United States
Environmental Protection
Agency
Office of
Emergency and
Remedial Response
EPA/ROD/R01 -90/047
June 1990
Superfund
Record of Decision;
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w
50272-101
.::>
REPORT DOCUMENTATION 11. REPORT NO. I ~ 3. RecIpient'. ACC888Ion No.
PAGE EPA/ROD/R01-90/047
4. TlUe.nd SubtiUe 5. Report Date
SUPERFUND RECORD OF DECISION 06/28/90
Coakley Landfill, NH
6.
First Remedial Action
7. Author(a) 8. Perfonnlng Organization Rapt. No.
II. Perfonnlng Orgalnlzlltion Name and Add.... 10. ProjectlTuklWoril Unit No.
11. Contrac1(C) or Grant(G) No.
(C)
(G)
1~ Sponaorlng OrganlutJon Name and Addte.. 13. Type 0' Report . Period Covered
U.S. Environmental Protection Agency 800/000
401 M Street, S.W.
Washington, D.C. 20460 14.
15. Supplementary Note.
16. Abatract (Limit: 200 word.)
The 92-acre Coakley Landfill site is in the towns of Greenland and North Hampton,
Rockingham County, New Hampshire. The site includes a 27-acre landfill, and borders
farmland, undeveloped woodlands, and wetlands to the north and west and commercial and
residential properties to the east and south. A drainage bounds the southern and
western sides of the landfill, channeling surface water runoff into wetlands north of
he landfill. Sand and gravel operations were conducted from 1968 to 1972 during which
eime rock quarrying and landfill operations also were conducted. From 1972 to 1985, the
landfill primarily accepted refuse from Pease Air Force Base and neighboring
municipalities and later accepted incinerator residue from the refuse-to-energy plant
operated at Pease Air Force Base. Much of the refuse disposed of at the landfill was
placed in open trenches created by the rock quarrying and sand and gravel operations.
In 1979, the State received complaints concerning leachate breakouts in the area and, by
1983 VOC-contamination had been identified in a domestic drinking water well.
Subsequent testing confirmed VOC-contamination in the ground water and public water was
extended to area residents and business who had previously received water from private
wells. This Record of Decision (ROD), the first of two operable units, addresses source
control and ground water contamination near the landfill. A subsequent ROD will address
(See Attached Sheet)
17. Document Analy.l. L Deacrlptora
Record of Decision - Coakley Landfill, NH
First Remedial Action
Contaminated Media: soil, sediment, gw
Key Contaminants: VOCs (benzene, PCE), other organics (phenols), metals (arsenic,
chromium)
b. Identifier./Open-Ended Tenna
c. COSA TI Reid/Group
.~ AvailablUty Statement 111. SeC\8'lty Cia.. (TIt1. Report) 21. No. of Pall"
None 263
I 20. SecurIty Cia.. (TIt1. Page) n Price
NonA
N .Z311.18 &HI/natrucfjOfUl on ReWfN 71
(See A 51
(Formerty NT1~)
Dep8rtment 0' Co-ce
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EPA/ROD/ROl-90/047
Coakley Landfill, NH
First Remedial Action
~stract (Continued)
Q
offsite ground water contamination should it be determined that a contaminated plume
underlying wetlands to the north of the site requires remediation. The primary
contaminants of concern affecting the soil, sediment, and ground water below the surface
of the landfill are VOCs including benzene and PCE; other organics including phenols; and
metals including arsenic and chromium.
u
The selected remedial action for this site includes excavating and consolidating
approximately 2,000 cubic yards of wetlands sediment and 30,000 cubic yards of solid
waste and depositing the material into the landfill prior to capping; collecting and
treating landfill gases using a thermal destruction process; ground water pumping and
treatment using chemical precipitation for metals removal, air stripping for VOC removal,
and biological treatment, if necessary, prior to recharge into the aquifer or discharge
to onsite surface water; treating air from the air stripper using incineration or
activated carbon filtration prior to release to the atmosphere; implementing site access
restrictions; and long-term environmental monitoring including air and ground water
monitoring. The estimated present worth cost for the remedial action is $20,200,000
which includes an annual O&M cost of $245,000 for 30 years.
PERFORMANCE STANDARDS OR GOALS: Soil cleanup levels were established to measure
contaminant levels in the sediment remaining in the wetlands following excavation and
will protect the aquifer from potential soil leachate. Soil cleanup values are based on
the Organic Leaching Model and incorporates SDWA MCLs/MCLGs and State standards.
Chemical-specific soil cleanup goals include benzene 0.055 mg/kg (MCL), PCE 0.13 mg/kg
State), and phenol 2.3 mg/kg (State). Ground water cleanup goals will meet SDWA
_.CLs/MCLGs, State standards, and health advisories and include benzene 5 ug/l (MCL), PCE
3.5 ug/l (State), arsenic 50 ug/l (MCL), phenol 280 ug/l (health advisory), and chromium
50 ug/l (MCL). In the absence of a chemical-specific cleanup standard, cleanup levels
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;' ft 'i
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UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
REGION I
J.F. KENNEDY FEDERAL 8UILPING, BOSTON, MASSACHUSETTS 02203-2211
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The remedial measures for the first OU described in this ROD will
protect the drinking water aquifer by minimizing further migration
of contami nants to the groundwater and surface water, and wi 11
eliminate threats posed by direct contact with or ingestion of
contaminated soils and wastes at the Site.
The major components of the selected remedy include:
Consolidation of the solid waste;
Consolidation of sediment in wetlands;
Capping of the landfill;
Collection and treatment of landfill gases;
Groundwater extraction and treatment;
Long-term environmental monitoring; and
Institutional controls where possible.
DECLARATION
The selected remedy is protective of human health and the
environment, attains Federal and State requirements that are
applicable or relevant and appropriate for this remedial action
and is cost-effective. This remedy satisfies the statutory
preference for remedies that utilize treatment as a principal
element to reduce the toxicity, mobility, or volume of hazardous
substances. In addition, this remedy utilizes permanent solutions
and alternative treatment technologies to the maximum extent
practicable.
As this remedy will result in hazardous substances remaining onsite
above health-based levels, a review will be conducted within five
years after commencement of remedi a 1 action to ensure that the
remedy continues to provide adequate protection of human health and
the environment.
~r 1110
~&
1e Belaga "r
Regional Administrator
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C.
D.
The Selected Remedial Action is Cost-Effective
The Selected Remedy utilizes Permanent Solutions and
Alternative Treatment or Resource Recovery
Technologies to the Maximum Extent Practicable
45
46
E.
The selected Remedy satisfies the Preference for Treatment
Which Permanently and Significantly Reduces the Toxicity,
Mobility or Volume of the Hazardous Substances as a Principal
Element. . . . . . . . . . . . . . . . . . . . . . . . 47
XIII. STATE ROLE
. . . .
. . . . .
. . . .
. . .
. . .
. . .
48
APPENDIX A - FIGURES
APPENDIX B - TABLES
APPENDIX C - RESPONSIVENESS SUMMARY
APPENDIX D - STATE OF NEW HAMPSHIRE CONCURRENCE LETTER
APPENDIX E - ADMINSTRATIVE RECORD INDEX
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ROD DECISION SUMMARY
"
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surface. The landfill has moderately steep slopes along its
western, eastern, and southern sides, and a gentle slope along the
northern side.
Fine, sandy soil of variable thickness covers most of the landfill,
and vegetative cover is essentially nonexistent. Along the top of
the northern and western slopes, incinerator residue is visible in
banks where wind and water action apparently removed the sand
cover. A drainage bounds the southern and western sides of the
landfill, channeling surface water runoff into a wetland area
situated immediately to the north-northwest of the landfill. The
wetland area generally extends from the northwest corner of the
landfill area, along both sides of the B&M Railroad, to a point
approximately 500 feet south of Breakfast Hill Road, The margins
of the wetlands adjacent to the landfill have been partially filled
with rock removed from the quarry and some native sand and ~ravel.
Wetlands west of the railroad track drain both the north and the
south. The landfill is located on a subregional drainage divide
and contributes runoff in a generally radial pattern into the
watersheds of four nearby streams west of the site: Little River,
Berry's Brook, North Brook, and Bailey Brook (Appendix A, Figure
2) .
Natural resources in the area include the agricultural lands,
woodlands, and wetlands which surround the site. surface water
bodies feed the wetland area. The groundwater is available in
aquifers formed by water saturated portions of sand and gravel
deposits and in fractured bedrock. Sand and gravel deposits are
found throughout the site. Some bedrock outcrops were mined for
crushed aggregate in a quarry operation. It is reasonable to
expect that wetland and stream areas receive some hunting and
fishing activity. This is considered minor recreational use.
There is also occasional use of all-terrain recreational vehicles
on and around the site.
B.
Geologic Characteristics
portions of the landfill site directly on fractured bedrock of the
Rye Formation or on an undetermined thickness of unconsolidated
sediments of the Pleistocene age. Bedrock consists of deformed
igneous and metamorphic metasediments of the Precambrian to
Ordovician Age intruded locally by pegmitites of the Hillsboro
plutonic series.
Onsite drilling and geophysical work indicated the bedrock surface
is irregular. and appears to form a northeast/southwest ridge
beneath the landfill.
Surficial geology in the site vicinity varies from ice contact sand
and gravel deposit on the easterly side of the landfill to marine
sandy silt on the westerly side. Ice contact deposits also appear
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to overlie the marine sediments on the northeastern side of the
landfill.
<)
The overburden materials onsite vary in thickness from three feet
to almost fifty feet and grade from highly permeable sands and
gravels to stiff, low permeability sandy silt.
C.
Hydrogeological Characteristics
The generalized groundwater hydraulics of the Coakley Landfill site
are presented in Appendix A, Figure 3. Both the direction and
magnitude of the hydraulic gradients appears to be similar in the
overburden and bedrock units. In addition, the data suggest that
the overburden is recharging bedrock over the topographic high area
east of the Coakley Landfill, and that bedrock is discharging into
the overburden in the wetlands area.
The primary directions of groundwater flow from the Coakley
Landfill are southwest, west and northwest toward the wetlands.
In the wetlands, an inferred east to west groundwater divide
directly west of the landfill causes groundwater to flow south
toward North Road and presumably north toward Breakfast Hill Road.
Residential and commercial pumping, occurring prior to the
installation of public water supplies, altered the natural
hydraulic system shown in Appendix A, Figure 3. EPA interprets
this pumping to be the primary reason for contaminant migration
south, east, and northeast of the landfill. As of the last round
of water level measurements on September 1987, essentially no
hydraulic gradient was present from the Coakley Landfill toward the
south, east, or northeast, including toward or from the Rye
landfill.
Overburden groundwater flow appears to be radial from the Coakley
Landfill and vertically downward into the bedrock aquifer. Surface
drainage is also multidirectional since the landfill is near the
headwaters of Berry's Brook to the north and the Little River to
the south. Flow within the bedrock aquifer is a function of
interconnected fractures and is affected locally by hydraul ic
gradients induced by bedrock water well usage within the area. At
least one major fracture system positioned in a south/southeast
direction has been documented to interconnect with the coakley
Landfill. This is located in the south/southwest boundary where
substantial recharge to the bedrock aquifer may be occurring.
Groundwater recharge from the overburden to the bedrock aquifer
occurs where overburden water levels are higher in elevation than
those in bedrock and fine grained materials do not prohibit this
recharge. Direct leachate discharge to the bedrock may take place
beneath parts of the landfill, since the refuse is in direct
contact with bedrock in areas where rock quarrying had previously
occurred.
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II.
site HISTORY AND ENFORCEMENT ACTIVITIES
A.
Land Use
In approximately 1965 sand and gravel operations began on the
Coakley property, which had previously consisted of wooded areas
and open fields as evidenced by aerial photographs. These
operations continued into the late 1970s.
Permitting for a landfill began in 1971 when the New Hampshire
Department of Public Health granted the Town of North Hampton a
permit to operate a landfill on the Coakley Site. Early in 1972,
coakley Landfill, Inc. and the Towns of North Hampton and the City
of Portsmouth entered into an agreement which prohibited the
dumping of shop and ordnance waste from Pease Air Forc~. Base,
located in Newington, NH, as well as demolished buildings, junk
autos, machinery, and large tree stumps or butts.
Landfill operations began in 1972, with the southern portion of
the site used for refuse from the municipalities of Portsmouth,
North Hampton, Newington, and New. Castle, along with Pease Air
Force Base. Coincident with landfill operations, rock quarrying
was conducted at the site from approximately 1973 through 1977.
Much of the refuse disposed of at Coakley Landfill was placed in
open (some liquid-filled) trenches created by rock quarrying sand
and gravel mining.
In 1978 and 1979 oil-soaked debris from accidents in Portsmouth
and Newington, was placed in what is known as the Oily Debris Area
in the northern section of the Coakley site (Appendix A, Figure 2) .
The precise volume of this material is unknown.
In 1981, the State of New Hampshire granted the Town of North
Hampton permission to dispose of pesticide waste containers at the
Coakley Landfill Site.
After the City of Portsmouth began operating a refuse-to-energy
plant on leased property at Pease Air Force Base in 1982. From
July 1982 through July 1985, Pease Air Force Base and the
municipalities of Rye, North Hampton, portsmouth, New Castle, and
Derry began transporting their refuse to this plant for
incineration. After that time, the Coakley Landfill generally
accepted only incinerator residue from the new plant. In March
1983, the Bureau of Solid Waste Management ordered an end to the
disposal of u~burned residue at the Coakley Landfill.
Prior to incineration, the New Hampshire Waste Management Division
estimated that approximately 120 tons per day were disposed of at
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the landfill. The daily weight of incinerator residue was
estimated to be approximately 90 tons. A more detailed description
of the site history can be found in the Remedial Investigation
Report at pages 1-6 through 1-10.
B.
Response History
In 1979, the New Hampshire Waste Management Division received a
complaint concerning leachate breakouts in the area. A subsequent
investigation by the Bureau of Solid Waste Management resulted in
the discovery of allegedly empty drums with markings indicative of
cyanide waste.
A second complaint was received in early 1983 by the New Hampshire
Water Supply and Pollution Control Commission (WSPCC) regarding the
water quality from a domestic drinking water well. Testing
revealed the presence of five different VOCs. ..
A subsequent confirmatory sampling beyond these initial wells
detected VOC contamination to the south, southeast, and northeast
of the Coakley Landfill. As a result, the Town of North Hampton
extended public water to Lafayette Terrace in 1983 and to Birch
and North Roads in 1986. Prior to this time, commercial and"
residential water supply came from private wells.
Also in 1983, the Rye Water district completed a water main
extension along Washington Road from the Corner of Lafayette Road
and along Dow Lane. This extension brought the public water supply
into the area due east and southeast of the Rye Landfill. The
WSPCC submitted proposals to the U. S. Environmental Protection
Agency (EPA) in May and October of 1983 recommending that the
Coakley site be included on the National Priority List (NPL). In
December 1983, the Coakley Landfill was listed on the NPL, and
ranked as No. 689.
In July 1985, after additional investigation conducted by the EPA
and the WSPCC, the Coakley Landfill ceased operations. The nearby
Rye Landfill ceased operations in 1987.
A cooperative agreement was signed with the State of New Hampshire
on August 12, 1985 to conduct a Remedial Investigation/Feasibility
Study (RI/FS). The contractor, Roy F. Weston, Inc., completed the
RI and the FS which were released for public comment on October 31,
1988 and March 2, 1990, respectively. The Proposed Plan which
contains EPA's preferred alternative was released with the FS.
c.
Enforcement History
The State of New Hampshire began discussions concerning the site
with Coakley, the owner, and with the municipalities as early as
December, 1983. Information request letters were sent by EPA to
these parties in September and October, 1987. Additional
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information request letters were sent to approximately 300 parties
during 1988.
On February 2, 1990, EPA notified approximately 59 parties who
either owned or operated the facility, generated wastes that were
shipped to the facility, arranged for the disposal of wastes at the
facility, or transported wastes to the facility of their potential
liability with respect to the site. The PRPs formed a steering
committee and initial negotiations are taking place. On March 14,
1990 EPA met with the potential responsible parties (PRPs) to
discuss their potential liability at the site.
Soon after the PRPs were noticed the City of Portsmouth, the Town
of North Hampton and the Town of Newington notified the EPA of
their suspicions that additional parties also dumped at the Coakley
site. These additional 126 parties were informed by letter that
EPA may notice them in the future. Copies of the Proposed Plan was
sent to parties to provide them with an opportunity to comment on
the EPA's Preferred Remedial Alternative.
The PRPs have been active in the remedy selection process for this
Site. The steering committee retained a technical consultant to
review the RIjFS and to evaluate EPA's preferred alternative. The
Coakley Landfill Steering Committee submitted technical comments
to the EPA during the public comment period. Responses to these
comments as well as comments from other members of the public are
summarized in the attached Responsiveness Summary.
III. COMMUNITY RELATIONS
Throughout the site's history, community concern and involvement
has been high. EPA and the State have kept the community and other
interested parties appraised of the Site activities through
informational meetings, fact sheets, press releases and public
meetings.
During January 1986, EPA released a community relations plan which
outlined a program to address community concerns and keep citizens
informed about and involved in activities during remedial
activities. On May 14, 1986, EPA held an informational meeting at
the North Hampton Town Hall, North Hampton, New Hampshire to
describe the plan for the RIjFS. On November 3, 1988, EPA held an
informational meeting at North Hampton Town Hall, North Hampton,
New Hampshire to discuss the results of the Remedial Investigation
(RI) .
On May 10, 1988, EPA made the administrative record available for
public review at EPA's offices in Boston and at the North Hampton
Public Library. Additional materials were added to the
Administrative Record on October 31, 1988 with release of the RI
and on March 2, 1990 with release of the FS and the Proposed Plan.
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Comments on the RI were received from Coakley, the Town of
Newcastle and the City of Portsmouth. EPA published a notice and
brief analysis of the Proposed Plan in Foster's Daily Democrat and
in the Portsmouth Herald on March 9, 1990 and made the plan
available to the public at the North Hampton Public Library.
On March 15, 1990, EPA held an informational meeting at the North
Hampton Elementary School to discuss the results of the Remedial
Investigation and the cleanup alternatives presented in the
Feasibility Study and to present the Agency's Proposed Plan. Also
during this meeting, the Agency answered questions from the public.
From March 16 to May 14, 1990, the Agency held a 60-day public
comment period to accept public comment on the alternatives
presented in the Feasibility Study and the Proposed Plan and on any
other documents previously released to the public. . On April 3,
1990, the Agency held a public meeting at the North Hampton
Elementary School to discuss the Proposed Plan and to accept any
oral comments. A transcript of this meeting and comments from the
general public and from the Coakley Landfill Steering Committee
along with the Agency's response to comments are included in the
attached Responsiveness Summary.
EPA has met with the potentially responsible parties at various.
times during the process to discuss the Site. More specifically,
EPA met with the City of Portsmouth in February, 1988, with several
municipalities involved with the Site in the Fall of 1989, and with
the Coakley Landfill Steering Committee chairs in April, 1990.
IV.
SCOPE AND ROLE OF THE RESPONSE ACTION
The selected remedy is the first operable unit of at least a two
operable unit approach to the remediation of the Site and provides
for the remediation of the source at the Coakley Site including the
contaminated groundwater beneath and in the vicinity of the
landfill (i.e., source control). The second operable unit will
address any groundwater contamination which has migrated from the
landfill and beyond the property boundary (Le., management of
migration). During this phase additional studies will be
undertaken to better characterize the nature and extent of this
offsite groundwater contamination and to develop and evaluate
alternatives for remediation should it be required. The presence
of a plume of low level contamination currently exists in the
bedrock under the wetlands beyond the property boundary to the west
of the site. An environmental assessment will be performed at that
time.
This first operable unit will address the following principal
threats to human health and the environment posed by the site:
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1.
The offsite migration of contaminants;
2.
The future ingestion of contaminated groundwater offsi te;
and
3.
The direct contact with contaminated soils, sediments
and solid waste.
v.
SITE CHARACTERISTICS
Chapter 1. 0 of the "Draft Feasibility Study, Coakley Landfill",
May 1989, contains an overview of the Remedial Investigation (RI).
The study area, as defined in the RI, includes the land from about
1,600 feet to the south of North Road to about 1,600 feet nQrth of
Breakfast Hill Road and about 4,000 feet to the east and west of
Lafayette Road. This study area is sUbstantially larger than the
Coakley Landfill Site itself in order to evaluate the extent of
the contaminant migration. The significant findings of the RI are
summarized below. Also shown is a summary of the hazardous
substances found at the Site which are subject to Superfund
remedial actions. A complete discussion of Site characteristics
can be found in the Remedial Investigation Report at pages 7-1
through 7-44.
A.
Air
Qualitative outdoor air sampling done at the Site detected low
concentrations of some volatile organic compounds (VOCs). Observed
concentrations ranged from 'not detected' to 48 parts per billion
(ppb or ug/L). Also, data obtained from another survey instrument,
an AID Model 580 organic vapor meter, during the initial Site
walkover of the RI did not indicate VOCs above the background level
that was set approximately 1/2 mile from the Site.
In 1986, the WSPCC conducted indoor air monitoring of three homes
at Lafayette Terrace. Several VOC's were detected, but the
concentrations were typical of those found in residential
dwellings. Nevertheless, the concentrations of VOCs ranged from
below measurable limits up to approximately 22 ppb. These results
are below the outdoor air VOc concentrations at the landfill
perimeter.
B.
Soil
In soils below the surface,of the ~andfill, laboratory and field
analyses found VOCs, pesticides, metals and acid and base/neutral
extractable compounds (ABNs), above detection limits. Soil samples
were screened from nine test pits located at the landfill (Appendix
A, Figure 4). Specific detected VOC's include tetrachloroethylene,
ethylbenzene, acetone, chloromethane, and dichloromethane. Total
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VOCs in the samples from the nine test pits ranged from minimal
detection to 178 ppb. Phenanthrene, anthracene, flouroanthrene,
benzo(a)anthracene, chrysene, benzo(k)-floranthrene,
benzo(a)pyrene, fluorene, naphthalene, 4-methylphenol, and various
phthalates were among the ABNs detected in several of the test pit
samples, particularly at test pits TP-11 and TP-18. Pesticide
compounds identified above their detection limits included 4,4'-
DDD and 4,4 '-DDT. No PCBs were observed at levels above the
dp.t:p.~t;on limits of the instruments used. Arsenic, cadmium, lead,
mercury, iron, manganese, and zinc were among the trace metals that
exceeded background levels at various test pits within the
landfill.
Twelve (12) soil borings were sampled and screened for VOC's in
and around the landfill. The highest concentration was observed
in GZ-106 which was bored in the landfill with a total VOC
concentration of 17 ppm. The VOC' s observed incl ude:
tetrahydrofuran, benzene, methyl ethyl 'ketone (MEK) , toluene,
xylenes and chlorobenzene.
The principal route of offsite migration of these contaminants is
from soil leaching into the groundwater. Because soils were
sampled below the surface, migration from volatilization of
chemical compounds and from wind and water erosion is unlikely.
c.
Sediments
Sediment samples were obtained for quantitative chemical analyses
at nine sampling points (Appendix A, Figure 5). Laboratory and
field analyses performed were VOCs, pesticides/pcb, metals and acid
and base/neutral extractable compounds (ABNs). Sediments with
detectable limits of contaminants were observed within the Little
River wetlands, and within the Berry's Brook wetland and at a
location downstream in Berry's Brook.
The highest measured total VOC concentration in a surface sediment
sample was located in the wetlands immediately .adjacent to the
northwest corner of the site which is considered part of Berry's
Brook wetland. Leachate breakout and eroded soils from the
temporary cap of the landfill can be seen at this location. The
predominant VOC's detected were acetone (300 ppb), ethylbenzene
(240 ppb), xylene (140 ppb), and chlorobenzene (89 ppb). The total
ABN concentration within this sediment sample was less than 123
ppb. The metals detected at this location included arsenic (46
ppm), chromium (57 ppm) and nickel (33 ppm).
D.
Surface Water
Two rounds of surface water samples were taken at eight sampling
station locations during the RI (Appendix A, Figure 5). Laboratory
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and field analyses were performed for VOCs, pesticides/PBCs, metals
and acid and base/neutral extractable compounds (ABN's).
Surface waters sampled in the vicinity of the Coakley Landfill
indicated the presence of VOCs and elevated levels of metals.
Overall, VOCs were detected in surface water samples at two of the
eight locations, namely S-10 (Berry's Brook at Breakfast Hill Road)
and S-ll (Berry's Brook, at the northwest corner of the Site).
These VOCs, also detected in the landfill leachate, consist of six
VOCs: toluene, MEK, MIBK, diethyl ether, tetrahydrofuran, and
acetone.
The highest total VOC concentrations were observed in Berry's
Brook, immediately northwest of the Coakley Landfill (sample
location S-ll), where total VOCs in the range of 459 ppb were
detected. Data from the March 1987 sampling round indicate that
tetrahydrofuran was detected at S-10 and S-ll at concentrations of
12 ppb and about 50 ppb, respectively. Data from the 1984 sampling
round indicate that toluene, acetone, tetrahydrofuran, MEK and MIBK
were detected at S-10 and S-]l at less than 10 ppb and 29 ppb, 89
ppb and 185 ppb, 11 ppb and 31 ppb, 130 ppb and 176 ppb, and 10 ppb
and 19 ppb, respectively.
Southwest of Coakley Landfill, surface water samples obtained from
the Little River (sample location S-l) by New Hampshire Department
of Environmental Services (NH DES) in 1983 also indicated the
presence of six VOCs consisting of toluene, acetone,
trichloromethane, trichloroethylene, tetrachloroethylene, and
tetrachloroethane, with a maximum observed total VOC concentration
of 102 ppb.
Numerous metals at or above anticipated background levels were
detected in samples obtained at stations S-10 and S-ll. Elevated
levels of aluminum were detected in a sample obtained from station
S-16 located approximately 4,000 feet downstream of station S-10.
The metal contaminants detected include iron, aluminum, barium,
manganese and potassium. Measured maximum level of these
contaminants are 100 ppm, 2.1 ppm, 0.23 ppm, 29.7 ppm and 25 ppm,
respectively. Inorganic parameters included: iron (100 ppm) ,
manganese (5.8 ppm) , COD (40.6 ppm) and chloride (185 ppm). Since
aluminum concentrations were high at stations located at headwaters
of Little River (5-7 and 5-17), these elevated levels could be from
naturally high aluminum levels or an alternate source.
E.
Groundwater
Observed Contaminants in the Overburden HVdroaeoloaical Unit
Groundwater samples were obtained from 23 overburden monitoring
wells in the study area (Appendix A, Figure 6). Concentrations of
tQtal VOCs detected in seven monitoring wells located within and
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along the border of the Coakley Landfill ranged from 600 ppb (MW-
1, MW-2) to 10,000 ppb (MW-3D). commonly observed VOCs detected
in these overburden wells and the observed concentration ranges
detected were as follows:
COMPOUND
benzene
ethyl benzene
(:'hlorobenzene
toluene
acetone
methyl ethyl ketone
methyl isobutyl ketone
tetrahydrofuran
diethyl ether
1,1-dichloroethane
1,2-dichloroethane
1,2-dichloropropane
trans-1,2-dichloroethylene
CONCENTRATION lPPB)
6-60.6
18-499
less than 5-182
21-1200
14-2800
17-2700
11-1130
16-1650
12-198.8
7.3-20.8
less than 5-72
30
11-16
Metals detected in these same seven overburden wells and their
detected concentration ranges are presented below.
COMPOUND
aluminum
barium
chromium
iron
manganese
nickel
potassium
sodium
arsenic
vanadium
CONCENTRATION
152-337 ppb
243-368 ppb
330 ppb
21,000-280,000 ppb
2,620-27,000 ppb
122-200 ppb
16,000-480,000 ppb
1,000,000-1,460,000 ppb
10-89 ppb
23-45 ppb
Observed contaminants in the Bedrock Hvdroqeoloqical Unit
Groundwater samples were obtained from 37 bedrock monitoring and
bedrock domestic wells within the study area. Bedrock monitoring
wells are those installed outside of the landfill itself by EPA and
the state of New Hampshire. Bedrock domestic wells are also
located offsite and are either current or past commercial and
residential drinking water sources. Highest measured total VOC
concentrations within the bedrock wells were detected in samples
obtained from MW-5, MW-6 around the southern perimeter of the
landfill and in GZ-105 located approximately 800 feet offsite in
a westerly direction. Maximum total VOC concentrations were less
than 2,400 ppb, 97 ppb and less than 807 ppb, respectively.
Individual compounds comprising the bulk of the observed
constituents in both the monitoring and domestic bedrock wells and
the observed concentration ranges detected were as follows:
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COMPOUND
benzene
chloroethane
toluene
diethyl ether
methyl ethyl ketone
methyl isobutyl ketone
tetrahydrofuran
acetone
xylene
ethyl benzene
1,1-dichloroethane
CONCENTRATION
5.2-12.8 ppb
294 ppb
125-1,340 ppb
180-350 ppb
170-407 ppb
85-96 ppb
238-715 ppb
16-437 ppb
21-87 ppb
less than 34 ppb
7-47 ppb
VOCs were detected in bedrock domestic wells located offsite to the
southeast at Lafayette Terrace (R-25, R-26 and R-28). Observed
total VOCs concentrations ranged from none detected (R-28) to less
than 1,445 ppb (R-25). Observed compounds in these wells were
similar to those observed within the offsite bedrock wells.
Metals detected in the bedrock monitoring and domestic wells
located throughout the study area of the Coakley Landfill and the
observed concentration ranges detected were as follows:
COMPOUND
aluminum
barium
iron
manganese
nickel
potassium
sodium
arsenic
vanadium
CONCENTRATION
119-200 ppb
12-269 ppb
14-140,000 ppb
100-120,000 ppb
8-65 ppb
2500-190,000 ppb
15,000-720,000 ppb
5-9.6 ppb
5-49 ppb
Monitorinq Reports Previous to the RI
Groundwater samples collected prior to the RI from onsite
monitoring wells in bedrock, overburden and from offsite
residential drinking water supply wells indicated the presence of
VOCs and are reported in the New Hampshire Water Supply and
Pollution control commission (NHWS&PCC), "Hydrogeological
Investigation of the Coakley Landfill site". Ten VOCs were
frequently detected in onsite and offsite wells, (toluene, MEK,
diethyl ether, tetrahydrofuran, xylenes, ethylbenzene,
dichlorobenzene, benzene, 1,1-dichloroethane and 1,2-
dichloroethylene).
F.
summary of contamination and Affected Media
Samples of surface water, stream sediment, soil, groundwater and
air were obtained from the study area for evaluation of possible
chemical contamination. Five basic types of chemical analyses were
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performed on samples from various environmental media (excluding
air). These analyses included methods for the detection of VOCs
ABNs, metals, PCBs and pesticides and analyses for several other
parameters considered to be indicators of landfill leachate.
In general, VOCs and metals were observed to be the predominant
contaminants in the study area. The highest contaminant
concentrations were typically detected within samples obtained from
t~~t pits; surface water/sediment stations, and monitoring wells
located within the Coakley Landfill or irl the portion of the Little
River and Berry's Brook wetlands immediately west of the landfill.
Analyses of environmental samples obtained elsewhere in the study
area typically indicated significantly diminished contaminant
levels.
Hydrogeological and water quality data indicate that contaminated
groundwater has migrated radially from the Coakley Landfill in both
overburden and bedrock hydrogeologic units. Although contaminants
detected within samples obtained in the site study area include
VOCs, ABNs, PCBs, metals and inorganic: VOCs and metals were
generally observed with the greatest frequency and distribution.
In general, VOCs are fairly mobile in groundwater and can expect
to be transported in the natural flow of the overburden and bedrock
groundwater. Although metals are usually considered fairly
immobile they can become dissolved in the groundwater especially
where bio-chemical changes in waste materials produce gross changes
in groundwater geochemistry. Therefore, metal constituents in the
groundwater beneath the site can be transported with the natural
flow of the overburden and bedrock groundwater.
Currently, the majority of this groundwater contamination is
localized under the landfill in the overburden and bedrock
hydrogeolog ical uni ts. However, prior to the introduction of
public water, significant levels of contaminants, particularly
VOC's, were found in the private water supply wells in the vicinity
of the coakley Landfill and particularly in the Lafayette Terrace
area. This suggests that if the pumping wells for private water
supply were reintroduced into this area, contaminants would once
again be drawn out from under the landfill, potentially exceeding
safe drinking water standards.
Although numerous contaminants were identified throughout the
landfill, no areas were identified which could be considered "hot
spots" (areas of high concentrations of contaminants) where special
source control measures could be warranted.
VI.
SUMMARY OF SITE RISKS
A risk assessment (RA) was performed to estimate the probability
and magnitude of potential adverse human health effects from
13
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exposure to contaminants associated with the site. The public
health risk assessment followed a four step process: 1)
contaminant identification, which identified those hazardous
substances which, given the specifics of the site, were of
significant concern; 2) exposure assessment, which identified
actual or potential exposure pathways, characterized the
potentially exposed populations, and determined the extent of
possible exposure; 3) toxicity assessment, which considered the
types and magnitude of adverse human effects associated wi th
exposure to hazardous substances, and 4) risk characterization,
which integrated the three earlier steps to summarize the potential
and actual risks posed by hazardous substances at the Site,
including carcinogenic and noncarcinogenic risks. The results of
the public health risk assessment for the Coakley Landfill site are
discussed below.
Seventeen contaminants of concern, listed in Appendix B, Tables 1
through 5, were selected for evaluation in the RA. These
contaminants constitute a representative subset of the more than
thirty-two contaminants identified at the site during the Remedial
Investigation. As shown in these tables, the seventeen
contaminants of concern were selected to represent potential site-
related hazards based on toxicity, concentration, frequency of
detection, and mobility and persistence in the environment. A
summary of the health effects of each of the contaminants of
concern can be found in section 8, Pages 8-1 to 8-18 of the Risk
Assessment.
Potential human health effects associated with exposure to the
contaminants of concern were estimated quantitatively through the
development of several hypothetical exposure pathways. These
pathways were developed to reflect the potential for exposure to
hazardous substances based on the present uses, potential future
uses, and location of the Site. The following is a brief summary
of the exposure pathways evaluated. A thorough discussion of
exposure pathways and parameters can be found in Section 7.3 and
8.3 of the Risk Assessment. For incidental ingestion and direct
contact of contaminated soil, the health risk was evaluated for a
child between the ages of five and 18 years old who may be exposed
to contaminated soils ten times per year for 14 years. For
ingestion of groundwater used as a drinking water supply, the
health risk was evaluated for an adult who may consume two liters
per day for seventy years. For incidental ingestion and dermal
absorption of surface water, the health risk was evaluated for a
child between the ages of five and 18 years old who may accidently
ingest or bathe in contaminated surface water once each year. For
incidental ingestion and dermal absorption of sediments, the health
risk was evaluated for a child between the ages of five and 18
years old who may accidently ingest or cover his or her self in
contaminated sediment once a year. For each pathway evaluated, an
exposure estimate was generated corresponding to exposure to the
average concentration detected in that particular medium.
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Excess lifetime cancer risks were determined for each exposure
pathway by multiplying the exposure level with the chemical
specific cancer potency factor. Cancer potency factors have been
developed by EPA from epidemiological or animal studies to reflect
a conservative "upper bound" of the risk posed by potentially
carcinogenic compounds. That is, the true risk is very unlikely
to be greater than the risk predicted. . The resulting risk
estimates are expressed in scientific notation as a probability
(e.g. 1 x 10.6 for 1/1,000,000) and indicate (using this example),
that an individual is not likely to have greater than a one in a
million chance of developing cancer over 70 years as a result of
site-related exposure as defined to the compound at the stated
concentration. Current EPA practice considers carcinogenic risks
to be cumulative when assessing exposure to a mixture.of hazardous
substances.
The hazard index was also calculated for each pathway as EPA IS
measure of. the potential for noncarcinogenic health effects. The
hazard index is calculated by dividing the exposure level by the
reference dose (RfD) or other suitable benchmark for noncarcino-
genic health effects. Reference doses have been developed by EPA
to protect sensitive individuals over the course of a lifetime.
They reflect a daily exposure level that is likely to be without
an appreciable risk of an adverse health effect. RfDs are derived
from epidemiological or animal studies and incorporate uncertainty
factors to help ensure that adverse health effects will not occur.
The hazard index is often expressed as a single value (e.g. 0.3)
indicating the ratio of the stated exposure as defined to the
reference dose value (for this example of 0.3, the exposure as
characterized is approximately one third of an acceptable exposure
level for the given compound). The hazard index is only considered
cumulative for compounds that have the same or similar toxic
endpoints (the hazard index for a compound known to produce liver
damage should not be added to a second whose toxic endpoint is
kidney damage).
Table 6 below, depicts the cumulative risk summary for the
carcinogenic and non-carcinogenic contaminants of concern for each
exposure pathways analyzed. For a more detailed analysis on the
risk for each contaminant of concern, see Tables 79 through 87 of
the Remedial Investigation.
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TABLE 6
CUMULATIVE CARCINOGENIC RISK ESTIMATES
AND CUMULATIVE HAZARD INDICES BY EXPOSURE PATHWAY
EXDosure Pathway
Cumulative I
Excess Lifetime I
Cancer Risk I
Maximum: Averaae:
Cumulative
. Hazard
:Index
Maximum: Averaae
Incidental Ingestion of Soils 9x10'9 8x10.s
Direct Contact (DC) with Soils 4x10.7 3x10.3
Ingestion of Groundwater (GW) 1x10.3 2x10.4 2X10'1 5X10.2
Ingestion of GW 1x10.4 1x10'1
- Well 43
Ingestion of GW 5x10'4 2x10.6
- Lafayette Terrace
DC with Surface Water (SW) 5x10-9 7X10.s
Incidental Ingestion of SW 3xlO'10 2x10-4
DC with Sediment 4X10.8 2x10.1
Incidental Ingestion of Sediment 4x10'9 6x10'4
Cumulative potential cancer risks associated with incidental
ingestion and direct contact with onsite soils, surface water, and
sediments did not exceed EPA's target cancer risk range of 10'4 to
10'6. Similarly, cumulative hazard indices as a measure of the
potential for. non-carcinogenic effects for each of the above
exposure pathways did not exceed unity (1.0).
Potential risks associated with the ingestion of groundwater as a
drinking water supply were estimated based on data from
overburden/bedrock monitoring wells and domestic wells at Lafayette
-------
Terrace and domestic well No. 43. These wells were located within
the same hydrogeologic regime (i.e., between the same groundwater
divides). The cumulative excess lifetime cancer risk predicted for
the consumption of groundwater moving from overburden and bedrock
monitoring wells exceeded EPA I S target risk range of 10.4 to 10.6.
The principle contribution to these risk estimates was posed by
arsenic whose maximum concentration 89 ug/L exceeded the Maximum
contaminant Levels of the Safe Drinking Water Act (MCLs) of 50
ug/L. A~~enic was also the major contributor to possible cancer
risks for the ingestion of groundwater from monitoring wells in the
vicinity of well 43 and monitoring wells in the vicinity of
Lafayette Terrace. Predicted cancer risk for consumption of
groundwater from monitoring wells in the vicinity of Lafayette
Terrace also exceeded the 10.4 to 10.6 cancer risk range.
The cumulative hazard indices for each of the groundwater pathways
evaluated were less than one indicating that the potential for non-
cancer health effects resulting from exposure to contaminants in
groundwater is unlikely.
Risks from the air pathway of
observed contaminant levels
.occupational threshold limit
continuous exposure.
exposure were not quantified because
were found to be less than the
value (TLV) adjusted to account for
Based on the findings in the Base Line Risk Assessment, EPA has
concluded that the risks posed by the ingestion of groundwater
exceed the acceptable risk range 10.4 to 10.6. The principle
contribution to the carcinogenic groundwater risk was posed by
arsenic. In addition, maximum concentrations of the following
compounds exceed their respective MCLs, state drinking water
standards or health advisories: arsenic, benzene, chlorobenzene,
chromium, 1,2-dichloroethylene, nickel, 2-butanone, and
tetrachloroethylene. Consequently, the cleanup at the Coakley
Landfill site will be based on protection of the groundwater beyond
the compliance boundary as a future drinking water supply. Actual
or threatened releases of hazardous substances in groundwater from
this Site, if not addressed by implementing the response action
selected in this ROD, may present an imminent and substantial
endangerment to public health or welfare or the environment.
VII. DOCUMENTATION OF NO SIGNIFICANT CHANGES
EPA presented a Proposed Plan (preferred alternative) for
remediation of the site on March 2, 1990. The source control
preferred alternative included:
1.
2.
3.
4.
Consolidation of sediments in the wetlands;
Consolidation of solid waste;
capping of the landfill;
Collection and treatment of landfill gases;
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5.
6.
7.
Groundwater extraction and treatment;
Long-term environmental monitoring; and
Institutional controls where possible.
No significant changes from the Proposed Plan briefly described
above have been made to the selected remedy as detailed in the
Record of Decision. However, at the time of the issuance of the
Proposed Plan, EPA had not specifically identified the construction
of a fence around the Site. The chain link fence was identified
as part of the remedy in the FS and the costs associated were
included in the cost estimate in the FS and Proposed Plan.
The cleanup level for arsenic has been revised to 50 ug/L from 30
ug/L to reflect consistency with MCLs set forth in the Safe
Drinking Water Act. This revision remains protective of human
health and the environment and does not impact the selection of the
remedy. The groundwater extraction and treatment component'. of the
remedy remains necessary since levels of arsenic detected at the
compliance boundary exceed 50 ug/L.
As stated in the Proposed Plan, the preferred alternative does not
include any action involving remediation of the oily debris area
identified at the Site (Appendix A, Figure 2). However, costs for
remediating this debris were included in the total cost for each
alternative in both the Feasibility Study and the Proposed Plan.
These amounts have been deducted in this ROD. For alternatives SC-
3 and SC-4, the total cost remains the same after rounding the
figures. For SC-5 the cost is reduced by $800,000; for SC-6 the
cost is reduced by $500,000. Given the overall cost of each
alternative, these amounts were insignificant to the remedy
selection process.
The fOllowing is presented as a point of clarification. In the
Proposed Plan EPA identified approximately 2000 cubic yards of
"contaminated" sediments located in the wetlands adjacent to the
northwest side of the landfill. The RI identified an area of
wetlands adjacent to the northwest corner of the Site as needing
remediation due to landfill operations and landfill temporary cap
erosion, which caused subsequent filling and sedimentation in the
wetlands. Sediments in the wetland, estimated to be approximately
2,000 cubic yards, would need to be excavated and redeposited in
the existing landfill area to restore the wetlands to its
beneficial use.
Although results from a sediment sample taken during the RI did not
exceed the cleanup level discussed above, this action is justified
on the basis of restoring the wetlands which were filled as a
result of the landfill operation and temporary cap erosion. During
excavation and restoration, appropriate steps will be taken such
as using clean and appropriate fill and installing silt barriers
to prevent damage to the wetlands downstream of the work area.
Sediment samples will be taken in and around the perimeter of the
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excavated area to confirm that the remaining sediments in the
wetland are below cleanup levels. To promote wetland revegetation,
soils similar to those of the natural wetlands will be used, and
sedges and other species will be planted.
VIII. DEVELOPMENT AND SCREENING OF ALTERNATIVES
A.
Statutory Requirements/Response Objectives
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 Comprehensive Environmental Response, Compensation,.
and Liability Act of 1980, (as amended by Superfupd and
Reauthorization Act of 1986) (CERCLA) establishes several other
statutory requirements and preferences, including: a requirement
that EPA's remedial action, when complete, must comply with all
federal and more stringer.t state environmental standards,
requirements, criteria or limitations, unless a 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 technologies to the
maximum extent practicable; and a preference for remedies in which
treatment which permanently and significantly reduces the volume,
toxicity or mobility of the hazardous substances is a principal
element over remedies not involving such treatment. Response
alternatives were developed to be consistent with these
Congressional mandates.
Based on preliminary information relating to types of contaminants,
environmental media of concern, prior and potential use as a
drinking water source and potential exposure pathways, remedial
action objectives were developed to aid in the development and
screening of alternatives. These remedial action objectives were
developed to mitigate existing and future potential threats to
public health and the environment. These response objectives were:
1. Prevent ingestion of groundwater containing contamination
in excess of Federal and State drinking water standards or
criteria, or that poses a threat to public health and the
environment.
2. Prevent the public from direct contact with contaminated
soils, sediments, solid waste and surface water which may
present a health risk.
3. Eliminate or minimize the migration of contaminants from
the soil into groundwater.
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4. Prevent the offsite migration of contaminants above levels
protective of public health and the environment.
5. Restore groundwater, surface water, soils and sediments to
the levels which are protective of the. public health and the
environment.
B.
Technology and Alternative Development and Screening
CERCLA and the National Oil and Hazardous Substances Pollution
Contingency Plan (NCP) set forth the process by which remedial
actions are evaluated and selected. In accordance with these
requirements, a range of alternatives was developed for the Site.
with respect to source control, which includes the groundwater
under the landfill, the RIfFS developed a range of alternatives in
which treatment that reduces the toxicity, mobility, or volume of
the hazardous substances is a principal element. This range
included an alternative that removes or destroys hazardous.
substances to the maximum extent feasible, eliminating or
minimizing to the degree possible the need for long term
management. This range also included alternatives that treat the
principal threats posed by the Site but vary in the degree of
treatment employed and the quantities and characteristics of the
treatment residuals and untreated waste that must be managed;
alternative(s) that involve little or no treatment but provide
protection through engineering or institutional controls; and a no
action alternative.
Section 2 of the Feasibility Study (FS) identified, assessed and
screened technologies based on implementability, effectiveness, and
cost. These technologies were combined into source control (SC)
and management of migration (MM) alternatives. Section 3 of the
FS presented the remedial alternatives developed by combining the
technologies identified in the previous screening process in the
categories identified in Section 300.430(e) (3) of the NCP. The
purpose of the initial screening was to narrow the number of
potential remedial actions for further detailed analysis while
preserving a range of options. Each alternative was then evaluated
and screened in Section 4 of the FS.
In summary, of the approximately 17 source control remedial
alternatives screened in Section 2, five were retained for detailed
analysis. Figure 3-1 in Section 3 of the Feasibility Study
identifies the five alternatives that were retained through the
screening process, as well as those that were eliminated from
further consideration. Management of migration alternatives,
although evaluated in the FS, will be reevaluated pending further
studies of offsite groundwater migration.
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IX.
DESCRIPTION OF ALTERNATIVES
This section presents a narrative summary of each alternative
evaluated. A detailed tabular assessment of each alternative can
be found in Table 3-1 in section 3 of the Feasibility Study.
A.
S~urc~ Control (SC) Alternatives Analyzed
The source control alternatives analyzed for the Site include the
following alternatives:
SC-l:
No-action Alternative;
SC-3:
Capping Including
Treatment) ;
Consolidation
(No
Groul}dwater
SC-4:
Capping/onsite Groundwater Treatment;
SC-5:
Capping/onsite Groundwater Pretreatment and Offsite
Treatment and Disposal; and
SC-6:
onsi te Sol id Waste/Groundwater
Disposal/Capping.
Treatment
and
SC-l
No-Action
This alternative is included in the Feasibility Study (FS), as
required by CERCLA, to serve as a basis for comparison with the
other source control alternatives being considered.
This source control alternative would involve no remedial action
on the contaminated soil, sol id waste or groundwater. However, the
no-action alternative would entail some activity in order to
provide minimal protection of human health and the environment.
A chain-link fence would be installed around the landfill area to
prevent all non-authorized personnel from entering the Site.
Institutional controls would be established in order to restrict
future land use. The landfill would be loamed and seeded to
control dust and erosion from wind and rain. A long term
monitoring program would be instituted that would involve periodic
collection of air, surface water and groundwater samples to
evaluate potential exposure routes.
This alternative does not meet any identified ARARs, particularly
since MCLs are already exceeded at the site.
