Final Closeout Report (Fcor)

Stipcrfund Records Cenler SlTIi: ShpaCK BREAK:

THE SHPACK LANDFILL SUPERFUND SITE

NOVEMBER 2016

U.S. ENVIRONMENTAL PROTECTION AGENCY NEW ENGLAND - REGION 1 5 POST OFFICE SQUARE, SUITE 100 BOSTON, MA 02109-3912

SEMS DocID 595021 I. INTRODUCTION This Final Close Out Report (FCOR) documents that the United States Environmental Protection Agency (EPA) has completed all response actions for the Shpack Landfill Superfund Site (Site), located on Union Rd. and Peckham Streets in Norton and Attleboro, Massachusetts. A Superfund Preliminary Close out Report (PCOR) was completed and signed in September 2014 for the Site. The PCOR documented that the soil clean up levels for the Source Control operable unit were achieved; that the remedial actions were completed and that all physical construction of the remedies were also complete. The PCOR did not cover the Institutional Controls as those measures were not yet implemented. The Institutional Controls consisting of Notices of Activity and Use Limitations for three property owners have now been completed and were recorded at the Bristol North Registry of Deeds on November 8th 2016. This FCOR has been completed in accordance with EPA guidance, Close Out Procedures for National Priorities List Sites, OSWER Directive 9320.2-22, dated May 2011.

II. SUMMARY OF SITE CONDITIONS

A. BACKGROUND SUMMARY & SITE DESCRIPTION The Site covers approximately 9.4 acres, with approximately 6 acres located within the Town of Norton, Massachusetts, and the remainder located in the City of Attleboro, Massachusetts (Figure 1). The Site was operated as a landfill from 1946 until the early 1970s, receiving domestic and industrial waste, including inorganic and organic chemicals and low-level radioactive waste. The Site is bordered to the north and northwest by Peckham Street (Attleboro) and Union Road (Norton); to the west and southwest by an approximately 55-acre municipal and industrial landfill owned by Attleboro Landfill Inc. (ALI); and on the southeast, east, and northeast by the Chartley Swamp, a vegetated wetland area. An electrical utility easement with multiple overhead transmission lines traverses the Site. The area of the Site where wastes were deposited is enclosed by a chain-link fence. Figure 2 provides a Site layout. Approximately 40,000 people live within a 3-mile radius of the Site. Municipal water supplies do not extend to the area around the Site. Residents in the area use private drinking water wells, most of which withdraw water from the bedrock aquifer. At the time of the ROD, the nearest residential well was located approximately 150 feet from the Site1 and there were 27 private wells located within 1-mile of the Site serving 103 people. The municipal water supply well fields for Norton and Attleboro are situated in the shallow aquifer. The nearest well fields are located approximately 3 miles east and

1 This well has now been decommissioned and the house in this location has been razed. The property is now zoned conservation land by the town of Norton.

Page 1 of 14 2.3 miles west of the study area in Norton and Attleboro, respectively. Groundwater monitoring has confirmed human ingestion of site-related groundwater contamination is not occurring. In 1978, the Nuclear Regulatory Commission (NRC) conducted radiological surveys at the Site after being contacted by a concerned citizen who had detected elevated radiation levels in the area. The NRC's investigation identified radioactive materials, primarily radium and uranium, within the landfill. In 1980, the Site was added to the Department of Energy's (DOE) Formerly Utilized Sites Remedial Action Program (FUSRAP), which dealt with the legacy of the nation's early atomic energy programs. In 1998, FUSRAP responsibility was transferred from DOE to the United States Army Corps of Engineers (USACE). In 1982 and 1984, DOE conducted additional studies and identified chemical contamination (volatile organic compounds [VOCs] and metals) in groundwater at the Site. In 1984, EPA evaluated the Site to determine if it should be listed on the National Priorities List (NPL). The Site was proposed to the NPL on October 15, 1984 (49 FR 40320). On June 14,1986 (51 FR 21054), the Site was added to the NPL.

B. SUMMARY OF THE SELECTED REMEDIES & REMEDIAL ACTION OBJECTIVES In September 2004, EPA signed a ROD identifying the selected remedial action for the Site. The ROD encompasses two response actions: one managed by the USACE under FUSRAP and the other managed by EPA under CERCLA. Special legislation was passed in 2002 (Section 8143, subsection (a), of the U.S. Department of Defense (DOD) Appropriations Act) that authorized USACE to conduct the cleanup of the radiological contamination at the Site. EPA is responsible for remediation of the non-radiological contamination at the Site. A group of potentially responsible parties, referred to herein as the Performing Defendants, signed a Consent Decree with EPA in June 2008 under which they agreed to perform the Site-wide cleanup of non-radiological contaminants. The ROD identified the following remedial action objectives (RAOs):

Source Control:

Soil

• Prevent ingestion/direct contact with soil having non-carcinogens in excess of a Hazard Index (HI) of 1 or with soil having carcinogens posing excess cancer risk above 10*4 to 10"6 and meet Applicable or Relevant and Appropriate Requirements (ARARs); • Prevent inhalation of carcinogens posing excess cancer risk levels above 10"4 to 10"6 or a HI of 1.0 and meet ARARs; and • Prevent exposure to contaminants in soil that present an unacceptable risk to the environment.

Sediment

Page 2 of 14 • Prevent exposure to sediment having carcinogens posing excess cancer risk above 10"4 to 10"6 or a HI of 1.0; and • Prevent exposure to contaminants in sediment that present an unacceptable risk to the environment.

Surface Water

• Prevent migration of contamination from site to surface water to reduce, to the extent practicable, the contribution of contamination from the site to surface waters of contamination that presents an unacceptable risk to human health and the environment.

