United States Office of
Environmental Protection Emergency and
Agency Remedial Response
EPA/ROD/R01-90/050
September 1990
v>EPA Superfund
Record of Decision:
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50272.101
REPORT DOCUMENTATION 11. REPORT NO. I ~ 3. Reclplent'e AcceMion No.
PAGE EPA/ROD/ROl-90/050
4. Title end Subtitle 5. Report Dete
~UPERFUND RECORD OF DECISION 09/28/90
,eacon Heights Landfill, tT '
6.
First Remedial Action - Final (Supplemental)
7. Author(e) 8. Perfonnlng Orgenlzatlon RepL No.
II. Perfonnlng Orgalnlzatlon Neme and Add..... 10. ProjectiTa8klWork Unit No.
11. COnlt8ct{C) or Grent(G) No.
(C)
(G)
1~ ~orIng Organization Neme and Addre.. 13. Type 01 Report & Perfod Covered
U.S. Environmental Protection Agency 800/000
401 M Street, S.W.
Washington, D.C. 20460 14.
15. Supplementary Notee
16. Abafrect (limit: 200 worde)
The 34-acre Beacon Heights Landfill site is on the northwest corner of an 82-acre
property in Beacon Falls, Connecticut. From the 1920s to 1970, a 6-acre area of the
site was used as a dumping and incineration area. The site was subsequently expanded to
a 34-acre area where waste materials including industrial liquids and chemicals were
"'1Jried until the State closed the landfill in 1979. Industrial waste water sludge also
s disposed of on site. Because of a slide of soil and buried waste in 1972, ground
water and leachate discharge points were created in the north/northwestern areas of the
landfill; several of these discharge points still persist in the slide area. In 1984,
sampling of forty-four residential wells downgradient of the site revealed
VOC-contaminated water in two residential wells. As a result of the sampling, the State
provided bottled drinking water to the affected residents. A 1985 Record of Decision
(ROD) documented remedial activities, including consolidation and capping of
contaminated soil at the six-acre area; installation of a leachate collection system;
and extension of a public water supply line to area residences. This ROD supplements
the 1985 ROD by resolving those determinations left open in the 1985 ROD including the
manner and locations of leachate treatment/disposal; cleanup levels for soil deemed
(See Attached Page)
17. Document Analyele .. Deecrfptore
Record of Decision - Beacon Heights Landfill, CT
First Remedial Action - Final (Supplemental)
Contaminated Media: soil, gw, sw
Key Contaminants: VOCs (benzene, toluene, xylenes)
b. IcI8ntlfler8l0pen-Ended Terme
c. COSA TI Reid/Group
18, Avel.abllty Statement 1 II. Security Cle.. (Thie Report) 21. No. 01 Pagea
, " None 126
20. Security Cle.. (Thie Page) 22. PrIce
None
.",
c,
(See ANSl-Z311.18)
See Inetruclione on Rsvel8e
(Formerfy NTlS-35)
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EPA/ROD/ROl-90-/050
Beacon' Heights Landfill, CT
'rst Remedial Action - Final (Supplemental)
Abstract (Continued)
impracticable to cap in areas contiguous to the landfill; and
controls on the landfill gas vents. The primary contaminants
soil, ground water, surface water, and air are VOCs including
xylenes.
the need for air pollution
of concern affecting the
benzene, toluene, and
Q
The selected remedial action for this site supplements the remedial actions documented
in the 1985 ROD and includes offsite leachate treatment at a waste water treatment
facility prior to offsite discharge of the treated effluent to offsite surface water;
offsite incineration of the sludge generated during leachate treatment; monitoring of
landfill gases; and providing the criteria for excavation of the contaminated soil
deemed impracticable to cap. Although air pollution controls are not currently
necessary, the vents to be built into the future cap will be constructed in such a way
as to facilitate the addition of pollution control devices should continual monitoring
reveal levels of air contaminants exceeding Federal and State standards. The present
worth cost for this supplemental remedial action is $2,241,000, with a present worth O&M
cost of $951,000.
PERFORMANCE STANDARDS OR GOALS: In order to protect the aquifer underlying the site
from further potential contamination, excavation levels for contaminants of concern in
soil contiguous to the area of the landfill deemed impracticable to cap are based on
leachate modeling. In the absence of a chemical-specific ARAR, cleanup goals will be
based on a 10-6 excess cancer risk level for carcinogens or a HI=l for noncarcinogens.
~il excavation levels include benzene 0.08 mg/kg, TCE 0.01 mg/kg, toluene 100 mg/kg,
.od xylenes 500 mg/kg. No cleanup levels for leachate were set because all but
negligible amounts of leachate will be removed and treated offsite. The treatment
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BEACON HEIGHTS LANDFILL
SUPPLEMENTAL RECORD OF DECISION
September ~8, 1"0
/
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DECLARATION FOR THE SUPPLEMENTAL RECORD OF DECISION
Beacon Heights Landfill
Beacon Falls, Connecticut
<.)
STATEMENT OF PURPOSE
This decision document completes, to the extent technically
practicable, the remedy outlined in the 1985 Record of Decision
(ROD) for the Beacon Heights Landfill Site (the Site) in Beacon.
Falls, connecticut, and represents the selected leachate
treatment and disposal alternative developed in accordance with
the Comprehensive Environmental Response, Compensation and
Liability Act of 1980 (CERCLA), as amended by the Superfund
Amendments and Reauthorization Act of 1986, and to the extent
practicable, the National oil and Hazardous Substances
Contingency Plan (NCP), 40 CFR Part 300 ~ ~., as amended.
This remedial action along with the determinations concerning the
soil cleanup levels and air pollution controls on the landfill
gas vents will be protective of human health and the environment
at the completion of the remedy. The Region I Administrator has
been delegated the authority to approve this supplemental ROD.
The Connecticut DEP concurs with the selected alternative for
leachate treatment and disposal and with the determination for
air pOllution controls, but does not concur with the soil
remediation levels. A copy of the declaration of
concurrence/non-concurrence is attached as Appendix B to this
supplemental Record of Decision.
STATEMENT OF BASIS
This decision is based on the Administrative Record which has
been developed in accordance with section 113 (k) of CERCLA and
which is available for public review at the Beacon Falls Town
Hall in Beacon Falls, Connecticut and at the Region I Waste,
Management Division Records Center in Boston, Massachusetts. The
Administrative Record Index (Appendix B to the ROD) identifies
each of the items comprising the Administrative Record upon which
the selection of the remedial action is based.
ASSESSMENT OF THE SITE
Actual or threatened releases of hazardous substances from this
site, if not addressed by implementing the response action
selected in this supplemental ROD, may present an imminent and
substantial endangerment to the public health or welfare or to
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g~~~~~i~~o~~' ~ c~J~~~ TRErkT,g~s~~~y E~~i~:~~~~~~IR
POLLUTION CONTROLS ON "lANDFILL GAS VENTS'
This supplemental ROD sets forth the selected alternative for the:
manner and location of leachate treatment, and determines the .
extent to which contaminated soils will be excavated for
consolidation with the main landfill and the need for air
pollution controls on the landfill gas vents at the Beacon
Heights Landfill site.
G
The selected leachate treatment/disposal alternative and the soil
and pollution control determinations described in this
supplemental ROD, together with the remedial action specified in
the 1985 ROD. will protect the drinking water aquifer by
minimizing further mdgration of contaminants to the groundwater
and surface water, and will eliminate threats posed by direct
contact with or ingestion of contaminated soils and wastes at the
site. .
The major components of this supplemental ROD include:
.
Transport and subsequent treatment of contaminated
leachate at the Naugatuck, connecticut wastewater
treatment facility.
Determination of the extent to which contaminated soils.
located outside the main landfill will be excavated.
.
.
Determination of the need for air pollution controls to
be installed on the landfill gas vents at the Site.
The major components of the 1985 ROD included:
.
Excavating and/or capping Betkoski's dump and other
contaminated soils for consolidation with the main
landfill prior to closure.
RCRA capping of the consolidated wastes, including gas
venting (with air pollution controls if determined
necessary in a supplementary Decision Document), and
stormwater management controls.
.
.
Installing a perimeter leachate collection system.
Extending a public water supply line along Skokorat
Road and along Blackberry Hill Road to service current
residences.
.
.
Enclosing the site with security fencing.
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.
Installing a more extensive groundwater monitoring
system.
Collection of leachate and transporting it to a
licensed waste water treatment facility or on~site
treatment followed by discharge to a tributary of the
Bockanum Brook. .
.
.
A supplemental ROD selecting the manner and location of
leachate treatment (onsite or offsite), the extent of
excavation of contaminated soils, and the need for air
pollution controls on the landfill gas vents would be
prepared.
DECLARATION
The selected leachate treatment/disposal alternative and the soil
and air pollution control determinations will be protective of
human health and the environment at the completion of the remedy,
attain Federal and state requirements that are applicable or
relevant and appropriate and are cost-effective. The selected
leachate treatment/disposal alternative satisfies the s~atutory
preference for remedies that utilize treatment as a principal
element to reduce the toxicity, mobility, or volume of hazardous
substances. In addition, this leachate treatment/disposal
alternative utilizes permanent solutions and alternative
treatment technologies to the maximum extent practicable.
As this alternative will result in hazardous substances remaining
onsite above health-based levels, a review will be conducted
within five years after commencement of remedial action to ensure
that the remedy continues to provide adequate protection of human
health and the environment.
?/a.r/ff)
.
I)a~al
Julia B aga
Regional A iDi8~ra~or
U.S. BPA, .egioD I
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BEACON HEIGHTS SUPPLEMENTAL RECORD OP DECISION
TABLE OP CONTENTS
%.
SI'1'B DBSCR%P'1'ION
. . . . . . . .
. . . . . . . . . . . .
%1.
SI'1'B HIS~RY AND BNFORCBMENT ACTIVI'1'IBS . . . . . . . .
A. GeDera1 site History. . . . . . . . . . . . .
B. state Response History. . . . . . . . . . . .
c. ~ederal Response History. . . . . . . . . . .
D. Bnforcement History. . . . . . . . . . . . .
"
%11. COMMUNITY RELATIONS
. . . . .
. . .
. . .
. - . .
. . .
XV.
SCOPB AND ROLE OP RESPONSE ACTION
. . . . . . . . . . .
V.
St1MKARY OP SITB CKADC'l'BRXSTICB . . . . . . . . . . . .
A. Soil.....................
B. Groundwa ter . . . . . . . . . . . . . . . . .
c. Leachate...................
1. Leachate Quanti~y . . . . . . . . .
2. Leachate Quality. . . . . . . . . .
Surface Water. . . . . . . . . . . . . . . .
Ai.r . . . . . . . . . . . . . . . . . . . . .
.
D.
E.
VI.
PUBLIC BEM,TB U1) BNVIROIlMDTAL CONCIRNS
. . . . . . . .
VII. DEVELOPMENT AND SCREENING O~ ALTERNATIVBS ~OR LEACHATE
TREATMENT AND DISPOSAL AND DETERMINATIONS REGARDING
CONTAMINANT LEVBLS ~OR SOIL EXCAVATION AND ~OR AIR
POLLUTION CONTROLS ON LANDPILL GAS VBNTS . . . . . . . .
A. statutory Requirements/Response objectives. .
B. Leacbate Disposal and Treatment Tecbnology
and Alternative Development and screeninq;
Basis for Soil Ezcavation and Gas Treatment
Determination. . . . . . . . . . . . . . . . .
VIII.
DESCRIPTION OP LEACHATE TREATMENT AND DISPOSAL
ALTERNATIVBS . . . . . . . . . . . . .
. . . .
%x.
SUMMARY O~ Till COMPARATIVE ANALYSIS 01' LEACHATB
TREA'rHEft AND DISPOSAL ALTERNATIVES. . . . . . . . . .
1. Overall protection of Human Healtb and tbe
Bnvironment . . . . . . . . . . . . . . . . .
compliance witb Applicable or Relevant and
Appropriate. . . . . . . . . . . . . . . . .
Lonq-term Effectiveness and Permanence.. . .
Reduction of Tozicity, Mobility, or Volume
ThrouqbTreatment . . . . . . . . . . . . . .
Short-Term Effectiveness. . . . . . . . . . .
Implementability . . . . . . . . . . . . . . .
cost. . . . . . . . . . . . . . . . . . . . .
2.
3.
C.
5.
I.
7.
8.
I.
. . . . . .
. .8 , . . .
state Acceptance. . .
community Acceptance.
.....~.
. . .
. . .
1
2
2
2
4
6
7
8
8
9
9
9
9
10
10
10
11
16
16
17
19
24
26
27
27
29
30
32
33
33
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X.
'1'JIB SELECTED ALTERNATIVB I'OR LEACHATE TREATMENT AND
DISPOSAL. . . . ... . . . . . . . . . . . . . . . . . .
A. Leachate Treatment and Di.posal Cleanup
Levels. . . . . . . . . . . . . . . . . . . .
Leachate Treatment Components. . . . ... . .
B.
XI.
DETERMINATION 01' CONTAMINANT LEVELS POR SOIL
BXCAVATION . . . . . . . . . . . . . . . . . .
A. Soil Cleanup Level. . . . . . . . .
B. Soil Excavation component. . . . . .
. . . . .
. . . . .
. . . . .
XII. DETERMINATION POR AIR POLLUTION CONTROLS ON LANDI'ILL
GAS VENTS. . . . . . . . . . . . . . . . . . . . . . .
A. 50 Air Pollution Controls are Neede4 . . . . .
B. continued Monitoring. . . . . . . . . . . .
XIII.
PUTURE ACTIONS. . . . . . . .
. . .
. . . . . . . . .
XIV. STATUTORY DETERMINATIONS. . . . . . . . . . . . . . . .
A. The Reme4ial Actions specifie4 in this
Supplemental ROD are protective of Human
Health an4 the Environment. . . . . . . . . .
B. . The Remedial Actions Specifie4 in this
supplemental ROD Attain ARARs . . . . . . . .
The Reme4ial Action i. Cost-Effective. . . .
The Selecte4 Alternative for Leachate
Treatment an4 Disposal an4 the Determination
for Air Pollution Controls.utili.e permanent
Solutions and Alternative Treatment
Technologie. or Resource Recovery
Technologies to the Maximum Bxtent
practica):)le . . . . . . . . . . .. . . . . . .
The Reme4ial Actions Selecte4 in this
Supplemental ROD satisfy the Preference for
Treatment Which significantly Re4uces the
Toxicity, Mobility or Volume of the Hazar40us
Substances a. a principal Element. . . . . .
C.
D.
E.
xv. DOCOHBNTATION 01' SIGNIPICANT CHANGES
. . . .
. . . . . .
XVI. STAT. ROLB .
. . . .
. . . . . . . . .
. . . .
. . . . .
APPENDIX A - Figure.
APPENDIX B - Tables
APPENDIX C - Responsiveness Summary
APPENDIX D - state of Connecticut Concurrence Letter
APPENDIX B - Administrative Recor4 Index
34
34
34:
..
35
36
39
40
40
41
42
42
42
43
46
48
50
50
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I.
8ITB DBSCRIPTIOB
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II.
SITB HISTORY AND ENFORCEMENT ACTIVITIES
A.
G8D8ra1 Si~8 Hi.~ory
C>
From the 1920's until 1970 a small portion of what is now known
as the Beacon Heights Site was known as nBetkoski's Dumpn and
consisted of approximately 6 acres of active dumping and open
burning in the northwest corner of the existing site. During
this period of' operation, there were qeneral complaints and
concerns, due to fumes, smoke, and "blowing litter. The Site was
not regulated by the State until 1970. (See section V for a more
detailed description of Site characteristics.) .
In 1970 Beacon Heights, Incorporated (BHI) purchased the Site,
which included the Betkoski Dump area. BHI and its owner, Harold
Murtha, owned and operated the Site as Beacon Heights Landfill
and expanded the landfill area to approximately' 34 acres. On-
site soil generated by this expansion was used as cover material
for the landfill. Wastes were placed directly onto bedrock and
covered with soil, and waste materials were no longer burned.
"
A slide of soil and buried waste occurred on the northwest side
of the landfill in 1972 due to both landfill operations and the
changed surface and groundwater patterns from construction of the
access road. This slide created groundwater and leachate
discharge points in the north/northwest areas of the landfill.
Several of these discharge points still persist in the slide
area.
From 1973 until the Site closed in July, 1979 specified areas or
cells were used for the disposal of various waste materials
rather than placing waste directly onto bedrock. Cover material
was placed over all working areas.
In 1977 the Connecticut Department of Environmental Protection
(CT DEP) approved spreading of waste water sludge from the
Naugatuck municipal/industrial waste water treatment facility
over covered areas of the landfill. These activities continued
until the summer of 1984.
B.
State .espoDse Bi.~ory
.~he State of Connecticut began regulating the Site in 1970.
. 1972 and 1973 BHIwas ordered by CT DEPto develop plans for
eliminating pollution from the landfill and surrounding
groundwater.
DEP attempted to close the landfill and regulate industrial
liquids and chemicals disposed at the landfill by issu1ng
additional orders to BHI in 1975 and 1976. These orders cited
contamination of well water and Hockanum Brook tributaries as a
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result of landfill operations. In response to these actions, BHI
submitted a second engineering report describing an improved
landfill operating plan but failed to provide a groundwater
monitoring plan.
These activities culminated in a Consent Order between BHI and CT
DEP to close the facility by July 1, 1979. The Consent Order was
siqned on June 20, 1979 and entered as a final order of the
Connecticut Commissioner of Environmental Protection on July 24,
l;;S. BIII complied with the consent order and the landfill was
closed in July, 1979.
Forty-four residential wells, located down gradient of the Site, .
along Skokorat and Blackberry Hill Roads were sampled by EPA in
1984. Samples were analyzed for Hazardous Substance List (HSL)
organic and inorganic para~eters. Two contaminated residential
wells located along Skokorat were resampled in November 1984.
These wells revealed benzene at concentrations ranging from 32 to
131 micrograms per liter (ug/l). As a result of EPA sampling, CT
DEP provided bottled water to these residences as a temporary
safe drinking water source. Other organic compounds detected in
some of the residential well samples were below levels that would
indicate any health risks. To provide more data on the nature of
residential well contamination, some residential wells were
resampled in January 1985. These results generally confirmed the
results of the previous samples. Benzene.was detected in the
same wells again at 42 to 89 ug/l. Low levels of other organic
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c.
Federal Response ~~
EPA conducted several preliminary study/sampling activities in :
1981 and 1982 to evaluate site CDDditions, to collect preliminary
sample data, and to identify the potential for immediate health
risk as a consequence of the Site. The Site was listed on the
EPA's National Priorities List on September 1, 1983. As a result
of the listing, the site became eligible for remedial actions
under the Comprehensive Environmental Response, Compensation, and
Li~~ility Act (CERCLA).
~
NUS corporation, EPA's contractor, performed a Remedial
Investigation (~) at the Site from March 1984 through April
to supplement the previous investigations at the site and to
provide sufficient data to perform an Feasibility Study (FS).
The RI/FS was released to the public in April 1985.
A more detailed description of the site history leading up to the
FS including a summary of the results of the RI can be found in
section 1 of the FS Report.
1985'
,
Based on the RI/FS studies, EPA issued a Record of Decision (ROD)
on September 23, 1985, documenting the selected remedial actions
for the site. The remedy included:
.
Excavating Betkoski"s dump and other.contaminated soils for
consolidation with the main landfill prior to closure.'
RCRA capping of the consolidated wastes, including gas
venting (with air pollution controls if determined necessary
in a Supplementary Record of Decision Document), and
stormwater management controls.
.
.
Installing a perimeter leachate collection system.
.
Extending a public water supply line along Skokorat Road and
along Blackberry Hill Road to service current residences.
Enclosing the site with security fencing.
.
.
Installing a more extensive groundwater monitoring system.
collecting of leachate and transporting it to a licensed
waste water treatment facility or on-site treatment followed
by discharge to a tributary of the Hockanum Brook.
.
'Although the 1985 ROD and the Proposed Plan call for
excavating Betkoski's dump, only a portion of the dump area will
be excavated. The remaining area ~ill be included under the cap.
(See section XIV, Explanation of Significant. Differences, for a
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Further studies and a supplemental ROD selecting the manner
and location of leachate treatment (on-site or off-site),
the extent of excavation of contaminated soils, and, the need ,:
for air pollution controls on the landfill gas vents would
be prepared.2 ' ,
After the 1985 ROD was signed, EPA issued an Administrative Order
in October, 1986 in response to contamination discovered in some
private residence wells and as a precaution against further
leachate contamination. The order required 31 generators to offer
residences in the vicinity of the landfill the opportunity to
become connected to the municipal water supply system. Fifty-
eight residences opted to become hooked up to the municipal water
system, and domestic water supply wells previously serving the
residences were decommissioned. Eight area residences declined
and continue to use private wells to supply drinking water.
.
<;)
In september, 1987 the United states entered a consent decree
with 32 PRPs, now known as the Beacon Heights Generators
Coalition (BHGC), under which those PRPs agreed to perform the
remedial action at the site. Among other things, the consent
decree required. the PRPs to perform pre-desiqn studies to qather
the information which forms the basis for the determinations made
in this supplemental ROD.
Because Beacon Heights, Inc. denied site access to BHGC for these'
studies and other remedial activities, remedial investigation
work was not performed until a court order issued in October 1988
required BHI to provide access.
In March, 1990, the BHGC submitted a final draft of the Pre-
Design Studies Report to EPA. A Proposed Plan regarding the
decisions to be made in this supplemental ROD was issued in May,
~his document represents the Supplemental ROD referred to in
the 1985 ROD. Therefore, this document is limited to resolving
those determinations left open in the 1985 ROD. Those
determinations are
(1) manner and location of leachate treatment/disposal;
(2) extent of excavation of contaminated soils; and
(3) need for air pollution controls on the landfill gas vents.
Both the 1985 ROD and this Supplemental ROD document the remedy
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1990. Based on the Pre~Design Studies Report, the RIfFS, and on
.public and State comments, EPA reached the determinations set out
in this supplemental ROD.
D.
Enforcem.nt Hi.tory
In March, 1985, EPA notified approximately sixty (60) parties who
either owned or operated the landfill, generated the wastes that
were shipped to the landfill, arranged for the disposal of wastes
at the landfill, or transported the wastes to the landfill of
their potential liability with respect to the Site. Negotiations
ensued with these potentially responsible parties (PRPs)
regarding the settlement of their liability at the Site.
A subset of the PRPs consisting primarily of waste generators
formed a steering committee (Beacon Heights Generators Coalition-
BHGC). Negotiations between EPA and BHGC resulted in a consent
decree in September, 1987 requiring BHGC to pay for and perform
all of the work necessary to complete the remedial action at the
Site. This work included the pre-design study work described
above.
~
In March, 1990, pursuant to the Consent decree, the BHGC
submitted a Pre-Design Studies Report which presented several
alternatives and recommendations for the treatment and disposal
of leachate as well as information on the. extent of soil
excavation and air pollution controls on the landfill gas vents.
The BHGC also submitted technical comments regarding the Proposed
Plan during the public comment period. These comments are
included in the Responsiveness Summary in Appendix C.
In addition to the above noted sections, the Beacon Heights Site
has also been the subject of extensive litigation. In March
1987, the United States sued Beacon Heights, Inc., Harold Murtha,
and a number of affiliated corporations and individuals under
section 107 of CERCLA to recover response costs incurred at the
site and another nearby site, the Laurel Park, Inc. Superfund
Site, also owned by a Murtha affiliated corporation. The BHGC
also filed claims against the Murtha entities for contribution
toward the anticipated cost of the cleanup of the Beacon Heights
Site.
In spring 1988, Beacon Heights, Inc., Harold Murtha, and their
affiliated corporations filed claims against approximately 200
individuals and corporations, claiming that they too were liable
. for the cleanup of the Beacon Heights and Laurel Park sites.
These claims sought to have these 200 persons contribute toward
the cleanup costs at the two Sites.
In September 1988, the United States brought claims against eiqht
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incurred at the Beacon Heights site, which were not collected
under the terms of the 1987 consent decree.
These various lawsuits have been consolidated into one action
currently pending in the Connecticut federal district court.
o
III. COMKONITY RELATIONS
Q
Thr011~hnu~ the Site's history, community concern and involvement
have been high. EPA has kept the Gommunity and other interested
parties apprised of Site activities through a series of
informational meetings, fact sheets, and press releases.
On May 9, 1990 EPA held a public informational meeting to discuss
the results of the Pre-Design Studies for this supplemental ROD.
At this meeting, EPA (1) presented the Agency's proposed Plan for
the manner and location of leachate treatment and disposal, the
soil excavation criteria for the contaminated soils located
adjacent to the main landfill area, and the need for air
pollution controls on the gas vents: (2) answered questions from
the public; and (3) announced that from May 9 to June 8, 1990 the
agency would hold a 30 day comment period to accept public
comment on the alternatives presented in the Pre-Design Studies
and the Proposed Plan.
On May 30, 1990, the Agency held a public hearing to discuss the
Proposed Plan and other alternatives evaluated and to accept any
oral-comments for the record. A transcript of this meeting and
all comments received during the comment period and the Agency's
response to these comments are included in the attached
Responsiveness summary. In response to public request, EPA
increased the original 30 day comment period to 60 days ending on
July 9, 1990 to allow opportunity for additional review and
comment. Approximately fourteen sets of comments were received
from residents, state and local government officials, and PRPs.
The PRPs were concerned primarily with pretreatment potential and
the criteria utilized to set the soil excavation levels for
cleanup. They also questioned the need to specify which off-
site alternative should be used and suggested a more generic
approach of merely choosing off-site treatment and leaving the
decision as to which type of off-site treatment for a later date
pending negotiations between the PRPS and the Town of Beacon
Falls and the Borough of Naugatuck.
An Administrative Record for the Site was originally established
in september, 1985 and has been updated as of the signing of this
supplemental ROD. This supplemental ROD and much of the material
used in its development are included in the Administrative Record
and are available for public review. Copies of the updated
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. the Beacon Falls Town Hall, the information repository that EPA
established for the Site: and at the EPA Records Center at 90
Canal Street, Boston, Massachusetts.
One of the alternatives described in the Proposed Plan
contemplated offsite leachate treatment and disposal at the Town
of Beacon Falls waste water treatment facility. Tbe BHGC met
with the Town of Beacon Falls at various times during the process
to discuss the possibility of sending leachate to the Beacon
Falls facility for treatment and disposal. EPA consulted with
both the Town and the BHGC from time to time during these
discussions to keep abreast of significant developments'. As of
the signing of this supplemental ROD, the Town of Beacon Falls
has not consented to accepting the leachate. Without the Town's
consent, this alternative cannot be implemented.
"
"
IV.
