1 ENVIRONftENTAL PROTECTION AGENCY · IN RE: 216 Ch esterton propert y does not appear to 17 b e...

13.'/. 1

ENVIRONftENTAL PROTECTION AGENCY·

SUPERFUND PROGRAft

IN RE:

GROVELAND WELLS NOS. 1 AND 2 GROVELAND, MASSACHUSETTS

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BEFORE: JAY NAPARSTEK, Chairman, Mass Department of Environmental Protection , Branch Chief for Bureau of Waste Site Manaqeaent; CHARLES TUTTLE, Geoloqist Mass Department of Environmental Protection, ROBERT J. LEGER, Reaedial Project Manager, U.S. Environaental Protection Agency

Groveland Town Hall 183 Main Street Groveland, Massachusetts Wednesday, July 31, 1991 7:33 p .m.

Marybeth Coldwell, RPR

M.A. TOROSIAN & ASSOCIATES, INC.

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P R 0 C E E 0 I N G S

MR . NAPA RST Ek: Okay . I t h ink

we will qet started now if t h at is

okay . Th a n k you all for coming

tonight . My name is Jay Naparstek.

I'm a Branch Chief with t h e Bu reau of

Wa ste Site Cl e an u p fo r th e Mass.

Depar t ment o f En vir onmental P rote ctio n

and I'll be ser v ing a s a hearing

10 officer for tonight 's he a r i ng o n t h e

11 propo s ed plan for groundwater

12 contaaination at the Gro v eland Wells

13 Site,

14 Let ae introduce the other

15 aeabers of the panel here tonight and

16 explain the agenda and the format for

17 tonight's hearing. On my right here i s

18 Rob e rt Leger and h e is the Remed i al

19 Project Manager with E. P . A . On my l e ft

2 0 i s Charl es Tu t tl e and h e i s th e P r oject

21 Manager for the . Mass . Department o f

Environmental Protection. Also here

2 3 tonight are Diane · Ready, Public

2 4 Relat i ons Coordinator, and Lisa West

ft . A . TOROSIAN & ASS OCIATES, INC.

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also working with Diane i n the Public

Relations Office.

Now, for those of you who are

not faailiar with the Groveland Wells

Site or with E.P . A . 's approach to the

cleanup, you should know that we have

divided the remediation i nt o two phases

which a re also known as Operable Units

1 and 2.

10 The first phase addresses the

11 c ontaainated s oil s and ground~ater t hat

u are on or a d jace n t t o the Valley

13 "a n ufacture d Pro du cts on Washingto n

14 Street. The reaedy for this phase is

15 presently being designed by . the

16 consultant for Valley under t h e te rm s

17 of a n Administrati ve Order with t h e

18 E . P . A.

19 The second pha se o f the project

20 addresses the c ont aminate d grou ndw ater

21 in the aquifer north of the valley

22 Property which is the subject o f

23 toniqht's hearing.

2 4 Now, back on J uly 9th the


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E.P.A. held a public meeting here to

present the results of the Feasibility

Study which examined alternative ways

for the cleaning up of the groundwater

and then we presented E.P.A.'s

preferred approach, followed by a

question and answer period.

Now, after I conclude these

introductory remarks, Bob Leger from

10 the E.P.A. will just briefly recap the

11 proposed plan and then we will begln

12 the actual hearing .

13 · The purpose of tonight's

14 hearing is to allow the public to

15 coaaent on the E.P . A,' s proposed plan

16 for cleaning up the groundwater under

17 the second operable unit . we will be

18 transcribing the meeting and later

19 provide a printed transcript which will

20 become part the administrative record

21 which is used by E . P.A. to make a final

22 remedy decision.

2 3 In order to ensure accuracy i n

24 the record, I ask that anyone who


wishes to make a s tat eme nt , first fill

out o n e of the index car d s that are

provided at the entrance with your

name , your address and your

affiliation, if you have any. I'll

then call on you in the order in which

the cards are submitted. I must

reserve the right to limit the ti~e

available to any o n e speaker to ten

10 minutes to e n sure that everybody who

11 wishes to make a statement gets a

12 chance.

