United States
Environmental Protection
Agency
Office of
Emergency and
Remedial Response
EPA/ROD/R01 -89/044
September 1989
&EPA
Superfund
Record of Decision:
South Municipal W?'ter Supply
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50272-101
REPORT DOCUMENTATION \'. REPORTNO. r 2-
PAGE EPA/ROD/ROl-89/044
3. Reclpient'a Acceaalon No.
4. TIlle and SubdUe
SUPERFUND RECORD OF DECISION
'outh Municipal Water Supply
iirst Remedial Action
7. Author(a)
s. Report Date
09/27/89
Well, NH
8.
8. Perfonnlng Organindon Rept. No.
9. Perfonnlng Orgalnizadon Nama and Add....
10. Pl'0jec1/Ta8klWork Unit No.
11. Contract(C) or Gr. nt(G) No.
(C)
(G)
12- Sponsoring Organization Name and Addraaa
U.S. Environmental Protection
401 M Street, S.W.
washington, D.C. 20460
13. Typo 01 Report & ,ariod Covered
Agency
800/000
14.
15. Supplementary Notea
16. Abstract (Limit: 200 worda)
The 250-acre South Municipal Water Supply Well site is approximately two miles south
of the Town of Peterborough, in Hillsborough County, New Hampshire. The site includes
the Contoocook River, the Noone Pond System, and a wetlands area. Also on the site
are the New Hampshire Ball Bearings Incorporated (NHBB) manufacturing facility,
-~veral commercial establishments, and several apartments. Land use in the vicinity
: the site is rural and undeveloped. Ground water flow beneath the site is generally
eastward from the NHBB property towards the South Municipal Well. The town of
Peterborough discontinued use of the South Well in May 1983 after the State
discovered.,VOC contamination in water samples taken from the well. Subsequent
investigations revealed that'~ plume of contaminated ground water extended from under
the NHBB property to the vicinity of the South Well. VOC contamination was also
detected in soil on the NHBB property, and wetlands sediment was found to be
contaminated with PCBs, metals, and PAHs. Investigations attributed the contamination
to in-house chemical releases that were subsequently wa5hed out through floor drains
or slop sinks to out falls, or washed out through facility doors. Exterior releases
contributed to contamination at the site through the draining of a truck-mounted waste
solvent tank. The primary contaminants of concern affecting the soil and ground water
::Iro "('I('e: i nr I1ri'nl'T P('P, '1'(,F. ::Inri t-nlllono. t-ho r.rim::lru (~oo Jl.t-t-::I,...hori ~hoot-)
17. Document Analyaia .. Descriptors
Record of Decision - South Municipal Water Supply Well, NH
First Remedial Action
Contaminated Media: soil, sediment, gw
Key Contaminants: VOCs (PCE, TCE, toluene), other organics (PCBs, PAHs), metals
b. Identifiers/Open-ended Torme
c. COSA 11 Reid/Group
111. A vailabiUty Statement
18. Secuity CI... (Thia Report)
None
211. Security CIa.. (Thia Page)
Nnnp
21. No. 01 Pagea
123
I
22. Price
(See ANSI-Z39.19)
See Instrucuons on ReverM
ORM 272 (4-77)
(Formerty NTIS-35)
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EPA/ROD/ROl-89/044
South Municipal Water Supply Well, NH
First Remedial Action
16.
Abstract (continued)
contaminants of concern affecting the sediment are organics inclvding PCBs and PAHs, and
metals.
The selected remedial. action for this site includes ground wate'. pumping from the highly
contaminated NHBB area plume and treatment using a phase separat .on settlement
tank/pretreatment system, air stripping, carbon columns for air ;mission control, and
onsite discharge; ground water pumping from the dilute plume out1ide the NHBB area and
treatment using air stripping and carbon columns and onsite disc1arge; in situ vacuum
extraction of 7,500 cubic yards of contaminated onsite soil; exc~vation and/or dredging
with dewatering of 1,170 cubic yards of wetlands sediment and of':site disposal; wetlands
restoration with clean fill, surface contouring, and revegetation; implementation of
institutional controls restricting ground water use and well inF~allation; and long-term
ground water monitoring. The estimated present worth cost for this remedial action is
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DECLARATION OF RECORD OF DECISION.
Sl'fE NAME AND IDCATION
South Municipal Water Supply Well
Peterborough, New Hampshire
STATEMENT OF PURPOSE
Tlis Decision Document presents the selected remedial action for
tIe South Municipal Water Supply Well Site in Peterborough, New
Hnmpshire, developed in accordance with the Comprehensive
El1vironmental Response, Compensation and liability Act of 1980
(CBRCLA), as amended by the Superfund Amendments and
Reauthorization Act of 1986 (SARA), and to the extent
practicable, the National oil and Hazardous Substances
Contingency Plan (NCP), 40 CFR Part 300 et sea., as amended. The
R~gion I Administrator has been delegated the authority to
approve this Record of Decision.
,
STATEMENT OF BASIS
.
This decision is based on the administrative record which has
been developed in accordance with section 113 (k). of CERCLA and.
which is available for public review at the Peterborough PublicI
Library in Peterborough, New Hampshire and at the Region I Waste
Management Division Records Center in at 90 Canal Street, Boston,
Massachusetts. The attached index identifies the items which
comprise the administrative record upon which the selection of
the remedial action is based.
DESCRIPTION OF THE SELECTED REMEDY
The selected remedy for the South Municipal Water Supply Well
Site includes both source control and management of migration (or
groundwater control) components to obtain a comprehensive remedy.
The source control remedial measures include:
*
In-situ treatment of contaminated soils with a vacuum
extraction system to reduce contaminant levels in the 7500
cubic yards of on-site soils to specified soil target
cleanup levels for volatile organic compounds. Attaining
the soil target cleanup levels will eliminate the potential
migration of contaminants from the soils into the
groundwater at levels exceeding groundwater cleanup target
levels. An activated carbon canister or other pollution
control device will be used to clean the air emissions
before discharge to the atmosphere.
Excavation and/or dredging of sediments to remove
approximately 1170 cubic yards of sediments in the wetlands
contamina~ed with PCBs at levels greater than 1 ppm and with
PAHs at levels greater that 1.1 ppm. The excavated
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- 2 .-
sediments will be dewatered, placed. in containers, and
transported to an off-site, licensed RCRA landfill for
disposal. Achievement of the target sediment cleanup levels
will require the disturbance and temporary loss of areas
classified as wetlands. The wetlands excavation/dredging
will be implemented so a's to avoid or minimize impacts on
and disturbance to the wetland areas. Following the
completion of excavation activities in the wetlands, a
wetlands restoration program will be implemented to return
the affected wetland areas to their original conditions, to
the maximum extent practicable.
,/
The management of migration remedial measures include:
*
. 'Active restoration of the groundwater aquifers contaminated
with volatile organic compounds using air stripping and
,carbon columns for air emission control. This component of
"the remedy will extract and treat groundwater contaminated
. by the Site to specified groundwater target cleanup levels
that will attain drinking water standards.
Groundwater will be extracted with two systems. The New
Hampshire Ball Bearings, Inc. (NHBB) area groundwater
. extraction system will consist of conventional extraction
wells, located in the vicinity of the northeast corner of
the NHBB building and pumping at a total rate of
approximately 200 gpm. The extraction system for
groundwater in the dilute plume area would consist of
groundwater extraction wells, pumping at a rate of
approximately 400 gpm. The di1uteplume extraction wells
will be placed so as to withdraw contaminated groundwater
that has migrated from the NHBB area.
*
*
Contaminated groundwater extracted by these two extraction
systems will be treated on-site by air stripping to reduce
contaminant levels in the treated water to the groundwater
target cleanup levels. Groundwater from the NHBB area will
first pass through a phase separation settlement
tank/pretreatment system where dense nonaqueous phase liquid
(DNAPL) could separate from solution prior to air stripping.
DNAPLs in this tank would be drained off periodically for
recycling or disposal. The remedy is expected to reach
target cleanup levels in the dilute plume area in 7.5 years,
while groundwater in the NHBB area is expected to reach
target cleanup levels in 19 to 32 years. This remedy will
continue to extract and treat groundwa~er in the NHBB area
and the dilute plume area until the cleanup targets are
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- 3 -
Additional measures include long-term environmental monitoring
throughout the implementation of the remedy to ensure its
effectiveness. Also, the remedy includes institutional controls
to restrict use of the South Municipal Water Supply Well and
prevent installation of private drinking water wells to ensure
that groundwater in the zone of contamination will not be used as
a drinking water SOlrce until drinking water standards are met.
DECLARATION
The selected remedy is protective of human health and the
environment, attain~ federal and state requirements that are
applicable or relevant and appropriate for this remedial action
and is cost-effectj~.re. This remedy satisfies the statutory
preference for remedies that utilize treatment as a principal
element to reduce the toxicity, mobility, or volume of hazardous
substances. In addition, this remedy utilizes permanent.
solu~ions and alternative treatment technologies to the maximum
extent practicable.
~J1 't~ IfJ f
Date
/?uc1 ,~/~
Paul G. Keough,?Acting
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I.
II.
SOUTH MUNICIPAL WATER SUPPLY WELL
TABLE OF CONTENTS
'SITE NAME, LOCATION AND DESCRIPTION
..........
SITE HISTORY AND ENFORCEMENT ACTIVITIES. . . . . . . .
A.' Response History. . . . . . . . . . . . . . . . .
. B. Enforcement History. . . . . . . . . . . . . . . .
III. COMMUNITY RELATIONS
V.
.. . . .
.. . . . .
.........
SCOPE AND ROLE OF THE RESPONSE ACTION
. . .
. . . . .. .
IV.
SITE
A.
B.
C.
CHARACTERISTICS. . . . . . . . . . . . . . . . . .
Geologic Characteristics. . . . . . . . . . . . .
Hydrogeologic Characteristics. . . . . . . . . . .
Env~ronmental Contamination. . . . . . . . . . . ,
VI.
'SUMMARY. OF SITE RISKS
.......
. . . . . . . . . .
VII. .DOCUMENTATION OF NO SIGNIFICANT CHANGES
........
VIII. DEVELOPMENT AND SCREENING OF ALTERNATIVES. . .
A.' Statutory Requirements/Response Objectives
B. Technology and Alternative Development and
Scre'ening .. .. .. .. .. . .. .. . .. . . .. .. .. .. ..
.. .. . ..
. .. .. .
.. .. .. ..
IX.
DESCRIPTION/SUMMARY OF THE DETAILED AND COMPARATIVE
ANALYSIS OF ALTERNATIVES. . . . . . . . . . . . . . . .
A. Source Control (SC) Alternatives Analyzed. . . . .
B. Management of Migration (GW) Alternatives
Ana'l.yzed .. .. .. .. .. .. .. .. .. .. .. .. .. .. .. .. .. .. .. .. .
X.
THE SELECTED REMEDY. . . . . . . . . . . . . . . . . .
A. Description of the Selected Remedy. . . . . . . .
B. Rationale for Selection. . . . . . . . . . . . . .
XI.
STATUTORY DETERMINATIONS. . . . . . . . . . . . . . . .
A. The Selected Remedy is Protective of Human Health
and the Environment. . . . . . . . . . . . . . . .
The Selected Remedy Attains ARARs . . . . . . . . .
The Selected Remedial Action is Cost-Effective
The Selected Remedy utilizes Permanent Solutions
and Alternative Treatment Technologies or Resource
Recovery Technologies to the Maximum Extent
Practicable.. .. .. .. .. .. .. .. .. .. .. .. .. .. .. .. .. .. .. .
The Selected Remedy satisfies the Preference for
Treatment as a Principal Element. . . . . . ~ . .
B.
C.
D.
E.
XII. STATE ROLE. .
.. . .. .. . .. .. .. .. .. .. ..
. . .
.. .. .. .. .. .
1
1
1
3
3
4
4
4
5
6
10
12
13
r3
14
15
15
23
30
30
38
41
41
42
44
44
46
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SOUTH MUNICIPAL WATER SUPPLY WELL
Figure 1
state Concurrence Letter
ARAR Tables
Responsiveness Summary
Administrative Record Index
LIST OF FIGURES
APPENDICES
Page 2
Appendix A
Appendix B
Appendix C
Appendix D
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I.
ROD DECISION SUMMARY
SITE NAME, LOcATION AND DESCRIPTION
SITE NAME:
SITE LOCATION:
SITE DESCRIPTION:
South Municipal Water Supply Well
Peterborough, New Hampshire
The Peterborough South Municipal Water Supply Well Superfund site
(the site) is located approximately two miles south of the center
of the Town of Peterborough in Hillsborough County, New
Hampshire. The South Well, situated at the edge of the Site, is
located on Sharon Road, approximately 350 feet east of the
Contoocook River (Figure 1). The site area is approximately 250
acres.
Land use in the vicinity of the Site, particularly east of the
river, is rural and undeveloped. A plumbing business and several
apartments are situated on the property adjacent to, and south
of, the well. Approximately 1,000 feet north of the well and
west ,of the river are an automobile dealership and several
commercial establishments. The New Hampshire Ball Bearings,
Incorporated (NHBB) manufacturing facility is located
apprdximately 1,200 feet west of the well.
The Site and adjacent area is served by a municipal water system
which receives water from two wells located north of the town \
center. The closest residential wells are located approximately
one-half mile north of the Site and upgradient.
Route 202, the main traffic artery to Peterborough from the
south, and the abandoned Boston and Main railroad which parallels
Route 202, run north-south through the Site. Two major surface-
water environments, the Contoocook River/Noone Pond system, and a
wetlands area, are present at the site. The river and wetlands
area are fed by two small unnamed creeks located east and north
of the NHBB plant.
A more complete description of the site can be found in the
"Remedial Investigation Report,. South Municipal Well site",
April, 1989, on pages 2-5.
II.
SITE HISTORY AND ENFORCEMENT ACTIVITIES
A.
Response History
c
The South Municipal Well was installed in 1952. The gravel
packed well is 70.5 feet deep with a reported safe yield of 0.5
million gallons per day (mgd). On October 22, 1982, the New
Hampshire Water Supply and Pollution Control Commission (NHWSPCC)
tested a sample of water taken frc~ the well for volatile organic
compounds (VOCs). The sample showed the presence of over 100
parts per billion (ppb) of total volatile organics. Subsequent
sampling on December 1, 1982 confirmed those results. At the
recommendation of the U.S. Environmental Protection Agency (EPA)
and NHWSPCC, the Town of Peterborough discontinued the use of the
well. The Town changed the source of municipal water to the
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.............. r\"\ .., +
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GG......... I.........
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SITE HAP
FIGURE I
Not to '-'''ale
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3 .
In May, 1983, the South Municipal Well area was inspected and
ranked according to the Haz".,,:d Ranking System (HRS). I.t was
listed as number 393 on the National Priorities List (NPL) of
sites eligible for funding under the Comprehensive Environmental,
Response, compensation and Liability Act of 1980 (CERCLA),
commonly known as Superfund.
During 1984 and 1985, a hydLogeologic investigation was
undertaken by NHWSPCC in orjer to characterize the aquifer
supplying groundwater to tte South Well.' NHBB conqucted
investigations into chemical use in the Peterborough facility and
to characterize on-property groundwater. As a result of these
investigations, it was deter.mined that a plume of contaminated
groundwater extended from u.lder the NHBB property to the vicinity
of the South Well. .
A more detailed descriptio~ of the Site history can be found in
the Remedial Investigation Report on pages 5-16 and pages 63-69.
B.
Enforcement History
On January 30, 1985, the Agency notified NHBB, which owned a
portion of the site and generated wastes which were released to
the environment,' eventually affecting the South Well, of the
company's potential liability with respect to the Site.
Negotiations commenced with NHBB on January 30, .1985, regarding
the performance of the Remedial Investigation/Feasibility Study
(RI/FS) for the site. On July 26, 1986, under an Administrative
Order by Consent with EPA, NHBB agreed to conduct the RI/FS under
EPA oversight.
NHBB has remained active in the remedy selection process for this
site by identifying and evaluating the remedial alternatives in
the FS and commenting upon the Agency's proposed plan. These
comments were presented by NHBB during the public comment period
at a public meeting in Peterborough and submitted in writing. In
addition, NHBB met with EPA in Boston during the public comment
period to discuss NHBB's comments and proposal. Summaries of the
meetings and written comments were included in the Administrative
Record. Responses to all comments are included in the
Responsiveness Summary, Appendix C. .
III.
COMMUNITY RELATIONS
Through the Site's history, the community has been moderately
involved. EPA has kept the community and other interested
parties apprised of the site activities through informational
meetings, fact sheets, press releases and public meetings.
In August, 1986, EPA released a community relations plan which
outlined a program to address community concerns and keep
citizens informed about and involved in activities during
remedial activities. On October 2, 1985, EPA held an
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4
Peterborough, New Hampshire, to describe the plans for the RI/FS.
On May 24, 1989, EPA held an informational meeting to discuss the
results of the Remedial Investigation (RI). The Agency published
a notice and brief analysis of the Proposed Plan in The Keene
Sentinel on July 14, 1989, and made the plan available to the
public at the Peterborough Public Library. Also, on July 20,
1989, EPA held an informational meeting to discuss the cleanup
alternatives presrnted in the Feasibility Study (FS) and to
present the Agenc~ 's Proposed Plan. During this meeting, the
Agency answered ~4estions from the public. From July 21, 1989 to
August 19, 1989, ':he Agency held a thirty day public comment
period to accept ~"lblic comment on the alternatives presented in
the FS and the Prc?osed Plan and on any other documents
previously releas~d to the public. On August 3, 1989, the Agency
held an informal public hearing to accept any oral comments. A
transcript of thi~ meeting and the comments and the Agency's
response to comments are included in the attached responsiveness
summary.
Copies of the transcript and all comments are also available at
the Peterborough Public Library and at the EPA Records Center at
90 Canal Street, ~oston, Massachusetts, as part of the
Administrative Record.
IV.
SCOPE AND ROLE OF THE RESPONSE ACTION
The selected remedy was developed by combining components of
different source control alternatives and a management of
migration alternative to provide a comprehensive approach for
site remediation. In summary, the remedy provides for extracting
and treating groundwater in the vicinity of the northeast corner
of the NHBB facility where groundwater contaminant concentrations
are highest. Gr~~ndwater contaminated at lower levels, which has
migrated beyond the NHBB property (the "dilute plume"), will also
be extracted and treated on-site, which will also provide
hydraulic control to protect the South Municipal Water Supply
Well. To reduce high contaminant levels in soils around and
under the northeast corner of the NHBB facility, the remedy calls
for installing an in~situ vacuum extraction system. Finally,
sediments from wetlands on-site contaminated above specified
action levels wjll be excavated and/or dredged.
V.
SITE CHARACTERISTICS
Chapter 2.0 of the "Feasibility Study Report, South Municipal
Well Site," July, 1989, contains an overview of the RI. The
significant findings of the RI are summarized below.
A.
Geologic Characteristics
The site is situated in the Contoocook River Valley, on
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5
thickness. Deposits are dominantly sands and ~ravels, although
silty layers are found dispersed both vertica~ly and horizontally
about the site area. Typical organic carbon contents for the
sands and gravels are generally low, estimated to be 0.1%. The
silty layers, some of which are highly contaminated, have an
organic carbon content estimated to be 0.25%.
Fracture trace studies and analysis of core samples indicate that
the bedrock varies from highly fractured to ~nfractured within
the site area. Bedrock beneath the northeast corner of the NHBB
facility is approximately 70-90 feet below the surface, with a
trough trending northeast away from that area. Bedrock generally
rises east of the Contoocook River.
B.
Hydrogeologic Characteristics
The site lies in the Contoocook River draina,oe basin. A small
unnamed brook transects the NHBB property at-its north end, where
it empties into the wetlands area of the NHBB property.
Three pumping tests were conducted on the site during the course
of the RI, and another was conducted prior to the RI by the New
Hampshire Department of Environmental.Services. Two of the RI
tests were conducted by pumping the South Municipal Well, and
another by pumping a pilot study extraction well, EX-I. The zone
of influence produced by pumping the South Well is elongated
para~lel to the Contoocook River, but the elongation is believed
to be caused by boundary effects as opposed to an anisotropic
aquifer. The zone of influence of well EX-} is roughly circular,
indicating the aquifer is isotropic in the vicinity of well EX-l.
Aquifer parameters and behavior were determined from the data
collected during these pump tests.
The overburden aquifer behaves differently than that of the
bedrock,,'.but'a hydraulic connection exists between the two. The
overburden aquifer is semi-confined to unconfined. The bedrock
aquifer behaves as a leaky confined aquifer.
Aquifer parameters for the overburden aquifer are highly variable
throughout the site. Vertical hydraulic conductivity is
generally low relative to radial hydraulic conductivity
indicating that lateral rather than vertical flow predominates.
Average flow direction and velocities were determined on the site
from water table measurements. Average flow direction on the
site under non-pumping conditions is controlled by the
topography, with some occasional bedrock control when the water
table is low. The average flow direction is east-northeast in
the vicinity of the NHBB plant and changes to a northerly
direction at the Contoocook River, paralleling the river.
The groundwater velocities are unusually high, as the media is
coarse and the gradients large.
A mini-piezometer study was conducted on the site to determine
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6
results of the study indicate a hydraulic connection exists
between groundwater and surface wate~ at Noone Pond and at the
sedge meadow/shallow marsh wetlands area located in the northeast
portion of the NHBB property. At times of high flow, surface
waters tend to recharge the aquifer; while at lower flow periods,
groundwater tends to discharge to the wetlands and Noone Pond.
Due to steep gradients east of the Contoocook River, there
appears to be little interconnectior. in the Site area between the
river and the aquifer.
c.
Environmental Contaminati'Jn
1.
All:
The air sampling done at ~he site did not indicate any
transport of VOCs from the NHBB property. Air sampling
done with an OVA found no significantly elevated levels'
of VOCs. The highest concentration, 1.5 ppm, was at
the southwest corner of the building near a ventilation
duct.
2.
Soil
Laboratory and field analyses found VOC contamination \
in unsaturated soils at the site. Higher
concentrations of VOCs in soils were found in
association with areas of high concentrations of VOC
contamination in the underlying groundwater (primarily
the GZ-4 area). Summari7.ed below are the findings of
the soil investigations.
.
The highest VOC concentration is found in the GZ-4
area (up to 5000 ppm of tetrachloroethylene). The
concentrations present indicate that release of
VOCs directly to Si~~ soils has taken place in the
GZ-4 area.
.
VOC concentrations were relatively high in the
vicinity of GZ-105. Concentrations appear to
increase with proximity to the eastern edge of the
fill/parking pad in the GZ-105 area, suggesting
that the VOCs are attributable to surface release
at that location, ~s opposed to contributions from
outfall 002, which has been tied to plant floor
drains and sinks.
.
Low levels of VOCs were detected in the leachfield
area soils. It is possible that these are present
as a result of volatilization from contaminated
groundwater. The low concentration found in
leachfield area soils strongly suggests that it is
not a source contributing to groundwater
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7
3.
Surface Water
;'
Low concentrations of VOCs were detected in surface
water samples in the sedge meadow wetland area east and
northeast of the NHBB facility. No VOC contamination
has been detected in either Noone Pond or the
Contoocook River. The VOC contamination in the
wetlands could result from surface runoff from the NHBB
parking lot, discharge from active roof drains from
NHBB,discharge of contaminated groundwater to the
wetlands area, or leaching of VOCsfrom contaminated
soils. However, the presence of VOCs, most notably at
location SW/SD-8, does not appear to be the result of
current releases from NHBB outfalls since sampling at
the outfalls has not detected elevated concentrations
of VOCs. While the surface water contamination could
be the result of discharge of contaminated groundwater,
piezometric data suggests that the wetlands (sedge
meadow) in the area of contamination is not an area of
groundwater discharge. While this may be a seasonal
effect, it is suggestive that the surface water and
associated sediment contamination is a result of
leaching of VOCs from contaminated soils, most likely
from the area of GZ-I05 identified in the discussion i
above.
4.
Sediments
Analysis of sediment samples in the sedge meadow
wetlands area east and northeast of the NHBB facility
indicated the presence of polychlorinated bipbenyls
(PCBS), polycyclic aromatic hydrocarbons (PAHs), and
metal contamination. The highest concentrations of
PCBs and PARs, in addition to the elevated metal'
concentrations, were found at the terminus of outfalls
001 and 002. These outfalls serviced floor drains and
slop sinks from the NHBB facility prior to their
closure or alteration (outfall 001 serviced the
transformer room). PCBs and metals were also found in
the distribution box for the unused septic system at
the NHBB facility.
l.
PAHs are present in highest concentration at the
terminus of outfall 001, and in lower concentrations in
the area of outfall 002, but do not appear dispersed
over a large area beyond those points. Since transport
of PAR contamination is expected to coincide with
transport of sediment(PARs tend to bind to organic
soils or sediments), PAH conta~'ination is limited to
the areas near the release, with some minor dispersion
downstream from the release points. Outfall 001
appears to have been the major release point of PAR
contamination. Information on past activities
indicates that outfall 001 was tied to a number of
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8
expected, such as areas where burnt or spent cutting or
machine oils containing PAHs might have been washed
down floor drains.
