United StttM
Environment** Protection
Agency
Office of
Emergency end
Remedial Response
EPA/ROO/R01-85/010
September 1985
Superfund
Record of Decision
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TECHNICAL REPORT DATA
(Please read Instructions on the 'e~ene bel ore completing)
1. REPORT NO. 12. 3. RECIPIENT'S ACCESSION NO.
EPA/ROD/ROl-85/0l0
4. TITLE AND SUBTITLE 5. REPORT DATE
SUPERFUND RECORD OF DECISION September 23, 1985
Beacon Heights, CT 6. PERFORMING ORGANIZATION CODE
7. AUTHOR(SI 8. PERFORMING ORGANIZATION REPORT NO.
9. PERFORMING ORGANIZATION NAME AND ADDRESS 10. PROGRAM ELEMENT NO.
1,. CONTRACT/GRANT NO.
~2. SPONSORING AGENCY NAME AND ADDRESS 13. TYPE OF REPORT AND PERIOD COVERED
U.S. Environmental Protection Agency Final ROD Report
401 M Street, S.W. 14. SPONSORING AGENCY CODE
.
Washington, D.C. 20460 800/00
15. SUPPLEMENTARY NOTES
16. ABSTRACT .
The Beacon Heights Landfill site is located two miles east of the intersection of
Connecticut Routes 8 and 42 in Beacon Falls, Connecticut. From the 1920's until 1970
the site was known as "Betkoski' s Dump" and consisted of approximately six acres on
which active dumping occurred. According to records at the Connecticut Department of
Environmental Protection (CT DEP), waste accepted at the dump included municipal ref-
use, rubber, plastics, and industrial chemicals and sludges. Landfill operations con-
sisted primarily of open burning along with burial of noncombustibles. In 1970, the
Betkoski property and adjacent properties totaling 83 acres were purchased by the
Murtha Trucking Company, and the name was changed to Beacon Heights, Inc. Landfill. At
this time, the landfill area was expanded to approximately 30 acres. Records of the
CT DEP, including a 1973 report by the landfill engineer, listed rubber, plastics,
oils, hydrocarbons, chemical liquids and sludges, and solvents as being disposed of at
the landfill by the trucking company.
The selected remedial action for this site includes: excavation of Betkoski's Dump
and other contaminated soils for consolidation with the main landfill prior to closure:
RCRA capping of the consolidated wastes including gas venting and stormwater management
controls: installation of a perimeter leachate collection system: collection of leach-
ate and transpor~ation to a licensed waste water treatment facility or onsite treat-
(see attached page)
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117. KEY WORDS AND OOCUMENT ANALYSIS
Ia. OESCRIPTORS b.IDENTIFIERS/OPEN ENDED TERMS C. COSATI Field/Group
Record of Decision
Beacon Heights, CT
Contaminated Media: gw, sw, soil
Key contaminants: voc s, benzene, chlorobenzE ne,
chloroethane, 2-butanone, bis(2-chloroeth 1)-
ether, xylenes
18. DISTRIBUTION STATEMENT 19. SECURITY CLASS (T/lis Reporr) 21. NO. OF PAGES
Nnnp 7~
20. SECURITY CLASS (Tilis page) 22. PRICE
None
<,
EPA "orin 2220-1 (R.... ~-77)
PREVIOUS EDITION IS OBSOL.ETE
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INSTRUCTIONS
1.
REPORT NUMBER
Insert the [PA report number as it appeus on the coyer of the publi!:ation.
LEAVE BLANK
2.
3.
RECIPIENTS ACCESSION NUMBER
Reserved for use by each report redpienl.
c.
TITLE AND SUBTITLE
Title should indicate dearly and brieny the subject covera~e of the report. and be disl'Jay~'d promill~'ntly. s~.t sU!>lit"', if us~..I. ill smalkr
type or otherwise subordinate it to main title. When a reporl is pr~":lred in mOH' than Oll~' volume, n'",~al Ih~' primary titl~', a.1I1 v'll:lm~'
number and inc:lude subtitle for the specific title,
REPORT DATE
Each report shaD carry a date indicating at least month and year. Indicate Ihe !>asis 011 whkh il "'ilS sd~.~'t~'d (c'./(.. JD'I' Ofils/lC', liD'" of
.pproWl/, d41~ 01 pr~ptlrtllion, ~IC.).
I.
e.
PERFORMING ORGANIZATION CODE
Leave blank.
7.
AUTHORCSI
Give name(s) in conventional order (John R. Doe, J. Ro/x'" Doc', c'II'.). list aUlhor's ilflilialloll if it .liff~'r' frlllll Ih~' I~'rfurminj: .
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SUPERFUND RECORD OF DECISION
Beacon Heights, CT
Continued
ment followed by discharge to a tributary of HoCkanum BrooK; extension of a public
water supply; fencing; installation of a more extensive ground water monitoring
system; and enforcement of State and local institutional controls on ground water
use in the impacted area. Total capital cost for the selected ~emedial alternative
is estimated to be $17,397,000 with O&M costs approximately $235,OOGper year. In
addition, a Supplementary Decision Document will be prepared during the design phase
to justify the decisions reached on the manner and location of leachate treatment,
the extent of excavation in the satellite areas, and the need for air pollution
controls on the landfill gas vents.
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RECORD OF DECISIO~
RF~EI)I AL ALTFFNP.TIVf S "~LECTION
,.
SITE: Beacon Heights Lanctfill, Beaco" Falls, Connecticut
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DOCUMENTS REVIEWED:
I am basing my decision primarily on the following documents
describing the analysis of cost-effectiveness of remedial
alternatives for the Beacon Heights Landfill site:
,
1.
Remedial Investigation for the Beacon Heights Landfill
site, Beacon Falls, Connecticut, April 1985, prepared for
u.S. EPA, Region 1, by NUS Corporation, Pittsburgh,
Pennsylvania.
2.
Feasibility Study for the Beacon Heights Landfill site,
Beacon Falls, Connecticut, August 1985, prepared for the
U.S. EPA, Region 1, by NUS Corporation, Pittsburgh,
Pennsylvania.
3.
Summary of Remedial Alternative Selection (attached)
Community Relations Responsiveness Summary (attached)
~.
4.
5.
Remedial Action Master Plan for the Beacon Heights Landfill
site, Beac6n Falls, Connecticut, June 1984, prepared for
the U.S. EPA, Region 1, by Camp, Dresser and McKee, Inc.,
Boston, Massachusetts.
7.
The National Oil and Hazardous Substances Pollution
Contingency Plan, 40 C.F.R. Part 300.
8.
40 C.F.R. Part 264, Standards for Owners and Operators of
Hazardous Waste Treatment, Storage, and Disposal Facilities.
DESCRIPTION OF SELECTED REMEDY
REMEDY:
- Excavation of Betkoski's Dump and other contaminated soils for
consolidation with the main landfill prior to closure.
-'RCRA capping of the consolidated. wastes, including gas venting
( with air pollution controls if determined necessary during
design ), and stormwater management controls. .
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- Collection of leachate a~d transport~tion to a licensed wast~
water treatment facility or on-site trp.at~e~t f0llowed by
discharge to, a tributary of Hockanum Brook.
- Extension of a public water supply along Skokorat Road to the
next municipal supply and along Blackberry Hill Road to the
demographic limits.
- Enclosure of the site with security fencing.
- Installation of a more extensive groundwater monitoring system.
..
OPERATION AND MAINTENANCE:
Maintenance will include lawnmowing of the grass cover overlying
the cap, inspection and repair of the cap, repair of da~age to
the security fence, removal of obstructions from the stormwater
management and gas venting systems, and regrading as necessary.
Monitoring will include sampling and analysis of upgradient and
downgradient monitoring wells and surface waters and collected
leachate. Operations will include collection of leachate and'
transport to an offsite facility or operation of an onsite .'
treatment facility. (To be decided during design phase).
DECLARATIONS
Consistent with the Comprehensive Environmental Response,
Compensation, and Liability Act of 1980 (CERCLA), and the National
Contingency Plan (40 C.F.R. Part 300), I have determined that at
the Beacon Heights Site, a full RCRA-approved cap, leachate
collection and treatment at an approved offsite facility or on-
site treatment and discharge to an unnamed tributary of Hockanum
Brook, extension of municipal water supply, long-term groundwater
monitoring and institutional controls on groundwater usage, and
other methods described above are the cost-effective remedies
which provide adequate protection of public health, welfare, and
the environment.
The 'State of Connecticut has been consulted and concurs with
the selected remedy. In addition, the action will require future
operation and 'maintenance activities to ensure the continued
effectiveness of the remedy. Leachate treatment will be considered
part of the approved action and eligible for Trust Fund monies
for a period of up to two years from the completion of the cap
and leachate collection system. All other operation and maintenance
activities will be eligible for Trust Fund monies for one year
after completion of the source control remedial action'.
I have also determined that the action being taken is
appropriate when balanced against the availability of Trust Fund
monies for use at other sites.
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EPA will utilize the post closure ~onitoring data to deter-
~ine the need for an additional remedial investigation/feasibility
study to evaluate off~ite groundwater contaminant Migration.
If additional remedial actions are deemed necessary a Record of
Decision will be prepared for approval of the future remedial
action.
In addition, a Supplementary Decision Document will be pre-
pared for the signature of the Regional Administrator during the
design phase to justify the decisions reached on the manner and
location of leachate treatment ( onsite or offsite ), the extent
of excavation in the satellite areas, and the need for air pollu-
tion controls on the landfill gas vents.
~ /'2-7/ fr' .r
Date
M~V28a~
Regional Administrator
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SlJ.1MARY OF REMEDIAL ALTERNATIVE SELECTION
FOR
BEACON HEIGHTS LANDFILL SITE, BEACON FALLS, cr.
.
September 20, 1985
u. S. Env ironrrental Protect ion Agency
Boston, Massachusetts
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TABLE OF amEN'IS
Site Locat ion arrl Desc:::- ipt ion. . . . . . . . . . . . . . . . . . . . . . . . . . . .
1
Site
H isto:-y. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .. 2
Cu::-rent Site Status......................................
3
Enforcement Analysis
(EPA Conf ident ial]
.................. 8
Alternatives
Evaluation .................................. 8
Al ternat ive t 1
Alternative t 2
Alternative. 3
Al ternat ive . )A
Al ternat ive . 38
Alternative" 3C
Alternative t 4
Alternative" 5
Al ternat ive t 45
Alternative t 7
AI ternat ive .. 8
Alternative' 9
Alternative. 10
Alternat ive # 11
AI ternat ive . 1 '2
Alternative" 13
.............................9
. . . . . . . . . . . . . . . . . . . . . . . . . . .. 10
. . . . . . . . . . . . . . . . . . . . . . . . . . .. 14
. . . . . . . . . . . . . . . . . . . . . . . . . . . .10
. . . .. . . . .. . . . . . . . . . . . . . . ... 15
16
............................ 17
18
............................11
11
12
. . . . . . . . . . . . . . . . . . . . . . . . . . .. 18
........................... 19
12
. . . . . . . . . . . . . . . . . . . . . . . . . .. 13
19
.... ..... .... ... ...........
.............. .......... ....
......... ...................
........................... .
......... ........ ... .......
....... ...... .... ..........
Oammunity Relations .....................................
20
Cons istency with Othe:::- Env irorrnental
I.,aws ...............
21
Recant\eooed Alternative...................."..'.'..'... 23
Operation aoo Maintenance
. . . . . . . . . . . . . . . . . . . . . . . . . . . . . .. '25
SChedule of Events
. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .. 27
Future Act ions
..... .............. .......... .... .........
28
APPmDlCES
A - Site Location
B - Site Contaminants
C - Remedial Alternative Cost Data
D - eamunity Relations Responsiveness SlJ'[I'[Iary
E - Enforcement Analysis
[EPA Conf ident ial]
F - Connecticut COst Share Letter
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Figure 1 -
Figure 2 -
Figure 3 -
Figure 4 -
Table 4-1 -
Table 4-2 -
Figure 5 -
Figure 6 -
Figure 7
Figure 8 -
Figure 9 -
Figure 10 -
Figure lOa -
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LIST OF FIGURES AND TARLES
.:.
Found after Page
Site Location Map
.... ........................ ....
1
sample Location Map
.......... ......... ...........
4
Flow Paths Figure
.................. ......... .....
5
List of Alternatives
......... ......... ...........
9
General Response Act ionse
........ .......... .....
9
Eliminated General Response Actions ..............
9
RCRA Cap EXtent
...................... .
........... 15
()Jantity Estimates for RCRA Cap
. . . . . . . . . . . . . . . . . .. 15
RCRA Cap C:'oss Sect ion
............................ 15
.
EXtent of Waterline
. . . . . . . . . . . . . . . . . . . . . . . . . . . . . .. 18
EXtent of Waterline
. ... ... ....... ... . ... ....... ... 18
Reccmneooed Alternative Cost SLmnary
. . . . . . . . . . . .. 26
Cost Sl.ITIT\ary for Leachate ~eatment ~tions
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SUMMARY OF REMEDIAL ALTERNATIVE SELECTION
SITE NAME
Beacon Heights Landfill site
SITE LOCATION AND DESCRIPTION
The Beacon Heights Landfill site is located two miles east
of the intersection of Connecticut Routes 8 and 42 in Beacon
Falls, Connecticut. Access to the landfill is from Blackberry
Hill road about 3500 feet from this road's intersection with
Route 42. The landfill occupies approximately 30 acres of an 83
acre property within the lower Naugatuck River valley. The site
sits atop a ridge southeast of the intersection of Skokorat and
Blackberry Hill roads. Approximately 21 homes border the site to
the west along Skokorat road and 23 homes lie to the north along
Blackberry Hill road in an area of low residential density. The
closest residence is about 800 feet away on Blackberry Hill Road. .
The site is located within the Hockanum Brook drainage area.
Hockanum Brook, which is 0.5 miles northwest of the landfill,
flows down toward the Naugatuck river, which is two miles west
of the site. Gravel pit operations also exist in this area, one
northwest of the site, the other to the northeast. Both are
approximately 0.5 miles from the landfill. Residences on Skokorat
road as well as those above a recently installed water main on
.Blackberry Hill road have private water supplies. The site
layout and location is further delineated on the maps presented
in appendix A and figure 1.
The entire site lies outside the 100 year floodplain of
Hockanum Brook, and neither includes nor borders any wetland
areas.
Groundwater in the region occurs in both the unconsolidated
deposits, till and drift, and in the bedrock. Based on regional
estimates of 47 inches of precipitation and 22 inches of evapotrans-
'piration annually, approximately 25 inches of precipitate contact
the landfill. Of this amount, 12 inches is discharged as surface
runoff whi~h allows 13 inches to percolate into the fill material.
This percolate becomes contaminated from contacting the wastes
prior to recharging the unconsolidated and bedrock aquifers
and/or discharging as ieachate at seeps at the base of the
landfill, as illustrated in Figure 3.
Groundwater in the shallow unconsolidated aquifer contributes
to the base flow of Hockanum Brook and to the flow of its two.
tributaries which flow north from the site and eventual~y join'
the Naugatuck River. The shallow unconsol idated aqu ifer also
provides water for a number of residential wells in the area.
.'
.
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Site Locat1on Map
Figure
1
.
:e
t
.
. .
BEACON HEIGHTS,
LANDFI LL
._~ 4:-.
. - Approximate Monitoring Well
Location
.
x- Contaminated Resident
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( 2)
SITE HISTORY
From the 1920's until 1970 the site was known as "Betkoski's
Dump" and consisted of approximately 6 acres of active dumping in
the northwest corner of the existing site. According to records
at the Connecticut Department of Environmental Protection (CT DEP),
the dump accepted a variety of waste including municipal refuse,
rubber, plastics, and industrial chemicals and sludges. Operations
consisted primarily of open burning along with burial of non-
combustibles. Problems of wind blown litter and smoke from open
burning were reported during this period. In 1970, the Betkoski
property and adjacent properties totaling 83 acres were purchased
by the Murtha Trucking Company, and the name was changed to
Beacon Heights, Inc. Landfill. The landfill area was expanded
to approximately 30 acres using excavated soils for daily cover
material. Records of the CT DEP including a 1973 report by the
landfill engineer listed rubber, plastics, oils, hydrocarbons~
chemical liquids and sludges, and solvents as being disposed at
the landfill. Site operations reportedly ceased in 1979 with
two exceptions. Wastewater treatment plant sludge was spread
over large areas of the site until 1983. Also a very small
refuse transfer station for neighboring Bethany residents remains.
in operation immediately inside the access gate. ,.
Several pools of liquid as well as evidence of open burning.
are visible on the site in aerial photographs taken in 1965. In i
addition, other aerial photographs taken in 1963,'1970, and 1975
visibly document the landfill expansion. An engineering geology
study of the landfill completed in April, 1973 stated that leach-
ate production was occuring. Another documented release of
contaminants to the environment was a sampling of surface water
near the site in 1979. The results from this sample were 30 parts
per billion (ppb) chloroform, 110 ppb ethyl acetate, 400 ppb
methyl acetate, and 30 ppb methyl ethyl ketone. Releases of
contaminants to the air, groundwater, and surface water surrounding
the Beacon Heights Landfill are further documented in the remedial
investigation report prepared by NUS Corp., and are discussed
further herein in the Current Site Status section.
During the period of operations from 1970 to 1979, both muni-
cipal wastes and industrial wastes and refuse were disposed of
by landfilling. The Connecticut DEP monitored and permitted
site operations during this period and issued a series of Adminis-
trative Orders to the owner/operator to perform engineering-geo-
logical studies to remedy alleged permit violations related to
unauthorized acceptance of industrial wastes, disposal in
unauthorized areas, surface water contamination from leachate
migration, inadequate cover, and others.
These activities culminated in a Consent Order to close the
facility by July 1, 1979. This Consent Order was signed by the
president of Beacon Heights, Inc. on June 20, 1979 and entered as
a final Order of the Connecticut Commissioner of Environmental
Protection on July 24, 1979. The closure requirements of the
Order, which included placement of final cover and implementation
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( 3 )
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of a g~oundwate~ monito~ing system, we~e n8ve~ implemented. On
December 4, 1979 the CT DEP inspected the Beacon Heights Landfill
and repo~ted that landfill ope~ations had ceased.
No response actions have been taken at the site hy EPA O~
the CT DEP. However, the DEP has been p~oviding bottled wate~
to 2 homes on Skokorat Road since Novembe~, 1984 afte~ thei~
wells we~e found to be contaminated above levels conside~ed
acceptable fo~ d~inking water by the Connecticut Depa~tment of
Health Services.
