>EPA
United States
Environmental Protection
Agency
Office of
Emergency and
Remedial Response
EPA/ROD/R01 83/002
November 1983
Superfund
Record of Decision:
Keefe Environmental
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TECHNICAL REPORT DATA
(Please read Instructions on the reverse before completing)
1. REPORT NO. f2. 3. RECIPIENT'S ACCESSION NO.
PA/ROD/ROl-83/002
4. TITLE AND SUBTITLE 5. REPORT DATE
SUPERFUND RECORD OF DECISION: 11/15/83
Keefe Environmental Site, NH 6. PERFORMING ORGANIZATION CODE
7. AUTHORIS) 8. PERFORMING ORGANIZATION REPORT NO.
9., PERFORMING ORGANIZATION NAME AND ADDRESS 10. PROGRAM ELEMENT NO.
11. CONTRACT/GRANT NO.
12. SPONSORING AGENCY NAME AND ADDRESS 13. TYPE OF REPORT AND PERIOD COVERED
U. S. Environmental Protection Agency Pin",' ~nT'l -
401 "M" Street, S. W. 14. SPONSORING AGENCY CODE
Washington, D. C. 20460 800100
15. SUPPLEMENTARY NOTES' '
16. A8STRACT
The Keefe Environmental Services (KES) site is located in a rural area in the
Town of Epping, NH. The site is located on approximately seventeen acres of woodland
off the north side of Exeter Road. The site is located in a State protected (Class A-
no discharges above background) watershed with wetland areas draining to the Piscassic
River. The Town of New Market has a water supply intake on the piscassic River seven
miles downstream from the site. The ground water aquifier is used as a water supply
for ten residences located close by and is the major source of drinking water for
approximately 2,000 persons within a three-mile radius of the site. The KES was
designed and constructed as a chemical waste storage and bulking facility. The site
cc .'\tains a 700,000 gallon open storage lagoon with a 100 mil. polyethylene liner.
During its period of operation, KES received over one million gallons of hazardous
wastes including toluene, methanol, acetone, MEK, glycols, waste oils, waste alcohols,
styrene cyanide and heavy metals. KES was cited on several occasions with health and
safety violations before filing for bankruptcy in January 1981.
Remedial actions included in the selected option are: removal of the contents
of the lagoon for disposal offsite at a RCRA-regu1ated facility, and removal 0 f the
lagoon liner and adjacent highly contaminated soil for disposal at a RCRA-regu1ated
facility. Estimated capital costs for this action are $500,000 with no estimated
f"Ir.M ,..,...."'+-'"
17. KEY WORDS AND DOCUMENT ANALYSIS
a. DESCRIPTORS b.IDENTIFIERS/OPEN ENDED TERMS C. COSATI Field/Group
Record of Decision.
Site Name: Keefe Environmental Site, NH
Contaminated media: sw, soil
Key contaminants: solvents (PCE, TCE,
xylene), volatile organics, glycols, waste
oils, alcohols, styrene, cyanide, heavy
me ta1s
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~T....~..... 1(\
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EPA Fo,m 2220-1 (Rn. "-77)
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Include a brief (200 words or less) factual summary of the mos! signitkant informal ion ,'untai",'" ill 110,' r,'purl. It Ih,' r"l'oll ,'On rains a
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17. KEY WORDS AND DOCUMENT ANALYSIS
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UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
WASHINGTON, D.C. %0410
tOI
A 933
OFFICE OF
SOLID wASTE AND EMERGENCY RESPONSE
Subject:
Record of Decision for the Keefe Environmental
Services Site, Epping, New Hampshire ~ \
I " .
william N. Hedeman, Jr., Direct JUL "'~'-uJ-V
,Office of Emergency and Remedia~onse
Lee M. Thomas, Assistant Admini:t::l:r
Office of Solid Waste and Emergency Response
From:
To:
. .
The attached Record of Decision is presented for your
authorization of Remedial Action at this site.
I am requesting your approval of the selection of the cost-
effective remedial action for the Keefe' Environmental Services
site in Epping, New Hampshire. The recommended remedial
alternative is the off-site transport and disposal of hazardous
substances. The proposed remedy is cost-effective, helps protect
public health, welfare and the environment and the remedy is
consistant with the permanent remedy.
The design and bid documents for the proposed remedy are
completed and by prompt approval of this remedy, it is possible
to have the removal underway this calendar year. This would eliminate
the possibility of another emergency action to prevent the overflow
of the lagoon that might otherwise occur this fall.