Similar to the distribution of PAHs, the highest
concentrations of PCBs were found in the sediments at
the ends of outfalls 001 and 002. PCB contamination is
confined to areas associated with relatively
significant flow rates, and are not dispersed within
the sedge meadow area. PCB contamination wou~d be
expected to adsorb to soils or sediments, and migrate
with sediments. The lack of detectable PCBs in samples
from areas of NHBB property outside the sedge meadow
suggests that the PCB contamination did not migrate to
its current location through the unnamed brook, or from
upslope areas to the south. Further, the lack of
detectable PCBs at or near the old Boston and Maine
railbed indicates the PCB contamination is not
associated with rail use. In addition, evaluation of
air photos indicates that prior to 1980, the area.
currently occupied by the sedge meadow and shallow
marsh was unsaturated (or partially so), and that flow
from the outfall was accommodated by excavated drainage
ditches. The PCB contamination, if released prior to\
1980 (as is very likely the case), should be restricted
to the areas of these ditches. The data gathered to
date appears to corroborate this.
The presence of PCBs in very low concentrations in the
sediment traps at the confluence of the wetlands and.
the Contoocook River suggests that PCB contaminated
sediment has migrated to this point. However, no PCBs
were detected downstream of the confluencei It is
possible that the confluence of the wetlands and the
Contoocook delineates the extent of PCB contamination.
5.
Groundwater
The major constituents of the contamination plume are
1,1,1-trichloroethane, trichloroethylene, and
tetrachloroethylene. Interviews and historical
investigations indicate that these solvents are or have
been used by NHBB as pure products or mixtures. These
investigations also indicate that these and other
compounds were released to the environment through:
.
in-house releases subsequently washed out floor
drains or sinks to outfalls, or washed out
facility doors, ~nd
.
exterior releases through the draining of a truck-
mounted waste solvent tank.
The highest concentrations of VOC contamination center
about the GZ-4 well cluster' area, and those areas
,;
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9
immediately downgradient (EM-B1 and GZ-104). The
uistribution of contamination between 1 and 10 ppm in
the upper portion of the aquifer extends across the
front of the building and disperses downgradient to the
area of the MW-5 well cluster. Contamination in
concentrations less than 1 ppm extends from the tumble/
garage area underneath the NHBB facility. The plume
disperses downgradient to the northeast, and in the
upper portion of the aquifer, extends at least as far
as boring B-5 on Route 202.
~
The contaminant distribution in the lower portion of
the overburden aquifer is, in general, very similar to
the extent and distribution in the upper portion of the
aquifer. Again, contamination is present under the
building and in the tumble/garage area. The
downgradient distribution of the dilute portion of the
plume, however, is less extensive. Total VOC '
contamination between 100 and 1000 ppb extends to at
least EM-3 in the upper portion of the aquifer;
however, in the lower portion of the aquifer, the same
concentration of contamination extends only as far as
the MW-5 area. vertical hydraullc conductivity
throughout the site is low compared to radial hydraulic -
conductivity, and can account for the lesser extent of
lower overburden contamination. Surface release of VOC
contaminants would be expected to disperse more rapidly
radially than downward into lower overburden materials.
The centering of high concentrations of vOcs--in the
GZ-4 area, coincident with the high soil contamination
discussed earlier, and the evaluation of air photos
strongly indicate that the area was the location of
significant VOC releases to the ground surface. These
solvents have migrated as a free phase (the solvent
remains in concentrated form) to a position in the
saturated zone approximately 50 feet below ground
surface in the GZ-4 area. While the exact extent of
free phase contamination is not known, the potential
volume, based on possible tank truck releases, is quite
large. Migration of solute from this free phase
contamination is believed to be the major source for
the plume found downgradient from the GZ-4 area. This
is consistent with groundwater flow directions, which
are oriented parallel to the elongate direction of the
plume. However, continued leaching of VOCs from
contaminated soils is also expected to contribute
significantly to the contaminant plume.
The northern boundary of the plume near or beneath
Noone Pond is not exactly defined. However,
concentrations are very dilute in the EM-3/EM-I09 area
(south of Noone Pond). At EM-110, north of the Pond,
no VOCs were detected. Quarterly monitoring of EM-109
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10
indicating that the plume terminates at some point near
EM-109 or between EM-109 and EM-llO.
A complete discussion of site characteristics can be found in the
Remedial Investigation Report on Pages 63-225.
,~.
Summary of site Risks
,~n Endangerment Assessment (EA) was performed to estimate the
~robability and magnitude of potential adverse human health and
~nvironmental effects from exposure to contaminants associated
~ith the site. sixteen (16) contaminants of concern, listed on
~age 244 of the RI were selected for evaluation in the EA. These
'=ontaminants constitute a representative subset of the more than
forty (40) contaminants identified at the Site during the
~emedial Investigation. The 16- contaminants were selected to
represent potential on-site hazards based on toxicity,
concentration, frequency of detection, and mobility and
persistence in the environment.
Poterltial human health effects associated with the contaminants
of concern in sediments, soils and groundwater were estimated
quantitatively through the development of several hypothetical i
exposure scenarios. Incremental lifetime cancer risks and a
measure of the potential for non-carcinogenic adverse health
effects were estimated for the various exposure scenarios.
Exposure scenarios were developed to reflect the potential for
exposure to hazardous substances based on the characteristic uses
and location of the site. A factor of specia~- note that is
reflected in the Endangerment Assessment is that the site is
within the zone of influence of the South Municipal Water Supply
Well when there is unrestricted pumping. Land use in and around
the Site, however, is industrial and commercial.
Although on-site groundwater is not currently used for drinking
water, this aquifer was used as a drinking water supply until
contamination from the Site was discovered. Therefore, the
aquifer is classified as an existing source of drinking water.
As such, risks associated with the consumption of groundwater
were evaluated and jUdged to be a likely exposure route which
would result in potential health hazards. Another exposure route
judged to be of potential health and environmental concern is
direct contact with sediments on the NHBB property. The human
health hazard was quantified while the threat to environmental
receptors was discussed qualitatively. other exposure routes
evaluated include: direct contact with soils, inhalation of
airborne contaminants, direct contact with surface waters and
ingestion of fish.
A.
Ingestion of Groundwater
The incremental lifetime cancer risks estimated for ingestion of
water pumped from the South Well was 4.5xlO-5. The exposure
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11
ingestion of groundwater involved a hypothetical off-property
residential well intersecting the contaminant plume. Total
incremental lifetime cancer risks for the average and maximum
scenarios were 2. 22x10-3 and 2 .lX10.2, respectively. For the
maximum case scenario only, there is the potential for chronic
toxic (non-carcinogenic) effects. The major contributors to the
excess cancer risk were tetrachloroethylene and vinyl chloride,
while the major contributor to non-carcinogenic health risks was
tetrachloroethylene.
Ingestion of groundwater from a hypothetical residential well on
NHBB property would result in excess incremental lifetime cancer
risks of 3. Ox10.Z and 3. 5x10.' for the average and m:::l>:i.mum cases,
respectively. This latter scenario, as a representat.ion of the
worst-case, is an estimation of the extreme risks associated with
ingestion of groundwater from the most contaminated area of the
site.
'B.
Direct Contact with Sediments on NHBB Property
Direqt contact with sediments in the wetlands area would result
in exposure to contaminants through dermal absorption and
incidental ingestion. The exposure scenario and risJ~ assessment
evaluate health impacts on children between the ages of 6 and 15
who would access the site 50 times annually for 10 years. In the
maximum exposure scenario, it is assumed that the child contacts
the maximum contaminant levels during each event. The
incremental lifetime cancer risks were 4. 3xlO.S and 2.1X10.1. for
the average and maximum scenarios, respectively. ~~sessment of
non-carcinogenic health risks found no potential for chronic
toxic effects for both average and maximum cases. PARs were the
major contributor to the cancer risk in this s~enario.
There is little information regarding the toxicity of soil
contaminated with PCBs or PARs to. aquatic freshwat~r organisms.
It is thought that exposure to, or toxic effects from,
contaminated sediments is primarily the result of exposure to
contaminated interstitial water. The concentration of
contaminants in the interstitial water is controlled by a number
of factors, the most important of which are the organic carbon
content of the soil and the organic carbon-water partition
coefficient of the contaminant. Because the applicability of
laboratory determined partition coefficients to natural systems
is not entirely precise, and the organic carbon content of soils
at the site is highly variable, model calculations of exposure
doses are approximate. For the wetlands area east and northeast
of the NHBB facility, with an assumed fraction of organic carbon
in the sediment of 0.5 and a Koc (organic carbon partition
coeffi~ient) of 1.3X10s for PCBs (Aroclor 1254, Kadeg et al.,
1986), the average and maximum concentrations of PCBs (based on
an assumed equilibrium partition model) in the interstitial water
are 0.005 ppb and 0.4 ppb, respectively. This must be regarded
as a rough estimate of PCB concentrations in interstitial water.
EPA has established an Ambient Water Quality criterion for
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12
PAHs and metals are expected to add to the total toxicity
associated with the sediment contamination.
Bioaccumulation and biomagnification of contamination is a matter
of concern with PCBs, PAHs, and metals. It is difficult, given
limited data, to estimate the magnitude of 1:he potential adverse
effects of this on environmental receptors, including
reproductory problems. Of particular conceJ:n is the potential
for migratory birds ingesting aquatic inver:ebrates, emergent
insects and sediments which are contaminatei with PCBs.
A complete discussion of site risks can be found in the Remedial
Investigation in Chapter 5.
Actual or threatened releases of hazardous ~ubstances from this
site, if not addressed by implementing the response action
selected in this ROD, may present an immin~lt and substantial
enda~germent to public health, welfare, or, the environment.
VII.
DOCUMENTATION OF NO SIGNIFICANT CHANGES
EPA adopted a proposed plan (preferred alternative) for
remediation of the site in July, 1989. Com~onents of the
preferred alternative included: .
1-
2.
In-situ vacuum extraction for contaminated soils;
Excavation and/or dredging with dewatering of sediments and
off-site disposal; .
Wetlands restoration;
Groundwater extraction and treatment by phase separation, as
needed, and air stripping with carbon columns for air
emission control; .
Long-term environmental monitoring; and
Institutional controls, including restrictions on use of the
South Municipal Water Supply Well.
3.
4.
5.
6.
The remedy selected in this document includes a minor change from
the preferred alternative described in the proposed plan in one
respect regarding the number of groundwater treatment facilities
that will be required to treat the groundwater extracted from
both the NHBB area plume and the dilute plume. The groundwater
component of the selected remedy establishes groundwater cleanup
levels, the period of time necessary to achieve those levels and
restore the groundwater to drinking quality standards, and the
rate for extracting and treating contaminated groundwater
necessary to achieve the cleanup levels in the specified period
of time. The number of groundwater treatment facilities that
must be constructed to treat the specified volume of extracted
groundwater is not specified. This aspect of the selected remedy
is a change from the analyses presented in both the FS and the
Proposed Plan, which described two separate air stripping
treatment plants, one to handle the contaminated groundwater
extracted from the dilute plume, and one to handle the extracted
groundwater from the NHBB area plume. EPA does not consider this
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13
described in the Proposed Plan. Although the analysis of
groundwater remedial alternatives and the preferred alternative
in both the FS and the Proposed Plan discussed two separate
treament facilities, EPA does not consider the possible use of
one treatment facility to change the remedial objectives to be
attained by the selected remedy. The remedy selected specifies
the cleanup levels and rate of aquifer restoration, but leaves
the decision on the number of facilities to the more detailed
analyses to be undertaken during the remedial design. If it can
be shown that onetreatment faciliy rather than two, can meet the
remedial action objectives and the statutory requirements, and
present an equivalent balance of the evaluation criteria, then
one facility may be constructed. The principal remedial action
objective will still be met, attainment of drinking water
standards throughout the aquifer in the shortest practicable
time.. Furthermore, the estimated. cleanup time for the dilute
plume of 7.5 years appears to be a realistic objective on which
to base plant capacities and groundwater extraction rates.
Therefore, the protectiveness and effectiveness of the remedy
will not be affected.
VIII.
DEVELOPMENT AND SCREENING OF ALTERNATIVES
A.
Statutory Requirements/Response Objectives
Prior to the passage of the Superfund Amendments and
Reauthorization Act of 1986 (SARA), actions taken in response to
releases of hazardo~~ substances were conducted in accordance
with CERCLA as enacted in 1980, and the revised National Oil and
Hazardous Substances Pollution contingency Plan (NCP) , 40 CFR
Part 300, dated November 20, 1985. until the NCP is revised to
reflect SARA, the procedures and standards for responding to
releases of hazardous substances, pollutants and contaminants
shall be in accordance with section 121 of CERCLA and to the
maximum extent practicable, the current NCP.
Under its legal authorities, EPA's primary responsibility at
Superfund sites is to undertake remedial actions that are
protective of human health and the environment. In addition,
section 121 of CERCLA establishes several other statutory
requirements and preferences, including: a requirement that EPA's
remedial action, when complete, must comply with applicable or
relevant and appropriate environmental standards established
under federal and state environmental laws unless a statutory
waiver is granted; a requirement that EPA select a remedial
action that is cost-effective and that utilizes permanent
solutions and alternative treatment technologies or resource
recovery technologies to" the maximum extent practicable; and a
statutory preference for remedies that permanently and
significantly reduce the volume, toxicity or mobility of
hazardous wastes over remedies that do not achieve such results
through treatment. Response alternatives were developed to be
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14
A number of potential exposure pathways were analyzed for risk
and threats to public health and the environment in the
Endangerment Assessment and the Wetlands Assessment included in
the. Remedial Investigation Report, April, 1989. Guidelines in
the Superfund Public Health Evaluation Manual (EPA, 1986)
regarding development of design goals and risk analyses for
remedial alternatives were used to assist EPA in the development
of response actions. As a result of these assessments, remedial
response objectives were developed to mitigate existing and
future threats to public health and the environment. These
response objectives are:
.
Eliminate or minimize, to the maximum extent
practicable, the threat posed to the public health,
welfare, and e~vironment by the current extent of
contamination for groundwater, soils, and sediments;
.
Eliminate or minimize the migration of contaminants
from the soils into the groundwater; and
,.
Meet federal and state Applicable or Relevant and
Appropriate Requirements (ARARs).
B.
Technology and Alternative Development and Screening
CERCLA, the NCP, and EPA guidance documents, including, "Guidance
on Feasibility Studies Under CERCLA," dated March, 1988, and the
"Interim Guidance on Superfund Selection of Remedy" [EPA Office
of Solid Waste and Emergency Response (OSWER) Directive No.
9355.0-19 (December 24, 1986)], set forth the ~rocess by which
remedial actions are evaluated and selected. In accordance with
these requirements and guidance documents, treatment alternatives
were developed for the site ranging from an alternative that, to
the degree possible, would eliminate the need for long-term
management (including monitoring) at the site to alternatives
involving treatment that would reduce the mobility, toxicity, or
volume of the hazardous substances as their principal elemeDt.
In addition to the range of treatment alternatives, a containment
option involving little or no treatment and a no-action
alternative were developed in accordance with Section 121 of
CERCLA.
Section 121 (b) (1) of CERCLA presents several factors that, at a
minimum, EPA is required to consider in its assessment of
alternatives. In addition to these factors and the other
statutory directives of Section 121, the evaluation and selection
process was guided by the EPA document "Additional Interim
Guidance for FY 87 Records of Decision" dated July 24, 1987.
This document provides direction on the consideration of SARA
cleanup standards, and sets forth nine factors that EPA should
consider in its evaluation and selection of remedial actions.
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15
1.
Compliance ~lith Applicable or Relevant and Appropriate
Requirements (ARARs);
2.
Long-term Effectiveness and Permanence;
Reduction o~: Toxicity, MObility or Volume;
3.
4.
Short-term :~ffectiveness;
5..
Implementabllity;
6.
community Acceptance;
7.
State Acceptance;
8.
.Cost; and
9.
Overall Protection of Human Health and the Environment.
sections 4.1 and 4.2 of the FS identified, assessed and screened
technologies based on implementability, effectiveness, and cost.
These technologies were combined into source control (SC) and
management of migration (MM) alternatives. Section 4.3 in the ~S
presented the remedial alternatives developed by cOmbining the
technologies identified in the previous screening process in the
categories required by OSWER Directive No. 9355.0-19. The
. purpose of the initial screening was to narrow the number of
potential remedial actions for further detailed analysis while
preserving a range of options. Each alternative was then
evaluated and screened in section 4.4 of the FS. In summary, of
the eighteen source control and nine management of migration
remedial alternatives screened in Chapter 4, twelve source
control and seven management of migration alternatives were
retained for detailed analysis. Tables 4-10, 11 and 12 of the FS
. identify the alternatives that were retained through the
screening process, as well as those that were eliminated from
further consideration.
IX.
DESCRIPI'ION/SUMMARY OF THE DETAILED AND COMPARATIVE
ANALYSIS OF ALTERNATIVES
This section pLesents a narrative summary and brief evaluation of
each alternative according to the evaluation criteria described
above. A detailed tabular assessment of each alternative can be
found in Tables 5-3, 5-4, and 5-5 of the FS.
A.
Source Control (SC) Alternatives Analyzed
The source control alternatives analyzed for the site have been
subdivided into soil (SL) or sediment (SD) alternatives and
include minimal no action alternatives (SL #1 and SD #1);
disposal of contaminated soils at an off-site landfill (SL #));
on-site incineration (SL #5); on-site mechanical aeration (SL
#6); in-situ vacuum extraction (SL #7): in-situ soil flushing (SL
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16
containm~~t of sediments with a permeable cap (SD #4); disposal
of contaminated sediments at an off-site landfill (SD #5); on-
site incineration of contaminated sediments (SD #7); and on-site
sediment washing (SD #8).
A description of each source control alternative is presented
below. The six soil alternatives are described, followed by the
six sedjment alternatives.
SL #1
No Acti.>n
Analyt;i. of the No Action alternative is required by the NCP and
is incltjed for comparison with other remedial alternatives.
Under this alternative, no action would be taken to remediate
contaminated soils at the South Municipal Well site. A No Action
alterna_ive would be selected only if the site posed an
acceptable risk to public health and the environment, and the
remedial objectives could be attained with no further response.
An eventual decrease in soil contaminant concentrations would
resuLt from the infiltration of rainwater and fluctuation of
groundwater levels, thereby causing VOC contaminants to leach
from the soil. However, some contaminants would adhere to soil
particles rather than migrate into the groundwater, preventing
soils from becoming completely "clean" with the no action
alternative. . In addition, a large percentage of the most highly
contaminated soils are covered with either pavement or the NHBB
facility, impeding the infiltration of rainwater and subsequent
leachL.g of soil contaminants.
The No Action alternative would not decrease risks to human
health and the environment associated with the contaminated soils
over the short-term and it would not be protective of human
health and the environment. ARARs for drinking water would not
be met due to the continued leaching of contaminants from soils
to groundwater. Without remediation, soil contaminants will
continue to migrate into the groundwater at the site, increasing
the ti~e needed to achieve target groundwater contaminant
concentrations beyond the foreseeable future. This alternative
would neither provide a permanent solution to site contamination,
nor reduce the mobility, toxicity, or volume of contaminants.
SL #3
DisDosal of Contaminated Soils at an Off-Site Landfill
For this alternative, contaminated soils would be disposed in an
off-site landfill which complies with the requirements of the
Resource Conservation and Recovery Act (RCRA). Approxim~tely
7500 cubic yards of contaminated soil would be excavated from the
vicinity of the northeast corner of the NHBB facility as well as
the areas near outfall 002 and the GZ-105 wells. These soils
would then be transported to a permitted RCRA landfill for
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.17
. .
Since contaminants would be permarently removed from the site
under this alternative within two months, the long-term
effectiveness of the remedy at the Site would be achieved and all
ARARs would be met. However, excavation of all contaminated
soils above the water table, including soils under the NHBB
building, would pose significant problems of maintaining the
structural integrity of the building, thus making implementation
of this alternative not practicable. Also, the remedy would
present a slight increase in risk to the community during the
period of remedial action due to the transport of hazardous waste
off-site. In addition, excavating all contaminated soil~ could
potentially release VOCs and dust into the air,. which.would be
controlled to the extent practicable during construction . .
activities. This alternative moves waste from one site to an
off-site landfill, where the long-term effectiveness of the
landfill is uncertain, and it does not reduce mobility, toxicity,
or volume of the contaminants or the contaminated media. . .
Estimated Period of Remediation: 2 months .
Estimated Capital Cost (net present worth): $4,021,718
Estimated Total Cost (net present worth): $4,021,718
SL #5
On-site Incineration
On~site incineration of contaminated NHBB soils would involve
excavating approximately 7500 cubic yards of soil, as in 5L #3.
The soils would be treated on-site with a mobile incinerator, and
the treated material would be replaced in excavated areas, and
covered with clean fill. Following these activities, the
excavated areas would. be seeded if not under the building or
parking areas. .
Since contaminants would be treated to achieve target levels
under this alternative within six months, the long-term
effectiveness of the remedy would be achieved and all ARARs would
be met. However, excavation of all contaminated soils above the
water table, including soils under the NHBB building, would pose
significant problems of maintaining the structural integrity of
the building, thus giving this alternative a very low
implementability rating. Potential risks to the community, site
workers, and the environment associated with the operating
incinerators would be controlled by the use of appropriate
technologies and control devices. In addition, excavating all
contaminated soils could potentially release VOCs and dust into
the air, which would be controlled to the extent practicable
during construction activities. Incineration technology is
readily available and permanently destroys 99.99% of the
contaminants.
Estimated Period of Operation: 6 months
Estimated capital Cost (net present worth): $4,355,078
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18
SL #6
On-Site Mechanical Aeraticn
On-site mechanical aeration involves excavating approximately
7500 cubic yards of contaminated soils, as in SL #3 and #5. The
excavated soils would be treated on-site with mechanical
aeration, which transfers volatile organics from the soil into
the air stream by physically mixing the soils in the presence of
an induced air flow. Excivation and replacement activities
parallel those described. n SL #5 and, therefore, will not be
discussed further here.
Mechanical aeration is i::; lementable and offers short-term and
long-term effectiveness. !n addition, all ARARs would be met and
the alternative would ach~eve a permanent reduction in toxicity,
mobility and volume of contaminants. However, excavation of all
contaminated soils above ~he water table, including soils under
the NHBB building, would pose significant problems of maintaining
the structural integrity of the building, thus giving this
alternative a very low implementability rating. Potential risks
to the community, site workers, and the environment ,associated
with 'air emissions from the mechanical aerators would be
controlled by th~ use of a~propriate technologies and control,
devices. In addition, excavating all contaminated soils could \
potentially release VOCs and dust into the air, which would be
controlled to the extent practicable during construction
activities.
Estimated
Estimated
Estimated
$443,025
Estimated
Period of Perfc:-mance: 9 months,
Capital Cost: $2,218,404
Operation and Maintenance Costs (net present worth):
Total Cost (net present worth):
$2,661,429
SL #7
In-situ Vacuum Extraction
This is the preferred alternative for soil remediation and is
described in Section X., The Selected Remedy.
SL #8
In-situ Soil Flushing
Soil flushing would inject washing agents (water, steam, or
surfactants) into areas of soil contamination, and the injected
fluids and contamination would be extracted for treatment and
recycling. The fluids would mobilize the soluble VOCs which are
adsorbed to soil particles. The washing solution would then be
extracted via an extraction well, treated, and reinjected to form
a closed loop continuous flushing system. Thus, soil
flushing must be considered in connection with groundwater
remediation, since extraction of flushing solutions will include
concurrent extraction of groundwater. Therefore, the design of '
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19
~
In-situ soil flushing may be effective in providing a long-term,
permanent solution. Upon implementation, adverse impacts to
human health or the environment, such as dust emissions during
installation of injection and extraction wells, could be
controlled. Furthermore, the remedy would comply with all ARARs
when the soil cleanup levels are reached, and meet the statutory
preference for on-site remediation and for alternatives that
significantly and permanently reduce the toxicity, mobility or
volume of contaminants. The short-term effectiveness in reaching
target soil cleanup levels is uncertain, with an estimated 30
years of flushing required. This remedy would require long-term
operation, maintenance and monitoring in order to ensure
effectiveness.
Estimated Period of Operation: 30 years
Estimated Capital Cost: $758,747
Estimated Operation and Maintenance Costs
$3,119,605
Estimated Total Cost (net present worth):
(net present worth) :
$3,878,352
SD #~
No Action
Under this alternative, no sediment remediation would be
performed. This alternative is included in the FS as required by
the NCP to serve as a basis for comparison with other remedial
alternatives considered. A No Action alternative would be
selected only if the site posed an acceptable risk to public
health and the environment, and the remedial objectives could be
attained with no further response.
The No Action alternative for remediating the wetlands would not
provide overall protection of human health and the environment.
This alternative would not reduce the toxicity, mobility, or
volume of contaminants, and would not abate the risks to humans
and environmental receptors posed by the contaminated sediments.
Allowing the sediments to remain in-place will continue to allow
the threat that contaminants may migrate off-site by movement of
surface waters. Therefore, the alternative would not be
effective in addressing the contamination problems in either the
long-term or the short-term.
SD #3
Containment of Sediments with an Impermeable Cap
This alternative would cover an estimated 15,800 square feet of
contaminated sediments located in on-site wetlands with a
multi-layered impermeable cap. Contaminated sediments are
located in an area of groundwater fluctuation, and are, at times,
saturated and even covered with water. Although impermeable
capping would eliminate rainwater infiltration and subsequent
leaching, it would have no effect on leaching as a result of
water table fluctuations. Impermeable capping would isolate
contaminated sediments and would eliminate risks to human health
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20
ingestion of contaminated sediments. This alternative would also
stop erosional transport of contaminants. A fence would be
erected around the cap to prevent public access to the area, and
the. property deed would be amended to indicate that these areas
are never to be excavated.
