FIVE-YEAR REVIEW REPORT

FOR

NORWOOD PCBS SUPERFUND SITE

Norwood, Massachusetts

December 2004

Prepared by:

United States Environmental Protection Agency

Region 1

Boston, Massachusetts

With Technical Assistance from:

Shaw Environmental, Inc.

100 Technology Center Drive

Stoughton, Massachusetts 02072

Approved by: tfU&SNU 4bdlli A Date:

Director, Office of Site Remediation and Restoration

USEPA, Region 1
Norwood PCBs Superfund Site 

Five-Year Review Report December 2004 

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TABLE OF CONTENTS 

TABLE OF CONTENTS .............................................................................................................. i

LIST OF TABLES ....................................................................................................................... iii

LIST OF APPENDICES ............................................................................................................. iv

ABBREVIATIONS AND ACRONYMS......................................................................................v

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 ...................................4-2

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.............................................................................................4-3

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 ........................................................................4-6

4.3 OPERATION AND MAINTENANCE .....................................................................................4-6

4.3.1 Cap/Cover ...........................................................................................................4-6

4.3.2 Groundwater Treatment......................................................................................4-7

4.3.3 Meadow Brook Restoration ................................................................................4-7

5.0 PROGRESS SINCE THE LAST REVIEW ................................................................ 5-1

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

5.1.1 1999 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
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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 Risk Assessment Data.........................................................................................6-4

6.5 SITE INSPECTION ..............................................................................................................6-5

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........................................................................................................... 11-2

12.0 REFERENCES............................................................................................................. 12-1
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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............................................. 5-2

Table 6-1 27th Quarterly Groundwater Analytical Results – Data Summary ................... 6-3

Table 6-2 Site Investigation Summary................................................................................... 6-6

Table 8-1 Issues ........................................................................................................................ 8-1

Table 9-1 Recommendations and Follow-up Actions ........................................................... 9-1
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LIST OF APPENDICES 

APPENDIX A Site Maps........................................................................................................ A-1

APPENDIX B Tables Documenting ARARs.........................................................................B-1

APPENDIX C Interview Notes.............................................................................................. C-1

APPENDIX D Photos Documenting Site Conditions .......................................................... D-1

APPENDIX E Five-Year Review Site Inspection Checklist ................................................E-1
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ABBREVIATIONS AND ACRONYMS 

ARAR Applicable or Relevant and Appropriate Requirement 

AWQC Ambient Water Quality Criteria 

 

CERCLA Comprehensive Environmental Response, Compensation, and Liability Act 

DOT Department of Transportation 

 

FS Feasibility Study 

 

GSA General Services Administration 

GZA GZA Geo Environmental, Inc. 

 

IRM Interim Remedial Measure 

 

MADEP Massachusetts Department of Environmental Protection 

MCP Massachusetts Contingency Plan 

 

NCP National Contingency Plan 

NPL National Priorities List 

 

O&M Operation and Maintenance 

OU Operable Unit 

 

PAH Polyaromatic Hydrocarbon 

PCB Polychlorinated Biphenyl 

ppm part per million 

PRP Potentially Responsible Party 

 

RA Remedial Action 

RBAL Risk Based Action Level 

RCRA Resource Conservation and Recovery Act 

RI Remedial Investigation 

ROD Record of Decision 

 

SARA Superfund Amendments and Reauthorization Act 

Shaw Shaw Environmental, Inc. (formerly Stone & Webster) 

SVOC Semi-Volatile Organic Compound 

 

TAT Technical assistance team 

TBC to be considered 

TCB Trichlorobenzene 

TCE Trichloroethylene 

TSCA Toxic Substances Control Act 

 

USACE U.S. Army Corps of Engineers 

USEPA United States Environmental Protection Agency 

UST Underground Storage Tank 

 

VOC Volatile Organic Compound 

 

yd3 cubic yards 
Norwood PCBs Superfund Site 

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EXECUTIVE SUMMARY 

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

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

Norwood, Massachusetts, in compliance with the Comprehensive Environmental Response, 

Compensation, and Liability Act (CERCLA), 42 U.S.C. §§ 9601, et seq. USEPA conducted this review 

between May 2004 and December 2004 with technical assistance from Shaw Environmental, Inc. (Shaw) 

under a General Services Administration (GSA) contract. This is the second Five-Year Review for the 

Site. The triggering action for the first Five-Year Review was the date of the start of the first RA in 1989. 

Subsequent reviews are conducted at least every five years. The purpose of the Five-Year Review is to 

evaluate whether response actions and original performance standards remain protective of human health 

and the environment. 

The RAs at the Site have been divided into four phases consisting of: Phase 1 – groundwater treatment; 

Phase 2 – building demolition; Phase 3A – cap and cover; and Phase 3B – Meadow Brook restoration. 

On January 11, 1996, construction of the 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. The clean up goals 

published in the 1989 Record of Decision (ROD) and 1996 Amended ROD have not been met; however, 

new clean up goals are being documented in the Explanation of Significant Differences (ESD) released in 

conjunction with this Five-Year Review. The most recent groundwater monitoring data shows that these 

new clean up goals are being met. Further sampling is planned to confirm that these clean up goals 

continue to be met. 

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 Operation and Maintenance at the site must be conducted 

regularly. 
Norwood PCBs Superfund Site 

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Five-Year Review Summary Form

SITE IDENTIFICATION

Site name (from WasteLAN): Norwood PCBs

USEPA ID (from WasteLAN): MAD980670566

Region: 1 State: MA City/County: Norwood/Norfolk County

SITE STATUS

NPL status: Final 

Remediation status (choose all that apply): Operating 

Multiple OUs?* No Construction completion date: September 1999 

Has site been put into reuse? Yes

REVIEW STATUS

Lead agency: USEPA 

Author name: Sharon Hayes and Bob Cianciarulo

Author title: Remedial Project Manager Author affiliation: USEPA

Review period: 05/04 to 12/04 

Date(s) of site inspection: 5/12/04 

Type of review:

X Post-SARA _ Pre-SARA _ NPL-Removal only 

Review number: 2 

Triggering action: 

Completion of First Five Year Review 

Triggering action date (from WasteLAN): 1999 

Due date (five years after triggering action date): 12/30/04

 
Norwood PCBs Superfund Site 

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Five-Year Review Summary Form (cont)

Issues: 

1) Groundwater treatment was stopped before ROD-specified clean up goals were met; new clean-up goals are 

being established under an Explanation of Significant Differences (ESD) issued concurrently with this 5-year 

Review. 

2) Additional groundwater monitoring is needed to ensure that new clean up goals are being met. 

3) Updated Institutional Controls have not been recorded. 

4) Monitoring of the remedy will continue as long as contamination above action levels remains on site.

Recommendations and Follow-up Actions: 

1) Continue groundwater monitoring; evaluate need for future groundwater extraction and treatment. 

2) Record updated Institutional Controls. 

3) Continue monitoring and O&M 

Protectiveness Statement: 

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. 
Norwood PCBs Superfund Site 

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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 of the 

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), as amended, and 40 C.F.R. 

§300.430(f)(4)(ii) of the 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 will 

not allow for unlimited use, future 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. 
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2.0 SITE CHRONOLOGY 

Major Site activities are summarized in Table 2-1

Table 2-1 

Site Chronology 

06/01/83 Initial discovery of contamination on the property 

06/24/83 Initial Removal Actions begin 

08/03/83 Removal Actions complete 

06/10/86 Site listed on National Priorities List (NPL) 

05/21/87 Remedial Investigation/Feasibility Study (RI/FS) complete 

09/29/89 Record of Decision (ROD) signed 

04/07/94 Remedial Design complete 

11/22/94 On-site construction begins for first phase, groundwater treatment plant 

01/11/96 Groundwater treatment plant construction complete (Phase 1) 

03/01/96 Operation and Maintenance of treatment system begins 

05/17/96 ROD Amendment Signed 

02/06/97 USEPA and MADEP performed final inspection of building demolition (Phase 2) 

04/97 PRP initiated Cap/Cover activities 

10/97 Meadow Brook Restoration begins 

08/11/98 USEPA and MADEP performed a final inspection of Cap/Cover (Phase 3A) 

08/11/99 USEPA and MADEP performed a final inspection of Meadow Brook Restoration – 

Phase 3B 

09/99 Construction Completion designation achieved 

12/30/99 First 5-Year Review complete 

04/00 Final Supplemental Risk Assessment submitted 

06/00 Groundwater treatment system temporarily shut down 

05/11/01 Groundwater Use and Value determination prepared by MADEP 

05/28/02 Final Amendment to the Risk Assessment submitted 

12/15/04 Final Cap & Cover Operation and Maintenance Plan approved 

12/30/04 Second Five-Year Review complete 
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3.0 BACKGROUND 

3.1 SITE DESCRIPTION 

The Norwood PCBs Superfund Site (referred to as the “Site”) is located in Norwood, Massachusetts 

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

for a Site Plan (Figure 5 of the GZA 2003 Soil/Brook Remedial Construction Report). It encompasses 

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 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 Cornell-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 Cornell-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 street, Kerry Place. 

On April 1, 1983, the MADEP, 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 investigation by MADEP was conducted. On 

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

confirmed the presence of PCBs. The MADEP 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 funds, the MADEP requested USEPA involvement. Subsequently, USEPA contractors 

assisted MADEP 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 
Norwood PCBs Superfund Site 

Five-Year Review Report December 2004 

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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 Site. A total of 518 

tons of contaminated soil was removed and disposed. The soils were removed from locations within the 

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, MADEP 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 MADEP contractor 

installed a cap over a 1.5-acre portion of the northwest and southwest corners of the Grant Gear Property. 

The contaminated surface soils were covered with a filter fabric liner and 6 inches of crushed 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 

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

2. Removal Action completed January 1986 by MADEP - 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 future 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 3-1 presents the contaminants found on the Site, the 

media in which they were found, and the group to which the contaminant belongs. 
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Table 3-1 

Norwood PCBs Superfund Site 

List of Contaminants 

Contaminant Media Contaminant Group 

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

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

1,2-Dichlorobenzene Groundwater, Sediment, Soil VOC 

1,2-Dichloroethane Groundwater, Sediment, Soil VOC 

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

1,3-Dichlorobenzene Groundwater, Sediment, Soil VOC 

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

Aroclor 1016 Groundwater, Sediment, Soil PCBs 

Aroclor 1254 Groundwater, 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 Groundwater, Sediment, Soil VOC 

PAH Groundwater, Sediment, Soil PAH 

PCBs Groundwater, Sediment, Soil PCBs 

Pentachloroethane Groundwater, Sediment, Soil VOC 

Phenol Groundwater, Sediment, Soil Base Neutral Acids 

Silver Groundwater, Sediment, Soil Metals 

Vinyl chloride Groundwater, Sediment, Soil VOC 

Zinc Groundwater, Sediment, Soil Metals 
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4.0 REMEDIAL ACTIONS 

4.1 REMEDY SELECTION 

Under its legal authorities, the USEPA's primary responsibility at Superfund sites is to undertake 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 and more stringent State environmental 

standards, requirements, criteria, or limitations, unless a waiver is invoked. 

• Select RAs shall be cost-effective and utilize permanent solutions and alternative 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 of the hazardous substances. 

