United States
        Environmental Protection
        Agency
               Office of
               Emergency and
               Remedial Response
EPA/ROD/R01-91/054
March 1991
EPA
Superfund
Record of Decision

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50272.101
REPORT DOCUMENTATION 1'. REPORTNO.
PAGE EPA/ROD/ROl-91/054
I ~
3. RecIpient. Acc:eaalon No.
4. TIle 8nd SubtIle
SUPERFUND RECORD OF DECISION
Mottolo Pig Farm, NH
First Remedial Action - Final
7. Author(a)
5. Report Date
03/29/91
6.
8. Perfonnlng Organization Rept. No.
8. Pwfonnlng Orgalnlzatlon Nama and Add-
10. ProjectlTaaklWortI Unit No.
l,
11. Contr8ct(C) or GrIlJ1t(G) No.
(C)
(G)
12. ~ng Orglll1lz8llon Nama 8nd AddreM
U.S. Environmental Protection
401 M Street, S.W.
Washington, D.C. 20460
13. Type of Report . Period Covared
Agency
800/000
14.
15. SupplemenWy No,"
16. Abenct (UmIt: 200 _nla)
The 50-acre Mottolo Pig Farm site is in Raymond, New Hampshire. Surrounding land is
primarily rural residential and undeveloped. The site includes a wooded area, an
inactive piggery area comprised of several structures, a building drum disposal area,
and wetlands. An onsite brook (Brook A) originating in the wetlands discharges into
the Exeter River. Prior to 1975, a piggery operation was located on site. From 1975
to 1979, the owner disposed of 1,600 drums and pails containing hazardous wastes in a
disposal area north of the piggery building, and subsequently filled in the area. In
1979, the State identified onsite buried drums some of which were crushed and leaking.
Consequently in 1980, EPA began excavation and staging of these drums. From 1981 to
1982, EPA removed and characterized drummed waste, then transported the waste offsite
along with 160 cubic yards of contaminated soil, drum parts, and plastic sheeting.
The area was then regraded and seeded. This Record of Decision (ROD) addresses
contaminated onsite soil, debris, and the associated ground water plume. The primary
contaminants of concern affecting the soil, debris, and ground water are VOCs
including TCE, toluene, vinyl chloride, and xylenes; and metals including arsenic.
(See Attached Page)
17. Docunent Analyllia L DncrIptora
Record of Decision - Mottolo Pig Farm, NH
First Remedial Action - Final
Contaminated Media: soil, debris, gw
Key Contaminants: VOCs (TCE, toluene, xylenes, vinyl chloride), metals (arsenic)
b. IdantifieralOpan-EndecI Tanna
c. COSA 11 RaIdIGrcql
18. Avlilabllty ~
18. Security CI..a (Thla Report)

None

20. Sec\8'lty CI... (Thla Page)
Nnnp
21. No. of Pagea

152
22. Price
8M ANSl-Z38.18
See IfI8trucliona on Rewl'lMl
)
(Formetfy NTl5-35)

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EPA/ROD/ROl-9l/054
Mottolo Pig Farm, NH
First Remedial Action
- Final
Abstract (Continued)
The selected remedial action for this site includes installing a ground water
interceptor trench upgradient of the former drum disposal area to reduce migration of
contaminants and facilitate treatment of contaminated soil; capping the the drum
disposal and southern boundary areas with temporary waterproof caps to improve treatment
efficiency; treating approximately 3,400-4,000 cubic yards of VOC-contaminated soil at
these areas using in-situ vacuum extraction and activated carbon to control off-gases,
followed by onsite or offsite carbon regeneration and disposal; allowing the
contaminated ground water plume to be restored through natural attenuation; monitoring
ground water and surface water; and implementing institutional controls including deed
and ground water use restrictions, and site access restrictions such as fencing. The
present worth cost for this remedial action is $690,000, which includes a present worth
O&M cost of $280,000.
PERFORMANCE STANDARDS OR GOALS: 50il cleanup levels were established to protect ground
water from soil leachate. Ground water interim cleanup levels were based on Federal
SDWA MCLs and MCLGs, or State Health Advisory Levels. The estimated time frame for the
restoration of the overburdened ground water affected by the drum disposal area soil and
the bedrock ground water affected by the southern boundary soil to acceptable levels by

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DECLARATION FOR THE RECORD OF DECISION
f)
Mottolo Superfund site
Raymond, New Hampshire
STATEMENT OF PURPOSE
'v
This Decision Document presents the selected remedial action for
the Mottolo Superfund Site in Raymond, New Hampshire, 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 (SARA),
the National oil and Hazardous Substances contingency Plan (NCP) ,
and 40 CFR Part 300 et sea., as amended. The Region I
Administrator has been delegated the authority to approve this
Record of Decision (ROD).
The State of New Hampshire concurs with the selected remedy.
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 Dudley-Tucker Public
Library in Raymond, New Hampshire, and at the Region I Waste
Management Division Records Center at 90 Canal street, Boston,
Massachusetts. The Administrative Record Index (Appendix E to
the ROD) identifies the items which comprise 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 ROD, may present an imminent and substantial
endangerment to the public health or welfare or to the
environment.
DESCRIPTION OF THE SELECTED REMEDY
The selected remedy for the Mottolo Superfund site includes both
source control and management of migration components to obtain a
comprehensive remedy.
The source control remedial measures include:
Installation of a groundwater interceptor trench upgradient
of the former disposal area. Lowering of the upgradient
overburden water table in this area will significantly
reduce groundwater flow through contaminated soils and,
accordingly, migration of contaminants from the former drum
disposal area. Dewatering will facilitate VES treatment of
that portion of contaminated soils that is currently

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2
effectiveness of source control. No dewatering will be
required for the southern boundary area since the overburden
soils remain unsaturated for most of the year.
"
.
Sealing the ground surface in both the former drum disposal
area and the southern boundary area with temporary caps
consisting of four or six-mil thick visqueen sheeting
covered with a six inch layer of seeded loam. This will
, improve the operational efficiency of the VES by limiting
short-circuit air flow from the ground surface to the
extraction wells and significantly reducing precipitation
infiltration. The caps will remain in place and be
effective for the expected operational period of the VES,
but they will not be designed to maintain their integrity on
a permanent basis.
.
Installation and operation of a vacuum extraction system
(VES) to remove air and vapor phase VOCs present in the soil
pore space (soil gas) in the former drum disposal and
southern boundary areas. VOCs sorbed onto soils will
partition from the soils into the replacement air and be
removed by the vacuum system.
The management of migration remedial measures include:
.
Natural attenuation of contaminated groundwater to lower
contaminant concentrations through physical, chemical and
biological processes until groundwater cleanup levels are
met. After completion of source remediation at each of the
two areas, no further contamination will be added to the
groundwater at levels which would prevent attainment of the
groundwater cleanup levels. It has been estimated that
overburden groundwater which has been affected by the former
drum disposal area soils will clean itself to the
groundwater cleanup levels within approximately six years
after completion of source remediation. Bedrock groundwater
should attain groundwater cleanup levels earlier. For the
bedrock groundwater affected by the southern boundary area
soil contamination (no appreciable overburden groundwater
was found in this area), approximately two years will be
needed to achieve groundwater cleanup levels.
Additional measures include:
.
A security fence consisting of approximately 1,300 linear
feet of galvanized chain link fence, ten feet high, to be
installed to control access to the former drum disposal and
southern boundary areas and to provide security for the

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3
.
Groundwater and surface water monitoring initiated during
remedial design and continuing for three years after
attaining groundwater cleanup levels to assess the
effectiveness of remediation and to confirm that contaminant
concentrations in groundwater attain cleanup levels.
.
Institutional controls to be implemented which would
restrict the use of contaminated groundwater and prevent
disturbance of on-going remedial actions. The objectives of
the institutional controls shall be to ensure that no
activities take place at the Site or in proximity to the
site which would either affect implementation of the
selected remedy or cause exposures to hazardous substances.
Examples of acceptable institutional controls include use
restrictions imposed on deeds and zoning ordinances, among
others.
DECLARATION
The selected remedy is protective of the human health and the
environment, attains federal and state requirements that are
applicable or relevant and appropriate for this remedial action,
and is cost-effective. This remedy satisfies the statutory
preference for remedies that utilize treatment as a principal
element to reduce the toxicity, mobility, or volume of hazardous
substances. In addition, this remedy utilizes permanent
solutions and alternative treatment technologies to the maximum
extent practicable.
~ lAd ~ ~
I
I qq /
r;]~ Cu' (3

~ Julie Bel~
~ Regional Administrator
u.s. EPA, Region I

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"
MOTTOLO SUPERFUND SITE
ROD DECISION SUMMARY

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D 
 I.
~ II.
.'
TABLE OF CONTENTS
. "e.'
MOTTOLO SUPERFUND SITE
RECORD OF DECISION
SITE NAME, LOCATION AND DESCRIPTION
. . . .
. . . . . .
SITE HISTORY AND ENFORCEMENT ACTIVITIES. . . . . . . .
A. Land Use and Response History 0 0 . 0 . 0 0 .
B. Enforcement History. 0 . 00 0 0 . . . 0 . .
III. COMMUNITY PARTICIPATION
IV.
V~
VI.
. . . .
. . . . . .
. 0 0
. . 0
SCOPE AND ROLE OF OPERABLE UNIT OR RESPONSE ACTION
. . 0
SUMMARY
A.
B.
C.
D.
E.
OF SITE CHARACTERISTICS
. . . . .
. . . .
000
Soil 0 0 0 0 0 0
o 0 0
. . . . .
. . . .
000
Groundwater 0 0 . . 0 0 0 0 0 0 0 0 0 0 . 0 0

Surface Water 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0


Sediment. . . . . . . . . . . . . . . . . . .


Ai r . . . . . . . . . . . . . . . . . . . . .
SUMMARY OF SITE RISKS
o 0 .
. . . .
000
.......
VII. DEVELOPMENT AND SCREENING OF ALTERNATIVES 0 0 0 0 0 0 0
A. statutory RequirementS/Response Objectives 0 0
B. Technology and Alternative Development and

screeninq 0 0 0 0 . . . . . . . . . . . . . .
VIII.
IX.
X.
XI.
DESCRIPTION OF ALTERNATIVES 0 0 0
000
. . . . . .
SUMMA~Y OF THE COMPARATIVE ANALYSIS OF ALTERNATIVES
THE SELECTED REMEDY 0 0 0 0 0 0 0 . 0 0 0 . 0 0 . 0 0 .
A. Interim Groundwater Cleanup Levels 0 . . 0 . .
B. Soils Cleanup Levels 0 0 0 0 0 0 0 0 . 0 . 0 0
C. Description of Remedial Components 0 0 0 0 0 .
STATUTORY
A.
DETERMINATIONS 0 0 . 0 . 0 0 0 0 0 0 0 0 . 0
The Selected Remedy is Protective of Human
Health and the Environment 0 0 0 0 0 0 0 0 . 0
The Selected Remedy Attains ARARs 0 0 0 0 0 0
The Selected Remedial Action is Cost-

Effective. . . . . . . . . . . . . . . . . .

The Selected Remedy utilizes Permanent
Solutions and Alternative Treatment or
Resource Recovery Technologies to the Maximum
Extent Practicable 0 0 0 . 0 0 0 0 0 0 . 0 . .
The Selected Remedy satisfies the Preference
for Treatment Which Permanently and
significantly reduces the Toxicity, Mobility
or Volume of the Hazardous Substances as a
Principal Element 0 0 . 0 0 0 . . 0 0 0 0 0 .
B.
C.
D.
E.
--
o
.
1
2
2
3
4
5
5
5
7
10
11
11
11
15
15
15
17
24
33
33
36
38
43
43
43
45
46

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XIII.
XII. DOCUM~NTATION OF NO SIGNIFICANT CHANGES
STATE ROLE
. . . .0.
. . . . . . .
APPENDICES
Figures
Tables
New Hampshire Letter of Concurrence
Responsiveness Summary
Administrative Record Index
:
. . . . .
. . .
. . . .
. . .
Appendix A
Appendix B
Appendix C
Appendix D
Appendix E
48
48

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MOTTOLO SUPERFUND SITE
ROD DECISION SUMMARY
MARCH 29, 1991
c
I.
SITE NAME, LOCATION AND DESCRIPTION
"
The Mottolo Superfund site (Mottolo site or Site) is located on
Blueberry Hill Road in southeastern Raymond, New Hampshire,
approximately two and one-half miles from. the intersection of
State Routes 101, 102 and 107. See Figure 1.
The Mottolo property is bounded on the north by a rural
residential neighborhood, on the south and east by properties
planned for residential development, and on the west by several
residences and undeveloped land. The nearest residence is
approximately 600 feet to the west. The Mottolo property
includes approximately fifty acres of primarily undeveloped,
wooded land, divided approximately in half by a brook which
originates beyond the southern property boundary and flows north
through the property, eventually discharging to the Exeter River.
The brook is hereinafter referred to as "Brook A." Approximately
two acres of the property remain cleared from the former piggery
which operated on-site. The cleared area is divided by a
drainage swale which flows from west to east, discharging to
Brook A. The former piggery is located within the southern
portion of the two-acre cleared area and was comprised of several
structures. The first structure, located along the site access
road, is an abandoned, one-story, wood and sheet metal shed which
houses a dug well and a boiler. The second structure is an
abandoned, one-story, wooden-frame building on a concrete slab,
formerly used as the main piggery building. The remaining
structures are two concrete slabs, located to the west and
southwest of the main piggery building; these slabs were
presumably the foundations for former one-story, wooden-frame
buildings that were used in the piggery operations. See Figure
2.
The Mottolo site is located within the Exeter River drainage
basin. The Exeter River nearly circumscribes the Mottolo Site.
The river is approximately 2,000 feet northwest of the Site at
its closest point. Based upon topographic and hydrologic
information, regional surface water and groundwater are
ultimately expected to discharge to the Exeter River.
Brook A is a perennial stream that flows across the Mottolo
property, draining approximately 285 acres at its confluence with
the Exeter River nearly a mile north of the Site. The headwaters
of Brook A originate in wetlands located immediately south and
southeast of the Mottolo site. A total of three acres of
wetlands were identified in the Brook A valley with approximately
50% of these found on the Mottolo property. The brook (and
wetland areas along it) is the discharge zone for local
overburden groundwater and for local bedrock groundwater, as

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2
At the base of the former disposal area, an ephemeral stream is
located in a swa1e which drains approximately four acres of the
undeveloped woodland between the cleared site area and Blueberry
Hill Road. The swa1e also receives surface water runoff from the
cleared areas to the north and south. The stream flows easterly
across the site into Brook A. Drainage patterns in the site
vicinity suggest that surface water drainage is generally toward
Brook A on either side of the brook. .
~
Overburden deposits in the upland site area consist primarily of
fine to coarse sand with pockets of gravel and generally range
from zero to fifteen feet in thickness with the thickest deposits
found at the base of the former disposal area south of the
drainage swa1e. These deposits are underlain by metamorphic and
igneous bedrock of the Merrimack Group. The shallow bedrock
appears to be only slightly weathered. The first five feet of
bedrock is typically more fractured than the next five feet.
However, some significant fracture zones may exist at depth.
A more complete description of the Site can be found in the
Remedial Investigation (RI) Report at pages 1-4 through 1-17 and
3-1 through 3-36. .
II.
SITE HISTORY AND ENFORCEMENT ACTIVITIES
A.
Land Use and Response History
Prior to disposal of hazardous substances, the site was the
location of a piggery operation. From 1975 through 1979,
the property owner disposed of approximately 1,600 fifty-
five-gallon drums and five-gallon pails containing wastes
into an approximately one-quarter acre depression located
immediately north of the main piggery building, hereinafter
termed the former drum disposal area. After dumping the
containers from the back of a truck, a bulldozer was used to
cover them with fill.
The site was discovered in April of 1979, and studies were
commenced by the New Hampshire Water Supply and Pollution
Control Commission [now the Department of Environmental
Services (NHDES)] which brought it to the attention of EPA.
In September 1980, EPA prepared the Site for exhumation,
staging, and removal of the buried drums. In 1979, the area
north of the drainage swale was cleared and graded to
construct temporary staging areas for the excavated wastes
and a berm constructed along the toe of the disposal area.
As the containers of waste were excavated, they were staged
on-site for characterization. Staging areas are shown on
Figure 2. Most of the drums appeared to be dented or
partially crushed and eighty-three fifty-five-gallon drums
and seven five-gallon pails were completely empty when
~

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3
~
exhumed. Analyses for numerous compounds including PCBs and
pesticides were conducted on samples from each container.
Toluene, xylene, and other hydrocarbons, methyl ethyl
ketone, alcohols, acetates, chromates, lead, zinc, lacquers,
turpentine, animal fats, chlorinated compounds, and packaged
laboratory chemicals were identified in drums and pails
removed from the Site. No evidence of pesticides,
herbicides, PCBs, or oils was detected.
.'
EPA did not receive funds for removal of the exhumed wastes
from the site until November 1981. Waste removal began
approximately one month later, on December 14, 1981, and was
completed on February 4, 1982. Many of the containers were
repacked into eighty-gallon recovery drums prior to
transportation off site.
Approximately 160 cubic yards of contaminated soil, drum
parts, and plastic sheeting used in the staging areas were
also transported off-site for disposal. The former disposal
area was regraded and seeded.
In January, 1985, the Site was reviewed by the EPA Field
Investigation Team (FIT) Contractor and evaluated, using the
Hazard Ranking System, for possible listing on the National
Priorities List (NPL) of sites eligible for cleanup under
the Superfund program. EPA proposed to add the site to the
NPL on April 10, 1985 (50 FR 14115), and the Site was
finally added to the NPL on July 22, 1987 (52 FR 27620).
B.
.Enforcement History
Enforcement activities were commenced shortly after
discovery of the site. The New Hampshire Attorney General
filed suit in Rockingham Superior Court (No. E-952-79) on
May 31, 1979, against Richard A. Mottolo, K.J. Quinn &
Company, Inc. (Quinn) and Lewis Chemical Company (Lewis
Chemical) for costs related to site responses. The U.S.
Department of Justice filed a complaint on September 8,
1983, against those same three defendants, as well as,
Service Pumping and Drain Company, Inc. (SPDC), the
transporter owned by Mottolo: and Carl Sutera, owner of
Lewis Chemical. The 'purpose of the United States' complaint
was to recover response costs resulting from EPA's removal
action as provided for by section 107(a) of the
Comprehensive Environmental Response, Compensation, and
Liability Act of 1980 (CERCLA), 42 U.S.C. ~9607(a). In
1985, the original complaints were amended to include
declaratory relief for future costs of remedial actions
incurred under CERCLA. A partial summary judgement
assigning joint and several liability to Mottolo, Quinn, and
SPDC for both past response and future remedial costs was
issued by the Court on August 28, 1988. The united States'
.
.

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.
4
and .the state of New Hampshire's subsequent negotiations
with Quinn have resulted in settlements of that firm's
liability for costs associated with the 1980 - 1982 removal
action, as well as, certain other response costs incurred
prior to May 1, 1988.
"
with respect to actions related to the current cleanup of
the Site, on December 29, 1987, and December 31, 1987, EPA
notified the five parties who either owned or operated the
facility, generated wastes that were shipped to the
facility, arranged for the disposal of wastes at the
facility, or transported wastes to the facility of their
potential liability with respect to the site and of EPA's
intent to begin the Remedial Investigation/Feasibility Study
(RI/FS) for the Site. Negotiations commenced with one of
these potentially responsible parties (PRPs), Quinn, on
January 15, 1988, regarding the settlement of Quinn's
liability at the Site, including Quinn's interest in
conducting the RI/FS. Substantial negotiations took place.
These negotiations resulted in the execution of an
Administrative Order by Consent between Quinn and EPA
providing for the development of the RI/FS for the Site by a
consultant under contract to Quinn.
The PRPs have not been active in the remedy selection
process for this site with the exception of Quinn and Mr.
Mottolo. Comments which were received in writing from Quinn
and Mr. Mottolo during the public comment period are
included in the Site's Administrative Record.
III. COMMUNITY PARTICIPATION
Throughout the site's history, community concern and involvement
has been moderate. EPA has kept the community and other
interested parties apprised of the Site activities through phone
conversations, progress reports, informational meetings, fact
sheets, press releases, and public meetings.
In October, 1988, EPA released a community relations plan which
outlined a program to address community concerns and keep
citizens informed about and involved in activities during
remedial activities. On september 7, 1988, EPA held an
informational meeting in the Raymond Middle School Media Center,
Raymond, New Hampshire, to describe the plans for the RI/FS. On
October 25, 1990, EPA held an informational meeting in the
Raymond Middle School Media Center, Raymond, New Hampshire, to
discuss the results of the RI.
On February 13, 1991, EPA made the Administrative Record
available for public review at EPA's offices in Boston and at the
Dudley-Tucker Library in Raymond, New Hampshire.
.-

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5
c
u
EPA publ~shed a notice and brief analysis of the Proposed Plan in
the Raymond Times on February 2, 1991, and made the plan
available to the public at the Dudley-Tucker Public Library,
Raymond, New Hampshire. On February 13, 1991, EPA held an
informational meeting to discuss the results of the RI and the
cleanup alternatives presented in the FS and to present the
Agency's Proposed Plan. Also during this meeting, the Agency
answered questions from the public.
From February 14, 1991 through March 16, 1991, the Agency held a
thirty-day public comment period to accept public comment on the
alternatives presented in the FS and the Proposed Plan and on any
other documents previously released to the public. On March 6,
1991, the Agency held an informal public hearing to discuss the
Proposed Plan and to accept any oral comments. A transcript of
this meeting is included in the attached responsiveness summary,
Appendix D.
IV.
SCOPE AND ROLE OF OPERABLE UNIT OR RESPONSE ACTION
The selected remedy was developed by combining components of
different source control and management of migration alternatives
to obtain a comprehensive approach for Site remediation. In
summary, the remedy provides for the following: fencing of a
portion of the Site: construction of a groundwater interceptor
trench and cap to isolate and dewater contaminated soils;
construction and operation of a vacuum extraction system (VES)
for treatment of contaminated soils; natural flushing of
groundwater currently contaminated by chemicals being leached
from soils: groundwater monitoring; and institutional controls to
prevent use of contaminated groundwater. This remedial action
will address the following principal threats to human health and
the environment posed by the Site: threat of contamination of a
potential water supply aquifer resulting from source area soils;
and overall threat resulting from a contaminated potential
drinking water supply.
V.
SUMMARY OF SITE CHARACTERISTICS
Chapter 2 of the FS contains an overview of the RI.
significant findings of the RI are summarized below.
The
A.
Soil
The RI determined that there are two areas of VOC-
contaminated soils which are adversely affecting the Site's
groundwater. These two areas, the former drum disposal area
and the southern boundary area, are described below.

Based upon site history and observations made during the EPA
drum removal program, the most significant releases to the
environment appear to have been from liquid wastes,
-
.

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6
primarily containing volatile organic compounds (VOCs) which
leaked from buried drums and pails in the former drum
disposal area during 1975 to 1979. The drums were excavated
during 1980, at which time releases to the area soils
ceased. Additional VOC releases may have occurred in the
vicinity of the large concrete pad west of the piggery
building (southern boundary area).

The vertical extent of soil contamination in the former drum
disposal area typically extends from two to four feet below
the ground surface to approximately the bedrock surface,
with the most contaminated soil being found near the water
table. The extent of soil contamination in the southern
boundary area is less well defined and has been arrived at
by inference from interpretation of groundwater and soil gas
data as mentioned below. The volumes of contaminated soil
within the former drum disposal area and within the southern
boundary area are estimated to be in the range of 1,400 to
1,800 cubic yards and 2,000 to 2,200 cubic yards,
respectively.
since the removal of the drums, the compounds representing
the source of the contamination in the former drum disposal
area and the southern boundary area have been, and at the
current time are, VOCs which have been adsorbed onto soil.
Since 1980, these two contaminated soils source areas have
been subjected to environmental decay. Primary soil
contamination decay mechanisms at the Mottolo Site are
groundwater flow (which dissolves and transports
contaminants from the contaminated soils), percolation
(which dissolves contaminants and transports them to
groundwater), and, to a lesser extent, volatilization (which
results in some fraction of VOCs forming a vapor phase in
unsaturated soil pore space and ultimately migrating to the
atmosphere). Because each of these decay processes result
in the reduction of contaminant mass in the source areas,
both the extent and magnitude of impacts associated with
these source areas have declined since removal of the
drummed wastes from the Site, and are expected to continue
to decline in the future.
The VOCs identified in site soils include the chlorinated
aliphatic compounds, methylene chloride,
1, 1, I-trichloroethane, trichloroethene, and
tetrachloroethene; the aromatic compounds, toluene,
ethylbenzene, and xylenes; and acetone, a ketone. Some VOCs
not detected in the soils but detected at significant
concentrations in groundwater include: vinyl chloride,
l,l-dichloroethane, 1,2-dichloroethene and tetrahydrofuran.
However, because releases from the previously buried drums
likely affected only localized areas of soils, it is
probable that the soil borings advanced in the former
..
"
~

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.'
7
~
disposal area did not identify each affected zone in the
area. Additionally, some of the VOCs not observed in soil
samples but found in groundwater could be the by-products of
degradation of VOCs which are known to be present on-site.

Based upon soil quality data for the former drum disposal
area, it appears that the most highly contaminated soils are
in the vicinity of the water table. The saturated volume of
contaminated soils will vary due to seasonal fluctuations
which were observed to be as much as five feet during the
course of the RI monitoring program. This fluctuation is
currently believed to have a significant effect on the
release of contaminants from soils to groundwater, the
greatest release occurring in the spring when the water
table is highest and groundwater is in contact with a larger
volume of contaminated soils. This occurrence is supported
by the analytical data for groundwater samples collected
from the two overburden monitoring wells located closest to
and downgradient of the former drum disposal area.
The source area responsible for the presence of VOCs in
groundwater in the southern boundary area is inferred to be
in overburden in the vicinity of the large concrete pad
located west of the piggery building. Having found higher
VOC concentrations in the bedrock monitoring well than in
the overburden well, it appears that the VOC source is in
overburden soils in close proximity to the bedrock surface.
However, borings advanced into the soil around the pad did
not confirm any contaminated soils. Due to the upland
location of the concrete pad and the thin layer of
overburden in this area, groundwater is not present in the
overburden in some areas during at least part of the year.
During these periods, VOC releases from source area soils
would occur as a result of either soil gas migration or
surface water infiltration through the soils.
B.
Groundwater
Two plumes of VOC-contaminated groundwater were identified
during the RI. One is the result of contamination migrating
from soils in the former drum disposal area. The other is
beneath the southern boundary area. Each is described
below.
VOCs were the group of compounds most often reported present
in groundwater samples analyzed during the RI. The VOCs
most commonly reported at elevated concentrations and the
maximum detected concentrations include aromatic compounds
(toluene - 9200 ppb, ethylbenzene - 1700 ppb and xylenes -
4700 ppb), chlorinated hydrocarbons (vinyl chloride - 360
ppb, 1,1-dichloroethane - 1300 ppb, 1,2-dichloroethene -
4700 ppb, trichloroethene - 2400 ppb and 1,1,1-
~

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.
8
trichloroethane - 2100 ppb), and tetrahydrofuran - 1600 ppb
(see Tables 2-17 and 4-1 of the RI). Elevated arsenic
concentrations (maximum detected concentration - 570 ppb)
were found in those wells with the highest voc
concentrations.
~
The groundwater flow directions in overburden in the former
drum disposal area are generally northeasterly from the
former disposal area to the drainage swale and then easterly
to Brook A. Groundwater in shallow bedrock in the former
disposal area flows generally in an easterly direction to
Brook A and then northerly along the brook, although a
limited northeasterly component of flow in this zone was
observed. Shallow bedrock monitoring wells demonstrate a
hydraulic connection between overburden and shallow bedrock
in the site area. Bedrock is recharged by groundwater in
the overburden in the vicinity of the former disposal area.
However, bedrock groundwater in the Brook A valley
discharges to the overburden.
contaminants migrate in overburden and bedrock groundwater
from the former disposal area to the east along the general
path of the drainage swale to Brook A and then northerly
along the west side of the brook. VOCs and other
contaminants were not detected in groundwater samples
collected from overburden wells located east of Brook A,
consistent with data suggesting that the brook is the
discharge zone for overburden groundwater. Levels of total
VOCs observed in shallow bedrock groundwater samples
downgradient of the former disposal area were generally
lower than or similar to those observed in overburden
groundwater samples, which is consistent with recharge of
bedrock from the overburden in the former disposal area and
recharge of overburden from the shallow bedrock in the Brook
A valley.
In general, detected concentrations of VOCs in groundwater
samples collected from monitoring wells on-site during the
RI were observed to be lower than those observed in
groundwater samples collected and analyzed in prior
investigations performed during and immediately following
the EPA removal action. Levels of total VOCs (TVOCs)
observed during the RI were lower than those observed in
prior investigations by factors of three to twenty. This
observation is consistent with the expected decline in VOC
levels in groundwater since the removal action as a result
of source removal and attenuation of residual VOC levels.
The extent of the VOC plume in groundwater was observed to
have decreased, which is also consistent with the
anticipated decline in groundwater concentrations. The
observed decrease in extent and levels of VOCs in site
groundwater, the local and regional groundwater flow
.-

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9
patterns, and the results of analyses of groundwater samples
from off-site monitoring and residential water supply wells,
are consistent with the belief that off-site groundwater was
not and is not now being affected by on-site conditions.
. ,
Groundwater data from wells in the southern boundary area,
indicated the presence of a different, more limited suite of
VOCs than was observed in groundwater samples from wells
monitoring the former drum disposal area and areas
downgradient. This information, coupled with groundwater
flow data and reports of past activities in the area,
indicated the presence of another source of VOCs in soils in
the vicinity of the concrete pad. Based upon the levels of
VOCs detected in groundwater and lack of detectable levels
of VOCs obtained from the soil gas survey and from borings
in the area, the source appears to be relatively small and
highly localized.

Observations of bedrock core samples collected during the RI
monitoring well installation program in the vicinity of the
southern boundary area were similar to those in the former
drum disposal area and did not indicate significant
fracturing of shallow bedrock below a relatively thin
weathered zone. Indications of infilling of fractures by
sediment particles, which could serve as a possible VOC
source, also were not observed. Observed rates of recovery
during bedrock well purging and sampling in this area were
extremely slow (on the order of several hours to several
days) suggesting that fractures in the zones monitored by
these-wells were relatively narrow and unlikely to be large
enough to collect significant amounts of sediment.
Accordingly, it appeared to be unlikely that a source of
VOCs was present within shallow bedrock in this area, and
that the source of VOCs observed in bedrock groundwater was
most likely VOC-affected overburden and overburden
groundwater.
Localized groundwater flow in the overburden and shallow
bedrock in the southern boundary area was observed to be
generally southerly or southeasterly. Information regarding
the local hydrogeologic system suggests that groundwater in
this area eventually flows to the Brook A valley as does
groundwater in the former drum disposal area. Available
potentiometric data indicate that the overburden in the
vicinity of the concrete pad is largely unsaturated during
portions of the year: these data, which, when considered
with the topography and the presence of a bedrock outcrop
north and west of the area, also suggest that overburden
groundwater flow from recharge areas to the west of the
Mottolo Site does not contribute to overburden groundwater
in the southern boundary area. Accordingly, it appears that
overburden groundwater in this area is derived primarily

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10
from precipitation recharge and, furthermore, that
percolating precipitation directly recharges shallow bedrock
during portions of the year. Similar temporal changes in
groundwater potentiometric heads in overburden and shallow
bedrock monitoring wells~in this area suggest a hydraulic
connection between overburden and shallow bedrock. Vertical
gradient data from wells in the southern boundary area
indicate that groundwater in the overburden, when present,
recharges bedrock in this area.
~
In general, analytical data obtained from groundwater
samples collected from overburden and bedrock wells were
consistent with the conceptual hydrogeologic model developed
in the RI from potentiometric data for the southern boundary
area. The detection of relatively lower levels of VOCs in
one overburden groundwater well than were observed in
bedrock and the absence of VOCs in other overburden wells
downgradient of the inferred source area indicated that VOC
transport by overburden groundwater flow is relatively
limited.
c.
Surface Water
Low levels of VOCs were found only in on-site surface waters
during the RI. No VOCs were detected in any surface waters
off-site.
Analytical results of surface water samples collected during
the RI indicate that surface water in the immediate area of
the lower drainage swale and its confluence with Brook A
contains low concentrations of VOCs. Significant
concentrations of contaminants related to drum disposal
activities were not reported in samples collected during the
RI in upstream reaches of the drainage swale, Brook A, and
the piggery waste drainageway, nor in downstream reaches of
Brook A beyond the site area boundary, nor in the Exeter
River.
The primary identified source of the VOCs detected in
surface water is groundwater originating from the former
drum disposal area and discharging to the lower drainage
swale and Brook A. Highest TVOC concentrations detected in
surface water samples were found in the drainage swale near
its confluence with Brook A. These compounds included 1,1-
dichloroethane, 1,2-dichloroethene, l,l,l-trichloroethane,
toluene and trichloroethene. The compound detected at the
highest concentration was l,l-dichloroethane which was
detected at 41 ppb and 19 ppb. The remaining VOCs were
reported at concentrations less than 15 ppb. Low or non-
detectable levels of total VOCs (14 ppb, non-detected and 7
ppb) were reported in the three samples collected in Brook A

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11
n
the.drainage swale. Of the three samples collected from
approximately 300 feet farther downstream, two did not
contain detectable levels of VOCs and one contained only 2
ppb of l,l-dichloroethane.

Since the soil berm at the base of the former disposal area
limits surface water runoff from this area from directly
entering the swale, groundwater discharging to the swale is
the likely source of VOCs detected in surface water samples
collected from the drainage swale. contaminated groundwater
discharging to Brook A, in addition to surface water
discharges from the drainage swale, are the likely sources
of VOCs detected in Brook A surface water samples.
D.
Sediment
Sediment sample analyses indicated contaminant distribution
trends similar to the surface water samples. These trends
included the observation of elevated concentrations of VOCs
in the lower swale and Brook A in the vicinity of the swale
with maximum detected concentrations of l,l-dichloroethane
of 360 ppb and of l,l,l-trichloroethane of 64 ppb.
E.
Air
Air screening conducted throughout the course of outside RI
activities did not indicate the presence of detectable
levels of VOCs in breathing zone ambient air. Given the low
levels of VOCs found in other media at the Site, this is
consistent.
A complete discussion of site characteristics can be found in the
RI Report in sections 3.0, 4.0 and 5.0.
VI.
SUMMARY OF SITE RISKS
A Risk Assessment was performed to estimate the probability and
magnitude of potential adverse human health and environmental
effects from exposure to contaminants associated with the site.
The public health risk assessment followed a four step process:
1) contaminant identification, which identified those hazardous
substances which, given the specifics of the Site were of
significant concern; 2) exposure assessment, which identified
actual or potential exposure pathways, characterized the
potentially exposed populations, and determined the extent of
possible exposure; 3) toxicity assessment, which considered the
types and magnitude of adverse health effects associated with
exposure to hazardous substances; and 4) risk characterization,
which integrated the three earlier steps to summarize the
potential and actual risks posed by hazardous substances at the
Site, including carcinogenic and non-carcinogenic risks. The

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.
l2
are discussed below followed by the conclusions of the
environmental risk assessment.
~
Ten contaminants of concern were selected for evaluation in the
Risk Assessment. Selected indicator compounds for the following
media included:
.
groundwater: arsenic, 1,1-dichloroethane, 1,2-
dichloroethene (total), ethylbenzene, tetrahydrofuran,
1,1,1-trichloroethane, toluene. trichloroethene, and
vinyl chloride
.
surface water: 1,1-dichloroethane and 1,2-
dichloroethene (total)
.
sediment:
1,l-dichloroethane and 1,1,1-trichloroethane
.
soil:
ethylbenzene, ~oluene, and xylene.
These contaminants constitute a representative subset of the more
than thirty contaminants identified at the Site during the RI.
The ten contaminants of concern were selected to represent
potential site related hazards based on toxicity, concentration,
frequency of detection, and mobility and persistence in the
environment. A summary of the health effects of each of the
contaminants of concern can be found on pages 18 through 24 of
Chapter 6.0 of the RI (Baseline Risk Assessment), and in Appendix
C-8 of the RI.
Potential human health effects associated with exposure to the
contaminants of concern were estimated quantitatively through the
development of several hypothetical exposure pathways. These
pathways were developed to reflect the potential for exposure to
hazardous substances based on the present uses, potential future
uses, and location of the site. The following is a brief summary
of the exposure pathways evaluated. A ~re thorough description
can be found in the Baseline Risk Assessment, Chapter 6 of the
RI.
For contaminated groundwater, potential future residential use of
the Site was assumed and exposure scenarios for both bedrock and
overburden aquifers were developed for two areas of the Site
(namely, the former drum disposal area and the southern boundary
area). In each case, a seventy-year lifetime of ingesting two
liters of the contaminated groundwater each day was presumed.
Since no existing residential wells have been found which are
impacted by site contaEinants. no current risk analysis was done
for ingestion or dermal contact with groundwater. For soils,
incidental ingestion and dermal contact scenarios were developed
for both current use and potential residential use of the Site.
For the current use, incidental ingestion and dermal contact was

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.'
13
"
soils at,the site an average of five days per year or a
reasonable maximum of ten days per year. For potential future
residential use, incidental ingestion and dermal contact were
evaluated over a seventy-year lifetime for average exposures of
seventy-eight times per year and for maximum exposures of 160
times per year. For each pathway evaluated, an average and a
reasonable maximum exposure estimate was generated corresponding
to exposure to the average and the maximum concentration of
contaminants detected in that particular medium.
Excess lifetime cancer risks were determined for each exposure
pathway by multiplying the exposure level with the chemical-
specific cancer potency factor. Cancer potency factors have been
developed by EPA from epidemiological or animal studies to
reflect a conservative "upper bound" of the risk posed by
potentially carcinogenic compounds. That is, the true risk is
very unlikely to be greater than the risk predicted. The
resulting risk estimates are expressed in scientific notation as
a probability (e.g. 1 x 10.6 or 1/1,000,000) and indicate (using
this example), that an individual is not likely to have greater
than a one in a million chance of developing cancer over seventy
years as a result of site-related exposure to the compound, as
defined, at the stated concentration. Current EPA practice
considers carcinogenic risks to be additive when assessing
exposure to a mixture of hazardous substances.
The hazard index was also calculated for each pathway as EPA's
measure of the potential for non-carcinogenic health effects.
The hazard index is calculated by dividing the exposure level by
the reference dose (RfD) or other suitable benchmark for non-
carcinogenic 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.
RfDs are derived from epidemiological or animal studies and
incorporate uncertainty factors to help ensure that adverse
health effects will not occur. The hazard index is often
expressed as a sirigle value (e.g. 0.3) indicating the ratio of
the stated exposure as defined to the reference dose value (in
this example, the exposure as characterized is three-tenths of
the acceptable exposure level for the given compound). The
hazard index is only considered additive for compounds that have
the same or similar toxic endpoints (for example: the hazard
index for a compound known to produce liver damage should not be
added to a second whose toxic endpoint is kidney damage).