The design of the impermeable cap would conform to the RCRA
landfill closure requirements.. EPA's guidance under RCRA
recommends that caps be a three-layered system consisting of an
upper vegetative layer, underlain by a drainage layer over a
low-permeability layer (US EPA, 1982). The cap would function by
diverting infiltrating liquids from the vegetative layer through
the drainage layer and away from the underlying waste materials.
Because the sediments would be capped in-place, no liner or
leachate collection system would be constructed.
capping would be protective of human health and the environment,
but its effectiveness over both the short- and long-terms is
uncertain. While capping would isolate contaminants,
construction of the cap could adversely affect the environment in
the 9hort-term by re-suspending contaminated sediments and
permitting migration of site contaminants. It may be possible,
however, to minimize re-suspension of contaminated sediments if\
cap construction is timed to take place during a period when the
water table is low. In addition, a cap would effectively
eliminate portions of the wetlands, change surface water and
groundwater flow patterns, and diminish the beneficial aspects of
the wetlands. Finally, the cap would be constructed in the 100-
year flood zone and would be partially submerged. In such a
situation, where the cap is subject to constantly changing
conditions and erosion, this alternative presents long-term
management problems to monitor the cap as necessary to avoid
failure of the containment and the release of contaminants.
Since other practicable and more protective alternatives exist
which would result in less harmful impacts to the wetlands and
floodplain, this alternative does not meet the wetland and
floodplain ARARs.
Estimated
Estimated
Estimated
$207,736
Estimated
Period of Operation: 30 years
Capital Cost: $323,923
Operation and Maintenance Costs (net present worth) :
Total Cost (net present worth):
$531,659
SD #4
Containment of Sediments with a Permeable CaD
This alternative, as T-ith SD #3, would cover approximately 15,800
square feet of contaminated sediments, except that this
alternative would utilize a permeable cap. Thus, it would not
eliminate infiltration of rainwater through contaminated
sediments beneath the cap.
Capping would be protective of human health and the environment,
but its effectiveness over both the short- and long-terms is
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21
uncertain. While capping would isolate contaminants,
construction of the cap could adversely affect the environment in
the short-term by re-suspending contaminated sediments and
permitting migration of site contaminants. It may be possible,
however, to minimize re-suspension of contaminated sediments if
cap construction is timed to take place during a period when the
water table is low. In addition, a cap would effectively
eliminate portions of the wetlands, change surface water flow
patterns, and diminish the beneficial aspects of the wetlands.
However, since the cap is permeable, the impact on groundwater
flow patterns will be ~uch less than that of SO #3. Finally, the
cap would be constructed in the 100-year flood zone and would be
partially submerged. In such a situation, where the cap is
subject to constantly changing conditions and erosion, this
alternative presents long-term management problems to monitor the
cap as necessary to avoid failure of the containment and the
release of contaminants.. since other practicable and more
protective alternatives exist which would result in ,less harmful
impacts to the wetlands and floodplain, this alternative does not
meet the wetland and flo~dplain ARARs.
.
Estimated
Estimated
Estimated
$236,790
Estimated
Period of Operation: 30 years
Capital cost: . $153,241
operation and Maintenance Costs (net present worth) :
Total Cost (net present worth): $390,031
so #5
Disposal of contaminated Sediments at an Off-site Landfill
. .
This is the preferred alternative for sediment remediation and is
described in section X., The Selected Remedy.
SO #7
On-Site Incineration
On-site incineration would involve dredging or excavating (over
the same area, 15,800 square feet, that would be remediated in so
#3, #4, and #5) an estimated 1170 cubic yards of sediments
contaminated above the sediment target cleanup levels from the
wetlands. The sediments would be incinerated to remove hazardous
PCB and PAH contaminants. The treated materials would be mixed
with clean fill, and replaced in excavated areas of the wetlands.
This alternative would be protective of human health and the
environment and reduce the toxicity, mobility, and volume of
organic contaminants by permanently destroying them. .
Incineration technology is technically feasible and
implementable.. However, given the small volume of sediments, the
limited availability of mobile incinerators and their extended
start-up time, the on~site incineration alternative would be
practicably implementable only if the selected soil remedial
action had been on-site incineration. . Its implementation could
present potential adverse human health and ecological impacts
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22
creating the potential for re-suspending contaminated sediments
and permitting migration of site contaminants. It may be
possible, however, to minimize re-suspension of contaminated
sediments if cap construction is timed to take place during a
period when the water table is low. In addition, excavation of
the sediments would destroy portions of the wetlands. However,
the excavation could be performed in a manner that minimizes, to
the extent feasible, impacts on and disturbance of the wetlands.
Finally, the remedy would require restoration of the affected
wetlands, to the extent practicable.
Estimated Period of Operation: 2 months
Estimated Capital Cost: $730,339
Estimated Total Cost (net present worth):
$730,339
SD #8 . .
On-site Sediment Washinq
This 'alternative would involve dredging or excavating (over the
same area, 15,800 square feet, that would be remediated in SD #3,
#4, ~5 and #7) an estimated 1170 cubic yards of sediments
contaminated above the sediment target cleanup levels from the
wetlands, as described above in SD #7. The only difference is
that this. alternative would treat the sediments with a washing
solution. . .
Sediments would be passed through a grinder to achieve a uniform
grain size. prior to treatment. From the grinder, sediments would
enter a'treatment tank where they~~uld.be agitated in a solution
of surfactanta.to remove organic contaminants. Following
agitation, liquids would be separated from solids in a
centrifugal filter; clean solids would be removed from the
filter, and liquids would be placed in a distillation column to
separate the organic contaminants from the water. Treated
materials would then be replaced in the excavated areas of the
wetlands, covered with clean fill, and revegetated to complete
restoration of the wetlands. .
This alternative would protect human health and the environment
from risks currently.associated with contaminated site sediments.
This alternative is a relatively new technology, and testing will
be required to determine the effectiveness of this technique on
NHBB sediments and contaminants. If the technology were
implementable, the remedy would offer both short- and long-term
effectiveness and would be a permanent solution to the
contamination problem. In addition, all ARARs would be met and
remediation would result in significant reduction in the toxicity
and volume of contaminated sediments.
As with SD #7, the implementation of this remedy, however, could
present potential adverse human health and ecological impacts
from excavating and/or dredging. sediments from the wetlands, as
discussed in SD #7, by creating the potential for re-suspending
contaminated sediments and permitting migration of site.
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23
re-suspension of contaminated sediments ~f cap construction is
timed to take place during a period when the water table is low.
In addition, excavation of the sediments would destroy portions
of the wetlands. However, the excavation could be performed in a
manner that minimizes, to the extent feasible, impacts on and
disturbance of the wetlands. Finally,l:he remedy would require
restoration of the affected wetlands, t~ the extent practicable.
Estimated
Estimated
Estimated
$377,031
Estimated
Period of Operation: 8 montts
Capital Cost: $750,290
Operation and Maintenance COf:ts (net present worth):
Total Cost (net present worth: :
$1,127,321
B.
Management of Migration (GW) Alternatives Analyzed
Management of migration alternatives address contaminants in
groundwater that have migrated from the original source of
contamination. At the South Municipal Water Supply Well Site,
conta~inants have migrated from the vicinity of the New Hampshire
Ball 'Bearings facility northeasterly towards Noone Pond.
Experience at the site has shown that pumping of the South Well i
can draw groundwater with these contaminants into the well. The
management of migration alternatives evaluated for the Site
include a minimal no action with monitoring alternative (GW #1):
groundwater extraction with on-site air-stripping (GW #3);
groundwater extraction with GAC (GW #4); well-head treatment
(South Well) with air stripping (GW #6); development of an
alternate water supply (GW #7); groundwater extraction with a
radial collector well with on-site air stripping (GW #8); and
groundwater extraction (accelerated) with on-site air stripping
( GW # 9) .
GW #1
No Action
~
Analysis of the No Action alternative is required by the NCP and
is included in the FS for comparison with other remedial
alternatives. A No Action alternative would be selected only if
the site posed little or no risk to public health and the
environment. Under this alternative for the South Municipal Well
site, no action would be taken to remediate contaminated
groundwater at the site. The contaminant plume would eventually
attenuate and contaminant concentrations would decrease, but
groundwater contaminant levels would not fall to within the
target cleanup levels for drinking water for more than 100 years.
The No Action alternative does not provide overall protection of
public health and the environment. Groundwater would not reach
drinking water quality ARARs in the foreseeable future. It does
not reduce the toxicity, mobility, or volume of contaminants in a
reasonable amount of time and would permit the contamination to
spread further in the regional groundwater aquifer. No action
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contamination in the short-term, ?nd would be ineffective in
attaining remedial objectives in the long-term.
GW #3
Groundwater Extraction with On-site Air Stripping
This alternative would involve the extraction and treatment of
groundwater from both near the NHBB building and the dilute
plume, and subsequent discharge of the treated water.
Groundwater from the northeast corner of the NHBB facility
(including the highly contamina~:ed GZ-4 area), where groundwater
contaminant concentrations are 1lighest, would be extracted at a
rate of approximately 200 gall~~ 3 per minute (gpm). An
additional groundwater extractic~ system, also capable of
extracting approximately 200 gpm, would be installed to draw
groundwater from the area of the dilute plume. This dilute plume
system would extract contaminan~s that have already migrated
beyond the NHBB property, and would provide hydraulic control of
the dilute portion of the plume.
Extracted groundwater from the area near the NHBB building would
be treated in packed column air strippers, with the addition of
phase separation prior to air stripping for the more contaminated
GZ-4 area groundwater. Under this alternative, the treated wat~r
from the air strippers would be discharged to an infiltration
trench upgradient of the contaminated NHBB plume in order to
enhance removal efficiencies.
A second air stripping system ~ould be installed near the
extraction wells located in the dilute portion of the plume. Due
to the low contaminant concentrations in the groundwater in this
area, phase separation and pretreatment would not be required
prior to air stripping. Water effluent would be discharged to an
infiltration trench installed between the second air stripping
treatment system and the South Well. This second infiltration
trench would provide extra protection for the South Well by
creating a more. positive hydraulic barrier between the
contaminant plume and the well
As an element of extracting contaminants near the northeast
corner of the NHBB building, it may be necessary to implement
technologies to enhance contaminant removal and to address the
presence of free phase solvents in the saturated zone of this
area. Two potentially applicable techniques are cyclic pumping
and steam injection. Either or both of these technologies could
be used in conjunction with the treatment system described above,
and are detailed in the FS.
v
The time estimate for accomplishing groundwater remediation would
be approximately 19 to 32 years for the NHBB area groundwater and
approximately 15 to 30 years for the dilute plume. The
restoration time is contingent upon treatment of contaminated
soils to eliminate further migration of VOCs into the
groundwater. The ranges presented reflect the uncertainties
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uncertainties would be clarified during design studies. Periodic
system and groundwater sampling would be conducted to monitor
contaminant concentrations and to assess the effectiveness of
site remediation.
The implementation of this remedial alternative would have no
adverse impacts to the community. Adverse environmental impacts
and risks to site workers could be controlled by implementation
of appropriate safety measures and' control technologies, as
described in theFS. This alternative would provide protection
of public health and the environment, and the groundwater. would
comply with all drinking water ARARs upon attainment of ~;he
groundwater cleanup levels. The remedy would permanently reduce
mObility, toxicity, and volume of groundwater contaminants, and
the services and technologies necessary for its implementation
are readily available. Once the groundwater is restored, this
alternative would be effective in the long-term and woulu be a
permanent remedy., Its implementation would, however, introduce a
potential change to the groundwater/wetlands relationship, but
only causing minimal effects on the nearby wetlands areas.
The primary problem with this alternative is length of time
necessary to restore the groundwater to drinking water quality.
The speed of restoration is dependant, in part, on the rate at
which contaminated groundwater is pumped from the aquifer for
treatment. This alternative would not permit use of the
~ntr~ated groundwater for 15 to 32 years, which could be
shortened if the rate of extraction and treatment is increased.
Therefore, this alternative would not achieve the remedial
objective of restoring the groundwater in the shortest period of
time practicaple. .
Estimated Period of Operation: 15 - 32 years
Estimated Capital Cost: $2,067,039
Estimated operation and Maintenance Costs (net present worth):
$6,193i965 '.
Estimated Total Cost (net present worth): $8,261,004
GW #4
Groundwater Extraction with GAC
This alternative involves extraction of contaminated groundwater
as described in GW #3, with the only significant difference being
the method of treatment, carbon adsorption.
Under this alternative, the water extracted from the NHBB area
and the dilute portion of the plume would be pumped to separate
activated carbon adsorption treatment systems, located near the
extraction wells. VOCs would bind to the carbon as the water
moves through the system. The contaminated carbon would be sent
to a licensed off-site treatment facility for regeneration.
since the contaminants are permanently removed from groundwater
during carbon adsorption, the treatment is irreversible. The
treated water would be piped to infiltration trenches for
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26
As with GW #3, the implementation of this remedial alternative
would have no adverse impacts to the community. Adverse
environmental effects and risks to workers could be controlled by
implementation of appropriate safety measures and control
technologies, as detailed in the FS. Its implementation would,
however, introduce a potential change to the gro~Jndwater/wetlands
relationship, but only causing minimal effects on the nearby
wetlands areas. Treatment of contaminated grounjwater with
carbon adsorption is effective in both the short and long terms,
and would be a permanent remedy. This treatment would reduce
contaminant concentrations in the dilute plume ~:roundwater to the
cleanup target levels. The time estimate for accomplishing these
target levels is the same as for GW 13, contin~~,~ upon treatment
of contaminated soils to eliminate further migra'~ion of VOCs into
the groundwater. '
This remedial alternative reduces the toxicity, mobility, and
volum~ of contaminants and of contaminated media, and complies
with all ARARs. Carbon adsorption has been shown to be an
effective technology for removing VOCs from groundwater, and the
services and technologies necessary for its implementation are
readily available.
One difference between this treatment approach and the air
stripping approach of GW #3 is that the carbon would have to be
maintained, presenting the need for long-term management of
treatment residuals. Maintaining the activated carbon i~cTe~se~
the costs of this alternative beyond the costs of GW #3.
However, the primary problem with this alternative, as with GW
#3, is length of time necessary to restore the groundwater to
drinking water quality. The speed of restoration is dependant,
in part, on the rate at which contaminated groundwater is pumped
from the aquifer for treatment. This alternative would not
permit use of the untreated groundwater for 15 to 32 years, which
could be shortened if the rate of extraction a~d treatment is
increased. Therefore, this alternative would not achieve the
remedial objective of restoring the groundwate~ in the shortest
period of time practicable.
Estimated Period of Operation: 15 - 32 years
Estimated Capital Cost: $1,485,940
Estimated Operation and Maintenance Costs (net present worth) :
$7,266,602
Estimated Total Cost (net present worth): $9,752,542
GW #6
Well-Head Treatment (South Well) with Air Stripping
Th~s alternative would directly treat groundwater for the
Peterborough public water supply through well-head treatment of
water extracted by the South Municipal Well. Water would be
ex~racted at 450 gallons per minute (gpm), which is the rate at
which water was, pumped prior to discovery of the contamination,
and treated with packed column air stripping. Pumping from the
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conta~inant plume into the well. contaminant concentrations
should not exceed 200 parts per billion (ppb) initially, but
continued pumping without treatment or isolation of the GZ-4 area
soils and groundwater would draw increasingly higher contaminant
conce.ntrations into the well.
A sirgle stripping tower approximately five feet in diameter and
20 feet high would receive the groundwater directly from the
well, Treated water from the tower would then enter a holding
tank from which it would be pumped to the public water
distribution system. Periodic monitoring of the treated water
would be performed to verify the efficiency of contaminant
remo\~al prior to public distribution of the treated water. In
addition, groundwater monitoring between the current contaminant
plume and the South Well would be performed to provide
information on the behavior of the plume under full South Well
pumping conditions.
Well~head treatment, by itself, would not remediate site
groundwater contamination and would not restore the ~quifer to
drin~ing water quality. Although it would ensure that the public
water supply is treated to remove any contaminants prior to
distribution, well-head treatment would not treat the highly
contaminated groundwater in the area of GZ-4 and would allow
contaminant migration to continue. For this reason, potential
risks to human health and the environment following its
installation and operation would be substantial. While th€
excessive risks to humans associated with ingestion of
contaminated groundwater from the South Well would be
sUbstantially decreased due to the direct treatment of the well
water, well-head treatment does not protect against risks from
the development of private wells in the contaminated aquifer and
use of the contaminated water.
This alternative would be effective in the short-term for
providing safe public water supplies. Implementation would
present minimal and controllable adverse environmental impacts,
and no adverse impacts to the community or site workers.
Although this treatment would meet all ARARs directly pertaining
to the treatment of South Well water, it would not reduce the
levels of contamination to meet drinking water standards
throughout the aquifer. The remedy would not restore what had
been a source of drinking water prior to the contamination.
This alternative, therefore, would not result in significant and
permanent reduction in the toxicity, mobility, or volume of
contaminants or of contaminated media. Since the contaminated
water would continue to be drawn to the well for treatment, the
well-head treatment would be required for a long peri~d of time
and-the remedial action would incur substantial costs to operate
and maintain.
Estimated Period of Remediation: 30 years
Estimated Capital Cost: $925,466
Estimated Operation and Maintenance Costs
$2,414,311 .
Estimated Total Cost (net present worth) :
(net present worth) :
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GW #7
DeveloDment of an Alternate Water SUDDly
Under this alternative, an alternate water supply would be
provided to the South Municipal Well site community. The
evaluation of this alternative was based on the Whitman and
Howard report (1985) prepared for the Town by Whitman and Howard
Engineering, Inc. The 1985 report determined that there are
several potential well sites in the Town of Peterborough, in
addition to the wells currently supplying the town with water.
Areas defined to have "major groundwater potential" in this
report, and which have not yet been developed as town water
supplies, include the Grove Street Aquifer, the northern swamp,
and the Bogle Road areas.
Development of an alternate water supply would require testing of
the potential aquifer areas to determine whether water yields are
sufficient to meet the Town's needs, and to verify that
groundwater from these areas is potable. Following testing, a
well would be installed with the appropriate piping to connect
the new water supply to the existing Town system for distribution
to the south end of Town. Both the testing and the well and
piping installation would be implemented easily and would present
no technical difficulties. \
With this alternative, short-term effectiveness would be achieved
with minimal and controllable adverse impacts to ,site workers,
the community, and the environment. This alternative would be
effective in the short-term for providing drinking water from the
aquifer and providing safe public water supplies.
Implementation would present minimal and controllable adverse
environmental impacts, and no adverse impacts to the community or
site workers. However, this approach does not protect against
risks from the development of private wells in the contaminated
aquifer and use of the contaminated water.
This alternative would not attain all ARARs directly pertaining
to drinking water in the aquifer and the remedy would not restore
what had been a source of drinking water prior to the
contamination. This-alternative, therefore, would not result in
significant and permanent reduction in the toxicity, mobility, or
volume of contaminants or of contaminated media. Although this
alternative would significantly reduce risks to human health and
the environment by providing a new, clean water supply, it would
not address the contaminant migration that will continue from the
GZ-4 area.
"
Estimated Capital Cost (net present worth): $641,118
Estimated Total Cost (net present worth): $u41,118
GW #8
Groundwater Extraction with a Radial Collector Well with Air
Stripping
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the method of groundwatsr extraction near the northeast corner of
the NHBB building. At that location, a single concrete caisson
would be installed. From the caisson, screened wells would be
extended radially at a chosen depth. These radial wells would be
capable of extracting groundwater from the most contaminated
portion of the aquifer at a rate of 200-300 gallons per minute.
This method of extraction is theoretically more efficient than
extraction from conventional wells since the horizontal screening
allows groundwater to be removed from a particular depth at high
volume. The ability to extract high volumes of groundwater from
a single depth allows placement of horizontal wells at several
points within the most highly contaminated "layer" of the
aquifer, increasing tha efficiency of contaminant removal. In
addition, high volume p-xtraction from a single depth would
increase the groundwater. flow rate through the extraction layer,
presumably enhancing contaminant removal. Installation of four
radial wells, extending from the caisson at a depth of 55 feet,
is expected to be sufficient to treat the contamination. Dilute
plume extraction and treatment will still be necessary. The time
estimate for accomplishing groundwater remediation would be the
same as for GW #3. The rate of restoration would be contingent
upon .treatment of contaminated soils to eliminate further
migration of VOCs into the groundwater. Periodic system and
groundwater sampling would be conducted to monitor contaminant
concentrations and to assess the effectiveness of site
remediation.
The implementation of this remedial alternative would have no
adverse impacts to the community. Adverse environmental impacts
and risks to site workers could be controlled by implementation
of appropriate safety measures and control technologies, as
described in the FS. This alternative would provide good overall
protection of public health and the environment, and the
groundwater would comply with all drinking water ARARs upon
attainment of the ground~ater cleanup levels. The remedy would
permanently reduce mobility, toxicity and volume of groundwater
contaminants, and the services and technologies necessary for its
implementation are readily available. Once the groundwater is .
restored, this alternative would be effective in the long-term
and would be a permanent remedy. The rate of groundwater
remediation would be contingent upon the elimination of
contaminant migration from the soils in the GZ-4 area. The
remedy would be permanent upon completion of groundwater
remediation.
v
Estimated Period of Operation: 15 - 32 years
Estimated Capital Cost: $2,909,827
Estimated Operation and Maintenance Costs (net present worth) :
$6,193,965 .
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GW #9
Groundwater Extraction (accelerated) with On-Site Air StriDDing
This is the preferred alternative for groundwater remediation and
is described in section X., The Selected Remedy.
x.
THF SELECTED REMEDY
The selected remedial action is a comprehensive approach
consisting 0; source control components for soils and sediments,
and a managel\p.nt of migratj~m component listed in Section VII.
A. Description of the Selected Remedy
L.
Remedial Action Objectives/CleanuD Goals
The selected remedy was developed to satisfy the following
remedial objectives which will guide the design of the remedy and
be used to measure the success of the remedy.
a.
Soil. Specific soil target cleanup levels will be met
in the remedial action in order to reduce contaminant\
levels to eliminate the potential migration of
contaminants from the soils into the groundwater at
levels exceeding groundwater cleanup target levels.
The target soil cleanup levels are listed below for each of the
qroundwater indicator chemicals. Those contaminants which are
also indicator chemicals for soils are shown in bold.
Contaminant Tarqet Level (DDb)
Tetrachloroethylene 4.5
l,l,l-Trichloroethane 76
Trichloroethylene 1.5
1,1-Dichloroethylene 1.1
Toluene 1500
l,l-Cichloroethane 60 u
Vinyl Chloride 0.28
The excess cancer risk associated with direct contact and
ingestion of soils containing these target levels is expected to
be 2.92 X 10.10, a level which is more protective of human health
and the environment than the risk range generally considered by
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31
The soil target cleanup levels set forth in this document are, i,!
part, based on estimates of soil characteristics developed during
the RIfFS. During the design of the remedy, additional soil
characterization will take place that could provide better
information from actual field data. Where appropriate, if
analysis of new 'data indicates that the parameters used in the
model should be adjusted to reflect actual field conditions, the
soil target cleanup levels may be adjusted, and an explanation cf
significant differences issued, if appropriate.
b.
Sediments. Specific sediment target cleanup levels
will be met in the remedial action in order to:
.
Eliminate, to the maximum extent practicable, the
potential exposure of humans or environmental recepto~s
to site related contaminants:
.
Prevent the potential migration of contaminants from
the sediments, including migration during
implementation of the remedy; and
.
Implement the remedy in a manner that minimizes
disturbance of the wetlands and restores the
wetlands, to the extent practicable.
To meet these objectives, sediments in the wetlands contaminated
with PCBs at levels greater than 1 ppm or with PARs at levels
greater than 1.1 ppm will be excavated and disposed off-site.
Further, the remedy selected will include measures to prevent the
potential migration of contaminated sediments during
implementation. The remedy will also include provisions to
minimize destruction of the wetlands area and to ensure that
damaged areas in the wetlands will be restored to the maximum
extent practicable.
The excess cancer risk resulting from the target sediment cleanup
levels would be 2.9 X 10"7 for PCBs and 1 x 10.0 for PAHs, for a
total risk of approximately 1.3 x 10"6, which is protective of
human health.
c.
Groundwater. Specific groundwater target cleanup
levels will be met in the remedial action in order to:
.
Restore the contaminated portion of the aquifer,
including all of the "dilute plume" area, to drinking
water quality (MCLs) in as short a time as practicable;
.
Prevent the migration of contaminated groundwater into
uncontaminated portions of the aquifer;
.
Implement a groundwater extraction system which creates
a barrier between highly contaminated groundwater in
the NHBB area and the dilute plume area, so that use of
the portion of the aquifer affected by the dilute plume
could occur independent of the restoration of the NHB8
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.
Implement a groundwater extraction system which creates
a barrier between the dilute plume area ar~ the South
Municipal Well, to permit restricted Use of the South
Well in the event of water supply emergencies prior to
full attainment of groundwater cleanup target levels in
the dilute plume.
The target ground water cleanup levels are listed below for each
of the groundwater indicator chemicals.
Contaminant Tarqet Level (DDb)
Tetrachloroethylene 5
I, 1, 1-Trichloroethane 200
Trichloroethylene 5
1,1-DichloroethYlene 7
Toluene 2000
1,1-Dichloroethane 810
Vinyl Chloride 2
Of the indicator chemicals, tetrachloroethylene is the most
resistant to treatment based on relative water solubilities and
soil adsorption coefficients. Therefore, it is expected that
concentrations of all other indicator chemicals will decrease
proportionally to, or more quickly than concentrations of
tetrachloroethYlene. Thus, at the conclusion of the groundwater
remediation, concentrations of each groundwater indi~ator
chemical will be at or below its target level. The carcinogenic
risks associated with post-remediation indicator chemical
concentrations are expected to range from 7.7 x 10~ to
1.0 X 10.5. The target levels were established in ordar to
remediate the groundwater so the aquifer may once again be a
source of drinking water for the Town of Peterborough. The
target levels for groundwater are based on Maximum Contaminant
Levels (MCLs) established under the federal Safe Drinking Water
Act and the corresponding standards of the State of New
Hampshire, except for tetrachloroethylene and 1,1-dichloroethane.