SCOPE UJ) ROLE OP RESPONSE ACTION
The performance objectives described in this document for
leachate treatment and disposal, for the extent of soil
excavation and the need for air pollution controls on tne
landfill gas vents are part of the overall remedial action
documented in the 1985 ROD for the site. The supplemental ROD
completes the remedial action decisions made in the 1985 ROD to
the extent technically practicable. Specifically, the
supplemental ROD determines the leachate treatment and disposal
plan: completes the soil excavation component for the capping
portion of the remedy: and establishes the performance standards
and procedures that will be utilized in determining the air
pollution control component of the gas venting system.
The performance objectives for remedial action are described more
fully in Sections X, XI, and XII of the supplemental ROD and are
an integral part of the remedial action decisions documented in
the 1985 ROD. The supplemental ROD and the 1985 ROD address the
following principal threats to human health and the environment
posed by the site: ,
.
Off-site migration of contaminants via leachate.
Future ingestion of contaminated groundwater on-site
and off-site.
.
.
Future ingestion and direct contact with contaminated
soils and solid wastes adjacent to the main landfill.
Inhalation of potentially harmful gas produced within
the landfill. .
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-.
9
8UMMARY O~ 8ITB CBARACTBR%8TIC8
v. '
n
, Chapters 3 and 4 of the Pre-Design studies contain an overview of
the most recent sampling and analysis performed at the site and'
sampling and analysis performed during the 1985 RI. The
significant findings of the Pre-Design studies and the RI are
summarized below.
o
A.
80il
site soils were subjected to physical and chemical testing during'
the 1985 RI/FS and the Pre-Design studies. This was done to
evaluate the extent of contaminated soils adjacent to the main
landfill. Analyses of soil samples taken in locations outside
the proposed cap area reveal the presence of benzene
(concentration range: 3.5 to 2,200 ug/kg), xylene (concentration
range: 460 to 490 ug/kg), lead (45,000 ugfkg), chlorobenzene
(concentration range: 20 to 2,400 ug/kg), trichlorofluoromethane
(280 ug/kg), 1,1-dichloroethane (3,700 ug/kg), 1,1-
dichloroethene (47 ug/kg), and bis (2-ethylhexyl) phthalate
(concentration range: 380 to 1,990 ug/kg). More complete
results of these analyses are presented in Table 1. Figure 2
delineates the approximate areas of contaminated soil located
outside the main landfill.
The 1985 ROD determined that due to the t~chnical difficulty and
the excessive cost of capping all contaminated soils on Site,
some areas will be excavated and consolidated with the main
section of the landfill prior to capping.
B.
Groundwater
The general flow of groundwater in the landfill area is to the
north/northwest, paralleling the direction of the adjacent
surface water streams and surface topography. studies conducted
during the RI show the average groundwater flow velocity in the
unconsolidated soils near the site to be approximately 50 feet
per year (1.8 em/see). More detailed descriptions of the ~
groundwater properties are located in section 4 of the RI.
c.
Leachate
1.
Leachate Quantity
The rate and quantity of leachate presently generated by the
uncapped landfill is a function of a variety of factors,
including precipitation, the permeability of the soil cover over
the wastes, and the degree of surface runoff f~om the landfill.
As part of the pre-Design studies the quantity of leachate'
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10
produced after capping. . This analysis showed that the landfill
generates an average of 20 gallons per minute (qpm) of leachate,
with the highest leachate peak flow estimated at approximately 42
qpm; in drier periods, flow may be .less than 10 qpm. ..
The Pre-Design studies also revealed that between 5 to 10 years
after capping of the main landfill, leachate production may
diminish to a point at which minimal or no collection and
treatment will be necessary. Figure 3 shows the expected
~~a~tity of leachate flow after capping.
..
"
2.
Leachate Quality
Samples taken during the RI/FS and the Pre-Design Studies from
leachate seeps and groundwater monitoring wells both inside and
outside the property boundary were evaluated to determine the
types of leachate treatment which would be most appropriate for
the site. These samples were analyzed for Hazardous Substance
List (HSL) components, organic and inorganic compounds, Total
organic Carbons (TOCs), and dioxin. Additionally, the samples
were analyzed for general chemistry parameters and BOD. The
variety of leachate and groundwater samples were contaminated
primarily with volatile organic compounds (VOCs), including
benzene (concentration range: 3 to 35,000 ug/l), chlorobenzene
(concentration range: 1.3 to 5,310 ug/l), toluene (concentration
range: 1.1 to 2,400 ug/l), ethyl benzene (concentration range: 2
to 590 ug/l), and chloroethane (concentration range: 10 to 1,450
ug/l). Semi-Volatile compounds were detected in the following
concentrations: bis(2-chloroethyl) ether (concentration range: 24
to 4,680 ug/l), xylene (concentration range: 3 to 447 ug/l) and
bis (2-ethylhexyl) phthalate (concentration range: 10 to 1,990
ug/l). Figure 4 shows the approximate sampling locations.
Inorganic analyses were performed to assist in evaluating
treatment processes for select metals. Elevated levels of
barium, cyanide, manganese, iron, and zinc were detected in the
leachate. Table 2 provides a summary of additional physical and
chemical analyses performed on leachate/groundwater samples
obtained as part of the Pre-Design Studies and the Remedial
Investigation.
D.
Surface Water
At present, leachate discharged from the site drains to a
tributary to the Hockanum Brook. Subsequently ,the leachate
enters the Hockanum Brook via the tributary. CT DEP has
classified the Hocka~um Brook as B/A, recreational use water with
the goal of becoming drinking water quality. CT DEP feels that
the Brook is currently class B (less than drinking water
standar~s) due to the contaminants leaching from the Beacon
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. .. .
11
sampling analysis was performed during the 1985 RI to
characterize any possible contamination of the local surface
waters. The results of this sampling are presented in Table 3.
(J
B.
air
A limited air investigation was performed as part of the 1985
RI/FS. The JlaXimum gas vent concentrations are below the Maximum
Allowable Stack Concentrations (MASC). Similarly, analyses of
ambient air samples at the landfill property boundaries indicate
that all constituents detected are' below both Connec~icut Hazard
Limiting Values and the Connecticut Odor Threshold Limits. The
results of the 1985 samplings revealed the ,presence of nine
volatile organic compounds. The highest concentsations observed
were for benzene 121.5 ug/m3), toluene (20.7 ug/m), and total
xylenes ( 8.8 ug/m)
No reliable trends were observed with air emissions at the Site
during the Pre-Design Studies because gas vent and ambient air
samples collected as part of the Pre-Design Studies were deemed
inadequate for the following reasons:
1.
Surrogate recoveries often were outside quality control
limits:
2.
Failure to report analytical data in units which could
be incorporated into an estimate of exposure (ug/m3):
significant sample breakthrough was observed during
vent sampling: and
3.
Failure to document or obtain meteorological conditions
and background air quality information in an adequate
fashion such that an assessment could focus on the
contribution of landfill gas to ambient air quality.
continued monitoring as outlined in section XII A. and B. will
ensure that all applicable or relevant and appropriate
requirements will be met at the completion of the remedy.
4.
VI.
PUBLIC HEALTH AND ENVIRONMENTAL CONCERNS
A public health and environmental analysis was performed during
the 1985 RI/FS to estimate the probability of potential ,adverse
human health and environmental effects from exposure to
contaminants associated with the site. Limited sampling of
groundwater, leachate, and soil ,conducted as part of the Pre-
Design Study was also considered in the analysis of the threat to
public health. Using both sets of 'samples, with the exception of
inhalation of VOCs from landfill gas emissions, and the
consumption of fish, site risks are based on the highest
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. .
12
contamination observed were similar or below the levels observed
as part of the 1985 RI/FS. Because the 1985 ROD eliminated the
no action decision for leachate treatment and disposal, a second
subsequent quantitative risk assessment was not perform~~. :
The public health analysis 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 the
exposure: 3) toxicity assessment which considered the types and
magnitude of adverse human and environmental effects associated
with exposure to hazardous substances, and 4) risk
characterization, which integrated the three earlier steps to
summarize the potential threats posed by hazardous substances at
the Site. The results of the public health and environmental
analysis for the Beacon Heights Landfill Site are discussed
below.
OVer 50 contaminants were detected at the Beacon Heights Landfill
during the Remedial Investigation/Feasibility Study and Pre-
Design Study. The analysis of public health concerns focused on
a subset of these contaminants found to pose the greatest risk to
human health at the Beacon Heights landfill. Seven (7)
contaminants of concern were selected to represent potential Site
related hazards based on observed concentration, toxicity,
frequency of detection, and persistence in the environment.
Observed ranges in concentration for the contaminants of concern
in each medium are listed in Tables 5-9 of this supplemental
Record of Decision. A discussion of the toxicity and health
effects of each of the contaminants of concern can be found in
section 2.3.2 "Potential Health Effects" in the Beacon Heights
Landfill Feasibility Study, May 1985. Further discussions can be
found at pages 5-8 of the 1985 ROD.
An evaluation of the potential threat to public health posed by
the consumption of contaminated groundwater and ingestion and
dermal contact of contaminated soils was performed by comparing
the observed concentration to the most relevant public health
criteria available in 1985. This included Acceptable Daily
Intakes (ADIs), suggested No Adverse Response Levels (SNARLs)
corresponding to a 1-day, lO-day, and long term health advisory,
and groundwater concentrations corresponding to a 10.' excess
cancer risk level. On the basis of these comparisons, observed
groundwater levels of be~zene and bis(2-chloroethyl) ether were
found to exceed concentrations corresponding to a 10.' excess
cancer risk level by 1,000 and 100,000 fold respectively.
~
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. .
. 13
/..)
Benzene was also found to exceed the 10-day and long term health
advisories. Additionally, the maximum concentration of
chlorobenzene in ground water exceeded the acceptable daily
intake for this compound.
In the 1985 RIfFS, potential human health effects associated with
exposure to the contaminants of concern in other media were
evaluated by considering potential exposure pathways. These
included direct contact with leachate, inhalation of contaminants
from the soil, groundwater, surface water, and leachate by
workers or other individuals, and consumption of fish. A
discussion of exposure pathways can be found in section 2.4.4 of
the Beacon Heights Landfill Feasibility Study, Hay 1985.
Gas vent and ambient air samples collected as part of the Pre-
Design Studies were inadequate for a quantitation of possible
health risks and for comparison to ARARs due to the factors
listed in Section A above. Despite these limitations, there is
evidence from the Pre-Design Studies to suggest that toxic
pollutants have been observed in landfill emissions and that as
part of future remedial activities (i.e. capping), monitoring of
landfill emissions will occur. Should subsequent monitoring data
reveal there to be a threat to human health or the environment,
controls will be implemented. Based on the air investigation of
1985, potential inhalation of VOCs originating"from contaminated
media was deemed unlikely to result in any adverse health.
consequences. '
In summary, ingestion of groundwater represented a significant
threat to public health although at present an alternate water
supply eliminates direct exposure to groundwater, except for the
eight residences which declined to be hooked up to the alternate
water supply. Furthermore, as long as source materials remain in
soils and groundwater, the potential exists for further
degradation of groundwater quality to levels which would endanger
public health if consumed. Direct contact with leachate was also
found to pose a substantial threat to public health if protective
measures are not imposed while consumption of fish was deemed
unlikely to result in adverse health consequences. Although VOCs
in the landfill gases did not appear to pose any adverse health
consequences in 1985, VOC concentrations are likely to fluctuate
over time as the landfill settles and ages and may pose a threat
to public health.
Actual or threatened releases of hazardous substances from
contaminated soils and leachate and which are present in the
groundwater at'this Site, ,if not addressed by implementing the
response action selected in this ROD, may present an imminent and
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14
'lADLE 3: SUMKARY OJ' CON'l'AMXRMr1'S
01' CONCERN XN GROUND WATER
contaminant. of
Concern
Obs.rv.4
Concentration
Rang. (ug/l)
.
Benzene
3.0 - 850
1.3 - 797
Chlorobenzene
Ethylbenzene
23.0 -
28
Toluene
1.1 - 110
Xylenes
3.0 -
47
Bis (2-
chloroethyl) ether
Bis (2-ethylhexyl)
phthalate
45.0 - 4,360
10.0 -
38
cODtamiDut8 of
CODC8rn
'lADLE": SUMMARY 01' CON'l'AHI~
OJ' CONCERN XN StJRPACE WATER
0)).81"'184
CODc8DtratioD
Rang. (ug/1)
Benzene
16.0 - 49
Chlorobenzene
17.5 - 95
Bis(2-
chloroethyl) ether
420
Bis(2-ethylhexyl)
phthalate
26.0 -
30
. ..
Sampling results
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15
'1'ABLB 5 I StJMHARY OJ' CONTAMINANTS
OJ' CONCERN IN LBACHATB
"'
ContaminaDts of Observed
Conoern Concentration
1tange (ug/l)
Benzene 27.8 - 35,000
Chlorobenzene 15.5 - 5,310
Ethylbenzene 5.0 - 590
Toluene 20.8 - 2,400
Xylenes (totals) 11.0 - 447
Bis(2-
chloroethyl) ether 24.0 - 4,680
'1'ABLB ,: SUMMARY OJ' CONTAMINANTS
OJ' CONCERN IN SOILS
contaminants of Observed
Concern Concentration
Range (ug/kCJ)
Benzene 3.5 - 2,200
Chlorobenzene 20.0 - 2,400
Ethylbenzene 25
Toluene 15.0 - 2,800
Xylenes (totals) 460 490
Bis(2-
chloroethyl) ether 228
Bis(2-ethylhexyl)
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" .
. .
16
TABLE 71 SUMMARY 01' CONTtKINUrrS
01' CONCERN IN AIR
contaminant. of
Conc.rn
ObS8rv.d
conc8ntratif.n
Rang. (uq/m)
Benzene
16.6 - 21.5
18.0 - 20.7
Toluene
xylenes (total)
7.9
- 8.8
.
Sampling results from 1985 RI/FS only
VII. DEVELOPMENT AND SCREENING 01' ALTERNATIVES JlOR LBACDH
TREATMENT AND DISPOSAL AND DETERMINATIONS REGARDING
CONTAMINANT LEVELS ~OR SOIL EXCAVATION AND JlOR AIR POLLUTION
CONTROLS ON LANDFILL GAS VENTS
A.
statutory Requirements/Respon.. objective.
Under its legal authorities, specified in CERCLA, as amended,
and the NCP, EPA's primary responsibility at Superfund sites is
to undertake remedial actions that are protective of human health
and the environment. In addition, Section 121 of CERCLA
establishes several other statutory requirements and preferences,
including: a requirement that EPA's remedial action, when
complete, must comply with all federal and more stringent 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 if a principal element over
remedies not involving such treatment. The response
'Because the 1985 ROD was written before CERCLA was amended by
SARA, the selected remedy in that ROD did not need to meet the more
stringent remedial standards specified in section. 121. In
accordance with the statutory and'regulatory system" in effect at
the time, the 1985 ROD determined that the remedial "action selected
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,
.17
alternatives for leachate treatment and disposal wefe developed
to be consistent with these Congressional mandates. .
Based on the requirements of the 1985 ROD, its underlying RIfFS, .:
and other information relating to types of contaminants,
environmental media of concern, and potential exposure pathways,
remedial action objectives were developed to aid in the
development and screening of alternatives for leachate collection
and treatment and to inform EPA's determinations relating to soil
excavation and landfill gas treatment. These remedial action
objectives were developed to mitigate existing and future
potential threats to public health and the environment. These
response obj ecti ves were:.
.
To determine the manner and location for leachate
treatment and disposal to prevent continued degradation
of the ground water and off-site surface water and
potential exposure to leachate via ingestion.
To determine the contaminant levels for soils adjacent
to the proposed cap which protect both the a~ifer and
human health and the environment.
.
.
To determine the risks associated with inhalation of
the gas being produced by the landfill and the need for
air pollution controls on the gas vents at the Site.
B.
Leacbate Disposal and Treatment Technology and
Alternative Development and Screening, Basis for 80il
Excavation and Gas ~r.atm.nt Determinations
CERCLA and the NCP set forth the process by which remedial.
actions are evaluated and selected. In accordance with these
requirements, and the remedial action requirements made in the
1985 ROD, a range of leachate treatment and disposal alternatives
using different treatment technologies were developed during the
public health, welfare, and the environment.
'The determinations concerning the level of contamination in
the satellite areas of soil to be excavated reached in this
Supplemental ROD and which complete the remedy outlined in the 1985
ROD, will be protective of human health and the environment, will
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".
18
Pre-Design studies. In addition, in accordance with the dictates
of the 1985 ROD, areas of contaminated soil deemed impracticable
to cap were delineated and sampled. Once the treatment and
disposal alternatives were evaluated, the selected alte~ative
for leachate treatment and disposal vas documented in this
supplemental ROD as was the levels of contaminants to be
excavated and the need for pollution controls on the landfill gas
vents.
..
"
The 1985 ROD made the decision that contaminated soils in
locations determined to be impracticable to cap would be
excavated and placed on top of the landfill prior to capping of
the main landfill. The 1985 ROD further stated that these
contaminated soils would be excavated to background levels or to
alternate levels protective of human health, welfare, and the
environment. Pre-design sampling was necessary to define the
excavation criteria: therefore, the only decisions to be made in
this supplemental ROD with regard to soil excavation are the
contamination levels for the purposes of determining the extent
of excavation necessary to ensure protectiveness of human health
and the environment.
Chapters 5, 6 and 7 of the Pre-Design Studies Report analyzed and
evaluated the extent of soil excavation, the need for air
pollution controls, and the alternatives for the manner and
location of leachate treatment and disposal.
Chapter 5 describes the criteria for determining the extent of
soil excavation. The purpose of establishing soil excavation
criteria is to identify acceptable levels of chemical
constituents that may remain in the soils without adversely
impacting public health and the environment. EPA used two
groundwater modeling techniques inputting federal Maximum
Contaminant Levels (MCLS), proposed federal MCLs, and minimum
contaminant detection levels to set these contaminant levels.
Soils contaminated above these levels will either be capped in
place under the main landfill cap or excavated to these levels
and consolidated within the main landfill. '
Chapter 6 assesses the need for pollution controls on the
landfill gas vents. Landfill gas samples and perimeter ambient
air samples were obtained during the pre-Design Studies.
However, the data obtained is not considered reliable to assess
this potential need, or to compare with federal and state air
emission requirements. After capping, air quality at the
property boundary and other compliance points will be monitored
to determine the future need for pollution controls.
Chapter 7 of the Pre-Design Studies 'identified, assessed and
screened leachate treatment and disposal technologies ~ased on
implementability, effectiveness, and cost. Chapter 7 also
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".
19
technologies identified in the previous screening process. 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 al ternati ve was th~n
evaluated and screened in Chapter 7.
In summary, six leachate treatment alternatives were screened in
Chapter 7 and retained for detailed analysis. Section VIII of
this document identifies the six alternatives that were retained
through the screening process.
VIII.
DESCRIPTION OF LEACHATB !1'REAIftIBHT un DISPOSAL
ALTERNATIVES
The 1985 ROD examined three methods of leachate treatment: on-
site treatment using a permanent treatment facility (alternative
3), off-site treatment by means of trucking leachate to a
treatment facility (alternative 3B), and on-site treatment using
a temporary mobile treatment system (alternative 3C). The 1985
ROD determined that these three alternatives "provide the same
degree of source control" (p. 26), differing slightly in cost,
but all of which were more cost effective than other alternatives
examined. The 1985 ROD left for subsequent de~ision, in light of
additional data needed on such matters as projected leachate flow
and further refinement of estimated costs, which of thes~three
options to choose.
Although the 1985 ROD did not consider the Beacon Falls facility
as an off-site treatment location because of concerns about its
ability to handle industrial-type discharges like the leachate,
the information presented in the pre-Design studies concerning
the feasibility of upgrading the facility enables EPA to include
this alternative for leachate treatment and disposal.
To further develop and refine the information necessary to make
the determination regarding leachate treatment, the pre-Design
studies adopted the methodology of examining specific treatment
technologies, rather than the categorical types of treatment'
technologies examined in the 1985 ROD. These technologies
constitute the six alternatives evaluated in this supplemental
ROD.
Below is a narrative summary of each alternative evaluated in the
Pre-Design Studies. A more complete description can be found "in
Section 7 of the Pre-Design studies. The 1985 ROD required
collection of leachate and treatment either on- or off-site1
thus, the no-action alternative was eliminated in the 1985 ROD
and therefore was not considered in this supplemental ROD. The
leachate treatment and disposal alternatives considered for the
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2.
3.
4.
5.
6.
20
1.
Off-site treatment at the Beacon Falls waste water
treatment facility, LT-1.
Off-site treatment at the Naugatuck waste water
treatment facility, LT-2.
Trucking to an appropriate off-site waste disposal
facility, LT-3.
un-site treatment with green sand and activated carbon
filtration, LT-4. .
On-site treatment with parallel bioreactors, LT-5.
On-site treatment by chemical coagulation and
clarification, and ultraviolet-enhanced oxidation, LT-
6.
LT-l Off-site Treatment at the Beacon Palls Waste Water
Treatment pacilitv
This alternative transfers the leachate from a collection
structure into the Beacon Falls sewer system for treatment at an
upgraded Beacon Falls waste water treatment facility. Installing
0.3 miles of new pipe from the landfill to the sewer system is
required and a central leachate collection structure will be
constructed. Prior to any discharge of leachate into the sewer
system, the sewer pipes would be inspected to insure that they
are in sound condition. Defective portions of the sewer line
would be repaired, replaced, or bypassed as necessary.
The Beacon Falls facility is a 0.5 million gallons per day
activated sludge treatment facility currently operating at about
half of its capacity. The estimated initial leachate flow only
represents approximately nine percent of the facility's total
capacity and is expected to decline dramatically after the first
year following installation of the cap. Treated water from the
Beacon Falls facility is discharged to the Naugatuck River.
An upgrade of the Beacon Falls facility will be necessary to
accommodate the high BOD, metal and VOC levels in the leachate.
The upgrade would include adding oxygen to the air used in the
treatment process, as well as increasing the capacities of the
sludge pumping and dewatering systems. Residual sludge byproduct
from leachate treatment will be consolidated with the facility's
normal sludge production which is incinerated at the Naugatuck
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".
- 21
Presently, the Beacon Falls racility is permitted by the CT DEP
to treat only domestic sewage. Treatment of industrial wastes
will require a permit modification. This permit may require some
degree of leachate pretreatment. A state permit will also be
necessary to discharge the leachate to the Town's sewer system.
In addition, the Town of Beacon Falls would have to consent to
accept the Beacon Heights leachate for treatment and disposal at
the ~eacon Falls facility.
ESTIMATED TIME FOR CONSTRUCTION: 1 year
ESTIMATED TIME FOR OPERATION: 7-~0 years
ESTIMATED CAPITAL COST: $668,000
ESTIMATED OPERATION & MAINTENANCE (Present Worth):
ESTIMATED TOTAL COST (Present WOrth): $1,501,000
(COST DOES NOT INCLUDE PRE1'REATMENT]
$948,000
LT-2 O~f-Site Treatment at ~be .suaatuck Waste Water
Treatment Facilitv
This alternative sends the leachate to the Naugatuck waste water
treatment facility for treatment. A five-mile long pipeline from
the site to a connection point with the Naugatuck sewer system
near the intersection of Cotton Hollow Road and Cross street is
required. The pipeline will lie pri~rily in the rights of way
of Bethany Road, Main street, and Route 8 and will be dedicated
solely to leachate transport from the Site. In addition,
construction of an on-site leachate collection tank of
approximately 5,000 gallon capacity 8S well as a pump station
near the site to pump the leachate to the Naugatuck sewer system
is necessary.
The Naugatuck waste water treatment facility is a 10.5 million
gallons per day activated sludge £acility which is currently
permitted by the CT DEP to treat both domestic and industrial
sewage. Since the Naugatuck facility currently treats
approximately 6.5 million gallons of sewage per day, it has
sufficient remaining capacity to accept the Beacon Heights
Landfill leachate. The facility will incinerate any sludge
remaining after treatment as part of its normal operation.
Treated water from the Naugatuck facility is discharged to the
Naugatuck River. No upgrade of this facility is necessary to
adequately treat the leachate. A state permit will also be
necessary to discharge the leachate to the Town's sewer system.
Pretreatment may also.be required by the State.
. .
The portions of the Naugatuck sewe~ system through which the
leachate would flow are large enough to handle the projected
additional volume. Prior to any discharge of leachate, the sewer
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22
condition. Defective portions of the sewer line would be
repaired, replaced, or bypassed as necessary.
ESTIMATED TIME FOR CONSTRUCTION: 1 year
ESTIMATED TIME FOR OPERATION: 7-10 years
ESTIMATED CAPITAL COST: $1,406,000
ESTIMATED OPERATION & MAINTENANCE (Present Worth):
ESTIMATED TOTAL COST (Present Worth): $2,241,000
[COST DOES NOT INCLUDE PRETREATMENT]
LT-3 Truckina to an Aooropriate Off-site Waste Di8008al
Facilitv
$951,000
In this alternative, leachate is collected and stored in a
leachate storage system to be constructed on-site. The leachate
is then transported to an approved treatment, storage, and
disposal facility licensed to treat hazardous wastes. Leachate
would be transported in 5,000 gallon tanker trucks by a licensed
waste hauler.
A total of approximately 4,700 round trips will be required to
dispose of the estimated volume of leachate over a ten-year
period (the length of time that leachate is expected to be .
produced within the landfill after capping). Eight round trips
per day are expected during the first year of operation: over two
round trips per day during the second year: and one round trip
per day during the fifth year declining to two trips per week at
the end of ten years.
ESTIMATED TIME FOR CONSTRUCTION: 2 months
ESTIMATED TIME FOR OPERATION: 7-10 years
ESTIMATED CAPITAL COST: $147,000
ESTIMATED OPERATION &
MAINTENANCE (Present Worth): $5,927,000
ESTIMATED TOTAL COST (Present Worth): $5,354,000
LT-4 On-site Treatment with Green Sand and Activated carbon
Filtration
This alternative treats leachate on-site using a combination of
three treatment processes: (1) granular activated carbon
filtration, (2) .green sand filtration, and (3) chemical
disinfection. .
The leachate is pumped from a collection basin through a green
sand filter to reduce iron and manganese levels. The filtered
leachate is then pumped through a granular activated carbon
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".
- 23
disinfection,. both before and after each process, will control
fouling of the filters by microorganisms and will remove cyanide.
The treated and disinfected water will then be discharged to the
Hockanum Brook.
These filtration processes will produce a waste sludge which may
or may not be hazardous. This sludge will be tested and, if
found to be hazardous, will be trucked to a licensed RCRA
disposal facility. Non-hazardous sludge will likewise be trucked
to an appropriate off-site disposal area.
A state National Pollutant Discharge Elimination System (NPDES)
perait is required for discharge to the Hockanum Brook.
ESTIMATED TIME FOR CONSTRUC'l'ION: 1 year
ES~IMATED TIME FOR OPERATION: 7-10 years
ESTIMATED CAPITAL COST: $522,000
ESTIMATED OPERATION &
MAINTENANCE (Present Worth): $1,248,000
.