0 13 You should understand that

14 E.P . A. will not be responding to any

15 questions tonight . However, you may

16 ask questions as part of your statement

17 and a response will be i ncluded in the

18 Responsi vene ss Summary that E.P.A . wil l

19 prepare after the public comment period

20 closes.

21 The Responsiveness Summary will

22 then will be included in the Record of

23 Decision which the E.P.A . plans to

24 issue later this fall. In addition to


tonight's hearing, you may also submit

written c omments for E.P.A.'s

consideration.

E. P .A . rece ntly received two

requests to extend the public comment

per iod a nd we will, therefore, be

extending the comment period to

September 9 , 1991. The written

comments should be written to the

10 E.P.A. c ontact in the proposed plan

11 which you could pick up at the front

12 desk and must be postmarked no later

0 13 than Septeaber 9, 1991. Copies of the

14 pr o posed plan are available at the

15 registration desk just as you came in.

16 And finally, let me remind you

17 that copies of the administrative

18 record are located at the Langley

19 Adams Library here in G~oveland as well

20 as the E.P . A. offi ce s at 90 Canal

21 Street in Boston and you may ceview any

22 documents contained in the

23 administcative cecocd at these

24 locations during the nocmal b usines s

M.A. TO ROSI AN & ASSOCIATES, INC .

hours .

Befor e I begin the ac tual

hearing, . are there any q u estions either

on the hearing format or on the public

participation process t ha t you wou ld

like clarified?

Yes, Karl.

MR . LeMUTH: Just one question.

I assume that you' v e gotte n the we ll

10 pollution committee request for a n

ll extension ,

1~ MR . NAPARSTEK : I believe that

1 3 have .:) l4 PIR. Le MU TH: Coul d I ask who

1 5 t h e other perso n was that asked for the

16 extension?

17 PIR , NAPARSTEK: I think. that is

18 part of the public record . That was

19 Martin Pentz from Nutter, McClennan &

~0 Fish. Okay.

2 1 Anybody else?

22 Okay. Bob Leger then is just

23 going to give a brief recap of the

24 proposed plan for the remediation o f


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groundwater under Operable Unit 2.

MR. LEGER: Thanks, Jay, My

name is Bob Leger, the Remedial P(oject

Manager. I'm with the Environmental

Protection Agency in Boston and I'll be

going over ve ry briefly tonight some of

the material that we went over in the

beginning of July when we presented the

proposed plan to you for your

10 consideration.

11 My coaaents wi ll be very brief

~2 to give y ou people a n o pportunity to

~ 13 present your opinion and your thoughts

14 and your c on s ideration s on our pr o pos e d

15 plan to clea n up t he pollution i n the

16 groundwater in Groveland .

17 Very quickly, Groveland Wells

18 No. 1 and 2 Superfund Site consists of

19 approximately 850 acres located mostly

20 in the town of Groveland, bounded by

21 School Street, Salem Street, Washinqton

22 Street, Main Street and the Haverhill

23 landfill. Get your bearinqs. Station

2 4 No. 1 (indicatinq), StAtion No. 2


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(·indicatinq), Valley Manufacturing

Company and A.W. Chesterton Company

(indicating).

Based on investiga tions that

were conducted over several years here

at the Site, we've identified three

sources of pollution .

Let me back up. Back in 1979,

the t own' s wells became -- were

10 discovered to be polluted with a

11 s ol ve nt called Trichloroethane. At the

1~ tiae Station 1 and Station 2 provided

13 entire d r inking water s upply o f the

14 town . And when the c ont aainatio n i n

15 the town we lls were discovered, both

16 well• were shut down and the tow n went

17 into eaergency water rationing and

18 subsequently d rilled a nother well right

19 up here (i ndi cating) Station No. 3

~0 which provided drinking water for the

~1 town. Subsequently, Station 1 was

~~ rehabilitated as a result of E.P.A.

~3 funding so now the town h's a safe

drinking water supply from the water~·


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being s up~lied from Station 3 and

Station 1. Station 2 has remained

closed since 1979.

