PB97-963101
                             EPA/541/R-97/003
                             November 1997
EPA  Superfund
      Record of Decision Amendment:
      Auburn Road Landfill,
      Londonderry, NH
      12/19/1996

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                UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
                                    REGION I
                        JOHN F. KENNEDY FEDERAL BUILDING
                       BOSTON, MASSACHUSETTS 02203-0001
       DECLARATION FOR THE AMENDED RECORD OF DECISION

                              Auburn Road Landfill
                          Londonderry, New Hampshire

STATEMENT OF PURPOSE

This Decision Document amends the selected remedial action for the Auburn Road Landfill
Superfund Site in Londonderry, New Hampshire, as outlined in the September 29, 1989 Record
of Decision, and is developed in accordance with the Comprehensive Environmental Response,
Compensation and Liability Act of 1980 (CERCLA), as amended by the Superfund Amendments
and Reauthorization Act of 1986 (SARA), the National Oil and Hazardous Substances
Contingency Plan (NCP), and 40 CFR Part 300 et seq.. as amended. The Region I Administrator
has been delegated the authority to approve this Record of Decision (ROD)

The State of New Hampshire concurs with the  selected remedy

STATEMENT OF BASIS

This decision is based on the administrative record which has been developed in accordance with
Section 113 (k) of CERCLA and which is available for public review at the Leach Public Library
in Londonderry, New Hampshire and at the Region I Waste Management Division Records
Center at 90 Canal Street, Boston, Massachusetts. The Administrative Record Index (Appendix
F to the ROD) identifies the items which comprise the Administrative Record upon which the
selection of the remedial action is based.

ASSESSMENT OF THE SITE

Hazardous substances have been released, or there is a substantial threat of release, into the
environment. Response actions are necessary to protect public health, welfare, or the
environment. Actual or threatened releases of hazardous substances from this Site, if not
addressed by implementing the response action selected in this ROD, may present an imminent
and substantial endangerment to the public health or welfare or to the environment.

DESCRIPTION OF THE SELECTED REMEDY

This Decision Document amends a portion of EPA's 1989 Record of Decision  The 1989 ROD
selected ground water pump and treat to restore ground water at the site This amendment is
based on information developed since 1989 that shows that the majority of the contaminants are
below the 1989 cleanup levels and those that remain will attain cleanup levels within a reasonable
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reasonable time frame. The selected remedy for the Auburn Road Landfill Superfund Site will
utilize natural attenuation of contaminants in ground water to obtain a comprehensive remedy.

The management of migration remedial measures include:

             the restoration of ground water through natural attenuation;

             the development and implementation of a revised ground water, surface water,
             sediment and air sampling program;

             the establishment of a Groundwater Management Zone, within which ground
             water will be restored;

             the establishment of institutional controls to notify and prevent residents from
             using contaminated ground water in the overburden and bedrock aquifers;

             the continued  maintenance of the landfill caps and drainage system to restrict
             ground water movement through the disposal areas to the greatest degree possible;
             and

             a review of site conditions every five years.

DECLARATION

The selected remedy is protective of human health and the environment, attains Federal and State
requirements that are applicable or relevant and appropriate for this remedial action, and is  cost-
effective.  The comprehensive remedy for the site, including the capping of the landfills and the
drainage improvements completed under the 1989 Record of Decision, satisfies the statutory
preference for remedies that utilize treatment as a principal element to reduce the toxicity,
mobility, or volume of hazardous substances.  In addition, this remedy utilizes permanent
solutions and alternative treatment technologies to the maximum extent practicable.

As this remedy will result in hazardous substances remaining on-site above health based levels, a
review will be conducted within five years after commencement of remedial action to ensure that
the remedy continues to provide adequate protection of human Health and the environment.
 '  I 'I*                              *s^isi<°~^*s ' '' '' ~'"yfi^j
    Date                                 Linda M. Murphy   /
                                         Director
                                         Office of Site Remediation & Restoration

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       AMENDED
RECORD OF DECISION
           For the
    AUBURN ROAD LANDFILL

       LONDONDERRY,
       NEW HAMPSHIRE

        December 19, 1996

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        AUBURN ROAD LANDFILL SUPERFUND SITE
              AMENDED RECORD OF DECISION

                     TABLE OF CONTENTS
I.    SITE NAME, LOCATION, RATIONALE FOR AMENDMENT & DESCRIPTION  . . 1
               FIGURE 1, Site Location	2
               FIGURE 2, Site Features 	5
               FIGURE 2A, Site Detail	6
               FIGURE 3, Geology & Hydrogeology 	9

II.    SITE HISTORY AND ENFORCEMENT ACTIVITIES	10
     A.    Land Use and Response History	10
     B.    Enforcement History	12

III    COMMUNITY PARTICIPATION 	13

IV    SCOPE AND ROLE OF OPERABLE UNIT OR RESPONSE ACTION           15

V.    SUMMARY OF SITE CHARACTERISTICS	17
     A.    Soil and Sediment	17
               FIGURE 4, Sediment Contamination 	19
     B.    Ground Water 	20
               FIGURE 5, Ground water contamination	22
     C.    Surface Water 	23
               FIGURE 6, Surface Water Sampling Locations	24
     D.    Air  	25

VI.   SUMMARY OF SITE RISKS	25
     A.    Risk to Human Health 	25
               TABLE 1 - COMPARISON OF 1984 TO 1995 DATA 	27
               TABLE 2 - CARCINOGENIC RISKS FOR THE POSSIBLE FUTURE
                    INGESTION OF GROUND WATER INSIDE THE PROPERTY
                    LINE	30
               TABLE 3 - CARCINOGENIC RISKS FOR THE POSSIBLE FUTURE
                    INGESTION OF GROUND WATER OUTSIDE THE
                    PROPERTY LINE	31
               TABLE 4 - NON-CARCINOGENIC RISKS FOR THE POSSIBLE
                    FUTURE INGESTION OF GROUND WATER INSIDE THE
                    PROPERTY LINE 	31
               TABLE 5 - CARCINOGENIC RISKS FOR CURRENT WADING AND
                    INCIDENTAL INGESTION OF SEDIMENT             32
               Summary of Human Health Risks	        32

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      B.     Ecological Risk  	33
      C.     Site Risk Summary	               34

VII.   DEVELOPMENT AND SCREENING OF ALTERNATIVES  	34
      A.     Statutory Requirements/Response Objectives	34
      B.     Technology and Alternative Development and Screening  	35

VIII.  DESCRIPTION OF ALTERNATIVES	37

IX.    SUMMARY OF THE COMPARATIVE ANALYSIS OF ALTERNATIVES 	42

X.    THE SELECTED REMEDY	50
      A.     Interim Cleanup Levels	50
                  TABLE 6 - INTERIM CLEANUP LEVELS IN GROUND WATER   54
      B.     Description of Remedial Components	55

XI.    STATUTORY DETERMINATIONS  	  60
      A.     The Selected Remedy is Protective of Human Health and the Environment     60
      B.     The Selected Remedy Attains ARARs  	61
      C.     The Selected Remedial Action is Cost-Effective	      .  65
      D.     The Selected Remedy Utilizes Permanent Solutions and Alternative Treatment or
            Resource Recovery Technologies to the Maximum Extent Practicable  	65
      E.     The Selected Remedy Satisfies the Preference for Treatment Which Permanently
            and Significantly reduces the Toxicity, Mobility or Volume of the Hazardous
            Substances as a Principal Element	66

XII.   DOCUMENTATION OF NO SIGNIFICANT CHANGES  	67

XIII. STATE ROLE	68

LIST OF APPENDICES

APPENDIX A - State of New Hampshire Letter of Concurrence
APPENDIX B - Applicable and Relevant and Appropriate Requirements (ARARs)
APPENDDC C - Screening and Comparison of Remedial Alternatives
APPENDK D - Results of Arsenic and Sediment Investigation
APPENDIX E - Responsiveness Summary
APPENDDC F - Administrative Record Index

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                    AUBURN ROAD LANDFILL
         AMENDED RECORD OF DECISION SUMMARY
                           December 19, 1996
I.    SITE NAME, LOCATION, RATIONALE FOR AMENDMENT &
     SITE DESCRIPTION

SITE NAME:  Auburn Road Landfill.

SITE LOCATION: Town of Londonderry, Rockingham County, New Hampshire.

RATIONALE  FOR AMENDMENT:  The 1989 Record of Decision (ROD)
directed the construction of a pump and treat facility to recover and treat ground
water contaminated with Volatile Organic Compounds (VOCs).  Natural attenuation
since 1989 has reduced the concentration of VOCs to below cleanup levels set in
that ROD, except in one well that directly abuts the landfilled area.

     The 1989 ROD is being amended by this document to reflect the changed
conditions at the Site. The contamination that remains is ground water contaminated
above cleanup levels with arsenic.  The landfilled areas were capped in 1994,
greatly reducing the infiltration of water through contaminated areas.  Ground water
modeling has demonstrated that the cleanup levels for arsenic will be attained
outside the landfilled areas five years after capping the landfilled areas. In addition,
cleanup levels for VOCs, including the one well directly adjacent to the landfill, will
be attained.

     This Amended Record of Decision changes the ground water remedy from
pumping and treating contaminated ground water to monitoring natural attenuation
at the Site. Institutional controls will also be implemented to ensure protection of
public health.

SITE DESCRIPTION: The Auburn Road Landfill site ("the site") is located in
the northeast corner of the Town of Londonderry, New Hampshire. It consists of
three, approximately four-acre disposal areas that received a mix of domestic wastes
and various hazardous wastes until it was closed in 1980. The area is served by
municipal water and the landfills were capped with RCRA-type C caps in 1994

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AUBURN  ROAD  LANDFILL
AMENDED RECORD OF  DECISION
                                         FIGURE 1.  SITE LOCATION
                                               The map at left shows the regional
                                         location of the Site.  The map below shows a
                                         more detailed map of the site, the property
                                         bounds, the landfilled areas, Whispering Pines
                                         Pond (directly above the property line), and
                                         Cohas Brook.
                                                               "  A   :
                                               Landfilled Areas [      ^

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AUBURN ROAD LANDFILL
AMENDED RECORD OF DECISION
      The landfill lies in Londonderry, close to the borders of the Towns of Auburn
and Deny, New Hampshire. The area surrounding the site is zoned for light
residential and business use. Consistent with zoning, the area to the west and north
of the site consists of light, rural, residential use and a gravel removal business.  To
the east is a large, undeveloped area that eventually gives way to light residential
and business use in the vicinity of the Route 28 Bypass.  To the south is more light
residential use and a gravel operation. Figure 1, on the following page, shows the
location of the site.

      The site is approximately bounded by Auburn  Road to the west, Old Deny
Road to the south, State Highway 28 Bypass to the east, and the Londonderry-
Auburn town line to the north. A number of houses surround the site. The site is
located in a rural-residential area with approximately 300 homes and a trailer park
with approximately 260 units within 1 mile of the site. In response to an EPA
Record of Decision, the Town of Londonderry installed a water main on Auburn
Road to provide municipal drinking water to potentially exposed residents and the
trailer park.1  No one is drinking ground water contaminated by the site.

      The site consists of 200 acres that slopes gently downward from south to
north.  The southern portion of the site is approximately 330 feet above  sea level.
The terrain is gentle, falling to roughly 270 feet above sea level over a distance of
approximately 2,000 feet.  However, because this area was also formerly a gravel
mining operation, some locally steep banks and disturbed areas are present. Gravel
removal occurred in several locations at the site; however, the largest portion of the
operation was in the north, in close proximity to the landfilling operations.  Much of
the mined out, disturbed areas contain no vegetation  because only sand was left. In
undisturbed areas that surround the site, including along Auburn Road, are stands of
varying ages of White Pine and many hardwoods such as Poplar.

       Although the site property  consists of approximately 200 acres, the three
disposal areas occupy only a total of 13 acres. The disposal areas consist of what
are now three landfilled  areas that have a top cover and no baseliner. The cover is a
modified RCRA C cap, roughly four feet thick, with a geotextile impermeable
      1  Auburn  Road  Record  of Decision,  U.S.  Environmental
 Protection Agency,  September 17,  1986.

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AUBURN ROAD LANDFILL
AMENDED RECORD OF DECISION
membrane, a clay liner, and a vegetated (grass) cap.  Formerly a septage disposal
area existed to the north of the solid waste dump (listed as area "3" on Figure 1);
however, the town excavated that area and disposed of it in the solid waste area in
1993. The landfills and the surrounding area are shown on Figure 2. The landfilled
areas total 13 acres and each is roughly four acres in size.  Northern-most of the
disposal areas is the "Old Town Dump."  The Old Town Dump is the oldest of the
disposal areas and the refuse is roughly eight to fifteen feet in thickness. The Tire
Pile and the Solid Waste Landfill occupy the southern portion of the site. The "Tire
Pile" was so named because of the large amount of tires disposed of in this area.
The Tire Pile is  slightly larger than the Town Dump;  however, it is just slightly
thicker, ten to twenty feet in depth.  The Solid Waste Landfill appears to be much
thicker; however, that is due to landfilling on an existing hill, and is only eight to ten
feet thick.

      Surface waters at the site flow between the landfilled areas and lie to the east
and north of the disposal areas. Whispering Pines Pond lies, in part, on the northern
boundary of the site and accepts all surface water flows from the site. The wetland
area to the east is actually a stream, periodically dammed by beavers, that  empties
into Whispering Pines pond. A seven acre wetland and drainage structures were
created in the area between the Solid Waste landfill and the Tire Dump by the Town
in order to replace affected wetlands and lower the water table in the area  of the
landfills. The wetland area and drainage structures flow northward to Whispering
Pines Pond.  None of the disposal areas lie within the 100-year floodplain  of any
stream although the Old  Town Dump lies very close  to the 100-year floodplain of
the Pond.

