Superfund Records Center

SITE*. t^Qf

BREAK.:

Norwood PCB OTHER:

NPL Site Administrative Record

Index

Compiled: August 11, 1989

ROD Signed: September 29, 1989

Prepared for

Region I

Waste Management Division

U.S. Environmental Protection Agency

With Assistance from

EBASCO SERVICES, INC.

211 Congress Street, Boston, Massachusetts 02110
Introduction

This document is the Index to the Administrative Record for the Norwood PCB

National Priorities List (NPL) Site. Section I of the Index cites site-specific documents,

and Section II cites guidance documents used by EPA staff in selecting a response

action at the site.

The Administrative Record is available for public review at EPA Region I's office in

Boston, Massachusetts, and at the Morrill Memorial Library, Walpole Street, Norwood,

Massachusetts, 02062. Questions concerning the Administrative Record should be

addressed to the EPA Region I site manager.

The Administrative Record is required by the Comprehensive Environmental Response

Compensation and Liability Act (CERCLA), as amended by the Superfund

Amendments and Reauthorization Act (SARA).
SECTION I

SITE-SPECIFIC DOCUMENTS
ADMINISTRATIVE RECORD INDEX

for the

Norwood PCB NPL Site

1.0 PRE-REMEDIAL

1.14 FIT Contract

1. "Massachusetts FIT Contract - Work and Cost Plan Proposal -

Grant Gear Company - Problem Evaluation Study - Site

Response Assessment - Site Management Plan," Wehran

Engineering (June 6, 1985).

1.18 FIT Technical Direction Documents (TDDs) and Associated Records

1. "Geophysical Survey," Weston Geophysical Corporation for NUS

Corporation (July 1984). NOTE: Oversize Maps and figures

are available for review at EPA, Region I, Boston,

Massachusetts.

2. "Field Investigation of the Norwood Site, Norwood,

Massachusetts," NUS Corporation (September 10, 1984).

2.0 REMOVAL RESPONSE

2.1 Correspondence

1. Letter from Anthony D. Cortese, Massachusetts Department of

Environmental Quality Engineering to Paul Keough, EPA Region

I (June 16, 1983). Concerning immediate removal action at the

Norwood PCB site.

2. Memorandum from David Mclntyre, EPA Region I to Richard T.

Leighton, EPA Region I (August 5, 1983). Concerning

immediate removal action at the Dean Street site.

3. Memorandum from Frank W. Lilley, EPA Region I to Dave

Mclntyre, EPA Region I (September 15, 1983). Concerning

Norwood II Airborne PCB investigation.

4. Letter from Richard Chalpin, Massachusetts Department of

Environmental Quality Engineering to William E. Baird, WEB

Engineering Associates, Incorporated (February 14, 1984).

Concerning review of four reports entitled "Kerry Place,

Norwood, Lots #1, #2, #3, and #4; Report of On Site

Investigation of Possible Chemical Contamination," dated

February 1, 1984.
2.1 Correspondence (cont'd)

5. Letter from Cameron Kerry, Mintz, Levin, Cohn, Ferris, Glovsky

& Popeo (Attorney for Grant Gear Works, Incorporated) to

Susan Bernard, Massachusetts Office of the Attorney General

(January 28, 1986). Concerning recent site activities relating to

on-site car storage and soil sampling.

2.4 Pollution Reports (POLREPs)

1. POLREP 1, (June 28, 1983).

2. POLREP 2, (July 1, 1983).

3. POLREP 3, (July 11, 1983).

4. POLREP 4, (July 12, 1983).

5. POLREP 5, (July 29, 1983).

6. POLREP 6, (August 3, 1983).

2.5 On-Scene Coordinator Report

1. "On-Scene Coordinator's Report," (June - August, 1983).

Including Attachments 1-21. (Confidential business information

redacted.)

3.0 REMEDIAL INVESTIGATION (Rl)

3.1 Correspondence

1. Notice from Bartley King, Norwood Board of Health and John

Carroll, Norwood Board of Selectmen to the residents of

Meadowbrook area (June 28, 1983). Concerning analysis of

soil samples.

2. Notice from Bartley King, Norwood Board of Health, and John

Carroll, Norwood Board of Selectment to residents of

Meadowbrook area (June 29, 1983). Concerning analysis of

soil samples.

3. Memorandum from John Figler, EPA Region I to Merrill S.

Hohman, EPA Region I (August 2, 1983). Concerning Norwood

PCB Blood Results.

4. Notice from Patricia Talbot, Norwood Board of Health and

Bernard Cooper, Norwood Board of Selectmen to residents of

Meadowbrook area (August 12, 1983). Concerning PCB test

results.

5. Letter from Robert Hurley, Grant Gear Works, Incorporated to

Leonard Pagnotto, Massachusetts Department of Labor and

Industries (December 7, 1983). Concerning letter of November

29, 1983.
3.1 Correspondence (cont'd)

6. Letter from David Christian!, Edward Baker, and Elizabeth Averill,

Norfolk County Hospital to Robert Hurley, Grant Gear Works,

Incorporated (September 24, 1984). Concerning group results

of PCB analysis of Grant Gear Works, Incorporated employees.

7. Letter from James C. Colman, Massachusetts Department of

Environmental Quality Engineering to John J. Carroll, Norwood

Town Manager (October 8, 1985). Concerning the presence of

Polychlorinated Biphenyl (PCB) contaminated material on and

around property owned by Grant Gear Realty Trust.

8. Letter from James Colman, Massachusetts Department of

Environmental Quality Engineering to John Hannon,

Massachusetts Department of Environmental Management

(January 15, 1986). Concerning analytical results on water and

sediment samples/Meadow Brook.

9. Letter from Susan M. Bernard, Department of the Attorney

General to Janine M. Sweeney, Morgan, Lewis & Bockius

(Attorney for Federal Pacific Electric); Cameron F. Kerry, Mintz,

Levin, Cohn, Ferris, Glovsky & Popeo (Attorney for Grant Gear

Works, Incorporated); Robert F. Sanoff, Foley, Hoag & Eliot

(Attorney for Cornell-Dubilier Electronics, Incorporated); Anton T.

Moehrke, Wright & Moehrke (February 11, 1986). Concerning

clients' agreement to prepare a scope of work for a Remedial

Investigation/Feasibility Study at the Grant Gear Works

Superfund site.

10. Letter from Cameron F. Kerry, Mintz, Levin, Cohn, Ferris,

Glovsky & Popeo (Attorney for Grant Gear Works, Incorporated)

to Philip R. Boxell, EPA Region I (July 11, 1986). Concerning

EPA's decision not to include any remedial investigation of PCB

contamination inside the industrial plant located at the site.

11. Letter from Susan M. Bernard, Department of the Attorney

General to Janine M. Sweeny, Morgan, Lewis & Bockius

(Attorney for Federal Pacific Electric); Cameron F. Kerry, Mintz,

Levin, Cohn, Ferris, Glovsky & Popeo (Attorney for Grant Gear

Works, Incorporated); Robert F. Sanoff, Foley, Hoag & Eliot

(Attorney for Cornell-Dubilier Electronics, Incorporated); Anton T.

Moehrke, Wright & Moehrke (July 15, 1986). Concerning DEQE

and EPA review of RI/FS Scope of Work at the Norwood

Superfund Site.

12. Letter from Susan M. Bernard, Department of the Attorney

General to Janine M. Sweeny, Morgan, Lewis & Bockius

(Attorney for Federal Pacific Electric); Cameron F. Kerry, Mintz,

Levin, Cohn, Ferris, Glovsky & Popeo (Attorney for Grant Gear

Works, Incorporated); Robert F. Sanoff, Foley, Hoag & Eliot

(Attorney for Cornell-Dubilier Electronics, Incorporated); Anton T.

