United States
Environmental Protection
Agency
Office of
Emergency and
Remedial Response
EPA/ROD/R01-89/046
March 1989
4>,£PA Superfund
Record of Decision:
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50272-101
REPORT D()CUMENTATION 1'. REPORTNO.
PAGE EPA!ROD/ROl-89/046
I ~
3. Recipienra Acce..lon No.
4. Tide and Subdue
SUPERFUND RECORD OF DECISION
'~,nkham' s Garage, NH
.rst Remedial Action (Amendment)
-.
7. Author(a)
5. Repon Date
3/10/89
6.
I. Perfonning Organization Rept. No.
9. Perfonnlng Orgalnlzation Name and Addre..
10. Projec1lTasklWork Unit No.
11. Conlr8ct(C) or Grant(G) No.
-
(C) ,
(G)
1~ Sponaorlng Organization Name and Addre..
U.S. Environmental Protection
401 M Street, S.W.
Washington, D.C. 20460
13. Type 01 Report & Period Covered
-
Agency
800/000
14.
15. Supplementary Notea
16. Abatract (Limit: 200 worda)
The Tinkham's Garage site includes 375 acres of residential and undeveloped land in
Londonderry, Ne~ Hampshire. EPA site investigations in 1981 revealed onsite soil and
ground water contaminated with VOCs resulting from onsite surface dumping of liquids
and sludge in 1978 and 1979. The major contaminated soil area is in a field behind
Tinkham's Garage. Two other source areas include a soil pile behind a condominimum
~-~plex and soil overlying the condominimum complex leach fields. The ground water
,erlying the major source areas and the bedrock aquifer underlying the site are
contaminated as well. Approximately 400 people residing in a condominium complex on
the western border of the site, residents of numerous single family homes to t~e
north of the site, and nearby wetlands may be potentially impacted by onsite
contamination. The first remedial action selected for ,the site was documented in a
1986 Record of Decision, (ROD), which included excavation of approximately 10,800
cubic yards of contaminated soil with onsite treatment using either thermal aeration,
composting or soil washing. Local wetlands impacted by soil excavating activities
and contaminated ground water were also to be remediated. Information generated
during a pre-design study led EPA in 1988 to propose this amendment to the 1986 ROD.
As a result of the pre-design study findings, the remedial action selected in the
(See Attached Sheet)
'"
17. Document Analyala' L Deacriptors
Record of Decision - Tinkham's Garage, NH
First Remedial Action (Amendment)
Contaminated Media: soil, gw
Key Contaminants: VOCs (PCE, TCE)
""
b. ldentlfiera/Open-Ended Terma
,
c. COSA TI Field/Group
~ailability Statement
19. Security Clan (Thia Report)
None
21. No. 01 Pagea
102
20. Security Clan (Thia Page)
NnnA
2~ Price
(See ANSI-Z39.11)
See InstrucUons on Reverse
212 (4-11)
(Formerty NTIS.35)
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EPA/ROD/R01-89/046
Tinkham's Garage, NH
First Remedial Action (Amendment)
Abstract (continued)
1986 ROD. As a result of the pre-design study findings, the remedial action selected in
the 1986 ROD was never implemented~ The primary contaminants of concern affecting the
soil and ground water are VOCs including TCE and PCE.
The selected remedial action for this site includes onsite treatment of approximately
9,000 cubic yards of contaminated so~l from all three source areas using a dual .vacuum
extraction method designed to extract vapors from unsaturated soil and to pump shallow
ground water; treatment of the soil pile and leachfield soil will be in situ or the
soil will be excavated, consolidated and treated with the garage soil; extraction of
contaminated ground water from the shallow zone via extraction wells and treatment
onsite before combining with ground water pumped from the deep zone, followed by
discharge to a POTW; and monitoring of wetland water levels. Present worth or total
capital costs were not specified.
'"
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AMENDED RECORD OF DECISION
SITE
- _0'
.--" ~
,.J
Tinkham's Garage site
Londonderry, New Hampshire
March, 1989
STATEMENT OF PURPOSE
.. (.
This docume~t formally specifies changes to the Record of ,
Decision issued for the Tinkham's Garage site in september 1986.
The Amended Record of Decision describes the changes adopted,
presents an evaluation of treatment technologies, and presents
the rationale for ~mending the 1986 Record of Decision.
This decision was developed in accordance with the Comprehensive
~r.viro.~ental Response, Compensation and Liability Act of 1980,
as amended (CERCLA), 42 U.S.C. SS 9601 et sea., and to the extent
practicable, the National Contingency Plan (NCP), 40 C.F.R. Part
300 (1988). The Regional Administrator has been delegated the
authority to approve this decision.
STATE CONCURRENCE
The State of New Hampshire has concurred on the selected remedy
and determined that the selected remedy is consistent with New
Hampshire laws and regulations.
STATEMENT OF BASIS
This decision is based on the Administrative Record which was
developed in accordance with Section 113(k) of CERCLA and which
is available for public review at the Leach Public Library
(LondonderIT, New Hampshire) and the EPA Region I Records Center
(Boston, Massachusetts). An index identifying the components of
the Administrative Record is attached as Appendix A.
RECORD OF DECISION AMENDMENT SUMMARY
f'
As a consequence of information generated during the Tinkham's
Garage site Pre-Design Study, EPA proposed in August 1988 to
amend the Record of Decision signed September 1986. The
"Londonderry Site Proposal to Amend the Record of Decision" has
been presented to the public and an opportunity for public
comment has been provided.
The changes to the 1986 Record of Decision address primarily the
nature of the soil treatment technology. The 1986 decision
specified either composting, soil washing, or thermal aeration as
'the soil treatment technologies for site remediation. The
Amended Record of Decision specifies the following remedial
actions for the Tinkham's Garage site:
-------
.
Areas of the site having soil with greater than 1 mg/kg
(ppm) volatile organics including the garage area,
condominium leachfields I/J and K/L, and the soil pile
located behind the condominium complex will be remediated to
1 mg/kg or less total volatile organics (VOCs). Remediation
of the soils will utilize vacuum extraction wells equipped
to pump shallow groundwater and simultaneously extract
vapors from the unsaturated soils. The degree of
remediation will be determined following evaluation of
operational and sampling data.' At a minimum, soil will be
treated to 1 mg/kg total VOCs.
.
Remediation of the soil pile and leach field will utilize
vacuum extraction either in situ or the contaminated soil
will be excavated, consolidated with other source material
at the garage area, and treated using vacuum extraction as
determined during the design phase.
.
When evaluation of systems operation data suggests that the
soil has been remediated to a total mass VOC of 1 mg/kg or
less, the soil will be sampled in accordance with an EPA
approved sampling and analysis plan to evaluate the status
of soil remediation. If the sampling results indicate that
soils have not been remediated below the 1 mg/kg VOC
threshold, a decision will be made to either continue vacuum
extraction for a specified length of time and resample or to
complete the rem~dy with some other suitable technology.
The decision on the ultimate degree of treatment (treatment
level) by vacuum extraction will be based on the technical
feasibility~ reliability, and cost effectiveness of
continued treatment to below 1 mg/kg total VOCs. Treatment
levels of less than 1 mg/kg will be selected if they can be
achieved without substantial increases in remediation costs.
Treatment of contaminated groundwater will be achieved in
accordance with the 1986 Record of Decision except that.
shallow groundwater underlying contaminated source material
behind the garage will be extracted using the dual
extraction wells which simultaneously draw air through the
contaminated soils and extract shallow groundwater. The
groundwater remediation objectives are 5 ug/L of
Trichloroethylene and Tetrachloroethylene, respectively, in
both the shallow and bedrock aquifers.
'.
-------
DECLARATION
The remedy selected and described in this Record of Decision
Amendment is protective. of public health and the environment,
attains federal and state requirements that are applicab~e or
relevant and appropriate and is cost effective.. This remedy
satisfies the statutory preference for treatment that permanently'
and significantly reduces the volume,' toxicity, and mobility of
the hazardous substances, pollutants and contaminants as a
principal element. Finally, it is determined that this remedy
utilizes permanent solutions and alternative treatment
technologies to the maximum extent practicable..
3/1 ~ /??i.
Dat.e
17~~
Michael R. Deland
Regional Administrator
~
-
'"
'"
.I
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I.
II.
A.
B.
C.
TABLE OF' CONTENTS
INTRODUCTION
site Background
Enforcement History
Purpose of the Amended Record of Decision
AMENDMENTS TO THE 1986 RECORD OF DECISION
III. SUMMARY - TREATMENT TECHNOLOGIES SPECIFIED IN THE
SEPTEMBER 1986 RECORD OF DECISION
IV.
V.
VI.
'"
VII.
A.
B.
A.
B.
C.
Source Control
Management of Migration
PRE-DESIGN STUDY SUMMARY
Pre-Design study Purpose
Extent of Soil and Groundwater Contamination
Soil Treatment Technology Evaluation
EVALUATION OF. SOIL TREATMENT TECHNOLOGIES
A.
B.
statutory Requirements.
Response Objectives/Technology and Alternative
screening
Analysis of Technologies
Rationale for Selection of Vacuum Extraction
C.
D.
STATUTORY DETERMINATIONS
A.
The Selected Remedy is Protective of Human
Health and the Environment
The Selected Remedy Attains ARARs .
The Selected Remedy is Cost Effective
The Selected Remedy Uses 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.
COMMUNITY RELATIONS
VIII. STATE ROLE
"
1
1
1
2
3
5
5
5
6
6
7
7
8
8
9
10
20
21
22
22
21
22
22
23
23
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APPENDICES
Appendix A
Administrative Record Index
. Appendix B
Appendix C
Responsiveness Summary
Federal and State ARARS
Appendix D
State of New Hampshire Declaration of
Concurrence
'"
./
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Tinkham's Garage Site - Amended ROD
page 1
I.
INTRODUCTION
A.
site Backqround
The Tinkham's Garage site (Site) includes 375 acres of
undeveloped and residentially developed property located
near the intersection of Interstate Route 93 and State Route
102 in Londonderry, New Hampshire. EPA evaluated the
Tinkham's Garage site between ~981 and 1986 prior to the
issuance of the September- 1986 Record of Decision. From its
investigations, EPA identified soils and groundwater that
were contaminated with volatile organic compounds. The
major soil source area is located in a field behind the
Tinkham's Garage. Two other source areas identified include
a soil pile located behind the Woodland village Condominium
Complex, and soils overlying the condominium complex
1eachfie1ds. Shallow groundwater underlying the source area
behind the garage is contaminated with volatile organics as
is the bedrock aquifer underlying the Site. A more detailed
description of contaminant distribution can be found in the
Tinkham's Garage Remedial Investigation and the Tinkham's
Garage site Pre-Design Study. .
The Record of Decision issued in September 1986 specified:
.
Source remediation of contaminated soil: contaminated
soils containing greater than 1 mg/kg total volatile
organic compounds (VOCs) will be treated by one of
three treatment technologies (thermal aeration,
composting, or soil washing). Soils will be treated to
a level that will be determined by EPA based on
technical feasibility, reliability, and cost
effectiveness. At a minimum, soil will be treated to 1
mg/kg total VOCs. .
.
Manaqement of miqration: Groundwater will be pumped
from deep bedrock wells and from shallow recovery
trenches and discharged- to the Derry, New Hampshire
Publicly Owned Treatment Works (POTW). Groundwater
wifl be pumped to the Derry POTW until the indicator
compounds, Trichloroethylene and Tetrachloroethylene,
have been reduced to 5 ug/L (ppb) each.
B.
Enforcement Historv
The PRPs and the state and federal governments have been
involved in negotiations regarding the Tinkham's Garage site
and three related Superfund sites since May 1, 1986.
Following issuance of the Record of Decision, EPA negotiated
an agreement to have a group of PRPs conduct Pre-Design
studies. An Administrative Consent Order was entered into'
on September 11, 1987 by EPA and a group of PRPs that
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Tinkham's Garage Site - Amended ROD
- page 2
Bench and pilot scale evaluations on the
effectiveness of soil treatment technologies:
.
Generation of data on the full extent of soil
contamination at the Site; and
.
Hydrologic and chemical evaluations of
groundwater. .
The results of this study are presented in the Pre-Design
Study Report and summarized in section III of this document.
On August 3, 1988, a Consent Decree was lodged containing a
comprehensive settlement of the Cannons Engineering
Corporation Superfund Case (Cannons Case) in the United
States District Court in Boston. The Cannons Case includes
four Superfund hazardous waste sites:
1.
The Cannons Engineering Corporation Bridgewater Site,
Bridgewater, MA
2.
The Cannons Engineering corporation PlYmouth Harbor
Site, -.PlYmouth, MA
3.
The Tinkham's Garage Site, Londonderry, NH
4.
The Gilson Road Site, Nashua, NH
The settlement includes cash paYments of approximately $17
million and commitments by the settling Parties to conduct
the remedies at the Cannons Bridgewater Site, the Tinkham's
Garage Site, and a removal of soils from the PlYmouth Site.
At the Tinkham's Garage Site, the Settling Parties have
agreed to undertake the remedial action selected by EPA in
the 1986 Record of Decision and any amendments thereto. The
major change to the Record of Decision that will be
implemented by the Settling Parties is selection of vacuum
extraction as the soil treatment technology for volatile
contaminated soils at the site. This revised approach to
~oil treatment is described herein and in the Pre-Design
Study Report and the Londonderry site Proposal to Amend the
Record of Decision.
C.
Purpose of the Amended Record of Decision
The purpose of the Amended Record of Decision is to formally
specify changes to the previously issued Record of Decision.
The Amended Record of Decision describes the changes
adopted, presents an evaluation of technologies which were
considered pursuant to the original Record of Decision and
..
"
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Tinkham's Garage site - Amended ROD
page 3
:II:.
those that were proposed in the Proposal to Amend the Record
of Decision. In addition, it presents the rationale for
changing the Record of Decision, the state and public
perspectives on the change, an explanation of how the change
differs from the original Record of Decision, and a
Responsiveness Summary which is EPA's response to pub~ic
comment on the change. .
The Amended Record of Decision specifies soii treatment- by a
dual vacuum extraction method. This decision contains no
significant changes from the previously issued Proposal to
Amend the Record of Decision.
Amendments to the 1986 Record of Decision
As a result of the information generated during the Pre-Design
study, EPA proposed to amend the Record of Decision in the
"LondonderrySite Proposal to Amend the Record of Decision:
August, 1988." That document describes the proposed change~ to
the 1986 Record of Decision and describes the significant
differences between what was specified in the 1986 Record of
Decision and what was being proposed. The remedial action
selected and specified in this ROD amendment does not contain any
significant changes from that proposed in August 1988. The
amended remedy includes:
.-
Source remediation of contaminated soils containing greater
than 1 mg/kg total VOCs from the garage area, leachfields
I/J and K/L, and the soil pile down to a treatment level
that will be determined following evaluation of field
operation and sampling data. The degree of cleanup will be
based on technical feasibility, reliability, and cost
effectiveness. At a minimum, soils will be treated to a
total mass volatile organic concentration of 1 mg/kg.
Treatment levels less than 1 mg/kg will be selected if they
can be attained without substantial increase in remediation
cost. Remediation of the soils will utilize vacuum
extraction wells equipped to pump shallow groundwater and
simultaneously extract vapors from the unsaturated soils.
Remediation of the soil pile and 1eachfie1d soils will be
treated by in situ vacuum extraction or these soils will be
excavated, consolidated and treated by vacuum extraction in
conjunction with the garage area soil remediation. When
evaluation of systems operation data suggests that the soil
has been remediated to a total mass VOC of 1 mg/kg or less,
the soil will be sampled in accordance with an EPA approved
sampling and analysis plan. If the sampling results
indicate that soils have not been remediated below the 1
mg/kg VOC threshold, a decision will be made to either
continue vacuum extraction for a specified length of time
.I
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Tinkham's Garage Site -Amended ROD
page 4
and resample or to complete the remedy with another suitable
technology.
Management of migration remediation will be accomplished in
a manner similar to that identified in the September 1986
ROD. Groundwater will be remediated by pumping the two
condominium wells, identified as LGAW and LGSW, as well as
extracting shallow groundwater via the dual vacuum
extraction system from the garage area. The contaminated
shallow groundwater extracted with the dual extraction wells
during soil remediation will be treated on-site before being
mixed with the water fr9m the condominium wells. Shallow
and deep groundwater will. be pumped via town sewers to the
Derry POTW where it will. be treated. Shallow and deep
groundwater remediation will continue until the groundwater
remedial objective of 5 ug/L PCE and TCE has been reacheu
for all on-site wells or for two years, at which time an
eva.1uation of remediation status, and a determination of
whether to continue pumping, will be made. .
The amended Record of Decision.specifies changes to the soil
treatment technology by selecting vacuum extraction, a technology
not specified in the 1986 ROD. The soil cleanup levels have been
retained from the 1986 ROD which specified that soils would be
remediated to a level chosen following selection of the treatment
technology. The 1986 ROD first established the 1 mg/kg cleanup
threshold as a level that would significantly reduce the
contaminant mass in source areas, was protective of public health
for direct contact exposures, and would. result in reduced
contaminant loading to groundwater during remediation. The
ultimate treatment level would be determined based on technical
feasibility, reliability, and cost effectiveness and be selected
consistent with RCRA Delisting procedures, but would, at a
minimum, require total VOCs to be reduced to 1 mg/kg.
.
The Delisting procedures were established for RCRA hazardous
wastes. A review of the contaminants of concern indicate that
there are no identifiable RCRA hazardous wastes at the Tinkham's
Garage site. In addition, there are no EP TOX criteria for any
of the Tinkham's Garage site contaminants of concern. Therefore,
the Delisting procedures, which are RCRA waste specific and
compound specific, will not be applicable to establishing'
treatment levels for this site.
As specified in the 1986 ROD, the ul~imate degree of treatment
will be based on technical feasibility, reliability, and cost
effectiveness, and be at least to 1 mg/kg total VOC. Treatment
levels less than 1 mg/kg total vbCs will be selected if they can
be attained without substantial increase in remediation costs.
The management of migration component of the 1986 Record of
Decision has essentially been embodied in the amended ROD. One
modification to the i986 ROD is the use of dual extraction wells
;
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Tinkham's Garage Site - Amended ROD
page 5
to simultaneously draw air through the contaminated soils and
pump shallow contaminated groundwater. The 1986 ROD had
specified use of trenches to capture the shallow groundwater.
The groundwater treatment goals of 5 ug/l TCE'and PCE have been
retained from the 1986 ROD. ' '
III. SUMMARY - TREATMENT TECHNOLOGIES SPECIFIED IN THE SEPTEMBER
1986 RECORD OF DECISION
A.
Source control
The Record of Decision signed for the site in September 1986
specified excavation of contaminated soils with on-site
treatment as the source control alternative. The components
of this action included:'
soil treatment by either thermal aeration, compostinq,
or soil washinq. Treatability studies are to be
performed to evaluate these technologies.
Excavation and treatment of soil located behind the
Tinkham's Garage by one of the above technologies.
Some of the soils to be treated are located in a
wetland. Best engineering practices will be employed
to minimize'adverse impacts to the wetland as well as
restoration activities following excavation and
treatment. '
Posting of hazard sighs in the field area behind the
Garage.
Sampling of potential soil source areas in the Woodland
Village Condominium Complex (leachfields, soil pile and
swale) to determine the need for remediation.