      Whispering Pines Pond is formed by a concrete dam at the northwest comer
of the Pond.  The stream that flows from the Whispering Pines Pond runs a short
distance before  discharging to Cohas brook, a few hundred feet to the north. Cohas
Brook drains an area of roughly eleven square miles  and is a tributary of the
Merrimack River. The confluence of Cohas brook and the Merrimack River lies
roughly 8 miles to the west, in the city of Manchester. On the next pages Figure 2
shows the site and the surrounding topography, Figure 2a shows the site with only
the pertinent features highlighted.

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AUBURN ROAD LANDFILL
AMENDED RECORD OF DECISION
            0
            Derry,NH
            Quadrangle
            Photo revised:
               1974
             1 inch =
             1,400 feet
            (Approximately)
                                        ..      .          f
                              .          Wetland repIicati6n;aireas i"
                              > i  ...;::•'' r ->Bsi.  ;     •'-    •    \   \   v
                                  '  '   '     '    *'           :    •'   '        '
    FIGURE 2, SITE AND SURROUNDING FEATURES. Site features are displayed on a
    USGS topographic map. The site features that have been added include the three disposal
    areas shown in orange, the wetland replication area, and the location of a residential area
    that was not present at the time the map was updated.  Waterbodies may also not be
    depicted accurately due to filling and other alterations associated with time and landfill
    construction.  The three disposal areas consist of the Town Dump (1), the Tire Dump (2),
    and the Solid Waste Landfill (3). Each disposal area covers roughly four acres. The
    wetland replication area totals seven acres. On-site surface water flows to the north to
    Whispering Pines Pond and then into Cohas brook which flows approximately eight miles
    eastward to the Merrimack River.

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AUBURN ROAD LANDFILL
AMENDED RECORD OF DECISION
   FIGURE 2 A. SITE DETAIL.. This map shows the pertinent portions of the site and the
   remedy. Already constructed are the caps, shown in the checkerboard pattern, the drainage
   swales to keep the landfill dewaterered, shown in a blue dashed line, and the wetland
   replication area.  The septage lagoon was excavated and placed in the Solid Waste Landfill.

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AUBURN ROAD LANDFILL
AMENDED RECORD  OF DECISION
      The general geology at the site is typical of New England, glacial deposits
overlying a bedrock surface. The glacial deposits may be further divided into thick
outwash deposits of sand and gravel that overlie a thin, discontinuous till unit. The
sands and gravels were reworked by glacial streams to create well-graded deposits
and range in thickness from 0 feet in the southern part of the site to 75 feet to the
north of the site in the vicinity of Whispering Pines Pond.  The till varies from 0 to
20 feet and contains sand, gravel, silt, and clay. Figure 3 shows two cross-sections
taken from the lines indicated on the plan.

      Ground water at this site is divided into two units: the bedrock aquifer and the
overburden aquifer. The overburden aquifer includes the outwash deposits and the
till aquifer. Ground water flow within the overburden aquifer is to the north.
Whispering Pines Pond receives some ground water from localized recharge;
however, the majority of ground water from the site discharges to Cohas Brook.
Hydraulic conductivities within wells  in both the outwash deposits and the till vary
from 0.1 to 140 feet per day.

      The bedrock underlying the site consists of foliated chlorite/biotite schists and
phyllites.  The tendency of these rocks, in this terrain is to develop orthagonal faults
and joints with a distinct orientation that may be conducive to ground water flow.
Fractures in bedrock at the site have a definite northeast-southwest and northwest-
southeast trend.  A steep zone of faulting parallels Auburn Road and is oriented in a
north northeast-south southwest direction. This fault, indicated by a thick zone  of
mylonite, was encountered in the drilling of wells R-l and R-2.  This fault does  not
appear to transmit ground water either along its strike or westward of its strike due
to either mylonite formation, or healing through silicification.2 Fractures east of this
fault, underlying the site, are oriented further clockwise from the Auburn Road Fault
and  exhibit a northeast strike and a southeast dip of between 50 and 70 degrees. A
small set of fractures run perpendicular to the northeast striking set although the dip
appears to be indeterminate.3
       2      Carol White, Sevee &  Mahar,  verbal communication with
 Darryl  Luce,  June  1995.

       3      Auburn Road Landfill  Remedial  Investigation  Report,
 NUS Corporation, April  10,  1986.

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AUBURN ROAD LANDFILL
AMENDED RECORD OF DECISION
      What the information on the bedrock geology implies is that the flow of
contaminated ground water in bedrock is limited to flow within narrow, well-defined
and well-oriented zones that trend roughly northwest-southeast and northeast-
southwest.  Ground water flow within the bedrock aquifer is controlled by the
structural orientation of the fractures. The silicified and mylonitized fault zone
probably serves as a hydraulic barrier between the site and the former residential
wells to the west. Evidence of this was the poor production from wells R-l and R-2
which despite being over 400 feet deep, produce only about 1 gallon per minute.
However, it is likely that the subparallel fractures that lie just to the east, and
directly beneath the site, are conduits of ground water and allow it to migrate
principally to the northeast and northwest in minor amounts.

      The EPA performed a number of investigations in the study area, a more
complete description of the area surrounding the site may be found in Auburn Road
Remedial Investigation Report, NUS Corporation for EPA, April 10, 1986. A
depiction of the general geology is shown in Figure 3 through the use of cross-
sections taken at  right angles through the site.  Ground water flows to the north, or
the top of the page on Figure 3.

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AUBURN ROAD LANDFILL
AMENDED RECORD OF DECISION
FIGURE 3, SITE GEOLOGY.  Two geologic cross-sections tanken at right angles through the
site as shown on the plan view at right. The upper box on the left is the slice B-B' and is as if
the reader were looking northward. The lower box is the slice A-A' and is as if the reader
were looking roughly eastward. No scale is attached because these figures are generalizations.
The depths vary but on-site the Glacial outwash sands are approximately forty to seventy feet
thick. The overall geometry of the bedrock is a narrow trough that points, and deepens, to the
north. A thin layer of glacial till, which consists of clay and rock fragments, lies on the bedrock.
The outwash deposits, made up of sands and gravels,  makes up the general topography and is
mined extensively throughout the area.
     Looking northward
       Glacial Till      Whispering
Bedrock         ggfl Pines Pond
           Glacial outwash
                                 Land filled areas

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AUBURN ROAD LANDFILL                                                10
AMENDED RECORD OF DECISION	

II.    SITE HISTORY AND ENFORCEMENT ACTIVITIES

      A.   Land Use and Response History

      From 1965 until 1980 the site operated as a municipal landfill. In August
1979, an investigation by the State of New Hampshire substantiated suspicions that
industrial wastes were being disposed of on the site and the State ordered that no
more drums be accepted for disposal at the site. Following a Preliminary Site
Assessment, a subsequent hydrologic investigation, and a Hazard Ranking System
(HRS) score of 36.6, the EPA proposed the site for listing on the National Priority
List (NPL) in December 1982. The U.S. Congress formally included the site on the
NPL in September 1983, ranking 383 out of 416 sites nationally at that time

      Since the site has been on the NPL, the EPA and State have generated the
following documents related to the preliminary investigations of the site:

      Auburn Road Remedial Investigation Report, NUS Corporation for USEPA,
      April 10, 1986. Three volumes.

      Auburn Road Landfill Endangermem Assessment, Planning Research
      Corporation for USEPA, July 1986. Two volumes.

      Auburn Road Landfill Site Final Focused Feasibility Study Report, NUS
      Corporation for USEPA, July 8, 1986.

      The above documents resulted in a September 17, 1986 Record Of Decision
that directed the installation of a 9,000 foot water line to supply uncontaminated
drinking water to the residents surrounding the landfill. After the Town installed the
waterline in 1987 and the EPA had removed over 2,000 drums of hazardous wastes
from the site in 1986, the EPA believed that conditions at the Landfill had changed
sufficiently to re-evaluate the site.  The EPA then produced the following documents
at the conclusion of the re-evaluation:

      Supplemental Remedial Investigation Report for the Auburn Road Landfill
      Site, R.F. Weston for USEPA, October 21, 1988. Three volumes.

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AUBURN ROAD  LANDFILL                                                 11
AMENDED RECORD OF DECISION	

      Feasibility Study Report for the Auburn Road Landfill Site, R.F. Weston, Inc.
      for USEPA, March 1989. Two volumes.

      These documents resulted in a September 29,1989 Record of Decision that
directed the construction of a ground water treatment plant to remove metals and
volatile organics from ground water and a cap over the diposal areas to prevent
infiltration through landfilled wastes.  To implement the provisions in the ROD, the
EPA issued an Unilateral Administrative Order to nine respondents on August 31,
1990. That Order directed that the Town of Londonderry would cap the disposal
areas and that a separate group of PRPs would cleanup the contaminated ground
water.  The Town completed construction of the cap over the landfill in 1994.
However, the ground water remedy was not built.

      When the EPA issued the Administrative Order to clean up the ground water
five of the eight respondents formed a Management of Migration group, or MOM
group, and produced the following documents:

      Initial Pre-Design Investigation, Sevee & Maher Engineers, Inc., January
      1992.

      Supplement I Investigation Report, Supplemental Pre-Design Investigation
     for Remediation ofGroundwater, Sevee & Maher Engineers, Inc., January
      1993.

      Supplement II Investigation Report. Supplemental Pre-Design Investigation
     for Remediation ofGroundwater, Sevee & Maher Engineers, Inc., August
      1993.

The sampling that the MOM group performed during these investigations pointed to
the following conclusions:

           that volatile organic compound (VOC) contamination decreased
           significantly from 1986.  In 1991 no VOCs exceeded the 1989 ROD
           cleanup levels beyond the site boundary.

           that arsenic was the only contaminant which exceeded the 1989

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AUBURN ROAD LANDFILL                                                 12
AMENDED RECORD OF DECISION	

            cleanup levels beyond the site boundary.

            that capping the landfills and lowering the water table to prevent
            ground water from percolating through the landfill would be the most
            effective way to reduce arsenic contamination in the ground water.

      The respondents have produced annual monitoring reports for the periods
1993, 1994, and 1995. It appears that VOC contamination continues to decline due
to dilution, biodegradation, and abiotic processes. Arsenic contamination has not
declined. However, the Town finished capping the landfill in 1994, therefore not
enough time has passed to gauge the effectiveness of the cap.

      In response to this information the EPA began to reconsider the ground water
remedy proposed in the 1989 ROD.  In April  1996 the EPA issued the Proposed
Plan for this site outlining a three remedial options and indicating a preference for
the Limited Action remedy.

      B.    Enforcement History

      From 1984 until 1989, the EPA conducted an investigation to identify parties
who are liable for response costs at the site. In this regard, EPA issued
approximately 200 information requests, employed private investigators, conducted
numerous interviews, and reviewed a multitude of records. At various times
throughout the duration of this project, as information became available, parties who
EPA determined either owned or operated the site, generated wastes that were sent
to the site, arranged for disposal of hazardous substances at the site or transported
hazardous substances to the site, were notified of their potential liability with
respect to the Site. To date, 21 parties have been notified.

      On August 31, 1990 the EPA issued an Administrative Order to two groups
of potentially responsible parties to perform the remedies outlined in the 1989
Record of Decision.  The EPA's Order directed the Town of Londonderry to
perform the Source Control component of the remedy. The Source Control remedy
is to cap the landfill and perform drainage improvements to minimize the contact of
ground water with the waste in the landfill. The second half of the Order directed a
group of PRP's known as the MOM group to design and build the Management of

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AUBURN ROAD LANDFILL                                                    13
AMENDED  RECORD OF  DECISION	

Migration portion of the remedy, the ground water treatment plant.

      In June 1994 the EPA and State of New Hampshire entered into dispute
resolution with a number of groups to settle litigation at the site. The parties to the
dispute resolution are the Town of Londonderry; the MOM group including BASF
Corporation, Disogrin Corporation, Waste Management of New Hampshire,
Lockheed Sanders, Inc., and General Latex & Chemical Corporation; Exxon; and a
number of third parties brought in by the Town of Londonderry. Peter Johnson who
is the former owner of the Landfill was invited to participate but declined the offer.

      Litigation has been stayed during the process of these negotiations with the
exception of those actions taken against non-settlers.
III.   COMMUNITY PARTICIPATION

      Throughout the site's history, community concern and involvement has varied.
Initially, the public's interest was very strong.  However, as site activities have
progressed, interest has waned. A few individuals, direct abuttors, retain a keen
interest in the cleanup process.  EPA has kept the community and other interested
parties apprised of the site activities through informational meetings, fact sheets,
press releases and public meetings.

During June, 1984 EPA released a community relations plan which outlined a
program to address community concerns and keep citizens informed about  and
involved in activities during remedial activities. Since that time the EPA has held
the following meetings related to the site:

      June 28,1984: Informational meeting to describe the plans for the Remedial Investigation and
      Feasibility Study.

      May 21,1985: Informational meeting to discuss results of the Remedial Investigation.

      April 30, 1986: Informational meeting to discuss results of the Remedial Investigation.

      July 30, 1986: Informational meeting to discuss the Focussed Feasibility Study.

      August 6, 1986: Public meeting to receive comments on the Focussed Feasibility Study

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AUBURN  ROAD LANDFILL                                                     14
AMENDED RECORD  OF DECISION	

      October 27,1987: Informational meeting to discuss the Supplemental Remedial Investigation.

      September 27,1988: Informational meeting to discuss the second barrel removal action.

      March 22,1989: Informational meeting to discuss the Feasibility Study results and EPA's Proposed
      Plan.

      March 30,1989: Second informational meeting for those people who could not attend the March
      22nd meeting.

      April 25,1989: Public hearing to receive comments on the Feasibility Study and the Proposed Plan.

      June 22, 1992: Informational meeting to discuss the design for the landfill cap and the results of the
      ground water Pre-Design Investigation.

      April 24,1996: Public meeting to discuss the results of site sampling and EPA's Proposed Plan

      May 16,1996: Public hearing to receive comments on the site conditions and the Proposed Plan.

      In addition, during construction of the landfill caps during 1993 and  1994
SEA Consultants, Engineers for the Town of Londonderry, released a number of
fact sheets to inform the public of construction activities at the site.