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CURRENT SITE STATUS
The site consists of two. overlapping waste management areas.
The main area, formerly operated by Beacon Heights, Incorporated
occupies approximately 30 acres of an 83 acre property. Visually
it is a large mound with elevations ranging from 550 to 718 ft.
above mean sea level. The depth of waste ranges from 0 feet at
the toe to 40-60 feet near the top. Based on comparisons of
current and old topographic maps it is estimated that 650,000
cubic yards of waste comprise the body of the landfill. Due to
the random codisposal of municipal refuse and industrial wastes
it is not possible to identify specific locations of hazardous ~
materials within the landfill mass. .
The second area of disposal is known as the former "Betkoski
Dump". This smaller 6 acre area is located immediately adjacent
to the landfill to the northwest of the site access road (see
figure 2), although portions of it extend beneath the access
road and beneath the Beacon Heights landfill area.
The following summary hydrologic profile of the landfill
explains the surface water and groundwater migration pathways
for contaminant migration from the site. Precipitation percolates
into the fill materials and becomes contaminated from contact
with the wastes. This contaminated water (leachate) flows through
the permeable refuse until it contacts the less permeable bedrock.
Some leachate then flows downward into the shallow bedrock system
under the influence of gravity, while the rest flows at the
interface of the fill and bedrock until it exits the landfill at
one of the leachate seeps. Some leachate entering the bedrock
flows downgradient in the upper fractured zone until the gradients
are such that allow this leachate to discharge as seeps at the
base of the landfill in local groundwater discharge areas. At
two of the three major seep areas, the leachate is collected by
a crude channel that runs along one side of the site until its
juncture with a.stream. The stream transports the leachate
offsite through a former gravel pit operation where a portion of
the stream percolates into the ground to recharge the shallow,
aqui~er. The remainder of the leachate entering the bedrock'
flows along the most transmissive fractures to the regional
discharge area, the Naugatuck River, located to the northwest of
the site.
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During the remedial investigation (RI) samples of leachate
were analyzed as the Most direct indication of the contaminant
source since no other specific waste materials could ba samplen,
i.e. liquid wastes, lagoon wastes, etc. Three major seep areas
were identified, sampled, and analyzed. The sample results
indicated significant contamination with volatile organics as
well a~ some acid extractable compounds. The primary contaminants
were benzene (35,100 ppb max.), chlorohenzene (5,310 ppb max.),
chloroethane (1,450 ppb max.), 2-butanone (6,090 ppb max.), and
bis(2-chloroethyl)ether (4,680 ppb max.). Specific sample loca-
tions and concentrations are further defined within the maps and
tables of Appendix B and.Figure 2 of this document.
Fifteen groundwater monitoring wells were installed at various
locations surrounding the site. Both unconsolidated and bedrock
wells were installed. Sampling and analysis of these wells indi-
cated significant contamination in four wells: two in the uncon-
solidated deposits, two in bedrock. The other wells contained
trace levels of both base/neutral and volatile organic chemicals.
One set of the significantly contaminated wells (one bedrock,
one unconsolidated) is located approximately 400 feet downgradient
and the other set approximately 1000 feet downgradient of the
landfill. Benzene was detected in these four wells at concen-
trations up to 850 ppb. Chlorobenzene and chloroethane were:
also detected at levels up to 797 and 131 ppb respectively. ,
Bis(2-chloroethyl)ether was also found at levels up to 4360 ppb. !
Water samples were also collected from 44 private residential
wells along Blackberry Hill and Skokorat Roads adjacent to the
landfill. These wells were considered to provide another good
indication'of offsite groundwater contaminant migration from the
landfill given the lack of any other apparent sources between
the homes and the landfill. Analysis of these water samples
indicated that two residential wells were contaminated with 48
and 131 ppb of benzene respectively. Fol10wup sampling confirmed
these results with levels of 22 and 98 ppb in the second round
and 42 and 89 ppb in the third round. Other residences sampled
had trace levels of contamination below current drinking water
standards. A complete listing of all residential well results
can be found in Appendix A to the feasibility study.
A tributary to Hockanum Brook (the largest surface water
stream in. the area) drains the northern part of the landfill.
This stream was contaminated with benzene (49 ppb), ch10robenzene
(95 ppb), bis(2-chloroethyl)ether (420 ppb) and iron (89,000 ppb).
This tributary stream accepts discharge from a channel which drains
both surface runoff and leachate from the landfill. The tributary
is free of contamination upstream of the landfill (See figure
A-2 in Appendix A of this document for details).
Results of ,limited air samples analyzed for volatile organics
and soil samp~es analyzed for PCB's, dioxin, and heavy metals
indicate no apparent health hazards at the current site as a result
of inhalation of volatile organic compounds or airborne contaminated
particulates. However, there are volatile organic emissions as
noted in Table B-3 of Appendix R as reported in the RI. Therefore
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SITE PLAN
BEACON HEIGHTS LANDFILL SITE. BEACON FALLS.CT-' '"
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-------
~
( 5 )
should onsite actions ~equi~e h~eaking into the fill, o~ excavation
of satellite a~eas, additional monito~ing wouln he ~equi~p.rl.
Thus, the major exposure pathway to human ~ecepto~s f~om the
release of hazardous suhstances f~om the site is the ingestion of
contaminated groundwater withd~awn f~om eithe~ the unconsolidated
aquifer or the bed~ock aquife~, both of which a~e contaminated with
benzene, chlorobenzene, chlo~oethanes, bis (2-chloroethyl) ethe~,
xylenes, and other haza~dous compounds. These two aquife~s p~ovide
water for 44 homes along Skokorat and Blackberry Hill Roads.
Assuming 3.8 occupants per residence, approximately 167 people
utilize private wells drawing wate~ from these aquife~s fo~
drinking water and other domestic uses.
The aforementioned hydrologic setting of the landfill provides
a pathway for contaminant releases from the site to reach these
.wells. As shown in Figure 3, the landfill is situated in a local
recharge area for the unconsolidated aquifer which discharges to
Hockanum Brook. The estimated groundwater velocity in this aquife~
is approximately 52 feet per year. The residences are within
approximately 1/2 mile (2640 feet) from the landfilll the closest
is within 800 feet. Since significant contamination has already
been found in the unconsolidated monitoring wells at distances of
400 and 1000 feet from the landfill, it is evident that the area.
residential wells which draw from the unconsolidated aquifer are~
threatened by continued offsite migration of contaminants from t~e
site.
Contaminant flow in the fractured bedrock also threatens the
nearby residential wells which draw from the bedrock aquifer.
Again referring to Figure 3, the landfill is sited in an area
which provides recharge to the bedrock aquifer which discharges
locally to Hockanum Brook and regionally to the Naugatuck River.
CT DEP records indicate that the unconsolidated deposits in the
filled areas were removed prior to landfilling for use as daily
cover material. Thus, the wastes were placed directly on the
bedrock sL:face, thereby providing a pathway for leachate to
enter the bedrock fractures. Outside the waste management areas,
the unconsolidated aquifer recharges the bedrock aquifer, i.e.
there is downward flow of water and contaminants from the uncon-
solidated deposits into the bedrock. Once contaminants enter
the bedrock, by either means, local flow paths and velocities
cannot be defined since they are governed by fracture spacing
and directions, interconnections of the fractures, and local
disturbances s~ch as pumping. However, the regional flow
direction is north-northwest toward Hockanum Brook and the
Naugatuck River. The residences on both Skokorat and Blackberry
Hill Roads are within the flow paths of contaminated groundwater
and could be impacted at any time.
Two .bedrock residential wells on Skokorat Road were found'
to be significantly contaminated with benzene, a human carcinogen,
during the remedial investigation performed by NUS. In three
separate sampling rounds in the summer and fall of 1984 and the
, .
,.. ,..-. --"-.'
-------
DRAINAGE DITCH
Figure J
. '1_,
-LANDFILL
LEACHATE BHEAKourS
ON f./EFU$E. SlOP[
LEACHATF- COLLECTIOU
T~ENC~t
MULTI-LEVEL our 1I[l)~O(K
GROUNOWATER MONITOkINl. WUI
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GROUNDWATER
DIVIDE
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THEORETICAL FLOW PATHS OF GROUNDWATER AND CONTAMINANTS
FROM THE BEACON HEI.GHTS LANDFILL
"
1
1
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. ;
. .
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-------
( 6 )
winte~ of 1985, benzene levels in the two wells we~e 48 and
131 ppb, 22 and 98 ppb, and 42 and 89 ppb. No ferle~al d~inking
wate~ standa~d has been set fo~ benzene; the EPA Office of
D=inking Wate= .has set a SNARL (Suggested No Adve=se Response
Level) of 70 ppb to p~otect against ch=onic systemic toxicity
f=om long te=m ingestion. The SNARL does not consider. ca~cino-
genicity, howeve=. The cance= ~isk associated with ingestion of
benzene at 131 ppb is 1.98 x 10-4 lifetime excess cancers,
i.e. 2 excess cancers above normal cancer rates for every 10,000
people ingesting this compound over a 70 year lifetime. Should
the levels in the residential wells reach the 860 ppb measured
in offsite monitoring wells, the cancer =isk would inc=ease
p=oportionately. Benzene is ubiquitous at the site, having been
found in g=oundwate=, leachate, surface wate=, soils, and air,
and the concentrations in offsite groundwate= can be expected to
increase over time as the plumes spread further out from the
site. .
The above findings prompted the Connecticut Department of
Health Services to notify the occupants of the two residences
that their well water was unfit for human consumption since the
benzene levels were substantially in excess of that Department's
guideline of 1 ppb. Subsequently, the CT DEP has provided bottled
water to the two residences under the provisions of Connecticut ,.
Public Act 85 - 407. .
Other contaminants detected in the residential wells by NUS i
include methylene chlo~ide, 1,1 dich1o~oethane, b~omodichlo~omethane,
xylene, trichloroethene, chloroform, bis(2-ethylhexy1)phtha1ate,
and di-n-octyl phthalate. Although current levels of these
contaminants a=e below fede=al and state guidelines fo= drinking
water, significant levels of many of these same contaminants
have been found in both leachate and offsite groundwate~ and
thus, the levels in the residential wells could inc~ease ove~
time as contaminant plumes migrate further from the landfill
source. A complete listing of the critical contaminants and
their associated threshold and non threshold effects is presented
in Taples B-4 and B-5 of the Feasibility Study Report prepared
by NUS. (See Appendix B of this document for additional info~-
ma t ion) .
Leachate discharges and contaminated surface =unoff from the
site have also degraded the small tributary of Hochanum Brook.
which drains the site. Both the. brook and its tributa~ies are
classified by the CT DEP as B/A, meaning that the desired classi-
fication is A but that. the current status approximates B due to
the effects of waste discharges on stream quality. Samples
taken from the tributary in the fall of 1984 at a location approx-
imately 800 feet downstream of the leachate discharge point we~e
contaminated with benzene (49 ppb), chlorobenzene (95 ppb), .
bis(2-chloroethyl)ether (420 ppb), and 1~2 dichlorobenzene (10
ppb), and the streambed is heavily discolored from the high iron
content of the leachate.
-------
( 7 )
..
The allowable level of chemical contaminants in Class A st~eams
is dete::-mined by Gene~al Pol icy 11 of the Connect icut ivate::- Qual ity
Standa~ds and C~iteria, adopted on Septembe~ 9, 1980. This policy
states that" the waters shall be free from che~ical constituents
in concentrations or combinations which would be harmful to human,
animal, 0= aquatic life fo= the most sensitive and gove::-ning wate~
use class. Criteria for chemical constituents contained in guide-
lines published by the u.s. Envi=onmental Protection Agency
shall be considered ..."
EPA has issued wate= quality criteria fo= benzene and fo=
bis(2-chloroethyl)ether pu=suant to S 304(a)(l) of the Clean
Water Act, 33 U.S.C. l3l4(a)(1). (See Fede=al Registe= Volume
45 Number 231, November 28,1980). These criteria are discussed
separately for each contaminant in the following excerpts from
that Federal Register.
Benzene:
"For the maximum protection of human health from
the potential ca=cinogenic effects due to exposu=e
to benzene through the ingestion of contaminated
wate= and contaminated organisms, the ambient
water concentration should be ze=o based on the
non-th=eshold assumption for this chemical.
Howeve=. zero level may not be attainable at
the present time. Therefore, the levels that
may result in incremental increase of cance=
risk over the lifetime are estimated at 10-5,
10-6, and 10-7. The cor=esponding crite=ia
a=e 6.6 ppb, .66 ppb, and .066 ppb, respectively.
If the above estimates are made for consumption
of aquatic organisms only, excluding consumption
of water, the levels are 400 ppb, 40 ppb, and
4 ppb, respectively."
~.
Bis(2-chloroethyl)ether :
IIFo= the maximum protection of human health f=om
the potential ca=cinogenic effects due to exposu=e
to bis(2-chloroethyl)ether th=ough ingestion of
contaminated wate= and contaminated aquatic
organisms, the ambient water concentration should
. be zero based on the non-threshold assumption fo=
this chemical. However, zero level may not be
attainable at the present time. Therefore, the
. levels which may result in incremental cancer
risk over a lifetime are estimated at 10-5,
10-6, and 10-7. The corresponding criteria.
are .3 ppb, .03 ppb, and .003 ppb, respectively.
If the above estimates are made for consumption
of aquatic organisms only, excluding consumption
of water, the levels are 13.6 ppb, 1.36 ppb,
-------
( 8 )
Thus, the attainment of Class A standa~ds is th~eatened by the
leachate disharge. It is noted that the aforementioned conta~ina~t
levels were measured at a point 800 feet downstream of the actual
disharge point." Sampling could not be conducted closer to the
discharge point, because the stream enters an underground culvert
immediately after the discharge point. Were this location accessible
to sampling, the contaminant levels would be expected to be higher
than at the downstream sampling location.
Finally, the presence of exposed leachate and contaminated
soils, primarily at leachate seeps, presents a potential direct
contact hazard from ingestion or dermal contact. Specific data
on the compounds present in these areas can be found in Chapter 2
of the Feasibility Study Report and in Appendix B of this document.
ENFORCEMENT ANALYSIS
Included as an EPA enforcement confidential document in Appendix E.
ALTERNATIVES EVALUATION
" The feasibility study has addressed both source control
remedial actions and offsite remedial actions. Source control
actions are appropriate since substantial concentrations of
hazardous substances remain at or near the area where they were
originally located and inadequate barriers exist to retard the
migration of hazardous substa~ces into the environment. (See 40
C.F.R. S 300.68 (e)(2) of the NCP) Offsite remedial actions
were also evaluated, since contaminants have migrated beyond the
area where they were originally located. Furthermore, source
control actions may not, in and of themselves, mitigate and
minimize damage to public health, welfare, and the environment.
(See 40 C.F.R. S 300.68 (e)(3) of the NCP)
.
Objectives
The objectives of the remedial action are to reduce the
generation of contaminated leachate and thereby mitigate future
groundwater and surface water contamination; to minimize offsite
migration of contaminants via surface runoff; to minimize direct
human contact with contaminated soils on site; and to assure a
safe drinking water supply for area residents. These objectives
may be achieved "by source control actions supplemented by
offsite actions. To meet these broad objectives, the landfill""
wastes must be isolated to minimize contact with groundwater
-------
( 9 )
Development of Alte~natives
The ~emedial alte~natives fo~ the Beacon Heights Landfill we~t
developed and evaluated using 40 C.F.R S 300.68 (g), (h), (i), and
(j) of the NCP as guidance.
The fi~st step in developing the ~emedial action alternatives
was to consider the wide ~ange of possible methods for remedying
releases at any site and then to select those methods which were
applicable to the stated objectives of ~emediation at the Beacon
Heights Landfill site. Table 4-1 lists the gene~al response methods
. considered appropriate fo~ evaluation at this site. Table 4-2 lists
those that were ~ejected as inapp~opriate. The methods listed in
Table 4-1 were then combined to form the 13 remedial action alte~-
natives listed in Figure 4. Alternatives 1 - 8 are source control
actions: alternatives 9 - 13 are offsite actions.
Initial Screening
The thirteen alternatives were screened based on the criteria
in 40 C.F.R. S 300.68 (h) of the NCP, i.e. cost, effects of the
alternative, and acceptable engineering practices.
The following is a brief discussion of those alt~rnatives ~
that were eliminated from detailed evaluation and the reasons for
the elimination. Please note alternatives are numbered as
prese~ted in Figure 4.
Alternative Numbe~ 1, Offsite Disposal in an Approved Facilit~
This alternative includes excavation of all contaminated materials,
disposal in an offsite RCRA-approved landfill, backfilling and
revegetation of the excavated areas, and installation of stormwater
management controls. The total present worth cost of this alternative
is $101,257,000 with an initial capital cost of $100,459,000.
This alternative is roughly twice the cost of the next cheapest source
control alternative. Although technically possible, this alternative
is not a reliable means of addressing the site problems. Implementation
could require 3 to 7 years or more, depending on the availability
of an approved landfill. Currently there are no approved facilities
located i~ Connecticut, or New England. Furthermore, the exca-
vated wastes may require extensive rehandling to meet the landfill
site's requirements on free liquid content, solvent content, or some
wastes may be encountered which would not be accepted even after
rehandling.
Significant short term adverse impacts could also result from
the implementation of this alternative. Excavation of 700,000,cubic
yards of waste would result in substantial amounts of contamin.ted
surface runoff and leachate migration whi~h would be extremely dif-
ficult if not impossible to control. Additionally, increased vola-
tilization of both hazardous organic compounds and methane from
garbage decomposition could cause local air emission problems.
Selection of this alternative would also not comply with the
."
-------
Figure 4
CATEGORIZATION AND CLASSIFICATION OF REMEDIAL ACTION ALTERNATIVES
BEACON HEIGHTS LANDFILL SITE
Remedial Action ~Iternative
Site Remediation Alternatives
1.
Offsite Disposal in an Approved Landfill
2.
Onsite Incineration
3.
RCRA Closure with Cap. Leachate
Collection. and Treatment to NPDES
Standards
4.
Onsite RCRA Landfill. Leachate
Collection. and Treatment to NPDES
Standards
5.
Onsite RCRA Landfill. Leachate
Collection. and Treatment to Drlnk.ing
Water Quality Standards .
6.
Soil Cover, Leachate Collection, and
Treatment to NPDES Standards
1.
No-Action
8.
limited No-Action with Long-Term
Monitoring
Water Supply Alternatives
9.
Public water supply provided to extended
area (Skokorat Road to next municipal
supply, Black.berry Hill Road to
demographic limits)
.
