COMMONWEALTH OF MASSACHUSETTSEXECUTIVE OFFICE OF ENVIRONMENTAL AFFAIRSDEPARTMENT OF ENVIRONMENTAL PROTECTIONONE WINTER STREET, BOSTON, MA 02108 617-292-5500

ARGEO PAUL CELLUCCIGovernor

JANE SWIFTLieutenant Governor

February 19, 1999

Paul CraffeyRemedial Project ManagerUS EPAJFK Federal Building (HBO)Boston, MA 02203

SUPERFUND RECORDS CTR

, Cher

BOB DURANDSecretary

DAVID B. STRUHS-Commissioner

Subject:

Dear Paul:

EPA Proposed Plan for Remedial Action, Atlas Tack Superfund Site;Fairhaven, Massachusetts; December 1998

The Bureau of Waste Site Cleanup (BWSC) reviewed the Proposed Plan for remedial actions atthe Atlas Tack Site dated December 1998, as well as the Draft Final Feasibility Study dated July1998. We also attended the Public Meeting on December 1, 1998 and the Public InformationSession on January 27, 1999. Comments on the Feasibility Study have previously beensubmitted to EPA. This letter provides BWSC's comments on the Proposed Plan based on ourreview of the Plan, the Feasibility Study, other pertinent documents and public comment.

It is the opinion of this office that the proposed remedy as described in the above documentsshould not be the selected remedy in the Record of Decision (ROD). This conclusion is reacheddue to the overwhelming public opposition to the proposal and the apparent availability of otherfeasible and more acceptable options. We recommend that EPA reconsider the way that thewaste and the contaminated soil is to be sorted and characterized at the site, and select analternative that incorporates off-site disposal to a much greater extent. The on-sitesolidification should be conducted only when it is required by the off-site disposal facility. TheROD should, however, include a contingency for on-site disposal in the event that an off sitefacility willing to accept the waste can not be identified or the cost of off-site disposal becomesprohibitive. We believe this approach, although somewhat higher in cost, is preferable forseveral reasons, including community acceptance and a reduction in long term operation,monitoring and maintenance requirements.

Below are more specific comments on the Proposed Plan. We understand that some of thecomments can only be addressed during the remedial design process. However, since desigrissues directly impact the remedy selection, they are raised here for EPA to consider in draftingthe ROD.

This information is available in alternate format by calling our ADA Coordinator at (617) 574-6872.

DEP on the World Wide Web http //www magnet state ma us/dep£J Printed on Recycled Paper

1. The accuracy of calculations pertaining to waste volumes and the consistency of waste characterization and sorting between the various alternatives are issues that were raised in our comments on the Feasibility Study. Because cost is a significant factor in EPA's decision to recommend on-site versus off-site disposal, it is important that the estimates of cost be as accurate as possible. Also, the sorting and characterization of waste, as presently proposed, may not lead to the selection of the most cost effective alternative. For example, much of the excavated soil may be above the cleanup standards for the site but be below the contaminant levels for soil reuse at landfills. A clearer decision flow chart for determining which wastes will be taken off site without solidification, which wastes will be solidified and left on site, and which will be solidified and taken off site should be developed early in the design process.

2. Neither the Feasibility Study nor the Proposed Plan present the treatment standards for the solidification technology. Also, the descriptions of the waste sorting and characterization processes in the Feasibility Study do mention contaminant levels which may or may not be acceptable at the various potential disposal facilities. The planning for the disposal of wastes and soils should begin with a clear understanding of the contamination levels acceptable for disposal at various off-site facilities as well as for on-site disposal.

3. The plan for the bioavailability studies should include clear criteria for decisions on whether marsh sediment should remain in place or should be excavated. The cost estimates for the competing alternatives should include a cost range, considering no marsh remediation to full remediation.

4. It is not possible to determine the costs of O&M for each combined alternative from the Feasibility Study. These costs are likewise not shown in the Proposed Plan. Since the Commonwealth may be responsible for the O&M, it is necessary to have these costs presented along with the proposed O&M requirements in order to compare alternatives.

