IHnvMnNMlmMttM 

SDMS DocID 457977 

THIR D FIVE-YEAR REVIE W REPORT!' -rrfcpd Records Center 

F O R ^' ' K: Mot-bvioQ-p rclSJS. 

NORWOO D PCBS SUPERFUND SITE? '/'^K : "g 3 

Norwood, Massachusetts 

December 2009 

Prepared by: 

United States Environmental Protection Agency 

Region 1 

Boston, Massachusetts 

'11 

Approved by: 

James T. Oy^ens HI, Difectbr 

Office of Site Remediation and Res^ration 

USEPA, Region 1 

Date: /Z-^/t/ / 
Norwood PCBs Superfund Site 

Five-Year Review Report December 2009 

TABLE OF CONTENTS 

EXECUTIVE SUMMARY ES-1 

1.0 INTRODUCTION 1-1 

1.1 PURPOSE 1-1 

1.2 AUTHORITY FOR CONDUCTING THE FIVE-YEAR REVIEW 1-1 

2.0 SITE CHRONOLOGY 2-1 

3.0 BACKGROUND 3-1 

3.1 SITE DESCRIPTION 3-1 

3.2 SITE HISTORY 3-1 

3.3 INITIAL RESPONSE - PRE-ROD CLEAN UP ACTIVITIES / REMOVAL ACTIONS 3-2 

3.4 BASIS FOR TAKING ACTION 3-2 

3.4.1 Summary of Remedial Investigations Results 3-2 

4.0 REMEDIAL ACTIONS 4-1 

4.1 REMEDY SELECTION 4-1 

4.1.1 Remedial Action (RA) Objectives: Soil and Sediment 4-1 

4.1.2 Remedial Action Objectives: Groundwater 4-2 

4.1.3 Remedial Action Objectives: Meadow Brook Sediment 4-3 

4.1.4 Remedial Action Objectives: Drainage System and Roof Decontamination & 

Grant Gear Machinery/Equipment and Floor Surfaces Decontamination 4-3 

4.2 REMEDY IMPLEMENTATION 4-4 

4.2.1 Source Control and Soil and Sediment / Cap and Cover 4-4 

4.2.2 Groundwater Treatment 4-5 

4.2.3 Meadow Brook Restoration 4-6 

4.2.4 Grant Gear Building Demolition 4-7 

4.2.5 Redevelopment 4-7 

4.3 OPERATION AND MAINTENANCE 4-7 

4.3.1 Cap/Cover 4-7 

4.3.2 Groundwater Treatment 4-7 

4.3.3 Meadow Brook Restoration 4-8 

5.0 PROGRESS SINCE THE LAST REVIEW 5-1 

5.1 PROTECTIVENESS STATEMENT FROM PREVIOUS FIVE-YEAR REVIEW 5-1 

5.1.1 2004 Protectiveness Statement 5-1 

5.2 PROGRESS SINCE PREVIOUS FIVE-YEAR REVIEW 5-1 

5.3 STATUS OF RECOMMENDATIONS FROM PREVIOUS FIVE-YEAR REVIEW 5-2 

6.0 FIVE-YEAR REVIEW PROCESS 6-1 

6.1 ADMINISTRATIVE COMPONENTS 6-1 

6.2 COMMUNITY NOTIFICATION AND INVOLVEMENT 6-1 

6.3 DOCUMENT REVIEW 6-1 

6.4 DATA REVIEW 6-2 

6.4.1 Groundwater Monitoring Data 6-2 

6.4.2 Surface Water/Sediment 6-3 
Norwood PCBs Superfijnd Site 

Five-Year Review Report December 2009 

6.4.2 Risk Assessment Data 6-5 

6.5 SITE INSPECTION 6-6 

6.6 INTERVIEWS 6-7 

7.0 TECHNICAL ASSESSMENT 7-1 

7.1 QUESTION A: Is THE REMEDY FUNCTIONING AS INTENDED BY THE DECISION 

DOCUMENTS? 7-1 

7.2 QUESTION B: ARE THE EXPOSURE ASSUMPTIONS, TOXICITY DATA, CLEAN UP LEVELS, 

AND REMEDIAL ACTION OBJECTIVES USED AT THE TIME OF REMEDY SELECTION STILL 

VALID? 7-1 

7.3 QUESTION C: HAS ANY OTHER INFORMATION COME TO LIGHT THAT COULD CALL INTO 

QUESTION THE PROTECTIVENESS OF THE REMEDY? 7-2 

7.4 ARARS REVIEW 7-2 

8.0 ISSUES 8-1 

9.0 RECOMMENDATIONS AND FOLLOW-UP ACTIONS 9-1 

10.0 PROTECTIVENESS STATEMENTS 10-1 

10.1 PROTECTIVENESS 10-1 

11.0 NEXT REVIEW 11-1 

12.0 REFERENCES 12-1 
Norwood PCBs Superfimd Site 

Five-Year Review Report December 2009 

LIST OF TABLES 

Table 2-1 Site Chronology 2-1 

Table 3-1 Norwood PCBs Superfund Site List of Contaminants 3-3 

Table 5-1 Issues & Recommendations from Previous Review 5-3 

Table 6-1 Maximum Observed Groundwater Analytical Results 6-4 

Table 6-2 Site Investigation Summary 6-6 

Table 8-1 Issues 8-1 

Table 9-1 Recommendations and Follow-up Actions 9-1 

in 
Norwood PCBs Superfijnd Site 

Five-Year Review Report December 2009 

LIST OF APPENDICES 

APPENDIX A Site Maps 

APPENDIX B Tables Documenting ARARs 

APPENDIX C Interview Notes 

APPENDIX D Photos Documenting Site Conditions 

APPENDIX E Five-Year Review Site Inspection Checklist 

IV 
Norwood PCBs Superfimd Site 

Five-Year Review Report December 2009 

ARAR 

AWQC 

CERCLA 

DOT 

FS 

GSA 

GZA 

IRM 

MassDEP 

MCP 

NCP 

NPL 

NRWQC 

O&M 

OU 

PAH 

PCB 

PPA 

ppm 

PRP 

RA 

RBAL 

RCRA 

RI 

ROD 

SARA 

SVOC 

TAT 

TBC 

TCB 

TCE 

TSCA 

USAGE 

USEPA 

UST 

VOC 

ABBREVIATIONS AND ACRONYMS 

Applicable or Relevant and Appropriate Requirement 

Ambient Water Quality Criteria 

Comprehensive Environmental Response, Compensation, and Liability Act 

Department of Transportation 

Feasibility Study 

General Services Administration 

GZA Geo Environmental, Inc. 

Interim Remedial Measure 

Massachusetts Department of Environmental Protection 

Massachusetts Contingency Plan 

National Contingency Plan 

National Priorities List 

National Recommended Water Quality Criteria 

Operation and Maintenance 

Operable Unit 

Polyaromatic Hydrocarbon 

Polychlorinated Biphenyl 

Prospective Purchaser Agreement 

part per million 

Potentially Responsible Party 

Remedial Action 

Risk Based Action Level 

Resource Conservation and Recovery Act 

Remedial Investigation 

Record of Decision 

Superfund Amendments and Reauthorization Act 

Semi-Volatile Organic Compound 

Technical assistance team 

To Be Considered 

Trichlorobenzene 

Trichloroethylene 

Toxic Substances Control Act 

U.S. Army Corps of Engineers 

United States Environmental Protection Agency 

Underground Storage Tank 

Volatile Organic Compound 

cubic yards 
Norwood PCBs Superfimd Site 

Five-Year Review Report December 2009 

EXECUTIVE SUMMARY 

The United States Envirormiental Protection Agency, Region 1 (USEPA) has conducted a Five-Year 

Review of the Remedial Actions implemented at the Norwood PCBs Superfund Site (Site) in Norwood, 

Massachusetts, in compliance with the Comprehensive Envirormiental Response, Compensation, and 

Liability Act (CERCLA), 42 U.S.C. §§ 9601 et seq. USEPA conducted this review between May 2009 

and December 2009. This is the third Five-Year Review for the Site. The triggering action for the first 

Five-Year Review was the start of remedial construction in 1994. Subsequent reviews have been 

conducted every five years. The purpose ofthe Five-Year Review is to evaluate whether response actions 

and original performance standards remain protective of human health and the environment. 

Remedial activities at the Site were implemented in three phases, with the third phase (Phase 3) consisting 

of an "A" and "B": Phase 1 - groundwater treatment; Phase 2 - building demolition; Phase 3 A - cap and 

cover; and Phase 3B - Meadow Brook restoration. On January 11, 1996, construction ofthe groundwater 

treatment facility (Phase 1) was completed. On February 6, 1997, the building demolition (Phase 2) was 

completed. On August 11, 1998, the Cap and Cover (Phase 3A) was completed. On August 11, 1999, 

Meadow Brook restoration (Phase 3B) was completed. The groundwater treatment facility operated from 

January 1996 until June 2000 at which time it was shut down; quarterly groundwater monitoring 

continued until October 2002. At this time, the clean-up goals published in the 1989 Record of Decision 

(ROD) and the 1996 Amended ROD had not been met; however, new clean-up goals based on a 

reclassification of the groundwater by the Commonwealth of Massachusetts (the Commonwealth) were 

established in a 2005 Explanation of Significant Differences (ESD). These have been met and routine 

monitoring has been [and will continue to be] performed to confirm they continue to be met. In March 

2008, institutional controls (ICs) in the form of a Grant of Environmental Restriction and Easement 

(Grant) were recorded for the Laham {i.e., the former Reardon) property, the area of the Site 

encompassing former industrial operations. Subsequent to their recording, EPA and MassDEP approved 

a Redevelopment Work Plan (RWP) thus allowing a commercial retail redeveloper to complete their 

construction of 56,000-square feet of commercial/retail space on the property. In the adjacent. Town of 

Norwood-owned Meadow Brook parcel within the Site, land use restrictions required under a Consent 

Decree with the Town (Book No. 25628, Page No. 534) have been recorded at the Norfolk County 

Registry of Deeds. Moreover, copies of Town Master Plans (sewer and water) have been annotated to 

alert any future public works project of the existence of property use restrictions within the Meadow 

Brook parcel due to Site contamination. 

The remedy at Norwood PCBs Superfund Site protects human health and the environment through 

meeting groundwater clean-up goals, the establishment of institutional controls, and the maintenance of 

remedy infrastructure concuretnly and during redevelopment of the Site. In order for the remedy to 

remain protective, the Operation & Maintenance (O&M) Plan and Environmental Monitoring Plan (EMP) 

must be updated to reflect changes in site conditions as a result of the redevelopment. Periodic inspection 

ofthe Site and abutting Meadow Brook will be conducted to insure compliance with the recently recorded 

ICs. 

ES-1 
Norwood PCBs Superfimd Site 

Five-Year Review Report December 2009 

Five-Year Review Summary Form 

SITE IDENTIFICATION 

Site name (from WasteLAN): Norwood PCBs 

USEPA ID (from WasteLAN): MAD980670566 

Region: 1 State: iVIA City/County: Norwood/Norfollc County 

NPL status: Final 

Remediation status (choose all that apply): Operating 

IVIultipie OUs?* No Construction completion date: September 1999 

Has site been put into reuse? Yes 

REVIEW STATUS 

Lead agency: USEPA 

Author name: Dan Keefe and Sham us Keohane 

Author title: Remedial Project Manager Author affiliation: USEPA 

Review period: 05/09 to 12/09 

Date(s) of site inspection: 7/8/09 

Type of review: 

fl Post-SARA , Pre-SAFIA , NPL-Removal only 

Review number: 3 

Triggering action: 

Completion of second Five Year Review 

Triggering action date (from WasteLAN): 2004 

Due date (five years after triggering action date): 12/30/09 

ES-2 
Norwood PCBs Superfimd Site 

Five-Year Review Report December 2009 

Five-Year Review Summary Form (cont) 

Issues: 

1) The existing O&M and EMP are out-of-date as a result of redevelopment. 

2) Punch list items associated with redevelopment need to be completed. 

Recommendations and Follow-up Actions: 

1) Complete revisions to the O&M and EMP that accurately reflects the post-redevelopment changes. 

2) Completed all pimch list items associated with the redevelopment within the 2 years period that was 

contemplated in the approved Redevelopment Work Plan (i.e., by March 2010). 

Protectiveness Statement: 

The remedy at Norwood PCBs Superfund Site remains protective of human health and the environment because 

2005 revised groundwater clean-up goals continue to be met, remedial infrastructure is being maintained, the 

Redevelopment Work Plan has been successililly completed (pending completion of punch list items), and 

institutional controls are in place. 

Other comments: 

The existing Prospective Purchaser Agreement with the Landowner needs to be amended to reflect revised 

institutional control obligations under the Grant to the Commonwealth. 

ES-3 
Norwood PCBs Superfund Site 

Five-Year Review Report December 2009 

1.0 INTRODUCTION 

1.1 PURPOSE 

The purpose of this Five-Year Review is to determine whether the remedy at the Norwood PCBs 

Superfund Site (Site) is protective of human health and the environment. In addition, this report identifies 

issues found during the review and recommendations to address them. The U.S. Environmental 

Protection Agency, Region 1 (USEPA) prepared this Five-Year Review pursuant to Section 121 ofthe 

Comprehensive Environmental Response, Compensation, and Liability Act (CERCLA), 42 U.S.C. § 9631 

and the National Contingency Plan (NCP), 40 C.F.R. Part 300. CERCLA Section 121 states: 

If the President selects a remedial action that results in any hazardous substances, pollutants, or 

contaminants remaining at the site, the President shall review such remedial action no less often than 

each five years after the initiation of such remedial action to assure that human health and the 

environment are being protected by the remedial action being implemented. In addition, if upon such 

review it is the judgment of the President that action is appropriate at such site in accordance with 

section [104] or [106], the President shall take or require such action. The President shall report to the 

Congress a list of facilities for which such review is required, the results of all such reviews, and any 

actions taken as a result of such reviews. 

The USEPA interpreted this requirement further in the NCP; 40 CFR §300.430(f)(4)(ii) states: 

If a remedial action is selected that results in hazardous substances, pollutants, or contaminants 

remaining at the site above levels that allow for unlimited use and unrestricted exposure, the lead Agency 

shall review such action no less often than every five years after the initiation of the selected remedial 

action. 

1.2 AUTHORITY FOR CONDUCTING THE FIVE-YEAR REVIEW 

Pursuant to Section 121(c) of CERCLA, 42 U.S.C. § 9631(c), and 40 C.F.R. §300.430(f)(4)(ii) ofthe 

NCP, Five-Year Reviews are required at sites for which, upon attainment of the Record of Decision 

(ROD) clean-up levels, there are remaining hazardous substances, pollutants, or contaminants remaining 

on the site that will not allow for unlimited use and unrestricted exposure. Since the ROD for this Site 

was signed in 1989, and because wastes remaining in the capped on-site landfill and within the adjacent 

Meadowbrook Parcel will not allow for unlimited use, fiiture Five-Year Reviews for this Site will 

continue to be required. 

This review reassesses Applicable or Relevant and Appropriate Requirements (ARARs) for substances 

identified as contaminants of concern, and considers whether ARARs have been changed such that the 

remedy is no longer protective. The review also considers pending or actual changes in zoning or land 

uses that could undermine the remedy and the need for institutional controls at and near the Site. This 

review has been performed in accordance with USEPA's June 2001 Comprehensive Five-Year Review 

Guidance. 

