United States
Environmental Protection
Agency
Office of
Emergency end
Remedial Response
EPA/ROD/R01-82/005
July 1982
c/EPA
Superfund
Record of Decision:
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TECHNICAL REPORT DATA
(Please read Instructions on the revene before completing)
1. REPORT NO. 12. 3. RECIPIENT'S ACCESSION NO.
EPA/ROD/ROl-82/00S
4. TITLE AND SUBTITLE 5. REPORT DATE
SUPERFUND RECORD OF DECISION: 07/29/82
Syl vester, NH 6. PERFORMING ORGANIZATION CODe
7. AUTHOR(S) 8. PERFORMING ORGANIZATION REPORT NO.
9..PERFORMING ORGANIZATION NAME AND ADDRESS 10. PROGRAM ELEMENT NO.
". CONTRACT/GRANT NO.
12. SPONSORING AGENCY NAME AND ADDRESS 13. TYPE OF REPORT AND PERIOD COVERED
u. S. Environmental Protection Agency Fin~' ~n ~eDOrt
401 "M" Street, S. W. 14. SPONSORING AGENCY CODE
Washington, D.. C. 20460 800/00
.
15. SUPPLEMENTARY NOTES
16. ABSTRACT
The Gibson Road hazardous waste dump site is located in the City of Nashua, New
Hampshire. The 6 acre site has been used as a sand borrow pit for an undetermined
number of years. Some time during the late 1960' s the operator of the pit began an
unapproved and illegal waste disposal operation. Household refuse, demoli Hon
materials, chemical sludges, and approximately 800,000 gallons of hazardous liquid
chemicals were dumped at the site. The ground water, air'and to a lesser extent
surface water have been contaminated.
The selected cost-effective remedial action includes the installation of a
slurry wall around a 20-acre area, an impervious cap, and treatment of the ground
water contained within the slurry wall. The present worth cost for the life of the
project is estimated to be $8,660,000.
17. KEY WORDS AND DOCUMENT ANALYSIS
a. DESCRIPTORS b.IDENTIFIERS/OPEN ENDED TERMS C. COSATI Field/Group
Record of Decision
Site Name: Sylvester Site, NH
Contaminated media: gw, sw, air
Key Contaminants: volatile organics,
inorganics, heavy metals
18. DISTRIBUTION STATEMENT 19. SECURITY CLASS (This ReporT) 21. NO. OF PAGES
".,..~..... 40
20. SECURITY CLASS (Tllis page) 22. PRICE
N,..,n",
EPA Form 2220-1 (Rev. 4-77)
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INSTRUCTIONS
1.
REPORT NUMBER
Insert the EPA report number as it appears on the cover of the publication.
LEAVE BLANK
2.
3.
RECIPIENTS ACCESSION NUMBER
Reserved for use by each report recipient.
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Title'should indicate dearly and briefly the subject coverage of the report, and be disl'lay~'d promin~'ntly. Sel suhlitk, if USl.'~I, in smalkr
-. type or otherwise subordinate it to main title. When a report is prepared in mon° than "n~' volume, reJ1'~at th~'primary till~',lItld V"hIl11l'
- 'number and include subtitle for the specific title.
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REPORT DATE
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PERFORMING ORGANIZATION CODE
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6.
7.
AUTHOR(S)
Give name(s) in ~'onventional order (JO/III R. Doc. J. Rom." Doc'. c.te.). List author's afliliation if it ~Iiffers frum th~' I,,'rforming ,"gani-
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Give name, street, city, state. and ZIP code. List no more than two levels of an organizational hireardlY.
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Insert contract or grant number under which report was prepared,
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Include ZIP code. .
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Insert appropriate code,
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Include a brief (200 words or less) factual summary of the most signilkanl information ~'ontaine,1 in III,' H'l'url. II Ih,' '''I'orl n'lIl:lill\ a
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Prepared in I:ooperation with. Translali..n ..I', I're".:nl,'d al ~...nh'I"lIn' ..f.