Moehrke, Wright & Moehrke (August 14, 1986). Concerning

DEQE and EPA review of RI/FS Scope of Work at the Norwood

Superfund Site.
3.1 Correspondence (cont'd)

13. Letter from Thomas McMahon, Massachusetts Department of

Environmental Quality Engineering to John Hannon,

Massachusetts Department of Environmental Management

(September 26, 1986). Concerning application for Water Quality

Certification.

14. Letter from Cameron F. Kerry, Mintz, Levin, Cohn, Ferris,

Glovsky & Popeo (Attorney for Grant Gear Works, Incorporated)

to Honorable Joyce London Alexander, United States Magistrate

(November 25, 1986). Concerning Hurley et al., v. CornellDubilier Electronics, Incorporated et al., Civil Action No. 85-

1417-MC.

15. Letter from Susan M. Bernard, Department of the Attorney

General to Honorable Joyce London Alexander, United States

Magistrate (November 28, 1986). Concerning response to

Cameron F. Kerry's letter of November 25, 1986.

16. Letter from Cameron F. Kerry, Mintz, Levin, Cohn, Ferris,

Glovsky & Popeo (Attorney for Grant Gear Works, Incorporated)

to Honorable Joyce London Alexander, United States Magistrate

(December 3, 1986). Concerning response to letters dated

November 25 and 28, 1986.

17. Letter from Cameron F. Kerry, Mintz, Levin, Cohn, Ferris,

Glovsky & Popeo (Attorney for Grant Gear Works, Incorporated)

to Philip R. Boxell, EPA Region I (December 3, 1986).

Concerning Grant Gear Works' involvement in expediting a

prompt remedy at the Norwood PCB site.

18. Letter from Laurie Burt, Foley, Hoag & Eliot (Attorney for

Cornell-Dubilier Electronics, Incorporated) to Lee Breckenridge,

EPA Region I (December 9, 1986). Concerning handling of the

Cornell-Dubilier Electronics, Incorporated proposal to perform

the Remedial Investigation and Feasibility Study at the Grant

Gear Works Site.

19. Letter from William F. Cass, Massachusetts Department of

Environmental Quality Engineering to Merrill Hohman, EPA

Region I (March 16, 1987). Concerning the Department of

Environmental Quality Engineering's decision to refer the lead

for the Norwood PCB site to EPA.

20. Letter from James C. Colman, Massachusetts Department of

Environmental Quality Engineering to Robert F. Sanoff, Foley,

Hoag & Eliot (Attorney for Cornell-Dubilier Electronics,

Incorporated) (March 18, 1987). Concerning the conditional

offer by Cornell-Dubilier Electronics, Incorporated to perform the

Remedial Investigation and Feasibility Study at the Norwood

Superfund site.

21. Letter from Marvin Rosenstein, EPA Region I to John J.

Hannon, Massachusetts Department of Environmental

Management (August 11, 1987). Concerning flood and erosion

control project.
3.2 Sampling and Analysis Data

Sampling and analysis data for the Remedial Investigation may

be reviewed, by appointment only, at EPA Region I, Boston,

Massachusetts. /.•-. - >- ^

3.4 Interim Deliverables

1. "Interim Report on Drainage System Contamination," Camp

Dresser & McKee Incorporated (January 19, 1988).

2. Memorandum from Susan Henderson, Camp, Dresser & McKee

to A. Quaglieri, Camp, Dresser & McKee (February 17, 1988).

Concerning soil boring under floor slab in Grant Gear Works

building.

3.6 Remedial Investigation (Rl) Reports

1. "Draft Report - Summary of Field Work - Norwood PCB Site,"

COM, Incorporated (September 28, 1988). (Confidential

business information redacted.)

2. "Final Remedial Investigation Report," ICF Incorporated for

Ebasco Services Incorporated, Volumes I and II (June 1989).

3. "Grant Gear Indoor Survey Results.Norwood PCB Site,

Norwood, Massachusetts" EPA Region I (June 1989).

3.7 Work Plans and Progress Reports

1. "Technical Oversight for EPA TES III - Work Plan," COM Federal

Programs Corporation (December 18, 1987).

2. "Work Plan - Remedial Investigation and Feasibility Study," ICF

Incorporated for Ebasco Services Incorporated (December

1987).

3. "Plan for Soil Sampling Below Slab on Grade at Grant Gear,

Incorporated, Norwood, Massachusetts," Camp, Dresser &

McKee, Incorporated (January 1988). (Confidential business

information redacted.)

4. "Plan for Video Examination of Drains at Grant Gear

Incorporated - Norwood Massachusetts," Camp Dresser &

McKee Incorporated (January 1988). (Confidential business

information redacted.)

5. "Grant Gear Indoor Survey Work Plan," EPA Region I (April

1989).
3.9 Health Assessments

1. Cross-reference: Notice from Patricia Talbot, Norwood Board of

Health, and Bernard Cooper, Norwood Board of Selectmen to

residents of Meadowbrook area (August 12, 1983). Concerning

PCB test results. (Filed and cited as entry number 4 in 3.1

Correspondence.)

2. Letter from David Christian! and Nancy Fox, Norfolk County

Hospital to Robert Hurley, Grant Gear Works, Incorporated

(August 29, 1983). Concerning transmittal of attached "Report

of PCB Blood Levels among Grant Gear Employees," Norfolk

County Hospital.

3. Letter from Leonard Pagnotto, Massachusetts Department of

Labor and Industries to Jack Lawler, Grant Gear Works,

Incorporated (November 29, 1983). Concerning transmittal of

attached letter report on health hazards to Grant Gear Works,

Incorporated employees.

4. Cross-reference: Letter from Robert Hurley, Grant Gear Works,

Incorporated to Leonard Pagnotto, Massachusetts Department

of Labor and Industries (December 7, 1983). Concerning letter

of November 29, 1983. (Filed and cited as entry number 5 in

3.1 Correspondence.)

5. "PCB Exposure Assessment in Norwood," Martha Steele,

Division of Environmental Health Assessment, Massachusetts

Department of Public Health (February 22, 1984).

6. Letter from David Christiani, Edward Baker, and Elizabeth Averill,

Norfolk County Hospital to Robert Hurley, Grant Gear Works,

Incorporated (August 29, 1984). Concerning transmittal of

attached "Report of Follow-up PCB Study at Grant Gear,"

Norfolk County Hospital (August 29, 1984).

7. Cross-reference: Notice from Bartley King, Norwood Board of

Health, and John Carroll, Norwood Board of Selectment to

residents of Meadowbrook area (June 29, 1983). Concerning

analysis of soil samples. (Filed and cited as entry number 2 in

3.1 Correspondence.)

3.10 Endangerment Assessments

1. "Final Endangerment Assessment Report," ICF Incorporated for

Ebasco Services Incorporated (August 1989).
4.0 FEASIBILITY STUDY (FS)

4.1 Correspondence

Letter from Cameron Kerry, Mintz, Levin, Conn, Ferris, Glovsky

& Popeo (Attorney for Grant Gear Works, Incorporated) to

David Fierra, EPA Region I, and William Gaughan,

Massachusetts Department of Environmental Protection (August

24, 1989). Concerning transmittal of "Evaluation of Discharge

Options for the Grant Gear Site, Norwood, Massachusetts"

ENSR Consulting and Engineering (August 1989). [("Evaluation

of Discharge Options for the Grant Gear Site ," (August 1989)

is file and cited as entry number 4 in 4.6 Feasibility Study (FS)

Reports.)]

