTION OF ARCHAEOLOGICAL RESOURCES (32 CFR PART 229, 229.4; Relevant and appropriate to 43 CFR PARTS 107, 171.1 - 171.500) X excavatiou act,vities.

HASSACHUSETTS STATE REQUIREMENTS

Does this Apply?

REQUIREMENT YES NO COHHENTS

1. ENVIRONMENTAL AFFAIRS - HEPA (301 CHR 10.00) __!_. Preparation of RI/FS precludes preparation of UR.

2. ENVIRONMENTAL AFFAIRS - COASTAL ZONE HANAGEHENT PROGRAM X Not applicable. (301 CHR 20.00 - 22.00)

6.87.157 0004.0.0

TABLE 3-2 (cont.) POTENTIAL LOCATION-SPECIFIC ARARS

SULLIVAN'S LEDGE SITE

MASSACHUSETTS STATE REQUIREHENTS (Continued)

Does this Apply?

REQUIREMENT YES NO COHtfENTS

3. DEQE - WETLANDS PROTECTION (310 CHR 10.00) X Will be considered for alternatives which affect wetlands.

4. D.F.W. - ENDANGERED WILDLIFE AND WILD PLANTS (321 CHR 1.00 - 9.00) X Threatened or endangered species are not present at the site.

5. STATE REGISTER OF HISTORIC PLACES X Not applicable.

6. MASSACHUSETTS FIRE PREVENTION REGULATIONS (527 CtfR 9.00 - TANKS) X Not applicable.

FEDERAL CRITERIA, ADVISORIES, AND GUIDANCE (FCAG)

Do these FCAGs Apply?

FCAG YES NO COHHENTS

1. FWS, NWFS ADVISORIES (UNDER FISH AND WILDLIFE COORDINATION ACT) X Requirements addressed in CWA Section 404.

2. FLOODPLAINS EXICtrrlVE ORDER (11988) X Requirements addressed in CWA Section 404.

3. WETLANDS EXICtrrlVE ORDER (11990) Applicable for alternatives that will affect wetlands.

4. FEDERAL SOLE-SOURCE AQUIFER REQUIREMENTS X Not applicable.

5. EPA OFFICE OF WATER-WASTELOAD ALLOCATION PROCEDURES X Not applicable.

EPA OFFICE OF WATER GUIDANCE TECHNICAL SUPPORT HANUAL:

WATER BODY SURVEYS AND ASSESSHENTS FOR CONDUCTING USE

ATTAINABILITY ANALYSES X Not applicable.

6.87.157 0005.0.0

--------

TABLE 3-3

POTENTIAL ACTION-SPECIFIC ARARS

SULLIVAN'S LEDGE SITE

FEDERAL REQUIREMENTS

Could this Apply?

REQUIREMENT YES NO

1. RCRA - STANDARDS FOR OWNERS AND OPERATORS OF PERMITTED HAZARDOUS WASTE

FACILITIES (40 CFR 264.10 - 264.18) X

2. RCRA - PREPAREDNESS AND PREVENTION (40 CFR 264. 30 - 264. 3 7) x

3. RCRA ~ CONTINGENCY PLAN AND EMERGENCY PROCEDURES (40 CFR 264.50 - 264.56) X

4. RCRA - MANIFESTING, RECORD KEEPING, AND REPORTING (40 CFR 264.70 - 264.77) X

5. RCRA - GROUNDWATER PROTECTION (40 CFR 264.90 - 264.109) X

..•

6. RCRA - CLOSURE AND POST-CLOSURE (40 CFR 264.110 - 264.120) X

7. RCRA - SURFACE IMPOUNDMENTS (40 CFR 264.220 - 264.249) X

8. RCRA - WASTE PILES (40 CFR 264.250 - 264.269) X

9. RCRA - LAND TREATMENT (40 CFR 264.270 - 264.299) X

10. RCRA - LANDFILLS (40 CFR 264.300 - 264.339) X

11. RCRA - INCINERATORS (40 CFR 264.340 - 264.999) X

12. CWA - 40 CFR PARTS 122, 125, 403, and 404 X

13. TSCA - HANUFACTURING, PROCESSING, DISTRIBUTION IN COl1HERCE, USE OF X

PCBs AND PCB ITEHS (40 CFR 761.60 - 761.79)

14. TSCA - HARICINGS OF PCBs AND PCB ITEMS (40 CFR 761.40 - 761.79) X

15. TSCA - STORAGE AND DISPOSAL (40 CFR 761.60 - 761.79) X

16. TSCA - RECORDS AND REPORTS (40 CFR 761.180 - 761.185, X

ALSO 40 CFR 129.105, 750)

COHMENTS

Applicable RCRA Requirements will be considered during the evaluation of remedial alternatives.