1-1 
Norwood PCBs Superfijnd Site 

Five-Year Review Report December 2009 

2.0 SITE CHRONOLOGY 

Major site activities are summarized in Table 2-1 

Table 2-1 

Site Chronology 

06/83 

06/83 

08/83 

06/86 

05/87 

09/89 

04/94 

11/94 

01/96 

03/96 

05/96 

02/97 

04/97 

10/97 

08/98 

08/99 

09/99 

12/99 

04/00 

06/00 

05/01 

05/02 

12/04 

12/04 

02/05 

07/05 

10/06 

05/07 

03/08 

03/08 

05/08 

11/08 

03/09 

09/09 

12/09 

Initial discovery of contamination on the property 

Initial Removal Actions begin 

Removal Actions complete 

Site listed on National Priorities List (NPL) 

Remedial Investigation/Feasibility Study (RI/FS) complete 

Record of Decision (ROD) signed 

Remedial Design complete 

On-site construction begins for first phase, groundwater treatment plant 

Groundwater treatment plant construction complete (Phase 1) 

Operation and Maintenance of treatment system begins 

ROD Amendment Signed 

USEPA and MADEP performed final inspection of building demolition (Phase 2) 

PRP initiated Cap/Cover activities 

Meadow Brook Restoration begins 

USEPA and MassDEP performed a final inspection of Cap/Cover (Phase 3 A) 

USEPA and MassDEP performed a final inspection of Meadow Brook Restoration 

- Phase 3B 

Construction Completion designation achieved 

First 5-Year Review complete 

Final Supplemental Risk Assessment submitted 

Groundwater treatment system temporarily shut down 

Groundwater Use and Value determination prepared by MassDEP 

Final Amendment to the Risk Assessment submitted 

Final Cap & Cover Operation and Maintenance Plan approved 

Second Five-Year Review complete 

ESD signed memorializing new Groundwater Clean-Up Levels 

28"" Comprehensive Groundwater Monitoring Report 

Redevelopment Work Plan Submitted 

Wastewater Treatment Plant Decommissioned 

ICs(Grant) recorded for the Laham property 

Redevelopment Work Plan Approved 

Redevelopment Begins 

Redevelopment substantially completed 

ICs (Notice) recorded for Town-owned Meadow Brook parcel 

Final Close-out Report complete 

Third Five-Year Review complete 

2-1 
Norwood PCBs Superfijnd Site 

Five-Year Review Report December 2009 

3.0 BACKGROUND 

3.1 SITE DESCRIPTION 

The Norwood PCBs Superfimd Site (referred to as the "Site") is located in Norwood, Massachusetts 

approximately 14 miles southwest ofthe City of Boston. See Figure 1 for a Site Locus Plan and Figure 2 

for a Site Plan. Historically, the site encompassed approximately 20 acres consisting of several parcels of 

land, including industrial/commercial properties and associated parking areas in an industrial/commercial 

area adjacent to a residential area. To the north, the Site is bordered by residential properties on Audubon 

Road; to the east by the heavily commercial U.S. Route 1 and the Dean Street access road; to the south by 

Dean Street; and to the west by residential properties on Pellana Road. Properties along U.S. Route 1 in 

the vicinity of the Site are primarily commercial, and include automobile dealerships, an equipment rental 

business, a pet shop, restaurants, and gasoline stations. A pharmacy, an auto parts store, a Direct Tire 

dealership, and a Mobil gasoline station are located to the southeast of the Site, near the Dean Street 

access road and Route 1. A shopping plaza, a car wash, and two restaurants are located across Dean 

Street to the south of the Site. The northern portion of the Site consists of a portion of Meadow Brook 

surrounded by a small wooded area. Meadow Brook is a shallow stream approximately 6 to 8 feet wide 

and 6 to 12 inches deep. The Brook serves as a drainage way for over 900 acres of densely developed 

land and discharges eastward into the Neponset River approximately 1,600 feet downstream of the Site. 

3.2 SITE HISTORY 

Contamination at the Site originated from disposal practices of the parties who owned the property or 

operated businesses on the Site. The former on-site building was constructed in 1942 by Bendix Aviation 

Corporation, which produced navigational control systems and conducted other electronic research for the 

U.S. Navy. In October 1947, the land was purchased by Tobe Deutschman Corporation, which 

manufactured electrical equipment at the Site, including capacitors and transformers. The property was 

purchased in October 1956 by Comell-Dubilier Electronics, Inc., which also manufactured electrical 

equipment at the facility. In January 1960, the property was briefly owned by Maryvale Corporation, and 

was then purchased by the Friedland brothers. The Friedland brothers leased the property to Federal 

Pacific Electric Company, which held the lease on the property until October 1979. During the period 

from 1960 to 1979, Federal Pacific Electric Company operated a business at the Site, and sublet portions 

of the facility to Comell-Dubilier Electronics, Inc. and to Arrow Hart Corporation, which also 

manufactured electrical equipment at the facility. In 1979, the Site was subdivided. The northeastern 

portion of the Site, approximately 9 acres, was purchased by Grant Gear Realty Trust, which leased the 

facility to Grant Gear Works, Inc., to produce gears for industry. The southern and western portions of 

the Site, approximately 16 acres, were purchased by Paul Birmingham, Paul Reardon, and Jack Reardon 

who further subdivided the property into seven lots and added a new private way, Kerry Place. 

On April 1, 1983, the MassDEP, then known as the Massachusetts Department of Environmental Quality 

Engineering, received a telephone call from a citizen living on Pellana Road reporting past industrial 

waste dumping and contamination in the then vacant field of Kerry Place between Pellana Road and the 

Grant Gear property. As a result of this call, an initial field mvestigation by MassDEP was conducted. 

On April 6, 1983, MassDEP collected soil and sediment samples. The initial MassDEP investigations 

confirmed the presence of PCBs. The MassDEP immediately moved to restrict public access to the field 

area and marked areas within the Grant Gear fence to alert workers of the possible danger. Because of 

limited state fimds, the MassDEP requested USEPA involvement. Subsequently, USEPA contractors 

assisted MassDEP with the collection of confirmatory samples of the oil-stained areas along the western 

fence line and in other areas on both the Grant Gear and Reardon properties. Based on these findings, it 

3-1 
Norwood PCBs Superfund Site 

Five-Year Review Report December 2009 

was determined that an emergency removal action was warranted to address soils outside the Grant Gear 

Property with PCB concentrations greater than 50 parts per million (ppm). 

Beginning June 23, 1983, the USEPA began removal of contaminated soils on the She. A total of 518 

tons of contaminated soil were removed and disposed of off-site. The soils were removed fi-om locations 

within Kerry Place and Grant Gear properties. Reported excavation depths were up to 30 inches. During 

the removal action, water samples taken from the storm drain system behind the Grant Gear Building 

indicated low levels of PCBs. The removal action was completed on August 5, 1983. In December 1983, 

the Site was further evaluated by USEPA and subsequently proposed for inclusion on the National 

Priorities List (NPL) on October 15, 1984. On June 10, 1986, the site was formally added to the NPL. 

Based on the preliminary findings, MassDEP implemented an Interim Remedial Measure (IRM) at the 

Site in January 1986. The IRM was considered necessary to limit access to areas of highest surface soil 

contamination within the fenced area of the Grant Gear Property. Specifically, a MassDEP contractor 

installed a cap over a 1.5-acre portion ofthe northwest and southwest comers ofthe Grant Gear Property. 

The contaminated surface soils were covered with a filter fabric liner and 6 inches of cmshed stone. The 

capped areas were enclosed with a 4-foot high wire mesh fence and the areas were delineated with yellow 

hazard tape. 

3.3 INITIAL RESPONSE - PRE-ROD CLEAN UP ACTIVITIES / REMOVAL 

ACTIONS 

The following Pre-ROD Removal Actions were performed at the Site 

1. Removal Action completed in the summer of 1983 by USEPA - 518 tons of contaminated soil 

were removed from locations within the Kerry Place and Grant Gear properties. 

2. Removal Action completed January 1986 by MassDEP - an IRM was implemented to limit access 

to areas of highest surface soil contamination by installing a cap over a 1.5-acre portion of the 

Grant Gear Property and fencing the capped areas. 

3.4 BASIS FOR TAKING ACTION 

The groundwater, soil, sediment, and surface water on and adjacent to the Site were found to be 

contaminated with volatile organic compounds (VOCs), polyaromatic hydrocarbons (PAHs), and PCBs. 

Health threats include direct contact with or accidental ingestion of contaminated groundwater or soil, as 

well as inhalation of airborne contaminants volatilized from groundwater. Remedial actions were also 

necessary to prevent fiiture migration of contaminants in groundwater. 

3.4.1 Summary of Remedial Investigations Results 

Remedial investigations at the Site revealed that contamination was present in sediment, soil, 

groundwater, surface water, and sludges. Table 1 presents the contaminants found on the Site, the media 

in which they were found, and the group to which the contaminant belongs. 

3-2 
Norwood PCBs Superfund Site 

Five-Year Review Report December 2009 

Table 3-1 

Nonvood PCBs Superfund Site 

List of Contaminants 

Contaminant Media Contaminant Group 

1,1,1 -Trichloroethane Groundwater, Sediment, Soil VOC 

1,2,4-Trichlorobenzene Groimdwater, Sediment, Soil SVOC 

1,2-Dichlorobenzene Groimdwater, Sediment, Soil VOC 

1,2-Dichloroethane Groundwater, Sediment, Soil VOC 

1,2-Trans-dichloroethylene Groundwater, Sediment, Soil VOC 

1,3-Diclilorobenzene Groimdwater, Sediment, Soil VOC 

1,4-Dichlorobenzene Groundwater, Sediment, Soil Base Neutral Acids 

Aroclor 1016 Groundwater, Sediment. Soil PCBs 

Aroclor 1254 Groimdwater, Sediment, Soil PCBs 

Aroclor 1260 Groundwater, Sediment. Soil PCBs 

Base neutral acids Groundwater, Sediment, Soil Base Neutral Acids 

Benzoic acid Groundwater, Sediment. Soil Base Neutral Acids 

Chlorobenzene Groundwater, Sediment. Soil VOC 

Chloroform Groimdwater, Sediment. Soil VOC 

PAH Groundwater, Sediment, Soil PAH 

PCBs Groundwater, Sediment. Soil PCBs 

Pentachloroethane Groundwater, Sediment Soil VOC 

Phenol Groimdwater, Sediment. Soil Base Neutral Acids 

Silver Groundwater, Sediment. Soil Metals 

Vinyl chloride Groundwater, Sediment Soil VOC 

Zinc Groimdwater, Sediment Soil Metals 

3-3 
Norwood PCBs Superfimd Site 

Five-Year Review Report December 2009 

4.0 REMEDIAL ACTIONS 

4.1 REMEDY SELECTION 

Under its legal authorities, the USEPA's primary responsibility at Superfund sites is to undertake 

Remedial Actions (RAs) that are protective of human health and the environment. In addition. Section 

121 of CERCLA establishes several other statutory requirements and preferences, including: 

• RAs, when complete, must comply with all Federal environmental and more stringent State 

environmental or facility siting standards, requirements, criteria, or limitations, unless a waiver is 

invoked. 

• Select RAs shall be cost-effective and utilize permanent solutions and altemative treatment 

technologies or resource recovery technologies to the maximum extent practicable; and a 

preference for remedies wherein treatment permanently and significantly reduces the volume, 

toxicity, or mobility ofthe hazardous substances. 

The ROD for the Norwood PCBs site was signed in September 1989. The 1989 ROD included pumping 

and treating contaminated groundwater, excavating and treating soils and sediments by solvent extraction, 

and decontaminating the Grant Gear building. Due to higher than anticipated costs for solvent extraction, 

an amendment to the ROD was published and signed in May 1996. The amended ROD included 

demolition of the Grant Gear building, excavation and consolidation of contaminated soils and sediments 

under an asphalt cap and cover areas, and restoration of Meadow Brook in conjunction with the Town of 

Norwood's flood control project within the area of the Site. Remedial ahematives at the Site were 

developed to be consistent with the NCP, 40 C.F.R. § 300.68(j), which states that the selected ahemative 

shall be cost effective; technologically feasible and reliable; and effectively mitigate and minimize 

damages to, and provide adequate protection of, public health, welfare, and the environment. 

4.1.1 Remedial Action (RA) Objectives: Soil and Sediment 

The RA objectives selected in the 1989 ROD to address contaminated soils and sediments at the Site are 

as follows: 

• Reduce risks posed by direct contact with soil contaminated with PCBs and PAHs. 

• Reduce risks posed by incidental ingestion of soils contaminated with PCBs and PAHs. 

• Minimize migration of VOCs to groundwater. 

The remedy selected in the 1989 ROD included soil and sediment excavation, treatment using solvent 

extraction, and on-site disposal. 

The USEPA issued a Request For Proposal (RFP) regardmg the soil/sediment solvent extraction portion 

of the remedy as outlined in the 1989 ROD. In 1995, the USEPA received a proposal for the 

implementation of this work; however, the cost greatly exceeded prior cost estimates. Also based upon 

that proposal, the USEPA believed that there would be difficulties in properly locating the appropriate 

solvent extraction equipment on the Site due to space constraints and safety issues. Based upon these 

mitigating factors, the USEPA determined that it was necessary to amend the remedy for the Site and a 

ROD Amendment was issued in 1996. 

The amended ROD proposed the excavation of high concentrations of chlorinated organic compounds to 

eliminate a continuous source of groundwater contamination, excavation and consolidation of PCB 

4-1 
Norwood PCBs Superfijnd Site 

Five-Year Review Report December 2009 

contaminated soil fi-om portions of the Grant Gear property and from other surrounding properties, 

including sediments fi-om the Meadow Brook, restoration of Meadow Brook consistent with the Town's 

flood control project, and finally cap and cover the consolidated contaminated soil and sediment. Cleanup levels for five main categories of PCB contaminated soil were set: 

Surficial soil on commercial/industrial properties: 40 parts per million (ppm) PCBs; 

Subsurface soil on commercial/industrial properties: 70 ppm PCBs; 

Surficial soil in wooded area north of Meadow Brook: 10 ppm PCBs; 

Subsurface soil in wooded area north of Meadow Brook: 50 ppm PCBs; 

Soils and sediment in Meadow Brook and its banks: 1 ppm PCBs 

4.1.2 Remedial Action Objectives: Groundwater 

The RA objectives selected in the 1989 ROD to address groundwater contamination at the Site are as 

follows: 

• To reduce, within a reasonable time frame, risks to workers posed by inhalation of airbome 

contaminants volatilized from groundwater. 

• To reduce risks to human health and the environment from current and fiiture migration of 

contaminants in groundwater. 

Groundwater at the Site is contaminated with PCBs, VOCs (such as trichloroethylene and vinyl chloride), 

and SVOCs. The 1989 ROD proposed that contaminated groundwater in the overburden and shallow 

bedrock aquifers would be collected by a barrier drain. The groundwater collection system would be 

designed to intercept contaminated groundwater both in the overburden aquifer that is moving toward 

Meadow Brook and in the shallow bedrock aquifer that, at the point of collection, would be discharging to 

the overburden aquifer. The barrier drain would be designed to collect contaminated on-site groundwater, 

but not draw in off-site groundwater and surface water. Contaminated groundwater collected would be 

treated by a groundwater treatment system, including the following treatment components: activated 

carbon, air stripping with vapor phase controls, and precipitation/filtration. 

The ROD Amendment did not change the plan to constmct the GWTP; however, it did change the method 

of contaminated groundwater collection, calling for a series of extraction wells in lieu of the barrier drain 

specified in the ROD and specified discharge of treated effluent to Meadow Brook rather than re-charge 

to the groundwater. The GWTP was operational in January 1996 and treatment continued until it was 

shut down in June 2000. 