17. KEY WORDS AND DOCUMENT ANALYSIS
(a) DESCRIPTORS. Select from the Thesaurus of Engineerin" and Sdentilk Terms the proper authuril.~'d terms that identify the majur
concept of the research and are sufficiently specific and precise to be used as index entries for cataloj:lllj:.
\
(b) IDENTIFIERS AND OPEN.ENDED TERMS - Use identifiers for project namlOS, code namc.:s, equipment I.h;signalors, ell:. Use ul'en-
ended terms written in descriptor form for those subjects for which no descriptor exists.
(c) COSA TI HELD GROUP - Field and group assignments are to be taken from the 1965 (,OS Al'l Suhjet:l ('all'j!ury Ust. Sincl' the ma.
jority of documents are multidisciplinary in nature, the Primary Field/Group assignmcIIUs) will be sp.:l"ilk diwiplinc. area of hUI1l~n
endeavor, or type of physical object. The appJication(s) will be cross-referenced with sel'ondary Hl'Id/C;ruul' a\\ll!lIlI1ellts that will toll.."
the primary posting(s).
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Denote releasability to the public or limitation for reasons other than security for example "Rl'Ica\C Unlilllil~'ll." C"ilc any ~vailahilil>' II)
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19. Be 20. SECURITY CLASSIFICATION
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Insert the total number of pages, including this one and unnumbered pages, but exclude distribution li,t, if any,
22. PRICE
Insert the price set by the National fechnicallnformation Scrvke or the Government Printing Office, if knuwn.
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UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
WASHINGTON, C.C. Z0460
~\. 2 9 lSC2
OFFICE OF
501.10 WASTE ANO EMERGENCY RES;>'::)NSE
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MEMORANDUM
SUBJECT: Record of Decision for the Sylvester Site, N~w Ha~pshire
. I 1/ I
FROM: William N. Hedeman, Jr., Di rector.1?L~ f';1.
. Office of Emergency and Remedial Response (WH:':S48)
TO:
,
.
Rita M. Lavelle, Assistant Administrator
Office of Solid Waste and Emergency'Response (WH-562-A)
~
1 forwarded a memorandum which you signed on June 21, 1982, which
amended the Cooperative Agreement with the State of New Hampshire for the
Sylvester Hazardous Waste Disposal Site. The amendment provided funds for
extending the slurry wall and cap to a 20 acre area and funds to conduct a
pilot study to optimize the ground water treatment system. This approach to
the site was approved by Christopher Capper during a brieftng by Mel Hohman,
Region 1 Superfund Coordinator, on March 30, 1982.
Attached for. your approval is a Record of Decision with accompanying
briefing summaries. and supporting documentation which were considered in the
selection of the cost-effective remedial action for the Sylvester Site. If
you feel the need for a briefing on the contents of the Record of Decision,
I can do 50 at your convenience.
Attachment
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Record of Decision
Remedial Alternative Selection
Site:
-
Sylvester Site, Gilson Road, Nashua, New Hampshire
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Analyses Reviewed:
I have reviewed the followini documents describing the
analysis of cost effectiveness of r~medial alternatives at the
Sylvester Site:--
Sylvester Hazardous Waste Dump Site Containment and
Cleanup Assessment, Roy F. Weston, Inc., January 1982.
- . Staff summaries and reco~mendations
Description of Selected Option:
- >'Installation of a slurry wall around a 20 acre area.
Installation of a cap over the 20 acre area.
Treatment of the ground water contained within the
s 1 u r ry wall.
Declarations:
Consistent with the Comprehensive Environmental Response,
Compensation and Liability Act of 1980 (CERCLA), and the
National Contingency Plan, I h~ve determined that the
co~tainment and treatment strategy for the Sylvester site is a
cost-effective remedy~ and that it effectively mitigates and
minimizes damage to, and provides adequate protection of public
health, welfare and the environment. I have also determined
that the action being taken is appropriate when balanced against
the need to use Trust Fund money at other sites.
. .