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ESTIMATED
ESTIMATED
ESTIMATED
ESTIMATED
ESTIMATED
TIME FOR DESIGN AND CONSTRUCTION:
TIME FOR OPERATION:
CAPITAL COST:
OPERATION AND MAINTENANCE (PRESENT WORTH):
TOTAL COST (PRESENT WORTH):
2 months
30 years
$ 820,000
$ 1,300,000
$ 2,120,000
SC-3
Cappinq Includinq Consolidation
This alternative involves consolidating approximately 2000 cubic
yards of eroded sediment in the wetland under a new multi-layer
cap to be installed on the landfill. Additionally, approximately
30,000 cubic yards of material from the east, west and south sides
of the landfill would be excavated to reduce the area nee4ing to
be covered by the cap (Appendix A, Figures 7 and 8). The excavated
material would then be mixed with sand as needed and used in the
cap construction. Emissions created by excavation will be
minimized by wetting down the soil with water or foam. Air
monitoring will ensure compliance with emission standards.
The multi-layer cap system will be constructed over the landfill
and will include a vegetative layer, a drainage layer and
impermeable barrier (low permeability barrier of clay or synthetic
liner material). The cap will reduce the potential for direct
contact with the contaminated materials onsite and will control
further migration of contaminants by reducing precipitation could
filtering through and away from the Site. This cap will conform
wi th state and RCRA sol id waste requirements. A typical cap
construction diagram can be found as Appendix A, Figure 9. A
chain-link fence would be installed around the landfill area to
prevent access to all non-authorized personnel. A gas collection
and treatment system would also be installed to collect the gases
coming off the landfill. These gases would be treated onsite by
a thermal destruction process such as incineration. A long term
monitoring program would be instituted involving periodic
collection of air, surface water and groundwater samples to
evaluate potential exposure routes.
Because this alternative does not include a groundwater treatment
system, it will not meet MCLs and other groundwater standards.
ESTIMATED TIME FOR DESIGN AND CONSTRUCTION:
ESTIMATED TIME FOR OPERATION:
ESTIMATED CAPITAL COSTS:
ESTIMATED OPERATION AND MAINTENANCE (PRESENT WORTH):
ESTIMATED TOTAL COST (NET PRESENT WORTH):
9 Months
30 Years
$ 8,800,000
$ 2,400,000
$ 11,200,000
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SC-4
CaDDinq/Onsite Groundwater Treatment
This alternative involves consolidation of the solid waste followed
by capping the landfill and extracting and treating onsite
groundwater. The treated groundwater would either be recharged
into the aquifer and/or discharged to onsite surface water.
RecnArgA trenches will be installed to alleviate draining the
wetlands. The cap Tj;'ould be similar to the one described in
alternative SC-3. This alternative would also be similar to SC-
3 in that it includes fencing, excavating 30,000 cubic yards of
material from the landfill, 2,000 cubic yards from the wetlands and
installing a gas collection and treatment system.
The groundwater extraction system would consist of several
overburden and bedrock wells located along the southern and eastern
perimeters of the landfill and a drainage system around the
perimeter of the landfill. Recharge trenches will be located on
the toe of the slope on the northwest and westerly edges of the
landfill adjacent to the wetlands. Groundwater would be treated
onsite to remove metals, VOCs and biological oxygen demand (BOD)
and ammonia through a series of technologies involving chemical,
physical and biological processes to comply with federal and state
drinking water and discharge standards. The exact treatment will
be determined during the design phase after additional studies.
A conceptual treatment process diagram is shown in Appendix A,
Figure 10. The processes are summarized below.
-Chemical process:
Metals removed by adding lime or
caustic to form a sludge for offsite
disposal
-Physical process:
VOCs removed by air stripping. Off-
gases removed by incineration or
activated carbon filtration.
-Biological process:
BOD, ammonia and remaining VOCs
removed by rotating biological
contactors (RBC) or activated carbon
filtration to. meet discharge
requirements.
A long term monitoring program would be instituted involving
periodic collection of air, surface water and groundwater samples
to evaluate potential exposure routes.
ESTIMATED TIME
ESTIMATED TIME
FOR DESIGN AND CONSTRUCTION: 2 years
FOR OPERATIONS: 10 vears groundwater extraction
and treatment: 30 vears for cap
maintenance and monitoring.
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ESTIMATED CAPITAL COST:
ESTIMATED OPERATION AND MAINTENANCE (PRESENT WORTH) :
ESTIMATED TOTAL COST (NET PRESENT WORTH):
$ 12,800,000
$ 7,400,000
$ 20,200,000
SC-5
Cappinq/Onsite Groundwater Pretreatment and Offsite Treatment and
Disposal
This alternative involves capping of the landfill and groundwat~r
collection followed by onsite pretreatment and offsite disposal.
Fencing, capping and groundwater collection would be accomplished
as described in alternatives SC-3 and SC-4.
Groundwater would be pumped to publicly owned treatment works
(POTW). Onsite pretreatment would occur to meet mu~icipal
requirements. Subsequent treatment would occur at the municipal
plant in the Town of Hampton. The extent of pretreatment could
include metals removal by precipitation and/or VOC removal by air
stripping as discussed for the previous alternative (SC-4). To
implement offsite treatment and disposal of groundwater, a pumping
station and a new sewer main extending along u.S. Route 1 to just
south of the Hampton-North Hampton town line would be constructed.
A long term monitoring program would be instituted involving
periodic collection of air, surface water and groundwater samples
to evaluate potential exposure routes.
ESTIMATED TIME FOR DESIGN AND
ESTIMATED TIME FOR OPERATION:
CONSTRUCTION: 2 Years
10 Years for groundwater extraction;
30 years for cap maintenance and
monitoring.
ESTIMATED CAPITAL COST:
ESTIMATED OPERATION AND MAINTENANCE (PRESENT WORTH)
ESTIMATED TOTAL COST
$ 13,200,000
$ 5,700,000
$ 18,900,000
SC-6
Onsite Solid Waste/Groundwater Treatment and Disposal/Capping
This alternative involves excavation of the entire landfill and
treatment of contaminated wastes and solids by incineration and/or
solidification. Emissions created by the extensive excavation will
be minimized by wetting down the soil with water or foam. Fencing,
regrading and capping of the landfill area as in alternative SC-
3, as well as collection and. treatment of the groundwater
underlying the Site as in alternative SC-4 would also be required.
Samples of soils and solid waste in the landfill would be collected
and analyzed to determine which areas should be removed for
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solidification and/or incineration to achieve the desired cleanup
goals. Material containing high levels of organic compounds would
be incinerated onsi te through the use of a mobile incinerator.
Emissions would be directly monitored to evaluate incinerator
performance.
Material containing high levels of metals, which could include the
incinerator ash, would be solidified and placed back into the
landfill along with the materials that meet cleanup goals.
Solidification of metals would be achieved by mixing the waste with
a lime or concrete based material that sets into an easily handled
solid product with reduced permeability. Incinerator ash
containing metals at levels that could leach into the groundwater
would also be solidified and placed in the landfill.
A long term monitoring program would be instituted involving
periodic collection of air, surface water and groundwater samples
to evaluate potential exposure routes.
ESTIMATED CAPITAL COST:
ESTIMATED OPERATION AND MAINTENANCE (PRESENT WORTH)
ESTIMATED TOTAL COST (NET PRESENT WORTH)
CONSTRUCTION: 2-Years
Solid waste excavation and treatment,
20 months; groundwater, 10 years; cap
maintenance and monitoring, 30 years. .
$ 45,300,000
$ 8,600,000
$ 53,900,000
ESTIMATED TIME FOR DESIGN AND
ESTIMATED TIME FOR OPERATION:
B.
Management of Migration (MM) Alternatives
.The Feasibility Study (FS) analyzed management of migration
alternatives to cleanup the contaminants that migrated offsite.
However, EPA believes that insufficient data exist to properly
characterize the extent and chemical makeup of the offsite
groundwater. Additionally, since the plume is primarily in or
under a major wetland, the implementation of a conventional
groundwater extraction system would be extremely difficult, very
.costly and could result in extensive and irreversible damage to the
wetland. The existence of a contaminant plume in the bedrock
aquifer will further complicate any cleanup effort for the offsite
.ground.
As part of the implementation of the source control. remedy, EPA
proposes to expand the offsite groundwater monitoring system and
undertake an investigation to better characterize the nature and
extent of contamination in the offsite groundwater. The
investigation will also include an evaluation of possible
remediation technologies and their impact on the wetlands. An
environmental assessment will also be performed. EPA will design
the onsite remedy to capture as much as practicable of the
contamination that has already migrated from the landfill.
-------
The expanded monitoring program, which includes monitoring
residential wells in the Coakley Landfill area, and the groundwater
investigation of the offsite contamination will be one of the first
actions taken as part of the Coakley Landfill remediation. The
investigation will continue until sufficient data is obtained for
EPA to make a decision regarding the remediation of offsi te
groundwater. That decision will be incorporated in a second Record
of Decision (ROD). .
Installing a well-designed source control remedy at the present
time will minimize offsi te migration of contaminants.
Accordingly, a less extensive management of migration remedy will
be necessary in the future. An effective source control remedy
will result in lower costs and less time to achieve offsite
groundwater cleanup goals.
x.
SUMMARY OF THE COMPARATIVE ANALYSIS OF ALTERNATIVES
section 121 (b) (1) of CERCLA presents several factors that at a
minimum EPA is required to consider in its assessment of
alternatives. Building upon these specific statutory mandates,
the NCP articulates nine evaluation criteria to be used in
assessing the individual remedial alternatives.
A detailed analysis was performed on the five alternatives using
the nine evaluation criteria in order to select a site remedy.
The following is a summary of the comparison of each alternative's
strength and weakness with respect to the nine evaluation criteria.
These criteria and their definitions are as follows:
. '
Threshold Criteria
An alternative must meet the two threshold criteria described below
in order to be eligible for selection in accordance with the NCP.
1. Overall protection of human health and the environment
addresses whether or not a remedy provides adequate protection
and describes how risks posed through each pathway are
eliminated, reduced or controlled through treatment,
engineering controls, or institutional controls.
2. compliance with Applicable or relevant and appropriate
requirements (ARARS) addresses whether or not a remedy meets
all ARARs or other Federal and state environmental laws and/or
provides grounds for invoking a waiver.
Primary Balancina criteria
The following five criteria are used to
elements of alternatives which have met the
each other.
compare and evaluate
threshold criteria to
-------
3. Long-term effectiveness and permanence refers to the
ability of a remedy to maintain reliable protection of human
health and the environment over time, once clean-up goals have
been met.
4. Reduction of toxicity, mobility, or volume through
treatment addresses the degree to which alternatives employ
recycling or treatment that reduces toxicity, mobility, or
volume including how treatment is used to address the
principal threats posed by the site.
5. Short term effectiveness addresses the period of time
needed to achieve protection and any adverse impacts on human
health and the environment that may be posed during the
construction and implementation period, until clean-up goals
are achieved.
6. Implementability addresses the technical and
administrative feasibility of a remedy, including the
availability of materials and services needed to implement a
particular option.
7. Cost includes estimated capital and operation
maintenance (O&M) costs, as well as present-worth costs.
&
Modifvina criteria
The mOdifying criteria are factored into the final balancing of
remedial alternatives. This generally occurs after EPA has
received public comment on the RI/FS and Proposed Plan.
8. state acceptance addresses the state's position and key
concerns related to the preferred alternative and other
alternatives; and the state's comments on ARARs or the
proposed use of waivers.
9. Community acceptance addresses public general response
to the alternatives described in the proposed Plan and RIFS
report.
A detailed tabular assessment of the nine criteria applied to each
alternative can be found in section 4 in Tables 4-2 to 4-6 of the
Feasibility Study.
Following the detailed analysis of each individual alternative, a
comparative analysis, focusing on the relative performance of each
alternative against the nine criteria, was conducted. This
comparative analysis can be found in Table 4-12 of the Feasibility
study.
The following section balances the strengths and weaknesses of the
five alternatives under each of the nine criteria set out above.-
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1.
Overall Drotection of ht~man health and the environment
Alternatives SC-4, SC-5 and SC-6 use technologies that will be
protective of human health and the environment by reducing
contamination. These technologies include capping, gas collection
and groundwater treatment. Alternative SC-1 is not protective
since it anticipates no action onsite. Alternative SC-3 is not
protective because it does not incorporate groundwater treatment,
only gas collection and treatment and capping.
The combined capping and gas and groundwater treatment components
of SC-4, SC-5 and SC-6 would treat already contaminated groundwater
to federal and state drinking water standards at the Site
compliance boundary. Further, downward and offsite.migration of
contaminants in the groundwater caused by precipitation and soil
leachate would be controlled. Dust erosion, surface runoff and
direct contact with contaminated soils, wastes and sediments would
also be minimized by capping, removing and consolidating the
sediments in the wetland into the landfill and fencing the landfill
area.
.Capping and gas treatment alone, without a groundwater treatment
system as in SC-3, would allow contaminants to continue to migrate
downward into the groundwater and offsite. Containment alone is
normally used as a remedy at sites which have naturally occurring
clay or till layers under the groundwater flow zone which act as
a cap under the Site to contain this downward migration. The
Coakley Landfill Site has no clay or till under the groundwater
flow zone; rather the Landfill is situated on bedrock. Without
groundwater treatment, SC-3 will not meet MCLs at the Site
compliance boundary.' Similarly, alternative SC-1 will not meet
MCLs at the Site boundary.
2.
ComDliance with ARARS
Each alternative was evaluated for compliance with ARARs, including
chemical-specific, action-specific and location specific ARARs.
These alternative specific ARARs are presented in Appendix B,
Tables 7 through 16. Alternatives SC-4 and SC-6 meet their
respective ARARs. SC-5 may not meet Executive Order 11990
(Protection of Wetlands) because of the negative impact groundwater
pumping and offsite treatment may have on the wetlands. SC-4 has
less impact on the wetlands in that treated groundwater is
recharged to the aquifers or discharged directly to surface water.
SC-1 and SC-3 do not attain the following applicable federal and
'The Site compliance boundary is described in Section XI. A.
1 at page 33.
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state ARARs for groundwater: Safe Drinking Water Act (SDWA), WS 410
NH Groundwater Quality Criteria, WS 300 NH Drinking Water
Standards, and Federal Ambient Water Quality criteria.
3.
Lonq term effectiveness and Dermanence
Alternative SC-6 offers the greatest degree of long-term
effectiveness and permanence. This alternative provides for onsite
ir.cir.c:::,~ti::m and/or solidification of contaminated soil and wastes,
onsite extraction and treatment of contaminated groundwater and
capping of the landfill. Incineration and/or solidification
destroys and/or immobilizes the source of contamination and meets
cleanup goals for VOCs and metals. However, should subsurface
conditions change significantly, metals bound into the
solidification matrix may again become mobile and ba released to
the groundwater.
Alternative SC-4 and SC-S also provide for long-term effectiveness
and permanence in that they include capping and groundwater
treatment. Capping will meet RCRA closure requirement~; however,
the design life of a cap is subj ect to some uncertainty. While cap
replacement in the future is possible, proper installation and
maintenance will extend the cap's life significantly. A long-term
monitoring program, such as the programs included in SC-4, SC-S and
SC-6, would provide sufficient warning of a potential cap failure.
Although SC-4 and SC-5 do not provide for direct treatment of the
soils and wastes, the waste material under the cap should degrade
naturally, over time, to levels which no longer pose a threat to
public health and the environment.
Groundwater treatment will meet cleanup goals at the site
compliance boundary as long as the cap integrity is maintained.
Capping and removing the groundwater from the site as required by
SC-4, SC-S and SC-6 are most effective in minimizing the potential
for further migration of contaminated groundwater. Since SC-3 does
not include groundwater extraction and treatment, only the long-
term effectiveness and permanence associated with capping would
apply to this alternative. contaminated groundwater would continue
to migrate offsite for a significant period of time. Alternatives
SC-l, is the No-Action Alternative, and as such provides very
little, if any, long-term effectiveness and permanence.
4.
Reduction of toxicitv. mobility. or volume throuqh treatment
Alternatives SC-4, SC-S, and SC-6 provide for some reduction of
toxicity, mobility or volume through treatment. SC-6 provides for
the most reduction of toxicity, mobility and volume in soil and in
groundwater through incineration and/or solidification of
contaminated soil and waste, extraction and treatment of
contaminated groundwater under the site, and collection and
treatment of gases generated in the landfill.
-------
Alternatives SC-4 and SC-5, although they do not include
incineration/solidification, will also reduce toxicity, mobility,
and volume of contaminants through groundwater extraction and
treatment. capping, which alternatives SC-3, SC-4, SC-5 and SC-
6 incorporate to varying extents; reduces only mobility of the soil
contaminants and does not involve treatment. The cap will limit
infiltration of precipitation and control leaching of soil
contamination into the groundwater. However, capping without
groundwater treatment as in SC-3, does not reduce toxicity and
volume of contaminants.
Alternative SC-3 will only reduce contamination associated with the
treatment of the landfill gases. Alternative SC-l provides no
reduction in toxicity, mobility or volume through treatment since
no treatment is included.
5.
Short-term effectiveness
with respect to protection of the community, alternatives SC-4 and
SC-5 pose a slight potential for adverse impact to community health
-from emissions during excavation and consolidation of waste.
material and sediments in the landfill prior to capping. However,
strict engineering controls, wetting the soil and monitoring the
air will be in effect to insure that negative impacts do not occur.
Alternative SC-6 could prolong community exposure to air emissions
because, unlike SC-4 and SC-5, most of the landfill will be
excavated and treated through solidification and/or incineration.
Excavation and treatment of waste and soils for SC-6 will last
approximately 20 months. Excavation and consolidation for SC-4 and
SC-5 will last only three months.' Therefore, in addition to
emissions from the exte..sive excavation, SC-6 may potentially
expose the community to incineration emissions from the wastes as
well as the captured gas emissions. The emissions from the gas
treatment systems of SC-4 and SC-5 are minimal.
Risk to workers during remedial actions in alternatives SC-4 to SC-
6 will be controlled with safe working practices. SC-6 may expose
workers to potential emissions as described above.
with respect to long-term environmental impacts, SC-4 through SC-
6 could potentially release contaminants to the wetlands during
excavation. Removing groundwater from the Site, as required in
SC-5, could temporarily dry up major portions of the wetlands.
While groundwater will also be removed for onsite treatment in SC-
4 and SC-6, impacts to the wetlands will be minimized by recharge
to the aquifer or by discharge to onsite surface water.
For alternatives SC-4, SC-5, and SC-6construction will be
completed in two years; groundwater will meet cleanup levels in 10
year. Alternatives SC-l and SC-3 will not be protective since
migration of contamination is not addressed.
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6.
Implementabilitv
While all of the alternatives can be implemented, some alternatives
are technically easier to implement than others, based on their
design and complexity.
SC-3, capping, would be implementable since the remedy is
technically easy to design and construct. SC-4 capping and onsite
groundwater treatment, is the simplest treatment alternative to
implement. This technology, used on other Superfund sites, is not
difficult to design and construct.
SC-5, capping with offsite groundwater treatment, may be very
difficult to implement since acceptance by a municipal wastewater
treatment facility of partially treated groundwater is required.
Whether a municipality would be willing to accept treated
groundwater is uncertain.
SC-6 would be the most difficult to implement since it involves
extensive excavation of the solid waste and treatment, incineration
and/or solidification, of the solid waste.
The no-action alternative would be difficult to implement
effectively since there is no guarantee that the institutional
controls will be complied with in the future.
Cost
The estimated present worth value of each alternative and the
. options are as follows:
COST COMPARISON OF SOURCE CONTROL ALTERNATIVES
Capital O&M Costs *Present
Costs (S/vr) Worth
SC-1 No Action $ 820,000 43,000 2,120,000
SC-3 capping Including Consol-
idation 8,800,000 80,000 11,200,000
SC-4 capping/Onsite Ground-
water Treatment 12,800,000 245,000 20,200,000
SC-5 Capping/Offsite Treat-
ment and Disposal 13,200,000 190,000 18,900,000
SC-6 Onsite Solid Waste/
Treatment and Disposal/
Capping 45,300,000 285,000 53,900,000
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state acceotance
The New Hampshire Department of Environmental Services (DES) has
been involved with the Site from the beginning as summarized in
Section II of this document .SITE HISTORY AND ENFORCEMENT
ACTIVITIES". The Remedial Investigation and Feasibility Study was
performed as a state lead through a cooperative agreement between
the state and the EPA. The New Hampshire DES and the Attorney
Generals Office have reviewed this document and concur with the
alternative selected for a source control remedy as documented in
the attached Declaration of Concurrence.
Communitv acceotance
The comments received during the public comment period and the
discussions during the Proposed Plan and FS public meeting are
summarized in the attached document entitled "The Responsiveness
Summary" (Appendix C). Varied comments were received from
residents living near the Site, environmental citizen groups, and
from the coakley Landfill steering Committee. The citizens
generally desire the EPA to choose the most stringent remedy, SC-
6, or else excavate and remove onsite waste. The Steering
Committee generally wants the EPA to choose the minimal remedy
which is similar to SC-3.
XI.
THE SELECTED REMEDY
EPA has selected alternative SC-4, CappingjOnsite Groundwater
Treatment, for the first operable unit at the Coakley Landfill
site. Managing offsite migration of contaminated groundwater, the
second operable unit, will be addressed in a later Record of
Decision. A detailed description of the selected remedy along with
cleanup levels is presented below.
A.
Cleanup Levels
Cleanup levels have been established for contaminants of concern
identified in the baseline risk assessment which have been found
to pose an unacceptable risk to public health. Cleanup levels have
been set based on the appropriate ARARs (e.g. Drinking Water MCLGs
and MCLs) if available. In the absence of a chemical specific ARAR
or other suitable criteria to be considered, a 10.6 excess cancer
risk level for carcinogenic effects or a concentration
corresponding to a hazard index of one for compounds with
noncarcinogenic effects was used to set cleanup levels. Periodic
assessments of the protection afforded by remedial actions will be
made as the remedy is being implemented and at the completion of
the remedial action. If the remedial action is not found to be
protective or fails to meet the cleanup levels established in this
Record of Decision, further action shall be required.
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1.
Groundwater
Because the aquifer at and beyond the compliance boundary of the
Site is a potential source of drinking water, it is a Class IIA
aquifer and the MCLs and non-zero MCLGs established under the Safe
Drinking Water Act are ARARs. The compliance boundary established
for groundwater cleanup levels is the perimeter of the site which
runs close to the current property boundary of the coakley Landfill
on the south, west and east sides and approximately 200 feet from
the current toe of the slope of the landfill to the north and
northeast within the site boundary. EPA has no reason to believe
that waste was disposed of beyond the property boundaries of the
Coakley Landfill site. However, the compliance boundary extends
200 feet beyond the edge of the apparent landfill to ensure that
all wastes are incorporated in the remedy since the exact location
of waste disposed of in this north and northeast area has not been
fully documented. This point of compliance is protective of the
public health and the environment in that it minimizes the
possibility of offsite migration of contamination from waste which
may extend beyond the apparent edge of the landfill.
Cleanup levels for known and probable carcinogenic compounds (Class
A & B) have been set at the appropriate MCL or non-zero MCLG.
Cleanup levels for the Class C, D and E compounds (possible
carcinogens not classified and no evidence of carcinogenicity) have
been set at the MCLG. In the absence of a MCLG, a MCL, or a
proposed drinking water standard or other suitable criteria to be
considered (i.e. health advisory, state standard), a cleanup level
was derived for carcinogenic effects based on a 10-6 excess cancer
risk level considering the ingestion of groundwater.
Cleanup levels for compounds in groundwater eXhibiting
noncarcinogenic effects have been set at the MCLG. In the absence
of a MCLG or a proposed drinking water standard or other suitable
criteria to be considered (i.e. health advisory, state standard),
cleanup levels for noncarcinogenic effects have been set at a level
thought to be without appreciable risk of an adverse effect when
exposure occurs over lifetime (hazard index = 1).
Table 12 below summarizes the cleanup levels for carcinogenic and
noncarcinogenic contaminants of concern identified in groundwater.
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TABLE 12: GROUNDWATER CLEANUP LEVELS
Carcinogenic
Contaminants
of Concern
Benzene
Tetrachloroethene
Arsenic
Cleanup
Level (ua/L)
5
3.5
50
Noncarcinogenic
contaminants
of Concern
2-Butanone (MEK)
Phenol
Diethyl phthalate
Chlorobenzene
Trans-1,2-dichloroethene
Chromium
~ickel
Cleanup
Level (ua/L)
200
280
2,800
100
100
50
100
KEY
8
Basis.
MCL
NH
MCL
Risk
Level
7xlO-o
5xl 0-6
2xlo-4.
Bas i s.
HA
HA
HA
pMCLG
pMCLG
MCL
HA
HI
Index
0.1
0.01
0.1
0.1
0.1
0.3
0.1
HA = Health Advisory
NH = NH Drinking Water standard
MCL = Maximum Contaminant Level, Safe Drinking Water Act
pMCLG = Proposed Maximum Contaminant Level Goal, Safe
Drinking Water Act
The cleanup level for arsenic has been set at the MCL of
50 ug/L. The carcinogenic risk posed by arsenic at 50
ug/L in groundwater will approximate 2 in 1,000.
However, in light of recent studies indicating that many
skin tumors arising from oral exposure to arsenic are
non-lethal in nature and in light of the possibility that
the dose-response curve for the skin cancers may be
sublinear (in which case the cancer potency factor used
to generate risk estimates will be overstated), it is
Agency policy to manage these risks downward by as much
as an order of magnitude {x 10).2 As a result, the
carcinogenic risks for arsenic at this site have been
managed as if they were 2 in 10,000.
.
2See EPA memorandum, "Recommended Agency Policy on the
Carcinogenicity Risk Associated with the Ingestion of Inorganic
Arsenic" dated June 21, 1988.
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These cleanup levels must be met at the completion of the remedial
action at the compliance boundary. EPA has estimated that these
levels will be attained within approximately ten years.
The hazard index for the remaining compounds were each
significantly less than 1. Conse~uently, the stated levels should
be without appreciable risk of non-carcinogenic health effects.
When achieved, the stated cleanup levels for these 10 contaminants
shall be protective of public health considering a lifetime of
consumption of 2 liters per day of groundwater. EPA will review
performance data periodically after the remedy is implemented to
insure that the remedy remains protective.
2.
Soil
Cleanup levels for the organic compounds in soils were established
to measure contaminant levels in the remaining sediments in the
wetlands after excavation. These cleanup levels are necessary to
protect human health and the aquifer from potential soil leachate
at the compliance boundary at the Coakley Landfill site. The
remaining sediments in the wetlands will meet these cleanup levels
after excavation. Direct physical contact or the accidental
ingestion of soils was not found to pose a significant health risk.
The Organic Leaching Model (OLM), 51 Fed. Reg. 41082, (1986), was
used to estimate residual soil levels that are not expected to
impair future groundwater quality. ARARs in groundwater (MCLGs
,and MCLs) were used as input into the leaching model. In the
absence of an ARAR, the level corresponding to a 10-6 risk level
(for carcinogens) or a hazard index of one (noncarcinogenic
effects) was utilized. If the values described above were
incapable of being detected or were below regional background
values, then either the detection limit or background values was
substituted. Table 13 below summarizes the soil cleanup values for
the contaminants of concern developed to protect public health and
the aquifer.
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TABLE 13: SOIL CLEANUP LEVELS
FOR THE PROTECTION OF HUMAN HEALTH AND THE AOUIFER BASED
ON THE ORGANIC LEACHING MODEL
carcinoqenic
contaminants
of Concern
Benzene
Tetrachloroethene
Soil
Cleanup
Level (ma/ka)
0.055
0.13
Noncarcinoqenic
Contaminants
of Concern
2-Butanone (MER)
Phenol
Diethyl phthalate
Chlorobenzene
Trans-1,2-dichloroethene
Soil
Cleanup
Level (ma/ka)
0.8
2.3
900
9.4
2.2
KEY
8
Basis for
Model
InDut8
MCL
NH
Residual
Groundwater
Risk
7x10-o-
5xl 0-6
Basis for
Model
InDut8
HA
NH
HA
pMCLG
pMCLG
Residual
Groundwater
Hazard Index
0.1
0.01
0.1
0.1
0.1
HA = Health Advisory
NH = NH Drinking Water standard
MCL = Maximum Contaminant Level, Safe Drinking Water Act
pMCLG = Proposed Maximum contaminant Level Goal, Safe
Drinking Water Act
These cleanup levels for organic constituents in soils are
consistent with ARARs for groundwater and attain EPA's goal for
remedial actions. soils exceeding these levels after testing will
be excavated.
B.
Description of Remedial components
Cappinq/Onsite Groundwater Treatment
Alternative SC-4, Capping/Onsite Groundwater Treatment, involves
consolidating sediments and solid waste followed by capping the
landfill and extracting and treating of onsite groundwater and
landfill gases. Below is a list of the major components of the
remedy:
1.
2.
3.
Consolidation of sediment in the wetlands
Consolidation of solid waste;
capping of the landfill;
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4.
5.
6.
7.
8.
Fencing of the landfill:
Collection and treatment of landfill gases:
Groundwater extraction and treatment:
Long-term environmental monitoring: and
Institutional controls where possible.
Approximately 2,000 cubic yards of sediment in the wetlands
adj~cent to the northwest corner of the site will be excavated and
redeposited into the existing landfill area before the new cap is
installed. During excavation and restoration of the wetlands,
appropriate steps such as using clean and appropriate fill and
installing silt barriers to prevent damage to the wetlands
downstream of the work area will be taken. Sediment samples in and
around the perimeter of the excavated area will also' be taken to
confirm that the remaining sediments are below cleanup levels. To
promote wetland revegetation, soils similar to those of the natural
wetlands will be used, and sedges and other species will be
planted.
In addition, approximately 30,000 cubic yards of material from the
east, west and south sides of the landfill will be excavated to
reduce the area to be capped. This material will be mixed with
sand as needed and used to construct the sub-base layer which lies
below the impermeable layer of the cap to ensure proper grading of
the landfill.
The landfill cap design will be consistent with NH DES and RCRA
closure requirements. At a minimum, the cap would consist of a
mUlti-layer system composed of a vegetative topsoil layer and a
subsurface drainage layer overlying a low-permeability barrier of
clay or synthetic liner material. The details of the materials of
construction and the thickness of the layers will be left to the
remedial design phase. This will give the designers the ability
to incorporate state of the art construction materials and
technology for site specific conditions as required by the EPA.
A typical diagram of cap construction can be found as Appendix A,
Figure 9.
capping also involves collecting and treating landfill gases, such
as methane, generated below the cap. Methane and other decomposing
gases will be vented by means of an active interior gas
collection/recovery system. The gas collection system will consist
of small-diameter PVC pipe placed in a network of shallow trenches
backfilled with crushed stone. The trenches will be located within
the intermediate cover layer below the final cover. The collected
gases will be treated onsite by a thermal destruction process.
Emissions generated by this process will be minimized by using best
available demonstrated technology and by monitoring. The
technology used for this process will be evaluated during the
design phase, which may include treatability studies.
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A 6 foot chain link fence topped with barbed wire will encompass
the landfill area which will be accessible only to authorized
personnel. Approximately 6,000 linear feet of fencing will be
required. Keys to the gates will be available to operators of the
treatment plant and to regulating authorities.
The groundwater extraction system will consist of overburden and
bedrock wells located within and along the perimeter of the
landfill. A drainage system will also be located around the
perimeter (Appendix A, Figure 11). Groundwater will be treated
onsite to remove metals and organics (both VOCs and semi-VOCs)
through a series of technologies involving chemical, physical and
biological processes. The exact treatment will be determined
during the design phase after additional studies, which may include
additional groundwater sampling and pilot and/or treatability work.
The treated groundwater will be recharged into the aquifer or
discharged to onsite surface water during periods of" high
groundwater. Any drying effect on the wetlands will be minimized
by recharging the treated groundwater to the aquifer or discharging
it to onsite surface water.
,A conceptual treatment process diagram is shown as Appendix A,
Figure 10 and described in more detail below. .
Extracted groundwater will first undergo removal of metals. Adding
lime or caustic causes iron, arsenic and other metals to coagulate
and settle into a sludge at the bottom of the tank. The sludge will
be tested and properly disposed of at an appropriate offsite
treatment or disposal facility.
The groundwater is then passed through an air stripping chamber to
remove VOCs by forcing air up through the water. This causes the
organic contaminants to be carried from the water into the air
stream. Since air leaving the stripper will contain small
quantities of VOCs, it will then be treated through incineration
or activated carbon filtration prior to release to the atmosphere.
The combined processes will effectively remove approximately 99
percent of VOCs from the groundwater and air stream.
After treatment the water will be discharged to a series of ten
recharge structures located along the service road west and north
of the landfill whenever feasible. Alternatively, during periods
of high groundwater, some or all of the treated water may need to
be discharged to the surface water. Should this occur, the treated
groundwater will not only meet federal and state drinking water and
discharge standards but also ambient water quality criteria through
additional treatment such as activated carbon filtration or
biological treatment. Biological treatment will effectively remove
BOD and ammonia. Activated carbon filtration may effectively
remove 30D and ammonia.
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Periodic review and modification of the design, construction,
maintenance and operation of the groundwater extraction and
treatment system will be necessary. Performance of the system will
be evaluated annually, or more frequently, to determine if the
goals and standards of the design criteria are being met. If not,
adjustment or modification may be necessary. These adjustments or
modifications may include relocating or adding extraction wells or
altc:::-ing pumping rates. switching from continuous pumping to
pulsed pumping may improve the efficiency of contaminant recovery
and should be evaluated should modification be necessary. Should
new information regarding the extraction and treatment technology
exist, it will be evaluated and applied as appropriate.
After the cleanup levels have been met and the remedy is determined
to be protective, the groundwater system will be shut down. A
groundwater monitoring system will then be utilized to collect
information quarterly for three years to ensure that the cleanup
levels have been met and the remedy is protective. Once these'
levels are maintained and the remedy is protective for this period
of time, an additional monitoring program for the site in
accordance with New Hampshire Hazardous and Solid Waste rules will
be implemented.
To the extent required by law, EPA will review the Site at least
once every five years after the initiation of remedial action at
the site if any hazardous substances, pollutants or contaminants
remain at the site to assure that the remedial action continues to
protect human health and the environment. If after 5 years there
is no progress or, if after 10 years cleanup levels are not
attained, the groundwater remedy shall be reconsidered. EPA will
also evaluate risk posed by the site at the completion of the
remedial action (i.e., before the site is proposed for deletion
from the NPL).
XII. STATUTORY DETERMINATIONS
The remedial action selected for the Coakley Landfill site is
consistent with CERCLA and, to the extant practicable, the NCP.
The selected remedy is protective of human health and the
environment, attains ARARs, and is cost-effective. The selected
remedy also satisfies the statutory preference for treatment which
permanently and significantly reduces the toxicity, mObility or
volume of hazardous, substances as a principal element.
Additionally, the selected remedy utilizes alternative treatment
technologies to the maximum extent practicable.
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A.
The Selected Remedy is Protective of Human. Heal th and the
Environment
The remedy at this site permanently reduces the risks posed to
human health and the environment by reducing and controlling
exposure to human and environmental receptors through treatment,
engineering controls, and institutional controls. More
specifically, capping the landfill will eliminate exposure to
contaminants by direct contact and will control exposure from dust
erosion and surface runoff. Capping will also limit infiltration
of precipitation and control leaching of soil contaminants into the
groundwater. Collecting and treating gas and pumping and treating
the groundwater will control potential exposure to VOCs and semi-
VOCs from the landfill. The selected remedy .will attain
remediation levels set in accordance with heal th-based ~s.
Moreover, the selected remedy will result in human exposure levels
that are below the hazard index of one for noncarcinogens.
Capping the landfill will eliminate further groundwater
contamination from soil leachate. Groundwater and gas treatment
will reduce the toxicity and concentration of contaminants and will
contain contaminants landfill to eliminate contamination of the.
aquifer. Extracting and treating groundwater reduces cancer and
chemical hazard risks. A long-term monitoring program will insure
the remedy remains protective of human health and the environment.
Finally, implementation of the selected remedy will not pose
unacceptable short-term risks or cross-media impacts since the
landfill will only be minimally disturbed during cap construction
and relocating of sediment in the wetland.
B.
The selected Remedy Attains ARARS
This remedy will meet or attain all applicable or relevant and
appropriate federal and state requirements that apply to the site.
Substantive portions of environmental laws identified as ARARs for
the selected remedial action include:
Chemical Specific
New Hampshire Surface Water Quality Standards (Ws 430)
New Hampshire Air Quality Rules (RSA Chapter 12S-C)
Safe Drinking Water Act - Maximum contaminant Levels (SDWA)
Federal Ambient Water Quality criteria
National Ambient Air Quality Standards
New Hampshire Drinking Water Standards
Location Spec1fic
Clean Water Act (CWA)
Fish and wildlife Coordination Act
Executive Order 11990 (protection of Wetlands)
New Hampshire Solid Waste Regulations (He-P 1901)
-------
New Hampshire Wetlands Regulations (Ws 300 and 400)
New Hampshire Hazardous Waste Regulations (He-P 1905)
New Hampshire Hazardous Waste Regulations
Action SDecific
Resource Conservation and Recovery Act (RCRA)'
OSHA General Industry Standards
OSHA ~~f~ty and Health Standards
OSHA Recordkeeping, Reporting and Related Regulations
DOT Rules for Transportation of Hazardous Materials
To Be Considered
New Hampshire Protection
EPA Risk Reference Doses
EPA Carcinogen Assessment
Threshold Limit Values
US EPA Offsite Policy
OSWER Directive 9355.0-28
of Ground Water Regulations .(Ws 410)
Group Potency Factors
1 New Hampshire is a RCRA authorized State Program.
Tables 2-1 through 2-3 in section 2.0 of the FS, lists all ARARs
identified for the Site and whether they are applicable, relevant
and appropriate or to be considered (See Appendix B, Tables 9, and
14 through 18). Appendix F of the FS contains a list of identified
ARARs for all the alternatives. Appendix F also presents a brief
synopsis of the requirements and notes whether or not they will be
attained and what action, if any, is necessary to meet the ARAR
(See Appendix B, Table 9). Any changes to applicability or
appropriateness or relevance are discussed below.
The remedial action involves installing groundwater collection
wells and trenches, constructing a groundwater treatment facility
and placing a multi-layer cap with a gas collection recovery system
incorporated over the source. An onsite thermal destruction unit
.will be constructed to treat the gas. During all construction and
operation activities, OSHA requirements. are applicable.
1.
Chemical SDecific
a.
Federal and State Drinkina Water Standards
The groundwater in the aquifer at and beyond the compliance
boundary of the landfill would be a possible drinking water source
were it not contaminated by leachate from the landfill. Maximum
contaminant Levels (MCLs) promulgated under the Safe Drinking Water
-------
Act which regulate public drinking water supplies, are applicable
to drinking water at the tap and are not applicable to groundwater.
However, because the groundwater may be used as a potential
drinking water source, MCLs are relevant and appropriate.
New Hampshire's Protection of the Groundwater of the state
regulations do not establish grcundwater quality standards, but do
establish groundwater criteria. Included in this criteria is the
requirement that no person shall cause the groundwater to contain
a substance at a level that the state determines may be potentially
harmful to human health or to the environment. Because New
Hampshire's regulations do not contain a standard or level of
control as required by ~ 121(d) (2) (A) (ii) of CERCLA, they will not
be an ARAR. They are, however, to be considered (TBCs) and will
be met. In addition, the state of New Hampshire Department of
Public Health Service consumption advisories for water supplies
have been determined to be considered (TBCs) and were used in
absence of an MCLs in setting Site cleanup levels for: Phenol, 280
ppb and Tetrachloroethene, 3.5 ppb.
This remedy will attain these ARARs by meeting the groundwater
cleanup goals at the compliance boundary through the groundwater
treatment system and by capping the source of contamination.'
Capping will control further leachate of contaminants into the
groundwater from the landfill itself. Treating the groundwater
will reduce levels of contamination at the compliance boundary to
the cleanup goals. Any leachate migrating from the landfill will
not contaminate the groundwater at levels exceeding the ARARs.
Treated groundwater will also meet federal standards and state
criteria for drinking water.
2.
Location SDecific
a.
Federal and State Surface Water Standards
The effluent standards of Title III of the Federal Water Pollution
Control Act, as amended by the Clean Water Act of 1977 (CWA) and
state surface water discharge standards are applicable to the
action since the selected remedy may involve direct discharge to
surface water rather than recharge into the aquifer. The state's
Water Quality Standards establish standards for surface water
quality based on three use classifications. These standards
incorporate by reference the Federal Ambient Water Quality
Criteria. The surface waters in an around the Site are classified
as Class B waters which are acceptable for swimming and other
recreation, fish habitat and, after adequate treatment, use as
water supplies.
Title III, along with Executive Orders 11990 (Protection of
Wetlands) and state wetland standards are applicable to that
portion of the action involving consolidation of 2,000 cubic yards
of sediment in the wetland under the cap. These rules prohibit
-------
activity adversely affecting a wetland if a practicable alternative
which has less affect is available. Consolidating sediment in the
wetland is necessary because soils have eroded from the temporary
cap on the landfill and from landfill operation activities, thereby
damaging portions of the wetlands. Leaving the wetlands in their
present condition fails to restore wetlands to their original
beneficial use and fails to maintain the adjacent wetlands' water
storage capabilities. Removing less than 2,000 cubic yards fails
to capture all of the eroded sediment presently in the wetlands.
Consolidation will be conducted to avoid or minimize the
destruction, loss and degradation of Site wetlands.
After reviewing the Federal Emergency Management Agency, Floodplain
Insurance Rate Maps for Towns of North Hampton, Greenland and Rye,
EPA has determined that the Site is not located in a 100-year
floodplain. Executive Order 11988 (Floodplain Managemept) is
therefore not an ARAR for the coakley Landfill site.
b.
Federal Clean Air Act and New HamDshire Air
Pollution Reaulations
The National Ambient Air Quality Standards promulgated under the
Clean Air Act are relevant and appropriate to the control of
particulate matter during excavation, groundwater treatment and
active gas collection and treatment. The New Hampshire air quality
standards are slightly more stringent than federal regulations and
are therefore applicable to the remedy. Although initial air
sampling offsite indicated airborne VOCs were below threshold limit
values, controls may be necessary to prevent fugitive dust and
chemical emissions during remedial action. The use of Best
Available Control Technology will meet these ARARs.
In addition, EPA guidance on control of air emissions (OSWER
Directive 9355.0-28, June 15, 1989) is to be considered for the
Site, which is in an non-attainment area. For such an area, the
directive indicates the need for control of VOC emissions from
Superfund air strippers and soil vapor extraction systems based
upon actual emission rates of VOCs. Gases generated by air
stripping during the groundwater treatment phase and gases
generated by the landfill will be treated by either a carbon
adsorption unit or a thermal destruction unit.
3.
Action sDecific
a.
Federal Hazardous and Solid Waste Amendments
to the Resource Conservation and Recoverv Act
and New HamDshire Hazardous and Solid Waste
Reaulations
The State of New Hampshire has been authorized by EPA to administer
and enforce RCRA programs in' lieu of the federal authority. The
-------
authorized state hazardous waste regulations are equivalent to or
more stringent than the federal RCRA regulations. Compliance with
New Hampshire's RCRA regulations is discussed below.
Compl iance wi th RCRA depends on whether the wastes are RCRA
hazardous wastes as defined under New Hampshire's RCRA program.
Wastes at the site are similar enough to RCRA waste to make these
regulations appropriate and relevant to this Site.
These standards are appropriate and relevant to the design,
monitoring and performance of the groundwater extraction and
treatment system, which will handle, treat and dispose of hazardous
materials. Closure standards are also appropriate and relevant
to capping of the site. Onsite hazardous and solid wastes will be
managed in accordance with these ARARs, including adequate security
and administrative measures, including inspections, a grou~dwater
monitoring program, a site closure and post closure plan and a
public notification plan. Specifically, this remedy will comply
with the provisions of New Hampshire's Hazardous Waste Management
Act at N.H. Admin. Code He-P Ch. 1905 and of the Solid Waste
Management Act, RSA Ch. 149-M and the Solid Waste Management Rules,
N.H. Admin. Rules He-P Ch. 1901 listed in Appendix B, Tables 17 and
18.
Sludge generated by the groundwater treatment unit will be treated
and/or disposed of at an offsite RCRA facility in accordance with
federal and state requ~rements.
RCRA includes specific provisions restricting the placement of
hazardous waste into a land-based unit, which includes a landfill.
The Land Disposal Restrictions (LDRs) are not ARARs for the
consolidated sediment in the wetland under the cap since this
action does not involve placing hazardous waste in a land-based
unit. The area of contamination at Coakley is comprised of the
southern end of the landfill as well as adjoining wetlands located
at the northwestern part of the site. The sediments in the
wetlands to be consolidated are contiguous to the Site,
uninterrupted by roads, paths, railroad tracks or other easements
or rights of ways. Sediments in the wetland result primarily from
the existing temporary cover which has eroded from the slopes of
the landfill and has filled in the wetland. Given the contiguous
location of the wetlands to the landfill subjecting it to erosion,
the landfill and wetlands constitute one area of contamination for
CERCLA purposes and thus one unit for land disposal purposes.
Therefore, movement of the sediment in the wetland to the landfill
does not qualify as placement but is merely movement within the
unit. .
-------
L
C.
The Selected Remedial Action is Cost-Effective
In the Agency's judgment, the selected remedy, SC-4, is cost
effective, i.e., the remedy affords overall effectiveness
proportional to its costs. Once EPA identified alternatives that
were protective of human health and the environment and that either
attain UL waive ARARs, EPA evaluated the overall effectiveness of
each alternative by assessing the relevant three criteria - long
term effectiveness and permanence; reduction in toxicity, mObility,
and volume through treatment; and short term effectiveness. The
relationship of the overall effectiveness of this remedial
alternative was determined to be proportional to its costs.
A summary of the costs associated with each of the source oontrol
remedies are presented below. All costs are presented in net
present costs.
COST COMPARISON OF SOURCE CONTROL ALTERNATIVES
Capital O&M Costs *Present
Costs (S/vr) Worth
SC-l No Action $ 820,000 43,000 2,120,000
SC-3 Capping Including Consol-
idation 8,800,000 80,000 11,200,000
SC-4 cappingjOnsite Ground-
water Treatment 12,800,000 245,000 20,200,000
SC-5 cappingjOffsite Treat-
ment and Disposal 13,200,000 190,000 18,900,000
SC-6 Onsite Solid Wastej
Treatment and Disposalj
capping 45,300,000 285,000 53,900,000
Of the three alternatives that are protective and attain ARARs, SC-
4, SC-5 and SC-6, EPA's selected remedy, SC-4, combines most cost-
effective remedial alternative components that were evaluated. The
remedy provides a degree of protectiveness proportionate to its
costs. Groundwater extraction and treatment was estimated to be
significantly less costly than incineration and/or solidification
of the landfill waste which would cost approximately 265 percent
more. Two of the less expensive alternatives, SC-1 (no-action)
and SC-3 (capping with consolidation), did not meet ARARs since
contamination above drinking water standards would have been
allowed to migrate offsite. Alternative SC-5, offsite treatment
-------
and disposal, although less expensive but comparable in costs to
SC-4, was found to be more difficult to implement since it involves
a municipal wastewater treatment facility accepting the
groundwater. Additionally, this alternative may have an adverse
impact on the wetlands adjacent to the site due to the removal of
significant amounts of groundwatgr from the area.
A summary of the costs for each of the elements of the selected
remedy are presented below. All cost are net present costs.
TOTAL COSTS OF SELECTED REMEDY
contaminated Media/Remedv CaDital O&M Total
Sediment $ 42,000 0 ..42,000
Capping 5,205,000 953,000 6,158,000
Groundwater 7.523.000 6.447.000 13.970.000
TOTAL 12,770,000 7,390,000 20,160,000
TOTAL ESTIMATED COST:
$ 20,200,000
D.