In accordance with EPA's 1996 Final Ground Water Use and Value Determination Guidance, in May 

2001, MassDEP submitted a "low" use and value determination for the groimdwater at and in the vicinity 

of the Site. This determination was made based on the aquifer's classification as a low yield, nonpotentially drinking water source area, as well as the fact that nearby residential and commercial 

properties are supplied by public, municipal drinking water sources. 

As a result of MassDEP's "low" use and value determination, the contaminant exposure pathways and 

exposure assumptions used for the ROD were re-evaluated. Accordingly, supplemental risk assessment 

activities were initiated in 2001 and were completed in 2004. As the result of these assessments, revised 

groundwater clean-up levels, or risk-based action levels (RBALs), were calculated for the Site 

groundwater in March 2003. In issuing the 2005 ESD, EPA determined that those RBALs, which 

4-2 
Norwood PCBs Superfijnd Site 

Five-Year Review Report December 2009 

established standards protective for non-potable groundwater, would be the new groundwater clean-up 

levels for this Site. 

4.1.3 Remedial Action Objectives: Meadow Brook Sediment 

As per to the 1989 ROD, steps were taken to minimize the destmction, loss, and degradation of wetlands 

during implementation ofthe remedy, including the use of sedimentation basins or silt curtains to prevent 

downstream transport of contaminated sediments. A wetland restoration program was implemented upon 

completion of the remedial activities in wetland areas adversely impacted by the remedial action and 

ancillary activities. 

The RA objectives selected in the 1989 ROD to Meadow Brook Restoration are as follows: 

• Mitigate any fiiture impacts of such remedial activities to Meadow Brook and the surrounding 

wetland areas. 

Measures used included adequate sloping of stream banks to prevent excessive soil erosion into Meadow 

Brook. The remedy did not propose to restore the excavated Meadow Brook streambed to similar 

conditions existing prior to excavation. Comments from the Town of Norwood indicated that the 

Meadow Brook flood control project, which would include all portions of Meadow Brook targeted for 

sediment excavation was slated for constmction upon completion of the Remedial Action. Therefore, 

upon completion of the soil and sediment excavation of the Meadow Brook, the brook streambed and 

adjacent banks from these areas were restored, to the maximum extent feasible, in a manner consistent 

with the Meadow Brook Flood Control Project plans and specifications. The amended ROD in 1996 did 

not change the proposed remedial altemative for Meadow Brook Restoration. 

4.1.4 Remedial Action Objectives: Drainage System and Roof Decontamination 

& Grant Gear Machinery/Equipment and Floor Surfaces Decontamination 

Flushing, cleaning, and/or containment and replacement of portions of Grant Gear drainage system, and 

cleaning and sealing of roof surfaces was proposed in the 1989 ROD. The RA objectives selected in the 

1989 ROD to address drainage system and roof contamination at the Site are as follows: 

• To minimize the continued release of hazardous substances to Meadow Brook. 

Decontamination of surfaces of machinery, equipment, and floor surfaces within the plant areas of the 

Grant Gear Building were also part ofthe 1989 ROD. The RA objectives selected in the 1989 ROD to 

address grant gear machinery/equipment and floor surface contamination at the Site are as follows: 

• To reduce risks to workers associated with direct contact with PCB-contaminated surfaces. 

• To reduce risks to workers associated with inhalation of airbome PCBs within the Grant Gear 

Building. 

Due to the fact that Grant Gear was no longer in operation and it was unlikely that the existing building 

would be used, the Amended ROD in 1996 called for demolition ofthe building and on-site disposal in 

several ways. PCB-contaminated building material was to be consolidated in the boiler room and 

disposed on-site under the cap. Any material, in excess ofthe capacity of onsite disposal areas would be 

disposed at an appropriate off-site property. Certain materials, which are subject to federal Resource 

Conservation and Recovery Act (RCRA), 42 U.S.C. § 6901 et seq., requirements, would be disposed at an 

appropriate off-site facility complying with RCRA and Toxic Substances Control Act (TSCA), 15 U.S.C. 

§ 2601 et seq., requirements. Debris that was uncontaminated could be reused or recycled as appropriate. 

4-3 
Norwood PCBs Superfimd Site 

Five-Year Review Report December 2009 

4.2 REMEDY IMPLEMENTATION 

The USEPA issued a ROD in 1989, an Amended ROD in 1996, and an ESD in 2005. Three separate 

remedial action phases were completed, with the third phase consisting of a phase "A" and "B". Phase 1 

was completed by the USEPA and consisted of groundwater treatment. Phase 2 was conducted by the 

Settling Defendants and consisted of the Grant Gear building demolition. Phase 3 A was conducted by the 

Settling Defendants and consisted of the constmction of a cap and cover over consolidated contaminated 

soil and sediments. Finally, Meadow Brook Restoration Phase (Phase 3B) was completed by USEPA. 

Remedies implemented at the Site are briefly described in the following subsections. 

4.2.1 Source Control and Soil and Sediment / Cap and Cover 

The Settling Defendants performed excavation of sediments in Meadow Brook as per the 1989 ROD from 

April 28, 1997 through July 30, 1998, with a temporary work stoppage from Febmary 19 to May 3, 1998 

during winter conditions. The Meadow Brook Remediation was divided into three sections referred to as 

Reach 1, 2, and 3. Excavation activities within Meadow Brook required the temporary diversion ofthe 

stream. Dewatering cells were constmcted in the northem portion of the Hurley property, located west of 

the existing groundwater treatment plant. Two dewatering cells were constmcted - one located to the 

west, which received sediment from Reach 1 only, and one located to the east, which received sediment 

from Reaches 2 and 3 only. The excavated sediment was segregated in this manner due to the lower 

concentrations of PCBs expected for the sediments removed from Reaches 2 and 3. On June 7, 1997, 

excavation of Reach 1 of Meadow Brook was completed. Approximately 2,400 cubic yards (yd^) of 

material was excavated from Reach 1. On July 23, 1997, the excavation of Reach 2 was completed. The 

excavation of Reach 3 was performed in two phases - the first consisted of sediment removal from the 

arched culvert section at Dean Street, and the second consisted of sediment removal from the box culvert 

section. Once clean-up levels (1 ppm in sediment) were achieved at 160 feet into the culvert, sediment 

removal activities were terminated. Approximately 2,300 yd' of material was excavated fi-om Reach 2 

and Reach 3. 

Following the excavation of Reach 1 to the excavation grades, an area of stained soils was observed 

below the elevation ofthe design excavation grade at the former drainage outfall pipe. On June 11, 1997, 

after receiving direction fi-om the USEPA, GZA collected a soil sample from the area and submitted it for 

laboratory analysis. Based on the analytical results, a decision was made to perform a limited removal of 

this stained sediment. The limited removal of the stained sediment was performed between August 14 

and August 19, 1997. The estimated volume of stained soil removed is 85 yd'. 

Soils with PCB concentrations exceeding the appropriate clean-up levels were targeted for excavation 

from several on-property areas. Trichlorobenzene (TCB)-contaminated soil identified near soil boring 

location SS-012, west ofthe former Grant Gear building, was excavated. The excavated unsaturated zone 

soils were backfilled from the base of the excavation to above the water table, and saturated zone soils 

were backfilled from above the water table in the area of the excavation to existing grade. Approximately 

5,900 yd' of PCB-contaminated soil was excavated from the North Cover Area and stockpiled on-site for 

placement under the cap/cover. Approximately 2,600 yd' of PCB-contaminated soil was excavated from 

the South Cover Area and stockpiled on-site for placement under the cap/cover. 

Soils with PCB concentrations exceeding the appropriate clean-up levels were targeted for excavation 

from several off-property areas. During the activities performed for the remediation of Reach 1 of 

Meadow Brook, areas containing PCB-contaminated soils along the North Bank Wooded Area were 

discovered. Approximately 100 yd' of soil was excavated from the southem half of the western North 

Bank Wooded Area and stockpiled on-site for placement under the cap/cover. After the conclusion ofthe 

Reach 1 remediation activities, areas containing PCB-contaminated soils were discovered along the South 

4-4 
Norwood PCBs Superfijnd Site 

Five-Year Review Report December 2009 

Bank Wooded Area. Approximately 780 yd' of soil was excavated from the South Bank Wooded Area 

and stockpiled on-site for placement under the cap/cover. Previously stockpiled soils fi-om the Reardon 

property were relocated to the Hurley property. The approximately 1,600 yd' of material was stockpiled 

in two areas of the Reardon property - one at the south end of the property adjacent to Dean Street, and 

the other located on the north end ofthe property adjacent to the south end ofthe Hurley property. Both 

stockpiles were excavated, transported, and stockpiled near the southwest comer ofthe Hurley property. 

Beginning on April 30, 1997, the stockpiled soils were consolidated on-site. Criteria were used for 

identifying how and where the materials should be placed. Materials with PCB concentrations exceeding 

the risk-based, site-specific industrial/commercial clean-up levels were placed within the limits of the 

proposed asphalt cap. Materials with PCB concentrations below clean-up levels were placed within the 

limits ofthe proposed cover areas. During soil excavation and consolidation, on-site underground storage 

tanks (USTs) were removed before the caps were installed. The existing 10,000-gallon underground 

heating fiiel tank located at the southwest comer of the former Grant Gear building and the 20,000-gallon 

UST discovered adjacent to the 10,000-gallon tank during the building demolition phase of work at the 

Site were both decommissioned. Both USTs were cleaned, removed, and disposed off-site. While 

excavating to remove the 20,000-gallon UST, an area in the northeast comer against the former building 

foundation appeared to have petroleum-contaminated soil. Based on visual observations, this area with 

the contaminated soils was then excavated. The material was stockpiled with the previously stockpiled 

solids from the 20,000-gallon UST. 

After the PCB-contaminated materials had been placed in accordance with the site-specific clean-up 

levels and consolidated on-property, the areas were prepared for the installation of the cap and covers. 

Once the fill was placed to the appropriate grade (i.e., approximately 12 inches below the final grade in 

capped and covered areas), a non-woven geotextile filter fabric was laid across the cap and cover areas. 

An asphalt Cap or gravel cover was installed in the appropriate areas. 

A detention basin and surface drainage system was designed and located to conduct runoff across the cap 

and cover to adequately manage the discharge of mnoff, and to maximize the area ofthe property suitable 

for redevelopment. The subsurface drainage stmctures, oil and gas separators, catch basin, drainage 

manholes, drainage lines, flared-end sections, and outlet control stmctures were designed to convey 

overland stormwater flow to the stormwater detention basin. 

4.2.2 Groundwater Treatment 

The selected remedy for the management of migration of groundwater included the collection of 

groundwater using an extraction system consisting of nine shallow extraction wells and groundwater 

treatment consisting of carbon adsorption for PCB removal, air stripping for VOCs removal, and 

precipitation filtration for metals removal. The Groundwater Extraction and Treatment System was 

designed in 1994 and constmcted in 1995. The objective ofthe system was to minimize migration by 

providing an integrated long-term groundwater remediation facility. 

Nine groundwater extraction wells were installed in August 1995, concurrent with the constmction ofthe 

treatment system. The facility was designed to operate up to 25 years. On January 11,1996, the USEPA 

and the MassDEP conducted a pre-final inspection ofthe treatment facility and it was deemed operational 

and functional on Febmary 23, 1997. 

Metals were removed from groundwater using a chemical precipitation and multi-media filtration process. 

Sodium hydroxide was added to the collected groimdwater to cause the dissolved metals to precipitate out 

of solution and form coagulated solids. The solids from the chemical precipitation and filtration process 

were collected as sludge and dewatered to facilitate handling. Dewatered solids were disposed off-site in 

an approved landfill, which operated in compliance with RCRA. The contaminated water was then 

4-5 
Norwood PCBs Superfijnd Site 

Five-Year Review Report December 2009 

pumped to the top of an air stripping tray tower where air was blown into the bottom of the tower, as the 

water was introduced at the top and cascaded down. This counter current flow through the tray tower 

transferred VOCs from the groundwater into the air stream. The air stream was then passed through a 

catalytic oxidizer to destroy contaminants before being released into the atmosphere. An activated carbon 

unit was used to remove PCBs as a final polishing step after the air stripper. All hazardous wastes 

transported off-site were disposed in accordance with RCRA, Department of Transportation (DOT), and 

Massachusetts Hazardous Waste regulations. Water extracted firom the sludge during dewatering was 

pumped back to the inlet equalization tank and mixed with the collected groundwater for treatment. 

The groundwater treatment system was operational until it was shut down (at that time temporarily) in 

June of 2000. As a result of the revised groundwater classification (from potable to non-potable) and 

"low" use and value ascribed by MassDEP, in the 2005 ESD EPA determined that no fiirther groundwater 

clean-up was necessary, as revised clean-up goals were already being met. A final comprehensive 

groundwater monitoring report was completed in 2005, 5 years after GWTP shut down, to ensure that the 

goals were being met. This report revealed that groundwater clean-up goals were continuing to be met 

and EPA subsequently began GWTP decommissioning activities in 2007. As per the Prospective 

Purchaser Agreement (PPA) signed with the property owner, EPA decommissioning activities included 

the removal of all process equipment and termination of utilities and extraction well piping. This was 

substantively completed during the Spring 2007, after which the shell of the building was transferred on 

April 5, 2007 to the owner who subsequently notified EPA of his intention to demolish the GWTP in 

favor of other redevelopment plans. The GWTP was dismantled in March 2008 just prior to the 

beginning of constmction ofthe commercial/retail buildings 

4.2.3 Meadow Brook Restoration 

In accordance with the 1996 Amended ROD, and after the Settling Defendants finished excavation of 

contaminated brook sediments, the USEPA restored and stabilized the side slopes and bottom of Meadow 

Brook in order to complete the Town of Norwood's flood control project within the area ofthe Site. The 

brook was excavated to the depths required to meet the contours ofthe flood control project. The side 

slope and bottom of the brook were then restored with a layer of geotextile fabric and appropriate 

restoration materials (riprap, interlocking concrete blocks or precast concrete), which covered any 

residual contamination located at depths below the flood control contours ofthe restored brook channel. 

Restoration activities along Reach 1, adjacent to the Site, took place between October and December 

1997. Due to concerns related to the use of interlocking concrete blocks on the steeper slopes of Reach 2, 

precast concrete channel sections were used. This redesign effort, as well as several high water 

conditions, resulted ui delays in completing restoration activities in Reach 2. Reach 2 activities took 

place between April and July 1999. No restoration activities were required for Reach 3, as those 

culverted sections remained intact. 

The USEPA and the MADEP performed a final inspection of the Meadow Brook Restoration project on 

August 11, 1999. Plantings and reseeding were completed and accepted in October 1999. On August 18, 

2000, Meadow Brook O&M responsibilities and the Operation and Maintenance Manual for the Meadow 

Brook Restoration were transferred to the Town of Norwood. 

In addition to these clean-up activities, a Notice of Right of Access and Declaration of Covenants, 

Condition, and Restrictions ("Notice"), which is an Attachment in the Town's Consent Degree, was 

recorded in the Norfolk County Registry of Deed (Book No. 25628, Page No. 534). This Notice 

describes various restrictions on the Meadow Brook parcel including, but not limited to, the following: 

4-6 
Norwood PCBs Superfimd Site 

Five-Year Review Report December 2009 

1. The restriction of groundwater extraction, except for the purpose of monitoring contamination 

levels. Groundwater wells for such purposes can only be installed pursuant to a plan approved by 

EPA. 

2. No use or activity shall be permitted on any portion of the property which may disturb or 

adversely affect any ofthe remedial measures implemented at the Site. 