I have determined that the treatment of the contained
contaminated ground water is necessary due to the uncertainties
of the slurry wall and cap and other geological conditions of
the site to adequately contain the contaminant plume. The
proper evaluation and select~on of the treatment system is being
conducted by the State of New Hampshire under a cooperative
agreement. I have determined that it is necessary to proceed
with the installation of the slurry wall and cap concurrent with
pilot studies for evaluating treatment processes. I will make a
future decision on the necessary ground water treatment
processes after the State has completed its technical analysis
and evaluation. /
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Rlta W. Lavelle
Assistant Administrator
Offi.ce of Solid Waste and Emergency Response
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Sylvester Site Remedial Action
Briefing Document
o
Purpose of this briefing is to obtain AA approval for the
remedial action plan ~ecommended by the Region and the State
for the Sylvester Site. A "Record of Decision" has been
prepared to document the approval.
The Sylvester Site orginally was a six ac~e site that 'was
used as a sand borrow pit for an undetermined number of years.
In the late 1960's, household refuse, demolition materials,
chemical sludges and hazardous liqu~d wastes were disposed
of at the site at various" times.
o
o
It is estimated that the site had been used for hazardous
waste disposal for approxima~ely five years. During the
period of January to October 1979, over 800,000 gallons of
hazardous wastes have been documented as being disposed of
at the si-te.
o
Groundwater, air, and to a lesser extent, surface water
contamination are of concern at the Sylvester Site. Public
water supply transmission lines have and will continue to
be extended to homeowners down-gradient of the site.
"EI:1ergency (EPA) funds have been utilized to retard move-
ment of the main contaminant plume to the _Lyle R~ed ~t:oo~
and other down-gradient groundwater and surface water -
receptors (th~_Nashua Riv~).
o
Unrestricted surface release of groundwater contaminants (Lyle
Reed Brook) would cause severe odor problems to adjacent
residential areas.
o
Roy F. Weston completed a feasibility study/remedial
investigation in January, 1982, as required by the existing
Cooperative Agreement. Five alternatives were considered
in detail as follows:
Hydrologic Isolation
(no containment)
$11,667,-000
Treatment (35 GPM)
with 20 acre slurry wall
Treatment (35 GPM) witn
20 acre slurry wall &
surface cap
8,839,000
9,012,000
Treatment (100 GPM) with
20 acre slurry wall & surface
cap
Split System/Trea~~ent
(100 GPM) with 14 acre
slurry wall & su~face cap
8,660,000
12,303,000
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The costs noted above include the present worth cost of
both capital and 0 & M costs for the project life (varied
with alternative). Each alternative was determined to
effectively mitigate damage and provide adequate protection
of public health, wel~are, and the environment.
o
A public meeting was held in Nashua on March 30, 1982.
Approximately 150 people were in attendance. The State
presented a summary of results and recocmended remedial
action to those in attendance for review and comment.
While no substantial criticis~ regarding the remedial
action plan wa~noted, the public was concerned about
the timing of the clean-up and urged that the State,
initiate action as soon as possible. ErA transmitted to
the public meeting concurrences regarding approval of the
plan recently received from EPA Headquarters.
Future public meetings are planned by the State as part
of the Community Relations Plan to update concerned citizens
regarding progress in the clean-up program.
"
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The State has taken the le~on enforcement actions regarding
this,site. Recently, a jury award of S14 million resulted
from action in State court. It is highly unlikely, however,
that defendants in this matter have assets available to
satisfy the court decision. It is likely that property
liens and other alternative cost-recovery strategies will,
to the extent possible, be pursued.