Table 1 depicts the carcinogenic and non-carcinogenic risk
summary corresponding to the average and the reasonable maximum
exposure scenarios for the contaminants of concern in soil,
sediment and surface water evaluated to reflect Dresent ingestion
and dermal contact exposure pathways. Table 2 depicts the
carcinogenic and non-carcinogenic risk summary corresponding to
.-

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.
14
the average and the reasonable maximum exposure scenarios for the
contaminants of concern in groundwater, soil, sediment and
surface water evaluated to reflect future ingestion and dermal
contact exposure pathways. The groundwater risks are presented
for exposures to overburden or bedrock groundwater in area 1
(downgradient of the former drum disposal area) and for exposures
to overburden or bedrock groundwater in area 2 (downgradient of
the southern boundary area). .
G
Cumulative potential cancer risks associated with current and
future scenarios for ingestion and dermal contact with on-site
sediment, soil and surface water did not exceed EPA's target
cancer risk range of 10'4 to 10'6. Similarly, cumulative hazard
indices as a measure of the potential for non-carcinogenic
effects for each of the above exposure pathways did not exceed
unity (1.0).
Based on the findings in the Baseline Risk Assessment, EPA has
concluded that the risk posed by the future ingestion of
groundwater from wells installed within the former drum disposal
area will exceed the acceptable risk range of 10.4 to 10'6. The
principal contributors to carcinogenic risk from the ingestion of
groundwater are arsenic, vinyl chloride and trichloroethylene.
The maximum concentrations of arsenic detected on-site, 570 ppb,
exceeded the Maximum Contaminant Level (MCL) of 50 ppb
promulgated under the Safe Drinking Water Act. Vinyl chloride
and trichloroethene were also found at high concentrations with
maximum concentrations of 360 ppb and 2400 ppb, respectively.
The MCL established in the Safe Drinking Water Act for vinyl
chloride is 2 ppb and for trichloroethene is 5 ppb.
The hazard index exceeds unity for the future ingestion of ground
water from the former drum disposal area for both the average and
maximum cases. Total 1,2-dichloroethene is the major contributor
for the noncarcinogenic effects with a hazard index of 7, as well
as, tetrahydrofuran with a hazard index of 3.
With respect to potential environmental impacts posed by site
contamination, neither current nor future significant adverse
impacts were identified.
Actual or threatened releases of hazardous substances from this
Site, if not addressed by implementing the response action
selected in this ROD, may present an imminent and substantial
endangerment to public health and welfare. Specifically,
consumption of overburden and/or bedrock groundwater would result
in unacceptable lifetime cancer risks, as well as, unacceptable
noncarcinogenic risks due to the levels of arsenic and VOCs
detected in the groundwater. Overburden and bedrock groundwater
near the former drum disposal area and the southern boundary area
will be the focus of remedial actions.

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15
VII. DEVELOPMENT AND SCREENING OF ALTERNATIVES
A.
statutory Requirements/Response Objectives
Under its legal authorities, EPA's primary responsibility at
Superfund sites is to undertake remedial actions that are
protective of human health and the environment. In
addition, Section 121 of 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 that permanently and significantly reduces
the volume, toxicity or mobility of the hazardous substances
is a principal element over remedies not involving such
treatment. Response alternatives were developed to be
consistent with these Congressional mandates.
Based on preliminary information relating to types of
contaminants, environmental media of concern, and potential
exposure pathways, remedial action objectives were developed
to aid in the development and screening of alternatives.
These remedial action objectives were developed to mitigate
existing and future potential threats to public health and
the ~nvironment. These response objectives were:
.
To eliminate or minimize the threat posed to the
public health, welfare, and environment by the
current extent of contamination of groundwater and
soils;
.
To eliminate or minimize the migration of
contaminants from the soils into the groundwater;
and
.
To meet federal and state Applicable or Relevant
and Appropriate Requirements (ARARs).
B.
Technology and Alternative Development and screening
CERCLA and the National Contingency Plan (NCP) set forth the
process by which remedial actions are evaluated and
selected. In accordance with these requirements, a range of
alternatives were developed for the Site.
:

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16
With respect to source control, the RI/FS developed a range
of 'alternatives in which treatment that reduces the
toxicity, mobility, or volume of the hazardous substances is
a principal element. This range included an alternative
that removes or destroys hazardous substances to the maximum
extent feasible, eliminating or minimizing to the degree
possible the need for long term management. This range also
included alternatives that treat the principal threats posed
by the Site, but vary in the degree of treatment employed
and the quantities and characteristics of the treatment
residuals and untreated waste that must be managed;
alternatives that involve little or no treatment, but
provide protection through engineering or institutional
controls; and a no action alternative.
c
With respect to groundwater response action, the RI/FS
developed a limited number of remedial alternatives that
attain site specific remediation levels within different
time frames using different technologies; and a no action
alternative.
As discussed in Chapter 2 of the FS, the RI/FS identified,
assessed and screened technologies based on
implementability, effectiveness, and cost. 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. The technologies which
remained after screening were combined into source control
and management of migration alternatives. Chapter 3 of the
FS presented the remedial alternatives developed by
combining the technologies identified in the previous
screening process in the categories identified in 40 CFR
Section 300.430(e) (3) of the NCP. Each alternative was then
evaluated and screened in Chapter 3 of the FS.
Of the nine source control and four management of migration
remedial alternatives screened in Chapter 3, eight
comprehensive alternatives (using combinations of seven
source control and three management of migration
alternatives) were developed and retained for detailed
analysis in Chapter 4. Table 3 identifies the alternatives
that were retained through the screening process and the
comprehensive alternatives developed, as well as, those
source control and management of migration alternatives that

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VIII.
17
. DESCR7PTION 01' ALTERJlATIVES
This section provides a narrative summary of each alternative
evaluated. The comprehensive alternatives analyzed for the site
include: no action (Alternative 1); groundwater interceptor
trench and capping (Alternative 2); in-situ vapor extraction
(Alternative 3); above-ground vapor extraction (Alternative 4);
chemical fixation (Alternative 5); on-site low temperature
thermal stripping (Alternative 6); off-site incineration
(Alternative 7); and in-situ vapor extraction with collection and
treatment of groundwater (Alternative 8). Alternatives 1 through
7 all rely on natural attenuation of groundwater contamination as
the management of migration component. A detailed tabular
assessment of each alternative can be found in Table 5-1 of the
FS.
~
A.
Alternative 1: No action
Under this alternative no treatment of groundwater
contamination would occur and no effort would be made to
restrict potential exposure to groundwater contaminants.
contaminated soil would continue to release VOCs to site
groundwater. Eventually, the natural flushing of the soil
by groundwater and rainwater would carry the contaminants
into Brook A where they would volatilize. The exact length
of time it would take to meet these levels cannot be
accurately estimated, however, at least several decades of
this natural flushing would be required. Monitoring of
groundwater and surface water at the Site would be conducted
for ~pproximately thirty years. Since contaminants would be
left on-site, site conditions would be reviewed every five
years to determine if further actions were needed.
CONSTRUCTION: N/A
several decades
$ 10,000
290,000
$ 300,000
ESTIMATED TIME FOR DESIGN AND
ESTIMATED TIME FOR OPERATION:
ESTIMATED CAPITAL COST:
ESTIMATED O&M (Present Worth):
ESTIMATED TOTAL COST (Present Worth):
B.
Alternative 2: Grounawater Luterceptor trench and
capping wi~ natural attenuation of
groundwater contamination
This alternative would use a groundwater interceptor trench
to reduce the flow of groundwater through the contaminated
soils in the former drum disposal area. contaminated soils
from the southern boundary area (estimated at 2000 to 2200
cubic yards) would be excavated to bedrock and placed in the
former drum disposal area prior to placement of a waterproof
cap over all the contaminated soils to prevent the
infiltration of rainwater and snowmelt. Excavation of the
southern boundary area soils would be done during a dry
-

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.
18
period which would make dewatering unnecessary. All soils
to'be capped would be graded and compacted to limit post-
construction settling. The cap would be composed of two
polyethylene membranes separated by a layer of sand for
drainage. This would be placed on a bedding layer of sand
to minimize the potential for damage to the cap during
construction. A layer of fill and topsoil would be placed
on top and seeded to prevent erosion. The total thickness
of the cap would be between five and six feet. The cap and
trench together would greatly decrease the leaching of
contaminants into the groundwater and would isolate the
contaminated soils from possible human contact.

This alternative would also include a thirty-year surface
water and groundwater monitoring program and institutional
controls to prevent disturbance of the cap and monitoring
wells, and to prevent use of the contaminated groundwater.
A ten-foot high chain link fence would be installed around
the contaminated soil area. The fence would have barbed
wire along the top and locked gates. Since contaminants
would be left on-site, site conditions would be reviewed
every five years to determine if further action were needed.
ESTIMATED TIME FOR DESIGN AND
ESTIMATED TIME FOR OPERATION:
CONSTRUCTION: 3-6 months
approximately I year to
dewater and up to 6 additional
years to achieve groundwater
cleanup levels
ESTIMATED CAPITAL COST:
ESTIMATED O&M (Present Worth):
ESTIMATED TOTAL COST (Present Worth):
$
$
440,000
350,000
790,000
C.
Alternative 3: In-situ vapor extraction system (VES)
with natural attenuation of contaminated
groundwater
This is the preferred alternative and is described in
section X., The Selected Remedy.
D.
Alternative 4: Above-ground vapor extraction system
(VES) with natural attenuation of
contaminated groundwater
This on-site remedial alternative includes installation of
an upgradient groundwater interceptor trench to lower the
water table in the former drum disposal area, excavation of
soil in the former disposal and southern boundary areas
(approximately 3400 to 4000 cubic yards), and treatment in
an above-ground VES. Excavation of the southern boundary
area soils would be done during a dry period which would
make dewatering unnecessary.
.

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. .
19
The VES system would consist of two lined treatment cells
each approximately 100 feet square by six to eight feet
high, constructed with pre-cast concrete barriers,
perforated or slotted PVC extraction pipes laid horizontally
in each treatment soil pile, an intake manifold pipe
connecting the extraction piping from each cell to a vacuum
pump, and vapor phase activated carbon filters for off-gas
treatment. A water trap would be installed in the manifold
piping system ahead of the vacuum blower. The source area
soils would be placed on the bottom liner (forty-mil
polyethylene) in lifts of approximately three feet with the
extraction pipes placed at appropriate depth intervals to
ensure effective treatment. A twenty-mil polyethylene cap
with air injection points would be placed over the pile to
limit air emissions and short circuiting air inflow.
Operation of the vacuum blower would extract air and VOCs in
the vapor phase from soil pore spaces. VOCs sorbed onto the
soils would partition into air that replaces the pore space
air removed. This process would continue until soil
remedial action objectives are attained. The carbon air
filters on the treatment system would be regenerated with
steam on-site or the spent carbon filters would be
transferred to off-site regeneration or disposal after
completion of remedial operations. If regenerated on-site,
steam condensate would contain VOCs previously sorbed onto
the carbon and would be collected and transferred off-site
for treatment or disposal. When treatment was complete, the
soils would be replaced in the excavations from which they
were removed and an earthen cap placed over them.

This alternative would require additional site clearing and
access drive improvements to allow construction of the
treatment cells. Fencing, construction of the groundwater
interceptor trench, and institutional controls would be
carried out as in Alternative 2. Groundwater and surface
water monitoring would continue for ten years after
completion of soil remediation to ensure the effectiveness
of the source remediation and the attainment of groundwater
cleanup levels.
ESTIMATED CAPITAL COST:
ESTIMATED O&M (Present Worth):
ESTIMATED TOTAL COST (Present Worth):
ESTIMATED TIME FOR DESIGN AND CONSTRUCTION: 6-12 months
ESTIMATED TIME FOR OPERATION: 1-2 years for dewatering and
VES and up to 6 additional
years to achieve groundwater
cleanup levels
$ 700,000
300,000
$1,000,000
:
.

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. .
20
E.
. Alternative 5: Chemical fixation with natural
attenuation of contaminated groundwater
o
This alternative would excavate all of the contaminated
soils from both the former drum disposal area and the
southern boundary area (3400 to 4000 cubic yards),
chemically bind the contaminants and soils together, and
then replace the soils on-site into a secure, capped cell in
the former drum disposal area.

Prior to excavation, dewatering of the former drum disposal
area would be accomplished by using the interceptor trench
described in Alternative 2. Excavation of the southern
boundary area soils would be done during a dry period which
would make dewatering unnecessary. Former drum disposal
area soils would be placed on a 100 feet square, lined cell
constructed similar to those described in Alternative 4
while the secure cell was under construction. Soils would
be screened to remove boulders, cobbles, and other material
not compatible with the fixation process, and be transported
to the fixation treatment plant constructed on-site. There,
batches of soil would be mixed with chemical binding agents,
water, and cement to form a concrete-like material. A pilot
study would be required prior to the start of treatment.
Prior to the pilot study, a treatability study would be
performed at an off-site laboratory to determine appropriate
fixation reagent types and proportions for contaminated
soils from the former disposal and southern boundary areas.
Soil samples for treatability and pilot testing would be
collected by excavating test pits in the source areas. The
results of the treatability study would be used to develop a
fixation formula to be tested in the pilot scale study. The
pilot study would be performed on-site using at least two
batches of soil from each area. The test would include
sampling and analysis of untreated and treated soils to
evaluate the performance of the selected mixture of reagent
binders in fixing contaminants present in site soils. The
tested soil batches would be allowed to cure for at least
fourteen days prior to testing using appropriate Toxicity
Characteristic Leaching Procedure (TCLP) methods. If TCLP
testing results are not satisfactory, another site-wide
alternative fixation process would be tested. Soils from
unsatisfactory tests would be re-processed during full-
scale operations.
After the fixation process was complete, each batch of soil
would be placed in a secure cell constructed in the former
drum disposal area. The cell would be constructed to
maintain the treated soil at least six feet above the
seasonal high water table. The cell would have impermeable
top, bottom, and side walls constructed similarly to the cap
described in Alternative 2, above.
.-

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. .
21
This alternative would require site clearing and access
drive improvements similar to those required for Alternative
4. Fencing, construction of a groundwater interceptor
trench, groundwater and surface water monitoring, and
institutional controls would be carried out as for
Alternative 2. Since contaminants would be left on-site,
conditions would be reviewed every five years to determine
if further actions were needed.
ESTIMATED TIME FOR DESIGN AND
ESTIMATED TIME FOR OPERATION:
CONSTRUCTION: 6-12 months
1-2 years for dewatering and
chemical fixation and up to 6
additional years to achieve
groundwater cleanup levels
ESTIMATED CAPITAL COST:
ESTIMATED O&M (Present Worth):
ESTIMATED TOTAL COST (Present Worth):
$1,600,000
300,000
$1,900,000
F.
Alternative 6: On-Site Low Temperature Thermal
Stripping (LTTS) with natural
attenuation of contaminated groundwater
This on-site remedial alternative includes installation of
an upgradient groundwater interceptor trench to lower the
water table in the former disposal area, excavation of soil
in the former drum disposal and southern boundary areas,
transfer of the soil to an on-site low temperature thermal
stripping (LTTS) unit to remove VOCs, followed by
replacement of the treated soil, and construction of a soil
cap over treated soils.
Prior to excavation, dewatering of the former drum disposal
area would be accomplished by using the interceptor trench
described in Alternative 2. Excavation of the southern
boundary area soils would be done during a dry period which
would make dewatering unnecessary. Soils would be screened
to remove boulders, cobbles, and other material not
compatible with the LTTS system. Soils would be stockpiled
or placed directly into the hopper of the LTTS. Soil would
then be fed into a rotating dryer where 3008F to 6008F air
volatilizes the VOCs. The treated soil would then be cooled
with water to control dust and be placed into a stockpile.
Each twenty-ton batch of soil would be then tested for VOCs.
Soils that would meet soil cleanup levels would be returned
to the excavation areas and covered with an earthen cap. If
soils could not meet cleanup levels they would be
reprocessed. The exhaust gases from the dryer would contain
VOCs, dust, and a small amount of acid vapor. The LTTS
system would utilize carbon filters to remove VOCs, cyclone
and baghouse filters to remove dust, and scrubbers to remove
acid vapors. The activated carbon would either be
--

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22
regenerated on-site during treatment operations or the
carbon would be sent to a facility for off-site regeneration
at the conclusion of treatment operations, as appropriate,
depending upon the mass of VOCs to be removed and the
capacity of the carbon beds. The dust collected in the
filters would be reprocessed, or tested for hazardous
materials and disposed of off-site in compliance with
Federal and state requirements. Wastewater from the
scrubbers would be sent off-site for treatment and disposal.
This alternative would require site clearing, fencing,
access drive improvements, and institutional controls
similar to those required for Alternative 4, above. Long-
term monitoring of ground and surface water quality would be
conducted for up to ten years after completion of source
remediation to assess the effects of remediation and confirm
improvement of groundwater quality as in Alternative 4.
ESTIMATED TIME FOR DESIGN AND
ESTIMATED TIME FOR OPERATION:
CONSTRUCTION: 6-12 months
1-2 years for dewatering and
LTTS and up to 6 additional
years to achieve groundwater
cleanup levels
$2,100,000
300,000
$2,400,000
ESTIMATED CAPITAL COST:
ESTIMATED O&M (Present Worth):
ESTIMATED TOTAL COST (Present Worth):
G.
Alternative 7: Off-site Incineration with natural
attenuation of contaminated groundwater
This off-site remedial alternative includes installation of
an upgradient groundwater interceptor trench to lower the
water table in the former disposal area, excavation of soil
in the former disposal and southern boundary areas
approximately 3400 to 4000 cubic yards), transfer of the
soil to an off-site incinerator to remove VOCs, followed by
backfilling of the excavated areas with clean, granular
material.
Prior to excavation, dewatering of the former drum disposal
area would be accomplished by using the interceptor trench
described in Alternative 2. Excavation of the southern
boundary area soils would be done during a dry period which
would make dewatering unnecessary. Excavated soils would be
loaded directly into ~ined trucks, covered to reduce air
emissions, and prepared for transport to a licensed
hazardous waste incinerator for incineration and disposal.
ApproxiEately twenty trucks per week wculd leave the Site.
Backfilling would be performed iEmedia~ely following
completion of soil excavation. Backfill material would be
placed and graded as necessary to ensure positive drainage

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23
fil~ and would be compacted to minimize the potential for
future settlement. The disturbed area would ultimately be
covered with topsoil, and vegetation would be reestablished.
This alternative would require site clearing, fencing, and
institutional controls similar to that required for
Alternative 2. Long-term monitoring of groundwater and
surface water would be conducted for up to ten years after
completion of source remediation to assess the effectiveness
of remediation and confirm attainment of groundwater cleanup
levels as in Alternative 4.
ESTIMATED TIME FOR DESIGN AND
ESTIMATED TIME FOR OPERATION:
CONSTRUCTION: 6-12 months
up to 1~ years to dewater and
remove soils and up to 6
additional years to achieve
groundwater cleanup levels
ESTIMATED CAPITAL COST:
ESTIMATED O&M (Present Worth):
ESTIMATED TOTAL COST (Present Worth):
$9,500,000
200,000
$9,700,000
H.
Alternative 8: In-Situ Vapor Extraction system (VES)
treatment of soils with collection and
treatment of groundwater
This alternative involves the installation of a groundwater
interceptor trench upgradient of the former disposal area,
in-situ vapor extraction of VOC source soil areas, and
collection and treatment of contaminated groundwater. The
groundwater treatment system would include metals removal
(to reduce air stripper fouling) through precipitation and
removal of VOCs through air stripping and carbon adsorption.
Treated groundwater would be discharged to the Brook A
valley.
This alternative would involve construction of a groundwater
interceptor trench and in-situ VES as in the preferred
alternative, but would also include the extraction and on-
site treatment of contaminated groundwater. A 100-foot long
trench would be used to collect both overburden and bedrock
groundwater downgradient from the former drum disposal area.
This trench would be similar in construction to the
interceptor trench described in Alternative 2, but located
just west of Brook A. The pumping of this trench would draw
both overburden and bedrock groundwater. It would also
dewater the wetlands next to Brook A and reduce the flow in
Brook A itself. In addition, overburden groundwater would
be extracted by approximately twelve wells located between
the extraction trench and the former drum disposal area. To
enhance removal of contaminants, the wells would pump in
cycles.
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24
Wells would be used to collect bedrock groundwater in the
southern boundary area and any small amounts of overburden
groundwater that may exist.
The groundwater treatment plant which would receive the
extracted groundwater from both the former drum disposal
area and the southern boundary area would be located on the
concrete pad where the piggery now stands. Removal of VOCs
would be accomplished by an air stripper. The exhaust air
containing the VOCs would be sent to carbon filters to
remove the contaminants and then vented to the atmosphere.
The treated water would be discharged into Brook A. Because
site groundwater contains levels of iron and manganese that
might foul the air stripping system, the water will be
pretreated to remove these metals prior to air stripping.
The sludges from the pretreatment would be dewatered,
analyzed, and disposed of off-site in compliance with
Federal and State requirements.

Site clearing and institutional controls similar to
Alternative 2 and approximately 1300 feet of ten feet high
chain link fencing would be required. Groundwater and
surface water would be monitored for up to ten years after
completion of the VES treatment to confirm that levels of
contaminants in the groundwater meet cleanup levels.
ESTIMATED TIME FOR DESIGN AND
ESTIMATED TIME FOR OPERATION:
CONSTRUCTION: 12 months
1-2 years for dewatering and
VES and up to 3 additional
years to achieve groundwater
cleanup levels
$1,100,000
1,000,000
$2,100,000
ESTIMATED CAPITAL COST:
ESTIMATED O&M (Present Worth):
ESTIMATED TOTAL COST (Present Worth):
IX.
SUMMARY OF THE COMPARATIVE ANALYSIS OF ALTERNATIVES
Section 121(b) (1) of CERCLA presents several factors that, at a
minimum, EPA is required to consider in its assessment of
alternatives. Building upon these specific statutory mandates,
the National Contingency Plan articulates nine evaluation
criteria to be used in assessing the individual remedial
alternatives.
A detailed analysis was performed on the alternatives using the
nine evaluation criteria in order to select a site remedy. The
following is a summary of the comparison of each alternative's
strength and weakness with respect to the nine evaluation
criteria. These criteria and their definitions are as follows:
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25
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.
2.
Overall protection of human health and the
environment addresses whether or not a remedy
provides adequate protection and describes how
risks posed through each pathway are eliminated,
reduced or controlled through treatment,
engineering controls, or institutional controls.
Compliance with Applicable or Relevant and
Appropriate Requirements (ARARs) addresses
or not a remedy will meet all of the ARARs
other Federal and state environmental laws
provide grounds for invoking a waiver.
whether
of
and/or
primarv Balancina criteria
The following five criteria are utilized' to compare and
evaluate the elements of one alternative to another that
meet the threshold criteria.
3.
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.
4.
Reduction of toxicity, mobility, or volume throuqh
treatment addresses the degree to which
alternatives employ recycling or treatment that
reduces toxicity, mobility, or volume, including
how treatment is used to address the principal
threats posed by the site.

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.
5.
6.
Implementability addresses the technical and
administrative feasibility of a remedy, including
the availability of materials and services needed
to implement a particular option.
7.
Cost includes estimated capital and Operation and
Maintenance (O&M) costs, as well as present-worth
costs.
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26
Modifvina criteria

The modifying criteria are used on the final evaluation of
remedial alternatives generally after EPA has received
public comment on the RIfFS and Proposed Plan.
8.
state acceptance addresses the State's position
and key concerns related to the preferred
alternative and other alternatives, and the
State's comments on ARARs or the proposed use of
waivers.
9.
community acceptance addresses the public's
general response to the alternatives described in
the Proposed Plan and RIfFS report.
A detailed tabular assessment of each alternative according to
the seven criteria (all but the Modifying Criteria) can be found
in Table 5-1 of the FS. Following the detailed analysis of each
individual alternative, a comparative analysis, focusing on the
relative performance of each alternative against the seven
criteria, was conducted. This comparative analysis can be found
in Figure 5-1 of the FS.
The section below presents the nine criteria and a brief
narrative summary of the alternatives and the strengths and
weaknesses according to the detailed and comparative analysis.
1.
Overall Drotection of human health and the environment
with the exception of Alternative 1, the site-wide
alternatives evaluated in section 4.0 of the FS report are
considered protective of human health and the environment.
Alternative 1, no action, cannot prevent exposure to
contaminated groundwater which would not attain cleanup
standards for decades. Alternative 2 provides protection
through engineering controls (the groundwater interceptor
trench and capping) which prevent continuing contaminant
releases to the qroundwater allowing cleanup levels to be
attained through natural attenuation. The use of
institutional controls will prevent use of the groundwater
until groundwater cleanup levels are met.
The remaining alternatives provide protectiveness through
engineering controls (each employing the groundwater
interceptor trench and capping), treatment to prevent
releases of contaminants from soils to levels which would
allow groundwater to attain cleanup levels through natural
attenuation, and the use of institutional controls to
prevent the use of groundwater until groundwater cleanup
levels are met. Alternative 8 employs treatment of
groundwater, in lieu of natural attenuation, to achieve
protectiveness.
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27
2.
. Compliance with ARARs
Each alternative was evaluated for compliance with ARARs,
including chemical-specific, action-specific and location-
specific ARARs. This evaluation is presented in tabular
form in Table 4. All alternatives, with the exception of
Alternative 1, no action, would comply with ARARs. With the
exception of Alternative 1, the remedial alternatives would
attain the cleanup levels in groundwater, which were based
upon protective chemical-specific ARARs and to-be-considered
standards (TBCs), for the nine groundwater indicator
constituents. Alternative 1, the no action alternative,
would not comply with these chemical-specific ARARs in the
short term, i.e. less than decades. Alternative 2 would
attain ARARs more rapidly than would Alternative 1 through
reduction in VOC releases to, and mobility, in groundwater,
but could become less effective over time.
Mitigation and restoration measures will be required to
limit potential impacts in disturbed wetland areas and to
meet wetlands ARARs for Alternatives 2 through 8. With the
exception of Alternative 8, however, the wetland areas that
would be disturbed are of low diversity and were
significantly altered by prior disposal and removal
activities. These disturbances would be of relatively short
duration. Alternative 8 would involve much more extensive
disturbance and possible destruction of more diverse
wetlands in the Brook A valley as a consequence of
construction and operation of a groundwater collection
syst~m in this area. In addition, Alternative 8 would
require the construction of semi-permanent roads through
wetland areas, which would reduce the overall size of the
wetland area.
Alternative 8 may, also, have some difficulty with meeting
the state's anti-degradation provisions of the Water Quality
Standards. Extensive treatment and discharge limitations
would likely be imposed in order to comply.
3.
Lena-term effectiveness and Dermanence
In practical terms, the long-term effectiveness of the eight
alternatives in reducing residual risk is substantially the
same. The primary differences among alternatives are the
degree of certainty of their ability to attain soil and
groundwater cleanup levels and the degree of reliability of
the technologies employed.

The long-term effectiveness of Alternative 1 would depend
exclusively on naturally occurring attenuation processes
such as volatilization, dispersion, and biodegradation to
reduce VOC levels. These processes require the greatest
-
.

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28
amount of time to attain cleanup levels and reduce potential
future risks to within an acceptable range and the degree of
certainty associated with the estimate of the time to attain
those levels is lowest; this alternative, therefore, ranks
lowest among the alternatives in long-term effectiveness.
Alternative 2 offers an additional level of protection due
to the reduction in VOC mobility offered by the cap system
and groundwater interceptor trench. However, this reduction
in mobility, and therefore, long-term protectiveness, would
depend on the continued integrity and performance of the cap
and trench systems, which would need continuing maintenance
or replacement to ensure their reliability. Use of these
systems may also inhibit some of the natural attenuative
mechanisms that would reduce VOC levels in soil and
groundwater, such as dispersion and dilution through
groundwater flushing and volatilization.
o
Alternatives 3 through 8 offer a greater degree of long-
term effectiveness than Alternatives 1 and 2, because levels
of VOCs in soil and groundwater would be reduced through
treatment or fixation, resulting in more efficient and rapid
attainment of cleanup levels. Of these six alternatives,
those that involve treatment of VOCs in soil on-site or off-
site (Alternatives 3, 4, 6, 7, and 8) would be most reliable
in the long-term. Alternative 5 would employ fixation to
reduce the mobility of VOCs in soil, but would not reduce
VOC volume or toxicity. The fixation process could allow
the release of contaminants over time, so that treated soils
could be subject to leaching of VOCs. Use of a secure cell
for ~isposal of treated soils in conjunction with this
alternative would mitigate the potential for release,
although the degree of mitigation is dependent upon the
continued maintenance of the secure cell. Accordingly, the
long-term effectiveness of Alternative 5 is less than that
of the other treatment alternatives because of the somewhat
lower reliability of the treatment technique employed. It
is estimated that groundwater cleanup levels could be
attained in groundwater within approximately six years after
soil remediation using these alternatives, with the
exception of Alternative 8 in which it is estimated that
cleanup levels would be attained within approximately three
years.
4.
Reduction of toxicity. mobility. or volume throuqh
treatment
Alternatives land 2 would provide no reduction in VOC
toxicity or mobility nor in the volume of VOCs through
treatment, although levels of VOCs would decline to
protective leyels over time through the natural attenuation
mechanisms operating at the site. Alternatives 3, 4, 6, 7,
and 8 involve treatment of VOC-contaminated soil from the
.

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29
two ,source areas. The soil treatment represents a
significant, irreversible reduction in VOC volume and
toxicity in each of these alternatives. Alternative 5 also
includes remedial action for soil VOC contamination.
However, the fixation process, which is the major treatment
component of this alternative, provides only reduction in
mobility of VOCs in soil. The contaminants are not removed
or destroyed by fixation except for incidental VOC emissions
released during soil excavation, handling, and mixing.' The
fixation process could allow the release of contaminants
bound to the soil particles to be leached out by
infiltrating precipitation or fluctuating groundwater
tables. Mitigation of this potential leaching is offered by
placement of treated soils in a secure cell, and by the
groundwater interceptor trench. However, this protection
depends on the continued integrity and performance of the
trench and secure cell.
5.
Short-term effectiveness
Comparison of short-term effectiveness for the alternatives
included consideration of the length of time needed to
achieve cleanup levels as well as consideration of any
adverse impacts posed during the construction and
implementation period. Alternative 1, the no action
alternative, offers no short-term effectiveness since thirty
years or more would pass before cleanup levels would be
achieved. Alternative 2 provides short-term effectiveness
through installation of a groundwater trench and
cons~lidation of all contaminated soils beneath a multimedia
cap. Alternative 5 is similar, but the soils would be
chemically fixed prior to placement beneath the cap. For
each alternative, these actions would prevent leaching of
VOCs to the groundwater and allow natural attenuation to
occur, resulting in attainment of cleanup standards within
six years. Alternatives 3, 4, 6, and 7 provide similar
short-term effectiveness principally through treatment of
VOC-contaminated soil and the associated decrease in the
mass of VOCs released to groundwater. This treatment would
allow natural attenuation to occur, also resulting in
attainment of cleanup standards within six years.
Alternative 8 would provide short-term effectiveness through
treatment of the VOC-contaminated soils and additionally
extract and treat the contaminated groundwater, resulting in
the shortest predicted time to attain cleanup levels,
approximately three years.

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30
with the exception of Alternative 1, remedial construction
will result in potential short-term, adverse impacts to
human health and the environment. Remedial construction
would involve handling of VOC-contaminated soils in
Alternatives 2 through 8. Alternative 3 would involve the
least disturbance of contaminated soil, with exposures
limited primarily to drilling cuttings from installation of
vapor extraction wells. If necessary to comply with air
quality ARARs, air emissions from installation of the vacuum
extraction wells could be easily controlled and treated.
This alternative, therefore, would present the lowest
incremental, short-term risk associated with remedial
construction and operations. Risks associated with remedial
construction and operations are similar for Alternatives 2,
4, 5, 6, and 7 which involve excavation and above-ground
handling of VOC-contaminated soils. These operations may
result in exposure of on-site workers to airborne VOCs in
vapor form and sorbed to particulates. Off-site populations
may also be exposed to airborne emissions from these
operations, although these potential exposures would be
significantly mitigated by the expected low levels released,
distance from the Site to potential receptor populations and
attendant dilution. These short-term risks posed by
Alternative 2 would be somewhat less than those for the
other alternatives that involve soil excavation because a
lesser volume of soil would be excavated and handling would
be less extensive than for aboveground treatment
alternatives. Air emissions associated with treatment
operations in Alternatives 4 and 6 could, if necessary, be
controlled and treated. Short-term risk associated with
remedial operations involved in Alternatives 5 and 7 would
be slightly greater than that with Alternatives 4 and 6
because operations would be less amenable to control of air
emissions. Although similar to Alternative 3 with respect
to short-term risk associated with treatment of source
soils, Alternative 8 poses significantly greater short-term
risk from construction of a groundwater collection system in
the Brook A valley. This effort would result in possible
direct contact and inhalation exposures to VOCs present in
overburden groundwater in this area because the water table
is at or just below ground surface. The level and duration
of risk would vary depending upon the type of collection
system constructed and the construction techniques used.

with the exception of Alternative 8, the eight remedial
alternatives would differ slightly in potential short-term
impacts. Alternative 1 would involve minimal disturbance of
wetlands and indigenous wildlife because no construction
activities are associated with this alternative.
Alternatives 2 through 7 would provide essentially similar
protectiveness of the environment in the short-term, with
impacts involving temporary disturbance of a small,
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31
low~diversity wetland area in the vicinity of the former
dram disposal area during construction and remedial
activities. Construction and site preparation for
Alternatives 4, 5, and 6 would also require limited clearing
of additional wooded areas at the site. Alternative 8 would
be less protective of the environment in the short-term
because of the extensive disruption and destruction of
wetlands in the Brook A valley that would be associated with
construction and operation of a groundwater collection
system in this area.
6.
Imt>lementabilitv
Significant limitations in implementability were generally
not identified for the eight alternatives in the detailed
analysis with the exception of Alternative 8.
Implementation of alternatives requiring treatment
operations by specialty contractors (Alternatives 4, 5, and
6, and, to a lesser degree, 3 and 8) would depend on
contractor qualifications and availability, as well as
equipment availability. In addition to contractor and
equipment availability, implementation of Alternative 5
would also depend on successful treatability and pilot scale
demonstrations of a chemical fixation for VOCs in on-site
soils. Implementation of Alternative 7 would depend on the
availability of off-site incineration capacity.
Implementation of Alternative 8 would be more difficult
because of the conditions affecting construction of a
grounQwater collection system in the Brook A valley
wetlands, e.g., travel of heavy equipment over soils with
the groundwater table at or near the surface and equipment
access down steep slopes that lead to the valley area.

Permitting will not be required for on-site alternatives.
Off-site elements of remedial alternatives will comply with
applicable federal and state regulatory requirements,
including applications for permits. The alternative which
would be most affected is Alternative 7, off-site
incineration.
7.
Cost
The estimated present worth value of each alternative is
presented below:
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 COSTS OF ALTERNATIVES   
  Capital aiM Costs  Total
  Costs prsnt Wrth  Present
      Worth
Alternative 1 $ 10,000 $ 290,000 $ 300,000
Alternative 2  440,000  350,000  790,000
Alternative 3  410,000  280,000  690,000
Alternative 4  700,000  300,000  1,000,000
Alternative 5  1,600,000  300,000  1,900,000
Alternative 6  2,100,000  300,000  2,400,000
Alternative 7  9,500,000  200,000  9,700,000
Alternative 8  1,100,000 1,000,000  2,100,000
8.
state acceptance
The New Hampshire Department of Environmental Services
(NHDES) has been involved with the Site from shortly after
its discovery. NHDES has reviewed the various alternatives
and has indicated its support for the selected remedy. The
State has also reviewed the RI, Risk Assessment and the FS
to determine if the selected remedy is in compliance with
applicable or relevant and appropriate state Environmental
laws and regulations. NHDES concurs with the selected
remedy for the Mottolo Superfund Site. A copy of the
declaration of' concurrence is attached as Appendix A.
9.
Community acceptance
The comments received during the public comment period are
summarized and included with EPA's responses in the
Responsiveness Summary, which is included as Appendix B. No
oral comments were made at the Proposed Plan and FS public
hearing. In general, the community is supportive of the
selected remedy and satisfied by the findings of the RIjFS.
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33
x.
THE .SELECTED REMEDY
EPA has selected Alternative 3, in-situ vacuum extraction with
natural attenuation for contaminated groundwater, as the remedy
for the Mottolo site. It is a comprehensive remedy since the
source control component will be designed to ensure cleanup of
soils to allow affected groundwater to reach levels which are
protective of public health by natural attenuation in a
reasonably rapid timeframe.

In order to remediate the contamination at the site, a
groundwater interceptor trench will be constructed to dewater the
former drum disposal area soils. No such trench will be needed
at the southern boundary area. To reduce precipitation
infiltration, waterproof caps will be placed over both areas.
Vacuum extraction wells will be installed in each area and both
areas' extraction well networks will be connected to a treatment
system to be located on the existing piggery building pad. The
vacuum extraction system will draw contaminants from the soils in
both areas and treat them using carbon canisters to levels which
will allow protective groundwater cleanup levels to be attained
through natural attenuation. Confirmatory vapor sampling or
direct soil sampling and testing will be used to determine when
vacuum extraction may be decommissioned. Groundwater monitoring
will be utilized throughout the design and operation of the
vacuum extraction system to ensure that natural attenuation will
attain protective groundwater cleanup levels. Fencing and
institutional controls will be implemented which will restrict
the use of contaminated groundwater and prevent disturbance of
on-going remedial actions.
A.
Interim Groundwater Cleanup Levels
Interim cleanup levels have been established in groundwater
for all contaminants of concern identified in the Baseline
Risk Assessment found to pose an unacceptable risk to either
public health or the environment. Interim cleanup levels
have been set based on the ARARs (e.g., Drinking Water
Maximum contaminant Level Goals (MCLGs) and MCLs) if
available, or other suitable criteria described below.
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. At the time that
all the groundwater interim cleanup levels described below
have been achieved, a risk assessment shall be performed on
the residual groundwater contamination. This risk
assessment of the residual groundwater contamination shall
follow EPA procedures and will assess the cumulative risks
for carcinogens and non-carcinogens posed by consumption of
site groundwater. If the risks are not within EPA's risk
management goal for carcinogens and non-carcinogens, then
the remedial action will continue until protective levels
are attained, or the remedy is otherwise deemed protective.
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34
Because the aquifer under the site is a Class IIB aquifer,
which is a potential source of drinking water, MCLs and non-
zero MCLGs established under the Safe Drinking Water Act are
ARARs.
Interim cleanup levels for known and probable carcinogenic
compounds (Class A & B) have been set at the appropriate
MCL. The interim cleanup level for l,l-dichloroethane, a
Class C compound (possible carcinogen) has been set at the
State drinking water consumption advisory level, since
neither a Federal standard (MCL) nor cancer potency factor
exists for this compound.
Interim cleanup levels for compounds in groundwater
exhibiting non-carcinogenic effects have been set at the
MCLG, which for the compounds at this site happen to be the
same as the MCL. In the absence of a MCLG, an interim
cleanup level for non-carcinogenic effects of
tetrahydrofuran was set at a level thought to be without
appreciable risk of an adverse effect should exposure occur
over a lifetime. The interim cleanup for tetrahydrofuran
was based on an interim RfD and risk management factors
which taake into account uncertainties in the risk studies
done for the compound.
Table 5, below, summarizes the interim cleanup levels for
carcinogenic and non-carcinogenic contaminants of concern
identified in groundwater.
. .
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TABLE 5: GROUNDWATER INTERIM CLEANUP LEVELS
carcinogenic
contaminants of
Concern
Arsenic 1
Trichloroethene
vinyl chloride
1,1-Dichloroethane
Interim Cleanup
Level (ua/l)
50
5
2
81
Basis
Level of
Risk
2x10.4
2xlO.6
1x10.10
2X10.10
MCL/rsk mgmt
MCL .
MCL
SHA2
SUM:
5X10-4
Non-carcinogenic
contaminants
of Concern
Toluene
Ethylbenzene
1,2-Dichloroethene(tot.)
Tetrahydrofuran
1,1,1-Trichloroethane
Interim Cleanup
Level (ua/l)
1,000
700
703
700
200
Basis
of Toxicitv
MCLG
MCLG
MCLG
RfDIo
MCLG
Target
Endpoint
Hazard
Index
. 1
.2
.2
10
.06
Liver*
Liver*
Serum Enzymes
Liver*
Liver*
SUM*
10
The cleanup level for arsenic has been set at the MCL of
50 ug/l. The carcinogenic risk posed by arsenic at 50 ug/l
in ground water will approximate 2X10.3. However, in light
of recent studies indicating that many skin tumors arising
from pral exposure to arsenic are non-lethal in nature and
in light of the possibility that the dose-response curve for
the skin cancers may not be a direct, straight-line
relationship (in which case the cancer potency factor used
to generate risk estimates will be overstated), it is Agency
policy to view these risks as lower by as much as an order
of magnitude (x10). As a result, the carcinogenic risks for
arsenic at this site have been treated as if they were 2x10.
10. See EPA memorandum, "Recommended Agency Policy on the
Carcinogenicity Risk Associated with the Ingestion of
Inorganic Arsenic" dated June 21, 1988.
2
state health advisory, risk estimate based on cancer potency
factor of 9.1X10.2 (mg/kg/day).' derived by State
3
More restrictive MCLG for cis-1,2-dichloroethene
10
Interim cleanup level based upon interim reference dose and
risk management factors which account for uncertainties in
the risk studies
*
Sum for similar target endpoints

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~
36
EPA,has estimated that these interim cleanup levels will be
attained within six years after completion of the source
control component.