Management of Migration:

Prevent ingestion of groundwater having carcinogens in excess of MCLs, non zero MCLGs, and a total excess cancer risk for all contaminants in groundwater greater than KT4 to 10"6;

Prevent ingestion of groundwater having non-carcinogens in excess of MCLs or non-zero MCLGs or a HI of 1.0; and

Prevent exposure to contaminants in groundwater that present an unacceptable risk to the environment.

The primary components of the selected remedy chosen to achieve the RAOs are:

• Relocation of existing power line structures, as needed, to implement necessary soil removal and backfill actions; • Extension of the public water supply line and connecting two residences, located adjacent to the Site, to public water. The residences were identified as Union Road House 1 and Union Road House 2; Excavation and off-site disposal of soil and sediment with contaminant concentrations exceeding the cleanup levels specified in Tables L-l through L-3 of the ROD; • Placement of clean fill in excavated areas to grade and/or wetlands restoration/ replication, as appropriate; • Preparation and implementation of a surface water, sediment, and groundwater monitoring program; • Performance of 5-year reviews to monitor the effectiveness of the remedy; • Implementation of any institutional controls necessary to restrict future use of property and groundwater, and monitoring compliance with institutional controls; and • Development and implementation of a traffic control plan to manage the increased volume of truck traffic associated with transporting contaminated material off-site.

Page 3 of 14 The ROD addresses groundwater contamination at and near the Site by addressing the risk of exposure to contaminated groundwater by requiring installation of a public water line to the two homes adjacent to the Site served by private wells2 and by mandating institutional controls to restrict future use of the property and groundwater. This decision was based on the commitment by the Massachusetts Department of Environmental Protection (MassDEP) to no longer consider this portion of the aquifer as a current or future water supply under the Massachusetts Contingency Plan once the remedial action is implemented, the two private drinking water supply wells abandoned, and controls placed on the properties prohibiting the future use of groundwater. Consistent with EPA's 1996 Final Ground Water Use and Value Determination Guidance, and the Commonwealth of Massachusetts' Comprehensive State Groundwater Protection Program (CSGWPP), MassDEP has developed a "Use and Value Determination" of the groundwater relative to the Site. The purpose of the Use and Value Determination is to identify whether the aquifer at the Site should be considered of "High," "Medium," or "Low" use and value. In the development of its Determination, MassDEP applied the criteria for groundwater classification as promulgated in the Massachusetts Contingency Plan (MCP). The classification contained in the MCP considers criteria similar to those recommended in the Use and Value Guidance. Since the conditions above have been met, MassDEP revised its Groundwater Use and Value Determination to a low use and value, and EPA considers the groundwater not suitable as a drinking water source. (See Appendix A for the November 14, 2013 MassDEP Revised Use and Value Determination.) Extension of the public water supply, ICs and abandoning nearby residential wells prevents current and future exposure to groundwater contaminants.

Remedial Action Completion

Construction of the remedial action was implemented in two parts, with the FUSRAP remedial action to address the radiological contamination performed first, and the CERCLA remedial action to address non-radiological contamination following completion of the FUSRAP remedial action. The two remedial actions are described below.

FUSRAP Remedial Action

The FUSRAP Remedial Action was performed by USACE contractor, Conti Federal Services, Inc. (Conti), with management and oversight by USACE. FUSRAP wastes requiring excavation and disposal were all located within the Landfill Interior portion of the Site with the exception of the ALI Debris Area, the Tongue Area, and the Inner Rung (Figure 2). The FUSRAP remedial action was performed in two phases.

Phase 1 operations began at the Site in August 2005. Activities included mobilization of equipment, personnel, and temporary facilities; construction of site infrastructure; excavation of test pits; installation of earth shoring; management of groundwater; excavation and characterization of wastes; post-excavation confirmatory sampling; backfilling with clean sand; and packaging, off-site transportation, and disposal of Low

2 The houses have since been razed and the private wells decommissioned. Page 4 of 14 Level Radioactive Waste (LLRW). After excavation began, it was determined that the horizontal and vertical extent of radiological contamination was more extensive than estimated in the ROD. Phase 1 cleanup operations were suspended in July 2006 based on insufficient funding to cover the increased volume of waste.

Phase 2 operations began at the Site in June 2007 and resumed the activities originally initiated during Phase 1. FUSRAP cleanup operations were completed in October 2011. A total of 57,805 cubic yards of material was excavated, of which 50,908 cubic yards were transported off-site for disposal. The primary waste class generated during the FUSRAP remedial action was LLRW. All wastes shipped off-site were ultimately transported by rail to the Energy Solutions disposal facility in Clive, Utah, a facility licensed for disposal of LLRW and/or mixed wastes.

Management of groundwater was performed during Phase 1 and Phase 2 utilizing a treatment system of settling tanks, sand filtration vessels, and bag filters. With MassDEP concurrence, all extracted groundwater was sent through the treatment system for removal of entrained solids prior to on-site infiltration into site soils, upgradient of the extraction area.

On-site waste management and transport of radioactive waste was performed in accordance with applicable local, state, and federal regulations for handling, labeling, storage, and transport of radioactive wastes. Truck traffic was managed during remedial activities in accordance with the traffic control plan developed by USACE with input from local and state authorities.

Following completion of off-site disposal in September 2011, the USACE contractor generated a punch list, including items necessary for complete demobilization from the Site. Over the next month, USACE monitored punch list activities and upon completion, the USACE and its contractors demobilized from the Site in October 2011. The USACE completed the Remedial Action Completion Report—Radiological Contamination in May 2012 documenting all completed FUSRAP-related remedial action activities at the Site.