Applicable to site closure.

Relevant and appropriate.

Not applicable.

Not applicable.

Relevant and appropriate.

Not applicable.

Applicable for remedial alternatives which

include discharges to surface Wdter.

Not applicable.

TSCA requirements will be considered during evaluation of soil remedial actions.

Governs responses to soil contaminated with PCBs at 50 ppm or greater. Consider during evaluation of remedial alterndtives.

6.87 .157

0006.0.0

TABLE 3-3 (cont.) POTENTIAL ACTION-SPECIFIC ARARS

SULLIVAN'S LEDGE SITE

FEDERAL REQUIREMENTS

Could this Apply?

REQUIREMENT YES NO COttHENTS

17. CAA NATIONAL AMBIENT AIR QUALITY STANDARDS FOR REPIRABLE PARTICULATES(PH-10) X Will be considered for soil removal (40 CFR 129.105, 750)

18. OSHA - GENERAL INDUSTRY STANDARDS (29 CFR PART 1910)

19. OSHA - SAFETY AND HEALTH STANDARDS FOR FEDERAL SERVICE CONTRACTS (29 CFR PART 1926)

20. OSHA - RECORDKEEPING, REPORTING, AND RELATED REGULATIONS

21. OSHA - TOXIC SUBSTANCE STANDARDS

22. DOT RULES FOR THE TRANSPORTATION OF HAZARDOUS MATERIALS (49 CFR PARTS 107, 171.1 - 171.500)

23. RIVERS AND HARBORS ACT (33 CFR PARTS 320-329)

24. GUIDELINES FOR SPECIFICATIONS OF DISPOSAL SITES FOR DREDGED OR FILL MATERIAL (40 CFR 230)

25. DENIAL OR RESTRICTION OF DISPOSAL SITES (40 CFR 231)

26. OCEAN DUMPING REGULATIONS (40 CFR 220-229)

27. DISPOSAL OF WASTE MATERIAL CONTAINING TCDD (40 CRF 775.180 - 775.197)

options.

X OSHA requirements 18-20 will be considered during implementation of remedial alternatives.

X

X

X

Will be considered during evaluation X of remedial alternatives requiring

transportation of hazardous materials.

X Not applicable.

X Will be considerd during evaluation of alternatives affecting Middle Harsh area.

X Not applicable.

X Not applicable.

X Not applicable.

MASSACHUSETTS REQUIREMENTS

Could this Apply?

___________RE~Q_UI_RE_ME_N_T___________________YE'--"-'-S___NO______________co_tn-lENTS______

1. DEPARTMENT OF ENVIRONMENTAL MANAGEMENT (302 CHR 2.00 - 6.00) X Not applicable.

2. DEQE - HAZARDOUS WASTE MANAGEMENT RECORDS AND FILES CONFIDENTIALITY X Not applicable. (310 CMR 1.00 - 5.00)

Will be considered when evaluating

3. DEQE - AIR QUALITY, AIR POLLUTION (310 CMR 6.00 - 8.00) X alternatives ~equiring soil removal.

6.87.157 0007.0.0

TABLE 3-3 (coot.) POTENTIAL ACTION-SPECIFIC ARARS

SULLIVAN'S LEDGE SITE

MASSACHUSETTS REQUIREMENTS

Could this Apply?