Returning treated soils to the excavation locations
followed by regrading and revegetating.
On-site soil treatment will proceed to a level that will be
determined by process optimization studies. The extent of
treatment (treatment level) will be based on technical
feasibility, reliability, and cost-effectiveness. The level
will be determined consistent with RCRA delisting procedures
and remedial objectives. At a minimum, soil will be treated
to 1 ppm of total volatile organics.
B.
Manaqement of Miqration
The manasement of migration component of the Record 'of
Decision signed for the site in September 1986 addressed
remediation of contaminated groundwater. The Record of
...
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Tinkham's Garage Site - Amended ROD
page 6
Decision specified removal of contaminated groundwater from
the shallow aquifer underlying the garage area soils and the
bedrock aquifer underlying the condominium complex, and off-
site treatment at the Town of Derry POTW,Which may be
preceded by on-site pretreatment with monitoring.
Groundwater treatment is to proceed until treatment goals
are met or for a. two year period from the date pumping of "
shallow and deep groundwater begins. At the end of the two-
year period, an evaluation will be made by EPA to assess
progress in meeting objectives for the cleanup of
groundwater at the Site. If steady state conditions have
been reached, and it is evident remedial objectives are not
achievable, EPA will re-evaluate the objectives and its
approach to groundwater remediation. Groundwater
remediation will cease upon achieving 5 ug/L (ppb) of
tetrachloroethylene and trichloroethylene, respectively, in
every well on-site and in the collection trench for shallow
groundwater collection behind the garage. Upon achieving
these goals a final determination will be made to determine
if water quality is protective of public health and the
environment. "
Wetlands will be monitored to ensure no detrimental effects
occur as a consequence of groundwater extraction.
IV.
PRE-DESIGN STUDY SUMMARY
A.
Pre-Desiqn study Purpose
The Pre-Design Study was conducted by a group of potentially
responsible parties with EPA oversight to determine more'
definitively the extent of soil and groundwater
contamination associated with the Site and to evaluate soil
treatment technologies. Sp"ecifically, the following issues
were addressed:
1.
Delineation of the volume and characteristics of soil
that requires remediation~
2.
Collection of analytical data concerning the chemical
and hydrogeological characteristics of the leachfields;
3.
Bench-scale and pilot-scale tests of soil remediation
technologies; "
4.
Characterization and evaluation of treatment
requirements of groundwater to be remediated; and
5.
Verification of groundwater pumping effects on local
aquifers.
~
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- Tinkham's Garage site - Amended ROD
page 7
B.
Extent of Soil and Groundwater contamination
The study concluded that approximately 9,000 cubic yards of
soil would require remediation: 6,500 cubic yards of garage
area soils: 2,000 cubic ya~ds of leachfield overburden soils
associated with two condominium leachfield systems: and 500
,cubic yard9 making up the soil pile behind the condominium
complex. '
Pumping of the condominium complex suppiy wells verified
that a connection exists between the garage area
- intermediate/deep bedrock aquifer and the pumping wells due
to a major fracture set in the bedrock. This fracture set
'hydraulically connects the garage source area to the
condominium supply wells. Wells located perpendicular to
the fracture set such as those along Ross Drive showed
little or no hydraulic connection to the contaminated deep
aquifer. At this time, the residential wells along Ross
Drive appear to be at low risk to contamination from the
garage area.
, C.
Soil Treatment Technoloqy Evaluation
Four soil treatment technologies were evaluated. A field
pilot study of vacuum extraction was conducted in the soils
behind the garag~. In addition, laboratory studies of soil
washinq (water extraction) and bioloqical treatment
(composting as identified in the 1986 ROD is considered
analogous to biological treatment) were conducted with site
soils. Data from these studies along with existing data
from thermal aeration studies were used to evaluate the
technologies which were contemplated in the 1986 ROD as well
as vacuum extraction. Vacuum extraction was not selected in
the original ROD.
Current data indicates that thermal aeration is capable of
treating soils to 1 mg/kg (ppm), which is the minimum
treatment level specified in the 1986 ROD. The bench and
pilot scale studies indicated that vacuum extraction and
biological treatment can treat contaminated soil to 1 ppm
total volatiles within a two year time frame. Laboratory
studies of water extraction indicated that this approach was
less feasible than other approaches considered due primarily
to the large quantities of water that would be required to
reach treatment goals and the process complexities resulting
from the excessive quantities of water which would be
required.
I
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Tinkham's Garage Site - Amended ROD
page 8,
V.
EVALUATION OF SOIL TREATMENT TECHNOLOGIES
A.
Statutory Requirements
Prior to the passage of the Superfund Amendments and
Reauthorizat,ion Act of 1986 (SARA), Pub. L. No. 99-499, 100
Stat. 1613 (October 17, 1986), actions taken in response to
releases of hazardous substances were conducted in accor-
dance with CERCLA as enacted in 1980 and the revised
National oil and Hazardous Substances Pollution Contingency
Plan (NCP), 40 C.F.R. Part 300, dated November 20, 1985.
The September 30, 1986 Record of Decision for the Tinkham's
Garage site was selected in accordance therewith. '
Pursuant to an Administrative Order entered into by EPA and
a group of PRPs, a Pre-Design Study of the site was
conducted. The study included, among other design and field
analyses, an evaluation of the source control remedial
technologies identified in the 1986 ROD. In addition, the
PRPs conducted, on their own initiative, a field pilot test
of vacuum extraction to remediate site soils.
Section 117(c) (3) of CERCLA requires that after adoption of
a final remedial action plan, if any settlement or consent
decree is entered into, and if such action, settlement, or
decree differs in any significant respect from the final
plan, an explanation of the significant differences and the
reasons such changes were made must be published for public
review. Section 121(b) of SARA requires that any ROD that
is reopened to modify or supplement the selection of the
remedy subsequent to the enactment of SARA, shall be subject
to the requirements of SARA. Because EPA is reopening the
ROD to modify or supplement the selection of the source
control treatment technology at the Site, its selection must
be in accordance with section 121. 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 and relevant and appropriate
environmental standards established under federal and state
environmental laws unless a statutory waiver is invoked; a
requirement that EPA select a remedial action that is cost-
effective and that utilizes permanent solutions and
alternative treatment technologies or resource recovery
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-Tinkham's Garage site - Amended ROD
page 9
technologies to the maximum extent practicable: and a statu-
tory prefe~ence for remedies that permanently and
significantly reduce the volume, toxicity or mobility of
hazardous substances over remedies that do not achieve .such
results through treatment.
B.
Response Obiectives/Technoloqy and Alternative
Development and Screeninq
The purpose of the technology evaluation conducted as part
of the Pre-Design study was .to identify the most cost-
effective remedial action"that will effectively mitigate and
minimize environmental threats and provide protection of
public health and the environment consistent with the
environmental standards set forth in the 1986 ROD and
section ~21 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. The nine
factors are: "
1.
Compliance with Applicable or Relevant and Appropriate
Requirements (ARARs).
2.
Long-term Effectiveness and Permanence.
3.
Reduction of Toxicity, Mobility or Volume.
4 .
Short-term Effectiveness.
5.
Implem~ntability.
6.
community Acceptance.
7.
State Acceptanc~.
8.
Cost.
9.
Overall Protection of Human Health and the Environment.
~
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Tinkham's Garage, site - Amended ROD
page 10.
C.
Analysis of Technoloqies
1.
Vacuum Extraction
The vacuum extraction process is an in situ treatment
process which uses enhanced vacuum driven
volatilization to remove volatile organic compounds
from unsaturated soil. The process utilizes dual
vacuum extraction wells equipped to simultaneously pump
groundwater, thus lowering the groundwater table and
inducing a vacuum on the ~esultant unsaturated soils.
Subsurface vacuum propagates laterally, causing in situ
volatilization of compounds absorbed to the soil
particles. The volatilized. compounds follow the air'
flow through the soils to the extraction wells, then
subsequently to a vapor phase activated carbon absorber
for volatile constituent capture.
a. Compliance with ARARs. This technology will
attain all applicable relevant and appropriate
regulations and standards. See Appendix C for a list
of state and federal ARARS. . .
b. Reduction of Toxicity, Mobility or Volume. Vacuum
extraction satisfies CERCLA's preference for treatment
as a principal element. Use of this technology will
significantly and permanently reduce the volume and
toxicity of contaminated soil by lowering the volatile
contaminant concentration throughout the site to the
treatment level of 1 ppm or less. This level, for the'
constituents encountered on this Site, is protective of
human health and the environment as stated in the.
September 30, 1986 ROD and its attainment will minimize
the potential for further releases to groundwater.
Residuals that are left in the soil at this low
concentration will continue to biodegrade and/or
volatilize over time. ~he mobility of the contaminants
found at the site will be significantly and permanently
reduced by their capture on the activated carbon
associated with the vacuum extraction process.
c. Short-Term Effectiveness. The rate of contaminant
removal from the soil is concentration dependent.
Therefore, the bulk of the contaminants will be removed
most quickly in the beginning when the concentration is
highest, and the concentration gradient is greatest.
The effect of this is to significantly reduce the risk
associated with the soils in a very short period of
time. The vacuum extraction technology has the added
benefit of also remediating groundwater at the source
through the dual operational mode of the extraction
wells, whiqh extract both organic vapors and
contaminated groundwater.
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Tinkham's Garage site
Amended ROD
page 11
The risk due to implementation of this remedy is
considered low. It will not require excavation or any
other major disturbance of the soils which could cause
a potentially significant release of volatile compounds
into the air in the garage area. Because excavation is
not required in the area behind the garage, the short
term impact on wetlands will be iess for this
technology than the others considered. Excavation may
be necessary at the leachfields and soil pile.
However, this approach would be required by the other
source control technologies as well. Once the remedy
is operational, volatile compounds will be captured on
activated carbon. The exhaust air will be monitored to
detect carbon breakthrough, and back-up carbon units
will be employed for added reliability and protection.
Because the system operates on negative pressure, any
leaks in the system will have the effect of bringing
ambient air into the system, rather than releasing
volatile constituents.
d. Lonq-Term Effectiveness and Permanence.
Remediation of the soils is expected to be achieved
witnin two years. Because the volatile constituents
will actually be removed from the soils, the
remediation' is permanent.
The Tinkham's Garage site soils consist of a shallow,
low permeability clay layer, 2 feet in depth which is
underlain by a medium grained sand 9 to 13 feet in
thickness. The clay layer is the more highly
contaminated of the geologic strata. Due to the lower
permeability and the possible channelling of recharge
air through preferential pathways, it is uncertain how
long it will take to remediate the clay layer using
this technology. An appropriate sampling program,
including sampling of the clay layer, to confirm the
efficacy of the vacuum extraction approach should
minimize the potential for unremediated hot spots.
continued operation of the vacuum extraction unit
beyond two years, or application of another remedial
technology will ensure that the treatment goals are met
for both soil types.
e. Implementabilitv. In recent years, numerous pilot
and full-scale vacuum extraction systems have been
constructed at sites where s6il types have ranged from
fine sand to sandy loam to clayey silt and silty clay
soils. The depth to groundwater has also varied.
contaminants such as chlorinated sol ve'nts i alcohols I
ketones and petroleum products have been successfully
recovered. The pilot test conducted on the Tinkham's
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Tinkham's Garage Site - Amended'ROD
page 12
Garage Site during the Pre-Design Study demonstrated
the ability of this technology to be installed and
operated at this Site and to extract significant'
quantities of volatile organic compounds from the
soils.
The equipment associated with this technology, PVC
pipe, vacuum pumps, vapor phase activated carbon, .
manometers, well screens, groundwater pumps and other
hardware are readily available. Well drillers,
engineering services and specialty contractors should
also be readily available. An off-site commercial
. facility will be required for the regeneration or
disposal of the spent activated carbon. Because these
facilities are numerous and available, their short-
term availability will have little or no impact on the
execution of remedial activities at the site.
The installation and operation of a vacuum extraction
system will not limit additional remediation at the
site. If a subsequent technology is needed to address
hot spots, or as a polishing step, the vacuum manifold,
vacuum pumps and carbon system could be removed
relatively easily. .
f. Cost. Capital and 0 & M costs for this
alternative' are summarized in Table 3-6 of the Pre-
Design study Report. The unit cost for this technology
is approximately $130 per cubic yard exclusive of
permitting and oversight costs. Because the cost of
treatment of contaminated .soil by this technique is
areally and time dependent, changes in the volume of
soil to be treated mayor may not affect the unit cost
of this technology depending on whether the increased
volume of contamination is with depth or area. In
addition, this technology utilizes a dual extraction
system which will address the most contaminated shallow
groundwater. Directly addressing shallow groundwater
contamination with the dual extraction system should
result in a reduced bedrock pumping regimen, resulting
in cost savings for the management of migration
alternative.
g. Protection of Human Health and the Environment.
1 ppm total mass volatiles cleanup standard for site
soils was developed in the September 30, 1986 ROD.
This cleanup level was selected because it resulted in
significant reduction in the mass of contaminants in
the source area behind the garage, was protective of
public health for direct contact exposures, and would
help accelerate cleanup of the contaminated bedrock
aquifer.
A
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Tinkham's Garage Site - Amended ROD
page 13
Vacuum extraction has been demonstrated as an
innovative technology and is capable of achieving the
treatment level of 1 ppm or less. Further, because the
contaminated groundwater under the garage area soils
will be remediated simultaneously, overall groundwater
remediation will be expedited. In addition, the vacuum
extraction process has inherent design characteristics
that minimize the potential for inadvertent release of
hazardous substances to the environment during the.
treatment process. Any leaks that might develop".wouid
tlraw clean air into the system rather than letting
contaminated air out due to the vacuum which drives the
sy.stem.
h. Communitv Acceptance. The public was given a 30-
day period to comment on the proposal to amend the
Record of Decision. No comments from the community
were received during the comment period.
i. state Acceptance. The state of New Hampshire
concurs with EPA that vacuum extraction should be
implemented to treat soils at the site.
2.
Thermal Aeration
Low temperature thermal aeration is an on-site process
in which excavated soils are passed through a materials
dryer where volatile contaminants are transferred to
the gas phase. The process gases are then passed
through appropriate abatement equipment to capture the
volatile contaminants and particulates.
a. Compliance with ARARs.
attain all ARARs.
This technology will
b. Reduction of Toxicitv. Mobilitv or Volume.
Thermal aeration satisfies CERCLA's preference for
treatment as a principal element by stripping off
volatile organic compounds down to the treatment level
of 1 ppm or less. . Exhaust gases laden with VOCs and
particulates are passed through appropriate abatement
equipment to prevent the release of contaminants to the
atmosphere.
The mobility and toxicity of the volatile contaminants
captured by the activated carbon. abatement equipment
will be further reduced or eliminated after their
disposal or treatment. The captured particulates are
recycled through the aeration equipment until the
action level is attained.
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Tinkham's Garage Site - Amended ROD
page 14
Treated soils will be used as backfill on-site.
Residuals that are left in the soil at low
concentrations will continue to biodegrade and/or
volatilize over time.
c. Short-Term Effectiveness. Implementation of this
remedial technology will require excavation and .
transport of site soils. Although precautions will be
taken to minimize the disruption of the soil,
particularly in the garage area, volati1.es and
particulate will be released. The excavation of
wetlands soils may also have a short-term detrimental
effect on the wetlands. This effect will be minimized
by the wetlands' fairly rapid recovery following
backfilling with treated soils.
The excavated contaminated soils will be passed through
the aeration unit until the remediation goal of 1 ppm
is attained. Thus discrete volumes of soils will be
remediated in a relatively short period of time. The
risk posed by site soils will decrease in proportion to
the volume of soil left to be remediated.
Upon start-up and operation, the process will be
adequately monitored to prevent fugitive emissions or
ignition of the soils. As previously mentioned,
appropriate abatement equipment will be in place to
prevent the release of volatile organic contaminants or
particulates.
Treated soils will be sampled and screened to validate
the attainment ~fthe remedial goal. Soils will be
recycled as necessary, and operation parameters
adjusted accordingly to ensure the proper level of
treatment.
d. Lonq-Term Effectiveness and Permanence. The
remediation of the soils is expected to be achieved
within a two-year period. Because the volatile
constituents will actually be removed from the soils,
the remediation is permanent.
e. Im?lementability. Several aeration units have
been constructed and operated in recent years, both in
the pilot and full scale modes. The process has been
proven for the removal of volatile organic compounds
for soils, and can be expected to attain the treatment
level of 1 ppm or less total VOCs at this Site.
The major implementation concern with this alternative
is. tailoring the process operation to the Site.
Thermal aeration is the most complex technology
considered, as it involves multiple mechanical systems,
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Tinkham's Garage Site - Amended ROD
page 15
each of which will require precise control to ensure
proper operation. Feed requirements of the heating
unit, soil moisture content, and maximum particle size
must be taken into consideration.
Use of this technology requires specialized equipment
as well as skilled personn~l. The equipment and
. appurtenances are mobile in the sense that they are
truck-mounted and can be easily brought to the site.
While the number of contractors experienced in this
technology is limited, availability does not appear to
be a problem at this time.
f. Cost. Capital and 0 & M costs for this
alternative are summarized in Table 3-6 of the Pre-
Design Study Report. The unit cost for this technology
was reported to be between $248-$288 per cubic yard,
with a total cost for soil remediation at this Site of
$2,233,000-$2,593,000 for 9,000 cubic yards of soil,
exclusive of any permitting requirements and oversight
costs. More recent estimates suggest that low
temperature aeration of soils may be as low as $160 per
cubic yard of soil.
g.
Protection of Public Health and the Environment.
It has been' demonstrated at other Superfund sites that
thermal aeration is capable of attaining the soil
treatment level of 1 mgjkg or less. Some air releases
of volatile compounds may occur during excavation;
however, this occurrence can be minimized through
proper engineering controls.
h. Community Acceptance. The public was given an
opportunity to express its assessment of this
technology during the public comment period for the
proposal to amend the ROD. No comments were received
from the community during the comment period.
i. State Acceptance. The State of New Hampshire
recognizes thermal aeration as a proven technology for
the treatment of volatile contaminated soils.
3.
Bioloqical Treatment
Biological treatment is an in situ treatment process
that utilizes indigenous aerobic microorganisms to
degrade the organic contaminants of concern in the
soil. . By providing an optimal environment for
indigenous microorganisms, their growth and chemical
degrading activity can be enhanced. Volatilization of
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Tinkham's Garage Site - Amended ROD
page 16
the contaminants is another process that occurs
concurrently with the biological treatment and acts to
reduce contaminant levels in soils treated by this
process.
a. Compliance with ARARs.
attain all ARARs.
This technology will
b. . Reduction of Toxicity. Mobilitv or Volume.
Biological treatment satisfies CERCLA's preference for
treatment as a principal element. Use of this
technology will significantly and permanently reduce
the volume and toxicity of contaminated soil by
lowering the volatile contaminant concentration
throughout the Site to the treatment level of 1 ppm or
less. The contaminant removal mechanism for this
technology includes both a biodegradation and a
volatilization component. Although the more highly
chlorinated organics are the most resistant to
biodegradation, thus favoring persistence of compounds
such as PCE and TCE in the soil, these compounds will
be volatilized and removed through aeration. The
contaminants that are biologically degraded are
metabolized to carbon dioxide, water and cell biomass,
thus permanently reducing their mobility, toxicity and
volume. The portion of the contaminants that are
volatilized are released either to the ambient air or
captured and treated. Based on current information
there is no evidence that indicates that "hazardous"
end products will be formed as a result of
biodegradation. Residuals left in the soil, including
volatile compounds at low concentrations and cell
biomass, will continue to biodegrade and/or volatilize
over time.
c. Short-Term Effectiveness. The rate of contaminant
biological degradation from the soil is concentration
dependent. Therefore, the bulk of the contaminants
will be removed most quickly in the beginning when the
concentration is highest, and the concentration -
gradient is greatest. The effect of this is to greatly
reduce the risk associated with the soils in a very
short period of time.