The target level for tetrachloroethylene is based Upon a proposed
MCL while the target level for l,l-dichlorothane is based Upon
the New Hampshire Department of Public Health Service consumption
advisory for water supplies, since no MCL has been promulgated.
"
It is estimated that the groundwater target cleanup levels under
the remedy should be attained in the dilute plume in 7.S years at
a groundwater extracion rate of 400 gpm. Target levels for the
groundwater in the NHBB area, near the GZ-4 well, should be
attained in 19 to 32 years at a groundwater extraction rate of
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33
h
target levels within 19 to 32 years due to the difficulties in
extracting such highly contaminated groundwater. The rate of
restoration of this remedy, as set forth in this document, is
calculated, in part, based on estimates of aquifer and soil
characteristics developed during the RI/FS. If during the
preliminary design, it is determined that the extraction rate
evaluated in the FS (400 gpm in the dilute plume and 200 gpm in
the NHBB area) and the number and configuration of extraction
wells specified for each area will not result in a restoration
time similar to that specified above, the extraction rates, and
number and configuration of wells may be adjusted.
1.:..
Description of Remedial Components
After evaluating all of the feasible alternatives, EPA is
selecting a remedy with six components to address soil, sediment,
and groundwater contamination at the site:
a.
SL 17 In-Situ Vacuum Extraction of Contaminated Soils
An in-situ vacuum extraction system (VES) will be installed to
reduce contaminant levels in the 7500 cubic yards of on-site
soils that are above target cleanup levels. Sin~e the treatmen~
is performed in-situ (i.e., in place), no excavation and
subsequent backfilling of treated soils will be necessary. The
in-situ vacuum extraction will be used to remove VOCs from
contaminated soils above the water table. VES is a relatively
new technology that has been demonstrated at the Groveland Wells
Superfund Site in Groveland, Massachusetts. It is described
briefly, below.
A vacuum pump extracts subsurface organic contaminants as vapors
through perforated pipes buried just above the water table. A
vacuum is developed within the soil matrix in order to induce air
and contaminant flow through the pore structure. As soil gas
migrates through the pore spaces, mass transfer between the
trapped residual unsaturated .contamination and the air occurs,
releasing the contamination. This facilitates contaminant
removal without soil excavation. Reports indicate significant
quantities of contamination can be removed in this manner in a
relatively short time frame.
Vacuum extraction is classified as an active vapor collection
system. It consists of vapor extraction wells, vapor collection
headers, vacuum blowers or pumps, and vapor collection
(condensers) and/or vapor treatment (carbon adsorption)
equipment.
Two areas at the site will be subject to the vacuum extraction
system. The depth to ground water in these areas varies from 15
feet at the northeast corner of the NHBB facility to 7 feet in
the area near well GZ-105. A maximum area of 7500 square feet is
estimated for vacuum extraction. This area will be confirmed
through additional soil sampling during a pilot plant study stage
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34
systems are installed, the ground water depth will drop, allowing
for improved efficiencies. Although the length of time for
treatment is dependent upon extraction efficiency and actual soil
areas to be treated (both of which will be further defined during
the pilot plant study stage), the FS estimated that the VES could
attain target levels after two years of operation. Continuous
monitoring of the off-gases will occur to evaluate the
effectiveness of the technology.
This alternative is expected to require relatively little time to
implement. Several vacuum wells can be completed by a single
crew in a day and collection piping and mechanical equipment can
be installed concurrently. No soil excavation- is required.
Vapor extraction can be started upon completion of the system and
immediate removal of contaminants realized.
The extracted gas will contain high levels of volatile organic
compounds (VOCs) and moisture. Moisture will be removed by a
sloping header followed by a water cooled condenser to remove any
remaining moisture and some VOCs. Water for the condenser will
be supplied by the ground water treatment system recommended for
the management of migration alternative. Moisture collected in
the condenser will be returned to the ground water treatment
system for treatment. The system provides a high degree of
flexibility. Valve adjustments enable the operator to maximize
(or,minimize} flow from an area. Flow adjustments are made
initially so that most of the extracted flow is from the area of
highest contamination: As concentrations are found to decrease,
adjustments can be made so that most of the flow is directed
toward areas having the highest contaminant levels. An activated
carbon canister or other pollution control device will be used to
clean the air stream before it is discharged to the atmosphere.
b.
SD #5 Excavation and/or Dredging with Dewatering of
Sediments and Off-Site Disposal
This remedy will remove sediments in the wetlands contaminated
with PCBs at levels greater than 1 ppm or with PARs at levels
greater than 1.1 ppm, estimated to total 1170 cubic yards. The
excavated sediments will be dewatered, placed in containers, and
transported to an off-site, licensed RCRA landfill for disposal.
While PCBs and PAHs have been found in the top six to twelve
inches of sediment in this area, approximately 15,800 square feet
area of sediments would be dredged/excavated to a depth of two
feet to ensure complete removal of contamination. Contaminated
sediments are located in an area of water table fluctuation, 50
that they are at times saturated while, at other times, above the
water line. For this reason, sediment removal may take the form
of either excavation or dredging.
Since it was determined that wetland sediment contamination was
at a level which posed an unacceptable risk to human health and
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35
risk. No practicable remedia~ion alternative exists which would
not include construction in the wetlands, however. Therefore,
the remedy in the wetlands will be undertaken in such a manner to
avoid or minimize the destruction, loss and degradation of site
wetlands and to preserve and enhance the natural and beneficial
use of wetlands. The work will be performed during low water
periods to minimize the need for dredging and the associated
potential spread of contaminants to other portions of the
wetlands. Controls will be used to isolate the contaminated
wetlands and to minimize res1:spension and downstream transport of
the pontaminated sediments. During excavation, monitoring will
be conducted in the area and downstream to determine whether
unacceptable contaminant transport is occurring.
c.
Wetlands Restoration
Following the completion of remedial activities in. the wetlands
to excavate contaminated sediments, a wetlands restoration
program will be implemented. The wetlands restoration program
will be designed to return the affected wetland areas to their
original conditions, to the maximum extent practicable. Clean
fill material will replace the contaminated sediments removed in
this component ot the. remedial action. The fill will be placed \
such that ground surface contours are returned to those which
existed prior to the excavation/dredging so as to maintain the
original hydrologic flow patterns. The wetlands will be
revegetated with appropriate wetland plants in order to minimize
erosion and to provide habitat for indigenous wildlife with a
program of transplanting, seeding or some combination thereof.
The remedy includes monitoring of the wetlands, and continued
restoration activities until the objectives of the wetlands
restoration program have been achieved.
d.
GW '9 Groundwater Extraction and Treatment with Air
stripping and Carbon Columns for Air Emission Control
This component of the remedy will extract groundwater from the
NHBB area plume (including the GZ-4 area plume) and the dilute
plume. The extracted water will be treated on-site with air
stripping to reduce contaminant levels to drinking water
standards,. and the treated water will be discharged to
groundwater on-site. The groundwater extraction/discharge system
for the NHBB area will be designed so as to provide a hydrologic
barrier between groundwater in the NHBB area and groundwater in
the rest of the aquifer; the groundwater extraction system for
the dilute plume area will be designed so as to provide a
hydrologic barrier between groundwater in the dilute plume and
the South Municipal Well.
The NHBB area groundwater extraction system will consist of
conventional extraction wells, located in the vicinity of the
northeast corner of the NHBB building and pumping at a total rate
of approximately 200 gpm. The extraction system for groundwater
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36
wells, pumping at a ~~te of approximately 400 gpm. The dilute
plume extraction wells will be placed so as to withdraw
contaminated groundwater that has migrated from the NHBB area.
Contaminated groundwater extracted by these two extraction
systems will be treated on-site by air stripping to reduce
contaminant levels in the treated water to the groundwater target
cleanup levels. Gr~undwater from the NHBB area will first pass
through a phase sep; ration settlement tank/pretreatment system
where dense nonaquel us phase liquid (DNAPL) could separate from
solution prior to a~r stripping. DNAPLs in this tank would be
drained off periodi,~ally for recycling or disposal. Water which
has passed through \~e phase separation or which is drawn from
the dilute plume arEa will be treated by one or more air
stripping systems capable of discharging effluent which will meet.
state of New Hampshire groundwater discharge limits. The
treatment system or systems will consist of stripping towers,
holding tanks, and transfer pumps to cycle water through the
system. Water treated by the air stripping system will be
monitored during the groundwater treatment operation to ensure
that 'the treatment system is effective. Treated effluent will
then 'be pumped to two infiltration trenches. The first
infiltration "trench will be located upgradient of the extractio~
wells for the NHBB area to enhance contaminant removals in that
area. A second infiltration trench could be installed between
the dilute plume and the South Well to provide a more positive
hydraulic barrier. It is likely that a portion of the treated
flow will be discharged to the Contoocook River. The discharge
point or points wi~l be determined in the design phase.
EPA estimates that the extraction and treatment systems will need
to operate for 13, 19, and 7.5 years for the NHBB area, GZ-4
area, and dilute plumes, respectively, in order to achieve the
groundwater target ~leanup levels in all parts of the aquifer.
Therefore, the point of compliance for determining whether the
groundwater target cleanup levels have been achieved is anywhere
in the aquifer.
As discussed above in Section X.A.l.c, the extraction rates and
the aquifer restoration times described here are estimates
calculated with models. During the design of the groundwater
extraction/treatment system, actual field data will be developed
and used to refin~ the modelling results and to determine the
optimal rate for extracting and treating groundwater.
Also as noted, the presence of DNAPLs in the NHBB area may
lengthen the time necessary to meet target cleanup levels for
groundwater located near the NHBB area. As the time estimates
for aquifer restoration indicate, the remedy is expected to reach
target cleanup levels in the dilute plume area before groundwater
in the NHBB area is remediated. This remedy will continue to
extract and treat groundwater in the NHBB area until the cleanup
targets are achieved in all locations. To account for the
different tr~atment periods, the extraction systems will be
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37
area and the rest of the aquifer so as to prevent the migration
of contaminants away from the NHBB area. The hydrologic barrier
will permit the use of groundwater in the aquifer while the
remedy continues to pump and treat contaminated groundwater in
the NHBB area.
e.
Long-Term Environmental Monitoring
A groundwater monitoring program will be developed for the
following purposes: '.
.
to determine the reduction of contami~ant
concentrations over time;
to evaluate the effectiveness of the remedial action
and attainment of the groundwater ta~get cleanup
levels; and .
to ensure that the groundwater contaminant levels in
treated effluent do not exceed target cleanup levels.
.
.
.
The details of the groundwater monitoring program will be
deveioped during remedial design and tailored to the specifics of
the design. Performance monitoring will be implemented .
consistent with 40 C.F.R. ~ 264.100(d), which requires
implementation of a monitoring program to assess the
effectiveness of a corrective action program. Groundwater
monitoring wells may need to be installed in order to ensure that
the objectives of the monitoring program are achieved. Selected
wells will be monitored on a periodic basis throughout the
implementation of the remedy. Groundwater will be monitored
quarterly in both the NHBB area and the dilute plume area. All
samples will be analyzed for VOCs. Specific analysis parameters
may be added or deleted depending on sampling results and
observed trends.
All monitoring data will be reviewed and evaluated during the
implementation of the remedial action to ensure that response
objectives are achieved. Adjustments to the extraction and
treatment systems will be implemented to optimize treatment and
restoration. Modifications to the remedial action will be
considered if the monitoring program shows that the groundwater
will not attain the target levels within the period of time
specified in this remedy or that remedy is not adequately
reducing risks to human health and/or the environment that are
posed by exposure to site contaminants.
To the extent required by law, EPA will review the site at least
vnce every five years after the initiation of the remedial action
at the site if any hazardous substances, pollutants, or
contaminants remain at the Site, to assure that the remedial
action continues to protect the human health and the environment.
EPA will also evaluate risk posed by the site at the completion
of the remedial action (i.e., before the site is proposed for
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Institutional Controls, Inclu~ing Restrictions on Use
of the South Municipal Water Supply Well
Since remediation of contaminated grou~dwater will require
several years for completion, this remedy includes institutional
controls designed to ensure that groun~water in the zone of
contamination will not be used as a drinking water source until
MCLs are met. EPA will work with the state and the Town of
Peterborough to restrict the use of tIe South Well and prevent
installation of private wells which mj3ht draw in contaminated
groundwater. The extent of restricticns (up to and including
prohibition of use) placed on the use of the South Well is
dependent upon the final design of t~~ dilute plume extraction
system and therefore must be developed in close coordination with
the remedial design.
f.
B.
Rationale for Selection
The rationale for choosing each selected alternative which is a
part .of the selected remedy is based on an assessment of each
criterion listed in the evaluation of alternatives section of
this document. In accordance with Sec~ion 121 of CERCLA, to be
considered as a candidate for selection in the ROD, the \
alternative must have been found to be protective of human health
and the environment and able to attain ARARs unless a waiver is
invoked. In assessing the alternatives that met these statutory
requirements, EPA focused on the other evaluation criteria,
including: short term effectiveness; long term effectiveness;
implementability; use of treatment to permanently reduce the
mobility, toxicity, and volume; and cost. EPA also considered
non-technical factors that affect the implementabi1ity of a
remedy, such as state and community acceptance. Based upon this
assessment, taking into account the statutory preferences of
CERCLA, EPA selected the remedial ap~roach for the site.
.L.
Soil
In-situ vacuum extraction, which was Alternative SL #7 in the FS
and the Proposed Plan, represents the best soil remediation
alternative when evaluated against the criteria and compared to
the other soil remediation alternatives evaluated. This
alternative is protective of human h~alth and the environment and
meets ARARs; reduces the toxicity, mobility and volume of the
contaminants; is implementable; has community and State
acceptance; and is cost-effective.
Other alternatives were considered less acceptable for the
following reasons. Alternative SL #1, No Action, does not
address risks associated with direct contact or from continued
migration of VOCs into the groundwater. All of the other
alternatives would achieve those remedial action objectives.
is not protective and does not achieve ARARs.
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The selected remedy will be more implementable than the
alternatives which required excavation of the soils, followed by
on- or off-site treatment or disposal. Remediation of
contaminated soils under and in close proximity to an operating
industrial facility presents special implementation problems
related to maintaining the structural integrity of the building.
In addition, the costs of the remedial alternatives involving
excavation were higher than the selected remedy, but would
provide no greater degree of protection or permanence.
The single advantage presented by the excavation alternatives is
the greater certainty of long- and short-term effectiveness in
meeting soil target cleanup levels at the site that landfilling,
incineration, and mechanical aeration afford. However, EPA
-believes that vacuum extraction can attain the target levels in
soil and, therefore is effective in the long- and short-term.
Yet, there is some degree of uncertainty that this innovative
technology can achieve site-wide reductions to the very low
levels established in this remedy. Therefore, this remedy
includes continued evaluation of the effectiveness of vacuum
extraction in meeting the target levels, and provides that
additional remedial approaches will be evaluated if experience
during the remedial action indicates that the remedy is not
protective. However, this remedy provides that the vacuum
extraction system will continue to operate, even if the target
levels are not attained in two years, until another remedy is
selected. Another factor that may affect considerations on the
effectiveness of vacuum extraction is that during the design of
this component of the remedy, additional soil and aquifer
characterization may support a recalculation of the model that
was used to establish the soil target cleanup levels. An
increase or decrease in target levels, as well as experience
gained during design of the remedy, may affect considerations
whether vacuum extraction continues as an element of the remedy.
After considering the technical complications from implementing
soils excavation, and the related increase in remedial costs,
with no in~rease in protectiveness, SL #7 is preferred over
alternatives which would require soil excavation (Alternatives SL
#3, SL #5, and SL #6).
The other alternative evaluated which would not require
excavation, SL #8, In-situ Soil Flushing, would require
approximately thirty years to reach the target cleanup levels,
while the selected alternative is expected to take approximately
two years. The selected remedy will reduce contaminant levels
sooner, so that the soils will not continue to be a source of
groundwater contamination, and therefore ha~ greater short-term
effectiveness. In addition, SL #8 is estimated to cost more than
the vacuum extraction system, which is related in part to the
extended remediation time, but the alternative does not provide a
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40
~
Sediments
Disposal of Contaminated Sediments at an Off-site Landfill, the
selected remedy for remediating contaminated sediments
(Alternative SD #5 in the FS and the Proposed Plan) represents
the best wetlands remediation alternative when evaluated against
the criteria and compared to the other options which were
evaluated. The selected alternative is protective of human
health and the environment and meets ARARs; is effective in the
long and short terms; is implementable; and has State and
commnnity acceptance. While this alternative does not reduce the
toxicity or volume of contaminants, containment of the excavated
sediments will reduce the mobility of the contaminants. Although
the selected remedy is not the least costly alternative
evaluated, the excavation and off-site disposal is the most cost-
effective approach because it is. a protective remedy for which
the costs are proportionate to its effectiveness.
Other alternatives were considered less acceptable for the
following reasons. Since Alternative SD #1, No Action, does not
address risks to humans nor environmental receptors, it is not
protective and would not attain the remedial objectives.
Alternatives SD '#3 and SD #4 both involve- capping the \
contaminated sediments, effectively destroying the wetland areas
that are capped and thus, result in non-compliance with ARARs for
wetland protection and floodplain management. In addition, the
contaminants would remain in place, thereby leaving a potential
exposure point for the long term should the capping systems fail
and require long-term management. Alternative SD #7, On-Site
Incineration, while providing for the treatment of the
contaminants, the small amount of sediments needing treatment is .
likely to limit the availability of the technology and affect the
short-term effectiveness of the alternative. While the FS and
Proposed Plan indicate that on-site incineration is somewhat less
expensive than the preferred sediment alternative, its cost was
based upon incineration in conjunction with soil incineration, an
alternative rejected because of cost and implementability
considerations previously described. On-site sediment washing,
SD #8, was rejected because the higher costs would not produce a
proportionate degree' of effectiveness due to the uncertainties of
the effectiveness of this technology to treat Site contaminants.
L.
Groundwater
Alternative GW #9 from the FS and the Proposed Plan, Groundwater
Extraction and Treatment with Air Stripping and Carbon Columns
for Air Emission Control, represents the best groundwater
remediation alternative when evalu~ted against the criteria and
compared to the other alternatives. The selected alternative is
protective; is effective in the long and short terms; reduces the
toxicity, mobility, and volume of contaminants; is implementable;
has community and State acceptance; and is cost-effective.
Finally, the selected remedy will achieve restoration of the
aquifer to drinking water quality in the shortest period of time.
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following reasons. . Alternative GW #1, No Action, "does not
address risks to humans nor environmental receptors and was
rejected from further consideration. GW #3 and GW #4 are
essentially the same as the preferred alternative but with a
longer cleanup time for the dilute plume portion of the
contamination. The estimated costs of implementing GW #3 and
GW #4 are higher than the costs of the selected remedy, primarily
because operating the pump and treat systems fora longer period
will result in increased costs.
Alternatives GW #6 and GW #7 do not address the environmental
risks posed by the contamination in the aquifer and do not
restore the aquifer to drinking water quality, thus failing to
attain ARARs or the remedial objectives. While each would
provide a safe water supply, neither provides for long term
protectivell~ss to public health or the environment. GW #8 is
similar to GW #3 and GW #4 in terms of environmental impacts and
the rate of aquifer restoration but uses a different groundwater
extraction system, a radial well collector system. However, the
cost ,of ~his system is greater than the selected remedy without
providing a faster rate of restoration or a more protective
remedy. In addition, application of this technology in "
remediating hazardous waste in groundwater is untested and may \
not be implementable. "
XI.
STATUTORY DETERMINATIONS
The remedial action selected for implementation at the" South
Municipal Water Supply Well Superfund site is consistent with
CERCLA and, to the" extent practicable, the NCP. The selected
remedy is protective of human health and the environment, attains
ARARs and is cost effective. The selected remedy also satisfies
the statu~ory preference for treatment which permanently and
significantly reduces the mobility, toxicity or volume of
hazardous substances as a principal element. Additionally, the
selected remedy utilizes alternate treatment technologies or
resource recovery technologies to the maximum extent practicable.
A.
The Selected Remedy is Protective of Human Health and
the Environment
The remedy at this site will permanently reduce the risks
presently posed to human health and the environment by exposure
to contaminated soils, sediments, and groundwater.
The soil cleanup levels to be attained by this remedy are
designed to prevent migration of contaminants into the
groundwater at levels which exceed drinking water standards.
Preventing further contamination of groundwater at unacceptable
levels will also expedite restoration of the aquifer. When
contaminant levels reach the soils target cleanup levels, the
risks associated with dermal contact and accidental ingestion are
protective of human health.
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risks to the wildlife which inhabit the area as well as reducing
the risks posed to humans through dermal contact and accidental
ingestion. Containment of the contaminated sediments in an off-
site landfill meeting RCRA requirements will protect humans and
environmental receptors from the threat of contact or
bioacculation. ..
Thf:: selected ground water remedy will significantly reduce the
rifks of ingestion of contaminated groundwater by treating
grtJundwater throughout the affected portion of the aquifer to
dr:i,nking water standards, which are ARARs at this Site. This
~e~~dy will achieve these protective drinking water standards in
the shortest period of time of any of the alternatives that were
evaluated. In addition, treatment of the air stream will prevent
exposure to the removed contaminants by inhalation.
Inbtitutional controls will ensure that no exposure to the
contaminated groundwater will occur during the implementation of
the selected remedy. This combination of elements results in a
.remedy which is protective of human health and the environment.
'B.
The Selected Remedy Attains ARARs
This remedy will meet or attain all applicable or relevant and \
appropriate federal and state requirements that apply to the
Site. Environmental laws from which ARARs for the selected
remedial action at the South Municipal Water Supply Well
Superfund Site are derived include:
Resource Conservation and Recovery Act (RCRA);
Clean Water Act (CWA);
Safe Drinking Water Act (SDWA);
Executive Order 11988 (Floodplain Management);
Executive Order 11990 (Protection of Wetlands);
Fish and wildlife Coordination Act;
Clean Air Act (CAA);
O=cupational Safety and Health Administration (OSHA);
S~ate Superfund Laws; and
State Hazardous Waste Facility Laws.
The following policies, criteria, and guidances have also been
considered (TBCs) during the selection of the remedy:
SDWA Maximum Contaminant Level Goals (MCLGs);
CWA Ambient Water Quality Criteria;
OSWER Directive 9355.0-28, Air Stripper Control Guidance; and
State Drinking Water Criteria and Consumption Advisories.
Chemical- and location-specific ARARs are found in Tables 3-1 and
3-2 of the Feasibility Study, respectively. Action-specific
ARARs are presented in the Feasibility Study in Tables 5-1 and
5-2. These tables (included in Appendix B) provide a brief
synopsis of the requirements and indicate whether the ARAR is
~pplicable, relevant and appropriate, or to-be-considered. A
brief narrative summary of the ARARs and TBCs follows.
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. .
Levels (MCLs) established in the Safe Drinking WaterAr.:t (40CFR
141.1 - 141.16) which has been determined to be relevant and
appropriate to the site. MCLs were used to help set the
groundwater cleanup levels, as well as, the soil cleanup levels.
The specific MCLs which are ARARs to be met include:
1,1,1-tricloroethane, 200 ppb: trichloroethylene, 5 ppb:
1,1-dichloroehtylene, 7 ppb: toluene, 2000: and vinyl ~hloride,
2 ppb. The level set for tetrachloroethylene, 5 ppb, is based
upon a proposed MCL which is considered a TBC. In addition,the
State of New Hampshire Department of Public Health Service
consumption advisories for water supplies, which have been.
determined to be a TBC, were used in the absence of an MCL for
1,1-dichloroethane in setting site cleanup levels for ~roundwater
and soil. The level to be met is 810 ppb. The Fish ~nd wildlife
Coordination Act has been determined to be a TBC for this Site
and comments submitted to EPA by the Fish and wildlifp. Service of
the U.S. Department of the Interior were used in setting PCB
cleartup levels for sediments.
With.respect to location-specific ARARs, the Executive Orders
concerning wetlands and floodplains are applicable to this site.
Since it was determined that wetland sediment contamination was
at a level which posed an unacceptable risk to human health and \
the environment, alternatives were evaluated to address that
risk. No practicable remediation alternative exists which would
not include construction in the wetlands, however. Therefore,
the remedy in the wetlands will be undertaken in such a manner to
avoid or minimize the destruction, loss and degradation of site
wetlands and to preserve and enhance the natural and beneficial
use of wetlands. Also, the remedy will be implemented in such a
manner as to maintain existing flow patterns so as not to impact
the floodplain.
In addition, this remedy was selected using EPA guidance on
control of air emissions (OSWER Directive 9355.0-28, June 15,
1989) as a TBC for the site, which is in an ozone non-attainment
area. For such an area, the directive indicates the need for
control of VOC emissions from Superfund air strippers and soil
vapor extraction systems based upon actual emission rates of
VOCs.
The principal action-specific ARARs include RCRA standards for
the treatment, storage, and disposal of hazardous wastes. These
standards are applicable to the design, construction and
operation of the groundwater extraction and treatment systems,
since those systems will be handling, treating and disposing of
hazardous waste and hazardous waste constituents. RCRA will
apply to the soil treatment alternative to the extent this
component of the remedy involves handling, treatment or disposal
of hazardous wastes.