The Selected Remedy Utilizes Permanent Solutions and
Alternative Treatment or Resource Recovery Technologies to
the Maximum Extent Practicable
Once the Agency identified those alternatives that attain ARARs
and that are protective of human health and the environment, EPA
identified which alternative utilizes permanent solutions and
alternative treatment technologies or resource recovery
technologies to the maximum extent practicable. This determination
was made by deciding which one of the identified alternatives
provides the best balance of trade-offs among alternatives in terms
of: 1) long-term effectiveness and permanence; 2) reduction of
toxicity, mobility or volume through treatment; 3) short-term
effectiveness; 4)implementability; and 5) cost. The balancing test
emphasized long-term effectiveness and permanence and the reduction
of toxicity, mobility and volume through treatment; and considered
the preference for treatment as a principal element, the bias
against offsite land disposal of untreated waste, and community
and state acc:eptance. The selected remedy provides the best
balance of trade-offs among the alternatives.
Alternative SC-4 was selected as the remedy because its
effectiveness and permanence and its ability to reduce
mobility and volume of contaminants through groundwater
was the most efficient of all alternatives in
long-term
toxicity,
treatment
light of
-------
implementability and cost concerns. The principal elements of the
remedy consist of removing contamination from the groundwater under
and around the landfill by collecting and treating the groundwater
through air stripping prior to discharging it back to the ground
or surface water. The air stripping process, along with capping,
is a proven technique which provides a permanent solution for
contaminated groundwater and has been used successfully at other
hazardous waste cleanup sites.
This remedy was also selected over other alternatives because of
its ability to achieve cleanup levels at a lower cost without the
necessity of directly treating solid waste. As explained
previously, there are no identifiable areas of high concentrations
of contaminants onsite; thus there is no need to excavate and treat
particular areas of the landfill. Groundwater treatment will
effectively control migration of contaminants offsite.
Alterative SC-5 is similar to SC-4 in that it is effective in the
long-term and will reduce toxicity, mobility and volume of
contaminants. Alternative SC-6 is the most effective. in both of
these categories. However, when implementabili ty and cost are
factored in, SC-4 becomes the selected remedy. "When the
alternatives provide similar long-term effectiveness and permanence
and reduction of toxicity, mobility or volume, the other balancing
criteria arise to distinguish the alternatives and playa more
significant role in selecting the remedy. NCP Preamble, 55 Fed.
Reg. 8725 (1990). Alternative SC-5 was not selected because it
involves offsite treatment and disposal of groundwater at a
publicly owned treatment plant. This component could be very
difficult to implement since it involves municipal acceptance of
groundwater. SC-6 was not selected because the large volume of low
concentration levels of contaminants did not justify the cost of
solidification/incineration.
E.
The Selected Remedy satisfies the Preference
Which Permanently and significantly Reduces
Mobility or volume of the Hazardous Substances
Element
for Treatment
the Toxicity,
as a principal
The principal element of the selected source control remedy is
groundwater treatment. This element addresses the primary threat
at the Site, contamination of the groundwater with VOCs and metals.
The selected remedy satisfies the statutory preference for
treatment as a principal element by treating the extracted
groundwater in treatment processes which result in the removal of
VOCs and metals.
-------
XIII. STATE ROLE
The state of New Hampshire, Department of Environmental Services
(DES) has reviewed the various alternatives and indicated its
support for the selected remedy. The State has also reviewed the
Remedial Investigation, Risk Assessment and the Feasibility Study
to determine if the selected remedy is in compliance with
applicable or relevant and appropriate State Environmental laws
and regulations. The New Hampshire DES concurs with the selected
remedy for the Coakley Landfill Superfund site. A copy of the
declaration of concurrence is attached as Appendix D.
-------
APPENDIX A
-------
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.~ ' , " ....,... . , - .~.. .
. -- \ 0" O' "'~.'.., ,.... --
" I I , '...... '.' /
..". . .."'" ,--t. ~-, (.~ .'.) ~'\.'. .,/ I
. ~ c ~'- , ~ ','
----- ::> ( i \1 ('
/' -,.,{ ~ii /,
-", ,.., I)
( , . lr /' '
\ --------- 't.. i " /
' '.........., '': ~ \ r
\ - ---- --.: - '" .... - ., '
. ;;;'.~ .... 'j,. ,
. . 0_- .~'" \. \
\ '-., ""', ----, ,
. ..........,~
I ."'-"'-
,
,
...... .. --::.:..:-
- .. --""''''''-........
.... =".....~ ~;.:-.... .. -.-..
=:'::".. 8M.---
.......- :
- -.
... :::.
$ --
6
I
/
l
.
..
.
)
~.. ...'
"..'
I
I
I
I
,
,
-'
-' MOI8TOI8ia wa.u
LOCATIOII PUUC. . . -
IXP\.OIIATIOII .
--
~I"
---
- - -
~. .'UDf .
~LEYL~
-------
.><
,
/'
/
'-
'-
......
--
LEGEND
"
",/
~ - ....-:--~-~
, ----""~/"''''''
17\, EXCESSIVE SLOPE.
\.!..J REGRAOE TO"D.I. MAX-
, ~
o REGRADE TO 25.1. SLOPE.
@ REGRADE TO REMOVE BERMS.
f4\ ADO SAND FILL AROUND ROCK
\:::/ CAJTCROPS AND REGRADf TO
~~8J. MAX. SlOPE.
(;;\ ADD SAND FILL AS NECESSARY
o 10 REGRADE TO 28J. MIN. SLOPE.
PLACE EXCAVATE:> SECIMEI'IT ANC
DEBRI!:, ADO INTERMEDIATE COVER
Ar~D GRADE 10 2°1. MIN. SLOPE.
I~
SCALE
(IN FEETI
.H. DEPT. OF ENVIRONMENTAL SERVICE
FEASIBIliTY STUDY
COAKLEY LANDFILL
NOATH HAMPTON. HEW HAMPS.-£
150
t
FIGURE 7
SUBGRADE PREPARATION,
LANDFILL CAP
-------
-
......
---
LEGEND
-" IZo- EXISTING GRAD(
-120- PROPOSED GRADE
------ lMT OF M'£Av1OUS CAP
.. PEIUMUER!UfFACE 0AMt
NOrE
-
25' OM.t COHSTflUCTI08I EASEMENT
REQUIRED AT SOUTH AND EAST
lANDfIU. 8OUNOARY.
... ; ~. "'.~.
I~
SCALE
(If FEETt
150
t
...... _PT. Of EIMIIONMENTAl SERVICES
FEASI8IlITY STUDY
COAKLEY LANDFILL
880ItTM HAWTON, NEW HA"""'"
FIGURE 8
FINAL GRADE AND
SURFACE DRAINAGE,
-------
FIGURE 9
CROSS-SECTION OF A TYPICAL
MULTIMEDIA CAP
SYNTHETIC
DARRIER
,
TOPSOL
GAS COU-ECT10N SYSTEM
I
GAS COLLECTION SYSTEM
~,
"
. SANDY SOL
DRAINAGE LA YEA
-------
CLEAN AIR
FIGURE 10
ON-SITE TREATMENT BY EXTRACTION/
CHEMICAL PRECIPITATION/
AIR STRIPPING/BIOLOGICAL TREATMENT
SETIUNG CA nON
AGENTS FILTERS
-
. IECDARGE
. TO
AQUIFER
GROUND- GROUND- GROUND-
WATER I CHEMICAL W A TEl AIR- W A TEl BIOLOGICAL SEnLiNG DISCHARGE TO
I PRECIPITATION STM IPPING TREATMENT BASIN SUIFACE
WATER
~
METALS ( AIR SLUDGE
I DEWATERING DEWATERtNG
OFF-SITE
-------
Table 11
ARARs FOR ALTERNATIVE SC-6
COAKLEY LANDFILL
NORTH HAMPTON, NE~ HAMPSHIRE
ARAR's
Requirement Synopsis
........................... -- ..........", ..-.. --... -- ........................................... --... ....O' -............ -..... .............---............-.. ....---....-..", -'" ....- ..",.. ------......... ............................---.................----..-..-..-.............--..................
Status/Action to be Taken to Attain ARAR's
....... --.............-.... --... --...............-.. ....-................"""" -..................."'...-.. --....... --... ----.................-..---"''' -- -......... ......... ...-..-.. -...-- -_............- -.......-......................----...................................-.....................
GROUND~ATER
SD~A - Maximum Contaminant
Levels (MCLs) (40 CFR
141.11 - 141.16)
MCLs have been promulgated for a number of common
organic and inorganic contaminants. These levels
regulate the contaminants In public drinking
water supplies, but may also be considered
relevant and appropriate for groundwater aquifers
potentially used for drinking water.
~S 410
New Hampshire Groundwater Quality Criteria have
bp.en promulgated for a number of contaminants.
~S 300
New Hampshire drinking water standards regulate
the concentration of contaminants in public
drinking water supplies.
EPA Risk Reference Doses
(RfDs)
RfDs are dose levels developed based on the
noncarcinogenic effects and are used to develop
Hazard Indices. A Hazard Index of less than or
equal to 1 is considered acceptable.
Federal Ambient Water
Quality Criteria (AWOC) -
Adjusted for Drinking
Water
Federal AWOC are health-based criteria which have
been developed for 95 carcinogenic and non-
carcinogenic compounds.
EPA Carcinogen Assessment
Group Potency Factors
Potency Factors are developed by the EPA from
Health Effects Assessments or evaluation by the
Carcinogenic Assessment Group and are used to
develop excess cancer risks. A range of 10A-4 to
10A-7 is considered accepptable~
SURFACE WATER
~s 430, ~ater Quality
Standards
New Hampshire Surface Water Quality Standards are
given for toxics, dissolved oxygen, temperature
increase, pH, and total coliform. Federal AWOC
were adopted by IIH in ~s 430.
Federal Ambient Water
Quality Criteria (AWOC)
Federal AWOC are health-based criteria which have
been developed for 95 carcinogenic and
noncarcinogenic compounds.
Attained
Attained (a)
Attained (a)
Attained
Attained
Attained
Attfllned (a)
-------
<
I: N---
,~~-.~~- /'('/:~
"I' GZ-105 .. .' ~
.. .
~ r or ...~~
r It" APPROXIMATE LIMITS ~
OF WETLANDS ----.
""
!I:
..
..
...
c-
~
r
~. ...............
.
¥
,-
.0
or
LEGEND
GZ"D9..411h..oIIIh.
"'''GZ'II?
CJ
-
CJ
!IIIIIIIID
MULTI- MEDIA CAP
"Ellt SERVICE IID&D
APPROXIMATE LOCATION OF BEDROCK CAPTURE 20"E
HOR'20"TAL DRA'N IN GLACIAL OUTIltASH (UNDER CAP)
.
BEDROCK OTRACTIO" WELL
v
o
G"ACIAl Till EITRACTIO" WEll
~
SURFACE ORA'''~GE FROM CAP
IC:
J::
'0.
!
':'.' .. 't(.
~
N.H. DEPT. 01' ENVIRONMENTAL SERVICES
FEASIBILITY STUDY
COAKLEY LANDFILL
NORTH HAMPTO'/ . NEW HAMPSHIRE
FIGURE 11
-------
APPENDIX B
-------
FOR SOILS
Arsenic
Bari u:n
Bcnzo (a) pyrene
Bis (2~thylhexyl) phthalate
Cadmium
DIYI'
~ad
Nickel
Tetrachloroethylene
SURFACE \lAm
Arsenic
Barium
Methyl Ethyl Ketone
Toluene
v
TABLE 1
SE:L:TED DID:::a.TOR $UB~w:ES
~ GROOID~.'!11<
Arsenic
Barium
Benzene
Chlorobenzene
Chranium
1.2-Dichloroethylene
Diethyl phthalate
Nickel
Phenol
SEDIMEmS
Arsenic
Barium
Cadmium
Lead
-------
TABLE 2: SUMMARY OF CONTAMINANTS
OF CONCERN IN SOIL
contaminants
of Concern
Arsenic
Barium
Benzo(a)pyrene
Cadmium
DDT
Lead
Nickel
Geometric
(ma/kq)
25
59
485
5
44
69
57
Mean
Maximum
(ma/ka)
32
133
490
11
61
435
96
TABLE 3: SUMMARY OF CONTAMINANTS
OF CONCERN IN GROUND WATER
"Frequency
of Detection
7/8
8/8
2/8
8/8
2/8
8/8
8/8
Contaminants Geometric Mean Maximum Frequency
of Concern (ua/1) (ua/1) of Detection
Arsenic 15.1 89 11/18
2-Butanone (MEK) 97.3 2700 13/88
Barium 68.9 368 14/15
Benzene 8.6 60 34/91
Chlorobenzane 9.7 182 12/88
Chromium 19.7 330 5/16
1,2-Dichloroethylene 15.7 72 4/88
Diethyl phthalate 16.7 230 5/15
Nickel 22.6 200 14/15
-------
contaminants
of Concern
Arsenic
Barium
2-Butanone
Toluene
Contaminants
of Concern
Arsenic
Barium
Cadmium
Lead
Nickle
(MEK)
TABLE" : SUMMARY OF CONTAMINANTS
OF CONCERN IN SURFACE WATER
Geometric
Mean (ua/1)
Maximum
(ua/1)
1
85.2
2.2
227
8.4
6.6
TABLE 5: SUMMARY OF CONTAMINANTS
OF CONCERN IN SEDIMENTS
Geometric
Mean (ma/ka)
Maximum
(mq/ka)
46
59
2.8
114
33
6.9
29
2.4
34.7
22.2
Frequency
of Detection
4/7 ~
2/7
1/9
- 1/9
Frequency
of Detection
9/9
7/9
4/9
9/9
-------
Table 7
ARARs FOR ALTERNATIVE SC-'
COAKLEY LANDFILL
NORTH HAMPTON, NEY HAMPSHIRE
ARAR's
Requirement Synopsis
"""''''''''''''''''.-'''''''''''''''''''''''''''''''''''''''''''''''''''''''''''''''''''''''''''''''''''''''''''''''''''''o6'''''-''''''''''''''''''''''''''''''''' ------ ....--.....""",,,,,,,,,,,,, -............ -.....................................",.. --.....................",...... --..... -- --..................................... -...-....
Status/Action to be Taken to Attain ARAR's
.. --........ ...........................--................ .....--....- -..-....... ""''''''------ .....-..... ....- .......... ..-..--.......----.......................... ---.... --- --.............. ----... ---------- ......-.... ....----.....-............---........ --- ..--_..
GROUNDYATER
SDYA - Maximum Contaminant
Levels (MCLS) (40 CFR
141.11 . 141.16)
MCLs have been promulgated for a number of common
organic and inorganic contaminants. These levels
regulate the contaminants in public drinking
water supplies, but may also be considered
relevant and appropriate for groundwater aquifers
potentially used for drinking water.
YS 410
New Hampshire Groundwater Quality Criteria have
been promulgated for a number of contaminants.
YS 300
New Hampshire drinking water standards regulate
the concentration of contaminants in public
drinking water supplies.
EPA Risk Reference Doses
(RfDs)
RfDs are dose levels developed based on the
noncarcinogenic effects and are used to develop
Hazard Indices. A Hazard Index of less than or
equal to 1 is considered acceptable.
Federal Ambient Yater
Quality Criteria (AYQC) .
Adjusted for Drinking
Yater
Federal AYOC are health-based criteria which have
been developed for 95 carcinogenic and fion-
carcinogenic compounds.
EPA Carcinogen Assessment
Group Potency Factors
Potency Factors are developed by the EPA from
Health Effects Assessments or evaluation by the
Carcinogenic Assessment Group and are used to
develop excess cancer risks. A range of 10~'4 to
10~-7 is considered accepptable.
SURFACE YATER
YS 430, Yater Quality
Standards
New Hampshire Surface Yater Quality Standards are
given for toxics, dissolved oxygen, temperature
increase, pH, and total coliform. Federal AYQC
were adopted by NH in Ys 430.
Federal Ambient Water
ou~lity Criteria (tWOC)
Federal AUOC arc health-based criteria which have
been developed for 9S carcinogenic and
noncarcinogenic compounds.
Not Attained
Not Attained (a)
Not Attained (a)
Not Attained
Not Attained
Not Attained
Nor Attained (a)
-------
"
Table 7
ARARs FOR ALTERNATIVE SC-1
COAKLEY LANDFILL
NORTH HAMPTON, NEW HAMPSHIRE
................."" --............"" --.................... -........................................ --... ...-............................................. ...---...................'"' ....................................... ..............",..... ..--- ........-....- ................................................. --..........
........-..-----......................-...............................................-----.....--..-------..........--........---.....--.....--.......................................---...............-.......------..-........-.............--.........----..............--...
ARAR's
Requirement Synopsis
Status/Action to be Taken to Attain ARA~'s
AIR
CAA - National Ambient Air
Quality Standards (NAAQS) -
1,0 CFR 52
Refer to State Implementation Plan and NHDES Air
Pollution Regulations.
Attained
Attained (a)
NH OES - Air Pollution
Regulations (Air)
a
Threshold limit Values
(TL Vs)
These standards were issued as consensus
standards for controlling air quality in work
place environments.
Attained
RCRA - Groundwater Protection
(40 CFR 264.30 - 264.31)
This regulation details requirements for a
groundwater monitoring program to be installed
at the site.
A groundwater monitoring program consistent with
this regulation will be developed and implemented.
OSHA - General Industry
Standards (29 CFR Part 1910)"
This regulation specifies the a-hour
time-weighted average concentration for various
organic compounds.
Proper respiratory equipment will be worn if it
is impossible to maintain the work atmosphere
below the TWA's
OSHA' Safety and Health
Standards (29 CFR Part 1926)
This regulation specifies the type of safety
equipment and procedures to be ,followed during
site remediation.
All appropriate safety equipment will be on-site.
In addition, safety procedures will be followed
during on-site activities.
OSHA - Recordkeeplng, Reporting,
and Related Regulations"
This regulation outlines the record- keeping and
reporting requirements for an employer under
OSHA. . .
These requirements apply to all site contractors
and subcontractors and must be followed during
all site work.
".
a:
-------
Table 8
ARARs FOR ALTERNATIVE 5C-3
COAKLEY lANDFill
NORTH HAMPTON, NE~ HAMPSHIRE
ARAR's
Requirement Synopsis
...................-.............. --........... ----..-.. .......-........ ---...... -- -....'" --.....--..--....----.... ...........---.. -- -... ....... --..-.......... --...... ---.... -_..-....- ..-..-.............................--------------- ...........-............-
Status/Action to be Taken to Attain AR~R's
............................................. --...... ..-....-......................"""""""""" ----.. ......-...... ............ -- --................................. --...... -................................ -""""''''''''''.''' -...................... --............ --....-...... -............
GROUND~ATER
SD~A - Maximum Contaminant.
levels (MCls) (40 CFR
141.11 - 141.16)
MCls have been promulgated for a number of common
organic and inorganic contaminants. These levels
regulate the contaminants in public drinking
water supplies, but may also be considered
relevant and appropriate for groundwater aquifers
potentially used for drinking water.
~S 410
New Hampshire Groundwater Quality Criteria have
been promulgated for a number of contaminants.
~S 300
New Hampshire drinking water standards regulate
the concentration of contaminants in public
drinking water supplies.
EPA Risk Reference Doses
(RIDs)
RfDs are dose levels developed based on the
noncarcinogenic effects and are used to develop
Hazard Indices. A Hazard Index of less than or
equal to 1 is considered acceptable.
Federal Ambient ~ater
Quality Criteria (A~C) .
Adjusted for Drinking
~ater
Federal A~C are health-based criteria which have
been developed for 95 carcinogenic and non-
carcinogenic compounds.
EPA Carcinogen Assessment
Group Potency Factors
Potency Factors are developed by the EPA from
Health Effects Assessments or evaluation by the
Carcinogenic Assessment Group ~nd are used to
develop excess cancer risks. A range of 10~-4 to
10~-7 is considered accepptable~
SURFACE ~ATER
~S 430, ~ater Quali,y
Standards
New Hampshire Surface ~ater Quality Standards are
given for toxics, dissolved oxygen, temperature
increase, pH, and total coliform. Federal A~QC
were adopted by NH in ~s '30.
Federal Ambient ~at?r
Quality Criteria (A~C)
Federal A~C are health-based criteria which have
been developed for 95 carcinogenic and
noncarcinogenic compounds.
Not Attained
Not Attained (a)
Not Attained (a)
Attained
Not Attained
Not Attained
Attained (a)
-------
Table 8
ARARs FOR ALTERNATIVE SC-3
COAKlEY lANDF III
NORTH HAMPTDN, NEY HAMPSHIRE
.................................................-.........-[[[ .......- ..--...... -........... --[[[ ........ ....--..--- ........-...... --.................. -.................
..-.-..--..........--.....-..-.-.................................-.............-......-..........----..-..-..---..---..-..--...........-----------..----..--......-------...-..-......--------..--.........--------...---..-..-..
ARAR's
Requirement Synopsis
Status/Action to be Taken to Attain ARAR's
AIR
CAA . National Ambient Air
Quality Standards (NAAQS) .
40 CFR 52
Refer to State Implementation Plan and NHDES Air
Pollution Regulations.
Attained
NH DES. Air Pollution
Regulations (Air)
a
Attained (a)
Threshold limit Values
(Tl Vs)
These standards were issued as consensus
standards for controlling air quality in work
place environments.
Attained
YET lANDS
Clean Water Act (CWA) .
Section f,0f,
Under this requirement, no activity that
adversely affects a wetland shall be permitted if
a practicable alternative that has less affect is
available.
Excavation of contaminated sediments west of the
landfill will be accomplished with minimal
effects on the. wetland.
Fish and Wildlife
Coordination Act (16 U.S.C.
661 )
This regulation requires that ~y Federal Agency
that proposes to modify a body of water must
consult with the U.S. Fish and Wildlife Services.
This requirement is addressed under CWA Section
f,04 requir~nts. .
Prior to excavation of contaminated sediments EPA
will consult the U.S. Fish and Wildlife Service.
Wetlands Executive Order
(EO 1'990)
Under this regulation, Federal agencies are
required to minimize the destruction, loss or
degradation of wetlands and preserve and enhance
natural and beneficial values of wetlands.
Excavation of contaminated sediments west of the
landfill will be accomplished with minimal
effects on the wetland.
Floodplains Executive
Order (EO '1888)
Federal Agencies are required to reduce the risk
of flood loss, to minimize impact of floods, and
to restore and preserve the natural and
beneficial value of floodplains.
-------
Table 8
ARARs FOR ALTERNATIVE SC-3
COAKLEY LANDFILL
NORTH HAMPTON, NEW HAMPSHIRE
.................................................-...-.-..................-.................................................. -..- -.......- ---..... -..................-...............-[[[ -- --- -... ---[[[ .......
ARAR's
Requirement Synopsis
Status/Action to be Taken to Attain ARAR's
........................................... --.-... -........... -.-...................................... ---......... -- -..-- -..- -----....... --... ---[[[ -..... --.. ...-.- .............-............................. -- -.................................
RCRA - Standards for Owner.
and Operators of Permitted
Hazardous Waste Facilities
(40 CFR 264)
General facility requirements outline general
waste analysis, security measures, inspections,
and training requirements.
The cap and gas incineration system will be
constructed, and operated in accordance with
these requirements. All workers will be properly
trained.
RCRA - Groundwater Protection
(40 CFR 264.30 - 264.31)
This regulation details requirements for a
groundwater monitoring program to be installed
at the site.
A groundwater monitoring program consistent with
this regulation will be developed and implemented.
RCRA - Closure and Post-closure
(40 CFR 264.110 - 264.120)
This regulation details specific requirements
for closure and post-closure of hazardous waste
facilities.
A monitoring and maintenance program for the
capping system will be implemented in accordance
with this regulation.
OSHA - General Industry
Standards (29 CFR Part 1910)
This regulation specifies the a-hour
time-weighted average concentration for various
organic compounds.
Proper respiratory equipment will be worn if It
is impossible to maintain the work atmosphere
below the TWA's '.
OSHA - Safety and Health
Standards (29 CFR Part 1926)
This regulation specifies the type of safety
equipment and procedures to be followed during
site remediation.
All appropriate safety equipment will be on-site.
In addition, safety procedures will be followed
during on-site activities.
OSHA - Recordkeeplng, Reporting,
and Related Regulations
This regulation outlines the record. keeping and
reporting requirements for an employer under
OSHA.
These requirements apply to all site contractors
and subcontractors and must be followed during
all site work.
US EPA Off-site Policy
This regulation requires that off-site treatment
and/or disposal be performed a~ a facility which
is in compliance with EPA regulations.
Off-site disposal of perched leachate will be
performed in accordance with this policy.
DOT Rules for Transportation
of Hazardous Materials (49 CFR
Parts 107, 171.10171.5)
This regulatjon out)ine~'procedures for the
packaging, labelinQ, manifesting, and
transporting of hazardous materials.
Perched leachate will be manifested and
transported in bulk to a licensed off'site TSD
fa~!lity in compliance with these regulations.
N.H. DES New Hampshire Solid
Waste Regulations H~-P 1901.
This regulation provides standards for solid
waste disposal facilities.
Standards for solid waste disposal facilities
~ill be followed when the landfill is capped. (a)
N.H. DES. Air Pollution
-------
Table 8
ARARS FOR ALTERNATIVE SC-3
COAKLEY LANDFILL
NORTH HAMPTON, NEW HAMPSHIRE
ARAR'S
Requ i rement Synops i s
procedures, and definitions are described.
Status/Action to be Taken to Attain ARAR's
New Hampshire Wetlands BMrd,
RSA 483-A, and RSA U9-8*.
These regulations are promulgated under the N.H.
Wetlands Board which regulates dredging,
filling, altering or polluting inland wetlands.
Excavation of contaminated sediments west of the
landfill will be accomplished with minimal
effects on the wetland, (a)
New Hampshire Hazardous Waste
Rules, He-P 1905.
These regulations outline the criteria for the
construction, operations, and maintenance of a
new facility or increase in an existing facility
for the storage, treatment, or disposal of
hazardous waste.
The disposal of material on-site and the
consruction end operation of the treatment
facility will be performed in accordance with
these regulations, (a)
-------
Table 9
ARARs FOR ALTERNATIVE 5C-4
COAKLEY LANDFILL
NORTH HAMPTON, NE~ HAMPSHIRE
ARAR's
Requirement Synopsis
..-----....--..-.----------..-...-----.-----.--------------------------.---------.----------------------------------------------------------------.-.----
Status/Action to be Taken to Attain ARAR's
---.---------------...---.-.--...-.------------.----.-....-----.-----.-.-.-......----------------------..---____a...-.----...-------....----.-.--.-------
GROUNDUATER
SD~A - Maximum Contaminant
Levels (MCLS) (40 CFR '
141.11 - 141.16)
MCLS have been promulgated for a number of common
organic and inorganic contaminants. These levels
regulate the contaminants in public drinking
water supplies, but may also be considered
relevant and appropriate for groundwater aquifers
potentially used for drinking water.
~S 410
New Hampshire Groundwater Quality Criteria have
been promulgated for a number of contaminants.
~S 300
New Hampshire drinking water standards regulate
the concentration of contaminants in public
drinking water supplies.
EPA Risk Reference Doses
(RfDs)
RfDs are dose levels developed based on the
noncarcinogenic effects and are used to develop
Hazard Indices. A Hazard Index of less than or
equal to 1 is considered acceptable.
Federal Ambient ~ater
Quality Criteria (A~C) .
Adjusted for Drinking
Water
Federal AWCC are health-based criteria which have
been developed for 95 carcinogenic and non-
carcinogenic compounds.
EPA Carcinogen Assessment
Group Potency Factors
Potency Factors are developed by the EPA from
Health Effects Assessments or evaluation by the
Carcinogenic Assessment Group and are used to
develop excess cancer risks. A 'range of 10A." to
10A-7 is considered accepptabl~.
SURFACE ~ATER
WS 430, ~ater Quality
Standards
New Hampshire Surface ~ater Quality Standards are
given for toxics, dissolved oxygen, temperature
increase, pH, and total coliform. Federal Auac
were adopted by NH in ~s 430.
Federal Ambient Uater
Quality Criteria (A~QC)
Federal A~C are health-based criteria which have
been developed for 95 carcinogenic and
noncarcinogenic compounds.
Attained
Attained (a)
Attained (a)
Attained
Attained
Attained
Attllined (a)
~
-------
Table 9
ARARs FOR ALTERNATIVE SC-4
COAKLEY LANDFILL
NORTH HAMPTON, NE~ HAMPSHIRE
[[[ -.- -.-.............................................-..............-...... .--... -...-...- -......................... -.............eo............................ -- --.................................. --...- -- -. ------......... --................. ---
ARAR's
Requirement Synopsis
Status/Action to be Taken to Attain ARAR's
...........-------.-.................----......----......--..-----.-..---...-..----..--.-.----...-------...-----.....-...-----......-----..-.............-..---.........----.....----...---...-.....----------...-.....---...-........----
AIR
CAA . National Ambient Air
Quality Standards (N~QS) -
40 CFR 52
Refer to State Implementation Plan and NHDES Air
Pollution Regulations.
Attained
NH DES. Air Pollution
Regulations (Air)
a
Attained (a)
Threshold limit Values
(TlVs)
These standards were issued as consensus
standards for controlling air quality in work
place environments.
Attained
~ETlANDS
Clean ~ater Act (C~A) .
Section 404
Under this requirement, no activity that
adversely affects a wetland shall be permitted if
a practicable alternative that has less affect is
available.
Excavation of contaminated sediments west of the
landfill will be accomplished with minimal
effects on the wetland.
fish and Wildlife
Coordination Act (16 U.S.C.
661)
This regulation requires that any federal Agency
that proposes to modify a body of water must
consult with the U.S. fish and ~ildlife Services.
This requirement is addressed under C~A Section
404 requirements.
Prior to excavation of contaminated sediments and
discharge of treated groundwater to the onsite
surface water, EPA will consult the U.S. Fish and
Wildlife Service.
Wetlands Executive Order
(EO 11990)
Under this regulation, Federal agencies are
required to minimize the destruction, loss or
degradation of wetlands and preserve and enhance
natural and beneficial values of wetlands.
Excavation of contaminated sediments west of the
landfill will be accomplished with minimal
effects on the wetland.
Floodplains Executive
Order (EO 11888)
Federal Agencies are required to reduce the risk
of flood loss, to minimize impact of floods, and
to restore and preserve the natural and
beneficial value of floodplains.
r
Excavation of contaminated sediments west of the
landfill and discharge of treated groundwater
-------
Table.9
ARARs FOR ALTERNATIVE SC-4
COAKLEY lANDFIll
NORTH HAMPTON, NEU HAMPSHIRE
[[[ --.... ..-..---..................... -. --.............. ----.... -"."...---.. --...........................................-[[[ --.. -- .--..-- --...... --................... '"''' -- -....
ARAR's
Requirement Synopsis
Status/Action to be Taken to Attain ARAR's
----........-----......-.......--------.....-..-------..--------..---........-....------------..---------------......----------..-----..--.-..-.....-.......----..---..---.-..-------------
condition.
RCRA - Standards for Owners
and Operators of Permitted
Hazardous Uaste Facilities
(40 CFR 264)
General facility requirements outline general
waste analysis, security measures, inspections,
and training requirements.
The cap, gas incineration groundwater treatment
system will be designed, constructed, and
operated in accordance with these requirements.
All workers will be properly trained.
RCRA - Groundwater Protection
(40 CFR264.30 - 264.31)
This regulation details requirements for a
groundwater monitoring program to be installed
at the site.
A groundwater monitoring program consistent with
this regulation will be developed and implemented.
RCRA - Closure and Post-closure
(40 CFR 264.110 - 264.120)
This regulation details specific requirements
for closure and post-closure of hazardous waste
f ac it i ties.
A monitoring and maintenance program for the
capping system will be implemented in accordance
with this regulation.
OSHA - General Industry
Standards (29 CFR Part 1910)
This regulation specifies the 8-hour
time-weighted average concentration for various
organic compounds.
Proper respiratory equipment will be worn if it
is impossible to maintain the work atmosphere
below the TUA's '.
OSHA - Safety and Health
Standards (29 CFR Part 1926)
This regulation specifies the type of safety
equipment and procedures to be followed during
site remediation.
All appropriate safety equipment will be on-site.
In addition, safety procedures will be followed
during on-site activities.
OSHA - Recordkeeping, Reporting,
and Related Regulations
This regulation outlines the record- keeping and
reporting requirements for an employer under
OSHA.
These requirements apply to all site contractors
and subcontractors and must be followed during
all site work.
RCRA - land Disposal
Restrictions (40 CFR 268)
This regulation outlines land disposal
requirements and restrictions for hazardous
wastes.
Sludge from the groundwater treatment unit which
fails the TClP extraction procedure will be
treated to the Best Demonstrated Available
Technology levels before being placed into a
at an off-site facility.
US EPA Off-site Policy
This regulation req~ires that off-site treatment
and/or disposal be performed at a facility which
is in compliance with EPA regulations.
Off-s'ite disposal of sludge from the groundwater
treatment unit will be performed in accordance
with this policy.
DOT Rules for Transportation
of Hazardous Materials (49 CFR
Parts 107, 171.10171.5)
This regulation outlines procedures for the
packaging, labeling, manifesting, and
transporting of hazardous materials.
Sludge from the groundwater treatment unit will
-------
Table 9
ARARs FOR ALTERNATIVE SC-4
COAKLEY LANDFILL
NORTH HAMPTON, NEW HAMPSHIRE
ARAR'S
R equ i rement Synops i s
Status/Action to be Taken to Attain ARAR's
N.H. OES New Hampshire Solid
Waste Regulations He-P 1901.
This regulation provides standards for solid
waste disposal facilities.
Standards for solid waste disposal facilities
will be followed when the landfill is capped, (a)
N.H. OES - Air Pollution
Regulations (Air)
This regulation outlines the standards and
requirements for air pollution control in the
State of New Hampshire; all provisions,
procedures, and definitions are described.
Emissions from excavation, air stripper and gas
incineration system will be maintained below
standards using emissions controls, as necessary.
(a)
New Hampshire Wetlands Board,
RSA 483-A, and RSA K9-8a.
These regulations are promulgated under the N.H.
Wetlands Board which regulates dredging,
filling, altering or polluting inland wetlands.
Excavation of contaminated sediments west of
landfill will be accomplished with minimal
effects on the wetland, (a)
the
New Hampshire Hazardous Waste
Rules, He-P 1905.
These regulations outline the criteria for the
construction, operations, and maintenance of a
new facility or increase in an existing facility
for the storage, treatment, or disposal of
hazardous waste.
The disposal of material on-site and the
constuction and operation of the treatment
facility will be performed in accordance with
these regulations, (a)
-------
Table 10
ARARs FOR ALTERNATIVE SC-5
COAKLEY LANDF I LL
NORTH HAMPTON, NE~ HAMPSHIRE
ARAR's
Requirement Synopsis
....e._......----......----.....----..-.-........-.---.-._e___..........-------...---.---...........---.-......---..---.....-.-....-----.-.--------------
Status/Action to be Taken to Attain ARAR's
.-...--...-----.-....-----.....-------..---...---...-..-.-........-.....-....--------------------.------..--.--.--------...--......-------.------..---.-.
GROUND~ATER
SD~A - Maximum Contaminant
Levels (MCLs) (40 CFR
141.11 - 141.16)
MCLs have been promulgated for a number of common
organic and inorganic contaminants. These levels
regulate the contaminants in public drinking
water supplies, but may also be considered
relevant and appropriate for groundwater aquifers
potentially used for drinking water.
~S 410
New Hampshire Groundwater Quality Criteria have
been promulgated for a number of contaminants.
~S 300
New Hampshire drinking water standards regulate
the concentration of contaminants in public
drinking water supplies.
EPA Risk Reference Doses
(RfDs)
RfDs are dose levels developed based on the
noncarcinogenic effects and ere used to develop
Hazard Indices. A Hazard Index of less than or
equal to 1 is considered acceptable.
Federal Ambie~t Water
Quality Criteria (AWQC) -
Adjusted for Drinking
Water
Federal AWQC are health-based criteria which have
been developed for 95 carcinogenic and non-
carcinogenic compounds.
EPA Carcinogen Assessment
Group Potency Factors
Potency Factors are developed by the EPA from
Health Effects Assessments or evaluation by the
Carcinogenic Assessment Group ~nd are used to
develop excess cancer risks. A range of 10A-4 to
10A-7 is considered accepptable-
SURFACE ~ATER
WS 430, ~ater Quality
Standards
New Hampshire Surface ~ater Quality Standards are
given for toxics, dissolved oxygen, temperature
increase, pH, and total coliform. Federal A~C
were adopted by NH in ~s 430.
Federal Ambient ~ater
Quality Criteria (A~JC)
Federal AWQC are health-based criteria which have
been developed for 95 carcinogenic and
noncarcinogenic compounds.
Attained
Attained (a)
Attained (a)
Attained
Attained
Attai ned
Atteined (a)
-------
Table 10
ARARs FOR ALTERNATIVE SC-S
COAKlEY LANDF ILL
NORTH HAMPTON, NEW HAMPSHIRE
.....................................-...................... ........................................... -.-.......... -- -..-.. ........- -- --..................-..................................-[[[ ---.. -.............. --................ --....
ARAR's
Requirement Synopsis
StatuS/Action to be Taken to Attain ARAR's
.......... --............ --............ --.......... -.. --..... --..................................... .-...-.......... --.. ..-- --[[[ -.......-...... -- --.... -- -........ ..............................
AIR
CAA . National Ambient Air
Quality Standards (NAAQS) .
1,0 CFR 52
Refer to State Implementation Plan and NHDES Air
Pollution Regulations.
Attained
NH DES' Air Pollution
Regulations (Air)
a
Attained (a)
Threshold Limit Values
(TLVs)
These standards were issued as consensus
standards for controlling air quality in work
place environments.
Attained
WETlANDS
Clean Water Act (CWA) .
Section 1,01,
Under this requirement, no activity that
adversely affects a wetland shall be permitted if
a practicable alternative that has less affect is
available.
Excavation of contaminated sediments west of the
landfill will be accomplished with minimal
effects on the wetland. .
Fish and wildlife
Coordination Act (16 U.S.C.
661 )
This regulation requires that any Federal Agency
that proposes to modify a body of water must
consult with the U.S. Fish and ~ildlife Services.
This requirement is addressed under CWA Section
1,01, requi re~nts. .
Prior to excavation of contaminated sediments and
construction of the discharge sewer, EPA will
consult the U.S. Fish and Wildlife Service.
Wetlands Executive Order
(EO 11990)
Under this regulation, Federal agencies are
required to minimize the destruction, loss or
degradation of wetlands and preserve and enhance
natural and beneficial values of wetlands.
Exc8vation of contaminated sediments west of the
landfill will be accomplished with minimal
effects on the wetland.
Floodplains Executive
Order (EO 11888)
Federal Agencies are required to reduce the risk
of flood loss, to minimize impact of floods, and
to restore and preserve the natural and
beneficial value of floodplains.
-------
Table 10
ARARs FOR ALTERNATIVE SC-5
COAKLEY LANDFILL
NORTH HAMPTON, NE~ HAMPSHIRE
.. ... .. ... .. .. .. .. .. .. .. .. .. .. .. .. ... .. .. .. ... ... ... .. ... ... ... ... .. .. .. .. ... ... .. ... ... ... ... .. .. .. .. .. .. .. .. .. .. ... .. ... .. .. .. .. ... ... ... .. .. ... .. .. ... .. ... .. .. .. .. .. .. ... ... .. .. .. .. ... .. .. .. .. .. --.. .. .. .. .. ... ... .. .. .. .. ... .. .. .. .. .. .. .. .. .. .. .. .. .. ... .. .. .. .. .. .. .. .. .. .. .. .. .. .. .. .. .. .. .. .. .. .. .. ... .. .. .. .. .. .. .. ... .. .. .. .. .. .. .. .. ..
ARAR's
Requirement Synopsis
Status/Action to be Taken to Attain ARAR's
[[[ -.......-[[[ ---------..-[[[-........ ......-.. --......'"'..-.............................
condition.
RCRA . Standards for owner.
and Operators of Permitted
Hazardous ~aste Facilities
(40 CFR 264)
General facility requirements outline general
waste analysis, security measures, inspections,
and training requirements.
The cap, gas incineration system and groundwater
treatment system will be designed constructed,
and operated in accordance with these
requirements. All workers will be properly
trained.
RCRA - Groundwater Protection
(40 CFR 264.30 - 264.31)
This regulation details requirements for a
groundwater monitoring program to be installed
at the site.
A groundwater monitoring program consistent with
this regulation will be developed and implemented.
RCRA - Closure and Post-closure
(40 CFR 264.110 . 264.120)
This regulation details specific requirements
for closure and post-closure of hazardous waste
fac II i ties.
A monitoring and maintenance program for the
capping system will be implemented in accordance
with this regulation.
OSHA - General Industry
Standards (29 CFR Part 1910)
This regulation specifies the 8-hour
time'weighted average concentration for various
organic compounds.
Proper respiratory equipment will be worn if it
is impossible to maintain the work atmosphere
below the T~A's
OSHA' Safety and Health
Standards (29 CFR Part 1926)
This regulation specifies the type of safety
equipment and procedures to be followed during
site remediation.
All appropriate safety equipment will be on-site.
In addition, safety procedures will be followed
during on-site activities.
OSHA - Recordkeeping, Reporting,
and Related Regulations
This regulation outlines the record- keeping and
reporting requirements for an employer under
OSHA.
These requirements apply to all site contractors
and subcontractors and must be followed during
all site work.
RCRA . Land Disposal
Restrictions (40 CFR 268)
This regulation outlines land disposal
requirements and restrictions ~or hazardous
wastes.
Sludge from the groundwater treatment unit and
material from the Oily Debris Area which fails
the TCLP extraction procedure will be treated to
the Best Demonstrated Available Technology levels
at an off-site facility.
C~A . 40 CFR Part 403
This regulation s~cifies pretreatment standards
for discharges to a publlcly'owned treatment
works (POT~).
Gene~al prohibition standard will be met.
..
TSCA . PCB Requirem~nts
(40 CFR 761)
This regulation outlines the requirements for the
disposal of materials containing PCB's.
-------
Table 10
ARARs FOR ALTERNATIVE SC-S
COAKLEY LANDF III
NORTH HAMPTON, NEU HAMPSHIRE
[[[ [[[ -.-...................... --........................................-........ ........ --......... ......- -. """"-""""""""''''''''''''''''''''' -.. ...--
ARAR's
Requirement Synopsis
Status/Action to be Taken to Attain ARAR's
-.... ---......... .....--.... -........-- -... .........--................-.-..-..... --... "....-..o.- -- _..-.... -..._- -..........-- --..... ............--.. -........._--- --........ ......... ..-..........-......-..------........-......-.............--...... ---...........-
and/or disposal be performed at a facility which
is in compliance with EPA regulations.
treatment unit, waste from the Oily Debris Area
and pretreated groundwater will be performed in
accordance with this policy.
DOT Rules for Transportatfon
of Hazardous Materials (49 eFR
Parts 107, 171.10171.5)
This regulation outlines procedures for the
packaging, label ing, manifesting, and
transporting of hazardous materials.
Sludge from the groundwater treatment unit and
waste from the Oily Debris Area will be packaged,
manifested, and transported to a licensed
off'site TSD facility in compliance with these
regulations.
NHDES Pretretment Regulations
(Us 904)
This regulation specifies preteatment
requirements for discharges to a POTU.
A permit would be obtained from the Town prior to
discharging the pretreated groundwater.
Pretreatment limitations will be used as design
basis for groundwater treatment. (a)
N.H. DES New Hampshire Solid
Uaste Regulations He-P 1901.
This regulation provides standards for solid
waste disposal facilities.
Standards for solid waste disposal facilities
will be followed when the landfill is capped. (a)
N.H. DES' Air Pollution
Regulations (Air)
This regulation outlines the standards and
requirements for air pollution control in the
State of New Hampshire; all provisions,
procedures, and definitions are described.
Emissions from excavation, air stripper and gas
incineration system will be maintained below
standards using emissions controls, as necessary.
(a)
New Hampshire Uetlands Board,
RSA 483'A, and RSA 149-8a.
These regulations are promulgated under the N.H.
Uetlands Board which regulates dredging,
filling, altering or polluting inland wetlands.
Excavation of contaminated sediments west of the
landfill will be accomplished with minimal
effects on the wetland. (a)
New Hampshire Hazardous Uaste
Rules, He'P 1905.
These regulations outline the criteria for the
construction, operations, and"maintenance of a
new facility or increase in an existing facility
for the storage, treatment, or disposal of
hazardous wa~te.
State of New Hampshire ARARs are included in Appendix H.'
-------
Table 11
ARARs FOR ALTERNATIVE SC-6
COAKLEY lANDFill
NORTH HAMPTON, NEW HAMPSHIRE
.................................................."'................. -----.......................................... --......................... -........ .......-[[[ --... -..-..... --.....-.................................... --..........
ARAR's
Requirement Synopsis
Status/Action to be Taken to Attain ARAR's
[[[ -.. [[[ --....... .........--.. -........ --.. -........................................... ...-................................................. -............ -- -. -- -......--... -.....-...............................--
AIR
CAA . National Ambient Air
Quality Standards (NAAQS) .
1,0 CFR 52
Refer to State Implementation Plan and NHDES Air
Pollution Regulations.
Attained
NH DES' Air Pollution
Regulations (Air)
a
Attained (a)
Threshold limit Values
(Tl Vs)
These standards were issued as consensus
standards for controlling air quality in work
place environments.
Attained
WETlANDS
Clean Water Act (CWA) .
Section 1,01,
Under this requirement, no activity that
adversely affects a wetland shall be permitted if
a practicable alternative that has less affect is
avai lable.
Excavation of contaminated sediments west of the
landfill will be accomplished with minimal
effects on the wetland.
Fish and Wildlife
Coordination Act (16 U.S.C.
661 )
This regulation requires that eny Federal Agency
that proposes to modify a body of water must
consult with the U.S. Fish and.wildlife Services.
This requirement is addressed under CWA Section
1,01, requirements.
. .
Prior to excavation of contaminated sediments and
discharge of treated groundwater to the onsite
surface water, EPA will consult the U.S. Fish and
Wetlands Executive Order
(EO 11990)
Under this regulation, Federal agencies are
required to minimize the destruction, loss or
degradation of wetlands and preserve and enhance
natural and beneficial values of wetlands.
ExCavation of contaminated sediments west of the
landfill will be accomplished with minimal
effects on the wetland.
Floodplains Executhe
Order (EO 11888)
Federal Agencies are required to reduce the risk
of flood loss, to minimizp impact of floods, and
-------
Table 11
ARARs FOR ALTERNATIVE SC-6
COAKLEY LANDFILL
NORTH HAMPTON, NE~ HAMPSHIRE
ARAR's
[[[ ....... .......................................... ..-............. --........ --...... -....--........................-............-[[[ ................................................- ---
Requirement Synopsis
Status/Action to be Taken to Attain ARAR's
-...............-..-......-..---.-....--...-................----..-........-......--.................-..--.............-....-............-...........-..............------..-..--..-...........-....-....-.......---.........---..-..------....---
RCRA - Standards for Owner.
and Operators of Permitted
Hazardous ~aste Facilities
(1,0 CFR 264)
RCRA - Groundwater Protection
(1,0 CFR 264.30 - 264.31)
RCRA - Closure and Post-closure
(1,0 CFR 264.110 - 264.120)
OSHA - General Industry
Standards (29 CFR Part 1910)
OSHA. Safety and Health
Standards (29 CFR Part 1926)
OSHA - Recordkeeplng, Reporting,
and Related Regulations
RCRA . land Disposal
Restrictions (1,0 CFR 268)
TSCA - PCB Requirements
(1,0 CFR 761)
US EPA Off'site Policy
DOT Rules for Transportation
condition.