The recommended alternative includes the installation of
a slurry wall containing 20 acres (the original 6 acres
and adjacent areas to which groundwater contamination has
spread) and an impervious capr In addition, pending the
results of pilot studies scheduled to begin during the
summer, 1982, the design of groundwater treatment facilities
will be completed. Careful review and evaluation of the
pilot study data and recommendations will occur prior
to the start of design. The State has agreed with this
approach. ..
o
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The "Record of Decision" certifies that:
The selected remedial action is a cost-effective
remedy for th~ site
The installation of the slurry wall and surface cap
constitutes the first phase of the remedial action plan
The approval of necessary groundwater trea~~ent ~rocesses
will be mace after the State has completed its tech-
nical analysis and evaluation
Monies are available in the Fund to finance the remedy
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o The following actions are required to move the project into construction:
- Approve proposed remedy
- Complete slurry wall and cap design
and complete/award construction contract
AA, OSWER
State
- Complete treatability studies
- Approve propo~ed treatment system and
amend Cooperative Agreement
State
AA, OSWER
Design treatment system
State
- Construct treatment system
State
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.. .,-lED ..;AL
IMPLEMENTATION ALTERNATIVE
SYLVESTER SITE
NASHUA, NEW HAMPSHIRE
JULY 15, 1982
SELECTION
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HISTORY
The Gilson Road hazardous waste dump site is located in the
City of Nashua, New Hampshire, off Route 111, in the south
easterly corner of that community. See Attachcent A for its
location. The 6-acre site had been used as a sand borrow pit
for an undetermined number of years. At some time during the
late 1960's, after-much of the sand had been removed from the
property, the operator of the pit began an unapproved and
illegal waste disposal operation, apparently intending to
fill,the excavation. Household refuse, demolition materials,
chemical sludges, and hazardous liquid chemicals all were
dumped at the site at various times. The household refuse
and demolition material were usually buried, while the sludges
and hazardous liquids were either mixed with the trash or,
allowed to 'percolate into the ground adjacent to the old sand
pit, or were stored in steel drums which were buried or placed
on the ground surface.
The illegal activity at the site was first discovered in late
1970. After several court appearances and court actions, an
injunction was issued in 1976 which ordered the removal of
all caterial from the site. This injunction was ignored by
the operator.
The first indication that hazardous wastes were also being
dumped occurred in November 1978 when'State personnel observed
drums being stored at the site. A court order was issued in
October 1979 prohibiting. all furtner disposal of haza~dous
wastes on the site.
It is estimated that the site had been used for hazardous
waste disposal for approximately 5 years. During the period
from January to October 1979, over 800,000 gallons of hazardous
wastes have been docucented as being disposed of at this site.
With the dump having been used for about five years, the total
. volume of waste which has been disposed of there is likely
substantial.' ' ,
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Clean-u~ activities ~egan as soon as legal access
prope~ty could be obtained.
In the period of May - June 1980, the 1314 drums, which were
accessible were removed by a contractor and disposed of at
approved sites in New York and Ohio.
to the
Groundwa ter testj.ng and moni toring was performed and in
. July 1981, a report investigated the extent of the contami-
'nation problem and determined that there were high concen-
trations of heavy metals and volatile and extractable organics
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, in the groundwater under the si te. The contamina.ted g.round-
water formed a plume which was moving from site toward Lyle
Reed Brook at the rate of 0.8 to 1.6 feet per day.
CURRENT STATUS
ContaDinant migration exists in groundwater and air, and, to
a lesser extent, surface water. Monitoring of groundwater and
air will continue during the EPA emergency action (groundwater
recirculation) to determine movement/migration of contaminants.
,-. Surface water discharge to the Lyle Reed Brook from contaminated
,- -, groundwater could,_if uncontrolled, ha.ve the dual effect of
surface water degradation with anoxic conditions and odors
generated from volotile organic co6pounds. Potential discharge
of contaminants to the Nashua River constitutes a secondarv
effect from the site. -
The groundwater recirculation system is a temDorarv means of
retarding movement of the contaminant plume. The implementation
of the remedial action will constitute the permanent long-
term remedy...
The feasibility study published by Roy F~ Weston, Inc. in
January, 1982, identified five alternatives for remedial action
at the Sylvester Site as follows:
~ .
Hydraulic Insolation
(no containment)
Treatment (100 GPM)
with 20 acre slurry wall
Sll,667,000.