CERCLA Remedial Action

A Remedial Design/Remedial Action Consent Decree for the remainder of the Site cleanup was signed by 14 parties and was lodged in the U.S. District Court in Boston on December 8,2008, and entered on January 27, 2009. Under the terms of the consent decree, the defendants were required to perform the remainder of the site-wide cleanup of chemical wastes and other contaminants. The defendants signing the agreement include: the City of Attleboro, Mass.; Avnet Inc.; Bank of America N.A. (Trustee u/w of Lloyd G. Balfour); BASF Catalysts LLC (formerly known as Engelhard Corporation); Chevron Environmental Management Company (for itself and on behalf of Kewanee Industries Inc.); ConocoPhillips Co.; Handy & Harman; International Paper Co.; KIK Custom Products, Inc. (formerly known as CCL Custom Manufacturing Inc.); Town of Norton, Mass.; Swank Inc.; Teknor Apex Co.; Texas Instruments Inc.; and Waste Management of Massachusetts Inc. The CERCLA Remedial Action was performed by the Performing

Page 5 of 14 Defendants' contractor, Environmental Resource Management (ERM). EPA and MassDEP provided oversight and approval. EPA's contractor, Nobis Engineering, Inc. (Nobis), performed field oversight during remedial construction to ensure that work was performed in accordance with the approved design and Remedial Action Work Plan. CERCLA wastes requiring excavation and disposal were located within the Tongue Area, Inner Rung, and ALI Debris Area (ALIDA) portions of the Site (Figure 4). Prior to the start of the CERCLA remedial action, EPA and MassDEP concurred that, based on the results of FUSRAP confirmation sampling and the Performing Defendants' subsequent pre-design investigation, further excavation of non-radiological wastes from the landfill interior (with the exception of the ALIDA) was not required.

The CERCLA Remedial Action began at the Site in June 2013. Activities included mobilization of equipment, personnel, and temporary facilities; construction of site infrastructure; installation of earth shoring; management of groundwater; excavation and characterization of wastes; backfilling and grading; packaging, off-site transportation, and disposal of wastes; and planting, seeding, and otherwise restoring and/or replicating wetlands and uplands. Management of groundwater was performed utilizing a treatment system of settling tanks, sand filtration vessels, and bag filters. With MassDEP concurrence, all pumped groundwater was sent through settling tanks for sediment settlement prior to on-site infiltration into upgradient site soils.

Initial wetland and upland plantings and seeding were completed in November and December 2013. Routine monitoring and maintenance of die wetland area is scheduled to continue for seven years following completion of construction to ensure the success of the restored wetland. Inspections, maintenance, and any required plant replacement and re-seeding will occur during the first year. The Final Operation and Maintenance Plan includes monitoring criteria with specific wetland restoration and creation performance goals keyed to a designated scheduled.

CERCLA remedial construction was completed in December 2013. A total of 27,083 tons of waste material was transported off-site for disposal. The material included the following waste classifications: Special Nuclear Material (SNM) non-hazardous; hazardous waste (leachable cadmium); non-hazardous waste; asbestos in soil (AIS); and non-hazardous asbestos-containing building materials.

On-site waste management and transport of wastes was performed in accordance with applicable local, state, and federal regulations for handling, labeling, storage, and transport of wastes. Overall, approximately 79 percent of the wastes removed from the Site were transported by rail to the US Ecology disposal facility in Grand View, Idaho. The US Ecology Idaho facility is licensed to accept RCRA hazardous wastes, low level radioactive wastes, low activity radioactive wastes, PCB-contaminated materials, and asbestos-containing materials for disposal. Most of the remaining wastes (approximately 20 percent of the total) were classified as non-hazardous and were transported by truck to the Waste Management Turnkey Landfill in Rochester, New Hampshire (a facility licensed to accept non-hazardous waste, including CERCLA waste). The remaining wastes contained asbestos and were shipped to a construction debris landfill licensed to

Page 6 of 14 accept asbestos. Truck traffic was managed during remedial activities in accordance with the traffic control plan developed by USACE with input from local and state authorities.

The public water supply line extension was completed in October 2012, prior to on-site remedial construction activities. The Performing Defendants' contractor extended the City of Attleboro public water supply line approximately 2,600 feet along Peckham Street, to within 500 feet of the Site, to meet ROD and MassDEP requirements. Connections to Union Road Houses 1 and 2 were not made because both houses were previously razed and the two private water supply wells properly abandoned. On November 14,2013, due to the installation of the water line to within 500 feet of the Site, MassDEP revised its Groundwater Use and Value determination from "high" to "low" within the vicinity of the Site. The MassDEP Revised Use and Value Determination is included in Appendix A.

The final inspection was completed on September 17,2014. The final inspection confirmed that punch list items identified during the pre-final inspection of the Site on June 9, 2014 were remedied.

Operation and Maintenance of the Remedy is being conducted by the City of Attleboro in accordance with the approved O&M Plan for the Site. Institutional Controls listed below were implemented following completion of the Remedial Action.

C. INSTITUITONAL CONTROLS

Prior to completion of the Remedial Action, an interim set of Institutional Controls (ICs) in the form of Easements, Restrictions, and Non-interference Agreements (ERNA) consistent with the requirements of the Consent Decree (CD) and Statement of Work (SOW) were placed on four properties. The ICs also granted Site access for the Performing Defendants to complete the Remedial Action and associated activities.

Following completion of the Remedial Action, a Notice of Activity and Use Limitation (NAUL) was recorded in November 2016 for each of the properties, with the exception of the land situated in Norton, Massachusetts, northeast of the Site, on which the Union Road House 1 was located, one of the two houses which necessitated construction of the water line. The property itself is not contaminated therefore it will continue to have an ERNA recorded for the property, but not a NAUL. The house was razed in August 2012 and the well decommissioned in September 2012 by the Performing Defendants, and was not a contiguous property to the Site. The property is now owned by Union Road, LLC. The NAULs on the four parcels prohibit activities and uses of the Site that may present an unacceptable risk to human health as well as providing Site access to the Performing Defendants for associated monitoring and O&M activities.

