flbull =I ~~r~ ~~ ifampwitvJnmuztol~ ~PI~~ ~PI 11lldb Jite-~

Oilniel S Creenb~oum ~J-mwJua ~~aRIOrfCommiUiontr

J~omes C Colman AWJUnrcomm-

Robert Leqer U S EPA HRS-CAN2 Boston MA April 18 1991

Dear Bob

Enclosed are the State bull s collllents to the oratt Feasibility Study tor the Groveland Wells Site Groundwater Operable Unit They include the list of ARARa relevant to this Operable Unit comaents to sections of the report body and also to the appendices

C) It you havo any colllllonts or questions you can roach mo at 292-5903

(itAo kiit Charles Tuttle Geoloqist Bureau ot Waste Site Cleanup Boston

cc Jay Neparstek BWSC Boa-con Groveland Wells tile

0

Maaaacbuaetta AJIAlla tor the Groveland Walla Operable Unit 2

310 CMR 1000 wetlands Protection Act Location specific

310 CMR 2200 Drinking Water Regulations Chemical Specific

310 CIIR 3000 Hazardous Waste Requl~tions Action Specific

310 CMR 600 Ambient Air Quality standards Chemical Specific

310 CMR 7 00 Air Pollution Control Regulations Action Specific sfl

310 CMR 4000 Massachusetts Continqency Plan Chemical specific

314 CMR 3 00 Surface Water Oischarqe Permit ~iProgram Action specific

314 CMR 4 00 Surface Water Quality Standards Chemical specific ~-314 CMR 5 00 Groundwater Oiacbarqe Permit ~~

Prcgraa Action Specific

314 CIIR 600 Groundwater Quality standards Chemical Specific

314 CIIR 7 00 Sewer System Extension and ~ Connection Perait Proqru Action Specific

314 CIIR a oo

314 CMR 1200 Operation and Maintenance and Pretreatment for Waetewater Treatment works and Indirect Diacharqea Action Specific

302 CMR 300 Scenic and Recreational Rivers Location Specific

302 CIIR 600 Inland Wetland Regulations Location Specific

454 CMR 2100 worker Right to Know Action Specific

105 CMR 6700 Riqht to Know Action Specific

Allowable Air Levels To Be Considered Chemical Specific

Page 1-11 - paragraph 1 The risk downqradient of the Haverhill Landfill is listed as

1x10-6 and arsenic is also identified in the groundwater at the landfill at 400 ppm which is in the risk range of 1X10-3

Page 2-4 - paragraph 1 It a~rd ougtient gt 1 is selected tor each i ndividual

compound aitCan the Tgtpl Combined Hazprd rndex be lass than 1 as stated is page

Tabla 2-4 The Massachusetts drinking water standard tor 11shy

dichloroethane is 5 ugjl which corresponds to a 10-5 risk It appears the cleanup number in the FS (3500 uqjl) does not taka into account that this compound is a carcinogen

Tabla 2-5 Mass drinking water standards are

chromium - SOug1 selenium - 10ugjl silver - 50ugjl

Page 4-3 - paraqraph 2 It needs to be noted that the Mill Pond discharge is in

compliance with the KPDES permit issUed jointly by the State and EPA specifically tor the purpose it is beinq used

Page 4-3 - under Effectiveness ot Institutional Controlsbull Deed restrictions have not proven to be vary ettactiva and

are difficult to enforce This should be made clear

Under Impleaentability deed restrictions to prevent private well usa is not easily implementable The State does not have the authority to do this and the Town would have to adopt new byshylaws

Page 4-4 - under Conclusionbullbull Deed restrictions are not a treatment technology

Page 4-14 - laat paraqraph Air strippinq will require emission controls

Page 4-17 and 4-18 A batter description ot the UVJOxidation technology should be

provided to include such things as what it is how it works limitations experience and a comparative discussion on the different oxidants middot

Also a batter description on wet-air oxidation would be helpful

Paqe 4-18 - under Effectiveness The text says air oxidation is only appropriate tor iron

treatment and later in the same section it says that it can adequately handle the volume and contaminants at the site This should be clearer in what is meant here

In the text it states that the OM costs are low for air strippinq medium for carbon adsorption and hiqh for oxidation but the cost t iqures don 1 t show this