      In April 1996, EPA made the administrative record available for public
review at EPA's offices in Boston and at the Leach Public Library in Londonderry,
New Hampshire. EPA published a notice and brief analysis of the Proposed Plan in
The Manchester Union Leader on April 17, 1996 and made the plan available to the
public on April 12, 1996.

      On April 24,1996, EPA held an informational meeting to discuss the results
of the Remedial Investigation and the cleanup alternatives presented in the
Feasibility Study and to present the Agency's Proposed Plan. Also during this
meeting, the Agency answered questions from the public.  From April 25,1996
through May 24, 1996, the Agency held a 30 day public comment period to accept
public comment on the alternatives presented in the Feasibility Study and the
Proposed Plan and on any other documents previously released to the public.  On
May 16,1996, the Agency held a public meeting to discuss the Proposed Plan and
to accept any oral comments. A transcript of this meeting and the comments and the
Agency's response to comments are included in the attached  Responsiveness
Summary in Appendix E.

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AUBURN ROAD  LANDFILL                                                 15
AMENDED RECORD OF DECISION	

IV.   SCOPE AND ROLE OF OPERABLE UNIT OR RESPONSE ACTION

      In 1989 the EPA issued a Record of Decision that selected Landfill capping
and ground water pump and treat as a comprehensive approach to site remediation.
In 1991 the PRPs began the pre-design investigation to build the ground water
cleanup facility. The ground water data from the pre-design investigation caused the
EPA to reconsider the necessity for constructing a ground water pump and treat
system. The Town of Londonderry completed capping the  landfill in 1994. Only
the ground water remedy remains to be completed to fully implement the 1989
ROD.

      Samples taken during the Ground Water Remedy Pre-Design indicated that
site ground water contamination conditions had changed dramatically from 1986.
The 1986 data were the basis of the ground water cleanup dictated in the 1989
ROD.  The pre-design samples demonstrated that the volatile organic compounds
(VOCs) that had contaminated much of the aquifer were now below the cleanup
levels set by the 1989 ROD. Only arsenic remained in concentrations sufficient to
pose a risk. The change in ground water conditions prompted the EPA to re-
examine the ground water cleanup strategy.

      The EPA believes that the low-permeability cap placed on the landfills will
halt the leaching of contaminants and other materials from the landfills.
Geochemical modeling has demonstrated that capping the landfill should result in
arsenic attaining cleanup levels off site within five years.

      In this Amended Record of Decision the EPA is modifying the decision in the
1989 ROD to build a ground water pump and treat facility.  The response action that
the EPA is now selecting to clean up the contaminated ground water is limited
action which includes:

            restoration of ground water through natural attenuation;

            the development and implementation of a revised ground water, surface
            water, sediment and air sampling program that provides for
            investigation and action contingent upon sampling data that show  any
            of the following:

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AUBURN ROAD LANDFILL                                                   16
AMENDED RECORD  OF DECISION	

                  1.    an increase in ground water contamination.
                  2.    toxicity to aquatic life or a public health risk from arsenic
                       contamination in sediments.
                  3.    a human health or ecological risk from contaminants in
                       surface water.

            the establishment of a Groundwater Management Zone, within which
            ground water will be restored;

            the establishment of institutional controls to notify and prevent
            residents from using contaminated ground water in the overburden and
            bedrock aquifers;

            the continued maintenance of the landfill caps and drainage system to
            restrict ground water movement through the disposal areas to the
            greatest degree possible; and

            a review of site conditions every five years.

      The EPA developed the selected remedy in consideration of other remedial
actions taken at the site, current site conditions, and other investigations.  Earlier
remedial actions at the site that have reduced or eliminated public health risks or
threats to the environment include:

            providing a municipal drinking water supply to residents whose wells
            were contaminated or threatened by contamination in ground water
            from the site;

            construction of a RCRA type C low-permeability cap on top of the
            three disposal areas. Ground water modeling has shown that arsenic
            should meet cleanup levels off-site within five years after the landfill is
            capped; and

            construction of drainage swales around the landfills to lower the water
            table in the vicinity of the disposal areas and thereby minimize contact
            of the water table with the wastes.

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AUBURN ROAD LANDFILL                                                  17
AMENDED RECORD  OF DECISION	

      This remedial action will address the only threat to human health posed by the
site: the future consumption of ground water for drinking water purposes. This
remedial action will also address any future contamination that poses a threat to
public health and the environment.
V.    SUMMARY OF SITE CHARACTERISTICS

      The significant findings of the 1989 Remedial Investigation and subsequent
investigations are summarized below.

      A.    Soil and Sediment

      In 1989 EPA's Record of Decision described four areas of soil
contamination.  Those areas were the four separate landfills at the Site. The
contaminants found in these areas included volatile organic compounds, semi-
volatile organic compounds, polychlorinated biphenyls, and pesticides. The
contaminated materials in those areas are now covered by a cap sufficient to
eliminate human exposure to those contaminants.

      Concentrations of arsenic exist in the soil and in the sediments in water
bodies that abut the Site.  Although arsenic appears naturally in both the ground
water and soil in this part of New Hampshire, the arsenic at issue here is not
naturally occuring. Rather, the arsenic present in sediments and ground water at the
site results from geochemical conditions created by the contamination within the
landfill. However, the concentrations  of arsenic do not pose any significant risk to
public health or the environment.  Because the  arsenic co-precipitates with  the iron,
no arsenic is seen in any significant concentrations in surface waters in Whispering
Pines Pond. Most of the arsenic-contaminated ground water from the site
discharges in a  narrow area of wetlands that borders Cohas Brook.  Elevated
concentrations in sediment, but again not in surface water, were reported in the
1995 Draft Annual Monitoring Report for the area in Cohas Brook in which ground
water from the  site appears to discharge.  Figure 4 displays the concentrations for
arsenic-in-sediments throughout the area of the site. Photo 1 shows the ground
water seeps in the wetlands adjacent to Cohas  Brook.

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AUBURN ROAD LANDFILL                                                 18
AMENDED RECORD OF DECISION	

      Because the 1995 Annual Report reported what appeared to be significant
increases in sediment concentrations of arsenic, the EPA chose to resample the area
of the highest concentration and the areas around it.  The EPA also chose to sample
sediments to gauge their toxicity to organisms rather than for just the specific
contaminant. The analysis consisted of taking a large amount of the sediment and
allowing an insect, an amphipod - Hyalella azteca, to live in the sample for ten days
and record how many of the organisms live and die.  The percentage of the
amphipod mortality is a gauge of the relative toxicity of the sediment. The results
showed no significant mortality to test organisms. Additional details of the
investigation into sediment toxicity are contained in Appendix D.  Sampling has
shown that none of the areas sampled pose a public health risk or are toxic to
aquatic life.
      4  1935  Annual  Report Long-term  Environmental Monitoring
 Program,  Auburn  Road Landfill Site, Londonderry,  New Hampshire
 (Draft),  Sevee & Maher Engineers,  Inc..   April 1996.

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AUBURN  ROAD  LANDFILL
AMENDED RECORD OF DECISION
19
   FIGURE 4 AND PHOTO 1, SEDIMENT CONTAMINATION. The results of sediment
   sampling, in parts per million, that was performed in August 1995.  Photo 1 shows the staining
   of sediments from iron precipitation that contains some arsenic adjacent to Cohas Brook.
   Photo 1 is standing on the edge of the ponded area, looking westward, the pond is to the right
   of the photo and Auburn Road lies approximately ten feet to the left of the edge of the photo

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AUBURN ROAD LANDFILL                                                20
AMENDED RECORD OF DECISION	

      B.   Ground Water

      Ground water at the site flows north ward. Although some ground water
flows into Whispering Pines Pond, this is only very localized flow and most of the
flow is towards, and into, Cohas brook. Ground water travel times are fast because
of the permeable sands and gravels that make up much of the aquifer.

      Prior to 1986 and through 1989 VOCs were wide-spread in ground water at
the site and were highly concentrated.5 Sampling conducted in 1991 and 1992
found that much of the VOC contamination was below the 1989 ROD cleanup
levels.6 The primary fate of the contaminated ground water was either by flowing
from the aquifer into Cohas Brook, or the contaminants were consumed by bacteria
within the aquifer. It is likely that both processes acted to reduce contaminant
concentrations in the ground water.  The contaminants in the ground water that had
discharged to surface water were either destroyed by ultraviolet radiation or reaction
with highly oxygenated water (hydrolysis).

      Table  1 compares the concentration of each contaminant of concern for the
site between 1984 and 1995. The VOCs have diminished in both frequency of
detection and maximum concentration. In 1995 only one well is found that has
exceedences of the cleanup levels set for the VOCs and that well, MW1.02A,
directly abuts the Town Dump. No off-site wells were found to contain  VOCs that
exceeded the cleanup  level.

      The majority of the VOC contamination in ground water is below cleanup
levels that were set in the 1989 ROD. The only significant contamination from the
site that remains is arsenic in ground water.  Ground water contaminated with
arsenic forms a narrow plume that courses northward across the site and appears to
discharge into Cohas brook. The arsenic contamination is either the result of the
slow leaching of arsenic from contaminated wastes within the landfill or it may be
      5  Auburn Road  Landfill  Remedial  Investigation Report, NUS
 Corporation,  April  10, 1989.

      6  Supplement II Investigation Report, Supplemental  Pre-
 Design  Investigation for  Remediation of Ground water,  Sevee  &
 Maher Engineers,  Inc., August 1993.

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AUBURN ROAD LANDFILL                                                 21
AMENDED RECORD OF  DECISION	

the result of contamination within the landfill changing the geochemical conditions
in the aquifer. The theory behind how the arsenic contaminating ground water may
be generated by contaminants from the landfill is outlined in Appendix C.

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AUBURN ROAD  LANDFILL
AMENDED RECORD OF DECISION
22
       FIGURE 5. Arsenic and VOC contamination in 1995. VOCs exist in
       concentrations that exceed cleanup levels in one well, MW-102A. Arsenic is
       widespread and exceeds the cleanup levels in many wells throughout the site.
       The contaminant plume is shown beneath water bodies and surface features
       because the highest concentrations of arsenic lie forty to fifty feet below the
       ground surface except in those areas in which ground water comes to the
       surface such as near some portions of Whispering Pines Pond and Cohas
       brook.
                                 Arsenic Concentration!^           	


             SOppb-lOOppb    100ppb-200 ppb   200 ppb - 300 ppb    Ore«ler thin 300

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AUBURN ROAD  LANDFILL                                                 23
AMENDED RECORD OF  DECISION	

      C.   Surface Water

      The ground water containing the arsenic flows to, and discharges to, Cohas
Brook and a smaller amount to Whispering Pines Pond.  However, sampling has
shown that the arsenic does not discharge into the surface water of the ponds
Instead, as the arsenic-contaminated ground water approaches the stream or pond
bed, oxygen-rich water contacts the contaminant-containing ground water and
changes the water chemistry.  The arsenic and iron (most of the plume is actually
composed of iron) precipitates in the sediments. The result is that surface water
concentrations of arsenic are similar to the regional background.

      In 1986 and 1989 very low levels of VOCs, less than 20 parts per billion,
were found in surface water during sampling conducted for the Remedial
Investigation. Due to the low concentrations in ground water and surface water, no
further sampling for VOCs was performed. The location of sampling points and the
values for each are shown on Figure 6.

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AUBURN  ROAD  LANDFILL
AMENDED RECORD OF DECISION
24
 FIGURE 6. Location of surface water sampling points sampled in August 1995. Arsenic
 concentradons are shown for each of the surface water (SW) sampling points in parts per
 billion.
                                                  ^        SW-3:1.9ppbi

                                           •~   v
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AUBURN ROAD LANDFILL,                                                  25
AMENDED RECORD OF DECISION	

      D.    Air

      Air samples were taken three times during the Remedial Investigation.  Only
very low levels of VOCs, less than 16 parts per billion, were found. The landfill has
not accepted any waste in over seventeen years. It is not expected that significant
emissions from the landfill occur. However, as a portion of the Operations and
Maintenance plan for the Source Control Remedy, the Town will monitor air quality
at appropriate intervals.
VI.   SUMMARY OF SITE RISKS

      Site risks are comprised of risks to human health and the environment.  The
contaminants of concern in this Record of Decision are a smaller subset of those
selected in the 1989 Record of Decision because many of the contaminants that
were of a concern then are no longer present in significant concentrations at the site.
Therefore, the results of the risk assessment presented below are based on data
collected from 1993 until  1995. Ecological risk was examined in greater detail due
to high concentrations in stream sediments reported in the 1995 Annual Report.7

      A.    Risk to Human Health

      In 1986 EPA performed an Endangerment Assessment (EA)8 to estimate the
probability and magnitude of potential adverse human health and environmental
effects from exposure to contaminants associated with the site. The public health
risk assessment followed  a four step process:

      1) contaminant identification, which identified those hazardous substances
      which, given the specifics of the site were of significant concern;
         1995 Annual Report. Environmental Monitoring Program. A uburn Road Landfill...,
Prepared by Sevee & Maher Engineers for the Management of Migration Group, April 1996

      8  A uburn Road Landfill Endangerment Assessment, Planning Research
Corporation for USEPA, July 1986.  Two volumes.

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AUBURN ROAD LANDFILL                                                  26
AMENDED RECORD OF DECISION	

      2) exposure assessment, which identified actual or potential exposure
      pathways, characterized the potentially exposed populations, and determined
      the extent of possible exposure;

      3) toxicity assessment, which considered the types and magnitude of adverse
      health effects associated with exposure to hazardous substances; and

      4) risk characterization, which integrated the three earlier steps to summarize
      the potential and actual risks posed by hazardous substances at the site,
      including carcinogenic and non-carcinogenic risks.

      In the 1986 EA the EPA showed that risks posed by future, potential
ingestion of ground water were outside of EPA's acceptable risk range and led the
EPA to set cleanup levels for ground water. The EPA determined that
concentrations of contaminants in soils, sediments, surface water and air did not
pose a risk outside of EPA's acceptable range.

