Letter (with enclosures) from Silfer (GE) to Cavagnero (USEPA),

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Letter (with enclosures) from Silfer (GE) to Cavagnero (USEPA), Powered By Docstoc
					                                                  GE Corporate Environmental Program;,
                                                  General f'ecmc Company
                                                  WO VJoodlawn Avenue. Pittslield. MA 0120'

                                                                                              SDMS DocID   240772

                                                    Septembers, 1999


Transmitted Via Federal Express

Mr. Richard Cavagnero
Chief, Emergency Planning & Response Branch
Office	 of Site Remediation and Restoration
U.S. Environmental Protection Agency
One Congress Street, Suite 1100 - HBR
Boston, Massachusetts 02203-2211

       Re:	   Pittsfield/Housatonic River Site
              On-Plant Consolidation Areas ­
              Supplemental Addendum to June 1999 Detailed Work Plan

Dear Mr. Cavagnero:

        Enclosed is a revised Supplemental Addendum to the General Electric Company's Detailed
 Work Plan for On-Plant Consolidation Areas. This Supplemental Addendum replaces the
Supplemental Addendum that was sent to you on August 25, 1999. It contains updated ARARs
tables for the On-Plant Consolidation Areas, which incorporate EPA's comments on prior versions.
We would appreciate receiving EPA's formal approval of this Supplemental Addendum.

                                                   Sincerely,



                                                   Andrew T. Silfer, P.E.
                                                   Senior Technical Manager

Enclosure

cc:	   John Kilborn, Esq., EPA                     Andrew Thomas, Jr., Esq., GE
       Tim Conway, Esq., EPA                       John Novotny, P.E., GE
       Bryan Olson, EPA                            James Nuss, P.E., L.S.P.,
       Michael Nalipinski, EPA                        Blasland, Bouck & Lee, Inc.
       Robert Bell, Esq. DEP                       Jeffrey Bernstein, Esq.,
       Alan Weinberg, DEP                             Bernstein, Cushner & Kimmel
       Betsy Harper, Esq., MAAG                    James Bieke, Shea & Gardner
       Cynthia Huber, Esq., DOJ
                                                                  TABLE 1


                                                  ARARs for Hill 78 Consolidation Area


      Regulation                 Citation                  Requirements                 Applicability/Appropriateness      Determination Re Attainment

Federal ARARs
TSCA Regulations (PCB     40CFR761.61             Establishes cleanup options for      Applicable to the extent Hill 78   Materials subject to this regulation
Remediation Waste)                                PCB remediation waste,               Consolidation Area contains        will not be added to Hill 78
                                                  including PCB-contaminated           preexisting materials with PCBs    Consolidation Area. However, to
                                                  soils. Options include risk-         50 ppm.                            the extent this area already
                                                  based approval by EPA. Parties                                          contains TSCA-regulated wastes,
                                                  seeking risk-based approval                                             this requirement will be attained
                                                  must demonstrate that cleanup                                           based on EPA finding that
                                                  plan will not pose an                                                   construction and use of this
                                                  unreasonable risk of injury to                                          Consolidation Area per Work Plan
                                                  health or the environment.                                              will not pose an unreasonable risk
                                                                                                                          of injury to health or the
                                                                                                                          environment.

TSCA Regulations          40CFR761.79             Establishes decontamination          Applicable to decontamination of   Will be attained in the event that
(Decontamination)                                 standards and procedures for         equipment used in consolidation    equipment used in Hill 78
                                                  removing PCBs from non­              excavation activities.             Consolidation Area requires
                                                  porous surfaces.                                                        decontamination for PCBs by
                                                                                                                          implementing equipment cleaning
                                                                                                                          procedures in accordance with
                                                                                                                          Section 6.15 of Work Plan.

Clean Water Act NPDES     40CFR122.26(c)(ii)(C)   Discharges of storm water            Applicable to discharges of        Will be attained by implementing
Regulations (Stormwater   40CFR122.44(k)          associated with construction         stormwater.                        erosion and sedimentation controls
Discharges)               40CFR125.100-.104       activities are required to                                              and stormwater management
                                                  implement best management                                               measures in accordance with
                                                  practices to control pollutants in                                      Sections 4.7, 5.9, 6.11, and 6.13 of
                                                  stormwater discharges during                                            Work Plan.
                                                  and after construction activities.




