PROPOSED PLAN: EPA PROPOSES CLEANUP PLAN FOR

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EPA Region ISuper-fund ProgramShaffer Landfill, Iron Horse ParkBillerica, MAProposedPlanJanuary 1991EPA Proposes Cleanup Plan for theShaffer Landfill portion of the IronHorse Park Superfund SiteThe U.S. Environmental Protection Agency (EPA) is proposing acleanup plan, referred to as a preferred alternative, to addresscontamination at the Shaffer Landfill, Iron Horse Park Superfund site inBillerica, MA. The Proposed Plan describes a cleanup optionrecommended from among those that were evaluated during the RemedialInvestigation (RI)* and Feasibility Study (FS) performed for the site. Inaccordance with Section 117(a) of the Comprehensive EnvironmentalResponse, Compensation, and Liability Act (CERCLA), EPA is publishingthis Proposed Plan to provide opportunity for public review and comment onthe cleanup alternatives, known as remedial alternatives, underconsideration for the site. EPA will consider public comments as part of thefinal decision-making process for selecting the cleanup remedy for the site.The preferred alternative includes: 1) partial reconstruction of theexisting cap; and 2) collection and treatment of leachate to remove andprevent further migration of contaminants. The preferred alternative isdescribed in greater detail on pages 7 through 8 of this document.This Proposed Plan:1. explains the opportunities for the public to comment on the remedialalternatives;2. includes a brief history of the site and the principal findings of siteinvestigations;3. provides a brief description of the preferred alternatives and otheralternatives evaluated in the FS;4. outlines the criteria used by EPA to propose an alternative for use at thesite, and briefly analyzes whether the alternatives meet each criterion;and5. presents EPA's rationale for its preliminary selection of the preferredalternative.To help the public participate in reviewing the cleanup options for thesite, this document also includes information about where interestedWords in boldface are defined in the glossary which begins on page 14.

citizens can find more detailed descriptions of the remedial process and thealternatives tinder consideration for the Shaffer Landfill section of the IronHorse Park site.The Public's Role in Evaluating RemedialAlternativesPublic Informational MeetingEPA will hold a public informational meeting on Tuesday, January 15,1991 at 7:30 p.m. at the Billerica Town Hall Auditorium, located at 365Boston Road in Billerica, MA to describe the preferred alternative and otheralternatives evaluated in the Feasibility Study. The public is encouraged toattend the meeting to hear the presentations and to ask questions.Public Comment PeriodEPA is conducting a 30-day public comment period from January 16 toFebruary 14,1991, to provide an opportunity for public involvement in thefinal cleanup decision. During the comment period, the public is invited toreview this Proposed Plan and the RI and FS reports and to offer commentsto EPA.Informal Public HearingEPA also will hold an informal public hearing on Tuesday, February 5,1991 at 7:30 p.m. at the Billerica Town Hall Auditorium, 365 Boston Rd.,Billerica, MA, to accept oral comments on the cleanup alternatives underconsideration for the site. This hearing will provide an opportunity forpeople to comment on the cleanup plan after they have heard thepresentations made at the public informational meeting and reviewed thisProposed Plan. Comments made at the hearing will be transcribed, and acopy of the transcript will be added to the site Administrative Recordavailable at the EPA Records Center at 90 Canal St. in Boston, MA, and atthe information repository location listed on page 3.Written CommentsIf, after reviewing the information on the site, you would like tocomment in writing on EPA's preferred alternative, any of the othercleanup alternatives under consideration, or other issues relevant to thesite cleanup, please deliver your comments to EPA at the Public Hearing ormail your written comments (postmarked no later than Feb. 14,1991) to:Don McElroy, Remedial Project ManagerU.S. Environmental Protection AgencyWaste Management Division (HEC-CAN6)JFK Federal BuildingBoston, MA 02203-1911(617)223-5518EPA's Review of Public CommentEPA will review comments received from the public as part of theprocess of reaching a final decision on the most appropriate remedialalternative, or combinations of alternatives, for cleanup of the ShafferLandfill, Iron Horse Park site. EPA's final choice of a remedy will beissued in a Record of Decision (ROD) for the site this spring. A document,Shaffer Landfill/Iron Horse Park Proposed PlanPage 2