       The 1989 Record of Decision listed nine  contaminants of concern.  The nine
contaminants were selected and evaluated in the Endangerment Assessment.  The
nine contaminants of concern were selected to represent potential site related
hazards based on toxicity, concentration, frequency of detection, and mobility and
persistence in the environment. A summary of the health effects of each of the
contaminants of concern can be found in Section 6 of the 1986 Endangerment
Assessment.  The maximum concentration and frequency of detection of the nine
contaminants of concern in 1989 are compared to their concentration and frequency
found in 1995 in Table 1. Three of the nine compounds, 1,2 dichloroethylene, 2-
butanone, and toluene are no longer found in concentrations that exceed the cleanup
level.  Although lead has an established cleanup level, it has not exceeded that level,
50 parts per billion, nor has it exceeded EPA's action level of 15 parts per billion.
All compounds, except arsenic, have greatly reduced concentrations and
frequencies.

       In 1993, 1994, and 1995 EPA conducted  additional sampling of ground
water, surface water, and sediment. The results of these sampling events were used

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AUBURN ROAD  LANDFILL
AMENDED RECORD  OF DECISION
27
to assess risks to human health and the environment.9
TABLE 1 - COMPARISON OF 1984 TO 1995 DATA
CONTAMINANT
CLEANUP LEVEL
Vinyl Chloride
2 ppb
t-1,2 Dichloroethene
70ppb
2-Butanone
172 ppb
Trichloroethene
5 ppb
Tetrachloroethene
5 ppb
Benzene
5 ppb
Toluene
2,000 ppb
Arsenic
50 ppb
YEAR
1984
1995
1984
1995
1984
1995
1984
1995
1984
1995
1984
1995
1984
1995
1984
1995
FREQUENCY
(detect /wells)
10/65
2/15
44/65
1/14
21/65
7/15
24/65
5/15
22/65
1/15
8/65
7/15
34/65
5/15
11/15
26/37
# WELLS
(exceeding
cleanup level)
10
1
25
0
14
0
20
1
16
1
7
1
4
0
7
19
HIGH
in parts per
billion CoDb)
82
6
330,000
6
12,000
6
1,600
44
8,500
100
12
6
6,500
6
130
354
      9  Memoranda from Margaret McDonough to Darryl Luce,  March
 1996,  June 1996, and November  18,  1996.

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AUBURN ROAD LANDFILL                                                  28
AMENDED RECORD OF DECISION	

      Potential human health effects associated with exposure to the contaminants
of concern were estimated quantitatively or qualitatively through the development of
several hypothetical exposure pathways. These pathways were developed to reflect
the potential for exposure to hazardous substances based on the  present uses,
potential future uses, and location.  The area is rural, residential  with residents
representing all age groups.  The following is a brief summary of the exposure
pathways evaluated for exposure in 1996. A more thorough description of all the
pathways considered and exposure scenarios used in 1986 may be found in Section
6 of the Endangerment Assessment.

      Ground water - current: There is no current use of ground water for drinking
      water purposes.

      Ground water - future: Potential use of ground water for residential drinking
      water was assumed.

      Sediment - current and future: Dermal contact and incidental ingestion of
      sediments was evaluated.

      For each pathway evaluated, an average and a reasonable maximum exposure
estimate was generated corresponding to exposure to the average and the maximum
concentration detected in that particular medium. Excess lifetime cancer risks were
determined for each exposure pathway by multiplying the exposure level with the
chemical specific cancer factor.  Cancer potency factors have been developed by
EPA from epidemiological or animal studies to reflect a conservative "upper bound"
of the risk posed by potentially carcinogenic compounds. That is, the true risk is
unlikely to be greater than the risk predicted.  The resulting risk estimates are
expressed in scientific notation as a probability (e.g. 1 x 10"6 for 1/1,000,000) and
indicate (using this example), that an average individual is not likely to have greater
that a one in a million chance of developing cancer over 70 years as a result of site-
related exposure as defined to the compound at the  stated concentration.  Current
EPA practice considers carcinogenic risks to be  additive when assessing exposure
to a mixture of hazardous substances. The acceptable risk range that EPA Region I
uses lies between a total of SxlO"4  and IxlO"6 for carcinogenic risks.

      The EPA calculated the hazard index for ground water considering its

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AUBURN ROAD LANDFILL                                                  29
AMENDED RECORD OF DECISION	

potential use as drinking water. The hazard index is EPA's measure of the potential
for non-carcinogenic health effects. A hazard quotient is calculated by dividing the
exposure level by the reference dose (RfD) or other suitable benchmark for non-
carcinogenic health effects for an individual compound.  Reference doses have been
developed by EPA to protect sensitive individuals over the course of a lifetime and
they reflect a daily exposure level that is likely to be without an appreciable risk of
an adverse health effect. RfDs are derived from epidemiological or animal studies
and incorporate uncertainty factors to help ensure that adverse health effects will not
occur. The hazard quotient is  often expressed as a single value (e.g. 0.3) indicating
the ratio of the stated exposure as defined to the reference dose value (in this
example, the exposure as characterized is approximately one third of an acceptable
exposure level for the given compound). The hazard quotient is only considered
additive for compounds that have the same or similar toxic endpoint and the sum is
referred to as the hazard index (HI). (For example: the hazard quotient for a
compound known to produce liver damage should not be added to a second whose
toxic endpoint is kidney damage).

      Below, each exposure pathway and scenario is discussed.  Following that, the
risks associated with assumptions are presented in Tables 2 through 4,

DRINKING WATER

      Future potential exposure from the ingestion of ground water as a residential
drinking water supply was evaluated.  This pathway and scenario assumes that a
future user of contaminated ground water will drink two liters of contaminated water
for 350 days per year for 30 years. Tables 3 and 4 depict the carcinogenic and non-
carcinogenic risk summary, respectively, for the contaminants of concern in ground
water evaluated to reflect potential future drinking water use corresponding to the
average and the reasonable maximum exposure (RME)  scenarios. Because
municipal drinking water is supplied to the area, no present risk values have been
calculated. Table 2, for comparison purposes, examines the risk in ground water
on-site, within the landfilled area which is not truly representative of what a future
ground water user may extract for domestic drinking water purposes.

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AUBURN ROAD LANDFILL
AMENDED RECORD OF DECISION
30
TABLE 2 - CARCINOGENIC RISKS FOR THE POSSIBLE FUTURE INGESTION OF GROUND WATER
INSIDE THE PROPERTY LINE
CONTAMINANT
Vinyl Chloride (A)
Trichloroethylene (NA)
Benzene (A)
Tetrachloroethylene (NA)
Arsenic (A)
Concentration
in parts per billion (ppb)
average maximum
0.5
3.2
0.9
7
74
6
44
6
100
354
Exposure
Factor
(1 /kg/day)
average =
1 x JO'3
RME =
1 x JO'2
Cancer Potency
Factor
(mg/kg/day)'1
1.9
1.1 xlO'2
2.9 x 10'2
5.2 xlO'2
1.5
TOTAL
Risk Estimate
average
2.3 x 10-6
8.4 x 10-'
6.2 x 10-8
8.7 xlO'7
3.7 xlO-4
3.7 x KT1
RME
1.4X10-4
5.7 xlO-6
2.0x10^
6.2 xlO'5
6.3 x lO'3
6.4 xlO'3

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AUBURN ROAD LANDFILL
AMENDED RECORD OF DECISION
31
TABLE 3 - CARCINOGENIC RISKS FOR THE POSSIBLE FUTURE INGESTION OF GROUND WATER
OUTSIDE THE PROPERTY LINE
CONTAMINANT
Arsenic (A)
Concentration
in parts per billion (ppb)
average maximum
104
318
Exposure Factor
(1/kg/day)
avg. = 2.9 x 10'2
RME=1.2xlO-2
Cancer Potency
Factor
(mg/kg/day)'1
1.5
Risk Estimate
average
3.8x10^
RME
5.6 x lO'3
TABLE 4 - NON-CARCINOGENIC RISKS FOR THE POSSIBLE FUTURE INGESTION OF GROUND WATER
INSIDE THE PROPERTY LINE
CONTAMINANT
1,2 Dichloroethylene
(NA)
Toluene (D)
2- Butanone (D)
Concentration
in parts per billion
(ppb)
avg. max.
0.4
1
0.9
6
6
6
Exposure Factor
(1 /kg/day)
avg. = 1.9 xlO'2
RME = 27x 10'2

Reference
Dose
(mg/kg/day)
1 x 10-2
2 x lO'1
6x10-'
Target
Endpoint of
Toxicity
Blood
Liver/Kidney
Decreased body
weight
Hazard Quotient
average
0.0008
0.00009
0.00003
RME
0.01
0.0008
0.0003

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AUBURN ROAD  LANDFILL
AMENDED RECORD OF DECISION
32
SEDIMENT AND SURFACE WATER

      The current and future potential for exposure from incidental ingestion of
contaminants in sediments assumes that adolescents between the ages of 6 to 15
years old will visit Cohas brook. The access to contaminated sediments would be
infrequent due to the location of nearby residents, the narrow road shoulder, and the
heavy truck and high speed passenger car use. Therefore, an estimated exposure
frequency of 20 days per year (once a week in summer months) for the RME and 10
days for the Central Tendency (CT) was assumed.  Table 5 depicts the carcinogenic
risk summary for the contaminant of concern in sediment evaluated to reflect present
and potential future wading corresponding to the average and the reasonable
maximum exposure (RME) scenarios.  The carcinogenic risk for swimming in, or
wading in, the surface water  of Cohas brook was not calculated because the
concentrations  are very low and the exposure would not be frequent enough to
generate any risk.
TABLE 5 - CARCINOGENIC RISKS FOR CURRENT WADING AND
INCIDENTAL INGESTION OF SEDIMENT

Arsenic
Concentration
in parts per
million
Avg.
218
Max.
1,340
Exposure Factor
(1/kg/day)
avg = 2.8xlO'9
RME= 1.1 x ID'8
Cancer
Potency
Factor
(mg/kg/day)'1
1.5
Risk
Avg.
9.0 x lO'7
RME
2.2 xlO-5
Summary of Human Health Risks

      The actions taken at the site have eliminated all significant present public
health threats.  The Town, by capping the thirteen acres of landfilled area, has halted
the public's exposure to contaminated soils.  The EPA, by removing over 2,000
drums of industrial wastes, eliminated the potential for present exposure to
contaminated air and the future potential for the drummed wastes to further
contaminate soil and ground water. The Town, by supplying municipal water to

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AUBURN ROAD  LANDFILL                                                 33
AMENDED RECORD OF DECISION	

those affected by or threatened by contaminated ground water, has eliminated the
potential for present exposure to contaminants in drinking water.

      However, some portions of the population may be exposed to site
contaminants in the present and future.  Sediment and surface water in Whispering
Pines Pond and Cohas brook are contaminated. However, the concentrations of
those contaminants are within EPA's acceptable risk range under either present or
future scenarios as outlined above.

      The future carcinogenic risk of ingesting arsenic-contaminated ground water
as drinking water is the only pathway that poses a significant public health risk.
This is a future use scenario since no individuals are currently using contaminated
ground water for drinking water purposes.

      B.   Ecological Risk

      A qualitative Ecological Risk Assessment was performed prior to the 1989
ROD.10 The assessment was inconclusive as to if ecological endpoints were
affected by contaminants from the site. Since 1993 the Responsible Parties have
monitored sediments and surface waters at the site.  The EPA examined the annual
sampling results and the 1995 sampling indicated a potential problem in Cohas
Brook where the arsenic-contaminated ground water plume discharges to surface
water.

      The 1986 Endangerment Assessment focussed on lipophilic compounds such
as tetrachloroethylene that have a tendency to bioaccumulate in fish tissues.
However, lipophilic compounds are either not present, or in extremely low
concentrations in the ground water plume.  Arsenic does not bioaccumulate to any
significant degree in fish or the food chain in particular."
      10   Auburn Road Landfill  Endangerment Assessment,  Volume  2
 of 2, Planning Research  Corporation for  USEPA,  July 1986.

      11   Ambient Water  Quality Criteria  for Arsenic, EPA 440/5-
 84-033.   USEPA Office  of Water  Regulations and  Standards Criteria
 and Standards  Division,  Washington, D.C.,  January 1985.

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AUBURN ROAD LANDFILL                                                 34
AMENDED RECORD OF  DECISION	

      Sediment sampling in 1995 indicated that one area of Cohas Brook, the area
where the site's ground water plume discharges to surface water, had significant
concentrations of arsenic.  The EPA and Responsible Parties re-sampled this area,
and surrounding areas, on July 1,1996. The results were that no significant
mortality was found to occur when test organisms, in this case Hyalella azteca,
were exposed to the sediments for a ten-day period. The results are discussed in
greater detail in Appendix D to this document.

      C.    Site Risk Summary

      No current risk to public health or the environment has been found to exist.
There is only future, potential risk posed by the site. The risk is to public health if
ground water is used as a drinking water source for an extended period of time (30
years). The drinking water risks are quantified in Section VI (A) of this document.

      Actual or threatened releases of hazardous substances from this site, if not
addressed by implementing the response action selected in this ROD, may present
an imminent and substantial endangerment to public health, welfare, or the
environment. In particular, the future,  potential ingestion of arsenic-contaminated
ground water would represent an unacceptable risk to human health.
VII.  DEVELOPMENT AND SCREENING OF ALTERNATIVES

      A.    Statutory Requirements/Response Objectives

      Under its legal authorities, EPA's primary responsibility at Superfund sites is
to undertake remedial actions that are protective of human health and the
environment. In addition, Section 121 of CERCLA establishes several other
statutory requirements and preferences, including: a requirement that EPA's
remedial action, when complete, must comply with all federal and more stringent
state environmental standards, requirements, criteria or limitations, unless a waiver
is invoked; a requirement that EPA select a remedial action that is cost-effective and
that utilizes permanent solutions and alternative treatment technologies or resource
recovery technologies to the maximum extent practicable; and a preference for
remedies in which treatment which permanently and significantly reduces the

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AUBURN ROAD LANDFILL                                                  35
AMENDED RECORD OF DECISION	

volume, toxicity or mobility of the hazardous substances is a principal element over
remedies not involving such treatment.  Response alternatives were developed to be
consistent with these Congressional mandates.