The risk due to ;mplementation of this remedy is
'considered low. It will require controlled tilling,
followed by excavation of the remediated soils for
stockpiling and finally, replacement of the soils.
modeling indicates that volatile emissions will not
exceed applicable air quality standards.
Air
Each lift of tilled soil will be sampled in accordance
with an approved sampling plan to verify that the soils
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Tinkham's Garage Site - Amended ROD
page 17'
have been sufficiently treated. When the remedial 'goal
is attained, the treated lift of soil will be removed
and stockpiled and treatment of the underlying lift
will commence. It is anticipated that two lifts will
be required.
d. Lonq-Term Effectiveness and Permanence. The
remediation of the soils is expected to be achieved
within two years. Because the volatile constituents
will actually Qe removed from the soils, the
remediation is permanent.
e. Implementability. Both pilot and full-scale
biological treatment systems have been successfully
demonstrated in recent years for a variety of soil
types and chemical constituents. The laboratory scale
evaluation conducted during the Pre-Design study
demonstrated the ability of this technology to remove
significant quantities of volatile compounds from the
site soils. The equipment associated with this
technology, agricultura~ vehicles, temporary
structures, pumps, piping and vapor phase carbon are
readily available. Engineering and specialty
remediation contractor services are also readily
available.,
f. cost.' Capital and O&M costs for this alternative
are summarized in Table 3-6 of the Pre-Design study
Report. The unit cost for this technology is $133 per
cubic yard, with a total cost for soil remediation at
this site of $1,199,000 for 9,000 cubic yards of soil,
exclusive of any permitting requirements and oversight
costs.
g. Protection of Public Health and the Environment.
It was demonstrated in the laboratory scale
biotreatment evaluation, performed as part of the Pre-
Design study, that biological treatment is capable of
attaining the soil treatment level of 1 mg/kg or less.
Further, the removal mechanisms (biodegradation and
volatilization) will ensure that no reaction products
of concern remain in the soils. Some releases of
volatile compounds are expected to occur during
excavation of the soil lifts to address deeper soils;
however, these potential releases can be minimized
through appropriate engineering controls.
h. Community Acceptance. The public was given an
. opportunity to express its assessment of this
technology during the public comment period for the
Proposal to Amend the ROD. No comments were received
f~om the community during the comment period.
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Tinkham's' Garage Site -Amended ROD
,page 18
i. State Acceptance. The State of New Hampshire
recognizes biological treatment as an effective
technolqgy for the treatment of volatile organic
contaminated soils.
4.
Water Extraction
The water extraction process consists of contacting the
contaminated soils with water. Through mass transfer,
the contaminants are ,transferred to the water phase
where they are treat~d.
a. Compliance with ARARs. This technology will attain
all ARARs.
b. Reduction of Toxicitv. Mobilitv. or Volume. Soil
washing satisfies CERCLA's preference for treat~ent as
a principal element. Reduction of site contaminants in
soil to 1 mg/kg or less is theoretically achievable
although it has-not been demonstrated. The bench scale
study indicated that high water to soil ratios would be
required to achieve the soil treatment level of 1 mg/kg
or less, thereby significantly increasing volume. The
contaminants that are removed are transferred to the
water phas~ where they are removed, destructed, or
degraded w~th a subsequent technology.
Assuming the specified treatment level is met, treated
soils will be used as backfill on-site. Residuals that
are left in the soil at low concentrations will
continue to biodegrade and/or volatilize over time.
c. Short-Term Effectiveness. Implementation of this
remedial technology will require excavation and
transport of site soils. Although precautions will be
taken to minimize the disruption of the soil, volatiles
and particulate will be released.
d. Lona-Term Effectiveness and Permanence.
Theoretically the concentration of volatile
contaminants could be reduced to below 1 ppm total
volatile organics in the soil: however, this was not
demonstrated by the bench scale tests conducted as part
of the Pre-Design Study, which used water-to-soil
ratios as high as 20:1 and resulted in total VOC levels
in the soil greater than 1 ppm.
Treated soils will be sampled and screened to validate
the attainment of the target treatment level. Soils
above the target treatment level will require further
treatment. There is no experiential information on
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Tinkham's Garage Site - Amended ROD
page 19
which to base estimates of time to cleanup. However,
it is likely that the cleanup could occur within a two
year period. Remediation of the soils is expected to
be achieved within a time frame consistent with
implementation of the management of migration component
of the remedy. Soils will be permanently treated to
levels below the cleanup goal. Thus, the soil washing
approach is considered permanent.
e. Implementabilitv. Water extraction has only been
used as a remedial technology in a limited number of
cases. Its capability to-remove volatile organic
compounds from soils-down to a treatment level of 1 ppm
has not been demonstrated. The bench test conducted
during the Pre-Design Study indicated that a water-to-
soil ratio of 20:1 or greater would be required for the
site soils. This translates to greater than 7,000
gallons per cubic yard of contaminated soil. The
disposition or treatment of this volume of water is a
serious drawback of this technology. Equipment
associated with this technology, such as tanks, pumps,
and dewatering equipment are commonly used in industry,
and thus, should be available. .
f. Cost. The water extraction process developed in
the Feasibility study (FS) used water-to-soil mass
ratios ranging from 3:1 to 6:1, with the water phase
containing 20 percent methanol. A present worth unit
cost of $340 per cubic yard was reported. The FS
present worth estimate is low for this technology
because it was based on the assumption that methanol,
which increases the extraction efficiency of the wash,
would be used. However, because of methanol's toxic
properties,it is not likely that it will be used. In
addition, the FS estimate is low because the estimate
assumed lower water-to-soil mass ratios than indicated
by the bench scale study. . .
g. Protection of Public Health and the Environment.
It is theorized, but has not been demonstrated, that
water extraction is capable of attaining the soil
treatment level of 1 mg/kg or less total VOC. The soil
washing technology will be protective if it attains the
treatment goal. Some release of volatile organics is
likely during excavation of site soils. The release of
volatiles during excavation can be minimized through
. application of appropriate engineering controls.
h. Community Acceptance. The public has been given
an opportunity to express its assessment of this
technology during the public comment period for the
Proposal to Amend the ROD. No comments were received
from the community during the Public Comment period.
...
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Tinkham's Garage Site - Amended ROD
- page 20
i. State Acceptance. The State of New Hampshire
feels that this technology is less implementable than
the other technologies under consideration.
Rationale for Selection of Vacuum Extraction
D.
The vacuum extraction approach has been selected to
remediate site soils ~~ the Tinkham's Garage Site. Although
not one of the three technologies specified in the Record of
Decision for "the Site, the viability of " vacuum extraction
has been demonstrated through the work undertaken during the
Pre-Design Study. In particular, the pilot study conducted
on site soils and summarized in the Pre-Design Study Report
indicates that the vacuum extraction technology will achieve
the target treatment level specified for the Site.
Implementation of this technology will result in
environmental conditions which are protective of public
health and the environment.
Vacuum extraction will comply with applicable or relevant
and appropriate requirements identified for the remedial
action. Vacuum extraction is an in situ treatm~nt process
that will permanently reduce the toxicity, volume and
migration potential of source areas identified in the RI/FS
and refined in the Pre-Design Study. .
The processes associated with biological treatment, thermal
aeration, and soil washing are likely to be more complex to
implement than vacuum extraction, owing to the additional
operational parameters such as soil chemistry and
nutritional optimization (biological treatment), mechanical,
control and feed requirements (thermal aeration), and water
quantity and batch dewatering requirements (soil washing).
Because of the relative simplicity of the vacuum extraction
process it will be easier to implement than the other
technologies. The short-term effectiveness and
implementability of_vacuum extraction is also unique among
the technologies under consideration in that implementation
does not require excavation of contaminated soils behind the
-garage thus eliminating the potential for air releases of
contaminants during excavation. In addition, EPA believes
that vacuum extraction will provide increased dewatering of
site soils as compared to the other technologies under
consideration at the Site, thus increasing the quantity of
soil that can be remediated and causing the most.
contaminated groundwater to be extracted. EPA also believes
that treatment of contaminated soils in situ will minimize
cost.
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Tinkham's Garage site - Amended ROD
page 21
,", '
Although in situ processes, such as vacuum extraction~ may
be less likely than a process that employs excavation
followed by batch treatment, such as thermal aeration, to
uniformly treat all contaminated areas, appropriate sampling
and verification processes can minimize the potential for
unremediated hot spots left by the vacuum extraction
approach,. continued operation of the in situ process or
application of an alternative treatment technology will
ensure appropriate remediation of any hot spots to levels
identified in the ROD, ensuring the long-term effectiveness
and permanence of the remedy. .
VI.
STATUTORY DETERMINATIONS
The remedial action selected for implementation at the
Tinkham's Garage site is consistent with CERCLA and, to the
extent practicable, the NCP. The selected remedy is
protective'of public health and the environment, attains
ARARs and is cost-effective. Further, the selected remedy
satisfies the statutory preference for a permanent solution
and for treatment which reduces the mobility, toxicity or
volume of hazardous substances as a principal element.
Finally, the se~ected remedy utilizes treatment technologies
to the maximum extent practicable. '
. A.
The Selected Remedv is Protective of Human Health and
the Environment
The selected remedy will achieve the treatment level of 1
mg/kg or less total mass volatiles concentration in site
soils. Residuals that are left in the soil at this low
concentration will continue to biodegrade and or volatilize
over time. In the event that the vacuum extraction process
is not able to reduce total mass volatiles to less than 1
ppm total VOCs, the selected remedy requires the
implementation of contingency measures such as the
implementation of a thermal aeration finishing process.
Because groundwater under the garage area soils will be
remediated during the vacuum extraction process, groundwater
remediation at the site will be expedited. The vacuum
extraction process is expected to preferentially strip PCE,
thus accelerating groundwater remediation at the site.
Finally, the vacuum extraction process has inherent design
characteristics that will minimize the potential for
inadvertent release of hazardous substances to the
environment during its operation, thus providing an
effective and protective remedy in the short term. In sum,
EPA has determined that the selected remedy at this site is
protective of human health and the environment.
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Tinkham's G~rage Site - Amended ROD
page 22
B.
The Selected Remedy Attains ARARs
The selected remedy will attain all applicable or relevant
and appropriate federal and state environmental requirements
at the Site. Federal and State of New Hampshire
environmental laws which are applicable or relevant and ap-
'propriate to the selected source control action at the Site
are presented in Appendix c.
c.
The Selected Remedial Action is Cost Effective
Once EPA identifies alternatives that are protective of
public health and the environment and attain ARARs (unless a
waiver is invoked), EPA evaluates each of those alternatives
to determine their cost-effectiveness. Capital and
Operation and Maintenance costs were estimated for each
alternative~ On the basis of the cost information compiled
by EPA and the potentially responsible parties, and EPA's
evaluation of the alternatives as described above, EPA has
determined that the selected remedy is cost-effective. The
unit treatment cost for Vacuum Extraction is as low or lower
than other technologies evaluated, and the process has
inherent efficiencies relative to groundwater remediation
due to the dual extraction process which also pumps shallow
contaminated groundwater. .
D.
The Selected Remedy utilizes Permanent Solutions and
Alternative Treatment Technoloqies or Resource Recovery
Technoloqies to the Maximum Extent Practicable
Vacuum extraction is an. in situ treatment process that uses.
enhanced vacuum driven volatilization to remove volatile
organic compounds from unsaturated soils. Remediation of
site soils is expected to be achieved in two years. Because
the vacuum extraction process will remove volatile
constituents from site soils the remedy will be permanent.
In light of these considerations, EPA has determined that
the selected remedy utilizes permanent solutions and
alternative treatment technologies or resource recovery
technologies to the maximum extent practicable.
E.
The Selected Remedy Satisfies the Preference for
Treatment as a Principal Element
The selected remedy satisfies the statutory preference for
treatment as a principal element. Use of vacuum extraction
at the site will significantly and permanently reduce the
volume and toxicity of contaminated soil by lowering the
total mass volatile level throughout the Site to 1 mg/kg or
less.
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Tinkham's Garage Site - Amended-ROD
. page 23
VII.
community Relations
Prior to commencement of the Pre-Design. Study, 'a fact sheet
describing the study activities was sent to area residents
in September 1987. Upon release of the Pre-Design Study
Report, an informational meeting was held August 4, 1988, to
describe the results and findings of the study.
The proposal to amend the Record of Decision was issued for
public comment from August 5, 1988, to September 9, 1988, .
during which the public was asked to comment on the
proposal. A public hearing was held on September 8, 1988,
in Londonderry, New Hampshire to formally accept oral
comment from the public on the proposal. A summary of
comments on the proposal and EPA responses to the comments
are provided in the Responsiveness Summary (Appendix B).
VIII.
STATE ROLE
The State of New Hampshire has reviewed the various
alternatives and has indicated its support for the selected
remedy. The State of ~ew Hampshire has also reviewed the
Pre-Design 'Study Report to determine if the selected remedy
is in complianc~ with applicable or relevant and appropriate
state environmental laws and regulations. On the basis of
these analyses, the State of New Hampshire concurs with the
selected remedy for the Tinkham's Garage Site. A copy of
the declaration of concurrence is attached as Appendix D.
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APPPENDIX A
Administrative Record Index
-------
ADMINISTRATIVE RECORD INDEX
for the
CANNONS LONDONDERRY (TINKHAM'S) site
, -
This Administrative Record supports the remedial actions determined'by
the Record of Decision (ROD) dated September 30, 1986, and the Amended
Record of Decision, dated March 10, 1989. '
1.0
PRE-REMEDIAL
1.2
Preliminary Assessment
1. Potential Hazardous Waste site Identification and
Preliminary Assessment Form, EPA Region I (May 12,
1982).
1.7
Correspondence Related to Proposal of a site to the NPL
1. Letter from Donald W. Stever, Jr., Day, Berry &
Howard (Attorney for Fred Tinkham and Tinkham
Investments) to Russel H. Wyer, EPA Region I
(February 25, 1983). CLD-001-1457-1461
1.18
FIT Technical Direction Documents (TDDs) and Associated
Records
1. Field Investigation Report, Rebecca Cleaver, NUS
Corporation to EPA Region I '(January 13, 1984).
CLD-001-2160-2404
2. Field Investigation Report Volume I: Report, Rebecca
Cleaver, NUS Corporation to EPA Region I (March 7,
1984). CLD-001-1940-2028 .
3. Field Investigation Report Volume II: Appendices,
Rebecca Cleaver, NUS Corporation to EPA Region I
'(March 7, 1984). CLD-001-2029-2159
REMEDIAL INVESTIGATION CRI)
3.0
3.1
Correspondence
1. Memo regarding March 21, 1980 inspection of the site
stating oil ,contaminated debris and soil is still
present, William E. Evans, New Hampshire Water Supply
and Pollution Control Commission, to Lynn A. Woodard,
State of New Hampshire (March 27, 1980). CLD-OOl-l323
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4.0
3.2
3.4
3.6
3.9
3.10
P~ge 2
2. Memo stating results of surface and groundwater
samples in the vicinity of the Tinkham's Garage Site
in Londonderry, Dave Cook, Ecology & Environment to
John F. Zipeto, EPA Region I (October 11, 1982).
CLD-001-0588
3. Memo providing comment on soil and groundwater
contamination, Georgi A. Jones, U.S. Department of
Health & Human Services to John E. Figler,' EPA Region
I (August 23, 1985). CLD-001-0233
Sampling and Analysis Data
The Sampling and Analysis Data for the Remedial
Investigation (RI) may be reviewed, by appointment only,
at EPA Region I, Boston, Massachusetts.
Interim Deliverables
1. Alternate Water Supply Evaluation for the Tinkham
Site Vicinity, Patrick C. Falvey, NUS Corporation
(March 1, 1983). CLD-001-0188-0213
2. Remedial Action Master Plan, John A. George, NUS
Corporation (September 1983). CLD-001-0001-0112
Remedial Investigation (RI) Reports
1. Remedial Investigation Report Volume I: Report,
Barbara Buckley, NUS Corporation (January 15, 1986).
CLD-001-1468-1601
2. Remedial Investigation Report Volume II: Appendices,
Barbara Buckley, NUS Corporation (January 15, 1986).
CLD-001-1602-1939
Health Assessments
1. Health Assessment for the Tinkham's Garage Site,
Londonderry, New Hampshire, SI-86-164 (September 8,
1986). .
Endangerment Assessments
1. Tinkham's Garage Site Endangerment Assessment Report,
Kathryn A. Rosica, NUS Corporation (May 7, 1986).
CLD-001-0250-0413
FEASIBILITY STUDY (FS)
4.6
Feasibility Study (FS) Reports -- 1986 Record of. Decision
1. Tinkham's Garage Site Draft Feasibility Study, Camp
Dresser & McKee (June 16, 1986). CLD-OOI-0663-0934
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5.0
4.6
4.9
Page J
2. Tinkham's Garage site Draft Feasibility study
Appendix, Camp Dresser & McKee (June 16,1986).
CLD-001-0935-1322
Feasibility study (FS) Reports -- 1989 Amended Record of
Decision .
3. Tinkham's Garage site pre-Design study, Cannons
Steering Committee, Malcolm Pirnie, Inc. (July 1,
1988). CLD-002-0075-0193 .
4. Tinkham's Garage site Pre-Design Study, Appendices:
Volume I (April 1988) and Volume II (July 1988),
Malcolm Pirnie, Inc. (July 1, 1988). CLD-002-0194
Proposed Plans for Amended Remedial Action
1. Londonderry Site Proposal to Amend the Record of
Decision, EPA Region I (July 1, 1988).
CLD-002-0001-0035
RECORD OF DECISION (ROD) -- 1986
5.3
5.4
Responsiveness Summary for the 1986 ROD
1. Cross Reference: Responsiveness Summary is found in
the Record of Decision [Filed and cited as entry
number 1 in 5.4 Record of Decision (ROD)].
Comments
2. Draft Feasibility study Review and Comment, Malcolm
Pirnie, Inc. to Four Sites Steering Committee
(September 1986). CLD-001-0415-0471
3. Letter forwarding report concerning the Draft
. Feasibility Study for Tinkham's Garage site and
requesting copies of test results of current
sampling, Margaret R. Tribble, Four Sites Steering
Committee to David P. Frasca, EPA Region I (September
26, 1986). CLD-001-0414
Record of Decision (ROD)
1. Record of Decision, Michael R. Deland, EPA Region I
(September 30, 1986). CLD-001-0472-0587
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5.0
Page 4
AMENDED RECORD OF DECISION (ROD) -- 1989
5.1
5.2
5.3
5.4
Correspondence
1. Letter providing update of remediation costs
contained in the Pre-Design study Report, Diane M.