5. The disposal area orientation for the preferred alternative shown in the Proposed Plan has been changed from that presented in the Feasibility Study. The disposal area now covers a portion of the commercial area, however, it still overlaps an area defined as a wetland in the Remedial Investigation. The disposal of the solidified waste in this area would not be compatible with wetland restoration plans at this site and may be in violation of ARARs. Also, the staging areas for the solidification technology are not identified and it is not clear if the 100 feet buffer zone requirements will be complied with or if a waiver would be necessary. If the area for the disposal of the solidified waste is reduced not to overlap the wetland, a presentation of both the height and depth of the solidified waste pile in the ROD should be provided.

6. It appears from the diagrams in the Remedial Investigation and the Feasibility Study that at least part of the proposed disposal area is at or near the groundwater table. We believe the solidified material should be located in an area that is safely above the annual high water table.

7. Neither the Feasibility Study nor the Proposed Plan clearly defines how the high concentrations of organics (221 ppm) found in the groundwater at one location will be addressed. Through discussions with EPA it is our understanding that EPA anticipates that the soil excavation will be sufficient to address this issue. We recommend that this be more clearly explained, and that additional provisions be specified in the ROD to address remaining LNAPL that is not removed as a result of soil excavation. LNAPL should not be left in place. In addition, during the design and construction phases, EPA should consider the benefit and feasibility of removing highly concentrated and localized areas of groundwater contamination.

8. The cleanup levels presented in the Proposed Plan and the Feasibility Study do not address the 0 to 2 feet of soil outside the building in the commercial area. It is not clear if the existing contamination outside the building meets the cleanup levels for the site or if the Remedial Investigation soil data did not trigger the risk assessment for this area. In either case, since this surface soil will be excavated to reach the soils below 2 feet, it should be clear where on the site it will be placed and if it will meet the cleanup levels for that location. Also, some of the cleanup levels presented in the Proposed Plan are not the same as those presented in the Feasibility Study. The PCB levels, for example, change from 0.87 ppm in the Study to 10 ppm in the Plan. In those cases where discrepancies exist an explanation would be helpful.

Also, enclosed with the above comments is a copy of the BWSC's November 2, 1998 letter on the Feasibility Study. The BWSC would appreciate these comments being addressed before the issuance of the ROD. Finally, the BWSC would like EPA to identify in the ROD those areas of contamination which are not going to be included in the remedial action, for example wastes or areas potentially contaminated with petroleum.

We appreciate the opportunity for review of the Proposed Plan and look forward to working with EPA during the cleanup of the site. If you have any questions please feel free to call Dorothy Allen at 617-292-5795.

Sincerely,

aparstek, Chief ral Superfund Section

Division of Response and Remediation

Cc: Millie Garcia-Surette, SERO Robert T. Hamilton, Chairman, Board of Selectman

enclosure

COMMONWEALTH OF MASSACHUSETTS EXECUTIVE OFFICE OF E^wmc•NMENTAL AFFAIRS

.DEPARTMENT OF ENVIRONMENTAL PROTECTION ONE W1NTEK. STREET, BOSTON, MA 02108 617-292-5500

ARGEOPAOLCELLUCa Governor T&UDYCQXE

DAVID B.STKDHS

November 2, 1998

Paul Craffey Remedial Project Manager

JFK Federal Building (HBO) Boston, MA 02203

Subject Atlas Tack Superfund Site, Fairhaven, Massachusetts Draft Final Feasibility Study, July 1998 (FS)

Dear Paul:

The Bureau of Waste Site Cleanup (B WSC) reviewed the above document by the Army Corps of Engineers. The BWSC is submitting the following attached comments that address the main issues pertaining to the FS. The BWSC recognizes that while no changes to the FS can be made, EPA should consider these observations while drafting the Proposed Plan and to the extent possible should address them hi the Record of Decision (ROD) for the above Site. Some of the comments may pertain to Remedial Design issues, however, since such issues were explored in the FS the BWSC's comments pertaining to them should be at least qualitatively addressed in the Propsed Plan or the ROD.