      Based on preliminary information relating to types of contaminants,
environmental media of concern, and potential exposure pathways, remedial action
objectives were developed to aid in the development and screening of alternatives.
These remedial action objectives were developed to mitigate existing and future
potential threats to public health and the environment. In 1989 EPA chose response
objectives for soil and ground water. Briefly, those objectives were  to provide
protection of public health risk from contaminated ground water, reduce
environmental risks from contaminated surface waters, and to reduce the public
health risk from ingestion of contaminated soil. These goals are enumerated on
page 17 of the 1989 ROD and are detailed fully in Section 2 of the 1989 Feasibility
Study.  No exposure pathway exists for drinking water consumption nor soil
ingestion due to the supplied public water system and limited contamination in
ground water and the landfill cap covering contaminated soil, respectively.
Therefore EPA chooses, as response objectives in the 1996 Record of Decision:

            1.    Ensure that ground water discharge from the site does not
            degrade the environment nor create a health risk for those people who
            wade or swim in surface waters near the site.

            2.    Ensure that ground water is not used as a source of drinking
            water and that progress is made towards achieving cleanup levels.

            3.     Maintain the effectiveness of the landfill cap and the drainage
            structures to eliminate or reduce ground water infiltration through the
            landfilled areas.

      B.    Technology and Alternative Development and Screening

      CERCLA and the National Contingency Plan (NCP) set forth the process by
which remedial actions are evaluated and selected.  In accordance with these
requirements, a range of alternatives were developed for the site.  These
alternatives, and the technical basis that underlie them are developed in the April

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AUBURN ROAD LANDFILL                                                  36
AMENDED RECORD OF  DECISION	

1996 Feasibility Documentation.12

      This Amended Record of Decision addresses ground water cleanup. The
Source Control actions proposed in the 1989 Record Of Decision have been
implemented. Circumstances have combined to change the character of ground
water contamination to require a re-examination of the means to remedy that
contamination. As previously noted, an entire class of contaminants has almost
disappeared from the site. Therefore, the EPA determined that a re-examination of
the ground water remedy was necessary. This re-examination is summarized in an
April  1996 Feasibility Supplement to the 1989 Feasibility Study.

      With respect to the chosen response action, the 1989 and 1996 Feasibility
Studies developed a number of remedial alternatives and a limited action alternative.
The 1989 Feasibility Study and the 1996 Feasibility Documentation identified,
assessed and screened technologies based on implementability, effectiveness, and
cost.  The EPA compared present site conditions against the ability of the
alternatives selected in the 1989 to address conditions within the arsenic-
contaminated aquifer. The EPA also investigated the potential of new, innovative
technologies to address contaminated ground water. No technology, neither
established nor innovative, was found that either the EPA or the State believed was
capable of achieving cleanup levels for arsenic any faster than capping the disposal
areas  and allowing natural attenuation to occur as proposed for the limited action
alternative. The EPA expects that the limited action, natural attenuation remedy,
will restore ground water within a reasonable time frame. Other than the limited-
action alternative, the EPA developed technologies that may achieve cleanup levels,
temporarily, and in localized areas. The EPA believes that the limited action
alternative will achieve protective cleanup levels in the same time frame as any
other  remedy.

      The NCP, 40 CFR Part 300 Section 300.430(e)(3) & (4) identifies a method
to develop a range of remedial alternatives to address contamination at the site.  The
1989  Feasibility Study and the 1996 Supplement present the remedial alternatives
      12   Feasibility Documentation,  Supplement  to 1989 Auburn
 Road Feasibility Study,  US  Environmental  Protection Agency,  April
 1996.

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AUBURN ROAD LANDFILL                                                  37
AMENDED RECORD OF DECISION	

developed by combining the technologies identified in the screening process
identified the NCP. The initial screening narrowed the number of potential remedial
actions for further detailed analysis while preserving a range of options. The
remedial actions were assembled as alternatives and then each alternative was then
evaluated and screened in Chapter 4 of the 1989 Feasibility Study and in the 1996
Supplement.

      In summary, one remedy that could be termed a source control measure, one
remedy that could be termed a management of migration measure, and the limited
action remedial alternative were retained for consideration.
VIII. DESCRIPTION OF ALTERNATIVES

      This Section provides a narrative summary of each alternative evaluated.  A
detailed assessment of each alternative can be found in Appendix C attached to this
document.  The area of contamination consists of a narrow plume of arsenic
contaminated ground water that flows northward from the site. The area is Class II
ground water, that is it is a potential source of drinking water in New Hampshire.
Surface waters in the area are classified as "B", that is  suitable for recreational
purposes, by the State.13

      All three alternatives will restore ground water to drinking water standards
off-site and on-site. Preliminary modeling shows that natural attenuation should
achieve cleanup levels for arsenic, off-site, within five years. A narrow plume of
arsenic-contaminated ground water flows off-site to the north of the disposal areas.
Institutional controls, either deed restrictions or implementation of New
Hampshire's Groundwater Protection Rules Env-Ws 410, will be necessary for all
alternatives to prohibit the use of contaminated ground water for drinking water
purposes.

      The three alternatives to address arsenic contaminated ground water are:
          Thomas Andrews, verbal communication with Darryl Luce, May 29th, 1996.

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 AUBURN ROAD  LANDFILL                                                  38
 AMENDED RECORD OF  DECISION
{Alternative 1: Limited Action.
      The key component of this, and the other alternatives, is the landfill cap that
 the Town of Londonderry constructed as a Source Control measure.  The Source
 Control measure, listed as Alternative SC-2 in the 1989 Record of Decision,
 featured construction of a synthetic cap on the landfilled areas and drainage
 improvements to lower the water table.  The cap and drainage improvements were
 completed in 1994.

      The cap and water table lowering will either effectively eliminate or diminish
 the flow of contaminants from the landfilled areas into the watertable.   Ground
 water modeling has shown that the arsenic in ground water should meet cleanup
 levels off-site within five years of the installment of the cap.14 Therefore, the EPA
 expects that cleanup levels will be attained within a reasonable time frame. The
 ground water discharges to surface water; however, based on sampling results, the
 arsenic does not appear to discharge to surface waters. It appears that when the
 arsenic-contaminated ground water nears the stream-bottom, oxygen-rich water
 contacts the up-welling contaminated water, changing the chemistry and causing the
 iron and arsenic to precipitate before discharging to the ponds and streams.

      Under this alternative only ground water, surface water, sediment, and air
 sampling would occur. This sampling would be evaluated periodically to determine
 if a risk to human health or the environment occurs, or if conditions within the
 aquifer require re-evaluation, or if the sampling program requires adjustment. The
 goals of the sampling program will be to:

             ensure that the public is not exposed to unacceptable concentrations of
             site contaminants in either surface waters or sediments;

             ensure that any contaminants in surface water and sediments in water
             bodies surrounding the site are not present in concentrations or forms
       14   Supplement II, Updated Solute Transport Model Simulations, Auburn Road Landfill
 Site..., Sevee & Maher Engineers, March 4, 1994.

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AUBURN ROAD LANDFILL                                                 39
AMENDED RECORD OF  DECISION	

           that are toxic to aquatic life; and

           determine progress in the cleanup of the aquifer.

      If the EPA and the State identify a problem, additional investigations would
be performed to determine the full nature of the problem.  The EPA and the State
would use those investigations to determine what the risk is, where the problem
originates, and the possible response actions. Prior to implementing any actions, the
EPA and the State would discuss investigation results, their conclusions, and any
recommendations with the public.

      EPA and the State would also require institutional controls to prevent
someone from using ground water that may be contaminated. The institutional
controls will be instituted through either deed restrictions or municipal land use
restrictions.  After five years EPA and the State would evaluate how well this
remedy protects the public health and environment.

      While Alternative 1 is similar to Alternative MM-1 in the 1989 Proposed Plan
and Record of Decision, one significant difference in the current proposal is in how
quickly the ground water will be cleaned. In the 1989 ROD, the EPA estimated that
it would take 30 years for the ground water to be restored to drinking water quality.
However, natural attenuation has reduced the majority of the VOC contaminants to
concentrations below the 1989 ROD cleanup levels and only arsenic remains.
Ground water modeling indicates that the time to achieve cleanup levels off-site is  5
years from when the cap was placed on the landfill. Because waste will remain on-
site, monitoring costs were calculated for over a  thirty-year period.

      The limited action alternative relies on the proper functioning of the landfill
cap and the drainage improvements.  The action  taken will ensure that the natural
processes that have prevented the public's contact with arsenic-contaminated
ground water will continue to occur.  Currently, natural processes appear to be
functioning to eliminate any arsenic discharges to surface water. Applicable and
relevant and appropriate requirements (ARARs) will include some substantive
portions of the State of New Hampshire's Groundwater Protection Rules, Env-Ws
410, February 1993 and Surface Water Quality Regulations, Env-Ws 430 - 438,
September 30, 1996. New Hampshire's Water Quality Standards, Env-Ws 310 -

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AUBURN  ROAD LANDFILL                                                  40
AMENDED RECORD  OF DECISION	

319 and Surface Water Quality Regulations replace the Federal Safe Drinking
Water Act and Clean Water Act, respectively, because these Federal programs have
been delegated to the state.  Federal ARARs will include the Fish and Wildlife
Coordination Act, 40 CFR 6.0302(g), and Executive Order 11990, Protection of
Wetlands, 40 CFR 6, Appendix A.  There will be no residuals nor implementation
requirements.

      Estimated Period of Operation: 5 years
      Estimated Total Cost: $2,000,000
{Alternative 2: On-Site Treatment by Extraction and Chemical Precipitation.      \


      This was chosen as "EPA's preferred alternative" for ground water cleanup in
 the 1989 Proposed Plan. In this alternative, contaminated ground water would be
 collected in wells and trenches. The contaminated water would be pumped to a
 central facility for chemical precipitation to remove metals.  The solvent compounds
 have largely disappeared eliminating the need for an air stripper. A monitoring
 program, similar to that outlined for Alternative 1, would be implemented under this
 alternative.

      To remove metal contaminants, such as iron and arsenic, established
 precipitation and settling technologies would be employed to precipitate and settle
 out metal contaminants.  The resulting sludges would be further compacted in a
 filter press. The resulting filtrate would be tested and disposed of properly.

      Any traces of volatile organic compounds that may occur would be removed
 from the ground water by liquid-phase carbon. The treated water would meet
 drinking water standards for metals and solvent compounds. The clean ground
 water would then be recharged back into the aquifer through recharge trenches.

      The pump and treat alternative would locally recover arsenic-contaminated
 ground water and remove the arsenic. The pump and treat remedy may limit
 migration; however, it is believed that it will not stop arsenic from entering the
 ground water. Therefore, it is expected that the optimum result will be localized

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AUBURN ROAD LANDFILL                                                 41
AMENDED RECORD OF  DECISION	

reductions of arsenic; however, arsenic will still exceed 50 parts per billion in the
majority of the aquifer. Applicable and relevant and appropriate requirements
(ARARs) will include the ARARs identified in alternative 1 and also New
Hampshire's Hazardous Waste Rules, Env-Ws 100 - 1000 which replaces Federal
hazardous waste rules under the Resource Conservation and Recovery Act (RCRA)
because the state has been delegated that program.   Construction of a ground water
treatment plant and the installation of wells will be required.

      Estimated Time to Construct: 1 to 2 years
      Estimated Time of Operation: 3 to 5 years
      Estimated Total Cost: $12,500,000 to $16,300,000
Alternative 3: Excavate the Landfills, Build a New Landfill On Site with a
Baseliner and Cap.	
       In the 1989 Feasibility Study and Record Of Decision this was Source
Control remedy SC-4.  This alternative proposes to completely encapsulate the
landfill to eliminate all leaching from the landfill. Such encapsulation would require
an impermeable baseliner beneath the landfill in addition to the existing top cap.
Because a baseliner cannot be placed under an existing landfill, the implementation
of this alternative would require that all of the existing waste be dug up, a new
disposal area be constructed with a base-liner, and the waste re-deposited into the
new landfill area. This would require construction of a new area, installing a new
baseliner, and then excavating and moving the old waste to the new landfill area.
Some of the excavated waste would require treatment to remove contaminants.
Such treatment would be through low-temperature thermal stripping. Once all waste
was placed in the new area, the new landfill would be capped much as it is now. A
monitoring program, similar to that outlined for Alternative 1, would also be
implemented under this alternative.

       Construction of a new landfill would require approximately 240,000 cubic
yards of materials to be excavated and moved.  It was estimated in the 1989
Feasibility Study that approximately 40,000 cubic yards  of contaminated soil would
need to be treated to reduce contamination present.  Applicable and relevant and
appropriate requirements include those  ARARs identified for alternatives 1 and 2,

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AUBURN ROAD  LANDFILL                                                42
AMENDED RECORD OF DECISION	

Federal Land Disposal Regulations 40 CFR 268, additional portions of the New
Hampshire's Hazardous Waste Rules, the Federal Clean Air Act and, New
Hampshire Air Quality Rules (RSA Chapter 125-C).

      Estimated Time to Construct: 1 to 2 years
      Estimated Time of Operation: 3 to 4 years
      Estimated Total Cost: $32,400,000

       EPA developed the above alternatives based on information contained in the
1989 Feasibility Report prepared by R.F. Weston, Inc. EPA presented these
alternatives as alternatives MM-1, MM-2 and SC-4, respectively, in the 1989
Proposed Plan  and Feasibility Study. Despite the shortened cleanup times for all of
the remedies, it should be noted that because it is a landfill and regardless of the
remedy, it will  still be necessary to monitor ground water for 30 years.
IX.   SUMMARY OF THE COMPARATIVE ANALYSIS OF
      ALTERNATIVES

      Section 121(b)(l) of CERCLA presents several factors that at a minimum EPA
is required to consider in its assessment of alternatives. Building upon these
specific statutory mandates, the National Contingency Plan articulates nine
evaluation criteria to be used in assessing the individual remedial alternatives.