called a Responsiveness Summary, that summarizes EPA's responses tocomments received during the public comment period will be issued withthe ROD. Once the ROD is signed by the EPA Regional Administrator, itwill become part of the Administrative Record, containing documents usedby EPA to choose a remedy for the site.Additional Public InformationBecause this Proposed Plan provides only a summary description of theinvestigation of the Shaffer Landfill, Iron Horse Park site and the cleanupalternatives considered, the public is encouraged to consult theAdministrative Record, which contains the Remedial Investigation andFeasibility Study reports and other site documents, for a more detailedexplanation of the site and all of the remedial alternatives underconsideration.The Administrative Record is available for review at the followinglocations:EPA Records CenterBillerica Public Library90 Canal Street, 1 st Floor25 Concord RoadBoston, Massachusetts 02114Billerica, MA 01821(617)573-5729(508)671-0949Hours:Hours:Mon. - Thur.: 9:00 a.m. to 9:00 p.m.Monday-Friday: 8:30 a.m. to 1:00p.m. and 2:00 p.m. to 5:00 p.m.Fri., Sat.: 9:00 a.m. to 5:00 p.m.Site HistoryThe Shaffer Landfill comprises just one part of the Iron Horse ParkSuper-fund site. The entire Site consists of approximately 553 acres of landin North Billerica, near the the Tewksbury town line (see Figure 1). TheSite is an active industrial complex and rail yard with a long history ofactivities that have resulted in contamination of soils, groundwater, andsurface water.The Shaffer Landfill is located on property originally owned by theBoston & Maine Corporation. In 1966, the Boston & Maine Corporation soldthe site to the Shaffer Realty Corporation. Title to the property was thentransferred to the Graypond Realty Trust. Graypond Realty Trust is thecurrent owner of the site.The landfill occupies 106 acres east of Pond Street and south ofRichardson Pond in the Town of Billerica, MA (see Figure 2).Approximately 60 acres of the site were used for disposal of residential andcommercial solid waste over a period of more than 30 years. Prior to its useas a landfill, the area was a wetland.The Shaffer Landfill itself is divided into two physically distinct sections.The western section includes approximately 24 acres and is referred to asthe "Residential Section". The eastern section includes approximately 36acres and is referred to as the "Commercial Section".Records from the Massachusetts Department of EnvironmentalProtection (MADEP) and the Town of Billerica indicate that the propertywas used for rubbish disposal by 1946, and was an open burning dump forover 20 years. In 1968 the Town of Billerica passed new regulations whichShaffer Landfill/Iron Horse Park Proposed PlanPage 3

required that all refuse be placed above the water table, that the dump beoperated as a sanitary landfill, and open burning be stopped. The landfill,however, generally did not meet these regulations: open burning continuedand daily cover was inadequate.After issuing a series of violation notices and administrative ordersciting continued noncompliance with the Commonwealth's environmentalregulations, the Massachusetts Department of Environmental QualityEngineering (now called the MA Department of Environmental Protectionor MADEP) filed suit in an attempt to obtain compliance with theserequirements. A settlement was reached by the parties in 1984. The termsof this settlement are contained in a Final Judgment. As part of thissettlement, the Shaffer Landfill ceased accepting refuse at the "CommercialSection" in 1984, and at the "Residential Section" in 1986. Work to close thelandfill in accordance with the Final Judgment has been continuing sincethat time.Iron Horse Park was placed on the National Priorities List (NPL) inSeptember 1984.Cleanup Activities to DateIn August 1984, EPA, using its removal authority, covered a portion ofthe Iron Horse Park Site, west of Pond Street, known as the Johns-ManvilleAsbestos Landfill, with gravel and topsoil to prevent asbestos in the landfillfrom becoming airborne.In 1985, EPA began evaluations of the Site to determine the nature andextent of contamination at Iron Horse Park. Under the first phase of theevaluation, EPA conducted a broad study of the Site. This study wasentitled the Phase 1A Remedial Investigation (RI), and was conducted fromSeptember 1985 to July 1987. As a result of the Phase 1A RI, EPA concludedthat the size and complexity of the Iron Horse Park Site warranted dividingthe Site into Operable Units. The Operable Units would then be studied andcleaned up in phases.The Phase IB RI and FS were conducted for Operable Unit 1, the B & MWastewater Lagoons. A Record of Decision (ROD), choosing a remedy forOperable Unit 1 was signed in September 1988. Work on the remedy for thisportion of the site is currently underway.The Shaffer Landfill is the second Operable Unit. The Phase 1C RI wascompleted in November 1989. The Phase 1C FS was completed in January1991. Under the Final Judgement entered into with Massachusetts, theowners of the landfill have commenced construction of a cap. This cap doesnot meet the technical specifications of the Final Judgment.The third Operable Unit contains the other areas of concern at IronHorse Park which were identified in the Phase 1A RI (see section 10.2 ofthat document for details). These areas will be addressed in asupplemental RI. The characterization of these areas will begin late thiswinter.Results of the Remedial Investigation (RI)The RI identifies the nature and extent of contamination at the site.EPA conducted field activities for the RI that included the collection andShaffer Landfill/Iron Horse Park Proposed PlanPage 4