ESTIMATED TOTAL COST (Present Worth): $1,618,000
.
Does not include cost of trucking hazardous sludge to
facility.
aRCRA
LT-5 On-site Treatment with Parallel Bioreactor8
This alternative requires constructing an on-site facility
consisting primarily of a pair of parallel bioreactors, green
sand filters, and disinfection equipment. The bioreactors will
remove VOCs through microorganism action. Green sand filters
remove iron and manganese from the leachate to prevent odors and
reduce discoloration caused by concentrations of those elements.
Sodium sulphate will be used to control barium levels as
necessary. Disinfection will control disease causing organisms.
In operation, the parallel bioreactors would be alternately
filled with leachate. Air would then be bubbled through the
leachate to increase the level of dissolved oxygen, induce
mixing, and promote microorganism growth. The contents would
then be allowed to settle, and the liquid filtrate poured off
through the green sand filters. The filtrate would then be
disinfected and discharged to Hockanum Broo~.
This treatment will produce a waste sludge which mayor may not
be hazardous. This sludge will be tested and trucked to an
appropriate off-site disposal area.
A State National pollutant Discharge Elimination System (NPDES)
permit is required for discharge to the Hockanum Brook.
Additional state permits are also necessary for discharge .of
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. .
".
24
ESTIMATED TIME FOR CONSTRUCTION: 1 year
ESTIMATED TIME FOR OPERATION: 7-10 years
ESTIMATED CAPITAL COST: $663,000
ESTIMATED OPERATION & MAINTENANCE (Present worthJ: $589,000
ESTIMATED TOTAL COST (Present Worth): $1,180,000
-
Does not include cost of trucking hazardous sludge to a RCRA
facility.
.
LT-I on-site Treatment bv Chemtcal Coaaulation an4
Clari~on. an4 Ultraviolet-Enhance4 Oxt4ation
In this alternative leachate is treated in two phases. The first
phase of treatment uses chemicals to cause certain metals and
some organic contaminants to coaqulate and settle out of the
leachate. The remaining liquid is then pumped directly through a
green sand filter to remove iron and manganese.
In the second phase, the resulting filtered water is acidified
and then flows through an ultraviolet-enhanced oxidation cell,
which destroys organic contaminants and high .BOD constituents.
Neutralization of the acid in the filtered water restores a
balanced pH. The treated water is then disinfected and
discharged to Hockanum Brook. Sodium sulphate will be added
during the process to control barium as necessary.
This treatment will produce a waste sludge which mayor may not
be hazardous. This sludge will be tested and trucked to an
appropriate off-site disposal area. .
A State National pollutant Discharge Elimination System (NPDES)
permit is required for discharge to the Hockanum Brook.
Additional state permits are also necessary for discharge of
effluent to the Hockanum Brook.
ESTIMATED TIME FOR CONSTRUCTION: 1 year
ESTIMATED TIME FOR OPERATION: 7-10 years
ESTIMATED CAPITAL COST: $980,000
ESTIMATED OPERATION'
MAINTENANCE (Present Worth): $1,063,000 -
ESTIMATED TOTAL COST (Present Worth): $1,914,000
-Does not include cost of trucking hazardous sludge to a RCRA
facility.
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25
IX.
8UHKARY 01' TD COKPARA'lIVB UALYSIS 01' !.BAeD'll: 'lRBA'l'MENT
aND DISPOSAL AL'lBRHA'lIVBS
section 12l(b) (1) of CERCLA, as amended, presents several factors
that at a minimum EPA is required to consider in its assessment
of alternatives. Building upon these specific statutory
mandates, the National contingency Plan articulates nine
evaluation criteria to be used in .ssessing the individual
remedial alternatives.
The 1985 ROD determined that the three categorical leachate
collection alternatives evaluated in that document were
equivalent in terms of feasibility, protectiveness, and other
factors. However, because the Pre-Design Studies presented a
range of leachate treatment technologies in greater detail than
had been considered in the 1985 ROD, this supplemental ROD will
evaluate those alternatives in accordance with the procedures and
criteria specified in the current NCP.
A detailed analysis was performed on the six alternatives using
the nine evaluation criteria in order to choose the selected
leachate treatment and disposal alternative. These criteria and
their definitions are as follows:
Threshold criteria
-The two threshold criteria described below must be met in
order for the alternatives to be eligible for selection in
accordance with the NCP.
1.
Overall protection of human health and the
environment addresses whether or not an
alternative provides adequate protection and
describes how risks posed through each pathway are
eliminated, reduced or controlled through
treatment, engineering controls, or institutional
controls.
Compliance with applicable or relevant and
appropriate requirements (ARABS) addresses whether
or not an alternative will meet all of the ARARs
of other Federal and state environmental laws
and/or provide grounds for invoking a waiver.
Jijmarv Balane~na cr~
2.
The following five criteria are utilized to compare and
evaluate the elements of one alternative to another that
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3.
4.
s.
26
Long-term effectiveness and permanence addresses
the criteria that are utilized to assess alter~
natives for the long-term effectiveness and
permanence they afford, along with the degree of
certainty that they will prove successful.
Reduction of toxicity, .o~ility, or volume through
treatmeD~ 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.
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 cleanup goals are
achieved.
6.
Implementability addresses the technical and
administrative feasibility of an alternative,
including the availability of materials and
services needed to implement a particular option.
Cost includes estimated capital and Operation
Maintenance (O&M) costs, as well as present-worth
costs.
7.
Modifvina criteria
The modifying criteria are used on the final evaluation of
remedial alternatives generally 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.
community acceptance addresses the public's
general response to the alternatives described in
the Proposed Plan andRI/FS report.
The following section balances the strengths and weaknesses of
the six alternatives under each of the nine criteria set out
above.
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. .
- 27
1.
OVerall Proteotion of Human .ealth and the Bnvironment
Alternatives LT-l, LT-2, LT-J, LT-4 and LT-6 all offer equivalent..
protection of human health and the environment by using reliable
treatment systems which reduce exposure to site contaminants in
the leachate and which attain desired water quality levels.
These technologies include on- and off-site leachate treatment
and disposal.
LT-6 provides the potential achievement of the highest water
quality of all the on-site alternatives to provide protection of
public health and the environment. This efficiency, however, is .
dependent on continuous operator attention and is very sensitive
to variability in leachate quality.
Alternative LT-S, on-site treatment of leachate with parallel
bioreactors, may not be protective of human health and the
environment because bioremediation and filtering will not remove
sufficient amounts of priority pollutant organics from the
leachate to meet state and federal regulations for discharge to
surface waters. ~
Alternatives LT-l, LT-2, and LT-3 all consist of removing the
leachate from the Site either through piping to an off-site waste
water treatment facility or trucking to an off-site treatment,
storage and disposal facility. Removing leachate as it is
generated reduces exposure to site contaminants and attains state
and federal water quality standards. Each of these alternatives
minimizes on-site treatment holding facilities and none produce
on-site by-product waste sludge. .
On-site treatment of leachate, described in LT-4 and LT-6, rely
on chemical coagulation (LT-6) and filtration (LT-4 and LT-6) of
contaminants to attain water quality standards. Although both
generate sludge by-products which require on-site short-term
storage, these technologies effectively remove metals and
priority pollutants from the leachate through a series of
filtration system and are equally as protective as LT-l, LT-2 and
LT-3. The resulting water meets all state and federal levels for
protectiveness. Further, the potential for contact with leachate
at the site is minimized and eventually eliminated as the refuse
dries out under the cap.
2.
Complianoe with Applioableor Relevant and Appropriate
Requirementa (ARARa) .
EPA evaluated each alternative for compliance with ARARs,
including chemical-specific, action-specific and locat~on
specif ic ARARs. Al ternati ves LT-l i LT-2, LT-J ,. LT-4, and LT-6
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"
28
Because bioremediation and ~iltration may not remove sufficient
amounts of priority pollutant organics in the effluent to be
discharged to Hockanum Brook, alternative LT-5 may not meet the
Connecticut Water Quality standards established for this Class
B/A surface water. Because this alternative may not be
protective of human health and the environment and because it
will not attain ARARs, it will not be carried through the
remaining criteria comparisons.
3.
.
LoDg-~.rm Bffec~iv.De.. an4 Permanence
The risk remaining from untreated leachate at the Site decreases'
as the refuse under the cap dries out and will be essentially
reduced to the maximum extent possible once the amount of
leachate generated diminishes to negligible amounts. Because all
alternatives will remove leachate from the Site, the long-term
effectiveness of each is therefore measured by a variety of
factors such as the type of technology used.
LT-l achieves the greatest degree of long-term effectiveness and
permanence when compared to LT-3, LT-4 and LT-6, and only
slightly more long-term effectiveness and permanence than LT-2.
Both LT-l and LT-2 provide long-term effectiveness by relying on:
(a) an established treatment system: (b) a waste water treatment
facility which is already in operation and capable of handling
industrial sewage: and (c) sophisticated facility personnel and
technology. LT-l, however, requires installing a 0.3 mile
pipeline for leachate transfer while LT-2 requires a 5 mile
pipeline. While cracking or deterioration of the pipes for
either LT-l or LT-2 is remote, the probability for pipe
replacement or repair is greater in LT-2 than LT-l as is the
potential for contamination of a wider area due to leakage given
the greater length of the pipe in LT-2.
Several modifications to the Beacon Falls facility are necessary
to effectively treat the leachate. Once Beacon Falls is
upgraded, both the Beacon Falls and Naugatuck facilities will
require only normal maintenance.
LT-3 on the other hand, provides less long-term effectiveness
than either LT-l or LT-2 since it is dependent on maintaining a
fleet of trucks to transport the leachate to a treatment, ,
storage, and disposal facility, (TSDF). The potential exists
during off-site trucking of leachate for adverse weather '
conditions to impede or stall truck transportation. In contrast,
adverse weather conditions will have minimal effect on piping
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29
brand new and transport will be underqround. Additionally,
, overflow, spillage, or leakage from the leachate holding tank in
LT-3 may occur, causing recontamination of clean areas around the ,:
landfill. .
While all of the alternatives rely on a leachate collection
structure and a leachate transfer system, LT-3 requires direct
transfer of leachate from the structure to the trucks through a
valve hookup. This transfer raises the possibility of Site
recontamination from uncontrolled discharge during coupling and
uncoupling of the transfer system.' In contrast, LT-l, LT-2, LT-
4 and LT-6 employ a closed leachate transfer system directly from
the collection structure to the treatment facility which
minimizes the chance of uncontrolled discharges.
LT-4 and LT-~ provide less long-term effectiveness and permanence
in that they require more maintenance and part replacements than
LT-l and LT-2. Both LT-4 and LT-6 require various types of
filtration; therefore, replacement filters will be necessary from
time to time. LT-l and LT-2 require construction of much simpler
facilities and do not require an additional work force, Unlike
LT-4 and LT-6, since both the Beacon Falls facility and the
Naugatuck facility already exist and are operational.
While LT-4, on-site leachate treatment using carbon absorption,
uses treatment processes which have been employed historically
with a high degree of reliability, it requires regular service to
regenerate the carbon beds which play an integral role in the
leachate treatment process.
LT-6, on-site leachate treatment using chemical coagulation and
clarification, employs a relatively new technology with a history
of some operations and maintenance difficulties and has an
extremely high electrical consumption. It has a high potential
for periodic process upsets and discharge of non-compliant
effluent from the facility without ongoing operator attention.
While this alternative has the potential to achieve the highest
water quality of all the on-site treatment alternatives, ,
treatment efficiency is very sensitive to operator attention and
to maintaining optimum water clarity, iron removal and solution
ph. Because treatment efficiency is heavily dependent on
maintenance, LT-6 provides the least amount .of long-term
effectiveness. .
4.
Re4uctioD of ~oxicity, MObility, or Volume ~brougb,
, ~r.atmeDt
Each of the alternatives will reduce , the mobility and volume of
leachate at the site because (1) all alternatives requ~re
collection and treatment of all but negligible amounts of
leachate generated by the landfill and (2) the 'volume of leachate
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30
approximately 10 years as the landfill dries out after capping. .
Additionally, all of the collected leachate will be treated
irreversibly to levels which eliminate the toxicity of the
leachate in all of the alternatives.
Since each alternative removes all but a negligible amount of the
leachate from the Site, contact and ingestion will be minimized
as will further deqradation of surface and groundwater. LT-4 and
LT-6 employ filtration systems on-site which remove VOCs, metals
and BODs from the leachate. LT-l, LT-2 and LT-3 transport
leachate off-site to a waste water"treatment facility which also
removes contaminants from the leachate. Whether the effluent is
discharged on-site to the Hockanum Brook (LT-4 and LT-6) or off-
site to the Naugatuck River (LT-l and LT-2), all NPDES permit
levels for discharge to a surface water will be met.
In addition, all of the alternatives may produce a certain amount
of residual sludge througb the leachate treatment process.
Sludge produced during treatment at the waste water treatment
facilities in LT-l and LT-2 will be incinerated at the Naugatuck
waste water treatment facility as part of the present ongoing
operations. Any sludge produced as a result of leachate
treatment associated with LT-3 will be treated or disposed as
part of the normal wastewater treatment process at whichever
treatment, storage, and disposal facility is selected for the
alternative.
For both on-site treatment alternatives, LT-4 and LT-6, the
residual sludge generated by the filtration processes will be
stored on-site pending periodic transport to an appropriate
treatment and disposal facility.
Therefore, each of the alternatives will reduce the toxicity,
mobility, and volume of contaminants through their respective
treatment processes.
5.
Short-Term Effectiveness
LT-l provides the greatest degree of short-term effectiveness of
all alternatives evaluated mainly because of the limited amount
of time and construction necessary to begin leachate treatment.
LT-2 provides a higher degree of short-term ~ffectiveness when
compared with alternatives LT-3, LT-4 and LT-6 mainly to its ease
of implementability and limited environmental impact risk.
Some dust and noise will be generated during construction of the
collection structur~ and pipe installation for both LT-l and LT-
2, causing some risk to the community from noise and dust. This
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31
the sewer line is only 0.3 miles away from the site. The
disturbance will be slightly longer with LT-2 since the closest
sewer line connection point for the Naugatuck facility is 5 miles
from the Si~e. .:
.
LT-4 and LT-6 will produce some air emissions from the ~reatment
processes. While these emissions will be con~rolled with best
available ~echnolo9Y, the facili~ies will be operating for an
expected 10 year period and must be constantly monitored. LT-3
will ~r~at.A the greatest amount of air emissions from the ~rucks
as they run ~heir estimated 4,632 round trips ~o and from the
Site.
LT-1 offers the briefest duration of communi~y disruption.
Although normal ~raffic patterns will be al~ered while ins~alling
both the 0.3 mile pipeline for ~-1 and the 5 mile pipeline for
LT-2, the time for installing the 0.3 mile pipe is shorter. As
soon as the pipe is in the ground, leachate can be pumped off-
site with no further communi~y disruption.
This is, however, overshadowed by the fact that the Beacon Falls
facility must be upgraded prior to being able to accept~the
leachate for treatment. ~he potential for spills and other
upsets during early operations exists until al~ startup problems
are worked out and the facility is completely operational.
Alternatively, the Naugatuck facili~y is curren~ly operational
and is already successfully treating contamina~ed leachate from
another Superfund Si~e.
In comparison ~o LT-1 and LT-2, LT-3 requires ~rucking of
leachate ~o an appropria~e TSDF in 5,000 gallon ~anker trucks.
Trucking leacha~e off-site is an ongoing process requiring use of
area roads every day for ten years. The number of round trips
per day (8 during the first year) on steep residential roads near
the site will increase air emissions and traffic in the area
considerably and will expose the community to hazards which EPA
considers unacceptable, at least in the early stages of this
alternative. However, as leachate production diminishes, truck
traffic is expected to diminish as well. .
With regard ~o LT-4 and LT-6, although best available controls
technology (BACT) will be used in constructing the facilities,
operations will generate air emissions which may be harmful to
the community. In addition, LT-4 and LT-6 will require heavy
construction equipment to travel to and from the site each day
for a period of approximately one year during construction of the
treatment facility.. Alternatively, once the pipelines in LT-l
and LT-2 are installed, noise and air pollution will be minimal.
Finally, risk to the community from exposure ~o the leachate is
less in LT-1 than in LT-2 or LT-3. The possibility of leakage
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" .
32
pipe than from a 5 mile pipe. Any leak would presumably be
detected much more quickly in the shorter pipe. Leaks in a 5
mile pipe could potentially affect a large number of residential
areas. Likewise, accidents and resulting spills from the trucks
carrying leachate and sludge in LT-3 could potentially affect a
wide range of residential areas.
Risk to workers in all of the alternatives will be controlled
with safe working practices. LT-4 and LT-6 may expose workers to
potent-ietl ~missions from the on-site treatment facilities.
Again, BACT will be implemented: h6wever, operations will
continue for approximately 10 years. With alternatives LT-1 and
LT-2 the possibility, although remote, does exist for accidental
discharge of and worker contact with leachate from any spills or
cracks in the pipe. Concentrations of volatile organic compounds
at the plant should be low due to the dilution of the leachate in
the sewage. Therefore, any risk to treatment plant workers from
inhalation of volatile organic compounds are expected to be
minimal if the plant is in compliance with OSHA ventilation
standards. The potential for contact with the leachate is high
in LT-3, especially in the first year since 5,000 gallon trucks
must be loaded with leachate 8 times per day.
..
As with worker exposure to leachate from pipeline cracks or
spills from trucks, the environment may also suffer from such
occurrences although the probability of pipeline leaks is small
since they will be newly installed and the sewer lines will be
thoroughly inspected before leachate is sent through them and
will be subject to regular inspection and maintenance.
All of the alternatives will also be the source air emissions for
varying amounts of time as explained above.
I.
xmplementability
All of the alternatives can be implemented to varying degrees
except LT-1. Some alternatives are technically easier to
implement than others based on their design and complexity.
LT-2 is the easiest to implement technically since it will use an
existing waste water treatment facility which has been
successfully treating residential and industrial waste water for
a number of years as well as leachate from the nearby Laurel
Park, Inc. Superfund site since January, 1990. owners and
operators, including the Borough of Naugatuck, have consented to
accept "the Beacon Heights Landfill leachate under specific
contractual terms and conaitions. .
The Town of Beacon Falls was not able to agree to conditions
under which it would accept the leachate for treatment'at its
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-.
33
LT-l is not implementable. EPA, therefore, cannot select it even
though it ranks highly in all selection criteria except
implementability.
piping materials necessary for LT-2 are readily available and
construction methods are conventional. LT-2 provides for a
pretreatment unit if necessary and the facility is already set up
to monitor the effectiveness of pretreatment and treatment.
LT-3, trucking of leachate to a treatment, storage and disposal
f~~i'ity (TSDF), although not physically difficult to implement,
requires long-term management of trucking and hauling schedules.
Additional trucks and on-site storage facilities can be added if
necessary, however, trucking the leachate off-site requires 8
round trips per day for the first year on steep residential
roads. Adding additional trucks would only increase the burden
of traffic on and hazards to the surrounding community and would
most likely require additional planning and oversight by local
agencies.
LT-4 and LT-6 are the most difficult to implement since they
require constructing on-site treatment facilities. Each may also
require an off-site disposal service for treatment of any
residuals produced as a result of leachate treatment. Additional
unit treatment processes can be added to these facilities if
necessary to treat the leachate to appropriate standards.
Administratively, LT-2 will require a state permit from the CT
DEP, for discharge to the sanitary sewer. Landowner approval has
been obtained from the one private landowner affected by the
proposed pipeline alignment for LT-2. The remaining pipeline
will be constructed in public rights of way. In addition to
consent from the Town of Beacon Falls, modification of the
current NPDES permits may also be required from the CT DEP for
LT-l. However, the administrative feasibility of securing
permits for either LT-l or LT-2 may be more easily achieved than
obtaining an on-site surface water discharge permit for
alternatives LT-4 and LT-6 since the state of Connecticut has
expressed some reservation about discharging treated effluent
into the Hockanum Brook. For LT-3, EPA must approve any TSDF
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. .
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34
7.
Cost
summary of Estimated Treatment Alternatives Costs
(In Thousands of Dollars)
Alternative Capital 0&1( .et Present Worth
.
Beacon Falls Facility 668 948 1,501
,.~ .)
,.....-.
.
Nauqatuck Facility 1,406 951 2.'241
(LT-2)
Truckinq 147 5,927 5,354
(LT-3)
. - 522 1,248 1,618
On-S1te II
(LT-4)
-
On-site III 980 1,063 1,914..
(LT-6)
.
Does not include pretreatment cost, if pretreatment is
necessary.
-
Does not include the cost of truckinq hazardous sludqe to a
RCRA facility if necessary.
8.
state Acceptance
The Connecticut Department of Environmental Protection has been
involved with the site from the beqinninq as summarized in
section II of this document "SITE HISTORY AND ENFORCEMENT
ACTIVITIES". The CT DEP has reviewed this document and concurs
with the selected alternative, LT-2, for leachate treatment and
disposal as documented in the attached Declaration of
Concurrence.
..
community Acceptance
The comments received durinq the public comment period and the
discussions durinq the Proposed Plan and FS public meetinq are
summarized in the attached document entitled "The Responsiveness
. Summary" (Appendix C). varied comments were re~eived from. .
residents livinq near the Site, representatives from the Town of
Beacon Falls and The Borouqh of Nauqatuck, and from the BHGC.
One citizen desires the EPA to avoid choosinq LT-2: another
citizen suqqested that treatinq the leachate on-site would
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35
are generally opposed to LT-ll the BHGC generally wants the EPA
to choose LT-21 and the Borough of Naugatuck commented that they
will accept leachate from Beacon Heights assuming certain
conditions are met. .
x.
'1'HB SELECTED ALTERNATIVE J'OR LEACHATB TREA'l'KBN'l' AND DISPOSAL
LT-2, off-site treatment and disposal of leachate at the
Naugatuck waste water facility, is the selected manner and
location for leachate treatment and disposal. This selection
along with the soil excavation cri~eria and landfill gas vent
pollution control decision completes the selected remedy for the
site.
The selections in this supplemental ROD and the 1985 ROD
constitute both the source control and management of migration
components for the site.
A.
Leachate Treatment and Disposal Cleanup Levels
The decision to treat/dispose of leachate from the site was made
in the 1985 ROD. No cleanup levels for leachate were set at the
site since all but negligible amounts of leachate will be removed
from the Site and treated at the Naugatuck facility. The treated
effluent will meet all requirements of the NPDES permit
requirements prior to discharge to the Naugatuck River.
B.
Leachate Treatment Components
One of the objectives of the 1985 ROD is to minimize the
migration of contaminants via groundwater and surface water
runoff. Therefore, part of the remedy required by that ROD is to
install a central leachate collection structure and a new
subsurface transfer pipeline located at the base of the ridge,
northwest of the property. Leachate would be pumped through a
new 5 mile pipeline connected to the existing sewer line at the
intersection of Androsko Drive and Cross Street. The leachate
will then travel through the sewer line and discharge to the
N~ugatuck waste water treatment facility.
Discharge of the leachate to the Naugatuck facility must comply
with the National Pretreatment Program of the Clean Water Act and
will require a state permit for discharge to the sewer line.
"Characteristics of sewer line segments include: (1) A 24 inch
. reinforced concrete sanitary sewer line in the vicinity of "
Androsko Drive and Cross Streetl (2) At the intersection of Cross
street and the Route B entrance/exit ramp, the pipe becomes 30-
inch-diameter'reinforced concrete pipe: (3) The pipeline.
continues along the entrance ramp for northbound Route 8 for
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" ..
36
underneath the Naugatuck River through a 36-inch-diameter
prestressed concrete cylinder pipeline: (5) The pipeline then
travels approximately 150 feet south where it discharges to the
Naugatuck facility. The entire pipeline system will require
further examination as part of the final leachate system desiqn.
If certain seqments are found to be structurally deficient, the
seqments would be repaired, replaced, or bypassed.
The Naugatuck facility is currently permitted by CT DEP to treat
both domestic and industrial sewage and does not require
upqrading to accept the Beacon Heights Landfill leachate. It has
the capacity to treat 10.5 million-gallons of sewage per day:
currently, only 6.5 million gallons per day are treated. The
Naugatuck facility, therefore, has sufficient capacity to accept
the Beacon Heights Landfill leachate for treatment. The
additional amount of sludge produced during the course of
leachate treatment will be incinerated at the facility as part of
its normal operations.
..
Additional analytical data will be developed for the leachate for
the design of pretreatment facilities if required by the state
permit and other authorities. This data may include the impact
of high concentrations of ammonia on the operation of tke
facility, the inhibition of nitrogen uptake from high ferrous
iron concentrations contained in the leachate, and a sewer system
inflow analysis to eliminate surges in waste water flows
apparently "related to rainfall events. In addition, DEP will
review the adequacy of leachate quality. A state permit for
discharge to the sanitary sewer is also required.
XI.
DETERMINATION OF CONTAMINANT LEVELS FOR SOIL BXCAVATION
The 1985 ROD determined that contaminated soils in certain
"satellite" areas outside the areas that were not practicable to
cap would be excavated and consolidated with the wastes in the
main landfill, to be covered by the main cap. The 1985 ROD
determined that the selected remedy, including, such excavation
and consolidation, would be protective of public health, welfare
and the environment and would be cost effective.
Cleanup levels have been established for contaminants of concern
in soil contiquous ~ the area of the landfill deemed
impracticable to cap, found to pose an unacceptable risk to
either public health, welfare or the environment. 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 non-carcinogenic effects was used to s~t cleanup
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37
not feasible tO,qUantifY, the practical quantification limit was
used as the cleanup level. 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 ia not found to be protective,
further action shall be required.
A.
8011 CleaDup Level.
In the 1985 ROD a qualitative baseline risk assessment was
performed; however, no quantitative cleanup levels for soils were
established. The 1985 ROD reserved that determination for a
later decision document. . Therefore, EPA has established cleanup
levels for soils in this supplemental ROD 1n order to protect
both human health and the aquifer below the Beacon Heights
Landfill site frOD further potential contamination. Levels
protective of human health from contamination due to dermal
contact and ingestion of soils were based on EPA cancer potency
factors. In addition, two leaching models based on contaminant
mobility were used to predict soil contaminant levels deemed
protective of the aquifer. Because the cleanup levels for
aquifer protection from soil leachate are .ore stringent than the
levels for ingestion and dermal contact with soils, the aquifer
protection levels are used for contaminant levels for soil
excavation. By employing the more stringent aquifer protection
contaminant levels, both protection of human health from dermal
contact and ingestion and protection of the aquifer will be
achieved.
Compared values from both the Summers Model and the Designated
Level Method were used to estimate residual soil levels that are
not expected to impair future groundwater quality. ARARs in
groundwater (MCLs) were used as input into the leaching models.