Also on this paqe (4-18) it states (under Implemantability)that wet-air oxidation requires no pretreatment Is this correct and will they still achieve discharqe requirements for inorqanicswith no pretreatment If this is the case is wet-air oxidation still more expensive than ozone

Paqe 4-21 In the treatment component list dewaterinq is missinq

Table 4-1 - under TreatmentPhysical It is unclear why reverse osmosis is listed as not

implemantable 11 The description says it is used to remove suspended solids but the footnote says it is not useable because ot the suspended solids present

Table 4-1 The dewaterinq options have bean lett out ie filter press

belt filter press and vacuum

Table 4-3 Where is the footnote explanation tor the double asterisk

Table 4-4 There are no units on this tabla so it is difficult to

understand

Table 4-5 Subsurface discharqe should be medium protectiveness not low

Deed restrictions should be medium implementability not hiqh

Volatilization should be medium OampM not low

Ch-ical treatmentoxidation should be medium OM not hiqh

Why is protectiveness tor all three of these medium

Paqe 5-5 - Alternative 1 No Action Doesnbullt the No Action alternative typically include

monitorinq

Paqe 5-6 - Paraqraph 1 last sentence The statement that vinyl chloride may pass throuqh the

carbon should be removed and replaced with somethinq like and may

require shut down ot the well andor may require additional treatment This occurs on several pages incluclinq 5-7 5-9 and 5-10 In addition vinyl chloride has never been detected in that area so is it appropriate to include this at all

Page 5-6 - Paraqraph 2 The discharqe at Mill Pond is in compliance ~ the NPDES

discharge permit issued j ointly by EPADEP and is 11 below the preliminary discharge standards tor TCE and 1 2-0 the major contaminants attributable to the site This should be stated This occurs several times throughout the document including page 5-7 5-9 5-10

Page S-7 - Paraqraph 4

middot There AJA steps being taken to actively restore the aquifer ie the Mill pond extraction system This paraqraph should be changed

Page 5-7 - Last Paraqraph Why is there a need for aciditional monitoring walls to monitor

Station 1 We believe the existinq monitorinq network is sufficient Same comment for paqes S-9 5-11 5-15 (2x) 5-16 s shy22 and 5-23

Paqe 5-9 - under Implementability of Institutional Controls The docwaent should nota that this would require the adoption

of local by-laws as well as a means to monitor and enforce them over the lonq term

Paqe 5-12 - under lliGaAl It should be asaued for cost purposes that the sludqe will

be claaaitied as hazardous

Paqe 5-12 - under Sbgrt Term Ettectiyeneaa Four to six months tram the siqninq ot the ROO see- too

optimiatic for qettinq Institutional Controls in place one year would seem mora likely

Paqe 5-13 - under Reductign of Toxicity Mgbility or yolwpt This treatment process also includes air oxidation which

appears to have been lett out

Paqt 5-17 and 5-19 OEP ARAR and EPA policy require air stripper emission control

Paqe 5-24 For the carbon adsorption option the use ot larqar carbon

units should be evaluated On site regeneration should also be evaluated

Paqa 5-28 - Last Paraqraph This alternative does not include air stripping (typo)

Page 5-30 The description ot UVOzone oxidation s hould be expanded to

include things like appropriate uses limitations actors to be considered experience different oxidants and their advantages and disadvantages ate

Table S-3 pages 2 and 3 Numbers 21 and 22 should ba checked as ARAR

If the particular action triggers Clean Air Act it should also trigger state Air Quality reqs - paqe 5 tables S-3 and 5-4

Why ian 1t the EPA 1 s Groundwater Protection Strateqy an ARAR or a To Be Considered for this Operable Unit

Table 5-6 page 5 3 Right To Know should be an ARAR 5 310 CMR 7 Air Pollution control Regulation is an ARAR 8 314 CMR 12 OampM and Pretreatment Standards tor Wastewater

Treatment Works and Indirect Discharges is an ARAR

For Alternative 4 should add the tollowinq Action Specific ARARs

310 CMR 400 - Surface Water Quality Standards To Be Considered (TBC) - Aabient Air Levels AALs)

For Alternative 5 should add the following Action Specific ARARs

3 Right To Know 5 310 CMR 7 Air Pollution Control Regulations 8 314 01R 12 310 C11R 4 00 To Be considered (TBC) - AALs

For Alternative 6 the same list as above are Action Specitic ARARs

Table 5-11 Paqe 5 Alternative 3 There is no 4estruotion ot contaminants in this alternative

or alternativas 4 or 5

Other general comments

Are there any restrictions on sludge disposal ie land disposal restrictions

If the Mill Pond system is to be included as part of the remedy then the cost tor upqradinq as necessary operating and maintaining the system should be included in the estimated cost ot the remedy