REQUIREMENT YES NO

4. DEQE - ADtfINISTRATION or WATERWAY LICENSES (310 CHR 9.00) X

5. DEQE - INSTALLATION, OPERATION AND MAINTENANCE OF SOLID WASTE TRANSFER STATIONS; DISPOSAL OF SOLID WASTE BY SANITARY LANDFILL; OPERATION OF PLANTS FOR TIIE PURIFICATION OF SHELLFISH; STATE PIERS X

6. DEQE - HAZARDOUS WASTE, PHASE I AND II (310 CHR 30.00) X

7. HAZARDOUS WASTE FACILITY SITE SAFETY COUNCIL (990 CHR 1.00 - 16.00) ...!._

8. DEQE WETLANDS PROTECTION (310 CHR 10.00) ~• X

9. HDWPC - SURFACE WATER DISCHARGE PERMITS; SURFACE WATER QUALITY STANDARDS; GROUNDWATER DISCHARGE PERMIT PROGRAH; GROUNDWATER QUALITY STANDARDS X

10. HDWPC - SUPPLEHENTAL REQUIREMENTS FOR HAZARDOUS WASTE MANAGEMENT FACILITIES; CERTIFICATION FOR DREDGING, DREDGED MATERIAL DISPOSAL, AND FILLING IN WATERS; GRANTS FOR CONSTRUCTION OF COLLECTION SYSTEHS; GRANTS FOR CONSTRUCTION OF WASTEWATER TREATMENT FACILITIES; OPERATION AND MAINTENANCE AND PRETREATMENT STANDARDS FOR WASTEWATER TREATMENT WORKS AND INDIRECT DISCHARGES; RULES FOR THE PREVENTION AND CONTROL OF OIL POLLUTION IN THE WATERS OF TIIE COHHON\IEALTH; OPERATION AND MAINTENANCE STANDARDS FOR INDUSTRIAL AND HUNICIPAL WASTEWATER TREATMENT FACILITIES WHICH HANDLE HAZARDOUS WASTE (314 CHR 8.00 - 29.00) X

11. MASSACHUSETTS GENERAL LAW - CHAPTER 21E X

12. MASSACHUSETTS FIRE PREVENTION REGULATIONS (527 CHR 9.00 - TANKS) X

COHHENTS

Not applicable.

Not applicable.

Applicable to all remedial actions.

Appropriate for public ootificatiou procedures.

Will be considered for alternatives that

affect the Hiddle Harsh.

Applicable for remedial alternatives which include discharges to surface water.

Will be considered for alternatives that affect the Hiddle Harsh.

To be considered if real e&tate transaction is proposed for any of the remedial alternatives.

Not applicable.

6.87.157 0008.0.0

·rAIII.E l-1 (cunt. )

l'u'l"EN'flAL ACTION·SPt:ClflC AkARS

SULLIVAN'S LEDGE SUE

£1:'.DEIIAL CIIITERIA, ADVISORIES, AND GUIDANCli (fCAG)

CoulJ tlu:111: fCAG:1 Ap11ly?

l!QUIREtlENT --------~vt:S NO -----------________ Clltlttl:NTS

I. EPA' S GROUNO"ATEI PROTECTlotl STRA'fEGY X

2. TSCA CONPLIANCE POLICY X

]. IIASTI LOAD ALLOCATIOII PROCEDURES (EPA OFFICE o•· "A'fER) Nut "llllli&:.al>lc.

U.S. EPA ICRA DESIGN GUIDELINES

A. IPA'S lCRA OESIGII GUIDELINES .... I, SlafACI IHPOUNIININTS, LINER SYST£HS, FINAL COVER AHO fR£EB0All0 CONTROL _!__ Tlluc RCk., Jui1111 1uiJcl1111::i wtll l>c

cuu:iiJcccJ it lbc~e type~ uf (4•ilil1~~ 2. VASTI PILI D£S1GII - LINER SYSTEHS X will l>c cutt~lauclcJ.

). LAND TltATHENT UNITS X

4. LAHOHLL DESIGN - LINU SYSUtlS AND FINAL COVER X

I. PERHITIING GUIDANCE lt.UIUALS

I, l'ERNIT APPLICANTS' GUIDANCE tt,NUAL fOR HA2AN0u1JS IJAS'f£ !AND TR£ATt1£NT, STOIIAGE AHO DISPOSAL FACILITIES X 'l'lu::ic pc 11111 l II" i JJttcc 111.11111,1 I :1 J • c nul

Jic~ctly Jj'j'licJLlc ~IIILC 2. PERtllT WRITERS' GUIDANCE HANUAL FON HAZARUOUS \I.\S'ft: I.AND TR£ATtlENT, pt:1Mil» nccJ uui ~" ~ccurcJ lur

STOllAGE AND DISPOSAL FACILITIES !C ou-~ilo: 1110111luri115. 'l'lu: ,unlcul~ ur the S11L11.a1 l t· a.;.,1,l.au.:c tl.auuJI "111 Le

). PERnlT WHITENS' GUIDANCE ttAHUAL FON SUIIPAkT f X ccvicwcJ Ju.-i11a1 llu: ,lcvcluv111c11t ul JIIY l'•"l'"~"J 11•uu11,l-.•lc.- >11u11ilu, 1ua1 proa11.1 ...