In the absence of an ARAR, the level corresponding to a 10.6 risk
level (for carcinogens), a hazard index of (1) (for
noncarcinogenic effects), or a proposed federal MCL was utilized
as the point of departure. The hazard index is calculated by
dividing the exposure level by the reference dose (RfD) or other
suitable benchmark for noncarcinogenic health effects. Reference
doses have been developed by EPA to protect sensitive individuals
over the course of a lifetime and they reflect a daily exposure
level that is likely to be without an appreciable risk of an
adverse health effect. The lower of the two model values was
chosen as the cleanup level unless these values were below
analyte detection limits. If the values described above were not
capable of being detected or were below regional background
, values, then the current practical quantitation limit was
substituted.' '
Based on this analysis, EPA developed the soil cleanup levels for
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. 38
soil cleanup values for .the contaminants of concern developed to
protect public health and the aquifer.
To ascertain that those areas which undergo excavation achieve
the soil cleanup levels specified in this supplemental ROD,
confirmatory sampling will occur once excavation is completed
within and along the perimeters of all excavated areas. This
sampling will be conducted to statistically determine whether a
particular excavated area has achieved the soil cleanup levels or
requires further excavation.
"
'lABLB 81 80%L CLEAJroP LEVELS POR '.rHB CARCINOGENJC CON'l'AMINAN'l'S .
BASED ON 'lRE SUMMERS MODEL AND ~RE DESIGNATED LEVEL MODEL~'
AND ASSOCIATED RISKS 'lO GROUNDWATER
CarciDogeDic 80il Basi. for Residual
cODtamiDaDt8 CleaDup Hodel GrouDdwater
of CODCerD Level (mg/kg) %DPUt (ug/l) Risk
Benzene 0.08 58 4.1*10.6
Bis(2-chloroetbyl)ether 0.330 PQLc 3.0*10-5
1,2 Dichloroethane 0.01 58 1.3*10-5
Trichloroethene 0.10 58 1.6*10-6
Vinyl Chloride 0.02 28 1.3*10-4
Bis(2-ethylhexyl) 0.30 3b 1.0*10.6
phthalate
Methylene Chloride 0.01 58 1.1*10-6
1,1 Dichloroethene 0.09 ,8 1.2*10-4
,
b
Maximum contaminant Level (MCL) established under the Safe
Drinking Water Act
Excess carcinogenic risk level of 1 * 10-6 assuming
consumption of 2 liters water per day. '
.
c
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39
'1'ABLB 'I SOIL CLEANUP LEVELS POR '!'BE NON-CARCINOGENIC QON'l'AMINANTS
BASED ON '!'BZ SUMMERS MODEL AND ~BB DESIGNATED LEVEL MODEL.
AND ASSOCIATED RXSKS '1'0 GROUNDWATER
lIon- 80il '1'arge~ Residual
carcinogenic cleanup Basia ror BD4poiD~ Hazard
contaminan~. Level Model of Index
of Concern (Jiq/kg) (uq/l) Tozici~y
Chlorobenzene 10 100. . liver and 0.1
kidney
Ethyl Benzene 70 700. liver and 0.2
Jticlney
Toluene 100 2,000. CNS 0.2
Xylene 500 10,000. none obs. 0.1
Bis(2- 3b increased
ethylhexyl) 0.3 liver wt. 0:'01
phthalate
Acetone 10 3, sooc liver and .
kidney 1
2-Butanone 10 1,7S0c feto- 1
toxicity
1,1 0.09 7. liver .02
Dichloroethene lesion
4-Methyl 2- 10 1,7S0c liver and 1
Pentanone kidney
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. .
. .
. .
40
.
Safe Drinking Water Act--Haximum contaminant .Level
(MCLGs)
Excess carcinogenic Risk Level of 1*10.' assuming'
consumption of 2 liters of water per day
Reference Dose (RfD)
Goals
b
c
~~A set these cleanup levels for soils in order to achieve ARARs
in groundwater at the conclusion of the remedial action. These
soil levels will be protective of public health ris~s posed by
direct contact or incidental ingestion of the 80ils at the
conclusion of the remedial action.
B.
80i1 Excavation components
In accordance with the 1985 ROD, contaminated soils will be
excavated and consolidated within the main landfill. These soils
may be used in recontouring the landfill surface in preparation
for landfill capping. Soil cleanup levels determine the quantity
of contaminated soils to be excavated. All areas of the Site
will either be capped, excavated to the top of bedrock, or
excavated to soils containing levels of chemical constituents
compatible with the soil cleanup goals set by EPA.
The 1985 ROD determined that the selected remedy, consisting (in
part) of capping, and excavation and consolidation of
contaminated soils in certain satellite areas, was cost effective
and provided adequate protection of public health, welfare, and
the environment. The cost estimates that formed the basis for
the cost effectiveness determination in the 1985 ROD assumed the
highest cost of capping and excavation (i.e., the largest cap and
largest expected excavation).
Establishing the soil cleanup goals was reserved for a later
decision document in the 1985 ROD. These soil cleanup goa18
establish the minimum levels to which soils must be excavated to
meet ARARs and to be protective of human health and the
environment. In setting the soil cleanup levels in this
document, EPA has used MCLs and proposed MCLs as inputs to the
Summers .odel groundwater equation in order to set specific
cleanup levels tbat are protective of human health and the
environment and comply with current ARARs. . .
The BHGC utilized the Designated Level Bethod Model to establish
soil cleanup levels~ EPA preferred the use of the Summers Model.
Except for one contaminant, levels set in the Designated Level
Method model were unacceptable since some of the varia~les in the
equation are nationwide averages and are not site specific as
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41
contaminant was. retained based on information from similar sites
within the Region. The levels in the Designated Level Method
model may not meet ARARs and Day not be protective.
At the other end of the spectrum are the Connecticut Action
Levels which are more stringent than the levels in the Summers
model. However, these Action Levels were not chosen for soil
cleanup goa18 because they are not ARARs.
Because the soil cleanup goals set the minimum volume of soil
necessary for excavation, this determination constitutes a
.component of a remedy determined to be cost effective as
envisioned in the 1985 ROD.
XII. DETE~~TION FOR AIR POLLUTION CONTROLS ON LANDFILL GAS
VENTS
The 1985 ROD determined that a gas venting system was necessary
to prevent the buildup of gases under the cap, but reserved until
a later decision document a determination whether air pollution
controls were required on the venting systems.
A.
50 Air POllutioD COD~ro18 Ar8 588484
until an impermeable cap has been installed on the landfill,
there is no acceptable way of assessing volume and concentrations
of gas generated at the Site. This is due to the fact that gas
emanates from diffuse locations over the entire surface of the
landfill and is therefore impracticable to capture. Once this
cap is in place, and gas can be routed to and vented at predicted
locations, an appropriate monitoring program which properly
characterizes emission volumes and concentrations, can be
implemented. If any federal or state ARARS or hazard risk ranges
are exceeded, treatability studies will be performed.
Once the cap is in place, if EPA determines that treatment is
necessary, it will consider an array of treatment technologies.
These technologies include carbon adsorption, incineration,
flaring, air stripping or other innovative or state-of-the-art
technology designed to treat air emissions. Protection of human
health and the environment will be achieved through continued
monitoring and the application of best available control
technology or lowest achievable emission rate, whichever is most
appropriate according to Connecticut's Air Pollution Control
Regulations.
Due to changing conditions as the landfill ages, properties and
concentrations of landfill gasses may change over time.
continued monitoring may indicate that a different technology
than initially selected would be more protective given a change
in landfill gas properties and concentrations. Theref6re, while
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42
pollution controls on the landfill gas vents, it necessary,
remains unaltered.- The.performance levels specified in the ROD
will be met by any new technology implemented.
B.
cODtiDue4 KODitoriDq
since it is impracticable to collect and treat air emissions from
the uncapped landfill, continued monitoring of the gas produced
within the landfill after capping will be provided. Prior to
capping, some perimeter monitoring will occur. The vents will be
constructed in such a way as to facilitate the addition of
pollution control devices should the continual monitoring reveal
levels of air contaminants exceeding the Federal National Ambient
Air Quality standards (NAAQS), state MASC, Odor Threshold Levels,
Hazard Limiting Values, fall outside the 10.' to 10.' cancer risk
range, or exceed a hazard index of 1. The remedy will therefore
be protective of human health and the environment once it is
completed.
As part of the monitoring activities, the following may be
required but not limited to:
1.
2.
3.
4.
5.
XIII.
On-site meteorological station:
Sampling at the landfill gas vents, at the landfill
perimeter, and at other removed sampling stations to
determine amounts and concentrations of hazardous
landfill gas emissions to differentiate landfill source
contribution from background levels of contamination:
Approved EPA sampling and analysis techniques suitable
for quantitative risk evaluation:
Approved Quality Assurance/Quality Control Plan:
6.
Sampling shall begin upon cap installation and continue
through remedy completion. Samples will be conducted
on a time weighted average basis to be determined
during design phase.
Emission and/or dispersion modelling..
1'1J'1'1JRB ACTIONS
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 upon completion or fails to meet the
cleanup levels established in this Record of Decision, further
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43
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 to assure' that the remedial action continues to protect
human health and the environment. EPA will also evaluate any
risks posed by the site at the completion of the remedial action ,:
(i.e., before the site is proposed for deletion from the NPL). '
XIV. STATUTOay DBTERKIHATIOBS
The selected alternative for leachate treatment and disposal is
consistent with CERCLA and, to the "extent practicable, the NCP.
This remedial action along with the soil cleanup levels is
protective of human health and the environment and attains ARARs.
The total remedy for this site which includes the selected
alternative for leachate treatment and disposal and the
determinations made in this supplemental ROD as well as the
remedial actions chosen in the 1985 ROD, is cost effective.
Additionally, the selected alternative for leachate treatment and
disposal satisfies the statutory preference for treatment which
permanently and significantly reduces the mobility, toxicity or
volume of hazardous substances as a principal element and
utilizes treatment technoloqies to the maximum extent.
practicable.
A.
The Reme4ial Actions specifie4 in this Supplemental ROD
are Protective of Human Health an4 the Bnvironment
The, remedial actions selected in this supplemental ROD and the
1985 ROD will permanently reduce the risks posed to human health
and the environment by eliminatinq, reducinq or controllinq
exposures to human and environmental receptors through treatment
and engineering controls.
Since it is impracticable to collect and treat qas at the
uncapped landfill, no air pollution controls will be installed on
the landfill qas vents prior to cappinq. Monitoring after
cappinq will provide information to allow EPA to determine
whether or not controls are necessary in order to be protective.
If controls are necessary, the chosen technology will be
protective.
The selected alternative for leachate treatment and disposal will
result in human exposure levels to qroundwater that comply with
ARARs and that are protective of public health. The selected
le~chatecollection a~d ,treatment alternative will siqnificantly
reduce the risks of contaminant inqestion and dermal contact as
well' aspreventinq furthe~ deqradation of the local qroundwater,
stream, and river systems.
Soils from areas contiquous to the main landfill will be
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44
prevent further degradation of the groundwater and expedite
restoration of the aquifer. When contaminant levels reach the
soils target cleanup levels, the risks from direct contact to and
incidental ingestion of soils will be reduced to a level
protective of human health. .
Moreover, the soil cleanup remedy specified in this supplemental
ROD will result in human exposure levels through dermal contact
and ingestion of soils that will be within the 10.' to 10.'
incremental cancer risk range and that are within the hazard
index of one (1) for noncarcinogens at the completion of the
remedy. .
~h8 Re.e4ial Actions specifi84 in thi8 8upple.ental ROD
Attain ARAb
The remedial actions specified in this supplemental ROD will
attain all applicable or relevant and appropriate federal and
state requirements that apply to the Site. Environmental laws
fro. which ARARs for these remedial actions are derived, and the
specific ARARs include:
B.
Safe Drinking Water Act - Maximum contaminant Levels (SOWA)
Clean Water Act (CWA)'
Clean Air Act (CAA)'
occupational Safety and Health Standards (OSHA)
OSHA Recordkeeping, Reporting and Related Regulations
OSHA General Industry Standards
Federal Pretreatment Requirements for Discharge to Publicly Owned
Treatment Works
Connecticut Water Discharge Permit Regulations
Connecticut Air Pollution Control Regulations
Connecticut Water Quality Standards and Classification
Connecticut Public Health Code-Standards for Quality of Public
Drinking Water (Sec. 19-13-B102)
'NPDES permitting is delegated to the State of Connecticut
as are the National Ambient Air Quality standards.
To Be considered
Clean Water Act--Sewage.Exclusion (40 CFR section 261.4(a) (1»
. A discussion of why these requirements are applicable or relevant
and appropriate may be found in the Pre-Design Studies Report at
pages. 13-23. The specific requirements and their citations can.
be found in Table 1 of the Pre-Design Studies Report which is
appended to this ROD. Any changes to applicability or
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45
The remedial actions in this supplemental ROD involve off-site
treatment and disposal of leachate, determining the extent of
80il excavation and determining the appropriateness of installing
pOllution controls on landfill gas vents. During all
construction and operation activities, OSHA requirements are .
applicable and will be met. .
Leachate Treatment and DisDosal
section 22a-430 of the Connecticut General statues as Amended
(RCSA) (state Permit for Discharges to "Waters of the Staten) is
applicable to the Site since leachate will be discharged to the
Beacon Falls sewer system. Leachate will be pretreated to
acceptable levels prior to discharge as required by the permit.
Even though untreated leachate meets the established categorical
pretreatment standards of Section 22a-430-4 for metals and
cyanide, this section is considered applicable.
Federal Pretreatment Requirements for Discharge to Publicly owned
Treatment Work$ (POTW), 40 CFR 403, are applicable to the
discharge of leachate from the sanitary sewerage system to the
Naugatuck facility. These requirements apply to the introduction
of all non-domestic waste water into a POTW. This includes
prohibited discharge standards, categorical discharge standards,
and local limits. These pretreatment requirements will be met if
necessary.
Naugatuck facility does not have a RCRA treatment, storage and
dispQsal facility permit. While the leachate at the site has not
yet been classified as hazardous, the domestic Sewage Exclusion
(40 CFR section 261.4(a) (1» provides that a hazardous waste,
when mixed with domestic sewage, is no longer considered a
hazardous waste. Therefore, even if the leachate is a RCRA
hazardous waste, it may be mixed with domestic sewage and sent to
the Naugatuck facility.
The state of Connecticut has been authorized by EPA to administer
and enforce the NPDES provisions of the Clean Water Act. The
state regulations are at least equivalent to federal regulations.
NPDES provisions are applicable to the site since treated
effluent will be discharged to the Naugatuck River. The
Naugatuck facility, which already has a NPDES permit, will be
reviewed by CT DEP to ensure that its current NPDES permit
requirements are met, along with any other limiting requirements
of CT DEP based on that agency's review of the leachate quality.
. The Naugatuck River is currently classified as Class C/B surface
water according to Connecticut Water Quality standards and
Classification, RCSA 22a-426. The treated effluent discharged
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46
Design studies and will not impair the state's objective of
improving the quality of" the Naugatuck River nor will it affect
the Naugatuck facility's ability to comply with its permit. "
50il Excavation
~
The groundwater in the aquifer beneath the landfill is
contaminated by leachate from the landfill and surrounding soils.
An alternate public water supply was brought into the area in
1987. However, eight residences continue to use the aquifer as a
drinking water source. 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 as a standard to be
used in setting soil cleanup levels.
Connecticut's Water Quality Standards establish designated uses
and classifications for surface water and groundwater and are
applicable to the aquifer and to any discharges to the Naugatuck
River. The soil cleanup levels were set using MCLs as ihput in
order to prevent further degradation of the groundwater.
Effluent discharged to the Naugatuck River will comply with all
permit requirements.
~
Connecticut's Public Health Code--Standards for Quality of Public
Drinking Water (Sec. 19-13-B102) establishes water quality
standards for water supplies. This requirement is relevant and
appropriate to setting the soil cleanup goals to prevent further
degradation to groundwater since the aquifer is a potential
source of public drinking water.
Connecticut Action Levels were useful in helping to determine
soil cleanup goals which would be protective. However, because
these action levels are not promulgated as required by
1121(d)(2)(A)(ii) of CERCLA, they are not ARARs.
Because this supplemental ROD determines only levels of
contaminants in the soils which will be protective of human
health and the environment, Resource Conservation and Recovery
Act (RCRA) regulations are not considered ARARs for this
selection. Likewise, Land Disposal Restrictions (LDRs)
provisions of RCRA do not apply. "
Air Pollution Controls on Landfill "Gas Vents
The State of Connecticut has been authorized by EPA to administer
and enforce the National Ambient Air Quality Standards.(NAAQS)
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standards, the state haspromulg~ted the Connecticut Air
Pollution Control Requlations.
The NMQS, which specify maximum primary and secondary ~4 hour
concentrations for particulate matter, are applicable because the
landfill gas emissions are discharged from a stationary source:
that is, the landfill gas vents. 'l'hese vents will be desiqned to
accommodate pollution controls should continued monitoring reveal
emissions in excess of the NMQS or MABCs. In addition, fugitive
dust emissions from Site activities will be controlled by water
and other dust suppressants.
Hazard Limiting Values (HLVs), which are used to calculated the
MASC value, are considered to be relevant and appropriate with
respect to allowable contaminant concentrations in air beyond the
site boundary. Future monitoring wi1l determine if conditions
beyond the compliance boundary comply with HLVs.
RCSA section 22a-174-23, Control of Odors, establishes odor
threshold limits for individual constituents at the Site
boundary. Continuous monitoring will reveal the presence of
levels above threshold limits.
If necessary to install air pollution controls on the gas vents,
emissions will comply with all other chemical, location, and
action specific ARARs.
C.
~he .e.e4ial Action i. Cost-Effective
In the Agency's judgment, the selected alternative for leachate
collection and treatment is cost effective, i.e., the alternative
affords overall effectiveness proportional to its costs. In
selecting this alternative, once EPA identified alternatives that
are protective of human health and the environment and that
attain, or, as appropriate, waive ARARs, EPA evaluated the
overall effectiveness of each alternative by assessing the
relevant three criteria--Iong term effectiveness and permanence:
reduction in toxicity, mobility, and volume through treatment:
and short term effectiveness in combination. The relationship of
the overall effectiveness of this alternative was determined to
be proportional to its costs. 'l'he costs of the remedial
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48
summary of Estimated Leachate ~reatm.nt Alternatives Costs
(In ~hOU8&Dd8 of DOllar.)
Alternative capital 0'. .et Present Worth
Beacon Falls Facility. 668 948 1,501
(LT-1)
~
.
Naugatuck Facility 1,406 951 2.241
(LT-2)
Trucking 147 5,927 5,354
(LT-3)
..
On-site II 522 1,248 1,618
(LT-4)
..
On-Site III 980 1,063 1,914
(LT-6)
.Does not include pretreatment cost, if pretreatment is
necessary.
..
Does not include the cost of trucking hazardous sludge to a
RCRA facility if necessary.
Of those alternatives that are protective, attain ARARs and are
implementable, LT-2 is the most cost-effective alternative
evaluated. LT-2 provides the greatest degree of protectiveness
proportionate to its costs. Treating and disposing of leachate
at the Naugatuck facility, although slightly more costly than
treatment and disposal via LT-4 or LT-6, it provides greater
long- and short-term effectiveness, is easily implementable and
is acceptable to the state of Connecticut and the SHGC. LT-S,
although less expensive, did not meet ARARs since bioremediation
and filtering would not remove sufficient priority pollutant'
organics to .eet state and federal requirements. LT-3 does not
offer a proportionate degree of protectiveness or long or short-
term effectiveness for its cost. Had LT-l met the
implementability requirement, it would have been considered the
most cost effective alternative evaluated.
LT-4 and LT-6, both on-site treatment alternatives with cost
estimates under $2 million, do not provide the same degree of
protectiveness as LT-2 for the costs of these alternatives. The
long-term effectiveness of LT-6 is n~t as reliable as other
alternatives given its operation and maintenance diffi~ulties.
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49
o'f waste by creating on-site residual sludge from the treatment
pr~cess which must be stored, treated,and disposed. Both
alternatives are difficult to implement in that they require a
'permit to discharge to the Hockanum Brook which the state has
expressed reluctance to grant. .
with respect to the determination of soil cleanup levels, the
1985 ROD examined the question of cost effectiveness of the
selected remedial action, of which excavation and consolidation
of contaminated soils in satellite areas was a significant
component. The 1985 ROD found the selected remedy to be cost
effective. Based on the soil cleanup goals determined in this
document and the corresponding volume of soil necessary to
excavate to meet these goals which are deemed to be protective,
the total selected remedy still remains cost effective.
with respect to air pollution controls on the landfill gas vents,
no controls ,will be required unless monitoring indicates that any
standard or requirement is not being met or that conditions at
the site pose a threat to human health or the environment after
capping. It is not necessary to make a determination as to the
cost effectiveness of air pollution controls at this time.
Should controls become necessary, cost-effective controls will be
chosen.
~he Selecte4 Alternative for Leachate Treatment an4
Disposal an4 the Determination for Air Pollution
controls utilize Permanent Solutions an4 Alternative
Treatment Technologies or .esource Recovery
Technologies to the xaximum Extent practicable
The general decision to collect and treat leachate was made in
the 1985 ROD. The requirements of section 121 of CERCIA, as
amended, were not in effect at that time and were therefore not
applicable to the remedial decisions made in the 1985 ROD.
This supplemental ROD is to determine the specific manner and
location of treatment and disposal of the collected leachate.
This selection of leachate treatment and disposal is consistent
with section 121 of CERCIA, as amended, and the NCP to the extent
practicable. Treatment of the leachate at the Naugatuck
facility, when compared to the other leachate treatment
alternatives considered in this supplemental ROD, utilizes a
permanent solution to the maximum extent practicable.
D.
Once the Agency identified those alternatives that attain or, as
appropriate, waive ARARs and that are protective of human health
and the environment, EPA identified which alternatives utilize
solutions and alternative treatment technologies or resource'
recovery technologies to the maxim~ extent practicable. This
determination was made by deciding which one of the identified'
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50
alternatives in terms of: 1) long-term effectiveness and
permanence; 2) ~eduction of toxicity, mObility or volume through
treatment; 3) short-term effectiveness: 4)implementability; and.
5) cost. The balancing test emDhasized long-term effectiveness
and permanence and the reduction of toxicity, mobility and volum~
through treatment: and considered the preference for treatment as
a principal element, the bias against off-site land disposal of
untreated waste, and community and state acceptance. The selected
alternative provides the best balance of trade-offs among the
alternatives.
LT-1 would have provided the best C::ombination of systems among
the leachate treatment alternatives reviewed for effectively and
permanently reducing the toxicity, mobility, and volume of
leachate at the Site. Although there are similarities between
LT-1 and LT-2 in that they both make use of existing treatment
facilities and the sludge produced by either treatment process
will be handled through the normal course of facility operations,
the Beacon Falls alternative requires construction of only a 0.3
mile pipeline for leachate transport. The Naugatuck facility
requires construction of a 5 mile pipeline for transport. In
addition, the cost associated with implementing the Beacon Falls
alternative versus that associated with the Naugatuck a~ternative
is projected to be less for the same result. However, since LT-
1 is not implementable, LT-2 is the next best solution based upon
a comparison with the other alternatives and, therefore, becomes
the selected alternative for leachate treatment and disposal at
the site.
LT-2, in contrast to LT-4 and LT-6 which involve filtration
processes, does not produce on-site residual sludge nor does it
have the potential for recontamination of the site as does LT-3
which involves trucking leachate off-site. Moreover, LT-2 has
fewer adverse short term effects in terms of the least disruption
on the surrounding community than LT-3, LT-4 and LT-6. LT-4 and
LT-6 require constructing facilities on-site which must operate
for a minimum of 10 years. These two alternatives add another
source of air emissions to the community. LT-3 requires 5,000
gallon trucks to make approximately 4,700 round trips to and from
the site through a residential neighborhood with steep streets
over a span of 10 years.
With respect to air pollution controls on the landfill gas vents,
no controls will be required unless monitoring indicates that any
standard or requirement is not being met or that conditions at
the site pose a threat to human health or the environment after
capping. If controls are required, they will utilize permanent
solutions and alternative treatment technologies or resource
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51
~b. ....4ial Ac~ion. 8.1.c~.4 in ~bi. 8uppl...n~al ROD
8a~i.fy ~b. Pr.fer.nc. for ~r..tmen~ Whicb
8i9DificaD~ly ae4uce. ~be ~ozici~y, Kobili~y or Volume
of ~b. ....r4ou. 8ub.~aDc.. a. a principal .1..en~
The requirements of section 121 ofCERCLA, as amended, were not
in effect at the time of the 1985 ROD and were therefore not
applicable to the remedial decisions made in the 1985 ROD,
including the general decision to collect and treat leachate, and
the decision to excavate and consolidate contaminated soils in
the satellite areas. Nonetheless, "the 1985 ROD selected a remedy
that included collection and treatment of leachate as a principal
element. With respect to the selection of a specific treatment
location and method from among the six alternatives presented in
the Pre-Design studies report, all involve treatment that
significantly reduces the toxicity, mObility or volume of the
hazardous substances as a principal element.
B.
With respect to the determination whether or not to require air
pollution controls on the landfill gas vents, because it is not
practicable to collect and treat air emissions at the Site prior
to capping, no controls will be installed. Should monitoring
indicate that any standard or requirement is not being met or
that conditions at the site pose a threat to human health or the
environment after capping, such controls will be installe?
xv. DOCUHENTATION 01' SIGNII'ICANT CHANGES
EPA presented a Proposed Plan (preferred alternative) for
remediation of the Site on May 9, 1990. The management of
migration portion of the preferred alternative includes (1)
pumping leachate collected on-site through a new pipeline to the
Naugatuck sewer system then to the Naugatuck waste water
treatment facility: (2) excavation of soil with contamination
levels above EPA allowable levels for consolidation with the main
landfill prior to capping: and (3) monitoring of gas vented from
the landfill after capping.
To clarify any potential misunderstanding regarding capping or
excavating of the area formerly known as Betkoski's Dump, the
northernmost portion of Betkoski's Dump, which is not cost
efficient to cap, will be excavated to the soil levels set in
this supplemental ROD while the more southerly end will be
covered by the landfill cap.
Also, this supplemental ROD did not carry forward the no-action
alternative presente~ in the Proposed Plan. The scope of this
supplemental ROD was limited to activities which completed the
remedy outlined in the 1985 ROD. Since the 1985 ROD determined
-------
.
. .
52
to selecting an alternative which most appropriately satisfied
the nine criteria. for the manner and location of leachate
treatment and disposal. No action was, therefore, not an
alternative for this determination.
XVI. STATB ROLE
The Connecticut Department of Environmental Protection has
reviewed the various alternatives and has indicated its support
for the selected alternative for leachate treatment and disposal
and for the determination for poll~tion controls on the landfill
gas vents.