Maaaacbuaetta AJIAlla tor the Groveland Walla Operable Unit 2

310 CMR 1000 wetlands Protection Act Location specific

310 CMR 2200 Drinking Water Regulations Chemical Specific

310 CIIR 3000 Hazardous Waste Requl~tions Action Specific

310 CMR 600 Ambient Air Quality standards Chemical Specific

310 CMR 7 00 Air Pollution Control Regulations Action Specific sfl

310 CMR 4000 Massachusetts Continqency Plan Chemical specific

314 CMR 3 00 Surface Water Oischarqe Permit ~iProgram Action specific

314 CMR 4 00 Surface Water Quality Standards Chemical specific ~-314 CMR 5 00 Groundwater Oiacbarqe Permit ~~

Prcgraa Action Specific

314 CIIR 600 Groundwater Quality standards Chemical Specific

314 CIIR 7 00 Sewer System Extension and ~ Connection Perait Proqru Action Specific

314 CIIR a oo

314 CMR 1200 Operation and Maintenance and Pretreatment for Waetewater Treatment works and Indirect Diacharqea Action Specific

302 CMR 300 Scenic and Recreational Rivers Location Specific

302 CIIR 600 Inland Wetland Regulations Location Specific

454 CMR 2100 worker Right to Know Action Specific

105 CMR 6700 Riqht to Know Action Specific

Allowable Air Levels To Be Considered Chemical Specific

Page 1-11 - paragraph 1 The risk downqradient of the Haverhill Landfill is listed as

1x10-6 and arsenic is also identified in the groundwater at the landfill at 400 ppm which is in the risk range of 1X10-3

Page 2-4 - paragraph 1 It a~rd ougtient gt 1 is selected tor each i ndividual

compound aitCan the Tgtpl Combined Hazprd rndex be lass than 1 as stated is page

Tabla 2-4 The Massachusetts drinking water standard tor 11shy

dichloroethane is 5 ugjl which corresponds to a 10-5 risk It appears the cleanup number in the FS (3500 uqjl) does not taka into account that this compound is a carcinogen

Tabla 2-5 Mass drinking water standards are

chromium - SOug1 selenium - 10ugjl silver - 50ugjl

Page 4-3 - paraqraph 2 It needs to be noted that the Mill Pond discharge is in

compliance with the KPDES permit issUed jointly by the State and EPA specifically tor the purpose it is beinq used

Page 4-3 - under Effectiveness ot Institutional Controlsbull Deed restrictions have not proven to be vary ettactiva and

are difficult to enforce This should be made clear

Under Impleaentability deed restrictions to prevent private well usa is not easily implementable The State does not have the authority to do this and the Town would have to adopt new byshylaws

Page 4-4 - under Conclusionbullbull Deed restrictions are not a treatment technology

Page 4-14 - laat paraqraph Air strippinq will require emission controls

Page 4-17 and 4-18 A batter description ot the UVJOxidation technology should be

provided to include such things as what it is how it works limitations experience and a comparative discussion on the different oxidants middot

Also a batter description on wet-air oxidation would be helpful

Paqe 4-18 - under Effectiveness The text says air oxidation is only appropriate tor iron

treatment and later in the same section it says that it can adequately handle the volume and contaminants at the site This should be clearer in what is meant here

In the text it states that the OM costs are low for air strippinq medium for carbon adsorption and hiqh for oxidation but the cost t iqures don 1 t show this

Also on this paqe (4-18) it states (under Implemantability)that wet-air oxidation requires no pretreatment Is this correct and will they still achieve discharqe requirements for inorqanicswith no pretreatment If this is the case is wet-air oxidation still more expensive than ozone

Paqe 4-21 In the treatment component list dewaterinq is missinq

Table 4-1 - under TreatmentPhysical It is unclear why reverse osmosis is listed as not

implemantable 11 The description says it is used to remove suspended solids but the footnote says it is not useable because ot the suspended solids present