                                                                     -1­
                                                                  TABLE 1

                                                   ARARs for Hill 78 Consolidation Area

      Regulation                   Citation                 Requirements                Applicability/Appropriateness         Determination Re Attainment

Federal ARARs (cont'd)

RCRA Regulations           40 CFR 264.30 l(g)-O)   Certain design and operating        Relevant and appropriate to           Will be attained.
Hazardous Waste                                    standards for hazardous waste       consolidation of waste to the
Management/Disposal                                landfills, including requirements   extent Consolidation Area already
Facilities (Landfill                               to have run-on and run-off          contains materials that constitute
Operation)                                         control systems for 25-year         hazardous waste.
                                                   storm, manage stormwater
                                                   control systems, and apply cover
                                                   if landfill contains paniculate
                                                   matter subject to wind dispersal.
                                                   These standards do not include
                                                   liner and leachate collection
                                                   requirements.

RCRA Regulations for       40 CFR 264.111          Standards for closure and final     Relevant and appropriate for          Will be attained. Final cover will
Hazardous Waste            40 CFR 264.117          cover of hazardous waste            capping and post-capping              meet standards in 264.310(a) for
Management/Disposal        40 CFR 264.310(a)       landfills. Also, requirements for   monitoring and maintenance of         cover design/construction. Post-
Facilities (Landfill       40 CFR 264.310(b)(l)&   post-closure monitoring and         Consolidation Area to the extent it   closure monitoring and
Closure and Post-Closure   (5)                     maintenance. Does not include       already contains materials that       maintenance will be conducted in
Care)                                              leachate collection and liner       constitute hazardous waste.           accordance with Sections 8 and 9
                                                   requirements.                                                             of Work Plan and will meet
                                                                                                                             requirements of 264.310(b)(l) &
                                                                                                                             (5).




                                                                     -2­
                                                                TABLE 1

                                                  ARARs for Hill 78 Consolidation Area

      Regulation                  Citation                Requirements            Applicability/Appropriateness        Determination Re Attainment

Federal ARARs (cont'd)

RCRA Regulations for      40 CFR 264, Subpart F   Regulated units must monitor   Relevant and appropriate to the      Groundwater monitoring by
Hazardous Waste                                   groundwater and comply with    extent Consolidation Area already    upgradient and downgradient
Management/Disposal                               groundwater protection         contains materials that constitute   monitoring wells will be
Facilities (Groundwater                           standards; hazardous           hazardous waste.                     conducted in accordance with
Monitoring and                                    constituents that exceed                                            Attachment B to August 12, 1999
Protection)                                       maximum concentration levels                                        Addendum (and any additional
                                                  or alternative concentration                                        addenda) to the Work Plan, as
                                                  levels must be removed or                                           approved or conditionally
                                                  treated.                                                            approved by EPA, and in
                                                                                                                      conjunction with the groundwater
                                                                                                                      monitoring program to be
                                                                                                                      described in Statement of Work
                                                                                                                      for Removal Actions Outside the
                                                                                                                      River (SOW). Criteria for further
                                                                                                                      response actions to meet
                                                                                                                      groundwater protection standards
                                                                                                                      will be as set forth in above-
                                                                                                                      referenced Addendum (and any
                                                                                                                      additional addenda), as approved
                                                                                                                      or conditionally approved by EPA,
                                                                                                                      and in the SOW. To the extent
                                                                                                                      these measures do not meet all
                                                                                                                      requirements in the cited
                                                                                                                      regulations, EPA has determined
                                                                                                                      that attainment is not practicable.