4. PERNIT APPLICANTS' GUIDANCE ttANUAL fOR Gt:NER.-'L BCll.l'fY SHNllAkDS X

S. IIASl'E ANALYSIS Pl.AN GUIDANCE HANUAL X

6. P£kt11T WRITERS' GUIDANCE tL\NUAL fOk 11.\ZAHIIOUS IIASlt:: l'.\NKS X

l. l100£L PEIUll'r Al'l'LICATION FON t:XISTINli INCINEIIA'fO~S

8. GUIPAHCt:: tlANUAL FOR EVALUATING PEkttlT APl'I.ICA'flONS lON TIit: OPERATlON

Of 11.\ZAROOUS \IASH: I NC INl:'.HA'ruk UN ns X

!I. A GUIDE .-OH PIU:l'ARING RCIU l'Ektll'C Al'l'Llt:.HIONS .-Uk EXl:i'l'INli :i'l'l>ltALE

FACILITIES

6. 81.1'>7 Olltl'J.O 0

http:S11L11.a1

-------

TABLE 3-3 (cont.)

POTENTIAL ACTION-SPECIFIC ARARS

SULLIVAN'S LEDGE SITE

FEDERAL CRITERIA, ADVISORIES, AND GUIDANCE (FCAG)

Could these FCAGs Apply?

GUIDELINE YES NO COMMENTS

10. GUIDANCE MANUAL ON CLOSURE AND POST-CLOSURE INTERIM STATUS STANDARDS X Relevant to capping.

C. TECHNICAL RESOURCE DOCUMENTS

1. EVALUATING COVER SYSTEMS FOR SOLID AND HAZARDOUS WASTE X Technical resource documents

Cl - C7 are not considered directly

2. HYDROLOGIC SIMULATION OF SOLID WASTE DISPOSAL SITES X applicable; however, their content may be relevant and appropriate and used as guidance for some alternatives.

3. LANDFILL AND SURFACE IMPOUNDMENT PERFORMANCE EVALUATION X -· 4. LINING OF WATER IMPOUNDMENTS AND DISPOSAL FACILITIES X 5. TEST METHODS FOR EVALUATING SOLID WASTES X

6. A METHOD FOR DETERMINING THE COMPATIBILITY OF HAZARDOUS WASTES X

7. GUIDANCE MANUAL ON HAZARDOUS WASTE COMPATIBILITY X

EPA OFFICE OF WATER GUIDANCE DOCUMENTS

A. PRETREATMENT GUIDANCE DOCUMENTS

1. 304(G) GUIDANCE DOCUMENT REVISED PRETREATMENT GUIDELINES X Not applicable.

B. NPDES GUIDANCE DOCUMENTS

1. NPDES BEST MANAGEMENT PRACTICES GUIDANCE MANUAL (6/81) X Not applicable.

2. CASE STUDIES ON TOXICITY REDUCTION EVALUATION (5/83) X Not applicable.

C. GROUNDWATER/UIC GUIDANCE DOCUMENT X This will be considered during remedial design.

USEPA MANUALS FROM THE OFFICE OF RESEARCH AND DEVELOPMENT

1. EW 846 METHODS - LABORATORY ANALYTICAL METHODS X Lab methods and protocols shall be

followed during chemical anJlysis.