The following four parcels, in their entirety or a portion thereof as indicated, are subject to the Institutional Controls:

The parcel of land situated in Attleboro, Massachusetts owned by Attleboro Landfill,

Page 7 of 14 Inc., which is shown on Figure 3. The Institutional Controls will affect the entire parcel.

The two parcels of land situated in Norton, Massachusetts owned by the Town of Norton, which are shown on Figure 3. The Institutional Controls will affect each of the two parcels in its entirety.

The parcel of the land situated in Norton, Massachusetts owned by the Estate of Harold L. Wetherell (the "Wetherell Parcel") as shown on Figure 3. The Institutional Controls will affect a portion of the Wetherell Parcel.

The four above-described parcels (or a portion thereof in the case of the Wetherell Parcel) are subject to the following requirements, which summarize the Institutional Controls to be established pursuant to the Consent Decree:

A. Activities and uses that are consistent with maintaining the Selected Remedy are:

(i) recreational use;

(ii) commercial use;

(iii) industrial use;

(iv) educational walking trails;

(v) routine maintenance and repair work, including excavation, provided such work is conducted entirely above the seasonal high water table or elevation 104.00 feet above MSL, whichever is the greater elevation; and

(vi) such other activities and uses not identified below as being activities and uses inconsistent with maintaining the Selected Remedy.

B. Activities and uses that are inconsistent with maintaining the Selected Remedy are:

(i) excavation of soil and/or sediment below the seasonal high water table or elevation 104.00 feet above MSL, whichever is the greater elevation, except when performed in strict compliance with plans/protocols, as submitted to and pre- approved by EPA and MassDEP.

(ii) extraction of groundwater for purposes other than groundwater monitoring, except when performed in strict compliance with plans/protocols, as submitted to and approved by EPA and MassDEP.

(iii) agricultural use or activity;

(iv) residential use or activity;

Page 8 of 14 (v) day care or, for children under eighteen (18) years of age, educational use or activity (except for educational walking trails);

(vi) hotel or motel use or activity;

(vii) construction of enclosed structures, except when performed in strict compliance with plans/protocols as submitted to and pre-approved by EPA and MassDEP; and

(viii) any activity or use which would interfere with, or would be reasonably likely to interfere with, the implementation, effectiveness, integrity, operation, or maintenance of the Selected Remedy, including, but not limited to, cap(s), cover(s) or other ground covering features of response actions conducted to implement the Selected Remedy; and systems and studies to monitor implementation of the Selected Remedy, to provide long-term environmental monitoring of on-site groundwater, soils and/or sediments, and to ensure that the remedial action is effective in the long-term and protective of human health and the environment.

C. Provision is also made for the property owner or any party holding an interest in the areas that are subject to the Institutional Controls, including parties with easement rights, to submit to EPA and MassDEP for their pre-approval plans or protocols for:

(i) excavating soils and/or sediment below the seasonal high water table or elevation 104.00 above MSL, which is the greater elevation;

(ii) extracting groundwater other than for purposes of groundwater monitoring; or

(iii) construction of an enclosed structure.

III. MONITORING RESULTS

A. FUSRAP Remedial Action

In accordance with the requirements of the Multi-Agency Radiation Survey and Site Investigation Manual, (MARSSIM), Revision 1 (August 2000), all excavated areas within the landfill interior required independent verification to ensure that site-specific cleanup criteria for radiological contaminants were met. (Figure 2 shows excavated areas with the exception of the ALI Debris Area, the Tongue Area, and the Inner Rung). Cabrera

Page 9 of 14 Services performed the MARSSIM-compliant Final Status Survey (FSS), and completed the Final FSS Report, Shpack FUSRAP Superfund Landfill Site, Norton/Attleboro, Massachusetts in May 2012. The FSS included collection of confirmation samples from excavation floors and sidewalls during the course of the project prior to backfill of each excavation area. Excavations were backfilled only after FSS sampling and on-site lab analytical results confirmed that radiological contaminants were below cleanup criteria. Further information can be found in the FSS Report listed above.

B. CERCLA Remedial Action

A total of 27,083 tons of waste material was excavated from the Site and transported off- site for disposal. The following is a discussion of the various areas excavated as part of the CERCLA Remedial Action (see Figure 4 for the location of each on-site area):

• The Inner Rung was a portion of Chartley Swamp that was slated for remedial activities due to ecological risk, rather than risk to human health. To address potential risk to benthic organisms in the wetland ecosystem, the excavation removed the top 2 feet of material throughout the area. The restoration of the area included placement of a 1-foot thick layer of clean fill followed by placement of a 1 -foot-thick layer of wetland topsoil to meet the pre-existing grades. Approximately 5,680 tons of waste material generated from the Inner Rung activities were removed and disposed of off Site.

• The Chemical-Only Soil Stockpile consisted of materials excavated by the USACE as part of the FUSRAP response actions. Based on information provided by the USACE, impacts to this material exceeded the ROD chemical cleanup criteria, but did not exceed ROD radiological criteria. The USACE secured the stockpile to protect it from the elements following its demobilization from the Site. Approximately 3,580 tons of waste material from the Chemical-Only Soil Stockpile were removed and disposed of off-Site.

• The ALI Debris Area (ALIDA) was a portion of the Shpack Landfill Interior immediately adjacent to the ALI property that was the location of a reported slope failure from the ALI Landfill. The material in this area consisted of ALI municipal landfill debris underlain by industrial landfill debris associated with the Shpack Landfill. The USACE excavated 17 test pits in the ALI Landfill Debris Area during the FUSRAP activities in 2005. The analytical results from samples collected from the test pits did not exhibit radiological activity above the ROD Table L-l cleanup goals. Thus, the material was not removed during the USACE's FUSRAP response actions. The USACE's test pit data did, however, indicate that that material exceeded several of the ROD Table L-l cleanup goals for chemical compounds. Approximately 7,970 tons of waste material from the ALIDA were removed down to native peat material and disposed of off-Site.