Table 4-1 The dewaterinq options have bean lett out ie filter press

belt filter press and vacuum

Table 4-3 Where is the footnote explanation tor the double asterisk

Table 4-4 There are no units on this tabla so it is difficult to

understand

Table 4-5 Subsurface discharqe should be medium protectiveness not low

Deed restrictions should be medium implementability not hiqh

Volatilization should be medium OampM not low

Ch-ical treatmentoxidation should be medium OM not hiqh

Why is protectiveness tor all three of these medium

Paqe 5-5 - Alternative 1 No Action Doesnbullt the No Action alternative typically include

monitorinq

Paqe 5-6 - Paraqraph 1 last sentence The statement that vinyl chloride may pass throuqh the

carbon should be removed and replaced with somethinq like and may

require shut down ot the well andor may require additional treatment This occurs on several pages incluclinq 5-7 5-9 and 5-10 In addition vinyl chloride has never been detected in that area so is it appropriate to include this at all

Page 5-6 - Paraqraph 2 The discharqe at Mill Pond is in compliance ~ the NPDES

discharge permit issued j ointly by EPADEP and is 11 below the preliminary discharge standards tor TCE and 1 2-0 the major contaminants attributable to the site This should be stated This occurs several times throughout the document including page 5-7 5-9 5-10

Page S-7 - Paraqraph 4

middot There AJA steps being taken to actively restore the aquifer ie the Mill pond extraction system This paraqraph should be changed

Page 5-7 - Last Paraqraph Why is there a need for aciditional monitoring walls to monitor

Station 1 We believe the existinq monitorinq network is sufficient Same comment for paqes S-9 5-11 5-15 (2x) 5-16 s shy22 and 5-23

Paqe 5-9 - under Implementability of Institutional Controls The docwaent should nota that this would require the adoption

of local by-laws as well as a means to monitor and enforce them over the lonq term

Paqe 5-12 - under lliGaAl It should be asaued for cost purposes that the sludqe will

be claaaitied as hazardous

Paqe 5-12 - under Sbgrt Term Ettectiyeneaa Four to six months tram the siqninq ot the ROO see- too

optimiatic for qettinq Institutional Controls in place one year would seem mora likely

Paqe 5-13 - under Reductign of Toxicity Mgbility or yolwpt This treatment process also includes air oxidation which

appears to have been lett out

Paqt 5-17 and 5-19 OEP ARAR and EPA policy require air stripper emission control

Paqe 5-24 For the carbon adsorption option the use ot larqar carbon

units should be evaluated On site regeneration should also be evaluated

Paqa 5-28 - Last Paraqraph This alternative does not include air stripping (typo)

Page 5-30 The description ot UVOzone oxidation s hould be expanded to

include things like appropriate uses limitations actors to be considered experience different oxidants and their advantages and disadvantages ate

Table S-3 pages 2 and 3 Numbers 21 and 22 should ba checked as ARAR

If the particular action triggers Clean Air Act it should also trigger state Air Quality reqs - paqe 5 tables S-3 and 5-4

Why ian 1t the EPA 1 s Groundwater Protection Strateqy an ARAR or a To Be Considered for this Operable Unit

Table 5-6 page 5 3 Right To Know should be an ARAR 5 310 CMR 7 Air Pollution control Regulation is an ARAR 8 314 CMR 12 OampM and Pretreatment Standards tor Wastewater

Treatment Works and Indirect Discharges is an ARAR

For Alternative 4 should add the tollowinq Action Specific ARARs

310 CMR 400 - Surface Water Quality Standards To Be Considered (TBC) - Aabient Air Levels AALs)

For Alternative 5 should add the following Action Specific ARARs

3 Right To Know 5 310 CMR 7 Air Pollution Control Regulations 8 314 01R 12 310 C11R 4 00 To Be considered (TBC) - AALs

For Alternative 6 the same list as above are Action Specitic ARARs

Table 5-11 Paqe 5 Alternative 3 There is no 4estruotion ot contaminants in this alternative

or alternativas 4 or 5

Other general comments

Are there any restrictions on sludge disposal ie land disposal restrictions

If the Mill Pond system is to be included as part of the remedy then the cost tor upqradinq as necessary operating and maintaining the system should be included in the estimated cost ot the remedy

Page 1-11 - paragraph 1 The risk downqradient of the Haverhill Landfill is listed as

1x10-6 and arsenic is also identified in the groundwater at the landfill at 400 ppm which is in the risk range of 1X10-3