All OSHA requirements for worker health and safety during.
hazardous waste operations and general industry standards are
applicable during implementation of this remedy.
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Groundwater Protection requirements. (40 CFR r.-'64, Subpart F) have
been determined to be relevant and appropriate for this Site.
The. groundwater monitoring program implemented will be consistent
with 40 CFR S264.100(d) to evaluate the effectiveness of the
remedy. .
C.
The Selected Remedial Action is Co:;t-Effective
Of those alternatives that are protective ari attain ARARs, EPA's
selected remedy is a combination of the most cost-effective
remedial alternative components that were e~aluated.. The remedy
provides a degree of protectiveness proportj -onate to its costs. .
The soil treatment component was estimated t.. be significantly.
less costly than the four other protective alternatives, costing
approximately 20% of the next cheapest alternative. The
excavation of sediments for off-site dispos?l is not the least
costly alternative that was evaluated. However, because the. .
selected remedy is more protective and effective in the long- and
short-terms in providing a permanent solution on-site than the.
capping alternatives, and because it can be more readily
implemented than the on-site treatment alternatives, it is the
most cost-effective alternative. As for gro'mdwater, the.. .
selected remedy is protective and is the least costly alternative
evaluated. This was due to the choice of treatment and .-
groundwater extraction technologies and to the more rapid rate of
extraction which resulted in lower operation and maintenance.
costs.
A summary of the costs for each of the elements of the seleqted
remedy are presented below. A~l costs are net present worth.
TOTAL COST OF SELECTED REMEDY
Contaminated Media
CaDital
Soil
$
327,583
O&M
$ 202,145
Total
$
529,728
Sediments
782,189
782,189
Groundwater
2,284,747
3,790,005
6,074,752
$7,387,769
D.
The Selected Remedy utilizes Permanent Solutions and
Alternative Treatment Technologies or Resource Recovery
Technologies to the Maximum Extent Practicable
The selected remedy utilizes permanent solutions and alternative
treatment technologies or resource recovery technologies to the
maximum extent practicable. A brief description regarding how
each component of the remedy meets this determination follows.
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45
sele~~edremedy utilizes an innovative treatment
technology, in-situ vacuum extraction, to permanently
reduce contaminants in soils to levels that are
.protective of human health and the environment. The
selected remedy will provide a permanent solution for
the VOC-contaminated soil by significantly reducing the
toxicity, mobility, and volume of the contamination.
The VOCs removed from the extracted soil vapor will be
treated by being adsorbed onto activated carbon, which
will be ~egenerated (and the VOCs destroyed) at an off-
site resourCe recovery facility or on-site as part of
the treatment process. While the alternatives
involving incineration and mechanical aeration would
also achieve the same degree of permanence using a
treatment technology, as noted above, these
alternatives would cost more without providing a more
protective solution.
2. Sediments. The excavation and containment of
contaminated sediments will provide a permanent
solution at the Site to contamination in the wetlands.
It provides for a permanent solution at this Site by .
removing and disposing of contaminated sediments in a \
RCRA landfill capable of insuring long-term security.
While long-term uncertainties exist with the permanence
of any landfilling alternative, the use of a licensed
RCRA minimizes these uncertainties. The two capping
alternatives, while considerably less expensive would
leave the contamination in place, thus requiring
perpetual maintenance to avoid failure of the
containment system, and allowing the potential for
future exposures to Site contaminants. Given the small
volume of sediments, the limited availability of mobile
incinerators and their extended start-up time, the on-
site incineration alternative would be practicably
implementable only if the selected soil remedial action
had been on-site incineration.
3. Groundwater. The groundwater extraction and
treatment component of the remedy will provide a
permanent solution to contamination of the drinking
water aquifer in the shortest period of time of any
alternative evaluated. Of the seven groundwater
remediation alternatives evaluated in the FS, three
alternatives were found .not to be protective nor able
to meet ARARs. These included the No Action
alternative, Well-Head Treatment, and Development of an
Alternative Water Supply. Of the remaining
alternatives, all of which were found to be permanent,
protective and able to attain ARARs, the selected
remedy attained the remedial objectives in the shortest
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The Selected Remedy satisfies the Preference for
Treatment as a Principal Element
The principal element of the selected remedy is the treatment of
groundwater and soils to permanently reduce contaminants to
levels which are protective of human health and the environment.
Groundwater extraction and treatment, used in conjunction with
the in-situ vacuum extraction system for soils, addresses the
primary threat at the Site, contamination of the groundwater.
The selected remedy satisfies the statutory preference for
treatment as a principal element by removing VOCs from the
groundwater through the use of air stripping towers followed ~~.
carbon columns. Upon regeneration of the carbon, the
contamination will have been effectively destroyed. Similarly,
the VOCs removed from the soil vapor by the vacuum extraction
process will effectively be destroyed during the regeneration ~f
the carbon.,
E.
XII. .
STATE ROLE
The New Hampshire Department of Environmental Services has
reviewed the various alternatives and has indicated its support i
for the selected remedy. The State has also reviewed the
Remedial Investigation, Risk Assessment and the Feasibility Study
to determine if the selected remedy is in compliance with
applicable or relevant and appropriate State Environmental laws
and regulations. The New Hampshire Department of Environment?l
Services concurs with the selected remedy for the South Municipal
Water Supply Well Superfund site. A copy of the declaration of
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APPENDIX A
DECLARATION OF CONCURRENCE
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State of New Hampshire
DEPARTMENT OF ENVIRONMENTAL SERVICES
OFFICE of the COMMISSIONER
6 Hazen Drive, P.O. Box 95. t:uncord, NH 03301
603-271-3503
ROBERT W. VARNEY
COMMISSIONER
GEORGE A. MOLUNEAUX. P.E.
ASSISTANT COMMISSIONER
September 20, 1989
Mr. Paul G. Keouqh
Actinq Reqional Administrator
U.S. Environmental Protection
JFK Federal Buildinq
Boston, MA 02203
Aqencv
Re:
Record of Decision
South Municipal Water Supply Well Site
Peterborouqh, NH
Dear Mr. Keouqh:
The New Hampshire Department of Environmental Services has reviewed the
above 'referenced Record of Decision (ROD) and concurs with the recommendations
therein and that the recommended alternative is consistent with the rules and
requlations of Applicable or Relevant and Appropriate State Requirements
(ARARs). Furthermore, if the project utilizes the trust fund, the state will
provide a 10 percent match and operational support for the project if state
funds are available.
GAM/RWV/TCA/jd/08440
cc: Michael A. Sills, Ph.D., P.L, DES-WMD
Carl W. Baxter, P.E., DES-WMEB
Richard H. Pease, P.E., DES-WMEB
Geoffrev M. Huntinqton, ESQ., NHAGO
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APPENDIX B
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REQUIREMENT
Table 3-1: Chemical-.)pecific ARARs
APPLICABLE OR RELEVANT
AND API)ROPRIATE
REQUIREMENT SYNOPSIS
ACTIONTOBETAKI!NTO ATTAIN ARAR
STATE. RF.QUlREMENT:
GROUNDWATER
I. RSA 149:8,III;N.H.
Admin. Code Ws Ch.4tO
P.Oll'coon of Ground
Wall:t
La. Ws 410.05(a)
.. Di54;harges to Gro\ll¥i
:Wau
I.b. Ws 410.09
Ground Water Ois-
chau t:e Criteria. incor-
po.aling by rderence:
Ws I'art 302 (Maximum
Contaminant Levels
(MCL's) and Suggested
No Adverse Response:
uvclsISNARLS\)
I.c. Ws 410.10
Addition31 ()round
Waler Criteria
Applicable
. Applicable:
Applicable:
Applicable
These: provisions regul3te discharges &0
ground waler and provide fur groood waler
Illotoclion. No subslance designated in W.
Ch. 410, or presenting a potcntial th.cat
10 health or the envirorunenl may be dis-
charged 10 ground waler so as 10 euccd waler
qualilyaile.ia.
Ws 410.05(a) prohibits discharge: of
hazardous waste 10 groood water.
Ws 410.09 establishes ground waler
discharge criteria including MCLa and
SNARLS, codiric:d al W. I)art 302, Drink-
ing Water Regulalions. Siandnnis appliqt!~e:
10 the sile: include: SNARLS for lifetime:
exposure: 10 to~ic conl3minants, Ws 302.08(a);
SNARLS for cOOlaminnnlS associAted with
cancer risk, Wi 302.0H(b); and ML:Ls,
Ws 302.02, Ws 302.04, and Ws 302.11.
1llis requiremenl provilles Ihat ground
W31er shuJl nOI be allered so as 10 rCllder
il unsuitable for drinking waler. D.inling
waler slandards include bolh Slale alld
fC(lerallllinimum requuemenLS.
The: Soulh Municipal Well Sile: muSI be
remedialed 10 pevent reluse of conlaminants
in violalion of these: provisions. See below
for discussion of specific waler qualilY
crileria pursuanito Ws Ch. 410.
Remedial action must be laken 10 eliminale: the:
\mConttoUcd dischar,e: of h8l.ll'dous waste
constituents, volalile: organic compounds
(VOCs), and inorganic contaminanLS 10 the:
ground water aquifer below the: sile.
Reme:dialaclions musl be laken at the: Soulh
Municipal Well Site to eliminale: Ihc: discharge
of conlaminants, including vae. and inorganic
contaminants, whkh result in ground waler
conlamination above Siale: MCL and SNARL
levels.
Remedial.clion must. be laken al the Sile to
eliminale discharge of conlaminants which
render the: ,round water unsuitable for drinling
waler.
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REQUIREMENT
APPLICADLEOR RELEVANT
AND AI)PROPRIATE
,..-
Table ]-1: Chemicah)pecific ARARs
REQUIREMENT SYNOPSIS
ACfIONTO DE TAKEN TO ATTAIN ARAR
STATE R":QUlREMENTS:
GROUND WATER (conl'd)
J.d. Ws 410.05(e)
Ground Waler Quality
Criteria; Health-based
GroWl.! Waler Protection
. Slar.brds
I.e. Ws 410.05(g)
Ground Waler QualilY
Criteria; Nondegradation
of Surface Waler
NIILWIIS Drinking
Waler Crileria
STATE REQUlRE~'ENTS:
SUR..'ACE WATER
RSA 149:8,1
Enforcemenl of Surfacc
Water Classificalions
Ws n. 400, Part 437
Wall" Quailly Siandlllds
Fuh Lire
Applicable
Applicable
To Bc Considered
Applicable
AI'Plicable
Under this requirement, ground waler
sh.1I nol comain any subslance which the
Waler Supply and Pollulion Conlrol Divi-
sion (WSI'CD) delermines may be harm-
folio human heallh or the envirolUnent.
Ws 410.05(g) provides that ground
wOller qualily shall not be del.'Tadcd such
thai il results in a violation of surface
waler slandlU'ds in any swface waler body
in or adjacent 10 the s ile.
11lese crileria are used by the NIIDPIIS as
a basis for consumplion advisories for
waler supplies. I,I-DCA has a criteria of
810 ppb.
This requirement prohibits the disposal
of wasles in such a manner as will lower
the qualily of any surface waler below the
rninimtun requirements of the swface
waler classificalion. Standards applicable
t.\llhe Soulh Municipal Well Sile are
slwuJards for the preservalion of Class n
walers.
11lis requiremem provides Ihal Slale slllface
walcrs shwl be free from chemicals or
condilions harmful 10 fish life. --
Remedial actions musl be laken to eliminate
discharges of substances which may be harm-
fullo human health or the environmenl. 1ltis
may include substances exceeding the cancer
risk health advisory limits established by Ihe
Nil Division of Public Health Services.
Remedial action musl be taken to eliminale any
discharge to ground water resuhing in violation
of surface waler quality at adjacent surface
walers, including the unnamed onsile brooks, the
ConloOCook River, Noone Pond, and the wellands.
1l1t NHDPHS criteria should be considered in
eSlablishing clean-up goals for contaminaled
groundwater.
Discharge or treated water to swface walers
as pari of any remedial allernative must comply
with this requiremenl.
Remedial actions which include discharge of
Irealed waler to surface waler must comply
with this requirement.
,
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REQUIREMENT
Table 3.1: ChemicI.-,,)pecific ARARI
APPUCABLEOR RELEVANT
AND AI'PROI'!UATE
REQUIREMENT SYNOPSIS
ACTION TO BETAKEN TO ATTAIN ARAR
STATE REQUIREMENTS:
SURIo'ACE \VATER (cont'd)
Ws Ch. 400, Part 439 .
An'id~gradation Policy
STATE REQUIREMENTS:
AIR EMISSIONS
RSA Ch. 115-C, Air
Pollution Conllol; NH
Admin. Code Air Ch. 100
Paris 604.606; 1002
FEUERAL REQUIREMENTS:
GROUND WATER
40 CFR 14L1 1-141.16
Safe Drinking WalJ:r Act
(SOW A) Maximum Con-
taminlU\t Levels (MCLs)
40 CFR 264.94
M(~""lce Coruuvllion
.1~IIt(co"(ry ACI (RCRA)
Mu.mwn ConcenUllion
LIIIIIU
Appliclble
Ws Ch.400, Part 439 establishes the sll,e
policy Iglinsl degradation of eaisting wllJ:r
quality, IJId require, proteclion of in-
5uenm beneficial uses.
"pplicable
This requirement establishes IIandards
for the release o( air emissions, includinS
VOCs arllJ huardoul air pollulams.
Appliclble
SDW A MCLs arc enforceable slandnrds
which hive been deyeloped (or 30 IOllie
compounds for public drinking waler sySlems.
MCLs reneci both heallh faclOrs IU\d tcch-
nicul and economic (ensibililY of removins
Ihe conlarninant from the waler supply.
Soulh Municipil Wells Sile conlaminlU\ls
for which MCLs have been promulj;alcd
inclut.!e I,I-OCE; I,I,I-TCA; IU\d TCE.
RCMA Mallimum Concenlralion Limils are
51B11dlllds for 14 tOllic compUlU\ds, primarily
1m IC melDls ant.! pcslicidcs, Idopl"\ as 1'1111
of MCRA j;IOIiOO waler prolccJi!>n slW1(liuds.
Remedill altemaLiycs which include dischnrge
o( b'eated Wlter to lur(acc wlters must comply
with this policy.
Actiona mlY be required 10 p'eyent unpermiued
lir emissions (rom the lite, parlicularly during
implementation of remedial allematives
involving eaclvllion.
Reff\ediallctions must be implemenled It the
Sile 10 rcduce contaminant concenllilions in
ground wlter 10 MCLa.
Conlaminanu found in NHOO ground willer are
not regulltoJ by RCRA MCLs.
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REQUIREMENT
APPLICABLE OR R ElEV ANT
AND APPROPRIATE
.........-:-- .
Tlble 3-1: ChemicII-.)pccific ARARs
REQUIREMENT SYNOPSIS
ACTION TO BE TAKEN TO ATTAIN ARAR
"'EUERAL REQUIREMENTS:
. GROUND WATER (conl'd)
40 CFR 141.S0-14t.S1
SOW A MCL GOlls ..
nmERAL REQUIREMENTS:
SURFACE WATER
PL 92.500 Sectior.s
301.302.303 and 304
Clean Wiler Act (CWA)
Waler Quality Crileril
for Proleclion of Human
Health
PL 92-500 Sections
301. 302, 303 and 304
Clean Wlter Act (CWA)
Ambient Wlter Qullity
Crilc,il (A WQC) for Pro-
. teclion of Aquatic Life
16 U.S.c. Suhseclion 661
CI Snt; Fish 8I\d Wildlife
CUII,dUJitIiOn Aci
To Be Considered
To Be Considered
To Be Considered
Applicable
MCL Goals arc nonenforcelble helhh goals
for public wiler syslems. The EPA has
promulglted MCL Goals for 9 conlaminanu.
including 1,I-DeE; I,I.I-TCA; Ind TCE which
lie found It the South Municipal Well Site.
Waler Qual.ty Crileril (WQC) are non-
enforceable guidance developed Wkler the
CW A. used by the IIlle, in conjunclion with
I designlled use for I sirewn segment. 10
eSlablish Wiler quality standards. WQC
levels for protection of human heallh from
consuming aquatic organisms hlfimurily
fi~h) hive been developed for PERC. TCI!,
loluene and I,I,I-TCA.
A WQC for prolection of Iquatic organisms
have been set for 1.I-DeE, PERC. TCE
and IOluene.
1l.is act requires ICiion to protect fish and
wildlife from aclion modifying slIeums or
Ileas affecling slleams.
U SOW A MCLs do not provide sufficient pro-
tection to human and environmental receptors,
MCL &oals should be considered in establishing
health-based standards.
Ground Wlt'=r r"medial Ihemltives which
include ulM-..arge of Ireuloo WilL" UIlO swface
wIU:rs must take this guidance into considerllion.
Groundwlter remedill alu:mltives which in-
clude discharge of treated wlter into surfoce wlten
must take A WQC into considerltion.
The selected remedy must be implemenled in
accordance with any IClions rcquiroo by the U.S.
Deparlment of the Interior's Fish and Wildlife
Service and the Stale of New Hampshire, which
oversee: administration of wildlife rCSOUlCl"
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Table 3-1: Cbemicat-.)pecific ARARs
REQUIREMENT
APPUCABLE OR RElEVANT
ANO AI)I'R(>I'RIATE
t REQUIREMENT SYNOPSIS
AcrlONTOBI!TAKENTOATIAIN ARAR
FF.OF.RAL REQUIREMENTS:
AIR EMISSIONS
42 USC 7401, Clean Air
ACI; 40 CFR pl.SO,
Nalional Ambient Air
Quality Standuds (NAAQS)
NAAQS ale enforced through slale regula.
lions. See NH RSA Ch.12S-C above.
A blank in the -Applicable or Relevant and Appropriate- column indicates Ihalthe requirement is neither applicable nor relevanl and appropriate at the site.
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REQUIREMENT
Table 3-2: L.ocation-.Jpecific ARARs
..-
APPLICABLE OK KELEV ANT
AND AI'I'IWI'IHATE
REQUIREMENT SYNOPSIS
ACTION TO BE TAKEN TO A IT AlN ARAR
STATE R.:QUIREMENTS:
WETLANDS
RSA 149:8-a,
Dredging and ConlJol
o( Run-O((; WI Ch.
400 Part 4 IS,
Dredging Rules
RSA Ch. 483-A,
Flllilfid Dredge in
Wetlands; and
Ws Ch. 300, Criteria
and Conditions
FEUERAL REQUIREMENTS:
WETLANDS
Clean Water Act (CWA)
Secliun 404; 40 CFR
part 230; 33 CFR
parIS 320-330
EO 11990
Wellands Eaeculive
0n.Icr
J
~ I .
Applicable
Applicable
Applicable
Applicable
These requirements establish criteria (or
conducting any activilY in or near llate
lur(ace waten which significanlly allers
teRain or may otherwise adversely aHcct
waler qualilY, impede nalural runoH or
creole unnalural runoff. This includes
'ucavation, dredging. and grading o( IOp-
soil in or near wellands arellS.
These requirements regulale filling and
olher activilies in or adjacent 10 wetlands.
They establish criteria (or Ihe protection.
o( wellands (rom adverse impocts on fish,
wildli(e, commerce and public recrealion.
These requirements prohibit the discharge
()( dredged or fill mllterial inlO wetlands
without a pennil.
Under !his regulation, foder-I agencies
arc required 10 preserve and enhance
natural and beneficial values o( wetlands,
and to minimize thc destruction and loss
or degradation of wetliUlds. .
Any remedial alternatives involving
dredging and/or CJlClvation in or near !he
wetlands on the NUDB site must wmply
wi!h these requirements.
Any remedial IClivitic.t in or adjacent to
. wetlands on the NIIDB site must comply
wi!h !hese rcquire~ents.
Wetlands are located in and adjacent \0 the
Sou!h Municipal Well Site. Remedial
activities on the site must comply wi!h
!hcsc criteria (or the discharge o( materials
into !he wetlands.
~ «'. 'x.~a .c~.:~'~": 8r.lion will be
undertaken in such. manner 10 avoid
or minimize the destruction, loss and
degradation of Site wetlands and to pre-
serve and enhance the nlJlural and bene-
ficial use of wetlands.
.
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REQUIREMENT
Table 3-1: lDcauoh-..pc:cifie ARARI
APPUCADLE OR RELEVANT
AND APPROPRIATE
REQUIREMENT SYNOPSIS
ArnON 1'0 BETAKEN TO ATTAIN ARAR
FEDERAL REQUIREMENTS:
WETLANDS «(ORI'd)
40 CFR pul 6,
AppendU A
"'EDERAL REQUIREMENTS:
"'LOODPLAINS
40 CFR 2M.18(b)
Resource ConsCfllation
alld Rcrovery ACI
(KCRA) Location
Swndlllds
EO 11988
Floodplains EJlecu-
tive Order
40 CFR 6, Appendix
A
. To Be Considered
40 CFR part 6, AppcndiJl A conl8ins Ihe
EPA policy ror carrying OUI!he provisions
or EO 11990. The policy involves !he con-
IlJUClion or racililies and the managemclIl
or properly in wcliluliis 10 avoid adverse
crrecls, minimize 1IIIIeniialluuffi, aoo
preserve and enhance wCllands 10 !he u-
lenl possible.
Applicable
The RCRA toealion standards include !he
requiremenls ror consllUcling a RCRA
rllCililyon . IOO-yelU' floodplain.
Applicable
Under !his requirement. rcderal agenda
arc required 10 reduce !he risk or nood
loss, 10 minimize impaci or noods, and 10
reslOre and preserve Ihe nalwal Uld
beneficial value or noodplains.
To Be Co~idcrcd
40 CFR 6, AppcndiJl A conlains!he EPA
policy ror clIlT)'ing OUllile provisions or
EO 11988.
RemediallCtivilies on !he lile musl comply
wi!h !heae requiremaus 10 preserve and
prolecllhc onsile and near-lile wellands
10 the Ulenl possible.
The Sou!h Municipal Well Sile is localed
on I loo-year floodplain. Any racililY
conslruClcd on !he lile muSI mee! !hese
RCRA location rcquircmenlS.
RemediallClivities will be undcrlalten
in luch I manner 10 reduce lIle li~k or
flood 1051, minimize !he impacl or noods,
UldlO rcstore and prcserve lIle nBlwal and
beneficial value or noodplains.
Remedial ahemalives musl comply wilh
this E"A policy 10 !he Ulenl possible.
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.-'"
Table S-I: Actio..-':;pccirlC ARAKI
Requirement No Action Grotmd WaJa Excavalion/Dredg- Excavation/Dreds- In-SiN In-Silu Soil Cappin&
OWN I, GWN7. EXIJilClioll, Trcat- ing " Off-Sile ing " On-Sile V IlCUwn Washing 50.0, .4
SUlI, SOli I mCIII and Disposal Disposal .Treatment EXlJlCtion SLII8
GW.J, 14, 116, SUJ, SOliS SUS,I6 sun
118, U9 50111,18
STATE REQUIREMENTS:
HAZARDOUS WASTE I
I. RSA Ch. t47-A, A A A A A A A
Ncw lIampshire lIazud-
ous Wasle Management
ACI; N.H. Admin. Code
Ue.p Ch. t90S.
L lIazardous Wasle A A A A A A A
Facility Secunl)'
HcquiremenLS, He-P
1')()S.08(d), incorpor-
IlIlIg by reference
40 CFK 264.14.
b. General Inspection A A A A A A A
KcquiremellLS, He-P
1905.08(dX4Xd)
incorporating by rer-
ercllce 40 CFR 264.~J.
c. Personnel Training, A A A A A A A
Uc-P I90S.08(d)(4)(e)
incorporaling by refer-
ellce 40 CFR 264.16.
.C;W'1, Development of an alternlte wlter lupply, will lIot in iuelf lake IllY direct IClion to Ireat cunent contamination. It is therefore included in the No Action cllegory here.
,
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Table ~-I; Action-;)pccific ARARs
Requiremenl No Action Ground WalU EJlclvaUonJDrcdg- EJlc.v.tio~cdg- . In-Situ In-Situ Soil C.pping
GWII, GWtl1. EJluaction, Trcllt- ing &. Orr-~ite ing &. On-Site V ilCuwn Washing SOU, 114
SUI, SOU ment and Disposal Disposal 'Tn:8unenl' Ellttaction SUl8
GWIIJ, '4, '6, SLIJ, SDtlS SLtlS, "6 SUI1
'8,'9 5DII1, .ft
ST AT"; REQUIREMENTS:
IIAZARDOUS \Y ASTE (cont'd)
d. Location Standards, A A A A A A A
tic-I' 1905.08(d)(4)(g)
incorporating by rder.
ence 40 CFR 264.18 and
tic-I' 1905.08(2)j.
e. Preparedness and A A A A A A A
Prevention Requirements,
lie-I' 1905.08(d)(4)(h)
incorporating by rderence
40 CfK 264, Subpart C.
f. Contingency Plan, A A A A A A A
lie. I' 1905.01l(d)(4)(i)
incorporating by rder-
ence 40 CFK 264. Sub-
pari O.
g. Groundwater Protcction, A A A A A A A
lIe.I' 1905.08(d)(4)(j)
incorporaling by rder.
ence 40 CFR 264, Sub-
pari F.
h. Closure and 1'051- A A A. A A A A
Closure, Ile.P
19H'I OIl(d)(4)(k)
u'('IlIl'o(1l1og by rder. '
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-'.
T.ble S-I: . AcLio"-.)pcciflC ARAR.