                                                                   -3­
                                                                 TABLE 1


                                                  ARARs for Hill 78 Consolidation Area


      Regulation                  Citation                Requirements                 Applicability/Appropriateness        Determination Re Attainment

State ARARs
Mass. Hazardous Waste      310CMR30.622(5)-(11)   Certain design and operating        Relevant and appropriate to          Will be attained, except that
Management Facility                               standards for hazardous waste       consolidation of waste to the        requirement to have run-on and
Regulations (Landfill                             landfills, including requirements   extent Consolidation Area already    run-off control systems to control
Operation)                                        to have run-on and run-off          contains materials that constitute   100-year storm will be attained
                                                  control systems for 100-year        hazardous waste.                     only to the extent practicable.
                                                  storm, manage stormwater
                                                  control systems, apply cover if
                                                  landfill contains particulate
                                                  matter subject to wind dispersal,
                                                  control migration of harmful
                                                  emissions, maintain access
                                                  roads, and use channeling
                                                  devices to prevent run-off that
                                                  could interfere with natural
                                                  drainage of adjacent lands.
                                                  These standards do not include
                                                  liner and leachate collection
                                                  requirements.                 ^^
Mass. Hazardous Waste      310 CMR 30.582         Standards for closure and final     Relevant and appropriate to the      Will be attained. Final cover will
Management Facility        310 CMR 30.592         cover of hazardous waste            extent Consolidation Area already    meet standards in 30.633(1) for
Regulations (Landfill      310 CMR 30.633(1)      landfills. Also, requirements for   contains materials that constitute   cover design/construction. Post-
Closure and Post-Closure   310CMR30.633(2)(a)&    post-closure monitoring and         hazardous waste.                     closure monitoring and
Care)                      (e)                    maintenance. Does not include                                            maintenance will be conducted in
                                                  leachate collection and liner                                            accordance with Sections 8 and 9
                                                  requirements.                                                            of Work Plan and will meet
                                                                                                                           requirements of 30.633(2)(a) &
                                                                                                                           (e).




                                                                    -4­
                                                           TABLE 1

                                            ARARs for Hill 78 Consolidation Area

      Regulation                 Citation           Requirements               Applicability/Appropriateness         Determination Re Attainment
State ARARS (cont'd)
Mass. Hazardous Waste     310 CMR 30.672    Regulated units must monitor      Relevant and appropriate to the       Groundwater monitoring by
Management Facility                         groundwater and comply with       extent that Consolidation Area        upgradient and downgradient
Regulations                                 groundwater protection            already contains materials that       monitoring wells will be
(Groundwater Monitoring                     standards; hazardous              constitute hazardous waste.           conducted in accordance with
and Protection)                             constituents that exceed                                                Attachment B to the August 12,
                                            maximum concentration levels                                            1999 Addendum (and any
                                            or alternative concentration                                            additional addenda) to the Work
                                            levels in groundwater must be                                           Plan, as approved or conditionally
                                            removed or treated.                                                     approved by EPA, and in
                                                                                                                    conjunction with the groundwater
                                                                                                                    monitoring program to be
                                                                                                                    described in the SOW. Criteria for
                                                                                                                    further response actions to meet
                                                                                                                    groundwater protection standards
                                                                                                                    will be as set forth in above-
                                                                                                                    referenced Addendum (and any
                                                                                                                    additional addenda), as approved
                                                                                                                    or conditionally approved by EPA,
                                                                                                                    and in the SOW. To the extent
                                                                                                                    these measures do not meet all
                                                                                                                    requirements in the cited
                                                                                                                    regulation, EPA has determined
                                                                                                                    that attainment is not practicable.
Mass. Air Pollution       310 CMR 7.09      Prohibition against creating      Applicable to construction and site   Will be attained by implementing
Control Requirements                        condition of air pollution in     alteration activities generating      dust control measures and air
                                            connection with dust generating   dust.                                 monitoring in accordance with
                                            activities.                                                             Sections 6.7 and 6.10 of Work
                                                                                                                    Plan and with the August 12, 1999
                                                                                                                    Addendum (and any additional
                                                                                                                    addenda) to the Work Plan, as
                                                                                                                    approved or conditionally
                                                                                                                    approved by EPA.