8,839,000*
Treatment (35 GPM) with
slurry wall and ~urface cap
,Treattlent (100 GPM) with
"20 acre slurry wall &
,surface cap - .
9,012,000.
8,660,000.
Split 'System/Treatment
(100 GPM) with 14 acre
slurry wall and surface cap
*(Present worth cost fQr capital and 0 & M costs
for life of. the project)
12,303,000.
Each of the alternatives suocarized above would effectively
mitigate damage and provide adequate protection of pUblic
health, welfare, and the environment.
On March 30, 1982, at a public hearing in Nashua, New Hampshire,
the findings anc recommendations of the Weston Report were
presented by the State of New Hampshire. While no definitive
criticism of the remedial action plan was raised, the,public
urged implementation of the clean-up plan as soon as possible.
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. 'EPA representatives transrni ;;i:ed i;o the public verbal concurrences
regarding approval of t~e clean-up plan recently ~eceived from
EPA Headquarters.
Prior to the public meeting, a presentation of the findings of
the Weston Report was ma~e to EPA Headquarters with opportunities
for comment and revisions to the report by the State. Approval
of the remedial action plan was made by Acting AA, OSWER, prior
to public meeting. The Region had previously reviewed arid
submitted comments to the State regarding the study. Based on
'. .a review of all available data, findings, recommendations of
current and earlier technical studies,. the Region recommended
approval of the proposed remedial actron plan.
RECOMMENDED ALTERNATIVE
Section 300~67(j) of the National Contingency Plan states that
the appropriate extent of remedy shall be determined by the
lead agency'.s selection of the remedial alternative which
the agency dete~ines is cost-effective (i.e., the lowest
cost alternative that is technologically feasible and reliable)
and which effectively mitigates and minimizes damage to and
provides adequate protection of public health, welfare, or the
environment. Based on our evaluation of. the cost-effectiveness
of each of the proposed alternatives, the comments received
from the public, information froe earlier technical studies,
and information from the State, we have determined that the
On-Site Containment/Treatment strateqy identified in the
feasibility study meets the NCP criteria.
The remedial action plan selected includes the installation
of a 20 acre slurry wal~ and surface cap with treatment of
groundwater (100 GPM) for approximately 6.2 years. Total
capital costs are shown in Attacbment B. Current estimates
for annual 0 & M costs ~re $750,000. However, one of the
crimarv concerns to be addressed during pilot studies will
be the reduction of operating costs for a arounciKa.t.~.Lt.:.e.at-
m!tltt_h~_ili 1;Y. -
PROPOSED ACTION
We request your approval of the 20-acre slurry wall and surface
. cap and groundwater treatment as the remedial implementation
option for the Slyvester Site. Attac~ents B - H provide
additional informatiQn to support the documentation for this
decision.
TENTATIVE SCHEDULE
Advertise and receive bids
By the State during
July, 1982
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A~ard contract and begin
construction of slurry wall
and surface cap
Followin~ bid receipt,
tabulation and reco~endation
of award to low, responsive,
responsible bidder
Public meeting
During late summer or
fall, 1982, by State of
New Hampshire
If you have any questions, please call John F. Zipeto at
'223-3468.
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Attachments:
As not:ed
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FIGURE 2-1
LOCATION MAP
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'SCALE ,": I MilE
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NEW
HAMPSHIRE
NASttUA
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7.
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TABLE 10-1
ESTIMATED COIlSTRUCTION COSTS
GROUNDWATER COiJTA INMENT A:~D TREATMENT rAC I L I TI ES
GILSON ROAD HAZARDOUS WASTE DUMP SITE
Item
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..Goundwater Containment
Estimated COSts
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1 .
Slurry Wall
2.
S 2,100,000
436.000
Su rface Cap
3.
4.
Recovery We 11 s
50,000
Gas Ventings System
65.000
S.ubtota 1 ..
$ 2,651,000
s.
6.