, O. Public water supply provided to affected
area (Partial coverage on Skokorat Road)
Groundwater Alternatives
, ,. Groundwater Extraction and Treatment to
Drink.lng Water Quality Standards
, 2. Additional Groundwater Hydrogeologic
Investigation
, 3. Limited' No-Action with Monitoring
,.
.
-------
General Response
Action
No Action
Containment
Pumping
Collection
Diversion
Complete Removal
Onslte Treatment
Offsite Treatment
Offsite Disposal'
Onsite Disposal
Alternative Water
Supply
Table 4-1
GENERAL RESPONSE ACTIONS AND
ASSOCIATED REMEDIAL TECHNOLOGIES
BEACON HEIGHTS LANDFILL SITE
Aoolicable Remedial TechnoloQies
Monitoring
Groundwater containment barrier
Capping
Onslte groundwater pumping - extraction
Offsite groundwater pumping - extraction
Leachate collection
Gas vents
Gas collection systems
Sedimentation basins
French drains
Pipe collection systems
Regrading and revegetation
Diversion channels
Excavation of landfill waste material including
soils, sediments, and liquid wastes
Waste Incineration - RCRA
Leachate treatment - physical, chemical, biological
Groundwater treatment - physical, chemical, biological
Waste incineration - RCRA
Leachate treatment - physical, chemical, biological
Groundwater treatment - physical, chemical, biological
RCRA landfill
RCRA Landfill
Municipal water system
Individual treatment devices
New wells
..
;.
-------
General Response Action
Containment
Diversion
Complete Removal
Partial Removal
Onsite Treatment
and
Offslte Treatment
In-situ Treatment
,
~ ~
Table 4-2
ELIMINATED G'"\:NERAl RESPONSE ACTIONS AND
. ASSOCIATED REMEDIAL TECHNOLOGIES
BEACON HEIGHTS lANDFill SITE
Eliminated Remedial Technologies
Bulk heads
Gas barriers
Stream diversion ditches
Terraces and benches
Chutes and downpipes
levees
Seepage basin
Contaminated structures
Sewers and water pipes
Excavation
Solidification
land treatment
Permeable treatment beds
Bloreclamation
SoU flushing
Neutralization
landfarming
,
'.
Comments
Not applicable to site characteristics and problems.
Data does not support the need for this technolouy.
Site or remediation not affected by stream location.
Surface water run-on not affecting site significantly.
Surface water run-on can be controlled by olhor lIH!ilnS
Flood plains not applicable to site.
Site characteristics do not support this teehnolouy.
Not applicable to this 51te
Not applicable to this site
The random codisposal 0' Industrial wastes with thu
municipal refuse eliminates the feasibility 0' ichmti
fylng specific locatl~ns of burled hazardous waste.
The codisposal o' Industrial wastes with munici'HlI
waste has created a complex waste that cannot hu
treated with any effectiveness by these technol()uw~
The codlsposal 0' industrial wastes with municipal
wa~tes has created a complex waste that cannot he
treated with any effectiveness by these technolo!)il!s
The complex hydrogeology also adversely atlcets the
ability to control implementation of these technolo!Jies.
._. t:-
-------
Table 4-2
ELIMINATED GENERAL RESPONSE ACTIONS AND
ASSOCIATED REMEDIAL TECHNOLOGIES
BEACON HEIGHTS LANDFill SITE
PAGE TWO .
General Response Action
. Storage
Onsite Disposal
Alternative Water Supply
Applicable Remedial Technologies
Impoundments
Storage Structures
Surface Impoundments
land applications
Bottled wat~r
Cisterns
Above-ground tanks
Relocation 01 intake structur6s
-I'
Comments
The massive volume 01 total waste and codisposal 01
the Industrial wastes with municipal wastes eliminale:--
these technologies.
These technologies are not applicable to the nalure 01
volume 01 wastes at the site.
The residential wells that have been contaminated .wed
to be replaced with an equally permanenl waler SIII'I'IV
The cisterns. above ground tanks. and bottled Willer
systems are temporary solutions and are not the he:>1
technology available In the affected area. The ilililkn
structure relocation Is not applicable 10 this sile
"
-------
( lO)
statuto~y ~e~t~ictions on offsite disposal unde~ C~RCLA ~ 101 (24).
It is not the cost effective alte~native, it is not necessa~y to
p~otect public health, welfa~e, an~ the envi~onment, and it would
not c~eate additional disposal capacity. Based cn the unce~tain
feasibility of secu~ing an app~oved disposal site, the potential
adve~se envi=onmental impacts of unea~thing, t~anspo=ting, and
~edisposing of such a la~ge amount of waste, the extende~ timef~ame
fo~ implementation, and the excessive cost ~elative to the othe~
alte~natives without co~~esponding benefit, this alte~native was
eliminated f~om detailed evaluation.
Alternative Numbe~ , Onsite Incine~ation. This ~emedial
action nvolves the excavation of all contaminated mate~ials
including the main landfill, the Betkoski Dump, and periphe=a1
contaminated soils. Following excavation the waste would be
burned in fou~ po~table incinerators. After incine=ation, all
ash and non combustibles (estimated at 200,000 cubic yards)
would be disposed in an onsite RCRA landfill. This is the most
complex of all 13 alternatives to implement.
The reliability and thus enginee=ing feasibility of this
alternative is highly questionable due to the heterogenous nature.
of the waste material and its mixture with large quantities of s~i1
and debris. This would hinder the ability of the incinerators to
effectively destroy the haza~dous constituents and would likely
result in a high incidence of malfunctions an~ downtime. Sho=t
term adverse impacts to air quality from malfunctions and poor
destruction efficiency could also be expected and could pose
a potential threat to public health. In addition, a minimum of
3 to 4 years would be required for implementation.
The total capital cost of this alternative is $51,201,000
with a total present worth cost of $64,055,000. Based on the
engineering infeasibility of burning the contents of the entire
30 acre, 650,000 cubic ya=d landfill in a safe, effective, and
timely manner, and the possibility of short term adverse impacts
to public health, this alternative was eliminated from detailed
evaluation.
.
Alternative 3A, RCRA Closure with a Cap, No Leachate Collection
or Treatment, postclosure Monitoring. This alternative is identical
to Al ternat ive .3 except the per imeter leachate collect ion is
omitted. Initial capital cost is $ 14,326,000 and total present
worth cost is $ 15,193,000. (See Table C-3 for cost comparison
with other options under Alternative 3). The CT DEP requested
an evaluation of this alternative based on their opinion that a
RCRA cap would so dramatically curb leachate production that a.
collection system would not be needed. Based on water balance
calculations, it is expected that leachate would be produced, at
least initially, at a rate of approximately 5000 gallons per
day. This rate of leachate production will most likely decline
after capping once the presently saturated wastes within the
landfill have dewatered. However, the degree to which leachate
-------
( 11)
-.)
p~oduction will d~op anrl the time ~equi~ed to co so cannot be
accu~ate1y p~edicted. Since no cap ~ay be enginee~ed to be complet~
impe~meab1e and since waste will ~emain beneath the cap, leachate
will continue to be p~oduced in some amount. If not collected,
this leachate will be a continuing sou~ce of contamination to
g~oundwate~ and su~face wate~s. Thus, this alte~native does not
p~ovide adequate cont~ol of sou~ce mate~ial as ~equi~ed by 40 C.F.R.
S 300.68 (h)(2) of the NCP and the~efo~e has been dropped from
conside~ation.
Alternative Number 6, Soil Cover, Leachate Collection, and
Treatment to Drinking Water Quality Standards, Postc10sure Monitoring.
In this alternative the entire site will be cove~ed with a soil cap,
leachate collection and t~eatment will be provided, and gas venting
and storm wate~ management systems will be installed. The soil
cove~ will consist of two feet of till material and a six inch
loam laye~ to maintain vegetation. The purpose of the soil cover is
to reduce contaminated su~face water runoff and to ~educe some of the
infiltration that subsequently generates leachate. The amount
of leachate reduction will depend on the impe~meability of the
cap. Even though leachate production would be ~educed, this
soil cap would pe~mit a substantial amount (10,000 to 20,000
gallons per day) of leachate to be produced as a ~esult of the
infiltrated precipitation. This alternative would control the
discharge of leachate and contaminated runoff into su~~ounding
surface waters but would allow continued releases of contaminants
to groundwater. The initial capital cost of this alternative is
$6,175,000 with a total present worth cost of $8,277,000.
Continued leachate production under this alternative poses
an ongoing threat to the environment and to the public health
and therefore does not meet the site objectives. Due to inadequate
control of leachate production, this action does not constitute
adequate control of source mate~ial as required by 40 C.F.R.
S 300.68 (h)(2) of the NCP and therefo~e has been d~opped f~om
further consideration.
;.
i
Alte~native Number 7, No Action. This alternative represents
the baseline against which all other alternatives a~e to be compa~ed.
The objectives for site remediation, described earlier, are based
on the conclusion that the current and future potential ~isks to
public' health, welfare, and the envi~onment a~e unacceptable. These
risks were identified in the Feasibility Study Repo~t and in the
Current Site Status section of this document. The No Action alter-
native provides no source control measures and no measures to
minimize and mitigate the offsite migration of contaminants. As
such it will not reduce leachate generation and subsequent migration
of contaminants into groundwater and local surface water and the~e-
fore will not reduce the public health threat from ingestion of
-------
(12 )
contaminated g~oundwate~ O~ the public health and envi~onmental
th~eats f~om continued su~face wate~ contamination. It also will
not ~educe the potential health th~eat associated with di~ect con-
tact with contaminated soils and wate~ at leachate b~eakouts (seeps).
In summary, the no action alte~native would not achieve adequate
control of source material and would not miniMize no~ .mitigate the
the th~eat of ha~m to human health, welfa~e, or the envi~onment as
required unde~ 40 C.F.R. S 300.68 (h)(2) of the NCP. The~efo~e, this
alternative was eliminated f~om detailed evaluation.
Alternative Number 8, Monitoring. This alternative is a
form of the no action alternative. As such it does not include
construction activities to remediate site contamination but instead
provides for developing and maintaining a long-term monitoring
program. The results of the monitoring program would be evaluated
to track any adverse impacts to the public health and/or environment,
and to identify a point at which remedial activities may be
required. Monitoring includes the sampling and analysis of
several newly installed wells, as well as sampling the residential,
groundwater, and surface waters 00 a quarterly basis over a 30
year period. The initial capital cost for this alternative is
$272,000 with a total present worth cost of $1,969,000. This ~
monitoring alternative does not provide for more immediate actions
to remedy contaminant mig~ation or adverse impacts to public.
health and the environment. It does not minimize continued release
of contaminants to the groundwater, nor does it provide a long
term solution for adequate source control. Again, based on 40
C.F.R S 300.68 (h)(2) of the NCP this alternative does not
constitute adequate control of source material. Based on this
reason as well as those outlined in alternative 7 above, this
alternative has been dropped from further consideration in the
detailed analysis.
Alternative Number 11, Groundwater Extraction and Treatment
to Drinking Water Quality Standards. A groundwater extraction
system was developed to mitigate the threat to human health caused
by the offsite migration of contaminants into drinking water aquifers.
This alternative includes the installation of approximately 79
bedrock extraction wells. Each well would have its own pumping
system. These pumps will discharge to a main line that leads to
a treatment unit. The treatment unit would use a combination
of air stripping and carbon adsorption to process the flow. This
process would operate for at least a 30 year period, or until remedial
cleanup goals are met (background, Maximum Concentration Limits - MCLls,
or Alternate Concentration Limits - ACL's as required '~nder RCR,A).
"-""",~----''''' -
-------
( 13)
Ext~action of conta~inated g~oundwate~ f~om deep f~actu~ed
bed~ock is not a proven practice. In addition, site specific
geologic and hyd~ologic conditions complicate the desiyn and
implementation of an extraction system. The bed~ock fractures
in the area have predominant vertical dips. This is ~eadily
visible on the abundant bed~ock outcrops su~~ounding the site.
This fact seve~ely complicates the siting of ext~action wells.
With a vertical fracture system, the probability of inte~secting
the fractures with vertical extractiQn wells is remote, and near
misses will render the well useless since unfractured impermeable
rock prevents water flow. Pumping wells that do intercept fractures
would only draw water from those particular fractures and any inter-
connected fractures. To circumvent this problem, an enormous
. number of wells would be Tequired. However, the probability of
intercepting all fractures carrying contaminants from the site
would still be remote, and any fractures that were missed would
continue to provide a conduit for contaminant migration from the
site, thereby rendering the entire system ineffective. ( See
Table C-2 for estimated costs ).
Removal of contaminated groundwater from the thin glacial
till material is technically feasible, although very difficult.
Even if removal of groundwater contamination from the till material
could be achieved, leachate would continue to enter the fractured.
bedrock beneath the landfill for subsequent Migration offsite. .
Thus, the threat to the environment and public health would not
be adequately mitigated.
Due to the technical infeasibility of groundwater extraction
from deep, fractured bedrock and the inadequate mitigation of
the public health threat provided by extraction and treatment of
-contaminants from the unconsolidated aquifer, this alte~native
was eliminated from further evaluation.
Alternative Number 12, Additional Groundwater Hydrogeologic
Study. This additional hydrogeologic study alternative was
developed to collect additional data to better design an effective
groundwater extraction and treatment system. An additional
hydrogeologic study would provide more information on bedrock
conditions. However, the existing data are adequate to conclude'
that the hydrogeologic setting of the landfill precludes effec-
tive interception and extraction of contaminated groundwater.
Therefore, this- alternative cannot provide for minimization or
mitigation of threats to public health and the environment from
the offsite migration of contaminated groundwater, and it was
-------
..
( 14 )
DETAILED EVALUATION OF ALTERNATIVES
The alte~natives ~ernaining fo~ detailed evaluation a~e discussed
below. A detailed analysis of these alte~natives was pe~fo~med
in accordance with 40 C.F.R. S 300.68 (i) of the National Contingency
Plan (NCP), which ~equi~es conside~ation of technical feasibility,
detailed cost estimation including dist~ibution of costs ove~
time, constructibility, effectiveness in add~essing envi~onmental,
welfa~e, and public health conce~ns, and adve~se envi~onmental impacts
and measu~es for mitigating those impacts.
In ~esponse to comments ~eceived by the CT DEP, the PRP's,
and othe~s on the draft Feasibility Study Repo~t, th~ee modifi-
cations to Alternative 3 were developed. These options relate
to whether or not leachate is collected, and, if collected, whethe~
to t~eat onsite or offsite. As indicated in the attached.
Figure 10, the range in total project costs among the options is
small enough that it does not affect the choice of a recommended
source control alternative from among the remaining Alternatives 3,
4, and 5.
The remaining offsite remedial alternatives include Alternatives
9 and 10, which would extend the municipal water supply to a limi~ed
(10) or an extended (9) area. Alternative 13 would deal with.
offsite groundwate~ contamination via long term monitoring coupled,
with institutional controls. Costs for all alternatives including
long term costs are included in Appendix C of this document.
Alternative Number 3, RCRA Cap, Leachate Collection and Onsite
Treatment, Postclosure Monitoring. This alternative involves closu~e
of the landfill with a RCRA capping system, along with the imp1ementa-
t ion of postclosu~e mon itor ing requ irements. The Betkosk i. Dump wastes
and contaminated soils and sludges around the site will be excavated,
consolidated and placed on top of the landfill prio~ to closure.
These "satellite" areas are shallow in depth (approximately 3 to 15
feet), and lie directly over bed~ock. Wastes in these a~eas will be
excavated to background or to alternate levels protective of human
health, welfare, and the environment. Predesign/design sampling will
be necessary to define the excavation criteria. A Decision Document
will be prepared at that time to document the cost-effectiveness
of the selected approach. The steep sideslopes on the north side of
Betkoski's Dump preclude the ability to effectively cap this area
and provide leachate collection, thus necessitating consolidation.
Leachate will be treated onsite and discharged to a tributary of
Hockanum Brook. The site will be enclosed with a fence, and new.
monitoring wells will be installed to monitor the effectiveness'
of the cap as required by 40 C.F.R. S 264 Subparts (F), (9), and (N).
-------
( lS )
A landfill gas venting system will also be installed to p~event
the buildup of gasses unde~ the cap. The need fo~ ai~ pOllution
cont~ols on the vented gasses would be evaluated du~ing design.
The initial capital cost fo~ this alte~native is S15,439,000
with a 30 year total p~esent wo~th cost of S17,155,000. The
p~oposed a~ea of capping and the extent of the leachate collection
system a~e shown in Figu~e 5. The quantities of mate~ials for
const~uction of a multimedia cap a~e outlined in Figu~e 6. A
c~oss section of the p~oposed cap is shown in Figure 7. A cost
summary of all leachate collection and treatment options included
under Alternatives 3, 3A, 38, and 3C can be found in Figure 6a
and in Appendix C Table C-3 of this document.
This alternative satisfies all of the objectives for source
control. Consolidation of the outlying contaminated soils with
the main landfill followed by capping that landfill will eliminate
the direct contact threat and the offsite migration of contamlnants
via surface runoff. Installation of a cap which meets the require-
ments of RCRA will minimize the future production of leachate which,
in turn, will minimize future groundwater contamination and surface
water contamination. The provision of a perimeter leachate col-
lection and treatment system will ensure adequate sour£e control
of the majority of the leachate which will be generated after
capping, during the period of time required for the presently
saturated wastes to dewater, and the small amount of leachate
which will be gene~ated by leakage through the cap.
,.
.
Alternative 3B, RCRA Cap, Leachate Collection, Offsite Treatme
This alternative is identical to Alternative 3 with the exception
that the leachate collected onsite would be transported to an offsite
treatment facility. The PRP committee requested an evaluation of
this alternative based on their opinion that onsite treatment and dis-
charge to Hockanum Brook (Alternative 3) would not be allowed
under Connecticut Water Quality Standards and that treatment at the
Naugatuck or Beacon Falls POTW would be more cost effective.
Under this alternative, the perimeter leachate collection
system would drain by gravity to a holding tank. An estimated 5000
gallons per day (GPD) would initially be removed off site by two
tank trucks pe~ day and transported to the nearest available
wastewater-treatment facility. Prior to removal, leachate would
be pretreated onsite with an alkaline metal precipitation process.
Preliminary scoping has shown that the Naugatuck wastewater
treatment facility may be able to accept and process this leachate
load. This facility is about four miles from the site. The
initial capital cost of this alternative is S15,2l6,000 with a
total 30 year present worth of $18,610,000. :
The Beacon Falls POTW was eliminated from consideration
for te~hnical reasons1 only domestic wastes are presently treated
at the facility, and the system is presently experiencing problems
-------
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Figure 5
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LEGENQ
- EXcAVATION MtA
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- - - APPROXfIIATE SIT[ 8OUMIIRY" LIMIT OF
CAPPED ARU
--- STORMWATER/L!ACHATt COLLECTION SYSTEM
-., ."" .