Leber, Ciba-Geigy Corporation to Gregory A. Roscoe,
EPA Region I (October 24, 1988). CLD-002-0205
2. Cross Reference: Letter from John A.
Minichiello, New Hampshire Department of
Environmental Se.rvices expressing agreement with
the Amended Record of Decision is Appendix D of the"
Amended Record of Decision [Filed and cited as entry
number 1 in 5.4 Amended Record of Decision (ROD)].
Applicable or Relevant and Appropriate Requirements
(ARARs) ".
1. Cross Reference: Applicable or Relevant and
Appropriate State Requirements is Appendix C of the
Amended Record of Decision [Filed and cited as entry
number 1 in 5.4 Ame~ded Record of Decision (ROD)].
2. Cross Reference: Applicable or Relevant and
Appropriate Federal Requirements is Appendix C of the
Amended Record of Decision [Filed and cited as entry
number 1 in 5.4 Amended Record of Decision (ROD)].
Responsiveness Summary for the Amended ROD
1. Cross Reference: Tinkham's Garage
Responsiveness Summary is Appendix
Decision [Filed and cited as entry
Amended Record of Decision (ROD)].
site Amended ROD
B of the Record of
number 1 in 5.4
Comments
2. Letter on behalf of the Cannons Sites Group
forwarding attached comments regarding the proposed
Amendment to the Record of Decision, Laurie Burt,
FOley, Hoag & Eliot to Gregory A. Roscoe, EPA Region
I (September 9, 1988). CLD-002-019~-0203
3. Letter on behalf of the Cannons Sites Group amending
opinion expressed in September 9, 1988 comments
regarding Proposed ROD Amendment, Laurie Burt, Foley,
Hoag & Eliot to Gregory A. Roscoe, EPA Region I
(September 29, 1988). CLD-002-0204
Amended Record of Decision (ROD)
1. Amended Record of Decision for the Tinkham's Garage
Site, March 10, 1989.
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9.0
10.0
11.,0
13.0
Page 5
STATE COORDINATION
9.1
Correspondence
1. Letter stating position of the NHWSPCC and the Town
of Derry,with respect to the water mains to be
constructed in connection with the Londonderry waste
problem, William A. Healy, New Hampshire Water Supply
and Pollution Control Commission to Merrill s.
Hohman, EPA Region I (June 20, 1983). CLD-06'1-0611
ENFORCEMENT
10.7
EPA Administrative Orders
1. Order #2303 ordering action to prevent further
pollution of public surface and groundwaters from
site, William A. Healy, State of New Hampshire to
John Tinkham, Tinkham Enterprises (May 31, 1978).
CLD-001-0215
2. Administrative Order by Consent, Michael R. Deland,
EPA Region I to Potentially Responsible Party (PRP)
(September 11, 1987). CLD-002-0036-0074
10.8
EPA Consent Decrees
1. Consent Decree, Uni~ad States v. Cannons Engineerinq
corporation, Docket Number 88-1786-WF; Massachusetts
v. Cannons Engineerinq Corporation, Docket Number
88-1787-WF; New Hampshire v. Cannons Enqineerinq
corporation, Docket Number 88-1788-WF (D. Mass)
(August 3, 1988) (Partial Consent Decree).
POTENTIALLY RESPONSIBLE PARTY CPRP)
11.7
PRP steering Committee Documents
1. Letter and attached PRP proposal for source
remediation by in situ vacuum extraction at the site,
Laurie Burt, Foley, Hoag & Eliot to Jeremy Firestone,
EPA Region I (May 27, 1988). CLD-001-0642-0662
COMMUNITY RELATIONS
13.1
Correspondence
1. Letter responding to August 1, 1986 letter confirmi-,g
Town of Derry's support for use of the publicly owned
treatment works in the cleanup effort, Rodney A.
. Bartlett, Town of Derry, New Hampshire to David P.
Frasca, EPA Region I (September 8, 1986).
CLD-001-1466-1467 '
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13.3
Page 6
2. Memo regarding July 12, 1988 meeting with Derry Towr
Council concerning the intended use , of the publicly
owned treatment works to treat groundwater at the
site, Gregory A. Roscoe, EPA Region I to file, EPA
Region I (July 15, 1988). CLD-001-1465
News Clippings/Press Releases
1. Press Release regarding investigation of possible
groundwater contamination from site a~d precautions
being taken to ,insure protection of public health,
Michael P. D~nahue, New Hampshire Water Supply and
Pollution Control Commission (October 29, 1982).
CLD-001-0589
2. Newspaper article titled "EPA Hosts Session at
Londonderry on Contamination," Manchester Union,
Leader, Manchester, New Hampshire (March 29, 1983).
CLD-001-0228-0229
3. Newspaper article titled "Water for Londonderry
Subject of PUC Hearing," David Raposa, Derry News,
Derry, New Hampshire (July 28, 1983).
CLD-001-0226-0227 '
4. Newspaper article titled "PUC Sets Second Public
Hearing on Water Franchise," Derry News, Derry, New
Hampshire (August 18, 1983). CLD-001-0232
5. EPA Environmental News Release announcing November
16, 1983 public meeting involving presentation of
plans for cleanup study at site, Debra Prybyla, EPA
Region I (October 20, 1983). CLD-001-0222
6. Newspaper article titled "EPA Hearing on Waste Site
Open to Public," John M. Peter, Derry News, Derry,
New Hampshire (November 10, 1983). CLD-001-0225
7. Newspaper article titled "contamination site on
R102 to be Discussed at Hearing," Derry News, Derry,
New Hampshire (April 19, 1984). CLD-001-0230
8. EPA Environmental News Release announcing
meeting to be held May 14, 1984 regarding
of the Superfund study of the site, Peter
Region I (April 24, 1984). CLD-001-0214
public
the results
Mc;:Glew, EPA
. .,
9. Notice of a public meeting to be held May 14, 1984
regarding results of a Superfund study at the site,
EPA Region I (April 30, 1984). CLD-001-0607
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13.4
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13.5
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Page 7
10. Newspaper article titled "Meeting to Air Results of
Garage Site Testing," Derry News, Derry, New
Hampshire (May 3, 1984). CLD-001-0231
11. Newspaper article titled "EPA.Holds Hearing on Auburn
Road," David Raposa, Derry News, Derry, New Hampshire'
(July 5, 1984). CLD-001-1462-1464
12. EPA Environmental News Release announcing public
'meeting to be held on February 5, 1986 to explain
results of a Remedial Investigation of groundwater,
soil, surface water, and surface water sediments,
Patty D'Andrea,' EPA Region I (January 22, 1986).
CLD-001-0613
13. EPA Environmental News Release announcing public
meeting to be held August 4, 1988 to discuss the
results of a Pre-Design study and to propose amending
the site cleanup plan, Paul Knittel, EPA Region I
(July 29, 1988). CLD-002-0195-0196
Public Meetings
1. 'List of Attendees at Tinkham/Londonderry Green Public
, Meeting (April 13., 1983). CLD-001-0175-0176
2. Public Meeting Agenda (April 13, 1983). CLD-001-0187
3. EPAAgenda of Public Meeting held on November 16,
1983 to discuss Remedial Action Master Plan, EPA
Region I (November 16, 1983). CLD-001-0220
4~ Agenda for the Tinkham's Garage Superfund site Public
Meeting held on February 5, 1985, EPA Region I
(February 5, 1985). CLD-001-0612
5. Summary of Public Meeting, EPA Region I (February 5,
1986). CLD-001-0246-0249
6. Cross Reference: Final Community Relations Summary
for the public hearing held on September 8, 1988
(includes hearing transcript) is Appendix B of the
Amended Record of Decision [Filed and cited as
entry number 1 in 5.4 Amended Record of Decision
(ROD)].
Fact Sheets
1. Superfund Program: EPA Progress and Plans, EPA
Region I (December 1985). CLD-00I-0241-0243
2.
Superfund Program Feasibility Study Fact Sheet, EPA
Region I (August 1986).
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17. O'
--..--- - ------
Page 8
3.
"Superfund Program Information Update;" Tinkham's
Garage Site, Londonderry, New Hampshire, EPA Regio
I (September 1987). .
4.
Fact Sheet - EPA Proposal to Amend site ROD, EPA
Region I (July 1988). CLD-002-0197
5.
Tinkham's Garage site Public Health and
Environmental Concerns Fact Sheet.
17.8
SITE MANAGEMENT RECORDS
State and Local Technical Records
1. Memo regarding site visit and discussing waste water
dumping (April 17, 1975j. CLD-OOl-1454
. 2. Memo regarding complaint from resident Ann Miller
about contamination of brook and drinking water near
site, Stewart Parker, NUS Corporation to Russell A.
Nylander, NUS Corporation (April 27, 1978).
CLD-001-0217
3. Memo regarding May 1~ 1978 site visit and discussion
with John Tinkham concerning oil residue at the site
(May 1, 1978). CLD-OOl-1455 .
4. Memo regarding site visits of June 5, 1978 and June.
28, 1978 and discussions concerning oil dumped at the
site (June 28, 1978). CLD-OOl-1456.
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APPENDIX B
...
Responsiveness summary
-------
Tinkham's Garage Site- Amended ROD
. Appendix B- Responsiveness Summary
page 1
RESPONSIVENESS 'SUKMARY
A summary of the public hearing held September 8, 1988 for the EPA
Proposal to.Amend the Tinkham's Garage Site Record of Decision is
presented in the "Responsiveness Summary for the Public Hearing
Held September 8, 1988 for the Tinkham's Garage Site, Londonderry,
New Hampshire" prepared by Booz, Allen & Hamil ton (Appendix E).
No oral. comments were presented for the record at the Public
Hearing.
One written comment was submitted during the c~!!'.!!!~!!t period by
counsel to the Settling Parties which recommended that EPA amend
the Record of Decision to allow either vacuum extraction or low
temperature thermal aeration. The Settling Parties had received
additional cost information in the course of their inquiries with
potential remedial contractors which indicated that thermal
aeration was more cost competitive with vacuum extraction than what
was previously believed. Based on this new information, the
Settling Parties recommended selection of both soil treatment
technologies in the amendment to the. ROD. This comment is
attached.
Subsequent to the comment period, the settling Parties reached
closure on their evaluation of vendor bids for soil remediation
and concluded that based on all factors vacuum extraction was the
most appropriate technology. This conclusion was conveyed to EPA
in a letter to Gregory A. Roscoe dated September 29, 1988
(attached).
Refinements to the technology cost assessment were conveyed to EPA
from the Settling Parties technical contact, in a letter to Gregory
A. Roscoe dated October 24, 1988 (attached). The letter indicated
that there were factors associated with each techn'ology that
affected total cost of site remediation which made a direct cost
comparison difficult.
EPA RESPONSE
EPA reviewed cost information presented in the Pre-Design Report
and concluded that although there may be some inherent cost savings
associated with vacuum extraction, there were not dramatic
differences in cost between it and thermal aeration.
Vacuum Extraction was selected as the soil treatment technology
because it was shown to be able to remediate site soils in a timely
fashion to the target treatment levels. In addition, two positive
attributes are unique to this technology:
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Tinkham's Garage site- Amended ROD
Appendix B- Responsiveness Summary
page 2
1.
The technology is capable of being implemented in the garage
. area without the need for excavation of contaminated soils.
The Vacuum Extraction technology can be implemented with the
soils in place, minimizing environmental disturbance and the
potential. for volatilization of soil contaminants to the
ambient air.
2.
utilization of a dual extraction system will simultaneously
extract contaminated shallow groundwater from underneath the
soil source area. This "approach will aggressively address
contaminated groundwater in the garage area which should
result in a reduction in time required to treat the bedrock
aquifer.
Based on an overall analysis of performance, vacuum extraction was
determined to possess several desirable and unique features, and
found to be cost-effective. Therefore, it did not seem appropriate
to leave any further ambiguity in the amended ROD by selecting two
technologies. . Thus, for the Tinkham's Garage site, Vacuum
Extraction was selected as the soil treatment technology.
..
.
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FINAL COMMUNITY RELATIONS SUMMARY
FOR THE PUBLIC HEARING HELD
SEPTEMBER 8, 1988
TINKHAM'S GARAGE SITE
Londonderry,.New Hampshire
January 20, 1989
Prepared for:
Region I
United States Environmental Protection Agency
Prepared by:
Booz, Allen & Hamilton Inc.
Under Subcontract No. TESK-TEAM-013, Work Assignment 541
EPA Contract No. 88-01-7331
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FINAL COMMUNITY RELATIONS SUMMARY
TINKHAM'S GARAGE SITE
LONDONDERRY, NEW HAMPSHIRE
SEPTEMBER 8, 1988
INTRODUCTION
In accordance with the U.S. Environmental Protection
Agertcy's (EPA) Community Relations pOlicy and guidance, the EPA
Region I Office held a public' hearing on September 8, 1988, to
record oral comments on the proposed amendment to the Record of
Decision (ROD) on the Tinkham Garage Superfund site. The
public hearing took place from 7:30 p.m. to 8:45 p.m. at the
Londonderry Public High School Cafeteria in Londonderry,
New Hampshire. Approximately 15 people attended and Mr. Greg
Roscoe, EPA's site Project Manager, served as the hearing
chairman. Two public notices were placed in area newspapers:
one published in The Derrv News, Wednesday, September 7, 1988,
a second published in The Nashua Telegraph, Sunday,
September 4, 1988. A fact sheet describing the vacuum
extraction technology proposed in the amendment to the ROD was
distributed in July 1988 and a public information meeting
explaining the technology was held on August 4, 1988'. The
30-day pUblic comment period on the ROD amendment ran from
August 5, 1988, through September 9, 1988.
This responsiveness summary was ,prepared by Booz, Allen &
Hamilton Inc., a subcontractor to CDM Federal Programs
Corporation, under a technical enforcement support (TES)
contract to provide community relations support to EPA
Region I. The summary is divided into three major sections.
Section 1 provides a brief background on the site and the
community relations activities carried out by EPA. Section 2
identifies public comments that EPA received on the ROD
amendment. Section 3 provides a summary of questions asked and
answers provided at the conclusion of the hearing. An official
verbatim transcript of the hearing, prepared by a court
reporter, is included in this document as Appendix A.
1.0
BACKGROUND
This section presents a-summary of the site status and
provides details on recent community relations activities
conducted for the Tinkham Garage site.
A.
Site Status
The Tinkham Garage site in Londonderry, New Hampshire,
was added in September 1983 to the National Priorities List
(NPL), EPA's list of most serious hazardous waste sites
;
-1- .
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that are eligible to receive cleanup funds under the
Superfund Program. The site was listed after inspection by
EPA and the New Hampshire Water Supply and Pollution
Control Commission revealed that the site posed a threat of
contamination to the primary drinking water supply of over
400 residents in the site vicinity. The compounds
considered to be posing a potential threat to ground and
surface water, soils and sediment, and wetland areas were
primarily volatile organic compounds (VOCs --
carbon-containing compounds that vaporize or evaporate
readily).
A remedial investigation and feasibility study (RIfFS)
was undertaken by an EPA contractor between 1984 and 1986
to determine the nature and extent of contamination, and to
identify and assess the alternatives for remedying problems
due to contamination. An endangerment assessment for the
site was also conducted in 1986. Based on information in
the endangerment assessment and data reported by the RI and
the FS reports, the ROD selected three remedial
technologies as possible cleanup alternatives for the
site. These included: thermal aeration, biological
treatment, and soil washing. The ROD selecting these
alternatives was signed in September 1986. Since the ROD
was signed, the potentially responsible parties (PRPs) have
conducted studies which have indicated the efficacy of the
vacuum extraction process to source control remediation at
the site. EPA agreed to propose an amendment to the 1986
ROD to implement vacuum extraction and presented this
proposal to the public in August 1988. EPA's public
meeting on August 4, 1988, took place to provide the
community with information on the various source control
alternatives, including the vacuum extraction technology.
B.
Community Relations
As ,part of its responsibility to include citizens in
the Superfund decision-making process for the Tinkham
Garage site, EPA held a public comment period in 1986 when
the initial ROD for the site was p~oposed. A second 30-day-
public comment period on the 1988 proposal to amend the ROD
was held from August 5, 1988, through September 9, 1988.
The 1988 public comment period opened with the public
information meeting held in Londonderry on August 4, 1988,
and closed on ~aptember 9, 1988, the day following EPA's
public hearing on the proposed amendment. EPA arranged the
public hearing to receive oral comments on the proposal.
In addition, a fact sheet on EPA's proposal to amend the
ROD was distributed to the site community in July 1988
(See Appendix C for site fact sheet.) The Site Information
Repositories also house documents associated with the site
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and are located at the the Londonderry Public Library and
Londonderry Town Hall. Interested persons can review
reports, fact sheets, and other site information sent by
EPA to these repositories.
2.0
SUMMARY OF COMMENTS FROM THE PUBLIC AND AGENCY RESPONSES
. EPA receiv~d one written c~mment during the 30-day public
comment period. The Cannons Site Group submitted a letter
recommending that the ROD be amended to permit the selection of
either thermal aeration or vacuum extraction for source
remediation of contaminated soils at the Tinkham Garage site.
The group cased their recommendation upon the fact that both
thermal aeration and vacuum extraction are superior
technologies when compared on the basis of compliance with
environnlental requirements and standards; reduction of
toxicity, mobility, or volume; cost; and protection of human
health and the environment. They also stated that both
technologies are capable of remediating the soils to a level of
1 part per million total VOCs, are roughly equivalent
. technically, and are equally applicable to the site, although
each has its advantages and disadvantages. Additionally,
recent information based on technological refinements indicates
that thermal aeration is more cost-competitive with vacuum
extraction than indicated in the Pre-Design Study.
3.0
SUMMARY OF OUEST IONS FROM THE PUBLIC AND AGENCY RESPONSES
. At the close of the official pUblic hearing, during which
no oral comments regarding the proposal to amend the ROD were
registered, the site Project Manager responded to oral .
questions about the site. The following section summarizes the
qu~stions asked and responses provided. Questions and
responses have been paraphrased and grouped by subject into the
following three categories:
Preferred Remedial Alternatives
Cleanup Objectives
Logistical and Scheduling Issues.
A.
Preferred Remedial Alternatives
Several questions were raised pertaining to the
remedial alternative technologies. One attendee asked how
effective the previous three technologies are and whether
they are more or less effective than the fourth proposed
alternative, vacuum extraction. Greg Roscoe, the site
Project Manager, explained that the vacuum extraction
technology has been proven effective and provided
information on how the technology works. He explained that
mechanically~ vacuum extractipn is a simpler process than
-3-
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the others, primarily because it does not require soil
excavation and that the treatment will use the Derry
wastewater treatment plant to decontaminate ground water.
Mr. Roscoe also identified reasons why the other three
alternatives are less desirable than vacuum extraction.
Soil washing is a more complicated physical system and
zequires large amounts of water. Biological treatment.
shows promise, but requires s~il excavation and involves a
more complicated decontamination process converting organic
contamination metabolically into carbon dioxide, water, and
- biomass. Thermal aeration, although mechanically a
relatively simple proces~, requires soil excavation, like
biological treatment.
A few questions were asked about the mechanics of
vacuum extraction technology, including what kind of pumps
will be used to extract contaminated ground water from the
aquifer, how the system will be powered, and how noisy it
will be. Mr. Roscoe explained that a series of submersed
pumps will draw contaminated ground ~ater from the aquifer
and one large vacuum extraction pump will draw contaminated
air through the treatment process and release treated air
into the atmosphere. Mr. Roscoe said that the contractor
will probably run electric power lines into the area to run
the pumps, and stated that he is confident that the pumps
are not loud and that precautionary measures will be taken
to minimize the public's inconvenience. . .