The E.P.A. through funding came

and started investigating into the

contamination of the property and

subsequently identified three major

sources of pollution o n this Site; the

Chesterton Com pany , the Valley

10 ftanufactured Products Com pan y a nd the

11 Ha ve rh i ll Landfill.

12 The c ontaminat io n of t he

13 Chesterton . property we discovered is

14 priaarily c onfin e d to 1the property

15 boundar y. The contamination of the

16 Chesterton propert y does not appear to

17 b e related in a dy way to the

18 contamination that was diseovered in

19 the Statio ns 1 and 2.

2 0 Haverhill landfill

21 contamination -

22 Let me back up a bit. The

23 Chesterton contamination is beinq dealt

24 with under the Resource Conservation


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and Recovery Act (RCRA). That

contamination in the Chesterton

property is being handled under another

law .

Contamination of the Haverhill

Landfill is being handled under a

Superfund law so basically what are

talking about tonight, we are not

talking about the contamination of the

10 Che sterton or t h e Haverhill. we are

11 talking a bout the co nt aai n a ti on

12

D eaanating froa the Valley Manufactured

13 Products.

lC Contaaination froa the Valley

15 Manufactu~ed Products Coapany primar i l y

16 consists of Trichloroethene

17 c ontJ ai nat to n, what we ca ll a Volatile

18 Organic Compound, solvent t h at was used

19 by valley Manufactured Products

20 Company. As a result of spills and

21 contamination leaks, it got into the

22 groundwater and resulted in groundwater

23 contamination ,

2 4 Basically the groundwater flows

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from s outh to the north . And again

here (indicati ng ) is the Cen ter Street

and Me r rimack is up here (indicating).

We discovered a groundwater

cont,mination, what we call co ntaminant

plume. What you see here is

concentrations of Trich l oroet han e of

above drinking-water sta nd ards, a bo ve

five parts per billion a nd this is wh a t

10 the groundwater within this area her e

11 (indicating) outlined in the black i&

12 contaainated with Trichloroethane above

13 safe-drinking water sta ndards for that

14 contaaination .

15 Basically it is about, the

16 contaaination is primarily 75 acres

17 surface area, about six billions

18 gallons of water, about 6,000 pounds of

19 trichloroethane that needs to be

20 cleaned up to drinking water standards.

21 When we were here in the

22 beqinninq of July, we basically put

2 3 forth to you what our objectives were.

Basically to clean up the groundwater


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so that it can be -- it c ould be uked

for drinking i n the future time. AI I

s aid right now there is no present

threat to gr oundwater because t h e

ground the groundwater you are

getting right now is from Stations 1

a nd 2 and that is perfectly safe.

The E . P.A . 's task is to clean

up the contamination to the groundwater

10 that possible future use if someone

11 wanted to drill a well in that area

12 that they could i n the future. So,

13 basically our objective is to clean up:) 14 the groundwater so that it can be

15 safely . drank .

16 KR. FALCONE ' Stations are

17 Sources 1 and 3.

18 MR. LEGER: I'm sorry ,

19 MR. FALCONE: You said Stations

20 1 and 2 . They are stations 1 a nd 3.

21 HR. NAPARSTEK: That's 1 and

22 are the stations, water drinking

23 stations.

24 MR. LEGER: Yes, that's

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c orrect . we looked at several

alternatives to clean up the

contaminant plume that I showed you

earlier and I'll put that picture back

up again so that you could take a look

at it. We looked at several

alternatives on how to clean that up.

When look at the

alternative, have to -- the law says

10 that we have to evaluate each

11 alternative according to the nine

12 criteria . And we look at all -- any

0 13 alternative that we look at, we balance

1C against theae nine criteria.

15 The No. 1 and 2 obviously the

16 overall protection of human health and

17 the environment in compliance with

18 ARARs . The compliance with the

19 environmental laws and regulations and

20 that's what ARARs a re . So, ·if any

21 alternative passes muster for the first

22 two, t hen we look at how i t passes

2 3 muster for the last remaining seven

2 4 criteria .

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we di scu s s ed this crite r ia

early in July so I'm not going to go

over them again. We looked at

basically -- we looked at a lot of

different things to clean up the

groundwater, a lot of technology, a lot

of differential techniques to best

clean up the water here at Groveland.