      A detailed analysis was performed on the alternatives using the nine
evaluation criteria in order to select a site remedy. The following is a summary of
the comparison of each alternative's strength and weakness with respect to the nine
evaluation criteria.  These criteria are summarized as follows:

      Threshold Criteria

      The two threshold criteria described below must be met in order for the
      alternatives to be eligible for selection in accordance with the NCP.

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AUBURN ROAD  LANDFILL                                                 43
AMENDED RECORD OF DECISION	

            1.    Overall protection of human health and the environment
                 addresses whether or not a remedy provides adequate protection
                 and describes how risks posed through each pathway are
                 eliminated, reduced or controlled through treatment, engineering
                 controls, or institutional controls.

            2.    Compliance with applicable or relevant and appropriate
                 requirements (ARARS) addresses whether or not a remedy
                 will meet all of the ARARs of other Federal and State
                 environmental laws and/or provide grounds for invoking a
                 waiver.

      Primary Balancing Criteria

      The following five criteria are utilized to compare and evaluate the elements
      of one alternative to another that meet the threshold criteria.

            3.    Long-term effectiveness and permanence addresses the
                 criteria that are utilized to assess alternatives for the long-term
                 effectiveness and permanence they afford, along with the degree
                 of certainty that they will prove  successful.

            4.    Reduction of toxicity, mobility, or volume through treatment
                 addresses the degree to which alternatives employ recycling or
                 treatment that reduces toxicity, mobility, or volume, including
                 how treatment is used to address the principal threats posed by
                 the site.

            5.    Short term effectiveness addresses the period of time needed to
                 achieve protection and any adverse impacts on human health and
                 the environment that may be posed during the construction and
                 implementation period, until cleanup goals are achieved.

            6.    Implementability addresses the technical and administrative
                 feasibility of a remedy, including the availability of materials and
                 services needed to implement a particular option.

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AUBURN ROAD LANDFILL                                                  44
AMENDED RECORD OF DECISION	

            7.    Cost includes estimated capital and Operation Maintenance
                 (O&M) costs, as well as present worth costs.

      Modifying Criteria

      The modifying criteria are used on the final evaluation of remedial
      alternatives generally after EPA has received public comment on the RI/FS
      and Proposed Plan.

            8.    State acceptance addresses the State's position and key
                 concerns related to the preferred alternative and other
                 alternatives, and the State's comments on ARARs or the
                 proposed use of waivers.

            9.    Community acceptance addresses the public's general response
                 to the alternatives described in the Proposed Plan and RI/FS
                 report.

      A detailed tabular assessment of each alternative according to the nine criteria
and an assessment of the relative performance of each alternative against the nine
criteria is attached as a portion of Appendix C to this ROD.  The section below
presents the nine criteria and a brief narrative summary of the alternatives and the
strengths and weaknesses according to the detailed and comparative analysis.

L.    Overall Protection of Human Health and the Environment

      This criteria considers whether an alternative, as a whole, will protect human
health and the environment. This includes an assessment of how public health and
environmental risks  are properly eliminated, reduced, or controlled through
treatment, engineering controls, or institutional controls.

      There are two primary considerations at this site: the first is that contaminated
ground water does not discharge to surface water in concentrations sufficient to
pose a risk to human health or the environment, and the second is that no one is
drinking contaminated ground water. Therefore, there is no present exposure to  site
contaminants under  any of the alternatives. Because the  time to attain cleanup

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AUBURN ROAD  LANDFILL                                                 45
AMENDED RECORD OF  DECISION	

levels is dependent upon the rate of flow of contaminants from the landfill, which
should diminish due to the cap, the time to attain cleanup levels, and comply with all
ARARs, is the same for all three alternatives.

      There are no exposures to contaminants in concentrations sufficient to pose a
risk at the site to either the public health or the environment.  Therefore, all three
alternatives are equally protective of human health and the environment.

2^    Compliance with Applicable and Relevant and Appropriate Regulations

      Addresses whether or not a remedy complies with all state  and federal
environmental and public health laws and requirements that apply or are relevant
and appropriate to the conditions and cleanup alternatives at a specific site. If an
Applicable or Relevant and Appropriate Requirement (ARAR)  cannot be met, the
analysis of the  alternative must provide the grounds for invoking a statutory waiver.

      All of the alternatives will meet the requirements of all ARARs within a
reasonable time frame. The only ARARs the site is not in compliance with are the
chemical specific ARARs that pertain to drinking water standards.

      The period over which any of the remedial alternatives will achieve
compliance with all of the chemical-specific ARARs will be in  approximately the
same time frame. Arsenic in ground water violates the drinking water standard, if
ground water were used as a drinking water source. Based on the results of ground
water modeling, EPA expects that contaminants leaching from the landfilled areas
will diminish due to the caps and that ground water will meet cleanup levels off-site
within five years.  The EPA believes that ground water will meet  cleanup levels in a
reasonable time frame, therefore there is no need to invoke an ARAR waiver for
ground water cleanup. Pumping and treating contaminated ground water will not
hasten the cleanup process because the contamination is dependent upon leaching
from the landfill.  The cleanup levels established in the 1989 Record of Decision are
essentially met for all compounds other than arsenic.15
      15  Methods for  Evaluating the Attainment of Cleanup
 Standards, Volume 2: Ground Water.  United States Environmental
 Protection Agency, Policy, Planning and Evaluation,  EPA 230-R-92-
 014.   July 1992.

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AUBURN ROAD LANDFILL                                                   46
AMENDED RECORD  OF DECISION	

3^    Long-term Effectiveness and Permanence

      Refers to the ability of an alternative to maintain reliable protection of human
health and the environment over time once the remedial action objectives and
cleanup levels have been met.

      Alternatives 1, 2, and 3 will be equally effective and permanent. They will be
equally effective in maintaining risk levels because they rely on the  flow of
contaminants from the landfill to be reduced due to the existing landfill cap. The
landfill cap will minimize infiltration, lessening ground water and contaminant flow
from the landfills, and permanently reduce the risk. The rebound of contaminant
concentrations occurs usually after the cessation of a remedy because of
disequilibrium conditions imposed such as pumping. However,  if cleanup levels
are attained through natural attenuation, the remedy will be permanent because
equilibrium conditions will have been maintained and the natural process will have
exhausted itself. Alternative 2 may reach cleanup levels more quickly than
alternative 1; however, it is very likely that arsenic concentrations will rebound once
pumping is stopped.  Neither alternatives 2 or 3 will attain cleanup levels through its
implementation alone. Natural attenuation, assisted by the capping  of the landfill
will ensure the effectiveness and the permanence once cleanup levels are attained.

4^    Reduction of Toxicity. Mobility, and Volume through Treatment

      These are the three principle criteria of the overall performance of an
alternative. The 1986 amendments to the Superfund statute emphasizes that,
whenever possible, EPA should select a remedy that uses a treatment process to
permanently reduce the level of toxicity of contaminants at the Site, inhibit or
eliminate the spread of contaminants away from the source of contamination, and
reduce the volume, or amount, of contamination at the Site.

      All three alternatives reduce mobility through the use of a landfill cap,
although Alternative 2 also uses hydraulic controls. Toxicity and volume are
diminished by all three alternatives by capping the disposal areas, thereby reducing
infiltration and leaching of contaminants from the aquifer.  Alternative 3,
encapsulation, should be more effective in reducing mobility  through the use of a
baseliner and the treatment of any wastes encountered during excavation.

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AUBURN ROAD LANDFILL                                                  47
AMENDED RECORD OF DECISION	

      The potential exists for Alternative 2, pump-and-treat, to reduce toxicity,
mobility, and volume through treatment. However, it is believed that any such
effects may be short-lived.  Once pump-and-treat draws down the aquifer, the
mobility of any contaminants leaching from the landfill will be zero, or nearly so.
The contaminants will be trapped above the water table until the recovery system is
turned off. The water table will then rebound and contaminant flow will resume. A
small scale pump-and-treat, designed solely to intercept a contaminant plume, may
limit migration but would not cleanup the aquifer.

5.    Short-term Effectiveness

      Refers to the likelihood of adverse impacts on human health or the
environment that may be posed during the construction and implementation of an
alternative until remedial action objectives and cleanup levels are achieved.

      Short-term effectiveness addresses the risks posed to workers and neighbors
during the construction and implementation of the remedy. In this regard,
Alternatives 1 and 2 would meet this criteria without much difficulty. The risks that
each poses over its construction or implementation can be easily managed.
However, Alternative 3 has the potential to pose significant short-term risks to
workers and the neighborhood. Engineering controls for Alternative 3 should be
able to minimize the potential risks that may be present. The excavation and re-
internment of wastes proposed for Alternative 3 will occur over two years. The
potential exists for fugitive gases or contaminant-bearing dusts to escape the control
measures during that time.

      The potential for impact to wetlands exists for all three alternatives. All three
alternatives could see the potential for ground water to produce  either violations of
surface water quality standards or potentially harmful effects to  wildlife due to
sediment exposure during the time period in which contaminated ground water flows
to surface water bodies. The potential also exists for significant impacts to wetlands
during the implementation of Alternative 3, encapsulation, due to erosion  or runoff
during the excavation.

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AUBURN ROAD LANDFILL                                                  48
AMENDED RECORD OF DECISION	

6^    Implementability

      Refers to the technical and administrative feasibility of an alternative,
including the availability of materials and services needed to implement the
alternative.

      All alternatives use technologies that are standard.  The sampling and
analysis, and maintenance of the cap, will need to be implemented for all three
alternatives. Alternative 3 is the most cumbersome of the alternatives and would
require years to implement. The construction of Alternatives 2 and 3 would require
careful planning and work, and both alternatives would require at least one-year for
design and one to two years for construction. For all three alternatives, long-term
monitoring of ground water and surface water will necessitate administrative
measures to ensure proper sampling and analysis.  Long-term management of the
data will also be necessary to be able to track progress  in the cleanup at the site or
identify problems. Obtaining institutional controls will  also be required.

L    Cost

      Includes the capital (up-front) cost of implementing an alternative as well as
the cost of operating and maintaining the alternative over the long-term, and net
present worth of both capital and operation and maintenance costs.

      The EPA has developed the costs using reasonable assumptions more fully
outlined in the Feasibility Study. However, the comparison for implementing each
remedy and monitoring over 30 years is:

            Alternative 1:     $ 2,000,000
            Alternative 2:     $12,500,000 to $14,300,000
            Alternative 3:     $32,800,000

CONCLUSION AFTER ANALYSIS OF SEVEN OF THE CRITERIA

      The comparison of the three alternatives to one another led EPA to  select
Alternative 1 for presentation to the public as EPA's preferred alternative  during the
public participation process and in the Proposed Plan.  The EPA selected this

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AUBURN ROAD LANDFILL                                                  49
AMENDED RECORD OF DECISION	

remedy because under Alternative 1 public health and the environment are
protected, ground water modeling indicates that cleanup levels and ARARs will be
met within a reasonable time frame, no active remedy will restore the aquifer any
faster than natural attenuation, and a source of public drinking water is supplied to
the affected area.

8.    State Acceptance

      Addresses whether, based on its review of the data derived from the Site and
the Proposed Plan, the State concurs with, opposes, or has no comment on the
alternative EPA has selected as the remedy for the Site.

      The State recommends Alternative 1 based on a similar, although
independent, analysis of the above seven criteria. The New Hampshire Department
of Environmental Services has provided EPA with a letter of concurrence with the
selected remedy. This letter is attached as Appendix A.

9.    Community Acceptance

      Addresses whether the public concurs with EPA's Preferred Alternative.
Community acceptance of this cleanup proposal was evaluated based on comments
received at the public hearing.

      Representatives of the  community and some of the residents support
Alternative 1 after presentation at the public meeting. Some residents, including
some who abut the site, did express concern regarding incidental exposure to
children in some of the surface water bodies in the area. Two residents, one an
abutter to the site, are ardently opposed to Alternative 1 and instead request that
EPA consider Alternative 2, pump and treat, or, preferably, Alternative 3,
encapsulation.

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AUBURN ROAD LANDFILL                                                  50
AMENDED RECORD OF DECISION	

X.    THE SELECTED REMEDY

      Alternative 1 is the selected remedy based on the following:

                 no current unacceptable risk is posed to public health or the
                 environment;
                 the remedy will attain cleanup levels and will meet all ARARs
                 within a reasonable time frame;
                 the remedy will be permanent;
                 past activities have acted to reduce mobility and toxicity;
                 the remedy will pose no short-term risks; and
                 the cost is much less over the other alternatives, yet cleanup
                 levels will be attained in approximately the same time frame with
                 identical residual levels.

      Combined with the source control remedy that the Town finished in 1994, the
landfill cap and drainage improvements, Alternative 1 will provide for a
comprehensive remedy.  Alternative 1, the Limited Action remedy consists of
maintaining the existing landfill cap and drainage  system, establishing institutional
controls, and implementing an environmental monitoring plan.  Institutional controls
will prevent the use of contaminated ground water for drinking water purposes in
the present and future. Municipal drinking water  is already supplied to the area. An
environmental monitoring plan will look at ground water, surface water, sediment,
and the air. Ground water modeling has shown that natural attenuation should attain
cleanup levels off-site in five years.

      A.    Interim Cleanup  Levels

      Interim cleanup levels that are being established as the performance standards
for this remedy are ground water quality standards.  Once the interim cleanup levels
are attained and all ARARs are complied with over a three-year period a risk
assessment will be performed.  The risk assessment will determine if conditions
both on-site  and off-site are such that no current or future risk is posed to either the
public health or the environment for any exposure pathway.  The protective residual
levels, as determined through that risk assessment, will be the final cleanup levels
for this Record of Decision and shall be considered the performance standards for

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AUBURN ROAD LANDFILL                                                 51
AMENDED RECORD OF  DECISION

this remedial action. The interim cleanup levels established under this Record of
Decision are only for ground water and are presented in Table 7.