As a general observation, the FS determines volumes of contaminated soils for different Site locations. The costs for aU remedial alternatives are based on these volume estimates. The volume estimates are a result of assumptions about results of laboratory analyses for the contaminated soil samples. In several instances the BWSC found problems with the assumptions, inconsistencies in how the assumptions were applied and errors hi how the costs were calculated. The BWSC recommends that the volume estimates and costs be thoroughly checked prior to the issuance of the Proposed Plan and the ROD. Also, sensitivity analysis may show clearly the degree to which the costs for each remedial alternative may vary depending on the outcomes of the recommended analytical protocols.

This information is svaflabte in alternate format by calling oar AD Coordinator *t (617) 574-6872.

DEEP on ttieWofW Wide Wetr. rOV/vwjTiagnetstateJTKLUsftiep ^S Printed on Recycled Paper

We appreciate the opportunity for review of the FS and look forward to working with EPA during the clean-up of the Site. If you have any questions please feel free to call Dorothy Allen at 617-292-5795.

Sincerely,

Jay Naparstek Section Chief Response and Remediation

enclosure

Attachment

1. A careful review of Remedial Process Flow Sheets for Commercial Area and Solid Waste Disposal Area (Figures 5-2, 5-3,5-5, 5-7, 5-8) indicates that the volumes of contaminated material to be disposed in solid waste landfills, RCRA disposal facilities, RCRA treatment facilities, and PCB disposal facilities are based on assumptions that are not defined in the FS. To determine the volumes for each disposal location the FS presumes outcomes of laboratory analyses. For example, in Figure 5-7, all contaminated soil found in the SWD area is presumed to pass a Toluene Test, while the presence of toluene as an LNAPL is also documented for SWD. From the Figure it appears that presence of toluene precludes the use of the treatment technology and would, therefore, raise the cost of this alternative. Also there appear to be inconsistencies in the way that the presumptions are applied to different alternatives. For example, in Figure 5-8, the contaminated soil appears to have a 70% failure rate for cyanide, metals, pest/PCB and toluene tests. In Figure 5-7, the same soil appears to be either not tested for the above parameters or appears not to fail.

The BWSC recommends that a sensitivity analysis be performed with respect to those assumptions that are most likely to make large differences in volumes, costs and, therefore, in remedy selection. The sensitivity analysis will also allow the cost differences among alternatives to be viewed with appropriate level of skepticism. This can be easily done prior to the issuance of the Proposed Plan or the ROD.

2. During the examination of the above Figures and the corresponding cost calculations • presented in Tables 5-5,5-7,5-9, 5-11, 5-13 several errors were found that effect the final costs for SWD-4 remedial alternative (see below). It is important that the these Figures and Tables be more thoroughly evaluated and corrected prior to the issuance of the Proposed Plan and the ROD. The errors found by BWSC may not be the only mistakes and the Figures and Tables should be checked for previously undetected errors.

The Remedial Process Flow Sheet for Alternative SWD-4, Figure 5-7, indicates that 17,050 cy will be treated from the CED and the Fill Areas and 4,200 cy will be treated from the Lagoon Area. The corresponding cost Table 5-11, however, lists only the 17,050 cy volume. If the 4,200 cy volume is considered, the cost for SWD-4 rises by 0.348 million, from 10.211 to 10.559 million. Another troubling assumption is that, out of 24,250 cy of the untreated waste from the CID and Fill Areas, 7,200 cy will pass a CN Metals Leach Test (apparently the same test that will be performed on the treated waste). If this assumption is wrong, the additional cost would be 0.596 million due to treatment and 0.51 million due to the assumption that approximately 10% of this volume will go to RCRA disposal facility. The SWD-4 alternative cost rises to 11.625 million.

3. The Cost Tables referenced hi Section 5 of the FS and used hi evaluating the CA, SWD, and MSS remedial alternatives in a number of instances repeat costs for the same activities. For example, demolition costs and asbestos removal costs are considered for CA, SWD, and MSS.

While it is difficult to understand why demolition and asbestos removal would be a cost for the remediation of the Marsh Area, it is even more difficult to know which costs can be added when a combination of alternatives is considered for the entire site. The BWSC recommends that the Cost Tables be redone for the purposes of the Proposed Plan and ROD to clearly show that individual activity costs are not double or even triple counted.