4.2.4 Grant Gear Building Demolition 

The former Grant Gear facility was demolished during the demolition phase of the RA performed 

between October 1996 and February 1997. Elevated concentrations of PCBs were detected in or on much 

of the building materials, including stmctural steel, equipment, concrete/brick, and roof decking. Brick, 

concrete block, and wallboard materials were cmshed and stockpiled on the building slab. Contaminated 

wood decking was shredded and stockpiled in the loading dock area west of the building slab. All other 

building materials, including asbestos-containing material, stmctural steel, and office and manufacturing 

equipment were either placed in the subgrade boiler room or disposed/recycled off-site. As the boiler 

room was filled, care was taken to limit void spaces. Remaining voids were filled with "flowable fill" 

and a 14-inch-thick reinforced concrete slab designed for anticipated loading (vehicle traffic) was 

constmcted over the boiler room opening. 

4.2.5 Redevelopment 

In addition to these remedial actions, redevelopment resulted in additional protectiveness of the soil and 

sediments under the cap. To ensure the integrity of the original cap, the developers constmcted new 

buildings around the cap thus utilizing the remedial cap as the area to be used as a parking lot. In order to 

make necessary surface grades as part ofthe redevelopment, an additional 6 to 12 inches of gravel and 4 

inches of asphalt were installed over the remedial cap, thereby increasing its protectiveness. In addition, 

as an added layer of protectiveness to future building occupants, the buildings were constmcted with a 

passive vapor mitigation system consisting of a layer of gravel, a network of transmission lines in the 

gravel layer which are passively vented to the exterior, and the application of Liquid Boot "^^ (a sprayapplied membrane system). 

4.3 OPERATION AND MAINTENANCE 

The Cap and Cover O&M Plan, detailed in the following section, was finalized in 2004, prior to the 

redevelopment of the Site. Accordingly, the O&M plan should be updated as soon as possible to reflect 

the components ofthe site that have been modified (such as well locations) as a result of redevelopment. 

4.3.1 Cap/Cover 

The purpose of the O&M Plan is to outline the actions that will be taken by the Settling Defendants and 

property owner (if redevelopment related) following the completion of remedial activities at the Site to 

monitor the long-term effectiveness of the RA. The O&M Plan presents a description of cap inspection 

and maintenance activities; potential operational problems; the operational safety plan; necessary 

equipment; record keeping procedures; groundwater, surface water, and sediment monitoring 

requirements; and a monitoring well maintenance program. The final (pre-development) O&M Plan was 

approved in December 2004. 

4.3.2 Groundwater Treatment 

Since the groundwater clean-up goals were achieved and the GWTP decommissioned there is no GWTP 

O&M. 

4-7 
Norwood PCBs Superfijnd Site 

Five-Year Review Report \ December 2009 

4.3.3 Meadow Brook Restoration 

A Meadow Brook O&M Manual was prepared by the United States Army Corps of Engineers (USACE) 

in June 2000 for the Meadow Brook restoration. The O&M of the Meadow Brook Restoration was 

transferred to the Town of Norwood in August 2000. The O&M Manual is intended to enable the Town 

to maintain the flood control project, as well as a municipal sewer easement that runs through the parcel, 

while preventing the release of any remaining contaminants that were left in place imdemeath the flood 

control stmctures. The project is mostly self-regulating and O&M is limited to preventing excessive 

vegetation or debris accumulation, and repairing damage caused by erosion and vandalism. 

Walking inspections are recommended at least every three months to detect deterioration of project 

features. Banks should be inspected for damage by rain, wave wash, sloughing, or vandalism. 

Obstmctions caused by debris should be removed. Vegetation should be allowed to grow in certain areas, 

but not others. Details are discussed in the Meadow Brook O&M Manual. 

Monitoring of water quality and sediment in within Meadow Brook is conducted by the non-municipal 

Settling Defendants to assess whether the remedy is remaining protective and is, therefore, part ofthe Cap 

and Cover O&M Plan. 

4-8 
Norwood PCBs Superfund Site 

Five-Year Review Report December 2009 

5.0 PROGRESS SINCE THE LAST REVIEW 

5.1 PROTECTIVENESS STATEMENT FROM PREVIOUS FIVE-YEAR REVIEW 

The following sections contain the protectiveness statements from the previous 2004 Second Five-Year 

Review. 

5.1.1 2004 Protectiveness Statement 

The following statement was included in the 2004 Second Five-Year Review Report: "The remedy at 

Norwood PCBs Superfund Site protects human health and the environment because new clean-up goals 

have been met. Operation & Maintenance (O&M) Plans have been submitted by the PRPs and approved 

for the Grant Gear Property, and institutional controls are in place. Meadow Brook O&M has been 

transferred to the Town of Norwood. However, in order for the remedy to be protective in the long-term, 

the following actions need to be taken: institutional controls for the industrial site and Meadow Brook 

must be updated and implemented and monitoring and Operation and Maintenance at the site must be 

conducted regularly." The 2004 Second Five-Year Review Report was signed on December 29, 2004 by 

Susan Studlien, Director, Office of Site Remediation and Restoration. 

5.2 PROGRESS SINCE PREVIOUS FIVE-YEAR REVIEW 

Below is a summary of progress since the last Five-Year Review. 

Shortly after the 2004 Five-Year Review was completed, EPA released an ESD to document new cleanup goals. These new clean-up goals for groundwater were based upon "RBALs" which were calculated 

for the protection of ecological receptors predominately that utilize Meadow Brook (which receives 

contaminated groundwater) and detailed in a Technical Memorandum in 2003. PCBs do not have a 

clean-up goal established in either the ROD or ESD. Moreover, the 1989 ROD acknowledged that cleanup of PCBs in groundwater would be "technically infeasible." Notwithstanding this, an RBAL was 

calculated [for PCBs] and which was exceeded in groundwater. PCBs were also detected in surface water 

above the Ambient Water Quality Criterion. Accordingly, a supplemental risk evaluation (Phase II 

Ecological and Human Health Risk Summary) was completed in 2004. This assessment concluded "that 

the existing conditions and levels of contaminants present in Meadow Brook do not represent a risk to the 

environment." In regards to human health, "no health concerns were indicated by the groundwater data 

relative to current or projected land use" and "no human health concerns [were identified] relative to the 

sediment samples fi-om Meadow Brook or the Neponset River." 

In 2005, a final comprehensive groundwater evaluation was completed and the resulting report 

documented no ROD-specified contaminants in groundwater above their respective groundwater clean-up 

goals established in the ESD. Having confirmed that all groundwater clean-up goals were being met 

(approximately 5 years after GWTP shut down), it was determined by USEPA and MassDEP that the 

GWTP was no longer necessary. The GWTP was subsequently decommissioned. As per the 1997 PPA 

with the property owner, EPA maintained responsibility for removing all chemical process equipment; 

this was done under contract by the USACE in 2007. As per the PPA, the building stmcture (shell) was 

left for the property owner to either reuse or dismantle; it was subsequently dismantled by the owner in 

2008. 

In 2006, a developer proposed a large (> 150,000 sf) redevelopment which would have been situated 

predominantly on/over the Cap and would have required excavation in the "capped material". Based on 

local concerns associated with disturbing contaminants from under the cap, this redevelopment was not 
Norwood PCBs Superfijnd Site 

Five-Year Review Report December 2009 

approved by the Town. Subsequently, the developer modified their redevelopment plans including, 

notably, the constmction of commercial/retail buildings around the footprint of the capped portion of the 

Site. This reuse would ensure that none of the highest-contaminated material would be exposed during 

constmction. The revised Work Plan for Redevelopment was approved by EPA and MassDEP in March 

2008, after which the developer received the necessary Town approvals. 

As required by the PPA, the Owner updated and recorded (with the Norfolk County Registry of Deeds) 

institutional controls in the form of a Grant of Environmental Restrictions and Easement (the "Grant") 

prior to the redevelopment. The Grant was recorded on March 27, 2008 and entered into Book No. 

25628, Page No. 534. The Grant prohibits certain activities such as: 

1. Agricultural use 

2. residential use 

3. day care or educational use 

4. recreational use 

5. extraction of groundwater 

6. excavation of material from the site (including soils, minerals, and resources) 

7. constmction of buildings on the cap 

8. any activities that would interfere with the effectiveness ofthe selected remedy 

Any request to allow or modify the Grant restrictions must be made to the Grantee, the Commonwealth 

represented by MassDEP, with notice to the USEPA. With these institutional controls in place, and with 

EPA's and the Town's approval, redevelopment began in May 2008 and was substantively completed by 

November 2008. The PPA with the landowner needs to be amended so that reporting requirements under 

the PPA are consistent with requirements under the Grant. 

In 2009, the Town of Norwood recorded a copy of the Consent Decree entered into by the Town, 

USEPA, and the Commonwealth. Included in the recorded CD is a Notice of Right of Access and 

Declaration of Covenants, Conditions, and Restrictions which provide long-term restrictions on the 

Meadow Brook parcel. Additional details of these restrictions are provided in Section 4.2.3 of this Fiveyear Review. With the Notice and Grant recorded, ICs exist throughout the site to ensure the safety of 

human health and the environment into the fiiture. 

The PRPs continue to conduct O&M including cap maintenance and periodic collection of surface water, 

sediment and groundwater. In September 2009, EPA completed a Final Closeout Report (FCOR) which 

states that remedial activities were complete, all institutional controls were in place, and clean-up levels 

were being met. 

5.3 STATUS OF RECOMMENDATIONS FROM PREVIOUS FIVE-YEAR REVIEW 

In the previous Five-Year Review, a list of recommended actions for continued O&M ofthe remedies and 

associated features was developed. These issues and recommendations are presented in Table 5-1, which 

also includes a description of how the issues have been resolved. 

5-2 
Norwood PCBs Superfimd Site 

Five-Year Review Report December 2009 

Table 5-1 

Issues & Recommendations from Previous Review 

Issues from Previous Review 

New groundwater monitoring data should be collected 

and evaluated relative to revised clean-up standards. 

Meadow Brook surface water and sediment should 

continue to be monitored to determine compliance 

with ARARs; ensure that there is not an unacceptable 

risk to human health and the environment and that the 

remedy remains protective. 

Updated institutional controls have not been 

recorded. 

A monitoring well was observed without a lock in the 

north cap area. 

No O&M procedures have been conducted in the 

Meadow Brook. 

Cracks were noted in the cap, which need to be 

investigated 

Cape Cod berms were damaged during plowing. 

Action Taken and Outcome 

Groundwater data continues to be collected and 

compared to clean-up goals. 

Meadow Brook surface water and sediment data 

continues to be collected and monitored. 

Institutional controls have been updated and 

recorded for both privately-owned (Laham) and 

municipally-owned (Meadow Brook) parcels 

As a resuh of GWTP demolition, the majority ofthe 

wells have been decommissioned. However, 

several monitoring wells were selected for longteiin monitoring and required relocation as a result 

ofthe redevelopment. This has been completed. 

In 2000, an O&M plan was given to the Town. 

This maintenance is recommended to ensure 

functionality of the drainage improvements. To 

date, this has not been performed. 

All cracks have been repaired. 

Cape Cod berms were eliminated as a result of 

redevelopment. 

5-3 
Norwood PCBs Superfijnd Site 

Five-Year Review Report December 2009 

6.0 FIVE-YEAR REVIEW PROCESS 

6.1 ADMINISTRATIVE COMPONENTS 

The USEPA Remedial Project Manager led the Norwood PCBs Superfund Site Five-Year Review team, 

while risk assessor Rick Sugat provided technical assistance. The review was conducted between April 

2009 and December 2009. The scope ofthe review included: 

• Document Review 

• Standards (ARAR) Review 

• Site Interviews 

• Site Inspection 

• Community Relations 

• Five-Year Review Report 

6.2 COMMUNITY NOTIFICATION AND INVOLVEMENT 

Community notification was initiated by a meeting held on April 6' 2009 between Remedial Project 

Manager Daniel Keefe and representatives from the Town of Norwood. A public notice was 

subsequently prepared and released on July 27, 2009 to the Daily News Transcript. Another notification 

to the newspaper will be issued announcing the completion ofthe report and the results ofthe review. A 

copy ofthe final report will be available for review at the Morrill Memorial Library in Norwood, MA; the 

USEPA's Region 1 Office; and the USEPA's website: 

http://www.epa.gov/regionl/superfund/sites/norwood. 

6.3 DOCUMENT REVIEW 

The project team reviewed documents and site files to become knowledgeable with the history and status 

of clean up, and to assess the protectiveness of RAs at the site. Specific documents reviewed included: 

1. September 29,1989 Record of Decision 

2. May 17, 1996 Amended Record of Decision 

3. September 23, 1999 Preliminary Close-Out Report 

4. December 30, 1999 Five-Year Review Report 

5. April 2000 Final Supplemental Risk Assessment (Foster Wheeler) 

6. June 2000 Operation and Maintenance Manual - Meadow Brook Restoration (USACE) 

7. August 2000 Interim Remedial Action Report for the Groundwater Treatment Plant (Foster 

Wheeler) 

8. May 11, 2001 MassDEP Groundwater Use and Value Determination 

9. January 2002 Meadow Brook Restoration Remedial Action Report (USACE) 

10. May 2002 Final Amendment to the Supplemental Risk Assessment (Foster Wheeler) 

6-1 
Norwood PCBs Superfimd Site 

Five-Year Review Report December 2009 

11. March 2003 Final Technical Memorandum - Development of Risk-Based Action Levels (Foster 

Wheeler) 

12. March 2003 27* Quarterly Groundwater Monitoring Report (Nobis) 

13. September 2003 Soil/Brook Remedial Constmction Report (GZA) 

14. January 2004 Environmental Monitoring Work Plan (GZA) 

15. January 2004 Operation and Maintenance Plan (GZA) 

16. July 2004 Draft Phase II Ecological and Human Health Risk Summary Report (Tetra Tech FW) 

17. December 2004 Operation & Maintenance Plan (GZA) 

18. December 2004 Five-Year Review Report (USACE/EPA) 

19. Febmary 2005 Explanation of Significant Differences (EPA) 

20. June/July 2005 28* Groundwater Monitoring Report (USACE/Tetra Tech) 

21. January 2006 Annual Monitoring Report (GZA) 

22. January 2007 Annual Monitoring Report (GZA) 

23. January 2008 Aimual Monitoring Report (GZA) 

24. March 2008 Revised Work Plan For Redevelopment (GZA) 

25. March 2008 Grant of Environmental Restriction and Easement (MassDEP) 

26. January 2009 Annual Monitoring Report (GZA) 

27. March 2009 Notice of Right of Access and Declaration of Covenants, Conditions, and 

Restrictions contained in Consent Decree in United States and the Commonwealth of 

Massachusetts v. Town of Norwood 

28. September 2009 Final Close-Out Report (EPA) 

6.4 DATA REVIEW 

6.4.1 Groundwater Monitoring Data 

Quarterly groundwater monitoring continued throughout the operation of the groundwater treatment 

system. In June 2000, the groundwater treatment system was shut down, however, quarterly groundwater 

monitoring continued for two years beyond the system shutdown. The last comprehensive groundwater 

monitoring was completed in June 2005 (the 28* monitoring round). 

The 28* quarterly groundwater monitoring round involved the collection and analysis of samples from 

thirty-one monitoring wells, nine extraction wells, and three surface water sample locations. 

Groundwater gauging rounds continue to indicate east to northeast flow in the overburden aquifer and 

east with a southeast component in the bedrock aquifer. The results revealed no contaminant exceeding 

the revised groundwater clean-up goals, which subsequently allowed EPA to decommission the GWTP. 