While these cleanup levels are consistent with ARARs or
suitable TBC standard for groundwater, a cumulative risk
that could be posed by these compounds may exceed EPA's
goals for remedial action. consequently, these levels are
considered to be interim cleanup levels for groundwater. In
addition, once all these levels are achieved for each
compound, EPA expects that due to different rates of
attenuation for each compound, levels of most will be below
these interim cleanup levels. Thus, when all of the interim
cleanup levels have been attained, a risk assessment will be
performed on residual groundwater contamination to determine
whether the remedial action is protective. Remedial actions
shall continue until protective concentrations of residual
contamination have been achieved or until the remedy is
otherwise deemed protective. These protective residual
levels shall constitute the final cleanup levels for this
Record of Decision and shall be considered performance
standards for any remedial action.
B.
Soils Cleanup Levels
Based upon data developed in the RI and the Baseline Risk
Assessment, remedial measures to address risk associated
with possible exposure to source soils are not warranted
because present and future risks did not exceed a 10-4
excess cancer risk or a Hazard Index of one. However,
available data indicate that source area soils are
continuing to release VOCs to groundwater. This release
results in groundwater contamination at concentrations,
which, under some exposure scenarios, are associated with
potential future risks above acceptable levels. Therefore,
cleanup levels for soils wer~ established to protect the
aquifer from potential soil leachate. The Summers Model was
used to estimate residual soil levels that are not expected
to impair future groundwater quality. The interim cleanup
levels for groundwater were used as input into the leaching
model. Tables 6A and 6B, below, summarize the soil cleanup
levels required to protect public health and the aquifer and
were developed for the groundwater contaminants of concern
detected above the interim groundwater cleanup levels in the
former drum disposal area (Area 1) and in the southern
boundary area (Area 2).
:
.

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37
".
TABLE 6A: SOIL CLEANUP LEVELS-AREA 1
"
FOR'THE PROTECTION OF HUMAN HEALTH AND THE AOUIFER BASED
ON THE SUMMERS MODEL
Carcinoqenic
contaminants
of Concern
Trich10roethene
Vinyl chloride
1,1-Dich10roethane
Non-carcinoqenic
contaminants
of Concern
Toluene
Ethylbenzene
1,2-Dichloroethene
1, 1, 1-Trich10roethane
Soil
Cleanup
Level Cma/ka)
.07
.005
.36
Basis for
Model
InDut
MCL
MCL
SHA'
Residual
Groundwater
Risk
2 xl 0.0
1x1 0-4
2x10.l,

3x10.4
Residual
Groundwater
Hazard Index
.1
.2
.2
.06
SUM*
.4
SUM:
soil
Cleanup Level
Cma/ka)
14
17.4
.46
2.1
Tarqet
Endpt of
Toxicitv
Liver*
Liver*
Serum Enzymes
Liver*
state health advisory, risk estimate based on cancer potency
factor of 9.1X10-2 (mg/kg/day).' derived by state
Basis for
Model
InDut
MCLG
MCLG
MCLG
MCLG
*
Sum for similar target endpoints
TABLE 6B: SOIL CLEANUP LEVELS-AREA 2
FOR THE PROTECTION OF HUMAN HEALTH AND THE AQUIFER BASED
ON THE SUMMERS MODEL
carcinoqenic
contaminants
of Concern
Trich10roethene
Non-carcinoqenic
contaminants
of Concern
1,2-Dichloroethene
Soil
Cleanup Level
(ma/ka)
.004
Basis for
Model
InDut
MCL
Residual
Groundwater
Risk
2xlO.o
Residual
Groundwater
Hazard Index
.2
These soi1 cleanup levels must be met at the completion of
the remedial action at the points of compliance which are
throughout the soil in the areas described below. The soil
cleanup levels will be considered to have been attained
when: 1) the levels are verified by direct soil sampling and
leachability testing; and/or, 2) the soil vapor phase VQCs
reach non-detectable levels at each well-head sampling
point. Area 1, the former drum disposal area, includes an
soil
Cleanup Level
(ma/ka)
.020
Basis for
Model
InDut
MCLG
Tarqet
Endpt of
Toxicitv
Ser. Enz.
~

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38
area of approximately 4200 square feet at a depth of from
nine to twelve feet (1400-1800 cubic yards). Area 2, the
southern boundary area, encompasses a less well defined area
of approximately 3600 square feet at about fifteen feet deep
(2000-2200 cubic yards). Further refinement of each area
will be required prior to final design to ensure that the
entire volume of soils contributing unacceptable amounts of
contaminants to groundwater is remediated.
c.
Description of Remedial components
The selected remedy, Alternative 3, is composed of 7 remedial
components: a fence; a groundwater interceptor trench; two
temporary caps; an in-situ vacuum extraction system; natural
attenuation of contaminated groundwater; environmental
monitoring; and institutional controls. Each is described below
and illustrated in Figures 3, 4, and 5.
1.
Fence
A security fence consisting of approximately 1,300 linear
feet of galvanized chain link fence ten feet high will be
installed to control access to the former drum disposal and
southern boundary areas and to provide security for the
vacuum extraction system.
2.
Groundwater interceptor trench
A groundwater interceptor trench will be installed
upgra~ient of the former disposal area. Lowering of the
upgradient overburden water table in this area will
significantly reduce groundwater flow through contaminated
soils and, accordingly, migration of contaminants from the
drum disposal area. Dewatering will facilitate VES
treatment of that portion of contaminated soils that is
currently saturated by groundwater, significantly increasing
the effectiveness of source control. Based upon a numerical
groundwater flow model, it is estimated that a period of
approximately three to nine months will be required to
dewater soils in the former disposal area; however,
installation of the VES can be initiated prior to completion
of dewatering. No dewatering will be required for the
southern boundary area since the overburden soils remain
unsaturated for most of the year.
3.
Two temporarY caps
The ground surface in both the former drum disposal area and
the southern boundary area will be sealed with temporary
caps consisting of four or six-mil thick visqueen sheeting
covered with a six inch layer of seeded loam. This will
improve the operational efficiency of the VES by limiting
.-

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39
.,
short-circuit air flow from the ground surface to the
extraction wells and significantly reducing precipitation
infiltration. The caps will remain in place and be
effective for the expected operational period of the VES,
but they will not be designed to maintain their integrity on
a permanent basis.
4.
In-situ vacuum extraction svstem
Air and vapor phase VOCs present in the soil pore space
(soil gas) in the former drum disposal and southern boundary
areas will be removed by inducing a vacuum on extraction
wells that extend vertically to the top of bedrock and are
screened from bedrock to two to three feet below ground
surface (see Figure 6). The. soil gas will flow through the
soil pore space to the extraction wells and would be
replaced by ambient air induced to flow into the soil by the
negative pressure or from air injection wells, if found to
be necessary during the design phase. VOCs adsorbed onto
soils will partition from the soils into the replacement air
and be removed by the vacuum system.
The vacuum extraction treatment equipment will be placed in
a building on the existing, large piggery building pad. A
vacuum pump will transfer the soil gas (from each source
area) containing VOCs through a moisture trap, installed at
the suction of the vacuum pump, and discharge into vessels
containing granular activated carbon beds. Liquid from the
moisture trap will be collected, analyzed, and transferred
to off-site treatment and/or disposal, based upon the
results of the analyses, in compliance with Federal and
state requirements. The VOCs in the soil gas will be
adsorbed by the carbon beds and the treated air discharged
to the atmosphere. See Figure 5. The carbon beds will
either be regenerated on-site using steam or sent off-site
for regeneration or disposal in compliance with Federal and
State requirements. In the case of on-site regeneration,
VOCs desorbed from the carbon would be collected with steam
condensate and transferred off-site for treatment and/or
disposal in compliance with Federal and State requirements.
Pressure monitoring gauges installed on the manifold piping
and in the ground at selected locations will provide
information regarding performance of the vacuum system.
Valves installed in the piping will, if warranted, be used
to adjust the vacuum exerted on various parts of the
collection systems.
Performance of the VES will be assessed by monitoring vapor
quality at the heads of individual collection points and at
the effluent air discharge. To optimize VES performance,
vacuum exerted at different points in the system might be
-
.

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:
40
adj~sted using control valves in response to vapor screening
or ~oil screening results, as previously discussed, or
additional extraction wells might be installed. It is
estimated that approximately one year will be required to
complete source remediation using the VES, although the
actual time may vary because of variability in subsurface
conditions. This estimate was based upon analysis of site
conditions, the estimated mass of VOCs in the soil,
anticipated VOC mass transfer rates, and estimated air flow
rates. operation of the VES will continue until VOCs are
not detected in air discharged from the VES and in air at
the collection point well heads. After VES operation
ceases, the vapor will continue to be monitored at the
individual well heads to determine if additional
volatilization occurs, in which case the VES will be
operated again unless direct soil sampling and leachability
testing indicate that soil cleanup levels have been met.
The VES equipment may be decommissioned and removed if no
VOCs are detected for one year after cessation of VES
operations and if the rate of groundwater cleanup is
proceeding such that the groundwater cleanup levels will be
met within six years after VES operation ceases.
Appropriate air monitoring methods and frequencies will be
established during remedial design to ensure that
statistically significant results will be used to determine
the appropriate time to cease operations and decommission
VES equipment.
When it is finally determined that VES operations have been
completed, soils in the source areas will be regraded, if
appropriate, and covered with a soil cover of approximately
six inches to one foot to provide positive drainage and
reduce precipitation infiltration. The cover will be
vegetated to limit possible erosion.
5.
Natural attenuation of contaminated aroundwater
Natural attenuation relies on groundwater attaining lower
contaminant concentrations through physical, chemical and
biological processes until groundwater cleanup levels are
met. After completion of source remediation at each of the
two areas, no further contamination will be added to the
groundwater at levels which would prevent attainment of the
groundwater cleanup levels. Based upon the hydrogeology of
the site, leachability studies conducted, and a simplified
mathematical model, it is expected that overburden
groundwater which has been affected by the former drum
disposal area soils will clean itself to the groundwater
cleanup levels within approximately six years after
completion of source remediation. Bedrock groundwater, due
to higher velocities and fewer opportunities for
adsorption/desorption to occur, should attain groundwater
~

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41
G
cleanup levels earlier. For the bedrock groundwater
affected by the southern boundary area soil contamination
.(no appreciable overburden groundwater was found in this
area), approximately two years will be needed to achieve
groundwater cleanup levels.
6.
Environmental monitorina
Groundwater and surface water monitoring will be initiated
during remedial design and continue for three years after
attaining groundwater cleanup levels to assess the
effectiveness of remediation and to confirm that contaminant
concentrations in groundwater attain cleanup levels. If at
any time during the implementation of the remedy an
evaluation of the groundwater monitoring data indicates that
the groundwater cleanup levels will not be met or are not
met within six years after completion of soil remediation
for the former drum disposal area or within two years after
completion of soil remediation for the southern boundary
area, then a detailed re-analysis of the nature and extent
of contamination at the site will be conducted and another
remedy proposed, if appropriate.
The groundwater monitoring program will be developed for the
following purposes:
.
to evaluate the effectiveness of the source
remediation measures to allow attainment of the
groundwater cleanup levels; and

to monitor the reduction of contaminant
concentrations over time in order to ensure
groundwater cleanup levels will be achieved
predicted timeframes.
that
in the
.
The details of the groundwater monitoring program will be
developed during remedial design and tailored to the
specifics of the design. Additional groundwater monitoring
wells will be installed in order to ensure that the
objectives of the monitoring program are achieved.
specifically, additional wells will be installed to define
the extent of the southern boundary area plume and to
determine the northwesterly edge of the plume emanating from
the former drum disposal area. Selected overburden and
bedrock wells will be monitored quarterly upon initiation of
remedial design until completion of the remediation.
Subsequent sampling frequencies will be determined by EPA
prior to completion of soils remediation. All samples will
be analyzed for Hazardous Substance List VOCs,
tetrahydrofuran, and arsenic. Specific wells and analytical
parameters may be added or deleted depending on sampling
results and observed trends.

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:
42
A s~rface monitoring program will be developed to ensure
that as the contaminants continue to discharge to Brook A,
no adverse environmental impacts result. Three surface
water stations, one at the headwaters of Brook A, one
upstream and one downstream of the former drum disposal
area, will be established and sampled. Sampling would occur
concurrently with the groundwater monitoring and samples
will be analyzed for Hazardous Substance List VOCs,
tetrahydrofuran, and arsenic. Specific analysis parameters
may be added or deleted and the frequency of sampling may be
adjusted depending on sampling results and observed trends.

All monitoring data will. be reviewed and evaluated during
the implementation of the remedial action to ensure that
response objectives are achieved. Adjustments to the vacuum
extraction system will be implemented to optimize treatment.
Modifications to the remedial action, including
implementation of a new remedy, if appropriate, will be
considered if the monitoring program shows that the
groundwater will not attain the target levels within the
period of time specified in this remedy or that the remedy
is not adequately reducing risks to human health and/or the
environment that are posed by current or future exposure to
site contaminants.
7.
Institutional controls
Institutional controls will be implemented which would
restrict the use of contaminated groundwater and prevent
disturbance of on-going remedial actions. The objectives of
the institutional controls shall be to ensure that no
activities take place at the Site or in proximity to the
Site which would either affect implementation of the
selected remedy or cause exposures to hazardous substances.
Examples of acceptable institutional controls include use
restrictions imposed on deeds and zoning ordinances, among
others.
To the extent required by law, EPA will review the site at least
once every five years after the initiation of remedial action at
the site if any hazardous substances, pollutants or contaminants
remain at the site to assure that the remedial action continues
to protect human health and the environment. EPA will also
evaluate risk posed by the Site at the completion of the remedial
action (i.e., before the Site is proposed for deletion from the
NPL).
:

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,
43
XI.
STATUTORY DETERMINATIONS
The remedial action selected for implementation at the Mottolo
site is consistent with CERCLA and, to the extent practicable,
the NCP. The selected remedy is protective of human health and
the environment, attains ARARs and is cost effective. The
selected remedy also satisfies the statutory preference for
treatment which permanently and significantly reduces the
mobility, toxicity or volume of hazardous substances as a
principal element. Additionally, the selected remedy utilizes
alternate treatment technologies or resource recovery
technologies to the maximum extent practicable.
A.
The Selected Remedy is Protective of Human Health and
the Environment
The remedy at this Site will permanently reduce the risks
posed to human health and the environment by eliminating,
reducing or controlling exposures to human and environmental
receptors through treatment, engineering controls, and
institutional controls; more specifically, YES for treatment
of contaminated soils, and restrictions on the use of
contaminated groundwater to prevent activities which would
result in exposure to contaminated groundwater. Moreover,
the selected remedy will result in human exposure levels
that are wi thin the 10." to 10.6 incremental cancer risk
range, at MCLs, or at health advisories and that are within
the hazard index of one or within health advisories for non-
carcinogens. More specifically, the final groundwater
cleanup levels will be determined as the result of a risk
assessment performed on residual groundwater contamination
after all interim cleanup levels have been met. Unless the
resultant cumulative risk is within the 10." to 10.6
incremental risk range and the cumulative hazard index for
similar target endpoints is less than one, remedial actions
shall continue until protective levels are attained.
Finally, implementation of the selected remedy will not pose
unacceptable short-term risks or cross-media impacts; i.e.,
use of the in-situ VES minimizes exposures to workers and
adjacent populations during construction, carbon adsorption
will prevent air releases of VOCs, and natural attenuation
will result in continually decreasing air emissions (which
are currently at non-detectable levels) and attainment of
groundwater cleanup levels within a reasonable timeframe.
B.
The Selected Remedy Attains ARARs
This remedy will attain all applicable or relevant and
appropriate federal and state requirements that pertain to
the site. Environmental laws from which ARARs for the
selected remedial action are derived, and the specific ARARs
include:
--

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:
44
Resource Conservation and Recovery Act (RCRA):
Clean Water Act (CWA):
Safe Drinking Water Act (SDWA):
Executive Order 11990 (Protection of Wetlands):
Clean Air Act (CAA):
occupational Safety and Health Act (OSHA): and
New Hampshire Hazardous Waste Act.

The following criteria have also been considered under the
category of To-Be-Considered (TBCs) during the selection of
the remedy:
. "
. 
. 
. 
. 
. 
. 
",
~
.
state Drinking Water Criteria and consumption
Advisories.
A listing of ARARs and TBCs are found in Tables 7, 8 and 9,
except for RCRA action-specific regulations, as explained
below. These tables (included in Appendix B) provide a
brief synopsis of the requirements, what action is necessary
to meet the ARAR, and whether the ARAR is applicable,
relevant and appropriate, or to-be-considered. A brief
narrative summary of the principal ARARs and TBCs follows.
The NCP requires CERCLA remedial actions to attain MCLGs, or
MCLs when the MCLG has been set at a level of zero, if the
non-zero MCLG or MCL is determined to be relevant and
appropriate. The principal chemical-specific ARARs are MCLs
for carcinogenic compounds and non-zero MCLGs for non-
carcinogenic compounds established in the Safe Drinking
Water,-Act, 40 CFR 141.1 - 141.16 and 40 CFR 141.50 - 141.52,
respectively. These have been determined to be relevant and
appropriate as in-situ cleanup standards, since the aquifer
is considered to be Class IIB, a potential drinking water
source. MCLs and MCLGs were used to help set the
groundwater cleanup levels, as well as, the soil cleanup
levels. The specific MCLs which are ARARs for carcinogenic
compounds include: trichloroethene, 5 ug/li vinyl chloride,
2 ug/l; and arsenic, 50 ug/l. Since no MCL or non-zero MCLG
has been promulgated and none proposed for 1,1-
dichloroethane, the State of New Hampshire Department of
Public Health Service consumption advisories for water
supplies, which have been determined to be a TBC, were used
for l,l-dichloroethane in setting site cleanup levels for
groundwater and soil. The level to be met for 1,1,-
dichloroethane is 81 ug/l in the groundwater. The specific
non-zero MCLGs which are ARARs for non-carcinogenic
compounds include: 1,1,1-trichloroethane, 200 ug/li
toluene, 2000 ug/li and ethyl benzene, 700 ug/l. The
Proposed MCLG has been determined a TBC for 1,2-
dichloroethene (70 ug/l for cis- and 100 ug/l for trans-
isomers) since no MCL or MCLG has, as yet, been promulgated
for those compounds.
.-

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45
with respect to location-specific ARARs, the Executive Order
concerning wetlands and Section 404 of the Clean Water Act
are applicable to this site. No practicable remediation
alternative exists to the selected remedy which would have
less adverse environmental impact on the site's wetlands.
The no action alternative would have less adverse impacts,
but it is not practicable since it cannot attain other ARARs
or be protective of public health. All other alternatives
involve similar disturbance of the drainage swale wetlands
with the exception of Alternative 8 which would, also,
adversely affect the wetlands near Brook A. Since there is
no practicable alternative, the remedy in the wetlands will
be undertaken in such a manner to avoid or minimize the
destruction, loss and degradation of site wetlands and to
preserve and enhance the natural and beneficial use of
wetlands.
The principal action-specific ARARs include New Hampshire
Hazardous Waste Rules which incorporate by reference RCRA
standards for the treatment, storage, and disposal of
hazardous wastes. These State regulations are currently
undergoing EPA review. If EPA determines that these State
regulations are more stringent than RCRA regulations, then
the state regulations shall be ARARs. If not, the
comparable RCRA citation presented in the ARAR Table will
control. These standards are relevant and appropriate to
the design, construction and operation of the vacuum
extraction system, since it will be handling, treating and
disposing of hazardous waste and hazardous waste
cons~ituents sufficiently similar to RCRA regulated wastes
to warrant compliance with RCRA standards. Land Disposal
Restrictions (LDRs) are not ARARs for this site because no
RCRA wastes have been identified and because no on-site
placement of wastes will occur as part of the selected
remedy.

All OSHA requirements for worker health and safety during
hazardous waste operations and general construction
standards are applicable during implementation of this
remedy.
C.
The selected Remedial Action is Cost-Effective
In the Agency's judgment, the selected remedy is cost
effective, i.e., the remedy affords overall effectiveness
proportional to its costs. In selecting this remedy, once
EPA identified alternatives that are protective of human
health and the environment and that attain ARARs, EPA
evaluated the overall effectiveness of each alternative by
assessing the relevant three criteria -- long-term
effectiveness and permanence; reduction in toxicity,

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~
46
effectiveness, in combination. The relationship of the
overall effectiveness of this remedial alternative was
determined to be proportional to its costs. The costs of
this remedial alternative are: estimated capital cost -
$410,00; present worth of operation and maintenance cost -
$280,000; total present worth cost $690,000. Other than the
no action alternative, which does not meet ARARs and is not
protective, this is the least expensive alternative. This
alternative is more effective in the short-term than any
other alternative and is as or more effective than the other
alternatives in long-term effectiveness and in reduction of
toxicity, mobility, and volume.
D.
The Selected Remedy Utilizes Permanent Solutions and
Alternative Treatment or Resource Recovery Technologies
to the Maximum Extent Practicable
Once the Agency identified those alternatives that attain
ARARs and that are protective of human health and the
environment, EPA identified which alternative utilizes
permanent solutions and alternative treatment technologies
or resource recovery technologies to the maximum extent
practicable. This determination was made by deciding which
one of the identified alternatives provides the best balance
of trade-offs among alternatives in terms of: 1) long-term
effectiveness and permanence; 2) reduction of toxicity,
mobility or volume through treatment; 3) short-term
effectiveness; 4)implementability; and 5) cost. The
balancing test emDhasized long-term effectiveness and
permapence and the reduction of toxicity, mobility and
volume 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 remedy provides the best balance
of trade-offs among the alternatives.
Alternatives 1 and 2 do not employ permanent solutions or
treatment so that no reduction of toxicity, mobility or
volume through treatment is achieved. The remaining
alternatives all provide a similar degree of long-term
effectiveness through a reduction in toxicity, mobility, and
volume through treatment. The selected remedy, however,
achieves the same level of long-term effectiveness as any
other alternative while being the most effective in the
short term .at the ~owest cost. Its long-term effectiveness
relies on two components, one of which is an alternative
treatment technology, in-situ VES for soil remediation, and
natural attenuation for contaminated groundwater
remediation.

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47
The..use of in-situ VES has advantages of lower impacts
during construction and operation over each of the other
alternatives (Alternatives 4,5,6,7) utilizing source control
technologies which would require excavation and, thus, a
potential for VOC releases. While Alternative 8, also,
would use in-situ VES for source control, the use of the
groundwater extraction system would have significant adverse
impacts on the site's wetlands without.a significant
improvement in protectiveness and at a greater cost.
In addition, the selected remedy would be more easily
implemented than any of the other alternatives considered,
with the exception of Alternatives 1 and 2 (which would not
employ treatment).
The long-term effectiveness of the selected remedy is
upon the in-situ VES being as efficient in treating
contaminated soils as the source control component of
the other alternatives and on the natural attenuation
contaminated groundwater being as effective as the
groundwater extraction and treatment component in
Alternative 8.
based
any of
of
Based upon the comments received during the public comment
period and the reactions from attendees of public
informational meetings, there appears to be community
acceptance of the selected remedy. The state acceptance is
documented in the declaration of concurrence which is
attached as Appendix C.
E.
The Selected Remedy satisfies the Preference for
Treatment Which Permanently and significantly reduces
the Toxicity, Mobility or Volume of the Hazardous
substances as a Principal Element
The principal element of the selected remedy is the source
control component, an in-situ VES. This element addresses
the primary threat at the site, contamination of groundwater
through continuing releases of VOCs from site soils. The
selected remedy satisfies the statutory preference for
treatment as a principal element by removing VOCs from
source area soils (using in-situ vacuum extraction with
carbon filtration of the off-gases) to levels which will
allow the groundwater to attain cleanup levels in a
reasonably rapid time frame through natural attenuation.

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-
.
48
%11. DOCUMENTATION OF NO SIGNIFICANT CHANGES
.j'
EPA presented the Proposed Plan (preferred alternative) for
remediation of the site on February 13, 1991. The elements of
the preferred alternative included: a fence; a groundwater
interceptor trench; two temporary caps; an in-situ vacuum
extraction system; natural attenuation of contaminated
groundwater; environmental monitoring; and institutional
controls.
No significant changes from the Proposed Plan have been made to
the selected remedy as detailed in this Record of Decision.
%111.
STATE ROLE
The New Hampshire Department of Environmental Services has
reviewed the various alternatives and has indicated its support
for the selected remedy. The State has also reviewed the RI,
Risk Assessment and FS to determine if the selected remedy is in
compliance with applicable or relevant and appropriate state
Environmental laws and regulations. The Department of
Environmental Services concurs with the selected remedy for the
Mottolo site. A copy of the declaration of concurrence is
attached as Appendix c.
-
.

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APPENDIX A
Figures

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"
.
.
o

I
2000
4000
6000
A~~~ ~.J. QUINN &
COMPANY. INC.
1Tn£ 
a JD.JS'IIIW. .,. y. t..t.U1A. ~ 0307'1 SHE LOCUS
 PLAN
D,\'T[ av... rrr CMDCIJ) I'IIO£CT 
9/13/90 M.F.J. T.S.S. MOTTOLO SITE
 RIfFS
s:AI.[ nL NO. JI"f'f«Na) J1Ca.R NO. I"IIIO.IJ:T NO.
AS SHOVrW RI2 LC.S. 1 6185/818
JURCE:
USGS, 1981, SANDOWN QUADRANGLE,
NEW HAMPSHIRE, US GEOLOGICAL SURVEY
7.5' SERIES (TOPOGRAPHIC), 1981

USGS, 1981, MT. PAwnJCKAWAY QUADRANGLE.
NEW HAMPSHIRE. US GEOlOGICAl SURVEY
7.5' SERIES (TOPOGRAPHIC), 1981
SCALE (FEET)

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I
I
I
I
I
I
I
,
,
i'
,
,
,
"'...
...
...
"'... ...
,
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 RI/FS 
-------
APPENDIX B
Tables
-
. .
-------
CURRENT RISK
DERMAL CONTACT AND INCIDENTAL INGESTION
TABLE 1
SITE SOIL
Nonarcinogenic Risk:
Endpoint
of
Concern
Noncarcinogenic
Indicator compounds
Oral
Ref. Dose
(mg/kg/day)

"1. OX10.1
1.0xlO.1
2.0
CONCENTRATIONS
HAZARD INDEX
Average Max.
(mg/kg) (mg/kg)
Average
Maximum
Ethylbenzene
Toluene
Total Xylenes
Liver
nerve sys.
nerve sys.
1. 4xlO.5 4.. 5xl0.'
* 2. 2xl0.6 * 5. Oxl0.5 .
* 1. 8xl0.6 * 4. 3xl0.5
* SUM 4. Oxl0.o 9. 3xl0.'
*******************************************************************************************************
SEDIMENT
Lifetime Cancer Risk:
Potentially Carcinogenic
Indicator Compounds
weight of
Evidence
1,1-Dichloroethane
C
Noncarcinogenic Risk:
Endpoint
of
Concern
Noncarcinogenic
Indicator Compounds
Oral Cancer
Potency Fact.
(mg/kg/day) -1

9.1xlO.z
Oral
Ref. Dose
(mg/kg/day)
9.2
4.1
22
140
47
270
CONCENTRATIONS LIFETIME CANCER RISK
Average Max.   
(mg/kg) (mg/kg) Average Maximum
0.068 0.36 2. 8xl0.10 1.4xl0.9
CONCENTRATIONS HAZARD INDEX
Average Max.   
(mg/kg) (mg/kg) Average Maximum
",1, 1, l-Trichloroethane Liver 9.0xlO.z 0.019 0.064 6.7xlO.a 5.7Xl0.7
*~*****************************************************************************************************
SURFACE WATER
Lifetime Cancer Risk:
potentially Carcinogenic
Indicator compounds
weight of
Evidence
l,l-Dichloroethane
C
Noncarcinogenic Risk:
Endpoint
of
Concern
Noncarcinogenic
Indicator compounds
1,2-Dichloroethene
( tota 1 )
Serum Enzymes
Oral Cancer
Potency Fact.
(mg/kg/day) -1

9.1X10.Z
Oral
Ref. Dose
(mg/kg/day)

2.0xlO-2
CONCENTRATIONS LIFETIME CANCER RISK
Average Max.  
(mg/l) (mg/l) Average Maximum
0.007 0.041 1.7xlO.a 2. 4Xl0-7
CONCENTRATIONS HAZARD INDEX
Average Max.  
(mg/l) (mg/l) Average Maximum
-------
FUTURE RISK
DERMAL CONTACT AND INCIDENTAL INGESTION
SITE SOIL
Nonarcinogenic Risk:
" Noncarcinogenic
Indicator Compounds
Endpoint
of
Concern
Oral
Ref. Dose
(mg/kg/day)

"1. Ox10.1
. 3. Ox10'1
2.0
CONCENTRATIONS
TABLE 2A
HAZARD INDEX
Average Max.
(mg/kg) (mg/kg)
Average
Maximum
1.1x10'4 3. 5x10']
* 1. 6X10.5 * 4. OXIO.4
* 1. 3x10'5 * 3. 4x10'4
*SUM 2. 9x10') 7. 4xlO'r.
********************************************************************************************************
SEDIMENT
Lifetime Cancer Risk:
Ethylbenzene
Toluene
Total Xylenes
Liver
Nerv. Sys.
Nerv. Sys.
Potentially ~~rcinogenic
Indicator compounds
Weight of
Evidence
1,1-Dichloroethane
C
Noncarcinogenic Risk:
Noncarcinogenic
Indicator Compounds
Endpoint
of
Concern
Oral Cancer
Potency Fact.
(mg/kg/daY)-l

9.0x10'2
Oral
Ref. Dose
(mg/kg/day)
9.2
4.1
22
140
47
270
CONCENTRATIONS
LIFETIME CANCER RISK'
Average Max.
(mg/kg) (mg/kg)
0.068
Average
1. 3x10'9
0.36
CONCENTRATIONS
Maximum
1.7xlO'8
HAZARD INDEX
Average Max.
(mg/kg) (mg/kg)
Average
Maximum
1,1,1-Trichloroethane Liver 9.0x10.2 0.019 0.064 2.0x10.7 1.7X10'6
. ***********************.********************************************************************************
.. .
SURFACE WATER
Lifetime Cancer Risk:
Potentially Carcinogenic
Indicator compounds
Weight of
Evidence
1,1-Dichloroethane
C
Noncarcinogenic Risk:
Noncarcinogenic
Indicator Compounds
Endpoint
of
Concern
1,2-Dict
roethene
tal)
Serum Enzymes
Oral Cancer
Potency Fact.
(mg/kg/day)-l

9.1x10'2
Oral
Ref. Dose
(mg/kg/day)

2. Ox] - .~
CONCENTRATIONS
LIFETIME CANCER RISK
Average
(mg/ I)
0.007
Max.
(mg/l)
Average
7.8x10'8
0.041
Maximum
1.1XIO'6
CONCENTRATIONS
HAZARD INDEX
Average
(mg/l)
0.003
Max.
(mg/l)
Average
8.5xlO'5
0.009
Maximum
-------
FUTURE RISK FROM AREA 1 - BEDROCK AND OVERBURDEN
INGESTION AND DERMAL CONTACT OF GROUND WATER
BEDROCK       
Lifetime Cancer Risk:    CONCENTRATIONS
     Oral Cancer  
Potentially Carcinogenic Weight of Potency Fact. Average Max.
Indicator Compounds Evidence (mg/kg/day) -1 (mg/l) (mg/l)
Arsenic   A 1.8  0.028 0.14
1,1-Dichloroethane C .9. 1X10-Z 0.032 0.22
Trichloroethene  82 1. 1xlO.Z 0.032 0.19
Vinyl Chloride  A 2.3  0.029 0.33
        SUM:
Noncarcinogenic Risk:    CONCENTRATIONS
    Endpoint Oral  
Noncarcinogenic of Ref. Dose Average Max.
Indicator Compounds Concern (mg/kg/day) (mg/l) (mg/l)
TABLE 2B
LIFETIME CANCER RISK
Average

1.4xlO.3
8.3X10.5
1. OX10.5
1. 9X10.3
3.0xlO..3
HAZARD
Maximum
7.2x10.3
5.7xlO.4
6.0X10-S .
2.2xlO.Z
3.0xlO'l
INDEX
Average
Maximum
Serum Enzymes
Liver *
Liver *
Nerv. Sys.
Liver *
1.9 2.7xlO.' 2.7
0.052 * 4.6xlO.3 *1.5xlO.z
1.6 * 2.9 *2.3xlO
0.44 3.lxlO.3 4.2x10.z
0.003 * 9.5X10.4 *9.5xlO.4
*SUM: 2.9 2.3xlO
********************************************************************************************************
1,2-Dichloroethene (tot.)
Ethylbenzene
Tetrahydrofuran
Toluene
1, 1, l-Trichloroethane
2.0X10'Z
1. ox10.'
2.0x10.3
3.0xlO.'
9.0X10.Z
0.19
0.016
0.2
0.033
0.003
OVERBURDEN        
Lifetime Cancer Risk:     CONCENTRATIONS 
      Oral Cancer   
Potentially Carcinogenic Weight of Potency Fact. Average Max.
.. Indicator Compounds Evidence (mg/kg/day) -1 (mg/l) (mg/l) 
Arsenic  A  1.8  0.19 0.57 
 1,1-Dichlorethane  C  9. lx10.z 0.25 1.3 
Trichloroethene  82  1. 1x10.z 0.15 2.4 
Vinyl Chloride  A  2.3  0.04 0.36 
         SUM: 
 Noncarcinogenic Risk:     CONCENTRATIONS 
    Endpoint Oral   
 Noncarcinogenic  of Ref. Dose Average Max. 
Indicator Compounds  Concern (mg/kg/day) (mg/l) (mg/l) 
1,2-Dichloroethene (tot.) Serum Enzymes 2. OX10.z 0.67 4.7 
 Ethylbenzene  Liver * 1.0X10.' 0.26 1.7 *
 Tetrahydrofuran  Liver * 2. oxlO.3 0.043 0.22 *
 Toluene  Nerv. Sys. 3. ox10" 1.2 9.2 
 1, 1, l-Trichloroethane  Liver * 9. ox10'z 0.16 2.1 *
         *SUM: 
LIFETIME CANCER RISK
Average

9.8X10.3
6.5xlO.4
4.7xlO.S
2.6X10.3
1x10-l
Average

9.6X10"
7 . 4xlO'Z
6.2xlO"
1.1X10.'
5.1Xl0'Z
7.4xlO'1
Maximum
2.9x10'Z
3.4x10'3
7.5XIO.4
2.4X10'Z
6x10.l
HAZARD INDEX
Maximum
6.7
* 4. 9xlO.'
* 3.1
8.8xl0"
* 6. 7xl0.1
-------
BEDROCK
Lifetime Cancer Risk:
Potentially carcinogenic
Indicator Compounds
Trichloroethene
Noncarcinogenic Risk:
Noncarcinogenic
Indicator Compounds
FUTURE RISK FROM AREA 2 - BEDROCK AND OVERBURDEN
INGESTION AND DERMAL CONTACT OF GROUND WATER
Weight of
Evidence
B2
Endpoint
of
Concern
Oral Cancer
Potency Fact.
(mg/kg/day)-l

1.1x10.2
Oral
Ref. Dose
(mg/kg/day)
CONCENTRATIONS
TABLE 2C
LIFETIME CANCER RISK
Average
(mg/l)
0.3
Max.
(mg/l)
Average
9.4x10-S
1.1
CONCENTRATIONS
Maximum
-4
. 3.5x10
HAZARD INDEX
0.11
4.1x10-2
Average
(mg/l)
Max.
(mg/l)
Average
Maximum
2.0x10.2
1.6x10-'
1,2-Dichloroethene
total)
Tetrahydrofuran Liver 2.0x10.3 0.076 0.23 1.1 3.3
~*******************************************************************************************************
OVERBURDEN
Lifetime Cancer Risk:
Potentially Carcinogenic
Indicator Compounds
Trichloroethene
,
~Noncarcinogenic Risk:
I
I
Noncarcinogenic
Indicator Compounds
1,2-Dichloroethene
(total)
Tetrahydrofuran
Serum Enzymes
Weight of
Evidence
B2
Endpoint
of
Concern
Serum Enzymes
Liver
Oral Cancer
Potency Fact.
(mg/kg/day)-l

1.1x10'2
Oral
Ref. Dose
(mg/kg/day)

2.0x10'2
2.0x10'3
0.029
CONCENTRATIONS
LIFETIME CANCER RISK
Average
(mg/l)
0.036
Max.
(mg/l)
Average
1.1x10.S
0.12
CONCENTRATIONS
Maximum
3.8x10-S
HAZARD INDEX
Average
(mg/l)
0.001
0.005
Max.
(mg/l)
Average
1.4x10.3
0.001
0.009
7.2X10-2
Maximum
1.4x16-3
-------
TABLE 3
COMPREHENSIVE ALTERNATIVES
'I
Alternative 1: No Action
q
SC-l and MOM-l
Alternative 2: Groundwater interceptor trench and capping with
natural attenuation of groundwater contamination
SC-2 and MOM-2
Alternative 3: In-situ vapor extraction system (VES) with natural
attenuation of contaminated groundwater
SC-3 and MOM-2
Alternative 4: Above ground vapor extraction system with natural
attenuation of contaminated groundwater
SC-4'and MOM-2
Alternative 5: Chemical fixation with natural attenuation of
contaminated groundwater
SC-5 and MOM-2
Alternative 6: On-site Low Temperature Thermal stripping (LTTS)
with natural attenuation of contaminated
groundwater
SC-6 and MOM-2
Alternative 7: Off-site Incineration with natural attenuation of
contaminated groundwater
SC-7 and MOM-2
Alternative 8: In-situ Vapor Extraction system (VES) treatment of
soils with collection and treatment of groundwater