Recommendation of this action is endorsed and supported by
the Regional office, the State of New Hampshire Water Supply and
Pollution Control Commission, the Town of Epping and the residents
of Epping who attended the August 11, 1983, public meeting.
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UNITED STATES
ENVIRONMENTAL PROTECTION AGENCY
REGION t
8OSTON.M~SACHUS~ ~
Date:
October 21, 1983
From:
Record of Decision. for Keefe Environmental Services Site,
Epping" New Hampshire
Mi~~: D~~d, Regional Adml
trator
Subject:
To:
Lee M. Thomas, Assistant Administrator
Office of Solid Waste and Emergency Response
Attached for your signature is copy of the Record of Decision
(ROD) prepared for the Keefe Environmental Services site in
~pping, New Hampshire. The analysis for the cost-effective
remedial action was developed via a Fast Track Feasibility Study.
which focused on the clean up of the 700,000 gallon lagoon on site.
This feasiblity study was reviewed and found technically adequate and
consistent with the National Contingency Plan by Region I and
members of your staff. In addition a Remedial Investigation
and Feasibility study will be completed by July, 1984 to
address the ground and surface water contamination problems at
the site.
This Record of Decision is endorsed and supported by the:
Regional Office, the State of New Hampshire Water Supply and
Pollution Control Commission, the Town of Epping and the
residents of Epping who attended the August 11, 1983 public
meeting.
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'.
Record of Decision
Remedial Action Alternative Selection
Site:
Keefe Environmental Services Site, Epping, New Hampshire
Analysis Reviewed:
.> I have reviewed the following documents describing the analysis
of cost-effective remedial actions developed for the Keefe
Environmental Services site (KES).
- Fast Track Feasibility Study for KES waste site, Epping,
New Hampshire, Tighe & Bond/SCI, Inc., July 29, 1983.
Revised August 31, 1983.
- Staff summary and .recommendation.
.
.
Description of Selected Option:
- Removal of the contents of the lagoon for disposal
offsite at a facility in compliance with Subtitle C
of the Resource Conservation and Recovery Act (RCRA).
- Removal of the lagoon liner and adjacent highly
contaminated soil for disposal at a facility in
compliance with Subtitle C of RCRA.
Declarations:
Consistent with the Comprehensive Environmental Response,
Compensation, and Liability Act of 1980 (CERCLA) and the National
Contingency Plan (40 CFR Part 300), I have determined that the
selected option is a feasible and cost-effective remedial action
that is necessary to protect public health and the environment.
I have also determined that the action being taken is consistant
with the permane~t remedy and is appropriate when balanced
against the need to use Trust Fund money at other sites. I have
determined that the off-site treatment and disposal of hazardous
substances is more cost-effective than other alternatives and
is, therefore, consistent with Section 101(24) of CERCLA.
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Lee ~. Thomas, Assistant Administrator
Office of Solid Waste and Emergency Response
,'1/./ ~)/'r3'
I
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Remedial Alternative Selection
Keefe Environmental Services Site
Epping, New Hampshire
Background
The Keefe Environmental Services (KES) site (Figure 1-1) is
located in a rural area in the Town of Epping, Rockingham County,
New Hampshire. The site is located on approximately seventeen
acres of woodland off the north side of Exeter Road (Old Route 101)
approximately two miles southeast from the municipal center of
Epping. The site is located in a State protected (Class A - no
discharges. above background) watershed with wetland areas draining
to the Piscassic River. The Town of New Market has a water
supply intake on the Piscassic River seven miles downstream from
the site. The ground water aquifer is used as a water supply
for ten residences located close by and is the major source of
drinking water for approximately 2,000 persons within a three
mile radius of the site. Approximately six to seven acres of
the total seventeen acre site were actually developed. The KES
site was designed and constructed as a chemical waste storage
and bulking facility.
KES received over one million gallons of hazardous wastes
including toluene, methanol, acetone, methyl ethyl ketone, glycols,
waste oils, waste alcohols, styrene cyanide and heavy metals.
KES was cited on several occasions, during the operational life
of the facility, with health and saf.ety violations.
KES site is on the final National Priorities List.
In January 1981, KES filed for bankruptcy and the site was
abandoned. Due to threats to the environment the USEPA began an
emergency cleanup action program at KES. Damaged drums were
overpacked and over 4,100 drums were staged in rows according to
general category.