In addition to the last comprehensive round, the Settling Defendants continue to collect bi-annual 

6-2 
Norwood PCBs Superfimd Site 

Five-Year Review Report December 2009 

groundwater data as per the final Cap and Cover O&M Plan. These results are reported in annual 

monitoring reports which have also demonstrated that clean-up goals are being met. A summary of 

highest detected concentrations of contaminants in groundwater over the last 5 years is given in Table 6-

1. It should be noted that redevelopment took place between the Spring and Fall 2008 monitoring rounds. 

The most recent groundwater data (Fall 2008) reflects the condition of groundwater post-redevelopment. 

Sample results from 2009 are jmticipated in January 2010. All of contaminants in groundwater (for 

which there was a ROD-specified clean-up goal) continue to meet their revised clean-up goals. 

6.4.2 Surface Water/Sediment 

Surface water and sediment samples are collected every 2 yccirs as per the approved EMP. During this 

five-year review period, samples were collection in 2006 and 2008. During each sampling event, three 

samples were collected (one each from northwest comer ofthe property, the mid-point of Meadow Brook 

and from the brook just prior to the Dean Street culvert). The maximum concentration detection in 

sediment were 0.21 and 0.48 ppm of PCBs in 2006 and 2008, respectively. In regards to surface water, 

three samples were collected during each ofthe events and no PCBs were reported (typical reporting limit 

0.5 ug/L). 

6-3 
'Norwood PCBs Superfijnd Site 

Five-Year Review Report December 2009 

Contaminants of Potential Concern 

Volatile Organic Compounds (VOCs) 

1,2,4-Trichlorobenzene 

1,2,3- Trichlorobenzene 

1,2- DIchlorobenzene 

1,3- Dichlorobenzene 

1,4-Dlchlorobenzene 

Total 1,2-Dichloroethenes 

1,1- Dichloroethene 

1,1- Dichloroethane 

Chlorobenzene 

Tetrachloroethene 

Trichloroethene 

tert- Butyl alcohol (TBA) 

Acetone 

1,2,4-Trimethylbenzene 

Tetrahydrofuran 

Vinyl Chloride 

Maxim 

Site-Specific RBAL 

(UQ/I) 

34,000 

4,600 

3,660,000 

37,000 

108,000 

310,000 

Table 6-1 

um Observed Groundwater Analytical Results (2005 - 2008) 

2005 Groundwater Data* 

Jun-05 

(ufl/l) 

1,500 

ND 

ND 

ND 

25 

420 

ND 

ND 

ND 

58 

2,100 

ND 

ND 

ND 

ND 

120 

Nov-05 

(ug/l) 

490 

ND 

ND 

ND 

96 

369 

ND 

ND 

ND 

ND 

1,800 

ND 

ND 

ND 

ND 

99 

2006 Groundwater Data 

1-May-06 17-Nov-06 

(ug/l) 

670 

ND 

ND 

ND 

78 

448 

ND 

ND 

ND 

ND 

1,100 

ND 

ND 

ND 

ND 

76 

(ug/l) 

850 

ND 

ND 

ND 

36 

468 

ND 

ND 

ND 

ND 

1,100 

ND 

ND 

ND 

ND 

75 

2007 Groundwater Data 

25-Jun-07 

(ug/l) 

1,313 

373 

31 

54 

74 

514 

6.8 

10 

187 

ND 

1,922 

ND 

ND 

ND 

ND 

131 

Nov/Dec 2007 

(uq/l) 

69 

17 

ND 

20 

22 

518 

7.3 

ND 

260 

ND 

250 

51 

ND 

ND 

ND 

91 

2008 Groundwater Data 

10-Apr-08 

(ug/l) 

9 

2.7 

5.3 

27 

39 

460.4 

6.4 

ND 

100 

3.3 

84 

ND 

65 

ND 

ND 

90 

13-Nov08 

(ug/i) 

980 

230 

19 

89 

72 

103.6 

15 

ND 

130 

11 

970 

ND 

ND 

1.2 

11 

61 

Polychlorinated Biphenyls (PCBs) 

Total PCBs 

Wells exceeding PCB RBALs^ 

4.3 

4.3 

30 

ME-17(B4) 

16.8 

ME-17(B-4) 

8.6 

MW-1A, ME17(84) 

13 

ME-17(B-4) 

,B-28 

34.4 

MW-1A, ME17(B4) 

61.5 

ME-17(B-4), 

MW-2A, MW-1A 

39 

MW-1A, 

ME-17(B4) 

5.6 

MW-1A 

*Last comprehensive round of sampling (31 wells 9 EW) 

^ While an RBAL for PCBs was calculated. It was not adopted in the 2005 ESD as a "clean-up goal" per se. The ROD acknowledged restoration of PCBs in 

groundwater as "technically impracticable" and, therefore, Identified institutional controls as the means by which exposure to PCBs would be controlled. 
Norwood PCBs Superfijnd Site 

Five-Year Review Report December 2009 

6.4.2 Risk Assessment Data 

A Groundwater Risk Assessment was completed in 1998 that evaluated human health exposure to 

chemicals that may volatilize from groundwater into indoor air of a proposed building as well as 

evaluated ecological risks associated with groundwater discharge to Meadow Brook. 

A Supplemental Risk Assessment was completed in 2000 by Foster Wheeler as an update to the 1998 

Groundwater Risk Assessment (Foster Wheeler, 2000). The Supplemental Risk Assessment consisted of 

a human health risk assessment and a screening level ecological risk assessment. The human health risk 

assessment focused on potential inhalation of compounds volatilized from contaminated subsurface soils 

and groimdwater in a future commercial building. The screening level ecological risk assessment focused 

on the potential impacts of the discharge of contaminated groundwater to the Meadow Brook. The 

assessment indicated that contributions to the projected carcinogenic risk from the subsurface soil and 

groundwater exceed the target values for each source medium separately. The risk drivers were vinyl 

chloride and trichloroethene in groundwater and trichloroethene and methylene chloride in subsurface 

soil. An assessment of potential indoor inhalation risks under fiiture conditions assuming the shutdown of 

the groundwater treatment system was also performed. The projected risk and hazard results were 

generally similar to the current conditions scenario with somewhat higher risk and hazard levels. The 

human health risk assessment concluded that a possible unacceptable risk exists from the inhalation of 

volatiles from groundwater and subsurface soils and engineering controls may be necessary if the use of 

the property changes and/or new stmctures were built. The screening level ecological risk assessment 

indicated no apparent risk to receptor species based on the available data and benchmark criteria. 

In 2002, Foster Wheeler completed an Amendment to the Supplemental Risk Assessment. The 

Amendment addressed the potential exposures of a fiiture constmction worker to contaminated 

groundwater. The results indicated that the hazard index exceeded the MassDEP target level and the 

calculated carcinogenic risk slightly exceeded the MassDEP target level for a hypothetical future 

constmction worker exposed to the Site groundwater. These results were based on an assumption of 

repetitive dermal and inhalation exposure over the course of typical building constmction The elevated 

risk and hazard index results relative to the MassDEP target levels are essentially the resuh of the 

detected Aroclor compounds in groundwater and the potential direct contact exposure route. Thus, any 

future excavation activities would likely require appropriate Health and Safety training and Personal 

Protective Equipment (PPE) to minimize risk to constmction workers and be conducted in compliance 

with applicable laws and regulations and the institutional controls for the site. 

In March 2003, Foster Wheeler Environmental Corporation, subsequently performed a Supplemental Risk 

Analysis for the Site and developed new groundwater clean-up goals [or Risk-Based Action Levels 

(RBALs)] in light of MassDEP's "low use and value" determination. The results are summarized in a 

March 2003 Technical Memorandum. The action levels were developed to reflect the protection of 

ecological receptors associated with the aquatic habitats of Meadow Brook and its associated riparian 

communities adjacent to the Site. Maximum concentrations of VOCs and semi-volatile organic 

compounds (SVOCs) in groundwater have all been consistently below the RBALs with a considerable 

margin. These RBALs were documented as the new groundwater clean-up goals in the 2005 ESD. This 

risk analysis raised some concems about the remaining PCB contamination in groundwater and hs 

impacts on Meadow Brook. The RBAL has been met for PCBs in all wells adjacent to Meadow Brook. 

Surface water Ambient Water Quality Criteria (AWQCs)' for PCBs was exceeded at the midstream and 

downstream stations in the 26* sampling round. The Technical Memorandum recommended that the 

detections of PCBs in surface water of Meadow Brook should be fiirther investigated and a second phase 

("Phase II") of investigation was initiated. 

' Now called "National Recommended Water Quahty Criteria ("NRWQC") (40 C.F.R. § 122.44). 

6-5 
Norwood PCBs Superfund Site 

Five-Year Review Report December 2009 

In July 2004, Tetra Tech FW prepared a Draft Phase II Ecological and Human Health Risk Summary 

Report as part of Phase II field investigations for Meadow Brook at the Site. The Phase II investigation 

was to assess PCB impacts from the Site to Meadow Brook and to examine sediment PCB distribution 

downstream of the Site. The report concluded that existing conditions and levels of contaminants present 

in Meadow Brook do not present a risk to human health or the environment. No unacceptable human 

health risks were indicated by the groundwater data relative to current or projected future land use. A 

possible human health concern associated with long-term direct contact exposure to soil was indicated at 

discrete locations off-site and down stream ofthe site, adjacent to the Neponset River. Additional offproperty samples were collected and exposure point concentrations (EPC) calculated (3 ppm); this value 

was less than the residential surface soil clean-up goal specified in the ROD (10 ppm). No human health 

concems relating to sediment samples taken from Meadow Brook and the Neponset River were indicated. 

Based on this data, and the 1989 ROD determination that it was technically impracticable to reduce PCB 

concentrations in groundwater to health-based levels, no groundwater clean-up level for PCBs was 

established by the ROD or the ESD. Any secondary risk to human health from exposure to PCB 

contamination on the site (in soil or groundwater) will continue to be controlled via institutional 

controls. Periodic surface water and sediment monitoring in Meadow Brook has been (and will 

continue to be) collected to evaluate long-term compliance with NRWQCs and the protection of 

the envirormient. 

6.5 SITE INSPECTION 

The Five-Year Review Site Inspection to assess the protectiveness of the remedies was conducted on July 

8, 2009. The inspection was conducted by Daniel Keefe and Shamus Keohane (USEPA); and Albert 

Ricciardelli, Senior Principal (GZA GeoEnvironmental Inc.). 

Table 6-2 provides a summary of the Site components that were inspected and a brief description of 

findings. Issues and recommendations are further discussed in Section 8.0. Photos can be found in 

Appendix D. 

Table 6-2 

Site Investigation Summary 

Access and Site 

Roads 

Detention Basin 

(along Meadow 

Brook) 

Detention Basin 

Side Slopes 

Cap and Cover 

Area 

The roads and parking lot appear to be in good shape. The Dean St. access roads appear to 

be used regularly, but the parking lot has Httle use because there are presently no 

commercial tenants. 

The detention basin had some water in it, due to the significant rains during Spring 2009. 

There was some overgrowth in the basin, but during the site inspection, landscapers hired 

by the property owner arrived to mow the area as seen in photographs 13-14. 

The slopes along the interior ofthe basin were in good condition. There was no exposed 

geotextile fabric and the weirs appeared to be in good shape. The outside slope ofthe basin, 

sloping dovm to the Meadow Brook however was considerably overgrown. Large shrubs 

and some young trees have taken root. 

The asphalt parking lot over the cap appeared to be in good condition. No cracks or other 

structural damage were noted. 

6-6 
Norwood PCBs Superfund Site 

Five-Year Review Report December 2009 

Table 6-2 

Site Investigation Summary 

Cap Area Use 

Monitoring Wells 

Meadow Brook 

The parking lot and additional utilities such as light posts appeared in good condition. 

The monitoring wells were found to be unlocked and easily opened. See photos 22-23. 

This condition was reflective more so recent relocation of wells (due to redevelopment) 

and is contained as one of the redevelopment punch list items. 

There was some debris such as a tire and an old shopping cart found in the brook that could 

impede flow as organic debris, such as logs and leaves pile up. See photographs 17-18. 

6.6 INTERVIEWS 

EPA conducted interviews of owners and businesses adjacent to the Site, and of local and State officials. 

The objective of the informal interviews was primarily to obtain general information and to update 

current understanding of activities at the Site. 

A few abutting businesses were visited on July 8, 2009. During these visits, abutters were given a brief 

summary of the events at the site over the past 5 years and a survey questionnaire. The following abutting 

businesses were visited: Neponset Valley Child Care, Advance Auto Parts, Walgreens, and Direct Tire. 

During these interviews, none of the abutters raised any concems about the site; they were given a 

questiormaire and contact information should any concems arise at a future time. 

In addition to the abutting businesses, interview questions were provided to the other project stakeholders 

including: Albert Ricciardelli, Senior Principal of GZA GeoEnvironmental Inc, on behalf of the Settling 

Defendants; Steve Costello, Director of Community Planning and Economic Development, Town of 

Norwood; Joe Laham, the owner of the former facility property; and Jim Grafrneyer, Todd Hamula, and 

Paul Dansczak representing Developers Diversified Realty, the redeveloping company; and Dave Buckley 

for MassDEP. 

Out of all these interviewees, no major concems were identified. The consensus was that the constmction 

was a very successflil project conducted with the coordination of all the parties. Steve Costello, 

representing the Town of Norwood, had this to say about the Remedial Actions at the site: 

"I think the EPA and DEP have done an outstanding job in assisting the Town with 

rehabilitiation of this site. There were absolutely no issues with the Town or abutting 

neighbors because the EPA and the developer agreed to a Work Plan with Remedial 

Actions [completed] prior to constmction. This Work Plan addressed the Town's primary 

concern... and, in my opinion, the final development is very protective of human health 

and the environment." 

Additional interview notes are provided in Appendix C. 

6-7 
Norwood PCBs Superfimd Site 

Five-Year Review Report December 2009 

7.0 TECHNICAL ASSESSMENT 

7.1 QUESTION A: IS THE REMEDY FUNCTIONING AS INTENDED BY THE 

DECISION DOCUMENTS? 

Yes, the review of documents, ARARs, and the results of the July 2009 site mspection indicate that the 

remedy is operating and fimctioning as designed. Based on observations during the site inspection, the 

RA has been determined to be performing as expected. The successful completion of redevelopment at 

the site created additional safety controls to ensure the success of the implemented remedy. The cap was 

given additional coverage with the constmction of the parking lot, and the passive vapor mitigation 

system installed under the retail buildings ensure the safety ofthe occupants. 

Indicators of potential issues pointing to a failmg remedy would be cap erosion or disturbance, increased 

contaminant concentrations in groundwater, or increased contaminant concentrations in Meadow Brook. 

Continued monitoring of groundwater, as well as Meadow Brook surface water and sediment, will be 

critical in evaluating the functionality and protectiveness ofthe remedy. 

Institutional controls have been recorded on the both the former facility and Meadow Brook properties 

that will ensure the remedy remains protective in the future. A Grant of Environmental Restriction and 

Easement was recorded between the property owner (Joe Laham) and the Commonwealth, represented by 

the MassDEP. In addition a Consent Decree, which includes a Notice of Right of Access and Declaration 

of Covenants, and Restrictions was recorded in the Norfolk County Registry of Deed by the Town for the 

Meadow Brook Parcel. 

7.2 QUESTION B: ARE THE EXPOSURE ASSUMPTIONS, TOXICITY DATA, 

CLEAN-UP LEVELS, AND REMEDIAL ACTION OBJECTIVES USED AT THE 

TIME OF REMEDY SELECTION STILL VALID? 

Soil and Sediment 

Soil and sediment standards identified in the 1989 ROD were updated in the 1996 ROD amendment. 

These standards have not been revised since the amended ROD and there are no newly promulgated 

standards that call into question the protectiveness of the remedy. 