The ROD for the Norwood PCBs site was published and 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 alternatives at 

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

selected alternative 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) regarding 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 as well as available 

funding for the project. Also based upon that proposal, the USEPA believed that there would be 

difficulties in properly siting the appropriate solvent extraction facilities 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. An Amended ROD 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 
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contaminated soil from portions of the Grant Gear property and from other surrounding properties, 

including sediments from the Meadow Brook, restoration of Meadow Brook consistent with the Town’s 

flood control project, and finally cap and cover the 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 airborne 

contaminants volatilized from groundwater. 

• To reduce risks to human health and the environment from current and future 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 amended ROD in 1996 did not change the groundwater treatment facility proposal, but 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. 

4.1.3 Remedial Action Objectives: Meadow Brook Sediment 

According to the 1989 ROD, steps would be taken to minimize the destruction, loss, and degradation of 

wetlands during implementation of the remedy, including the use of sedimentation basins or silt curtains 

to prevent downstream transport of contaminated sediments. A wetland restoration program would be 

implemented upon completion of the remedial activities in wetland areas adversely impacted by remedial 

action and ancillary activities. 

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

• Mitigate any future impacts of such activities to Meadow Brook and the surrounding wetland 

areas. 
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Five-Year Review Report December 2004 

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Measures to be used would include 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 construction upon completion of the remedial action of the Meadow 

Brook area performed under Superfund. Therefore, upon completion of the soil and sediment excavation 

of the Meadow Brook, the brook streambed and adjacent banks from these areas would be 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 alternative 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 proposed as part of the 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 airborne 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 of the 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 of the 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 sec., requirements. Debris that was uncontaminated could be reused or recycled as 

appropriate. 

4.2 REMEDY IMPLEMENTATION 

The USEPA issued a ROD in 1989 and an Amended ROD in 1996. Three separate remedial action 

phases have been completed at the Site. Phase 1 was completed by the USEPA and consisted of 

groundwater treatment. Phase 2 was conducted by the Settling Defendants and consisted of building 

demolition. Phase 3 was conducted by the Settling Defendants and consisted of the construction of a cap 

and cover over consolidated contaminated soil and sediments, and Meadow Brook restoration. Remedies 

implemented at the Site are briefly described in the following subsections. 
Norwood PCBs Superfund Site 

Five-Year Review Report December 2004 

4-4

4.2.1 Source Control and Soil and Sediment / Cap and Cover 

The Settling Defendants performed excavation of sediments in Meadow Brook as proposed in the 1989 

ROD from April 28, 1997 through July 30, 1998, with a temporary work stoppage from February 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 of the stream. Dewatering cells were constructed in the northern portion of the Hurley property, 

located west of the existing groundwater treatment plant. Two dewatering cells were constructed - 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 

(yd3

) 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 yd3

 of material was excavated 

from 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 of the design excavation grade at the former drainage outfall pipe. On June 11, 1997, 

after receiving direction from 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 yd3

. 

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 of the 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 yd3

 of PCB-contaminated soil was excavated from the North Cover Area and stockpiled on-site for 

placement under the cap/cover. Approximately 2,600 yd3

 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 yd3

 of soil was excavated from the southern half of the western North 

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

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

Bank Wooded Area. Approximately 780 yd3

 of soil was excavated from the South Bank Wooded Area 

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

property were relocated to the Hurley property. The approximately 1,600 yd3

 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 of the property adjacent to the south end of the Hurley property. Both 

stockpiles were excavated, transported, and stockpiled near the southwest corner of the 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 
Norwood PCBs Superfund Site 

Five-Year Review Report December 2004 

4-5

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

limits of the 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 fuel tank located at the southwest corner 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 corner 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 this runoff, and to maximize the area of the Property 

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

drainage manholes, drainage lines, flared-end sections, and outlet control structures 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 constructed in 1995. The objective of the 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 construction of the 

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

and the MADEP conducted a pre-final inspection of the treatment facility and it was deemed operational 

and functional on February 23, 1997. 

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

Sodium hydroxide was added to the collected groundwater 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 

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 try 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 from the sludge during dewatering was 

pumped back to the inlet equalization tank and mixed with the collected groundwater for treatment. 
Norwood PCBs Superfund Site 

Five-Year Review Report December 2004 

4-6

The groundwater treatment system was operational until it was temporarily shut down in June of 2000. It 

is, however, still intact until a determination is made on whether it is needed anymore. 

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 of the Site. 

Although clean up levels for PCBs in the brook sediments was 1 ppm, the brook was only excavated to 

the depths required to meet the contours of the 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 the remaining contamination located at 

depths below the flood control contours of the restored brook’s 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, 

a decision was made to utilize precast concrete channel sections. This redesign effort, as well as several 

high water conditions, resulted in 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 were transferred 

to the Town of Norwood. 

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 structural steel, equipment, concrete/brick, and roof decking. Brick, 

concrete block, and wallboard materials were crushed 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, structural 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 

constructed over the boiler room opening. 

4.3 OPERATION AND MAINTENANCE 

4.3.1 Cap/Cover 

For several years, EPA and DEP have worked with the Settling Defendants to compel them to produce an 

acceptable O&M Plan for the Cap & Cover portion of remedial actions at the Norwood PCBs Site. Final 

plans were approved in December 2004. The purpose of the Operation & Maintenance (O&M) Plan is to 

outline the actions that will be taken 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; and a monitoring well 

maintenance program. 
Norwood PCBs Superfund Site 

Five-Year Review Report December 2004 

4-7

4.3.2 Groundwater Treatment 

In accordance with Section 104(c)(3)(A) of CERCLA, 42 U.S.C. § 9603(c)(30)(A), states are responsible 

for all future O&M activities for the 30-year expected life of these remedies on fund lead projects. 

CERCLA and the NCP handle state O&M responsibility for groundwater cleanup actions somewhat 

differently than other remedial actions. The State’s obligation to assure O&M of the groundwater 

collection and treatment system and monitoring well network will begin upon completion of the 

restoration phase, which is when the clean up goals in the ROD are achieved or ten years have elapsed, 

whichever is earlier. The finding that the groundwater clean up goals established in the ROD have been 

achieved will be based upon groundwater monitoring to verify that clean up goals have indeed been met. 

In the event that groundwater clean up goals are achieved during the restoration phase, the State will have 

no obligation to assure O&M of the groundwater collection and treatment system and monitoring well 

network. With the change in groundwater clean up levels outlined in the ESD, no long-term groundwater 

treatment is expected and therefore O&M of the groundwater portion is not expected to be needed. 

4.3.3 Meadow Brook Restoration 

An 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 was intended to enable the Town to obtain all 

benefits and protection for which the restoration was designed. Failure to maintain and operate the 

project could cause property losses and loss of public confidence in the flood protection system. 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 were recommended at least every three months to detect deterioration of project 

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

Obstructions caused by debris were to be removed. Vegetation should be allowed to grow in certain 

areas, but not others. Details are discussed in the Meadow Brook O&M Manual (USACE, June 2000). 

Inspection and annual reporting was recommended. Monitoring of water quality and sediment in 

Meadow Brook will also be conducted to assess whether the remedy is remaining protective.
Norwood PCBs Superfund Site 

Five-Year Review Report December 2004 

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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 Five-Year Review 

completed in 1999. 

5.1.1 1999 Protectiveness Statement 

The following statement was included in the 1999 Five-Year Review Report: “I certify that the remedies 

selected for this Site remain protective of human health and the environment.” The 1999 Five-Year 

Review Report was signed by Patricia L. Meaney, 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, which was conducted for this site in 

1999. 

A Supplemental Risk Assessment was completed in 2000 as an update and revision to the 1998 

Groundwater Risk Assessment. The Supplemental Risk Assessment consisted of a human health risk 

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

concluded that an unacceptable risk to inhalation of volatiles from groundwater and subsurface soils may 

be expected and engineering controls may be necessary if the use of the property changes and/or new 

structures were built on the site. The ecological screening assessment of potential impacts on wildlife 

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

The groundwater system was temporarily shut down in June 2000, and groundwater monitoring continued 

quarterly until October 2002. 

Ownership and responsibility for the O&M of the Meadow Brook restoration was transferred to the Town 

of Norwood in August 2000. The Town was supplied with an O&M Manual prepared by the USACE in 

June 2000. 

On May 11, 2001, the MADEP submitted a Groundwater Use and Value Determination for groundwater 

in the vicinity of the Site. The MADEP classified the groundwater at the Site as GW-3, and not a 

potential drinking water source. 

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

Amendment addressed the potential exposures of a future construction worker to the Site groundwater 

and was conducted for possible future development. The results of the analysis indicated that the 

calculated hazard index exceeded the MADEP target level and the calculated carcinogenic risk slightly 

exceeded the MADEP target level for a hypothetical future construction worker exposed to the Site 

groundwater. The elevated risk and hazard index results relative to the MADEP target levels are 

essentially all the result of the detected Aroclor compounds in groundwater and the potential direct 

contact exposure route. 

Foster Wheeler Environmental Corporation, on behalf of the USEPA, subsequently performed a 

supplemental risk analysis for the Site and developed new groundwater clean up goals or risk-based 

action levels (RBALs). 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 
Norwood PCBs Superfund Site 

Five-Year Review Report December 2004 

5-2

concentrations of VOCs and SVOCs in groundwater have all been consistently below the developed 

RBALs with a considerable margin. These RBALs for VOCs and SVOCs are documented as the new 

groundwater clean up goals in the ESD. 

This risk analysis raised some concerns about the remaining PCB contamination in groundwater and its 

impacts on Meadow Brook. At some locations, RBALs for PCBs (4.3 ppb total PCBs) have not been met 

since the shutdown of the treatment facility. In addition, the surface water Ambient Water Quality 

Criteria (AWQC) for PCBs was exceeded at the midstream and downstream stations in the 26th sampling 

round. The Technical Memorandum recommended that the detections of PCBs in surface water of 

Meadow Brook should be further investigated. In response to these exceedances and recommendations, 

additional studies and risk assessments were conducted. 

In July 2004, Tetra Tech FW prepared a Draft Phase 2 Ecological and Human Health Risk Summary 

Report as part of Phase 2 field investigations for Meadow Brook at the Site. The Phase 2 investigation is 

to assess PCB contributions 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. 

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 of the 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. 

Table 5-1 

Issues & Recommendations from Previous Review

Issues from Previous Review Action Taken and Outcome 

A site-specific Risk Assessment needs to be completed. Risk Assessment has been conducted (See 

Section 6.4.2) 

Groundwater clean up standards should be revised to be 

consistent with the State’s current groundwater 

classification. 

USEPA calculated revised groundwater 

clean up levels and are being documented via 

an ESD released concurrent with this FiveYear Review 

Groundwater treatment should be stopped when new clean 

up goals have been reached. 

Groundwater treatment was temporarily 

stopped in June 2000. EPA will evaluate 

data and new standards to make a 

determination as to whether the groundwater 

remedy can be deemed complete. 

Groundwater monitoring should continue to ensure that clean 

up standards have indeed been met. 