4.4 Interim Deliverables

1. "Oversight at Grant Gear - Norwood Massachusetts - During

Pipeline Video Taping," COM Federal Programs Corporation

(March 15, 1988).

2. "Trip Report - Grant Gear Building, Norwood, Massachusetts,

Dye Testing of Sewer Connection," CDM Federal Programs

Corporation (April 12, 1988).

4.6 Feasibility Study (FS) Reports

1. Letter Report from Charles Martin and Jeffrey Lawson, ERT to

Cameron Kerry, Mintz, Levin, Cohn, Ferris, Glovsky & Popeo

(Attorney for Grant Gear Works, Incorporated) (June 10, 1988).

Concerning summary evaluation of drainage line remedial

actions.

2. "Feasibility Study Report," ICF Incorporated for Ebasco Services

Incorporated (August 1989).

3. "Draft Feasibility Study for the Grant Gear Building, Norwood

PCB Site, Norwood, Massachusetts," Camp, Dresser & McKee

(August 17, 1989).

4. "Evaluation of Discharge Options for the Grant Gear Site -

Norwood, MA," ENSR Consulting Engineering (August 1989).

(Confidential business information redacted.)

Comments received by EPA Region I during the formal public comment

period on the Feasibility Study and Proposed Plan are filed and cited in

5.3 Responsiveness Summaries.
4.7 Work Plans and Progress Reports

1. Cross-Reference: "Work Plan - Remedial Investigation and

Feasibility Study," ICF Incorporated for Ebasco Services

Incorporated (December 1987) (Filed and cited as entry number

2 in 3.7 Work Plans and Progress Reports.)

4.9 Proposed Plans for Selected Remedial Actions

1. "EPA Proposes Clean-up Plan for the Norwood PCB Site," EPA

Region I (August 1989).

2. Memorandum from Jane Downing, EPA Region I to File (August

14, 1989). Concerning Grant Gear Works' machinery and office

equipment clean-up goal.

Comments received by EPA Region I during the formal public comment

period on the Feasibility Study and Proposed Plan are filed and cited in

5.3 Responsiveness Summaries.

5.0 RECORD OF DECISION

5.1 Correspondence

1. Letter from Janine Sweeney, Morgan, Lewis & Bockius (Attorney

for Federal Pacific Electric Company) to Paul Keough, EPA

Region I (August 31, 1989). Concerning extension of comment

period.

2. Letter from Robert Sanoff, Foley, Hoag & Eliot (Attorney for

Cornell-Dubilier Electronics, Incorporated) to Jane Downing, EPA

Region I (September 6, 1989). Concerning extension of

comment period.

3. Letter from Merrill Hohman, EPA Region I to Janine Sweeney,

Morgan, Lewis & Bockius (Attorney for Federal Pacific Electric

Company) (September 12, 1989). Concerning EPA's response

to Sweeney's request for extension of the comment period.

4. Letter from Richard McAllister, EPA Region I to Robert Sanoff,

Foley, Hoag & Eliot (Attorney for Cornell-Dubilier Electronics,

Incorporated) (September 13, 1989). Concerning EPA's

response to Sanoff's request to extend the comment period.

5.2 Applicable or Relevant and Appropriate Requirements (ARARs)

1. Cross-Reference: Letter from Massachusetts Department of

Environmental Protection to EPA Region I concerning state

concurrence with selected remedy and attainment of state

ARARs is Appendix C of the Record of Decision [filed and cited

as entry number 1 in 5.4 Record of Decision (ROD)],

8
5.3 Responsiveness Summary

1. Cross-Reference: Responsiveness Summary is Appendix A of

the Record of Decision [filed and cited as entry number 1 in 5.4

Record of Decision (ROD)].

The following citations indicate documents received by EPA Region I

during the formal public comment period.

2. Comments Dated August 5, 1989 from Faye Siegfriedt, Norwood

resident, on the August 1989 Norwood PCB Proposed Plan -

"EPA Proposes Clean-up Plan for the Norwood PCB Site," EPA

Region I.

3. Comments Dated August 29, 1989 from John Carroll, Norwood

Town Manager, on the August 1989 Proposed Plan - "EPA

Proposes Clean-up Plan for the Norwood PCB Site," EPA

Region I. NOTE: "Specifications for the Meadow Brook Flood

Control Project," may be reviewed, by appointment only, at EPA

Region I, Boston, Massachusetts.

4. Letter from Cameron Kerry, Mintz, Levin, Conn, Ferris, Glovsky

& Popeo (Attorney for Grant Gear Works, Incorporated) to Jane

Downing, EPA Region I (September 8, 1989) with attached

index. Concerning inclusion of additional documents in the

Norwood PCB Site Administrative Record.

5. Comments Dated September 11, 1989 from Robert Sanoff,

Foley, Hoag & Eliot (Attorney for Cornell-Dubilier Electronics,

Incorporated) on the August 1989 Norwood PCB "Final

Feasibility Study Report," ICF Incorporated for Ebasco Services

Incorporated.

6. Comments Dated September 11, 1989 from Leslie Ritts, Morgan,

Lewis & Bockius (Attorney for Federal Pacific Electric) on the

June 1989 Norwood PCB "Final Remedial Investigation Report,"

ICF Incorporated for Ebasco Services Incorporated, on the

August 1989 Norwood PCB "Final Feasibility Study Report," ICF

Incorporated for Ebasco Services Incorporated, and on the

August 1989 Norwood PCB "Final Endangerment Assessment

Report," ICF Incorporated for Ebasco Services Incorporated.

7. Comments Dated September 12, 1989 from Cameron Kerry,

Mintz, Levin, Cohn, Ferris, Glovsky and Popeo (Attorney for

Grant Gear Works, Incorporated) on the August 1989 Proposed

Plan - "EPA Proposes Clean-up Plan for the Norwood PCB

Site," EPA Region I.

8. Letter from Dale Young, Massachusetts Department of

Environmental Protection to Jane Downing, EPA Region I

(September 27, 1989). Concerning Massachusetts Department

of Environmental Protection's comments on the Norwood PCB

site Proposed Plan.
5.4 Record of Decision (ROD)

1. "Record of Decision - Remedial Alternative Selection," EPA

Region I (September 29, 1989).

9.0 STATE COORDINATION

9.1 Correspondence

1. Letter from Richard Chalpin, Massachusetts Department of

Environmental Quality Engineering to John J. Carroll, Norwood

Town Manager (March 6, 1985). Concerning a brief history and

update on the status of the Norwood PCB hazardous waste

site.

10.0 ENFORCEMENT

10.1 Correspondence

1. Letter from Charles W. Stenholm, United States House of

Representatives, Committee on Small Business to Michael

Deland, EPA Region I (July 23, 1985). Concerning the

testimony of Robert J. Hurley, President of Grant Gear Works,

Incorporated, before the House Small Business Committee.

2. Letter from Samuel L Silverman, United States Department of

Justice, United States Attorney, District of Massachusetts to

Cameron F. Kerry, and Michael S. Gardener, Mintz, Levin,

Cohn, Ferris, Glovsky & Popeo (Attorney for Grant Gear Works,

Incorporated) (October 11, 1985). Concerning John F. Hurley,

et al., v. Cornell-Dubilier Electronics, Incorporated et al., Civil

Action No. 85-1417-MC.

3. Letter from Thomas C. McMahon, Massachusetts Department of

Environmental Quality Engineering to Joseph Dorsett, Jr.,

Certified Engineering and Testing Co., Incorporated (March 16,

1987). Concerning response to Joseph Dorsett, Jr.'s letter of

February 23, 1987.