Page 2-4 - paragraph 1 It a~rd ougtient gt 1 is selected tor each i ndividual

compound aitCan the Tgtpl Combined Hazprd rndex be lass than 1 as stated is page

Tabla 2-4 The Massachusetts drinking water standard tor 11shy

dichloroethane is 5 ugjl which corresponds to a 10-5 risk It appears the cleanup number in the FS (3500 uqjl) does not taka into account that this compound is a carcinogen

Tabla 2-5 Mass drinking water standards are

chromium - SOug1 selenium - 10ugjl silver - 50ugjl

Page 4-3 - paraqraph 2 It needs to be noted that the Mill Pond discharge is in

compliance with the KPDES permit issUed jointly by the State and EPA specifically tor the purpose it is beinq used

Page 4-3 - under Effectiveness ot Institutional Controlsbull Deed restrictions have not proven to be vary ettactiva and

are difficult to enforce This should be made clear

Under Impleaentability deed restrictions to prevent private well usa is not easily implementable The State does not have the authority to do this and the Town would have to adopt new byshylaws

Page 4-4 - under Conclusionbullbull Deed restrictions are not a treatment technology

Page 4-14 - laat paraqraph Air strippinq will require emission controls

Page 4-17 and 4-18 A batter description ot the UVJOxidation technology should be

provided to include such things as what it is how it works limitations experience and a comparative discussion on the different oxidants middot

Also a batter description on wet-air oxidation would be helpful

Paqe 4-18 - under Effectiveness The text says air oxidation is only appropriate tor iron

treatment and later in the same section it says that it can adequately handle the volume and contaminants at the site This should be clearer in what is meant here

In the text it states that the OM costs are low for air strippinq medium for carbon adsorption and hiqh for oxidation but the cost t iqures don 1 t show this

Also on this paqe (4-18) it states (under Implemantability)that wet-air oxidation requires no pretreatment Is this correct and will they still achieve discharqe requirements for inorqanicswith no pretreatment If this is the case is wet-air oxidation still more expensive than ozone

Paqe 4-21 In the treatment component list dewaterinq is missinq

Table 4-1 - under TreatmentPhysical It is unclear why reverse osmosis is listed as not

implemantable 11 The description says it is used to remove suspended solids but the footnote says it is not useable because ot the suspended solids present

Table 4-1 The dewaterinq options have bean lett out ie filter press

belt filter press and vacuum

Table 4-3 Where is the footnote explanation tor the double asterisk

Table 4-4 There are no units on this tabla so it is difficult to

understand

Table 4-5 Subsurface discharqe should be medium protectiveness not low

Deed restrictions should be medium implementability not hiqh

Volatilization should be medium OampM not low

Ch-ical treatmentoxidation should be medium OM not hiqh

Why is protectiveness tor all three of these medium

Paqe 5-5 - Alternative 1 No Action Doesnbullt the No Action alternative typically include

monitorinq

Paqe 5-6 - Paraqraph 1 last sentence The statement that vinyl chloride may pass throuqh the

carbon should be removed and replaced with somethinq like and may

require shut down ot the well andor may require additional treatment This occurs on several pages incluclinq 5-7 5-9 and 5-10 In addition vinyl chloride has never been detected in that area so is it appropriate to include this at all

Page 5-6 - Paraqraph 2 The discharqe at Mill Pond is in compliance ~ the NPDES

discharge permit issued j ointly by EPADEP and is 11 below the preliminary discharge standards tor TCE and 1 2-0 the major contaminants attributable to the site This should be stated This occurs several times throughout the document including page 5-7 5-9 5-10

Page S-7 - Paraqraph 4

middot There AJA steps being taken to actively restore the aquifer ie the Mill pond extraction system This paraqraph should be changed

Page 5-7 - Last Paraqraph Why is there a need for aciditional monitoring walls to monitor

Station 1 We believe the existinq monitorinq network is sufficient Same comment for paqes S-9 5-11 5-15 (2x) 5-16 s shy22 and 5-23

Paqe 5-9 - under Implementability of Institutional Controls The docwaent should nota that this would require the adoption

of local by-laws as well as a means to monitor and enforce them over the lonq term

Paqe 5-12 - under lliGaAl It should be asaued for cost purposes that the sludqe will

be claaaitied as hazardous

Paqe 5-12 - under Sbgrt Term Ettectiyeneaa Four to six months tram the siqninq ot the ROO see- too

optimiatic for qettinq Institutional Controls in place one year would seem mora likely