Monitoring was continued until October 

2002. Additional monitoring is planned in 

the spring of 2005. Monitoring of the 

remedy will continue as long as 

contaminants above action levels remain in 

place. 
Norwood PCBs Superfund Site 

Five-Year Review Report December 2004 

6-1

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 Shaw provided technical assistance. The review was conducted between May 2004 and December 

2004. The Scope of Work provided to Shaw included the following activities: 

• Project Planning and Support 

• Document Review 

• Standards (ARAR) Review 

• Site Interviews 

• Site Inspection/Technology Review 

• Community Relations 

• Five-Year Review Report 

• Close-Out 

6.2 COMMUNITY NOTIFICATION AND INVOLVEMENT 

Community notification was initiated by the release of the fact sheet announcing the start of the Five-Year 

Review. Stacy Greendlinger, USEPA Community Involvement Coordinator, issued the fact sheet in June 

2004. The notification went out to over 300 parties including abutters, community members, and 

interested Federal, State, and local agencies. In addition, an article was published in the Daily News 

Transcript covering the start of the Five-Year Review. 

Another fact sheet and notification to the newspaper will be issued announcing the completion of the 

report and the results of the review. A copy of the final report will be available for review at the Morrill 

Memorial Library, Norwood, MA; the USEPA’s Region 1 Office; and the USEPA’s website at 

http://www.epa.gov/region1/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 MADEP Groundwater Use and Value Determination 
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Five-Year Review Report December 2004 

6-2

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

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

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

Wheeler) 

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

13. September 2003 Soil/Brook Remedial Construction 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) 

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 temporarily shut down, however, quarterly 

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

monitoring round was conducted in October 2002 (the 27th monitoring round). An additional round of 

groundwater monitoring is planned for the Spring 2005. 

The 27th 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. 

Laboratory analytical data for the 27th quarter was similar to results in prior monitoring rounds, except for 

a few minor changes. Certain monitoring and extraction wells showed increased total chlorinated volatile 

organics (TCV) concentrations, including EW-11. Other wells, including EW-8 and EW-9, decreased 

since the previous monitoring round. Groundwater chemical and hydrogeological data continue to 

suggest that elements of the VOC plume are shifting north and migrating toward Meadow Brook. Trace 

levels of chlorinated volatiles were again detected in Meadow Brook at one sample location. 

The volatile data for the 27th monitoring round indicated that the frequency of vinyl chloride increased 

significantly (20/40 wells) in comparison to previous sampling rounds (12/40 wells). Also, high vinyl 

chloride concentrations were observed in EW-8, EW-9, ME-11A, and ME-8. The results suggest that 

increasing amounts of vinyl chloride may be resulting from the degradation of Trichloroethylene (TCE). 

The results of the 27th groundwater monitoring round depict a decreasing chlorinated hydrocarbon 

product/daughter mole ratio, moving eastward. These results suggest that active TCE biodegradation may 

be occurring at the Site. The results for vinyl chloride also suggest the likelihood of ongoing 

biodegradation, particularly in some northern portions of the Site. 

Trace levels of PCBs were detected in Meadow Brook surface water at one sampling location. This result 

supports the previous detection of PCBs in surface water in the previous (26th) monitoring round. This 

data raised the possibility that PCBs might be slowly migrating toward Meadow Brook with Site 

groundwater. PCBs were detected in wells ME-11B, EW-4, and EW-5 near Meadow Brook. Analytical 

Results from the 27th Quarterly Sampling Event are given in Table 6-1. 
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Five-Year Review Report 

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Table 6-1 

27th Quarterly Groundwater Analytical Results – Data Summary & Comparison to Stand

Chemical ROD 

Clean Up 

Level 

mg/L 

Number of 

Samples 

Exceeding 

ROD Clean 

Up Levels 

New Clean 

Up Goals 

mg/L 

Number of 

Samples 

Exceeding 

New Clean 

Up Levels

MCP 

GW-2 

mg/L 

MCP

GW-3 

mg/L 

Detection 

Frequency

Maximum 

Concentrat

mg/L 

Volatile Organic Compounds Chlorobenzene NA NA NA NA 1 0.5 4/40 0.063 Cis-1,2-Dichloroethene NA NA NA NA 20 50 28/40 2.2 trans-1,2-Dichloroethene NA NA NA NA 20 50 13/40 0.160 1,2-Dichloroethylene (total) 0.175 8 3,660 0 20 50 28/40 2.5 Tetrachloroethene 0.005 1 37 0 3 5 4/40 0.0052 1,1,2-trichloroethane NA NA NA NA 20 50 3/40 0.012 Trichloroethylene 0.005 15 108 0 0.3 20 26/40 1.4 Vinyl Chloride 0.002 15 310 0 0.002 40 20/40 0.088 Semi-Volatile Organic Compounds 1,2-Dichlorobenzene NA NA NA NA 10 8 3/40 0.017 1,3-Dichlorobenzene NA NA NA NA 10 8 2/40 0.030 1,4-Dichlorobenzene 0.005 4 4.6 0 30 8 5/40 0.030 1,2,4-Trichlorobenzene 0.030 2 34 0 10 0.5 8/40 1.4 PCBs Aroclor-1016 NA NA NA NA NA 0.0003 0/40 NA Aroclor-1221 NA NA NA NA NA 0.0003 0/40 NA Aroclor-1242 NA NA NA NA NA 0.0003 1/40 0.00028 Aroclor-1248 NA NA NA NA NA 0.0003 4/40 0.0084 Aroclor-1254 NA NA NA NA NA 0.0003 9/40 0.012 Aroclor-1260 NA NA NA NA NA 0.0003 0/40 NA 

NA- Not Applicable New Clean Up Goals are published in the ESD 
Norwood PCBs Superfund Site 

Five-Year Review Report December 2004 

6-4

The results of the 27th quarterly groundwater monitoring report indicated the continued presence of target 

chlorinated volatile organics in groundwater across the Site, with sporadic detections of SVOCs, 

particularly 1,2,4-trichlorobenzene. PCBs were detected in less than half of the wells across the Site. 

VOCs did not exceed Massachusetts Contingency Plan (MCP) GW-3 standards for any chlorinated 

solvents, although vinyl chloride and TCE were determined to exceed MCP GW-2 standards. SVOCs 

were detected in eight samples. This is one more than the previous quarter. SVOCs were detected below 

MCP GW-2 and GW-3 standards, except 1,2,4-Trichlorobenzene, which was detected above GW-3 but 

well below the RBAL concentration of 34 ppm. None of these results exceeded the new groundwater 

clean up levels, documented in the ESD. PCBs, for which no cleanup standard was set, were detected in a 

total of 14 wells. PCB concentrations ranged from 0.05 μg/L to 12 μg/L. PCB concentrations in twelve 

samples equal or exceed the MCP GW-3 standard of 0.3 μg/L as well as the RBAL that was calculated 

for PCBs. In addition to the groundwater monitoring round planned for Spring 2005, future groundwater 

data will be collected by the Settling Defendants as part of their Operation and Maintenance 

responsibilities. 

6.4.2 Risk Assessment Data 

An Initial Groundwater Risk Assessment for the Site was completed in 1998 by GZA. The Groundwater 

Risk Assessment evaluated exposure to chemicals that may volatilize from groundwater into the indoor 

air of a proposed building and an environmental exposure to groundwater that may discharge to Meadow 

Brook. 

A Supplemental Risk Assessment was completed in 2000 by Foster Wheeler as an update and revision 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 groundwater in a possible future commercial building that could be constructed on 

the Site. 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 driving factors of risk were the presence of vinyl chloride and 

trichloroethene in groundwater and trichloroethene and methylene chloride in subsurface soil. An 

assessment of potential indoor inhalation risks under future 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 an unacceptable risk to inhalation of volatiles from groundwater and 

subsurface soils may be expected and engineering controls may be necessary if the use of the property 

changes and/or new structures were built on the site. 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 future construction worker to the Site groundwater. The results of 

the analysis indicated that the calculated hazard index exceeded the MADEP target level and the 

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

construction worker exposed to the Site groundwater. These projected results are based on an assumption 

of repetitive dermal inhalation exposure over the course of a construction effort that may be associated 

with a new commercial building. The elevated risk and hazard index results relative to the MADEP target 

levels are essentially all the result of the detected Aroclor compounds in groundwater and the potential 

direct contact exposure route. Thus, any future excavation activities at the site for redevelopment or for 

other purposes, would likely require appropriate Health and Safety training and Personal Protective 
Norwood PCBs Superfund Site 

Five-Year Review Report December 2004 

6-5

Equipment (PPE) to minimize risk to construction workers and be conducted in compliance with 

applicable laws and regulations and the Institutional Controls for the site. 

Foster Wheeler Environmental Corporation, on behalf of USEPA, subsequently performed a 

supplemental risk analysis for the Site and developed new groundwater clean up goals [or Risk-Based 

Action Levels (RBALs)] acknowledging MADEP’s revised groundwater classification. 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 

developed RBALs with a considerable margin. These RBALs are documented as the new groundwater 

clean up goals in the ESD. This risk analysis raised some concerns about the remaining PCB 

contamination in groundwater and its impacts on Meadow Brook. RBALs for PCBs have not been made 

since the shutdown of the treatment facility. 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 26th sampling round. The Technical Memorandum 

recommended that the detections of PCBs in surface water of Meadow Brook should be further 

investigated and a second phase (“Phase II”) of investigation was initiated. 

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 is 

to assess PCB contributions 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 human health concerns 

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

concern associated with long-term direct contact exposure to soil was indicated at discrete locations offsite and down stream of the site, adjacent to the Neponset River and the Town of Norwood electrical 

Substation. No human health concerns relating to sediment samples taken from Meadow Brook and the 

Neponset River were indicated. Based on this data, and the 1989 ROD’s 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 

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 will 

continue to be conducted to evaluate long-term compliance with AWQCs and to ensure that they 

do not increase to a level that may pose an unacceptable risk to human health or the environment.

6.5 SITE INSPECTION 

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

May 12, 2004. The inspection was conducted by Sharon Hayes, USEPA Remedial Project Manager, Bob 

Cianciarulo, USEPA Massachusetts Superfund Section Chief, Chris Turek, USACE Resident Engineer, 

Daniel Keefe, MADEP Project Manager, and Eileen London and Pernilla Lindblom of Shaw. 

Pernilla Lindblom and Eileen London returned to the Site on September 7, 2004 to verify that some issues 

had been addressed since the original Site visit. 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. 
Norwood PCBs Superfund Site 

Five-Year Review Report December 2004 

6-6

Table 6-2 

Site Investigation Summary

Access and Site 

Roads 

The current occupant (storing new automobiles) has staff that routinely visit the site to pick 

up and drop off vehicles. After business hours, cars are routinely parked to block the 

entrance thereby inhibiting vehicular access; however, pedestrian access is unrestricted 

Groundwater 

Treatment Plant 

The building appears in good condition. See Photograph 1 and 2. The treatment plant is 

not currently operating, however, the equipment appears to be in good condition. The 

discharge pipe is located adjacent to Meadow Brook, and has been capped while the system 

is not in use. See Photograph 3. 

Treatment facility 

access and security 

A security system is installed in the treatment facility. The building is kept locked when it 

is not occupied. 