      Interim cleanup levels were established in the 1989 ROD for ground water for
all contaminants of concern identified in the Baseline Risk Assessment found to
pose an unacceptable risk to either public health or the environment. The cleanup
levels for the nine contaminants have been retained, with one exception, in this
Amended Record of Decision despite the fact that four compounds are below the
cleanup levels and three compounds are within EPA's acceptable risk range.  The
cleanup level for toluene has been lowered from 2,000 parts per billion (ppb) to
1,000 ppb to reflect the changes in regulations and to be in conformance with the
State of New Hampshire's Drinking Water Standards.  Interim cleanup levels were
set based on the ARARs (e.g., Drinking Water Maximum Contaminant Level Goals
(MCLGs) and MCLs) as available, or other suitable criteria described below.

      Periodic assessments of the protection afforded by the selected remedy will
be made as the remedy is being implemented and at the completion of the remedial
action. At the time that Interim Ground Water Cleanup Levels identified in the
Amended ROD and newly promulgated ARARs and modified ARARs which call
into question the protectiveness of the remedy have been achieved and have not
been exceeded for a period of three consecutive years, a risk assessment shall be
performed on the residual ground water contamination to determine whether the
remedial action is protective. This risk assessment of the residual ground water
contamination shall follow EPA procedures and will assess the cumulative
carcinogenic and non-carcinogenic risks posed by:

            the ingestion and dermal absorption of arsenic from surface water and
            sediments; and

            the ingestion of ground water used for drinking water purposes.

      If, after review of the risk assessment, the remedial action is not determined
to be protective by EPA, the remedial action shall continue until either protective
levels are achieved, and are not exceeded for a period of three consecutive years, or
until the remedy is otherwise deemed protective.  These protective residual levels
shall constitute the final cleanup levels for this Record of Decision and shall be

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AUBURN ROAD LANDFILL                                                  52
AMENDED RECORD OF DECISION	

considered performance standards for any remedial action.

      Because the aquifer at and beyond the compliance boundary for the landfill is
a Class II aquifer which is a potential source of drinking water, MCLs established
under New Hampshire's Water Quality Standards are ARARs.

      Interim cleanup levels for known, probable, and possible carcinogenic
compounds (Classes A, B, and C, respectively) have been established to protect
against potential carcinogenic effects and to conform with ARARs. Interim cleanup
levels for Class D and E compounds (not classified, and no evidence of
carcinogenicity) have been established to protect against potential non-carcinogenic
effects and to conform with  ARARs.

      In the absence of a MCL,  other suitable criteria were considered (i.e., health
advisory, state guideline). In the absence of the above standards and  criteria,
interim cleanup levels for all other compounds (Classes D and E) were established
based on a level that represent an acceptable exposure level to which  the human
population including sensitive subgroups may be exposed without adverse affect
during a lifetime or part of a lifetime, incorporating an adequate margin of safety
(hazard quotient =1) considering the ingestion of ground water or the ingestion and
dermal exposure to arsenic-contaminated surface water. If a value described by any
of the above methods was not  capable of being detected with good precision and
accuracy or was below what was deemed to be the background value, then the
practical quantification limit or background value was used as appropriate for the
Interim  Cleanup Level.

      The Table on the following page summarizes the Interim Cleanup Levels
established in the 1989 Record of Decision. This Amended Record of Decision will
retain those cleanup levels.  Within Table 6 a number of compounds,  other than
arsenic, exceed cleanup levels. Vinyl chloride, trichloroethylene,
tetrachloroethylene, and benzene exceed the cleanup levels in only one well, MW-
102A. Well MW-102A is directly adjacent to the Old Town Dump, down-gradient
from this well the contaminants are naturally attenuated and are not detected.
Although the concentrations for trichloroethylene and tetrachloroethylene are
significantly over their cleanup levels in MW-102A the maximum risk posed by
those concentrations in drinking water is within EPA's acceptable risk range (5x10"*

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AUBURN ROAD LANDFILL                                                  53
AMENDED RECORD OF DECISION	

to 1 x 10"6). Benzene and vinyl chloride barely exceed their cleanup level in MW-
102A and the risk for drinking water is within EPA's acceptable risk range. Vinyl
chloride is a degradation product of trichloroethylene and other chlorinated
hydrocarbons, therefore vinyl chloride is likely to be seen in well MW-102A where
trichloroethylene and other compounds are degrading. Vinyl chloride had not been
found to exceed its cleanup level in any wells outside of the site property boundary.

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AUBURN ROAD  LANDFILL
AMENDED  RECORD  OF DECISION
TABLE 6 - INTERIM CLEANUP LEVELS IN GROUND WATER
Contaminant
Vinyl Chloride
trans 1,2 Dichloroethylene
2-Butanone
Trichloroethylene
Tetrachloroethylene
Toluene
Benzene
Arsenic16
Lead
BASIS
MCL
MCL
Health Advisory
MCL
PMCL
MCL
MCL
MCL
MCL
ACTION LEVEL
CLEANUP
LEVEL
(parts per billion)
2
70
172
5
5
1,000
5
50
50
15
1995 CONCI
(in parts
AVERAGE
0.5
0.4
0.9
only one well
detect
only one well
detect
1.1
0.9
74.2
iNTRATIONS
)er billion)
MAXIMUM
6
6
6
44
100
6
6
354
NUMBER OF WELLS
EXCEEDING
CLEANUP LEVEL
1 out of 15
0 out of 14
0 out of 15
1 out of 15
1 out of 15
0 out of 15
1 out of 15
19 out of 37
Lead has not exceeded cleanup levels or Action Levels.
        1 b    Recent studies indicate that many skin tumors arising from oral exposure to arsenic are non-lethal and that the dose-response curve for the skin cancers
may be sublinear (in which case the cancer potency factor used to generate risk estimates may be overestimate).  It is Agency policy to manage these risks downward
by as much as a factor often. As a result, the carcinogenic risk for arsenic at this Site has been managed as if it were one order of magnitude lower than the calculated
risk  Consequently, the risk level for arsenic in Table 2 reflects a risk management factor

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AUBURN ROAD LANDFILL                                                 55
AMENDED RECORD OF  DECISION	

      These interim cleanup levels are consistent with ARARs or suitable TBC
criteria for ground water, attain EPA's risk management goal for remedial actions
and are determined by EPA to be protective. However, the true test of protection
cannot be made until residual levels are known. Consequently, at the time that
Interim Ground Water Cleanup Levels identified in the ROD and newly
promulgated ARARs and modified ARARs which call into question the
protectiveness of the remedy have been achieved and have not been exceeded for a
period of three consecutive years, a risk assessment will be performed on residual
ground water contamination to determine whether the remedial action is protective.

      A risk assessment of the residual ground water contamination shall follow
EPA procedures and will assess the cumulative carcinogenic and non-carcinogenic
risks posed by future ground water consumption as drinking water. If, after review
of the risk assessment, the remedial action is not determined to be protective by
EPA, then remedial actions shall continue until either protective levels are achieved
and are not exceeded for three consecutive years or until the remedy is otherwise
deemed protective. These protective residual levels shall constitute the final
cleanup levels for this Record of Decision and shall be considered performance
standards for any remedial action.

      All Interim Cleanup Levels identified in the Amended ROD and newly
promulgated ARARs and modified ARARs which call into question the
protectiveness of the remedy and protective levels determined as a consequence of
the risk assessment of residual contamination,  must be met at the completion of the
remedial action. The EPA has estimated that these levels will be obtained within
five years after completion of the source control component.

      B.    Description of Remedial Components

      The selected remedy, Alternative 1, consists of operating and maintaining the
existing Site controls to achieve the natural restoration of the ground water and to
protect surface water quality. This alternative will prevent the public from using
contaminated ground water for drinking water purposes, will meet, through natural
processes, cleanup levels in ground water, and act to address any contamination in
ground water, surface water, or sediments that threaten public health or the
environment. The selected remedy consists of the following remedial components:

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AUBURN ROAD LANDFILL                                                 56
AMENDED RECORD OF  DECISION	

      1.    Natural Attenuation of Contaminated Ground Water

           Restore ground water to meet final cleanup levels and meet all ARARs
      through natural attenuation. Contaminated ground water flows to the north as
      shown on Figure 5 on page 22. There shall be no degradation of ground
      water quality such that cleanup levels or ARARs are violated outside of the
      area of contamination. Ground water flow is to the north and ultimately
      discharges to Cohas Brook. Therefore, no degradation of ground water, due
      to the site, shall be allowed to the north of Cohas Brook.

      2.    Establishment of a Ground Water Management Zone ("GMZ...")

           The selected remedy essentially adopts the process established under
      New Hampshire's Ground water Protection Rules for providing a temporary
      exemption from ground water quality standards within a zone of non-
      compliance.  This process involves establishment of a Ground water
      Management Zone (GMZ) which in combination with establishment of
      institutional controls within the GMZ will allow for protection of public
      health while the other components of the natural attenuation remedy are
      implemented. However, cleanup levels also will be achieved within the GMZ
      within a reasonable time frame.  A monitoring program will be established
      within the Long Term Monitoring Plan that will allow the EPA and the State
      to determine the effectiveness of the remedy over time. Data generated
      through the Long Term Monitoring Plan will be evaluated for each five-year
      review; however, annual assessments of the data and cleanup progress will be
      performed. If ground water quality standards are exceeded outside the GMZ
      or if surface water quality is affected, or if sediments are  found to be
      significantly toxic to test organisms, modifications to the  remedy may be
      required to address the restoration of ground water outside the GMZ and/or
      restoration of surface water quality.

           The Scope of Work (SOW) for remedial design and remedial action
      will address what information must be submitted for establishment of the
      GMZ and will establish the schedule for compliance with performance
      standards.

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AUBURN ROAD LANDFILL                                                  57
AMENDED RECORD OF DECISION	

      3.     Implementation of Long Term Monitoring Plan

            A detailed plan for monitoring the performance and effectiveness of the
      remedial action will be developed and submitted to the state and EPA for
      approval during the remedial design phase of the remedial response.  The
      ground water monitoring component of the plan will provide the data
      necessary to monitor the effectiveness of the existing site controls and the
      natural attenuation component of the remedy.  The surface water/sediment
      component of the plan will also provide data necessary to determine the
      effectiveness of existing site controls or whether contaminated ground water
      is impacting surface water or migrating beyond the compliance boundary,
      thereby necessitating modification to the remedial components.

            If the monitoring program detects  significant events, additional
      investigation will be performed. Significant events are:

            a.    Ground water contaminated by the site moves northward, in
                 either the bedrock or overburden aquifers from Cohas Brook.
                 These events would be detected either by a well established for
                 such monitoring or surface seeps. Such an event would indicate
                 that the arsenic contaminated plume has migrated past the
                 compliance boundary.

            b.    A violation of the surface water standards contained in New
                 Hampshire's Surface Water Quality Regulations Env-Ws 430 -
                 438 for the compounds with cleanup levels listed in this, and the
                  1989, Record of Decision in either Whispering Pines Pond or
                  Cohas Brook.  The specific cases that are significant events are:

                        1.  Surface water quality violations occur if arsenic
                       concentrations in Cohas brook or Whispering Pines Pond
                       are significantly elevated over the up-gradient samples or
                       if arsenic concentrations exceed the standards contained
                       in Env-Ws 430 - 438. The arsenic standards for
                       Freshwater (acute) are 850 ppb for pentavalent arsenic
                       (As5*) and 360 ppb for trivalent (As3+). The standards for

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AUBURN ROAD LANDFILL                                                 58
AMENDED RECORD OF  DECISION	

                       freshwater (chronic) are 4& ppb for pentavalent arsenic
                       and 190 for trivalent.

                       2.  Surface water quality standards for vinyl chloride - 2
                       parts per billion (ppb), trichloroethylene - 5 ppb, benzene
                       - 5 ppb, and tetrachloroethylene - 0.8 ppb are exceeded.

                       3.  If arsenic contaminated sediments are found to be toxic
                       to aquatic life.

            If data show evidence that any one of the criteria in Section X. B. 3. a.
      & b. may be violated, a plan of action will be developed that describes what
      investigatory actions will be taken to determine if a problem exists and the
      magnitude of that problem. The results of the investigatory action will  be
      used to determine if additional sampling or remedial action is necessary. If
      the established standards contained within the ARARs are violated, or  if an
      unacceptable risk is posed to either public health or the environment, a plan
      of action will be developed that outlines how the problem creating those
      conditions will be corrected. That plan will be brought before the public for
      review and comment before implementation.

            The EPA and State will review all sampling data as it becomes
      available and conduct a comprehensive review on an annual basis. Annual
      meetings will be held to apprise the public of what risk the site may pose at
      that time.

      4.     Maintenance of Existing Site Controls (cap and drainage system)

            The landfill cap maintenance plan, which is already in place and is
      being implemented  by the  town, will continue to be implemented as (O&M).17
      The O&M plan includes procedures for maintaining the integrity of the cap,
      including inspections for determining areas of erosion or failure  of the cap. It
      1   Post-Closure Operations  and Maintenance  Plan,  Auburn
 Road Landfill  Superfund Site,  Source Control Remedial  Action,
 Prepared for the Town of Londonderry by SEA Consultants  Inc.,
 February 1995,  Revised May  1996.

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AUBURN ROAD LANDFILL                                                  59
AMENDED RECORD  OF DECISION	

      also requires monitoring of internal landfill gases to ensure that
      concentrations of methane and other gases do not pose a risk to health or the
      environment.

            The O&M plan also includes procedures for maintenance of the
      drainage components to ensure that ground water contacts the smallest
      possible amount of landfilled volume.  This includes periodic inspections to
      determine if water is able to flow freely from the area surrounding the
      landfills.  Ground water is also measured to determine if the water table is
      contacting waste in the landfilled areas.

      5.     Establishment of Institutional Controls

            Institutional controls will be established to provide notice and to
      restrict use of contaminated  ground water within the GMZ.  The notice and
      recordation portions of the state's ground water statutes and rules are
      ARAR's, so that recordation notice or notice through municipal land controls
      will be provided to affected  persons.  Restrictions on use of ground water
      through easement or ownership will also be established.