Paqe 5-13 - under Reductign of Toxicity Mgbility or yolwpt This treatment process also includes air oxidation which

appears to have been lett out

Paqt 5-17 and 5-19 OEP ARAR and EPA policy require air stripper emission control

Paqe 5-24 For the carbon adsorption option the use ot larqar carbon

units should be evaluated On site regeneration should also be evaluated

Paqa 5-28 - Last Paraqraph This alternative does not include air stripping (typo)

Page 5-30 The description ot UVOzone oxidation s hould be expanded to

include things like appropriate uses limitations actors to be considered experience different oxidants and their advantages and disadvantages ate

Table S-3 pages 2 and 3 Numbers 21 and 22 should ba checked as ARAR

If the particular action triggers Clean Air Act it should also trigger state Air Quality reqs - paqe 5 tables S-3 and 5-4

Why ian 1t the EPA 1 s Groundwater Protection Strateqy an ARAR or a To Be Considered for this Operable Unit

Table 5-6 page 5 3 Right To Know should be an ARAR 5 310 CMR 7 Air Pollution control Regulation is an ARAR 8 314 CMR 12 OampM and Pretreatment Standards tor Wastewater

Treatment Works and Indirect Discharges is an ARAR

For Alternative 4 should add the tollowinq Action Specific ARARs

310 CMR 400 - Surface Water Quality Standards To Be Considered (TBC) - Aabient Air Levels AALs)

For Alternative 5 should add the following Action Specific ARARs

3 Right To Know 5 310 CMR 7 Air Pollution Control Regulations 8 314 01R 12 310 C11R 4 00 To Be considered (TBC) - AALs

For Alternative 6 the same list as above are Action Specitic ARARs

Table 5-11 Paqe 5 Alternative 3 There is no 4estruotion ot contaminants in this alternative

or alternativas 4 or 5

Other general comments

Are there any restrictions on sludge disposal ie land disposal restrictions

If the Mill Pond system is to be included as part of the remedy then the cost tor upqradinq as necessary operating and maintaining the system should be included in the estimated cost ot the remedy

Paqe 4-18 - under Effectiveness The text says air oxidation is only appropriate tor iron

treatment and later in the same section it says that it can adequately handle the volume and contaminants at the site This should be clearer in what is meant here

In the text it states that the OM costs are low for air strippinq medium for carbon adsorption and hiqh for oxidation but the cost t iqures don 1 t show this

Also on this paqe (4-18) it states (under Implemantability)that wet-air oxidation requires no pretreatment Is this correct and will they still achieve discharqe requirements for inorqanicswith no pretreatment If this is the case is wet-air oxidation still more expensive than ozone

Paqe 4-21 In the treatment component list dewaterinq is missinq

Table 4-1 - under TreatmentPhysical It is unclear why reverse osmosis is listed as not

implemantable 11 The description says it is used to remove suspended solids but the footnote says it is not useable because ot the suspended solids present

Table 4-1 The dewaterinq options have bean lett out ie filter press

belt filter press and vacuum

Table 4-3 Where is the footnote explanation tor the double asterisk

Table 4-4 There are no units on this tabla so it is difficult to

understand

Table 4-5 Subsurface discharqe should be medium protectiveness not low

Deed restrictions should be medium implementability not hiqh

Volatilization should be medium OampM not low

Ch-ical treatmentoxidation should be medium OM not hiqh

Why is protectiveness tor all three of these medium

Paqe 5-5 - Alternative 1 No Action Doesnbullt the No Action alternative typically include

monitorinq

Paqe 5-6 - Paraqraph 1 last sentence The statement that vinyl chloride may pass throuqh the

carbon should be removed and replaced with somethinq like and may

require shut down ot the well andor may require additional treatment This occurs on several pages incluclinq 5-7 5-9 and 5-10 In addition vinyl chloride has never been detected in that area so is it appropriate to include this at all

Page 5-6 - Paraqraph 2 The discharqe at Mill Pond is in compliance ~ the NPDES

discharge permit issued j ointly by EPADEP and is 11 below the preliminary discharge standards tor TCE and 1 2-0 the major contaminants attributable to the site This should be stated This occurs several times throughout the document including page 5-7 5-9 5-10

Page S-7 - Paraqraph 4

middot There AJA steps being taken to actively restore the aquifer ie the Mill pond extraction system This paraqraph should be changed