Detention Basin 

(along Meadow 

Brook) 

The detention basin was dry during the Site visit, which is the normal condition. See 

photographs 4 and 5. Gravel from plowing activities was noted in the detention basin. See 

photograph 6. Some vegetation was noted to have begun growing in the spillway. See 

photograph 7. In September, Shaw verified that the vegetation issues had been addressed 

in the basin and had been mowed. 

Detention Basin 

Side Slopes 

Some areas of missing riprap were noted along the landfill cover on the detention basin 

slopes. The geotextile fabric was exposed in these missing riprap areas. See photograph 8. 

In September, it was verified that these issues had been resolved, although the geotextile 

was beginning to show again and this may be a reoccurring issue, which should be checked. 

See photograph 9. 

Cover Areas Cover areas appear to be in good condition. Some vegetation (grass) has begun to grow 

which may be a future issue. See photograph 10 and 11. 

Cap Areas The cap appears to be in good condition. No areas of settling were noted. A few cracks 

were noted which should be investigated. See photograph 12. Gravel was noted on the 

northern cap area (possibly from snow removal activities). See photograph 13. It was 

verified in September that this gravel had been removed. See photograph 14. Much of the 

cap areas had parked cars on it, which limited observation ability. 

Cap Area Use Cape Cod berms were damaged on both the north and south side of the cover area, due to 

plowing. See photographs 15 though 17. Repairs may have begun by the second visit, but 

were not complete. See photograph 16. 

Monitoring Wells A monitoring well was found without a lock in the north cap area. See Photograph 18. 

Meadow Brook No vegetation or debris was encountered which could impede flow. See photographs 19 

through 22. 

Although no major issues were found that would affect the protectiveness of the remedies, there were 

several issues that, if not corrected or if left unchecked, could affect components at the site or could 

potentially affect the protectiveness of the remedy. See Section 8.0. 
Norwood PCBs Superfund Site 

Five-Year Review Report December 2004 

6-7

6.6 INTERVIEWS 

Interviews of owners and businesses adjacent to the Site, and of local and State officials, were conducted. 

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

current understanding of activities at the Site. 

A few neighboring businesses were visited on June 22, 2004. During these visits, John Marcelonis (sales 

person at Direct Tire), Bill Eliot (Fill-In Manager at Lappens), and Michelle Coffin (Curriculum 

Coordinator at Neponset Valley Child Care) were interviewed. No significant problems regarding the 

Site were identified during the interviews. 

On August 5, 2004, Steve Costello, Norwood’s Town Planner, was interviewed. The main issue that he 

voiced was possible redevelopment plans for the Site. He believed that the public would not have a 

problem with redevelopment, as long as the cap was not disturbed. He hoped that the next possible 

developer would be prepared to present plans to the public and would work with the EPA and Town of 

Norwood on a redevelopment plan. 

On August 12, 2004, Dan Keefe (the current DEP Site Project Manager) and Jay Naparstek (the former 

DEP Site Project Manager) were interviewed. Both believed that the main issues regarding the Site are as 

follows: 

1. An acceptable O&M Plan had not been submitted for the Cap and Cover, although they expected 

one by the end of the year. 

2. Revised Institutional Controls have been drafted but have not yet been filed for the Site. 

On August 18, 2004, Joe Laham (the Site owner) was interviewed. Joe Laham was dissatisfied with the 

EPAs performance at the Site. He believes that the EPA should take a more proactive role in convincing 

the public that there are no environmental issues with the redevelopment of the Site, and that the EPA 

should be more helpful in getting the public to accept development plans. He was under the impression 

that the groundwater treatment system plant was to be demolished soon and wanted to know the 

timeframe for this. He had no knowledge of when institutional controls were to be issued. 

Chris Turek of the Army Corps of Engineers was interviewed on September 12, 2004. He believed that 

the construction went well, with the exception of a few minor difficulties. He speculated that if more 

monitoring wells had been installed, or if they had been located differently, that more definitive 

information may have been obtained, which could have made the treatment decisions more definitive. 

Interview notes are provided in Appendix C. 
Norwood PCBs Superfund Site 

Five-Year Review Report December 2004 

7-1

7.0 TECHNICAL ASSESSMENT 

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

DECISION DOCUMENTS? 

The review of documents, ARARs, and the results of the May 2004 site inspection indicate that the 

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

RA has been determined to be performing as expected. New clean up goals should be published and a 

groundwater sampling round should be conducted to verify that the new clean up goals are being met. 

Indicators of potential issues pointing to a failing 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 of the remedy. 

Institutional Controls (ICs) have been recorded on the main site property (921 Providence Highway) as 

part of a settlement with then-owners Grant Gear, Inc. (often referred to as the "Hurley Controls", after 

Grant Gear's owners, the Hurley brothers). Those ICs describe the remedy as planned in the 1989 ROD. 

Subsequently, new ICs were drawn up to reflect the amended remedy and incorporated into the 

Prospective Purchaser Agreement with Joe Laham (the Site owner). Those new ICs have not yet been 

recorded on the property deed. Until new ICs are changed the "Hurley Controls" remain in effect. ICs 

for the Meadow Brook Property were drafted and included as part of a Consent Decree with the Town of 

Norwood, but may need to be modified and have not been recorded yet. 

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. Criteria considered in selecting clean 

up levels at the Site have not changed and will not affect the protectiveness of the remedy. 

Land use or expected land use on or near the Site has not changed; however, proposed redevelopment 

planning is ongoing. There have been no newly identified human health or ecological routes of exposure 

or receptors identified or changed in a way that could affect the protectiveness of the remedy. There are 

no newly identified contaminants or contaminant sources. Also, there are no unanticipated toxic 

byproducts of the remedy not previously addressed by the decision documents. Physical Site conditions 

have not changed in a way that could affect the protectiveness of the remedy. However, continued 

monitoring of groundwater as well as Meadow Brook surface water and sediment will be critical in 

evaluating the functionality and protectiveness of the remedy. 

Containment characteristics and toxicity factors for contaminants of concern at the Site have not changed 

in a way that could affect the protectiveness of the remedy. In addition, standardized risk assessment 

methodologies have not changed in a way that could affect the protectiveness of the remedy. 
Norwood PCBs Superfund Site 

Five-Year Review Report December 2004 

7-2

Groundwater

The Site aquifer has been reclassified by the State and it is no longer classified as a current or potential 

future drinking water supply by the Commonwealth of Massachusetts. Therefore, Maximum 

Contaminant Levels (MCLs) promulgated under the Safe Drinking Water Act, and Massachusetts 

Drinking Water Standards are not applicable. As a result of the revised aquifer classification and 

additional risk assessment activities, the USEPA calculated revised groundwater clean up goals which are 

being documented in the ESD published concurrent with this Five Year Review. 

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 May and September 2004 site inspections that could affect the protectiveness 

of the 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 RODs were 

issued. For the purposes of this review and compliance with current requirements, ARARs are 

summarized in a table presented in Appendix B. 

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 and amended ROD, would be in compliance with the 

requirement. 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 rules and regulations. Recommendations are made as to whether any changes to 

the list of contaminants of concern 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 of Massachusetts should 

be requested to identify State ARARs promulgated or modified since the ROD and amended ROD were 

signed, which may have a bearing on the protectiveness of the remedy. According to the DEP, the only 

regulation that should affect the ARARs is the change in groundwater classification from GW-1. 

Few changes to the ARARs have occurred since the Amended ROD was signed. Most location specific 

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

discussed in the last Five-Year Review. Ambient Water Quality Criteria (AWQCs) have been added as 

action-specific standards for monitoring water quality in Meadow Brook. The ARARs that are no longer 

necessary have been removed from the list (presented in Appendix B) 

It should be noted that Massachusetts Drinking Water Standards and Maximum Contaminant Levels 

should have been included in the list of chemical-specific ARARs originally; however, they are no longer 

applicable since the groundwater in the area has been reclassified. 
Norwood PCBs Superfund Site 

Five-Year Review Report December 2004 

8-1

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 

Affects Current 

Protectiveness 

(Y/N) 

Affects Future 

Protectiveness

(Y/N) 

New groundwater monitoring data should be collected and evaluated 

relative to revised clean up standards 

Y Y 

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 

N Y 

New Institutional Controls have not been recorded. N Y 

A monitoring well was observed without a lock in the north cap area. N N 

No O&M procedures have been conducted in the Meadow Brook. N Y 

Cracks were noted in the cap, which need to be investigated. N N 

Cap Cod berms were damaged during plowing. N N 
Norwood PCBs Superfund Site 

Five-Year Review Report December 2004 

9-1

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 Affects 

Protectiveness (Y/N) Recommendations and 

Follow-up Actions 

Party 

Responsible

Oversight 

Agency 

Milestone 

Date 

Current Future 

Groundwater 

Treatment 

Continue to monitor 

groundwater to determine 

compliance with new clean up 

goals, evaluate whether 

groundwater remedy can be 

deemed complete. 

USEPA USEPA 6/05 Y Y 

Meadow 

Brook 

Monitoring 

Continue to monitor surface 

water and sediment to determine 

compliance with ARARs and 

protectiveness of the remedy 

USEPA, 

Settling 

Defendants

USEPA Periodic N Y 

Meadow 

Brook O&M 

Maintain Meadow Brook O&M Town of 

Norwood 

USEPA Periodic N Y 

Cap & Cover 

O&M 

Maintain Cap/cover O&M Settling 

Defendants

USEPA Periodic N Y 

ICs Record new ICs Owner and 

MADEP 

MADEP 6/05 N Y 

Owner O&M Owner should follow 

recommendations outlined in 

Cap & Cover O&M Plan 

Property 

Owner 

USEPA Periodic N Y 
Norwood PCBs Superfund Site 

Five-Year Review Report December 2004 

11-1

10.0 PROTECTIVENESS STATEMENTS 

10.1 PROTECTIVENESS 

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. 
Norwood PCBs Superfund Site 

Five-Year Review Report December 2004 

11-2

11.0 NEXT REVIEW 

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

Review will be due five years from the signature date of this (second) Five-Year Review. 
Norwood PCBs Superfund Site 

Five-Year Review Report December 2004 

12-1

12.0 REFERENCES 

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

PCB Superfund Site. April 2000. 

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

Norwood PCB Superfund 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. Final Technical Memorandum, Development of 

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

Concern in the Groundwater at the Norwood PCB Superfund Site. March 2003. 

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

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

Site. January 2004. 

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

Superfund Site. January 2004. 

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

Site. December 2004. 

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

Determination. May 11, 2001. 

10. Nobis Engineering Inc. and Foster Wheeler Environmental Corporation, 2002. 27th Quarterly 

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

2002 Sampling Event. March 4, 2003. 

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

Norwood PCB Superfund Site. July 2004. 

12. U.S. Environmental Protection Agency, 1989. USEPA Superfund Record of Decision, Norwood 

PCBs. September 29, 1989. 

13. U.S. Environmental Protection Agency, 1996. USEPA Superfund Record of Decision Amendment, 

Norwood PCBs. May 17, 1996. 

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

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

Norwood, Massachusetts. December 1999. 