4. In the FS complicated plans for handling contaminated soil, involving excavation, sorting, grinding, decontamination, screening, sampling, field and laboratory analyses, can only be inferred from the Remedial Process Flow Sheets and Cost Tables. The costs for the analyses alone are not insignificant. For example, analytical costs associated with Table 5-11 items 17, 18, and 19 for S WD-4 alternative are 0.73 million of the 10.211 million remedy. The Remedial Design should clearly explain the on-site waste handling plan and the field and laboratory sampling and analyses plan for the chosen remedial alternative. With the information supplied hi the FS it is difficult to determine the adequacy of the plans or to check the accuracy of the cost calculations pertaining to them.

5. The FS mentions the need for performing a treatability study for the on-site waste treatment alternatives. There is no discussion in the FS pertaining to the content of this study. While the Remedial Design may address the details of the study in terms of the different methods of treatment, the performance criteria of the treatment, and the tests used to evaluate the performance criteria, the FS should at least describe the scale of the anticipated investigation. The treatability study is particularly important in this case since the waste will be placed in part below the unsaturated zone of the aquifer. The BWSC encourages a thorough investigation into the longevity of the solidified waste under conditions of prolonged exposure to water. Finally, the cost of this study should be estimated and considered together with other implementation costs for each on-site treatment alternative.

6. Figure 5-6 presents the Conceptual Landfill Plan for Alternative SWD-4. It is not clear from the FS why this spatial orientation for the disposal area was chosen. It places virtually all the treated waste hi an area that was previously (before disposal began and contamination ensued) undeveloped. Also approximately half of the treated waste will be located within the wetland boundary as presented hi Figure 3-13 of the Remedial Investigation Report, Atlas Tack Corporation dated May 5,1995, (RI). Finnally, this orientation assures that the treated waste is, at least hi part, below the saturated zone and subject to tidal fluctuations. From the perspective of reclaiming the wetland area and assuring that the treated waste is placed above the saturated zone the'disposal area orientation should be as that presented in Figure 5-4, Conceptual Landfill Plan for Alternative SWD-3. EPA should consider extending the limits of Atlas Tack building demolition to accommodate any necessary staging areas or to move the disposal area even farther upland.

7. The FS presents remedial alternatives for marsh surface soils. The volume of these soils is 14,000 cy, excluding 700 cy of marsh vegetation. The costs of the remedial alternatives are high, 3.328 million for MSS-3, 5.004 million for MSS-4 and 8.12 million for MSS-6. The need for these remedial actions does not appear to be supported by an adequate soil characterization. The RI indicates that only three soil samples were taken and analyzed hi the Marsh Area, close to the CID boundary. The FS Sections 1.2.5.3, 2.3.3, which should pertain to the Marsh Area, are

descriptions of risk assessments pertaining to the Boys Creek sediments. While the FS does state that a bioavailability study for the area is needed, the Proposed Plan and the ROD should be explicit hi stating that the need for the design and implementation of the chosen remedial alternative for this area is contingent on further soil characterization.

8. The FS does not address the localized contamination of ground-water by organics that is presented in the RI, Figure 4-9. The levels of toluene in MW-5 were 220,000 ug/1, well hi excess of 50,000 ug/1 GW-3 groundwater standard. In evaluating the groundwater treatment alternatives the FS does not include an option of performing a partial groundwater remedy. The BWSC recommends a cleanup of any hot spot which may act as a source of contamination to the groundwater. The relatively small volume of wastewater can be either shipped off-site or can be treated for the target contaminants only. If the hot spot contamination is in a form of LNAPL and is expected to be addressed during the soil remediation then the Proposed Plan and the ROD should make this clear and state it explicitly. Finally, the results of a mass balance may show that the remediated marsh surface soils will not become re-contaminated (if remediated) or that exisiting soil will not exceed cleanup levels (if not remediated) under the no action alternative for groundwater.

9. During the Remedial Design additional wetland mitigation, restoration and monitoring options should be explored for the remediated marsh areas. Excavated areas should have detailed mitigation, restoration and monitoring plans prepared with DEP staff involved in design review. Some of the present recommendations include: taking of additional soil cores to better determine extent of hydric soils, reseeding of hard shell clam beds, increasing culvert size through the hurricane barrier, examining the use of filter fabric, sand or military sheet metal tracks for temporary roads during remediation.