10.3 State and Local Enforcement Records

1. Memorandum from A. Charles Lincoln, EPA Region I to Robert

DiBiccaro, EPA Region I (March 14, 1984). Concerning

transmittal of Proposed Civil Complaint against Cooper

Industries, Arrow Hart Division, Hartford, Connecticut.

2. Complaint, Director of the Division of Water Pollution Control v.

Kelek Division of Arrow-Hart. Incorporated. Suffolk County

Superior Court.

10
10.4 Interviews, Depositions, and Affidavits

1. Affidavit of Arthur F. Hurley (February 8, 1985).

2. Affidavit of Joseph Lewis (June 6, 1985).

10.6 PRP-Specific Negotiations

1. Letter from Michael Gardener, Mintz, Levin, Cohn, Ferris,

Giovsky & Popeo (Attorney for Grant Gear Works, Incorporated)

to Samuel Silverman, United States Office of the Attorney

General, and Stephen Leonard, Massachusetts Office of the

Attorney General (June 27, 1985). Concerning Hurley, et al., v.

Cornell-Dubilier Electronics, Incorporated.

2. Letter from Cameron F. Kerry, Mintz, Levin, Cohn, Ferris,

Giovsky & Popeo (Attorney for Grant Gear Works, Incorporated)

to Michael R. Deland, EPA Region I (March 31, 1987).

Concerning Norwood PCB site.

3. Letter from Larry S. Snowhite, Mintz, Levin, Cohn, Ferris,

Giovsky & Popeo (Attorney for Grant Gear Works, Incorporated)

to Gene A. Lucero, EPA Washington (April 6, 1987).

Concerning final settlement of Grant Gear Works' potential civil

liability to federal government arising from the release of PCBs

at the Grant Gear Works site.

4. Letter from Cameron F. Kerry, Mintz, Levin, Cohn, Ferris,

Giovsky & Popeo (Attorney for Grant Gear Works, Incorporated)

to Gene Lucero, EPA Washington (July 21, 1987). Concerning

Norwood PCB site Innocent Landowner Settlement.

5. Letter from Gene Lucero, USEPA to Cameron Kerry, Mintz,

Levin, Cohn, Ferris, Giovsky & Popeo (Attorney for Grant Gear

Works, Incorporated) (August 11, 1987). Concerning innocent

landowner settlement issues.

6. Letter from Cameron Kerry, Mintz, Levin, Cohn, Ferris, Giovsky

& Popeo (Attorney for Grant Gear Works, Incorporated) to

Richard McAllister, EPA Region I (April 28, 1988). Concerning

Grant Gear Works, Incorporated settlement issues.

7. Letter from Cameron Kerry, Mintz, Levin, Cohn, Ferris, Giovsky

& Popeo (Attorney for Grant Gear Works, Incorporated) to

Michael Deland, EPA Region I, John DeVillars, Massachusetts

Executive Office of Environmental Affairs, and Daniel

Greenbaum, Massachusetts Department of Environmental Quality

Engineering (April 24, 1989). Concerning innocent landowner

settlement.

10.7 Administrative Orders

1. Administrative Order, In the Matter of Grant Gear Works.

Incorporated and Grant Gear Realty Trust. Norwood.

Massachusetts. Docket No. 89-05 (December 16, 1988).

11
10.8 Consent Decrees

1. Consent Agreement and Order, In the Matter of Cornell-Dubilier

Electronics, Incorporated. Commonwealth of Massachusetts,

Department of Environmental Quality Engineering (August 29,

1985).

11.0 POTENTIALLY RESPONSIBLE PARTY (PRP)

11.12 PRP-Related Documents

1. Letter from Joseph Nassif, Monsanto Company to Cameron

Kerry, Mintz, Levin, Conn, Ferris, Glovsky & Popeo (Attorney for

Grant Gear Works, Incorporated) (July 3, 1984). Concerning

PCS sales by Monsanto to previous owners of Grant Gear site.

2. Cross-reference: Affidavit of Arthur F. Hurley (February 8,

1985). (Filed and cited as entry number 1 in 10.4 Interviews,

Depositions, and Affidavits.)

3. Letter from Stokley Towles, Brown Brothers Harriman &

Company to Robert Hurley, Grant Gear Works, Incorporated

(March 4, 1985). Concerning financing.

4. Cross-reference: Affidavit of Joseph Lewis (June 6, 1985).

(Filed and cited as entry number 2 in 10.4 Interviews,

Depositions, and Affidavits).

5. Statement of Robert J. Hurley, Grant Gear Works, Incorporated,

before the Committee on Judiciary, United States Senate (June

10, 1985). Concerning effect of Superfund law on Grant Gear's

business.

6. Letter from Alan Wardyga, Old Stone Bank to Robert Hurley,

Grant Gear Works, Incorporated (June 14, 1985). Concerning

financing.

7. Letter from Nicholas Mavroules, Member of Congress,

Subcommittee on General Oversight and the Economy, and

Charles Stenholm, Member of Congress, Subcommittee on

Energy, Environment and Safety, United States House of

Representatives to Robert J. Hurley, Grant Gear, Incorporated

(July 1, 1985). Concerning the hearing to be held on July 15,

1985 to review the impact of the current Superfund law on small

businesses.

8. Statement of Robert J. Hurley, Grant Gear Works, Incorporated,

before the Committee on Small Business, Subcommittees on

General Oversight and the Economy, and Energy, Environment

and Safety, United States House of Representatives (July 15,

1985). Concerning the effect of Superfund law on Grant Gear's

business.

12
11.12 PRP-Related Documents (cont'd)

9. Letter from Michael Gardener, Mintz, Levin, Cohn, Ferris,

Glovsky & Popeo (Attorney for Grant Gear Works, Incorporated)

to Stephen Leonard, Massachusetts Office of the Attorney

General (July 17, 1985). Concerning Grant Gear's financial

situation.

10. Letter from Debbie Freedman, Massachusetts Industrial Services

Program to Robert Hurley, Grant Gear Works, Incorporated

(September 5, 1985). Concerning financing.

11. Letter from Edward McSweeney, EPA Region I to Robert Hurley,

Grant Gear Works, Incorporated (November 18, 1986).

Concerning Grant Gear NPDES permit application.

12. Letter from Thomas McMahon, Massachusetts Department of

Environmental Quality Engineering to Joseph Dorsett, Certified

Engineering and Testing Company, Incorporated (March 16,

1987). Concerning Grant Gear NPDES permit.

13. Letter from Thomas McMahon, Massachusetts Department of

Environmental Quality Engineering to Robert Hurley, Grant Gear

Works, Incorporated (January 26, 1988). Concerning Grant

Gear NPDES permit.

14. "Authorization to Discharge Under the National Pollutant

Discharge Elimination System," State Permit No. MA 0029262,

EPA Region I and Massachusetts Department of Environmental

Quality Engineering (January 29, 1988).

15. Letter from Margaret Sheehan, Massachusetts Office of the

Attorney General to Cameron Kerry, Mintz, Levin, Cohn, Ferris,

Glovsky & Popeo (Attorney for Grant Gear Works, Incorporated)

(April 5, 1988). Concerning Grant Gear's application for a

waiver from anti-degredation provisions of the Massachusetts

Clean Waters Act regulations.

16. Letter from Cameron Kerry, Mintz, Levin, Cohn, Ferris, Glovsky

& Popeo (Attorney for Grant Gear Works, Incorporated) to

Thomas McMahon, Massachusetts Department of Environmental

Quality Engineering (April 15, 1988). Concerning application for

anti-degredation variance.