analysis of samples of groundwater, sediment, and surface water. Theseanalyses identified contaminants such as Volatile Organic Compounds(VOCs), acid/base/neutral (ABN) compounds, and metals in groundwater,sediments, and surface water. The findings of the field activities aresummarized below.1. Groundwater: Groundwater flows in three directions aroundShaffer Landfill. West and southwest of the landfill, groundwater flowsnorth toward Richardson Pond. In the central portion of the landfill,groundwater flow is both north toward Richardson Pond, and south towardthe Middlesex Canal. In the eastern portion of the landfill, groundwaterflows to the east. As part of the process of reaching these conclusions onflow, EPA installed 12 new wells and used 37 existing wells in its study ofgroundwater.The highest levels of VOCs in groundwater were detected east(downgradient) of the landfill. EPA found that VOCs such as benzene,xylenes, and others are present hi this groundwater at levels that are aboveMaximum Contaminant Levels (MCLs) for drinking water.Acid/base/neutral (ABN) compounds were detected at low levels in somewells southeast (downgradient) of the landfill. Metals were detected atlevels above MCLs in groundwater north (upgradient) of the landfill andsouth of the Middlesex Canal.The RI groundwater data suggests that leachate is contaminatinggroundwater and flowing off-site to the east and southeast.2. Sediment: Sediment samples were taken in 33 locations surroundingand adjacent to the landfill. The highest concentrations of VOCs werefound north of the landfill on the southern edge of Richardson Pond. ABNcompounds were found both upstream and downstream of the landfill. Thehighest levels of ABN compounds were found west of the landfill atrelatively low levels and do not appear to have a connection with thelandfill.3. Surface Water: EPA collected surface water samples from 19locations. VOCs were found north of the landfill on the southern edge ofRichardson Pond and along Content Brook east and downstream of thelandfill. All Ambient Water Quality Criteria (AWQC) for arsenic wereexceeded both upstream and downstream of the landfill, but again thehighest concentration was measured downstream. The AWQC for nickelwas exceeded downstream of the landfill.Summary of Site RisksAn Endangerment Assessment was prepared in 1989 for the ShafferLandfill site. The Endangerment Assessment determines the present andfuture potential risks to public health and the environment posed by thesite, based on existing conditions as determined by the RI. EPA concludedin the Endangerment Assessment that drinking groundwatercontaminated by leachate from the landfill poses a potential risk to humanhealth. EPA believes that groundwater hi the area around the site is notcurrently being used for drinking water. This means that nobody iscurrently exposed to this risk. If, in the future, residents were to use theon-site groundwater as a drinking water supply, such use could poseShaffer Landfill/Iron Horse Park Proposed PlanPage 5

unacceptable risks to human health. The risk through skin contact withcontaminated sediments in the streams is very low.Air quality studies by MADEFs Office of Research and Standards, haveindicated that while Allowable Ambient Levels (AALs) for certain airpollutants have been exceeded on-site, there is no indication that residentsoff-site are exposed to those higher concentrations.Actual or threatened releases of hazardous substances from this site, ifnot addressed by the preferred alternative or one of the other activemeasures considered, may present a current or potential threat to publichealth, welfare or the environment.For an explanation of risks posed by contamination at the ShafferLandfill site, please refer to the Endangerment Assessment presented inSection 6.0 of the Shaffer Landfill RI report and the site administrativerecord which are available at the information repository at the BillericaPublic Library.Proposed Cleanup ObjectivesUsing the information gathered during the RI and FS, EPA identifiedremedial response objectives for cleanup of the Shaffer Landfill site. Thecleanup objectives are listed below.1. Prevent ingestion/direct contact with landfill waste contamination;2. Prevent migration of contamination via leachate which would result ingroundwater concentrations in excess of federal MCLs andMassachusetts Groundwater Quality Standards;3. Prevent migration of contamination via leachate to surface waters andsediments to ensure that AWQCs are not exceeded due to the site;4. Prevent damage and loss of wetlands caused by eroding soil from thelandfill cap, and meet all federal and state wetlands protection ARARs;5. Prevent ingestion of water having contamination in excess of federalMCLs and Massachusetts Groundwater Quality Standards, and;6. Restore groundwater aquifer off site to contaminant concentrationsbelow federal MCLs and Massachusetts Groundwater QualityStandards.The principle threats at the site stem from groundwater contaminationwhich is a result of leachate migration from the landfill. Groundwaterbeyond the boundary of the waste management unit will meet MCLs andMassachusetts Groundwater Quality Standards following capping andleachate collection which will result in attenuation of groundwatercontamination over time. Although exceedances of AWQC have beendetected in surface waters, this operable unit addresses the landfill,leachate and groundwater only. Surface waters will be looked at in thefuture to see if Superfund is the appropriate mechanism to deal with thisproblem.Finally, it should be noted that the preferred alternative for the site doesnot meet the closure requirements of the Resource Conservation andRecovery Act (RCRA) Subtitle C. RCRA Subtitle C closure is not identifiedas an Applicable or Relevant and Appropriate Requirement (ARAR) forthis Site because there is no evidence that hazardous waste was disposed ofShaffer Landfill/Iron Horse Park Proposed PlanPage 6