General facility requirements outline general
waste analysis, security measures, inspections,
and training requirements.
The cap, gas incineration, groundwater treatment,
soil incineration and solidification units will
be designed, constructed, and operated in
accordance with these requirements. All workers
will be properly trained.
This regulation details requirements for a
groundwater monitoring program to be installed
at the site.
A groundwater monitoring program consistent with
this regulation will be developed and Implemented.
This regulation details specific requirements
for closure and post-closure of hazardous waste
facilities.
A monitoring and maintenance program for the
capping system wjll be implemented in accordance
with this regulation.
This regulation specifies the 8-hour
time-weighted average concentration for various
organic compounds.
Proper respiratory equipment will be worn if It
is impossible to maintain the work atmosphere
below the T~A's -
This regulation specifies the type of safety
equipment and procedures to be followed during
site remediation.
All appropriate safety equipment will be on-site.
In addition, safety procedures will be followed
during on-site activities.
This regulation outlines the record- keeping and
reporting requirements for an employer under
OSHA.
These requirements apply to all site contractors
and subcontractors and must be followed during
all site work.
This regulation outlines land disposal
requirements and restrictions for hazardous
wastes.
Soil and solid waste from the landfill or sludge
from the groundwater treatment unit which falls
the TCLP extraction procedure will be treated to
the Best Demonstrated Available Technology levels
at an off-site facility.
This regulation outlines the requirements for the
disposal of materials containing PCB's.
The material excavated from the landfill will be
an~lyzed for PCB's prior to redisposal in the
I andf ill.
This regulation requires that off-site treatment
and/or disposal be performed at a facility which
is in compliance with EPA regulations.
Pff-site disposal of sludge from the groundwater
-------
Table 11
ARARs FOR ALTERNATIVE SC-6
COAKLEY LANDFILL
NORTH HAMPTON, NEW HAMPSHIRE
~.........._-..-.._-._-..........__...._.....-..__._-.-___e______-----------------.......-----.-.-------.------------.------------------.---------------.
ARAR'S
Requirement Synopsis
Status/Action to be Taken to Attain ARAR's
..._e_.____-----.....-----...-.-------.--------.-----....--.....------..---.----------------------.------.-------------.-...-----------------------------
of Hazardous Materials (49 CFR
Parts 107, 171.10171.5)
packaging, labeling, manifesting, and
transporting of hazardous materials.
be packaged, manifested, and transported to a
licensed off-site TSD facility in compliance
with these regulations.
i.:;
N.H. DES New Hampshire Solid
Waste Regulations He-P 1901.
This regulation provides standards for solid
waste disposal facilities.
Standards for solid waste disposal facilities
will be followed when the landfill is capped. (a)
N.H. DES, Air Pollution
Regulations (Air)
This regulation outlines the standards and
requirements for air pollution control in the
State of New Hampshire; all provisions,
procedures, and definitions are described.
Emissions from excavation, air stripper,
soil/solid waste incinerator and gas incineration
system will be maintained below standards using
emissions controls, as necessary. (a)
New Hampshire Wetlands Board,
RSA 483-A, and RSA 149-8a.
These regulations are promulgated under the N.H.
Wetlands Board which regulates dredging,
filling, altering or polluting inland wetlands.
Excavation of contaminated sediments west of the
landfill will be accomplished with minimal
effects on. the wetland. (a)
New Hampshire Hazardous Waste
Rules, He'P 1905.
These regulations outline the criteria for the
construction, operations, and maintenance of a
new facility or increase in 8n existing facility
for the storage, treatment, or disposal of
hazardous waste.
The disposal of material on-site and the
constuction and operation of the treatment
facility will be performed in accordance with
these regulations. (a)
a:
State of New Hampshire ARARs are included in Appendix H.
-------
Table
Chemical-Specific ARAR's and Criteria, Advisories, and Guidance
Coakley Landfill Site, North Hampton, New Hampshire
Requirement
Status
Requirement Synopsis
Consideration in the RI/FS
Medium/Authority
GROUNOWATER
federal Regulatory
Requirements
State Regulatory
Requirements
Federal Criteria,
Advisories, and
Guidance
SOWA - Haximu8 Contaminant
Levels (HCL's) (40 crR
141. 11 - 141.16)
RSA 149:8, 111/
Ws 410
U.S. EPA Risk Reference
Doses (RfD's)
Federal Ambient Water
Quality Criteria (AWQC) -
Adjusted for Drinking
Water
Relevant and
appropriate
Applicablea
To be
considered
Relevant and
appropriate
U.S. EPA Carcinogen Assess- To be
ment Group Potency ractors considered
SDWA - Maximum Contaminant
Level Goals (MCLG's)
To be
considered
HCL's have been promulgated for a number
of common organic and inorganic contami-
nants. These levels regulate the con-
taminants in public drinking water sup-
plies but may also be considered rele-
vant and appropriate for groundwater
aquifers potentially used for drinking
water.
New Hampshire Groundwater Quality
Standards have been promulgated for
a number of contaminants.
RfD's are dose levels developed based
on the noncarcinogenic effects.
federal AWQC are health-based criteria
that have been developed for 95 car-
cinogenic and noncarcinogenic com-
pounds.
Potency factors are developed by the
EPA from Health Effects Assessments or
evaluation by the Carcinogenic Assess-
ment Group.
Similar to HCl's; unenforceable
goals based ~n the health risk.
When the risks to human health due
to consumption of groundwater were
assessed, concentrations of contami-
nants of concern were compared to
their HCl's. MCl's were used to set
cleanup levels for these contaminants
(see Table 2-4).
When the state standards were more
stringent than Federal levels, the
state standards were used.
U.S. EPA RfD's were used to character-
ize risks due to exposure to conta~i-
nants in groundwater.
AWQC were used to characteri z,e heal th
risks due to contaminant concentrations
in drinking water.
U.S. EPA Carcinogenic Potency factors
were used to compute the individual
incremental cancer risk resulting
from exposure to site contaminants.
HCLG's may be used 'as cleanup goals if
deemed more appropriate than HCL's by
U.S. EPA.
399013
2-2
-------
Table 14
(continued)
'-
Requirement Synopsis
Consideration in the RI/fS
Medium/Authority
Requirement
Status
SURfACE WATER
State Regulatory
Requirements
federal Criteria,
Advisories, and
Guidance
Ws 430/RSA: 149:8. I;
Water Quality Classifica-
tions
Ws 400, Surface Water
Quality Standards
federal Ambient Water
Quality Criteria (AWQC)
CONTAMINATED SOILS AND SOLID WASTE
federal Criteria,
Advisories, and
Guidance
U.S. EPA Risk Reference
Doses (RfOs)
U.S. EPA Carcinogenic
Assessment Group Potency
factors
U.S. EPA Off-site Policy
Applicable
Applicable
Relevant and
appropriate
To be
considered
To be
considered
To be
considered
New Hampshire Surface Water Quality
Standards are given for toxics, dis-
solved oxygen, temperature increase,
pH, and total coliform. federal AWQC
were adopted by NH in WS 430.
Protects surface water from degraddtion
and protects aquatic life.
federal AWQC are health-based criteria
that have been developed for 95 car-
cinogenic and noncarcinogenic compounds.
RfD's are dose levels developed based
on the noncarcinogenic effects.
Potency factors are developed by the
U.S. EPA from Health Effects Assessments
or evaluation by the Carcinogenic
Assessment Group.
Specifies appropriate method of off-site
treatment on disposal of waste from a
Super~und sileo
NH requirements for dissolved oxygen,
temperature increase, pH, and total
coliform will be attained if state
standards are more stringent (see
Table 2-5).
Remedial action to eliminate discharge
that may cause degradation or endanger-
ment of aquatic life.
AWQC were considered in characterizing
human health risks and toxic effects on
aquatic organisms due to concentrations
in surface water. Because this water is
not used as a drinking water source,
the criteria for aquatic organism pro-
tection and ingestion of contaminate
aquatic organisms were considered (see
Table 2-4).
U.S. EPA RfD's were used to character-
ize risks due to exposure to contami-
nants in groundwater.
U.S. EPA Carcinogenic Potency factors
were used to compute the individual
incremental cancer risk resulting
from exposure to site contaminants.
Off-site disposal costs were calculated
based on compliance with the present
off-site policy.
3990U
2-3
-------
T, 14
( cont 1 nued)
Medium/Authority
Requirement Synopsis
Consideration in the RI/fS
Requirement
Status
AIR
federal Regulatory CAA - National Ambient Air Relevant and
Requirements Quality Standards (NAAQS) - appropriate
40 CfR 52
These standards were primarily developed
to regulate stack and automobile emis-
sions.
State Regulatory
Requirements
RSA 125-C/AIR lOa,
NH DES - Air Pollution
Regulations (Air)
Applicable
Establishes standards for release of
VOC's and hazardous pollutants.
federal Criteria.
Advisories. and
Guidance
Threshold Limit Values
(TLVs)
To be
considered
These standards were issued as
consensus standards for controlling
air quality in work place environ-
ments.
Standards for particulate matter will
be used when assessing excavation and
emission controls for soil treatments.
Applicable for alternatives involving
excavation and emission controls for
incineration, soil treatment, and
groundwater treatment.
TLV's could be used for assessing site
inhalation risks for soil removal
operations.
aA more detailed description of this regulation and its requirements can be found in Appendix H.
2-4
3990B
-------
Table 15
location-Specific ARAR's and Criteria, Advisories, and Guidance
Coakley Landfill Site, North Hampton, New Hampshire
Medium/Authority
Consideration in the RI/FS
Requirement
Status
Requirement Synopsis
WETLAND/FLOOD PLAINS
Federal Regulatory
Requirements
C1 ean Water Act (CWA) -
Sec ti on 404
fish and Wildlife
Coordination Act (16
U. S . C. 661)
RCRA Location Standards
(40 CFR 264.18)
Wellands Executive Order
(EO 11990)
flood Plains Execulive
Order (EO 11988)
Applicable
Applicable
Applicable
Applicable
App 1 i cab 1 e,
Under this requirement, no activity
that adversely affects a wetland shall
be permitted if a practicable alterna-
tive that has less effect is available.
This regulation requires that any
Federal agency that proposes to modify
a body of water must consult with the
U.S. Fish and Wildlife Service. This
requirement is addressed under CWA
Section 404 requirements.
This regulation outlines the require-
ments for constructing a RCRA facility
on a 100-year flood plain.
Under this regulation, Federal agencies
are required to minimize the destruc-
tion, loss, or degradation of wetlands
and preserve and enhance natural and
beneficial ~a1ues of wetlands.
Federal agencies are required to reduce
the risk of flood loss, to minimize
i~pact of floods, and to restore and
preserve the natural and beneficial
value of flood plains.
During the identification, screening,
and evaluation of alternatives, the
effects on wetlands are evaluated.
During the identification, screening,
and evaluation of alternatives, the
effects on wetlands are evaluated.
If an alternative modifies a body of
water, U.S. EPA must consult the U.S.
Fish and Wildlife Service.
A facility located on a 100-year flood
plain must be designed, constructed,
operated, and maintained to prevent
washout or any hazardous waste by a
100-year flood, unless waste may be
removed safely before flood water can
reach the facility or no adverse
effects on human health and 'the envi-
ronment would result if washout
occurred, Applicable alternatives
involve removing, filling, dredging, or
altering a NH-defined wetland.
Remedial alternatives that involve con-
struction must include all practicable
means of minimizing harm to wetlands.
Wetlands protection considerations must
be incorporated into the planning and
decision making about remedial alterna-
tives.
The potential effects of any action
must be evaluated to ensure that the
.planning and decision making reflect
", consideration of flood hazards and
flood plain management, including res-
toration and preservation of natural
underdeveloped flood plains.
3990U
-------
Tabl e 15
(continued)
Medium/Authority
Requir....nt
Status
Requirement Synopsis
Consideration in the Ri/fS
State Regulatory
Requirements
40 CfR 6.
New Hampshire Wetlands
Board RSA 483-A and RSA
l49-8A.
N.H. DES - Hazardous Waste
Regulations, He-P 1905
New Hampshire Solid Waste
Management Rules, He-P
Ch. 1901.
Applicable
Applicable
Applicable
Applicable
Promulgated the foregoing wetlands
and flood plains executive orders.
These regulations are promulgated under
the New Hampshire Wetlands Board, which
regulate dredging, filling, altering,
or polluting inland wetlands.
These regulations outline the criteria
for the construction, operation, and
maintenance of facilities for the stor-
age, treatment, or disposal of hazardous
waste.
This regulation outlines procedures for
establishing a solid waste facility in
the State of New Hampshire.
Considered with the foregoing executive
orders.
May be relevant and appropriate if
alternatives involve removing, filling,
dredging, or altering a NH-defined
wetland.
Applicable for final disposal of
hazardous wastes generated on-site.
Nonhazardous waste may remain on-site
after treatment, requiring solid waste
facility management and closure.
2-6
-------
Table 16
Potential Action-Specific ARAR's
Coakley landfill Site, North Hampton, New Hampshire
ARAR's
Action to Be Taken to Attain ARAR's
Requirement Synopsis
RCRA - Standards for Owners and
Operators of Permitted Hazardous
Waste facilities (40 CfR 264)
RCRA - Groundwater Protection
(40 CfR 264.30 - 264.31) .
RCRA - Closure and Post-Closure
(40 CfR 264.110 - 264.120)
OSHA - General Industry Standards
(29 CfR Part 1910)
OSHA - Safety and Health
Standards (29 CfR Part 1926)
OSHA - Recordkeeping, Reporting,
and Related Regulations
RCRA - land Disposal Restrictions
(40 CfR 268)
CWA - 40 CfR Part 403
CWA - Section 404
General facility requirements outline general
waste analysis, security measures, inspections,
and training requirements.
This regulation details requirements for a
groundwater monitoring program to be installed
at the si te.
This regulation details specific requirements
for closure and post-closure of hazardous waste
facil it ies.
This regulation specifies the 8-hour, time-
weighted average concentration for various
organic compounds.
This regulation specifies the type of safety
equipment and procedures to be followed during
site remediation.
This regulation outlines the recordkeeping and
reporting requirements for an employer under
OSHA.
This regulation outlines land disposal require-
ments and restrictions for hazardous wastes.
This regulation specifies pretreatment. standards
for discharges to a publicly owned treatment
works (POTW).
This regulation outlin~s req~irements for dis-
charges of dredged or fill material. Under this
requirement, no activity that affects a wetland
shall be permitted if a practicable alternative
that has less impact on the wetland is available.
If there is no other practicable alternative,
impacts must be mitigated.
Any facilities will be constructed, fenced, posted, and
operated in accordance with this requirement. All workers
will be properly trained, These standards would apply to
any treatment or disposal facility operated on-site.
A groundwater monitoring program is a component of all
alternatives. RCRA regulations will be considered during
development of this program.
Those parts of the regulation concerned with long-term
monitoring and maintenance of the site will be considered
during remedial design.
Proper respiratory equipment will be worn if it is impos-
sible to maintain the work atmosphere below the concen-
trations.
All appropriate safety equipment will be on-site. In
addition, safety procedures will be followed during
on-site activities.
These requirements apply to all site contractors and sub-
contractors and must be followed during all site work.
Soils that fail the
treated to the Best
levels before being
onto the land.
TClP extraction procedure will be
Demonstrated Available Technology
placed into a landfill or replaced
If a leachate collection system is installed and the
discharge is sent to a POTW, a permit would be obtained
from the POTW prior to discharge.
During the final selection of remedial alternatives, the
effects on wetlands must be evaluated.
3990B
-------
Ta.. 16
(cont i nued )
ARAR's
Requirement Synopsis
Action to Be Taken to Attain ARAR's
TSCA - PCB requirements
(40 CfR 761)
This regulation outlines the requirements for
disposal of materials containing PCB's.
Any alternative that includes treatment or disposal will
have representative samples analyzed for PCB's. PCB
treatment would be performed off-site.
CAA-NAAQS (40 CfR 52)
This regulation specifies maximum primary and
secondary 24-hour concentrations for particulate
maller.
fugitive dust emIssions from site excavation activities
will be maintained below standards using dust suppres-
sants, if necessary.
fish and Wildlife Coordination
Act 16 USC661 et seq.
This act requires that before undertaking any
federal action that causes impoundment, diver-
sion, or other modification of any body of water
the following agencies must be consulted: the
appropriate state agency exercising jurisdiction
over wildlife resources and the U.S. fish and
Wildlife Service.
Before discharging treated groundwater to surface water,
the appropriate agencies will be consulted.
Protection of Archeological
Resources (32 CfR Part 229,229.4:
43 CfR Parts 107, 171.1-171.5)
This regulation develops procedures for the
protection of archeological resources.
If archaeological resources are encountered during soil
excavation, work will stop until the area has been
reviewed by federal and state archaeologists.
Contaminated materials will be packaged, manifested, and
transported to a licensed off-site disposal facility in
compliance with these regulations.
DOT Rules for Transportation of
Hazardous Materials (49 CfR Parts
107, 171.1-171.5)
This regulation outlines procedures for the
packaging, labeling, manifesting, and trans-
porting of hazardous materials.
N.H. DES New Hampshire Solid
Regulations He-P 1901.
N.H. DES - Air Pollution Regula-
tions AIR 604-604, 1002
This regulation provides standards for solid
waste disposal facilities.
Standards for solid waste disposal facilities will be
followed.
This regulation outlines the standards and
requirements for air pollution control in the
State of New Hampshire: all provisions, pro-
cedures, and definitions are described.
Particulate matter emissions from site activities must
be maintained within acceptable limits.
New Hampshire Wetlands Board, RSA
463-A, and RSA 149-8a.
These regulations are promulgated under the NH If applicable alternatives involve removing, filling,
Wetlands Board, which regulates dredging, filling, dredging, or altering a New Hampshire-defined wetland.
altering, or polluting inland wetlands.
These regulations outllne the crileria for the
construction, operation, and 'maintenance of a
new facility or increase in an existing facility
for the storage, treatment, or disposal of
hazardous waste.a
New Hampshire Hazardous Waste
RSA HIA/He-P 1905.
These regulations supplement RCRA hazardous waste regula-
tions and, therefore, must also be'considered at the
Coakley Landfill "ite.
aA more detailed description of this regulation and its requirements can be found in Appendix H.
2-8
-------
Table 16
(continued)
ARAR's
Action to Be Taken to Attain ARAR's
Requirement Synopsis
Groundwater Protection limits
RSA 149:8, III; N.H. Admin Code
Ws Ch. 410
Surface Water Protection Standards
RSA Ch. 149, N.H. Admin Code
Ws Ch. 430
RSA 149:4-a; N.H. Admin Code
Ws Ch. 900. part 904, Pre-
treatment Standards for
Publicly Owned Treatment Works
( POTW)
N.H. Safe Drinking Water Act
RSA Ch. 148-B; N.H. Admin Code
Ws Part 300
These provisions establish criteria for
groundwater protection.
These provisions establish criteria for surface
water protection.
These provisions establish standards for
discharges to publicly owned sewage treatment
fad 1 i ti es .
These provisions establish state drinking
water standards and govern the location and
operation of public water systems.
Remedial alternatives involving discharges to groundwater
must comply with these standards.
Remedial al~ernatives involving the discharge to
surface water of contaminants, treated effluents
treated groundwater must comply with these standards.
Remedial alternatives involving discharges of
treated groundwater or other effluent to any POTW
must comply with these standards.
or
Remedial alternatives involving the establishment
of alternative public drinking water supplies-must
comply with these standards.
3990B
2-9
-------
TABT ,J:' 17
I. CONTAMINANT A LOCATION-SPECIFIC
APPLICABLE OR RELE.VAN'r AND APPROPRIATE
STATE REQUIREt1EN'i'S, COAKLEY LANDFILL SITE, NORTH HAHPTON,
NEW HN1PSHIREl
Applicable2
Relevant & Appropriate2
A. GROUNDWA'rER:
"
1.
RSA 149:8,UI;
N. H. Admin. ws
Ch. 410 -,
Protection of
Groundwater.
x
a.
Ws 4l0.05(a)
Discharges to
Groundwater.
x
b.
Ws 410.09
Groundwater
Discharge
Criteria,
incorporating
by reference
WS Part 302
(Maximum
Contaminant
Levels [r-LL's]
and Suggested
1'10 Adverse
Response
Levels
[ SNARLS] )
'.
x
1
See Appendix A for synopsis of each requirement and discussion of action necessary to
attain ARAR's.
2
The absence of any symbol in the columns designated "Applicable" or "Relevant and
Appropriate" indicates that, in the circumstances present at this site, the requirement is
-------
.~ 11
I. CONTAMINAN'l' AND LCCA'l'ION-SPECIFIC
APPLICABLE OR RELEVANT AND APPROPRIATC
STATE REQUIREMENTS, COAKLEY LANDFILL SI'fB, NORTH HAMPTON, NEW HAI1PSHIR/:)
Applicable
Relevant & Appropriate
c. Ws 410.10,
Additional ."1: X
Ground\oJater .
Criteria.
d. vis 410.05(e)
Groundwater X
Quali ty
Criteria;
Health-based
groundwater
protection
standards.
e. Ws 410.05(9)
Grounawater
Quality X
Criteria;
l.JOndegradation
of Surface
~later .
..
-------
TABLE 17
I. CONTAMINANT AND L( ION-SPOCH'IC
APPLICABLE OR RELEVANT A~D APPROPRIA'~E
STATE R~UIREMEN'rS, COAKLEY LAlIDFILL SITE, NORTH HAt1PTON, NEW HANPSHIREl
Applicable
Relevant & Appropriate
B. SURFACE \vATER
1.
RSA 149:8,1 -
Enforcemel1t of
Surface \-1ater
Classifications.
x
2.
\'Is Ch. 400,
part 437 -
Water Quality
Standards -
Fish Life
x
3.
\1S Ch. 400,
part 439 -
Antidegradation
policy.
x
C. WE'rLANDS It-1PACT
1.
RSA l49:8-a,
Dredging and
Control of
RU n-Of f: v1s
Ch. 400 Part
415, Dredging
Rules.
.
x
-3-
-------
'.L~ 11
I. CONTAMINAN'f AND LCCA'l'ION-SPECIFIC
APPLICABLE OR RELEVANT AND APPROPRIAT~
STATE REQUIREMENTS, COAKLEY LANDFILL SITE, NORTH HAI1P'l'ON, NEll HAMPSHIREI
Applicable
Relevant & Appropriate
2.
Fill and
Dredge in
Vletlt:mds, RSA
Ch. 483-A and
Wt. Ch. 30D,
Criteria and
Conditions.
x
D. AIR EMISSIONS
1. RSA dl. 125-C,
Air Pollution
Control; N.H.
Admin. Code
Air Ch. 100
Parts 604
through 606;
Part 1002.
E. HIS'raRIC
PRESERVATION
x
1.
New Hampshire
Historic
Preservatiol'l
Act, RSA 227-C.
2.
Local Historic
Districts, RSA
3l:89-a-31:89-k.
".
-------
'~ 11
I. CONTA1lINANI' ANr . 'X:ATION-SPECIFIC
APPLICABLE OR HELE\i. AND APPROPHIATE
STATE REXlUIREf-1ENTS, COAKLEY LANDFILL SITE, NORTH HAr'1PTON,
NIJ-J HAMPSHIREl
Appl icable
Relevant & Appropriate
E. HAZAHDOUS WASTE
REXlUIREMENTS
"
N.H. Hazardous
Haste rv:anagement
Act, RSA Ch.
147-A; Hazardous
Waste Hanagement
Rules, N.H. Admin.
Rules He-p Ch.
1905.
x
G. SOLID WASTE
REDU IREl1ENTS
N.H. solid Waste
r1anagement Act,
RSA Ch. 149-M;
Solid \oJaste
Management Rules,
N.H. Admin. Rules
He-P Ch. 1901.
x
'.
-------
'.ffi.t1Lt,; 1. t:S
II. AC'TION-SPF.CIFIC
APPLICABLE on RELEVANT AND APPROPRIATE
STATE REQUIREf'tEN'rS, COAKLEY LANm'ILL SITE, NORTH HNIJ?TON,
N£:.W HPJ1PSHIREl
Requirement
NO
Action
g:-l
capping
SC-3
capping/On-
Site Treatment
& Disposal
SC-4
capping/On-
Site Treatment
Off-Site TSD
g:-5
On-Site/Treatment
&. Disposal (SH &
Grwater)/Capping
SC-6
NO Action
Mt1-1
Groundwater
Treatment/
Disposal
t'l11-2
Alternate
Water
Supply
Hf1- 3
A. HAZARDOUS WASTE
REQUIRE11EfITS
1. RSA Ch. 147-A, X X X X K X X X
New Hampshire
Hazardous
\Jaste
f1anal)ement
Act; N.H.
Admin. Coae
lIe-P Ch. 1905.
a. Hazardous
Waste Facility X X X X .X X X X
Security
requirements,
He-P
1905.08(d),
incorporating
by reference
40 C.F.R.
~264.l4.
b. General
Inspection X X X . X X X X X
Requirements,
He-P .
1905.08 (d)( 4)(e:)
KEY: X - Applicable
0 - Relevant and Appropr ia te
The absence of any symbol in the column below a designated alternative indicates that the requirement
is not applicable, or relevant and appropriate, with regard to the alternative.
-------
TABLE 18
II. AC~I jP8CIfIC
APPLICABLE OR HELEV/\(']'J' AND AlJPHOPRIAT8
SfA'fE REQUIREMENTS, COAKLEY LANDFILL SITE, NOI~TH ilNWTOn, NLW HJll'IPSIIIIU)
Requirement
NO
Action
OC-l
capping/On-
Site Trp.atment
& Disposal
SC-4
capping
SC-3
capping/On-
Site Treatment
Off-Site TSO
SC-5
On-Site/Treatment
& Disposal (£"l &
Grwater)/Cap?ing
SC-6
NO Action
Mr.I-l
Groundl.Jater
Treatment/
oisp::>sal
1111- 2
Alternate
\'iat e r
Supply
1-11-1-3
incorporating
by reference
40 C.F.R.
~264.l5.
c.
Personnel
Training, He-P
1905.08(a)(4)(e)
incorporating
I)y reference
40 C.F.R.
~264.16.
x
x
x
d.
Location
standards,
iie-P
1 <)05.08 (d) (4 ) (g)
incorporating
by reference
40 C.F.H.
~264.l8 and
lie-P
1905.08(2)j.
x
x
x
e.
preparedness
and prevention
Requirements,
Ile-P 1905.08
(d)(4)(h)
incocporating
by reference
40 C.P.?
~ 264 I Su bpa r t
C.
x
x
x
x
x
x
-7-
x
x
x
x
x
x
x
x
x
x
x
-------
TABLE 18
II. ACi'IOtJ-SPECIF IC
APPLICABLE OR HELINANl' AND APPHOPHIATE
S'rATE REQUIREl'tENTS, COAKLEY LANDFILL SITE, NORTH! 1AJ'-1PTON, NEiv HN1PSHIREl
Capping/On- Capping/O~- On-Site/~reatment (;rouncl\.Ja Cf? r Alten,(!;
NO Si te Trea tment Site Treatment & Di sposa 1 (Si'J ~ Treatment/ \'Idte(
I{eguirement Action capping & Disposal Off-Site TSD Cnlater )/Capping I~O ~.ction Disposal Supply
SC-1 SC-3 SC-4 SC-5 SC-6 ~IT-1-1 f11-1-2 MI-1-3
f. Contingency
Plan, He-P X X X X X X X X
1905.08(d)(4)(i
) incorporating -
by reference
40 C.F.R.
264, Subpart
D.
g. Groundwater
protection,
fle-P 1905.08 X X X X X X X x
(d)(4)(j),
incorporating
by reference
40 C.F.R.
264, Subpart
F.
h. Closure and
Post-Closure,
He-P X X X X X X X x
1905.08(d)(4 )(k
) incorporatins
by reference
40 C.F.R.
~264, SUbpart
G.
l. '~'ransfQr ot
facility, X X
He-P X X X X X x
1 ~U5 .08 (d)( 5) .
-------
TABT
18
II. ACTIorl-SPECIFIC
APPLICABLE. Of{ RELEVANT AND APPROPRIATE
STATE RECJUIREt-:ENTS, COAKLEY LANDFILL 5I1'E, NORTH H!\i'JP'l'Otl, N~\'J H!..!'\PSHII~El
Requirement
No
P.ct ion
X-I
Capping
5C-3
capping/On-
Site Treatment
& Disposal
SC-4
cappin~/On-
Site Treatment
ot f -Si te TSD
SC-5
On-$i te/'i'rea t/llent
& Di SpJ:>d 1 (SiJ &
Grwater)/Capping
SC-6
NO Action
£1i1-1
GroUflU',vij te r
TreatllP2nt/
Disposal
!'u.)-2
id r.e r ilJ L
I'later
Su lJ[Jl y
l'U.}-j
j. Monitoring,
lIe-p X X X X X X X X
1905.0U(d)(6);
k. Publ ic
l'btification
plan, He-P 0 0 0 0 0 0 0 0
1905.08(d)(9).
1. General
environmental
standards, X X X X X X X X
He-p
1~05.08(d)(l).
ro. C~neral design
standards, X X X X X X X X
He-P
lY05.08(d) (2).
n. Technical
Standards for X X X 'x X X
Landfills,
He-p
1905.08 (f) (l ) (f)
incorporating
by reference
40 C.F.R.
~264, Subpart
N, and He-p
lY05.08(f)(2)(d)
-------
TABLE 18
II, ACTION-SPDCIPrC
APPLICABLE Of{ Hl:~r.l:.V!\N'l' AND APPHOI'In lI'l'r.
HEQUIREf'lENTS, c..'OAKLEY L.I\NUFILL SITE, tJO{{,l'i1 HNIJ>'~'OI'J,
STATE
m:\-i HNiP:JI!] PEl
Requirement
No
Action Capping
SC-l SC-3
Capping/On-
Site Treatrrent
& Disp:>sal
SC-4
capping/On-
Site Treatment
Off-Site TSD
SC-5
On-Si tej'l'reatment
t. Di spJsal (S\J &
Grwater)/Capping
92-6
IJO Action
l'll'1-1
Groundwctter
'i'rec1unent/
Dis[:-'Osal
t"Jt'1- L
Alternate
\':a t e r
Supply
t'll'l- 3
o.
Additional
Technical
Standards for
'i'reatmellt He-P
1 ~05. 08 (f) (2 )
(a) .
x
p.
He-P
1905.08(f)(2)(c)
Storage
Stanaaros.
x
q.
Technical
Standards for
Haste Piles,
He-p
1905.08(f) (1) (d)
incorporating
by reference
40 C.F.R. 264
Subpart L,
r,
Technical
Standards for
Use and
r'lanagement of
Containers,
He-P
1 ~05 ,08 (f) ( 1 ) (a )
incorporating
I)y reference
40 C.F.R, 264,
"ultpa r t I.
x
x
x
x
x
x
-10-
x
x
x
x
"
-------
TAB!
18
II. ACTI'ON-SPOCIFlC
APPLICABLE OR HELEVAl-rf AND APPHOPIri'i'!Eh' J1Ni;'>~;HIHEl
Capping/On- Capping/On- On-Si te/'l'reatment ---
(; rOlJrJ(J'dd L '.'::- ;"lr:0frl.:,"
No Site Treatment SHe TreatlO~nt & Di sr:OSrj 1 (S"W & '~'re()tlilent/ \-!i:!ter
Requirement Action capping & DisfX)sal Off-Si te TSD Grwater)/Capping NO Action DisfX)sal Supply
&;-1 SC-3 SC-4 SC-5 5(-6 ~lI'l-l f'11 J- 2 fii-l- 3
S.
Technical
Standa ras for
Tanks, He-p
1905.08(f) (1) (b)
incorporating
by reference
40 C.F.R. 264,
SUbpart J.
t.
Scandards for
Generators,
He-p 1905.06.
lJ.
f1anifest i ng
Hequiremencs
Ife-p 1~05.04.
v.
packaging and
Labelling
Hf.:!qu i rement:~,
He-p lY05.05,
incorporating
by reference
iJ. H. Admin.
Cod~ saf-C-GOO
and 40 C.F.R.
~j~ 172,173,
178, and 179.
x
x
x
x
x
x
x
x
:\
x
x
x
x
x
x
x
x
x
..
r ..
-------
TABLE 18
II. ACTIOI~-SPECIFIC
APPLICABLE OR RELEVANl' AND APPROPRIATE
STATE REQUIKFl1ENTS, COAKLEY LANDFILL SITE, NORTH HN1P'I'ON,
[JEiV HAftUJSfJIREl
cappingjOn- CappingjOn- On-Site/7reatment Groundlvd te r AlternCit(:'
No Site ".'reatment Site Treatment (, Disposal (SI-J [, 'l'reatllienc./ \-J
-------
TABLE
18
II. ACTION-SPEC.
APPLICABLE OJ{ RELEVANr AND APPROPRIATE
STATE REQUIREMENTS, COAKLEY LANDFILL SITE, NOR'i'H HAHPTON, [WI'I HjIJ'U)SHIREl
Requirement
No
Action
$(::-1
capping
SC-3
Capping/On-
Site Treatm2nt
& DisfX)sal
SC-4
cappingjOn-
Site Treatment
Oft-Site TSD
5C-5
On-Site/Treatment
& Disposal (SW &
Gn-Jater )/Capping
SC-6
NO Action
1'11'-1-1
Groundwater
Treatment/
Disposal
~11"1-2
AlternatE:
via t e r
Supply
111'}-)
1. RSA
149:8,III:
N.H. Admin X
Cooe Ws Ch.
410.
E. AC'l'ION-SPEC I FIC
SURFACE WATER
PROrOC'i'!ON
S'J.'P, NDAHDS
1. RSA Ch. 14 Y;
N.H. Admin
Code WS Ch. X
430.
') RSA 149: 4-a;
...
N.H. Admin.
Code Ws Ch.
YOO, Part
904,
pretreatment
X
X
X
X
X
x
x
x
-13-
x
x
".
x
X
x
x
x
x
-------
TABLE 18
II. ACTION-SPEC I PIC
APPLICABLE OR RELEVANT AND APPROPRIATE
STATE REQUIREt.1ENTS, COAKLEY LANDf'ILL SITE, NORTH HA[1PTON,
NEW HAl1PSHIREl
Requirement
NO
Action
SC-1
capping
SC-3
cappingjOn-
Site Treatment
& Disposal
SC-4
cappingjOn-
Site Treatment
Off-Site TSD
SC-5
On-SitejTreatment
& Di sposal (StJ &
Grwater)jCapping
SC-6
NO Action
Ml1-l
Groundwater
Treatmentj
Disposal
t-1l1-2
Alternate
Water
Supply
[11"1-3
Standards for
publ icly
owned
treatment
works (POI'W).
F. STANDARDS FOR
PUBLIC W.l\TER
SYSTfJ1S
1. N.H. safe
Drinking
Water Act, X
RSA 148-8
".
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APPENDIX C
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COAKLEY LANDFILL
RESPONSIVENESS SUMMARY
TABLE OF CONTENTS
Preface. . . . .
. . . . .
. . . . . . .
. . . .
. . .
. . .
I.
OVERVIEW OF REMEDIAL ALTERNATIVES CONSIDERED IN THE
FEASIBILITY STUDY AND PROPOSED PLAN . . . . . . . . . .
II.
SITE HISTORY AND BACKGROUND ON COMMUNITY INVOLVEMENT AND
CONCERNS. . . . . . . . . . . . . . . . . . . . . . . ...
III. SUMMARY OF COMMENTS RECEIVED DURING THE PUBLIC COMMENT
PERIOD AND EPA RESPONSES TO THESE COMMENTS. . . . . . .
A. Summary of Resident and Citizen Group Comments
1. Comments Regarding EPA and State Response to
site Cleanup. . . . . . . . . . . . . . . . .
2. Comments Regarding site Testing Procedures
3. Comments Regarding Remedial Alternatives. . .
4. Comments Regarding Health Risks. . . . . . .
5. Comments Regarding PRPs . . . . . . . . . . .
Summary of Potentially Responsible Parties
Comments. . . . . . . . . . . . . . . . . . . . .
1. Evaluation of site Characterization. . . . .
2. Evaluation of EPA's Preferred Alternative
(SC- 4) . . . . . . . . . . . . . . . . . . . .
Evaluation of Other Remedial Alternatives
Alternative Proposal for Staged Remedial
Actions. . . . . . . . . . . . . . . . . . .
B.
3.
4.
ATTACHMENT A - COMMUNITY RELATIONS ACTIVITIES CONDUCTED AT
THE COAKLEY LANDFILL SUPERFUND SITE IN NORTH
HAMPTON, NEW HAMPSHIRE
ATTACHMENT B - POTENTIALLY RESPONSIBLE PARTY COMMENTS
ATTACHMENT C - TRANSCRIPT OF
PUBLIC HEARING
THE
APRIL
3 I
1990
INFORMAL
ATTACHMENT D - SUPERFUND TECHNICAL ASSISTANCE GRANTS
i
1
2
4
4
4
7
9
16
17
18
18
25
29
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COAKLEY LANDFILL RESPONSIVENESS SUMMARY
Preface
The U. S. Environmental Protection Agency (EPA) held a 60 day
public comment period from March 16, 1990 to May 14, 1990 to
provide an opportunity for interested parties to comment on the
Remedial Investigation (RI), Health Assessment, Feasibility Stlidy
(FS) and the Proposed Plan prepared for the Coakley Landfill
Superfund site (the Site) in North Hampton, New Hampshire. EPA
made a preliminary recommendation of its preferred alternative for
site remediation in the Proposed Plan issued on March 2, 1990,
before the start of the public comment period. .
The purpose of this Responsiveness Summary is to document EPA's
responses to comments and questions raised during the public
comment period. EPA considered all of the comments summarized in
this document before selecting a final remedial alt~rnative to
address contamination at the Site.
This Responsiveness
sections:
Summary
is
organized
into
the
following
I.
overview of Remedial Al ternati ves Considered in the
Feasibilitv Studv and ProDosed Plan - This section
briefly outlines the remedial alternatives evaluated in
the FS and Proposed Plan, including EPA' s preliminary
recommendation of a preferred alternative.
II.
site Historv and Backqround on Communitv Involvement and
Concerns - This section provides a brief Site history,
and a general overview of community interests and
concerns regarding the site.
III. Summarv of Comments Received Durina the Public Comment
Period and EPA ReSDonses to These Comments This
section summarizes and provides EPA's responses to the
comments received from residents and other interested
parties during the public comment period. Additionally,
comments received from the Potentially Responsible
Parties (PRPs) are summarized and EPA's responses to the
comments are provided.
IV.
Remainina Concerns - This section summarizes comments
raised during the public comment period that cannot be
fully addressed at this stage of the Superfund process
.,' but which continue to be of concern during the design
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and implementatio~ of EPA' s selected remedy for the
site. EPA responds to these comments and will address
these concerns during the Remedial Design and Remedial
Action (RDjRA) phase of the cleanup process.
Attachment A - List of cc~unity relations activities that
EPA has conducted to date at the site.
Attachment B - Potentially Responsible Parties' comments.
Attachment C - Transcript of the April 3, 1990 informal
public hearing on the Site, held in North Hampton, New
Hampshire.
I.
OVERVIEW OF REMEDIAL ALTERNATIVES
FEASIBILITY STUDY AND PROPOSED PLAN
CONSIDERED
J.N
THE
Using information gathered during the Remedial Investigation (RI)
(an investigation of the nature and extent of both onsite and
offsite contamination) and the Risk Assessment (an assessment of
the potential risks to human health and the environment associated
with site contamination) , EPA identified several cleanup
objectives for the Site.
The primary cleanup objective is to reduce the risks to public
heal th and the environment posed by exposure to the source of
contamination onsite or to contamination that may potentially
migrate, offsite. Cleanup goals for groundwater and soils are set
at levels that EPA considers to be protective of public health and
the environment.
After identifying the cleanup objectives, EPA developed and
evaluated potential cleanup alternatives, called remedial
alternatives. The Feasibility Study (FS) describes the remedial
alternatives considered to address contamination from soil waste,
onsite groundwater and sediment contamination and offsite
migration. The FS also describes the criteria EPA used to narrow
the range of alternatives to five potential source control (SC)
remedial alternatives. The three potential management of
migration (MM) remedial alternatives reviewed in the FS are not
addressed by this Record of Decision. However, an additional
study and a second Record of Decision will follow in order to
properly define the extent of contamination and, subsequently, to
remediate the migrated contamination related to the Coakley
Landfill.
EPA's preliminary recommendation of a preferred alternative to
address the Site contamination involves consolidation of the solid
waste and sediments in the wetlands followed by capping of the
landfill, collection and treatment of landfill gases and the
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{-
2
REMEDIAL ALTERNATIVES EVALUATED IN THE FS
The five remedial alternatives considered for source control by
EPA are listed below. The February 1990 Proposed Plan should be
consulted for a detailed explanation of these remedial
alternatives as well as EPA's preferred alternative:
ALTERNATIVES TO ADDRESS SOURCE CONTROL
Alternative SC-1:
No Action
Alternative SC-3:
Consolidation and Capping
Alternative SC-4:
Capping/Onsite Groundwater Treatment/Onsite
Disposal (EPA has recommended this as the
preferred alternative.)
Alternative SC-5:
Capping/Onsite Groundwater
Pretreatment/Offsite Groundwater Treatment and
Disposal
Alternative SC-6:
Onsite Solid Waste/Groundwater Treatment and
Disposal/capping
II. SITE HISTORY AND BACKGROUND ON COMMUNITY INVOLVEMENT AND
CONCERNS
The Coakley Landfill Superfund Site is situated on approximately
92 acres of land within the Towns of Greenland and North Hampton,
New Hampshire. It is located west of Lafayette Road (U.S. Route
1) and bordered on the north by Breakfast Hill Road. The landfill
itself covers approximately 27 acres and is situated within the
southernmost portion of the Site.
In 1971, the New Hampshire Department of Public Health granted the
Town of North Hampton a permit to operate a landfill on the
Coakley Site. The Coakley Landfill accepted municipal and
industrial waste from the Portsmouth area from early 1972 through
1983 and incinerator residue generated by an incinerator located
at Pease Air Force Base from 1982 through 1985. The landfill
stopped accepting material in July 1985. A temporary cap was
eventually placed on the landfill.
In early.1983 the New Hampshire Department of Environmental
Services (DES) (formerly the Water Supply and Pollution Control
Commission, or WSPCC) received a complaint from a resident of
Lafayette Terrace, near the southeastern corner of the Coakley
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3
DES analysis determined that the well
volatile organic compounds (VOCs).
Subsequent sampling of resiGential wells by DES detected
additional areas of VOC contamination to the south, northeast, and
southeast, of the Coakley Landfill site. As a result of these
findings, water supply distribution lines were extended into the
area in March 1983.
was
contaminated with
In December 1983 the site was placed on EPA's National Priorities
List (NPL) making it eligible to receive Federal superfund money
for investigation and cleanup. The RI was conducted at the Site
from April 1986 to May 1987. -
In general, results of the RI indicated that VOCs and metals were
observed to be the predominant contaminants within the landfill
and in the overburden and bedrock wells under and immediately
adjacent to the landfill.
Using data collected during the RI, EPA developed a
included the initial screening of the source control (SC)
alternatives and the management of migration (MM)
alternatives.
FS that
remedial
remedial
Foremost concerns of Town residents focus on the potential health
risks to residents living near the Site, the delay in action
toward site cleanup, the cost and responsibility for cleaning up
the Site, and the proposed cleanup method. Residents believe that
contamination from the Site caused and may cause serious health
problems in the area and feel that the health assessment completed
in October 1988 by Agency for Toxic Substances and Disease
Registry (ATSDR) is insufficient. Residents are also concerned
that continued delays in site cleanup may result in further
migration of contamination from the Site, causing an increase in
potential health risks. Another concern of area residents is cost
and responsibility for Site cleanup. Residents feel that the
state and EPA are spending too much time and money to determine
cost and responsibility rather than taking action to clean up the
Site. Finally, many residents have expressed concern that EPA's
proposed remedial alternative will not address site cleanup
effectively.
The coakley Landfill Steering Committee (Committee) raised
concerns about migration and commingling of contamin\lti::;n, the
cost of the remedial action, and overestimation of the risk
assessment. In particular, the Committee feels that the selected
remedy will draw in contamination from sources other than the
Coakley Landfill. The Committee also feels that the selected
remedy is too costly in that-it incorporates groundwater treatment
without justification. The Committee claims that the risk
assessment is exaggerated because of overestimates of exposure to
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I
,4
A complete list of community relations activities conducted at the
site is included in Attachment A at the end of this document.
III. SUMMARY OF COMMENTS RECEIVED DURING THE PUBLIC COMMENT PERIOD
AND EPA RESPONSES TO THESE COMMENTS
This Responsiveness Summary summarizes the comments received
during the public comment period held from March 16, 1990 to May
14, 1990. Ten sets of written comments were received: five from
individual residents (including a petition with f4 signatures
presented by a local youth), three from representatives of
citizens' groups (including a petition with approximately 568
signatures from the citizens' group, C.O.A.S.T), one from a public
drinking water supplier, and one from the Coakley Landfill
Steering Committee (PRP comments). Five sets of the written
comments received by EPA, were also presented orally at the
informal public hearing held on April 3, 1990. In addition, four
other people made comments orally at the informal public hearing.
All of these comments are summarized below. The PRP comments are
included as Attachment B. A copy of the transcript from the
informal public hearing is included as Attachment.:: of this
document and is available in the Administrative Record located at
the site information repositories at the North Hampton Public
Library North Hampton, New Hampshire and at the EPA Records
Center, 90 Canal Street, Boston, Massachusetts.
A.
Summarv of Resident and citizen Group Comments
Comments from residents and concerned citizens' groups are
summarized below. The comments are organized into the following
categories:
1. Comments Regarding EPA and State Response to site
Cleanup
2. Comments Regarding site Testing Procedures
3. Comments Regarding Remedial Alternatives
4. Comments Regarding Health Risks
5. Comments Regarding PRPs
1.
Comments Regarding EPA and State Response to site Cleanup
Comment a: Several commentors stated that EPA and the State
of New Hampshire are not addressing site cleanup in a timely
manner and requested that cleanup begin immediately to avoid
possible spread of contamination to the municipal water
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5
EPA Response: EPA recognizes public frustration with the
lengthy Superfund process; however, EPA and the State are
required to conduct the investigation of the Coakley Landfill
in accordance with the Superfund Law (CERCLA) and with the
regulations and guidance documents promulgated under that
law. The investigation and cleanup process is complex and
lengthy. This ensures thoroughness in addressing site
contamination. EPA evaluates all Superfund sites dur.Lng
various investigatory stages to ensure that no releases occur
which could exacerbate any potential public health or
environmental problems. Should such a release occur, or if
one is likely to occur, EPA can take immediate action under
its Emergency Removal Program.
The immediate threat to the local public health is from
consumption of groundwater from private wells in the area of
the Coakley Landfill. This threat was eliminated when the
Town of North Hampton extended public drinking water lines to
affected residents of Lafayette Terrace in March 1983 and to
Birch and North Roads in 1986. The Rye Water District
completed a water main in 1983 along Washington and Dow
Lanes. Households choosing not to hook up to public waters
and which were located within a potential impact area were
moni tored during the RI/FS process. They continue to be
sampled to date.
In 1988 concerns were raised regarding incinerator ash
exposed by wind and rain erosion at the surface of the
landfill. Following testing by the EPA and a health risk
analysis of the site by the Agency for Toxic Substances and
Disease Registry (ATSDR), the site I s temporary cover was
repaired under an Administrative Order issued by the NH DES.
Comment b: One commentor expressed concern that the State
might be withholding information about site contamination,
has not been responsive to citizens' requests for information
about the site, and has generally ignored the needs and
demands of local residents.
EPA ReSDonse: This comment is directed at the State, not
EPA. However, EPA is not aware that NH DES is withholding any
information regarding the extent of contamination at the
Coakley Landfill Site.