• The Tongue Area was the area formerly extending southeastward from the Shpack Landfill Interior toward the Inner Rung that was elevated above the

Page 10 of 14 surrounding wetlands grades in the Inner Rung. Waste and debris from a fire at an industrial plastics manufacturing facility were reportedly disposed of in the Tongue Area. Approximately 9,680 tons of waste material were removed from the Tongue Area down to native peat material and disposed of off-Site.

Wetlands Restoration

In accordance with the requirements of the ROD, the remedial action required disturbance of approximately 203,500 square feet of wetlands to remove waste materials and to restore the wetlands impacted by the FUSRAP response actions. Wetlands impacts were mitigated through restoration and construction of additional wetlands on-Site (see Figure 5 for the final wetland and upland restoration layout). The final square footage of wetlands restored and created during the remedial action is approximately 231,313 square feet.

IV. SUMMARY OF OPERATION & MAINTENANCE REQUIRED

Under the terms of the CD, the Performing Defendants are responsible for monitoring compliance with and enforcement of the ICs. The Performing Defendants have agreed that the City of Attleboro will perform the O&M activities, including: compliance monitoring; enforcing the ICs as necessary, and prepare and submit annual reports to EPA and MassDEP regarding the status of the ICs, as outlined in the Operations and Maintenance Plan, Revision #J, dated July 2015. The responsible parties (RPs) will provide support to EPA (as directed) and EPA will conduct future Five Year Reviews at the Site to ensure the remedies remain protective of both human health and the environment.

V. DEMONSTRATION OF CLEANUP ACTIVITY QA/QC

A. FUSRAP Remedial Action

USACE's remedial project manager and engineering contractor were responsible for verifying the quality assurance arid quality control (QA/QC) of the FUSRAP Remedial Action. This began with review and approval of the remedial design, remedial action work plan, and construction drawings and specifications. Verification that cleanup criteria for radiological contaminants were achieved in the excavations was performed by an independent contractor, in accordance with requirements of the MARSSIM. Quality control activities included confirmation sampling of excavation bottoms and sidewalls as necessary, use of electronic survey methods to record the limits of excavation, testing of excavation material for disposal characterization, and adherence to approved plans and standard operating procedures. Field oversight and weekly construction meetings verified that other remedial activities were performed in accordance with the approved

Page 11 of 14 plans. Based on the above, the construction contractors performed the work in accordance with the USACE and EPA-approved remedial designs and remedial work plan. Detailed information on FUSRAP QC procedures can be found in Section 4 of the Remedial Action Completion Report, Operable Unit 1- Radiological Contamination, Shpack Landfill Site, prepared for U.S. Army Corps of Engineers, prepared by Conti Environmental, dated May 2012.

B. CERCLA Remedial Action

The EPA and its oversight contractor were responsible for verifying the QA/QC of the CERCLA Remedial Action. This began with review and approval of the remedial design, remedial action work plan, and construction drawings and specifications. Verification that cleanup criteria for CERCLA contaminants were achieved in the excavations was performed via field oversight of confirmation sampling, excavation, and backfill activities and review of results. QC activities included use of electronic survey methods to record the limits of excavation, testing of excavation material for disposal characterization, and adherence to approved plans and standard operating procedures. Field oversight and weekly construction meetings verified that other remedial activities were performed in accordance with the approved plans. Based on the above, the Performing Defendants' construction contractors performed the work in accordance with the EPA and MassDEP-approved remedial design and remedial action work plans. The only slight deviation from the ROD was that the selected remedy called for extension of the public water supply line and connection to two residences adjacent to the Site with private wells (Union Road Houses 1 and 2). However, prior to completion of the CERCLA remedial construction, both residences were demolished and the two private wells were properly abandoned. Due to the installation of the water line to within 500 feet of the Site, consistent with the Commonwealth of Massachusetts' Comprehensive State Groundwater Protection Program (CSGWPP), MassDEP revised its Groundwater Use and Value determination from "high" to "low" within the vicinity of the Site; however, the final connections were not made. Additionally, ICs were placed on the properties to prevent groundwater extraction and prohibit future residential use of the two parcels. Detailed information on QC procedures can be found in Section 4.3 of the Final Remedial Construction and Demonstration of Compliance Report (CERCLA RA Report), dated April 2015. The Commonwealth's revising its groundwater use and value determination from "high" to "low" is consistent with the ROD, remedial action and CSGWPP. Extension of the public water supply, implementation of ICs, and abandoning nearby residential wells prevents current and future exposure to GW contaminants.

VI. FIVE YEAR REVIEWS

Hazardous substances remain at this Site above levels which would allow for unlimited use and unrestricted exposure. Pursuant to CERCLA, Section 121(c) and 40 Code of Federal Regulations Part 340.430(f)(40(ii), as provided in the current guidance on Five Year Reviews (OSWER Directive 9355.7.03B-P), Comprehensive Five Year Review Guidance, EPA must conduct five-year reviews. The first Statutory Five-Year Review

Page 12 of 14 Report will be completed prior to June 12, 2018, which is five years from the initiation of construction of the CERCLA remedy.

VII. SITE COMPLETION CRITERIA

The remedial actions which have been implemented for the FUSRAP and CERCLA operable units achieve the clean-up requirements identified in the 2004 ROD for the Site. Furthermore the remaining Site related contaminants are within EPA's acceptable risk range of 1 x 10-4 to 1 x 10-6 and below an HI = 1 for all appropriate exposure pathways.

All of the selected remedial and removal actions and the remedial action objectives and associated cleanup goals are consistent with the Comprehensive Environmental Response, Compensation, and Liability Act (CERCLA), the National Contingency Plan (NCP) and EPA policy and guidance.

All Institutional Controls are in place'and currently EPA expects that no further Superfund response is needed to protect human health and the environment, except future Five Year Reviews.