17. Letter from Paul Dekker, Certified Engineering & Testing

Company Incorporated to Joanne Robbins, Mintz, Levin, Cohn,

Ferris, Glovsky & Popeo (Attorney for Grant Gear Works,

Incorporated) (April 15, 1988). Concerning lab results for water

samples collected at Grant Gear Works, Incorporated.

18. Letter from Thomas McMahon, Massachusetts Department of

Environmental Quality Engineering to Robert Hurley, Grant Gear

Works, Incorporated (May 24, 1988). Concerning application for

variance to authorize discharges to Meadow Brook.

13
11.12 PRP-Related Documents (cont'd)

19. Cross-reference: Letter Report from Charles Martin and Jeffrey

Lawson, ERT to Cameron Kerry, Mintz, Levin, Cohn, Ferris,

Glovsky & Popeo (Attorney for Grant Gear Works, Incorporated)

(June 10, 1988). Concerning summary evaluation of drainage

line remedial actions. (Filed and cited as entry number 1 in 4.6

Feasibility Study (FS) Reports.)

20. Letter from Cameron Kerry, Mintz, Levin, Cohn, Ferris, Glovsky

& Popeo (Attorney for Grant Gear Works, Incorporated) to

Thomas McMahon, Massachusetts Department of Environmental

Quality Engineering (June 28, 1988). Concerning application for

antidegredation variance.

21. Letter from Thomas McMahon, Massachusetts Department of

Environmental Quality Engineering to Cameron Kerry, Mintz,

Levin, Cohn, Ferris, Glovsky & Popeo (Attorney for Grant Gear

Works, Incorporated) (July 18, 1988). Concerning Grant Gear

Works' request for extension to provide arguments for variance.

22. Letter from Marian Rambelle and Jeffrey Lawson, ERT to

Cameron Kerry, Mintz, Levin, Cohn, Ferris, Glovsky & Popeo

(Attorney for Grant Gear Works, Incorporated) (August 12,

1988). Concerning PCB sampling plan at Grant Gear Works

property.

23. Letter from Cameron Kerry, Mintz, Levin, Cohn, Ferris, Glovsky

& Popeo (Attorney for Grant Gear Works, Incorporated) to

Thomas McMahon, Massachusetts Department of Environmental

Quality Engineering (August 12, 1988). Concerning Grant

Gear's application for anti-degredation variance.

24. Letter from Thomas McMahon, Massachusetts Department of

Environmental Quality Engineering to Cameron Kerry, Mintz,

Levin, Cohn, Ferris, Glovsky & Popeo (Attorney for Grant Gear

Works, Incorporated) (August 26, 1988). Concerning Grant

Gear Works' request for variance.

25. Letter from Jane Downing, EPA Region I to Cameron Kerry,

Mintz, Levin, Cohn, Ferris, Glovsky & Popeo (Attorney for Grant

Gear Works, Incorporated) (August 30, 1988). Concerning

review of PCB Sampling Plan at Grant Gear Works

Incorporated.

14
11.12 PRP-Related Documents (cont'd)

26. Memorandum from Cameron Kerry, Mintz, Levin, Cohn, Ferris,

Glovsky & Popeo (Attorney for Grant Gear Works, Incorporated)

to Thomas McMahon, Judith Perry, Dale Young, Massachusetts

Department of Environmental Quality Engineering; Jane

Downing, Richard McAllister, Joan Jouzaitis, EPA Region I;

Margaret Sheehan, Office of the Attorney General;

Massachusetts Water Authority; Executive Office of

Transportation; Commissioner of Public Works; Town of

Norwood Board of Selectmen; Metropolitan Area Planning

Council; Robert Hurley; John Hurley; Joanne Robbins (August

31, 1988). Concerning Grant Gear Works, Incorporated

NPDES permit application.

27. Letter from Cameron Kerry, Mintz, Levin, Cohn, Ferris, Glovsky

& Popeo (Attorney for Grant Gear Works, Incorporated) to

Thomas McMahon, Massachusetts Department of Environmental

Quality Engineering (August 31, 1988). Concerning Grant Gear

Works request for variance.

28. Letter from Cameron Kerry, Mintz, Levin, Cohn, Ferris, Glovsky

& Popeo (Attorney for Grant Gear Works, Incorporated) to Jane

Downing, EPA Region I (September 1, 1988). Concerning

review of PCS sampling at Grant Gear Incorporated.

29. Letter from Cameron Kerry, Mintz, Levin, Cohn, Ferris, Glovsky

& Popeo (Attorney for Grant Gear Works, Incorporated) to

Thomas McMahon, Massachusetts Department of Environmental

Quality Engineering (September 7, 1988). Concerning

application for NPDES permit and antidegredation variance.

30. Letter from Elisabeth Goodman, Massachusetts Department of

Public Works to Cameron Kerry, Mintz, Levin, Cohn, Ferris,

Glovsky & Popeo (Attorney for Grant Gear Works, Incorporated)

(September 13, 1988). Concerning Grant Gear Works' possible

permit application to discharge storm drainage into state

highway drainage system.

31. Letter from David Fierra, EPA Region I to Robert Hurley, Grant

Gear Works, Incorporated (September 30, 1988). Concerning

denial of NPDES permit No. MA 0029262.

32. Letter from Cameron Kerry, Mintz, Levin, Cohn, Ferris, Glovsky

& Popeo (Attorney for Grant Gear Works, Incorporated) to

David Fierra, EPA Region I (October 11, 1988). Concerning

NPDES permit No. MA 0029262 denial.

33. Letter from David Fierra, EPA Region I to Robert Hurley, Grant

Gear Works, Incorporated (November 7, 1988). Concerning

Grant Gear, Incorporated, Norwood, Massachusetts NPDES

permit application No. MA 0029262 denial.

15
11.12 PRP-Related Documents (cont'd)

34. -Letter from Cameron Kerry, Mintz, Levin, Cohn, Ferris, Glovsky

& Popeo (Attorney for Grant Gear Works, Incorporated) to

David Fierra, EPA Region I and William Gaughan,

Massachusetts Department of Environmental Quality Engineering

(December 30, 1988). Concerning Grant Gear Works,

Incorporated and Grant Gear Realty Trust, Docket No. 89-05.

35. Letter from Cameron Kerry, Mintz, Levin, Cohn, Ferris, Glovsky

& Popeo (Attorney for Grant Gear Works, Incorporated) to

David Fierra, EPA Region I, and William Gaughan,

Massachusetts Department of Environmental Quality Engineering

(January 6, 1989). Concerning transmittal of attached "Revised

Sampling Plan," ENSR Consulting and Engineering (January 3,

1989).

36. Letter from Robert Chrusciel, Norwood Engineering Company,

Incorporated to Robert Hurley, Grant Gear Works, Incorporated

(January 18, 1989). Concerning roof drainage study.

37. Letter from Cameron Kerry, Mintz, Levin, Cohn, Ferris, Glovsky

& Popeo (Attorney for Grant Gear Works, Incorporated) to

David Fierra, EPA Region I, and William Gaughan,

Massachusetts Department of Environmental Quality Engineering

(January 20, 1989). Concerning Grant Gear Works,

Incorporated and Grant Gear Realty Trust, Docket No. 89-05.

38. Letter from Cameron Kerry, Mintz, Levin, Cohn, Ferris, Glovsky

& Popeo (Attorney for Grant Gear Works, Incorporated) to John

Healey, EPA Region I (February 1, 1989). Concerning approval

of sampling plan.