- - - APPROXIMATE PROPERTY BOUNDARY
-c- FENCE
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-.....
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.-TER I LEACHATE
~ECTION SYSTEMS
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. SCHEMATIC OF RCRA TYPE CLOSURE-ALTERNATIVE 3
eEACON HEIGHTS LANDFILL SITE. BEACON FALLS. CT
SCALE: I": 400'
400
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400
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SCAlE IN FEET
-------
..
Figure 6
QUANTITY ESTIMATES
REMEDIAL ACTION ALTERNATIVE 3
BEACON HEIGHTS LANDFill SITE
Remedial Action
Estimated Quantity
. Excavation
Betkoskl Dump
Sewage Sludge and Salls
25,000 CY
18,000 CY
. Leachate Colfectlon System
Perimeter Drain
Trench Excavation
Synthetic liner (50 mil)
Gravel Backfill (Ie> 10-3" cm/sec)
8 In. perforated pipe
Filter Fabric
16 , 700 CY
157,000 SF
16,700 CY
4,500 LF
7,500 SY
. Stormwater Management System
Chlnnel Exclvltlon Ind Grlding
Berm Construction
Site Revegetation
11 ,000 CY
10,000 CY
40 AC
;.
. Leachate Treatment System
Package Treatment Plant
5,000 GPD
. Multimedia Cap
Gas Flow Zone
2 ft. sand & gravel Ie> 10-3 em/see
Impervious Zone
2 ft. clay Ie < 10-7 em/see
50 mil synthetic liner
Filter fabric
Infiltration Zone
1 ft. sand & grevel Ie> 10-3 em/see
Soil Zone
FUtir Flbrlc
1 ft. topsoil
106,500 CY
106,500 CY
1,437,500 SF
159,700 SY
53,200 CY
159,700 SY
53,200 CV
CY:Cublc Yards
LF: linee' Feet
AC:Acres
GPO: Gallons Per DIY
SF: Square Feet
SV: Squire Verd
Ie: PermeiblUty .
cm/sec: Centimeters' Per Second
.4
-------
Figure 7
.
REVEGETATION
,8 -0. TOPSOIl;
FIL TEA fABAtC
18-0. INFILTRATION ZONE
!SO MIL sYNTHETIC UNER
2'-0. CLAY BARRIER ZONE
. FILTER FABRIC
2'- O. GAS FLDW ZONE
E)oSTING GfQ,JND SURFACE
(GRADED UNDER CAP)
GAS PIPE VENT (TVP.)
STaWWATER CQ..LECTION CHANNEL
LINER ANCHOR TRENCH
$TORMWATER COLLECTION
CHANNEL
.v
WASTE I TILL OR BEDROCK CONTACT
LEACHATE COLLECTION SYSTEM (DISCHARGE TO TREATMENT PLANT)
BERM AS R£QlIRED FOR CONSTRUCTION OF S1URMWATER COLLECTION CHANNEL
AL OF RCRA'TYPE CAP C RNA
BEACON HEIGHTS ~LL SITE. BEACON FALlS. CT
NOT 10 SCALE
I
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."~ .'... :11.<-
-------
(16 )
CERCLA, Section 101 (24), defines "~emedial action" as inclu-
ding the use of offsite t~anspo~t of haza~dous substances only if
is necessa~y to p~otect public health, welfa~e, and the envi~onmer
c~eates additional disposal capacity, o~ is mo~e cost effective
than onsite remedies. The fi~st two c~ite~ia a~e not satisfied
by this alternative. However, the p~esent wo~th cost is ve~y
close to that of Alternative 3 (onsite t~eatment). Since the
degree of source control provided is identical to that p~ovided
by Alternative 3, a final decision on the leachate treatment
aspect of Alternative 3 would be deferred to the design phase of
the project, during which time additional data would be collected
and analyzed and the cost effectiveness analysis refined to
better compare the leachate treatment options within Alternative
3. . A Dec is ion Memorandum signed by the Reg ional Adm in istrator
~ould then be prepared to justify the selected option. .
Alternative 3C, RCRA Cap, Leachate collection and t~eatment
onsite with a temporary mobile system, Postclosure monitoring.
This alternative is identical to Alternative 3 with the exception
that a temporary, mobile treatment system from a commercial vendor.
would be used instead of bu ild ing a permanent "installa"t ion. ,.
This unit will most likely consist of an air stripper, to remove.
volatile organics, combined with carbon adsorption for removal
of non-volatile organics. The unit would remain on-site until
either leachate production drops to non-processable levels or
leachate production does not drop as expected, at which point
additional leachate handling techniques would be evaluated. The
primary advantage of this option is that a permanent on-site
facility need not be built if leachate production is only to
continue for a few short years, and in the meantime a less costly
treatment option can be pursued. However, this alternative has
disadvantages in that commercially available mobile systems may not
have all necessary unit processes to adequately process leachate to
discharge standards. It has been assumed for costing purposes that this
treatment will continue for five years after completion of the sou~ce
control remedy. The total 30 year present worth cost of this
alternative, assuming that leachate collection and treatment is
needed for only 5 years, is $16,409,000. Again, costing data
are included. within Appendix C, Table C-3. If design or predesign
work confirms that leachate production may drop to non processable
levels within a "short time and that a mobile unit can adequately
treat the leachate, this option is the most cost effective of
all the leachate.treatment options that provide adequate protection
of public health, welfare and the environment. Based on this
possibility, if Alternative 3 is selected this option would be .
further investigated during the design phase of the project and
a Decision Document would be prepared were this option to be
selected over options 3 or 3B.
-------
( 1 7 )
Alternative Number 4, Onsite RCR~ Landfill, Leachate
Collection and Treatment to NPDES Standarrts. This remedial
alternative involves the phased construction of an onsite landfill
meeting the technical requirements of RCRA, and the placement of
all conta~inaied material within the new landfill. The leachate
from the new landfill (double lined bottom) would be treated to
NPDES standards and discharged to the tributary of Hockanum Brook.
Th.is alternative includes a gas venting system and fencing around
the entire site. The phased construction process requires constructing
sections of the new landfill while excavating portions of the
old landfill. The project would require extremely high quality
control during construction to maintain the integrity of the bottom,
double lined layer, since large earth moving equipment will be moving
on top of it. Free liquids found within the existing landfill would
also require stabilization before disposal in the new landfill.
This alternative satisfies all source control objectives .for
site remediation and would provide a slightly increased degree of
protection beyond that afforded by Alternative 3 since all leachate
would be collected. 'Nonetheless, an offsite remedy would still be
required to mitigate the groundwater contamination which already
exists.
The implementability and therefore feasibility of " this alter~
native is questionable. Construction of this landfill would require
significant quantities of both fill and impermeable cover and liner
materials to be delivered to the site and consequently may take 4
or more years to implement. In addition, the siting would have
to take place partly on adjacent property since Beacon Heights,
Inc., does not own enough suitable land on which to build a new
landfill. This would require purchasing or taking land by eminent
domain to construct the new landfill and could also add to the
estimated time required for implementation. Excluding the costs
to purchase this additional land, the initial capital cost of
this alternative is $38,240,000 with a 30 year total present
worth cost of $40,040,000. .
Implementation of this alternative may also cause short
term adverse impacts to human health and the environment which
may not be totally coAtrollable by the use of mitigative measures.
The excavation and rehandling of such a huge mass of waste may
result in releases to the air of both hazardous organic chemicals
and methane from garbage decomposition in sufficient quantities
to pose a threat to the health of area residents. The control
of contaminated leachate and surface runoff during this operation,
particularly during storm events, would be extremely difficult if
" .not impossible with the result that both surface waters and
groundwater would be adversely affected.
Thus" on the basis of high costs and adverse environmental.
impacts of the alternative, this alternative has been eliminated.
.
, ,
~
-------
( 18)
Alte~native Numbe~ 5, Onsite RCRA Landfill, Leachate Collectior
and T~eatment to D~inking Wate~ Quality Standa~ds. This alte~nati,
is the same as alte~native numbe~ 4 except that the leachate will t
t~eated to a more stringent discharge standard, the drinking wate~
quality standards rather than the NPDES standa~ds. This option was
eliminated for the same ~easons as numbe~ 4 above.
Alternative Number 9, Public Wate~ Supply Provided to Extended
Area. This alternative includes extending the municipal water supply
approximately 7,000 feet along Skoko~at Road to the next town's
existing water main, and extending the public water SUpply along
Blackberry Hill R~ad approximately 5,200 feet to the demographic
limits. The limits of t~e wate~line extension are shown in Figures
8 and 9. All present and potential human receptors along Skoko~at Road
and Blackbe~ry Hill Road will be p~ovided with an alternate.
water supply.
The area of coverage for the water line was initially based
on the hydrogeologic setting of the landfill which was described
earlier. The indeterminate nature of local contaminant flow in
anisotropic, fractured bedrock mandates that coverage extend
beyond both the p~esently impacted area and the area of impact ..
inferred from consideration of surface topography to account for.
local disturbances in flow patterns due to pumping of private
wells or quirks in stratigraphy. These influences may cause
contaminants to flow toward deep bedrock receptor wells upgradient
of the landfill. Under this alternative, the wate~ line would
be extended to the limits of residential development on Blackberry
Hill Road to encompass these more distant potential ~eceptors.
The next possible receptor is 3000 feet from the p~oposed limit
of the wate~line. Homes in this a~ea would require extremely
deep wells to penetrate the bedrock formation that may carry
groundwater from the landfill, and such homes a~e far enough
away to avoid influences of pumping or other disturbances on
local contaminant flow patte~ns. The Skoko~at Road waterline
would be extended to the next town's se~vice limits for the same
~easons.
This wate~line extension will also requi~e upgrading of a
pumping station and installation of individual tap-ins to all.
residences .(approximately 54). Construction and engineering
requirements needed to complete this alternative are very common.
Since none of the source control remedies will mitigate the
existing groundwater contamination and all will allow some
leachate to ~nte~ the groundwater, this alternative would serve
as a supplement to a Source control remedy to mitigate and minimize
the risk from groundwater contamination. The initial capital
cost of this alternative is $1,958,000 with a long term present.
worth cost of $2,458,000. The quality of water from a municipal
source is predictable and costs are reasonable for the extent,
degree, and quality of remediation aChieved.
~
-------
Figure 8
I
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Remedial Action Alternatives 9 and 10
-------
Figure 9
PUB IC WATER SUPPLY-ALTERNATIVE 9 I
BEACON HEIGHTS LANDFILL SITE. BEACON FALLS. CT
SCALE: (=2000'
.,. . .
~~~
o A Hallib
~omp~nv.
-------
<19 )
Alte~native Numbe~ 10, Public Wate~ Supply to Affected A~ea.
Remedial action alte~native numhe~ 10 add~esses the a~ea that has
been shown to be impacted by contamination above cu~~ent acceptahle
standa~ds. Th. impacted a~ea includes a section of Skoko~at
Road app~oximately 2,000 feet long. The limit of this wate~
line extension is shown on Figu~e 8, along with Alte~native 9. This
alte~native would ~equi~e the installation of tap-ins to affected
residences (approximately 18) along the p~oposed extension. The
connection of a new public wate~ supply to the affected residences
along Skokorat Road will eliminate exposu~e whe~e site contaminants
have al~eady been identified in ~esidential wells in excess of
recommended fede~al and state guidelines. Howeve~, no mitigation
or minimization of the public health threat to those current res-
idents and/or future ~esidents outside the proposed se~vice a~ea
would be provided. Given" the aforementioned hydrologic setting of
the site, these residents may be exposed to higher levels of
contaminants in g~oundwate~ at some futu~e time. Already,
residential wells outside this affected area have been shown to be
contaminated witht~ace levels of o~ganic chemicals below cu~~ent
health advisory levels. The total capital cost of this alternative
is $370,000 with a long term p~esent worth cost of $870,000. This.
alternative, in conjunction with a source cont~ol alternative, .
will eliminate exposure to residences along Skoko~at Road only. ~.
Due to the lack of adequate protection provided to residents outside
the proposed se~vice limits (Blackberry Hill Road and the
top of. Skokorat road), this alternative has been eliminated since
it does not adequately mitigate or minimize the th~eat to public
health posed by offsite migration of contaminants f~om the site.
.
Alte~native Numbe~ 13, Long Te~m Monitoring with Institutional
Controls. This alte~native assumes that, due to the specific technical
const~aints posed by the site hydrogeology, an effective groundwater
extraction and treatment system cannot be implemented. Approximately
10 to 15 varying depth groundwate~ monitoring wells will be
installed adjacent to and downg~adient of the site to monitor the
effectiveness of the cap and to track any further sp~ead of
groundwater contamination. Several of these wells will be located
below the junction of Skokorat Road and Blackberry Hill Road to.
assess the potential for future groundwater contaminant migration
to this area, which contains several streets which lack municipal
water service and thus where private wells provide drinking water
. supply. Monitoring will be performed for a period of 30 years, or until
determined unnecessary by the Agency after thorough review of the data.
The long te~m monitoring data to be provided from these wells may
form the basis for establishment of ACL's (Alternate Concentrat~on
Limits), if needed to protect other groundwater users beyond the'
-------
(20)
It is expected that after a source control remedy is implemented
(cap) the groundwater contamination will attenuate ~nd dilute to
insignificant level~. In the unlikely event that contamination in
these monitoring wells does not reduce after the cap is completed,
the Agency reserves the right to perform further testing or studies
On the extent of contamination in the bedrock aquifer.
In order to ensure the long term protection of public health in
the area surrounding the site, strict institutional control over the
extraction and use of groundwater within the area of influence
of the landfill can be carried out under State institutional
controls, which are authorized by sections 2532 and 2533 of the
Connecticut General Statutes." For public supplies the Connecticut
Department of Health Services (DOHS) must approve the well site
prior to drilling. Prior to use of the welles), extensive testing
is required, and the data reviewed and approved by DOHS before
use of the well is allowed. For private water supplies no site
approval is needed, but a permit for use is required from the
local hea~th department. In addition, the Connecticut state
building codes require new homes to connect to a municipal water
supply if it is available within 200 feet from the residence.
This alternative, in and of itself, does not provide adequate
mitigation of the public health threat posed by groundwater con- ;'
"tamination emanating from the site, but may be a necessary adjunct to
whatever source control and offsite remedies are selected.
The initial capital cost of this alternative is $272,000 with
a 30 year total present worth cost of $998,000.
COMMUNITY RELATIONS
The public comment period for the Beacon Heights landfill
site began on May 20, 1985 with a press release announcing the
availability of the draft feasibility study for public comment.
During the comment period, a public meeting was held (JuneS,
1985), to present results of the RI/FS and answer questions from
the public concerning the cleanup alternatives. On June 11, 1985
a formal public hearing.was held to record comments on the cleanup
alternatives for the Beacon Heights landfill. The public comment
'period closed on June 14, 1985.
The overriding concern of many residents was to be provided
with a new wate~ supply first, cleanup later. Getting clean
"water to affected and potentially affected residents was priority
number one for the residents themselves and local officials.
Alternative number 9, water supply to an extended area was the
only water supply option that residents would accept. The State
of Connecticut agreed with the residents on this point. .
Another major concern expressed by several citizens.was that
alternatives 2, 4, and 5, onsite incineration, and RCRA approved
landfill with leachate collection and treatment to NPDES or
drinking water standards, could lead to other wastes from other
-------
( 21)
a~eas being b~ought onsite fo~ incine~ation o~ disposal. Since
no othe~ RCRA pe~rnitted landfills a~e available in Connecticut
the fea~ of othe~ wastes being b~ought to the Beacon Heights
landfill was b~ought up. In addition, a g~oup of potentially
~esponsible pa~ties, the Connecticut DEP, and othe~s submitted
comments du~ing the public comment pe~iod. These comments along
with those of the citizens a~e add~essed in the ~esponsiveness
summa~y. Fu~the~ information on 'community ~elations conce~ns can
be found in the Beacon Heights ~esponsiveness summa~y in appendix
D of this document.
CONSISTENCY WITH OTHER ENVIRONMENTAL LAWS
Environmental laws which may be applicable or relevant to
the Beacon Heights ~emedial action are as follows:
- Resou~ce Conse~vation and
- Clean Water Act
- Safe Drinking Wate~ Act
- Clean Air Act
Recove~y Act (RCRA)
Based on written comments from EPA's Planning and Standa~ds ~
Section the~e a~e no wetlands on site and no potential wetland
impacts as a ~esult of remedial activities at the site. The
Connecticut Historic Preservation office concludes that this
project will have no effect on historical, architectural, or
archaeological ~esou~ces listed on or eligible for the National
Register of Historic Places. Flood Plain maps provided by the
u.S. Department of Housing and Urban Development do not list the
site as lying within a 100 year flood plain. Gary King of the
Connecticut office of Policy and Management, the Designated Single
Point of Contact for intergovernmental review of federal financial
assistance and direct federal development recommended federal
agency funding of this project and fu~ther concluded that funding
is not inconsistent with the Connecticut Conservation and Development
Policies Plan.
The primary environmental law of concern at the Beacon
Heights site is the Resource Conservation and Recovery Act (RCRA),
42 U.5.C. S 6901, et seq. The proposed alternatives were reviewed
for consistency with applicable RCRA technical standards, Closure
and Post Closure Care, and 40 C.F.R. S 264 Subpa~t F entitled
Ground Water Protection. The first area addressed is the capping,
followed by the leachate collection and treatment, and lastly, the
alternate water supply and the g~oundwater remediation strategy.
The RCRA cap will be designed in accordance with 40 C.F.R. S 264.310
(a) to achieve the following: .'
.
1) Provide long term minimization of migration of liquids through
the closed landfill. .
-------
( 22)
3) P~omote d~ainage and mininize e=o5ion 0= ab=asion of the cove=.
4) Accomodate settling and subsidence 50 that the cove= integ=ity
is ma inta ined.
5) Have a pe~meability less than o~ equal to the pe~meability of
the unde~lying soils.
The cap installation and inspection will be pe~formed as
specified °in S 264.303. The landfill will be su~veyed and notice
will be filed with the deed and given to the local land autho~ity
as specified in S 264.119 and S 264.120. The applicable closu~e
requiremepts in S 264 Subpa~t G will be addressed. (Decontamination/
Disposal of Equipment, Ce~tification by Professional Enginee~,
and Site Security will be provided as specified in S 264.1l7(b».