at the site. If information becomes available that shows that hazardouswaste was disposed of at the site, closure of the landfill under Subtitle Cstandards may not be possible because it would necessitate covering aportion of the Boston and Maine Railroad tracks and filling a portion of thewetlands. EPA seeks your comments on a potential waiver of ARARspursuant to Section 121 (d) (4) of CERCLA.EPA's Preferred AlternativeEPA's selection of the preferred cleanup alternative for the ShafferLandfill site, as described in this Proposed Plan, is the result of acomprehensive evaluation and screening process. The FS for the site wasconducted to identify and analyze the alternatives considered for addressingcontamination at the site. The FS report for the Shaffer Landfill sitedescribes the alternatives considered, as well as the process and criteriaEPA used to narrow the list of eight potential remedial alternatives. (Fordetails on EPA's screening methodology, see Sections 3 and 4 of the FS.)The following sections describe the preferred alternative and the otheralternatives EPA retained for "detailed analysis.EPA is proposing a cleanup plan to address the source of contaminationat the landfill as well as the resultant groundwater contamination. The FSevaluates alternatives which address both Source Control and Managementof Migration. In the FS, EPA's preferred alternative is referred to asAlternative #4Source ControlEPA's preferred alternative for Shaffer Landfill consists ofimprovements to the landfill cap, and collection, removal, treatment, anddisposal of leachate.This alternative would control the sources of contamination by: Reconstruction of the top portions (approximately 16 acres) of theexisting landfill cap. This will improve its ability to preventprecipitation from leaching through the landfill. Reconstructionwould be achieved by removing the existing topsoil layer, adding filland regrading to achieve a minimum 5% slope, installing additionallow permeability material (either an additional 12-inches of soil witha maximum permeability of 1x10'? cm/sec or a flexible membraneliner), installing a new 6-inch drainage layer, reinstalling the topsoillayer to a depth of 12-inches, and reseeding the disturbed areas. Improvements to the existing surface drainage system. Maintenance of dap, surface drainage system, and landfill gascollection/flare system. If necessary, improvements will be made. Monitoring of the gas collection/flare system. Construction, operation, and maintenance of leachate collectionfacilities. Off-site treatment and disposal of leachate. Construction of a site perimeter security fence.Shaffer Landfill/Iron Horse Park Proposed PlanPage 7