F:\GE\ARAR\ARARl\Hill78chartwpd


                                                             -5­
                                                                          TABLE 2

                                                         ARARs for Building 71 Consolidation Area
                                              and Potential Consolidation Area at New York Ave./Merrill Road




       Regulation                  Citation                      Requirements                  Applicability/Appropriateness       Determination Re Attainment

Federal ARARs

TSCA Regulations (PCB      40CFR761.61               Establishes disposal options for PCB      Applicable to disposal of PCB      Will be attained based on EPA
Remediation Waste)                                   remediation waste, including PCB-         remediation waste, which           finding that construction and use
                                                     contaminated soils and sediments.         includes soils and sediments at    of these on-plant consolidation
                                                     Options include risk-based approval by    concentrations > 50 ppm PCBs       areas per Work Plan will not pose
                                                     EPA. Parties seeking risk-based           that were contaminated prior to    an unreasonable risk of injury to
                                                     approval must demonstrate that method     April 18, 1978 and any PCB         health or the environment.
                                                     will not pose an unreasonable risk of     waste contaminated after that
                                                     injury to health or the environment.      date where the original source
                                                                                               was > 500 ppm beginning on
                                                                                               April 18, 1978, or > 50 ppm
                                                                                               beginning on July 2, 1979.

TSCA Regulations           40CFR761.79               Establishes decontamination standards     Applicable to decontamination      Will be attained by implementing
(Decontam ination)                                   and procedures for removing PCBs          of equipment used in               equipment cleaning procedures in
                                                     from non-porous surfaces.                 consolidation activities.          accordance with Section 6.15 of
                                                                                                                                  Work Plan.

RCRA Regulations for       40 CFR 264, Subpart C     Various requirements for design and       Relevant and appropriate to        Will be attained. Operation of on-
Hazardous Waste                                      operation of a hazardous waste facility   consolidation of hazardous         plant consolidation areas will
Management/Disposal                                  to minimize possibility of fire,          waste (if any) in these on-plant   comply with Section 6.17 of Work
Facilities (Preparedness                             explosion, or sudden release.             consolidation areas.               Plan and with the Health, Safety,
and Prevention)                                                                                                                   and Contingency Plan that will be
                                                                                                                                  prepared by the contractor selected
                                                                                                                                  to perform the project.




                                                                             -1­
                                                                          TABLE 2

                                                         ARARs for Building 71 Consolidation Area
                                              and Potential Consolidation Area at New York Ave./Merrill Road



       Regulation                Citation                        Requirements                   Applicability/Appropriateness       Determination Re Attainment

Federal ARARs (cont'd)

RCRA Regulations         40 CFR 264.13-. 19          Various requirements relating to waste     Relevant and appropriate to        Will be attained. On-plant
Hazardous Waste                                      analysis, security, inspections,           consolidation of hazardous         consolidation areas will be
Management/Disposal                                  personnel training, precautions to         waste (if any) in these on-plant   operated in accordance with
Facilities (General)                                 prevent accidental ignition or reaction    consolidation areas.               Section 6.2 and Appendix C of
                                                     of wastes, location standards, and                                            Work Plan and with the Health,
                                                     construction quality assurance                                                Safety, and Contingency Plan that
                                                     program.                                                                      will be prepared by contractor
                                                                                                                                   selected to perform the project.

RCRA Regulations         40 CFR 264.30l(g)-(j)       Certain design and operating standards     Relevant and appropriate to        Will be attained.
Hazardous Waste                                      for hazardous waste landfills, including   consolidation of hazardous
Management/Disposal                                  requirements to have run-on and run­       waste (if any) in these on-plant
Facilities (Landfill                                 off control systems for 25-year storm,     consolidation areas.
Operation)                                           manage stormwater control systems,
                                                     and apply cover if landfill contains
                                                     particulate matter subject to wind
                                                     dispersal. These standards do not
                                                     include liner and leachate collection
                                                     requirements.