Engineering and Contingencies (25~)
662,500
28.500
Land AcquiSition
Total Containment Cost
. S 3.342,000
Groundwater Treatment
1 .
Construction of Treatment Building and
Ut i 1 it i es .
s
462.~OO
306,300
2.
Chemical Precipitation and Neutralization
Steam Stripping and Incineration
234.500
274,600
Aerated Lagoons and Effluent
Electrical, Instrumentation, Piping and HVAC
366.700
1,644,100
Subtota 1
Eng~neering and ContingencY(30~}
~9J_.900
$ 2,138,000
Total Treatment COSt
. rota I Containment and Treatment Cost
S 5,480.000
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CATE:
SU8JEC'T:
P'f'OIll:
TO:
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UNITED Sr ATES ENVlRONMENT AL PROTECTIUH AGeH~l Ri/1L'D \'{,~SiE StiES
AIR & P.AZA?~JU3 rr.iUERJALS on
SEP - 3 198~ (r.,)
AlJ;USt 27, 1981
~t for ExeaptiontJnCer 40 CFR 1506.ll - Sylvester Ba%ardOJs Waste-
Site, Nashua, New ~
Wallace E.. Stickney, P.E., :oirectcr
Emriromental Ilrpct Office, Regia1 I
'-'-'~
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W;" imn N. Bedeman, Jr., ~tc:C
Office of Fec:itnl Activities (A-;o4)
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legion I is requestin; an exen;stia1 fr::m the requi.~ts of t.~e National
E:nvircnmental Pclicy Act (NEPA) an:ier 40 CFR 1.506.ll (Emergencies) am
EPA's.NEPA Rules and Begulations under 6.106 for the abatement of existi.~
public health hazards at the sylvester Hazardous Waste Site in Nashua, .
New Bampshire.
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~ site, whicb bas been under study for sc:.ne dme, is loc:atea near a.
residential area incluain; a near by tniler park. Residents £ran the
area ana state authorities are ooncemed about "i~tne health hazards, -
i=5sible explosions and fire.
'!he site itself is an ~oned gravel pit were the wast~ has been ~
over a ten year period. '!he site has been fenceQ off and ten cbservation
wells were installec3 tQ test for groundwater ccntaminaticn. P.esul t.!'
saItples show high levels of organic chemicals, iron and manganese ir,
pl1.Jne -traveling about one foot per day ~ Lyle P.eed Brook, whic."i
t:ca.rQers the tniler paJ:k. .
E?A and the State of. New ~ire have recently sic;ned a c:coperative
ag"eenent to implement the =nstrUction of t::eat:nent facilities on t.'1e
site. CcnstrUcticn is ~..ed to beqin wit.hin several m::nths.
Since the desiqn of the remedial.facilities is nearly c:::at;)leted, Reqion !
. telieves that the application of NUA -,.,ould cause significant delay in an
already existin;; emargency situation. 'n1erefore, we request the exemptio;
uneer t.~e ab:we refe~ provisions of t..~e a:Q and EPA NEPA P.egulaticr.s
I wculd appreciate- your c;uic:k response to our request.
cc: l'4.ic::-..ael C::iok, Di~..cr
Office of E::nergenC'j an:: ?e.~ial ?.es~nse
tcug Cohen (W"c-548)
Office of ~~e."1cy and Re.'!'£.dial ReS;C~
John BaCkler ./
t?A, Region I
Mike tcnohue,
NB Water SU?,91y ,Pollution Cont:ol.
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. ~'A'- moo, Ot... 3.761
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(D)
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WASI-II:-1GTON." O.C. 20460
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AOMINIS"i~... TCR - '
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MEMORANDUM
SUBJECT:
Reg~on I Request that the Superfund
the Sylvester Hazardous Waste Site,
Receive Special Consi~eration under
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~li 1 1 i am N. Hedeman,. Jr. II 01 rectm f.1. n... I~'
Office. of Federal Activities ....~~~.