VIII. BIBLIOGRAPHY

• Record of Decision (ROD), Shpack Landfill Site, Norton/Attleboro, MA, prepared by EPA, dated September 2004.

• Consent Decree for Remedial Design/Remedial Action as entered by the United States District Court for the District of Massachusetts, January 27, 2009 in U.S. v. City of Attleboro, Massachusetts et al (Civil Action No. J:08-CV-120378), Federal Register Volume 73, Number 245

• Remedial Action Completion Report, Operable Unit 1- Radiological Contamination, Shpack Landfill Site, preparedfor U.S. Army Corps of Engineers, prepared by Conti Environmental, dated May 2012.

• Final Status Survey Report, Shpack FUSRAP Superfund Landfill Site, Norton/Attleboro, MA, preparedfor U.S. Army Corps of Engineers, prepared by Cabrera Services, dated May 2012.

• Final Remedial Construction and Demonstration of Compliance Report, Shpack Landfill, prepared by ERM, dated April 2015

• Operation and Maintenance Plan, Revision #/, prepared by ERM, dated July 2015

Page 13 of 14 Approved by:

\llzzliu Bryan Olsmi, Director JJ Date Office oMe Remediation and Restoration USEPA New England - Region 1 5 Post Office Square, Suite 100 Boston, MA 02109-3912

Page 14 of 14 Water Tank

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Asphalt Area

Existing Gravel Roadway/Pad

— Parcel Boundary —•—•— Chain Link Fence Off-Site Wetlands Boundary (Approximate) Underground Storm Drain Pipe (Temporary) Property Line Municipality Line

Existing Sheet Pile

Existing Unimproved Roads Remedial Action Wort Areas

# Landfill Interior Hot Spots Notes: 1. Features other than the Remedial Action Work Areas are taken from the Plan entitled ALI Landfill Debris Area (ALIDA) 'Existing Conditions Survey. Shpack Landfill. Superfund Site, Peck ham Street Norton/ Attleboro, MA. prepared for ERM" by WSP-SELLS dated January 7,2013. Tounge Area 2. Remedial Action Work Area boundaries are based on field surveys conducted by A-Plus Construction Services. Corp. at various times during the Remedial Action. Inner Rung 3. Horizontal datum refers to the North American Datum of 1983 (NAD83). Figure 4 - Areas of Excavation Under CERCLA Remedial ActionI Chemical-Only Soil Stockpile Shpack Superfund Site - Norton and Attleboro, MA National Grid Substation Town of Norton Conservation Garage

Gate installed during Remedial Action

Chartley Swamp

Attleboro Landfill. Inc.

Approximate location of sheet pile wall installed and left in place below grade. The majority of sheets were driven to an approximate depth of 25 feet, but varied from sheet to sheet based on subsurface resistance.

Notes: 1. Chain Link Fence was taken from the Plan entitled "Existing Conditions Survey. Shpack Landfill, Scale (1"=120) Supetfund Site. Peckham StreeL Norton/AtDeboro. MA, prepared for ERM" by WSP-SELLS dated 60 120 January 7,2013. 2. Restored Wetland and Upland Area boundaries are based on field surveys conducted by A-Plus Construction Services, Corp. at various times during the Remedial Action. 3. Horizontal datum refers to the North American Datum of 1983 (NAD83) Figure 5 - Restored Wetland and Upland Areas Shpack Superfund Site - Norton and Attleboro, MA ATTACHMENT 1

MassDEP Groundwater Use and Value Determination November 14,2013 Commonwealth of Massachusetts Executive Office of Energy & Environmental Affairs Department of Environmental Protection One Winter Street Boston, MA 09108 • 617-299-5500

DEVAL L PATRICK RICHARD K SULLIVAN JR Governor Secretary

KENNETH L KIMMELL Commissioner

November 14, 2013

Melissa Taylor, Remedial Project Manager US EPA Region 1 Mail Code OSRR07-4 5 Post Office Square, Suite 100 Boston, MA 02109-3912

RE: Groundwater Use and Value Determination Shpack Superfund Site (RTN#4-0132)

Dear Ms. Taylor:

Enclosed please find the revised Groundwater Use and Value Determination prepared by the Department (DEP) for the Shpack Superfund Site (the Site). This groundwater Use and Value determination was revised because of an installation of a waterline within 500 feet of the site. This Determination was conducted by the DEP pursuant to the Memorandum of Agreement (1998) between the U.S. Environmental Protection Agency and the DEP.

In determining the use and value of the groundwater in the vicinity of the Shpack Site, we referred to the aquifer classification contained in the Massachusetts Contingency Plan (MCP). The classification in the MCP gives consideration to all of the factors in the Use and Value Guidance.

Enclosed with the Use and Value Determination is the GIS 2IE Resource map (0.5 and 1 mile radii) used to develop the Use and Value Determination. This map provides a variety of information, including the USGS yield classification, the locations of public water supplies and zones of protection, and areas of sensitive ecological resources.

If you have any questions regarding this letter, please don't hesitate to contact Garry Waldeck of my staff at 617-348-4017.

Sincerely,

Jay Naparstek Deputy Division Director

This information is available in alternate format Call Michelle Waters-Ekanem, Diversity Director, at 617-292-5751. TDD# 1-866-539-7622 or 1-617-574-6868 MassDEP Website www mass gov/dep Printed on Recycled Paper GROUNDWATER USE AND VALUE DETERMINATION Shpack Superfund Site Norton, MA

November 14, 2013

Consistent with the Environmental Protection Agency's (EPA) 1996 Final Ground Water Use and Value Determination Guidance, the Department has developed a revised "Use and Value Determination" of the groundwater relative to the Shpack Superfund Site in Norton and Attleboro (the "Site"). This groundwater Use and Value determination was revised because of an installation of a waterline within 500 feet of the site. The purpose of the Use and Value Determination is to identify whether the aquifer at the site should be considered of "High", "Medium", or "Low" use and value. In the development of its Determination, the Department has applied the criteria for groundwater classification as promulgated in the Massachusetts Contingency Plan (MCP). The classification contained in the MCP considers criteria similar to those recommended in the Use and Value Guidance as agreed to in the Memorandum of Agreement (MOA) between EPA and DEP. The Department's recommendation supports a low use and value for the Site Area groundwater. A brief background of the Site, an explanation for the determination, and a table listing the criteria that facilitated the determination are outlined below and DEP's Preliminary Assessment Maps for a 500 foot and Vi mile radius is attached.