39. Letter from Cameron Kerry, Mintz, Levin, Cohn, Ferris, Glovsky

& Popeo (Attorney for Grant Gear Works, Incorporated) to

David Fierra, EPA Region I (February 14, 1989). Concerning

sampling plan.

40. Letter from Cameron Kerry, Mintz, Levin, Cohn, Ferris, Glovsky

& Popeo (Attorney for Grant Gear Works, Incorporated) to

David Fierra, EPA Region I, and William Gaughan,

Massachusetts Department of Environmental Quality Engineering

(March 21, 1989). Concerning stormwater sampling.

41. Letter from Cameron Kerry, Mintz, Levin, Cohn, Ferris, Glovsky

& Popeo (Attorney for Grant Gear Works, Incorporated) to

David Fierra, EPA Region I and William Gaughan,

Massachusetts Department of Environmental Quality Engineering

(April 4, 1989). Concerning progress on sediment and

stormwater sampling.

42. Letter from Dianne Chabot, Mintz, Levin, Cohn, Ferris, Glovsky

& Popeo (Attorney for Grant Gear Works, Incorporated) to

David Fierra, EPA Region I, and William Gaughan,

Massachusetts Department of Environmental Quality Engineering

(May 19, 1989). Concerning progress report.

16
11.12 PRP-Related Documents (cont'd)

43. Letter from Dianne Chabot, Mintz, Levin, Cohn, Ferris, Glovsky

& Popeo (Attorney for Grant Gear Works, Incorporated) to

David Fierra, EPA Region I and William Gaughan,

Massachusetts Department of Environmental Quality Engineering

(June 15, 1989). Concerning Administrative Order Docket No.

89-05.

44. Letter from Cameron Kerry, Mintz, Levin, Cohn, Ferris, Glovsky

& Popeo (Attorney for Grant Gear Works, Incorporated) to

David Fierra, EPA Region I and William Gaughan,

Massachusetts Department of Environmental Quality Engineering

(June 29, 1989). Concerning availability of Grant Gear's draft

report required by Administrative Order.

45. Letter from Mark Stein, EPA Region I to Cameron Kerry, Mintz,

Levin, Cohn, Ferris, Glovsky & Popeo (Attorney for Grant Gear

Works, Incorporated) (July 5, 1989). Concerning Grant Gear

Works, Incorporated Clean Water Act Administrative Order No.

89-05.

46. Letter from Dianne Chabot, Mintz, Levin, Cohn, Ferris, Glovsky

& Popeo (Attorney for Grant Gear Works, Incorporated) to

David Fierra, EPA Region I and William Gaughan,

Massachusetts Department of Environmental Quality Engineering

(July 19, 1989). Concerning Administrative Order No. 89-05.

47. Cross-reference: Letter from Cameron Kerry, Mintz, Levin,

Cohn, Ferris, Glovsky & Popeo (Attorney for Grant Gear Works,

Incorporated) to David Fierra, EPA Region I, and William

Gaughan, Massachusetts Department of Environmental Quality

Engineering (August 24, 1989). Concerning transmittal of

"Evaluation of Discharge Options for the Grant Gear Site," ENSR

Consulting and Engineering (August 1989). (Filed and cited as

entry number 1 in 4.1 Correspondence.)

13.0 COMMUNITY RELATIONS

13.2 Community Relations Plans

1. "Interim Final Draft Community Relations Plan, Norwood PCB

Site," ICF Incorporated for Ebasco Services Incorporated (June

1988).

2. "Final Community Relations Plan for the Norwood PCB Site," ICF

Incorporated for Ebasco Services Incorporated (September

1989).

17
133 New Clippings/Press Releases

1 "Senator Kennedy Announces Director of Centers for Disease

Control to Visit Norwood, Massachusetts," Office of Senator

Edward M Kennedy of Massachusetts (June 23, 1983)

2 "Bellotti and DEQE Negotiate for Private Study of PCB Site,"

EPA Region I (August 29, 1985)

3 "DEQE Announces Interim Measure at Norwood PCB Site," EPA

Region I (December 9, 1985)

4 "The Environmental Protection Agency Will Hold a Public

Meeting to Discuss Current Work in Progress at the Norwood

Superfund Site in Norwood, Massachusetts," Environmental

News - EPA Region I (March 3, 1987).

5 "EPA Announces Public Meeting to Explain Results of the

Remedial Investigation and Endangerment Assessment for the

Norwood PCB Superfund Site," Environmental News - EPA

Region I (June 8, 1989).

6 "Public Meeting to Explain Proposed Cleanup Plan for the

Norwood PCB Superfund Site," Environmental News - EPA

Region I (August 3, 1989)

7 'United States Environmental Protection Agency Invites Public

Comments on the Feasibility Study and Proposed Plan for the

Norwood PCB site in Norwood, Massachusetts and Announces

the Availability of the Site Administrative Record,' The Patriot

Ledger - Qumcy, Massachusetts (August 4, 1989).

8 "United States Environmental Protection Agency Invites Public

Comments on the Feasibility Study and Proposed Plan for the

Norwood PCB site in Norwood, Massachusetts and Announces

the Availability of the Site Administrative Record," The Daily

Transcript - Dedharn, Massachusetts (August 9, 1989).

9 Media Advisory, Environmental News - EPA Region I (August

18, 1989) Concerning announcement of public hearing to

accept oral comments on the cleanup alternatives for Norwood

PCB site

13 4 Public Meetings

1 Meeting Notes, October 23, 1984 Norwood Board of

Selectmen's meeting on the Norwood PCB site

2 "Hazard Assessment, Norwood PCB Site, Norwood,

Massachusetts," Public meeting for the Norwood PCB site, EPA

Region I (March 1988).

3 EPA Region I Meeting Notes, Norwood Community Workgroup

meeting for the Norwood PCB site (April 24, 1989). Concerning

purpose of the community work group and discussions on

information EPA could provide to citizens

18
13.5 Fact Sheets

1. Cross-reference: Notice from Bartley King, Norwood Board of

Health, and John Carroll, Norwood Board of Selectmen to

residents of the Meadow Brook area (June 28, 1983). (Filed

and cited as entry number 1 in 3.1 Correspondence.)

2. Cross-reference: Notice from Bartley King, Norwood Board of

Health, and John Carroll, Norwood Board of Selectmen to

residents of the Meadow Brook area (June 29, 1983).

Concerning analysis of soil samples. (Filed and cited as entry

number 2 in 3.1 Correspondence.)

3. "EPA Sampling Activities Begin at Norwood PCB Site,"

Superfund Program Fact Sheet, EPA Region I (November 1987).

4. "EPA Completes Field Investigation at the Norwood PCB Site,"

Superfund Program Information Update, EPA Region I

(November 1988).

5. "EPA Announces the Results of the Remedial Investigation and

Endangerment Assesssment," Superfund Program Fact Sheet,

Norwood PCB Site, EPA Region I (June 1989).

14.0 CONGRESSIONAL RELATIONS

14.1 Correspondence

1. Letter from Michael R. Deland, EPA Region I to Honorable John

J. Moakley, United States House of Representatives (July 13,

1983). Concerning response to letter dated June 22, 1983

regarding the discovery of PCB contamination in Norwood,

Massachusetts.

2. Cross-reference: Statement of Robert J. Hurley, Grant Gear

Works, Incorporated, before the Committee on Judiciary, United

States Senate (June 10, 1985). (Filed and cited as entry

number 5 in 11.12 PRP-Related Documents.)