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

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

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

Restoration, Norwood, Massachusetts. June 2000. 
Norwood PCBs Superfund Site 

Five-Year Review Report December 2004 

12-2

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

Norwood, Massachusetts. January 2002. 
Norwood PCBs Superfund Site 

Five-Year Review Report December 2004 

A-1

APPENDIX A 

SITE MAPS 
NORWOOD

CANTON

WALPOLE SHARON SHARON

NORWOOD PCB SUPERFUND SITE

NORWOOD, MASSACHUSETTS

FIGURE 1 

SITE LOCUS PLAN

SOURCE 

USGS TOPOGRAPHIC QUAD

MASSGIS 

 ́

0 0.2 0.4 0.6 0.8 0.1

Miles

\\swibosfs01\envir\DHuffaker\working\Norwood Dec. 14, 2004

SITE
INSERT POUCH HERE
Norwood PCBs Superfund Site 

Five-Year Review Report December 2004 

B -1

APPENDIX B 

TABLES DOCUMENTING ARARs 
AUTHORITY REQUIREMENT STATUS REQUIREMENT SYNOPSIS ACTION TAKEN TO 

ARARs

B-2 

CHEMICAL SPECIFIC ARARs: Federal Criteria, Technical Basis for Deriving Sediment To be This guidance is used to establish criteria to The criteria established 

Advisories, and Guidance Quality Criteria for Non-ionic Organic Considered protect the aquatic organisms in streams and to evaluate risks to aquati Contaminants for the Protection of Benthic determine environmental risk exposed to contaminat

 Organisms Using Equilibrium Partitioning within the sediment and to set sediment.  (EPA-822-R-93-011) cleanup levels.  Clean Water Act – Sec. 304 Relevant and Federal AWQC are criteria for protection of AWQC were used to c Federal Ambient Water Quality Criteria Appropriate human health and aquatic organisms which have to fresh water aquatic l

 33 USC 1314; 40 CFR 122.44 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.  EPA Carcinogenic Assessment Group To be Potency factors are developed by the EPA from EPA Carcinogenic Pot

 Potency Factors Considered Health Effects Assessments or Evaluation by the used to complete the in Carcinogenic Assessment Group. incremental cancer risk  exposure to site contam EPA Risk Reference Doses (RfDs) To be RfDs are does levels developed by the EPA for EPA RfDs were used t Considered non-carcinogenic effects. risks due to exposure t site. LOCATION SPECIFIC ARARs Federal Regulatory Wetlands Executive Order (EO 11990) Applicable Under this regulation, Federal agencies are Any redevelopment or  40 CFR Part 6, Appendix A required to minimize the destruction, loss, or all practicable means o degradation of wetlands, and preserve and harm to wetlands.  enhance natural and beneficial values of  wetlands.  Floodplains Executive Order (EO 11988) Applicable Federal agencies are required to reduce the risk The remedial action w

 40 CFR Part 6, Appendix A of flood loss, to minimize the impact of floods, keep all activities out o

 and to restore and preserve the natural and the greatest extent prac beneficial values of floodplains.  Clean Water Act (CWA) – Section 404 Applicable No activity that adversely affects a wetland shall Ongoing monitoring an

 Dredge and Fill Requirements be permitted if a practicable alternative that has adjacent to Meadow B (33 U.S.C. 1344; 40 CFR Part 230) less effect is available. wetlands will meet the Fish and Wildlife Coordination Act Applicable Before undertaking any Federal action that causes Federal and State fish a 16 U.S.C. 661 the modification of any body of water or affects consulted concerning a fish and wildlife. activities in and adjace
AUTHORITY REQUIREMENT STATUS REQUIREMENT SYNOPSIS ACTION TAKEN TO 

ARARs

B-3 

 Resource Conservation and Recovery Act Relevant and This regulation outlines the requirements for Hazardous waste dispo

 (RCRA) Location Standards Appropriate constructing a RCRA facility on a 100-year floodplain of Meadow  (40 C.F.R. 264.18) floodplain. prevent a release of ha

 flood event. State Regulatory Massachusetts Wetlands Protection Act Applicable These regulations outline the requirements All redevelopment, mo (M.G.L. c.131 Section 40 necessary to work within 100 feet of a wetland. areas regulated under t : 310 CMR 10.00) in compliance with the Massachusetts Waterways Regulations Applicable Regulates work within waterways, including All redevelopment, mo

 (M.G.L. c.21, Sections 26-53; 314 CMR 9.00) water quality protection. or adjacent to Meadow 

 standards. ACTION SPECIFIC ARARs Federal Regulatory Resource Conservation and Recovery Act Applicable RCRA regulates the generation, transport, Wastes generated durin

Requirements (RCRA) Subtitle C (40 C.F.R. 260-262) (for generated storage, treatment, and disposal of hazardous or O & M activities wi

 wastes)/; Waste. CERCLA specifically requires (in and handled in accorda

 Relevant and Section 121(d)(3) that hazardous substances regulations. Wastes le Appropriate from response actions be disposed of at facilities will be managed in com (for closure/ in compliance with Subtitle C of RCRA and post-closure standa post closure)  Toxic Substances Control Act (TSCA), Applicable Establishes standards for PCB landfills, including Closure/post closures s 15 U.S.C. §§ 2601, et seq., 40 C.F.R. permitting waivers for clay soils, synthetic liner, waivers invoked under  761.75 50 feet to water table, and leachate collection the capped PCB waste requirements upon a finding by the Regional  Administrator.  Toxic Substances Control Act (TSCA), Establishes treatment and disposal standards for Treatment and disposa

 (40 C.F.R. 760.60) PCB wastes generated as part of redevelopment, PCB generated wastes  monitoring or O&M activities.  Clean Water Act - Sec. 304 Relevant and AWQC are developed under the Clean Water Act AWQC are used to mo Federal Ambient Water Quality Criteria Appropriate (CWA) as guidelines from which states develop in Meadow Brook to a

 33 USC 1314; 40 CFR 122.44 water quality standards. of the remedy.  Guide on Remedial Actions at Superfund To be Sets forth guidelines for implementing remedial Ongoing monitoring an

 Sites with PCB Contamination (OSWER considered actions for PCBs be conducted consisten

 Directive 9355.4-01, August 1990) State Regulatory Massachusetts Groundwater Protection Relevant and These regulations establish the criteria for Groundwater has been Requirements Regulations Appropriate classifying ground water and for establishing designated for uses oth

 314 CMR 6.00 monitoring standards. water supply. The regu will be used for monito
AUTHORITY REQUIREMENT STATUS REQUIREMENT SYNOPSIS ACTION TAKEN TO 

ARARs

B-4 

 Massachusetts Ambient Air Quality Applicable These regulations specify emissions standards for All redevelopment, mo Standards particulates and lead. will be conducted in a  generation of dust or o Massachusetts Air Pollution Control Applicable Regulations specific to control of odor and Any odors and fugitive 

 Regulations requirements for handling asbestos wastes and redevelopment, and mo 310 C.M.R. 7.00 fugitive dust emissions. under these standards.  Massachusetts Hazardous Waste Regulations Applicable Regulations governing the generation, treatment, These regulations will 

 310 C.M.R. 30.00 storage, and disposal of hazardous waste. O&M, monitoring, and  Potions of these regula on-site PCBs are not ap adequately regulated u

 Massachusetts Hazardous Waste Regulations Applicable Requirements for Toxic Characteristic Leaching Wastes generated for o

 310 C.M.R. 30.125(b) Procedure (TCLP). O&M, monitoring, and 

will be characterized athese standards. 

 Massachusetts Hazardous Waste Regulations Applicable Requirements for any generator of a waste to Wastes generated for o

 310 C.M.R. 30.302 determine if the waste is hazardous. O&M, monitoring, and 

will be characterized a

these standards. 
Norwood PCBs Superfund Site 

Five-Year Review Report December 2004 

C -1

APPENDIX C 

INTERVIEW NOTES 
INTERVIEW DOCUMENTATION FORM

The following is a list of individual interviewed for this five-year review. See the attached 

contact record(s) for a detailed summary of the interviews. 

Bill Eliot

Name 

Temp. Manager

Title/Position 

Lappens

Organization 

6/22/04

Date 

 

John Marcelonis

Name 

Sales

Title/Position 

Direct Tire

Organization 

6/22/04

Date 

 

Michelle Coffin

Name 

Curriculum 

Coordinator

Title/Position 

Neponset Valley 

Child Care

Organization 

6/22/04

Date 

 

Scott Webber

Name 

Manager

Title/Position 

Lappens

Organization 

6/30/04

Date 

 

Steve Costello

Name 

Norwood Town 

Planner

Title/Position 

Town of Norwood

Organization 

8/5/04

Date 

 

Dan Keefe

Name 

Project Manager

Title/Position 

DEP

Organization 

8/12/04

Date 

 

Jay Neparstak

Name 

Former Project 

Manager

Title/Position 

DEP

Organization 

8/12/04

Date 

 

Joe Laham

Name 

Site Owner

Title/Position Organization 

8/18/04

Date 

 

Chris Turek

Name 

Title/Position 

US Army Corps of

Enigneers

Organization 

9/12/04

Date 
INTERVIEW RECORD

Site Name: Norwood PCBs EPA ID No.: MAD980670566

Subject: 5 Year Review Time: 12:45 Date: 6/22/04

Type: _ Telephone Ξ Visit _ Other 

Location of Visit:

_ Incoming _ Outgoing 

Contact Made By:

Name: Pernilla Lindblom Title: Environmental Scientist Organization: Shaw E & I

Individual Contacted:

Name: Bill Eliot Title: Temp. Manager Organization: Lappens

Telephone No: 

Fax No: 

E-Mail Address:

Street Address: 961 Providence Hwy 

City, State, Zip: Norwood, MA

Summary Of Conversation

Bill Eliot is just filling in for the Project Manager (Scott Webber) while he is on vacation. 

Scott Webber will be back on Monday 6/28/04 and can be reached at 781-440-9992. 

Bill Elliot Was not aware of any problems with the Norwood PCBs site and had no concerns. 

 

 Page 1 of 1
INTERVIEW RECORD

Site Name: Norwood PCBs EPA ID No.: MAD980670566

Subject: 5 Year Review Time: 13:00 Date: 6/22/04

Type: _ Telephone Ξ Visit _ Other 

Location of Visit:

_ Incoming _ Outgoing 

Contact Made By:

Name: Pernilla Lindblom Title: Environmental Scientist Organization: Shaw E & I

Individual Contacted:

Name: John Marcelonis Title: Sales Organization: Direct Tire

Telephone No: 

Fax No: 

E-Mail Address:

Street Address: 981 Providence Turnpike 

City, State, Zip: Norwood, MA 02062

Summary Of Conversation

John was aware of the site and knew that there was remediation going on. He knew that digging was not allowed 

on the Norwood PCBs site. He did not have any questions or concerns. 

 

 Page 1 of 1
INTERVIEW RECORD

Site Name: Norwood PCBs EPA ID No.: MAD980670566

Subject: 5 Year Review Time: 13:15 Date: 6/22/04

Type: _ Telephone Ξ Visit _ Other 

Location of Visit:

_ Incoming _ Outgoing 

Contact Made By:

Name: Pernilla Lindblom Title: Environmental Scientist Organization: Shaw E & I

Individual Contacted:

Name: Michelle Coffin Title: Curriculum Coordinator Organization: Neponset Valley 

Child Care 

Telephone No: 781-769-7720 

Fax No: 

E-Mail Address:

Street Address: 110 Kerry Place 

City, State, Zip: Norwood, MA

Summary Of Conversation

The manager was not available at the time of the visit. Michelle was aware of the site and of remediation work 

there. She remembers a previous visit by someone concerning the site where they dropped off flyers about the 

proposed new development. She did not know of any problems and said that the site seemed secure. 