SC-8 and MOM-3
SOURCE CONTROL ALTERNATIVE SCREENED OUT
SC-7 On-site thermal destruction
MANAGEMENT OF MIGRATION ALTERNATIVE SCREENED OUT
MOM-4
Collection and off-site treatment of groundwater
-------
TABLE 4
IDrroW REroRD OF DOCISlOO
Page 1 of 6
  8UJof,.fARY OF' AIIArt. ANALYSIS       
  ,.lOtTOLO 5UI'[IIF'UNO SITE       
  RAYMOND. /fEW IWfl'SlII1lE       
  AllAR Allo..otl.. I Alle,.otl.. . Alloreoll.. , AII.-..U.. . Alto...tI... AlIen.tI... Alton.d.. , AJto...U.. .
  rEDEItALI        
  ClfEMICAL.SI'ECIFIC,        
  '!'rIehl.,..lh.n, ,.,d".1 MCL of ,ed,,.t MCL.r ... Altom,lI.. 2. ... AlIe",.II... 2. ... Al18""lh, 2. ... Aile..,.... I. ... Alleno,lI.. 2. redorel MCL.r
   I ppb will 1101 ... I .... IhouJ. ... _t      . ,pi> ,......... ... -,
   ,,"Iln ,118 ,.....noI In ....un" ....,      .. ......... _..,
   .....,. withlll . ,.....      wlthl. ,,,ratmaJel,.
          "0'''''
  VI.,I ChI.rld. ,.010,.1 MCL or ,ed."t MCL of Boo AI..""II.. 2. ... AI"""II.. 2. Soo Aile"""" I. Boo AlIe""II.. 2. ... Al18""I1'" 2. redor,' NCLor
   2 ,,10 will not ... ....t 2 .pI> ohou" ... _t      I ,pi> ,... ... ...,
   In ,118......"d .,,,,. In ...un' .,to,      ... ......,.. ..,..,
    within' J"'"      wlthl. ,,,...dmaJel,
          .,......
  An..te F.d.,.1 MCL or ,...,.1 MCL or ... Altom,II". 2. ... Allenl,lI.. 2. Soo Al18""I1'" 2. Boo Aile..,.... I. ... Al18""II.o I. "'0,.1 McL of
   10 ,pb will 1181 ... 10 pplo ,"'w' ... _t      10 .pI> .uld ... _t
   ....1 In ,118 ...un. ... "'''11' .'18'      ... ......,.. _18'
   ..18'. wlthlll . ,..,..      wlthl. ."rod-Jel,
          ''''''''
  1...1.1.2. '04,,.1 MCL.r ,...,,1 MCL or ... Allem,II", 2. ... Alto..,II.. 2. ... Al18""II"o 2. S. AlIe""II.. 2. ... Al18""II.. 2. redorol MCL or
. b~"Io,..lh,., 100 ,pb win not ... 100 .... ,...... ...      100 .pI> ,houl" ...
. .  ....1 In ,Ito ...und _I In .......... ..,to,      _I I.. .-an" -...
.  ..a.,. wlthl. . ,.....      wlthl.. ."rod....tot
          . ,,-
  EI"""'.oo., F.oI,..1 MCL.r ,....01 Met. of ... AlIe".,II.. I. ... Alto...II.. I. ... AI..""II". 2. !lee AI""""" I.  ... Alieni..... 2. ,..,..I Net. '"
   700 ,plo win ...t ... 100 .pb ....... ...  
   ....1 In ,Ito ......,.d _I I. ........ .,18,      100 ..... ,hould ...
   ...ltr. wlthl. . J"'"      _t I. Ift'U'd .,,,,
        ..thiD ,,,rodm,tol;
  T.I"on, F.oIor" MCL.r ',d.,,1 MCL.r ... AI..""II". 2. ... AI"m,II", 2.    . ""'.'
   2000 ,pi> will ...t... 2OOOppb..........   ... AI"""II.. 2. S. AlIe""II.. I. ... AlII..,II.. 2. ,.....1 Met. of ....
   ...11. "" ......,d _t In"""" .,,,,      2OOO.pI> ,,,.
   ....,. wlthl. . ,..,..      ...1 I.. .-d ..18'
         ..thl. ."mlm.tol)
  1.1.1.1'rIchlo,oolhl.' ,..01.,.1 MCL.r '0'.,,1 MCL or ... AI..""II". 2. ... Al18""I1". 2.    . ,.....
   200 ,pi> will ...1 ... 200 ,pb ....... ...   ... AlIe""II.. I. ... AlIe""II..!. ... Al18""I1". 2. ,...,., Met. of
   In lil8 ,",,,"" .,1.,. mol I. ........ .,18,      100 ..... ,"01 ...
    withl. . ,..,..      _t I. .....,., .....,
          ..thl. ."rod....tol,
-------
TABLE 4
IDrroID REL'ORD OF DOCISICN
Page 2 of 6
 AIL.rDIU.. 1 AU.reoll". I AlIe...ou". I AlienoU... . Aller.oU". I AlteraoU... . AI""'oU... ,  AI""'oll... .
AltAR       
LOCATION-SP£CIFIC,         
 Nol .pplicablo. WlII_L WiII_L WIII_L WiII_L WlII_L WIII-L " ~-L
[1I...li.. Ordor  
11'88 (J1oodploin         
MU'lllmlnt).         
Evll...te potenll.1         
.lTleta .1 Iclion .nd         
Umil or miti,lle         
I w-oid Ich.,..         
Imp.cll.         
£.oocull.. Ordo, NDI oppllcabl.. MlnlraoIlmpoda 18 WDI-.L See Alt.om.lI"o I. ImpocU pooolblo 18 s.o Aile. n.lI... II. .. AlIe..oll.. ..  Iat,ocU poooIbI. 18
IIVIIO (W.llind  droln... "01.   dr.lno.. 0.01. .    droIno.. ..010 0.'
I'nt.octtonl. [..h..te  ..IIOM; ..1..,   w.llaM; .of..,    ....... " ..Uod.;
potenliollmp.eta onel  J...tll\acI 18 ro...cII818   jlUli6..t 18 romodlo18    .of- roqaInd 18
mill, "".   .....\anllnoliDL   ""'''''''''elloo.    bapl_L
RCIIA TW I.dlll, Nol .ppllcabl.. WlII_L WUI_L WIIIIMDl WlII_L WlII_l WDI_L  WDI_L
Iocalion In loo.,oor         
IIoocIpllin         
ICO CFR 264.111         
 Location Stenel.rel. Will mo.L Will .....L WIII-L WIII_L WiII_L Will_L WIII_L WUI-L
 011'1' ItO~.08        
 (dKCKcl).        
 R..ldonll&l .nel Willnol_1 Will nol -I: .01.., s.. Allamolly. I. s.. Altornoll.. I. S. Alt.omell.. I. s.o AliorDedye I. S. Al18melly. I. S. Alto..ell.. 2.
 Ac'ricuJtw.1 Zonl B boa...1 J...llllael 18 -..eIIo18      
 (Town or lUoymonel DOolemin.toel ,",unel .....      
 Articl. 3, SeelIDn Wlte, will Inlerf...       
 3:2). Limito.... Df witb WI'I.IriCleel IU.       
 Iind in lite oro. Ie DI .ito.       
. . tb... Ut',.        
 .        
 AC110N.        
 SPECIFIC,        
 RCIlA TSD focllil, Not .ppliabl.. Will o..bolantiyol, s.. Allamolly. I. S. AlIa...tI"e 2. s.o Allamelly. 2. s.o Allamedye 2. s.o Allamell.. i. .. Allamod"e I.
 Stendorclo  _I ,.".enl en'      
 (CO CfR 264.14,  eppropriola      
 26U6, 26"'6)..  .londa,cIo.      
 F.alit, .ocurll,.        
 in.pedion. penonn,l        
 Ir.lnin,        
 requiNcnent.a.        
RCIIA TSD "Idlil,
PYeptrldn... .nd
Prevention
Iltqu.irwmtnh
(CO CflI 26C.
Subplri CI .
[.ubli,h..
fWd,lin.. ror ..r..,
_HlinmAnl .nill
Not Ippliubll.
Will .ubotonliy.r,
rn.t ,.I...nt anel
Ippropri.to
.land.rd..
Seo Allomoll.. 2.
See Allom.Ii.. 2.
Nol oppllcablo.
Will luboll nllo.l,
_I rei.. .nl an.
opproprial ,
otonclorclo.
Seo Allemoll..1.
-------
TABLE 4

MJTroIJJ REroRD OF DOCISlOO
Page 3 of 6
  AIIAA AI......u.. I AlIer..II.. . AlIen.II... e AlIen.U... .. AlIen.U... . AI....,.u... . AI.....u.... ,   
   AI"...oll... . 
  ICIA no PodIle, Not ."11..,,,.. Not ."Ilea"'" Will ".,.... ... "'18...11... e. ... "'1.....11... a. ... Al18...oll... e. N.I .ppllea"'.. 600 Allomoll... 3. 
  CIoIhopnqr PI...   -......, roopo"..    
  .. ErMr8o...,   pI.n.       
  ......-          
  ..en 2M.          
  ....... D)..          
  JIoooIro.          
  ""'_to'"          
  ...... .. an,          
  .......... ., ..10..          
  "........ .......          
  II:aA N.,"'1It ... Net ."11..,,,.. Net."........ WDI_, ... AlIe...II.. a. No' ."lIea"'" ... ~....II... e. WtllmooL Boo AI......II... 3. 
  ..... KH,I...   lWqal...-.to fo, 011'.  
  I" en auo.   II.. bo.,,"'... or       
  84.n).   tro.brIo,,' ..014..1..       
  II:aA no PoeIIh, N., .,plleabl.. WOlmoo' I. WlII_. II, ... Aile......... I. 600 Altom..... 2. Boo Allem...... .. ... Allem...... .. Boo AlIo....II.. 3. 
  0000 Cleo...  -Il1o.. ........" bo..brIo'" .. 
-------
TABLE 4

MJITOI.D REL'ORD OF DEX:ISlOO
Page 4 of 6
 ARAII AI,-...Ih. I AlI.r..eI.. . AllerD.U" . AI'-r..U.. . AI'-r.oU...' AlIen.II.... AlIen.U.. , Allenolh.. .
 Cloon AI. Ad . 1f.1 .,pUca"'o. Will-L Will_L WIII-a. WiII_L WUI_L WUI -'- WUI_L
 Halionll ""'bionl AI.        
 Qulil, Standordo        
 I.. Tota' S......ndod        
 ,".ucW"tao. (40 CPR        
 12'.10$. 160)        
 Clun AI. "d Hol ."Uca"'o. :. Not ."IIcabI.. WIII_L Will-a. tW .,,11aIbIo. WUJ_L Hot ."IIca"'. WU1~
 Hllionll Emi..IOftI        
 S..nd.,dt 10' AI.        
 'ollutanla (40 CPR        
 81)        
 Conlrol ., AI. Ifol .,pllca"'.. H.t .,pllca"'o. Will noML N.I .,plIClDblo. tW .ppllcabl.. H.t .,,1""'" No&."U..III.. WUI_L
 Emillion from       
 Suporfuod AI.        
 Stnppo.. 01        
 SuporfWld Ground        
 Wlla. 5,10. (OSWER        
 'J~&.O.281        
 D.O.T. lIuloo ro. Iho Hol .p,li..blo. Nol .,,11.111.. WilllMOl 600 AI'-m.U.. .. Hol o,pllcallio. &eo AI'-m.lI.. I. WUI_L 800 AlI8.ud.. I.
 1'1'onoportltioo 01   ",,"'nmonl8 re,    
 IIo..nlo... M.loriol.   Ir.nlr.. ol1..il8 of     
 141 crll '"rto 101.   Ir..tmonl ...'du.lo.     
 111.1 . I1UOO~        
. '        
I 0911A . Oono..1  N.' ."U..bI.. N.I ."Uca"'" Will rMOL WUI_L WUI_L wm_L WUI_L WDI_L
 Ind...,ry Stand.,dt        
 (2' Cf1IltlO~        
 BTAm        
 CIu:r.UCAJ..SPECII'IC,        
 1.I..Dlchloroolhono SIa'- T1IC .1 II ,pb 5'-18 TOC 01.1 ppb 800 All8m.ti.. 2.  8M All8m.II.. 2. 800 All8l11oll.. L &eo Allam.II.. 2. 11818 TBC 01.1 ,,II
 600 AlIarD.II.. 2.  ....uld be -, welN.
  will MI be _I in  .ho...d be .t ID      .ppndm8Ca1,
  .......d ..Ia.. . ,..n.      . ,..,..
 TOllAh,d""..,.n Slalo T8C .r IW ,,II TCL of 710 ,pb s.. All8m.II,. L 600 Altars.II.. L 8M AlIoI1l.IIo. S. .. Alton"'" S. .. AlIoI1lIl.. 2. teL of 710 ~
  will .... be _t In ohoul' be _I In     Mould .. ... welN.
  _nd .otar. teL . ,.....      . .ppndnaal8l,
  10' 01 710 ppb well       . ,.0...
-------
TABLE 4
IDrroID REXX)RD OF DOCISlOO
Page 5 of 6
 AltAR AlI.,,,.lh,. I AI&I,..&I.. . AI&I....&I". J AI&I....&I". . AI&I,..&I... . AI&I",.&I" . AI&I....&I". , AI&eno.&I". .
 I.o<:ATION.        
 6I'EClt'IC,        
 N- 'hmpohlrw Nol .ppllobl.. Will _I ""."."1 Sea ""10....11". 2. Sea ""10...11". 2. Sea ""10...11"0 I. .. .........11... I. .. ....tem.lI.. 2. .. .........11.. 2. '
 llau.do... Woolo Act  .nd .,,,,,"'.&1      
 (RSA Ch.IU.A. NIl  .....cIo,d..      
 Mmln. C'" IIo.P        
 CII. "051.        
 c-o..1 Will-L WiII_L WUI_L WRI _L WIII_L WUI_L WIII_L WUI_L
 r..."'",nmin,"1        
 Stendo.do ()Io.p        
 19O5.01Id."C! .n'        
 ,.,) Jl,qul..o        
 ....pllonc. wllh        
 OS"A ond .o.h,        
 ri"'l to kno.. Nloo.        
 Tnn,l.. or Foality wiII_L WIII_L WiII_L WUI_L WIII_L WUI_L WUI_L WUI_L
 01.' "OUlld..l)        
 "-,,uI.tO "'01 l1lil1li        
 .""'0" be nolir..d.r        
 01.. .... ..olrictiono.        
. Addition.' Toch"ical Nol .,plicabl.. N.I .,pllcalol.. WlII_L Will.-&. WlII_L WII--.  
. Stando.do roo      Will_L WilI-L
 T...lm.nl (lIo.P        
 1105.0810121011.        
 MoniltOtinr Nol ."lIcobl.. No' ."Iicalol.. WUI _I opplioblo Sea ""10....11"0 3. Nel oppllcaW.. .. ""10,..11....  
 lIoqu...monta OI..P   nqul..._.10 r.r  WlII_L .. """..all..1-
 1106.041.   "a"or.r .rr..11o ar     
    "'._"1 ....id.....     
 P,ch,;nl ond Nol o"lIcobl.. N.I a,pUubl. WUI _I .ppllable Soo ""10"'011.. a. Nal .ppll..bI.. Sea ""Io..all.. 3. WiII_L .. ""10....11..1-
 ubohn.   !'Oqul..._,,10 r., 
 R.quirtn1ent8 nl..p   Ir.noror .«..'10 or     
 190605.   tr..lenonl ...oid.....     
 inoo'1'O",lnl b,        
 "I".nco N.lt        
 "dm. n. Codo        
 501.C .600 ond 49        
 CrR 172. \13. \18        
-------
TABLE 4

MJTroID REXX>RD OF DIXISlOO
Page 6 of 6
       ;".
...llAR AlterD.II... I Alle...II.. . Alt..D.th. , Alt....U.. 4 AlIar.oU.. . AlIe..oU... . ~t....tI.., Alt4I.-.U..,
Stondord. ro, tlot Ippli.-bl.. tlo' oppll.-bl.. Will -, .ppllcabl. See Allam.lh. I. N.I oppllabl.. See AI.....II.. ,. WUI_" See AI.....II.. a.
Con,,""''' (HI'P   requi..-.u r..     
urS.06I.   troDlrO. .«..11a .I     
   tnolmln' _101.....     
tit. Ilomplhl.. tlot .pplicablo. Nol o"lI.-bl.. No' .ppllabl.. Will -, ..Ie..., See AlIa",.II.. .. Boo AlIen.II.. .. Not ...,u.w.. .. AI.....II..I.
Solid W.... Focilil,    ..... ."..pril"    
lIul.. (III'P 190I.Ofi).    .............    
O..drin, Inol c..trol Nol Ippli.-bli. WIII_L ..., ."ncabl.. \WI-.&. wnl_L WIII_L WlII_" Win ......, I.
,11I""...n; RSA        .... A _Ulnd:
149:'..: Orodrin.        ....... ...........
lIul.. (W. Ch. 400       
Port et6).        
"11 Ind Drool.. In Not .ppli.-bl.. Will _I In r.rme, Soo Alum.II.. 2. See Allamllt.. So See Allam.II.. 2. .. AI.......... I. See Allem.lI.. 2. WIn'" _II.
"'..llnd.. Cn"';1  0111,...1 .....      renno. ...,...1 ....
1.01 c.nditionl (RSA        .... ... I. B_II A
483..... W. Ch. '00.        ..uanolo: ..1..,
Ind WI Chip"" 100        ..........
U"o",h 1001.       
""lid..,.ldlllo" Will nel....L WIII_" WiII....l Will-l WIII....l WUI_l  
I'oliq (WI Ch. 400,       WlII_" Wln_"
. I Plrt .,11.        
.   See Allam.Ii.. 2. Soo Allam.II.. So Soo AlIe",.II.. 2. 800 Allem.lI.. 2. Boo AlIa",.II.. 2. .. AlIa,..II.. I-
I'll. Hlmp.hiro Will nol _" Will _I within'  
e....,;" Wile'  ,.0... 0....... ..Ia,      
rrot..ecti.n  oIIoch.... panni' will      
11o",lllion. (WI etO)  be requl....      
C",u.d Wll8r        
QUIIiI, Cn"';1        
1'1.. Hlmp.hi.. AI. Not Appllabll. WiII_" Will _L A plnNl Will _l A ...-, WlII_L WUI-Il A plrI'IIIl wm-" WIn _l A po""'1
1Ia",lltion. Tode AI,   -, ... """rod ror -, ... ........... I'M  -,... .....,..... Iw  ..., be ....... ",
l'ollul8nl8 (Chlpt.,   .., dl8chu.. rnm II, oIIodu,.. hm  II, dIod .,.. "...  .1. .1IeN,.. n-
t...A 13001.   YES. YES.  LTt'8.  YES .... AIr
       Slrlppoo.
ruriti," 0...1 1'101 .ppll.-bl.. WIII_" tIol .ppllabl.. Will..&. WlII_" WID_L WUI-" WU1-L
t:m.ulo" Control        
-------
FEDERAJ,:
RCRA:
REQUIREMENT
Miscellaneous Units
40 CFR 264, Subpart X
Clean Vater Act (40 CFR Parts 122 and 125).
OSHA:
.
.
"
OSHA:
Hazardous Vaste Operations and
Emergency Response
(29 CFR 1910.120)
Safety and Health Standards for
Construction Sites
(29 CFR 1926.652)
Rivers and Harbors Act
(33 CFR 320 - 329)
STATUS
Relevant
and
Appropriate
Appl i cabl e
Appl i cabl e
Appl icable
Appl i cabl e
TABLE 7
ACTION-SPECIFIC ARARs
MOTTOLO SUPERFUND SITE
SYNOPSIS
'.
This regulation sets forth design and
operation standards for miscellaneous
treatment units.
Regulation 40 CFR Part 122 addresses
permitting requirements for discharge into
waters of the United States. According to
Part 122, waters of the Uni ted States
include wettands, bogs, swamps and
marshes. Regulation 40 CFR Part 125
establishes criteria and standards for the
National Pollutant Discharge Elimination
system and references the pretreatment
standards established in 40 CFR Parts 401
through 464.
This regulation sets forth health and
safety procedures for employees conducting
hazardous substance response operat i ons
under CERClA. More specifically, it
addresses personal protective equipment,
hazardous materials handling procedures,
fire protection, and medical and first aid
preparation procedures.
Specifies the safety precautions and
equipment necessary to conduct excavation
activities (Subparts C, 0, P). Subpart E
specifies general safety equipment which
must be used by personnel working in
dangerous areas or under dangerous
conditions.
This regulation outlines requirements for
discharging dredged or fill materials into
waters of the Uni ted States. Furthermore,
this regulation addresses dredge and fill
ACTION TO BE TAREN TO COMPLY
The treatment component of the VES will be designed,
constructed, operated, maintained and closed in compl iance
with this regulation.
Management of diverted groundwater and construction runoff
will comply with this regulation.
Personal protective equipment and measures will be employed
as required to comply with appl icable provisions of this
regulation during construction and operation of the YES.
Appropriate safety equipment wit I be on site, and safety
procedures will be observed. Health and Safety Plans will be
developed in compliance with these regulations for'oesign,
construction and operation phases. Construction of the
groundwater interceptor trench wi I I be done In compl i ance wi th
this regulation.
Activities In the drainage swale and Brook A valley wetland
-------
REOUIREMENT
Guidelines for Specification of Disposal Sites
for Dredged or Fill Material
(40 CFR 230)
STATE:
Hazardous Yaste Facility Security Requirements
Env-\Im 708.08(c)
[40 CFR 264.14]
Ground Yater Protection
Env-\Im 708.02(j)
[40 CFR 264, Subpart F]
.
.
.
Closure and Post-closure
Env-\Im 708.02(k)
[40 CFR 264, Subpart G]
STATUS
Applicable
Relevant
and
Appropriate
Relevant
and
Appropriate
Relevant
and
Appropriate
TABLE 7
ACTION-SPECIFIC ARARs
MOTTOLO SUPERFUND SITE
SYNOPSIS
operations with respect to protection of
wetlands and floodplains.
This regulation sets forth guidelines to
restore and maintain the chemical and
biological integrity of the waters of the
United States through the control of
discharges of dredged or fill materials.
This regulation sets forth the
respons i bi lit i es of owners of hazardous
waste facilities.
This regulation, which incorporates
federal RCRA standards and supplements
N.H. Admin. Code Ys th. 410, establishes
additional standards for ground water
monitoring and appropriate remediation at
hazardous waste facilities. The provision
prohibits the discharge of constituents
into ground water above federal RCRA
limits for such contaminants at the
compliance point, which is defined as the
boundary of each waste management unit
under 40 CFR 264.95.
This regulation sets forth the specific
requirements for closure and post-closure
of hazardous waste facilities. These
requirements include but are not limited
to: closure performance standards, a
detailed closure pI an, time allowed for
closure, disposal or decontamination of
equipnent, structures and soils,
certification of closure, survey plat,
post-closure care and use of property, and
post-closure notice.
ACTION TO BE TAKEN .TO COMPLY
Mitigative measures, such as erosion and siltation controls
will be used during activities in wetland areas to comply
with this regulation.
Access to remedial activities and facilities
controlled in compliance with this regulation.
will be
A ground water monitoring program consistent with the
requirements of this regulation will be' developed and
implemented. The compliance boundary is everywhere under the
site.
Moni toring and maintenance programs will be implelMnted In
compliance with this regulation. The YES will be
-------
REQUIREMENT
Post-Closure Care Requirements
Env-Wm 708.03(d)(6)
r40 CFR 264, Subpart F - landfills]
Technical Standards for Tanks
Env-Wm 708.03(d)(2)
[40 CFR 264, Subpart J - Tanks]
New Hampshire Ground Yater
Regulations (Ys 410)
Ground Yater Quality Criteria
Protection
New Hampshire Air Regulations
Toxic Air Pollutants
(Chapter Env-A 1300)
Fugitive Dust Emission Control
(N.H. Admin. Code, Air, Part 1002).
.
,
.
STATUS
Relevant
and
Appropriate
Relevant
and
Appropriate
Appl icable
Applicable
Applicable
TABLE 7
ACTION-SPECIFIC ARARs
MOTTOLO SUPERFUND SITE
SYNOPSIS
This regulation sets forth the specific
requirements for closure and post-closure
of landfills. These requirements address
cont rol of eros i on and leachate
generation.
This regulation incorporates federal RCRA
requirements for facilities using tanks to
treat or store hazardous wastes.
These regulations establish monitoring and
intervention requirements and water
qual i ty standards for ground water
discharges. .
These regulations establish ambient air
limits for toxic pollutants from new
sources.
This regulation requires precautions to
prevent, abate and control fugitive dust
during construction and excavation
activities.
ACTION TO BE TAREN TO COMPLY
After remediation Is complete, the former drum disposal area
and the southern boundary area will be closed in compliance
with this regulation.
Management of contaminated liquid in tanks from demister
portion of VES will comply with this regulation.
The discharge of water from the Interceptor trench and the
groundwater monitoring program wi II comply with this
. regulation.
Emissions from the carbon canisters will be monitored to
ensure that limits on specific VOCs are met or additional
controls are implemented In compliance with this regulation.
(See chemical-specific ARARs for VOCs).
Monitoring and, if warranted, control measures will be.
employed to ensure compliance with this regulation.
-------
REQUIREMENT
FEDERAL:
Protection of Wetlands
Executive Order 11990
Statement of Proc~res on
Management and Wetland Protection
(40 CFR part 6, Appendix A)
Floodplain
Clean Water Act, Section 404
(40 CFR Part 230i 33 CFR Parts 320-330)
state:
Dredging and Control of Run-offi RSA 149:8-a:
Dredging Rules (Ws th. 400 Part 415)
.
.
I
.
Fill and Dredge tn Wetlands, Criteria and
Conditions
(RSA 483-A, Ws Ch. 300, and Wt Chapters 100
through 100)
STATUS
Applicable
To-Be-
Considered
Appl i cabl e
Appl icabl e
Appl icabl e
TABLE 8
LOCATION-SPECIFIC ARARs
MOTTOLO SUPERFUND SITE
SYNOPSIS
Requires Federal Agencies to preserve and
enhance natural and beneficial values of
wetlands and to minimize the destruction
and loss or degradation of wetlands.
EPA poltcy for carrying out the provistons
of EO 11990.
Prohibtt the discharge of dredged or fill
material into wetlands without.a permit.
RSA 149:8-a and Ws th. 400 Part 415
establish criteria for conducting any
activity in or near state surface waters
which significantly alters terrain or may
otherwise adversely affect water quality,
impede natural runoff or create unnatural
runoff. Acttvlties within the scope of
these provisions include excavation,
dredging, and grading of topsoi I in or
near wetland areas.
These regulations govern filling and other
activities in or adjacent to wetlands, and
establish criteria for the protection of
wetlands from adverse i.cts on fish,
wi Idl !fe, conmerce and publ ic recreation.
ACTION TO BE TAKEN TO COMPLY
The selected remedy avoids wetland iqJ3cts to the maxinull
extent practicable and will Include mitigation measures to
limit any minor, unavoidable t.cts.
Selected remedy was chosen taking Into accOU'lt the provisions
of this policy.
Work performed In wetland areas near the drainage swale will
comply with thts regulation.
Work performed In wetland areas and in the vicinity of Brook
A (discharge trench) will comply with these regulations.
Activities in the drainage swale and near Brook A valley
wetland areas will included measures to mitigate petentlal
-------
FEDERAL:
SO\lA :
SO\lA :
RCRA:
CM,
.
STATE:
REOUIREMENT
Maximum Contaminant Levels
(MCLs) and Maximum contaminant
Level Goals (MCLGs)
(40 CFR 141.11-141.16 and
141.50-141.52)
Proposed Maximum Contaminant
Level Goals
(40 CFR 141.50-141.52)
Maximum Concentration
(MCLs)
(40 CFR 264.94)
Limits
National Amlent Air Quality
Standards (NAAQS)
(40 CFR 50.1-50.12)
Groundwater Protection Standards
(ENV-\ls 410.05)
Ambient Air Quality Standards
(NH Administrative Code ENV-A:300)
STATUS
Relevant
and
Appropriate
To-Be-
Cons i dered
Relevant
and
Appropriate
Applicable
To-Be-
Considered
Appl icable
TABLE 9
CHEMICAL-SPECIFIC ARARs
MOTTOLO SUPERFUND SITE
SYNOPSIS
SO\lA standards for public drinking water
supplies.
Proposed health goals for publ ic water
systems set at levels which would result
in no known or anticipated adverse health
effects with a margin of safety.
MCLs have been adopted for 14 c~unds
under RCRA as groundwater protection
standards. These are equivalent to SO\lA
MCLs.
NMQS defines levets of six primary and
secondary air contaminants.
Allowable lImi ts are based upon New
Hampshire Public Health Services drinking
water cons~tlon advisories and Federal
MCLs, MCLGs, and other pertinent
standards. Groundwater non-degradation
requi rements Incorporate the surface water
quality standards at ENV-\ls 432.
Establishes primary and secondary levels
for eight air contaminants. All but one,
hydrocarbons, are the same as NAAQS.
ACTION TO BE TAREN TO COMPLY
Groundwater will attain MCLs for carcinogens and HClGs for
noncarcinogens.
Proposed MCLG for 1,2-dichloroethene will be attained.
The only compound affected Is arsenic whose MCl of 50 ug/l
will be met.
Construction activities will be controlled to ensure that
releases of particulates and carbon monoxide do not exceed
standards-
1,1-dlchloroethane advisory will be met In groundwater at the
Site.
Construction and operation activities will be controlled to
-------
REQUIREMENT
STATUS
Toxic Air Pollutants
(NH Administrative Code ENV-A 1300)
Applicable
.
.
ff
TABLE 9
CHEMICAL-SPECIFIC ARARs
MOTTOLO SUPERFUND SITE
SYNOPSIS
".
Establishes ambient air limits for 74
cOfl1XlU'lds.
ACTION TO BE TAKEN TO C~MPLY
"
Air emissions from YES will be controlled to corrply with these
I imlts for the following c~s: 1,1, 1-trichloroethane;
vinyl chloride; trichloroethene; ehtylbenzene; toluene;
xylene; and arsenic.
-------
APPENDIX C
New Hampshire Letter of Concurrence
..
-------
/;~f~~~:~"
~'~)~~"<' '>~~'k(~\\
1/..'"o,;('J1.) ~. ~~ ~'..=:...\
. . f!f /~. " l'~~'~'
'"'r' . ,~-,
;r.>~'i:'J
'.:,;.)1;: . {:j
\~A ..,,- ./.~~
,:[""",~'''.'~
~(:'l" ; , - ~ J'..~
~~~_.
SLat.' o( :\'cw HamJ>shin'
DE I'AUT1\1E:--;T OF E.\iVlHO:\'!\tEi\T\L SEH\'ICE~

WASTE 1\1iL'\AGE:\1El\T [l1\'ISWN
6 Hnt>n Drive. Con,-ord. ~;H 1)33Ul-6S(\~
603-271-2~!(i()
R013ERT \\'. VAk."-JEY
CC:>MMI55!o:-:r.R
TTYiTDD 1-,~)1).??2 -.,3; ~ (.r 22.'..4033
PHILIP J. O'BRll::~;. Ph.D.
DIRECTOk
MICHAEL A. ~rLLS, Ph.D., P.E.
CHI!:./' ~N";'srEI(
Much 29. 1991
Mr. Merrill Horman
Wa ste Ma nageme nt 0; vi sian
USEPA, Region I
JFK Federal Bldg.
Boston, MA 02203
Re:
RECORD OF DECISION
MOTTOLO SUPERFUND SITE
RAYMOND, NEW HAMPSHIRE
Dear Mr. Hotman:
\\~~'r~' :'1 ".~":;'i.E\~i:';' l \.,. "'" ::
, ~:C..~J..':...Lf j.:...:r.;"!"~J< .:t..a.r""'",J'
~'\.t.~I~i nHEEU../1, '." ..,...:"':'::'-:"'.
\\';LLlA~.! ,\;':....\":JJ.C
~OB;::~"T ~,L~!iR~,~\'3
Vjr:{~1:~I.'" :;::\'.'1:-.
\\!!..U,4.",~ lr::,':..'F5,~
,(;in; LA"'~!.il.r
J0H:-; :,;:(;:..:..\\
:"'1=;"'I\F.PI<':'~: ""1(.:G".n~(',
j()H}.: O~{;()(,LI
IJ)KR,,\I~f; ~.'-~ u;;,
'j IX,'UH~ El\.ili~fY, ?r"LJ
This office has reviewed the above referercedRecord of Decision (ROD) and
concurs wi th the USEPA that the reconmended ranedy is cons;stent wi th the
rules and regulations of applicable or relevant and appropriate state
standards. Furthentrore, if the project utll izes the trust fund, and 1 f state
funds are available, the state will provide matching funds and operational
support for the project.
51 ncere ly I - "j

--- ,-/ (
(- ,-/) ,,-
V.. t.,. --1 . () (:-
Philip J. O'Brien, ~
~tor -

~i!v.~e~Y~2S

Comni ss10ner
MJR/PJO/RWV/jd/548
cc: Michael A. 51115, Ph.D, P.L. Chief Engineer, NHDES-\t8t1D
Carl W. Baxter, P.E.. Administrator, NHDES-WMEB
Anne E. Renner, E$q., NHAGO
Charles Holtman, E~q., NHAGO
Michael J. Robinette, P.G., NHDES-WMEB
-------
APPENDIX D
Responsiveness Summary
-------
United States
Environmental Protection Agency
Region I
SUPERFUND
Responsiveness Summary
Mottolo Site

Raymond, New Hampshire
March 1991
-------
Table of Contents
Preface. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .. 1
I.
Overview of Remedial Alternatives Considered in the
Groundwater Feasibility Study and Feasibility Study
Addendum, Including the Preferred Alternative. . . . . . . . . . . .. 2
. .
II. Background on Community Involvement and Concerns. . . . . .. 3
III. Summary of Comments Received During the Public
Comment Period and EP A Responses. . . . . . . . . . . . . . . . . . .. 5
Part I - Citizen Comments. . . . . . . . . . . . . . . . . . . . . . . . . . .. 5
Part II - Potentially Responsible Party Comments. . . . . . . . .. 6
IV. Remaining Concerns. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .. 8
Attachment A: Formal Community Relations Activities Conducted To Date
at the Mottolo Superfund Site
-------
Preface
The U.S. Environmental Protection Agency (EPA) held a 3D-day comment
period from February 14,1991, to March 16,1991, to provide an opportunity for
interested parties to comment on the Feasibility Study (FS) and the Proposed Plan
prepared for the Mottolo Superfund site in Raymond, New Hampshire. The FS
examined and evaluated various options, called remedial alternatives, to address soil
and groundwater contamination at the site. EPA identified its preferred alternative for
addressing site contamination in the Proposed Plan dated January 1991.
The purpose of this Responsiveness Summary is to document EPA responses
to the questions and comments raised during the public comment period on the FS
and Proposed Plan. EPA considered all of these questions and comments before
selecting the final remedial alternative to address the groundwater contamination at
the Mottolo site.
This Responsiveness Summary is organized in the following sections:
I.
Overview of Remedial Alternatives Considered in The Feasibility Study,
Including the Preferred Alternative- This section briefly outlines the remedial
alternatives evaluated in the FS and the Proposed Plan, including EPA's
preferred alternative.
II.
Background on Community Involvement and Concerns - This section
provides a brief history of community interests and concerns regarding the
site.
III.
Summary of Comments Received During the Public Comment Period and
EPA Responses - This section summarizes and provides EPA responses to
the oral and written comments received from the public during the public
comment period. In Part I, the comments received from citizens are
presented. Part II summarizes comments received from the PRPs.
IV.
Remaining 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 site. EPA will address these concerns during the
Remedial Design/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 participation activities that EPA has
conducted to date at the site. Attachment B contains a copy of the transcript from the
informal public hearing held on March 6, 1991, in Raymond, N.H.
Mottolo Superfund Site
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I.
Overview of Remedial Alternatives Considered in the
Feasibility Study, including the Preferred Alternative
The cleanup plan selected by EP A (Alternative 3 in the FS) will treat
contaminated soil by use of an in-ground vapor extraction system (VES). A network of
wells will be installed on the site to pump air from the soil, creating a vacuum and
drawing contaminants from the soil. Because a YES is not efficient in wet soil, the-
ground will be dewatered by a groundwater interceptor trench and a temporary cap
installed ,to prevent groundwater and rainfall from entering contaminated soil.
Contaminants extracted by the YES will be captured using activated carbon filters.
After the YES treatment is completed, an earthen cover will be constructed over the
area of formerly contaminated soil to reduce the amount of water infiltrating the soil.
EPA estimates that groundwater target cleanup levels will be met within six years or
less after the soil is cleaned. Ground- and surface-water monitoring will be conducted
for up to ten years following completion of the YES treatment. The estimated net
present worth of the site cleanup is $690,000.
In the FS, EPA evaluated a total of eight potential cleanup alternatives for
contamination at the Mottolo site. The seven other alternatives are described briefly
below.
Alternative No.1: No Action: This alternative was evaluated to serve as a baseline
for other remedial alternatives under consideration. Under this alternative, no
treatment of groundwater or soil contamination would occur. Ground- and surface-
water monitoring would be conducted for 30 years, and site conditions would be
reviewed every five years to determine if further actions would be needed.
Alternative No.2: Groundwater Interceptor Trench and Capping: This alternative
would use a groundwater interceptor trench to reduce the flow of groundwater into
contaminated soils in the former drum disposal area. Contaminated soil from the
southern boundary area would be excavated and placed in the former drum disposal
area. A waterproof cap would then be placed over the area to reduce the infiltration of
rain and snowmelt. Ground- and surface-water would be monitored for thirty years.
Alternative No.4: Above-Ground Vapor Extrar.t!~n System: This alternative would.
involve excavation of all contaminated soil and treatment using an above-ground VES
that would be constructed at the site. Ground- and surface-water would be monitored
following the cleanup.
Alternative No.5: Chemical Fixation: This alternative would excavate all
contaminated soil, chemically bind (fIX) the contaminants to the soil, and replace the
soil in a secure capped cell that would be constructed on the site. Ground- and
surface-water would be monitored following the cleanup. Because contaminants
would be left on-site, site conditions would be reviewed every five years.
Alternative No.6: On-Site Low Temperature Thermal Stripping (L TTS): In this
alternative, contaminated soil would be excavated and treated in a L TIS unit that
. removes contaminants by heating the soil and causing the contaminants to volatilize.
Exhaust gases would be captured using various air pollution technologies. Ground-
and surface-water would be monitored following the cleanup.
2
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Alternative No.7: Off-Site Incineration: This alternative would excavate all
contaminated soil and transport it off-site for treatment in a licensed hazardous waste
incinerator. Surface- and ground-water monitoring would be conducted for ten years
to determine the effectiveness of the excavation in eliminating the source of the
groundwater contamination.
Alternative No.8: In-Ground Vapor Extraction Treatment of Soli with Collection
and Treatment of Groundwater: This alternative would treat soil by vapor extraction,
as in the preferred alternative, but would also include extraction and on-site treatment
of contaminated groundwater. Groundwater would be collected using a system of
trenches and wells, and a groundwater treatment plant would be constructed on-site.
Surface- and ground-water monitoring would be conducted for ten years after
completion of the soil treatment to confirm the effectiveness of the groundwater
cleanup.
Additional information on each of the remedial alternatives can be found in the
Record of Decision (ROD), copies of which are located in the Dudley-Tucker Library, 6
Epping Street, Raymond, New Hampshire, and the EPA Records Center at 90 Canal
Street in Boston, Massachusetts.
II.
Background on Community Involvement and Concerns
Site History
The Mottolo Superfund site is located in the southeastern portion of the town
of Raymond, New Hampshire, east of Blueberry Hill Road. The site is wooded, except
for a two-acre area cleared for a pig farm that operated there until the mid 1970s. The
pig farm area includes a one-story wooden building located at the southern edge of
the site that was used to house the pigs. To the east of the farm area is a small brook
(termed "Brook A") which flows into the Exeter River. A residential neighborhood is
located to the north of the Mottolo property, and new residential development is
planned for the lands to the east and south.
In 1975, the owner of the property began disposing of chemical manufacturing
w~(es Trom KJ. Quinn & Company, Inc. (Quinn) and the Lewis Chemical Corporation
in a quarter acre, shallow depression immediately north of the piggery building. In
April 1979, a local police officer discovered the dump. State officials investigated the
site and observed that some exposed drums were leaking, and that leachate from the
dump was flowing down a drainage swale to the north of the dump and into Brook A.
Groundwater samples taken from on-site monitoring wells installed by the State were
contaminated with volatile organic compounds (VOCs). In the fall of 1979, the State
sampled household wells in the vicinity of the site, but found no contamination.
In April 1980, EPA took groundwater and surface water samples and
confirmed the VOC contamination. The State also began a more detailed investigation
that verified that groundwater in both the bedrock and overburden was contaminated
with VOCs, and that the contaminants were flowing with the groundwater toward Brook
A.
Mottolo Superfund Site
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In September 1980, EPA began an emergency action to remove approximately
1,600 55-gallon drums and 5-gallon pails buried at the site. From 1985 to 1986 the
State conducted an investigation that concluded that the site posed a potential, but
not immediate, risk to residential water supplies. In 1986 and 1987, very low levels of
VOCs were found in samples from recently installed household wells. EPA placed the
site on the National Priorities List (NPL) in August 1987, making it eligible for Federal
cleanup funds.
In May 1988, EPA signed a legal agreement with Quinn, one of the five parties
EPA had identified as potentially responsible for the contamination at the site. Quinn
agreed to perform the RI and FS for the site under EPA supervision. Field work on the
RI began in the Fall of 1988. In October 1990, the final RI report was completed. The
final FS report was completed in February, 1991.
History of Community Activity at the Mottolo Site
Community interest and activity around the site has varied with the amount of
activity occurring at the site. Community interest was especially focused from 1979,
when a local policeman discovered the dump, through 1982, when the removal action
was completed. Community interest increased again in 1987, when State testing of
residential wells indicated the presence of contaminants in two wells. A Community
Relations Plan prepared for the site in 1988, indicates that community concerns
focused on:
.
The nature and extent of groundwater contamination and the potential for
further spread of contamination;
.
Potential risks associated with groundwater contamination;
.
The impact of the site on property values; and
.
Safety issues surrounding future site cleanup activities.
Community interest in the site during the FS has been relatively low.
Community concerns expressed at the October 1990 public meeting, prior to the
release of the Proposed Plan, are listed below.
1. Remedial Action Options and Schedule. Residents were interested in
how long the site cleanup could take and whether funding for the cleanup was
available through EPA.
2. Off-Site Impacts. Concerns focused on potential sources of the trace
levels of contamination detected in some nearby residential wells; possible
limitations on development of properties near the site; and whether
commercial blasting near the site could affect groundwater migration from the
site.
3. Property Values. Residents questioned the continuing impact of the site
on area residents' abilities to secure local bank financing.
4
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Community interest in the site appears to have continued to decline following
EPA's release of the site Remedial Investigation; only four residents attended the
FS/Proposed Plan public meeting held by EPA on February 13, 1991. The principal
community concerns expressed at that meeting are given below.
1. Operations 0' the Vacuum Extraction System. Residents were interested
in whether VES has been used elsewhere in New Hampshire; how effective it
would be at treating site contaminants; nuisance noises resulting from VES
operations; and whether the VES equipment would be removed from the site
after the cleanup is complete.
2. Funding 0' the Cleanup. Residents were interested in whether the PRPs
would pay for the cleanup and what EPA would do if they would not.
III.
Summary of Comments Received During the Public Comment
Period and EP A Responses
This Responsiveness Summary addresses the comments received by EPA
during the public comm~nt period (February 14 to March 16. 1991) concerning the FS
and EPA's Proposed Plan for cleanup at the Mottolo site. Three sets of written
comments were received during the public comment period: one from a Raymond
resident (dated 18 February 1991), one from KJ. Quinn & Company, a PRP (dated 15
March 1991), and one from Richard Mottolo. also a PRP (dated 15 March 1991). No
oral comments were provided at the informal public hearing. A copy of the public
hearing transcript is included as Attachment B.
Part I - Citizen Comments
Comment 1: A resident stated that EPA should ensure that noise control measures
are included in the Remedial Design.
EPA Response: Noise control measures will be addressed during Remedial Design.
Comment 2: A resident stated that EP A should ensure that the carbon bed air
pollution control system ~hnllirl in~h It:fc? ~~ "uta-shutdown mechanism to prevent
contaminant release in the event of a breakthrough.
EPA Response: Appropriate controls will be considered during Remedial Design.
Comment 3: A resident stated EPA should consider inclusion of a fire-control system
to prevent fire in the carbon beds.
EPA Response: The vacuum extration system facility will be designed, constructed,
operated and maintained to minimize the threat of fire or explosion.
Mottolo Superfund Site
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Part II - Summary of Potentially Responsible Party Comments
Comments by both K.J. Quinn & Co. (K.J. Quinn) and Richard Mottolo
Comments provided by K.J. Quinn addressed only items presented in Comment 1.
Additional PAP comments were provided by Mr. Manalo and were not addressed by
K.J. Quinn.
Comment 1: The PRPs contended that past disposal activities were limited to the
area directly north of the piggery building. The PRPs further alleged that
contamination in other areas of the site -- adjacent to the concrete pad west of the
piggery building, and south of the shed and the piggery building -- was the result of
drum handling activities undertaken by EPA and the State of New Hampshire during
the removal action. K.J Quinn and Mr. Mottolo deny any liability for contamination
found adjacent to the concrete pad west of the piggery building, and south of the
shed and the piggery building. KJ. Quinn and Mr. Mottolo assign liability for
remediation of that contamination to EPA and the State of New Hampshire.
EPA Response: The issue of liability is not addressed through the RIIFS process.
The ROD specifies that additional source identification activities will be implemented
prior to use of the YES to identify more conclusively a source of overburden
contamination in the southern boundary area. Among the possible causes of this
contamination that will be investigated is the possibility that under conditions of
fluctuating water levels, a discrete contaminant plume migrated through a bedrock
fracture from the former disposal area. RI water level data from this area is not
extensive enough to either confirm or refute this possibility.
Comments by RIchard Mottolo
Comment 2: Damage to the piggery building is "indicative of very sloppy
workmanship" by EPA contractors who used the building for barrel storage.
EPA Response: EPA has no knowledge of damage to the piggery building. Further,
EPA does not see damage to the piggery building, if any, as relevant to the remedy
selection process.
Comment 3: A modified "no-action" remedial alternative is an appropriate response
to site conditions. Preventing site access by fencing would restrict exposure to site
contaminants, and allowing a 'natural flushing' of groundwater contaminants would, in
time, meet site cleanup levels.
EPA Response: Fencing alone will not effectively prevent human contact with
contaminants found in groundwater. EPA believes that natural attenuation in the
former drum disposal area soils and affected groundwater should result in attainment
of groundwater cleanup levels (Safe Drinking Water Act Maximum Contaminant Levels
[MCLs] and Maximum Contaminant Level Goals [MCLGs». However, the length of
time necessary to attain these MCLs is on the order of decades. This is not in
compliance with EPA's mandate to meet applicable or relevant and appropriate
. regulations in drinking water aquifers as rapidly as practicable. The full rationale for
EPAas choice of a remedial alternative is presented in the detailed evaluation of
alternatives in the FS.
6
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Comment 4: The residents of the neighborhood adjacent to the site are minimally
concerned about the site. based on their understanding of site conditions.
EPA Response: EPA agrees that, while community concern at present is apparently
low, community concerns are important to EPA and community acceptance of
remedial alternatives is considered in developing a Record of Decision. In evaluating
remedial alternatives. however, EPA must first seek to achieve compliance with ARARs
and protection of public health and the environment.
Comment 5: The monies that would be required to implement Alternative 3 should
be used instead at other sites where oft-site migration of VOCs has occurred.
EPA Response: Alternative 3 is the least costly alternative that will achieve cleanup
levels in groundwater both within and outside the site boundaries within a reasonable
time. The Site was evaluated and placed on the NPL, thus, EPA must meet pertinent
cleanup criteria
Comment 6: Alternative 3 may require demolition of the piggery building to
accommodate construction of VES. There should be compensation for the loss of the
building.
EPA Response: The issue of compensation for the demolition of the piggery building
is not addressed through the RifFS process.
Comment 7: Deed restrictions should apply only to those areas that would be within
the site fence.
EPA Response: Details concerning the implementation of deed restrictions will be
addressed during the design phase of the project. Deed restrictions and/or other
institutional controls will be used to prevent use of contaminated groundwater and to
ensure that the remedy is not adversely affected by activities that could draw the
contaminated groundwater to currently unaffected areas. Accordingly, the location of
the fencing will have no bearing on the implementation of institutional controls.
Comment 8: Certain construction and institutional activities associated with
implementation of Alternative 3, such as site access road improvements, are
.outrageous,. and add unnecessary costs to the alternative. These costs also serve to
increase the 25% contingency costs included in the cost estimates. The inclusion of a
25% contingency fee on top of the capital costs .compounds the outrageousness. of
the cost estimates.
EPA Response: The costs presented in the FS and the ROD have been developed
within EPA regulatory guidelines which establish an acceptable range of .study
estimate. costs of between +50% to -30%, i.e., the actual costs may be 50% higher or
30% lower. They are developed consistently among alternatives to ensure a balanced
evaluation. Actual costs and the necessity for each facet of the cleanup will be
carefully evaluated during the design phase.
Mottola Superfund Site
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Comment 9: "Even an unsophisticated aeration operation could effect a far less
expensive dissipation of the volatile organic contaminants from contaminated soil."
Aerated soils could be used as a site cap.
EPA Response: The evaluation of alternatives conducted in the FS allowed the
Agency to select the most efficient, protective, and cost-effective response to site
contamination. Many alternatives, including "unsophisticated" procedures, were
evaluated and eliminated by the FS process because they would not meet EPA's
goals for protection of public health and the environment.
Comment 10: Groundwater cleanup standards established for the site are "unfair." If
no groundwater wells are dug within the fenced area, there is no need to make the
groundwater safe for drinking.
EPA Response: EPA has determined that the Safe Drinking Water Act MCLs and
MCLGs are relevant and appropriate as cleanup standards since the affected aquifer
is considered a potential drinking water source. Attainment of these standards
throughout the contaminated portions of the aquifer when "no wastes are left in place"
is consistent with the National Contingency Plan.
Comment 11: Groundwater sampling costs and parameters are excessive.
EPA Response: The costs will be refined during design. Well locations and
sampling parameters may be adjusted to reflect data generated during the monitoring
program.
w.
Remaining Concerns
Issues raised during the public comment period that will continue to be of
concern as the site moves into the RD/RA phase are listed below. EPA will continue
to address these issues as more information becomes avaJlable during the RD/RA.
1.
Residents would like actions taken to ensure that impacts on the surrounding
neighborhood are minimized during construction and implementation of the
site cleanup.
8
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Attachment A
Formal Community Relations Activities Conducted To Date
at the Mottolo Superfund Site
14 June 1988:
August 1988:
3 September 1988:
September 1988:
7 September 1988:
October 1990:
25 October 1990:
2 February 1991:
1 February 1991:
13 February 1991:
14 February 1991 -
16 March 1991:
6 March 1991:
29 March 1991:
EPA Press Release on the Consent Order.
EPA Fact Sheet on the commencement of the Remedial
Investigation/Feasibility Study process published.
EPA Press Release announcing a public meeting on the Remedial
Investigation/Feasibility Study process.
EPA released a Community Relations Plan for the site.
EPA Public Meeting on the commencement of the Remedial
Investigation/Feasibility Study.
EPA Fact Sheet on the results of the Remedial Investigation published.
EPA Public Meeting on the Remedial Investigation.
EP A advertisement of the Proposed Plan and public comment period
published.
EPA Proposed Plan published.
EPA Public Meeting on the Proposed Plan and Feasibility Study.
EPA Public Comment Period.
EPA Informal Public Hearing on the Proposed Plan and Feasibility Study.
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II
'I
I,
;1

!
1 ""b, .1.
, !
i
2 II
II
3 :1
4 I
UNITED STATES OF AMERICA
ENVIRONMENTAL PROTECTION AGENCY
'"
BOSTON REGION
sjIn the Matter 01:

6 !PUBLIC HEARING ON THE PROPOSED PLAN
lAND FEASABLITY STUDY FOR THE
i MOTTOLO SUPERFUND SITE CLEAN-UP
8
9
10 I
ji
12
Wednesday
Mayo c h 6, 1'3'31
13
14
Raym,:.nd Hi gh
R.:II:.m 2()2
S c h ':":. I
15
Raymond, New Hampshire
16
The above entitled matter came on for hearing,
17
pursuant to Notice at
7:32 o'clock p.m.
18
19
BEFORE:
20
21
22
23
24
25
ROGER DUWART
~~~~=~Ql Project Manager
U.S. Environmental Protection
Regi.:.n One
JFK Federal Building
Boston, Massachusetts 02203
Agency
APEX REPORTING
Registered Professional Reporters
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o
-
PRO C E E DIN G S
2
7 : 3 2 P. >: .
3
:lR. DUWAR T :
\.]e 1 com~ .
My name is Roger Duwart.
.4
1'm EPA's Rt:!medial Project Manager for the ~10ttolo Superfund
5
Site.
And this t:!vening I'll be serving as the Hearing
6
Officer chairing the public hearing on the proposed plan and
f~asibility study for th~ Mottolo Superfund Site clean-up.
7
8
I'm also responsible for the overall managemt:::llt of the
9
proj~ct and I'm rt:::sponsible for t:!nsuring complianct:! with the
10
federal laws and regulations.
11
Also with us this evening is Michael Robinette of
12
the N~w Hampshire D~partmt:!nt of Environmental Servic~s.
13
What I'll do is give you a brief overview tonight
14
of EPA's proposed plans afeer which I will acct:!pe any oral
15
comments that you wish to make for the record.
7hose of you
16
wishing to comment art:! ask~d to sign up on the way in; you
can still make comments later, I'll give you another
17
18
opportunity if you haven't signed up and you still wish to
19
make a comment.
,n
All comments received, both oral and written, will
21
be transcribed and become part of the record.
At the
22
conclusion your comments -- of your comments I may ask you a