Management of Contaminant MigrationThe preferred alternative would manage the migration of contaminantsby: Monitoring of groundwater and surface water quality.Under this alternative, the top, flatter portions of the landfill cap wouldbe partially reconstructed to improve the runoff of surface water, and toreduce the infiltration of water through the landfill and waste, and therebyreduce the production of leachate. The leachate produced by the landfillwould be collected into a leachate storage tank and then treated anddisposed off-site in accordance with applicable requirements. Groundwaterand surface water quality would be monitored to show the effectiveness ofthese measures in controlling the spread of further contamination andmeeting clean up standards.Estimated Time for Design and Construction: 1 YearEstimated Time for Operation: 30 yearsEstimated Capital Cost: 2,095,000Estimated Operation and Maintenance Cost: 3,541,000Estimated Total Cost: 5,637,000Other Alternatives Evaluated in the FSThe public is invited to comment not only on the preferred cleanupalternative, but also on the other seven remedial alternatives that EPAevaluated in detail. Each of these alternatives is described briefly below. Amore detailed description of each alternative can be found in the FeasibilityStudy report.Alternative 1: No Action: This alternative was evaluated in detail in theFS to serve as a baseline for comparison with the other remedialalternatives under consideration. Under this alternative, no treatment orcontainment of waste or leachate would occur and no effort would be madeto restrict potential exposure to site contaminants.Alternative 2: Landfill Cap Completion/Repair: Alternative 2 is similarto the preferred alternative (alternative 4) but involves fewer improvementsto the existing landfill cap. Alternative 2 would include:- Repair of top portions (approximately 16 acres) of existing cap on bothsections of the landfill by addition of fill, and regrading to achieveminimum 5% slopes followed by reconstruction of the low permeabilityand topsoil layers over those areas;- Maintenance of cap, surface drainage system, and landfill gascollection/flare system. If necessary, improvements will be made;- Monitoring of gas collection/flare system;— Monitoring of groundwater and surface water quality, and;- Construction of a site perimeter fence.Estimated Time for Design and Construction: 6 monthsEstimated Period for Operation: 30 yearsEstimated Capital Cost: 1,330,000Estimated Operation and Maintenance Cost (net present worth): 901,000Estimated Total Cost (net present worth): 2,231,000Shaffer Landfill/Iron Horse Park Proposed PlanPage 8

Alternative & Landfill Cap Completion/Repair with LeachateCollection: Alternative 3 contains the same features as Alternative 2 interms of completion and maintenance of the landfill cap. In addition,Alternative 3 calls for:- Improvements to the existing surface drainage system;— Construction, operation, and maintenance of leachate collectionfacilities, and;- Off-site treatment and disposal of leachate.Estimated Time for Design and Construction: 1yearEstimated Period for Operation: 30 yearsEstimated Capital Cost: 1,649,000Estimated Operation and Maintenance Cost (net present worth): 3,541,000Estimated Total Cost (net present worth): 5,190,000Alternative 3A: Landfill Cap Completion/Repair with LeachateCollection and Groundwater Extraction and Treatment: Alternative 3Acontains the same features as Alternative 3 in terms of; completion andmaintenance of the landfill cap, improvements to the surface drainagesystem and leachate collection and treatment. In addition, Alternative 3Acalls for:— Construction, operation, and maintenance of a groundwater extraction— system along the eastern side of the landfill;- Construction, operation and maintenance of an on-site systern fortreatment of groundwater and leachate, and;- Discharge of treated groundwater to surface water.Estimated Time for Design and Construction: 2 yearsEstimated Period for Operation: 30 yearsEstimated Capital Cost: 8,842,000Estimated Operation and Maintenance Cost (net present worth): 4,310,000Estimated Total Cost (net present worth): 13,152,000Alternative 4A: Partial Reconstruction of Landfill Cap with LeachateCollection and Groundwater Extraction and Treatment: Alternative 4Aincludes all of the landfill cap reconstruction features, improvements to thesurface drainage system, and leachate collection and treatment, which arealso part of the Preferred Alternative (Alternative 4) described earlier. Inaddition, Alternative 4A also includes:— Construction, operation, and maintenance of a groundwater extractionsystem along the eastern side of the landfill;- Construction, operation, and maintenance of an on-site system fortreatment of groundwater and leachate, and;- Discharge of treated groundwater to surface water.Estimated Time for Design and Construction: 2 yearsEstimated Period for Operation: 30 yearsEstimated Capital Cost: 9,257,000Estimated Operation and Maintenance Cost (net present worth): 4,310,000Estimated Total Cost (net present worth): 13,567,000Shaffer Landfill/Iron Horse Park Proposed PlanPage 9