Page 5-7 - Last Paraqraph Why is there a need for aciditional monitoring walls to monitor

Station 1 We believe the existinq monitorinq network is sufficient Same comment for paqes S-9 5-11 5-15 (2x) 5-16 s shy22 and 5-23

Paqe 5-9 - under Implementability of Institutional Controls The docwaent should nota that this would require the adoption

of local by-laws as well as a means to monitor and enforce them over the lonq term

Paqe 5-12 - under lliGaAl It should be asaued for cost purposes that the sludqe will

be claaaitied as hazardous

Paqe 5-12 - under Sbgrt Term Ettectiyeneaa Four to six months tram the siqninq ot the ROO see- too

optimiatic for qettinq Institutional Controls in place one year would seem mora likely

Paqe 5-13 - under Reductign of Toxicity Mgbility or yolwpt This treatment process also includes air oxidation which

appears to have been lett out

Paqt 5-17 and 5-19 OEP ARAR and EPA policy require air stripper emission control

Paqe 5-24 For the carbon adsorption option the use ot larqar carbon

units should be evaluated On site regeneration should also be evaluated

Paqa 5-28 - Last Paraqraph This alternative does not include air stripping (typo)

Page 5-30 The description ot UVOzone oxidation s hould be expanded to

include things like appropriate uses limitations actors to be considered experience different oxidants and their advantages and disadvantages ate

Table S-3 pages 2 and 3 Numbers 21 and 22 should ba checked as ARAR

If the particular action triggers Clean Air Act it should also trigger state Air Quality reqs - paqe 5 tables S-3 and 5-4

Why ian 1t the EPA 1 s Groundwater Protection Strateqy an ARAR or a To Be Considered for this Operable Unit

Table 5-6 page 5 3 Right To Know should be an ARAR 5 310 CMR 7 Air Pollution control Regulation is an ARAR 8 314 CMR 12 OampM and Pretreatment Standards tor Wastewater

Treatment Works and Indirect Discharges is an ARAR

For Alternative 4 should add the tollowinq Action Specific ARARs

310 CMR 400 - Surface Water Quality Standards To Be Considered (TBC) - Aabient Air Levels AALs)

For Alternative 5 should add the following Action Specific ARARs

3 Right To Know 5 310 CMR 7 Air Pollution Control Regulations 8 314 01R 12 310 C11R 4 00 To Be considered (TBC) - AALs

For Alternative 6 the same list as above are Action Specitic ARARs

Table 5-11 Paqe 5 Alternative 3 There is no 4estruotion ot contaminants in this alternative

or alternativas 4 or 5

Other general comments

Are there any restrictions on sludge disposal ie land disposal restrictions

If the Mill Pond system is to be included as part of the remedy then the cost tor upqradinq as necessary operating and maintaining the system should be included in the estimated cost ot the remedy

require shut down ot the well andor may require additional treatment This occurs on several pages incluclinq 5-7 5-9 and 5-10 In addition vinyl chloride has never been detected in that area so is it appropriate to include this at all

Page 5-6 - Paraqraph 2 The discharqe at Mill Pond is in compliance ~ the NPDES

discharge permit issued j ointly by EPADEP and is 11 below the preliminary discharge standards tor TCE and 1 2-0 the major contaminants attributable to the site This should be stated This occurs several times throughout the document including page 5-7 5-9 5-10

Page S-7 - Paraqraph 4

middot There AJA steps being taken to actively restore the aquifer ie the Mill pond extraction system This paraqraph should be changed

Page 5-7 - Last Paraqraph Why is there a need for aciditional monitoring walls to monitor

Station 1 We believe the existinq monitorinq network is sufficient Same comment for paqes S-9 5-11 5-15 (2x) 5-16 s shy22 and 5-23

Paqe 5-9 - under Implementability of Institutional Controls The docwaent should nota that this would require the adoption

of local by-laws as well as a means to monitor and enforce them over the lonq term

Paqe 5-12 - under lliGaAl It should be asaued for cost purposes that the sludqe will

be claaaitied as hazardous

Paqe 5-12 - under Sbgrt Term Ettectiyeneaa Four to six months tram the siqninq ot the ROO see- too

optimiatic for qettinq Institutional Controls in place one year would seem mora likely