B.
Cleanup Obiectives
Another attendee asked about the cleanup goals,
specifically, whether all four technologies are capable of
meeting the cleanup goals; and how EPA will ensure that
cleanup goals are achieved. Mr. Roscoe explained that a
prerequisite in proposing remedial alternatives is that the
technology must achieve the established cleanup objectives,
and stated that the objective is one part per million (ppm)
total VOCs in soil. He explained that EPA will conduct a
comprehensive sampling program to evaluate soil
contamination throughout the implementation phase and
during ope~ation and maintenance of the technology.
One attendee asked whether area residents will be ab:e
to use their residential wells again. Mr. Roscoe explained
that EPA's 90al is to make the aquifer usable. The Agency
will continually monitor the aquifer; he explained,
however, that because this site presents a unique problem
-- the contamination is in a bedrock aquifer -- EPA is not
sure whether contamination can be eliminated completely.
-4-
;
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One attendee asked about the concentration of
contamination in the soil at and around the site,
specifically in the leach fields for the condominium
complex that is located on-site, south of Tinkham's
garage. Mr. Roscoe quoted VOC results from the latest
sampling, stating that the contaminant levels in leach
fields in the vicinity of Monitoring Wells I, J, and K are
in the range of 50 to 70 part per million (ppm); the leach
field in the vicinity of Monitoring Well L is lower, in the
range of 3 to 6 ppm. (See Map in Appendix C.)
C.
Logistical and SchedulinQ Issues
One attendee raised questions pertaining to
contractual arrangements, specifically who bids for the
work and how. Mr. Roscoe indicated that, in the case of
this site, EPA has reached a settlement with the
responsible parties (RPs), who agreed to finance the site
cleanup. This means the RPs are responsible for obtaining
a contractor and establishing the contract terms.
One attendee asked about the cleanup schedule.
Mr. Roscoe stated that work at the site- may start as early
as the Spring of 1989. He said that soil treatment will be
complete in the first two years, while ground-water
treatment and monitoring will continue for at least two
years and perhaps longer, depending on water quality. He
indicated that, as the contractor achieves cleanup
milestones, EPA will provide the community with updated
information.
One attendee asked whether at any time during the
cleanup residents will be asked to leave their homes,- and
if so, who will subsidize the accommodations. Mr. Roscoe
stated that it is unlikely that residents will have to
leave their homes, but if this situation arises, EPA has
procedures for reimbursing affected families for costs.
~
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At't'~NI.J J. A ~- .
.1 - 7 (.
UNITED STATES
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ENVIRON~UL~TAL PROTECTION AGENCY
3
REGION ONE
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5 I In the Matter of:
6 I ~~END~ENT TO THE RECORD
7 ! RE:
8 Ii TINKHAW S G!'.R~GE SUPERFUND SITE
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Thursday
September 8, 1988
. Cafet.eria
Londonderry High
295 Mammoth Road
Londonderry, NH
School
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Whereupon-the above. enti tlt~(l matter came on for
pursuant to Notice at 7:42 P.~.
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20 ;: GREGORY ROSCOE.
. Ii Environrnantal Protection
21 'I Region One
. J.F.K. Federal Building
22 I Boston, ~~ 02203
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23 ,
Agency
24
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APEX Reporting
Rtgisttrtd ProftSsional Reportt'Ts
(617) 426-3077
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PRO C E E DIN G S
- --
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- --
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(7:42 A.M.)
3
REMEDIAL PROJECT MANAGER:
Okay, I gues:
we'll start the Public Hearing for the Tinkham's Garc:ge
. . ..
Superfund Site now.
I'd like to begin the hearing and
welcome everybody.
My name is Gregory P~scoe and I'm an
environmental scientist with the Environmental Protection
Agency here, Region No.1, in Boston, and my pOEition is
environmental scientist in the New Hampshire Superfund
Section of the Waste Management Branch and my duties and
-- responsibilities include implementation of the Superfund
Program here in the State of New Hampshire.
-I
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I will serve as Chairman of this hearing
and I want to welcome you all here this evening.
The purpos~
I
I
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I
of the hearing is to forrnall~.accept. your comments on the
proposal to amend the Record of Decision for the Tinkham's
Garage Site located in Londonderry, New Hampshire.
Also present here today is Charlie Berube!
I
from the New Hampshire Department of Environmental Services, i
,
I
i
I
As many of you know, I I
and Charlie, you can raise your hand.
B~fore beginning I I'd like to briefly
describe the format of the hearing.
was here
last month and described a proposal to amend the
"ROD" at an informational meeting we held at the high schoo' I
-'
APEX Reporting
Rtgisttrtd Proftssional RtparttTs
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1 -
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August 4th.
Those of you wishing to make comments on the
record concerning the proposal to amend the "ROD" should
have already indicated y6ur desire to do so by filling out
-the index cards available from the EPA representative
located at the entrance to the doorway.
If you have not
completed a card and wish-to co~ment, please do so now or
at anytime during the course of the hearing. I will callout
the names of those of you wishin~ to make a statement from
the list of those who have signed in this .evening.
~\~.en
called on, I ask that you come to the front of the roo~ and
comment using the microphones provided.
50 that everyone
will have a chance tospeak~ we'd lik~ to'liI!'.it the comments I
to a reasonable amount of t~me. I th~nk that we'll have' I
- I
plenty of ti~e to accomodate everybody's comments so we i
I
,
I
won't put a time limit on that.
FOllowing your comment, I or another mernben
i
of this panel will have the opportu~ity to ask you clarifyir.g
questions regarding your comment that may assist us in
\
considering your statement. After all comments have beer.
heard, I will close the formal hearing.
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quest~oI1s
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,
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EPA a:1d 5ta~e
representatives will then be available to answer any
you may have on issues raised this evening.
As you know, the public comment period
for the proposed plan opened on August 5th and runs through
September 9th.
If you wish to submit written comments, and
~
APEX Reporting
Rtgis/trtd PraftSs'-onal Rtp'lr/rrs
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I encourage you to do so, they must be postmarked no later
2
than September 9th and mailed to Our office .in Boston.
The
3
appropriate address can be found on the proposal to amen~
4
the" ROD" and the fact sheet which are both located in the
5
information repositories here in Londonderry.
6
At the conclusion of the meeting, please
see myself or Charlie if you have any question~ on the
process for making written comments. Actually, I'd probably
be the most appropriate person to see concerning s~ffiitti~g I
written comments. All oral comments that we receive tonight
and those we receive in writing during the comment period
will be responded to in a Responsiveness Summary and this
summary will be included with a Decision Document, which
would be the amended Record of Decision if the" ROD" is
so amended which the EPA prepares at the conclusion to the
comment period.- --Are' the're any sucstions on the format for
the meeting this evening?
i
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Okay, again I encourage any of you wishing I
to comment to do so now or in writing before September 9th
briefly give an overview
I
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of what we talked about last month I
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I
and before we take any comments on the record I'll just
and the purpose of this.
On August 4th, when I was here last, we
discussed proposal to amend the Tinkharn's Garage Record of
Decision and basically what that proposal is the result of
"
APEX Reporting
Rtgis/trtd Profusional Rtporttrs
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is the Record of Decision which was originally signed
5
2
identified three candidates soil treatment techr-logies for
3
the site.
They were thermal aeration, soil washing and
composting.
s
A group of potentially responsible parties
6
that we've been negotiating with undertook a 'predesign study
7
on their own initiative to evaluate soil treatment
8
technologies and several other technical factors that need
to be taken into consideration prior to going into design.
As a consequence of that study, a fourth candidate soil
treatment technology was identified which had previously
only been briefly addressed in the feasibility study.
That
, fourth candidate was vacuum extraction utilizing a dual
extraction system which included a cOmbination of a grouna-
water pump and a vacuum pump whereby the groundwater pUr.lp
would serve to lower the water table in the area behind t~e
garag~ to increase the volume of soil which could be treated:
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I
by the vacuum process and also to pump the l!\ost conta1-'.inatedj
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I
portion of the shallow ground water for treatment at the
Derry Wastewater Treatment Plant.
The vacuum part of the
extraction system would create a negative vacuum in the
soils which would draw air through the contaminated soils
carrying contaminants to the extraction wells which would
then be carbon filtered and discharged into the surrounding
a~r .
APEX Reporting
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6,
7
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That is a quick s~4ry of the vacuum
extraction process and the agency based on the results of
the predesigned study has issued a proposal to amend the
"ROD" to utilize this dual vacuum extraction system for
soil treatment for the Tinkham's Garage Site.
At this time
I will now take public comments, oral comments on the
proposal to amend.
Does anybody have any desire to make
comments at this time?
Okay, I'd like to thank you all for your
participation and I now hearby declare this hearing closed,
and we'll take any questio~s, Charlie and I will take any
ques tions .
(~1ereupon the hearing concluded at 7:48 A.M.)
I
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APEX Reporting
R(gis/(Ttd Pruf(ssional R(pllr/tTS
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'7
C£RTIFICATE OF REPORTER AND TRANSCRIBER
This :'3 to certify that the attached proceedings
:::~:ore:
United States Environmental Protection Agency
~~ the Matter of:
'k~ENDMENT TO THE RECORD OF DECISION
RE:
TINKHAM'S GARAGE SUPERFUND SITE
?lace:
Londonderry, New Hampshire
~:-c.
-'-"--.
August 8, 1988
&.':,,= =~
.~e:= as
he=:.:.~
appears, and ~'a~ ~,is is the t=ue,
:: =:-:'::-',::e
a~d co~?lete transcript prepared from the notes
. , . .
~~~~.Q= ~ec=~c~~gs
taken 0= the above titled proceedi~g.
v. Rasmussen
13/8/88
Date
:\=::C~t.2:'"
J. Rasmussen
8/12/88
Da~e
-:=:~~s==:::':e=
-------
...... 10. ~.l"LJ..Li'\, 1.J
UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
REGION I
PUBLIC HEARING ON TIlE AMENDMENT TO TIlE REroRD OF DECISION
. for
Tinkha~'s Garage Superfund She
September 8, 1988
Hearing AUendees
Nlme
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; Superfun~ Program Fact Sheet
Tinkh,am's Garage Site
Londonderry, NeuJ Hampshire
1
EPA I
Region I
July 1988
EPA Proposes Use of Vacuum Extraction
Process to Treat Contamination at the
Tinkham's Garage Superfund Site
On $epten .ber 30, 1986, EP A signed a Record of ulU:hing Fid4s: Sampling for Soil contamina tion was
D~dsion (ROO)- for the Tinkham's Garage Superfund site conducted (or alllhirteen condominium leaching fields.
designating either thermal aeration, biological treatment, SignHicant levels of Vex: contamination were foW\d only
ot:soiI washing as the remedial alternative that EP A would in fields III and K/L No contamination was detected in
use to address soil contamination at the site. Contaminated signiiicant amounts in the other leaching fields. Soil
groundwater would be treated at the Derry, New Hamp- contamination in fieJds III and K/l is limited to soils
shire Publidy Owned Wastewater Treatment Works overlying the leachfieJds. Approximately 2,CXXJ cubic yards
(PO'IW). of soil from the leachfields will require treatment.
In September 1987, EP A entered into an agreement . - ,
witli 23 of the Potentially Responsible Parties (PRPs) at Garag~ Ar~a Soil: The pre-design study found thA, .
the, T1Iill\am's Garage Superfund site to conduct a pre- ' approximately 6,500 cubic yards of soi]s in the garage area
design study to address remaining groundwater issues, are contaminated with volatile organic compoU1\cU
define furthe!o the extent of soil contamination, and evalu- (VOCs) at levels ~ng ~~,tI!1,eJ:I~,The YOC cont:ami-
a:te-the soil treatment technologies4dentiliecHnthe'ROD:'--- unatiOn' ifppearS-tobe'tim£ted to the upper garage area and
uraddition.. the PRPs conducted an on-site piJot study of is concentrated in the top (our (eet of soil.
the effectiveness of in-situ vacuum extraction, an innova-
tive'technology for treatment of contaminated soils. These
s.tudies are now complete.
A5 a result of the infonnation gathered in the pre-
design study and the pilot study of vacuum extraction,
ErA.is proposing to amend the ROD for the Tinkham's
Garage Superfund site to designate the use of vacuum
extraction to treat contaminated soils at the site. The
results of the study,EP A's proposed amendments, and the
rationale for amending the ROD are presented in this
information update.
Results of the Pre-Design Study
A5 part of the pre-design study, the PRPs coI1ected
additional data to characterize the extent of contamination
at the site. 1l\e results are descnOed briefly below. (For
locations of areas described below, please refer to Figure
n.
.Words 111 boW ~ ar~ defined ~ a gJOISISal)' on page S.
.;
Soil Pile:The soil pile contains soil that was rerroved
during earlier excavations of leaching field soils. It aver-
ages six (E!(!t in dept!' and encompasses an area approxi-
mately 30 feet by 70 feet. Four to five hundred cubic yards
of soil in the pile are contaminated with volatile organic
compounds at levels requiring treatment
SoltJent Swal~:No contarrunants at levels requiring
remediation were detected in the solvent sw~le.
Groundwater EtJlllua tit. n:The pre-design study
confirmed a direct ronnection between groundwater
beneath the garage are41 and the wells formerly used by
the condominium complex. Contamination levels in the
two bedrock production wells were evaluated (or compli-
The Public's Role
See page 2.
-------
ance with the pre-treatment standards (or the Deny
PO'IYV. The groundwater contaminants from'these wells
were weD bclow the pre-treatment standards and, there-
(ore, can be pumped directly to the POTW without pre-
tre> o.rr.ent. .
l
-------
Figure 1: Map of Study Area, Tmkham's Garage Site, Londonder~ NH
TLnkham's
Garage
o
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LEGEND
kitrj Woodland Village Condominium Buildings
~ Leachfields for Condominiums
Not To Scale
~
Wetlands
-------
process or treated with groundwater coUected from other
parts of the site.
. It is believed that biological treatment would meet
federal and state public health and environmental stan-
df.rds, wou1d reduce the mobility. volume, and toxicity of
~ mtarninants, and would provide both short- and
lo"o-tenn protection of public health and the environ-
ment. Engineering controls would be required to prevent
the emission ,of contaminants during excavation of con-
o taminated soil. The total cost of implementing biologic:al
treatment is estimated at $1,200,0CX>.
In-Sib V4CSlum &tracticm: A.lb?r evaluating the
results of the pre-design study and the pilot study test 01
vacuum extraction, EP A is proposing to atTend the ROD
to require the use of vacuum extraction to treat contami-.
nated soil. Vacuum extraction would involve pumping air
from the unsaturated zone through a network of extrac-
tion wens to create a vacuum within the ground. The
vacuum draws VOCs out of the soils and into the weDs.
The VOCs would be captured in activated carbon filters,
after which the treated air would be released into the
atmosphere.
At the Tinkham's Garage site, 3S wens would be used
to create the required vacuum and cot1ection system. To
increase the size of the unsaturated zone and allow for
effective vacuum extraction of soil contamination. su~
mersible pump' would be pla~ in each well to extract
the shaUow groundwater lower the groundwater table.
Because contaminant levels in the shaUow groundwater
are above the requirements of the Derry PO'IW, the
extracted groundwater would be pre-treated to reduce
contaminant levels to rreet the POnV standards (see .
Figure 2). AU contaminated groundwater, including the
pre-treated garage area groundwater, would be piped to
the Derry, New Hampshire POTW in conformance with
the 1986 ROD.
Vacuum extraction. the soil treatment technology
being proposed by EPA for use at the Tinkham's Garage
site, is believed to meet federal and state public health and
environmental standards, would reduce the mobility,
volume. and toxidty of the contaminants, and would
provide both short- and long-term protection of public
health and the environment. It is believed that vacuum
extraction could reduce contaminant levels in soils to
cleanup goals in twc years or less. This alternative would
not require excavation of contaminated soils and, there-
fore, would not pose the risk of a release of VOCs due to
excavation. A positive safety consideration associated with
this remedial alternative is that, in the event of electrical or
mechanical breakdown. the vacuum would draw air into
the extraction system, limiting the possibility of the escape
of contamiJunts into the air. The estimated total cost of
vacuum extraction is $1,D45,(XX).
Figure 2: Typical Schematic of Vacuum, Extraction
." _: --~:':'~'~'--~.~~--~ ---~ . .
. """. .-. -.'- --. --- --- ..
~2
"
4
Groundwater to Derry
P.O.T.W.
Clean
Air
1
3 5 -+ 6
Water Table
l~end
1. &bnerslble pum p$ extract contaminated
grtU"Idwater and lower !tie groond'N3181'
~~8 .
2. Extraction W9Ds sat up along a grid sys1Bm
create vacuum
3. Water Separator
4. Pr&-trBatment of contaminated groundwa18r
5. Contaminant removal by carbon treatmer'lt
-------
.
For More Information
In!or",uztiO'ff R~otitori~,
Because this information update provides only a brief
description of the results of the pre- p.rn. - 8:00 p.m.
Sal, Sun.: Oased July - September
. .
Glossary .
Acti:t1't:.~4 Carbon: A powdered or granular form of
carOOD t:n.at has been treated to increase its surface area
amdadsorptlve properties. Activated carbon is widely
used. in pollution control. systems because many
ccnt:a.mi:nants readily adsorb, or adhere, onto il
. .
. .
Paftmtiizl1y Responsibl~ Parties CPRPs): Any.
imdi,vidu.al(s) or company{ies} (such as owners, trans-
porters, or geI\erators) potentially responsible for, or
c:ontributing to, the contamination problems at a ..
Superfund site. Whenever possible, EPA requires
PRPs, through administrative and legal actions, to
dean up ha..z.ardous waste, sites.
PTr-D'esip Study: A study undertaken to gather addi-
tinnal. site informa tion prior 10 implementing design of
~r.e:r.nedial alternative
-------
Mailing List Additions
If you or someone you know would like to be placed on the Tinkham's Garage Site Mailing List.
please fill out a1\d mail this form to: .
Paul Knittel
US. Environmental Protection Agency, Region I
Office of Public Affairs (HSV -2203) .
John F. Kennedy Federal Building
Boston, Massachusetts 02203-2211
Name:
Address:
Affilia tion:
Phone:
.-
United States
Environmental Protection
Agency
Region I
Office of Public Affairs-2203
John F. Kennedy Federa1 Building
. I3
-------
n
~
Tinkham's Garage Superfund Site
The t1. S . EPA announce8 that they will
hold a public hearing Thur8day, September
8 at 7: 30 p . Ill. on the prop08al to amend
the,Record o~ Deci8ion (ROD) on the
Tinkham' 8 Garage Superfund site, in
Londonderry, New Rampshire. - The hearing
will be held in the Cafeteria of the
Londonderry Public High School, located
on Mammoth Road in Londonderry. The
hearing i. intended to recei.e oral
comments from the public on the proposal
to amend the ROD. The public comment
period ends close-of-business on
September g, after which time no
additional comment8 can be accepted.
U.S.ENVIRONMENTAL PROTECTION
AGENCY - REGION I
-------
FOLEY, HaAG & ELIOT
ONe;. POST OF"F"ICE: SOUARE:
BOSTON, MASSACHUSETTS 02109
TELEPHONE: (617) 482.1390
IN WASHINGTON. O.C.