It came down to basically six

10 major a lternat ives we consid er ed to

11 cleaning up groundwater. The first is

12 an alternative wh ich we are mandated by

13 law to c onsider and that is to not do

14 anything . No action. All the other

15 criteria are based against that.

16 So, the first criteria i s not

17 to do anything . What would happen7

18 Well , obviously t he groundwater would

19 never get cleaned up. Wouldn't be

2 0 safey to drink for a long long time.

21 But, that . is -- there is no action

22 alternative is one that we are required

23 to look at by law . We are required to

24 balance each alternative and compare it

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a g ainst no action.

The second alternative is

basically what we ca ll institutional

controls. Prevent people through deed

restr ictio ns to prevent them from

puttinq a well in the contaminated

groundwater area. Now, that wouldn't

clean up the groundwater but it would

provide some protection to the public.

1 0 Th ey wo uldn't be able t o drill a well

11 t h e r e.

12 And t h e reaaining four

13 alternat iv e s ba s i c a l ly c ~n si der tak i ng

14 the groundwa t e r out a nd treating it by

15 s o •• way a nd putt in g t h e wat e r b a ck in .

1 6 Ta k ing t h e wat e r o u t a nd trea t ing it to

17 d r i n k in g wa ter sta n da r ds . On ce yo u

1 8 take it o u t, y o u put i t t h rough

19 sort of treatment so that when you put

20 it back in it is now safe to drink . we

21 looked at four different alternatives

22 to pump the water out.

23 No. 1 was to pump it out and to

24 send it to the Haverhill publicly owned

M.A . TOROSIAN & ASSOCIATES, INC.

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treatment plant . When we take i t out,

we have to do some s ort of metal s

r em o va l be c a u se we have to meet t h e

s t an d ard for me t als in water before we

gave it to t h e Haverhil l - to the

Haver h ill treatme n t pla n t. The fourth

a lt er n a t ive was to t a ke it ou t .

The fourth , f i fth a nd s i xt h

alte r nat iv e was to t ake i t o ut a nd

10 treat it onsite . Take i t out and treat

11 it using air stripping. If you are

12 faailiar with the air stripper up at

13 "ill Pond, basically air is forced

14 thiough the water and contaainants go

15 fro• the water to the air .

16 The fifth alternative was to

17 take the groundwater out and put i t

18 through a· filter c alled th e Granular

19 Acti v ated Carbon similar t o what i s

20 us e d n o w a t St ation 1 . Th e wat e r t h a t

2 1 you have been drinking now has been

22 filtered through what is called a

23 Gran u lar Activated Carbon. It filters

24 out all the contaminants.


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rr

And the six th al t e rnati ve that

we looked at was to take t he water out

and to take care of t h e inorganics and

then d~stroy the co ntaminants by a

process known as Ultraviolet Light /

Oxidation. I'm not going to go into

the actual details of ultraviolet light

and oxidation. It is a n i nnovat ive

process but it involves actual

10 destruction of the contaminants onsite.

11 Any volati l e organic coapou nd that

u co•es out of the groundwater would be

destroyed onaite aa opposed to taking:J 13

14 the water out and the water the

15 contaainant would be transferred to

16 another media, i f you like, the air

17 stripping . T he co ntaminant would be

1 8 tkansfered from the water ·to the air

1 9 a nd then you have to treat the air o r

20 the carb on . You would have to t r eat

I 21 the carbon . That treatmeant would

22 occur off site. But, the ultraviolet

23 light / (UV) oxidation process

24 .con tam inants are being actually

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destroyed onsite,

So, we opted for that primarily

because the new Superfund law requires

that we look at the permanent treatment

and so we thought that would be in line

with the idea and the intent of the new

Superfund laws. The cost was al&o a

consideration. The particular costs

were one of the cheaper ones .

10 We looked at air strip p ing.

11 Air stripping and ultraviolet / oxidation

12 were the two cheaper. I'a not going to

13 say cheap because they were over a

14 aillion dollar s. It is n 't c h eap but

15 they were two of the cheaper

16 alternatives that we looked at.