Paqe 5-13 - under Reductign of Toxicity Mgbility or yolwpt This treatment process also includes air oxidation which

appears to have been lett out

Paqt 5-17 and 5-19 OEP ARAR and EPA policy require air stripper emission control

Paqe 5-24 For the carbon adsorption option the use ot larqar carbon

units should be evaluated On site regeneration should also be evaluated

Paqa 5-28 - Last Paraqraph This alternative does not include air stripping (typo)

Page 5-30 The description ot UVOzone oxidation s hould be expanded to

include things like appropriate uses limitations actors to be considered experience different oxidants and their advantages and disadvantages ate

Table S-3 pages 2 and 3 Numbers 21 and 22 should ba checked as ARAR

If the particular action triggers Clean Air Act it should also trigger state Air Quality reqs - paqe 5 tables S-3 and 5-4

Why ian 1t the EPA 1 s Groundwater Protection Strateqy an ARAR or a To Be Considered for this Operable Unit

Table 5-6 page 5 3 Right To Know should be an ARAR 5 310 CMR 7 Air Pollution control Regulation is an ARAR 8 314 CMR 12 OampM and Pretreatment Standards tor Wastewater

Treatment Works and Indirect Discharges is an ARAR

For Alternative 4 should add the tollowinq Action Specific ARARs

310 CMR 400 - Surface Water Quality Standards To Be Considered (TBC) - Aabient Air Levels AALs)

For Alternative 5 should add the following Action Specific ARARs

3 Right To Know 5 310 CMR 7 Air Pollution Control Regulations 8 314 01R 12 310 C11R 4 00 To Be considered (TBC) - AALs

For Alternative 6 the same list as above are Action Specitic ARARs

Table 5-11 Paqe 5 Alternative 3 There is no 4estruotion ot contaminants in this alternative

or alternativas 4 or 5

Other general comments

Are there any restrictions on sludge disposal ie land disposal restrictions

If the Mill Pond system is to be included as part of the remedy then the cost tor upqradinq as necessary operating and maintaining the system should be included in the estimated cost ot the remedy

Page 5-30 The description ot UVOzone oxidation s hould be expanded to

include things like appropriate uses limitations actors to be considered experience different oxidants and their advantages and disadvantages ate

Table S-3 pages 2 and 3 Numbers 21 and 22 should ba checked as ARAR

If the particular action triggers Clean Air Act it should also trigger state Air Quality reqs - paqe 5 tables S-3 and 5-4

Why ian 1t the EPA 1 s Groundwater Protection Strateqy an ARAR or a To Be Considered for this Operable Unit

Table 5-6 page 5 3 Right To Know should be an ARAR 5 310 CMR 7 Air Pollution control Regulation is an ARAR 8 314 CMR 12 OampM and Pretreatment Standards tor Wastewater

Treatment Works and Indirect Discharges is an ARAR

For Alternative 4 should add the tollowinq Action Specific ARARs

310 CMR 400 - Surface Water Quality Standards To Be Considered (TBC) - Aabient Air Levels AALs)

For Alternative 5 should add the following Action Specific ARARs

3 Right To Know 5 310 CMR 7 Air Pollution Control Regulations 8 314 01R 12 310 C11R 4 00 To Be considered (TBC) - AALs

For Alternative 6 the same list as above are Action Specitic ARARs

Table 5-11 Paqe 5 Alternative 3 There is no 4estruotion ot contaminants in this alternative

or alternativas 4 or 5

Other general comments

Are there any restrictions on sludge disposal ie land disposal restrictions

If the Mill Pond system is to be included as part of the remedy then the cost tor upqradinq as necessary operating and maintaining the system should be included in the estimated cost ot the remedy

APPENDICES Comments

Appendix A

standard Calculation Sheet Paqe s ot 13

The Lett Column ot this tallle should have the word saturated added to the word overburden

Standard Calculation Sheet Paqe 6 ot 13

The Table on this paqe should have col~ headinqs added

Grid Conubulllnttlon trlddi_ION Tlllckneu of Votubullbull of ntloofgrld Stturtttcl Conttbulllntftd-

Bottom ot Page 6 ot 13

Number 9 0775 haa no apparent bearinq in calculation and needs clarification

Appendix c

Standard Calculation Page J ot 24

Upper halt ot paqe is not leqible

Standard Calculation Paqa 4 ot 24

Portions ot this paqe are not leqibla

1. barcode 558980
2. barcodetext SDMS Doc ID 558980