Alternative 5: Total Reconstruction of Landfill Cap: This alternativeinvolves a complete reconstruction of the landfill cap but does not includeleachate collection and treatment. The components of Alternative 5 are:- Reconstruction of the entire landfill cap to meet the EPA'srecommended final cover design standards for hazardous wastelandfills;- Maintenance of cap and landfill gas collection/flare system. Ifnecessary, improvements will be made;- Monitoring of gas collection/flare system;- Monitoring of groundwater and surface water quality, and;— Construction of a site perimeter security fence.The cap reconstruction is extensive, and would include the followingactivities:- Excavation of the existing vegetated topsoil;- Temporary storage of the excavated soil;- Removal of existing surface drainage facilities;- Protection and raising of existing gas collection manholes;- Regrading to establish required slopes;— Upgrading the existing low permeability soil layer to achieve 24 inches ofsoil with a maximum permeability of 1 x 10-7 cm/sec;- Testing of the upgraded low permeability layer to assure designstandards are achieved;- Installation of a flexible membrane liner (FML) component directlyabove the upgraded low permeability soil layer;- Installation of a soil drainage layer above the FML to drain theimmediate and upgradient areas of the landfill;- Installation of a geotextile filter between the drainage layer and uppervegetative layer,— Installation of the vegetative support layer consisting of a minimum 24 inch layer of soil;— Re-establishment of vegetative cover,— Construction of required surface water runoff control facilities, and;- Erosion control during construction activities.Estimated Time for Design and Construction: 2 112 yearsEstimated Period for Operation: 30 yearsEstimated Capital Cost: 12,799,000Estimated Operation and Maintenance Cost (net present worth): 901,000Estimated Total Cost (net present worth): 13,700,000Alternative 5A: Total Reconstruction of Landfill Cap with GroundwaterExtraction and Treatment: Alternative 5A contains all components ofAlternative 5. Alternative 5A also includes:— Construction, operation, and maintenance of a groundwater extractionsystem along the eastern side of the landfill;- Construction, operation, and maintenance of and on-site groundwatertreatment system, and;- Discharge of treated groundwater to surface water.Estimated Time for Design and Construction: 21l2 yearsEstimated Period for Operation: 30 yearsShaffer Landfill/Iron Horse Park Proposed PlanPage 10

Estimated Capital Cost: 19,992,000Estimated Operation and Maintenance Cost (net present worth): 4,310,000Estimated Total Cost (net present worth): 24,302,000Summary of the Comparative Analysis ofAlternativesEPA uses nine criteria to evaluate each remedial alternative retained fordetailed analysis in the FS. The nine criteria are used to select a remedythat meets the national Superfund program goals of protecting humanhealth and the environment, maintaining protection over time, andminimizing untreated waste. Definitions of the nine criteria and asummary of EPA's evaluation of the alternatives using the nine criteria areprovided below:1.Overall Protection of Human Health and the Environmentaddresses how an alternative as a whole will protect human healthand the environment. This includes an assessment of how publichealth and environmental risks are properly eliminated, reduced, orcontrolled through treatment, engineering controls, or institutionalcontrols.The preferred alternative (Alternative 4) for addressing contaminationat the Shaffer Landfill would provide overall protection by preventing directcontact and ingestion of site contaminants, reducing the volume of leachateproduction, and minimizing erosion of the landfill into surroundingwetlands. Further protection would be provided by the collection and off-sitetreatment and disposal of leachate.Alternatives 2, 3, 3A, 4A, 5, and 5A would also provide overallprotection, but to varying degrees. In general, cap effectiveness and erosionprotection increase from Alternative 2 to Alternative 5. In addition, the "A"alternatives provide additional protection by treating groundwater.Alternative 2 is the least protective, and Alternative 5A is the mostprotective. Only Alternative 1, the no action alternative, would not meetthis criterion. Under Alternative 1 there is a cap in place, however it is notproperly maintained and access to the site is not adequately restricted.2.Compliance with Applicable or Relevant and AppropriateRequirements (ARARs) addresses whether or not a remedy complieswith all State and Federal environmental and public health laws andrequirements that apply or are relevant and appropriate to theconditions and cleanup options at a specific site. If an ARAR cannotbe met, the analysis of the alternative must provide the grounds forinvoking a statutory waiver.Alternatives 2 through 4 in the detailed analysis in the FS would meetall ARARs. Alternative 1 would not meet MCLs and MassachusettsGroundwater Quality Standards. Alternative 5 would not meet wetlandsARARs.3.Long-term Effectiveness and Permanence refers to the abilityof an alternative to maintain reliable protection of human health andthe environment over time once the cleanup goals have been met.Shaffer Landfill/Iron Horse Park Proposed PlanPage 11

Alternatives 1 and 2 do not meet this criterion because they contain nomeasures to address leachate or groundwater. In general, the long-termeffectiveness and permanence of the alternatives increases fromAlternative 2 to Alternative 5 because of increasing cap stability. Inaddition , all alternatives require operation and maintenance to ensure theyare prot

Shaffer Landfill, Iron Horse Park Billerica, MA . Proposed Plan : January 1991 ; EPA Proposes Cleanup Plan for the Shaffer Landfil portiol n of the Iron Horse Park Superfund Site . The U.S. Environmental Protectio Agencn (EPAy ) is proposing a cleanup

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