1C51!t ~ STREET, N_W
CABLE ADDRESS ""OLETHOAG"
TELECOPIER (617) 482.7347
WASHINGTON, D.C. Z0036
LAURIE; BURT
TELEX 840683
TELEPHONE (202) 775 '0&00
TELECO"'ER (202) 857.01.0
September 9, 1988
BY HAND
Gregory A. Roscoe, Esquire
U.S. Environmental Protection Agency
Waste Management Division HSN/CAN 3
J.F.K. Federal Building
Boston, MA 02203
Re:
Cannons Engineering Superfund Matter
Londonderry ROD Amendment.
Dear Mr. Roscoe:
On behalf of the Cannons Site Group, I enclose herewith for
inclusion in the record written comments with respect to the
proposed amendment to the Tinkham Garage Record of Decision. As
you know, the Cannons Sites Group is currently evaluating
vendors' bids for both thermal aeration and vacuum extraction
with respect to soil remediation at the Londonderry Site. . We
expect to be in a position to select a vendor within the next
week and a half and will advise you promptly of our decision.
Sincerely yours,
~~~
Laurie Burt
Project Coordinator
Cannons Sites Group
RSS:lk
enclosure
cc:
E. Michael Thomas, Esquire
Cannons Sites Group Executive
Cannons Sites G~oup Technical
Judy Tinkham
Committee
Committee
-------
September 9, 1988
Comments on the
Proposed Amendment of the Tinkham Garaqe ROD
Submitted by:
The Cannons Sites Group
After a careful review o~ the U.S. Environmental"Protection
Agency's Proposal to Amend the Record of Decision ("ROD") with
respect to the Tinkham's Garage Superfund Site in Londonderry,
New Hampshire (the "Site"), it is the view of the Cannons Sites
Group, a group of 25 potentially responsible parties, that the
ROD should be amended to permit the use of either thermal
."
aeration or vacuum extraction for source remediation of
; contaminated soils ai the Site.
During the course of the Pre-Design Study, thermal aeration,
vacuum extraction," biological treatment and solvent washing were
evaluated for application at the Tinkham Garage Site. Whe~
compared on the basis of compliance with ARARSi reduction of
toxicity, mobility or volumei short and long-:e:m e:fective~ess,
implementabilitYi costi and protection of human health and the
environment, vacuum extraction and thermal ae:ation were clearly
superior over the other two.
Furthermore, recent cost
information makes these ~echnologies more equivale~t.
Both thermal ae:ation and vacuum extraction are capable ~E
remediating the soils
to ::.
ppm total volatiles, although each
technolgy has. certain advantages over the other.
Low temperature
-------
thermal aeration processes batches under controlled conditions
such that the level of cleanup is assured throughout the batch.
Each batch is sampled for cleanup verification before it is
backfilled on site.
A passive downgradient collector trench will
. collect contaminated. shallow groundwater for treatment. On the
other hand, excavation of soils will be required during which
some release of volatile organic compounds will occur.
Any
disturbed wetlands will take time to ~eestablish themselves.
Vacuum extraction will treat the entire site at once;
however, remediation of some of the clay soils may require a
longer treatment time.
Vacuum extraction is advantageous in that
it would treat the entire soil profile rather than just the upper
four to six feet and without disturbing the soils.
It would also
aggressively remove ~ontaminated shallow groundwater from the
source area for treatment through the use of dual extraction
wells.
With respect to cost-effectiveness, the Pre-Design Study
indicated that vacuum extraction was far more competitive, that
is less costly, than thermal aeration.
The information upon
which this cost evaluation was based was provided by expert
consulting firms with extensive experience in development and
operation of these two technologies in the field.
-2-
-------
In light of the completion of the pre-Design Study report
and the pendency of the parties' settlement agreement in the
. Cannons Superfund matter, the Cannons Sites Group voluntarily has
begun the selection process for remedial action contractors, even
though the settlement embodied in the Consent Decree has not
received final court approval.
In preparing to implement the
settlement as eipeditiously as possible, the Group has recently
received cost information that suggests that thermal aeration is
more cost-competitive with vacuum extraction than had been
previously thought at the time the Feasibility Study was
developed.
This appears to be the result of recent refinements
in the thermal aeration technology based on the extensive
experience with that technology at the McKinn Superfund site in
Grey, Maine.
As we have advised EPA's technical staff, the Technical
Committee is working very closely with potential vendors of those
two technologies to better determine the cost and performance
implications, as well as the capabilities of each vendor.
The
Committee expects to complete its evaluation of vendor proposals
in the very near future and to make its final reco~~endation.
It
is our "current belief that both te~hnologies are technically
equivalent and appropriate for use at the site, and final
selection between the two can be made on the basis of refined
cost analysis in the contractor selection process.
In light of
-3-
-------
the technical equivalance of these technologies, 'we would request
that the Tinkham Garage Si~e Record of Decision be amended to
allow for use of either vacuum extraction or low temperature.
thermal aeration.
-4-
-------
FOLEY. HOAG & ELIOT
ONE: POST OF"F".CE: SOUARE:
BOSTON, MASSACHUSETTS 02109
TELEPHONE: (617) ",SZ.1390
IN WA.SHINGTON. D.C
CABLE ADDRESS "..OLEYHOAG"
TELECOP'ER (6'7) .152.7347
161!a L. STREET. N.W.
WASt04INGTOH. D.C. 20036
TELEX a.06a3
TELEPHO..E (202) 77!1.0600
TELECOPIER (202) 1I!l7.0'AO
LAURIE B"URT
September 29, lY~~
BY HAND
Gregory A. Roscoe, Esquire
u.S. Environmental Protection Agency
Waste Management Division HSN/CAN 3
J.F.K. Federal Building
Boston, MA 02203
Re:
Cannons Engineering Superfund Matter
Londonderrv ROD Amendment
Dear Mr.' Roscoe:
As you know, the Cannons Site Group submitted comments to
EPA earlier this mon~h expressing the opinion that both vacuum
extraction and thermal aeration appeared to be acceptable
technologies for soil remediation at the Londonderry Site. The
Group noted, however, that it was in the process of evaluating
vendors' bids for both thermal aeration and vacuum extraction
with respect to soil remediation at the Londonderry Site.
Having completed that evaluation, the Cannons Site Group has
come to the conclusion that based on all of the factors,
including the dual extraction capabilities of vacuum extraction
and its cost effectiveness, that the most appropriate technology
for soil remediation at the Londonderry Site is vacuum
extraction. Accordingly, the Cannons Site Group urges that the
Record of Decision with respect to the Londonderry Site be
amended to select vacuum extraction as the technology for soil
remediation at the Site.
Sinc()erelY yo~
~"--J ~~
Laurie Burt
Project Coordinator
Cannons Sites Group
LB:rs .
cc: E. Michael Thomas, Esquire
Cannons Sites Group Executive
Cannons Sites Group Technical
Judy Tinkham
Committee
Committee
-------
Environmental Protection Department
CIBA-G EIGY. Corporation
Ardsley, New York 10502-2699
Telephone 914 478 3131
CIBA-GEIGY
October 24, 1988
EMERY EXPRESS MAIL
Mr. Greg Roscoe
EPA REGION I
J. F. K. Federal Building
Boston, MA 02203
Re:
Tinkham Garage Site - Londonderry, Nfl
Update of Remediation Costs
Dear Greg:
I have reviewed the cost information for remedial technologies contained
in the Tinkham Garage Pre-Design Study Report. Since the submission of
this report, the technical committee has received turn key bids for both.
vacuum extraction and low temperature thermal aeration. When compared
purely on the basis presented in Table 3-6, that is, 9,000 cubic yards of
soil and collection and treatment of contaminated shallow ground water in
the garage area, the unit cost of vacuum extraction is $130/cu. yd. and
the uni~ cost of low temperature thermal aeration is $160/ cu. yd.
It is difficult to perfo,rm a true cost comparison of these technologies
as there are factors which affect the total cost of remediation which are
not easily quantified. For instance, while the volume of soil treated by
aeration can be quan~ified exactly and each additional cubic yard of soil
over the 9,000 cubic yards can be assigned a unit cost~vacuum extraction
is areally and time dependent, and an increaSe in the volume of
contaminated soil mayor may not increase the cost. It would depend on
whether the increase in contamination is with depth or area. Similarly,
it is felt that the dual vacuum extraction wells will more aggressively
capture contaminated ground water from the shallow aquifer in the garage
area. This should translate to a reduction in the time required for.
pumping the bedrock wells, and a cost savings. Such a savings would not
be reflected in Table 3-6 which provides cost information for soil
treatment independent of groundwater remediation.
I hope this information fulfills your request.
additional information is required.
Please contact me if
Sincerely yours,
4];'~aJ q 6£v
Diane M. Leber
SuperVisor, Environmental Protection
DLS:gg:04
cc:
J. McGuire/Monsanto
R. Sanoff/Foley Hoag & Eliot
M. Walters/Polaroid
'vv
..
-------
APPENDIX C
Federal and state ARARS
-------
Tinkham's Garage Site Amended ROD
Appendix C . Federal and State ARARs
page 1
Applicable or Relevant and Appropriate Federal Requirements
ReQuirement
Applicable
Relevant arid Appropriate""
RCRA 40 CFR Part 264
- Subpart G
x
X
X
X
X
- Subpart L
- Subpart N
National Ambient Air
Quality Standards
Clean Water Act
- Section 404
Part 230 CFR 40
Fish & Wildlife Coordination
Act
X
OSHA
X
- 29 CFR Parts:
1910
1904
E.O. 11990 (Wetlands)
X
-------
Tinkham's Garage Site Amended ROD
Appendix C Federal and State ARARs
page 2
Federal ARAR AnalTsis
RCRA 40 CFR Part 264
Subpart G: Closure and Post Closure
The Site shall be closed consistent with appropriate
subsections in a manner that minimizes the need for
further maintenance and; the closure minimizes or
eliminates to the extent necessarT to protect human
health and the environment, post closure escape of
hazardous substances into the environment. .
Subpart L: Waste Piles
Closure of the waste pile behind the condominium complex
shall comply with the appropriate components of 264.258
including removal of all residues, contaminated
containment. system components, and all equipment
contaminated with waste and leachate. .
Subpart N: Landfills
The Si te shall be closed consistent wi th appropriate
subsections of this subpart based on the nature of the
contaminant distribution as determined by post remedial
action sampling and analysis.
National Ambient Air Quality Standards (NAAQS)
40 C.F.R. Part 50, promulgated pursuant to the Clean Air Act
The appropriate discharge standards in this statute will
apply to air discharges from the vacuum extraction
process and the groundwater air stripper (if utilized).
Section 404 of the Clean Water Act
33 U.S.C. Section 1344 and 40 C.F.R. Part 230
The applicable subparts of this section will applT to
operations which may impact the wetlands and surface
water bodies on or near the Site. No activity that
adversely affects a wetland is permitted if a practicable
alternative exists.
Fish and Wildlife ,Coordination Act
16 U.S.C. subsection 661 et seq
Requires action to protect fish and wildlife from actions
modifying streams or areas affecting streams. EPA
consulted with the Department of Interior and the State
-------
Tinkham's Garage Site Amended ROD
Appendix C Federal and State ARARs
page 3
of New Hampshire which oversees administration over
wildlife resources prior to the selection of the remedy.
EPA will implement the action in accordance therewith.
Worker Safety Regulations
29 CFR Part 1904 promulgated pursuant to the Occupational Safety
and Health Act (OSHA)
This applicable regulation requires
occupational illness and injury
recordkeeping
of
29 CFR Part 1910 (OSHA)
This applicable regulation
conducted at the Site.
covers
work
operations
Executive Order 11990, Protection of Wetlands
40 CFR Part 6
The Protection of Wetlands Executive Order and this EPA
regulation are applicable and were weighed in the
evaluation ~nd development of remedial a1 terna ti ves.
The selected remedial action 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.
"
-------
I. CONTAMINANT AND ux:ATION-SPOCIFIC
APPI.lCABLF. OR REI.F:VANT AND APPROPRIATE
STATE RHJUIRF.NEUJ'S, J\MENDl:D RI'IT>HO OF mCISION
TINKHAM GJ\Rl\GF. SITE, LONDONDFJmy, NEW HAMPSHIRE1
l\{:plicable2
Relevant & Appropriate2
A. GROlJN[MA'I'ER:
1.
RSA 149:8,III:
N.H. J\dmin. Ws
Ch. 410 -
Protection of
Groundwater.
x
a. WS 410.05(a)
Discharges to
Groundwater.
x
b. Ws 410.09
Groundwater
Discharge
Cri teria,
incorporating
. by reference
Ws Part 302
(Maximum"
Contaminant.
Levels [MCL'sJ
a,nd Suggested
No Adverse
Response
Levels
[ SNARLS »
x
1
See Appendix A" for synopsis of each requiranent and discussion of action necessary to
attain J\RAR's.
2
'l11e absence of any symbol in the colunms designated "Applicable" or "Relevant and
Appropriate" indicates that, in the cirClUnStances present at this site, the requiranent is
'. applicable or relevant and appropriate. . - .
-------
1. mN'I'ANINlWI' AND LOCl\TlON-SPOCn'IC
APPI,ICJ\DJ.F. OR RELEVANT AND APPROPRIATE
S'I1\TE RB;2UJRFMEttI'S, ]\' TDID RfXX)RD OF DH~ISION
TINKHAM G1\RAGf; SITE, L ONDERHY, NEW H/\MPSHlREl
Applicable
Relevant & ~ropriate
c. Ws 4'10.10,
Additional
Groundwater
Cri teria. ,
x
d. Ws 410.05(e)
Groundwater
Quali ty
Criteria;
Health-based
groundwater
protection standards.
x
e. WS 410.05(9)
Groundwater
Quali ty
" Criteria;
t«:>ndegradation
of Surface
Water.
x
-------
I. CONI'J\MINl\NT AND r.OCATlOO-SPOCJFIC
APPI.ICABI.f: OR RElEVANT AND APPROPRIA1'E
STATE RD;)UIREMENI'S, AMfM)fD JUll)RD OF DEX::JSJON
TINKHAM GARAGR S1 rJ'Ef, LONDONDERRY, NEW HAMPSIUREI
I
Applicable
Relevant & Appropriate
B. SURFACE WATER
1. RSA 149:8,1 -
Enforcement of
Surface Water
Classifications.
I
2. Ws Ch. 400~'
Part 431 -
Water Quality
Standards -
Fish Life
3. Ws Ch.. 400,
Part 439 -
Antidegradation
Policy.
C. Wffi'LANOO n-wAcr
1. RSA 149:8-a,
Dredging and
Control of
Run-off: Ws
Ch. 400 Part
415, Dredging
Rules.
x
x
I X
X
-3-
-------
I. CONrnMlNANT 1-. ~TIOO-SP~IFIC
APPLICABLE OR RELI::VANT AND APPROPRIATE
STATE RFQUIHI'MEN'I'S, J\MEM)I'D RFroRD OF DOCISION
TINKHAM Gl\RJ\GE SIn:, r.ONDONmJmy, NEW HAMPSHIRE1
Applicable
Relevant & Appropriate
I
2. Fill and
Dredge in
Wetlands, RSA.
Ch. 483-A and
Wto Ch. 300,
Cri teria and
Conditions.
D. AIR .EMISSIONS
1. RSA 01. 125-C,
Air Pollution
Control1 N.H.
Admin. Code .
Air 010 100
Parts 604
through 6061
Part 1002.
E. HIS'IDRIC
PRESERVATION
1. New Harrpshire
Historic
Preservation
Act, RSA 227-C.
2. Weal Historic
Districts, RSA
31:B9-a-31:89-k.
x
x
-------
I. roNI1\MlNANT AND IDCATION-SPOCIFIC
APPLICABI.E OR RELEV1\NT AND APPROPRIA'I'E
STAn: lUQUIRD1EN1'S, AMENDfJ) RHX)J{n OF DErISION
TINKHAM GARAGE SJ'lE, LONIX)NDERRY, NEW HAMPSHIREI
Applicable
Relevant & Appropriate
E. HAZARPOUS WASTE
~I~
N.H. Hazardous
Waste Management
Act, RSA Ch..
l47-A; Hazardous
Waste Management
Rules~ N.H. ~n. .
Rules He-P Ch.
1905.
G. SOLID WASTE
RBJUIREMF.NI'S
N.H. Solid waste
Manag€ment Act,'
RSA Ch. l49-M; .
Solid Waste
Management Rules,
N.H. hlntin. Rules
He-P Ch. 1901.
y.
x
-------
J\CJ'ION-SPOCIFIC
APPI.lCABL.-- -0R REI lEVANT 1\ND APPROPRIATE
STAn: RFQJJRFMFNl'S, ]\MF1-Jmn RFroRD OF DOCJSION
TINKHAM GARAGE SI'l'F., I.ONIOIDERRY, NFW HJ\MPSflIIml
saJRCE CONI'ROL:
VAaJUM EXPRACTION
MJ\NAGEMENI' OF MIGRATION:
GROlJNIMA'l'ER PUMPDG AND
'mEA'lMENI'
A. HAZARDOOS WAS'I'E
IID;2UlREMENTS
1. RSA Ch. 147-A,
New HaJrpshire
Hazardous
Waste
Management
Act; N.H.
Mnin. Code
He-P Ch. 1905.
x
a. Hazardous!
Waste Facility
Security
requirements,
He-P
1905.08(d) ,
incoi:porating
by reference
40 C.F.R.
~264.14.
x
b. General
Inspection
Requirements,
He-P
1905.08 (d)( 4)(d)
x
KEY: X - AJ:pli cable .
- 0 - Relevant and Awrq>riate
'!he ~sence of any symbol in. the. column belCM a designated alternative indicates that the requirement
is not at1J1icable, or relevant and apptbtJ.tiate, with regard to the alternative.
- .
-------
II. ACTION-SPFCIFIC
1\PPI.lCABI.E OR REI.EVANT l\ND APPROPRIATE
STJ\1'E ~IRU1EN'J'S, J\MENDFD HEXX)RD OF nOCISION
'J'INKHAM GARAGE SI1'E, IONDONDF.RRY, NBV Hl\MPS}II~l
SOURCE CONrROI,:
VACUUM EXPRJ\C1'ION
MANAGEMENI' OF MIGRATION:
GROUNDWA'J'ER PUMPlOO J\ND
'IRE1\'IMENT
incorporating
. by reference
40 C.F.R.
~264.15.
c.
Personnel
Training, He-P
1905.08(d) (4) (e)
incorporating
by reference
40 C.F.R.
~264.16.
I
x
d. Location
standards,
He-P
1905.08(d)(4)(g)
incorporating
hy reference
40 C.F.R.
~264.18 and
He-P
1905.08(2)j.
x
e.
Preparedness
and Prevention
Requi rements,
lIe-P 1905.08
(d)(4)(h)
incorporating
by refprence
40 C
~264, ..,LItpart
C.
I
! .
x
-------
11. ACl'lUN-SPl'l..:H'JC
]\PPY,ICABl.E OR REI ,EVANT l\NI) l\PPROPIUA'I'E
STATE RB;2UIREMEN'J'S, AMENDI y,CORD OF DErISION
TINKHAM GAAJ\GE SI1'E, J,ONDONur.t{HY, NEW I\AMPSIIIREl
SCURCE CONTROL:
VAaJUM EXPRAC1'ION
MANAGEMEm' OF MIGRATION:
GROUNDWATER PUMPIN; AND
'IREA'IMENl'
. .
f.