17 The alternative that the E . P . A .

18 is proposing will c ost approximately

19 nine million dollars to clean up the

20 groundwater. It basically consists of

21 installing a network of groundwater

22 extra~tion wells to take the

23 groundwater out, to const ruct the

24 treatment facililties for special

M.A. TOROSIAN ' ASSOCIATES, INC.

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inorganic and for organics, to extract

the water from the ins tallation of the

we lls , extra ct the water and finally to

discharge the treated water back to

Johnson Creek .

The schematic basically looks

like this. The e xtraction wel ls wi ll

take the water out and flow is

approximately 400 gallons per minute .

10 There is s ome inorqanics l i ke me tal s

11 that needs to be reaoved to protect the

12 equipaent, to help the process, the

13 tr,ataent process operate more

~ 14 effectively and need to take the aetals

15 out . So, the metals are taken out .

16 They are eventually put into what we

17 call a dry, a dry sludge . They are

18 transported out off site to a landf i ll.

19 The filtered water that now has most o f

20 the inorqanics remo ved fro m it is

21 su b ject to what we call the ozone ,

22 ultraviolet light, hydrogen peroxide

23 treatment and then basically the

24 qroundwater - once it is treated, i t

M.A. TOROSIAN & ASSO CIATES, I NC.

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ia discharqed back t o Johnson Creek .

The a pproximate location of the

we ll s so to give you a n i d ea of where

the we lls would be located

(indicating). This is very

p relimi nary, very prelimina ry . These

little circles over here represent

(indicating) the ext raction wells . Six

of them. Most of th~ contamination

10 from the Va lley is around this area

11 right here (indicating) so we want to

12 put a well over here. The wells have

~ 13 been deaigned to extract all of the

14 contaaination, all of the

15 contamination . Ba s ically figure

16 'around s ix wells would be needed to be

17 installed . Exact location of the wells

18 or the exact location of the treatment

19 facilities, we are leaving that for a

2 0 later dec isi on in wha t we c all during

21 remedial desiqn. We will be lookinq at

22 where is the best place to loc a te t hPse

23 wells, where is the best place to

2 4 locate the . treatment facility. Riqht

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now we are very proximal to the

location of the treatment stati on .

Now, Station 2 that doesn't say

where it is qoing to be put . For now

that is a possible location. The

wells, as I said, is not absolute , The

location isn't set in c oncrete. These

are preliminary locations of the wells.

The wel ls are to be in~ talled and to

10 ca pture the entire con taminant .

11 Basically our best stateaent

u right n o w for a tiae of clean up is

13 a p proxiaately 30 years it will take to

14 cl ean up the gr ou ndwater to drinking

15 water standards. Right now that's our

1·6 be s t estimate.

17 That 's all I really ha ve to sa y

18 about E.P.A.'s proposed alter na tives .

..I.,ft I ·~

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We welcome

responding

format is

questions

we c all a

q uest ions. I won 't be

to your questions. The

to ask questions and your

will be responded to in what

Responsi ve ness Summary which

24 will be issued by the E.P.A. at a later

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time .

With that, Mr . Chairman, that's

a ll I have .

MR. NAPARSTEK: Thanks, Bob .

Okay . I just wa n t to emphasize

one more time the purpose of the

hearing tonight is as Bob said it is ,

although, I'm sure that you all have

soae questions t hat you would like to

10 aak, we are not here to answer your

11 questions tonight . we are here to take

12 your co•aenta a n d your questions and

0 13 then c o nsider those in the fi n al

14 decision for the reaedial action . All

15 your coaaents will go into the record

16 and will be responded to as part of the

17 responsiveness summary.

18 I think wit h that, I would like

19 to begin the hearing. I only have two

20 speakers ~ hat hav e filled o ut ca rds .

21 I'm sure that there are pro bably a

22 couple that would want to but I'm going

23 to go in order that I have them.

2 4 would ask that you come up and give

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y ou r name a n d any affiliati on that you

have. The first speaker t h at I have is

Linda Loreth .

115. LORETH: Hi .

MR , NAPA RST! P:: Hi.