Intensity and frequency of use of the Site has changed since the last Five-year review as a result of 

redevelopment. EPA reexamined exposure pathways in its review of the RWP. Due to concems about 

vapor intmsion into indoor air, a passive vapor mitigation system was required and installed in each ofthe 

commercial building. See Photographs 5 & 7. As required in the RWP, post constmction and prior to 

occupancy, sub-slab air samples were obtained an analyzed and a risk assessment completed. The 

assessment conservatively assumed that the exposure population would be residential. Based on this 

analysis, the risks were found to be acceptable (less than 1 x 10"^). In the fiiture, as necessary and pending 

future monitoring results, the sub-slab ventilation systems can be made to be actively vented with the 

addition of blowers or vacuum pumps. 

Groundwater 

The aquifer beneath the site is no longer classified as a current or potential future drinking water supply 

by the Commonwealth. Therefore, Maximum Contaminant Levels (MCLs) promulgated under the Safe 

Drinking Water Act, and Massachusetts Drinking Water Standards are no longer applicable and were 

removed as ARARs by the 2005 ESD. As a result ofthe revised aquifer classification and additional risk 

7-1 
Norwood PCBs Superfimd Site 

Five-Year Review Report December 2009 

assessment activities, the USEPA calculated revised groundwater clean-up goals (i.e., RBALs) which 

were documented in a 2005 ESD. These clean-up goals have been and are currently being met. 

7.3 QUESTION C: HAS ANY OTHER INFORMATION COME TO LIGHT THAT 

COULD CALL INTO QUESTION THE PROTECTIVENESS OF THE REMEDY? 

No newly identified human health or ecological risks have been identified to date. No other information 

has come to light since the July 2009 site inspection that could affect the protectiveness ofthe remedy. 

7.4 ARARS REVIEW 

A review of ARARs was conducted to evaluate whether the RAs are protective of human health and the 

environment. The review accounted for updated regulatory standards promulgated since the ROD, 

amended ROD and ESD were issued. 

An analysis of newly promulgated or modified requirements of Federal and State environmental 

regulations was conducted to determine if these new ARARs change the protectiveness of the remedy. 

The evaluation includes a determination of whether the regulation is currently an ARAR or TBC, and 

whether the remediation, as planned in the ROD, amended ROD, and ESD, would be in compliance with 

the requirements. Action-, location-, and chemical-specific requirements are tabulated and located in 

Appendix B of this report. 

The standards review was based on the review of USEPA-provided documents, as well as published 

Federal, State, and local mles and regulations. Recommendations are made as to whether any changes to 

the list of contaminants of concem need to be made. Under Section III. A of Attachment I "Explanation of 

Five-Year Review Policy" to OSWER Directive 9355.7-02, the Commonwealth should be requested to 

identify State ARARs promulgated or modified since the ROD, amended ROD, and ESD were signed, 

which may have a bearing on the protectiveness of the remedy. According to the MassDEP, as of this 

report, they were not aware of any new or revised State ARARs affecting the protectiveness of the 

Remedy. 

Few changes to the ARARs have occurred since the ESD was signed. Most location and action specific 

ARARs currently apply to ongoing monitoring and O&M activities rather than the constmction activities 

discussed in the last Five-Year Review. Two location-specific ARARs regarding federal protection of 

wetlands and protection of floodplain no longer exist as promulgated standards. No other substantive 

changes were identified for ARARs cited in the ESD. No changes to ARARs have occurred that would 

affect the protectiveness ofthe remedy. 

7-2 
Norwood PCBs Superfimd Site 

Five-Year Review Report December 2009 

8.0 ISSUES 

Table 8-1 provides a summary of the issues identified at the Site during this Five-Year Review. 

Table 8-1 

Issues 

Issues 

The O&M and EMP plans need to be updated to account for changes 

as a result of redevelopment. 

Punch list items associated with RWP have not been completed, 

including, but not limited to, the installation of cap benchmarks and 

the installation of protective casing around vapor sampling points. 

Affects Current 

Protectiveness 

(Y/N) 

N 

N 

Affects Future 

Protectiveness 

(Y/N) 

Y 

Y 
Norwood PCBs Superfimd Site 

Five-Year Review Report December 2009 

9.0 RECOMMENDATIONS AND FOLLOW-UP ACTIONS 

Table 9-1 provides recommended follow-up actions for issues discovered at the Site during this 

Five-Year Review. 

Table 9-1 

Recommendations and Follow-up Actions 

Issue 

O&M and EMP 

plans out of 

date 

Punch list items 

associated with 

redevelopment 

incomplete 

Recommendations and 

Follow-up Actions 

Developer to amend, as per the 

approved Redevelopment Work 

Plan, the existing final O&M 

and EMP. 

Developer to complete 

miscellaneous items as 

described in the approved Work 

Plan for Redevelopment. 

Party 

Responsible 

Developer 

Developer 

Oversight 

Agency 

USEPA 

USEPA 

Milestone 

Date 

Spring 

2010 

Spring 

2010 

Affects 

Protectiveness 

(Y/N) 

Current 

N 

N 

Future 

Y 

Y 

9-1 
Norwood PCBs Superfijnd Site 

Five-Year Review Report December 2009 

10.0 PROTECTIVENESS STATEMENTS 

10.1 PROTECTIVENESS 

The remedy at Norwood PCBs Superfund Site protects human health and the environment because cleanup goals are being met and institutional controls have been recorded. The Laham property has been 

redeveloped and consists of two (2) new buildings totaling 56,000 square feet of commercial/retail space. 

Gravel and asphalt were added to the Remedial Cap thereby increasing its protectiveness. To be ensure 

protectiveness in the future, the O&M and EMP plans needs to be updated, punch list items associated 

with the redevelopment need to be completed. 

10-
Norwood PCBs Superfimd Site 

Five-Year Review Report December 2009 

11.0 NEXT REVIEW 

In accordance with the June 2001 Comprehensive Five-Year Review Guidance, the fourth Five-Year 

Review will be due five years from the signature date of this (third) Five-Year Review. 

11-
Norwood PCBs Superfimd Site 

Five-Year Review Report December 2009 

12.0 REFERENCES 

1. Foster Wheeler Environmental Corporation, 2000. Final Supplemental Risk Assessment, Norwood 

PCB Superfimd Site. April 2000. 

2. Foster Wheeler Environmental Corporation, 2000. Final Interim Remedial Action Report for the 

Norwood PCB Superfimd Site Groundwater Treatment Plant. August 2000. 

3. Foster Wheeler Environmental Corporation, 2002. Final Amendment to the Supplemental Risk 

Assessment, Norwood PCB Superfund Site. May 2002. 

4. Foster Wheeler Environmental Corporation, 2003. Fmal Technical Memorandum, Development of 

Risk-Based Action Levels for the Protection of Ecological Receptors for Contaminants of Potential 

Concem in the Groundwater at the Norwood PCB Superfimd Site. March 2003. 

5. GZA Geo Environmental, Inc., 2003. Soil/Brook Remedial Constmction Report. September 2003. 

6. GZA Geo Environmental, Inc., 2004. Operation and Maintenance Plan, Norwood PCB Superfund 

Site. January 2004. 

7. GZA Geo Environmental, Inc., 2008. Revised Work Plan for Redevelopment, Norwood PCB 

Superfimd Site. March 2008. 

8. GZA Geo Environmental, Inc., 2007. Annual Monitoring Report for 2006, Norwood PCB Superfund 

Site. January 2007. 

9. GZA Geo Environmental, Inc., 2008. Annual Monitoring Report for 2007, Norwood PCB Superfund 

Site. January 2008. 

10. GZA Geo Environmental, Inc., 2009. Annual Monitoring Report for 2008, Norwood PCB Superfimd 

Site. January 2009. 

11. GZA Geo Environmental, Inc., 2004. Environmental Monitoring Work Plan, Norwood PCB 

Superfimd Site. January 2004. 

12. GZA Geo Environmental, Inc., 2004. Operation and Maintenance Plan, Norwood PCB Superfimd 

Site. December 2004. 

13. Laham, Joseph. 2008 Grant of Environment Restriction and Easement from Joseph Laham (Grantor) 

to Commonwealth of Massachusetts (Grantor), [date] 

14. Massachusetts Department of Environmental Protection, 2001. Groundwater Use and Value 

Determination. May 11, 2001. 

15. Nobis Engineering Inc. and Foster Wheeler Environmental Corporation, 2002. 27* Quarterly 

Groundwater Monitoring Report, Norwood PCB Superfund Site, Norwood, Massachusetts, October 

2002 Sampling Event. March 4, 2003. 

16. Tetra Tech FW, Inc., 2004. Draft Phase II Ecological and Human Health Risk Summary Report, 

Norwood PCB Superfimd Site. July 2004. 

12-1 
Norwood PCBs Superfimd Site 

Five-Year Review Report December 2009 

17. Tetra Tech FW, INC., 2005. Twenty-Eighth Groundwater Monitoring Report Norwood PCB 

Superfund Site, Norwood, MA. June/July 2005. 

18. Town of Norwood letter re: Master Plans 

19. U.S. Environmental Protection Agency, 1989. USEPA Superfimd Record of Decision, Norwood 

PCBs. September 29, 1989. 

20. U.S. Environmental Protection Agency, 1996. USEPA Superfimd Record of Decision Amendment, 

Norwood PCBs. May 17, 1996. 

21. U.S. Environmental Protection Agency, 1999. Preliminary Close-Out Report. September 23, 1999. 

22. U.S. Environmental Protection Agency, 2009. Final Close-Out Report. September 22, 2009. 

23. U.S. Environmental Protection Agency, 1999. Five-Year Review, Norwood PCB Superfund Site, 

Norwood, Massachusetts. December 1999. 

24. U.S. Environmental Protection Agency, 2001. Comprehensive Five-Year Review Guidance. U.S. 

Environmental Protection Agency, Office of Emergency and Remedial Response. June 2001. 

25. U.S. Army Corps of Engineers, 2000. Operation and Maintenance Manual, Meadow Brook 

Restoration, Norwood, Massachusetts. June 2000. 

26. U.S. Army Corps of Engineers, 2002. Meadow Brook Restoration Remedial Action Report, 

Norwood, Massachusetts. January 2002. 

27. U.S. Environmental Protection Agency, 2004. Five-Year Review, Norwood PCB Superfimd Site, 

Norwood, Massachusetts. December 2004 

28. U.S. Environmental Protection Agency, 2005. Explanation of Significant Differences for the 

Norwood PCB Superfimd Site. Norwood, Massachusetts. Febmary 2005. 

12-2 
mMltmmmfmiM t mnnfiiiM X 

Norwood PCBs Superfimd Site 

Five-Year Review Report December 2009 

APPENDIX A 

SITE MAPS 
1 

^Mt^-" 

t GZ^ V 

' • '*-" " ^' " •^"* " •"' - jiZ . 

SOURCE SCANNEO USSS TCPOGIW :>HIC OUADRANSLE S 

SCANNEO SY THE MASSACHUSETTS BXBCijnm OFFtt* OF 

eN(VMOI*IEN^AL AJFFAlHfi IWIASSGIS OlSTHlBUTSa JL#J6. JtWI. 

^ S 

PSOJ MGH 3BP 

DESlGr«£0 SV. DR 

OPeSATOR EM3 

QATE. 12 ia-2C0S 

LOCUS PLAN 

NORWOOD PCB SUPERFUND SITE 

NORWOOD. MASSACHUSETTS 

j Oi NC. 

0' 0318605 001 

F-IEURfe MO 

1 
U

M <T Ll*r- -WP •^Tl V. 7VH 

11 

.A-* 

•Hi.! 

illlli 

1S3M.S0 

APPENDIX B 

TABLES DOCUMENTING ARARs 
AUTHORITY REQUIREMENT 

CHEMICAL SPECIFIC ARARs: 

Federal Criteria, 

Advisories, and Guidance 

Technical Basis for Deriving Sediment 

Quality Criteria for Non-ionic Organic 

Contaminants for the Protection of Benthic 

Organisms Using Equilibrium Partitioning 

(EPA-822-R-93-011) 

Clean Water Act - Sec. 304 

Federal Ambient Water Quality Criteria 

33 us e 1314; 40 CFR 122.44 

EPA Carcinogenic Assessment Group 

Potency Factors 

EPA Risk Reference Doses (RfDs) 

STATUS REQUIREMENT SYNOPSIS 

To be This guidance is used to establish criteria to 

Considered protect the aquatic organisms in streams and to 

determine environmental risk 

within the sediment and to set sediment, 

cleanup levels. 

Relevant and Federal AWQC are criteria for protection of 

Appropriate human health and aquatic organisms which have 

been developed for carcinogenic and Brook 

noncarcinogenic compounds. 

AWQC are developed under the Clean Water Act 

(CWA) as guidelines from which states develop 

water quality standards. 

To be Potency factors are developed by the EPA ftom 

Considered Health Effects Assessments or Evaluation by the 

Carcinogenic Assessment Group. 

To be RfDs are does levels developed by the EPA for 

Considered non-carcinogenic effects. 

ACTION TAKEN TO ATTAIN 

ARARs 

The criteria established were used to 

evaluate risks to aquatic organisms 

exposed to contaminated water entrained 

AWQC were used to characterize risks 

to fresh water aquatic life in Meadow Brook 

EPA Carcinogenic Potency Factors were 

used to complete the individual 

incremental cancer risk resulting from 

exposure to site contaminants. 

EPA RfDs were used to characterize 

risks due to exposure to contaminants on 

site. 

LOCATION SPECIFIC ARARs 

Federal Regulatory Wetlands Executive Order (EO 11990) Applicable 

40 CFR Part 6, Appendix A 

Under this regulation. Federal agencies are 

required to minimize the destruction, loss, or 

degradation of wetlands, and preserve and 

enhance natural and beneficial values of 

wetlands. 

Any redevelopment or O &M will include all 

all practicable means of minimizing 

harm to wetlands. 

Floodplains Executive Order (EO 11988) Applicable 

40 CFR Part 6, Appendix A 

Clean Water Act (CWA) - Section 404 Applicable 

Dredge and Fill Requirements 

(33 U.S.C. 1344; 40 CFR Part 230) 

Federal agencies are required to reduce the risk 

of flood loss, to minimize the impact of floods, 

and to restore and preserve the natural and 

beneficial values of floodplains. 

No activity that adversely affects a wetland shall 

be permitted if a practicable altemative that has 

less effect is available. 

The remedial action was designed to 

keep all activities out of the floodplain to 

the greatest extent practicable. 

Ongoing monitoring and O&M activities in and 

adjacent to Meadow Brook or any other Site 

wetlands will meet these standards. 

Fish and Wildlife Coordination Act 

16 U.S.C. 661 

Applicable Before undertaking any Federal action that causes 

the modification of any body of water or affects 

fish and wildlife. 

Federal and State fish and wildlife agencies will be 

consulted concerning any monitoring and O&M 

activities in and adjacent to Meadow Brook. 
AUTHORITY REQUIREMENT STATUS REQUIREMENT SYNOPSIS ACTION TAKEN TO ATTAIN 

ARARs 

Resource Conservation and Recovery Act Relevant and 

(RCRA) Location Standards Appropriate 

(40 C.F.R. 264.18) 

This regulation outlines the requirements for 

constmcting a RCRA facility on a 100-year 

floodplain. 

Hazardous waste disposed of or generated within the 

floodplain of Meadow Brook will be managed to 

prevent a release of hazardous waste in the event of a 

flood event. 

State Regulatory Massachusetts Wetlands Protection Act Applicable 

(M.G.L. C.131 Section 40 

:310CMR10.00) 

Massachusetts Waterways Regulations Applicable 

(M.G.L c.21. Sections 26-53; 314 CMR 9.00) 

These regulations outline the requirements 

necessary to work within 100 feet of a wetland. 