3. Cross-reference: Letter from Nicholas Mavroules, Member of

Congress, Subcommittee on General Oversight and the

Economy, and Charles Stenholm, Member fo Congress,

Subcommittee on Energy, Environment and Safety, United

States House of Representatives to Robert J. Hurley, Grant

Gear Works, Incorporated (July 1, 1985). (Filed and cited as

entry number 7 in 11.12 PRP-Related Documents.)

4. Cross-reference: Statement of Robert J. Hurley, Grant Gear

Works, Incorporated, before the Committee on Small Business,

Subcommittees on General Oversight and the Economy, and

Energy, Environment and Safety, United States House of

Representatives (July 15, 1985). (Filed and cited as entry

number 8 in 11.12 PRP-Related Documents.)

19
14.1 Correspondence (cont'd)

5. Meeting Notes, Jane Downing, EPA Region I and Edward M

Kennedy, Member of the United States Senate, Michael Deland,

EPA Region I, John Caroll, Norwood Town Manager, Daniel

Greenbaum, Massachusetts Department of Environmental Quality

Engineering, and Massachusetts Department of Public Health

Staff (April 5, 1989). Concerning Town of Norwood's concerns

about clean-up and flood control project.

6. Letter from Edward M. Kennedy, Member of the United States

Senate to Michael Deland, EPA Region I (May 3, 1989).

Concerning discussions at meeting with Town of Norwood

official about cleanup.

16.0 NATURAL RESOURCE TRUSTEE

16.1 Correspondence

1. Letter from Gordon E. Beckett, United States Department of the

Interior Fish and Wildlife Service to John C. Keane, EPA Region

I (September 14, 1987). Concerning receipt of Trust Notification

Form for the Norwood PCB site.

2. Letter from Kenneth Finkelstein, National Oceanic and

Atmospheric Administration to Jane Downing, EPA Region I

(September 20, 1989). Concerning PCB sediment criterion.

16.4 Trustee Notification Form and Selection Guide

1. Letter from Merrill S. Hohman, EPA Region I to William

Patterson, Department of the Interior (August 19, 1987).

Concerning EPA documentation of release or threatened release

of hazardous substances, pollutants or contaminants at

Norwood PCB site.

16.5 Technical Issue Papers

1. "A Discussion of PCB Target Levels in Aquatic Sediments,"

National Oceanic and Atmospheric Administration and EVS

Consultants, Incorporated (January 8, 1988).

20
17.0 SITE MANAGEMENT RECORDS

17.4 Site Photographs/Maps

The record cited in entry number 1 may be reviewed, by appointment

only, at EPA Region I, Boston, Massachusetts.

1. "Site Analysis - Norwood PCB Site," EPIC (April 1984).

17.7 Reference Documents

1. "Site Investigation, Grant Gear Incorporated, Norwood,

Massachusetts," E.G. Jordan Company (June 1983).

2. "Kerry Place Norwood, Lot #1 Report of On Site Investigation of

Possible Chemical Contamination," WEB Engineering Associates,

Incorporated (January 20, 1984).

3. "Kerry Place Norwood, Lot #2 Report of On Site Investigation of

Possible Chemical Contamination," WEB Engineering Associates,

Incorporated (January 20, 1984).

4. "Kerry Race Norwood, Lot #3 Report of On Site Investigation of

Possible Chemical Contamination," WEB Engineering Associates,

Incorporated (January 20, 1984).

5. "Kerry Place Norwood, Lot #4 Report of On Site Investigation of

Possible Chemical Contamination," WEB Engineering Associates,

Incorporated (January 20, 1984).

6. "Kerry Place Norwood, Lot #5a Report of On Site Investigation

of Possible Chemical Contamination," WEB Engineering

Associates, Incorporated (January 20, 1984).

17.8 State and Local Technical Records

1. Letter from James C. Colman, Massachusetts Department of

Environmental Quality Engineering to John J. Carroll, Norwood

Town Manager (October 31, 1985). Concerning understanding

between Division of Solid and Hazardous Waste and the

Division of Waterways in the meeting held in the Division's

Boston office.

2. Letter from James C. Colman, Massachusetts Department of

Environmental Quality Engineering to John Hannon, Division of

Waterways (January 15, 1986). Concerning response action to

levels of contaminants found in the water and sediments of

Meadow Brook.

3. Certificate of the Secretary of Environmental Affairs on the

Environmental Notification Form, Massachusetts Office of

Environmental Affafrs (May 9, 1986).

4. Property Location Plan, Meadow Brook Improvement Project,

Norwood, Massachusetts (July 1986).

5. Public Notice, Department of the Army, New England Division,

Corps of Engineers (January 22, 1987).

21
18.0 INITIAL REMEDIAL MEASURE (IRM) RECORDS

18.1 Correspondence

1. Letter from Cameron Kerry, Mintz, Levin, Cohn, Ferris, Glovsky

& Popeo (Attorney for Grant Gear Works, Incorporated) to

Susan Bernard, Massachusetts Office of the Attorney General

(August 19, 1985). Concerning GZA study.

2. Letter from Cameron Kerry, Mintz, Levin, Cohn, Ferris, Glovsky

& Popeo (Attorney for Grant Gear Works, Incorporated) to

Susan Bernard, Massachusetts Office of the Attorney General

(August 23, 1985). Concerning GZA study.

3. Letter from Robert Hurley, Grant Gear Works, Incorporated to

James Colman, Massachusetts Department of Environmental

Quality Engineering (September 10, 1985). Concerning GZA

study.

4. Letter from William F. Cass, Massachusetts Department of

Environmental Quality Engineering to Merrill S. Hohman, EPA

Region I (October 11, 1985). Concerning request for transfer of

responsibility for managing remedial activities at Norwood to

Massachusetts Department of Environmental Quality

Engineering.

5. Letter from James C. Colman, Massachusetts Department of

Environmental Quality Engineering to Heather Ford, EPA Region

I (December 11, 1985). Concerning DEQE belief that an Initial

Remedial Measure (IRM) should be implemented at Norwood

site.

6. Letter from James C. Colman, Massachusetts Department of

Environmental Quality Engineering to Robert S. Sanoff, Foley,

Hoag & Eliot (Attorney for Cornell-Dubilier Electronics,

Incorporated) (January 15, 1986). Concerning Initial Remedial

Measure (IRM).

22
SECTION II

GUIDANCE DOCUMENTS
NORWOOD PCB

NPL SITE ADMINISTRATIVE RECORD

GUIDANCE DOCUMENTS

EPA guidance documents may be reviewed at EPA Region I, Boston, Massachusetts.

General EPA Guidance Documents

1. "Appendix D - Protection of Wetlands: Executive Order 11990," 42

Federal Register 26961 (1977). Ct?D3

2. Memorandum from John W. Lyon toxic Substance Division, USEPA to

Sanford W. Harvey, Jr., Enforcement Division, EPA Region IV (August

3, 1979). Concerning applicability of PCB regulations to spills which

occurred prior to the effective date of the 1978 regulation, c^^y

3. U.S. Environmental Protection Agency. Office of Emergency and

Remedial Response. Community Relations in Superfund: A Handbook

(Interim Version) (EPA/540/G-88/002), June 1988. 1000

4. U.S. Environmental Protection Agency. Office of Emergency and

Remedial Response. Guidance for Conducting Remedial Investigations

and Feasibility Studies Under CERCLA (EPA/540/G-89/004) (OSWER

Directive 9355.3-01), October 1988.

5. "National Oil and Hazardous Substances Pollution Contingency Plan,"

Code of Federal Regulations (Title 40, Part 300), 1985.