The Site covers approximately 9 acres at the Norton/Attleboro town line in Massachusetts. The Site is bounded by wetlands, a solid waste landfill, a residence, and local roadway. The groundwater under evaluation for this determination is within one mile of the Site as shown on the attached Figure.

The Shpack site exists in a watershed consisting of large tracts of wetlands. Within the wetlands exist a substantial network of streams, pools, and ponds. The area can be generally described as a regional groundwater discharge area consisting of glacial deposits with an overlying organic layer associated with the existing wetlands. According the draft Remedial Investigation developed by ERM dated October 17, 2003, bedrock in the area consists of sandstone and siltstone with low primary porosity and moderate secondary porosity. Hydraulic conductivity values as determined by ERM indicate overall moderate to low values for bedrock. Regional groundwater flow is generally in a northerly direction from the Shpack Superfund Site. For these reasons, the review area was limited to a one-mile radius of the site.

Within one mile of the site, two areas have been identified as PPAs, one is approximately lA mile west of the site along Chartley Brook opposite the Attleboro Landfill Incorporated landfill (ALI), the other is located approximately % miles north, northeast along the Wading River downstream of the Chartley Pond dam. The site would not impact these areas as ALI and Chartley Pond provide substantial hydraulic barriers to the movement of

Page 1 of7 Groundwater Use and Value Determination Shpack Superfund Site, Norton, MA October 29,2013 site contaminants in the unconsolidated aquifer and due to the low hydraulic conductivity values for the bedrock. There are no public and non-community water supplies within one mile of the site. The closest non-community water system is two miles of the site, and the nearest public water supply is approximately three miles of the site. The site would not impact these water supplies for the reasons discussed.

There are no residences or known private drinking water wells within 500 feet of the site.

A number of considerations are used to determination the use and value of the groundwater underlying Shpack including the groundwater classification system in the Massachusetts Contingency Plan. Under the MCP, all groundwater in the Commonwealth is classified as GW-3, which considers the ecological and human health impacts and risks associated with the discharge of groundwater to surface water. In addition, groundwater can be classified as GW-2, and GW-1. GW-2 groundwaters are those that may pose an indoor vapor risk, and as such, is outside of the scope of this determination. GW-1 groundwaters are those that are of high quantity and quality and are used for water supplies or have the potential to be used for water supplies. Groundwater is classified as GW-1 under the MCP if it is located: 1. within a Current Drinking Water Source area, which includes groundwater located: a. within a Zone II for a public water supply, b. within the Interim Wellhead Protection Area for a public water supply, . c. within the Zone A of a Class A surface water body used as a public water supply, or d. within 500 feet of a private well.

2. within a Potential Drinking Water Source Area, which includes groundwater located: a. 500 feet or more from a public water supply distribution pipeline, b. within an area designated by a municipality specifically for the protection of groundwater to ensure its availability as a source of potable water, or c. within a Potentially Productive Aquifer.

The groundwater underlying the site meets criteria for classification as GW-2 due to no private drinking water wells within 500 feet of the site, and due to the fact there is a public water supply distribution pipeline within 500 feet of the site.

The criteria established in the MCP that were examined in this determination supports a low use and value for the Site area groundwater. The overriding fact establishing the determination of low use and value is the absence of private drinking water wells within 500 feet of the site and a public water supply within 500 feet of the site.

Page 2 of7 Groundwater Use and Value Determination Shpack Superfund Site, Norton, MA October 29,2013

Pursuant to the Memorandum of Agreement (MOA) between the EPA and MassDEP concerning Ground Water Use and Value Determinations, and consistent with EPA's 1996 Final Ground Water Use and Value Determination Guidance, the Department has developed a revised Use and Value Determination of the groundwater beneath and in the vicinity of the Shpack Superfund site located in Norton and Attleboro, MA (the "Site"). The purpose of the Use and Value Determination is to identify whether the local area groundwater is of high, medium, or low use and value. These are designations contained in EPA's guidance. In the development of this Determination, as agreed to in the MOA, the Department has applied the criteria for groundwater classification promulgated in the Massachusetts Contingency Plan (MCP). The classification contained in the MCP considers criteria similar to those recommended in EPA's Use and Value Guidance.

The Departments determination for the groundwater at the Shpack site is a medium use and value. This recommendation is based on the non-drinking water status of the groundwater beneath and in the general vicinity of the site, and the presence of sensitive ecological resources in the immediate vicinity of the site. This recommendation is explained in more detail below.

For the purposes of this Determination, the groundwater under evaluation is defined as that underlying the Site and the surrounding area extending in a one mile radius from the central portion of the Site as shown on the attached Figure.

The Shpack site covers approximately 9 acres at the Norton/Attleboro town line. It exists in a watershed consisting of large tracts of wetlands. The Site is bounded by wetlands, a solid waste landfill, a residence, and local roadway. Within the wetlands exist a substantial network of streams, pools, and ponds. The area can be generally described as a regional groundwater discharge area consisting of glacial deposits with an overlying organic layer associated with the existing wetlands. According the draft Remedial Investigation developed by ERM dated October 17, 2003, bedrock in the area consists of sandstone and siltstone with low primary porosity and moderate secondary porosity. Hydraulic conductivity values as determined by ERM indicate overall moderate to low values for bedrock. Regional groundwater flow is generally in a northerly direction from the Site.