Post Closure Ca~e and g~oundwate= monitoring will be pe=fo=med in
accordance with 40 C.F.R. S 264 Subpa=ts F and Gand Subpa=t N S
264.310 (b).
If offsite leachate disposal is chosen as the most cost effec-
tive =emedial action fo= sou=ce control, then leachate collection,
transportation, and disposal will be pe=fo=med in acco=dance with.
the applicable RCRA =egulations at 40 C.F.R. S 262, St~ndards App)icable
to Generators of Haza=dous Waste and with 40 C.F.R. S 263, Stand~rds
Applicable to T=ansporte=s of Hazardous Waste. Leachate collection
will be in compliance with 40 C.F.R. Part 262.34, Accumulation of
Hazardous Waste on-site fo= 90 days 0= less, and will not =equi=e
a RCRA permit. Even if treatment occu=s onsite, a RCRA pe=mit will
be required. Offsite facilities used for the treatment and
disposal of the leachate will be approved facilities ~hich have a
pe=mit or interim status and are in compliance with the RCRA
regulations. Proper manifesting of the wastes will be conducted. 0
The source control alternatives that satisfy all applicable
or relevant environmental laws (primarily RCRA) are alternatives
1, 2, 3, 38, 3C, 4, and 5. Alternatives 3A, 6, 7, and 8 do not
provide adequate control of source material as required by 40
C.F.R. S 300.68 (h)(2) of the NCP.
Extension of a municipal water supply to area residents
(Alternatives 9 and 10) is consistent with the appropriate
extent of remedial action as defined in 40 C.F.R. S 300.68 (e)(3)
of the NCP.Contamination has migrated beyond the area where the
hazardous substances were originally located, and the installation
of an alternate "water supply is necessary to provide long term
protection of public health and welfare by preventing ingestion
of contaminated groundwater.
Since existing data are adequate to conclude that the hyd=o-
geologic setting of the landfill precludes the ability to effectively
intercept and extract contaminated groundwater, neither alternative
11 or 12 is technically practicable. In addition, since they provide
little assurance of reducing offsite groundwater contamination,
-------
. .
(23)
they provide. Under RCRA 40 C.F.R. Part 264, Subpart F, Groundwate~
Protection, contaminaterl groundwater leavin~ the wast~ management
area must be .re~ediated to background levels, to MCL's (~axi~u~
Concentration Limits, which are enforcible), or to ACL's (Alternate
Concentration Limits). The long term monitoring data to be provided
by i~~lementation of alternative 13 may form the basis for future
establishment of ACL's. This determination will be made by the
Regional Administrator in a future Decision Document if necessary.
RECOMMENDED ALTERNATIVE
Section 300.68 (j) of the National Contingency Plan (NCP)
states that the appropriate extent of remedy shall be determined
by the lead agency's (in this case EPA) selection of the alternative
that 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 ~ealth, welfare, and the environment.
In order to meet the stated objectives of site remediation,
both a source control remedy and an offsite remedy are necessary
since neither can provide adequate protection of public health,
~
welfare, and the environment without the other. .
Based on the evaluation provided in the Feasibility Study
Report, and after consideration of the comments expressed by
the public, local officials, potentially responsible parties,
and the State of Connecticut, EPA has determined that the
following combination of source control and offsite remedies
meets the aforementioned NCP criteria:
SOURCE CONTROL REMEDY:
Excavation of outlying contaminated soils including the
Betkoski's Dump area, leachate seep areas, and sludge
disposal areas
Consolidation of this material with the main landfill
Capping of the landfill area in conformance with the
technica~ requirements of RCRA
. Gas venting ( with air pollution controls if determined to
to be ne~essary during design phase)
Perimeter leachate collection system
Treatment of collected leachate either onsite or offsite,
-------
(24)
Enclosu~e of the site with $ecu~ity fenci~g
Stormwa.ter management c()nt~ols
Construction of a more extensive groundwate~ monito~ing
network to enable future evaluation of the effectiveness
of the cap
OFFSITE REMEDY:
Extension of municipal waterline to supply water to residents
along Skokorat and Blackberry Hill Roads
Long term monitoring of groundwater contaminant ~igration
State and local institutional controls on groundwater use
in the impacted area
The source control remedy is Alte~native 3, described in the
Feasibility Study Report and in the Detailed Evaluation section of,
this document. Source control Alternatives 1 (Offsite"disposal) ;
and 2 (Incineration) were eliminated during the initial screening-
on the basis of cost, engineering feasibility, and potential ad- .
verse environmental effects. Alternatives 3A (RCRA cap with no
leachate collection/treatment), 6 (Soil cap), 7 (No action),
and 8 (Monitoring) were also eliminated during the initial
screening, since they would not achieve adequate source control.
The rema in ing source control al ternat ives, 3 and. its
options Band C ( RCRA cap, leachate collection/treatment, post-
closure monitoring), 4 (RCRA landfill, leachate cOllection/
treatment to N.P.D.E.S. standards), and 5 (RCRA landfill,
leachate cOllection/treatment to drinking water standards) all
provide adequate source control. A comparison of the present
worth costs for these alternatives clearly shows Alternative 3
to be cost effective since it is the lowest cost source control
alternative that is technologically feasible and reliable and
provides adequate control of source material. As indicated
previously, a reconsideration of the option for leachate treatment
will be made during the design phase of the project. Further
data gathering and analysis is needed to refine the costs for
treatment onsite' with a permanent installation (Alternative
3), treatment onsite with a temporary installation (Alternative
3C), or offsite treatment (Alternative 38). The present worth
costs for 3 and 38 are virtually identical based on the level
of analysis provided in the Feasibility Study (+50%, -30%).
The refinement of stream discharge requirements, timeframes for
landfill dewatering, offsite facility costs and requirements,
-------
(25)
allow costs to be estimated to the + 10% level. This will in
tu~n ve~ify o~ ~efute the existing analysis which shows that the
onsite t~eatment Alte~native 3 is the cost effective alte~native.
This design phase analysis will also p~ovide the data to dete~mine
if a tempora~y (Alte~native 3C) o~ a pe~manent (Alte~native 3)
installation is necessa~y. A Decision Memo~andum will be p~epa~ed
fo~ the signatu~e of the Regional Administ~ato~ to document the
cost effectiveness of the ~ecommended option. This memo~andum
will also detail the extent of excavation in those a~eas to be
consolidated with the main landfill p~ior to capping.
The recommended offsite ~emedy is a combination of Alternatives
9 and 13 described ea~lie~. Offsite alternative 11 (Groundwate~
extraction /treatment) was eliminated during the initial screening
on the basis of enginee~ing infeasibility. Alte~natives 12 .
(Additional Study), 7 (No action), and 8 (Monitoring) were also
screened out since they do not provide minimization or mitigation
of the offsite mig~ation threat.
The limited wate~line extension (Alternative 10) was elimi-
nated during the detailed evaluation because it would p~ovide no
protection to those residents beyond the extension limits who are
threatened by offsite groundwater contaminant mig~ation f~om
the site. Thus, this alternative does not meet the requirements:
of 40 C.F.R. S 300.68 (h)(2) of the NCP. .
The combination of municipal water supply extension to the'
present and inferred area of impact, long term groundwater moni-
toring, and state institutional controls over the withdrawal and
use of groundwater in the a~ea will provides minimization and
mitigation of the threat posed by offsite contamination.
The estimated capital and present worth costs for the recommended
alternatives are as follows:
Capital cost
: $ 17,397,000
P~esent worth cost: $ 19,613,000
(These costs are less than the additive costs of Alternatives
3, 9, and 13 presente~ in the Feasibility Study and in this document
because the well installation and monitoring costs of Alternative 13
duplicate those included in Alternatives 3 and 9).
OPERATION AND MAINTENANCE
Operation anq maintenance costs (0 & M) are those requi~ed
to operate and maintain the remedial action throughout its
lifetime. This activity ensures the lifetime effectiveness of .
the remedial alte~native. A present worth analysis was done
On the 0 & M costs for all remedial alternatives and is
presented in appendix D. This present worth analysis represents
-------
( 26)
expenditures that will occur in the futu~e in te~~s of cU~re~t
dollar value. Unless otherwise specified, a 30 year project life
was assumed for the 0 & M analysis for all alternatives.
The alternatives chosen for the cleanup of the Beacon Heights
site are alternatives number 3, 9, and 13. These alternatives
implement technologies to control the source of contaminant
releases and to mitigate offsite migration. A complete breakdown
of project costs, including both capital and 0 & M for the selected
remedy is presented in figure 10.
Under source control alternative 3 a RCRA cap will be placed
over the entire landfill to reduce the degree of leachate
generation and migration. Maintenance of the source control
alternative 3 will include lawnmowing of the grass cover overlying
the cap, repair of damage to the security fence, removal of
obstructions from the stormwater management and gas venting
systems, and regrading as necessary. Monitoring will include
sampling and analysis of upgradient and downgradient monitoring
wells, surface waters, and collected leachate.
Alternative number 3 also provides for the collection and
treatment of leachate. The different options for treatment of
the leachate provided the basis for development of alternatives
38 and 3C. Since both these offshoots of alternative 3 provide ~
the same degree of source control as alternative 3 itself, .
the final decision on the leachate treatment aspect of source
control is being deferred to the design phase of this project.
During this time additional data will be collected and analyzed
and the cost effectiveness analysis refined to better compare the
leachate treatment options. A Decision Memorandum will then be
prepared to justify the selected option.
Annual 0 & M costs for leachate treatment will include labor
for operation of the leachate collection system and materials and
labor for operation of the onsite treatment system. If data
gathered during design shows alternatives 38 or 3C are more cost
effective than onsite treatment (alternative 3) 0 & M costs will
include transportation of the leachate to a licensed hazardous
waste ~reatment facility, or costs for rental of a temporary
treatment system. Again, this decision will be documented in a
Supplemental Decision Memorandum. .
Leachate collection and treatment will be considered part. of
the approved action (not an operation and maintenance cost) and
will be eligible for Trust Fund monies for a period of up to two
years from completion of the source control remedial action.
This action is consi~ered part of the source control remedy since
it may be a temporary action and control of leachate production
is considered to be a vital component of adequate source control.
Water balance calculations indicate that a RCRA cap over'
the entire landfill will drastically reduce the amount of
infiltration allowed to reach the waste material, and will
therefore reduce leachate generation. However, in the interim,
before the water level within the waste drops due to the influence
-------
F igu:.-e 10
RECO'1MENDED ALrSR.~ATlVE COST S:..r,.1MARY
Remedial Action Alternative 3 - RCRA Cap C1osu:.-e
INITIAL CAPITAL COSTS
Excavation of adjacent wastes - 43,000 CY
Mult imed ia Capping System (Includes Fence)
Leachate Collection System
Leachate Treatment Syst~
Methane Vent ing System
Stormwater Management System
Mon itor irYJ Well Installat ion
Upgrade Access !bad
Redes ign Bor ing Program
'IUl'AL, INITIAL CAPITAL COST (ALTERNATIVE 3)
9Peration and Maintenance (O&M) Cost
Leachate Treatment System
. Site Maintenance
Monitoring and Analysis (without residential wells)
1Ul'AL O&M cnsTS
PRESENI' \rDRTH O&M COSTS
'IDrAL ALTERNATIVE 3 COST
$ 1,010,000
$11 ,514 ,000
$ 850,000
$ 263,000
S 340,000
S 489,000
$ 272,000
S 540,000
$ 161,000
$ 15,439,000
$
$
$
90,000
23,000
. 69,000
$ 182,000
$ 1,716,000
$ 17,155,000
Rented ial Act ion A1 ternat ive 9 - EX tended Waterline
-------------------------------------------------------
. INITIAL CAPITAL COSTS
Alternate ~inking Water System
Monitoring well Installation
TCYI'AL, INITIAL CAPITAL COST (ALTERNATIVE 9)
Operation and Maintenance Cost
Inspection and Maintenance
Monitoring and Analysis
'l'Ol'AL O&M OOSTS
PRESENT K>RI1f O&M OOSTS
TOTAL AL~TIVE .g COST
--
S 1,844,488
$ 113,438
$ 1,958,000
$
$
8,760
43,800
S 53,000
$ 500,000
$ 2,458,000
----------------------------------
TOTAL PInJECT INITIAL CAPITAL COST
'IDrAL O&M OOST
'l'Ol'AL PRESENT K>Rm O&M COST
'IDrAL PInJECT CX>ST
S 17,397,000
$ 235,000
S 2,216,000
S 19,613,000
* Note Alternative 13 costs not included because costs (well insta1!.ation and
monitoring) duplicate those included in Alternatives 3 and 9 above.
, .
,.
.
-------
, \
. .
Figure. lOA
COST SUMMARY FOR
lEACHATE COUECTION AND TREATMENT OPnONS
BEACON HEIGHTS I.ANDFIU. SITE
Initial Total
Capital Annual( 1) Present Worth(2) Project
Altematlve/ODtlon Cost 08rM Cost O&M Cost Cost
Alternative 3: RCRA Cap with l88chate $15.439,000 $182.000 $1,716,000 $17.155,000
Collection and Treatment
(30 year 0 & M)
Option A: RCRA Cap without leachate 14.326.000 92.000 867.000 15,193,000
Collection and Tr.atment
Option 0: RCRA Cap with u.. 0' POlW 15.218,000 380.000 3,394,000 18.610,000
(30 years leach at. treatment) (275.000)(3) (2,592,000) (17,808.000)
Option 0: RCRA Cap with Us. 0' POlW 15,216.000 380.000 1.883,000 17,099.000
(5 years leacha.. treatment) (275,000) (1.561.000) (16.777.000)
Option C: RCRA Cap with Use 0' Mobile Units 15.238.000 172.000 1.171.000 16,409.000
(5 years 'eachate treatment)
(1)
(2)
(3)
O&M Costs Include site melntenance at $23.000 per year and sampling and analysis of monitoring wells (no residential
wells) at $69.000 per ye.r. I total 0' S92,000. .. .
Includes 30 years 0' O&M for site maintenance and monitoring for an present worth calculltlons.
These costs Issume leachate treatment for $.06 per gallon. an average cost quoted by the treatment plant.
-------
(27 )
of the cap, leachate will continue to be p~oducerl. Du~ing this
pe~iod the leachate p~oduction must ~e cont~olled. In the two
yea~s following completion of onsite const~uction the floN~ate of
leachate and the wate~ level within the fill mate~ial will ~e
monito~ed to see if a steady state has been ~eached. Afte~ the
two yea~s a decision will be made to eithe~ continue collection
and t~eatment of leachate as an ope~ation and maintenance activity
o~ to terminate onsite treatment and pursue other treatment
methods due to ve~y low levels of production. These actions will
be documented in a Decision Memorandum.
STATE ~
The state's role in "this federal lead site is multiple. The
state reviews documents to determine if they are in compliance
with applicable state laws, and provides comments on all EPA
funded studies at the site. The state of Connecticut, as represented
by the Connecticut Department of Environmental Protection (DEP),
concurs with EPA's chosen remedy for the cleanup of the Beacon
'Heights site located in Beacon Falls, Connecticut. The state
will provide 10 percent of the initial capital costs of the
chosen remedy and will assume responsibility for all 0 & M
costs following completion of onsite construction activities.
~
.
SCHEDULE *
- Approve Remedial Action (sign ROD)
- Complete Enfo~cement Negotiations
- Septembe~ 20, 1985
- November 20, 1985
Phase I - Alternate Water Supply, Water Main Extension
.
- Award Superfund Contract for Design
- November 21, 1985
- Start Design
- Start Construction
- Complete Construction
- January 1, 1986
- May 1, 1986
- September 1, 1986
" .
Phase II - Source Control, Cap and Leachate Collection
- Send Interagency Agreement
the Army Gore of Engineers
- Start Design
- Start Construction
- Complete Construction
(lAG) to
for Design
- November 21, 1985
.
- January 1, 1986
- October 1, 19~6
- March 1, 1988'
* Pending availability of funds
\
~
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(28)
FUTURE ACTIONS
~
Some additional field investigation wo~k will ~e ~ecessay
du~ing the design phase of this p~oj~ct to ~p.lineate the exact
extent of coverage of the RCRA cap on the landfill and the a~eal
extent and depth of the satellite a~eas (Betkoski's Dump, sludge
disposal a~ea, and leachate seep areas) to be excavated and
conso~idated on the main landfill. Requi~ements for handling
these contaminated a~eas to meet RCRA requirements on free liquids
content must also be determined. This contingency has been add~essed
within the cost sensitivity analysis in the Feasibility Study.
Costing data included in Figure 10 and Appendix C assume highest
cost, and hence, la~gest cap and largest excavation expected.
Future actions include monitoring the cap's effectiveness,
as well as assuring the future effectiveness of the selected
remedy through ope~ation and maintenance. Monitoring for cap
effectiveness is required under Post Closure Care and Groundwater
Monitoring as defined in accordance with 40 C.F.R. Part 264 '
Subparts f and G and Subpart N S 264.3l0(b).
An additional possible future action may be are-evaluation
of offsite g~oundwater contamination. Contingent on monitoring
results for the cap effectiveness and groundwater tracking, a
decision to revisit the feasibility of groundwater ex~raction and:'
treatment may be made by the Regional Administrator. This decisiOn
may include additional remedial actions to ensure adequate protec~ion
-------
APPENDIX A - SITf:: LOCATION
:.
-------
J
Figure A-I
LOCATION MAP
BEACON HEIGHTS LANDFILL SITE. BEACON FA.LLS. CT
SCALE: 1"' : 2000.
.~ '"
E!l~@
-------
9;..':'C'
-------
~
o
~
,
IC
.
-
10'....11" 881..11
FIGURE A-3
REGIONAL
BEACON
MAP - BEACON HEIGHTS
FALLS, CONNECTICUT
LANDFILL
SITE
-------
APPENDIX B - SITE CONT~INANTS
,
,.
.
..
-------
fjj~Y~
A ~
w A Halliburton Company
~.-
-------
Figure B-2
etj~Yii
o A Halliburton Company
, .
. ..- ,- .~_.' .".