MS. LORETB: Did you want me

o v er there?

MR. NA PARSTEK: Anywhere that

y o u wou ld like.

10 MS. LOR ET H : Okay. I'm the

11 En vi ronm e nt a l Hea lt h a "d Sa f e t y Manage r

with A.w . Chester t on Coapany and my

13 naae is Linda Loreth . I'd lik e to r e ad

a written coa a ent that we ha v e .

15 • This i s i n regards t o your

16 Fea s ib i l i ty Study r e gard i ng t he E . P . A.

17 re g ion S uperfund for G r o Ve l a nd We ll s ,

18 No . 1 a n d 2 , i n G r ovelan d ,

19 Massachuse t ts of July of '91. Th is is

20 submitted within your 30-day comment

21 period• which has been extended.

22 MR. NAPAR STEK: Which has been

2 3 extended.

24 MS . LORETH : ~You are aware


2 5

that Cheste r ton wen t to great lengths

and e xpense prior to t he i nvolv e ment o f

t he E. P . A . t o as s u r e t h e t own a nd

i ts el f th a t Ch es t er t o n was not t h e

s ou rce of the contaminatio n of t h e

Gr o vela n d we l ls Nos. 1 and 2. De s pite

that ef fort Cheste r t on c on ti nu e s t o

receive a d ve rs e and i naccurate

public i ty . Your proposed plan dat e d

10 July 19 9 1 describes Chesterton Site a s

11 11) " li ke l y" r a t h er th a n " po ssi b le *

12 source of the c ont aa ination, ( 2) as on e

13 of •s everal s ource s of conta a ination •

14 of the Grovel a nd wells, and ( 3) n o t

15 " curr e nt l y " co nt a min a t i ng t h e we ll s.

16 Th e r e is n o evi d e n ce t hat we h a v e ever

1 7 c ont a mi nate d t h e we l ls . I n fac t , t h e

1 8 contami nants o n Ch esterton ·property are

19 distinctly different from the

20 co n taa i nan t s a sso c iate d wi t h t h e

2 1 Grovela nd we lls No. 1 a n d 2.

22 "Please comment on wh y the

23 E.P.A. as recently as July 2nd , '91 in

24 the E.P.A. Environmental News Press

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Release refers to the A . W. Chesterton

Company as a "likely source of

contaminationw in relation to the

closing of the Grovela nd wells No. 1

and 2; when (1) Chesterton has

used or stored the well c ontaminant ;

(2) the E.P.A. remedial investigation

determined that the co nt amination was

confined t o Chesterto n property

10 boundary ; (3) t h e E.P.A. co ns i der ed

11 Che s terton property aA a separate

12 r e'!l eclial unit ; and ( 4) t he E . P.A . ' s

13 reaediation is to treat Che s t e rton

separately u~der RCRA .

15 "If you n ee d clarification to

16 this request, please contac t ' me at

17 (617) 438-7000 extension 2309." I thank

18 you for t h e opportunity to speak and I

19 would like to offer you written copies.

20 MR. NAPARSTEK: Thank you,

21 Linda.

22 The second speaker that I ha ve

23 subaitted on a card is David Argyros .

24 KR. ARGYROS: Ky name is Dave

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Argyros . I'm an environmental engineer

by background . I've also been a

Chesterton employee for the past 11

years and familiar with t he Groveland

Well problem, a member of the town and

meaber of the aquifer protection

coaaittee for several years .

My comments are in regards to

the proposal from the point of view of

10 a U.S. citizen and taxpayer and someone

11 who has been a taxpayer and may have to

12 ulti aately f oot the bi~l ' t or the

13 proj~c t. My c oaaent s are i n regards to

14 tvo areas.

15 The first are t he treating

16 plant . Given that the town Well, No.

17 1, the primary town well is currently

18 supplying safe drinking water a nd that

19 the area surrou nd ing well No. 1 is no

20 longer contaminated due to the natural

21 flushing and the controlled puaping and

22 also that the . natural flow of the

23 contaainant pluae is not directly

24 towards well No . 1, it should be

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c on cl uded that groundwater monitoring,

co n trol p ump ing and limited well-head

treatment such as the c urrent carbon

polishing and institutional controls

would be effective in assuring

continued safe drinking water supply

for the town.