The state has a180 reviewed the Pre-Design studies to determine
if the selected alternative for leachate treatment and disposal
and the determinations for air pollution controls and soil
cleanup levels are in compliance with applicable or relevant and
appropriate state environmental laws and regulations. The CT DEP
agrees that the remedial actions for leachate treatment and
disposal and for pollution controls on the landfill gas vents in
this supplemental ROD are in compliance with all promulgated
ARARs.
The Connecticut DEP concurs with the selected alternative for
leachate treatment and disposal and with the determination for
air pollution controls, but does not concur with the soil
remediation levels. A copy of the declaration of
concurrence/non-concurrence is attached as Appendix D to this
-------
FIGURE
1
'02).0 , ' .- . " ' - , .4 '.
o 'N,,' ~/i'~~~,~~~\~~~.,;t~~,;r."':~ . ;.,...: . ',' :~~~:,~?'::;~~~{&'..i'.k{~¥;:: :f~~':~~~/:F{:~::,~,~..,.:,:,:'..~~~,}::
U) '. .' ~ ~-:-::""'~:.~~!';,\,,~~ \"J~'t...:'J'''''':",~ ...~;;~ ',"'"iJ . ';.t~~m'~r'Jf';,"~~,..~"tPo..... "1' ,";' "'}':)I;!t.~""':':~:';~''''.i;':'!,'
.., ,.! ,,' "
I";' ". ", ":-~.~..~,,,,~..~:..t.,. ...~,.,.~ -. "l'~ i V'!;"..'/, ::,...,.1"":;A ,!". -j .t." .-H~ry.:!.,.~ ' \ :
~ '::': .~~ ",' ~ ',';" ~~~~,:~\~,~~!f\;;Z~j\:.':ti;~T"'i:~.."I,?, ~,:\~/~;'<>r-'\T",'.f,,:'~'1'/:.. '~':~f~,~et~~~"'",~':;'/
- , " ' ,.", V, ~~" ~:~"'" ",~+w..}, ' (V.Io"."~. ~,~,,~:,' "~',;,:-,~., ,,.{c"" .,..;.-:." " ;;il.-, "".' '"
I "', ,'\,,:,,'" ~1-};:':::';;::....~~"~V;:.'''"Z\'I.~~- :, ~i '''~l"':;: ~.,{(/) .~' !.'..'-r-: . J<~>,' '~::,:~;r,'~'~.;';'\"I,~,:
10 "', ':-.,,~, 1i", '\ "-~.~~~:;<"'''"f! ,I ;~,. " : 'J'; .'",'~ N-J..::,f':"", :;/.;:::.'\ ~ :;,;, ...:, ..~.,~",~,:';i',i~,
CD .:: : >;."'~~;, \: ' \ ~~,~~~~\;~; ,:,W-;"f:~~: F"r ~~, \~ ~ ,,;.:;~pt:~":,:'<",;~,J :::\ :.~'~'.;:YA: ;:'f\l'.~ ..~~/
I-' CI: ' " ' '.. , ' ,- ., , - i'~" " ... N' 'ii"-' ,h '...,-., 'Jo);' ., " ~ ' "- ,,,,' A'" ,., ", -. . '.. "
~ i '~[. .:;, , "";:, {?>~, ,:~,"'~", ,.<. .~}~~,':.~'.~,~~.~~~~r,~.'lb/,:'~~ 1 ~~'.t,:,';;'~.:,~~.'~,~.:~~:~.',.;..,...,~~~.~~~"'i.~\,':~"}J:,r.-.!.it,f;i~'{C~~~....,:..
o Z ,'.: ' "." ,!$'" . ,""NA'O'AtuCK,-,: .t;. ~'-;'" ~. "':. """:'-r~~~"':' '. ''''J~''''''.:J.''' ,} '. r', "-....,.,"
.'" '-' !.:::.~... ':::.::~....\.&~':' \. -l'.\:'.~:. ,'.' '1;~~w~,~,.,:.:~.:,; ..",;: . :~.~~~ ;.~'i...~"..:. 'v r,,':'<-~;:;.~~'~"":'~.:.{f~:: ..~::'";-~:,.,,-_...~..~~.
" ~. -j', ~1. - ..~" ~ .;., ~~' .. '" rT. "y~,- r ." .,:'. ~, ~(.,;.,;,o<, ..,-,~" . '(...:_: :~... "~, \.. ( ~.~ " "".-.b ;:.:r'''.
. ..;." ~,..'" :'-'''...''':'' .~.~.,~.~~~ \'i :;. . ~.I '~'. -."'.. ~~-: :,- ... ~,:.~ ~:'.' ,).:.;.~.~ ~-:~'..~~';:~~~~"~~",\(.::
~ ,~~..\ :",:\"'\'~r..' ( \ . .-118 fE'£: -,~! ,'~"',~k,,,..;.,' .._;".."~~~,.L~;f.',,,,,;,,,:,,.to ...,
~ ~'~ ;~~i~~~\;i;i';~~)0~J~':~'~ ~;~;!t~~~i;~~Z~fli~~~!J.sI
~'\ ,......-.t. : ,.{, , ,,,,,,,,,,f', ,~ ,.....~,. .~!,: "', POT£NTIAL.:,.-",." P.i;:::i"'~-~:~~/.'~" ,..,4t...
. ~:-'~:~:i',~: l;~,,~~.,~>~,,~','._;..""'...I:'.:';~j~t,.,.. ~""~,1: ,',,..'PJSCHARG£-TO' ,;~~ir-7-~s.:;~:"":~U~~
~ ~ ' L..:,',...,-'~.~ /~ -{. .:,'" ''\; «-'. "'~-' l' ~ 'i~""'7.~-": ~ i- ,~.. 'NAUGATUCK:~AtJITA~L~NE.~' ;;"'~~ "-,,=t,/;
; 0....". ',. '.;.". .~.~... ~~.. '\0;" r.'-. ~ ~.: . -:~.'.. .~~. --".. .,. -.".". ,~w.,.", ,.;~.''''''.'':'- . ~-~~~}:":'
ID 0 ,. ,. ,;fi~'t* J-te;;~~r.:n.....*i"F'\,'.;'"., '" '~.'''~' ..''''.:' ;.1/.,"~ "'-::..:::\':1''f';:,':-';'T. ':'''''', ".''';;'::;'':''';''~''/f,::,
o ~ ;:~ .:" ,~: ~/: ~;' .. ~"=-;.... .~~,r-,~:~.~~~: " ::-;..;~/_":;:-':.,/ '/' ;.':.,- :' ",,,:,, ~~i~""';"'''~'''-:~s",~~'}:;;:;'''t~',
~ 0:', ~..,-~':, -,:' ~', ' ~",':\. '",::~} . ,: ~j;i',}Z'~'/. ')$~:' il ':...;, .~ "-' ; ~ ,~.,,~,,:o, . '-,' ',' ,'>:t' , ..~, ~ 't"". #-., , f
~ i ~):>." ".> ;--«';;<'=; ~~~~:; ,~':~~~' '~''Ji~~~..(~',~~~~,t:'~..'~'' ,:" ,~',~-:":.)- :' '.;":: r:'(~~'::"~~~~:j.! (;
U C( ...": " '. -,': ,-:,,'':'" ...,~.:,.,~'-' "'?ii-=: ,...,.:1<'; '.:,'t'.kTJ> ,,'IH:Lb'I.,.,', :, ,,:,; ~',"-i.';?, -: '.
G\:: }~'~, ~'~::T~~<-,:~,::~t,r:,- :'~'~:,';i:- i:gj~;.r{;. ;'~.~":\,',',<,..~_...;...,"":,..':~L:...,:: ",~<~:~;~-:'J;~'(- ;~>~,,~,~:'
:i CD "'1' 0j.,~ 'I ; '".'! j ,::;.:., ;,!¥"~J.i:'-',l~:.d(.~3~\;."~ ~,,,,:,~,,,,,,", ' ;", '''', ..\,rl::"..,.,~i' . " ,,', "'I
.-: cD ~ ,\~"jr/', )t\\'~~,;', ~;:r.'~~'i;';"~~;.t~.t. .,~~:;~,,,.':,~\;:~.,~,: ':,'.,"-".~~~\J ""~. ',f~,/:' if, ';-''''.'1:i:..
:E I '.. :i''''. fl. .' "...-... ; '/'.:".' "." ~fj~''''~~''''~~:''''''''''': ;', o':;'-~ -/". ".1~,. ;,.J,.;':":-, ,r;:'", : ''':''--:::'~,',
C) : ..:.;~ :(':,~, '",'" ;: i){.;: ,~~. ..' "J ',~-=,,~'~1\~,:;r::-:: ~" ',,-- :':..:~:::'~' . \ ,:;, >: 3:'''i:~'' i -~~' ..e;."'"', " .:.,'"
, ',t"j '.. -' :,.~.' ",,: ~~- ,."', ",./.,,,,,,,~,,,.,,,,,,, ,,,O" ',. ~ "-,.,,....: I' ""."..~
; ~,,;.;.' :.. ii..~.. »t',,~i:',t ',.;r ';'-'';'L-:':.''I'!<:~'''': ,:::" "t "~"'''''\ J ',:".ih '.-'~'
z "'" " ~,~; ~,',:>,'~.-.-i.P.:"..:f' :f':::f) . ~,~:~~':~~~~f~;,CL()SEs'f.-\aE;AC:ONI~L~5 ,f!I)T;,#' ..,EW.t.n .,tiNE-: ,: :
: ~ ~:~"~~'~.ir -;; -~>,;~;'G~';'~~~~'(:: \~}~*~!~..~ti1!..j0~'!;";'~~Ol. ~t.~~'8.!i~~~)~~~~~~~9;~~::~~~~f~r~,~"
CO) "'" ,-1''''' -r~'It','f-\.,,'~' i\~:':.ot::~""'-,'-,,,,,,,. .." ",;". ,,,'1'''. "r"'"' .:",,:~r "
, """'~',~~:; . ~.,~,;; ,;; /~.' "', '}'~~:~'f~"t;I 'f;a~' ,:-St- . .', ,'.'
.~y~m~~f~"" r~<; :,.:d'-"-::~R~i~ ~2::::i~" 'b:~(:'~~:"f£R~n..:' ,,'
,,(ELEYATION.: .~),'~ - J" ,l./ ';1'::';' ~:;.;;;',;,:'.: -" " ',',.;'" ,,:..1 ,.., J:,' <. ")Y':' ~l.A,REA.,' ,,"
\;'~!3~. ';.F../.~~~~~'''>:'\:' ':;'~1f:'~;'.'~'~;:;;~E:AC()N;:"'~/'~""I';'l /: -",:,~" ,~; ",' ,~,
"" .' ,:"4'';';'''.' '.,i.:o"..t.t:., ':. . .~,"..':', ."~~~ "":HEIGHTS' L ' I' " :~ " ...
" :. ,.: "~"~_::,\:,':-',f::;..- ;~'''''i!j',,,,,' ~ t:'~NDFI"f'" ,:1 .~ .-:: : ,
"" -' :, --', "i ,': ':' "~#' ,";: ',."" ..,.' - M. w:. L.. ' I' , /' ."" ,. ,
!;"-:-:'~ ~:,: ... "~~ ,..~jL;Xr ,I",;~"~~'.i:, , ; :;.'.'~ ~:>1EL EVATION :, ,:' ., ~'i 'r',,,',". ,".:
, \'t~:t.::-;!/ ~J~ f :{ff.i :"':'j;f;t.650 ~EEI t r '-~'~~ ~J~/>i; ",,'
, '., ' -," J" '/" , . ' , '/" " ':'1, ...., ,
t. . .... ... .. or: . i .'.r:-~";"-_.:. --- -
,(, ,("-'; - \'.' f':, r< "",'.' -~ 3000 P 3000 FEET
LEGEND:
---
PIPELINE ALIGNMENT TO BEACON FALLS
PUBLICLY OWNED TREATMENT WORKS (POTW)
PIPELINE ALIGNMENT TO NAUGATUCK POTW
VICINITY MAP
BEACON HEIGHTS LANDFILL
BEACON FALLS. CONNECT ICUT
NOTE:
I. PIPELINES WILL DISCHARGE INTO EXISTING
MAIN SEWAGE SYSTEM.
REFERENCE:
USGS 7.5 MINUTE SERIES
QUADRANGLE OF NAUGATUCK,
CONNECTICUT, I
DATED: 1964, SCALE: ," =2000,
PHOTOREVISED: 1984.
DATE: 5-6-89
SCALE' AS SHOWN
DRAWING NUMBER
-------
50
E I I I
Q.
~ MAXIMUM ESTIMATED PEAK FLOW 42 GPM
:i
I.AJ 40
....
~
z
0
)- 5
)-a:I UJ
mo ...J
~
o~ 0 AVERAGE ESTIMATED FLOW 20 GPM
16.10 0
{Sa:
&&.14. L.J
5~ ~
:r:
0
L5
oJ
~ 10
~
0
~
0
0 24 48 72 96 120
ElAPSED TIME FOLLOWING CAPFING, MONTHS
,
"'It
an
<
I
I')
I')
-
I
an
co
CIa:
ZIoJ
~m
<::I
a:::;)
oz
, .
FIGURE 3
ESTIMATED LEACHATE PRODUCTION
BEACON HEIGHTS LANDFILL
BEACON FALLS, CONNECT1CUT
DAl[: 5-4-B9
SCAl.£: AS SHOWN
DRAWING NUMBER
-------
l./
./
I ,"'/'
..
0>-
z!
I
;
w
FIGURE 4
J.l.IiUID:
.... ~ l1li' IIIIf\.I
.... "11____.LL
.... --
...... - ..
-. _...~
..... ....... ~
..-. -_..~
---
.'" &UOIIIt: lIP' IIIIfiLI -.......
..... ....- 'III8LL 8Y"'"
tiit\ II.StIIC 8U1IICIOI L'"
............ uur-..."" .
..JQm:.
, ~ 01 KtIIIIC llllllR" ca1C-.D
UP~ .,... ftC ,... ..
......-' ..... -~
.. -. ..- ta'
FIELD EXf'U)RATION LOCATIONS
BEAOJN HEIGHTS L.ANJf"ILL
IIEACO' fAU.S. CONNECTICUT
-------
TABLE 1
SOIL SAMPLE ANALYSES - 8TX AND LEAD (mu/kg)
8U OA-'
............................. (A-6 b b
Analyt. A-1 A.2 A-] A-4 A,-5 A.6 ouplleete) A-7 A.8 A.9 A,.10 A-11
.... ....... ......... .......... ........ ........ ........ ........ ........ ........ .......... ......... ........ ........ ........ ........
8~zene NO 0.025 lID 0.025 NO 0.025 NO 0.025 110 0.025 ND 0.025 . NO 0.025 lID 0.025 lID 0.125 0.26 lID 0.025 lID 0.125
Ethyl 8enzene NO 0.025 NO 0.025 NT NT lit NT NT NT lID 0.125 II' lID 0.025 lID 0.125
Toluene lID 0.025 NO 0.025 NO 0.025 110 0.025 110 0.025 lID 0.025 lID 0.025 NO 0.025 lID 0.125 lID 0.025 lID 0.025 lID 0.125
Xylene lID 0.025 NO 0.025 lID 0.025 NO 0.025 110 0.025 lID 0.025 NO 0.025 lID 0.025 NO O. '25 0.20 lID 0.025 NO 0.125
Leed lID 5.0 40 45 25 6.8 8.0 25 27 32 16 20 19
. a
Halogenated Volatile Organic.
.............................
Analy'.
. Chi orobenzene
Trlchlorofluor08eth808
1,1-0lchioroeth8Ol
I, "Olchloroethene
liT
liT
liT
liT
liT
NT
liT
liT
0.052
NO
NO
ND
0.027
NO
lID
lID
NO
0.280
3.7
110
lID N'
110 N'
lID N'
0.047 N'
N'
N'
N'
N'
0.550 2.4
lID lID
lID lID
lID lID
N'
II'
N'
II'
lID
lID
lID
NO
.............................
Notes:
T. ND. Not detected at indicated concentration.
2. NT. Not tested.
a
Halogenated Volatile Organic result. were Identified only by review of benzene, toluene, ethyl benzene. and Aylene analytical data for additional
constituents.
b
-------
TABLE 1
(Cant. )
SOIL $AMPLE AIIALYSES - VOLATILE AND SERIVOL'TILE GaGAMIC COMPOUNDS (88Ik8)
vo'aci'. Or8anic. concenuac ion Sealvol.c'Ie Orlanic. concencraclon
.......................... ................. Detection ............................. ..................... Daceel ion
IPA I2C.O A-a ,-11 Li-ic IPA 1270 A-a A-n Li.h
.......................... ....... ......... ............................. ......... ......... .........
t.t.t-Trich,oroechane 810 NO O. tZS '.2.c.-Irichlorobenlen8 810 lID 0.310
t.t.2.2-1etrach,oroeth8n8 NO NO O. tZS t.2-0ichlor~ena lID 110 0.310
t.t.Z-Irichioroeth8n8 lID liD O. tZS t.S-Oichlorobe~ene 810 810 0.330
t.t'Oiehloroethane NO MO O. t2S '.C.,Oichioroben,ene 110 lID 0.330
t.t-Oichloroethene MO MO 0.1ZS 2'MethI'~tha'ene liD lID 0.S30
1.1-0ichlorobenlen8 110 MO 0.11S 2.C.,6- ric lorophenol liD 810 0.330
t.2-0ichloroethane MO NO 0.12S 2,C.,Oichiorophenoi 110 110 0.330
t.2-0ichlor~~ liD NO O.US 2,C.'Oi8eth~enoi liD 110 0.330
t.S-Oleh'or ,ena 110 110 O. t2S 2,c.-Oinitr enol 110 MO 1.700
t.C.-Oich'oroben'ene 110 110 O.US 2,C.-Oinitrotoluena liD 110 0.330
tMl-Dichlor08Ch8A8 (local) liD 110 0.1ZS 2,6-0initrotoluena 110 110 0.330
2-Ch'or08Chyl vlny' .Cher 810 lID 0.2S0 2-Chloronaphtha,ene 810 110 0.330
len,ene MO liD O. t2S 2-CMo~enoi 110 810 0.330
Ir08OdichlorG88Chane 110 liD O. tZS 2-lIhr enol 810 lID 0.330
Ir08O'or. 110 NO O. tZS S,S'.Oich'orobenlidine 110 lID 0.330
I rC*IMt hane 810 110 O.ZSO c..6-0initro-2-Methylphenol 110 NO '.700
Carbon lecrachtori. 810 110 0.12S C..lrQ8OPhenyl-phenylether NO 110 o.:no
Chi oroben.en8 O_SSG NO 0.1ZS 4-Ch'or~enY'-phenylether NO NO 0.330
Chlor08thane 810 NO O.ZSO c.'Ch'oro-3-Methyiphenol 110 NO 0.330
Chtoro'or. 810 110 o. tZS "-II it rophenol liD 110 1.700
Chlor_thane liD 110 O.lSO 'eenaphthene liD 110 0.330
Ci'-t.S-Oichloropr~ liD 110 O. tlS Acenaphthylene liD 810 0.330
oichiorodi'luor-t ana MO NO 0.12S Anthracene 110 810 0.330
Oibr08OChlor088chant 810 110 o. tZS lenl idine 110 810 0.330
Ith~1 len..,. liD 110 O. t2S Ben.o (.) pyrene liD liD 0.330
Met vlena Chloride liD 110 O. tZS Ben'o (b) f uoranthene MO 810 0.330
letrachlorOl,hene liD 110 O. t2S BeRlO (~\h,i) Perylene 110 810 0.330
10luene liD 110 0.12S Benlo (Iuorenthena 110 NO 0.330
Ir~,-1.J,-dichloropropene 110 MO 0.12S 8eRlO~a)Anthr.cene NO 810 0.330
1 rtchlotoethene 810 110 O.US bit ( -Chlor08thvl) Eth.r 110 110 0.330
Irichlorotluor088thane 810 110 0.12S bi. (2-ChiOroi$~~~') Eth.r 110 110 0.330
vinv' Chlortde 810 110 0.2S0 bia (2-Ethylhe.~) thal.C. 0.'S80 110 0.330
.~Iena ClotaU MO 110 O. t2S bia (2-Chlor08t oav) Methane lID 110 0.330
8utvlbeRlylphth.lat. 110 110 0.330
Chry,ene 110 MO 0.330
Oibanlo (a, h) Anthracene ..0 110 0.330
Oieth~l~t .'ate liD 110 0.330
Oi8rt v Phthal.t. 110 110 0.330
Oi-II.Huty'phth.I.t. NO 110 0.330
Oi-..OCt~I phthalete 110 810 0.330
Huonnt ene 110 110 0.330
fluorene 110 110 0.330
Heaachlorobcn'en8 110 110 0.310
Heaachlorobut8diene 110 110 0.310
"ea.chIOrocVclopentadiene 110 810 0.310
IndenO (t.2,S-cd) pyrene NO 110 0.130
h=orone 110 810 0.330
IIi th.lene 110 810 0.330
.i uobenleRe 110 810 0.330
....itrosodiphenyl..ine 110 110 0.330
1I-liitroSooOi-pr:fYl..ine 110 110 0.330
Pent.ch'oropheno MO 810 \.700
Phenenthrene 110 NO 0.330
Phenol 110 110 0.330
pyrene 110 110 O.uO
--
-------
TABLE 2
aJIIUISCII OF PU-DESIGII_SM'f' ,nSICAL ,AUlETtaS
- .ISCEU,AIIEQJS AllALnES VITI "101 MAL'f'IES
fOl.LEACKATE/GIauMD WATEa
ANlyte
.................................
Alt8Unity total
(.. c.ca:s), 88/l
Cyanide, 88/l
(.Itrate, ..,1>
(ErdoSUl ten, 881\)
Sulfate, IIIII/l
tot.l Dinolwd Sol ids, 88/1
Specific Conductivity,
""'05/ CII
pM (ltd. ",iU)
.lolOfleal Oa)'ie'\ DeMnd
OI",ic.' OIt'fge" Oell8nd, 8IIiI/l
toul Or,enie Carbon, ,,/l
(Chlorinated Olbentofurens, "8/l)
tetra
'enu
leu
118I)ta
Oct.
(Oiben1o'P~Dioltlns, "8/l:)
Octa
... of Yater Concentration
.-...............................................
..-dial
IfW8SU..tlon
I81pU"I
,'"
Pre-Deslen
~lt"l
'981- 1989
...................
.
....................
250
- 1.400
1.210
- 2.1SO
0.C1Z3 .
0_90 -
0.030
7.9
0.57
9.7
0.019 .
0.23
2.7
1.7 ",
1 ,400 . 3,690
2,550 . 5,500
6.7 7.'
'" 990
3Slo . ',630
70 7'0
115
. 4.600
6. " .
41
9.63
660
1
. 1.555
0.07. 2.2
0.67. 6.9
3.0 160
9.7 ~ . 1.300 ~
" 690
6
lotes:
1. (). ANlyte "as not tested for 4Irlng pre-desi", UllPltng pha.e.
-------
o
RESPONSIVENESS SUMMARY
BEACON HEIGHTS LANDFILL SUPERFUND SITE
BEACON FALLS, CONNEC'.rICUT
SEPTEMBER 28, 1990
U.S. ENVIRONMENTAL PROTECTION AGENCY
-------
BEACON HEIGHTS LANDFILL SUPERFUND SITE
RESPONSIVENESS SUMMARY
TABLE OF CONTENTS
PREFACE. . . . . . . . . .
. . . . . . . .
. . . . . . . . .
I.
OVERVIEW OF REMEDIAL ALTERNATIVES CONSIDERED IN THE
PRE-DESIGN STUDIES, INCLUDING THE PREFERRED ALTERNATIVE
SITE HISTORY AND BACKGROUND ON COMMUNITY INVOLVEMENT AND
II.
CONCERNS. . . . . . . . . . . . . . . . . . .
. . . . .
III. SUMMARY OF COMMENTS RECEIVED DURING THE PUBLIC
COMMENT PERIOD AND EPA RESPONSES. . . . . . .
. . . . .
Part I - citizen Comments. . . . . . . . . . . . . .. 7
A. Comments Regarding Treatment at the Beacon Falls Waste
Water Treatment Facility. . . . . . . . . . . . .. 7
B. Comments Regarding Treatment at the Naugatuck Waste
Water Treatment Facility. . . . . . . . . . . . . . . .
C. Comments Regarding On-site Leachate Treatment. . .
D. General Comments. . . . . . . . . . . '. . . . . . .
Part II - Potentially Responsible Party Comments. . . . 13
ATTACHMENT A -COMMUNITY RELATIONS ACTIVITIES CONDUCTED AT THE
BEACON HEIGHTS LANDFILL SUPERFUND SITE
ATTACHMENT B - TRANSCRIPT OF THE MAY 30, 1990 INFORMAL PUBLIC
HEARING
Page
1
3
5
7
9
11
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Preface
The U. S. Environmental Protection Agency (EPA) held a 60-
day public comment period from May 10, 1990 to July 9, 1990 to
provide an opportunity for interested parties to comment on the
draft Pre-Design Studies and the May 1990 Proposed Plan. prepared
for the Beacon Heights Landfill Superfund site in Beacon Falls,
Connecticut. The draft Pre-Design Studies examine and evaluate
various options, called remedial alternatives, to address
treatment and disposal of leachate generated at the Beacon
Heights Landfill. The Pre-Design Studies also examined and
evaluated contaminant levels for soils to be excavated and
consolidated into the main landfill before capping as well as the
need for air pollution controls on landfill gas vents. EPA
identified its preferred alternative for addressing leachate
contamination in the Proposed Plan issued on May 8, 1990, before
the start of the public comment period. EPA extended the 30-day
public comment period (May 10, 1990 to June 8, 1990) originally
scheduled for this site in response to a request from the public
for a 30-day extension.
In 1985, EPA signed a Record of Decision (ROD) that
determined a series of remedial actions at the Site to protect
public health and the environment. These actions included:
connection of homes surrounding the Site to the Beacon Falls
municipal water supply: construction of an impermeable cap over
the landfill, excavation of contaminated soil outside the area to
be capped and consolidation of those soils within the main
landfill area: installation of gas vents in the cap: and,
treatment of leachate. The 1985 ROD called for additional
studies to determine the extent to which the soils would be
excavated, the manner and location for treatment and disposal of
leachate and the need for air pollution controls on the landfill
gas vents. A 1987 Consent Decree between EPA and 32 potentially
Responsible Parties (PRPs) required that the PRPs, among other
actions, conduct the cleanup and perform the pre-design studies
necessary to evaluate leachate treatment options and the soil and
air pollution controls determinations.
The purpose of this Responsiveness Summary is to document
EPA responses to the questions and comments raised during the
public comment period on the Pre-Design Studies and the Proposed
Plan. EPA will consider all of these questions and comments
before making its final selection of a leachate treatment and
disposal alternative or its final determinations on contaminant
levels for soil excavation or the need for air pollution controls
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This Responsiveness Summary is organized into the following
sections:
I.
overview of Leachate Treatment and DisDosal Alternatives.