-------
CT [:tj~~.J
-------
-------
Table B-I
CRITICAL CONTAMINANTS - TOXICOl06:cAl DATA
FOR HEAlTII EFFECTS WITH ASSOCIATED TtfWHDlD lIMITS
Chronic JOIlIr.ity
M'Jllmum Does not Consider
Observed Acute TOJllcity Indlutors C.rclnogenlcity
ConcentflUon Humana OermalD AcceptableiJ-
Crltlcel (Media) Inha" TCLO (ppm) Absorption He.lth Advlsorlesc Dally "","es
Contemln.tlon lIan Ofll TO. n Imglllal TOlllclty IlIalll -11!!J~} ---
1. Benrene 35. 100 "uJI TClO . 100 Mode,.te Penelretlon 1 day - 230
CAS No. 71-43-2 leech"e TOlO . 130 Moderete locel Potency Iona term - 70
EIItreme Systemetlc (In liquid form)
2. Chlorobenl8ne 1.310 lIan Moderate PenetreUon I.OUII
CAS No. 108-90-7 leachlte Mode"te lOCII Ind System
Potency (In Hquld form)
3. Ethylbenzene &90 IIg/1 TCLO . 100/8M Slight Penetretlon 1 dlY - 21.500 9.5UO
CAS No. 100-41-4 leachlte Moder.te local Ind Systematic
3.800 "glllg Potency (In liquid form)
Sludge
4. Toluene 2.400 lIan TClO . 100 Slight Penetretion IdlY - 21.500 :10,000
CAS No. 108-88-3 leach"e Slight loul Ind System 10 dly - 2.200
11.000 IIglIIg Potency (liquid) lon9 term - 620
Sludge
5. Xylene. Totll 447 "gll TClO . 200 1 day - 12,000 11601
CAS No. 1330-20-7 l.echlte 10 day - 1.300
12,000 IIg"g 10119 lerm - 620
Sludge
BII (2-chloroethyl)ether ".680 11911
lelcha"
-------
, .\
Table a-1
CRITICAL CONTAMINANTS - TOXICOlOGICAL DATA
FOR IIEAlTH EffECTS WITH ASSOCIATED THRESItOlD UlnTS
PAGE TWO
Chronic TOMlclly
Mlllimum Does not Cunsi:lcr
Observed Acute TOlllcity Indicators Carclno~!=!!1__-- -- -
Concentrlltion Humen. OermalD Aeeeill ahled
CrlUcal (Media) Inhl" TClO (ppm) Absorption Hellth Advlsorlese Daily Int;,ke5
Cont.mlnatlon IIAII Or.1 TO. n (mA/kg) TOlllcity (lIgIII - --11!9{!!'!yL-
7. Bls(2-ethylheJlyl)phthlllll 58 IIgII TOlO - 10 "1.111111
CAS No. 117-81-7 Res. Wells
65.000 IIglltg
Sludge
8. 1,2-dIChloroeth.n. 119 11911 TClO . 4000M
CAS No. 107-062 Lelch.t. lOLO. 714
~. Trlchloroet"ene 17.4 IIUIl TClO - 110/8H 1 d.y - 2.020
CAS No. 79-01-1' Lelch.te lClO - 7000 10 d.y - 200
long-term - 15
10. Vinyl Chloride' . 778 119II TCLO . 20130M High PenetrlUon (Oil'
CAS No. 75-00-3 Le.ch.te hlreme System Ind LOClI
Potency (0..)
11. Chloro.thlne 1.450 IIglI TCLO . 13.000
CAS No. 75-00-3 Le.ch.te
12. Mlthylene Chloride 500 IIgII TCLO . 500/8H Moderate PenatraUon 1 day - 13.000 1:1.11110
C.. No. 75-09-2 Resldlntlll Moderate System and LocI' 10 d.y - 1.300
Well Potency (liquid) long-term - 150
~
13. Acetone 3.490 11011 500 111111.1111111
CAS NO. -17-64-1 Leilch.te 12 . 000/8H
41.000 IIgII
Sludge
'" ; .
-------
Table B-1
....
CRITICAL CONTAMINANTS - TOXlCOlOOlCAl. DATA
FOR HEAlTII EFFECTS WITH ASSOCIATED THRESIIOlO lll'UTJ
PAGE TIIR£E
Critical
ConlamlnaUon
Maximum
Observed
Concenlrltlon
(Media)
IIAII
Humlnl
Inhal. TCLO (ppm)
Or.1 TO. n (mgJltAI
Acute Toxicity Indicators
OermalD
Absorpllon
ToxlcllY
14.
2-bUtinone (MElt)
CAS No. 78-9J-J
29.000 1/911
Sludge
&.090 I/gII
leach..e
100I5M
15.
4-methyl-2-pentanon8
CAS No. 108-01-1
1.850 IIgII
leachlte
Sources:
(I)
(c)
(d)
USOHHS July 1984
USEPA 19801
USEPA 198Gb
None reponld In toxicology dat. basI
Lowest reponed loxlc concenlr.tlon (In 1mb lent II"lor In Ixposure dur.tlon (8M - 8 minutes. ItC.).
lowest dosl at which the loxlc e"ect was observed
Suggested no adverse reaction 'evles .t which no Idverse .ttecls would b. ellpected below this level.
lowest reponed lethal dose
TCLO
TOLO
SNARLS
LOLO
NOIIS:
t.
Thl lack 0' eVlllable dala dOl. not Imply associated he.llh implcls .re not present.
.
'" r. .
.,
Chronic Toxicity
Does nol Consider
CarcinOllenlclty_, -,
Ar.coptabloil
Hlallh Advlsorlesc Daily IIIIa.os
(lIglII hlg/day) '-
.
1 dly - 7.500
10 day - 750
11,400'
-------
Table a-I
Ma.imum Cardnogenl(
CRITICAL Observed Potency Caused Reported
Con(entratlon. (mg/IIg/dayl- t Mutagenkl3 Reprodu(tive Tumorigeni(
CONTAMINANT (ugIU C.rdnogenldty (e) (I) (gl Bioanay. (a Efle(ts Ca) A(tivity Ca)
I. lenre..(4Y) JUDO huINn.definite (el G.OS! (human .!!! Y!1!g . ,.alt Cauleel reprodudlve effects Cauled tumon - O8al.rat
CAS No. U-4J.J le.hat~ beMII on epldernlo- ouupation.l . !!!..!!!!g - human. In ratl end mice. lO,o' 519"""11.
tovk" data by Inhal- e.posure rat. _.e. ,abbll Oral-moulllOto Ulflll'1I All other elletts by
atlon. O8al, Inhalation Ii Studiel inhalalion roule.
H- & _mal
s"specled (f)
J. Chlorobenlt.. (7Y) UtI none 'eporleel (al Nil Nil Nil
CAS No. '08-10-7 le.hate Nit
J. Ith,abenlene ()IV) HI pretently bel", lesteelln . lisle' chr_lide.. 4 entries. lloute of e.posure Non.ltepo.led
CAS No. ,.41.4 le.hate 1M NIP (al Nil change bi08"a, on human by Inhalation onl,.
I,mphatic II"ue ., I. fft9Il.
Onl, 1 entr,.
4. '01_(16Y) J.- pr""'II, bel", testeelln Nit . !!! ~. J bioalsa,. Caused ,eproductlve elfects None IIepolled
CAS No. 'OI...J le.Mle lheNIP (el In bacte,la end ,.ast; In mice. or.n, doMII at
t U_malial cell Woe"a, 'Otool... 11""'11
. i!!!!!JI- inhalalion onl,
S. 'otal .,..nes 447 none ,eported Nil . in ~in ,east CauMII ,eproducllve elfedl None Iteporled
CAS No. tJ)O.JO.7 le.hat. In mice. or"l, doMd el
'Oto- JI..
,. lislJ-chloroeth,a) 4.'" .nlmal positive (h) . Arnes 8108".'
11M' (tll) le.hal. 1.14 Nil Nil
CAS No. '''-44.4
.,. lit(J-ethylhe.yt) sa ...._1 poslli".; human Nil . Ames 1100"a, Cauleelelfeds In mice end Caused tumoll in mICe
Phthalale (MI) ..sldenl'" Indefinite 1ft . l Mamalian cell bioa"a,I rats- O8all, dosed at and .ats. o.all, adm (!f
CAS No. Well e.peeled 10 be a . i!! ili! mousa bioa"a, 'Ot 0 )5. "40""" II .aUl"'''''''g
I cardnogen (e) mitelliG gmll"J
CRITICAL CONTAMINANTS. TOXICOlOGKAl DATA
fOR HEALTH EffECTS WITH NO
ASSOCIATED THRESHOLD LIMITS
.~ t. .
.'
-------
Table B-2
..
, .
VOlATU 0R0NaC CONTAMINMTS RUm MOVE DE1"EC11OI8 LMII .. tHE VARIJUS MEDIA
IIEACON HEIOHTS tANOFIU. SITE
Surf8Ce Surface
AIr SoUa le8Chate. Water Sediment I
PP3 CAS No, Contemlnant I uatm3. luaJKa. lua". IUQIL IUglkgt
VoIltll. Oraanlc.
4V 71-43-2 b8nHne 18.' - 21.5 (3) 35 - 2.200 (3) 27.8 - 35.000 .(11) 16 - 49 (2) -+
7V 108-90-7 chloroben,.... 20 - 1.030 (8) 15.5 - 5.310 (10) 17.5 - 95 (2) -+
IOY 107-06-2 1,2-dlchloroeth8n8 119 - 245 (2) -+
l1V 71-55-8 1. 1. I-trichloroethane 283 (1) -+
13V 75-34-3 1.I-dlchloroettl8ne 37 (1) '.2 - 512 (5) -+
IIV 75-00-3 chiorMthane 20 (1) 29 - 1.450 (8) 10 ( I) -+
38V 100,..41-4 ethylb8n,ene 25 (1) 5 - 590 (B) -+
44V 75-09-2 methylene chloride . - 120 (18) 4 - 126 (10) S - 22 (12) 31 - 210+ (7)
30Y 158-60-5 1,2-tranl-dlchloroethene 138 C I)
49V 75-68-4 fluorotrlchlor08thene 20.8 (I)
86V 108-B8-3 toluene 18 - 20.7 (3) 15 - 2.800 (I) 20.8 - 2.400 (I)
87V 78-01-1 trlch_oath.... 17.4 (I)
B8V 75-01:-4 vinyl chloride 12 CI) 77' (I)
'7-64--1 Icatone 24 - 3.400 (5) 10 - 3.490 (10) 10 - 19.9 (8) 52+
78-83-3 2-butanon. (MEK) 140 - 20.000 (4) '.3 - 1.090 CB) 8.3 - 36.4 (2) 17 - 163. CS)
108-10-1 4-methyl-Z-pentlnone CMIBIC) 35 - 1.080 (4) 8,8 - 1.850 . (I)
100-42-5. Ityrene 40 - 10 (2)
Total xyI.ne. 7.83 - 8.8 (3) 480-- (2) 11 - 447 (5)
518-78-1 2-h...non.
"
-------
Table B-2
VOtATU 0R0AI8C CONJAI8WRS FOUND ~ OE1ECOOII tMTS
.. mE vARIOUS MEDIA
BEACON HEIOHTS tANDfIU. SITE
PAGE TWO
Groundw8ter
(5h8110w Weill)
PP3 CAS No. Cont8mlnent Cuall)
VoIetH. Oraanlcl
4V 71-43-2 benzen. 8-800 (4)
7V 108-90-7 chlorob8nZ- 1.3 - 320 (4)
10V 107-0602 1.2-dlchlor08tha.
11V 71-55-8 1.1.1-trlchlorotth8.
13V 15-34-3 1.1-dlchloroeth8ft8
16V 75-00-3 chloroethan. ~80 (2)
38V 100-41-4 ethylb.nz..
4.V 15-09-2 methylen. chCorld8 '-380 (7)
30V 158-80-5 1.2-tranl-dlchloroethln.
49V 75-89-4 ftuorotrlchlorometha.
86V 108-88-3 toluen. 1.1-8 (2)
a7V 79-01-8 trtchloro8thln. 1.2 - 11 (2)
88V 75-01-4 vinyl chlorld.
87-84-1. .cetone
78-93-3 2-butanon. (MElt)
108-01-1 4-m.thyl-2-pantanon. (MIlK)
100-42-5 Ityr.n.
Tot" ayl8n81 4 - 34 (2)
518-78-8 2-h...none
. .
-------
"
Table B-2
II
VOtATU ORGANIC CONTAI8tANTS ~ MOVE DETECI'IOH lMTS
.. THE VARIOUS MEDIA
. .BEACON HEIGHTS lANOfI.1. SI1E
PAGE THREE
~:
1)
2)
Numb." In par.nth.... (8) If8 the number o' po.ltlve ob.ervatlon..
Blckground vllue. '0' IIr contamln8nt. I,. I' .0110..: benzen. (1.18 ..81m3); toluene (5.38 "81m3); xyI..... (3.53 ..81m3).
3)
R.ported valu.. a,. the mlnlmum-:-mulmum (35 - 2.200) contaminant concentration range..
Entrl.. mlrlted with I da.h (-) Indlcat. non. wlr. found above detection UmIt. few that medium. For detection IImh. o. the plrtlcular ob..rvaUons. ...
the tabl.. In Appendl. C.
. 4)
5)
(+) Indlcat.. only on. .ampllng round. R..ult. .r. rncluded In thl. tlbl..
-------
. .\
Table B-2
S08-VOIA1U ~ 0II0M8C co.rM8WIIS
JCJUII8) AICM DE1tC11OII tMTS . tIlE VANOUS MBM
. 8EAaJN HBOHTS tN8JR1. lITE
Ofoundw8ter QrouncIw....
CShIItow caldfoc' Oroundwltlr
Surfacl Surt8C8 MonItoring . Monltortng CRelldenU.t
'* Sol. l88ctI8t.. Wa.... S.IIIMftt. Well.) Well.) Well.)
~ CAS No. ConI"""" ~ I ulll'al lua/U I ua/U lulll'at lualll lua/U lua/U
128 17-72-' ~h8n8 NA 232 C')
'88 111-"-. blaC2-lthylhuyl)8tll8r NA 228 C2) 2. - ..180 C4) .20' C') .1 - 1.2ooC2) is - 4.360 (3)
2M1 95-50-1 '.2-cllchlorob8N"" filA SO - '38 (2) '0 (')
398 208-44-0 nucw....t""" NA 1.100 - n... CS)
558 11-20-3 nlpllt..."'" NA 710 C') S04 ' 110 - 250. C4)
668 117-81-7 blaC2-.....,...ayQpIIthaI8Ia filA 1.810 C') 21 - 30 (2) -. 38 (') 32 - 58 (3)
178 85-18-7 butyl b8NyI pIIt""", NA 117 C') -.
188 84-74-2 dI-n-butyi pIIt"...t. NA -. 510 (')
I. "7-81-7 dI-n-octyi pIIt"...'a NA 22 C') -. 22-44 (3)
.
728 51-55-3 benzoCltanttwIC'''' NA 100 - UOO. I.)
738 60-33-1 benzoCI."" NA UOO - 3.800. (3)
748 205-99-2 banzoCb)ftuoran''''''' NA . UOO - 5.SOO. C4)
758 207-08-1 benzol')nuorlnt".... filA 2. '00 - 4:zao. (2)
718 2'8-01-1 clvy..... filA SOO - 4.100. (5)
778 208-91-1 8c:_pIIllIyIan' NA 410 - 730. (3)
788 nO-n-7 anl"'ac.... NA 17 - ISO. (5)
718. "'-:24-2 benzoC"'--.,te... filA 100 - 1.200. C4)
lOB 86-73-7 11_"" fIlA 280 - .80. (2)
118 85-0'-8 pIIananttnn8 filA 5.100 - 7.700. C.)
828 113-39-5 1nd8noI'.2.3-ccQpyr8n8 NA 2.030 - 3.400. I.)
848 121-00-0 pyrena fIlA .70 - to..+ C5)
132-84-1 'dibenloIur8n NA '30 - 780. P)
11-57-1 2-mathyln8phtha18n8 fIlA " ..) no. I')
fIIumb8n In p""''''''' CS) .,. the number of po.IIM obl....tloftl.
Reported Vlllu81 .rl the minimum 10 mutmum (35 - 2.200) cont""""'" concentrltlon "noeL
(ntrla. merted. wit" . ell'" C-) lndIc.t. none wer. found .bo" detection limit. for U"I medium. For
dltlCtlon ImItI .. t'" pantcul8r obl8JVItlonL .1. the ....... In App8ndbI C.
C.) C.) 1ndIc.... only one sampling round r..unl .,. Included In thll tabll.
NA Not An.lylld
..)
(2)
C3)
.~ .. .
-------
, ,
Table B-2
.
SEMl-VOIAtU (ACID . PESTICIDE) 0II0AI8C COIITM8U.NTS
fOUHD AIKJVE DETECnON I.MTS II THE VARIOUS MEDIA
BEACON HEIOHfS tANDfU. SITE
PP3
CAS No.
Cont.mln.nt
Air
IIIa/m31
Surf8c:.
Sol. .
luallCal
l.ech.t..
lualll
SUrfIC.
Wlt~r
fuall
Sedlm.nt.
fug/l(g)
SemI-V"" 0ra8I*8
Add Ex1r8c181118.
~
6SA
108-6-2
65-85-0
95-48-7
108-38-4
phenol
benzoic ecld
2-methyl pItenoI
4-m.thyt ""'nol
N/A
N/A
N/A
NlA
52 - 201 (3.
1,44 - ~.220 C5.
268 - 1.188 (2)
42 - 103 CSt
272
CI,
-+
-+
-+
-+
P88tlcld88 Fr8c:tIoft
&OP.
103P
105P
80-57-1
319-85':"7
58-88-1
dieldrin
BHC-I8tI
BHC-oam.... (llnd.n..
NlA
N/A
N/A
1.5 - 3.2 (2)
3.2 CI,
1.2 - 8.3 C3,
..+
-+
-+
Note.:
1.
2.
3.
N""'be,. In p.,...th.... (8) .,. t'" number of pOI It'" ob..",.tlon..
Reported v.lue. .,. th. mlnlmum-m.xlmum C35 - 2.200' contemlnent concentr.tlon nna...
Ent"', m.rked with. dI.h C-) Indlc.t. non. wer. found .bov. d8t8CIlon limit. 'or th.t medium.
the t.bI.. In Appendix C.
C.. Indlc.t.. only on. ..mpllng round. R..ul.. I . Included In thl. t.bIe.
NlA - Not .nalyzed for.
For d.t8Cllon limit. .t th. p.rtlcullr ob..rvltlons, s..
4.
5.
.~ '" .
-------
APPENDIX C - REMEDIAL ALTERNATIVE COST [).A.TA
:.