Wallace E. Stickney, P.E., Director
Environmental Impact Office, Region I
""
Remedial Ac:ion for,
~ashua. New Hampshire
NE?A
SEP~..l'J~
FROM:
TO:
This is in response to your August 27, 1981 memorandum. Both OERR and OFA
ag~ee that the potential to create an emergency because of the release of
hazardous waste from the Sylvester site is significa~t enough to qualify it
for alternative National Environmental Policy Act (NEPA) arrangements under
. 40 CFR 1506.11 of the Council on Environmental Quality.(CEQ) regulations.
You may, therefore. proceed with' your plans for design of remedial facilities.
along with the work under your cooperative agreement with the State of New HampshirE
to implement construction of treatment facilities, without satisfying the
procedural requirements of NEPA and the CEQ regulations. This exemption is
granted with the understanding that whatever remedial acti~ns that must be
taken are carried out in the most environmentally safe manner possible.
If there any questions please contact Frank Rusincovitch of my staff on (FTS)
755-9368.
C~.
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Michael Cook (WH-548)
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COMMISSIONERS
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DELBERT F. DOWNINC
RUSSELL DUMAIS
HERBERT A. FINCHER
RICHARD M. FI.YNN /'DH ~1) ~ c.d t'.d
JAMESJ. "ACE UDE -t.V~ ~~~t,. a.nd ::T")g~~~ ~~ ~~ .
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RONAUJ F. I'OLTAIC
WtWAM T. WALLACE.. M.D- M,~.H, ~ E?~ - Y'. (!j gJ(J4;, 95
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June 9,1982
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Mr. John F. Zipeto
Office of Uncontrolled Sites
Air &. Hazardous Materials Division
Environmental Protection Agency
John F. Kennedy Federal Building
Boston, Massachusetts 02203
Ui:~Ui~m~lL~~ ,(iA~iE gritS
~lR & HAZARDQUS MAmuALS arL
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Dear r~r. Zi pete:
This letter serves to confirm my telephone conversation with you on
June 8, 1982. The State of New Hampshire has co~pleted its review of the
draft contract documents for the Gilson Road hazardous waste site slurry.
trench cut-off wall and cap project. GHR Engineering Corporation is pre-
pared to inc~rporate the State's comments in~o the final containment
design and provide the Sta~e with the final contract documents by June 10,
1 982. .
As you are aware, the State and Environmental Protection Agency are
facing severe construction time constraints that recuire the completion'
of the containment-project before the onset of freezing weather. In light
of this requirement, it is my understanding the Environmental Protection
Agency is reviewing the draft containment contract documents and will
- ... contact the" State by J'iitfe 9,' 1982 with any signi ficant comments that
would prevent the submittal of the final contract documents to the State
and Env;ronmen~a1 P~tec:ion Agency by June 10, 1982.
Should you feel it necessary to have State and Environmental Protec-
tion Agency representatives ~eet with Camp, Dresser & McKee to clarify
any desi9n qu~stions, please call this office immediately. Likewise, we
would be hapoy to have our engineers attend any meetings with your office
for the pur?ose of expediting this project.
Should you have any questions on this matter, please contact me at
271-2229,
T:::~/~h
Sincere lv,
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Thomas E. Roy, pi.
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UNITED STATES ENVIRONMENTAL PROjECTION AGENCY
REGION I
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60 W!STVIEW STFIe:r. 1.5X~Gi"ON. MASSACHUSEi"'iS 021'73
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UNCDNTRDLLED WASTE sms
AlP. & HAl~RDDUS MAiERIALS DI'.',
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June 23, 1982'
Mr. Michael Donohue
State of New Hampshire
WS&PCC
Hazen Drive - P.O. Box 95
Concord, NH 03301
JUl
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REF:
Final Feasibility Report on Gilson Road Hazardous Waste Site, Nashua, NH
,
Dear Mr. Donohue:
I hav~ reviewed the subject report prepared by Roy F. Weston as a special condition of
the existing coopera.tive agreement on the Cilson Road Hazardous Waste Site. Based
on this review, I approve the report in its entirety.