NH DES ResDonse: All information generated by NH DES with
respect to the Site, including domestic well water quality
analysis, health risk assessments, inspection reports, and
investigation reports done by state or federal agencies are
available to the public, either at the Concord offices of the
NH DES or at the Site information repository in the North
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6
office can be made through the Waste Management Division at
271-2919. Some documents are not available to the public due
to their enforcement sensitive nature or as specified by
state law.
Comment c: One commentor requested that the qualifications
and past experience of the project managers be placed in the
public record as proof of qualifications for the position.
EPA Response: EPA does not consider it appropriate or
necessary to release personal information regarding its
employees including qualifications of Superfund site
managers. Region I has established a management proc~ss for
evaluating major decisions by review teams on all Superfund
sites. These review teams consist of employees with a range
of expertise to ensure appropriateness and conformity with
the Superfund Law and its regulations.
Comment d: One commentor stated that more than the Superfund'
Law and regulations should be used to resolve the problems at
the site. He wanted EPA to report on other regulations,
procedures, state and local agencies, and other organizations
that could be used to analyze and implement remedies for site
cleanup.
EPA Response: The Superfund Law requires EPA to comply with
all federal and state laws which are applicable or
appropriate and relevant to the site cleanup. Included in
Tables 2-1, 2-2 and 2-3, pages 2-2 to 2-9 of the Feasibility
Study are extensive lists of all the various laws,
regulations and guidances which have been identified and
included in the decision-making process for the Coakley
Landfill.
In addition to identifying these state laws, NH Department of
Environmental Services has been an integral part in
developing technical information at the site and in choosing
the preferred alternative. An environmental engineering
firm, Roy F. Weston, Inc., performed the RI/FS under a state
contract.
Local agencies, other organizations and interested parties
were given the opportunity to comment during designated
comment periods as prescribed by the Superfund Law. Finally,
the EPA held a Public Comment Period lasting 60-days from
March 16 to May 14, 1990 to accept comments on EPA's
preferred alternative as outlined in the Proposed Plan and
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7
Comment e: A commentor asked if the transcript from this
meeting, the chemical analysis results from samples taken at
the landfill, and other EPA findings would become public
information.
EPA Response: Information concerning the site has been
available since the Administrative Record was issued in May,
1988. The transcript of the April 3, 1990 Informal Public
Hearing is attached to this document in Attachment C.
Validated results of chemical analyses performed at the site
for the RI/FS are in the Administrative Record. Results of
additional sampling performed on local residential wells can
be obtained by contacting the NH DES in Concord, New
Hampshire. The Administrative Record is located at the North
Hampton Library, North Hampton, New Hampshire and at the EPA
Records Center in Boston, Massachusetts.
2.
Comments Regarding site Testing Procedures
Comment a: Two commentors questioned whether the State and
EPA documented well testing on a regular basis from 1983 to
the present. The commentors stated that wells RW-25, 26, 27,
and 28 were tested in February and March of 1983, and that
these were the only tests ever actually done.
EPA Response: The dates for the various sampling events at
the site during the RI, the resulting data and additional
sampling are in the RI. This information is included in the
Administrative Record.
NH DES Response: Residential wells identified in the
Remedial Investigation as RW-25, 26, 27 and 28 were all wells
on Lafayette Terrace. RW-25, 26 and 28 were sampled twice in
1983, RW-27 was sampled three times in 1983. A fourth
sampling of RW-27 reported in Table 37 in the RI and shown on
Figure No. 20, listing another analysis in 1987, is not
substantiated by records in the project files. Although
there was a sampling round taken July 28 and 29, 1987 neither
the chain of custody form nor the lab reports mention a well
sampled at Lafayette Terrace.
Comment b: One cammentor questioned the accuracy of
contamination levels reported based on testing done while the
ground was frozen. Tbe commentor also asked what possible
health risks may exist from having drunk contaminated well
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8
EPA ReSDonse: Seasonal weather conditions do not adversely
effect the quality and accuracy of groundwater data
collection. Fluctuations in air and near surface soil
temperatures have minimal effect on groundwater quality.
The health risk from drinking the contaminated groundwater
over an extended period of time has actually been calculated
in the risk assessment portion of the RI. Risk estimates
were based on conservative assumptions. Specifically, the
health risks for consumption of groundwater were based on an
adult consuming two liters of water per day for seventy
years. Since the Coakley Landfill started operation in 1972
and local residents were supplied municipal drinking water by
March 1983, any possible exposures from drinking contaminated
groundwater during this period are expected to pose risks
less than those quantifi9d in the r~sk assessment. The ATSDR
stated there is no test available to evaluate past exposure.
Comment c: A commentor wanted to know specifically what was
dumped into the North Hampton landfill by government
installations.
EPA ReSDonse: Ash from an incinerator operated by the City
of Portsmouth was disposed of at the Site. Trash and wastes
from surrounding communities as well as from Pease A.F.B.
were sent to this incinerator. EPA has reason to believe
that Pease AFB and Portsmouth Naval Yard disposed of material
at the Site. Specifically what was dumped at the site is
currently considered enforcement sensitive and cannot be
released at this time.
Comment d: A commentor expressed concern about contamination
found in a monitoring well abutting his property. He had
planned to dig two new water supply wells on his property but
is worried about possible contamination of these new wells.
The commentor also expressed concern that he was unable to
sell or rent his property due to its proximity to the Coakley
Landfill site.
EPA ReSDonse: EPA believes contaminants in the wells located -
to the north/northeast of the Coakley Landfill property may
come from other sources. Trihalomethanes, which were found
in the commentor's drinking water well, were not found in the
groundwater under and around the Coakley Landfill. Also,
groundwater flow from the landfill tends to move in a
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9
3.
Comments Regarding Remedial Alternatives
Comment a: Several commentors asked if EPA has analyzed the
risk of cap failure or damage and the procedures necessary to
maintain protectiveness in such a situation.
EPA Resoonse: EPA is aware that cap failure or damage may
occur. However, proper cap installation and maintenance will
extend the cap's life significantly. Specific details of
operation and maintenance will be directly addressed in
Remedial Design when an "Operation and Maintenance Plan" is
developed for the cap. The operation and maintenanc~ costs
developed for all "capping" alternatives include costs for
maintenance, erosion control and fence repair. Maintenance
includes inspection and replacement, as necessary, of cap
components, and repair of damage to the cap as it occurs.
Comment b: Several commentors requested that all residents
within a half-mile of the site be evacuated if soil
excavation takes place at the site.
EPA Resoonse: The remedy includes the excavation and
consolidation of' 2000 cubic yards of sediments from the
wetlands on the west side of the landfill and 30,000 cubic
yards of material from the edges of the landfill. While
there is a potential for releases to the atmosphere during
this work, the remedy will be designed to best control such
releases and to ensure public health is not adversely
affected. Additionally, state and federal laws concerning
air emissions have been identified for the Site and will be
attained during the remedial action. Evacuation during this
work will be considered; however, EPA believes it will not be
necessary in light of the engineering controls identified in
the FS.
Comment c: One commentor disapproved of EPA's plan to move
soil from around the site to the area where it will be capped
without first cleaning the soil.
EPA Resoonse: EPA does not believe treating the 30,000 ~ubic
yards of excavated soils prior to consolidation on the
landfill proper would significantly improve the remedy since
the landfill area represents a much larger volume of
contaminated material. Additionally, prior testing has
revealed that the sediment to be excavated from the wetlands
and from the edges of the landfill has only low levels of
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10
Comment d: Two commentors requested the removal and proper
disposal of the "nuclear black silt" and oil spill debris
areas. One commentor stat~d that the oil spill debris, the
disposal of which had originally been authorized by the
state, was to have been removed by the state within three
weeks of its disposal.
EPA ReSDonse: There is currently no evidence of a black silt
with a nuclear, radioactive makeup exists in or on the site.
Several radioactive surveys done on the site during the
Remedial Investigation found only background (normal)
radioactivity. There have been unconfirmed reports of "black
beauty," a sand blasting material, from the Portsmouth Naval
Yard ship painting activities being disposed of at the site.
However, no evidence of its existence or of radioactivity was
found during test pit testing.
As stated in the Proposed Plan, EPA, under the Superfund Law,
cannot take any action with regard to the oily "debris" since
the law specifically excludes petroleum products from the
definition of hazardous substances. Remediation of this
area has been referred to the NH DES and their oil spills
program.
Comment e: Several commentors stated that "Pump and Treat"
technology to clean contaminated groundwater does not work
for the following reasons: 1) using water samples does not
effectively estimate the amount of contamination; 2) using
average flow rate does not effectively estimate the rate of
contaminant flow through the aquifer; 3) it is not possible
to locate all significant contamination using the current
site investigation technologies; 4) many contaminants do not
mix with water; and 5) carbon filtering does not remove
acetone and tetrahydrofurans. Other commentors questioned
the feasibility of "Cap and Treat" to achieve cleanup goals.
EPA ResDonse: In general there is no absolute guarantee that
a groundwater extraction and treatment system will be
completely effective at the coakley Landfill Site or any
other site where it may be recommended. This system was
selected as part of the remedy after EPA assessed all-
available information which was gathered by widely accepted
and proven methods. Based on this site-specific data, EPA
believes the system will attain the cleanup goals set in the
Record of Decision for this site. Moreover, additional
studies, including treatability and/or pilot studies,
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11
conditions will be conducted
Design/Remedial Action phase of the
identified standards, requirements,
are met.
during the Remedial
remedy to insure that all
criteria and limitations
The commentor is correct that it cannot be stated with
absolute certainty that all contaminants present within the
landfill were detected during the RI. To eliminate all
uncertainty regarding sources within the landfill, however,
complete excavation and sampling would be required. One of
the alternatives evaluated in the Feasibility Study (SC-6)
included this activity, but this alternative was not found to
be more protective than the preferred alternative in
proportion to the cost of the two remedies. The information
collected during the RI is believed to be representative of
the overall contaminant profile of the landfill.
While it is true that most of the organic indicator compounds
do not "mix" with water, all of the indicator compounds do
dissolve to some extent in water. None of the compounds have
been found at levels approaching their solubility limit,'
indicating they are present in the groundwater in dissolved
form, not in their pure form. Indicator compounds that have
been detected in the landfill but have not been detected in
the groundwater would be expected to be released to the
groundwater over time if no action is taken.
The commentor is also correct that activated carbon does not
effectively remove acetone and tetrahydrofuran from
groundwater. However, activated carbon has not been included
in the Proposed Plan for the purpose of removing these
compounds from groundwater, but rather as a treatment
technology for contaminants in the off-gases from the air
stripper. In addition, incineration was presented in the
Feasibility study for treatment of off-gases from the air
stripper. Incineration would effectively destroy these
contaminants if this is determined to be necessary.
The technologies selected for cleanup at the Coakley Landfill
site have been used effectively at other similar sites to
achieve cleanup levels. The remedy is expected to be
effective based on best professional jUdgement at this time.
Further information as to the adequacy of the technologies
will be gathered during Remedial Design. If information is
collected which suggests that the proposed alternative will
not achieve cleanup levels, the design will be modified to
include processes that will achieve those cleanup goals.
EPA assumes that "Cap and Treat" refers to the selected
remedy of capping and groundwater extraction and treatment.
In addition to the above discussion on the effectiveness of
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12
for the first operable unit of the Coakley Landfill Site
discusses the effectiveness of the selected remedy.
Comment f: One comrnentor asked if EPA has analyzed the risk,
damages, and cost of cleanup for "Pump and Treat" failure and
requested to see a cost analysis before a ROD is signed.
EPA ResDonse: Cost estimates for the various components of
all the alternatives carried through the detailed analysis
are included in the Feasibility Study. EPA is not required
to conduct any additional cost analysis. Costs associated
with a failure of the pump and treat system would depend upon
the type of failure. It could range from replacemen~. of the
entire system, which is highly unlikely, to replacement of
some of the system components. Operation and maintenance
costs are included in the overall cost of the remedy to
address failure. While it may be necessary to replace some
of the components within the system during the planned ten
year operation, EPA does not anticipate the need for a major
or total replacement.
Additionally, groundwater monitoring will be conducted
throughout the remedial action to evaluate the effectiveness
of the treatment.
Comment g: Several comrnentors expressed concern about
contamination affecting Little River and wetlands to the west
of the site; particularly contaminant affects on habitats for
wildlife, fish, and birds as well as on hunting and
recreational areas. One comrnentor was concerned about
possible contaminant migration north, northeast, and west of
the site. Comrnentors requested that contaminant migration be
addressed in the cleanup alternative.
EPA ResDonse: There is some information that a plume of
relatively low level contamination exists under these
wetlands which partially discharges through some low
permeability soils into the wetlands. The extent and
characteristics of this plume must be better defined before
a cleanup is undertaken, if warranted. Further studies,
including an environmental assessment, will be conducted
concerning migration of contaminants. A second Record of
Decision will be issued if necessary. CUrrently, there is no
evidence of significant impacts to the aquatic environment in
these areas.
Comment h: Two comrnentors requested that alternative SC-6 be
chosen as the preferred cleanup method because it is the most
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13
EPA ResDonse: EPA's rationale for not selected alternative
SC-6 is contained in the Record of Decision for the first
operable unit of the Coakley Landfill site.
While EPA does agree that SC-6 is a somewhat more effective
remedy in terms of permanence and reduction of toxicity,
mObility and volume through treatment, EPA does not believe
the increased effectiveness is commensurate with the
increased cost. We base this belief on the following
observations:
.
The residual risk to public health and the environment
after capping and groundwater extraction and treatment
is low as long as cap integrity is maintained. ..
.
The cap will be consistent with RCRA closure
requirements and will therefore be adequate to prevent
contact with any contaminated material within the
landfill. Offsi te migration of contaminants will be
mi tigated by the groundwater portion of both cleanup
alternatives. Under either alternative that the
contaminated groundwater under the landfill will meet
safe drinking water requirements at the compliance
boundary.
.
In addition, S 300.430(a) (1) of the NCP has established
program goals for identifying and implementing
appropriate remedial actions. These goals include:
1)
2)
Treating principal threats, wherever practicable;
Combining treatment and containment in appropriate
remedies; and
3)
Considering containment for wastes that pose a
relatively low long-term threat or where treatment
is impracticable.
While compliance with these program expectations is not
required and does not in itself constitute sufficient grounds
for the selection of a remedy, they are presented as guidance
for developing cleanup options.
Comment i: A landowner located north of the Coakley
property, commented that testing has shown VOCs in nis water
supply, suggesting evidence of possible contaminant migration
to the west, north and northeast. The commer.tor requested
that municipal water supply lines be extended to residents of
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14
EPA ResDonse: EPA believes contaminants in the wells located
to the north of the Coakley Landfill property may come from
other sources. Trihalomethanes, which were found in the
commentor I s drinking water well, were not found in the
groundwater under and ar\Jund the Coakley Landfill. Also,
groundwater flow from the landfill tends to move in a
westerly direction. The request to extend the water supplies
must be addressed at a local level.
Comment j: One commentor noted that alternative SC-4
includes an extraction system of overburden and bedrock wells
on the southern and eastern perimeters of the landfill. The
comment or requested that the groundwater extraction.. system
also be extended to the north and west perimeters.
EPA ResDonse: The conceptual design of the groundwater
extraction system includes recovery wells on the east and
south perimeters of the landfill because these locations were
the most practical extraction points for developing a
groundwater capture zone to control the source of
contamination. This system does not attempt to collect
contaminated groundwater that has migrated away from the
source or which may be coming from other sources. The exact
location of the extraction system will be finalized during
the Remedial Design phase. This final design may include
extraction wells at the north and west perimeters.
Comment k:
effectiveness
specifically,
bedrock wells
Several commentors questioned the level of
of the preferred cleanup method, and, more
how EPA's preferred alternative SC-4 protects
in the area.
EPA ResDonse: Alternative SC-4 was selected for the
effectiveness of the technologies in addressing site
conditions and contaminants based on their use at other
similar sites. Actual information as to their effectiveness
at the Coakley Landfill Site will be collected during
Remedial Design treatability studies and operation of the
facility.
This remedy was also selected to minimize the risks
associated with the source of contamination (the landfill)
and to prevent further offsite migration of contaminants from
the source. While SC-4 will not clean up offsite wells, it
will minimize any further contamination of these wells which
is attributable to the Coakley Landfill, and will decrease
the amount of time required for the natural reduction of
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15
Comment 1: A commentor asked if a fence could be constructed
around the landfill in North Hampton.
EPA ReSDonse: The preferred alternative includes a fence
around the perimeter of the landfill.
Comment m: Several commentors requested that the land at the
site be returned to a safe and usable environment, as
determined and agreed upon by local citizens and their chosen
advisors.
EPA ReSDonse: The selected remedy is, in EPA's.opinion, the
best remedy when judged against all applicable statutQry and
regulatory criteria (see ROD, Section X). The remedy
required to meet the goals suggested by this comment appears
to be significantly more costly than alternative SC-6 which
provides for excavation and treatment of all the. wastes and
redeposition on the site under a cap at an estimated cost of
approximately $52,000,000, yet the overall protectiveness in.
proportion to the cost is not better than SC-4. Returning
the site to a safe and usable environment would involve
offsite disposal of the waste and groundwater treatment and
extraction at a substantial cost. In addition, such measure
would not absolutely guaranty the site would be safe and
usable for all purposes. In fact, ~ 300.430(f) of the NCP
states that a remedy is cost-effective if its "costs are
proportional to its overall effectiveness."
The Superfund Law gives EPA the responsibility to make
cleanup decisions with appropriate input from the community
as specified in the NCP.
EPA sponsors a program called Superfund Technical Assistance
Grants (TAG). A TAG award to a group affected by the coakley
Landfill would provide the group with funds to hire a
technical advisor to assist them in interpreting and
commenting on site findings and further proposed actions. A
fact sheet on the TAG program is attached which contains
general information and contacts for further information.
..
Comment n: The Hampton Water Works Company (HWWCo) commented
that it is currently developing a production well field for
an additional water supply in the area of North Road and
Birch Road, southwest of the Coakley Landfill site, in North
Hampton. HWWCo stated that the Coakley Remedial
Investigation Report indicated that the area of this well
site is not likely to be contaminated in the near future.
HWWCo expressed concerned that the remedial action chosen for
cleanup may contaminate this new potential water supply
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16
extensive groundwater testing and modeling in the area as a
result of the new well's relative proximity to the landfill
and expects that EPA, through its monitoring program, will
alert HWWCo of any contaminant migration toward HWWCo's
production well.
EPA Response: EPA will continue to monitor the groundwater
in and around the Coakley Landfill during implementation of
the remedy and for a period of time thereafter. EPA does not
anticipate nor envision that the remedial action will result
in any contamination to the well site because the remedial
action selected is designed to control migration of offsite
contaminants from the source area. The future studies of the
contamination under the wetlands west of the site called for
in the Proposed Plan will also address HWWCo.' s concerns.
EPA will keep HWWCo advised of any monitoring results that
could have a bearing on this matter. EPA also suggests that
HWWCo obtain the results of tests that the NH DES has
periodically performed on residential wells in the area.
4.
comments Regarding Health Risks
Comment a: Several commentors stated that the health
assessment conducted by the state was inadequate and
requested a thorough health study.
EPA Response: A health assessment report dated October 13,
1988, by ATSDR is included in the Administrative Record.
Because most of the residents and businesses surrounding the
site have been serviced by municipal water lines since 1983,
and indoor air monitoring conducted in 1986 did not detect
concentrations of VOCs that would be expected to cause
adverse health effects, the Coakley Landfill is not being
considered for follow-up health studies at this time. -
Comment b: Several commentors stated their concerns for the
health and well-being of children living in the area of the
site and asked about the possible future health risks facing
these children.
EPA Response: Based upon data collected during the RIjFS
and evaluated in the Risk Assessment, children who play in
the water, sediments or soils on or near the landfill are not
expected to be more susceptible to the risk of developing
cancer. The remedial action will minimize future risks from
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17
5.
Comments Regarding PRPs
Comment a: Several commentors stated that the State of New
Hampshire should be held responsible for site cleanup because
it was the State that originally permitted the landfill. Two
commentors alleged that the State was aware of and allowed
illegal dumping at the site, ignoring Class II landfill laws.
EPA ReSDonse: EPA is continuing its investigation regarding
parties which could be considered potentially responsible for
the Coakley Landfill site as they are defined under the
Superfund Law (CERCLA). At this time EPA does.not consider
the State to be a potentially responsible party (PRP).
..
Comment b: A commentor requested that reparations be made to
residences and businesses affected by the site even if this
requires evacuation and relocation and/or purchase of
property.
EPA ReSDonse: There is no provision in CERCLA that allows
for compensation to residents and property owners in the
vicinity of a Superfund site to sell, rent or buy their
homes.
Comment c: Several commentors stated that federal law
required EPA to take action against toxic sites first, and
then to recover cleanup costs from polluters. Commentors
feel that EPA has compromised an effective permanent remedy
because of costs and have requested that EPA not wait to
negotiate settlements with PRPs before taking action to
cleanup the site.
EPA ReSDonse: The immediate threat to public health from the
Coakley site was removed from the site when the residents
were supplied public water in March 1983. All previous,
current and future response actions at Coakley Landfill site
have been and will continue to be undertaken as required by
the Superfund Law (CERCLA) and its regulations (NCP).
Comment d: Two commentors requested an investigation into
government and business practices that caused this problem in
order to determine who should be held ultimately responsible.
The commentors suggested public. disclosure, and civil and
criminal prosecution of those found responsible.
EPA ReSDonse: The EPA is continuing to investigate
potentially responsible party (PRPs) practices which may have
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18
Appropriate action will be taken against parties found to be
liable for contamination at the site.
Comment e: One commentor requested that EPA consider the
Departments of the Air Force and Navy as major PRPs.
EPA Response: The EPA has sent general notice letters to the
U.s. Air Force and the U.s. Navy naming them as potentially
responsible parties (PRPs) as well as to 58 other PRPs.
B.
Summarv of Potentiallv Responsible Parties Comments
One set of written comments was received from a group of
PRPS, known as the Coakley Landfill PRP Group. The main
points made by this group of PRPs are summarized briefly
below. The PRP comments are included in Attachment B. PRP
comments are divided into the following four categories:
1.
2.
3.
4.
Evaluation of Site Characterization
Evaluation of EPA's Preferred Alternative
Evaluation of Other Remedial Alternatives
Alternative Proposal for Staged Remedial Actions
1.
Evaluation of site Characterization
Comment a: The possible impact of contaminant migration from
Rye Landfill during groundwater extraction under the proposed
remedial plan has not been characterized by the EPA.
EPA Response: commingling of contaminants from the Coakley
and Rye landfills is unlikely under natural or stressed
(pumping) conditions. The contamination attributed to. the
coakley and Rye landfills is separated by the presence of
high bedrock and groundwater levels in the area between the
two landfill. The overburden aquifer was found to be dry in
this area during the RI, precluding contaminant migration
from Rye Landfill from mixing with coakley contaminants via
an overburden pathway.
For contaminants from the Rye Landfill to enter the
groundwater collection system at coakley, the bedrock pumping
wells would have to cause a gradient reversal extending
beyond the groundwater high north of the landfill. Given the
anticipated placement of the wells, the pumping rate and the
conductivity of the bedrock, this seems unlikely. This
supposition will be confirmed during Remedial Design.
Groundwater gradients will be monitored during operation of
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19
individual wells will be adjusted routinely to control the
boundaries of the capture zone of the groundwater collection
system.
Comment b: The possible impact of contaminant migration from
other source areas (several body shops and auto dealerships
that generate hazardous waste, and a number of establishments
that have underground storage tanks) during groundwater
extraction under the proposed remedial plan has not been
characterized.
EPA Response: The EPA has not disputed the possibility of
other sources of chemical constituents in groundwater..in the
general area of the Coakley Landfill. The focus during
remediation will be to limit the collection of groundwater to
"source control", Le. water within and immediately adjacent
to the compliance boundary. Groundwater contamination at
GZ-122 would be addressed under the implementation of a
management of migration alternative. As discussed in the
Proposed Plan, the selection of a management of migration
alternative has been delayed pending the collection of
further data. The groundwater extraction system will be
designed and operated so as to minimize the collection of
groundwater potentially contaminated by sources other then
Coakley Landfill.
Comment c: Of the seven organic indicator chemicals, none
have been detected in offsite overburden monitoring wells
directly attributable to Coakley Landfill.
EPA Response: This comment is very specific to existing
offsite overburden wells. Onsite overburden wells have shown
contamination above cleanup goals. The contamination appears
to be migrating to the bedrock groundwater both on and
offsite. The majority of this groundwater contamination is
localized under the landfill in the overburden and bedrock
hydrogeological units. However, the indicator compounds have
been detected in numerous offsite bedrock wells and have been
found at levels exceeding the cleanup goals in two offsite
bedrock monitoring wells and five former domestic wells. It
is also possible there is some contamination of overburden
groundwater close to the site boundary, however, the offsite
overburden monitor well network was not established close to
the boundary.
The list of wells chosen by the PRP group as "offsite" wells
is very limited. They have eliminated wells that they feel
are potentially affected by sources other than Coakley. To
ignore downgradient wells installed for the purpose of
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20
information to the desired view.
Comment d: Of the seven organic indicator chemicals, only
benzene, 2-Butanone (MEK) and chlorobenzene were detected in
on-site overburden wells at concentrations that exceed their
respective cleanup goal.
EPA ReSDonse: This comment fails to mention that trans-l,2-
dichloroethene and the three inorganic indicator chemicals
(arsenic, chromium, and nickel) were also detected on-site in
concentrations greater than their respective cleanup goals.
Dichloroethene is listed in the data table as .the combined
total of the cis and trans isomers, however it shquld be
conservatively assumed that this concentration represents the
trans isomer (an indicator chemical). The other three
indicator compounds (tetrachloroethene, phenol, and diethyl
phthalate) were chosen as indicator compounds due to their
presence in te~~ pit samples collected within the landfill.
They were reta.ined as groundwater indicator chemicals and
cleanup goals were developed based on the potential for
leaching to the groundwater.
Comment e: Only two organic indicator chemicals have been
detected in bedrock monitoring wells at concentrations that
exceed their respective cleanup goals.
EPA ReSDonse: Indicator chemicals were not selected based
solely on their presence in bedrock groundwater monitoring
wells. All indicator chemicals have been detected in at
least one of the media sampled during the RI. The use of the
word "only" is inappropriate in this comment since it is
significant that the cleanup goals for two of the indicator
chemicals are exceeded in two bedrock monitor wells. The
indicator chemicals have been detected in four off-site
bedrock monitoring wells and in numerous former residential
wells including wells at Lafayette Terrace.
v
Comment f: Even if one assumes that the Lafayette Terrace
wells were affected by the landfill due to past pumping of
the wells, rather than from natural gradients, these
residential wells are now closed and additional migration'
from the landfill to Lafayette Terrace would not be expected.
EPA ReSDonse: This comment seems to imply that it would be
necessary for a groundwater mound to exist to the east of the
landfill in order to allow contamination to migrate towards
Lafayette Terrace. Data from the RI suggest that a gradient
existed, while the residential wells were pumping, towards
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21
data, the impact of discontinued use of these wells on
groundwater gradients. It was assumed that groundwater would
continue to flow in the direction of Lafayette Terrace, but
at a shallower gradient, due the fact that the landfill sits
on several watershed divides. There is an expected
diminished flow in the direction of Lafayette Terrace but
this would not remove the potential risk for use of the
groundwater as a drinking water source in the future. The
groundwater collection system design effort will include
measurement of flow gradients under pumping conditions.
Even if the assertion made were correct, EPA would be
required, under several regulations and/or policies including
RCRA, the Groundwater Protection strategy and the Safe
Drinking Water Act, to undertake a remedy which would insure
that the migration of contaminants above MCLs and/or levels
protective of public health would not occur under any
scenario. The groundwater in the coakley Landfill' area would
be required to be returned to a qual i ty consistent with
previous highest beneficial use, i.e. drinking water.
Comment q: The stated groundwater cleanup goal for arsenic,
30 ug/L, should be updated to 50 ug/L to reflect current EPA
policy.
EPA ResDonse: As explained in the Record of Decision for the
first operable unit of the Coakley Landfill Site, the cleanup
level for arsenic in groundwater has been set at 50 ug/L in
accordance with the MCL.
Comment h: Only two monitoring wells have had arsenic values
above 50 ug/L and no wells outside the compliance boundary
have levels of arsenic above 50 ug/L.
EPA ResDonse: An objective of the source control remedy is
to prevent future offsite migration of contaminants which are
presently within the capture zone. The chosen alternative is
a source control remedy which includes the prevention of
migration of onsite contaminants. The two monitoring wells
with levels exceeding 50 ug/L are located at the compliance
boundary of the Site. Because of the potential use of the
aquifer at and beyond the compliance boundary as a drinking
water source, EPA will meet MCLs at the compliance houndRry.
d
Comment i: Based on the data collected, no monitoring wells
outside the compliance boundary have levels of chromium and
nickel above their respective cleanup goal.
EPA ReSDonse:
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22
chromium have not been found in offsite wells above the
cleanup goals, these metals were detected in onsi te wells
above cleanup levels. It is EPA' s . contention that this
represents a source of these metals which must be controlled
from migrating off-site. As discussed in the FS, the
proposed treatment system is designed for removal of metals.
Comment;: The risks are overestimated because they are
based on ingesting water from wells located within the
boundaries of the landfill and are based on overly
conservative exposure assumptions.
EPA ResDonse: Consistent with EPA guidance, EPA has.. made a
conservative estimate of existing and potential public health
risks under a "no action" alternative. As part of this
analysis, it is EPA practice to use monitoring information
from both within and beyond the boundary of the landfill as
needed to fully characterize the extent of contamination and
thus possible exposure. Assumptions used to estimate
exposure including exposure duration, were made consistent
with the EPA guidance available at the time the risk
assessment was written (Superfund Public Health Evaluation
Manual, October 1986) and with assumptions made by EPA's
Office of Drinking Water regarding exposure duration. EPA
Region I views a 70-year exposure period to be a reasonably
conservative estimate for the duration of possible exposure
over a lifetime under the "no-action" alternative. While the
recent guidance referred to by the PRP group (EPA Exposure
Factors Handbook, 1989) suggests that exposure durations of
less than 70 years may be suitable in some instances, it also
affords the risk manager the opportunity to select an
exposure duration of his choice depending on site specific
information, consideration of policy or precedent factors.
Furthermore, the publication date of this report was such
that it was not available at the time the risk assessment was
written (Oct. 1988) thus it could not have been considered
for the Coakley Landfill risk assessment.
G
Comment k: The risks are overestimated because they are
driven by the ingestion of arsenic which is subject to
considerable scientific uncertainty.
EPA ResDonse: Much of the "scientific uncertainty" regarding
the carcinogenic potential posed. by the ingestion of arsenic
referred to by the PRP group has been resolved. In a memo
from the EPA Administrator to Assistant Administrators (June
21, 1988) summarizing the work of EPA's Risk Assessment Forum
Special Report on Arsenic he states that, "the Forum
concluded... that arsenic is a human carcinogen by the oral
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23
scheme for designating the weight-evidence". As a known
human carcinogen EPA Region I does not believe that a
discussion of the scientific uncertainty on the carcinogenic
potential of arsenic is warranted. . The extent to which
arsenic causes cancer (c~ncer potency estimate) and the
nature of the cancer induced (skin) influenced the selection
of a cleanup level for this compound and were the subject of
discussion in the Record of Decision (Section XI).
Comment 1: EPA has not demonstrated that the metals selected
as indicator chemicals are above background levels or are, in
fact, site contaminants.
EPA ReSDonse: The selection of indicator chemica-Is was
performed during the RI in accordance with accepted procedure
at the time it was performed. contaminants were selected
based on frequency of detection, concentration, toxicological
effects, and chemical and physical properties. The selection
of the three metals was based primarily on elevated levels in
soil and/or groundwater. As noted by the PRP group, several
wells exist which do not appear to have been impacted by
Coakley Landfill. In several of these "background" wells
none of the three indicator metals were found in
concentrations above the detection 1 imi t. However,
significant concentrations were detected in wells immediately
adjacent to the landfill. This supports the selection of
these metals as indicator chemicals of site contamination.
These metals, therefore, may have been directly disposed of
in the landfill.
It is EPA's belief that arsenic may be emanating from waste
materials in the landfill or may be mobilized from naturally
occurring arsenic in contact with leachate, thereby causing
contamination of the groundwater. The phenomena of iron
mobilization from soils within organic rich leachate plumes
is well documented. The geochemistry of arsenic is such that
it tends to adsorb on iron oxide deposits in soil. Thus
arsenic may be released from soil when iron is mobilized.
Elevated levels of iron have been noticed in groundwater and
iron staining is evident on surface soils and sediments in
the area surrounding Coakley landfill. Review of the data
indicates the occurrence of arsenic above the detection limit
typically coincides with elevated VOC and iron
concentrations. Arsenic levels in excess of the clean up
levels have been found in overburden wells at the compliance
boundary along the southern and eastern edge of the landfill.
.:)
Comment m: All of the seven comments in Part II. D of the
PRP group's written comments and all of the five comments in
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24
D
conceptual
groundwater
alternatives.
groundwater extraction system
simulation conducted to
design and
evaluate
the
the
EPA ResDonse:
as follows:
In general our response to these comments is
The final groundwater flow model configuration provides a
conceDtual recovery system design based on both the field
data collected and on the model "calibration" process.
Calibration of a steady state groundwater flow model based on
unstressed water level data (non-pumping conditions) is
difficult, and will provide only qualitative estimates of
stressed conditions (pumping). However, the estimates
obtained were deemed sufficient for cost purposes (plus 50
percent to minus 30 percent of estimated cost). The EPA
recognizes that additional field work will be required prior
to final design. Bedrock aquifer pumping tests are
recommended in the FS in order to provide more accurate
values of transmissivity and hydraulic conductivity, and
provide additional data on leakage between layers, potential
bedrock well pumping rates and eventual recovery well
spacing.
\t
An additional evaluation of some of the comments with respect
to the number, location, and pumping rates (as related to
treatment plant costs and design) of the groundwater recovery
system using a Theis type drawdown analysis of the
groundwater capture zone was performed. This analysis
assumed a 100 foot thick aquifer with a hydraulic
conductivity of 0.8 ft/day, storage coefficient of 0.05 and
a 365 day pumping period. Eight bedrock wells were included
in the analysis, each well pumping about 10 gpm. This
analysis results in drawdowns in each of the eight recovery
wells of approximately 60 feet with drawdowns of 20 feet or
more extending more than 200 feet from the recovery wells.
If we assume, as the commentors suggest, that the bedrock
recovery system will dry up the shallow overburden aquifer
and recovery trench, the 100 gallon per minute flow included
in the FS is a reasonable, if somewhat conservative
conceptual design flow.
It should be noted that the Theis analysis performed to.
review the design used the geometric mean of the field
derived hydraulic conductivities of the bedrock. These
values may be somewhat higher than the bulk aquifer
conductivities determined during a pumping test because the
field tests were performed on what was interpreted to be the
more productive zones of the bedrock. Also because it was
noted in the RI that the fracture zones may be less open
below a depth of 50 feet in rock, serious consideration
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25
the pumping tests. This may result in reduced pumping rates
and still affect complete contaminant capture.
The commentors suggest that the groundwater recovery system
is over designed. The final design of the recovery well and
trench system may differ from the conceptual design, but the
final optimal design cannot be determined until the field
work and analysis is complete during the design phase. The
total flow from the recovery system appears to be somewhat
conservative but within the range of a reasonable design flow
given the field data available.
2.
Evaluation of EPA's Preferred Alternative (SC-4)
Comment a: EPA has not justified that every element of the
proposed multi-media cap over the landfill area is necessary.
EPA ResDonse: The cap described in the FS and in the
Proposed Plan, was designed based on compliance with both
RCRA and state of New Hampshire regulations. The state of
New Hampshire hazardous waste regulations, and solid waste
regulations for landfills, were deemed to be ARARs for the
Coakley site by EPA. As noted in the FS, the proposed cap is
simply a conceptual model for the capping technology.
Therefore, any cap proposed during the Remedial Design phase
which is as effective as the one described and meets all
ARARs, would be acceptable.
Further, the only difference between the cap described by the
PRP group and the one in the Proposed Plan is the inclusion
of a drainage net between the liner and the sub-base and a
drainage mesh along the top of the landfill. The drainage
net is provided to assist the sand in draining infiltration
away from the landfill, while the drainage mesh is included
. to prevent erosion and settling in the cap layers. Both of
these features have been included in several cap designs
recently approved by NH DES.
Comments b: EPA has not justified the need for active
collection and treatment of landfill gases generated below.
the cap. These comments focused on active landfill gas
collection and treatment, which was included with all capping
alternatives in the FS.
<>
T!
EPA ReSDonses: The overriding factor influencing the
decision to perform active gas collection was the proximity
of the landfill to residential and commercial properties to
the east and south. The risk assessment performed relative
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26
which detected up to 48 ppb of VOCs. The presence of a cap
will alter gas migration patterl1s. Without active gas
collection, gas could potentially migrate horizontally under
the cap and across the site boundary in the vadose zone.
Also, gas collected by gravity vents (in a passive collection
system) would be emitted at higher concentrations at discrete
points on the site. The unknown and potential risks
associated with these scenarios makes it reasonable to
include active gas collection as a component of the
alternatives evaluated, and as an integral part of the
Proposed Plan.
Treatment of collected gas is proposed for the following
reasons:
.
Treatment provides reduction in toxicity in accordance
with CERCLA, and
.
The treatment methods selected, thermal destruction,
provide economic benefit for on-site groundwater
treatment alternative by making available a heat source.
This benefit would be in the form of reduced capital and
operation and maintenance cost for treatment of air
emissions from the groundwater treatment system.
Another potential benefit which could be derived from active
gas collection, but which was not included in the cost
evaluations presented, is cogeneration of electricity. This
on-site generated electricity could decrease the O&M cost of
gas and groundwater collection and treatment systems.
Comment c: The groundwater treatment system is significantly
overdesigned since the influent concentrations are based on
average levels found in the most contaminated wells instead
of all wells.
EPA ReSDonse: The groundwater treatment system design
presented in the FS and Proposed Plan is a conceptual design
for the purpose of alternative evaluation. The influent
concentrations used in designing the proposed system, while
conservative, were used as a common design basis for all
alternatives evaluated. Further information as to expected
influent concentrations will be collected during pump tests.
and any bench or pilot-scale testing performed during
Remedial Design. This information will then be used to
design an efficient cost-effective groundwater treatment
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27
Comment d: The groundwater treatment system is likely to be
overdesigned because it was based on a flow rate of about
100,000 gallons per day.
EPA Response: As previously discussed, a groundwater model
was used to develop a common conceptual design basis for
evaluating alternatives. The groundwater extraction rate
estimated by the model (75 gpm) is a reasonable estimate, as
discussed in response 1.m. The design flow rate for the
groundwater treatment system cost estimate was 100 gpm, which
conservatively incorporated a .safety factor of one-third of
the flow predicted by the model. The actual design basis for
the final design of the groundwater treatment system will be
set following pumping tests conducted during the Remedial
Design.
Comment e: No analysis has been advanced to suggest that
activated carbon or an incinerator are necessary for air
pollution controls for public health or environmental
protection.
EPA ReSDonse: There is currently an OSWER Directive 9355.0-
28 that requires air emissions control for air strippers at
Superfund groundwater sites in ozone non-attainment areas as
established by the National Ambient Air Quality Standards.
Coakley Landfill in Rockingham County is in a ozone non-
attainment area which requires an air emissions control.
Comment f: It is not apparent that both an air stripper and
a biological treatment units are needed to attain water
quality objectives.
EPA ResDonse: The unit operations presented in EPA's
selected remedy are representative process options selected
from applicable technologies during the screening phase of
the FS process. As such, different process options from the
same technology type which are capable of meeting cleanup
goals could be implemented during Remedial Design and
Remedial Action. Representative process options are selected
to limit the screening process and are not meant as a final
required design. Further, if a surface water discharge is
required during high groundwater periods, the effluent from
the air stripper would require further treatment to meet the
more stringent requirements for surface water discharge.
Additional treatment would likely include nitrification of
ammonia and removal of biochemical oxygen demand (BOD).
If biological treatment were used as the representative
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28
excessive treatment would occur for alternatives SC-4 with
only recharge to aquifer and SC-5. Neither of the
alternatives require the level of treatment provided by
biological treatment and therefore the cost increase could
not be justified. The cost savings to SC-4 with surface
water discharge due to the PRP group's proposed modification
would be less than $150,000, consisting mostly of the capital
cost of the air stripper. Minimal savings of O&M costs would
be realized.
Many of the compounds detected at the site are biodegradable,
therefore, biological treatment is possibly applicable and
will be investigated during the Remedial Design phase for the
Site. Although biological treatment will be considered, air-
stripping remains the selected process for removing VOCs
because of the following uncertainties with biological
treatment:
.
Air emission controls;
.
Potential toxicity problems arising due to site
contaminants which would limit the effectiveness of
biological treatment; and
.
Chlorinated volatile organics (e.g. trans-l,2-
dichloroethene) often convert to vinyl chloride by
biological processes. Vinyl chloride is a known
carcinogen which could not be discharged to surface
water at a concentration above the detection limit or
the groundwater above its MCL of 2 ppb.
Comment q: The levels of metals present in the groundwater
at the Site are insufficient to justify their pretreatment.
EPA ReSDonse: The metals pretreatment process described in
the Proposed Plan was designed to meet two objectives: (1) To
remove indicator metals to cleanup goals and (2) To remove
metals which would limit the effectiveness of the organics
treatment process(es). The level of treatment required to
meet these two objectives would be finalized during Remedial
Design. The major metal of concern for an air
stripper/biological syst~m would be iron. The levels of iron
found in wells on-site i~dicates difficulty operating either
of these treatment scenarios without metals removal. While
air strippers have been installed for groundwater treatment
wi thout iron removal, depending on the iron concentration
they either require frequent acid washing to remove iron from
the packing or frequent replacement of the packing. O&M cost
may be greatly increased if metal pretreatment is not
-------
29
Comment h: The PRP group refers to a memorandum regarding a
study that suggests that it may be difficult to achieve
cleanup concentration goals in groundwater extraction
systems. Additionally, the PRP group claims that inadequate
data has been collected by EPA at the Coakley Landfill site
to allow for an adequate design of an efficient -:leanup
approach.
EPA ReSDonse: The findings of the study referred to in the
memorandum states that "extractions systems are generally
effective in containing contaminant plumes, thus preventing
further migration of contaminants." As a source control
remedy and as stated in the FS, an objective of the remedial
action is to "Prevent the off-site migration of contaminants
above levels protective of public health and the
environment." The study suggests that the chosen alternative
would meet this objective. Data collected to date is
adequate for conceptual design of the groundwater extraction
system part of the remedy. Additional data needed for final
design will be collected during the Remedial Design phase.
3.
Evaluation of Other Remedial Alternatives
Comment a: EPA does not adequately demonstrate that
alternative SC-3 would not meet federal and state ARARs and
would not minimize the migration of contaminants from soils
into groundwater.
EPA ReSDonse: EPA acknowledges in the FS that migration of
contaminants is lowered to some extent by construction and
maintenance of the cap. However, as stated, this alternative
would not allow ARARs to be achieved in an acceptable time
period. Based on the preamble in the new National
Contingency Plan published March 8, 1990, it is EPA's policy
to, "return usable groundwaters to their beneficial uses
within a time frame that is reasonable".
The assumption that MCLs would not be met for several decades
without groundwater collection and treatment was based on the
following:
(1) Elevated levels of indicator compounds were observed
offsite (particularly west of the landfill) as well as
-------
30
(2) After the cap is placed, contaminants will migrate
and/or degrade at a slower rate due to the decrease of
infiltration. Slower percolation of contaminants to
groundwater causes longer sustained contaminant level
above MCLs.
Given that the significant migration pathway for the site is
through the bedrock, that indicator compounds above cleanup
goals have been found in bedrock wells both on and off-site,
and that the conductivity of the bedrock is very low, the
conclusion is drawn that contaminants would take a long time
to reach cleanup goals at the compliance boundary.
..
No acceptable modelling tool was found for contaminant
transport which could be applied to the site. Given the
heterogeneity of the material in the landfill, it would be
difficult to accurately predict source characteristics. The
HELP model referenced in this comment is a tool for
estimating the flow vertically through a landfill, and does
not provide information regarding contaminant transp~rt.
Comment b: EPA does not demonstrate that alternative SC- 4
is superior to alternative SC-5.
EPA Response: Alternative SC-5 was evaluated to the maximum
extent possible during the FS process and was evaluated
appropriately relative to other alternatives. As discussed
in the Proposed Plan, it was not selected due to concerns
with the administrative implementability of the alternative,
(i.e. whether approval could be obtained from the Town of
Hampton to discharge to their sewerage system), and in part
due to uncertainty regarding impact on the wetland. Each of
the individual topics bulleted by the PRP group are discussed
below:
During the FS process, inquiries were made to the Town of
Hampton concerning their willingness to take pretreated
groundwater from the Coakley site, the estimated user charge
for such a hookup, and the most appropriate location to
connect to the sewerage system. The estimated cost and
connection location were used to perform the conceptual
design and costing of Alternative SC-5. The Town personnel'
contact indicated that the acceptance and actual cost would
have be negotiated before permission would be given. The
negotiation process is a post-ROD activity and not part of
the FS process.
The Portsmouth POTW was not considered to be an acceptable
treatment facility for the groundwater from Coakley. The
-------
4.
31
experiences permit compliance problems. This POTW would not
provide the necessary residual organic and ammonia removal.
Based on calculations performed on all data from Table 13 of
the RI, it is estimated that during semi-annual low flow
cycles the groundwater extraction system may extract 100% of
the surface water leaving the wetland via Berry's Brook and
up to 20% of the surface water leaving the wetland via Little
River, based on an extraction rate of 100 gpm. If SC-5 were
to be selected, further study would be needed during Remedial
Design to predict what effect will occur.
While the Proposed Plan does not specifically cite reduction
of residual organic carbon and ammonia at an off-site POTW,
it does discuss that a reduction of toxicity, mobility and
volume of contaminants would occur if SC-5 were implemented.
However, removal of organic carbon and ammonia is not unique
to SC-S, as this comment implies. This feature is included
also in SC-4 and in the Proposed Plan.
Finally, the total costs for SC-5 and SC-4 are relatively
close ($18,900,000 versus $20,200,OO~' making the basis for
selection something other than costs. EPA has determined
that the potential implementation problems and possible
negative impacts to the adjacent wetlands (short-term
effectiveness) associated with SC-5 make it a less desirable
alternative.
Comment c: Cost analyses presented in the FS Appendix Bare
not consistent between alternatives for certain line items.
EPA ResDonse: The oily debris is not included as part of
EPA's Proposed Plan and has been referred to NH DES. The
overall cost differential to Alternative SC-S would be a
reduction of approximately $800,000, reducing the overall
cost of the alternative to approximately $18,900,000. This
cost is less than that of SC-4 as shown in the Proposed Plan
by just over $1 million dollars. In the overall assessment,
alternatives SC-4 and SC-5 would be considered to have
similar costs leaving other criteria (i.e., implementability
and short-term effectiveness) as the basis for selection.
Alternative proposal for staqed Remedial Actions
Comment a: The PRP group states that the most effective
remedial action would be installation of a cap that meets New
Hampshire municipal landfill closure standards and assessing
-------
32
EPA Response: This proposal essentially provides for the
capping of the landfill and deferral of the groundwater
remedy until a evaluation of the impact of the cap on
migration of contaminants is conducted. Discussion relevant
to this proposal is included in part in response numbers 2.a
and 3.a and as follows:
.
The cap included in the selected remedy (SC-4) is
consistent with the state of New Hampshire, Department
of Environmental Services current requirements for
closure of a solid waste landfill. EPA has determined
that the New Hampshire hazardous and solid waste
regulations are ARARs for the Coakley Landfill.