                                                                             -2­
                                                                           TABLE 2

                                                          ARARs for Building 71 Consolidation Area
                                               and Potential Consolidation Area at New York Ave./Merrill Road



       Regulation                  Citation                       Requirements                   Applicability/Appropriateness        Determination Re Attainment

Federal ARARs (cont'd)

RCRA Regulations for       40 CFR 264.111             Standards for closure and final cover of   Relevant and appropriate to         Will be attained. Final covers will
Hazardous Waste            40CFR264.117               hazardous waste landfills. Also,           closure and post-closure care of    meet standards in 264.310(a) for
Management/Disposal        40 CFR 264.310(a)          requirements for post-closure              these on-plant consolidation        cover design/construction. Post-
Facilities (Landfill       40 CFR 264.310(b)(l)&      monitoring and maintenance. Does not       areas.                              closure monitoring and
Closure and Post-Closure   (5)                        include leachate collection and liner                                          maintenance will be conducted in
Care)                                                 requirements.                                                                  accordance with Sections 8 and 9
                                                                                                                                     of Work Plan and will meet
                                                                                                                                     requirements of 264.310(b)(l) &
                                                                                                                                     (5). Although not required by the
                                                                                                                                     ARAR, GE will install a liner and
                                                                                                                                     leachate collection system at these
                                                                                                                                     consolidation areas as described in
                                                                                                                                     the Work Plan.

RCRA Hazardous Waste       40 CFR 264, Subparts I     Subparts I and J of Part 264 identify      Relevant and appropriate to         Will be attained. Leachate
Regulations (Storage of    and J                      design, operating, monitoring, closure,    storage of leachate collected       collected may be stored
Hazardous Waste)           40 CFR 262.34(a)           and post-closure care requirements for     prior to treatment, to the extent   temporarily for 90 days or less in
                                                      long-term storage of RCRA hazardous        that leachate is a hazardous        tanker trucks that will meet the
                                                      waste in containers and tank systems,      waste.                              standards for up to 90-day
                                                      respectively. However, 262.34(a)                                               accumulation in containers.
                                                      allows accumulation of RCRA                                                    Alternatively, leachate will be
                                                      hazardous wastes for up to 90 days in                                          stored in containers or tanks that
                                                      containers or tanks provided generator                                         will meet requirements for long-
                                                      complies with requirements of                                                  term storage.
                                                      Subparts I and J of Part 265 for
                                                      containers and tanks.




                                                                              -3­
                                                                         TABLE 2

                                                       ARARs for Building 71 Consolidation Area
                                             and Potential Consolidation Area at New York Ave./Merrill Road


       Regulation                 Citation                      Requirements              Applicability/Appropriateness       Determination Re Attainment
Federal ARARs (cont'd)
RCRA Regulations for      40 CFR 264, Subpart F     Regulated units must monitor          Relevant and appropriate to        Groundwater monitoring by
Hazardous Waste                                     groundwater and comply with           consolidation of hazardous         upgradient and downgradient
Management/Disposal                                 groundwater protection standards;     waste (if any) in these on-plant   monitoring wells will be
Facilities (Groundwater                             hazardous constituents that exceed    consolidation areas.               conducted in accordance with
Monitoring and                                      maximum concentration levels or                                          Attachment B to the August 12,
Protection)                                         alternative concentration levels in                                      1999 Addendum (and any
                                                    groundwater must be removed or                                           additional addenda) to the Work
                                                    treated.                                                                 Plan, as approved or conditionally
                                                                                                                             approved by EPA, and in
                                                                                                                             conjunction with the groundwater
                                                                                                                             monitoring program to be
                                                                                                                             described in Statement of Work
                                                                                                                             for Removal Actions Outside the
                                                                                                                             River (SOW). Criteria for further
                                                                                                                             response actions to meet
                                                                                                                             groundwater protection standards
                                                                                                                             will be as set forth in above-
                                                                                                                             referenced Addendum (and any
                                                                                                                             additional addenda), as approved
                                                                                                                             or conditionally approved by EPA,
                                                                                                                             and in the SOW. To the extent
                                                                                                                             these measures do not meet all
                                                                                                                             requirements in the cited
                                                                                                                             regulations, EPA has determined
                                                                                                                             that attainment is not practicable.