6. U.S. Environmental Protection Agency. Office of Emergency and

Remedial Response. Superfund Remedial Design and Remedial Action

Guidance (OSWER Directive 9355.0-4A), June 1986.

7. U.S. Environmental Protection Agency. Office of Research and

Development. Hazardous Waste Engineering Research Laboratory.

Handbook for Stabilization/Solidification of Hazardous Wastes

(EPA/540/2-86/001), June 1986. ^

8. Comprehensive Environmental Response. Compensation, and Liability

Act of 1980, amended October 17, 1986.

9. U.S. Environmental Protection Agency. Office of Emergency and

Remedial Response. Superfund Public Health Evaluation Manual

(OSWER Directive 9285.4-1), October 1986.

24
General EPA Guidance Documents (cont'd)

10. U.S. Environmental Protection Agency. Office of Solid Waste and

Emergency Response. Interim Guidance on Superfund Selection of

Remedy (OSWER Directive 9355.0-19), December 24, 1986.

1 1 . U.S. Environmental Protection Agency. Office of Solid Waste and

Emergency Response. Data Quality Objectives for Remedial Response

Activities: Development Process (EPA/540/G-87/003), March 1987.

ai<7[

12. "Part 761 - Polychlorinated Biphenyls (PCBs) Manufacturing,

Processing, Distribution in Commerce, and Use Prohibitions," Code of

Federal Regulations (40 CFR Part 761), 1987.

13. Memorandum from J. Winston Porter to Addressees ("Regional

Administrators, Regions I-X; Regional Counsel, Regions I-X; Director,

Waste Management Division, Regions I, IV, V, VII, and VIII; Director,

Emergency and Remedial Response Division, Region II; Director,

Hazardous Waste Management Division, Regions III and VI; Director

Toxics and Waste Management Division, Region IX; Director,

Hazardous Waste Division, Region X; Environmental Services Division

Directors, Region I, VI, and VII"), (July 9, 1987). Concerning interim

guidance on compliance with applicable or relevant and appropriate

requirements. Cc''55

14. U.S. Environmental Protection Agency. Office of Health and

Environmental Assessment. A Compendium of Technologies Used in

the Treatment of Hazardous Waste (EPA/625/8-87/014), September

1987. l^CQ

15. Memorandum from Denise M. Keehner, Chemical Regulation Branch,

USEPA to Bill Hanson, Site Policy and Guidance Branch, USEPA

(October 14, 1987). Concerning comments on the PCB ContaminationRegulatory and Policy Background Memorandum. Cc5(;

16. "Guidelines for PCB Levels in the Environment," The Hazardous Waste

Consultant, pp. 26-32 (January/February 1988). _

17. Memorandum from Christopher Zarba, USEPA to Jane Downing, EPA

Region I (April 11, 1988). Concerning the application of interim^

sediment criteria values at Sullivan's Ledge Superfund Site.

18. U.S. Environmental Protection Agency. Office of Emergency and

Remedial Response. Draft Guidance on Remedial Actions for

Contaminated Groundwater at Superfund Sites (OSWER Directive

9283.1-2), April 1988. CO

25
General EPA Guidance Documents (cont'd)

19. "Supplemental Risk Assessment Guidance for the Superfund Program,"

EPA Region I (June 1989). C/ £ if

20. "Summary of the Requirements: Land Disposal Restrictions Rute," EPA

Region I.

Norwood PCB NPL Site-Specific Guidance Documents

1. U.S. Environmental Protection Agency. Office of Health and

Environmental Assessment. Development of Advisory Levels of

Polvchlorinated Biphenyls fPCBs) Cleanup (OHEA-E-187). May 1986.

2. "Project Summary: PCB Sediment Decontamination -

Technical/Economic Assessment of Selected Alternative Treatments."

Ben H. Carpenter, EPA Region V (March 1987).

3. "PCB Spill Cleanup Policy," (40 CFR Part 761), Federal Register (April

2, 1987). -L o * '

4. "Sediment Quality Values Refinement: 1988 Update and Evaluation of

Puget Sound AET," PTI Environmental Services for Tetra Tech, ^^ ^

Incorporated (September 1988). '3

5. Letter from Lanny D. Weimer, Resources Conservation Company to

Angelo L Massullo, ICF Technology, Incorporated (December 16,

1988). Concerning technical paper entitled "Basic Extractive Sludge

Treatment (B.E.S.T.)* - Demonstrated Available Technology."

6. "PCB Sediment Decontamination Processes Selection for Test and

Evaluation," Ben H. Carpenter, Engineering Research Applications, and

Donald L. Wilson, EPA Region V (1988).

7. "Evaluation of the B.E.S.T.* Solvent Extraction Sludge Treatment

Technology Twenty-Four Hour Test," Gerard W. Sudell, Enviresponse,

Incorporated. /- « i/i

26
REMOVAL ADMINISTRATIVE RECORD INDEX

for the

NORWOOD PCBs NPL SITE *

i.O PRE-REMEDIAL

1.14 FIT Contract

"Massachusetts FIT Contract - Work and

Cost Plan Proposal - Grant Gear

Company - P^oblen, Eva ..?•_! <~, L" u.,/

Site Response Assessment Site

Management Plan," Wehran Engineering

(June 6, 1985).

1.18 FIT Technical Direction Documents (TDDs) and

Associated Records

1. "Geophysical Survey," Weston Geophysical

Corporation for NUS Corporation (July

1984). NOTE: Oversize Maps and figures

are available for review at EPA, Region

I, Boston, Massachusetts.

2. "Field Investigation of the Norwood

Site, Norwood, Massachusetts," NUS

Corporation (September 10, 1984).

2.0 REMOVAL RESPONSE

2.1 Correspondence

1. Letter from Anthony D. Cortese,

Massachusetts Department of

Environmental Quality Engineering to

Paul Keough, EPA Region I (June 16,

1983). Concerning immediate removal

action at the Norwood PCB site.

2. Memorandum from David Mclntyre, EPA

Region I to Richar'd T. Leighton, EPA

Region I (August 5; 1983). Concerning

immediate removal action at the Dean

Street site.

3. Memorandum from Frank W. Li 1 ley, EPA

Region I to Dave Mclntyre, EPA Region I

(September 15, 1983). Concerning Norwood

II Airborne PCB investigation.
4. Letter from Richard Chalpin,

Massachusetts Department of

Environmental Quality

Engineering to William E. Baird, WEB

Engineering Associates, Incorporated

(February 14, 1984). Concerning review

of four reports entitled "Kerry Place,

Norwood, Lots #1, #2, #3, and #4; Report

of On Site Investigation of Possible

Chemical Contamination," dated February

1, 1984.

5. Letter from Cameron Kerry, Mintz, Levin,

Cohn, Ferris, Glovsky, and Popeo

(Attorney for Grant Gear Works,

Incorporated) to Susan Bernard,

Massachusetts Office of the Attorney

General (January 28, 1986). Concerning

recent site activities relating to onsite car storage and soil sampling.

2.4 Pollution Reports (POLREPS)

1. POLREP 1, (June 28, 1983).

2. POLREP 2, (July 1, 1983).

3. POLREP 3, (July 11, 1983).

4. POLREP 4, (July 12, 1983).

5. POLREP 5, (July 29, 1983).

6. POLREP 6, (August 3, 1983).

2.5 On-Scene Coordinator Report

1. "On-Scene Coordinator's Report," (June -

August, 1983). Including Attachments 1 -

21. (Confidential business information

redacted.)

* Documents listed in this index may be found in the Norwood

PCBs NPL Site Administrative Record for the Record of

Decision signed September 29, 1989.