Therefore, the cap must be consistent wi th', these
requirements.
.
As discussed in comment l.c and in the ROD, EPA believes
that the majority of groundwater contamination is under
and beyond the landfill in the overburden and bedrock
hydrogeological units and is migrating radially out
beyond the compliance boundary established in the
Proposed Plan. Capping of the landfill may, and
probably will, slow this migration. However, we have no
evidence to suggest it will be retarded such that
cleanup levels (ARARs) will be met at the compliance
boundary wi thin a reasonable timeframe. Further, EPA
believes that if water supply wells are reintroduced to
the area in the vicinity of the Coakley Landfill, the
groundwater gradients will be significantly altered.
Such alteration will accelerate migration of
contaminated groundwater from the landfill beyond the
compliance boundary in concentrations exceeding cleanup
levels.
.
The al ternati ve proposed by the PRP group does not
satisfy the preference for treatment that reduces
toxicity, mobility or volume as a principal element of
the remedy as set forth in Section 121 of CERCLA.
.
The construction of an effective groundwater extraction
system would be significantly more complicated if done
after the cap were in place and the integrity of the cap
-------
ATTACHMENT A
COMMUNITY RELATIONS ACTIVITIES
CONDUCTED AT THE LANDFILL SUPERFUND SITE
IN NORTH HAMPTON, NEW HAMPSHIRE
EPA/DES have conducted the following community relations activities
at the Coakley Landfill Superfund site:
o
August 18, 1983 - Site Tour (presentations by NH WSPCC,
North Hampton Selectmen, US EPA, and Senator Gordon
Humphrey) .
o
November 4, 1985 - North Hampton Board of Selectmen hold
a Public Informational Meeting to receive State input
about the hydrogeological study to assist the town in
planning water line extensions.
o
January 1986 - DES/WSPCC prepared a Community Relations
Plan.
o
April 1986 - DES issues a Press Release announcing the
Public Meeting to kickoff the RI/FS.
o
May 14, 1986 - DES holds the RI/FS kickoff Public
Informational Meeting.
o
July 8, 1988 - NH Division of Public Health Services
issues Report #88-007, "Evaluation of Cancer Incidence
and Mortality."
o
October 13,
Report.
issues
a Health Assessment
1988 - ATSDR
o
October 25, 1988 - EPA issues a Press Release announcing
the Public Meeting to discuss DES/EPA Remedial
Investigation results.
October 1988 - EPA issues a Fact Sheet on the RI results.
o
o
October 1988 - DES issues a Fact Sheet on the RI results.
o
November 3, 1988 - DES/EPA hold a Public Informational
Meeting on the results of the RI.
o
November 30, 1988 - EPA issues a Public Notice in the
Portsmouth Herald announcing the availability of the
Administrative Record.
-------
~
o
February 1990 - EPA
cleanup.
issues
the Proposed Plan for site
o
March 7, 1990 - EPA issues a Press Release announcing
the availability of the Proposed Plan, the dates of the
Public Informational Me~ting and Informal Public Hearing
and the beginning of the Public Comment Period.
c
March 9, 1990 EPA issues Public Notices in the
Portsmouth Herald and Foster's Daily Democrat announcing
the Proposed Plan, the dates of the Public Informational
Meeting and Informal Public Hearing, and the beginning
of the Public Comment Period.
o
March 15, 1990 - EPA/DES hold a Public Informational
Meeting on the Proposed Plan for site cleanup.
o
March 16, 1990 - May 14, 1990 - Public Comment Period on
the Proposed Plan.
o
March 30 1990 - EPA issues a press release announcing
the extension of the Public Comment Period.
o
April 3, 1990 - EPA/DES hold an Informal Public Hearing
on the Proposed Plan.
-------
ATTACHMENT B
-------
.
.
COMMENTS ON EPA's
PROPOSED REMEDIAL PLAN FOR THE
COAKLEY LANDFll..L SUPERFUND SITE
NORTII HAMPTON, NEW HAMPSHIRE
Prepared by
ENVIRON Corporation
Arlington, Virginia
-------
I. INTRODUCI'lON
A
Background .
ENVIRON Corporation (ENVIRON) was retained by the Coakley Landfill
Steering Committee, a group of potentially responsible parties (PRPs) at the Coakley
Lanufill SUl-'~tfuuu Site (the Site), to review the Remedial Investigation (RI) and
Feasibility Study (FS) reports prepared for the Site and to evaluate the Site remedy
proposed by the u.S. Environmental Protection Agency (EPA). .
A major conclusion of EP A's effort is that the Site poses no current potential
risks to public health and the environment. In its analysis of potential future risks,
EP A concludes that no significant adverse health effects are expected from Site
contaminants present in soils, surface water, sediments, and air. Under a worst-case
scenario where a drinking water well is installed adjacent to the landfill, EP A
concludes that there is a low-level future carcinogenic risk to humans through the
ingestion of ground water, primarily due to arsenic.
Based on the abQve, the EPA has proposed a source control remedy (the SC-4
alternative in the FS) for the Site, consisting of the following major elements:
.
construction and maintenance of a multi-media cap over the landfill
.
area;
excavation of sediments and their placement underneath the cap;
construction and operation of a trench and extraction well system around
the perimeter of the landfill for removal of ground water;
on-site treatment of the ground water; and
disposal of the treated ground water by ground water recharge or surface
water discharge.
.
.
.
EP A has delayed a decision regarding a remedial alternative for the off-site
ground water contamination until the nature and extent of the contamination in this
media is better characterized.
-------
Additional source control alternatives considered but not selected by EP A
include alternatives SC-3 and SC-S. Alternative SC-3 consists of the following major
elements:
. ,
.
construction and maintenance of a multi-media cap over the landfill
.
area;
excavation of sediments and their placement underneath the cap; and
collection and off-site treatment of ground water perched in the quarry
area of the landfill.
.
Alternative SC-S is identical to alternative SC-4, except that extracted ground water
would be pretreated on-site, and then sent off-site for treatment and disposal at a
publicly owned treatment works (POTW).
Executive Summary
Because EP A has not adequately characterized the nature and extent of
contamination at the Site, has not justified each element of its preferred alternative,
and has poorly analyzed other remedial alternatives, the following remedial alternative
is proposed: -
B.
.
construction and maintenance of a multi-media cap, which meets current
New Hampshire municipal landfill closure standards, over the landfill
area;
.
excavation of sediments and their placement underneath the cap;
following installation of the cap, evaluate the feasibility of and need for
collection and - off-site treatment of ground water that may be perched in
the quarry area of the landfill; and
ground water monitoring to assess the beneficial effects of the remedial
alternative on ground water migration and contaminant attenuation.
.
.
-------
Comments are organized into three sections, as follows:
1.
Evaluation of Site Characterization
.
All sources of ground water contamination in the vicinity of the
Site have not been well characterized. The EP A cannot be
certain, therefore, that its source control remedy addresses all
major sources of ground water contamination. In addition, EP A
has not analyzed the impact of contaminant migration from these
sources during the proposed ground water extraction.
.
EP A has established the compliance boundary for attainment of
site-specific ground water cleanup goals as the current boundary
of the Coakley landfill on the south, west, and east; and
approximately 200 feet from the limits of the landfill on the north
and northeast. EP A has not adequately described the minimal
nature and extent of contamination inside and outside the
compliance boundary. The extensive remedial action proposed by
EP A is not consistent with the low level of observed
contamination.
.
EP A has overestimated the hypothetical future risks to humans via
the ingestion of ground water.
.
EP A's ground water flow model, MODFlOW, is seriously flawed
and provides poor representation of actual Site flow conditions.
Therefore, conclusions regarding the preferred remedial
alternative, which are directly based on this model, are invalid.
-------
3.
2.
.
Evaluation of EPA's Preferred Alternative (SC-4)
.
EP A has not justified that every element of the proposed multi-
media cap over the landfill area is necessary.
.
EP A has not justified the need for active collection of landfill
gases generated below the cap.
.
EP A has not justified the need for treatment of landfill gases
generated below the cap.
.
Because the proposed ground water extraction system is based on
a seriously flawed and unreliable model, the preferred remedial
alternative itself is likely to be flawed and unreliable.
.
EP A proposes to treat extracted ground water on-site to remove
metals and organics through chemical precipitation, air stripping,
and biological treatment. EP A has not justified the need for such
extensive treatment. .
EP A has not adequately discussed the large uncertainties
associated with the effectiveness of ground wa~er extraction
systems.
Evaluation of Other Remedial Alternatives
.
EP A does not adequately demonstrate that alternative SC-3 would
not meet Federal and State ARARs and would not minimi7.e the
migration of contaminants from soils into ground water.
-------
.
EP A does not demonstrate that alternative SC-4 is superior to
alternative SC-5.
.
Cost analyses presented in FS Appendix B are Dot consistent
between alternatives for certain line items.
-------
ll. EVALUATION OF SITE CHARACTERIZATION
A.
All sources of ground water contamLWlation in the vicinity of the Site have Dot
been well characterized. The EP A cannot be certain, therefore, that its source
control remedy addresses all major sources of ground water contamination. In
aawdon, EP A has not analyzed the impact of contaminant migration from
these sources during the proposed ground water extraction.
1.
As stated in several places of the RI (pp 7-33, 7-34, 7-39 and 7-4D), the
Rye Landfill is a potential contaminant source area within the northern
portion of the Coakley study area. In fact, the RI states (p 7-27) that
the actual downgradient and ultimate fate of ground water contamination
within the study area is extremely difficult to assess in part because of
the effect of the Rye Landfill. The possible impact of contaminant
migration from Rye Landfill during ground water extraction under the
proposed remedial plan has not been characterized by EP A.
2.
The RI states (p 7-28) that extensive commercial activity in the
immediate area of the Site results in the possibility of additional
contaminant source areas. These include several auto body shops and
auto dealerships that generate hazardous waste, and a number of
establishments that have underground storage tanks. The nature and
type of contaminants at these potential sources may be different than
those identified at the Site.
For example, possible contamination of bedrock well GZ-l22,
located across Lafayette Road approximately 3000 feet southeast of the
landfill, may be attributable to sources other than Coakley Landfill. The
contaminants present during one sampling event (out of three) in this
well were dichloromethane, benzene, and acetone. These do not match
the suite of major contaminants, such as toluene, xylene, tetrahydrofuran,
diethyl ether, 2-butanone, and methyl isobutyl ketone, present in the
-------
landfill area. In two other sampling events, GZ-122 was
uncont~minated.
The possible impact of contaminant migration from other source
area.) during ground water extraction under the proposed remedial plan
has not been characterized.
B.
EPA has established the compliance boundary for attainment of site-specific
ground water cleanup goals as the current boundary of the Coakley landfill on
the south, west, and east; and approximately 200 feet teom the limits or the
landfill on the north and northeast. EP A has not adequately described the
minimal nature and extent of contamination inside and outside the compliance
boundary. The extensive remedial action proposed by EPA is not consistent
with the low level of observed contamination.
1.
Of the seven organic indicator chemicals (e.g., benzene, 2-butanone,
chlorobenzene, diethyl phthalate, phenol, tetrachloroethylene, and trans-
1,2-dichloroethylene), none have been detected in off-site overburden
monitoring wells directly attributable to Coakley Landfill (see Table 1).
2.
Of the seven organic indicator chemicals, only benzene, 2-butanone and
chlorobenzene were detected in on-site overburden wells at
concentrations that exceed their respective cleanup goal (see Table 2).
3.
Only two organic indicator chemicals (benzene and 2-butanone) have
been detected in bedrock monitoring wells at concentrations that exceed
their respective cleanup goals. Both chemicals were detected at the sole
on-site bedrock monitoring well (MW-S, as shown in Table 1) and only
in a single off-site bedrock monitoring well (GZ-10S, as shown in Table
1).
-------
Indicator Che8tcat
Benzene
2-lutanone
Phenol
Dlethyl phthatate
Tetrachtoroethylene
Chlorabenzene
trens.'.2-Dlchtoroethytene
Arsenic
tltr.l...
.tcket
Table 1
Cont..lnent levels In Off-site Groundwater
Coakley landfll I
North H~ton. Nev Hampshire
Overburden Yel I. Bedrock "eU.
Grcudi8ter ...--.----.-.-.-....-.---........ --....-...-....-.-.......--...-.-
ctHNlp Artth8ettc Frequency Artth8etlc ,~
._1 AVI ".. 0' AVI .... 0'
(ug/U (ug/U (UII/U Detection (UII/U (UII/U Detection
5 016 6 6.7 2/10 (2)
200 0/6 249.5 282 2/10 (2)
280 0/1 0/1
2800 0/1 0/1
3.5 0/6 0/10
100 0/6 0/10
100 0/6 0/10
50 (1) 0/1 0/1
50 2.7 2.7 1/1 0/1
100 5.5 5.5 1/1 10 10 1/1
Iotea:
O".Ite overbu~ Metl, .u.88rlzed here are &%-101. GZ-117.
end GZ.123. There are no off.lte overburden MeUS to the
Melt of the landfllt. Those to the north are IlIIpICted by
addl tI one I sources.
Off,Ite bedrock Melts su.88rtzed here are "".6. GZ.103.
GZ.105. and GZ-109. Those to the north are IlIIpICted by
~Itl0n81 sources.
(1) The FS erroneously uses 30 "Ill as the MCl for .rsenlc.
-------
Indtcator Che8tcal
lenIene
2-iut....
Phenol
Dlethyl phthalate
Tetrachloroethylene
CIIlorobenzene
trens-1,2-Dtchtoroethytene
Arsenic
CII..-I..
Ilcket
Table 2
Cont..lnant levets In On..lte Groundweter
C08kley landftll
lorth H~ton, leM HllllpShi re
overburden Yel t. Bedrock Yel I ""-5
,.....,.ter --------.-.------.....-.---...--- .--------------......-.--........
CI..-. Artth8ettc 'r~ Artth8ettc Frecpncy
Goal AVI "a. of AVI "'. of
(ug/l) (ug/t) (ug/t) Detection (UIIl) (ug/t) Detectlan
5 21.4 60.6 16/22 13.1 19.4 4/4
200 745.7 2700 6/22 217.5 401 3/4
280 110 120 2/5 0/1
2800 136.3 230 ]/5 0/1
3_5 0/22 0/4
100 166.5 182 2/22 (2) 10.1 14.1 3/4
100 13.3 15.8 2/22 0/4
50 (1) 40.1 89 617 1.95 8 2/2
50 170.5 330 2/7 0/1
100 99.8 200 5/5 65 65 1/1
lot..:
On8tte overburden ...U. are ""-1, ""-2, ""-3S, ""-3D, ""-4, ,z-t, end
GZ-106.
(1) The FS erroneously us.. 30 ug/l as the MCl for ar.enlc.
-------
4.
I
Q i
.. i
Based upon available data, it is difficult to determine whether a ground
water mound exists to the east of the landfill. Thus, it is also difficult
to determine whether the residential wells .in the vicinity of Lafayette
Terrace (RW-2S, RW-26, RW-27 and RW-28) were contaminated by the
landfill or by off-site sources. However, even if one assumes that the
Lafayette Terrace wells were affected by the landfill due to past
pumping of the wells, rather than from natural gradients, these
residential wells are now closed and additional migration from the
landfill to Lafayette Terrace would not be expected
5.
The stated ground water cleanup goal for arsenic, 30 ugfL, should be
updated to 50 ug/L to reflect current EP A policy. The maximum
contaminant level (MCL) for arsenic is 50 ug/L At the time of the
publication of the RI, the proposed MCL for arsenic, 30 ug/L, was used
as a cleanup level. Due to the uncertainty over health effects from
arsenic ingestion, EP A is no longer proposing to change the MCL for
arsenic. Therefore, the ground water cleanup goal for arsenic should be
50 ug/L.
6.
Only two monitoring wells have had arsenic values above 50 ug/L (MW-
3D at 89 ug/L; and MW-4 at 59 ug/L). Monitoring well MW-4 was
resampled on May 26, 1987 following the initial sampling of December
4, 1985, resulting in arsenic concentrations less than 50 ug/L
Monitoring well MW-3D has not been resampled. Based on the above,
resampling of MW-3D would possibly show arsenic concentrations below
the cleanup goal. No wells outside the compliance boundary have levels
of arsenic above 50 ug/L
7.
Based on the data collected, no monitoring wells outside the compliance
boundary have levels of chromium and nickel above their respective
cleanup goal.
-------
c.
EP A has overestimated the hypothetical future risks to humans via the
ingestion of ground water.
EP A concludes that there is a low-level future carcinogenic risk to bl]m~n"
liuuugli i,Ilt: iugt:stion of ground water from a hypothetical well installed adjacent to
the landfill (Tables 81, 82, and 87 of the RI). These risks are overestimated for the
following reasons:
1.
They are based on ingesting water from wells located within the
boundaries of the landfill, rather than from wells located outside the
boundaries of the landfill. Although arsenic has been detected in wells
outside the landfill perimeter only in concentrations less than 10 ug/~
the average arsenic concentration used by EP A (Table 87 of the RI) in
the risk characterization is 38 ug/L. Benzene has been detected outside
the landfill perimeter at a maximum concentration of 6.7 ug/L (not
including wells impacted by sources other than the landfill); however, the
average benzene concentration used by EP A (Table 87) in the risk
characterization is 28 ug/L. Because risk is linearly related to
contaminant concentration, the risks due to ingestion of arsenic and
benzene in ground water have been overestimated by approximately a
factor of four.
2.
They are based on overly conservative exposure assumptions. For
example, current EPA guidance (EPA 1989a) suggests that a risk
assessment be based on a nine year exposure for typical ~ase scenarios
and a thirty year exposure for reasonable worst case scenarios, rather
than the seventy year exposure assumed in the RI. Because risk is
linearly related to exposure duration, the use of a seventy year exposure
period has resulted in overestimation of risks by more than a factor of
two.
-------
D.
3.
They are primarily driven by the ingestion of arsenic. Whether and to
what extent ingested arsenic poses a human risk of cancer has been the
subj~ct of considerable scientific debate within EP A (EP A 1988a, EP A
1989b). A full discussion of the scientific uncertainty of this issue should
be included in the RI.
4.
EP A has not demonstrated that the metals selected as indicator
chemicals (e.g., arsenic, chromium, and nickel) are above backgroiind
levels and are, in fact, site contaminants. No ground water well was
installed by EP A to determine the background level of metals in the
ground water. Based on a review of data retrieved from STORET, a
water quality database supported by the EP A, ambient background
ground water arsenic concentrations are as high as 43 ugfL in Strafford
and Rockingham Counties, New Hampshire.
EPA's ground water flow model, MODFLOW, is seriously flawed and provides
poor representation of actual Site flow conditions. Therefore, conclusions
regarding the preferred remedial alternative, which are directly based on this
model, are invalid.
1.
A ground water flow model is a mathematical representation of the
actual ground water flow regime of the modeled site. In general, the
objective of the model is to conduct simulations to evaluate the impact
of various imposed stresses such as pumping on the site's ground water
flow. If such a model does not provide accurate and reliable
representation of the observed field conditions, then any simulation
obtained from the model will be unreliable. Poor agreement between
measured and predicted ground water elevations resulted from
MODFLOWs calibration effort. As shown in Table C-l of the FS,
-------
4.
5.
differences between modeled and actual water levels were often as large
as one to four feet.
2.
In order to "calibrate" the model, EP A used input values of hydraulic
conductivity (Kh) that greatly differ from values measured during field
i.cSLs.
.
For the upper outwash zone, the Kh value (50 ft/day) used
uniformly in the model is within the range of values measured at
the site. However, because the three measured values were 2.1,
2.5, and 510 ft/day, it is likely that the Kh value chosen is too
high for the majority of the site.
.
For the bedrock aquifer, the range of Kh values (3 x 10-5 to 5 X
10-3 ft/day) is approximately three orders of magnitude less than
the range of values measured at the site (see RI Table 4).
3.
The uniform annual recharge rate of 11 inches to the upper layer used
in the model represents only 30% of the 37 inch average annual
precipitation in the area (NOAA 1984), rather than the 50% infiltration
rate quoted elsewhere in the report (see page 4-42). In addition,
applying a uniform recharge rate throughout the Site is an unrealistic
approach because a significant portion of the modeled area is occupied
by wetlands.
As shown in Figure C-2 of the FS, the model predicts flow directions
that are in conflict with the RI water level data (see Figure 12 of the
RI), particularly east and south of the landfill.
The landfill area was modeled with no. flow boundaries assumed to the
north and south. Because water level data indicate that there is a
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substantial southerly £10\" component from the landfill, this approach is
not representative of observed conditions.
6.
Prior to conducting model slinulations, a ground water model should be
calibrated, using one set of water level data, and validated, using a
second set of water level data. The model was only calibrated with data
from 2 September, 1987, but was never validated.
7.
Based on the above, conclusions reached with regard to the preferred
remedial alternative, which are directly based on this model, are invalid.
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A
B.
m. EVALUATION OF EPA's PREFERRED AL1ERNATIVE (SC-4)
EPA has not Justified that every ele1l1ent of the proposed multi.media cap. over
the landfill area is necessalJ'.
The multi-media cap proposed by EP A consists of a six-inch vegetative
topsoil layer, a sub.base layer of two feet of sand, a drainage net, a low-
permeability barrier of clay or synthetic liner material, a six inch layer of sand,
and a drainage mesh (see Figure 4-6 of the FS). No analyses are presented to
demonstrate whether or not a less stringent cap would be sufficiently effective
in minimizing the migration of contaminants from the landfill. For example,
current New Hampshire's closure requirements for municipal landfills consist of
a six-inch vegetative topsoil layer, a sub-base layer of two feet of sand, and a
low-permeability barrier of clay or synthetic liner material. This and other cap
alternatives should have been analyzed by EP A to determine their effectiveness.
EPA has conducted these analyses at many Superfund sites. After conducting
such analyses at the Mason County Landfill, Michigan Superfund Site, EP A
stated in its ROD (EP A 1988b, p. 16) that the risk of contaminant release to
the ground water at the site did not warrant the extra protection and
concurrent high capital and replacement costs associated with the multi-media
cap.
EP A has not justified the need for active collection of landfill gases generated
below the cap.
The need for active collection of landfill gas has not been justified by
EP A Passive collection of landfill gas has been used by EP A at many
Superfund Sites (e.g., Mason County Landfill, Michigan (EPA 1988b); Volney
Landfill, New York (EPA 1987a); Dorney Road Landfill, Lehigh City,
Pennsylvania (EPA 1988c». In addition, a passive venting system is currently
used at Rye Landfill. There is no reason to believe that a passive system
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would not be effective at Coakley, since similar wastes were likely disposed at
Rye and Coakley. EPA should evaluate the use of a passive gas venting
system at Coakley Landfill.
C.
EP A has not justified the need for treatment of landfill gases generated below
the cap.
The treatment of landfill gas cannot be justified on the basis of health
benefits, when the risk assessment concluded that the site currently poses no
risks due to air emissions and inhalation of toxies. At the Landfill & Resource
Recovery, Rhode Island SuperfuLd Site, EP A proposed treatment of landfill gas
only after a risk assessment was performed (EP A 1988d). At the Laurel Park
Site in Naugatuck, Connecticut, EP A delayed a decision on whether to treat
landfill gas until emissions could be tested (EP A 1988e). At the Mason
County Landfill, Michigan Superfund Site (EP A 1988b), EP A proposed a vent
system without an incinerator because of negligible risks.
Because the proposed ground water extraction system is based on a seriously
flawed and unreliable model, the preferred remedial alternative itself is likely
to be flawed and unreliable.
1.
EP A has proposed the construction and operation of. a collection trench
and extraction well system around the perimeter of the landfill for
removal of ground water. This system includes seven overburden wells
and eight bedrock wells and is primarily based on capture zones derived
from simulation of the ground water flow model. Because the model is
flawed, this design likely represents a redundant and unnecessarily costly
extraction system.
2.
Because the steepest gradients and most of the bedrock aquifer
contamination are to the west, bedrock extraction wells need not have
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been proposed for the east side of the landfill. Contamination migration
to the east may have occurred in the past due to pumping of residential
wells; however, based on the RI water quality and water level data,
contaminant migration is now primarily to the west. Simulation using a
reliable model would likely have resulted in similar conclusions.
3.
Because the conductivity of the upper sand and gravel zone in some
portions of the Site is substantially less than the value used in the
modelling, the trenches will likely not intercept as much flow as the
model suggests. Therefore, the estimate of the volume captured by the
trench is likely unreliable and cannot be used for designing the ground
water treatment system.
4.
Because the bedrock conductivity values used in the model were much
too low, the bedrock extraction system is likely overdesigned and will
result in a greater discharge than that assumed in the preferred
alternative.
5.
Placement of bedrock extraction wells directly underneath the
overburden recovery trenches, as proposed by the EP A, could lead to
dewatering of the trenches. The marine clay layer, which would
otherwise serve as an aquitard between the shallow and bedrock zones,
is absent in the landfill area. Pumping from the deep zones could
quickly reduce the shallow ground water levels and provide a rapid
pathway for the introduction of contaminants to the bedrock aquifer.
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E.
EP A proposes to treat extracted ground water on-site to remove metals and
organics through chemical precipitation, air stripping, and biological treatment.
EP A has not justified the need for such extensive treatment.
1.
The ground water treatment system design influent concentrations were
based on the average levels of contamination found in the most
contaminated wells (MW-S, MW-3S, MW-3D, and GZ-106). Based on
FS Figure 4-13, four additional wells (MW-1, MW-2, MW-4, and PZ-1)
are located within the capture zone of the collection trenches and
bedrock wells. The lower levels of contamination in these wells should
have been included in the calculation of design influent concentrations.
In addition, because the extraction system will capture ground water
from less contaminated areas outside the landfill perimeter, the quality
of the water obtained will be substantially better, i.e. less contaminated,
than that represented by the four most cont~min~ted wells. The
proposed treatment system is therefore significantly overdesigned.
2.
The ground water treatment system was based on a flow rate of about
100,000 gallons per day, eighty percent of which is from the collection
trencbes. As discussed above, less ground water will likely be
intercepted by the trenches and more will be extracted by the bedrock
system. No reliable model is available to estimate the water quality of
the effluent. Therefore, the proposed treatment system is likely
overdesigned.
3.
Activated carbon or an "incinerator" are m~ntioned as possible air
pollution controls for an air stripper. No analysis has been advanced,
however, to suggest that tbese controls are necessary for public health or
environmental protection.
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4.
Both an air stripper and a biological treatment unit are suggested for
reducing concentrations of volatile and semi-volatile organics in extracted
ground water. Benzene, the organic compound of greatest concern, is
readily biodegradable and volatilized (stripped) in biological treatment
units. Therefore, it is not apparent that a separate air stripper is
lic;cdcd to attain water quality objectives.
5.
The levels of metals present in the ground water at the Site are not
sufficient to justify their pretreatment Only a limited number of.metals
are present in on-site leachate at levels that exceed cleanup levels. As
discussed above, the quality of the water obtained by the extraction
system will be substantially better than that represented by the four most
contaminated wells.
F.
EP A has not adequately discussed the large uncertainties associated with the
effectiveness of ground water extraction systems.
In a recent memorandum (EPA 1989c), EPA discusses findings from a
study of several sites where ground water extraction is being conducted to
contain or reduce levels of contaminants in ground water. This study suggested
that in many cases, it may be difficult, if not impossible, to achieve cleanup
concentration goals in ground water. EP A should include a discussion of these
large uncertainties when presenting its preferred altemative~ In the
memorandum, EP A also encourages the collection of data to allow for the
design of an efficient cleanup approach that more accurately estimates time
frames required for remediation and the practicability of achieving cleanup
goals. Adequate data have not been collected by EP A at the Site to allow for
an adequate design of an efficient cleanup approach.
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IV. EVALUATION OF OTHER REMEDIAL ALTERNATIVES
EP A does not adequately demonstrate that alternative Se.3 would not meet
Federal and State ARARs and would not minimize the migration or
contaminants from soils into ground water.
SC-3 involves construction and maintenance of a cap over the landfill area;
excavation of sediments and their placement underneath the cap; and collection and
off-site treatment of ground water. In the Proposed Plan, EPA states that this
alternative would not meet Federal and State ARARs and minimize the migration of
contaminants from soils into ground water.
. .
.
EPA states that (FS page 4-47) "compliance with MCL's in groundwater
at the site boundary would not be achieved for several decades."
However, EP A does not provide any analysis, such as the use of the
Hydrologic Evaluation of Landfill Performance (HELP) model, to
support this statement. Given the low level of contamination observed
at the Site, it is certainly possible that ARARs would be met at a time
frame considerably less than that proposed by EP A EP A is being
premature by proposing this alternative and then dismissing it from
further consideration because the agency did not perform an adequate
analysis.
.
In the FS (p 4-47), EPA states that a cap would, in fact, U"inimize the
percolation of contaminants to surface water and ground water. This
fact is not acknowledged in the Proposed Plan.
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B.
EP A does not demonstrate that alternative SC-4 is superior to alternative
SC-S.
In the detailed analysis of remedial alternatives, EP A qualitatively
discusses the differences between alternatives SC-4 and SC-S. SC-S involves
lil~ capping of the landfill and ground water collection followed by on-site
pretreatment and off-site disposal. . Capping and ground water collection would
be accomplished as described in the preferred alternative (SC-4). Apparently,
SC-5 was not selected because a municipality may not accept the extracted
ground water for treatment and because the off-site disposal of ground water
could have the adverse environmental impact of temporarily drying up major
portions of the adjacent wetlands. The validity of these hypotheses have not
been demonstrated.
.
As stated in the FS (P 4-74), the Town of Hampton has a wastewater
treatment plant with secondary treatment and over 1 million gallons per
day in excess capacity. BPA apparently did not inquire whether the
Town might accept the extracted ground water for treatment. EP A is
being premature by proposing this alternative and then dismissing it from
further consideration because the agency did not perform an adequate
analysis.
.
Similarly, EPA has not adequately analyzed the alternative that would
include pretreatment of extracted ground water on-site and discharge to
the Portsmouth POlW.
.
Tbe effect of ground water collection and recharge on the wetlands has
not been adequately studied or modeled. No analysis or data are
provided to support EP A's statement (p 4-75 of the FS) that adverse
impacts on the wetlands would result if extracted ground water is
removed from the wetland hydrological system. A preliminary water
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balance shows that about 2300 acre-feet per year of water leave the
wetlands from Berry's Brook and Uttle River (Table 13 of the RI). If
. the total volume of extracted ground water (108,000 gallons per day or
120 acre-feet per year) is conservatively assumed to discharge to the
wetlands, then only five percent of the water entering the wetlands
would be diverted to the off-site treatment system.
.
EP A states in the FS (p 4-75) that off-site treatment (jf ground water
would remove residual organic carbon plus a percentage of the ammonia
..
and trace metals remaining in the pretreated ground water from reaching
the surface waters in the wetlands. This benefit of off-site treatment is
not considered U1 EP A's Proposed Plan.
c.
Costs analyses presented in FS Appendix B are not consistent between
alternatives for certain line items.
.
It is unclear why off-site disposal of the oily debris as proposed in SC-5
is necessary. Under alternative SC-4, the debris is excavated and
disposed on-site under the landfill cap. Because off-site disposal is
significantly more costly than on-site, this inconsistency results in an
overestimate of the cost of the POTW option (SC-S) as compared to the
on-site treatment option (SC-4).
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V. ALTERNATIVE PROPOSAL FOR STAGED REMEDIAL ACDONS
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The above comments point out several areas of significant concern regarding
EP A's analyses of remedial alternatives and their final selection of a preferred
alternative. Given that EP A has not demonstrated that all elements of its proposed
It:1l1t:UY wt: !t:4Wred to provide overall protection of human health and the
environment, it is proposed to implement a modified alternative SC-3 and defer
construction of the trench/well extraction system until the benefits of a site cap can
be assessed. The modification would be the installation of a cap that will me~t New
Hampshire municipal landfill closure standards rather than the cap proposed by EP A
In addition, the feasibility of and need for collection and off-site treatment of ground
water that may be perched in the quarry area of the landfill would be evaluated. As
stated above, EP A has found that in many cases it may be difficult, if not impossible
to reach cleanup goals by pump and treat methods. EP A itself states on page 4-48 of
the FS that "the effectiveness of the capping system would be easily monitored by
visua] inspection and sampling the groundwater around it."
Temporarily deferring remedial action for on-site ground water would create
the opportunity to monitor how an impermeable cover impacts ground water
contamination and migration. Furthermore, additional studies on the nature and
extent of off-site ground water contamination could be undertaken. To the extent
that either on-site and/or off-site ground water remediation is necessary, deferral will
allow for the design and implementation of a comprehensive plan.
At several other Superfund sites, EP A cited the potentially beneficial effects a
site cap can have on ground water migration and contaminant attenuation and
proposed deferring ground water recovery and decontamination (see RODs for South
Brunswick, New Jersey (BPA 1987b); Mason County Landfill, Michigan (BPA 1988b);
Kummer Sanitary Landfill (BPA 1988f); and Marion/Bragg Landfill (EPA 1987c».
EP A itself proposes to defer action on off-site ground water remediation, in
part because of the uncertainties in the hydrologic characterization of the site vicinity.
Any harm to long-term protectiveness caused by deferring cleanup of off-site ground
water should be no less than the harm of deferring the pumping and treatment of on-
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site ground water, given the minimal impact on off-site ground water to date and the
beneficial impacts that the cap can have.
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REFERENCES
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U.S. Department of Commerce. National Oceanic and Atmospheric Administration.
(NOAA). 1984. Comparative Climatic Data for the United States.
U.S, ET,.,.i1"nr.meT1t~l Protection Agency (EPA). 1987a. Superfund Record of Decision:
Volney Landfill, NY. EPA/ROD/R02-87/040.
U.S. Environmental Protection Agency (EPA). 1987b. Superfund Record of Decision:.
South Brunswick, NJ. EPA/ROD/R02-87/052.
..
U.S. Enviromnental Protection Agency (BPA). 1987c. Superfund Record of Decision:
Marion/Bragg Landfill, IN. EP A/ROD /R05-87 /055.
U.S. Environmental Protection Agency (EPA). 1988a. Special report on ingested
inorganic arsenic: Skin Cancer; Nutritional Essentiality. Risk Assessment
Forum. EPA/625/3-87/013.
U.S. Environmental Protection Agency (EPA). 1988b. Superfund Record of Decision:
Mason County Landfill, MI. EP A/ROD /R05-88/080.
U.S. Environmental Protection Agency (EPA). 1988c. Superfund Record of Decision:
Dorney Road Landfill Superfund Site, Lehigh County, Pennsylvania.
EP A/ROD /R03-88/056.
U.S. Environmental Protection Agency (EPA). 1988d. Superfund Record of Decision:
Landfill & Resource Recovery, RI. EPA/ROD/R01-88/032.
U.S. Environmental Protection Agency (EPA). 1988e. Superfund Record of Decision:
Laurel Park, cr. EPA/ROD/R01-88/025.
U.S. Environmental Protection Agency (EPA). 1988f. Superfund 'Record of Decision:
Kummer Sanitary Landfill, MN. EPA/ROD/ROS-88/082.
U.S. Environmental Protection Agency (BPA). 1989a. Exposure factors handbook.
Exposure Assessment Group. Office of Health and Environmental Assessment.
EP A/600/8-89/043.
r
U.S. Environmental Protection Agency (EPA). 1989b. Science Advisory Board's
review of the ARSENIC issues relating to the Phase n proposed regulations
from the Office of Drinking Water. EP A-SAB-EHC-89-038.
U.S. Environmental Protection Agency (EPA). 1989c. Directive No. 9355.4-03.
Considerations in Ground Water Remediation at Superfund Sites.
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U.S. Environmental Protection Agency (EPA). 1990. Memorandum to File. Backup
For Costing of Groundwater Treatment, Coakley Landfill Site, North Hampton,
NH. February 22, 1990.
U.S. Environmental Protection Agency (E~ A). 1990. Proposed Plan, EP A Region I
Superfund Program, Coakley Landfill Site, North Hampton, New Hampshire.
February 1990.
Roy F. Weston (Weston). 1988. Remedial Investigation, Coakley Landfill, North
Hampton, New Hampshire.
Roy F. Weston (Weston). 1989. Draft Feasibility Study, Coakley'Landfill, North
Hampton, New Hampshire. .
Roy F. Weston (Weston). 1990. Addendum to Coakley Landfill Feasibility Study:
Revised Table 2-7. February 27, 1990.
net\coakJey.rpt
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STATE OF NEW H~~PSHIRE
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HEARING REI
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E.P.A. REGION I
SU PER FUND PROGRAM
COAKLEY LANDFILL SITE
NORTH HAMPTON, NEW HAMPSHIRE
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BEFORE:
Dennis Hueber, N.H. and R.I. Waste Management
Steven Calder, Remedial Project Manager
Michael Robinette, Remedial Project Manager
Dan Coughlin, Chief, New Hampshire Superfund
Branch
North Hampton Elementary School
201 Atlantic Avenue
North Hampton, New Hampshire
Tuesday, April 3, 1990
7:40 p.m.
*****************COMPUTER-AIDED*TRANSCRIPTION******************
MARIANNE KUSA-Rn.L
REGISTERED PROFESSIONAL ~PORTER
P.O. BOX 610, 252 JUSTICE HILL ROAD
STERLING, MASSACHUSETTS 01564-0610
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speakers I
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Steven Calder
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l.illian Wylie
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Tammy Wylie
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Jay Chase
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Shawn Wylie
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John Burns
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Martha Bailey
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John Doggett
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Elmer Sewall
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Jean Gregg Lincoln
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Stuart Leide~an
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PRO C E E DIN G S
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MR. HUEBNER:
Okay.
If I can
have your attention.
Can everybody hear me okay up
here?
Again thank you for coming.
My name is
Dennis Huebner.
I am the Chief of the "Rhode Island
and New Hampshire Waste Management Branch for the
u.s. Environmencal Protection Agency in Boston,
Hassachusetts.
My staff and 1 are responsible for
the implementation of the E.P.A. Superfund Program
in New Hampshire and in the State of Rhode Island.
I am going to serve as the presiding officer over
this hearing today, and my sole purpose is to make
sure that we have orderly conduct and make sure we
accomplish the objectives of this hearing.
Also present here this evening and on the
hearing panel are Dan Coughlin.
Dan is sitting in
the middle over here to Ir(y left.
Dan works for me.
He is the chief of the New Hampshire Superfund
Section.
Steve Calder.
Steve 1s the remedial site
manager on this site.
Steve 1s sitting to my
immediate left.
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Mike Robinette works for the State of
New Hampshi re.
He has played a very active role
over the life of the study for this particular
site.
Mike works in the Department of
Environmental Services in the State of
New Hampshire.
The purpose of this hearing is to formally
..
receive your comments on the cleanup alternatives
under consideration at this site.
E.P.A. conducted a public information meeting
on Thursday evening, March 15, in which E.P.A.
presented the results of its remedial investigation
and feasibility study and presented the proposed
cleanup plan.
A question and answer period
followed that meeting, and I believe each of the
three gentlemen sitting up here at the front of the
room attended that meeting and spoke.
The public comment period began Friday, March
16,1990, and in a letter dated March 2,3,1990,
E.P.A. was requested by the public to extend the
public comment period an additional 30 days.
E.P.A. has responded in writing to this request.
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Friday, March 16, 1990 to Monday, May 14, 1990, a
total of 60 days.
Before beginning, I would like to describe for
you the for.mat for the bearing.
Essentially, tbe
evening will be structured as follows I
First, I am
going to ask Steve Calder -- be was the remedial
site manager that I introduced a couple of minutes
ago -- I am going to ask Steve to give a brief
overview of the E.P.A. proposed cleanup plan.
Following his presentation, we are going to accept
any oral comments you wish to make for the record.
This hearing 1s an opportunity for E.P.A. to listen
to what you have to say and your concerns with
respect to the study that was done here at the site
as well as our proposed cleanup plan.
If I find
that the comments are wandering from the purpose of
the meeting, I will try to remind you to focus your
comments more sharply.
This is not an attempt on
my part to limit what you have to say, but rather
to assure that we accomplish the objectives of this
hearing.
In summary, the purpose of the hearing 1s
to receive your comments, not to engage in an
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information meeting that was held a couple of weeks
ago.
Those of you wishing to comment should have
already done so by filling out the index cards
available at the desk in the rear of this ~.
Also available, I believe we have copies of the
proposed cleanup plan, which you can -- did we
bring extra copies of the cleanup plan?
The answer
is yes.
So if any of you would now like to go down
and get a copy of it, or at your leisure, please so~
do.
If you have not completed one of the cards,
and you wish to speak, the cards are at the rear of
the room.
Again, I would ask you to go down there
and get a card.
Does anyone need a card at this point in ttme?
Has everyone filled one out that desires to speak
here this evening?
What I am going to do is to call upon you in
the order in which you signed in this evening,
unless when you signed in you indicated you needed
to speak earlier because of other oammi~ents.
When called on, I will ask you to come to the
middle of this room.
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So that everyone will have a chance to speak, I am
going to ask you if you plan on speaking longer
than 15 minutes, 1f you would try to summarize your
comments in 15 minutes.
The cards that I have received so far are -- it
appears that we have nine people that are
interested in making a statement here this ev.~ning,
and I see sorne more people down back of the roam
right now probably filling out the cards, so we may
have 10 to 12 or more people wishing to make a
comment.
The text in its entirety from this hearing
tonight is being transcribed.
It will became part
of the hearing record.
Again, following your
comments, I or another member of the panel will
have the opportunity to ask you clarifying
questions, if we feel we need to do that regarding
your comments, and hopefully that will help us to
further clarify exactly what you would have 1m mind
should we choose to do so.
After all the comments have been heard, I am
going to close the for.mal hearing.
If you wish to
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to do so, these must be postmarked no later than
Monday, May 14, 1990.
Monday, May 14, 1990 is the
date to which we have extented the public comment
period due to the request from you, the public.
Those comments must be mailed to our office in
Boston. The appropriate address can be found on
page two of the proposed cleanup plan. Again, 1f
you need a copy of that cleanup plan, it's on the
table in the rear of the room.
At the conclusion of the hearing, if you have
any additional questions or comments concerning
what we are doing here this evening, please speak
to some of the staff.
They will be here as well as
I will be here.
The summary of the hearing will be included in
a report -- we will be responding to the comments
made here tonight in a document called a
responsiveness summary.
That responsiveness
summary is part of the Record of Decision process
that we will be going through and deciding what the
remedy will be for the cleanup of this site.
I am now going to ask Steve Calder to present a
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I have asked him to be Quick about thie ~nd to
present his summary.
MR. CALDER:
Good evening.
Again, my name 1s Steven Calder.
I work f or the
E.P.A. as the Remedial Project Manager for the
Coakley Landfill Superfund Site.
The purpose of my
presentation is to summarize the proposed cleanup
plan which was presented at the public information
meeting on March 15, 1990.
Here is a map of the site.
In the northern
most part of the site is an oily debris area
(indica ting) .
Although the feasibility study
discussed oPtions of redisposal of this material in
the landfill in conjunction with the cleanup of the
landfill proper, Superfund Law specifically
excludes petroleum products.
Therefore, E.P.A. 's
preferred alternative does not address this
material.
The decision on the final disposition of
this material has been referred to the State of
New Hampshire.
The obj ective of the remedy is to prevent the
off-site migration of the contaminated groundwater.
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study, we found that the contaminated groundwater
over the landfill proper were the areas of most
risK.
1 will now briefly review the five remedial
alternatives that were analyzed in detail in the
feasibility study and are also presented in the
proposed cleanup plan.
The first alternative that was reviewed in
detail was the -No Action- alternative.
Al though
this option is called the -No Action- alternative,
there would be a fence installed, the landfill
would be learned and seeded, and a long-te~
monitoring program would be instituted to evaluate
the potential exposure routes.
This alternative
provides a baseline for comparison and is required
to be reviewed by law.
The estimated cost for this
remedial alternative is approximately $2 million.
The second alternative reviewed in detail is
the capping, including consolidation.
The capping
of a landfill typically involves the covering of
the surface with a multi-layer cap system.
A cap
typically includes a vegetative layer on top, a
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permeability barrier of clay or a synthetic liner.
The cost of this remedial alternative estimate waB
to be $11 million.
The third alternative that was reviewed in
detail was the capping with off-site treatment and
disposal.
This alternative involves the capping of
the site and the construction of a sewer and ,pump
station for treatment of the extracted groundwater
from the site at the local wastewater tr.eatment
facility.
The cost of this remedial alternative
was estimated to be $20 million.
The fourth alternative that was reviewed in
detail was the on-site solid waste and groundwater
treatment and disposal and capping.
This
alternative involves digging up the refuse for
treatment, either incineration and/or
solidification, pumping and treating the
groundwater and the capping of the landfill.
The
cost of this remedial alternative was estimated to
be $54 million.
The fifth and preferred alternative is the
capping and on-site groundwater treatment.
This
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pumping and treating the groundwater before
recharging it to the ground and/or locally
discharging to surface waters.
The cost estimate
for this remedial alternative was estimated to be
$20 million.
The positive aspects to this alternative
includes the reduction of the mobility, vol~e and
toxicity of the contaminants.
This alternative
would be protective to human health and the
environment, and meets all state and federal
regulations.
And this al ternative would be
impl emen tabl e.
A negative aspect of this
alternative is the potential of exposure to the
local residents and the workers during the
excavation of the 30 -- estimated 30 cubic yards
[sic] of material that would need to be
transplanted -- moved about to put "the cap on
properly.
This is necessary in order to properly
construct the cap.
However, emissions would be
controlled by applying strict engineering controls,
and the monitoring of the air would confi~ the
controls are affective.
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alternative fOt the off-site contaminated
groundwater at this time, therefore meaning the
management of the migration.
A1 though the da ta in
the remedial investigation indicates that a plume
of low-level contamination exists off-site to the
west of the landfill, insufficient data was
collected to dete~ine the full extent of the
plume.
Additionally, the E.P.A. is concerned that
serious damage and alterations to the wetlands
would occur if a conventional groundwater pump and
treatment system were to be installed.
Therefore,
E.P.A. will continue to expand its investigation of
the off-site groundwater.
A second Record of
Decision will be issued once we have a ~tter
understanding of the off-site groundwater system.
I want to thank you.
MR. HUEBNER I
Steve, do you want
to clarify one thing?
You mentioned 30 cubic
yards.
It's 30,000 not 30.
MR. CALDER:
Yes.
I said thirty
. cubic?
MR. HUEBNER:
Yes.
MR. CALDER:
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30,000 cubic yards.
MR. HUEBNER a
Did everybody hear
tha t ?
Steven mentioned 30 cubic yards.
I believe
the information you have in front of you says
30,000 cubic yards of material would have to be
moved.
Okay.
Thank you, Steve.
I would like to begin.
I am going to be
working off the cards here.
I will go in the order
in which people have signed in.
The first person
..
wishing to make comment on the proposed cleanup
plan is Lillian Wylie.
If 1 pronounce your name
wrong, I apologize.
t probably will, and 1 think t
will try to spell the last names for the court
reporter here.
W-Y-L-I-E.
Lillian Wylie.
LILLIAN WYLIE a
Hello.
I am
here tonight, and 1 hope -- as you know, t have
been living with the contamination problem for
going on 15 years now, and I expect this to be
justice for you to listen to our feelings.
Well, we hope that this information on the
informal hearing has become a little more fo~al
tonight.
I will repeat myself in some cases,
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because the March 15, 1990 was not a matter of
record.
I consider myself to be a peaceful
resident of North Hampton.
1 have had public
servants in It\Y family.
I have been brought up to
be respectful.
Under these circumstances, you can
understand my disrespect to you tonight.
In 1983, Ruth Martin, a former Lafayette
Terrace resident, and I were known as the two crazy
ladies of Lafayette Terrace, screaming for nothing.
At that time, it was known as a Lafayette Terrace
problem.
Now our nightmare has become a
frightening reality not only for Lafayette Terrace
residents, but also for over 80,000 other residents
of the Seacoast area.