2. LAB PROTOCOLS DEVELOPED PURSUANT TO CLEAN WATER ACT §304(h) X

6.87 .157 0010.0.0

------------------------------------ ----------

TABLE l-l (Co"t.)

l'OH:N'flAL AC'flON-St'ECIHC AHAHS

SULLIVAH'S I.EDGE SIU

ttASSACIIUSET'fS AND LOCAL CII ITEII I A, ADV I SON I ES, ANO tiU !DANCE ( tU.CAti)

Co~IJ lhc:i;c: HLCAGa Al'l'I y·t

YES NO ______ COtltlt:N'fS ____ ·----- ______

I. LOCAL OR01NAHC£S, REGULATIONS, AND WAS'fEWATEII Tll£ATl1£NT WOHi R£QUlll£HENTS l>c:c:J cc:i;te1.:t1011:., c:lc. to tu, c:vJluJlc:J Jur11111

cc-•h•l Jc:.i1111

-·

6.111 . •~, 0011.0.0

characterization, and to support engineering treatability studies. These data are both qualitative and quantitative.

Level IV - CLP-RAS. This quality level represents confirmational data characterized by rigorous quality control and validation procedures. This level is adequate for site characterization to support risk assessment, enforcement, engineering alternative selection, and design, and for cost recovery documentation. Level IV data may be both qualitative and quantitative.

Specifics regarding QA/QC, costs, validation, and uses of each data level are described in EPA Office of Emergency and Remedial Response and Office of Waste Program Enforcement Draft Guidance (Data Quality Ob-jectives for the RI/FS Process; March 25. 1986). DQOs for the Sullivan's Ledge site are outlined in Section 3.3.2.

3.3 OBJECTIVES AND SCOPING OF THE PHASE II REMEDIAL INVESTIGATION

3.3.1 Objectives of the Phase II RI

The objectives of the Phase II RI are:

1) to define the vertical distribution of organic contamination in the deep groundwater adjacent to the quarry pits;

2) to obtain site-specific biota data needed to evaluate the environmental risk created by the site contamination;

3) to develop site cleanup standards; and

4) to secure additional environmental data needed for the evaluation of remedial alternatives.

The first objective concerns contamination in the bedrock groundwater adjacent to the quarry pits. The Phase I RI indicates that VOC contamination increased significantly with depth. This observation will be checked by drilling two 300-foot deep bedrock wells on the site and two 300-foot bedrock wells off-site on the golf course. The objective of these wells is to determine the vertical distribution of organic contamination at the site and to determine potential migration pathways off-site in the golf course area.

The second and third objectives concern the lack of a site-specific biota investigation for the unnamed stream, Middle Marsh area, and Apponagansett Swamp. Based on available information, it is difficult to determine what organisms exist

-57

in these environments and how they are being impacted by site contaminants. This information is necessary for evaluating the environmental risks posed by the site amd developing site cleanup standards.

Last, additional environmental data are needed for several site media to evaluate remedial alternatives. The information needed is as follows:

• Additional soil data are needed from the eastern edge of the site near TP-2. TP-2 was a hot spot for PCBs, lead, and VOCs, and is the only test pit in this location. Additional information is needed to determine the aerial extent of these contaminants.

• Additional information concerning soil properties is required to determine the effectiveness of source control alternatives, such as capping, solidification, and in situ biodegradation.

• Additional PCB sediment data are needed for stations both upstream of the site, within the Middle Marsh, and in the Apponagansett Swamp. Data for the upstream stations will be needed in determining site-specific background PCB levels. The PCB data from Middle Marsh will be used to further estimate the aerial extent of contamination and the volume of contaminated sediment. The Apponagansett Swamp samples will be used to determine if PCBs from the Sullivan's Ledge site have reached the Apponagansett Swamp.

3.3.2 Scope of the Phase II Field Investigation

To fulfill the objectives of the Phase II RI, a field investigation program has been developed. The scope of this program is outlined in this section, while Section 4.3 of this Work Plan and the FSAP discuss the specifics for each component.

3.3.2.1 Initial Activities

Initial activities for the Sullivan's Ledge site include mobilization, a receptor search, water level measurements, and road maintenance.

3.3.2.2 Bedrock Drilling Program

It is anticipated that four deep (approximately 300-foot) bedrock wells will be installed at, and north of, the site. These wells will help determine if contamination is present within the deep bedrock groundwater (100-300') and if it is present, is it increasing with depth.

-58

All groundwater analysis will be for HSL organic and inorganic parameters. Level IV data analysis will be required for volatile and semivolatile HSL parameters and HSL metals. In addition, several samples will be analyzed for oil and grease, total suspended solids, total dissolved solids, biochemical oxygen demand (BOD), and chemical oxygen demand (COD). This information will be used to evaluate the effectivene