                                                                            -4­
                                                                          TABLE 2

                                                       ARARs for Building 71 Consolidation Area
                                             and Potential Consolidation Area at New York Ave./Merrill Road



       Regulation                 Citation                      Requirements                    Applicability/Appropriateness    Determination Re Attainment

Federal ARARs (cont'd)

Clean Water Act NPDES     40CFR122.26(c)(ii)(C)     Discharges of stormwater associated         Applicable to discharges of     Will be attained by implementing
Regulations (Stormwater   40CFR 122.44(k)           with construction activities are            stormwater.                     erosion and sedimentation controls
Discharges)               40CFR 125.1 00-. 104      required to implement best                                                  and stormwater management
                                                    management practices to control                                             measures in accordance with
                                                    pollutants in stormwater discharges                                         Sections 4.7, 5.9, 6.1 1, and 6.13 of
                                                    during and after construction activities.                                   Work Plan.

State ARARs
Mass. Hazardous Waste     310 CMR 30.513-30.516     Various requirements relating to waste      Relevant and appropriate to     Will be attained. On-plant
Management Facility                                 analysis, security, inspections, and        consolidation of hazardous      consolidation areas will be
Regulations (General)                               personnel training.                         waste in these on-plant         operated in accordance with
                                                                                                consolidation areas.            Section 6.2 of Work Plan and the
                                                                                                                                Health, Safety, and Contingency
                                                                                                                                Plan that will be prepared by the
                                                                                                                                contractor selected to perform the
                                                                                                                                project.




                                                                             -5­
                                                                      TABLE 2

                                                     ARARs for Building 71 Consolidation Area
                                          and Potential Consolidation Area at New York Ave./Merrill Road



      Regulation               Citation                      Requirements                   Applicability/Appropriateness    Determination Re Attainment
State ARARs (cont'd)
Mass. Hazardous Waste   310CMR30.622(5)-(11)     Certain design and operating standards     Relevant and appropriate to     Will be attained, except that
Management Facility                              for hazardous waste landfills, including   consolidation of hazardous      requirement to have run-on and
Regulations (Landfill                            requirements to have run-on and run-       waste in these on-plant         run-off control systems to control
Operation)                                       off control systems for 100-year storm,    consolidation areas.            100-year storm will be attained
                                                 manage stormwater control systems,                                         only to the extent practicable.
                                                 apply cover if landfill contains
                                                 participate matter subject to wind
                                                 dispersal, control migration of harmful
                                                 emissions, maintain access roads, and
                                                 use channeling devices to prevent run­
                                                 off that could interfere with natural
                                                 drainage of adjacent lands. These
                                                 standards do not include liner and
                                                 leachate collection requirements.
Mass. Hazardous Waste   310 CMR 30.560           Various requirements relating to           Relevant and appropriate to     Will be attained. On-plant
Management Facility                              precautions to prevent accidental          consolidation of hazardous      consolidation areas will be
Regulations                                      ignition or reaction of wastes.            waste in these on-plant         operated in accordance with the
(Ignition/Reaction)                                                                         consolidation areas.            Health, Safety, and Contingency
                                                                                                                            Plan that will be prepared by the
                                                                                                                            contractor selected to perform the
                                                                                                                            project.




                                                                         -6­
                                                                         TABLE 2

                                                       ARARs for Building 71 Consolidation Area
                                             and Potential Consolidation Area at New York Ave./Merrill Road



       Regulation                 Citation                      Requirements                   Applicability/Appropriateness    Determination Re Attainment
State ARARs (cont'd)
Mass. Hazardous Waste      310 CMR 30.582           Standards for closure and final cover of   Relevant and appropriate to     Will be attained. Final covers will
Management Facility        310 CMR 30.592           hazardous waste landfills. Also,           consolidation of hazardous      meet standards in 30.633(1) for
Regulations (Landfill      310 CMR 30.633(1)        requirements for post-closure              waste in these on-plant         cover design and construction.
Closure and Post-Closure   310CMR30.633(2)(a)&      monitoring and maintenance. Does not       consolidation areas.            Post-closure monitoring and
Care)                      (e)                      include leachate collection and liner                                      maintenance will be conducted in
                                                    requirements.                                                              accordance with Sections 8 and 9
                                                                                                                               of Work Plan and will meet
                                                                                                                               requirements of 30.633(2)(a) &
                                                                                                                               (e). Although not required by the
                                                                                                                               ARAR, GE will install a liner and
                                                                                                                               leachate collection system at these
                                                                                                                               consolidation areas as described in
                                                                                                                               the Work Plan.