clarifying qUt:!stion or two to make sure we understand your
23
24
statement, and after all the comments have been heard I will
25
close the hearing.
I will, however, then make myself and
APEX REPORTING
Registered Professional Reporters
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"
oth~rs here available to you for questions and on anv other
2
aspects of the :easibility study and proposed plan.
3
As you know, the public comment period is running.
4
It began February 14th and it closes March 16th.
If you do
i)
5
wish to make comrnent s on the proposed plan and fea 5 ib i 1 i t'l
6
study for remedial investigation or risk assessment it must
7
be postmarked by March 16th.
8
At the conclusion of the meeting please
.-F
see me ::.-
9
you have any questions about making those written comments;
10
my address is in the proposed plan which you all should have.
11
If you don't have it I will give you my
the meeting.
address at the end 0: I

I

I
12
13
All oral comments that are received tonight and

with the comments received during the comment period will be
14
15
responded to in response in the summary which will be
16
included in EPA's record and decision for the clean-up of the
17
site.
18
Does anybody have any comment about or questions
about the way we've been running these?
19
20
(No response.)
21
MR. Dm~ART:
On February 13th we gave a detailed
22
presentation of the propos~d plan and feasibility study.
that time EPA's preferred alternative proposed plan was
At
23
24
presented.
I'll give you just a really quick rundown on what
25
it is.
Basically, we will begin by constructing about a 1300
APEX REPORTING
Registered Professional Reporters
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o
3 :
foot. t~n foot high chain link fenc~ around the s~te,
2
primarily to protect the equipment that we'll be installing.
3
w~ have two sources of contamination to the groundwater, here
4
and here.
Hhat we propose to do is install a vacuum
5
extracting syst~m in each area in order to remove the
6
contaminants from the soil.
At this source area we will be
7
installing a trench to dewater those soils for a couple 0:
8
reasons and we'll get to that in a second.


Over here we do not need to put in any sort of a
9
10
trench to dewater the soil because there is very little
11
groundwat~r in this area.
50 we will be able to run the
12
vacuum extraction system without dewatering that area.
13
This is the tr~nch I had talked about before.
~'!ha t
14
this will do will be lower this water table so that it will
15
be below the contaminated soil.
That will do two things for
16
us.
It will pr~vent contamination from continuing to get
17
into the groundwater.
It will also make these vacuum
18
extraction wells effective by pulling clean air instead of
19
moisture out of the soil.
If there is any moisture pulled
20
out of these areas it will be taken care of by a demister and
any contaminants in that liquid train will be sent off-site
21
22
for disposal if determined to be necessary at a RCRA
facility; that's a hazardous waste treatment facility.
23
24
This vacuum extraction system will be in a small
25
building on a concrete pad at a pigg~ry building on the site
APEX REPORTING
Registered Professional Reporters
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~
I
~
at its existing concrete pad.
You will be receiv:ng
from
2
these wells and the former Drum disposal area; also from t~e
3
southern boundary area, the two areas on the site.
The
4
vacuum pump or blower will be pulling this through and
o
5
putting the air through carbon filters which will essentially
result in no discharge of conta~inants to the atmosphere.
6
7
The carbon,
will be gen~rated probably off-
if necessary,
8
site.
9
And that in a nutshell is the nuts and bolts of the
10
plan.
In addition to this we'll be monitoring the
11
groundwater for upwards of ten years to insure that we are


meeting our clean~p levels in the groundwater and to insure
12
13
that we are meeting our cleanup levels in a timely fashion

which is approximately six years after we've gotten the soils
14
15
cleaned up in the former Drum disposal area.
In the southern
16
boundary area, because there's less contamination and
17
overburden and the bedrock should clean itself up much
18
quicker, we're expecting only two years worth of time to pass
before we get to the clean up levels in that area.
19
20
One last aspect of the proposed plan would be to
21
use institutional controls to make sure that nobody is
getting to that groundwater until it is actually cleaned up
22
23
and suitable for drinking.
And those controls will be on
24
site.
They a~e on site now as it is so that no one can touch
25
that groundwater and effect the cleanup.
APEX REPORTING
Registered Professional Reporters
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5 .
I
That is EPA's preferr~d alternative and that is the
2
subject of this evening's public hearing.
Your comments on
3
that alternative, any of the other alternatives that we've
4
discussed and presented in the proposed plan and the
5
feasibility study which is available at the Town Hall.
I:
6
there is anybody, I know no one has put their name in to
speak, but if there is anybody who'd like to make a stateDent
7
8
speak now.
If you would rather write down comments then you
9
may write down comments and send them to me.
If not -- if
10
not we will close the formal portion of the public hearing.
(No response.)
11
12
MR . Dt};t! ART:
All right, the public hearing, then,
13
is closed.
Let me remind you you have a deadline of
14
March 16th for your comments.
15
16
17
'8
19
20
21
22
23
24
25
APEX REPORTING
Registered Professional Reporters
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e.,
CERTIFICATE OF REPORTER AND TRANSCRI8ER
2
This is to certify that the attached
p r .:' c e e din 9 s
3
bef,:)re:
u.s. ENVIRONMENTAL PROTECTION AGENCY
4
in the Matter of:
5
6
PU8LIC HEARING RE:
MOTTOLO SUPERFUND SITE
7
8
9 Place:
Raym':.nd,
New Hampshire
10 Date:
March 6,
1':1':11
11
were held as herein appears, and that this is the true,
12
~ccurate and complete transcript prepared from the notes
13
and/or recordings taken
of the above entitled proceeding.
14
15
16 Eric S. Pedersen
Rep.:.r ter
03/15/':11
Date
17
Elaine Bartlett
18 Transcriber
03/15/'31
Date
19
20
21
22
23
24
25
APEX REPORTING
Registered Professional Reporters
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APPENDIX E
Administrative Record Index
"
--
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. .
Mottola Pig Farm
NPL Site Administrative Record
Index
Compiled: December 11, 1990
Updated: February 13, 1991
ROD Signed: March 29,1991
Prepared for

Region I
Waste Management Division
U.S. Environmental Protection Agency
With Assistance from

AMERICAN MANAGEMENT SYSTEMS, INC.
One Kendall Square, Suite 2200. Cambridge, Massachusetts 02139. (617) 621-7090
.-
.
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Introduction
This document is the Index to the Administrative Record for the March 29, 1991 Record of
Decision (ROD) for the Mottolo Pig Fann National Priorities List (NPL) site. Section I of the Index
cites site-specific documents and Section n cites guidance documents used by EP A staff in selecting
a response action at the site.
The Administrative Record is available for public review at EP A Region I's Office in Boston,
Massachusetts and at the Dudley-Tucker Public Library, 6 Epping Street, Raymond, New
Hampshire 03077. Supplemental/Addendum volumes may be added to this Administrative Record.
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
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Section I
Site-Specific Documents
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2.0
1.0
,
ADMINISTRATIVE RECORD INDEX
for the
Mottolo Pig Farm NPL Site
Pre-Remedial
1.2
Preliminary Assessment
1.
2.
1.3
"Potential Hazardous Waste Site: Identification and Preliminary Assessment,"
EPA Region I and State of New Hampshire (February 13, 1980).
"Potential Hazardous Waste Site: Identifit'ltJon and Preliminary Assessment,"
EP A Region I (February 19, 1980).

Site Inspection
1.
"Potential Hazardous Waste Site:. Site Inspection Report," EPA Region I and
State of New Hampshire (February 13, 1980).
"Potential Hazardous Waste Site: Site Inspection Report," EPA Region I
(April 14, 1980).
2.
Removal Response
2.3
Sampling and Analysis Data

The records cited in enrry numbers I through 40 may be reviewed, by appointment
only, at EPA Region I, in Boston, Massachusens.
Environmental Protection Agency Region I
1.
Water Sampling Sheets and Sampling Tags, EPA Region I (April 16, 1980) with
attached pages from New England Regional Laboratory Gas Chromatograph!
Mass Spectrometer Logbook #14.
Memorandum from Richard Siscanaw, EPA Region I to Arthur E. Clark, EPA
Region I (May 1, 1980). Concerning transmittal of attached volatile organic
analysis.
Water Sampling Sheets, EPA Region I (May 18, 1980) with attached pages from
New England Regional Laboratory Sample Logbook #16, Gas Chromatographic
Screening Book #1, and Gas Chromatograph/Mass Spectrometer Log #28.
Memorandum from Richard Siscanaw and Arthur E. Oarle, EPA Region I to
. Edward L. Taylor, EPA Region I (December 9, 1980). Concerning transmittal
of attached purgeable organic analysis.
Memorandum from Arthur E. Clark, Ello Goffi, and Richard Siscanaw, EP A
Region I to Edward L. Taylor, EP A Region I (December 30, 1980).
Concerning transmittal of attached purgeable organic analysis.
Memorandum from Kathleen Polgar, EPA Region I to Edward L. Taylor, EPA
Region I (June 9,1981). Conceming tranC:TI1itfaJ of attached purgeable organic
screening of drinking water.
Memorandum from Kathleen Polgar, Arthur E. Clark, and Richard Siscanaw,
EPA Region I to Edward L. Taylor, EPA Region I (June 10, 1981).
Concerning transmittal of attached purgeable organic analysis of ground water.
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2.
3.
4.
s.
6.
7.
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Page 2
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2.3
Sampling and Analysis Data (cont'd.)
Energy Resources Co. Inc.
"Volatiles Organics by Purge & Trap/GCMS," Energy Resources Co. Inc. for
GHR Engineering Associates, Inc. (November 19, 1979).
Letter from Nancy Stewart, Energy Resources Co. Inc. for GHR Engineering
Associates, Inc. to John J. Gushue, GHR Engineering Associates, Inc.
(November 10, 1980). Concerning attached volatile organic analysis by
purge-and-trap gas chromatograph/mass spectrometer.

GHR Engineering Associates, Inc.
8.
9.
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c
10. Water Sampling Sheets, GHR Engineering Associates, Inc.
(October 9, 1980) with attached pages from New England Regional Laboratory
Sample Logbook #15, Sample Logbook #14, and Gas ChromatographlMass
Spectrometer Log #19.
Goldberg Zoino Associates

11. Water Sampling Sheets, Goldberg Zoino Associates for GHR Engineering
Associates, Inc. (December 11, 1980) with attached pages from New England
Regional Laboratory Sample Logbook #15 and Gas ChromatographlMass
Spectrometer Log #6. .
Kent Laboratories Inc.
12. Letter Report from Rockwell Kent ill, Kent Laboratories Inc. for Marlyn
Engineering Company to Marlyn Engineering Company (January 2, 1981).
Concerning attached sampling data.

~lyn Engineering Company.
The record cited as entry number 13 may be reviewed, by appointmenl only, at EPA
Region I, Boston, Massachusetts.
13. Lab Data, Marlyn Engineering Company is Attachment ROR-037 to "On-Scene
Coordinator Repon," EP A Region I.

New Hampshire, State of
14. Laboratory Analysis, State of New Hampshire Water Supply and Pollution
Control Commission (March 28, 1978).
15. Laboratory Analysis, State of New Hampshire Water Supply and Pollution
Control Commission (April 18, 1978).
16. "Pesticides Laboratory Sampling Information," State of New Hampshire Water
Supply and Pollution Control Commission (April 16, 1979).
17. "Pesticides Laboratory Sampling Information," State of New Hampshire Water
Supply and Pollution Control Commission (May 2, 1979).
18. "Pesticides Laboratory Sampling Information," State of New Hampshire Water
Supply and Pollution Control Commission (May 14, 1979).
19. "Pesticides Laboratory Sampling Information," State of New Hampshire Water
Supply and Pollution Control Commission (May 21, 1979).
20. "Pesticides Laboratory Sampling Information," State of New Hampshire Water
Supply and Pollution Control Commission (May 29, 1979).
21. Laboratory Analysis, State of New Hampshire Water Supply and Pollution
Control Commission (May 29, 1979).
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3.0
Page 3
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2.3
Sampling and Analysis Data (cont'd.)

22. "Pesticides Laboratory Sampling Information," State of New Hampshire Water
. Supply and Pollution Conttol Commission (June 6, 1979).
23. "Pesticides Laboratory Sampling Information," State of New Hampshire Water
Supply and Pollution Conttol Commission (July 18, 1979).
24. Laboratory Analysis, State of New Hampshire Water Supply and Pollution
Conttol Commission (July 18, 1979).
25. "Pesticides Laboratory Sampling Information," State of New Hampshire Water
Supply and Pollution Conttol Commission (August 14, 1979).
26. "Pesticides Laboratory Sampling Information," State of New Hampshire Water
Supply and Pollution Conttol Commission (October 2, 1979).
27. "Residential Well Organics Analyses," State of New Hampshire Water Supply
and Pollution Conttol Commission (May 2, 1979 through October 18, 1979).
28. Well Water Sampling Analyses, State of New Hampshire Water Supply and
Pollution Conttol Commission (May 2, 1979 through November 1, 1979).
29. Organics Analyses, State of New Hampshire Water Supply and Pollution
Conttol Commission (January 16, 1980).
30. Organics Analyses, State of New Hampshire Water Supply and Pollution
Conttol Commission (February 28, 1980).
31. Organics Analyses, State of New Hampshire Water Supply and Pollution
Conttol Commission (July 22, 1980).
32. Memorandum from Steve Mangion, State of New Hampshire Bureau of Solid
Waste Management to File (July 25, 1980) with attached location map.
Concerning test pit operations.
33. Organics Analyses, State of New Hampshire Water Supply and Pollution
Control Commission (October 9, 1980).
34. Letter from Paul J. Cavicci, State of New Hampshire Water Supply and
Pollution Control Commission to John 1. Gushue, GHR Engineering
Associates, Inc. (November 7, 1980). Concerning attached analytical results
obtained for round one sampling taken July 22, 1980.
35. Letter from Paul J. Cavicci, State of New Hampshire Water Supply and
. Pollution Conttol Commission to John J. Gushue, GHR Engineering
Associates, Inc. (November 18, 1980). Concerning attached analytical resu!ts
obtained for round two sampling taken October 8 to 10, 1980.
36. Organics Analyses, State of New Hampshire Water Supply and Pollution
Conttol Commission (December 11, 1980).
37. "Pesticides Laboratory Sampling Information," State of New Hampshire Water
Supply and Pollution Conttol Commission (February 16, 1982).
SCA Chemical Services

38. "Waste Material ProfIle Sheet," SCA Chemical Services.
39. Results of PCB Composites, SCA Chemical Services.
40. Laboratory Notebook, SCA Chemical Services.
Remedial Investigation (RI)
3.1
Correspondence
Well Water Sampling
1.
Letter from Michael A. Sills, State of New Hampshire Water Supply and
Pollution Conttol Commission to John Britt (October 16, 1985). Concerning
. well water sampling on September 6, 1985.
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Page 4
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3.1
Correspondence (cont'd.)

2. Letter from Michael A. Sills, State of New Hampshire Water Supply and
Pollution Control Commission to Bradley Ciechomsky (October 16, 1985).
Concerning well water sampling on September 6, 1985.
3. Letter from Michael A. Sills, State of New Hampshire Water Supply and
Pollution Control Commission to AI Jewett (October 16, 1985). Concerning
well water sampling on September 6, 1985.
4. Letter from Michael A. Sills, State of New Hampshire Water Supply and
Pollution Control Commission to William Robinson (October 16, 1985).
Concerning well water sampling on September 6, 1985.
5. Letter from Michael A. Sills, State of New Hampshire Water Supply and
Pollution Control Commission to John K. Sayers (October 16, 1985).
Concerning well water sampling on September 6, 1985.
6. Letter from Michael A. Sills, State of New Hampshire Water Supply and
Pollution Control Commission to Barry Sullivan (October 16, 1985).
Concerning well water sampling on September 6, 1985.
7. Letter from Michael A. Sills, State of New Hampshire Water Supply and
Pollution Control Commission to Scott Brimicombe (June 6, 1986).
Concerning well water sampling on May 15, 1986.
8. Letter from Michael A. Sills, State of New Hampshire Water Supply and
Pollution Control Commission to John Britt (June 6, 1986). Concerning well
water sampling on May 15, 1986.
9. Letter from Michael A. Sills, State of New Hampshire Water Supply and
Pollution Control Commission to James Cadoret (June 6, 1986). Concerning
well water sampling on May 15, 1986.
10. Letter from Michael A. Sills, State of New Hampshire Water Supply and
Pollution Control Commission to Roben Choumitsky (June 6, 1986).
Concerning well water sampling on May 15, 1986.
11. Letter from Michael A. Sills, State of New Hampshire Water Supply and
Pollution Control Commission to Susan Clauson (June 6, 1986). Concerning
well water sampling on May 15, 1986.
12. Letter from Michael A. Sills, State of New Hampshire Water Supply and
Pollution Control Commission to Peter Deflumeri (June 6, 1986). Concerning
well water sampling on May 15,1986.
13. Letter from Michael A. Sills, State of New Hampshire " Water Supply and
Pollution Control Commission to Ruth Graves (June 6, 1986). Concerning well
water sampling on May 15, 1986.
14. Letter from Michael A. Sills, State of New Hampshire Water Supply and
Pollution Control Commission to Roben Sensale (June 6, 1986). Concerning
well water sampling on May 15, 1986.
15. Letter from Michael A. Sills, State of New Hampshire Water Supply and
Pollution Control Commission to Melenda Varney (June 6, 1986). Concerning
well water sampling on May 15, 1986.
16. Letter from Michael A. Sills, State of New Hampshire Water Supply and
Pollution Control Commission to Leonard Carleton (August 25, 1986).
Concerning well water sampling on August 8, 1986.
17. Letter from Michael A. Sills, State of New Hampshire Water Supply and
Pollution Control Commission to Robert Castellucci (August 25, 1986).
Concerning well water sampling on August 8, 1986.
18. Letter from Michael A. Sills, State of New Hampshire Water Supply and
Pollution Control Commission to Robert Iovanni (August 25, 1986).
Concerning well water sampling on August 8, 1986.
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Page 5
3.1
Correspondence (cont'd.)

. 19. Letter from Michael A. Sills, State of New Hampshire Water Supply and
. Pollution Control Commission to Charles Walsh (August 25, 1986).
Concerning well water sampling on August 8, 1986.
20. Letter from Muriel S. Robinette, State of New Hampshire Department of
Environmental Services to John and Bonnie Britt (April 13, 1987). Concerning
well water sampling on March 19, 1987.
21. Letter from Muriel S. Robinette, State of New Hampshire Department of
Environmental Services to Joanne Cocchiaro (April 13, 1987). Concerning well
water sampling on March 19, 1987.
22. Letter from Muriel S. Robinette, State of New Hampshire Department of
Environmental Services to Timothy Stewart (April 13, 1987). Concerning well
water sampling on March 19, 1987.
23. Letter from Muriel S. Robinette, State of New Hampshire Department of
Environmental Services to Barry Sullivan (April 13, 1987). Concerning well
water sampling on March 19, 1987.
24. Letter from Muriel S. Robinette, State of New Hampshire Department of
Environmental Services to Melenda Varney (April 13, 1987). Concerning well
water sampling on March 19, 1987.
25. Letter from Muriel S. Robinette, State of New Hampshire Department of
Environmental Services to Dana Kingston, Town of Raymond (April 16, 1987).
Concerning well water sampling on March 19, 1987.
26. Letter from Muriel S. Robinette, State of New Hampshire Department of
Environmental Services to Peter Deflumeri (April 22, 1987). Concerning well
water sampling on March 15, 1986 and April 26, 1985 with attached:
A. Letter from Michael A. Sills, State of New Hampshire Water Supply and
Pollution Control Commission to Peter Deflumeri (May 17, 1985).
Concerning well water sampling on April 26, 1985.
B. Letter from Michael A. Sills, State of New Hampshire Water Supply and
Pollution Control Commission to Peter Deflumeri (June 6, 1986).
. Concerning well water sampling on May 15, 1986.
27. Letter from Muriel S. Robinette, State of New Hampshire Department of
Environmental Services to Joel Cadoret (May 5, 1987). Concerning well water
sampling on April 9, 1987.
28. Letter from Muriel S. Robinette, State of New Hampshire Department of
Environmental Services to John Cadoret (May 5, 1987). Concerning well water
sampling on April 9, 1987.
29. Letter from Muriel S. Robinette, State of New Hampshire Department of
Environmental Services to James Cadoret (May 5, 1987). Concerning well
water sampling on April 9, 1987.
30. Letter from Muriel S. Robinette, State of New Hampshire Department of
Environmental Services to Robert Sensale (May 5, 1987). Concerning well
water sampling on April 9, 1987.
31. Letter from Muriel S. Robinette, State of New Hampshire Department of
Environmental Services to Lawrence Tremonti (May 5, 1987). Concerning well
water sampling on April 9, 1987.
32. Letter from Muriel S. Robinette, State of New Hampshire Department of
Environmental Services to Charles Walsh (May 5, 1987). Concerning well
water sampling on April 9, 1987.
33. Letter from Muriel S. Robinette, State of New Hampshire Department of
Environmental Services to Russell Berube (May 11, 1987). Concerning the
results of well water sampling on April 29, 1987 and May 4, 1987.
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Page 6
3.1
Correspondence (cont'd.)

34. Letter from Amy Juchatz, State of New Hampshire Department of Health and
Human Services to Russell Berube (May 19, 1987). Concerning the results of
well water sampling on Apri129, 1987 and May 4. 1987 and recommendations
on water usage and future retesting.
35. Letter from Muriel S. Robinette. State of New Hampshire Department of
Environmental Services to Donna Carroll (May 27. 1987). Concerning well
water sampling on Apri19. 1987 and April 29. 1987.
36. Letter from Muriel S. Robinette. State of New Hampshire Department of
Environmental Services to Leonard and Karen Carleton (June 1. 1987).
Concerning well water sampling on May 13. 1987.
37. Letter from Muriel S. Robinette. State of New Hampshire Department of
Environmental Services to Ruth Graves (June 1. 1987). Concerning well water
sampling on May 13. 1987.
38. Letter from Muriel S. Robinette. State of New Hampshire Department of
Environmental Services to Stephen McLaughlin (June 1. 1987). Concerning
well water sampling on May 13. 1987.
39. Letter from Muriel S. Robinette. State of New Hampshire Department of
Environmental Services to Robert Castellucci (June 9. 1987). Concerning well
water sampling on May 28. 1987.
40. Letter from Muriel S. Robinette. State of New Hampshire Department of
Environmental Services to Susan Clauson (June 9. 1987). Concerning well
water sampling on May 28. 1987.
41. Letter from Muriel S. Robinette. State of New Hampshire Department of
Environmental Services to Peter Deflumeri (June 9. 1987). Concerning well
water sampling on May 28. 1987.
42. Letter from Muriel S. Robinette. State of New Hampshire Department of
Environmental Services to Virginia Fernald (June 9. 1987). Concerning well
water sampling on May 28. 1987.
43. Letter from Muriel S. Robinette, State of New Hampshire Department of
. . Environmental Services to Dana Iverson (June 9. 1987). Concerning well water
sampling on May 28. 1987.
44. Letter from Muriel S. Robinette. State of New Hampshire Department of
Environmental Services to Mark Panageotes (June 9. 1987). Concerning well
water sampling on May 28. 1987.
45. Letter from Muriel S. Robinette. State of New Hampshire Department of
Environmental Services to Kent Wilkinson (June 9. 1987). Concerning well
water sampling on May 28. 1987.
46. Letter from Amy Juchatz. State of New Hampshire Department of Health and
Human Services to Cindy Sayers (June 17, 1987). Concerning the results of
well water sampling on June 5. 1987 and recommendations on water usage and
future retesting.
47. Letter from Muriel S. Robinette. State of New Hampshire Department of
Environmental Services to Scott and Joanne Brimicombe (July 27. 1987).
Concerning well water sampling on July 14. 1987.
48. Letter from Muriel S. Robinette. State of New Hampshire Department of
Environmental Services to James Campbell (July 27, 1987). Concerning well
water sampling on July 14, 1987.
49. Letter from Muriel S. Robinette. State of New Hampshire Department of
Environmental Services to Lewis Chesno (July 27, 1987). Concerning well
water sampling on July 14. 1987.
SO. Letter from Muriel S. Robinette. State of New Hampshire Department of
Environmental Services to William Warren (July 27. 1987). Concerning well
water sampling on July 14. 1987.
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Page 7
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3.1
Correspondence (cont'd.)

51. Letter from Muriel S. Robinette, State of New Hampshire Department of
Environmental Services to Mr. and Mrs. Kent Wilkinson (July 27, 1987).
Concerning well water sampling on July 14, 1987.
52. Letter from Muriel S. Robinette, State of New Hampshire Department of
Environmental Services to Mr. and Mrs. Alben Alix (August 11, 1987).
Concerning well water sampling on July 10, 1987.
53. Letter from Muriel S. Robinette, State of New Hampshire Department of
Environmental Services to Mr. Cross (August 11, 1987). Concerning well
water sampling on July 10, 1987.
54. Letter from Muriel S. Robinette, State of New Hampshire Department of
Environmental Services to Louis Diamtopolos (August II, 1987). Concerning
well water sampling on July 10, 1987.
55. Letter from Muriel S. Robinette, State of New Hampshire Department of
Environmental Services to Stephen Doherty (August 11, 1987). Concerning
well water sampling on July 10, 1987.
56. Letter from Muriel S. Robinette, State of New Hampshire Department of
Environmental Services to Mr. Donovan (August II, 1987). Concerning well
water sampling on July 10, 1987.
57. Letter from Muriel S. Robinette, State of New Hampshire Department of
Environmental Services to Kathleen Flibotte (August 11, 1987). Concerning
well water sampling on July 10, 1987.
58. Letter from Muriel S. Robinette, State of New Hampshire Department of
Environmental Services to Mr. Robertie (August II, 1987). Concerning well
water sampling on July 10, 1987.
59. Letter from Muriel S. Robinette, State of New Hampshire Department of
Environmental Services to Margaret Santoro (August II, 1987). Concerning
well water sampling on July 10, 1987.
60. Letter from Muriel S. Robinette, State of New Hampshire Department of
Environmental Services to Frederick Sommer (August 11, 1987). Concerning
well water sampling on July 10, 1987.
61. Letter from Muriel S. Robinette, State of New Hampshire Department of
Environmental Services to Stephen E. Toohey (August 11, 1987). Concerning
well water sampling on July 10, 1987.
62. Letter from Muriel S. Robinette, State of New Hampshire Department of
Environmental Services to Russell Berube (August 12, 1987). Concerning the
results of well water sampling on July 23, 1987.
63. Letter from Muriel S. Robinette, State of New Hampshire Department of
Environmental Services to Donna Carroll (August 12, 1987). Concerning well
water sampling on July 23,1987.
64. Letter from Muriel S. Robinette, State of New Hampshire Department of
Environmental Services to Joanne Cocchiaro (August 12, 1987). Concerning
well water sampling on July 23, 1987.
65. Letter from Muriel S. Robinette, State of New Hampshire Department of
Environmental Services to William Stine (August 12, 1987). Concerning well
water sampling on July 23, 1987.
66. Letter from John M. Regan, State of New Hampshire Department of
Environmental Services to Leonard Banagura, Town of Raymond Board of
Selectmen (September 9, 1987). Concerning well water sampling on
August 7, 1987.
67. Letter from John M. Regan, State of New Hampshire Department of
Environmental Services to John Cadoret (September 9, 1987). Concerning well
water sampling on August 7, 1987.
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Page 8
3.1
Ccmespondence (cont'd.)