Also, _ the fact that the

contaainant source has bee n discharging

10 i nto the Vall ey area for approximately

11 15 years a n d that it cu rrently

12 continues to discharge into tha t a r ea

~ 13 and that t he natural migration of t hat ~

14 pluae is along the brook a nd towards

15 the river and a lso given that t h ere is

16 a high rate of tra n sitivity in the

17 sandy soils, I would also like to point

18 out that t he majority of the

19 contaminants within that entire

20 contaminated 75 acre plume, more than

21 80 percent of that entire

22 contamination, is confined to a

23 relatively small area near the Valley

24 site, that area is roughly l / 20th or


29

five percent of the total v o lume of the

plume contains 80 percent of the

contamination where those

concentrations near the Valley site are

approximately one thousand times higher

than the majority of the pluae.

Considering now seve~al facts;

one that the cost of treatment, cost of

the treatment plant are proportional to

10 the v o lume of water that you are going

11 t o c ap t u re a nd t r e a t; also t h at t h e

12 di s rupt i on to the t own 's peop l e and th e

13 town i t s elf fro a e xtraction we ll &,

14 piping a y a t aa , pu a ps , t ank s , e tc., that

15 i s a l s o propo r t i on a l t o t he v olu a e o f

16 wat er that y ou a r e g o i n g t o be p u mp ing

17 a nd t r e a ti ng . Ho wever, t h e c on ta mi n a n t

1 8 red u ction and removal and destruction

19 of contaminants is not proportional to

20 the volume of water as nearly as much

21 as it is proportional to the

22 concentrations of the contaainated

23 water that you are pumpinq out and that

24 is if you pump out at a small quantity -I M.A. TOROSIAN ' ASSOCIATES, INC.

30

of gr~undwater contaminated at a

thousand parts per billion , you will

g e t mu c h mo re tr e atme n t t han a greater

quan ti t y o f water a t five pa r ts per

bi l lion.

For these reaso ns, it

s hould b e c onclud e d th at f or max im um

e ffic i ency, c o s t e ff ec t iv en e s s , a nd a

minimum disrupt i on to the town

10 treatment efforts themsel ves should be

11 focuaed at eliminating the source area

12 where 80 percent of t~e contamination

13 is c oncentr a t ed a nd that is five

percent of the area and voluae,

15 If you were to do this, if y ou

16 were to focus your efforts not on the

17 entire size of the plume but on that

18 five percent area where it is

19 concentrated , you could roughly reduce

20 you r tre a tment p lan t i n th e vic in ity o f

21 1 / lOth t he p r opo s ed size a n d a l so

2 2 red u ce your costs from ei9ht million'

23 do l lars dow n to a much smaller and

2 4 reasonable level. You won't be


31

10

11

12

13

14

15

16

17

18

19

2 0

21

22

23

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treating the entire 360 million gallons

contaminated water. You would be

treating roughly 18 million gallons, 12

million gallons of highly contaminated

water.

Also, because of the smaller

size of the system needed to treat that

higher contaminated but smaller volume,

it may be more practical to use a

different type treatment method such as

air stripping alone with the carbon

capture. It might be even poasib~e to

uae the air stripper that waa once at

No. 1 when the levels we re higher

there.

In summary, to summarize my

comments to E.P.A.'s proposal, it is

that in your proposed clea ' nup plan, you

evaluated several widely different

alternatives from do nothing

alternative to alternatives which

involved complete plume extract i on.

There was no evaluation of an

alternative that was in between whi c h

M.A. TOROSIAN ' ASSOCIATES , INC .

0

32

woul d seem to be t h e most pr a ctical.