                                                                            -7­
                                                                         TABLE 2

                                                        ARARs for Building 71 Consolidation Area
                                             and Potential Consolidation Area at New York Ave./Merrill Road



       Regulation                 Citation                      Requirements              Applicability/Appropriateness    Determination Re Attainment
State ARARs (cont'd)
Mass. Hazardous Waste      310 CMR 30.672           Regulated units must monitor          Relevant and appropriate to     Groundwater monitoring by
Management Facility                                 groundwater and comply with           consolidation of hazardous      upgradient and downgradient
Regulations (Groundwater                            groundwater protection standards;     waste in these on-plant         monitoring wells will be
Monitoring and                                      hazardous constituents that exceed    consolidation areas.            conducted in accordance with
Protection)                                         maximum concentration levels or                                       Attachment B to the August 12,
                                                    alternative concentration levels in                                   1999 Addendum (and any
                                                    groundwater must be removed or                                        additional addenda) to the Work
                                                    treated.                                                              Plan, as approved or conditionally
                                                                                                                          approved by EPA, and in
                                                                                                                          conjunction with the groundwater
                                                                                                                          monitoring program to be
                                                                                                                          described in SOW. Criteria for
                                                                                                                          further response actions to meet
                                                                                                                          groundwater protection standards
                                                                                                                          will be as set forth in above-
                                                                                                                          referenced Addendum (and any
                                                                                                                          additional addenda) to the Work
                                                                                                                          Plan, as approved or conditionally
                                                                                                                          approved by EPA, and in the
                                                                                                                          SOW. To the extent these
                                                                                                                          measures do not meet all
                                                                                                                          requirements in the cited
                                                                                                                          regulation, EPA has determined
                                                                                                                          that attainment is not practicable.




                                                                            -8­
                                                                         TABLE 2

                                                        ARARs for Building 71 Consolidation Area
                                             and Potential Consolidation Area at New York Ave./Merrill Road



        Regulation                Citation                      Requirements                   Applicability/Appropriateness      Determination Re Attainment

 State ARARs (cont'd)

 Mass. Hazardous Waste     310 CMR 30.680, 30.690   30.680 and 30.690 identify                 Relevant and appropriate to       See discussion of federal RCRA
 Regulations (Storage of   310 CMR 30.340           requirements for long-term storage of      accumulation and storage of       Hazardous Waste Regulations
 Hazardous Waste)                                   RCRA hazardous waste in containers         leachate prior to treatment, to   (Storage of Hazardous Waste)
                                                    and tank systems, respectively, that are   the extent that leachate is       above.
                                                    similar to federal RCRA storage            considered a hazardous waste.
                                                    requirements identified above. 30.340
                                                    allows on-site accumulation of
                                                    hazardous waste by generator for up to
                                                    90 days in containers and tanks
                                                    provided that generator complies with
                                                    certain container and tank standards,
                                                    and is also similar to federal RCRA
                                                    storage requirements identified above.

 Mass. Air Pollution       310 CMR 7.09             Prohibition against creating condition     Applicable to construction and    Will be attained by implementing
 Control Requirements                               of air pollution in connection with        site alteration activities        dust control measures and air
                                                    dust-generating activities.                generating dust.                  monitoring in accordance with
                                                                                                                                 Sections 6.7 and 6.10 of Work
                                                                                                                                 Plan and with the August 12, 1999
                                                                                                                                 Addendum (and any additional
                                                                                                                                 addenda) to the Work Plan, as
                                                                                                                                 approved or conditionally
                                                                                                                                 approved by EPA.



F:\GE\ARAR\ARARl\Building71 chart.wpd




                                                                            -9­