Regulates work within waterways, including 

water quality protection. 

All redevelopment, monitoring, or O&M work within 

areas regulated under this standard will be conducted 

in compliance with these regulations. 

All redevelopment, monitoring, or O&M work within 

or adjacent to Meadow Brook will comply with these 

standards. 

ACTION SPECIFIC ARARs 

Federal Regulatory Resource Conservation and Recovery Act 

Requirements (RCRA) Subtitle C (40 C.F.R. 260-262) 

Toxic Substances Control Act (TSCA), 

15 use . §§ 2601,et seq., 40 C.F.R. 

761.75 

Applicable 

(for generated 

wastes)/; 

Relevant and 

Appropriate 

(for closure/ 

post closure) 

Applicable 

RCRA regulates the generation, transport, 

storage, treatment, and disposal of hazardous 

Waste. CERCLA specifically requires (in 

Section 121(d)(3) that hazardous substances 

from response actions be disposed of at facilities 

in compliance with Subtitle C of RCRA 

Establishes standards for PCB landfills, including 

permitting waivers for clay soils, synthetic liner, 

50 feet to water table, and leachate collection 

requirements upon a finding by the Regional 

Administrator 

Wastes generated during monitoring 

or O & M activities will be characterized 

and handled in accordance with applicable RCRA 

regulations. Wastes left in place under the cap 

will be managed in compliance with closure 

and post-closure standards. 

Closure/post closures standards (incorporating 

waivers invoked under the ROD amendment) for 

the capped PCB wastes will be followed. 

Toxic Substances Control Act (TSCA), 

(40 C.F.R. 760.60) 

Clean Water Act - Sec. 304 

Federal Ambient Water Quality Criteria 

33 us e 1314; 40 CFR 122.44 

Relevant and 

Appropriate 

Establishes treatment and disposal standards for 

PCB wastes generated as part of redevelopment, 

monitoring or O&M activities. 

AWQC are developed under the Clean Water Act 

(CWA) as guidelines from which states develop 

water quality standards. 

Treatment and disposal standards for 

PCB generated wastes will be satisfied. 

AWQC are used to monitor water quality 

in Meadow Brook to assess the protectiveness 

ofthe remedy. 

Guide on Remedial Actions at Superfimd To be 

Sites with PCB Contamination (OSWER considered 

Directive 9355.4-01, August 1990) 

Sets forth guidelines for implementing remedial 

actions for PCBs 

Ongoing monitoring and O&M activities will 

be conducted consistent with the goals of this guidance. 

State Regulatoo' Massachusetts Groundwater Protection Relevant and 

Requirements Regulations Appropriate 

314 CMR 6.00 

These regulations establish the criteria for 

classifying ground water and for establishing 

monitoring standards. 

Groundwater has been reclassified as Class III, 

designated for uses other than as a source of potable, 

water supply. The regulations also set standards that 

will be used for monitoring. 
AUTHORITY REQUIREMENT 

Massachusetts Ambient Air Quality 

Standards 

STATUS REQUIREMENT SYNOPSIS 

Applicable These regulations specify emissions standards for 

particulates and lead. 

ACTION TAKEN TO ATTAIN 

ARARs 

All redevelopment, monitoring and O&M activities 

will be conducted in a manner to minimize the 

generation of dust or other hazardous wastes. 

Massachusetts Air PoJiution Control 

Regulations 

310C.M.R. 7.00 

Applicable 

Massachusetts Hazardous Waste Regulations Applicable 

310C.M.R.30.00 

Regulations specific to control of odor and 

requirements for handling asbestos wastes and 

fugitive dust emissions. 

Regulafions goveming the generation, treatment, 

storage, and disposal of hazardous waste. 

Any odors and fiigiti ve dust generated by O&M, 

redevelopment, and monitoring will be controlled, 

under these standards. 

These regulations will be followed in conducting 

O&M, monitoring, and redevelopment activities. 

Potions of these regulations, which are specific to 

on-site PCBs are not applicable since PCB are 

adequately regulated under TSCA. 

Massachusetts Hazardous Waste Regulations Applicable 

310 CMR. 30.125(b) 

Requirements for Toxic Characteristic Leaching 

Procedure (TCLP). 

Wastes generated for off-site disposal in conducting 

O&M, monitoring, and redevelopment activities 

will be characterized and handled in accordance with 

these standards. 

Massachusetts Hazardous Waste Regulations Applicable 

310 C.M.R. 30.302 

Requirements for any generator of a waste to 

detemiine if the waste is hazardous. 

Wastes generated for off-site disposal in conducting 

O&M, monitoring, and redevelopment activities 

will be characterized and handled in accordance with 

these standards. 
APPENDIX C 

INTERVIEW NOTES 
^^ ^ ^ \ UNITED STATES ENVIRONMENTAL PROTECTION AGENCY 

s ^S.2 ^ I Region 1 

^ ^^^ ^ I 1 Congress Street, Suite 1100 

%^**^ ^ BOSTON, MA 02114-2023 

^ "i PROl*-^ 

Norwood PCB's Site Interviews 

Name: David Buckley Title: Project Manager 

Organization: MassDEP 

What is your relationship to the Norwood PCBs Site? 

Project Manager for the Commonwealth of Massachusetts (acting through MassDEP). 

Are there any issues regarding the site that you would like to bring to EPA's attention? 

Site remediation has been completed to MassDEP's satisfaction. Also, redevelopment 

activities have been substantially completed to MassDEP's satisfaction. Redevelopment 

activities have had to necessarily interact with the site remedy components and EPA, 

MassDEP, the site owner, and developer have worked closely to see the two 

complemented each other. Redevelopment to a shopping center was a beneficial use that 

MassDEP believes is an overall improvement. 

There are a number of minor punch list items which the developer has committed to 

completing in short order. Some of these items are critical to the long term protection 

and monitoring ofthe remedy including the Grant of Environmental Restriction and 

Easement. Of critical importance are installing bench marks to identify the critical cap 

components and updating the as-built plans to reflect actual field conditions. 

Do you believe that the completed Remedial Actions are protective of human health and 

the environment? 

Yes, upon completion ofthe punch list items referenced in the answer to question 1 

above. 

Do you foresee any issues becoming a problem affecting the protectiveness ofthe remedy 

in the future? 

No, as long as the various responsible parties continue to maintain the remedy 

components they are responsible for. To date this has not been a problem. 

Do you have any other questions, comments or concems? 

No 
^^ ^ ^ % UNITED STATES ENVIRONMENTAL PROTECTION AGENCY 

S Region 1 

o ^^^ ^ I 1 Congress Street, Suite 1100 

\^''~., ^ BOSTON, IVIA 02114-2023 

Norwood PCB's Site Interviews 

Name: Albert Ricciardelli Title: Senior Principal 

Organization: GZA GeoEnvironmental, Inc^ 

What is your relationship to the Norwood PCBs Site? 

Project Coordinator for Settling Defendants Remedial Action 

Are there any issues regarding the site that you would like to bring to EPA's attention? 

No 

Do you believe that the completed Remedial Actions are protective of human health and 

the environment? 

Yes 

Do you foresee any issues becoming a problem affecting the protectiveness ofthe remedy 

in the future? 

No 

Do you have any other questions, comments or concems? 

None 
^,^<^^°^r. 

^ ^ ^ ^ UNITED STATES ENVIRONMENTAL PROTECTION AGENCY 

s ^^***rf^ 1 Region 1 

^ ^^^ ^ I 1 Congress Street, Suite 1100 

V^^*^^ ^ BOSTON, MA 02114-2023 

^-tt PROlt*^ 

Norwood PCB's Site Interviews 

Name: Steve Costello Title: Director of Community Planning and 

Economic Development 

Organization: Town of Norwood 

What is your relationship to the Norwood PCBs Site? 

The Norwood Planning Board issued the Special Permit allowing the redevelopment of 

this site. I am the primary contact for the Board. 

Are there any issues regarding the site that you would like to bring to EPA's attention? 

None at this time 

Do you believe that the completed Remedial Actions are protective of human health and 

the environment? 

I think the EPA and DEP have done an outstanding job in assisting the Town with the 

rehabilitation of this site. There were absolutely no issues with the town or abutting 

neighbors because the EPA and the developer agreed to a Work Plan with Remedial 

Actions prior to constmction. This Work Plan addressed the town's primary concem (i.e. 

do not disturb the capped area) and, in my opinion, the final development is very 

protective of human health and the environment. 

Do you foresee any issues becoming a problem affecting the protectiveness ofthe remedy 

in the fiiture? 

None at this time 

Do you have any other questions, comments or concems? 

None at this time 
^''^'^^ \ UNITED STATES ENVIRONMENTAL PROTECTION AGENCY 

s »,^M ^ S Region 1 

I. ^XiA ? ? 1 Congress Street, Suite 1100 

^b^'"^sO ^ BOSTON, MA 02114-2023 

Norwood PCB's Site Interviews 

Name: Jim Grafineyer Title: V.P. Development 

Organization: Developers Diversified Realty (DDR) 

What is your relationship to the Norwood PCBs Site? 

Lessee/Developer 

Are you aware ofthe past remedial activities (capping, groundwater treatment) at the Norwood 

PCBs site? 

Yes 

Are you aware ofthe most recent redevelopment activities at the Norwood PCBs site? 

Yes 

Do you have any questions or concems regarding either the remedial (i.e.. clean-up) activities or 

redevelopment activities at the Norwood PCBs? 

No 

Do you have any recommendations for the USEPA regarding this site? 

No 
APPENDIX D 

PHOTODOCUMENTATION 

Photograph 1: The Redeveloped Site (cap/parking lot foreground/retail buildings background). 

D-1 
Photograph 2: Retail Building A (looking towards Route 1). 

Photograph 3: Retail Building B (looking towards Meadow Brook). 

D-2 
^^^^^^^^B. ! 

1 

r 

Photograph 4: The interior of Retail Building A. 

Photograph 5; Elements ofthe Passive Vapor Mitigation System in 

Building A. 

D-3 
Photograph 6: The Liquid Boot '•'^ Vapor Barrier layer which underlies concrete slab. 

Photograph 7: Roof penetration and exhaust vent to passive Vapor Mitigation System (Retail 

Building A). 

D-4 
Photograph 8: The interior of Retail Building B. 

Photograph 9: Elements ofthe Passive Vapor Mitigation System in Retail Building B. 

D-5 
Photograph 10: The Liquid Boot ^^ Vapor Barrier layer which underlies concrete slab. 

Photograph 11: The newly-constructed parking lot that overlies the Remedial Cap. 

D-6 
Photograph 12: The northwest edge ofthe parking lot and property botmdary with Kerry Place. 

Photograph 13: Detention basin facing Southeast with maintenance crews visible. 

D-7 
Photograph 14: Grounds crew maintaining detention basin. 

Photograph 15: Meadow Brook, looking facing down stream (Southeast). 

D-8 
Photograph 16: Strom drain point of discharge into the detention basin. 

Photograph 17: Overgrowth on slope ofthe detention basin along Meadow Brook. 

D-9 
r*'^# 

Photograph 18: Shopping cart discarded in Meadow Brook. 

teSho ppes 

01vya>;Parr]r|s 

f O R LEASE 

pBJ^g ^•^1 

HBHI • ^ H 

•IH I 

^ ^ H 

• • q •1^ 

• • • 

•I^H 

H H 

• • 

Photograph 19: Sign fronting Rt. 1. 

D-10 
Photograph 20: The mural on the rear of Retail Building A, as viewed from Route 1 (required by the Town of Norwood). 

Photograph 21: Sub-slab sampling ports located along the rear of Retail Building A 

D-11 
Photograph 22: Sub-slab sampling ports located along the rear of Retail Building B. 

^^^H^B^^rX'*^ 

^Ki" .'j3^atSM 

A 1 

« ! ' 

6 ^ 

•"^ 

^•mk 

c,. ^'v " 

g ^ 

k 

^ ^ • 

•'4.yf^;:,.';.;..;:»,> ^ -• 

b . 

^ 

0 ^ 

:a-.< ^ 

n • 

^ 

4 1 %lfiL. 

ri^-:".»m: 

WHt-^ 

- \ '-f 

r 

Photograph 23: Sub-slab sampling ports located along the rear of Retail Building B. 

D-12 
APPENDIX E 

SITE INSPECTION CHECKLISTS 

E-l 
Five-Year Review Site Inspection Checklist 

Norwood PCBs Superfund Site, Norwood, Massachusetts 

I. SITE INFORMATION 

Site name: Norwood PCBs Date of Inspection: July 8,2009 

Location and Region: Rt. 1 and Dean St, Norwood, 

Massachusetts, USEPA Region I 

EPA ID: MAD980670566 

Agency, office, or company leading the five-year 

review: USEPA Region I 

Weather/temperature: Partly Cloudy ~ 70 F 

Remedy Includes: (Check all that apply) 

• Landfill cover/containment 

n Access controls 

• Institutional controls 

D Groundwater pump and treatment 

n Surface water collection and treatment 

D Other 

D Monitored natural attenuation 

D Groundwater containment 

D Vertical barrier walls 

Attachments: D Inspection team roster attached n Site map attached 

II. INTERVIEWS (Check all that apply) 

1. O&M site manager Albert Ricciardelli Senior Principal. GZA 

Interviewed 

Name 

at site D at office D by phone Phone no. 

Title Date 

Problems, suggestions; Report attached Interview record attached 

2. O&M staff 

Name 

Interviewed D at site D at office D by phone Phone no. 

Problems, suggestions; Report attached 

Title Date 

E-2 
3. Local regulatory authorities and response agencies (i.e., State and Tribal offices, emergency response 

office, police department, office of public health or environmental health, zoning office, recorder of 

deeds, or other city and county offices, etc.) Fill in all that apply. 

Agency Environmental Protection Agency 

Contact Daniel Keefe 

Name Title 

Problems; suggestions; D Report attached 

Remedial Project Manager 7-8-2009 

Date 

Agency Environmental Protection Agency 

Contact Shamus Keohane Intern 7-8-2009 

Name Title 

Problems; suggestions; D Report attached 

Date 

617-918-1327 

Phone no. 

Phone no. 

Agency Massachusetts Department of Environmental Protection 

Contact David Buckeyt Project Manager 12/09 617-556-1156 

Name 

Problems; suggestions; • Report attached 

Title Date Phone no. 

4. Other interviews (optional) • Reports attached. 

Joe Laham - Site Owner 

Steve Costello - Town of Norwood 

Paul Dansczak - Developers Diversified Realty 

E-3 
III. ON-SITE DOCUMENTS & RECORDS VERIFIED (Check all that apply) 

1. 

2. 

3. 

4. 

5. 

6. 

7. 

8. 

9. 

10. 

O&M Documents 

• O&M manual • Readily available 

• As-built drawings • Readily available 

n Maintenance logs D Readily available 

Remarks 

D 

n 

n 

Site-Specific Health and Safety Plan • Readily available • 

D Contingency plan/emergency response plan D Readily available D 

Remarks This H&S Plans exist for O&M and Redevelopment activities. 