Includina the Preferred Alternative. and the Determinations
for the Extent of Soil Excavation and the Need for Air
Pollution Controls on Landfill Gas Vents Considered in the
Pre-Desian Studies - This section briefly outlines the
leachate treatment and disposal alternatives evaluated in
the Pre-Design Studies and the Proposed Plan, including
EPA's preferred alternative.
Backaround on Community Involvement and Concerns - This
section provides a brief history of community interest and
concerns regarding the Beacon Falls Landfill site.
III. Summarv of Comments Received Durina the Public Comment
Period and EPA ReSDonses - This section summarizes and
provides EPA responses to the oral and written comments
received from state and local authorities, the public and
PRPs during the public comment period. In Part I, the
comments received from citizens and state and local
government authorities are organized by subject. In Part
II, the comments received from the PRPs and EPA's responses
are addressed. .
II.
IV.
.
Remainina Concerns - This section describes issues that may
continue to be of concern to the community during the design
.and implementation of EPA's selected remedy for the Beacon
Falls Landfill site. EPA will address these concerns during
the Remedial Design and Remedial Action (RD/RA) phase of the
cleanup process.
In addition, two attachments are included in this
Responsiveness Summary. Attachment A provides a list of the
community relations activities that EPA has conducted to date at
the Beacon Falls Landfill Site. Attachment B contains a copy of
the transcript from the informal public hearing held on May 30,
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. 3
OVERVIEW OP LEACHATE TREATKEN'r AND DISPOSAL ALTERNATIVES,
AND THE DETERMINATIONS POR THE EXTEN'r OP SOIL EXCAVATION AND
THE NEED POR AIR POLLUTION CON'rROLS ON LANDFILL GAS VEN'rS
CONSIDERED IN ~HE PRE-DESIGN STUDIES
I.
As directed in the 1985 ROD, leachate treatment and disposal
alternatives which treated leachate either on or off-site were
developed in the Pre-Design studies. In addition, modeling for
the contaminant levels to which soils must be excavated and the
amount of air pollution generated by the landfill were included
in the studies. Based on the results of the Pre-Design studies,
EPA issued a supplemental ROD. The decisions made by EPA in the
supplemental ROD are an integral part of the remedy. documented in
the 1985 ROD and will address the following principal threats to
human health and the environment posed by the site:
o
.
y.
.
Off-site migration of contaminants via leachate.
Prevention of future groundwater degradation.
.
Future ingestion and direct contact with contaminated
soils and solid wastes adjacent to the main landfill.
Inhalation of potentially harmful gas produced within
the landfill.
EPA screened and evaluated several potential leachate
treatment alternatives for the Beacon Heights Landfill site.
Additional information on each of the alternatives can be found
in the supplemental ROD, copies of which are located in the
Beacon Falls Town Clerk's Office in the Beacon Falls Town Hall,
10 Maple Avenue, and the EPA Records Center'at 90 Canal street in
Boston, Massachusetts. The leachate treatment alternatives are
described briefly below.
.
Off-Site Treatment at the Nauaatuck Waste Water
Treatment Facilitv. This alternative would treat
leachate off-site at the Naugatuck, Connecticut
wastewater treatment facility. Implementing this
alternative would require construction of a five-mile
long pipeline to the Naugatuck sewer system which
discharges to the Naugatuck facility. The Naugatuck
facility is currently permitted to treat industrial
sewage and has the hydraulic capacity to accept the
leachate from the Beacon Heights site.
In the proposed Plan issued prior to the
period, EPA recommended this alternative
preferred remedy for addressing leachate
at the site.
public comment
as its
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.
Off-site Treatment at ~he Beacon Falls Wastewater
Treatment Facili~y. This alternative would treat
leachate off-site at the Beacon Falls wastewater
treatment facility. Implementing this altern~tive
would require construction of a 0.3 mile pipeline to
the Beacon Falls sewer system which discharges to the
Beacon Falls facility, upgrading of the facility, and
consent from governing authorities of the facility to
accept the leachate.
On-site Treatment with G~een Sand and Activated Carbon
Filtration. In this alternative an on-site treatment
facility would be constructed which would utilize a
combination of green sand filtration to reduce iron and
manganese levels, and carbon filtration to remove
organic contaminants and reduce BOD levels. Chemical
disinfection would control disease causing organisms.
Treated leachate would be discharged to Hockanum Brook.
~
.
.
Truckina to an Off-site DisDosal Facilitv. In this
alternative, leachate in a collection structure would
be transported off-site in five-thousand gallon tanker
trucks to an appropriate waste ~reatment facility.
On-Site Treatment with Parallel Bioreactors. This
alternative would utilize microorganisms in an on-site
treatment plant to remove VOCs ~rom leachate. Green
sand filtration would be used to remove manganese and
iron, while chemical disinfection would control disease
causing organisms.
.
.
On-site Treatment bv Che~ica1 Coaaulation and
Clarification. and Ultraviolet-Enhanced Oxidation.
This alternative would treat leachate in two phases.
First, certain metals and other contaminants would be
removed by coagulation. FOllowing this treatment, the
water would be acidified and treated by ultraviolet
light to reduce BOD and destroy organic contaminants.
Treated water would be discharged to Hockanum Brook.
No Action. Although analysis of a No Action
alternative is normally required by Federal law, the no
action alterative was not included in the supplemental
ROD since the 1985 ROD had already directed that
leachate treatment and disposal be performed.
Therefore a no action alternative was not viable for
leachate treatment and disposal.
.
Using the information gathered during the pre-Design Studies
concerning contaminant levels in soils, EPA used a groundwater
modeling technique to determine levels of contaminants in the
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n
Also based on the Pre-Design studies, EPA made a determination
that air pollution controls on landfill gas vents are not
practicable to install on the landfill gas vents at this time.
The vents will, however, be designed to allow the addit~on of
controls if necessary based on continued monitoring of air
emissions after capping. .
o
II.
SITB HISTORY AND BACKGROUND ON COMMUNITY INVOLVEMENT AND
CONCBRNS
The Beacon Heights Landfill site is located south of
Blackberry Hill Road near Skokorat Road in Beacon Falls,
Connecticut, 10 .iles south of Waterbury. The site encompasses
82 acres, 34 of which comprise the actual Beacon Heights
Landfill. Residential areas lie to the north of the site along
Blackberry Hill Road and to the west along Skokorat Road.
From the 1920s until 1970 the site was known as "Betkoski's
Dump". This dump area consisted of approximately 6 acres of
active landfill in the northwest corner of the site. According
to Connecticut Department of Environmental Protection (CT DEP)
records, a variety of waste materials including municipal
garbage, rubber, plastics, and industrial chemicals and sludges
were deposited on the site. Waste disposal methods consisted
primarily of open burning and burial .of any remaining unburnable
wastes.
In 1970, Beacon Heights, Inc. purchased the Betkoski
property and adjacent properties and changed the name of the Site
to the Beacon Heights Landfill. The landfill area then greatly
expanded. CT DEP records show that rubber, plastics, oils,
chemical liquids, sludges, and solvents were dumped at the site
along with municipal wastes.
By 1979 most landfill operations had reportedly ceased
following numerous actions by the CT DEP to enforce waste
disposal permit violations. However, wastewater treatment plant
sludge continued to be spread over large areas of the site until
1983. During the years of operation an estimated total of
650,000 cubic yards of waste were placed at the site. The waste
mound is up to 60 feet deep and extends down to bedrock in some
areas.
The site was listed on the EPA's National Priorities List on
September 1, 1983. As a result of the listing, the site became
eligible for remedial actions under the Comprehensive
Environmental Response, compensation, and Liability Act (CERCLA).
In 1984, EPA conducted a Remedial Investigation (RI) to
determine the nature and extent of contamination at the. landfill.
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6
solvents in two private wells on Skokorat Road at levels
exceeding the state of Connecticut's drinking water standards.
CT DEP subsequently supplied these two residences with bottled
water until they, along with 42 other homes in the vici~ity of
the Site, were connected to the municipal water supply. By
summer 1989, all owners of homes with wells threatened by
contamination from the landfill desiring public water had been
connected to the municipal water system.
EPA signed a ROD for the site in 1985 following a comment
period lasting from May 20, 1985 to June 14, 1985. Community
concerns at that time focused most"heavily on completion of a new
drinking water supply for" area residents. Residents were also
concerned about two remedial alternatives evaluated in the 1985
Feasibility Study: 1) an on-site incineration facility, and 2) a
RCRA-permitted landfill. Specifically, they were concerned that
wastes from other hazardous waste sites could be brought to the
Beacon Heights Landfill for treatment by or for disposal in one
of these facilities.
In September, 1987, EPA entered a consent decree with 32
PRPs, now known as the Beacon Heights Generators Coalition (BHGC)
under which the PRPs agreed to perform remedial actions at the
site. Among other things, the consent decree required the PRPs
to perform pre-design studies to gather information which forms
the basis for the determinations made in this supplemental ROD.
Community concern surrounding contamination at the Beacon
Heights Site has been high during the Pre-Design Studies and
public comment period. A public informational meeting held on
May 9, 1990 concerning the results of the Pre-Design Studies and
EPA's Proposed Plan was attended by approximately 20 people. The
principal community concerns expressed at that time are
summarized below.
.
Potential Liability of the Town of Beacon Falls. Town
officials and residents expressed concern that, if the
Town were to accept leachate from the landfill and
problems with treatment at the facility occurred in the
future, the Town would bear financial or legal
responsibility for those problems.
ImDacts on Neighbor~na Aaricultural Lands. A resident
questioned whether he was, or could be, at risk working
in his orchards located adjacent and downstream of the
site and the proposed leachate collection system.
.
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o
Ouest ions Concerninq the Landfill CaD. Residents
expressed interest in the effectiveness of the cap,
whether leachate was formed as a result of groundwater
infiltrating the landfill in the area of the cap or
from infiltration of rainwater, and why EPA was
installing gas vents in the landfill.
III. SOMHARY 01' COMMENTS RECEIVED DURING THE PUBLIC COMMENT
PERIOD AND EPA RESPONSES
.
This Responsiveness summary addresses the comments received
by EPA concerning the Pre-Design Studies and EPA's Proposed Plan
for the Beacon Heights Landfill site. Nine sets of written
comments were received during the public comment period (May 10,
1990 - July 9, 1990). Comments were submitted by members of the
general public, state and local government authorities, and
representatives of the PRPs. Four oral comments were presented
at the May 30, 1990 informal public hearing. certain oral
comments were accompanied by corresponding written comments.
Commentors at the public hearing were either residents or local
government officials. A copy of the public hearing transcript is
included as Attachment B. Copies are also available at the Town
Clerk's Office at the Beacon Falls Town Hall, the information
repository that EPA has established for the site; and at the EPA
Records Center at 90 Canal street, Boston, Massachusetts, as part
of EPA's Administrative Record.
Part I - citizen, State and Local Government Comments
Comments from citizens, along with EPA responses, are
summarized and organized into the following categories:
B.
Comments Regarding Treatment at the Beacon Falls waste
water treatment facility;
Comments Regarding Treatment at the Naugatuck waste
water treatment facil-ity;
Comments Regarding On-site Leachate Treatment; and
General Comments.
A.
C.
D.
Comments Regarding Treatment at ~he Beacon Falls
.as~ewater Treatment Facility
Comment No.1: The Town of Beacon Falls, in a letter dated June
29, 1990, advised EPA of its willingness to accept leachate from
the Beacon Heights Landfill Superfund Site, subject to the PRPs
meeting certain technical and legal requirements. This comment
reversed the Town's earlier decision, presented to EPA in an
undated letter, not to accept the leachate.
A.
EPA's ResDonse:In the 1985 ROD EPA determined the Beaco~ Falls
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condition of the facility at that time. Further studies
performed in the Pre-Design Studies document indicated that the
Beacon Falls facility could be upgraded to accomodate leachate
from the site. Therefore, the Beacon Falls facility became a
viable option. .
In accordance with Section 121 of CERCLA, as amended, and
the National contingency Plan (NCP) 40 CFR 1300.68(i), EPA must
select a cost effective leachate treatment and disposal
alternative that effectively mitigates and minimizes threats to
and provides adequate protection of human health and the
environment which is cost effective. In reaching its decision
for the selected leachate treatment and disposal alternative, EPA
is required to compare alternatives developed in preliminary
studies to each other using nine specific criteria set out in the
NCP (see section IX of the supplemental Record of Decision). In
addition to community acceptance, EPA must also evaluate whether
the selected leachate treatment and disposal alternative:
~
.
Is protective of human health and the environment;
Attains all Applicable or Relevant and Appropriate
Requirements;
.
.
Provides for long-term effectiveness and permanence;
Provides for reduction of toxicity, mobility, or
volume;
.
.
Considers the short term effectiveness
.
Is implementable;
Is cost effective and;
.
.
Has State acceptance.
When evaluated against the other alternatives using the
above criteria from the NCP and taking into account the Beacon
Falls upgrade, both Beacon Falls and the Naugatuck waste water
treatment facility alternatives are protective, meet ARARs and
meet the technical criteria for selection.
During the Proposed Plan process, the Naugatuck option was
preferred for leachate treatment and disposal based upon the nine
evaluation criteria listed above because the Town of Beacon Falls
did not agree to accept the leachate for treatment and disposal
at the time the Proposed Plan was issued. The Beacon Falls
alternative was deemed unimplementable based on this lack of
consent by the Town. Subsequently, the Town reversed its earlier
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o
certain conditions were met by the BHGC. Since receiving the
June 29 letter, EPA actively considered the Beacon Falls
alternative in the selection process. Negotiations between the
PRPs and the Town of Beacon Falls relative to the condi~ions have.:
taken place since June 29. However, at the time this
supplemental ROD was signed, no agreement was reached and the
Beacon Falls alternative w~s, therefore, deemed unimplementable.
Comment No.2: In a letter to EPA dated July 9, 1990, the state
of Connecticut DEP supported treat~ent of Beacon Heights leachate
at the Beacon Falls facility, subject to approval of the Town and
technical upgrading of the treatment facility.
EPA's ReSDonse: Based upon a review of the nine evaluation
criteria for leachate treatment and disposal selection (see
Comment I.A.) as applied to the on- and off-site alternatives,
EPA concurs with the Connecticut Department of Environmental
Protection's (CT DEP) comment to the extent that treatment of the
leachate at the Beacon Falls facility is superior in many
respects to most of the alternatives considered. The Beacon
Falls option would, among other things, reduce both the cost of
remediation as well as the potential for leakage/breakage as a
function of pipeline length. However, as discussed in section
IX.6. of the supplemental ROD, because the Town of Beacon Falls
has not agreed to accept the leachate for treatment and disposal,
the Beacon Falls alternative is deemed unimplementable.
Therefore, the Naugatuck wastewater facility alternative became
the selected alternative based on the NCP criteria.
B. Comments Regarding ~reatment at the Naugatuck Waste Water
~reatment Facility
Comment No.1: A resident expressed her opposition to piping
Beacon Heights leachate to the Naugatuck facility. The resident
noted her concerns over objectionable odors associated with
current facility operations as well as potential negative impacts
on two cemeteries in the vicinity of the facility. The resident
entered into the record copies of articles from the Nau9atuck
Dailv News reporting on odors associated with the facility. An
article on an accident at an industrial pre-treatment facility
was also submitted.
EPA's ResDonse: One of the major contributors to malodorous
characteristics of industrial type leachates is the compound
hydrogen sulfide. Leachate emanating from the Beacon Heights
Site does not contain this compound. In addition, the amount of
sludge produced through leachate treatment will decrease
proportionately within 5 to 10 years of capping as the amount of
leachate generated within the landfill decreases. By the end of
10 years only minimal amounts of leachate are expected to be
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out. Sludge production will likewise decrease. (see section
V.C.l. of the supplemental ROD).
During the first year, leachate from the Beacon Heights
Landfill site will be generated at approximately 20 gallons per
minute (gpm). This would constitute slightly less than l' of
the total inflow at the Naugatuck facility. Therefore, the
introduction of leachate from the Beacon Heights site would have
negligible impacts on current operations at the facility in terms
of odors being emitted from the plant.
In addition, state air pOllution control requirements ensure
that air emissions from the Naugatuck facility do not exceed odor
threshold and hazard limits which are protective of human health.
with regard to the danger of explosions at the facility as
referenced by the newspaper article submitted by the commentor,
concentrations of volatile organic compounds at the plant should
be low due to the dilution of the leachate by sewage in the sewer
pipes. Therefo*e, the danger of explosion at the facility due to
the Beacon Heights leachate is minimal.
Comment No.2: A local representative of the Town and Borough of
Naugatuck noted the Borough's concern with odors from the
treatment facility, but stressed that odors at the plant are not
related to the facility's treatment of leachate from the Laurel
Park Superfund site, nor would the facility produce increased
odors as a result of receiving and treating Beacon Heights
Leachate. The Borough representative entered into the record the
Borough of Naugatuck's willingness to accept the leachate subject
to conditions presented to the PRPs.
EPA's ReSDonse: Refer to response to comment I.B.l: EPA
acknowledges the Borough of Naugatuck's willingness to accept the
leachate from the Beacon Heights Landfill subject to conditions
presented to the PRPs. Based on this consent, as well as the
comparison of this alternative to the other five alternatives,
and in the absence of consent from the Town of Beacon Falls to
accept the leachate, EPA has selected the Naugatuck option as the
most protective and cost effective alternative for treating and
disposing of the Beacon Heights landfill leachate.
Comment No.3: The State of Connecticut expressed its support
for EPA'S choice of the Naugatuck facility provided EPA is unable
to choose the Beacon Falls facility as the off-site treatment
location. .
EPA's ReSDonse:
I.B.2.
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c.
Commen~8 Reqar4inq On-Si~eLeacba~e ~reatmen~
Comment No.1: The state of Connecticut submitted its 9PPosition
to the use of an on-site treatment facility at the Site, noting
concerns regarding water quality impacts to the Hockanum Brook.
EPA's Res'Oonse: EPA acknowledges CT DEPs opposition to any on-
site treatment alternatives requiring disposal of treated waste
waters to the Hockanum Brook. EPA concurs that "on-site
'packaged' treatment systems require extensive upkeep and are
subject to frequent upsets." .
EPA does not necessarily agree that "creation of a treated
leachate discharge would result in continued non-attainment of
the water quality 90al" of the Bockanum Brook. Effluent
discharge to any surface water from an on-site treatment facility
would be treated to NPDES standards. However, EPA understands
that a discharge of this type could result in non-attainment of
State water quality goals should an upset occur.
Finally, on-site treatment and disposal alternatives were
found to be less protective and cost-effective than off-site
alternatives based on the NCP criteria for selection of remedial
actions.
Comment No.2: A resident expressed his support for on-site
treatment of landfill leachate, noting that this alternative
would alleviate problems with the Towns of Beacon Falls and
Naugatuck and move the cleanup along.
EPA's Res'Oonse: The Agency acknowledges this resident's concern
regarding the importance of expediting the remedial action. As
with every Superfund Site, a specific schedule is developed for
the progress of remedial actions. The schedule for the Beacon
Heights site was laid out in the Remedial Action Plan which was
attached to the 1987 consent decree. EPA has adhered to this
schedule. The only significant delay in the cleanup of this
site arose when legal access to the site was denied by the site
owner after the 1985 ROD was signed. No delays have resulted
from negotiations involving the Towns of Beacon Falls, Naugatuck
or with the PRPs.
Included in the schedule referred to above is the process of
selecting a remedial action for the site. For the Beacon Heights
Landfill Site, on- and off-site alternatives were developed,
screened and compared against each other using the nine
evaluation criteria set out in the NCP (See response to comment
I.A.1.). EPA determined that piping to and subsequent treatment
and disposal of the Beacon Heights leachate at the Naugatuck
facility provides the best balance of the nine evaluation
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12
selection process has not been influenced by any actions of
ei ther Town: the same amount of time is required whether the
selected alternative was located on-site or off-site.
D.
General Commen~.
Comment No.1: CT DEP stated that it does not support EPA's soil
excavation criteria. CT DEP noted that EPA's choice of soil
excavation criteria, leaving soils in place with contamination
levels exceeding Connecticut Action Levels, with no groundwater
treatment or containment program planned, would not meet the
state's groundwater quali~y goal.
EPA's ReSDonse: The removal of contaminated soils to Connecticut'
Action Levels, as advocated by CT DEP, is more stringent than is
necessary to preserve federal drinking water standards at the
Site. A certain amount of contaminants always remain in the
soils and are not flushed through to groundwater by surface
runoff or precipitation. Through the use of groundwater mOdeling
which incorporate federal MCLs and proposed MCLs for drinking
water, the levels of contaminants left in place will not endanger
human health and the environment nor will they further degrade
groundwater at the Site. EPA believes the soil excavation limits
selected in the supplemental ROD are protective of human health
and the environment and meet all promulgated ARARs.
.
Comment No.2: CT DEP stated that landfill gas emissions must be
monitored following cap construction, and that the CT DEP must be
consulted on any decisions regarding the use of air pollution
control devices. .
EPA's ReSDonse: EPA has incorporated pre-cap monitoring and
post-cap construction monitoring at the landfill gas vents, at
the landfill perimeter, and at other removed sampling stations to
determine concentrations of landfill gas emissions of hazardous
compounds and to differentiate landfill source contribution from
backqround levels of contamination as part of the final remedy.
The remedial action also requires that the landfill gas vents be
constructed in such a way that pollution control devices will be
installed should air monitoring reveal that emissions from the
landfill exceed federal or state standards or exceed any hazard
risk range.
CT DEP will be consulted in the decision regarding the use
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- 13
Part II - potentially Responsible Party Comments
o
SummarY of Comments
Comment No.1: The PRPs (Beacon Heights Generators Coalition)
state that on-site pretreatment of leachate, prior to pumping to
an off-site wastewater treatment facility, is unnecessary and
would result in increased environmental and safety risks in the
site area.
c
EPA's ReSDonse: A state permit is required to discharge the
leachate from the leachate collection structure to the sewer
lines. Sampling and analysis during the design phase will
determine what, if any, pretreatment elements are necessary to
meet these permit requirements.
While environmental and safety risks are always present when
activities concerning hazardous substances are performed,
pretreatment, as necessary, will be conducted in accordance with
all applicable federal and state standards including all OSHA
standards for worker safety.
Comment No.2:
state that the
Design Studies
environment.
The PRPs (Beacon Heights Generators Coalition)
soil excavation levels established in the Pre-
are appropriate to protect public health and the
EPA's ReSDonse: EPA disagrees that the soil excavation levels
established through the Designated Level Method discussed in the
Pre-Design Studies protect human health and the environment. The
July 6, 1990 letter of comment from the PRPs states that the
Designated Level Method has been used in other sites according to
the EPA document entitled "Determining Soil Response Levels Based
on Potential contaminant Migration to Ground Water: A Compendium
of Examples". However the only cases referenced were located in
Region 9.
The degree of attenuation in soils is dependent on the
chemical properties of the waste constituents, distance from the
waste management unit to usable water, the geologic materials
including the permeability, chemistry and structure, and the
velocity of the ground or surface water. The "Compendium of
Examples" document clearly states that one of the limitations of
the Designated Level Method model is that it does not address
site-specific considerations in detail. Therefore, the model
uses a somewhat arbitrary attenuation factor for its
calculations. Also, the model fails to assign specific
attenuation factors to individual contaminants.
EPA calculated soil cleanup levels using primarily. the
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other similar sites in Region 1. The Summers model incorporates
federal MCLs and proposed MCLs as well as site specific
information. The cleanup levels calculated through the Summers
Model include a level for one compound which is also found in the
Desiqnated Level Method model results. This level was included
based on similar sites in the Region. EPA believes that the soil
cleanup levels established and documented in this supplemental
ROD will be protective of human health and the environment at the
completion of the remedy.
The Summers model assumes tha~ a percentage of rainfall at
the site will infiltrate and desorb contaminants from the soil
based on equilibrium soil/water partitioning. Using groundwater
modeling, the 80il cleanup level is calculated from the original
soil concentration, the concentration of the infiltrating water,
and an equilibrium coefficient.
c
The Summers model was developed to estimate the point at
which contaminant concentrations in the soil will produce
groundwater contaminate concentrations above acceptable levels.
The resultant soil concentrations can then be used as guidelines
in estimating extents of soil contamination and specifying soil
cleanup goals for remediation.
.
with regard to specific areas of concern raised by the PRPs
in terms of the Summers model, the following responses apply:
1) At superfund investigations throughout New England,
.total organic carbon (TOC) values below the soil horizon
have routinely been found to be less than 1 percent.
Therefore, the use of 0.4 percent, the lowest value
determined for the site seems reasonable.
2) Published ROC values do vary in the literature.
However, the range in values can still be used. (It should
be noted that attenuation factors used in the Designated
Level Method also vary.)
Comment No.3: The PRPs (Beacon Heights Generators Coalition)
suggest that EPA's supplemental ROD specify leachate treatment at
an off-site wastewater treatment facility, and not specify the
specific location of the facility to allow EPA the discretion to
choose either Beacon Falls or Naugatuck following negotiations.
EPA's Resoonse: EPA attempts to resolve all remedial. cleanup
decisions that are practicable to make. The two wastewater
treatment facility alternatives are very different in terms of
plant upgrades necessary, pipeline construction lengths and
designs, costs, and community acceptance. EPA disagrees with the
PRP comment that by specifying "that the leachate be discharged
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15
o
. -
stipulating a specific facility" would "promote an expedient
conclusion to successful negotiations" with either facility. On
the contrary, EPA believes that an .open-ended" decision would
only lead to delays in the project.
Since the first draft of the Pre-Design Studies was
delivered to EPA in August, 1989 negotiations with the respective
wastewater treatment facility authorities and the PRPs have been
ongoing. The public comment period was extended 30 days in
accordance with the NCP at the request of the Town of Beacon
Falls to facilitate the review of the Beacon Falls facility
alternative by a private contractor. It has been EPA's
experience at Superfund sites that only when faced with a
reasonable deadline will issues become resolved. EPA believes
that adequate time has passed for negotiations and that the
decision to send leachate to the Naugatuck facility for treatment
and disposal which is documented in this supplemental ROD is in
the best interests of protecting human health and the
environment, and allows EPA to maintain the schedules previously
set for cleaning up the Site (see response to Comment I.C.2).
Comment No.4: The third party defendants in the Murtha
litigation argued that, should EPA choose the Naugatuck facility
alternative as the remedial alternative due to the Town of Beacon
Falls unwillingness to accept leachate at that Town's wastewater
treatment facility, the difference in cost between these two
treatment locations be allocated to the Town of Beacon Falls.
The third party defendants also argued that the Town of Beacon
Falls cannot refuse to treat Beacon Heights wastes at their
facility, and that EPA has given illegal and improper weighting
to the community acceptance criteria in choosing treatment at the
Naugatuck facility.