 

 Page 1 of 1
INTERVIEW RECORD

Site Name: Norwood PCBs EPA ID No.: MAD980670566

Subject: 5 Year Review Time: 12:45 Date: 6/22/04

Type: Ξ Telephone _ Visit _ Other 

Location of Visit:

_ Incoming Ξ Outgoing 

Contact Made By:

Name: Pernilla Lindblom Title: Environmental Scientist Organization: Shaw E & I

Individual Contacted:

Name: Scott Webber Title: Manager Organization: Lappens

Telephone No: 781-440-9992 

Fax No: 

E-Mail Address:

Street Address: 961 Providence Hwy 

City, State, Zip: Norwood, MA

Summary Of Conversation

Scott was aware of ongoing sampling on the Norwood PCBs site. He was not aware of any problems on the site 

and had no concerns regarding the Site. 

 He had received a pamphlet regarding the possible development of a Lowes at the site, but was under the 

impression that it was not going to happen. 

He does not feel well informed. He does not recall receiving any information (positive or negative) regarding the 

site in the 5 years he has been working at Lappens. 

He had a question regarding a dumpster which is stored on the Norwood PCBs property behind his, which gets 

picked up and dropped off on a regular basis. He was wondering if someone rents this part of the property for 

this. He did not have a concern regarding this but was just curious. He was informed to contact the EPA or DEP 

contacts if a concern came up regarding this issue. 

 

 Page 1 of 1
INTERVIEW RECORD

Site Name: Norwood PCBs EPA ID No.: MAD980670566

Subject: 5 Year Review Time: 16:45 Date: 8/5/04

Type: Ξ Telephone _ Visit _ Other 

Location of Visit:

_ Incoming X Outgoing 

Contact Made By:

Name: Pernilla Lindblom Title: Environmental Scientist Organization: Shaw E & I

Individual Contacted:

Name: Steve Costello Title: Norwood Town Planner Organization: Town of Norwood

Telephone No: 781-762-1240 

Fax No: 

E-Mail Address:

Street Address: 

City, State, Zip:

Summary Of Conversation

6/30/04 10:15 – Steve is on vacation until 7/6/04. I left a message that I will be calling back. 

8/5/04 4:45 

Steve was not aware of any vandalism, trespassing, or emergency response issues at the Norwood PCBs Site. 

He believes that the public would not have a problem with redevelopment as long as the cap was not disturbed. 

For example, the current use of the site as a car lot would be very acceptable. 

Steve was worried about the fact that Lowes was not prepared for questions from the public. The Public does get 

involved with this site. The possible developers need to be prepared for questions regarding the environmental 

issues of redevelopment. 

The only real issue he sees with the Site is that the developers need to work with the EPA as well as the Town in 

coming up with their plans for the site. He hopes that the next possible developer will attempt to work with the 

EPA first, and then involve the planning board. 

 

 Page 1 of 1
INTERVIEW RECORD

Site Name: Norwood PCBs EPA ID No.: MAD980670566

Subject: 5 Year Review Time: 13:30 Date: 6/12/04

Type: Ξ Telephone _ Visit _ Other 

Location of Visit:

_ Incoming X Outgoing 

Contact Made By:

Name: Pernilla Lindblom Title: Environmental Scientist Organization: Shaw E & I

Individual Contacted:

Name: Dan Keefe & Jay 

Neparstak

Title: current and former PM Organization: Department of 

Environmental Protection

Telephone No: 617-292-5940 

Fax No: 

E-Mail Address: Daniel.keefe@state.ma

Street Address: 

City, State, Zip:

Summary Of Conversation

Dan Keefe and Jay Neparstak both believe the biggest issues at the site are that the remediation is not complete 

and an acceptable O&M plan has not been submitted. 

DEP is responsible for taking over the O&M on fund-lead projects. Therefore the DEP would be responsible for 

O&M on the groundwater phase although none is expected since longterm groundwater treatment is not expected. 

Groundwater treatment was stopped when most of the constituents had met groundwater cleanup goals and analyte 

concentrations were stable. TCB and PCB had not reached cleanup goals. RBALs were calculated to prove there 

would be no surface water impact at the current concentrations. The RBALs proved to be protective for TCB in 

groundwater but not PCB. A risk analysis was conducted and the report came out the end of July 04. This risk 

analysis concluded that PCBs were not a risk to Meadow Brook. This report is being discussed at a meeting on 

August 23rd. 

An acceptable O&M plan for the rest of the site (excluding groundwater) has not been submitted yet. 

Quarterly groundwater sampling was stopped partly due to contractual issues and partly because groundwater 

concentrations were stable. 

The settling defendants still have to do sampling of some of the wells as part of their Environmental Monitoring 

Program they are supposed to have instituted. 

Other loose ends: Institutional Controls have not been filed by the owner and the settling defendants. 

They were not aware of any changes in regulations which may effect the protectiveness or the ARARs at the Site 

except for the change in groundwater classification form GW-1. Some groundwater clean up goals are being 

revised, however this should not impact the site since it is not GW-1. 

 Page 1 of 1
INTERVIEW RECORD

Site Name: Norwood PCBs EPA ID No.: MAD980670566

Subject: 5 Year Review Time: 10:00 Date: 6/18/04

Type: Ξ Telephone _ Visit _ Other 

Location of Visit:

X Incoming _ Outgoing 

Contact Made By:

Name: Pernilla Lindblom Title: Environmental Scientist Organization: Shaw E & I

Individual Contacted:

Name: Joe Laham Title: Site Owner Organization: 

Telephone No: 508-888-8200 X 223 

Fax No: 

E-Mail Address:

Street Address: 

City, State, Zip:

Summary Of Conversation

8/17/04 Pernilla of Shaw left a message with Joe Laham 

8/18/04 Joe Laham returned the call. 

Joe Laham had several issues with the Site: 

He wants to know when is the treatment plant building is being demolished? He was hoping that the building was 

being removed. 

He believes that the EPA needs to be more proactive and cooperative in the development of the site. The Site was 

denied development by the Town due to traffic issues, size of building, and environmental issues. Joe believes 

that the EPA should have been more proactive in ensuring the town and the public that there are no longer any 

environmental issues at the Site. During public hearings regarding the development of the Site, environmental 

issues were brought up which concerned the public. He believes that the EPA should have been proactive in 

ensuring the public that there were no environmental issues with the development plan for the Site. 

He did not know anything about whether or not Institutional Controls had been filed or were being filed. 

 

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INTERVIEW RECORD

Site Name: Norwood PCBs EPA ID No.: MAD980670566

Subject: 5 Year Review Time: 9:00 Date: 9/12/04

Type: Ξ Telephone _ Visit _ Other 

Location of Visit:

_ Incoming Ξ Outgoing 

Contact Made By:

Name: Eileen London Title: Environmental Scientist Organization: Shaw E & I

Individual Contacted:

Name: Chris Turek Title: Construction Manager Organization: US Army Corp of 

Engineers

Telephone No: 978/318-8234 

Fax No: 

E-Mail Address:

Street Address: 

City, State, Zip: 

Summary Of Conversation

Chris believes that the construction went well and the plant operated well with just a few minor bugs, which were 

worked out. Operators were only required to check on it 3 days a week since the system was fully automated. 

Construction is currently complete. No problems were encountered which impacted construction progress or 

implementability. 

He speculated that if more monitoring wells had been installed or if they had been located differently, results may 

have tracked the plume more precisely, more definitive information may have been obtained, which would have 

made the treatment decisions more definitive. 

 

 Page 1 of 1
Norwood PCBs Superfund Site 

Five-Year Review Report December 2004 

D-1

APPENDIX D 

PHOTOS DOCUMENTING SITE CONDITIONS 
Norwood PCBs Superfund Site 

Five-Year Review Report December 2004 

D-2

Photograph 1 

Exterior of the Groundwater Treatment Facility from the cover area located west of the building.

Photograph 2 

Interior of the Groundwater Treatment Facility. 
Norwood PCBs Superfund Site 

Five-Year Review Report December 2004 

D-3

Photograph 3 

Treatment system discharge pipe. 

Photograph 4 

Detention Basin looking southeast toward Route 1. 
Norwood PCBs Superfund Site 

Five-Year Review Report December 2004 

D-4

Photograph 5 

Detention Basin along north cover areas facing northwest. 

Photograph 6 

Gravel spilled into the Detention Basin. 
Norwood PCBs Superfund Site 

Five-Year Review Report December 2004 

D-5

Photograph 7 

Vegetation growing in the spillway of the detention basin. 

Photograph 8 

Exposed geotextile and displaced riprap on side slopes of detention basin. 
Norwood PCBs Superfund Site 

Five-Year Review Report December 2004 

D-6

Photograph 9 

Repaired riprap side slopes (second site visit). 

Photograph 10 

Vegetation growing in North cover area. 
Norwood PCBs Superfund Site 

Five-Year Review Report December 2004 

D-7

Photograph 11 

Vegetation growing in South cover area. 

Photograph 12 

Crack in the paved cap area. 
Norwood PCBs Superfund Site 

Five-Year Review Report December 2004 

D-8

Photograph 13 

Gravel spilled in the cap area. 

Photograph 14 

Gravel removed from the paved cap area (second visit) gravel pit, to the right of the cap area.
Norwood PCBs Superfund Site 

Five-Year Review Report December 2004 

D-9

Photograph 15 

Damaged Cape Cod berms. 

Photograph 16 

Repaired Cape cod berms noted at the (second site visit). 
Norwood PCBs Superfund Site 

Five-Year Review Report December 2004 

D-10

Photograph 17 

Cape Cod berms still requiring repair (second site visit). 

Photograph 18 

Unlocked monitoring well. 
Norwood PCBs Superfund Site 

Five-Year Review Report December 2004 

D-11

Photograph 19 

Meadow Brook adjacent to the site near discharge treatment system. 

Photograph 20 

Meadow Brook culvert under Route 1. 
Norwood PCBs Superfund Site 

Five-Year Review Report December 2004 

D-12

Photograph 21 

Meadow Brook U-Channel east of Route 1. 

Photograph 22 

Meadow Brook east of Route 1. 
Norwood PCBs Superfund Site 

Five-Year Review Report December 2004 

E-1

APPENDIX E 

FIVE-YEAR REVIEW SITE INSPECTION CHECKLIST 
OSWER No. 9355.7-03B-P

E-2

Please note that “O&M” is referred to throughout this checklist. At sites where LongTerm Response Actions are in progress, O&M activities may be referred to as “system 

operations” since these sites are not considered to be in the O&M phase while being 

remediated under the Superfund program. 