Contingency
Plan, He-P
1905. 08(d)( 4) (i
)incorporating'
by reference
40 C.F.R.
264, Subpart
D. .
x
g. Groundwater
Protection,
He-P 1905.08
(d)(4)(j),
incorporating
by reference
40 C.F.R.
264, Subpart
F.
x
,
h. Closure and
Post-C1osure,
He-P
1905.08(d)(4)(k
) incorporating
by reference
40 C.F.R.
5264, Subpart
G.
x
1.
Transfer of
facility,
He-P
1905.08(d)(5).
x
I
! .
-------
II. ACJ'ION-SPECIFIC
APPLICABLE OR RElJ;:V1\NI' l\ND APPROPRIATE
STA'I'E RFQJIREMEN'I'S, AMENDED HH:'ORD OF DOCISION
TINKHAM G1\IU\CE SITE, I.oNDONDFJffiY, NEW If1\MPSHIREl
SOORCE COOTROL:
VAaJUM EXPRACTION
MANAGEMEm' OF MIGRATION:
GR()lJNIMA'I'ER PUMPIK; AND
'IREA1MENl'
. . .
j'. ~itoring,
, He-P
1905.08(d)(6):
x
k.
Public
Notification
p]an, He-P
1905.08(d) (9).
o
1. General
envi ronmental
standards,
He-P
1905.08(d)(1).
x
m. General design I
standards,
He-P
1905.08(d) (2).
x
n. Technical
Standards for
landfills,
He-P
1905.08(f) (1) (f)
incorporating
by reference
40 C.F.R. ,
'~264, Subpart
, N, and He-P
1905.08(f) (2) (d)
-------
II. ACT10N-SPBCIFIC
A,PPI..ICADLE OR RELEVJ\N'f/ "),J[) APPROPRIATE
STA'I'E ~IREMEN'JS, J\MF1IIDF,. .XDM OF DOCISION
TINKHAM GARAGE S,ITE,LONDONDtAAY, NEW Hl\MPSHIREl
SOURCE CONI'ROr..:
VAaJUM EXPRACTION
Ml\NAGEMEN'J' OF MIGRATION:
GRO~A'l'ER PUMPItIG AND
'lRFA'IMENI'
o. Additional
Technical
Standards for
Treatment He-I'
1905.08(f) (2)
(a). .
p. lIe-I'
... 1905.08(f) (2) (e)
Storage
Standards.
q. Technical
Standards for
Waste Piles,
He-I'
1905.08 (f)( 1 )(d)
incorporating
by reference
40 C.F.R. 264
Sutpart L.
r. Technical
Standards for
Use and
Management of
Cont.ainers,
He-I'
1905.08(f) (1) (a)
incorporating
by reference
40 C.F.R. 264,
Suhpa rt 1.
x
x
x
I
I
. !
i
I
I
x
:,
I
I
I
I
I
- I
-------
II. J\CI'lON-SPfCIFJC
APPLICABLE OR RETJ;:\1ANr /\ND APPROPIUATE
STA'I'E ~IREMI1'ITS, J\MENDJ:D RfffiRD OF DFLISION
TINKHl\M G!\Rl\GE SI'J'E, LONDONDfJmY, NEW IIAMPSHIR1::1
. .
SOURCE CONI'ROL:
VACUUM EXPRACI'ION
MANJl,GEMEN'I' OF MIGRATION:
GROUNrM'A'I'ER PUMPUG AND
'I~EA'IMENl'
s.
Technical
Standards for
Tanks, He- P
1905.08 (f) (1 )(b)
incorporating
by reference
40 C.F.R. 264,
Subpart J.
x
t.
Standards for
Generators,
He-P 1905.06.
x
u. Manifesting
Requirements
He-P 1905.04.
x
...
v.
Packaging and
labelling
Requirements,
He-P 1905.05,
incorporating
by reference
N.H. Pdrnin. .
Code Saf-C-600
and 40 C.F.R.
~~ 172, 173,
178, and 179.
x
-11-
-------
II. AC]'ION-SPFCIFIC
APPLICABLE OR RELEV"'- AND APPROPHIATE
STATE REJ;2UIRFMENI'S, N1Fl\ . RJX'ORD OF DOC] SION
TINKHAM GARAGE SITE, I .oNOONDERRY, NEW IIJ\MPSllIJml
saJRCE CONI'ROL:
VACUUM EXPRAC]'ION
MANAGEMfl\IT OF MIGRATION:
GROlJlIDV1\'I'ER PUMPIN:; AND
TREA'IMENI'
SOLID WASTE
~UIREMENl'S
1. REA Ch. 149-M,
New Hampshire
Solid Waste
Management
Act; N.H.
Mmin. Code
He-P Ch. 1901.
B.
x
C. ACTION-SPECIFIC
AIR ENISSION
LIMITS
1. N.H. Admin.
Code Air Parts
604 through
606.
.,
x
2.
Fugitive Dust
EhUssion
Control, . N.H. ,
Mmin. Code
Air Part 1002.
x
D.
ACTION-SPECIFIC
GROUNDWATER
PHO'l'OC'I'ION
STANDARDS
-------
II. ACI'ION-SPOCIFIC
,
APPLICABLE OR RELEVANT AND APPROPRIATE
STATE RB;!l]IREMmI'S, J-\MF2-JmD RIXDRD OF DOCJSION
TINKJIl\M GARAGE SITE, IONDONmJlRY, NfW Hl\MPSIITRE1
SOORCE CONI'ROL:
VJ-\aJUM EXPRACfION
Ml\NJ\GEMENT OF MIGRATION:
GROt.JNOOATER PUMPlf\(; AND
TREA'lMENT
1. RSA
149:8,III;
N.H. lIdmin
Code Ws Ch.
410.
x
AcrION-~PECIFIC
E.
SURFACE WATER
PRm'I£TION
S'l'ANDARDS
1. RSA Ch. 149;
N.H. Admin
Code WS Ch.
430.
x
~
2.
RSA 149:4-a;
N.H. Admin.
Code Ws Ch.
900, Part
. 904,
Pretreat:ns1t
-------
II. . ACTION-SPFCIFIC
APPLICABLE OR Rill. 'ff AND 1\PPHOPRIA.TE
ST!\TE REY.JUIRFMEN'rs, A. - ~~DFD JUillRD OF DErISION
TINKHAM GARAGE SITE, WNDONDERRY, NJ~ HJ\MPSflTREl
SOORCE CONI'ROL:
VAaJUM EXPRACTION
MJ\NJ\GEME1'J'I' OF MIGRNT'ION:
GR~A'l'ER PUMPIN.; AND
TRJ:A'IMENT
Standards for
publicly
'wned
treatment
works (roIW).
x
F.
STANDARDS FOR
PUI3LIC WA'I'ER
SYS'l'IMS
1. N.H. Safe
Drinking
Water Act,
RSA l48-B: Ws
Part
...
-------
APPIN)IX [\
I. CONI'AMIN1W~ AND I.o:::J\TION-SPFCIFIC
APPLICABLE OR REtJ':VANT AND [\pPHOPHIA'1'E
STA'l'E REJJ{JIREMENfS,. TINKlW1 GARAGE SITE, LONOONDERRY, NEW HAMPSIlIRE
. .
S1'm'E RB;;?UIR,EMENl'
R,BJUIREMENI' SYOOPS1S
A.
GR()lJNOOATER :
1. RSA 149:8,111; N.H. These provisions regulate dis-
lIdmin. Code Ws Ch. 410 - charges to groundwater and
Protection of Ground- provide for groundwater protec-
water. tion. No substance designated
in Ws Cho 410, or presenting
a potential threat to health or
the environment pursuant to
Ws 410.05, may be discharged to
groUndwater' so as to exceed water
quality criteria at or beyond any
CCIT1pliance boundary, as defined by
Ws 410.04(c) and Ws 410.13(a)(3).
COrrective action may also be
required if groundwater degradation
occurs at any point wi thin an inter-
vention zone, as defined under
Ws 410.13. see WS 410.14(b)(2).
a.
Ws 410.05(a)
Discharges to
Groundwater
Ws 410.05(a) prohibits discharge
of hazardous waste to groUnd-
water
ACTION '10 BE TAKEN 'IP ATI'A1N ARM
. . .
Site must. be remediated to prevent
release of contaminants in violation of
these provisions. See below for dis-
cussion of specific water quality cri-
teria pursuant to Ws Ch. 410.
~
Raoodial action to eliminate the uncon-
trolled discharge of hazardous waste
constituents, volatile organic
compounds (VOC's), and inorganic
contaminants to the groundwater
-------
CON'.I7\MINJ\NT-. AND LOCA1'ION-SPH::IFIC
APPLICABLE OR RELP'>I"JT AND APPHOPRJATE
STA'l'E HEQUlREMENTS, TINKHAM GAJV\.. JI'J'E, LONlX)NDERRY, NEW HAMPSHIRE
S'l'A'j'E REX;2UI~
ACTION '.ro BE TAJ(m ro A'JWJ'AIN ARM
REQUIREMENT SYNOPSIS
I
A.
GROUNOOATER: (Continued )
b.
Ws 410.09 Ground-
water Discharge
Criteria,
incorporating by
reference Ws Part
302 (Maximum
Contaminant Levels
[fvCL's] and
Suggested No
Adverse Response
levels [SNARLS])
c.
Ws 410.;10,
lIddi tional Ground-
water Criteria
Ws 410.09 establishes groundwater
discharge criteria which
include the MCLs and
SNARLS adopted by the Water
Supply and Pollution Control
Division and codified at
Ws Part 302, Drinking Water
Regulations. Standards appli-
cable to contaminants found at
at the site include SNARLS for
lifetime exposure to toxic con-
taminants, Ws 302.08{a);
SNARLS for contaminants associated
with cancer risk, Ws 302.08 (b); and
MCL's, WS 302.02, Ws 302.04, and
WS 302.11.
Ws 410.10 provides that ground-
water shall not be altered so as
to render it unsuitable for
drinking water. Drinking water
standards applicable to the
site pursuant to Ws 410.10
include both state and federal
miniImnn requiranents. See,~.;
N.H. Safe Drinking Water Act, RSA
Ch. l48-B; N.H. Admin Code Ws Part
302; federal MCLs for volatile
-2-
Remedial action to eliminate discharge
of contaminants, including VOC' s and
inorganic contandnants, resulting in
groundwater contamination above State
MCL and SNARL levels.
Remedial action to eliminate discharge
of contaminants rendering groundwater
unsui table for drinking water.
-------
CDNTAMlNAN'l'- AND 11X:J\TION-SPECIFIC
I . APPLICABLE OR RH.I::VAN'f AND APPHOPRJATE
S'I'ATE ~UIRF14ENTS, TINKJll\M GARAGE SI'1'E, IDNIXJNDERHY, NEW HAMPSHIRE
S1~1TI Rl'~UlREMENT
J\CI'ION '1'0 BE 'J'J\KEN TO A'JWJ'AIN J\RJ\R
RBJUlREMENr SYNOPSIS
A.
GROUNDWA'l'ER: (Continued )
d.
Ws 4l0.05(e)
Groundwater
Quality Criteria1
Health-based
groundwater
protection
standards.
e.
Ws 410.05(g)
GrO\mdwater
Quality Criteria1
Nondegradation
of Surface
Water.
organic contaminants, 52 Fed.
Reg. 25,716 (July 8, 1987) (to
be codified at 40 C.F.R.
S141. 61 (a) ) .
Ws 4l0.05(e) provides
that groundwater shall
not contain any substance which
the Water Supply and Pollution
Control Division (WSPCO) deter-
mines may be harmful to human
health or theenvi ronment . In
determdning applicable standards
under Ws 4l0.05(e), WSPCD refers
to health advisory lindts
established by the New Hampshire
Division of Public Health
Services (DPHS). See RSA
l48-B:V,IV.
Ws 410.05(g) provides that
groundwater quality shall not
be degraded such that it results
in a violation of surface water
standards in any surface water
body within or adjacent to the
site, and therefore incorporates
surface water standards set forth
at RSA 149:3 and Ws Ch. 400 Parts
-3-
Remedial action to eliminate discharge
of substances which may be harmful to
health or the environment, which may in-
clude substances exceeding the 10-6
cancer risk health advisory limits
established by DPHS.
~
Remedial action to eliminate any dis-
charge to groundwater resulting in a
violation of surface water quaiity at
adjacent surface waters, including
Beaver Brook. Class B standards
include dissolved oxygen,
coliform and pI! limits, see RSA 149:3,II
and WS 432.02; limits on potentially
toxic concentrations or
-------
CONTAMINANT- AND J1X1\'l'ION-SPFX::IFIC
APPLICABLE OR Rill,EVJ\NT ~~:rT) APPHOPRIJ\'I'E .
STATE IID;2UlREMENTSv TINKHAM GARAGE: SI1~ DNDONDEHHY, NEW HAMPSHIRE
S'I'A'l'E RB;2UIREMlWI'
! .IIDJUIREMENr SYNOPSIS
ACTION '00 BE TJ\KEN 'IU ATI'AIN ARM
A.
GROUNDWATER :
(Continued)
"
4)1-43~. The unnamed brook at
the Tinkham Garage site
discharges into Beaver Brook,
a Class B surface water;' See
Laws 1957, 130:1 (designation
as Class B-I of all Beaver Brook
tributaries in specified towns
including wndonderry) Laws 1967
147:15 (reclassifying Class B-1
waters as Class B). Therefore,
standards applicable to the
Tinkham Garage site include
standards for the preservation of
Class B waters set forth in RSA
149:3,11 and N.H. Adndn. Code
Ws 432.01 - 432.16.
. B.
SURFACE WATER
1.
RSA149:8,1
RSA 149:8 prohibits the dispqsal
of wastes in such a manner as
will lower the quality of any
surface water below the minimum
requirements of the surface
water classification. Standards
applicable to the Tinkham Garage
site include standards for the
preservation of Class B waters.
See discussion at I,A,l,e above.
-4-
canbinations of substances, WS 432.03;
and limits on the discharge of phenols,
WS 432.14. Discharge of inadequately
treated wastes into Class B surface
waters is prohibited, and Class B waters
are to be maintained as acceptable for
use, after adequate treatment, as water
supplies. RSA 149:3,11.
."
Remedial action to eliminate any dis-
charge to surface waters in or adjacent
to the site which lowers the qL3lity of
any surface water body below the appli-
cable classification requirements.
-------
CONTAMINl\Nl'- J\ND UX1'\'I'JON-Spn:IFIC
APPLICABLE OR RELEVANT AND APPROPRIA'l'E
I STATE ~IRfl\1ENI'S, TINKlI!\M GARAGE SI'I'E, IONDONDERRY, NFW HAMPSHIRE
S'I7\'I'E REQUlREMENI'
ACTION 'ro BE TAKEN 'ro A'ITAIN ARAR
RB;2UlREMEm' SYNOPSIS
B.
SURFACE WNl'ER:
(Continued )
I .
I
2.
Ws Ch. 400,
Part 437 - Water
Quality Standards
- Fish Life
3.
Ws Ch. 400,
Part 439 - Anti-
degradation
Policy .
C.
WE.TLANDs IMPACT
1.
RSA l49:8-a~
Dredging anc1
Control of
Run-of f.; Ws Ch.
400 Part 415,
Dredging Rules.
Ws Ch. 400, Part 437 provides
that state surface waters shall
be free fran chEmicals or con-
ditions inimical to fish life,
see Ws 437.02, and shall be pre-
served as potential cold water
fisheries, Ws 437.01.
Ws Ch. 400, Part 439 establishes
the state policy against
degradation of existing water
quali ty, and requires protec-
tion of in-stream beneficial uses.
RSA l49:8-a and Ws. Ch. 400
Part 415 establish criteria
for conducting any acti vi ty
in or near state surface waters
which significantly alters ter-
rain or may otherwise adversely
affect water quality, inpede
natural runoff or create
unnatural runoff. Activities
-5-
Remedial action to eliminate dis-
charge of substances, including VOC's
and inorganic contaminants, which may
cause condi tions inimical to aquatic
life.
Ranedial action to ensure that
surface water quality is not
degraded due to discharge of con-
tamdnants fram the site.
Wetlands and surface waters are located
in and adjacent to the site. Remedial
activities on the site must canply with
these criteria for the protection of
state surface waters.
-------
OOWfAMI~ AND IOCATION-SPFCIFIC
APPLICl\DLE OR RELE\(J\N'f AND APPROPRIA'l'E
STATE REJ;2UlREMENI'S, 'I'INKJ\J\M GARJI{;' .'I'E, IONJ)OY-JDI;;RRY, NEW HAMPSHIRE
STATE ~IREMENl'
~IREMFNI' S:YNOPSIS
AcrION 'ff) DE TAKm 'IO A'ITAIN MAR
C. WETLANDS IMPAql':
(Continued )
2.
Fill and Dredge
in Wetlands, RSA
Ch. 483-A and
Wt. Ch. 300,
Criteria and
Condi tions.
D.
AIR. a-uSSIONS
1.
RSA Ch. 12S-C, Air
Pollution Control;
N.H. MInin. Code
Air Ch. 100. Parts
604 through 606;
Part 1002. "
j
wi thin the scq>e of these pro-
visions include excavation,
dredging, and grading of topsoil
in or near wetland. areas.
RSA 483-A and Ws Ch. 300 regulate
filling and other activities in
or adjacent to wetlands, and
establish criteria for the
protection of wetlands fran
aaverse impacts on fish, wild-
life, carmerce and public
recreation.
These provisions establish
standards for the release of
air emissions, including VOC's
and hazardous air pollutants.
Applicable standards include
the most stringent of the follow-
ing requirements:
(1) New Source Performance
Standards, (40 C.F.R.. Part 60):
-6-
Wetlands are located in and adjacent to
the site. Ranedial activities on the
site must comply with these wetlands
protection requirements.
Renedial action may be necessary
to prevent unpenni tted
air emissions fram the site, including
volatilization of soil contaminants,
and to prevent the release of fugitive
dust, during ranedial activities.
-------
mID'N1IWWI'- AND I,OCATION-SPI'CJFIC
APPLICABLE OR RF1J--;vANT AND 1\PPROPRIATE .
SrATE ~IR&1ENTS, 'I'INKHl\M GARAGE SI'I'E, IONIXJI-JDEJUerties.
This provision authorizes
municipalities to establish
historic districts and to regu-
late construction, 'alteration,
other activities affecting
historical prq>erties and
districts.
-7-
Site activities which affect any
historic property must comply with
the provisions of this statute.
Site activities which affect historic
properties or districts should take
into consideration local historical
preservation provisions.
~
I
-------
,'mNrAMINANI'- AN)) LO::ATION-SPlCIFIC
APPLICABLE OR RELE'/ ~ AND J\PP}IOPHJ ATE
STATE ~IREMENrS, TINKHJ\M GMAGt. "':'fE, rD.NI:X)NDfJmy, NEW HAMPSHIRE
STATE RB;2(.JIREMENT
ACTION. W DE 'l'1\KnJ TO A'ITAIN ARM
RD;2UIREMENI' SYOOPSIS
F.
HAZARroUS. WASTE ~.IJID1EW'S
N.H. Hazardous Waste
Managanent Act, RSA Ch.
l47-A; Hazardous Waste
Managenent Rules, N.H.
Admin. Rules He-P Ch.'
1905.
G.