The land use surrounding the Site is mostly light industrial with some residential areas. The nearest residence is located Vi mile from the site. There are no public or private water supplies within one mile of the site. Municipal water is available through a newly installed extension to the Attleboro municipal water line which runs along Peckham Street/Union Road. The closest municipal water supply well is located in Rehoboth, approximately 3 miles southwest of the site. Sensitive ecological areas are located at and around the site and include wetland areas surrounding the site and Certified Vernal Pools within 600 feet to the north of the Site.

Page 3 of7 Groundwater Use and Value Determination Shpack Superfund Site, Norton, MA October 29, 2013

The aquifer immediately beneath the Site is classified as a low yield aquifer by the United States Geological Survey. This groundwater is not considered to be a Current or Potential Drinking Water Source Area (MCP Category GW-1) and is category GW-3 under the MCP. Drinking water standards do not apply at GW-3 areas.

There are two medium yield aquifers, as defined by the USGS, within the study area. One is located approximately lA mile west of the site along Chartley Brook opposite the Attleboro Landfill Incorporated landfill (ALI). The other is located approximately % miles north/northeast along the Wading River downstream of the Chartley Pond dam. These are considered category GW-1, Potential Drinking Water Source Areas. State and federal drinking water standards apply to these areas. Any groundwater migrating from the site should meet or exceed State and federal drinking water standards (MCLs/GW-1) if and when it reaches any of these areas.

In summary, groundwater directly beneath and in the immediate vicinity of the site is category GW-3 and GW-2 and not considered a source of drinking water. Drinking water standards are not directly applicable in these areas. Some groundwater areas outside the site boundary and not in the immediate vicinity of the site, but within the study area, are category GW-1 and should be considered as drinking water source areas. Drinking water standards do apply in these locations. Finally, there are sensitive environmental receptors within the study area at and in the immediate vicinity of the Site. Determinations of protectiveness should include evaluation of the impacts to these areas.

Definitions of the various groundwater categories in the MCP are summarized as follows:

GW-1 The groundwater is located within an area that is currently used for drinking water or is considered to be a location that has the potential to be developed for public water supply. State and federal drinking water standards are directly applicable to these areas.

GW-2 This designation addresses areas where there is a potential for migration of vapors from groundwater to occupied structures. The classification applies to locations where groundwater has an average annual depth of 15 feet or less and where there is an occupied building or structure within a 30 foot surface radius of that groundwater. In these cases, evaluation of risk should include indoor air exposures through contaminant vapor intrusion.

GW-3 This designation considers the impacts and risks associated with the discharge of groundwater to surface water and therefore applies to all groundwater in the Commonwealth, regardless of any other category it may also fall within. Evaluation of risk should include human health and environmental exposure resulting from discharge of contaminated groundwater to surface water bodies.

Page 4 of 7 Groundwater Use and Value Determination Shpack Superfund Site, Norton, MA October 29, 2013

Considering these classifications, evaluation of the groundwater risks and remedy performance at the Shpack site should include, but is not limited to, the following:

Human Health: a) vapor seepage into buildings, b) migration of contaminants to GW-1 areas off-site, c) potential exposures resulting from discharge to surface water (e.g. wading, recreation, fishing), d) other potential non-consumptive exposures.

Ecological: • a) ecological risks posed by discharge of groundwater to nearby wetlands and Vernal Pools.

In light of the use and value factors contained in EPA's guidance and similar criteria established in the MCP that were examined in this determination, the Department recommends a medium use and value for the Site groundwater.

Page 5 of 7 Groundwater Use and Value Determination Shpack Superfund Site, Norton, MA October 29, 2013

Groundwater Use and Value Considerations Factors High. Medium Low Comments 1. Quantity X Aquifer would be considered low to moderate yield based on hydraulic conductivity values determined at the site. 2. Quality X Testing of private wells in the area indicate the presence of inorganics at concentrations that occasionally exceed secondary standards. 3. Current X There are no known public or non-community Public Water water supplies within one mile of the site. The Supply Systems nearest pubic water supplies are over two miles from the site. 4. Current X No private drinking water supplies exist in the Private Drinking area. None within 500 hundred feet of the site. Water Supply Wells 5. Likelihood Given the hydraulic conductivity values and I.D. of determined by site studies, and the presence of a Future Drinking subtitle D facility, it is unlikely the aquifer in Water Use this area would be considered as a viable source of future drinking water. 6. Other Current X Given the lack of industry near the site and the or reasonable presence of ALI, it is unlikely the groundwater Expected would be permitted to be utilized for other Groundwater purposes. Use(s) in Review Area 7. Ecological X Groundwater in the study area discharges to Value significant wetland resource areas 8. Public X The absence of private drinking water supplies Opinion within the review area would lead to the public's medium value of the groundwater resource.

Page 6 of 7 Groundwater Use and Value Determination Shpack Superfund Site, Norton, MA October 29, 2013

MassDEP - Bureau of Waste Site Cleanup Site Information: MCP Numerical Ranking System Map: 500 feet & 0.5 Mile Radii ,, , The information shown B the beat avaWilB at (he M0RT£>N' date of p>..-ling HoweverJl may be incwnptev. The 153 MassDEP OakSwM'»« surrounding Ihe site Metadatafor data layers shown J ' on this map can be found at S tWifwirlunnnt * IftititinmatMl hit? /fwwifit fntta&MHY/mHia/

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Aqutfort Medium Ylald, Wiuh Yield, SPA Sola Souice Cat RaraWadand Wlldnfo Hab.vamal Pool: Carl. Potential L_i_J Madfom, High (Yield),, SolidWhip LpndAii.Rwi! Cow OW.IW,lmota,Non«Com 82821 O O # O

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