Five-Year Review Site Inspection Checklist (Template)

I. SITE INFORMATION

Site name: Norwood PCBs Date of inspection: 5/12/04 (& 9/7/04 return visit)

Location and Region: Near Rt 1 & Dean St, 

 Norwood, EPA Region 1

EPA ID: MAD980670566

Agency, office, or company leading the five-year 

review: EPA Region 1, Shaw Environmental

Weather/temperature: Partly cloudy, ~70o

Remedy Includes: (Check all that apply) 

 Landfill cover/containment Monitored natural attenuation 

 Access controls Groundwater containment 

 Institutional controls Vertical barrier walls 

 Groundwater pump and treatment

 Surface water collection and treatment 

 Other_groundwater treatment system is available, however is not currently in use (“temporarily shut 

down”)__________________________________________________________________________ 

Attachments: Inspection team roster attached Site map attached 

II. INTERVIEWS (Check all that apply) 

1. O&M site manager _____N/A_______________________ ______________________ ____________ 

Name Title Date 

 Interviewed at site at office by phone Phone no. ______________ 

 Problems, suggestions; Report attached ________________________________________________ 

 __________________________________________________________________________________ 

2. O&M staff _____N/A_______________________ ______________________ ____________ 

Name Title Date 

 Interviewed at site at office by phone Phone no. ______________ 

 Problems, suggestions; Report attached _______________________________________________ 

 __________________________________________________________________________________ 
OSWER No. 9355.7-03B-P

E-3

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.) See Appendix C for interview notes.

Agency Environmental Protection Agency

Contact Sharon Hayes __________________ _5/12/04 (on site)

Name Title Date 

Agency Environmental Protection Agency

Contact Bob Cianciarulo Massachusetts Superfund Section Chief 5/12/04 (on site)

 Name Title Date 

Agency Massachusetts Department of Environmental Protection

Contact Dan Keefe Project Manager 5/12/04 (on site)

Name Title Date 

Also interview on the phone 9/12/04 along with Jay Neparstak, the former Project Manager at DEP. 

Agency Army Corps of Engineers

Contact Chris Turek __________________ 5/12/04 (on site)

 Name Title Date 

Also interviewed over the phone on 9/12/04

4. Other interviews See Appendix C for interview notes. 

Joe Laham – Site Owner 

Bill Eliot & Scott Webber – Lappens 

John Marcelonis – Direct Tire 

Michelle Coffin – Neponset Valley Child Care 

Steve Costello – Town of Norwood 
OSWER No. 9355.7-03B-P

E-4

III. ON-SITE DOCUMENTS & RECORDS VERIFIED (Check all that apply) 

1. O&M Documents

 O&M manual Readily available Up to date N/A 

 As-built drawings Readily available Up to date N/A 

 Maintenance logs Readily available Up to date N/A 

Remarks__________________________________________________________________________ 

____________________________________________________________________

2. Site-Specific Health and Safety Plan Readily available Up to date N/A 

 Contingency plan/emergency response plan Readily available Up to date N/A 

Remarks This Plan is for O&M activities.

3. O&M and OSHA Training Records Readily available Up to date N/A

Remarks__________________________________________________________________________ 

_________________________________________________________________________________ 

4. Permits and Service Agreements

 Air discharge permit Readily available Up to date N/A

 Effluent discharge Readily available Up to date N/A

 Waste disposal, POTW Readily available Up to date N/A

 Other permits_____________________ Readily available Up to date N/A

Remarks__________________________________________________________________________ 

_________________________________________________________________________________ 

5. Gas Generation Records Readily available Up to date N/A

Remarks__________________________________________________________________________ 

_________________________________________________________________________________ 

6. Settlement Monument Records Readily available Up to date N/A

Remarks__________________________________________________________________________ 

_________________________________________________________________________________ 

7. Groundwater Monitoring Records Readily available Up to date N/A 

Remarks These records are kept in USACOE offices.

8. Leachate Extraction Records Readily available Up to date N/A 

Remarks There are no leachate extraction records, however, there are groundwater extraction records 

and they are kept in the USACOE offices.

9. Discharge Compliance Records 

 Air Readily available Up to date N/A 

 Water (effluent) Readily available Up to date N/A 

Remarks These records are kept in USACOE offices.

10. Daily Access/Security Logs Readily available Up to date N/A

Remarks__________________________________________________________________________ 

_________________________________________________________________________________ 
OSWER No. 9355.7-03B-P

E-5

IV. O&M COSTS – O&M 

1. O&M Organization 

 State in-house Contractor for State 

 PRP in-house Contractor for PRP 

 Federal Facility in-house Contractor for Federal Facility 

 Other__________________________________________________________________________ 

_________________________________________________________________________________ 

2. O&M Cost Records 

 Readily available Up to date 

 Funding mechanism/agreement in place 

Original O&M cost estimate____________________ Breakdown attached 

Total annual cost by year for review period if available 

From__________ To__________ __________________ Breakdown attached 

Date Date Total cost 

From__________ To__________ __________________ Breakdown attached 

Date Date Total cost 

From__________ To__________ __________________ Breakdown attached 

Date Date Total cost 

From__________ To__________ __________________ Breakdown attached 

Date Date Total cost 

From__________ To__________ __________________ Breakdown attached 

Date Date Total cost 

3. Unanticipated or Unusually High O&M Costs During Review Period 

Describe costs and reasons: __________________________________________________________ 

_________________________________________________________________________________ 

_________________________________________________________________________________ 

_________________________________________________________________________________ 

_________________________________________________________________________________ 

_________________________________________________________________________________ 

V. ACCESS AND INSTITUTIONAL CONTROLS Applicable N/A 

A. Fencing

1. Fencing damaged Location shown on site map Gates secured N/A

Remarks The site is not fenced

B. Other Access Restrictions 

1. Signs and other security measures Location shown on site map N/A 

Remarks Car dealers, which use the property for storage, block access to the lot overnight and have 

security during the day. Treatment building has a security system installed and remains closed and 

locked when unattended.
OSWER No. 9355.7-03B-P

E-6

C. Institutional Controls (ICs)

1. Implementation and enforcement 

Site conditions imply ICs not properly implemented Yes No N/A 

Site conditions imply ICs not being fully enforced Yes No N/A 

Type of monitoring (e.g., self-reporting, drive by) _________________________________________ 

Frequency ________________________________________________________________________ 

Responsible party/agency ____________________________________________________________ 

Contact ____________________________ __________________ ________ ____________ 

Name Title Date Phone no. 

Reporting is up-to-date Yes No N/A 

Reports are verified by the lead agency Yes No N/A 

Specific requirements in deed or decision documents have been met Yes No N/A 

Violations have been reported Yes No N/A 

Other problems or suggestions: Report attached 

Institutional controls include use restrictions, no groundwater withdrawal, no interference with response 

actions, disruption of caps, or excavation of contaminated material. 

2. Adequacy ICs are adequate ICs are inadequate N/A 

Remarks_New ICs need to be published. 

_________________________________________________________________________________ 

_________________________________________________________________________________ 

D. General

1. Vandalism/trespassing Location shown on site map No vandalism evident

Remarks__________________________________________________________________________ 

_________________________________________________________________________________ 

2. Land use changes on site N/A 

Remarks A portion of the capped area is leased out for the storage of new cars by auto dealers. Cape Cod 

berms have been installed to keep possible discharge from vehicles in areas with storm drains installed. 

3. Land use changes off site N/A 

Remarks 

VI. GENERAL SITE CONDITIONS

A. Roads Applicable N/A 

1. Roads damaged Location shown on site map Roads adequate N/A 

Remarks__________________________________________________________________________ 

_________________________________________________________________________________ 
OSWER No. 9355.7-03B-P

E-7

B. Other Site Conditions

Remarks gravel from plowing has been plowed into the drainage ditch north of the site and onto the 

northwest corner of the landfill cap. The gravel is likely due to plowing. The gravel had been removed 

form the capped area prior to the second site visit. The current property occupant was required to install 

Cape Cod berms on the north and west side of the portion of the landfill cap that is used to park new 

cars. In several areas, these berms have been damaged or removed (likely due to plowing) and need to 

be replaced or repaired. 

VII. LANDFILL COVERS Applicable N/A 

A. Landfill Surface

1. Settlement (Low spots) Location shown on site map Settlement not evident

Areal extent______________ Depth____________ 

Remarks____________________________________________________________ 

__________________________________________________________________ 

2. Cracks Location shown on site map Cracking not evident 

Lengths____________ Widths___________ Depths__________ 

Remarks Minor cracking noted in some spots at seams in the pavement.

3. Erosion Location shown on site map Erosion not evident 

Areal extent______________ Depth____________ 

Remarks Erosion of rip rap into the drainage ditch has occurred in three locations along the northern 

edge of the north cover and cap area. Rip rap has eroded into the ditch and geotextile fabric is exposed. 

This issue had been fixed prior to the second visit but appears it may be a future problem if not checked.

4. Holes Location shown on site map Holes not evident

Areal extent______________ Depth____________ 

Remarks__________________________________________________________________________ 

_________________________________________________________________________________ 

5. Vegetative Cover Grass Cover properly established No signs of stress 

 Trees/Shrubs (indicate size and locations on a diagram) 

Remarks No vegetative cover used on the landfill areas However grass is growing in the gravel cover 

area which may be a future issue.

6. Alternative Cover (armored rock, concrete, etc.) N/A

Remarks__Most of the cap area is paved. Pavement is generally in good condition, Some minor cracking 

was noted along the seams.

__________________________________________________________________________________ 

7. Bulges Location shown on site map Bulges not evident

Areal extent______________ Height____________ 

Remarks__________________________________________________________________________ 

_________________________________________________________________________________ 

8. Wet Areas/Water Damage Wet areas/water damage not evident

 Wet areas Location shown on site map Areal extent______________ 

 Ponding Location shown on site map Areal extent______________ 

 Seeps Location shown on site map Areal extent______________ 

 Soft subgrade Location shown on site map Areal extent______________ 

Remarks__________________________________________________________________________ 

_________________________________________________________________________________ 
OSWER No. 9355.7-03B-P

E-8

9. Slope Instability Slides Location shown on site map No evidence of slope instability 

Areal extent______________ 

Remarks Three areas of rip rap slides were noted along the northern edge of the north cover area and the 

northern edge of the capped area. Rip rap has slid down into the site drainage ditch and geotextile fabric 

is exposed. This had been fixed at the second site visit, however appears it may be a future concern.

B. Benches Applicable N/A

(Horizontally constructed mounds 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 

channel.) 

1. Flows Bypass Bench Location shown on site map N/A or okay

Remarks__________________________________________________________________________ 

_________________________________________________________________________________ 

2. Bench Breached Location shown on site map N/A or okay

Remarks__________________________________________________________________________ 

_________________________________________________________________________________ 

3. Bench Overtopped Location shown on site map N/A or okay

Remarks__________________________________________________________________________ 

_________________________________________________________________________________ 

C. Letdown Channels Applicable N/A

(Channel lined with erosion control mats, riprap, grout bags, or gabions that descend down the steep side 

slope of the cover and will allow the runoff water collected by the benches to move off of the landfill 

cover without creating erosion gullies.) 