The addi~ional investigations of optimal cost-efiec:-Jve flow rates will be separately
reviewed, as these are new requirements outside of !.'ie original scope of work for this
r~o~ '
aSinC~Y'
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Carl L.. Eidam
Pro ject Officer
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Merrill Hohman, EP A Region I
John Zipeto, EPA Region I V
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. UNITED STATES ENVI~ONMENTAL. P~OTECT10N AGENCY
REGION I
50 wesTV'EW STJ'e:r. L.!XING'TON, MAS$ACHUSE'M'S 02'~
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UNCOHTRD1.I.ED WASTE SlitS
AIR & HAZARDOUS MATIRlALS Dl'J.
JUl G 198:
June 30, 19&2
Mr. Michael Donohue
State of New Hampshire
WS&PCC '
Hazen Drive - P.O. Box 9'
Concord, NH 03301
REF:
Groundwater Treatment Pilot Studies at Gilson Road Hazardous Waste Site,
Nashua, New Hamsphire ..
Dear Mr. Donohue:
I have reviewed the draft plan of StUdy for the subjeCt pilot treatment plant and based
on this review, approve the plan of StUdy in its entirety.
In developing the aCt\Jal experimental design for Task IV - Pilot Plant Expedmental
Runs, considerarion muSt be given to determining the n~d for biological treatment as
a par; of the proc~ train. The origi~ Weston Report indicated a. reduc:-Jon in
ex-:ac:able organics through the metals precipitation/air stripper units. While the
reduc:-J.ons noted in the original report were not large enough to preclude the n~d for
biological trea.tment, variable inputs during the pilot plant studies may alter this
conclusion. In any event, I would like to s~ t.'"1e whole issue of the need for biological
treatment as it r~lates to removal e!!iciences of the front end of the process train
finalized as a par'": of -this stUdy. .
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-If you have any questions or comme.'1ts, please conta~ me.
SinC<;'~) .
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Carl I- Elda.m
ProjeCt Officer
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Me:orill Hohma.n, Superfund Coordinator, EPA Region I
john Zipe!o, E? A Region I J
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UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
REGION I
60 WESTVIEW STRE;T.I..EXI.N~ON. MAS$ACMUSET'iS C2,T.I
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Mr. Michael Donohue
State of New Hampshire
WS&PCC ,
Hazen Drive - P.O. Box 95
Concord, NH 0330 1
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AIR & HAZARDOUS MATERIALS DI~i
June 30, 1982
JUL
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REF:
Revie-.v. of Final DocumentS, Plans, and Specifications for Cap' and
Containment Wall ConstruCtion at the Sylvester Hazardous Waste Site, Gilson
Road, Nashua, New Hampshire
Dear Mr. Donohue:
I have reviewed the subjeC1 documentS pertaining to the Gilson Road Hazardous Waste
Site, Nashua, New Hampshire. Based on this review, the documentS are conditionally
approved, provided that the following changes/additions are made: .
1.
Page 306-27, SeCt~on 3.70 - The proteCtion and allowance for continued
operation of the existing groundwater recirculation system is inadequately
addressed in !his seCtion. It would be bener addressed in Section 300 -
Execution of Work and should specifically identify the componentS of the
system that require proteC1ion (l.e. interceptor wells, piping and manifolds,
recharge trench, and control center/oftice trailer). Proteetion should
include provisions for continuous vehicular access to these areas to allow tor
normal maintenance an~ should specify that power interruptions to the
system necessitated by pole relocation must be minimized.
2.
Page 306-17, Section 3.10 - The construCtion seq~nce specified in this
seCtion (l.e. starting cutofi wall at G2-14- and proceeding counter-clockwise)
is inconsistent with the construction sequence in the callout on dra'wing no.
SG-2 (from G2-12 clockwise). The sequence should be as specified in SeCtion
3.10.
.
If you have any questions or commentS regarding the above, please call me a': my
office.
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Merrill Hohman, EP A Region I
John Zipeto, EP A Region I J
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