SOLID WASrE ~IJID1EW'S
N.H. Solid Waste
Management Act, RSA Ch.
l49-M; Solid Waste .
Managenent Rules, N.H.
Admin. Rules He-P Ch.
1901. I
i'
These provisions establish
requirements for the treabnent,
storage, transportation and dis-
posal of hazardous waste.
These provisions establish
requirements for the treatment,
storage, and disposal of solid
wastes.
-8-
Hazardous wastes on site must be managed
and disposed of in accordance with these
requirenents. ~ Section II, supra.
. Solid wastes 00 site must be managed
and disposed of in accordance with these
requirements. See Section II, supra.
,
-------
II. ACTION-SPECIFIC
APPLICABLE OR REJ~-Vl\NI'. AND APPHOPRIA'I'E
S'rA'I'E R,I~I~, TINKHAM GARAGE SI'l'E, IONIXJNDrnRY, NEW HAMPSHIRE
STA'1'E ~UIREMENT
. .
~IREMENT SYOOPSIS
ACTION '10 BE TAKEN 'IO AT'I'AIN ARAR
A.
HAZAJUX)US W1\STE ~UUHmS
b.
1.
RSA Ch. 147-A,
New Hanlpshire
Hazardous Waste
Managanent Act;'
. N.H. hhnin. Code
He-P Ch. 1905.
a.
Hazardous Waste
Facility Security
requirements,
He-P 190.5.08(d),
incOrporating by
reference 40
C.F.R. S264.14.
General Inspection
Requirements,
lre-P 1905.08(d)(4)
(d ), incorpora-
ting by reference
40 C.F.R. S264.15.
c.
Personnel Train-
ing, He-P 1905.08
(d)(4)(e),
incorporating by
reference
40 C.F.R.
S264.l6.
These provisions establish
standards awlicable to the
treatment, storage, transport
and disposal of hazardous waste
and the closure of hazardous
waste facilities. See He-P
1905.02(a) .
This provision incorporates
federal RCRA requirements for
tle adoption of security
measures to protect the public
fran exposure to hazardous wastes.
'I1ris provision incorporates
federal RCRA requirements for
tile regular inspection of
hazardous waste facilities.
'I11is provision incorporates
federal RCRA requi ranents for
the training of hazardous waste
facill ty personnel to ensure
canpliance with applicable
standards and effective emer-
gency response.
-9-
Hazardous waste on site must be
managed, stored, transported and dis-
posed of in accordance with the
Hazardous Waste Management Act and
t he rules thereunder. See
belON for additional diS::-
cussion of these requirements.
. The facility would be required to be
fenced, posted, and operated in cern-
pHance with this provision.
'!he facility would be required to
implement regular inspections, main-
tain written records, and remedy
operational problems in accordance with
this provision.
....
The facility would be required to
implement a personnel training pro-
gram and to maintain wri tten records
in accordill1ce with this provision.
-------
II. AC~'ION-SPECIFIC
APPLICABLE OR m1J~VANT AND l\PPHOPR,lA'I'E 0
STA'l'E ro:1JUIRENENI'S, TINKHAM GJIJUIGr TTE, . LONOONDrnRY , NB>l HAMPSHIRE
S1'M'E RWJI~
~IREMENT SYOOPSIS
ACTION TO BE TAKEN TO. A'ITlUN l\RAR
d.
Location standards,
He-P 1905.08(d)(4)
(g), incorporating
by reference .
40 C.F.R. S264.l8
and He-P 1905.08
(2)j.
e.
Preparedness and
Prevention .
Requirements,
He-P 1905.08
. (d)(4)(h)
incorporating by
reference 40 C.F.R.
S264, Suq,art C.
f.
Contingency Plan,
He-P 1905.08(d)(4)
(i), inCC?rporating
by reference
40 C.F.R. 264,
Suq:art D.
He-P 1905.08(d)(4)(g) restricts
the siting of hazardous waste
facilities near geological fault
areps and flood plains. He-P
1905.08(2)(j) sets forth the
State procedure for identifying
the boundaries of flood plains.
'!his provision incorporates
federal RCRA requirarents for
prevention and response to
releases of hazardous waste.
'ltIis provision inoorporates
federal RCRA. requirernents for
oontingency plans and emergency
procedures. .
-10-
. '!11e location and design of any hazardous
waste facility must meet the require-
ments of He-P 1905.08(d)(4)(g).
Facility construction and cperation must
include provisions for internal CX111T1uni-
cation, equipnent, emergency response
capability, and arrangements with local
anergency response authorities in
acoordance with his provision.
. The facility would be required to
develop and maintain written oontin-
gency plans and arergency procedures
in accordance with this provision.
-------
II . ACTION-SP~IFI~
APP,LICABLl~ OR RELEVAm' AND lWPROPRIATE .
STA'I'E- ~IREMEN'rs, TINKH!\M GJ\I~E SI'l'£, lpNIX>NDEamY, ~ HAM,PSHlRE
STA'I'E ~IREMEW'
g.
GroundWater
Protection,.
He-P 1905.08
(d)(4)(j),
incorporating by
reference
40 C.r.R. 264,
Subpart F.
h.
Closure and
Post-C1osure,
He-P 1905.08
(d)(4)(k)
incorporating
by reference
40 C.F.R. S264,
Subpart G.
I
! .
. .
RB:2UIREMENT SYNOPSIS
'Itlis provision, which incorpor-
ates federal RCRA standards, .
sU(t>lements N.H. Mmin. Code
Ws Ch. 410 by establishing
additional standards for ground-
water,monitoring and appropriate
remediation at hazardous waste
facilities. '!he provision pro-
hibits the.discharge of consti-
tuents into groundwater above
federal RCRA limits for such
ccntaminants at the ~liance
point, which is defined as the
boundary of each waste management
unit under' 40 C.F.R. S264.95.
'Ibis provision, inoorporating
fEderal RCRA requirenents, sets
forth design and performance.
standards for hazardous waste
facility remediation and closure.
-11-
J\C'TION ro BE TAKEN ro ATl'AIN l\RAR
. . .
~le facility would be required to
implanent a groundWater monitoring and
protection program in accordance wi th
this provision.
'!he facility would be required to
develop and imp1arent a written plan
for site closure and post-closure
care in accordance with this provision.
:)
.0
I
-------
II. Ael'ION-SPFCIFJC
,APPLIC1\I3JJ-: OR REI.r.VANT AND APPHOPRI]\TE
S'N\TE ~IREMENI'S, TINKHAM GARAG' "n:q IDNI)'JNDERRY, NEW HJ\M:PSHIRE
o
'.
S'I'J\'I'E ~IREMENT
,. ..
i.
Transfer of
facility,
He-P 1905.08
(d)(5).
j. . fobni wring,
He-P 1905.08
(d)(6).
k.
Public Notifi-
cation Plan,
He-P 1905.08
(d)(9).
1.
General
environmental
standards, He-P
I
i:
~IREMENl' SYNOPSIS
. .. - . .
~li5 provision establishes
requirements for notifying the
Division and future a-mers or
~rators when the facility
is transferred.
~ese provisions establish .
groundwater monitoring require-
ments and authorize the Division
to require other appropriate
environmenta 1 rooni toring.
~lis provision authorizes the
Division to require develcpnent
of a program to infoD1\ the .
public of the status of facility
activities. ]I. public notifica-
tion plan is appropriate to
ensure that the public will
receive on-going information as
to the iIrplementation of the
selected remedyand'the'status
of site closure. .
~is provision requires
facilities to CCII{>ly with
specified state and federal
-12-
ACTION 'ro BE TAKEN ~ ATTAIN ARM
Carpliance with this provision would be
required prior to any transfer of
facility a-mership or operation.
Operation of the facility would require
groundwater monitoring; additional rooni-
toring, including air emissions testing,
may be necessary to detect releases of
fugitive dust or VOC's during remedial
activities.
]I. program for regular notification of
the public as to the status of site
ranediation should be developed.
Facility operation must CCII{>ly with
environmental and occupational safety
requirements.
~
-------
II. ACI'ION-SPR~IFIC
. APPI,ICABIE OR REI ;E:-JANl' AND APPROPRIA'l'E
STATE REQUIREMENTS, TINKJIJ\M GAlU\GE SITE, IDNOONDERRY, NI;W H1\MPSHlRE
S'IWI'E REQUIREMENT
1905.08(d) (1).
m.
General design
standards, He-P
1905.08(d) (2).
n.
Technical
Starrlards for
landfills, He-P
1905.08(f)(1)(f),
incorporating by
reference
40 C.F.R. S264,
Subpart N, and
He-P 1905.08
(f)(2)(d).
~IREMD1I' S:YOOPSIS
. .
environmental standards and to
provide protection to workers
in accordance with state and
federal occupational health
and safety requir€!11eI1ts. Appli-
cable occupational standards
include 29 C.F.R. Ch. 1910
(industry standards): 29
C.F .R. Ch. 1926 (safety and
health standards) ~ N.H. RSA
Ch. 277-A (Worker I s Right-to-
Knew Act): N.H. Mnin. Rules
He-P Ch. 1800, Part 1803
('T'Oxic Substances in the Work-
place) .
This provision establishes
general facility design stand-
ard? to prevent release of
hazardous cansti tuents.
He-P 1905.08(d)(1)(f) incor-
porates federal RrnA require-
JOOnts for landfills, supple-
mented by additional state
standards set forth in He-P
1905.08(f)(2)(d). He-P 1905.08
(f) (2)(d) requires a danonstra-
tion that landfill disposal is
the only practical way to dispose
of wastes, and a description of
how the facility will meet
specified design requirements.
-13-
ACTION 'IQ DE TAKW 'IQ ATTAIN MAR
Plans for the facility would be required
to incorporate these design standards to
control releases of hazardous constitu-
ents.
~
Disposal by landfill in the State
of New Hampshire must be
-deared to be the only practical way to
dispose of hazardous wastes,. after
assessing all available waste management
alternatives and must meet all other
standards set forth in
1~-P1905.08(d)(1)(f). Hewever, this
alternative does not involve on-site
disposal of hazardous waste, and these
standards would not be applicable unless
hazardous waste such as spent activated
Cilrbon is designated for in-state
]<1nd£ill disposal-.
()
-------
II. ACl'ION-SPOCIFIC
APPLICABLE OR REI.EVANJ' r ") APPROPRIJ\TE
S'I7\TE ~IREMEN'I'Su TINKHAM Gl\RA.GE SI'l I.oNOONDffiHY, NEW HAMPSHIRE
:)
S'l7\'I'E ~UIREMENT
RB;)UlREMENr SYNOPSIS
AC'l'ION TO J3E TAKEN 'ro ATI'AIN ARM
o.
J\dditional
Technical
Standards for
Treatment
HE-P 1905.08
(f)(2)(a)
p.
He-P 1905.08(f)
( 2 )( c), Storage.
Standards.
q.
Technical
Standards for
Waste Piles,
He-P 1905.08(f)(1)
(d), incorporating
by reference
40 C.F.R. 264
. Subpart L.
He-P 1905.08(f)(2)(a)
requires a demonstration
that proposed treatment methods
will meet specified design and
construction requirenents.
'!his provision sets:forth
specified design and construction
requrements for facilities which
store hazardous wastes.
'!his provision incorporates
federal 'RrnA requirements for
waste piles.
-14-
A treatment facility must demonstrate
that the technology will be effective,
will include autanatic controls to stop
inflON in any continuous flew process,
will control toxic gases or fumes, and
will meet other design requirements of
this provision.
'llie storage of hazardous wastes, ground-
water treatment residuals, and contamin~
ated soils must minimize any danger to
hl.DT\an health or environment, must
include mechanisms to prevent and detect
releases to the environment, and must
otherwise comply with design standards
set forth in this provision. This
provision, as well as those set forth
in paragraph q. through v. below, will
be applicable to spent activated carbon
and other treatment residuals when
stored, transported or recycled.
...
Waste pi les must be operated in
-------
II. ACTION-SPECIFIC.
APP,LICABLE OR REI.E.Vmr AND l\PPROPRIATE
STATE ~~IREMENTS, TINKHAM C,J\RJ\GE SI'J'E, I.ONIXJNDEI{}~Y, NEW H1\MPSHIRE
S~'ATE RBJU~
. .
r.
Technical stan-
dards for Use and
Managanent of
Containers, He-P
1905.08(f) (1) (a),
incorporating by
reference 40 C.F.R~
264, Subpart I.
s.
Technical
Standards for
Tanks,
He-P 1905.08
(f)(l)(b),
Incorporating
by Reference
40 C.F.R. 264,
Subpart J.
t.
Standards for
Generators,
He-P 1905.06.
u. .
Manifesting
Requiranents
He-P 1905.04.
. . .
~I~ SYN:)PSJS
This provision incorporates
federal RrnA requirarents for
facilities that store containers
of hazardous waste.
'lhis provision incorporates
federal RCRA requirements for
. fClcilities using tanks to .
treat or store hazardous wastes.
. This provision establishes
requirements awlicable to
generators, including persons.
transporting hazardous wastes or
treatment residues off-site.
. 1
'l11e tr~sport of any hazardous
wastes off-site must comply
with the manifesting and rec6rd-
keeping requirements set forth
in this provision.
-15-
ACTION 'IU B~. TAKEN 'TO A'ITAIN. ARM
The design and managanent of hazardous
waste containers must comply with this
provision.
. The design and maintenance of tanks must
catt>ly with this provi sion, and the
facility must implement regular tank
inspection and maintenance in ccmpliance
with these requirements.
}\ facility generating wastes for.
transport offsite must comply with these
requiranents, including the performance
of hazardous waste determinations and
the maintenance of records regarding
facility activities.
Shiprents of hazardous wastes, including
t.reatment residuals, fran the site for
further treatment or disposal must be
properly manifested and handled in
accordance with this provision.
Q
-------
t:
II. J\C'rION:-SPOCIFIC
APPLICABLE OR m~.Er' 'AND APffiOPRIA'l'E
S,-A'J'E ~IREMENI'S,. TINKHAM ~E. ..-<-'J'E, IONL'(JNDm,RY, NEW HAMPSHIRE
S'l'}\TE REQUIREMENI'
. .. . ... - .
v.
Packaging and
labelling
Requirements,
He-P 1905.05,
incorporating by
reference N.H.
J\dmin. Code
Saf-C-600 and
49 C.F.R. SS
172, 173, 178,
. and 179.
B.
SOLID WASTE ~~
1.
RSA C'l1~ 149-M, New
Hampshire Solid'
Waste Management
Act; N.H. Mmin.
Code He-P Ch. 1901.
~IRF.MJ'Nl' SVOOPSIS
Hazardous wastes transported
off-site must be packaged and
labelled in accordance with
New Hampshire Department
of Safety rules and federal
transportation requirements.
These provisions establish
standards applicable to the .
treabnent, storage, and disposal
of solid waste and the closure of
solid waste facilities.
C. ACTIPN-SPECIFIC ~ E}1ISSION LIMI'l'S
1.
N.H. 1v:IDdn.
Cede Air Parts
604 through 606.
2.
Fugi ti ve Dust
Emission Control
N.H. Mnin. Code
Air Part 1002.
These provisions establish.
limits for the emission of air
pollutants. See discussion at
Section I,D. above.
This provision requires.
precautions to prevent, abate
and cOntrol fugitive dust during
specified activities including
construction, excavation, ana
bulk hauling. See N.H. Mlnin.
Code Air 1002.0~
-16-
ACT,ION TO. 13E Tl\I
-------
I;I. ACTION-SPOCIFI~
APPLICN3I.E OR JlliLEVANf AND APPROPR.IJ\TE
STATE: ~IREMENTS, TINKHAM GARAGE SrI'F., IDNIX)NDffiRY.,. NEW. HAMPSHIRE
S:l'A'm REWJREMn.n'
. . .
REQUIREfw1E]ifI' SYOOPSIS
. .
. .
. . .. .'
D. Jl,CTION-SPEC;IFI(: ~~. .PRcrncrION. LIMI'l'S
1.
RSA 149:8,111;
N.H. MninCede
Ws Ch. 410
These provisions establish
criteria for groundwater
protection. See discussion
at Section 1,A:" al'OVe.
E. ACTION-SP~I~I~ ~~~ WATrn PRQTEX:TION ~"l\NDJ\1U)S
1.
RSA Ch. 149,
N.H. Mmin. Code
Ch. Ws 430
These provisions establish
criteria for surface water
protection. See discussion at
Section I, B above.
These provisions establish
standards for discharges to .
publicly a.med sewage treatment
facilities.
F. N. H. SJ\FE PRINKDX; ~'n~ ACT
2.
RSA 149:4-a;
N.H.. Mnin Code
Ws Ch. 900, part
904, Pretreatment
Standards for
Publicly Owned .
Treatment Works
(roIW) .
1.
RSA Ch. 148-B;
N.H. klmir}. Cede
Ws Part 300
These prCNisions establish state
drinking water standards and
govern the location and operation
of public water systems.
-17-
. .
ACTION ro BE TAKm ro A'ITAIN ARAR
. . .
Ranedia1 alternative must eliminate
. discharges to groundwater which do not
CClTply with these standards.
Ranedial a1 ternati ve must eliminate the
discharge to surface water of
contaminants, treated effluents
or treated groundwater which does not
carp1y with these standards.
The discharge of treated groundwater
or other effluent to any PCYIW must
crnp1y with these standards.
."
Remedial alternatives involving the
establishment of alternative public
drinking water supplies must CClTp1y with
these standards.
.
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APPENDIX D
state of New Hampshire Declaration
of Concurrence
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Statt' of New Hampshire
DEI'AHn,U:NT OF EN\'lHONME~T..\L SERVICES
W-\STE 1\ I.-\.\" AG E!\I ENT IH\'ISION
6 Hazen Drive. Concord. NH 03301-6509
603-271-2900
SOLID \\:.I,STE COUr;CIL
(; Iik:\IH.t-:\ t(;0011
WIlIIAIN~ SANII~II
1'. nlWIl ~:I(;H~IY. 1''' II.
ALL-...., H. HO\\:-\IW. P.E.
"'U~I~II""IIIM:II
MICHAEL A. SILLS, Ph.D.. P.E.
"'HI~:F'EN(;a/lO~;~;1I
January 13, 198t
Mr. Merrill Hohman
Waste Management Division
USEPA
JFK Federal Building
Boston, MA' 02203
Re:
Amended Record of Decision (ROO) (December 1988)
Tinkham's Garage Site
'Londonderry, NH
Dear Mr. Hohman:
The New Hampsh ire Depa rtment of Envi ronmenta 1 Servi ces has revi ewed the
above referenced amended Record-oF-Decision (ROD) ~nd is in agreement with the
ecommended amendment. The recommended a 1 ternat i ve to uti 1 i ze vacuum
extraction for soil source remediation is consistent with the rules and
regulations of applicable or relevant and appropriate state standards
(ARARs). Because all the ROO activities at the Tinkham Site' will now be
completed by the Potentially Responsible Parties (PRP's) under an enforcement
lead with EPA, no further State matches will be necessary.
Sincerely,
~M~
John A. Minichiello,
Di rector /
~~~~~
Alden H. Howard,
Corrmissioner
JAM/AHH/jd/02900
cc: Michael A. Sills, Ph.
Carl W. Baxter, P.E.,
G. Dana Bisbee, Esq.,
Gregory Roscoe. EPA -
D., P.L,
DES-WMD
NHAGO
Region I
DES-WMO
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