-------
Taple C-l
REMEDIAL ACTION ALTERNATIVE
COST SUMMARY
BEACON HEIGHTS lANDFIll SITE
Initial Annual Present Worth Total
Alternative Capital Cost O&M* Costs O&M Costs Project Gust
1 S100,4S9,000 S 9,000/90 , 000.. S 34,000/798,000 S100,493,OOO/101,2~/,OOO
2 51,201,000 4,751,000 12,854,000 (ill, (J!)!J .ono
3 15,439,000 182,000/254,000 1,716,000/2,394,000 17 , 155,000/1' , n:n , nnn
4 38,240,000 191 ,000/263 , 000 1,800,000/2,479,000 40,040,onO/010.1IH,(JOII
5 38,246,000 191 ,000/263 , 000 1,800,000/2,479,000 40,046,000/010, I:'!,. noo
6 6,175,000 223,000/295,000 2,102,000/2,781,000 8,277 ,OOOIn, 9!,h. noo
7 0 0 0 (J
8 272,000 180,000 1,697,000 1 . !11i!J , 000
9 1,958,000 53,000 500,000 '} . 01 !,II, n(Jo
10 370,000 53,000 500,000 II IU . olin
11 1,544,000 216,000 2,036,000 J . !iBO . ()(IO
I
12 197,000
13 272,000 77,000 726,000 !J~'" . (1110
.
-
.~ f:.
Operation and maintenance
-------
Table C- 2
REMEDIAL ACTIc-X'J ALTERNATIVES
Beacon ~ights Landfill
I
ALTERNATIVE CCMPONENTS COSTING
Capital I O&M* I 1btal**
-
1.
Offsite disposal Offsite disposal of all 100,459,000 9,000 100,493,000
contaminated material in
a RCM approved 1andf ill
, (700,000 cubic ya.rds)
-
2.
Onsite Incineration of all 51,201,000 4,751,000 64,055,000
incineration contaminated material in
( RCRA) four portable
incinerators. Return of
ash to a on-site RCRA
landf ill.
-
3.
-
RCRA Cap, Construction of a 30 acre 15,439,000 182,000 17,155,000
leachate collect multi"'1t'ledia cap
and treat to including gas venting and
NPDES standards stormwater controls. 254,000 17,833,000
Also, installation of (with monitoring)
leachate collection and
treatment system.
4.
Onsi te RCRA Placement of all 38,240,000 191,000 40,040,000
landfill. contaminated material
leachate collect in an on-site RCRA
and treat to approved, double lined
NPDES Standards landfill, with leachate
collection and treatment
"
,.
.
-
* annual operations and maintenance cost (excluding well monitoriWJ costs)
** total present '«)rth cost including 0 & M costs (30 year)
-------
Table C- 2
ALTl:."RNATlVES
cntPONENTS
COSTING
Capi tal I 0 & M* I Total **
I
5.
Onsi te RCRA Placement of all 38,246,000 191,000 40,046,000
landfill. contaminated material
Leachate collect in an on-site RCRA I
and treat to approved, double lined
Drinkin;;J Water landfill, with leachate
Standards. collection and treatment
6.
Soil Cover, TWo feet of soil cover, 6,175,000 223,000 8,277,000
Leachate 6 inches of topsoil
Collection and placed over entire site,
treatment to Leachate collection .
NPDES Standards system and treatment to
NPDES discharge
standards
- ~
7.
No Action Strict no action 0 0 0
I
8. I
LUnited No Action Sampling, analysis and 272,000 180,000 I 1,969,000
with Lon;;J Term review of groundwater, I I
Monitorin;;J surface water 400 other
media sanples for a
30 year period.
9.
Public Water Extend Water Main up 1,958;000 53,000 2,458,000
Supply to an Skokorat A:>ad to next
Extended Area municipal supply, up
Blackberry Hill A:>ad
to dertOJraphic limits
(54 total hates)
..- r
.
:.
-------
Table C-2
ALTERNATIVE
ad (18 hares)
-
11.
Grounwater Installation of 70 1,544,000 216,000 3,580,000
Extraction and extraction wells in
Treatment to bedrock, PI.IT\P and treat
Drinking Water water for a 30 year
Standards period.
12.
Additional Gather additional data 197,000 - -
Groundwater on nature and extent
Hydrogeolog ic of contaminant migration
Investigation in the bedrock,
recommend effective
groundwater treatment
schemes.
13.
-
Limi ted No-Action Establish a network of 272,000 77,000 998,000
with I.Dng Term m:>riitoring 'NeUS to
Monitoring track the groundwater
cont.aminat ion. If it
poses s threat to public
health, 'Nelfare, or the
environment in the
. future, additional
actions will be taken
. ,
.
:.
.
-.~. .. ~.~. ,~.
-------
Table C-3.
COST SUMMARY FOR
LEACHATE COllECTION AND TREATMENT OPTIONS
BEACON HEIGHTS lANDFill SITE
Initial Total.
Capital Annual(1) Present Worth(2) Project
Alternative/Option Cost O&M Cost O&M Cost Cost
Alternative 3: RCRA Cap with leechate $15,439,000 $182,000 $1,716,000 $17. 155,OllO
Collection end Treetment
(30 year 0 & M)
Option A: RCRA Cap without Leachate 14.326,000 92.000 867,000 15, 193. ()(JfI
Collection end Treetment
Option B: RCRA Cap with use of POTW 15.216.000 360.000 3,394,000 18,610,O()()
(30 years leachate treatment) (275,000)(3) (2,592.000) (17,BOR,OOO)
Option B: RCRA Cap with Use Of POTW 15,216,000 360,000 1,883,000 17,099.0(11)
(5' years leachate treatment) (275.000) (1.561,000) (16,177, (IOU)
Option C: RCRA Cap with Use of Mobile Units 15.238.000 172.000 1.171.000 16,409.0UII
(5 years leachate treatment)
(1)
(2)
(3)
O&M Costs Include site maintenance at $23,000 per year and sampling and analysis of monitoring wells (no residolll".1
wells) at $69.000 per year, a tote I of $92.000.
Includes 30 years of O&M for site maintenance and monitoring for all present worth calculations.
These costs as~ume leachate. treatment for $.06 per gallon. an average cost quoted by the treatment plant.
-------
APPENDIX D - CXJfttUNITY RELAT:ONS RESPONSIVENESS SUMMARY
.
.
,.
-------
COMMUNITY RELATIONS RESPONSIVENESS SUMMARY
BEACON HEIGHTS SITE
BEACON FALLS, CONNECTICUT
Introduction
This responsiveness summary for the Beacon Heights Site documents for the public
record concerns and issues raised during remedial planning, comments raised
during the comment period on the feasibility study, and the responses of EPA to
the-se concerns.
Concerns Raised Prior to the Feasibility Study CQ88ent Period
The predominant concern expressed by many members of the community wa.s the
immediate need for a new water supply for affected residents. Citize~s
expressed fear that their drinking wells might be contaminated leading to
adverse health effects. Cleaning up the contamination at the site was viewed
by many residents as a secondary activity, to take place after a new water
supply was operating. Residents of two houses on Skokorat Road, where wel1s
were found to be contaminated, expressed concern about the co"tami"ated water
but were more concerned about why they were not notified sooner that their
water was unsafe to drink.
In response to concerns raised by some residents over prompt notification, EPA
made certain that all new information (i.e.. verified well test results) was
immediately channelled through the State Health Department and the First
Selectman of Beacon Falls, Leonard D'Amico.
Residents and local officials also expressed concern over the instability of
the landfill due to its history of accepting unknown quantities of industrial
waste. Several members of the community wanted to know what materials were in
the landfill and how great a threat they posed.
In order to keep residents informed about the site, EPA set up an information
repository at the Beacon Falls Town Hall and Public library. EPA also
informed concerned citizens and officials of tt:e many dangers involved in
direct onsite testing of the landfill because of the toxic nature of some of
the chemicals buried in the landfill.
Community Relations Activities Conducted by EPA
Community relations activities were conducted by EPA to elicit citizen input
and address concerns over remedial actions. Activities that took place
include the following:
o
A Community Relations Plan was (CRP) prepared by EPA based on inter-
views with town residents and officials in September, 1983.
EPA briefed local officials by phone and in-person. as new informa-
tion concerning the Beacon Heights site became available.
o
o
A public meeting was held on March 26, 1984 by EPA at Laurel Ledge
School in Beacon Falls to explain the work plan for the remedial
investigation (RI) and the feasibility study (FS).
-------
o
An information repository was established in the Beacon Falls Town
'Hall-and Public Library containing press releases, Remedial Actior
Master Plan (RAMP) fact sheets, engineering reports,. RIfFS, ant"
public hearing transcript.
Press releases were issued, including results of the RI on April 25,
1985 and results of the FS on May 20, 1985.
o
o
A Feasibility Study was released on May 20, 1985 for public review
and comment.
.0
A second informational public meeting was held on June 5, 1985 by
EPA at Laurel Ledge School in Beacon Falls to explain the results of
the remedial investigation and feasibility study.
o
A public hearing was held on June 11, 1985 by EPA at Laurel Ledge
School in Beacon Fall s to record comments and suggest ions on the
feasibility study for the Beacon Heights Landfill.
The public comment period closed on June 14, 1985.
o
Concerns Raised During the Comment Period
The publ ic comment period began on May 20, 1985 with the release of the
feasibility study report. During the cOl1lTlent period, a public meeting was
held on June 5, 1985, attended by approximately 30 people, to present results
of the RIfFS and to answer questions from the public concerning the cleanur
alternatives. On June 11, 1985 a formal public hearing was held to record
cOl1lTlents on the cleanup alternatives for the Beacon Heights Landfill. Nine
comments from public officials and local citizens were recorded at the
hearing. These comments along with written cOl1lTlents received by EPA and
concerns generated at the public meeting are summarized in the following
section. In addition, the following section provides a summary of all
Potentially Responsible Party (PRP) comments received by EPA. .
-------
1.
2.
Index to Community Comments
Onsite Incineration
Providing New Water Supply
3.
Notification
4.- landfill Cleanup
5. Groundwater Cleanup
6. Monitoring
7. Offsite Contamination
-------
COMMUNITY CONCERN
RESPONSE.
1.
Providing New Water Supply
The overriding request of many citizens
was to provide a new water supply first,
clean up the site later. Getting clean
water to affected and potentially affected
citizens is their highest priority.
EPA intends to "fast track" the design and
construction of the municipal water extension
separately from the site closure design and
construction.
Several citizens stated that Alternative 9
is the only alternative that will ensure
that all residents are drinking uncon-
taminated water. .
To ensure protection of public health and to
account for uncertainties which exist in the
understanding of groundwater contamination,
the waterline extension will encompass all
affected and potentially affected areas with
-------
~
COMMUNITY CONCERN
RESPONSE
.
2.
Onsite Incineration
A major concern expressed by several citi-
zens was that Altern~tive 2, Onsite Incin-
eration, could lead to wastes from other
areas being brought onsite for incinera-
tion purposes and the incinerator becoming
a regional incinerator. These citizens
were opposed to other wastes being treated
ons ite.
Onsite incineration was eliminated from con-
sideration during the detailed evaluatioh ,of
alternatives based on cost considerations and
time required for implementation. However.
the intent of Atternative 2 was to process
only the Beacon Heights wastes and not to
-------
COMMUNITY CONCERN
RESPONSf
3.
Notification
Several residents felt that they were not
promptly and properly notified that thei r
wells were contaminated. One resident
stated that he read of the contamination
in the newspaper prior to being personally
notified. Residents questioned why they
could not be warned immediately if the
water may be contami nated and unsafe to
drink, instead of waiting for complete
verification and validation of the
results.
Communication to residents is through the
State Department of Health Services,' the
Agency charged with protecting the health of
Connecticut residents. Analytical results
must be validated to ensure their legitimacy
prior to release. Since the contaminants
found present a ri sk from 10n9 term consump-
tion, the additional 3-4 weeks to validate
prel imi nary resul ts were warranted to ensure
that the contamination was real and not the
result of laboratory or sampling problems.
-------
COMMUNITY CONCERN
RESPONSE-
4.
landfill Cleanup
One citizen was concerned that contamina-
tion at the site cannot really be con-
trolled unless the entire site is exca-
vated and the contents of the landfill are
disposed of offsite.
Site contamination can be controlled without
complete excavationOf all wastes. Due to
the vol ume of wastes at the sHe (much of
which is municipal waste) complete excavation
and offsite disposal would be a very expen-
sive alternative to implement. It is ques-
tionable if sufficient landfill space can be
made available to implement this action
within a reasonable time period. In addition
to being prohibitively expensive, offsite
disposal would cause major short term impacts
due to heavy truck traffic, air emissions
during excavation, and the length of time
required for implementation.
Futhermore, the use of a RCRA-type cap wi 11
create an impermeabl e barrier over the land-
fill and will minimize the volume of leachate
that is generated from the site. A leachate
collection system will control contamination
emanating from the site, and when coupled
with the provision of an alternate water
supply, this system will effectively
-------
COMMUNITY CONCERN
RESPONSE
.
5.
Groundwater Cleanup
One citizen felt that Alternative 11 is
the most environmentally sound method to
ensure against any future and long-range
migration of contaminated groundwater to
areas not served by a public water source.
The technical difficulties in implementing
this alternative are several owing to' ~he
nature of the fractured bedrock and depth of
contamination. Flow in the bedrock is
through an extensive fracture system that
mus t be tota 11 y intercepted to extract the
groundwater.
When the municipal water line is extended,
the health threat resulting from groundwater
contamination will be removed. Additional
monitoring will be done to determine if
groundwater contamination is migrating
-------
COMMUNITY CONCERN
R[SPONS~
6.
Monitoring
A citizen was, concerned whether residents
can be confident that wastes won' t seep
out after the monitoring program is com-
pleted.
A monitoring program of 30 years is proposed.
It is expected that this is a sufficiently
long period to evaluate the steady-state
condit ions that shoul d develop fo11owi ng the
implementation of remedial actions. After
the sHe is capped the leachate genera t ion
should reduce quickly. Within a t'eriod of
several years the rate may reduce further as
the wastes within the landfill are dewatered.
The resul t i ng effect on the groundwater to
reduce contaminant concentrations will lag
somewhat, owing to the time it takes for flow
to travel through the aquifer, but woul d be
detected within the 30 year period.
At the end of 30 years, the levels of con-
taminat ion wi 11 be reeval uated to determine
-------
C_UNITY CONCERN
RESPONSE-
7.
Off site Contamination
Several citizens expressed concern that
there is no way to tell whether wells just
outside the immediate contamination area
might be affected through further ground-
water seepage.
The feasibility study states that con-
tamination was detected upgradient of the
site. More testing should be done to
explore the possibility of offsite sources
of contamination. Citizens were concerned
why wells were not being tested upgradient
of the si tee
Results of the remedial investigation, (RI)
report indicate that some low level contam-
ination was found in wells upgradient from
the site. These wells were very close to the
landfill and may have been contaminated by a
mounding effect from the landfill, or were
not truly upgradient wells (MW-3).
Contaminant levels were very low and may have
been a result of laboratory or sampling
equipment. Although the results of the study
do not indicate a major source of upgradient
contamination, a continued monitorin~ program
for the site would include the installation
of additional upgradient monitoring wells and
deep bedrock wells. Monitoring wells will be
placed in the area to the northwest of the
site where the public water supply is not
available (Cook lane).
More i nfornation should be gathered on the
-------
CClltUIUTY COKER"
RESPOIISE.
8.
Health Risks
A citizen felt that the impact on resi-
dents in the affected area cannot be
measured in numbers alone. Mental anguish
is difficult to measure. Equally dif-
ficult to assess is the impact on property
values. These two factors can be allevi-
ated by bringing public water to the
effected and extended area.
A chemical analysis must be completed on the
municipal water supply to actually compare it
with the current well water. Municipal water
suppl ies are subject to qual i ty cri teria and
monitoring. .
Several citizens commented about the
potential health risk of drinking contam-
inated water.
A citizen was concerned over who sets the
standards for allowable hazardous concen-
trations of chemical s? Why are the State
and Federal standards di fferent? Why are
the standards always changing?
The risks associated with ingesti ng the well
water were identified in the feasibility study.
Only 2 samples from residences along Skokorat
Road were identified as presently contai ni n9
contaminants above levels that are considered
safe. Those residents whose wells were wn-
tami nated with benzene were advi sed to di s-
continue use of their water supply for
ingestion. Contaminants found in other wells
were not determined to be above safe level s
from an acute (short term) or chroni c (1 on9
term) exposure scenario at the present time.
Residents with health problems were advised
at the public meetings to discuss these
problems with the Connecticut Department of
Health Services and/or their physicians.
The Federal government sets standards for
pollutants in various media (e.g.. air. sur-
face water. drinking water) through its pro-
cess of issuing regulations. A state may
adopt these standards or may set more
stringent standards due to differences in
philosophy, consideration of special state
-------
COMMUNITY CONCERN
RESPONSE.
Health Risks (continued)
8.
Regulatory standards do not exist for, many
hazardous chemicals. In the absence of regu-
lations, both Federal and State governments
may issue guidel ines as an interim control
measure based on existing information on
chemical toxicity, persistence, likelihood of
exposure, analytical detection limits and
other factors. Standard setting is an evalu-
ationary process because the understanding of
chemicals and their effects on human health
-------
Index to State Comments
1.
2.
Providing New Water Supply
Onsite Incineration
3.
Interpreting and Conveying Data
4 '.-
Landfill Cleanup
5.
6.
Access
-------
STATE CONCERN
RESPONSE,
1.
Providing New Water Supply
Several officials representing the State
expressed the opinion that the first
responsibility is to provide a safe public
water supply as quickly as possible.
EPA Agrees that provision of a safe water
supply should take preference over la'ndfi11
closure and intends to phase in this aspect
of the cleanup of accomplish it as rapidly dS
possible. EPA also supports the extended
waterline, Alternative 9.
The State supports Alternative 9 because
of the potential for contamination of
private wells within downgradient prox-
imity of the land fill.
-------
STATE CONCERN
RESPONSE.
2.
I nc i nera t i on
Similar to the concerns expressed by the
citizens, the State opposes onsite incin-
eration. The pote'ntial for further envi-
ronmental damage during the burning
process and the possibility that the area
can be used in the future to incinerate
hazardous waste brought in from other
sources is too great for thi s plan to be
considered.
Incineration has been ruled out on the. basis
of cost and time for impl ementa t ion. . thus
-------
STATE CONCERN
RESPONSE,
3.
Interpreting and Conveying Data
The State thinks that EPA should make sure
proper resources are available to inter-
pret data received at the dump site. Thi s
data needs to be quickly, accurately and
clearly passed on to the communi ty.
Regardless of which solution is selected,
a system should be available to feed back
useful information to the residents.