EPA's ReSDonse: section 107 of CERCLA, as amended, provides
that any owner, operator, generator, or transporter of hazardous
substances to a site shall be liable for all costs of removal or
remedial action at the site. The leachate treatment and disposal
component of the remedy is considered part of the remedial
actions for which any of the named PRPs is liable. The location
of this alternative does not alter, in any way, the PRPs
liability for payment of this remedial cost. The Town of Beacon
Falls has not been identified as a PRP at this Site and is
therefore not liable to the Agency for the remedial costs at the
site.
EPA has no authority to order the Town of Beacon" Falls, and
any other municipality, to modify its legitimately licensed
treatment facility.
The Agency's decision to select Naugatuck as the location
for leachate treatment and disposal is documented in the
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balancing of all the alternatives using the nine criteria set out
in the NCP. The Beacon Falls location was determined not to be
implementable and the Naugatuck facility became the selected
location for leachate treatment and disposal.
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ATTACHMENT A
COKMUNITY RELATIONS ACTIVITIES CONDUCTED AT .
~ BEACON HEIGHTS LANDFILL SUPERFUND SITE
o
SeDtember. 1983 - EPA developed a Community Relations Plan
outlining a strategy for communicating with residents and other
interested parties.
.
Februarv. 1984 - EPA distributed a fact sheet describing the
upcoming remedial investigation activities.
March 26. 1984 - EPA held a public meeting to discuss remedial
the investigation.
June. 1985 - EPA distributed a fact sheet outlining the
feasibility study and soliciting public comment.
June 11. 1985 - EPA held a public hearing to accept public
comments on the feasibility' study
Auaust. 1987 - EPA distributed a fact sheet describing the
progress made on implementation of the remedy, including the
extension of the municipal water line to 50 homes near the site.
Auaust 24. 1987 - EPA held a public meeting on remedy progress
and waterline extension.
May. 1990 - EPA distributed a Proposed Plan for the supplemental
Record of Decision.
Mav 9. 1990 - EPA held a public meeting to explain the Proposed
Plan.
Mav 30. 1990 - EPA held a public hearing to accept comments on
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ATTACHMENT B
Transcript of the May 30, 1990 Informal Public Hearing
\>
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1
e_B_g~-~-~~_!_~-~-~
2
[7140 p.m.]
3
HARGARET LESHENI
Good evening and welcome.
4
I'm Haggie Leshen.
I'. Chief of the
5
Connecticut Superfund Section and I'll be running
6
tonight's hearing.
7
I did want to tell you -- can everyone hear
8
me? -- that these microphones are for the transcriber
9
and they do not amplify.
So if any point you can'-t
10
hear us, just let us know.
11
I'm going to tell you how we're going to be
12
running tonight's meeting.
13
We're going to have basically three parts.
14
First, Eric is going to give a very bri!f
15
description of the site and the proposed plan, and then
16
we're going to have the actual hearing part, where you
17
come up and make comments into the record of which we
18
do not respond to.
We will be responding at a later
19
point in a response in this summary when we make-.
20
decision on this .ite, and that will be a written
21
document responding to all the comments raised tonight.
22
After everyone has had the opportunity to
23
make their comments into the record, we will close the
24
hearing and we will stick around a. long as W8 can to
25
answer ~ny questions you might have informally at that
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UNITED ST"7=~ OF AMERICA
1
ENVIRONMENTAL PROTECTION AGENCY
2
REGION I
3
4
5
In the Matter of:
("
PUBLIC HEARING
6 SUPERFUND PROGRAM
7 BEACON HEIGHTS lANDFILL SITE
BEACON FALLS, CONNECTICUT
~;
8
9
Town Hall
10 Maple Avenue
Beacon Falls, Connecticut
Wednesday
May 30, 1'3'30
The above entitled matter came on for hearing,
16
pursuant to Notice at 7:40 p.m.
17
BEFORE:
18
MARGARET lESHEN
ERIC VAN GESTEl
ERICA PEACH
MIKE POWERS
JAMES SEBASTIAN
19
20
21
22
23
24
25
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poin~.
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Basically, we're going to open it up to the
3
formal comments for each person for about ten minutes
4
in the event people have -- J don't know how long your
S
comments are, and 50 that give. each person a chance to
Q 6 speaJ~ in.. relatively short amount of till'le, and then we
7 will stick around for however long it does take,
8 because I did notice some people have 50me very long
9
comments at this point.
But I just want to make sure
10
you understood that.
11
Tonight is the hearing, a public hearing,
12
for you to put your comments into the record orally.
We will be accepting written comments until July 9th.
w. have made the decision to extend the public comment
13
14
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period to that time.
That gives you an additional
16
30 days to respond in writing.
17
The comments must be received in our office
18
by July 9th and they need to be addressed to Eric Van
19
Gestel, and his name is on the back of the fact sheet
20
if anyone needs it.
21
As I said earlier, we have Eric Van Bestel,
22
the EPA Site Manager with us.
23
We have Erica. Peach, the State Site Manager,
24
here tonight, a. well a. Mike Powers from the State.
25
And in the back, Jim Sebastian, our
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Community Relations Spe~ialist, with us this evening.
2
That's how it is going to be running.
80,
3
first, we're going to have Eric give a very shor~
4
discussion of the prop05ed plan, so everyone
..
5
understands what the hearing is on tonight.
6
And, .. J said, we will open it up to your
~
7
comments.
e
60 Eric is going to run through it right
9
now.
10
ERIC VAN GESTELI
This is a recap of the
11
document that was presented at the public meeting.
12
The U. S. Environmental Protection Agency
13
(EPA>, has proposed a cleanup plan, referred to as a
14
preferred alternative or proposed plan, to addres5
15
leachate contamination at the Beacon Heights Landfill
16
Superfund site at Beacon Falls, Connecticut.
The
17
preferred alternative is EPA's preliminary selection of
18
a remedy and may be changed if public comments or -new
19
information is presented to EPA during the public"
20
comment p:::-iod
ttot significantly affects EPA's
21
evaluation of the alternative..
22
EPA recommends . ~ethod of leachate
23
treatment and off-site disposal at a municipal sewage
24
treatment facility.
EPA selected this preferred
25
alternative from among the treatment options that were
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evaluated during the pre-design studies required by the
1987 Consent Decree and the 1985 Record of Decision for
3
the site.
4
After evaluating 811 of the reasonable
5
alternatives, EPA proposes to pretreat the leachate
6
on-site and pipe the treated leachate to the Naugatuck
7
sewage treatment plant.
That's the POTW in Naugatuck.
8
This alternative would require the
9
construction of a five-mile-long pipeline from-the site
10
to a point in the pipes of the Naugatuck sewer system
11
the intersection of Cotton Hollow Road and Cross
near
12
Street.
The pipeline will be laid primarily in the
13
rights of way of Bethany Road, Main Street and Route B.
14
This pipeline would carry the leachate from the site.
15
This alternative would 41so require the installation of
16
. leachate collection tank of approximately
17
5,000-gallon capacity and a pump station near the site
18
to pump the leachate to the Naugatuck sewer system.
19
The resul t. of the pre-designed study..
2v
indicate that the extended aeration activated sludge
21
process at the Naugatuck POTW could effectively treat
22
the contaminants of the leachate with no adver.e
23
effects on the plant'. o~erations.
The POTW
24
incinerates any sludge remaining after treatment as
25
part of its normal operation.
Treated water from the
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facility is then dischArged to the Naugatuck River.
2
If public comment and further information
3
change EPA's evaluation of this or any of the other
4
alternatives, in particular, those involving Beacon
c'""
5
Falls approvals or State approvals, EPA .ay decide on
6
another alternative for its final selection.
7
I'd like to quickly run through the other
8
alternatives evaluated in ~he Pre-Design Study Report.
9
Alternative No.1 in the proposed plan
10
document is similar to EPA's preferred alternative.
11
This alternative would discharge pretreated
12
leachate into the Beacon Falls sewer system for
13
treatment at an upgraded Beacon Falls POTW plant.
14
Construction of . .3 mile pipeline from the landfill to
1S
the sewer system would be requir.d.
16
The upgrade of the POTW would include the
17
addition of oxygen to the air used in the activated
18
sludge process, as well as an increase in the
19
capacities of the sludge pumping and dewatering".
20
systems.
Sludge from the Beacon Falls POTW is
21
incinerated at the Naugatuck facility.
22
Alternative No.2 would treat the leachate
23
on-site, using granular activated carbon filtration,
24
green sand filtration, and che.ieal disinfection.
The
25
treated disinfected water would then be discharged to
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the Hockanum Brook.
Any waste sludge will be trucked
2
to an appropriate off-site disposal area.
Alternative No. 3 in the proposed pla~.
advocates transporting the leachate via ~,OOO gallon
3
4
5
tanker trucks to an approved treatment, .torage and
6
disposal facility licensed to treat haz.rdou& waste.
7
Alternative No. . requires the construction
8
of an on-site tT.a~ment facility consisting of a pair
9
of parallel bioreactors, green sand filters and.
10
disinfection equipment.
The treated disinfected water
11
would then be discharged to the Hockanum Brook.
Any
12
waste sludge will be trucked to an appropriate off-site
13
~isposal area.
14
Alternative No.5 would require the
15
construction of an on-site facility which would treat
16
the leachate using chemical coagulation and
17
clarification and ultraviolet-enhanced oxidation.
The
18
treated disinfected water would then be discharged to
19
the Hockanum Brook and any waste sludge will be .trucked
20
to an appropriate off-site disposal area.
21
Alternative No.6, the last in the proposed
~
plan, is the analysis of a No Action remedy.
This
23
analysis is required by Federal law and is included for
24
a comparison as a baseline against which all other
25
alternatives would be evaluat.d.
In this alternative,
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the contaminated leAchate would not be treated and
2
contaminants would not be prevented from reaching
3
surface and groundwater.
4
Again, if public ~omments and further
..
5
information change EPA'. evaluation of this or any of
6
the other alternatives, in particular those involving
7 Beacon
8 decide
9
10
11 round.
12
Falls approvals or StAte approvals, EPA may
on another alternative for its final selection.
MARGARET lESHENa
Thanks, Eric.
And now we are going to begin the comment
The first commentor that I have is Mr. Swan.
13
Would you like to come forward?
14
WILFRED SWANa
Good evening, and good
15
evening.
16
I'm glad to see some people are interested
17
in what's going on, whether it's the dump or not.
It's
18
nice to see somebody here.
19
t will start off with saying that I gAve a
20
letter to Mr. Van Gestel of my opinion.
21
It is my opinion and my suggestion that the
22
cleAnup of the Beacon Falls Heights landfill be
initiated soon by using the plan of installing the
23
24
sewer plant method on-site.
25
This would eliminate all the problems with
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the town and only need the approval of one person, me.
2
That'. why I say it.
We're going through a rigamarole.
3
I want to say that this is what happ~ns with
4
a rigamarole.
This is newspaper clippings, letters,
5
pictures that I've accumulated for 2S year. on the
6
dump.
It never stops, but it'. still going on.
And
7
it's been going on, now, fo~ two years since the
-- I
8
guess since the environmental people got in it, and it
9
never seems to come to a completion.
10
80 I'm saying, stop, start tomorrow and
11
start digging, fill it in on my property.
That's where
12
the plant will be.
We'll make a deal.
But nobody has
13
to worry about it.
Don't have to have any meetings or
14
anything.
That's it.
15
MARGARET LESHENI
Thank you.
16
The next person that I have is Len D'Amico.
17
LEN D'AMICO:
I'm going to sit down.
I'm
18
not as strong as Bill.
19
There are a couple of comments I'd like to
20
make and I'd like to have them part of the record.
21
Just recently sent a letter to Eric Van
22
Gestel at the EPA Office in 80ston and it was in
23
reference to the cleanu~.
And the letter is as such:
24
MDear Mr. Van Bestel,
25
MAs counsel to the Town of Beacon Falls, I
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hereby request that the EPA extend the time allotted
2
10r reaching a decision on the supplemental cleanup
3
plan 10r treating leachate 1rom the Beacon Heig~t. site
4
in Beacon Falls, Connecticut.
~
5
"The Town 01 Beacon Falls has retained the
6
engineering 1irm 01 Fossen O'Neil to evaluate the
7
possibility 01 treating leachate 1rom Beacon Heights at
8
the Beacon Falls ~astewater treatment 1acility.
9
"We anticipate that Fossen O'Neil ~ill-make
10
its recommendations by the last week in June, at which
11
time the town will be in a position to decide whether
12
or not to accept the treatment 01 the leachate at its
13
wastewater treatment plant."
14
This is signed by Donald Silitello, under
our ~uthority to request the extension.
15
16
We want to make that part 01 the record.
17
And now I'd like to brie1ly comment, i1 I
18
may, at your initial hearing your pre1erred alternative
19
was to take the leachate on-site pretreated and have it
20
1low to the Naugatuck wastewe.te~
tYeM~ii.cf..t
plant which,
21
01 course, is prepared to accept this type 01 leachate.
22
The second alternative, a. you've just read,
23
would be the Beacon Falls wastewater treatment plant
24
a1ter it'. been upgraded.
25
I just want to let the 101ks know that a1ter
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due consideration we did retain Fossen O'Neil, who are
2
eminently qualified, to review the recommendations of
3
Kimony and the generators and to evaluate and to. .
4
recommend to the Town of Beacon Falls what would be in
5
our best interest, both presently and in the future.
6
Now, in the meantime, I received a copy of a
7
letter that was sent from t~e law firm of Adams ~
8
Harding out of Middletown, Connecticut, and it was sent
9
to William A. Butler, Esquire, of the law firm of
10
Dixtine, Shapiro ~ Morin in Washington, D. C.
11
Now, Bill Butler is the lead counsel for all
12
the municipalities.
He is representing all the
13
municipalities in this Beacon Heights and laurel Park
14
cleanup.
And the letter -- and J want it placed in
1S
record, the Proposed Supplemental Cleanup Beacon
16
Heights Leachate.
17
"Dear Billl
18
"I have finished reviewing the EPA Proposed
19
Supplemental Cleanup plan to address leachate treatment
20
and dispcsal
~~ t:-.~ c.eacon
Heights Landfill site, dated
21
May 1990, in which various alternatives to the
22
treatment of the Beacon Heights leachate is discussed.
23
"I noticed that the selected alternative is
24
the $2,241,000 not present value alternative 01 piping
25
the leachate from Beacon Falls to the Naugatuck
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treatment plant, A distance of five miles.
2
"One of the Alternatives which evidently is
not available is the piping of the leAchate .3 miles
3
4
and upgrAding the Beacon Falls sewAge treatment plant.
'"
5
The next present value '01 that alternative is
6
$1,501,000.
7
"The Beacon Falls alternative evidently is
8
not available because 01 a" -- and I love this
9
word -- "because of the recalcitrance of a member of
10
your class, and that is the Town 01 Beacon Falls.
11
"While I have great sympathy for any
12
community which is a host community by a mistake 01
13
geography rather than by choice, I cannot have sympathy
14
for a community which wishes to increase the costs of
15
the remedy by an amount of $740,000 and have that cost
16
allocated against all other parties to this action.
17
"In the event that the Naugatuck treatment
18
plant alternative becomes a selected alternative, the
19
transporters, as a class, are prepared to argue that
20
t~e difference in net present vAlue of the remedy of
21
$740,000 be allocated to the Town of Beacon Falls and
22
then only an amount 01 $1,501,000 will be shared by
23
other parties to this suit."
24
I want to go on record as saying I received
25
a copy of this letter And I resent it very much.
I
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think the Town of 8e.co~ Falls and the people who are
involved, our committee, have been working very, very
hard to come up with a very fair and equitable
.ettlement to all parties concerned.
We are not, 'we are not under any pressure by
6
any law firm, going to take and agree to anything that
7
15, 20 or 40 years from now; our children or our
e
grandchildren are going to be burdened with a problem
9 that'.
10 today.
11
12
13
14
15
16
17
going to cost them much more than we envision
50 I want that part of the record.
MARGARET LE5HEN:
Thank you.
The next commentor is Ray Fitzpatrick.
FROM THE FLOOR: No comment.
MARGARET LESHEN: Okay, we can come back.
The next person is Dorothy Mason.
DOROTHY MASON:
I'm just a very ordinary
18
citizen of Naugatuck.
And I don't know whether --. I
19
suppose our town officials have probably met with you
20
but it has been my experience in life that -- I speak
21
out for myself and a lot of people and I don't usually
22
care what town officials say.
I do what I think is
23
right.
24
And as far as I'm concerned, I would like to
25
say that I speak on behalf of myself and us who live in
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the immediate area of the wast. disposal plant.
One is
2
ninety years old, one will be eighty-eight, my mother,
3
June 30th.
And one is eighty-three years old.
4
Right now my aunt is very, very sick.
And
5
Just the other day she.aid to me, Dolly, she said, I
6
hate the summertime to come because the stench coming
7
in those windows, we can't even open our windows.
8
They live on Gorman Street.
9
And I think it's every person's right to be
10
able to breathe clean air, especially when you're
11
ninety years old and eighty-eight and every day could
12
be your last breath.
13
Let's see, what else do I wa~t to say?
14
There is a possibility, I feel, that the
15
people of Naugatuck have not drawn a clean breath of
16
air in the last 100 years.
Yet in the last few months
17
a wood burning plant and this S2-million-plus pipeline
18
with its insidious contents have been proposed again in
19
Naugatuck.
20
We have trailers hauling who knows what into
21
our town, over our roads.
I understand there are at
22
least 2S different municipalities sending their sewer
23
contents to our town.
24
Where does it all end?
25
Our taxes are escalating and 50 is the
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stench.
2
1 feel, 81so, ~hat with all the pollution of
3
our air in the vicinity of our cemeteries, St. James
4
and Grove, both Catholic and Protestant, these are both
5
directly across from the numerouS smokestacks and the
6
holding tanks and waste disposal plant.
And I feel
7
this i. a total desecration"of both Catholic and
8
Protestant cemeteries.
And I feel ~hat perhaps the
9
only way to stop some of this is a civil suit on behalf
10
of some of us that have our loved ones buried there.
11
The Indians took care of their dead and
12
preserved their burial grounds.
Now, I don't think
13
it's right that -- whether our town officials, whether
14 a deal has been sealed already, I don't know, but I
15 speak very genuinely here tonight, that I think ~hat
16 Naugatuck has had enough.
17
And I hope that this 2-million -- what was
18
it?
I just wrote it down -- $2,041,000 pipe will .never
19
be built, heading to Naugatuck.
20
As far a. I'm concerned we have enough pipes
21
pointed to our town.
22
Let's see.
Also, there were a couple of
23
other things.
Oh, I didn't take it with me.
24
But there are a couple of things I'd like to
25
give to you to put in the record.
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In 1985 -- you think I'm the only one
2
complaining -- there were a group of people in that
3
Cotton Hollow area, for what reason, 1 don't kno~~ a
lot of people in Naugatuck are deathly afraid to get up
...
4
5
and speak.
Perhaps because their families work for
6
Uniroyal or for the chemical.
And that's a sad case in
7
the United States of America today, that people can't
8
come and speak.
9
Also, in 19 -- was it -- '85, there was a
10
young .an th.t died.
His name was
It was on a Friday.
11
Copeland.
He was treating some kind of affluent.
I
12 have the story right in the paper. And I don't think
13 it ever came out just what he died from. But I think
14 that he was twenty-nine years old. And I think this
15
makes us cognizant of the fact that some of that stuff
16
pouring through their pipes can be very dangerous.
17
And I just hope that you will consider
18
people like myself who have a substantial home there,
19
pay substantial taxes, have paid the like for years,
20
and I hope that you still listen to peo~!~ !i~~ ==.
21
Thank you very much.
1 appreciate it.
22
Do you want those papers ---
23
MARGARET LESHEN:
Sure.
24
ERIC VAN GESTEL:
Sure.
2S
DOROTHY MASON:
--- for evidence?
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1 The next person is Brian Fitzpatrick.
2 FROM THE FLOOR. He'. not here.
3 MARGARET lESHENI Has Ray decided he ~ants
4 to make any comment?
5 DOROTHY MASON I Here you go, dear. You
6 should read that.
o
7
MARGARET lESHEN.' Does anyone -- thank you.
8
DOROTHY MASON I
This is 1995 and I think you
9
should really read that.
10
And that man had just spoke to us the night
11
before he was killed, telling some us that if we were
12
interested in the Laurel Park Landfill, but we didn't
13
have anything to worry about.
14
I submit that.
Thank you.
,s
MARGARET LESHEN:
ThAnk you.
16
Would anyone else like to make a comment
17
tonight into the record?
18
GARY WOODFIELD:
Attorney Gary Woodfield for
19
the Town of Naugatuck, for the Borough of Naugatuck.
20
And jv~t briefly, ~e've had -- again, I've
21
met with Eric in the past with regard to the Borough
22
accepting the leachate in the future.
23
And the Borough, I think it came out
24
incorrectly, prior, 8. far 85 what the Borough would be
25
willing to do if the leachate were accepted into
APEX REPORTING
Registered Professional Reporters
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18
1
Naugatuck.
2
What was not emphasized was the fact that
3
the Borough is very concerned with the people of. .
4
Naugatuck and the environmental effect of bringing the
5
leachate to Naugatuck.
6
Mrs. Mason very eloquently stated the fact
7
of the stench that currently exists with the water
8
treatment facility.
9
But currently from the Laurel Park site, .
10
approximately 1 percent of what is being brought to the
11
water treatment company is the leachate from Laurel
12
Park.
80 that if there is a problem with the water
13
treatment facility's aromas or whatever, I don't think
14
that the leachate from Naugatuck, the Laurel Park site
15
has really an impact on that.
And the Beacon Heights
16
leachate is even a le.ser extent, by about one-tenth of
17
what -- or Eric may be able to expound on that or
18
someone from the treatment company.
19
But current, the effect of what the leachate
?"
or th~ e:.~unt of leachate that is coming from Laurel
21
Park and in the future, if it does come from Beacon
22
Heights, is of very minimal impact to the Borough
23
of Naugatuck, in particular, the water treatment
24
facility.
25
And with regard to the cemeteries, if the
APEX REPORTING
Registered Professional Reporters.
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"
,>
"
19
.".
1
leachate does come to Naugatuck, it would be through
2
the sewer system, which is below ground and is
3
currently below Route B.
And I don't know of r.~lly
4
any major impact ~hat it will have in that area.
5
There is a concern .that we have in Cotton
6
Hollow and at Cross street.
Obviously, there are
7
people living there.
And we, in our negotiations with
8
the Beacon Heights Coali~ion, that was one of our major
9
is that this is handled properly.
concerns,
10
With regard to what has happened with
11
this gentlemAn who was twenty-nine years old, I
12
think -- well, I'd rather not get into that part 01
13
it.
14
The Borough of Naugatuck, for the record,
15
would be willing to accept the leachate, subject to a
16
quite extensive list that we have forwarded to the
17
Beacon Heights Coalition, and the priority of which is
18
the protection of human li1e and to ensure that all
19
environmental impacts are handled properly.
20
Thank you.
21
MARGARET LESHEN:
Thank you.
22
Would anyone else like to make a comment?
23
Seeing that there are no further comments, I
24
would like to close the hearing.
J'
25
We'll be staying around to answer any
APEX REPORTING
Registered Professional Reporters
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-'
20
1
questions if people have them.
2
As I was saying .arlier, we encourage you to
3
submit written comments, especially if you didn'~ .
4
present anything tonight.
And they will be accepted in
5
our office.
They should be addressed to Eric Van
6
Gestel.
They need to be received in our office by
7
July 9th, as we were saying:
8
After he receives all the comments, we will
9
be preparing a document called the Record of Decision,
10
which will document our decision.
And it will be based
11
on public comments and any new information that has
12
been raised during the comment period.
13
The decision document will have appended to
14
it responses to comment in a document called the
15
Responses of Summary.
16
You will become aware of these documents
17
through a press release and they can also be obtained
18
-- at the Selectmen's Office we have a repository of
19
all the documents, as well as our office in Canal
20
Street.
21
If you have any questions at any time, feel
22
free to call Eric.
His number is on the back of the
23
fact sheet, if you need any information or you have a
24
question.
25
I don't hear any further comments.
We will
APEX REPORTING
Registered Professional Reporters
(617)416-3077
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21
1 close the hearing.
2 [Whereupon, at BIOS p.m., May 30, 1990, the
3 above matter was concluded.]
<> 4
5
" 6
7
8
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25
APEX REPORTING
...." /' Registered Pro1essional Reporters
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..,.-.
"..:;.
CERTIFICATE OF REPORTER AND TRANSCRIBER
1
2
This is to certify that the attached proceedings
3 before: U.S. ENVIRONMENTAL PROTECTION AGENCY
4 in the Matter of:
5
PUBLIC HEARING
6 SUPERFUND PROGRAM
7 BEACON HEIGHTS LANDFILL SIT~
BEACON FALLS, CONNECTICUT
8
9
10
Place:Beacon Falls, Connecticut
11
Date: May 30,
1990
12 were held as herein appears, and that this is the true,
13 accurate and complete transcript prepared from the notes
14
and/or recordings taken
of the above entitled proceeding.
15
16
L. Marshak
17 Repclr ter
18 N. Beecroft
Transcriber
19
5-3(1-90
Date
6-6-St(>
Date
20
21
22
23
24
25
-~.J
APEX REPORTING
Registered Professional Reporters
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. SEN7 BY:D. E. P. waste Bureau
: 8-28-80 ;.3:'OPM :
203566182e~
617 565 '141:' 2
"'.. . -..
STATE OF CONNECTICUT
.DEPARTMENT OF ENVIRONMENTAL PROTECTION
e
S.p~.mb'r 28. 1180
("
H.. Julie B.laga
blional Ad.mW.trator
u.s. IPA 18110n 1
J.r.K. r,deral lui1dinl
BOlton. KA 02203
. Dear X.. I.lagla
The Cormecticut Department of InviroMental Protection bioi revi."ed tb.e
supplemlntal &Icord of Dlct.ion of remedial alternative. for the Beacon B'ishta
Landfill. fhi. letter reiterate. the departm.nt" position a. identified in my
previou. eorre.pondance dated July 8. 1880. .
!hI department .upport. the lel,cted alternative £0: leachate treatment and
dhpol&l and for continued monitorinl and Ivaluation. of the landfill la....
upon completion of the cap. .
. Bovev.r. the department blliev.. that .0111. of the water qualit, loall u.'d
to ntablbh loi1 cleanup 18vell are. 1ncondlunt "ith Connecticut Action
Lev.lI for contamina1\tI in drink1ng water and Connecticut" Wattr ~11ty
Standardl. Connlcticut b.al nt Action Levell for contaminantl in c!r1l\kina
watar that ar. equivalent to 0: more Itrinaent than fed.ral ddnkinl wat.r
Itandard.. AI thea. Itandard. havi b..n Iitablilh.d by the Connecticut
. Departm.nt of Health Service. and have been timely and conli.tlntly applied by
both the Department8 of Health S.rvic.. and Environmental 'rotact1on. thl State
contendl that th... Action Levell ,hou14 be considered AlAI..
