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EDWARD J MARKEY 7Tll DIITIIICT MASIACHUiml

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COOIliiATION IN EUIIOfE March 21 1989

Barbara Newman Remedial Project Manaqer us Environmental Protection Aqency Reqion I Waste Manaqement Division (HRS-CAN 3)JFK Federal BuildinqBoston MA 02203-2211

Dear Ms Newman

Attached are my comments on EPAs proposed cleanup plan tor Wells G and H Superfund Site in Woburn Massachusetts

SincerelyI

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COMMENTS ON THE ENVIRONMENTAL PROTECTION AGENCYS

Proposed Plan - EPA Region I Superfund ProgramWells G and H Superfund Site

Woburn Massachusetts

submitted byus RepresentatiVe Edward J Markey

Marchmiddot 21 1989

Introduction

j I welcome at long last EPAs attention to the serious problemof contamination at the Wells G and H Site The Site has been a recognized health hazard to the community since May of 1979 when Woburn police discovered 184 fifty-five gallon drums of industrial waste abandoned on a vacant lot on Mishawum Road inthe vicinity of Wells G and H Three years later in 1982 theSite made the EPAs National Priorities List

Seven years have passed without action by the responsibleauthorities I hope this proposed plan represents the beginning of a sustained effort to restore this site to a safecondition

General

The tecbnoloqies proposed for cleaning up volatile organiccompounds (VOCs) and non-voc contaminants at the Site are appropriate for the identified contaminants However the data are limited given the size of this Site which leads to the concern ~at EPAs proposed plan will not clean All healthshythreatening contaminants at Wells G and H Site More completeanalysis should be provided Furthermore before being removed from the National Priorities List any separate operable units (for example Aberjona River sediments) must be remediated

Specifics

Positive aspects of the proposed plan

Cleanup goals are among the most stringent anywherein the nation to date for many of the chemicals at the site

Permanent treatments technologies are proposed for

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Comments Wells G and H Superfund Site Page 2

soil decontamination

Air released from the soil during in situ volatilization will be treated

Shortcomings of the proposed plan

Given the seriousness of the observed levels of contamination and areal extent of the Wells G and H Superfund Site the volume of soil treated seems extremely small The Site is 330 acres in size yetcleanup will treat only 7600 cubic yards (cy) for voc contaminations and will incinerate only 1900 cy of soil contaminated with a mix of polychlorinatedbiphenyl$ (PCBs) polycyclic aromatic hydrocarbons(PAHs) pesticides and vocs The total volume of treated soil (9500 cy) is equivalent to just a fraction of an inch spread across the entire Site

Data in tite feasibility study (FS) do not rule out the possibility that hazardous contamination is moreJ extensive than the plan proposes to address The data base in the FS is small and conclusions are drawn based largely upon computer models Note 1 of Table 3-1 (page 3-7) seems to acknowledge inadequacyof tile data set

Additional water and soil samples should be collected to ensure that all healtil hazards are identified

EPA established clean-up goals for selected contaminants that contributed to the m~jority (pg 7 of proposed plan) of potential risk at the Site Contamination levels of major contaminants ar so great that targeting only major contaminants guarantees neither safe drinking water for Woburn residents nor clean soil The clean-up goal should be to remove all risk

The sediment samples in the Aberjona River and alongthe river banks indicate that contamination is widespread The proposed plan points out that the nature and extent of contamination has not been fullydetermined

Remediation of the sludge and debris at the Wildwood property should be included in tile clean up

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Comments Wells G and H Superfund Site bull

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Finally the EPA must follow through and ensure that all responsible parties meet their obligation as spelled out in middotthe Record of Decision that results If for some unforseen reason the plan is approved but requires modification then further public comment must be permitted

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1. barcode 564128
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Comments Wells G and H Superfund Site Page 2

soil decontamination

Air released from the soil during in situ volatilization will be treated

Shortcomings of the proposed plan

Given the seriousness of the observed levels of contamination and areal extent of the Wells G and H Superfund Site the volume of soil treated seems extremely small The Site is 330 acres in size yetcleanup will treat only 7600 cubic yards (cy) for voc contaminations and will incinerate only 1900 cy of soil contaminated with a mix of polychlorinatedbiphenyl$ (PCBs) polycyclic aromatic hydrocarbons(PAHs) pesticides and vocs The total volume of treated soil (9500 cy) is equivalent to just a fraction of an inch spread across the entire Site

Data in tite feasibility study (FS) do not rule out the possibility that hazardous contamination is moreJ extensive than the plan proposes to address The data base in the FS is small and conclusions are drawn based largely upon computer models Note 1 of Table 3-1 (page 3-7) seems to acknowledge inadequacyof tile data set

Additional water and soil samples should be collected to ensure that all healtil hazards are identified

EPA established clean-up goals for selected contaminants that contributed to the m~jority (pg 7 of proposed plan) of potential risk at the Site Contamination levels of major contaminants ar so great that targeting only major contaminants guarantees neither safe drinking water for Woburn residents nor clean soil The clean-up goal should be to remove all risk

The sediment samples in the Aberjona River and alongthe river banks indicate that contamination is widespread The proposed plan points out that the nature and extent of contamination has not been fullydetermined

Remediation of the sludge and debris at the Wildwood property should be included in tile clean up

-~ -shy

middot

Comments Wells G and H Superfund Site bull

I

bullf

Page 3 bull

Finally the EPA must follow through and ensure that all responsible parties meet their obligation as spelled out in middotthe Record of Decision that results If for some unforseen reason the plan is approved but requires modification then further public comment must be permitted

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1. barcode 564128
2. barcodetext SDMS Doc ID 564128

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Comments Wells G and H Superfund Site bull

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Page 3 bull

Finally the EPA must follow through and ensure that all responsible parties meet their obligation as spelled out in middotthe Record of Decision that results If for some unforseen reason the plan is approved but requires modification then further public comment must be permitted

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1. barcode 564128
2. barcodetext SDMS Doc ID 564128