      6.     Five Year Reviews

            The 1986 CERCLA amendments require review of conditions every
      five years at NPL sites if any hazardous substances, pollutants or
      contaminants remain to assure that the remedial action continues to protect
      human health and the environment.. All data obtained in the monitoring
      program, and evaluated on an annual basis, will be further evaluated in the
      five-year reviews. These reviews will consider all relevant data, any
      significant trends, and determine if additional remedial actions, adjustment to
      the monitoring plan, or other actions, are necessary.

            The criteria established in the SOW will provide the basis for
      determining whether the remedial components should be  modified.

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AUBURN ROAD LANDFILL                                                 60
AMENDED RECORD OF  DECISION	

XL   STATUTORY DETERMINATIONS

      The remedial action selected for implementation at the Auburn Road Landfill
Superfund Site is consistent with CERCLA and, to the extent practicable, the NCP.
The selected remedy is protective of human health and the environment, attains
ARARs and is cost effective.  The selected remedy also satisfies the statutory
preference for treatment which permanently and significantly reduces the mobility,
toxicity or volume of hazardous substances as a principal element. Additionally, the
selected remedy utilizes alternate treatment technologies or resource recovery
technologies to the maximum extent practicable.

      A.    The Selected Remedy is Protective of Human Health and the
            Environment

      The remedy at this Site will permanently reduce the risks posed to human
health and the environment by eliminating, reducing or controlling exposures to
human and environmental receptors through engineering controls and institutional
controls; more specifically, allowing natural attenuation to restore ground water to
concentrations that are protective while preventing exposure through institutional
controls and direct action when necessary.

      Moreover, the selected remedy will achieve potential human health risk levels
that attain the 10"4 to 10"* incremental  cancer risk range and a level protective of
noncarcinogenic endpoints, and will comply with ARARs and to-be-considered
criteria. At the time that the Interim Ground Water Cleanup Levels identified in the
ROD and newly promulgated ARARs and modified ARARs which call into
question the protectiveness of the remedy have been achieved and have not been
exceeded for a period of three consecutive years, a risk assessment shall be
performed on the residual ground water contamination to determine whether the
remedial action is protective.  This risk assessment of the residual ground  water
contamination shall follow EPA procedures and will assess the cumulative
carcinogenic and non-carcinogenic risks posed by drinking ground water.  If, after
review of the risk assessment, the remedial action is not determined to be protective
by EPA, the remedial action shall continue until protective levels are achieved and
have not been exceeded for a period of three consecutive years, or until the remedy
is otherwise deemed protective.  These protective residual levels shall constitute the

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AUBURN ROAD  LANDFILL                                                 61
AMENDED RECORD OF DECISION	

final cleanup levels for this Record of Decision and shall be considered performance
standards for any remedial action.

      B.   The Selected Remedy Attains ARARs

      This remedy will attain all applicable or relevant and appropriate federal and
state requirements that apply to the Site. All ARARs for the Site are listed in tabular
form in Appendix B, Tables 1 through 3 of this document.  Environmental laws from
which ARARs for the selected remedial action are derived include:

                 New Hampshire Drinking Water Quality Standards.
                 New Hampshire Surface Water Quality Rules
                 New Hampshire Groundwater Protection Rules
                 Federal Fish and Wildlife Coordination Act, 40 CFR 6.03 02(g)
                 Executive Order 11990 (Protection of Wetlands)

      Because no actions are being taken at the site, other than monitoring and cap
maintenance, New Hampshire's Hazardous Waste Rules (RCRA Authorized),
Executive Order  11988 (Floodplain Management), and New Hampshire's Wetlands
Program do not apply. The only air emissions that occur is the passive venting of
the landfill gases and the size of the landfill is such that the Clean Air Act does not
apply.  The RCRA Land Ban requirements do not apply to the selected remedy as
no excavation, placement, or disposal of Land Ban waste will occur as a result of
the remedial action. The Federal Safe Drinking Water Act and the Clean Water Act
are supplanted by the  delegated State programs.

      The following policies, criteria, and guidance will also be considered (TBCs)
during the implementation of the remedial action:

                 EPA Health Advisories
                 EPA Guidance to Management of Investigation-derived Wastes
                 EPA Policy for low-stress sampling

A brief narrative summary of the ARARs and TBCs follows.

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AUBURN ROAD LANDFILL                                                  62
AMENDED RECORD OF DECISION	

      CHEMICAL SPECIFIC

      New Hampshire Drinking Water Quality Standards Maximum Contaminant
      Levels (MCLs). These are standards for metals, pesticides, VOCs,
      radionuclides, and other classes of contaminants.  The state drinking water
      program is authorized and these regulations have been adopted as enforceable
      standards for public drinking water systems identical to the Safe Drinking
      Water Act (SDWA). MCLs for non-carcinogens are based in part on the
      allowable lifetime exposure to the contaminant for a seventy kilogram (154
      pound) adult who is presumed to consume two liters of water per day. The
      basic jurisdictional prerequisite for MCLs is that they apply to "public water
      systems," defined as systems for the provision of piped water for human
      consumption with at least fifteen service connections.  Although not directly
      applicable to activities at the Site, the potential exists for residential drinking
      water use of ground water at the Site. Therefore, these standards are
      considered to be relevant and appropriate.

      To attain this requirement, ground water at and beyond the Site will attain
      MCLs at the completion of the remedy. These levels will be attained by
      natural attenuation of arsenic and other residual compounds, hastened by the
      landfill capping and drainage improvements.  In the overburden and bedrock
      aquifers MCLs are expected to be attained  off site in approximately five
      years.

      New Hampshire Surface Water Quality Rules Water Quality Criteria Water
      quality criteria relating to surface water are developed under the State's
      Surface Water Quality Rules. They are used by the State of New Hampshire,
      in conjunction with a designated use for a stream segment, to establish water
      quality standards.  The appropriateness of the WQC guidelines are dependent
      on site-specific circumstances. These regulations apply to point and non-
      point sources and include sediments. Ground water discharges to  surface
      water at Cohas Brook and, to a lesser degree, Whispering Pines Pond,
      therefore AWQC are applicable.

            Monitoring will ensure that contaminants do not affect surface water
      bodies and sediments to the extent to pose  a threat to the environment or

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AUBURN ROAD LANDFILL                                                 63
AMENDED RECORD OF  DECISION	

      public health.

      New Hampshire Groundwater Protection Rules The substantive rules provide
      quantitative limits on contaminants in ground water and the use of that ground
      water, regardless of whether it is used as a drinking water source or not.
      Therefore, these standards are considered to be applicable.

            Ground water within and beyond the Site will attain State standards at
      the completion of the remedy. These levels will be obtained by natural
      attenuation and hastened by the installation of the landfill cap and the
      drainage improvements. The time to achieve these standards is expected to
      be five years.

      LOCATION SPECIFIC

      There are few location-specific ARARs because there will be no action at the
      site other than sampling and limited actions. Therefore the only ARARs are:

            Federal Protection of Wetlands Executive Order 11990 - 40 CFR Part
      6 Appendix A is an applicable ARAR for any discharges of ground water into
      surface water, hi this case the long-term discharge of arsenic-contaminated
      ground water to surface waters and the creation of an arsenic-bearing
      sediment will require monitoring to ensure that the sediments do not pose a
      threat to human health and the environment.

            Compliance with the Executive Order will be ensured by ground water,
      surface water, and sediment monitoring.

            Federal Fish and Wildlife Coordination Act - 40 CFR 6.0302(g) which
      is also an applicable ARAR for any pollutants discharged to surface water
      from ground water.

      New Hampshire Groundwater Protection Rules -  Env-Ws 410.26 (a - g)
      establishes a compliance boundary which requires any contamination within
      the boundary to not migrate outside the compliance boundary and requires
      that the area within the boundary be restored within a reasonable time frame

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AUBURN ROAD LANDFILL                                                 64
AMENDED RECORD OF  DECISION	

      All property owners within the compliance boundary are to be notified
      through appropriate means and ground water use is to be restricted by
      ownership, easement, or other appropriate means.  These standards are
      considered to be applicable.

            Ground water within and beyond the Site will attain State standards at
      the completion of the remedy and migration of contaminants will not be
      allowed to occur. All property owners will be notified of the contamination
      and the appropriate institutional controls will be established to restrict ground
      water use.

      ACTION SPECIFIC

      There are few action-specific ARARs because there will be no action at the
      site other than sampling and limited actions in some circumstance. Therefore
      the only ARARs are:

                 New Hampshire Groundwater Protection Rules Portions of
            these regulations, require that landowners be notified if ground water
            beneath their properties is unusable due to contamination, and requires
            that use of that ground water be restricted and an alternative source of
            drinking water supplied. This requirement is applicable.

                 Federal Guidance to Management  of Investigation-Derived
            Wastes provides guidelines in the handling of contaminated media and
            equipment.  Because this is a guideline it is to-be-considered.

                 September 23.1996 Memorandum from Linda Murphy.
            Director. Office  of Site Remediation and Restoration New Procedure
            for collecting Groundwater samples for the determination of organic
            and Inorganic contamination establishes the low-stress method of
            sampling as the only method to collect valid samples. All ground water
            samples, with noted exceptions, will be collected using this technique.
            Because this is a guideline it is to-be-considered.

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AUBURN ROAD LANDFILL                                                  65
AMENDED RECORD OF DECISION	

      C.    The Selected Remedial Action is Cost-Effective

      In the Agency's judgment, the selected remedy is cost effective, i.e., the
remedy affords overall effectiveness proportional to its costs. In selecting this
remedy, once EPA identified alternatives that are protective of human health and the
environment and that attain ARARs, EPA evaluated the overall effectiveness of
each alternative by assessing the relevant three criteria in combination:

            long term effectiveness and permanence;
            reduction in toxicity, mobility, and volume through treatment; and
            short term effectiveness,

      The relationship of the overall effectiveness of this remedial alternative was
determined to be proportional to its costs. The costs of this remedial alternative are
approximately $2,000,000 for sampling over a thirty-year period. Although the
ground water pump and treat remedy, Alternative 2, is cost effective as well, it was
determined that it would not cleanup ground water any faster than Alternative 1 and
would cost at least $10,000,000 more.

      D.    The Selected Remedy Utilizes Permanent Solutions and
            Alternative Treatment or Resource Recovery Technologies to the
            Maximum Extent Practicable

      Once the Agency identified those alternatives that attain ARARs and that are
protective of human health and the environment, EPA identified which alternative
utilizes permanent solutions and alternative treatment technologies or resource
recovery technologies to the maximum extent practicable. This determination was
made by deciding which one of the identified alternatives provides the best balance
of trade-offs among alternatives in terms of:

       1) long-term effectiveness and permanence;
       2) reduction of toxicity, mobility or volume through treatment;
       3) short-term effectiveness;
       4) implementability; and
       5) cost.

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AUBURN ROAD LANDFILL                                                   66
AMENDED RECORD  OF DECISION	

      The balancing test emphasized:
            long-term effectiveness and permanence; and
            the reduction of toxicity, mobility and volume through treatment.
      The balancing test considered as principle elements:
            the preference for treatment;
            the bias against off-site land disposal of untreated waste; and
            community and state acceptance.

The selected remedy provides the best balance of trade-offs among the alternatives.

      Although generally a preference for treatment exists, the EPA and State
believe that no treatment system will achieve cleanup levels in ground water any
faster than natural attenuation. The EPA and the State also believe that any
treatment system may also generate hazardous residues that will require
management and off-site disposal.  Therefore the only remaining criteria to evaluate
was cost. The community, as evidenced by Town representatives and officials,
believe natural attenuation to provide a better remedy than pump and treat because it
will preclude intensified traffic and the  generation of potentially hazardous
materials.

      E.    The Selected Remedy Satisfies the Preference for Treatment
            Which Permanently and Significantly reduces the Toxicity,
            Mobility or Volume of the Hazardous Substances as a Principal
            Element

      The Limited Action alternative, due to the  cap installed over the landfills, will
reduce mobility and toxicity by lessening infiltration and contact with ground water
lessening the amount of arsenic mobilized.

      As cited earlier, it is believed that no treatment system will achieve cleanup
levels any faster than natural attenuation. A ground water remedy in this area would
need to pump and treat a significant volume of water and yet would not achieve
cleanup levels any faster than natural attenuation. A pump and treat remedy may
generate hazardous residues and will increase truck traffic.

      A pump and treat system may arrest migration; however, it is believed that

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AUBURN ROAD LANDFILL                                                 67
AMENDED RECORD OF  DECISION	

such reductions would be localized and that contaminant concentrations would
rebound once pumping is ceased if contaminants are still leaching from the landfill.

      Volume would not be reduced under the Limited Action alternative. Now
that the disposal areas are capped, the slow leaching of contaminants from the
landfill will diminish and ultimately cease.  The same volume of arsenic would exist
in the subsurface; however, once contaminants diminish or cease flowing from the
landfill the conditions in the aquifer concentrations in the ground water will also
diminish.
XII.  DOCUMENTATION OF NO SIGNIFICANT CHANGES

EPA presented a proposed plan with a preferred alternative for remediation of the
Site on April 24,1996. The preferred alternative included.

      restoration of ground water through natural attenuation;

      sampling of ground water, surface water, and sediments;

      establishing institutional controls to prevent the consumption of contaminated
      ground water; and

      investigate and act on any indications that ground water contamination is
      worsening or impacting surface waters.

      This amended Record of Decision contains all of those components and
remains substantially unchanged from the presentation given in the Proposed Plan.
Some concern existed over arsenic-contaminated sediments in Cohas Brook due to
data collected in 1995 that showed localized high concentrations.  The EPA and a
group of the PRPs sampled this area and found that it did not pose a threat to human
health and the environment. The results of this investigation are presented in
Appendix D.

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AUBURN ROAD LANDFILL
AMENDED RECORD OF DECISION
XIII. STATE ROLE

The New Hampshire Department of Environmental Services has reviewed the
various alternatives and has indicated its support for the selected remedy. The State
has also reviewed the Remedial Investigation, Risk Assessment and Feasibility
Study to determine if the selected remedy is in compliance with applicable or
relevant and appropriate State Environmental laws and regulations.  The State of
New Hampshire concurs with the selected remedy for the Auburn Road Landfill
Site. A copy of the declaration of concurrence is attached as Appendix A .

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