EPA will disseminate information to the
affected community through its comm'unity
relations program of formal and informal
meetings, press releases, fact sheets, and
-------
STATE CONCERN
RESPONSE,
4.
landfil1 Cleanup
The State expressed the concern that
remedial measures designed to divert
groundwater and surface water will be
ineffective. Therefore. the contents of
the Betkoski Dump should be excavated and
placed atop the main landfi 11. The land-
fill should then be regraded and covered
with an impermeable cap.
EPA agrees that diversion of groundwater and
surface waters around the Betkoski Dump. area
is not feasible and that these wastes should
be excavated and consolidated with the larger
landfill. This wil1 also make possible a
perimeter leachate collection system which
encompasses all waste deposits. The contents
of the Betkoski Dump wi 11 be placed atop the
main landfill prior to placement of any cap.
Alternative 6. placement of a soil cover. was
-------
STATE CONCERN
RESPONS~
5.
Access
The State thi nks that access to the 1 and-
fill should be restricted. Children and
other unauthorized entrants must be pre-
vented from going onsite.
Access to t.he landfill will be restricted to
prevent contact with materials on site and to
prevent vandalism of site facilities (treat-
ment facilities. site cap. etc.) following
implementation of remedial actions. The site
area and additional working areas required
-------
STATE COICERN
RESPOIS@
6.
Monitoring
The State commented that there needs to be
a monitoring system in place for those
residents who are not connected to a public
water supply and are potentially at risk.
Future studies and monitoring of offsite
groundwater migration should be con-
ducted.
The extension of the public water supply will
include the area identi fied as the extended
area in the FS report. This limit includes
areas that are currently not affected by con-
tamination above safe levels but could be
affected in the future. Extension of the
waterline includes provisions for install a- -
tion of monitoring wells in areas outside the
study area to the northwest of the site that
currently do not have public water supply
available. These areas are primarily along
Cook lane. The public water line will not he
extended to these areas initially because no.
data is available to indicate they are con-
taminated and because concentrations should be
diluted at this distance. which is approxi-
-------
Index to PRP Comments
1. Offsite Disposal (pp. 5-11)*
2. Onsite Incineration (pp. 12-15)*
3. Landfill Adjacent to Site (pp. 15-20)*
4. RCRA Cap With Leachate Collection and Treatment (pp. 20-21)*
5.. Soil Cover and Leachate Collection and Treatment (pp. 22-28)*
6. Public Water Supply Extension (pp. 28-29)*
7. "Long-Term Monitoring (pp. 29-30)*
8. Groundwater Treatment (pp. 30-31)*
*For the full text of comments refer to the Written Comments of: The Beacon
Heights Generators Committee, prepared by the Beacon Heights Generators
-------
PRP CONCERN
RES POlIS I!
1.
Offsite O;sposal
Does not meet Federal requirements:
o Transportation from one CERCLA site to
another is not consistent with intent
of CERClA.
o landfilling of wastes is not consistent
with requirements of and policy under-
lying the Hazardous and Solid Waste
Amendments of 1984 or EPA's Policy
under RCRA.
CERCLA prohi bits the use of offs ite di,sposa 1
remedies unless it is cost effective. it is
necessary to protect public health. welfare.
or the envi ronment. or it creates new di s-
posal capacity. The Beacon Heights situation
dues not meet these statutory requirements
and offsite disposal is not the selected
remedy.
Offsite disposal is technically imprac-
tical and will cause adverse environmental
impacts:
o No hazardous waste landfills located in
Connecticut.
o limited space in New York and New York
has strict limits on total organics in
waste.
o Other states ava U abl e (Ohi o. Indiana.
and South Carolina) but disposal will
take much longer. cost much more and be
a greater safety hazard.
o Excavation and long-distance transport
would take much longer than projected.
o Would result in uncontrolled releases
when site is uncovered for excavation.
o Contact of storrnwa ter with exposed
wastes wi 11 increase duri n9 excavation.
forming leachate and possible ground-
water contamination.
If the wastes were to be exhumed. it is pos-
sible that certain wastes would be encoun-
tered which are now or w111 be prohi bited
from land disposal in the present form.
Rehandling to first treat or stabilize the
wastes would be required prior to land-
filling: this cannot be predicted based on
existing information.
Many of the hazards associated with excava-
tion of the wastes and offsite disposal were
considered during the preparation of the
feasibility study and were implied in the FS
report. The large volume of wastes at the
Beacon Heights landfill Site make any offsite
disposal techno)ogy a limited option based on
the risks involved with exposing the wastes.
hazards of long-distance transport. and the
potential lack of available landfill space.
this alternative does have serious contraints
as identified in the FS. The costs for
implementing this alternative are excessive
-------
PRP CONCERN
RESPONSE.
1.
Offsite Disposal (continued)
o Potential risks excavating hazardous
waste unknown.
o Cannot move all wastes by bulk handling
method as described in FS.
o Drums will be uncovered that need test-
ing. transporting and disposal.
o Pooled or ponded free liquids will be
encountered--cannot be placed in a
landfill and wHl require offsite
processing and treatment.
o Costs are underestimated by $20-$30
million.
through placing a RCRA cap. Evaluati9n of
this alternative was included to comply with
EPA guidance to evaluate offsite disposal,
storage. or destruction technologies. It has
-------
PRP CONCERN
RESPONS£
2.
Onsite Incineration
Institutional issues should be considered
and may pose significant drawbacks to 0-
nsite incineration:
This alternative was screened out as a result
,
of costs, and public opinion against .this
a 1 ternat he. *
o Permits must be obtained from Connect-
icut Department of Environmental Pro-
tection (CDEP).
o Formal siting application must be sub-
mitted to state's siting council. The
council has not sited a new facility to
date.
o Construction and testing phase for
incinerator may take 3-5 years.
o Disposal of incinerated residue in new
RCRA 1 andfi 11 is not encouraged under
RCRA.
o New land must be purchased to locate
new 1 andfi 11 .
o FS does not address new landfill in
terms of ownership, financial assur-
ance, property acquisition and buffer
zones.
As outlined under Alternative 1, offsite
d i sposa 1, many of the poi nts i dent ifi ed by
the PRPs were considered during preparation
of the feas i bil i ty study and were addressed
in the report, although not elaborately.
This alternative was included to comply with
the FS guidance documents to identify
alternatives that attain all applicable or
relevant Federal publ ic heal th or
environmental standards, guidances, or
advisories and to evaluate an alternative
that provides destruction of the waste
materials.
The Connecticut Water Quality standards do
allow for variances on a case by case basis.
EPA recognizes that such a variance woul d be
requi red for any di scharge to Hockanum Brook
or its tributaries.
Technical impracticalities for landfill
di scussed under offsite 1 andfill al so
apply here (i.e., exposure risks, leachate
formation). Other technical problems also
exist:
waste-
*NB. "CERCLA compliance with other
environmental laws" policy states that
Superfund remedies need only comply with the
technical requirements of federal statutes.
Neither state nor federal permi ts need III'
obtained.
o FS does not address adverse
from emissions from incinerator.
o Need for scrubber and scrubber
water disposal is not discussed.
-------
PRP CONCERN
RESPONSE.
2.
Onsite Incineration (continued)
o Discharge of even highly treated 1each-
a te from 1 andfi 11 into Hockanum Brook
is prohibited. by Connecticut Water
-------
PRP CONCERN
RESPOIISE
3.
landfill Adjacent to Site
Construction of a RCRA landfill adjacent
to site is not technically practical to
implement and presents significant adverse
environmental, health, and safety risks:
o High health risk from exposure to wa~te
during excavation.
o High cost but doesn't provide greater
protection to public health and the
environment than Alternative 3 or 6.
o Similar health and safety risks as
those presented under offsite disposal.
o FS overestimated level of protection
provided by leachate treatment system
under Alternative 5. It will not meet
primary drinking water standards for
chloride or nitrate nitrogen.
o Discharge to Hockanum Brook is pro-
hibited.
o Onsite RCRA landfill not consistent
with Policy of Hazardous and Solid
Waste Amendments of 1984 and EPA Policy
under RCRA which discourages landfill-
ing of hazardous waste.
o Prohibition against siting landfills in
Connecticut.
o Must purchase property.
o Given a reasonable estimate of con-
struction activity and traffic, would
take 2 years to construct landfill
bottom, 4 years to construct cap, and
3-4 years to move waste. This lengthy
Development of an onsite landfilling alterna-
tive was used to satisfy many of the require-
ments of the FS guidance process. Several of
the comments from the PRPs were di scussed in
the feasibility study and are valid concerns
associated with implementation of this alter-
native. These concerns include the risks
created by exposure of the wastes, the time
period required for construction, and neces-
sary purchase of additional property.
Although landfilling of hazardous wastes may
be di scouraged under RCRA, the focus of the
onsite RCRA landfill alternatives was to pro-
vide an onsite containment measure in con-
trast to onsite destruction technologies
(incineration) that are more expensive and
have adverse environmental impacts.
By containing the wastes within a fully lined
and capped system where all leachate can be
collected and managed, this alternative would
provide greater protection to the public
health and envi ronment than the cappi ng
Alternatives 3 and 6. However, difficulties
in obtaining property, materials for
construction, and time to implement, do not
warrant the costs for Alternatives 4 and 5
($38 million) versus the appreciable benefits
that can be achieved for the cost of placing
a RCRA cap in' Alternative 3 ($15 million)
since Alternative 3 adequately protects
-------
PRP CONCERN
RESPONSE,
3.
landfill Adjacent to Site (continued)
time greatl y increase envi ronmental and
health risks.
o Estimate on clay is too low. low
permeability clay would cost $25 per
cubic yard in New York. This would
increase costs $1.93 million for both
Alternatives 4 and 5.
o FS fail s to menti on costs of movi ng
free liquids--could add $1 million to
total costs.
o FS does not address excavation and
removal costs for liquid-filled drums.
Based on further discussion with Connec~icut
regulatory agency personnel, it does appear.
that discharge to Hockanum Brook may be
.allowed under its classification as a BIA
stream. Discharge to Class B streams may be
allowed when the treated discharge is an im-
provement over the quality of current dis-
charges and will help to improve the stream
class from B to A. The inplace cost of clay
used in the estimate was approximately $20
per cubic yard, a direct cost prior to the
addition of contingencies. The total cost
for clay is derived from elements listed
under material, labor, and equipment costs.
The extent of free liquids within the wastes
cannot be adequately determined prior to
test i ng and sampl i ng whi ch wi 11 be i nc 1 uded
as part of the design. The additional costs
for excavation and disposal of free liquids
was addressed in the final FS in the
sensitivity cost analysis.
Excavation of the entire landfill contents
would result in increased air emissions of
volatil e organi cs. However, exposure coul d
be controlled by use of proper personnel pro-
tective equipment by the workers, an air
monitoring network to determine periphecy
exposure levels in conjunction with a con-
tingency plan. and a controlled work
-------
PRP CONCERN
RESPONSE,
3.
landfill Adjacent to Site (continued)
The 1984 RCRA Amendments do discourage land-
filling. However, creation of a new lan'dfi1l
ons i te or on adjacent property woul d not be
inconsistent with those Amendments since it
would merely upgrade the already existing
1 andfill .
Purchase of adjacent property for a RCRA
landfill would be the responsibility of the'
State of Connecticut. Current EPA policy on.
feasibility studies does require that land
acquisition costs be included in capital cost
estimates. However, the additional cost
would be relatively insignificant in com-
parison to the $15 million capital cost for
this alternative.
It is unclear if the "prohibition" on new
landfill s would apply to construction of a
RCRA landfill adjacent to the existing Beacon
Heights landfill. Under present EPA policy,
remedial actions do not have to comply with
the procedural and administrative aspects of
other environmental laws, i.e., state siting.
Construct ion of a new landfill woul d be a
lengthy process requiring several years. The
11-12 years estimated by the PRPs neglects
the ability to conduct discrete items
-------
PRP CONCERN
RESPONSE
RCRA Ca~ With Leachate
Co11ectl0n and Treatment
4.
o One year construct ion wou1 d requi re 18
trucks per hour which is not feasible.
o Cap would realistically take 4 years to
construct.
o Prohibition against
Hockanum Brook. '
o Clay costs are underestimated by $2
mi 11 ion.
o Leachate collection system cost is
inconsistent with the estimate in
Alternative 6.
o Overall costs underestimated--not a
cost-effective remedy.
discharge
to
,
The placement of a RCRA-approved cap would
provide a cost-effective alternative for
minimizing the generation of leachate from
the 1 andfi 11 and subsequent contami nat i on of
the groundwater. The purpose of a RCRA cap
is to place an impermeable layer that mini-
mizes the degree of infiltration. The con-
cept of a RCRA-approved cap allows for va r-
iability in the design and use of materials
to create thi s impermeab1 e layer. The pro-
posed design (reduced from 8 feet to 6 feet
thick) used both clay and synthetic membrane
layers to illustrate the cost and design of u
cap that could provide the greatest reduction
of infiltration. Additional layers include d
gas flow zone to vent methane gas from the
1 andfi 11 and surface dra i nage 1 ayers to
di rect runoff from the 1 andfi 11 . A 1 a rge
volume of material, approximately 450,000
cubic yards, would be required at the site
for construction of a cap and liner. The
increase in truck traffic may require upgrad-
ing of the local roads. The time required to
obtain and transport the construction mater-
ials to the site may be several years.
Eight-foot RCRA cap is technically imprac-
tical:
The cost for the use of clay in the cap was
properly estimated and is derived from cost
elements listed under materials, labor, and
equi pment. Thi s cost accounts for haul i ng
-------
PRP CONCERN
RESPONSE
RCRA Cap With leachate
Collection and Treatment (continued)
4.
The cost for leachate collection syste's was
re-evaluated in the final FS and revised.
The cost is essentially the same for both
capping alternatives. Discharge of treated
leachage to Hockanum Brook may be allowed in
thi s case when the treated discharge will be
improved over the quality of current
discharge and will help to improve the
qual ity of the stream from Class B to
-------
PRP CONCERN
RESPONSE'
5.
Soil Cover and leachate Collection and Treatment
PRPs are in favor of Alternative 6 for the
following reasons:
A soil cover will reduce infiltration. but
wi 11 not mi nimi ze it. The 1 ack of a bottom
line and the inability to extract
contaminated ground-water from the fractured
bedrock system support the need for a more
impermeable cover than the soil cover
described in Alternative 6.
o Alternative 6 meets all CERClA requi re-
ments.
o Does not present technical impractical-
ities and adverse environmental health
and safety impacts associated with
Alternatives 1-5.
o less cost but just as much protection.
o No risk of exposure as under excavation
alternatives.
o Can be implemented in 1-2 years.
o Should discharge leachate to pub1ic1y-
owned treatment works (POTW).
Several modifications to the soil capping
proposal would further increae the level
of protection. In addition the FS con-
tains an erroneous figure for the estimate
of leachate flow. It does not take into
account any reduction in leachate flow
resulting from the soil cap proposed under
A1 ternative 6.
The Beacon Falls POTW is not designed to
treat industrial wastes and is currently
experiencing operating problems due to
infiltration/inflow. .
The FS did account for a decrease in the
leachate flows as a result of placing the
soi 1 cover. Based on water ba lance
calculations it was determined that this
a1 ternative may decrease the amount of
leachate, but not to the level created by
placement of a RCRA type cap. Based on
variations in the calculation methods, the
volume of leachate generation under this
alternative may vary from 20,000 to 50,000
gallons per day. Although this alternative
requires less material and can be implemented
more quickly, it does not provide the same
level of protection that would be provided by
placing some variation of a RCRA cap that
c rea tes a more i mpermea b 1 e ba rri er . It does
not meet CERCLA requirement since it does not
provide "adequate source control" as required
-------
c
PRP COIICERII
RESPOIISE .
6.
Public Water Supply Extension
Technical basis for Alternative 9 is not
clear from FS. Outer 1 imit of potential
downgradient flow of groundwater from site
emcompasses a small er area than that
covered by Alternative 9. Should extend
water line 4,500 linear feet along
Skokorat Road and 3,200 feet along Black-
berry Hill Road. This would encompass the
area that could be affected.
. The 1 imits of downgradient flow cannot be
fully characterized based on the nature .of
the fractured bedrock. Groundwater
contamination has been identified along both
Blackberry Hill and Skokorat Roads. Benzene
levels in two of these wells have exceeded
State and Federal guidel i nes and the other
wells are clearly threatened.
The limits of waterline extension proposed by
the PRP's are based solely on surface
topographic conditions which totally neglect
the possible influence of pumping wells on
local groundwater flow system boundaries and
flow directions in fractured bedrock.
Extension of the waterline along Skokorat Road
to the next municipal water supply and along
Blackberry Hill Road to the limit of
residential development provides the only
effective protection of public health and
welfare to residents in the vicinity of the
-------
PRP CONCERN
RESPOIISE,
7.
long-Term Monitoring
Monitoring for a full spectrum of organic
and inorganic constituents is unnecessary.
It is sufficient to monitor for volatile
organics.
Th~ data gathered in the remedial investigation
indicate that compounds in the ex:rac'table
fractions have also migrated offsite in
addition to those in the volatile fraction.
Furthermore, it is entirely possible that other
fractions and/or heavy metals may migrate in
the future due to chemical and physical
processes occurring within the landfill. This
cannot be predi cted and, therefore, supports
-------
o -
PRP CUICERN
RESPOIISE .
8.
Groundwater Treatment
Further groundwater treatment at the si te
is not technically feasible. Treated
water cannot be discharged to Hockanum
Brook or accommodated by the Beacon Fall s
publicly-owned treatment works (POTW).
EPA is of the opinion that extraction of
contaminated groundwater in deep bed~ock
fractures is impractical due to the
impossibility of intercepting all fractures
carrying contaminated groundwater. There-
fore, the feasibility of treating the collected
-------
. --- . .
J
Alternatives Not Evaluated in FS
~
There were no new remedial alternatives proposed by citizens, PRPs or thl
State that were not evaluated in the feasibility study.
Remaining Concerns
During remedial design and construction, community concern may be generated
over noise from trucks entering and leaving the site. To help alleviate this
preblem, idling trucks will be parked in an area away from houses and people.
The reconmended alternative includes the installation of a new water 1 ine.
This may require some blasting of bedrock, and measures will be taken to keep
disturbance to nearby residents at a minimum. In addition, local access loads
on Blackberry Hill will be upgraded to minimize damage and improve driving and
-------
# Q
.
.
ENFORCDtENT cnJFlOO'n'IAL
..
APPDmIXE - ENFORCEMENT ANALYSIS
.
-------
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APPENDIX F - CONNECTICUT COST SHARE LETTER
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-------
ST A TE OF CONNECTICUT
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