68. Letter from John M. Regan, State of New Hampshire Department of
Environmental Services to James Cadoret (September 9, 1987). Concerning
well water sampling on August 7,1987.
69. Letter from John M. Regan, State of New Hampshire Department of
Environmental Services to Joel Cadoret (September 9, 1987). Concerning well
water sampling on August 7, 1987.
70. Letter from John M. Regan, State of New Hampshire Department of
Environmental Services to Leonard Carleton (September 9, 1987). Concerning
well water sampling on August 7,1987. .
71. Letter from John M. Regan, State of New Hampshire Department of
Environmental Services to Dana Iverson (September 9, 1987). Concerning well
water sampling on August 7.. 1987.
72. Letter from John M. Regan, State of New Hampshire Department of
Environmental Services to Richard Mailhot, Town of Raymond
(September 9, 1987). Concerning well water sampling on August 7, 1987.
73. Letter from John M. Regan, State of New Hampshire Department of
Environmental Services to Keith Noyes, Exeter Department of Public Works
(September 9, 1987). Concerning well water sampling on August 7, 1987.
74. Letter from John M. Regan, State of New Hampshire Department of
Environmental Services to Andrew Perry (September 9, 1987). Concerning
well water sampling on August 7, 1987.
75. Letter from Carl W. Baxter, State of New Hampshire Department of
Environmental Services to Mr. and Mrs. Steve Cashman (December 22, 1987).
Concerning the results of well water sampling on October 1, 1987.
76. Letter from Boyd P. Smith, State of New Hampshire Department of
Environmental Services to Steve Cashman (December 28, 1987). Concerning
the results of well water sampling on November 12, 1987.
77. Letter from Boyd P. Smith, State of New Hampshire Department of
Environmental Services to Kees Oudekerk (December 28, 1987). Concerning
the results of well water sampling on November 16, 1987.
78. Letter from Boyd P. Smi~ State of New Hampshire Department of
Environmental Services to William Robinson (December 28, 1987). Concerning
the results of well water sampling on November 16, 1987.
79. Letter from Boyd P. Smith, State of New Hampshire Department of
Environmental Services to Leonard and Karen Carleton (January 13, 1988).
Concerning well water sampling on December 16,1987.
80. Letter from Boyd P. Smith, State of New Hampshire Department of
Environmental Services to Robin Castellucci (January 13, 1988). Concerning
well water sampling on December 16, 1987.
81. Letter from Boyd P. Smith, State of New Hampshire Department of
Environmental Services to Mr. and Mrs. Lewis Chesno (January 13, 1988).
Concerning well water sampling on December 16, 1987.
82. Letter from Boyd P. Smith, State of New Hampshire Department of
Environmental Services to Mr. and Mrs. Paul GIeske (January 13, 1988).
Concerning well water sampling on December 16, 1987.
83. Letter from Boyd P. Smith, State of New Hampshire Department of
Environmental Services to Ruth Graves (January 13, 1988). Concerning well
water sampling on December 16,1987.
84. Letter from Boyd P. Smith, State of New Hampshire Department of
Environmental Services to Mr. and Mrs. John Iber (January 13, 1988).
Concerning well water sampling on December 16,1987.
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Page 9
3.1
Correspondence (cont'd.)

85. Letter from Boyd P. Smith, State of New Hampshire Department of
Environmental Services to Michael 1.oos (January 13, 1988). Concerning well
water sampling on December 16, 1987.
86. Letter from Boyd P. Smith, State of New Hampshire Department of
Environmental Services to Andrew Perry (January 13, 1988). Concerning well
water sampling on December 16, 1987.
87. Letter from Boyd P. Smith, State of New Hampshire Department of
Environmental Services to Mrs. Stracke-Morrill (January 13, 1988).
Concerning well water sampling on December 16, 1987.
88. Letter from Boyd P. Smith, State of New Hampshire Department of
Environmental Services to Deborah Wilkinson (January 13, 1988). Concerning
well water sampling on December 16,1987.
89. Letter from Amy Juchatz, State of New Hampshire Depamnent ofHea1th and
Human Services to Steve Cashman (January 19, 1988). Concerning the results
of well water sampling on November 12, 1987.
90. Letter from Amy Juchatz, State of New Hampshire Department of Health and
Human Services to Kees Oudekerk (January 19, 1988). Concerning the results
of well water sampling on November 16, 1987.
91. Letter from Amy Juchatz, State of New Hampshire Department of Health and
Human Services to William Robinson (January 19,1988). Concerning the
results of well water sampling on November 16, 1987.
92. Letter from Boyd P. Smith, State of New Hampshire Department of
Environmental Services to John Britt (March 7, 1988). Concerning well water
sampling on November 12, 1987.
93. Letter from Boyd P. Smith, State of New Hampshire Department of
Environmental Services to James Cadoret (March 7, 1988). Concerning well
water sampling on December 3,1987.
94. Letter from Boyd P. Smith, State of New Hampshire Department of
Environmental Services to Robert Casoni (March 7,1988). Concerning well
water sampling on November 16, 1987.
95. Letter from Boyd P. Smith, State of New Hampshire Department of
Environmental Services to Susan Clauson (March 7, 1988). Concerning well
water sampling on November 16, 1987.
96. Letter from Boyd P. Smith, State of New Hampshire Department of
Environmental Services to Peter Deflumeri (March 7, 1988). Concerning well
water sampling on December 3,1987.
97. Letter from Boyd P. Smith, State of New Hampshire Department of
Environmental Services to George Demerrlt, Len-Kay Campground
(March 7, 1988). Concerning well water sampling on October I, 1987.
98. Letter from Boyd P. Smith, State of New Hampshire Department of
Environmental Services to Patrice Fredette (March 7, 1988). Concerning well
water sampling on November 16, 1987.
99. Letter from Boyd P. Smith, State of New Hampshire Department of
Environmental Services to E. Fongeallaz (March 7, 1988). Concerning well
water sampling on November 16, 1987.
100. Letter from Boyd P. Smith, State of New Hampshire Department of
Environmental Services to Dana Iverson (March 7, 1988). Concerning well
water sampling on December 3,1987.
101. Letter from Boyd P. Smi,th, State of New Hampshire Department of
Environmental Services to Al Jewett (March 7,1988). Concerning well water
sampling on December 3, 1987.
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Page 10
3.1
Correspondence (cont'd.)

102. Letter from Boyd P. Smith, State of New Hampshire Department of
Environmental Services to Richard Mailhot, Town of Raymond
(March 7,1988). Concerning well water sampling on November 12,1987.
103. Letter from Boyd P. Smith, State of New Hampshire Department of
Environmental Services to Mark Panageotes (March 7, 1988). Concerning well
water sampling on December 3, 1987.
104. Letter from Boyd P. Smith, State of New Hampshire Department of
Environmental Services to Olive Peabody (March 7, 1988). Concerning well
water sampling on October 1, 1987.
105. Letter from Boyd P. Smith, State of New Hampshire Department of
Environmental Services to Robert Sensale (March 7, 1988). Concerning well
water sampling on November 16, 1987.
106. Letter from Boyd P. Smith, State of New Hampshire Department of
Environmental Services to Barry Sullivan (March 7, 1988). Concerning well
water sampling on November 16, 1987.
107. Letter from Boyd P. Smith, State of New Hampshire Department of
Environmental Services to Melenda Varney (March 7, 1988). Concerning well
water sampling on November 16, 1987.
108. Letter from Boyd P. Smith, State of New Hampshire Department of
Environmental Services to William Wanen (March 7, 1988). Concerning well
water sampling on December 3, 1987.
109. Letter from Boyd P. Smith, State of New Hampshire Department of
Environmental Services to Robert Iovanni (March 8, 1988). Concerning well
water sampling on December 3, 1987.
110. Letter from Boyd P. Smith, State of New Hampshire Department of
Environmental Services to Mr. and Mrs. Annis (May 9, 1988). Concerning well
water sampling on April 14, 1988.
111. Letter from Boyd P. Smith, State of New Hampshire Department of
Environmental Services to Mr. and Mrs. Banarer/Flick (May 9, 1988).
Concerning well water sampling on April 20, 1988.
1'12. Letter from Boyd P. Smith, State of New Hampshire Department of
Environmental Services to Mr. and Mrs. Russell Berube (May 9, 1988).
Conce~;ng well water sampling on April 20, 1988.
113. Letter ...m Boyd P. Smith, State of New Hampshire Department of
Envirc.:nental Services to Mr. and Mrs. Blake (May 9, 1988). Concerning well
water sampling on April 20, 1988.
114. Letter from Boyd P. Smith, State of New Hampshire Department of
Environmental Services to Mr. and Mrs. James Campbell (May 9, 1988).
Concerning well water sampling on April 20, 1988.
115. Letter from Boyd P. Smith, State of New Hampshire Department of
Environmental Services to Mr. and Mrs. Steve Cashman (May 9, 1988).
Concerning well water sampling on April 20, 1988.
116. Letter from Boyd P. Smith, State of New Hampshire Department of
Environmental Services to Mr. and Mrs. Fernald (May 9, 1988). Concerning
well water sampling on April 14, 1988.
117. Letter from Boyd P. Smith, State of New Hampshire Department of
Environmental Services to Mr. and Mrs. James McDermott (May 9, 1988).
Concerning well water sampling on April 14, 1988.
118. Letter from Boyd P. Smith, State of New Hampshire Department of
Environmental Services to Mr. and Mrs. Papamichael (May 9, 1988).
Concerning well water sampling on April 14, 1988.
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Page 11
3.1
Correspondence (cont'd.)

119. Letter from Boyd P. Smith, State of New Hampshire Department of
Environmental Services to Mr. and Mrs. Robinson (May 9, 1988). Concerning
well water sampling on April 20, 1988.
120. Letter from Boyd P. Smith, State of New Hampshire Department of
Environmental Services to Mr. and Mrs. William Stine (May 9, 1988).
Concerning well water sampling on April 20, 1988.
121. Letter from Boyd P. Smith, State of New Hampshire Department of
Environmental Services to Mr. and Mrs. Sid Vallet (May 9, 1988). Concerning
well water sampling on April 14, 1988. .
122. Letter from Patricia Hannon, State of New Hampshire Department of
Environmental Services to Mr. and Mrs. Robert Banara (October 11, 1988).
Concerning well water sampling on September 15, 1988.
123. Letter from Patricia Hannon, State of New Hampshire Department of
Environmental Services to Mr. and Mrs. Russell Berube (October 11, 1988).
Concerning well water sampling on September 14, 1988.
124. Letter from Patricia Hannon, State of New Hampshire Department of
Environmental Services to Mr. and Mrs. James Cadoret (October II, 1988).
Concerning well water sampling on September 14, 1988.
125. Letter from Patricia Hannon, State of New Hampshire Department of
Environmental Services to Mr. and Mrs. Michael Campbell (October II, 1988).
Concerning well water sampling on September 14, 1988.
126. Letter from Patricia Hannon, State of New Hampshire Department of
Environmental Services to Donna Carroll (October 11, 1988). Concerning well
water sampling on September 14, 1988.
127. Letter from Patricia Hannon, State of New Hampshire Department of
Environmental Services to Leonard and Karen Carleton (October 11, 1988).
Concerning well water sampling on September 15, 1988.
128. Letter from Patricia Hannon, State of New Hampshire Department of
Environmental Services to Mr. and Mrs. Cashman (October II, 1988).
Concerning well water sampling on September 15, 1988. .
129. Letter from Patricia Hannon, State of New Hampshire Department of
Environmental Services to Robert and Robin Castellucci (October 11, 1988).
Concerning well water sampling on September 15, 1988.
130. Letter from Patricia Hannon, State of New Hampshire Department of
Environmental Services to Mr. and Mrs. Ciechomski (October 11, 1988).
Concerning of well water sampling on September 15, 1988.
131. Letter from Patricia Hannon, State of New Hampshire Department of
Environmental Services to Susan Clauson (October 11, 1988). Concerning well
water sampling on September 22, 1988.
132. Letter from Patricia Hannon, State of New Hampshire Department of
Environmental Services to Mr. and Mrs. Cocchiaro (October 11, 1988).
Concerning well water sampling on September 14, 1988.
133. Letter from Patricia Hannon, State of New Hampshire Department of
Environmental Services to Linda Dawson (October 11, 1988). Concerning the
results of well water sampling on September 14, 1988.
134. Letter from Patricia Hannon, State of New Hampshire Department of
Environmental Services to Peter Deflumeri (October II, 1988). Concerning
well water sampling on September 22, 1988.
135. Letter from Patricia Hannon, State of New Hampshire Department of
Environmental Services to Virginia Fernald (October 11, 1988). Concerning
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Page 12
3.1
Correspondence (cont'd.)

136. Letter from Patricia Hannon, State of New Hampshire Department of
Environmental Services to Mr. and Mrs. John Fredette (October II, 1988).
Concerning well water sampling on September 22, 1988.
137. Letter from Patricia Hannon, State of New Hampshire Department of
Environmental Services to Ruth Graves (October II, 1988). Concerning well
water sampling on September 22, 1988.
138. Letter from Patricia Hannon, State of New Hampshire Department of
Environmental Services to Mr. and Mrs. Robert Iovanni (October II, 1988).
Concerning well water sampling on September 14, 1988.
139. Letter from Patricia Hannon, State of New Hampshire Department of
Environmental Services to Mr. and Mrs. James McDermott (October 11,1988).
Concerning the results of well water sampling on September 14, 1988.
140. Letter from Patricia Hannon, State of New Hampshire Department of
Environmental Services to Mr. and Mrs. Kees Oudekerk (October 11, 1988).
Concerning the results of well water sampling on September 14, 1988.
141. Letter from Patricia Hannon, State of New Hampshire Department of
Environmental Services to Mark Panageotes (October II, 1988). Concerning
well water sampling on September 22, 1988.
142. Letter from Patricia Hannon, State of New Hampshire Department of
Environmental Services to Mr. and Mrs. Papamichael (October II, 1988).
Concerning well water sampling on September 14, 1988.
143. Letter from Patricia Hannon, State of New Hampshire Department of
Environmental Services to Mr. and Mrs. William Robinson (October II, 1988).
Concerning well water sampling on September 14, 1988.
144. Letter from Patricia Hannon, State of New Hampshire Department of
Environmental Services to Mr. and Mrs. Robert Sensale (October 11, 1988).
Concerning well water sampling on September 22, 1988.
145. Letter from Patricia Hannon, State of New Hampshire Department of
Environmental Services to Michael Stiling (October 11, 1988). Concerning
well water sampling on September 22, 1988.
1~6. Letter from Patricia Hannon, State of New Hampshire Department of
Environmental Services to William Stine (October II, 1988). Concerning well
water sampling on September 15, 1988. .
147. Letter from Patricia Hannon, State of New Hampshire Department of .
Environmental Services to Charles Stracke (October 11, 1988). Concerning
well water sampling on September 22, 1988.
148. Letter from Patricia Hannon, State of New Hampshire Department of
Environmental Services to Barry Sullivan (October 11. 1988). Concerning well
water sampling on September 22, 1988.
149. Letter from Patricia Hannon. State of New Hampshire Department of
Environmental Services to Mr. and Mrs. William Warren (October 11. 1988).
Concerning well water sampling on September 14, 1988.
150. Letter from Patricia Hannon, State of New Hampshire Department of
Environmental Services to Sag Harbor Builders (October 17, 1988).
Concerning well water sampling on September 15, 1988.
151. Letter from Patricia Hannon, State of New Hampshire Department of
Environmental Services to Mr. and Mrs. Zins (October 17. 1988). Concerning
well water sampling on September 15, 1988.
152. Letter from Amy Juchatz, State of New Hampshire Department of Health and
Human Services to Linda Dawson (November 4, 1988). Concerning the results
of well water sampling on September 14, 1988 and recommendations on water
usage and future retesting.
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Page 13
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3,1
Correspondence (cont'd.)

153. Letter from Amy Juchatz, State of New Hampshire Department ofHea1th and
Human Services to Mr. and Mrs. James McDennott (November 4, 1988).
Concerning the results of well water sampling on September 14, 1988 and
recommendations on water usage and future retesting.
154. Letter from Amy Juchatz, State of New Hampshire Department of Health and
Human Services to Mr. and Mrs. Kees Oudekerk (November 4, 1988).
Concerning the results of well water sampling on September 14, 1988 and
recommendations on water usage and future retesting.
155. Letter from Patricia Hannon, State of New Hampshire Department of
Environmental Services to Leonard and Karen Carleton (March 14, 1989).
Concerning well water sampling on February 9, 1989.
156. Letter from Patricia Hannon, State of New Hampshire Department of
Environmental Services to Mr. and Mrs. Cashman (March 14, 1989).
Concerning well water sampling on February 9, 1989.
157. Letter from Patricia Hannon, State of New Hampshire Department of
Environmental Services to Mr. and Mrs. Dawson (March 14, 1989).
Concerning well water sampling on February 9, 1989.
158. Letter from Patricia Hannon, State of New Hampshire Department of
Environmental Services to Mr. and Mrs. James McDennott (March 14, 1989).
Concerning well water sampling on February 9, 1989.
159. Letter from Patricia Hannon, State of New Hampshire Department of
Environmental Services to Mr. and Mrs. Kees Oudekerk (March 14, 1989).
Concerning well water sampling on February 9, 1989.
160. Letter from Patricia Hannon, State of New Hampshire Department of
Environmental Services to Mr. and Mrs. William Robinson (March 14, 1989).
Concerning well water sampling on February 9, 1989.
161. Letter from Brook S. Dupee, State of New Hampshire Department of Health and
Human Services to Mr. and Mrs. Kees Oudekerk (March 21, 1989).
Concerning recommendations following well water sampling on
February 9, 1989.
162. Letter from Brook S. Dupee, State of New Hampshire Department of Health and
Human Services to Mr. and Mrs. Dawson (March 22, 1989). Concerning
recommendations following well water sampling on February 9, 1989.
163. Letter from Brook S. Dupee, State of New Hampshire Department of Health and
Human Services to Mr. and Mrs. James McDennott (March 22, 1989).
Concerning recommendations following well water sampling on
February 9, 1989.
164. Letter from Joseph N. Donovan, State of New Hampshire Department of
Environmental Services to Russell Berube (May 25, 1989). Concerning well
water sampling on April 20, 1989.
165. Letter from Joseph N. Donovan, State of New Hampshire Department of
Environmental Services to James Cadoret (May 25, 1989). Concerning well
water sampling on April 20, 1989.
166. Letter from Joseph N. Donovan, State of New Hampshire Department of
Environmental Services to John Cadoret (May 25, 1989). Concerning well
water sampling on April 20, 1989.
167. Letter from Joseph N. Donovan, State of New Hampshire Department of
Environmental Services to Leonard Carleton (May 25, 1989). Concerning well
water sampling on April 20, 1989.
..
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Page 14
3.1
Correspondence (cont'd.)

168. Letter from Joseph N. Donovan, State of New Hampshire Department of
. Environmental Services to Mr. Cashman (May 25, 1989). Concerning well
water sampling on April 20. 1989.
169. Letter from Joseph N. Donovan, State of New Hampshire Department of
Environmental Services to Mr. Dawson (May 25, 1989). Concerning well water
sampling on April 20, 1989.
170. Letter from Joseph N. Donovan, State of New Hampshire Department of
Environmental Services to Virginia Fernald (May 25. 1989). Concerning well
water sampling on April 21, 1989. .
171. Letter from Joseph N. Donovan, State of New Hampshire Department of
Environmental Services to Emery Graves (May 25. 1989). Concerning well
water sampling on April 20, 1989.
172. Letter from Joseph N. Donovan. State of New Hampshire Department of
Environmental Services to Dana Iverson (May 25. 1989). Concerning well
water sampling on April 21. 1989.
173. Letter from Joseph N. Donovan, State of New Hampshire Department of
Environmental Services to James McDermott (May 25, 1989). Concerning well
water sampling on April 21. 1989.
174. Letter from Joseph N. Donovan, State of New Hampshire Department of
Environmental Services to Stephen McLaughlin (May 25, 1989). Concerning
well water sampling on April 20. 1989.
175. Letter from Joseph N. Donovan, State of New Hampshire Department of
Environmental Services to Kees Oudekerk (May 25, 1989). Concerning well
water sampling on April 24. 1989.
176. Letter from Joseph N. Donovan, State of New Hampshire Department of
Environmental Services to William Robinson (May 25, 1989). Concerning well
water sampling on April 21. 1989.
177. Letter from Joseph N. Donovan, State of New Hampshire Department of
Environmental Services to John Scuto (May 25. 1989). Concerning well water
sampling on April 20, 1989.
178. Letter from Joseph N. Donovan, State of New Hampshire Department of
Environmental Services to Robert Sensale (May 25, 1989). Concerning well
water sampling on April 20, 1989.
179. Letter from Joseph N. Donovan, State of New Hampshire Department of
Environmental Services to Michael Stiling (May 25. 1989). Concerning well
water sampling on April 21, 1989.
180. Letter from Joseph N. Donovan, State of New Hampshire Department of
Environmental Services to Charles Stracke (May 25, 1989). Concerning well
water sampling on Apri121, 1989.
181. Letter from Joseph N. Donovan. State of New Hampshire Department of
Environmental Services to Barry Sullivan (May 25, 1989). Concerning well
water sampling on April 20, 1989.
182. Letter from Joseph N. Donovan. State of New Hampshire Department of
Environmental Services to Sid Vallet (May 25, 1989). Concerning well water
sampling on April 20, 1989.
183. Letter from Michael J. Robinette, State of New Hampshire Department of
Environmental Services to Kent Wilkinson (May 26, 1989). Concerning the
results of well water sampling on April 21, 1989.
184. Letter from Amy Juchatz, State of New Hampshire Department of Health and
Human Services to Kent Wilkinson (June 2, 1989). Concerning well water
sampling on April 21, 1989, a health evaluation, and recommendations on water
usage and future retesting.
.
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Page 15
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3.1
Correspondence (cont'd.)

185. Letter from Michael J. Robinette, State of New Hampshire Department of
Environmental Services to Russell Berube (October 25, 1989). Concerning well
water sampling on September 28, 1989.
186. Letter from Michael J. Robinette, State of New Hampshire Department of
Environmental Services to Scott Brimicombe (October 25, 1989). Concerning
well water sampling on September 26, 1989.
187. Letter from Michael J. Robinette, State of New Hampshire Department of
Environmental Services to James Cadoret (October 25, 1989). Concerning well
water sampling on September 28, 1989. '
188. Letter from Michael J. Robinette, State of New Hampshire Department of
Environmental Services to John Cadoret (October 25, 1989). Concerning well
water sampling #135532 on September 28, 1989.
189. Letter from Michael J. Robinette, State of New Hampshire Department of
Environmental Services to John Cadoret (October 25, 1989). Concerning well
water sampling #1355533 on September 28, 1989.
190. Letter from Michael J. Robinette, State of New Hampshire Department of
Environmental Services to Leonard Carleton (October 25, 1989). Concerning
well water sampling on September 28, 1989.
191. Letter from Michael J. Robinette, State of New Hampshire Department of
Environmental Services to Mr. Cashman (October 25, 1989). Concerning well
water sampling on September 28, 1989.
192. Letter from Michael J. Robinette, State of New Hampshire Department of
Environmental Services to Mr. and Mrs. Cashman (October 25, 1989).
Concerning well water sampling on September 28, 1989.
193. Letter from Michael 1. Robinette, State of New Hampshire Department of
Environmental Services to Mr. Dawson (October 25, 1989). Concerning well
water sampling on September 26, 1989.
194. Letter from Michael 1. Robinette, State of New Hampshire Department of
Environmental Services to Virginia Fernald (October 25, 1989). Concerning
well water sampling #135527 on September 28, 1989.
195. Letter from Michael J. Robinette, State of New Hampshire Department of
Environmental Services to Virginia Fernald (October 25, 1989). Concerning
well water sampling #135528 on September 28, 1989.
196. Letter from Michael J. Robinette, State of New Hampshire Department of
Environmental Services to Emery Graves (October 25, 1989). Concerning well
water sampling on September 28, 1989.
197. Letter from Michael J. Robinette, State of New Hampshire Department of
Environmental Services to Dana Iverson (October 25, 1989). Concerning well
water sampling on September 26, 1989.
198. Letter from Michael 1. Robinette, State of New Hampshire Department of
Environmental Services to Stephen McLaughlin (October 25, 1989).
Concerning well water sampling on September 28, 1989.
199. Letter from Michael 1. Robinette, State of New Hampshire Department of
Environmental Services to Mr. and Mrs. Stephen McLaughlin
(October 25, 1989). Concerning well water sampling on September 26, 1989.
200. Letter from Michael J. Robinette, State of New Hampshire Department of
Environmental Services to Kecs Oudekerk (October 25, 1989). Concerning well
water sampling on September 26, 1989.
201. Letter from Michael 1. Robinette, State of New Hampshire Department of
Environmental Services to William Robinson (October 25, 1989). Concerning
well water sampling on September 26, 1989.
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Page 16
3.1
Correspondence (cont'd.)
202. Letter from Michael 1. Robinette, State of New Hampshire Department of
, . Environmental Services to John Scuto (October 25, 1989). Concerning well
. water sampling on September 28, 1989.
203. Letter from Michael J. Robinette, State of New Hampshire Department of
Environmental Services to Robert Sensale (October 25, 1989). Concerning well
water sampling on September 28, 1989.
204. Letter from Michael J. Robinette, State of New Hampshire Department of
Environmental Services to Timothy Stewart (October 25, 1989). Concerning
well water sampling on September 28, 1989. .
205. Letter from Michael J. Robinette, State of New Hampshire Department of
Environmental Services to Michael Stiling (October 25, 1989). Concerning well
water sampling #135415 on September 26, 1989.
206. Letter from Michael J. Robinette, State of New Hampshire Department of
Environmental Services to Michael Stiling (October 25, 1989). Concerning well
water sampling #135416 on September 26, 1989.
207. Letter from Michael 1. Robinette, State of New Hampshire Department of .
Environmental Services to Charles Stracke (October 25, 1989). Concerning
well water sampling on September 26, 1989.
208. Letter from Michael J. Robinette, State of New Hampshire Department of
Environmental Services to Barry Sullivan (October 25, 1989). Concerning well
water sampling on September 26, 1989.
209. Letter from Michael J. Robinette, State of New Hampshire Department of
Environmental Services to Sid Vallet (October 25, 1989). Concerning well
water sampling on September 28, 1989.
210. Letter from Michael 1. Robinette, State of New Hampshire Department of
Environmental Services to Kent Wilkinson (October 25, 1989). Concerning
well water sampling #135406 on September 26, 1989.
211. Letter from Michael 1. Robinette, State of New Hampshire Department of
Environmental Services to Kent Wilkinson (October 25, 1989). Concerning
well water sampling #135407 on September 26, 1989. .
212. Letter from Michael J. Robinette, State of New Hampshire Department of
Environmental Services to Mr. and Mrs. James McDermott (October 30, 1989).
Concerning well water sampling on September 28, 1989.
213. Letter from Amy Juchatz, State of New Hampshire Department of Health and
Human Services to Mr. and Mrs. James McDermott (November 15, 1989).
Concerning the results of well water sampling on September 28, 1989 and
recommendations on water usage and future retesting.
214. Letter from Michael J. Robinette, State of New Hampshire Department of
Environmental Services to Russell Berube (January 17, 1990). Concerning well
water sampling on December 13, 1989.
215. Letter from Michael J. Robinette, State of New Hampshire Department of
Environmental Services to Scott and Joanne Brimicombe (January 17, 1990).
Concerning well water sampling on December 14,1989.
216. Letter from Michael J. Robinette, State of New Hampshire Department of
Environmental Services to James Cadoret (January 17, 1990). Concerning well
water sampling #140200 on December 13, 1989.
217. Letter from Michael 1. Robinette, State of New Hampshire Department of
Environmental Services to James Cadoret (January 17, 1990). Concerning well
water sampling #140201 on December 13, 1989.
218. Letter from Michael 1. Robinette, State of New Hampshire Department of
Environmental Services to John Cadoret (January 17, 1990). Concerning well
water sampling on December 13,1989.
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3.1
Page 17
.::..
COITespondence (cont'd.)

219. Letter from Michael 1. Robinette, State of New Hampshire Department of
Environmental Services to Leonard and Karen Carleton (January 17, 1990).
Concerning well water sampling on December 14,1989.
220. Letter from Michael 1. Robinette, State of New Hampshire Department of
Environmental Services to Mr. and Mrs. Cashman (January 17, 1990).
Concerning well water sampling on December 13, 1989.
221. Letter from Michael J. Robinette, State of New Hampshire Department of
Environmental Services to Mr. and Mrs. Dawson (January 17, 1990).
Concerning well water sampling on December 13, 1989.
222. Letter from Michael 1. Robinette, State of New Hampshire Department of
Environmental Services to Virginia Femald (January 17, 1990). Concerning
well water sampling on DeGember 13, 1989.
223. Letter from Michael 1. Robinette, State of New Hampshire Department of
Environmental Services to Ruth Graves (January 17, 1990). Concerning well
water sampling on December 14, 1989.
224. Letter from Michael J. Robinette, State of New Hampshire Department of
Environmental Services to Dana Iverson (January 17,1990). Concerning well
water sampling on December 14, 1989.
225. Letter from Michael 1. Robinette, State of New Hampshire Department of
Environmental Services to James McDermott (January 17, 1990). Concerning
well water sampling on DeGember 13, 1989.
226. Letter from Michael J. Robinette, State of New Hampshire Department of
Environmental Services to Mr. and Mrs. Kees Oudekerk (January 17, 1990).
Concerning well water sampling on December 14,1989.
227. utter from Michael 1. Robinette, State of New Hampshire Department of
Environmental Services to William Robinson (January 17, 1990). Concerning
well water sampling on December 13, 1989.
228. Letter from Michael 1. Robinette, State of New Hampshire Department of
Environmental Services to Mr. and Mrs. Scuto (January 17, 1990). Concerning
well water sampling on DeGember 14, 1989.
229. Letter from Michael 1. Robinette, State of New Hampshire Department of
Environmental Services to Robert Sensale (January 17, 1990). Concerning well
water sampling on December 18, 1989.
230. Letter from Michael J. Robinette, State of New Hampshire Department of
Environmental Services to Timothy Stewart (January 17, 1990). Concerning
well water sampling on December 14,1989.
231. Letter from Michael 1. Robinette, State of New Hampshire Department of
Environmental Services to Michael Stiling (January 17, 1990). Concerning well
water sampling on December 14, 1989.
232. Letter from Michael J. Robinette, State of New Hampshire Department of
Environmental Services to Charles Stracke (January 17, 1990). Concerning
well water sampling on DeGember 13,1989.
233. Letter from Michael J. Robinette, State of New Hampshire Department of
Environmental Services to Barry Sullivan (January 17, 1990). Concerning well
water sampling on December 13, 1989.
234. Letter from Michael J. Robinette, State of New Hampshire Department of
Environmental Services to Sid Vallet (January 17, 1990). Concerning well
water sampling on December 14, 1989.
235. Letter from Michael 1. Robinette, State of New Hampshire Department of
Environmental Services to Kent Wilkinson (January 17,1990). Concerning
well water sampling on DeGember 13, 1989.
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Page 18
"
3.1
Correspondence (cont'd.)

236. Letter from Michael J. Robinette, State of New Hampshire Department of
Environmental Services to Russell Berube (July 26, 1990). Concerning well
water sampling on June 28, 1990.
237. Letter from Michael J. Robinette, State of New Hampshire Department of
Environmental Services to Scott Brimicombe (July 26, 1990). Concerning well
water sampling on June 27, 1990.
238. Letter from Michael J. Robinette, State of New Hampshire Department of
Environmental Services to James Cadoret (July 26, 1990). Concerning well
water sampling on June 28, 1990. .
239. Letter from Michael J. Robinette, State of New Hampshire Department of
Environmental Services to John Cadoret (July 26, 1990). Concerning well
water sampling on June 28, 1990.
240. Letter from Michael 1. Robinette, State of New Hampshire Department of
Environmental Services to Leonard Carleton (July 26, 1990). Concerning well
water sampling on June 27, 1990.
241. Letter from Michael J. Robinette, State of New Hampshire Department of
Environmental Services to Mr. Cashman (July 26, 1990). Concerning well
water sampling on June 27, 1990.
242. Letter from Michael J. Robinette, State of New Hampshire Department of
Environmental Services to Mr. Dawson (July 26, 1990). Concerning well water
sampling on June 27, 1990.
243. Letter from Michael J. Robinette, State of New Hampshire Department of
Environmental Services to Virginia Fernald (July 26, 1990). Concerning well
water sampling on June 27, 1990.
244. Letter from Michael J. Robinette, State of New Hampshire Department of
Environmental Services to Emery Graves (July 26, 1990). Concerning well
water sampling on June 28, 1990.
245. Letter from Michael J. Robinette, State of New Hampshire Department of
Environmental Services to Dana Iverson (July 26, 1990). Concerning well
water sampling on June 27, 1990.
246. Letter from Michael 1. Robinette, State of New Hampshire Department of
Environmental Services to Stephen McLaughlin (July 26, 1990). Concerning
well water sampling on June 27, 1990.
247. Letter from Michael J. Robinette, State of New Hampshire Department of
Environmental Services to Mrs. Oudekerk (July 26, 1990). Concerning well
water sampling on June 27, 1990.
248. Letter from Michael J. Robinette, State of New Hampshire Department of
Environmental Services to William Robinson (July 26,1990). Concerning well
water sampling on June 27, 1990.
249. Letter from Michael 1. Robinette, State of New Hampshire Department of
Environmental Services to John Scuto (July 26, 1990). Concerning well water
sampling on June 27, 1990.
250. Letter from Michael 1. Robinette, State of New Hampshire Department of
Environmental Services to Timothy Stewart (July 26, 1990). Concerning well
water sampling on June 27, 1990.
251. Letter from Michael J. Robinette, State of New Hampshire Department of
Environmental Services to Robert Sensale (July 26, 1990). Concerning well
water sampling on June 28, 1990.
252. Letter from Michael 1. Robinette, State of New Hampshire Department of
Environmental Services to Michael Stiling (July 26, 1990). Concerning well
water sampling on June 27, 1990.
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Page 19
r
3.1
Correspondence (cont'd.)

253. Letter from Michael J. Robinette, State of New Hampshire Department of
Environmental Services to Charles Stracke (July 26, 1990). Concerning well
water sampling on June 27, 1990.
254. Letter from Michael 1. Robinette, State of New Hampshire Department of
Environmental Services to Barry Sullivan (July 26, 1990). Concerning well
water sampling on June 27,1990.
255. Letter from Michael J. Robinette, State of New Hampshire Department of
Environmental Services to Sid Vallet (July 26, 1990). Concerning well water
sampling on June 27, 1990.
256. Letter from Michael J. Robinette, State of New Hampshire Department of
Environmental Services to Kent Wilkinson (July 26, 1990). Concerning well
water sampling on June 27, 1990.
257. Letter from Michael 1. Robinette, State of New Hampshire Department of
Environmental Services to James McDennott (July 30, 1990). Concerning the
results of well water sampling on June 27, 1990.
Progress Meetings

258. Letter from Roger Duwart, EPA Region I to John Peltonen, Stark & Pelton en
(Attorney for KJ. Quinn & Company, Inc.) (June 14, 1988). Concerning a
summary of the June 7, 1988 monthly progress meeting.
259. Letter from Roger Duwart, EPA Region I to John Peltonen, Stark & Peltonen
(Attorney for K.J. Quinn & Company, Inc.) (July 29, 1988). Concerning a
summary of the July 12, 1988 monthly progress meeting.
260. Letter from Roger Duwart, EP A Region I to John Peltonen, Stark & Peltonen
(Attorney for K.J. Quinn & Company, Inc.) (August 24, 1988). Concerning a
summary of the August 16, 1988 monthly progress meeting.
261. Letter from Roger Duwart, EPA Region I to John Peltonen, Stark & Peltonen
(Attorney for KJ. Quinn & Company, Inc.) (October 6, 1988). Concerning a
summary of the September 22, 1988 monthly progress meeting.
2'62. Letter from Roger Duwart, EP A Region I to John Peltonen, Stark & Peltonen
(Attorney for KJ. Quinn & Company, Inc.) (November 10,1988). Concerning
a summary of the October 18, 1988 monthly progress meeting.
263. Letter from Roger Duwart, EPA Region I to John Peltonen, Stark & Peltonen
(Attorney for KJ. Quinn & Company, Inc.) (December 7, 1988). Concerning a
summary of the December 6, 1988 monthly progress meeting.
264. Letter from Roger Duwart, EPA Region I to John Peltonen, Stark & Peltonen
(Attorney for K.J. Quinn & Company, Inc.) (January 25, 1989). Concerning a
summary of the January 10, 1989 monthly progress meeting.
265. Letter from Roger Duwart, EP A Region I to John Peltonen, Stark & Peltonen
(Attorney for K1. Quinn & Company, Inc.) (March 2, 1989). Concerning
postponement of the February 14, 1989 progress meeting until March 7, 1989.
266. Letter from Roger Duwart, EP A Region I to John Peltonen, Stark & Peltonen
(Attorney for KJ. Quinn & Company, Inc.) (March 8, 1989). Concerning a
summary of the March 7, 1989 monthly progress meeting.
267. Letter from Roger Duwart, EP A Region I to John Peltonen, Stark & Peltonen
(Attorney for KJ. Quinn & Company, Inc.) (April 5, 1989). Concerning a
summary of the April 4, 1989 monthly progress meeting.
268. Letter from Roger Duwart, EP A Region I to John Peltonen, Stark & Peltonen
(Attorney for KJ. Quinn & Company, Inc.) (May 8, 1989). Concerning
postponement of the May 9, 1989 progress meeting until June 6, 1989.
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Page 20
.
3.1
Correspondence (cont'd.)
3.2
, 269. Letter from Roger Duwart, EP A Region I to John Peltonen, Stark & Peltonen
,> (Attorney for K.J. Quinn & Company, Inc.) (June 13, 1989). Concerning a
summary of the June 6, 1989 monthly progress meeting.
270. Letter from Roger Duwart, EP A Region I to John Peltonen, Stark & Peltonen
(Attorney for K.J. Quinn & Company, Inc.) (September 25, 1989). Concerning
a summary of the August 22, 1989 monthly progress meeting.
271. Letter from Roger Duwart, EPA Region I to John Peltonen, Stark & Peltonen
(Attorney for K.J. Quinn & Company, Inc.) (October 26, 1989). Concerning a
summary of the October 24, 1989 monthly progress meeting.
272. Letter from Roger Duwart, EP A Region I to John Peltonen, Stark & Peltonen
(Attorney for K.J. Quinn & Company, Inc.) (November 28, 1989). Concerning
a summary of the November 28, 1989 monthly progress meeting.
273. Letter from Roger Duwart, EP A Region I to John Peltonen, Stark & Peltonen
(Attorney for K.J. Quinn & Company, Inc.) (January 30, 1990). Concerning a
summary of the January 23, 1990 monthly progress meeting.
274. Letter from Roger Duwart, EPA Region I to John Peltonen, Stark & Peltonen
(Attorney for K.J. Quinn & Company, Inc.) (February 26, 1990). Concerning
conflmlation of upcoming progress meeting on March 12, 1990.
275. Letter from Roger Duwart, EPA Region I to John Peltonen, Stark & Peltonen
(Attorney for K.J. Quinn & Company, Inc.) (March 13, 1990). Concerning a
summary of the March 12, 1990 monthly progress meeting.
276. Letter from Roger Duwart, EP A Region I to John Peltonen, Stark & Peltonen
(Attorney for K.J. Quinn & Company, Inc.) (June 1, 1990). Concerning a
summary of the May 22, 1990 monthly progress meeting.