RequiJemenl No AClion Ground Waler EllcavalionJDrcdg. Ellcavaa.io~edg- In-Situ In-Silu Soil Cappin.
aWl I, awn. EXlIlIClion. Treal- ing & Off-Sile ing& On-Sile Vacuum Washing son. 114
SUI, SOIl menl and Disposal Disposal . TreallncrII EJllJacLion SU8
OWNJ.II". N6. SUJ, SOliS SU5,II6 SU1
118, NI) 50111.118
STATE REQUIREMENT:
IIAZAHDOUS \V ASTE (Coni-d)
i. TrlU\5fcr of Facilily. A A A A A A A
1Ic:-P 1905.08(1.1)(5).
j. Moniloring. A A A A A A A
lIe-P 1905.08(d)(6).
Ie. Public NOlificalion R4:A R&A R&A R4:A RitA R4:A R&A
Plan. He-P 190.5.08(d)(9).
I. General EnviJonrnenlal A A A A A A A
Slanl.lards. He-P 1905.08
(1.1)( I).
m. General Design Sian. A A A A A A A
duds, He-P 1905.08(1.1)(2).
n. Technical Sianduds A A A RitA RitA A
(or lanlIfilis. "e-P
1905.08(f)(I)(f)
incorporaling by refer-
cnee 40 CFR 264, sub.
pari N. and 1Ic:-P
190~i.08(f)(2)(d).
o. Adl.lilionol Technical A A A A A
SlDndards for Trcallnem ,
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.-'
Table S-I: Aclion-"JXCiflC ARARs
RcquiJemenl No AClion GrowxJ W BIer EJlC8V8lion./Orcdg- EAcDvalio~edg- In-Situ In-Silu Soil I 'uppin!
GWII,GWII1. EJllJacliun, Treal- ing '" Off-Sile ing '" On-Sile Vacuwn Washing :, UN), M4
SLlI, SOli I mcnland Disposal Disposal :r rcallneQI EXIr8Ction SLII8
GWn, 114, 116, SU), SOliS Slll5,116 SLII1
ilK, II') SDII7,II8
STATE REQUIREMENT:
IIAZARDOUS WASTE (cont'd)
p. Siorage Siandards A A A A A
He-I' 1905.08(f)(2)(c)
q. Tcchnical Siandards A A
(or Wasle Piles, Ife-P
1905.08(f)(I)(d)
incurporaling by re(er-
enco: 40 CFK 264, Sub-
panL
r. TcdlRicai Siandards (or A A A A A
Use and Management o(
Conlainers, lIe-P 19O5.
O!l(fJ( I >
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.-.
Table 5-1: Aclio..-.:ipcc:iric ARARs
Requirement No Action Grow\d W8Jcr ElcavationlOrc.lg- Elcavalion/Dr.cdg- In-Situ In-Situ Soil Capping
GWIII,GWM7. ExtrllCtion, Trcat- ing & orf.Site ing & On-Site VICUwn Washing SDn,M4
SUI I, SOli 1 ment and Disposal ()isposal - Treatment EXlJlCtion sua
GWMJ, 114, 116, SUJ, SDII5 SU5,II6 SU7
MH, 1#9 SDM7, 118
STATE RF.QUIREMENT:
HAZARDOUS WASTE (cont'd)
v, Packaging and Labelling A A A A A
RC'luirements, lIe-P
19\15.05, incorporating
by reference Nil Admin,
Clkle Sd.C.600 and
40 CFR 172, 173, 178,
and 179.
w. Technical Standards for A
Inl lIIentors, lIe.p 1905.08(1)(1)!,
inmrporating by reference
40 CFR 264, Subpart 0
STATE RF.QUlREMENTS:
Am EMISSION LIMITS
N.II. Admin Code Air A A A A A A A
ParIS 604-606.
Fucitive Dust Emission A A A A A A
Control, N.H. Admin.
Cllde Air Pan 1002.
'
STATE RF.QUlREMENTS:
(;lWUNO WATER
HSA 149:8,111; N.II. A A
AIJmin. Codc Ws Ch.410.
..
II
.1
,
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Requirement
STATE REQUIREMENTS:
sun FACE WATER
RSA Ch. 149; N.H. Admin.
Code W. Ch. 430.
RSA 149:4-.; N.H. Admin.
Code W. Ch. 900, Part
904, P.etteaunent Stan-
dilf(L~ for Publicly Owned
Trntrnenl Works (POTW).
Ws Ch. 400, Pan 437
Watcr QualilY Siandards-
Fish Life.
W. Ch. 400, Part 439
Anlitlegradation Policy.
.'EDERAL REQUIREMENTS:
HAZARDOUS WASTE
.. I. Haz..dous Wasle Regu-
lation.. RCRA Subtitle
C, 40 CFR P..t 264.
No Action
GW'I.GWn.
SUI, SOli
"
T.ble S-I: Action-w.,c:cific ARARI
Ground WBlCf
EJllJlICtion, Trut-
ment and Disposal
GWI]. 114, 1/6,
1/8, /Ie)
ExcaY8lionJDredg-
ing'" Off-Sitc
Disposal
SU3. SO'S
EJlc.vauo~cdg-
ing '" On-Site
. 1.caunent
SUiS. 116
S0ll1,I/8
In-Sina
Vacuwn
EJllJaction
SU1
In-Situ Soil
Washing
sua
Capping
.SOll3.114
A
A
A
A
.. All pro\/uions or 40 CfR. 264 arc addrcssed by pro\/isio~ of Ihe New Ilnmpshirc Waste M,uIIgcment Act, which becomc ARAR for the South Municip.1 Wcll Site.
-------
Requirement
nWERAL REQUIREME"iT:
IIAZARDOUS WASTE (c:ont'd)
OSIIA Requirements
29 CFR 1910, 1926
and 1904.
DOT Rules ror Uazardous
Matcrials Trul5port
49 CFR 107, 171.1.
11 UOO:
TSCA regulations governing
DR E requirements ror PCB
wastes, 40 CFR 761.70
land Disposal Reg\Jlations
40 CFR 268
FE()ERAL REQUIREMENTS:
SUit FACE WATER
PL 92-S00 5«tions 301.
302, 303, and 304
Clean Water Act (CWA)
. Water Quality Criteria
40 CFR 430 Federal Pre.
tsculment RcquilcmcnLS (or
D'~l hilge to l'ubllcly
Owned TrCltmcnt Works.
No Action
OW'I,GWn.
SLlI, SD.I
A
Table S-I: Action-~aJCCiflC ARAR.
.--...
Ground Wilier
Extraction, Treat-
ment and Disposal
GW'3, '4, 116,
118,119
A
A
A
A
A
Excavation1Drcdg-
ing &. Orf-Site
Disposal
SU3, SDIIS
A
A
A
EJlcavatio~cdg-
ing &. On-Site
. -Treatment
SLIIS,II6
SDII7, /lK
A
~
A
A
In-Situ
Vacuum
EJllraction
SU7
A
A
A
In-Situ 'Soil
Washing
SUB
A
A
A
> ,
Capping
SDII3, 114
A
-------
-
Table 5-1: Action-_,.eciflC ARARa
Requircment No AClion GroW1J Walcr E.c'YaUo~edg- ExcavalionlDrcdg- In-SiN In-Silu Soil Cappins
GW'I, GW/I1. EJllrlll.:lion, Tfcal- inS'" orf-She ing '" On-Silc Vacuum Washing son, .4
SLlI,SO'1 mcnl and Disposal Disposal TfCllmenl EJluacuon SLliIi
GWn, 114, '6, SU3, SOlIS SU5,'6 SU1
118,119 50111, 118
lo'EDERAL REQUIREMENTS:
SUHIo'ACE WATER «(ODI.)
40 CFR 125 RcguJoliona A
on Crilcria and 5undards for
the NalionaJ Pollulanl Ois-
char gc Eliminalion Syslcm
(NI'OES)
FEDERAL REQUIRJo:MENTS:
. AIH Jo:MISSIONS LIMITS
Clean Air ACI42 USC 6401; A A A A A A I\.
NalionaJ Arnbienl Air
QualilY Siandards (NAAQS)
40 CFR 50.
-------
,--...
Table S-2: AClion Sp......ic ARAR Synopses
REQUIREMENT
REQUIREMENT SYNOPSIS
STATE REQUIREMENT:
IIAZARDOUS WASTE
'1. RSA Ch. 147-A, New
Hampshire Hazardous Waste
Ml11Iagemenl ACI; N.H. Admin.
Code He-P Ch. 1905.
The New lIampshire Hazardous Wasle Managemenl ACI
cslablishes slandards applicable 10 Ihe "calmenl, slorace,
"lI\Sporl and disposal of hazardous wasle and the clll~ure
of hllardous wasle facilities.
a. Hazardous WioSle Facility
Security RequiremenlJ,
lIe.p 1905.0R(d), incorpor-
aling by rderence 40 CFR
264.14.
Federal "CR A requiremenlJ for the 8dopion of securily
measures are incorporaled by Ibis provision. These
measures are intended 10 prolCcllhe public from u-
posure 10 hllardous waslU.
b. General Inspection Require-
mcnlJ, He-P 1905.08(d)(4)(d)
incorporaling by rdcrence
40 CFR 264.1S.
This provision incorporalu federal RCRA requiremenls
for the regular inspection of hazardous waste facililies.
c. Personnel Training
lIeP 1905.08(d)(4)(e), .
inwrporaling by reference
40 CFR 264.16.
Hazardous wasle facility personnel must be "ained 10
ensure compliUlCe with applicable siandards and efrective
emergency response to comply wilh federal RCRA re-
quirements which arc incol)lOraled under this provision.
d. Localion Standards,
He.p 1905.01l(d)(4)(g),
incorporating by reference
40CFR 264.18 and He-P
1905.011(2 )(j).
Siting of hazardous wasle facilities near geological fault
areas and nood plains is restriclc(j untler the Location
Siandards. He-P 1905.08(2)(j) sets forth the Siale
procedure for idenlifying Ihe boulIJuies of nood plains.
ACTIONTOBBTAKENTOATTAIN ARAR
Hllardous wasle althe Soulh Municipal Well Site must be
managed, stored, "allsported and disposed of in accordance
with Ihe Nil Hazar.lous WaSIe Managemenl A~I. Specific re-
quirelllcnlJ of Ihe Au are discussed below.
The focilirV would be Mluired 10 t>c fenced.. posted, and
operated 11\ compai- ". . willi th,~ p'U. ;,.;.:....
Ocncrallnspection RequircmcnlJ require hallJdous wasle
facilities 10 implemenl reJular inspections, maintain
written records, and remedy operational problems.
The facility would be required 10 implemenl a personnel
training program and 10 maintain wrillen records in
accordance wilh lhis provision.
The location and duign of any hazardous waste facility al
lhe Soulh Municipal Well Site musl meet lhe requirements
of the toeatiun Standards. The Sile is Iocaled on a IOO-yelll'
Ooodplain. .
..
-------
REQUIREMEI'IT
STATE REQUIREMENT:
HAZARDOUS WASTE (COD I'd)
e. Preparedness and Pre.
venlion Requirements,
lIe-I'I90S.08(d)(4)(b)
incorporating by reference
40 CFR 264, Subpul C.
f. Contingency Plan,
lIe.p 1905.08(d)(4)(i),
incorpouting by rderence
40 CFR 264, Subpart D.
g- Groundwater Protcction,
Ile-I'I90S.08(d)(4)(j),
incorporaling by rderence
40 CFR 264, Subpart F.
h. Closure and Posl-Closure,
lIe-P 1905.08(d)(4)(k).
incorporating by rderence
40 CFR 264, Subpart O.
i. Transfer of Facility,
lIe-P 1905.08(d)(S).
.....
Table S.2: Action Specllic ARAR Synopses
REQUIREMEI'IT SYNOPSIS
This provision incorporates federal RCRA requirements
for prevention and response 10 rdeases of hazudous
waste.
Fc:dcral RCRA requirements for emergency procedures
and contingency plans are inrorporaled under this
provision.
This provision establishes Ilandards (additional 10
ItandaJtls in NH Admin. Code: Ws Ch. 410) for ground-
water monilOring and applO,_iate remediation II hazud-
ous waste bcilities. The pt'ovision prohibits Ihe dis-
chuge of constiluents inin glOunt! wa\c:r above federal
RCR.A limils for such conluminonts at the compliance
point, which is dermed as the tx)Undary of each waste
management unit under 40 CFR 264.9S.
Design and performl')(;C standards for hvudous was\c:
facility remediation and closure ue set forth under
this provision which incorporates federal RCRA re-
quiremenl5.
This provision establishes requirements for notifying
the Division of WaSle MllJlagement (Division) and
future owners or operalors when the focility is Iransfened.
ACTION TO DE TAKEN TO ATTAIN ARAR.
Provisions must be mlde during facility construction and
operation for internal communication, equipment, emer-
gency response: capability. and anangements wilh local
emergency response authorities under this rcquircmenL
The facility would be required 10 develop and maintain
wrillen contingency plaru and emergency procedures in
accordance with this provision.
The facility would he required 10 implement a ground
water mon ilOring and pro\c:Ction program in accordance
with this provision.
A wriuen plan for liw closure and po5l.dosure care must
be: denl pc:d and irnp!l':m~l~ in ~rdancc with this pro-
vision.
The requirements of Ibis provision must be: met prior 10
-------
,'. .
REQUIREMENT
STATE REQUIREMENT:
IIAZAROOUS WASTE (cont'd)
j. Monitoring
lIe.P 1905.08(d)(6).
k. Public Notification Plan,
"e.P 1905.08(d)(9).
I. General Environmenlll
Sundards, "e.p I90S.08(d)(I).
m. General Design Standards,
He.p 1905.08(d)(2).
n. Technical SlIndards for
Landfills, He.p 19O5.08
(d)( 1)( f), inrorporat ing by
rcl..,ence 40 CFR 264, Sub.
pall N, and lIe.P 190t08
(I) lXd).
J
W I,
---
Table 5.2: Action SpeCIfIC ARAR Synopses
REQUIREMENT SYNOPSIS
GroW1d water monilOring rC(luirements and authoriza-
lion of the Dureau 10 require other appropriate environ-
mental monilOring are established in this provision.
The Bweau is authorized 10 require development of
. program 10 inform the public of the Slltus of facility
activities under this provision.
This provision requires facilities 10 comply with
IpcciflCd ltate and federal envirorunental standaflb
and 10 provide protection 10 workers in accordance with
Illte and federal ouupationalllCahb and Slifety require-
ments. Apl,licable occupational slandards include
29 CFR Ch. 1910 (ir.dusuy slandards); : 9 CFR
01. 1926 (sofelY and health siondards); Nil RSA
Ch. 277.A (Worker's Righl'IO-Know Act); Nil Admin.
Rules lIe-P Ch. IROO,I'11f1 IRO] (Tolic Substances
in the Workplace).
General facility design standords 10 prevent release of
hazardous constituents 110 eSlablished WIder this provision.
NH Technical Standards fur Landfills incorporatcs fed-
eral RCRA requirements for landfills, supplemented by
IIddilional siale siandards sel fUt11i in lIe.P 1905.08
(f)(2)(d). 'lIe.p 1905.08(1)("2)(d) requires a
dcmolUualion thallandfll! tliiposal is Ihe only practical
way 10 dispose of wasles, anti a descriplion of how the
facililY will ",eel specified d~si&n requirements.
ACTION TO BETAKENTO ATTAIN ARAR
GroWld water monitoring would be required for operation
of any hazardous waste faciliry. Additional moniloring,
such as air emission monitoring may be necessary to detect
releases of fugilive dust or VOCs dwing remedial activities.
A public ooLitication plan is appropriate to ensure that the
public will receive on-going information as to the imple-
menlation of Ihe seluted remedy and the SlalUS of siLC
closure. A program f.1f regular nOlificalion of die public
as 10 the slalUS of site remediation should be developed.
Flcilily operation mllSi comply wilh environmenlal and
ouupationalilfety requirements.
The dcsi,n standards from this provision must be incor-
poraled into plans for huudous waste facililies.
Several South Municipal Well SiLC ahernalives involve
on-sile land disposal of huardous Wlltes. Disposal by
landfill in Ihe Slale of New Hampshire must be deemed to be
die only practical way to dispose of bazarduus wasles, Iflu
assessing allavailahlo was Ie management ahernalives and
musl meet all odler standards set forth in lIe-P 1905.08
(d)( I )(f).
,
-------
REQUIREMENT
ST A.TE R F.Q UI R EM F.NT:
HAZARDOUS WASTE (COD I'd)
o. Addilional Technical
Slantlards for TrealmCIII
lie. P I90S.08(f)(2)(a).
p. Siorage Standards,
He.p 1905.08(f)(2)(c)
q. Technical Slandards for
WlSle Piles, He.P 1905.08
(f)( I Xd), incorporaUng by
rderence 40 CFR 264,
Suhpll1 L
r. Technical Siandards lor UICI
and M anagemenl of Conlaincrs.
tle.P 1905.08(f)(IXa),
inwrporaling by refc:.:nce
40 CFR 264, Subpll1 I.
I. Technical Slandards' for
Tanks, fle-P 1905.08(f)(l)(b)
incorporaling by reference
. 40 CFIt 264, lubpll1 J.
I. Slanda,,1s (or Generalors,
lIeI) 19U5.06
-
Table S.2: Acuon SJI'-walic ARAR Synopsel
REQUIREMENT SYNOPSIS
This povision requires a demonstration Ibat proposed
treatment melbods will mcel specified design and con-
abUclion requirements.
Design and construclio~ requirements for (acililiCi
which Slore haz.ardous WlSlcs arc specified in this pro-
vision.
This provision incorporalcs (ederal RCRA require-
ments for WISIe piles.
Thi. J>tovlsion incorporales lederal RCRA require.
ments for facilities Ibal slore conlainers 01 hazard-
ous WlSle.
This povision incorporales leder.1 ItCRA requirc:mc:nls
for focililies using lanks 10 Ircal or Ilore hazardous
Wasles.
Requiremenu applicahle 10 gencralors, including per.
10115 Iransporting haullious wdSlcs or lrealrRent
residuals Ale eSllblishct.l by Ihis pfOvision.
-\
ACTION TO DE TAKEN TO ATTAIN ARAR
A trealment facility must demonstrate Ihat the Icchnology
will be eflective and will meet the design requirements
of Ibis provision.
The Ilora&e of hazardous wastes, groundwalcr treatment
residuals, and contaminated soils must minimize any danger
to human heallb or the CRvirorvnent, mwt include mechan-
isms 1.0 prevent and delect relcascs to the environment, and
muSI olbcrwise comply wilb design standards set forlb in
this provision.
Wl5te piles mwt be operaled in compliance wilb
40 CFR 264 Subpll1 L . . .
Design and management of hazardous wasle conlaincrs
must comply with this provision. These container stan-
duds apply to the shipment of treatment residuals and
conlarninalcd materials for off-sile treatment or disposal.
Design and maintenance of tanb must comply wilb Ibis
povision, and regular tonk inspection and mainlenanee
must be conducted by the I.cilily.
Any (acilily gener'ling WlSles lor transport oflsile must
comply wilh these requirements.
-------
REQUIREMENT
STATE REQUIREMENT:
IIAZARDOUS WASTE (coal'd)
u. Manifesting Requiremenu.
I
He-P 1905.04
v. Packaging and labelling
Re(luirements. "e-P 1905.05.
incorporating by rdc:rence
Nil Admin. CoJe Saf.C-600
and 49 CFR 172. 173. 178.
and 179.
w. Tcchnical Standards for In-
cineralOrs, "e-P 1905.08(f)(l)g.
incorporating by rdc:rence
40 CFR 244. Subplt1 -,
STATE REQUIREMENTS:
AIR EMISSION LIMITS
N.II. Admin. Code Air
Palts 604-606.
Fugitive Dust Emission
COlilIol. N.lt. Admin. Code
Air Pllt 1002.
.-
Table 5-2: Action S~..ic ARAR Synopsci
REQUIREMENT SYNOPSIS
The Iransporl of any huardous wastes orr-site must
comply with the manifest and record-keeping require-
ments let forth in this provision.
Hazardous walles Iranspomd off.site must be packaged
and labelled in accordance with New lIarnpshire 1A.-p1t1-
ment of Safely rules and federal Illl\SporIItion require-
ments.
This povision incorporales federal RCRA requirements
for incineration of hazardous was lei, .
UmilJ for the emission of air pollutants are established
Wlder this provision.
Activities sucllas cONlJUction and ucavation must
include prccautioN to prevent. abate and control fugi-
tive dust emissions.
ACTION TO BETAKEN TO ATIAJN ARAR
Any hazardous wastes. including Irealment residuals.
shipped from the lite for fwther Irealment or disposal
must be popcrly manifested and handled.
Treatment residuals and hazardous wastes must be packaged
and handled in compliance with these requirements. Con-
tainc:rs of huardous waste must be cJeuly muked, and
Iransport vehicles placarded prior to Iransporl orr-site.
Any incinc:ration of huardous waste. musl comply
with the requiremc:n1J sel forth in these regulations,
AU remedial alternatives must comply with these air
emission limits, including limits ~n the release of volatile
comtaminanlJ into the envirorunenl.
All remedial actions involving conslJUction. uCivation
or oth..." activities which may emit dust must include
pecautions to control the fugitive dusl emissioN.
,
I
-------
REQUIR~MENT
STATE REQUIREMENTS:
GROUND WATER
RSA 149:8, III; N.H.
Admin. Code Ws Ch. 410.
Prolection or GroWld Wiler
STATE REQUIREMENTS:
SURJo'ACE WATI::R
RSA Ch. 149, N.H. Admin.
Code Ch. Ws 430
RSA 149:4-1; N.H. Admin.
Code Ws Ch. 900, PUI 904,
Prelreillneni Standards ror
Puhlicly Owned Treillnent
Works (POTW).
Ws Ch. 400, Put 431
Waler Qualiry Standuds-
Fish We.
Ws Ch. 400, Put 439
Anlidcgradltion Policy.
..-
Tlble S-2: Action Spccllic ARAR Synopses
REQUIREMENT SYNOPSIS
These:! provisions esllblish aileril ror ground waler
proJeCtion. See turrlu:r discussion or Ibis provision
in Tlble 3-1.
These provisions estlblish ailcril ror lurracc
Wiler prolecliorL
These provisions CSl.ablish slandards ror dischuges
10 publicly owncd sewige heallnenl racilities.
This requiremenlS provides rh11S1A1e surrace Wllera
Ihall be hee hom chemicab or conditions harmrul
10 fISh lire.
Ws Ch. 400, PUI 439 eSlahlishes rhe llale policy
Igairrsl degradation or exislins waler qualiry, and re-
quires prolcclion or in-slrcam beneficial uses.
ACTIONmOETAKENTO ATTAIN ARAR
All remedial 1!lernthVe whkh invc!ve d!s<;!1ug~ 10
ground waler must comply wilh Ihcse lIandards.
ConlaminanlS, arealcd erfluenl or aruled groWld Wiler
which 8Ie disch_led 10 audlce Wiler musl comply wilh
Ibese Slandards.
Treal~ groWld wiler or other dfluenl dischuged 10
any POTW musl comply wirh rhese alanduds.
Remedial aclions which include discharge or llealed Wiler
10 aurrlce wiler musl comply wilh Ibis requiremenl.
Remedial allernalive. which inclnde dischuge or healed
Wiler 10 surCace Wilen musl comply wilh rhis policy.
-------
r-.
REQUIREMENT
FEDERAL REQUIREMENTS:
IIAZARDOUS WASTE
I. lIazlldous Waste Regul.-
lions, RCRA SubLille e,
40 CFR Pili 264.--
OSHA RequiremenlJ
29 CFR PillS 1910, 1926
IJId 1904.
DOT Rules (or Hazlldous
Materials Transpon,
4') CFR 107, t71.1-I1I.S00.
TSCA regulaLions BOyemina
ORE requirements (or PCB
wlISles, 40 eFR 761.70
Land Disposal RegulaLions
40 CFR 2611
...-...
Table S-2: AClion SpecifIC ARAR Synopses
_REQUIREMENT SYNOPSIS
RCRA Sublille e establishes IIII\OOds applicable 10 the
Ireallnent, slOrage, transport and disposal o( hllardoltS
waste and the cIoswe o( hlUldous wasle (aciliLies.
These requirements p'oyide regulaLions for worker
health and u(ely dwinS remedial acLiyiLies, non.
workplace public health, and rcporLing and record keeping.
These requirements regulale transpon of hazlldous
malerials.
These regula Lions Boyern destrueLion and remoyal efficiencies
(ORE) for PCB contllninllted wastes, and PCB concenluLions
in lleated materials.
These regulation Boyern and resllict the land disposal of
,paific hllardous wastcs (groundwal.cf and soils conlam.
Inated with spcnt halogenated solyenlJ in this case) II\d pro-
vide concenllations o( waste conslilUenlJ which will allow
(or land disposal.
ACTIONTOBI!TAKENTOAITAIN ARAR
Hazlldous wastea Irealed, IlDred. transponed from or
disposed o( .t the South Municipal Well Sile must comply
wilh RCRA SubLille e regulalions.
All OSIIA requiremenlJ must be met for workers engaged
in on-site remedi.1 acLivilies, and for non-workplace
public heahh.
Remedial allernaLivel which involYCllranspon o( hazardous
wasle or lIealment residual. o((-si~ must comply with
IhCJC regulaLions.
Incineration o( PCB contaminated wasles musl achieve
Breilier than 99.9999" dcslrUclion and removal efficiency (DR E);
and trealed malerials must Contain <200 ppb PCO's.