O&M and OSHA Training Records • Readily available 

Remarks 

Permits and Service Agreements 

D Air discharge permit D Readily available 

n Effluent discharge D Readily available 

D Waste disposal, POTW D Readily available 

D Other permits Dumpster for the City D Readily available 

Remarks 

• 

D 

D 

D 

• 

Up to date 

Up to date 

Up to date 

Up to date 

Up to date 

Up to date 

Up to date 

Up to date 

Up to date 

Up to date 

Gas Generation Records D Readily available D Up to date 

Remarks 

Settlement Monument Records D Readily available 

Remarks 

D Up to date 

Groundwater Monitoring Records • Readily available • Up to date 

Remarks These records are submitted annual in Groundwater Monitoring Reports 

Leachate Extraction Records D Readily available 

Remarks 

Discharge Compliance Records 

D Air • Readily available 

D Water (effluent) D Readily available 

Remarks 

DaUy Access/Security Logs D Readily available 

Remarks 

D 

D 

D 

D 

Up to date 

Up to date 

Up to date 

Up to date 

D N/A 

D N/A 

• N/A 

D N/A 

D N/A 

D N/A 

• N/A 

• N/A 

• N/A 

• N/A 

• N/A 

• N/A 

D N/A 

• N/A 

• N/A 

• N/A 

• N/A 

E-4 
rv. O&M COSTS 

O&M Organization 

n State in-house D Contractor for State 

D PRP in-house • Contractor for PRP 

n Federal Facility in-house D Contractor for Federal Facility 

D Other 

2. O&M Cost Records 

D Readily available D Up to date 

• Funding mechanism/agreement in place 

• Original O&M cost estimate: Contractor -negotiated O&M for fixed price over 30 years 

D Breakdown attached 

From 

From 

From 

From 

From 

Date 

Date 

Date 

Date 

Total annual cost by year for review period if available 

n Breakdown attached 

Date Total Cost 

Date Total Cost 

Date Total Cost 

Date Total Cost 

D Breakdown attached 

D Breakdown attached 

D Breakdown attached 

D Breakdown attached 

Date Date Total Cost 

3. Unanticipated or Unusually High O&M Costs During Review Period 

Describe costs and reasons: 

Not applicable (none). 

V. ACCESS AND INSTITUTIONAL CONTROLS • Applicable D N/A 

A. Fencing 

1. Fencing damaged D Location shown on site map D Gates secured • N/A 

Remarks This site is not fenced 

B. Other Access Restrictions 

1. Signs and other security measures D Location shown on site map • N/A 

Remarks The site is redeveloped and is open to the public. 

E-5 
C. Institutional Controls (ICs) 

1. Implementation and enforcement 

Site conditions imply ICs not properly implemented D Yes • No D N/A 

Site conditions imply ICs not being fully enforced D Yes • No D N/A 

Type of monitoring (e.g., self-reporting, drive by) Site visits 

Frequency No less than quarterly 

• Yes 

• Yes 

• Yes 

n Yes 

Phone 

D No 

D No 

D No 

• No 

no. 

• N/A 

D N/A 

D N/A 

D N/A 

Responsible party/agency MassDEP is responsible: however, site visits routinely conducted by 

PRP's consultants (GZA). EPA and MassDEP. 

Contact David Buckley Project Manager 617-556-1156 

Name Title 

Reporting is up-to-date 

Reports are verified by the lead agency 

Specific requirements in deed or decision documents have been met 

Violations have been reported 

Other problems or suggestions: b Report attached 

Institutional Controls include following (general) use restrictions: no groundwater withdrawal, no 

interference with response actions, disruption of caps, or excavation of contaminated material. 

No formal reports required by MassDEP: however, property use is described (and updated) in Aimual 

Monitoring reports prepared by GZA and reviewed by EPA and MassDEP 

2. Adequacy • ICs are adequate • ICs are inadequate D N/A 

Remarks 

D. General 

1. Vandalism/trespassing D Location shown on site map D No vandalism evident 

Remarks Graffiti was noticed during one site inspection and has since been removed. 

2. Land use changes on site • Redevelopment D N/A 

Remarks The site has been redeveloped for commercial/retail use. Two buildings 

are on the site but are currently vacant. 

3. Land use changes off site • N/A 

Remarks 

VI. GENERAL SITE CONDITIONS 

A. Roads • Applicable D N/A 

1. Roads damaged D Location shown on site map • Roads adequate D N/A 

Remarks 

E-6 
B. 

A. 

1. 

2. 

3. 

4. 

5. 

6. 

7. 

8. 

9. 

Other Site Conditions 

Remarks As a result ofthe completed redevelopment, site conditions are generally improved 

(for example there 

Landfill Surface 

are new access 

VII. 

Settlement (Low spots) 

Areal extent 

Remarks 

Cracks 

Lengths 

Remarks 

Erosion 

Areal extent 

Remarks 

Holes 

Areal extent 

Remarks 

Vegetative Cover 

n Trees/Shrubs (indicate 

Remarks 

road, additional asphalt over the cap . mcreased lightmg. etc.). 

LANDFILL COVERS • Applicable D N/A 

Widths 

D Location shown on site map 

Depth 

D Location shown on site map 

Depths 

n Location shown on site map 

Depth 

n Location shown on site map 

Depth 

• Settlement not evident 

• Cracking not evident 

• Erosion not evident 

• Holes not evident 

D Grass D Cover properly established D No signs of stress 

size and locations on a diagram) 

Alternative Cover (armored rock, concrete, etc.) • Additional Layer: Parking Lot 

Remarks As a result of redevelopment, an asphalt parking lot was installed over the remedial 

cap. 

Bulges 

Areal extent 

Remarks 

Wet Areas/Water 

D Wet areas 

n Ponding 

D Seeps 

D Soft subgrade 

Remarks 

Slope Instability 

Areal extent 

Remarks 

Damage 

D Slides 

D Location shown on site map 

Height 

• Wet areas/water damage not evi 

n Location shown on site map 

D Location shown on site map 

D Location shown on site map 

n Location shown on site map 

• Bulges not evident 

dent 

Areal extent 

Areal extent 

Areal extent 

Areal extent 

D Location shown on site map • No evidence of slope instability 

E-7 
B. Benches D Applicable • N/A 

(Horizontally constructed moimds of earth placed across a steep landfill side slope to interrupt the slope 

in order to slow down the velocity of surface runoff and intercept and convey the runoff to a lined 

chaimel.) 

1. Flows Bypass Bench 

Remarks 

D Location shown on site map N/A or okay 

2. Bench Breached 

Remarks 

D Location shown on site map N/A or okay 

3. Bench Overtopped 

Remarks 

D Location shown on site map N/A or okay 

C. Letdown Channels D Applicable • N/A 

(Channel lined with erosion control mats, riprap, grout bags, or gabions that descend down the steep side 

slope ofthe cover and will allow the nmoff water collected by the benches to move off of the landfill 

cover without creating erosion gullies.) 

1. Settlement 

Areal extent_ 

Remarks 

D Location shown on site map D No evidence of settlement 

Depth 

2. Material Degradation D Location shown on site map IH No evidence of degradation 

Material type Areal extent 

Remarks 

Erosion 

Areal extent_ 

Remarks 

D Location shown on site map D No evidence of erosion 

Depth 

Undercutting 

Areal extent 

Remarks 

D Location shown on site map • No evidence of undercutting 

Depth 

Obstructions Type 

n Location shown on site map 

Size 

Remarks 

D No obstructions 

Areal extent 

6. Excessive Vegetative Growth Type 

n No evidence of excessive growth 

D Vegetation in channels does not obstruct flow 

D Location shown on site map Areal extent_ 

Remarks 

D. Cover Penetrations • Applicable D N/A 

E-8 
Gas Vents D Active D Passive 

D Properly secured/lockedD Fimctioning D Routinely sampled 

• Evidence of leakage at penetration D Needs Maintenance 

Remarks 

• Good condition 

• N/A 

Gas Monitoring Probes 

D Properly secured/lockedD Functioning 

D Evidence of leakage at penetration 

Remarks 

D Routinely sampled 

D Needs Maintenance 

D Good condition 

• N/A 

3. Monitoring Wells (within surface area of Cap) 

D Properly secured/locked • Functioning • Routinely sampled • Good condition 

D Evidenceof leakage at penetration • Needs Maintenance D N/A 

Remarks One groundwater monitoring well was noted to be missing a lock in the north 

cover area. This is a redevelopment punch list item. 

4. Leachate Extraction Wells 

D Properly secured/lockedD Fimctioning D Routinely sampled D Good condition 

n Evidence of leakage at penetration D Needs Maintenance • N/A 

Remarks 

5. Settlement Monuments 

Remarks 

D Located D Routinely surveyed N/A 

E. Gas Collection and Treatment D Applicable N/A 

1. Gas Treatment Facilities 

D Flaring D Thermal destruction D Collection for reuse 

n Good condition • Needs Maintenance 

Remarks 

Gas Collection Wells, Manifolds and Piping 

D Good condition D Needs Maintenance 

Remarks 

Gas Monitoring Facilities (e.g., gas monitoring of adjacent homes or buildings) 

D Good condition D Needs Maintenance D N/A 

Remarks 

F. Cover Drainage Layer n Applicable N/A 

1. Outlet Pipes Inspected 

Remarks 

n Functioning D N/A 

2. Outlet Rock Inspected 

Remarks 

D Functioning D N/A 

E-9 
G. Detention/Sedimentation Ponds • Applicable D N/A 

A detention basin is located along the northem edge ofthe property and is used to manage stormwater 

form the Roof drains and parking lot (i.e.. Cap). 

1. Siltation Areal extent_ 

• Siltation not evident 

Remarks 

Depth D N/A 

2. Erosion Areal extent_ 

• Erosion not evident 

Remarks 

Depth_ 

Outlet Works 

Remarks 

Functioning D N/A 

4. Dam 

Remarks 

D Functioning • N/A 

Vegetative Growth D Location shown on site map D N/A 

• Vegetation does not impede flow 

Areal extent Type 

Remarks Vegetative growth in the detention basin is maintained by grounds crew 2 times per year. 

E-10 
H. Retaining WaUs n Applicable N/A 

1. Deformations D Location shown on site map • Deformation not evident 

Horizontal displacement Vertical displacement 

Rotational displacement 

Remarks 

2. Degradation 

Remarks 

D Location shown on site map D Degradation not evident 

I. Perimeter Ditches/Off-Site Discharge • Applicable D N/A 

Meadow Brook flows along the northem edge ofthe site and receives stormwater from the detention 

1. 

basins. 

Siltation 

Areal extent_ 

Remarks 

D Location shown on site map 

Depth 

Siltation not evident 

Vegetative Growth D Location shown on site map D N/A 

• Vegetation does not impede flow 

Areal extent Type 

Remarks While the flow does not seem to be restricted, some debris has accumulated in the 

Brook and the vegetation on the side slopes is moderate. The Town has been made aware of their 

responsibility to perform the recommend O&M as per the O&M Manual for Meadow Brook. 

Erosion 

Areal extent_ 

Remarks 

D Location shown on site map 

Depth 

Erosion not evident 

Discharge Structure 

Remarks 

Functioning D N/A 

VIII. VERTICAL BARRIER WALLS D Applicable N/A 

Settlement 

Areal extent_ 

Remarks 

n Location shown on site map 

Depth 

n Settlement not evident 

Performance Monitoring Type of monitoring 

n Performance not monitored 

Frequency 

Head differential 

Remarks 

D Evidence of breaching 

E-11 
IX. GROUNDWATER/SURFACE WATER REMEDIES D Applicable • N/A 

A. Groundwater Extraction Wells, Pumps, and Pipelines D Applicable • N/A 

1. Pumps, Wellhead Plumbing, and Electrical 

n Good condition D All required wells properly operating D Needs Maintenance • N/A 

Remarks 

2. Extraction System Pipelines, Valves, Valve Boxes, and Other Appurtenances 

D Good condition D Needs Maintenance 

Remarks 

3. Spare Parts and Equipment 

D Readily available D Good condition D Requires upgrade D Needs to be provided 

Remarks 

B. Surface Water Collection Structures, Pumps, and Pipelines D Applicable • N/A 

1. Collection Structures, Pumps, and Electrical 

n Good condition D Needs Maintenance 

Remarks 

2. Surface Water Collection System Pipelines, Valves, Valve Boxes, and Other Appurtenances 

D Good condition D Needs Maintenance 

Remarks 

3. Spare Parts and Equipment 

D Readily available D Good condition D Requires upgrade D Needs to be provided 

Remarks 

E-12 
C. Treatment System D Applicable N/A (GWTP decommissioned and removed) 

1. Treatment Train (Check components that apply) 

D Metals removal D Oil/water separation: 

D Air stripping D Carbon adsorbers: _ 

D Filters 

D Bioremediation 

D Additive (e.g. 

D Others 

, chelation agent, flocculent) 

D Good condition D Needs Maintenance 

D Sampling ports properly marked and functional 

n Sampling/maintenance log displayed and up to date 

D Equipment properly identified 

Quantity of groundwater treated annually 

Quantity of surface water treated annually 

Remarks 

Electrical Enclosures and Panels (properly rated and functional) 

D N/A D Good condition D Needs Maintenance 

Remarks 

Tanks, Vaults, Storage Vessels 

D N/A D Good condition 

Remarks 

D Proper secondary containment D Needs Maintenance 

Discharge Structure and Appurtenances 

n N/A n Good condition 

Remarks 

D Needs Maintenance 

5. Treatment BuUding(s) 

D N/A D Good condition D 

D Chemicals and equipment properly stored 

Remarks 

Needs repair 

6. Monitoring Wells (pump and treatment remedy) 

n Properly secured/locked D Functioning D Routinely sampled • Good condition 

n All required wells located D Needs Maintenance D N/A 

Remarks 

D. Monitoring Data 

The last comprehensive monitoring data was collected on July 2005 (31 monitoring wells and 9 

extraction wells). Since that that time, bi-annual groundwater monitoring has continued as part ofthe 

PRPs Cap and Cover O&M Plan. Aimual reports are received. 

1. Monitoring Data 

• Is routinely submitted on time Is of acceptable quality 

Monitoring data suggests: 

• Groundwater plume is effectively contained D Contaminant concentrations are declining 

E-13 
D. Monitored Natural Attenuation 

1. Monitoring Wells (natural attenuation remedy) 

D Properly secured/locked D Functioning D Routinely sampled 

n All required wells located D Needs Maintenance 

Remarks 

D Good condition 

• N/A 

X. OTHER REMEDIES 

If there are remedies applied at the site which are not covered above, attach an inspection sheet describing 

the physical nature and condition of any facility associated with the remedy. An example would be soil 

vapor extraction. 

XL OVERALL OBSERVATIONS 

B. 

D. 

Implementation of the Remedy 

Describe issues and observations relating to whether the remedy is effective and functioning as designed. 

Begin with a brief statement of what the remedy is to accomplish (i.e., to contain contaminant plume, 

minimize infiltration and gas emission, etc.). 

The purpose ofthe remedy is isolated and prevent direct contact with PCB-contaminated soil and sediment. 

Based upon the site inspection, monitoring results, and observations during this review, the remedy appears 

to be functioning as intended. New groundwater cleanup goals established in the 2005 ESD have been met. 

The Site was approved for and subsequently redeveloped in 2008. 

Adequacy of O&M 

Describe issues and observations related to the implementation and scope of O&M procedures. In 

particular, discuss their relationship to the current and long-term protectiveness ofthe remedy. 

O&M plans exist for the Cap and Cover area ofthe site and the Meadow Brook parcel. However, the O&M 

plan needs to be updated so as to reflect minor changes as a result ofthe completed redevelopment. 

Early Indicators of Potential Remedy Problems 

Describe issues and observations such as unexpected changes in the cost or scope of O&M or a high 

frequency of unscheduled repairs that suggest that the protectiveness ofthe remedy may be compromised in 

the fiiture. 

No issues or observations which suggest the protectiveness ofthe remedy may be compromised. 

Opportunities for Optimization 

Describe possible opportunities for optimization in monitoring tasks or the operation ofthe remedy. 

Remedial Action is complete and the Final Close-out Report (FCOR) has been prepared. Remaining 

remedial activities consist predominantly of PRP-lead O&M activities, therefore, no real opportunity for 

optimization. 

E-14