Sampling and Analysis Data
The records cited in entry numbers 1 through 40 may be reviewed, by appointment
only, at EPA Region I, in Boston, Massachusens.

Aquatec Inc.
1.
Analysis of Water Samples, Aquatec Inc. for Balsam Environmental
Consultants, Inc. (October 13, 1989) with attached Balsam Environmental
Consultants, Inc. "Chain-of-Custody Records."
Analysis of Water Samples, Aquatec Inc. for Balsam Environmental
Consultants, Inc. (October 20, 1989) with attached Balsam Environmental
Consultants, Inc. "Chain-of-Custody Record."
Analysis of Water Samples, Aquatec Inc. for Balsam Environmental
Consultants, Inc. (October 23, 1989) with attached Balsam Environmental
Consultants, Inc. "Chain-of-Custody Record."
Analysis of Water Samples by Gas ChromatographylMass Spectrometry,
Aquatec Inc. for Balsam Environmental Consultants, Inc. (January 4, 1990)
with attached Balsam Environmental Consultants, Inc. "Chain-of-Custody
Records."
2.
3.
4.
-
.
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Page 21
3.2
Sampling and Analysis Data (cont'd.)
Balsam Environmental Consultants, Inc.
"
. 5. Letter from Timothy S. Stone and Leonard C. Sarapas, Balsam Environmental
Consultants, Inc. for KJ. Quinn & Company, Inc. to Roger Duwart, EPA
Region I (June 8, 1989). Concerning transmittal of attached:
A. Memorandum from Stefan C. Sokol and Thomas P. Woodard, Balsam
Environmental Consultants, Inc. for KJ. Quinn & Company, Inc. to File
(June 7, 1989). Concerning attached validation of Phase I soil borings
organic compound analyses. .
B. Memorandum from Stefan C. Sokol and Thomas P. Woodard, Balsam
Environmental Consultants, Inc. for K.J. Quinn & Company, Inc. to File
(June 8, 1989). Concerning attached validation of Phase I soil borings
inorganics analyses.
C. Memorandum from Stefan C. Sokol and Thomas P. Woodard, Balsam
Environmental Consultants, Inc. for KJ. Quinn & Company, Inc. to File
(June 8, 1989). Concerning attached validation of Phase II soil borings
organic compound analyses.
D. Memorandum from Stefan C. Sokol and Thomas P. Woodard, Balsam
Environmental Consultants, Inc. for KJ. Quinn & Company, Inc. to File
(June 2, 1989). Concerning attached validation of Phase II soil borings
lead analyses.
6. Letter from Stefan C. Sokol and Timothy S. Stone, Balsam Environmental
Consultants, Inc. for KJ. Quinn & Company, Inc. to Roger Duwart, EPA
Region I (June 30, 1989). Concerning transmittal of attached lead analytical
validation tables for Phase II soil borings.
7. "Draft - Phase I Ground Water Data Summary," Balsam Environmental
Consultants, Inc. for KJ. Quinn & Company, Inc. (August 1989) with
attached:
A. "Site Area Monitoring Well & Stream Elevation Locations," Balsam
Environmental Consultants, Inc. for KJ. Quinn & Company, Inc.
(August 18, 1989).
B. "Off-Site Monitoring Well Locations," Balsam Environmental Consultants,
Inc. for KJ. Quinn & Company, Inc. (August 18, 1989).
C. "Surface Water/Sediment Sampling & Stream Gauging Locations," Balsam
Environmental Consultants, Inc. for KJ. Quinn & Company, Inc.
(August 18, 1989).
D. "Overburden Ground Water Contour Map Site Area," Balsam Environmental
Consultants, Inc. for KJ. Quinn & Company, Inc. (August 18, 1989).
E. "Bedrock Ground Water Contour Map Site Area," Balsam Environmental
Consultants, Inc. for KJ. Quinn & Company, Inc. (August 18, 1989).
F. "Bedrock Contour Map," Balsam Environmental Consultants, Inc. for
KJ. Quinn & Company, Inc. (August 18, 1989). .
8. Memorandum from Stefan C. Sokol, Balsam Environmental Consultants, Inc.
for KJ. Quinn & Company, Inc. to File (November 15, 1989). Concerning
attached Phase I ground water, surface water, and sediment sampling data
validation of pesticide/PCB organic compound analyses.
9. Memorandum from Stefan C. Sokol and Brian T. Quinlan, Balsam
Environmental Consultants, Inc. for K.J. Quinn & Company, Inc. to File
(November 16, 1989). Concerning attached Phase I ground water, surface
water, and sediment sampling data validation of volatile organic compound
analyses.
10. Memorandum from Stefan C. Sokol and Mindi F. Jacobs, Balsam
. Environmental Consultants, Inc. for K.J. Quinn & Company, Inc. to File
(November 21, 1989). Concerning attached Phase I ground water, surface
water, and sediment sampling data validation of inorganics analyses.
..
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Page 22
;
3.2
Sampling and Analysis Data (cont'd.)
...' Balsam Environmental Consultants, Inc. (cont'd.)

11. Memorandum from Stefan C. Sokol, Balsam Environmental Consultants, Inc.
for K.J. Quinn & Company, Inc. to File (November 30, 1989). Concerning
attached Phase I ground water, surface water, and sediment sampling data
validation of semivolatile organic compound analyses.
12. Letter from Timothy S. Stone and Leonard C. Sarapas, Balsam Environmental
Consultants, Inc. for K.J. Quinn & Company, Inc. to Roger Duwart, EPA
Region I (December 4, 1989) with attached "Phase I and Phase IT Ground Data
Summary." Concerning recommendations for the third round sampling program
analytical suite.
13. Memorandum from Mindi F. Jacobs, Balsam Environmental Consultants, Inc.
for K.J. Quinn & Company, Inc. to File (February 12, 1990). Concerning
attached Phase IT ground water sampling data validation of inorganic analyses.
14. Memorandum from Brian T. Quinlan, Balsam Environmental Consultants, Inc.
for K.J. Quinn & Company, Inc. to File (February 14, 1990). Concerning
attached Phase IT ground water and surface water sampling data validation of
volatile organic compound analyses, semivolatile organic compound analyses,
and pesticide/PCB analyses.
15. "Groundwater Data Summary," Balsam Environmental Consultants, Inc. for
K.J. Quinn & Company, Inc. (revised February 23, 1990).
16. Memorandum from Brian T. Quinlan, Balsam Environmental Consultants, Inc.
for K.J. Quinn & Company, Inc. to File (MaJ:Ch 15, 1990). Concerning
attached Phase ITI ground water sampling data validation of inorganics analyses.
17. "Groundwater Data Summary," Balsam Environmental Consultants, Inc. for
KJ. Quinn & Company, Inc. (revised March 19, 1990).
18. Memorandum from Brian T. Quinlan, Balsam Environmental Consultants, Inc.
for KJ. Quinn & Company, Inc. to File (March 19, 1990). Concerning
attached Phase ill ground water and surface water sampling data validation of
.' volatile organic compound analyses.
Cambridge Analytical Associates

19. Letter from Edward A. Lawler, Cambridge Analytical Associates for Balsam
Environmental Consultants, Inc. to Stefan C. Sokol, Balsam Environmental
Consultants, Inc. for K.J. Quinn & Company, Inc. (December 14, 1988) with
attached Balsam Environmental Consultants, Inc. "Chain-of-Custody Record"
Concerning transmittal of attached volatiles and ABN data packages for soil
samples collected November 1988.
20. Letter from Edward A Lawler, Cambridge Analytical Associates for Balsam
Environmental Consultants, Inc. to Stefan C. Sokol, Balsam Environmental
Consultants, Inc. for K.J. Quinn & Company, Inc. (December 20, 1988).
Concerning transmittal of attached pesticide/PCB and inorganics data packages
for soil samples collected November 1988.
.
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Page 23
3.2
Sampling and Analysis Data (cont'd.)
Cambridge Analytical Associates (cont'd.)
."
:-. 21. Letter from Edward A Lawler. Cambridge Analytical Associates for Balsam
Environmental Consultants. Inc. to Stefan C. Sokol, Balsam Environmental
Consultants, Inc. for K.J. Quinn & Company, Inc. (December 28, 1988).
Concerning transmittal of attached data sheets for the methyl+butyl (MTBE) and
tetrahydrofuran (TIiF) searches performed on soil samples collected
November 1988.
22. Letter from Edward A Lawler. Cambridge Analytical Associates for Balsam
Environmental Consultants, Inc. to Stefan C. Sokol, Balsam Environmental
Consultants, Inc. for KJ. Quinn & Company. Inc. (February 8, 1989) with
attached Balsam Environmental Consultants. Inc. "Chain-of-Custody Records."
Concerning transmittal of attached CLP data packages for samples collected
December 1988 through January 1989.

CDM Federal Programs Corporation
23. Letter from Michael Kulbersh. CDM Federal Programs Corporation to Timothy
S. Stone, Balsam Environmental Consultants, Inc. for KJ. Quinn & Company,
Inc. (January 16, 1989). Concerning Phase I ground water, surface water, and
sediment sampling collection and analysis for semi-volatiles, pesticides/PCBs,
metals, cyanide, and volatile organics.
24. Letter from Michael Kulbersh, CDM Federal Programs Corporation to Roger
Duwart, EP A Region I (April 6, 1989). Concerning collection of split samples
for Phase I ground water, surface water. and sediment sampling.
25. Letter from Karen Stone, CDM Federal Programs Corporation to Rose Harvell,
EP A Headquarters (April 13, 1989). Concerning transmittal of attached
April 13, 1989 "Data Validation Letter Report for Inorganic Case 11170," CDM
Federal Programs Corporation.
26. Letter from Karen Stone, CDM Federal Programs Corporation to Rose Harvell,
EP A Headquarters (May 31. 1989). Concerning transmittal of attached
May 31. 1989 "Data Validation Letter Report for Organics SAS Ca~~ #4372A,"
CDM Federal Programs Corporation.
27. "Data Validation Letter Report for Inorganic Case 11766," CDM Federal
Programs Corporation (August 30, 1989).
28. "Data Validation Letter Report for Organic Case SAS4570A," CDM Federal
Programs Corporation (September 20. 1989) with attached September 1989
"Sampling Plan."
29. "Data Validation Letter Report for Organic Case 11766," CDM Federal
Programs Corporation (November 3, 1989).
30. Letter from John Walker, CDM Federal Programs Corporation to Jack Jojokian,
EP A Headquarters (December 27, 1989). Concerning transmittal of attached
December 27, 1989 "Data Validation Letter Report for Organic Case 12791,"
CDM Federal Programs Corporation.
31. Letter from John Walker, CDM Federal Programs Corporation to Jack Jojokian,
EP A Headquarters (February 22, 1990). Concerning transmittal of attached
February 22, 1989 "Data Validation Letter Report for Inorganic Case 12791,
SDG MAL540," CDM Federal Programs Corporation.
32. Letter from John Walker. CDM Federal Programs Corporation to Jack Jojokian,
EP A Headquarters (March 2, 1990). Concerning transmittal of attached
March 2, 1990 "Data Validation Letter Report for Inorganic Case 13312, SDG
MAMI01," CDM Federal Programs Corporation.
-
.
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3.4
Page 24
3.2
Sampling and Analysis Data (cont'd.)
. CDM Federal Programs Corporation (cont'd)
.r
33. Letter from John Walker, CDM Federal Programs Corporation to Jack Jojokian,
EP A Headquarters (March 6, 1990). Concerning transmittal of attached
March 6, 1990 "Data Validation Letter Report for Organic Case 12791, SDG
AQ421,"CDM Federal Programs Corporation.
34. Letter from John Walker, CDM Federal Programs Corporation to Jack Jojokian,
EPA Headquarters (March 6,1990). Concerning transmittal of attached
March 6, 1990 "Data Validation Letter Report for Organic Case 13312, SDG
AQ4141," CDM Federal Programs Corporation. .

Enseco Incorporated
35. Letter from Hilton Rivera, Enseco Incorporated for Balsam Environmental
Consultants, Inc. to Stefan C. Sokol, Balsam Environmental Consultants, Inc.
for K.l Quinn & Company, Inc. (November 17, 1989). Concerning transmittal
of attached water sample analyses and corresponding Balsam Environmental
Consultants, Inc. "Chain-of-Custody Record."
36. Letter from Hilton Rivera, Enseco Incorporated for Balsam Environmental
Consultants, Inc. to Stefan C. Sokol, Balsam Environmental Consultants, Inc.
for K.J. Quinn & Company, Inc. (December 29,1989). Concerning transmittal
of attached water sample analyses and corresponding Balsam Environmental
Consultants, Inc. "Chain-of-Custody Record."

Lapuck Laboratories, Inc.
37. Letter from lL. Lapuck, Lapuck Laboratories, Inc. for Enseco Incorporated to
Hilton Rivera, Enseco Incorporated for Balsam Environmental Consultants, Inc.
(October 16, 1989). Concerning transmittal of attached water sample analyses.

New Hampshire, State of
38. "Residential Well Sampling Standard Operating Procedure," State of New
Hampshire Department of Environmental Services (February 22, 1989).
39. Letter from Michael J. Robinette, State of New Hampshire Department of
Environmental Services to Timothy S. Stone, Balsam Environmental
Consultants, Inc. for K.J. Quinn & Company, Inc. (November 3, 1989).
Concerning transmittal of attached second round domestic well sampling
analysis.
40. Letter from Michael 1. Robinette, State of New Hampshire Department of
Environmental Services to Timothy S. Stone, Balsam Environmental
Consultants, Inc. for K.J. Quinn & Company, Inc. (January 19, 1990).
Concerning transmittal of attached third round domestic well sampling analysis
and corresponding Chains-of-Custody Records.

Interim Deliverables
1.
"Volume I ofll - Project Operations Plan - Remedial InvestigationlFeasibility
Study," Balsam Environmental Consultants, Inc. for KJ. Quinn & Company,
Inc. (October 4, 1988).
"Volume n of n - Project Operations Plan - Remedial InvestigationIFeasibility
Study," Balsam Environmental Consultants, Inc. for KJ. Quinn & Company,
Inc. (October 4, 1988)
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"
Page 25
3.4
Interim Delivcrab1es (com'd.)
3.6
Letter from Timothy S. Stone and Jo1m A. Gilbert, Balsam Environmental
Consultants, Inc. for K.J. Quinn & Company, Inc. to Roger Duwart, EPA
Region I (April 7, 1989). Concerning proposed modification of deep bedrock
well purging protocol.
Letter Report from Pei-Fung Hurst, EPA Region I to Roger F. Duwart, EPA
Region I (May 3, 1990). Concerning RID computations and an assessment of
the toxicity of tetrahydrofuran (1HF) for the site based on a study by Katahira.

Remedial Investigation (RI) Reports
3.
4.
1.
"Volume I ofvm - Remedial Investigation Report - Sections 1 through 7,"
Balsam Environmental Consultants, Inc. for KJ. Quinn & Company, Inc.
(September 28, 1990).
"Volume n of VITI - Remedial Investigation Report - Tables and Figures,"
Balsam Environmental Consultants, Inc. for KJ. Quinn & Company, Inc.
(September 28, 1990).
2.
The maps associaled with the record cited in entry number 3 ore oversized and may be
reviewed, by appointment only, at EPA Region I, Boston, Massachusetts.
3.7
"Volume ill of vm - Remedial Investigation Report - Appendix A-I," Balsam
Environmental Consultants, Inc. for KJ. Quinn & Company, Inc.
(September 28, 1990).
"Volume IV of vm - Remedial Investigation Report - Appendices B-1
through B-2," Balsam Environmental Consultants, Inc. for KJ. Quinn &
Company, Inc. (September 28, 1990).
"Volume V ofVIll - Remedial Investigation Report - Appendices B-3
through B-7," Balsam Environmental Consultants, Inc. for KJ. Quinn &
Company, Inc. (September 28, 1990).
"Volume VI of VIII- Remedial Investigation Report - Appendices C-l
through C-4," Balsam Environmental Consultants, Inc. for KJ. Quinn &
Company, Inc. (September 28, 1990).
"Volume Vll of VIII - Remedial Investigation Report - Appendices C-5
through C-7," Balsam Environmental Consultants, Inc. for K.J. Quinn &
Company, Inc. (September 28, 1990).
"Volume VIll of VIll -Remedial Investigation Report - Appendix C-8," Balsam
Environmental Consultants, Inc. for KJ. Quinn & Company, Inc.
(September 28, 1990).
Letter from Leonard C. Sarapas, Balsam Environmental Consultants, Inc. for
KJ. Quinn & Company, Inc. to Roger Duwart, EPA Region I
(September 28, 1990). Concerning transmittal of the attached responses to the
Agency's comments on the Draft "Remedial Investigation Report."

Work Plans and Progress Reports
3.
4,
5.
6.
"
7.
8.
9.
1.
Cross-Reference: "Work Plan - Remedial InvestigationIFeasibility Study,"
Balsam Environmental Consultants, Inc. for KJ. Quinn & Company, Inc.
(May 20, 1988) [Filed and included as Appendix I in entry number 1 in 10.7
EPA Administrative Orders].
Progress Report, Balsam Environmental Consultants, Inc. for KJ. Quinn &
Company, Inc. (July 7, 1988).
Progress Report, Balsam Environmental Consultants, Inc. for KJ. Quinn &
Company, Inc. (July 30, 1988).
Progress Report, Balsam Environmental Consultants, Inc. for KJ. Quinn &
Company, Inc. (September 8, 1988).
2.
3.
4.
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Page 26
3.7
Work Plans and Progress Reports (cont'd.)
..." S. ''Draft - Proposed Monitoring Well Locations," Balsam Environmental
Consultants, Inc. for K.J. Quinn & Company, Inc. (October 4, 1988) with
attached "Remedial InvestigationlFeasibility Study Approach" and "DQO
Process. "
6. Progress Report, Balsam Environmental Consultants, Inc. for K.J. Quinn &
Company, Inc. (October 14, 1988). .
7. Progress Report, Balsam Environmental Consultants, Inc. for KJ. Quinn &
Company, Inc. (November 18,1988).
8. Progress Report, Balsam Environmental Consultants, Inc. for KJ. Quinn &
Company, Inc. (December 21, 1988).
9. Progress Report, Balsam Environmental Consultants, Inc. for KJ. Quinn &
Company, Inc. (January 17, 1989).
10. "Proposed Domestic Well Sampling Program," Balsam Environmental
Consultants, Inc. for KJ. Quinn & Company, Inc. (January 1989).
11. Progress Report, Balsam Environmental Consultants, Inc. for KJ. Quinn &
Company, Inc. (February 16, 1989) with attached schedules of activities and
deliverables.
12. Progress Report, Balsam Environmental Consultants, Inc. for K.J. Quinn &
Company, Inc. (March 16, 1989).
13. Progress Report, Balsam Environmental Consultants, Inc. for KJ. Quinn &
Company, Inc. (April 17, 1989).
14. Progress Report, Balsam Environmental Consultants, Inc. for KJ. Quinn &
Company, Inc. (May 17, 1989).
15. Progress Report, Balsam Environmental Consultants, Inc. for K.J. Quinn &
Company, Inc. (June 22, 1989).
16. Progress Report, Balsam Environmental Consultants, Inc. for K.J. Quinn &
Company, Inc. (July 24, 1989).
17. Progress Report, Balsam Environmental Consultants, Inc. for K.J. Quinn &
. Company, Inc. (August 17,1989).
18. Letter from Timothy S. Stone and Leonard C. Sarapas, Balsam Environmental
Consultants, Inc. for K.J. Quinn & Company, Inc. to Roger Duwart, EPA
Region I (September 11, 1989). Concerning proposed one day refraction
survey, one-day boring program, and installation of two additional monitoring
wells.
19. Progress Report, Balsam Environmental Consultants, Inc. for K.J. Quinn &
Company, Inc. (September 12, 1989).
20. Letter from Timothy S. Stone and Leonard C. Sarapas, Balsam Environmental
Consultants, Inc. for KJ. Quinn & Company, Inc. to Roger Duwart, EPA
Region I (September 15, 1989). Concerning recommendations for the second
round sampling program analytical suite.
21. Letter from Timothy S. Stone and Leonard C. Sarapas Balsam Environmental
Consultants, Inc. for KJ. Quinn & Company, Inc. to Roger Duwart, EPA
Region I (September 25, 1989). Concerning responses to questions related to
the recommendations for the second round sampling program analytical suite.
22. Trip Report on a Visit to Mottolo Site, Roger Duwart and Steve Mangion, EP A
Region I and Michael Kulbersh and Bill Holden, CDM Federal Programs
Corporation (October 10, 1989). Concerning technical oversight of the second
round of ground water and surface water sampling and well installation
program.
23. Progress Report, Balsam Environmental Consultants, Inc. for KJ. Quinn &
Company, Inc. (November 17, 1989).
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c,
3.7
3.9
Page 27
Work Plans and Progress Reports (cont'd.)

24. Trip Report on a Visit to Mottolo Site, Michael Kulbersh and Mary Pothier,
CDM Federal Programs Corporation and Kim Margolies, State of New
Hampshire Department of Environmental Services (December 20, 1989).
Concerning technical oversight activities of the second round of ground water
and surface water sampling.
25. Progress Report, Balsam Environmental Consultants, Inc. for K.J. Quinn &
Company, Inc. (December 28, 1989).
26. Progress Report, Balsam Environmental Consultants, Inc. for K.J. Quinn &
Company (February 27, 1990). '
27. Progress Report, Balsam Environmental Consultants, Inc. for K.J. Quinn &
Company, Inc. (June 12, 1990).
28. Progress Report, Balsam Environmental Consultants, Inc. for K.J. Quinn &
Company, Inc. (August 1, 1990).
29. Progress Report, Balsam Environmental Consultants, Inc. for K.J. Quinn &
Company, Inc. (March 5, 1991).
Health Assessments
"Preliminary - Health Assessment for Mottolo Hazardous Waste Site," U.S.
Department of Health and Human Services Agency for Toxic Substances and
Disease Registry (A TSDR) (April 12, 1989).

Feasibility Study (FS)
4.0
4.1
1.
Correspondence
1.
Letter from Roger F. Duwart, EP A Region I to John E. Peltonen, Stark &
Peltonen (Attorney for KJ. Quinn & Company, Inc.) (November 30, 1990).
Concerning a restatement of EP A's position regarding the setting of soil cleanup
level at the site.
4.2
Sampling and Analysis Data
The records cited in entry numbers 1 through 4 may be reviewed, by appoinonent
only, at EPA Region I, in Boston, Massachusens. .
Balsam Environmental Consultants, Inc.
1.
Letter from John A. Gilbert and Leonard C. Sarapas, Balsam Environmental
Consultants, Inc. for KJ. Quinn & Company, Inc. to Roger Duwan, EPA
Region I (February 20, 1990). Concerning attached soil leaching study
protocol.
Letter from Roger Duwart, EP A Region I to John A. Gilbert, Balsam
Environmental Consultants, Inc. for KJ. Quinn & Company, Inc.
(March 19, 1990). Concerning ~tt~!('}1ed commf"Trt~ on the soil leaching study
protocol.
Letter from John A. Gilbert and Leonard C. Sarapas, Balsam Environmental
Consultants, Inc. for K.J. Quinn & Company, Inc. to Roger Duwart, EPA
Region I (May 1, 1990). Concerning Tevised soilleacbing study protocol.
Letter from John A. Gilbert and Leonard C. Sarapas, Balsam Environmental
Consultants, Inc. for KJ. Quinn & Company, Inc. to Roger Duwan, EPA
Region I (June 15, 1990) with attached analytical reports. Concerning
responses to comments on the revised soil leaching study protocol.
2.
3.
4.
-
.
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4.6
Page 28
.'
Feasibility Study (FS) Repons
Repons
1.
2.
3.
4.
S.
6.
"Draft - Volume I of n - Feasibility Study Repon - Scctions 1 through S,"
Balsam Environmental Consultants, Inc. for K.J. Quinn & Company, Inc.
(September 28, 1990).
"Draft - Volume II ofn - Feasibility Study Repon - Appendices," Balsam
Environmental Consultants, Inc. for K.J. Quinn & Company, Inc.
(September 28, 1990).
"Draft - Volume I of n - Feasibility Study Repon - Sections 1 through S,"
Balsam Environmental Consultants, Inc. for KJ. Quinn & Company, Inc.
(December 10, 1990).
"Draft - Volume n of n - Feasibility Study Repon - Appendices," Balsam
Environmental Consultants, Inc. for K.J. Quinn & Company, Inc.
(December 10, 1990).
"Final- Volume I of n - Feasibility Study Repon - Sections 1 through S,"
Balsam Environmental Consultants, Inc. for KJ. Quinn & Company, Inc.
(February 1, 1991).
"Final- Volume n ofn - Feasibility Study Report - Appendices," Balsam
Environmental Consultants, Inc. for KJ. Quinn & Company, Inc.
(February 1, 1991).
(,
Comments
Comments Dated November 7, 1990 from Roger F. Duwan, EP A Region I on
the September 28, 1990 "Draft - Feasibility Study Report," Balsam
Environmental Consultants, Inc. for K.J. Quinn & Company, Inc.
Comments Dated December 24, 1990 from Roger F. Duwan, EP A Region I on
the December 10, 1990 "Draft - Feasibility Study Repon," Balsam
Environmental Consultants, Inc. for KJ. Quinn & Company, Inc.

Response to Comments
7.
8.
9.
Response Dated December 13, 1990 from John A. Gilben and Leonard C.
Sarapas, Balsam Environmental Consultants, Inc. for K.J. Quinn & Company,
Inc. on the November 7, 1990 Comments from Roger F. Duwan, EPA
Region I.

4.7 Work Plans and Progress Repons
4.9
Cross-Reference: "Work Plan - Remedial InvestigationIFeasibility Study,"
Balsam Environmental Consultants, Inc. for K.J. Quinn & Company, Inc.
(May 20, 1988) [Filed and included as Appendix I in entry number 1 in 10.7
EPA Administrative Orders].

Proposed Plans for Selected Remedial Action
1.
1.
"EPA Proposes Cleanup Plan for the Mottolo Site," EPA Region I
(January 1991). Concerning site history, results of the remedial investigation,
summary of the site risks, EPA's preferred alternatives, other alternatives
evaluated in the Feasibility Study, and EPA's rationale for proposing the
preferred alternative.
.
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Page 29
5.0
Record of Dedsion (ROD)
Responsiveness Summary
5.3
.,
/ 1.
"
5.4
10.0 ~orcenlent
Cross-Reference: Responsiveness Summary is Appendix D of the Record of
Decision [Filed and cited as entry nUnlber 1 in 5.4 Record of Decision (ROD)].
The following citalions indicate wrinen comments received by EP A Region I during
the formal public comment period.
Conunents Dated February 18, 1991 fronl Melvil B. Clauson on the "EPA
Proposes Cleanup Plan for the Mottolo Site," EPA Region I.
Conunents Dated March 15, 1991 fronl Mark Gearrea1d, Engel & Gearrea1d
(Attorney for Richard A. Mottolo) on the "EP A Proposes Cleanup Plan for the
Mottolo Site," EP A Region I.
Conunents Dated March 15, 1991 frOnl John E. Peltonen, Stark & Peltonen
(Attorney for KJ. Quinn & COnlpany, Inc.) concerning conunents to be
provided by Balsam Environnlental Consultants, Inc.
Conunents Dated March 15, 1991 from John A. Gilbert and Leonard C.
Sarapas, Balsam Environnlental Consultants, Inc. concerning conditions m the
southern portion of the site referred to m the Remedial Investigation and
Feasibility Study as the southern boundary area (SBA).

Record of Decision (ROD)
2.
3.
4.
5.
1.
Record of Decision, EPA Region I (March 29, 1991).
10.7 EPA Administrative Orders
Administrative Order, In the matter of KJ. Quinn & Co., Inc., Docket No.
1-88-1027 (May 20, 1988).

11.0 Potentially Responsible Party (PRP)
1.
11.9 PRP-Specific Correspondence
KJ. Quinn & Company, Inc.
1.
Letter from Rita M. Lavelle, EPA Headquarters to KJ. Quinn & Company, Inc.
(February 3, 1983). Concernmg notification of potcntialliability and denland
for payment of response costs mcurred by EP A.
Letter from Merrill S. Hohman, EP A Region I to Rodney L. Stark, Stark &
Peltonen (Attorney for KJ. Quinn & Company, Inc.) (July 29, 1987).
Concerning the opportunity for KJ. Quinn & Company, Inc. to perform the
Remedial InvestigationIFeasibility Study.
Letter from Merrill S. Hohman, EPA Region I to Rodney L. Stark, Stark &
Peltonen (Attorney for KJ. Quinn & Company, Inc.) (December 29, 1987).
Concerning formal demand for payment of removal costs and special notice of a
period of negotiations to perform the Remedial InvestigationlFeasibility Study.
2.
3.
,
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Page 30
11.9 PRP-Specific Correspondence (cont'd.)
" Lewis Chemical Corporation
4.
Letter from Rita M Lavelle, EP A Headquarters to Lewis Chemical Corporation
(February 3, 1983). Concerning notification of potential liability and demand
for payment of response costs incurred by EP A.
Letter from Merrill S. Hohman, EP A Region I to Claudia C. Damon, Sheehan,
Phinney, Bass & Green (Attorney for Lewis Chemical Corporation)
(July 29, 1987). Concerning the opportunity for Lewis Chemical Corporation to
perform the RemediallnvestigationlFeasibility Study.
Letter from Menill S. Hohman, EP A Region I to Claudia C. Damon, Sheehan,
Phinney, Bass & Green (Attorney for Lewis Chemical Corporation)
(December 31,1987). Concerning EPA's decision not to send Lewis Chemical
Corporation a special notice letter.

Richard A. Mottolo
5.
6.
Letter from Rita M. Lavelle, EP A Headquarters to Richard A. Mottolo
(February 3, 1983). Concerning notification of potential liability and demand
for payment of response costs incurred by EP A.
Letter from Merrill S. Hohman, EP A Region I to Richard A. Mottolo, Service
Pumping & Drain Company, Inc. c/o Lynn D. Morse, Engel and Morse
(Attorney for Richard A. Mottolo) (July 29, 1987). Concerning the opportunity
for Richard A. Mottolo to perform the RemediallnvestigationIFeasibility Study.
Letter from Merrill S. Hohman, EP A Region I to Richard A. Mottolo, Service
Pumping & Drain Company, Inc. c/o Mark Gearreald, Engel & Gearreald
(Attorney for Richard A. Mottolo) (December 31, 1987). Concerning EPA's
decision not to send Richard A. Mottolo a special notice letter.

Service Pumping & Drain Company, Inc.
7.
8.
9.
i'o. Letter from Rita M. Lavelle, EP A Headquarters to Service Pumping & Drain
Company, Inc. (February 3, 1983). Concerning notification of potential liability
and demand for payment of response costs incurred by EPA.
11. Letter from Merrill S. Hohman, EP A Region I to Lynn D. Morse, Engel and
Morse (Attorney for Service Pumping & Drain Company, Inc.) (July 29, 1987).
Concerning the opportunity for Service Pumping & Drain Company, Inc. to
perform the RemediallnvestigationlFeasibility Study.
12. Letter from Merrill S. Hohman, EPA Region I to Mark Gearreald, Engel &
Gearreald (Attorney for Service Pumping & Drain Company,lnc.)
{December 31, 1987). Concerning EPA's decision not to send Service
Pumping & Drain Company, Inc. a special notice letter.

Carl Sutera
13. Letter from Rita M. Lavelle, EPA Headquarters to Carl Sutera, Lewis Chemical
Corporation (February 3, 1983). Concerning notification of potential liability
and demand for payment of response costs incurred by EPA.
14. Letter from Menill S. Hohman, EPA Region I to Carl Sutera, Lewis Chemical
Corporation (July 29, 1987). Concerning the opportunity for Lewis Chemical
Corporation to perform the RemediallnvestigationlFeasibility Study.
15. Letter from Merrill S. Hohman, EP A Region I to Carl Sutera, Lewis Chemical
Corporation (December 31, 1987). Concerning EP A 's decision not to send Carl
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Page 31
13.0 Community Relations
13.2 Community Relations Plans
IJ
"Final Report - Community Relations Plan," Booz Allen & Hamilton, Inc. for
CDM Federal Programs Corporation (October 4, 1988).

13.3 News ClippingslPress Releases
()
1.
News Clippings

1. "More Hazardous Waste in Dumps?' Manchester Union Leader - Manchester,
NH (May 19, 1979).
2. "Beginning the Chemical Cleanup," The Boston Globe - Boston, MA
(June 8, 1979).
3. "Raymond Chemical Dump Hearing Delay Asked," Manchester Union Leader -
Manchester, NH (June 12, 1979).
4. "List of Chemicals Promised: Agreement Reached on Raymond Dump,"
Manchester Union Leader - Manchester, NH (June 13, 1979).
5. "3 Wells Drilled to Check Raymond Chemical Dump," Manchester Union
Leader - Manchester, NH (July 19, 1979).
6. "State Asks Toxic Removal," Foster's Daily Democrat - Dover, NH
(October 15, 1979).
7. "Judge Authorizes Dump Cleanup," Manchester Union Leader - Manchester,
NH (October 19, 1979).
8. "Dump Ruled Hazardous," Exeter Newsletter - Exeter, NH (October 24, 1979).
9. "Dump Ruled Hazardous," The Raymond Times. Exeter, NH
(October 24, 1979).
10. "Gallen Tabs Task Force on Dumps," Manchester Union Leader - Manchester,
NH (May 6, 1980).
11. "Ground Water Sampled at Illegal Dump Site," Derry News - Derry, NH
(August 7, 1980).
1'2. "Officials Begin Removing Chemical Barrels in Raymond," Manchester Union
Leader - Manchester, NH (September 11, 1980).
13. "Cleanup Starts at Raymond Hazardous Waste Dump," Manchester Union
Leader - Manchester, NH (September 16, 1980).
14. "Cleanup Underway at Hazardous Waste Site," Derry News - Derry, NH
(September 18, 1980).
15. "Crews Begin Removing Barrels of Toxic Wastes from N.H. Dump," Evening
Bulletin - Providence, RI (September 19, 1980).
16. "No Surprises at Illegal Blueberry Hill Dump," The Raymond Times - Exeter,
NH (October 8, 1980).
17. "Paint Lacquer Found on Blueberry Hill," Manchester Union Leader -
Manchester, NH (October 17, 1980).
18. "EP A Looks for Disposal Site," The Raymond Times. Exeter, NH
(December 17, 1980).
19. "EPA Finishes Cleanup of Dlegal Waste Dump, Seeks Disposal Site for 1600
Barrels," Derry News - Derry, NH (December 24, 1980).
20. "Funds Gone - Barrels Stay," Pawtuckaway Post - Plaistow, NH
(March 4, 1981).
21. "Blueberry Hill Report Released for Inspection," Foster's Daily Democrat -
Dover, NH (May 22, 1981).
22. "EPA to Air Cleanup Plans for Mottolo Site," The Raymond Times - Exeter, NH
(May 27, 1981).
23. "EPA Asks $500,000 for Blueberry Hill Cleanup," Manchester Union Leader-
Manchester, NH (July 28, 1981).
:
.
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Page 32
.
13.3 News ClippingslPress Releases (cont'd.)
News Clippings (cont'd.)
24. "'Superfund' Tapped for Third Dump," Manchester Union Leader - Manchester,
NH (October 15, 1981).
25. "Superfund," Granite State News - Wolfeboro, NH (October 21, 1981).
26. "'Superfund' To Be Used To Cleanup Dump Site," The Raymond Times -
Exeter, NH (October 21, 1981).
27. "Toxic Waste Site to Receive $500,000 from Superfund," Derry News - Derry,
NH (October 22, 1981).
28. "Blueberry Hill Cleanup Should Begin Next Month," The Raymond Times -
Exeter, NH (November 18, 1981).
29. "EP A Begins Cleanup of Blueberry Hill Site," The Raymond Times - Exeter,
NH (December 2, 1981).
30. "DPHS Completes Risk Assessment," Portsmouth Herald - Portsmouth, NH
(June 22, 1987).
31. "Contaminated Landfill Surprises Town Officials," Portsmouth Herald -
Portsmouth, NH (July 22, 1987).
32. "Testing Underway to Discover if Drinking Water is Polluted," Exeter
Newsletter - Exeter, NH (July 24, 1987).
33. "Raymond Farm Superfund Site," Exeter Newsletter - Exeter, NH
(July 24, 1987).
34. "Exeter River Screened for Contaminants," Foster's Daily Democrat - Dover,
NH (July 28, 1987).
35. "Mining Plan Near Waste Site Concerns Raymond," Union Leader -
Manchester, NH (March 16, 1988).
36. "Mottolo Site Subject of Order," The Raymond Times - Exeter, NH
(June 22, 1988).
37. "Raymond's Hazwaste Site Revisited," The Raymond Times - Exeter, NH
(June 29, 1988).
38. "No Answers on Spread of Pollutants," The Raymond Times - Exeter, NH
. (July 6, 1988).
39. "Cleanup Not Always Practical," The Raymond Times - Exeter, NH
(July 13, 1988).
40. "EP A to Sponsor Info Meeting on Mottolo Hazwaste Status," The Raymond
Times - Exeter, NH (August 31, 1988).
41. "Raymond Residents Briefed on Toxic Dump Cleanup," Foster's Daily
Democrat - Dover, NH (September 9, 1988).
42. "Study of Hazwaste Site Begins: EPA Probe to Map Contamination at Fonner
Raymond Pig Farm," The Raymond Times - Exeter, NH (September 13, 1988).
43. "EPA Begins Mottolo Site Study to Determine Hazwaste Spread," The Raymond
Times - Exeter, NH (September 14, 1988).

Press Releases
44. Press Release, State of New Hampshire Office of Governor
(December 17,1981). Concerning Governor Hugh Gallen's praise ofEPA
cleanup efforts.
45. "Environmental News - EPA Announces Consent Order at Mottolo Superfund
Site," EPA Region I (June 14, 1988).
46. "Environmental News - Public Meeting to Explain Remedial Investigation!
Feasibility Study Process at Mottolo Superfund Site," EP A Region I
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Page 33
.
13.4 fublic Meetings
"Final Report - Public Information Meeting Summary," Booz Allen & Hamilton,
Inc. for CDM Federal Programs Corporation (December I, 1988).
"Summary of the Public Informational Meeting on the Remedial Investigation at
the Mottolo Superfund Site," EPA Region I (October 25, 1990). Concerning the
remedial action options, contUnination outside of the site property, and other
issues of discussion.
"Summary of the Public Informational Meeting on the Proposed Plan and
Feasibility Study for the Mottolo Superfund Site," EPA Region I
(February 13, 1991). Concerning attendance, presentations, and concerns of the
community .
Transcript, Public Hearing for Proposed Plan for the Mottolo Superfund Site
Oean-up, Apex Reporting (March 6,1991).