Dischllge o( Irealed croWtdwaltr and disposal of collected
leachate, disposal o( COnll/11inated soils which have been
eXClyated for Ireatment, and disposal o( residuals or leachate
collecled from in-litu soil remediation must comply wilh
these regulations.
.. All provisions of 40 CFR 264 lie addressed by provisions o( Ihe New lIampshi," Waste Managemenl Act, which become ARAR (or the South Municipal Well Sile.
-------
REQUlREMENT
n:O":RAL RF.QUlREMENTS:
SURFACE WATER
PL 92-500 Scclions 301,
302, 303, and 304
Clean Waler ACI (CWA)
Water Qualily Criteria.
40 CFR 403, Federal Pre-
Ireatmenl Requirements Cor
Dischllge 10 Publicly Owned
Treatmenl WorkJ (POTW)
40 CFR 12S Regulalions on
Criteria and S\JIndards for the
Nallonal Pollutant Discharge
Elimination System (NPDES)
FEOERAL RF.QUlREMENTS:
Alii EMISSIONS LIMITS
Clean Air Act 42 USC 6401;
National Ambient Air Qualily
Sialldards (NAAQS) 40 CFR SO.
...
Table 5-2: ACIion SPCC;IIac: ARAR Synopses
REQUIREMENT SYNOPSIS
Water Qualily Criteria 110 nonenCorceable luidance
developed under the CW A 10 establish water qualily
atmdanis.
'J1ICIC requirements developed under thc Clean Water
Act establish standards Cor walCf which is dischllged
10 POTW.
These requirements developed under the Clean Water Act
eslAblish criteria and standwds for water which is discharged
\0 surface water.
These requirements eslablish standards for emilsion
of vllious contuninants inlO the atmosphere.
ACTIONTOOETAKENTOATfAIN". HAR'
Remedial alternativcs which involve dischllgc oC II" ..tcd
ground water \0 IUrfac:e waten must comply with II" ~e
criteria.
Remedial alternativcs includinC discharge oC lreate.1 "",Iter
10 POTW must comply with these prelrCltment re'jolt/e-
ments.
All remedial alternalives involvinC dischllge /If lIeated
water 10 surCace water musl comply with ihc~c rCtluirements.
All remedial ahernatives must comply with these sun-
duds. Vapor collection technologies may be necessary
for some alternalivcllO meet emissions standuds. Dust
control may be nccessary during ncavation and/or
well installation to meet ltandllds.
-------
APPENDIX C
-------
PREFACE
The U.S. Environmental Protection Agency (EPA) held a public
comment period, from July 21, 1989 to August 19, 1989, to provide
an opportunity for interested parties to comment on the draft
Feasibility Study (FS) and the July 1989 Proposed Plan prepared
for the South Municipal Water Supply Well Superfund Site (the
site) in Peterborough, New Hampshire. The draft FS examines and
evaluates various options, called remedial alternatives, for
addressing contamination of groundwater, soil and sediment at the
Site. EPA identified its preferred alternative for the cleanup
of the site in the Proposed Plan before the start of the public
comment period.
The purpose of this responsiveness summary is to identify major
comments raised during the public comment period and to provide
EPA response to t.le comments. EPA has considered all of the
comments summarized in this document before selecting a final
remedial alternative for the contamination at the Site in
Peterborough, New Hampshire. .
This.responsiveness summary is divided into the following
sections:
I.
overview of Remedial Alternatives Considered in the Draft
Feasibilitv Study. Includinq the. Preferred Alternative -
This section briefly outlines the remedial alternatives
evaluated in the draft FS and the Proposed Plan, including
EPA's prefe~red alternative.
II.
Backqround on Communitv Involvement and C6ncerns - This
section provides a brief history of community interest and
concerns regarding the Site.
III. Summary of Comments Received Durinq the Public Comment
Period and EPA Responses - This section summarizes and
provides EPA responses to the oral and written comments
received from the public during the public comment period.
In Part I, the comments received from citizens and EPA's
responses are organized by subject. In Part II, the
comments received from the PRP, including the PRP's
preferred alternative, are presented followed by EPA's
response.
Exhibit A - This exhibit is a list of the community relations
activities that the EPA has conducted at the Site.
Exhibit B ~ This exhibit is a copy of the transcript from the
-------
I.
2
OVERVIEW OF REMEDIAL ALTERNATIVES CONSIDERED IN THE DRAFT
FEASIBILITY STUDY, INCLUDING THE PREFERRED ALTERNATIVE
Using the information gathered during the Remedial Investigation
(RI) and thf:! Endangerment Assessment (EA) , EPA identified several
objectives for the cleanup of the Site. These response
obj ecti ves .'\re:
.
Eliminate or minimize, to the maximum extent
~ 'acticable, the threat posed to the public health,
w..dfare, and environment by the current extent of
contamination for groundwater, soils, and sediments;
.
bliminate or minimize the migration of contaminants
from the soils into the groundwater; and
.
Meet federal and state Applicable or Relevant and
Appropriate Requirements (ARARs).
New Hampshi~e Ball Bearings, Inc. (NHBB), with EPA oversight,
screened and evaluated potential cleanup alternatives for the
site. This evaluation, contained in the FS, specifically
describes alternatives for addressing contamination of
groundwater and contaminated soil and sediments, as well as the
criteria used to narrow the list to six alternatives for
groundwatc~ contamination and eleven alternatives for soil and
sediment contamination. Each of these alternatives is briefly
described below.
SL #1
No Action
Analysis of the No-Action alternative is required by federal
regulations and is included for comparison with other remedial
alternatives. Under this alternative, no action would be taken
to remediate contaminated soils at the South Municipal Well site.
SL #3
Disposal of Contaminated soils at an Off-site Landfill
For this alternative, 7500 cubic yards of
would be disposed in an off-site landfill
requirements of the Resource Conservation
(RCRA) .
contaminated soils
that complies with the
-------
3
SL #5
On-Site Incineration
On-site incineration of contaminated NHBB
excavating approximately 7500 cubic yards
The soils would be treated on-site with a
the treated material would be replaced in
covered with clean fill.
soils would involve
of soil, as in SL #3.
mobile incinerator, and
excavated areas and
SL #6
On-site Mechanical Aeration
On-site mechanical aeration involves excavating approximately
7500 cubic yards of contaminated soils, as in SL #3 and #5. The'
excavated soils would be treated on-site with mechanical
aera~ion.
SL #7
In-S~tu Vacuum Extraction
This alternative removes the' contamination from the 7500 cubic \
yards of soil by extracting the organic contaminants as vapors.
The process involves no excavation as it is done in-place.
In the Proposed Plan issued prior to the public comment period,
EPA presented this alternative as the preferred alternative for
addressing soil contamination at the Site.
SL #8
In-situ Soil Flushinq
Soil flushing would inject washing agents (water, steam, or
surfactants) into areas of soil contamination, and the injected
fluids and contamination would be extracted for treatment and
recycling.
SD #1
No Action
Analysis of the No-Action alternative is required by federal
regulation and is included for comparison with the other
alternatives. Under this alternative, no sediment remediation
would be performed. PCBs and PAHs would remain in the wetland
sediments above target cleanup levels.
SD #3
containment of Sediments with an Impermeable Cap
This alternative would cover an estimated 15,800 square feet of
contaminated sediments located in on-site wetlands with a
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SD #4
Containment of Sediments with a Permeable CaD
This alternative, as with SD #3, would cover approximately 15,800
square feet of contaminated sediments, except that this
alternative would utilize a permeable cap.
SD #5
DisDosal of Contaminated Se!\iments at a RCRA Landfill
This alternative would inv~: Ie the dredging or excavating from
the wetlands approximately 1170 cubic yards of sediments (over
the same 15,800 square foot area remediated in SD #3 and #4)
contaminated above the sediment target cleanup levels. The
sediments would be dewatere~ as needed and transported to an off-
site landfill licensed under RCRA unless sufficient land is
available on-site to accommodate the sediments in a landfill that
can meet RCRA requirements.
.
In the Proposed Plan issued prior to the public comment period,
EPA recommended off-site laLjfilling as the recommended disposal
element of the preferred alternative for addressing the sediment
contamination at the site. This was based upon screening
criteria which eliminated the on-site landfill due to inadequate
space on-site. The final decision will be made as to the
adequacy of the on-site landfill during detailed design
investigations.
SD #7
On-Site Incineration
On-site incineration would involve dredging or excavating from
the wetlands (over the sa~~ 15,800 square foot area remediated in
SD #3, #4, and #5) an estimated 1170 cubic yards of sediments
contaminated above the sediment target cleanup levels. The
sediments would be incinerated to remove hazardous PCB and PAH
contaminants.
SD #8
On-Site Sediment Washing
This alternative would involve dredging or excavating from the
wetlands (over the same 15,800 square foot area remediated in SD
#3, #4, #5 and #7) an estimated 1170 cubic yards of sediments
contaminated above the sediment target cleanup levels. The only
difference is that this alternative would treat the sediments
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GW #1
No Action
Analysis of the No Action alternative is required by the NCP and
is included in the FS for comparison with other remedial
alternatives. The aquifer would remain unsuitable for use as a
drinking water supply for the foreseeable future.
GW #3
Groundwater Extraction with On-site Air strippina
This alternative would involve the extraction and treatment of
groundwater by air stripper technology from both near the NHBB
building and the dilute plume, and subsequent discharge of the
treated water.
GW #4
Groundwater Extraction with GAC
This.alternative involves extraction of contaminated groundwater
as described in GW #3. The configuration of the entire system is
very similar to that of GW #3, with the only significant. \
difference being the method of treatment, carbon adsorption.
GW #6
Well-Head Treatment (South Well) with Air strippina
This alternative would directly treat groundwater for the.
Peterborough public water supply through well-head'~reatment of
water extracted by the South Municipal Well using air strippers.
GW #7
Development of an Alternate Water SupplY
Under this alternative, an alternate water supply would be
provided to the South Municipal Well site community.
GW #8
Groundwater Extraction with a Radial Collector Well with Air
Strippina
This alternative 1S similar to GW #3, the only difference being
the method of groundwater extraction near the northeast corner of
the NHBB building. At that location, a single concrete caisson
would be installed. From the caisson, screened wells would be
extended radially at a chosen depth in an attempt to enhance
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GW #9
Groundwater Extraction
accelerated
with On-Site Air Stri
This is similar to GW #3 except that a greater extraction rate is
used for the d,ilute plume groundwater extraction system, thus
resulting in a faster cleanup time for that portion of the
aquifer. In the Proposed Plan issued prior to the pUblic comment
period, EPA recommended this alternative as the preferred
alternative for addressing groundwater contamination at the Site.
II.
BACKGROUND ON COMMUNITY INVOLVEMENT AND CONCERNS
The Site consists of that area potentially affected by a
contaminated plume of groundwater whose areal extent is
approximately 250 acres. From 1952 until 1982, the South
Municipal Water Supply Well drew water from the aquifer affected
by the plume. The pumping of the well caused the contamination
to be drawn into the municipal suPply causing Use of the well to
be discontinued.
The primary concern of the community has been the adequacy of t)1e
municipal water supplies, especially during periods of high
demand. Twice during the performance of the RI, the well was
used for short periods of time, coinciding with dry summer
seasons and high demand. For the second incident, residents
concerned with the quality of the South Well water presented a
petition to Selectmen which resulted in discontinuance of Use of
the well. ,
Planned and implemented modifications to the water supply
distribution system have lessened concern over the short term
need for the South Well. However, there is still a recognition
that the South Well aquifer will play an important role in
serving the future water supply needs of the town.
With EPA's issuance of the Proposed Plan in July of 1989, some
pUblic concern was expressed over the financial impact that the
cost of the remedy might have on NHBB, a large employer in the
town.
III. SUMMARy OF COMMENTS RECEIVED DURING THE PUBLIC COMMENT
PERIOD AND EPA RESPONSES
This responsiveness summary addresses the comments received by
EPA concerning the FS and Proposed Plan for the Site. Six
written sets of comments were received during the public comment
period (July 21 - August 19, 1989): two from residents, two from
town officials, one from the PRP, and one from, the Speaker of the
New Hampshire House of Representatives. Several oral comments
were presented at the August 3, 1989 informal pUblic hearing.
These oral comments clarified and/or reiterated the written
comments. A copy of the transcript of the hearing is included as
Exhibit B. Copies of the transcript and all comments are 'also
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Records Center at 90 Canal street, Boston, Massachusetts, as part
of the Administrative Record.
~he comments from the public and EPA responses are presented
helow, followed by comments from the PRP and EPA responses.
Part I - Citizen Comments
1.
Three commenters stated support of EPA's proposed plan and
urged that the cleanup of the aquifer be done as quickly as
possible to enable the Town to once again use the South
Well.
EPA Response: The principal remedial action objective for
addressing groundwater contamination stated in this Record of
Decision is to restore the aquifer to drinking water quality in
as short a time as practicable. EPA believes that the
groundwater remediation alternative proposed as part of the
remedy will meet that objective. In addition, by providing
separate extraction systems, EPAbelieves that the dilute plume
can be isolated from both the NHBB area plume and the South Wel~.
This will result in a shorter cleanup time for that portion of
the aquifer affected by the South Well. Also, should a situation
arise that necessitates use of the South Well during remediation,
the hydraulic control provided by the dilute plume extraction
system will provide a degree of protection. The exact
requirements which would be imposed on use or. the well, up to and
including prohibition of use, will be detailed during remedial
design.
One commenter suggested an approach to enable emergency use
of the South Well during remediation, diverting South Well
water through the groundwater remediation facility for
treatment before the groundwater entered the water
distribution system.
EPA Response: The hydraulic control provided by the dilute plume
extraction system coupled with institutional controls restricting
the use of the South Well would result in no contaminants being
drawn into the zone of influence of the well. EPA believes that
approach would provide effective protection without incurring the
additional costs associated with the citizen's suggestion.
However, as mentioned in the first response, the final decision
on whether to restrict or simply prohibit use wil! be done in
conjunction with the remedial design.
2.
3.
Three commenters urged that flexibility be allowed in the
Record of Decision to enable the use of new technologies as
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EPA Response: EPA agrees that new technologies that provide for
a faster, more effective, or less costly cleanup are desireable.
Therefore, a wide range of technologies was screened during the
FS. The Record .of Decision (ROD) has determined that an
innovative technology for soil remediation, in-situ vacuum
extraction, is appropriate to be applied at this Site. However,
as discussed in the ROD, since it is an innovative technology,
careful monitoring and continual evaluation of its effectiveness
is required. If this evaluation results in the conclusion that a
more effective technology should be implemented, it is possible
to amend the ROD to enable use of that technology.
4.
One commenter requested that flexibility be allowed during
the remedial design so that costs can be kept to a minimum.
The concern is that consideration be given to the
preservation of jobs.
. .
EPA Response: EPA is required by the National Oil and Hazardous
Substances Pollution Contingency Plan (NCP) to implement a remedy
that. is cost-effective. The alternatives which make up the
comprehensive remedy for this site have been det~rmined to be
cost-effective. During the design phase there are several
decisions that still must be made, based upon more detailed
design investigations. These decisions could have significant
impacts on the final costs of the project. EPA will continue to
ensure that design decisions will be made with effectiveness and
costs considered.
5.
One commenter recommended that monitoring wells be located
north of the Noone Falls area and that the cost of any
monitoring required if the South Well were to be used during
remediation would not be borne by the town.
EPA Response: The decisions on the placement of monitoring wells
will be made as part of the final design of the remedy. . The
decision as to when and how the South Well would be used will be
dependent on the final configuration of the dilute plume
extraction system. The monitoring associated with that system
will be determined in conjunction with the design of the
extraction system. It is anticipated that all monitoring costs
will be considered as operational costs of the remedy.
Part II - PRP Comments
The PRP, NHBB, presented variations on the preferred alternatives
which EPA presented in the Proposed Plan. These variations were
documented in a letter and amplified on in a meeting, the minutes
of which have been made part of the Administrative Record.
6.
The PRP has suggested that EPA select a modification of GW
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This alternative would expand the existing groundwater
treatment facility to accommodate flows up to 400 gpm
initially. Data would be collected during a one year trial
of the expanded plant to determine the effectiveness of
remediating the dilute portion of the plume with the goal of
approximating the cleanup schedule presented in the Proposed
Plan (about 7.5 years). The data would be evaluated to
assist in design of a fUll-scale treatment. As part of this
modification and central to it from the standpoint of NHBB,
. is that the extracted groundwater be treated in one
treatment facility. NHBB asserts that this alternative can
more cheaply handle the extracted groundwater from both the
NHBB and dilute plume areas while achieving a cleanup
timeframe compatible with EPA's goal of 7.5 years.
EPA Response: The major objective of the remedy selected by EPA
is to clean the aquifer as soon as practicable. The parameters
used in the model which helped determine the probable cleanup
time 'were literature values which were deemed appropriate for the
types of coarse sands and gravels found at this Site. Any
preliminary design information which could be generated to
confirm those values would aid in designing an optimal system.
However, if the results of further investigations indicate that
the aquifer parameters assumed in the FS resulted in too Iowa
groundwater extraction rate to achieve EPA goals, then EPA would
expect that the rate would be increased (and hence the treatment
plant expanded) in order to approach the 7.5 year cleanup of the
dilute plume. ....
Furthermore, a rigorous cost-effective analysis of one treatment
plant compared to.two treatment plant~ needs to be done using
consistent methodologies and parameters. Complicating the
analysis is the shorter time it will take tu clean the dilute
plume. While the extraction of NHBB area groundwater can be
expected to continue for at least 19 years, the dilute plume
system could be shut down much sooner. Carrying that much excess
capacity in a single plant may not prove cost-effective. The ROD
provides that if it. can be shown that one, rather than two
treatment facilities can meet the remedial action objectives and
the statutory requirements, and present an equivalent balance of
the evaluation criteria, then one facility may be constructed.
In summary, final determinations relating to the number of
treatment facilities, number and location of extraction wells,
groundwater extraction rate, and the number and location of
discharge points will be based on site specific data collected
during the remedial design. Remedial action objectives will be
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7.
The PRP supported the sele~tion of the soil remediation
technology, vacuum extraction, but have expressed concern
thast this innovative technology may be unable to reach the
very low soil cleanup levels. The PRP requested that
flexibility be allowed during remedial design to evaluate
technological advances being made in the treatment of
contaminated soils.
EPA Resconse: EPA's Position or the Use of vacuum extraction is
presented in Section X.B.l. of the ROD. The remedy selected was
the best of those identified in the FS prepared by the PRP. It
is not clear what other techno'.~ ical advances are referred to
nor is it clear how they could b( evaluated during remedial
design so as not to delay implem~ntation of the remedy. EPA's
concerns are stated in the response to Comment #3.
8.
'The PRP recommended a modified sediment treatment
alternative because it believes that the selection of the
,EPA alternative is premature. The PRP has proposed burying
a portion of the PCB-contaminated sediments in an unlined,
on-site landfill to be located under the NHBB parking lot,
with a cap which would meet :ederal landfill closure \
requirements. The remaining portion of the PAH-contaminated
sediments would be shipped off-site for disposal.
EPA Resconse: There are several reasons why EPA does not agree
with NHBB's remedial alternative. The PRP's proposal would
result in the creation of a new ~andfill at the Site which would
require long-term monitoring and maintenance. Not only would
federal landfill closure requirements need to be met, but federal
requirements for new landfills related to a liner system would
also need to be incorporated into the design. In general, while
there is a preference for on-site solutions expressed in federal
law, in this case EPA has select"d off-site disposal and does not
believe that there are practicable on-site treatment alternatives
for the sediments. Off-site disposal will provide a protective
remedy that permanently removes contaminants from the site. In
this case, EPA believes that the short and long term
effectiveness of an off-site, RCRA-licensed landfill that has
been designed to contain hazardous substances is more protective
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EXHIBIT A
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EXHIBIT A
COMMUNITY RELATIONS ACTIVITIES AT THE
SOUTH MUNICIPAL WATER SUPPLY WELL SITE
PETERBOROUGH, NEW HAMPSHIRE
EPJ~ Community Relations activities conducted at the
South M~nicipal Water Supply Well site have included:
.
August 23, 1985 - EPA issued a press release announcing
the availability for public review of the work plan for
the Remedial Investigation of the site.
October 2, 1985 - EPA conducted a public meeting in
Peterborough to discuss the work plan for the Remedial
Investigation of the site.
'.
.
July 23, 1986 - EPA issued a press release announcing,
that New Hampshire Ball Bearings, Inc. would perform \
the site investigation under the terms of a Consent
Order signed with EPA.
'August, 1986 - EPA issued a Community Relations Plan
outlining issues of concern to the community and
activities to address information and public
involvement needs.
December 1986 - EPA issued a fact sheet on the
progress of the Remedial Investigation and plans for
future EPA activities at the site.
.
May 17, 1989 - EPA issued a press release announcing
the availability of the report on the results of the
Remedial Investigation, and announcing a public meeting
to present .the results of the Remedial Investigation.
.
May 24, 1989 - EPA held a public meeting, as part of
the Peterborough Selectmen's meeting, to discuss the
Remedial Investigation results and upcoming steps in
the Superfund process, and to offer the public an
opportunity to ask questions about the site.
May 1989 - EPA issued a fact sheet to the site mailing
list of interested and affected individuals expl~ining
the results of the Remedial Investigation and EPA plans
for future action at the site.
.
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July 13, 1989 - EPA issued a press release to the site
mailing list announcing the availability of the
Feasibility study and Proposed Plan for the site; the
schedule for the public informational meeting, public
hearing and public comment period on the Feasibility
study and Proposed Plan; and the availability of the
Administrative Record for the site.
.
July 14, 1989 - EPA placed a paid public notice in the
Keene Sentinel newspaper announcing the availability of
the Feasibility Study and Proposed Plan for the site;
the schedule for the public informational meeting,
public hearing and public comment period on the
Feasibility study and Proposed Plan; and the
availability of the Administrative Record for the site.
.
July 20, 1989 - EPA held an informational meeting,
during the Peterborough Selectmen's meeting, to review
the findings of the feasibility study, present the
Proposed Plan, explain the public comment process, and
answer questions from the public and local officials. i
.
July 21 - August 19, 1989 - EPA held a public comment
period on the Feasibility Study and Proposed Plan.
August 3, 1989 - EPA held an informal public hearing to
accept comments on the Feasibility Study and Proposed
Plan.
.
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EXHIBIT B
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UNITED. STATES
ENVIRONMENTAL PROTECTION
REGION I
PETE:~~~~~G:E~~GHALL ~~\~
P,ETERBOROUGH, NEW HAMPSHIRE ~,
AG ENCY
Thursday Evening
August 3, 1989
7:30 p.m.
SOUTH MUNICIPAL WATER SUPPLY WELL SITE
PROPOSED SUPERFUND PROGRAM PLAN
PUBLIC COMMENT re PREFERRED REMEDIAL
ALTERNATIVES PROPOSED BY EPA
Appearing for the EPA:
Dan Coughlin, Hearing Officer
Chief, New Hampshire Superfund
and
Roger Duwart
Remedial Project Manager
u.S. Environmental Protection Agency
Region I
John F. Kennedy Federal
Boston, MA 02203
Building
Court Reporter:
Richard E. Cowing, CSR
COW I N G R E P 0 R TIN G 5 E R V ICE S
VERBATIM REPORTING« » AUDIO TRANSCRIPTION
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I N D E X
Preliminary Comments:
Mr. Coughlin
. . . . . . . . . .
EPA PreSentation in Brief:
Mr. Duwart
. . . . . . . . . . . .
Public Comment:
Mr. Hoffman ...........
Mr. Pease .............
Mr. Samide ............
Mr. Thompson ..........
Mr. Dye r ..............
Mr. Thompson ..........
Question & Answer Session:
. . * . .
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FRO C E E DIN G S
2
[The EFA public hearing commenced at
3
approximately 7:30 p.m.]
4
SELECTMEN CHAIRMAN:
Turning to the public
5
comment period this evening on the EFA and the New Hampshire
6
Ball Bearing cleanup of their property and the South Well.
7
This is not beirig conducted by the
:8.' 'Fe~erborough Selectmen; it is being conducted by the EFA.
;9.
. A~d c6mments made this evening.-- and I'm sure they'll be
'explained -- comments being made this evening will be \
'. recorded by the public stenographer that they have with them.
At the momentth'e Selectmen will not make a
. comment.
'. .
. .
They will' have a comment to make.
So the hearing officer for the EFA is Dan
Coughlin, and I would turn the meeting over to him at this
time.
MR. COUGHLIN:
Good evening.
My name is Dan
Coughlin.
I'm chief of the New'Hampshire Superfund Section
at EPA in Boston.
We're here tOlLight to conduct a publ ic
hea~ing on .the cleanup of the South Municipal Well Superfund
site at New Hampshire Ball Bearing in Feterborough.
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left: he's the project manager for EPA.
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The purpose of the hearing is to obtair
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formal comments for the record on the proposed plan that was
4
issued approximately a month ago and the Remedial
5
Investigation and Feasibility Study that has been out for -~
6
the Remedial Investigation has been out approximately six
7
months: the Feasibility Study was issued probably also a
8
month ago.
9.
Before we actually start the hearing process,
let me teli you how we will run the process~
First, '~oger
will give a brief description of the proposed plan which will
outline EPA's preferred remedy for the cleanup of New
Hampshire Ball Bearing or the South Municipal Superfund site.
At that point we will accept any formal oral comments that
you wish to make.
There are cards out back.
If you wish to
make a comment, you should have signed a card on your way in;
if you haven't, please do so.
We will call on people in
order of when you signed up on the cards.
After each person has made a comment we will
reserve the right to ~sk any questions to clarify those
comments: if not, we will. go on to the next person.