In July 1982, EPA contracted to have a number of lab-packs,
shock-sensitive materials, water reactive materials, and flammable
materials disposed off-site. The contents of several above ground
storage tanks were also disposed off-site during this period.
In October of 1982, EPA completed a Remedial Action Master
Plan (RAMP) prepared by the zone contractor, Camp, Dresser & McKee
(CDM). The RAMP recommended a fast track feasibility study to
evaluate the remedial alternatives for the lagoon, since it
could only be used for temporary storage. This study is in
addition to the overall remedial investigation and feasibility
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The KES site contains a 117 feet x 122 feet open storage
lagoon with a depth generally ranging from approximately 7 feet
in the southwest corner to 10 feet in the northwest corner.
However, the normal level of liquid in the lagoon is approximately
4.5 feet deep. The lagoon has an estimated total capacity.of
approximately 700,000 gallons.
Much of the lagoon appears to be constructed above natural
grade and therefore above the ground water table, however, this
has not been confirmed. The walls of the lagoon were reportedly
constructed from fill material excavated on-site. Because of the
above-grade configuration surface water runoff would not enter
the facility. The lagoon is lined with a 100 mil polyethylene
liner installed by Schelgal Area Sealing Systems, Inc. of Rochester,
N.Y. The present integrity of the synthetic liner is not known.
The FIT report noted that KES claimed that a leachate
collection system was installed in the lagoon floor under the
liner, but there is no evidence of such a system. There is
evidence that liquids were dumped into the lagoon before the
installation of the liner. In order to avoid overflows, the
lagoon was drawn down by the EPA Emergency Response Team (ERT)
on five separate occasions since March 1981, using a mobile
carbon filter unit for a total cost in excess of $250,009.
Analyses of lagoon contents indicate that the lagoon is stratified
into several distinct layers with each layer exhibiting varying
concentrations of specific compounds and distinct color changes
from one layer to another. Some compounds were found to have
increasing concentrations with depth. These include. methylene
chloride, l,l-dichloroethane, trichloroethylene, tetrachloro-
ethylene, ethylbenzene, and xylenes. The lagoon was also found
to have significant amounts of heavy metals, including arsenic,
silver, copper, zinc, nickel, chromium and manganese. Cyanide
was also present in the lagoon in concentrations ranging from
less than 1 ppm at the surface to approximately 10 ppm at the
bottom.
The Fast Track Feasibility Study was supervised by the NH
WS&PCC under a Cooperative Agreement with the EPA. On July 29,
1983, EPA's Boston Regional Office released the .Preliminary
Fast Track Feasibility Study for the Keefe Environmental Services
Site Lagoon-. This report was prepared by the consulting firm
Tighe & Bond/SCI. The report was revised after the public comment
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Community Relations
Copies of the feasibility study were placed in the Town offices
and Town library for public review and comment. Press releases
and notices were placed in the local newspapers announcing the
public meeting to be held on August 11, 1983. The purpose of
. the meeting was to discuss the remedial options which have been
considered and receive input from the affected community on the
selection of the remedial action. A summary of the meeting is
incorporated into the appendix of the revised feasibility study.
Few questions were asked about the selected remedy of removal
and off-site disposal of the lagoon contents. It was agreed
upon by all present that they would accept this remedy. Several
residents'v9iced concern about on-site solidification, as well
as the no ac~ion alternative. The meeting was sparsely attended
and the proceedings were recorded for future consideration.
Enforcement - See attached.
Feasibility Study Alternatives
The object of the fast track feasibility study was to
develop and evaluate source control remedial actions which would
reduce and/or eliminate the direct contact hazards at the site
emanating from the lagoon and any off-site migration that could
result via surface runoff or ground water contamination from
potential liner failure. Table I is a summary of the capital
costs, annual operation and maintenance (O&M) costs, and present
worth costs for the alternatives.
The remedial alternatives considered are:
O. No Action. The no action alternative was rejected due to
the contamination of surface and ground waters from the overflow
of the lagoon, and the threat to public health and the environment
via ground water from the failure of the lagoon liner.
1. Continued Pump Down. This option would require periodic pump
down and provision of site security. Lagoon wastes and contaminated
soils will threaten the ground water.. The costs of lowering the
lagoon level is estimated at S120,000 per year with a net present
value of 52.3 million after 20 years of operation.