13.5 Fact Sheets
l>
o
1.
2.
3.
4.
1.
"Mottolo Hazardous Waste Site," (June 1987). Concerning the state's
involvement at the site including field work, litigation, hydrogeological
investigation, and residential well sampling.
"Mottolo Superfund Site," EP A Region I (August 1988). Concerning site
history and Superfund process background, as well as current clean-up status,
public comment period information, and further opportunities for public
involvement .
"EPA Announces the Results of Remedial Investigation and Risk Assessment
Studies," EP A Region I (October 1990). Concerning site description, site
history, field activities conducted during the Remedial Investigation, results of
the Remedial Investigation, results of the Risk Assessment, and opportunities
for public involvement.
2.
3.
16.0 Natural Resource Trustee
16.1 Correspondence
1.
utter from Gordon E. Beckett, U.S. Department of the Interior Fish and
Wildlife Service to Daniel J. Coughlin, EPA Region I (July 21,1987).
Concerning receipt of "EP A Trustee Notification Form" and interest in future
coordination with EP A in developing and reviewing draft documents and
remedial activities.
Letter from Kenneth Finkelstein, U.S. Department of Commerce National
Oceank and Atmospheric Administration (NOAA) to Roger Duwart, EP A
Region I (September 21, 1987). Concerning thanks for "EP A Trustee
Notification Form," an explanation of NOAA's interest in the Mottolo site, and a
request for the Remedial InvestigationlFeasibility Study upon completion.
2.
17.0 Site Management Records
17.7 Reference Documents
1.
"Declaration for the Explanation of Significant Differences - Keefe
Environmental Services Superfund Site," EPA Region I (June 8, 1990).
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Page 34
17.8 State and Local Technical Records
"
",
1.
"Hydrogeological Investigation of the Mottolo Hazardous Waste Site," State of
New Hampshire Water Supply and Pollution Control Commission
(August 1986).
"Final- Health Risk Assessment," State of New Hampshire Division of Public
Health Services (May 1987).
-------
r,
:0
Section II
Guidance Documents
,"
.'
-------
GUIDANCE DOCUMENTS
EPA guidance documents may be reviewed at EPA Region I. Boston. Massachusetts.
(J
Genera) EPA Guidance Documents
1.
2.
3.
4.
5.
6.
7.
8.
9.
"Protection of Wetlands (Executive Order 11990). Appendix D." Federal Reiister
(Vol. 42). 1977.
U.S. Environmental Protection Agency. Guidance Manual for Minimizini Pollution from
Waste Disposal Sites (EPA/600/2-78/142). August 1978.

U.S. Environmental Protection Agency. Municipal Environmental Research Laboratory.
Biodeif3.dation and TreatabilitY of Specific Poilutants (EPA/600/9-79/034). October 1979.
U.S. Environmental Protection Agency. Muni: Jal Environmental Research Laboratory.
Carbon Adsm:ption Isotherms for Toxic Or~an'cs (EPA/600/8-80/023). April 1. 1980.

U.S. Environmental Protection Agency. Office of Water and Waste Management
Evaluatine Cover Systems for Solid and Hazardous Waste. 1980.
U.S. Environmental Protection Agency. Municipal Environmental Research Laboratory.
Costs of Remedial Response Actions at Uncontrol1ed Hazardous Waste Sites,
April 15, 1981.
U.S. Environmental Protection Agency. Office of Water and Waste Management
Eniineerine Handbook for Hazardous Waste Incineration (SW-889, OSWER Directive
9488.00-5). September 1981.
U.S. Environmental Protection Agency. Office of Solid Waste and Emergency Response.
Evaluatine Cover Systems for Solid and Hazardous Waste (Revised Edition) (SW-867,
OSWER Directive 9476.00-1), September 1982.

U.S. Environmental Protection Agency. Office of Solid Waste and Emergency Response.
Linine of Waste Impoundment and Disposal Facilities (SW-870. OSWER Directive
9480.00-4), March 1983.
10.
U.S. Environmental Protection Agency. Office of Solid Waste and Emergency Response.
Joint C011>s/EP A Guidance (OSWER Directive 9295.2-02). June 24. 1983.

U.S. Environmental Protection Agency. Office of Solid Waste and Emergency Response.
Guidance Manual for Hazardous Waste Incinerator Permits  (EPA SW-966). July 1983.
11.
12.
U.S. Environmental Protection Agency. Municipal Environmental Research Laboratory.
Handbook for Evaluatine Remedial Action Technoloi)' Plans (EPA/60012-83/076),
August 1983.

U.S. Environmental Protection Agency. Office of Emergency and Remedial Response.
CommunitY Relations in Superfund: A Handbook (Interim Version) (EPA/HW-6),
September 1983.
13.
14.
U.S. Environmental Protection Agency. Environmental Monitoring Systems Laboratory.
Soil Sampline OualitY Assurance User's Guide (EPA/600/4-84/043). May 1984.

U.S. Environmental Protection Agency. Office of Ground-Water Protection.
Ground-Water Protection Strateey (EPA/440/6-84/002). August 1984.
15.
.
-------
16.
17.
')
18.
19.
20.
21.
22.
23.
24.
25.
26.
27.
28.
29.
Page 36
u.s. Environmental Protection Agency. Office of Research and Development and Office of
Emergency and Remedial Response. Review of In-Place Treatment TechniQues for
Contaminated Surface Soils - Volume 1: Technical Evaluation (EPA/540/2-84/003a),
September 1984.
U.S. Environmental Protection Agency. Environmental Criteria and Assessment Office.
Health Effects Assessment Documents (58 Chemical Profiles) (EPA/540/1-861001-058),
September 1, 1984.

"Guidelines Establishing Test Procedures for the Analysis of Pollutants Under the Oean
Water Act; Final Rule and Interim Final Rule and Proposed Rule," Federal Re~ster
(Vol. 49, No. 209), October 26, 1984.
U.s. Environmental Protection Agency. Hazardous Response Support Division. Standard
Qperatine Safe~ Guides, November 1984.

U.S. Environmental Protection Agency. Office of Solid Waste and Emergency Response.
Field Standard Qperatin~ Procedures Manual #4: Site Entty (OSWER Directive
9285.2-01), January 1, 1985.
U.S. Environmental Protection Agency. Office of Solid Waste and Emergency Response.
Field Standard Qperatine Procedures Manual #8: Air Surveillance (OSWER Directive
9285.2-03), January 1, 1985.
U.S. Environmental Protection Agency. Office of Health and Environmental Assessment.
Develqpment of Statistical Disnibution or Ran~es Standard Factors Used in E'tp05ure
Assessments (EPA OHEA-E-16), March 1985.
U.S. Environmental Protection Agency. Office of Solid Waste and Emergency Response.
Field Standard Qperatin~ Procedures Manual #6: Work Zones (OSWER Directive
9285.2-04), April 1, 1985.
U.S. Environmental Protection Agency. Office of Solid Waste and Emergency Response.
Field Standard Qperatin~ Procedures Manual #9: Site Safety Plan (OSWER Directive
9285.2-05), April 1, 1985.
U.S. Environmental Protection Agency. Office of Emergency and Remedial Response.
Guidance Document for CleanQP of Surface Tank and Drum Sites (OSWER Directive
9380.0-3), May 28, 1985.
U.S. Environmental Protection Agency. Environmental Research Laboratory. EPA Guide
for Minimizin~ the Adverse Environmental Effects of Cleanup of Uncontrolled
Hazardous-Waste Sites (EPA/600/8-85/008), June 1985.

U.S. Environmental Protection Agency. Office of Solid Waste and Emergency Response.
Guidance on Remedial Investi~ations under CERCLA (Comprehensive Environmental
Response. Compensation. and Liabili~ Act) (EP A/540/G-85/002), June 1985.
U.S. Environmental Protection Agency. Office of Solid Waste and Emergency Response.
Guidance on Feasibili~ Studies under CERCLA (Comprehensive Environmental Response.
Compensation. and Liabili~ Act) (EPA/540/G-85/003), June 1985.

U.S. Environmental Protection Agency. Environmental Monitoring Systems Laboratory.
Sediment Sampline Quali~ Assurance User's Guide (EPA/600/4-85/048), July 1985.
.
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30.
31.
32.
33.
34.
35.
36.
37.
38.
Page 37
--
:
U.S. Environmental Protection Agency. Office of Waste Programs Enforcement
Endaniennent Assessment Handbook, August 1985.

Memorandum from William N. Hedeman, Director, U.S. Environmental Protection Agency
Office of Emergency and Remedial Response to Toxic and Waste Management Division
Directors, Regions I-X (OSWER Directive 9280.0-02), August 1, 1985 (discussing policy
on flood plains and wetland assessments for CERCLA Actions).
U.S. Environmental Protection Agency. Office of Waste Programs Enforcement
Toxicolo~ Handbook (OSWER Directive 9850.2), August 1, 1985.

Memorandum from Gene Lucero, U.S. Environmental Protection Agency Office of Waste
Programs Enforcement to Addressees C'Director, Waste Management Division, Regions I,
IV, V, vn, and vm; Director, Emergency and Remedial Response Division, Region n;
Director, Hazardous Waste Management Division, Region ill; Director, Air and Waste
Management Division, Region VI; Director, Toxics and Waste Management Division,
Region IX; Director, Hazardous and Waste Division, Region X"), August 28, 1985
(discussing community relations activities at Superfund Enforcement sites).
U.S. Environmental Protection Agency. Hazardous Waste Engineering Research
Laboratory and Office of Emergency and Remedial Response. Covers for Uncontrolled
Hazardous Waste Sites (EPA 540/2-85/(02), September 1985.

U.S. Environmental Protection Agency. Chemical. Physical. and Bioloiical Properties of
Compounds Present at Hazardous Waste Sites (OSWER Directive 9850.3),
September 27, 1985.
U.S. Department of Health and Human Services. National Institute for Occupational Safety
and Health, and Occupational Safety and Health Administration. Occupational SafetY and
Health Guidance Manual for Hazardous Waste Site Activities, October 1985.
U.S. Environmental Protection Agency. Office of Emergency and Remedial Response.
Handbook of Remedial Action at Waste Disposal Sites (EPA/625/6-85/006), October 1985.

U.S. Environmental Protection Agency. Hazardous Waste Engineering Research
Laboratory. Handbook: Remedial Action at Waste Di~posal Sites (Revised)
(EPA/625/6-85/006), October 1985.
39.
Memorandum from J. Winston Porter, U.S. Environmental Protection Agency Office of
Solid Waste and Emergency Response to Addressees ("Regional Administrators, Regions
I-X; Directors, Environmental Services Division, Regions I-X; Regional Counsels, Regions
I-X, Director, Waste Management Division, Regions I, IV, V, VIT, and VIll; Director,
Emergency and Remedial Response Division, Region ll; Director, Hazardous Waste
Management Division, Region ill; Director, Air and Waste Management Division, Regions
II and VI; Director, Toxics and Waste Management Division, Region IX; Director,
Hazardous and Waste Division, Region X") (OSWER Directive 9850.0-1),
November 22, 1985 (discussing endangerment assessment guidance).

U.S. Environmental Protection Agency. Hazardous Waste Engineering Research
Laboratory. Practical Guide - Trial Burns for Hazardous Waster Incinerators
(EP A/600/2-86/050), April 1986.
40.
41.
U.S. Environmental Protection Agency and Michigan Department of Natural Resources.
Field Screenini for Orianic Contaminants in Samples from Hazardous Waste Sites,
April 2, 1986.
.;
.
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42.
43.
(>
44.
45.
46.
47.
48.
49.
Page 38
U.S. Environmental Protection Agency. Hazardous Waste Engineering Research
Laboratory. Handbook for Stabilization/Solidification of Hazardous Waste
(EPA/540/2-86/001), June 1986.
U.S. Environmental Protection Agency. Office of Emergency and Remedial Response.
Superfund Remedial Desi~ and Remedial Action Guidance (OSWER Directive
9355.0-4A), June 1986.

Memorandum from Barry L. Johnson, Associate Administrator, ATSDR to U.S.
Environmental Protection Agency Regional Superfund Programs, June 16, 1986,
(discussing A TSDR health assessments on NPL sites). .
U.S. Environmental Protection Agency. Hazardous Waste Engineering Research
Laboratory. Proiect Summary: Practical Guide - Trial Bums for H::I7i1Tdous Waste
Incinerators (EP N600/S2-86/050), July 1986.

U.S. Environmental Protection Agency. Center for Environmental Research Information.
Handbook: Pennit Writer's Guide to Test Burn Data: Hazardous Waste Incineration
(EPN625/6-86/012), September 1986.
U.S. Environmental Protection Agency. Hazardous Waste Engineering Research
Laboratory. Systems to Accelerate in Situ Stabilization of Waste Deposits (EPA
540/2-86/(02), September 1986.

U.S. Environmental Protection Agency. Office of Emergency and Remedial Response.
Mobile Treatment Technoloeies for Superfund Wastes (EPA 540/2-861003 (f»,
September 1986.
50.
"Guidelines for the Health Risk Assessment of Chemical Mixtures," Federal Re~ster
(Vol. 51, No. 185), September 24, 1986.

U.S. Environmental Protection Agency. Office of Emergency and Remedial Response.
Superfund Public Health Evaluation Manual (EPA/540/1-86/060, OSWER Directive
9285.4-1), October 1986.
51.
U.S. Environmental Protection Agency. Office of Emergency and Remedial Response.
Draft Guidance on Remedial Actions for Contaminated Groundwater at Superfund Sites
(OSWER Directive 9283.1-2), October 1986.
52.
U.S. Environmental Protection Agency. Comprehensive Environmental Response.
Compensation. and Liability Act of 1980, as amended October 17, 1986.

U.S. Environmental Protection Agency. Office of Solid Waste and Emergency Response.
Test Methods for Evaluatine Solid Waste: Laboratoty Manual Physical/Chemical Methods.
Third Edition (Volumes IA. m. IC. and In (SW-846), November 1986.
53.
54.
"Hazardous Waste Management Systems; Land Disposal Restrictions; Final Rule,"
Federal Reeister (Vol. 51, No. 216), November 7, 1986.

U.S. Environmental Protection Agency. Office of Emergency and Remedial Response.
Superfund GlossaI)' (WH/FS-86-007), Winter 1986.
55.
56.
U.S. Environmental Protection Agency. Office of Emergency and Remedial Response.
Superfund Federal-Lead Remedial PrQject Manaeement Handbook (EPA/540/G-87/001,
OSWER Directive 9355.1-1), December 1986.
-------
62.
63.
64.
65.
66.
67.
68.
Page 39
57.
U.S. Environmental Protection Agency. Office of Emergency and Remedial Response.
Superfund State-Lead Remedial Proiect Manaiement Handbook, (EPA/540/G-87/002),
December 1986. .
58.
U .5. Environmental Protection Agency. Office of Ground-Water Protection. Guidelines
for Ground-Water Classification under the EP A Ground-Water Protection StrateeY,
December 1986.
59.
U.S. Environmental Protection Agency. Office of Solid Waste and Emergency Response.
Interim Guidance on Superfund Selection of Remedy (OSWER Directive 9355.0-19),
December 24, 1986.
60.
Memorandum from J. Winston Porter, U.S. Environmental Protection Agency Office of
Solid Waste and Emergency Response to Regional Administrators, Regions I-X; Regional
Counsels, Regions I-X, Director, Waste Management Division, Regions I, IV, V, vn, and
VllI; Director, Emergency and Remedial Response Division, Region n; Director,
Hazardous Waste Management Division, Regions ill and VI; Director, Toxics and Waste
Management Division, Region IX; Director, Hazardous and Waste Division. Region X;
Environmental Services Division Directors, Regions I. VI. and vn (OSWER Directive
9355.0-19), December 24, 1986 (discussing interim guidance on Superfund selection of
remedy).

U.S. Environmental Pro\ection Agency. Hazardous Waste Engineering Research
I..abaratory. Te.chnolo~y Briefs: Data Requirements for Selectin~ Remedial Action
Techno)0eY (EPA/600/2-87/001), January 1987.
61.
U.S. Environmental Protection Agency. Office of Solid Waste and Emergency Response.
Data Quality Objectives for Remedial Response Activities: Development Process
(EPA/540/G-871003, OSWER Directive 9355.0-7B), March 1987.
U.S. Environmental Protection Agency. Office of Waste Programs Enforcement. lata
Duality Obiectives for Remedial Response Activities - Example Scenario: RIfFS Activities
at a Site with Contaminated Soils and Groundwater (EPA/540/G-87/004, OSWER Directive
9355.0-7B), March 1987.
U.S. Environmental Protection Agency. Office of Solid Waste and Emergency Response.
Environmental Review ReQuirements for Removal Actions (OSWER Directive 9318.0-05).
April 13. 1987.

U.S. Environmental Protection Agency. Office of Water Regulations and Standards.
Quality Criteria for Water 1986 (EPA/440/5-861001), May 1, 1987.
Memorandum from J. Winston Porter, Assistant Administrator, U.S. Environmental
Protection Agency to Regional Administrators, Regions I-X (OSWER Directive
9285.4-02), May 14, 1987 (discussing fmal guidance for the coordination of A TSDR health
assessment activities with the Superfund remedial process).

Letter from Lee M. Thomas, U.S. Environmental Protection Agency 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 Superfund Amendments and Reauthorization Act of 1986).
U.S. Environmental Protection Agency. Quality Assurance Management Staff. Guidelines
and Specifications for Preparin& Quality Assurance Pro~m Documentation, June 1987.
-
.
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69.
70.
:J
71.
72.
73.
74.
75.
76.
77.
78.
79.
Page 40
U.S. Environmental Protection Agency. Office of Solid Waste and Emergency Response.
Alternate Concentration Limits Guidance (OSWER Directive 9481.00-6C,
EPA/530-SW-87-017), July 1987.
Memorandum from J. Winston Porter, U.S. Environmental Protection Agency Office of
Solid Waste and Emergency Response to Addressees ('Regional Administrators, Regions
I-X; Regional Counsel, Regions I-X; Director, Waste Management Division, Regions 1, IV,
V, VII, and VTII; Director, Emergency and Remedial Response Division, Region n;
Director, Hazardous Waste Management Division, Regions ill and VI; Director, Toxics and
Waste Management Division, Region IX; Director, Hazardous Waste Division, Region X;
Environmental Services Division Directors, Region I, VI, and VII") (OSWER Directive
9234.0-05), July 9, 1987 (discussing interim guidance on compliance with applicable or
relevant and appropriate requirements).

Memorandum from Henry L. Longest, U.S. Environmental Protection Agency Office of
Emergency and Remedial Response to Directors, Waste Management Division, Regions I,
IV, V, VI, VII, and VITI; Director, Emergency and Remedial Response Division, Region II;
Directors, Hazardous Waste Management Division, Regions III and X; Directors, Toxics
and Waste Management Division, Region IX (OSWER Directive 9355.0-20), July 23, 1987
(discussing RI/FS improvements).
U.S. Environmental Protection Agency. Environmental Research Laboratory. Role of
Acute Toxicity Bioassays in the Remedial Action Process at hazardous Waste Sites
(EPA/600/8-87/044), August 1, 1987.

Memorandum from Henry L. Longest, U.S. Environmental Protection Agency Office of
Emergency and Remedial Response and Gene Lucero, U.S. Environmental Protection
Agency Office of Waste Programs Enforcement to Waste Management Division Directors,
Regions I-X and Environmental Services Division Directors, Regions I, VI, and VII,
August 11, 1987, (discussing land disposal restrictions).
U.S. Environmental Protection Agency. Office of Emergency and Remedial Response.
Public 'Involvement in the Superfund Pro~m (WHIFS-87-004R), Fall 1987.

U.S. Environmental Protection Agency. Center for Environmental Research Information.
A Compendium ofTechnolo~ies Used in the Treatment of Hazardous Waste
(EPA/625/8-87/014), September 1987.
U.S. Environmental Protection Agency. Office of Research and Development and Office of
Solid Waste and Emergency Response. Remedial Action Costin& Procedures Manual,
October 1987.
U.S. Environmental Protection Agency. Office of Solid Waste and Emergency Response.
Office of Emergency and Remedial Response. Interim Final Guidance on Removal Action
Levels at Contaminated Drin1dn~ Water Sites (OSWER Directive 9360.1-01),
October 6, 1987.
Memorandum from J. Winston Porter, U.S. Environmental Protection Agency Office of
Solid Waste and Emergency Response to Regional Administrators, Region I-X (OSWER
Directive 9834.11), November 13, 1987 (discussing revised procedures for implementing
off-site response actions) with attached "Revised Procedures for Implementing Off-Site
Response Actions."

U.S. Environmental Protection Agency. Office of Emergency and Remedial Response.
A Compendium of Superfund Field Qperations Methods (OSWER Directive 9355.0-14),
December 1987.
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80.
81.
82.
83.
84.
85.
86.
87.
88.
89.
90.
91.
92.
Page 41
:
"Estimated Soil Ingestion Rates for Use in Risk Assessment," Risk Analysis
(Vol. 7. No.3), 1987.

U.S. 'Environmental Protection Agency. Office of Solid Waste and Emergency Response
and Office of Research and Development The Superfund Innovative TechnolQ~
Evaluation Prowam: Pro~ess and Accomplishments (EPA/540/5-88/001). February 1988.
U.S. Environmental Protection Agency. Office of Emergency and Remedial Response.
Superfund Removal Procedures - Revision Number Three (OSWER Directive
936O.0-03B). February 1988.
U.S. Environmental Protection Agency. Hazardous Evaluation Division. Laboratory Data
Validation Functional Guidelines for Evaluatin~ Or~anics, February 1. 1988.
U.S. Environmental Protection Agency. Office of Emergency and Remedial Response.
Draft Guidance on Remedial Actions fOT Contaminated GroundWater at Superfund Sites
(OSWER Directive 9283.1-2), April 1988.
U.S. Environmental Protection Agency. Office of Emergency and Remedial Response.
Superfund Exposure Assessment Manual (EPA/540/1-88/001, OSWER Directive
9285.5-1), April 1988.
Memorandum from Timothy Fields, Jr., U.S. Environmental Protection Agency Office of
Solid Waste and Emergency Response to Superfund Branch Chiefs. Regions I-X and OHM
Coordinators. Regions I-X. April 19. 1988 (discussing infonnation on drinking water
action levels).

Memorandum from Henry L. Longest, U.S. Environmental Protection Agency Office of
Emergency and Remedial Response to Directors. Waste Management Division, Regions I,
IV, V, and VI; Director, Emergency and Remedial Response Division. Region n; Directors.
Hazardous Waste Management Division. Regions ill and X; Directors, Toxics and Waste
Management Division, Region IX; Director, Environmental Services Division, Regions I-X
(OSWER Directive 9355.0-05), April 25. 1988 (discussing RI/FS improvements
follow-up).
U.S. Environmental Protection Agency. Office of Water. Interim Sediment Criteria Values
for Nonpolar Hydrophobic Orianic Contaminants (SCD #17). May 1988.

Memorandum fonn 1. Winston Porter, U.S. Environmental Protection Agency Office of
Solid Waste and Emergency Response to Regional Administrators, Regions I-X; Regional
Counsel, Regions I-X; Director, Waste Management Division, Regions I, IV, Y, VII, and
VllI; Director. Emergency and Remedial Response Division, Region TI; Director,
Hazardous Waste Management Division. Regions ill and VI; Director, Toxics and Waste
Management Division, Region IX; and Director, Hazardous and Waste Division. Region X
(OSWER Directive 9835.1a), May 16, 1988 (discussing interim guidance of potentially
responsible party participation in remedial investigations and feasibility studies).
U.S. Environmental Protection Agency. Office of Emergency and Remedial Response.
Community Relations in Superfund: A Handbook (Interim Version) (EPA/540/G-88/002,
OSWER Directive 9230.0-3A), June 1988.
U.S. Environmental Protection Agency. Office of Emergency and Remedial Response.
Catalo~ of Superfund Pro~m Directives (Interim Version) (OSWER Directive 9200.7-01),
July 1988.
U.S. Environmental Protection Agency. Hazardous Site Evaluation Division. Laboratory
Data Validation Functional Guidelines for Evaluatin~ InoT&anics. July I, 1988.
-
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93.
94.
~
95.
96.
97.
98.
99.
Page 42
u.s. Environmental Protection Agency. Office of Emergency and Remedial Response.
Draft Guidance on CERCLA (Comprehensive Environmental Response. Compensation.
and Liability Act) Compliance with Other Laws Manual (EPA/540/G-89/006,OSWER
Directive 9234.1-01), August 1988.

U.S. Environmental Protection Agency. Office of Emergency and Remedial Response.
Technolo~ Screenin~ Guide for Treatment of CERCLA (Comprehensive Environmental
Response~ Compensation. and Liability Act) Soils and Slud~es (EPA 540/2-88/004),
September 1988.
u.s. Environmental Protection Agency. Office of Emergency and Remedial Response.
Field Screenine Methods Cataloe: User's Guide (EPA/54O/2-88/005), September 1988.

Public Health Risk Evaluation Database (PHREn) User's Manual (two diskettes containing
the dBase lli+ system are included), September 16, 1988.
u.S. Environmental Protection Agency. Office of Emergency and Remedial Response.
~:erim Final Guidance on Conductin~ Remedial Investieations and Feasibility Studies
d~~ CERCLA (Comprehensive Environmental Response. Compensation. and Liability
&.t1 October 1988.
u.S. Environmental Protection Agency. Office of Emergency and Remedial Response.
Guidance for Conductin~ Remedial Investieations and Feasibility Studies Under CERCLA
(Comprehensive Environmental Response. Compensation. and Liability Act) (Interim Final)
(EPA/540/G-89/004, OSWER Directive 9355.3-01), October 1988.

U.S. Environmental Protection Agency. Office of Emergency and Remedial Response.
Superfund Removal ProiJ'3.m Policy Notebook - Volume 1, October 12, 1988.
100.
u.s. Environmental Protection Agency. Office of Emergency and Remedial Response.
Superfund Removal Prowam Policy Notebook - Volume 2, October 12, 1988.

U.S. Environmental Protection Agency. Office of Emergency and Remedial Response.
Community Relations in Superfund: A Handbook (Interim Version), Chapter 6 (OSWER
Directive 9230.0-3B), November 3, 1988.
101.
102.
u.S. Environmental Protection Agency. Office of Emergency and Remedial Response.
Guidance on Remedial Actions for Contaminated Ground Water at Superfund Sites
(EPA/540/G-88/003, OSWER Directive 9283.1-2), December 1988.
103.
u.S. Environmental Protection Agency. Office of Solid Waste and Emergency Response.
Hi&h Temperature Thermal Treatment for CERCLA (Comprehensive Environmental
R~Ponse. Compensation. and Liability Act) Waste: Evaluation and Selection of Onsite and
Offsite Systems (EPA 5401X-88/006), December 1988.

U.S. Environmental Protection Agency. Office of Emergency and Remedial Response.
User's Guide to the Contract Laboratoty Prowam (OSWER Directive 9240.0-1),
December 1988.
104.
105.
Memorandum from Don. R. Clay, Assistant Administrator, U.S. Environmental Protection
Agency Office of Solid Waste and Emergency Response to Waste Management Division
Directors, Regions I-X and Regional Counsel, Regions I-X (OSWER Directive 9234.1-06),
December 27, 1988 (discussing applicability of land disposal restrictions to RCRA and
CERCLA ground water treatment reinjection; Superfund management review:
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106.
107.
108.
109.
110.
111.
112.
113.
114.
115.
116.
117.
118.
Page 43
Interagency Cooperative Publication. Federal Manual for Identifyini and Delineatini
Jurisdictional Wetlands, January 1989.
U.S. Environmental Protection Agency. Risk Reduction Engineering Laboratory.
Technolo~ Evaluation R~rt SITE Pr0iTam Demonstration Test. HAZCON
Solidification. Douilassville. Pennsylvania. Volume I. (EPA/540/5-89-OOla),
February 1989.

Memorandum from Bruce M. Diamond, U.S. Environmental Protection Agency Office of
Waste Programs Enforcement et al. to Addressees ('Directors, Waste Management
Division, Regions I, IV, VII, VIII; Director, Emergency and Remedial Response Division,
Region ll; Directors, Hazardous Waste Management Division, Regions ill, VI; Director,
Toxic and Waste Management Division, Region IX; Director, Hazardous Waste Division,
Region X"), February 9, 1989 (discussing interim fmal guidance on soil ingestion rates).
Solarchem Environmental Systems. Ra,yox - The Advanced Water Decontamination
System, February 15, 1989.

U.S. Environmental Protection Agency. Risk Reduction Engineering Laboratory.
Technolo~ Evaluation R~rt: SaE..Pr0iTam Demonstration Test Terra Vac In Situ
Vacuum Extraction System Groveland. Massachusetts. Volume I (EPA/540/5-89/003a),
April 1989.
U.S. Environmental Protection Agency. Office of Solid Waste and Emergency Response.
A Guide on Remedial Actions for Contaminated Ground Water (OSWER Directive
9283.1-2FS), April 1989.
U.S. Environmental Protection Agency. Office of Research and Development
Requirements for Hazardous Waste Landfill Desiin. Construction. and Closure
(EPA/625/4-89/022), April 1989.
Memorandum from Jonathan Z. Cannon to Regional Administrators, Regions I-X (OSWER
Directive 9347.1-0), April 17, 1989 (discussing policy for Superfund compliance with the
RCRA land disposal restrictions). .

U.S. Environmental Protection Agency. Office of Solid Waste and Emergency Response.
ARARs Q's & A's (OERR 9234.2-01FS), May 1989.
U.S. Environmental Protection Agency. Office of Solid Waste and Emergency Response.
Land Disposal Restrictions: Summary of Requirements, June 1989.
U.S. Environmental Protection Agency. Risk Assessment Work Group, Region I.
Suwlemental Risk Assessment Guidance for the Superfund Prowam {Draft Final)
(EPA/901/S-89/001), June 1989.
Memorandum from Henry L. Longest, U.S. Environmental Protection Agency Office of
Emergency and Remedial Response to Directors, Waste Management Division, Regions I,
IV, V, VII, VIII et al. (OSWER Directive 9347.2-01), June 5, 1989 (discussing land
disposal restrictions as relevant and appropriate).

Memorandum from Henry L. Longest n and Gerald Emison, EP A Headquarters to
Addressees ('Regional Waste Management Division Directors; Regional Superfund Branch
Chiefs; Regional Air Division Directors; Regional Air Branch Chiefs; OERR Division
Directors; OAQPS Division Directors"), June 15, 1989 (discussing control of air emissions
from air strippers).
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.
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119.
v
120.
tJ
121.
122.
123.
124.
125.
126.
127.
128.
129.
130.
131.
132.
Page 44
U.S. Environmental Protection Agency. Office of Solid Waste and Emergency Response.
~und LDR Guide #2. Complyini With the California List Restrictions Under Land
Disposal Restrictions lLDRs) (OSWER Directive 9347.3-02FS), July 1989.

U.S. Environmental Protection Agency. Office of Solid Waste and Emergency Response.
Superfund LDR Guide #3. Treatment Standards and Minimum TechnoloiY ReQuirements
Under Land Disposal Restrictions (u)Rs) (OSWER Directive 9347.3-03FS), July 1989.
U.S. Environmental Protection Agency. Office of Solid Waste and Emergency Response.
Superfund LDR Guide #4. Complyini With the Hammer Restrictions Under Land Disposal
Restrictions lLDRs) (OSWER Directive: 9347.3-04FS), July 1989.

U.S. Environmental Protection Agency. Office of Solid Waste and Emergency Response.
Superfund LDR Guide #5. Determinini When Land Disposal Restrictions lLDRs) Are
Applicable to CERCLA Response Actions. (OSWER Directive: 9347.3-05FS), July 1989.
U.S. Environmental Protection Agency. Office of Solid Waste and Emergency Response.
Superfund LDR Guide #6A. Obtainini a Soil and Debris Treatability Variance for Remedial
Actions. (OSWER Directive: 9347.3-06FS), July 1989.
U.S. Environmental Protection Agency. Science Advisory Board. Evaluation ofthe
Apparent Effects Threshold (AET) Approach for Assessini Sediment Duality
(SAB-EETFC-89-027), July 1989.
U.S. Environmental Protection Agency. Office of Emergency and Remedial Response.
Interim Final Guidance on ~arin~ Superfund Decision Documents (OSWER Directive
9355.3-02), July 1989.
U.S. Environmental Protection Agency. Office of Solid Waste and Emergency Response.
Risk Assessment Guidance for Superfund Human Health Evaluation Manual Part A,
July 1989.
U.S. Environmental Protection Agency. Office of Research and Development. Technical
Guidance Document: Final Covers on Hazardous Waste Landfills and Surface
Impoundments (EPA/530-SW-89-047), July 1989.

U.S. Environmental Protection Agency. Office of Solid Waste and Emergency Response.
Superfund LDR Guide #1. Overview of RCRA Land Disposal Restrictions lLDRs)
(OSWER Directive 9347.3-01FS), July 1989.
"RCRA Regulations," Code of Federal Re~ulations (Title 40, Part 264), July 1989.

"Protection of Environment," Code of Federal Reiulations (Title 40, Parts 190-299),
Revised as of July 1, 1989.
"Land Disposal Restrictions for Certain 'California List' Hazardous Wastes and
Modifications to the Framework (Final Rule)," Federal Reeister (Vol. 52, No. 130),
July 8, 1989.
Memorandum from Louis F. Gitto, U.S. Environmental Protection Agency Air, Pesticides,
and Toxic Management Division, Region I to Menill S. Hohman, Waste Management
Division, Region I (OSWER Directive 9355.0-28), July 12, 1989 (discussing air stripper
control guidance).
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.
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133.
134.
135.
136.
137.
138.
139.
140.
141.
142.
143.
139.
145.
146.
Page 45
U.S. Environmental Protection Agency. Office of Solid Waste and Emergency Response.
CERCLA (CoIT\Prehensive Environmental Response. Compensation. and Liabi1i~ Act)
C~mpliance with Other Laws Manual - Part TI: Clean Air Act and Other Environmental
Statutes and State Requirements (EPA/540/G-89/009, OSWER Directive 9234.1-02),
August 1989.

U.S. Environmental Protection Agency. Office of Solid Waste and Emergency Response.
State and Local Involvement in the Superfund Pro~ (9375.5-01/FS), Fall 1989.
U.S. Environmental Protection Agency. Office of Emergency and Remedial Response.
Evaluation of Ground Water Extraction Remedies. Volume 1. Summary Report
(EPA/54012-89/054), September 1989.

U.S. Environmental Protection Agency. Office of Solid Waste and Emergency Response.
CERCLA Compliance with Other Laws Manual - RCRA ARARs: Focus and Closure
R~uirements (OSWER Directive 9234.2-04), October 1989.
U.S. Environmental Protection Agency. Office of Solid Waste and Emergency Response.
Detenninini Soil Response Action Level Based on Potential Contaminant Mi~tion to
Ground Water: A Con,pendium of Examples (EPA/540/2-89/057), October 1989.

U.S. Environmental Protection Agency. Office of Solid Waste and Emergency Response.
Ground Water Issue - Performance Evaluation of PurT\P-and- Treat Remediations
(EPA/540/4-89/005), October 1989.
Memorandum from Jonathan Z. Cannon, EP A Headquarters to Regional Directors,
October 18, 1989. (Discussing considerations in ground water remediation at
Superfund sites).

U.S. Environmental Protection Agency. Office of Solid Waste and Emergency Response.
The Superfund Innovative Technolo~y Evaluation Pro~am: Technolo~ ProfUes
(EPA/540/5-89/013), November 1989.
.'
U.S. Environmental Protection Agency. Office of Solid Waste and Emergency Response.
The Feasibi1i~ Study: Develo.pment and Screenin~ of Remedial Action Alternatives
(OSWER Directive 9355.3-01FS3), November 1989. .
U.S. Environmental Protection Agency. Office of Solid Waste and Emergency Response.
Gettin~ Ready Scopini the RIIFS (OSWER Directive 9355.3-01FS1), November 1989.

U.S. Environmental Protection Agency. Office of Solid Waste and Emergency Response.
The Remedial Investieation: Site Characterization and Treatabili~ Studies
(OSWER Directive 9355.3-01FS2), November 1989. .
U.S. Environmental Protection Agency. OSWER Directive Initiation Request Analysis of
Treatabili~ Data for Soil and Debris: Evaluation of Land Ban Impact on Use of Superfund
Treatment Technoloeies (OSWER Directive 9380.3-04), Nov~mber 30, 1989.

U.S. Environmental Protection Agency. Office of Emergency and Remedial Response.
Risk Assessment Guidance for Superfund - Volume I: Human Health Evaluation Manual
(part A - Interim Finan (EPA/540/1-89/002), December 1989.
U.S. Environmental Protection Agency. Office of Solid Waste and Emergency Response.
Superfund LDR Guide #1. Determinini When Land Disposal Restrictions fLDRs) are
Relevant and Appropriate to CERCLA Response Actions. (OSWER Directive
9347.3-08FS), December 1989.
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.
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147.
148.
149.
150.
151.
152.
153.
154.
155.
Page 46
u.s. Environmental Protection Agency. Office of Solid Waste and Emergency Response.
CERdA Compliance with Other Laws Manual - CERCLA COT11Pliance with State
RCQuirements (OSWER Directive 9234.2-05/FS), December 1989.

u.l Environmental Protection Agency. Office of Solid Waste and Emergency Response.
CERCLA Compliance with Other Laws Manual - Overview of ARARs - Focus on ARAR
Waivers (Publication 9234.2-03/FS), December 1989.
U.S. Environmental Protection Agency. Risk Reduction Engineering Laboratory.
TechnolQ~ Evaluation Report: SITE Pro~ Demonstration of the Ultrox International
lntraviolet Radiation/Oxidation Technolo~ (EPAl540/5-89/012), January 1990.

U.S. Environmental Protection Agency. Risk Reduction Engineering Laboratory.
Handbook on In Situ Treatment of Hazardous Waste-Contaminated Soils
(EPA/540/2-90/002), January 1990.
u.S. Environmental Protection Agency. Risk Engineering Laboratory. Proiect Summary -
State of Technolo~y Review: Soil Vapor Extraction Systems (EP A/600/S2-89/024),
January 1990.

U.S. Environmental Protection Agency. Office of Solid Waste and Emergency Response.
CERCLA Compliance with Other Laws Manual - CERCLA Compliance with the CW A and
SDW A (OSWER Directive 9234.2-06/FS), February 1990.
U.S. Environmental Protection Agency. Office of Solid Waste and Emergency Response.
The Feasibility Study: Detailed Analysis of Remedial Action Alternatives (OSWER
Directive 9355.3-01FS4), March 1990.
"National Oil and Hazardous Substances Pollution Contingency Plan; Final Rule," Federal
Re~ister (Vol. 55, No. 46), March 8, 1990, p. 8666.

"A Field Evaluation of the UV/Oxidation Technology to Treat Contaminated Groundwater,"
HMC.,,'MarchlAprilI990.
156.
U.S. Environmental Protection Agency. Office of Emergency and Remedial Response.
ROD Annual Report: FY 1989 (EP A/540/8-90/(06), April 1990.

U.S. Environmental Protection Agency. Office of Solid Waste and Emergency Response.
CERCLA Compliance with Other Laws Manual - Summary of Part n - CAA. TSCA. and
Other Statutes (OSWER Directive 9234.2-07/FS), April 1990.
157.
158.
"Control Technology: A Field Demonstration of the UV /Oxidation Technology to Treat
Groundwater Contaminated with VOCs," Journal of the Air & Waste Mana~ement
Association (Vol. 40, No.4), April 1990, pp. 54047.

U.S. Environmental Protection Agency. Office of Emergency and Remedial Response.
EPA Guide for Identifyin~ Cleanup Alternatives at Hazardous Waste Sites and Spills:
Biolo~ical Treatment (EP A/600/3-83/063).
159.
160.
U.S. Environmental Protection Agency. Office of Emergency and Remedial Response.
Personnel Protection and Safety.
161.
U.S. Environmental Protection Agency. Hazardous Waste Engineering Research
Laboratory. Evaluation of the B .E.S.T. Solvent Extraction Sludie Treatment TechnoIQ~:
Twenty-Four Hour Test (EPA/600/2-88/051).
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162.
163.
164.
165.
Page 47
U.S. EnvironmentaI Protection Agency. Risk Reduction Engineering Laboratory.
Incineration of a Chemically Contaminated Synthetic Soil Matrix (SSM) Usin~ a Pilot-Scale
Rotaty Kiln System.

U.S. EnvironmentaI Protection Agency. Impact of the RCRA Land Disposal Restrictions of
Superfund Response Actions in Superfund.
U.S. EnvironmentaI Protection Agency. Hazardous Waste Engineering Research
Laboratory. Application of Low-Temperature Thennal TechnolOi:Y to CERCLA
(Col11Prehensive Environmental RespOnse. Compensation. and Liability Act) S~ils.

U.S. Department of Health and Human Services. Agency for Toxic Substances and
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