AdcHtionally. the .tate' I adopted and federally approved watlr quality
Itandard. cla..if, the Iround water at the tit. a. ~B/QA. thl loa1 beina GA.
Thit loal cla..ification requir.. action necu.ary to allure that the wat.rs
art luitable for drinking without fte'lS for tr'atmlnt. . It further require. that
~. vatl: quality be fret from pollutant. other than tho.. naturally occurring
and that chemical conltituentt b. lubject to .tate and federal luidelin.. and
Idvl.oriel. The loal GA raquire. c1.anup to mIlt thl, .tan4ard. Thl .t.nd.rd.
furthlr limit the tou:ce. of di.charat which would be permitted within thl area
clauified and would prlcludt nlw landfillt. leachate ditcharae. and othlr
chemical dilcharl".
!o mitt the.. GA Itandar41. the d.partment hat requirld removal of
contaminated .oi1. to the drinkina .ater ttandard llva1 or the in8tallation of
collection and treatment t,lum. a. wIll a. providinl an alternativ. .ater
lupply to all per.on. poten~ially affecttd by the contm.inatt4 loil 1..chtl1a.
In cu.. "hlre toxicity 1mpactl on lurfact water "ould be :lali&14 from the
lite be,ond drinkina .aur .tandard levtlt. additional controll. or rlmoval
would b. required. .
(PriAt8d 01\ Rcyc18d Paper)
165 CapIto! AY8DUI . Hartford. CT 06106
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~~N I D 1 . LJ. c;. r.
"Q.,."" ",WI ........
.. . .. ,
. .
LTll Beacon Beiiht8
Supplemental ROD
'a8e 2
September 28. 1990
.,
I
"
Laavina .011. in plac. at 100 timl' the drink1na water .tandard. at thil
lit. i. !neon,lltent with the GA 8tandard bleau.. there art DO planned control.
aver the around water plume movemlnt, fQr further mlalur.. to collict and treat
ccmtaminanu d.riv.d from tho.. '0111. or oap the 8011., and no propolal to
1.lurl alternativi wattr lupplil.. . .
Althouah the Ii.partm.nt aare.. tbat 8zcavat.lou of contaminatld .0Ua ,it
n.e"lary to protlet. human h.altb and the Invironment, we cannot eoneur with I
.oil remediation loal that would have contaminat.ed loill 11ft in plael at the
.it..
'iJ
'.
il
i
Sinelrely,
~C~~
L..111 Caroth.rl
Commb .ioner
LAC liMP I It
i'
j:
! I
I
I
I
-
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o
Introduction
o
This document is the index to.the Administrative Record for
the Beacon Heights Landfill National Priorities List (NPL) site.
section I of the index cites site-specific documents, and section
II cites guidance documents used by EPA staff in selecting a
response action at the site.
The Administrative Record is available for public review at
EPA Region I's Office in Boston, Massachusetts, and at the Beacon
Falls Town Hall, 10 Maple Avenue, Beacon Falls, Connecticut,
06403. This Administrative Record includes, by reference only,
all documents included in the June " 1'88 Administrative Record
(september 23, 1985 Record of Decision) for this NPL site.
Questions concerning the Administrative Record.should be
addressed to the EPA 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 Reauthorization Act
-------
Volume Z
Beacon Height. Landfill
NPL site Administrative Record
~able of Content.
"
1.0
Pre-Remedial
1.3
3.0
Remedial Investigation
Site Inspection
3.9
Health Assessments
4.0
Feasibility study (FS)
4.1
4.6
4.9
Correspondence
Feasibility study (FS) Reports
Proposed Plans for Selected Remedial Action
5.0
Record of Decision (ROD)
5.1
5.2
5.3
5.4
Correspondence
Applicable or Relevant and Appropriate
Requirements (ARARs)
Responsiveness Summary
Record of Deci$ion (ROD)
6.0
Remedial Design (RD)
6.1
VOLma: II
6.4
VOLt7KE III
6.4
VOLt7KE IV
6.4
Correspondence
Remedial Design Documents (continued)
Remedial Design Documents (continued)
-------
Beacon Heights Landfill
NPL site Administrative aecord
~able of Contents (continued)
()
VOLUHE V
6.6
Work Plans and Progress Reports
o
10.0 Enforcement
10.8 EPA Consent Decree
10.9 Pleadings
13.0 Community Relations
13.3 News Clippings/Press Releases
13.4 Public Meetings
13.5 Fact Sheets
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..
SECTION I
-------
ADMINISTRATIVE RECORD INDEX
for the
Beacon Heights Landfill NPL site
1.0
Pre-Remedial
1.3
Site Inspection
<.)
1.
o
"Potential Hazardous Waste site - Site Inspection
Report - Betkoski Dump," EPA Region X (March 25,
1986).
3.0
Remedial Investigati~n (RI)
3.9
Health Assessments
1.
"Health Assessment for Beacon Heights Landfill
National Priorities List (NPL) Site," u.S. .
Department of Health and Human Services, Agency
for Toxic Substances and Disease Registry (AT5DR)
(January 26, 1989).
4.0
Feasibility study (FS)
4.1
correspondence
1.
2.
Letter from Eric van Gestel, EPA Region I to
Leonard D'Amico, Town of Beacon Falls (April 24,
1990). Concerning an invitation to meet prior to
Proposed Plan Public Meeting to discuss critical
issues.
Letter from Eric van Gestel, EPA Region I to Doug
Ritchie, Naugatuck Treatment Company (April 25,
1990). Concerning an invitation to meet prior to
Proposed Plan Public Meeting to discuss critical
issues.
4.6
Feasibility Study (F5) Reports
1.
Cross-Reference: "Pre-Design Studies - Revision
2," Canonie Environmental Services Corp. for
Beacon Heights Generators Coalition (March 1990)
[Filed and cited as entry number 3 in 6.4 Remedial
Design Documents].
Letter Report from Francis C. Sampson,. Fuss and
O'Neill to Robert F. Carter, Carter, Rubenstein &
Civitello (attorney for the Town of Beacon Falls)
(June 27, 1990). Concerning Beacon Heights
Landfill Leachate Treatment (CONFIDENTIAL).
2.
-------
4.9
Proposed Plans for Selected Remedial Action
Reports
1.
"EPA Proposes Supplemental Cleanup Plan to Address
Leachate Treatment and Disposal at the Beacon
Heights Landfill Site," EPA Region I (May 1990).
Comments
~
2.
Letter from Brian D. Fitzgerald, Waste Water
Treatment Plant Superintendent, Town of Beacon
Falls, Connecticut to EPA Region I (May 9, 1990).
Letter from Nicholas J. Harding, Adams' Harding
to William A. Butler, Dickstein, Shapiro' Morin
(May 15, 1990). concerning comments on the
Proposed Plan.
Cross Reference: Letter from Donna Civitello,
Carter, Rubenstein' Civitello (attorney for the
Town of Beacon Falls) to Eric van Gestel, EPA
Region I (May 25, 1990). Concerning request to
extend the public comment period on the Proposed
Plan. [Filed and cited as entry number 1 in 5.1
Correspondence].
Letter from Wilfred Swan, Beacon Falls Resident
to Eric van Gestel, EPA Region I (May 30, 1990).
Concerning comments on the Proposed Plan.
Letter from Oliver P. Wesley, Canonie
Environmental to Eric van Gestel, EPA Region I
(July 6, 1990). Concerning comments on the
Proposed Plan. with attached:
A: Letter from Oliver P. Wesley, Canonie
Environmental to Russell Bartley, Wehran
Enginnering Corp. (May 22, 1990). Concerning
response to comments on the Beacon Falls
Publicly Owned Treatment Works.
B: Letter from Oliver P. Wesley, Canonie
Environmental to Russell Bartley, TRC
Environmental Consultants (February 9, 1990).
concerning technical evaluation of the
treatment of leachate from the Beacon Heights
Landfill.
Letter from Leslie Carothers, Commissioner,
Connecticut Department of Environmental Protection
to Eric van Gestel, EPA Region I (July 9, 1990).
Concerning the State of connecticut's comments on
the Proposed Plan.
Letter from Nicholas J. Harding, Adams' Harding
to Eric van Gestel, EPA Region I (July 9, 1990).
Concerning comments on the Proposed Plan.
3.
4.
5.
6.
7.
8.
-------
4.9
"
I)
Proposed Plans for Selected Remedial Action (continued)
Comments (continued)-
9.
Letter from Dorothy (Mrs. Edward J.) Mason, Beacon
Falls Resident to Eric van Gestel, EPA Region I.
Concerning comments on the proposed supplemental
cleanup plan. With attached:
A: Letters to the Editor - "Who's Minding
Leachate Decisions?" Dorothy Mason, Naugatuck
Resident - Naugatuck Daily News, Naugatuck,
Connecticut.
B: Letter from Richard F. Meagher, Catholic
Cemetaries Association of the Archdiocese of
Hartford, Inc. "to Dorothy Mason (March 21,
1990). Concerning odors affecting st. James
Cemetery.
C: "Man Killed At Chemical" - Naugatuck
Daily Nevs, Nauqatuck, Connecticut (July 27,
1990).
D: MOdor Bothers Area" - Naugatuck Daily
News, Naugatuck, Connecticut (July 23, 1985).
E: "Uniroyal High In Toxic Releases" -
Naugatuck Daily News, Naugatuck, Connecticut
(January 19, 1990).
F: "Borough Renews Uniroyal Pact" -
Naugatuck Daily News, Naugatuck, Connecticut
(June 26, 1990).
5.0
Record of Decision (ROD)
5.1
correspondence
1.
Letter from Donna Civitello, Carter, Rubenstein &
Civitello (attorney for the Town of Beacon Falls)
to Eric van Gestel, EPA Region I (May 25, 1990).
Concerning request to extend the public comment
period on the Proposed Plan.
Letter from Donna Civitello, Carter, Rubenstein &
civitello (attorney for the Town of Beacon Falls)
to Julie Taylor, Office of Regional counsel,
EPA Region I (June 29, 1990). Concerning
provisional acceptance of leachate at the Beacon
Falls POTW.
Letter from Donna Civitello, ~arter, Rubenstein &
Civitello (attorney for the Town of Beacon Falls)
to David E. Rosengren, Pepe & Hazard (attorney for
the Beacon Heights Coalition) (July 13, 1990).
Concerning terms and conditions to be met by the
Beacon Heights Coalition before the town POTW will
accept leachate from the Beacon Heights Landfill.
2.
3.
-------
5.1
5.2
5.3
5.4
Correspondence (continued)
Letter from Thomas F. Harrison, Beacon Heights
Coalition to Donna Civitello, Carter, Rubenstein &
Civitello (attorney for the Town of Beacon Falls)
(July 26,1990). Concerning response to the
letter of July 13, 1990 from Donna Civitello
regarding the Beacon Heights Leachate Treatment
Proposal.
Letter from Robert F. Carter, Carter, Rubenstein &
Civitello (attorney for the Town of Beacon Falls)
to Thomas F. Harrison, (attorney for Beacon
Heights Coalition) (September 12, 1990).
Concerning terms and conditions to be met by the
Beacon Heights Coalition before the town POTW will
accept leachate from the Beacon Heights Landfill.
Letter from Thomas F. Harrison, (attorney for
Beacon Heights Coalition) to Robert F. Carter,
Carter, Rubenstein & Civitello (attorney for the
Town of Beacon Falls) (September 17, 1990).
Concerning terms and conditions to be met by the
Beacon Heights Coalition before the town POTW will
accept Leachate from the Beacon Heights Landfill.
Applicable or Relevant and Appropriate Requirements
(~s)
4.
5.
g
Q
6.
1.
Cross-Reference: Letter from Leslie Carothers,
Commissioner, Connecticut Department of
Environmental Protection to Julie Belaga, EPA
Region I (September 28, 1990). Concerning
Connecticut Department of Environmental
Protection's concurrence with EPA Region 1's
Remedial Action remedy selection for the Beacon
Heights Landfill Site, including the State's
requirements for concurrence. [Filed and cited as
entry number 1 in 5.4 Record of Decision (ROD) as
Appendix D).
Responsiveness Summaries
Cross-Reference: "Responsiveness Summary, Beacon
Heights Landfill Superfund site, Beacon Falls,
Connecticut," EPA Region I (September 28, 1990).
[Filed and cited as entry number 1 in 5.4 Record
of Decision (ROD) as Appendix C).
Record of Decision (ROD)
1.
1.
"Beacon Heights Landfill
Decision, Beacon Heights
Falls, New Haven County,
I (September 28, 1990).
Supplemental Record of
Site, Town of Beacon
Connecticut," EPA Region
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6.0
Remedial Design
6.1
,-'
6.4
(;
Correspondence
Letter from Geoff McGean, EPA Region I to Russell
W. Bartley, TRCEnvironmental Consultants, Inc.
(December 9, 1988). Concerning final approval of
the Beacon Heights Pre-Design Work Plan.
Remedial Design Documents
1.
Reports
..
~.
"Pre-Design studies," Canonie Environmental
Services Corp. for Beacon Heights Coalition (July
1989).
"Pre-Design studies - Revision 1," Canonie
Environmental Services Corp. for Beacon Heights
Coalition (December 1989).
"Pre-Design Studies - Revision 2," Canonie.
Environmental Services Corp. for Beacon Heights
Coalition (March 1990).
"Evaluation of Leachate '1'reatment Alternatives,"
Canonie Environmental Services Corp. for Beacon
Heights Coalition (May 1990).
2.
3.
4.
Correspondence
5.
Letter from Merrill S. Hohman, EPA Region I to
Russell W. Bartley, TRC Environmental Consultants,
Inc. (November 9, 1989). Concerning EPA comments
on the July 1989 "pre-Design Studies," Canonie
Environmental services Corp. for Beacon Heights
Generators Coalition.
Letter from Eric van Gestel, EPA Region I to
Russell W. Bartley, TRC Environmental Consultants,
Inc. (January 10, 1990). Concerning pre-design
studies and the Beacon Falls POTW.
Letter from Merrill s. Hohman, EPA Region I to
Russell W. Bartley, TRC Environmental Consultants,
Inc. (February 14, 1990). Concerning EPA comments
on the December 1989 "Pre-Design studies," Canonie
Environmental Services Corp. for Beacon Heights
Generators Coalition. .
Letter from Eric van Gestel, EPA Region I to
Russell Bartley, Wehran Engineering corporation
(April 19, 1990). Concerning compilation of nine
evaluation criteria for evaluating remedial
alternatives.
6.
7.
8.
-------
Work Plans and Progress Reports
Reports
6.6
"Pre-Design Work Plan and Project Operation Plan,"
Canonie Environmental Services Corp. for Beacon
Heights Generators Coalition (November 1987).
Comments
1.
2.
3.
Comments Dated January 20, 1988 from Karl W.
Novak, EPA Region I on the November 1987
"Pre-Design Work Plan and Project Operation Plan,"
Canonie Environmental Services Corp. for Beacon
Heights Generators eoalition.
Comments Dated November 14, 1988 from Geoff
McGean, EPA Region I on the November 1987
"Pre-Design Work Plan and Project Operation Plan,"
Canonie Environmental services Corp. for Beacon
Heights Generators Coalition.
Responses to Comments
4.
5.
10.0 Enforcement
Response Dated February 26, 1988 from Oliver P.
Wesley, Canonie Environmental Services Corp. on
the January 20, 1988 Comments from Karl W. Novak,
EPA Region I.
Response Dated December 5, 1988 from Oliver P.
Wesley, Canonie Environmental Services Corp. on
the November 14, 1988 Comments from Geoff McGean,
EPA Region I.
10.8 EPA Consent Decrees
Amended Consent Decree, United states of America
v. The B.F. Goodrich ComDanv et al., United states
District Court for the District of Connecticut,
(Civil Action No. N-87-286 (PCD» (September 15,
1987) with "Appendix A - Remedial Action Plan".
10.9 Pleadings
1.
1.
Ruling on Motion for Order in Aid of Access and
for Preliminary Injunction, The B.F. Goodrich
ComDanv et a1. v. Harold Murtha. et a1.; uniroval
Chemical ComDanv Inc. v. Harold Murtha. et al.:
united States of America v. Harold Murtha. et al.:
State of Connecticut v. Harold Murtha. et al.,
United States District Court for the District of
Connecticut, (Civil Action No. N-87-52, -67, -74,
&-73) (PCD) (October 24, 1988).
-------
10.9 Pleadings (continued)
2.
L,
()
Order, The B.F. Goodrich ComDanv et ale v. Harold
Murtha. et al.: Uniroyal Chemical ComDanv Inc. v.
Harold Murtha. et al.: United states of America v.
Harold Murtha. et al.: state of Connecticut v.
Harold Murtha. et al., United states District
Court for the District of connecticut, (Civil
Action No. N-87-52,-67,-74,&-73) (PCD) (October
24, 1988).
13.0 Community Relations
13.3 News Clippings/Press Releases
"Environmental News - Cleanup Plan for Beacon
Heights Superfund site Announced," EPA Region I
(September 23, 1985).
"Environmental News - EPA Issues Administrative
Order," EPA Region I (october 6, 1986).
"Environmental News - EPA Obtains Warrant for
Access to Beacon Heights Landfill," EPA Region I
(July 1, 1987).
"Environmental News," EPA Region I (July 8, 1987).
"Environmental News - EPA Announces Public Meeting
on Beacon Heights Site," EPA Region I (August 12,
1987).
"Environmental News - Court Orders Waste site
Owners to Allow Cleanup to Start," EPA Region I
(November 4, 1988).
"The u.s. Environmental Protection Agency
Announces the Availability of the Administrative
Record for the Beacon Heights Landfill Site,"
Naugatuck News - Naugatuck, Connecticut (December
12, 1988).
"Environmental News - EPA to Hold Meeting on
Beacon Heights Cleanup Plan," EPA Region I (April
27, 1990).
"Environmental News - EPA Extends Comment Period
on Beacon Heights Cleanup Plan," EPA Region I
(June 5, 1990).
13.4 Public Meetings
1.
2.
3.
4.
5.
6.
7.
8.
9.
1.
"Summary of the Public Informational Meeting on
the Proposed Plan for the Beacon Heights Landfill
Superfund Site," EPA Region I (May 9, 1990).
Cross-Reference: Transcript, Public Hearing (May
30, 1990) [Filed and cited as entry number 1 in
5.4 Record of Decision (ROD)in Appendix C as
Attachment A].
2.
-------
13.5 Fact Sheets
1.
"Superfund Program Information Update - EPA
Cleanup Activities Underway," EPA Region I (August
1987). .
"EPA Information Update - Beacon Heights Landfill
Superfund Site," EPA Region I (July 1988).
Concerning update of waterline and landfill cap
activities. .
2.
~
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\,
o
SECTION :II
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GUIDANCE DOCUMENTS.
EPA guidance documents may be reviewed at EPA Region I, Boston,
Massachusetts. .
General SPA Guidance Documents
1.
2.
3.
4.
5.
u.s. Environmental Protection Agency. Office of Research
and Development. Municipal Environmental Research
Laboratory. Biodearadation and Treatabilitv of SDecific
Pollutants (EPA-600/9-79-034), October 1979. [c007]
U.S. Environmental Protection Agency. Office of Research
and Development. Municipal Environmental Research
Laboratory. Carbon Adsorotion Isotherms for Toxic Oraanics
(EPA-600/8-80-023), April 1980. [2301] .
q
c
u.s. Environmental Protection Agency. Office of Research
and Development. Municipal Environmental Research
Laboratory. Handbook for Evaluatina Remedial Action
Technoloav Plans (EPA-600/2-83-076), August 1983. [2307]
U.S. Environmental Protection Agency. Office of Emergency
and Remedial Response. Community Relations in SUDerfund:
Handbook (Interim Version) (EPA/hw-6), september 1983.
A
u.s. Environmental Protection Agency. Office of Ground-
Water Protection. Ground-Water Protection strateav, August
1984. [2403]
6.
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-504/2-84-003a),
September 1984. [2316]
7.
"Guidelines Establishing Test Procedures for the
pollutants Under the Clean Water Act: Final Rule
Final Rule and Proposed Rule" (40 CFR Part 136),
Reaister, October 26, 1984. [C036]
Analysis of
and Interim
Federal
8.
u.s. Environmental Protection Agency. Office of Emergency
and Remedial Response. Hazardous Response support Division.
Standard Operating Safety Guides, November 1984. [c082]
9.
"National oil and Hazardous Substances Pollution contingency
Plan," Code of Federal Re9Ulations (Title 40, Part 300),
1985.
10.
u.S. Environmental Protection Agency. Office of Emergency
and Remedial Response. ~dance Document for CleanuD of
Surface Tank and Drum sites (OSWER Directive 9380.0-3), May
28, 1985. [2306]
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General EPA Guidance Documents (continued)
11.
12.
o
D
13.
14.
15.
16.
17.
18.
19.
20.
U.S. Environmental Protection Agency. Office of Solid Waste
and Emergency Response. Guidance on Feasibilitv Studies
under CERCLA (ComDrehensive Environmental ReSDonse.
ComDensation. and Liabilitv Act) (EPA/540/G-85/003), June
1985. [c034]
U.S. Environmental Protection Agency. Office of Solid Waste.
and Emergency Response. Guidance on Remedial Investiaations
under CERCLA (Comprehensive Environmental ReSDonse.
Compensation. and Liabilitv Act) (EPA/540/G-85/002), June
1985. [c035]
Memorandum from Gene Lucero to the U.S. Environmental
Protection Agency, August 28, 1985 (discussing community
relations at Superfund Enforcement sites). [c053]
U.S. Department of Health and Human Services. National
Institute for Occupational Safety and Health, and
Occupational Safety and Health Administration. OccuDational
Safety and Health Guidance Manual for Hazardous Waste Site
Activities, October 1985. [c065)
u.S. Environmental Protection Agency. Office of Research
and Development. Hazardous Waste Engineering Research
Laboratory. andbook: emedia1 ction at Waste is osa1
sites (Revised) (EPA/625/6-85/006), October 1985. [2309)
U.S. Environmental Protection Agency. Office of Emergency
and Remedial Response. Communitv Relations in SUDerfund:
Handbook (Interim Version) (EPA/HW-6, OSWER Directive
9230.0-3A) March 1986.
A
U.S. Environmental Protection Agency. Office of Research
and Development. Hazardous Waste Engineering Research
Laboratory. Treatment Technoloav Briefs: Alternatives to
Hazardous Waste Landfills (EPA/600/S-86/017), July 1986.
[2320]
u.s. Environmental Protection Agency. Office of Solid Waste
and Emergency Response. ~le Treatment Technoloaies for
SUDerfund Wastes (EPA 540/2-86/003 (f», September 1986.
[2311]
u.S. Environmental Protection Agency. Office of Emergency
and Remedial Response. Draft Guidance on Remed~al Actions
for contaminated Groundwater at SUDer fund Sites (OSWER
Directive 9283.1-2), September 20, 1986. [c022]-
u.S. Environmental Protection Agency. Office of Emergency
and Remedial Response. SUDer fund Public Health Evaluation
Manual (OSWER Directive 9285.4-1), October 1986. [5014]
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. .
General EPA Guidance Documen~B (con~inued)
21.
22.
23.
24.
25.
26.
27.
28.
Comprehensive Environmental Response. compensation. and
Liabilitv Act of 1980, amended October 17, 1986. [co18]
-Hazardous Waste Management systems Land Disposal
Restrictions Final Rule," (November 1986), 40 CFR Part 260
Et Al. [c103]
u.s. Environmental Protection Agency. Office of Emergency
and Remedial Response. Superfund Federal-Lead Remedial
proiect Management Handbook (EPA/540/G-87/001, OSWER
Directive 9355.1-1), December 1986. [2010]
U.S. Environmental Protection'Agency. Office of Solid Waste
and Emergency Response. Interim Guidance on Superfund
Selection of Remedv (OSWER Directive 9355.0-19), December
24, 1986. [9000)
"
u.s. Environmental Protection Agency. Office of Research
and Development. Hazardous Waste Engineering Research
Laboratory. Technologv Briefs: Data Reauirements for
Selectinq Remedial Action Technoloav (EPA/600/2-87/001),
January 1987. [c088)
u.s. Environmental Protection Agency. Office of Solid
and Emergency Response. Data Oualitv Obiectives for
Remedial Response Activities: Development Process
(EPA/540/G-87/003), March 1987. [2101)
Waste
Letter from Lee M. Thomas to James J. Florio, Chairman,
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 S~perfund Amendments and
Reauthorization Act of 1986). [c044]
Memorandum from J. Winston Porter to Addressees ("Regional
Administrators, Regions I-Xi Regional Counsel, Regions I-Xi
Director, Waste Management Division, Regions I, IV, V, VII,
and VIII: Director, Emerqency and Remedial Response
Division, Region IIi Director, Hazardous Waste Management
Division, Regions III and VIi Director, Toxics and Waste
Management Division, Region IX: Director, Hazardous Waste
Division, Region Xi Environmental Services Division
Directors, Region I, VI, and VII"), July 9, 1987 (discussing
interim guidance on compliance with applicable or relevant
and appropriate requirements). [C055]
29.
U.S. Environmental Protection Agency. Office of Emergency
and Remedial Response. A Compendium of Superfund Field
operations Methods (EPA/540/P-87/001, OSWER Directive
9355.0-14), December 1987. [2100]
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General EPA Gui~ance Documents (continue~l
30.
31.
tv
32.
"
33.
34.
35.
36.
u.s. Environmental Protection Agency. Interim Guidance on
PotentiallY Responsible Party ParticiDation in Remedial
Investiaations and Feasibility Studies (OSWER Directive
9835.1a) (May 1988).. [8001)
u.s. Environmental Protection Agency. Office of Emergency
and Remedial Response. Community Relations in SUDerfund: A :
Handbook (Interim Version) (EPA/HW-6, OSWER Directive
9230.0-03B) (June 1988). [7000]
"Catalog of Superfund Program Directives," (July 1988),
OSWER '9200.7-01. [co12)
"CERCLA Compliance with other Laws Manual, Draft Guidance,"
(August 1988), OSWER '9234.1-01. [3002]
u.s. Environmental Protection Agency. Office of Emergency
and Remedial Response. Guidance for Conductina Remedial
Investiaations and Feasibility studies Under CERCLA
(EPA/540/G-89/004, OSWER Directive 9355.3-01) (October
1988). [2002)
u.s. Environmental Protection Agency. Office of Emergency
and Remedial Response. Determinina Soil ReSDonse Action
Levels Based on Potential contaminant Miaration to
Groundwater: A Compendium of Examples (EPA/540/2-89/057)
October 1989. [c133)
U.S. Environmental Protection Agency. Office of Emergency
and Remedial Response. Personnel Protection and Safety.
[c071]
Beacon Hei9hts NFL site SDecific Gui~ance Documents
1.
"The Designated Level Methodology
and Cleanup Level Determination",
California Regional Water Quality
1987.
for Waste Classification
Jon B. Marshack,
Control Board, 23 April
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