Clearly knowing the facts surrounding the
Coakley Landfill - North Hampton toxic site, the
State of New Hampshire and the United States
Environmental Protection Agency should tmplement
the best method of isolating and removing the
toxics and waste-plumes, restoring and making the
land usable again, protecting the aquifers and
environment, and recognizing and eliminating the
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this site.
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We at Lafayette Terrace and the people
of the surrounding area demand that a more
effective plan be sought and put into action
without waiting any further for the Environmental
protection Agency to negotiate costs with the
suspected responsible parties.
May I stress again that there are five
municipal water supplies within 13,000 feet of this
sitel
Greenland Well, 12,000 feet, Garland Well,
3,800 feet, and the Crenshaw, Jenness and Coakley
Wells owned and operated by the Hampton Water
Works, 12,000 to 13,000 feet from the site.
Here are some facts surrounding the toxic site.
(1) We know that the bedrock that protects our
aquifers which feeds our wells and municipal water
supplies was blown up and sold for crushed rock.
(2) We know that in 1975 a complaint was made
to the State of New Hampshire, although nothing was
done until 1983.
Fourteen years have passed
without any protection or solutions to the serious
matter whatsoever.
The only action being done is
testing wells, bureaucracy and connecting area
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serious danger.
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More than 80,000 residents will be
affected if the toxics hit the area municipal
welle.
(3) In 1987, a test well at the landfill only a
few hundred yards from Lafayette Terrace was
tested, and benzene was detected at 60 parts per
billion, twelve times higher than E.P.A.,
Environmental Protection Agency, standards.
Benzene also is known to be one of the mpst lethal
cancer-causing chemicals.
(4) It was reported to the press by the State
of New Hampshire and the Environmental Protection
Agency that our wells were being tested on a
regular basis fram 1983 to present.
Wells RW-25,
26 and 28 were tested in February and ~~rch of
1983.
These wells were the only -- these tests
were the only tests actually ever done.
According
to Figure 20, Volume 1 of the Remedial
Investigation Coakley Landfill - North Hampton
Toxic Site, done by the State of New Hampshire,
Department of Environmental Services Waste
Management Division, dated October, 1988;
Well
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toxi c.
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This alleged test on Well RW-28 was never
done.
This well 11es on my property and formerly
served 12 hanes.
It was shut off and closed in
1983 and has never been reopened or tested since.
(5) My hOme has been tested three times when
the ground was frozen and still showed lOll!' level.
of carcinogens I
Acetone, benzene,
1,1,1-Trich10roethane, Trichloroethylene, Toluene
9
and others.
Taking into consideration that we
drank several toxic chemicals in our well water
over an extended period of time, and have been and
still are breathing low levels of carcinogens in
our home. we do not know what all these toxic
combinations can do to our body metabolism, our
health, our personality or our children's learning
ability.
(6) It is known that radioactive waste called
Black Silt WAS dumped at the Coakley
Landfill -- North Hampton toxic waste site from the
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Portsmouth Naval Shipyard, and also we found out
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that asbestos bas been also dumped there.
There 1s
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also serious reason to believe that midnight
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occurred.
(7) A health study was requested for the area
surrounding Coakley Landfill - North Hampton toxic
4
site.
Instead we got a health assessment which
5
presented only what the State chose to present and
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was a disgusting injustice to the entire SeacO&at
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area.
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(8) There is a health risk to the area, and
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it's very likely it has already destroyed lives and
families.
Explain the little boy with neo-blastema
cancer, or the tragedies in Ruth ~~rtin's family,
her husband dead from enlarged kidney, heart and
liver, her adopted son, the same SYmptoms.
Lynne
and Roberta Martin have kidney disease and cannot
bear children.
They are not expected to live past
the age of 40.
An entire family destroyed.
In
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other homes, tucors have been detected and
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increased amounts of cancer-related deaths and
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illnesses.
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As a victim of this tragic disaster, 1 demand
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that the State and Federal Government agencies stop
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their beating around the bush and their games and
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constructive, unlike what they have proposed and
done so far.
Enough have suffered.
Stop
pretending this isn't a problem of unbelievable
proportions.
Stop playing chess with the laws and
money and help the people.
This isn't a political
game.
This a human issue.
Again, I repeat to you, we are innocent
victims, who aren't just eating too much peanut
butter.
Give us and our future generations a
future we can enjoy.
What you propose 80 far only
spells more nightmares, tragedy and disaster.
And I have something personal to the State of
New Hampshire that I would like to express.
What
bothers me about the State of New Hampshire and the
whole Coakley mess is that the State knew they were
contaminating our wells and letting us drink from
it.
The State wasn't going to tell us that they
were poisoning us, or what could have been
thousands of residents in the Seacoast area.
The
State of New Hampshire didn't care about D1Y family
. or anyone else' s.
In the State of New Hampshire, I
thought it was against the law to commit negligent
homicide or to be an accomplice to murder.
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put my family and many other families through a
living hell.
The State should have sat us all down
and gave us a glass full of arsenic, benzene, lead
mixed with all the other toxic chemicals instead of
the slow death they have now sentenced us with.
These kinds of cover-ups by the State and condoned
by the Federal Government must stop.
People.~re
angry allover the United States.
This is not just
happening in North Hampton, but allover the
country.
Here in this State of New Hampshire alone there
are 15 hazardous waste Superfund sites.
New Hampshire's cancer rates are ten times higher
than any other state.
People are concerned about
their loved ones.
As long as the records have been
kept, it is against the law to kill thy neighbor.
The State of New Hampshire and the polluters must
pay and dig deep so this won't happen in this state
or in any other state.
What the E.P.A. and the
S ta te of New Hampshi re have proposed and done so
far is a criminal act and must not continue.
Stop
this nightmare at once and start doing what your
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And in closing, I would like the Federal
officia18 to Fax a message to President Bush and
John Sununu.
Read my lips.
When are you going to
wake up.
No nuclear power plants.
No toxic sites.
Now the children would like to say something.
TAMMY WYL IE I
Hi.
My name i8
Tammy Wylie, and I --
MR. HUEBNER I
Excuse me for one
second.
. .
Let me indicate to the group here who had
requested to speak, it was Tammy Wylie, W-Y-L-I-E,
Jay Chase, C-H-A-S-E, and Shawn Wylie, W-Y-L-I-E.
TAMMY WYL IE I
My name is
Tammy Wylie.
I am nine years old.
I live at
Lafayette Terrace.
The children are victims, too.
We are always sick.
One little bay has cancer.
This isn't right.
Chemicals can kill me and my
friends.
JAY OiASE I
Hi.
My name 1s
Jay Chase.
I am 17.
I, like the other children
and young adults have lived in North Hampton almost
my whole life.
We are gathered here to ask you for
help.
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sometimes very scared what might happen to us or
our families if something is not done about the
toxic waste that is at Coakley Landfill right now.
This is why we are asking for (1) The toxic waste
does not get covered up, but actually taken away to
a designated toxic waste dump.
(2) That the land
will not be taken away.
We would like the v~luable
wetlands to be cleaned and restored for future use.
The victims of -- (3) The victims from the dumps
should be compensated, and (4) We just want
something done.
The children of Coakley Landfill are not
pointing fingers at anyone.
We just want sane
resul ts.
Last of all, us children are considered
tomorrow's future.
Please do not take this future
from us.
Thank you.
SHAWN WYLIE.
Hi.
My name i8
Shawn Wylie.
I live at Lafayette Terrace.
Our voice should be accepted for the record.
I
am here in defense of the babies, children and
young adul ts.
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to a problem and agree with the petition to be
presented by John Burns.
Before he speaks, the
children and young adults have their own petition
with 17 signatures.
Before the deadline of
May 14th, we will have more signatures.
Thank you.
MR. HUEBNER:
Thank you.
Thank
you very much for each of your comments.
The next person I would like to call on is
John Burns, B-U-R-N-S.
JOHN BURNS:
My name is
John Burns.
I am a Co-Chairperson for Citizens
Organized Against Seacoast Toxics.
First. I would like to thank the federal, state
and town officials present here tonight that are
interested and concerned in this matter.
The Coakley Landfill - North Hampton toxic site
has been on the national priority list now for
about seven years and still DO action has been
taken to clean up the site or protect the Seacoast.
. The Federal and State authorities have wasted
critical time doing nothing except covering up
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the Seacoast future health and well-being.
26
The cap
and treat method that was proposed has been shown
to be completely ineffective and unreliable.
In
fact, the Congressional Office of Technology
Assessment has completely discredited thi8 form of
so-called cleanup in their publication, Coming
Clean.
When there is a house fire, the fire department
immediately comes and extinguishes the fire.
After
it's put out, they determine the cause and
responsibility.
They wouldn't let the fire burn
while they make these determinations.
At Coakley,
this fire has been burning for 15 years.
Meanwhile
the State of New Hampshire, D.E.S. and the E.P.A.
focus on who is going to pay for it and how they
can cover the State's backside by using Superfund
Laws to hide their responsibility in using small
towns and businesses as scapegoats.
When will
State and Federal agencies provide and protect the
public and environment, start doing their duties
-and stop being evasive and unreliable.
What we have here in North Hampton is just a
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socially and environmentally destructive.
As a concerned citizen, I demand that all
involved begin to provide answers and solutions,
not Band-Aids and cover-ups.
There are
88,000 residents on the seacoast in danger of being
affected by the site and many who have already
been.
Stop whimpering and hiding and start
protecting the people.
On behalf of C.O.A.S.T. and the Concerned
Citizens of the Seacoast area, 1 now would like to .
\
present to the United States Environmental
Protection Agency, the State of New Hampshire
Department of Environmental Services and the State
of New Hampshire Attorney General's office this
petition that has been signed by 270 local
residents so far.
C.O.A.S.T. will continue to
circulate this petition until shortly before the
May 14 comment period deadline, and we will forward
all additional copies to the three parties stated
at that time.
It reads as follows I
As representatives of the
best interests of the concerned citizens affected
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Citizens Organized Against Seacoast Toxics,
C.O.A.S.T., hereby petitions the following te~8
which are endorsed by those signing below.
(1) Getting the job done.
We need the bes t
solution for all "the problems at and around the
Coakley Landfill- North Hampton Toxic Site.
To U8
this means more than the cap and treat clean~~
proposed by the united States Environmental
Protection Agency.
The ,toxics and waste-plumes
must be isolated and removed1 the landfill itself
must be restored to safe and usable condition1 the
aquifers and environment must be protected and the
health problems and future threats must be
recognized and eliminated.
(2) Human issues.
The Coakley Landfill - North
Hampton toxic site is not only an environmental
problem, but also a serious health and
economic issue of major proportions.
Irrrnediate
and full-value relief and assistance to the
individuals, families and homes most affected by
the site in North Hampton, Greenland and Rye must
be part of any plan plus additional help for other
victims:
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towns and others.
29
Even if this requires evacuation
and relocation and/or purchase of property.
(3) Health study.
The United States Government
sponsored Health Assessment done in 1988 i8 totally
unacceptable as a picture of past, pre8ent and
future problems caused by the Coakley
Landfill - North Hampton toxic site.
Anew
government-funded comparative health study that i8
scientific, impartial and agreed to and
participated in by the residents and their own
..
expert advisors must be done.
This is as urgent
and important as any work that may be considered on
the toxic site itself.
(4) Horses before carts.
Federal Law requires
the United States Environmental Protection Agency
to take action first again8t the toxic sites, and
then to recover cleanup costs from polluters, not
the reverse.
Therefore, we will not wait until the
U.S. E.P.A. negotiates a settlement with the
suspected responsible parties.
This is unlawful
and inhumane.
(5) The State of New Hampshire.
The question
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identifying those who ultimately deposited toxics
at the Coakley Landfill - North Hampton toxic site.
Because it was responsible for reviewing,
licensing. per.mitting, monitoring and otherwise
managing affairs concerning the aite, the State of
New Hampshire must be held &s a major party in thi8
serious matter. including the financial burden of
the entire plan.
(6) Accountability.
The Coakley
Landfill - North Hampton toxic site did not
magically become one of our countries most
contaminated and dangerous locations.
There must
be a c~~plete investigation into the government and
business practices that caused this problem.
Who
is involved and what, when and how were local.
state and federal laws violated, followed by public
disclosure and civil and criminal prosecution.
(7) No 10s8 of land.
We will not accept the
1088 or sacrifice of this valuable site and
wetlands to any cleanup action.
The land must be
'"
. returned to safe and agreeable conditions,
deter.mined and agreed to by the concerned citizens
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chosen experts and advisors.
Is there eom8one here fran the State of
New Hampshire Attorney General's Office?
VOICE.
Yes, I am.
JOHN BURNS.
Here is copies.
Should I bring them up there?
MR. HUEBNER.
Are they copies of
the petition?
JOHN BURNS I
Yes.
(Documents handed to the Hearing
Committee.)
MR. HUEBNER:
Okay.
Thank you
for your comments.
The next person that requested to speak was
Martha Bailey, B-A-I-L-E-Y.
MARTHA BAILEYa
lam
Martha Bailey of the New Hampshire Toxic Hazards
Campaign.
The essential goal of the Superfund Program is
to clean up land and water that are so contaminated
that they constitute threats to human health and
the environment.
On paper, the program is supposed
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supposed to set up cleanup goals that will protect
human health and the environment, then select
remedies that will meet these goals, and finally
find the responsible partie8 to pay for cleanup, or
otherwi8e use government funds.
In reality, the
program is working backwards here.
An amount of
money for partial cleanup has been chosen that
responsible parties might be willing to spend, and
then cleanup technologies were selected that could
be carried out within the budget.
Superfund as
amended (SARA) requires permanent cleanup, wherever
it i8 feasible.
By law, the E. P. A. is allowed to
consider cost only after having chosen effective
permanent alternatives and solutions that will
adequately protect health and the environment.
The
E.P.A. is never justified in selecting a short-term
remedy, that is capping, simply because it is
cheaper than a permanent alternative.
Has the
E.P.A. analyzed the risk of cap failure, damage and
cleanups for this containment?
The tide fran the
. Atlantic Ocean ebbs and flows twice a day acting
like an oscillating pump at this site.
Here the
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containment, when SARA says cost-effectiveness
analysis is to be used.
The fact that the E.P.A.
has no intention of cleaning the 80il that will be
removed from around the site before being placed
atop the landfill is criminal.
All residents
within a half mile should be evacuated while this
operation takes place.
The first oil spill dumped at Coakley, now
covered up in Greenland and next to the nuclear
black silt dumping, now covered up near the
railroad tracks, should be removed, as well as the
second oil spill dumped at the left of the main
gate as you enter Coakley, and to be disposed of
properly.
We will know you have removed the
nuclear waste when you can show us a picture of a
shoe that became stuck in the goo and had to be
abandoned in the goo.
Incidently, the second oil
apill was to be removed by the State of
New Hampshire within three weeks.
The dumping of
the oil spills were pe~itted by the State.
Groundwater moves because it is pulled by
gravity.
Its ultimate destination is the nearest
ocean.
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will not cleanse itself as surface water does.
There is very little bacteria, no sunlight, and the
water is relatively cool.
For these reasons~
contaminated groundwater tends to remain
contaminated for eons of time.
The E.P.A. began
using pump and treat technology at many groundwater
contaminated 8ites years ago.
Pump and treat means
..
that the groundwater is pumped to the surface and
is treated in some fashion to remove contaminants.
A large body of scientific evidence has now
accumulated showing that pump and treat does not
work, and given today's knowledge cannot work for
the following reasonsl
Much contamination attaches itself to the soil
particles, therefore using water samples to
estimate the amount of contamination will result in
major underestimates of the size of the problem.
Number two, soil and rock formations below
ground are not uniform.
Using an average flow rate
could greatly underestimate the time it will take
to flush contaminents out of part8 of the aquifer
through which water moves slowly.
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remediation technologies, it is not possible to
locate all significant contamination, nor can
anyone predict contaminant movement, fate, exposure
or remedial technology performance.
Number four.
Many contaminents do not mix
readily with water.
Chlorinated solvents are an
example.
We should expect to have to pump and
treat in the foreseeable future with no end in
sight.
If most of the contamination is not being
removed by pump and treat, someday the money will
run out for maintaining the pumps, and on that day,
the contamination will resume its natural movement,
and citizens will be threatened again.
A carbon filter will not remove acetone and
Tetrahydrofurans.
They go right through the
filter, as the E.P.A. experienced at the Tibbets
Road Superfund site.
Therefore, an afterburner
must be used to destroy these volitiles.
Pump and
treat i8 not a permanent remedy.
Has the
E.P.A. analyzed the risk, the damages and cost of
cleanup for pump and treat failure?
Before any
Record of Decision is signed, we would like to see
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pump and treat and containment failures.
At one time it could -- and it could still be
happening when the tide was coming in you could see
the contamination bubbling up into the river.
The
Little River is in the wetlands to the west of the
si tee
This will probablY continue cap or no cap,
pump and treat or no pump and treat.
At the same
time, you could see the contamination from Coakley
at low tide at the ocean.
There are five municipal wells around Coakley
supplying drinking water to 88,000 people.
We do
not find your solution to the cleanup of Coakley
Landfill anywhere near adequate.
The wetlands
where the contamination is being pushed to are
being completely ignored.
Many types of game
animals and birds live in these wetlands, and much
hunting and fishing in the river takes place in
these wetlands.
There is a human exposure here as
well as an environmental exposure.
You are not
addressing this issue, yet you repeatedly say,
-Protective of human health and the environment-.
Alternative SC-6 is the most permanent of the
alternatives given.
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contamination is removed, it leaves only the
surrounding groundwater and wetlands to be cleaned.
Because of the potential risks .from air emissions,
we recommend evacuation of residents within a
radius of a half mile during the excavation and
soil treatment process.
On December 7, 1987, Lillian Wylie wrote
Doctor Barry Johnson, head of the A.T.S.D.R.
program and asked him for a heal th study at Coakley
Landfill/Lafayette Terrace area.
She received only.
a health assessment from A.T.S.D.R.
We are now
formally asking the E.P.A. to demand a comparative
health study that is scientific, epidemiological
and impartial as stated in the petition.
(Applause.)
MR. HUEBNER I
Okay.
Thank you
very much.
The next person that requested to speak was a
John Doggett. D-O-G-G-E-T-T.
JOHN DOGGETT:
Thank you.
I am
really concerned.
I just found out that I am a
member of the Superfund, and therefore I guess we
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I would like to know has there been any input
brought from the Federal Government in regard to
what the Pease Air Force Base has contributed to
thi s dil emma tha t we know we have. and also I have
a question for the State pertaining to the dump.
Why i8 this dump not corraled by way of a chain
link fence. and nobody can get in there?
MR. HUEBNER I
Okay.
Just to
clarify again.
The purpose of the hearing is
really not for us at this point in time to respond'
to a lot of the questions that you had.
There was
a public information meeting that took place a week
and a half or two weeks ago, which I don' t know
whether or not you were in attendance.
JOHN DOGG ETT I
Yes, I came
March 15th, and this is a carbon copy of the
March 15th meeting.
MR. HUEBNER I
Okay.
JOHN DOGGETT I
And I. was
wondering if you had any. input from the March 15th
meeting back to us townspeople.
MR. HUEBNER I
Okay.
Could you
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and Steve, are you aware of what this gentleman 18
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talking about?
3
DAN COUGHLIN:
Yes.
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MR. HUEBNER:
Could you speak to
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these tWo gentleman at the conclusion of the
6
hearing?
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JOHN DOGG E'l'T :
Thank you. .
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MR. HUEBNER:
Okay.
9
AUDIENCE PARTICIPANT:
We all
want to hear.
.
AUDIENCE PARTICIPANT;
All the
answers were presented on behalf of the entire
audience.
The answer should be given to the entire
audience.
MR. HUEBNER:
Okay.
At the
conclusion of the hearing -- all right -- let's
17
answer those questions, is that acceptable?
18
AUDIENCE PARTICIPANT:
Sure.
19
AUDIENCE PARTICIPANT.
Will it
20
go on record?
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MR. HUEBNER.
It will go on
22
record.
All right.
I don't want this to get out
23
of hand in terms of opening this up.
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everyone to have the opportunity to speak.
40
So I
will tell you what.
How about if we run through
the remaining people that have asked to speak, and
then we will cane back to you.
Yes, sir.
AUDIENCE PARTICIPANT.
I was
going to suggest that Mr. Doggett be called ~e
last, if you place hi. card in the back.
MR. HUEBNER:
I will do that.
I
will do that.
AUDIENCE PARTICIPANT:
Thank
you.
MR.. HUEBNER.
Okay.
The next
person is Elmer Sewall, S-E-W-A-L-L.
ELMER SEWALL J
My name is
Elmer Sewall.
I live on Breakfast Hill Road in
G reenl and.
I own the land that is north and west of the
Coakley Landfill.
I have a monitor well in one of
my fields, which has shown same evidence of
contamination.
I have a house in a field opposite,
which I rent which is now without water, and I
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the possible contamination problem.
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I had had
opportunities twice to s811 a piece of land, and it
has fallen through because of this being adjacent
to the landfill and because there has been evidence
of contamination in that field, and it also appears
that my CMn well has shown recently some evidence
of contamination which presumablY comes from ~e
Coakley fill.
Now it also seems to me that in reviewing the
proposals much of this is predicated on the fact
that areas to the south and east have already been
supplied with municipal water.
On Breakfast Hill
Road, we do not have that privilege, and I am a
little concerned that these proposals don't take
that into account, and the migration factor is not
at this point being considered.
It would seem to me that these plans fall a
little short of protecting us on Breakfast Hill
Roa d.
There aren't that many of us. and perhaps we
don't speak loud enough. but I would like to put
. this on the record that VB have these concerns.
10m. HUEBNER:
Okay.
Thank you
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The next person is Greg Lincoln, L-I-N-C-O-L-N.
JEAN GREGG LINCOLN a
Jean Gregg.
MR. HUEBNER:
Jean Gregg.
lam
sorry.
JEAN GREGG LINCOLN.
lam
Jean Gregg Lincoln fran North Hampton, and I just
would like to go on record and say I don't think we
have the very best technology today to bring us to
this cleanup.
I doubt that the current proposal is
tha t .
I am particularly concerned for the wells
that Mrs. Wylie spoke of.
I think that some of
those wells probably draw water as far away as
Seabrook.
I also would like to just read some small
things that concern me about what happens to the
water that goes down into the marshes into the
ocean.
I think we have to do a particularly fine
job because of the people who live all the way down
through that estuary and all the people who come to
our beaches.
This comes from a study done this
year in January.
It's called Objectives and
Concepts of Contaminated Underwater Sediment or
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January 1990.
43
I will just take a small piece out
of it.
Findings, according to a 1987 study
conducted by the E~vironmental Protection Agency,
E.P.A., it is likely that every major river and all
types of water bodies in the United States have
contaminated underwater sediments.
These sediments
pose a threat to the health of fish, shellfish,
wildlife and humans through food chain and/or
direct exposure.
Sediments can be a primary source
of contamination exposing living organisms and the
environment to toxics.
Many examples exist of fish
contamination warnings or bans due to contamination
by PCBs, mercury and dioxins and other pollutants
released from sediments.
When I was here at the last meeting, I spoke of
some concern about the runoff from this site, this
toxic site, and a gentleman from the D.E.S. said
that there was nothing to worry about, that down
the river the birds and the bunnies would be fine,
and I found that a little shocking, and I just want
to put it on the record that I don't accept that
kind of comment with this sort of serious toxic
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Thank you.
MR. HUEBNER I
Thank you for your
comment.
Do we have any other carda?
All right.
Is there anybody else that wishes
to make some comments at this point in time?
You do. sir.
Okay.
Stuart Leide~n. L-E-I-D-E-R-M-A-N.
STUART LEIDERMANI
1 just have a
couple of brief remarks.
The first is 1 think that.
it's very important to put it on the public record
the qualifications and past experience and history
of success as project manager for this particular
proj ect.
I think there probably won't be any
objection to something like that.
Because of the
way in which the projects are delegated first to
the regional offices and then to the various people
who are competent and experienced, the fate of the
proj ect really must rest in the hands of the
proj ect manager, and 1 am glad that Mike 1s here
tonight, and I am sure that it makes a lot of
difference to those of us affected by this problem
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entirely satisfied that he was the person for the
jOb and we were in good hands.
So 1 think that
would go a long way towards having a good rapport.
It goes on in a periocl of time.
The second thing 1 would like to say i. that
it's very clear to me that fOllowing the letter of
the law of the Superfund per .e will not enti,rely
solve the problem and I do believe that the only
thing that will be satisfactory is a composite
attack on this problem, where E.P.A. is acting not ~
only on the Superfund area but enacting laws and
regulations and other ways to address problems not
specifically in regard or reference to Superfunds.
I think it's very ilnportant for the E.P.A. to
report to us all the other ways that it can use
congressionally delegated powers, executively
delegated powers, regulations, administrative
procedures, so on and so forth, to address what we
have been describing as basically loose ends, but
significant loose ends that surround this entire
. probl ern.
I also believe that we need to bring in other
federal agencies.
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alone describes this as more than a Superfund
problem, and I believe the solutions would rest
with many other agencies and levels of government
involved in it, and certainly public health areas
and planning and development in the Federal
Government and many. others.
At the State level,
there is no question that their corresponding,
agencies must be involved, because of the
addi tional things other than just the Superfund
site itself that is defined in the Federal
Superfund Law.
Also local government must be
involved with this.
Also business organizations,
such as Chambers of Commerce, planning and
development organizations and agencies,
quasi-governmental groups in this area, all who
have entered in advocating, permitting, allowing,
watching, monitoring of any area in promoting the
use of that site as the place for which -- for I
suppose 10 to 12, 13 years was the place where
waste was permitted to go.
So that point addresses the need for a
solution.
The solution does hold to the Superfund,
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what office, what agency and which person.
47
Will it
be the project manager that 1s here before us
tonight, someone who may not be here, or someone
who 1s not designated yet?
There must be a lead
person or an agency to develop a comprehensive
solution to this, because beyond simply what is
covered under Superfund, I think it has been a lot
that E.P.A. has responded finally to this official
end to what it considers it to be its perhaps most
topical way of responding to the problem.
And, you -
know, you deserve our respect for that; however, it
does not respond to the problem as it's presented,
and we expect that the number of people sitting at
the tables at hear1ngs from now on will probably
have to be broadened quite a bit, which would
include also s~e kind of meaningful public
participation program similar to the
Clean Water Act.
I continue to be surprised,
shocked, dismayed that there isn't already a
designated citizens' committee that would work
.alongside with officials, as is customary in water
pollution control areas involving the environment,
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at least three plus a number of people involved and
concerned would be a great help.
The last thin~ I would like to say is a
historical note that may help put this in
perspective and perhaps help us evoke fran you the
kind of information we need, which is what we are
going through right now is preventing you from
being on our eide in every way.
We need to know
tha t.
It was only about -- oh, it was about two years
\
ago early March when myself and t:: :~ge associates
drove into Ponca City, Oklahoma on a rainy, cold
morning very much like we have today.
For many
years Ponca City -- the residents of Ponca City,
Oklahoma have been involved in a similar type of a
problem.
I am sure some of you are familiar with
what happened there.
It's the home to a Conoco oil
refinery that got out of control.
Contamination
there went uphill.
In the center of that town was
an iron casket to name the people who have died in
that town as a cause of the operating of the
refinery.
People died of rare, exotic metabolic
diseases.
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years, and in recent years they even camped out on
the lawn at the State Capitol, and this morning it
was announced that Conoco was offering to buyout
that town, essentially a $23 million purchase of at
least 400 hanes.
Now I believe that that is
totally without precedent and history of those who
have been experiencing these kinds of probl~$.
I
also believe it's totally without precedent in
terms of raising defiance of the public spirit,
which we are all good neighbors and must live as
good neighbors.
I believe that offer will be
rejected out of hand.
It doesn't begin to solve
the problem, and it will only move the people out
and pollution in there, and I certainly don't want
to see that kind of thing befall this part of the
country as well.
Those of us who are concerned about these
things, some qualified experienced people,
technical people, citizens who are lay people bave
been raising these issues for years, and I cannot
recall one time when we have ever really known, and
it's just a matter of time where all of us will
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down the road may be, and the ones that haven't yet
been discovered.
We have got to decide on working
together on these things and using all of the
resources and solving the problem the way it
presents to us, not redefining the problem.
So if
one is to be helpful, I think that we may be able
to find a solution.
Thank you.
MR. HUEBNER:
Thank you.
Are
there other people that wish to comment at this
time?
Anybody else?
Okay.
John Doggett.
JaiN DOGGETT:
Number one, I
just want to know from the E. P. A. are they going to
do anything about putting a fence around that?
That is just a question.
That is the first one.
MR. HUEBNER:
Okay.
Coul d you
repeat that again, please.
JOHN DOGGETT:
We have a problem
here.
We have got a dump in our Town of
North Hampton.
We all know we have problems, and
it's polluted.
Can the State and not the town do
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keep anybody from going in there until something is
done?
!om. HUEBNER I
Okay.
We
understand the question.
Can we give this
gentleman an answer now or --
MR. COUGHLIN a
I can give you
the answer that we gave about a year ago rel~tive
to the fence.
Our removal people evaluated the
site and the condition of the cover that was on the
site.
The people from the A. T. S. D. R. evaluated the.
site and wrote a report, which the site would be
protected from public health if the cover was
properly maintained, and there were signs posted
around the si te.
They do not feel that a fence at
this point in time was absolutely necessary.
Now a
fence is part of the final remedy here as we get
into the process and start implementing the
cleanup.
JOHN DOGGETT:
So it's posted
then.
MR. COUGHLIN.
It's in posted
areas of a six-inch cover over the entire site.
JOHN DOGGETT:
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to the western side?
MR. COUGHL IN.
I am sorry .
JOHN DOGGE'l"1'.
Is that on the
western side of the dump?
MR. ROBINETTE.
That is the
entire landfill.
The towns of North Hampton,
Portsmouth, and Coakley Landfill, Incorporat~d
received an administrative order telling them to
cover those portions of the ash that were exposed
with six inches of cover and then to maintain that
cover.
JOHN DOOGET'l'.
The ash came in
"
from Pease Air Force Base?
MR. ROBINETTE.
Yes.
JOHN DOGGETT.
Second question
is can the Federal Government who represents Pease
Air Force Base represent wbat is in the ash, the
chemicals from Pease Air Force Base?
And the
reason I ask this i6 prior to the Coakley dump, in
this little Town of North Hampton we had a dump in
South Hampton, which was filled up over the years,
and we had to have a new one.
Hence we moved the
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Pease Air Force Base.
There was never any
pollution before. but now all of a sudden we have a
lot of it.
A lot of it is corning from outside the
town dumping there.
So therefore, my question 1s
once again:
Can they te 11 - - can the
Federal Government tell us specifically what was
dumped there from government installations?
MR. COUGHL IN:
We can tell you,
as you already know. it was ash deposited there
from the resource recovery facility of the trash
incinerator on the Pease Air Force Base.
AUDIENCE PARTICIPANT:
How about
speaking into the microphone.
MR. COUGHLIN:
I am sorry .
JOHN DOGG I'M' :
Thank you.
MR. COUGHLIN:
We can tell you.
as you have already suggested, that there was ash
disposed of at the site fram the Pease Air Force
Base.
It was from an incinerator run by the City
of Portsmouth taking trash and waste from
"surrounding communities as well as Pease itself.
We have in the administrative record at the library
the chemical analyses of all that Ash material.
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also are aware of suggestions that other waste
materials were disposed of in landfills from the
Pease Air Force Base.
We are still in the process
of evaluating and investigating those allegations.
That is all 1 can tell you.
We can show you what
is in the landfill based on the data that we got
during the investigation.
JOHN DOGGETT a
The other items
that we mentioned will that become a public record?
MR. COUGHLIN:
It's all part of "
an enforcement case that is being developed not
only just for the involvement of Pease but all the
responsible parties.
How much actually would be
made public is really subject to question at this
time.
JOHN DOOGETTa
Thank you.
MR. HUEBNER a
Okay.
Are there
any other people that wish to make comment at this
point in time?
AUDIENCE PARTICIPANTa
1 have a
question if I can get an answer.
Is thi &
transcript going to be made available to the
people?
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available and all the results of your findings?
1
am wondering if this transcript and the results of
your findings are going to be made available here
to the public.
MR. COUGHLIN,
The transcript,
yes, will be made available.
The data that I am
referring to is available already.
AUDIENCE PARTICIPANT,
I mean
the transcript of this.
MR. COUGHLIN:
Yes.
Yes,
absolutely.
No question about it.
MR. HUEBNER I
Okay.
Any other
comments?
Again I thank you all for coming.
Remember I
reminded you that the deadline for getting your
written comments in is March 14, 1990.
AUDIENCE PARTICIPANT,
May.
May.
May.
MR. HUEBNER,
May 14.
Sorry.
Thank you.
May 14, 1990.
Thank you for coming.
-------
10
11
12
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14
15
56
1
hearing was adjourned.)
2
3
4
5
6
7
8
9
16
17
18
19
20
21
22
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1
2
3
4
5
6
7
8
9
10
11
12
. - 13
14
15
16
17
18
19
20
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57
C E R T I FIe ATE
-~-----
... ... ... ...
I. Marianne Kusa-Ryll. Registered ProCessional
Reporter. hereby certify the foregoing to be a true
and complete transcript of the proceedings held at
North Hampton Elementary School. 201 Atlantic Avenue,
North Hampton, New Hampshire, on Tuesday, April 3, 1990.
A IA ~(~;~,~~ :Jf!.~ J:/ 1-
-------
ATTACHMENT D
-------
United Stat-
Environmental Prot8ction
Agency
Office of
Solid Wate and
Emergency Re8ponM
Publication No. 9230.1 ~S
Januaty 1990
&EPA
Superfund Technical
Assistance Grants
Office of Emergency and Remedial ReeponM
Hazardou8 Site Control Divltion (05-220)
Ouick Reference Fact Sheet
WHAT ARE TECHNICAL ASSISTANCE GRANTS
Bad~un4 of Prottrrun - In 1980, the Comprehensive Environmental Response. Compensation'and
Uability Act (CERCLA) - otherwise known as .Superfund. - established a tnlSt fund for the cleanup of
hazardous waste sites in the United States, CERCLA was amended and reauthorized when Congress passed
the Superfund Amendments and Reauthorization Act (SARA) of 1986. The U.s. Environmental Protection
Agency (EP A), working in conccn with the States, is responsible for admini~tering the Superfund program.
An important aspect of the Superfund program is citizen involvement at the local level in decision-
making that relates to site-specific cleanup actions, For this reason, community ouueach activities are
underway at each of the 1,200 sites that are presently on, or proposed for listing on, the National Priorities
List (NPL), The NPL is EP A's published list of the most serious abandoned or otherwise unconuolled'
hazardous waste sites nationwide, which have been identified for possible remedial cleanup under Superfund.
Rea>gnizing the importance of community involvement and the need for citizens living near NPL sites
10 be well-informed, Congress included provisions in SARA U) establish a TechDical Assistance Grant
(TAG) Program intended to foster informed public involvement in decisions relating U) site-specific cleanup
strategies under Superfund.
In addition to regulatory and legal requirements, decisions concerning cleanup initiatives at NPL sites
must take into account a range of technical considerations. These might include:
.
Analytical profiles of conditions at the site;
.
The nature of the wastes invotved; and
e
The kinds of technology available for performing the necessary cleanup actions.
The TAG Program provides funds for qualified citizens' groups to hire independent technical advisors to
help them understand and comment on such technical factors in cleanup decisions affecting them.
&sic Prrrrision.s of 1M TecJuaiad A.ssisIIJna Grants Prwnun
.
Grants of up to SSO,
-------
USES OF TECHNICAL ASSISTANCE GRANTS
Citizen groups may use grant funds to hire technical advisors to belp. them understand information
that already exists about the site or information developed during the Superfund cleanup process.
Acceptable uses of these grant funds include payments to technical advisors for services sucb as:
.
Reviewing site-related documents, whetber produced by EPA or others;
~.~..::.:.ing ..ith the recipient group to explain technical information;
Providing assistance to the grant recipient in communicating the group's site-related concerns;
Disseminating interpretations of technical information to the community;'
Panicipating in site visits, wben possible, to gain a better understanding of cleanup activities;
and
Traveling to meetings and hearings directly related to the situation at the site.
.
.
.
.
.
TAG funds may not be used to develop new information (for example, additional sampling) or to
underwrite legal actions in any way, including the preparation of testimony or the hiring of apen witnesses.
You can obtain a complete list of eligible and ineligible uses of grant funds by contacting your EPA
Regional Office or tbe Headquaners information number listed at the end of this pamphleL In addition,
this information is included in the EPA publication entitled The Citizens' GuidJJnce Manual/or lhe Technical
Assistance Grant Program (OSWER Directive 9230.1-03), also available from your Regional EPA Office.
WHO MAY APPLY
As stated in the 1986 Superfund amendments, groups eligible to receive grants under the TAG
program are tbose whose membership may be affected by a release or threatened release of toxic wastes at
any facility listed on the NPL or proposed for listing, and wbere preliminary site work has begun. In
general, eligible groups are groups of individuals who live Dear the site and whose health, economic well-
being, or enjoyment of the environment are directly threatened. Any group applying for a TAG must be
nonprofit and incorporated or working towards incorporation under applicable State laws. Applications are
. encouraged from:
.
Groups that have a genuine interest in learning more about the technical aspects of a nearby
hazardous waste site; and
Groups that have, or intend to establish. an organization to manage a grant efficiently and effectively.
.
For example, such groups could be:
.
Existing citizens' associations;
Environmental or health advocacy groups; or
Coalitions of sucb groups formed to deal with community concerns about the hazardous waste site
and its impact on the surrounding area.
'.
.
Groups that are not eligible for grant funds are:
.
Potentially responsible panies: any individuals or companies (such as facility owners or operators. or
transporters or generators of hazardous waste) potentially responsible for, or contributing to, the
contamination problems at a Superfund site;
Academic institutions;
Political subdivisions; and
Groups established and/or sustained by governmental entities (including emergency planning
com:;1iltccs and some citij,~'j~ 3~hisory grl)ups).
.
.
-------
BOW TO APPLY FOR A GRANT
RtJTUimrrmts - When applying for a TAG, a group must provide information to EPA (or to the Slate,.
if the State is administering the TAG program) to determine if the group meets specific administrative &Del
management requirements. The application also must include a description of the group's history, ~
and plans for using the te.chnical assistance funds. Factors that are panicularly important in this evaluation
process include:
.
The group's ability to manage the grant in compliance with EPA grant and procurement regulations;
The degree to which the group members' health, economic well-being, and enjoyment of the
environment are adversely affected by a hazardous waste site; -
The group's oommitment and ability to share the information provided by the technical advisor with
others in the community;
Broad representation of affected groups and individuals in the community; and;
Whether the applicant group is nonprofit and inoorporated for TAG purposes. (Only incorporated
groups may receive grants. Groups must either be incorporated specifically for the purpose of
addressing site-related problems or inoorporated for broader purposes if the group has a substantial
history of involvement at the site.)
.
.
.
.
In general, a group must demonstrate that it is aware of the time commitment, resources, aud
dedication needed to successfully manage a TAG. Applicant groups should consult The Citiuns' Guidiuaa
Manual For TM Technical Assistanct Grant Program for detailed instructions on how to present such
information.
Notifictzlion Proa!tluns and Evaluation 0iJeria - The 1986 Superfund amendments state that only one
TAG may be awarded per site. To ensure that all eligible groups have equal access to technical assistance
and an equal opponunity to compete for a single available grant (if a coalition of groups proves to be
impossible), EPA has establisbed a formal notification process, which inClu~es the following steps:
.
Groups wishing to apply for a technical assistance grant must first submit to EP A a shan letter
stating their group's desire to apply and naming the site(s) involved. If site project work is already
underway or scheduled to begin, EP A will provide formal notice through mailings, meetings, or other
public notices to other interested panies that a grant for the site soon may be awarded.
Other potential applicants would then have 30 ciays to contact the original applicant to fonn a
coalition.
If potential applicants are unable to fonn a coalition, they will notify EP A within this time period
and EP A will aa:ept separate applications from all interested groups for an .additional 30-day period.
EP A would then award a grant to the application that best meets the requirements described above.
.
.
.
The maximum grant that can be awarded to any group is $50,000. The actual amount depends on
what the group intends to aa:omplish. A group's minimum contribution of 20 percent of the total costs
of the technical assistance project can be covered with cash and/or .in-kind. contributions, such as office
supplies or services provided by the:: group. These services might include, for example, publication of a
newsletter or tbe time an aa:ountant donates to managing tbe group's finances. The value of donated
professional services is determined based on rates charged for similar work in the area.
In special cases where an applicant group intends to apply for a single grant covering multiple sites
in close proximity to each other, EP A can allow a waiver of the S50,000 grant 1imit. In ~uch cases, h(No"ever.
thc recipient c.'mnot receive morc than $50.000 for each site to which it intends to apply fund$ (example:
3 sites x SSu,!!')) = maximum gr::nt amount of S1)O.O(X))"
I
.
-------
CHOOSING A TECHNICAL ADVISOR
When choosing a technical advisor, a group should oonsider the kind of technical advice the group
needs most and whether a prospective advisor has the variety of skills necessary to provide all of the advice
needed. Each technical advisor must have:
.
Knowledge of hazardous or toxic waste issues;
.
Academic training in relevant fields such as those listed above; and
.
The ability to translate technical information into terms understandable to lay persons.
In addition, a technical advisor should have:
.
Experience working on hazardous waste or toxic waste problems;
.
Experience in making technical presentations and working with oommunity groups; and
.
Good writing ski11s.
Technical advisors will need specific knowledge of one or more of these subjects:
Cbemistry: Analysis of the chemical oonstituentS and properties of wastes at the site;
Toxicology: Evaluation of the potential effects of site oontaminantS upon human health and the environment;
Epidemiology: E~uation of the pattern of human health effectS potentially associated with site
contaminantS;
Hydrology and Hydrogeology: Evaluation of potential oontamination of area surface water and ground-water
wells from wastes at the site;
Soil Science: Evaluation of potential and existing soil contamination;
Umnology: Evaluation of the impact of site runoff upon the plant and animal life of nearby streams, lakes,
and other bodies of water;
Meteorology: Assessment of background atmospheric conditions and the potential spread of contaminantS
released into the air by the site; and/or
Engineering: Analysis of the development and evaluation of remedial alternatives and the design and
construction of proposed deanup actions.
A grant recipient may choose to hire more than one technical advisor to obtain the combination of
skills required at a particular site. For example, a group may be unable to find a single advisor experienced
in both hydrology and epidemiology, two of the skills most needed at itS site. Another approach would
be to hire a consulting firm that bas experience in aU the needed areas. The Citizms' Guidance Manual for
1M Technit:al Assistance Grant Program identifies other issues that citizens' groups may wisb to consider in
-------
ADDmONAL INFORMATION
For further information on the application process or any other aspect of the TAG program, please .
contad your EPA Regional Office or call the national information number, both of which are listed below.
An application package is available free by calling the EPA Regional Office for your State (see map on back
cover). Each application package includes aU the necessary application and certification forms as weU as a
copy of The Otiun's Guidance Manual For The Technical Assistance Grant Program. This manual contains
sample forms with detailed instructions to assist you in preparing a TAG application.
EPA Superfund Offices
EPA Region 5
Emergency and Remedial
Response Branch
230 S. Dearborn Street
Chicago, IL 60604
(312) 886-1660
nIinois, Indi4na, Michigan, MinMsota, Ohio,
WISconsin
EPA Headquarters
Office of Emergency & Remedial
Response
401 M Street, SW
Washington, DC 20460
(202) 382-2449
EP A Region 1
Emergency and Remedial
Response Division
John F. Kennedy Building
Boston, MA 02203
(617) 573-5701
Connecticut, Maine, Massachusetts, New Hampshire,
Rhode Island, Vennont
EP A Region 2
Superfund Branch
26 Federal Plaza
New York, NY 10278
(212) 264-4534
New Jersey, New York, Puerto Rico, Vitgin Islands
EPA Region 3
Superfund Branch
841 Chestnut Building
Philadelphia, P A 19106
(215) 597-3239
Delaware, District of Columbia,
Pennsylvania, Virginia, West Virginia
Maryland,
EPA Region 4
Emergency and Remedial
Response Branch
345 Courtland Street, NE
Atlanta, GA 30365
(404) 347-2234
Alabama, Florida, Georgia, Kentucky, Mississippi,
North Carolina, South Carolina, Tellllessee
L-
EPA Region'
Superfund Program Branch
Allied Bank Tower
1445 Ross Avenue
Dallas, TX 75'1JJ2-1:733
(214) 655-2200
ArkDnsas, LouisiaM, New Mexico, Oklahoma, Te:ms
EPA Region 7
Superfund Branch
726 Minnesota Avenue
Kansas City, KS 66101
(913) 236-2803
Iowa, KDnsas, Missouri, Nebraska
EP A Region 8
Waste Management Division
1 Denver Place
999 18th Street
Denver, CO 80202-2413
(303) 564-7040
Colorado, Montana, North Dakota, Soudl Dakota,>
-------
EP A Region 9
Superfund Programs Branch
215 Fremont Street
San Francisoo, CA 94105
(415) 454-744-1766
ArizoM, CaJjfomitJ, Guam, Hawaii, NevadtJ,
American Samoa
EPA Region 10
Superfund Branch
1200 6th Avenue
Seattle, W A 98101
(206) 442-0603
Idaho, Oregon, Rtilshington, Alaska
SuperfundIRCRA Hotline
(800) 424-9346 or 382.3000
in the Washington, DC, metropolitan area (for information on programs)
Nadonal Response Center (800) 424-8802
(to repon releases of oil and b.a.zardous substances)
_.~
EP A Superfund Offices
q,~
~
-------
APPENDIX D
-------
ROBERT W. VAR.'\EY
CO~I~IISSIOSER
TTY/TDD 1-800-992-3312 or 225-4033
\\:o\STE MA."\AGEMENT COUNCIL
G. BRADLEY RlCH.~RDS. CIwrman
ROBERT WHEELER. \"lc"CIwrman
WILLIA~1 AR.'iOLD
ROBERT BrRROWS
\"lRGISIA IRWiS
WILLlA~1 )ESSESS
)OHS LAVALLEE
)OHS LECRAW
FREDERICK MCGARRY
JOHS OSGOOD
LORRAISE SASDER
T. TAYLOR EIGHMY. PI1.D.
State of New Hampshire
DEP.-\RT~IE:\" OF E2'.~IRONME2'.lAL SERVICES
\\:.\STE )I!~'I;AGE)IE~T DIVISIO~
6 Hazen Drive, Concord. NH 03301-6509
603-271-2900
PHILIP j. O'BRIEN
DIRECTOR
MICHAEL A. SILLS, Ph.D., P.E.
CHIEF ESG!\F.ER
June 28, 1990
Ms. Julia Belaga
Regional Administrator
U.S. Environmental Protection
JFK Federal Building
Boston, MA 02203
Agency
Re: Declaration of Concurrence with Record of Decision
Coak1y landfill Site
North Ha~ ton, NH
Dear Ms. Belaga:
This office has reviewed the above referenced Record of Decision and
concurs wi th the USEPA that the sel ected remedy is consi stent wi th the rules
and regulations of applicable or relevant and appropriate state standards.
Furthennore, if the project util izes the trust fund, the state will provide a
50 percent match and operational support for the project if state funds are
available.
Very truly yours,
c;21'~ £-
Philip J. O'Brien, Ph.D.,
Di rec tor
Waste Management Division
:~~~
~~1 SS10ner
PJO/RWV /j d/12820
cc: Michael A. Sills, Ph.D, P.E., NHDES-WMD
Carl W. Baxter, P.E., NHDES-WMEB
Anne Renner, Esq., NHAGO
-------
APPENDIX E
-------
Coakley Landfill
NPL Site Administrative Record
Index
Compiled:
Updated:
Updated:
ROD Signed:
May 10, 1988
December, 1988
March 2, 1990
June 28, 1990
Prepared for
Region I
Waste Management Division
U.S. Environmental Protection Agency
With Assistance from
AMERICAN MANAGEMENT SYSTEMS, INC.