At the conclusi.on of the hearing we will
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question-and-answer session where you can ask questions of
either myself or Roger, and we'd be happy to respond.
We
also .have with us tonight members of the New Hampshire DES
sitting up back, and if there are any questions that you havE
for them I'm sure they'll be glad to respond.
There is a microphone up front.
I think you
can make your comments from your seats, if you'll just stand
up.
I think the acoustics are good enough in here.
If not,
then we may ask you to move up front.
But we'll try it at
. -....
your seats for the moment, and that should work just 'fine.
As you know, we had a public meeting two
weeks ago to explain to you the proposed plan and the content
of the RI/FS which essentially led up to the proposed plan
and our recommendation as to how we would expect to see the
Superfund site cleaned up.
The public comment period will
end on August 19th.
So if you don't make comment tonight and
you wish to make a written comment -- and we would encourage
you to do so -- please make sure your written comments are
addressed to us, the address is in the proposed plan.
If you
don't have one, there are some up back; just make sure you
get one, an~ make sure they're postmarked on or before August
19th.
Oka y .
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conduct the hearing?
2
Okay, Mr. Dyer.
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MR. DYER:
I just had one comment, one
4
question.
You said August 19th.
I was under the impression
5
it was August 20th, was the end of the comment period.
6
MR. DUWART:
It began July 20th and ends
7
August 19th.
The 20th is a Sunday, actually.
August 20th is
8
a Sunday.
So it will end Saturday.
9
MR. DYER:
Midnight on the 19th?
. ".."
MR. DUWART:
Yeah.
MR. DYER:
Thank you.
MR. COUGHLIN:
Mr. Thompson?
MR. THOMPSON:
That was my same question.
It's midnight on the 19th, or is it midnight on the 18th?
MR. DUWART:
Postmarked the 19th.
MR. THOMPSON:
As long as it's postmarked the
19th.
MR. DUWART:
Yeah.
MR. COUGHLIN:
Postmarked the 19th.
Anything else?
[No response.]
MR. COUGHLIN:
Okay.
With that, Roger, wnv
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EPA PRESENTATION
[Overhead projection display being utilized.]
MR. DUWART:
This will be a very brief
overview.
Most of the faces in here are familiar, you heard
this last week -- two weeks ago.
The proposed plan tha~ BPA has presented to
the public two weeks ago consists of three preferred
alternatives, handling three different media at the site.
First and most important, and the one that everybody is
probably most familiar with, is the ground water.
What we
,have proposed is a groundwater extraction and treatment
. system: actually, two extraction systems -- one to handle the
concentrated plume which is close to the NHBB facility; a
second extraction system to get what is known as the dilute
plume which has migrated off the facility, and which in times
of pumping at the South Well is moved into that zone of
influence.
The two systems will be hooked up to a
treatment facility or two treatment facilities, depending on
the design as we move through the remedial design.
The
,treatment technology chosen has been air stripping.
After
the air stripping, to drive the volatiles off, which is the
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will actually be placed through activitated carbon to remove.
2
those contaminants before they dre discharged to the
3
atmosphere.
4
The effluent, the water portion of the
5
treatment system, will be disc!arged into the ground,
6
probably behind New Hampshire iall Bearing, to enhance the
7
removals.
There will be some P~ssibility that we will
8
continue with the discharge to the Contoocook River as well.
9
Again, this is going to be a design decision that will take
place after the Record of Decision is issued.
There's two other -- actually, three other
aspects of the groundwater portion that I want to make clear.
One is that we will be looking during design at the
possibility of a cyclic pumping or steam injection.
Right
now it looks like it will prob~cly be a cyclic pumping system
which will help remove the contaminants especially near the
Ball Bearing plant which the heaviest concentrations are
located~
That cyclic pumping -- pump it, let is rest; pump
it again -- will help to remove those heavily-contaminated
areas, the heaviest contamination, from the aquifer.
It will
be more effective than straight pumping.
. As I said, we will be looking at steam
injection.
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indicate that it probably would not be cost-effective to use
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steam.
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During the remedial action and on into the
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future we will have a groundwater monitoring system in place,
5
probably quarterly initially.
That again will be determined
6
during the design phase.
This will be to ensure the
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effectiveness of the remedy that we have in place and to
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ensure that we are not allowing any contamination to migrate
'9
any further from the aquifer that we're looking at right now.
Finally, another important part of this
groundwater No.9 -- which is fully described, by the way, in
the proposed plan and the Feasibility Study -- is the
institution of controls on the use of the South Well.
At
this point we are looking at probable restrictions and
possible prohibition of the use.
Again, that will depend on
the final design of the extraction system that we do put in
out there.
This is something that we want to ensure that
that well does not affect our remedy and that the
contaminants that right now are not being drawn into that
well will not be drawn into the well.
So that's another very
important aspect of the Record of Decision as we move along
in this process.
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preferred alternative for soils, and it goes hand in hand
2
with the cleanup of the groundwater, is in-situ vacuum
3
extraction of the soils in and under the northeast portion 0:
4
the New Hampshire Ball Bearing facility and just out front Of
5
the facility.
In-situ vacuum extraction is similar to an
6
extraction system for groundwater only it occurs above the
7
water table.
What we'll be pulling through the granular
8
overburden there is clean air which will drive the volatiles
9
again off; they will again be run through carbon columns and
. -...
the effluent or the air stream will be discharged tO,the
\
atmosphere.
We estimate this will take approximately two
years.
It's important to do concurrently with the
groundwater treatment because it will save us from a lot more
operation and maintenance costs associated with treatment of
the groundwater, if we prevent the migration of those
contaminarits into the water table, the continued migration of
those contaminants into the water table.
The third and final portion of the proposed
plan is the preferred alternative for the sediment
contamination in front
of the Ball Bearings plant. We have
the contamina~ed sediments at an
chosen the disposal of
off-site land fill.
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~ossible, to excavate those sediments so we will try to do
2
that in the dry period so that we wouldn't have to dredge and
3
create a lot of sedimentation in the wetlands.
4
As part of this portion of the proposed plan
5
we would be revegetating those wetlands and restoring them to
6
as close to possible as beforehand in terms of the
7
groundwater contours -- or the surface contours.
8
The three pieces together make up our
9
proposed plan.
As I said, it is fully explained, and the
alternatives to them are fully explained in the Feasibility
Study.
In addition, New Hampshire Ball Bearings has proposed
some modifications as well.
The proposed plan is another
source of information for you to take a look at those, and we
are welcoming here tonight comments on those -- on the
proposed plan and these alternatives.
MR. COUGHLIN:
Okay; that is .the end of our
presentation this evening.
And so we can go into the comment
period.
PUBLIC COMMENT
MR. COUGHLIN:
As was previously stated,
everything is being transcribed.
We will have a copy of it
made and we will respond to any comments in the response
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be issued when we make that decision.
So each and everyone
2
of your comments will be given careful consideration a:
~ill
3
be responded to in that summary.
4
[Brief pause.]
.)
MR. COUGHLIN:
Ted HOffman, would you like tc
6
make a comment?
1
MR. HOFFMAN:
I have just a few comments.
d
The first comment is really a correction.
I assume that the
9
EPA received my letter of July 22nd dealing with the
. --'
comments?
Is it safe to assume that the EPA receive~ ~y
letter of July -- all right.
I would like to make a
correction.
-
Since I'm my own typist, I have to assume r '1
responsibility.
But on page two, under paragraph 3(e), I, in
error, included the word "soil" in there.
And this paragraph
deals with my concerns about the proposed alternative
sediment operation, and since there's no alternative to the
soil correction process, then obviously I made an error in
saying that.
So, therefore, paragraph 3(e) should have the
word "soil" deleted since it makes no sense to be in there.
The other comments also deal Tith this same
letter that I sent, and in that letter I expressed my
concern, which I think reflects a lot of the townspeople'~
concern,
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shortest practical time.
"Practical" .is an important word,
2
"shortest" is an important word.
And in the letter -- and
3
I'm going to add a little more technical reference to suppor'
4
that'-- I pointed out that the Town of Peter borough now
5
depends exclusively upon the North aquifer, drawing from the
6
North Well and the Summer Street Well, whict. are about 3,000
7
feet apart, and there's a proposed new site, the Tarbell (ph)
8
site, that's about a thousand feet away, but all of them are
9
in the same general aquifer.
And, therefore, it's of vital
importance to the Town to have the South aquifer cleaned as
\
SOon as possible in the event that there should be an
eme~gency need for water due to some unforeseen contamination
of the North aquifer.
And to support the fact that the North
aquifer is vUlnerable, I'd like to quote frota the Whitman &
Howard aquifer map and protection study made for the Town of
Peterborough in November of 1985.
And on page 15 they made
the statement:
"The South aquifer is a prov~n aquifer with
major groundwater potential.
If the planned groundwater
cleanup in this aquifer is successful, and if aquifer
protection measures are taken, the South aquifer could once
I
I
again be a major groundwater source."
So that the South
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Peterborough's water supply.
2
Also in that same report, on page 48, t
3
state:
"The Contoocook River provides substantial amounts,
4
if not the majority, of recharge to areas that are heavily
5
pumped.
Water from the river is indl~ed into the aquifer
6
near the well.
If a hazardous liqu~~ spill OCcurs in the
7
river, contaminated water could travel quickly in~o primary
8
aquifer areas and enter the well."
9
The point of my quoting that is to reinforce
my contention that Peterborough's primary aquifer, the North
aquifer, is vulnerable, and the more that can be done to
reduce the critical nature of that sole aquifer's
vulnerability by bringing the South aquifer into play, the
better it is.
One further point in support of that
same
aspect -- In a letter of May 18, 1989 from Whitman & Howard
to Mr. John Isham, the town administrator, concerning the
South Well Reactivation Program, in ~he lower part of the
first page they state:
"It is almost certain that if the
well was returned a hundred percent full service that Sooner
or later contaminated water from the plume would be drawn to
the well.
This happened in the past and would almost
certainly happen again.
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that somewhere between zero percent and one hundred percent
2
pumping there lies a threshold pumping rate below which
3
contaminants will be drawn into the well."
4
And this is the point I'm really building to
5
-- "It is important to state that even if this threshold
6
turns out to be very low, it will still be cost-effective for
7
the Town to exploit.
The well is in place and operational
8
after all.
There are no costs other than power and
9
maintenance to run it.
It is by a significant margin you~
cheapest
'new'
supply on a per-gallon basis."
My only reason for quoting that is that I
understand -there's some interest on the part of New Hampshire
Ball Bearing in acquiring the South Well, but I understand
that's strictly in the discussion stage, and I just want to
state that in my opinion -- and I think the townspeople would
bear it out -- that any proven water supply that we now own
should never be sold; you can't put a price on a good water
supply.
Peterborough has been here 250 years, it may take
30, 40 years or what-not to clean the South Well; but you
have to consider Peterborough is going to be here at least
another 250 years and so, therefore, even though we can't use
the well now we should not part with it.
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MR. COUGHLIN:
Okay, thank you.
Richard Pease, from the New Hampshire DF~
MR. PEASE:
I would first like to note that
the State of New Hampshire has been an active participant in
the investigation of the South Municipal Well site sin:;e the
time of the di scovery of the si te through a sampling h~' the
New Hampshire Water Supply & Pollution Control Commission.
[Speaker requested to move closer to
recording microphone.]
MR. PEASE:
The State of New Hampshire has
, \
conducted a hydrogeological study of the site area prior to
the inclusion on the national priorties list, and during the
Superfund remedial process the State participated in the
monthly progress meetings that were conducted by New
Hampshire Ball Bearing and the EPA and their consultants.
Also the Department of Environmental Services
reviewed all the technical submittals that were made to the
Environmental Protection Agency, and has participate1l in the
management and review meetings.
And therefore, all this
involvempnt by the Department of Environmental Services, we
have no objections to the proposed plan.
MR. COUGHLIN:
Thank you.
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MR. SAMIDE:
[PronunCiation
"Samide"
2
distinct~onJ.
3
MR. COUGHLIN:
Excuse me.
"Samide."
4
MR. SAMIDE:
My name is Michael Samide, I'm
5
the president of New Hampshire Ball Bearings.
I apologize
6
for not being able to make your meeting two weeks ago, I was
7
out of to~n.
8
New Hampshire Ball Bearings considers the
9
Town of Peterborough and its employees, its business here
very important -- "the" most important thing we have.\
We're
in agreement with the Federal EPA, and we've worked very
closely with them, and the State EPA. We have aggressively
pursued the remedy of the situation up there, and will
continue to do so.
For Over a year and a half now we have been
processing the contaminated groundwater, and we will continue
at a very aggressive pace to clean this up in the most
expeditious manner we can.
To date we've spent three million
dOllars, and we are committed to do what's right for
Peterborough and this company.
We have other plans, with regard to some of
the comments that Mr. Hoffman made, to alleviate some of the
town's problems and concerns of the water usage.
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actively implementing a situation where we think we can save'
2
the town a million gallons of water a day by recycling t
3
existing well water now, thus reducing our share of the
4
tcwn's usage by some 20 percent.
5
We agree with the EPA, Mr. Duwart's comments;
6
tl~t a one-to-two system air stripping thing, and we would
7
hope that we coqld finalize that in the design phase.
The
a
important thing is, from our perspective, timeliness and
9
cost-effectiveness, and to us the longer we wait and the more
. --~
time that drags on, the more it costs us.
So time isiof 'the
essence.
And the last comment I would like to mak
s
specifically to Mr. Hoffman -- New Hampshire Ball Bearings
has no intention of purchasing the South Well at this point
in time; we're not even entertaining that.
So you can rest
assured we will not be doing that.
Those are my comments.
MR. COUGHLIN:
Thank you.
Mr. Thompson.
Jim Thompson.
MR. THOMPSON:
Okay.
I'm Jim Thompson with
New Hampshire Ball Bearing, and I'd like to add a i~w
comments on the alternative proposals that New Hampshire Ball
Bearing presented at the previous meeting, and the one-to-~wo
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New Hampshire Ball Bearing feels that one
2
system can be very effective, and we mean one system,
we me,
3
the stripping towers and using extraction wells to pump frof
4
both the plume area near the plant but also what we call the
5
dilute plume across the road and in the area of EM-I09 and
6
EM-I03 as you see on that map right there -- I guess we coul
7
call it a map -- (referring to overhead projection display>
8
9
MR. COUGHLIN:
This being the dilute plume
area (indicating on overhead projection map).
MR. T~OMPSON:
out in that area.
And in
'the earlier discussions there may have been some confusion as
to what we were really looking at, and at this point we
believe expansion of the existing stripping tower system that
is at the northeast corner of our plant -- would you please
point to that.
[Mr. Coughlin complying.]
MR. THOMPS0N:
Thank you.
Bringing that to a
larger pumping capacity and using extraction wells as far
east in that plume as both the EPA and the Company work out
in detail in the design phase, can be an effective timely
remediation.
It can also be much more" cost-effective for the
Company.
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million dollars that we can save using that; that is a
2
significant saving~ to the Company.
And we hope thatt~~ EP;
3
will write the Record of Decision such that this can be
4
strongly considered in the design phase.
Even to the point
5
where the Company is willing to quickly expand that system ~-
and when we say n<;uickly" we mean in the next few months and
7
not next year -- Such that it will provide additional data
8
from both the di l,.te plume and the plume near our plant that
'9
we can use in our modeling and in the calculations to get a
. "-'"
better handle on just how long it will take to clean it up.
. \
A point we wish to make very clearly when we
discuss one system versus two system:
we can always go to
the second system.
Good information, better information can'
be gathered by expanding that single system and quickly using
"live" informati~n as opposed to the theoretical calculations
which got us to the estimate of some seven to 20 years or
whatever -- the seven to 30 years that we're looking at at
this time.
The Company is willing, and we'll be
discussing that with EPA and seeking support for that
expansion in the coming months as we go parallel into the
process of Record of Decision, through Consent Decree, and
down through des1gn phase and effectively into remediati
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the coming months next spring.
2
As far as the soil, I think we've made it
3
very clear as we are fairly -- in fact, we're comfortable
4
with the proposals for the soil cleanup.
As far as the
5
sediments, the Company does have alternatives that we would
6
like to pursue and to take some more time to do that.
The
7
contamination in that sediment area attaches itself to the --
8
the sediment to the soil, it is not migratory at this point.
9
A few months to gather some more information, to talk some
. -....
more issues that we would like to discuss with the EPA, may
help us find a more cost-effective solution.
So we are
proposing and, to reiterate, requesting the EPA to write the
Record of Decision with some flexibility that this may be
considered.
Thank you.
MR. COUGHLIN:
Thank you.
Okay, Mr. Dyer, Peterborough Board of
Selectmen.
MR. DYER:
On behalf of the Peterborough
Board of Selectmen, my name is Martin Dyer and I'm chairman
of the Board of Selectmen this year.
We would like to say and be on record as
supporting the work that Ball Bearing is doing and has done;
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stepped forward very early and have done more than were aske(
2
to do in trying to clean up the well.
3
We would like to see it cleaned up in the
4
shortest possible time, and if that means changing the methoc
5
or removing the solvents from the ground or something, we
6
would approve that.
We would hope that the Record of
7
Decision would be written in such a fashion that allows a
8
degree of flexibility both to Ball Bearing and to EPA.
There
9
may be some methods that come along in the next year or two
. --~
that could be very useful, and we would hate to see the
\
decision written so that it was very rigid and new policies
could not be followed.
We would like to see this clean~~ up
in the best possible way.
We agree with the New Hampshire Ball Bearing
people, we have met with them.
We have also reviewed the
report of the EPA, and we agree with them that the method
outlined for the soil seems to be the proper method.
On the
sediment we would like to see additional study done as to
capping or removal, and whichever is the best method.
w
As far as the stripping tower goes, we would
like to see any method that keeps the cost down to our
employer here in town, and a company that is in business to
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some method that wasn't appropriat~.
We would hope that the
2
Record of Decision would be flexible so that if one tower,
3
two towers or three is the b~st, that could be put into use.
4
We hope to clean the area, clean the well up,
5
and possibly use it in the future~
I think it would be some
6
years before we do get a chance to use it.
We are in
7
reasonably good shape now.
As Ted has pointed out, we are
8
getting most of our water from the North aquifer which could
9
.
present a problem under certain circumstances.
The present Board of Selectmen, and Iithink
others that might follow us, have no intention of selling,
leasing, loaning or disposing of any water source that we
presently have or may acquire in the future.
We still have
water rights to Cunningham Pond which haven't been used in
probably 20 years.
So we will maintain or keep POssession of the
South Well, and hopefully it will be cleaned up in the
shortest Possible time at the lowest cost to all parties
involved 50 that we can proceed and move forward.
Thank you.
MR. COUGHLIN:
Thank you.
Anybody else who would like to make a
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MR. THOMPSON:
A comment I would like to make
2
that I forgot to make:is New. Hampshire Ball Bearing is - ~y
3
interested in the public's comments.
On the table in the
4
back I put a no~e, a piece of paper with my name, our
5
address, and my telephone number -- I'm Jim Thompson.
And if
6
any of the public would like to know more about New Hampshire
7
Ball Bearing's position or any information that we can
8
provide the public, we invite them to call me and we will
9
arrange for that information to be provided.
And -- that's
. ".'"'
it, thank you.
MR. COUGHLIN:
Thank you.
If there are no more comments, let me
officially declare the hearing closed.
QUESTION-AND-ANSWER SESSION
MR. COUGHLIN:
We can now go into a
question-and-answer session.
If anybody has any questions
that are in need of answer, we'd be happy to try to address
them for you.
Yes, sir.
MR. DUNBAR:
Are you taking general comments,
too, or --
MR. COUGHLIN:
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25
question-and~answer session now.
This will be trans~ribed
2 .
well.
You can make
3
(Inaudible comment.]
4
MR. COUGHLIN:
Okay.
5
MR. DUNBAR:
r wa~ glad to hear Mr. Dyer's
7
Comments and Concerns for New Hampshire Ball.Bearing's
financial well-being, but speaking as a member of the town
8
and someone who uses the water, my first Concern is the
9
health and welfare of the citizens of Peterborough and
secondary would be the Concern for the financial wel(are of
\.
an employer, and I would hope that would be the concern of
the Town, too.
My second Concern is that other ~atepayers in
the town are not -- and I'm not Sure if they are or not --
supporting the cleanup of the South Well through any
increases in rate charges or work that had to be done ahead
of schedule because of the loss of one well.
MR. COUGHLIN:
Okay, thank you.
[Court reporter requesting name of speaker.]
MR. COUGHLIN:
Oh yes, would you state your
name please.
MR. LEEDHAM:
I would justanswetone part of
that, Andy, in saying that we had thought -- I'm not Sure
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where this fits in with the EPA's schedule, b~t --
2
MR. DUNBAR:
(Interposing)
Charles, he
~ed~
3
a name.
Andrew Dunbar -- D-U-N-B-A-R.
4
MR. LEEDHAM:
Is it okay now?
Okay.
Andrev
5
Dunbar.
6
We assum~d that it went without saying that
7
we are primarily concern~d about the quality of the water anc
8
the continuation of adeqoate water supply for the Town of
9
Peterborough, and our concern for the financial arrangements
. -.'"
of New Hampshire Ball Bear ings is defini tely' ,secondarl' but
it's something that we do take into account because they are
a citizen of the town and a major employer.
MR. COUGHLIN:
Any other' questions?
Yes,
sir.
MR. SAMiDE:
I'd just like to, reiterate my
point for Mr. Dunbar, that New Hampshire Ball Bearings is
concerned about the water supply also and has taken methods
-- steps right now to b~ sure that Peterborough has the water
supply; that everything that we can possibly do we're
,..
implementing right now, in terms of cutting our usage,
basically, to almost zero.
MR. COUGHLIN:
Mr. Dyer.
MR. DYER:
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1:
was said by the president of Ball Bearing.
They have gone tc
considerable expense to themselves -- it's going to save ther.
3
money -- to redo their plumbing and their Cooling machines
4
and other devices, to reduce, if possible, gallonage of
5
disposable water that they're using by up to a million
6
gallons a day.
This will make a substantial saving to the
7
amount of water that we're pumping from the North Well at
8
this time.
9
Part of our problem a year ago was
inefficient and too small pipes connecting the Summeri Street
. Well with Main Street and some of the pipes on Sanville (ph)
Road.
That is being corrected now.
That is being corrected
.with water department funds.
It does not come out of the
taxpayers' money, it comes out of the water department funds,
paid by water department users.
This was necessary anyway,
whether the South Well was operating or not.
But I think
Ball Bearing is taking a good lead here in reducing the water
usage, and I think we could all take a line from that and try
and conserve water.
I think water is going to turn out to be
one of our most precious commodities that we have.
MR. DUNBAR:
Could someone from New Hampshire
Ball Bearing perhaps let us in on what steps are being taken
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MR. THOMPSON:
The Company at this
Ah yes.
.2
time -- all volatiles, all the chemicals that are used :-th,
3
plant are handled in the strict accordance with current
4
regulations, all drains -- there is no discharge to the
5
environment that we know of.
We've gone to great pain in t~e
6
past 10, 15 years to upgrade.
It actually started in the
7
seventies.
Our knowledge got better in t~je mid- to late-
8
seventies in controlling this.
The condi.ions which have
9
occurred over the years occurred in the fifties, sixties, and
. -.'"
early seventies, as far as we can tell, although it's sketchy
to go back and gather all the data.
But certainly, in this
modern age, in the eighties, all discharges and controls were
implemented to prevent discharges to our environment.
So
we're very, very concerned about that.
I'd like to -- may I Cornrn~nt on, to support
or provide some more information to the public on what the
Company has done.
Think of that stripping tower system at
the northeast corner of the building.
We made the decision
-- with support from the EPA, but it was a Company decision
c I
-- to put that system in place; we made that in about 186 --
designed it in '87, late '87.
While the formal process was going on, we put
about a million dollars in the northeast corner's system.
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datei as of the end of July, in the past year to 15, 16
2'
months, some 30 million gallons have been pulled out of the
3
ground and sent through the stripping system and cleaned up.
4
So we've aggressively taken that stance with
5
a parallel effort tO,the formal process that EPAhas to go
6
through by law.
So I think it's a credit to New Hampshire
7
Ball Bearing to -- on a, plus side, also, that that was made
by our senior ,management back some two years ago.
. ,
And a point I think it makes very 'handily --
. -.."
y=s, New Hampshire Ball Bearing is extremely concer,ned that
the Town has water.
We want to clean it up.
We, believe we
have some alternatives that makes some good seri.~, too.
Thank you.
'MR. COUGHLIN:
Anybody else?
(No response.]
,MR. COUGHLIN:
If not, I guess we'll bring it
to a close.
Thank you very much for coming.
We appreciate
your comments.,
Thank you.
SELECTMEN CHAIRMAN:
Thank you, Dan.
Illl
call a five-minute recess now.
. .
. [The EPA public hearing was concluded at
8:05 p.m., August 3, 1989.]
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1.
COURT REPORTER'S CERTIFICATION
3
4
I, Richard E. Cowing, a certified court reporter in
the State of New Hampshire, do hereby certify that the
foregoing is a true and accurate transcription of the
public proceedings conducted at Peterborough, New Hampshire,
on Thur~day, ,August 3, 1989 relative to the EPA Proposed
Cleanup Plan for the South Municipal Well, to the best of my
. -...
knowledge and belief, professional skill~ and abilit~es, and
. ..
under the conditions of the recording environment.
~~.
Richard E. Cowing, CS
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APPENDIX D
ADMINISTRATIVE RECORD INDEX
(Vo-t
/11 C. itA..- cI e ell
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