And that alternative which should be

evaluated in detail involves basically

the capture and the treatment of the

highly contaminated head portion of the

plume which is continuing to migrate

off the Valley site. That treatment of

the smaller highly conta minated area at

a mu ch l o wer c o st c o abined with the

1 0 instit ut io n al a n d mon itori ng controls

11 at the well head a nd throughout t h e

12 re s t of t he p l u a e s hou l d be abl e to

13 tr , at the co n ta a ination, s top th e

14 s o urce . An d d u ri n g that ti•e that t h e

15 head of the p lu ae o r t he highl y

16 conta a inat e d por tio n i s b e ing t r ea t e d ,

17 t he rea ain i ng 9 5 per ce nt o f th e pl u me

1 8 with t h e 2 0 perce n t of the

19 c o ntamination will naturally dissipate

20 on its own. The hiqh transivity of the

21 soils there, I think the water flow is

22 that of about a foot per ~ay combined

23 with the fact that it is basically

2 4 discharqinq towards the Merrimack and


33

valley would dissipate the less

concentrated but larger size of that

plume probably well within the ti~e

that it wo uld take you to treat the

highly coqcentrated portion. In that

majority, that large size plume, the 95

percent that is less contaminated,

there may only be 120 gallons of the

solvent or in the order of 800 pounds

10 of material that would actually not be

11 captured a nd would be left to naturally

1~ decrease.

13 That suaaarizes a y c o aaent i n

14 relation to the tow n' s ayatea itself or

15 the proposed treatment i t se lf . It is

16 to evaluate a practical alternative

17 somew h e re in between do nothing a nd

18 clean up the entire 360 mi.llion gallon

19 plume.

~0 My second comme nt , again, as a

~1 taxpayer, who may some day foot part . of

~2 the bill for this project involves just

2 3 briefly looking through the costs of

2 4 the sample program outlined in the

H. A. TOROSIAN & ASSOCIATES, INC.

rep o rt a n d the nUmbers we r e s o rt of

shocking, au , prisinq to me. For

example, in alternative No. 2, it

indicates eight groundwater samples for

the sampling. For the cost of sampling

itself, the eight samples four times a

year, the cost was $8,000 baaed upon 24

aa n hours per sampling, plus travel,

l i v i ng a n d t h e s h ippi ng ex p e n ses. The

10 a n a l ysis of those, t h ere wo ul d be 40

11 a a a pl ea a y ear would b e $ 20 , 000 and t h e

12 reporting, 20 man hours to produ c e a

13 report, plus othe r direct coats was0 14 approximately 4, 000 a year roughl y

15 looking at $ 32,000 a yea r to pull ei ght

16 ground wa t e r s ampl es fo ur t i mes a day

17 a nd produc e a repor t . I t may be mo re

1 8 c o st e f f e ctive rat h er t h a n E. P.A .

1 9 se nd ing so me bo dy o u t and p u tting thea

20 In the hotel to take the samples to

21 contract with a private agency, private

22 testinq lab with the E. P. A., a

23 certified E , P. A. lab a nd simply putting

24 them on a rotating scheduling to pull


35

saa ples an d produce a report. The cost

s houl d be approximately half or to a

quarter the costs contained in the

report.

So that summarizes my second

coament. Again, cost associated one.

Simply look at the cost of private

contracting pulling the sa mp les.

Sho uld be sig n ificantly less. Thank

10 you ve ry much .

11 ftR , NAPAR ST Ek: Than k you,

12 Mr . Argyroa . Okay.

J 13 Those are the only tvo people

14 that have subaitted cards. Are t her e

15 any other s peakers that would like t o

16 a ubait a coaaent a t this time?

17 Okay. Well , if there are no

18 others t hat would like to make a

19 statement, I'll close the h earing. Let

20 me just remind you again that the

21 deadline to submit written comments is

22 September 9th. All comments must be

23 postmarked or hand-delivered to the

24 E.P.A. at that time. I thank you for


0 coainq and for y our

tonight. Thank you.

(Whereupon,

concluded at

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participation

the hearing

8:05p.m .)

M.A. TOROSIAN ' ASSOCIATES, INC .

1 ENVIRONftENTAL PROTECTION AGENCY · IN RE: 216 Ch esterton propert y does not appear to 17 b e...

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Transcript of 1 ENVIRONftENTAL PROTECTION AGENCY · IN RE: 216 Ch esterton propert y does not appear to 17 b e...