-------
Volume I
Coakley Landfill
NPL Site Administrative Record
~
1.0 Pre-Remedial
1.2 Preliminary Assessment
1.7 Correspondence Related to Proposal of a Site to the NPL
1.8 Responses to Comments on the Proposal
1.12 Hazard Ranking Package
1.18 FIT Technical Direction Documents (IDDs) and Associated Records
3.0 Remedial Investigation (RI)
3.1
3.2
3.4
3.5
3.6
Volume IT
3.6
Volume ill
Correspondence
Sampling and Analysis Data
Interim Deliverables
Applicable or Relevant and Appropriate Requirements (ARARs)
Remedial Investigation (RI) Reports
Remedial Investigation (RI) Repons (cont'd.)
3.6
3.9
Remedial Investigation (RI) Reports (cont'd)
Health Assessments
4.0 Feasibility StUdy (FS) Reports
4.2 Sampling and Analysis Data
4.5 Applicable or Relevant and Appropriate Requirements (ARARs)
4.6 Feasibility StUdy (FS) Reports
Volume IV
4.9
Proposed Plans for Selected Rem...n1S11 Action
5.0 Record of Decision (ROD)
5.3
5.4
Responsiveness Summaries
Record of Decision (ROD)
9.0 State Coordination
9.2
-------
Coakley Landfill
NPL Site Administrative Record
Volume V
10.0 ~".forceDQent
10.3 State and Local Enforcement Records
11.0 Potentially Responsible Party (PRP)
11.9 PRP-Specific Correspondence
13.0 Community Relations
13.1 Conespondence
13.2 Community Relations Plans
13.3 News Clippings/Press Releases
13.4 Public Meetings
13.5 Fact Sheets
14.0 Congressional Relations
14.1 Conespondence
16.0 Natural Resource TlUstee
16.1 Conespondence
16.4 TlUstee Notification Form and Selection Guide
16.5 Technical Issue Papers
V olume VI
17.0 Site Management Records
17.8 State and Local Technical Records
-------
Introduction
This document is the Index to the Administrative Record for the Coakley Landfill
National Priorities List (NPL) site. Section I of the Index cites site-specific documents, and Section
II cites guidance documents used by EP A staff in selecting a response action at the site.
The Admini3trative Record is available for public review at EP A Region I's Office in Boston,
Massachusetts, and at the Nonh Hampton Public Library, 235 Atlantic Avenue, Nonh Hampton,
New Hampshire 03862. Questions concerning the Administrative Record should be addressed to
the EP A Region I site manager.
The Administrative Record is required by the Comprehensive Environmental Response,
Compensation, and Liability Act (CERCLA), as amended by the Superfund Amendments and
-------
Section I
-------
1.0
ADMINISTRATIVE RECORD INDEX
for the
Coakley Landfill NPL Site
Pre-Remedial
1.2
Preliminary Assessment
1.7
"Potential Hazardous Waste Site - Preliminary Assessment" Form,
EPA Region I (August 25, 1983).
Correspondence Related to Proposal of a Site to the NPL
1.
1. Letter from Gordon J. Humphrey and Warren B. Rudman, U.S. Senate to
Michael R. Deland, EPA Region I (July 26,1983). Concerning the submission
of sites for inclusion on the EPA National Priorities List for Superfund.
2. Letter from Norman E. D'Amours, U.S. House of Representatives to Lee M.
Thomas, EPA Headquaners (July 28, 1983). Concerning the consideration of
the Coakley Landfill site for National Priorities List inclusion.
3. Lener from Michael R. Deland, EPA Region I to Rex Lamben
(August 25, 1983). Concerning assistance and continuing effom on issues
related to the Coakley Landfill Site.
4. Lener from Alan Cranston, U.S. Senate to Lee M. Thomas, EPA Headquaners
(August 29, 1983). Concerning suppon for the inclusion of the Coakley
Landfill Site on the National Priorities List.
5. Letter from Norman E. D'Amours, U.S. House of Representatives to Michael
R. Deland, EPA Region I (September 14, 1983). Concerning well
contamination.
6. Letter from Gordon J. Humphrey, U.S. Senate to William D. Ruckelshaus,
EPA Headquaners (September 21, 1983). Concerning proposed update to the
National Priorities List.
7. Lener from Rex Lambert to Michael R. Deland, EPA Region I
(September 30, 1983). Concerning the request for inclusion of the Coakley
Landfill Site on the National Priorities List
8. Letter from Dudley W. Dudley, State of New Hampshire Executive Department
to William D. Ruckleshaus, EPA Headquaners (October 11, 1983). Concerning
the addition of the Coakley Landfill Site to the National Priorities List.
9. Letter from John H. Sununu, Governor of the State of New Hampshire to
Russell H. Wyer, EPA Headquaners (October 18,1983). Concerning proposed
update to the National Priorities List.
10. Letter from William A. Healy, State of New Hampshire Water Supply and
Pollution Control Commission to Russell H. Wyer, EPA Headquaners
(October 31, 1983). Concerning the request for inclusion of the Coakley
Landfill Site on the National Priorities List.
11. Lener from Roben A. Shatten, EPA Region I to Michael P. Donahue, State of
New Hampshire Water Supply and Pollution Control Commission
(October 5, 1984). Concerning the attached site description for the Coakley
-------
Page 2
1.8
Responses to Comments on the Proposal
Letter from Jack W. McGraw and Lee M. Thomas. EPA Headquarters to
Gordon J. Humphrey. U.S. Senate (October 25. 1983). Concerning the
discovery of new information on the Coakley Landfill Site.
Letter from John F. Zipeto. EPA Region I to Rex Lamben (November 1.1983).
Concerning a revised calculation of the Hazard Ranking System (HRS) score for
the site.
Letter from John F. Zipeto. EPA Region I to Alice F. Buckley
(November 3, 1983). Concerning the proposed amendment to the Superfund
National Priorities List.
Letter from John F. Zipeto. EPA Region I to Edmond F. Gauron
(November 3,1983). Concerning the proposed amendment to the Superfund
National Priorities List.
Letter from John F. Zipeto, EPA Region I to Ruth C. Martin
(November 3, 1983). Concerning the proposed amendment to the Superfund
National Priorities List.
Letter from William N. Hedeman, Jr., EPA Headquarters to Dudley W. Dudley.
State of New Hampshire Executive Depanment (November 3, 1983).
Concerning the discovery of new information on the Coakley Landfill Site.
Letter from Russell H. Wyer, EPA Headquarters to John H. Sununu, Governor
of the State of New Hampshire {December 16, 1983). Concerning the discovery
of new information on the Coakley Landfill Site.
Letter from Jack W. McGraw for Lee M. Thomas, EPA Headquarters to
Norman E. D'Amours, U.S. House of Representatives (December 29, 1983).
Concerning the discovery of new information on the Coakley Landfill Site.
1.12 Hazard Ranking Package
1.
2.
3.
4.
5.
6.
7.
8.
Letter from Andrew M. Platt, The MITRE Corporation to Peter McGlew, EP A
Region I (December I, 1983). Concerning the scoring of Coakley Landfill and
attached HRS worksheets and documentation (September 20, 1983).
1.18 FIT Technical Direction Documents ('IDDs) and Associated Records
1.
3.0
Draft "Infonnation Summary on the Coakley Landfill Site," NUS Corporation
(August 12, 1983).
Remedial Investigation (RI)
1.
3.1
Correspondence
1. utter from Michael P. Donahue, State of New Hampshire Water Supply and
Pollution Control Commission to Stanley Knowles, Town of Nonh Hampton
Board of Selectmen (October I, 1985). Concerning update on Coakley landfIll.
Hydrogeological Activities.
2. Letter from Michael J. Robinette, State of New Hampshire Water Supply and
Pollution Control Commission to Stanley Knowles, Town of Nonh Hampton
Board of Selectmen (March 31, 1986). Concerning monthly summary of
Coakley Landfill Remedial Investigation/Feasibility Study.
3. Meeting Agenda and Notes. State of New Hampshire Water Supply and
Pollution Control Commission, EPA Region I, Roy F. Weston, Inc. and GZA
-------
Page 3
3.1
COITespondence (cont'd.)
4. Letter from Carl W. Baxter for Michael J. Robinette, State of New Hampshire
Water Supply and Pollution Control Commission to Town of Nonh Hampton
Board of Selectmen (May 5, 1986). Concerning monthly update of Coakley
Landfill Remedial InvestigationIFeasibility Study.
5. Letter from Michael J. Robinette, State of New Hampshire Water Supply and
Pollution Control Commission to Walter Lermer, Town of Nonh Hampton
Board of Selectmen (June 2, 1986). Concerning monthly summary of Coakley
Landfill Remedial InvestigationIFeasibility Study.
6. Letter from Michael 1. Robinette, State of New Hampshire Water Supply and
Pollution Control Commission to Walter Lermer, Town of NOM Hampton
Board of Selectmen (July 2, 1986). Concerning monthly summary of Coakley
Landfill Remedial Investigation/Feasibility Study. .
7. Letter from Michael 1. Robinette, State of New Hampshire Water Supply and
Pollution Control Commission to Walter Lermer, Town of Nonh Hampton
Board of Selectmen (August 1, 1986). Concerning monthly summary of
Coakley Landfill Remedial InvestigationlFeasibility Study.
8. Letter from Michael J. Robinette, State of New Hampshire Water Supply and
Pollution Control Commission to Walter Lermer, Town of Nonh Hampton
Board of Selectmen (October 3, 1986). Concerning monthly summary of
Coakley Landfill Remedial Investigation/Feasibility Study. .
9. Letter from Michael J. Robinette, State of New Hampshire Water Supply and .
Pollution Control Commission to Walter Lermer, Town of Nonh Hampton
Board of Selectmen (December 15, 1986). Concerning monthly summary of
Coakley Landfill Remedial Investigation/Feasibility Study.
10. Letter from Paul N. Marchessault, EPA Region I to Michael J. Robinette, Slate
of New Hampshire Water Supply and Pollution Control Commission
(December 23, 1986). Concerning revisions to the proposed monitoring well
installation, chemical quality sampling, and test pitting plans.
11. Letter from Michael J. Robinette, State of New Hampshire Water Supply and
Pollution Control Commission to Walter Lermer, Town of NOM Hampton
Board of Selectmen (February 20,1987). Concerning monthly summary of
Coakley Landfill Remedial InvestigationIFeasibility Study.
12. Letter from Michael J. Robinette, State of New Hampshire Office of Waste
Management to Town of North Hampton Board of Selectmen
(June 30, 1987). Concerning monthly summary of Coakley Landf1l1
Remedial InvestigationIFeasibility Study.
13. Letter from Michael 1. Robinette, State of New Hampshire Office of Waste
Management to Town of North Hampton Board of Selectmen
(August 11, 1987). Concerning monthly summary of Coakley Landf1l1
Remedial Investigation/Feasibility Study.
14. Letter from Michael J. Robinette. State of New Hampshire Office of Waste
Management to Town of North Hampton Board of Selectmen
(September 8, 1987). Concerning monthly summary of Coakley Landfill
Remedial InvestigationIFeasibility Study.
15. Letter from Barry L. Johnson, U.S. Department of Health and Human Senices
Public Health Service Agency for Toxic Substances and Disease Registry
(ATSDR) to Lillian E. Wylie (January 14, 1988). Concerning request for
Health Assessment.
3.2 Sampling and Analysis Data
1.
Letter from Kevin H. Hopkins, State of New Hampshire Department of
Environmental Services to Peter H. Thompson (March 30, 1987). Concerning
-------
Page 4
i ,<
- ."t
Interim Deliverables
The record cited in entry 1 may be reviewed, by appointment only, at EPA Region /,
Boston, Massachusetts.
3.5
"Draft Project Operation PI:n," Roy F. Weston, Inc. (May 28, 1986).
Letter from Wayne T. Wirtanen, EPA Region I to Dan Coughlin,
EPA Region I (September 16, 1986). Concerning attached Project Operations
Plan "Quality Assurance Acceptance" Form.
Applicable or Relevant and Appropriate Requirements (ARARs)
1.
2.
3.6
Letter from Emily S. Bernheim, State of New Hampshire, Office of the Attorney
General to Paul N. Marchessault, EPA Region I (September 14, 1988).
Concerning attached contaminant and location-specific ARARs, with synopsis'
and discussion of necessary action to attain ARARs.
Remedial Investigation (RI) Reports
1.
Repons
1.
"Remedial Investigation - Coakley Landfill- Volume One," Roy F. Weston, Inc.
and Goldberg-Zoino and Associates, Inc. for the State of New Hampshire \
Department of Environmental Services (October 1988).
"Remedial Investigation - Coakley Landftll- Volume Two," Roy F. Weston,
Inc. and Goldberg-Zoino and Associates, Inc. for the State of New Hampshire
Department of Environmental Services (October 1988).
"Remedial Investigation - Coakley Landfill- Volume Three," Roy F. Weston,
Inc. and Goldberg-Zoino and Associates, Inc. for the State of New Hampshire
Department of Environmental Services (October 1988).
2.
3.
Comments
4.
Comments Dated December 13, 1988 from Roben J. Gallo, McNeill, Taylor &
Dolan (Attorney for the Towns of New Castle and North Hampton) with
attached Comments Dated December 9, 1988 from David Woodhouse, Quest
Environmental Sciences,' Inc. on the October 1988 "Re~al Investigation,"
Roy F. Weston, Inc. and Goldberg-Zoino and Associates Inc. for the State of
New Hampshire Department of Environmental Services.
Comments Dated December 20, 1988 from Kevin C. Devine, Devine & Nyquist
(Attorney for Coakley Landfill, Inc.) on the October 1988 "Remedial
Investigation," Roy F. Weston, Inc. and Goldberg-Zoino and Associates Inc.
for the State of New Hampshire Department of Environmental Services.
Comments Dated January 6, 1989 from E. Tupper Kinder, Ransmeier &
Spellman (Attorney for the City of Portsmouth) with attached Comments Dated ,
December 19, 1988 from Thomas E. Roy and George G. Draper m, Aries
Engineering, Inc. on the October 1988 "Remedial Investigation," Roy F.
Weston, Inc. and Goldberg-Zoino and Associates Inc. for the State of New
Hampshire Depanment of Environmental Services.
5.
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Page 5
3.9
Health Assessments
4.0
Memorandum from Marilyn R. DiSirio, U.S. Depanment of Health and Human
Services Public Health Service Agency for Toxic Substances and Disease
Registty (A TSDR) to Dennis Huebner and Donald Berger, EPA Region I
(August 18, 1988). Concerning site access and posting.
"Health Assessment for Coakley Landfill, Nonh Hampton, New Hamphshire,"
Department of Health and Human Services Public Health Service Agency for
Toxic Substances and Disease Registty (A TSDR) (October 13, 1988).
Feasibility Study (FS)
1.
2.
4.2 Sampling and Analysis Data
Memorandum from Peter R. Kahn, EPA Region I to Paul N: Marchessault. EPA
Region I (May 23, 1989) with attached "Residential Indoor Air Study-8ampling
Results," EPA Region I (May 1989).
Letter from Paul N. Marchessault, EPA Region I to Lillian E. Wylie
(June 26. 1989). Concerning "Residential Indoor Air Study Sampling Results."
EPA Region I (May 1989) and attached Memorandum from Louise House, U.S.
Department of Health and Human Services Public Health Service Agency for
Toxic Substances and Disease Registry (ATSDR) to Paul N. Marchessault, EPA
Region I (June 8, 1989). .
4.5 Applicable or Relevant and Appropriate Requirements (ARARs)
1.
2.
1.
Letter from Michael J. Robinette. State of New Hampshire Department of
Environmental Services to Steven J. Calder. EPA Region I (February 12. 1990).
Concerning action level for phenols.
4.6 Feasibility Study (FS) Reports
Reports
"Draft Feasibility Study." Roy F. Weston. Inc. for the State of New Hampshire
Department of Environmental Services (May 1989).
Memorandum from Steven J. Calder. EPA Region I to File
(February 22. 1990). Concerning updated infonnation on the estimated costs of
the ground water treatment preferred remedy.
Comments
1.
2.
C011llMnts on the Feasibility Study (FS) Report received by EPA Region I during the
formal public c011llMnt period are filed and cited in 5.3 Responsiveness Sumnuuies.
4.9 Proposed Plans for Selected Remedial Action
Reports
1.
"EP A Proposes Cleanup Plan for Coakley Landf1l1 Site." EP A Region I
(February 1990).
Comments
C011llMnlS on the Proposed Plan received by EP A Region I during the formal public
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5.0
Page 6
Reoord of Decision (ROD)
5.3
Responsiveness Summaries
Cross Reference: Responsiveness Summary is Appendix "c" of the Record of
Decision [Filed and cited as ~ntry number 1 in 5.4 Record of Decision (ROD)].
The f{lilowing citations indicate written comments received by EP A Region I during
the formal public comment period.
1.
5.4
2. Comments Dated March 15, 1990 from Citizens Organized Against Seacoast
Toxics (COAST) on the February 1990 "EPA Proposes Cleanup Plan for
Coakley Landfill Site," EPA Region I.
3. Comments Dated April 3, 1990 from Lillian E. Wylie on the February 1990
"EPA Proposes Cleanup Plan for Coakley Landf1l1 Site," EPA Region I.
4. Comments Dated April 3, 1990 from Tammy Wylie on the February 1.990 "EPA
Proposes Cleanup Plan for Coakley Landfill Site," EPA Region I.
5. Letter from Susan Frank, EPA Region I to Pam Schwotzer, North Hampton
Public Library (April 19, 1990). Concering transmittal of the attached transcript
of April 3, 1990 Proposed Plan public hearing at North Hampton Elementary
School.
6. Comments Dated May 2,1990 from Judith C. Melvin on the February 1990
"EPA Proposes Cleanup Plan for Coakley Landf1l1 Site," EPA Region I.
7. Comments Dated May 3, 1990 from Elmer M. Sewall on the February 1990
"EPA Proposes Cleanup Plan for Coakley Landf1l1 Site," EPA Region I.
8. Comments Dated May 12, 1990 from Laurel F1ax, Hampton WaterWorlcs Co.
on the February 1990 "EPA Proposes Cleanup Plan for Coakley Landfill Site,"
EP A Region I.
9. Cross Reference: Letter from Thomas G. Fiore, Monison, Mahoney & Miller
(Attorney for Coakley Landfil Steering Committee) to Steven J. Calder, EPA
Region I (May 14, 1990). Concerning transmittal of attached comments dated
May 14, 1990 from ENVIRON Corporation for the Coakley Landfill Steering
Committee on the February 1990 "EPA Proposes Cleanup Plan for Coakley
Landfill Site," EPA Region I. [Filed as an attachment to entry number 1 in 5.3
Responsiveness Summaries].
10. Comments (petition) from Citizens Organized Against Seacoast Toxics
(COAST) on the February 1990 "EPA Proposes Cleanup Plan for Coakley
Landf1l1 Site," EPA Region I.
11. Comments from Lillian E. Wylie on the February 1990 "EPA Proposes Cleanup
Plan for Coakley Landfill Site," EP A Region I.
12. Comments from Lillian E. Wylie on the February 1990 "EPA Proposes Cleanup
Plan for Coakley Landfill Site," EPA Region I.
13. Comments (Petition) from Shawn Wylie, et ale on the February 1990 "EPA
Proposes Ceanup Plan for Coakley Landfill Site," EPA Region I.
14. Comments from Doug Bogen, Great Bay Region Greens on the February 1990
"EPA Proposes Cleanup Plan for Coakley Landf1l1 Site," EPA Region I.
Record of Decision (ROD)
1.
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Page 7
9.0
State Coordination
9.2
Cooperative Agreements
1.
Memorandum from David G. Scott, State of New Hampshire, Office of State
Planning to EPA Region I (June 11, 1985). Concerning concurrence with the
Intergovernmental Review Process and the attached "Request for Review."
Memorandum from Merrill S. Holunan, EPA Region I to Michael R. Deland,
EPA Region I (August 12,1985). Concerning recommendation to award
Cooperative Agreement to the State of New Hampshire.
"EPA Assistance Agreement/Amendment" Form, State of New Hampshire
(August 12, 1985).
''EPA Assistance Agreement/Amendment" Form, State of New Hampshire
(April 9, 1987).
2.
3.
4.
10.0 Enforcement
1 0.3 State and Local Enforcement Records
1. Letter from Brian C. Strolun, State of New Hampshire Department of Health
and Welfare to Town of North Hampton Board of Selectmen
(December 6, 1983). Concerning the arrangement of an upcoming meeting.
2. Letter from Brian C. Strolun, State of New Hampshire Department of Health
and Welfare to Calvin Canney, Town of North Hampton (December 6,1983).
Concerning the arrangement of an upcoming meeting.
3. Lener from Brian C. Strolun, State of New Hampshire Department of Health
and Welfare to Ronald C. Coakley, Coakley Landfill, Inc.
(December 6, 1983). Concerning the arrangement of an upcoming meeting.
4. Letter from Brian C. Strolun, State of New Hampshire Department of Health
and Welfare to Ronald C. Coakley, Coakley Landf1l1, Inc. (February 29, 1984).
Concerning the summary of the January 23, 1984 meeting.
5. Letter from Brian C. Strolun, State of New Hampshire Department of Health
and Welfare to Town of North Hampton Board of Selectmen
(February 29, 1984). Concerning the summary of the January 23, 1984
meeting.
6. Letter from Brian C. Strolun, State of New Hampshire Department of Health
and Welfare to Calvin Canney, Town of North Hampton (February 29, 1984).
Concerning the summary of the January 23. 1984 meeting.
7. Letter from George Dana Bisbee, State of New Hampshire, Office of the
Attorney General to Paul Kent, Town of Newington Board of Selectmen
(December 28, 1984). Concerning the state's request for funding a Remedial
Investigation/Feasibility Study.
8. Letter from George Dana Bisbee, State of New Hampshire, Office of the
Attorney General to Roben A. Southworth, Town of North Hampton Board of
Selectmen (December 28, 1984). Concerning the state's request for funding a
Remedial Investigation/Feasibility Study.
9. Letter from George Dana Bisbee, State of New Hampshire, Office of the
Attorney General to Richard Carroll, Pease Air Force Base
(December 28, 1984). Concerning the state's request for funding a
Remedial Investigation/Feasibility Study.
10. Letter from George Dana Bisbee, State of New Hampshire, Office of the
Attorney General to James Flynn, City of Ponsmouth (December 28, 1984).
Concerning the state's request for funding a Remedial Investigation/Feasibility
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Page 8
10.3 State and Local Enforcement Records (cont'd.)
11. Letter from George Dana Bisbee, State of New Hampshire, Office of the
Attorney General to Kevin C. Devine, Devine, Millimet, Stahl & Branch,
Professional Association (December 28, 1984). Concerning the state's request
for funding a Remedial Inve~tigation/Feasibility Study.
12. Letter from George Dana Bisbee, State of New Hampshire, Office of the
Attorney General to Douglas Woodward, Town of New Castle
(December 28, 1984). Concerning the state's request for funding a
Remedial Investigation/Feasibility Study.
13. Letter from George Dana Bisbee, State of New Hampshire, Office of the
Attorney General to John Moebes, EPA Region I (December 28,1984).
Concerning the State of New Hampshire's request for EPA funding and
technical assistance to carry out a Remedial Investigation/Feasibility Study.
11.0 Potentially Responsible Party (PRP)
11.9 PRP-Specific Correspondence
Letter from Merrill S. Hohman, EPA Region I to Jeremy Waldron, Coakley
Landflll, Inc. (February 2, 1990). Concerning notice of potential liability with
attached mailing list of Potentially Responsible Parties. .
Letter from Merrill S. Hohman, EPA Region I to Potentially Interested Parties'
(March 2, 1990). Concerning special interest and remedy selection.
Letter from Merrill S. Hohman, EPA Region I to Potentially Interested Parties
(March 21, 1990). Concerning special interest and remedy selection.
Letter from E. Tupper Kinder, Ransmeier & Spellman (Attorney for the
Temporary PRP Steering Committee) to Steven J. Calder, EPA Region I and
Timothy E. Williamson, EPA Region I (March 23, 1990) with "Attachment A-
Temporary Steering Committee - Coakley Landfill". Concerning request for
thirty-day extension on deadline for submission of comments on proposed
remedial plan.
13.0 Community Relations
1.
2.
3.
4.
13.1 Correspondence
1.
Letter from Michael R. Deland, EP A Region I to Raymond F. Hennessey,
Mayor of the City of Dover, New Hampshire (October 3, 1983). Concerning
the assessment for Superfund ranking and suppon for the state's negotiations
with Ronald C. Coakley.
Letter from John F. Zipeto, EPA Region I to Ruth Martin, New Hampshire
People's Alliance (March 1, 1984). Concerning the attached concerns of Ruth
Manin and Dale McLeod about the Coakley Landfill Site.
Letter from John F. Zipeto, EPA Region I to Ruth Martin, New Hampshire .
People's Alliance (January II, 1985). Concerning responses to questions about
the Coakley Landfill Site raised at the November 1,1984 meeting.
Letter from Robert J. Ankstitus, EPA Region I to Ruth Martin. Citizens
Organized Against Seacoast Toxics (COAST) (January 22.1985). Concerning
the July 20. 1984 site investigation and assessment activities at Coakley Landfill
Site. .
Letter from Lillian E. Wylie, Citizens Organized Against Seacoast Toxics
(COAST) to Michael R. Deland, EPA Region I (February 9. 1985). Concerning
the attached newspaper clippings.
Letter from Lillian E. Wylie. Citizens Organized Against Seacoast Toxics
(COAST) to Michael R. Deland. EPA Region I (February 20. 1985).
Concerning the clean-up of Coakley Landfill Site.
2.
3.
4.
5.
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Page 9
13.1 Correspondence (cont'd.)
"New Hampshire Questions," Manha Bailey, New Hampshire Hazards
Campaign (June 26, 1985). Concerning municipal and private drinking water
wells.
Cross-Reference: Letter frOJ11 Paul N. Marchessault, EPA Region I to Ullian E.
Wylie (June 26,1989). Concerning "Residential Indoor Air Study Sampling
ResultS," EP A Region I (May 1989) and attached Memorandum from Louise
House, U.S. Department of Health and Human Services, Public Health Service.
Agency for Toxic Substances and Disease Registry (A TSDR) to Paul N.
Marchessault, EPA Region I (June 8, 1989) [Filed and cited as entry number 2
in 4.2 Sampling and Analysis Data].
"Coakley Landflll," New Hampshire Toxic Hazards Campaign Inc. Concerning
testing of four residential bedrock wells and air sampling in three homes.
13.2 Community Relations Plans
7.
8.
9.
"Community Relations Plan," State of New Hampshire Deparnnent of
Environmental Services (January 1986).
13.3 News Clippings/Press Releases
"Environmental News - Media Advisory," EPA Region I (October 25, 1988).
''Environmental News - EPA Announces Public Meeting to Explain Proposed
Cleanup Plan for the Coakley Landfill Superfund Site," EPA Region I
(March 7, 1990).
"Environmental News - EPA Announces Extension of Public Comment Period
on Cleanup Plan for the Coakley Landfill Superfund Site," EPA Region I
(March 30, 1990).
''Environmental News - Coakley Landfill Remedial Investigation Announced, "
State of New Hampshire Depanment of Environmental Services.
13.4 Public Meetings
1.
News Clippings
1.
"The United States Environmental Protection Agency Invites Public Comment
on the Feasibility Study and Proposed Plan for the Coakley Landfill Site in
Nonh Hampton, New Hampshire and Announces the Availability of the Site
Administrative Record," Ponsmouth Herald - Ponsmouth, NH
(March 9, 1990).
"The United States Environmental Protection Agency Invites Public Comment
on the Feasibility Study and Proposed Plan for the Coakley Landfill Site in
Nonh Hampton, New Hampshire and Announces the Availability of the Site
Administrative Record," Foster's Daily Democrat - Dover, NH (March 9, 1990).
2.
Press Releases
3.
4.
5.
6.
1.
2.
Draft "Hydrogeological Investigation of the Coakley Landfill Site, North
Hampton, New Hampshire," EPA Region I (January 9,1986).
"Informational Notice," State of New Hampshire Water Supply and Pollution
Control Commission (April 1986). .
State of New Hampshire Water Supply and Pollution Control Commission
Meeting Agenda, Public Meeting for the Coakley Landfill Site (May 14, 1986).
Concerning the Remedial InvestigationJFeasibility Study.
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Page 10
13.4 Public Meetings (conI'd.)
4.
State of New Hampshire Department of Environmental Services Meeting
Agenda, Public Infonnational Meeting for the Coakley Landfill Site
(November 3, 1988). Concerning Remedial Investigation presentation and
representatives available for question and answer period.
Letter from Jill M. Paradis, Ebasco Services Incorporated to Paul N.
Marchessault, EP A Region I (March 1, 1989). Concerning transmittal of
attached "Final Public Meeting Summary," of the November 3, 1988 Remedial
Investigation Public Meeting.
"Public Meeting Summary - Coakley Landfill Site," (March 15, 1990).
Cross-Reference: Letter from Susan Frank. EPA Region I to Pam Schwotzer,
Nonh Hampton Public Library (April 19, 1990). Concerning transmittal of the
attached transcript of April 3, 1990 Proposed Plan public hearing at Nonh
Hampton Elementary School. [Filed and cited as entry number 5 in 5.3
Responsiveness Summaries].
5.
6.
7.
13.5 Fact Sheets
1.
"State of New Hampshire Releases Results of Remedial Investigation,"
EPA Region I (October 1988).
14.0 Congressional Relations
14.1 Correspondence
"Coakley Landf1l1 Tour," Agenda, EPA Region I (August 18, 1983).
Letter from Michael R. Deland, EPA Region I to Norman E. D'Amours, U.S.
House of Representatives (September 14, 1983). Concerning assessment for
Superfund ranking and suppon for the state's negotiations with Ronald C.
Coakley.
Letter from Gordon J. Humphrey, U.S. Senate to Michael R. Deland, EPA
Region I (September 27, 1988). Concerning attached letter from Dean
Merchant, State of New Hampshire House of Representatives to Gordon J.
Humphrey, U.S. Senate (September 19,1988) regarding construction of a fence
at the Coakley Landfill.
Letter from Paul Keough for Michael R. Deland, EP A ~egion I to
Gordon J. Humphrey, U.S. Senate (October 25, 1988). Concerning
construction of a fence at the Coakley Landfill.
Lener from Paul Keough for Michael R. Deland, EPA Region I to Gordon J.
Humphrey, U.S. Senate (March 20.1989). Concerning soil sample results.
16.0 Natural Resource Trustee
1.
2.
3.
4.
5.
16.1 Correspondence
1.
Letter from Gordon E. Beckett, U.S. Department of the Interior, Fish and
Wildlife Service to Paul N. Marchessault, EPA Region I (July 21, 1987).
Concerning the development and review of draft documents and activities
relating to Department of the Interior trust resources.
Letter from Kenneth Finkelstein, U.S. Department of Commerce National
Oceanic and Atmospheric Administration to Paul N. Marchessault, EPA
Region I (June 30, 1988). Concerning anadromous species and off-site
migration of contaminants.
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~
Page 11
16.4 Trustee Notification Fonn and Selection Guide
Letter from Patricia L. Mean~y for Merrill S. Hohman, EPA Region I to William
Patterson, U.S. Depanment of the Interior (May 15, 1987). Concerning the
anached "Trustee Notification Form," EPA Region I.
16.5 Technical Issue Papers
1.
"Preliminary Natural Resource Survey - Findings of Fact," U.S. Department of
Commerce National Oceanic and Atmospheric Administration (August 23,1989).
17.0 Site Management Records
1.
17.4 Site Photographs/Maps
The record cited below may be reviewed by appointment only, at EPA Region I,
Boston, Massachusetts.
"Site Analysis Coakley Landfill," EPA Environmental Monitoring Systems
Laboratory (March 1985).
17.8 State and Local Technical Records
~
1.
Letter from Michael P. Donahue, State of New Hampshire Water Supply and
Pollution Control Commission to Mark Aldrich, Office of the U.S. Senator
Gordon S. Humphrey (March 17, 1983). Concerning the chronology of events
following the discovery of volatile organic chemicals in well water near the
Coakley Landfill Site.
Letter from Dan H. Allen, State of New Hampshire Water Supply and Pollution
Control Commission to Robert A. Southworth, Town of North Hampton Board
of Selectmen (July 18, 1983). Concerning water sampling ofLinIe River and
North Brook.
Letter from Michael P. Donahue, State of New Hampshire Water Supply and
Pollution Control Commission to Stanley Knowles, Town of North Hampton
Board of Selectmen (May 29,1985). Concerning drilling program for Coakley
Landfill Study.
Letter from Patricia L. Meaney for Menill S. Hohman, EPA Region I to Martha
Bailey (June 28, 1985). Concerning specific questions regarding three NPL
sites.
Lener from Michael P. Donahue, State of New Hampshire Water Supply and
Pollution Control Commission to Nonh Hampton Public Library
(June 28,1985). Concerning additional documents to be made available for
public review.
The record cited in entry 6 may be reviewed, by appointment only, at EP A Region I, .
Boston, Massachusens.
1.
2.
3.
4.
5.
6.
7.
"Hydrogeological Report on the Town of Rye Sanitary Landfill," DuBois &
King, Inc. (June 1985).
Letter from Michael P. Donahue for Michael A. Sills, State of New Hampshire
Water Supply and Pollution Control Commission to Stanley Knowles, Town of
North Hampton Board of Selectmen (July 26, 1985). Concerning the anached
"Organic Chemical Analysis."
Lener from Michael P. Donahue, State of New Hampshire Water Supply and
Pollution Control Commission to Stanley Knowles, Town of North Hampton
Board of Selectmen (August 30, 1985). Concerning update on the Coakley
Landfill Hydrogeological Study.
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Page 12
17.8 Slale and Local Technical Re-.cords (cont'd.)
9. Letter from Michael A. Sills, State of New Hampshire Water Supply and
Pollution Control Commission to Stanley Knowles, Town of North Hampton
Board of Selectmen (November I, 1985). Concerning Coakley Landfill
Remedial Investigation/Feas;bility Study monthly update.
10. Letter from Michael A. Sills, State of New Hampshire Water Supply and
Pollution Control Commission to Stanley Knowles, Town of Nonh Hampton
Board of Selectmen (December 3, 1985). Concerning Coakley Landfill Study
monthly update.
11. Letter from Michael A. Sills, State of New Hampshire Water Supply and
Pollution Control Commission to Stanley Knowles, Town of North Hampton
Board of Selectmen (December 17, 1985). Concerning the attached "Inorganic
Chemical Analysis."
12. Letter from Michael A. Sills, State of New Hampshire Water Supply and
Pollution Control Commission to North Hampton Town Library ..
(J anuary 8, 1986). Conce:-1ing hydrogeological investigation of the Coakley
Landf1l1 Site.
13. Letter from Michael A. ~ .5, State of New Hampshire Water Supply and
Pollution Control Comr.:~ssion to Stanley Knowles, Town of North Hampton
Board of Selectmen (January 23, 1986). Concerning approval of a warrant
article for a waterline extension.
14. Letter from Michael A. Sills, State of New Hampshire Water Supply and
Pollution Control Commission to Martha Bailey, WASTE, Inc.
(January 24, 1986). Concerning transmittal of Draft Commission Report #147.
15. Letter from Michael A. Sills, State of New Hampshire Water Supply and
Pollution Control Commission to Lillian E. Wylie, Qtizens Organized Against
Seacoast Toxins (COAST) (January 24, 1986). Concerning transmittal of Draft
Commission Report #147.
16. Letter from Michael A. Sills, State of New Hampshire Water Supply and
Pollution Control Commission to Stanley Knowles, Town of North Hampton
Board of Selectmen (February 28, 1986). Concerning monthly summary of
Coakley Landfill Hydrogeological Investigation.
17. "Hydrogeological Investigation of the Coakley Landfill Site, North Hampton,
New Hampshire," New Hampshire Water Supply and Pollution Control
Commission (February 1986).
18. Memorandum from William T. Wallace, Ir., State of New Hampshire Division
of Public Health Services to Alden H. Howard, State of New Hampshire
Department of Environmental Services (July 14, 1988) with attached "Evaluation
of Cancer Incidence and Monality in NOM Hampton, New Hampshire,
1980-1986," State of New Hampshire Division of Public Health Services
(July 8, 1988).
19. Letter from Michael J. Robinette, State of New Hampshire Department of
Environmental Services to Board of Selectmen, Town of North Hampton
(August 8, 1988). Concerning transmittal of ''Evaluation of Cancer Incidence
and Mortality in North Hampton, New Hampshire, 1980-1986," State of New
Hampshire Division of Public Health Services (Iuly 8, 1988).
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I
Section II
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Page 13
GUIDANCE DOCUMENTS
EPA guidance documents may be reviewed at EPA Region I, Boston, Massachusetts.
General EP A Guidance Documents
1. U.S. Environmental Protection Agency. Office of Research and Development. Municipal
Environmental Research Laboratory. Biodegradation and Treatability of Specific Pollutants
(EPA-60019-79-034), October 1979.
2. U.S. Environmental Protection Agency. Office of Research and Development. Municipal
Environmental Research Laboratory. Carbon Adso11'tion Isotherms for Toxic Oreanics
(EPA-60018-80-023), April 1980.
3. U.S. Environmental Protection Agency. Office of Water and Waste Management Evaluating
Cover Systems for Solid and Hazardous Waste, 1980.
4. U.S. Environmental Protection Agency. Office of Research and Development. Municipal
Environmental Research Laboratory. Handbook for Evaluating Remedial Action Technology
~ (EPA-600/2-83-076), August 1983.
5.
"National Oil and Hazardous Substances Pollution Contingency Plan," (40 CFR Pan 3(0),
November 20, 1985.
6. U.S. Environmental Protection Agency. Office of Ground-Water Protection. Ground-Water
Protection Strategy, August 1984.
7. U.S. Environmental Protection Agency. Office of Solid Waste and Emergency Response,
Office of Emergency and Remedial Response, and Office of Research and Development.
Review of In-Place Treatment Techniques for Contaminated Surface Soils - Volume 1:
Technical Evaluation (EPA-54012-84-003a), September 1984.
8.
"Guidelines Establishing Test Procedures for the Analysis of Pollutants Under the Clean Water
Act; Final Rule and Interim Final Rule and Proposed Rule" (40 CFR Pan 136),
October 26, 1984.
9. U.S. Environmental Protection Agency. Office of Emergency and Remedial Response.
Hazardous Response Suppon Division. Standard Qperatin~ Safety Guides. November 1984.
10. U.S. Environmental Protection Agency. Office of Emergency and Remedial Response.
. n . (OSWER Directive
11. U.S. Environmental Protection Agency. Office of Research and Development Environmental
Research Laboratory. EPA Guide for Minimizin~ the Adverse Environmental Effects of
Cleanup of Uncontrolled Hazardous Waste Sites, (EPA-600/8-85/008), June 1985.
12. U.S. Environmental Protection Agency. Office of Solid Waste and Emergency Response.
Guidance on Feasibility Studies under CERCLA (Comprehensive Environmental Response.
Compensation. and Liability Act) (EPN540/G-85/003, OSWER Directive 9355.0-05C),
June 1985.
13. U.S. Environmental Protection Agency. Office of Solid Waste and Emergency Response.
Guidance on Remedial Investi~ations under CERCLA (Comprehensive Envl:onmental
Response. Compensation. and Liability Act) (EPN5401G-851OO2, OSWER Directive
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Page 14
14. Memorandum from Gene Lucero to the U.S. Environmental Protection Agency,
August 28, 1985 (discussing community relations at Superfund Enforcement sites).
15. U.S. Environmental Protection Agency. Office of Waste Programs Enforcement.
The Endan~erment Assessment Handbook. August 1985.
16. U.S. Environmental Protection Agency. Office of Waste Programs Enforcement. Toxicolo~
Handbook. August 1985.
17. Covers for Uncontrolled H37.3rdous Waste Sites, September 1985.
18. U.S. Deparunent of Health and Human Services. National Institute for Occupational Safety
and Health, and Occupational Safety and Health Administration. Occupational Safe~ and
Health Guidance Manual for H37.3mous Waste Site Activities, October 1985.
19. U.S. Environmental Protection Agency. Office of Emergency and Remedial Respopse.
Handbook of Remedial Action at Waste Di~sal Sites (EPAl625/6-85/006). October 1985.
20. U.S. Environmental Protection Agency. Office of Research and Development Hazardous
Waste Engineering Research Laboratory. Handbook: Remedial Action at Waste Disposal Sites
(Revised) (EPAl625/6-85/006), October 1985.
21. U.S. Environmental Protection Agency. Office of Research and Development Hazardous
Waste Engineering Research Laboratory. Handbook for Stabilization/Solidification of
Hazardous Wastes (EPAl540/2-86/OO1), June 1986.
22. U.S. Environmental Protection Agency. Office of Research and Development Hazardous
Waste Engineering Research Laboratory. Treatment Technolo~ Briefs: A1tematives to
H37.3rrlous Waste Landftlls (EPAl600/8-861017), July 1986.
23a. U.S. Environmental Protection Agency. Office of Emcrgency and Remr.dia1 Response. Dati
Guidance on Remedial Actions for Contaminated Groundwater at Superfund Sites (OSWER
Directive 9283.1-2). September 20, 1986.
23b.U.S. Environmental Protection Agency. Office of Emergency and Remedial Response.
Guidance on Remedial Actions for Contaminated Groundwater at Superfund Sites
(OSWER Directive 9283.1-2). December 1988.
24. U.S. Environmental Protection Agency. Office of Solid Waste and Emergency Response and
Office of Emergency and Remedial Response. Mobile Treatment Technolo~es for SQperfund
Wastes (EPA 540/2-861003 (I), September 1986.
25. Comprehensive Environmental Re~nse. Compensation. and Liabili~ Act of 1980. amended
October 17, 1986.
26. U.S. Environmental Protection Agency. Office of Emergency and Remedial Response.
Superfund Public Health Evaluation Manual (OSWER Directive 9285.4-01). October 1986.
27. U.S. Environmental Protection Agency. Office of Emergency and Remedial Response. DDf1
Guidance on Remedial Actions for Contaminated Groundwater at Sqperfund Sites (OSWER
Directive 9283.1-2), October 1986.
28. U.S. Environmental Protection Agency. Office of Solid Waste and Emergency Response.
Interim Guidance on Superfund Selection of Remedy (OSWER Directive 9355.0-19),
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Page 15
29. U.S. Environmental Protection Agency. Office of Emergency and Remedial Response.
Superfund Federal-Lead Remedial PrQject Mana~ement Handbook (EPN540/G-87/001,
OSWER Directive 9355.1-1), December 1986.
30. U.S. Environmental Protection Agency. Office of Emergency and Remedial Response.
Superfund State-Lead Remedial Proiect Mana~ement Handbook, (EPA/540/G-871OO2),
December 1986.
'V
31. U.S. Environmental Protection Agency. Office of Research and Development Hazardous
Waste Engineering Research Laboratory. Technolo~ Briefs: Data Requirements for Seler.tin~
Remedial Action Technolo~ (EPN6fYJI2-871OO1), January 1987.
32. U.S. Environmental Protection Agency. Office of Solid Waste and Emergency Response.
Data Ouality Obiectives for Remedial Re$Ponse Activities: DevelQpment Process
(EPN540/G-87/003), March 1987.
33. Letter from Lee M. Thomas to James J. Florio, Chainnan, Subcommittee on Consumer
Protection and Competitiveness, Committee on Energy and Commerce, U.S. House of
Representatives, May 21, 1987 (discussing EPA's implementation of the Superfund
Amendments and Reauthorization ACt of 1986).
34. Memorandum from J. Winston Potter to Addressees ("Regional Administrators, Regions I-X;
Regional Counsel, Regions I-X; Director, Waste Management Division, Regions I, IV, V, vn,
and vm; Director, Emergency and Remedial Response Division, Region ll; Director,
Hazardous Waste Management Division, Regions ill and VI; Director, Toxics and Waste
Management Division, Region IX; Director, Hazardous Waste Division, Region X;
Environmental Services Division Directors, Region I, VI, and Vll"), July 9, 1987 (discussing
interim guidance on compliance with applicable or relevant and appropriate requirements).
35. U.S. Environmental Protection Agency. Office of Solid Waste and Emergency Response.
Additional Interim Guidance for Fiscal Year 1987 Record of Decisions, July 24, 1987.
36. U.S. Environmental Protection Agency. Office of Health and Environmental Assessment
A Compendium ofTechnolo~es Used in the Treatment of Hazardous Waste
(EPN625/8-871014), September 1987.
37a. U.S. Environmental Protection Agency. Office of Solid Waste and E!Dergency Response.
Draft Guidance on CERCLA Conwliance with Other Laws Manual (OSWER Directive
9234.1-01), November 25, 1987.
37b.U.S. Environmental Protection Agency. Office of Solid Waste and Emergency Response.
Draft Guidance on CERCLA Conwliance with Other Laws Manual (OSWER Directive
9234.1-01), August 8, 1988.
38. U.S. Environmental Protection Agency. Office of Emergency and Remedial Response. A .
Compendium of Superfund Field Qperations Methods (EPN5401P-87/001, OSWER Directive
9355.0-14), December 1987.
39a. U.S. Environmental Protection Agency. Office of Emergency and Remedial Response. DDW
Guidance on Conductine Remedial Investi,ations and Feasibility Studies under CERCLA
(Comprehensive Environmental Re~ponse. Compensation. and Liability Act), March 1988.
39b.U.S. Environmental Protection Agency. Office of Emergency and Remedial Response.
Interim Final Guidance on Conductin, Remedial Investi~ations and Feasibility Studies under
CERCLA (Comprehensive Environmental Response. Compensation. and Liability Act),
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Page 16
Q
40. U.S. Environmental Protection Agency. Office of Emergency and Remedial Response. DriW
Guidance on Remedial Actions for Contaminated GroundWater at Superfund Sites
(OSWER Directive 9283.1-2), April 1988.
41a. U.S. Environmental Protection Agency. Office of Emergency and Remedial Response.
Communi~ Relations in Superfund: A Handbook (Interim Version) (EPA/HW-6, OSWER
Directive 9230;0-3A), September 1983.
\J
41b.U.S. Environmental Protection Agency. Office of Emergency and Remedial Response.
Communi~ Relations in Superfund: A Handbook (Interim Version) (EPA/HW-6, OSWER
Directive 9230.o-3A), June 1988.
42. Memorandum from Henry L. Longest n. U.S. Environmental ProteCtion Agency Office of
Emergency and Remedial Response and Gerald Emison, U.S. Environmental ProteCtion
Agency Office of Air Quality Planning and Standards!O Addressees ("Regional Wasse
Management Division Directors, Regional Superfund Branch Chiefs, Regional Air Division
Directors, Regional Air Branch Chiefs, OERR Division Directors, OAQPS Division
Directors"), June 15, 1989 (discussing control of air emissions from Superfund air strippers at
Superfund groundwater sites).
43. U.S. Environmental Protection Agency, Region 1. Supplemental Risk Assessment Guidance .
for the Superfund Proeram, (EPA 901/5-89-0(1), June 1989. '
44. U:S. Environmental ~tection Agency. Office of Solid Waste an~ Emergency Response.
45. Memorandum from Don R. Oay, U.S. Environmental Protection Agency Office of Solid
Waste and Emergency Response to Regional Administrators Regions I - X, December 6, 1989
(discussing CERaA settlements involving municipalities or municipal wastes).
46. Memorandum from Don R. Oay, U.S. Environmental Protection Agency Office of Solid
Waste and Emergency Response to Regional Administrators Regions I - X, January 29, 1990
(discussing delegation of remedy selection authority).
47. U.S. Environmental Protection Agency. Office of Emergency and Remedial Response.
Personnel Protection and Safe~.
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