1. Settlement Location shown on site map No evidence of settlement

Areal extent______________ Depth____________ 

Remarks__________________________________________________________________________ 

_________________________________________________________________________________ 

2. Material Degradation Location shown on site map No evidence of degradation

Material type_______________ Areal extent_____________ 

Remarks__________________________________________________________________________ 

_________________________________________________________________________________ 

3. Erosion Location shown on site map No evidence of erosion 

Areal extent______________ Depth____________ 

Remarks__________________________________________________________________________ 

_________________________________________________________________________________ 

4. Undercutting Location shown on site map No evidence of undercutting 

Areal extent______________ Depth____________ 

Remarks__________________________________________________________________________ 

_________________________________________________________________________________ 

5. Obstructions Type_____________________ No obstructions 

 Location shown on site map Areal extent______________ 

Size____________ 

Remarks__________________________________________________________________________ 

_________________________________________________________________________________ 
OSWER No. 9355.7-03B-P

E-9

6. Excessive Vegetative Growth Type____________________ 

 No evidence of excessive growth 

 Vegetation in channels does not obstruct flow 

 Location shown on site map Areal extent______________ 

Remarks__________________________________________________________________________ 

_________________________________________________________________________________ 

D. Cover Penetrations Applicable N/A 

1. Gas Vents Active Passive 

 Properly secured/locked Functioning Routinely sampled Good condition 

 Evidence of leakage at penetration Needs Maintenance 

 N/A

Remarks__________________________________________________________________________ 

_________________________________________________________________________________ 

2. Gas Monitoring Probes

 Properly secured/locked Functioning Routinely sampled Good condition 

 Evidence of leakage at penetration Needs Maintenance N/A

Remarks__________________________________________________________________________ 

_________________________________________________________________________________ 

3. Monitoring Wells (within surface area of landfill) 

 Properly secured/locked Functioning Routinely sampled Good condition

 Evidence of leakage at penetration Needs Maintenance N/A 

Remarks One groundwater monitoring well was noted to be missing a lock in the north cover area. 

4. Leachate Extraction Wells

 Properly secured/locked Functioning Routinely sampled Good condition 

 Evidence of leakage at penetration Needs Maintenance N/A

Remarks__________________________________________________________________________ 

_________________________________________________________________________________ 

5. Settlement Monuments Located Routinely surveyed N/A

Remarks__________________________________________________________________________ 

_________________________________________________________________________________ 

E. Gas Collection and Treatment Applicable N/A

1. Gas Treatment Facilities 

 Flaring Thermal destruction Collection for reuse 

 Good condition Needs Maintenance 

Remarks__________________________________________________________________________ 

_________________________________________________________________________________ 

2. Gas Collection Wells, Manifolds and Piping

 Good condition Needs Maintenance 

Remarks__________________________________________________________________________ 

_________________________________________________________________________________ 

3. Gas Monitoring Facilities (e.g., gas monitoring of adjacent homes or buildings) 

 Good condition Needs Maintenance N/A 

Remarks__________________________________________________________________________ 

_________________________________________________________________________________ 

F. Cover Drainage Layer Applicable N/A
OSWER No. 9355.7-03B-P

E-10

1. Outlet Pipes Inspected Functioning N/A 

Remarks__________________________________________________________________________ 

_________________________________________________________________________________ 

2. Outlet Rock Inspected Functioning N/A 

Remarks__________________________________________________________________________ 

_________________________________________________________________________________ 

G. Detention/Sedimentation Ponds Applicable N/A 

A detention ditch is located along the northern edge of the property (south of Meadowbrook) and is 

used for surface water drainage from the parking lot stormdrains located in the cap area.

1. Siltation Areal extent______________ Depth____________ N/A 

 Siltation not evident

Remarks__________________________________________________________________________ 

_________________________________________________________________________________ 

2. Erosion Areal extent______________ Depth____________ 

Erosion not evident 

Remarks Three areas of rip rap slides noted along the northern edge of the north cover area and the 

northern edge of the capped area. Riprap has slid down into the site drainage ditch and geofabric is 

exposed. This issue had been fixed prior to the second visit, however it appears this may be a future 

issue if not checked.

3. Outlet Works Functioning N/A

Remarks__________________________________________________________________________ 

_________________________________________________________________________________ 

4. Dam Functioning N/A

Remarks__________________________________________________________________________ 

_________________________________________________________________________________ 

5. Vegetative Growth Location shown on site map N/A 

Vegetation does not impede flow 

Areal extent______________ Type____________ 

Remarks There is no flow in the drainage ditch, however vegetative growth in the riprap spillway area is 

evident and may be problematic.

H. Retaining Walls Applicable N/A

1. Deformations Location shown on site map Deformation not evident 

Horizontal displacement____________ Vertical displacement_______________ 

Rotational displacement____________ 

Remarks__________________________________________________________________________ 

_________________________________________________________________________________ 

2. Degradation Location shown on site map Degradation not evident 

Remarks__________________________________________________________________________ 

_________________________________________________________________________________ 

I. Perimeter Ditches/Off-Site Discharge Applicable N/A 

Meadowbrook flows along the northern edge of the site and was part of the remediation project. When 

the groundwater treatment system is running it discharges to Meadowbrook.

1. Siltation Location shown on site map Siltation not evident

Areal extent______________ Depth____________ 

Remarks__________________________________________________________________________ 

_________________________________________________________________________________ 
OSWER No. 9355.7-03B-P

E-11

2. Vegetative Growth Location shown on site map N/A 

Vegetation does not impede flow

Areal extent______________ Type____________ 

Remarks__________________________________________________________________________ 

_________________________________________________________________________________ 

3. Erosion Location shown on site map Erosion not evident 

Areal extent______________ Depth____________ 

Remarks__________________________________________________________________________ 

_________________________________________________________________________________ 

4. Discharge Structure Functioning N/A 

Remarks There is a discharge pipe present from the groundwater treatment system, which is closed and 

not currently in use. It appeared to be in good condition.

VIII. VERTICAL BARRIER WALLS Applicable N/A

1. Settlement Location shown on site map Settlement not evident 

Areal extent______________ Depth____________ 

Remarks__________________________________________________________________________ 

_________________________________________________________________________________ 

2. Performance Monitoring Type of monitoring__________________________ 

 Performance not monitored 

Frequency_______________________________ Evidence of breaching 

Head differential__________________________ 

Remarks__________________________________________________________________________ 

_________________________________________________________________________________ 

IX. GROUNDWATER/SURFACE WATER REMEDIES Applicable N/A 

A. Groundwater Extraction Wells, Pumps, and Pipelines Applicable N/A 

1. Pumps, Wellhead Plumbing, and Electrical 

 Good condition All required wells properly operating Needs Maintenance N/A 

Remarks The groundwater treatment system is available but not currently in use. 

2. Extraction System Pipelines, Valves, Valve Boxes, and Other Appurtenances 

 Good condition Needs Maintenance 

Remarks__________________________________________________________________________ 

_________________________________________________________________________________ 

3. Spare Parts and Equipment 

 Readily available Good condition Requires upgrade Needs to be provided 

Remarks__________________________________________________________________________ 

_________________________________________________________________________________ 

B. Surface Water Collection Structures, Pumps, and Pipelines Applicable N/A

1. Collection Structures, Pumps, and Electrical 

Good condition Needs Maintenance 

Remarks__________________________________________________________________________ 

_________________________________________________________________________________ 

2. Surface Water Collection System Pipelines, Valves, Valve Boxes, and Other Appurtenances 

Good condition Needs Maintenance 

Remarks__________________________________________________________________________ 

_________________________________________________________________________________ 
OSWER No. 9355.7-03B-P

E-12

3. Spare Parts and Equipment 

Readily available Good condition Requires upgrade Needs to be provided 

Remarks__________________________________________________________________________ 

_________________________________________________________________________________ 

C. Treatment System Applicable N/A Available but not currently in use

1. Treatment Train (Check components that apply) 

 Metals removal Oil/water separation Bioremediation 

 Air stripping Carbon adsorbers 

 Filters_________________________________________________________________________ 

 Additive (e.g., chelation agent, flocculent)_____________________________________________ 

 Others_________________________________________________________________________ 

 Good condition Needs Maintenance 

 Sampling ports properly marked and functional 

 Sampling/maintenance log displayed and up to date 

 Equipment properly identified 

 Quantity of groundwater treated annually________________________ 

 Quantity of surface water treated annually________________________ 

Remarks__________________________________________________________________________ 

_________________________________________________________________________________ 

2. Electrical Enclosures and Panels (properly rated and functional) 

 N/A Good condition Needs Maintenance 

Remarks__________________________________________________________________________ 

_________________________________________________________________________________ 

3. Tanks, Vaults, Storage Vessels 

 N/A Good condition Proper secondary containment Needs Maintenance 

Remarks__________________________________________________________________________ 

_________________________________________________________________________________ 

4. Discharge Structure and Appurtenances

 N/A Good condition Needs Maintenance 

Remarks The pipe in to the discharge structure to Meadow brook has been shut off.

5. Treatment Building(s)

 N/A Good condition (esp. roof and doorways) Needs repair

 Chemicals and equipment properly stored 

Remarks Flashing on the roof of the building in the northwest corner is loose and needs repair.

6. Monitoring Wells (pump and treatment remedy) 

Properly secured/locked Functioning Routinely sampled Good condition 

All required wells located Needs Maintenance N/A 

Remarks One monitoring well was found without a lock in the north cover area.

D. Monitoring Data The last montoring data was collected in October 2000 (27th round). Up until this time, 

data was reported as required.

1. Monitoring Data 

 Is routinely submitted on time Is of acceptable quality 

2. Monitoring data suggests: 

 Groundwater plume is effectively contained Contaminant concentrations are declining 
OSWER No. 9355.7-03B-P

E-13

D. Monitored Natural Attenuation

1. Monitoring Wells (natural attenuation remedy) 

Properly secured/locked Functioning Routinely sampled Good condition 

All required wells located Needs Maintenance N/A

Remarks__________________________________________________________________________ 

_________________________________________________________________________________ 

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. 

XI. OVERALL OBSERVATIONS

A. 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 of the remedy is to protect human health and the environment. Based upon the site 

inspection, monitoring results, and observations during this review, the remedy appears to be functioning 

as intended. Although a definite, protectiveness determination cannot be made at this time until new 

clean up goals have been published and groundwater sampling has been conducted to verify that the new 

clean up goals have been met. 

 B. 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 of the remedy. 

The site is not currently in an O& M Phase. An O&M Plan has been prepared for Meadow Brook. This 

is the responsibility of the Town of Norwood although they have not performed any O&M to date. An 

acceptable O& M Plan for the cap and cover has not been submitted yet. The groundwater treatment 

system has been temporarily shut down due to changes in groundwater standards. 
OSWER No. 9355.7-03B-P

E-14

C. 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 of the remedy may be 

compromised in the future. 

____________________________________________________________________

____________________________________________________________________ 

____________________________________________________________________ 

____________________________________________________________________ 

____________________________________________________________________ 

____________________________________________________________________ 

____________________________________________________________________ 

____________________________________________________________________ 

____________________________________________________________________

D. Opportunities for Optimization 

Describe possible opportunities for optimization in monitoring tasks or the operation of the remedy. 

____________________________________________________________________ 

____________________________________________________________________ 

____________________________________________________________________ 

____________________________________________________________________ 

____________________________________________________________________ 

____________________________________________________________________ 

____________________________________________________________________ 

____________________________________________________________________ 

____________________________________________________________________