2. Lagoon Covering. Several types of lagoon cover systems were
evaluated as temporary remedial measures. The capital costs of
these systems ranged from 580,000 to 5400,000. However,
replacement of the cover system would be required every five to
ten years and the contaminated soils and lagoon contents would
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3. On-site Solidification. The on-site solidification was
evaluated and was found to be unacceptable due to the need to
investigate the ground under the lagoon to determine the need
for further remedial action and the uncertainty of the process
effectiveness. At present, none of the companies that are
developing solidification techniques could assure the stabilization
of the lagoon with its wide mixture and high levels of volatile
organic contaminants posing the risk of further release over
time. The extended period of O&M contribute to the high present
worth of this alternative.
4. Off-site Disposal. Off-site disposal was found to be the
most cost-effective option that posed the least threat to the
Class A w~tershed and the surrounding populations. This
alternative includes the removal of the liquid contents of the
lagoon for treatment and disposal at a facility in compliance
with Subtitle C of the Resource Conservation and Recovery Act
(RCRA). It wlil also include the removal of the lagoon's sludge,
liner,. and highly contaminated soil to q disposal facility in
compliance with Subtitle C of RCRA.
5. On-Site Treatment & Discharge. The cost of on-site treatment
for the disposal of the liquids from the lagoon, is based on a
granular activated carbon treatment system that discharges directly
to. the adjacent brook. This cost estimate may be low since it
does not account for any additional treatment that may be required
. due to the high concentrations of contaminants. Additional costs
would not be available. until after a pilot plant study. Although
this treatment system is reliable at typical effluent discharge
levels, the ability to adequately treat the effluent to drinking
water standard levels or to obtain a variance to the discharge
criteria for a Class A watershed will also impact the final cost
of this alternative. The sludges and contaminated soils would be
addressed in the overall site feasibility study. The costs of
disposing the sludges and contaminated soils are not included in
this summary. Therefore, this option is not cost effective when
compared to alternative 4 since this option cost more and does
provide less protection to public health and the environment.
6. On-Site Incineration. The alternative of on-site incineration
for the disposal of the liquids from the lagoon, was rejected for
cost and technical reasons. The relatively low BTU content and
high percent of water makes this waste difficult to incinerate.
In addition, the delays involved with permitting and site mobili-
zation drastically reduce the cost-effectiveness of this alternative
and raise the possibility of emergency pump downs in the interim.
The sludges and contaminated soils would be addressed in the
overall site feasibility study. The costs of disposing the
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Recommended Action
The recommended alternative is off-site disposal of ,the
liquid, sludge, liner, and highly contaminated soil from the
lagoon. This alternative is the less expensive option that
"" mitigates the threat to public health and the environment from
. "the lagoon, with minimum impact on the overall site remedial
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Table 1
Cost Analysis of Alternatives
Keefe Environmental Services
Epping, New Hampshire
Capital ( 2)
Alternatives Costs Annual O&M Present Worth
I
opera- \ Sec~ri t~ / (1) I \
tional monltorlng 20 yr. 30 yr.
I ( S) I ( $ ) I ( $ ) ( S ) ( $ )
80.,000
102,300
745,000
r
2.747.000\
857.000\
1.412.000\.
o
1
I
\ 120.000
\ 28.000(7)
r
. 10. No Action I
\1. Continued
Pump Down
\2. Lagoon
Covering
\3. on-site \570,000
solidification
\4. Off-site
Disposal
I
\5. ~~::~;:nt \625.000(51
6. On-site \1.1-1.6
incineration million(6)
\ I
102,300
(3) 2,353,000
500,000(4)
o
o
\1.293.000\
\ 500.000\
500,000
32,200
34,800
o
34,800
990,000
1
1,046,000
o
34,800
\ 1.4-1.9 I 1.5-2.0
million million
I I
NOTES:
(1) Security costs for 24 hours/day, 365 days/year at $67,500/year.
Monitoring of two streams and three groundwater monitoring wells
quarterly for full priority pollutant analysis at $34,800/year.
(2) Discount rate used was 7 1/8% for EPA Region I.
(3) Both monitoring and site security included.
(4) The capital cost of $500,000 includes actual estimates of
approximately $400,000 and a 25% contingency of $100,000.
(5) The capital cost of $625,000 is the total cost of leasing a package
unit for twO to four months and includes the leasing and operational
costs for the entire liquids removal operation. The total cost does
not include the cost of disposing the sludges and contaminated soils,
thus understating the total cost of on-site treatment.
(6) The total cost does not include the cost of disposing the sludges and
contaminated soils.
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Figure 1-; . SITE PLAN: KEEFE ENVIRONMENTAL
SERVICa EPPING. NEW HAMPSHIRE
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